UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX

Ms. Charlene Albee, Director Washoe CountyHealth District Air QualityManagement Division 1001 E. 9th Street, Building B



### Reno;~2 Dearlbee: 75 Hawthorne Street San FrancAi1§•



### r~92o~(-3901

I am writing to transmit the findings from the U.S. Environmental Protection Agency's (EPA's) 2013 Technical System Audit (TSA) ofthe Washoe County Health District Air Quality Management Division (AQMD) ambient air monitoring program. This audit was performed in accordance with 40 CFR Part 58, Section 2.5, which requires that EPA conduct TSAs ofprimary quality assurance organizations every three years. EPA reviewed AQMD's ambient air monitoring program, including network management, field operations, laboratory operations, quality assurance, and data management procedures. Generally, we found that AQMD's air monitoring program is robust and meets EPA requirements. As with any audit, this TSA uncovered some program areas that can be improved byAQMD. 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 ofambient monitoring in Washoe County, Nevada. Please contact me ifyou have questions, or your staffmay contact Katherine Hoag at (415) 972-3970 or Meredith Kurpius at (415) 947-4534. Sincerely, 

# Mw
Deborah Jordan Director, Air Divi
Enclosure
cc: Dan Inouye, AQMD

Printed on RecycledPaper

# Technical System Audit Report Washoe County Health District Air Quality Management Division Ambient Air Monitoring Program (September 4-6, 2013)

Air Quality Analysis Office Air Division 

## Conducted by
Quality Assurance Office Management and Technical Services Division

US EPA Region 9 75 Hawthorne Street San Francisco, California 94105

Final Report: (August 2014)CONTENTS GLOSSARY OF ACRONYMS ....................................................................................................................................111 EXECUTIVE SUMMARY............................................................................................................................................. 1 TSA ACTIVITIES ..........................................................................................................................................................3 OVERVIEW OF AIR MONITORING PROGRAM...................................................................................................6 FINDINGS ................................................................................................................................................................... 10 APPENDIX A: SUMMARY OF FINDINGS ............................................................................................................ 32 APPENDIX B: GOOD PRACTICE RECOMMENDATIONS ............................................................................... 33 APPENDIX C: ORGANIZATIONAL CHART........................................................................................................ 34 APPENDIX D: STATUS OF FINDINGS FROM 9/16/2010 TSA ................................................................... 35

11GLOSSARY OF ACRONYMS AQMD.......................... Washoe County Health District Air QualityManagement Division AQS...................................... Air Quality System CO........................................ Carbon Monoxide CFR...................................... Code ofFederal Regulations EMC............................ Environmental Monitoring Company FEM............................. Federal Equivalent Method FRM............................ Federal Reference Method NAAQS................................ National Ambient Air Quality Standard NAMS.................................. National Air Monitoring Station NCore........................... National Core Multipollutant Monitoring Network NIST............................ National Institute for Standards and Technology N02............................. Nitrogen Dioxide NOx/NOy........................
..... Nitrogen Oxides OJ.......................................... Ozone Pb................................ Lead PM........................................ Particulate matter PM2.s..................................... Particulate matter 2.5 microns or less in aerodynamic diameter PM10...................................... Particulate matter 10 microns or less in aerodynamic diameter PM10-2.s ........................... Particulate matter, coarse: between 10 microns and 2.5 microns in aerodynamic diameter QA........................................ QualityAssurance QA Handbook.
................. 

### QualityAssuranceHandbook forAirPollution Measurements Volume II EPA AmbientAir Quality Monitoring Program, December 2008. EPA-454/B-08-0003. QAPP................................... QC........................................ QMP............................ SLAMS................................ SOP...................................... S02....................................... SPM..................................... TAPI. .......................... TSA...................................... EPA.............................. Quality Assurance Project Plan Quality Control QualityManagement Plan State or Local Air Monitoring Station Standard Operating Procedure Sulfur Dioxide Special Purpose Monitor Teledyne Air Pollution Instruments Technical System Audit United States Environmental Protection Agency

iiiThis document is a report on the findings ofthe United States Environmental Protection Agency (EPA) made during a Technical Systems Audit (TSA) ofthe Washoe County Health District Air QualityManagement Division (AQMD) ambient air monitoring program. A TSA is an on-site review and inspection ofa_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 ofthe AQMD monitoring organization required by40 CFRpart 58, appendix A, §2.5. The TSA was conducted byEPA Region 9 stafffrom September 4-6, 2013. EPA interviewed management and staffon specific aspects ofthe air monitoring program including network design, field operations, laboratory operations, data handling, quality assurance and quality control procedures. The audit team also inspected all ofthe monitoring sites operated byAQMD. The site inspections consisted ofan interview with the site operator when possible, review of station and instrument logbooks, and evaluation ofthe station siting with respect to EPA requirements for probe siting. The TSA is one ofthe ways that EPAprovides oversight to ensure that data collected by state, local, and tribal agencies meet required minimum data quality objectives. Other assessments, such as network reviews and performance evaluations, also provide information about the overall quality ofambient air monitoring data. These assessments enable agencies to identify and correct those program elements that may be adversely affecting the quality ofambient air data. The results ofthe. TSA are summarized here and fully described in this report, along with recommended actions to address the findings. The specific actions to be taken by AQMD will be determined through negotiations between EPA and AQMD, and will be documented in a corrective action plan prepared byAQMD. EPA would like to thank all the staffand management ofAQMD for their assistance and cooperation during the audit.


### A. Program Strengths: Listed below are examples ofprogram strengths observed over the course ofthe audit. 1. There has been substantial progress on findings from the previous TSA. 2. Staffdemonstrate a high level ofprofessionalism and technical expertise. 3. Comprehensive procedures for most ambient air monitoring activities have been documented and are used as required reading to help train staff. 4. Annual Monitoring NetworkPlans are well developed, succinct, and valuable information tools. 5. Monitoring stations are routinely visited (multiple times per week) and kept well organized, clean, and secure. 6. Some-amount ofback-up power supply is available at all sites.

17. Documentation in support ofambient air monitoring operations is thorough, easily accessible, and helpful to staffin understanding and preventing operational issues. 

### 8. Equipment needs are managed and prioritized through the use ofa comprehensive inventoryreplacement plan. Back-up equipment is generally available on-hand to minimize downtime andprevent data loss. 9. Formal corrective actions are well documented. 10. The Gravimetric PM laboratory is neat and well maintained. 11. Data is uploaded to AQS ahead ofthe quarterly deadline. 12. Thorough documentation is kept and accessible for data that is uploaded to AQS. 13. QC action levels more stringent than the minimum recommended are in place. 14. Internal performance evaluation audits are conducted more frequently (quarterly) than at the minimum required frequency (annually for gaseous parameters and semi-annually for PM). 15. Flow checks are conducted more frequently (bi-weekly) than atthe minimum required frequency (monthly) and have helped prevent data loss in some instances.
B. Program Major Findings: During the TSA, EPA identified areas where AQMD's monitoring program should be strengthened. The major findings are:
• [Finding 2] Several procedures were found either not documented or in need ofupdating. • [Finding 4] Steel was found as part ofthe sampling train for reactive gases (i.e., S02, N02, and Oa). · • [Finding 5] Trees at the Galletti site were within 10 meters ofthe probe. • [Finding 8] SOPs were not always accessible from the field. • [Finding 11] PM filter concentrations and accompanying supporting information is not backed-up in a timely manner. The individual findings are reported in the Findings section ofthis document and are also summarized in Appendix A. Ithas been EPA Region 9's experience that all monitoring programs have areas that could be improved. Unless explicitly stated, EPA's findings are not cause for data invalidation. As stated previously, AQMD has a robust airmonitoring program that produces reliable, defensible, valid data for regulatory use.

2TSA ACTIVITIES From September 4-6, 2013, the U.S. EPA Region 9 Air Quality Analysis Office (AQAO) conducted a Technical System Audit ofAQMD's ambient air monitoring program. The TSA reviews one part ofAQMD's program responsibility, the collection and analysis ofambient air quality data, which is the responsibility ofthe Air Quality Assessment Section. The TSA covered the following program areas:
• General 

### I QualityManagement Program organization Facilities Independent quality assurance and quality control Planning documents (including QMP, QAPPs, & SOPs) General documentation policies Training Corrective action Quality improvement External performance audits • Network Management 

### I Field Operations Network design Changes to the network since the last audit Proposed changes to the network Field support • Laboratory Operations Routine operations Quality control Laboratory preventive maintenance Laboratoryrecord keeping Laboratory data acquisition and handling Specific pollutants: 

### PMw and PM2.s • Data and Data Management Data handling Software documentation Data validation and correction Data processing Internal reporting External reporting EPA tracked supporting documentation for data points from calendar years 2010 through 2013. Elfego Felix ofthe EPA Region 9 Air Division's Air Quality Analysis Office conducted the onsite TSA. Participating managers and supervisors ofAQMD's ambient air monitoring program included: Kevin Dick, Director 

### 3

### Daniel Inouye, Air Quality Supervisor Craig Petersen, Senior Air Quality Specialist Julie Hunter, Senior Air Quality Specialist Brendan Schnieder, Air Quality Specialist Daniel Timmons, Air Quality Specialist Genine Wright, Air Quality Specialist
This report is divided into the following sections: • Executive Summary- describes the purpose ofthe TSA and a summary ofthe major findings. • TSA Activities

- outlines the timing ofthis TSA and the programs that were covered. • Overview ofAir Monitoring Program- describes AQMD's Air Monitoring Program. • Findings

- describes the details associated with each finding. • Appendix A

- provides a summarized list offindings. • Appendix B -provides a list ofgood practice recommendations. • Appendix C- provides an organizational chart ofAQMD. • Appendix D- Status offindings from 9/16/2010 TSA. The findings are grouped byprogram area. Recommendations to resolve findings are provided for each finding that requires corrective action to give some indication ofthe EPA expectations as to how findings can be addressed. IfAQMD has other approaches or alternatives to address the concerns identified, EPA will consider them, provided the corrective action adequately addresses the finding. General 

### The audit team interviewed management and staffon specific aspects ofthe air monitoring program including network design, field operations, laboratory operations, data handling, quality assurance and quality control procedures. EPA interviewed AQMD management and stafffrom the Monitoring and Planning branches and reviewed procedures, quality assurance documents, performed data tracking, visited all SLAMS monitoring sites, and reviewed findings from the previous TSA conducted in 2010. Network Management 

### EPA interviewed Daniel Inouye and Craig Petersen and reviewed AQMD's Annual Monitoring Networkplan submitted for July 2013. AQMD also submitted a five-year Annual Network Assessment as required by40 CFRpart 58.10. The next network assessment will be due in 2015. Generally, the monitoring network meets the requirements for the minimum number of monitoring sites designated as SLAMS for all ofthe criteria pollutants. EPA visited all SLAMS monitoring sites in AQMD's network. Most sites met the siting criteria of40 CFRpart 58, appendix E. The evaluation included inspection ofthe inlet manifolds, examination ofstation and instrument logbooks, and a check ofwhether appropriate QC checks


### 4and QA audits were being performed. EPA found that sites were well maintained and in good working condition. Field Operations EPA interviewed Craig Petersen, Genine Wright, and Daniel Timmons and reviewed field operation procedures as well as documentation generated in the field. Staffmaintain and generate thorough records for field operations, facilitating understanding and prompt resolution of operational issues. Laboratory Operations Particulate Matter Laboratory (Gravimetric Laboratory) EPA visited the particulate matter (gravimetric) laboratory and interviewed Genine Wright and Craig Petersen. The particulate matter laboratory was well organized and maintained. All equipment in use at the laboratory was found to be within expiration dates. EPA observed a weekly maintenance lab check conducted byAQMD staff. Data and Data Management This section covers data management for criteria pollutants (03, CO, N02, S02, PM2.s, and PMw). EPA interviewed Brendan Schnieder who serves as the Data Manager for AQMD. During this portion ofthe audit, EPA requested information to track data that had been uploaded into AQS. Quality Management EPA interviewed Daniel Inouye, Craig Petersen, and Julie Hunter and reviewed quality management documents. In addition, EPA collected information about QA/QC activities during interviews ofother sections ofthe technical system.

5OVERVIEW OF AIR MONITORING PROGRAM General Program Federal and state laws relating to achieving and maintaining clean air, as required bythe Clean Air Act (CAA), are in place throughout the country to protect public health. The State of Nevada has three governmental agencies that are responsible for collecting ambient air quality data as directed bythe 1977 Clean Air Act and 1990 Clean AirAct Amendments. Washoe County Health District Air QualityManagement Division (AQMD) operates the air monitoring network in the Reno/Sparks Metropolitan area and Washoe County. The Clark County Department ofAir Quality operates the ambient air monitoring network in the Las Vegas Metropolitan area. The Nevada Division ofEnvironmental Protection operates the ambient air monitoring network in the rest ofthe State. AQMD is headed by a Director who is overseen by a District Health Officer and District Board ofHealth. Ambient air monitoring is conducted within the Monitoring Branch ofAQMD. The Monitoring Branch is overseen by an Air Quality Supervisorthat also oversees the Planning Branch. The Monitoring Branch consists ofa SeniorAir Quality Specialist and two additional Air Quality Specialist staff. The QA independence function is held by a Senior Air Quality Specialist within the Planning Branch. AQMD reported air monitoring operations as fully staffed since February 2013. AQMD is responsible for operating the equipment that collects gaseous and particulate matter criteria air pollutants. AQMD installs and maintains all monitoring equipment and performs basic quality control checks. AQMD is in charge ofthe partic1:1late matter filter weighing laboratory and is also responsible for performing quality assurance audits, developing and implementing the quality assurance program, performing monitoring network reviews, and the review and preparation ofdata for submittal to EPA's AQS database. Network Management AQMD operates a network ofeight monitoring sites consisting ofState and Local Air Monitoring Stations (SLAMS) and Special Purpose Monitors (SPM). NetworkManagement is overseen bythe Air Quality Supervisor for Monitoring and Planning. The table below summarizes the sites and parameters monitored by AQMD. More details about the AQMD network at the time ofthe TSA can be found in the Washoe CountyHealth District Air Quality Management Division 2013 Ambient Air Monitoring Network Plan submitted to EPA July 1, 2013. The Senior Air Quality Specialists withinthe Monitoring and Planning Branch share responsibility for preparation ofthis plan.

6WASHOE COUNTY HEALTH DISTRICT AMBIENT AIRMONITORING NETWORK Site 03 

## co S02 NOx/NOy PM10 PM2.s PM10-2.s PM2.s Meteorology Name Speciation Galletti X X X X Incline X Village Lemmon X X

Valley Plumb-Kit X

Reno3 X X X X X X X X X South X X X Reno Sparks X X X X

Toll X X X

7Field Operations AQMD employs three air quality technicians who maintain and operate the sites in the network and visit on average each oftheir sites three times a week. The Senior Air Quality Specialist within the group oversees the two otherjunior staff. Technicians conduct audits using a unique set ofaudit standards but do not audit instruments they maintain. Training offield technicians consists of, but is not limited to, required ambient monitoring document readings, vendor/EPA/website course/conference attendance, and on-the-job shadowing. All maintenance and repair work on instruments is performed at the monitoring site when possible. When repairs cannotbe made on-site, instruments are brought backto the AQMD office, which serves as the centralized maintenance and repair facility. Repair work is typically performed bythe technicians. Equipment is rarely sent to the manufacturer for repair and AQMD has no service contracts in place for its equipment. The AQMD office has a room dedicated to equipment repair. Spare equipment and supplies are stored here, and there is a refrigerator for long-term PM2.s filter storage. The PlumbKit monitoring site, along with a rented storage bunker in Sparks, is also used for short and longterm storage. Laboratory Operations AQMD operates a filter weighing laboratory for low volume 

### PMw and PM2.s filter weighing. The primaryresponsibility ofthe laboratory is to process PM filters, which includes preparation, weighing, tracking, and short-term storage. The PM laboratory is managed by one of the field technicians. Data and Data Management The AQMD data manager is responsible for reviewing data quality as well as submitting data to AQS and AirNow. AQMD recently moved from the Environmental Monitoring Company (EMC) system to the Air Vision system. Continuous data is downloaded hourly directly onto the dedicated server and accessed with the Air Vision software. The program handles the collection, editing, and file formatting for all continuous pollutant data to be uploaded to AQS. As AirNow only uploads continuous instrument data, it is not considered to be collecting data for an official record. The AirNow data are not correctedpriorto uploading. Manual methods data is collected one day after a completed run and is first recorded in a logbook, transcribed onto field sample reports, and entered on spreadsheet files that can be uploaded for editing in the AirVision system.AQMD submits all required data to the AQS database and Air Now, including concentrations for all criteria pollutants, supporting precision and accuracy information, and data from the network. Data submittedto AQS are certified annually byAQMD. Quality Management



### 8Qualitymanagement is the system put inplace to oversee quality assurance, quality control, and quality improvement activities. EPA defines quality system requirements for ambient air monitoring activities in 40 CFRPart 58 Appendix A. Additionally, EPA's quality policy (EPA Order CIO 2105.0) along with grant regulations (40 CFRPart 31.45) specifically require that each grantee develop and implement a quality system. EPA views the application of these quality management system components as integral to monitoring programs. AQMD's ambient air monitoring program employs a quality management system targeted to conform to40 CFR Part 58 Appendix A by:

• Having a documented quality system that meets EPA requirements for QMPs and QAPPs. • Having a quality management function (held by a Senior Air Quality Specialist within the Planning Branch) that is independent ofair monitoring operations. • Developing or adopting DQOs, or equivalent systematic planning procedures, for all monitoring programs. • Participating inNational Performance Evaluation Programs, which consist ofperformance audits used to independently determine program adequacy, national monitoring network performance, and national consistency. • Having Technical Systems Audits performedbyEPA Regional Offices at a frequency of every three years or less. • Using certified reference materials to standardize monitoring equipment.



### 9FINDINGS Program Area Findin2 Numbers General 

### 1-3 Network Management 

### 4-7 Field Operations 

### 8-10 Particulate Matter (Gravimetric) Laboratory None Data Management 

### 11-13 Quality Assurance/Quality Control 

### 14-16

10

### Finding# 1 

### Agency: Washoe County AQMD 

### Date ofAudit: September 4-6, 2013**Pro~ram** 

### Area(s): General 

### Fin**din~:** The QMP is conditionally approved. 

### Discussion: The QMP describes the quality system in terms ofthe organizational structure, functional responsibilities ofmanagement and staff, lines ofauthority, and required interfaces for those planning, implementing, assessing and reporting activities involving environmental data operations. AQMD made significant progress since the previous TSA (20 1 0) obtaining full EPA approval ofthe QAPP (February 2013) and conditional approval ofthe QMP (August 2013). 

### References: 

## • 40 CFR Part 58, Appendix A, Section 2 

## • EPA Requirements for QualityManagement Plans, EP A/240/B-01/002, March 2001
. 

### Recommendation to Address Finding: To obtain full EPA approval, AQMD should resubmit a QMP that adequately addresses EPA's conditional approval comments sent in August 2013.

11

### Findin2# 2 (Major) Washoe County AQMD 

### Date ofAudit: September 4-6, 2013 

### Pro2ram Area(s): General Several procedures were found either not documented or in need ofupdating. 

### Discussion: EPA was unable to find AQMD-documented procedures for the following activities: • Use ofPM filter lot blanks (previous TSA finding). • Meteorological audits (required for NCore sites). • Daily data review conducted by site technicians. • Related to PM filter handling outside ofthe lab: o Receipt ofnew shipments. o Sample deployment and return from the field. 

### o Archival and disposal. • Use ofthe new AirVision software pertaining to data management activities, including: o Uploading to AirNOW. o Continuous Monitoring Methods data validation. • Transcription error checks for data that is manually entered into the data management system. The PM Lab SOP did not specifythe following instructions: • Cleaning ofcassettes. • Re-weighing offilters conducted priorto field deployment. • Use ofanti-static spraywhen cleaning the weighing area. • Action to take ifQuarterly Weight Standard Verification, Temperature, orrelative humidity audits fail. • Frequency for conducting temperature andrelative humidity audits. • Requirement for weekly lab documentation. The following inconsistencies were noted in the PM Lab SOP: • Section M.2.1.2 #4 & #9 call for the use ofa 400 and 300 mg weight standard, while Figure 2 (Sample Filter Weigh Log) contains a 200 & 100 mg weight standard slot. Section M.4.1 #4 should also be made consistent with Figure 2. • Figure 2 (Sample Filter Weigh Log) notes that pre-samples must equilibrate two months priorto weighing, whereas section M.2.1.1 #7 states that it should be a minimum ofthree months. • Section M.5.1#4 incorrectlyreferences Figure 4 as the QuarterlyWeight Standard Verification form which actually appears as Figure 5 on page M-11. • Figure 5 (Quarterly Weight Standard Verification form) disagrees with seetion M.2.1.2, which specifies the use of300 and 400 mg weights.

12

## • Section M.5.2 #3 incorrectly references Figure 5 as the Intercomparison Worksheet form. That worksheet is Fig].Ire 6 on page M-13. 

### References/Guidance: QA Handbook forAirPollution Measurement Systems, Vol II: AmbientAir Quality Monitoring Program, EPA-454/B-13-003, December 2013. (Section 5) 

### Recommendation to Address**Findin~:** AQMD should ensure that all procedures in support ofregulatory monitoring are documented and up to date.

133 Washoe Count AQMD

Examples ofinadequate or incomplete documentation were found. Discussion: Several instances ofinadequate documentation practices were found on a PM2
.sQuarterly Weight Standard Verification form dated 06/27/13 (Figure 3a). Examples circled in red on the form below include: use ofscribbling or multiple lines to cross out an entry, illegible handwriting, and the use ofan outdated form requiring several corrections
.



## +.'-2 **go ini**  **~** nla

.,· 1 · 0 Figure 3a- PM2.s Quarterly Weight Standard Verification form. ... . ... .

EPA found that a trace level CO instrument audit conducted on August 27,2013 (Figures 3b & 3c) was incomplete. The audit worksheet and logbook entry did not clearly indicate whether the audit passed or failed. ·

14

## .....

# -

Figure 3b- Audit Worksheet.

Figure 3c- Logbook Entry. References/Guidance: QA Handbook forAirPollution Measurement Systems, Vol II: AmbientAir Quality Monitoring Program, EPA--454/B-13-003, December 2013. (Section 5)

15Recommendation to Address Finding: AQMD should ensure staffare trained on and practice proper documentation. All audit results shouldbe clearly indicated as "PASS" or "FAIL" onrelevant forms.

16Steel was found as part ofthe sampling train for reactive gases (i.e., SO,, NO,, and 0 3 )
. 

### Discussion: EPA found that AQMD was using steel splitters in the sampling train throughout the reactive gaseous site network (see pictures). Given the potential for reactive gas interference from inlet probe to the back ofthe analyzer steel should not come into contact with reactive ambient air samples. EPA has specified that borosilicate glass, FEP Teflon®or their equivalent must be the only material in the sampling train (from inlet probe to the back ofthe analyzer) that may come into contact with the ambient air sample for existing and new SLAMs.

Steel splitters at South Reno (left) and Toll (right) sites
. 

### References/Guidance: 40 CFR Part 58, Appendix E, Section 9 

### Recommendation to Address Findin : AQMD should ensure only appropriate material is used in the sampling train for the reactive gases, SO,, NO,, and 03.

17Discussion: During the Galletti site visit, EPA observed trees growing that were less than the minimum required distance of 10 meters from the probe (see picture). AQMD was aware ofthis siting deficiency at the time ofthe audit and indicated that there were plans to relocate the**sit~** in order to correct the situation.

Trees near Galletti probe. References/Guidance: 40 CFR Part 58, Appendix E, Section 5 Recommendation to Address Findin : AQMD should ensure all sites meet the minimum requirements for spacing from trees. If relocated to correct for the siting deficiency, the Galletti spatial scale should be reevaluated.

186 Washoe Count AQMD

The Galletti site spatial scale for PM measurements was listed as neighborhood despite the presence ofa nearby minor PM source. Discussion: During a visit to the Galletti site, EPA found a dirt pile nearby (see picture) that mayhave been impacting the neighborhood-scale PM measurements taken at the site. Given the proximityto nearby sources observed at the time ofthe audit, the middle or micro scales may be more appropriate for PM measurements at this location.

Picture ofnearby dirt pile taken from Galletti rooftop.
References/Guidance: • 40 CFR 58, Appendix D, Section 4.6 • 40 CFR Part 58, Appendix E, Section 3 Recommendation to Address Findin : AQMD should review the scale for PM measurements at the Galletti site and adjust as needed. Specifically, AQMD should review the spacing from minor sources and representative source mix as theypertain to the scale ofrepresentativeness per 40 CFR 58, Appendix D, Section 4.6.

19

### Finding# 7 

### Agency: Washoe CountyAQMD 

### Date ofAudit: September 4-6, 2013 

### Program Area(s): Network Management 

### Finding: The middle spatial scale assigned for 

### 03 at the Toll site should be neighborhood scale based on traffic counts available at the time ofthe audit. 

### Discussion: EPA noted that the spatial scale for 

### 03 at the Toll site has shifted in the past based on changing traffic counts. For example, in Finding C3 ofthe previous AQMD TSA, it was noted that 

### 03 the Toll site did not appear to meet neighborhood scale siting requirements since the site was listed at a distance of20 meters from the road with average traffic counts of 16,033 vehicles per day. 

### In the Network Plan submitted byAQMD in 2013, EPA found that 

### 03 at the Toll site was listed as middle scale. Based on a distance from the road listed at 21 meters, and a traffic count from the nearest road listed at 15,000 AADT, neighborhood scale would be acceptable for this site, assuming there are no other reasons requiring designation as middle scale. The appropriate scales for 

### 03 monitors are neighborhood, urban, orregional scale in order to satisfy minimum SLAMS monitoring requirements. 

### References/Guidance: 

## • 40 CFR Part 58, Appendix D 

## • 40 CFR Part 58, Appendix E, Table E-1 

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

### Recommendation to Address Finding: AQMD should review the spatial scale for 

### 03 at the Toll site to ensure it is current andreflects distance to the road and recent traffic counts. 

### In order for the Toll site to meet 

### 03 SLAMS minimum monitoring requirements, the spatial scale should be neighborhood or larger.

20

### Finding# 8 (Maior) 

### Agency: Washoe County AQMD 

### Date ofAudit: September 4-6, 2013**Pro~ram** 

### Area(s): Field Operations 

### Fin**din~:** SOPs were not always accessible from the field. 

### Discussion: AQMD noted that electronic copies ofupdated SOPs are maintained on the server for staff access. When EPA asked staffto access SOPs from the field, some were not able to gain access. 

### References/Guidance: QA Handbook forAirPollution Measurement Systems, Vol II: AmbientAir Quality Monitoring Program, EPA-454/B-13-003, December 2013. (Section 5) 

### Recommendation to Address**Findin~:** AQMD should ensure that all staffhave access to the mostrecent electronic orhard copy SOPs from the field.

21

### Finding# 9 

### Agency: Washoe County AQMD 

### Date ofAudit: September 4-6, 2013 

### Program Area(s): Field Operations 

### Finding: Some recommended instrument maintenance checks were not being conducted. 

### Discussion: EPA found that AQMD was not conducting the following EPA and manufacturer recommended maintenance checks on the Met One BAM-1020 instruments: 

## • Smart heater tests
. 

## • Internal debris filter cleaning/replacement. 

# • Membrane span foil check. 

## • Check on beta detector count rate
. 

## • 72-hour zero filter test. AQMD staffnoted that field technicians had not yet received manufacturer training on the operation ofrecently acquired BAMunits. This training had been planned for some time in the fall of2013. 

### References/Guidance: 

## • DRAFT SOP for the Met One BAM -1020; Federal Equivalent Method EQPM-0308- 170 for PM2.5

- 8/28/2009 http://www.epa.gov/ttn/amtic/files/ambient/pm25/sop_project/905505_BAM_SOP_Dr aft _Final_Oct09.pdf 

## • Technical Note- Met One BAM Zero Tests- 10/05/2012 http://www.epa.gov/ttn/amtic/files/ambient/pm25/sop_project/TechNoteMet0neBAM ZeroTests.pdf 

### Recommendation to Address Finding: AQMD should incorporate all recommended instrument maintenance checks and update procedures accordingly. A rationale should beprovided ifmaintenance recommendations are not adopted. Staffshouldbe trained priorto field deployment ofnew instruments, whenever possible.

22Finding# 10 Agency: Washoe County AQMD Date ofAudit: September 4-6, 2013 Program Area(s): Field Operations Finding: Some instrument maintenance checks were notbeing conducted atthe recommended schedule. Discussion: EPA found two examples ofinstrument maintenance checks being conducted less often than the recommended frequency. 1. AQMD noted that other than at the NCore site, zero/precision/span gaseous instrument checks are conducted manually on a bi-weekly schedule and multi-point calibrations once per year. The NCore site undergoes daily zero/precision/span checks. For instruments doing bi-weekly zero/precision/span checks, EPA recommends a multipoint calibration once every six months. For instruments doing daily zero/precision/span checks, EPArecommends a multi-point calibration once per year. 2. AQMD indicated that cleaning ofthe Capstan Shaft for BAMunits was conducted every other month rather than the recommended monthly cleaning. The Capstan Shaft cleaning step and frequency was not clearly documented in AQMD's BAM SOP. References/Guidance: 

## • QA Handbook forAirPollution Measurement Systems, Vo/11: AmbientAir Quality Monitoring Program, EPA-454/B-13-003, December 2013. (Appendix D) 

## • DRAFT SOP for the Met One BAM-1020; Federal Equivalent Method EQPM-0308- 170 for PM2.5- 8/28/2009 http://www.epa.gov/ttn/aintic/files/ambient/pm25/sop_project/905505_BAM_SOP_Dr aft _Final_ Oct09.pdf Recommendation to Address Finding: AQMD should conduct all instrument maintenance checks at the recommended frequency and update procedures accordingly. A rationale for deviations from the recommended maintenance schedule should be documented. Tables showing recommended maintenance frequencies (e.g. see Table 10-1 ofthe DRAFT SOP for the Met One BAM-1020; Federal Equivalent Method EQPM-0308-170 for PM2.5- 8/28/2009) may be a useful addition to AQMD's instrument SOPs.

23

### Finding# 11 (Major) 

### Agency: Washoe CountyAQMD 

### Date ofAudit: September 4-6,2013 

### Program Area{s): Data Management 

### Finding: PM filter concentrations and accompanying supporting information is not backedup in a timely manner. 

### Discussion: After weighing PM filters, AQMD field staffcompile and generate a data package containing concentrations and QA/QC information for the Data Managerto validate and enter into the Air Vision data handling software. Once data are entered, they are backed up on a daily basis, however the data package is not backed up at the same frequency. The Data Manager noted these PM filter data packages are usually entered into the data handling software within 2-5 days, however there were times when these packages had accumulated for longer periods of time. As an example, at the time ofthe audit, the Data Manager hadbeen occupied with wildfire response activities and estimated that approximately 3 weeks ofdata packages had not yet been entered. 

### References/Guidance: QA Handbook forAirPollution Measurement Systems, Vol II: AmbientAir Quality Monitoring Program, EPA-454/B-13-003, December 2013. (Section 14) 

### Recommendation to Address Finding: AQMD should ensure PM filter data packages are backed up as soon possible after being generated in order to minimize the potential for data loss.

24

### Finding# 12 

### Agency; Washoe County AQMD 

### Date ofAudit: September 4-6, 2013 

### Program Area(s): Data Management 

### Fin**din~:** Appropriate qualifier codes (flags) are not always applied to data in AQS. 

### Discussion: The Data Manager noted that not many ofthe data qualifier codes were in use and that AQMD was working towards using more complete and more descriptive qualifier code options. EPA noted two examples in which the qualifier codes entered into AQS did not accurately reflect the situation on the ground. 1. Data from a PM2.s BAMunit that failed a flow check at the Sparks site was nullified between 01/01/13-01/14/13 and given a machine malfunction flag. Other qualifiers describing out-of-limit flow orpoor quality assurance results would have been more appropriate in this situation. 2. Several instances were noted during which AQMD entered miscellaneous null flags during a calibration. AQMD applied the miscellaneous null flag for all instruments that hadto be taken off-line, due to a shared manifold, during a calibration ofa separate gaseous instrument. 

### Inthese cases, use ofavailable calibration flags would have been more appropriate. 

### References/Guidance: 

## • 40 CFR Part 58.16 

## • AQS Qualifier Codes https://aqs.epa.gov/aqsweb/codes/data/QualifierCodes.html 

### Recommendation to Address Finding: AQMD should ensure flags applied to AQS data are given the most appropriate qualifier codes available and continue to supplement this with field documentation. 

### In general, EPA recommends avoiding use of"Miscellaneous" or "Other" flag codes whenever possible.

25Finding# 13 Agency: Washoe CountyAQMD Date ofAudit: September 4-6, 2013 Program Area(s): Data Management Finding: A significant amount ofPM2.s data was lost during a time ofexpected high concentrations. Discussion: EPA found that the PM2.s POC 1 atthe Sparks site reported a completeness of56% for the month ofJanuary 2013 due to invalidation that occurred because ofa failed flow audit between 12/31114 to 01/14/14. Data capture during this time ofthe year is critical for implementation ofthe NAAQS given thathigher concentrations are often observed during the winter months and around the holidays. Itis worth noting that AQMD's robust practice ofconducting bi-weekly flow checks, rather than the minimallyrequired monthly checks, helped prevent further data loss. References/Guidance: 40 CFR 58, Appendix A Recommendation to Address Finding: AQMD should take steps to ensure the maximum capture rate during seasons when higher concentrations are expected.

26**Findin~** 

### # 14**A~ency:** Washoe County AQMD 

### Date ofAudit: September 4-6, 2013**Pro~ram** 

### Area(s): QA 

### Fin**din~:** The corrective action process can be improved. 

### Discussion: AQMD has developed a formal corrective action process that is initiated through a standardized form (see picture) and several instances were noted where resolution to a problem was promptly reached due to the system now in place. EPA noted the following improvement opportunities from AQMD's corrective action process: 

## • Staffwere unclear on the types ofsituations in which to generate a formal corrective action using the form. 

# • The corrective action form mayrequire a corrective action to be taken within a matter ofhours, however a time stamp field for the requestor and responder is not specified.

27Corroctivo Action Request



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### AQMD Sample Corrective Action Form. 

### References/Guidance: QA Handbook forAirPollution Measurement Systems, Vol II: AmbientAir Quality Monitoring Program, 

### EPA-454/B-13-003, December 2013. (Section 15) 

### Recommendation to Address Finding: AQMD should work with staffto identifythe appropriate situations in which to initiate a corrective action through the standardized form and to ensure the form includes a time stamp for the requestor and responder.



### 28Findin2

### # 15 A2ency: Washoe County AQMD Date ofAudit: September 4-6, 2013 Program Area(s): QA/QC Finding: Standards were found to have expired in some instances. Discussion: AQMD shared schedules used to track and document when standards are due for certification (see 2011 and 2012 schedules copied below). Upon inspection, EPA noted several standards that had gone significantlypasttheir expiration date. These included: 

## • Primary Ozone TAPI 400E (Serial#:607) expired for approximately five months between April-September 2011. 

## • Audit MFC Environics 6103 (Serial#: 4259) expired for approximatelythree months between August-November 2011. 

## • Flow Chinook Streamline FTS (Serial#: 117) expired for approximately three months between May-August 2012. 

## • MET Vaisala WXT520 (Serial#: E0230001) expired approximately four months between January-May 2012. Annual Traceabilitylrllaintenance Schedule Year: 2011

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AQMD should ensure that all standards are certified at the appropriate frequency and that 

### QAJQC checks are not performed with expired standards.

30

### Finding# 16 

### Agency: Washoe CountyAQMD 

### Date ofAudit: September 4-6, 2013 

### Program Area(s): QA 

### Finding: Quality assurance practices for a special study were not found. 

### Discussion: In an effort to better understand the spatial distribution ofPM2.s, AQMD initiated a special study in the Reno-Sparks area. AQMD awarded a contract for the colleCtion ofambient monitoring data for the special study. The contractor used its equipment and protocols, but EPA was unable to verify whether AQMD made sure that appropriate quality assurance procedures were followed. The steps that AMQD takes to ensure the quality assurance of contracted special studies were not documented in the QAPP or QMP. 

### References/Guidance: 40 CFR Part 58, Appendix A 

### Recommendation to Address Finding: AQMD should document the steps taken to ensure proper quality assurance is followed for special studies performed in house andbycontractors. The general procedure AQMD follows to ensure proper quality assurance for special studies should be included in the QAPP or QMP and submitted to EPA for approval.

31APPENDIX A: Summary ofFindings FINDINGS Finding 1: The QMP is conditionally approved. Finding 2 (Major): Several procedures were found either not documented or in need of updating. Finding 3: Examples ofinadequate or incomplete documentation were found. Finding 4 (Major): Steel was found as part ofthe sampling train for reactive gases (i.e., S02, N02, and 03). Finding 5 (Major): Trees at the Galletti site (AQS 

### ID:J2-031-0022) were within 

### 10 meters of the probe. Finding 6: The Galletti site spatial scale for PM measurements was listed as neighborhood despite the presence ofa nearby minor PM source. Finding 7: The middle spatial scale assigned for 

### 03 at the Toll site shouldbe neighborhood scale

.based on traffic counts available at the time ofthe audit. Finding 8 (Major): SOPs were not always accessible from the field. Finding 9: Some recommended instrument maintenance checks were notbeing conducted. Finding 10: Some instrument maintenance checks were not being conducted at the recommended schedule. Finding 11 (Major): PM filter concentrations and accompanying supporting information is not backed up in a timely manner. Finding 12: Appropriate qualifier codes (flags) are not always applied to data in AQS. Finding 13: A significant amount ofPM2.s data was lost during a time ofexpected high concentrations. Finding 14: The corrective action process can be improved. Finding 15: Standards were found to have expired in some instances. Finding 16: Quality assurance practices for a special study were not found.

32APPENDIX B: Good Practice Recommendations
1. Safety rails should be installed on all sides ofmonitoring sites requiring rooftop access and all staffshould be trained on how to prevent falls when visiting the rooftop ofsites. 2. Transcription ofthe same information across various QA/QC forms should be minimized wherever possible in order to eliminate redundancies, save time, and decrease the chance ofhumantranscription error. Information should still maintain its integrity and be easily accessible. Consideration might be given to expanding the use ofelectronic systems to maintain and enter data. 3. An SOP should be developed for operation ofthe eBAM unit. 4. In orderto add additional levels ofsecurity for PM filters, it is recommended that the lab door and archived filter refrigerator require lock entry. 5. A more permanent fix to the BAM pump muffler clogging issue should be pursued. Drilling a hole through the pump muffler is considered an acceptable temporary fix.

33

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JAPPENDIX D: Status of Findings from 9/16/2010 TSA

Finding Corrective Action Status

A. General Program AI AQMD's Quality Assurance program QAPP was approved by EPA February Partially completed.

documentation, including the Quality Management 2013 and QMP conditionally approved QMP requires full

Plan (QMP) and the Quality Assurance Project August 2013. approval. See 2013

Plan (QAPP), was not complete and was not TSA Finding 1.

approved by EPA at the time of the audit.

A2 AQMD's Standard Operating Procedures (SOPs) SOPs were updated and approved with Completed.

were not up-to-date at the time of the audit. QAPP in February 2013.

A3 AQMD does not have a formal training program Formal training requirements Completed.

for new and existing staff. documented in approved QAPP.

B. Network Management Bl AQMD does not submit all continuous PM data to All data are now being submitted to Completed.

AQS. AQS.

B2 AQMD's 2009 Ambient Air Monitoring Network Toll Site spatial scale was adjusted to Completed.

Plan does not accurately characterize the Toll accordingly and reflected in the annual

site's spatial scale for CO. monitoring network plan.

B3 AQMD's 2009 Ambient Air Monitoring Network A statement of purpose has been Completed.

Plan does not include a statement of purpose for incorporated into the annual monitoring

each monitor at each site. network plan beginning with the 2011 submittal. I

C. Field I I

Operations I I

!

Cl Zero air scrubbers are not compared against a Zero air scrubbers are and will continue Completed.

certified zero air standard and are not changed out to be compared against ultra-pure air

on a routine schedule. cylinders. This procedure is documented

i11_b.QMD's audit SOP.

35C2LogbooksarenotbeingconsistentlytrackedandAconsistenttrackingandlabelingCompleted.labeled.systemwasimplementedJuly2013.C3AQMD'sTollsitedoesnotappeartomeetTheTollsitespatialscaleappearstobeIncomplete.Seeneighborhoodscalesitingrequirements.shiftingfromyeartoyear.related2013TSAFinding7.C4TheorganizationofQAauditsandoversighttasksThisisnowdocumentedinAQMD'sCompleted.isnotsufficientlydocumented.approvedQAPP.D.LaboratoryOperationsD1TheprocedureAQMDusestotestPMblanksisConsistentwithEPAguidance,AQMDCompleted.inconsistentwithEPAguidance.hasstartedusinglotblanksinitstestingoffilterblanks.D2Pre-andpost-sampleweightsaretranscribedontoQualitycontrolcheckson10%oftheCompleted.fieldsamplereportsfromweighlogs,andarethentranscriptionsarebeingconductedasofmanuallyenteredintoexcelspreadsheets.July2013.ArevisedSOPcontainingthisstephasbeenpreparedbyAQMD.E.DataandDataManagementE1HandwrittenchangesmadeinrecordbooksandLogbookchangesarenowinitialedandPartiallycompleted.logbooksarenotenteredinaconsistentmanner.dated.DocumentationpracticescanstillSeerelated2013beimproved.TSAFindings3.F.QualityAssuranceandQualityControlFlTheozoneauditstandardandcalibrationtransferAQMDhasstartedcertifYingboththeCompleted.standardreferencethesameprimarystandard.primaryandauditstandardsindependentlyofoneanother.36