AMTACApril 12th, 2011

Meredith KurpiusEPA R9

1

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

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 9 (1)R9 approves PQAO structure

AQS is not the official listCurrent 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

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.

QA Requirements Per PQAO

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

documents

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 Options1. Be part of a multi-agency PQAO2. Be a single-agency PQAO3. Remain outside the PQAO structure – only

and option for non-regulatory data that is not submitted to AQS.

PQAO Strategy DocumentR9 developed a PQAO Strategy Document to

implement the PQAO requirement in R9PQAO 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 DocumentJoining/formalizing a pre-existing PQAOForming a new PQAOWithdrawing from current PQAO

Joining vs. Formalizing Pre-existing PQAOFormalizing 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 PQAOSmaller 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)

Process to Join/Formalize a PQAORequest membership from the PQAO lead

organization – skip if formalizingChoose 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

Reasons to Withdraw from PQAOAn organization wants to join a different

PQAO or form its ownNote 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

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

Contact Information

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