S7 1

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX

1 q c’ 75 Hawthorne Street

San Francisco, CA 941 05-3901



## JAN 182013

Mr. Eric Massey

Air Division

Arizona Department of Environmental Quality

1110 W. Washington Street

Phoenix, Arizona 85007



## ØI

Dear M1VjYIsey:

I am vriting to transmit the findings from U.S. Environmental Protection Agency’s (EPA’s) 2012

Technical System Audit (TSA) of the Arizona Department of Environmental Quality (ADEQ) ambient

air monitoring program. This audit was performed in accordance with 40 CFR Part 58, Section 2.5,

which requires that EPA conduct TSAs of primary quality assurance organizations every three years.

EPA reviewed ADEQ’s ambient air monitoring program, including network management, field

operations, laboratory operations, quality assurance, and data management procedures. Generally, we

found that ADEQ’s air monitoring program is robust and meets EPA requirements. As with any audit,

this TSA uncovered some program areas within the agency that can be improved. Your agency has been

very responsive to the audit findings and has already begun working on corrective actions. The formal

corrective action response is due to EPA within 60 days of receipt of the final TSA report.

I want to thank you and your staff for your full cooperation and participation during the audit. The

results of this audit significantly contribute to EPA’s overall understanding of ambient monitoring in

Arizona.

Please contact me if you have questions, or your staff may contact Michael Flagg at (415) 972-3372 or

Matthew Lakin at (415) 972-3851.

Sincerely,

Jordan

Director, Air Division

Enclosure

cc: Theresa Rigney, ADEQ

Printed on Recycled Paper

# Technical System Audit

Arizona Department of Environmental Quality

Ambient Air Monitoring Program

April 9

- April 13, 2012

Conducted by

Air Quality Analysis Office Quality Assurance Office

Air Division Management and Technical

Services Division

US EPA Region 9

75 Hawthorne Street

San Francisco, California 94105

Final Report: January 201 3

### ii INDEX

GLOSSARY OF ACRONYMS

.................................................... ..................... ............... 1

EXECUTIVE SUMMARY

................................................................................ ............... 2

TSA ACTIVITIES

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

OVERVIEW OF AIR MONITORING PROGRAM

..................................... ............... 7

FINDINGS..........................

....................................................................... ............... 11

APPENDIX A : Summary of Findin gs

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

APPENDIX B : Organizational Chart...............

......................................... ............... 3 6

### 1 GLOSSARY OF ACRONYMS

ADEQ

......................................... . Ari zona Department of Environmental Quality

AQAO.......................................... Air Quality Analysis Office

AQCD.......................................... Air Quality Control Department

AQS............................................. Air Quality S ystem

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

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

DMS............................................. Data Management System

DQO..............................

............... Data Quality Objective

EPA.............................................. Environmental Protection Agency

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

FRM............................................. Federal Ref erence Method

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

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

NBS.............................................. National Bureau of Standa rds

NCORE........................................ National Core mult i pollutant monitoring stations

NO

x 

### /NO

y 

### ...................................... Nitrogen Oxides

O 3



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

PCAQCD

....................... ........ ...... Pinal County Air Quality Control District

PM............................................... Particulate Matter

PM 2.5



### ............................................ Particulate Matter with aerodynamic diameter <= 2.5 μ m

PM 10



### .............................. ............... Particulate Matter with aerodynamic diameter <= 10 μ m

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

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

QAPP..........................

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

QAO............................................. Quality Assurance Office

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

QMP............................................. Quality Managemen t Plan

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

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

SO 2



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

STN.................

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

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

### 2 EXECUTIVE SUMMARY

This document is a report on the findings of the United States Environmental Protection Agency

(EPA) made during a Technical Systems Audit (TSA) o f the Arizona Department of

Environmental Quality (ADEQ), Air Quality Division, ambient air monitoring program. A TSA

is an on

- site review and inspection of a state or local ambient air monitoring program to assess

its compliance with established regulations governing the collection, analysis, validation, and

reporting of ambient air quality data. This TSA meets the requirements for EPA audits of the

ADEQ monitoring organization required by 40 CFR p art 58, a ppendix A

, § 2.5.

The TSA was conducted by EPA Region 9 staff from April 9

- 13, 2012

. The audit team

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

network design, field operations, laboratory operations, data handling , quality assurance and

quality control procedures. The audit team also inspected some of t he monitoring sites operated

by ADEQ . The site inspections consisted of an in terview with the site operator when possible

, review of station and instrument logbooks, and evaluation of the station siting with respect to

EPA requirements . The laboratory inspection included a review of the particulate matter (PM)

program for mass determinations of PM 10 

### and PM 2.5



### .

The TSA is part of the system by which EPA provides overs ight to ensure that data collected by

state

, local , and tribal agencies meet required mi nimum data quality objectives. Other

assessments

, such as network reviews and performance evaluations

, also provide information

about the overall quality of ambient air monitoring data. These assessments enable agencies to

identify and correct those program elements that may be adversely affecting the quality of

ambient air data. The results of the TSA are summarized here and fully described in this report,

along with re commended actions to address the findings. The specific actions to be taken by

ADEQ will be determined through negotiations with EPA and will be documented in a corrective

action plan prepared by ADEQ

.

EPA would like to thank all the staff and managemen t of ADEQ for their assistance and

cooperation during the audit.

### 3

A. Program Strengths:

ADEQ has a robust ambient air monitoring program that is generally well

- run. Specifically :

 Monitoring stations are well maintained and or ganized.

 Entr ies in station logbooks are very detailed and informative.

 The Data Management Team prepares very detailed quarterly reports that summarize and

explain all major data issues and how they were investigated.

 Carbon copies of station logbooks are reviewed a s part of the data validation process,

which has significantly improved the overall process.

 The particulate matter weigh lab is well organized and activities are thoroughly

documented.

B. Program Major Findings:

During the TSA, EPA identified areas wh ere ADEQ ’s monitoring program should be

strengthened. The major findings are :

1. ADEQ does not have Quality Assurance Project Plans (QAPPs) for O 3 

### , SO 2 

### , NO 2 

### , C O,

and NCore monitoring; QAPPs for PM 10 

### and PM 2.5 

### are outdated and should be revised.

2. Field Techni cians are not sufficiently involved in the review of daily monitoring data and

the data validation process , which can lead to unnecessary data loss.

3. A formal corrective action process for significant QA deficiencies has not been

developed or implemented

.

4. ADEQ has not performed internal audits of the air monitoring program activities or

support contractors on a regular basis

.

5. A formal training program for air monitoring staff and contractors who perform routine

monitoring system operations has not been es tablished

.

6. ADEQ does not have a mechanism to pass through Clean Air Act Section 103 grant

funds that are allocated specifically for Pinal County Air Quality Control Department’s

( PC AQCD) ambient air PM 2.5 

### monitoring program.

The individual findings are r eported in the topic sections of this document and are also

summarized in Appendix A.

### 4 TSA ACTIVITIES

EPA Region 9 Air Quality Analysis Office (AQAO) and the Region 9 Quality Assurance Office

(QAO) conducted a Technical System Audit of ADEQ’s ambient air monitoring program during

April 9

- 13, 2012. The TSA reviews one part of ADEQ’s program responsibility, the collection

and analysis of ambient air quality data, which is the responsibility of the Air Quality

Assessment Section. The TSA covered the fol lowing program areas:

 General / Quality Management

- Program organization

- Facilities

- Independent quality assurance and quality control

- Planning documents (including QMP, QAPPs, & SOPs)

- General documentation policies

- Training

- Corrective action

- Quality improv ement

- External performance audits

 Network Management / Field Operations

- Network design

- Changes to the network since the last audit

- Proposed changes to the network

- Field support

 Laboratory Operations for PM

- Routine operations

- Quality control

- Laboratory prev entive maintenance

- Laboratory record keeping

- Laboratory data acquisition and handling

- Specific pollutants: PM 10 

### and PM 2.5



###  Data and Data Management

- Data handling

- Software documentation

- Data validation and correction

- Data processing

- Internal reporting

- Extern al reporting

EPA tracked supporting documentation for data points from calendar years 2010 and 2011.

Michael Flagg of the Region 9 Air Quality Analysis Office and Mathew Plate of the Region 9

Quality Assurance Office conducted the TSA. In addition to the EPA Audit Team, Matthew

Lakin and Eugenia McNaughton, m anagers of the Air Quality Analysis Office and Quality

Assurance Office , respectively, participated in the opening and closing meetings. Participating

managers and supervisors of the Air Quality A ssessment Section included Theresa Rigney, Air

### 5

Quality Assessment Section Manager, Bernard Lum, Air Quality Monitoring Unit Manager, and

Bryan Paris, Air Quality Data Management & Quality Assurance Unit Manager

.

The findings and recommendations in this r eport are grouped by program area and listed in

priority order. Recommended actions to resolve findings are provided for each finding to give

some indication of the EPA’s expectations as to how they may be addressed. If ADEQ has other

approaches or alter natives to address the concerns identified, EPA will consider them, provided

the corrective action adequately addresses the finding.

Network Management

EPA interviewed Bryan Paris and Jon Midgley and reviewed ADEQ’s 2011 Annual Network

plan. ADEQ also submitted a five

- year Annual Network Assessment as required by

40 CFR part 58.10. Generally, t he monitoring network meets or exceeds the requirements for the

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

Field Operations

In addition to Bernard Lum

, EPA interviewed several Air Quality Monitoring Unit staff. All staff

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

responsible.

EPA visited five monitoring sites (Globe Highway , Hayden Old Jail, Miami Golf Course, Miami

Ridgeline, and Rillito )

. All sites met the siting criteria of 40 CFR part 58, a ppendix E. The

evaluation included inspection of the inlet manifolds, examinatio n of station and instrument

log books, and a check of whether appropriate QC checks and Q A audits were being performed.

All monitoring s ites are well organized and maintained. Station logbooks and instrument

logbooks were up to date and contained relevant information on operations and maintenance

activities. Generally, the site operators provide a very high level of oversight and a

comprehensive understanding of their field sites.

Particulate Matter Laboratory

EPA visited the particulate matter (gravimetric) laboratory and interviewed John Olasin. The

parti culate matter laboratory was well maintained and organized

. Generally, the quality of the

PM 10 

### and PM 2.5 

### laboratory measurements reflect ADEQ’s high level of technical expertise,

ensuring the collection of data of appropriate quality

.

Data Management

T his section covers data management for criteria pollutants (O 3 

### , CO, NO 2 

### , SO 2 

### , PM 2.5 

### , and

PM 10 

### )

. Staff interviewed were Bryan Paris, Heather Colson, Teresa Mackey, and Mark Carrel.

### 6

Quality Assurance/Quality Control

EPA interviewed Theresa Rigney, Ceres a Stewart and Bryan Paris and reviewed quality

management documents. In addition, EPA collected information about QA/QC activities during

interviews of other sections of the technical system. ADEQ’s quality management system meets

the basic EPA requirement s. At the time of the TSA, ADEQ was operating under an approved

QMP and an approved QAPP for Pb monitoring, but lacked appropriate QAPPs for PM 10 

### , PM 2.5 

### , and gaseous criteria pollutants (O 3 

### , CO, NO 2 

### , SO 2 

### ,). Overall, the ADEQ system conforms to the

data qua lity objectives and/or the systematic planning developed by EPA for criteria pollutants.

EPA also perform s national performance audits of ADEQ’s gaseous and PM 2.5 

### monitors and

technical evaluations of the monitoring network.

### 7 OVERVIEW OF AIR MONITORIN G PROGRAM

General Program

Authority for air quality monitoring is given to ADEQ in the Arizona Administrative Code, Title

18, Chapter 2, Article 2 . Section R18

- 2

- 215 discusses the requirements for ambient air

monitoring of criteria pollutants. ADEQ has e ntered into delegation agreements with Maricopa,

Pima, and Pinal Counties to administer air quality programs in their respective counties. These

agreements include sharing of air monitoring data with ADEQ. ADEQ does not provide formal

oversight of county a ir monitoring agencies, but does conduct performance audits of Pinal

County as well as other monitoring networks in the State of Arizona (i.e., facility networks). This

TSA focused on A DEQ’s Air Quality Assessment Section, which is responsible for the

impl ementation of the ambient air monitoring program.

The Air Quality Assessment Section is managed by Theresa Rigney , who reports directly to the

Air Quality Division Director of A DE Q

, Eric Massey

. The Assessment Section is further

organized into four units : Air Quality Monitoring Unit, Air Quality Data Management & Quality

Assurance Unit, Air Quality Evaluation Unit, and the Air Quality Special Applications Unit. The

Monitoring and Data Management & Quality Assurance Units are responsible for the collection

and QA/QC of ambient air monitoring data. At the time of the TSA, the Monitoring Unit was

managed by Bernard Lum, who oversaw the operation of monitoring sites, and the particulate

matter laboratory operations. The Data Management & Quality Assurance Unit is managed by

Bryan Paris, who oversees QA/QC activities, the Data Management Team, and network design.

Quality Control and Quality Assurance

Quality management is the system put in place to oversee quality assurance, quality control and

quality improve ment activities. EPA requires that ambient air monitoring agencies have a

quality management system that conforms to 40 CFR part 50 Appendix A and EPA’s quality

policy (EPA Order CIO 2105.0). Additionally, EPA grant regulations specifically require each

grantee to provide for QA activities (40 CFR part 31.45). Specifically, 40 CFR part 50

Appendix A, § 3 requires that each ambient air monitoring Primary Quality Assurance

Organization (PQAO) conform to certain quality management practices. These include:

 A documented quality system in place that meets EPA requirements for QMPs

and QAPPs

.

 A quality management function that is independent of air monitoring operations

.

 Defined Data Quality Objectives (DQOs), or equivalent systematic planning procedures,

for all monitoring programs

.

 Participation in National Performance Evaluation Programs, which consist of

performance audits used to independently determine program adequacy, national

monitoring network performance, and national consistency

.

 Participation in Te chnical Systems Audits by EPA at a frequency of at least once every

three years.

 Use of certified reference materials to standardize monitoring equipment

.

### 8

EPA views the application of these quality management system components as integral to

monitoring pr ograms. Insufficient quality management and control may undermine the ability of

EPA to make NAAQS designation decisions.

The organization of the Assessment Section divides QA/QC responsibility among units and

personnel. For example, the Data Management & Quality Assurance Unit performs audits, the

Monitoring Unit performs routine QC

, and the Data Management Team performs data validation.

General QA functions are found within the Data Management & Quality Assurance Unit.

Network Management

The ADEQ a mbient air monitoring network throughout Arizona consists of 24 ambient air

monitoring sites that utilize a variety of ambient air monitors. The following table summarizes

the air monitoring sites and the pollutants monitored.

Site Name Pollutant

CO SO 2 NO 2 O 3 PM 10 PM 2.5 PM

10

- 2.5 Pb NO

y Met

Ajo x x

Alamo Lake x

Bullhead City x

Douglas Red Cross x x

Flagstaff x x x

Globe Highway x x

Gree n Water Treatment Plant

Hayden Old Jail x x x

Ike’s Backbone

JLG x x x x x x x x x x

Meadview

Miami Golf Course x x

Miami Ridgeline x

Nogales Post Office x x x

Paul Spur Lime Plant x x

Payson Well Site x x

Pleasant Valley Ranger Sta tion

Prescott College AQD x x

Prescott Valley x x

Queen Valley x x x

Rillito x x

Sycamore Canyon

Tonto National Monument x

Yuma Supersite x x x x



### Field Operations

Field operation d uties for monitoring are primarily managed by the Monitoring Unit with support

for instrument audits by the Data Management & Quality Assurance Unit . Monitoring Unit staff

handle all day

- to

- day operations

, including instrument installation, repair and main tenance

, sample collection

, some quality control activities

, and general field site maintenance. Each field

operator is responsible for several sites that are visited a few times every two weeks

.

### 9

Particulate Matter Laboratory (Gravimetric Laboratory)

The gravimetric laboratory operations are overseen by John Olasin, Lead Lab Technician. The

laboratory is located in an environmentally controlled room located within ADEQ’s main

offices. Generally, the Lead Lab Technician performs analyses in

- house and i s supported by

Kanika Simmons, Lab oratory Technician. The particulate matter laboratory is responsible for

handling filters, which includes preparation, weighing, tracking, and storing PM 2.5 

### and PM 10



### filters. The PM laboratory is well organized and run . A DEQ utilizes an automated balance that

collects multiple weights for each filter increasing the accuracy of the data. As is noted in

Finding 12 , the laboratory continues to use multiple data systems and manual transcription to

process laboratory data.

Dat a Management

Data management involves data collection, data validation process, and a data management

system. ADEQ manages continuous data, data produced by the ADEQ PM laboratory, and data

produced by contract laboratories. Data management is generally h andled by the Data

Management Team in the Air Quality Data Management & Quality Assurance Unit.

Continuous Data

Air quality data measured by the continuous analyzers at the field stations are transferred to the

ADEQ server(s) on a regular basis. Data ar e reviewed daily to weekly by Mark Carrel of the

Data Management Team.

Laboratory Data (PM)

PM 10 

### and PM 2.5 

### filters are weighed by an automated system and results are transferred to the

weigh laboratory MTL database. MTL automatically flags data if we igh session parameters are

out of specification. These data are then exported to an Excel file where they are reformatted and

saved in a “weights” spreadsheet, which is translated into a site specific spreadsheet where mass

concentrations are calculated.

Sampler run information is recorded on a “data card” (i.e. chain of custody form) and manually

reviewed and entered into an Excel spreadsheet. Interval data are periodically downloaded from

the samplers and emailed to the laboratory technicians. These data are compared against the

information on the data card in true/false tables within an Excel spreadsheet, which is considered

the level 1 QA check. Finally, data are compiled and sent to the Data Management Team for

review and submittal to AQS.

Contract La boratory Data for Lead, PAMS, and Toxics

Contract laboratory data are initially reviewed by the laboratory performing the analysis and

reported to ADEQ for entry into the data system. The Data Management Team verifies the data

and performs a final revie w

.

### 10

Data Validation

The data validation process is primarily handled by the Data Management Team. Air Quality

Monitoring Unit field operators provide review of field forms and some input to the data

validation process. On a monthly to quarterly basis, f ield data sheets and copies of field logs are

organized and assembled by the data validation staff , Heather Colson and Teresa Mackey of the

Data Management Team, and reviewed in conjunction with the database. After final validation,

data are uploaded from the ADEQ database to the AQS system. The data validation staff also

prepare quarterly reports which document the data validation decisions that are made as well as

providing data summaries for their internal clients.

### 11 FINDINGS

Program Area Findi ng Numbers EPA Contact

General 1,5

- 7 ,1 7

, & 20 M. Flagg & M. Plate

Network Management 1 5 M. Flagg

Field Operations 2, 9

- 1 1 ,1 4 ,1 8 ,1 9

, & 2 1 M. Flagg

Particulate Matter (Gravimetric) Laboratory 1 2 M. Flagg

Data Management 1 3 & 1 6 M. Plate

Quality Assurance /Quality Control 3,4, & 8 M. Plate

### 1 2

Finding # 1

Agency: ADEQ

Date of Audit: April 9

- 13, 2012

Program Area: General

Finding:

ADEQ does not have QAPPs for O 3 , SO 2 , NO 2 , CO, and NCore monitoring; QAPPs for PM 10 and PM 2.5

are outdated.

Discussion:

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

QAPP integrates all technical and quality aspects of a project, including planning, implementation and

assessment. Th e purpose of the QAPP is to document planning activities for collecting environmental

data operations and to provide a project

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

environmental data needed for a specific decision or use. The QAPP doc uments the quality assurance and

quality control that are applied to an environmental data operation to assure the results obtained are of the

type and quality needed and expected.

Based on significant findings from the past two EPA TSAs, ADEQ was requir ed to update and/or develop

approvable QAPPs. ADEQ has only developed QAPPs for the PAMS, Toxics, and high volume Pb

programs.

References:

40 CFR p art 58, a pp endix A

, § 2.1

EPA Requirements for Quality Assurance Project Plans, EPA/240/B

- 01/003, March 20 01

Guidance for Quality Assurance Project Plans, EPA/240/R

- 02/009, December 2002

EPA Region 9 Guidance for Quality Assurance Program Plans, R9QA/03.2, March 2012

Recommendation to Address Finding:

QAPPs for O 3 , SO 2 , NO 2 , CO, and NCore monitoring must b e developed

, and QAPPs for PM 10 and PM 2.5 must be updated, with the goal of having approvable plans for all criteria pollutants in place and

submitted to EPA as soon as possible.

### 13

Finding # 2

Agency: ADEQ

Date of Audit: April 9

- 13, 2012

P rogram Area: Field Operations

Finding:

Operational procedures are not sufficient to minimize loss of air quality data due to malfunction or

out

- of

- control conditions. The ADEQ Field Technicians are not sufficiently involved in the review of

daily monit oring data and the data validation process to ensure data completeness requirements are met.

Discussion:

As was discussed in the previous two TSAs, data review is an ongoing process that should be performed

by the site operators. Reviewing QC results, hourly data, and applying flags is best done by the person

working most closely with the measuring instrument.

Currently, ADEQ field technicians do not participate in the review of the daily monitoring data. Field

technicians have a better understanding of the monitoring stations, instrumentation

, and the current issues

that might be adversely affecting data and thus should be participating in an initial review of monitoring

data on a daily basis. At present, only one staff member, Mark Carrel of the Data Management & Quality

Assurance Unit, is responsible for reviewing daily data, identifying problems, placing initial flags, and

communicating any data issues to monitoring unit staff

.

Because the field technicians have to rely on information from the Data Management & Quality

Assurance Unit to identify problems, there have been a few instances where large amounts of data have

been lost (i.e., O 3 data at Prescott College and Queen Valley, and PM 10 data at Nogales Post Office).

References:

40 CFR p art 58

, a ppendix A

, § 2

40 CFR p art 50

, a ppendices H, I, K, N, P, R, S, & T

Recommendation to Address Finding:

Field operators should be actively reviewing ambient monitoring data on a more frequent basis and

performing Level I QA on data for the monitoring s tations to which they are assigned on a day

- to

- day

basis or as needed.

### 14

Finding # 3

Agency: ADEQ

Date of Audit: April 9

- 13, 2012

Program Area: Quality Assurance/ Quality Control

Finding:

ADEQ has not developed a formal corrective action process for significant QA deficiencies.

Discussion:

EPA identified several deficiencies that had been identified by ADEQ late in the data validation process

but not fully investigated or corrected. Also, PM 10 and PM 2.5 filter data loss due to operator error has been

an issue at remote monitoring locations that are operated by contractors. ADEQ staff indicated that they

are in the process of developing a corrective action SOP, but the procedures have not yet been

implemented.

Formal corrective action should include:



###  A process that encourages staff to identify problems

.



###  A system to inform management, staff and the QA Manager so that problems can be corrected

before significant data are impacted

.

 Resolution of operational problems within a definite time frame, whether they are identified

during the course of routine operations or during an audit

.

 An evaluation of any data that were directly affected as well as any data being collected using

similar instruments and processes

.

 An investigation as to the roo t cause(s) of the problem so that changes can be made to prevent re

occurrence of similar problems

.

 Independent approval by the QA Manager that the process was appropriate and complete.

References:

EPA Requirements for Quality Assurance Project Plans, EPA/240/B

- 01/003, March 2001

, § 3.4.1

QA Handbook for Air Pollution Measurement Systems, Volume II, EPA

- 454/b

- 08

- 002

, § 1.2.4, 10, & 15

Recommendation to Address Finding:

Develop and implement a formal corrective action process.

### 15

Finding # 4

Agency: ADEQ

Date of Audit: April 9

- 13, 2012

Program Area: Quality Assurance/ Quality Control

Finding:

ADEQ has not performed internal audits of the air monitoring program activities or support contractors

on a regular basis

.

Discussion:

EPA reco mmends that ADEQ perform internal audits that are required under the ir agency

- wide QMP.

Independent evaluations of all aspects of air monitoring activities that are performed by ADEQ staff or

contractors are an important piece of the agenc y’s overall QA sy stem. The agency should maintain an

independent QA management function that conduct s “ independent oversight ” and assure s the

implementation of the organization's air monitoring program is functioning appropriately.

Data or internal program audits are a f orm of the independent oversight that is required as part of a QA

system. EPA guidance for QMPs states that the adequacy of the quality system must be assessed at least

annually.

References:

40 CFR p art 58, a ppendix A, § 2 .2

EPA Requirements for Qualit y Management Plans, EPA QA/R

- 2, March 2001

, § 3.10

ADEQ Quality Management Plan, August 2010, § 9.2

QA Handbook for Air Pollution Measurement Systems, Volume II, EPA

- 454/b

- 08

- 002, § 1.2.4 & 1.3.3

Recommendation to Address Finding:

Develop an audit schedul e for annual internal audits of the air monitoring program and its support

contractors.

### 16

Finding # 5

Agency: ADEQ

Date of Audit: April 9

- 13, 2012

Program Area: General

Finding:

ADEQ does not have a formal training program for air mon itoring staff and contractors who perform

routine monitoring system operations.

Discussion:

Personnel assigned to ambient air monitoring activities are expected to have the education, work

experience and training required for their positions. In some c ases, certain positions may require

certification and/or recertification. Adequate education and training of staff are critical components of any

monitoring program. Appropriate training should be available to employees supporting the Air

Assessment Sectio n commensurate with their duties. Such training may consist of classroom lectures,

workshops, web

- based courses, teleconferences, vendor provided, and on

- the

- job training. It is

recommended that monitoring organizations maintain some requirements for air p ersonnel qualifications

(combination of education and experience). Training increases the effectiveness of employees and their

organization.

In addition to staff, ADEQ continues to use support contractors for some routine operations. In order to

ensure t hat staff and contractors performing routine monitoring and quality control operations have a

common approach, a formal training program should be implemented.

References:

QA Handbook for Air Pollution Measurement Systems, Volume II, EPA

- 454/b

- 08

- 002

, § 4

Recommendation to Address Finding:

Develop a training program and system to document training of monitoring staff and contractors.

### 17

Finding # 6

Agency: ADEQ

Date of Audit: April 9

- 13, 2012

Program Area: General

Finding:

ADEQ does not have a mechanism to pass through Clean Air Act Section 103 grant funds that are

allocated specifically for Pinal County Air Quality Control District’s (PC AQCD ) ambient air PM 2.5 monitoring program.

Discussion:

For some years, ADEQ has been rec eiving Clean Air Act Section 103 grant funds that have been

allocated to P C AQCD. Specifically, ADEQ has received funds for field operation and maintenance,

weigh lab operation and maintenance, and other site costs for three PM 2.5 monitoring sites (Casa Gra nde,

Cowtown, and Apache Junction) operated and maintained by P C AQCD. As explained in the 2012 “Please

Apply” letter, EPA is “providing $471,010 for the operation and maintenance (O&M) of ADEQ's and

Pinal County's Federal Reference Method (FRM) network inc luding the mass analysis of FRM filters”.

According to the March 21, 2012, letter

, the portion for Pinal County’s FRM network was $43,964.

While EPA acknowledges that ADEQ is exploring options for correcting this issue, funds allocated for

P C AQCD should b e distributed appropriately and expeditiously as possible.

References:

Letter from Stephanie Valentine, Manager, Grants and Program Integration Office, U.S. EPA Region IX,

to Eric Massey, Air Quality Division Director, ADEQ dated March 21, 2012



### .

Re commendation to Address Finding:

Distribute the appropriate Clean Air Act Section 103 grant funds to Pinal County AQCD as expeditiously

as possible.

### 18

Finding # 7

Agency: ADEQ

Date of Audit: April 9

- 13, 2012

Program Area: General

Find ing:

The PQAO relationship between ADEQ and PCAQCD is ambiguous

.

Discussion:

A PQAO is defined as a monitoring organization or a coordinated aggregation of such organizations that

is responsible for a set of stations that monitors the same pollutant and for which data quality assessments

can logically be pulled. The CFR further explains that each PQAO shall be defined such that

measurement uncertainty among all stations in the organization can be expected to be reasonably

homogeneous, as a result of c ommon factors. EPA Region 9 has also developed a PQAO strategy

document that outlines additional requirements for PQAO development, such as a formalized mechanism

to receive EPA funding in order to support required audits

.

During the audit, it became clea r that PCAQCD independently meets most of the five common factors for

a PQAO. For example, PCAQCD has independent QAPPs for ozone, PM 2.5 , and PM 10 ; monitoring sites

are solely operated by PCAQCD staff ; the district maintain s a separate data validation and certification

process and operate s an independent gravimetric lab for PM 10 and PM 2.5 filters.

While PCAQCD meets most of the common PQAO requirement s , the agency does rely on the ADEQ’s

Data Management & Quality Assurance Unit for O 3 annual performance ev aluations and PM 10 and PM 2.5

semi

- annual flow audits. Also, PCAQCD does not have a mechanism to receive EPA funding. In the past,

ADEQ has agreed to accept funding on behalf of PCAQCD, but this process has never been appropriately

formalized.

Given th is mixed set of responsibilities , it is important to clarify the roles and responsibilities of the two

agencies, specifically with respect to the PQAO status of the agencies. EPA acknowledges that the two

agencies are working toward develop ing a memorandum of agreement that will formalize the roles and

responsibilities and allow PCAQCD to indirectly gain access to EPA grant funds

.

References:

40 CFR part 58, appendix A, §3.1

U.S. EPA Region 9 Procedure for Implementation of the Primary Quality Assurance Or ganization

Structure for Ambient Air Monitoring Organizations, U.S EPA Region 9

, July 2012

.

Recommendation to Address Finding:

Formalize the roles, responsibilities, and the relationship between ADEQ and Pinal County AQCD as

they relate to ambient air monitoring.

### 19

Finding # 8

Agency: ADEQ

Date of Audit: April 9

- 13, 2012

Program Area: Quality Assurance/ Quality Control

Finding:

The high volume ROOTS meter has not been calibrated on a regular basis

.

Discussion:

Flow rate measurements must be made by a flow measuring instrument that is traceable to a known

volume or other applicable standard and certified in accordance with EPA guidance. Specifically for

PM 10 , the flow rate transfer standard must be suitable for the sampler's operating flow rate and must be

calibrated against a primary flow or volume standard that is traceable to the National Bureau of Standards

(NBS).

In general, all working and primary standards should be calibrated at least annually, unless there is

information to indica te that less frequent calibration is acceptable. ADEQ has not calibrated its ROOTS

meter in over five years. EPA recognizes that a ROOTS meter is a very stable standard if the instrument is

in good condition, is not mishandled, and is not frequently moved or transported. EPA would consider a

calibration frequency of once every three years as acceptable for a ROOTS meter if ADEQ monitors the

instrument for signs of instability. A less frequent certification schedule would not produce sufficient

documentation of standards traceability.

References:

40 CFR p art 58, a pp endix A

, § 2.6.3

40 CFR p art 50, a pp endix J

, § 7.3

Recommendation to Address Finding:

The ROOTS meter should be appropriately calibrated and ADEQ should develop a calibration schedule

of at least once every three years.

### 20

Finding # 9

Agency: ADEQ

Date of Audit: April 9

- 13, 2012

Program Area: Field Operations

Finding:

Interval data are not always collected from manual PM 10 and PM 2.5 samplers.

Discussion:

ADEQ operates a number of manual PM 10 and PM 2.5 samplers (R&P 2000s) located in remote locations

within the network (i.e., Nogales Post Office, Douglas Red Cross, Prescott Valley, Flagstaff Middle

School, and Yuma Supersite) that are visited by ADEQ field technicians a pproximately once a month,

while filters are collected and shipped by contractors as needed.

During the filter collection process, the sample interval data are recorded on a “data card” (chain of

custody form) by the contractor, and sent to the particula te matter laboratory with the sample filter, while

the interval data that are digitally stored in the sampler are downloaded and transmitted to the particulate

matter laboratory approximately once a month. The information on the data card is verified in th e

laboratory against the interval data of the sampler to check for accuracy or inconsistencies.

At the time of the audit, it was discovered that the interval data are not always available for review. The

R&P 2000 has a two

- week interval data storage capa city, and because sites may not be visited within that

time period by ADEQ field technicians, these data are often lost or overwritten. Without these data, the

information on the data cards cannot be verified. These checks become increasingly important, as

previous evaluations have shown that the information on the data card and the interval data do not always

match.

References:

N/A

Recommendation to Address Finding:

Interval data should be collected on a regular basis. ADEQ should evaluate remote c ommunication

capabilities with the remote PM 10 and PM 2.5 samplers or implement a mandatory site visit schedule so that

interval data are not lost or overwritten.

### 21

Finding # 10

Agency: ADEQ

Date of Audit: April 9

- 13, 2012

Program Area: Field Operations

Finding:

Procedures for cleaning and changing sample lines are not sufficient for the local conditions experienced

throughout the network.

Discussion:

Due to the prevailing dusty conditions throughout Arizona, preventive maintenance may need to be

performed with greater frequency than is necessary in other areas of the U.S . These conditions increase

the likelihood for sampling lines to become contaminated with dust, which may cause O 3 scavenging

.

References:

QA Handbook for Air Pollut ion Measurement Systems, Volume II, EPA

- 454/b

- 08

- 002

, § 7.2 & appendix F

Technical Manual, Model 400E Photometric Ozone Analyzer, 2011

Recommendation to Address Finding:

Develop and implement a schedule for sample line cleaning or change out.

### 22

Finding # 1 1

Agency: ADEQ

Date of Audit: April 9

- 13, 2012

Program Area: Field Operations

Finding:

P recision checks or routine maintenance are performed inappropriately during high pollution episodes.

Discussion:

Field technicians should avoid performing QC checks or other routine maintenance or operations during

high pollution episodes. During 2011, there were multiple instances of missing O 3 data at the Queen

Valley site during some of the highest 8

- hour O 3 days of the year. Typi cally, agencies have SOPs or other

defined procedures related to checking the ambient concentration against a pollutant specific threshold on

an instrument prior to taking it off

- line for a QC check or maintenance.

References:

N/A

Recommendation to A ddress Finding:

Develop procedures to ensure instruments are not taken off

- line to perform routine procedures during

high pollution episodes.

### 23

Finding # 1 2

Agency: ADEQ

Date of Audit: April 9

- 13, 2012

Program Area: Particulate Matter Laboratory

Finding:

The PM laboratory data handling and processing system is inefficient, involving several steps, which

increases the likelihood of human error.

Discussion:

The data handling system found to be inadequate during the previous two TSAs of ADEQ is still

essentially unchanged. However, the verification process has been improved and no data errors have been

reported to AQS, as had been noted during the previous TSA.

The current data handling process involves four steps: collectio n and initial processing using the

analytical balance’s data system; transcription and entry of data into an Excel spreadsheet; data

processing and review in Excel; and data translation and importation into the ADEQ air monitoring data

base. Ideally, the d ata system used should be configured for complete electronic processing and transfer.

References:

QA Handbook for Air Pollution Measurement Systems, Volume II, EPA

- 454/b

- 08

- 002

, §14

Recommendation to Address Finding:

Evaluate methods to improve the efficiency and integrity of the PM laboratory data processing system.

### 24

Finding # 1 3

Agency: ADEQ

Date of Audit: April 9

- 13, 2012

Program Area: Data Management

Finding:

Documentation of the data validation process was not suffici ent to verify that all data had been validated

by the Data Management Team.

Discussion:

In general, documentation procedures have improved since the 2008 ADEQ TSA. For example, a process

has been put in place that provides the data validators with c opies of the field logbooks. However,

documentation of the validation process was not sufficient to follow the validation decisions. EPA

tracked several ADEQ validation decisions and did not find sufficient information to substantiate the

decision made w ith the information in the database and validation records. Normally these decisions

would be documented on a data validation worksheet that is peer/management reviewed and kept with the

validation “packages.”

The data valida t ion group do es produce quar terly reports on network data that contain useful information

regarding significant data deficiencies

. These help ed to resolve the validation decisions that were not well

documented in the validation records.

References:

QA Handbook for Air Pollution M easurement Systems, Volume II, EPA

- 454/b

- 08

- 002

, § 5 & 17

Recommendation to Address Finding:

Develop a method to record the validation process and document changes or flags applied to the data.

Formalize and standardize quarterly data validation report s.

### 25

Finding # 1 4

Agency: ADEQ

Date of Audit: April 9

- 13, 2012

Program Area: Field Operations

Finding:

Procedures for deploying new or replacement monitors to the field are inadequate, causing significant loss

of data

.

Discussion :

In three specific instances, data were lost due to instrument malfunction that could have been prevented.

In 2011, data were lost at the Prescott College site due to a pump failure caused by an overloading of an

in

- line particulate filter of a newly installed Teledyne 400E analyzer, which replaced the previously

operating O 3 analyzer. It was determined that, given the local conditions, the in

- line particulate filter of

the 400E was easily overloaded and had the potential to cause instrument malfunctio n.

Later in 2011, approximately four weeks of O 3 data at the Queen Valley site were lost during July and

August (peak O 3 season) due to the same problem with a newly installed 400E analyzer. Although the

problem had been identified, no corrective action or modification of procedures occurred within the

Monitoring Unit to address the instrument malfunction. Ideally, when new field instruments experience

problems, systematic changes should be made to the instrument itself (e.g. adding a second in

- line filte r to

sample line) or the maintenance or operating procedures (e.g. more frequent inspection and replacement

of in

- line filters) so that problems do not reoccur.

In a third instance, approximately eight months of PM 10 at Nogales Post Office were lost due to an

instrument malfunction that caused unusually low PM 10 values in the BAM 1020 analyzer at the site. The

Monitoring Unit believes that the unusually low values were caused by the erroneous use of a calibration

constant. It was not clear whether the err or was the result of operator error or an error on the part of the

manufacturer. Again, although the cause of the problem has been identified, no corrective actions or

changes to monitor testing and installation procedures have been made.

References:

N /A

Recommendation to Address Finding:

Develop the appropriate procedures for instrument deployment to reduce identified field instrument

malfunctions from reoccurring.

### 26

Finding # 1 5

Agency: ADEQ

Date of Audit: April 9

- 13, 2012

Program Area: Network Design

Finding:

The PM 2.5 sampler at Nogales Post Office is sampling at the incorrect frequency.

Discussion:

EPA, in conjunction with ADEQ, has reviewed the monitoring requirements for ADEQ’s PM 2.5 network

and has determined that only the N ogales Post Office site is required

. The other PM 2.5 sites in the network

are not explicitly required, as these sites are located in MSAs with populations between 50,000 and

500,000 and all available data show that PM 2.5 concentrations are less than 85% of the NAAQS.

Manual PM 2.5 samplers at required SLAMS without a collocated continuously operating PM 2.5 monitor

must operate on at least a 1

- in

- 3 day sampling schedule , unless a request for a sampling frequency

reduction to 1

- in

- 6 is approved by the Regiona l Administrator

. Furthermore, there are two instances

where PM 2.5 sites are required to maintain at least a 1

- in

- 3 sampling frequency: (1) for SLAMS whose

measurements determine the design value for their area and that are within plus or minus 10 percent o f the

NAAQS and (2) all required sites where one or more 24

- hour values have exceeded the NAAQS each

year for a consecutive period of at least 3 years.

While a continuous non

- FEM monitor operates at the Nogales Post Office site, previous design values at

the site have been within 10% of the NAAQS, and the site measured exceedances of the NAAQS within a

consecutive three year period from 2008

- 2010. Th erefore, a request to reduce the sampling frequency is

not appropriate, and the Nogales Post Office site i s required to meet the 1

- in

- 3 day sampling schedule.

References:

40 CFR p art 58.12 (d)(1)(ii)

40 CFR p art 58

, a pp endix D

, § 4.7.1

Recommendation to Address Finding:

Implement a 1

- in

- 3 day PM 2.5 sampling schedule at the Nogales Post Office site fo r at least a three

- year

period

.

### 27

Finding # 1 6

Agency: ADEQ

Date of Audit: April 9

- 13, 2012

Program Area: Data Management

Finding:

ADEQ’s procedure for making significant changes to data in AQS is not timely

.

Discussion:

ADEQ’s current procedure for making changes to certified data in AQS is to make the changes when

errors are found and certify the data as part of the next annual certification. ADEQ does not have a formal

procedure to review and approve these changes outside of the annu al certification process.

Because certified data in AQS are considered final and are used by EPA, the public and others, it is

important to have clear justification and approval when changes are made. EPA uses data from AQS

throughout the year in making regulatory decisions

, so agencies collecting data should promptly re

- certify

data if significant changes are made. In certain circumstances, i f significant changes have been ma de, it

may be necessary to re

- certify these data before the next annual certific ation.

References:

40 CFR p art 58.15

QA Handbook for Air Pollution Measurement Systems, Volume II, EPA

- 454/b

- 08

- 002

, § 14 .3.3

Recommendation to Address Finding:

ADEQ should strengthen the procedures for re

- certifying data when significant changes ar e made to

certified data in AQS.

### 28

Finding # 1 7

Agency: ADEQ

Date of Audit: April 9

- 13, 2012

Program Area: General

Finding:

ADEQ does not have back up capacity or cross

- training for the field auditor position.

Discussion:

As no ted in the previous TSA, the field auditor has a very heavy workload and there is no back up

capacity for this position. The QA Lead has been trained in some of the field auditor’s duties; however,

she is not an experienced field technician and also has a very heavy workload.

It was also noted that much of the field auditor’s operational knowledge of the audit program is unique.

Therefore the possibility of backfilling or supplementing the auditor’s position with other staff is limited.

References:

N /A

Recommendation to Address Finding:

Develop and implement a plan for cross

- training the field auditor’s duties.

### 29

Finding # 1 8

Agency: ADEQ

Date of Audit: April 9

- 13, 2012

Program Area: Field Operations

Finding:

R esidence time calculations are not tracked or documented

.

Discussion:

Residence time is defined as the amount of time that it takes for a sample of air to travel from the opening

of the cane to the inlet of the instrument. 40 CFR Part 58, a ppendix E

, § 9 states that for the reactive gases

(O 3 , NO 2 , and SO 2 ) residence times must be less than 20 seconds. Additionally, it is recommended that

the residence time within the manifold and sample lines to the instruments should be less than 10 seconds.

ADEQ fie ld technicians are calculating residence times, but not documenting the process or archiving

historical calculations. The field technicians should calculate the residence time, document it in the station

logbook, periodically verify the data, and take appr opriate corrective action if residence times are outside

acceptable limits.

During the TSA, it was also discovered that the residence time at the JLG S upersite exceeded the required

20 seconds.

References:

40 CFR p art 58, a pp endix E

, § 9(c)

Recommendation to Address Finding:

Appropriately track and document the calculation of residence time and take the appropriate corrective

action if residence times are outside acceptable limits. Specifically, the issue at the JLG S upersite should

be addressed as soon as possible.

### 30

Finding # 1 9

Agency: ADEQ

Date of Audit: April 9

- 13, 2012

Program Area: Field Operations

Finding:

ADEQ is not formally documenting the quality of zero air being used in the program at most of the

monitoring sites.

Disc ussion:

Zero air scrubbers are used in place of certified zero a ir for instrument calibrations. This is a common

practice and is acceptable. Because zero air is used to generate the zero point and the calibration mixes, it

must be treated as a standard. Therefore, zero air scrubber maintenance and verification must be

documented.

References:

QA Handbook for Air Pollution Measurement Systems, Volume II, EPA

- 454/b

- 08

- 002

, § 11 & appendix D

40 CFR part 50, app endices A

, C, D, & F

Recommendation to Addre ss Finding:

Document the quality of zero air when maintenance is performed on the zero air scrubbers and on a

periodic basis.

### 31

Finding # 20

Agency: ADEQ

Date of Audit: April 9

- 13, 2012

Program Area: General

Finding:

F acility

- collected data may not be appropriate to compare to the NAAQS

.

Discussion:

ADEQ submits PM 10 data collected by different facilities (i.e. Freeport McMoRan) to AQS, though the

data may not be appropriate to compare against the NAAQS, as the level of ove rsight by ADEQ may not

be adequate to make such a determination.

References:

40 CFR p art 50 , appendices J & K

40 CFR p art 58 , appendices A, C, D, & E

Recommendation to Address Finding:

Evaluate whether data collected by facilities or other organiz ations meet the requirements for NAAQS

decisions. ADEQ should either ensure that the data collected meet all applicable requirements for

comparison to the NAAQS or appropriately characterize the data in AQS as “non

- regulatory”.

### 32

Fi nding # 2 1

Agency: ADEQ

Date of Audit: April 9

- 13, 2012

Program Area: Field Operations

Finding:

There is insufficient room at the Globe Highway monitoring site for EPA Pb PEP audit samplers.

Discussion:

Two collocated high

- volume TSP samplers are located approximately two meters apart on a 2x3m metal

platform. Collocated high

- volume PEP samplers must be within four meters of each other horizontally

and at least two meters apart to preclude airflow interference. Also, it is a general practice for t he vertical

distance between the PE sampler inlet and the audited site sampler inlet to be ≤1 meter.

In the current configuration, there may be insufficient room for EPA Pb PEP audit samplers to meet these

general requirements.

References:

40 CFR part 58, a pp endix A

, § 3.3.1.2

Field Standard Operating Procedures for the Federal PM 2.5 Performance Evaluation Program, 2009

Recommendation to Address Finding:

Provide appropriate accommodation for EPA Pb PEP audit samplers.

### 33 APPENDIX A: SUMMARY OF F INDINGS

FINDINGS

Finding 1: ADEQ does not have QAPPs for O 3 

### , SO 2 

### , NO 2 

### , CO, and NCore monitoring; QAPPs

for PM 10 

### and PM 2.5 

### are outdated and should be revised.

Finding 2: Operational procedures are not sufficient to minimize loss of air quality data due to

malfunction or out

- of

- control conditions. The ADEQ Field Technicians are not

sufficiently involved in the review of daily monitoring data and the data validation

process to ensure data completeness requirements are met.

Finding 3: ADEQ has not develope d a formal corrective action process to address significant

QA deficiencies.

Finding 4: ADEQ has not performed internal audits of the air monitoring program activities or

support contractors on a regular basis

.

Finding 5: ADEQ does not have a formal trai ning program for air monitoring staff and

contractors who perform routine monitoring system operations.

Finding 6: ADEQ does not have a mechanism to pass through Clean Air Act Section 103 grant

funds that are allocated specifically for PC AQCD’s ambient ai r PM 2.5 

### monitoring

program.

Finding 7: The PQAO relationship between ADEQ and PCAQCD is ambiguous

.

Finding 8: The high volume ROOTS meter has not been calibrated on a regular basis

.

Finding 9: Interval data are not always collected from manual PM 10 

### and PM 2.5 

### samplers.

Finding 10: Procedures for cleaning and changing sample lines are not sufficient for the local

conditions experienced throughout the network.

Finding 11: Precision checks or routine maintenance are performed inappropriately during high

po llution episodes.

Finding 12: The PM laboratory data handling and processing system is inefficient, involving

several steps, which increases the likelihood of human error.

Finding 13: Documentation of the data validation process was not sufficient to ver ify that all

data had been validated by the Data Management Team.

Finding 14: Procedures for deploying new or replacement monitors to the field are inadequate,

causing significant loss of data

.

### 34

Finding 15: The PM 2.5 

### sampler at Nogales Post Office is op erating at the incorrect frequency.

Finding 16: ADEQ’s procedure for making significant changes to data in AQS is not timely

.

Finding 17: ADEQ does not have back up capacity or cross

- training for the field auditor

position.

Finding 18: R esidence time c alculations are not tracked or documented.

Finding 19: ADEQ is not formally documenting the quality of zero air being used in the

program at most of the monitoring sites.

Finding 20: F acility

- collected data may not be adequate to compare to NAAQS

.

Findi ng 21: There is insufficient room at the Globe Highway monitoring site for EPA Pb PEP

audit samplers.

### 35 APPENDIX B : ORGANIZATIONAL CHART S

### 36