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.
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
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