Technical System Audit Report 

Clark County Department of 

Air Quality and Environmental 

Management 

Ambient Air Quality Monitoring 

Program 

July 28 – July 30, 2009 

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 

February 2010 
Clark Co. TSA Report: September 2009 

CONTENTS 

PAGE 

GLOSSARY OF ACRONYMS.........................................................................3 

 EXECUTIVE SUMMARY................................................................................4

INTRODUCTION............................................................................................ .6 

 A. GENERAL PROGRAM...............................................................................8 

 B. NETWORK MANAGEMENT.....................................................................14 

 C. FIELD OPERATIONS..................................................................................17 

 D. LABORATORY OPERATIONS................................................................. 20 

 E. DATA AND DATA MANAGEMENT.........................................................22 

 F. QUALITY MANAGEMENT........................................................................23

 APPENDIX A, Summary of Findings...................................................25 

 

 APPENDIX B, QMP and QAPP Comments...........................................27 

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Clark Co. TSA Report: September 2009 

GLOSSARY OF ACRONYMS 

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

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

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

EMS............................ Electronic Management System 

LEADS......................... Leading Environmental Analysis and Display System 

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

NCore.................................. National Core multipollutant monitoring stations 

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

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

NV............................... State of Nevada 

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

ORD............................. Office of Research and Development 

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

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

diameter 

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

PM10...................................... Particulate matter 10 microns or less in aerodynamic 

diameter 

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

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

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

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

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

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

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

SO2....................................... Sulfur Dioxide 

SRP............................. Standard Reference Photometer 

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

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

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

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Clark Co. TSA Report: September 2009 

EXECUTIVE SUMMARY

 This report documents the findings made by EPA Region 9 during its Technical 

System Audit (TSA) of the Clark County Department of Air Quality and Environmental 

Management (DAQEM) 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 measurement data. This TSA meets the requirements for EPA 

Regional 9 audits of the DAQEM monitoring organization required by 40 CFR Part 58, 

Appendix A, Section 2.5. 

 The TSA was conducted by EPA Region 9 staff from July 28 – July 30, 2009. 

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 several monitoring sites and visited several additional monitoring sites 

including the proposed NCore monitoring station. The site inspections consisted of 

interviewing the site operator, reviewing station and instrument logbooks, and evaluating 

the station siting with respect to EPA requirements for probe siting1. 

 The TSA is one of the ways EPA oversees data collection activities performed by 

state and local agencies to ensure they meet certain minimum data quality objectives. 

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

to collect information on the overall quality of ambient air monitoring data. These 

assessments enable agencies to identify and correct program elements which may be 

adversely affecting the quality of ambient air data. 

 The results of the TSA are summarized below and discussed in more detail in the 

specific sections of this report Recommendations for addressing each of the findings are 

provided. The specific actions taken by DAQEM to address the findings should be 

approved by EPA and documented by DAQEM in a corrective action plan. 

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

support and cooperation during the audit. 

Program Strengths: 

• Overall, DAQEM has well qualified, very knowledgeable, and experienced staff. 

• DAQEM has recently upgraded the data collection system for continuous 

pollutants. This upgrade has improved its ability to process data efficiently and 

control data quality. 

 

1

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

Air Quality Monitoring” 

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Clark Co. TSA Report: September 2009 

• Each DAQEM monitoring station visited is well sited to collect representative 

data. 

• DAQEM data specialists were able to easily track the data points requested by the 

auditors. 

• The PM2.5 laboratory is well maintained and organized by the analysts. 

• Many DAQEM staff members have implemented measures to improve the quality 

of the overall monitoring program. 

Program Findings: 

 While acknowledging the strengths of DAQEM’s monitoring program, EPA 

identified several program elements that could be improved. Specifically, DAQEM 

should: 

• Strengthen the Quality Assurance program by giving it a more formal role in its 

oversight of the monitoring program, and by providing technical capacity at 

higher levels of management to oversee the QA officer’s work. 

• Ensure the Quality Management Plan and Quality Assurance Plans include 

sufficient information to meet EPA requirements. 

• Improve procedures for maintaining hard copy records that are consistent, secure, 

and regularly updated. DAQEM should also standardize procedures for creating 

records in the Leading Environmental Analysis and Display System (LEADS) 

data system. 

• Improve the procedures for reporting data in Air Quality System (AQS) by 

adequately identifying compromised data. DAQEM should maintain records in 

the LEADS data system that document why data have been flagged in AQS and 

should verify that data submitted to AQS is consistent with the data that are 

published on its website. 

• Improve the systems for tracking the location and status of equipment, and 

improve the procedures for initiating and documenting equipment repairs. 

 In addition to these significant findings, EPA has identified additional findings 

and made recommendations. The individual findings are reported in the topic sections of 

this document and are also summarized in Appendix A. 

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Clark Co. TSA Report: September 2009 

INTRODUCTION

 The Clark County DAQEM is the government agency with delegated authority 

and responsibility for collecting ambient air quality data pursuant to the Clean Air Act of 

1977 and the Clean Air Act Amendments of 1990. 

 From July 28 through July 30, 2009, Michael Flagg of the Region 9 Air Quality 

Analysis Office and Matthew Plate of the Region 9 Quality Assurance Office conducted 

a Technical System Audit of DAQEM’s ambient air monitoring program. The TSA 

covered the following program areas: 

• General / Quality Management 

o Program Organization 

o Facilities 

o Independent Quality Assurance and Quality Control 

o Planning Documents (including QMP, QAPPs, & 

SOPs) 

o General Documentation Policies 

o Training 

o Corrective Action 

o Quality Improvement 

o External Performance Audits 

• Network Management / Field Operations 

o Network Design 

o Changes to the Network since the last audit 

o Proposed changes to the Network 

o Field Support 

 SOPs 

 Instrument Acceptance 

 Calibration 

 Repair 

 Site and Monitor Information Form 

• Laboratory Operations 

o Routine Operations 

o Quality Control 

o Laboratory Preventive Maintenance 

o Laboratory Record Keeping 

o Laboratory Data Acquisition and Handling 

o Specific Pollutants: PM10, PM2.5 and Lead 

• Data and Data Management 

o Data Handling 

o Software Documentation 

o Data Validation and Correction 

o Data Processing 

o Internal Reporting 

o External Reporting 

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Clark Co. TSA Report: September 2009 

 Additionally, EPA tracked supporting documentation for several data points/sets 

from calendar year 2008. 

 Participating DAQEM managers, supervisors and staff included: 

• Mike Sword, Engineering Manager 

• Yousaf Hameed, Monitoring Supervisor 

• Mickey Palmer, Senior Monitoring Tech. (QA Officer) 

• Mickey Turner, Senior Monitoring Tech. 

• Phillip Wiker, Senior Monitoring Tech. 

• Pravin Perna, Monitoring Tech. II 

• Dave Dickens, Monitoring Tech. II 

• Mathew Nelson, Monitoring Tech. II 

• Kris Simonian, Monitoring Tech. II 

 This report is divided into ten sections. The first section is an executive summary 

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

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

air monitoring program, identifies participating DAQEM personnel and the EPA audit 

team, and describes the report’s organization. The third section discusses the 

general/significant findings. The next five sections address specific aspects of the air 

monitoring program: network management, field operations, laboratory operations, data 

management and quality assurance/quality control. Appendix A is a summary listing of 

the findings contained in this report. Appendix B includes EPA concerns with the 

DAQEM Quality Management Plan, QA Project Plans, and associated Standard 

Operating Procedures. Recommendations for each finding are provided to give some 

indication of the EPA Region 9’s expectations as to how findings can be addressed. If 

the DAQEM has other approaches or alternatives to address the concerns identified, the 

Region will consider them, provided the corrective action adequately addresses the 

finding. 

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Clark Co. TSA Report: September 2009 

A. GENERAL PROGRAM

 

 The Governor of Nevada gave authority for Air Quality Matters in Clark County 

to the Clark County Board of Commissioners in 2001. This is reflected in the Nevada 

Revised Statutes 445B.500, which delegate significant air pollution control authority to 

Nevada counties with populations greater than 400,000. The Clark County Board of 

Commissioners created an Air Quality Management Board to govern air quality programs 

and DAQEM to implement air quality programs, including ambient air quality 

monitoring. Prior to 2001, ambient air quality monitoring was implemented by the Clark 

County District Health Department. 

 DAQEM currently has 16 active monitoring stations for criteria pollutants. The 

pollutants measured include:

• Carbon Monoxide 

• Nitrogen Dioxide 

• Ozone 

• Particulate Matter (PM10 and PM2.5) 

DAQEM is headed by a Director and two Assistant Directors. At the time of the 

audit one of the Assistant Director positions was vacant. Ambient air monitoring is 

conducted by the Engineering Division, which is lead by an Engineering Manager, who 

reports to an Assistant Director. The Engineering staff consists of a Monitoring 

Supervisor, who oversees 11 technical staff. At the time of the audit one of these staff 

positions was vacant. An Office Specialist and a Senior Technician/QA Officer report 

directly to the Engineering Manager.

FINDING A1:

DAQEM’s Quality Assurance program may lack sufficient management and should have 

a more formal and independent role in the oversight of the monitoring program. 

Discussion: 

The EPA requirements for independence of quality assurance for Primary Quality 

Assurance Organizations (PQAOs) are in 40 CFR Part 58, Appendix A, Section 

2.2. This section states that “the quality assurance management function must 

have sufficient technical expertise and management authority to conduct 

independent oversight and assure implementation of the organization’s quality 

system.” The DAQEM program includes one senior technician who serves as the 

quality assurance auditor and quality assurance officer. While this organizational 

structure provides a level of independence for the QA functions performed that is 

generally acceptable, it is less than the two layers of management that EPA 

recommends. More significantly, the quality assurance function does not include 

sufficient formal technical oversight of the monitoring program and there is no 

mechanism for independent review of the QA officer’s work. EPA also found that 

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Clark Co. TSA Report: September 2009 

the following functions, which should be performed by the independent QA 

officer, were either not being performed or were not being performed adequately: 

• Periodic audits of the quality management system (management system 

reviews), routine procedures, and data quality to identify areas of 

improvement and to ensure that monitoring programs continue to follow 

sound and documented procedures. 

• Formalized review of certain QA activities, such as data validation, annual 

certification of the O3 transfer and flow standards, and the certification of 

calibration gas cylinders for NOx, CO, and SO2 instrument calibration. 

• Review and approval of corrective actions. 

• Review and tracking of precision and accuracy data. 

EPA QA/R-5, EPA Requirement for Quality Assurance Project Plans, lists the 

types of assessments that should be elements of a quality management program. 

These include, “surveillance, management systems reviews, readiness reviews, 

technical systems audits, performance evaluations, audits of data quality, and data 

quality assessments.” 

 Recommendations: 

2. DAQEM should strengthen the Quality Assurance/Quality Management 

function by giving it more formal authority to oversee the monitoring 

program. 

1. DAQEM should consider alternative organizational or reporting structures 

which will provide for greater technical capacity at higher levels of 

management to oversee the work of the QA officer. 

3. DAQEM should also consider moving functions, such as data management 

and validation, into the QA unit because it is not directly involved in data 

collection. 

FINDING A2:

The Quality Management Plan (QMP) and Quality Assurance Project Plans (QAPPs) 

need additional information to meet EPA requirements. 

Discussion: 

The QMP and QAPPs submitted to EPA by DAQEM in 2008 do not include 

many elements required in QA planning documents. Specific comments on these 

documents are provided in Appendix B. 

All organizations conducting environmental programs funded by EPA are 

required to establish and implement a quality management system. In accordance 

with 40 CFR Parts 31 and 35, grant recipients are required to document their 

quality systems in a Quality Management Plan through EPA Order 5360.1 A2, 

Policy and Program Requirements for the Mandatory Agency-wide Quality 

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Clark Co. TSA Report: September 2009 

System (EPA 2000). Additionally, specific ambient air monitoring requirements 

are found in 40 CFR, Part 58, Appendix A, Section 2.1. Guidance on developing 

QMPs can be found in the EPA guidance document “EPA Requirements for 

Quality Management Plans”, EPA/240/B-01/002, March 2001. 

EPA also requires that organizations develop a QAPP for each type of ambient 

pollutant that is 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 results for 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. Further guidance on developing QAPPs can be 

found in the guidance documents “EPA Requirements for Quality Assurance 

Project Plans,” EPA/240/B-01/003, March 2001, and “Guidance for Quality 

Assurance Project Plans,” EPA/240/R-02/009, December 2002. 

 

 Recommendation: 

DAQEM should work with EPA Region 9 to develop approved QA planning 

documents. 

 

FINDING A3:

The consistency of records generated and maintained in the LEADS Electronic 

Management System (EMS) is inadequate. Inconsistencies in the generation and 

retention of other records may also exist. 

Discussion: 

Many of the records DAQEM generates and maintains are kept in the LEADS 

EMS, which is an useful central repository. However, EPA noted inconsistencies 

in the generation and completeness of records in the system. Significant 

examples are the monitoring station logs and data validator’s notes. 

When comparing data in the LEADS system to data in AQS, it was not always 

clear why certain data were flagged in AQS and other data were not. This was 

mainly due to the level of detail in the electronic “logs” and comments. Because 

the LEADS EMS entry fields are “free form”, it is especially important that the 

operators and validators develop and use a standardized minimal level of detail 

when entering information. The procedure for documenting peer, supervisor, 

validator, and QA Officer review of these records should also be standardized. 

DAQEM has established systems for maintaining other information in instrument 

logbooks and laboratory records. For other records maintained by individual 

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Clark Co. TSA Report: September 2009 

staff, the department has no clear recordkeeping procedures. The Department 

should evaluate the records maintained by individuals to ensure they are 

consistent, secure, regularly maintained, and (for electronic records) backed-up. 

 Also see Finding C6. 

 Recommendation: 

DAQEM should create a standardized method for creating and maintaining 

“station logs” and other entries within the LEADS system. Additionally, the 

Department should evaluate other electronic and hard-copy documentation to 

ensure that they are consistently prepared and maintained. 

 

FINDING A4:

Procedures for submitting data to the AQS, flagging data in AQS, and reporting data to 

the public need to be improved. 

 

Discussion: 

In the past year and a half, DAQEM has shifted most data reporting to a new data 

system supported by IPS MeteoStar. 

If data are compromised, the appropriate AQS flags should be applied. DAQEM 

uses the “miscellaneous void (AM)” flag to describe a number of different issues 

with the data. Using flags that specifically describe how the data are compromised 

enables DAQEM and EPA staff and the public to understand better what the 

issues associated with the data are. All AQS codes and flags can be found at: 

http://www.epa.gov/ttn/airs/airsaqs/manuals/codedescs.htm. 

Data that DAQEM intends to submit for consideration under EPA’s exceptional 

events rule have not been flagged as such in AQS. Pursuant to 40 CFR 

50.14(c)(2)(iii), “Flags placed on data being due to exceptional events together 

with an initial description of the event shall be submitted to EPA not later than 

July 1st of the calendar year following the year in which the flagged measurement 

occurred.” Because the exceptional events rule allows for the exclusion of data 

from consideration against the NAAQS, values affected by exceptional events 

will impact the planning process of both DAQEM and EPA Region 9. This 

timeline ensures the efficiency of exceptional event evaluation and should be met 

in accordance with the CFR. 

Finally, EPA noted discrepancies when comparing validated data reported by 

DAQEM on its website with data in AQS. An example of this is ozone data 

reported from the E. Craig Road site from February 1-4, 2008. The Department 

web-based system reported zeros during this time period, while the data in AQS 

were invalidated. An evaluation of similar data during the audit found that this 

was an artifact of importing data into the system. This raises the possibility that a 

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Clark Co. TSA Report: September 2009 

significant amount of data available to the public may not match what was 

reported to AQS. 

One instance of data not being reported to AQS was also noted. This was for 

ozone at the Joe Neal site from November 3-5, 2008. An evaluation of the data 

system revealed the data were not reported to AQS by the LEADS EMS because 

it had not been marked as “validated” in the system. 

 Recommendations: 

1. DAQEM should improve its use of flagging by using more descriptive flags 

and by avoiding overuse of the “miscellaneous void (AM)” flag. 

2. DAQEM should identify and resolve all discrepancies between the data in 

AQS and the data reported on its website. DAQEM should additionally 

implement procedures to eliminate such discrepancies in the future. 

FINDING A5:

DAQEM lacks an adequate system for tracking equipment status, initiating equipment 

repairs, and documenting repair history. 

Discussion: 

DAQEM does not have an established mechanism for tracking instrument 

location, condition, and repair history. Currently monitors that are not 

functioning properly are replaced with working instruments as available from the 

main office. Because poorly functioning equipment may have bearing on data 

quality, this information should be tracked in a manner that is easily recoverable. 

Improved efforts to track such information may prevent the deployment of poorly 

functioning instruments and allow DAQEM to reduce the number of instruments 

held in reserve. 

At the time of the audit, it was also not clear who was responsible for initiating 

repairs to broken instruments. This should be resolved so that instrument repair is 

undertaken and verified by qualified individuals. 

Overall, it is evident that establishing a formal communication system related to 

instrument operation and maintenance would improve data quality in all elements 

of the quality management system, including some which may not have been 

identified in this audit. 

 Recommendations: 

1. DAQEM should develop a system to track the location and status of all 

instruments. 

2. DAQEM should establish standard procedures for initiating and documenting 

equipment repairs. 

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Clark Co. TSA Report: September 2009 

B. NETWORK MANAGEMENT

 The Clark County network for state and local air monitoring stations (SLAMS) 

consists of 16 stations. The following table summarizes the SLAMS air monitoring sites 

in Clark County by the respective pollutants monitored and the year monitoring began at 

the site. 

SITE NAME 

(year established) 

POLLUTANT 

CO SO2 NO2 O3 PM10 PM2.5 PM2.5 

continuous

Apex(1998) X X X 

Boulder City (1998) X X 

E. Craig Road (1992) X X X 

E. Sahara (1995) X 

Green Valley (1998) X X 

J.D. Smith (1998) X X X X X X 

Jean (1995) X X X X 

Joe Neal(2000) X X X 

Lone Mountain (1998) X X 

Mesquite(2001) X X 

Orr (2002) X X X 

Palo Verde (1998) X X 

Paul Meyer (1998) X X 

Sunrise Acres (1996) X X X X 

Walter Johnson (1995) X 

Winterwood (1979) X X 

Source: DAQEM 2008 Air Monitoring Network Plan 

 The Clark County network currently meets or exceeds the requirements for the 

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

pollutants. All of the monitoring sites are properly located with respect to monitoring 

objectives, spatial scales and other siting criteria. 

Pursuant to 40 CFR 58.20, states must perform an annual review of their ambient 

monitoring network. The annual network review is used to determine how well the 

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

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

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

objectives and data needs. The main purpose of the review is to improve the network to 

ensure it provides adequate, representative, and useful air quality data. Based on changes 

to the monitoring regulations, which went into effect in December 2006, the annual 

network plan now requires evidence of a public inspection process. Clark County 

DAQEM submits a monitoring network plan every year. The most recent submittal by 

DAQEM, in 2009, contains all of the required information about the monitoring stations, 

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Clark Co. TSA Report: September 2009 

including the information required by 40 CFR Part 58, Appendix A (quality assurance 

requirements) and Appendix D (network requirements and monitoring site objectives). 

Network Management

Finding B1: 

The DAQEM system lacks the necessary flexibility to establish new monitoring stations 

in response to changing conditions. 

Discussion: 

 DAQEM has been working through the logistics of establishing a new NCore 

monitoring station for over a year. DAQEM has indicated that this is due to Clark 

County facility and permitting requirements, which are outside its control. In the 

future, DAQEM may be required to move and/or establish new monitoring sites 

to accommodate new monitoring requirements and/or other changes in the 

network. Excessive start-up times could mean required data are not collected. 

Recommendation: 

DAQEM should develop a system to establish monitoring sites more 

expeditiously (e.g., develop standardized pre-approved monitoring station 

configurations). 

Finding B2: 

DAQEM is working to resolve the status of its formal application for a PM2.5 Approved 

Regional Method (ARM) for the continuous monitors. 

Discussion: 

 In 2006, EPA published criteria for approving continuous methods for PM2.5

monitoring ARMs in 40 CFR Part 58, Appendix C. ARMs must be approved or 

disapproved by EPA within 120 days of submittal. EPA ORD is currently 

requesting more information from DAQEM to supplement its ARM application, 

which will reset the 120-day clock. 

A more recent model of the Thermo Beta Attenuation Monitoring being used by 

DAQEM has recently been approved as a Federal Equivalent Method (FEM). It 

would be advantageous from a collocation standpoint to use the FEM rather than 

an ARM method as the latter requires 30% collocation with an FRM or FEM and 

7.5% collocation ARM to ARM (see the text below from 40 CFR Part 58, 

Appendix C). 

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Clark Co. TSA Report: September 2009 

2.4.4.5 Collocation with an ARM under this part for purposes of 

determining the coefficient of variation of the method shall be conducted 

at a minimum of 7.5 percent of the sites with a minimum of 1 per network. 

This is consistent with the requirements in Appendix A to this part for onehalf of the required collocation of FRM/FEM (15 percent) to be collocated 

with the same method. 

Recommendation: 

DAQEM and EPA Region 9 should follow up on the status of the ARM submittal, 

but also consider initiating a program to upgrade the continuous instruments to 

FEMs in order to save on long-term operational costs. 

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Clark Co. TSA Report: September 2009 

C. FIELD OPERATIONS

Field operations for ambient monitoring are performed by staff who report to the 

Monitoring Supervisor. Staff are assigned to monitoring stations and are responsible for 

all criteria pollutant operations at their respective stations. One Senior Technician is 

assigned the responsibility for calibration of field standards for gaseous pollutants and 

flow. 

As part of this TSA, Monitoring Technicians were interviewed about their duties 

related to monitoring station operation. All station operators interviewed demonstrated a 

thorough knowledge of the monitoring equipment for which they were responsible. 

The Field Sites reviewed included Apex, Joe Neal, East Craig, and East Sahara. 

EPA evaluation at these sites included inspection of the inlet manifolds, examination of 

station and instrument log books, and a specific check of whether appropriate Quality 

Control (QC) checks and Quality Assurance (QA) audits were being performed for dates 

in 2007 selected for review prior to the audit. Each of the eight sites visited were well 

organized and had clean sampling lines. Instrument logbooks were up to date and 

contained relevant information on operations and maintenance activities. Station 

logbooks are maintained electronically in the data acquisition system. All sites met the 

siting criteria of 40 CFR 58, Appendix E. 

Field Operations

Finding C1: 

EPA and DAQEM staff noted significant problems with the operations of the Tanabyte 

Engineering Calibrators. DAQEM staff also noted issues with the nitrogen dioxide 

instruments. 

Discussion: 

In order to maintain an effective and efficient monitoring system, problems with 

equipment should be identified and corrected promptly. If problems cannot be 

prevented from occurring, formal procedures should be established to minimize 

the impact of instrument deficiencies on day-to-day monitoring operations. These 

could include: 

• Changing the QC frequency of the given instrument. 

• Adding additional QC checks. 

• Having additional back-up instruments available. 

Recommendation: 

DAQEM should issue a formal corrective action plan to address potential 

equipment problems. For equipment with persistent or recurrent problems, the 

plan should call for the development of a replacement schedule. 

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Clark Co. TSA Report: September 2009 

Finding C2: 

DAQEM typically fits each probe line end with an 

unacceptable stainless steel mesh filter cap. 

Discussion: 

According to DAQEM staff, the stainless steel mesh filters are used to keep 

insects out of the probe lines. However, this material is inconsistent with the 

requirements of 40 CFR Part 58, Appendix E, Section 9, which states that 

borosilicate glass or Teflon are the “only acceptable probe materials” for reactive 

gasses (ozone, sulfur dioxide, and nitrogen dioxide). 

Recommendation: 

DAQEM must replace the stainless steel mesh caps with an equivalent Teflon 

mesh cap. 

Finding C3: 

DAQEM has identified upgrades that need to be made to many of the monitoring 

stations, some of which have safety implications. 

Discussion: 

DAQEM has developed a list of “Site Conditions & Safety Upgrades.” Items on 

the list are specific to physical condition, aesthetics, and unsafe conditions; they 

do not include information about any needed equipment and instrument upgrades. 

While these items do not directly relate to monitoring, they have the potential to 

impact the monitoring program if they are not addressed. 

Recommendation: 

DAQEM should develop a target schedule for site upgrades. 

 

Finding C4: 

DAQEM lacks a consistent method for documenting activities and required duties 

performed at each site. There is variability in documentation based on the site location 

and the site operator. 

Discussion: 

The level of detail in the logbooks varies with the station operator. DAQEM 

currently utilizes two different methods for documenting field and equipment 

operation. An “equipment logbook” is used to document calibrations, problems 

associated with the instrument, and repairs. This log book is kept with the 

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Clark Co. TSA Report: September 2009 

instrument (e.g. the logbook follows the instrument from site to site). The “station 

logbook” is maintained in the LEADS system and does not have a formal 

structure (see finding A3). 

Recommendation: 

DAQEM should establish a standardized method for documenting field 

operations. 

Finding C5: 

DAQEM does not document the quality of zero air used in the program. 

Discussion: 

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

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

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

as a standard. As such, zero air scrubbers should be verified after maintenance 

and this verification must be documented. 

Recommendation: 

DAQEM should document the performance verification of zero air scrubbers. 

Finding C6: 

DAQEM has inadequate procedures for scheduling and documenting preventive 

maintenance for the gaseous and PM instruments. 

Discussion: 

Preventive maintenance is a key component in the successful operation of air 

monitoring equipment. These procedures help to increase the lifetime of 

instruments and ensure they continue to operate efficiently and correctly. The 

preventive maintenance schedules are currently loosely kept within the 

“equipment logbook.” Some site operators keep them in different locations. 

The current form of documentation is incomplete and inconsistent. There is no 

place on the schedule to indicate who has performed the operation and whether or 

not the required maintenance is being checked by the QA officer or the 

monitoring manager. 

Recommendation: 

DAQEM should reevaluate the structure of the preventive maintenance schedule 

to address inconsistent and incomplete documentation. These documents should 

be kept in a common location to ensure they are not misplaced or lost. 

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Clark Co. TSA Report: September 2009 

D. LABORATORY OPERATIONS

DAQEM has a PM2.5 laboratory located in the basement of the main County 

Office Building Complex. The primary responsibility of the laboratory is the 

handling of PM filters, which includes preparation, weighing, tracking, and storage. 

The PM2.5 laboratory is well run and organized. It was noted that the 

laboratory relies on manual data collection methods for the recording of laboratory 

conditions and filter weighing sessions. This process is acceptable. However, it is 

recommended that DAQEM evaluate the cost/benefit of automating the laboratory 

processes. If filter weighing sessions were automated, less hand written 

documentation would be required and the analyst and data validator would not need 

to evaluate the manually entered data for transcription errors. This would have the 

potential to substantially increase laboratory productivity and data quality.

Laboratory

Finding D1: 

The times that filters are weighed and the time that filter conditioning begins are not 

documented. 

Discussion: 

Pursuant to 40 CFR Part 50, Appendix L, Section 8.2, PM2.5 filters must be 

conditioned for a minimum of 24 hours prior to weighing. In order to document 

that filters have been conditioned appropriately, sample weighing time and the 

conditioning start time must be documented. 

Recommendation: 

DAQEM should record the times that filter batches begin conditioning and the 

times that individual filters are weighed. 

Finding D2: 

The temperature and humidity of the weigh-room occasionally fluctuate outside of the 

acceptable control limits. 

Discussion: 

It was noted that the laboratory temperature and humidity occasionally violate the 

control limits established in 40 CFR Part 50, Appendix L, Section 8.2. The 

analyst indicated that the average temperature and humidity over 24 hours is 

evaluated when excursions are noted. While EPA recognizes that the temperature 

and humidity may fluctuate at times, such as when the air handling system cycles 

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Clark Co. TSA Report: September 2009 

or when individuals enter and exit the conditioning environment, the regulatory 

criteria for the laboratory environment are not based on a daily average. 

Recommendation: 

DAQEM should identify and address the causes of unacceptable temperature and 

humidity fluctuations in the weigh-room. In the absence of other corrective 

measures, laboratory staff should wait until conditions in the room re-stabilize 

before proceeding. 

Finding D3: 

The dates that filters are received from EPA, and the dates that exposed filters are 

disposed of are not tracked. 

Discussion: 

Sampling media and filters should be tracked through the laboratory. 

Recommendation: 

DAQEM should develop a procedure to track the dates of new filter receipt and 

exposed filter disposal. 

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Clark Co. TSA Report: September 2009 

E. DATA MANAGEMENT

 DAQEM has defined procedures in place for handling data from the time of 

acquisition to the time that it is submitted to EPA. The procedures are well known to the 

principal data providers and reviewers. The Air Monitoring Group is responsible for 

managing ambient monitoring data and reporting to the EPA AQS database. 

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

stored in data loggers and on DAQEM servers. Each station is polled every fifteen 

minutes and the data are transmitted directly to the central server in the IT facility. The 

first review of the data is performed by the station operators. 

 Data from continuous analyzers are received and processed using an IPS 

MeteoStar data management system that began operations 2008. The system provides 

real-time, as well as historical, data on the DAQEM internet portal. Several of the 

monitoring staff are involved in evaluating/validating the gaseous measurement and 

quality control data provided by the LEADS Electronic Management System (EMS). 

The LEADS EMS prepares the validated data for submittal to the AQS system. 

 DAQEM laboratory-generated data includes 24-hour PM2.5 data. Laboratorygenerated data are processed using spread-sheets and validated and submitted separately 

to AQS from the LEADS EMS. 

 

 DAQEM submits all required data to the AQS database, including concentrations 

for all criteria pollutants, supporting precision and accuracy information and data from 

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

 Please refer to items 3 and 4 in Section A for a discussion of data management 

findings. 

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Clark Co. TSA Report: September 2009 

F. QUALITY MANAGEMENT

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

minimal requirements for quality assurance for Primary Quality Assurance Organizations 

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

quality management, and cooperation with performance and technical audits by EPA. 

EPA views the application of quality management systems as integral to monitoring 

programs. Insufficient quality management and control has been cited a as rationale for 

legal challenges to NAAQS redesignation decisions. 

DAQEM has a defined quality management system, which includes a quality 

management plan and oversight by an independent quality assurance officer/auditor. 

While some QA issues are formally raised with the Engineering Manager, many formal 

QA oversight and review functions are either not performed or are performed informally 

with minimal or no documentation. EPA recognizes that the QA Officer’s role has 

recently been elevated and DAQEM is developing a more formal and comprehensive role 

for the QA Officer. 

EPA regulations require independent performance audits of gaseous pollutants 

and flow audits of PM2.5, and PM10 and monitors. For gaseous pollutants, the current 

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

calendar quarter so that each instrument is audited once per year. Prior to 2007, flow 

audits of these monitors were also required. Additionally, quarterly independent flow 

audits of PM2.5 samplers were required. Beginning in calendar year 2007, semi-annual 

flow audits of each PM2.5, PM10, and TSP sampler are required (40 CFR, Part 58, 

Appendix A, Sections 3.2.4 and 3.3.3.) This is in addition to the required monthly flow 

evaluations (40 CFR, Part 58, Appendix A, Sections 3.2.3 and 3.3.2.). 

The Quality Assurance Officer is responsible for conducting the required gaseous 

pollutant audits and PM10 and PM2.5 flow audits. Audits are performed at the minimum 

frequency or more for all pollutants. The auditor provides audit results to site operators, 

but does not use audit data to perform statistical analyses or develop control charts. 

DAQEM does not have an audit program for meteorological equipment, but plans to 

institute one in the near future. EPA recommends that a meteorological audit program be 

instituted prior to bringing the NCore site online. 

Quality Assurance and Quality Control

Finding F1: 

The DAQEM QA Auditor does not formally communicate failing audit results to the data 

managers/validators. 

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Clark Co. TSA Report: September 2009 

Discussion: 

The results of the required QA audits of gaseous and particulate monitors are not 

transmitted so that they can be responded to formally by the site Monitoring 

Technicians and the Monitoring Supervisor and evaluated during the data 

validation process. The audit results should be transmitted to the data validator 

and other staff formally, using the LEADS EMS or another formal process 

developed by the QA Officer. 

Recommendation: 

DAQEM should develop a formal process for the auditor to inform the data 

management group of failing audits, as this can be incorporated into data 

validation decisions. 

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Clark Co. TSA Report: September 2009 

APPENDIX A: Summary of Findings 

Significant Findings 

FINDING A1:

DAQEM’s Quality Assurance program may lack sufficient management and should have 

a more formal and independent role in the oversight of the monitoring program. 

FINDING A2:

The Quality Management Plan (QMP) and Quality Assurance Project Plans (QAPPs) 

need additional information to meet EPA requirements. 

FINDING A3:

The consistency of records generated and maintained in the LEADS Electronic 

Management System (EMS) is inadequate. Inconsistencies in the generation and 

retention of other records may also exist. 

FINDING A4:

Procedures for submitting data to the EPA Air Quality System (AQS), flagging data 

within AQS, and reporting data to the public need to be improved.

FINDING A5:

DAQEM lacks an adequate system for tracking equipment status, initiating equipment 

repairs, and documenting repair history. 

Other Findings 

Finding B1: 

DAQEM lacks the necessary flexibility to establish new monitoring stations in response 

to changing conditions. 

Finding B2: 

DAQEM is working to resolve the status of its formal application for a PM2.5 Approved 

Regional Method (ARM) for the continuous monitors. 

Finding C1: 

EPA and DAQEM staff noted significant problems with the operations of the Tanabyte 

Engineering Calibrators. DAQEM staff also noted issues with the nitrogen dioxide 

instruments. 

Finding C2: 

DAQEM typically fits each probe line end with an unacceptable stainless steel mesh filter 

cap. 

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Clark Co. TSA Report: September 2009 

Finding C3: 

DAQEM has identified upgrades that need to be made to many of the monitoring 

stations, some of which have safety implications. 

Finding C4: 

DAQEM lacks a consistent method for documenting activities and required duties 

performed at each site. There is variability in documentation based on the site location 

and the site operator. 

Finding C5: 

DAQEM does not document the quality of zero air used in the program. 

Finding C6: 

DAQEM has inadequate procedures for scheduling and documenting preventive 

maintenance for the gaseous and PM instruments. 

Finding D1: 

The times that filters are weighed and the time that filter conditioning begins are not 

documented. 

Finding D2: 

The laboratory does not have criteria for evaluating short-term excursions of weigh-room 

temperature and humidity outside of the control limits. 

Finding D3: 

The dates that filters are received from EPA, and the dates that exposed filters are 

disposed of are not tracked. 

Finding F1: 

The DAQEM QA Auditor does not formally communicate failing audit results to the data 

managers/validators. 

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Clark Co. TSA Report: September 2009 

APPENDIX B: QMP and QAPP Comments 

All Documents 

1) [Distribution List] These documents should include a distribution list. 

Quality Management Plan 

2) [Quality Policy] The QMP should include a Quality Policy for the organization 

that clearly and concisely states the importance of QA/QC to the organization, the 

QA goals of the organization, and the commitment to allocate and prioritize 

resources for QA/QC activities. 

3) [Authority] The QMP should discuss how DAQEM derives its authority from the 

EPA, the State of Nevada, and Clark County to provide air monitoring to support 

the NAAQS. 

4) [Additional Sections] This document should include sections that discuss 

Planning and Assessment & Response. 

5) [Section 2, User] This section refers to EPA’s “Quality Management Plan 

requirement.” EPA recommends that the plan discuss the specific regulatory 

requirements. Note that EPA requires organizations it funds which use or collect 

environmental information to have a Quality Management System (40 CFR Part 

30, 31, and 35). EPA also requires that data collected for NAAQS decision 

making must be performed under a Quality Management System that conforms to 

EPA requirements and guidance for Quality Management (EPA QA/R-2) (40 

CFR Part 58, Appendix A). 

6) [Section 3, User Requirements] This section should discuss the requirements in 

40 CFR Part 58, Appendix A, Section 2 to: develop QA planning documents; 

provide independent Quality Assurance; use data quality objectives or another 

systematic planning process; provide for and submit to independent system and 

performance audits; and follow all relevant EPA requirements and guidance. 

7) [Section 4.2, Organization] The QMP should provide the entire organizational 

chart for DAQEM in addition to the chart provided for the Engineering Division. 

8) [Section 4.2, Organization; Section 4.3, Responsibilities] These sections should 

discuss the responsibilities of organizational groups that are important to DAQEM 

air monitoring efforts such as EPA, the State of Nevada, and the DAQEM 

Engineering Division. Additionally, the responsibilities of the senior DAQEM 

managers for the Quality System should be discussed (i.e., who authorizes the 

QA/QC system, provides resources, and reviews QA summaries). 

9) [Section 4.4, Training] This section should be expanded to describe personnel 

qualifications associated with key QA positions or responsibilities. The present 

discussion does not explain why monitoring technicians are in the Engineering 

Division. A reference is made to a training plan, but no detailed information 

about the training program is provided.. 

10) [Sections 5, User Requirements Reconciliation (Quality Control); Section 6, User 

Reconciliation Assurance (Quality Assurance)] These sections should include a 

discussion of policy. Such issues as the minimum requirements for quality 

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Clark Co. TSA Report: September 2009 

control and quality assurance, and their authority should be discussed. The DQO 

process and systematic planning should be explained. Note that DQOs for criteria 

pollutant NAAQS monitoring are developed by EPA. Other monitoring 

objectives should be evaluated by DAQEM to determine if they require additional 

QA/QC measures or more stringent criteria, as compared to relevant federal 

regulations. These sections should expand on the different documents and what 

their role is in defining the DAQEM air monitoring quality system. 

11) [Section 7, Dispute Resolution] This section discusses the QA Manager’s 

responsibilities with respect to corrective action requests (CARs) without first 

describing the process associated with them. The discussion should be expanded 

to include a description of the overall corrective action system. A discussion of 

what triggers a CAR, what paperwork is generated and how is it tracked should be 

included. 

13)

12) [Section 8, Recording and Documentation] This section should define how 

custody of the documentation, in both hard copy and electronic form, will be 

tracked and it should discuss how documents are made accessible to all staff. 

The section also should contain provisions for retaining copies of some 

documents, such as SOPs, for historical purposes in case there is a need to track 

how data were generated. Some of the terms in the accompanying table are not 

well defined (i.e., “keeper,” “access,” “medium,” “retention,” and “disposition”). 

The section does not provide information on documentation requirements for 

routine activities. At a minimum, the QMP should indicate where these 

documentation requirements can be found, for example in SOPs or a QA Project 

Plan. 

[Section 10.1.1, Purchasing and Procurement; Section 10.1.2, Subcontracting] 

These sections should discuss the quality assurance measures that will be taken to 

assure goods and services are of acceptable quality and that problems with such 

goods and services will be corrected. 

14) [Section 10.2, Electronic Data Handling Systems] These sections should discuss 

the policies and/or procedures for validation and monitoring of the quality of data 

from these systems. 

Quality Assurance Project Plans (QAPPs) 

15) [Additional Sections] The following sections should be specifically included in 

each QAPP: 

a. Project description and background 

b. Sampling design (i.e., probe design and residence time) 

c. Quality control checks 

d. Instrument inspection and maintenance, instrument calibration 

e. Inspection of supplies 

f. Assessment and response (including internal and EPA technical and 

performance assessments), reports to management, data review and 

validation, and reconciliation with user requirements 

16) [Section 4.1, Organization] This section should include a discussion of external 

organizations that support this monitoring program. 

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Clark Co. TSA Report: September 2009 

28

17) [Section 5, User Requirements Reconciliation] This section should include a 

discussion of the EPA’s DQO for Ozone and PM2.5 monitoring. Additionally, 

any non-NAAQS specific data uses should be evaluated to determine if they have 

monitoring or data quality objectives that are more stringent than those prescribed 

by regulation. 

18) [Table 5, Ozone Measurement Quality Objectives (MQOs) and Measurement 

Quality Indicators (MQIs) by Sampling Site] The MQOs and MQIs for ozone 

should be updated to reflect the 7% DQO for ozone monitoring. 

19) [QAPP, Appendix Equipment] This appendix discusses various standards and 

certifications of these standards, but does not include criteria for evaluation of 

standards. 

20) [SOPs, Standards] All supporting standards and calibration and verification of 

these standards should be included the QAPP and/or the attached SOPs. 

21) [SOPs, Criteria] Many of the required tasks discussed in the SOPs do not include 

acceptance criteria. 

22) [SOPs, Ozone Standard] The procedure and criteria for certification of ozone 

primary and transfer standards is not included in the SOPs. 

23) [SOPs, Zero Air] The equipment used for generation of zero air is not specified 

in the SOPs.