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 Division Management and Technical 

Services Division

US EPA Region 9

75 Hawthorne Street

San Francisco, California 94105

September 2010
ADEQ TSA Report: September 2010

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CONTENTS

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

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

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

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

B. NETWORK MANAGEMENT.................................................................................... 13

C. FIELD OPERATIONS................................................................................................. 16

D. LABORATORY OPERATIONS ................................................................................ 21

E. DATA MANAGEMENT............................................................................................. 24

F. QUALITY MANAGEMENT....................................................................................... 27

APPENDIX A: Summary of Findings.............................................................................. 29
ADEQ TSA Report: September 2010

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GLOSSARY OF ACRONYMS

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

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

AZ............................... State of 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

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

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

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

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

diameter

PM10...................................... 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 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
ADEQ TSA Report: September 2010

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EXECUTIVE SUMMARY

This report documents 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 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 ADEQ monitoring organization required by 40 CFR Part 58, 

Appendix A, Section 2.5.

This TSA was conducted 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 design, 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 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 

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 the 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 

used 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

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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 understand.

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 Findings:

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 demonstrate 

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 for 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

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INTRODUCTION

 ADEQ 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 in the State of Arizona. 

From September 28 through October 1, 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 ADEQ’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 Toxics

Data and Data Management

o Data Handling

o Software Documentation

o Data Validation and Correction

o Data Processing

o Internal Reporting

o External Reporting 
ADEQ TSA Report: September 2010

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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 Unit 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 Lead)

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 Review)

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 (Field 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 section 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 discusses 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 this 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 consider them, provided the corrective action adequately addresses the 

finding. 
ADEQ TSA Report: September 2010

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A. GENERAL PROGRAM

Authority for air quality monitoring is given to ADEQ in the Arizona 

Administrative Code, Title 18, Chapter 2, Article 2. Section R18-2-215 discusses the 

requirements for ambient air monitoring of criteria pollutants. ADEQ has entered into 

delegation agreements with Maricopa, Pima, and Pinal Counties to administer air quality 

programs in their respective counties. These agreements include providing air monitoring 

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 currently operates or oversees 18 active monitoring stations for criteria 

pollutants. The pollutants measured include:

Carbon Monoxide

Nitrogen Dioxide

Sulfur Dioxide

Ozone

Particulate Matter (PM10 and PM2.5)

ADEQ is organized into five divisions and two Regional 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 sections, 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 Offices. 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 majority 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 Standard 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 Parts 31 and 35, grant recipients are required to document their 
ADEQ TSA Report: September 2010

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quality systems 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 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.

The EPA also requires that organizations develop 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 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 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 2001, and “Guidance for Quality 

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

ADEQ has an agency-wide QMP that includes 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 and upcoming changes to air 

monitoring requirements. The Air Assessment Section QA/QC Lead has 

identified dates for QAPPs to be updated. While this plan is appropriate it may be 

challenging to meet the dates identified. 

 Recommendations:

1. Work 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

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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 McMoran, may not be 

collecting data that can be used 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 guidance 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)

will 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 quality 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?

Will 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)?

 Recommendation:

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

the State of Arizona. If the data are required, ADEQ should ensure that they are

adequate to demonstrate compliance with the NAAQS. ADEQ should also 

identify data in 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 adequate 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 

activities that occurred at that site. Maintaining such logbooks will help to 

develop a comprehensive history of the station. This will aid field technicians to 

pinpoint and assess problems that may arise with the station.
ADEQ TSA Report: September 2010

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All instruments operated within a particular monitoring site should have 

logbooks. These should be kept with the instrument and, at a minimum, include 

all repairs, calibrations, audits, or other maintenance performed. 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. Maintain 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 documentation 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, NO2, and 

SO2) residence times must be less than 20 seconds. Additionally, it is 

recommended that the residence time within the manifold and sample lines to the 

instruments should be less than 10 seconds. The station technicians should 

calculate the residence time, document it in the station logbook, and periodically 

verify 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 exceeded 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 excessive 

residence times.
ADEQ TSA Report: September 2010

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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 AQS. 

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. Currently, 

ADEQ field technicians do not participate in the review of the daily monitoring 

data. Field technicians have a better understanding of the monitoring stations, 

instrumentation and the current issues that might be adversely affecting data and

thus should be participating in an initial review of monitoring data. At 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 issues 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 loss.

Improved interaction between the monitoring unit and the data management 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 for the monitoring 

stations to which they are assigned on a day-to-day basis.
ADEQ TSA Report: September 2010

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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 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

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 Network 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 

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 
ADEQ TSA Report: September 2010

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objectives and data needs. 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 requires evidence of a public inspection process. ADEQ submits a monitoring 

network plan every year. The most recent submittal by ADEQ (2009) 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 relies on meteorological data from secondary sources that are not 

routinely evaluated.

Discussion:

When evaluating monitoring data and performing forecasting ADEQ relies on 

data supplied by various sources. These data are essential in certain areas when 

the State does not have a dense meteorological network. Anytime secondary data 

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 challenges 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 delegated to local monitoring 

organizations. The counties of Yuma, Santa Cruz, 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 state, 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 by 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 to 
ADEQ TSA Report: September 2010

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develop innovative approaches to monitoring station establishment and 

management and/or delegation to local authorities. 

FINDING B3:

ADEQ needs to have more direct oversight on monitors operated for source compliance 

that are being used for NAAQS comparison.

Discussion:

Source orientated monitors, 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 PM10 and PM2.5 instruments located in Miami are 

operated by an independent contractor hired by Freeport McMoran. Similarly the 

PM10 instruments located in Hayden are operated by an independent contractor 

hired through EPA’s Superfund program. 

Recommendation:

If ADEQ wants to use data 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 the ADEQ monitoring network.

FINDING B4:

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 1st, 2010.

Discussion: 

ADEQ needs 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, installation, 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

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C. FIELD OPERATIONS

Field operations for ambient monitoring 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 reviewed 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 

stations are 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 monitoring 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 

technicians at the monitoring stations. Most stations do not have dedicated computers or 

printers. Equipping 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 

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

for dates in 2008 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 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

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Discussion:

Currently there is no formal documentation 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 

screen.

Discussion:

The stainless steel is 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 and Teflon are the “only acceptable 

probe materials” for reactive gasses (ozone, sulfur dioxide, and nitrogen dioxide). 

Recommendation:

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

caps.

FINDING C3:

Several of the zero air generators have not been 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 helpful in 

documenting problems with instruments at a particular location, they lack specific 
ADEQ TSA Report: September 2010

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information about the instrument. There are other informal procedures in practice 

for identifying and correcting problems with the instruments that need to be 

improved. 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 procedures 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 inventory.

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, Appendix E, Section 5 states “trees can provide surfaces for 

SO2, O3, NO2 adsorption or reactions, and surfaces for particle deposition . . . to 

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 

regularly 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.

Discussion:

Canister and cartridge sampling systems should be certified and verified “nonbiasing” 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 and 
ADEQ TSA Report: September 2010

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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 systems 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 and other 

supporting equipment. Various methods are available to perform field 

certifications, such as introduction of blank or spiked air through the probe inlets 

and collocated sampling directly into evacuated canisters.

Recommendation:

Develop a system that ensures that all toxics and PAMS sampling equipment 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 significant 

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, the 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 responsibilities are subject to change on a monthly schedule.

Discussion:

Field technicians have monthly meetings to decide which sites are going to be 

visited by whom. While it is beneficial for technicians to have experience with 

multiple site locations, not assigning a site to a particular technician increases the 

potential for error in data collection. Given the differences in documentation and 
ADEQ TSA Report: September 2010

20

the lack of consistency with logbook procedures, changing site responsibilities on 

a frequent basis may not be promoting quality data collection.

Recommendation:

Field technicians should have at least one site for which they are primarily 

responsible. 
ADEQ TSA Report: September 2010

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D. LABORATORY OPERATIONS

ADEQ has a PM laboratory located at its main offices. The primary 

responsibility of the laboratory is the handling of PM filters, which includes preparation, 

weighing, 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 provided by the Eastern Research Group, Inc. (ERG) and was not reviewed as 

part of this TSA. 

The PM2.5 laboratory is well run and organized. ADEQ utilizes an automated 

balance, which enables the laboratory to collect multiple weights for each filter, 

increasing 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 inefficient 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 has been 

improved and no data errors were 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, transcription and entry of 

data into an Excel spreadsheet, data processing and review in Excel, and data 

translation and importation into the ADEQ air monitoring data base. 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:

The laboratory does not use blank controls for PM10 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, see 
ADEQ TSA Report: September 2010

22

40 CFR Part 50, Appendix J, Section 7.2.3, and EPA Compendium Method IO3.1 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 PM2.5 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 

process. However, there is no place to document routine events, exceptional 

events, problems, repairs to the weighing environment, and visitors to the weighroom.

Recommendation:

Provide a logbook in the weigh-room.

FINDING D5:

ADEQ is using 4oC as the criteria for invalidating filters based on temperature rather than 

average ambient temperature.

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-

to 30-day post sampling from 4

oC 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

oC, which results in 

unnecessary invalidation of data.
ADEQ TSA Report: September 2010

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Recommendation:

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

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E. DATA 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 validation 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 data 

validators 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. 

The Air Monitoring QA Lead should independently confirm that these were adequately 

addressed.

Data Management

FINDING E1:

During the data validation process, the validators do not use information provided in 

station, instrument, and other logbooks.

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 referred 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 noted 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 logbooks as needed.
ADEQ TSA Report: September 2010

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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 reported as valid to AQS. 

Operational criteria failures indicate that data may need to be invalidated or 

flagged. Failures of systematic criteria indicate that the monitoring system needs 

to be evaluated. Consistent failures of any of these criteria may cause entire data 

sets to be suspect.

The ADEQ validators evaluate individual data points for many critical and 

operational criteria. However, validation does not consider systematic criteria or 

the adequacy of the data sets based on these criteria. 

Recommendation:

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.

Discussion:

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 data 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

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Recommendation:

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

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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 ADEQ. 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. 

ADEQ has a defined quality management system, which includes a Departmental

quality management plan and oversight by an independent ADEQ Quality Assurance

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 sites, 

the 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 performed a recent review of quality 

management by the Air Assessment Section.

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. 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 Auditor 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. Performance audits of monitors operated by other 

organizations and facilities in Arizona are also performed by the QA Auditor. Due to 

time constraints, quality control of the Performance audit program was not reviewed 

during this TSA.

Quality Assurance and Quality Control

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.
ADEQ TSA Report: September 2010

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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 interpretation 

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 program 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

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APPENDIX A: Summary of Findings

Significant Findings

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 

by 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 B2:

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:

ADEQ 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 smelter in Miami and the ASARCO smelter in Hayden by 

January 1st, 2010.
ADEQ TSA Report: September 2010

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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 probe 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. 

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.

FINDING C6:

The equipment used for non-NATTS toxics monitoring and PAMS monitoring is not 

regularly 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 ADEQ 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 inefficient 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 PM2.5 is not being performed.

FINDING D4:

There is no logbook to document conditions and activities in the weigh-room.
ADEQ TSA Report: September 2010

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FINDING D5:

ADEQ is using 4oC as the criteria for invalidating filters based on temperature rather than 

average ambient temperature.

FINDING E1:

During the data validation process, 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.

FINDING 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.