Primary Quality Assurance Organization Structure in Region 9

1. Primary Quality Assurance Organization Structure in Region 9 AMTAC April 12th, 2011 Meredith Kurpius EPA R9 1

2. What is a PQAO? • PQAO: Primary Quality Assurance Organization • “A monitoring organization or a coordinated aggregation of such organizations that is responsible for a set of stations that monitors the same pollutant(s) and for which data quality assessments can logically be pooled.” • Developed as part of monitoring regulations in 2006 • 40 CFR 58 Appendix A (Quality Assurance section) • Note: Being part of a PQAO is a requirement to collect data for regulatory purposes

3. PQAO Definition Each primary quality assurance organization shall be defined such that measurement uncertainty among all stations in the organization can be expected to be reasonably homogeneous, as a result of common factors. Common factors that should be considered by monitoring organizations in defining primary quality assurance organizations include: (a) Operation by a common team of field operators according to a common set of procedures; (b) Use of a common QAPP or standard operating procedures; (c) Common calibration facilities and standards; (d) Oversight by a common quality assurance organization; and (e) Support by a common management, laboratory or headquarters.

4. Current PQAOs in Region 9 (1) • R9 approves PQAO structure • AQS is not the official list • Current State/Local PQAOs • Washoe County Health District • Nevada Division of Environmental Protection • Clark County Department of Air Quality and Environmental Management • San Diego County Air Pollution Control District • South Coast Air Quality Management District • California Air Resources Board • Bay Area Air Quality Management District • Hawaii Department of Health • Arizona Department of Environmental Quality • Pima County Department of Environmental Quality • Maricopa County Air Quality Department • State/local agencies not listed as their own PQAO are part of their state monitoring agency’s PQAO

5. Current PQAOs in Region 9 (2) • Tribes: As a default, all tribes that collect air monitoring data have been designated as their own PQAO • Non-state/local/tribal agencies: Other PQAOs (e.g., R9 Superfund, private facilities, etc.) will be considered case-by-case.

6. QA Requirements Per PQAO • Many air monitoring regulations apply to the PQAO • Independent standards and audits • Co-located monitoring • EPA’s performance monitoring programs NPAP & PEP • Personnel that are independent from the site operator to conduct independent reviews of the data • Quality Management Documents: QAPPs, SOPs, QMPs • For small organizations this means that a significant percentage of monitoring funds are allocated to meeting these requirements

7. Benefits to Being Part of a PQAO • QA requirements can be effectively reduced if multiple organizations work as one PQAO • Cost savings: reduced audits and co-location • Opportunities for cooperation • Data consistency • Opportunities to share expertise • Standardizes formal documentation • Greater consistency • Reduced workload in creation and review of QA documents

8. Example: of NPAP/PEP cost savings with Federal implementation • NPAP- $2200/audit • 20% of sites in PQAO audited • Would need 8 sites for 2 audits a year. • PEP- $2000/audit • 5 audits for PQAO with < 5 sites = 10K/year • 8 audits for PQAO with >5 sites = 16K/year Total Savings: $34,400

9. PQAO Options • Be part of a multi-agency PQAO • Be a single-agency PQAO • Remain outside the PQAO structure – only and option for non-regulatory data that is not submitted to AQS.

10. PQAO Strategy Document • R9 developed a PQAO Strategy Document to implement the PQAO requirement in R9 • PQAO Strategy Document provides background on the PQAO requirement and describes the process to establish the PQAO structure in R9 • The following procedures are specifically outlined in the PQAO Strategy Document • Joining/formalizing a pre-existing PQAO • Forming a new PQAO • Withdrawing from current PQAO

11. Joining vs. Formalizing Pre-existing PQAO • Formalizing a PQAO • PQAOs exist in R9 that are comprised of multiple state/local air monitoring organizations (e.g., CARB, ADEQ) • These PQAOs are already established – doing nothing maintains the status quo • Formalizing this relationship does not change structure but establishes roles, responsibilities and expectations • Joining a PQAO • Smaller organizations may seek to join a PQAO that it is currently not a member of (e.g., a tribe may wish to join the PQAO of a large nearby air monitoring district or another tribe)

12. Process to Join/Formalize a PQAO • Request membership from the PQAO lead organization – skip if formalizing • Choose pollutants • Outline funding mechanism to access EPA audits • Assess common factors with existing PQAO • Establish how requirements for QA documentation will be met • Prepare Memorandum of Agreement (MOA) • Request approval from EPA Region 9 for addition/confirmation of new member to PQAO

13. Reasons to Create New PQAO • An organization is not part of a PQAO and there is no pre-existing PQAO that share common factors. • Note that a PQAO must be able to meet ALL QA requirements • PEP/NPAP audits • technical system audits • Co-location • Precision/accuracy, etc.

14. Process to Form a New PQAO • Identify the PQAO lead organization • Choose pollutants • Arrange and outline funding mechanism to access EPA audits • Document how PQAO requirements will be met • Prepare a Memorandum of Agreement, if there are multiple organizations forming the new PQAO • Request approval from EPA Region 9 to form new PQAO

15. Reasons to Withdraw from PQAO • An organization wants to join a different PQAO or form its own • Note that organizations collecting data for regulatory purposes must be part of a PQAO … • therefore an organization can’t withdraw from a PQAO until approval has been granted to form or join a different PQAO

16. Process to Withdraw from PQAO • Obtain official approval for admittance into a different PQAO or formation of a new PQAO • Obtain approval to withdraw from current PQAO • Transition to new PQAO

17. Contact Information • Meredith Kurpius • Kurpius.meredith@epa.gov • 415-947-4534