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 1 
A.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: /u,$f/// 

Bernard Lum, Manager, Air Monitoring IJnit 

Signature: Date: cw // 

Quality Assurancc Unit 

Signature: 

Date: \O/s Lt/\ ! 

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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2 

LIST OF FIGURES 

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 CONTINUOUS DATA COLLECTION SYSTEM 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 QUALITY DIVISION (AQD) PB PROGRAM PERSONNEL .....................................8

TABLE A.2 PIMA COUNTY WASTEWATER RECLAMATION LABORATORY PERSONNEL ..............11

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

TABLE A.4 SUMMARY OF PCWRL DOCUMENTS AND RECORDS ...........................................................21

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

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

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

TABLE B.4 LEAD (PB) AIR MONITORING 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 PREVENTATIVE MAINTENANCE OF FIELD ITEMS................................................................38

TABLE B.9 STANDARD MATERIALS AND/OR APPARATUS FOR PB TSP CALIBRATION AND 

VERIFICATION .......................................................................................................................................................41

TABLE B.10 ACCEPTANCE CRITERIA 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 LEVELS FOR FILTER-BASED AND CONTINUOUS 

MEASUREMENTS...................................................................................................................................................78

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

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

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A.3 DISTRIBUTION LIST 

For the Arizona Department of Environmental 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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SECTION A. PROGRAM MANAGEMENT 

A.4 PROGRAM ORGANIZATION 

This Quality Assurance Program Plan (QAPP) describes ADEQ’s Lead (Pb) Monitoring 

Network for collecting source-oriented and non-source-oriented data for airborne Pb particles. 

The purpose of this QAPP is to provide an outline 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. The 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 and practices will be stringently applied to the EDO. In the 

event questions arise or additional information is needed regarding elements of this air 

monitoring program such as the sampling plan, instrumentation operation and QC requirements, 

data and measurement quality objectives, assessments, reports to management, or data 

management, the contact information for key program 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 analytical laboratory for the Pb network, the 

Pima County Wastewater Reclamation Laboratory (PCWRL), i.e., contract laboratory. This 

entity is performing work for ADEQ under a service agreement or Intergovernmental Agreement 

(IGA) and is responsible for managing their own QA/QC programs as required in their Quality 

Manual and internal standard operating procedures (SOPs) which are referenced in the QAPP 

and provided as attachments. The PCWRL is periodically audited by the Arizona Department of 

Health Services (ADHS) and the ADEQ QA Team will review these audit reports as they 

become available. In addition, the QA Team may conduct technical systems audits of PCWRL. 

The SOP for the EPA Region 9 analytical laboratory performing the analyses of quarterly 

QA/QC Pb Performance Evaluation Program (PEP) samples is also included in this QAPP. 

ADEQ will cooperate with both analytical laboratories regarding pertinent information 

concerning the collection, preservation, shipment, analysis, and reporting of sample results. 

ADEQ is responsible for collecting air filter samples, arranging for sample analyses, and 

applying accepted quality assurance (QA) practices to the field operations as well as data review 

and validation. The ADEQ Air Assessment Section (AAS) is responsible for the Pb air 

monitoring network. All AAS personnel worked together 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 modeler was responsible for identifying potential 

sites where the highest airborne Pb concentrations are expected using meteorological data 

collected by the source(s). A senior environmental engineer was responsible for finding 

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physical locations that met EPA criteria and final sites were approved by EPA Region 9 

program representatives. 

 Within the Air Monitoring Unit (AMU), the manager and several staff were responsible 

for selecting, testing, and installing Pb samplers at each site. Technicians tested the new 

samplers in-house before deploying to the air monitoring sites. Once installed at the sties, 

the technicians evaluated the new samplers’ performance in the field, performed trouble 

shooting on flow issues, and developed the 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 Laboratory (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 development of the AFL SOPs. A senior laboratory 

analyst is responsible for support (backup) sample handling services when needed. 

 Within the Data Management & Quality Assurance (DM&QA) Unit, the selection of sites 

and the modeling results were reviewed by the 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) audits 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 Program 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 securing 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 monitoring 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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Table A.1 ADEQ Air Quality Division (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.gov
Figure A.1 Pb Air Monitoring Program Organizational Chart 

Lead (Pb) Program

Functional/Staff Chart

Theresa Rigney

Air Assessment 

Section Manager

Kami Budhu

Administrative 

Assistant

Bernard Lum

Air Monitoring Unit 

Manager

Bryan P

DM&QA 

Manag

(Vacant)

Evaluation Unit 

Manager

Randy Redman

Site Coordinator

Feng Mao

Air Modeler

Greg Kendall

Lead Site Operator

John Olasin

Air Filter Lab 

Supervisor

Ralph Lucero

Lead Monitoring 

Technician

Kanika Simmons

Alternate 

Laboratory Support

Jon Midgley 

Toxic Data 

Reviewer 

Heather Colson 

Lead Data 

Reviewer 

Terry Taflinger

Lead Service 

Report Reviewer

Mark Ca

Lead Cont

Data Rev

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Figure A.2 ADEQ Air Quality Division Organizational Chart 
PCWRL is responsible for providing analytical laboratory services as stipulated in the IGA. 

Responsibilities include: analyzing Pb air filter 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 with, and approving this QAPP. 

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

• Evaluating quality system performance through 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 unmet quality assurance needs in a timely 

manner. 

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A.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 ambient airborne concentrations of Pb from 

1.5μg/m3 to 0.15μg/m3 for both the primary and secondary standards. Lead is one of six criteria 

pollutants identified by the EPA. Stationary sources 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 Air 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 assurance 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 health, especially in “sensitive” populations 

which include asthmatics, children, and the elderly. An array of adverse health effects can be 

attributed to Pb exposure including neurocognitive and neurobehavioral effects in children. 

Initially, Pb monitoring was required near sources that emit more than one ton of Pb per year. 

EPA later revised the Pb monitoring requirements to include monitoring near 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. and Freeport McMoRan, Inc., respectively. Tables 

and figures showing maps and metadata for these 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 these two areas at the beginning of the 4th quarter 

2010. The EPA required Pb monitoring at the beginning of 2010, but ADEQ funding limitations 

delayed the purchase of the new instrumentation until the summer of 2010. In addition to 

ADEQ’s Pb sampling near Hayden, additional EDOs 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 monitors near sources of Pb, EPA‘s Revised Lead Ambient Air 

Monitoring Requirements also requires Pb monitors 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 500,000 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 that Pb concentrations generated from the speciated PM10 filter sample 

used for the National Air Toxics Trends Station (NATTS) may be used. ADEQ is awaiting a 

final determination for use of these data from EPA. Monitoring at the JLG Supersite is 

anticipated to begin in December, 2011. The collection 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 Assurance 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. Maricopa and Pima Counties are each designated as a 

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PQAO by EPA Region 9, and they are responsible for all aspects of their Pb air monitoring 

network in the event they operate one. 

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A.6 PROGRAM DESCRIPTION 

The principal objective of the Pb network is to measure 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 reasonableness of source-oriented sites 

selected based on air shed models and to adjust site locations if needed 

 Determine the level of ambient airborne 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 monitoring, ambient air samples will be collected onto 8X10 inch 

fibrous glass filters using high-volume TSP samplers 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; Determination of Lead in TSP Using ICPMS 

with Heated Ultrasonic Digestion. 

For the non-source-oriented Pb monitoring, ADEQ plans to use a PM10 low-volume sampler for 

the collection of Pb at JLG Supersite. Information 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 provide useful information regarding the source or 

origin of Pb in ambient air. Monitoring methods and objectives for meteorological monitoring 

are addressed in a separate QAPP. 

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A.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 maintained within the established acceptance criteria. 

Data Quality Objectives

DQOs are defined as the qualitative 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 decisions 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 precision and bias. ADEQ will adhere to the DQOs 

and MQOs developed by the EPA. 

Measurement Quality Objectives

Overall MQOs/Measurement Uncertainty for the Pb program are: 

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

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

The measure of precision will be determined from the collocation results and will only include 

Pb concentration data > 0.02 μg/m3. 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 and control various phases of the measurement process to ensure 

that total measurement uncertainty is within the range prescribed 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 which data accurately and precisely 

represent a characteristic of a population, parameter variations at a sampling point, a 

process condition, or an environmental condition. Representativeness is controlled 

largely by the site location and type of air samplers used. 

 Precision – is the measure of mutual agreement among individual measurements of the 

same property usually under prescribed similar conditions. This is the random component 

of error. Precision is estimated by various statistical techniques using 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 distortion of a measurement process which causes 

error in one direction. Bias will be determined by estimating the positive and negative 

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deviation for the true value as a percentage of the true value. Bias is determined by Pb 

PEP filter results and routine PE audits. 

 Detectability – The determination of the low range critical value of a characteristic that a 

method specific procedure can reliably discern. 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 less than, 5% of the NAAQS (0.15 μg/m3). 

 Comparability (reporting units and analysis) – Pb concentrations will be reported in 

micrograms/meter cubed (μg/m3) as required 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 expected to be obtained under correct, normal 

conditions. The minimum data completeness requirement 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 being 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 criteria not being met 

All monitoring instruments will be operated within 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 Validation 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 Analytical Methods on Table B.5. If any instrument 

fails its verification, calibration, or performance evaluation (PE) audit, AMU will take the 

appropriate actions to correct instrument performance as quickly as possible to prevent missing 

scheduled sample collection days. 

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A.8 SPECIAL TRAINING/CERTIFICATIONS 

The TISCH HIGH-VOL+ TSP air samplers purchased 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 more sophisticated low-volume samplers becoming 

the required method for particulate matter sampling 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 primary 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 demonstration of capability (IDOC) before working 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 professional development to employees whenever possible. Training 

includes courses, workshops, conferences, or trade shows. In addition, employees participate in 

webinars provided by EPA and complete self-instructional courses available through EPA’s Air 

Pollution Training Institute (APTI). 

In addition, the technical staff involved in the 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 sufficient time to the personnel directly involved in 

this project, including field technicians, to read and understand these documents. 

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A.9 DOCUMENTATION AND RECORDS 

Staff within the AAS use the J drive on our shared network for storing documents electronically 

in addition to maintaining hard copies of program-related documentation. The network drive is 

backed up daily by ADEQ Information Technology. Documents are stored for a minimum of 

five years. 

The modeling reports developed by the Evaluations 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\MONITORING UNIT\SITE_LOG\ADEQ Active Sites. 

AMU service documents, aka, field sheets, related to the operation of air 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, communication 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” reference 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 documents for Level 3 data validation. 

The AFL manages the ADEQ LeadTSP Air Sampling Record, e.g., chain-of-custody (COC) 

and/or field data form, associated with each sample. 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 audit sheets to the QA/QC Lead for review and 

approval and then the reports are forwarded to the Lead Pb Data Reviewer and the QA Team will 

submit any technical system audit (TSA) reports to the DM&QA Unit Manager for approval. 

Once approved, the report is sent to the 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 the 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 listed 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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Table 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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Type 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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Table A.4 shows the PCWRL documents 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 Files 

X:\CRAO\Lab Svcs\_Shared Data\Lab\trainingfiles 

Lab – Nancy 

Powell 

Final Reports Hardcopy and 

Electronic 

PCWRLP Files 

X:\CRAO\Lab Svcs\_Shared Data\Lab\trainingfiles 

Lab – Nancy 

Powell 

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SECTION B. DATA GENERATION 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 potential for population exposures, and the feasibility of operating 

samplers. To determine locations that represent the highest concentrations of airborne Pb, 

dispersion modeling and existing environmental data were used. This information was compared 

to the location of the population and the ability to obtain power, avoid obstacles that obstruct air 

movement, provide sufficient security to ensure sample custody and integrity, and safe 

accessibility for personnel. A review of all factors combined with consultation from the Region 9 

contact, yielded the following locations: 

1. Globe Highway (near ASARCO) 

2. Miami Golf Course (near 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 metadata 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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Table 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 maintains 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 Coupled 

Argon 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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Figure 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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Table B.2 Site and Metadata Information 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 Miami. Freeport McMoRan also maintains 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 Coupled 

Argon 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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Figure 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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Table 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 residential neighborhoods, with I-17 roughly 1,609 

meters west. 

Site Information

AQS ID 04-013-9997 ADEQ ID 16328 

Address 4530 N. 17th 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 concerning the Pb sampler at JLG Supersite. 

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Figure 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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Monitoring Plan

The objective of this work is to quantify the amount of airborne Pb, a toxic metal, near regulated 

sources emitting 0.5 tpy or more and the ambient 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 samples 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 sampler 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 collocation 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 the 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, ADEQ 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 schedule 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 for sample collection, only two (2) filter-based 

samples can be missed for each three-month period. 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 collecting makeup or extra samples. 

Make-up Samples

The EPA makeup sample requirements for the Pb program are aligned with the PM10 and PM2.5 

requirements. Makeup samples will be collected according to the following guideline: 

 If a TSP sampler fails to collect a valid sample 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 filter provided for the next scheduled run (a 

replacement filter will be obtained for the next scheduled run day), OR

 on the 7th day following the missed event 

Since sequential samplers are not in-use, meeting 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 concentrations from these samples are useful and will be 

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used in design value calculations that are comparable 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 10th 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 sample collection could be 

interrupted if a site becomes inaccessible temporarily 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 the proper authorities. Field personnel will report 

the site closure information to their direct supervisor and the program manager will be alerted to 

the incident as well. Each incident of site inaccessibility and the need for possibly establishing an 

alternate site or relocating an existing site will be handled on a case-by-base basis. 

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B.2 SAMPLING METHODS 

Lead (Pb) Air Sample Collection 

The objective of the Pb sample collection is to evaluate whether or not airborne 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 midnight 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 audit the samplers according to QA-013 SOP. Each TISCH TSP 

sampler contains a microprocessor with the ability 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 achieve the required flow rate due to altitude 

at the source-oriented sites), and an automated mass flow controller. Menu-driven software is 

used to program these samplers so they operate 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 meteorological conditions. The samplers will operate 

in Actual Conditions (AC), also known as Local Conditions (LC). Again, Table B.4 shows the 

air monitoring instruments and the sample 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 regulatory 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 LeadTSP Air Sampling Record for each sample to be 

collected. This process follows the AFL-Pb-001 SOP. The filters will not be weighed before or 

after sampling to determine a PM concentration 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 filters 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 attachments 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 occur. Sample volume is periodically checked by 

hand using the following equation: 

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

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Table 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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B.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 followed 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 analyzed 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 and 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 LEADTSP Air Sampling Record serves 

as the chain-of-custody as well as the sample collection 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 authored 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 analysis at an analytical laboratory. 

To ensure each sample’s integrity while installed in a sampler, each Pb air monitoring site is 

protected from trespassers or unauthorized persons using security fencing that is at least 6 feet 

high with razor or barb wire installed 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 filter samples during handling, the exposed filter is 

quickly covered with a filter holder faceplate following the retraction of the sample saver shield. 

The filter cassette holder is carefully removed from 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 prior to the next unexposed 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 each 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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B.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 performing analysis for environmental compliance 

purposes be licensed by the ADHS for the analytical method. Table B.5 shows the approved 

EPA analytical method or equivalency for determining 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. PCWRL 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 Spectrometry (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 volume 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 for 

Lead (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 46th St 

Richmond, CA 94804-4600 Phone: 510-412-2389 

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B.5 QUALITY CONTROL 

Quality control (QC) is the overall system of technical activities that measure the attributes and 

performance of a process against established standards to verify that performance meets the 

stated requirements established by the decision maker or data user. Information on data 

validation and verification can be found in Section D. 

To assure the quality of data from air monitoring measurements, two distinct and important 

interrelated functions must be performed. One function is the control of the measurement process 

through broad quality assurance activities such as establishing policies and procedures, 

developing DQOs, assigning roles and responsibilities, conducting oversight and technical 

system review, and implementing corrective actions. 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: certification of calibration equipment as required, 

calibrations, verifications, PE audits, collocation of samplers, proper maintenance and care of 

sampling, calibration and analytical instruments, and participation in the national EPA Pb PEP. 

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B.6 INSTRUMENT TESTING, INSPECTION, AND MAINTENANCE 

The purpose of this element is to discuss the procedures used to verify that all instruments and 

equipment are maintained in the proper condition 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, and if possible, backup samplers and 

meteorological monitors. Supplies and consumables are inspected for defects prior to use and 

their availability in-house is monitored by the AMU lead technician and operator. 

ADEQ plans to use only Pb high volume TSP samplers that meet 40 CFR Part 50 Appendix B 

specifications. Currently, Pb samplers do not have manufacturer-specific 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 requirements. 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 m3/min 

(39 – 60 CFM) 

Operational Set Point 1.13 m3/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 cm2 (63 in2) Part 50 App B sec 7.1.2 

NOTE: Criteria verified prior to purchase of sampler/start of sampling 

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The main component of ensuring correct instrument operation is through routine verifications. 

As mentioned previously, the frequency of these routine verifications 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 verified by using a water manometer following ambient 

temperature and pressure verifications. 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 details 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 the inspections performed in the field before and after sample 

collection. 

Table B.7 Inspection of Field Items

Item Inspection 

Frequency 

Inspection 

Parameter 

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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Preventative Maintenance of Field Items

There are many field items associated with appropriate preventative maintenance of a successful 

field program. Table B.8 details the appropriate maintenance checks of the Pb samplers and their 

frequency. Details on maintaining this instrument 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 Shop 

TISCH HIGHVOL+ 

Control and 

pump box 

Clean monthly AMU Operator 

or Technician 

In field at site 

NOTE: Adjustments in routine, preventative maintenance frequencies will be made as needed 

once a strong operating history is established and based upon the operational demands on the 

samplers. 

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B.7 INSTRUMENT CALIBRATION AND FREQUENCY 

Calibration is defined as the comparison of a measurement standard, instrument, or item with a 

standard or instrument of higher accuracy to detect 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 software occurred. EPA recommends that adjustments 

be minimized to prevent introducing measurement 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. Typically, calibration activities follow a two-step 

process. 

1. Certifying the calibration standard and/or transfer (working) standard against an 

authoritative standard, usually the National 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 temperature and pressure sensors against the working 

temperature and pressure 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 will be used to verify and calibrate the 

instrument’s flow rate. Flow verifications are performed manually by the field technicians and 

are conducted in ambient conditions. Flow calibrations are initiated by field technicians, but the 

calibration process is an automated process. Due to instrumentation limitations, calibrations are 

performed in standard conditions. Prior to the auto-calibration procedure, 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 and pressure. See the AMU-Pb-001 SOP for exact 

calibration flow ranges for sites with TSP samplers. The equivalent ambient flow rates were 

calculated for each site, based on typical measurements of temperature and pressure. The 

calibration flow rates are determined by the digital 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 digital manometer is out of tolerance during the flow verification, a 

Pcal (inches of water) calibration is conducted. For more details on the calibration procedure, see 

the AMU SOP in the attachments. A digital temperature 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 verifications. The high frequency 

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of one-point verifications allows for an assessment of the temperature 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 sampler calibration and verification are shown in 

Table B.9. 

For the Pb TSP samplers, ADEQ is conducting calibrations 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 criteria for calibrations, verifications, and audits 

of the TSP samplers are found according to Table B.10 and the ADEQ Pb Validation Template 

found in Section D. The associated SOPs are included as attachments. Parameters of the ADEQ 

Pb TSP samplers that are subject to routine calibrations, verifications, and audits in the field 

include:

 Flow rate 

 Ambient temperature 

 Barometric pressure 

 Date/Time 

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Table B.9 Standard Materials and/or Apparatus 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 7 

years 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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Table 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 m3

/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 m3

 / 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 H2O) 

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 

m3

/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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Table B.11 shows acceptance criteria 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 R2 = 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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Criteria 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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B.8 INSPECTION/ACCEPTANCE REQUIREMENTS FOR SUPPLIES AND 

CONSUMABLES 

The purpose of this element is to establish and 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 supplies and consumables that 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 & Receiving 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 consumed at a faster rate than anticipated for any 

reason, AFL will contact the currently designated EPA representative and request additional 

filters. In the event the annual allotment 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 network to the normal EPA monitoring schedule. 

To prevent damaging the brittle, fibrous glass filters 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 environment 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 unexposed 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 inspected several times during the sample collection 

process to verify that the filter is without damage or defects including pin holes, tears, uneven 

thickness. Filters are examined when loaded into the filter holder cassette, upon installation and 

removal from the sampler, and during sub-sampling prior to shipment to the analytical 

laboratory. 

Table B.12 shows the critical field supplies for the Pb network. 

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Table B.12 Critical Field 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 

TISCH 

TISCH HIGHVOL+ Sampler 

Back-up fibrous glass 

filter for 

calibration/verification 

check 

Used during 

calibration/verification 

process 

EPA 

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B.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 includes both outside and historical monitoring 

data. 

Chemical and Physical Properties Data

Chemical and physical properties data and conversion 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 Standards 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 longitude 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 historical trends, it is important to verify that historical 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 organization 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 the 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 biases, 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 are comparable with the measurements and that the 

original data generator had an acceptable QA program in place. 

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Meteorological Data from Other Sources

Meteorological data from sources such as the National Weather Service, National Climate Data 

Center, and other regional climate centers are used to provide 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 utilized. These data were obtained from ambient air 

quality and meteorological monitors operated by local facilities. The ADEQ QA Auditor 

performs annual PEs on these facility-operated monitors to verify the quality of these data. Also, 

ADEQ often utilizes meteorological data collected 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 reviewed 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, particularly for the Miami area. The 

AERMOD dispersion model, utilizing facility and NWS data, was utilized to determine the area 

of maximum Pb concentrations in the Miami area. 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 information available. For these cases, the limitations and 

precautions are considered throughout the decision making process. 

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B.10 DATA MANAGEMENT 

Data management (DM) describes how the data are handled through the collection, analysis, 

validation, and reporting processes; and, it identifies responsibilities and requirements during 

each process. DM begins with sampling activities and includes any or all of the following 

operations and their documentation: data recording, transformation, 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 the Pb and meteorological data. 

Source-oriented data measurements 

For Pb data, interval and sample summary data 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 shipped to the analytical 

laboratory. This check involves review of the interval data by the AMU lead operator or AFL 

supervisor to verify that the sampler operated within acceptance criteria and each filter sample 

was not exposed to air flow before or after the scheduled sample collection day. In addition, the 

summary data for each sample run day is checked to verify the information provided on the 

corresponding ADEQ LeadTSP Air Sampling Record sheet is correct. Following analysis, 

PCWRL performs verification and validation on Pb concentration data prior to sending results in 

μg/m3 and μg/strip to DM&QA. This constitutes the Level 2 validation. PCWRL assigns the 

appropriate validation flag to data as needed. The data are submitted in electronic AAAD format 

on a monthly basis. These data are then loaded to ADEQ’s AAAD by the DM&QA Lead Pb 

Data Reviewer, who then performs Level 3 validation on the data. Upon completion of the Level 

3 validation, the data are then transferred to the EPA AQS database. 

For meteorological data, ADEQ has established 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 collection 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 used, DM&QA will be responsible for determining if 

it meets EPA and/or internal standards for quality.
Figure B.4 Continuous Data Collection System Hardware Architecture 

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Data Management Responsibilities by Entity

DM activities and responsibilities at ADEQ for the 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 three monitoring sites (MIGC, HAGH, JLG) 

 documenting all instrument verifications, calibrations, maintenance, change-outs, instrument 

and site log books, site information forms; and, providing such reports to DM&QA for QA 

purposes 

 transporting unexposed filters and exposed filter samples to and from sites; loading and 

unloading of filters into samplers; and, providing sample collection information in the field 

portion of the ADEQ LeadTSP 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 documents in AMU and/or with DM&QA 

 communicating status of air monitoring to management 

Good data management practices also include personnel accountability for completion of 

specific tasks. Therefore, all field sheets, ADEQ LeadTSP Air Sampling Records, shipping 

documents, etc., will be reviewed by the appropriate AAS staff member for correctness and 

completeness, including any required signatures or initials. 

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Air Filter Laboratory Responsibilities

The AFL is responsible for: 

 pre-sampling - for all three monitoring sites setting-up filters in the filter cassette holders for 

each sampler and initializing ADEQ LeadTSP 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 emails, shipping records, copies of ADEQ 

LeadTSP Air Sampling Records (COC/data form), and other documents as needed 

The AFL staff will follow good data practices by: 

 reviewing all ADEQ LeadTSP Air Sampling Record information for completeness and 

correctness 

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

 storing hard copy documents (COC, shipping schedules and records, etc.) in the 

appropriate files 

 communicating with management 

Good DM practices rely upon personnel accountability for completion of specific tasks. To 

ensure good DM practices are continuously employed, documentation, such as ADEQ LeadTSP 

Air Sampling Records, shipping documents, etc., and required signatures/initials, is routinely 

reviewed by AAS staff for correctness and completeness. 

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Data 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 instrument metadata and entering it into AAAD 

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

sites 

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

 overseeing the automated Level 1 QA procedures performed within the AAAD 

 performing Level 2 and 3 QA of the 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 field 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 data summaries for delivery to the program 

managers 

 overseeing and evaluating PE and PEP results 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 provided the format and specific variables 

required. 

As stated above, good data management practices 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 naming conventions for each data set 

 storing hard copy documents from the AMU staff 

 providing reports to management 

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Contract Laboratory Data Management Responsibilities 

The contract laboratory, PCWRL, 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 management procedures are described in their 

respective QM and SOPs which are found in the Attachments. PCWRL has a Laboratory 

Information Management Systems (LIMS) to store sample metadata, analysis, flags, and any 

additional information available for validation of the sample results. The laboratory must retain 

any data review documents provided by ADEQ. 

ADEQ expects the PCWRL to follow EPA and ADHS guidelines such as good laboratory 

practices. They are also expected to follow good data management practices regarding sample 

identification and tracking, data entry, verification, storage and security. 

The laboratory is responsible for integrating field data from the ADEQ LeadTSP Air Sampling 

Record with the analyzed data from the filter samples. The laboratory is also responsible for 

maintaining sample analysis and COC information. 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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Data Management Responsibilities by Activity

Pre-sampling and Start-up Activities

For source-oriented sampling, AMU will set-up TISCH HIGH-VOL+ TSP samplers at the three 

monitoring sites, perform initial and subsequent calibrations, and verify 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 initial and subsequent calibrations and precision 

checks. DM&QA will conduct PE audits on all of the instruments near the beginning of 

monitoring and quarterly thereafter. DM&QA personnel will complete site and instrument 

metadata forms. DM&QA staff will enter the required 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 LeadTSP Air Sampling Record for all Pb filter samples and blanks. 

AFL will set-up and adjust as needed a shipping schedule for sending the Pb filter samples and 

field blanks for ICPMS analysis with PCWRL. All required supporting 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 LeadTSP 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 LeadTSP Air Sampling Record forms. The AMU 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 LeadTSP Air Sampling Record forms to AFL. The downloaded 

electronic data files will be reviewed and loaded to the designated 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 download summary and interval data files from the 

samplers onto laptops, thumb drives, palm pilot or other suitable electronic device and copy to 

the ADEQ network drive. Data downloads are schedule to occur after 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 monitoring instruments in the Pb network on a regular 

basis. 

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AFL will ship Pb filters to PCWRL for ICPMS analysis on monthly basis, or other frequency if 

needed. 

The Lead Continuous Data Reviewer or their designee 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 designee 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 performed 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 handwritten numbers are clearly identifiable 

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

 verifying that the documents have been filed in the appropriate location 

Field records are reviewed for completeness and accuracy and initialed by the Lead Service 

Report Reviewer, the Lead for QA/QC, and the Lead Pb Data Reviewer. 

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Electronic 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 have been correctly programmed 

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

It is best to inspect these files as soon as possible after receiving the files, especially if data 

review will not occur immediately. 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 performing the operation must verify that the data 

have transferred correctly. Checks on electronic data operations 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., leading 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 proper procedures are followed, 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. All necessary site and 

instrument information (e.g., site location, sampler 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 kept at each site and with each Pb sampler for use by the field 

technicians to record all activities 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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Chain-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 information for each sampling event are recorded on the 

ADEQ LeadTSP 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 LeadTSP Air Sampling Record has 

specific spaces for each item below. The handwritten 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 notes regarding any irregularities 

An example of this form and additional information regarding its use is provided in the AFL & 

AMU SOPs found in the Attachments. Completed ADEQ LeadTSP Air Sampling Records will be 

made available to the PCWRL and DM&QA staff validating Pb data. A copy of each ADEQ 

LeadTSP Air Sampling Record is retained by ADEQ and checked 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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Data 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 summarizes the specific ADEQ records and documents 

and the Unit responsible for storing them. The contract 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 produced by the contract laboratory 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 data 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 contains both continuous data from the DCS and noncontinuous data from filters, canisters, and cartridges (FCC). The AAAD also contains 

instrument information and has graphics capability to assist users in quality assurance data 

review. AAAD is linked to the ADEQ AZURITE database 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 including table access, screen access, and the ability to insert, 

update and delete data and metadata. User roles are assigned by the database administer (the 

DM&QA Unit Manager). In addition, the AAAD is linked to ADEQ’s central AZURITE 

database which contains ‘Place’ and ‘Customer’ information. The user role to access the ‘Place’ 

information required for the AAAD is assigned 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 procedures 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 security 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 procedures have not been finalized and may be 

part of the current ISDU development of an AZURITE data warehouse. 

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Table 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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SECTION C. ASSESSMENT AND OVERSIGHT 

C.1 ASSESSMENTS and RESPONSE ACTIONS 

This element describes the internal and external 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 implemented 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 the control efforts are adequate or need to be 

improved. Documentation of QA/QC efforts implemented during the data collection, analysis, 

and reporting phases is important to data users, who can then consider 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 identify 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 collection operation or organization to establish 

whether the prevailing quality management structure, policies, practices, and procedures are 

adequate for ensuring the type and quality of data needed are obtained. MSRs are conducted or 

lead by the ADEQ QA/QC Unit Manager and are targeted 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 part of the MSR. The ADEQ QA/QC Unit will report 

the findings to the AAS Manager within sixty (60) days of completion of the MSR. The report 

will be appropriately issued to ADEQ Directors. Follow-up and progress on corrective action(s) 

will be tracked, documented, and filed appropriately.

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Assessments 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 are being fulfilled. On a routine basis, ADEQ AMU 

and DM&QA personnel will review log books and instrument service reports (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 information from the PCWRL is also reviewed 

when batches of data are submitted for Level 3 validation. 

Annual Monitoring Network Plan and Five-Year Network Assessment

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 identifies the purpose of each monitor and provides 

evidence that the siting and operation of each monitor meets EPA requirements. It is used to 

determine how well a particular air monitoring network is achieving its required air monitoring 

objective(s) and what modifications are needed for it to continue or to better meet its 

objective(s). 

The annual monitoring network plan must be made available for public inspection (website, 

hardcopy posting in libraries and public offices, and/or newspaper listing) for at least 30 days 

prior to submission to EPA. Although not required, EPA recommends soliciting comments 

during the public inspection period. If an opportunity 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 quality 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 sites are not longer needed and can be terminated, and 4) whether 

new technologies are appropriate for incorporation into the ambient air monitoring network. This 

assessment must also include a review of existing and proposed sites to determine if areas with 

relatively high populations of susceptible individuals (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 the 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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Types of Network: 

Air quality surveillance systems consist of networks 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 (SLAMS), including FRM, FEM, and approved 

regional method (ARM) monitors 

2) National Core multi-pollutant monitoring stations (NCore) 

3) Chemical Speciation Network (CSN) stations (formerly known as Speciation Trends 

Network (STN) stations) 

4) Photochemical Assessment Monitoring Stations (PAMS) 

5) Special Purpose Monitor (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 independently by permittees (Industry) 

12) Meteorological sites 

Technical Systems Audits (TSAs)

A TSA is a thorough and systematic on-site qualitative audit, where facilities, equipment, 

personnel, training, procedures, and record keeping are examined for conformance to the QAPP. 

External (EPA) TSAs are scheduled to be conducted 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 comprised of the QA/QC Lead and QA Auditor, 

conducts TSAs as a team, but either may individually conduct the audit. In addition, the QA 

Team may request that other personnel or technical experts participate on the Audit Team. The 

Audit Team will perform three TSA 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 collection, flagging, data editing, security, upload. 

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Key personnel to be interviewed during the audit are those individuals with responsibilities for: 

planning, field operations, QA/QC, data management, 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 present 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 pertinent information such as: pollutant(s) impacted, 

estimated time period of deficiency, site(s) affected, and reason of action. During the debriefing 

discussion, evidence may be presented that reduces the significance of the finding; in which case, 

the finding may be removed. If the audited group is in agreement with the finding, the discussion 

is documented and the form is signed by the organization’s director or their designee during the 

exit interview. If a disagreement occurs, the Audit Team will record the opinions of the audited 

group and set a time at some later date 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 major ADEQ Internal Audit Finding form generated 

that can not be resolved at the debriefing. Minor findings and recommendations will be tracked 

using a less formal system and solutions identified will be tracked until implemented and 

monitored to ensure a positive result is realized. Solutions to audit findings will be further 

explored as needed at follow-up meetings held 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 executive summary of findings covering the following 

areas: planning, field operations, laboratory operations, QA/QC, data management, and 

reporting. Findings and recommendations will be discussed 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 Team 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. See Section C.2 for more on the TSA report. 

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Figure 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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Figure 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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Audits 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. ADQs 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 evaluation of both the raw data and the supporting 

documentation. Sufficient time and effort will be devoted 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 checklist or questionnaire to ensure that the data collected at 

each stage maintain their integrity. The ADQ will serve as an effective 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 requirements 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 quality 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 the 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 field 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 samplers as specified in the EPA’s QAPP or 

associated SOPs. If the flow rates do not fall within the acceptable range, then the QA Auditor is 

notified, who in turn notifies AMU so that a remedial 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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Performance Evaluation

A performance evaluation (PE) is a type of audit in which the data generated by the measurement 

system are obtained independently and compared with the routinely obtained data to evaluate the 

proficiency of a technician, analyst, or laboratory. ADEQ PE audits 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 the 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 auditor sets up a second audit 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 Laboratory 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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C.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 procure necessary additional resources. Routine 

reporting also provides a means 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 uncertainties 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 associated data acquisition, validation, 

assessment, and reporting. 

Quarterly and Annual Data and QA Summary Reports

Data summary reports will be distributed quarterly to management to brief them on the status of 

the operations of the instrumentation as well as the status of data summary metrics in comparison 

to the NAAQS. These quarterly reports are based on quality assured Level 3 data. During the 

first year of Pb monitoring, monthly reports will also be provided to management to provide 

more timely updates on the overall operation of the instrumentation and the status of data 

summary metrics in relation to the NAAQS. These 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 certification 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. All 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 particulate data throughout the state of Arizona for those monitors 

operated by ADEQ. The Pb data and QA summaries are included as a section within the Newsy 

Letter. Information such as data completeness, NAAQS comparisons, collocation details, and a 

summary of quality assurance issues are contained within the Newsy Letter. 

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Annual reports to management primarily include 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 collected throughout the state of Arizona, 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 Report serves as a centralized document that 

reports on air quality data collected by the state and local agencies in Arizona. 

The annual data certification 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 quality assurance and data 

review aspects that are associated with ambient 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 any 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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Annual 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 describes 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 network, including Pb beginning in 2011. The Annual 

Audit Report includes, but is not limited to, the following QA information: 

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

 a summary of the flow rate and performance 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 uncertainties, 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 with 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 information such as an audit ID number; 

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

 background information about the project, purpose of the audit, dates of the audit; 

particular measurement phase or parameters that 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 prepared 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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group has written comments or questions concerning 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 sixty (60) days following the TSA 

debriefing. The report will include an agreed-upon 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 situations are often identified by ADEQ staff during 

the course of everyday activities. If a program deficiency is discovered that may impact the 

quality of data generated, a process is in-place to ensure that the appropriate personnel are 

notified and that a corrective action(s) is taken. AQD will use a notification and response process 

through the use of the Non-Conformance Event Notification & Response Form (NCEF) (See 

Figure C.3). This form may be used by any 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 notification and response by multiple AAS Units. 

The NCEF is designed as a closed-loop system. First, it identifies the originator, the person who 

is reporting and identifying the NCE. The originator describes the event 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 requiring that the recipient(s) take any necessary 

action in a timely manner and document the action taken and its effectiveness. The form is 

signed by all responsible parties, routed for 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 corrected in a timely manner, 

d) provide a fast and effective way to communicate to all parties who may 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 ambient air monitoring programs and instruments, 

including those operated by other parties, and any ambient air monitoring equipment indirectly 

associated with the AAS, such as permitted facilities. 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 AAS staff person who will then be responsible for 

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

complete the necessary actions in an effective 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 Manager 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 laboratory and/or monitoring 

program staff (field or data management) cannot be resolved at the Unit Management 

level.

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Figure C.3 ADEQ AQD Non-Conforming Event Form 

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SECTION D. DATA VALIDATION AND USABILITY 

D.1 DATA REVIEW, VALIDATION, and VERIFICATION REQUIREMENTS 

Data review is the set of verification and validation procedures used to examine the products of 

data collection and data processing to determine their 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 verification 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 implemented to ensure the operation was done 

correctly. 

Data review also provides feedback on the field 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 require further investigation with meteorological, climatological, 

and other environmental information to determine what event they represent. Ideally, data review 

is to be performed as soon as possible after data collection and on a regular schedule during the 

project to enable timely investigation of questionable data, to meet data reporting requirements, 

and to take corrective action. 

Data verification and validation are defined as follows: 

 Data Verification techniques confirm by examination and 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. The 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 validation are typically sequential steps performed by different 

persons. Data validation begins with the outputs from data verification and, ideally, it is 

performed by a data reviewer independent of the data collector, data processor, and data user. In 

general, data verification techniques occur during the sample collection and processing phases of 

the project. Data validation techniques are then applied on the resulting data product, which 

requires review of information generated throughout the entire sample collection, sample 

analysis, and data handling process. Additional verification and validation checks can be created 

as necessary to check the results of any operation affecting the data product. 

 

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Data review is not the same as data quality assessment or evaluation of the DQOs. Only after the 

data set has been reviewed, verified, 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 requirements. The specific data review procedures 

used by the contract laboratories 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 matches the sampler’s record. 

The contract laboratory usually performs Levels 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 laboratories. Level 2 checks include verification of the 

processed data with the ADEQ LeadTSP 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, and 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 agreement to DM&QA at ADEQ. These deliverables 

include electronic files of: 

 raw and validated sample data in the laboratory’s format with detection limits or 

uncertainties 

 a definition list for all acronyms and 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 checks of the validated data by reviewing the 

data flags applied by the laboratory in the laboratory’s files. ADEQ will use its in-house records 

to examine data that have been flagged for attribution, 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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Data Review, Validation and the Air Assessment Ambient Database (AAAD)

Much of the data review and validation process is done within the AAAD. As discussed in 

Section B, AAAD offers some tools 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 the 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 instruments, laboratories, and 

agencies are of a common data format. While these data transformation may occasionally occur, 

the raw data files are always archived. 

Levels of Data Review

The data review procedure at ADEQ requires all data measurements to move through multiple 

levels of quality assurance. When each level of data 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, and to validate their quality in relation to the 

requirements of conformance to procedures, equipment operation, and environmental effects. 

Those measurements not meeting the requirements are assigned invalid or suspect status with a 

reason code describing the nonconformance. A description of ADEQ’s QA Levels is listed in 

Table D.1. 

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Table 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 events (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 associated 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 invalidated based on the best assessment of the 

individual situation. Data corrections and flagging are noted in regular 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 considered to be valid can 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 results and activities that occurred throughout the 

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given year. This annual review and promotion of data to Level Final occurs during the data 

certification process. 

AAAD flagging protocol requires a reason code for each sample value 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 specific reason codes that further explain the status 

code. If additional explanation is needed, the comment field can be utilized. Each data record is 

comprised of a data value field, a QA status field, a reason code field, 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 code 
D.2 VERIFICATION and VALIDATION METHODS 

All data collected by the AAS must be reviewed and quality assured to the appropriate QA Level 

for the data type. These levels of quality assurance have the objective of reviewing the data at 

different scales to identify those measurements influenced by sampler problems, collection 

errors, or laboratory analysis errors. The remaining data are considered representative of their 

ambient environment; measurements above or below expected values are investigated to 

determine the nature of the environmental conditions they represent. 

Data verification and validation requirements have been previously described in Section D.1. 

The multiple levels of quality assurance have been described in Section D.1. This section will 

describe the data review methods employed to verify and validate data 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 Level 2 focuses on internal and between sample 

consistency on a site by site basis; data may be reviewed over a week (continuous data) or in 

sample batches (FCC data) to examine the behavior of the data through time. QA Level 3 

reviews the data over longer periods of time, investigating data behavior 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 based 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 scope 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 effort between laboratories, which conduct the 

chemical analyses and complete the first stages of data validation, and ADEQ, which conducts 

further validation and verification. For continuous measurements collected by the DCS, ADEQ is 

solely responsible for the data validation. FCC and DCS data are stored in the AAAD, the data 

repository for the AAS. As discussed in Section D.1, AAAD, and the tools within AAAD, is 

used to perform certain data review checks and 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 instrument is connected to a data logger 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 store both raw data files and AAAD formatted data 

files on the ADEQ network drives for loading 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 accurate 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 identify 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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will review the data to verify data validity flags 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 reviewers and QA levels. This field is also 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 consisting of automated 

checks: 

1. Data Upload from DCS to AAAD using Oracle SQL Loader: The upload process verifies 

correct formatting of each data record coming from 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 the record. Valid records enter 

the AAAD staging table. 

2. Data Validation: The data in the staging tables 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 the time period with a null value assigned 

for the raw value and the QA value at Level 1. A preliminary determination of the 

QA status and reason code is assigned 

 check for hour beginning or hour ending; adjust all data from hour ending instruments 

to hour beginning 

 convert English unit measurements to metric units 

 check screening limits for the parameter and assign Level 1 QA status of Suspect if 

outside the limits 

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Figure D.1 AAAD DCS Secondary Quality Assurance Screen 

DCS QA Level 2 Review

QA Level 2 review will be done by the Lead Continuous Data Reviewer or their designee as 

soon as possible after loading the data into the 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 any 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 pollutant data undergo Level 2 quality assurance procedures on a daily basis, 

while meteorological data undergo Level 2 data review on a weekly basis. The Level 2 review 

includes the following steps: 

1. Check the AAAD DCS Upload Validation screen 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. The deficiency will be identified, the records 

corrected or deleted, and the 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. The AAAD graphing tool 

will identify any data that were determined suspect during the automated level 1 validation 

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process. Evaluate all data that are represented in the graphical plot. 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 appropriate ‘B’ code using any field 

reports, verbal communication, or email communication. Check flagged data and if valid, 

copy the data to Level 2 and assign the V1 flag. Promote the remaining data to Level 2 

using the appropriate reason code. 

3. The Lead Continuous Data Reviewer or their 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 continuous data reviewer or their designee. Level 3 

data review includes an evaluation of the data on longer temporal scales, usually on the order of 

months. The Level 3 data review process also serves 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 also during the Level 3 data review process that data are flagged 

with the appropriate qualifier flag, if needed. Most often, this includes 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 parameter. The data review steps are: 

1. Review all field sheets associated with the parameters of concern. Verify that all 

instruments passed their QC checks. The QC checks that are considered during the Level 3 

data review process can be found in the critical criteria section of the validation template 

(see Table D.3). If a QC failure occurs, data should be invalidated 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 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 during the previous QA 

level reviews. Communicate and coordinate with other data reviewers, air quality 

forecasters, and instrument technicians to determine validity of data. Other data sources 

may be utilized, such as the data from the NWS, 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. 

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83 
FCC Data Review Methods

Pb data consist of discrete 24-hour samples and 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 analysis results from the fibrous glass filter samples. The data 

are delivered to the DM&QA Unit for review and loading into the AAAD for Level 2 and Level 

3 validation checks by the lead Pb data reviewer or their designee. 

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

Filter-based data undergo the majority 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 are completely filled out and accurately 

document the transfer of filters throughout the data collection and analysis process 

 Filters have been analyzed for any deformities 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 instrumentation 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 validation procedures above, some automated validation 

procedures may also be incorporated. These include: 

 Continuous laboratory environment monitoring, 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 metadata are accurate and exist within the AAAD 

The laboratory is primarily responsible for Level 2 validation and data review. This consists of 

verifying that all samples passed their QC criteria, or flagging those data that exceeded 

laboratory specific acceptance criteria. 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 final 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 

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The FCC Level 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 data on longer temporal 

scales, usually on the order of months. The Level 3 data review process also serves as a nearOctober 2011 

84 
final validation of data and incorporates the official field activity reports (and the instrument QC 

data) into the validation decision-making process. It is also during the Level 3 data review 

process that data are flagged with 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 the parameters of concern. Verify that all 

instruments passed their QC checks. The QC checks that are considered during the Level 3 

data review process can be found in the critical criteria section of the validation template 

(see Table D.3). If a QC failure occurs, data should be invalidated 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. Graph 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 during the previous QA 

level reviews. Communicate and coordinate with other data reviewers, air quality 

forecasters, instrument technicians, and laboratory 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 validation process, refer to the Lead Data Review 

SOP FCC-003 which is included as an attachment. 

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85 
D.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 assess the data along with 

the meteorological data to gain a better understanding 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 process, 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 the national Pb network, are continuously not 

met, then AAS will re-evaluate any internal 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 stringent for the monitoring methodologies in-use. If 

ADEQ AAS determines that any internal DQOs are 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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86 
Measurement 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. Information from the revised EPA Pb validation 

template will be included in this section once it is available. 

ADEQ developed the following validation template 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 tables of criteria where each table has a different degree of 

implication about the quality of the data. The criteria 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 analytical methods found in 40 CRF Appendix 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 flow rate for the sampling period must be maintained to within +5% 

of the set point which is currently 40 CFR in actual conditions. The second table has the criteria 

that indicate that there might be a problem with the quality of the data and further investigation is 

warranted before making a determination about the 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 impact 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 collected and validated. 

To determine the appropriate table for each criterion, the ADEQ Pb Team members considered 

how significantly the criterion impact the resulting concentration. This was based on experience 

from Pb Team members, experience from EPA Region 9 and OAQPS, criteria contained in the 

1977 Pb High Volume (TSP) Validation Template which was developed for sampling by TSP 

and analysis by atomic absorption, and feasibility of implementing the criterion. 

Criteria that were deemed critical to maintaining the integrity of a sample or group of samples 

were placed on the first table. Observations that 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 other quality control information demonstrates 

otherwise. The reason for not meeting the criteria MUST be investigated, mitigated or justified. 

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88 

Finally, those criteria which are important for the correct interpretation 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 objectives 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 criterion, the tables include (1) the operational range that is 

acceptable, (2) the frequency with which compliance is to be evaluated, (3) the number of 

samples that are impacted if violation of a criterion occurs (possible values include 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 violating the criterion must be 

flagged before entering them into AQS. 

This validation template has been developed 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 resulting mass estimate. Interactions of the criteria, whether 

synergistic or antagonistic, should also be incorporated 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. 

PbTSP 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 augmented 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 

CFR Part 136, Federal Register 73 FR 66964, Draft Technical Notes developed by EPA OAQPS, PCWRL Method EQL-0SOPs. Table D.3 Pb High-Volume (TSP) Validation Template 

Criteria Frequency Acceptable Range Cita

CRITICAL CRITERIA- Pb in TSP

Sampling Period all filters 1440 minutes + 60 minutes 

midnight to midnight 

P

P

Pa

Average Flow Rate every 24 hours of operation *1.13 m3/min (40 CFM) in Actual Conditions AVerification/CalibrationSystem Leak Check Every other sampling event Visual and Auditory Inspection FR Multi-point Verification/Calibration 

Quarterly – (Annually at 

minimum); 

After receipt, upon 

installation, after repair or 

motor maintenance, or failure 

of 1-point check, when action 

level is triggered 

5 points spanning range of 1.13 actual m3/min + 10% 

R value = >0.99 

Pa

One-point Flow Rate Verification Every other sampling event 

(Quarterly in Part 58)

ADEQ Action Level - + 5% from transfer standard

Failure Level is +7% from transfer standard

A

Part 58 

Filter Checks Verified for Each Sample Visual Defect Check (unexposed) all filters - Initial backlight inspection - no pinholes or 

imperfections 

- Visual inspection prior to shipping to analytical lab 

Pa

Sampling Instrument Verified prior to start of 

sampling 

See Pb QAPP in Element B.6 

* - Based on sampler air velocity being between 20 to 35 cm/sec 

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Criteria Frequency Acceptable Range Cita

OPERATIONAL EVALUATIONS TABLE Pb in TSP 

PrecisionCollocated Samples 15% of each method code in 

PQAO 

Frequency - every sampling 

event (may be reduce to 1/12 

days) 

CV < 20% of samples> 0.02 μg/m3 Part 

Audits Semi Annual Flow Rate Audit Quarterly – (Semi-annually at 

minimum); near beginning of 

program; upon instrument 

change-out; following 

corrective action; and prior to 

sampler removal 

 15% of audit standard and design value Part 58, App 

Lead Strip Analysis 6 strips/quarter 

2/conc. ranges 

+10% difference Part 

Blanks Field Filter Blank 10% < 40 μg/filter Sampler Run Information (collected each run)Sample ID Record and verify filter ID PaVerify Run Conditions Based on flow verification during or after sampling PaTime, Flow, Temperature and Pressure 

Record and verify readings from the instrument Pa

Pa

Handling Filter handled only from the outer edges and folded in half 

lengthwise 

PaPa

Verification/Calibration Flow Rate Transfer Std. (Orifice) 1/yr Connects without leaks 

Approximate range: 1.0 – 1.8 m3/min (~35 – 66 CFM) 

Resolution 0.02 m3/min 

 +2% reproducibility 

Maximum pressure drop at 1.7 std m3/min; 50 cm H20 

PaPaPa

Field Thermometer 1/yr Range -40o C to 50o C 

2o C resolution 

Pa

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Criteria Frequency Acceptable Range Cita

Field Barometer 1/yr Range 500 to 800 mm Hg

5 mm Hg resolution 

Pa

Filter (Specs for Manufacturer) (Report to EPA and assess impact on data quality if noted.) 

Pa

Size all filters 20.3+0.2 cm x 25.4 +0.2 cm ParMaterial all filters Glass fiber Par

Par

Collection Efficiency all filters 99 % minimum ParPressure Drop Range all filters 42 – 54 mm Hg at 1.5 std m3/min ParpH all filters 6-10 ParIntegrity (may not need for Pb) all filters 2.4 mg maximum weight loss ParPin holes all filters none ParTear Strength all filters 500 g minimum for 20 mm strip ParBrittleness all filters No cracks or material separations after single lengthwise crease Part Lead Content all filters < 20 μg/filter ADEQ speci

than the NAA

flo

SYSTEMATIC CRITERIA - Pb in TSP

Data Completeness quarterly Rolling three -month mean (i.e., the 3-month data capture rate)

> 75% 

P

Filter Sample Recovery all filters Within 6 days of sampling Reporting Units all filters μg/m3 at local temperature and pressure. ParRounding Convention all filters Report data to 3 decimal places (data after 3 are truncated). ParDetection LimitICPMS Each analytical batch MDL of 0.00006 μg Pb/m3

PQL of 0.000018 μg Pb/m3

Sampler MaintenanceSampler hood & sampling chamber Before and after each 

sampling event 

Inspect/Clean 

Motor/housing gaskets Annually Replace Brushless blower motor Every 8 years Replace Control and pump box Monthly Clean 

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Criteria Frequency Acceptable Range Cita

Filter cassette holder & sample saver shield

Before and after each 

sampling event

Inspect/Clean 

Analytical StandardsReagents  Nitric acid (HNO3)  Hydrochloric acid (HCL) 

Each analytical batch ACS reagent grade Pa

 Pb nitrate (Pb(NO3)2) Each analytical batch ACS reagent grade PaVerification/CalibrationClock/timer Verification Every other sampling event +2 min/mo ParBiasPerformance Evaluation Program (PEP) 

Annually – 1 field audit 

Quarterly – 1 collocated filter 

sample 

95% CL Absolute bias 15% Part 

SD= standard deviation CV= coefficient of variation 
Attachment A 

Rationale for the Hayden Globe Highway Station Siting 
Rationale for Sitting ASARCO Hayden Pb at Globe Highway Site 

ASARCO Hayden Pb monitor: Rationale for sitting ASARCO Hayden Pb monitor at 

Globe Highway Station based on discussion 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 ASARCO 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 Chemical Mass Balance model concluded 

that 80% of the PM10 Pb came from process fugitive emissions within the smelter 

("Source Apportionment of Suspended Particles and Toxic Elements in Hayden, Arizona, 

Final Report", NEA Inc., April 15, 1987). Direct observation by ADEQ staff confirmed 

that particulate plume emanates principally from the smelter building itself, rather than 

from other sources such as ore handling facilities 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, the highest ground level concentrations 

from such a buoyant plume would not be expected to occur immediately adjacent to the 

facility. 

Because the bulk of SO2 emissions are also thought to be emitted as buoyant fugitives 

from the smelter building, 1970's monitoring of SO2 is relevant for Pb. (Since the stack is 

1,000 feet tall, SO2 impacts from stack emissions occur farther away and are diluted by 

the time stack plume reaches the ground.) At that time SO2 monitoring was conducted at 

twelve different monitor locations; Globe Highway Station was found to have the highest 

concentrations. Because of the similar emission characteristics of SO2 and Pb fugitives, 

this suggests Globe Highway may also have the highest concentrations for Pb. 

The ASARCO Hayden smelter is located in very 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 the facility, and mountains rising toward the 

north/northeast. The varied terrain causes complex 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 facility, and toward the south on the east of the 

facility. However, given the buoyancy of the smelter building fugitive plume, and the 

facility's elevated location, emissions typically 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 polluted air to reach the ground. The vertical 

mixing also causes the flow to be coupled with winds aloft, which generally flow toward 

the east. As was the case for SO2, these are the conditions expected to lead to high Pb 

concentrations and that also carry the plume 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 Siting 
Lead (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 specify that the lead monitor should be sited 

at the location of the highest ambient level taking into account the potential for 

population exposure. The results indicated that 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 ambient air quality impacts was 

conducted using AERMOD (User’s Guide for the AMS/EPA Regulatory Model – 

AERMOD, U.S. Environmental Protection Agency, Office of Air Quality 

Planning and Standards, Emissions, Monitoring, 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 fugitive emissions were not modeled since 

detailed source information is not available. Moreover, it is believed that the 

impacts from the fugitive emissions are limited 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 97 
4. Receptors: Modeling receptors were placed in locations in ambient air and no 

receptors were established within the process area of the facility (Figure 1). 

Moreover, receptors were not placed in the remote mountainous areas where there 

is no potential for population exposure. The following receptor grid density was 

used: 50 m spacing along the ambient area 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 indicated 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-year site specific meteorological data set was used. 

This data set, pre-processed by ADEQ, combines the surface observations from 

the FMMI facility site, the cloud cover data from the NWS Phoenix Airport 

(Surface ID 23183), and the upper air observations 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" format. 
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 Tower (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 average. To calculate the rolling 3-month 

averages, the monthly concentration output from AERMOD must be post 

processed by using LEADPOST. Since the 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 annual and monthly concentrations of lead is shown in Figure 

3 and Figure 4, respectively. For discussion purposes, the locations 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 the 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 northeast 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 site, 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 appeared to be supported by the PM10 monitoring data, 

which indicated that the PM10 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