1

Maricopa County Air Quality Department

Air Monitoring Division

Technical System Audit

Phoenix, Arizona

September 2008

Pre-Final

EPA Region 9
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Table of Contents

Table of Contents................................................................................................................ 2

Glossary of Acronyms ........................................................................................................ 3

Introduction......................................................................................................................... 4

Executive Summary............................................................................................................ 6

Network Management......................................................................................................... 7

Introduction..................................................................................................................... 7

Network Management Findings...................................................................................... 9

Field Operations................................................................................................................ 11

Introduction................................................................................................................... 11

Field Operation Findings .............................................................................................. 12

Laboratory Operations...................................................................................................... 13

Introduction................................................................................................................... 13

PM10 Laboratory Findings ............................................................................................ 13

PM2.5 and PM10 Laboratory Findings............................................................................ 14

Standard Equipment Laboratory Findings.................................................................... 15

Data Management ............................................................................................................. 19

Introduction................................................................................................................... 19

Data Management Findings.......................................................................................... 20

Quality Assurance............................................................................................................. 22

Introduction................................................................................................................... 22

Quality Assurance Findings.......................................................................................... 23

Appendix A: List of Findings.......................................................................................... 26
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Glossary of Acronyms

ADEQ – Arizona Department of Environmental Quality

AQS – Air Quality System Database

CAA – Clean Air Act

CARB – California Air Resources Board

CFR – Code of Federal Regulations

CO – Carbon Monoxide

EPA – Environmental Protection Agency

FAU – Fixed Asset Update

MCAQD – Maricopa County Air Quality Department

NBS – National Bureau of Standards

NIST – National Institute of Standards and Technology

NO2 – Nitrogen Dioxide

NVLAP – National Voluntary Laboratory Accreditation Program 

PM – Particulate Matter

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

PM10 – Particulate matter 10 microns or less in aerodynamic diameter

210Po – Polonium

ppm – Parts per million

PQAO – Primary Quality Assurance Organization

QA – Quality Assurance

QAO – Quality Assurance Officer

QAPjP – Quality Assurance Project Plan

QC – Quality Control

SLAMS – State and Local Air Monitoring Station

SO2 – Sulfur Dioxide

SOP – Standard Operating Procedure

SPM – Special Purpose Monitor

TSA – Technical System Audit
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Introduction

 The Maricopa County Air Quality Department (MCAQD) is the governmental 

agency delegated under Arizona state law with the authority and responsibility for 

collecting ambient air quality data in Maricopa County, Arizona as directed by the Clean 

Air Act 1977 and Clean Air Act Amendments 1990. MCAQD operates ambient 

monitoring stations in Maricopa County, Arizona and is the Primary Quality Assurance 

Organization (PQAO)1for Maricopa County with the exception of ambient air 

monitoring stations operated by the Arizona Department of Environmental Quality

(ADEQ). 

The ambient air monitoring program in Maricopa County encompasses many air 

quality assessment activities including collecting and analyzing data for the Federal 

criteria pollutants2as well as many other air pollutants of concern, collecting data from 

special studies as directed by MCAQD management and conducting annual performance 

audits of all monitoring equipment within its PQAO.

The U.S. Environmental Protection Agency, Region 9 (EPA) conducted a 

Technical System Audit (TSA) of the ambient monitoring program operated by MCAQD

in September, 2008. EPA staff interviewed all management and staff involved in the 

collection, analysis and processing of ambient air quality data. The TSA covered the 

areas of Air Monitoring Network Management, Field Operations, Laboratory Operations, 

Data and Data Management, and Quality Assurance (QA). 

MCAQD personnel were very accommodating to the EPA audit team in making 

their time available for many interviews, procedural reviews and monitoring site visits. 

The staff interviewed included:

Ben Davis - Unit Manager, Air Monitoring Division

Larry Seals - QA Supervisor3, Air Monitoring Division

Gary Ensminger - Special Projects Supervisor, Air Monitoring Division

Del Hawkins - Operations Supervisor, Air Monitoring Division

Ron Pope - Data Analyst, Air Monitoring Division

EPA Staff also interviewed many of the operators and technicians that perform 

the day-to-day activities that enable MCAQD to meet its obligations under the Clean Air 

Act (CAA). MCAQD has one of the highest data capture rates in the country, routinely 

collecting greater than 95% of scheduled samples for all criteria pollutants. 

 

1

A Primary Quality Assurance Organization means a monitoring organization or other organization that is 

responsible for a set of stations that monitor the same pollutant and for which data quality assessments can 

be pooled. Each criteria pollutant sampler/monitor at a monitoring station in the SLAMS and SPM 

networks must be associated with one, and only one, primary quality assurance organization.

2 Criteria pollutants are those air pollutants for which the U.S. Environmental Protection Agency has 

established National Ambient Air Quality Standards and include carbon monoxide, lead, nitrogen dioxide, 

ozone, particulate matter, and sulfur dioxide. 

3

In this report we also refer to the QA Supervisor as the QA Officer.
5

We appreciate that MCAQD ensured that the EPA Audit team had access to all 

key personnel involved in the collection and quality assurance of ambient air quality data.

The EPA regional staff members conducting the TSA were Robert Pallarino of 

the Air Division’s Air Quality Analysis Office and Roseanne Sakamoto of the Region 9 

Quality Assurance Office. 

The TSA began with a general meeting with MCAQD managers and staff on 

September 22, 2008 at the MCAQD office in Phoenix, AZ. At this meeting the EPA 

Audit Team discussed the purpose of the TSA, the program areas the TSA would review 

and answered questions from MCAQD management and staff.

This report is divided into seven sections. The first section is an introduction that 

provides a brief description of the organization of MCAQD's air monitoring program, the 

EPA audit team, and the report organization. The next section is an executive summary 

that describes the purpose of the TSA and a summary of the most significant findings. 

The remaining five sections address specific aspects of the air monitoring program: 

network management, field operations, laboratory operations, data management and 

quality assurance/quality control. Appendix A is a summary listing of the findings 

contained in this report. The findings and recommendations in this report are listed in 

priority order. Recommendations are provided to give some indication of the Region’s 

expectations as to how findings can be addressed. If MCAQD has other approaches or 

alternatives to address the concerns identified, the Region will consider them, provided 

the corrective action adequately addresses the finding.
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Executive Summary

This document is a report on the findings made by the EPA after conducting a 

TSA on the air monitoring program of the MCAQD ambient air monitoring program. A 

TSA is an on-site review and inspection of a PQAO’s ambient air monitoring program to 

assess its compliance with established regulations governing the collection, analysis, 

validation, and reporting of ambient air quality data.

The TSA was conducted by EPA staff in September 2008. The audit team 

interviewed the monitoring staff and management on various aspects of the air 

monitoring program including such areas as network design, field operations, laboratory 

operations, data management, and quality assurance and quality control procedures. The 

audit team also inspected a number of the monitoring sites operated by MCAQD. The 

site inspections consisted of an interview with the site operator, reviewing station and 

instrument logbooks, and evaluating the station siting with respect to EPA requirements 

for probe siting4. 

The 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 quality of ambient air data. These assessments also 

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

affecting the quality of ambient air data. 

The TSA uncovered some deficiencies within the agency which are discussed in 

more detail in this report. There were no findings that we would consider major 

deficiencies in the MCAQD monitoring program. Overall, we found the MCAQD 

program to be exceptionally well run. The program has fully integrated quality assurance 

into its operations and the staff recognize the importance of verifying and validating the 

data they produce. The most serious finding we made during this TSA was the lack of 

Standard Operating Procedures for some of day-to-day monitoring and laboratory 

routines. These are discussed in more detail below.

The staff employed by MCAQD exhibited an extensive knowledge of the 

monitoring program and were exceptionally dedicated to collecting quality data. 

MCAQD evaluates new monitoring technologies and often offers its assistance to the 

national monitoring program by providing monitoring locations and support for special 

studies. In conclusion, we found the MCAQD air monitoring program to be very well 

run. Given the expertise and knowledge of the staff, it may be one of the top monitoring 

organizations in the four-state Region 9 area5.

 

4

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

Monitoring”

5 U.S. EPA Region 9 oversees the environmental programs of Arizona, California, Hawaii, and Nevada.
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Network Management

Introduction

Overall management of the ambient air pollutant monitoring networks is overseen 

by the Unit Manager with assistance as necessary from other MCAQD staff. The 

ambient air monitoring network operated by MCAQD in Maricopa County consists of 24

monitoring sites where data are collected for a variety of air pollutants. Table 1

summarizes the air monitoring sites in Pima County and the pollutants monitored.

Table 1 - Maricopa County Air Quality Department

Criteria Pollutant Ambient Air Quality Monitoring Network - 2007

SITE NAME Ozone/

Designation

PM2.5/

Designation

PM10/

Designation

CO/

Designation

SO2/

Designation

NO2/

Designation

Blue Point SLAMS

Buckeye SLAMS SLAMS SLAMS SLAMS

Cave Creek SLAMS

Central Phoenix SLAMS SLAMS SLAMS SLAMS SLAMS

Coyote Lakes SPM

Durango Complex SLAMS SLAMS

Dysart SLAMS SLAMS SLAMS

Falcon Field SLAMS

Fountain Hills SLAMS

Glendale SLAMS SLAMS SLAMS

Greenwood SLAMS SLAMS SLAMS

Higley SLAMS

Humboldt Mtn. SLAMS

Mesa SLAMS SLAMS SLAMS

North Phoenix SLAMS SLAMS SLAMS

Pinnacle Peak SLAMS

Rio Verde SLAMS

South Phoenix SLAMS SLAMS SLAMS SLAMS

South Scottsdale SLAMS SLAMS SLAMS SLAMS SLAMS

Tempe SLAMS SLAMS

West Chandler SLAMS SLAMS SLAMS

West 43rd Ave. SLAMS

W. Indian School 

Rd.

SLAMS

West Phoenix SLAMS SLAMS SLAMS SLAMS SLAMS

# of SLAMS 17 4 14 13 2 5

# of SPMs 0 0 1 0 0 0

Source: 2007 Air Monitoring Network Review, Maricopa County Air Quality Department

SLAMS - State or local Air Monitoring Station

SPM - Special Purpose Monitors
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In addition to the criteria pollutant monitors listed in the above Table 1, MCAQD 

also operates many meteorological instruments and continuous PM instruments at many 

of the monitoring sites. MCAQD operates a total of 155 instruments to collect criteria 

pollutant and meteorological measurement data. 

Eight of the monitoring sites operated by MCAQD have been collecting data in 

the same location for 20 years or more; three of these have been operating for nearly 30 

years and the oldest site, Central Phoenix, has been in operation for over four decades. 

These long term sites allow MCAQD to examine trends in air quality and are valuable in 

assessing the progress the Department has made in managing and reducing ambient 

concentrations of criteria pollutants.

EPA monitoring regulations require a minimum number of ozone, particulate 

matter [2.5 microns or less in aerodynamic diameter (PM2.5)] and particulate matter [10 

microns or less in aerodynamic diameter (PM10)] pollutant monitors be designated as 

SLAMS. While EPA regulations do not require any minimum number of SLAMS for 

carbon monoxide (CO), nitrogen dioxide (NO2) and sulfur dioxide (SO2), any of these 

instruments designated as SLAMS must retain this designation unless its discontinuation 

is approved by the EPA Regional Administrator. According to the requirements of 40 

CFR 58, Appendix D, MCAQD needs to operate a minimum number of SLAMS sites for 

ozone, PM2.5 and PM10 (Table 2).

Table 2 - Required SLAMS Monitoring Sites for the Phoenix Metropolitan Area

Phoenix MSA

Population 

(2007)

1

Pollutant /

Design Value2

Number of 

SLAMS Sites

Required

Number of 

SLAMS Sites 

Operated

4,179,427

Ozone / 0.083 ppm 3 17

PM2.5 / 12.6 g/m3(annual)/

32 g/m3(daily) 3 4

PM10 / 225 g/m3

6 - 10 14

1 - Annual Estimates of the Population of Metropolitan and Micropolitan Statistical Areas: April 1, 2000 to July 1, 2007 (CBSAEST2007-01), U.S. Census Bureau, Population Division, March 27, 2008

2 - Design Values are based on data collected from the period 2005 - 2007 and submitted to the EPA AQS database. These design 

values are not intended to be used for State Implementation Plan or area designation purposes.

MCAQD's network exceeds the minimum requirements for the required number 

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

monitoring sites are all properly located in terms of monitoring objectives and spatial 

scales except where noted in the findings. 

MCAQD operates a portion of its CO and ozone networks on a seasonal basis. As 

discussed in the MCAQD Annual Network Review, operating a portion of these networks 
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on a seasonal basis allows the County to upgrade instruments, perform preventive 

maintenance, extend the life expectancy of the instruments, reduce replacement costs and 

better utilize its QA and Quality Control (QC) resources on the remaining instruments. 

Even with operating a portion of the ozone and CO networks seasonally, the year round 

MCAQD networks significantly exceed the minimum number of monitoring sites 

required by EPA regulations. Seasonal ozone monitoring sites operate from April 1 

through November 1. Seasonal CO sites operate from September 1 through April 1. The 

following Table 3 lists the ozone and CO sites that operate on a seasonal basis.

TABLE 3 – Seasonal Ozone and Carbon Monoxide Monitoring Sites in the

Maricopa County Air Quality Department Air Monitoring Network

Ozone Seasonal Monitoring Sites

April 1 – November 1

Carbon Monoxide Seasonal Monitoring Sites

September 1 – April 1

Rio Verde South Phoenix

Humboldt Mountain Tempe

Cave Creek Mesa

Tempe West Chandler

West Chandler South Scottsdale

Falcon Field North Phoenix

Glendale Glendale

Dysart Dysart

Buckeye Buckeye

Source: 2007 Air Monitoring Network Review, Maricopa County Air Quality Department

The MCAQD provides an organizational chart which outlines the agency’s 

structure in its Quality Assurance Program Plan. All aspects of the data collection 

functions are performed by the Department, including procurement of equipment, field 

and laboratory operations, quality assurance checks, and data review and submittal to 

EPA. Anticipated changes to be made to the networks in the upcoming year include 

establishing new monitoring locations and the evaluation and testing of new PM 

continuous instruments.

The MCAQD creates an annual network plan that is made available to the public 

for review and meets EPA regulatory requirements as described in 40 CFR 58.10. The 

staff are well trained and routinely attend EPA air monitoring and air quality conferences. 

The facility that houses the air monitoring unit is well equipped and staff indicated that 

all needed supplies are kept on hand to ensure the operation of the various monitoring 

networks with limited down time, as evidenced by the MCAQD high data capture rate.

Network Management Findings

Finding NM1: The Ambient Air Monitoring Networks operated by the MCAQD 

are well managed and meet or exceed most requirements in EPA regulations. 
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Discussion: MCAQD is commended for not only its well managed monitoring networks 

but also for the fact that the Department is continually looking for ways to improve the 

program. The Department maintains a robust monitoring network while concurrently 

investigating new monitoring locations and evaluating and testing new monitoring 

technologies. Thus, MCAQD is able to provide a high level of service to the citizens of 

Maricopa County and the Phoenix metropolitan area. EPA’s Office of Research and 

Development routinely seeks MCAQD assistance when it needs to test new equipment 

and does so not only because of the representative environmental characteristics of the 

Phoenix area (hot, arid desert climate), but also because of the talented and cooperative 

monitoring staff employed by MCAQD.

Finding NM2: MCAQD should investigate the siting of the Blue Point ozone 

monitor.

Discussion: MCAQD’s 2007 Air Monitoring Network Review characterizes the Blue 

Point ozone monitor as a monitor sited to record the highest concentration of ozone 

expected to occur in the area. Based on historic data, this was true at one time and based 

on the meteorology of the Phoenix area air shed, the highest concentration of ozone is 

normally found in the areas east of the urban area, where the Blue Point station is located. 

The highest ozone site, based on data from 2005 through 2007, is the Rio Verde 

monitoring site, also located to east of the urban area but farther north than Blue Point. 

In reviewing 2005 – 2007 data, the Blue Point monitor ranked as the 16th lowest 

reading site for ozone, out of 17 monitoring locations. Given its past history of high 

ozone levels, this sudden drop to one of the cleanest sites deserves to be investigated. At 

a minimum, the site should not be characterized as recording the highest concentration of 

ozone when it is in fact one of the lowest reading ozone monitors in the MCAQD 

network.

Recommendation: As part of the 2008 Annual Plan Review, MCAQD should re-evaluate 

its classification of the Blue Point monitoring station to ensure that its site type 

classification is appropriate. 
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Field Operations

Introduction

All routine field operations are performed by the MCAQD Air Monitoring 

Division. The staff responsible for field operations includes an Operations Supervisor, 

Del Hawkins, and five instrument technicians. As part of this TSA, EPA reviewed field 

operations at three of the monitoring stations operated by MCAQD: West Phoenix, 

Fountain Hills, and West 43rd Ave. All of these stations met the probe siting criteria 

contained in 40 CFR 58, Appendix E for all of the pollutants monitored. 

The monitoring stations were clean, neat and well organized. Appropriate and 

complete SOPs and instrument operating manuals were kept at the stations, except where 

noted in the findings. Sites where data are collected for multiple gaseous pollutants

utilize manifolds. All sample lines from the manifolds to the instruments are Teflon. At 

sites where single pollutants are being monitored, e.g. Fountain Hills, Teflon sampling 

lines run directly from the inlet probe to the instrument. Stations are visited at least once 

a week. All criteria pollutant instruments used by MCAQD are EPA designated methods 

and are operated in accordance to EPA and manufacturer requirements.

Data collected at the sites are stored in a data logger (ESC 8832) and the data 

logger is polled either every hour or half hour by the MCAQD main computer. Station 

operators review station data each morning to determine whether there are any unusual or 

unexpected data that would necessitate a special site visit. Routine weekly operations 

include visual checks of the equipment and sample lines (appropriate sample flow, 

cooling fans operational, solenoid valves operating correctly), checks of the particulate 

filters (change if necessary), and a check of the data logger to ensure data is being 

recorded correctly.

Weekly zero and span checks are performed for all gas analyzers. Span checks 

for ozone, NO2, and SO2 analyzers are performed at 0.4 part per million (ppm) and for 

CO analyzers at 40 ppm. Precision checks are performed by the QA group overseen by 

the Project Manger, Gary Ensminger. Checks for flow and leaks are performed biweekly on PM instruments.

Field operators maintain logbooks at all stations which detail activities conducted 

at the site. Entries are dated and signed in ink. The field supervisor reviews the logbooks 

on a monthly basis. All information on measurement quality checks is recorded on 

specific forms, including zero/span records, gas usage logs, precision checks and audits. 

Instrument calibration information is readily available to field technicians.

Training of new staff is primarily carried out by the Operations Supervisor and/or 

experienced technicians. New staff is also encouraged to take additional training courses 

offered by EPA and may attend specialized conferences when appropriate.
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Minor repair and maintenance of equipment is generally conducted at the 

monitoring station. Major repairs are conducted at the Division facility. Staff indicates

that they have adequate supplies of spare parts and consumables.

Field Operation Findings

The Technical Supervisor for the field team maintains a list of instruments that require 

calibration each month. This list is checked periodically throughout the month to ensure 

that calibrations take place as scheduled. This is noted as a commendable practice. 

Finding FO1: Copies of all field generated documentation is not retained at the 

main office at Watkins and 7th Avenue. 

Discussion: Raw data is retained on site. Results from the raw data are transcribed onto 

Field Check Forms which are returned to the office for review. As final results are 

derived from the raw data, copies should be scanned for transmission to the office. The 

raw data may help data reviewers performing validation understand how results were 

derived. 

Recommendation: Routinely scan and submit raw data entries to the main office. 

Original copies may be retained on site until the end of the year, at which time they 

should be transferred to the office. 

Finding FO2: One point quality control checks specified at 40 CFR Part 58 

Appendix A, Section 3.2.1 and 3.2.1.1 need to be implemented.

Discussion: MCAQD performs one point quality control checks, also known as precision 

checks, at the appropriate frequency required by EPA regulations. However, the gas 

concentrations MCAQD uses to perform this check is based on older EPA regulations,

which directed agencies to use concentrations between 0.08 and 0.10 ppm for ozone, NO2

and SO2 and between 8 and 10 ppm for CO. When EPA revised its monitoring 

regulations in October 2006, the requirements for precision checks, now called

measurement quality checks, changed. The new regulations direct agencies to use gas 

concentrations between 0.01 and 0.10 ppm for ozone, NO2, and SO2 and between 1 and 

10 ppm for CO. The actual concentration used by the agency should be related to the 

routine concentrations normally measured at the sites.

Recommendation: Implement 40 CFR Part 58 Appendix A, Section 3.2.1 and 3.2.1.1 to 

ensure checks are performed at routine concentrations normally measured at sites. 
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Laboratory Operations

Introduction

The Division Laboratory is divided into two Sections: the Filter Conditioning and 

Weighing Lab and the Standards Lab. With exception of the PM10 filter conditioning 

environment, the laboratory facilities are adequate for the Division’s needs. The 

laboratory provides analytical support for the criteria pollutants, PM10, and PM2.5. The 

laboratory audit focused on PM2.5 and Standards Laboratory. 

QA/QC performance in the Filter and Standard Laboratory were being performed 

by staff that are very knowledgeable in their areas of responsibility. Space has been 

dedicated for filter pre/post conditioning, and weighing. Separate areas were dedicated to 

housing primary, transfer standards, and equipment repair. Overall, EPA was impressed 

with the organization and the attention to detail both laboratories exhibited. Of particular

note is the protocol for receiving a new instrument: the Standards Laboratory performs 

frequent calibrations to ensure it is within the required specifications,. 

Laboratory Findings

PM10 Laboratory Findings

Finding PMLAB1: Procedures for preconditioning PM10 filters were not as well 

defined as for PM2.5. It was not clear how temperature and humidity were 

monitored to meet +/- 2

oC standard deviation for temperature, +/- 5% standard 

deviation for relative humidity.

Discussion: The PM10 filter pre/post conditioning environment is located in the same 

room as the PM2.5 conditioning chamber. Whereas the PM2.5 filter pre/post conditioning 

occurs in a temperature and humidity controlled chamber, this is not the case for the PM10

conditioning environment. The thermometer and humidity meter attached to the interior 

column in the filter conditioning and weighing room were used to determine whether the 

conditioning environment for PM10 filter weighing and condition were satisfactory. The 

meter is not at eye level.. 

The Control Company Dew-Point, Wet-Bulb, Humid, Therm, Model 4410, SN 61794834 

was last calibrated in July 2006 with calibration due in July 2008. Method 2.12, Table 

3.2 recommends temperature and humidity verifications be conducted every quarter. 

There were no records of verification having taken place. 

Recommendation: Develop a method for PM10 to determine whether temperature and 

humidity criteria were met to ensure the filter weighing and conditioning environment 

meets the requirements at 40 CFR Part 50, App L., Section 8.2. Conduct temperature 

audits quarterly as recommended in Method 2.12, Table 3.2. 
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Finding PMLAB2: Entries in the Laboratory logbook for the PM10 balance were 

limited to QC checks. There was no separate logbook to document when routine 

maintenance or recertification of the balance/scale took place. 

Discussion: Maintenance and recertification of the PM10 balance should be recorded to 

monitor the frequency of maintenance or adjustments to the instrument. 

Recommendation: Document balance maintenance and other records in a separate 

logbook. 

Finding PMLAB3: Alkalinity determinations were not performed on PM10 filters. 

Discussion: 40 CFR Part 50, Appendix J, Section 7.2.4 requires alkalinity checks to be 

performed on PM10 filters. The alkalinity of glass fiber or quartz high-volume filter is 

measured because alkaline sites react with SO, NO, and other acid gases in the air 

forming sulfates, which are indistinguishable from the particulate mass collected by the 

filter. Without this information, total particulate weight could be biased high. 

Recommendation: Perform alkalinity tests on PM10 hi-volume glass fiber or quartz 

filters. A copy of the procedure is available in Quality Assurance Guidance Document 

2.12, Monitoring PM2.5 in Ambient Air Using Designated Reference or Class I Equivalent 

Methods, November 1998, Appendix A, Measuring Alkalinity of Filters.

Finding PMLAB4: With exception of two entries in the PM2.5 logbook (10/25/06 and 

12/07/07), there were no records to demonstrate that antistatic polonium (210Po)

strips are being routinely changed out at six month intervals as recommended in 

Quality Assurance Guidance Document 2.12, Monitoring PM2.5 in Ambient Air 

Using Designated Reference or Class I Equivalent Methods, November 1998, Section 

7.8. 

Discussion: It is important to document that non-expired 210Po strips are used when 

conditioning and weighing samples, as electrostatic charge buildup will prevent a 

microbalance from operating properly. Buildup of electrical charges may also impact 

sample results by drawing or repelling minute PM particles. 

Recommendation: Request 21 0Po strips expiration dates from manufacturer to ensure 

their effectiveness and validity of sample results. 

Common PM2.5 and PM10 Laboratory Findings

Finding PMLAB5: Recertification of weigh standards has lapsed for both PM2.5 and 

PM10 weights. 

Discussion: The reviewer obtained certification for Troemner weights used in PM2.5 

quality assurance checks: 7034-4T (5 mg); 7029-1T (100 mg); 7028-1T (200 mg)
15

Certificates for these weights expired in January 08, 2008. Quality Assurance Guidance 

Document 2.12, Monitoring PM2.5 in Ambient Air Using Designated Reference or Class I 

Equivalent Methods, November 1998, Sections 4.3.7 and 7.3 recommends “reference 

standards should be recertified on a regular basis (e.g., yearly) at a State weight and 

measures laboratory or at another laboratory that is accredited by the National Voluntary 

Laboratory Accreditation Program (NVLAP), which is administered by National Institute 

of Standards and Technology (NIST).” 

Recommendation: Recertify reference standards annually. 

Finding PMLAB6: PM10 and PM2.5 quarterly weight checks of the working 

standard against the primary standard are not conducted. 

Discussion: A primary standard is maintained in the filter weighing lab for both PM10

and PM2.5. Routine comparison of working standard weight against the primary standard 

provides information that help to determine whether there is a balance/scale problem or 

whether working standard has degraded. Please see Quality Assurance Guidance 

Document 2.12, Monitoring PM2.5 in Ambient Air Using Designated Reference or Class I 

Equivalent Methods, November 1998, Section 7.9, Presampling Filter Weighing (Tare 

Weight), Step 5.

Recommendation: Perform quarterly checks of the working standard against the primary 

standard. 

Finding PMLAB7: Some changes or erroneous entries in the filter lab and field 

logbooks were not struck out using a single line, signed or dated. 

Discussion: Logbook entries were satisfactory in that it was possible to follow what 

occurred on a particular date, however, entries made in logbooks should be closed out 

with a signature and dated by the individual making the entries. A single line should be 

used to strike out erroneous information,. The change should be signed and dated

Recommendation: Sign and date any entries made in field and lab logbooks. Use a 

single strike through entry, date and signature when making changes to these logbooks. 

Standard Equipment Laboratory Findings

Finding SLAB1: The annual recertification of the Laboratory’s primary standard 

to a NIST standard reference photometer is not documented. 

Discussion: California Air Resources Board’s (CARB) ozone primary standard 

verification report does not identify Maricopa’s primary standard by instrument or serial 

number. The ozone verification report reviewed uses a number generated by CARB, and 

not Maricopa’s instrument serial number. Definitive documentation is therefore lacking 

to confirm that Maricopa’s primary standard is being calibrated annually with a NIST 

standard reference photometer. 
16

Recommendation: Request confirmation by CARB that the number in their verification 

records, 107559, has always been associated with Maricopa’s primary standard, 0211-

0075; SN 74 and maintain this on file. It is recommended that all primary and transfer 

standard and field instrument recertification results be reviewed periodically to identify 

when instrument performance is deteriorating, which may potentially be used to increase 

the frequency at which recertification takes place or justify its replacement. 

Finding SLAB2: The check performed by the Laboratory to verify instruments are 

within specifications after recertification is completed is not maintained. 

Discussion: A visual check is performed to verify that returned instruments were 

properly calibrated, but there is no record to document that these visual checks are being 

conducted, 

Recommendation: Document the visual checks that are performed to verify instrument 

was received and properly calibrated. 

Finding SLAB3: There were a number of lapses noted for recertification of the 

Laboratory’s in-house standards (i.e., standards used to calibrate transfer and field 

instruments), for example, 

A) the primary or “slave” standard recertification has lapsed recently; 

B) the recertification Bench Ozone Transfer Standard, serial number 319, multi 

point calibration has expired; 

C) The Bios International Calibration Certificate for DC-HC-1, Serial Number 

541, indicate that recalibration dates are slipping by one month each year.

Discussion:

A) The “slave” standard is recalibrated in-house using the ozone primary standard. 

Several records were produced to demonstrate primary “slave” standard recalibration. 

Recalibration in 2008 had lapsed by a few months. It is important that the slave standard 

certification is up to date, as this standard is used to calibrate transfer standards, which in 

turn are used to audit and calibrate field instruments. Data produced by instruments out 

of certification criteria will need to be flagged. This may impact Maricopa’s Air Quality 

System (AQS) completeness reporting requirements. 

B) The auditor obtained calibration records for the ozone bench transfer standards for 

0303-002 and standard with serial number (SN) 319. The transfer standard for 0303-002 

is calibrated on a near monthly basis to the second primary or “slave” standard (the 

“slave” standard has been calibrated in-house with the primary standard). This is 

excellent practice. The bench transfer standard is then used to calibrate audit 

instruments. 

The transfer standard with SN 319 did not go through similar recertification. The 

previous recertification took place on 04/10/07, with recertification due on 04/10/08, but 
17

it was not recalibrated until 08/15/08. It is particularly important that the working or 

bench transfer standard recertification occur on a timely, annual or more frequent 

schedule, as this is the standard used to calibrate field instruments. 

The auditor was also unable to locate the record for the recalibration of SN 319 on the 

Fixed Assets Update (FAU) as of 14 October 2008. The FAU identifies all monitoring 

equipment for Maricopa County, the location at which the monitoring equipment is 

maintained, when the instrument was verified and the due date for calibration. If SN 319 

is not being used, it should be noted on the FAU. 

C) Flow calibration recertification records show a monthly lapse in calibration dates 

e.g.,: 03/31/06; 04/23/07; and 05/12/08. Calibrations should have been completed by 

03/31/07 and 03/31/08 to meet annual schedule identified in 40 CFR Part 50, App L, 

Section 9.1 and 9.2. A similar finding was made for Definer 220-H, Serial Number 

114031, where the calibration date on the certificate was 03/17/08, while the projected 

calibration date on “Test Equipment Calibration Due Dates” is noted as 04/18/09. It is 

important that the instruments used to standardize or calibrate other instruments meet 

their calibration schedule. 

Recommendation: Develop a tickler system in the equipment database or FAU to 

provide an early warning (perhaps by two months) for recertifications. Verify this list 

against actual hard copy records to ensure the database is generating accurate dates for 

recertifications. Perform recertification on annual, per regulatory requirement, or more 

frequent schedule. 

Finding SLAB4: There are discrepancies between the Fixed Assets Update as of 14 

October 2008 and site records.

Discussion: The auditor requested the FAU information to compare against site records 

for Central Phoenix (CP), South Phoenix (SP), South Scottsdale (SS), Glendale (GL), and 

West Phoenix (WP). In addition to comparing them against the FAU, they were 

reviewed for consistency with discussions conducted during the audit, i.e., instruments 

are calibrated every six months (and after any changing out of instruments, per Technical 

Supervisor and Project manager), rather than on the regulated annual schedule. In the 

majority of cases, recalibration takes place every six to nine months. Calibration every 

six months is commendable and will minimize any data loss. The switching out of the 

instruments and their recalibration when they go back on-line is also commendable. 

Some discrepancies were noted on the FAU: Recalibration date was expired for the 

Multi-gas calibrator, Air Mon Number 0601-0007: the date verified was 12/12/06 and 

due date for recalibration is 03/11/08. The record should be clarified to indicate whether 

and when this occurred. 

There were also a few discrepancies, likely typos, where recalibration takes place either 

before the last verification took place (Ozone Analyzer, Air Mon Number 9804-0009; 

Ozone primary standard, Air Mon Number 0111-0013; SO2 Analyzer, Air Mon Number 
18

9712-0020; Temp Probe for E-Bam, Air Mon Number 0608-0003) or a little after (a few 

days after anniversary calibration date). In a few instances, the date due for calibration 

was vacant. It is not clear whether these instruments are in use (e.g., Delta T System with 

Air Mon Number 0403-0024 and 0403-0019; Microbalance, PM2.5, Air Mon Number 

0601-0010; Temperature Sensor Room, Air Mon Number 0605-0001, 0605-0004, 0605-

0002, 0605-0003). 

Inconsistencies noted between the site records and FAU are identified below. . 

For site CP, a five point calibration check for ozone took place on 08/16/08, whereas the 

FAU identifies the check taking place on 07/23/08. Additionally, the FAU information is 

not consistent with Air Monitoring Equipment Failure/Repair History Document for CP. 

The most recent site record for performing a check on the TEOM continuous PM2.5 

sampler control unit was on 04/15/08, whereas the FAU shows this as being completed 

on 07/28/08. 

Site records for SS were not consistent with FAU, e.g., sulfur dioxide records show that 

the last 5 point check took place in 02/19/08, whereas the FAU shows it took place on 

07/21/08. The multi-gas calibrator records show that the last check having taken place on 

05/23/08 whereas the FAU shows it taking place on 07/21/08. The ozone records show 

the last 5 point check took place on 06/12/08, whereas the FAU shows it taking place on

07/21/08. 

Site records for SP were not consistent with FAU. The 5 point calibration check for 

ozone took place on July 10, 2008, whereas the FAU shows 07/23/08. The TEOM 

control unit records show the last repair was performed on 04/10/08, whereas the FAU 

shows 07/23/08. 

Site records for WP were not consistent with FAU. Site records show 5 point calibration 

for carbon monoxide taking place 06/16/08, whereas the FAU shows 10/02/08. Site 

records show the last 5 point check for NO/NO2/NOx taking place on 01/24/08, whereas 

the FAU shows 09/19/08. The site record for TEOM flow check show the last audit took 

place on 09/19/08, whereas the FAU shows 07/27/08. Site records for the multi-gas 

calibrator similar show a different date from that on the FAU, 06/06/08 and 07/27/08, 

2008, respectively. 

It is suspected that site information is the more accurate as there is documentation to 

support the activity occurred, whereas the FAU is entirely dependent on what is entered,

which may be a missed or inaccurate entry. 

Recommendation: Include all monitoring equipment in the FAU database, and ensure all 

dates are current, accurate, and consistent with Site records. Ensure that all recalibration 

takes place as specified on the FAU, if the update is being used to track when 

recalibrations are due. 
19

Data Management

Introduction

Management of the ambient air quality data stream is handled by the MCAQD 

Data Coordinator. The Data Coordinator’s primary duty is to validate all air monitoring 

data collected by MCAQD and ensure that is properly submitted to the EPA. The Data 

Coordinator tasks include organizing the ambient data in the proper format and preparing 

it for submission to EPA’s AQS database, preparing, organizing and submitting precision 

and accuracy data to EPA’s AQS database, preparing the MCAQD Annual Monitoring 

Network Plan and analyzing the performance of the existing monitoring network, as well 

as assisting in the evaluation of new monitoring locations.

The flow of data begins at the ambient air monitoring stations. Data collected by 

air pollution instruments are recorded in the station data logger. Monitoring station data 

loggers are polled hourly by the MCAQD main computer and maintained in an ESC 

database. Data is backed up hourly and daily at the MCAQD office, as well as at a 

remote location maintained by Maricopa County. Data recovery abilities are very good

Each morning, station operators review all continuous data collected at their 

stations from the previous day. At this point flags and null codes can be added to the 

data. The Operations Unit Supervisor reviews all data and operator annotations either 

daily or every other day. The data is then forwarded to the Data Coordinator.

The Data Coordinator reviews all raw data and precision and accuracy data sheets 

and performs a monthly review. As part of this review the Data Coordinator looks for 

blank or negative values. Using a spreadsheet developed in-house, the Data Coordinator 

calculates various statistics such as means, standard deviations and modes. Any edits are 

recorded in the ESC database.

After the Data Coordinator reviews the data and makes necessary edits, a final 

statistical review is performed. Control charts are developed and reviewed, final edits are 

made and the data package is forwarded the MCAQD Quality Assurance Officer (QAO) 

for review.

The Data Coordinator prepares a monthly report which details and explains all 

null codes placed on data sets. This report is sent to EPA monthly.

MCAQD has access to all appropriate AQS database manuals. The software used 

to manage their data is a commercially available product developed by ESC. The version 

used by MCAQD is 5.42a, released in January 2003. MCAQD has developed some of 

their own internal spreadsheets that they use to review data.
20

MCAQD has developed validation criteria for all pollutant data consistent with 

EPA regulations and guidance. All information on edits made to the data are recorded 

and adequately documented.

MCAQD has developed a draft SOP for data processing.

Data Management Findings

Finding DM1: Verification of manual data entry into electronic systems is not being 

performed. 

Discussion: Two methods are typically used for keystroke data entry QC: duplicate 

keying and proofing. Duplicate keying is defined as data entry by two different 

operators, followed by resolution of all discrepancies by referring back to the original 

forms. Proofing refers to manual (visual) comparison of data entered by a single operator 

against the original forms. The person who proofs the data should not be the person who 

entered it originally. Duplicate keying is far more likely to eliminate simple keystroke 

mistakes than proofing. 

If a data set has not been entered by the duplicate keying technique, a certain percentage 

of residual errors is to be expected. Keystroke data entry error rates can be estimated by 

comparing the original report pages or logbooks to the data reported out of the data 

system. The end use of the data should be considered in determining whether the error 

rate is unacceptably high.

Recommendation: Perform duplicate keying or proofing using original forms to verify 

entries made into electronic systems are consistent and accurate with originals. 

Finding DM2: The Data Coordinator’s results from validation are not 

communicated to Division manager and staff prior to submission to AQS.

Discussion: One of the Data Coordinator’s sources for determining gaseous monitoring 

data quality is the monitoring staff (i.e., he makes direct inquiries with staff to determine 

how to flag qualified data). The final gaseous validation report is submitted to the QAO 

for approval, but the final reports for PM are not shared with monitoring staff. Sharing 

the validated information with monitoring staff will afford staff an opportunity to review 

the results of their work and identify for themselves the types of activities that cause data 

loss, the amount of loss, and corrective actions to minimize data loss. 

Recommendation: Provide monitoring staff results from validation on data loss of 1 hour 

and greater and provide opportunity for review. Consideration should be given to 

including monitoring staff in the validation process prior to submitting data into AQS, if 

significant flagging discrepancies arise based on this review

The Data Coordinator has already incorporated the notification and review process with 
21

monitoring staff, per an email sent to EPA on November 3, 2008. 

Finding DM3: The sources of information used by the Data Coordinator for 

qualifying and flagging data are not identified in the Data Coordinator Procedures 

Manual. 

Discussion: The Data Coordinator’s knowledge and responsibility resides with one 

individual. To ensure his function can be completed by others when he is unavailable, 

elements that he reviews (e.g., monitoring staff, qualifiers used and definition, precision 

and accuracy checks and audits, site logs, validation work sheet) to determine data 

quality should be included in the Data Coordinator’s Procedures Manual. 

Recommendation: Include the sources of information used to validate and qualify results 

in the Data Coordinator’s Procedure’s Manual. 
22

Quality Assurance

Introduction

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

minimal requirements for quality assurance for Primary Quality Assurance Organizations 

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

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

views the application 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, MCAQD has a quality 

management system in place, however, it is not well documented. The Division does not 

have a Quality Management Plan (QMP). The Quality Assurance Project Plans 

(QAPjPs) for monitoring criteria pollutant gaseous and particulate matter (PM) 2.5 and 

10 are in various stages of completion (please see Comment QA3). 

Although the plans were lacking, it was apparent that the Division manager is 

committed to the generation of defensible data by MCAQD and ensures quality assurance 

practices are integrated into every staffs knowledge and responsibilities. This 

commitment is highly commendable. The commitment to continuous improvement was 

demonstrated by the staff in response to a verbal audit finding of reviewing validation 

results to prevent recurrence was almost immediately implemented. 

Strong components of the Division’s monitoring program are:

1) Training. It is highly encouraged, both on the job and formal training. The 

Division manager frequently recommends training and ensures sufficient resources are 

available to ensure training, both refresher and new regulatory requirements and technical 

information, occurs. Training is tracked on a checklist for field technicians. 

2) Conduct of semi-annual performance audits, rather than on annual basis. Site 

instrument calibration also occurs on a semi-annual and/or more frequent basis (site 

instruments are routinely changed out and moved to another site on a semi-annual 

schedule, and when site instruments are submitted for repair, respectively). This is 

consistent with regulatory requirements at 40 CFR Part 50, App D (ozone), Section 5.2.3; 

App F (NO2). 

In lieu of the designated QAO, the Division manager appears to be performing the 

role of the QAO. The QAO assigned QA/QC responsibilities has other conflicting duties 

that prevent him from functioning in the QA management role. The QAO’s primary 

responsibilities are to perform PM2.5 and 10 filter preparation, weighing, distribution, and 

validate of filter and gaseous monitoring instead of performing oversight of the entire 

quality system being implemented (i.e., the QAO is performing technician functions, 
23

rather than QAO functions). There should be a separation of responsibilities, so that the 

manager is not performing QA oversight of the unit he oversees. This should be the 

responsibility of the QAO to avoid any conflict of interest. The QAO has direct reporting 

authority to Steve Fowers, Deputy Director of the MCAQD, should the Division manager 

fail to address any concerns raised by the QAO. 

The Division’s Audit Team also maintains an equipment database. It was 

developed in house by retired staff. Although it is useful for tracking where air 

monitoring equipment is in the field, office, or recertification to external NIST traceable 

vendors, the database sometimes “loses” information, despite efforts to uncover in the 

programming code the cause for loss. The system may “crash” at times, and at other 

times it is not known how the loss occurs. It is commendable that Division staff know 

that loss may periodically occur. The information entered is reviewed, thereby 

minimizing any data loss. Information is re-entered if it cannot be located. There were 

no reports of “duplicate” entries, when information is re-entered. Division staff noted 

that there are plans to upgrade the system with new off the shelf software. This 

observation is not noted as a finding, but recorded for the next scheduled audit. 

Quality Assurance Findings

Finding QA1: The QAO’s responsibilities are not inclusive of those identified in 40 

CFR Part 58, Appendix A, Section 2.2: Responsibilities include strategic planning, 

allocation of resources and other systematic planning activities (e.g., planning, 

implementation, assessing and reporting) pertaining to the quality system. The 

quality assurance management function must have sufficient technical expertise and 

management authority to conduct independent oversight and assure the 

implementation of the organization’s quality system relative to the ambient air 

quality monitoring program and should be organizationally independent of 

environmental data generation activities. 

The QAO primarily performs PM10 and PM2.5 filter preparation, weighing, and 

distribution. He also performs validation of filter weighing results and for gaseous 

monitoring. These functions should be overseen by the QAO, rather than 

performed by him. 

Discussion: 40 CFR Part 58, Appendix A, Section 2.2 requires the monitoring 

organization provide for a quality assurance management function that determines and 

implements the quality policy defined in a monitoring organization’s Quality 

Management Plan (QMP). 

Based on audit discussions, however, the Air Monitoring Division manager appears to be 

performing QA oversight responsibilities as part of the Division manager responsibilities. 

While it is commendable that Maricopa County has a manager with technical skills and 

knowledge so that oversight can be performed, this does not meet the QA

“independence” criterion, as he is responsible for the data generation operations. 
24

Recommendation: Recruit additional personnel to perform the technical function the 

current QAO is performing. This will enable the QAO to provide guidance for the 

monitoring activities the organization conducts and to perform independent oversight 

including in-house audits and reporting results to management. 

Finding QA2: A Quality Management Plan (QMP) has not been developed for Air 

Monitoring Division overall data collection operations. 

Discussion: EPA Order 5360.1 A2, Policy and Program Requirements for the 

Mandatory Agency-wide Quality System (EPA 2000) requires all organizations that 

conduct environmental data operations for EPA through contracts, assistance agreements, 

and interagency agreements to develop and operate management processes and structures 

for assuring that data or information collected are of the needed and expected quality for 

their desired use.

A QMP documents how an organization structures its quality system and describes its 

quality policies and procedures, criteria for and areas of application, and roles, 

responsibilities, and authorities. It also describes an organization’s policies and 

procedures for implementing and assessing the effectiveness of the quality system. EPA 

requirements for QMPs are defined in EPA Requirements for Quality Management Plans 

(QA-R-2), EPA/240/B-01/002 (EPA 2001). 

The QMP may be viewed as the ‘umbrella’ document under which individual projects are 

conducted. The QMP is then supported by project specific QAPjP e.g., PM2.5, PM10, SO2, 

NO2, ozone, CO. A QAPjP provides more specific information by which individual 

projects involving environmental data are implemented and assessed and how specific 

QA and QC activities will be applied during a particular project. 

Recommendation: Develop QMP based on QA R-2 within an agreed upon time frame 

e.g., one year that describes the Divisions’ overall quality system. 

Finding QA3: A QAPjP has not been developed to address PM10 monitoring. The 

QAPjPs for priority pollutants (PM2.5, CO, NO2, ozone, SO2) require completion.

Discussion: 40 CFR Part 58, Appendix A, Section 2.1.2 requires monitoring 

organizations develop a quality system that is described in a QAPjP. The QAPjP is a 

formal document describing, in sufficient detail, the quality system that must be 

implemented to ensure that monitoring results meet a well-defined need, use, or purpose: 

provide data of adequate quality for the intended monitoring objectives; satisfy 

stakeholder expectations; comply with applicable standards specifications; comply with 

stationary (and other) requirements of society; and reflect consideration of costs and 

economics.

Recommendation: Develop a QAPjP for PM10 monitoring and complete other plans. 

Finding QA4: SOPs were incomplete or not always accessible where expected. 
25

Discussion: A good effort has been made by the organization to prepare SOPs. SOPs 

help ensure consistency in performing repetitive tasks and improve data quality. 

Master copies were not in the assigned folders e.g., Quality Control Manual: Section 5, 

Ozone Analyzers; Section 8, Nitrous Dioxide Analyzers; Section 9, Multi-Gas 

Calibrators. Field technicians, however, had their copies. Master copies should always 

be complete, as there may be a need to access them by staff or auditors. 

Additionally, when reviewing the PM2.5 and PM10 Laboratory, SOPs were requested, 

however, they were incomplete and not available, respectively. 

Recommendation: Complete preparation of SOPs and have them signed off by 

responsible party, e.g., party preparing (along with title) and quality assurance officer. 

When completed, the County might consider placing them on an internal website and in 

their Quality Control Manual. 

Finding QA5: The corrective action process is undocumented. 

Discussion: The QAPjP describes program assessment techniques and resulting reports. 

The corrective action process, however, is not described. The Division has a very 

proactive system for checking for error through audits and calibration checks. Corrective 

actions are taken where deficiencies are found, but these actions are not documented.

Recommendation: Develop a corrective action procedure that includes documentation of 

the corrective action taken, by whom, and date addressed. Steps to verify that the 

satisfactory corrective action has taken place should also be included. 

Finding QA6: Training records are not maintained for all staff at the Watkins and 

7

th Avenue main office. 

Discussion: Staff in the Air Monitoring Division appear to be well trained. The 

promotion of both on the job and off-site training is very commendable. Staff in the Air 

Monitoring Division noted that training is encouraged and in some cases is mandatory. 

Based on this reporting, it appears that training information is being tracked by 

management in some form, however, with exception of the Training Checklist 

maintained by the Technical Supervisor, is undocumented. 

Recommendation: Maintain records of training received by all staff at the Watkins and 

7th Avenue office including the type and frequency. 
26

Appendix A: List of Findings

Network Management Findings

Finding NM1: The Ambient Air Monitoring Networks operated by the MCAQD are well 

managed and meet or exceed most requirements in EPA regulations. 

Finding NM2: MCAQD should investigate the siting of the Blue Point ozone monitor.

Field Operation Findings

Finding FO1: Copies of all field generated documentation is not retained at the main 

office at Watkins and 7th Avenue. 

Finding FO2: One point quality control checks specified at 40 CFR Part 58 Appendix A, 

Section 3.2.1 and 3.2.1.1 need to be implemented.

Laboratory Operation Findings

Finding PMLAB1: Procedures for preconditioning PM10 filters were not as well defined 

as for PM2.5. For example, it was not clear how temperature and humidity criteria were 

being checked to meet +/- 2

oC standard deviation for temperature, +/- 5% standard 

deviation for relative humidity.

Finding PMLAB2: Entries in the Laboratory logbook for the PM10 balance were limited 

to only QC checks. There was no separate logbook to document when routine 

maintenance or recertification of the balance/scale took place.

Finding PMLAB3: Alkalinity determinations were not performed on PM10 filters. 

Finding PMLAB4: With exception of two entries in the PM2.5 logbook (10/25/06 and 

12/07/07) there were no records to demonstrate that antistatic 210Po strips are being 

routinely changed out at six month intervals.

Finding PMLAB5: Recertification of weight standards has lapsed for both PM2.5 and 

PM10 weights. 

Finding PMLAB6: PM10 and PM2.5 quarterly weight checks of the working standard 

against the primary standard are not conducted.

Finding PMLAB7: Not all changes or erroneous entries struck out using a single line in 

the filter lab and field logbooks. Some of these changes were not signed or dated. 

Finding SLAB1: The traceability of the Laboratory’s primary standard being annually 

recertified to a NIST standard reference photometer is not documented. 
27

Finding SLAB2: The check performed by the Laboratory to verify instruments are 

within specifications after recertification is completed is not maintained. 

Finding SLAB3: Recertification of the Laboratory’s in house standards (i.e., standards 

used to calibrate transfer and field instruments) were not always performed within the 

required time period.

Finding SLAB4: There are discrepancies between the Fixed Assets Update as of 14 

October 2008 and site records.

Data Management Findings

Finding DM1: Verification of manual data entry into electronic systems is not being 

performed. 

Finding DM2: The Data Coordinator’s results from validation are not communicated to 

Division manager and staff prior to submission to AQS.

Finding DM3: The sources of information used by the Data Coordinator for qualifying 

and flagging data are not identified in the Data Coordinator Procedures Manual. 

Quality Assurance Findings

Finding QA1: The QAO’s responsibilities are not inclusive of those identified in 40 CFR 

Part 58, Appendix A, Section 2.2.

The QAO primarily performs PM10 and PM2.5 filter preparation, weighing, and 

distribution. He also performs validation of filter weighing results and for gaseous 

monitoring. These functions should be overseen by the QAO, rather than performed by 

him. 

Finding QA2: A Quality Management Plan (QMP) has not been developed for Air 

Monitoring Division overall data collection operations. 

Finding QA3: A QAPjP has not been developed to address PM10 monitoring. The 

QAPjPs for priority pollutants (PM2.5, CO, NO2, ozone, SO2) require completion.

Finding QA4: Standard Operating Procedures (SOPs) were incomplete or not always 

accessible where expected. 

Finding QA5: The corrective action process is undocumented. 

Finding QA6: Training records are not maintained for all staff at the Watkins and 7th

Avenue main office.