## Technical System Audit Report

Arizona Department of Environmental Quality Air Quality Division Ambient Air Quality Monitoring Program

September 28

– October 1, 2009

Conducted by

Air Quality Analysis Office Quality Assurance Office

Air Divi sion Management and Technical

Services Division

US EPA Region 9

75 Hawthorne Street San Francisco, California 94105

September 20 10ADEQ TSA Report: September 2010

2 C ONTENTS

GLOSSARY OF ACRONYM S

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

EXECUTIVE SUMMARY

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

INTRODUCTION

................................ ................................ ................................ .............. 6

A. GENERAL PROGRAM

................................ ................................ ................................ 8

B. NETWORK MANAGEMENT

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

C. FIELD OPERATIONS

................................ ................................ ................................ . 16

D. LABORATORY OPERAT IONS

................................ ................................ ................ 21

E. DATA MANAGEMENT

................................ ................................ ............................. 24 F. QUALITY MANAGEMENT

................................ ................................ ....................... 27

APPENDIX A: Summary of Findings

................................ ................................ .............. 29ADEQ TSA Report: September 2010

3 GLOSSARY OF ACRONYMS

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

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

AZ...

............................ State o f Arizona

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

O 3

.......................................... Ozone

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

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

PM 2.5

..................................... Particulate matter 2.5 mic rons or less in aerodynamic

diameter

PM 10

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

diameter PQAO................................... Primary Quality Assurance Organization QA.................................

....... Quality Assurance QC........................................ Quality Control QAPP................................... Quality Assurance Project Plan QMP............................ Quality Management Plan

SPM..................................... Special Purpose Mon itor

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

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

SO 2

....................................... Sulfur Dioxide

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

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

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

EPA

...................................... United States Environmental Protection AgencyADEQ TSA Report: September 2010

4

EXECUTIVE SUMMARY

This report document s the findings made by EPA Region 9 during its Technical System 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 prog ram 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 ADEQ monitoring organization r equired by 40 CFR Part 58, Appendix A, Section 2.5.

This TSA was conduct ed by EPA Region 9 staff from September 28

– October 1,

2009 . The audit team interviewed management and staff on specific aspects of the air monitoring program including network des ign, field operations, laboratory operations, data handling, quality assurance and quality control procedures. The audit team also inspected several monitoring sites and including the proposed NCore monitoring station.

The site inspections consisted of i nterview ing the site operator, reviewing station and instrument logbooks, and evaluating the station siting with respect to EPA requirements for probe siting 1

.

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

state and loc al 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 result s of th e TSA are summarized below and discussed in more detail i n the specific sections of this report

. Recommendation s for addressing each of the findings are

also provided . The specific actions taken by ADEQ to address the findings should be approved by EPA and documented by ADEQ in a corrective action plan.

EPA would like to thank all the staff and management of t he ADEQ Air Quality

Division for their support and cooperation during the audit.

Program Strengths:

ADEQ has conscientious, well qualified, knowledgeable

, and experienced staff.

The ADEQ data management program has very well organized documentation

use d to support data validation.

1 40 CFR, Part 58, Appendix E, “Probe and Monitoring Path Siting Criteria for Ambient Air Quality Monitoring”ADEQ TSA Report: September 2010

5 ADEQ staff has recently taken proactive steps to improve the quality of their

documentation and data collection activities.

ADEQ field technician ’ s entries into the monitoring station logbooks are detailed and easy to unders tand.

The ADEQ monitoring stations visited are well sited.

The ADEQ audit program routinely provides audits of monitoring sites operated by other agencies and facilities.

Program F indings:

Despite the strengths of ADEQ’s monitoring program and notable program improvement since the last TSA, EPA identified several program elements that need to be addressed. In general, ADEQ should:

Ensure that approved Quality Management Plan (QMP), Quality Assurance Plans (QAPPs), and Standard Operating Procedures ( SOPs) are developed and/or updated

.

Ensure that all required criteria pollutant data collected by facilities and/or other organizations uses adequate methods and QA/QC procedures and meet completeness requirements so that this data can be used to demonstr ate compliance as well as non

- compliance with the National Ambient Air Quality Standards (NAAQS).

Ensure that the worksheets and logbooks are present and appropriate to document all aspects of the data collection process.

Ensure that residence times fo r all instrument sampling lines/manifolds are calculated and meet EPA requirements.

Strengthen the involvement of the field technicians in the day

- to

- day station operational evaluation and data review process.

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.ADEQ TSA Report: September 2010

6

INTRODUCTION

ADEQ is the government agency with delegated authority an d responsibility for collecting ambient air quality data pursuant to the Clean Air Act of 1977 and the Clean

Air Act Amendments of 1990 in the State of Arizona.

From September 28 through October 1

, 2009, Michael Flagg of the Region 9 Air Quality Analys is Office and Matthew Plate of the Region 9 Quality Assurance Office conducted a Technical System Audit of ADEQ’s ambient air monitoring program. The TSA covered the following program areas:

General / Quality Management

o Program Organization

o Facilities

o In dependent 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 Mainte nance

o Laboratory Record Keeping

o Laboratory Data Acquisition and Handling

o Specific Pollutants: PM 10 , PM 2.5 , and Toxics Data and Data Management

o Data Handling

o Software Documentation

o Data Validation and Correction

o Data Processing

o Internal Reporting

o External R eportingADEQ TSA Report: September 2010

7

Additionally, EPA tracked supporting documentation for several data points/sets from calendar year 2008.

Participating ADEQ managers, supervisors and staff included :

Steven Peplau, Air Assessment Section Manager Bernard Lum, Air Monitoring U nit Manager Sandra Wardwell, Data Management and QA Unit Manager Ralph Lucero, Environmental Program Specialist (Filter

- Based PM)
John Olasin, Environmental Program Specialist (Lead Lab Technician) Cerresa Steward, Environmental Program Specialist (QA/QC L ead) Andy Cilfton, Environmental Health Specialist II (QA Auditor) Terry Taflinger, Environmental Program Specialist (Continuous) Bryan Paris, Environmental Program Specialist (Data Specialist) Jon Midgley, Environmental Program Specialist (Network/Data Re view) Heather Colson, Environmental Program Specialist (Database) Greg Kendall, Environmental Health Specialist II (Field Technician) Richard Montenegro, Environmental Health Specialist II (Field Tech.)

Warren Mason, Environmental Health Specialist II (Fie ld Tech.)

Mark Carrel , Information Technology Specialist III

This report is divided into nine 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 sectio n is an introduction that provides a brief description of the ADEQ air monitoring program, identifies participating ADEQ personnel and the EPA audit team, and describes the report’s organization. The third section discuss es the general/major 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 thi s report. Recommendations for each finding are provided to give some indication of the Region’s expectations as to how findings can be addressed. If the ADEQ has other approaches or alternatives to address the concerns identified, the Region will conside r them, provided the corrective action adequately addresses the finding.ADEQ TSA Report: September 2010

8

A. G ENERAL 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

req uirements 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 providing air monito ring data to ADEQ. ADEQ does not provide formal oversight of county air monitoring agencies, but does conduct performance audits of Pima and Pinal Counties as well as other monitoring networks in the State of Arizona (i.e., facility networks)

.

ADEQ curr ently operates or oversees 18 active monitoring stations for criteria pollutants. The pollutants measured include:

Carbon Monoxide
Nitrogen Dioxide

Sulfur Dioxide

Ozone

Particulate Matter (PM 10 and PM 2.5 )

ADEQ is organized into five divisions and two Regi onal Offices (Northern and Southern). The Air Quality Division was headed by a Director, Nancy Wrona who reports to the ADEQ Director, Benjamin H. Grumbles. Eric Massey is the current Air

Division Director. The Air Quality Division is divided into five se ctions, Air Assessment, Planning, Permits, Compliance, and Vehicle Emissions. Ambient Air monitoring is the responsibility of the Air Quality Division’s Air Assessment Section with assistance from several staff in the Northern and Southern Regional Office s. The Air Assessment Section

was headed by a Manager, Steven E. Peplau, and is divided into four units, Data Management and Quality Assurance, Monitoring, Evaluation, and Special Applications. Theresa Rigney is the current Air Assessment Manager. The maj ority of air monitoring is conducted by the Monitoring Unit (with some assistance from the ADEQ Regional Offices) ; however the some projects are implemented by the Evaluations Unit.

Oversight of monitoring and laboratory activities is conducted by the QA/ QC Team, which resides in the Data Management and QA Unit. The Data Management and QA Unit is independent of air monitoring data collection activities.

FINDING A1:

ADEQ’s The Quality Management Plan (QMP) , Quality Assurance Project Plans (QAPPs), and St andard Operating Procedures (SOPs) need to be updated.

Discussion: All organizations conducting environmental programs funded by EPA are required to establish and implement a quality management system. In accordance

with 40 CFR Part s 31 and 35, grant re cipients are required to document theirADEQ TSA Report: September 2010

9 quality system s in a Quality Management Plan through EPA Order 5360.1 A2, Policy and Program Requirements for the Mandatory Agency

- wide Quality System (EPA 2000). Additionally, ambient air monitoring specific requir ements 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.

The EPA also requires that organizations de velop a QAPP for each type of ambient pollutant that is 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 environme ntal 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 how quality assurance and quality control 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 200 1, and “Guidance for Quality Assurance Project Plans,” EPA/240/R

- 02/009, December 2002.

ADEQ has an agency

- wide QMP that include s the Air Quality Division. This plan has been recently revised but has not been approved by EPA Region 9.

ADEQ was following a plan to develop and update QAPPs as a corrective action to the last EPA TSA of the Air Monitoring Program. This effort fell behind schedule and updates to air monitoring QAPPs are overdue to EPA. Updates to QAPPs and SOPs are critical due to recent an d upcoming changes to air monitoring requirements. The Air Assessment Section QA/QC Lead has identified dates for QAPPs to be update d . While this plan is appropriate it may be challenging to meet the dates identified

.

Recommendations:

1. Wo rk with the ADEQ QA manager to ensure that the ADEQ QMP is approved by EPA or develop a separate Ambient Air Monitoring QMP.

2. Evaluate QAPPs and SOPs in use to ensure that the procedures being used conform to current EPA requirements.

3. Work with EPA to track the schedule to update air monitoring QAPPs.

FINDING A2:

ADEQ needs to ensure that data collected for ADEQ, for NAAQS compliance, by other organizations meets siting, QA/QC, completeness, and independent oversight requirements.ADEQ TSA Report: September 2010

10 Discussion: ADEQ works with facilities and other organizations that collect data that used for comparison to the NAAQS. In review some of the existing data

, EPA is concerned that at least one of these organizations , Freeport McMo r an, may not be collecting data that can be use d for demonstration of NAAQS compliance. Additionally, the level of oversight and authority of ADEQ for this other monitoring may not be adequate to ensure that data can be used for NAAQS comparisons.

The Air Assessment Section has recently developed gui dance for the ADEQ permits program to help alleviate this concern for some facility monitoring. This document is a good summary of ambient air monitoring requirements. However, ADEQ needs to clarify how Primary Quality Assurance Organizations (PQAOs)

wil l be assigned to facility monitoring. In particular the guidance should address

the issue as to whether ADEQ or the facility will be the PQAO for NAAQS monitoring

. If ADEQ is named as the PQAO

, the Air Assessment Section must take a more active role in q uality management of the data produced by the facility. If the facility is the PQAO

, the guidance should resolve the following:

How will the required independent EPA performance and technical systems audits of the facility monitors be funded/conducted?

W ill the facility be allowed to enter into a larger PQAO with multiple

facilities in different states ?

What actions will be taken if data produced by the facility PQAO does not meet regulatory requirements or data quality objectives (DQOs) ?

Rec ommendation: ADEQ should assess data being collected and reported for NAAQS compliance in

the State of Arizona. If the dat a are required

, ADEQ should ensure that they are adequate to demonstrate compliance with the NAAQS. ADEQ should also identify data i n AQS that should not be compared to the NAAQS.

FINDING A3:

Appropriate logbooks and forms to document air monitoring and laboratory operations were not always available

.

Discussion: In general, documentation needs to demonstrate that data are of adequa te quality and any unusual circumstances are documented and explained. Documentation of the activities occurring at monitoring stations should be consistent throughout the network. Also, each site should contain a single logbook that documents all

activiti es that occurred at that site. Maintaining such logbooks will help to develop a comprehensive history of the s tation . This will aid field technicians to pinpoint and assess problems that may arise with the s tation

.ADEQ TSA Report: September 2010

11 All instruments operated within a partic ular monitoring site should have logbooks . These should be kept with the instrument and, at a minimum, include all repairs, calibrations, audits, or other maintenance p er formed. Currently, ADEQ does not have a standard system in place to ensure consistency of documentation. There is variability in the type of logbooks used at a number of sites and how they

are handled and maintained.

Recommendations:

1. Maintain station logbooks that document all activities at a particular monitoring location

2. Main tain instrument logbooks that document all issues pertaining to that specific instrument.

3. Develop a system for tracking logbooks to ensure all information about a particular station or instrument is easily accessible

4. Develop forms for field notes and docum entation of QC procedures

FINDING A4:

ADEQ has not calculated residence times for its reactive gas monitors and several sites may exceed the 20

- second residence time specified in regulation.

Discussion:

The 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 Section 9 states that for the reactive gases (Ozone, NO 2 , and

SO 2 ) residence times must be less than 20 seconds. Addit ionally, it is recommended that the residence time within the manifold and sample lines to the

instruments should be less than 10 seconds. The station technicians should calculate the residence time, document it in the station logbook, and periodically

v erify the data.

ADEQ monitoring stations are configured with individual 1⁄4 inch sampling lines

that run from each gaseous instrument to the probe inlet on the roof of the monitoring station. Most of the monitoring stations have line lengths of less than 6 meters between the instrument and the ambient air inlet point. However, if a volume of 13 milliliters (this varies based on the type of tubing used) is assumed for each meter of tubing, at a flow rate of 500 ml/min a 20 second residence time

would be e xceeded with 13 meters of tubing.

Recommendations:

1. Calculate residence times for all gaseous monitors.

2. Modify sites with residence times in excess of 20 seconds with a goal of 10 seconds and evaluate any impact on compliance data due to exces sive

residence times.ADEQ TSA Report: September 2010

12

FINDING A5:

The ADEQ Field Technicians are not sufficiently involved in the review of station operations. This has lead to increased instrument down

- time and error in the data validation process and subsequently data reported to A QS.

Discussion: Data review is an ongoing process that should be performed by the site operators. Reviewing calibration information, hourly data and applying flags is optimally done by the person working most closely to the measuring instrument. Current ly, 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 shoul d be participating in an initial review of monitoring data. A t present, a
staff member , who is a part of the data management unit, is solely responsible for reviewing daily data, identifying problems, placing initial flags, and communicating any data issue s to the monitoring unit. The monitoring unit receives an email if there are potential issues with the data. There is also verbal communication between the monitoring and data management staff if there are potential issues with the data. Because the field technicians have to rely on

information from the data management unit to identify problems, there is potential for delayed corrective action or miscommunication that could lead to data los s

. Improved interaction between the monitoring unit and the data man agement unit will help increase the collection of appropriate quality monitoring data and eliminate potential data invalidation.

Recommendations: Field operators should be performing Level I QA on data f or the monitoring

stations to which they are assigned on a day

- to

- day basis.ADEQ TSA Report: September 2010

13

B. NETWORK MANAGEMENT

The ADEQ network for state and local air monitoring stations (SLAMS) consists

of 18 stations. The following table summarizes the SLAMS air monitoring sites in

Arizona by the respective pollu tants monitored and the year monitoring began at the site.

SITE NAME (year established) POLLUTANT

CO SO 2 NO 2 O 3 PM 10 PM 2.5 PM 2.5 C ontinuous Ajo (1969) X

Alamo Lake (2005) X Bullhead City (1997) X Bethune Elementary School(2002) X

Douglas Red

Cross (1998) X X

Flagstaff Middle

School (1996) X X X

Hayden Old Jail (1969) X X Miami Ridgeline (1993) X X Nogales Post

Office (1980) X X X

Paul Spur Chemical

Lime Plant (1985) X

Payson Well Site (1991) X JLG Supersite (1993) X X X X X X X Prescott Valley (2003) X X Queen Valley(1998) X Rillito(1985) X

Tonto National Monument(1988) X

Yuma Supersite (2006) X

Yuma

Courthouse (2002) X X

Source: ADEQ 2009 Air Monitoring N etwork Plan

The Arizona 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 obj ectives, 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 moni toring 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 monitoringADEQ TSA Report: September 2010

14

objectives and data need s. The main purpose of the review is to to verify that the network 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 require s evidence of a public inspection process. ADEQ submits a monitoring network plan every year. The most recent submittal by ADEQ ( 200 9 ) contains all of the required information about the monitoring stations , 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 :

In various areas

, ADEQ r el ies on meteorological data from secondary sources that are not routinely eva luated.

Discussion: When evaluating monitoring data and performing forecasting ADEQ relies on data supplied by various sources. Th ese data are essential in certain areas when the State does not have a dense meteorological network. Anytime secondary dat a is used

, the quality of the data source and the appropriateness for the data use

should be assessed.

Recommendation: Evaluate the quality of secondary sources of meteorological data.

FINDING B2 :

ADEQ faces significant resource and logistical challe nges to establish new monitoring sites that will be required due to growth in AZ counties without monitoring programs and changes to EPA monitoring requirements for criteria pollutants.

Discussion: ADEQ’s core monitoring responsibilities cannot be delega ted to local monitoring organizations . The c ounties of Yuma, Santa C ruz, Cochise, Coconino, Yavapai,

and Mohave have or will have required monitoring in the near future, but do not have established local monitoring agencies. Although Phoenix is centrally

located within the s tate, establishing and maintaining monitors at these radially distributed remote locations poses logistical and fiscal challenges. Currently

, the existing ADEQ field stations located in some of these areas are visited less frequently b y qualified field technicians and auditors

.

Recommendation: ADEQ and EPA Region 9 should develop a long term plan to ensure that monitoring requirements can be efficiently met. This could involve continuing toADEQ TSA Report: September 2010

15 develop innovative approaches to monitoring station establishment and management and/or delegation to local authorities.

FINDING B3 :

ADEQ needs to have more direct ov ersight on monitors operated for source compliance that are being used for NAAQS comparison.

Discussion:

Source orientated monito rs, which are being used for NAAQS compliance are located at Miami Ridgeline, Miami Golf Course, and Hayden Maintenance Yard

and are currently being operated by contractors that are not part of the ADEQ monitoring program. The PM 10 and PM 2.5 instruments lo cated in Miami are operated by an independent contractor hired by Freeport McMoran. Similarly the

PM 10 instruments located in Hayden are operated by an independent contractor hired through EPA’s Superfund program.

Recommendation: If ADEQ wants to use dat a from these monitors for regulatory purposes, the monitoring program must provide more direct oversight with respect to the operation of the instruments to ensure that the data collected from these locations are consistent with data collected throughout t he ADEQ monitoring network.

F INDING B 4 :

ADEQ is required to establish source

- oriented lead ( Pb ) monitors for the copper smelters at both the Freeport McMoran smelter in Miami and the ASARCO smelter in Hayden by January 1 st , 2010.

Discussion : ADEQ need s to establish two new monitoring locations in Miami and Hayden at the expected maximum concentration site for Pb concentrations. EPA has procured funding to establish these two new Pb sites and will be working closely with ADEQ to assist in the siting, in stallation, and operation of the monitors to deploy the monitors as soon as possible.

Recommendation : Install TSP Pb monitors at the maximum concentration locations for the two

sources described above.ADEQ TSA Report: September 2010

16

C. FIELD OPERATIONS

Field operation s for ambient m onitoring are performed by technicians that report to the Air Monitoring Unit Manager, contractors that perform filter pick

- up, and staff from the Northern and Southern Regional Offices . For the purposes of this TSA

, only Monitoring Unit field technicians were interviewed. Staff are assigned to monitoring stations on a rotating basis to perform scheduled calibrations and checks. Repair and calibration of field standards is performed by Terry Taflinger

, Environmental Program Specialist. The Field Sites revi ewed included Bethune Elementary School, Hayden Old Jail, JLG Supersite (proposed NCORE), Miami Ridgeline, Miami Golf Course (facility operated), Queen Valley, South Phoenix (Toxics), and Tonto National Monument.

ADEQ criteria pollutant monitoring

statio ns a re housed in both trailers and fixed

structures. Gaseous monitors are maintained inside controlled environments. Each gaseous monitor samples through its own dedicated 1⁄4 inch line. Lines for multiple monitors are

collocated on the roof of each monit oring station.

Filter

- based PM instruments are generally roof mounted while continuous PM samplers are either

in roof

- mounted cabinets or inside the monitoring

stations.

EPA noted that there is a limited amount of support equipment for the field

technic ians at the monitoring stations. Most stations do not have dedicated computers or printers. E quip ping sites with these instruments promotes real

- time documentation and troubleshooting.

EPA evaluation at these sites included inspection of the probe lines, examination of station and instrument log books , and a specific check as to whether appropriate Q uality C ontrol (QC) checks and Quality Assurance ( QA ) audits were being performed

for dates in 200 8 selected for review prior to the audit. Each of the eight sites visited

were well organized and had clean sampling lines. I nstrument logbooks were up to date and contained relevant information on most operations and maintenance activities. All criteria pollutant sites evaluated met the siting criteria of 40 CFR 58, Appendix E

.

Field Operations

FINDING C1:

Ambient air monitoring training should be provided and verification of procedures used by the contract and Regional Office operators should be documented

.ADEQ TSA Report: September 2010

17 Discussion: Currently there is no formal doc umentation or procedure for the training of contracted operators.

Recommendation: Develop a formal procedure for training and oversight of operators.

FINDING C2:

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

sc reen.

Discussion:

The stainless steel is used to keep insects out of the probe lines. However, t his

material is inconsistent with the requirements of 40 CFR Part 58, Appendix E

Section 9

, which states that borosilicate glass and Teflon are the “only acc eptable probe materials” for reactive gasses ( o zone, s ulfur d ioxide, and n itrogen d ioxide).

Recommendation: ADEQ must replace the stainless steel mesh caps with equivalent Teflon mesh

cap s

.

FINDING C3:

Several of the zero air generators have not b een serviced in several years, according to tags on the instruments.

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 scrubber maintenance should be regularly

scheduled and zero air verification must be documented.

Recommendation:

Ensure that the zero air scrubbers are routinely maintained and verified.

FINDING C4:

Equipment management needs to be improved.

Discussion: The current system for managing equipment involves the use of Field Service Reports that are organized by site location. Though these reports are h elpful in documenting problems with instruments at a particular location, they lack specificADEQ TSA Report: September 2010

18 information about the instrument. There are other informal procedures in practice for identifying and correcting problems with the instruments that need to be impr oved. For example, red tags are placed on instruments that need repair and

green tags on instruments that are functioning correctly. Also, there seems to be limited documentation of equipment inventory.

Recommendation:

1. Develop standard operating procedure s for equipment repair.

2. Develop documentation that details the repairs done on specific instruments. These records should be organized by instrument to ensure a complete history of that instrument is documented and easily accessible.

3. Develop an equipment i nventory

. 4. Develop an equipment replacement plan

.

FINDING C5:

There is a eucalyptus tree that partially obstructs the South Phoenix site approximately 5

to 10 meters southeast from the inlet of the Toxics monitor.

Discussion: The 40 CFR Part 58, Appendi x E, Section 5 states “ t rees can provide surfaces for SO2, O3, NO2 adsorption or reactions, and surfaces for particle deposition . . . t o reduce this possible interference/obstruction, the probe, inlet, or at least 90 percent of the monitoring path must be at least 10 meters from the drip line of trees.” Because the toxics inlet is on the southeast corner of the monitoring trailer the tree is a significant obstruction to the toxics monitoring but is far enough away and small enough so as not to provide an obstruction to the County’s manifold

inlet.

Recommendation:

Trim the tree and / or tap the toxics inlet line directly from the Maricopa County’s

manifold

.

FINDING C6:

The equipment used for non

- NATTS toxics monitoring and PAMS monitoring is not regularl y certified. Additional ly

, field certifications or verifications of the entire sampling system including the 1/8 inch stainless steel probe lines used for all toxics and

PAMS samplers should be performed.

Discussion: Canister and cartridge sampling syste ms should be certified and verified “non

biasing” initially and on a regular basis. These certifications and verifications should control for contamination introduced from the sampling system, losses from the sampling system (absorption and reaction), and dilution andADEQ TSA Report: September 2010

19 concentration effects from the sampling system. These checks are routinely performed by running blanks and blank spikes through these systems.

ADEQ does have the systems used for NATTS routinely certified by ERT. However, other sampling syst ems have not been certified recently. ADEQ does not perform certifications, verifications, and/or audits of the sampling systems as they are used in the field

, which include a 1/8 steel sampling lines a nd other supporting equipment. Various methods are av ailable to perform field

certifications

, such as introduction of blank or spiked air through the probe inlets and collocated sampling directly into evacuated canisters.

Recommendation:

D evelop a system that ensures that all toxics and PAMS sampling equipm ent are certified on a regular basis

.

FINDING C7:

The documentation provided to ADEQ by ERT that supports monitoring of NATTS, PAMS, and other toxics is not sufficient

.

Discussion: A brief review of the documentation provided by ERT yielded several sig nificant deficiencies including:

The NATTS equipment certifications are not properly maintained and do

not include formal certificates. The media custody forms do not include sufficient information. Media expiration dates are not provided.

In general, t h e documentation practices of the ERT laboratory should be evaluated routinely

.

Recommendation: EPA OAQPS, Region 9, and ADEQ should work together to ensure that ERT’s documentation practices are fully evaluated.

FINDING C8:

Field technician site resp onsibilities are subject to change on a monthly schedule.

Discussion: Field technicians have monthly meeting s to decide which sites are going to be visited by whom. While it is beneficial for technicians to have experience with multiple site locations, n ot assigning a site to a particular technician increase s the potential for error in data collection. Given the differences in documentation andADEQ TSA Report: September 2010

20 the lack of consistency with logbook procedures, changing site responsibilities on a frequent basis may not be p romoting quality data collection.

Recommendation:

Field technicians should have at least one site for which they are primarily responsible.ADEQ TSA Report: September 2010

21

D. LABORATORY OPERATIONS

ADEQ has a PM l aboratory located at its main offices. The primary responsibility of the laboratory is the handling of PM filters

, which includes preparation,

wei ghing, tracking, and storage

. ADEQ also has programs for laboratory analysis of toxics and PAMS compounds. Laboratory support for the toxics and PAMS programs is currently prov ided by the Eastern Research Group, Inc. (ERG) and was not reviewed as part of this TSA.

The PM 2.5 l aboratory is well run and organized. ADEQ utilizes an automated balance, which enables the laboratory to collect multiple weights for each filter,

incre asing the accuracy of the data reported. As noted in Finding A6

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

data.

Laboratory

FINDING D1:

The laboratory data handling and processing system is ine fficient and includes several unnecessary steps which increase the likelihood of human error.

Discussion: The data handling system found to be inadequate during the previous TSA of ADEQ is still essentially unchanged . However, the verification process ha s been improved and no data errors w ere found to have been reported to AQS

, as was noted during the previous TSA.

The current data handling process involves four steps, collection and initial processing using the analytical balance’s data system, transcri ption 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. Optimally the data system used should be configured for electronic processing and transfer

.

Recommendation: ADEQ should evaluate methods to improve the efficiency and integrity of the laboratory data processing system for particulate monitoring.

FINDING D2 :

Th e laboratory does not use blank controls for PM 10 weighing sessions

.

Discussion : Blank controls are used to determine the potential for filter contamination and to evaluate consistency of the balance over the filter handling period. Additionally, blanks are required in regulation as a mechanism for evaluating filter media, seeADEQ TSA Report: September 2010

22 40 CF R Part 50, Appendix J, Section 7.2.3, and EPA Compendium Method IO

3.1 notes in Section 5.4, “Provide one blank sample with every 10 actual samples.”

Recommendation: ADEQ should include blank filters as part of each weighing batch

.

FINDING D3 :

Lot blank evaluations for PM 2.5 are not being performed.

Discussion: ADEQ indicated that laboratory blanks are tracked and changed on a quarterly basis. In addition to these blanks each filter lot should be evaluated for stability. Please see USEPA Method 2.12, Section 7.7.

Recommendation:

Perform laboratory lot blank evaluation

.

FINDING D4 :

There is no logbook to document conditions and activities in the weigh

- room.

Discussion: ADEQ has documentation that supports most aspects of the filter weighing

proces s. However, there i s no place to document routine events, exceptional events, problems

, repairs to the weighing environment, and visitors to the weigh

room.

Recommendation:

Provide a logbook in the weigh

- room

.

FINDING D5 :

ADEQ is using 4 o C as the crite ria for invalidating filters based on temp erature rather than

average ambient temp erature

.

Discussion: 40CFR Part 50, Appendix L, Section 8.3 was modified in December 2006 to change the required post sampling temperature for weighing conducted from 10

- t o 30

- day post sampling from 4 o C to “maintained at temperatures below the average ambient temperature during sampling (or 4 °C or below for average sampling temperatures less than 4 °C).” ADEQ is still using 4 o C

, which results in unnecessary invalidation of data.ADEQ TSA Report: September 2010

23 Recommendation: ADEQ should change its invalidation criteria to match the regulatory requirement.ADEQ TSA Report: September 2010

24

E. D ATA MANAGEMENT

Data management is handled by the Data Management and Quality Assurance Unit, with the exception of some data management performed by the PM laboratory. The data management staff persons are well versed in the procedures for validation and management of data. However, as noted in Finding A5

, the Field Services Unit personnel are not involved or fully aware of the data val idation and management process.

Air quality data measured by the continuous analyzers at the field stations are transferred to the ADEQ server(s) on a regular basis. Data is reviewed daily to weekly by Mark Carrel in the Data Management Unit. Data from the PM laboratory is regularly provided in Excel format to a Database Specialist to input into the database and perform

validation.

Field data sheets are organized and assembled by site and used by the d ata

v alidators during the validation process. This system is well organized and the validation process, while not well documented, was easy to reproduce. After final validation

, data

are uploaded from the ADEQ database to the AQS system.

Note that during the previous EPA TSA

, several concerns regarding documentation of the data management system and data validation process were raised

. T he Air Monitoring QA Lead should independently confirm that these were adequately

addressed.

Data Management

FINDING E1:

During the data validation process, the vali dators do not use information provided in station, instrument, and other logbook s

.

Discussion: Logbooks provide critical information that should feed into validator decisions as to how to validate and/or flag data sets. Logbooks are generally not referr ed to during the data validation process and

, since Field Technicians do not review data validation decisions against their notes in these logs

, errors are made during the validation process. EPA note d that this had occurred for several of the data points

that were tracked.

Recommendation: ADEQ should include copies of the station logbooks with the documentation packages for each monitoring station

. If questions arise during the data validation

process
, data validators should obtain copies of other logbo oks as needed.ADEQ TSA Report: September 2010

25

FINDING E2:

The validation process does not include a review of systematic concerns

.

Discussion: EPA recommends validating data using critical, operational, and systematic criteria. Critical criteria must be met for data to be repor ted as valid to AQS. Operational criteria failures indicate that data may need to be invalidated or flagged. Fa ilures of systematic criteria indicate that the monitoring system needs to be evaluated. Consistent failures of any of these criteria may caus e entire data sets to be suspect.

The ADEQ validators evaluate individual data point s for many critical and operational criteria. However, validation does not consider systematic criteria or the adequacy of the data sets based on these criteria.

Reco mmendation: Implement a validation process that considers overall QA/QC performance. This could be done either by the current data validators or as part of the QA/QC Lead’s

data review.

FINDING E3:

The data validation process is not well documented

.

Di scussion: The data validators document that data validation has been completed in the ADEQ data base. However, this process does not provide sufficient information

as to why specific data validation decisions were made.

Recommendation:

Provide for a dat a validation signoff and comments. This could either be done on

the existing form, in the database, or on a data validation check

- sheet.

FINDIND E4:

ADEQ should develop a procedure for documentation and approval of changes in AQS

.

Discussion: Changes to the values or validity of criteria pollutant data in AQS can significantly impact decisions made by ADEQ and EPA. These changes should be justified, documented, and approved by the Air Assessment Section managers.ADEQ TSA Report: September 2010

26 Recommendation: Develop a procedure for approval and documentation of changes to AQS.ADEQ TSA Report: September 2010

27

F. Q UALITY 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 ADE Q . These requirements include quality planning, independent

qu ality management, and cooperation with performance and technical audits by EPA. EPA views the application of quality management systems as integral to monitoring programs. Insufficient qualit y management and control has been cited a as rationale for legal challenges to NAAQS redesignation decisions.

ADEQ has a defined quality management system, which includes a Departmental quality management plan and oversight by an independent ADEQ Quality A ssurance Manager

. The Air Assessment Section has an independent QA/QC lead that reports to the Data Management and Quality Assurance Unit Manager as well as to the ADEQ QA Manager. With the exception of meteorological data from non

- ADEQ monitoring site s,

t he Data Management and QA Unit does not generate any data

. Therefore, QA and data

collection activities are appropriately independent from each other. The QA/QC Lead and Auditor also have a good working relationship with the field and laboratory staff . The QA/QC Lead and Auditor have performed training

, conducted internal audits of some aspects of the monitoring operation , and prepared formal QA/QC summary reports

. However, the ADEQ QA Manager has not perform ed a recent review of quality management b y the Air Assessment Section.

EPA regulation s require independent performance audits of gaseous pollutants

and flow audits of PM 2.5

, and PM 10 and monitors. For gaseous pollutants

, the current regulation requires that 25% of each pollutant monitoring netw ork be audited per calendar quarter so that each instrument is audited once per year. Beginning in calendar year 2007

, semi

- annual flow audits of each PM 2.5 , PM 10 , and TSP sampler are required (40 CFR, Part 58, Appendix A, Sections 3.2.4 and 3.3.3.) This is in add ition to the

req uired monthly flow evaluations (40 CFR, Part 58, Appendix A, Sections 3.2.3 and 3.3.2.)

.

The Quality Assurance Auditor is responsible for conducting the required gaseous pollutant audits and PM 10 and PM 2.5 flow audits. Audits ar e performed at the minimum frequency or more for all pollutants. Performance audits of monitors operated by other organizations and facilities in Arizona are also performed by the QA Auditor

. Due to

time constrain t s
, quality control of the Performance au dit program was not reviewed during this TSA.

Quality Assurance and Quality Control

F INDING F1:

Considering the expanded requirements for monitoring

, the performance audit and field station oversight requirement exceed what can reasonably be performed b y one auditor.ADEQ TSA Report: September 2010

28 Discussion: Considering the distance traveled, the number of audits conducted currently by the QA/ QC auditor each year constitutes a very heavy workload. Additionally, the QA/QC auditor should be involved in a more through statistical in terpretation and evaluation of the data generated from these audits.

In the future ADEQ will need to develop additional audit programs including: A formal audit program for meteorology and other required NCORE

parameters An audit program for Pb An audit p rogram that ensures data collected by facilities for NAAQS compliance meets EPA requirements

Recommendation: ADEQ should develop a staffing plan that ensures that audit tasks will be adequately covered.ADEQ TSA Report: September 2010

29

APPENDIX A: Summary of Findings

Significant Findin gs

FINDING A1: ADEQ’s The Quality Management Plan (QMP) , Quality Assurance Project Plans (QAPPs), and Standard Operating Procedures (SOPs) need to be updated.

FINDING A2: ADEQ may not be able to ensure that data collected for ADEQ for NAAQS compliance

b y other organizations meet siting, QA/QC, completeness, and independent oversight requirements.

FINDING A3: Appropriate logbooks and forms to document air monitoring and laboratory operations were not always found to be present.

FINDING A4: ADEQ has not calculated residence times for its reactive gas monitors and several sites may exceed the 20

- second residence time specified in regulation.

FINDING A5: The ADEQ Field Technicians are not sufficiently involved in the review of station operations. This has lead to increased instrument down

- time and error in the data validation process and reporting to AQS.

Other Findings

FINDING B1 : In various areas

, ADEQ relies on meteorological data from secondary sources that are not routinely evaluated.

FINDING B 2 : ADEQ faces significant resource and logistical challenges to establish new monitoring sites that will be required due to growth in AZ counties without monitoring programs and EPA changes to monitoring requirements for criteria pollutants.

FINDING B3 : A DEQ should have more direct oversight on monitors operated for source compliance

that are also being used for NAAQS comparison.

FINDING B4: ADEQ is required to establish source

- oriented Pb monitors for the copper smelters at both the Freeport McMoran smel ter in Miami and the ASARCO smelter in Hayden by January 1 st , 2010.ADEQ TSA Report: September 2010

30

FINDING C1: Training should be provided and verification of procedures used by the contract and Regional Office operators should be documented.

FINDING C2: ADEQ typically fits each prob e line end with an unacceptable stainless steel mesh filter

screen.

FINDING C3: Several of the zero air generators have not been serviced in several years, according to tags on the instruments.

FINDING C4: Equipment management needs to be improved.

FI NDING C5: There is a eucalyptus tree that partially obstructs the South Phoenix site approximately 5

to 10 meters southeast from the inlet of the Toxics monitor.

FINDING C6: The equipment used for non

- NATTS toxics monitoring and PAMS monitoring is not

reg ularly certified. Additionally, field certifications or verifications of the entire sampling system including the 1/8 inch stainless steel probe lines used for all toxics and PAMS samplers should be performed.

FINDING C7: The documentation provided to AD EQ by ERT that supports monitoring of NATTS, PAMS, and other toxics, is not sufficient

.

FINDING C8: Field technician site responsibilities are subject to change on a monthly schedule.

FINDING D1: The laboratory data handling and processing system is inef ficient and includes several unnecessary steps which increase the likelihood of human error.

FINDING D2: The laboratory does not use blank controls for PM10 weighing sessions.

FINDING D3:

Lot blank evaluation for PM 2.5 is not being performed

.

FINDING D4 : There is no logbook to document conditions and activities in the weigh

- room.ADEQ TSA Report: September 2010

31

FINDING D5: ADEQ is using 4 o C as the criteria for invalidating filters based on temperature rather than average ambient temperature.

FINDING E1: During the data validation pr ocess
, the validators do not use information provided in station, instrument, and other logbooks.

FINDING E2: The validation process does not include a review of systematic concerns.

FINDING E3: The data validation process is not well documented.

FINDIN G E4: ADEQ should develop a procedure for documentation and approval of changes in AQS.

FINDING F1: Considering the expanded requirements for monitoring, the performance audit and field station oversight requirement exceed what can reasonably be performed by one auditor.