1



# Maricopa County Air Quality Department Air Monitoring Division Technical System Audit

Phoenix , Arizona September 2008

Pre

- Final

EPA Region 92



## 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

PM 10 Laboratory Findings

................................ ................................ ............................ 13

PM 2.5 and PM 10 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

................................ ................................ .......................... 263



## Glossary of Acronyms

ADEQ

– Arizona Department of Environmental Quality AQS

– Air Quality System Database

CAA

– Clean Air Act

CARB

– California Air Resources Board

C FR

– 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 Te chnology

NO 2
– Nitrogen Dioxide

NVLAP

– National Voluntary Laboratory Accreditation Program

PM

– Particulate Matter

PM 2.5

– Particulate matter 2.5 microns or less in aerodynamic diameter

PM 10
– Particulate matter 10 microns or less in aerodynami c diameter

210 Po

– Polonium

ppm

– P arts per million PQAO

– Primary Quality Assurance Organization QA

– Quality Assurance QA O

– Quality Assurance Officer QAPjP

– Quality Assurance Project Plan QC

– Quality Control

SLAMS

– State and Local Air Monitoring Station

SO 2
– Sulfur Dioxide

SOP

– Standard Operating Procedure

SPM

– Special Purpose Monitor

TSA

– Technical System Audit4



## Introduction

The Maricopa County Air Quality Department ( MCAQD ) is the governmental agency delegated under Arizona s tate 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 Marico pa County, Arizona and is the Primary Quality Assurance Organization (PQAO) 1 for Maricopa County with the exception of ambient air monitoring stations operated by the Arizona Department of Environmental Quality (ADEQ)

.

The ambient air monitoring progr am in Maricopa County encompasses many air quality assessment activities including collecting and analyzing data for the Federal criteria pollutants 2 as 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 monito ring equipment within its PQAO.

The U.S. E nvironmental Protection Agency, Region 9 (EPA) conducted a Technical System Audit (TSA) of the ambient monitoring program operated by MCAQD

in Sep tember , 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 an d 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 Supervisor 3 , 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 Na tional 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 manag ers and staff on September 22 , 200 8 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 di vided 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 describ es the purpose of the TSA and a summary of the most significant finding s. The remaining five sections address specific aspects of the air monitoring program: network management, field operations, laboratory operations, data management and quality assuran ce/quality control. Appendix A is a summary listing of the finding s contained in this report. The finding s and r ecommendation s in this report are listed in priority order. Recommendation s are provided to give some indication of the Region’s expectations as to how finding s 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

.6



## Executive Summary

This document is a report on the finding s made by the EPA after conducting a TSA on the air monitoring program of the MCAQD ambient a ir m onitoring p rogram. A

TSA is an on

- site review and inspection of a PQAO ’s ambient air monitoring program to assess its compliance with e stablished 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 M CAQD . 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 siting 4

.

The TSA is one of the ways that EPA provides o versight 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 a nd 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 d iscussed in more detail below.

T he 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 assistan ce 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 wel l

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

- state Region 9 area 5

.

4 40 CFR, Part 58, Appendix E, “Probe and Moni toring Path Siting Criteria for Ambient Air Quality Monitoring”

5 U.S. EPA Region 9 oversees the environmental programs of Arizona, California, Hawaii, and Nevada.7



## Network Management

Introduction

Overall management of the ambient air pollutant monitoring networks is overseen by the Unit Manager with assistance as necessary from other MCAQ D staff. The

am bient air monitoring network operated by MCAQ D in Maricopa County consists of 24 monitoring sites where data are collected for a variety of air pollutant s

. 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 PM 2.5 /

Designation PM 10

/ Designation CO/

Designation SO 2 /

Designation NO 2 /

Designation
Blue Point SLAMS Buckeye SL AMS 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 S LAMS

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 SL AMS SLAMS SLAMS SLAMS SLAMS Tempe SLAMS SLAMS

West Chandler SLAMS SLAMS SLAMS

West 43 rd Ave. SLAMS

W. Indian School

Rd. SLAMS

West Phoenix SLAMS SLAMS SLAMS SLAMS SLAMS

# of SLAMS 1 7 4 1 4 13 2 5

# of SPMs 0 0 1 0 0 0

Source: 200 7 Air Monitoring Network Review

, Maricopa County Air Quality Department

SLAMS

- State or local Air Monitoring Station

SPM

- Special Purpose Monitors8 In addition to the criteria pollutant monitors listed in the above Table 1, MCAQD also operates many me teorological 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 bee n 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 a ir quality and are valuable in assessing the progress the D epartment 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 ( PM 2.5 ) ] and particulate matter [ 10 microns or less in aerodynamic diameter ( PM 10 ) ] pollutant monitors be designated as SLAMS. While EPA regulations do not require any minimum number of SLAMS for carbon monoxide ( CO )

, n itrogen d ioxid e ( NO 2 ) and sulfur dioxide ( SO 2 ), 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 op erate a minimum number of SLAMS sites for
ozone, PM 2.5 and PM 10 ( Table 2 )

.

Table 2

- Required SLAMS Monitoring Sites for the Phoenix Metropolitan Area

Phoenix MSA Population (200 7 ) 1 Pollutant / Design Value 2 Number of

SLAMS Sites Required Number of

SLA MS Sites Operated

4,179,427 Ozone / 0.0 83 ppm 3 1 7

PM 2.5 / 12

. 6  g/m 3 (annual) /

32  g/m 3 (daily) 3 4

PM 10 / 225  g/m 3 6

- 10 1 4

1

- Annual Estimates of the Population of Metropolitan and Micropolitan Statistical Areas: April 1, 2000 to July 1, 2007 (CBSA

EST2007

- 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 exceed s 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 fin ding s

.

MCAQD operates a portion of its CO and ozone network s on a seasonal basis. As discussed in the MCAQD Annual Network Review, operating a portion of these networks9

on a seasonal basis allows the County to upgrade instruments, perform preventive

m aintenance, extend the life expectancy of the instruments, reduce replacement costs and better utilize its QA and Q uality C ontrol (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

follo wing 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

– Novem ber 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

Buc keye 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

est ablishing 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 58.1 0. 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 s taff 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.



### N etwork M anagement Finding s

Finding NM1 : The Ambient Air Monitoring Networks operated by the MCAQD are well managed and meet or exceed most requirem ents in EPA regulations

.10

Discussion: MCAQD is commended for not only its well managed monitoring networks

but also for the fact that the Department is con tinually looking for ways to improve the program. The D epartment maintains a robust monitoring net work while concurrently investigat ing new monitoring locations and evaluat ing and test ing 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 Offi ce 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 tal ented 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 chara c terizes the Blue

Point ozone monitor as a monitor s ited 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 20 05

– 2007 data, the Blue Point monitor ranked as the 16 th 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 c lassification of the Blue Point monitoring station to ensure that its site type
classification is appropriate

.11



## Field Operations

Introduction

All routine field operations are performed by the MCAQD Air Monitoring Division. The staff responsible for fie ld 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 43 rd 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 k ept at the stations

, except where

noted in the finding s

. 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 moni tored , 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 t o EPA and manufacturer requirements.

Data collected at the site s are stored in a data logger (ESC 88 32 ) 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 determ ine 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 operati ng correctly), checks of the particulate filters (change i f necessary), and a check of the data logger to ensure data is being recorded correctly.

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

for o zone, NO 2 , and SO 2 analy z ers 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 bi

weekly 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

sp ecific 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

expe rienced technicians . New staff is also encouraged to take additional training courses offered by EPA and may attend specialized conferences when appropriate

.12 Minor r epair and maintenance of equipment is generally conducted at the monitoring station. Ma

jor repairs are conducted at the Division facility. Staff indicate s that they have adequate supplies of spare parts and consumables.



### Field Operation Finding s

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

calibr ation 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

mai n office at Watkins and 7 th Avenue.

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

Field Check Forms which are return ed to the office for review. As final results are derived from the raw data, copies shoul d 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

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

Discussion: MCAQD perfor ms 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 u se concentrations between 0.08 and 0.10 ppm for ozone, NO 2 and SO 2 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 ne w regulations direct agencies to use gas concentrations between 0.01 and 0.10 ppm for ozone, NO 2 , and SO 2 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 A ppendix A, Section 3.2.1 and 3.2.1.1 to ensure checks are performed at routine concentrations normally measured at sites.13



## Laboratory Operations

Introduction

The Division Laboratory is divided into t wo Sections: the Filter Conditioning and Weighing Lab and the Standards Lab. With exception of the PM 10 filter conditioning environment, the laboratory facilities are adequate for the Division’s needs. The laboratory provides analytical support for the criteria pollutants, PM 10 , and PM 2.5 . The laboratory audit focused on PM 2.5 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. S pace has been dedicated for filter pre/post conditioning, and weighing. Separate areas w ere dedicated to housing primary, transfer standards, and equipment repair. Overall, EPA was impressed with the organization and the attention to detail both laborato ries exhibited. Of particular note is the protocol for receiving a new instrument : the Standards Laboratory performs frequent calibration s to ensure it is within the required specifications,.



### Laboratory Findings

PM 10 

### L aboratory Findings

Finding PMLAB 1 : Procedures for preconditioning PM 10 filters were not as well

defined as for PM 2.5 . It was not clear how temperature and humidity were monitored to meet +/

- 2 o C standard deviation for temperature, +/

- 5% standard deviation for relative humidity.

Discu ssion : The PM 10 filter pre/post conditioning environment is located in the same

room as the PM 2.5 conditioning chamber. Whereas the PM 2.5 filter pre/post conditioning occurs in a temperature and humidity controlled chamber, this is not the case for the PM 10 conditioning environment. The thermometer and humidity meter attached to the interior column in the filter conditioning and weigh ing room were used to determine whether the conditioning environment for PM 10 filter weighing and condition were satisfac tory. 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 verifica tions be conducted every quarter. There were no records of verification having taken place.

Recommendation : Develop a method for PM 10 to determin e whether temperature and humidity criteria were met to ensur e the filter weighing and conditioning envi ronment

meets the requirements at 40 CFR Part 50, App L., Section 8.2. Conduct temperature audits quarterly as recommended in Method 2.12, Table 3.2.14

Finding PMLAB2 : Entries in the Laboratory logbook for the PM 10 balance were limited to QC checks. Th ere was no separate logbook to document when routine maintenance or recertification of the balance/scale took place.

Discussion : Maintenance and recertification of the PM 10 balance should be recorded to
monitor the frequency of maintenance or adjustm ents to the instrument.

Recommendation : Document balance maintenance and other records in a separate logbook.

Finding PMLAB3 : Alkalinity determinations were not performed on PM 10 filters.

Discussion : 40 CFR Part 50, Appendix J, Section 7.2.4 re quires alkalinity checks to be performed on PM 10 filters

. The a lkalinity 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 t he particulate mass collected by the

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

Recommendation : Perform alkalinity tests on PM 10 hi

- vol ume glass fiber or quartz filters. A copy of the procedure is available in Qu ality Assurance Guidance Document 2.12, Monitoring PM 2.5 in Ambient Air Using Designated Reference or Class I Equivalent Methods, November 1998, Appendix A, Measuring Alkalinity of Filters.

Finding PMLAB 4 : With exception of two entries in the PM 2.5 logbo ok (10/25/06 and 12/07/07)

, there were no records to demonstrate that antistatic polonium ( 210 Po ) strips are being routinely changed out at six month intervals as recommended in Quality Assurance Guidance Document 2.12, Monitoring PM 2.5 in Ambient Air

Usin g Designated Reference or Class I Equivalent Methods, November 1998, Section

7.8.

Discussion : It is important to document that non

- expired 210 Po strips are used when conditioning and weighing samples, as electrostatic charge buildup will prevent a

micr obalance from operating properly. Buildup of electrical charges may also impact sample results by drawing or repelling minute PM particles.

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

their effectiveness and vali dity of sample results.



### Common PM

2.5 

### and PM

10 

### L aboratory Findings

Finding PMLAB 5 : Recertification of weigh standards has lapsed for both PM 2.5 and

PM 10 weights.

Discussion : The reviewer obtained certification for Troemner weights used in PM 2.5 qual ity 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 PM 2.5 in Ambient Air Using Designated Reference or Class I Equivalen t 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

Laborat ory Accreditation Program (NVLAP), which is administered by National Institute of Standards and Technology ( NIST ) .”

Recommendation : Recertify reference standards annually.

Finding PMLAB 6 : PM 10 and PM 2.5 quarterly weight checks of the working

standard against the primary standard are not conducted.

Discussion : A primary standard is maintained in the filter weigh ing lab for both PM 10 and PM 2.5

. R outine compar ison 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 PM 2.5 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 PMLAB 7 : 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 date d by the individual making the entries. A single line should be

used to str ike o ut erroneous information,

. The change should be sign ed and date d

Recommendation : Sign and date any entries made in field and lab logbooks. Use a single strike through ent ry, date and signature when making changes to these logbooks.



### S tandard E quipment L

aboratory Findings

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

to a N IST 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. D efinitive d ocumentation 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 Laborato ry 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 d ocument 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 ca libration 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.

R ecalibration 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 cal ibrate 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 req uirements.

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 “sla ve” 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 simil ar recertification. The

pr evious recertification took place on 04/10/07, with recertification due on 04/10/08 , but17

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 ide ntifies 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 a s 04/18/09. It is import ant 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 recertificati ons . Verify this list against actual hard copy records to ensure the database is generating accurate dates for

re certifications

. Perform recertification on annual, per regulatory requirement, or more frequent schedule.

Finding SLAB4: There are di screpancies 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 Techn ical 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 12/12/0 6 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 (O zone Analyzer, Air Mon Number 9804

- 0009; Ozone primary standard, Air Mon Number 0111

- 0013; SO2 Analyzer, Air Mon Number18

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, PM 2.5 , Air Mon Number

0601

- 0010; Temperature Sensor Room, Air Mon Num ber 0605

- 0001, 0605

- 0004, 0605

- 0002, 0605

- 0003).

Inc onsistenc ies 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 PM 2.5 sampler control unit was o n 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/NO 2 /NO

x taking plac e 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, 0 6/06/08 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 inaccurat e 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 us ed 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 a ir 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 ai r 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 dail y 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 flag s 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 preci sion 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, standar d 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 d ata package is forwarded the MCAQD Q uality A ssurance 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 ap propriate 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 t hey 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.

MCAQ D has developed a draft SOP for data processing.



### Data Management Finding s

Finding DM 1 : 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. Duplicat e 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 form s. 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 cert ain 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 determi ning 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 DM 2 : 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 source s for determining gaseous monitoring data quality is the monitoring staff (i.e., he makes direct inquiri es with staff to determine how to flag qualified data). The final gaseous validation report is submitted to the QAO

for approva l

, but the final report s for PM are not shared with monitoring staff. Sharing the validated information with monitoring staff w ill 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 action s to minimize data loss

.

Recommendation : Provide monitoring staff resu lts from validation on data loss of 1 hour and greater and provide opportunity for review. C onsideration should be given to including monitoring staff in the validation process pr ior 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 with21

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

Finding DM3: The sources of information used by the Data Coordinator for quali fying 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 unavailab le, 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

minim al 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 D ivision does not have a Quality Management Plan (QMP). The Quality Assurance Project Plans (QAPjPs) for monitoring criteria pollutant gaseou s 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 D ivision manager is

committed to the generati on of defensible data by MCAQD and ensures qual ity assurance practices are integrated into every staffs knowledge and responsibilities. This commitment is highly commendabl e

. The commitment to continuous improvement was

demonstrated by the staff in response to a verbal audit finding of reviewing vali dation results to prevent recurrence was almost immediately implemented.

Strong components of the D ivision ’s monitoring program are:

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

D ivision manager frequently rec ommends 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 p erformance 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 (NO 2 ).

In lieu of the designated QAO, the D ivision manager appears to be performing the role of the QAO. Th e 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 PM 2.5 and 10 filter preparation, weighing, distribution, and

validate of fil ter 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 recert ification 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 i s 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 informa tion 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.



### Q uality A ssurance Finding s

Finding QA1 : T he 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, asse ssing 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 PM 10 and PM 2.5 filter preparation, weighing, and distribution. He also per forms 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 perfo rming 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 colle ction 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 agr eements, 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 effective ness 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., PM 2.5 , PM 10 , SO 2 , NO 2 , 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 activitie s 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 P M 10 monitoring. The QAPjPs for priority pollutants (PM 2.5 , CO

, NO 2 , ozone, SO 2 ) 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 QAP j P. The QAP

j P 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; satis fy 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 PM 10 monitoring and complete o ther 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 qual ity.

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 the ir copies. Master copies shou ld always be complete, as there may be a need to access them by staff or auditors. Additionally, when reviewing the PM 2.5 and PM 10 Laboratory, SOPs were requested, however, they were incomplete and not available, respectively.

Recommendation : Compl ete 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 Manua l.

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 correc tive 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.

D iscussion : 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 mandat ory. 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 recor ds of training received by all staff at the Watkins and

7th Avenue office including the type and frequency.26



## Appendix A: List of Finding s

Network Management Finding s

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

mana ged and meet or exceed most requirements in EPA regulations.

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

Field Operation Finding s

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

office at Watkins and 7 th 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 Finding s

Finding PMLAB1: Procedures for preconditioni ng PM 10 filters were not as well defined

as for PM 2.5 . For example, it was not clear how temperature and humidity criteria were being checked to meet +/

- 2 o C standard deviation for temperature, +/

- 5% standard deviation for relative humidity.

Finding PML AB2: Entries in the Laboratory logbook for the PM 10 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 PM 10 filters.

Finding PMLAB 4 : With exception of two entries in the PM 2.5 logbook (10/25/06 and 12/07/07) there were no records to demonstrate that antistatic 210 Po strips are being routinely changed out at six month intervals.

F inding PMLAB 5 : Recertification of weigh t standards has lapsed for both PM 2.5 and

PM 10 weights.

Finding PMLAB 6 : PM 10 and PM 2.5 quarterly weight checks of the working standard against the primary standard are not conducted.

Finding PMLAB 7 : Not all cha nges 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: R ecertification of the Labora tory’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 Finding s

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 Finding s

Finding QA1: The QAO ’s responsibilitie s are not inclusive of those identified in 40 CFR Part 58, Appendix A, Section 2.2

.

The QAO primarily performs PM 10 and PM 2.5 filter preparation, weighing, and distribution. He also performs validation of filter weighing results and for gaseous

monitori ng. 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 bee n developed to address PM 10 monitoring. The QAPjPs for priority pollutants (PM 2.5 , CO

, NO 2 , ozone, SO 2 ) require completion.

Finding QA4: Standard Operating Procedures (SOPs) were incomplete or not always accessible where expected.

Finding QA5: The c orrective action process is undocumented.

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

Avenue main office.