Do You Need A Quality Assurance Performance Plan (QAPP)?

The proposed Mandatory Greenhouse Gas (GHG) Reporting Rule  (40 CFR Part 98) issued in March 2009 would require the economy-wide reporting of emissions data from facilities or sources that emit 25,000 metric tons or more per year of GHG emissions.  40 CFR §98.3(g)(11) proposes that sources develop and maintain a written Quality Assurance Performance Plan (QAPP) that describes the procedures for maintenance, repair, calibration, and other quality assurance (QA) activities for all continuous monitoring systems, flow meters, and other instrumentation used to provide data for the GHG emissions reported.  The QAPP would serve as a road map for collecting valid monitoring data.  Specifically, the QAPP should document the procedures involved with the acquisition of emissions data and operating information. Aggressive planning for data collection and maintenance activities will allow for early detection of problems and will increase the effectiveness and efficiency of a data management program.  A QAPP should be completed and submitted for review and approval before the data collection project is initiated.  Although the approved QAPP must be implemented as prescribed, it should be flexible as changes to original plans are often needed.  The QAPP should be a “living document” that is reviewed frequently and updated according to facility needs and operations.  Significant steps toward developing a QAPP include: 

• Assessing what needs to be done based on what is known about the site and regulatory requirements.
• Assembling a project team with the necessary expertise.
• Determining the actions needed to obtain relevant and accurate data to support the project.
• Writing the QAPP.
• Submitting the QAPP for review and approval. 
• Implementing the QAPP.

U.S. EPA has proposed that data collection for GHG reporting begin for the calendar year 2010, with reports due in 2011.  This would require sources to develop and implement a QAPP prior to December 31, 2009.