17

Technical System Audit Report

South Coast Air Quality Management District

April 13 – April 16, 2010

Conducted by

Air Quality Analysis Office Quality Assurance Office

Air Division Management and Technical Services Division

US EPA Region 9

75 Hawthorne Street

San Francisco, California 94105

March 2011
SCAQMD TSA Report: March 2011

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CONTENTS

PAGE

GLOSSARY OF ACRONYMS.........................................................................3

EXECUTIVE SUMMARY................................................................................4

INTRODUCTION............................................................................................ .6

A. GENERAL PROGRAM...............................................................................8

B. NETWORK MANAGEMENT.....................................................................14

C. FIELD OPERATIONS..................................................................................17

D. LABORATORY OPERATIONS................................................................. 20

E. DATA AND DATA MANAGEMENT........................................................22

F. QUALITY MANAGEMENT........................................................................23

APPENDIX A: Summary of Findings...................................................25

APPENDIX B: Additional Recommendations...... ..................................27 

APPENDIX C: Final Report of NATTS Program Review by RTI...............27 
SCAQMD TSA Report: March 2011

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GLOSSARY OF ACRONYMS 

AQS...................................... Air Quality System

AQIS..................................... Air Quality Instrument Specialist

BAM..................................... Beta Attenuation Monitor

CA........................................ California

CARB................................... California Air Resources Board

CO........................................ Carbon Monoxide

CFR...................................... Code of Federal Regulations

EMS............................ Electronic Management System

EPA................................... United States Environmental Protection Agency

FEM...................................... Federal Equivalent Method

FID........................................ Flame Ionization Detector

FRM...................................... Federal Reference Method

GC........................................ Gas Chromatograph (Gas Chromatography)

ICP-MS.......................... Inductively Coupled Plasma- Mass Spectroscopy

IO.................................Inorganic Compendium

MATES.......................... Multiple Air Toxics Exposure Study

MDL..................................... Method Detection Limit

MS........................................ Mass Spectrometer

MSD...................................... Mass Selective Detector

NAAQS................................ National Ambient Air Quality Standard

NATTS................................. National Air Toxics Trends Stations

NCore.................................. National Core multipollutant monitoring stations 

NIST............................ National Institute for Standards and Technology

NOx/NOy............................. Nitrogen Oxides 

O3.......................................... Ozone

ORD............................. Office of Research and Development

PAMS................................... Photochemical Assessment Monitoring Stations

Pb........................................ Lead

PE........................................ Performance Evaluation

POC...................................... Parameter Occurrence Code

PM........................................ Particulate matter

PM2.5..................................... Particulate matter 2.5 microns or less in aerodynamic diameter

PM10...................................... Particulate matter 10 microns or less in aerodynamic diameter

PQAO................................... Primary Quality Assurance Organization

QA........................................ Quality Assurance

QC........................................ Quality Control 

QAPP................................... Quality Assurance Project Plan

QMP............................ Quality Management Plan

RTI....................................... Research Triangle Institute (EPA Contractor)

SCAQMD............................ South Coast Air Quality Management District

SPM..................................... Special Purpose Monitor

SOP...................................... Standard Operating Procedure

SLAMS................................ State or Local Air Monitoring Station

SO2....................................... Sulfur Dioxide
SCAQMD TSA Report: March 2011

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SRP............................. Standard Reference Photometer 

STN............................. Speciation Trends Network

STP....................................... Standard Temperature and Pressure

TAD..............................Technical Assistance Document

TEOM................................... Tapered Element Oscillating Microbalance

TO................................ Toxic Organic Compendium

TSA...................................... Technical System Audit

TSP....................................... Total Suspended Particles

XRF...................................... X-ray Fluorescence 
SCAQMD TSA Report: March 2011

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EXECUTIVE SUMMARY

This report documents the findings made by the US Environmental Protection Agency 

(EPA) Region 9 during its Technical System Audit (TSA) of the South Coast Air Quality 

Management District (SCAQMD) ambient air monitoring program. A TSA is an on-site review 

and inspection of a state or local ambient air monitoring program to assess its compliance with 

established regulations governing the collection, analysis, validation, and reporting of ambient 

air quality measurement data. This TSA meets the requirements for EPA Region 9 audits of the 

SCAQMD monitoring organization required by 40 CFR Part 58, Appendix A, Section 2.5.

The TSA was conducted by EPA Region 9 staff from April 13 – April 16, 2010. The 

audit team interviewed management and staff on specific aspects of the air monitoring program 

including network design, field operations, laboratory operations, data handling, quality

assurance and quality control procedures. The audit team also inspected a number of monitoring 

sites and visited several additional monitoring sites. The site inspections consisted of 

interviewing the site operator, reviewing station and instrument logbooks, and evaluating the 

station siting with respect to EPA requirements for probe siting1. 

The TSA is one of the ways EPA oversees data collection activities performed by state 

and local agencies to ensure they meet certain minimum data quality objectives. Other 

assessments, such as network reviews and performance evaluations, are also used to collect 

information on the overall quality of ambient air monitoring data. These assessments enable 

agencies to identify and correct program elements which may be adversely affecting the quality 

of ambient air data. 

The results of the TSA are summarized below and discussed in more detail in the specific 

sections of this report. Recommendations for addressing each of the findings are provided. The 

specific actions taken by SCAQMD to address the findings should be approved by EPA and 

documented by SCAQMD in a corrective action plan. 

EPA would like to thank all the staff and management of SCAQMD for their support and 

cooperation during the audit.

Program Strengths:

Overall, SCAQMD staff was very professional and helpful.

SCAQMD site operators were very competent (e.g., the Rubidoux operator is 

exceptionally knowledgeable and documents station operations thoroughly and 

consistently.

 

1 40 CFR, Part 58, Appendix E, “Probe and Monitoring Path Siting Criteria for Ambient 

Air Quality Monitoring”
SCAQMD TSA Report: March 2011

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Since the last audit in 2007, SCAQMD has initiated a process to put a Quality 

Management program in place.

Instrument down time has decreased significantly since the last audit. This is due in part 

to decreased repair and calibration response times.

The senior field technicians have implemented systems to document instrument down 

time on forms and to review results from the electronic data loggers that have improved 

data quality. Logbooks are well maintained at the monitoring sites.

The Particulate Matter (PM)2.5 laboratory is well organized and the electronic data 

handling system for the information gathered in the laboratory is well designed and 

comprehensive. 

Program Findings:

While acknowledging the strengths of SCAQMD’s monitoring program, EPA identified 

several program elements that could be improved. Specifically: 

While significant improvement has been made to put the QA system in place, the lack of 

completed, finalized, and approved QAPPs and SOPs is an outstanding concern. 

Documentation produced by the monitoring, quality, and laboratory systems generally is 

good. However, several areas do not produce records that are fully reproducible and 

defensible.

Several areas were identified where staffing and/or equipment limitations affected the 

quality of data being produced. Additionally, there is a need to plan for a shift in staff to 

accommodate future changes to the monitoring program.

The laboratory has improved its quality assurance oversight program. However, this 

program needs to be refined further to ensure consistency in implementation of laboratory 

quality systems and procedures.

Quarterly data entry to AQS and annual data certification were not completed on time.

In addition to these significant findings, EPA has identified other priority findings and 

made good practice recommendations. The individual findings are reported in the topic sections 

of this document and are summarized in Appendix A and good practice recommendations are 

included in Appendix B. 
SCAQMD TSA Report: March 2011

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INTRODUCTION

 The SCAQMD is the government agency to which EPA delegated the authority and 

responsibility for collecting ambient air quality data pursuant to the Clean Air Act of 1977 and 

the Clean Air Act Amendments of 1990. 

From April 13 through April 16, 2010, the Region 9 Air Quality Analysis Office and the 

Region 9 Quality Assurance Office conducted a Technical System Audit (TSA) of SCAQMD’s 

ambient air monitoring program. The TSA covered the following program areas:

General / Quality Management

o Program Organization

o Facilities

o Independent Quality Assurance and Quality Control

o Planning Documents (including QMP, QAPPs, & SOPs)

o General Documentation Policies

o Training

o Corrective Action

o Quality Improvement

o External Performance Audits

Network Management / Field Operations

o Network Design

o Changes to the Network since the last audit

o Proposed changes to the Network

o Field Support

 SOPs

 Instrument Acceptance

 Calibration

 Repair

 Site and Monitor Information Form

Laboratory Operations

o Routine Operations

o Quality Control

o Laboratory Preventive Maintenance

o Laboratory Record Keeping

o Laboratory Data Acquisition and Handling

o Specific Pollutants: PM10, PM2.5, Toxics, PAMS, and Lead

Data and Data Management

o Data Handling

o Software Documentation

o Data Validation and Correction

o Data Processing

o Internal Reporting

o External Reporting 

EPA also tracked supporting documentation for data points/sets from calendar years 2008 

and 2009.
SCAQMD TSA Report: March 2011

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Participating SCAQMD managers, supervisors and staff included:

Chung Liu, Deputy Executive Officer, Science & Technology

Rudy Eden, Manager, Laboratory

Solomon Teffera, Pr. Chemist, Laboratory

Steve Barbosa, Pr. Chemist, Laboratory

Dan Houghton, Sr. Chemist, Laboratory

Tai-Ching Hu, Sr. Chemist, Laboratory

Sandra Hom, Sr. Chemist, Laboratory

Wimol Chanjamsri, Chemist, Laboratory

Ken Sanchez, Chemist, Laboratory

Yang Song, Chemist, Laboratory

Jason Low, Manager, Quality Assurance

Raul Dominguez, Sr. Chemist, Quality Assurance

Mike Hamdan, Sr. Instrument Specialist, Quality Assurance

Philip Fine, Manager, Monitoring

Rene Bermudez, Pr. Instrument Specialist, Monitoring

David Sawyer, Pr. Instrument Specialist, Monitoring

Summer Wilson, Pr. Instrument Specialist, Monitoring

Albert Dietrich, Sr. Instrument Specialist, Monitoring

Paul Chavez, Sr. Instrument Specialist, Monitoring

Claudius Phipps, Sr. Instrument Specialist, Monitoring

Donald Jacobs, Sr. Instrument Specialist, Monitoring

Mike Koch, Sr. Instrument Specialist, Monitoring

Keith Brown, Sr. Instrument Specialist, Monitoring

Brian Vlasich, Sr. Instrument Specialist, Monitoring

Jorge Diez, Instrument Specialist, Monitoring

David Carillo, Instrument Specialist, Monitoring

Terry Corcoran, Instrument Specialist, Monitoring

Brian Speaks, Instrument Specialist, Monitoring

Norman Broellos, Instrument Specialist, Monitoring

Tuong Mac, Instrument Specialist, Monitoring

Robert Wimmer, Instrument Specialist, Monitoring

Cirila Enriquez, Instrument Specialist, Monitoring

Twyla Miner, Instrument Specialist, Monitoring

Jeff Barenwald, Instrument Specialist, Monitoring

Richard Rodgers, Instrument Specialist, Monitoring

Leonard Edwards, Data Translator, Monitoring

Hanna Zhuang, Data Translator, Monitoring

Kevin Durkee, Sr. Meteorologist, Planning

This report is divided into eleven sections. The first section is an executive summary that 

describes the purpose of the TSA and a summary of the most significant findings. The following 
SCAQMD TSA Report: March 2011

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section provides a brief description of the SCAQMD air monitoring program, identifies 

participating SCAQMD personnel and the EPA audit team, and describes the report’s 

organization. The third section discusses the general/significant findings. The next five sections 

address specific aspects of the air monitoring program: network management, field operations, 

laboratory operations, data management and quality assurance/quality control. Appendix A lists 

the findings contained in this report. Appendix B includes minor concerns and recommendations 

for SCAQMD to consider. Appendix C includes final comments from a concurrent review of the 

SCAQMD NATTS program by EPA’s RTI contractor. Recommendations for each finding are 

provided to give some indication of EPA Region 9’s expectations as to how findings can be 

addressed. If the SCAQMD has other approaches or alternatives to address the concerns 

identified, the Region will consider them, provided the corrective action adequately addresses the 

finding. 
SCAQMD TSA Report: March 2011

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A. GENERAL PROGRAM

Federal and State of California laws require that clean air standards be met and 

maintained throughout the country and the State of California. An ambient monitoring program 

is essential to verifying compliance with these standards. The SCAQMD is defined in the 

California Health and Safety Code, Division 26, Air Resources, Section 40412 as the “Sole and 

exclusive agent having responsibility for air pollution control within the District.” The State 

defines the geographic extent of SCAQMD as “portions of Counties of Los Angeles, Orange, 

Riverside, and San Bernardino included within the area of the South Coast Air Basin, as 

described in Section 60104 of the Title 17 of the California Administrative Code.” This area is 

home to over 16 million people, nearly half the population of the State of California, making it 

the second most populated urban area in the United States. The area covered by the SCAQMD 

has historically experienced some of the highest air pollution in country. 

A Governing Board that adopts policies and regulations that promote clean air within the 

District’s jurisdiction oversees SCAQMD. The Governing Board has thirteen members, of 

which ten are local elected officials and three are state appointed. 

SCAQMD currently has 34 active monitoring stations for criteria pollutants. The 

pollutants measured include:

Carbon Monoxide

Nitrogen Dioxide

Sulfur Dioxide

Lead

Ozone

Particulate Matter (PM10 and PM2.5)

The Executive Officer of SCAQMD is, Barry Wallerstein. Chung Liu, Deputy Executive 

Officer, heads the Science & Technology Advancement Division. The Monitoring & Analysis

sub-Division is the primary organization in Science & Technology Advancement responsible for 

air monitoring. The Monitoring and Analysis group has three functional areas: Laboratory 

Services & Source Test Engineering (Rudy Eden, manager), Atmospheric Measurements (Philip 

Fine, manager), and Quality Assurance (Jason Low, manager).

Atmospheric Measurements (Monitoring), Laboratory Services & Source Test 

Engineering (Laboratory), and Quality Assurance (QA) each have a role in the collection and 

evaluation of ambient air data as defined by the SCAQMD Quality Management Plan (QMP). 

The Monitoring group is responsible for most of the ambient air data collection, including 

sampling and data processing of continuous air monitors. The Laboratory is responsible for 

preparation of sampling media, analysis of analytical samples from the non-continuous monitors, 

and processing of data for these samples analyzed by the laboratory. Both groups are responsible 

for implementing routine quality assurance and quality control (QA/QC) procedures. The QA 

group is responsible for tracking and oversight of training, corrective actions, and data handling. 
SCAQMD TSA Report: March 2011

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The QA group also implements performance and technical audits and coordinates and 

participates in the preparation of QA planning documents.

Overall, the monitoring program at SCAQMD is well executed, having taken a number of 

corrective actions since the last EPA TSA in 2007. Quality management functions are formally 

integrated into the program and in most areas are well documented. EPA noted an improvement 

in the quality and quantity of data SCAQMD entered into the AQS system over the past several 

years. However, there are still some significant issues that need to be addressed. The most 

significant findings are discussed below. Other priority findings follow in subsequent sections, 

while good practice recommendations are included as a courtesy in Appendix B.

FINDING A1:

SCAQMD’s Quality Assurance program documentation, including most Quality Assurance 

Project Plans (QAPPs) and Standard Operating Procedures (SOPs), was not complete and was 

not approved by EPA at the time of the audit. 

Discussion:

EPA requires that organizations develop a QAPP for each type of ambient pollutant being 

measured. The QAPP integrates all technical and quality aspects of a project, including 

planning, implementation, and assessment. The purpose of the QAPP is to document 

planning results for environmental data operations and to provide a project-specific 

“blueprint” for obtaining the type and quality of environmental data needed for a specific 

decision or use. 

The QAPP documents the quality assurance and quality control that are applied to an 

environmental data operation to assure the results obtained are of the type and quality 

needed and expected. Further guidance on developing QAPPs can be found in the 

guidance documents “EPA Requirements for Quality Assurance Project Plans,” 

EPA/240/B-01/003, March 2001, and “Guidance for Quality Assurance Project Plans,” 

EPA/240/R-02/009, December 2002. 

Most major SOPs were completed, tracked and finalized with internal review and 

signatures. SCAQMD had draft versions of quality assurance documentation available to 

staff and the auditors for many of the air monitoring programs and procedures. While 

these updated documents have not been approved by EPA, the fact that staff and 

management worked together on SOP development helps to ensure consistent and 

complete implementation of the monitoring program. There were some SOPs that were 

not updated or completed, for example:

An SOP reflecting current laboratory practice was not available to the auditors. 

According to initial staff responses while on-site, significant deviations to the TO15 method had been made, and because there was no SOP available, it was 

difficult to evaluate the effects of the deviations. 
SCAQMD TSA Report: March 2011

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 Recommendation:

SCAQMD should work with EPA Region 9 to develop approved QA planning 

documents.

FINDING A2:

In several operational areas, official records were not available or were stored in a manner that 

did not ensure their reproducibility. 

Discussion:

EPA Region 9 Laboratory Documentation Required for Data Evaluation, August 2001 

notes that:

In order for data to be used for decision-making purposes, it is essential that it be 

of known and documented quality. Verification and validation of data requires 

that appropriate quality assurance and quality control (QA/QC) procedures be 

followed, and that adequate documentation be included for all data generated 

both in the laboratory and in the field.

Most air monitoring and support tasks included sufficient, complete documentation such 

that the work performed could be verified and validated. However, reviews of 

documentation in several areas highlighted the need for a consistent policy to produce 

data that support analytical results. Specifically in the QA Audit Laboratory and 

Monitoring Calibration Laboratory, EPA found that:

Not all records were readily accessible

Electronic records are not maintained in a manner that prevents

modification

There is no system in place to back up some electronic records 

Some forms are not consistent for different calibrations and some lack 

space to document pertinent information

Required information is not always recorded

Recording errors were found that should have been corrected by the 

primary technician, by the peer reviewer, or during management review 

These deficiencies in organizationally separate areas of SCAQMD indicate the need to 

evaluate all monitoring program documentation procedures.

 Recommendation:

SCAQMD should review documentation practices in all operational areas, develop a QA 

policy for producing and archiving documentation, and implement improvements. 

FINDING A3:

Limited staffing in several key areas is significantly impacting monitoring program performance 

and quality.

 
SCAQMD TSA Report: March 2011

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Discussion:

EPA observed deficiencies in data validation and reporting (Finding A5), QA audits 

(Finding F1), QA management (Findings A1 & A3), and laboratory operations (D5) that 

are directly related to the lack of sufficient resources. Additionally, it was observed that:

The PAMS Department appeared to be close to its capacity to handle the sample 

load as indicated by the fact that there was not enough time to analyze sample 

duplicates as a quality control measure during the PAMS season due to the 

quantity of PAMS samples taken in 2009. During the Laboratory TSA debrief 

meeting, SCAQMD management concurred that the PAMS department was 

nearing capacity.

New monitoring requirements may necessitate a shift in how the resources within 

the monitoring, lab and QA groups are allocated.

The QA Manager has a small staff, which limits his ability to shift staff to respond 

to current needs (e.g., ensure field audits are conducted at required frequency and 

are appropriately documented and ensuring validation has sufficient staff and 

resources). 

 

Capacity issues arising from staffing shortages can compromise quality; over scheduling 

staff time can increase opportunities for introducing error. 

 Recommendation:

SCAQMD should evaluate current and long-term staffing needs to ensure that core tasks 

are being accomplished in a timely manner and with reliable and appropriate quality. 

FINDING A4:

The QA staff oversight of fixed laboratory needs to be strengthened. 

Discussion:

EPA noted the following issues related to the QA oversight of the data quality from the 

laboratory:

The laboratory must finalize Standard Operating Procedures (SOPs), including 

EPA approval. The final SOPs should incorporate a regular schedule for which 

the QA group performs activities to ensure ongoing data quality. These activities 

include, but are not limited to, performing internal QA audits, running PE samples 

and MDL studies, participating in inter-laboratory comparisons, and conducting 

and documenting reviews of logbooks and control charts. 

More frequent and comprehensive internal laboratory audits should be performed. 

Ideally, these audits should be performed annually or more frequently. 

In order to improve oversight, QA staff should become more familiar with ongoing laboratory operations. In addition, SCAQMD should place special 

emphasis on facilitating the process by which quality assurance findings and 

corrective actions are tracked. 

Adding method acceptance limits or control limits to calibration control process 

charts or charting duplicate sample precision results can help staff review quality 
SCAQMD TSA Report: March 2011

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control results more easily. The stated lack of confidence by QA staff as to the 

reliability of TO-15 standards purchased by the laboratory needs to be addressed. 

Validation of laboratory PM data should be performed by staff not performing 

sample collection and/or analysis. For more information see the QA Handbook 

for Air Pollution Measurement Systems, Volume II, Ambient Air Quality 

Monitoring Program, December 2008 (Section 17.2 “Effective data validation 

procedures usually are handled completely independently from the procedures of 

initial data collection.”) 

 Recommendation:

The Laboratory and QA group need to work together on methods to promote consistency 

and a robust, independent QA program for the fixed laboratory. 

FINDING A5:

Quarterly data entry to AQS for filter-based PM2.5 and PM10 and annual data certification were 

not completed on time. 

Discussion:

EPA requires that data must be received by AQS 90 days after the end of each quarterly 

reporting period (40 CFR, Part 58.16) and that this data be certified by May 1 of each 

year starting in 2010 (40 CFR, Part 58.15). SCAQMD significantly exceeded these 

requirements. This limited EPA’s ability to evaluate and assess data collected by the 

SCAQMD network. 

Recommendation:

SCAQMD needs to meet the data submission and certification schedules required by 

EPA. This could be aided by the addition of a staff person whose responsibility is to 

ensure these deadlines are met. 
SCAQMD TSA Report: March 2011

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B. NETWORK MANAGEMENT

The ambient air monitoring network in the South Coast AQMD currently consists of 34 

State/Local Air Monitoring Stations (SLAMS) plus several source oriented lead monitors, 

special studies and Special Purpose Monitoring (SPM) sites that utilize a variety of air pollutant 

measuring instruments. The following table summarizes the SLAMS sites in the SCAQMD.
SCAQMD TSA Report: March 2011

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Table 1: SLAMS sites in the SCAQMD

Site O3 CO NOx SO2 FRM 

PM10

BAM 

PM10

TEOM 

PM10

FRM 

PM2.5

BAM

PM2.5

Pb

Anaheim X X X X X X X

Azusa X X X X X

Banning Airport X X X

Big Bear X

Burbank X X X X X X X X

Compton 

(Replaced Lynwood)

X X X X X

Costa Mesa X X X X

Crestline X X X

Fontana X X X X X X

Glendora X X X X

Indio X X X X, X

La Habra X X X

LA-Main St X X X X X X X, X X

Lake Elsinor X X X X

LAX Hastings X X X X X X

Long Beach - North X X X X X X X X X

Mira Loma - Van 

Buren (replacing 

Jurupa)

X X X X X X

Mission Viejo X X X X

Norco X

Ontario Fire Station X X

Palm Springs X X X X X X

Pasadena X X X X

Perris X X

Pico Rivera #2 X X X X X

Pomona X X X

Redlands X X

Reseda X X X X

Riverside X X X X

Rubidoux X X X X X X X, X X X

San Bernadino X X X X X X X

Santa Clarita X X X X

South Long Beach X X X

Upland X X X X X

West LA X X X

Source: SCAQMD 2009 Air Monitoring Network Plan
17

SCAQMD also operates the following special purpose monitoring sites (SPM) and sourceoriented lead sites:

Port study sites at the Ports of Los Angeles and Long Beach

Pb at Exide: Rehrig in Vernon, and ATSF in City of Commerce

Pb at Quemetco (Closet World) in City of Industry

Pb at Trojan Battery (Uddelholm) in Santa Fe Springs

Pb at Van Nuys Airport 

In addition, the District operates a network of air toxics stations, including a National Air 

Toxics Trends Stations (NATTS) at the Los Angeles (Main) and Rubidoux sites. This audit 

addressed air toxics activities that support the NATTS, including both field and laboratory 

operations. These two sites are also designated as National Core (NCore) multipollutant 

monitoring sites. 

The District operates a network of Photochemical Assessment Monitoring Stations (PAMS). 

The PAMS network consists of seven sites. LAX/Hastings is a Type 1 (upwind, background, and 

transport) PAMS site; Azusa, Burbank, Los Angeles (Main), and Pico Rivera are Type 2 

(maximum precursor emission/central business district) sites; Rubidoux and Santa Clarita are 

Type 3 (maximum ozone concentration) sites. EPA has approved the District’s PAMS network, 

operating schedule and forecasting scheme.

The SCAQMD network currently meets or exceeds the requirements for the minimum 

number of monitoring sites designated as SLAMS for all of the criteria pollutants. SCAQMD 

managers exhibit broad knowledge of air quality issues within the District and a thorough 

understanding of current and upcoming EPA network requirements and recommendations. As a 

result, SCAQMD has very effective network planning. In addition, most monitoring sites are 

properly located with respect to monitoring objectives, spatial scales and other siting criteria. 

40 CFR 58.20 requires States to perform an annual review of their existing ambient 

monitoring networks and to provide information about the monitoring stations, including the 

information required by 40 CFR Part 58, Appendix A (quality assurance requirements) and 

Appendix D (network requirements and monitoring site objectives). Based on changes to the 

monitoring regulations, which went into effect in December 2006, the annual network plan now 

requires evidence of a public inspection process. The District submits an annual monitoring 

network plan and the most recent submittal, in 2009, includes all of the required information 

about the monitoring stations. The current SCAQMD document meets the requirements to 

describe the network and the intended monitoring objectives of each site. 

In addition to the network plan, 40 CFR 58.10 (d) states “The State, or where applicable 

local, agency shall perform and submit to the EPA Regional Administrator an assessment of the 

air quality surveillance system every 5 years to determine, at a minimum, if the network meets 

the monitoring objectives defined in appendix D to this part, whether new sites are needed, 

whether existing sites are no longer needed and can be terminated, and whether new technologies 

are appropriate for incorporation into the ambient air monitoring network.” 
SCAQMD TSA Report: August 2010

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Network Management

FINDING B1: 

PM10 data at the Indio monitoring site may be affected by middle scale sources.

Discussion:

Currently, the PM10 data from the Indio monitoring site is characterized as representing 

neighborhood scale monitoring. 40 CFR 58 Appendix D states that, for PM10

neighborhood scale monitoring measurements should “represent conditions throughout 

some reasonably homogeneous urban sub-region with dimensions of a few kilometers.” 

The CFR clarifies that “homogeneity refers to the particulate matter concentrations, as 

well as land use and land surface characteristics.” Upon visiting this site, it was 

discovered that it is located in very close proximity to an unpaved vacant lot, which is 

actively used for vehicle parking. Due to its close proximity to a known source of PM10, 

it is reasonable to assume that the Indio monitoring site is representative of an area

smaller than neighborhood scale monitoring.

 Recommendation:

The spatial scale of the PM10 monitoring at the Indio site should be changed to middle 

scale or specific actions should be taken to mitigate fugitive dust from the vacant lot to 

minimize the impact of local sources on the monitoring data.

FINDING B2:

Exide-Rehrig should be a collocated lead (Pb) monitoring site.

Discussion:

As specified in 40 CFR part 58, Appendix A, section 3.3.4.3, the first collocated Pb site 

must be the site measuring the highest concentrations in the network. In the SCAQMD 

Pb network, the highest site is now (based upon 2009 data) Exide-Rehrig. There are 

currently three monitors at Exide Rehrig, each operating on a staggered 1:3 schedule. 

The three monitors report to a single Parameter Occurrence Codes (POC), and 

collectively have an every-day sampling schedule. Distinct POCs for each monitor are 

strongly recommended. A combined site report may still be pulled. This report would 

sum the data from all monitors at the site, while the information as to which data are 

associated with each monitor would still be retained. (Also see Finding C2) 

 

Recommendations:

1. In order to meet the collocation requirement, SCAQMD needs a collocated 

monitor at Exide-Rehrig. 

2. SCAQMD should have distinct POCs for each monitor. 
SCAQMD TSA Report: August 2010

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FINDING B3:

Placement of PM monitors at Anaheim does not meet collocation requirements.

Discussion:

At the site visit to Anaheim, EPA noted that there are two reference method samplers for 

both PM10 and PM2.5, one filter-based and one continuous for each method at the site. 

The distance between each of these pairs exceed the four meter horizontal and one meter 

vertical requirement for collocated monitoring. For PM2.5 there are network collocation 

requirements for filter-based FRM and continuous FEM. If both of these PM2.5 samplers 

are to remain at this site, they should be moved to within one to four meters of each other 

and mounted at a similar height so they can be considered to be formally collocated. 

There is no collocation requirement for PM10 filter-based and continuous instruments, 

however it is still recommended that, if practical, these samplers be moved to within two 

to four meters horizontally and one meter vertically of each other.

Recommendation:

Confirm whether or not the PM2.5 samplers are intended to meet the collocation 

requirements. EPA suggests that all monitors measuring the same pollutant meet these 

distance parameters in order to produce comparable data per the collocation 

requirements.

FINDING B4:

SCAQMD does not routinely notify EPA about collecting data from SPMs and sometimes does 

not enter that data into AQS. 

Discussion:

The SCAQMD operates many temporary monitors as part of short-term studies or to 

address public concerns. EPA fully supports SCAQMD’s responsiveness to address 

community concerns or other issues, however, any data thus collected that meets the QA 

requirements should be entered into AQS. This is consistent with 40 CFR Part 58.20(b) 

that states:

Data collected at an SPM using a FRM, FEM or ARM meeting the requirements 

of Appendix A must be submitted to AQS according to the requirements of §58.30. 

It is also useful for EPA to be aware of all the data being collected by SCAQMD to 

remain informed about air quality in the basin.

Recommendation:

SCAQMD should:

1. Include a list of major projects that are ongoing or have been completed in the 

previous year in the Annual Network Plan. This list would include the start date 

of sampling, what pollutants are measured, the sampling methods being used (or 

FRM/FEM status), the data objective and expected duration.
SCAQMD TSA Report: August 2010

20

2. Put the data from the site into AQS, beginning with the start date, if a study is 

extended and lasts over one year.

3. EPA may also request an annual updated list of all ongoing monitoring projects. 

This list would be the same as the list in the network plan, but would include all 

special monitoring projects.

FINDING B5:

The SCAQMD has a dense monitoring network that may include redundant or low-value sites.

Discussion:

The SCAQMD operates one of the most extensive networks in the US. While a dense 

network can provide important spatial detail, it is expensive to maintain and does not 

always provide necessary information. The SCAQMD recently submitted a 5-year 

Network Assessment that identified sites that could be considered for closure. 

Recommendation:

Seek to close sites that have been identified as redundant or low-value.
SCAQMD TSA Report: August 2010

21

C. FIELD OPERATIONS

Field operations are performed by the Atmospheric Measurements Division, which is 

managed by Philip Fine. This division is divided into two groups: Ambient Monitoring and 

Special Monitoring. Routine ambient monitoring is conducted by the Ambient Monitoring 

Group. The Special Monitoring Group undertakes special projects and seasonal monitoring as 

needed. The Ambient Monitoring group is subdivided into Operations, Support, and Data 

Management sections. Day-to-day monitoring station operations are performed by the 

Operations section, which is broken into sub-sections. Each sub-section has at least one Senior 

Air Quality Instrument Specialist (AQIS) and five AQISs. Repairs and calibrations are 

performed by the AQISs in the Support section.

As part of this TSA, Operations section AQISs were asked about their duties related to 

monitoring station operation. Additionally, AQISs in the support section were interviewed about 

aspects of the instrument repair and calibration processes. All AQISs interviewed demonstrated 

a thorough knowledge of the monitoring and calibration equipment for which they were 

responsible. 

The Field Sites reviewed included Anaheim, Exide, Fontana, Indio, Lake Elsinore, Los 

Angeles North Main, Mission Viejo, Palm Springs, Pasadena, Perris, Pico Rivera, Pomona, 

Rubidoux, and Van Nuys. EPA evaluation at these sites included inspection of the inlet 

manifolds, examination of station and instrument log books, and a specific check of whether 

appropriate Quality Control (QC) checks and Quality Assurance (QA) audits were being 

performed for dates in 2008 and 2009 that had been selected for review prior to the audit. Each 

of the sites visited was well organized. Instrument logbooks were up to date and contained 

relevant information on operations and maintenance activities. Most sites met the siting criteria 

of 40 CFR 58, Appendix E. 

Field Operations

FINDING C1:

One-point flow rate verifications were not being performed on continuous PM10 instruments 

throughout the SCAQMD monitoring network until approximately August of 2008.

Discussion:

40 CFR 58, Appendix A 3.2.3 states that “a one-point flow rate verification must be 

performed at least once every month on each automated analyzer used to measure PM10”. 

The BAM 1020 and the Thermo TEOM instruments are subject to this requirement. On 

visits to various monitoring sites, it was discovered that these checks were not being 

performed until mid 2008. The QA Handbook Volume II, Appendix D lists this 

requirement as a “critical criterion” in the Continuous PM10 Standard Temperature and 

Pressure (STP) Conditions Validation Template and is a very important measure of the 

performance of the instrument. These checks are used to not only assess the bias of the 

monitoring data, but also serve as a critical indicator of potential instrument malfunction 
SCAQMD TSA Report: August 2010

22

or other data quality issues. Failure to perform these checks could compromise the quality 

of the PM10 data being measured. 

 Recommendation:

Though SCAQMD has already corrected this issue and has been performing these checks 

post August 2008, it is recommended that SCAQMD assure these checks are performed 

in the future. 

FINDING C2:

Collocated filter based PM10 data are not currently submitted to AQS under an independent 

monitor POC. 

Discussion:

Data from multiple filter-based PM10 samplers are being reported to AQS under one 

monitor and POC. POCs indicate how may monitors are operating at a site for a given 

pollutant. For collocated PM10 monitoring, 40 CFR 58 Appendix A 3.3.1.3 states that “for 

each pair of collocated samplers, designate one sampler as the primary sampler whose 

samples will be used to report air quality for the site, and designate the other as the audit 

sampler.” The CFR also directs state or local agencies to “report the measurements from 

both samplers at each collocated sampling site.” Typically, the primary sampler is 

designated as POC 1, while the collocated sampler is designated as POC 2. All other 

samplers should be designated as POC 3, 4, or 5 as needed. These practices ensure that 

the data in AQS accurately represents what is physically being monitored at a given 

location.

 Recommendation:

SCAQMD should designate collocated and primary samplers appropriately and report 

data to AQS from each PM10 sampler under a separate POC.

FINDING C3:

The inlet at the Pomona station does not meet the 40 CFR 58, Appendix E siting criteria for O3

and NO2 monitoring.

Discussion:

The gaseous inlet probe at the Pomona monitoring station is approximately 6.5m from the 

roadway (Garey Avenue), but the 2008 data year network plan indicates that it is 50m 

away and that the vehicle counts are 10,000 vehicles/day. 40 CFR 58, Appendix E, 

section 6.1 states that for a station approved before December 18, 2006, a probe for 

monitoring ozone and oxides of nitrogen should be at least 10 m from a road with traffic 

of 10,000 vehicles per day.

Recommendation:

SCAQMD should confirm the correct traffic counts for Garey Ave. and determine the 

minimum distance between the road and the probe to meet the siting requirements of 
SCAQMD TSA Report: August 2010

23

CFR 58, Appendix E, section 6.1, and correct the information in the next network plan. 

The District should consider moving the inlet at this site to meet the siting requirements, 

move the site or discontinue monitoring O3 and NO2 at this location.
SCAQMD TSA Report: August 2010

24

D. LABORATORY OPERATIONS

Analytical laboratories provide support for measurement methods that are either too complex 

or too sensitive to perform in the field environment. In order to provide these services, 

laboratories employ advanced instrumentation and staff with highly specialized training. 

For ambient air samples to provide useful information or evidence, laboratory analyses must 

meet the following basic requirements:

 1. The laboratory must maintain a suitable facility for sample receipt, storage, analysis, and 

reduction and storage of data.

 2. The laboratory must have sufficient and appropriate equipment that must be calibrated and 

maintained frequently. 

 3. The laboratory must have an adequate number of qualified staff. 

 4. Analytical procedures must be in accordance with official guidance, EPA methods and 

accepted practice.

 5. Complete and accurate records must be kept. 

 SCAQMD has a clean, modern, expansive laboratory facility located at the headquarters 

office in Diamond Bar, California. The laboratory supports many chemical analyses necessary 

to understand a large complex air basin and its diverse source mix. One of the primary 

responsibilities of the laboratory is the handling of PM filters, which includes preparation, 

weighing, tracking and storing PM2.5, PM10 and total suspended particle (TSP) filters. In 

addition to PM responsibilities, the laboratory is also responsible for sample analyses of 

Speciation Trends Network (STN), PAMS, NATTS and special projects run by SCAQMD, such 

as the Multiple Air Toxics Exposure Study (MATES) series. The compounds SCAQMD 

routinely analyzes for include:

- VOCs for PAMS (TO-14)

- VOCs for NATTS (TO-15)

- Carbonyls for PAMS and NATTS (Toxic Organic Compendium [TO]-11A)

- PM2.5 metals for STN by X-ray Fluorescence (XRF) (Inorganic Compendium [IO]-3.3)

- PM10 metals for NATTS by Inductively Coupled Plasma-Mass Spectroscopy (ICP-MS) 

(IO-3.5)

- Pb-TSP by XRF

- Acrolein for NATTS (modified TO-15)

- Hexavalent chrome for NATTS by ion chromatography (modified California Air 

Resources Board (CARB) method)

- Anions for STN 

 There are a number of additional activities the laboratory undertakes to support the collection 

and analysis of air pollutants. These include canister cleaning and preparation, data validation 

and sample storage. 
SCAQMD TSA Report: August 2010

25

Laboratory Operations

FINDING D1:

The cleaning process of canisters appeared to be at maximum capacity, which falls outside 

guidance and good laboratory practice. 

Discussion:

Laboratory staff stated that the length of time that canisters are subjected to vacuum and 

heating during the cleaning process varies depending on the demand for canisters. When 

demand for canisters is high, the cleaning time is shortened to the point where canisters 

begin to fail the certification process for cleanliness. At that point, the process is 

manipulated until the shortest time necessary to pass certification is achieved. (Technical 

Assistance Document [TAD], Sec. 2.5.2.2).

The cleaning process described by staff can lead to undetected, residual carryover 

contamination in canisters. Cleaning canisters for 10 - 12 minutes is less than the 30 

minutes prescribed in the guidance, and balancing the cleaning time as finely as described 

against passing certification versus using a fixed cleaning time raises the potential for 

residual contamination. Carryover contamination from previous samples may go 

undetected because only a percentage of the canisters cleaned in every batch is selected 

for certification analysis. This indicates a need for additional canisters, cleaning 

apparatus or staff time. 

Recommendation:

Evaluate the Laboratory’s capacity to meet the demand for clean canisters against the 

guidance and add whatever combination of new canisters, new cleaning apparatus, and 

staff is needed to achieve it.

FINDING D2:

Deficiencies observed in an external TO-15 performance audit sample have not been 

satisfactorily resolved.

Discussion:

SCAQMD Quality Assurance staff attributed deficiencies observed in analysis of an 

external TO-15 performance audit sample to problems with the accuracy of 

concentrations of target compounds provided by the vendor for calibration gas standards. 

Staff further expressed a general lack of confidence in the reliability of the gas standards 

provided by the vendor. Use of calibration gas standards forms the basis for determining 

the concentration levels of contaminants reported in samples. Their accuracy must be 

assured.

Several options are available for addressing the reliability of the gas calibration 

standards. They range from verifying gas cylinder concentrations are within a "tolerance 

range" when analyzed against a second source gas standard to purchasing customized 
SCAQMD TSA Report: August 2010

26

TO-14 gas calibration standards containing most TO-15 compounds directly from the 

National Institute of Standards and Technology (NIST), where the target compound 

concentrations have been established with accuracy and have been certified through a 

rigorous testing protocol. NIST will also analyze commercially purchased gas standards 

and provide a certification of the concentration of each target compound for a fee. 

Also, the California Air Resources Board (CARB) is available to analyze one sample 

obtained from a cylinder or the cylinder itself against a certified NIST cylinder that 

CARB routinely uses for TO-15 analyses and provide the results to SCAQMD at no 

charge. CARB will not provide certified concentrations for the cylinder analysis since it 

is based on one run. This analysis is similar to a high quality second source analysis 

where results fall within a tolerance range, but accurate concentrations have not been 

established for each compound. 

Because research by CARB and NIST has shown that stability is cylinder specific and 

that degradation occurs for some compounds, an established verification schedule is 

required. To perform these verifications, purchasing a certified cylinder directly from 

NIST and purchasing a NIST certification of a commercially purchased gas standard 

cylinder are preferred options. 

Recommendations:

1. The laboratory should take prompt measures to assure the accuracy of target 

compound concentrations in the gas standard cylinders used for testing equipment 

calibration. 

2. The laboratory should outline the frequency for verifying continued stability with 

an independent standard or re-certifying TO-15 gas standard concentrations in its 

QAPP and SOPs.

FINDING D3:

The QA measures used to control PAMS analyses are generally less rigorous than specified in 

guidance and by good laboratory practices.

Discussion:

Internal standards and calculated relative retention times are not being used as part of the 

target peak compound identification process as prescribed in the PAMS guidance. In 

addition, quality control measures supporting proper peak identification and quantitation, 

such as periodic sample confirmation of a percentage of analytical results by Gas 

Chromatography/Mass Spectrometry (GC/MS), are not being performed as per the 

guidance. Instead, they are performed sporadically. Additionally, while duplicate 

analyses are being performed, they were performed outside the 2009 PAMS season 

(TAD, Sec. 2.3.7). 

Although gas chromatographic systems are generally stable, variations in conditions can 

and do occur that can shift absolute retention times. This can result in improper or 

missed compound identification. The use of internal standards with calculated relative 
SCAQMD TSA Report: August 2010

27

retention times would address this concern and generally facilitate the target compound 

identification process. This seems especially important considering the complex 

chromatography observed with PAMS analysis. 

In discussing the chromatography process, staff stated they are able to identify target 

compounds in calibration standards by studying the profile of peak intensities relative to 

each other in the chromatogram. This type of data reduction process increases the 

potential for error when identifying sample peaks where published or established profiles 

are not used for comparison. 

When instruments are deployed in the field, PAMS guidance suggests that changes in 

ambient conditions can cause changes in gas flow rates, column temperature, detector 

response, sample injection volumes and sample moisture, and that internal standards help 

to compensate for system variability. Sec. 7.3 of the laboratory's TO-15 SOP states that 

staff have found that the most common problem with that method is a retention time shift 

caused by oven temperature control, column flow and concentration operation. 

Although the PAMS Gas Chromatograph Flame Ionization Detector (GC FID) method 

can provide accurate results, upgrading the system configuration to a dual column - dual 

detector FID and Mass Selective Detector (MSD) or similar configuration would yield 

significant benefits. Quantitation could still be performed by calibrating the FID detector 

with propane while the mass spectrometer would be used for identification. Such a 

system configuration may involve a natural evolution for PAMS analysis and is already 

being used in some commercial laboratories. 

Incorporation of an MSD into the system configuration would greatly facilitate target and 

non-target contaminant peak identification, and significantly reduce the potential for 

human error. The process would provide a higher level of confidence for contaminant 

identification. The use of a mass spectrometer detector would address the quantitation 

problems with manual editing and integration of co-eluting peaks as described by the 

laboratory and confirmed by the PAMS PE study sample. 

Recommendations:

1. At a minimum the laboratory should transition to the use of internal standards for 

all instrumentation as prescribed in the PAMS method. GC/MS confirmation 

should also be performed on a percentage of samples according to guidance. 

2. GC/MS should be used to resolve issues with samples containing co-eluting 

compounds in place of the current practice of manual integration of unresolved 

gas chromatographic peaks. The laboratory is strongly encouraged to investigate 

and consider upgrading its system configuration to one that includes an MSD for 

compound identification. 

FINDING D4:

The primary TO-15 analyst stated that a method detection limit (MDL) study has not been 

performed for many years due to time constraints.
SCAQMD TSA Report: August 2010

28

Discussion:

According to method TO-15, MDL studies should be performed according to CFR Part 

136, part B. MDL studies should be performed at a minimum annually, and any time a 

significant change is made or maintenance is performed that might affect instrument 

sensitivity. MDL studies are needed any time data are reported with non detect results. 

Recommendation:

MDL studies should be performed on a regular schedule, at a minimum annually, and any 

time significant changes are made to the instrument. 

FINDING D5:

The laboratory's process for certifying a batch of eight cleaned PAMS canisters as clean based on 

selecting three canisters for certification analysis and allowing one to fail before the batch is 

rejected is outside guidance and common laboratory practice. 

Discussion:

Technical guidance calls for one out of every batch of eight canisters cleaned on a 

cleaning apparatus at the same time to meet analysis certification criteria. Without 

appropriate documentation, it is uncertain if the laboratory's procedure yields an 

equivalent level of confidence in canister cleanliness. 

(TAD, Sec. 2.5.2.3) 

According to guidance, 100% of new canisters should undergo the blanking and 

certification process. Following initial certification, one out of eight canisters cleaned as a 

batch should be tested for contamination. If the canister tested meets certification criteria, 

the batch may be certified as clean. Since the laboratory's practice deviates from 

guidance, the rationale and demonstration of equivalency should be documented. Please 

contact Region 9 for assistance with the statistical evaluation, if needed. 

Recommendation:

The laboratory should provide the rationale and documentation to demonstrate 

equivalency to the process described in the PAMS TAD guidance. 

FINDING D6:

There was no evidence of consistent secondary review of instrument run logbooks. This was 

also observed during the previous TSA. 

Discussion:

Periodic review of instrument logbooks ensures that proper analysis protocols are being 

followed for calibration, blanks, duplicates and other quality control procedures. 

Repeated failures or attempts to analyze calibrations noted in logbooks can be an 

indication that instrument maintenance or other corrective action needs to be performed. 
SCAQMD TSA Report: August 2010

29

Initials or signatures of the reviewing official should be included to document that these 

reviews occurred. 

Recommendation:

It is recommended that the lead chemist or supervisory staff regularly review instrument 

run logbook entries and document their review by signing or initialing and dating the 

logbook. The QA group should also periodically spot-check these logbooks.

FINDING D7:

The method being used for analysis of Pb for NAAQS compliance is a modification of an 

existing Federal Equivalent Method (FEM). 

Discussion:

Approximately five years ago, SCAQMD upgraded the method being used for analysis of 

Pb on TSP filters. The method is based on an existing FEM, and has been verified with 

performance evaluation samples. However, it was not clear whether the method 

modifications represent a significant change to the FEM. In order to clarify the issue of 

method equivalency, SCAQMD plans to share results from filter strip audits with EPA 

and have filters analyzed by an independent lab following a different FEM. SCAQMD 

has indicated they are planning to use a different analyzer for Pb in the future and may 

apply for FEM status.

Recommendation:

Perform an evaluation of the current Pb method to validate consistency with an FEM for 

data generated from this method. SCAQMD should either apply for FEM status for 

current method or change to one of the newly designated Pb FEM methods.

FINDING D8:

The sampling systems for collection of PAMS and Toxics sample are not routinely certified

using gaseous standards.

Discussion:

The Technical Assistance Document for Sampling and Analysis of Ozone Precursors, 

September 1998, Section 2.5.1.7 specifies the procedure that should be followed to 

certify samplers. It is recommended that certification occur one to three times per year 

for each sampler. SCAQMD is currently blank-certifying these samplers. 

Recommendation:

SCAQMD should develop a procedure, schedule, and criteria for certification of PAMS 

and Toxics sampling equipment with gaseous standards at a frequency of at least once a 

year.
SCAQMD TSA Report: August 2010

30

FINDING D9:

The monitoring field technician was not aware of storage and handling requirements of carbonyl 

sampling cartridges in the field. 

Discussion:

The field technician was not aware of any criteria for storage temperature or time for the 

carbonyl media prior to use. Additionally, no expiration data was found on the carbonyl 

media. All sampling media should include an expiration date and handling instructions to 

ensure that they are not used for sampling beyond their expiration date. Method TO-11A 

specifies a 90-day certification period for sampling media prepared by analytical 

laboratories. It is possible that the vendor may have tested the media and can justify 

recommending a storage period longer than 90 days.

Recommendation:

SCAQMD should develop and inform the field technician of handing procedures for 

carbonyl media.

FINDING D10:

The procedure to test PM2.5 lot blanks is inconsistent with EPA guidance.

Discussion:

In EPA Quality Assurance Guidance Document 2.12, 1998, Section 7.7 it is specified that 

three lot blanks be tested from each lot of PM2.5 filters and periodically re-weighed. 

SCAQMD currently uses lot blanks from the original filter lot as “exposure blanks” 

instead of filters from the current filter lot. While these blanks yield similar information, 

they are not as representative as using blanks from the current lot.

Recommendation:

SCAQMD should use lot blanks that are from the current filter lot.
SCAQMD TSA Report: August 2010

31

E. DATA MANAGEMENT

SCAQMD has defined procedures for handling data from the time of acquisition to the 

time that it is submitted to EPA. The procedures are well known to the principal data providers 

and reviewers. Responsibility for managing ambient monitoring data is divided between the 

Atmospheric Measurements Branch operators, data validators, and Senior and Principal Air 

Quality Instrument Specialists (AQIS). 

The Quality Assurance Manager reports results of QA audits and evaluations to a Quality 

Assurance Alert Log, AQS Event Flag Summary, and Corrective Action Request Log. These 

reports are incorporated into the review processes of Atmospheric Measurements and the 

Laboratory. 

EPA identified four separate data management and validation processes in place for 

different data streams reported to AQS by SCAQMD. Continuous monitoring data is handled by 

Atmospheric Measurements. The laboratory has three separate data streams: 1) filter-based 

PM2.5; 2) filter-based PM10, TSP, Pb, and non-NAAQS metals; and 3) organic analyses.

Continuous Monitoring for Gaseous Pollutants and Particulates

Air quality data measured by the continuous analyzers at the field stations 

are stored in SCAQMD data loggers and station computers. Each station is polled 

minute-by-minute and the data are transmitted directly to the District’s central 

computer. Electronic chart recorders (Eurotherm Chessels) located at each station 

serve as a back-up system and provide a supplemental record for the data 

validation. Data may also be transferred manually using various devices, 

including laptop computers and flash drives.

SCAQMD performs four levels of validation for continuous data. The 

station data loggers and the FORTRAN-based data system perform automated 

checks. Field Operation staff review data and recommend flags. Data validators 

review quality control parameters. Data validators then evaluate data in relation 

to concurrent, corresponding data sets.

Laboratory Data Systems: Filter-Based PM2.5 Particulate Monitoring; Monitoring of Lead 

and non-NAAQS Metals; and Monitoring of Organic Compounds

PM2.5 filters are prepared and pre-weighed by the filter laboratory and 

transferred to the field technicians. The laboratory also prepares other sampling 

media (canisters, filters, and sorbents) to be collected by the field technicians, 

with the exception of PAMS auto GCs, which are operated in the field by the 

laboratory staff. The field group performs a review of the field handling, sampler 

performance, and other field collection information. When filters are processed at 

the laboratory, the filter laboratory staff performs a review of the field operational 

parameters, including electronic records produced by the samplers. The 
SCAQMD TSA Report: August 2010

32

laboratory reviews the Quality Assurance Alert Log, AQS Event Flag Summary, 

and Corrective Action request log for items specific to the data being processed. 

Data is appropriately flagged or invalidated and a Senior Laboratory Chemist 

performs the final levels of data review prior to uploading data to AQS. 

FINDING E1:

For continuous monitoring data, SCAQMD uses a limited number of validations flags that may 

not reflect the most appropriate AQS flags. 

Discussion:

Numerous flags are available in AQS to invalidate or qualify data. SCAQMD is not 

using most of these flags because the FORTRAN-based data management system 

SCAQMD uses for continuous monitors is only programmed for up to six different flags. 

This results in many data points being coded using the “miscellaneous void” flag that is 

not very informative. EPA and others evaluate data submitted to AQS for quality 

purposes and/or when taking air quality actions. EPA relies on descriptive and 

appropriately coded information for making these decisions.

Recommendation:

SCAQMD needs to ensure that appropriate data flags are submitted to AQS.

FINDING E2:

Data validators do not differentiate between upper limit flat-lined data and instrument error data 

issues.

Discussion:

The BAM 1020 instrument has an upper limit on reporting hourly PM10 concentrations. 

When the upper limit is reached for an hourly value, a default reading of the upper limit 

is displayed. Unfortunately, this is very similar to the default reading for an instrument 

error. Currently, SCAQMD invalidates all data that appears to be flat-lining for long 

periods of time with a miscellaneous void (AM) flag, under the assumption that there was 

a potential instrument malfunction. While this is an appropriate procedure in most cases, 

PM10 hourly values that are extremely high may be confused for values associated with 

an instrument malfunction or error.

 Recommendations:

1. New procedures should be developed for continuous PM10 data validation to 

minimize the potential for improper invalidation of extremely high PM10 data. 

2. When the upper limit of an instrument is reached, SCAQMD should use the proper 

AQS Quality Assurance Qualifier code “EH” (estimated value: exceeds upper range) 

in the place of the current “AM” flag.
SCAQMD TSA Report: August 2010

33

FINDING E3:

No validation flag was assigned for the Perris ozone monitor from May 2-5, 2009.

Discussion:

EPA noted that data were missing from the Perris ozone monitor from May 2-5, 2009, 

but no validation flag was assigned. 

Recommendation:

SCAQMD should determine why data are missing, restore information from the chessel 

backup system (if appropriate), and apply appropriate flags to the data in AQS.

FINDING E4:

Electronic records are not always handled in a manner that maintains their reproducibility.

Discussion:

The original raw data file used by the laboratory for particulate matter is editable and 

used by the data validators. Similar practices were observed in the calibration laboratory. 

It is essential that record integrity be preserved. The 2003 NELAC Standard, June 5, 

2003 (EPA/600/R-04/003) notes that “records that are stored or generated by computers 

or personal computers shall have hard copy or write-protected backup copies.”

Recommendation:

SCAQMD should ensure that any electronic records are appropriately write-protected and 

backed-up.

FINDING E5:

The data validators do not review the PM2.5 filter custody forms.

Discussion:

The PM2.5 custody forms are the original records for many steps in the filter-based data 

collection process. These forms contain information that may have been entered 

erroneously into the laboratory data system. Additionally, these forms may contain notes 

from the field technicians that provide useful information for the validation process. 

Therefore it is essential that these forms be reviewed as part of the data validation 

process.

Recommendation:

The PM2.5 data validation process should include a review of the filter custody forms.
SCAQMD TSA Report: August 2010

34

F. QUALITY MANAGEMENT

The Code of Federal Regulations Volume 40, Part 58, Appendix A, establishes minimal 

requirements for quality assurance for PQAOs such as SCAQMD. These requirements include 

quality planning, independent quality management, and cooperation with performance and 

technical audits. Insufficient quality management and control has been cited a as rationale for 

legal challenges to NAAQS redesignation decisions. 

SCAQMD has a defined quality management system, which includes a quality 

management plan and oversight by an independent quality assurance manager and audit 

program. Draft QAPPs are in place or in development for all aspects of the monitoring program 

although these need to be finalized, please see General Comment A1.

Soon after the last EPA TSA, SCAQMD established a QA group lead by a QA Manager, 

Jason Low, which was given organizational parity with the Ambient Monitoring and Laboratory 

Managers. There are two direct reports to the QA Manager, a QA auditor and a QA Chemist. 

The QA group also manages a support contract that performs additional QA/QC audits of the 

monitoring network. Based on the current workload, as noted in Finding A3, the current QA 

group staffing is inadequate to maintain a rigorous, long-term quality management program.

Despite the limited staffing levels, the QA group has laid the foundations of a strong QA 

program. 

EPA regulations require independent performance audits of gaseous pollutants and flow 

audits of PM2.5, and PM10 and monitors. For gaseous pollutants, the current regulation requires 

that 25% of each pollutant monitoring network be audited per calendar quarter so that each 

instrument is audited once per year. Prior to 2007, flow audits of these monitors were also 

required. Additionally, quarterly independent flow audits of PM2.5 samplers were required. 

Beginning in calendar year 2007, semi-annual flow audits of each PM2.5, PM10, and TSP sampler 

are required (40 CFR, Part 58, Appendix A, Sections 3.2.4 and 3.3.3.) This is in addition to the 

required monthly flow evaluations (40 CFR, Part 58, Appendix A, Sections 3.2.3 and 3.3.2.).

The Quality Assurance group is responsible for conducting the required gaseous pollutant 

audits and PM10 and PM2.5 flow audits. An independent contractor supports the flow audits of 

filter-based samplers and provides audit results to site operators. A contractor also supports 

meteorological audits.

Quality Assurance and Quality Control

FINDING F1:

Flow audits of continuous particulate monitors are not conducted at the required frequency.
SCAQMD TSA Report: August 2010

35

Discussion:

Semi-annual flow rate audits are required in 40 CFR Part 58, Appendix A, Section 3.3.3 

for all FRM and FEM monitors measuring particulates. Audits of filter-based monitors 

that are conducted by a SCAQMD contractor have been completed at the required 

frequency. Audits conducted by the SCAQMD auditor of the continuous monitor have 

not met the required frequency. Prior to October 2006, audits were required annually for 

PM10 and TSP and quarterly for PM2.5. SCAQMD indicated that, for continuous 

monitoring, there are insufficient audit staff to meet this requirement. These audits 

constitute required, independent evaluations of SCAQMD monitors. The 2007 EPA 

Region 9 TSA Report also identified this activity as one that required implementation. .

Recommendation:

SCAQMD should schedule and conduct the required audits of continuous particulate 

monitors. 

FINDING F2:

Logbooks in all operational areas were not formally tracked and controlled.

Discussion:

Logbooks are used extensively by SCAQMD to record information that supports the 

validity and defensibility of data. Because of the size of the SCAQMD monitoring 

organization, a significant number of logbooks are used. For document tracking 

purposes, the existence and status of each logbook should be recorded and tracked. This 

function should be performed by the QA program or in each operational unit. For more 

information on records management, refer to 2003 NELAC Standard, June 5, 2003 

(EPA/600/R-04/003).

Recommendation:

SCAQMD should create and implement a system for management of logbooks and 

similar documentation.

FINDING F3:

The SCAQMD formal corrective action process should be improved.

Discussion:

During the audit EPA noted:

Some significant corrective actions were not handled through the formal 

corrective action process.

Staff indicated that some identified problems had not been resolved.

The formal corrective action process did not include a discussion of the cause of 

the problem, nor did it document the steps taken to prevent similar deficiencies 

from occurring in the future.
SCAQMD TSA Report: August 2010

36

The SCAQMD corrective action process should be the primary system to document how 

significant deficiencies have been addressed. This information should be accessible to all 

monitoring staff and managers. Additionally, staff should be encouraged to use this 

process to resolve or document issues that they believe are significant or are not being 

resolved through normal management communications. It was also noted that the 

corrective action form did not included a discussion of how similar deficiencies would be 

prevented from recurring.

Recommendation:

SCAQMD should evaluate the formal corrective action process to make it more 

transparent, accessible, and useful.

FINDING F4:

The control charts used by the QA group to track data quality do not include all the data being 

produced.

Discussion:

The use of control charts to monitor quality control parameters is strongly recommended 

in the QA Handbook for Air Pollution Measurement Systems, Volume II, Ambient Air 

Quality Monitoring Program, December 2008. The SCAQMD monitoring group uses 

control charts to monitor individual field sites. However, control charts are not 

commonly used by the QA group to monitor network performance. Given the size of the 

SCAQMD network, it would be helpful to use a visual/graphic approach to understand 

and respond to trends in the quality of monitoring data. SCAQMD’s QA support 

contractor produces control charts for quality control audits that they perform. 

Recommendation:

The QA group should develop metrics and control charts to support possible 

interpretations of the ambient air data sets.

FINDING F5:

QA audits of gaseous pollutants were not performed as required by regulation.

Discussion:

40 CFR Part 58, Appendix A, Sections 3.2.2 indicates that each calendar quarter at least 

25% of the monitoring sites in the network must be audited. For two or more quarters, 

fewer than 25% of monitoring sites are audited. Additionally, the time between audits of 

an individual monitoring site can be overly long (a 20-month auditing gap was noted for 

the Pasadena monitoring station). 

Recommendation:

The QA group should develop and meet schedules for conducting performance audits that 

are consistent with 40 CFR Part 58, Appendix A.
SCAQMD TSA Report: August 2010

A – 1

APPENDIX A: Summary of Findings

Significant Findings

FINDING A1:

SCAQMD’s Quality Assurance program documentation, including most Quality Assurance 

Project Plans (QAPPs) and Standard Operating Procedures (SOPs), was not complete and was 

not approved by EPA at the time of the audit. 

FINDING A2:

In several operational areas, official records were not available or were stored in a manner that 

did not ensure their reproducibility. 

FINDING A3:

Limited staffing in several key areas is significantly impacting monitoring program performance 

and quality.

FINDING A4:

The QA staff oversight of fixed laboratory needs to be strengthened. 

FINDING A5:

Quarterly data entry to AQS for filter-based PM2.5 and PM10 and annual data certification were 

not completed on time. 

FINDING B1: 

PM10 data at the Indio monitoring site may be affected by middle scale sources.

FINDING B2:

Exide-Rehrig should be a collocated lead (Pb) monitoring site.

FINDING B3:

Placement of PM monitors at Anaheim does not meet collocation requirements.

FINDING B4:

SCAQMD does not routinely notify EPA about collecting data from SPMs and sometimes does 

not enter that data into AQS. 

FINDING B5

The SCAQMD has a dense monitoring network that may include redundant or low-value sites.

FINDING C1:

One-point flow rate verifications were not being performed on continuous PM10 instruments 

throughout the SCAQMD monitoring network until approximately August of 2008.
SCAQMD TSA Report: August 2010

A – 2

FINDING C2:

Collocated filter based PM10 data are not currently submitted to AQS under an independent 

monitor POC. 

FINDING C3:

The inlet at the Pomona station does not meet the 40 CFR 58, Appendix E siting criteria for O3

and NO2 monitoring.

FINDING D1:

The cleaning process of canisters appeared to be at maximum capacity, which falls outside 

guidance and good laboratory practice. 

FINDING D2:

Deficiencies observed in an external TO-15 performance audit sample have not been 

satisfactorily resolved.

FINDING D3:

The QA measures used to control PAMS analyses are generally less rigorous than specified in 

guidance and by good laboratory practices.

FINDING D4:

The primary TO-15 analyst stated that a method detection limit (MDL) study has not been 

performed for many years due to time constraints.

FINDING D5:

The laboratory's process for certifying a batch of eight cleaned PAMS canisters as clean based on 

selecting three canisters for certification analysis and allowing one to fail before the batch is 

rejected is outside guidance and common laboratory practice. 

FINDING D6:

There was no evidence of consistent secondary review of instrument run logbooks. This was 

also observed during the previous TSA. 

FINDING D7:

The method being used for analysis of Pb for NAAQS compliance is a modification of an 

existing Federal Equivalent Method (FEM). 

FINDING D8:

The sampling systems for collection of PAMS and Toxics sample are not routinely certified

using gaseous standards.

FINDING D9:

The monitoring field technician was not aware of storage and handling requirements of carbonyl 

sampling cartridges in the field. 
SCAQMD TSA Report: August 2010

A – 3

FINDING D10:

The procedure to test PM2.5 lot blanks is inconsistent with EPA guidance.

FINDING E1:

For continuous monitoring data, SCAQMD uses a limited number of validations flags that may 

not reflect the most appropriate AQS flags. 

FINDING E2:

Data validators do not differentiate between upper limit flat-lined data and instrument error data 

issues.

FINDING E3:

No validation flag was assigned for the Perris ozone monitor from May 2-5, 2009.

FINDING E4:

Electronic records are not always handled in a manner that maintains their reproducibility.

FINDING E5:

The data validators do not review the PM2.5 filter custody forms.

FINDING F1:

Flow audits of continuous particulate monitors are not conducted at the required frequency.

FINDING F2:

Logbooks in all operational areas were not formally tracked and controlled.

FINDING F3:

The SCAQMD formal corrective action process should be improved.

FINDING F4:

The control charts used by the QA group to track data quality do not include all the data being 

produced.

FINDING F5:

QA audits of gaseous pollutants were not performed as required by regulation.
SCAQMD TSA Report: August 2010

B – 1

APPENDIX B: Good Practices Recommendations

Recommendations for Field Operations

I. SCAQMD uses horizontal manifolds at some monitoring sites. EPA recommends 

(Appendix F of the QA handbook) that horizontal manifolds be oriented in a manner so 

as to prevent condensation from getting into the instrument lines. Several SCAQMD 

sites have horizontal manifolds oriented with the inlets on the bottom, which would not 

prevent debris or condensations from getting into sampling lines. 

II. Based on a review of field PM2.5 tracking forms received by the laboratory, it was 

observed that the field technicians do not always complete these forms. The information 

included in these forms documents the field collection process and should be completed.

III. The toxics sampling site visited, Pico Rivera, is equipped with a manifold system similar 

to a standard air monitoring station. The technician confirmed that the proper operation 

of this manifold and “kicker pump” is evaluated during site visits. However, this QC 

check is not recorded on a site maintenance form or in the station logbook. 

IV. In order to verify the integrity of ambient air samples, it is recommended that the final 

canister pressures be recorded from a certified pressure gauge both in the field and in the 

laboratory.

V. Canisters should be stored in the field at ambient temperature and away from direct 

sunlight. If they will be stored for several hours in a vehicle in the field, they should be 

placed in an insulated container. 

VI. Station temperatures need to be recorded consistently. 

VII. Other siting recommendations: 

a. Monitor the distance and height of the trees near the Rubidoux site. 

b. Check to determine if the LA Main site height meets requirements for all 

programs.

c. Evaluate whether the TSP monitor at the Pasadena site can be moved to an 

unobstructed location. 

d. Construction activities near the Pico Rivera site are probably impacting the PM 

monitoring, which could lead to problems with data completeness. Consideration 

should be given to moving this site so that it is not impacted by construction.

e. Mission Viejo PM monitors are sited next to a building on the downwind side. 

While the distance from the building to the monitors may meet siting 

requirements, predominant wind on the day of the EPA visit was such that the 

monitors may have been experiencing an altered air mass from the inlets on the 

roof. EPA suggests moving the monitors out further from the building to sample a 

more representative air mass.
SCAQMD TSA Report: August 2010

B – 2

Recommendations for Laboratory Operations

I. The run channels of the carbonyl samplers should be evaluated periodically for blank 

contamination. As currently operated, the carbonyl samples have channels dedicated for 

blank samples. This approach does not provide for any blank control of the normal 

sampling channels. 

II. PM filter disposal should be documented so that the laboratory can track the filters that 

are available in storage and those that have been disposed of.

III. Filter custody forms should originate from the laboratory and include information on 

filter ID, conditioning, preweight, and expiration dates. The recorder should initial the 

entry. 

IV. The filter laboratory temperature and humidity sensor should be placed so that it cannot 

be influenced by the analyst's breath.

V. The ventilation system for the filter weighing room brings hot air to an air-conditioned 

interior space. This configuration wastes energy. Altering the configuration to vent 

outside would be more energy efficient and might reduce costs.

VI. The field log books for PAMS and Toxics should be checked by the validators. 

VII. The laboratory should investigate and consider upgrading to a dual GC/FID /mass 

selective detector configuration. Such as configuration would reduce the effort involved 

in the current process and significantly facilitate proper compound identification. It 

would add another measure of confidence in compound identification.

VIII. The Pb data report has a place for a senior chemist's signature, but was not signed. The 

District should complete documentation of QA activities, including initials or signatures.

IX. Two student interns perform visual inspection of all the filters to be used for Pb analysis. 

This is a repetitive task that relies heavily on analyst concentration of effort. The 

laboratory may wish to introduce a quality control check point, such as introducing filters 

with known defects, into the filter inspection stream. 

X. Internal chain of custody forms are not used once filters are received from the field. 

Filters are logged in when they are received, but there is no record of when they are 

transferred to the ICP-MS for analysis. Demonstration of custody control after samples 

are in the laboratory can be an important factor if data are challenged. Internal custody 

can be tracked using forms or sign-out sheets The secondary source standard that is used 

to verify carbonyl calibration is from a different lot, but is purchased from the same 

vendor as the primary standard (TO-11, Sec. 11.4.4). The method requires that each 

calibration curve be verified against a standard prepared from a material obtained from a 

second source. Although the standards used for this purpose are obtained from a 
SCAQMD TSA Report: August 2010

B – 3

different lot, it would be a more appropriate to use material from a different vendor. 

Standards from the same vendor, but a different lot, probably do not qualify as second 

source standards. The importance of second standard source verification in adding 

confidence to the reliability of standards is highlighted by the laboratory's stated 

experience with problem gas standards in the TO-15 Department.

XI. The laboratory's method of bringing cartridge extracts to 5mL volume introduces a 

source of analytical error. Extracts are not brought to volume using volumetric 

glassware. Instead, extracts are brought to volume in vials on which the 5mL level has 

been marked and measured against a reference vial with a similar mark (TO-11, Sec. 

11.2.3 and 11.2.4). It is recommended that volumetric glassware be used at all stages of 

analysis, and specifically where cartridges are extracted and brought to 5mL volume. 

XII. Analyst and other staff were unaware of the target value for carbonyl MDLs, which 

increases the risk that they fall short of measurement goals. MDL results were reported 

in liquid (mL) units, and not back calculated to air volume units, which made it difficult 

to assess if method MDLs were achieved. Presenting MDLs study results in air units 

instead of liquid units would make it easier to confirm that measurement quality 

objectives are being met. Regardless of how MDL calculations are presented, target 

criteria for MDLs should be established for passing or failing, and staff should be 

familiar with the target values present in the SOP in order to ensure they are met. 

XIII. The laboratory tracks daily calibration standard results using a process quality control 

chart. However, it was not easy to determine if results were within control limits. 

Including method acceptance limit control or quality control lines to the plots would be 

useful. 

XIV. Duplicate samples are being analyzed, but the analyst was not able to state the control 

limits for acceptable results or what result would trigger a corrective action. Replicate 

results are being documented in tabulated format. It is important that the analyst and 

quality assurance staff refer to QC results when corrective action is needed, and that 

outliers are taken into account when data are evaluated against their intended use. 

Plotting duplicate results or calculated percent difference of duplicate results would help 

staff evaluate quality control results and limits. 

XV. Laboratory staff were not clear if the acetonitrile used for extracting cartirdges is tested 

for purity, nor what the upper limit of acceptable formaldehyde contamination is. 

According to the TO-11 method (Sect. 6.3; 9.2.1), it is important to know the amount of 

formaldehyde in the acetonitrile reagent since it will be converted to hydrazone, and 

therefore should be checked on a regular basis. 
SCAQMD TSA Report: August 2010

B – 4

Recommendations for Quality Assurance

I. There are no assigned document custodians in the operational areas. Some documents 

are tracked by the staff that created them. A formal system should be developed whereby 

official documents are created, used and archived so that they are available to all staff at 

all times. 

II. The QA performance auditor does not audit short term projects. However, data from 

some short-term projects may be used to make critical decisions regarding human health 

and the environment, in which case the data needs to be of known quality. It is 

recommended that when short-term projects are in the planning stage, the project data 

quality objectives (DQOs) be evaluated to determine whether QA audits should be 

included.

III. The QA Laboratory should develop a schedule for certifying primary and transfer 

standards. Certified standards should be verified upon receipt or soon thereafter.

IV. The QA group should conduct regular audits of data quality. This should include 

selecting several reported values, verifying all the steps of the data collection process and 

recalculating the results.