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I

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX

PO0 75 Hawthorne Street

San Francisco, CA 941 05-3901

AUG 012013

Mr. Lewis Wallenmeyer, Director

Clark County Department ofAir Quality

4701 W. Russell Rd. Suite 200Las Vegas, Nev da 89118

Dear M’meyer:

i am wi4ing to transmit the findings from U.S. Environmental Protection Agency’s (EPA’s) 2012

Technical System Audit (TSA) ofthe Clark County Department ofAir Quality (DAQ) ambient air

monitoring program. This audit was performed in accordance with 40 CFR Part 58, Section 2.5, whichrequires that EPA conduct TSAs ofprimary quality assurance organizations every three years.

EPA reviewed DAQ’s ambient air monitoring program, including network management, fieldoperations, laboratory operations, quality assurance, and data management procedures. Generally, wefound that DAQ’s air monitoring program is robust and meets EPA requirements. As with any audit, thisTSA uncovered some program areas within the agency that can be improved. Your agency has been

very responsive to the audit findings and has already begun working, on corrective actions. The formal

corrective action response is due to EPA within 60 days ofreceipt ofthe final TSA report.

I want to thank you and your stafffor your full cooperation and participation during the audit. The

results ofthis audit significantly contribute to EPA’s overall understanding of ambient monitoring inClark County, Nevada.Please contact me if you have questions, or your staffmay contact Elfego Felix at (415) 947-4141 or

Meredith Kurpius at (415) 947-4534.

Sincerely,

Deborah JordanDirector, Air Division

Enclosure
Technical System Audit Report 

Clark County Department of Air Quality 

Ambient Air Monitoring Program 

July 26 – July 27, 2012 

Conducted by 

Air Quality Analysis Office Quality Assurance Office 

Air Division Management and Technical 

Services Division 

US EPA Region 9 

75 Hawthorne Street 

San Francisco, California 94105 

Final Report: July 2013 
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CONTENTS

GLOSSARY OF ACRONYMS -----------------------------------------------------------------3 

EXECUTIVE SUMMARY ----------------------------------------------------------------------4 

TSA ACTIVITIES --------------------------------------------------------------------------------6 

OVERVIEW OF AIR MONITORING PROGRAM--------------------------------------- 12 

FINDINGS --------------------------------------------------------------------------------------- 16 

APPENDIX A: Organizational Charts ------------------------------------------------------- 35 
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GLOSSARY OF ACRONYMS 

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

CAA........................... Clean Air Act 

CO........................................ Carbon Monoxide 

CFR...................................... Code of Federal Regulations 

DAQ........................... Department of Air Quality 

EMS............................ Electronic Management System 

LEADS......................... Leading Environmental Analysis and Display System 

NAAQS................................ National Ambient Air Quality Standard 

NCore.................................. National Core multipollutant monitoring stations 

NIST............................ National Institute for Standards and Technology 

NO2...................................... Nitrogen Dioxide 

NOy.............................. Total Reactive Nitrogen 

NRS........................... Nevada Revised Statutes 

NV............................... State of Nevada 

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

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

PM........................................ Particulate Matter 

PM2.5..................................... Particulate Matter 2.5 microns or less in aerodynamic diameter 

PM10...................................... Particulate Matter 10 microns or less in aerodynamic diameter 

PM10-2.5...........................Coarse Particulate Matter between 10 and 2.5 microns 

aerodynamic diameter 

PMspeciation........................Speciated Particulate Matter 

Pb.................................Lead 

POC..............................Parameter Occurrence Code 

PQAO................................... Primary Quality Assurance Organization 

QA........................................ Quality Assurance 

QAO..................................... Quality Assurance Officer 

QC........................................ Quality Control 

QAPP................................... Quality Assurance Project Plan 

QMP............................ Quality Management Plan 

SPM..................................... Special Purpose Monitor 

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

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

SO2....................................... Sulfur Dioxide 

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

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

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

EPA...................................... United States Environmental Protection Agency 
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EXECUTIVE SUMMARY 

This document is a report on the findings made by the U.S. Environmental Protection 

Agency (EPA) Region 9 while conducting a Technical Systems Audit (TSA) of the Clark County 

Department of Air Quality (DAQ) ambient air monitoring program. A TSA is an on-site review 

and inspection of a state or local ambient air monitoring program to assess its compliance with 

established regulations governing the collection, analysis, validation, and reporting of ambient 

air quality data. This TSA meets the requirements for EPA audits of monitoring organizations 

required by 40 CFR Part 58, Appendix A, Section 2.5. 

The TSA was conducted by EPA staff during the summer of 2012. An on-site visit to the 

DAQ Engineering Division, responsible for ambient air monitoring program operations, located 

in Las Vegas, NV, took place on July 26 – 27,2013. EPA interviewed management and staff to 

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

laboratory operations, data handling, and quality assurance (QA) and quality control (QC) 

procedures. EPA also inspected two of the monitoring sites operated by DAQ: J.D. Smith and 

Sunrise Acres. The site inspections consisted of an interview with the site operator, review of 

station and instrument logbooks, and an evaluation of station siting with respect to EPA 

requirements for probe siting (40 CFR 58, Appendix E). The laboratory inspection included a 

review of the Particulate Matter (PM) program for mass determinations. 

The TSA is one assessment EPA conducts to ensure data collected by state, local, and tribal 

agencies meet data quality objectives. Other assessments, such as network reviews and 

performance evaluations, are also used to evaluate the overall quality of ambient air monitoring 

data. These assessments enable agencies to identify and correct elements which may be 

adversely affecting the quality of ambient air data. The results of the TSA are summarized 

below. Findings and recommendations to address findings are discussed in further detail within 

the report. Specific corrective actions related to findings will be determined through negotiations 

between EPA and DAQ and documented in a corrective action plan (CAP) prepared by DAQ. 

EPA would like to thank all of DAQ staff and management for their support and 

cooperation throughout the audit. 

Program Strengths: 

EPA found that overall DAQ operates a robust ambient air monitoring program. Listed 

below are examples of program strengths observed over the course of the audit. 

1. There has been substantial progress on findings from the previous TSA. 

2. QA staff demonstrate a high level of technical expertise. 

3. There is a well developed system in place to access monitoring guidance electronically and 

remotely. 

4. The QC monitoring section shows evidence of a rigorous training program. 

5. Formal corrective actions are well documented. 

6. There is an extensive collection of well documented procedures for ambient air 

monitoring. 
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7. Regular site operator visits and routine inspections by the Monitoring Supervisor support 

an excellent preventive maintenance practice. 

8. The electronic data management system records and retrieves a variety of valuable 

monitoring information. 

9. Monitoring stations are well organized, maintained, and secure. 

10. Instrument repairs are made promptly and supported by a sufficient stock of monitoring 

supplies and equipment to minimize downtime. 

11. QC equipment is tracked and maintained within certification bounds. 

12. Weighing equipment used within the DAQ PM Laboratory is well maintained and within 

certification. 

Program Findings: 

While acknowledging the strengths of DAQ’s monitoring program, EPA identified several 

program elements that could be improved. The major findings discussed in this TSA, include: 

1. DAQ has not yet received full EPA approval on all Quality System documentation and 

some SOPs have not been completed. 

2. An assessment of maximum O3 concentration monitoring within Clark County is needed. 

3.Requests for SLAMS site terminations and relocations do not always include the 

appropriate analysis and evidence for EPA approval. 

4.PM2.5 data completeness criteria were not met at the Sunrise Acres site for the 3rd and 4th

Quarters of 2012. 

 

These findings and others are discussed in further detail in the Findings sections of this 

report. EPA expects that all findings will be addressed in a corrective action plan prepared by 

DAQ following the issuing of the final TSA report. The plan should have a schedule of 

completion that will occur as expeditiously as possible. 
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TSA ACTIVITIES 

On July 26 - 27, 2012, the EPA Air Quality Analysis Office and Quality Assurance 

Office conducted a TSA of DAQ’s ambient air monitoring program. This TSA reviews one 

aspect of DAQ’s program, collecting and analyzing ambient air quality data, which is the 

responsibility of the Engineering Division within DAQ. 

The TSA covered the following program areas: 

· General / Quality Management 

Program organization 

Facilities 

Independent quality assurance and quality control 

Planning documents (including QMP, QAPPs, General documentation policies 

Training 

Corrective action 

Quality improvement 

External performance audits 

· Network Management / Field Operations 

Network design 

Changes to the network since the last audit 

Proposed changes to the network 

Field support 

· Laboratory Operations: particulate matter 

Routine operations 

Quality control 

Laboratory preventive maintenance 

Laboratory record keeping 

Laboratory data acquisition and handling 

Specific pollutants: PM10, PM2.5 and Lead 

· Data and Data Management 

Data handling 

Software documentation 

Data validation and correction 

Data processing 

Internal reporting 

External reporting 

Additionally, EPA tracked supporting documentation for several data points entered into the Air 

Quality System (AQS) for the calendar years 2009-2012. Applicable annual monitoring network 

plans and an assessment for this time period were reviewed as part of the audit. A review of the 

progress of findings from EPA’s previous TSA of DAQ (2009) was also conducted. 

Elfego Felix of the EPA Region 9 Air Division Air Quality Analysis Office conducted 

the TSA. Matthew Lakin, Manager of the Air Quality Analysis Office, and Eugenia 

McNaughton, Manager of the Quality Assurance Office, attended the introductory meeting by 

teleconference. 
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Participating DAQ management and staff included: 

· Lewis Wallenmeyer, Director 

· Tina Gingras, Assistant Director 

· Mike Sword, Engineering Manager 

· Yousaf Hameed, Monitoring Supervisor 

· Brandon Cunningham, Air Quality Supervisor 

· Mickey Palmer, Sr. Monitoring Tech 

· Pravin Perna, Monitoring Tech. II 

· Mickey Turner, Sr. Monitoring Tech 

· Phillip Wiker, Sr. Monitoring Tech 

· Joseph Biebrich, Monitoring Tech. II 

· Dave Dickens, Monitoring Tech. II 

· Matthew Nelson, Monitoring Tech. II 

· Kris Simonian, Monitoring Tech. II 

This report is divided into the following sections: 

· Executive Summary – describes the purpose of the TSA and a summary of the program 

strengths and findings. 

· TSA Activities – outlines the scope of this TSA, a progress update on findings from the 

previous TSA, and a description of activities that were covered during this TSA. 

· Overview of Air Monitoring Program – describes the DAQ Air Monitoring Program. 

· Findings – describes the details associated with each finding. 

· Appendices – includes additional reference information. 

The findings in this report are organized by program area and generally listed in priority order 

within each program area. Recommended actions to resolve findings are provided for each 

finding to give some indication of EPA’s expectations as to how these may be addressed. Should 

DAQ have other approaches or alternatives to address the concerns identified, EPA will consider 

them, provided the corrective action adequately addresses the finding. 

Progress on Findings from Previous TSA (2009)

DAQ has been very responsive in following through on corrective actions from the 2009 

TSA, providing regular updates to the CAP, and making substantial progress on a majority of the 

findings. DAQ’s commitment to improving monitoring operations has been clear. Listed below 

are specific instances of progress made on 2009 TSA findings. DAQ has: 

· Obtained conditional EPA approval for a Quality Management Plan (QMP) covering 

ambient air monitoring operations. 

· Created a QA supervisory position within the Engineering Division that provides for 

appropriate independence between the quality system and environmental data generation. 

· Introduced a three-year equipment replacement program that phases out older, less reliable 

instruments. 
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· Commenced independent inspections of electricity and structure at monitoring shelters and 

allocated funds for the replacement of inadequate shelters. 

· Improved station logbooks by developing a template for standard entries and requiring 

initial or last name sign off for each entry logged. 

· Improved PM laboratory operations by establishing procedures to: 

a. Document filter weighing times. 

b. Monitor shelter stability conditions for relative humidity and temperature prior to 

weighing samples. 

c. Track dates of filter receipt and disposal. 

Network Management

EPA interviewed the Engineering Manager and Monitoring Supervisor about several 

network management topics. EPA reviewed the most recent Annual Network Plan and sent DAQ 

an approval letter on February 28, 2013. DAQ also submitted its first five-year Annual Network 

Assessment in 2010, as required by 40 CFR 58.10. The assessment has been used as a tool to 

inform DAQ’s network management decisions. The air monitoring network within Clark County 

meets or exceeds the requirements for the minimum number of monitoring sites designated as 

SLAMS for all of the criteria pollutants. 

Suggestions for improvements in network management are included in the findings 

section. 

 

Field Operations

EPA interviewed the Monitoring Supervisor, field staff, and instrument lab staff 

regarding field operations. Monitoring stations visited as part of the audit included the J.D. Smith 

and Sunrise Acres sites, where field technicians Dave Dickens and Joseph Biebrich were 

interviewed. Evaluation of sites included an inspection of 40 CFR 58 Appendix E siting criteria, 

examination of logbooks, and a review of QC checks occurring at the monitoring sites. Mickey 

Turner, who is responsible for the instrument lab in support of field operations, was the primary 

staff interviewed. 

EPA found that the instrument lab and monitoring sites visited were well organized, 

maintained, and operated. Instrument manuals, SOPs, and QA/QC documentation was generally 

readily available. Staff demonstrated a thorough knowledge of the monitoring equipment and 

sites for which they were responsible. DAQ’s system for electronic station logbooks is an agency 

strength. The Monitoring Supervisor routinely visits, evaluates, and provides feedback to his 

monitoring site operators. Each site is visited by the supervisor several times per quarter. This is 

an excellent preventive maintenance practice. 

The monitoring section displayed evidence of a rigorous training program. Rotation of 

regular station assignments and cross-training by senior technicians allow for sharing of 

expertise with all monitoring staff. Whenever possible, the group has also taken advantage of 

opportunities to send staff to external monitoring conferences and trainings. 
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Suggestions for improvements in field operations are included in the findings section. 

Particulate Matter Laboratory

EPA visited the particulate matter (gravimetric) laboratory and interviewed the back-up 

laboratory technician, Kris Simonian as the lead technician, Matthew Nelson, was not available. 

The particulate matter laboratory was well organized and maintained. All equipment in 

use at the laboratory was found to be within expiration. A copy of the PM laboratory operations 

SOP was not found at the laboratory at the time of the visit. 

Suggestions for improvements in the PM laboratory are included in the findings section. 

Data Management

EPA interviewed Pravin Pema, the primary staff person in charge of data management 

and validation activities for all pollutants monitored by DAQ. During monitoring site and 

laboratory visits, field and laboratory staff described their roles in the early data validation 

process. 

The primary data management staff member displayed a wealth of knowledge relating to 

data management activities and was very responsive to EPA requests for tracking of data points. 

Several data points tracked during the audit could have had more specific qualifier codes and 

DAQ may also benefit from better cross training of the data validator’s activities. Overall, EPA 

found that DAQ’s data management and validation program is robust. 

Suggestions for improvements in Data Management are included in the findings section. 

Quality Assurance/Quality Control

EPA reviewed QA/QC documents and spoke with a variety of Engineering Division staff, 

both supervisors and the Engineering Manager, concerning DAQ’s ambient air monitoring 

QA/QC activities. Focused sessions on QA independence were also held with the QA Officer 

Mickey Palmer. 

It was noted that, since the time of the previous TSA (2009), DAQ has worked to achieve 

appropriate independent QA oversight of data generation activities by incorporating a formal QA 

management function into the process. Although still in need of full approval of all quality 

system documentation, since the time of the 2012 audit, DAQ has taken a substantial step toward 

full independence by obtaining conditional approval for the Quality Management Plan (QMP). 

DAQ may also benefit from better cross training of the QA Officer’s activities. 

During the audit, EPA was provided with an example of a formal corrective action taken 

that was documented in a Corrective Action Request Form developed by DAQ. The formal 
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action described demonstrated commitment to prompt, meaningful, and well documented 

corrective action (see figure below). 

Example of DAQ Corrective Action form 

Another mechanism that DAQ utilizes to ensure adequate QA/QC is the development of 

a comprehensive set of monitoring operation standard operation procedures (SOPs). Examples of 

well documented SOPs include procedures for: 

· Monitoring station visits. 

· Station monitoring equipment operation. 

· Residence Time and Line Changes. 

· PM lab operations. 

· Gas QA Field audits. 

· Zero Air generation. 

· Data Validation. 
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· Instrument Acceptance Testing. 

Suggestions for improvements in QA/QC are included in the findings section. 
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OVERVIEW OF AIR MONITORING PROGRAM 

General Program

Federal and state laws relating to achieving and maintaining clean air, as required by the 

Clean Air Act (CAA), are in place throughout the country to protect public health. The Clark 

County DAQ is the government agency with delegated authority and responsibility for collecting 

ambient air quality data pursuant to the Clean Air Act of 1977 and the Clean Air Act 

Amendments of 1990. 

The Governor of Nevada gave authority for Air Quality Matters in Clark County to the 

Clark County Board of Commissioners in 2001. This is reflected in the Nevada Revised Statutes 

(NRS) 445B.500, which delegate significant air pollution control authority to Nevada counties 

with populations greater than 400,000. The Clark County Board of Commissioners created an 

Air Quality Management Board to govern air quality programs and DAQ to implement air 

quality programs, including ambient air quality monitoring. Prior to 2001, ambient air quality 

monitoring was implemented by the Clark County Health District, a Special District defined 

under NRS. 

DAQ currently has 13 active monitoring stations for criteria pollutants. The criteria 

pollutants measured include: 

· Carbon Monoxide (CO). 

· Lead (Pb). 

· Nitrogen Dioxide (NO2). 

· O3. 

· Particulate Matter (PM10 and PM2.5). 

· Sulfur Dioxide (SO2). 

In addition to the criteria pollutants monitored, DAQ also operates a National Core multipollutant network (NCore) site at the Jerome Mack site that measures a series of additional noncriteria pollutants including Total Reactive Nitrogen (NOy), Coarse Particulate Matter (PM10-2.5), 

and Speciated Particulate Matter (PMspeciation). 

DAQ is headed by a Director and an Assistant Director. Ambient air monitoring is 

conducted by the Engineering Division, which is lead by an Engineering Manager, who reports 

to the Assistant Director. The Engineering staff consists of a Monitoring Section and a 

QA/Grants Section, each headed by a Supervisor who report directly to the Engineering 

Manager. A Senior Office Specialist also reports directly to the Engineering Manager. At the 

time of the audit, the Monitoring Supervisor was overseeing six Monitoring Technicians and a 

Management Analyst, while the QA/Grants Supervisor had oversight of a Quality Assurance 

Officer and Data Management Specialist. Since the audit, DAQ’s Assistant Director and the 

Engineering Division’s QA/Grants Supervisory and Management Analyst position have been 

vacant. DAQ has approved funds to hire for the three vacancies and anticipates filling the three 

positions in the near future. 
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Network Management

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

of 13 stations. Several of these stations host basic meteorology parameters (i.e., wind 

speed/direction, relative humidity, and temperature). The Jerome Mack NCore site is the only 

one that maintains equipment to measure a series of required meteorology parameters. A 

complete, updated description of the agency’s network is provided annually in the Ambient Air 

Monitoring Network Plan. The following table summarizes the SLAMS air monitoring sites in 

Clark County by the pollutant monitored and the year monitoring began at the site. 

SITE NAME 

(year established) 

POLLUTANT 

CO SO2 NO2 NOy NO O3 PM10 PM2.5 PM2.5 

continuous 

PM10-2.5 PM2.5

speciation 

Pb 

Apex(1998) S 

Boulder City 

(1998) 

X X 

Green Valley 

(1998) 

X X 

J.D. Smith 

(1998) 

X X X X X 

Jean (1995) X X X X 

Jerome Mack 

(2010) 

T T T T X X X X X X X 

Joe Neal 

(2000) 

X X X 

Mesquite 

(2001) 

S 

Palo Verde 

(1998) 

X X 

Paul Meyer 

(1998) 

X X 

Sunrise Acres 

(1996) 

X X X X 

Walter Johnson 

(1995) 

X 

Winterwood 

(1979) 

X X 

S = Seasonal O3 monitor approved by EPA to monitor April 1 – September 30. 

T = Trace monitor required as part of NCore network. 

In addition to SLAMS, the DAQ Engineering Division has in the past conducted monitoring for 

a series of special O3 studies, pollen, and visibility. 

 

Field Operations

Field operations for ambient monitoring are performed by staff who report to the 

Monitoring Supervisor. Staff are assigned to monitoring stations and are responsible for all 

criteria pollutant operations at their respective stations. One Senior Technician is assigned the 

responsibility for calibration of field standards for gaseous pollutants and flow. 
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Particulate Matter Laboratory Operations

DAQ has a PM2.5 laboratory located in the basement of the main Government Center in 

Clark County. The primary responsibility of the laboratory is the handling of PM filters, which 

includes preparation, weighing, tracking, and storage. 

Data Management

Data management includes data collection, data validation, and a data management 

system. Data management at DAQ follows two separate tracks: one for continuous (i.e., non-PM 

laboratory) data and one for PM laboratory data. 

The QA/Grants section is responsible for managing ambient monitoring data and 

reporting to the EPA AQS database. 

Air quality data measured by the continuous analyzers at the field stations are stored in data 

loggers and on DAQ servers. Each station is polled every fifteen minutes and the data are 

transmitted directly to the central server in the IT facility. The first review of the data is 

performed by the station operators. 

Data from continuous analyzers are received and processed using an IPS MeteoStar data 

management system that began operations in 2008. The system provides real-time as well as 

historical data on the DAQ internet portal. Several of the monitoring staff are involved in 

evaluating/validating the gaseous measurement and quality control data provided by the Leading 

Environmental Analysis and Display System (LEADS) Electronic Management System (EMS). 

The LEADS EMS prepares the validated data for submittal to the AQS system. 

DAQ laboratory-generated data includes 24-hour PM2.5 data. Laboratory generated data are 

processed using spreadsheets and validated and submitted separately to AQS from the LEADS 

EMS. 

 

DAQ submits all required data to the AQS database, including concentrations for all 

criteria pollutants, supporting precision and accuracy information, and data from the network. 

Data submitted to AQS are annually certified by DAQ. 

Quality Control and Quality Assurance

Quality management is the system put in place that oversees quality assurance, quality 

control, and quality improvement activities. EPA requires that ambient air monitoring agencies 

have a quality management system that conforms to 40 CFR Part 50 Appendix A and the EPA 

quality policy (EPA Order CIO 2105.0). Additionally, EPA grant regulations specifically 

require each grantee to provide for QA activities (40 CFR Part 31.45). 

Specifically, 40 CFR Part 50 Appendix A Section 2 requires that each ambient air 

monitoring PQAO conforms to certain quality management practices. These include: 
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· Having a documented quality system that meets EPA requirements for QMPs and QAPPs. 

· Having a quality management function that is independent of air monitoring operations. 

· Developing or adopting DQOs, or equivalent systematic planning procedures, for all 

monitoring programs. 

· Participating in National Performance Evaluation Programs, which consist of performance 

audits used to independently determine program adequacy, national monitoring network 

performance, and national consistency. 

· Having Technical Systems Audits performed by EPA Regional Offices at a frequency of 

every three years or less. 

· Using certified reference materials to standardize monitoring equipment. 

EPA views the application of these quality management system components as integral to 

monitoring programs. 

DAQ has a defined quality management system, which includes a quality management 

plan and oversight by an independent QA/Grants section. The Quality Assurance Officer (QAO) 

within the QA/Grants section is responsible for conducting the required gaseous pollutant audits 

and PM flow audits. 
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FINDINGS 

Summary Table

No. Program Area Finding

1 General (Major) DAQ has not yet received full EPA approval on all Quality 

System documentation and some SOPs have not been completed.

2 General (Major) An assessment of maximum O3 concentration monitoring within 

Clark County is needed. 

3 General A PM lab SOP was not readily available for reference at the time 

of the audit. 

4 

Network Management (Major) 

Requests for SLAMS site terminations and relocations do not 

always include the appropriate analysis and evidence for EPA 

approval. 

5 Field Operations Standardized station logbook entries are not always 

appropriately used. 

6 Field Operations Power and communications issues at the Jean and Sunrise Acres 

sites respectively have not been resolved. 

7 Field Operations Instrument logbooks were not available during monitoring 

station visits. 

8 Data Management (Major) PM2.5 data completeness criteria were not met at the Sunrise 

Acres site for the 3rd and 4th Quarters of 2012. 

9 Data Management Appropriate qualifier codes are not always applied to data in 

AQS. 

10 Quality Assurance/Quality 

Control 

QA performance evaluation equipment certification was found to 

have expired or be without a recommended recertification date. 

Evidence for verification of zero air was not found. 

11 Quality Assurance/Quality 

Control 

QA Performance Evaluation audit results are not always 

effectively communicated to the appropriate staff. 

12 Quality Assurance/Quality 

Control 

A formalized performance evaluation program for required 

meteorological (MET) equipment is not in place. 
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Finding # 1 

Agency: DAQ 

Date of Audit: Summer 2012 

Program Area(s): General (Major) 

Finding: 

DAQ has not yet received full EPA approval on all Quality System documentation and some 

SOPs have not been completed. 

Description: 

A similar finding was included (Finding A2) in the 2009 TSA. DAQ submitted a revised QMP 

shortly after the TSA visit and received conditional approval from EPA in December 2012. An 

approved QAPP is still needed to define DAQ’s criteria for agency acceptable audit results and 

comprehensive corrective action. It should also include or reference complete monitoring 

operation SOPs. 

Overall, DAQ maintains a nearly complete and readily accessible library of SOPs. A few 

procedural gaps were identified at the time of the audit, including missing SOPs for: 

· Zero air verification procedures followed by the QA officer. 

· Data review expected during site operator visits. 

· Operation and maintenance of NCore equipment. 

· Audits of MET equipment (see Finding 12). 

· Use of station logbook template language. 

DAQ should ensure that SOPs are regularly updated and developed for practical use by the 

intended users. 

Authority: 

40 CFR Part 58, Appendix A, Section 2 

 

References: 

QA Handbook for Air Pollution Measurement Systems, Vol II: Ambient Air Quality Monitoring 

Program, Appendix C, EPA–454/B-08-003, December 2008. 

EPA Requirements for Quality Assurance Project Plans, EPA/240/B-01/003, March 2001. 

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

Guidance for Preparing Standard Operating Procedures, EPA/600/B-07/001, April 2007. 

Recommendation to Address Finding: 

DAQ should achieve full approval of all Quality System documentation and update and complete 

cited SOPs. 
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Finding # 2 

Agency: DAQ 

Date of Audit: Summer 2012 

Program Area(s): General (Major) 

Finding: 

An assessment of maximum O3 concentration monitoring within Clark County is needed. 

Description: 

Summer studies of O3 monitoring at the Spring Mountain Youth Camp (SMYC) site (operating 

between 2010-2012) revealed higher 8-hour design value estimate concentrations (by 

approximately 5ppb) than the currently listed maximum O3 SLAMS monitor at the Joe Neal site. 

SMYC was the only summer study site (of several that were in operation between 2010-2012) to 

operate for three consecutive years and record higher design value estimates compared to 

maximum concentration at the Joe Neal SLAMS site in the Las Vegas Valley. 

O3 at the SMYC site was measured using FEM instruments. FEM instruments are those that have 

been approved by EPA as appropriate for NAAQS comparison. Due to the site’s high elevation 

(~8400 ft), operational boundaries specified by the FEM instrument designation may not have 

been within range. 

Due to its special purpose nature, the SMYC summer study site was not set up to meet the 

quality assurance criteria of 40 CFR 58 Appendix A. Accordingly, DAQ excluded summer O3

study seasonal monitors from their Annual Data Certification package submitted for 2011 

calendar year data. Siting criteria of 40 CFR 58 Appendix E was also not adhered to for the 

SMYC site. 

The need for an assessment of maximum O3 concentration monitoring within Clark County is 

also highlighted in EPA’s review of DAQ’s Annual Network Plan Report, June 2012. DAQ and 

EPA continue to work together to explore appropriate options to address the issue of maximum 

O3 concentration monitoring within Clark County. 

Authority: 

40 CFR Part 58, Appendix D, Section 4.1 

References: 

Guideline on Ozone Monitoring Site Selection, EPA-454/R-98-002, August 1998. 

Recommendation to Address Finding: 

DAQ should continue to work with EPA to ensure appropriate action is taken to capture 

maximum ambient O3 concentrations within the Las Vegas-Paradise Metropolitan Statistical 

Area (MSA). 
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Finding # 3 

Agency: DAQ 

Date of Audit: Summer 2012 

Program Area(s): General 

Finding: 

A PM lab SOP was not readily available for reference at the time of the audit. 

Description: 

The PM lab back-up analyst was not familiar with certain aspects of the program. Some of the 

audit questions could have been addressed by referencing a PM lab SOP, but a copy of the SOP 

was not available at the time of the audit. 

Authority: 

N/A 

References: 

Guidance for Developing a Training Program for Quality Systems, EPA/240/B-00/004, 

December 2000. 

QA Handbook for Air Pollution Measurement Systems, Vol II: Ambient Air Quality Monitoring 

Program, Section 4, EPA–454/B-08-003, December 2008. 

Recommendation to Address Finding: 

Copies of all applicable SOPs should be made available for reference. 
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Finding # 4 

Agency: DAQ 

Date of Audit: Summer 2012 

Program Area(s): Network Management (Major) 

Finding: 

Requests for SLAMS site terminations and relocations do not always include the appropriate 

analysis and evidence for EPA approval. 

Description: 

Per 40 CFR 58.14, monitoring agencies are required to obtain EPA approval for modifications to 

SLAMS monitors. Due to budget constraints, in 2010 DAQ reduced the SLAMS network. DAQ 

took appropriate measures to notify EPA of the terminations and relocations both informally via 

email notification as well as formally through the Annual Monitoring Network Plan. The process 

for approval, however, was delayed as insufficient information was provided to show how 

systems modification criteria of 40 CFR 58.14 have been met. 

In order for EPA to proceed with approval for SLAMS system modifications, system 

modification requests should be accompanied by supporting analysis and/or other evidence 

demonstrating how conditions of 40 CFR 58.14 are being met. Since 2010, DAQ and EPA have 

been working to improve the system modification process. 

Authority: 

40 CFR Part 58.14 

References: 

Ambient Air Monitoring Network Assessment Guidance: Analytical Techniques for Technical 

Assessments of Ambient Air Monitoring Networks, Section 4, EPA-454/D-07-001, February 

2007. 

Recommendation to Address Finding: 

DAQ should ensure that all proposals for termination or relocation of SLAMS monitors include 

sufficient information to demonstrate that proposed site modifications meet criteria of 40 CFR 

58.14. 
Finding # 5 

Agency: DAQ 

Date of Audit: Summer 2012

Program Area(s): Field Operations

Finding: 

Standardized station logbook entries are not always appropriately used.

Description: 

DAQ has made significant strides in improving station logbook entries since 

including more complete documentation of QA performance evaluation at a site and 

development of template language for site visit entries.

improve station logbook entries by including

(see Finding 11), and providing training on proper use of template language for site visit entries.

Recent efforts to make the station logbook entry system

template language found in station entries

Authority: 

N/A 

References: 

Guidance for Developing a Training Program for Quality Systems, 

December 2000. 

Guidance for Preparing Standard Operating Procedures

Recommendation to Address Finding:

DAQ should ensure that station operators are properly trained to fill out template language for 

standardized station logbook entries.

be documented. 

21

Field Operations

Standardized station logbook entries are not always appropriately used.

DAQ has made significant strides in improving station logbook entries since the 2009 TSA, 

documentation of QA performance evaluation at a site and 

development of template language for site visit entries. In a few instances, DAQ may further 

including reporting of QA performance evaluation results 

training on proper use of template language for site visit entries.

Recent efforts to make the station logbook entry system more consistent were observed in the 

template language found in station entries (see below). 

Guidance for Developing a Training Program for Quality Systems, EPA/240/B-00/004

Standard Operating Procedures, EPA/600/B-07/001, April 2007.

Recommendation to Address Finding:

DAQ should ensure that station operators are properly trained to fill out template language for 

Procedures for proper use of the template language should 

2009 TSA, 

further 

QA performance evaluation results 

training on proper use of template language for site visit entries.

more consistent were observed in the 

00/004, 

, April 2007.

DAQ should ensure that station operators are properly trained to fill out template language for 

se of the template language should 
22

Finding # 6 

Agency: DAQ 

Date of Audit: Summer 2012 

Program Area(s): Field Operations 

Finding: 

Power and communications issues at the Jean and Sunrise Acres sites respectively have not been 

resolved. 

Description: 

During the on-site TSA visit, DAQ highlighted power issues at the Jean site and communications 

issues at the Sunrise Acres site. DAQ indicated that the Jean site has experienced ongoing power 

issues which have correlated at times with missed PM2.5 sample runs (see related Finding 8). At 

Sunrise Acres, there has been limited capability to access the agency’s Virtual Private Network 

(VPN). At the time of the TSA visit, the site operator was unable to log onto DAQ’s network to 

access SOPs and other site information remotely. 

Authority: 

40 CFR Part 50, Appendix N 

References: 

N/A 

Recommendation to Address Finding: 

DAQ should take the steps necessary to identify and resolve the root cause of power and 

communication failures at the Jean and Sunrise Acres sites respectively. 
23

Finding # 7 

Agency: DAQ 

Date of Audit: Summer 2012 

Program Area(s): Field Operations 

Finding: 

Instrument logbooks were not available during monitoring station visits. 

Description: 

Instrument logbooks are important record keeping tools used by agencies to document and 

understand the performance history of an instrument. DAQ has historically kept a logbook that 

travelled with each instrument. Prior to the on-site TSA visit, the instrument logbooks were 

removed from all sites due to involvement in legal challenges. The removal of logbooks was not 

anticipated and therefore regular monitoring operations underwent some disruption. In a followup conversation during September of 2012, DAQ indicated that a new electronic instrument 

logbook system was anticipated to be in place by the end of 2012. 

Authority: 

N/A 

References: 

QA Handbook for Air Pollution Measurement Systems, Vol II: Ambient Air Quality Monitoring 

Program, Section 5 & 11, EPA–454/B-08-003, December 2008. 

Recommendation to Address Finding: 

DAQ should ensure that an instrument logbook system is promptly developed so that monitoring 

operations are minimally disrupted. 
24

Finding # 8 

Agency: DAQ 

Date of Audit: Summer 2012 

Program Area(s): Data Management (Major) 

Finding: 

PM2.5 data completeness criteria were not met at the Sunrise Acres site for the 3rd and 4th

Quarters of 2012. 

Description: 

The Jean and Sunrise Acres sites each host FRM PM2.5 samplers that DAQ uses for NAAQS 

compliance objectives. These FRM samplers constitute two of the three operated by DAQ. 

Continuous PM2.5, O3, PM10, and CO are other parameters monitored at the two sites. 

DAQ did not meet the 75% PM2.5 completeness criteria at the Sunrise Acres primary and 

collocated monitors for the 3rd Quarter (July-September) of 2012. The collocated monitor (POC 

2) did not meet completeness for the 4th Quarter (October-December). In December of 2012, 

DAQ reported these completeness issues to EPA and indicated data loss was due to a problem 

with the way the instrument vertically and horizontally shuttled cassettes. 

DAQ also provided logbook entries for the Jean site dating back to 2008 indicating a probable 

correlation between electrical reliability issues and missed PM2.5 sample runs (see related 

Finding 6). 

In light of NAAQS planning actions that are forthcoming for 2013-2014, it will be especially 

important for agencies to meet completeness requirements for PM2.5. 

Authority: 

40 CFR Part 50, Appendix N 

References: 

N/A 

Recommendation to Address Finding: 

DAQ should take the steps necessary to minimize PM2.5 data loss at the Sunrise Acres and Jean 

sites and ensure completeness is met for each quarter at all sites. 
25

Finding # 9 

Agency: DAQ 

Date of Audit: Summer 2012 

Program Area(s): Data Management 

Finding: 

Appropriate qualifier codes are not always applied to data in AQS. 

Description: 

It is important to ensure that data flagged in AQS has qualifier codes that most accurately 

represent the situation. The users of the data, including EPA, researchers, and the general public 

expect that reported data are accurate. Although DAQ typically does a robust job of ensuring that 

entries to the AQS database are accurate, a few observations are described below as areas for 

improvement. 

· For DAQ data collected from 2009 to 2011, EPA found a total of 185 flags within the 

Request for Exceptional Event Exclusion (REQEXC) qualifier type. Of this total, 160 

were given the qualifier code RL described in AQS as “Other.” On June 22, 2010, several 

instances of O3 data were flagged at the J.D. Smith, Joe Neal, and Walter Johnson sites 

with the RL code. DAQ noted that the RL flag is most commonly applied when the cause 

of an exceedance is not clear and that the REQEXC type qualifier is applied to all the 

hours that lead to an exceedance of the standard. Follow-up conducted shortly after the 

audit revealed that DAQ’s Planning section concluded the events of June 22, 2010 were 

due to smoke intrusion into Las Vegas from a wildfire originating outside of Clark 

County. As of an AQS data pull done on March 27, 2013, the RL “Other” code remained 

in AQS for the events of June 22, 2010. 

· On June 18, 2012 data generated at the Sunrise Acres CO monitor was flagged and given a 

miscellaneous void null code (i.e. AM flag). Upon review of the station logbook and 

notes from the data validator, EPA found that there had been a power failure. A power 

failure null code (i.e. AV flag) qualifier would have been more accurate in this case. 

Authority: 

40 CFR Part 58.16 

References: 

AQS Data Coding Manual, Version 2.38. Available online at: 

http://www.epa.gov/ttn/airs/airsaqs/manuals/AQS%20Data%20Coding%20Manual.pdf

Link to AQS Manuals and Guides: http://www.epa.gov/ttn/airs/airsaqs/manuals/

Recommendation to Address Finding: 

DAQ should ensure flags applied to AQS data are given the most appropriate qualifier codes 

whenever possible. It is recommended that qualifier codes be adjusted appropriately prior to 

annual data certification due by May 1 of each year. Rather than automatically applying the 

REQEXC qualifier type to hours leading up to an exceedance, it is recommended that more 

accurate criteria be established to distinguish exceptional events from other NAAQS 

exceedances. In general, EPA recommends avoiding use of “Miscellaneous” or “Other” flag 
26

codes whenever possible. 
27

Finding # 10 

Agency: DAQ 

Date of Audit: Summer 2012 

Program Area(s): QA/QC 

Finding: 

QA performance evaluation equipment certification was found to have expired or be without a 

recommended recertification date. Evidence for verification of zero air was not found. 

Description: 

Equipment (i.e. flow and gas standards, mass flow controller) used to conduct QA performance 

evaluations had labels or tags indicating expired certifications ranging from approximately 3-7 

months (relative to July 26, 2012 TSA visit date). Although it was mentioned that zero air used 

during QA performance evaluation was checked against the zero air at the monitoring sites, 

documentation showing these verification was not found. 

The tetraCal flow standard (see below) did not specify a recalibration date. 
28

The SO2 gas cylinder pictured below expired January 15, 2012. 
29

The deltaCal flow standard pictured below expired March 10, 2012. 
30

The Mass Flow Controller standard pictured below expired April 6, 2012. 
31

Authority: 

40 CFR Part 58, Appendix A, Section 2.6 

40 CFR Part 50, Appendix J & L

References: 

N/A 

Recommendation to Address Finding: 

DAQ should ensure that all equipment used for QA performance evaluations specify expiration 

dates and be certified at the appropriate frequency. Evidence of zero air verification should be 

maintained. 
Finding # 11 

Agency: DAQ 

Date of Audit: Summer 2012

Program Area(s): QA/QC

Finding: 

QA performance evaluation audit results are not always effectively communicated to the 

appropriate staff. 

Description: 

A similar finding was included as Finding F1 from the 2009 TSA. 

It is particularly important for failing audit results to be formally and promptly communicated

writing to staff for appropriate action. Staff 

Supervisor, and Monitoring Supervisor

effective communication, particularly of failing audits, has 

example, a site technician mentioned an instance of a failed URG carbon sampler at the Jerome 

Mack NCore site that should have been communicated in writing to expedite resolution. 

noted that QA performance evaluations are noted in the LEADS station logbook (see picture 

below). An indication of PASS/FAIL 

In a March 2013 follow-up conversation with the QA auditor, it was noted that in early 2013 

DAQ developed a formalized electronic notification system to communicate failing audits to 

appropriate staff. No audit failures had occurred to date to test the sys

Authority: 

40 CFR Part 58, Appendix A, Section 3

32

Summer 2012

audit results are not always effectively communicated to the 

A similar finding was included as Finding F1 from the 2009 TSA. 

t is particularly important for failing audit results to be formally and promptly communicated

to staff for appropriate action. Staff to be notified should include the Data Validator, QA 

Supervisor. The QA auditor maintains audit results, however

effective communication, particularly of failing audits, has been lacking in the past. As an 

mentioned an instance of a failed URG carbon sampler at the Jerome 

Mack NCore site that should have been communicated in writing to expedite resolution. 

noted that QA performance evaluations are noted in the LEADS station logbook (see picture 

PASS/FAIL associated with the electronic entry was not observed.

up conversation with the QA auditor, it was noted that in early 2013 

DAQ developed a formalized electronic notification system to communicate failing audits to 

had occurred to date to test the system. 

on 3

audit results are not always effectively communicated to the 

t is particularly important for failing audit results to be formally and promptly communicated in 

include the Data Validator, QA 

The QA auditor maintains audit results, however, 

in the past. As an 

mentioned an instance of a failed URG carbon sampler at the Jerome 

Mack NCore site that should have been communicated in writing to expedite resolution. It was 

noted that QA performance evaluations are noted in the LEADS station logbook (see picture 

the electronic entry was not observed.

up conversation with the QA auditor, it was noted that in early 2013 

DAQ developed a formalized electronic notification system to communicate failing audits to 
33

References: 

QA Handbook for Air Pollution Measurement Systems, Vol II: Ambient Air Quality Monitoring 

Program, Section 16 & Appendix I, EPA–454/B-08-003, December 2008. 

Recommendation to Address Finding: 

DAQ should ensure that the formal system for communicating failed audits is properly 

implemented. It is also recommended that a PASS/FAIL note be incorporated into LEADS 

station logbook entries each time a QA performance evaluation is conducted at a site. 
34

Finding # 12 

Agency: DAQ 

Date of Audit: Summer 2012 

Program Area(s): QA/QC 

Finding: 

A formalized performance evaluation program for required meteorological (MET) equipment is 

not in place. 

 

Description: 

In 2011, DAQ began operation of the Jerome Mack NCore site that requires the operation of 

MET parameters. Since generation of this MET data is required by regulation, these parameters 

are subject to quality assurance measures described in 40 CFR 58, Appendix A. At the time of 

the audit, DAQ did not have formalized procedures in place to audit the NCore site MET station. 

Authority: 

40 CFR Part 58, Appendix A, Section 1 

References: 

QA Handbook for Air Pollution Measurement Systems, Vol IV: Meteorological Measurements, 

Version 2.0, EPA–454/B-08-002, March 2008. 

Recommendation to Address Finding: 

DAQ should establish a formal audit schedule and system for required NCore MET parameters. 

EPA recommends that other MET stations operated by DAQ also be subject to periodic audit 

evaluations with priority given to those stations that may be used in regulatory planning 

demonstrations (e.g. exceptional event packages). 
APPENDIX A: Organizational Charts 
36