S71

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX 1q 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) ofthe 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 ofreceipt ofthe final TSA report.

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

results ofthis 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 2013
ii

INDEX

GLOSSARY OF ACRONYMS........................................................................................1

EXECUTIVE SUMMARY...............................................................................................2

TSA ACTIVITIES.............................................................................................................4

OVERVIEW OF AIR MONITORING PROGRAM ....................................................7

FINDINGS................................................................................................................11

APPENDIX A: Summary of Findings.......................................................................33

APPENDIX B: Organizational Chart.......................................................................36
1

GLOSSARY OF ACRONYMS

ADEQ.......................................... Arizona Department of Environmental Quality

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

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

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

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 Reference Method

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

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

NBS..............................................National Bureau of Standards

NCORE........................................National Core multipollutant monitoring stations

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

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

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

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

PM2.5............................................ Particulate Matter with aerodynamic diameter <= 2.5 μm

PM10............................................. Particulate Matter with aerodynamic diameter <= 10 μm

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

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

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

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

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

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

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

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

SO2............................................... 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) of 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 part 58, appendix 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 the monitoring sites operated 

by ADEQ. The site inspections consisted of an interview 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 PM10 and PM2.5.

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

state, local, and tribal agencies meet required minimum 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 recommended 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 management 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 organized.

 Entries 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 as 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 where ADEQ’s monitoring program should be 

strengthened. The major findings are:

1. ADEQ does not have Quality Assurance Project Plans (QAPPs) for O3, SO2, NO2, CO, 

and NCore monitoring; QAPPs for PM10 and PM2.5 are outdated and should be revised.

2. Field Technicians 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 established.

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 

(PCAQCD) ambient air PM2.5 monitoring program.

The individual findings are reported 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 following 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 improvement

- 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 preventive maintenance

- Laboratory record keeping

- Laboratory data acquisition and handling

- Specific pollutants: PM10 and PM2.5

 Data and Data Management

- Data handling

- Software documentation

- Data validation and correction

- Data processing

- Internal reporting

- External 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, managers 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 Assessment 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 report 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 alternatives 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, the 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, appendix E. The

evaluation included inspection of the inlet manifolds, examination of station and instrument 

logbooks, and a check of whether appropriate QC checks and QA audits were being performed. 

All monitoring sites 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 

particulate matter laboratory was well maintained and organized. Generally, the quality of the 

PM10 and PM2.5 laboratory measurements reflect ADEQ’s high level of technical expertise, 

ensuring the collection of data of appropriate quality. 

Data Management

This section covers data management for criteria pollutants (O3, CO, NO2, SO2, PM2.5, and 

PM10). Staff interviewed were Bryan Paris, Heather Colson, Teresa Mackey, and Mark Carrel.
6

Quality Assurance/Quality Control

EPA interviewed Theresa Rigney, Ceresa 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 requirements. 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 PM10, PM2.5, 

and gaseous criteria pollutants (O3, CO, NO2, SO2,). Overall, the ADEQ system conforms to the 

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

EPA also performs national performance audits of ADEQ’s gaseous and PM2.5 monitors and 

technical evaluations of the monitoring network.
7

OVERVIEW OF AIR MONITORING 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 entered 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 air 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 ADEQ’s Air Quality Assessment Section, which is responsible for the 

implementation 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 ADEQ, 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 improvement 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 Technical 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 programs. 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 ambient 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 SO2 NO2 O3 PM10 PM2.5 PM10-2.5 Pb NOy Met

Ajo x x

Alamo Lake x

Bullhead City x

Douglas Red Cross x x

Flagstaff x x x

Globe Highway x x

Green 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 Station

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 duties 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 maintenance,

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 is supported by 

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

handling filters, which includes preparation, weighing, tracking, and storing PM2.5 and PM10

filters. The PM laboratory is well organized and run. ADEQ 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.

Data 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 handled 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 are reviewed daily to weekly by Mark Carrel of the 

Data Management Team. 

Laboratory Data (PM)

PM10 and PM2.5 filters are weighed by an automated system and results are transferred to the 

weigh laboratory MTL database. MTL automatically flags data if weigh 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 Laboratory 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 review. 
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, field 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 Finding Numbers EPA Contact

General 1,5-7,17, & 20 M. Flagg & M. Plate

Network Management 15 M. Flagg

Field Operations 2,9-11,14,18,19, & 21 M. Flagg

Particulate Matter (Gravimetric) Laboratory 12 M. Flagg

Data Management 13 &16 M. Plate

Quality Assurance/Quality Control 3,4, & 8 M. Plate
12

Finding # 1

Agency: ADEQ

Date of Audit: April 9-13, 2012

Program Area: General

Finding:

ADEQ does not have QAPPs for O3, SO2, NO2, CO, and NCore monitoring; QAPPs for PM10 and PM2.5 

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. The 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 documents the quality assurance and 

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

type and quality needed and expected. 

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

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

programs.

References:

40 CFR part 58, appendix A, §2.1

EPA Requirements for Quality Assurance Project Plans, EPA/240/B-01/003, March 2001

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 O3, SO2, NO2, CO, and NCore monitoring must be developed, and QAPPs for PM10 and PM2.5 

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

Program 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 monitoring 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., O3 data at Prescott College and Queen Valley, and PM10 data at Nogales Post Office).

References:

40 CFR part 58, appendix A, §2

40 CFR part 50, appendices 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 stations 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, PM10 and PM2.5 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 root cause(s) of the problem so that changes can be made to prevent reoccurrence 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 recommends that ADEQ perform internal audits that are required under their 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 agency’s overall QA system. The agency should maintain an 

independent QA management function that conducts “independent oversight” and assures the 

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

Data or internal program audits are a form 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 part 58, appendix A, §2.2

EPA Requirements for Quality 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 schedule 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 monitoring 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 cases, 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 Section 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 personnel 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 that 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 (PCAQCD) ambient air PM2.5

monitoring program.

Discussion:

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

allocated to PCAQCD. Specifically, ADEQ has received funds for field operation and maintenance, 

weigh lab operation and maintenance, and other site costs for three PM2.5 monitoring sites (Casa Grande, 

Cowtown, and Apache Junction) operated and maintained by PCAQCD. 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 including 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 

PCAQCD should be 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.

Recommendation 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

Finding:

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 common 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 clear that PCAQCD independently meets most of the five common factors for 

a PQAO. For example, PCAQCD has independent QAPPs for ozone, PM2.5, and PM10; monitoring sites 

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

process and operates an independent gravimetric lab for PM10 and PM2.5 filters.

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

Data Management & Quality Assurance Unit for O3 annual performance evaluations and PM10 and PM2.5 

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 this 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 developing 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 Organization 

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 

PM10, 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 indicate 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 part 58, appendix A, §2.6.3

40 CFR part 50, appendix 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 PM10 and PM2.5 samplers.

Discussion:

ADEQ operates a number of manual PM10 and PM2.5 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 approximately 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 particulate 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 the 

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 capacity, 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 communication 

capabilities with the remote PM10 and PM2.5 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 O3 scavenging.

References:

QA Handbook for Air Pollution 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 # 11

Agency: ADEQ

Date of Audit: April 9-13, 2012

Program Area: Field Operations

Finding:

Precision 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 O3 data at the Queen 

Valley site during some of the highest 8-hour O3 days of the year. Typically, 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 Address Finding:

Develop procedures to ensure instruments are not taken off-line to perform routine procedures during 

high pollution episodes.
23

Finding # 12

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: collection 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 data 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 # 13

Agency: ADEQ

Date of Audit: April 9-13, 2012

Program Area: Data Management

Finding:

Documentation of the data validation process was not sufficient 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 copies 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 with 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 validation group does produce quarterly reports on network data that contain useful information 

regarding significant data deficiencies. These helped to resolve the validation decisions that were not well 

documented in the validation records.

References:

QA Handbook for Air Pollution Measurement 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 reports. 
25

Finding # 14

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 O3 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 malfunction. 

Later in 2011, approximately four weeks of O3 data at the Queen Valley site were lost during July and 

August (peak O3 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 filter 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 PM10 at Nogales Post Office were lost due to an 

instrument malfunction that caused unusually low PM10 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 error 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 # 15

Agency: ADEQ

Date of Audit: April 9-13, 2012

Program Area: Network Design

Finding:

The PM2.5 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 PM2.5 network 

and has determined that only the Nogales Post Office site is required. The other PM2.5 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 PM2.5 concentrations are less than 85% of the NAAQS.

Manual PM2.5 samplers at required SLAMS without a collocated continuously operating PM2.5 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 Regional Administrator. Furthermore, there are two instances 

where PM2.5 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 of 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. Therefore, a request to reduce the sampling frequency is 

not appropriate, and the Nogales Post Office site is required to meet the 1-in-3 day sampling schedule.

References:

40 CFR part 58.12 (d)(1)(ii)

40 CFR part 58, appendix D, §4.7.1

Recommendation to Address Finding:

Implement a 1-in-3 day PM2.5 sampling schedule at the Nogales Post Office site for at least a three-year 

period.
27

Finding # 16

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 annual 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, if significant changes have been made, it 

may be necessary to re-certify these data before the next annual certification.

References:

40 CFR part 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 are made to 

certified data in AQS.
28

Finding # 17

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 noted 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 # 18

Agency: ADEQ

Date of Audit: April 9-13, 2012

Program Area: Field Operations

Finding:

Residence 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, appendix E, §9 states that for the reactive gases 

(O3, NO2, and SO2) 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 field 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 appropriate corrective action if residence times are outside 

acceptable limits.

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

20 seconds.

References:

40 CFR part 58, appendix 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 Supersite should 

be addressed as soon as possible.
30

Finding # 19

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.

Discussion:

Zero air scrubbers are used in place of certified zero air 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, appendices A, C, D, & F

Recommendation to Address 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:

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

Discussion:

ADEQ submits PM10 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 oversight by ADEQ may not 

be adequate to make such a determination. 

References:

40 CFR part 50, appendices J & K

40 CFR part 58, appendices A, C, D, & E

Recommendation to Address Finding:

Evaluate whether data collected by facilities or other organizations 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

Finding # 21

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 the 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, appendix A, §3.3.1.2

Field Standard Operating Procedures for the Federal PM2.5 Performance Evaluation Program, 2009

Recommendation to Address Finding:

Provide appropriate accommodation for EPA Pb PEP audit samplers. 
33

APPENDIX A: SUMMARY OF FINDINGS

FINDINGS

Finding 1: ADEQ does not have QAPPs for O3, SO2, NO2, CO, and NCore monitoring; QAPPs 

for PM10 and PM2.5 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 developed 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 training 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 PCAQCD’s ambient air PM2.5 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 PM10 and PM2.5 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 

pollution 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 verify 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 PM2.5 sampler at Nogales Post Office is operating 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: Residence time calculations 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: Facility-collected data may not be adequate to compare to NAAQS.

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

audit samplers.
35

APPENDIX B: ORGANIZATIONAL CHARTS
36