# Technical System Audit

Report

Hawaii Department of Health

Ambient Air Quality Monitoring Program

January 24

– January 27, 2011

Conducted by

Air Quality Analysis Office Quality Assurance Office

Air Division Man agement and Technical

Services Division

US EPA Region 9

75 Hawthorne Street

San Francisco, California 94105

Final report: June 1 , 2011

### 2 INDEX

PAGE

GLOSSARY OF ACRONYMS

................................ ................................ .......................... 3

EXECUTIVE SUMMARY

................................ ................................ ................................ 4

GENERAL PROGRAM

................................ ................................ ................................ ..... 9

NETWORK MANAGEMENT

................................ ................................ ......................... 17

FIELD OPERATIONS

................................ ................................ ................................ ..... 21

LABORATORY OPERATIONS

................................ ................................ ..................... 28

DATA MANAGEMENT

................................ ................................ ................................ .. 33

QUALITY CONTROL (QC) AND QUALITY ASSURANCE (QA)

............................. 36

APPENDIX A: Summary of Findings

................................ ................................ .............. 42

APPENDIX B: Hawaii Department of Health: Air Surveillanc e & Analysis Section and

Clean Air Branch Staff

................................ ................................ ................................ ...... 46

APPENDIX C: EPA Quality Assurance Handbook, Appendix H, as completed by Hawaii

Department of Health

– Clean Air Branch, and Air Surveillance & Analysis Section

.... 4 7

APPENDIX D: 2011 TSA Schedule

................................ ................................ .............. 107

### 3 GLOSSARY OF ACRONYMS

Air Surveillance & Analysis

Section

......... ......... .......... Air portion of the Environmental Health Analytical

Services Branch, State Laboratori es Division

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

CAB............................. Clean Air Branch

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

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

GFAAS........................

... Graphite Furnace Atomic Absorption Sampling

DOH

........................... Department of Health, State of Hawaii

EPA

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

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

NAAQS................................ Natio nal Ambient Air Quality Standard

NCore...........................

. .National Core monitoring stations

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

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

O 3



### .......................................... Ozone

Pb..

...................................... Lead

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

PM 2.5



### ..................................... Particulate matter 2.5 microns or less in aerodynamic

diameter

PM 10



### ...................................... P articulate matter 10 microns or less in aerodynamic

diameter

ppm..............................

. .parts per million

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

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

QAPP................................... Q uality Assurance Project Plan

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

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

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

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

SO 2



### ....................................... Sulfur Dioxide

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

TSP...........................

.. ...Total Suspended Particulates

VOCs............................ Volatile Organic Compounds

VOG............................... Volcanic s mog/haze

### 4

EXECUTIVE SUMMARY

This document is a report of the findings made by EPA Region 9 while

conducting a Technical Systems Audit (TSA) o f the Hawaii Department of Health ( DOH )

air monitoring program. A TSA is an on

- site review and inspection of a st ate 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.

The TSA was conduct ed by EPA Region 9 staff during th e week of January 24

– January 27, 2011

. Prior to the site visit, EPA asked DOH to fill out Appendix H of the

Quality Assurance Handbook for Air Pollution Measurement Systems, Volume II,

December 2008 ( QA Handbook ) . EPA provided Appendix H to DOH in Novem ber, and

DOH Clean Air Branch ( CAB ) and the Air portion of the Environmental Health

Analytical Services Branch, State Laboratories Division ( Air Surveillance & Analysis

Section ) all submitted documentation in January. This documentation is attached as

App endix C

. The audit team reviewed the submittal and used it, together with the

previous TSA ‟s findings , to focus on

- site discussions. The audit team interviewed

management and staff on specific aspects of the air monitoring program including

network desig n, field operations, laboratory operations, data handling, quality assurance

and quality control procedures. The audit team also inspected all five of the monitoring

sites operated by DOH on the island of Oahu and six of the seven DOH stations on the

Big Island of Hawaii . The site inspections consisted of an interview with the site

operator when possible, reviewing station and instrument logbooks, and evaluating the

station siting with respect to EPA requirements for probe siting 1 

### . The laboratory

inspect ion included a review of the particulate matter program for mass determinations,

metals analysis (including lead ( Pb ) analysis) for filters, and laboratory analysis program s

for VOCs and carbonyls for air toxics

.

Conducting a TSA is one of the ways that EPA provides oversight to ensure that

data collected by state and local agencies meet certain minimum data quality objectives.

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

to collect information on the overall qua lity of ambient air data. These assessments

enable agencies to identify and correct those program elements which may be adversely

affecting the quality of ambient air data.

The result s of th e TSA are summarized here and fully described i n this report,

a long with recommend ed actions to address the findings.

1 

### 40 CFR, Part 58, App endix E, “Probe and Monitoring Path Siting Criteria for Ambient

Air Quality Monitoring”

### 5

Program strengths:

Overall, the DOH has very knowledgeable and dedicated staff. All of the

participating staff were most cooperative ; many went out of their way to

accommodate the auditors ‟ sche dules ; all were open and forthcoming with

information about their job responsibilities

. In general, DOH sites on Oahu and the Big Island are well located , well run, and

well maintained. Some logs and records are models of good record keeping

. Site operato rs are capable of completing most instrument repairs in

- house, and for

the most part the maintenance shop has sufficient spare parts and instruments

ready to be sent to the field, thereby minimizing the amount of down

- time

associated with instrument repair

. CAB maintains very detailed station and network files.

DOH has done a good job implementing its through

- the

- probe and audit program,

including developing corrective action forms for the audit program.

DOH has changed to a new data system. DOH has done a n exemplary job getting

the system in place at the stations and at the Air Surveillance & Analysis Section

, is working through any problems that have arisen and identifying areas where the

system could be improved. The change to the Envista program prese nted many

challenges. S ite operators and data validators and the ir management are to be

commended for successful implementation and ongoing work to improve the

system in moving to an electronic calibration record keeping system , which will

allow more time ly data validation.

The Laboratory QA program has started to perform peer review of PM 2.5 

### data

.

Program Findings:

During the TSA, EPA identified areas where the DOH monitoring program

should be strengthened. The most significant of these findings inclu de:

Communication between the Air Surveillance & Analysis Section and the CAB

should be strengthened and formalized. This was a finding of the 2008 TSA.

Lack of effective communication is significantly impacting successful

implementation of the air mon itoring program at DOH . Some specific examples

of significant issues arising from communication gap s that were noted during the

2011 TSA include:

o Lack of Quality Assurance Project Plan ( QAPP ) and Standard Operating

Procedure (SOP) submittals to EPA due to misunderstanding of roles and

responsibilities and/or miscommunication

o Questionable data certification procedures

o Delayed response to public and media questions regarding specific data

o Lack of adequate quality assurance and corrective action procedures

o D elay in addressing findings from the 2008 TSA

The division of q uality a ssurance (QA) responsibilities between CAB and the Air

Surveillance & Analysis Section should be clarified. While the Air Surveillance

### 6 & Analysis Section has a QA manager for laborato ry analysis

, DOH lacks a QA

Manager for the field and for the program overall. DOH must find a way to

address these key QA responsibilities.

The individual findings are reported in the topic sections of this document and are

also summarized in Append ix A. In addition to these general findings, EPA also

identified areas that could be strengthened and those recommendations and suggested

best practices are described in this report.

The specific actions to be taken by DOH will be determined through ne gotiations

between EPA and DOH and will be documented in a corrective action plan prepared by

DOH

.

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

support and cooperation during the audit.

### 7

INTRODUCTION

The Department of Health for the State of Hawaii (DOH) is the governmental

agency with delegated authority and responsibility for collecting ambient air quality data

as directed by the Clean Air Act 1977 and Clean Air Act Amendments 1990.

From January 24

– January 27, 2 011, EPA Region 9 conducted a Technical

System Audit (TSA) of the ambient monitoring program operated by DOH . The TSA

covered the following program areas:

Network Management

Network Design and Monitoring Station Siting

Organization, Staffing and Training

Facilities

Field Operations

Routine Operations

Field Quality Control

Preventive Maintenance

Record Keeping

Data Acquisition and Handling

Laboratory Operations

Routine Operation

Lab Quality Control

Prevent ive Maintenance

Record Keeping

Data Acquisition and Handling

Specific Pollutants:

PM

Air Toxics

Metals, including Pb

Data and Data Management

Data Handling

Software Documentation

Data Validation and Correction

Data Processing

Internal Reporting

External Reporting

Participating DOH managers, supervisors and staff included :

Wilfred Nagamine , Manager, Clean Air Branch

Wanda Chang , Manager, Environmental Health Analytical

Services Branch, State Laboratorie s Division

Lisa Young, Supervisor, Monitoring Section, Clean Air Branch

Henry Yee, Supervisor, Air Surveillance and Analysis Section

Susan Kihara, Environmental Health Specialist IV

Jensen Yoshimoto, Environmental Health Specialist IV

### 8 Terri Shinsato, Data Processing System Analyst IV

Michael Ibara, Air Quality Electronics Technician II

Harold Higashida, Air Quality Electronics Technician I

Lisa Wallace, C hem ist III

Kimberly N ichols , Chemist III

Jocelyn Licudine, Chemist III

Darren Suzuki, Chemist III

Richard Kiyokane, Quality Assurance Officer

A full list of air staff, both CAB and Air Surveillance & Analysis Section

, is

included as Appendix B

.

The EPA r egional staff members conductin g the TSA were Gwen Yoshimura of

the Air Division‟s Air Quality Analysis Office and Ma t hew Plate of the Region 9 Quality

Assurance Office.

This report is divided into eleven sections. The first sec tion is an executive

summ ary that describes the purpose of the TSA and a summary of the most significant

findings. The following section is an introduction that provides a brief description of the

DOH air monitoring program, identifies the participating DOH personnel and the EPA

audit team, and describes the report organization. The third section discusses the general

findings on the DOH monitoring program as a whole. The remaining five sections

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

ope rations, laboratory operations, data management and quality assurance/quality control

(QA/QC) . Appendix A is a summary listing of the findings contained in this report. The

findings and recommendations in this report are listed in priority order.

Recomm endations are provided to give some indication of EPA‟s expectations as to how

findings can be addressed. If DOH has other approaches or alternatives to address the

concerns identified, EPA will consider them, provided the corrective action adequately

add resses the finding.

### 9

GENERAL PROGRAM

The state of Hawaii is a 1,523

- mile chain of volcanically formed islets and eight

main islands in the Pacific Ocean more than 2500 miles west of San Francisco. Of the

eight main islands, the four most populated are : Oahu (Honolulu County)

– 905,034

people ; Hawaii (Hawaii County)

– 175,784 people ; Maui (Maui County)

– 143,574

people ; Kauai (Kauai County)

– 63,689 people

.

Federal and state laws require that clean air standards, developed to protect public

health, b e met and maintained throughout the country and in all states. In addition to

federal criteria pollutant air quality standards, the State of Hawaii has set air quality

standards for carbon monoxide, oxides of nitrogen, sulfur dioxide, lead, PM10, ozone and

hydrogen sulfide.

In Hawaii, the Department of Health is responsible for air pollution control and

ambient air quality monitoring. For these programs, the relevant operations are shared by

the C lean A ir B ranch (CAB) and the Environmental Health Analy tical Services Branch

( Air Surveillance & Analysis Section ) of the State Laboratories Division. CAB conducts

engineering analysis, inspections, enforcement, and permitting, and, i n conjunction with

the Air Surveillance & Analysis Section , establishes and maintains the ambient air

monitoring network and conducts special air monitoring studies as necessary. C AB

c ompiles, assesses and manages the validated data retrieved from the monitori ng stations ;

produc es data assessments through graphs , charts, maps and repor ts ; handl es network

design and oversight; conducts performance evaluation audits at all monitoring stations

operated by the Air Surveillance & Analysis Section section ; responds to public inquiries ;

evaluates trends ; calculates design values for desig nation recommendations ; and submits

exceptional event packages. The Air Surveillance & Analysis Section runs and maintains

the monitoring stations, collecting measurements of ambient levels of air pollutants

throughout the state to ensure that the state a nd federal air quality standards are met. The

Air Surveillance & Analysis Section is also responsible for analysis and reporting

ambient monitoring data to EPA‟s Air Quality System (AQS) database ; conduct ing

instrument calibrations ; validatin g the continu ous pol lutant monitoring data ; and

analyzing PM filters and air toxics samples for metals (in cluding Pb), VOCs, and

carbonyls

.

U nder the Clean Air Act, DOH receives Section 105 grant funds f rom EPA every

year to support air quality management activitie s, including ambient monitoring.

Operation of th is network allows DOH to notify the public whenever air quality reaches

levels regarded as unhealthful. In 2008, DOH, working with EPA Region 9, EPA Office

of Air Quality Planning and Standards (OAQPS)

, and the National Park Service (NPS),

was able to expand its public reporting capabilities to include:

Near

- Realtime reporting of PM 2.5 

### throughout Hawaii via EPA‟s AIRNow

website

Near

- Realtime reporting of SO 2 

### levels on the Big Island (made possible by

the de velopment of the Air Quality Advisory: a short

- term, Air Quality

### 10 Index (AQI)

- like health effects

- based breakpoints specific to SO 2 

### )

. Air

Quality Forecasting of SO 2 

### levels was also achieved at a later date.

The DOH offices that are the subject of this TS A are the Monitoring Section of

the CAB in the Environmental Management Division, managed by Wilfred Nagamine

, and the Air Surveillance and Analysis Section of the Environmental Health Analytical

Services in the State Laboratories Division

, under the direc tion of Wanda Chang . The

State Laboratories Division and the Environmental Management Division are placed

under the Environmental Health Administration.

The Air Surveillance & Analysis Section operates, collects, validates and reports

air quality dat a from stations located on Oahu, Maui, and Hawaii. Currently , there is no

station operating on Kauai but a special purpose monitoring station to monitor cruise ship

emissions near Nawiliwili Harbor is planned in the near future. Pollutants measured

includ e:

Carbon m onoxide (CO)

Nitrogen d ioxide (NO 2 

### )

Sulfur d ioxide (SO 2 

### )

Ozone (O 3 

### )

Particulate Matter (PM 10 

### and PM 2.5 

### )

Lead

Air Toxics including:

o 

### Metal Compounds

o 

### Volatile Organic Compounds (VOCs)

o 

### Carbonyl Compounds

Special Monitoring:

o 

### New Year Fireworks

### 11 o 

### VOG (v olcanic haze)

o 

### Agricultural Burns (sugarcane)

o 

### Geothermal (Hydrogen s ulfide )

T he Air Surveillance & Analysis Section QA Officer is Richard Kiyokane, the

Air Surveillance and Analysis Section Supervisor is Henry Yee, the Air Quality

Electronic Technician S upervisor is Michael Ibara and the information technology

specialist is Terri Shinsato. The Monitoring Section of the CAB is supervised by Lisa

Young.

Overall, EPA found that Hawaii has a n extensive network and that staff

overseeing the network stations are knowledgeable. Updating DOH ‟s QAPPs and SOPs

will ensure that the ir good practices , once formalized, will be followed into the future

.

The following findings relat e to the General Program:

General Program

Finding A1 :

In sufficient communicat ion between the Air Surveillance & Analysis Section and

the CAB is compromising the quality of Hawaii‟s air monitoring program.

Discussion:

The effect of insufficient communication on the quality of work produced by DOH ‟s

air monitoring program is demons trated by the following examples :

Regulatory requirements are not being met:

o QAPPs have not been completed

, due to a lack of communication and to

lack of agreement as to roles and responsibilities; and

o Data are not being recertified as there is no pro cess in place to document

when data have been revised.

Several significant 2008 TSA findings have not been addressed:

o The previous TSA found that communication between the Air

Surveillance & Analysis Section and CAB should be strengthened and

formalized. This situation has not improved and may have deteriorated

further ;

o The lack of currently approved QAPPs was a finding of the previous

TSA. No QAPPs have been submitted to EPA for approval since the last

TS A;

o The previous TSA also noted that QA roles and responsibilities were not

clearly assigned to one or the other branch ; and

o The previous TSA called for an improved corrective action system by

both the Air Surveillance & Analysis Section and CAB

.

D iscussions about resources do not seem to be occurring. As resources

diminish , it becomes increasingly important that these conversations occur, so

### 12 that both groups understand and come to an agreement about what is needed to

maintain the continued success of the program, what can be accomplish ed given

the ava ilable staff and funding levels

, and where it may be possible to disinvest to

save resources . Examples of discussions that could result in a better use of

resources :

o Clear assignment of QA/QC responsibilities, to avoid duplication of effort

while maintain ing appropriate data quality ;

o Closer coordination on new site leasing and set

- up, to avoid incurring

costs before the site is set up and operation can begin ; and

o Consideration of site

- operator resources when conducting monitoring

network assessments and es tablishing or shutting down sites.

There are several communication

- related issues that may ultimately impact data

quality:

o Lack of central QA oversight ;

o Lack of data oversight and technical audits ;

o M inimal evaluation of system

- wide QA ; and

o Delayed, unilat eral resolutions of QA issues

. Effects on Response to the Public

o The process for responding to public inquiries concerning data is not

obvious ; and

o The l evel of validation that is needed before data are shared with the

public is not clear

.

Recommendation:

CAB and the Air Surveillance & Analysis Section should discuss, come to

agree ment and document roles and responsibilities for each entity and how formal

communications

, such as the corrective action process, data certification, and

public inquiries

, will be handled. Mangers and staff should schedule regular

meetings together , not only via phone but in person, to discuss projects, issues,

upcoming activities , etc.

Finding A2 :

The EPA requirement for independent quality assurance is not being fully met.

Discussion:

40 CFR Part 58, Appendix A, Section 2.2 requires that each primary quality

assurance organization (PQAO) have independent quality assurance. In their

draft Quality Management Plan ( QMP ), DOH has identified the CAB as the QA

lead for ambien t air monitoring. The CAB performs some independent QA of the

program, including:

Independent performance audits on particulate and gaseous instruments,

and some meteorological equipment

Limited review of data in the AQS system

### 13 Development and approval o f QAPPs

The Air Surveillance & Analysis Section has an independent QA person who

reviews laboratory data. However, there is no independent entity that performs:

Oversight of field monitoring

Audits of data quality

Review of systematic QA/QC

Technical audi ts

Oversight of corrective actions

Recommendation:

DOH needs to ensure that all aspects of independent QA are implemented. It is

recommended that these elements be consolidated into one independent oversight

authority who is responsible for data quality and can interact directly with EPA

regarding data quality issues.

Finding A3 :

The performance of EPA Method TO

- 15 is not meeting minimal data quality

requirements to characterize the low concentrations of toxics in ambient air.

Discussion:

The Air S urveillance & Analysis Section is performing EPA Method TO

- 15 to

obtain toxics information similar to the National Air Toxics Trends Stations

(NATTS). Section 7.1.2 of the HDOH Air Toxics QAPP indicates that the data

are intended to “characterize ambient concentrations and deposition in a

representative monitoring area.”

During the TSA, several inadequacies were noted in the implementation of the

volatile organic compound (VOC) Method TO

- 15. These include:

The canister cleaning system is outdated and not well understood by the

analyst;

The laboratory does not certify that the canisters are clean, as required by

the method;

The analytical system is performing erratically and the analyst is unable to

cor rect the problems, but continues to analyze canisters when the system

“appears” to be more stable;

There is no recent method detection limit study;

Field blanks are not run;

The date of one set of working standards has expired; and

Recent performan ce evaluation samples were at concentrations that were

too high to be representative.

EPA attempted to quantify the impacts of these discrepancies by evaluating

HDOH‟s QAPP and Hawaii‟s AQS data for benzene (as benzene is one of the

### 14 critical TO

- 15 toxics) . Table 7

- 5 in Hawaii‟s QAPP estimates that a generic

detection limit for the TO

- 15 compounds should be at least 0.5 parts

- per

- billion

by volume (ppbv). Hawaii‟s minimum detectable limit (MDL) in AQS is entered

as 0.1 ppbv as benzene. From 2008 through 2010, there are no actual benzene

values reported below 0.25 ppbv benzene. This indicates a loss of monitoring

system sensitivity since the MDL was established. However, these data also

indicate that concentrations above the QAPP limit of 0.5 ppbv benzen e may not

be significantly impacted by false negative reporting.

Due to inconsistencies in the data, the lack of blank controls, detection limits, and

analytical system stability, the VOC concentration data currently being produced

by the Air Surveillance & Analysis Section may have significant errors, especially

at low concentrations. This is not consistent with the stated objective of

characterizing representative concentrations of these pollutants.

Recommendation:

DOH should consider the cost/benefit of maintaining an analytical system for

VOCs. Should the decision be to continue this monitoring, an evaluation should

be made as to how much it would cost to bring the Air Surveillance & Analysis

Section up to a level to meet the requirements versus wh at it would cost to have

the analysis done elsewhere.

Finding A4 :

Quality Assurance Project Plans (QAPPs) have not been completed or updated

since the last TSA.

Discussion:

The Clean Air Act requires that organizations using EPA funding to collect

environmental data develop a Quality Management Plan (QMP), an overarching

description of an organization‟s quality system

, and a QAPP for each type of

ambient pollutant being measured ( 40 CFR 58 App endix A, section 2.1 )

. The

QAPP describes all technical and quality aspects of a project and document s the

results of the QA planning process for environmental data operations , thereby

providing a project

- specific “blueprint” for obtaining the type and quality of

environmental data needed for a specific decisio n or use. 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

.

HI DOH agreed in response to EPA‟s previous TSA to submit QAPPs for criteria

pollutants PM 10 

### , O 3 

### , NO 2 

### , and SO 2 

### , as well as updating their PM 2.5 

### QAPP to

include changes to the regulation and reflect the use of continuous PM 2.5

### 15 monitors. These plans have not been completed and submitted to EPA for review.

Additionally, QAPPs need to be submitted for the NCore pollutants and for Pb

monitoring under the new Pb National Ambient Air Quality Standard ( NAAQS )

.

Recommendation:

QAPPs should be completed and sub mitted to EPA. Criteria pollutant QAPPs

should be prioritized, as further delay could impact the defensibility of EPA‟s

NAAQS decisions for Hawaii

.

Finding A5:

DOH should have more formalized training requirements for new and existing

staff.

Discuss ion:

This was noted in the previous TSA and has not been addressed. DOH continues

to send staff to air monitoring trainings and conferences on an “as needed” basis.

EPA appreciates DOH‟s efforts to participate when these opportunities arise.

However, DOH does not have a formalized program to ensure that staff are

trained on procedures and demonstrate proficiency on tasks directly related to

their job functions.

The QA Handbook, Section 4 discusses the need for a formalized training

program. EPA recog nizes that funding is limited and it is often difficult to send

people to trainings or be able to offer trainings on the islands. Developing a

formalized training program can help agencies identify what trainings are needed,

what the highest priority issu es are , and what resources are available. If it is not

possible to fulfill the training need immediately, the training plan allows agencies

to look for future funding or other opportunities.

EPA also encourages agencies to formalize and document on

- the

- j ob trainings.

Trainings could be given by DOH staff to their fellow staff to provide comm on

understanding and competency and minimize future problems and questions . I n

house trainings could include how to use DOH ‟s Envista program ; how to use the

public webpage and pull associated data; site

- operator training on the electronic

logs and the new process for electronic calibration sheets; training for site

operators, data users, and data validators on AQS flags and why they are

important; new QAPP/SOP traini ng; data validation and analysis; instrument

operation and maintenance training.

Recommendation:

DOH should develop a formal training program and tracking system to ensure that

all staff and managers (CAB and Air Surveillance & Analysis Section ) are

### 16 f amiliar with the relevant QAPPs and SOPs related to producing data in the field,

data management and tracking, quality assurance, laboratory operations, and all

data systems. Training objectives are to develop proficiency in new staff, and

give experience d staff the opportunity to keep skills current, to learn about

emerging technologies and capabilities, and to ensure that all staff are familiar

with the current QAPPs and SOPs.

### 17

NETWORK MANAGEMENT

The ambient network for state and local air monito ring stations (SLAMS) and

Special Purpose Monitoring (SPMs) in Hawaii consists of 13 s tations that have a variety

of air pollutant measurement instruments. The following table summarizes the air

monitoring sites in Hawaii by island, the respective polluta nts monitored

, and the year

monitoring began at the site

.

SITE NAME

(year established) POLLUTANT

Pb Toxics CO SO 2 

### NO 2 

### O 3 

### PM 10



### cont. PM 2.5 

### PM 2.5



### cont. H 2 

### S NCore

Oahu

Honolulu (1972) 

### X X X X

Kapolei (1991) 

### X X X X X X X

Pearl Ci ty (1994) 

### X X X X

Sand Island (1981) 

### X X

West Beach (1991) 

### X X X

Maui

Kihei SPM PM10

(1999) 

### X X

Hawaii

Hilo (1995) SPM 

### X X

Kona (2005) SPM 

### X X

Mountain View (2007)

SPM 

### X X

Pahala (2007) SPM 

### X X

Ocean View (2010)

SPM 

### X X

Puna H (2002) SPM 

### X

Puna E (2005) SPM 

### X X

Source: DOH 2010 Air Monitoring Network Plan

SPM = Special Purpose Monitor. Non

- SLAMS.

Most of the population e xposure monitoring sites o n Oahu have been operating at

the same location for over 1 0 years

. These long

- term sites allow the D OH to examine

trends in air quality and demonstrate that the State continues to meet all the federal air

quality standards with ex ception of SO 2 

### and fine particulate matter (PM 2.5 

### ). With

increas ing volcanic venting on the Big Island since 2008 , the source

- oriented monitors on

the Big Island began measuring numerous exceedances of both SO 2 

### and PM 2.5 

### standards.

### 18 Photo: Halema ’ um a ’ u crater release, January 26, 2011



### The State of Hawaii ‟s 2010 Ambient Air Monitoring Network Five

- Year

Assessment, submitted July 1, 2010, includes Hawaii‟s recommendations based upon

priorities stated in the assessment, funding and resource sections

. Recognizing that the

S tate‟s first priority

– monitoring volcanic emissions

– is resource

- intensive, and that an

additional monitor will be located on the Big Island, the S tate recommends closing 1 )

West Beach, 2 ) Kihei, and 3 ) Sand Island. EPA appreciate s the work that went into

making the a ssessment and will review site closure requests as they are submitted to EPA

for approval.

The Hawaii network currently meets the requirements for the minimum number

of monitoring sites designated as SLAMS for O 3 

### , Pb , and the new SO 2 

### standard, and

exceeds the minimum requirements for PM 10 

### and PM 2.5 

### . The SLAMS monitoring sites

are all properly located in terms of monitoring objectives and spatial scales and siting

criteria. Hawaii will be required to have a near

- road N O 2 

### monitor operating by 2013.

However, until EPA issues the NO 2 

### monitor siting Technical Support Document

( expected in summer 2011), it is not appropriate for DOH to work to secure any specific

site for the NO 2 

### monitor. Hawaii also successfully initiated NCore monitoring at Kapolei

in early 2011.

Photos: Kapolei Site

– looking south into site (SLAMS monitors on left most trailer , NCore monitors on middle t railer); looking

north from roof.

### 19 40 CFR 58.20 requires s tates to perform an annual review of th eir ambient

monitoring networks to ensure that they continue to meet the monitoring objectives of 40

CFR 58, appendix D. The annual network review is used to determine how well the

network is achieving its required air monitoring objectives, how well it i s meeting data

users needs, and how it should be modified ( e.g. , through termination of existing stations,

relocation of stations, or establishment of new stations) to continue to meet its monitoring

objectives and data needs. The main purpose of the revie w is to ensure that it provides

adequate, representative, and useful air quality data. DOH has submit ted a monitoring

network plan every year after a period of public review . The most recent review ( 2010 )

includes all of the required information about th e monitoring stations . T he current DOH

document meets the requirements of describing the monitoring network , compliance with

Appendix A quality assurance requirements, Appendix D network requirements and the

intended moni toring objectives of each site.

O verall, EPA found that CAB maintains excellent network and station files.

Stations are well

- maintained and well

- run, and site operators were knowledgeable and

helpful.

Network Management

Finding B1 :

While the volcanic activity is the State‟s highest ai r quality concern, the Big

Island monitoring network may have some redundancies

.

Discussion:

DOH now operates five VOG monitoring stations on the Big Island and plans to

add a station on the northwest part of the island in Waikaloa. In addition to the

VO G sites, DOH operate s two sites near the geothermal plant (Puna E and Puna

H).

The two geothermal sites are very close to one another and appear to be

redundant. The geothermal facility also operates an extensive monitoring

network. If DOH is concerne d about resources, including site operator time on

the Big Island, one or both of the Puna sites might be evaluated for possible

closure

.

In general terms, it may be appropriate to evaluate whether every monitor in the

VOG network is of equal value. It m ay be possible to discontinue operation of

one or two of the VOG monitors while maintaining a network sufficient to protect

public health and monitor for NAAQS compliance.

### 20

R ecommendation:

Given resource constraints, community concerns, and concern for p ublic health

and NAAQS compliance, an evaluation of the Big Island monitoring network

should be undertaken to determine whether closing some sites might be

appropriate.

Finding B2 :

As was found with the 2008 TSA, the DOH ambient air monitoring program do es

not have an up

- to

- date emergency episode plan for the Island of Hawaii.

Discussion:

40 CFR 51.150 states that an area with SO 2 

### ambient concentrations greater 0.04

parts per million ( ppm ) annual arithmetic mean, or 0.17 ppm 24

- hour maximum,

must be cl assified as a “Priority I Region” and must have a contingency plan for

emergency episodes. Hawaii does not have such a plan . Contingency plan

requirements are addressed in 40 CFR 51.152 and include providing for public

announcement s , emission control act ions and communications procedures

, including procedures for contact with public officials, descriptions and locations

of major emission sources, information resources for public health, safety, and

emergency agencies . This should include use of new media as well as print, radio

and television

.

Recommendation:

Develop a contingency plan for the Island of Hawaii. T he emergency episode

contingency plan should b e included as part of Hawaii‟s I nfrastructure State

Implementation Plan , due in 2013 for the 2010 SO 2 

### NAAQS , or submitted to EPA

at an earlier date

.

### 21

FIELD OPERATIONS

Field operation s for ambient monitoring are carried out by Air Surveillance &

Analysis Section staff. The day

- to

- day operations at the criteria pollutant monitoring

stations are perfo rmed by Air Surveillance & Analysis Section staff under the supervision

of Henry Yee and Mike Ibara

.

As part of this TSA, Air Quality Electronics Technicians were interviewed with

respect to their duties in monitoring station operation. All station oper ators interviewed

demonstrated a thorough knowledge of the monitoring equipment for which they were

responsible. The station operators had copies of current D OH SOPs

.

The Field Sites visited on Oahu included Honolulu, Kapolei, Pearl City, San

Island, and West Beach. Hilo, Mountain View, Ocean View, Pahala, Puna E, and Puna H

Field Sites were visited on the Big Island

. I nspection included examination of the inlet

manifolds, the station and instrument log books, and random data point checks. Each of

the el even sites visited were well organized and had clean inlet manifolds. Station

logbooks and instrument logbooks were up to date and contained relevant information on

operations and maintenance activities.

DOH recently changed to the Envista data system. Envista has the ability to

insert automatic data flags, allows the use of electronic logbooks, and can be

programmed to send automatic alerts, among many other features. Hawaii DOH has

been successful in making the change to the Envista system

.

Most sites met 40 CFR 58, Appendix E criteria , with the exception of probes on

the Big Island (see Finding C1 below ).

Field Operations

Finding C1:

Gaseous inlet probe heights at the Big Island sites do not meet the CFR

requirement for height above the roof.

Discussion:

40 CFR 58, Appendix E section 2 requires inlets to be “at least 1 meter vertically

or horizontally away from any supporting structure, walls, parapets, penthouses,

etc.” Probes measured at Big Island sites were 0.7

– 0.8 meters above the tra iler

roofs.

### 22

Recommendation:

Sites should be modified so that all gaseous probe inlets meet the 1 meter vertical

height requirement.

Finding C2 :

Maintenance and repairs of monitoring equipment used at the field stations were

not sufficiently documented

. Maintenance sheets used to track instrument repairs

do not appear to be consistently available or utilized.

Discussion:

DOH has implemented the use of maintenance sheets in response to a concern

raised during the previous TSA. These sheets partiall y address the previous

concern. However, it is apparent that they are not routinely used, are easy to

misplace, do not have sufficient space to document complex repairs, and are

completed inconsistently . DOH should develop a more robust and permanent

sys tem to document instrument maintenance. This could be accomplished by the

use of bound logbooks or an electronic system.

Proper applic ation of maintenance and repair of air monitoring instruments and

supporting equipment, including subsequent calibratio ns and verifications, is

needed to support Federal Reference Method (FRM) and Federal Equivalent

Method (FEM) designations. None of the field instruments have maintenance

logbooks. Some field maintenance is documented in station logbooks; however,

this d ocumentation does not appear to be comprehensive. There is no central

logbook for documentation of instrument maintenance performed in the Air

Surveillance & Analysis Section ‟s instrument repair shop. In order to establish

instrument maintenance, repair, performance, and related compliance with FRM

and FEM designations, detailed maintenance records must be maintained.

Recommendation:

Improve the system to document instrument maintenance. Document

maintenance for all field instruments in logbooks or oth er traceable and defensible

systems to demonstrate instrument maintenance and repairs and track when and

where they are deployed.

Finding C3 :

The documentation of PM 2.5 

### filter data from the site operators and feedback from

the analytical and validation p rocess need to be improved.

### 23

Discussion:

EPA noted PM 2.5 

### filter

- based data that was flagged in AQS, where the field

operator had not noted problems on the filter custody form. Upon further

investigation it was determined that the instrument had automat ically inserted a

standard out

- of

- specification flag in the sampler‟s electronic record. The PM 2.5 

### analyst explained that the electronic records are not routinely reviewed by the

station operators when data is download ed in the field. E lectronic data fla gs are

subsequently noted by the analyst, but not communicated to the station operators.

This is problematic, because:

information on the custody forms should indicate if there were any field

problems in the case that the electronic files are lost or corr upted ;

operators should be aware of instrument problems that may indicate that a

sampler need s repair or maintenance (i.e ., samplers may have intermittent

flags if the instrument fan is non

- operational or the fan filter is dirty) ; and

flags could be errone ous and not need to be retained in the validation

process or they could indicate a more serious problem which would

require data to be invalidated. T he stat ion operators are in the best

position to make that determination

.

Recommendation:

Improve docume ntation and communication between the field operators,

la boratory analysts, and the data validators.

Finding C4 :

DOH is lacking a corrective action process for field operations.

Discussion:

A formal tracking process should be in place for addressing s uspect or missing

data, instrument problems, or other problems seen in the field. Currently, it

appears that site operators and data validators informally make corrections as

issues arise, without bring the issue to the attention of others or documenting the

issue and correction . A corrective action process allows for clear tracking of

problems, faster identification of systematic issues, ensures that all those affected

by the issue are notified, and that the corrective action is followed through to the

a ppropriate conclusion.

Recommendation:

DOH should establish a corrective action process and ensure that all staff are

trained on the use and importance of the system.

### 24

Finding C5 :

Neither the field operations nor the CAB auditor document the qualit y of zero air

used in the program. This was a finding in the 2008 TSA.

Discussion:

Zero air scrubbers are used in place of certified zero air for instrument

calibrations. This is a common, acceptable practice. Because zero air is used to

generate the zero point and it is mixed as part of the calibration, it must be treated

as a standard. As such, zero air scrubber maintenance and verification must be

documented.

Recommendation:

Document the performance verification of zero air scrubbers.

Fi nding C 6 :

Not all Big Island sites are recording the results of high range SO 2 

### precision and

zero/span calibrations.

Discussion:

It appears that high range SO 2 

### precision and zero/span calibrations are being

conducted at all Big Island VOG sites. Site operato rs record the normal (lower)

range results on the calibration sheets. Not a ll site operators are recording the

high range results.

Photo: Example of a Zero/Span Log Sheet with high range results.



### These results are important, as the Big Island sites often experience higher levels

of SO 2 

### and the high range checks allow for greater confidence in those higher

range data.

### 25

Recommendation:

Ensure that all Big Island site operators record the results of high range SO 2 

### precision and zero/span calibrations.

Finding C7 :

There is a tree at the Hilo site that presents a significant siting issue and an

obstruction.

Discussion:

Photos: Hilo site.



### The 40 CFR Part 58, App endix E, s ection 5 states “Trees can provide surfaces for

SO 2 

### , O 3 

### , NO 2 

### adsorption or reactions, and surfa ces for particle deposition

. . . To

reduce this possible interference/obstruction, the probe, inlet, or at least 90

percent of the monitoring path must be at least 10 meters from the drip line of

trees.” The tree at the Hilo site is 5 meters from the SO 2 

### probe inlet, over 10

meters tall, and obstructs approximately 60 degrees of the monitoring path. While

the tree is not in the most predominant wind direction

, it is in the direction the

wind comes from when Hilo is impacted by VOG

. As such, the tree is an

obstruction and does not meet the criteria for trees cited above.

While not as critical

, it should also be noted that there is a palm tree at the Ocean

View site that is approximately 6 meters from the probes

. Removal of dead fron ds

would improve siting.

### 26

Recommendation:

Evaluate if the tree interfering with the Hilo siting can be trimmed or if the trailer

can be moved and/or re

- aligned to improve siting.

Finding C8: (Best Practices Recommendation)

Filter tape from continuous instruments is not archived.

Discussion:

While there is no requirement to archive filter tape from continuous instruments,

there are reasons for doing so. In cases where data are invalidated due to a hole in

the filter, debris contamination on the filt er, or other such issues, EPA strongly

recommends that the filter tape from that time period be labeled and kept for three

or more years. HDOH may also receive requests for the filters, from the public or

internally.

Recommendation:

Develop a system f

or archiving filter tape that includes either keeping the entire

tape, or

, at a minimum

, archiving the portion of the tape associated with

invalidated data.

Finding C9 : ( Best Practices Recommendation)

The Mountain View site experie nces periodic temperatur e drift due to loss of

power.

Discussion:

The Mountain View site periodically loses power. Most systems are on back

- up

power and are not affected. The air conditioning unit is not, however, and it turns

off and does not turn back on until it is manuall y reset . This increases the

possibility that the temperature at the site may go out of the acceptable range,

resulting in voided data.

Recommendation:

Devise a plan to prevent loss of data at Mountain View due to the temperature

going out of the accepta ble range following a loss of power.

### 27

Finding C10 : ( Best Practices Recommendation)

The sample residence times are not calculated and posted at each monitoring site.

Discussion:

Overall, DOH has done an excellent job of posting residence times at the v arious

stations. Residence times for most sites are calculated and there are several

different configurations included if applicable. However, there were a few sites

that did not have residence times posted.

Recommendation:

Ensure that all stations hav e residence times calculated and posted.

### 28

LABORATORY OPERATIONS

Analytical laboratories provide support for measurement methods that are either too

complex or too sensitive to be perform ed in the field environment. In order to provide

these services, la boratories 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:

The laboratory must maintain a suit able facility for sample receipt, storage,

analysis, and reduction and storage of data.

The laboratory must have sufficient and appropriate equipment that must be

calibrated and maintained frequently.

The laboratory must have an adequate number of qualif ied staff.

Analytical procedures must be in accordance with official guidance, EPA

methods and accepted practice.

Complete and accurate records must be kept.

The DOH has a clean, modern laboratory facility located in Pearl City . This

laboratory s upports many chemical analyses for air, water and biological samples

. The Air Surveillance & Analysis Section routinely analyzes for:

Mass of PM 2.5 

### filters

Mass or total suspended particulates ( TSP ) filters

VOCs for air toxics (TO

- 15)

Carbonyls for air t oxics (TO

- 11A)

TSP metals by graphite furnace atomic absorption ( GFAA ) (IO

- 3.2)

There are a number of additional activities the Air Surveillance & Analysis Section

undertakes to support the collection and analysis of air pollutants. These include

caniste r cleaning and preparation, data validation, and sample storage.

General Laboratory

Finding D1 :

The use of the PM 2.5 

### weigh

- room is so low as to be inefficient and potentially

error prone.

### 29

Discussion:

DOH has successfully transitioned to continuous monitoring for PM 2.5 

### . As such,

the sampling frequency has been reduced to collocated sampling at one

monitoring site three days per

- week. At this monitoring frequency

, the weigh

room is only in use several days a month. At the current sampling frequency

, Hawaii‟s cost per sample is extremely high due to the fixed cost of maintaining

the filter weighing facility and associated documentation. As this analysis

becomes less routine

, the potential for quality control errors is also increased.

EPA also noted that the PM 2.5 

### analy st is validating the data she collects . T o

correct this lack of independent QA

, another validator would need to be trained.

Recommendation:

Consider sending PM 2.5 

### filters to a commercial laboratory or to another air

monitoring age ncy to save on analytical cost and to potentially improve data

quality.

Finding D2 :

Contamination from a performance evaluation sample may have caused erroneous

data to be reported to AQS

.

Discussion:

The primary and collocated Pb sample results for A ugust 12, 2010 at the Pearl

City monitoring location were significantly different, as reported to AQS. An

investigation of these data found that on the day these samples were analyzed the

GFAA sampling system experienced significant carry

- over contaminati on from a

performance evaluation sample that had been submitted at too high a

concentration. One other sample in the analytical batch was re

- run confirming the

interference. The potential ly erroneous results of August 12 were quickly

identified as proble matic in AQS by EPA , and should have been noticed during

the peer review, data validation, or overall data check by the QA manager prior to

submission to AQS

.

Recommendation:

1. Metals data from the time of the performance evaluation sample should be

inv estigated by the QA officer and any suspect data should be flagged or

removed from AQS.

2. Performance evaluation samples should be ordered to be made up at a

concentration similar to ambient samples.

3. The laboratory QA oversight system should be improved.

### 30

F inding D3 :

The sampling system for collection of carbonyl sample s is not routinely certified.

Discussion:

The Technical Assistance Document for Sampling and Analysis of Ozone

Precursors , September 1998, Section 2.5.1.7

, specifies which procedure should

be followed to certify sampling systems . It is recommended that certification take

place one to three times pe r year for each sampler. DOH does not currently have

a schedu le for certifying these systems

.

Recommendation:

DOH should develop a procedure , schedule, and criteria for certification of

carbonyl sampling equipment.

Finding D4 :

DOH should develop an approved method for laboratory analysis of Pb filters for

the NAAQS program.

Discussion:

DOH has a well established procedure for analyzing m etals from TSP filters.

While this method is acceptable

, it does not meet the equivalency requirements

for NAAQS decisions. Currently the laboratory cuts squares out of each TSP

filter, digests them with nitric acid in a 60 °C ultrasonic bath, and analyz es the

extracts by GFAA. DOH could modify this procedure slightly and apply to EPA

for a federal equivalent method (FEM) for Pb. The FEM application process

would also help the laboratory to develop and understand their analytical

techniques more thoroug hly

.

EPA noted several areas that could be improved if the existing method were to be

used as an FEM for comparison to the NAAQS standard.

The laboratory should follow 40 CFR Part 50, Appendix G and cut TSP

filters into strips instead of squares.

The dige stion temperature should be raised

to 80 °C to be consistent with other

approved Pb FEMs

.

Also note that total mass of the TSP filters is not

required for comparison to the Pb NAAQS.

### 31

Recommendation:

DOH should develop and apply for a Pb FEM using the existing method, use a

procedure that follows an existing FRM or FEM, or plan to send lead filters to an

external laboratory for NAAQS comparison.

Finding D5 :

Field blanks are not implemented for metals.

Discussion:

All aspects of the sampling and an alysis program should have blank controls.

DOH runs laboratory blanks for metals but does not run field blanks. This does

not control for contamination introduced during field hand l ing procedures.

Recommendation:

Initiate routine field blanks for the metals program.

Finding D6 : ( Best Practices Recommendation)

The vendor does not provide an expiration date with the carbonyl sampling

media.

Discussion:

All sampling media should include an expiration date to ensure that they are not

used for samplin g outside of their “lifetime.” Method TO

- 11A specifies a 90

- day

certification period for sampling media prepared by analytical laboratories. It is

conceivable that the vendor may have tested the media for a longer period and can

justify recommending a pe riod longer than 90 days. This information should be

included in the SOP and the documentation kept with the certification.

Recommendation:

Set an expiration period for carbonyl sampling media based on the vendor‟s

holding time data or the 90

- day recomm endation of TO

- 11A.

Finding D7 : ( Best Practices Recommendation)

Staff at t he PM 2.5 

### laboratory indicated that they have many more new filters than

they can use.

### 32

Discussion:

EPA incurs significant program cost purchasing and shipping filters to monito ring

agencies. T he shelf life of filters for use in the PM 2.5 

### NAAQS monitoring

program is 3 years. It is possible that the remaining, un expired, filters could be

used by other agencies in the network.

Recommendation:

DOH should cut back on any future f ilter shipments from EPA and consider

sending filters to another agency if they will not be used by Hawaii before their

expiration date.

### 33

DATA MANAGEMENT

DOH has a draft QAPP in place for handling data from the time of acquisition to

the time that t hey are submitted to EPA. It has been revised to reflect Envista

, DOH ‟s

new data management system. The Air Surveillance & Analysis Section is primarily

responsible for managing ambient monitoring data and reporting to EPA‟s AQS database.

Air quality d ata measured by the continuous analyzers at the field stations used to

be stored in EMC data loggers and station computers. With the Envista system, each

station is connected to the central computer at the Air Surveillance & Analysis Section on

Oahu. Raw data and electronic logsheets maintained in Envista are immediately

available to the data validators. The electronic Monarch chart recorders located at each

station provide a supplemental record for the data validation process and act as a back

- up

data l ogging function . The first review is performed by the station operators. The data

validators review the data next , and the Information Technology S pecialist does a last

review and submits the m to AQS.

The State‟s Laboratory

- generated data include air t oxics (VOCs, carbonyls, and

metals

, including Pb) measurements and data from the one remaining PM 2.5 

### filter

- bas ed

instrument . Laboratory

- generated data are validated and submitted separately to AQS.

DOH submits all required data to the AQS database

, inc luding concentrations for

all criteria pollutants, supporting precision and accuracy information

, and data from the

network. Data submitted to AQS are annually certified by the DOH.

Data Tracking

Finding E1 :

Several incorrect flags were entered into AQ S.

Discussion:

EPA selected a number of data points to track from the station where they were

generated through the data validat i o n process . In a number of cases, the flags

were found to be errors.

Some problems were related to automatic flags insert ed by Envista . When

Envista was first brought online, it was automatically inserting flags incorrectly.

In some instances, flags were incorrectly translated from the data validator ‟ s

record into the file that is se nt to be upload ed into AQS. In other in stances

, a flag

had been entered by the data validator, but it was not possible or was very

difficult to verify why the flag was inserted

.

### 34 DOH does not have anyone performing QA/QC on the data validation process.

Some of the errors m ight have been fou nd if the data validators had more time to

review the data prior to sending them to AQS , or if there were a QA manager

whose task it was to review the final product

.

Recommendation:

1. Ensure that any flags Envista is automatically entering are correct.

2. Allow data validators more time to review data before sending them to AQS.

3. Review the data validation process to determine if there is a way to minimize data

entry from the site operators to the data validators to the data file that is sent to

AQS.

4. I de ntify a person whose task it is to perform QA/QC oversight of the data

validation process.

Finding E2 :

The first

- level of data validation by site operators is inconsistently executed.

Discussion:

Site operators do not appear to be familiar with AQS f lags or the process data go

through after leaving the site. However, as they are the ones most familiar with

the sites, the instruments, and the day

- to

- day conditions

, t hey should act as first

level data validators, reviewing the data for any outliers

, fl ag ging data

, or call ing

something to the data validator‟s attention.

Currently, some activities, such as auto calibrations or zero/span checks, are

automatically flagged by Envista and noted in the station logbook . In order to

find other field

- associat ed issues that should result in AQS flags, the data

validators must review each station log, as well as the monthly check

- sheets,

precision/accuracy an d zero calibration sheets. Given the capabilities of the new

Envista system, EPA encourages DOH to iden tify a way to allow data

- flagging by

the site operators. This would minimize the amount of information (electronic or

hard

- copy) the data validators mus t review to identify issues and would provide

more consistent QA/QC.

Recommendation:

Review Envista capabilities, in particular how the data validation QAPP addresses

data review and flagging by site operators, and revise the QAPP as appropriate to

ensure first

- level data review and data

- flagging at the site operator level.

### 35

Finding E3 :

Data validat ion is only performed at the end of the quarter , limiting the time for

review

.

Discussion:

The data validators try to complete their review of a quarter‟s worth of data by the

end of the quarter following the quarter the data were collected

. They re view the

raw data, station logbooks, checksheets, and precision/accuracy and zero/span

calibration logs. Thanks to the new Envista system, the raw data and station

logbooks are immediately available. The checksheets, precision/accuracy and

zero/span calibration logs, however, are primarily still available only in hard

copy. Site operators are supposed to bring the hard copies to the lab every month,

scan them, and g ive the hard copy and electronic copy to the data validators , but

in practice this occurs at the v ery end of the quarter. As a result

, the data

validators have a limited time to perform their review

.

Staff are working to develop an electronic system for the checksheets,

precision/accuracy and zero/span calibration logs. Station operators will be abl e

to track information on excel spreadsheets. When the spreadsheets are complete,

the station operators will save them as pdf file s to a centrally

- available network

drive. Once this system is set up, the data validators will be able to view the

spreadshe ets as soon as the y have been saved , and this w ill eliminate the need for

station operators to scan hard copies at another location

.

Recommendation:

DOH staff should continue to w ork with the site operators to ensure that

checksheets, precision/accuracy and zero/span calibration logs are available to the

data validators on a more frequent ( at a minimum , on a monthly) basis.

### 36

QUALITY CONTROL (QC) AND QUALITY ASSURANCE (QA)

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

minima l requirements for quality assurance for Primary Quality Assurance Organizations

(PQAOs) such as DOH . These requirements include quality planning, independent

quality management, and submission to performance and technical audits by EPA. EPA

views the ap plication of quality management systems as integral to monitoring programs.

Insufficient quality management and control has been cited as rationale to support legal

challenges to NAAQS redesignation decisions.

As compared to EPA‟s minimal requirements, DOH has a defined quality

management system. DOH has an approved quali ty management planning document and

has identified independent quality assurance functions. However, implementation of the

overall QA system as defined has been problematic for DOH in general and the ambient

air monitoring program specifically. With the exception of CAB performance audits and

EPA TSA corrective actions

, QA issues are elevated through the regular

technical/supervisory methods instead of through systems specifically desig ned to

improve QA/QC

. This can result in the QA/QC aspect of an issue not being addressed.

EPA regulation requires independent performance audits of gaseous pollutants

and flow audits of PM 2.5

, 

### PM 10 

### and TSP ( Pb ) monitors. For gaseous pollutants

, the

cur rent regulation requires that 25% of each pollutant monitoring network be audited per

calendar quarter so that each instru ment is audited once per year. S emi

- annual flow

audits of each PM 2.5 

### , PM 10 

### , and TSP sampler are also required (40 CFR, Part 58,

Appen dix A, Sections 3.2 .4 and 3.3.3 )

. This is in add ition to the req uired monthly audit

(or quarterly for high volume samplers) (40 CFR, Part 58, Appendix A, Sections 3.2.3

and 3.3.2.) These requirements are met by a combination of independent CAB and Air

Su rveillance & Analysis Section field operator audits.

Quality Assurance and Quality Control

Finding F1 :

The DOH Quality Management Plan (QMP), conditionally approved by EPA

Region 9 in 2005, has not been implemented.

Discussion:

The DOH QMP requires t hat the DOH environmental monitoring QA program be

lead by a central QA Manager. There have been no significant interactions

between the ambient air monitoring program and the DOH central QA program in

the past several years. This situation does not meet the requirement in 40 CFR

Part 58, Appendix A, Section 2 that all ambient air monitoring programs should

have a n operational Quality System.

### 37

Recommendation:

DOH must implement the QMP in existence or the ambient air monitoring

program must develop a separate quality system.

Finding F2 :

DOH‟s corrective action system is not comprehensive.

Discussion:

EPA quality management standards (EPA QA/R

- 2, Quality Improvement Section)

req uire that management and staff ensure that conditions impacting quali ty are

prevented or identified promptly, that they are fully defined and corrected, and

that measures are taken to prevent them from recurring

. The entire process should

be documented as corrective actions and tracked to successful closure. The CAB

has a formal process specifically for corrective actions of field performance

evaluations, however

, the resolution of the actions are not always clear to all

parties involved and are not approved by a QA manager. T here is no formal

corrective action process for field operations

. Air monitoring agencies should

have corrective action system s for all aspects (field, laboratory, data review, et

cetera) of their air monitoring program s . Th ese system s should allow for

corrective actions to be initiated by staff as w ell as auditors and data reviewers.

Recommendation:

The DOH air monitoring program should include a formal and comprehensive

corrective action process for all aspects of the air monitoring program

.

Finding F3 :

The CAB does not have current SOPs for the performance audit program.

Discussion:

All monitoring activities should be covered by an SOP that represents current

procedures.

Recommendation:

CAB should develop SOPs for their audit program.

Finding F4 :

The criteria used for gaseous audits d o not consider the current data quality

objectives (DQOs).

### 38

Discussion:

DOH uses audit criteria of 10% for O 3 

### audits and 15% for all other gaseous

pollutants. The national DQOs of gaseous pollutants

, as specified in 40 CFR Part

58, Appendix A, Sectio n 2.3

, are 7% for O 3 

### and 10% for all others. DOH needs

to tighten or modify the audit criteria so that some corrective actions are taken

when results are near the DQO limits. Note that criteria for audit points that fall

well below the NAAQS concentratio ns could be greater than the DQO levels.

Please see EPA‟s Technical Guidance on Assessment Statistics for Annual

Performance Evaluations

( http://www.epa.gov/ttn/amtic/files/ambient/pm25/datamang/20110217lowlevelst

atmemo.pdf

)

.

Recommendation:

DOH should incorporate the DQOs into the audit criteria. At a minimum the 7%

and 10% DQOs should be used as warning limits.

Finding F 5 :

DOH needs to develop a strategy for evaluating the PM 2.5 

### FEM data and

FEM/FRM collocations.

Discussion:

The DOH has converted to PM 2.5 

### FEM monitoring throughout their network. As

other agencies have noted that PM 2.5 

### FEMs may have a bias when compared to

the FRMs, EPA is investigating this further. As noted in the previous TSA, DOH

should be doing formal FEM/FRM data comparison s and evaluations.

Recommendation:

DOH should evaluate and understand the data produce d by the PM 2.5 

### FEM

monitors.

Finding F 6 :

The audit forms used by the CAB when conducting performance audits are not

routinely peer reviewed.

Discussion:

Peer r eview of technical evaluations should be done to ensure accuracy of the

information reported and to verify that the audits have been properly documented.

### 39

Recommendation:

The CAB should implement a system to conduct and document peer reviews of

performa nce audits.

Finding F7 : (Best Practices Recommendation)

The CAB does not perform statistical evaluations of the annual gaseous audit

results.

Discussion:

The CAB has criteria for acceptance of individual performance audits and

requests corrective acti on when these specifications are not met. AQS also

summarizes audit results across all the DOH stations with the required statistical

test specified in 40 CFR Part 58 Appendix A. However, the summaries of quality

control audits produced by AQS combine au dits by the field operators with audits

performed by the CAB. Because the CAB audits represent independent

equipment as well as an independent auditor, these results should be statistically

evaluated independently, as well being evaluated to determine ove rall network

performance and trends.

Recommendation:

Some of the simple statistical tests specified in EPA regulation should be

performed on the annual CAB audit data to evaluate overall network performance.

Finding F8 : ( Best Practices Recommendation)

DOH has not developed methods to conduct and evaluate audits from the gaseous

trace level monitors at the NCore site.

Discussion:

The field operations staff and the CAB auditor are working together to develop an

audit process for the trace level gaseou s instrument. Audits should be performed

in 2011 to validate performance of the NCore site.

Recommendation:

DOH should continue to develop and implement methods for trace level audits.

### 40

Finding F9 : ( Best Practices Recommendation)

DOH is not equipped t o perform audit s of relative humidity or solar radiation at

the NCore site.

Discussion:

Data on r elative humidity and solar radiation are being collected at the NCore site.

In order to verify that these methods are working properly

, they should be

peri odically audited with independent standards.

Recommendation:

DOH should develop methods to audit the relative humidity and solar radiation

sensors independently

.

Finding F10 : ( Best Practices Recommendation)

The CAB auditor is not currently auditing the high calibration range for SO 2



### .

Discussion:

The auditor indicated that audits of the high SO 2 

### calibration range are not

currently being conducted. Because readi ngs in this calibration range are used to

inform the public of potential health impacts

, th ey should be independently

verified on a regular basis.

Recommendation:

The CAB should perform audits of both SO 2 

### calibration ranges for the Big Island

stations.

Finding F11 : ( Best Practices Recommendation)

The amount of excess flow provided during the gaseous audits is not significantly

above the total system flow and is not verified by the auditor.

Discussion:

The amount of flow used during gaseous audits is set to match the flow of the

gaseous calibration checks. This flow rated is based on the c alculated flow of the

sampling system plus a slight excess. Because audits are meant to be independent

of the existing system and control for all problems, including inconsistent and/or

miscalculated flow rates, the amount of audit gas delivered should be based on

verification of excess flow. This means that the audit system should deliver

excess flow that is properly vented, so as not to pressurize the station‟s sampling

### 41 system. Excess flow should be verified at the audit system‟s vent line and/or at

th e sampling station inlet (depending on station configuration).

Recommendation:

Provide and verify excess flow when conducting gaseous audits.

### 42 APPENDIX A: Summary of Findings

A. Major Findings

GENERAL PROGRAM

Finding A1 :

Insufficient communication be tween the Air Surveillance & Analysis Section and

the CAB is compromising the quality of Hawaii‟s air monitoring program.

Finding A2 :

The EPA requirement for independent quality assurance is not being fully met.

Finding A3 :

The performance of EPA Metho d TO

- 15 is not meeting minimal data quality

requirements to characterize the low concentrations of toxics in ambient air.

Finding A4 :

Quality Assurance Project Plans (QAPPs) have not been completed or updated

since the last TSA.

Finding A5:

DOH shoul d have more formalized training requirements for new and existing

staff.

NETWORK MANAGEMENT

Finding B1 : While the volcanic activity on the Big Island is the state‟s highest air quality

concern, the Big Island monitoring network may have some redundancie s.

Finding B2 :

As was found with the 2008 TSA, the DOH ambient air monitoring program does

not have an up

- to

- date emergency episode plan for the Island of Hawaii.

FIELD OPERATIONS

Finding C1:

Gaseous inlet probe heights at the Big Island sites do not me et the CFR

requirement for height above the roof.

Finding C2 :

Maintenance and repairs of monitoring equipment used at the field stations were

not sufficiently documented. Maintenance sheets used to track instrument repairs

do not appear to be consistentl y available or utilized.

### 43

Finding C3 :

The documentation of PM 2.5 

### filter data from the site operators and feedback from

the analytical and validation process need to be improved.

Finding C4:

DOH is lacking a corrective action process for field operations.

Finding C5 :

Neither the field operations nor the CAB auditor document the quality of zero air

used in the program. This was a finding in the 2008 TSA.

Fi nding C6 :

Not all Big Island sites are recording the results of high range SO 2 

### precision and

zero/s pan calibrations.

Finding C7 :

There is a tree at the Hilo site that presents a significant siting issue and an

obstruction.

LABORATORY OPERATIONS

Finding D1 :

The use of the PM 2.5 

### weigh

- room is so low as to be inefficient and potentially

error prone.

F inding D2 :

Contamination from a performance evaluation sample may have caused erroneous

data to be reported to AQS

.

Finding D3 :

The sampling system for collection of carbonyl sample s is not routinely certified.

Finding D4 :

DOH should develop an approved method for laboratory analysis of Pb filters for

the NAAQS program.

Finding D5 :

Field blanks are not implemented for metals.

DATA AND DATA MANAGEMENT

Finding E1 :

Several incorrect flags were entered into AQS.

### 44

Finding E2 :

The first

- level of data valida tion by site operators is inconsistently executed.

Finding E3 :

Data validat ion is only performed at the end of the quarter , limiting the time for

review

.

QUALITY ASSURANCE AND QUALITY CONTROL

Finding F1 :

The DOH Quality Management Plan (QMP), conditio nally approved by EPA

Region 9 in 2005, has not been implemented.

Finding F2 : DOH‟s corrective action system is not comprehensive.

Finding F3 :

The CAB does not have current SOPs for the performance audit program.

Finding F4 :

The criteria used for gaseo us audits do not consider the current data quality

objectives (DQOs).

Finding F5 :

DOH needs to develop a strategy for evaluating the PM 2.5 

### FEM data and

FEM/FRM collocations.

Finding F6 :

The audit forms used by the CAB when conducting performance audits are not

routinely peer reviewed.

B. Minor Findings

FIELD OPERATIONS

Finding C8: (Best Practices Recommendation)

Filter tape from continuous instruments is not archived.

Finding C9: (Best Practices Recommendation)

The Mountain View site experie nces periodic temperature drift due to loss of

power.

### 45

Finding C10 : ( Best Practices Recommendation)

The sample residence times are not calculated and posted at each monitoring site.

LABORATORY OPERATIONS

Finding D6: ( Best Practices Recommendation)

The ve ndor does not provide an expiration date with the carbonyl sampling

media.

Finding D7: ( Best Practices Recommendation)

Staff at the PM 2.5 

### laboratory indicated that they have many more new filters than

they can use.

QUALITY ASSURANCE AND QUALITY CONTROL

Finding F7: (Best Practices Recommendation)

The CAB does not perform statistical evaluations of the annual gaseous audit

results.

Finding F8: ( Best Practices Recommendation)

DOH has not yet developed methods to conduct and evaluate audits from the

gaseou s trace level monitors at the NCore site.

Finding F9: ( Best Practices Recommendation)

DOH is not equipped to perform audits of relative humidity or solar radiation at

the NCore site.

Finding F10: ( Best Practices Recommendation)

The CAB auditor is not cu rrently auditing the high calibration range for SO 2



### .

Finding F11: ( Best Practices Recommendation)

The amount of excess flow provided during the gaseous audits is not significantly

above the total system flow and is not verified by the auditor.

### APPENDIX B : Hawaii Department of Health: Air Surveillance & Analysis Section and Clean Air Branch Staff

Air Surveillance & Analysis Section

Name Title Phone Fax Email

Castillo, Jeffrey AQET I 808

- 453

- 6620 808

- 453

- 6640 jeffrey.castillo@doh.hawaii.gov

Figueiroa, Carrie Clerk

- Steno II 808

- 453

- 6620 808

- 453

- 6640 carrie.figueiroa@doh.hawaii.gov

Furukawa, Eric AQET I 808

- 453

- 6620 808

- 453

- 6640 eric.furukawa@doh.hawaii.gov

Higashida, Harold AQET I 808

- 453

- 6620 808

- 453

- 6640 harold.higashida@doh.hawaii.gov

Ibara, Michael AQET II 808

- 453

- 6620 808

- 453

- 664 0 michael.ibara@doh.hawaii.gov

Licudine, Jocelyn Chemist III 808

- 453

- 6620 808

- 453

- 6640 jocelyn.licudine@doh.hawaii.gov

Lizama, Corey AQET I 808

- 453

- 662 0 808

- 453

- 6640 corey.lizama@doh.hawaii.gov

Nichols, Kimberly Chemist III 808

- 453

- 6620 808

- 453

- 6640 kimberly.nichols@doh.hawaii.gov

Shinsato, Terri ITS I V 808

- 453

- 6620 808

- 453

- 6640 terri.shinsato@doh.hawaii.gov

Suzuki, Darren Chemist III 808

- 453

- 6620 808

- 453

- 6640 darren.suzuki@doh.hawaii.gov

Tamashiro, Ma rk AQET I 808

- 453

- 6620 808

- 453

- 6640 mark.tamashiro@doh.hawaii.gov

Wallace, Lisa Chemist III 808

- 453

- 6620 808

- 453

- 6640 lisa.wallace@doh.hawaii.gov

Yee, Hen ry Chem i s t V

- Supervisor 808

- 453

- 6620 808

- 453

- 6640 henry.yee@doh.hawaii.gov



### Environmental Health Analytical Services Branch

Chang, Wanda Manager 808

- 453

- 6683 808

- 453

- 6685 

### wanda.chang@doh.hawaii.gov

Kiyokane, Richard QA Officer 808

- 453

- 6679 808

- 453

- 6685 

### richard.kiyokane@doh.hawaii.gov

Clean Air Branch

Name Title Section Phone Email

Wilfred K. Nagamine Manager (808) 586

- 4200 wilfred.nagamine@doh.hawaii.go v

Susan Kihara EHS IV Monitoring Section (808) 586

- 4200 susan.kihara@doh.hawaii.gov

Jensen Yoshimoto EHS IV Monitoring Section (808) 586

- 4200 jensen.yos himoto@doh.hawaii.gov

Crystal Peltier EHS IV Monitoring Section (808) 586

- 4200 crystal.peltier@doh.hawaii.gov

Gary Wu EHS IV Monitoring Section (808) 586

- 4200 gary.wu@doh.hawaii.gov

Lisa Young EHS V

- Supervisor Monitoring Section (808) 586

- 4200 lisa.young@doh.hawaii.gov

AQET = Air Quality Electronic Technician

ITS = Information Technology Specialist

EHS = E nvironmental Health Specialist

### 47

APPENDIX C: EPA Quality Assurance Handbook, Appendix H, as filled out by Hawaii

Department of Health

– Clean Air Branch, and Air Surveillance & Analysis Section

### 48 

# Appendix H

– As filled out by Hawaii Department of Health, Clean Air Branch

January 7, 2011



# United States Environmental Protection Agency

National Ambient Air Monitoring Technical System Audit Form

### 49



## 1) General / Quality Management

State/ Local / Tribal Agency Audited: Hawaii State Dep artment of Health, Clean Air Branch

Address: 919 Ala Moana Blvd.

City, State, and Zip Code: Honolulu, HI 96814

Date of Technical System Audit: January 24

- 27, 2 011

Auditor / Agency: U.S. EPA Region 9



## a) Program Organization

1) Key Individuals

1.1) Agency Director: Wilfred Nagamine, Manager, Clean Air Branch (CAB)

1.2) Ambient Air Monitoring (AAM) Network Man ager: Lisa Young, Supervisor, Monitoring

Section (CAB)

1.3) Quality Assurance Manager:

1.4) QA Auditors: Jensen Yoshimoto, Environmental Health Specialist, Monitoring Section

(CAB)

1.5) Field Operations Supervisor / Lead:

1.6) Laboratory Supervisor:

1.7) QA Laboratory Manager:

1.8) Data Management Supervisor / Lead:

Attach an Organizational Chart : Will be provided during the audit.

Flow Chart:

### 50

Key position staffing. Number of personnel available to each of the following program areas:

Program Area Number of

People

Primary Number of

People

Backup V acancies Program Area Number

of People

Primary Number

of People

Backup Vacancies

Network

Design and

Siting 1 1 0 Data and Data

Management 1 0 0

QC activities Equipment

repair and

maintenance

QA activities 1 1 0 Financial

Management



### List available personnel by name and percentage of time spent on each task category

Name Network

Design

and siting QC

activities QA

activities Equipment repair

and maintenance Data and

Da ta Management Financial

Management

Crystal Peltier 10%

Gary Wu 10%

Jensen

Yoshimoto 5% 20% 10% 10% 10%

Susan Kihara 25% 10% 25%

Lisa Young 10% 10% 10% 10%



### Comment on the need for additional personnel, if applicable

List personnel who have authority or are responsible for:

Activity Name Title

QA Training Field/Lab

Grant Management Lisa Young Supervisor, Monitoring Section

(CAB)

Purchases greater than $500 Lisa Young/ Jensen Yoshimoto

Equipment and Servi ce Contract

Management Jensen Yoshimoto/ Gary Wu

Staff appointment

## c) Independent Quality Assurance and Quality Control

1. Status of Quality Assurance Program

Question Yes No Comment

Does the agency perform QA activities with

internal personnel? If no go to Section d. X

Does the agency maintain a separate

laboratory to support quality assurance

activities? X

Has the agency documented and

implemented specific audit procedures

separate from monitoring procedures? X

Are there two levels of m anagement

separation between QA and QC operations?

Please explain: X

See attached Organizational Chart

Does the agency have identifiable auditing

equipment and standards (specifically

intended for sole use) for audits? X



### 2. Internal Performance Audits

Question Yes No Comment

Does the agency have separate facilities to

support audits and calibrations? X

If the agency has in place contracts or similar agreements either with another agency or contractor to perform

audits or calib rations, please name the organization and briefly describe the type of agreement.

Clean Air Branch conducts performance audits of all DOH monitoring stations annually.

If the agency does not have a performance audit SOP (included as an attachment), ple ase describe performance

audit procedure for each type of pollutant.

See attachment 1

Does the agency maintain independence of audit

standards and personnel? X Clean Air Branch personnel conduct audits

with independent equipment.

Please provide inform ation on certification of audit standards currently being used. Include information on

vendor and internal or external certification of standards.

See attachment 2

Does the agency have a certified source of zero

air for performance audits? X Currently using Environics 7000 zero air

generator

Does the agency have procedures for auditing

and/or validating performance of

Meteorological monitoring? X

Please provide a list of the agency‟s audit equipment and age of audit equipment.

See attachment 3

### 52

Is audit equipment ever used to support routine

calibration and QC checks required for

monitoring network operations? X

If yes, please describe.

Are standard operating procedures (SOPs) for

air monitoring available to all field personnel? X

Has the agency established and has it

documented criteria to define agency

- acceptable

audit results? X

Please complete the table below with the pollutant, monitor and acceptance criteria.

Pollutant How is performance tracked (e.g., con trol

charts) Audit Result Acceptance

Criteria

CO Percent dif. of each audit level

< 15%

O 3 Percent dif. of each audit level

< 15%

NO 2 Percent dif. of each audit level

< 15%

SO 2 Percent dif. of each audit level

< 15%

Continuous PM 10 Flow + 4% of audit standard,

Temp + 2 ° C, Pres + 10 mm Hg

PM 2.5 Flow + 4% of audit standard,

Temp + 2 ° C, Pres + 10 mm Hg

Pb

- TSP* + 10% of design value

VOCs

Carbonyl s

PM 2.5 speciation Flow < 10% of audit standard, Temp + 2 ° C, Pres + 10 mm Hg

PM 10

- 2.5 speciation

PM 10

- 2.5 FRM Mass

Continuous PM 2.5 Flow + 4% of audit standard, Temp + 2 ° C, Pres + 10 mm Hg

Trace Levels (CO)

Trace Levels (SO 2 )

Trace Levels (NO)

Trace Levels (NOy)

Surface

Meteorology Wind Dir. + 5 Deg , Wind

sp eed + 5%, Temp + 1 ° C

Others

*If Pb

- PM 10 data are being collected, please enter this information under “Others .”

### 53

Question Yes No Comment

Were these audit criteria based on, or derived from, the

guidance found in Volume II of the QA Handbo ok for

Air Pollution Measurement System, Section 2.0.12? X If no, please explain.

If yes, please explain any changes or

assumptions made in the derivation.

What corrective action may be taken if criteria are exceeded? If possible, ind icate two examples of corrective

actions, taken within the period since the previous systems audit which are based directly on the criteria dis cussed

above.

Corrective Action # 1

Continuous PM2.5 failed flow audit. Pinholes discovered in tape, techni cian cleaned BAM nozzle, cross

hair plate, capstan, and pinch roller.

Corrective Action #2

### 54



## d) Planning Documents including QMP, QAPP, &SOP

f) Training

QMP questions Yes No

Does the agency have an EPA

- approved

quality management plan? X Yes for Environmental Management Division

No t for the Clean Air Branch

If yes, have changes to the plan been

approved by the EPA? X Not for the Clean Air Branch

Has the QMP been approved by EPA

within the last five years? X

Please provide: Date of Original Approval 4/2002 Date of Last Revision : 4/2003 Date of Latest

Approval :

QAPP questions Yes No Comment

Does the agency have an EPA

- approve d

quality assurance project plan? X PM2.5, PM Speciation and Air Toxics

Not for Criteria gasses and PM10

If yes, have changes to the plan been

approved by the EPA? X Need to update PM2.5, PM Speciation and URG

Has the QAPP been reviewed by EPA

annu ally? X

Please provide: Date of Original Approval PM2.5 12/9/1998 Date of Last Revision 2/2008 Date of Latest Approval

Does the agency have any revisions to your

QA project plan still pending? X

How does the agency verify the QA projec t

plan is fully implemented?

How are the updates distributed?

What personnel regularly receive updates?

SOP questions

Has the agency prepared and implemented

standard operating procedures (SOPs) for

all facets of agency operation?

Do the SOPs adequately address

ANSI/ASQC E

- 4 quality system required

by 40 CFR 58, Appendix A?

Are copies of the SOP or pertinent sections

available to agency personnel?

How does the agency verify that the SOPs

are implemented as provided?

How ar e the updates distributed?

### 55

Question Yes No Comment

Does the agency have a training program and training plan? X No formal training plan

Where is it documented? In our personnel file,

Does it make use of seminars, courses, EPA sponsored

college level courses? X

Are personnel cross

- trained for other ambient air monitoring

duties? X Within the CAB

Are training funds specifically designated in the annual

budget? Not sure but have used WESTAR

Does the training plan i nclude : Yes No Comment

Training requirements by position

Frequency of training

Training for contract personnel

A list of core QA related courses

Indicate below the three most recent training events and identify the per sonnel participating in them.

Event Dates Participant(s)

URG and PM Speciation Training April 13

- 15, 2009 Monitoring Section



### Note: We were not able to get documentation (certificates for the training above). I

requested numerous ti mes with no reply.

CAB has also requested training from the Air Surveillance & Analysis Section for the

new data acquisition system and website.

### 56 

# Appendix H

As filled out by Hawaii Department of Health, Air Surveillance & Analysis Section

January 10, 2011



# United States Environmental Protection Agency

National Ambient Air Monitoring Technical System Audit

Form

### 57

### 58 Page intentionally left blank

### 59

Table of Contents

1) General / Quality Management

a) Program Organiz ation

b) Facilities

c) Independent Quality Assurance and Quality Control

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

e) General Documentation Policies

f) Training

g) Corrective Action

h) Quality Improvement

i) External Performance Audits

2) Networ k Management / Field Operations

a) Network Design

b) Changes to the Network since the last audit

c) Proposed changes to the Network

d) Field Support

i) SOPs

ii) Instrument Acceptance

iii) Calibration

iv) Repair

v) Site and Monitor Information Form

3) Labor atory Operations

a) Routine Operations

b) Quality Control

c) Laboratory Preventive Maintenance

d) Laboratory Record Keeping

e) Laboratory Data Acquisition and Handling

f) Specific Pollutants: PM 10, PM 2.5 and Lead

4) Data and Data Management

a) Data Handli ng

b.) Software Documentation

c) Data Validation and Correction

d) Data Processing

e) Internal Reporting

f) External Reporting

### 60



## 1) General / Quality Management

State/ Local / Tribal Agency Audited: State of Hawaii, Department of Health, Stat e

Laboratories Division, Environmental Health Analytical Services Branch, Air Surveillance

& Analysis Section

Address: 2725 Waimano Home Road

City, State, and Zip Code: Pearl City, Hawaii 96782

Date of Technical System Audit:

Au ditor / Agency:



## a) Program Organization

1) Key Individuals

1.1) Agency Director: Dr. Chris Whelen

1.2) Ambient Air Monitoring (AAM) Network Manager:

1.3) Quality Assurance Manager:

1.4) QA Auditors: Richard Kiyokane

1.5) Field Operat ions Supervisor / Lead: Michael Ibara

1.6) Laboratory Supervisor: Henry Yee

1.7) QA Laboratory Manager: Wanda Chang

1.8) Data Management Supervisor / Lead: Terri Shinsato

DOH = Department of Health, State of Hawaii; EHA = Environmental Health Administ ration; SLD = State

Laboratories Division; EHASB = Environmental Health Analytical Services Branch; ASAS = Air Surveillance &

Analysis Section. EMD = Environmental Management Division; CAB = Clean Air Branch; AQET=Air Quality

Electronic Technician; DOA=De partment of Agriculture; DVP=Data Validation Person; ITS=Information

Technology Specialist;



### Attach an Organizational Chart: See attached diagram , SLD Organization Chart

### 61

Flow Chart:

Key position staffing. Number of personnel available to each of the f ollowing program areas:

Program Area Number of

People

Primary Number of

People

Backup Vacancies Program Area Number

of People

Primary Number

of People

Backup Vacancies

Network

Design and

Siting 0 0 Data and Data

Management 1 0

QC activities 6 0 Equipment

repair and

maintenance 6 1

QA activities 5

2* 1 Financial

Management 1 1

*Data audits by DVP



### List available personnel by name and percentage of time spent on each task category

Name Network

Design

and siting QC

activities QA

activit ies Equipment repair

and maintenance Data and

Data Management Financial

Management

Wanda Chang 5 95

Henry Yee 5 15 75

Michael Ibara 5 85 10

Terri Shinsato 100

Richard

Kiyokane 100

Kimberly Nichols 30 60 10

Lisa Wallac e 1 50 35 5 9



### Comment on the need for additional personnel, if applicable

Nee d s another full time field technician on the Big Island

– Currently seven monitoring stations and one more in the

near future. Goal: Faster response time should reduce instru ment downtime.



### List personnel who have authority or are responsible for:

Activity Name Title

QA Training Field/Lab Michael Ibara/Richard Kiyokane AQET Supervisor/QA Officer

Grant Management Wanda Chang Branch Chief, EHASB

Purchases greater than $ 500 Wanda Chang Branch Chief, EHASB

Equipment and Service Contract

Management Henry Yee ASAS Supervisor

Staff appointment Wanda Chang Branch Chief, EHASB

### 62



## b) Facilities

Identify the principal facilities where the agency conducts work that is related to air monitoring. Do not include

monitoring stations but do include facilities where work is performed by contractors or other organizations.

Facility AAM Function Offices responsible for

ensuring adequacy Location Adequate Y/N

(To be completed b y

auditor)

Instrument repair ASAS SLD, Room #

3116

Certification of Standards e.g.

gases, flow transfers, MFC ASAS Vendor

certification’s

facilities

PM filter weighing ASAS SLD, Room

#3104

Data verification and processing

ASAS SLD, Room

#3105; Hilo

District Office

General office space ASAS SLD, Hilo District

Health Office

Storage space, short and long

term ASAS SLD, Hilo District

Health Office

Air Toxics (Carbonyls, VOC s,

Metals): ASAS SLD, Rooms

#3207, 3203,

3206.

Indicate any fa cilities that should be upgraded. Identify by function and any suggested improvements or

recommendations

Monitoring stations

– Puna E & H

Are facilities adequate concerning safety? Yes / No Please explain if answer is no any suggested

improvement s or recommendations

No, most monitoring stations need hand railings on roof for technicians servicing roof monitors, met sensors and

probes.

Are there any significant changes which are likely to be implemented to agency facilities within the next on e to two

years? Comment on agency‟s needs for additional physical space (laboratory, office, storage, etc.).

Facility Function Proposed Change

- Date

None

### 63



## c) Independent Quality Assurance and Quality Control

1. Status of Quality Assu rance Program

Question Yes No Comment

Does the agency perform QA activities with

internal personnel? If no go to Section d. X Field & data audits

Does the agency maintain a separate

laboratory to support quality assurance

activities? X

Has the agenc y documented and

implemented specific audit procedures

separate from monitoring procedures? X Data audit SOP

Are there two levels of management

separation between QA and QC operations?

Please explain: X X Yes

- SLD

- QA responsible for lab analysis; No

- field

audits performed by AQET. Yes

- data validation. See

attached organization chart , SLD Organization Chart

Does the agency have identifiable auditing

equipment and standards (specifically

intended for sole use) fo r audits? X



### 2. Internal Performance Audits

Question Yes No Comment

Does the agency have separate facilities to

support audits and calibrations? X

If the agency has in place contracts or similar agreements either with another agency o r contractor to perform

audits or calibrations, please name the organization and briefly describe the type of agreement.

CAB conducts performance audits of criteria pollutants & meteorological sensors.

If the agency does not have a performance audit S OP (included as an attachment), please describe performance

audit procedure for each type of pollutant.

Does the agency maintain independence of audit

standards and personnel? X X ASAS: No independent personnel; yes for

independent audit standards.

Please provide information on certification of audit standards currently being used. Include information on

vendor and internal or external certification of standards.

See attached, Audit equipment Cert.

Does the agency have a certified source of zero

air for performance audits? X

Does the agency have procedures for auditing

and/or validating performance of

Meteorological monitoring? X

Please provide a list of the agency‟s audit equipment and age of audit equipment.

See attached, Audit equipment Cert.

### 64

Is audit equipment ever used to support routine

calibration and QC checks required for

monitoring network operations? X

If yes, please describe.

Are standard operating procedures (SOPs) for

air monitoring available to all field personnel? X

Has the agency established and has it

documented criteria to define agency

- acceptable

audit results? X

Please complete the table below with the pollutant, monitor and acceptance criteria.

Pollutant How is performance tracked (e .g., control

charts) Audit Result Acceptance

Criteria

CO Zero/span log & QC sheet Zero: ± 1.0 ppm; Span ± 2.0

ppm

O 3 Zero/span log & QC sheet Zero: ± 10 ppb; Span: ± 20

ppb

NO 2 Zero/span log & QC sheet Zero: ± 10 ppb; Span: ± 20

ppb

SO 2 , 500 pp b F.S. Zero/span log & QC sheet Zero: ± 10 ppb; Span: ± 20

ppb

SO 2 , 1000 ppb F.S. Zero/span log & QC sheet Zero: ± 10 ppb; Span: ± 30

ppb

Continuous PM 10 QC sheet ± 4% of 16.67 LPM

PM 2.5 Sampler Daily Use Maintenance Form ± 4% of 16.67 LPM

Pb

- T SP* Sample Flow Check Data Sheet ± 10% of 1.13 m3/min

VOCs Flow rate control ±10% of 50 cc/min

Carbonyls Flow rate control ±10% of 100 cc/min

PM 2.5 speciation Flow rate control ±10% of 6.7 LPM

- SASS

±10% of 22 LPM

- URG 3000N

PM 10

- 2.5 speciatio n

PM 10

- 2.5 FRM Mass Flow rate control ±4% of 16.67 LPM

Continuous PM 2.5 Flow rate control ±4% of 16.67 LPM

Trace Levels (CO) Zero/span log & QC sheet Zero: ± 40ppb;

Span: 4500 ppb ± 10%

Trace Levels (SO 2 ) Zero/span log & QC sheet Zero: ± 0.100ppb;

S pan 90 ppb ± 10%

Trace Levels (NO) Zero/span log & QC sheet ?

Trace Levels (NOy) Zero/span log & QC sheet 180 ppb ± 10%

Surface

Meteorology ?

### 65

Others

*If Pb

- PM 10 data are being collected, please enter this information under “Others.”

Ques tion Yes No Comment

Were these audit criteria based on, or derived from, the

guidance found in Volume II of the QA Handbook for

Air Pollution Measurement System, Section 2.0.12? X If no, please explain.

If yes, please explain any cha nges or

assumptions made in the derivation.

What corrective action may be taken if criteria are exceeded? If possible, indicate two examples of corrective

actions, taken within the period since the previous systems audit which are based directly on the criteria dis cussed

above.

Corrective Action # 1

Repair and calibrate analyzer

Corrective Action #2

Troubleshoot and repair calibration equipment

### 66



## d) Planning Documents including QMP, QAPP, &SOP

QMP questions Yes No

Does the agency have a n EPA

- approved

quality management plan?

If yes, have changes to the plan been

approved by the EPA?

Has the QMP been approved by EPA

within the last five years?

Please provide: Date of Original Approval Date of Last Revision: Date of Latest Approval:

QAPP questions Yes No Comment

Does the agency have an EPA

- approved

quality assurance project plan?

If yes, have changes to the pl an been

approved by the EPA?

Has the QAPP been reviewed by EPA

annually?

Please provide: Date of Original Approval Date of Last Revision Date of L atest

Approval

Does the agency have any revisio ns to your

QA project plan still pending?

How does the agency verify the QA project

plan is fully implemented?

How are the updates distributed?

What personnel regularly receive updates?

SOP questions

Has the agency prepared and imp lemented

standard operating procedures (SOPs) for

all facets of agency operation? X NCore and new data acquisition system

Do the SOPs adequately address

ANSI/ASQC E

- 4 quality system required

by 40 CFR 58, Appendix A?

Are copies of the SOP or pert inent sections

available to agency personnel? X

How does the agency verify that the SOPs

are implemented as provided? DVP staff

How are the updates distributed? Updated and approved SOPs posted on SharePoint

### 67



## e) General Documentation Policies

Question Yes No Comment

Does the agency have a documented records management

plan? X

Does the agency have a list of files considered official records

and their media type I.E. paper, electronic? X

Does the agency have a schedule for retenti on and disposition

of records? X

Are records for at least three years? X

Who is responsible for the storage and retrieval of records? ITS IV

What security measures are utilized to protect records? Electronic FOBs required for entry into lab;

m echanical door locks for individual rooms.

Documents are backed up and password

protected.

Where/when does the agency rely on electronic files as

primary records? Once the continuous data is retrieved from the

datalogger, the database is the primary rec ord.

ASAS relies on electronic files as primary records for

continuous data and diagnostics including site logs

but excluding particulates. In addition, most

manual method instrument diagnostics are primary

electronic files.

What is the system for the s torage, retrieval and backup of

these files? Computer server for DR DAS Envista ARM database

is backed up.

### 68



## f) Training

Question Yes No Comment

Does the agency have a training program and training plan? X

Where is it documented?

Does it make use of seminars, courses, EPA sponsored

college level courses? X EPA sponsored seminar

Are personnel cross

- trained for other ambient air monitoring

duties? X In progress

Are training funds specifically designated in the annual

budget? X

Does the training plan include: Yes No Comment

Training requirements by position X

Frequency of training X

Training for contract personnel X

A list of core QA related courses X

Indicate below the three most recent trainin g events and identify the personnel participating in them.

Event Dates Participant(s)

NCore Seminar at Sacramento, CA August 2008 Michael Ibara and Harold Higashida.

Safety Training (on

- line) December 2010 All ASAS staff.

### 69

O versight of Contractors and Suppliers

Question Contractors Yes No Comment

Who is responsible for oversight of contract personnel?

What steps are taken to ensure contract personnel meet

training and experience criteria?

How often are co ntracts reviewed and /or renewed?

Question Suppliers

Have criteria and specification been established for

consumable supplies and for equipment? X Per manufacturers’ recommendations

What supplies and equipment have established

specifications? All equipment and supplies

Is equipment from suppliers open for bid? X Per purchasing rules



## g) Corrective Action

Question Yes No Comment

Does the agency have a comprehensive corrective

action program in place and operational? X

Have th e procedures been documented? X

As a part of the QA project plan? X

As a separate standard operating procedure? X

Does the agency have established and documented

corrective limits for QA and QC activities? X

Are procedures implemented for corrective actions

based on results of the following which fall outside

the established limits:

Performance evaluations X

Precision goals X

Bias goals X

NPAP audits X

### 70 PEP audits (PM and Pb) X

Vali dation of one point QC check goals X

Completeness goals X

Data audits X

Calibrations and zero span checks X

Technical Systems Audit X

Have the procedures been documented? X

How is responsibility for implementing c orrective actions assigned? Briefly discuss.

QA Officers notify ASAS supervisor with a written audit report of findings. Signed corrective action form is

completed and returned to QA Officers.

How does the agency follow up on implemented corrective a ctions?

Field: contact site operator

Lab: subsequent QC checks

Briefly describe recent examples of the ways in which the above corrective action system was employed to remove

problems.

Level 1 span check failed, site operator notified, site operator tro uble

- shooted, repaired, & calibrated analyzer.

Operator monitored subsequent data & QC checks.



## h) Quality Improvement

Question Yes No Comment

What actions were taken to improve the quality system

since the last TSA? Installed new d ata logging systems at all sites . Initiated

file server storage for electronic documents.

Since the last TSA do your control charts indicate that the

overall data quality for each pollutant steady or X

### 71

improving?

For areas where data quality appears to be declining has a

cause been determined? X

Have all deficiencies indicted on the previous TSA been

corrected? X

If not explain.

Need a Quality Management Plan.

Are there pending plans for quality improvement such as

purchase of new or i mproved equipment, standards, or

instruments? X If funds are available.

### 72



## i) External Performance Audits

Question Yes No Comment

Does your agency participate in NPAP, PM2.5 PEP, Pb PEP

and other performance audits performed by an external party

and/o r using external standards. X

If the agency does not participate, please explain why not:

Are NPAP audits performed by QA staff, site operators,

calibration staff, and/or another group? X



### National Performance Audit Program (NPAP) and Addition al Audits

Does the agency participate in the National Performance Audit Program (NPAP) as

required under 40 CFR 58, Appendix A? If so, identify the individual with primary

responsibility for the required participation in the National Performance Audit Pro gram.

Name: Program function:

Please complete the table below:

Parameter Audited Date of Last NPAP Audit

CO 2010

O 3 2010

SO 2 2010

NO 2 2010

PM 10 2010

PM 2.5 2010

Pb 2008

VOCs 2 008

Carbonyls 2008

### 73



## 2) Network Management/Field Operations

State/Local/Tribal Agency Audited:

Address:

City, State, and Zip Code:

Auditor / Agency:

Key Individuals

Ambient Air Monitoring Network Manager:

Quality Assurance Manager:

Field Ope rations Supervisor/Lead:

Field Operations Staff involved in the TSA:

### 74 1 NCore

- National Core monitoring stations; SLAMS

- state and local air monitoring stations; SPM

- special purpose monitors; PAMS

- photochemical assessment monitoring stations

* monitoring will begin 1/1/11 ** NCore Pb monitoring pending EPA guidance + Kapolei station also SLAMS

Indicate by Site ID # any non

- conformance with the requirements of 40 CFR 58, Appendices D and E, along with any waivers granted

by the Regional Office (provide waiver documentation)

Monitor Site ID Reason for Non

- Conformance

SO 2 150012010 Probe height < 2 meters above ground for primary purpose of monitoring

for H 2 S

O 3

CO

NO 2

PM 10

PM 2.5

Pb 

## a) Network Design

Complete the table below for each of the pollutants monitored as part of your air monitoring network. (Record applicable cou nt by

category.) Also indicate seasonal monitoring with an S for a Parameter/Category as appropriate. Provid e the most recent annual

monitoring network plan, including date of approval and AQS quicklook or if not available, network description and other simi lar

summary of site data, including SLAMS, Other and Toxics

Category SO 2 NO 2 CO O 3 PM 10 PM 2.5 Pb Other

(type) Other

(type)

NCore 1 1 1 1 1* 1 1 1** PM 2.5 spec. PM 10

- 2.5

SLAMS 3 + 2 + 2 + 1 4 + 5 +

SPM 6 5 1 1 AT

PAMS

Total 10 3 3 2 5 11 2**

Question Yes No Comme nt

What is the date of the most current Monitoring Network Plan? July 1, 2010

I. Is it available for public inspection 

### 

II. Does it include the information required for each site?

AQS Site ID # 

### 

Street address and geographic coordinates 

### 

Sampling and Analysis Method(s) 

### 

Operating Schedule 

### 

Monitoring Objective and Scale of Representativeness 

### 

Site suitable/not suitable for comparison to annual PM 2.5 NAAQS? 

### 

MSA, CBSA or CSA indicated as required? 

### 

### 75



## b) Changes to the Network since the last audit

W What is the date of the most recent network assessment? (Provide copy) July 1, 2010

Ar Are al l SLAMS parameters included? Yes.

Others? Air Toxics, H 2 S

Please provide information on any site changes since the last audit

Pollutant Site ID Site Address Site

Added/Deleted/R

elocated Reason (Assessment, lost lease, etc.

Provide documentation of reason for each site change.)

SO 2 150031006 92

- 670 Farrington

Hwy. Kapo lei Deleted Low value site; site slated for future development

PM 2.5

co

- located 150031001 1250 Punchbowl St.,

Honolulu Deleted Extra co

- located site discontinued to maximize resources. FRM

moved to Pearl City co

- located site

PM 2.5 Speciation 150032004 8 60 4 th St.

Pearl City Relocated Moved to the NCore station in Kapolei

PM 10 150090006 Hale Piilani Park,

Kihei, Maui Deleted SPM monitor closed to conserve resources

SO 2 , PM 2.5 150012020 92

- 6091 Orchid

Mauka Cir., Ocean

View, Hawaii Added For downwind mon itoring of volcanic emissions

SO 2 , PM 2.5 150012017 170860 Volcano Rd.,

Mt. View, Hawaii Relocated Site shut

- down on 10/27/10 and being relocated to Mt. View

Elementary School Question Yes No Comment

Are hard copy site information files retained by the agency for all

air monitoring stations within the netw ork? 

### 

Does each station have the required information including:

AQS Site ID Number? 

### 

Photographs/slides to the four cardinal compass points? 

### 

Startup and shutdown dates? 

### 

Documentation of instrumentation? 

### 

Who has custody of the c urrent network documents Name: Susan Kihara

Title: Environmental Health Specialist

Does the current level of monitoring effort, station placement,

instrumentation, etc., meet requirements imposed by current grant

conditions? 

### 

How often is the networ k siting reviewed? Frequency: Annually

Date of last review: February 2010

Are there any issues 

### 

Do any sites vary from the required frequency in 40 CFR 58.12? 

### 

Does the number of collocated monitoring stations meet the

requirements of 40 CFR 58 Appendix A? 

### 

### 76



## d) Field Support

Question Yes No Comment

On average, how often are most of your stations visited by a field

operator? 1

_ per

_ week

_

Is this visit frequency consistent for all reporting organizations within

your agency? X Remote sites are visited less

frequently

On average, how many stations does a single operator have responsibility

for? 2

How many of the stations of your SLAMS/NCORE network are equipped

with sampling manifolds? 6

Do the sample inlets and manifolds meet the requirements for through the

probe audits? X

I. Briefly describe most common manifold type CARB octopus type

II. Are Manifolds cleaned periodically X How often? Inspected on site visits;

cleaned as needed

I II. If the manifold is cleaned, what is used to perform cleaning water , brush & rinse

IV. Are manifold(s) equipped with a blower X

V. Is there sufficient air flow through the manifold at all times? X Approximate air flow: 3

– 5 LPM

VI. How is the air flow through the manifold monitored? Rotameter and magnehelic gauge

VII. Is there a conditioning period for the manifold after cleaning? X Length of time:

VIII. What is the residence time? On average, less than 20 seconds.

Sampling lines: 1) What material is used for instrument sampling lines? Teflon. 

## c) Proposed changes to the Network

W Are future network changes propose d? Yes.

Please provide information on proposed site changes, including documentation of the need for the change and any required

approvals

Pollutant Site ID Site Address Site to be

Added/Deleted/

Relocated Reason (Assessment, lost lease, etc.

Provide documentation of reason for each site

change.)

PM 10 , SO 2 , NO 2 150030011 Ko‟Olina Golf

Course Delete Low value site, resources needed in areas identified by

the state as high priority monitoring . Data and

documentation to be presented to EPA Region 9 for

approval prior to discontinuance.

PM 2.5 , SO 2 , NO 2 , CO TBD 2342 Hulemalu Rd.,

Niumalu Kauai Add SPM to monitor cruise ship emissions

PM 2.5 , SO 2 TBD Waikaloa, Hawaii Add SPM to monitor volcanic emissions on the northwest side

of Hawaii island

PM 2.5 co

- loc ated 150032004 860 4 th St., Pearl City,

HI Relocate Co

- located monitors to be relocated to Kapo lei

(150030010). EPA Regional approval received.

### 77 2) How often are lines changed? As needed.

Do you utilize uninterruptable power supplies or backup power sources at

your sites? X

What instruments or devices are protected? X Gas monitors, data loggers,

calibrators and modems.



### i). SOPs

Question Yes No Comment

Is the documentation of monitoring SOPs complete? X

Are any new monitoring SOPs needed? X NCore

Are such procedures available to all field o perations personnel? X

Are SOPs that detail operations during episode monitoring

prepared and available to field personnel? X

Are SOPs based on the framework contained in Guidance for

Preparing Sta200ndard Operating Procedures EPA QA/G

- 6? X



### Please complete the following table:

Pollutant Monitored Date of Last SOP Review Date of Last SOP Revision

SO 2 2008 2008

NO 2 2008 2008

CO 2008 2008

O3 2008 2008

PM 10 2008 2008

PM 2.5 FRM mass 2008 2008

Pb

– TSP* 2008 2008

PM 2.5 speciation 2008 2008

PM 10

- 2.5 FRM mass

PM 10

- 2.5 speciation 2008 2008

Continuous PM 2.5 mass 2008 2008

Trace levels (CO)

### 78

Trace levels (SO 2 )

Trace levels (NO)

Trace levels (NOy)

Total reactive nitrogen

Surface Meteorology

Wind speed and direction, temperature, RH,

precipitation and solar radiation

Others

*If Pb

- PM 10 data are being collected, please enter this information under “Others.”



### ii). Instrument Acceptance

Has your agency obtained necessary waiver provisions to operate equipment which does not meet the

effective reference and equivalency requirements? List

all waivers.

Please list instruments in your inventory

Pollutant Number Make and Models Reference or Equivalent number

SO 2 10 Thermo Environmental Inst ruments

43C, 43i EQSA

- 0486

- 060

NO 2 2 Thermo Environmental Instruments

42C RFNA

- 1289

- 074

CO 2 Thermo Environmental Instruments

48C RFCA

- 0981

- 054

O3 1 Thermo Environmental Instruments

49C EQOA

- 0880

- 047

1 American Ecotech Serinus 10

PM 10 4 Met One Instruments BAM 1020 EQPM

- 0798

- 122

PM 2.5 2 Graseby Andersen Model RAAS2.5

- 300 PM2.5 Sequential Ambient Air

Sampler RFPS

- 0598

- 120

1 BGI Inc. Models PQ200 RFPS

- 0498

- 116

Pb

- TSP* 2 Graseby Andersen/GMW Model

1200 High

- Volume Air Sampler;

Manual Referenc e Method: 40 CFR

Part 50, Appendix B RFPS

- 1287

- 063 or RFPS

- 1287

- 064

Multi gas calibrator 13 Thermo Environmental Instruments

Model 146

Environics 6100

PM 2.5 speciation 1 Met One SASS MetOne SASS Method 118

1 URG 3000N URG 3000 Method 838

PM 10

- 2.5 speciation 0

PM 10

- 2.5 FRM mass 1 Met One Instruments BAM

- 1020

PM10

- 2.5 Measurement System EQPM

- 0709

- 185

Continuous PM 2.5 mass 10 Met One Instruments BAM 1020Met

One BAM

- 1020 Monitor

– PM2.5

FEM Configuration EQPM

- 0308

- 170

Trace levels (CO) 1 Teledyne API 300EU RFCA

- 1093

- 093

### 79

Trace levels (SO 2 ) 1 Teledyne API 100EU EQSA

- 0495

- 100

Trace levels (NO) 1 American Ecotech 9843

Trace levels (NOy) 1 American Ecotech 9843

Surface Meteorology 14 RM Young WD/WS 05103VP

Others

* If Pb

- PM 10 data are being collected, please enter this information under “Others.”



### Please comment briefly and prioritize your currently identified instrument needs.

Question Yes No Comment

Are criteria established for field QC equipment? X

Are criteria established for field QC gas standards? X



### iii ) Calibration

Please indicate the frequency of multi point calibrations.

Pollutant Frequency Name of Calibration Method

SO2, O3, CO, NO2, H2S Monthly or as needed Gas dilution

Continuous PM 2.5 6 Months or as needed Reference flow device

Continuous PM 10 6 Months or as needed Reference flow device

Question Yes No Comment

Are field calibration procedures included in the document/SOPs? X Location (site, lab etc.): site and lab

Are calibrations performed in keeping with the guidance in

section Vol II of the QA Handbook for Air Pollution

Measurement Systems? X

If no, why not?

Are calibration procedures consistent with the oper ational

requirements of Appendices to 40 CFR 50 or to analyzer

operation/instruction manuals? X

If no, why not?

Have changes been made to calibration methods based on

manufacturer‟s suggestions for a particular instrument? X

Do standard materials used for calibrations meet the requirements

of appendices to 40 CFR 50 (EPA reference methods) and X

Comment on deviations

### 80

Appendix A to 40 CFR 58 (traceability of materials to NIST

SRMs or CRMs)?

Are all flow

- measurement devices checked and certified? X

Additional comments:

Please list the authoritative standards used for each type of flow measurement, indicate the certification frequency of stand ards

to maintain field material/device credibility.

Flow Device Primary Standar d Frequency of Certification

HiVol orifice Vendor certified annual

Streamline

TetraCal Vendor certified annual

BIOS

DeltaCal Vendor certified annual

Gilibrators Vendor certified annual

Where do field operations personnel obtain gaseous standards? Scott Marrin Gases; Airgas

Are those standards certified by:

The agency laboratory? x

EPA/NERL standards laboratory? x

A laboratory separate from this agency‟s but part of the

same reporting organizat ion? x

The vendor? x

Other (describe).

How are the gas standards verified after receipt?

How are flow measurement devices certified? Vendor certified.

Please provide copies of certifications of all standards currently in

u se from your master and/or satellite standard certification

logbooks (i.e., chemical standards, ozone standards, flow

standards, and zero air standards).

What equipment is used to perform calibrations (e.g., dilution

devices) and how is the perf ormance of this equipment verified? Dilution calibrator. Flow checked with certified

Gilabrator.

Does the documentation include expiration date of certification? Y

Reference to primary standard used? Y Vendor provided

What traceability i s used? NIST

Please attach an example of recent documentation of

traceability

Is calibration equipment maintained at each station? x Gas calibrators are maintained at

### 81 site

.

How is the functional integrity of this equipment documented? Site log book and gas dilution calibrator calibration

form.

Who has responsibility for maintaining field calibration standards? AQET Supervisor

.

Please list the authoritative standards and frequency of each type of dilution, permeation and ozone calibrator and indicate the

certification frequency...

Calibrator Primary Standard Frequency of

Certification

Permeation calibrator flow controller

Permeation calibrator temperature

Dilution calibrator air and gas flow controllers Gilabrator ann ual

Field/working standard photometer Thermo Environmental Instruments 49C annual

Ozone generator Thermo Environmental Instruments 49C annual

o) Please identify station standards for gaseous pollutants at representative air monitoring stat ions (attach additional sheets as

appropriate): see attach ment

Parameter Station(s) Identification of Standard(s) Recertification Date(s)

CO Kinau Hale (DH) and Kapolei

(KA) See attachment

NO 2 KA and West Beach (WB) See attachment

SO 2 DH

, KA, WB, KN, OV, PA, MV,

HL, PE See attachment

O 3 Sand Island (SI) See attachment



### iv ) Repair

a) Who is responsible for performing preventive maintenance? Site operator (AQET)

b) Is special training provided them for performing preventive maintenance? No. Briefly comment on background or

courses.

c) Is this training routinely reinforced? Yes No X

If no, why not?

d) What is your preventive maintenance schedule for each type of field instrumentation? See SOP.

### 82 e ) If preventive maintenance is MINOR , it is performed at (check one or more): field station X , headquarters facili

ties , equipment is sent to manufacturer

f) If preventive maintenance is MAJOR, it is performed at (check one or more ): field station X , headquarters facili

ties , equipment is sent to manufacturer

g) Does the agency have service contracts or agreements in place with instrument manufacturers? Indicate below or

attach additional pages to show which i nstrumentation is covered? No, excluding DR DAS Inc. (data loggers and

central data base server)

h) Comment briefly on the adequacy and availability of the supply of spare parts, tools and manuals available to the

field operator to perform any necessary m aintenance activities. Do you feel that this is adequate to prevent any

significant data loss?

No, spare parts adequacy limited due to fiscal restrictions. Availability limited for aging equipment. For

example: Encoders for Andersen PM 2.5 RAAS

- 300 Sequ ential FRM Sampler in short supply. Tools and

manuals are adequate.

i) Is the agency currently experiencing any recurring problem with equipment or manufacturer(s)? If so, please identify

the equipment or manufacturer, and comment on steps taken to reme dy the problem.

j) Have you lost any data due to repairs in the last 2 years?

More than 24 hours? Yes

More than 48 hours? Yes

More than a week? Yes

k) Explain any situations where instrument down time was due to lack of preventive maintenanc e of unavailability of

parts.

Budget restrictions and more purchasing scrutiny have made it increasing difficult to obtain spare parts.



### RECORD KEEPING

Question Yes No Comment

What type of station logbooks are maintained at each

monitoring station ? (maintenance logs, calibration logs,

personal logs, etc.) Monthly QC checklist; station log book

What information is included in the station logbooks? Date, time, AQET name, Site name, equipment

serviced.

Who reviews and verifies the logbooks for adequacy of station

performance? AQET Supervisor.

How is control of logbook maintained? AQET have sole custody.

Where is the completed logbook archived?

At station.

### 83 What other records are used?

Zero span record? X

Gas us age log? X

Maintenance log? X

Log of precision checks? X

Control charts? X

A record of audits? X

Please describe the use and storage of these documents. Logs are periodically reviewed by AQET Supervisor and QA

staff. Log books and other documents are stored at site.

Are calibration records or at least calibration constants available

to field operators? X

Please attach an example field calibration record sheet to this questionnaire.

See attached, Sample SO2 Gas Analyzer Calibration Form

### 84



# V) Site/Monitor Information Form

PQAO_______________________________________________________

AQS Site Name

________________________________ _______________

AQS Site Number

________________________________ _____________

Agency Site Name/No.

________________________________ _________ (if different than AQS Site Name/Number)



## Site Address

________________________________ __________________

City & County

________________________________ ________________

Site Coordinates

________________________________ _______________ (specify lat/long or UTM)



## Site Elevation (m)

________________________________ _______

Criteria Pollutants Monitored

________________________________ _____

________________________________ ____________________________

Other Parameters

________________________________ ______________

Nearest Meteorological Site

________________________________ ______ („on site‟ is met tower present at this site)

Photographs to and from each cardinal direction attached?

______________ (Yes or No)



## Name(s) of Report Preparer(s)

________________________________ ____

Name(s) of Auditors ____________________________________________

Date

________________________________ ________________________

### 85



## Phone Number

________________________________ _________

### 86



# Site Map

Draw map of site and surrounding terrain and features, up to 100 meters.

Map notes

### 87



# Monitor Information

Pollutants

Manufacturer

Model

Serial number

Scale of representation

Micro, Middle, Neighborhood, Urban

Objective (Population, Max concentration,

Background, Transport)

H eight of probe above ground(m)

Distance from obstruction (m)

Type of obstruction (Wall, Tree, etc)

Distance from roadway (m)

Unrestricted airflow (Yes, No)

Designation (NCore, SLAMS, etc)

Siting Criteria Met (Yes, No)

Manu facturer

Model

Serial number

Scale of representation

Micro, Middle, Neighborhood, Urban

Averaging time 1

- , 8

- , 24

- hour

Objective (Population, Max concentration,

Background, Transport)

Height of probe above ground(m)

Distance fr om obstruction (m)

Type of obstruction (Wall, Tree, etc)

Distance from roadway (m)

Unrestricted airflow (Yes, No)

Designation (NCore, SLAMS, etc)

Siting Criteria Met (Yes, No)



### Insert additional copies of table as needed

### 88



# Area Informa tion

Street Name Traffic Count

(Vehicles/day)



# Direction Predominant Land Use (Industry, Residential, Commercial

or Agriculture)

North

East

South

West



# Direction Obstructions Height (m) Distance (m)

North

East

South

West

Note: This table is for large obstructions that affect the entire site, such as large clusters

of trees or entire buildings. Individual obstructions, such as walls, single trees, other

monitors, etc, should be entered in the Monitor Information table

.



# Direction Topographic Features

(hills, valleys, rivers, etc.) General Terrain

(flat, rolling, rough)

North

East

South

West

### 89



# Comments

3) LABORATORY OPERATIONS

State/Local/Tribal Agency Audited:

City, State, and Zip Code:

Date of T echnical System Audit:

Auditor / Agency:

Key Individuals

Laboratory Manager:

Laboratory Supervisor:

Quality Assurance Manager:

Laboratory Staff involved in the TSA:

### 90

### 91



## a) Routine Operations

What analytical methods are employed i n support of your air monitoring network?

Analysis Name or Description of

Method

PM 10 N/A N/A

PM 2.5 Mass SOP: PM 2.5 FRM Method

Pb Flameless AA SOP: ASAS Method

Others (list by pollutant)

Air Toxics VOCs GM/MS EPA Method TO

- 14A

Air Toxics Carbonyls HPLC/UV EPA Method TO

- 11A



### Please describe areas where there have been difficulties meeting the regulatory

requirements for any of the above analytical methods.

In the table below, please identify the current versions of written methods, supplements, and

guidelines that are used in your agency.

Analysis Documentation of Method

PM 10 N/A

PM 2.5 QA Handbook Vol II, Appendix D Revision No 1 12/08 page 11

- 13 and 40 CFR Part 58,

Appendix L

Pb

- TSP ASAS SOP: STANDARD OPERATING PROCEDURE (SOP) FOR THE DETERMINATION OF METALS

IN AMBIENT PARTICULATE MATTER BY GRAPHITE FURNACE ATOMIC

ABSORPTION SPECTROSCOPY (GFAAS) Version 3

Pb

- PM 10 N/A

Others (list by

pollutant)

Q uestion Yes No Comment

Were procedures for the methods listed above included in

the agency‟s QA Project Plan or SOPs? Were these

reviewed by EPA? Also, are SOP‟s easily/readily

accessible for use and reference? X EPA’s 2008 TSA

Does you lab hav e sufficient instrumentation to conduct

analyses? X



### d) Please describe needs for laboratory instrumentation.

### 92

### 93



## b) Laboratory Quality Control

Please identify laboratory standards used in support of the air monitoring program, including standa rds

which may be kept in an analytical laboratory and standards which may be kept in a field support area or

quality assurance laboratory that is dedicated to the air monitoring program (attach additional sheets if

appropriate):

Parameter Location of

S tandards Laboratory

Standard Recertification

Date Primary Standard*

CO

NO 2

SO 2

O 3

Weights SLD Room3207;

SLD Room#3104 Weight Set

#MS402

PM 2.5 weight set

Red Dot TSP

- 10/20/2011

(PM 2.5)

- 11/12/2011 DOA NIS T Weight Set D

& Primary

Temperature SLD Room #3104; RMY 41372VC 12/17/2011 RMY NIST thermometer

Moisture SLD Room #3104; RMY 41372VC 12/17/2011 RMY NIST thermometer

Barometric Pressure SLD Room #3116 Delta Cal 000678 11/19/2011 Princo M odel 453 Cer #

P

- 7485

Flow SLD Room #3116 Delta Cal 000678 11/19/2011 Critical Venturi Flow

Meter (NIST)

Other Flow Standard

Lead SLD Room #3221 Inorganic Ventures

1000 ppm Stock

Solution 200 ppm Stock Solution

of Mixed Metals wi th

Pb. WW

- IPC

- 1 from

Inorganic Ventures

Other

*Standards to which the laboratory standards can be traced.

Question Yes No Comment

Are all chemicals and solutions clearly marked with an

indication of shelf life? X

Are chemicals removed and properly disposed of when shelf

life expires? X

Are only ACS grade chemicals used by the laboratory? X Technical grades used for cooling or

washing

.

### 94 e) Comment on the traceability of chemicals used in the preparation of calibratio n standards

Question Yes No Comment

Does the laboratory purchase standard solutions such

as those for use with lead or other metals analysis? X

Are all calibration procedures documented?

X

If answer “yes” to (f), please describe the following:

(1) Title of the document: Calibration data GFAAS of Metals

(2) Revision number: 3

(3) Where the document is: GFAAS instrument room

Are at le ast one duplicate, one blank, and one

standard or spike included with a given analytical

batch? X

Briefly describe the laboratory‟s use of data derived from blank analyses.

Pb blank analyses data are used to correct ambient air data if equal or ab ove the analyte’s MDL.

Are criteria established to determine whether a

blank data are acceptable? X

How frequently and at what concentration ranges does the lab perform duplicate analysis? What constitutes an ac

ceptable agreement? Please comment i n the space below.

PM 2.5

– every ten samples for all ranges must be within 15 ug difference;

Pb

– Duplicate analysis is done once for every month samples. Concentration range from 5

- 50ug/L. The relative

percent deviation should be within 10%.

Plea se describe how the lab use data obtained from spiked samples, including the acceptance criteria (e.g.,

acceptable percent recovery).

TSP

– Pb: Recovery from spiked samples indicates extraction efficiency of analytical method. Errors resulting in

sample loss (spiking of analytes, leak etc.) could result in lower recovery while sample contamination may exceed

recovery limit. Possible source of error in analytical steps are investigated if criteria are not met. However for low

spike levels (5ppb Pb) recov ery reported without further action.

### 95

Question Yes No Comment

Does the laboratory routinely include samples of

reference material within an analytical batch? x

If yes, indicate frequency, level, and material used.

PM25: Every 10 we ightings lab standards are referenced.

Pb: Done every batch of extraction at 5ppb and 20ppb levels.

Are mid

- range standards included in analytical

batches? x Not PM2.5

Please describe the frequency, level and compound used in the space provided b elow.

Pb: Every 10 samples a 20ppb mid

- level standard is run.

Are criteria for real time quality control

established that are based on the results obtained

for the mid

- range standards dis cussed above? x

If yes, briefly discuss them below or in dicate the document in which they can be found.

Perkin Elmer software auto calibrates on mid

- level standard.

Are appropriate acceptance criteria for each type

of analysis documented? x It is attached in the reports of Pb.



## c) Laboratory Preventi ve Maintenance

Question Yes No Comment

For laboratory equipment, who has the responsibility for performing preventive maintenance?

Chemist.

Is most maintenance performed in the lab? X

Is a maintenance log maintained for each major la boratory

instrument? X

Are service contracts in place for major analytical instruments?

X Except for analytical balances



## d) Laboratory Record Keeping

### 96

Question Yes No Comment

Are all samples that are received by the laboratory

logged in? X

Discuss sample routing and special needs for analysis (or attach a copy of the latest SOP which covers this). Attach a flow chart

if possible. See SOPs and flow charts

.

Are log books kept for all analytical laboratory

instruments? X

Are there log books or other records that indicate

the checks made on materials and instruments such

as weights, humidity indicators, balances, and

thermometers? X

Identify type of record, acceptable/non

- acceptable Logbook, electronic spreadshe et,

Are log books maintained to track the preparation

of filters for the field? X

Are they current? X

Do they indicate proper use of conditioning? X

Weighings? X

Stamping and numbering? X

By manufacturer

Are log books k ept which track filters returning

from the field for analysis? X

PM25 Electronic and Pb paper

How are data records from the laboratory archived?

Where? SLD Rooms 3105,104 and hard copies in sample room

Who has the responsibility? Chemis t

Title: Chemist

How long are records kept? Years 10

Does a chain

- of

- custody procedure exist for

laboratory samples? x

If yes, indicate date, title and revision number where it can be found

PM25: Standard Operating Procedures for PM25 FRM

Pb: STANDARD OPERATING PROCEDURE (SOP) FOR THE DETERMINATION OF METALS IN AMBIENT PARTICULATE

MATTER BY GRAPHITE FURNACE ATOMIC

ABSORPTION SPECTROSCOPY (GFAAS) Version 3

### 97



## e) Laboratory Data Acquisition and Handling

Question Yes No Comme nt

Identify those laboratory instruments which make use of computer interfaces directly to record data. Which ones use strip cha rts?

Integrators?

PM25: Mettler UMX and RMY translator RH and T through HyperTerminal to Windows XP and GLIMS Software

PM25 FR M and speciation COC Andersen DataLink cartridges through RS 232 to DataLink program

RH and T of freezers and balance room to circular strip charts.

TSP

- Pb analysis: Perkin

- Elmer 4100 ZL Graphite Furnace AAS connected via computer interface; Weigh balances

are connected via computer interface; TSP filters: Mettler AJ

- 100.

Are QC data readily available to the analyst during

a given analytical run? x

What is the laboratory‟s capability with regard to data recovery? In case of problems, can they rec apture data or are they

dependent on computer operations? Discuss briefly.

Logged in main instruments but in different format.

Has a user‟s manual been prepared for the

automated data acquisition instrumentation? X

Please provide below a data fl ow diagram which establishes, by a short summary flow chart: transcriptions, vali dations, and

reporting format changes the data goes through before being released by the laboratory.

### 98



## f) Specific Pollutants: PM 10 

## , PM 2.5 

## and Lead

Question Yes No Comment

PM 10 and PM 2.5

Does the agency use filters supplied by EPA? X

Do filters meet the specifications in 40 CFR 50? X

Are filters visually inspected via strong light from a

view box for pinholes and other imperfections? X

Where does the laboratory keep records of the serial numbers of filters?

Are unexposed filters equilibrated in controlled

conditioning environment which meets or exceeds

the require ments of 40 CFR 50? X

Are the temperature and relat ive humidity of the

conditioning environment monitored? X

Are the temperature and humidity monitors

calibrated? X

Are balances checked with Class S or Class M

weights each day when they are used? X

Is the balance check information pla ced in QC log

book? X Electronically in MS Excel and GLIMS (PM 2.5)

To what sensitivity are filter weights recorded?

Are filter serial numbers and tare weights recorded

in a bound notebook? X PM2.5: Electronically stored; TSP: 3

- ring binder

Are filters packaged for protection while

transporting to and from the monitoring stations? X

How often are filter samples collected? (Indicate the average elapsed time in hours between end of sampling and labora tory

receipt.) 48 h ours.

In what medium are field measurements recorded (e.g., in a log book, on a filter folder, or on standard forms)?

PM25 Datalink cartridge , on instruments and Sample Run Data Sheet

TSP Pb Field Data Sheet

Are exposed filters reconditioned for at least 24 hrs

in the same conditioning environment as for

unexposed filters? X

Briefly describe how exposed filters are prepared for conditioning.

Exposed PM 2.5 filters placed in petri dish in a temperature and humidity controlled room (SLD Room # 3104 ).

Exposed TSP filters are placed in a filter holder and placed in a temperature and humidity controlled chamber (SLD

Room # 3217 ).

Briefly describe how exposed filters are stored after being weighed.

### 99

PM25 Stored in Freezer

TSP Pb stored at room temperature in plastic.

Are blank filters reweighed? x

Are chemical analyses performed on filters? X TSP

- Pb

LEAD

Are lead filters PM

- 10 (PTFE filters) or TSP (glass

fiber filters)? X TSP

- Glass fiber

What analysis method is be ing used? Does it

precisely follow an FRM / FEM? For Pb

- TSP,

what is the extraction procedure being used? X No, DH SOP, Rev 3(2009 Jan 1) Based on EPA

Compendium Method IO

- 3.2 and CARB SOP MLD

005, Rev 5.2

Sonication with dilute nitric acid.

Are all batches of filters tested for background lead

content? X

At a rate of 20 to 30 random filters per batch of 500

or greater? x Indicate rate. 1 per 6

How is/are the instrument(s) calibrated? X Vendor Pb certified standards

How often is /are the instrument(s) calibrated? X Every analysis.

If applicable: Is Class A borosilicate glassware

used throughout the analysis? X No glassware is used in the analysis except for

acid dispensing.

If applicable: Is all glassware cleaned wit h

detergent, soaked and rinsed three times with

distilled or deionized water? X

Labwares used are polyethylene disposable

plasticware except magnetic filter funnels, acid

washed, cleaned with chromium free detergent

and rinsed with MilliQ and processed water.

If applicable: If extracted samples are stored, are

linear polyethylene bottles used? X

If applicable: What reagents are used? Reagent grade nitric acid,

### 100



## 4) DATA AND DATA MANAGEMENT

State/Local/Tribal Agency Audited:

City, State, and Zip Code:

Date of Technical System Audit:

Auditor / Agency:

Key Individuals

Data Manager:

Data Supervisor:

Quality Assurance Manager:

### 101



## a) Data Handling

Question Yes No Comment

Is there a procedure, description, or a chart which shows a

complete data sequence from point of acquisition to point of

submission of data to EPA? X

Please provide below a data flow diagram indicating both the data flow within the reporting organization.

Air Toxics (VOC, Metals, Carbonyl)

- S ee attached, Air Toxics Program Flow Chart

Data validation flow chart in SOP

PM2.5 flow chart in SOP

Electronic data system SOP

Are procedures for data handling (e.g., data reduction, review,

etc.) documented? X DV SOP

In what media (e.g., diskette , data cartridge, or telemetry) and formats do data arrive at the data processing location? Please list

below.

Category of Data (by Pollutant) Data Media and Formats

TSP

- Pb and mass, Air Toxics Chain of custody form (paper);plain text format

PM 2.5 mass and field environmental conditions Data cartridge and Chain of custody form (paper);

plain text format

Criteria Pollutants (gases: CO, SO2, O3, NO2, PM25, PM10,

PM25frmfinal) Telemetry, email and diskettes. Vendor proprietary

format

Ho w often are data received at the processing location from the field sites and laboratory?

Continuously polled every 3

- 10 minutes ; every 3 days for manual samples

Is there documentation accompanying the data regarding any

media changes, transcriptions, or flags which have been placed

into the data before data are released to agency internal data

processing? 

### X

Describe the type of documentation: S tatus flags on continuous monitors are assigned at site level using predefined

criteria and trac ked with software.

How data are actually entered to the computer system (e.g., computerized transcription (copy from disk or data transfer devic e),

manual entry, digitization of strip charts, or other)?

Telemetry, copied from data cartridges to computer , manual entries, and digitization of some strip charts.

For manual data, is a double

- key entry system used? X Mostly cut and paste



## b) Software Documentation

Question Yes No Comment

Does your agency use any AQS Manual? X

### 102

Does your agency use any Air Now Manual? X

If yes, list the title of manual used including the , version number and date published

X

What are the origins of the software used to prepare air monitoring data for release into the AQS and AirNow database? P lease

list the documentation for the software currently in use for data processing, including the names of the software packages,

vendor or author, revision numbers, and the revision dates of the software

.

DR DAS, Ltd. Envista ARM and Envidas Ultimate.

What is the recovery capability in the event of a significant computer problem (i.e., how much time and data would be lost)?

48 hours upon discovery of problem, excluding weekends, holidays, and furlough days.

Has your agency tested the data processin g software to ensure its

performance of the intended function is consistent with the QA

Handbook, Volume II, and Section 14.0?

Does your agency document software tests? X X Central DAS (Envista ARM)

– Yes

Field

– No

If yes, provide the documentati on



## c) Data Validation and Correction

Question Yes No Comment

Have your agency established and document the validation

criteria? X If yes, indicate document where such

criteria can be found (title, revision date).

DV SOP

Does documentatio n exist on the identification and applicability

of flags (i.e., identification of suspect values) within the data as

recorded with the data in the computer files? X

Does your agency document the data validation criteria

including limits for values s uch as flow rates, calibration

results, or range tests for ambient measurements? X

(i) If yes, please describe what action the data validator will take if he/she finds data with limits exceeded

(e.g., flags, modifies, or delete, etc.). Data flagg ed; AQET Supervisor notified. Change submission

submitted to ITS.

(ii) The DVP will use the most recent EPA Null and Qualifier codes available to label data on an hourly basis



### (iii) If yes, give examples to illustrate actions taken when limits we re exceeded.

Include one submission form. If there is a particulate ambient air quality standard exceedance due to fireworks a

“RH” qualifier code is assigned for the hour as valid. If there is a failed calibration and it is determined to be and

error of the analyzer impacting ambient data the DVP assigns a null code to the hourly average to void data.

### 103

Please describe how changes made to data that were submitted to AQS and AirNow are documented.

Requests for change to the Envista database are submitt ed to ITS. The Envista ARM keeps track of changes to the

data, i.e. there are two databases raw and edited. At any time one can view the raw data.

Who has signature authority for approving corrections?

Name Henry Yee Program function

_ Supervisor

_______________________

What criteria are used to determine a data point be deleted? Discuss briefly.

DVSOP and AQET SOPs are established on CFR and instrument manuals to determine guidelines for acceptability.

EPA QA Handbook Volume II; CFR; Instrument manufacturer’s manual and recommendations.

What criteria are used to determine if data need to be rep rocessed? Discuss.

EPA QA Handbook Volume II; CFR; Instrument manufacturer’s manual and recommendations.

Are corrected data resubmitted to the issuing group for

cross

- checking prior to release 

### ? x



## d) Data Processing

Question Yes No Comment

Does the agency generate data summary reports? x Reports are available on Envista Web

Edition.

Please list at least three reports routinely generated, including the information requested below.

Report Title Distribution Period Covered

AMP12 0 ASAS Supervisor quarterly

Emergency Data Validation Through ASAS supervisor to CAB Weekly and as

requested

Performance Improvement Report ASAS Supervisor

monthly

Question Yes No Comment

How often are data submitted to AQS and AirNow ? Data is submitted to AQS quarterly. Data is sent to AIRNow every

15 minutes and hourly.

Briefly comment on difficulties the agency may have encountered in coding and submitting data following the guidance of the

AQS guidelines? The limitations of the Envista ARM software prevents data qualifiers from being stored and

submitted to AQS.

Does the agency routinely request a hard copy printout on

submitted data from AQS? X Only to verify that the data has been

submitted.

### 104 Are records kept for at least 3 years by the agency in an orderly,

accessible form? X

If yes, does this include raw data X , calculation X , QC data X , and reports X ? If no, please comment:

Has your agency submitted data along with the appropriate

calibratio n equations used to the processing center? X

Are concentrations of pollutants other than PM 2.5 corrected to

EPA standard temperature and pressure conditions (i.e.,

298 ° K, 760 mm Hg) before input to AQS, and concentrations of

PM 2.5 and Pb reported to AQS under actual (volumetric)

conditions? X TSP

- Pb needs to be changed to

actual conditions (from 2009)

Are audits on data reduction procedure performed on a routine

basis? X

If yes, at what frequency? DV SOP revised, two years

.

Are data precision and accuracy checked each time they are

calculated, recorded, or transcribed to ensure that incorrect

values are not submitted to EPA? X



## e) Internal Reporting

What internal reports are prepared and submitted as a res ult of the audits required under 40 CFR 58, Appendix A?

Report Title Frequency

Data Quality Indicator Report Quarterly

What internal reports are prepared and submitted as a result of precision checks also required under 40 CFR 58, Appen dix A?

Report Title Frequency

Data Quality Indicator Report Quarterly

Question Yes No Comment

Do either the audit or precision check reports

indicated include a discussion of corrective actions X

### 105

initiated based on audit or precisio n check results?

Who has the responsibility for the calculation and preparation of data summaries? To whom are such summaries delivered?

Name Title Type of Report Recipient



## f) External Reporting

F or the current calendar year or portion thereof which ended at least 90 calendar days prior to the receipt of this questionna ire,

please provide the following percentages for required data submitted on time.

Percent Submitted on Time* Period Covered:

Monitoring Qtr. SO 2 CO O 3 NO 2 PM 10 PM 2.5 Pb

1 (Jan 1

- March 31) 90 100 100 100 100 90 100

2 (Apr 1

- June 30) 90 100 100 100 100 90 100

3 (July 1

- Sept. 30) 90 5 0 100 50 75 90 100

4 (Oct.1

- Dec. 31)

*"On time" = within 90 calendar days after the end of the quarter in which the data were collected.

For the same period, what fraction of the stations (by pollutant) reported less than 75% of the data (adjusted for seasonal moni

toring and site start

- ups and terminations)?

Percent of Stations <75% Data Recovery Period Covered:

Monitoring Qtr. SO 2 CO O 3 NO 2 PM 10 PM 2.5 P b

1 (Jan 1

- March 31)

2 (Apr 1

- June 30)

3 (July 1

- Sept. 30)

4 (Oct.1

- Dec. 31)

Identify the individual within the agency with the responsibility for reviewing and releasing the data.

### 106

Name Program function

Question Yes No Comment

Does your agency report the Air Quality Index?

X ASAS post s AQI directly

Has your agency submitted its annual data certification (as

required in 40 CFR 58.15)?

If yes, did your agency‟s annual report include the

following:

Annual precision and accuracy information described in

Sec tion 5.2 of Appendix A?

Location, date, pollution source and duration of all

episodes reaching the significant harm levels?

Is Data Certification signed by a senior officer of your

agency?

### APPENDIX D: 2011 TSA Schedule

### 108 Hawaii DOH TS 

### A Schedule, 1/24/11

– 1/28/11

Schedule

Monday 1/24

9:00 Intro briefing CAB Office

9:30

- 12:00 General / QA Management,

Network Design

- Program & CAB CAB Office

Potential NO2 near roadway site

1:00

- 2:00 General / Q A Management Lab

- Lab & Field

2:00

- 3:00 Field operations overview Lab

Tuesday 1/25

8:00

- 12:00 CAB audit program + Matt (Gwen) & CAB . Kapolei.

Field audit

11:00

– 2:00 Other Oahu Site Reviews Gwen

2:00

- 4:00 Data Management/ Gwen a t Lab

Validation/Reporting/

Tracking

1:00

- 2:30 Instrument Repair/ Matt at Lab

Maintenance

2:30

- 4:00 PM lab review Matt

6:20pm Flight to Hilo

Wednesday 1/26

6:44 a.m.

– Jensen arrives in Hilo, Ed to pick me at airport. Pick up Kona State vehicle at

DOH Hilo office.

7:05

– Leave DOH Hilo office

7:15

– pick up Gwen & Matt @ hotel, leave for Volcano

8:00

– 8:50 meet with NPS (Cindy)

9:00

– 10:00 meet with USGS (Jeff & Tamar)

11:00

– arrive @ DOH Ocean View

1:00

– arrive @ DOH Pahala

2:30

– arrive @ DOH Mountain View

3:45

– arrive @ DOH Puna E

### 109 4:30

– arrive @ DOH Puna H

5:30

– arrive @ DOH Hilo

6:30

– arrive @ Airport, leave Kona vehicle in parking lot

7:40

– flight departs for Honolulu

Thursday 1/27

8:00

- 10:00 Follow

- ups Gwen Lab

8:00

- 10:00 Toxics Lab Review Matt Lab

10:00

- 11:00 Quality System Lab/CAB at Lab

11:00

- 12:00 Pb Lab Review Lab

1:30

- 2:00 Audit de

- brief Lab

2:30

- 4:00 Post Meeting CAB Office