TECHNICAL SYSTEM AUDIT

OF THE

CALIFORNIA ENVIRONMENTAL PROTECTION

AGENCY

AIR RESOURCES BOARD

2007

Conducted by US EPA Region 9

August 2008
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TABLE OF CONTENTS

TABLE OF CONTENTS ....................................................................................................3

LIST OF TABLES...............................................................................................................4

EXECUTIVE SUMMARY .................................................................................................5

INTRODUCTION ...............................................................................................................9

MAJOR FINDINGS ..........................................................................................................11

NETWORK MANAGEMENT .........................................................................................21

Introduction....................................................................................................................21

Network Management Findings ....................................................................................25

OPERATIONS ..................................................................................................................29

Introduction....................................................................................................................29

General Findings on ARB Operations...........................................................................29

Instrument Calibration Program ....................................................................................30

Special Purpose Monitoring Section .............................................................................31

FIELD OPERATIONS ..................................................................................................32

ARB Monitoring Sites...............................................................................................33

ARB Field Operation Findings..................................................................................34

San Joaquin Valley APCD Monitoring Sites.............................................................35

SJVAPCD Field Operation Finding ..........................................................................36

Northern Sierra AQMD Monitoring Sites.................................................................38

NSAQMD Field Operation Findings.........................................................................38

Great Basin Unified APCD Monitoring Sites ...........................................................41

GBUAPCD Field Operation Findings.......................................................................43

LABORATORY OPERATIONS ......................................................................................45

Introduction....................................................................................................................45

Inorganic Laboratory .....................................................................................................45

Organic Laboratory........................................................................................................48

DATA MANAGEMENT ..................................................................................................55

Introduction....................................................................................................................55

Data Management for: ARB-Operated Field Monitoring Stations...............................56

Data Management: Laboratory Analytical Methods ....................................................57

Data Management: Quality Assurance Performance Evaluation Audit .......................58

Data Management: Special Purpose Monitoring..........................................................58

Data Management: Local-District-collected/ARB-Uploaded-to-AQS.........................58

Data Management: Local District-Collected/Uploaded-to-AQS..................................59

QUALITY ASSURANCE.................................................................................................65

Introduction....................................................................................................................65

General Quality Management........................................................................................67

QA Section.....................................................................................................................69

Standards Laboratory.....................................................................................................72

Operations Planning and Assessment (OPA) ................................................................78

List of Acronyms...............................................................................................................81

APPENDIX A....................................................................................................................83

APPENDIX B....................................................................................................................93
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LIST OF TABLES

TABLE 1: SUMMARY OF SLAMS CRITERIA POLLUTANT

MONITORS IN THE ARB PQAO...............................................................19

TABLE 2: SUMMARY OF OTHER SPECIAL PURPOSE

POLLUTANT MONITORS IN THE ARB PQAO.............................................20

TABLE 3: SUMMARY OF NON-CRITERIA POLLUTANT AND

METEOROLOGICAL MONITORING IN THE ARB PQAO...............................21

TABLE 4: MONITORING STATIONS EVALUATED BY

US EPA DURING THE 2007 ARB TSA........................................................29
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EXECUTIVE SUMMARY

In accordance with Federal regulations at 40 CFR Part 58, Appendix A, EPA

Regional offices are required to conduct Technical System Audits (TSA) of each Primary

Quality Assurance Organization at least once every three years. This report presents the

findings of the TSA of the California Air Resources Board (ARB) monitoring program

conducted in the summer of 2007. 

A TSA is one of the ways that EPA provides oversight to ensure that data

collected by state and local agencies 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 those program elements which may

be adversely affecting the quality of ambient air data.

A Primary Quality Assurance Organization (PQAO) is a monitoring organization

or a coordinated aggregation of such organizations that is responsible for a set of stations

that monitors the same pollutant and for which data quality assessments can logically be

pooled. Each criteria pollutant sampler/monitor at a monitoring station in the State and

Local Air Monitoring Station (SLAMS) network must be associated with one, and only

one, PQAO.1 The term PQAO is a new term established in EPA’s revised monitoring

regulations promulgated on October 17, 2006. Previously the term “reporting

organization” was used to describe agencies that combined data quality assessments.

The California Air Resources Board (ARB), part of the California Environmental

Protection Agency, is the governmental agency delegated under State law with the

authority and responsibility for collecting ambient air quality data as directed by the

Clean Air Act of 1977 and Clean Air Act Amendments of 1990. The ARB and local Air

Pollution Control Districts (Districts) operate ambient monitoring stations throughout the

State. The ARB was designated as the Reporting Organization (RO) for the entire State

with the exception of the ambient air monitoring programs of the Bay Area Air Quality

Management District, the South Coast Air Quality Management District, and the San

Diego Air Pollution Control District.2 Based on similar quality assurance definitions of

the terms RO and PQAO in the previous version and current version of the CFR, EPA

Region 9 has tentatively defined ARB as the PQAO for all of California with the

exception of the three monitoring agencies listed above. Many of the smallest local

Districts do not have active air monitoring programs and rely solely on ARB for the

operation of monitoring stations within their jurisdictions.

The EPA Region 9 audit team interviewed the ARB management and staff on

various aspects of the air monitoring program including network design, field operations,

laboratory operations, data handling, quality assurance and quality control procedures.

1

40 CFR 58, Appendix A, section 3.1

2

State of California, Air Resources Board, Air Monitoring Quality Assurance, Volume I, Quality

Assurance Plan, Monitoring and Laboratory Division, June 2005, Section 1.0.2.2
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Since ARB oversees the quality assurance of data collected by local Districts3 within the

ARB PQAO, we also reviewed field operations, data management and quality assurance

activities at local Air Pollution Control Districts. For this TSA, it was not possible for

EPA to evaluate all of the 22 local Districts that collect ambient air quality data;

therefore, the EPA audit team reviewed operations at three local Districts, the San

Joaquin Valley Air Pollution Control District, the Great Basin Unified Air Pollution

Control District, and the Northern Sierra Air Quality Management District.

The local Districts included in the ARB PQAO have their own organizational

structures and these will vary depending on the size of the local district program. The

San Joaquin Valley Air Pollution Control District was chosen for review because it is the

largest local District in the ARB PQAO and has the most significant air quality issues.

Great Basin Unified Air Pollution Control District was chosen as an example of a

medium size organization and also because of the unique air quality problems that exist

in that air basin. Finally, the Northern Sierra Air Quality Management District was

chosen to be representative of the small Districts and, given more stringent the National

Ambient Air Quality Standards for PM2.5 and ozone, the mountain counties air basin is

beginning to face air quality nonattainment issues for the first time.

The major findings of this TSA pertain to the ARB’s role as a PQAO. One of the

most important elements in the implementation of an air monitoring program is

documentation. Appropriate documentation includes, but is not limited to, standard

operating procedures for all aspects of an organization's program, data quality

assessments, logbooks tracking actual day-to-day operations, and records of quality

control and maintenance checks. Oversight of personnel and activities involved in the

collection, processing and submittal of data is much more straightforward when

procedures are standardized and responsible personnel record their compliance with these

procedures. The ARB's internal monitoring program is both well organized and well

maintained, and generally meets or exceeds EPA monitoring requirements. However, our

review of the local District programs shows that the ARB, in its role as a PQAO for most

local Districts, does not fully meet EPA requirements. Specifically, information collected

through this TSA indicates that the ARB is not fulfilling its oversight role as the PQAO.

Examples include:

• The ARB PQAO does not have sufficient controls in place to ensure that local

Districts follow consistent procedures and produce data of similar quality.

• The ARB PQAO does not have support of common management, headquarters, or

laboratory facilities, with the exception of some analytical laboratory analysis

performed by the ARB's Monitoring and Laboratory Division (MLD) for some

Districts.

• There is no central organization that ensures Districts are aware of and follow

changes to the QA Manual and related SOPs.

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There are 32 local Districts that are part of the ARB PQAO. According to the California State and Local

Air Monitoring Network Plan - 2007, prepared by the ARB's Planning and Technical Support Division, Air

Quality Data Branch in June 2007, 22 local Districts operate air monitoring stations in the ARB PQAO.
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• Districts that are part of the ARB PQAO collect data for EPA decision making

and/or funded by EPA that is not quality assured by the ARB PQAO.

Generally, the findings presented in a TSA are followed with recommendations to

address the stated finding. In the case of this TSA, some of the major findings contained

in this report do not include a recommendation. This is because in some instances we

believe it is more appropriate to discuss the findings with the ARB management and

arrive at a mutually agreeable corrective action. For these most significant, overarching

findings, we expect solutions to involve a coordinated effort between the ARB, the local

Districts within the ARB’s PQAO, and EPA Region 9. On the other hand, where

possible and appropriate, recommendations are provided to give some indication of the

Region’s expectations as to how findings can be addressed. If the ARB has other

approaches or alternatives to address the concerns identified, EPA will consider them,

provided the corrective action adequately addresses the finding. In general, the findings

and recommendations in this report are listed in priority order. Finally, it is important to

note that the findings in this TSA are not intended to be used to validate or invalidate

ambient air quality data.

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

support and cooperation during this audit.
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INTRODUCTION

In the summer of 2007, EPA Region 9 conducted a Technical System Audit

(TSA) of the ambient monitoring program operated by and overseen by the ARB. The

ambient air monitoring program in the State of California encompasses many air quality

assessment activities including collecting and analyzing data for the Federal criteria

pollutants and many other air pollutants of concern, collecting data from special studies

as directed by the Board, determining which monitoring methods are used by the State

and local air districts, in compliance with Federal and State regulations, conducting

annual performance audits of all monitoring equipment within its PQAO, implementation

of a program to calibrate and certify measurement standards, and conducting training in

the operation of ambient air monitoring instruments.

EPA staff interviewed management and staff in three branches of the ARB

Monitoring and Laboratory Division (MLD) and one branch of the Planning and

Technical Support Division (PTSD). The TSA covered the areas of Air Monitoring

Network Management, Field Operations, Laboratory Operations, Data and Data

Management, and Quality Assurance. In addition, the EPA staff reviewed these same

areas as implemented by three local Districts: the San Joaquin Valley Air Pollution

Control District, the Great Basin Unified Air Pollution Control District, and the Northern

Sierra Air Quality Management District.

The ARB managers and staff were very accommodating to the EPA audit team in

making themselves and their staff available for many interviews, procedural reviews and

monitoring site visits. Branch Chiefs interviewed were:

Ken Stroud - Chief, Air Quality Surveillance Branch (AQSB), MLD

Jeff Cook - Chief, Quality Management Branch (QMB), MLD

Michael Poore - Chief, Northern Laboratory Branch, MLD

Karen Magliano - Chief, Air Quality Data Branch (AQDB), PTSD

Many other individual section managers and staff were interviewed in Sacramento and in

the field. We appreciate that ARB ensured that the EPA audit team had access to all key

personnel involved in the collection and quality assurance of ambient air quality data.

The EPA regional staff members conducting the TSA were Catherine Brown,

Meredith Kurpius and Robert Pallarino of the Air Division’s Technical Support Office

and Mathew Plate, Steve Remaley and Roseanne Sakamoto of the Region 9 Quality

Assurance Office.

The TSA began with a general meeting with ARB managers and staff on June 7, 

2007 at the Monitoring and Laboratory Division office in Sacramento, CA and continued

during the months of June, July, and August, 2007. In addition to the EPA Audit Team,

Sean Hogan and Eugenia McNaughton, respectively Managers of EPA Region 9's
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Technical Support Office and Quality Assurance Office, attended the opening meeting

representing EPA Management.

This report is divided into eight main sections. This first section is an executive

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

findings. The next section is an introduction that provides a brief description of the

ARB's air monitoring program activities, the EPA audit team, and the report organization.

The third section discusses our major findings on the ARB monitoring program as a

whole. The remaining five sections address specific aspects of the air monitoring

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

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

the findings contained in this report. Appendix B contains tables summarizing the State’s

air basins, metropolitan statistical areas, and the minimum monitoring requirements for

ozone, PM2.5 and PM10.
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MAJOR FINDINGS

Finding M1: The ARB Primary Quality Assurance Organization does not meet the

requirements in 40 CFR Part 58, Appendix A, Section 3.1 for its dependent Districts.

Discussion: The ARB Primary Quality Assurance Organization (formerly called

“Reporting Organization”) does not have sufficient controls in place to ensure that local

Districts follow consistent procedures and produce data of similar quality. During the

course of our review of the California ambient air monitoring program we found that the

ARB's oversight and its control over the quality of data produced by its dependent

Districts does not meet the requirements of 40 CFR 58 and that Districts have become

more independent in their data collection activities, either by choice or necessity. Based

on our interviews with the ARB staff and management, we believe that a significant

contribution to this reduction of the ARB's oversight role is the fact that MLD’s budget

and staffing levels have been insufficient to support many District activities (such as

calibration, standardization, training, data validation, and data reporting). 40 CFR 58, 

Appendix A notes:

3.1 Primary Quality Assurance Organization. A primary quality assurance

organization is defined as a monitoring organization or a coordinated

aggregation of such organizations that is responsible for a set of stations that

monitors the same pollutant and for which data quality assessments can logically

be pooled. Each criteria pollutant sampler/monitor at a monitoring station in the

SLAMS network must be associated with one, and only one, primary quality

assurance organization.

3.1.1 Each primary quality assurance organization shall be defined such that

measurement uncertainty among all stations in the organization can be expected

to be reasonably homogeneous, as a result of common factors. Common factors

that should be considered by monitoring organizations in defining primary quality

assurance organizations include:

(a) Operation by a common team of field operators according to a 

common set of procedures;

(b) Use of a common QAPP or standard operating procedures;

(c) Common calibration facilities and standards;

(d) Oversight by a common quality assurance organization; and 

(e) Support by a common management, laboratory or headquarters.

3.1.2 Primary quality assurance organizations are not necessarily related to the

organization reporting data to the AQS. Monitoring organizations having

difficulty in defining the primary quality assurance organizations or in assigning

specific sites to primary quality assurance organizations should consult with the

appropriate EPA Regional Office. All definitions of primary quality assurance
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organizations shall be subject to final approval by the appropriate EPA Regional

Office during scheduled network reviews or systems audits.

The ARB PQAO does not have common field operators between the ARB and

local Districts. The ARB does offer some training and meetings for field operators;

however, these are currently not extensive and many Districts do not participate. It was

noted that the ARB is improving its training program for ambient air monitoring. This

includes four modules, Fundamentals of Air Monitoring, Station Operations, Calibration

Principles, and Individual Instrument Training. These courses will be available to the

ARB employees as well as to District personnel.

The ARB PQAO has common procedures available; however, there are no

apparent mechanisms or programs in place to ensure that Districts are adopting the same

procedures as the ARB. Moreover, the ARB has not developed standard operating

procedures for some equipment employed by individual Districts. Although the ARB

sometimes informs Districts of procedural changes and problems, the ARB staff indicated

that they do not consider themselves obligated to inform Districts of these issues. Many

Districts chose not to follow the ARB procedures and Districts that develop and follow

their own procedures do not have them approved by ARB as required in the ARB QA

Manual:

Section 1.0.2.3: “Unless alternative procedures are submitted in writing to, and 

approved in writing by the ARB Monitoring and Laboratory Division, the

procedures set forth in the ARB Air Monitoring Quality Assurance Manual

(Volumes I through VI, as developed) apply to all agencies within the ARB 

reporting organization.”

The ARB PQAO has a “Standards Laboratory.” However, this laboratory is not

utilized by some Districts and utilization of the Standards Laboratory is not compulsory.

Additionally, the ARB does not track or control the types of standards used by the

Districts.

The ARB PQAO does have common QA oversight in regards to instrument audits

and criteria pollutant data evaluation. However, not all instruments are audited nor are

non-criteria pollutant laboratories and projects operated or contracted by the Districts

routinely overseen by the ARB. Additionally, data validation and internal data corrective

actions (not related to audits) are not performed consistently by the Districts and are not a

part of the ARB QA system.

The ARB PQAO does not have support of common management, headquarters, or

laboratory facilities, with the exception of some analytical laboratory analyses performed

by the MLD laboratory for some Districts.

In addition to the CFR requirements discussed above, other complicating factors

are that some Districts receive separate monitoring grants from EPA and/or

independently report data to AQS. Based on the discussion of the five PQAO criteria, the
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ARB PQAO does not meet the CFR requirements. Meeting these requirements for some

Districts may be easy to achieve, however others operate with a significant level of

independence (e.g. Great Basin Unified APCD).

Recommendation:

The definition of a PQAO includes five criteria as discussed above. The ARB has

proposed a number of actions that would enable them to meet the first two criteria,

operation by a common team of field operators according to a common set of procedures

and use of a common QAPP or standard operating procedures. The ARB's proposed

actions have been incorporated into this recommended corrective action.

To fulfill the requirement that a PQAO demonstrate that monitoring equipment is

operated according to a common set of procedures and that all agencies within the ARB

PQAO use common QAPPs and SOPs, the ARB AQSB will:

1) Identify a primary monitoring point of contact for each non-ARB district (‘District’)

within the ARB PQAO.

2) Provide Districts with SOPs, calibration spreadsheets, data review procedures,

maintenance forms and technical bulletins for FRM and FEM analyzers and samplers

operated by the ARB. These will be updated annually.

3) Require that each District formally adopt the ARB SOPs calibration spreadsheets,

maintenance forms and technical bulletins.

4) Require that each District notify Chief, AQSB when the relevant materials have been

adopted for FRM and FEM devices, or that they do not conduct FRM/FEM air

monitoring and periodically update their adoption list.

5) Require that each District develop SOPs and other relevant documentation for

FRM/FEM analyzers and samplers that are not operated by the ARB using the ARB's

standardize SOP format. Districts will be requested to submit their SOPs, etc. to ARB for

review and approval. Provide each staff person a copy of relevant SOP and ensure it is

understood and followed.

The ARB has also correctly identified training of operators as necessary to ensure

consistency of monitor operations. In addition to the training program mentioned above

in the discussion of this finding, the ARB has also proposed that the AQSB will:

1) Provide training annually (in Sacramento) on

a) fundamentals of air monitoring,

b) principles of calibration,

c) station operation, and,

d) instrument specific training, including data validation for that instrument (only

for instruments operated by the ARB).

2) Require the Districts to send staff to appropriate training (considering staff's duties)

and that the District provide for staff's travel and per-diem expenses as appropriate.
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Regarding the PQAO criterion that agencies within the organization use common

calibration facilities and standards, the ARB has proposed that the Quality Management

Branch (QMB) will:

1) Initiate the Air Quality Data Action (AQDA) process in the ARB's Standard’s

Laboratory. This process will notify Districts when an instrument fails

acceptance criteria for recertification. The AQDA will request an investigation of

the problem from the client District.

2) Retain up-to-date records on the source of certification of gas and flow

standards for FRM and FEM instruments used by districts in the ARB PQAO.

Records indicate there are few if any Districts that do not use the Standards

Laboratory for criteria pollutant monitoring. QMB/QA staff will conduct a

survey to determine the source and ensure NIST traceability is maintained for all

FRM and FEM instruments operated by those in the ARB PQAO.

Regarding data corrections that may be necessary as a result of the data

verification and validation process, the ARB has proposed to have the AQSB contact

Districts that receive any air quality data actions (AQDAs) that result from an audit. The

AQSB will follow-up with the District staff as part of the AQDA corrective action

resolution and provide training or other technical assistance as needed. The Air Quality

Data Branch (AQDB) will require that Districts within the ARB PQAO, for which ARB

does not submit data, make corrections caused by an AQDA in a timely manner in AQS.

Further, the Districts will submit a copy of the EPA required annual certification

documentation to the Air Quality Data Branch.

The ARB needs to take some additional actions to ensure that its own

organization, as well as the local Districts in its PQAO, is fully and consistently aware of

QA issues in the monitoring program. To that end, we propose that the ARB designate a

QA lead with defined authority for working with PQAO districts for each relevant office

in the ARB, e.g. the AQSB, the Northern Laboratory Branch and the Quality

Management Branch within the Monitoring and Laboratory Division and the AQDB

within the Planning and Technical Services Division. We also recommend that the ARB

designate a QA coordinator with responsibility for overseeing QA activities, convening

QA working group meetings and reviewing and approving quality documents submitted

by the air districts, MLD, and other ARB Divisions. Districts in the ARB PQAO should

also designate QA points of contact. To assist the ARB in implementing this

recommendation, EPA Region 9 will:

1) Participate in QA working group meetings in an advisory capacity, taking an

oversight role for document review (QMPs, QA Project Plans, including tribal

plans);

2) Coordinate with the ARB on district monitoring and quality assurance.

3) Defer and refer to the ARB questions and issues from districts regarding

monitoring conducted that supports the ARB PQAO. This would occur regardless

of the district's status as an EPA grantee or data reporting organization.

4) Recommend that districts use the ARB process in place to request the use of

alternative methods and equipment.
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Finding M2: There is no central organization that ensures Districts are aware of and

follow changes to the QA Manual and related SOPs.

Discussion: The ARB MLD branches use the agency website to update documents

incorporating operational changes. These changes are not normally communicated to the

Districts in the ARB PQAO. To ensure the PQAO is functioning consistently, it should

notify all District monitoring staff of changes and, where needed, provide guidance and

training on implementing changes, and verify that changes have been implemented or

that the procedures used are otherwise equivalent.

Recommendation: As discussed in the recommendation to Finding 1 above, the AQSB

will take steps and implement procedures to ensure that the ARB and the Districts in its

PQAO are all using the same QA and Standard Operating Procedures. The AQSB will

achieve this by:

1) Providing Districts with SOPs, calibration spreadsheets, data review

procedures, maintenance forms and technical bulletins for FRM and FEM

analyzers and samplers operated by the ARB. This will be updated annually.

2) Requesting that each District formally adopt the ARB SOPs calibration

spreadsheets, maintenance forms and technical bulletins.

3) Requesting that each District notify the Chief of the AQSB when the relevant

materials have been adopted for FRM and FEM devices, or that they do not

conduct FRM/FEM air monitoring and periodically update their adoption list.

4) Requesting that each District develop SOPs and other relevant documentation

for FRM/FEM analyzers and samplers that are not operated by the ARB using the

ARB's standardize SOP format. Districts will be requested to submit their SOPs,

etc. to ARB for review and approval. Provide each staff person a copy of the

relevant SOP and ensure it is understood and followed.

Finding M3: The ARB PQAO has a corrective action process in its QA Manual, but it is

not being applied outside the Quality Management Branch (QMB) performance audit

program.

Discussion: The QA Manual Volume I defines the ARB’s only formal data corrective

action as an Air Quality Data Action (AQDA). The definition from Section 1.0.6.3 is:

An Air Quality Data Action (AQDA) is a request for an investigation of the

validity of ambient air quality data for a certain period of time. Figure 1.0.6.3 

depicts an AQDA request form. AQDA requests can be initiated by any person

suspecting erroneous data and serves as a means for withholding questionable air

quality data pending further investigation.

AQDA corrective actions were not found to be used outside of the ARB MLD Quality

Assurance Section’s performance/site audit program. The MLD Air Quality Surveillance

Branch has a formal corrective action process beyond the AQDA Process that results in
16

monitoring bulletins being sent out, but this process does not go through independent QA

review. The extent to which formal corrective action is taken in the Districts was not

determined. However, District corrective action does not routinely go to the ARB MLD

for review, and on the occasion when it does (for NAAQS determinations) the process

used is not defined.

Recommendation: As discussed in the recommendation to Finding 1, the ARB has

proposed to have the AQSB contact Districts that receive an air quality data action

(AQDA) that results from an audit, and follow up with the staff in the resolution with

training or other technical assistance as needed. The Chief of the ASQB will request that

Districts within the ARB PQAO, for which ARB does not submit data, make corrections

caused by an AQDA in a timely manner in AQS, and that the Districts submit the

required annual certification documentation to the EPA Region 9 offices, with a "cc"

copy sent to the Chief of the AQDB. Further, the Chief of the QMB will initiate the

AQDA process in the ARB's Standard’s Laboratory. This process will notify Districts

when an instrument fails acceptance criteria for recertification. The AQDA will request

an investigation of the problem from the client District.

In addition to the ARB's existing AQDA process, additional corrective action

procedures should be initiated to address other aspects of the air quality monitoring

program. In the section of this report that addresses Quality Assurance, we note in

Findings QA4, QA5 and QA6 that the ARB should institute a program of data quality

audits, reviews of the MLD's and District data reduction and review procedures, and

checks of the precision and accuracy of District generated data. The ARB needs to

develop and implement these additional review procedures. Appropriate corrective

procedures should be undertaken, if necessary, as a result of these reviews. In addition,

ARB needs to incorporate a process to handle corrective actions that originate from

District staff and management in a consistent manner.

Finding M4: The ARB collects environmental data for EPA decision-making that is

funded in whole or part by EPA but is not subject to the requirements of the ARB and

EPA quality assurance programs.

Discussion: EPA grant dollars, in whole or part, are used by the ARB to collect

environmental data. However, the ARB does not have a system of centralized Quality

Management to ensure that these data, which in some cases are used to support EPA

decision-making, meet federal quality assurance requirements. This is contrary to what is

reflected in the ARB QA Manual.

The QMB's focus is on monitoring projects which originate in the MLD. The

QMB staff was unable to provide the EPA auditors with the details on projects that

originate in other ARB Divisions. Furthermore, the QMB does not believe that MLD has

any QA responsibility for projects originated by other ARB Divisions, and is disinclined

to apply EPA quality assurance standards to data collected by MLD that is not directly

required of MLD by EPA air monitoring regulation.
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One specific project with EPA funding, over which the MLD QMB has not

exercised QA authority, is the ongoing Lake Tahoe study. Another project, with which

the QA Branch is involved, but the QMB staff stated was not relevant to EPA’s

oversight, is the Lodi diesel emissions study. After reviewing the ARB’s 2007 Federal

Clean Air Act Section 105 grant work plan, EPA auditors determined it is evident that the

Lodi study supports several activities specifically called out under the grant.

All organizations conducting environmental programs funded by EPA are

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

40 CFR Part 31 and 35, grant recipients are required to document their quality system in

a Quality Management Plan through EPA Order 5360.1 A2, Policy and Program

Requirements for the Mandatory Agency-wide Quality System (EPA 2000).

Where data collection is not funded by EPA but the results used for EPA

decisions (including SIPs and CAA rulemaking), the data must either directly meet the

requirements for EPA funded projects in 5360.1 or be acceptable as secondary data by

demonstrating validity through quality assurance and/or scientific peer review. This is

dictated by requirement 8 of EPA Order 5360.1 A24:

(8) Assessment of existing data, when used to support Agency decisions or other

secondary purposes, to verify that they are of sufficient quantity and adequate

quality for their intended use.

Where data collection efforts do not include sufficient quality controls to be

assessed or peer reviewed, the data should not be used to support EPA decisions.

Recommendation: Institute a QA workgroup for the ARB PQAO. This workgroup, or

the ARB PQAO QA Coordinator and EPA will work together to identify special projects

that use EPA funding for data collection and ensure that all appropriate and required QA

activities are being met.

Finding M5: Districts that are part of the ARB PQAO collect data for EPA decisionmaking and/or funded by EPA that are not quality assured by the ARB PQAO.

Discussion: The Districts that are part of the ARB PQAO collect monitoring data that

are not related to the PQAO’s activities. These data could be for special projects initiated

by individual Districts or for programs dictated by EPA (such as PAMS). Where this

data could be used for EPA decision-making or their collection funded by EPA, the

Districts should have independent quality systems and supporting quality assurance

plans. This is not always the case. The Districts should make it transparent to EPA and

the ARB which monitoring is intended to be included under the ARB PQAO. Where

monitoring is not clearly part of the ARB PQAO responsibilities, the Districts must

maintain an appropriate quality assurance system. In the case of EPA-funded work, this

4

Policy and Program Requirements for the Mandatory Agency-wide Quality System, Classification No.:

5360.1 A2, May 5, 2000
18

requires the District to act as a PQAO for the work in question and to submit appropriate

QAPPs.

Recommendation: As discussed in Finding 4, all organizations conducting

environmental programs funded in whole or part by EPA are required to establish and

implement a quality management system. The requirements of EPA Order 5360.1 A2

apply to the Districts within the ARB PQAO, as well as to the ARB itself. The QA

workgroup mentioned in the recommendation to Findings 5 should also address this issue

and ensure that all data collection activities funded in whole or part by EPA meet the

appropriate QA requirements.

Finding M6: The ARB QA Manual does not fully meet EPA’s QMP and QAPP

requirements.

Discussion: The ARB Air Monitoring Quality Assurance Manual is regularly updated

and posted on the ARB website for MDL and District staff reference. The QA Manual

meets many of the EPA’s requirements for Quality Management Plans (QMPs) and

Quality Assurance Project Plans (QAPPs). However, some additional information and

procedures need to be incorporated into this document. EPA also requests that the ARB

formally divide this document into a QMP and QAPPs or provide a crosswalk of how and

where the EPA QMP and QAPP requirements have been addressed in a preamble to the

document.

The last QA planning documents approved by EPA were a PM2.5 QAPP and the

ARB’s Quality Assurance Manual in December 1998 and June 1993, respectively. In

order to facilitate review, the ARB should formally contact EPA Region 9 any time

significant changes are made to the QAM or its attachments so EPA can expeditiously

perform reviews.

All organizations conducting environmental programs funded by EPA are

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

40 CFR Part 31 and 35, grant recipients are required to document their quality system 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, requirements specific to ambient air monitoring 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/B01/002, 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
19

obtained are of the type and quality needed and expected. Further guidance on 

developing QAPPs can be found in the guidance documents “EPA Requirements for

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

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

Recommendation: As part of the overall reinvigoration of the ARB QA program, the

ARB will develop a schedule to update its QA documentation to meet EPA requirements.

Finding M7: Data are not validated using consistent procedures.

Discussion: In order to maintain a consistent data set, a PQAO should have a consistent

standard for routine data validation. However, the QA Manual does not dictate a specific

validation scheme for each of the criteria pollutants. This leads to data validation that is

inconsistent and has the appearance of being arbitrary. This is of special concern when

data are used for NAAQS determination.

Recommendation: See our recommendations to Finding 3 above and to Findings DM1,

DM2, DM3, and DM 5.

Finding M8: EPA commends the ARB MLD for producing Quality Assessment Reports

and recommends that the ARB PQAO develop a mechanism to use these reports to make

specific corrective actions or other quality improvements.

Discussion: The MLD Quality Assurance Section produces excellent reports to assess

the overall quality assurance effectiveness of each part of the ARB PQAO. These

reports, no doubt, have a positive impact on many of the Districts' performance.

However, in order to produce data of consistent quality, the ARB PQAO needs to have a

mechanism for systematic evaluation of the practices that lead to both poor and good

quality data in order to improve data quality and consistency.
20

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21

NETWORK MANAGEMENT

Introduction

The purpose of this section is to evaluate the methods and procedures used by the

ARB to manage the State's air monitoring network. Our review of the ARB PQAO

network is based on the network design criteria contained in 40 CFR 58, Appendix D and

the ARB State and Local Air Monitoring Network Plan, prepared annually by the

Planning and Technical Support Division of the ARB.

The State network consists of monitoring stations operated by both the ARB and

the local Districts. The ARB organizes the State monitoring networks by air basin, of

which there are 15 defined in the State. Air basin monitoring networks consist of stations

with criteria pollutant monitors designated as State and Local Air Monitoring Stations

(SLAMS) monitors, special purpose monitors (SPM), or, in some cases, no designation.

For the purposes of our evaluation we treated monitors with no designation as SPMs.

As discussed previously, there are four PQAOs in the State of California: the

ARB, the South Coast AQMD, the Bay Area AQMD, and the San Diego APCD. These

four organizations operate monitoring networks that provide data for the 15 air basins in

the State. The three local PQAOs operate monitoring networks that provide data for

three of the 15 State air basins: South Coast, Bay Area, and San Diego County. The

ARB PQAO operates multiple monitoring networks that cover the remaining 12 State air

basins: Great Basin, Lake County, Lake Tahoe, Mojave Desert, Mountain Counties,

North Central Coast, North Coast, Northeast Plateau, Sacramento Valley, Salton Sea, San

Joaquin Valley, and South Central Coast. The ARB issues an annual network description

which provides details on the monitoring stations throughout the State, including those

outside of the ARB PQAO (i.e. monitoring stations operated by the South Coast AQMD,

the Bay Area AQMD, and the San Diego APCD). Monitoring stations operated by the

National Park Service and some monitoring stations operated by private contractors are

also listed in the annual report. The annual report also includes information on 

monitoring stations in Baja California, Mexico that are located near the border of

California. This annual network description includes not just active monitoring sites but

any monitoring site that collected air pollution data in the State of California since the

early 1970's.

In some instances, multiple local Districts operate the monitoring networks in a

given air basin. Furthermore, the boundaries of metropolitan and micropolitan statistical

areas (MSAs), which are established by the US Census bureau, also overlap air basins

and local monitoring districts. EPA uses the population statistics of MSAs to determine

the minimum SLAMS monitoring requirements for ozone, PM10, and PM2.5

5

. Appendix

5

There are currently no minimum monitoring requirements for the criteria pollutants carbon monoxide,

nitrogen dioxide, sulfur dioxide, and lead.
22

B at the end of this report provides details on the air basins, MSAs, minimum monitoring

requirements and actual number of SLAMS ozone, PM2.5 and PM10 monitors in the ARB

PQAO.

We have reviewed the SLAMS monitoring network for the ARB PQAO and have

determined that, due to changing population statistics and the tightening of the PM2.5

daily NAAQS, there are a few MSAs which do not meet the minimum monitoring

requirements for ozone, PM2.5 and PM10 established by EPA in its regulations at 40 CFR

58, Appendix D. These are addressed in the findings in this section of the report.

Table 1 summarizes the number of SLAMS monitoring sites operated in the ARB

PQAO.

TABLE 1: SUMMARY OF SLAMS CRITERIA POLLUTANT

MONITORS IN THE ARB PQAO

OPERATING

AGENCY

Ozone CO NO2 SO2 PM2.5 PM10 TSP

Lead

ARB 25 6 14 1 17 22 1

Antelope Valley 1 1 1

Great Basin Unified APCD 1 11

Imperial County APCD 2 1 2 5

Kern County APCD 1 1

Lake County AQMD 1 1 1

Mendocino County APCD 2 2 2 1 3

Mojave Desert AQMD 6 2 3 2 1 4

Monterey Bay Unified APCD 6 1 2 2 5

North Coast Unified AQMD 2 2

Northern Sierra AQMD 2 4 2

Northern Sonoma County APCD 1 3

Placer County APCD 2

Sacramento Metropolitan AQMD 4 3 4 2 2 5

San Joaquin Valley APCD 11 5 10 5 8

San Luis Obispo County APCD 5 3 1 1 4

Santa Barbara County APCD 4 2 3 3 2

Shasta County AQMD 2 1 2

Siskiyou County APCD 1

Tehama County APCD 1

Ventura County APCD 6 2 4 3

Yolo-Solano AQMD 2 1

TOTALS 81 23 44 9 48 85 1

Source: California State and Local Air Monitoring Network Plan - 2007, Planning and Technical Support

Division, Air Quality Data Branch, June 2007

The SLAMS monitors do not represent all of the criteria pollutant monitors

operated in the ARB PQAO. A significant number of criteria pollutant monitors are

designated as Special Purpose Monitors or have no designation as summarized in Table

2.
23

TABLE 2: SUMMARY OF OTHER SPECIAL PURPOSE

POLLUTANT MONITORS IN THE ARB PQAO

OPERATING

AGENCY

Ozone CO NO2 SO2 PM2.5 PM10

ARB 7 2

Antelope Valley 1

Great Basin Unified APCD 1

Imperial County APCD 3 1 2 5

Mojave Desert AQMD 1

Monterey Bay Unified APCD 2 1 1 1 1 2

North Coast Unified AQMD 1 1 1 1 1

Sacramento Metropolitan AQMD 2 1 1

San Luis Obispo County APCD 1

Santa Barbara County APCD 4 2 4 2 2

Siskiyou County APCD 1 2

Tehama County APCD 1 1

Yolo-Solano AQMD 3

TOTALS 22 5 8 4 1 15

Source: California State and Local Air Monitoring Network Plan - 2007, Planning and Technical Support

Division, Air Quality Data Branch, June 2007

The ARB PQAO also collects data for non-criteria pollutants and meteorological

data as summarized in Table 3. 
24

TABLE 3: SUMMARY OF NON-CRITERIA POLLUTANT AND

METEOROLOGICAL MONITORING IN THE ARB PQAO

OPERATING

AGENCY

Met. PM2.5

BAM

PM10

TEOM

PM2.5

Spec.

NMHC NMOC Toxics COH Light

Scat.

H2S THC

ARB 37 18 2 7 3 2 6

Antelope Valley APCD 1 1

Great Basin Unified APCD 11 10

Imperial County APCD 1

Lake County AQMD 1 1 1

Mendocino County APCD 4

Mojave Desert AQMD 5 3 1 1

Monterey Bay Unified APCD 6 2 2

North Coast Unified APCD 1

Northern Sierra AQMD 3 1 1

North Sonoma County APCD 2

Sac. Metro. AQMD 8 3 2 4 4 1

San Joaquin Valley APCD 13 5 3 4 4

San Luis Obispo County APCD 3 1

Santa Barbara County APCD 7 1 2

Shasta County AQMD 1 1

Ventura County APCD 6 4 1 2 2 1

Yolo-Solano AQMD 3 2

TOTALS 113 35 25 13 14 8 7 1 2 2 2

Source: California State and Local Air Monitoring Network Plan - 2007, Planning and Technical Support

Division, Air Quality Data Branch, June 2007

The ambient monitoring network in the ARB PQAO has evolved over time and its

size, in terms of number of sites and spatial coverage, has generally kept pace with the

changing demographics of the State. The individual pollutant networks have been

modified over time in response to the change in air pollution problems. For instance, the

number of sulfur dioxide monitors operated in the State has decreased from a maximum

of about 80 monitors in 1990 to its current number of approximately 366. This decrease

reflects the progress made in reducing the amount of sulfur dioxide air pollution and the

subsequent decrease in the need to monitor for this pollutant. All air basins in the State

of California are currently in attainment of the sulfur dioxide NAAQS.

In previous years there has been no formal process of network design followed by

the agencies that make up the ARB PQAO. The SLAMS monitoring networks in each of

12 air basins in the ARB PQAO consist of monitors operated only by the local District or

a combination of monitoring sites operated by the local Districts and the ARB. When a

local District wishes to modify a network, e.g. shutting down or relocating an existing

6

Page 1-3, California State and Local Air Monitoring Network Plan - 2007, Planning and Technical

Support Division, Air Quality Data Branch, June 2007. This number includes sulfur dioxide monitors

operated by the South Coast AQMD, the Bay Area AQMD, and the San Diego APCD.
25

site or establishing a new site, they will informally consult with the ARB for feedback on 

the proposed change.

As a result of changes to EPA monitoring regulations, which included more

specific requirements for the development and submittal of Annual Network Plans7, the

ARB has developed a questionnaire which will be sent annually to Districts in their

PQAO. This questionnaire asks Districts to provide information on how many pollutant

monitors they operate, the purpose of each monitor, proposals for upcoming changes to

the monitors they operate, a listing of monitors they operate but for which they do not

submit data to EPA, and how Districts provide for public review of the local monitoring

network. A copy of this questionnaire is included in Appendix C.

Network Management Findings

Finding NM1: The ARB annual network plan includes not only active monitoring sites

but any monitoring site that collected air pollution data in the State of California since the

early 1970's, whether still in operation or not.

Discussion: The ARB annual network plan includes much useful information on the

history of air monitoring in the State and the availability of data. It includes not only

information about the criteria pollutant monitors but also the non-criteria pollutants of

interest and importance. However, while it is useful to know that historic data are

available, a separate table or report that addresses the currently active monitoring stations

in the State would be more useful.

Recommendation: Revise the format of the annual network plan to include a table that

lists only the active monitoring stations

Finding NM2: The Stockton MSA in the San Joaquin Valley Air Basin does not meet

the minimum SLAMS monitoring requirements for PM2.5.

Discussion: In 2000, the Stockton MSA had a population of 563,598 people and an

estimated 2006 population of 673,170 people. The 2004-2006 annual and daily PM2.5

design values for this MSA, based on data collected at the Stockton Hazelton monitoring

site, are 12.9 ug/m3 and 41 ug/m3 respectively. EPA regulations require MSAs with

populations between 500,000 and 1,000,000 people and PM2.5 design values greater than

85% of either the annual or daily NAAQS to have a minimum of two PM2.5monitoring

sites designated as SLAMS. There is currently only one PM2.5 site in the Stockton MSA,

Stockton-Hazelton Street (AQS#06-077-1002) designated as a SLAMS site.

Recommendation: The ARB or the San Joaquin Valley APCD needs to establish an

additional PM2.5 SLAMS monitoring site in the Stockton MSA.

7

See 40 CFR 58.10.
26

Finding NM3: The Modesto MSA in the San Joaquin Valley Air Basin does not meet

the minimum SLAMS monitoring requirements for PM2.5.

Discussion: In 2000, the Modesto MSA had a population of 446,997 people. The

population of this MSA has grown and the estimated 2006 population was 512,138

people. The 2004-2006 annual and daily PM2.5 design values for this MSA, based on data

collected at the Modesto-14th Street monitoring site, are 14.1 ug/m3 and 51 ug/m3

respectively. EPA regulations require MSAs with populations between 500,000 and

1,000,000 people and design values greater than 85% of either the annual or daily

NAAQS to have a minimum of two PM2.5 monitoring sites designated as SLAMS sites.

There is currently only one PM2.5 site in the Modesto MSA, Stockton-14th Street

(AQS#06-099-0005) designated as a SLAMS site.

Recommendation: The ARB or the San Joaquin Valley APCD needs to establish an

additional PM2.5 SLAMS monitoring site in the Modesto MSA.

Finding NM4: The Visalia-Porterville MSA in the San Joaquin Valley Air Basin does

not meet the minimum SLAMS monitoring requirements for ozone.

Discussion: The Visalia-Porterville MSA had a population of 368,021 people in 2000.

The population of this MSA has grown and the estimated 2006 population was 419,909 

people. The 2004-2006 ozone design value for this MSA, based on data collected at the

Visalia-Church Street monitoring site, is 0.092 ppm. EPA regulations require MSAs with

populations between 350,000 and 4,000,000 people and design values greater than 85%

of the ozone NAAQS to have a minimum of two ozone monitoring sites designated as

SLAMS sites. There is currently only one ozone site in the Visalia-Porterville MSA,

Visalia-Church Street (AQS#06-107-2002) designated as a SLAMS site.

Recommendation: The ARB or the San Joaquin Valley APCD needs to establish an

additional ozone SLAMS monitoring site in the Visalia-Porterville MSA.

Finding NM5: Some information in the ARB State and Local Air Monitoring Network

Plan, dated June 2007, does not agree with information in the EPA AQS database or with

local district Annual Network Plans. The specific examples noted in the discussion

related to this finding may or may not constitute the actual total number of

inconsistencies in the 2007 plan.

Discussion: In comparing data in the EPA AQS database and the ARB Network Plan,

we discovered a number of inconsistencies.

The Grass Valley and Truckee PM10 sites operated by NSAQMD (AQS # 06-057-

0005 and 06-057-1001, respectively) collect continuous data that has been reported to

AQS through 2006, however ARB's 2007 S&L Monitoring Network Plan indicates that

continuous PM10 data for these sites are only available through 2003.
27

In Glenn County, the Willows-East Laurel Street site (AQS # 06-021-0002)

discontinued PM10 operations in September 2006 and was replaced by the Willows-North

Colusa Street site (AQS# 06-021-0003). The 2007 S&L Monitoring Network Plan states

that the old site continued to collect PM10 data through 2007 and indicates that the new

site only collects ozone data.

In San Luis Obispo County, the Carrizo Plains School SLAMS PM10 Monitor

(AQS# 06-079-8006) was closed in AQS as of December 31, 2006, yet the 2007 S&L

Monitoring Network Plan indicates that data for 2007 is available. The NipomoGuadalupe Road PM10 Monitor (AQS# 06-079-2004) is identified as a SLAMS site in the

2007 S&L Monitoring Network Plan, but is not designated as a SLAMS monitor by the

San Luis Obispo APCD in their 2007 Ambient Air Monitoring Network Review.

Recommendation: The ARB should ensure that the Annual Network Plans accurately

reflect the availability of monitoring data, including which monitors are currently

operational, and that there is agreement between the ARB and local districts as to the

designation of sites.

Finding NM6: The ARB 2007 Network Plan is not complete with respect to GBUAPCD

sites, monitoring objectives or monitoring scales.

Discussion: Examples of errors in the ARB 2007 Network Plan include:

Dirty Socks is a source-oriented monitor (Owens Lake), however the ARB 2007 

Network Plan provides no scale or monitoring objective.

Mono Shores is a source-oriented, maximum concentration site, but is listed as

urban scale in ARB network plan. For these site types it is unlikely that the

monitor is urban scale.

Recommendation: The ARB should give local Districts the opportunity to review the

information in the Annual Network plans to ensure site information is correct.
28

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29

OPERATIONS

Introduction

The purpose of this section is to evaluate the operation, support and siting of air

monitoring instrumentation according to EPA requirements at 40 CFR 58, Appendices A,

C, D and E. Network operations at the ARB are primarily performed by the Air Quality

Surveillance Branch (AQSB) of MLD. AQSB duties include the operation of the ARB

monitoring sites, monitoring support for the ARB special studies, and general air

monitoring support, which includes repair and calibration facilities. This section of the

TSA report addresses AQSB's general operations, the calibration program, field

operations of the AQSB at the ARB operated criteria pollutant monitoring sites, and field

operations at criteria pollutant monitoring sites operated by the San Joaquin Valley

APCD, the Great Basin Unified APCD and the Northern Sierra AQMD.

EPA interviewed those managers and staff of the Air Quality Surveillance Branch

(AQSB) who provide support to the field monitoring task. The individuals interviewed

included Ken Stroud, Chief Air Quality Surveillance Branch, Reginald Smith, Manager

Operational Support Section, Eric McDougall, Manager Special Purpose Monitoring

Section, Joe Rohr, Instrument Technician Operations Support Section, and Ronald Lewis,

Air Pollution Specialist Air Monitoring Central Section. All persons interviewed in the

Air Quality Surveillance Branch were very helpful and forthcoming. The AQSB has a

well developed framework to support the MLD monitoring task. It was particularly noted

that the Operational Support Section includes functions that add significant value to

AQSB’s monitoring program, both in terms of technical expertise and improved

monitoring data quality.

General Findings on ARB Operations

Finding AQSB1: Field operators do not always document shipping information on their

sample report/tracking sheets. See also Lab Finding #IL7

Discussion: Documentation of sample shipping, transport, and relinquishment, maintains

the integrity of sample custody throughout the sampling process, attests that sample were

handled properly, and documents by whom they were handled. This information is

important if a question about a sample’s validity arises.

Recommendation: Ensure that field operators are aware of the importance of

documenting shipping information.

Finding AQSB2: Some ARB MLD monitoring SOPs are outdated and/or incomplete.
30

Recommendation: ARB should develop a schedule for updating all monitoring SOPs

and ensure that the SOPs posted are complete and cover all instruments used in the ARB

monitoring network.

Finding AQSB3: The use of correction fluid was noted on an MLD air monitoring form.

Discussion: It was noted that correction fluid was used on a form produced by the MLD

monitoring group. Changes to official records should not be covered or obliterated.

Generally, mistakes should be indicated by a single line crossed out and accompanied by

initials and date.

Recommendation: ARB personnel should follow appropriate procedures when making

corrections to official documentation and records.

Instrument Calibration Program

ARB is responsible for calibrating its own criteria pollutant monitors and offers

calibration support to districts if requested. Of the approximately 341 criteria pollutant

monitors in the ARB PQAO, ARB calibrates 139 instruments (96 ARB instruments and

45 District instruments). ARB also calibrates some non-criteria pollutant instruments.

Of the approximately 97 non-criteria pollutant instruments and 113 meteorological

instruments, ARB calibrates its own 39 non-criteria instruments and 37 meteorological

stations and calibrates 11 District operated non-criteria instruments and 2 District

operated meteorological stations.

Finding AQSB4: ARB MLD does not calibrate monitoring equipment at all PQAO

sites.

Discussion: Over the past decade, the ARB MLD monitoring sections have reduced

calibration support for District sites. Consequently, Districts have established their own

instrument calibration procedures independent of the ARB PQAO. This practice does not

support the existence of a centralized standardization of instrumentation and

consequently consistent data quality throughout the PQAO.

Recommendation: The corrective action for this finding is dependent on how the EPA,

the ARB and the local Districts address the overall organization issues of the ARB PQAO

(See Finding M1).

Finding AQSB5: Second level review of calibration records and calculations is not

routinely performed.

Discussion: The senior field technicians are responsible for calibration of the ARB MLD

field instruments for their respective monitoring sections (North, South, and Central).

These technicians generate calibration records, which are not generally reviewed by a
31

peer or a manager. Second level review helps to ensure consistency and to catch errors

made in transcriptions or calculations.

Recommendation: The ARB should institute a program of second level review of

calibration records.

Finding AQSB6: The lowest ozone calibration point is at a concentration that is above

the 8-hour standard.

Discussion: The ARB MLD Air Quality Surveillance Branch calibrates ozone monitors

down to 0.09 ppm. This concentration is above the NAAQS of 0.075 ppm8. In order to

verify linearity around or below the NAAQS, ARB should change the low ozone

calibration point to at or below 0.075 ppm.

Recommendation: The ARB calibration program needs to ensure the performance of

ozone instruments at levels at or lower than the ozone NAAQS. EPA suggests this be

accomplished by using a lowest calibration point at or below 0.075 ppm.

Finding AQSB7: The calibration technician noted that only 2 gas phase titration points

are used to verify the NO2 calibration.

Discussion: 40 CFR Part 50, Appendix F describes the requirements for NO2 calibration.

Section 1.5.9.4 states: “Maintaining the same FNO, FO, and FD as in section 1.5.9.1, adjust

the ozone generator to obtain several other concentrations of NO2 over the NO2 range (at

least five evenly spaced points across the remaining scale are suggested).” Based on the

regulation, “several” other NO2 points after the initial point must be evaluated.

Recommendation: ARB MLD should include more evaluation points in the NO2 gas

phase titration.

Finding AQSB8: Maintenance and performance verification of zero air scrubbers used

for calibrations is not documented.

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

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

generate the zero point and the calibration mixes, it must be treated as a standard. As

such, zero air scrubber maintenance and verification must be documented.

Recommendation: The ARB should document the maintenance and performance

verification of zero air scrubbers.

Special Purpose Monitoring Section

8 At the time this TSA was conducted the ozone NAAQS was set at 0.08 ppm. EPA subsequently revised

the ozone NAAQS to 0.075 ppm.
32

Finding AQSB9: The Special Purpose Monitoring Section should keep EPA informed

of its monitoring projects.

Discussion: The Special Purpose Monitoring Section conducts monitoring as a

“contractor” for the ARB or other agency (e.g., Department of Pesticide Regulation)

researchers. Some of this monitoring may be funded wholly or partially by EPA (through

ARB or other State Agencies) and could have implications related to NAAQS

determinations, network design, or other EPA requirements and/or decision-making.

Therefore, where possible and appropriate, an EPA monitoring contact should be

informed of such monitoring.

FIELD OPERATIONS

During this TSA the EPA audited the operations at 14 monitoring stations as

summarized in the following table.

TABLE 4. MONITORING STATIONS EVALUATED BY

EPA DURING THE 2007 ARB TSA

Operating Agency Monitoring Station

ARB Stockton - Hazelton

Modesto - 14th Street

Oildale

Visalia

Fresno – 1st Street

San Joaquin Valley APCD Bakersfield – Golden State Highway

Corcoran

Parlier

Tracy

Fresno – Clovis

Northern Sierra AQMD Grass Valley

Portola

Truckee

Quincy

Great Basin Unified APCD Coso Junction

Dirty Socks

Lone Pine

Mono Shore

Lee Vining

Mammoth
33

ARB Monitoring Sites

Five monitoring stations operated by the ARB were evaluated as part of this TSA.

EPA interviewed a number of ARB field technicians, including Ron Lewis, Phillip

Powers, Ralph Robles, Dianne Arnold, George Jung, and Patrick Seamus. The ARB is to

be commended for having an especially competent staff of field operators. During our

discussions of operations, all staff exhibited detailed knowledge of instrument operations

and the day-to-day documentation of activities was exemplary. Senior field technicians

were very engaged in all operations of their sites. EPA also appreciates the relationship

the Air Monitoring Central Section has with local District operators. The strong technical

support provided to the Districts was very evident.

All ARB monitoring sites evaluated were well equipped, organized and clean.

The field technicians had access to all relevant SOPs. Stations were set up to

automatically perform zero, span and precision checks of continuous gaseous instruments

on a schedule that exceeds EPA requirements. The flow rate of low flow PM instruments

is checked bi-weekly, calibrations of low-flow samplers are checked semi-annually.

High volume PM sampler flow checks are performed monthly and calibrated semiannually. Flows are checked at 16.67 lpm for low flow instruments and at 40 scfm for

high volume instruments. For gaseous instruments, flow checks are done daily and

calibrations are performed semi-annually.

Field technicians interviewed were well versed in their duties regarding data

validation and how to address corrective actions. Corrective actions are dealt with on a

case-by-case basis. If a site instrument fails an annual audit, specific corrective actions

are taken based on consultation with senior field operations staff. The operators are

encouraged to document any unusual events in the station log, sample data forms and

strip charts. All documentation regarding data editing and validation is reviewed and

signed off monthly by the senior field technician before forwarding to the Special

Purpose Monitoring and Data Support Section of the Air Quality Surveillance Branch of

the Monitoring and Laboratory Division. While deviations from SOPs are rare, in the

event that a deviation from a SOP is necessary, it is documented in the station log after

consultation with senior field technicians.

All stations maintain log books to document site visits, preventive maintenance,

resolution of operational problems, and corrective actions taken. Logbooks were

generally very detailed. The senior monitoring technicians periodically review the

logbooks and also note in the logbook when they visit the station. A standard, routine

review of logbooks is not performed. Operators archive station logbooks at their main

monitoring station or office. Other station records include QC checklists and

maintenance sheets which are also archived at the operator’s main monitoring station or

office. All necessary calibration information is available to the field operators.

The ARB has a comprehensive mandatory training program for new staff.

Refresher courses given by the ARB and instrument manufacturers are also open to all

staff.
34

Minor instrument repair work is done at the station. If necessary, equipment is

sent to the MLD for major repairs. Replacement equipment is sent to the station within a

day to replace any instruments taken out of service for repair. Other than standard

manufacturer warranties, the ARB does not have any service contracts in place. Station

operators indicated that they have an adequate supply of spare parts and consumable

supplies to ensure that necessary repairs and maintenance can be performed.

ARB Field Operation Findings

Finding AQSB10: The trees to the east of the Fresno 1st Street station building are

about 15 meters from the inlet probe and PM manual instruments.

Discussion: EPA siting criteria require that trees are at least 10 meters from instrument

inlets and at least 20 meters when the trees act as an obstruction. The ARB’s plan to

relocate this station to its proposed new site 375 meters to the east southeast will address

this finding.

Recommendation: None.

Finding AQSB11: At the Stockton-Hazelton monitoring station, a large tree to the south

of the trailer is acting as an obstruction for the gaseous pollutant sample train inlet as well

as to the PM10 and PM2.5 samplers. This site does not meet the probe siting criteria in 40 

CFR 58, Appendix E. 

Discussion: The obstruction caused by this tree has been noted in previous visits to the

site. According to Ron Lewis, Lead Air Pollution Specialist, the tree has been trimmed in

the past in an attempt to minimize its affect as an obstruction. The PM manual samplers

were previously located on the roof of the Health Department Building but were moved

to the top of the station trailer when the Health Department roof was repaired. Ron

believed they could return the PM samplers to the roof. If so, the PM samplers would

meet all siting criteria.

The inlet for the gaseous instruments will need to be moved or the tree trimmed

significantly in order to meet siting criteria.

Recommendation: Address siting issues by relocating PM samplers to the roof of the

Health Department Building. Develop a plan to address the siting of the gaseous

instrument inlet probe by either moving inlet probe (although this may not be an option

since probe already appears to be as far away from tree as possible), moving the trailer

farther from the tree, or by significantly trimming the tree so that it no longer obstructs

air flow.

Finding AQSB12: The palm tree northwest of the Visalia monitoring station is within

10 meters of the inlet probe.
35

Discussion: As stated in 40 CFR 58, Appendix E (Probe and Monitoring Path Siting

Criteria for Ambient Air Quality Monitoring), sections 2.4 and 8.2, trees can provide

surfaces for ozone or NO2 adsorptions or reductions, surfaces for particulate deposition,

and generally obstruct wind flow. EPA understands that removing a tree, especially from

a leased site, is not always possible. ARB should perform an analysis of the prevailing

wind direction at the Visalia site to determine the direction of the prevailing winds. If the

prevailing winds are generally from the northwest, ARB will need to correct this siting

issue, either by having the tree trimmed or removed or relocating the site.

Recommendation: Perform an analysis of prevailing wind directions at the Visalia site

to help evaluate the impact of the palm tree northwest of the inlet probe and manual

samplers.

San Joaquin Valley APCD Monitoring Sites

Five monitoring stations operated by the SJVAPCD were evaluated as part of this

TSA. Four operators, Warren Leleaux, Duane Thompson, Jaime Contreas, and Carl

Camp, were interviewed. Other SJVAPCD staff interviewed were Steve Shaw and

Kashmir Pandher. The San Joaquin Valley District field technicians are well versed in

equipment operations but there are variations as to how they perform certain procedures,

such as general station documentation and manifold cleaning and conditioning.

However, quality control checks and maintenance of equipment are performed in

accordance with EPA requirements and guidance. Field technicians are responsible for

day-to-day operations as well as instrument repair and maintenance at their assigned

stations.

There are no District-specific field SOPs available to site operators. Operators

rely on instrument operation manuals and ARB SOPs, when available. SJVAPCD

operators acknowledged the need for specific instrument and operation SOPs, but stated

that lack of District monitoring resources made it difficult to address all of the areas in

the monitoring program that needed attention.

Stations were set up to automatically perform zero, span and precision checks of

continuous gaseous instruments on a schedule that exceeds EPA requirements. The flow

rate of low flow PM instruments is checked bi-weekly, calibrations of low-flow samplers

is semi-annually. High volume PM sampler flow checks are performed monthly and

calibrated semi-annually. Flows are checked at 16.67 lpm for low flow instruments and

at 40 scfm for high volume instruments. For gaseous instruments, flow checks are

performed each time the field technician visits the site and calibrations are performed

semi-annually.

All stations maintain log books to document site visits, preventive maintenance,

resolution of operational problems, and corrective actions taken. Logbooks were

generally detailed. Operators archive station logbooks at their main monitoring station or
36

office. Other station records include QC checklists and maintenance sheets which are

also archived at the operator’s main monitoring station or office. All necessary

calibration information is available to the field operators.

Corrective actions are dealt with on a case-by-case basis. If a site instrument fails

an ARB annual audit, specific corrective actions are taken based on consultation with

ARB field operations staff. The SJVAPCD does not have any specific SOPs that address

instrument corrective actions. Station operator can note special circumstances on strip

chart.

SJVAPCD Field Operation Findings

Finding SJV1: The San Joaquin Valley APCD does not have District specific SOPs

addressing the operation and maintenance of its air pollution monitoring network.

Discussion: The district staff relies on the ARB SOPs for instrument operations. While

this is acceptable in practice, the district should ensure that copies of the SOPs are readily

available to all station operators. There is no process in place to ensure this will occur.

From a strictly performance perspective, the station operators have demonstrated

knowledge of the monitoring instruments and all required and appropriate QC checks are

performed and documented. Yet there are some variations in the QC checks, e.g.

concentrations used in span checks for gaseous instruments as well as maintenance

procedures, such as manifold cleaning procedures.

SOPs detail the work procedures that are to be conducted or followed within an

organization. SOPs document the way activities are to be performed to ensure consistent

conformance to technical and quality system requirements and to support data quality.

SOPs are intended to be specific to the organization or facility whose activities are

described and to assist that organization to maintain their quality control and quality

assurance processes and to ensure compliance with governmental regulations.

Sufficiently detailed SOPs can also serve as training materials and references for

operators, particularly if they are updated regularly (which is recommended to be done on 

a three- year cycle). SOPs should be distributed so that only the most recent versions are

used (controlled-copies). Further guidance on developing SOPs can be found in the EPA

guidance document "Guidance for Preparing Standard Operating Procedures",

EPA/240/B-01/004, March 2001. Deviations and changes from SOPs should be dated,

documented, and kept in a bound or electronic file that is routinely available to all staff.

Recommendation: The SJVAPCD should develop District specific SOPs (with ARB

approval) for all pollutant and meteorological monitoring instruments. Alternatively, the

SJVAPCD can adopt the ARB SOPs.

Finding SJV2: The SJVAPCD field operators do not maintain zero and span or

precision check control charts.
37

Discussion: The data logging software used by the District at its monitoring stations can

chart QC check data if technician wishes to examine a graphical presentation of QC data,

however, there is not a standard practice of printing control charts on any set schedule.

This is in contrast to the ARB operations, where the station operators print out and review

control charts on a monthly basis as part of the first level data review.

Recommendation: As part of the overarching finding on SOPs discussed above, the San

Joaquin Valley APCD should develop first level data review SOPs for use by the field

technicians. This SOP should require the use of control charts as part of the data review

and verification process.

Finding SJV3: Station and instrument logbooks are not reviewed by the Supervising Air

Quality Instrument Technician.

Discussion: There are log books maintained at all stations to document site visits,

preventive maintenance, resolution of operational problems and corrective actions taken.

The logbooks were all complete, detailed and up-to-date. However, no supervisors

review the station logbooks. The SJVAPCD Supervising Air Quality Instrument

Technician acknowledged the need for reviewing the logbooks periodically but stated

that given the limited number of personnel, the time available to him to perform such

supervisory tasks was limited.

Recommendation: In order to ensure that field personnel are performing activities

consistent with the District SOPs (see SOP discussion above) there should be some level

of oversight of field staff. This oversight task can either be performed by the Supervising

Air Quality Instrument Technician or by a first line supervisor.

Finding SJV4: There is no current, consistent procedure in place for archiving all

station records.

Discussion: Field technicians will generally archive used logbooks at their offices.

Instrument maintenance and check sheets, which are the record of QC checks, are

archived at the District office or at ARB. While a decentralized system of archiving

station is acceptable, there should be written procedures in place so that field technicians

use consistent procedures. Ideally, there should be a central, secure facility for all

ambient monitoring documentation. Station documentation sent to the ARB should be

copied and retained by the District.

Recommendation: The San Joaquin Valley APCD should develop a SOP for document

and record archiving.

Finding SJV5: At the Bakersfield – Golden State Highway site, the area surrounding the

trailer which houses the monitoring equipment needs to be stabilized.

Discussion: Bakersfield Golden State Highway is one of the higher reading PM10 sites in

the San Joaquin Valley District network. EPA regulations at 40 CFR 58, Appendix E, 
38

section 8.4 states "Stations should not be located in an unpaved area unless there is

vegetative ground cover year round, so that the impact of wind blown dust will be kept to

a minimum".

Recommendation: Stabilize the parking area where the Bakersfield Golden State

Highway trailer is located.

Northern Sierra AQMD Monitoring Sites

The Northern Sierra Air Quality Management District (NSAQMD) operates a

network of ozone and PM monitoring instruments. Four monitoring stations run by the

NSAQMD were evaluated. Three field technicians were interviewed: Joe Fish, the air

monitoring manager, George Ozanich, and Ken Walker. The NSAQMD field technicians

all exhibited a thorough knowledge of equipment operations. All quality control checks

and maintenance are performed in accordance with EPA regulations. Field technicians

are responsible for day-to-day operations as well as instrument repair and maintenance at

their assigned stations. The monitoring manager performs calibrations of the ozone

instruments.

The monitoring stations operated by the NSAQMD are not set up to perform

automated QC checks. All zero, span, and precision checks for ozone are performed

manually about once a week and flow checks of PM instruments are performed once per

month, which exceeds EPA requirements.

Northern Sierra AQMD uses the ARB SOPs. Hardcopies of the SOPs are kept at

the Grass Valley office/site but not at any other sites. Site operators have the instrument

manuals but not the SOPs. Operators keep track of unusual events or anomalies for

continuous instruments in a monthly report sheet and also document issues for the

monitoring manager. Any special events or anomalies for FRM PM2.5 are recorded on 

the Chain of Custody sheet and sent to ARB with the filter. Standard logbooks are not

used by NSAQMD, but alternative documentation methods are utilized, e.g. electronic

files and binders. Station operators may keep their own records, though the records kept

are at their own discretion.

NSAQMD Field Operation Findings

Finding NS1: The NSAQMD field technicians have instrument manuals but not SOPs.

The ARB SOPs are only kept at the District’s main office in Grass Valley and are not at

field stations. Additionally, the District operations deviate from the ARB SOPs but do 

not document those deviations.

Discussion: SOPs detail the work procedures that are to be conducted or followed within

an organization. SOPs document the way activities are to be performed to ensure

consistent conformance to technical and quality system requirements and to support data
39

quality. SOPs are intended to be specific to the organization or facility whose activities

are described and to assist that organization to maintain their quality control and quality

assurance processes and to ensure compliance with governmental regulations.

Sufficiently detailed SOPs can also serve as training materials and references for

operators, particularly if they are updated regularly (which is recommended to be done on 

a three- year cycle). SOPs should be distributed so that only the most recent versions are

used (controlled-copies). Further guidance on developing SOPs can be found in the EPA

guidance document "Guidance for Preparing Standard Operating Procedures",

EPA/240/B-01/004, March 2001. Deviations and changes from SOPs should be dated,

documented, and kept in a bound or electronic file that is routinely available to all staff.

The NSAQMD has modified some of the practices in the ARB SOPs, but these

deviations are not documented. For example, the NSAQMD uses 5% as an action level

for zero/span checks for ozone. ARB uses 10% as an action level. While it is

commendable that the District uses such a stringent acceptance criterion, since they are

part of the ARB PQAO, they should request approval from ARB to use this criterion.

Recommendation: The NSAQMD needs to develop District specific SOPs for all

monitoring instruments and submit them to ARB for approval. Alternatively, the

NSAQMD can adopt the ARB SOPs.

Finding NS2: The NSAQMD record-keeping procedures should be more rigorous.

Discussion: The NSAQMD has no record keeping standard operating procedures.

Pollutant instrument information is kept in an electronic format and periodically printed

out and stored in a binder. Record keeping by individual operators is not consistent and

seems to be at the operator’s discretion. No station logbooks are maintained. No records

for manual PM sampling are maintained.

Recommendation: The NSAQMD should develop a SOP for record keeping that

includes procedures for utilizing station logbooks, for maintaining other necessary

records of instrument operations (e.g. QC and maintenance check sheets), for regular

management review of records, and for suitable archiving procedures to ensure the

security of these records.

Finding NS3: The NSAQMD experiences significant ozone data loss due to a lack of

spare parts.

Discussion: The NSAQMD experiences significant data gaps because of failing ozone

pumps that cannot be replaced quickly. They must either be rebuilt or new ones ordered.

40 CFR 50.11 requires hourly data that are at least 75% complete. To ensure that this

requirement is met, prolonged instrument down-time should be avoided, if at all possible.

Recommendation: NSAQMD should have at least one spare ozone pump to avoid

unnecessary loss of data.
40

Finding NS4: Audits performed by ARB of the NSAQMD PM instruments do not

conform to CFR requirements. Additionally, the NSAQMD stated that the ARB does not

perform through the probe audits of NSAQMD ozone monitors.

Discussion: Flow audits for PM instruments should occur every 6 months, but the actual

schedule has been closer to once a year. For example, the two most recent PM flow

audits performed by the ARB were listed by the NSAQMD monitoring manager as

occurring on 8/8/2006 and 6/4/2007.

While the ARB performs ozone audits at the required frequency, the NSAQMD

monitoring manager noted that during the last two audits, on 6/26/2006 and 6/4/2007, the

ARB staff did not perform through-the-probe audits. The NSAQMD monitoring

manager stated that the audit gas was introduced directly into the ozone instruments and

not through the sampling train. There was no explanation for this revised procedure.

Recommendation: ARB flow checks for PM samplers should be scheduled for every 6 

months for PM instruments. Regarding the ozone audits, the ARB should ensure that

consistent procedures are followed by the audit team. If there is a specific reason why a

through-the-probe audit is not possible, this should be communicated to the NSAQMD

monitoring manager and documented in the audit report.

Finding NS5: There is no feedback from the ARB on outcome of PM filters. See also

Laboratory Finding # IL8.

Discussion: The chain of custody sheets and PM filters are sent from local Districts to

ARB, where all subsequent sample handling and data reporting occurs. ARB does not

report back to Districts for several months, so there is no opportunity to make up 

sampling runs or to address problems in a timely manner. In the case of exceedance

values and PM10 samplers running on a one in six day schedule, Districts should be

informed promptly when an exceedance of the 24 hour NAAQS occurs. This would

allow the Districts the option of increasing the PM10 sampling frequency to avoid having

a single exceedance represent a violation of the NAAQS.

Recommendation: Immediately report filter results when there is a problem or an

exceedance.

Finding NS6: The most recent ARB site survey report was not accurate.

Discussion: The EPA auditor noted a number of inaccuracies on the ARB audit sheet for

Grass Valley, including:

• A tree within 4 m of ozone inlet

• Ozone calibration listed as not current but not listed as an action item.

• The audit report did not specify whether the BAM is PM10 or PM2.5. The BAM at

Grass Valley is measuring PM2.5 while the purpose listed in the audit sheet is

SLAMS. The BAM is not a FEM approved method for PM2.5.
41

• The logbook at Portola was listed as being up-to-date, but in fact there is no

logbook.

Recommendation: ARB should review siting criteria and information on site survey

report during audits.

Finding NS7: There are trees within 20 m of monitors.

Discussion: Siting requirements state that trees should be >20 m from ozone inlet (40

CFR 58, appendix E). At the Grass Valley site, there is a tree within 4 m of the ozone

inlet. At the Quincy site, there is a group of trees 10-12 m from ozone, PM2.5, and PM10

instruments.

Recommendation: The NSAQMD needs to address this siting issue, either by trimming

or removing the trees or relocating the inlets of the instruments.

Great Basin Unified APCD Monitoring Sites

The Great Basin Unified Air Pollution Control District (GBUAPCD) is the

responsible local agency for ambient monitoring in Inyo, Mono and Alpine Counties in

California. As stated in the District’s QAPP for PM10, “...it is the GBUAPCD’s

responsibility to develop long-range comprehensive programs to achieve and maintain

Federal and state air quality standards. The GBUAPCD is responsible for the

implementation of the air quality monitoring program and the enforcement of Federal,

State and local rules and regulations governing air quality at the local level”.

The Air Quality Monitoring Section conducts all air quality and meteorological

monitoring and laboratory activities for the District. The Air Monitoring Specialist,

Christopher Lanane, supervises day-to-day operation of the network and the laboratory,

including field operations, maintenance and calibrations, field QC, data collection and

validation and is responsible for writing the QAPPS. The QA (including performance

audits, level 2 data validation and AQS upload) personnel are supervised by the Deputy

Air Pollution Control Officer, Duane Ono. The members of GBUAPCD staff

interviewed by EPA for this audit include:

Christopher Lanane, Air Monitoring Specialist

Dan Johnson, Air Quality Technician II

Guy Davis, Air Quality Technician II

Gabe Ibarra, Air Quality Technician II

Jim Parker, Senior Research Analyst

Phil Kiddoo, Research and Systems Analyst II

Mike Horn, Air Quality Technician II
42

All staff interviewed showed a thorough understanding of the monitoring program and

required QC and QA practices and their importance in determining the quality of

GBUAPCD’s monitoring data.

Station operators conduct day-to-day operations as well as instrument repair and

maintenance at their assigned stations. Their duties include extensive and welldocumented biweekly, monthly and periodic quality control checks for all instruments

and data validation through level 1 at each station. The operators interviewed were

familiar with the District QAPPs although copies were not in place at all sites. In part,

this is due to the lack of secure storage space at some monitoring stations.

The majority of GBUAPCD’s network (8 of 14 SLAMS sites) consists of both

filter-based FRM and continuous PM10 monitors for surveillance of known sources:

Owens and Mono lakebeds and a geothermal power generator. The District currently

does not operate any gaseous criteria pollutant monitors. Under EPA's monitoring

regulations, the District has no areas requiring gaseous criteria pollutant monitoring based

on the low population of its towns and villages. However, discussion with the District

was begun regarding the possibility of establishing a rural NCore station in the air basin.

The monitoring stations visited included Coso Junction, Dirty Socks, Lone Pine,

Mono Shore, Lee Vining and Mammoth. The monitoring objectives at each site vary

from population-oriented surveillance (Lone Pine, Lee Vining, Mammoth) to sourceoriented monitoring (Coso Junction, Keeler, Mono Shore). Station logbooks and

instrument logbooks were mostly up to date and contained relevant information on 

operations, repair and maintenance activities. All sites met the siting criteria of 40 CFR

58, Appendix E, where applicable (population-oriented sites).

GBUAPCD operates an independent QA program for all its PM and

meteorological monitoring and laboratory activities. Although there is not a defined

manager for QA activities, well-defined and documented QA procedures were clearly

described by the personnel interviewed. The District’s QA project plans for PM2.5 and

PM10 are very thorough and include district-specific standard operating procedures. The

QA program includes biweekly flow checks by the station operators, quarterly

independent flow audits of the instruments, chain-of-custody procedures for collected

filters, a system of QC procedures which are documented for each site, extensive QA/QC

for the gravimetric laboratory for both PM10 and PM2.5 filter weighings, monthly data

review station-by-station to verify completeness and validity, detailed corrective action

procedures, annual calibration of all flow standards (transfer standards and NISTtraceable primary). During the audit, EPA received a copy of GBUAPCD’s most recent

PM10 QAPP which will be reviewed for approval by Region 9. In 2002, as part of the

PM10 QA program, the District employed an outside consultant to conduct an

independent System Audit of the PM10 monitoring program which found no compliance

issues. Another example of an independent QA program element is the monthly meeting

of the District’s technical staff which allows for interaction on problem-solving and

standardizing of procedures among operators.
43

GBUAPCD manages all of the ambient monitoring data generated by the district.

Data quality objectives and measurement quality objectives have been defined for the

GBUAPCD’s program. Station operators ensure that data collection and sample handling

are performed according to specific SOPs and validate data from their stations. The QA

staff (non-operators) verify and validate data through level two validation, as defined in

the QAPPs. Based on a memorandum of understanding with the District, ARB and EPA,

GBUAPCD submits its data to AQS. Data is archived at either the main office in Bishop

or the field office in Keeler.

GBUAPCD maintains a laboratory for weighing PM2.5 and PM10 filters. The

laboratory meets or exceeds the gravimetric and temperature and humidity QC

requirements for PM2.5 (40CFR Part 50 Appendix L) and therefore meets and exceeds the

requirements for weighing PM10 filters. They employ a rigorous monthly verification

procedure for microbalance standards, temperature and humidity measurement checks.

GBUAPCD has provided technical and QA support to tribal monitoring programs

within the Great Basin. EPA commends the District for its willingness to extend its

monitoring expertise to the development of community monitoring programs by tribal

agencies.

GBUAPCD Field Operation Findings

Finding GB1: Great Basin operates an independent monitoring, laboratory and QA

program from that of ARB.

Discussion: GBUAPCD has independent QAPPs for its PM2.5 and PM10 monitoring

programs and laboratory operations. The QAPPs incorporate SOPs written by the

District. QA oversight by ARB consists of a flow audit once per year.

Recommendation: GBUAPCD should be considered an independent QA organization,

separate and distinct from the ARB, for purposes of annual data summary statistical

evaluation and comparison to the NAAQS.

Finding GB2: GBUAPCD’s training program, a QA function, is independent and

separate from that of ARB.

Discussion: GBUAPCD has independent training and education requirements as part of

its General and Ambient Monitoring-specific training.

Recommendation: See Finding GB1.

Finding GB3: Some logbooks were not up to date and signed by the GBUAPCD

operators at all stations.
44

Discussion: Logbooks are an important legal record for defending the monitoring data

collected by an agency. They document the activities performed by the operator at the

site.

Recommendation: All logbook entries should be signed and should reflect on-site

activities which may affect data validation and/or completeness.
45

LABORATORY OPERATIONS

Introduction

Analytical laboratories provide support for measurement methods that are either

too complex or sensitive to perform in the field environment. In providing these services,

laboratories employ complex instrumentation and staff with highly specialized training.

For ambient air samples to provide useable information or evidence, laboratory

analyses must meet the following basic requirements:

Equipment must be frequently and properly calibrated and maintained.

Personnel must be qualified to make the analysis.

Analytical procedures must follow accepted practice.

Complete and accurate records must be kept.

The ARB MLD Northern Laboratory Branch (NLB) is divided into three sections:

the Inorganic Laboratory Section, Organic Laboratory Section, and the Special Analysis

Section. The laboratory facility is adequate for the NLB’s needs. The laboratory

provides analytical support for the criteria pollutants PM10 and PM2.5. Additionally, the

laboratory supports the EPA PM Speciation Trends Network (STN), the California Air

Toxics Monitoring Network, and Special Study Monitoring. The laboratory audit

focused on PM10, PM2.5, and methods that had not been previously audited as part of the

Speciation Trends Network. Many of the non-criteria pollutant methods are performed

primarily for State purposes with minimal support from EPA. The NLB Chief and all the

staff interviewed were extremely cooperative, knowledgeable, and interacted

professionally with the auditors.

Overall, EPA was impressed with the organization and the attention to detail

exhibited by laboratory personnel and records. While EPA has included several areas for

potential improvement, no serious deficiencies were noted.

This section is divided into two sections: the first addresses findings for the

Inorganic Laboratory operations; the second addresses findings for the Organic

Laboratory operations.

Inorganic Laboratory

Finding IL1: The MLD weigh sessions have been automated in a manner that reduces

the possibility of operator error.

Discussion: EPA observed that the automated weighing process functioned as described

by the technicians, who had been actively engaged in the development of the system.
46

Finding IL2: Mass determination of PM10 filters should include blank controls.

Discussion: Blank controls help to evaluate the impacts of filter handling and storage in

the laboratory and the field. They are required by regulation as a mechanism for

evaluating filter media, see 40 CFR Part 50, Appendix J, Section 7.2.3. EPA

Compendium Method IO-3.1 states, in Section 5.4: that “...one blank sample [should be

provided] with every 10 actual samples.”

Recommendation: The MLD should include routine blank controls as a part of the PM10

laboratory operations.

Finding IL3: Temperature and humidity measurements in the weigh rooms are logged

on a paper chart and not formally analyzed to determine compliance with regulatory

criteria.

Discussion: Generally, the temperature and humidity in MLD’s two weigh rooms are

stable. However, there are times when temperature and humidity spikes and/or

excursions occur. Currently, the technicians “eyeball” the charts to determine

compliance with regulatory requirements. If MLD were to calculate the actual conditions

with the aid of a software program and electronic data logging software, the acceptability

of weigh room conditions would be quickly discernible . 

Recommendation: MLD should look into upgrading the system for monitoring

compliance with temperature and humidity requirement in the weigh rooms.

Finding IL4: The PM10 laboratory has only recently begun to track verification of

“working” mass standards in a logbook.

Discussion: The PM10 “working” mass standards are weighed with every batch of filters

to verify balance performance. Their weight is periodically verified by a comparison

check to “primary” mass standards. No documentation of this verification was available

for the data tracked from 2006. However, this deficiency has been corrected recently

with the use of a logbook. It is recommended that the use of the logbook be continued

and that additional documentation, such as mass standard identifiers, be tracked, which

would be similar to what is provided for the PM2.5 “working” standard verification

logbook.

Recommendation: The PM10 standard verification logbook should include information

similar to that available in the PM2.5 standard verification logbook.

Finding IL5: Several additional improvements could be made to the PM2.5 weighing

process.

Discussion: The following observations were noted:
47

The PM2.5 filter identification numbers that are embossed on each filter are not

recorded. The numbers on the filters can be used as a mechanism to prevent

misidentification of filters. Since the MLD PM2.5 weigh room procedure is well

organized, this is not a significant concern.

The start date and time for the beginning of pre-weigh conditioning of PM2.5

filters was not documented. Because filters are conditioned well in excess of 24 hours

and the PM2.5 laboratory is well organized, this is not a significant concern.

The laboratory staff was not aware of the new regulatory requirement for PM2.5

monitoring. In particular, the new temperature requirement from 40 CFR Part 50, 

Appendix L, included below:

8.3.6 The post-sampling conditioning and weighing shall be completed within 240 

hours (10 days) after the end of the sample period, unless the filter sample is maintained

at temperatures below the average ambient temperature during sampling (or 4 °C or 

below for average sampling temperatures less than 4 °C) during the time between

retrieval from the sampler and the start of the conditioning, in which case the period

shall not exceed 30 days.

Reference 2 in section 13.0 of this appendix has additional guidance on transport of

cooled filters.

Recommendation: The MLD laboratory should take these three observations into

consideration for potential improvements to the current PM2.5 mass analysis process.

Finding IL6: The PM10 and PM2.5 documentation and archived filters were well

organized and easily tracked.

Discussion: EPA performs a data tracking exercise as part of its technical system audits

to simulate what might happen if the designation decisions are challenged and data

documentation must be verified. The MLD laboratory staff was not able to locate the

information quickly.

Finding IL7: Field operators do not always document shipping information on their

sample report/tracking sheets. See also Operations Finding #AQSB1.

Discussion: Documentation of sample shipping, transport, and relinquishment

demonstrates sample custody throughout the sampling process, confirms that samples

were handled properly, and documents by whom they were handled. This information

supports sample identification.

Recommendation: Ensure that field operators are aware of the importance of

documenting shipping information.
48

Finding IL8: A local District stated that there was lack of sufficient feedback from the

ARB on result of PM filter analysis. See also Operations Finding #NS8.

Discussion: The chain of custody sheets and PM filters are sent from local Districts to

the ARB, where all subsequent sample handling and data reporting occurs. The ARB

does not report back to Districts for many months, which does not allow sampling runs to

be made up or to address other problems in a timely manner. In the case of exceedance

values and PM10 samplers running on a one-in-six day schedule, Districts need to know

as soon as possible when an exceedance of the 24 hour NAAQS has occurred so that they

have the option of increasing the PM10 sampling frequency to avoid having a single

exceedance represent a violation of the NAAQS.

Recommendation: ARB should report filter results to the Districts as soon as possible

when they indicate a problem or an exceedance.

Organic Laboratory

EPA reviewed and evaluated five procedures performed by the Organic Laboratory

Section:

SOP MLD 022, Aldeydes and Methyl Ethyl Ketone (MEK) by High Performance

Liquid Chromatography (HPLC)

SOP MLD 039, Hexavalent Chromium by Ion Chromatography (IC)

SOP MLD 058, Aromatic and Halogenated Hydrocarbons by Gas

Chromatography/Mass Spectrometry (GC/MS)

SOP MLD 066, Oxygenated Hydrocarbons and Nitriles, and Canister Cleaning &

Certification

In general, the Organic Laboratory Section is well run. The most significant

findings address the issues of analyzing audit samples, evaluation of a new GC/MS, and

carbonyl field blanks. The remaining findings are recommended practices that might

improve the defensibility of data produced by the laboratory.

Aldeydes and Methyl Ethyl Ketone (MEK) by High Performance Liquid

Chromatography (HPLC)

Finding OL1: A second source quality control standard is not being analyzed as

required by the method. Analysis of a second standard is being performed, but the

standard is not prepared from a second standard source but rather is prepared as a dilution

of the same standard solution that is used to prepare the working calibration standards.

Discussion: Analysis of a second source quality control standard referenced to the initial

calibration is an effective quality assurance control check on the integrity of the primary

standard solution and is required by the method.
49

Recommendation: The analysis of the control standard should be prepared from a

second standard source.

Finding OL2: Audit samples are not being analyzed.

Discussion: Audit samples that are prepared from a different standard source than

instrument calibration standards serve as an important independent quality assurance

technique to assess the accuracy of the data generation process. Results from audit

samples can identify out of control conditions relating to the instrument, the standards or

other problems that may not be apparent from routine instrument-generated quality

control (QC) results such as calibrations or data inspection. Documentation of

acceptable results for routine audit samples would increase the level of confidence in

data.

Recommendation: A program including the routine submission of audit samples should

be implemented. Ideally, the audit samples should be submitted double blind to the

laboratory to eliminate possible bias. Results of audit samples should be kept on control

charts. EPA may be able to assist ARB in securing resources for an audit program.

Finding OL3: Field blanks are not being analyzed. Sample results are being corrected

for background contamination based on an average background contamination of 0.3 

μg/cartridge determined from a field blank study performed by MLD 15 years ago. It is

the understanding of the audit team that field blanks have not been deployed for 15 years.

Discussion: Routine submission of field blanks is necessary to evaluate possible

contribution of contamination from sources extraneous to samples. The importance of

conducting field blank studies is heightened in light of changes observed in field

sampling technology since the background study was performed.

Recommendation: The practice of conducting field blank analysis on a routine basis

should be initiated.

Finding OL4: The laboratory is not using an internal standard method of analysis as

described by the method. The laboratory is currently using the external standard method

of standardization.

Discussion: The use of internal standards compensates for any changes occurring in the

electrical system during sample analysis and detection and, more importantly,

compensates for changes in autosampling volumes, which can vary. Internal standard

methods are more accurate than external standard methods.

Recommendation: The laboratory should use the internal standard method or evaluate

the accuracy of its data generation process through audit samples with rigorous control

ranges and consider changing to the internal standard methods based on the results.

Finding OL5: Secondary review of instrument logbooks is not being documented.
50

Discussion: Regular review of instrument logbooks by a supervisor or QA department

helps to ensure that proper analysis protocol is being followed, e.g. calibrations, blanks

analyses etc. Repeated failures or attempts to pass calibrations noted in logbooks can be

an indication that instrument maintenance or other corrective actions need to be

performed.

Recommendation: It is recommended that a system of periodic review and

documentation of review of instrument run log books be implemented and documented

with initialing the instrument run logbook.

Hexavalent Chromium by Ion Chromatography (IC)

Finding OL6: Audit samples are not being analyzed. The audit team was told that the

ARB QA Department suggested the department initiate its own system of audit sample

analysis.

Discussion: Audit samples prepared from a standard source different from the

instrument calibration provide independent quality assurance checks to assess the

accuracy of the data generation process. Results from audit sample analysis can help

identify out of control conditions relating to the instrument, the standards or other

problems that may not be apparent from routine instrument-generated quality control

results such as calibrations or data inspection. Documentation of acceptable results for

routine audit samples would increase the level of confidence in data.

Recommendation: A program including the routine submission of audit samples should

be implemented. Ideally, the audit samples should be submitted double blind (a sample

submitted in such a way that neither its composition nor its identification as a check

sample is known to the analyst) to the laboratory to eliminate possible bias. Results of

audit samples should be kept on control charts.

Finding OL7: Secondary review of instrument logbooks is not being documented.

Discussion: Regular review of instrument logbooks by a supervisor or QA department

helps to ensure that proper analysis protocol is being followed, e.g. calibrations, blanks

analyses etc. Repeated failures or attempts to pass calibrations noted in logbooks can be

an indication that instrument maintenance or other corrective actions need to be

performed.

Recommendation: A system of periodic review and documentation of review of

instrument run log books should be implemented.

Finding OL8: It is noted that the laboratory is looking into the purchase of an additional

IC instrument.
51

Discussion: The laboratory currently has one IC instrument dedicated to hexavalent

chromium analysis which it takes great care to keep in working order given the rapid

sample degradation of hexavalent chromium samples once they have been extracted. The

purchase of a second system to serve as a back up system in case of instrument failure

will help prevent the potential loss of samples through degradation.

Recommendation: The possible purchase of back up testing equipment is encouraged.

Finding OL9: Secondary review of instrument logbooks is not being documented.

Discussion: Regular review of instrument logbooks by a supervisor or QA department

helps to ensure that proper analysis protocol is being followed, e.g. calibrations, blanks

analyses, etc. Repeated failures or attempts to pass calibrations noted in logbooks can be

an indication that instrument maintenance or other corrective actions need to be

performed.

Recommendation: It is recommended that a system of periodic review and

documentation of review of instrument run log books be implemented.

Aromatic and Halogenated Hydrocarbons by Gas Chromatography/Mass

Spectrometry (GC/MS)

Finding OL10: Duplicate samples are being analyzed and presented as tabulated results

in quarterly QA reports, but control charting is only occasionally performed.

Discussion: Keeping a control chart of duplicate sample results helps to evaluate trends

as discussed and agreed to with management.

Recommendation: The laboratory may also want to consider plotting duplicate results.

Finding OL11: The GC/MS is not vented to outside the facility.

Discussion: It is normal good laboratory practice to vent GC/MS instrumentation to

outside the facility.

Recommendation: It is recommended that instrumentation be vented to outside the

facility or to traps to reduce the possibility of inhalation of contaminated air by

employees.

Finding OL12: Secondary review of instrument logbooks is not being documented.

Discussion: Regular review of instrument logbooks by a supervisor or QA department

helps to ensure that proper analysis protocol is being followed, e.g. calibrations, blanks

analyses, etc. Repeated failures or attempts to pass calibrations noted in logbooks can be
52

an indication that instrument maintenance or other corrective actions need to be

performed.

Recommendation: It is recommended that a system of periodic review and

documentation of review of instrument run log books be implemented.

Oxygenated Hydrocarbons and Nitriles

Finding OL13: Audit samples are not currently being analyzed.

Discussion: Audit samples prepared from a standard source different from the

instrument calibration provide independent quality assurance checks to assess the

accuracy of the data generation process. Results from audit sample analysis can help

identify out of control conditions relating to the instrument, the standards or other

problems that may not be apparent from routine instrument-generated quality control

(QC) results such as calibrations or data inspection. Documentation of acceptable results

for routine audit samples would increase the level of confidence in data.

Recommendation: A program including the routine submission of audit samples should

be implemented. Ideally, the audit samples should be submitted double blind to the

laboratory to eliminate possible bias. Results of audit samples should be kept on control

charts.

Finding OL14: The GC/MS Saturn D is a new instrument that was brought on-line in

April, 2007. It is being used to generate data, but an MDL study has not been performed

and documented.

Discussion: Documentation of instrument-specific MDL by studies is fundamental to the

interpretation of data with non detects is being reported.

Recommendation: Data should not be reported on instrument Saturn D until an MDL

study has been performed and documented.

Finding OL15: The MLD 066 method is based on the TO-15 method, which describes

an internal standard method of calibration. The laboratory is using an external method of

standardization; internal standards are not being used.

Discussion: Use of internal standards compensates for changes in the testing equipment

electrical system during sample analysis and detection and, perhaps more importantly,

compensates for changes in autosampling volumes which can have significant impacts on 

quantitation information. Internal standard methods are generally more accurate than

external standard methods.

Recommendation: It is recommended that the laboratory assess the accuracy of data

generated by the use of audit samples with defined quality control limits.
53

It is the understanding of the audit team from discussion with management during the

onsite visit that development of an internal standard method was initially attempted

during method development, but abandoned due to difficulty of identifying suitable

internal standards. The EPA Region may be able to offer assistance in the procurement

of audit samples and identification of suitable internal standards.

Finding OL16: Secondary review of instrument logbooks is not being documented.

Discussion: Regular review of instrument logbooks by a supervisor or QA department

helps to ensure that proper analysis protocol is being followed, e.g. calibrations, blank

analyses, etc. Repeated failures or attempts to pass calibrations noted in logbooks may be

an indication that instrument maintenance or other corrective actions need to be

performed.

Recommendation: A system of periodic review and documentation of review of

instrument run log books should be implemented.

Finding OL17: Mass calibration is performed using perfluorotributylamine (FC -43),

but confirmation that tuning abundance criteria have been met is not being verified

through the analysis of 1-bromo-4fluorobenzene (BFB). It is the understanding of the

audit team that tentatively identified compounds are not routinely being reported with this

method.

Discussion: BFB instrument tuning checks serve to ensure correct mass peak assignment

(i.e., to rule out possible mass shifts) and ion abundance ratios. Verifying that tuning and

performance criteria have been met prior to sample analysis with BFB ensures that data

produced by the instrument may be correctly interpreted and allows non target list

compounds to be tentatively identified through library search routines. In our experience,

the BFB tune also serves to monitor sensitivity as failure of the tuning check is often the

first indication of instrument sensitivity loss.

Recommendation: The FC-43 method of tuning should be acceptable as long as

tentatively identified compounds (TICs) are not reported. It is recommended the SOP be

revised to reflect that a BFB tune will be performed for special events where TICs are

reported.

Finding OL18: The GC/MS is not vented to outside the facility.

Discussion: It is good laboratory practice to vent GC/MS instrumentation to outside the

facility to reduce health risks to employees.

Recommendation: Instrumentation should be vented to outside the facility or to traps to

reduce the possibility of inhalation of contaminated air.

Canister Cleaning & Certification
54

Finding OL19: Laboratory staff stated that canisters are randomly selected for

certification testing. The staff does not consider which canisters had the highest

concentrations of contaminants in deciding which canister in a batch to test for

cleanliness certification.

Discussion: Randomly selecting canisters for certification might result over time in of

the selection of all canisters, including those most heavily contaminated, prior to

cleaning. However, some sources, such as the "Technical Assistance Document for

Sampling and Analysis of Ozone Precursors," recommend tracking the historical

contamination level of canisters and pulling canisters that contained the most highly

contaminated samples for certification. ARB staff person Steve Madden stated that he

had recommended or was planning to recommend tracking canisters to ensure that all

canisters at some point are certified through the random pull process, which would serve

a similar objective.

Recommendation: ARB should consider other options to ensure that all canisters go

through the certification process, such as tracking the canisters, or, alternatively, select

the canisters with the highest prior sample concentrations for certification.

Finding OL20: Canisters are not vented in hoods and are vented to ambient air.

Discussion: It is good laboratory practice to release sample air including ambient air in a

hood to avoid the potential for contributing to air contamination.

Recommendation: Unused sample in canisters should be released in a hood.

Finding OL21: The laboratory has not established a retention time for canisters after

they have been certified. The laboratory relies on the canister pressure gauge reading as

an indication the canisters have not lost vacuum.

Discussion: Pressure gauge monitoring after canister shipment to the field following

cleaning and certification is a good quality assurance measure for ensuring significant

vacuum loss has not occurred. Establishing a retention time policy for canisters stored at

the laboratory after they have been cleaned and certified would add additional assurance

that canisters have not become contaminated over time through smaller leaks.

Recommendation: The laboratory should establish a retention time policy for clean

canisters after which they will be re-cleaned and certified as an added quality assurance

measure. A retention time of 30 days would be reasonable. Alternatively, it is

recommended that language be included in the Quality Assurance Plan that all canisters

are used and recycled within 30 days, if this reflects workload demand.
55

DATA MANAGEMENT

Introduction

A primary goal of the U.S. Environmental Protection Agency’s Quality System is

“to ensure that environmental programs and decisions are supported by data of the type

and quality needed for their intended use...” (EPA Quality Manual for Environmental

Programs, EPA Order 5360A1 (EPA, 2000a)). Achievement of this goal involves

planning, implementation and assessment of the data collection process. Data

verification and data validation are key steps in the assessment of environmental

measurements. EPA defines data verification as the process of evaluating completeness,

correctness and compliance of a data set against the method requirements. Data

validation extends the verification process to determine the analytical quality of a data

set. As a part of this TSA, EPA evaluated the ARB’s data handling, verification,

validation, storage and upload to AQS of ambient monitoring measurements generated

from within their quality assurance system.

California has five organizational units in two different Divisions of the ARB and

26 separate Air Pollution Control Districts through which ambient monitoring data enters

EPA’s AQS database. Responsibility for managing the state’s CAA-required ambient

monitoring data is divided between the following groups:

1) ARB-Operated Field Monitoring Stations Data - Air Quality Surveillance

Branch, Ken Stroud, Manager (Monitoring & Laboratory Division)

2) Laboratory Analytical Data - Northern Laboratory Branch, Mike Poore,

Manager (Monitoring & Laboratory Division)

3) Quality Assurance Performance Audit Program Data – Quality Assurance

Section, Merrin Wright, Manager (Monitoring & Laboratory Division)

4) Special Purpose Monitoring Projects- Operations Planning and Assessment

Section, Jeff Wright, Manager (Monitoring & Laboratory Division)

5) Local District-Operated Monitoring Station Data - Air Quality Data Section,

Ron Rothacker, Manager (Planning & Technical Support Division)

6) Local District-Operated and Local District-AQS-uploaded Data - various local

Air Pollution Control Districts

The ARB has defined procedures in place for handling internal data from the time

of acquisition to the time when it is submitted to the U.S. EPA. The procedures are well

known to the principal data providers and reviewers within ARB.
56

Data Management for: ARB-Operated Field Monitoring Stations

The ambient monitoring stations operated by ARB staff directly are under the

management of Ken Stroud, Chief, Air Quality Surveillance Branch. In the branch, there

are three regional Supervisors: Deborah Popejoy (Northern), Curt Schreiber (Southern),

and Gary Zimmerman (Central). The Air Quality Specialists interviewed on June 13, 

2007 for this TSA on this section were:

Norma Montez

Joseph Cruz

Greg Frye (via conference call, 9/06/07)

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

operated and maintained by ARB are stored in data loggers and station computers. Each

station is polled hourly by modem and the data are transmitted directly to the ARB’s

central computer system in Sacramento. The computer system consists of a server

located within an ARB-owned facility and a second backup server located in a separate,

leased facility. The data are housed in the Air Quality Data Acquisition System

(AQDAS). The AQDAS (now AQDAS-2) is ARB’s primary data repository for ambient

measurements and the primary data validation tool for data obtained at ARB-operated

stations. AQDAS was developed in-house by ARB staff. Data is retained in AQDAS for

180 days by which time it has been uploaded to AQS. Once submitted to AQS, the data

is then downloaded to the ARB database Air Data Management System (ADAM).

ADAM is ARB’s official state database for ambient air quality data. Chart recorders and

data loggers located at each station provide a supplemental record for the data validation

process.

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

QA Manual Volume II contains data acquisition procedures, including instructions for

conducting the first level of data validation. For data in need of correction, the station

operator makes a notation on the data logger or chart recorder at the station. The

AQDAS has data verification and validation capability to aid flagging of suspect data.

Flags that are generated by station operators or information describing the data being

processed are included in the database. Data corrections are reviewed and validated by

the Section Specialist who approves all data corrections and recommends implementation

of corrections. The data stream then proceeds to the next level of review by the section

supervisor.

At this point in the process, a final data validation summary is produced. The

monthly data report is sent to the Branch Chief for approval. Once approved, the data are

stored in the State archive system and submitted to the U.S. EPA’s AQS database.

The Air Quality Surveillance Branch (AQSB) Section Specialists, responsible for

upload of the ARB-collected ambient data to EPA’s AQS database, have all the relevant

and up-to-date AQS manuals.
57

Little or no data would be lost in the event of significant computer problems due

to the redundant data backup systems maintained at the air monitoring stations and on the

two computer system servers.

ARB does utilize a flagging system to identify data outside of expected levels and

anomalous flow-rate changes. This flagging system is not formally documented in a

control-copied SOP. The second level review process relies on the AQDA protocol to

provide corrective actions in the system.

Second-level review for all stations is carried out by Section Specialists, Norma

Montez and Joseph Cruz. Following the second level review and any corrections to data,

the section supervisor reviews data from their stations on a monthly basis and Ken Stroud

signs off on the data and approves data package for upload to AQS by Norma Montez.

ARB submits all required data to the U.S. EPA's AQS database, including

concentrations for all criteria pollutants, and supporting precision and accuracy

information.

Data Management: Laboratory Analytical Methods

Among its many responsibilities within the ARB organization, the Northern

Laboratory Branch is responsible for mass determinations for PM2.5 and PM10, chemical

speciation analysis, air toxics analysis and VOC and carbonyl analysis according to the

PAMS program-required sampling methods. The Northern Laboratory Branch is located

in Sacramento and is managed by Mike Poore.

Staff and managers from the laboratory interviewed on June 13, 2007 for the data

management section of this report included:

Mike Poore

Kathy Gill

Dan Tackett

Samantha Scola

W. Howard Bakes

Sean S. Roy

All lab analyses are stored in the ARB’s Laboratory Information Management

System (LIMS). The original LIMS was a product purchased from Perkin-Elmer, but the

system has had many modifications to customize it for use by ARB over the years.

The LIMS database is housed in the Monitoring and Laboratory Division and is

backed up once per week to tape. It is accessed by all chemists and managers. The

system makes use of limited access and password-protection for security. The raw data

in the system is stored for five years. Data from the LIMS is uploaded to the AQS

database by Samantha Scola and Sean Roy on a weekly basis.
58

Data flow in the laboratory begins with the chemist running the analytical method

and generating measurement data (gravimetric or chemical analysis). Data goes from the

analytical instrument to the LIMS. LIMS assigns QC flags as defined by ARB SOPs.

All data are subjected to peer review for level two data validation, which is followed by

reviewing and ‘locking’ of the data by lab managers. Data peer-review groups are

organized around the analytical methods: PM10, PM2.5, PM2.5 speciation, TSP-lead. The

QC criteria as written in the laboratory and analytical methods are used for data

validation.

Data Management: Quality Assurance Performance Evaluation Audit

The Quality Assurance Section in the Monitoring and Laboratories Division

conducts performance evaluation audits and technical system audits at ambient air

monitoring stations throughout the state. Performance audits are conducted annually of

each local air pollution control district for gaseous criteria pollutant monitoring and

particulate matter monitoring flow audits. The results of the audits are maintained online

on the ARB website and are also uploaded to AQS in most cases. In some instances, the

ARB has not received update rights to some local District’s screening files in AQS.

EPA conducts an annual intercomparison with the ARB audit vehicles to ensure

comparability with EPA’s National Performance Audit Program (NPAP) and

Performance Evaluation Program (PEP).

Data Management: Special Purpose Monitoring

The Operations Planning and Assessment Section, which is located within the

Quality Management Branch of the Monitoring and Laboratory Division, conducts

special purpose monitoring projects on an as-needed basis. This section is responsible for

covering emerging issues in air monitoring. In most cases the measurement data are

uploaded to AQS.

EPA was not given access to interview staff in this section about data

management practices.

Data Management: Local-District-collected/ARB-Uploaded-to-AQS

The Air Quality Data Section, of the Air Quality Data Branch in the Planning and

Technical Support Division, is the organization responsible for uploading ARB’s

continuous particulate matter data and all meteorology data to AQS. In addition, the

AQDS also uploads data from those local Districts that submit only hardcopy data and

the gaseous criteria pollutant monitoring data from local Districts without direct access to

AQS. The AQDS is located in Sacramento and is managed by Ron Rothacker.
59

The individual staff members interviewed on July 19, 2007 about data managed

by AQDS were:

Karen Magliano, Manager, Air Quality Data Branch

Ron Rothacker, Manager, Air Quality Data Section

Pheng Lee, Air Pollution Specialist

Data is received electronically by email or as hard copy through the mail from 10 

different local Districts.

One of the AQDS’ primary functions is to review and upload hourly data

produced at ARB monitoring sites and data submitted by local Districts without direct

access into AQS (Glenn County APCD, Lake County AQMD, Mendocino County

APCD, Northern Sonoma APCD, Placer County APCD, Sacramento Metropolitan

AQMD, Shasta County AQMD, Siskiyou County APCD, Tehama County APCD and

Yolo-Solano AQMD). The type of data uploaded for these Districts include gaseous

criteria pollutant, continuous particulate matter and meteorological data.

Air Quality Data Action (AQDA) reports based upon performance audits are

produced by QAS. These reports are provided to the Districts for follow up within 30 

days and to AQDS to inform them of data requiring attention by the Districts. The

Districts must respond within 30 days. If the response is acceptable to QAS, the AQDA

is completed, signed, dated, and forwarded to the AQDS for appropriate action, i.e., data

correction, acceptance, or deletion for the affected time period. No changes are made to

District data without their knowledge and consent. Further follow-up is performed by

QAS if deficiencies remain.

A User’s Guide (manual) was developed by AQDS providing instructions on data

receipt and input into AQS. The data checks performed by AQDS are primarily for

historical highs, duplicate data and to ensure a monitor is defined in AQS.

Data Management: Local District-Collected/Uploaded-to-AQS

The local Districts reviewed as part of this TSA include Northern Sierra AQMD,

San Joaquin Valley APCD and Great Basin Unified APCD.

The reporting of data into AQS by local Districts was agreed upon by District

specific Memorandums of Understanding that were signed by the Districts, the ARB and

U.S. EPA in 2002. The level of QA data review performed by the GBUAPCD is

extensive and documented in the District’s QAPPs. The SJVAPCD has developed its

own data review and validation procedures for the data it uploads to AQS. NSAQMD

reviews and submits data to AQS but does not have written procedures in place.
60

Based on interviews of the AQDS staff, it is clear that they are not familiar with

the QA/QC review practices performed in the Districts and whether those practices are in

compliance with ARB’s practices.

FINDINGS

Finding DM1: The data validation and review/verification procedures for the Air

Quality Surveillance Branch are not formally published in a control-copied SOP.

Discussion: 40CFR Part 58 Appendix A Section 3.1.1 states that “Each primary quality

assurance organization shall be defined such that measurement uncertainty among all

stations in the organization can be expected to be reasonably homogeneous, as a result of

common factors. Common factors....include use of a common QAPP or standard

operating procedures”.

Recommendation: Develop control-copied SOPs for the data validation and

review/verification procedures in the AQSB.

Finding DM2: The data validation and data review/verification procedures for the

Northern Laboratory Branch are not formally published in control-copied SOPs.

Discussion: 40CFR Part 58 Appendix A Section 3.1.1 states that “Each primary quality

assurance organization shall be defined such that measurement uncertainty among all

stations in the organization can be expected to be reasonably homogeneous, as a result of

common factors. Common factors....include use of a common QAPP or standard

operating procedures”.

Recommendation: Develop control-copied SOPs for the data validation and

review/verification procedures in the NLB.

Finding DM3: The data validation and data review/verification procedures for the Air

Quality Data Section are not formally published in a control-copied SOP.

Discussion: 40CFR Part 58 Appendix A Section 3.1.1 states that “Each primary quality

assurance organization shall be defined such that measurement uncertainty among all

stations in the organization can be expected to be reasonably homogeneous, as a result of

common factors. Common factors....include use of a common QAPP or standard

operating procedures”.

Recommendation: Develop control-copied SOPs for the data validation and

review/verification procedures in the AQDS.

Finding DM4: EPA was not given access to special projects data management activities

to review. It is not clear that QA procedures are being applied to all projects receiving

federal funding.
61

Discussion: EPA requires organizations that receive Federal funding to collect and

produce environmental data to establish QAPPs that include data verification and

validation procedures. The purpose of the QAPP is to ensure the data produced is of

known and documented quality that can be used for its intended purpose. This applies to

special purpose monitoring as well as SLAMS, PAMS and NCORE monitoring.

Recommendation: EPA should be given access to review data validation and

verification procedures for special purpose monitoring projects.

Finding DM5: The AQDS does not ensure that local District data are validated prior to

upload to AQS.

Discussion: At the NSAQMD, automated instrument outputs are telemetered to the

District office. The monitoring manager reviews the ozone data and then submits these

data directly to AQS with no additional QA checks.

Recommendation: ARB should ensure that all local Districts having the responsibility

for submitting data directly to AQS follow consistent procedures for reviewing and

validating data before it is submitted to AQS.

Finding DM6: Ambient monitoring data submitted to the AQS database by the ARB

PQAO is not being certified annually.

Discussion: 40 CFR Part 58.15 requires data to be certified by a specific date i.e.,

coincident with annual summary report which, until 2009, is due by July 1 of each year;

beginning in 2010, the annual data certification letter is due by May 1 of each year.

Since the data are considered certified, official, and not subject to change after submittal

of the certification letter, changing data at a later date is a significant concern, as the

expectation is that the data will not change and may be used for attainment and decision

making purposes. Data verification should take place before upload to AQS, not after,

when it has the potential to impact numerous decisions already made by several

organizations.

Recommendation: All data changes and certification should take place consistent with

deadlines established in Part 58.15.

Finding DM7: ARB does not review GBUAPCD’s data prior to its being uploaded to

AQS.

Discussion: ARB does not review the monitoring data from the GBUAPCD’s network.

Recommendation: See Finding GB1.

Finding DM8: Annual certification of the GBUAPCD’s monitoring data in AQS is not

being done.
62

Discussion: The certification of ambient monitoring data in AQS by the air pollution

control official responsible is required to be performed on an annual basis. Review of

the database from 2000-2006 shows no annual certifications in AQS.

Recommendation: GBUAPCD should submit the annual certification letter and

required AMP350 and AMP450 reports from AQS to EPA Region 9. 

Finding DM9: Valid concentration data for the Yreka PM2.5 monitor (AQS# 06-093-

2001) have not been submitted to the AQS database since December 2006.

Discussion: Based on the null value codes in the AQS database, it appears that this

monitor began malfunctioning in November 2006. No data were submitted to AQS from

December 13, 2006 through July 2007. Null value codes of "machine malfunction" and

"scheduled but not collected" were entered into AQS during this period. While this

monitor is not required under EPA regulations, the ARB has designated it as a SLAMS

site. SLAMS sites should meet a data capture rate of 75%.

Recommendation: The ARB should work with the Siskiyou County APCD to

determine the reason for the poor data capture at this monitoring site and implement

appropriate corrective actions to ensure a data capture rate of at least 75%.

Finding DM10: The AQS database identifies the Siskiyou County APCD as its own

PQAO.

Discussion: Two sites in Siskiyou County, Mount Shasta (AQS# 06-093-0004) and Lava

Beds National Monument (AQS# 06-093-0005) are listed as being part of the Siskiyou

County PQAO. According to the ARB 2007 S&L Monitoring Network Plan, Mount

Shasta is operated by Siskiyou County APCD; therefore, it should be listed as part of the

ARB PQAO. Lava Beds National Monument is operated by the National Park Service.

Depending on the how this monitor is being operated, whether it is audited by ARB and

which laboratory performs the mass analysis of filters, this monitor's PQAO association

should be verified.

Recommendation: The ARB should work with EPA to ensure that the monitors in the

ARB PQAO are correctly identified in the AQS database.

Finding DM11: The Lakeport PM10 site has not reported PM10 data correctly to AQS

since March 2001.

Discussion: Beginning in April 2001, PM10 data from the Lakeport monitoring site

(AQS# 06-033-3001) have been submitted to the AQS database under the local condition

parameter (AQS code 85101) rather than under the standard Temperature and Pressure

parameter (AQS code 81102). The PM10 NAAQS requires that data be adjusted to

Standard Temperature and Pressure conditions (See 40 CFR 50, Appendix J, section 11).
63

Recommendation: The ARB PQAO should ensure that PM10 data are submitted to the

AQS database under the appropriate parameter codes. The ARB should review the PM10

data from the Lakeport monitoring site to determine if PM10 data at local conditions were

correctly submitted to the AQS database. If this is not the case, the PM10 concentrations

will need to be recalculated according to the procedures in 40 CFR 50, Appendix J and

resubmitted to AQS under the correct parameter code. Alternatively, the data in AQS

may already have been corrected to Standard Temperature and Pressure and simply

incorrectly submitted under the wrong AQS parameter code.
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QUALITY ASSURANCE

Introduction

The Quality Management Branch (QMB) is composed of two sections: the

Quality Assurance Section (QAS) and Operations Planning and Assessment (OPA). The

ARB’s Standards Laboratory is part of the QAS. EPA auditors interviewed Jeff Cook,

QMB manager, Merrin Wright, Manager of the Quality Assurance Section (QAS) and

Donald Fitzell and Long Liu of her staff, Brian Spreadborough and Robert Russell,

leaders of the Standards Laboratory, and Jeff Wright, manager of the OPA Section and

Don Hammond of his staff.

The QAS’s primary responsibilities include:

• Conducting performance audits of ARB-MLD and District monitoring

instruments;

• Assessing air monitoring laboratories' capabilities periodically through analysis of

interlaboratory standards or whole air samples (these are sent to all California

Photochemical Assessment Monitoring laboratories. Other laboratories that

perform hydrocarbon analyses may also choose to participate.);

• Assisting with system audits of California air districts;

• Updating standard operating procedures (SOPs) specific to the QAS’s activities;

• Validating ARB-MLD’s field generated monitoring data (accuracy assessments);

• Preparing annual reports on the status of QA activities occurring in ARB-MLD;

• Preparing data quality summary reports for Reporting Organizations and Districts

in California.

The Standards Laboratory provides standards certifications for gaseous and flow

transfer standards. Standards certifications are performed for all ARB-MLD Sections’

gaseous and flow transfer standards. Some California Districts also choose to employ

these services.

The OPA section is responsible for Board-wide oversight, including review of

MLD laboratory performance to ensure defensible laboratory data and oversight of and

planning for special purpose monitoring.

QA-related functions are also performed by the Air Quality Surveillance Branch’s

(AQSB) Operations Support Section (OSS) and Northern Laboratory Branch (NLB), both

of which are located within the Monitoring and Laboratory Division. The Planning and

Technical Support Division (PTSD) also has a QA role in reviewing ambient data

collected by ARB-MLD and some Districts and works with QAS to ensure that only

validated data are reported to EPA's Air Quality Subsystem (AQS) database.

The AQSB performs several quality management functions. These include:
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• Developing and administering the training program for instrument operators;

• Performing instrument certifications;

• Validating ARB-MLD’s field generated monitoring data (precision assessments);

• Maintaining a system for formal corrective actions;

• Preparing and reviewing SOPs for the air monitoring program.

Training and instrument certifications are the responsibilities of the Operations

Support Section (OSS) within AQSB. The OSS also provides independent review and

approval of field SOPs. OSS's other responsibilities includes instrument repair and

technical support. However, while support (training, field procedures, and other

technical support) is available to the all local Districts in California, the AQSB’s role is

not to actively manage the Districts’ field monitoring quality systems nor does the AQSB

have the resources to do so.

The Northern Laboratory Branch develops laboratory and ambient air collection

test procedures, performs near-source ambient air monitoring, conducts analyses of

ambient air samples and consumer products, and provides technical assistance to clients.

The lab performs self assessments each quarter and produces a quality control summary

report that is provided to the Division chief.

As observed and confirmed during interviews, QA related functions are

incorporated throughout the ARB’s air monitoring operations. However, since the QA

activities and responsibilities are spread among different offices and branches within the

ARB, it is difficult for the QA activities to be coordinated by the QMB and, based on 

EPA’s interviews with QMB staff, the scope and organization of these various QA

activities is not fully understood by the QMB. The efficiency of the existing

decentralized system could be improved if the QMB or another entity took a more of a

leadership role. For example, internal checks conducted by QAS do not require written

corrective action responses (Performance audit dated June 7, 2007, Ambient Air Toxics

Laboratory Comparison Check Results). QMB’s authority is diminished when no 

corrective action response is required. With the exception of Air Quality Data Action

(AQDA) forms that are issued primarily out of the QAS and the technical bulletins from

the AQSB, corrective action documentation was not sufficient. Minimally,

recommendations for corrective action and responses to them should be addressed in

writing.

An example of an activity that would be improved by better coordination is the

guest instrument certification/calibration procedure. Currently, when a guest instrument

fails a calibration of certification, the Standards Laboratory is not required to report this

failure to the ARB field auditors or the ARB data reviewers. If this procedure were

revised to require the reporting of the results of the certification/calibration procedure, the

QAS and AQSB would be able to address the consequences of these failures. For

example, this information would be useful to the QAS during future instrument

performance audits and to AQSB for determining whether data produced prior to failure

should be rejected or more closely reviewed.
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The QMB staff is not aware of the extent to which QA activities are performed in

the Districts. The Districts in the ARB PQAO are expected to follow ARB-MLD’s

Quality Assurance Plan (QAP). No records of regular system audits to ensure that the

Districts were in conformance with the plan were available. See Finding QA3 below.

In order to determine the effectiveness and efficiency of the ARB’s QA system, a

regular schedule of system audits by QMB, or other centralized quality management

entity, of the ARB and local district ambient air monitoring programs is recommended

for capturing deviations from the ARB QA plan and to insure ongoing quality

improvement.

The ARB has all the necessary components for an effective and robust QA

system. Each Division involved in the collection and reporting of ambient air data

understands and performs QA. A “QMP-like” document is already in place to ensure

QA/QC practices are followed or improved upon, and the QMB is in a position to

potentially provide an authoritative oversight role.

General Quality Management

Finding QM1: The MLD does not have central, independent authority in the

organization to provide direction and recommendations to the data collection, production,

and verification programs.

Discussion: Although QMB is independent and centrally situated in the ARB’s

organization chart, the Branches appear to be self directed in the QA they perform.

Functionally, in addition to QMB, QA is performed in the Northern Laboratory Branch,

Air Quality Surveillance Branch and its Operations Support Section. QMB has attempted

to perform QA oversight and there are some records of reviews (e.g., performance audits

of the Northern and Southern Laboratory Branch, whole air interlaboratory comparison

checks). No records in response to QAS reports were available and it was noted by QAS

that report recipients only need to consider recommendations made by them; there is no 

requirement that recipients respond in writing. The lack of centralized quality

management authority and Branches acting independently of one another does not result

in an effective quality assurance program for the organization. If this continues to be the

case, 40 CFR Part 58, Appendix A, Section 2.2, requires that each ambient air monitoring

organization have an independent quality assurance function that is responsible for the

effective implementation of the overall quality assurance operations of the organization.

Recommendation: Empower a central, independent quality management authority

coordinated within MLD to work in the PQAO (ARB and Districts) to ensure the

production of quality data. Its role should be to establish a unified, structured,

comprehensive QA program in the ARB that includes overseeing (approving) the QA/QC

activities conducted in the field, information management, and laboratory operations.
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To fully implement such a program, internal audits should be conducted to capture any

deviations from ARB and EPA QA requirements not addressed in this report. This would

enable the ARB to develop and administer a comprehensive QA system that is not

independently operated in the Branches and Districts, but led by the MLD. Based on this

self assessment, training programs should be developed. Communication channels

should also be evaluated to ensure efficient exchange of QA related information (e.g.,

information concerning changes in EPA’s monitoring regulations) and that matters raised

are acted upon and responded to in a timely manner.

The authority and responsibilities of the central, independent QA authority should

include the provision for effective training, technical assistance and guidance such as

developing quality assurance project plans and standard operating procedures, data

collection plan approvals, and the performance of self assessments and audits of

Branches, Divisions, and Districts involved in data collection, production, or verification.

Finding QM2: Training, while in place for the ARB MLD, does not necessarily extend

to all staff and the ARB PQAO Districts. See also Finding M1.

Discussion: The QAS and the AQSB (through the OSS) have implemented training

programs, which are in place but still being refined. These programs are very beneficial

and EPA encourages the ARB MLD to continue these programs as well as other training

programs in place. It would be more efficient, however, to coordinate a central training

and evaluation program that represents the entire PQAO to ensure that all monitoring

staff receive adequate and consistent QA training.

Recommendation: The ARB should ensure that the AQSB and QAS coordinate their

training programs. One way to achieve this is to develop a centrally administered

training program that includes both operations and QA activities.

Finding QM3: Some Districts do not have a central, independent, dedicated quality

assurance manager/officer responsible for communicating and ensuring that quality

assurance activities are carried out in field operations and information management.

Discussion: Two of the Districts evaluated as part of this TSA, the San Joaquin Valley

APCD and the Northern Sierra AQMD, have no staff assigned to perform QA oversight

of their operations. In 40 CFR, Part 58, Appendix A, Section 2.2, it is stated that each

ambient air monitoring organization must have an independent quality assurance

function. While the ARB performs some functions, such as the annual certification of the

ozone standard and flow audits, there are many QA functions not being performed.

These include periodic audits of the quality management system (management system

reviews); data quality reviews to identify areas of improvement and to ensure that

documented procedures are being followed in monitoring programs; and the routine

review and tracking of precision and accuracy data.

Recommendation: The ARB needs to perform an evaluation of District QA

management activities. Some Districts, such as Great Basin Unified APCD, perform
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their own QA management activities and would require only periodic assessments to

ensure they continue to meet the ARB and EPA QA requirements. Other Districts

programs will need the ARB to play a more active role in QA management.

QA Section

Finding QA1: The QAS does not assure that sites that fail performance audits are retested after a corrective action is implemented.

Discussion: The QAS makes an effort to re-test sites based on their field schedule. In

practice sites that are far from the Sacramento office do not get retested because it is

prohibitively labor and resource intensive.

Recommendation: The QAS should establish criteria for retesting based on the need for

the data and/or develop an alternative to sending the audit trailer based system to retest

sites.

Finding QA2: The QAS has experienced a high staff turnover in recent years, which has

impacted the level of institutional knowledge in the section and impacted its ability to

perform audits.

Discussion: The QAS has responsibility for performance and site audits across the ARB

PQAO. This is a critically important part of the quality assurance program. Additionally,

when instrument and site problems are encountered during the audits, staff that has

detailed knowledge of air monitoring operation across a diverse range of equipment is

required to correct the situation. The retention of staff with this knowledge base within

the QAS helps to correct problems encountered conducting audits; to determine the cause

of audit failures; to evaluate siting and instrument configuration issues; and to evaluate

the site operator’s ability to correct deficiencies needed for re-testing sites.

Some audits have been canceled due to a lack of trained staff to perform them.

Recommendation: The ARB MLD needs to develop a plan to reduce turnover in QA

audit staff and/or attract more senior staff to the QA Section.

Finding QA3: System audits of local Districts by QAS and the Stationary Source

Division are only conducted by request or on an as needed basis.

Discussion: The frequency for performing system audits are documented on

www.arb.ca.gov/audits/schedule.pdf. However, upon review of ARB-MLD’s Annual

Data Quality Report and the interview, system audits are performed only by request or on 

an as needed basis. The program areas reviewed during these audits do not fall within

EPA’s definition of complete system audits, focusing solely on program elements

(compliance, permitting, rule development, hot spots, emission inventory, and ambient
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air programs) The QAS audit checklist does include both program and QA elements.

Both areas should be reviewed.

Recommendation: Future system audits should be performed as identified on the ARBMLD’s website cited above. The audits should be inclusive of both program and QA

activities reviewed and conducted using ARB-MLD’s Audit procedures contained in

Volume V, Appendix AH3.0, System Audit Procedures for Ambient Air Monitoring

Programs, August 2002.

Finding QA4: ARB MLD does not perform routine audits of data quality.

Discussion: EPA QA/R-5, EPA Requirement for Quality Assurance Project Plans,

discusses assessments that should be elements of a quality management program. These

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

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

assessments.” Audits of data quality include periodic checks of a small portion of the

data produced to ensure that the data set was collected as specified by regulations and the

QA planning documents. It should include the appropriate supporting documentation,

verify that all supporting data calculations were correct, and evaluate whether the

validation was properly performed.

Recommendation: ARB should develop a schedule and procedure for conducting audits

of data quality.

Finding QA5: Internal audits are not conducted on ARB-MLD’s and Districts data

management, reduction and review process.

Discussion: Results of reviews for both ARB-MLD and District produced data are

reported into the AQS database. It is important that QAS develop procedures for

conducting internal audits of ARB-MLD and Districts data reduction and review to

ensure that the process is performed properly; to ensure that the quality of data for both

ARB-MLD and District data is verified and known when submitted to the AQS database;

and to ensure results reported to the AQS database can be used by those accessing the

information.

Recommendation: Internal audits should be conducted as soon as possible, and on a

scheduled frequency. SOPs should be developed for conducting internal audits of ARBMLD’s and Districts data management, reduction and review process.

Finding QA6: The ARB’s MLD does not routinely conduct monthly (day-to-day)

checks of all the precision and accuracy of data being uploaded by the local Districts to

the AQS database.

Discussion: It is commendable that the ARB-MLD produces annual reports for precision

(nightly zero and span for gases and flow rates for particulate matter) and accuracy

reports combining ARB-MLD and District sites. While the ARB does perform this
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monthly check for those Districts that request it, data are being uploaded to the AQS

database that have not been reviewed. Since the annual precision and accuracy (P&A)

report by the ARB-MLD occurs after all the data from the ARB PQAO sites are reported

to AQS, the pooling and averaging of data collected over a year may smooth out or mask

any P&A criteria failures specific to a site

Recommendation: As the primary quality assurance organization, the ARB-MLD,

should develop SOPs to include day-to-day check routines for District-produced data.

The “script” for performing these checks can be provided to Districts for incorporation

into their data review computer program to enable the process to be automated. This is to

ensure that all of the daily data reported to AQS meet the precision and accuracy criteria

established at 40 CFR Part 58, Appendix A, Section 2.3, and that precision and accuracy

reporting is performed consistently throughout the organizations that comprise the

PQAO.

It is further recommended that standard operating procedures be developed for

performing these precision and accuracy checks on a monthly basis. These SOPs should

include a step to check results of the annual performance audits against daily precision

and accuracy results of the station for agreement, and should designate the personnel

responsible for doing so. Procedures for qualifying data and reporting to QAS should be

developed.

Finding QA7: The ARB Reporting Organization (RO)9is not able to access the AQS

accounts of Districts that are part of the ARB PQAO but serve as their own RO for the

purposes of uploading data to the EPA AQS database.

Discussion: Each RO must be consulted to obtain permission to submit data for the sites

operated by the RO to the AQS database. The MLD QA Section and others involved in

central PQAO activities has not been able to gain access to the screening files that would

allow them to submit data to the AQS database for dependent ROs. For a PQAO to

function properly, the central QA and Data managers need to be able to access all the

relevant data files in the AQS database.

Recommendation: Over the short term, ARB should work with the ROs in the ARB

PQAO to facilitate obtaining access. Over the long term, EPA Region 9 can work with

OAQPS to develop AQS access procedures, consistent with data quality objectives, for

PQAO’s with multiple ROs.

9

 EPA defines a “Reporting Organization” as an agency that has editing rights for a subset of monitors

reporting data to EPA’s AQS database. The reporting organization associated with a subset of monitors is

the only organization that can upload data to the AQS database for those monitors, though other AQS users

have read-only rights to the data.
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Standards Laboratory

The MLD’s Standards Laboratory is part of the QAS. EPA staff evaluated the

Standards Laboratory’s primary pollutant operations on June 26 and its operations

involving the verification of flow measurement devices on August 2, 2007. Individuals

interviewed during the audit were Brian Spreadborough and Robert Russell. Mr.

Spreadborough leads the ozone primary and transfer standards lab. Mr. Robert Russell

leads the primary and transfer standard laboratory for certification and verification of

gaseous criteria pollutants, particulate matter, toxic air contaminants and hydrocarbon

pollutants. Mr. Russell and Mr. Spreadborough can perform one another’s respective

responsibilities. They also oversee two student interns, Trisha San Juan and Nick Barker,

who perform flow calibrations on an as needed basis. Both Mr. Russell and Mr.

Spreadborough perform a final check of results of each other’s work before it is released.

Hard copy and electronic records of the calibrations and verifications are maintained in

the Standards Laboratory.

The Standards Laboratory performs verifications of ozone and flow rate primary

standards, calibrations and certifications of ozone and flow transfer standards, and

certification of compressed gas cylinders. NIST traceable standard and certified

reference materials are used to certify primary and transfer flow standards for the ARB

and Districts which submit their standards for certification and verification. Traceability

is defined in 40CFR Parts 50 and 58 as meaning “. . . that a local standard has been

compared and certified, either directly or via not more than one intermediate standard, to

a primary standard such as a National Institute of Standards and Technology Standard

Reference Material (NIST SRM or a EPA/NIST-approved Certified Reference Material

(CRM). The Standards Laboratory performs calibration and certification for gaseous

criteria pollutants and particulate matter for the following districts:

• Bay Area AQMD

• Great Basin Unified APCD

• Lake County AQMD

• Mendocino County APCD

• Monterey Bay Unified APCD

• Northern Sonoma County APCD

• Placer County APCD

• Sacramento Metroploitan AQMD

• San Diego County APCD

• San Luis Obispo County APCD

• Santa Barbara County APCD

• Shasta County AQMD

• Siskiyou County APCD

• Tehama County APCD

• Ventura County APCD

• Yolo/Solano AQMD
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The flow standards are received by the Standards Laboratory either directly (hand

carried in), by mail, or by courier. The standards are signed in, certification or calibration

performed on a first come, first served basis, with a turnaround time of up to three weeks.

The following must be satisfied for calibration, certification, or verification:

Ozone

Certification of transfer standards requires six acceptable comparisons against the

EPA/NIST Standard Reference Photometer (SRP). Each comparison must have a

correlation coefficient of 0.9999 or greater, each slope must be within 5 percent of the

expected value, and each intercept must be less than 3 ppb ozone. A certification is valid

if the six most recent comparisons have a Relative Standard Deviation (RSD) of less than

1.5% for the slope and a Full Scale Relative Standard Deviation (FRSD) less than 0.5 

percent for the intercept. For re-certifications, the current comparison’s slope must be

within 1 percent of the most recent comparison’s slope, otherwise, another comparison

must be performed to verify the change. The certified slope and intercept is the average

of each of the six comparisons and should be used by the client to correct or adjust the

instrument’s displayed ozone concentration. EPA requires reproducibility of 2 times the

coefficient of variation (40 CFR Part 50, App B, Section 7.8.3)

Verification of an ozone primary standard consists of one acceptable comparison

against the SRP that is maintained by the ARB. For the verification to be valid, the linear

regression must have a correlation coefficient of 0.9999 or greater, the slope must be

within 3 percent of the expected value, and the intercept must be less than 3 parts per

billion (ppb) ozone.

Low-Volume Flows (0.005 to 50 lpm)

Prior to calibrating or verifying the guest device under test (GDUT) instrument, a

calibration check is performed by the Standards Laboratory to ensure the primary flow

standard instrument is within the ARB’s specifications. These checks include: leak

check, tare value is stable (zeroed), and temperature. Upon satisfactory check, they

commence with the calibration or verification of the GDUT and electronically capture the

output on the display panel of the GDUT. Results are read directly off the GDUT display

panel and entered into an electronic database system (DBASE). Access to the database

system is password protected and limited to Mr. Russell and Mr. Spreadborough. It was

noted that DBASE would soon be updated.

A calibration consists of one comparison against a primary flow calibrator. The

comparison must have a linear regression with a correlation coefficient of 0.9999 or

greater. The derived slope and intercept should be used by the client to correct or the

instrument’s displayed flow rate adjusted.

Certifications require four consecutive comparisons against a primary flow

calibrator. Primary flow calibrators should be alternated for each comparison. Each

comparison must have a linear regression with a correlation coefficient of 0.9999 or
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greater. A certification or recertification is valid if the four most recent comparisons

have a RSD less than 1 percent for the slope and FRSD less than 1 percent for the

intercept. For recertification’s, the current comparison slope must be within 1 percent of

the most recent comparison slope, otherwise, another comparison must be performed to

verify the change. The certified slope and intercept is the average of each for the four

comparisons and should be used by the client to correct or adjust the instrument’s

displayed flow rate.

Verifications consist of one multi-point comparison against one of two primary

flow calibrators: Molbox/MolblocA or Molbox/MolblocB Flow Calibrator. For a

verification to be valid, the linear regression of the comparison must have a correlation

coefficient of 0.9999 or greater, the slope must be within 3 percent of the expected value,

and the intercept must be less than 1 percent (full scale) from the calibrator’s intercept.

High Volume Flows (566 to 2,360 lpm) for Particulate Matter

Certifications of high volume flows are performed with a Rootsmeter that is

certified every two years by the original manufacturer. A certification or recertification is

valid if the two most recent comparisons have a RSD less than 0.7 percent for the slope

and intercept. In order for each comparison to be valid, all the points in the assay must be

within 2 percent of the regression line. The certified slope and intercept is the average of

each for the two comparisons. A slope and intercept is provided to determine both the

Actual Flow (Qa) and Standard Flow (Qstd). EPA’s acceptance criteria is +/-2% of NIST

traceable standard, 40 CFR Part 50, App. L, Section 9.1, 9.2 

The flow standard for particulate matter is recalibrated in-house with a NIST

certified primary standard #7 provided by EPA. For a calibration to be satisfactory, the

assay must have a correlation coefficient of better than 0.9999. Slope RSD % compared

to the previous assay must be less than 0.7 %. Intercept FRSD % compared to the

previous assay must also be less than 0.7 %. Results are discussed with EPA and upon 

satisfactory determination, a recertification is issued to ARB.

In-House Certification checks.

Gaseous flow evaluations are performed on a quarterly basis by the Standards

Laboratory. These evaluations are referenced to a primary NIST traceable flow device.

Eight molbox performance are checked using five different flow rates comprising the full

calibration scale. The molbox performance is also cross checked against the others on an

alternating cycle. The results from each level tested are pooled and averaged with the

prior three quarterly calibrations and correlation coefficient (CC) determined. For flow

transfer standards, the relative standard deviation for the slope must be less than 1 percent

and the intercept divided by full scale reading x 100 percent must be less than 1 percent

for the last four calibrations.

The criteria used by the Standards Lab are more stringent than those required by

EPA in 40 CFR Part 50 (varies between 1 and 2% for flow controllers and meters,
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respectively). Any deviation from criteria is monitored and retested on the following

day. If there is a shift that not meet criteria, the primary standard is sent for recalibration

and recertification by DH Instruments. A significant shift was determined in November

of 2004 on two molboxes where the flow standard was sent to DH Instruments for

recalibration. Upon its return, a verification check was performed. The instrument was

still found to be out of criteria bounds and was resubmitted to DH Instruments. The

Standard Laboratory’s verification check of DH Instruments calibration for this period

was not available for review. It was stated by the Standard Laboratory manager that this

would be prepared in the future.

The molbox flow transfer standards are sent out to DH Instruments on an annual

or more frequent basis when degradation in instrument performance is observed, as

required in 40 CFR Part 50, Appendix L, Section 9.2.2.

Finding SL1: There is no procedure in place to notify Quality Assurance or Field Audit

staff of failure, i.e., the potential that data from the period prior to the current calibration

check might be rejected if transfer and flow standards fail calibration.

Discussion: The Standards Laboratory notifies the guest (ARB site manager or District)

of failure, and that the failure must be remedied prior to resubmission of standards. The

same notice can be provided to Quality Assurance and Field Audit staff.

. 

Recommendation: A reporting mechanism should be developed to communicate

calibration/verification failures to Quality Assurance and Field Audit staff. Similarly

QAS should develop procedures as to how to evaluate and address data produced prior to

the determination of failure.

Finding SL2: The thermometer in the Standards Laboratory needs to be verified with

another NIST traceable standard.

Discussion: While the calibration certification noted that the thermometer once

calibrated does not require recalibration, verification is recommended to occur on a

scheduled frequency e.g., annually. Annual calibration is suggested as this is the required

frequency for standards. This is to ensure temperature recordings are accurate

Recommended: Verify the thermometer against a NIST traceable standard on an annual

basis when other instrumentation is recertified or recalibrated.

Finding SL3: There is insufficient documentation in logbook entries in the ozone

Standards Laboratory.

Discussion: Accurate and complete recording of logbook entries is essential if the

logbook is to support quality assurance information. Some logbook entries were

incomplete. For example, the only record of zero and span was found on the chart

recorder. Documentation should include analyzer identification, date, calibration

standard used and its traceability, identification of calibration equipment used, the
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individual conducting the span calibration, the unadjusted zero and drift span responses,

the adjusted zero and span responses, calibration equation(s) (and curve, if prepared).

Quality control charts help to graphically record and track calibration results (see

comment 5 below). Zero and span documentation should be maintained in a central file

and at the monitoring site. The Instrument certification and maintenance log also had

information gaps, for example entries had no staff names associated with them from 1989 

to present.

Recommendation: Complete and full descriptions of what was performed, by whom,

when, etc. should be documented in log books or log sheets.

Finding SL4: Calibration of the primary flow standards brought in by ARB staff or

District does not always occur on an annual basis. There is no tracking by the Standard

Laboratory to ensure District or ARB flow standards are annually recertified.

Discussion: 40 CFR Part 50, Appendix L, Section 9.2.2 and Volume II, Part 1, QA

Handbook for Air Pollution Measurement Systems, Ambient Air Quality Monitoring

Program, Quality System Development, EPA 454/R-98-004, August 1998 requires that

the primary flow standard be calibrated annually. For the Air Monitoring North site, the

Graseby variable orifice, bar code 107376, sn 5346 was brought in for certification on 

02/25/04, 01/19/06 and 07/18/07. This calibration schedule does not meet regulatory or

handbook requirements.

Recommendation: ARB Field staff and Districts need to become more familiar with 40 

CFR Part 50 recert/recal requirements. This step should be included in a Standard

Operating Procedure (SOP) for calibrations to ensure that they are performed on an

annual or more frequent basis (when deviations occur before scheduled recalibration).

A method for tracking the submission of flow standards for recertification and

calibration should be developed to ensure the standards are recertified on a regular basis

or recalibrated if necessary. A computer generated reminder to ARB sites and Districts

might be helpful.

Finding SL5: Manometers were not calibrated separately from transfer standards.

Discussion: Manometers are often changed out, and separated from the transfer standard

that was sent in for certification. As this appears to be common practice, manometers

should be calibrated separately to ensure that if they are exchanged, there is a record that

the instrument satisfies certification criteria.

Recommendation: All manometers should be calibrated separately.

Finding SL6: The control charts for Hi Vol flow standard was above two standard

deviations from September 2005 and reached three standard deviations in January 2006 

before corrective measures were taken to bring the situation back into control.
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Discussion: It is commendable the Standards Laboratory produces control charts to

evaluate its own performance. As ARB is expected to establish and maintain “the

standard” for use in calibrating Districts and ARB-MLD flow standards, the Standards

Laboratory should maintain its primary standard running as close to one standard

deviation as possible..

Recommendation: Continue to produce control charts to self assess and monitor

performance. When charts show controls at 2 standard deviations, checks should be

performed to correct the problem..

Finding SL7: The Standards Lab's High Volume Orifice Calibration Work Sheet is not

always filled out completely. As per the logbooks, the person performing calibrations for

the ozone standards does not sign her/his name.

Discussion: To enable calibration tracking, the worksheet should be completed,

particularly noting which Roots meter is used to perform calibration and who performed

the calibration of the ozone standards.

Recommendation: All Standard Laboratory worksheet entries should be completed,

including identification of the party making the entries.

Finding SL8: Calibration records from DH Instruments, Inc. are not always opened

upon receipt.

Discussion: Some records from 2006 (calibration report No. 48879, October 3, 2006 and

47162, July 12, 2006) indicate that the primary standard was out of tolerance. Results of

recalibration should be opened and reviewed upon receipt. Out of tolerance

determinations may impact District and ARB generated data that has been submitted to

AQS. Notice should be issued to the impacted Districts and ARB site managers to

communicate the out of tolerance situation and its potential impact on data. Where out of

tolerance incidents were reviewed by DH Instruments the company concluded there was

no expected impact on data quality.

It was stated in the introduction that Standards Laboratory personnel perform calibration

checks on a quarterly basis. They also verify that the primary standard meets ARB

criteria after being recalibrated by DH Instruments. These practices minimize loss of

data. Records of the checks performed after recalibration by DH Instruments were not

available for review but will be maintained in the future (see comment 9).

Recommendation: Open and review calibration results from DH Instruments. Develop

procedures to issue data impact notices, as appropriate.

Finding SL9: The Standard Laboratory does not maintain calibration verification

records it performed on instruments recalibrated by DH Instruments.
78

Discussion: One of the standards was found to be out of criteria by the Standard

Laboratory during its routine performance checks and was sent to DH Instruments for

recalibration at least two times before the standard was in criteria by ARB-MLD. The

fact that the Standards Laboratory verifies a standard that has been recalibrated is a

commendable.

Recommendation: Verification of calibration should be performed and records

maintained.

Finding SL10: There is no backup to the stand alone DBASE database server that

maintains records from results of calibrations performed at District and ARB-MLD sites.

Discussion: The database may be subject to failure as the software used to store

records from calibration is DBASE. DBASE is no longer in production and not

supported by the manufacturer. Currently, despite the system being only accessible to

Standard Laboratory staff, DBASE failure or database corruption would require Standard

Laboratory staff to review each hard copy record and compare it against database records

to ensure the electronic record is complete and accurate. ARB-MLD noted that it will

obtain up-dated software to minimize the potential to lose electronic calibration records.

Recommendation: A back-up system should to be developed and standard operating

procedures (SOPs) developed to implement it. While the backup system can be

maintained on site, it is preferred that it be off-site in a secure, safe location, potentially

in ADAM.

Finding SL11: Hard copy records of changes made to DBASE electronic data (see

comment SL10 above) are not easily accessible.

Discussion: The database of calibrations of District and ARB-MLD flow standards is

capable of recording changes, however, the hard copy from which the change was made

was not accessible at the time of review. The auditor was informed that changes rarely

occur, and that the records could be found if necessary. The reviewer sought to verify

that the electronic change was included in the hard copy record, and also to see the

original data.

Recommendation: Any changes to electronic data should kept in a bound logbook and

traceable to the hard copy data e.g., with a serial number or date of analyses and project.

Operations Planning and Assessment (OPA)

OPA’s primary responsibility is to perform the lead function for Special Purpose

Monitoring (SPM) projects. This function entails the planning and coordination of

projects, working with affected stakeholders, developing data quality objectives for the

SPM projects, tracking of these projects to ensure they are meeting the QA objectives and

describing how projects are meeting those objectives. OPA performs pre- and post audits
79

for SPM projects. A recent example is the Roseville Railyard project OPA has also

performed quality control review and method development reviews of the Northern and

Southern Laboratory Program.

OPA Quality Assurance Findings

Finding OPA1: OPA’s QA audit role in the organization is underutilized and could be

more effective.

Discussion: OPA’s has conducted quality control review and method development

reviews of the Northern and Southern Laboratory Program. Results of these reviews are

not formalized, but verbally reported at the Division Chief level. A corrective action plan

is not required, even if findings requiring action are made. OPA staff stated that, as a

result of these reviews, standard QA procedures are now being implemented, whereas

they were not prior to review. However the QA procedures being implemented were not

clearly defined by OPA.

Recommendation: Expand OPA's authority to include self assessments of the QMB and

its effectiveness e.g., data production (field and lab), data handling and management

activities within the QMB, performance audits conducted by the ARB, and Standards

Laboratory calibration activities, as these areas are critical for ensuring the quality of

ARB-MLD and Districts data. Understanding and comprehensively evaluating how these

functions are performed as well as interactions within the organization will help in the

evaluation of the effectiveness of the existing QA system.

Finding OPA2: Special Purpose Monitoring (SPM) projects are not implemented under

a Quality Assurance Project Plan (QAPP), but there is a protocol developed specifically

for the SPM.

Discussion: ARB is to be commended for developing data collection protocols

specifically tailored to the SPM. The contents of a protocol we reviewed as part of this

TSA, “Freeway-Based Diesel Particulate Matter Signature Study”, is more or less

consistent with what is contained in a QAPP. However, it is not clear from the topics

covered how QAPP objectives for sample collection and handling are met.

EPA requires organizations that receive Federal funding to collect and produce

environmental data establish QAPPs that include sample collection and handling

procedures. The purpose of the QAPP is to ensure the data produced is of known and

documented quality that can be used for its intended purpose.

Recommendation: The SPM protocols should be developed that addresses all the

elements of a QAPP, including sample collection and handling. A crosswalk should be

developed linking the SPM protocol to the QAPP element to which it corresponds to

ensure all elements covered.
80

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81

List of Acronyms

ADAM...............................................................Air Data Management System

AMP350......................................................Air Quality System Raw Data Report

AMP450.....................................................Air Quality System Quicklook Report

APCD.................................................................Air Pollution Control District

AQDA......................................................................Air Quality Data Action

AQDAS......................................................Air Quality Data Acquisition System

AQDB......................................................................Air Quality Data Branch

AQDS......................................................................Air Quality Data Section

AQMD...........................................................Air Quality Management District

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

AQSB.............................................................Air Quality Surveillance Branch

ARB.............................................................................Air Resources Board

BAM...........................................................................Beta Attenuation Mass

BFB........................................................................1-bromo-4flourobenzene

CAA.....................................................................................Clean Air Act

CC............................................................................Correlation Coefficient

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

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

COH..............................................................................Coefficient of Haze

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

FD................................................................................Diluent Air Flowrate

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

FNO.......................................................................... ...Nitric Oxide Flowrate

FO.........................................................................Ozone Generator Flowrate

FRM.....................................................................Federal Reference Method

FRSD......................................................Full Scale Relative Standard Deviation

GBUAPCD.................................Great Basin Unified Air Pollution Control District

GC/MS...................................................Gas Chromatograph/Mass Spectrometer

GDUT.....................................................................Guest Device Under Test

H2S..................................................................................Hydrogen Sulfide

HPLC................................................High Performance Liquid Chromatography

IC................................................................................Ion Chromatography

LIMS..............................................Laboratory Information Management System

lpm....................................................................................liters per minute

MDL.....................................................................Minimum Detection Limit

MEK............................................................................Methyl Ethyl Ketone

MLD.........................................................Monitoring and Laboratory Division

MSA...............................Metropolitan Statistical Area/Micropolitan Statistical Area

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

NCORE.............................................................National Core Monitoring Site

NIST.............................................National Institute of Standards and Technology

NLB....................................................................Northern Laboratory Branch
82

NMHC...............................................................Non-methanated Hydrocarbon

NO2.................................................................................Nitrogen Dioxide

NPAP.......................................................National Performance Audit Program

NSAQMD....................................Northern Sierra Air Quality Management District

OSS.......................................................................Operation Support Section

PAMS...........................................Photochemical Assessment Monitoring Station

PEP...............................................................Performance Evaluation Program

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

PM10...........................Particulate Matter 10 microns or less in aerodynamic diameter

PM2.5..........................Particulate Matter 2.5 microns or less in aerodynamic diameter

ppb....................................................................................parts per billion

ppm...................................................................................parts per million

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

PTSD....................................................Planning and Techncial Support Section

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

Qa..........................................................................................Actual Flow

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

QAS......................................................................Quality Assurance Section

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

QMB..................................................................Quality Management Branch

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

Qstd......................................................................................Standard Flow

RO...........................................................................Reporting Organization

RSD....................................................................Relative Standard Deviation

S&L...................................................................................State and Local

scfm...............................................................Standard Cubic Feet per Minute

SIP........................................................................State Implementation Plan

SJVAPCD....................................San Joaquin Valley Air Pollution Control District

SLAMS...................................................State and Local Air Monitoring Station

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

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

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

SRM...................................................................Standard Reference Material

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

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

TEOM................................................Tapered Element Oscillating Microbalance

THC..............................................................................Total Hydrocarbons

TIC...............................................................Tentatively Identified Compound

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

TSP....................................................................Total Suspended Particulates

VOC....................................................................Volatile Organic Compound
83

APPENDIX A

SUMMARY OF REPORT FINDINGS
84

MAJOR FINDINGS

Finding M1: The ARB Primary Quality Assurance Organization does not meet the

requirements in 40 CFR Part 58, Appendix A, Section 3.1 for its dependent Districts.

Finding M2: There is no central organization that ensures Districts are aware of and

follow changes to the QA Manual and related SOPs.

Finding M3: The ARB PQAO has a corrective action process in its QA Manual, but it is

not being applied outside the Quality Management Branch (QMB) performance audit

program.

Finding M4: The ARB collects environmental data for EPA decision making that is

funded in whole or part by EPA but is not subject to the requirements of the ARB and

EPA quality assurance programs.

Finding M5: Districts that are part of the ARB PQAO collect data for EPA decision

making and/or are funded by EPA that is not quality assured by the ARB PQAO.

Finding M6: The ARB QA Manual does not fully meet EPA’s QMP and QAPP

requirements.

Finding M7: Data are not validated using consistent procedures.

Finding M8: EPA commends the ARB MLD for producing Quality Assessment Reports

and recommends that the ARB PQAO develop a mechanism to use these reports to make

specific corrective actions or other quality improvements.

NETWORK MANAGEMENT

Finding NM1: The ARB annual network plan includes not only active monitoring sites,

but any monitoring site that collected air pollution data in the State of California since the

early 1970's, whether still in operation or not.

Finding NM2: The Stockton MSA in the San Joaquin Valley Air Basin does not meet

the minimum SLAMS monitoring requirements for PM2.5.

Finding NM3: The Modesto MSA in the San Joaquin Valley Air Basin does not meet

the minimum SLAMS monitoring requirements for PM2.5.

Finding NM4: The Visalia-Porterville MSA in the San Joaquin Valley Air Basin does

not meet the minimum SLAMS monitoring requirements for ozone.

Finding NM5: Some information in the ARB State and Local Air Monitoring Network

Plan, dated June 2007, does not agree with information in the EPA AQS database or with

local district Annual Network Plans. The specific examples noted in the discussion
85

related to this finding may or may not constitute the actual total number of

inconsistencies in the 2007 plan.

Finding NM6: The ARB 2007 Network Plan is not complete with respect to GBUAPCD

sites, monitoring objectives or monitoring scales.

OPERATIONS

Finding AQSB1: Field operators do not always document shipping information on

sample report/tracking sheets. See also Lab Finding #IL7

Finding AQSB2: Some ARB MLD monitoring SOPs are outdated and/or incomplete.

Finding AQSB3: The use of correction fluid was noted on an MLD air monitoring form.

Finding AQSB4: ARB MLD does not calibrate monitoring equipment at all PQAO

sites.

Finding AQSB5: Second level review of calibration records and calculations is not

routinely performed.

Finding AQSB6: The lowest ozone calibration point is at a concentration that is above

the 8 hour standard.

Finding AQSB7: The calibration technician noted that only 2 gas phase titration points

are used to verify the NO2 calibration.

Finding AQSB8: Maintenance and performance verification of zero air scrubbers used

for calibrations is not documented.

Finding AQSB9: The Special Purpose Monitoring Section should keep EPA informed

of its monitoring projects.

Finding AQSB10: The trees to the east of the Fresno 1st Street station building are too

close (about 15 meters) to the inlet probe and PM manual instruments.

Finding AQSB11: At the Stockton-Hazelton monitoring station, a large tree to the south

of the trailer is acting as an obstruction for the gaseous pollutant sample train inlet and

the PM10 and PM2.5 samplers. This site does not meet the probe siting criteria in 40 CFR

58, Appendix E. 

Finding AQSB12: The palm tree northwest of the Visalia monitoring station is within

10 meters of the inlet probe.

Finding SJV1: The San Joaquin Valley APCD does not have District specific SOPs

addressing the operation and maintenance of its air pollution monitoring network.
86

Finding SJV2: The SJVAPCD field operators do not maintain zero and span or

precision check control charts.

Finding SJV3: Station and instrument logbooks are not reviewed by the Supervising Air

Quality Instrument Technician.

Finding SJV4: There is no current consistent procedure in place for archiving all station

records.

Finding SJV5: At the Bakersfield – Golden State Highway site, the area surrounding the

trailer which houses the monitoring equipment is not stable.

Finding NS1: The NSAQMD field technicians have instrument manuals but no SOPs.

The ARB SOPs are kept at the District’s main office in Grass Valley, not at field stations.

Additionally, the District operations deviate from the ARB SOPs but do not document

those deviations.

Finding NS2: The NSAQMD record-keeping procedures should be more rigorous.

Finding NS3: The NSAQMD experiences significant ozone data loss due to a lack of

spare parts.

Finding NS4: ARB-performed audits of the NSAQMD PM instruments do not conform

to CFR requirements. Additionally, the NSAQMD stated that the ARB does not perform

through the probe audits of NSAQMD ozone monitors.

Finding NS5: There is no feedback from the ARB on results of PM filters. See also

Laboratory Finding # IL8

Finding NS6: The most recent ARB site survey report was not accurate.

Finding NS7: There are trees within 20 m of monitors.

Finding GB1: Great Basin operates an independent monitoring, laboratory and QA

program from that of ARB.

Finding GB2: GBUAPCD’s training program (a QA function) is independent and

separate from that of ARB.

Finding GB3: Logbooks were not up to date or signed by the GBUAPCD operators at

all stations.

LABORATORY OPERATIONS

Inorganic Laboratory
87

Finding IL1: The MLD weigh sessions have been automated in a manner that reduces

the possibility of operator error.

Finding IL2: Mass determination of PM10 filters should include blank controls.

Finding IL3: Temperature and humidity measurements in the weigh rooms are only

logged on a paper chart and are not formally analyzed to determine compliance with

regulatory criteria.

Finding IL4: The PM10 laboratory only recently started a logbook to track verification

of “working” mass standards.

Finding IL5: Several additional improvements could be made to the PM2.5 weighing

process.

Finding IL6: The PM10 and PM2.5 documentation and archived filters were well

organized and easily tracked.

Finding IL7: Field operators do not always document shipping information on their

sample report/tracking sheets. See also Operations Finding #AQSB1.

Finding IL8: A local District stated that there was lack of sufficient feedback from the

ARB on outcome of PM filters. See also Operations Finding #NS8.

Organic Laboratory

Aldeydes and Methyl Ethyl Ketone (MEK) by High Performance Liquid

Chromatography (HPLC)

Finding OL1: A second source quality control standard is not being analyzed as

required by the method. Analysis of a second standard is being performed, but the

standard is not prepared from a second stand source but rather is prepared as a dilution of

the same standard solution that is used to prepare the working calibration standards.

Finding OL2: Audit samples are not being analyzed.

Finding OL3: Field blanks are not being analyzed. Sample results are being corrected

for background contamination based on an average background contamination of 0.3 

μg/cartridge determined from a field blank study performed by MLD 15 years ago. It is

the understanding of the audit team that field blanks have not been deployed for 15 years.

Finding OL4: The laboratory is not using an internal standard method of analysis as

described by the method. The laboratory is currently using the external standard method

of standardization.
88

Finding OL5: Secondary review of instrument logbooks is not being documented.

Hexavalent Chromium by Ion Chromatography (IC)

Finding OL6: Audit samples are not being analyzed. The audit team was told that the

ARB QA Department suggested the department initiate its own system of audit sample

analysis.

Finding OL7: Secondary review of instrument logbooks is not being documented.

Finding OL8: It is noted that the laboratory is looking into the purchase of an additional

IC instrument.

Finding OL9: Secondary review of instrument logbooks is not being documented.

Aromatic and Halogenated Hydrocarbons by Gas Chromatography/Mass

Spectrometry (GC/MS)

Finding OL10: Duplicate samples are being analyzed and presented as tabulated results

in quarterly QA reports, but control charting is only occasionally performed.

Finding OL11: The GC/MS is not vented to outside the facility.

Finding OL12: Secondary review of instrument logbooks is not being documented.

Oxygenated Hydrocarbons and Nitriles

Finding OL13: Audit samples are not currently being analyzed.

Finding OL14: The GC/MS Saturn D is a new instrument that was brought on-line in

April, 2007. It is being used to generate data, but an MDL study has not been performed

and documented.

Finding OL15: The MLD 066 method is based on the TO-15 method, which describes

and internal standard method of calibration. The laboratory is using an external method

of standardization; internal standards are not being used.

Finding OL16: Secondary review of instrument logbooks is not being documented.

Finding OL17: Mass calibration is performed using perfluorotributylamine (FC -43),

but confirmation that tuning abundance criteria have been met is not being verified

through the analysis of 1-bromo-4fluorobenzene (BFB). It is the understanding of the

audit team that tentatively identified compounds are not routinely being reported with this

method.

Finding OL18: The GC/MS is not vented to outside the facility.
89

Canister Cleaning & Certification

Finding OL19: Laboratory staff stated that canisters are randomly selected for

certification testing. The staff does not consider which canisters had the highest

concentrations of contaminants in deciding which canister in a batch to test for

cleanliness certification.

Finding OL20: Canisters are not vented in hoods and are vented to ambient air.

Finding OL21: The laboratory has not established a retention time for canisters after

they have been certified. The laboratory relies on the canister pressure gauge reading as

an indication the canisters have not lost vacuum.

DATA MANAGEMENT

Finding DM1: The data validation and review/verification procedures for the Air

Quality Surveillance Branch are not formally published in a control-copied SOP.

Finding DM2: The data validation and data review/verification procedures for the

Northern Laboratory Branch are not formally published in control-copied SOPs.

Finding DM3: The data validation and data review/verification procedures for the Air

Quality Data Section are not formally published in a control-copied SOP.

Finding DM4: EPA was not given access to special projects data management activities

to review. It is not clear that QA procedures are being applied to all projects receiving

federal funding.

Finding DM5: The AQDS does not ensure that local District data are validated prior to

upload to AQS.

Finding DM6: Ambient monitoring data submitted to the AQS database by the ARB

PQAO is not being certified annually.

Finding DM7: ARB does not review GBUAPCD’s data prior to its being uploaded to

AQS.

Finding DM8: Annual certification of the GBUAPCD’s monitoring data in AQS is not

being done.

Finding DM9: Valid concentration data for the Yreka PM2.5 monitor (AQS# 06-093-

2001) have not been submitted to the AQS database since December 2006.

Finding DM10: The AQS database identifies the Siskiyou County APCD as its own

PQAO.
90

Finding DM11: The Lakeport PM10 site has not reported PM10 data correctly to AQS

since March 2001.

QUALITY ASSURANCE

Finding QM1: The MLD does not have central, independent authority in the

organization to provide direction and recommendations to the data collection, production,

and verification programs.

Finding QM2: Training, while in place for the ARB MLD, does not necessarily extend

to all staff and the ARB PQAO Districts. See also Finding M1.

Finding QM3: Some Districts do not have a central, independent, dedicated quality

assurance manager/officer responsible for communicating and ensuring that quality

assurance activities are carried out in field operations and information management.

Finding QA1: The QAS does not assure that sites that fail performance audits are retested after a corrective action is implemented.

Finding QA2: The QAS has experienced a high staff turnover in recent years, which has

impacted the level of institutional knowledge in the section and impacted its ability to

perform audits.

Finding QA3: System audits of local Districts by QAS and the Stationary Source

Division are only conducted by request or on an as needed basis.

Finding QA4: ARB MLD does not perform routine audits of data quality.

Finding QA5: Internal audits are not conducted on ARB-MLD’s and Districts data

management, reduction and review process.

Finding QA6: The ARB’s MLD does not routinely conduct monthly (day-to-day)

checks of all the precision and accuracy of data being uploaded by the local Districts to

the AQS database.

Finding QA7: The ARB Reporting Organization (RO) is not able to access the AQS

accounts of Districts that are part of the ARB PQAO but serve as their own RO for the

purposes of uploading data to the EPA AQS database.

Finding SL1: There is no procedure in place to notify Quality Assurance or Field Audit

staff of failure, i.e., the potential that data from the period prior to the current calibration

check might be rejected if transfer and flow standards fail calibration.

Finding SL2: The thermometer in the Standards Laboratory needs to be verified with

another NIST traceable standard.
91

Finding SL3: There is insufficient documentation in logbook entries in the ozone

Standards Laboratory.

Finding SL4: Calibration of the primary flow standards brought in by ARB staff or

District does not always occur on an annual basis. There is no tracking by the Standard

Laboratory to ensure District or ARB flow standards are annually recertified.

Finding SL5: Manometers were not calibrated separately from transfer standards.

Finding SL6: The control charts for Hi Vol flow standard was above two standard

deviations from September 2005 and reached three standard deviation in January 2006 

before corrective measures were taken to bring the situation back into control.

Finding SL7: The Standards Lab's High Volume Orifice Calibration Work Sheet is not

always filled out completely. As per the logbooks, the person performing calibrations for

the ozone standards does not sign her/his name.

Finding SL8: Calibration records from DH Instruments, Inc. are not always opened

upon receipt.

Finding SL9: The Standard Laboratory does not maintain calibration verification

records it performed on instruments recalibrated by DH Instruments.

Finding SL10: There is no backup to the stand alone DBASE database server that

maintains records from results of calibrations performed at District and ARB-MLD sites.

Finding SL11: Hard copy records of changes made to DBASE electronic data (see

comment SL10 above) are not easily accessible.

Finding OPA1: OPA’s QA audit role in the organization is underutilized and could be

more effective.

Finding OPA2: Special Purpose Monitoring (SPM) projects are not implemented under

a Quality Assurance Project Plan (QAPP), but there is a protocol developed specifically

for the SPM.
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93

APPENDIX B

CALIFORNIA METROPOLITAN STATICAL AREAS AND

MINIMUM MONITORING REQUIREMENTS
MINIMUM OZONE MONITORING REQUIREMENTS

Source of 2006 population estimates - MSA DV > 0.068 ppm DV < 0.068 ppm Meets Requirements

US Census Bureau, Annual Estimates of the Population Population

of Metropolitan and Micropolitan Statistical Areas: > 10 million 4 2 See Footnote

April 1, 2000 to July 1, 2006 (CBSA-EST2006-01) 4 - 10 million 3 1

350K - 4 million 2 1 Does Not Meet Requirements

50K - 350K 1 0

Required 2004 - 2006

ARB PQAO AIR BASINS Estimated MSA # of Ozone # of Ozone Ozone Site 

Metropolitan Statistical Areass (MSA) 2000 2006 Ozone SLAMS SLAMS Counties SLAMS Sites AQS # Design Values1

Micropolitan Statistical Areas (msa) Population Population Design Value per CBSA* per CBSA* (ppm)

Great Basin / Bishop msa 17,945 17,980 0 0 Inyo None

Great Basin / No CBSA* 0 0 Mono None

Great Basin / No CBSA* 0 0 Alpine None

Lake County / Clearlake msa 58,309 65,933 0.062 0 1 Lake Lakeport 06-033-3001 0.062

Lake Tahoe/Sacramento-Arden-Arcade-Roseville MSA 1,796,857 2,067,117 0.067 1 0 Placer (east) None

1 El Dorado (east) South Lake Tahoe-Airport 06-017-0013 0.067

Mojave Desert / Riverside-San Bernardino-Ontario MSA 3,254,821 4,026,135 0.100 3 5 San Bernardino Barstow 06-071-0001 0.084

Hesperia 06-071-4001 0.100

Phelan 06-071-0012 0.098

Trona 06-071-1234 0.081

Victorville 06-071-0306 0.090

1 Riverside Blythe 06-059-0003 0.061

Mojave Desert / Bakersfield MSA 661,645 780,117 0.086 2 1

2

Kern County Mojave-Poole St. 06-029-0011 0.086

Mojave Desert / Los Angeles-Long Beach-Santa Ana MSA 12,365,627 12,950,129 4 0

3

Los Angeles None

1. These Design Values are for the purpose of determining the minimum number of monitoring sites for MSAs. They are not intended for use in SIP planning or for designation purposes. 

2. Additional ozone monitors in the San Joqauin Valley Air Basin meet the required # of ozone monitors.

3. Additional ozone monitors in the South Coast Air Basin meet the required # of ozone monitors. 

* CBSA - Core Based Statiscal Area is a term that refers collectively to metropolitan and micropolitan statiscal areas

MINIMUM OZONE MONITORING REQUIREMENTS

Source of 2006 population estimates - MSA DV > 0.068 ppm DV < 0.068 ppm Meets Requirements

US Census Bureau, Annual Estimates of the Population Population

of Metropolitan and Micropolitan Statistical Areas: > 10 million 4 2 See Footnote

April 1, 2000 to July 1, 2006 (CBSA-EST2006-01) 4 - 10 million 3 1

350K - 4 million 2 1 Does Not Meet Requirements

50K - 350K 1 0

Required 2004 - 2006

ARB PQAO AIR BASINS Estimated MSA # of Ozone # of Ozone Ozone Site 

Metropolitan Statistical Areass (MSA) 2000 2006 Ozone SLAMS SLAMS Counties SLAMS Sites AQS # Design Values1

Micropolitan Statistical Areas (msa) Population Population Design Value per CBSA* per CBSA* (ppm)

Mountain Counties / Sacramento-Arden-Arcade-Roseville MSA 1,796,857 2,067,117 0.097 3 1

2

El Dorado (west) Placerville 06-017-0010 0.095

1
1

2

Placer (central) Colfax 06-061-0004 0.097

Mountain Counties / Truckee-Grass Valley msa 92,033 98,764 0.097 0 2 Nevada Grass Valley-Litton Bldg 06-057-0005 0.097

Truckee-Fire Station 06-057-1001 0.068

Mountain Counties / Phoenix Lake-Cedar Ridge msa 54,501 56,855 0.078 0 1 Tuolumne Sonora 06-109-0005 0.078

Mountain Counties / No CBSA* 0 0 Plumas None

Mountain Counties / No CBSA* 0 1 Calaveras San Andreas 06-009-0001 0.093

Mountain Counties / No CBSA* 0 1 Mariposa Jerseydale 06-043-0006 0.082

Mountain Counties / No CBSA* 0 0 Sierra None

Mountain Counties / No CBSA* 0 1 Amador Jackson-Clinton Road 06-005-0002 0.084

1. These Design Values are for the purpose of determining the minimum number of monitoring sites for MSAs. They are not intended for use in SIP planning or for designation purposes. 

2. Additional ozone monitors in the Sacramento Valley Air Basin meet the required # of ozone monitors.

* CBSA - Core Based Statiscal Area is a term that refers collectively to metropolitan and micropolitan statiscal areas

MINIMUM OZONE MONITORING REQUIREMENTS

Source of 2006 population estimates - MSA DV > 0.068 ppm DV < 0.068 ppm Meets Requirements

US Census Bureau, Annual Estimates of the Population Population

of Metropolitan and Micropolitan Statistical Areas: > 10 million 4 2 See Footnote

April 1, 2000 to July 1, 2006 (CBSA-EST2006-01) 4 - 10 million 3 1

350K - 4 million 2 1 Does Not Meet Requirements

50K - 350K 1 0

Required 2004 - 2006

ARB PQAO AIR BASINS Estimated MSA # of Ozone # of Ozone Ozone Site 

Metropolitan Statistical Areass (MSA) 2000 2006 Ozone SLAMS SLAMS Counties SLAMS Sites AQS # Design Values1

Micropolitan Statistical Areas (msa) Population Population Design Value per CBSA* per CBSA* (ppm)

North Central Coast / San Jose-Sunnyvale-Santa Clara MSA 1,735,819 1,787,123 0.068 2 1

2

San Benito Hollister 06-069-0002 0.068

North Central Coast / Santa Cruz-Watsonville MSA 255,602 249,705 0.062 0 3 Santa Cruz Santa Cruz-Soquel Ave 06-087-0007 0.055

Scots Valley-Scots ValleyDr. 06-087-0006 0.062

Watsonville 06-087-0004 0.056

North Central Coast / Salinas MSA 401,762 410,206 0.062 1 2 Monterey Carmel Valley 06-053-0002 0.062

Salinas-High School 06-053-1003 0.056

North Coast / Eureka-Arcata-Fortuna msa 126,518 128,330 0 0 Humboldt None

North Coast / Ukiah msa 86,265 88,109 0.059 0 2 Mendocino Ukiah-E Gobbi St. 06-045-0008 0.059

Willets-Main St 06-045-0009 0.046

North Coast / Crescent City msa 27,507 28,893 0 0 Del Norte None

North Coast / Santa Rosa - Petaluma MSA 458,614 466,891 0.055 1 1 Sonoma (north) Healdsburg 06-097-1003 0.055

North Coast / No CBSA* 0 0 Trinity None

Northeast Plateau / Mo CBSA* 0 0 Siskiyou None

Northeast Plateau / Mo CBSA* 0 0 Modoc None

1. These Design Values are for the purpose of determining the minimum number of monitoring sites for MSAs. They are not intended for use in SIP planning or for designation purposes. 

2
2. Additional ozone monitors in the Bay Area Air Basin meet the required # of ozone monitors.

* CBSA - Core Based Statiscal Area is a term that refers collectively to metropolitan and micropolitan statiscal areas

MINIMUM OZONE MONITORING REQUIREMENTS

Source of 2006 population estimates - MSA DV > 0.068 ppm DV < 0.068 ppm Meets Requirements

US Census Bureau, Annual Estimates of the Population Population

of Metropolitan and Micropolitan Statistical Areas: > 10 million 4 2 See Footnote

April 1, 2000 to July 1, 2006 (CBSA-EST2006-01) 4 - 10 million 3 1

350K - 4 million 2 1 Does Not Meet Requirements

50K - 350K 1 0

Required 2004 - 2006

ARB PQAO AIR BASINS Estimated MSA # of Ozone # of Ozone Ozone Site 

Metropolitan Statistical Areass (MSA) 2000 2006 Ozone SLAMS SLAMS Counties SLAMS Sites AQS # Design Values1

Micropolitan Statistical Areas (msa) Population Population Design Value per CBSA* per CBSA* (ppm)

Sacramento Valley / Sacramento-Arden-Arcade-Roseville MSA 1,796,857 2,067,117 0.097 3 2 Yolo Davis 06-113-0004 0.074

Woodland-Gibson Road 06-113-1003 0.079

5 Sacramento Elk Grove 06-067-0011 0.083

Folsom-Natoma 06-067-0012 0.097

Sacramento-Airport Road 06-067-0013 0.073

Sacramento-Del Paso Manor 06-067-0006 0.091

Sacramento-T Street 06-067-0010 0.076

2 Placer (west) Auburn 06-061-0002 0.093

Roseville 06-061-0006 0.089

Sacramento Valley / Chico MSA 203,171 215,881 0.073 1 1 Butte Chico-Manzanita Ave. 06-007-0002 0.073

Sacramento Valley / Yuba City MSA 139,149 161,806 0.075 1 1 Sutter Yuba City 06-101-0003 0.075

0 Yuba None

Sacramento Valley / Redding MSA 163,256 179,951 0.080 1 2 Shasta Anderson 06-089-0007 0.079

Redding 06-089-0004 0.080

Sacramento Valley / Red Bluff msa 56,039 61,686 0 0 Tehema

Sacramento Valley / Vallejo Fairfield MSA 394,542 411,680 0.074 2 1

2

Solano (east) Vacaville 06-095-3003 0.074

Sacramento Valley / No CBSA* 0 1 Colusa Colusa-Sunrise Blvd 06-011-1002 0.067

Sacramento Valley / No CBSA* 0 1 Glenn Willows-Colusa St 06-021-0003 0.064

1. These Design Values are for the purpose of determining the minimum number of monitoring sites for MSAs. They are not intended for use in SIP planning or for designation purposes. 

2. Additional ozone monitors in the Bay Area Air Basin meet the required # of ozone monitors.

* CBSA - Core Based Statiscal Area is a term that refers collectively to metropolitan and micropolitan statiscal areas

MINIMUM OZONE MONITORING REQUIREMENTS

Source of 2006 population estimates - MSA DV > 0.068 ppm DV < 0.068 ppm Meets Requirements

US Census Bureau, Annual Estimates of the Population Population

of Metropolitan and Micropolitan Statistical Areas: > 10 million 4 2 See Footnote

April 1, 2000 to July 1, 2006 (CBSA-EST2006-01) 4 - 10 million 3 1

350K - 4 million 2 1 Does Not Meet Requirements

50K - 350K 1 0

Required 2004 - 2006

ARB PQAO AIR BASINS Estimated MSA # of Ozone # of Ozone Ozone Site 

3
Metropolitan Statistical Areass (MSA) 2000 2006 Ozone SLAMS SLAMS Counties SLAMS Sites AQS # Design Values1

Micropolitan Statistical Areas (msa) Population Population Design Value per CBSA* per CBSA* (ppm)

San Joaquin Valley / Bakersfield MSA 661,645 780,117 0.110 2 7 Kern Arvin 06-029-5001 0.110

Bakersfield- CA Ave. 06-029-0014 0.099

Bakersfield-Golden State Hwy 06-029-0010 0.088

Edison 06-029-0007 0.100

Maricopa 06-029-0008 0.089

Oildale 06-029-0232 0.097

Shafter 06-029-6001 0.089

San Joaquin Valley / Fresno MSA 799,407 891,756 0.098 2 5 Fresno Clovis 06-019-5001 0.091

Fresno-1st St. 06-019-0008 0.098

Fresno-Drummond 06-019-0007 0.087

Fresno-Sierra Skypark 06-019-0242 0.096

Parlier 06-019-4001 0.092

San Joaquin Valley / Madera MSA 123,109 146,345 0.078 1 1 Madera Madera-Pump Yard 06-039-0004 0.078

San Joaquin Valley / Stockton MSA 563,598 673,170 0.093 2 2 San Joaquin Stockton-Hazelton St. 06-077-1002 0.076

Tracy Airport 06-077-3005 0.093

San Joaquin Valley / Modesto MSA 446,997 512,138 0.086 2 2 Stanislaus Modesto-14th St. 06-099-0005 0.086

Turlock 06-099-0006 0.086

San Joqauin Valley / Visalia - Porterville MSA 368,021 419,909 0.092 2 1 Tulare Visalia-Church St. 06-107-2002 0.092

San Joaquin Valley / Merced MSA 210,554 245,658 0.089 1 1 Merced Merced-S Coffee Ave. 06-047-0003 0.089

San Joaquin Valley / Hanford-Corcroan MSA 129,461 146,153 0.086 1 1 Kings Hanford-Irwin St. 06-031-1004 0.086

1. These Design Values are for the purpose of determining the minimum number of monitoring sites for MSAs. They are not intended for use in SIP planning or for designation purposes. 

* CBSA - Core Based Statiscal Area is a term that refers collectively to metropolitan and micropolitan statiscal areas

MINIMUM OZONE MONITORING REQUIREMENTS

Source of 2006 population estimates - 

US Census Bureau, Annual Estimates of the Population MSA DV > 0.068 ppm DV < 0.068 ppm Meets Requirements

of Metropolitan and Micropolitan Statistical Areas: Population

April 1, 2000 to July 1, 2006 (CBSA-EST2006-01) > 10 million 4 2 See Footnote

4 - 10 million 3 1

350K - 4 million 2 1 Does Not Meet Requirements

50K - 350K 1 0

Required 2004 - 2006

ARB PQAO AIR BASINS Estimated MSA # of Ozone # of Ozone Ozone Site 

Metropolitan Statistical Areass (MSA) 2000 2006 Ozone SLAMS SLAMS Counties SLAMS Sites AQS # Design Values1

Micropolitan Statistical Areas (msa) Population Population Design Value per CBSA* per CBSA* (ppm)

Salton Sea / El Centro MSA 142,361 160,301 0.085 1 4 Imperial El Centro 06-025-1003 0.085

Calexico East 06-025-0006 0.076

Calexico-Ethel 06-025-0005 0.074

Westmoreland 06-025-4003 0.085

Salton Sea / Riverside-San Bernardino-Ontario MSA 1 0

2 Riverside

South Central Coast / SLO-Paso Robles MSA 246,681 257,005 0.086 1 7 San Luis Obispo Atascadero 06-079-8001 0.068

Carrizo Plains School 06-079-8006 0.086

Morro Bay 06-079-3001 0.055

Nipomo-Park 06-079-4002 0.061

Paso Robles 06-079-0005 0.071

Red Hills 06-079-8005 New

San Luis Obispo-S Higuera St 06-079-2006 0.057

4
South Central Coast / Santa Barbara - Santa Maria MSA 399,347 400,335 0.066 1 4 Santa Barbara El Capitan Beach 06-083-0008 0.063

Goleta 06-083-2011 0.065

Lompoc-H St. 06-083-1013 0.066

Santa Ynez 06-083-3001 0.065

South Central Coast / Oxnard-Thousand Oaks-Ventura MSA 753,197 799,720 0.090 2 6 Ventura El Rio 06-111-3001 0.063

Ojai 06-111-1004 0.090

Piru 06-111-0009 0.085

Simi Valley 06-111-2002 0.090

Thousand Oaks 06-111-0007 0.080

Emma Wood State Beach 06-111-2003 0.064

1. These Design Values are for the purpose of determining the minimum number of monitoring sites for MSAs. They are not intended for use in SIP planning or for designation purposes. 

2. SCAQMD operates ozone monitors in this MSA that meet the minimum requirements.

* CBSA - Core Based Statiscal Area is a term that refers collectively to metropolitan and micropolitan statiscal areas

5
MINIMUM PM2.5 MONITORING REQUIREMENTS

Source of 2006 population estimates - MSA DV > 85% DV < 085% Meets Requirements

US Census Bureau, Annual Estimates of the Population Population NAAQS NAAQS

of Metropolitan and Micropolitan Statistical Areas: > 12.75 annual < 12.75 annual See Footnote

April 1, 2000 to July 1, 2006 (CBSA-EST2006-01) > 29.75 daily < 29.75 daily

> 1 million 3 2 Does Not Meet Requirements

500K - 1 million 2 1

50K - 500K 1 0

MSA MSA Required 2004 - 2006 2004 - 2006

ARB PQAO AIR BASINS Estimated PM2.5 Annual PM2.5 Daily # of PM2.5 # of PM2.5 PM2.5 Site Annual PM2.5 Site Daily

Metropolitan Statistical Areass (MSA) 2000 2006 Design Value Design Value SLAMS SLAMS Counties SLAMS Sites AQS # Design Values1 Design Values1

Micropolitan Statistical Areas (msa) Population Population (ug/m3

) (ug/m3) per CBSA* per CBSA* (ug/m3) (ug/m3)

Great Basin / Bishop msa 17,945 17,980 5.3 19 0 1 Inyo Keeler-Cerro Gordo Road 06-027-1003 5.3 19

Great Basin / No CBSA* 0 0 Mono None

Great Basin / No CBSA* 0 0 Alpine None

Lake County / Clearlake msa 58,309 65,933 4.8 14 0 1 Lake Lakeport-Lakeport Blvd 06-033-3001 4.8 14

Mojave Desert / Bakersfield MSA 661,645 780,117 6.4 15 1 2 Kern Mojave-923 Poole Street 06-029-0011 5.7 15

Ridgecrest-100 West California Avenue 06-029-0015 6.4 15

Mojave Desert / Los Angeles-Long Beach-Santa Ana MSA 12,365,627 12,950,129 8.3 16 2 1

2

Los Angeles Lancaster-43301 Division Street 06-037-9033 8.3 16

Mojave Desert / Riverside-San Bernardino-Ontario MSA 3,254,821 4,026,135 10.3 24 2 0 Riverside None

1

2

San Bernardino Victorville-14306 Park Avenue 06-071-0306 10.3 24

Mountain Counties / No CBSA* 0 0 Amador None

Mountain Counties / No CBSA* 0 1 Calaveras San Andreas-Gold Strike Road 06-009-0001 7.7 21

Mountain Counties / Sacramento-Arden-Arcade-Roseville MSA 1,796,857 2,067,117 No Data No Data 2 0

3

El Dorado None

Placer (central) None

Mountain Counties / No CBSA* 0 0 Mariposa None

Mountain Counties / Truckee-Grass Valley msa 92,033 98,764 6.7 16 0 2 Nevada Grass Valley-Litton Bldg. 06-057-0005 5.3 15

Truckee-Fire Station 06-057-1001 6.7 16

Mountain Counties / No CBSA* 0 2 Plumas Quincy-N Church Street 06-063-1006 8.9 27

Portola-161 Nevada Street 06-063-1009 11.1 30

Mountain Counties / No CBSA* 0 0 Sierra None

Mountain Counties / Phoenix Lake-Cedar Ridge msa 54,501 56,855 No Data No Data 0 0 Tuolumne None

1. These Design Values are for the purpose of determining the minimum number of monitoring sites for MSAs. They are not intended for use in SIP planning or for designation purposes. 

2. SCAQMD operates PM2.5 sites in this MSA that exceed the required number of sites.

3. The SMAQMD and ARB operate more than the required number os sites in this MSA. See the Sacramento Valley Air Basin.

* CBSA - Core Based Statiscal Area is a term that refers collectively to metropolitan and micropolitan statiscal areas

MINIMUM PM2.5 MONITORING REQUIREMENTS

Source of 2006 population estimates - MSA DV > 85% DV < 085% Meets Requirements

US Census Bureau, Annual Estimates of the Population Population NAAQS NAAQS

of Metropolitan and Micropolitan Statistical Areas: > 12.75 annual < 12.75 annual See Footnote

April 1, 2000 to July 1, 2006 (CBSA-EST2006-01) > 29.75 daily < 29.75 daily

> 1 million 3 2 Does Not Meet Requirements

500K - 1 million 2 1

50K - 500K 1 0

MSA MSA Required 2004 - 2006 2004 - 2006

ARB PQAO AIR BASINS Estimated PM2.5 Annual PM2.5 Daily # of PM2.5 # of PM2.5 PM2.5 Site Annual PM2.5 Site Daily

Metropolitan Statistical Areass (MSA) 2000 2006 Design Value Design Value SLAMS SLAMS Counties SLAMS Sites AQS # Design Values1 Design Values1

Micropolitan Statistical Areas (msa) Population Population (ug/m3

) (ug/m3) per CBSA* per CBSA* (ug/m3) (ug/m3)

1
North Central Coast / Salinas MSA 401,762 410,206 6.9 14 0 1 Monterey Salinas-High School 06-053-1003 6.9 14

North Central Coast / San Jose-Sunnyvale-Santa Clara MSA 1,735,819 1,787,123 2 1

2

San Benito None

North Central Coast / Santa Cruz-Watsonville MSA 255,602 249,705 7.0 16 0 1 Santa Cruz Santa Cruz-2544 Soquel Avenue 06-087-0007 7.0 16

North Coast / Crescent City msa 27,507 28,893 No Data No Data 0 0 Del Norte None

North Coast / Eureka-Arcata-Fortuna msa 126,518 128,330 13.4 25 0 2 Humboldt Eureka-I Street 06-023-1002 8.3 25

Eureka-Jacobs 06-023-1004 13.4 21

North Coast / Ukiah msa 86,265 88,109 6.7 16 0 1 Mendocino Ukiah-County Library 06-045-0006 6.7 16

North Coast / Santa Rosa - Petaluma MSA 458,614 466,891 No Data No Data 0 0 Sonoma (north) None

North Coast / No CBSA* 0 0 Trinity None

Northeast Plateau / Susanville, CA msa 33,828 34,715 No Data No Data 0 0 Lassen None

Northeast Plateau / No CBSA* 0 0 Modoc None

Northeast Plateau / No CBSA* 0 1 Siskiyou Yreka-Foothill Drive 06-093-2001 6.7 24

Salton Sea / El Centro MSA 142,361 160,301 12.5 40 1 3 Imperial Calexico-Ethel Street 06-025-0005 12.5 40

Brawley-220 Main Street 06-025-0007 8.6 22

El Centro-9th Street 06-025-1003 9.3 25

Riverside None

1. These Design Values are for the purpose of determining the minimum number of monitoring sites for MSAs. They are not intended for use in SIP planning or for designation purposes. 

2. The balance of required PM2.5 monitors in the San Jose-Sunnyvale-Santa Clara MSA are operated by the Bay Area AQMD

* CBSA - Core Based Statiscal Area is a term that refers collectively to metropolitan and micropolitan statiscal areas

MINIMUM PM2.5 MONITORING REQUIREMENTS

Source of 2006 population estimates - MSA DV > 85% DV < 085% Meets Requirements

US Census Bureau, Annual Estimates of the Population Population NAAQS NAAQS

of Metropolitan and Micropolitan Statistical Areas: > 12.75 annual < 12.75 annual See Footnote

April 1, 2000 to July 1, 2006 (CBSA-EST2006-01) > 29.75 daily < 29.75 daily

> 1 million 3 2 Does Not Meet Requirements

500K - 1 million 2 1

50K - 500K 1 0

MSA MSA Required 2004 - 2006 2004 - 2006

ARB PQAO AIR BASINS Estimated PM2.5 Annual PM2.5 Daily # of PM2.5 # of PM2.5 PM2.5 Site Annual PM2.5 Site Daily

Metropolitan Statistical Areass (MSA) 2000 2006 Design Value Design Value SLAMS SLAMS Counties SLAMS Sites AQS # Design Values1 Design Values1

Micropolitan Statistical Areas (msa) Population Population (ug/m3

) (ug/m3) per CBSA* per CBSA* (ug/m3) (ug/m3)

Sacramento Valley / Chico MSA 203,171 215,881 13.5 56 1 1 Butte Chico-Manzanita Avenue 06-007-0002 13.5 56

Sacramento Valley / No CBSA* 0 1 Colusa Colusa-Sunrise Blvd 06-011-1002 7.4 27

Sacramento Valley / No CBSA* 0 0 Glenn None

Sacramento Valley / Sacramento-Arden-Arcade-Roseville MSA 1,796,857 2,067,117 12.0 49 3 5 Placer (west) Roseville-N Sunrise Blvd 06-061-0006 10.2 38

Sacramento Sacramento-Del Paso Manor 06-067-0006 12.0 49

Sacramento-Health Dept Stockton Blvd 06-067-4001 10.5 39

Sacramento-T Street 06-067-0010 11.6 41

Yolo Woodland-Gibson Road 06-113-1003 9.4 30

Sacramento Valley / Redding MSA 163,256 179,951 7.7 22 0 1 Shasta Redding-Health Dept Roof 06-089-0004 7.7 22

Sacramento Valley / Vallejo Fairfield MSA 394,542 411,680 No Data No Data 0 0 Solano (east) None

Sacramento Valley / Yuba City MSA 139,149 161,806 10.3 40 1 1 Sutter Yuba City-Almond Street 06-101-0003 10.3 40

Yuba None

Sacramento Valley / Red Bluff msa 56,039 61,686 No Data No Data 0 0 Tehema None

San Joaquin Valley / Fresno MSA 799,407 891,756 17.2 59 2 3 Fresno Fresno-1st Street 06-019-0008 16.6 58

Fresno-Hamilton & Winery 06-019-5025 17.2 59

Clovis-N Villa Avenue 06-019-5001 16.4 56

2
San Joaquin Valley / Bakersfield MSA 661,645 780,117 18.9 64 2 3 Kern Bakersfield-5558 California Avenue 06-029-0014 18.5 62

Bakersfield-410 E Planz Road 06-029-0016 18.9 60

Bakersfield-Golden State Highway 06-029-0010 18.6 64

San Joaquin Valley / Hanford-Corcroan MSA 129,461 146,153 17.2 58 1 1 Kings Corcoran-Patterson Avenue 06-031-0004 17.2 58

San Joaquin Valley / Madera MSA 123,109 146,345 No Data No Data 0 0 Madera None

San Joaquin Valley / Merced MSA 210,554 245,658 14.7 45 1 1 Merced Merced-2334 M Street 06-047-2510 14.7 45

San Joaquin Valley / Stockton MSA 563,598 673,170 12.9 41 2 1 San Joaquin Stockton-Hazelton Street 06-077-1002 12.9 41

San Joaquin Valley / Modesto MSA 446,997 512,138 14.1 51 2 1 Stanislaus Modesto-14th Street 06-099-0005 14.1 51

San Joqauin Valley / Visalia - Porterville MSA 368,021 419,909 18.2 56 1 1 Tulare Visalia-N Church Street 06-107-2002 18.2 56

South Central Coast / SLO-Paso Robles MSA 246,681 257,005 8.0 22 1 2 San Luis Obispo San Luis Obispo-3220 South Higuera St 06-079-2006 6.9 16

Atascadero-Lewis Avenue 06-079-8001 8.0 22

South Central Coast / Santa Barbara - Santa Maria MSA 399,347 400,335 10.6 25 1 2 Santa Barbara Santa Maria-906 S Broadway 06-083-1008 7.7 18

Santa Barbara-700 East Canon Perdido 06-083-0011 10.6 25

South Central Coast / Oxnard-Thousand Oaks-Ventura MSA 753,197 799,720 11.4 30 2 4 Ventura Thousand Oaks-Moorpark Road 06-111-0007 10.5 27

Piru-3301 Pacific Avenue 06-111-0009 9.6 21

Simi Valley-Cochran Street 06-111-2002 11.4 30

El Rio-Rio Mesa School #2 06-111-3001 10.6 25

 

1. These Design Values are for the purpose of determining the minimum number of monitoring sites for MSAs. They are not intended for use in SIP planning or for designation purposes. 

* CBSA - Core Based Statiscal Area is a term that refers collectively to metropolitan and micropolitan statiscal areas

3
MINIMUM PM10 MONITORING REQUIREMENTS

Source of 2006 population estimates - High Medium Low

US Census Bureau, Annual Estimates of the Population Population Concentration Concentration Concentration Meets Requirements

of Metropolitan and Micropolitan Statistical Areas: DV = > 180 ug/m3 DV > 120 ug/m3 DV < 120 ug/m3

April 1, 2000 to July 1, 2006 (CBSA-EST2006-01) See Footnote

> 1,000,000 6 - 10 4 - 8 2 - 4

500K - 1,000K 4 - 8 2 - 4 1 - 2 Does Not Meet Requirements

250K - 500K 3 - 4 1 - 2 0 - 1

100K - 250K 1 - 2 0 - 1 0

MSA Required 2004 - 2006

ARB PQAO AIR BASINS Estimated PM10 # of PM10 # of PM10 PM10 Site 

Metropolitan Statistical Areass (MSA) 2000 2006 Design Value SLAMS SLAMS Counties SLAMS Sites AQS # Design Values1

Micropolitan Statistical Areas (msa) Population Population (ug/m3

) per CBSA* per CBSA* (ug/m3)

Great Basin / Bishop msa 17,945 17,980 8,299 0 6 Inyo Lone Pine-E Locust Street 06-027-0004 349

Olancha-Walker Creek Road 06-027-0021 428

Dirty Sox 06-027-0022 6277

Flat Rock-Highway 190 06-027-0024 610

Shell Cut-Highway 190 06-027-0025 8299

Coso Junction-Highway 395 Rest Area 06-027-1001 97

Keeler-Cerro Gordo Road 06-027-1003 3322

Great Basin / No CBSA* 0 4 Mono Mammoth Lakes-Gateway HC 06-051-0001 86

Lee Vining-SMS 06-051-0005 95

Mono Lake-Simis Residence 06-051-0007 110

Mono Lake North Shore 06-051-0011 1915

Great Basin / No CBSA* 0 0 Alpine None

Lake County / Clearlake msa 58,309 65,933 0 1 Lake Lakeport-Lakeport Blvd 06-033-3001 No Data

Lake Tahoe/Sacramento-Arden-Arcade-Roseville MSA 1,796,857 2,067,117 47 2 - 4 0 Placer (east)

1

2

El Dorado (east) South Lake Tahoe-Sandy Way 06-017-0011 47

Mojave Desert / Bakersfield MSA 661,645 780,117 65 1 - 2 2 Kern Mojave-923 Poole Street 06-029-0011 65

Ridgecrest-100 West California Avenue 06-029-0015 65

Mojave Desert / Los Angeles-Long Beach-Santa Ana MSA 12,365,627 12,950,129 63 2 - 4 1

3

Los Angeles Lancaster-43301 Division Street 06-037-9033 63

Mojave Desert / Riverside-San Bernardino-Ontario MSA 3,254,821 4,026,135 88 2 - 4 0 Riverside None

4 San Bernardino Barstow 06-071-0001 80

Hesperia-Olive Street 06-071-4001 58

Lucerne Valley 06-071-0013 64

Trona-Athol and Telegraph 06-071-1234 88

1. These Design Values are for the purpose of determining the minimum number of monitoring sites for MSAs. They are not intended for use in SIP planning or for designation purposes. 

2. The SMAQMD and ARB operate more than the required number os sites in this MSA. See the Sacramento Valley Air Basin.

3. SCAQMD operates PM10 sites in this MSA that exceed the required number of sites.

* CBSA - Core Based Statiscal Area is a term that refers collectively to metropolitan and micropolitan statiscal areas

MINIMUM PM10 MONITORING REQUIREMENTS

Source of 2006 population estimates - High Medium Low

US Census Bureau, Annual Estimates of the Population Population Concentration Concentration Concentration Meets Requirements

of Metropolitan and Micropolitan Statistical Areas: DV = > 180 ug/m3 DV > 120 ug/m3 DV < 120 ug/m3

April 1, 2000 to July 1, 2006 (CBSA-EST2006-01) See Footnote

1
> 1,000,000 6 - 10 4 - 8 2 - 4

500K - 1,000K 4 - 8 2 - 4 1 - 2 Does Not Meet Requirements

250K - 500K 3 - 4 1 - 2 0 - 1

100K - 250K 1 - 2 0 - 1 0

MSA Required 2004 - 2006

ARB PQAO AIR BASINS Estimated PM10 # of PM10 # of PM10 PM10 Site 

Metropolitan Statistical Areass (MSA) 2000 2006 Design Value SLAMS SLAMS Counties SLAMS Sites AQS # Design Values1

Micropolitan Statistical Areas (msa) Population Population (ug/m3

) per CBSA* per CBSA* (ug/m3)

Mountain Counties / No CBSA* 0 0 Amador None

Mountain Counties / No CBSA* 0 1 Calaveras San Andreas-Gold Strike Road 06-009-0001 42

Mountain Counties / Sacramento-Arden-Arcade-Roseville MSA 1,796,857 2,067,117 34 2 - 4 1

2

El Dorado Placerville-Gold Nugget Way 06-017-0010 34

Placer (central) None

Mountain Counties / No CBSA* 0 1 Mariposa Yosemite Village-Visitor Center 06-043-1001 133

Mountain Counties / Truckee-Grass Valley msa 92,033 98,764 0 0 Nevada None

Mountain Counties / No CBSA* 0 2 Plumas Quincy-N Church Street 06-063-1006 54

Chester-1st Ave 06-063-1007 64

Mountain Counties / No CBSA* 0 0 Sierra None

Mountain Counties / Phoenix Lake-Cedar Ridge msa 54,501 56,855 0 0 Tuolumne None

North Central Coast / Salinas MSA 401,762 410,206 49 0 - 1 2 Monterey Carmel Valley-Ford Road 06-053-0002 31

Salinas-High School 06-053-1003 49

North Central Coast / San Jose-Sunnyvale-Santa Clara MSA 1,735,819 1,787,123 45 2 - 4 1

3

San Benito Hollister-Fairview Road 06-069-0002 45

North Central Coast / Santa Cruz-Watsonville MSA 255,602 249,705 78 0 - 1 2 Santa Cruz Watsonville-Airport Boulevard 06-087-0004 40

Santa Cruz-2544 Soquel Avenue 06-087-0007 78

North Coast / Crescent City msa 27,507 28,893 42 0 1 Del Norte Crescent City-880 Northcrest Drive 06-015-0006 42

North Coast / Eureka-Arcata-Fortuna msa 126,518 128,330 68 0 1 Humboldt Eureka-I Street 06-023-1002 68

North Coast / Ukiah msa 86,265 88,109 57 0 3 Mendocino Fort Bragg-N Franklin Street 06-045-0002 57

Ukiah-County Library 06-045-0006 36

Willits-Firehouse 06-045-2001 38

North Coast / Santa Rosa - Petaluma MSA 458,614 466,891 37 0 - 1 3 Sonoma (north) Cloverdale 06-097-0001 37

Healdsburg-133 Matheson Street 06-097-0002 30

Guerneville-Church and 1st 06-097-3002 33

North Coast / No CBSA* 0 1 Trinity Weaverville-Courthouse 06-105-0002 161

1. These Design Values are for the purpose of determining the minimum number of monitoring sites for MSAs. They are not intended for use in SIP planning or for designation purposes. 

2. The SMAQMD and ARB operate more than the required number os sites in this MSA. See the Sacramento Valley Air Basin.

3. The BAAQMD operates additional sites in this MSA. There are a total of 5 PM10 sites in this MSA.

* CBSA - Core Based Statiscal Area is a term that refers collectively to metropolitan and micropolitan statiscal areas

MINIMUM PM10 MONITORING REQUIREMENTS

Source of 2006 population estimates - High Medium Low

US Census Bureau, Annual Estimates of the Population Population Concentration Concentration Concentration Meets Requirements

of Metropolitan and Micropolitan Statistical Areas: DV = > 180 ug/m3 DV > 120 ug/m3 DV < 120 ug/m3

April 1, 2000 to July 1, 2006 (CBSA-EST2006-01) See Footnote

> 1,000,000 6 - 10 4 - 8 2 - 4

2
500K - 1,000K 4 - 8 2 - 4 1 - 2 Does Not Meet Requirements

250K - 500K 3 - 4 1 - 2 0 - 1

100K - 250K 1 - 2 0 - 1 0

MSA Required 2004 - 2006

ARB PQAO AIR BASINS Estimated PM10 # of PM10 # of PM10 PM10 Site 

Metropolitan Statistical Areass (MSA) 2000 2006 Design Value SLAMS SLAMS Counties SLAMS Sites AQS # Design Values1

Micropolitan Statistical Areas (msa) Population Population (ug/m3

) per CBSA* per CBSA* (ug/m3)

Northeast Plateau / Susanville, CA 33,828 34,715 0 0 Lassen None

Northeast Plateau / Mo CBSA* 0 Modoc None

Northeast Plateau / Mo CBSA* 0 Siskiyou None

Sacramento Valley / Chico MSA 203,171 215,881 110 0 1 Butte Chico-Manzanita Avenue 06-007-0002 110

Sacramento Valley / No CBSA* 0 1 Colusa Colusa-Sunrise Blvd 06-011-1002 91

Sacramento Valley / No CBSA* 0 1 Glenn Willows-E Laurel Street 06-021-0002 135

Sacramento Valley / Sacramento-Arden-Arcade-Roseville MSA 1,796,857 2,067,117 110 2 - 4 1 Placer (west) Roseville-N Sunrise Blvd 06-061-0006 55

6 Sacramento North Highlands-Blackfoot Way 06-067-0002 110

Sacramento-Del Paso Manor 06-067-0006 71

Sacramento-3801 Airport Road 06-067-0013 90

Sacramento-Branch Center Road #2 06-067-0284 81

Sacramento-Health Dept Stockton Blvd 06-067-4001 64

Sacramento-T Street 06-067-0010 109

0 Yolo None

Sacramento Valley / Redding MSA 163,256 179,951 76 0 3 Shasta Shasta Lake-4066 La Mesa Avenue 06-089-0008 47

Redding-Health Dept Roof 06-089-0004 76

Anderson-North Street 06-089-0007 53

Sacramento Valley / Vallejo Fairfield MSA 394,542 411,680 56 0 - 1 0 Solano (east) None

Sacramento Valley / Yuba City MSA 139,149 161,806 63 0 1 Sutter Yuba City-Almond Street 06-101-0003 63

Yuba None

Sacramento Valley / Red Bluff msa 56,039 61,686 70 0 1 Tehema Red Bluff-Messer Drive 06-103-0002 70

1. These Design Values are for the purpose of determining the minimum number of monitoring sites for MSAs. They are not intended for use in SIP planning or for designation purposes. 

* CBSA - Core Based Statiscal Area is a term that refers collectively to metropolitan and micropolitan statiscal areas

MINIMUM PM10 MONITORING REQUIREMENTS

Source of 2006 population estimates - High Medium Low

US Census Bureau, Annual Estimates of the Population Population Concentration Concentration Concentration Meets Requirements

of Metropolitan and Micropolitan Statistical Areas: DV = > 180 ug/m3 DV > 120 ug/m3 DV < 120 ug/m3

April 1, 2000 to July 1, 2006 (CBSA-EST2006-01) See Footnote

> 1,000,000 6 - 10 4 - 8 2 - 4

500K - 1,000K 4 - 8 2 - 4 1 - 2 Does Not Meet Requirements

250K - 500K 3 - 4 1 - 2 0 - 1

100K - 250K 1 - 2 0 - 1 0

MSA Required 2004 - 2006

ARB PQAO AIR BASINS Estimated PM10 # of PM10 # of PM10 PM10 Site 

Metropolitan Statistical Areass (MSA) 2000 2006 Design Value SLAMS SLAMS Counties SLAMS Sites AQS # Design Values1

Micropolitan Statistical Areas (msa) Population Population (ug/m3

) per CBSA* per CBSA* (ug/m3)

3
Salton Sea / El Centro MSA 142,361 160,301 248 1 - 2 6 Imperial Calexico-Ethel Street 06-025-0005 188

Calexico-Grant Street 06-025-0004 248

Brawley-220 Main Street 06-025-0007 163

El Centro-9th Street 06-025-1003 146

Westmorland-W 1st Street 06-025-4003 201

Niland-English Road 06-025-4004 141

0

2 Riverside None

San Joaquin Valley / Fresno MSA 799,407 891,756 132 2 - 4 3 Fresno Fresno-1st Street 06-019-0008 117

Fresno-Drummond Street 06-019-0007 132

Clovis-N Villa Avenue 06-019-5001 104

San Joaquin Valley / Bakersfield MSA 661,645 780,117 154 2 - 4 3 Kern Bakersfield-5558 California Avenue 06-029-0014 153

Oildale-3311 Manor Street 06-029-0232 145

Bakersfield-Golden State Highway 06-029-0010 154

San Joaquin Valley / Hanford-Corcroan MSA 129,461 146,153 142 0 - 1 2 Kings Corcoran-Patterson Avenue 06-031-0004 140

Hanford-S Irwin Street 06-031-1004 142

San Joaquin Valley / Madera MSA 123,109 146,345 No Data 0 0 Madera None

San Joaquin Valley / Merced MSA 210,554 245,658 94 0 1 Merced Merced-2334 M Street 06-047-2510 94

San Joaquin Valley / Stockton MSA 563,598 673,170 82 1 - 2 2 San Joaquin Stockton-Hazelton Street 06-077-1002 82

Stockton-Wagner-Holt School 06-077-3010 69

San Joaquin Valley / Modesto MSA 446,997 512,138 97 2 - 4 2 Stanislaus Modesto-14th Street 06-099-0005 96

Turlock-S Minaret Street 06-099-0006 97

San Joqauin Valley / Visalia - Porterville MSA 368,021 419,909 141 1 - 2 1 Tulare Visalia-N Church Street 06-107-2002 141

1. These Design Values are for the purpose of determining the minimum number of monitoring sites for MSAs. They are not intended for use in SIP planning or for designation purposes. 

2. SCAQMD operates two PM10 SLAMS in Riverside County at Indio and Palm Springs (Coachella Valley)

* CBSA - Core Based Statiscal Area is a term that refers collectively to metropolitan and micropolitan statiscal areas

MINIMUM PM10 MONITORING REQUIREMENTS

Source of 2006 population estimates - High Medium Low

US Census Bureau, Annual Estimates of the Population Population Concentration Concentration Concentration Meets Requirements

of Metropolitan and Micropolitan Statistical Areas: DV = > 180 ug/m3 DV > 120 ug/m3 DV < 120 ug/m3

April 1, 2000 to July 1, 2006 (CBSA-EST2006-01) See Footnote

> 1,000,000 6 - 10 4 - 8 2 - 4

500K - 1,000K 4 - 8 2 - 4 1 - 2 Does Not Meet Requirements

250K - 500K 3 - 4 1 - 2 0 - 1

100K - 250K 1 - 2 0 - 1 0

MSA Required 2004 - 2006

ARB PQAO AIR BASINS Estimated PM10 # of PM10 # of PM10 PM10 Site 

Metropolitan Statistical Areass (MSA) 2000 2006 Design Value SLAMS SLAMS Counties SLAMS Sites AQS # Design Values1

Micropolitan Statistical Areas (msa) Population Population (ug/m3

) per CBSA* per CBSA* (ug/m3)

South Central Coast / SLO-Paso Robles MSA 246,681 257,005 146 1 - 2 6 San Luis Obispo Paso Robles-Santa Fe Avenue 06-079-0005 59

Morro Bay 06-079-3001 60

Nipomo-Regional Park 06-079-4002 71

Nipomo-Guadalupe Road 06-079-2004 146

Atascadero-Lewis Avenue 06-079-8001 58

Carrizo Plains School-9640 Carrizo 06-079-8006 55

South Central Coast / Santa Barbara - Santa Maria MSA 399,347 400,335 83 0 - 1 3 Santa Barbara Santa Maria-906 S Broadway 06-083-1008 54

El Capitan Beach 06-083-0008 50

Lompoc-S H Street 06-083-2004 83

4
South Central Coast / Oxnard-Thousand Oaks-Ventura MSA 753,197 799,720 119 1 - 2 3 Ventura Ojai-Ojai Avenue 06-111-1004 60

Simi Valley-Cochran Street 06-111-2002 74

El Rio-Rio Mesa School #2 06-111-3001 119

 

1. These Design Values are for the purpose of determining the minimum number of monitoring sites for MSAs. They are not intended for use in SIP planning or for designation purposes. 

* CBSA - Core Based Statiscal Area is a term that refers collectively to metropolitan and micropolitan statiscal areas

5