EPA Region 9Meredith KurpiusAugust 19, 2010

Status of Tribal Air MonitoringValue of tribal monitoring

Used to protect public health on tribal landFills in gaps in ambient air monitoring

Can be for informational purposes (e.g., smoke alerts) or regulatory purposes (NAAQS decisions)

Sometimes there is a question if Tribal data is of sufficient quality for NAAQS decisions, based on limited information about audits and QC checks that may be missed by Tribes, due to funding limits or misunderstandings of the requirements.

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)

PQAO DefinitionEach 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.

Current PQAOs in Region 9R9 approves PQAO structureNo tribes are currently part of a PQAOCurrent 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

Note: Being part of a PQAO is a requirement to collect data for regulatory purposes

Summary of QA RequirementsPQAO with Independent Quality AssuranceApproved Quality Planning Documents (QMP, QAPPs, &

SOPs)Approved Network Design PlanMonitoring sites that are unobstructed and meet siting

requirementsApproved FRM/FEM instrumentsMeet 75% completenessCalibrate all equipment and standards (quarterly to annually)Quality control checks (daily to monthly)Perform audits (quarterly to semi-annually)Co-locationPEP/NPAP auditsTechnical System AuditsData reported to AQS quarterlyData certified annuallyQA goals for bias and precision met

QA Barriers for Tribes

Example: of NPAP/PEP cost savings with Federal implementation

NPAP- $2200/audit20% of sites in PQAO audited Would need 8 sites for 2 audits a year.

PEP- $2000/audit5 audits for PQAO with < 5 sites = 10K/year8 audits for PQAO with >5 sites = 16K/year

Total Savings: $34,400

PQAO Options for Tribes1. Join a pre-existing state/local PQAO2. Create a multi-tribe PQAO3. Create a tribe-state/local PQAO4. Create a single-tribe PQAO5. Remain outside the PQAO structure – only

and option for non-regulatory data.

Benefits to Being Part of a PQAOQA requirements can be effectively reduced if

multiple organizations work as one PQAOCost savings: reduced audits and co-locationOpportunities for cooperationData consistencyOpportunities to share expertiseStandardizes formal documentation

Greater consistencyReduced workload in creation and review of QA

documentsFormalizes what Tribes may already be doing

Process to Join a PQAORequest membership from the PQAO lead

organizationChoose pollutantsOutline funding mechanism to access EPA

auditsAssess common factors with existing PQAOEstablish how requirements for QA

documentation will be metPrepare Memorandum of Agreement (MOA)Request approval from EPA Region 9 for

addition/confirmation of new member to PQAO

Reasons to Create New PQAOAn 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 requirementsPEP/NPAP auditstechnical system auditsCo-locationPrecision/accuracy, etc.

Process to Form a New PQAOIdentify the PQAO lead organizationChoose pollutantsArrange and outline funding mechanism to

access EPA auditsDocument how PQAO requirements will be metPrepare a Memorandum of Agreement, if there

are multiple organizations forming the new PQAO

Request approval from EPA Region 9 to form new PQAO

Consequences of not Forming PQAOs• Tribes will continue to spend disproportionate

resources to meet QA requirements• Tribes may have trouble meeting QA/QC

requirements• The amount of funding needed to perform NPAP

and PEP audits may prevent Tribes from collecting data for NAAQS comparison.

• EPA may not be able to meet the required TSA frequencies.

• Tribes will have to defend independently collected data when Tribal decisions/data are contested

• Data may not be used for regulatory decisions!!!

Current StatusRegion 9 is finalizing the PQAO Strategy

DocumentTribes will be able to join/form PQAOs

following the PQAO StrategyEPA Region 9 will work with all tribes

collecting air monitoring data to determine the most sensible PQAO structure

PQAO status will be reflected in future grant agreements

Contact Information

Meredith KurpiusKurpius.meredith@epa.gov415-947-4534