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Quality Assurance Project PlansMelinda Ronca-Battista, ITEP

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What is a QAPPTool for project managers and planners to document type and quality of data needed for environmental decisionsDescribes methods for collecting and assessing dataIntegral part of fundamental principles and practices that form foundation of EPA Quality SystemRequired by EPA

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Why is a QAPP important?

EIs are the foundation of decisionsSets goals and objectivesRoad map of how to conduct EIProvides long-term guidanceMakes writing the EI report easier

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Formats of QAPPTEISS Inventory Preparation Plan (IPP) WizardQAPP Emission Inventory Improvement Plan (EIIP) Format

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IPP Wizard

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QAPPGroup A: Project Management

Group B: Data Generation and Acquisition

Group C: Assessment and Oversight

Group D: Data Validation and Usability

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Inventory Planning

Determine the Audience

Determine the Uses

Chose a Category Level

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Determine the UseAir quality program planningAssess contributions of future new sourcesAssess need for tribal permitting programSupport development of TIPSupport participation in regional AQ planning efforts

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Levels of EILevels of EILevel 1

Requires highest degree of defensibility Based on site-specific dataResults can be used directly in enforcement, compliance or litigation support if sufficient scope

Level 2 Used to directly support decision-making or standard settingCAA-SIP inventory or other national inventory developed to support numerous EPA regulatory requirementsSite- or region-specific information generally required

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Levels of EI (cont.)Levels of EI (cont.)Level 3

General assessment or researchSite-specific data may be gatheredDo not directly support rulemaking activities

Level 4Usually compiled from previously-published emissions dataNot intended to directly support rulemaking or compliance activities

From US EPA’s Emission Inventory Improvement Program (EIIP) Vol. 6, page 2.1-5

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Levels of EI (cont.)Level 4 EI – Gather Existing Data

Everyone should start by doing a Level 4 EICompile existing data from the National Emission Inventory (NEI).

Shows air pollution emitting facilities in your area. (Point sources)Identifies non-point sources that create most emissions in your area

If tribal lands already adequately covered by NEI/state inventory, level 4 is all you need to do!

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Levels of EI (cont.) After existing data is collected, decide which of two paths to take

Path 1 – Write Level 4 EI ReportPath 2 – Write a QAPP for a Level 3 or 2 EI

How do you know which path to take?

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Levels of EI (cont.)Do Level 4 report if land area is very small AND you don’t have sources

Write report summarizing what you foundWhich sources put out the most pollution?Which are closest to you?Which are upwind of you?What pollutants concern you the most?

This data is NOT submitted to NEI by tribe— unless you want to claim a portion of those emissions to be assigned to reservation

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Levels of EI (cont.)Do QAPP for Level 2 or 3 EI if

Your tribe’s land area is larger AND/OR you have sources on tribal land

List sources on tribal land for which you will estimate emissionsUse TEISS calculators to determine data you need to collect to estimate emissionsSummarize off-reservation data in separate section of report

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Scope of the InventoryDefine

Geographic area – include a map!Pollutants: Criteria and/or HAPsSource types – point, nonpoint, mobileTime period

Annual – state which yearSeasonal (e.g., Ozone season)

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Where to start?Sources on reservation

Existing inventories: Tribal, NEI, RPOTEISS Calculators

List sources on paperFind using calculator

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Exercise 1. Make a list of Point Sources on

your reservation2. Draw out organization chart3. Open up Calculator and look up

• Gas station with mini-mart• Asphalt batch plant• Plywood manufacture

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Point Source ListFacility Name Address Type of Source

Colville Indian Precision Pine

373 Omak Riverside-Eastside Road, Omak

Lumber Manufacturing, Title V Permit, Point Source

Colville Indian Plywood and Veneer

1100 Eighth Avenue East, Omak

Manufacturing Veneer, Plywood and Power, Title V Permit, Point Source

Atlas Pellets 325 Omak Riverside-Eastside Road, Omak

Manufacture Wood Pellets for Stoves

Granite Northwest Inc.

249-B Rodeo Trail Road, Okanogan

Asphalt Production and Paving

Coulee Dam Concrete

26 Canyon Street, Elmer City

Ready Mix Concrete, Sand and Gravel

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Organization Chart

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TEISS CalculatorGas station with mini-martAsphalt Batch PlantPlywood manufacturer

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Planning WorkEstablish staff and resource requirements, scheduleIdentify partners and develop communication plan Industry Agencies Community groups

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Quality Assurance PlanQA CoordinatorData Quality Objectives (DQOs)Inventory implementation timeline

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Data Management and Reporting

Describe how data will be storedIn TEISSPaper and electronic filing system

Data collection and calculations on paperCalculations done in spreadsheets

Final Products of EICompleted TEISS project – has ALL the detailsPaper report – gives general details, summarizes resultsPresentation – summarizes results

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ExerciseLook at Section 8.0 of the Example Tribal EI QAPP handoutUse TEISS calculators to write out estimation method you’ll use and data you’ll need to collect for one of your reservation’s nonpoint sources

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Boring – Questionable

Useful – Positively