## QUALITY ASSURANCE PROGRAM PLAN

for the



## LEAD (Pb) 

## AMBIENT
AIR MONITORING NETWORK



# Interim 

# Final

Prepared by:

Arizona Department of Environmental Quality

Air Quality Division
1110 W. Washington Street
Phoenix AZ 85007

Version 1.0
October 201 1A.l TITLE and APPROVAL PAGE



### Title: Quality Assurance Program Plan for the Arizona Department of Environmental Quality
Lead (Pb) Ambient Air Monitoring Network

ADEQ has prepared this Quality Assurance Progranl Plan (QAPP) following the EPA Requirenrents.for Quality Assurcrnce Project Plans (EPA QA/R-5) dated Marcli 200 1, the EPA C;rtidance./br Quulity
Assuruncc. Project Plans (EPA QMG-5) dated December 2002, the EPA Region 9 Requiremenis,for Quulily A.~surance Progruin Plun (R9QA/A03) dated March 20 1 0, and the ADEQ Q~lality Murrugerneir t Plan dated August 20 10. Additions to this QAPP will be made to reflect planning for Pb air monitoring

at JLG Supersite and pending additional guidance from EPA.

'This quality assurance program plan is hereby recornmended for approval and co~nmits the Department to follow tlie clenients described within.

Arizona Department of Environmental Quality

[>ate: 

# +A&/

Signature: 

# &L-%+

; &2 Date: 

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Bernard Lum, Manager, Air Monitoring IJnit

Signature: Date: 

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Quality Assurancc Unit

Signature:

Date: 

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Julie kioskin, Laboratory & Quality Assurance Manager, ADEQ

signature: 

# ~'/h~k~~u Date:

I EPA Region 9

Eugenia McNaughton, Quality Assurance Manager, EPA Kegion 9

Signature: Date:

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# - ADEQ Pb Ambient Air Monitoring Network QAPP
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2LIST OF F IGURES

FIGURE A.1 PB AIR MONITORING PROGRAM ORGANIZATIONAL CHART ..........................................9

FIGURE B.1 PHOTOGRAPHS OF THE GLOBE HIGHWAY SITE .................................................................24

FIGURE B.2 PHOTOGRAPHS OF THE MIAMI GOLF COURSE SITE .........................................................26

FIGURE B.3 PHOTOGRAPHS OF THE JLG SUPERSITE ...............................................................................28

FIGURE B.4 CONT INUOUS DATA COLLECTION SY STEM HARDWARE ARCHITECTURE ..............50

FIGURE C.1. ADEQ INTERNAL AUDIT FINDING FORM .............................................................................65

FIGURE C.2 ADEQ AUDIT RESPONSE FORM ................................................................................................66

FIGURE C.3 ADEQ AQD NON-CONFORMING EVENT FORM ....................................................................74

FIGURE D.1 AAAD DCS SECONDARY QUALITY ASSURANCE SCREEN .................................................82

LIST OF TABLES

TABLE A.1 ADEQ AIR QUAL ITY DIVISION (AQD) PB PROGRAM PERSONNEL .....................................8

TABLE A.2 PIMA COUNTY WA STEWATER RECLAMATION LABORATORY PERSONNEL ..............11

TABLE A.3 SUMMARY OF ADEQ DOCUMENTS AND RECORDS ...............................................................19

TABLE A.4 SUMMARY OF PCWR L DOCUMENTS AND RECORDS ...........................................................21

TABLE B.1 SITE AND METADATA INFORM ATION FOR THE GLOBE HIGHWAY SITE .....................23

TABLE B.2 SITE AND METADATA INFORMAT ION FOR THE MIAMI GOLF COURSE SITE ..............25

TABLE B.3 SITE AND METADATA INFO RMATION FOR THE JLG SUPERSITE ....................................27

TABLE B.4 LEAD (PB) AIR MO NITORING PLAN PER SITE .........................................................................32

TABLE B.5 ANALYTICAL METHODS FOR PB HIGH-VOL TSP SAMPLES ...............................................34

TABLE B.6 HIGH VOLUME TSP SAMPLER SPECIFICATIONS ...................................................................36

TABLE B.7 INSPECTION OF FIELD ITEMS ......................................................................................................37

TABLE B.8 PREVENTATI VE MAINTENANCE OF FIELD ITEMS ................................................................38

TABLE B.9 STANDARD MATERIAL S AND/OR APPARATUS FOR PB TSP CALIBRATION AND
VERIFICATION

............................................................................................................................... ........................ 41

TABLE B.10 ACCEPTANCE CRITER IA FOR HIGH VOL+ TSP LEAD (PB) SAMPLERS OPERATING
IN ACTUAL CONDITION

............................................................................................................................... ....... 42

TABLE B.11 LABORATORY ACCEPTANCE CRITERIA ................................................................................43

TABLE B.12 CRITICAL FIELD SUPPLIES AND CONSUMABLES ................................................................46

TABLE B.13 SUMMARY OF DATA RECORDS STORED AT ADEQ .............................................................60

TABLE C.1. EXTERNAL ASSESSMENT SUMMARY ......................................................................................68

TABLE C.2. INTERNAL ASSESSMENT SUMMARY .......................................................................................68

TABLE D.1 ADEQ QUALITY ASSURANCE LEV ELS FOR FILTER-BASED AND CONTINUOUS
MEASUREMENTS

............................................................................................................................... .................... 78

TABLE D.2 DATA VALIDATION CODE TYPES ...............................................................................................79

TABLE D.3 PB HIGH-VOLUME (T SP) VALIDATION TEMPLATE ...............................................................89

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4A.3 DISTRIBUTION LIST

For the Arizona Department of Environm ental Quality – Air Quality Division

Theresa Rigney, Assessment Section Manager

Vacant, Evaluation Unit Manager

Bernard Lum, Air Monitoring Unit (AMU) Manager

Ralph Lucero, Lead, Technician, AMU

Greg Kendal, Lead, Operator, AMU

John Olasin, Supervisor, Air Filter Laboratory

Bryan Paris, Manager, Data Management & Quality Assurance (DM&QA) Unit

Ceresa Stewart, Lead, QA/QC, DM&QA

Andy Clifton, QA Auditor, DM&QA

Heather Colson, Lead, Pb Data Reviewer, DM&QA

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5SECTION A. PROGRAM MANAGEMENT

A.4 PROGRAM ORGANIZATION

This Quality Assurance Program Plan (QA PP) describes ADEQ’s Lead (Pb) Monitoring Network for collecting source-orie nted and non-source-oriented data for airborne Pb particles. The purpose of this QAPP is to provide an outli ne of the Pb program’s technical plan and associated environmental data operation (EDO), the key project personnel, and the data quality objectives to be achieved by the program. Th e QAPP communicates to all ADEQ parties the specifications for implementing this program’s design in one clear, concise, and complete
document.

The effectiveness of quality assurance/quality control (QA/QC) depends on field and laboratory procedures following program specifications. Air monitoring procedures will be carefully followed and QA/QC principles a nd practices will be stringently applied to the EDO. In the event questions arise or additi onal information is needed rega rding elements of this air monitoring program such as the sampling plan, in strumentation operation and QC requirements, data and measurement quality objectives, assessments, reports to management, or data management, the contact information for key pr ogram personnel is provided in this document.

This QAPP includes information regarding the analysis method for Pb filter samples and the QA/QC procedures followed by the independent an alytical laboratory for the Pb network, the Pima County Wastewater Reclam ation Laboratory (PCWRL), i.e ., contract laboratory. This entity is performing work for ADEQ under a serv ice agreement or Interg overnmental Agreement (IGA) and is responsible for ma naging their own QA/QC programs as required in their Quality Manual and internal standard operating procedur es (SOPs) which are referenced in the QAPP and provided as attachments. The PCWRL is peri odically audited by the Ar izona Department of Health Services (ADHS) and the ADEQ QA Team will review these audit reports as they become available. In addition, the QA Team ma y conduct technical systems audits of PCWRL. The SOP for the EPA Region 9 analytical labora tory performing the analyses of quarterly QA/QC Pb Performance Evaluati on Program (PEP) samples is also included in this QAPP. ADEQ will cooperate with both analytical labo ratories regarding pertinent information concerning the collection, preservation, shipment, analysis, and reporting of sample results.

ADEQ is responsible for collec ting air filter samples, arrang ing for sample analyses, and applying accepted quality assurance (QA) practices to the field opera tions as well as data review and validation. The ADEQ Air Assessment Sect ion (AAS) is responsible for the Pb air monitoring network. All AAS personnel worked t ogether as a team in launching this new
network. Personnel from several Units within the AAS are involved with the network. Key responsibilities for each Unit are:

 Within the Evaluation Unit (EU), an air mode ler was responsible fo r identifying potential sites where the highest airborne Pb concentra tions are expected using meteorological data collected by the source(s). A senior environm ental engineer was responsible for finding

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6physical locations that m et EP A criteria and final sites were approved by EPA Region 9 program representatives.

 Within the Air Monitoring Unit (AMU), the ma nager and several staff were responsible for selecting, testing, and installing Pb sample rs at each site. Technicians tested the new samplers in-house before deploying to the air m onitoring sites. Once inst alled at the sties, the technicians evaluated the new samplers’ performance in the field, performed trouble shooting on flow issues, and developed th e standard operating procedure (SOP) for properly operating the samplers and collecting air filter samples. The program’s lead operator is responsible for filter sample collection.

 Within the Air Filter Laborator y (AFL), the lab supervisor is responsible for preparing unexposed filters for sampling, sub-sampling (cutting filter samples into strips for analysis), shipping sub-samples to the PCWRL, and archiving the remaining samples in case they are needed for future reference. The lab supervisor also prepares and manages the shipment of the quarterly Pb PEP QA sample to the Region 9 laboratory. The lab supervisor was responsible for the developm ent of the AFL SOPs. A senior laboratory analyst is responsible for support (backup) sample handling services when needed.

 Within the Data Management & Quality Assu rance (DM&QA) Unit, the selection of sites and the modeling results were reviewed by th e Unit manager and toxics data reviewer who also prepares the agency’s network plans. The Pb data reviewer is responsible for monthly data validation, reporting the Pb data to the EPA’s Air Quality System (AQS), and developing an SOP for these validation and reporting procedures. The QA Auditor is responsible for performance evaluation (PE) a udits on the samplers, the associated SOP, and coordinating the EPA PEP audits. The QA/ QC Lead is responsible for maintaining the official, approved Quality Assurance Pr ogram Plan and serving as a backup field auditor. Both the QA Auditor and the QA/QC Lead are responsible for additional QA assessment such as technical system audits . The QA/QC Lead established the Pb Team and will be responsible for coordinating meetings as needed. DM&QA staff also correspond with PCWRL staff and review the laboratory reports as part of the data review and QA process.

 The AAS Manager is responsible for securi ng program funding, serving as a liaison to EPA Region 9, and providing leadership and guidance to all Unit personnel involved with
the Pb network.

Table A.1 shows ADEQ personnel involved with the Pb air m onitoring program and their responsibilities. Figures A.1 and A.2 provide organizational charts of the ADEQ Air Quality Division (AQD) personnel involved with the Pb program. As shown on the chart, the QA Team is housed in the DM&QA Unit and is independent from the Air Monitoring Unit which generates the Pb filter samples.

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7INTERIM FINAL - ADEQ Pb Ambient Air Monitoring Network QAPP
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8 Table A.1 ADEQ Air Quality Divisi on (AQD ) Pb Program Personnel

Lead (Pb) Ambient Air Monitoring Program

Name and Title Role Responsibilities Contact
Information

Theresa Rigney, Environmental Program Manager Air Assessment
Section Manager Program manager and liaison to Region 9 program lead 602-771-2274 tr3@azdeq.gov

Bernard Lum, Environmental Program Supervisor Air Monitoring Unit Manager Air Monitoring Unit operations and
deliverables 602-771-2364 bvl@azdeq.gov Randy Redman, Environmental Engineer Site
Coordinator Site establishment and liaison to site

owners 602-771-2278 rrr@azdeq.gov

Ralph Lucero, Environmental Program Specialist Lead, Monitoring
Technician Air monitoring instrument maintenance & troubleshooting 602-771-2390 rvl@azdeq.gov

Greg Kendall, Environmental Health Specialist, II Lead, Site Operator QA Level 1 reviews, sample collection, instrument verifications
and calibrations 602-771-2258 gwk@azdeq.gov

Terry Taflinger, Environmental Program Specialist Lead, Service Report
Reviewer Reviews all AMU field service reports for completeness and

correctness 602-771-2392 tkt@azdeq.gov

John Olasin, Environmental Program Specialist Laboratory Supervisor Pb filter handling, sub-sampling, shipping, receiving, and archiving 602-771-2345 jro@azdeq.gov Kanika Simmons, Environmental Health Specialist, II Laboratory Support Alternate for filter lab operations 602-771-2241 ks5@azdeq.gov Bryan Paris, Environmental Program Supervisor DM&QA Manager Data Management and Reporting, QA/QC logistics and deliverables 602-771-7665 bp2@azdeq.gov Mark Carrel, Information Technology Specialist,

III Lead,
Continuous
Data Reviewer Continuous data collection, DCS operations, QA Level 2 reviews 602-771-2359 mwc@azdeq.gov

Heather Colson, Environmental Health Specialist, II Lead, Pb Data
Reviewer QA Level 3 Pb data reviewer and AQS data entry 602-771-4488 hc2@azdeq.gov

Jon Midgley, Environmental Program Specialist Toxics Data
Reviewer &
Network Plan
Coordinator Pb data review support & network plan development and review 602-771-2356 jm9@azdeq.gov

Ceresa Stewart, Environmental Program Specialist Lead, QA/QC QA Team, QAPP, QA oversight; technical system audits (TSA) 602-771-2297 cs5@azdeq.gov Andy Clifton, Environmental Health Specialist, II QA Auditor QA Team, air monitoring instrument audits and TSA support 602-711-4382 agc@azdeq.gov Feng Mao, Environmental Program Specialist Air Modeler Prepare air models in support of identifying air monitoring sites 602-711-4529 mf8@azdeq.gov

Kami Budhu, Program and Project Specialist I Administrative
Assistant Procurement of goods and services 602-711-2370 kb2@azdeq.govFigure A.1 Pb Air MonitoringProgramOrganizational ChartLead (Pb) ProgramFunctional/Staff ChartTheresa RigneyAir AssessmentSection ManagerKami BudhuAdministrativeAssistantBernard LumAir Monitoring UnitManagerBryan ParisDM&QA UnitManager(Vacant)Evaluation UnitManagerRandy RedmanSite CoordinatorFeng MaoAir ModelerGreg KendallLead Site OperatorJohn OlasinAir Filter LabSupervisorRalph LuceroLead MonitoringTechnicianKanika SimmonsAlternateLaboratory SupportJon MidgleyToxic DataReviewerCeresa StewartLead QA/QCHeather ColsonLead DataReviewerAndy CliftonQA AuditorTerry TaflingerLead ServiceReport ReviewerMark CarrelLead ContinuousData ReviewerINTERIM FINAL -ADEQ Pb Ambient Air Monitoring Network QAPPOctober 20119INTERIM FINAL -ADEQ Pb Ambient Air Monitoring Network QAPPOctober 201110Figure A.2 ADEQ Air Quality Division Organizational ChartPCWRL is responsible for providing analytical la boratory services as st ipulated in the IGA. Responsibilities includ e: analyzing Pb air fi lter samplers according to approved method EQL0510-191, archival of solubilized filter samples for a period of 30 days minimum and reporting analytical results in a timely manner to ADEQ.

Table A.2 shows key personnel with PCWRL.

Table A.2 Pima County Wastewater Reclamation Laboratory Personnel

Program Title: Pb Ambient Air Monitoring Program

Name and Title Role Responsibilities Contact Information

Barbara Escobar, Laboratory Director Executive Project
Director and Interagency
Liaison Program Oversight & Contract
Liaison Barbara.Escobar@wwm.pima.gov (520) 443-6052

Nancy Powell, Quality Assurance Officer Quality

Assurance
Officer Quality Management Plan, QA Oversight, Pb Pep Sample
coordination Nancy.Powell@wwm.pima.gov (520) 443-6183

Belinda Gamboa-Felix,
Environmental Data Project Supervisor Data Management and Analytical Reports Report and data deliverables Belinda.GamboaFelix@wwm.pima.gov (520) 443-6007

Richard Aros, Chemical Specialist Inorganic
Chemical Lab Supervisor Analytical laboratory logistics
and deliverables Richard.Aros@wwm.pima.gov (520) 443-6065

Melissa Bomar, Laboratory Chemist Lead Analyst Sample preparation and analysis Bomar.Melissa@wwm.pima.gov (520) 443-6065

EPA Region 9 is responsible for the following activities in support of this program:

• Reviewing, providing assistance wi th, and approving this QAPP.

• Responding to requests for technical and policy information and interpretations.

• Evaluating quality system performance thr ough technical systems audits, performance evaluations, and network reviews as appropriate.

• Making available to ADEQ the technical and quality assurance information developed by EPA, and making the ADEQ aware of any un met quality assurance needs in a timely

manner.

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11A.5 PROBLEM DEFINITION/BACKGROUND

On November 12, 2008, the U.S. EPA published the Final Rule for lowering the National Ambient Air Quality Standards (NAAQS) for ambi ent airborne concentrations of Pb from 1.5μg/m 3 to 0.15μg/m 3 for both the primary and secondary standards. Lead is one of six criteria pollutants identified by the EPA. Stationary s ources are thought to be the major emitter of airborne Pb, but mobile sources contribute as well. The revised air quality standards for Pb are
found in 40 CFR Part 50.16 – National Ambient Ai r Quality Standards for Lead; Final Rule November 12, 2008 (see 73 FR 67052). The primary and secondary NAAQS became effective on January 12, 2009. Monitoring and quality assura nce requirements for Pb are found in 40 CFR Parts 53 and 58. There are no anticipated end dates for the air monitoring of Pb particulate under
either standard.

The primary standard was revised to better public healt h, especially in “sensitive” populations which include asthmatics, children, and the elderl y. An array of adverse health effects can be attributed to Pb exposure incl uding neurocognitive and neurobeh avioral effects in children. Initially, Pb monitoring was require d near sources that emit more than one ton of Pb per year. EPA later revised the Pb monitoring requirements to include monitoring n ear sources that emit more than 0.5 tons of Pb per year.

To comply with the current primary NAAQS, ADEQ will operate two source-oriented sites east of the Phoenix metropolitan area near the towns of Hayden and Miami. The sites are near copper smelting facilities operated by ASARCO, Inc. a nd Freeport McMoRan, Inc., respectively. Tables and figures showing maps and metadata for thes e sites can be found in Section B. The mining and smelting operations release Pb particulate into the atmosphere. The rationale for siting
stations in their current location can be found in Attachments A and B.

ADEQ started monitoring for ambient Pb in th ese two areas at the beginning of the 4 th quarter 2010. The EPA required Pb monitoring at the beginning of 2010, but ADEQ funding limitations delayed the purchase of the new instrumenta tion until the summer of 2010. In addition to ADEQ’s Pb sampling near Hayden, additional E DOs under the direction of EPA Region 9 are ongoing in a portion of the area which is designated as a Superfund site.

In addition to the required m onitors near sources of Pb, EP A‘s Revised Lead Ambient Air Monitoring Requirements also requires Pb monito rs to be placed in large urban areas. Pb monitors are required at NCore sites that are located within Core Based Statistical Areas (CBSAs) with a population of 500,00 0 people or more. To meet this requirement, ADEQ will
ascertain Pb concentrations in the Phoenix metropolitan area at ADEQ’s NCore site: JLG Supersite. It is possible th at Pb concentrations generated from the speciated PM 10 filter sample
used for the National Air Toxics Trends Sta tion (NATTS) may be used. ADEQ is awaiting a
final determination for use of these data fr om EPA. Monitoring at the JLG Supersite is anticipated to begin in December, 2011. The collec tion of Pb samples at the JLG Supersite will satisfy concurrent monitoring requirements for both the Pb NAAQS and the NCore program.

ADEQ serves as the Primary Quality Assura nce Organization (PQAO) for all primary and secondary NAAQS Pb air monitoring data collected throughout the State of Arizona with the exception of Maricopa and Pima Counties. Maric opa and Pima Counties are each designated as a

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12PQAO by EPA Region 9, and they are responsible for all asp ects of their Pb air monitoring network in the event they operate one.

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13A.6 PROGRAM DESCRIPTION

The principal objective of the Pb network is to m easure the concentration of Pb in ambient air. ADEQ will use data collected from the Pb monitoring network to:

 Determine total suspended particulate (TSP) concentrations of airborne Pb for comparison to the NAAQS

 Ascertain the impact regulated sources have on air quality in their vicinity

 Provide an estimate of the reason ableness of source-oriented sites
selected based on air shed models and to adjust site locations if needed

 Determine the level of ambient airb orne Pb occurring in the Phoenix Metropolitan area

 Support the development and implementation of a SIP (if required)

 Produce high quality data for decision makers (data users) such as public health officials assessing the potential ill health effects associated with
Pb

For the source-oriented Pb m onitoring, ambient air samples w ill be collected onto 8X10 inch fibrous glass filters using high-volume TSP samp lers as required by EPA. Samples will be collected on the EPA 1/6 day national air monitoring schedule which is found at: http://www.epa.gov/ttn/amtic/calendar.html . See Attachment C for the 2011 schedule. Collocated samples will be collected on every 1/ 6 sample run day and one of the non-required collocated samples will be used for the EPA Pb PEP program. The PCWRL will analyze samples using the EPA approved method EQL 0510-191; Dete rmination of Lead in TSP Using ICPMS with Heated Ultrasonic Digestion.

For the non-source-oriented Pb monitoring, ADEQ plans to use a PM 10 low-volume sampler for the collection of Pb at JLG Supersite. Info rmation concerning the Pb monitoring at JLG Supersite will be added to this QAPP as it becomes available.

Meteorological instrumentation will also be utilized at the Pb sites in support of the Pb program. Data generated from these instruments may provi de useful information regarding the source or origin of Pb in ambient air. Monitoring me thods and objectives for meteorological monitoring are addressed in a separate QAPP.

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14A.7 QUALITY OBJECTIVES and CRITERIA

ADEQ will follow the data quality objectives (DQO) and measurement quality objectives (MQO) developed by the U.S. EPA. EPA utilized the DQO process to determine appropriate precision and bias MQO. Once DQOs are established, the quality of the data must be evaluated and controlled to verify that it is maintain ed within the established acceptance criteria.

Data Quality Objectives

DQOs are defined as the qualitati ve and quantitative statements derived from the DQO process that clarify the study’s technical and quality objectives, define the appropriate types of data, and specify the tolerable error of deci sions that will be made from the data. DQOs are used to assess the adequacy of data (new or existing) in relation to the intended use. EPA utilizes the DQO process to determine appropriate MQOs for pr ecision and bias. ADEQ w ill adhere to the DQOs and MQOs developed by the EPA.

Measurement Quality Objectives

Overall MQOs/Measurement Uncertai nty for the Pb program are:

 Precision goal will be ≤ 20% CV for a 90% confidence lim it coefficient of variation, and

 Overall absolute bias upper bound goal is ≤ 15% at the 95% c onfidence limit.

The measure of precision will be determined fr om the collocation results and will only include Pb concentration data > 0.02 μg/m 3 . The measure of absolute bias will be determined by the PEP program results. EPA will assess these goals on three years of data at the PQAO level of aggregation. ADEQ will assess these goals both annually and on a three year basis.

MQOs are designed to evaluate a nd control various phases of the measurement process to ensure that total measurement uncertain ty is within the range prescr ibed by the DQOs. As QA/QC data
are collected and evaluated over the course of the Pb program, MQOs may be revised or updated based on the initial results. MQOs can be defined in terms of the following data quality indicators (DQI):

DQIs for the Pb program are:

 Representativeness – a measure of the degree to wh ich data accurately and precisely represent a characteristic of a population, parameter variations at a sampling point, a process condition, or an environmental condi tion. Representativeness is controlled largely by the site location and type of air samplers used.

 Precision

– is the measure of mutual agreemen t among individual measurements of the same property usually under prescribed sim ilar conditions. This is the random component of error. Precision is estimated by various st atistical techniques us ing some derivation of the standard deviation (based upon monitoring calibration and verifications). Precision is determined using collocated sampling results and routine verifications.

 Bias – the systematic or persistent distor tion of a measurement process which causes
error in one direction. Bias will be determined by estimating the positive and negative

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15deviation for the true value as a percentage of the true valu e. Bias is determ ined by Pb
PEP filter results and routine PE audits.

 Detectability – The determination of the low range cri tical value of a characteristic that a method specific procedure can reliably discer n. The Pb TSP samplers collect particulate matter with aerometric diameter of up to 50 micrometers. The method sensitivity for the analysis of Pb TSP samples using ICPMS is adequate for determining Pb at concentrations equal to, or le ss than, 5% of the NAAQS (0.15 μg/m 3 ).

 Comparability (reporting units and analysis) – Pb concentrations will be reported in micrograms/meter cubed (μg/m3) as require d by EPA for air monitoring organizations.

 Completeness – a measure of the amount of valid data obtained from the measurement system compared to the amount that was e xpected to be obtained under correct, normal conditions. The minimum data completeness re quirement set by EPA is 75% for a rolling three-month average.

To ensure 75% data completeness, ADEQ is targeting 85% completeness for the collection of Pb samples. To meet 85% completeness, no more than two (2) sample run days can be missed per quarter. To meet 75% completeness, no more than three (3) sample run days can be missed per three-month period. ADEQ will attempt to make-up any missed sampling event within 7 days of the missed sample run date if feasible to do

so.

A variety or errors can result in a sample be ing missed or an analytical result not being
available. These include:

1. Sampling error such as instrument failure or malfunction

2. Collection error such as damaging a filter during retrieval

3. Shipping error such as a shipment being lost

4. Laboratory error such as a filter being damaged prior to analysis

5. Quality assurance/quality control error such as PE audit failures and analytical laboratory cr iteria not being met

All monitoring instruments will be operated w ithin the acceptance criteria defined by ADEQ, which meet or exceed the minimum EPA requirements. Operating criteria for the TSP samplers are found in Section B and in the ADEQ Pb Va lidation Template found in Section D. This template is also used for the validation of data.

Additional information concerning ADEQ’s air monitoring plan per site can be found under Sampling Methods on Table B.4 and under Analytic al Methods on Table B.5. If any instrument fails its verification, calibration, or performa nce evaluation (PE) audit, AMU will take the appropriate actions to correct in strument performance as quickly as possible to prevent missing scheduled sample collection days.

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16A.8 SPECIAL TRAINING/CERTIFICATIONS

The TISCH HIGH-VOL+ TSP air samplers pur chased by ADEQ for source-oriented Pb monitoring had not been operated by AQD prior to 2010. In previous years, early versions of high-volume TSP samplers were used for particulate air monitoring. However, use of those samplers was discontinued years ago due to mo re sophisticated low-volume samplers becoming the required method for particulate matter sampli ng and the requirement to sample for airborne Pb being lifted after sufficiently low levels of Pb were detected in Arizona for a suitable period
of time.

ADEQ conducts on-the-job training as the primar y means of training personnel. New staff are assigned to work with an experienced staff for a period of one to three months. Staff must pass
an initial demonstrati on of capability (IDOC) before work ing independently on air monitoring
instruments. Staff also review instrument manuals, monitoring literature, EPA regulations and take trainings offered on-line. Additionally, all staff’s program knowledge is reviewed annually by the unit manager.

AQD strives to provide professi onal development to employees whenever possible. Training includes courses, workshops, conferences, or trad e shows. In addition, employees participate in webinars provided by EPA and comp lete self-instructional course s available through EPA’s Air Pollution Training Institute (APTI).

In addition, the technical staff involved in th e Pb program have access to the ADEQ QMP, all QAPPs, Standard Operating Procedures (SOPs) and other guidance such as manufacturer’s operating manuals. Management will provide sufficien t time to the personnel directly involved in this project, including fi eld technicians, to read and understand these documents.

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17A.9 DOCUME NTATION AND RECORDS

Staff within the AAS use the J drive on our shar ed network for storing documents electronically in addition to maintaining hard copies of program-related docu mentation. The network drive is backed up daily by ADEQ Information Technolo gy. Documents are stored for a minimum of five years.

The modeling reports developed by the Evaluation s Unit for source-oriented site selection are provided in Attachments A and B and electronic copies are found in each sites respective folder at: J:\AQD\AQD\ASSESS\M ONITORING UNIT\SITE_L OG\ADEQ Active Sites.

AMU service documents, aka, field sheets, relate d to the operation of ai r monitoring sites and instruments are generated and stored in hardcopy site files and/or electronically in each site’s folder at: J:\AQD\AQD\ASSESS\MONITORING UNIT\SITE_LOG\ADEQ Active Sites. Field sheets include: site logs, instrument logs, co mmunication logs, instrument verification and calibration sheets, site and instrument change forms, and field service reports. The hardcopy reports are reviewed and approved by the AMU Pb field sheet reviewer then routed to the QA/QC Lead for review and approval. The QA/QC Lead records the services rendered on an Outlook calendar used as a “quick look” re ference for AMU, AFL and DM&QA personnel. Next, the field sheets are routed to the lead Pb data reviewer for use during data review and validation. DM&QA uses these docume nts for Level 3 data validation.

The AFL manages the ADEQ Lead TSP Air Sampling Record, e.g., chain-of-custody (COC) and/or field data form, associated with each sa mple. An original and two copies are produced with each form using no-carbon-required sheets. The original accompanies the sample when it is sent to the analytical laboratory. A copy is maintained by the AMU operator and by AFL along with the shipment records.

In addition, the QA Auditor submits the PE audi t sheets to the QA/QC Lead for review and approval and then the reports are forwarded to th e Lead Pb Data Reviewer and the QA Team will submit any technical system audit (TSA) repor ts to the DM&QA Unit Manager for approval. Once approved, the report is sent to th e AAS Manager and the AMU Manager.

The QA Team plans to generate control charts for the Pb program once enough data are collected to be statistically significant.

A record of data collected from the Pb network will be archived by ADEQ in the Air Assessment Ambient Database (AAAD) for future reference by th e agency and other interested parties. Data will be uploaded to the EPA AQS database as required by EPA.

PCWRL maintains all laboratory records separately from ADEQ’s Air Assessment Section, the type of records maintained, the location they are stored, and the person responsible for maintaining these records are li sted with the table below.

Table A.3 shows the documents and records that are generated in conjunction with the Pb

program.

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18Table A.3 Summary of ADEQ Documents and Records

Type of Record Medium Data Storage Location(s) Responsibility

AQS Reports Electronic J:\AQD\AQD\ASSESS\DATA MANAGEMENT AND QA UNIT\DM\Programs\NAAQS\Lead DM&QA

Calibration and verification records Hardcopy and electronic DM&QA Site File or
J:\AQD\AQD\ASSESS\MONITORING UNIT\SITE_LOG\ADEQ Active Sites
and DM&QA Site File AMU and DM&QA

Certificates for all

instruments and standards Hardcopy and Electronic DM&QA Site File, AMU instrument files
J:\AQD\AQD\ASSESS\MONITORING UNIT\SITE_LOG\ADEQ Active Sites and AMU and DM&QA

Corrective Action Reports Hardcopy and Electronic DM&QA Site Files or
J:\AQD\AQD\ASSESS\DATA MANAGEMENT

AND QA UNIT\Quality Assurance\Corrective Actions QA Team

Custody and field data forms Hardcopy and Electronic AMU COC Files or
J:\AQD\AQD\ASSESS\DATA MANAGEMENT

AND QA UNIT\DM\Programs\NAAQS\Lead AMU, DM&QA, and PCWRL

Data Review/Validation

forms and notes Electronic J:\AQD\AQD\ASSESS\DATA MANAGEMENT AND QA UNIT\DM\Programs\NAAQS\Lead DM&QA

Downloaded files from samplers with QC data Electronic J:\AQD\AQD\ASSESS\MONITORING UNIT\Airlab\Field Instruments\Field Instrument Data (Palm Data)\Lead Sites AMU

Lab validated data sets sent from the laboratory to ADEQ including metadata Electronic J:\AQD\AQD\ASSESS\DATA MANAGEMENT AND QA UNIT\DM\Programs\NAAQS\Lead DM&QA

Maintenance and

service records Hardcopy AMU Instrument File and DM&QA Site File AMU and DM&QA

Pb QAPP Hardcopy and electronic Hardcopies provided to AMU and DM&QA staff

and
J:\AQD\AQD\ASSESS\QUALITY ASSURANCE DOCUMENTS\QAPPs QA Team

Quality Assurance

Audit Records (includes all audit reports, e.g., PE audit, TSA, ADQ, etc.) Hardcopy and electronic DM&QA Site Files and J:\AQD\AQD\ASSESS\DATA MANAGEMENT AND QA UNIT\AUDITS DM&QA

Raw Data Electronic J:\AQD\AQD\ASSESS\DATA MANAGEMENT AND QA UNIT\DM\Programs\NAAQS\Lead DM&QA and PCWRL

Sample Preparation

notes Hardcopy and Electronic Notes stored at PCWRL and available upon request by ADEQ PCWRL

Shipping and receiving records Hardcopy AMU Shipping File AMU/AFL

Site and instrument logbooks Hardcopy Site logbook stored at site until closure Instrument logbook travels with sampler until retired – then in AMU AMU and DM&QA

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19Type of Record Medium Data Storage Location(s) Responsibility

Site Information Hardcopy and Electronic Network Plan
J:\AQD\AQD\ASSESS\DATA MANAGEMENT AND QA UNIT\DM\Docs\AQD\Reports

And
J:\AQD\AQD\ASSESS\MONITORING UNIT\SITE_LOG AMU and DM&QA

Site Photographs Hardcopy and Electronic Network Plan
J:\AQD\AQD\ASSESS\DATA MANAGEMENT AND QA UNIT\DM\Docs\AQD\Reports

And
J:\AQD\AQD\ASSESS\MONITORING UNIT\SITE_LOG AMU and DM&QA

SOPs Hardcopy and Electronic Hardcopies provided to AMU and DM&QA staff

and
J:\AQD\AQD\ASSESS\QUALITY ASSURANCE DOCUMENTS\SOPs\Current SOPs (AMU AFL DM&QA)\Lead (Pb) QA Team

Training records Hardcopy Unit Manager’s Staff Files and
J:\AQD\AQD\ASSESS\QUALITY ASSURANCE DOCUMENTS\TRAINING_RECORDS\Internal (Employee) AAS

Validation documents and notes Electronic J:\AQD\AQD\ASSESS\DATA MANAGEMENT AND QA UNIT\DM\Programs\NAAQS\Lead DM&QA

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20Table A.4 shows the PCWRL docum ents and records generated for the Pb program.

Table A.4 Summary of PCWRL Documents and Records

Type of Record Medium Data Storage Location(s) Responsibility

Audit Records Hardcopy and electronic Arizona Department of Health Services ADHS Lab Licensure

Calibration and verification records Electronic PCWRL ICPMS computer for each run - backed up on cd. Lab

Certificates for all instruments and standards Hardcopy and Electronic PCWRL X:\CRAO\Lab Svcs\_Shared Data\Lab\Intelex Certificates of Analysis\Inorganic Z:\Dir Div\CRAO\Lab Svcs\_Shared

Data\Lab|Sapphire Certificates of Analysis\Inorganic Lab - Nancy Powell, , hard copies
Richard Aros, electronic on Z drive

Control Charts Electronic PCWRL Files Hardcopy in Supervisor’s Office Hard copy only by Importing data into qc program and printing graphs. Audit Strips: Z:\Dir Div\CRAO\Lab Svcs\_Shared Data\Lab\Inorganic Unit\Inorganic Unit Lab – Nancy Powell, hard copies

Richard Aros

Corrective Action Reports Electronic PCWRL Files X:\CRAO\Lab Svcs\_Shared Data\Lab\Corrective Action\Inorganic\EQL TSP air filters Lab – Nancy Powell

Chains of Custody Hardcopy & Electronic PCWRL Files, Electronic PDF’d with Final Report Lab – Belinda Gamboa

Data Review/Validation forms and notes Hardcopy and electronic PCWRL Files Hardcopies in Supervisor’s Office, Electronic Sapphire Approvals Lab - Richard Aros & Nancy Powell

Digestion Log Hardcopy and Electronic Notes stored at PCWRLP and available upon request by ADEQ

Z:\Dir Div\CRAO\Lab Svcs\Shared Data\Lab\Inorganic Unit\Inorganic Unit\Digestion Logs\Pb Air Filters Lab – Melissa Bomar

Instrument logbooks Hardcopy PCWRLP benchtop Lab – Melissa
Bomar

Maintenance and service records Hardcopy PCWRL in Instrument Logbooks Lab - Melissa Bomar & Belinda Gamboa

Raw Data Electronic PCWLRP Instrument based computers ICPMS computer and backed up on cd Lab – Richard Aros

SOPs Hardcopy and Electronic PCWRLP Files \\spsaphire1\SOP , Intelex Lab
QA/ QC Unit

Training records Hardcopy and Electronic PCWRLP FilesX:\CRAO\Lab Svcs\_Shared Data\Lab\trainingfiles Lab – Nancy Powell

Final Reports Hardcopy and Electronic PCWRLP FilesX:\CRAO\Lab Svcs\_Shared Data\Lab\trainingfiles Lab – Nancy Powell

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21SECTION B. DATA GENE RATION and ACQUISITION

B.1 SAMPLING PROCESS (NETWORK) DESIGN

Site Selection

Siting of Pb samplers meets 40 CFR Part 58 Appendix E.

Source-Oriented Monitoring Sites

Site selection was based on the location where the highest level of airborne Pb concentration is expected to occur, the pote ntial for population exposures, an d the feasibility of operating samplers. To determine locations that represen t the highest concentrations of airborne Pb, dispersion modeling and existing en vironmental data were used. This information was compared to the location of the population and the ability to obtain power, avoid obst acles that obstruct air movement, provide sufficient security to en sure sample custody a nd integrity, and safe accessibility for personnel. A review of all factors combined with consultation from the Region 9 contact, yielded th e following locations:

1. Globe Highway (near ASARCO)

2. Miami Golf Course (n ear Freeport-McMoRan)

Non-Source-Oriented Monitoring Site

Site selection was based upon the NCore requirements and the need for sampling to occur in CBSAs where the population is greater than 500,000 people.

1. JLG Supersite (in Phoenix)

See Tables B.1, B.2, and B.3 for site and metada ta information and Figures B.1, B.2, and B.3 for photographs concerning the above sites. See Attachment A and B for source-oriented siting
rationales.

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22Table B.1 Site and Metadata Information for the Globe Highway Site

Globe Highway Site Purpose : NAAQS compliance network and a source permit requirement.

This site is the location for the Pb monitoring in Hayden . ASARCO mine also maintain s a sulfur dioxide analyzer at the site. This site is used to meet the Pb collocation requirement.

Site Information AQS ID 04-007-1002 ADEQ ID 16593

Address SR 77 Winkelman, AZ 85292 County Gila Groundcover Gravel

CBSA Payson Latitude 33.002 Surrounding Area Residential Longitude -110.765

Distance to road 5 m – W Elevation 602 m

Traffic count n/a Site Established Date 01/01/1975

Monitoring Information

Pollutant/Atmospheric parameter Pb Wind Temp/RH Network or Program SLAMS ADEQ-MET ADEQ-MET

Monitor location at site Platform Tower Tower Monitoring objective Source Population Population Spatial scale Middle Neighborhood Neighborhood Monitor type TSP Anemometer Probe Analysis method High-Vol None None

Lab analysis method Inductively CoupledArgon PlasmaOptical Emission

Spectrometry
-- -- Make of monitor Tisch RM Young Rotronics

Model of monitor TE-5170-BL 5103 MP101A

Method code 191 40
-- Monitor start date 10/1/2010 4/14/2011 4/14/2011 Sampling schedule 1 in 6 Continuous Continuous Sampling duration 24 hour Hourly Hourly Sampling season All year All year All year

In climate controlled shelter N N N Probe height from ground 3 m 10 m 2 m

Probe distance from structure

-- -- 1 m

Distance from closest obstruction

-- -- -- Distance from trees 1.5 m 4 m 4 m Unrestricted airflow degrees 360° 360° 300°

Dist. between collocated monitors 2 m Monitor audit frequency Quarterly Annual Annual Flow rate verification frequency Every 12 days

-- --

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23Figure B.1 Photographs of the Globe Highway Site

Site Photos

Aerial view of Globe Highway Shelter, towers, and TSP monitors at Globe Highway – 5/10/2011

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24Table B.2 Site and Metadata Informatio n for the Miami Golf Course Site

Miami Golf Course Site Purpose : NAAQS compliance network and a source permit requirement.

This site is the location for the Pb monitoring in Miam i. Freeport McMoRan also main tains two particulate matter
monitors at the site.

Site Information AQS ID 04-007-8000 ADEQ ID 16629

Address SR 188 and US 60 Miami, AZ 85539 County Gila Groundcover Gravel

CBSA Payson Latitude 33.4190 Surrounding Area Residential Longitude -110.8296

Distance to road 230 – E Elevation 1000 m

Traffic count n/a Site Established Date 01/01/1997

Monitoring Information

Pollutant/Atmospheric parameter Pb Wind Temp/RH Network or Program SLAMS ADEQ-MET ADEQ-MET

Site monitor located Miami Golf Course Miami Golf Course Miami Golf Course

Monitor location at site Platform Tower Tower Monitoring objective Source Population Population Spatial scale Middle Neighborhood Neighborhood Monitor type TSP Anemometer Probe Analysis method High-Vol None None

Lab analysis method Inductively CoupledArgon PlasmaOptical Emission

Spectrometry
-- -- Make of monitor Tisch RM Young Rotronics

Model of monitor TE-5170-BL 5103 MP101A

Method code 191 40
-- Monitor start date 10/1/2010 6/8/2011 6/8/2011 Sampling schedule 1 in 6 Continuous Continuous Sampling duration 24 hour Hourly Hourly Sampling season All year All year All year

In climate controlled shelter N N N Probe height from ground 3.5 m 10 m 2 m

Probe distance from structure

-- -- 1 m

Distance from closest obstruction

-- -- -- Distance from trees 5 m
-- -- Unrestricted airflow degrees 180° 360° 360° Monitor audit frequency Quarterly Annual Annual Flow rate verification frequency Every 12 days

-- --

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25Figure B.2 Photographs of the Miami Golf Course Site

Site Photos

Aerial view of Miami Golf Course Fenced Miami Golf Course site – 07/2011

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26Table B.3 Site and Metadata Information for the JLG Supersite
JLG Supersite Site Purpose : NAAQS compliance network, PAMS, NATTS, STN, NCore, AIRNow, AQI forecasting, monitor urban haze, and meteorological support.

The site was established to represent air quality in the central core of the Phoenix metropolitan area. The surrounding area is primarily reside ntial neighborhoods, with I-17 roughly 1,609

meters west.

Site Information AQS ID 04-013-9997 ADEQ ID 16328

Address 4530 N. 17 th Ave. Phoenix, AZ 85015

County Maricopa Groundcover Gravel

CBSA Phoenix-Mesa-Scottsdale Latitude 33.5038 Surrounding Area Residential Longitude -112.0957

Distance to road 8.5 m – E Elevation 354 m

Traffic count 20,214 – Campbell Ave. Site Established Date 07/01/1993

Monitoring Information
Pollutant/Atmospheric parameter Pb Network or Program SLAMS

Site monitor located JGL Supersite

Monitor location at site Metal Roof Monitoring objective

-- Spatial scale

-- Monitor type

-- Analysis method

-- Lab analysis method

-- Make of monitor

-- Model of monitor

-- Method code

-- Monitor start date

-- Sampling schedule 1 in 6 Sampling duration 24 hour Sampling season All year

In climate controlled shelter N Probe height from ground

-- Probe distance from structure

-- Distance from closest obstruction

-- Distance from trees

-- Unrestricted airflow degrees

-- Monitor audit frequency Quarterly Flow rate verification frequency Every 12 days

NOTE: The above table only shows information con cerning the Pb sampler at JLG Supersite.

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27Figure B.3 Photographs of the JLG Supersite

Site Photos

Aerial view of JLG Supersite Eastern side of JLG Supersite – 09/2008

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28Monitoring Plan

The objective of this work is to quantify the amount of airborne Pb, a toxi c metal, near regulated sources emitting 0.5 tpy or more and the ambien t level of Pb occurring in CBSAs. Continuous meteorological data will also be collected at each site. Measurement error will be kept at minimum by following the established acceptance criteria for air monitoring instruments found in Section B7. There is no anticipated end date for operating the Pb network.

Each calendar year, a total of 60 - 61 routine samp les will be collected on the primary samplers following the 1/6 day monitoring schedule, aka sample run day. A total of 60-61 collocated samples will be collected on the secondary sa mpler at the Globe Highway site. Initially, collocated samples will be collected on the 1/6 day monitoring schedule. ADEQ may elect to revert to the EPA 1/12 day schedule for collocat ion in the future. Each quarter one collocated sample collected on a non-required 1/6 day monitoring schedule will be used for the EPA’s Pb PEP. ADEQ’s plan is to use th e first non-required 1/6 collocated sample for the PEP. If for any reason the Pb PEP sample is not successfully collected on that day, ADE Q will default to using the next non-required collocated sample. ADEQ will continue to default to the next possible 1/6 sample run day that is not a required 1/12 sample run day in the event collection problems arise. An example of the national monitoring schedul e is provided in Attachment C. Near the beginning of each calendar year, the annual schedule will be obtained from EPA here: http://www.epa.gov/ttn/amtic/calendar.html

.

Again, to meet 85% data completeness targeted fo r sample collection, only two (2) filter-based samples can be missed for each three-month peri od. To meet the minimum requirement of 75% data completeness, only three (3) filter-based samples can be missed. Completeness will be based on rolling three-month periods, rather than calendar quarters. AMU will strive to keep data completeness ≥ 85% to reduce the need for coll ecting makeup or extra samples.

Make-up Samples

The EPA makeup sample requirements for the Pb program are aligned with the PM 10 and PM 2.5 requirements. Makeup samples will be collected according to the following guideline:

 If a TSP sampler fails to collect a valid samp le at a site on the regularly scheduled 1/6 sample day run day, then a makeup sample will be collected at the site prior to the next run day if possible using the unsampled filt er provided for the next scheduled run (a replacement filter will be obtained for the next scheduled run day), OR

 on the 7 th day following the missed event

Since sequential samplers are not in-use, meeti ng the makeup requirements could pose logistical challenges in the field. Timely communication among the Pb Team regarding any sample loss is important and will allow field staff to plan for makeup samples as needed providing as much leeway as possible.

Any additional, valid samples collected outside the makeup sample timeframe requirements will be considered extra samples. The Pb concentrat ions from these samples are useful and will be

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29used in design value calculations that are com p arable to the Pb NAAQS; however, extra samples can not be used for data completeness purposes.

Field Blanks

Field blanks will be collected for each sampler at a frequency of 10%. A field blank will be
collected on the 10 th run day following the start of sampling for each calendar year.

Site Accessibility

The source-oriented sites are located near or adjacent to major state highways making them easily accessible for service and sample collection. It is possible that samp le collection could be interrupted if a site becomes inaccessible tempor arily due to unusual circumstances such as a road closure, wildfire, or a hazardous condition that was not previously present. If this occurs, ADEQ personnel will not attempt to access the site for sample collection or any other purpose until the area has been cleared and reopened by th e proper authorities. Field personnel will report the site closure information to their direct supe rvisor and the program ma nager will be alerted to
the incident as well. Each incident of site inacc essibility and the need fo r possibly establishing an alternate site or relocating an existing site will be handled on a case-by-base basis.

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30B.2 SAMPLING METHODS

Lead (Pb) Air Sample Collection

The objective of the Pb sample collection is to eval uate whether or not air borne levels of Pb are compliant with the NAAQS. The collection of Pb filter samples is critical for this network.

For source-oriented sites, ADEQ will use high-volume total suspended particulate (TSP) samplers to collect filter-based samples from mi dnight to midnight every sixth day following the EPA’s Monitoring Schedule. These samplers meet EPA’s requirements for the collection of Pb samples. AMU personnel will maintain and operate these samplers according to AMU-Pb-001 SOP. The QA Auditor will aud it the samplers according to QA-013 SOP. Each TISCH TSP sampler contains a microprocessor with the abil ity to store sample run summary data and 5- minute interval data, a scan diskette for data backup and retrieval, a pump, a step-up transformer (added per the manufacturer’s recommendation to ach ieve the required flow rate due to altitude at the source-oriented sites), and an automated mass flow controller. Me nu-driven software is used to program these samplers so they opera te according to the required sampling schedule. These samplers do not use size-selective inlets and can collect particles up to 50 micrometers (μm) in aerometric diameter depending on meteor ological conditions. The samplers will operate in Actual Conditions (AC), also known as Lo cal Conditions (LC). Again, Table B.4 shows the air monitoring instruments and the sa mple collection plan for each site.

Samples will be collected onto 8X10 inch fibrous glass filters supplied annually by the EPA. These filters are assumed to meet all regulator y and acceptance criteria established by EPA prior to receipt. AFL will receive these filters and prepare them for sampling by assigning sample
identification numbers to each filter , loading the filters into each sampler’s filter holder cassette, and preparing the associated ADEQ Lead TSP Air Sampling Record for each sample to be collected. This process follows the AFL-Pb-001 SO P. The filters will not be weighed before or after sampling to determine a PM concentr ation because ADEQ does not currently own a microbalance that can accommodate the 8X10 inch filter size. ADEQ may elect to weigh filters in the future. AFL will receive exposed sample f ilters from the field operator, sub-sample each filter, and prepare and coordinate shipments of Pb filter sample strips to PCWRL according to
the AFL-Pb-002 SOP. All SOPs are included as a ttachments to this QAPP. Sub-sampling refers to the process of cutting the filter into strips that are to be used for laboratory analysis.

Sample volume is provided by each sampler in the summary data. Interval data files are checked
to ensure that an over or under run did not occu r. Sample volume is periodically checked by hand using the following equation:

Sample Volume = (Collection Time ) (Average Ambient Flow Rate)

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31Table B.4 Lead (Pb) Air Monitoring Plan per Site

ADEQ

Site
(Abbreviation) Instruments (Quantity/Type/ Operating Mode/Designatio n) Measurements Collection
Media Collection Frequency
Duration &
Time Annual Quantity
of Samples

Planned Scale

1/TISCH HIGHVOL+ TSP/AC/Primary 8” X 10” fibrous glass
filter 1/6 day
23 – 25 hours midnight to midnight 60-61

1/ TISCH HIGHVOL+
TSP/AC/Second

ary Pb particles up to 50μm aerodynamic
diameter depending on meteorological
conditions 8” X 10” fibrous glass
filter 1/6 day
23 – 25 hours midnight to midnight 60-61

(30-31 are required
from 1/12 day schedule; 4 are PEP;
remainder

are extra samples) 1/RM Young
Model
5103/Wind
Monitor/
Continuous Wind speed and
direction Direct read -
electronic
communicat
ion to data logger Hourly values
with 5 minute
max wind speed N/A HAGH*

1/Vaisala HMP

45C T&RH
Sensor/Continuo

us Temperature and relative humidity Direct read -
electronic
communicat
ion to data logger Hourly values
with 5 minute
max wind speed N/A Middle

1/TISCH HIGHVOL+ TSP/AC/Primary Pb particles up to 50μm aerodynamic
diameter depending on meteorological
conditions 8” X 10” fibrous glass
filter 1/6 day
23 – 25 hours/ midnight to midnight 60-61

1/RM Young
Model
5103/wind
monitor/
Continuous Wind speed and
direction Direct read -
electronic
communicat
ion to data logger Hourly values
with 5 minute
max wind speed N/A MIGC

1/Vaisala HMP

45C T&RH
Sensor/Continuo

us Temperature and relative humidity Direct read -
electronic
communicat
ion to data logger Hourly values
with 5 minute
max wind speed N/A Middle

JLG Reserved Neighborhood

* Collocated Site Key: HAGH = Globe Highway
MIGC = Miami Golf Course JLG = JLG Supersite

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32B.3 SAMPLE HANDLING AND CUSTODY

Sample handling and custody is one of the most important aspects of a quality system. Sample handling procedures must be consistently follo wed to provide data meeting the DQOs. Currently, EPA does not require that Pb filter samples be collected within a certain timeframe, or that they be chilled to a specific temperature, or analy zed within a certain number of days following collection. ADEQ plans to collect filter samples within 6 days following each run day, usually within 48 hours. The samples will be handled as carefully as possible to prevent loss of particulates from the filters. The samples do not need to be chilled and there is no holding time limit. However, shipments of sample strips to the analytical laboratory will be done in a timely manner to ensure adequate time for analysis , and the reporting a nd validation of data.

To protect a sample from tampering and to ensure that a sample’s history and integrity is known, a chain-of-custody accompanies each sample. The ADEQ LEAD TSP Air Sampling Record serves as the chain-of-custody as well as the sample co llection data card for each sample generated. A sample is considered to be in custody if it is in one’s actual physical possession, is stored in a
secured area restricted to au thored personnel as found with the AFL or AMU office/lab/shop area, or when it is in view after being in one’s possession such as when the a sample is being relinquished for shipping or analys is at an analytical laboratory.

To ensure each sample’s integrity while installe d in a sampler, each Pb air monitoring site is protected from trespassers or unaut horized persons using security fe ncing that is at least 6 feet high with razor or barb wire in stalled around the top. The access gate of the station is padlocked and the sampler’s shelter door is kept locked as well.

To prevent loss of material from exposed filte r samples during handling, the exposed filter is quickly covered with a filter hol der faceplate following the retrac tion of the sample saver shield. The filter cassette holder is carefully removed fr om the sampler, placed into a plastic zipper storage bag, and then placed into a site-specific transport case which further protects the sample from disturbance during transport to AFL.

To prevent sample contamination, each filter cassette holder and filter holder faceplate is cleaned following sample collection and pr ior to the next unexpos ed filter being prepared for the next sample run day. The Pb operator cleans dust from the surface inside the sampler and from the sample saver shield prior to ea ch sample collection. The tools used for sub-sampling, i.e., cutting a filter into strips for analysis , are cleaned following each use.

More details concerning filter handling and custody can be found in the SOPs which are provided as attachments.

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33B.4 ANALYTICAL METHODS

Laboratory Analyses

AFL receives filter samples from the AMU operator. AFL cuts the filter samples into strips (sub-sample), verifies information on the chain- of-custody (COC)/data information sheets, and ship samples and all required documentation to the PCWRL on a monthly basis. The frequency of shipments will be adjusted as needed.

Arizona law requires that any laboratory perf orming analysis for environmental compliance purposes be licensed by the ADHS for the anal ytical method. Table B.5 shows the approved EPA analytical method or equivalency for determ ining the concentration of Pb in TSP samples
as well as the ADHS license number for PCWRL. The PCWRL Quality Manual (QM) and SOPs are found as attachments within this QAPP. PCWR L will provide the laboratory analysis results on a monthly basis.

The Manual Equivalent Method: EQL-0510-191, “Determination of Lead Concentration in TSP by Inductively Coupled Plasma Mass Spectrome try (ICP-MS) with Heated Ultrasonic Nitric and Hydrochloric Acid Filter Extraction,” is approved for analyzing TSP Pb filter samples collected according to 40 CFR Appendix B to Part 50, EPA Reference Method for the Determination of Suspended Particulate Matter in the Atmosphere (High-Volume Method) . The method uses a portion of the 8X10” filter sample which is immersed into an acid solution, heated to 80oC and sonicated for one hour, brought to a final volu me of 40 mL, and analyzed by ICPMS based on
EPA SW-846 Method 6020A.

Table B.5 Analytical Methods for Pb HIGH- VOL TSP Samples

Parameter EPA Method Licensure# Analytical Method Laboratory

Pb – applies to routine primary & secondary samples, field blanks, audit strips EQL-0510-191 AZ Dept. of
Heath
Services - # AZ0159 ICP-MS with Heated Ultrasonic Digestion Pima County

Wastewater
Reclamation Laboratory, Tucson, AZ

Pb – applies to quarterly PEP sample EQL-0710-192 Not applicable Heater Nitric Acid Hot Block Digestion and ICP/MS Analysis forLead (Pb) on TSP HighVolume Filters US EPA Region 9 Laboratory, Richmond, CA

The quarterly collocated Pb PEP filter samples are shipped to:

USEPA Region 9 Laboratory Bldg. 201
1337 South 46 th St Richmond, CA 94804-4600 Phone: 510-412-2389

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34B.5 QUALITY CONTROL

Quality control (QC) is the overall system of tec hnical activities that measure the attributes and performance of a process against established standards to verify that performance meets the stated requirements established by the decisi on maker or data user. Information on data
validation and verification can be found in Section D.

To assure the quality of data from air monito ring measurements, two distinct and important interrelated functions must be pe rformed. One function is the cont rol of the measurement process through broad quality assurance activities such as establishing policies and procedures, developing DQOs, assigning roles and responsibili ties, conducting overs ight and technical system review, and implementing corrective ac tions. The other function is the control of measurement error by implementing specific quality control checks at established frequencies to ensure the TSP high-volume samplers operate within specified criteria. Quality control procedures include, but are not limited to: certif ication of calibration equipment as required, calibrations, verifications, PE audits, collocati on of samplers, proper maintenance and care of sampling, calibration and analytical instruments, a nd participation in the national EPA Pb PEP.

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35B.6 INSTRUMENT TESTING, IN SPECTION, AND MAINTENANCE

The purpose of this element is to discuss the proc edures used to verify that all instruments and equipment are maintained in the proper condi tion and are capable of operating at acceptable performance levels. Inspection and acceptance of filter sample media is discussed as well.

To prevent an interruption in the collection of Pb filter samples and to ensure DQIs are met, ADEQ strives to keep all critical supplies and consumables in stock such as fibrous glass filters, calibrators (references) , spare parts for instrumentation, a nd if possible, backup samplers and meteorological monitors. Supplies and consumable s are inspected for defects prior to use and their availability in -house is monitored by the AMU l ead technician and operator.

ADEQ plans to use only Pb high volume TSP samp lers that meet 40 CF R Part 50 Appendix B specifications. Currently, Pb samplers do not have manufacturer-speci fic federal reference method (FRM) or federal equivalent method (FEM ) designation. Prior to being deployed to a site, new air monitoring instruments are tested in the AMU Shop to verify that they are working properly and that they meet the general FRM re quirements. Instruments are properly maintained following the manufacturers’ requirements in conjunction with recommendations of technical personnel in AAS. Specifications include:

Table B.6 High Volume TSP Sampler Specifications

Criteria Acceptable Range Citation/
Information Design Criteria

- seal filter to housing without leaks

- filter convenient to change

- adjustable flow rate Operational Flow Range Operate within 1.1 to 1.7 m 3 /min (39 – 60 CFM) Operational Set Point 1.13 m 3 /min (actual conditions) (40 CFM) Part 50 App B sec 7.2.1

Motor Capable of reliably operating for continuous 24 hr periods Part 50 App B sec 7.2.4

Sampler Shelter

- Rectangular with gabled roof

- Protects filter from precipitation/weather

- Exhaust discharge 40 cm from inlet

- Designed to minimize collection of dust by incorporating a baffle between exhaust and the supporting surface

- Filter in horizontal position at least 1 m above supporting surface Part 50 App B sec 7.3.1

Sample Cover

- Uniform inlet on all sides

- Air velocity between 20 and 35 cm/sec (0.66 - 1.15 ft/sec)

- Recommended velocity 25 cm/sec + 2 (0.82 ft/sec + 2) Part 50 App B sec 7.3.2

Filter Exposed Area (nominal) 406.5 cm 2 (63 in 2 ) Part 50 App B sec 7.1.2

NOTE: Criteria verified prior to purch ase of sampler/start of sampling

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36The m ain component of ensuring correct instrument operation is through routine verifications. As mentioned previously, the fre quency of these routine verificatio ns may change as the program gets well established, but the procedures for performing the verifications will remain the same.
The flow rate from the instrument is verifi ed by using a water manometer following ambient temperature and pressure verifi cations. All of this information is used in a calculation to determine the flow, and this flow calculation is compared to the set point of the instrument. Refer
to the AMU-Pb-001 SOP in the attachments for de tails pertaining to the verification procedures. Table B.10 also contains some common acceptance criteria associated with these verifications.

Inspection of Field Items

There are several items that need routine inspection in the field before and after a Pb sample has
been collected. Table B.7 shows th e inspections performed in the field before and after sample
collection.

Table B.7 Inspection of Field Items

Item Inspection Frequency Inspection

Paramete r Action if Item Fails Inspection Documentation Requirement

Filter holder cassette including the following
components:

 2-part metal
frame

 (2) Thumb (finger) nuts

 Metal wire
mesh filter
holder
support

screen

 (2) 8x10”
silicon gaskets Before and
after each

run Any damage (warps, cracks, other signs of wear)

AND

Visible particulate or foreign objects Replace

Clean with a cloth using amended
water or other
surfactant
solution such as
Windex Document in sampler and site logbooks; on AMU Field Service Report
and/or other AMU
form

Same as above

Filter Holder Faceplate Before and
after each

run Any damage Replace Document in sampler and site logbooks and AMU Field Service Report Filter holder gasket (rubber gasket
located between
filter holder and blower motor) Semiannually Any damage Replace Document in sampler and site logbooks; on AMU Field Service Report
and/or other AMU
form

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37Preventative Maintenance of Field Items

There are many field items associated with approp riate preventative maintenance of a successful field program. Table B.8 details th e appropriate maintenance checks of the Pb samplers and their frequency. Details on maintaining this instrume nt and laboratory information can be found in
the associated SOP.

Table B.8 Preventative Maintenance of Field Items

Instrument Item Maintenance Frequency Responsible Party Location
Maintenance
Performed

Filter holder
cassette silicon gaskets Replace every 3

years OR Replace if found compromised in any way during routine inspection
or when leak is
present AMU Operator

OR AFL Supervisor
or support analyst AFL

Rubber filter holder gasket Replace annually AMU Operator
or Technician In field at site

Wire mesh
filter holder
support screen Clean monthly AMU Operator

OR AFL Supervisor or Support Analyst AFL

CPU backup power battery Replace biannually AMU Operator
or Technician In field at site

Sampler hood and sampling
chamber Clean before and after each sample
collection event AMU Operator In field at site

Brushless

motor Replace every 8 years or sooner if
motor function is compromised AMU Operator
or Technician In field at site or in AMU ShopTISCH HIGHVOL+

Control and pump box Clean monthly AMU Operator
or Technician In field at site

NOTE: Adjustments in routine, preventative main tenance frequencies will be made as needed once a strong operating history is establishe d and based upon the operational demands on the samplers.

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38B.7 INSTRUMENT CALIBRATION AND FREQUENCY

Calibration is defined as the comparison of a m easurement standard, instrument, or item with a standard or instrument of higher accuracy to de tect and quantify inaccuracies and to report or eliminate those inaccuracies by adjustment. Use of the term “calibration” indicates that an adjustment either in the instrument or the soft ware occurred. EPA recomm ends that adjustments be minimized to prevent introducing measuremen t uncertainty and that verifications, “checks without correction”, be used to confirm whether or not an instrument is operating within the acceptable operating range.

The purpose of calibration is to minimize bias. Typi cally, calibration activities follow a two-step

process.

1. Certifying the calibration sta ndard and/or transfer (wor king) standard against an authoritative standard, usually the Nationa l Institute of Standards and Technology (NIST).

2. Comparing the routine sampling or analytical instrument against a calibration or transfer
standard.

The following calibrations are typically performed in the field:

 Verification/calibration of volumetric flow rate meter or mass flow control meter of each sampler against the transfer standard;

 Verification/calibration of sampler temperatur e and pressure sensor s against the working temperature and pre ssure standard; and

 Verification/calibration of sampler’s internal clock against a NIST-traceable timepiece such as a cell phone, GPS, or atomic watch.

The primary standard for calibrating the TISCH HIGH-VOL+ samplers is an orifice (top hat) manufactured by TISCH. A water manometer w ill be used to verify and calibrate the
instrument’s flow rate. Flow verifications are performed manually by th e field technicians and
are conducted in ambient conditions . Flow calibrations ar e initiated by field technicians, but the calibration process is an automated process. Du e to instrumentation limitations, calibrations are performed in standard conditions. Prior to the auto-calibration procedur e, the calibration flow range in standard conditions (SC) is entered by the technician so that the equivalent ambient flow range brackets the set point equally on both sides. The flow range may vary from site to site, based on differences in ambient temperature a nd pressure. See the AMU-Pb-001 SOP for exact calibration flow ranges for sites with TSP sample rs. The equivalent ambient flow rates were calculated for each site, based on typical meas urements of temperat ure and pressure. The calibration flow rates are determined by the dig ital manometer within the instrument. While the digital manometer cannot be verified during the calibration process, it is verified during the flow verifications. If the on-board dig ital manometer is out of tolerance during the flow verification, a Pcal (inches of water) calibrati on is conducted. For more details on the calibration procedure, see the AMU SOP in the attachments. A digital temp erature and pressure device will be used for verifying ambient temperature and barometric pressure. One-point temperature and pressure
verifications are conducted at the same frequency as the flow ve rifications. The high frequency

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39of one-point verifications allows for an assessm ent of the tem perature and pressure sensors over a wide range of ambient conditions as they are conducted throughout the year. Standard materials and/or apparatus used for Pb TSP sa mpler calibration and veri fication are shown in
Table B.9.

For the Pb TSP samplers, ADEQ is conducting calib rations more frequently than required by EPA because ambient temperature and barometric pressure vary significantly from season to season throughout the state. This frequency may be reduced once the Pb TSP samplers have a well-established operating history. Acceptance criteri a for calibrations, verifications, and audits of the TSP samplers are found according to Ta ble B.10 and the ADEQ Pb Validation Template
found in Section D. The associated SOPs are in cluded as attachments. Parameters of the ADEQ Pb TSP samplers that are subjec t to routine calibrations, verificat ions, and audits in the field
include:

 Flow rate

 Ambient temperature

 Barometric pressure

 Date/Time

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40Table B.9 Standard Materials and/or Apparatu s for Pb TSP Calibration and Verification

Parameter

M=Material A=Apparatus Std.
Material Std. Apparatus Mfr. Name Model# Acceptance
Criteria Variable
Control Settings

Flow Rate

A

A

M+A

A

M

M NA

NA

NA

NA

NA

Fibrous
Glass Orifice (top hat)

Roots

Meter

Water

manometer

Syringe

Tubing

8X10” size TISCH

Dresser

Dwyer

Any

Any

Any #TE-5025 (or equivalent)

#5M125

30”

NA

NA

NA Annually

NISTtraceable
certification

Every 7years NISTtraceable
calibration

Use with
low
resistance
fluid

1/8” ID or 10 gauge

No visible damage MFC Set
Point

NA

NA

NA

NA

NA

Temperature

A NA Digital
standard BGI, BIOS,
or other comparable
manufacturer Tetracal or equivalent digital
standard Annual

NISTtraceable
certification NA

Pressure

A NA Digital
standard BGI, BIOS,
or other comparable
manufacturer Tetracal or equivalent digital
standard Annual

NISTtraceable
certification NA

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41Table B.10 Acceptance Criteria for HIGH VOL+ TSP Lead (Pb) Samplers Operating in
Actual Condition

Criteria Frequency Acceptance Range Actions Monitoring Instrument

Average Flow Rate (FR) Every 24 hours of operation Set Point: 1.13 m 3 /min (40 CFM) If sampler fails to
maintain FR troubleshoot/repair/cali
brate Standards (Reference)
Flow Rate TISCH Orifice (Top Hat)

Digital Temperature Probe Digital Pressure Probe Certified annually to a NISTtraceable primary standard

Certified annually to a NISTtraceable primary standard Resolution 0.02 m 3 / min
± 2% reproducibility

2 oC resolution ± 5 mm Hg resolution Ensure annual
certification is completed and repair or

replace references as
needed

Verification/Calibration

One-point (QC) Flow Rate
Verification

Date and Time Temperature Verification
Pressure Verification
Leak Check

5 point PCal (in H 2 O)

Multi-point Flow Rate
Verification/Calibration Prior to every other sample
collection event (may be reduced after

operating history is established)

Same as above

“

“

“

Performed prior to
flow rate calibration if needed

Quarterly - (Annually, at minimum); upon installation; after repair; following flow rate failure; when action level is triggered In Actual Conditions:
Action Level: + 5%
difference from std
Failure Level: ±7%
difference from std

± 2 min

± 2oC ± 10 mmHg
Audible check with

faceplate blocked

5 points over operating range of ~1.02 – 1.25

m 3 /min (36 – 44 CFM)
within + 10% limits of linearity (36 – 44 CFM) If failure occurs, adjust, repair, or replace unit.

Respond to Auditor using Corrective Action
form

Adjust or replace

“

“

“

“

“

See AMU-Pb-001 SOP for calibration range in

standard conditions

Performance Evaluations

ADEQ PE Audits Each Sampler

EPA Pb PEP Quarterly; Near beginning of program; upon instrument change-out; following corrective action;
and prior to sampler removal

Annually - 1 field audit Quarterly - 1 collocated filter sample ± 10% of audit standard and design value (40 CFM)

95% CL Absolute bias ±

15% If sampler fails audit,
Submit Corrective
Action form and audit field sheet to QA/QC Lead, DM&QA and

AMU Managers

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42Table B.11 shows acceptance crite ria for laboratory analysis.

Table B.11 Laboratory Acceptance Criteria

Criteria Frequency Acceptance Range Actions

Verification/Calibration

Calibration - standards at 1, 5, 25, 50, 75, and 100ppb Every Run R 2 = 0.998 or greater
The lowest standard must
recover ±15% of the expected value and the remaining must recover ±10% of the expected values to be acceptable Must meet criteria to continue, if fails make adjustments to system and reanalyze
calibration curve until it
meets criteria

Initial Calibration Verification (ICV) – must be from second

source Immediately following
calibration ±10% to continue Must pass to continue,
if fails make adjustments to system,
recalibrate and

reanalyze. Initial Calibration Blank (ICB) Immediately following
calibration and ICV <Reporting Limit to
continue Make adjustments to system, reanalyze.

LLCV Low Level Calibration Verification (LLCV) –
Concentration shall not be more
than 3X the lowest calibration
standard and at a level not used
in calibration curve. Following ICV and ICB and at
the end of each run ±30% of the expected
values to continue The problem must be
corrected and the
instrument re-calibrated and the analysis repeated

. The analysis may be restarted at the last passing set of the

LLCV/CCV/CCB Continuing Calibration Verification – (CCV) Following ICV, and every 10 extracted samples, and at the
end of the run 10% of the expected values
to continue The problem must be identified, corrected

and the analysis restarted at the point
where the last set of

LLCV/CCV/CCB passed. Continuing Calibration Blank – (CCB) Following ICV, and every 10 extracted samples <Reporting Limit to
Continue The problem must identified, corrected

and the analysis restarted at the point
where the last set of

LLCV/CCV/CCB passed Quality Control

Laboratory Reagent Blank - (LRB) Once per batch <Reporting Limit If the result of the LRB is greater than the reporting level, then the
source of contamination
must be identified and
corrected.. Laboratory Fortified Blank – (LFB), Once per batch ±20% If the result of the LFB
is outside the acceptance criteria, the

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43Criteria Frequency Acceptance Range Actions problem must be identified, corrected

and the LFB reprepped/re-analyzed.

Internal Standard - All samples and QC Samples Must meet recovery
between 70% and 120%. If matrix effects are suspected the sample
must be diluted and reanalyzed. Dilution is

continued until the
internal standard falls within the range. Ratio
must fall within 0.833- 1.42 to pass Spike – Concentration should
be near calibration curve midpoint. Once per Batch ±20% of expected value Document any nonconformance, qualify samples appropriately Duplicate Once per Batch ≤ 20% RPD Document any nonconformance, qualify samples appropriately.

Serial Dilution – Concentration
of 10X the lowest standard.
Five fold dilution. Once per Batch ±10% of undiluted result If the serial dilution fails, physical or
chemical interferences should be suspected. Qualify sample results appropriately

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44B.8 INSPECTION/ACCEPTANCE REQUIREMENTS FOR SUPPLIES AND
CONSUMABLES

The purpose of this element is to establish a nd document a system for inspecting and accepting all supplies and consumables that may directly or indirectly affect the quality of the Pb Program. The ADEQ Pb monitoring network relies on various s upplies and consumables th at are critical to its operation. This section details the supplies/consumable, their acceptance criteria, and the required documentation for tracking this process.

Sampling Media Supplies

On an annual basis, EPA will provide 8X10” fibrous glass filters to be used for the collection of routine samples, collocated and PEP samples, and field blanks. AFL will collect the shipment upon arrival at the ADEQ Building Shipping & R eceiving Office. Typically, EPA provides an ample supply of filters; however, AFL will inspect the shipment to ensure the number of filters shipped is adequate for the year. If filters are co nsumed at a faster rate than anticipated for any reason, AFL will contact the currently designate d EPA representative and request additional
filters. In the event the annual al lotment of filters is exhausted at an unusually high rate, the QA Team will help determine the root cause of excessive filter use and identify any corrective
actions needed to return the Pb networ k to the normal EPA monitoring schedule.

To prevent damaging the brittle, fibrous glass fi lters before or after sampling, a second filter holder cassette and faceplate were purchased for each sampler to allow filter setup and removal
from the cassette to occur in an indoor environm ent free of wind gusts and dust. In addition, the duplicate filter holders and faceplates allow the operator to easily set-up a makeup sample run if needed without having to handle exposed and une xposed filters in the field which reduces the opportunity for contamination or physical damage to the filter. The QA Auditor also has a separate filter holder cassette and faceplate which are dedicated to QA and used to protect filter integrity while a PE audit is being conducted.

Unexposed and exposed filters are visually insp ected several times during the sample collection process to verify that the filter is without dama ge or defects including pin holes, tears, uneven
thickness. Filters are examined wh en loaded into the filter hol der cassette, upon installation and removal from the sampler, and during sub-samp ling prior to shipment to the analytical laboratory.

Table B.12 shows the critical fi eld supplies for the Pb network.

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45Table B.12 Critical Fiel d Supplies and Consumables

Area Item Description Vendor
Windex

Citrus Cleaner Used for cleaning - surfactant-based cleaning
solutions Paper Towels

Canned Air Medium-size, soft paint
brush Used for cleaning - debris removal and/or drying apparatus/material

Combo Philips/Flat-head
screw driver Channel lock pliers

Crescent wrench

5/16” nut driver Used during routine service checks and repairs

Powder-free anti-static gloves Worn to protect sample integrity during filter change-out and operator from exposure to settle dust components 6 feet of: 1/8” tubing with t-fitting Grainger, Costco, Home Depot, etc.

Water manometer with colored, low resistance
fluid TISCH, Grainger, Costco, Home Depot, etc Digital Temperature and
Pressure sensor/calibrator BGI, BIOS, etc.

Orifice and resistance plates TISCHTISCH HIGHVOL+ Sampler

Back-up fibrous glass
filter for
calibration/verification
check Used during
calibration/verification

process

EPA

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46B.9 NON-DIRECT MEASUREMENTS (Data from other Sources)

This element addresses data to be used in the Pb program that is not obtained by direct measurement from the ADEQ Pb network. It in cludes both outside and historical monitoring
data.

Chemical and Physical Properties Data

Chemical and physical properties data and c onversion constants are often required in the processing of raw data into reporting units. This type of information that has not already been specified in the monitoring regulations will be obtained from nationally and internationally recognized sources. The following sources may be used without prior approval:

• National Institute of Sta ndards and Technology (NIST)

• U.S. EPA
• The current edition of “standard handbooks”

Geographic Location

Another type of data that will commonly be used is geographic information. For identifying the location of sampling sites, conventional longitu de and latitude coordinates, or universal transverse mercators (UTMs) are reported in EPA’s AQS database.

Historical Monitoring Information

Historical monitoring data and summary information derived from previous data may be used in conjunction with current monitoring results to calculate and report trends in pollutant concentrations. In calculating histor ical trends, it is important to verify that hist orical data are fully comparable to current monitoring data. If different methodologies were used to gather the historical data, the biases and other inaccuracies must be described in trends reports based on
those data.

External Monitoring Databases

It is the policy of ADEQ that no data obtained from any other or ganization or agency shall be used in creating published reports or regulatory actions unless the data were collected under a QA program that meets the requirements of 40 CFR Part 58, and has been approved by the ADEQ QA Manager.

Data from the USEPA AQS database may be used in published reports with appropriate caution. Care must be taken in reviewing/ using any data that contain flags or data qualifiers. If data are flagged, such data shall not be utilized unless it is clear that th e data still meet critical QA/QC requirements. It is impossible to assure that a database such as AQS is completely free from errors including outliers and bias es, so caution and skepticism is called for in comparing data from other reporting agencies as reported in AQS. Users should review available QA/QC
information to assure that the external data ar e comparable with the measurements and that the original data generator had an acceptable QA program in place.

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47Meteorological Data from Other Sources

Meteorological data from sources such as the National Weather Service, National Climate Data Center, and other regional clim ate centers are used to provi de information required when developing monitoring sites, computing corrections needed to convert form standard conditions to actual conditions, and to support analysis and monitoring efforts. These data are not reported to AQS and are identified if they are used in monitoring or reporting.

Data Used to Establish this Network

To ascertain the geographical areas where the highest concentration of airborne Pb is expected to occur, several non-ADEQ data sources were utilize d. These data were obtained from ambient air quality and meteorological monitors operate d by local facilities. The ADEQ QA Auditor performs annual PEs on these facil ity-operated monitors to verify the quality of these data. Also, ADEQ often utilizes meteorological data colle cted by the National Weather Service (NWS) to aid in the understanding of the relationship between ambient air quality concentrations and meteorological phenomena. AAS staff have revi ewed the QA/QC measures associated with NWS data and have found them to be acceptable. In addition, EPA-approved dispersion modeling was used to assist in the siting of Pb monitors, partic ularly for the Miami area. The AERMOD dispersion model, utilizing facility an d NWS data, was utilized to determine the area
of maximum Pb concentrations in the Miami ar ea. ADEQ strives to approve all environmental data and computer software that are to be used to aid in the monitoring effort, though sometimes data of lesser quality are the only informati on available. For these cases, the limitations and precautions are considered througho ut the decision making process.

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48INTERIM FINAL - ADEQ Pb Ambient Air Monitoring Network QAPP
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49 B.10 DATA MANAGEMENT

Data m anagement (DM) describes how the data are handled through th e collection, analysis, validation, and reporting processes; and, it identifies responsibilities and requirements during each process. DM begins with sampling activitie s and includes any or all of the following operations and their documentatio n: data recording, transfor mation, transmittal, reduction, validation, analysis, storage, and retrieval. DM also includes an overview of any mathematical operations and analyses performed on raw (“as-collected”) data. The handling of data is covered in ADEQ and PCWRL SOPs found as attachments to this QAPP.

Data Flow and Management

Data collected from ADEQ-operated instruments in the Pb network will consist of measurements from filter-based samplers operating on an every sixth day (1/6) schedule and from meteorological instruments generating hourly measurements. The DM&QA Unit will apply accepted QA/QC procedures to th e Pb and meteorological data.

Source-oriented data measurements For Pb data, interval and sample summary da ta from the TSP samplers operated by ADEQ AMU is scheduled to be downloaded following each sample run day during filter changes and transferred to the appropriate folder in the shared network drive. A Level 1 QA check is performed on the filter samples prior to them being prepped and shi pped to the analytical laboratory. This check involves review of the in terval data by the AMU lead operator or AFL supervisor to verify that the sampler operated within acceptance criteri a and each filter sample was not exposed to air flow before or after th e scheduled sample collec tion day. In addition, the summary data for each sample run day is chec ked to verify the information provided on the corresponding ADEQ Lead TSP Air Sampling Record sheet is correct. Following analysis, PCWRL performs verification and va lidation on Pb concentration data prior to sending results in μg/m 3 and μg/strip to DM&QA. This constitute s the Level 2 validation. PCWRL assigns the appropriate validation flag to data as neede d. The data are submitted in electronic AAAD format on a monthly basis. These data are then lo aded to ADEQ’s AAAD by the DM&QA Lead Pb Data Reviewer, who then performs Level 3 valid ation on the data. Upon completion of the Level 3 validation, the data are then tr ansferred to the EPA AQS database.

For meteorological data, ADEQ has estab lished electronic communication with the meteorological instruments using a DCS data logger system. DM&QA staff will perform all levels of data validation on wind direction, wind speed, ambient temperature, and relative humidity data. Figure B.4 shows the data collect ion system hardware architecture for retrieving
continuous data.

Non-source-oriented filter-based samplers Reserved for non-source-oriented monitoring information

Other measurements If secondary Pb or meteorological data are use d, DM&QA will be responsib le for determining if it meets EPA and/or internal standards for quality.Figure B.4 Continuous Data Collection System Hardware ArchitectureINTERIM FINAL -ADEQ Pb Ambient Air Monitoring Network QAPPOctober 201150Data Management Responsibilities by Entity

DM activities and responsibilities at ADEQ for th e Pb network will be shared by the AMU, AFL, and the DM&QA Units.

Air Monitoring Unit Responsibilities

The AMU is responsible for:

 set-up, operation, maintenance, and take -down of the ADEQ air monitoring and meteorological instruments and the thr ee monitoring sites (MIGC, HAGH, JLG)

 documenting all instrument verifications, calibra tions, maintenance, change-outs, instrument and site log books, site information forms; and, providing such repor ts to DM&QA for QA

purposes

 transporting unexposed filters and exposed filte r samples to and from sites; loading and unloading of filters into samplers; and, providing sample collection information in the field portion of the ADEQ Lead TSP Air Sampling Record sheet for each sample

 downloading of data from filter-based samplers and transferring such files to proper ADEQ
network drives

 ordering and managing air monitoring instruments, supplies and consumables

 responding to Corrective Action Notices (CAN) generated by the QA Auditor for failed PE
audits

 site maintenance unless the site is not owned by ADEQ – then ADEQ will work with site owner regarding any changes or upgrades needed

 reporting and documenting any changes to a monitoring site to management

The AMU will follow good data practices by:

 filling out all hand-recorded documents completely, accurately, and legibly

 verifying all hand-recorded documents

 maintaining the site and instrument logbooks

 using consistent naming conventions for each site

 storing electronic and hard copy docum ents in AMU and/or with DM&QA

 communicating status of air monitoring to management

Good data management practices also incl ude personnel accountability for completion of specific tasks. Therefore, all field sheets, ADEQ Lead TSP Air Sampling Records, shipping documents, etc., will be reviewed by the appr opriate AAS staff member for correctness and completeness, including any re quired signatures or initials.

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51Air Filter Laboratory Responsibilities

The AFL is responsible for:

 pre-sampling - for all three monitoring sites set ting-up filters in the filter cassette holders for each sampler and initializing ADEQ Lead TSP Air Sampling Record for each sample and field
blank collected

 post-sampling – removing exposed filter samples and field blanks from the filter cassette
holders

 sub-sampling filter samples and shipping sample strips along with all needed paperwork to

PCWRL

 shipping PEP Pb filter samples to the USEPA Region 9 analytical laboratory

 keeping relevant correspondence including em ails, shipping records, copies of ADEQ
Lead TSP Air Sampling Records (COC/data form), and other documents as needed

The AFL staff will follow good data practices by:

 reviewing all ADEQ Lead TSP Air Sampling Record information for completeness and

correctness

 developing and using consistent identification numbers for filter samples and blanks

 storing hard copy documents (COC, shippi ng schedules and records, etc.) in the appropriate files

 communicating with management

Good DM practices rely upon personnel accountabili ty for completion of specific tasks. To ensure good DM practices are continuously employed, documentation, such as ADEQ Lead TSP Air Sampling Records, shipping documents, etc., and required signatures/in itials, is routinely reviewed by AAS staff for correctness and completeness.

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52Data Management & Quality Assurance Unit Responsibilities

The DM&QA Unit is responsible for conducting PE audits and TSAs, reviewing all field sheets, and managing and reviewing all data. Specific responsibilities for the Pb network are:

 collecting site and in strument metadata a nd entering it into AAAD

 reviewing PCWRL data results for the filter samples and blanks from the three monitoring
sites

 loading of lead concentration and meteor ological data into DCS, AAAD and AQS

 overseeing the automated Level 1 QA pr ocedures performed within the AAAD

 performing Level 2 and 3 QA of th e meteorological data in AAAD

 verifying deliverables needed from PCWRL for Pb concentration data

 performing Level 3 QA on Pb concentration data results,

 loading Pb data into AAAD

 reporting to the program manager when review , loading, and reporting of each batch of data is completed

 maintaining files containing all hard copy fiel d sheets, instrument checks, audit reports, site and instrument change forms, etc.

 PE audits of TSP samplers and meteorological equipment

 generating and tracking of any CAN for monitoring instruments and data

 preparing metadata and quality assured da ta summaries for delivery to the program

managers

 overseeing and evaluating PE and PEP result s to ensure high degree of data quality

The validated data deliverables from the PCWRL will be provided in the appropriate units and format for loading into the AAAD. DM&QA pr ovided the format and specific variables required.

As stated above, good data management practic es also include personnel accountability for completion of specific tasks. DM&QA will follow good data practices and document the data management processes by:

 verifying any electronic data entry of files during loading into AAAD and other software applications for analysis

 developing and using consistent na ming conventions for each data set

 storing hard copy documents from the AMU staff

 providing reports to management

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53Contract Laboratory Data Ma nagement Responsibilities

The contract laboratory, PCWR L, is responsible for:

 processing the collected samples and blanks

 validating the sample and blank results

 transforming the results into AAAD format

 delivering the results in a timely manner to ADEQ

 storing the data and associated documents

Details regarding PCWRL’s internal data mana gement procedures are described in their respective QM and SOPs which are found in the Attachments. PCWRL has a Laboratory Information Management Systems (LIMS) to stor e sample metadata, analysis, flags, and any
additional information available for validation of the sample results. The laboratory must retain any data review docum ents provided by ADEQ.

ADEQ expects the PCWRL to follow EPA a nd ADHS guidelines such as good laboratory practices. They are also expect ed to follow good data management practices regarding sample identification and tracking, data entr y, verification, stor age and security.

The laboratory is responsible for inte grating field data from the ADEQ Lead TSP Air Sampling Record with the analyzed data from the filter samples. The la boratory is also responsible for maintaining sample analysis and COC inform ation. The ADEQ AMU with support from AFL will follow their usual procedures for providing preliminary Level 1 sample validation of filter samples prior to the filter samples being sub-sampled and sent to PCWRL. PCWRL will conduct Level 2 QA reviews of analytical results prior to sending the data to DM&QA Unit for review and entry into the AAAD.

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54Data Management Responsibilities by Activity

Pre-sampling and Start-up Activities

For source-oriented sampling, AMU will set-up TI SCH HIGH-VOL+ TSP samplers at the three monitoring sites, perform initial and subsequent calibrations, and ve rify flow rates prior to every other run until otherwise approved by the AAS Manager. AMU will set-up the meteorological instruments needed at the sites and perform in itial and subsequent calibrations and precision checks. DM&QA will conduct PE audits on all of the instruments near the beginning of monitoring and quarterly therea fter. DM&QA personnel will comp lete site and instrument metadata forms. DM&QA staff will enter the re quired information in DCS, AAAD, and AQS; and, establish file folders for hard copy field sheets.

AFL will obtain and prepare the unexposed fibrous glass filters to be used in the samplers. AFL will establish an ADEQ Lead TSP Air Sampling Record for all Pb filter samples and blanks.

AFL will set-up and adjust as needed a shippi ng schedule for sending the Pb filter samples and field blanks for ICPMS analysis with PCWRL. All required supporti ng data will also be sent to the laboratory.

Sample Collection Activities

The AMU operator or their designee will collect the prepped, unexposed filters/filter cassette holders and their associated ADEQ Lead TSP Air Sampling Record forms from AFL and load the TSP samplers per the EPA Monitoring Schedule for 1/6 day collection. The AMU operator or their designee will collect filters/ filter cassette holders after the sampling has completed and fillin the ADEQ Lead TSP Air Sampling Record forms. The AM U operator or their designee will download summary and interval data from the Pb samplers. The AMU operator or their designee will return filters and ADEQ Lead TSP Air Sampling Record forms to AFL. The downloaded
electronic data files will be re viewed and loaded to the desi gnated location(s) on J drive.

AFL Laboratory Supervisor or their designee will process the Pb filter samples and blanks from the TSP samplers following procedures found in the Attachments. AFL staff will ship filter strips to PCWRL for analysis on a monthly basis or other timeframe as needed.

The AMU operator or their designee will downloa d summary and interval data files from the samplers onto laptops, thumb drives, palm pilot or other suitable elect ronic device and copy to the ADEQ network drive. Data downloads are schedule to occur afte r each sample run day.

The AMU operator or their designee will perform a Level 1 review of the sample summary and
interval data files. The Lead Pb Data Reviewer or their designee will perform Level 3 validation
on the Pb data once it is received from PCWRL.

AMU will perform routine maintenance, verifications, and calibrations. DM&QA QA Auditor will perform routine PE audits on air monitori ng instruments in the Pb network on a regular
basis.

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55AFL will ship Pb f ilters to PCWRL for ICPMS an alysis on monthly basis, or other frequency if
needed.

The Lead Continuous Data Reviewer or their de signee will load files into DCS and then AAAD and will do a Level 2 QA check on data and report the results to DM&QA manager. The Senior Continuous Data Reviewer will do Level 3 QA on meteorological data and report to the DM&QA Manager.

Post Sample Collection Activities

DM&QA Auditor will perform final PE audits on samplers and meteorological instruments prior to their shutdown. AMU will remove equipment from monitoring sites. DM&QA will verify presence of field documents for completion of Level 3 QA review. The DM&QA Lead Pb Data Reviewer or their design ee will load the final data into AAAD and into AQS.

Data Management Practices

This section describes the data handling practices that will be followed by ADEQ. The data handling practices followed by the PCWRL and the Region 9 laboratory are described in their respective quality manuals and SOPs.

Manual Data

In general, whenever data are recorded by hand, manually copied or entered into an electronic medium, the staff member performing the operation and, if possible, the staff member receiving the data, must verify that the operation was pe rformed correctly. Manual data checks include:

 verifying that the information was recorded or copied correctly (e.g. from instrument screens to field sheets)

 verifying that handwriting is legible and ha ndwritten numbers are clearly identifiable

 verifying that documents have been da ted and signed or initialed as required

 verifying that the documents have b een filed in the a ppropriate location

Field records are reviewed for completeness a nd accuracy and initialed by the Lead Service Report Reviewer, the Lead for QA/QC, and the Lead Pb Data Reviewer.

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56Electronic Data

All electronic files must be visually inspected by opening the files and viewing the records. This includes files downloaded from samplers and dataloggers, files from the AFL, and files received from the contract laboratory. The purpose of this inspection is to:

 verify that the file can be opened and is readable

 verify that all deliverables have been received per the contract

 verify that the dataloggers ha ve been correctly programmed

 identify the format of the data prior to load ing into a database or software application

It is best to inspect these files as soon as po ssible after receiving the files, especially if data
review will not occur immediat ely. Any questions or problems that arise during this inspection can be resolved in a timely manner.

In general, when electronic data are copied or saved to another file format or loaded from one software application to another, the person perf orming the operation must verify that the data have transferred correctly. Checks on electronic data ope rations include:

 verifying that the data are in the correct fields

 verifying that the old and new files have the same number of records

 verifying that formats are correct (e.g., l eading zeroes are included and the data are rounded or truncated to the correct number of decimal places)

 verifying that the files are in the correct locations

Sample and Data Tracking and Documentation

The following information and documents are used by ADEQ to track and control the movement and handling of samples and data, to ensure pr oper procedures are fo llowed, and to support the data review and validation processes.

Site and Metadata Information

The representativeness of a site or monitor can be the most important factor when making
decisions about the data collected from that site or monitor. The metadata associated with the site
or monitor serves as the documentation of this representativeness. A ll necessary site and instrument information (e.g., site location, sa mpler siting information, date(s) of sampler installation and/or removal, etc.) is recorded in a Site Information and Metadata File which is maintained by the DM&QA Unit. Site and instrument change forms are used to document changes. In addition, logbooks are ke pt at each site and with each Pb sampler for use by the field
technicians to record all activit ies at each site visit and note any problems. Site and metadata information for the three (3) sites generating data for this network is shown in Tables B.1, B.2, and B.3 and on Figures B.1, B.2, and B.3.

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57Chain-of-Custody & Field Data Forms

A chain-of-custody ( COC) will be used with each Pb filter sample and field blank generated by ADEQ. Both the COC and field data informati on for each sampling event are recorded on the ADEQ Lead TSP Air Sampling Record. The COC portion tracks who is in possession of and responsible for the filter. The COC originates with the first party responsible for the filters. For the Pb network, the COC for the Pb filters will be initiated by AFL staff.

The field data portion provides critical sample collection information which is needed for calculating the Pb concentration for each sample. The ADEQ Lead TSP Air Sampling Record has specific spaces for each item below. The handwri tten notations on the forms provide critical information including, but not limited to the following:

 site, date, and time that sampling actually occurred

 total volume sampled

 minimum, maximum, and average temperature, flow rate, and barometric pressure (BP) during the sampling period

 identification numbers for samples and field blanks, and

 operators’ names and free-form not es regarding a ny irregularities

An example of this form and additional inform ation regarding its use is provided in the AFL & AMU SOPs found in the Attachments. Completed ADEQ Lead TSP Air Sampling Records will be made available to the PCWRL and DM&QA st aff validating Pb data. A copy of each ADEQ
Lead TSP Air Sampling Record is retained by ADEQ and ch ecked to ensure that all information is complete, accurate, and legible prior to samples being shipped for analysis.

Shipping and Handling Records

ADEQ AFL will maintain shipment records.

Data Corrections

Following good data management practices helps to ensure that mistakes will either be avoided or found and corrected early in the process. Occasionally, however, errors will be made and overlooked, or problems discovered at a later date. In such cases, it may be necessary to change data after it has been uploaded to the AAAD. The DM&QA Unit is responsible for making the changes in the AAAD.

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58Data Storage and Retrieval

Data management includes storing and archiving all data, data files and any related documents needed to ensure data quality. Table B.15 summ arizes the specific ADEQ records and documents and the Unit responsible for storing them. The co ntract laboratory’s data storage and retrieval techniques are described in their respective QM and SOPs.

The analyzed data will be kept in AAAD. In addition, the analyzed data will be kept in the original electronic form produ ced by the contract laborator y and stored on ADEQ AQD’s network drive. A brief description of the AAAD database is provided below.

AAAD

The AAAD is the central data repository for da ta collected and used by the AAS. The AAAD is
an Oracle relational database built by ADEQ’s Information Systems Development Unit (ISDU) and put into production in July 2002. It contai ns both continuous data from the DCS and noncontinuous data from filters, canisters, and cartridges (FCC). The AAAD also contains instrument information and has graphics capabilit y to assist users in quality assurance data review. AAAD is linked to the ADEQ AZURITE data base which contains place information for the monitoring sites.

Access to the AAAD is controlled by a valid User ID and password. There are also six user roles which control user privileges in cluding table access, screen acce ss, and the ability to insert, update and delete data and metada ta. User roles are assigned by the database administer (the DM&QA Unit Manager). In addition, the AAA D is linked to ADEQ’s central AZURITE
database which contains ‘Place’ and ‘Customer’ in formation. The user role to access the ‘Place’ information required for the AAAD is assigne d by ADEQ’s Information Technology Section (ITS) after the user has completed an in-house training course. User roles and privileges are tracked by the DM&QA.

The AAAD database is housed on the ADEQ Oracle server kept in the ITS server room. The ITS has daily, weekly, and monthly back up procedur es as well as back-up power support to the
server room. The Oracle server is inside the ADEQ firewall and protected with antivirus and other security software. The ITS has Oracle database administrators with 24-hour/7-day access to identify any server issues. The back-up and securi ty procedures of the ITS are described in the ADEQ QMP.

The AAAD was designed to store up to ten years of data online with older data rolled off to archive storage space. Archived data will be kept in simple text-delimited files that can be accessed via special request to the ITS. These pr ocedures have not been finalized and may be part of the current ISDU developmen t of an AZURITE data warehouse.

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59Table B.13 Summary of Data Records Stored at ADEQ

Type of Record Medium Data Storage Location or Responsibility

Completed COC and field data forms Hardcopy and electronic AMU and DM&QA

Site and instrument logbooks Hardcopy DM&QA

Shipping and receiving records Hardcopy AMU/AFL

Certificates for all instruments and standards (e.g., NIST or manufacturer's certificate) Hardcopy AMU and DM&QA

Instrument calibration and verification records Hardcopy AMU and DM&QA

Instrument maintenance and service records Hardcopy AMU and DM&QA

Downloaded files from monitors with QC data Electronic AMU (computer - network drive)

QA records, including PE audit and technical system audit reports Hardcopy and electronic DM&QA

Lab validated data sets sent from the laboratory to ADEQ including metadata Electronic DM&QA (computer – network drive)

Data Review forms Hardcopy and electronic DM&QA

Quality Assured Data Electronic (AAAD) DM&QA

AQS Reports Hardcopy and electronic DM&QA

Purchasing records Hardcopy AMU and AAS

Correspondence between ADEQ and the PCWRL Electronic AMU and DM&QA

Correspondence and business records with subcontractors involved with the program Hardcopy and
electronic AMU and AAS

Training records Hardcopy AAS

Correspondence and reports with subcontractors performing data analysis (if applicable) Hardcopy and electronic DM&QA and AAS

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60SECTION C. ASSESSMENT AND OVERSIGHT

C.1 ASSESSMENTS and RESPONSE ACTIONS

This elem ent describes the internal and ex ternal checks necessary to ensure that:

 all elements of the QAPP are correctly implemented as prescribed,

 the quality of the data generated by implementation of the QAPP is adequate, and

 corrective actions, when needed, are impl emented in a timely manner and their
effectiveness is confirmed.

An assessment, for this QAPP, is defined as an evaluation process used to measure the performance or effectiveness of the quality system or the establishment of a monitoring network, its sites, and various measurement phases of the EDO.

The results of QA assessments indicate whether th e control efforts are adequate or need to be improved. Documentation of QA/QC efforts impl emented during the data collection, analysis, and reporting phases is important to data users, who can then consid er the impact of these control efforts on the data quality (See Section C.2). Both qualitative and quantitative assessments of the
effectiveness of these control efforts will identif y those areas most likely to impact the data quality and to what extent.

To ensure the adequate performance of the quality system, ADEQ, in conjunction with EPA Region 9, will perform assessments on various air monitoring networks periodically.

Assessment of the Subsidiary Organizations

Management Systems Review (MSR)

A MSR is a qualitative assessment of a data co llection operation or orga nization to establish whether the prevailing quality management struct ure, policies, practices , and procedures are adequate for ensuring the type and quality of da ta needed are obtained. MSRs are conducted or lead by the ADEQ QA/QC Unit Manager and are targ eted for every three years. The reviewer(s) will ensure that sufficient management controls are in-place and carried out by the organization to adequately plan, implement, and assess the results of the program. The QA activities for all criteria pollutants including Pb should be pa rt of the MSR. The ADEQ QA/QC Unit will report the findings to the AAS Manager within sixty (6 0) days of completion of the MSR. The report will be appropriately issued to ADEQ Director s. Follow-up and progress on corrective action(s) will be tracked, documented, and filed appropriately.

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61Assessments of Program Activities

Surveillance

Surveillance is the continual or frequent monitoring of the status of a program and the analysis of records to ensure that specified requirements ar e being fulfilled. On a routine basis, ADEQ AMU and DM&QA personnel will review log books and instrument service re ports (calibrations, verifications, PE audits, instrument change forms, etc.) generated from the operation and maintenance of the Pb samplers to verify that the acceptance criteria are being met. In addition, electronic data files from the Pb samplers will be reviewed to ensure that samplers operated correctly during sample collection events. QA in formation from the PCWRL is also reviewed
when batches of data are submitted for Level 3 validation.

Annual Monitoring Network Plan an d Five-Year Network Assessm ent

Effective December 18, 2006, 40 CFR 58.10 requires states to complete an annual monitoring network plan and submit it to the EPA Regional Administrator for approval by July 1st of the following year. The monitoring network plan identif ies the purpose of each monitor and provides evidence that the siting and operation of each mo nitor meets EPA requirements. It is used to determine how well a particular air monitoring network is achiev ing its required air monitoring objective(s) and what modificati ons are needed for it to conti nue or to better meet its objective(s).

The annual monitoring network plan must be ma de available for public inspection (website, hardcopy posting in libraries and public offices, and/or newspaper li sting) for at least 30 days prior to submission to EPA. Although not re quired, EPA recommends soliciting comments during the public inspection period. If an oppor tunity for public comment is provided, any
comments received must be included in the network plan, and any changes made to the plan after the public comment period must be identified.

Every 5 years, in addition to the annual plan, an assessment of the air qu ality network must be submitted to EPA Region 9. This five-year network assessment must determine 1) if the network meets the monitoring objectives defined in 40 CFR 58 Appendix D, 2) whether new sites are needed, 3) whether existing site s are not longer needed and can be terminated, and 4) whether new technologies are appropriate for incorporati on into the ambient air monitoring network. This
assessment must also include a review of existin g and proposed sites to determine if areas with relatively high populations of susceptible i ndividuals (e.g., children with asthma) are characterized. In addition to the requirements above, the five-year network assessment may also include 1) re-evaluation of th e objectives and budget for air monitoring, 2) evaluation of a network’s effectiveness and efficiency relative to its objectives and costs, and 3) development of recommendations for network reconfigurations and improvements. The first assessment under these new regulations was due July 1, 2010.

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62Types of Ne twork:

Air quality surveillance systems consist of networ ks of monitors at carefully-chosen physical
locations referred to as sites or stations. The networks, stations, and monitors that must be included in the annual monitoring network plan include:

1) State and Local Air Monitoring Stations (S LAMS), including FRM, FEM, and approved regional method (ARM) monitors 2) National Core multi-pollutant monitoring stations (NCore) 3) Chemical Speciation Network (CSN) stati ons (formerly known as Speciation Trends Network (STN) stations) 4) Photochemical Assessment Monitoring Stations (PAMS) 5) Special Purpose Mon itor (SPM) stations

Additional networks, sites, and stations that may be described and evaluated in the ADEQ annual monitoring network plan include:

6) National Air Toxics Trends Sites (NATTS) 7) Urban Haze monitoring sites 8) Interagency Monitoring of PROtected Visual Environments (IMPROVE) 9) ADEQ visibility stations located in or near mandatory Class I areas (national parks, wilderness areas). Class I monitoring sites are subject to specific siting and operational guidance developed by the IMPROVE Steering Committee. 10) AIRNow information sites 11) Source-oriented monitoring sites operated independen tly by permittees (Industry) 12) Meteorological sites

Technical Systems Audits (TSAs)

A TSA is a thorough and systema tic on-site qualitative audit, where facilities, equipment, personnel, training, procedures, a nd record keeping are examined for conformance to the QAPP. External (EPA) TSAs are scheduled to be conduct ed at least once every three years by the EPA Region 9 QA Office as required by 40 CFR Part 58. A TSA of the Pb network will be targeted for every three years. Regulations and this QAPP will be used to determine that the Pb network and its related quality systems are operating adequately.

Typically, the AQD QA Team, which is compri sed of the QA/QC Lead and QA Auditor, conducts TSAs as a team, but either may indi vidually conduct the audit. In addition, the QA Team may request that other pe rsonnel or technical experts pa rticipate on the Audit Team. The Audit Team will perform three TS A activities that can be accomplished separately or combined:

 Field – handling, sampling, shipping

 Laboratory (ADEQ AFL) – filter receiving, pre-sampling filter setup, post-sampling shipping, archiving and associated QA/QC

 Data Management - information collecti on, flagging, data editing, security, upload.

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63Key personnel to be interviewed during the audit are those individuals with responsibilities for: planning, field operations, QA/QC, data m anageme nt, and reporting. To increase uniformity of a TSA, an audit checklist or questionnaire will be used.

Findings and recommendations identified during a TSA will be reported. Any major (serious) deficiencies that may compromise the quality of the data will also be identified. The ADEQ Internal Audit Finding form will be used to pres ent such findings to the audited group at the TSA debriefing (See Figure C.1). An internal audit finding form will be generated for each major deficiency and it will clearly identify pertin ent information such as: pollutant(s) impacted, estimated time period of deficiency, site(s) aff ected, and reason of acti on. During the debriefing discussion, evidence may be presented that reduces the significance of the finding; in which case, the finding may be removed. If th e audited group is in agreemen t with the finding, the discussion is documented and the form is signed by the orga nization’s director or their designee during the exit interview. If a disagreement occurs, the Aud it Team will record the opinions of the audited group and set a time at some later da te to address the finding at issue.

The Audit Team and the audited group may work together to solve required corrective actions. An ADEQ Internal Audit Response form (Figure C.2) will be initiated by the audited group’s unit or section manager in response to each ma jor ADEQ Internal Audit Finding form generated
that can not be resolved at the debriefing. Minor fi ndings and recommendations will be tracked using a less formal system and solutions iden tified will be tracked until implemented and monitored to ensure a positive result is reali zed. Solutions to audit findings will be further explored as needed at follow-up meetings he ld by the QA Team with the audited group.

Post-Audit Activities:

The major post-audit activity is the preparation of the TSA report. The Audit Team will prepare a post audit report that includes a written execu tive summary of findings covering the following areas: planning, field operations, laboratory operations, QA/QC, data management, and reporting. Findings and recommendations will be di scussed in adequate detail in the written report. An attempt will be made to rank the findings in order of their potential impact on data quality. To prepare the report, the Audit T eam will meet and compare observations with
collected documents and results of interviews and discussions with key personnel. Expected QAPP implementation is compared with observed accomplishments and deficiencies and the audit findings are reviewed in detail. S ee Section C.2 for more on the TSA report.

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64Figure C.1. ADEQ Internal Audit Finding Form

ADEQ Internal Audit Finding

Audited Unit/Team:

______________________________________________________

Audited Activity : Audit Date : Finding # :

_______________

Finding:

___________________________________________________________________________________

Discussion:

Audit Team Lead Signature: __________________________ Date: ______________

Audited Unit Supervisor Signature:____________________ Date: ______________

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65Figure C.2 ADEQ Audit Response Form

ADEQ Internal Audit Finding Response Form

Audited Unit/Team :______________________________________________________________

Audited Activity:

____ Audit Date:

________ Finding #:

__________

Finding:

Cause of the problem:

Actions taken or planned for correction:

Responsibilities and timetable for the above actions:

Prepared by: Title________________ Date:

_____________

Audited Unit Supervisor: Title _______________ Date:

_____________

Audit Team Lead: Date:

_____________

Remarks:

Is this audit finding closed? When?

File with official audit records. Send copy to Auditee

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66Audits of Data Quality

An audit of data quality (ADQ) reveals how the data are handled, what judgments were made,
and whether uncorrected mistakes were made. A DQs can often identify the means to correct systematic data reduction errors. ADQs are detailed evaluations of a small percentage of the data reported to EPA and include an evaluati on of both the raw data and the supporting
documentation. Sufficient time and effort will be devot ed to this activity so that the auditor or team has a clear understanding and complete documentation of data flow. Pertinent ADQ questions will appear on the TSA ch ecklist or questionnaire to ensure that the data collected at each stage maintain their integr ity. The ADQ will serve as an eff ective framework for organizing the extensive amount of information gathered during the audit of the laboratory, field monitoring, and support functions within the agency. The ADQ will have the same reporting/corrective action requi rements as the TSA. The QA/QC Lead and QA Auditor may conduct the ADQs in conjunction with a TSA of a pollutant program/network or as a separate review. The EPA Region 9 QA Office may also conduct ADQs. The ADQ should not be confused with the data qu ality assessment (DQA).

Data Quality Assessments

A DQA is a statistical analysis of environmental data to determine whether the quality of data is adequate to support the decision upon which th e DQOs are based. The DQA process is discussed in detail in Section D.3 of this QAPP.

Independent Performance Audit

An Independent Performance Audit (IPA) is a fi eld operations audit that ascertains whether the samplers are operating within the specified limits as stated in the SOPs and QAPP. The IPA is performed by an EPA contractor and may be performed in conjunction with a TSA. The IPA consists of challenging the samplers to operate using independent NIST-traceable standards. Once the IPA has been performed, the flow rate of the independent sampler(s) is calculated and compared against the flow rates of ADEQ’s sa mplers as specified in the EPA’s QAPP or
associated SOPs. If the flow rates do not fall with in the acceptable range, then the QA Auditor is notified, who in turn notifies AMU so that a re medial action can be taken. Once the AMU field technician has remedied the situation, a post IPA may be conducted to confirm the adjustment or maintenance. The IPA audit results are then written in a detailed report.

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67Performance Evaluation

A performance evaluation (PE) is a type of audi t in which the data generated by the measurement system are obtained independently and compared w ith the routinely obtained data to evaluate the proficiency of a technician, an alyst, or laboratory. ADEQ PE a udits are conducted once a quarter by the auditor within the DM&QA Unit. Audits of the instrument’s flow rate, ambient temperature, and ambient pressure are th e main components audited during the PE.

For the Pb network, EPA is managing a national Pb PEP. The Pb PEP program is using a twopart approach: a Pb PEP sample and collocated samples as follows:

1. A PEP sample where an independent field audi tor sets up a second a udit sampler, collects a 24-hour sample, and sends the sample to an independent laboratory for analysis.

2. A collocated sample where each quarter the monitoring organization field operator will take one additional collocated sample and sends this sample to the independent laboratory.

For Pb, the EPA Region 9 Analytical Laborat ory will be performing the analysis of PEP samples. PEP reports will be compiled by EPA.

Table C.1. External Assessment Summary

Agency Responsible Type of Assessment Agency Assessed Frequency
EPA QA Support Contractors Field TSAs, IPAs ADEQ Annually

EPA Contract Laboratory PEs ADEQ contract laboratory Annually

MSRs or TSAs ADEQ Once every three

years
Network Plan ADEQ Annually EPA Region 9

Network Assessment ADEQ Once every five years beginning 2010

Table C.2. Internal Assessment Summary

Personnel Responsible Type of Assessment Frequency

ADEQ QA/QC Unit MSRs Once every three years

DM&QA QA Team TSAs, ADQs Once every three years

DM&QA, AMU Surveillance Ongoing

DM&QA, AMU Annual Monitoring Network Plan Annually

DM&QA, AMU, and Evaluation Unit Monitoring Network 5-year Assessment Once every five years beginning 2010

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68C.2 REPORTS to MANAGEMENT

Effective communication among all personnel is also an integral part of a quality system. Reports to management provide the opportunity to alert management of data quality problems, to propose viable solutions to problems, and to pr ocure necessary additional resources. Routine reporting also provides a mean s for tracking the following:

 adherence to scheduled delivery of data and reports;

 documentation of deviations from approved QA and test plans, and the impact of these deviations on data quality; and

 analysis of the potential uncertainti es in decisions based on the data.

The following sections describe the quality-related reports and communications to management necessary to support the Pb network operations and the asso ciated data acquisition, validation, assessment, and reporting.

Quarterly and Annual Data and QA Summary Reports

Data summary reports will be dist ributed quarterly to management to brief them on the status of the operations of the instrumentation as well as th e status of data summary metrics in comparison to the NAAQS. These quarterly reports are base d on quality assured Level 3 data. During the first year of Pb monitoring, mont hly reports will also be provid ed to management to provide more timely updates on the overall operation of th e instrumentation and the status of data summary metrics in relation to the NAAQS. Th ese monthly reports are based on preliminary
Level 2 data.

Periodic assessments of the Pb data quality are required to be reported to EPA (40 CFR 58 Appendix A). This requirement is fulfilled by the reporting of precision and bias data to the AQS. These precision and bias data are also taken into consideration when certifying the ambient
Pb data as documented in the annual data certif ication package to EPA. The precision and bias
data are obtained from:

 AMU flow verifications (precision checks)

 QA Auditor flow rate audits (bias checks)

 Routine collocated sample results (precision estimates),

 Pb PEP audits and quarterly collocated PEP sample (bias estimates).

Data from the AMU precision checks and DM& QA audits are uploaded to the AQS once a quarter for the previous quarter. A ll precision and bias data for the calendar year must be entered
before the annual certification deadline of the following year.

Quarterly reports to management primarily include the DM&QA Newsy Letter. The Newsy Letter summarizes filter-based par ticulate data throughout the state of Arizona for those monitors operated by ADEQ. The Pb data a nd QA summaries are included as a section within the Newsy Letter. Information such as data completene ss, NAAQS comparisons, collocation details, and a summary of quality assura nce issues are contained within the Newsy Letter.

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69Annual repo rts to management primarily incl ude ADEQ’s Air Quality Annual Report and the
annual data certification letter to EPA. The Air Quality Annual Report includes a summary of all ambient air quality data colle cted throughout the state of Ar izona, with a primary focus on comparisons with the NAAQS. Due to a lack of Pb monitoring in the past, Pb data summaries were not included in previous reports; however, Pb data summaries will be included in future annual reports. The ADEQ Air Quality Annual Repor t serves as a centralized document that reports on air quality data collected by the state and local ag encies in Arizona.

The annual data certifica tion letter is a requirement that is due to EPA by May 1 of the following year for which the data have been collected. This letter focuses on the qua lity assurance and data review aspects that are associated with ambi ent air quality monitoring. DM&QA staff utilize the AQS AMP255 Data Quality Indicator Report to summarize and assess precision and bias information for each monitor ADEQ operates. If a ny significant issues arise throughout the year or during the annual review of the QA data, this is documented in the certification letter.

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70Annual Audit Report

At the end of each calendar year, an annual audit report is developed by the ADEQ AQD QA
Team and distributed as above. This document de scribes the quality objectives for measurement data and how those objectives have been met. The QA Annual Report includes quality information for all data collected by each ne twork, including Pb beginning in 2011. The Annual Audit Report includes, but is not limited to, the following QA information:

 monitoring program overviews and update s on any changes to the audit program,

 a summary of the flow rate and performan ce audits performed in that year for each network, and

 a summary of any internal or EPA TSAs conducted during the year and any corrective actions taken in response

For reporting measurement uncer tainties, the QA Annual Report contains the annual AQS QA summary report and summary statistics of the following for each monitoring network or

program:

 Precision

 Bias

 Completeness

 Timeliness

Technical System Audit Reports

External TSAs are scheduled to be conducted at least every three years by the EPA Region 9 Office as required by 40 CFR Part 58. The report w ith the audit findings will be provided to the ADEQ AQD Director and forwarded to the AAS Manager. Internal TSA reports provided by the DM&QA QA Team will be provided to the AAS unit managers, the AQD Director, and made available to EPA personnel when they audit ADEQ or provided upon request. The reports will be filed appropriately.

The internal TSA report will include:

 audit title and any other identifying info rmation such as an audit ID number;

 audit team leaders, audit team par ticipants and audited participants;

 background information about the project, purp ose of the audit, dates of the audit; particular measurement phase or parameters th at were audited, and a brief description of the audit process;

 summary and conclusions of the audit and corrective action requires; and

 attachments or appendices that include all audit evaluations and audit finding forms.

The goal is to have the TSA draft audit report pr epared within thirty days (30) following the debriefing. The report will be made available to the audited group for comment. The audited group will have at least two (2) weeks to review the report and make comments. If the audited

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71group has written comments or questions concer n ing the audit report, the Audit Team will review and incorporate them as appropriate, and subsequently prepare and resubmit a final report. The final report should be ready for distribution about sixt y (60) days following the TSA debriefing. The report will include an agreed-u pon schedule for corrective action implementation or follow-up meetings will be held to develop a schedule.

Non-Conformance Events and Corrective Action Reports

Opportunities for improvement and unusual situat ions are often identifi ed by ADEQ staff during the course of everyday activities. If a program deficiency is discovered that may impact the quality of data generated, a pr ocess is in-place to ensure th at the appropriate personnel are notified and that a corrective action(s) is take n. AQD will use a notificatio n and response process through the use of the Non-C onformance Event Notification & Response Form (NCEF) (See Figure C.3). This form may be used by a ny AAS staff who find a non-conforming event (or condition) that may be affecting the quality of the ambient air monitoring data. An NCE may include operational or procedural problems, safety defects, or unusual data statistics. A separate form will be used for each NCE identified. NCEs may require immediate and/or long-term corrective actions they may require notif ication and response by multiple AAS Units.

The NCEF is designed as a closed-loop system. Fi rst, it identifies the originator, the person who is reporting and identifying the NCE. The orig inator describes the ev ent or condition and may recommend an action to be taken in response. The form is then directed to the person or persons who need to be notified of the NCE and/or who would be best qualified to take any necessary action. Finally, the form closes the loop by requiri ng that the recipient(s) take any necessary action in a timely manner and doc ument the action taken and its effectiveness. The form is signed by all responsible parties, routed fo r review and signature by managers, DM&QA personnel, and appropriately filed.

The NCEF serves to:

a) document any NCE that has or may have affected data and the means by which the event or condition was corrected, b) document that someone was notified of the NCE and when, c) ensure that problems are co rrected in a timely manner, d) provide a fast and effective way to communicat e to all parties who ma y need to know about the NCE, including managers, e) ensure that managers are aware of major events as they occur, the possible impacts of those events, and the corrective actions taken, if any, and f) prevent small problems from becoming big ones, or worse yet, from becoming
institutionalized.

The NCEF process applies to all AAS ambien t air monitoring programs and instruments, including those operated by other parties, and any ambient air m onitoring equipment indirectly associated with the AAS, such as permitted facili ties. However, the NCEF will be directed to internal AAS staff only; NCEFs involving SRO and non-ADEQ site operators (including permittees) will be directed to the appropriate AA S staff person who will then be responsible for

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72working with the site operator to take any nece ssary actions. If the AAS staff person is unable to

com plete the necessary actions in an effectiv e manner, the situation will be elevated to management. If the person initiating the NCEF process is the same person responsible for working with the site operator, the NCEF will be directed to the initiator’s immediate supervisor for oversight purposes.

An NCE will be elevated to the AAS Manage r and the ADEQ QA/QC Unit Manager if any of the following occurs:

 more than one quarter of criteria pollutant data have been impacted,

 evidence of fraud has been discovered, or

 disagreement between the AAS QA Team and the air filter laborator y and/or monitoring program staff (field or data management) ca nnot be resolved at the Unit Management
level.

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73Figure C.3 ADEQ AQD Non-Conforming Event Form

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74SECTION D. DATA VALIDATION AND USABILITY

D.1 DATA REVIEW, VALIDATION, and VERIFICATION REQUIREMENTS

Data review is the set of veri fication and validation procedures used to exam ine the products of data collection and data processing to determine th eir quality and usability. It spans a wide scope of tests from low level checks on sample identity to high level checks on spatial and temporal comparability. The main goal of the review is to determine if the data products (measurements) are representative of their environment. This is accomplished through ve rification and validation of the preliminary data results with sample collection procedures, sampler operation, and laboratory processing. In general, whenever an operation affects the data product, verification
and validation checks should be defined and im plemented to ensure the operation was done correctly.

Data review also provides feedback on the fiel d and laboratory analysis activities; it identifies those data points that may indicate the need for corrective action to a field or laboratory procedure. Outliers not explained by instrument or processing errors are considered valid from an operations standpoint and requi re further investigation with meteorological, climatological,
and other environmental information to determine wh at event they represent. Ideally, data review is to be performed as soon as possible after da ta collection and on a re gular schedule during the project to enable timely investigation of questio nable data, to meet data reporting requirements,
and to take corrective action.

Data verification and valida tion are defined as follows:

 Data Verification techniques confirm by examination a nd through objective evidence that specified requirements have been fulfilled. Data verification ensures and documents that the data are what they purport to be; i.e., it verifies what was actually done and documents that the data fulfill applicable requirements. Data not meeting the requirements are to be
identified and documented with the cause of the insufficiency.

 Data Validation techniques confirm by examination and through objective evidence that the particular requirements for a specific intended use are fulfilled. Data validation focuses on the particular data needs for a project. Th e goal of data validation is to identify and evaluate the impact of any technical non-compliance or quality control (QC) nonconformances on the complete data set.

Data verification and data vali dation are typically sequentia l steps performed by different persons. Data validation begins with the outputs from data ve rification and, ideally, it is performed by a data reviewer inde pendent of the data collector, data processor, and data user. In general, data verification techni ques occur during the sample colle ction and processing phases of the project. Data validation techniques are then applied on the resulti ng data product, which requires review of information generated thr oughout the entire sample collection, sample analysis, and data handling pro cess. Additional verifi cation and validation ch ecks can be created as necessary to check the results of any operation affecting the data product.

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75Data review is not the sam e as data quality a ssessment or evaluation of the DQOs. Only after the data set has been reviewed, verifi ed, and validated can it be fully assessed and/or used to address the specific scientific and regulatory questions embodied in the DQOs. The following sections describe ADEQ’s data review processes and requ irements. The specific data review procedures used by the contract laborato ries are not included here.

The Data Validation Process

Data validation will be performed by both the contract laboratory and by ADEQ. AMU personnel will review summary and interval data for each sample collected and verify that the
field data information matc hes the sampler’s record.

The contract laboratory usually performs Leve ls 1 and 2 QA review and validation. ADEQ is responsible for Level 3 validation but will also perform additional Level 2 checks as a means of verifying the results obtained from the laborator ies. Level 2 checks include verification of the processed data with the ADEQ Lead TSP Air Sampling Records and review of all flagged data including invalid and qualifier flags. Level 3 data validation will be performed to identify and validate outliers, monitor trends over time, a nd incorporate field QC checks into the data validation decision making process.

The contract laboratory provides the required deliverables in batches approximately 30 to 60 days after sampling based on the contract agr eement to DM&QA at ADEQ. These deliverables
include electronic files of:

 raw and validated sample data in the labor atory’s format with detection limits or
uncertainties

 a definition list for all acronyms a nd abbreviations used by the laboratory

 an index or key to identify sites, sample ids and sample dates

 a list of flag definitions

 any narratives by laboratory staff

 validated data in AAAD format

The DM&QA Unit will continue with Level 2 QA ch ecks of the validated data by reviewing the data flags applied by the laboratory in the labora tory’s files. ADEQ will use its in-house records to examine data that have been flagged for attr ibution, sampler problems, and outliers. Questions about flags applied by the laboratory will be directed to the laboratory manager.

The DM&QA lead data management specialist will perform Level 3 QA on the data set. The specific procedures used for data validation are described in the Pb data validation SOP found in
the Attachments.

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76Data Review, Validation and the Air Assessment Ambient Database (AAAD)

Much of the data review and validation pro cess is done within the AAAD. As discussed in Section B, AAAD offers some t ools to assist data reviewers and validators throughout the data review and validation process. The degree to which each datum has been reviewed is documented in AAAD through the QA Levels. The QA Levels range from Raw to Final. The raw data are considered to be the original data derived from the instrumentation or laboratory analysis. Occasionally, transformations of th e data are performed by DM&QA within AAAD. These data transformations typically occur during the AAAD automated upload and validation processes and only occur so that data reported from various instrument s, laboratories, and agencies are of a common data format. While th ese data transformation may occasionally occur, the raw data files are always archived.

Levels of Data Review

The data review procedure at ADEQ requires a ll data measurements to move through multiple levels of quality assurance. When each level of da ta review is completed, the data are assigned a
Data Validation Level which is entered in the AAAD, ADEQ’s central data repository, along with the status (valid, invalid, or suspect) of the data at that level and a reason code. The primary objective of each level of quality assurance is to examine the data results, to verify the measurements are what they purport to be, a nd to validate their quality in relation to the requirements of conformance to procedures, eq uipment operation, and environmental effects. Those measurements not meeting the requirements ar e assigned invalid or suspect status with a reason code describing the nonconformance. A desc ription of ADEQ’s QA Le vels is listed in
Table D.1.

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77Table D.1 ADEQ Quality Assurance Levels for Filter-based and Continuous Measurements

QA Level QA Objective QA Results

Raw Original unchanged sample data recorded at sampler or produced by laboratory analysis; to be archived. None

1 Data are reviewed (either manually or programmatically)
to determine if:

 sample value produced came from proper and
assumed instrument

 instrument producing sample value came from proper and assumed site

 instrumentation problems occurred, as documented by instrument flags or error log Flag data as valid, invalid, or suspect.
Add comments. Corrective actions taken if necessary.

2 Review Level 1 data to:

 identify outliers or anomalous data (typically temporal-based) and make a preliminary
validation decision.

 identify media preparation problems, laboratory transformation problems, etc. Flag Level 1 data as valid, invalid, or
suspect. Add qualifiers to valid and suspect data if necessary. If necessary, add comments to data values further explaining issues at
hand. Initiate Corrective Action if necessary.

3 Review Level 2 data over longer periods of time ( ≥ one month for continuous data and ≥ three months for filterbased data). Additionally, Level 3 data review is intended

to:

 compare data both spatially and temporally

 incorporate and verify the field generated QC results into the data review process

 make a final determination on the validity of outliers identified during the Level 1-3 QA

process

 identify environmental even ts (natural or humancaused) with appropriate flagging protocol Flag Level 2 data as valid or invalid. Add qualifiers to valid data if

necessary. If necessary, add comments that help explain validation rationale. Initiate corrective action if necessary.

Final Field generated QC data asso ciated with environmental data are reviewed annually for precision, bias, and completeness. This occurs as part of the data certification procedures. Certified data are promoted to Level Final. Promote Level 3 data to Level Final after performing annual certification procedures.

In general, data are corrected, flagged, or i nvalidated based on the best assessment of the
individual situation. Data corrections and fl agging are noted in re gular QC reports to management. Systematic problems that lead to unacceptably large biases are investigated and documented by DM&QA. Corrective actions are initiated as needed.

Data completing all three levels of review and co nsidered to be valid ca n be promoted to Level Final or can remain at Level 3. Promoting data to Level Final occurs on an annual basis and is associated with an overall review of QA/QC re sults and activities that occurred throughout the

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79 given year. This annual review and promotion of data to Leve l Final occurs during the data certification process.

AAAD flagging protocol requires a reason code for each sample va lue at each quality assurance
level. The reason code format consists of a letter followed by a number or another letter depending on the code type. The data validation code types are shown in Table D.2. The unique combination of letters and numbers creates specif ic reason codes that further explain the status code. If additional explanation is needed, the comme nt field can be utilized. Each data record is comprised of a data value field, a QA status field, a reason code fiel d, and a comment field.

Table D.2 Data Validation Code Types

Data Field Letter Number or

Letter QA Status Meaning

Null B Number Invalid Sample not processed or
determined invalid

Data Value V Number Valid QA complete

Data Value S Number Suspect Requires further QA

Data Value Q Number or

Letter Valid Letter or number following ‘Q’ is the AQS qualifier codeD.2 VERIFICATION and VALIDATION METHODS

All data collected by the AAS must be reviewed and quality assu red to the appropriate QA Level for the data type. These levels of quality assura nce have the objective of reviewing the data at different scales to identify those measuremen ts influenced by sampler problems, collection errors, or laboratory analysis e rrors. The remaining data are cons idered representative of their ambient environment; measurements above or be low expected values are investigated to
determine the nature of the envir onmental conditions they represent.

Data verification and validation requirements ha ve been previously described in Section D.1. The multiple levels of quality assurance have be en described in Section D.1. This section will
describe the data review methods employed to verify and validate da ta at these levels and ensure that QA requirements have been met. These QA levels segregate the verification and validation
checks to focus the data review in a particular way. QA Level 1 reviews the data from an individual sample at a single site. QA Leve l 2 focuses on internal and between sample consistency on a site by site basi s; data may be reviewed over a week (continuous data) or in sample batches (FCC data) to examine the be havior of the data through time. QA Level 3
reviews the data ove r longer periods of time, investigating data behavi or seasonally or annually or in comparison with historic data. QA Level 3 also reviews the data spatially, looking at regional patterns and performs a final validation ba sed on all information that was collected and documented during the sample collection and analysis process.

Data Verification and Validation Processes

The complete data review process spans a wide sc ope of tests from low level verification checks on sample identity to high level validation checks on temporal and spatial comparability. For FCC samples, the process is a cooperative e ffort between laboratories, which conduct the chemical analyses and complete the first stag es of data validation, and ADEQ, which conducts
further validation and verificati on. For continuous measurements collected by the DCS, ADEQ is solely responsible for the data validation. FCC and DCS data ar e stored in the AAAD, the data repository for the AAS. As discussed in Sect ion D.1, AAAD, and the tools within AAAD, is used to perform certain data review checks a nd to move the data through the QA Levels. The data review methods used by ADEQ are described in the following sections.

DCS Data Review Methods

The meteorological measurements collected at the Pb monitoring sites will be collected using the DCS. Each meteorological instrume nt is connected to a data logge r that continuously records and calculates hourly averaged measurements. At least once per day, the DCS will poll each site, download data from the dataloggers, and stor e both raw data files and AAAD formatted data files on the ADEQ network drives for loadi ng to the DCS and AAAD. The AAAD load and validation process performs Level 1 automated checks to verify the presence of all hours, all site
and instrument metadata are accu rate and exist in the database, conversion of units if necessary, and initial flagging of outliers. Level 2 data validation will be done by the DCS specialist as soon as possible after the load process to iden tify any problems with the data caused by the instruments (instrument failures, clock errors, power outages, etc.). The QA Level 3 reviewer

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80will r eview the data to verify data validity fl ags applied by the Level 2 reviewer are accurate, validate the data based on field QC checks, and to identify and document any issues that were not addressed during the previous QA levels. All data are assigned reason codes (flags) at each QA level. The comment field within AAAD is often utilized as a means of communication
between the various data reviewer s and QA levels. This field is al so used to further clarify the use of flags during the QA process.

DCS QA Level 1 Review

Loading data into the AAAD from the DCS is a two-step operation c onsisting of automated
checks:

1. Data Upload from DCS to AAAD using Oracl e SQL Loader: The upload process verifies correct formatting of each data record coming fr om DCS; i.e., correct number of fields and valid data type in each field. If the record is incorrect, a file containing the invalid record is written back to the DCS. The Lead Continuous Data Reviewer or their designee checks the
file and makes corrections and uploads the file or deletes th e record. Valid records enter the AAAD staging table.

2. Data Validation: The data in the staging tabl es are validated and moved to the database where they are accessed with the DCS Quality Assurance screen or the DCS Secondary Quality Assurance screen (Figure D.1). The original DCS value is displayed in the Raw Data section of the screen; the validated data are displayed in the lower portion of the screen at QA Level 1 with a QA status and QA reason code assigned.

The following automated validation checks are performed:

 check for missing observations and fill in th e time period with a null value assigned for the raw value and the QA value at Leve l 1. A preliminary determination of the QA status and reason code is assigned

 check for hour beginning or hour ending; ad just all data from hour ending instruments to hour beginning

 convert English unit measur ements to metric units

 check screening limits for the parameter a nd assign Level 1 QA status of Suspect if
outside the limits

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81Figure D.1 AAAD DCS Secondary Quality Assurance Screen

DCS QA Level 2 Review

QA Level 2 review will be done by the Lead Con tinuous Data Reviewer or their designee as soon as possible after loading the data into th e AAAD. The Level 2 QA is performed to verify data collection by DCS and AAAD and to identify any values that were instrument checks or other outages, and to identify a ny problems in data collection. In addition to the data collection verification, Level 2 review includes a manual review of data on a scale of three to nine days. Typically, criteria polluta nt data undergo Level 2 quality assu rance procedures on a daily basis, while meteorological data undergo Level 2 data re view on a weekly basis. The Level 2 review includes the following steps:

1. Check the AAAD DCS Upload Validation scre en to verify upload and validation processes. Records appearing in this screen are in the AAAD staging tables and have not met the automated verification requirements. Th e deficiency will be identified, the records corrected or deleted, and th e validation process run.

2. Using the DCS Secondary QA screen, examine the parameters for the most recent week’s worth of measurements. Graph the Level 1 data and examine. Th e AAAD graphing tool will identify any data that were determined suspect during the automated level 1 validation

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82process. Evaluate all d ata that are represen ted in the graphical pl ot. Return to the QA screen and visually scroll through the data. Check flagged and suspect data. If invalid,
enter the Level 2 status of invalid and assign the appropria te ‘B’ code using any field reports, verbal communication, or email commun ication. Check flagged data and if valid, copy the data to Level 2 and assign the V1 fl ag. Promote the remaining data to Level 2 using the appropriate reason code.

3. The Lead Continuous Data Reviewer or thei r designee will send an email report to the project manager and to DM&QA after each batch of data are loaded and reviewed.

DCS QA Level 3 Review

QA Level 3 review is completed by the lead conti nuous data reviewer or their designee. Level 3
data review includes an evaluati on of the data on longer temporal scales, usually on the order of months. The Level 3 data review process also se rves as a near-final validation of data and incorporates the official field activity reports (and the instrument QC data) into the validation decision-making process. It is al so during the Level 3 data review process that data are flagged with the appropriate qualifier fla g, if needed. Most often, this incl udes flagging of data that have been influenced by natural or exceptional events. An Oracle Discoverer procedure is used to query AAAD and extract Level 2 data by pa rameter. The data review steps are:

1. Review all field sheets associated with th e parameters of concern. Verify that all instruments passed their QC checks. The QC ch ecks that are considered during the Level 3 data review process can be found in the critic al criteria section of the validation template (see Table D.3). If a QC failure occurs, data should be invalidate d back to the last successful QC check unless the QC data or ambient data indicate an exact point of
instrumentation failure.

2. Using the DCS Secondary QA screen, examine the parameters for a period of one to three months worth of measurements. Graph the Le vel 2 data and examine. The AAAD graphing tool will identify any data that were dete rmined suspect during the level 2 validation process. Evaluate all data that are represen ted in the graphical pl ot. Check flagged and suspect data.

3. Identify any additional anomalous data that were not identified dur ing the previous QA
level reviews. Communicate and coordinate with other data revi ewers, air quality forecasters, and instrument technicians to dete rmine validity of data. Other data sources may be utilized, such as the data from the NW S, to assist with the validation process.

4. Perform spatial comparisons of the da ta parameters, when applicable.

5. When completed, promote values in AAAD to QA Level 3 with appropriate status and
reason codes.

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83FCC Data Review Methods

Pb data consist of discrete 24-hour samples a nd will be loaded into the FCC section of the
AAAD. These data are loaded into the AAAD through the DCS computer, but do not become part of the DCS database. Collectively, PCWRL performs extensive Level 1 and Level 2 checks
on the data collection and ICPMS an alysis results from the fibrous glass filter samples. The data are delivered to the DM&QA Unit for review an d loading into the AAAD for Level 2 and Level 3 validation checks by the lead Pb da ta reviewer or their designee.

FCC QA Level 1 & 2 Review of Filter Lab and Contract Lab Files

Filter-based data undergo the majori ty of their Level 1 and 2 data review within a laboratory setting or out in the field. Unlike continuous data collection which goes through an automated validation process, the Level 1 and 2 data review and validation process for filter-based data is predominantly subjected to a manual review to verify the following:

 For each sample, chain of custody sheets ar e completely filled out and accurately document the transfer of filters throughout the data collection and analysis process

 Filters have been analyzed for any deform ities or anomalous particulate deposits and documented if any exist

 Review the COC and electronic data to verify that the samplers operated for the desired amount of time and any instrume ntation errors are documented

 Confirm that the laboratory has provided all information a user would need to interpret the analysis results

 Review and verify results of laboratory equipment calibrations

In addition to the manual Level 1 and 2 validatio n procedures above, some automated validation procedures may also be incorporated. These include:

 Continuous laboratory environment monito ring, verifying correct temperature and humidity during filter analysis

 Similar to the DCS validation process, FCC data undergo an automated validation process
that verifies the instrument and site meta data are accurate and exist within the AAAD

The laboratory is primarily responsible for Level 2 validation and data revi ew. This consists of verifying that all samples passed their QC crite ria, or flagging those data that exceeded laboratory specific acceptance criter ia. For a list of these laboratory specific acceptance criteria, see Table B.13. Upon receipt of the filter-based data from the laboratory, the Level 3 FCC specialist (Lead Pb Data Reviewer) performs a fina l Level 2 review of the data checking for data formatting issues or ambiguities in the flags issued by the laboratory.

FCC QA Level 3 Review

INTERIM FINAL - ADEQ Pb Ambient Air Monitoring Network QAPP The FCC Le vel 3 QA and data review procedures are similar to that of the DCS Level 3 procedures. FCC Level 3 data review includes an evaluation of the da ta on longer temporal scales, usually on the order of months. The Level 3 data review process also serves as a nearOct ober 2011

84final validation of data and incorporates the offici al field activity reports (and the instrum ent QC data) into the validation decisi on-making process. It is also during the Level 3 data review process that data are flagged w ith the appropriate qualifier flag, if needed. An Oracle Discoverer procedure is used to query AAAD and extract Level 2 data by parameter. The data review steps

are:

1. Review all field sheets associated with th e parameters of concern. Verify that all instruments passed their QC checks. The QC ch ecks that are considered during the Level 3 data review process can be found in the critic al criteria section of the validation template (see Table D.3). If a QC failure occurs, data should be invalidate d back to the last successful QC check unless the QC data or ambient data indicate an exact point of
instrumentation failure.

2. Using the FCC Quality Assurance screen, examine the parameters for a period of one to
three months worth of measurements. Gra ph the Level 2 data and examine. The AAAD graphing tool will identify any data that were determined suspect during the level 2 validation process. Evaluate all data that are represented in the graphical plot. Check flagged and suspect data.

3. Identify any additional anomalous data that were not identified dur ing the previous QA
level reviews. Communicate and coordinate with other data revi ewers, air quality forecasters, instrument technicians, and laborat ory staff to determine validity of data. Other data sources may be utilized, such as the data from the National Weather Service, to assist with the validation process.

4. Perform spatial comparisons of the data parameters, when applicable.

5. When completed, promote values in AAAD to QA Level 3 with appropriate status and
reason codes.

For additional details on the data review and valid ation process, refer to the Lead Data Review
SOP FCC-003 which is incl uded as an attachment.

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85D.3 RECONCILIATION and USER REQUIREMENTS

The program manager will be responsible for assessing the Pb data collected by ADEQ to determine compliance with the NAAQS. PCWRL will provide the validated filter data results from the ICPMS analysis for further validation by ADEQ. ADEQ will a ssess the data along with the meteorological data to gain a better understand ing of Pb concentrations. Site and instrument metadata and a report on the quality of the data will be included.

On and annual basis and in conjunction with the data certification pro cess, the ambient data collected by ADEQ and their associated QA/QC data are subjected to a DQA. This DQA includes a final review of the ambient data (via a data summary review), a review of data completeness, and a review of the QA/QC data in comparison with the DQOs that have been defined. This data quality assessment serves two primary purposes:

1. Acts as a final validation of the ambient data which typically results in official
certification of the data

2. Serves as an overall assessment of data quality for a particular program or network by comparing the desired objectives with the actual results

For criteria pollutant data, EPA’ s Data Quality Indicator Report is the primary tool for relating the QA/QC results to each monitoring program’s DQOs . If it is determined that ADEQ’s internal DQOs, which exceed those established by EPA for th e national Pb network, are continuously not met, then AAS will re-evaluate any intern al DQOs for the Pb network. Based upon this evaluation, ADEQ AAS will identify improvements that can be made to the Pb network and/or determine if the internal DQOs are too string ent for the monitoring methodologies in-use. If ADEQ AAS determines that any internal DQOs ar e too stringent, then AAS staff will develop and implement more realistic internal DQOs. If the national DQOs established by the EPA are not met, ADEQ AAS staff will work with the EPA as needed to develop more realistic DQOs the
national Pb network.

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86Measurement Quality Objectives and Validation Template

ADEQ expects new guidance related to analytical FEM (ICP-MS, XRF, etc.) to be developed and included as additional guidance for Pb. In formation from the revised EPA Pb validation template will be included in this section once it is available.

ADEQ developed the following validation templa te for the Pb TSP samplers. The template establishes a procedure that is used to provide for a consistent validation of Pb TSP mass concentrations collect by the agency and to ensure consistency with monitoring organization
across the US. There are three ta bles of criteria wher e each table has a different degree of implication about the quality of the data. The cr iteria and information included on the tables are derived from the TSP sampling method found in 40 CFR Part 50 Appendix B and 40 CFR Part 58 Appendix A, as well as analy tical methods found in 40 CRF A ppendix G, and a few criteria that were provided by TISCH.

One of the tables has the criteria that must be met to ensure the quality of the data. An example criterion is that the average fl ow rate for the sampling period mu st be maintained to within + 5% of the set point which is curren tly 40 CFR in actual conditions. The second table has the criteria
that indicate that there might be a problem with the quality of th e data and further investigation is warranted before making a determination about th e validity of the sample or samples. The third
table has criteria that indicate a potentially systematic problem with the environmental data collection activity. Such systematic problems may im pact the ability to make decisions with the data. An example criterion is that at least 75% of the scheduled samples for each quarter should be successfully colle cted and validated.

To determine the appropriate table for each criterion, the ADEQ Pb Team members considered how significantly the criterion im pact the resulting concentrati on. This was based on experience from Pb Team members, experience from EPA Region 9 and OAQPS, criter ia contained in the 1977 Pb High Volume (TSP) Validation Template which was developed for sampling by TSP and analysis by atomic absorption, and f easibility of implem enting the criterion.

Criteria that were deemed critical to maintaini ng the integrity of a samp le or group of samples were placed on the first table. Observations th at do not meet each and every criterion on the
Critical Criteria Table should be invalidated unless there are compelling reason and justification for not doing so. Basically, the sample or group of samples for which one or more of these criteria are not met is invalid until proven otherwise. The cause of not operating in the acceptable range for each of the violated criteria must be investigated and minimized to reduce the likelihood that additional samples will be invalidated.

Criteria that are important for maintaining and evaluating the quality of the data collection system are included on the second table, the Operational Evaluations Table . Violation of a criterion or a number of criteria may be cause for invalidation. The decision should consider other quality control information that may or may not indicate the data are acceptable for the parameter being controlled. Therefore, the sample or group of samples for which one or more of these criteria are not met is suspect unless ot her quality control information demonstrates otherwise. The reason for not meeting the criteria MUST be investigated, mitigated or justified.

INTERIM FINAL - ADEQ Pb Ambient Air Monitoring Network QAPP

Oct ober 2011

87INTERIM FINAL - ADEQ Pb Ambient Air Monitoring Network QAPP
October 2011

88 Finally, those criteria which are important for the correct interp retation of the data but do not usually impact the validity of a sample or group of samples are included on the third table, the Systematic Issues Table . For example, the data quality objectiv es are included in this table. If the data quality objectives are not met, this does not invalidate any of the samples but it may impact the error rate associated with the attainment/non-attainment decision.

Following are the tables. For each cr iterion, the tables include (1) the operational range that is acceptable, (2) the frequency with which complia nce is to be evaluated, (3) the number of samples that are impacted if viol ation of a criterion occu rs (possible values in clude single filters, a batch of filters, or a group of filters from a specific instrument), (4) sections of 40 CFR that
describe the criterion. The table also indicates whether samples vi olating the criterion must be flagged before entering them into AQS.

This validation template has been develope d based on the current state of knowledge. The template should evolve as new information is discovered about the impact of the various
criterion on the error in the re sulting mass estimate. Interactio ns of the criteria, whether synergistic or antagonistic, should also be incorp orated when the impact of these interactions becomes quantified. Due to the potential misuse of invalid data, data that are invalidated will not be uploaded to AQS but will be retained on the ADEQ AAAD database. This data will be invaluable to the evolution of the validation template.

Pb TSP Note of Caution

The validation template for Pb shows that the TSP samplers are calibrated in standard temperature and pressure (STP) but verified and operated in actual conditions. In addition to the CFR, the validation template were developed by also reviewing the TISCH operating manual for the samplers and the validation template were au gmented with QC information specific to the
TSP method.The following Pb validation template is derived from information found in: 40 CFR Part 50 Appendices B and G, 40 CFR Part 58 Appendix A, 40CFR Part 136, Federal Register 73 FR 66964, Draft TechnicalNotes developed by EPA OAQPS, PCWRL Method EQL-0510-191 and ADEQSOPs.Table D.3 Pb High-Volume (TSP) Validation TemplateCriteriaFrequencyAcceptable RangeCitation/InformationCRITICAL CRITERIA- Pb in TSPSampling Periodall filters1440 minutes +60 minutesmidnight to midnightPart 50 App B 7.7.1Part 50 App B 8.10Part 50 App G sec 7.1Average Flow Rateevery 24 hours of operation*1.13 m3/min (40 CFM) in Actual ConditionsADEQ specificationVerification/CalibrationSystem Leak CheckEvery other sampling eventVisual and Auditory InspectionTISCHFR Multi-pointVerification/CalibrationQuarterly – (Annually atminimum);After receipt, uponinstallation, after repair ormotor maintenance, or failureof 1-point check, when actionlevel is triggered5 points spanning range of 1.13 actual m3/min +10%R value = >0.99Part 50 App B sec 9.3One-point Flow Rate VerificationEvery other sampling event(Quarterly in Part 58)ADEQ Action Level - + 5%from transfer standardFailure Level is +7% from transfer standardADEQ specificationPart 58 App A sec 3.2.3 & 3.3.2Filter Checks Verified for EachSampleVisual Defect Check (unexposed)all filters-Initial backlight inspection - no pinholes orimperfections-Visual inspection prior to shipping to analytical labPart 50 App B sec 8.2Sampling InstrumentVerified prior to start ofsamplingSee Pb QAPP in Element B.6* - Based on sampler air velocity being between 20 to 35 cm/secINTERIM FINAL -ADEQ Pb Ambient Air Monitoring Network QAPPOctober 201189CriteriaFrequencyAcceptable RangeCitation/InformationOPERATIONAL EVALUATIONS TABLE Pb in TSPPrecisionCollocated Samples15% of each method code inPQAOFrequency - every samplingevent (may be reduce to 1/12days)CV <20% of samples> 0.02 μg/m3Part 58 App A, sec 3.3.4.3AuditsSemi Annual Flow Rate AuditQuarterly – (Semi-annually atminimum); near beginning ofprogram; upon instrumentchange-out; followingcorrective action; and prior tosampler removal15% of audit standard and design valuePart 58, App A, sec 3.2.4, 3.3.4.1 & 3.3.3Lead Strip Analysis6 strips/quarter2/conc. ranges+10% differencePart 58, App A, sec 3.3.4.2BlanksField Filter Blank10%< 40 μg/filterrecommendationSampler Run Information(collected each run)Sample IDRecord and verify filter IDPart 50 App B sec 8.9Verify Run ConditionsBased on flow verification during or after samplingPart 50 App B sec 8.11Time, Flow, Temperature andPressureRecord and verify readings from the instrumentPart 50 App B sec 8.12Part 50 App B sec 8.15HandlingFilter handled only from the outer edges and folded in halflengthwisePart 50 App B sec 8.13Part 50 App B sec 8.14Verification/CalibrationFlow Rate Transfer Std. (Orifice)1/yrConnects without leaksApproximate range: 1.0 – 1.8 m3/min (~35 – 66 CFM)Resolution 0.02 m3/min+2% reproducibilityMaximum pressure drop at 1.7 std m3/min; 50 cm H20Part 50, App B sec 7.4Part 50, App B sec 7.8Part 50, App B sec 9.2Field Thermometer1/yrRange -40o C to 50o C2o C resolutionPart 50, App B sec 7.5INTERIM FINAL -ADEQ Pb Ambient Air Monitoring Network QAPPOctober 201190CriteriaFrequencyAcceptable RangeCitation/InformationField Barometer1/yrRange 500 to 800 mm Hg5 mm Hg resolutionPart 50, App B sec 7.6Filter (Specs for Manufacturer)(Report to EPA and assess impacton data quality if noted.)Part 50 App B sec 7.1Sizeall filters20.3+0.2 cm x 25.4 +0.2 cmPart 50 App B sec 7.1.1Materialall filtersGlass fiberPart 50 App B sec 7.1.2Part 50 App G sec 6.1.1Collection Efficiencyall filters99 % minimumPart 50 App B sec 7.1.4Pressure Drop Rangeall filters42 – 54 mm Hg at 1.5 std m3/minPart 50 App B sec 7.1.5pHall filters6-10Part 50, App B sec 7.1.6Integrity (may not need for Pb)all filters2.4 mg maximum weight lossPart 50, App B sec 7.1.7Pin holesall filtersnonePart 50, App B sec 7.1.8Tear Strengthall filters500 g minimum for 20 mm stripPart 50, App B sec 7.1.9Brittlenessall filtersNo cracks or material separations after single lengthwise creasePart 50, App B sec 7.1.10Lead Contentall filters< 20 μg/filterADEQ specification based on 10 times lessthan the NAAQS of 0.15 μg/ m3based on aflow rate of 1.1 m3/minSYSTEMATIC CRITERIA -Pb in TSPData CompletenessquarterlyRolling three -month mean (i.e., the 3-month data capture rate)>75%Part 50 App R. sec 3Filter Sample Recoveryall filtersWithin 6 days of samplingPart 50 App BReporting Unitsall filtersμg/m3at local temperature and pressure.Part 50 App R sec 3 (b)Rounding Conventionall filtersReport data to 3 decimal places (data after 3 are truncated).Part 50 App R sec 3 (b)Detection LimitICPMSEach analytical batchMDL of 0.00006 μg Pb/m3PQL of 0.000018 μg Pb/m3PCWRL SOPSampler MaintenanceSampler hood & sampling chamberBefore and after eachsampling eventInspect/CleanrecommendationMotor/housing gasketsAnnuallyReplacerecommendationBrushless blower motorEvery 8 yearsReplacerecommendationControl and pump boxMonthlyCleanrecommendationINTERIM FINAL -ADEQ Pb Ambient Air Monitoring Network QAPPOctober 201191INTERIM FINAL -ADEQ Pb Ambient Air Monitoring Network QAPPOctober 201192CriteriaFrequencyAcceptable RangeCitation/InformationFilter cassette holder & sample savershieldBefore and after eachsampling eventInspect/CleanrecommendationAnalytical StandardsReagentsNitric acid (HNO3)Hydrochloric acid (HCL)Each analytical batchACS reagent gradePart 50 App G sec.6.2Pb nitrate (Pb(NO3)2)Each analytical batchACS reagent gradePart 50 App G sec.6.2Verification/CalibrationClock/timer VerificationEvery other sampling event+2 min/moPart 50, App B sec 7.7.2BiasPerformance Evaluation Program(PEP)Annually – 1 field auditQuarterly – 1 collocated filtersample95% CL Absolute bias15%Part 58, App A, Sec 2.3.1SD= standard deviationCV= coefficient of variationAttachment A

Rationale for the Hayden Globe Highway Station Siting

### Rationale for Sitting ASARCO Hayd en Pb at Globe Highway Site

ASARCO Hayden Pb monitor: Rationale fo r sitting ASARCO Ha yden Pb monitor at Globe Highway Station based on discussi on between ADEQ and EPA Region 9, March 31, 2010. The following was prepared by Region 9:

Source-oriented lead (Pb) monitoring is required for the ASAR CO copper smelter in Hayden, Arizona. ADEQ chose the Globe Highway Station site after an analysis that considered source emission characteristics, past monitoring, and the topography and meteorology of the facility location.

A 1987 source apportionment study using the Ch emical Mass Balance model concluded
that 80% of the PM 10 Pb came from process fugitive emissions within the smelter ("Source Apportionment of Suspended Particle s and Toxic Elements in Hayden, Arizona, Final Report", NEA Inc., April 15, 1987). Dire ct observation by ADEQ staff confirmed that particulate plume emanates principally fr om the smelter building itself, rather than from other sources such as ore handling facili ties or re-entrained dust from storage piles. Because of the high temperatures involved in the smelting process, this plume is buoyant

and has substantial vertical velocity, reaching to 100 feet or more above ground level. Unlike for non-buoyant ground level plumes, th e highest ground level concentrations from such a buoyant plume would not be expe cted to occur immediately adjacent to the facility.

Because the bulk of SO 2 emissions are also thought to be emitted as buoyant fugitives

from the smelter buildin g, 1970's monitoring of SO 2 is relevant for Pb. (Since the stack is 1,000 feet tall, SO 2 impacts from stack emissions occur farther away and are diluted by the time stack plume reaches the ground.) At that time SO 2 monitoring was conducted at twelve different monitor locations; Globe Hi ghway Station was found to have the highest

concentrations. Because of the sim ilar emission characteristics of SO 2 and Pb fugitives, this suggests Globe Highway may also ha ve the highest concentrations for Pb.

The ASARCO Hayden smelter is located in ve ry complex terrain, with the Gila River making a winding semi-circle east to south of the facility, and intersected by the San Pedro River valley from the south. The facility itself is elevated relative to the valleys; there is a 200 foot hill just south of th e facility, and mountai ns rising toward the

north/northeast. The varied terrain causes co mplex wind flow. Within and adjacent to the river valleys, drainage winds tend to dominate at night under stable conditions, toward

the west on the south and west of the facili ty, and toward the south on the east of the facility. However, given the buoyancy of th e smelter building fugitive plume, and the facility's elevated location, emissions typica lly rise above these surface flows and would not be expected to result in high Pb concentrations. During the day under convective conditions, good vertical mixing causes pollute d air to reach the ground. The vertical mixing also causes the flow to be coupled with winds aloft, which ge nerally flow toward
the east. As was the case for SO 2 , these are the conditions expected to lead to high Pb concentrations and that also carry the plum e east, toward the Globe Highway Station.Should placement of another Pb-TSP monitor be possible, EPA supports placement west of the smelter building, to capture winds moving east to west over the smelter area.Attachment B

Rationale for the Miami Golf Course Station SitingLead (Pb) Modeling Analysis for FMMI Miami Smelter

Executive Summary

The purpose of this modeling was to evaluate the spatial distribution of lead concentrations from the vent fume stack at the FMMI Miami smelter. New requirements for source oriented ambient lead monitoring sp ecify that the lead monitor should be sited at the location of the highest ambient le vel taking into account the potential for population exposure. The results indicated th at the maximum impacts, based on the potential for human exposure, occurred nearby the FMMI facility. The modeled

concentrations at the Golf Course site were higher compared to those of the Ridgeline site

and the Townsite site.

Modeling Methodology

1. Model selection: Evaluation of the maximum am bient air quality impacts was conducted using AERMOD (User’s Guide for the AMS/EPA Re gulatory Model – AERMOD, U.S. Environmental Protec tion Agency, Office of Air Quality Planning and Standards, Emissions, Mon itoring, and Analysis Division, Research Triangle Park, North Carolina, EPA-454/B-03-001, September 2004).

2. Source characterization: According to Air Quality Control Permit No. 29622 For Phelps Dodge Miami, Inc. (now FMMI), two major sources of lead are the vent fume stack and the smelter’s fugitive emissions. The vent fume stack was modeled as a point source. The fug itive emissions were not modeled since detailed source information is not available. Moreover, it is believed that the impacts from the fugitive emissions are li mited to the locations nearby the sources due to low release heights.

3. Source parameters: The emission rate and the source release parameters are

summarized in Table 1. Note that the modeled emission rate was based on the permit limits rather than the actual emission rate. Therefore, the predicted concentrations should not be considered accurate. However, the location where the maximum concentrations are likely to occur can be considered valid since the spatial distribution of particulates is largely a product of meteorological and dynamical drivers and not necessarily emissions.

Table 1 Source Release Parameters Utilized in Lead (Pb) Modeling Analysis

Source Description Emission

rate (TPY) Stack diameter (ft) Stack height (ft) Stack exit velocity (ft/sec) Stack exit temperature (F)

Vent Fume
Stack 100 10 160 63 974. Receptors: Modeling receptors were placed in locations in ambient air and no receptors were established within the pr ocess area of the f acility (Figure 1). Moreover, receptors were not placed in th e remote mountainous areas where there is no potential for population exposure. The following receptor grid density was used: 50 m spacing along the ambient ar ea boundary, 100 m resolution from the ambient area boundary to 1 km, and 250 m resolution from the 100-m grid outward to 2 km. Preliminary tests indica ted that the receptor grid was adequate for determining the maximum impacts and significant impact areas.

Figure 1 Receptor Grid Used for Lead (Pb) Modeling Analysis

5. Meteorological data: A one-yea r site specific mete orological data set was used. This data set, pre-processed by ADEQ, combines the surface observations from the FMMI facility site, the cloud cove r data from the NWS Phoenix Airport (Surface ID 23183), and the upper air obser vations from the NWS Tucson Airport (Upper WBAN ID 23160). The wind rose plot is presented in Figure 2.

6. Terrain data: USGS DEM (30 m) data were downloaded from the website of http://data.geocomm.com/dem/demdownload.html . The SDTS2DEM program

was used to convert the DEM files from SDTS format to "native" form at.AERMAP, the terrain pre-processor, was used to generate terrain base elevations for receptors and sources as well as hill height scaling factors for receptors.

Figure 2 Wind Rose from FMMI On Site Tow er (100 ft)

7. Building downwash: Building downwash was not included since the building

information is not available.

8. Averaging time periods for modeling: The NAAQS for lead is based on a rolling 3-month average. However, AERMOD is not able to directly calculate the concentration for the rolling 3-month averag e. To calculate the rolling 3-month averages, the monthly concentrati on output from AERMOD must be post processed by using LEADPOST. Since th e purpose for this modeling analysis is not to demonstrate compliance with NAAQS, but to evaluate the spatial distribution of lead, only the annual and monthly average concentrations were reported.Results

The spatial distribution for annua l and monthly concentrations of lead is shown in Figure 3 and Figure 4, respectively. For discussion purposes, the lo cations of the existing air quality monitors (Townsite, Ridgeline, and Golf Course) as well as schools are also presented in the figures.

As indicated in Figure 3 and Figure 4, the maximum modeled ambient lead

concentrations occurred east-northeast of th e smelter. Two significant impact areas were identified; one is located approximately 0.5 miles eastside of the vent fume stack and the other is located approximately 1.5 miles northea st of the vent fume stack (nearby the golf course). All schools were outside of the two significant impact areas.

The modeled annual and monthly concentrations at the Golf Course site were higher than those at the Townsite site and the Ridgeline si te, mainly due to the fact that the Golf

Course site is located in the downwind side of the prevailing wind direction from the

smelter. The modeled results a ppeared to be supported by the PM 10 monitoring data,

which indicated that the PM 10 concentration recorded at the Golf Course monitor is average 1.5 times higher than that from the Ridgeline monitor.

Figure 3 Predicted Spatial Distribution of Lead (Pb) Annual Concentrations