UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION IX 

Ms. Charlene Albee, Director 

Washoe County Health District 

Air Quality Management 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) of the 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 of primary 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 by AQMD. 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 of receipt of the final TSA report. 

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

results ofthis audit significantly contribute to EPA's overall understanding of ambient monitoring in 

Washoe County, Nevada. 

Please contact me if you have questions, or your staff may 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 Recycled Paper 

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 

11 
GLOSSARY OF ACRONYMS 

AQMD .......................... Washoe County Health District Air Quality Management 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........................................ Quality Assurance 

QA Handbook. ................. Quality Assurance Handbook for Air Pollution Measurements 

Volume II EPA Ambient Air 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 

Quality Management 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 

iii 
This document is a report on the findings of the United States Environmental Protection Agency 

(EPA) made during a Technical Systems Audit (TSA) of the Washoe County Health District Air 

Quality Management Division (AQMD) 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 the AQMD 

monitoring organization required by 40 CFR part 58, appendix A, §2.5. 

The TSA was conducted by EPA Region 9 staff from September 4-6, 2013. EPA interviewed 

management and staff on specific aspects of the air monitoring program including network 

design, field operations, laboratory operations, data handling, quality assurance and quality 

control procedures. The audit team also inspected all of the monitoring sites operated by AQMD. 

The site inspections consisted of an interview with the site operator when possible, review of 

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

requirements for probe siting. 

The TSA is one of the ways that EPA provides 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 of ambient air monitoring data. These assessments enable agencies to identify and correct 

those program elements that may be adversely affecting the quality of ambient air data. The 

results of the. 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 by AQMD. 

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

cooperation during the audit. 

A. Program Strengths: 

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. Staff demonstrate a high level of professionalism 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 Network Plans 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 of back-up power supply is available at all sites. 

1 
7. Documentation in support of ambient air monitoring operations is thorough, easily 

accessible, and helpful to staff in understanding and preventing operational issues. 

8. Equipment needs are managed and prioritized through the use of a comprehensive 

inventory replacement plan. Back-up equipment is generally available on-hand to 

minimize downtime and prevent 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 of the 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 at the 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 of updating. 

• [Finding 4] Steel was found as part of the sampling train for reactive gases (i.e., S02, N02, 

and Oa). · 

• [Finding 5] Trees at the Galletti site were within 10 meters of the 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 of this document and are also 

summarized in Appendix A. 

It has 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 air monitoring program that produces reliable, defensible, valid 

data for regulatory use. 

2 
TSA ACTIVITIES 

From September 4-6, 2013, the U.S. EPA Region 9 Air Quality Analysis Office (AQAO) 

conducted a Technical System Audit of AQMD's ambient air monitoring program. The TSA 

reviews one part of AQMD's program responsibility, the collection and analysis of ambient air 

quality data, which is the responsibility of the Air Quality Assessment Section. The TSA covered 

the following program areas: 

• General I Quality Management 

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 

Laboratory record 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 of the EPA Region 9 Air Division's Air Quality Analysis Office conducted the onsite TSA. 

Participating managers and supervisors of AQMD'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 of the TSA and a summary of the major 

findings. 

• TSA Activities - outlines the timing of this TSA and the programs that were covered. 

• Overview of Air Monitoring Program- describes AQMD's Air Monitoring Program. 

• Findings - describes the details associated with each finding. 

• Appendix A - provides a summarized list of findings. 

• Appendix B -provides a list of good practice recommendations. 

• Appendix C- provides an organizational chart of AQMD. 

• Appendix D- Status of findings from 9/16/2010 TSA. 

The findings are grouped by program 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. If AQMD 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 staff on specific aspects of the air monitoring 

program including network design, field operations, laboratory operations, data handling, quality 

assurance and quality control procedures. EPA interviewed AQMD management and staff from 

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 

Network plan submitted for July 2013. AQMD also submitted a five-year Annual Network 

Assessment as required by 40 CFR part 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 of the criteria pollutants. 

EPA visited all SLAMS monitoring sites in AQMD's network. Most sites met the siting criteria 

of 40 CFR part 58, appendix E. The evaluation included inspection of the inlet manifolds, 

examination of station and instrument logbooks, and a check of whether appropriate QC checks 

4 
and 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. Staff maintain 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 by AQMD 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 of the 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 of other sections of the technical system. 

5 
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 State of 

Nevada has three governmental agencies that are responsible for collecting ambient air quality 

data as directed by the 1977 Clean Air Act and 1990 Clean Air Act Amendments. Washoe 

County Health District Air Quality Management Division (AQMD) operates the air monitoring 

network in the Reno/Sparks Metropolitan area and Washoe County. The Clark County 

Department of Air Quality operates the ambient air monitoring network in the Las Vegas 

Metropolitan area. The Nevada Division of Environmental Protection operates the ambient air 

monitoring network in the rest of the State. 

AQMD is headed by a Director who is overseen by a District Health Officer and District 

Board of Health. Ambient air monitoring is conducted within the Monitoring Branch of AQMD. 

The Monitoring Branch is overseen by an Air Quality Supervisor that also oversees the Planning 

Branch. The Monitoring Branch consists of a Senior Air 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 of the 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 of data for submittal to EPA's AQS database. 

Network Management 

AQMD operates a network of eight monitoring sites consisting of State and Local Air 

Monitoring Stations (SLAMS) and Special Purpose Monitors (SPM). Network Management is 

overseen by the 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 of the TSA can be found in the Washoe County Health District Air Quality 

Management Division 2013 Ambient Air Monitoring Network Plan submitted to EPA July 1, 

2013. The Senior Air Quality Specialists within the Monitoring and Planning Branch share 

responsibility for preparation of this plan. 

6 
WASHOE COUNTY HEALTH DISTRICT AMBIENT AIR MONITORING 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 

7 
Field Operations 

AQMD employs three air quality technicians who maintain and operate the sites in the 

network and visit on average each of their sites three times a week. The Senior Air Quality 

Specialist within the group oversees the two other junior staff. Technicians conduct audits using 

a unique set of audit standards but do not audit instruments they maintain. Training of field 

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 cannot be made on-site, instruments are brought back to the AQMD 

office, which serves as the centralized maintenance and repair facility. Repair work is typically 

performed by the 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 primary responsibility of the 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 corrected prior to 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 submitted to AQS are certified annually by AQMD. 

Quality Management 

8 
Quality management is the system put in place to oversee quality assurance, quality 

control, and quality improvement activities. EPA defines quality system requirements for 

ambient air monitoring activities in 40 CFR Part 58 Appendix A. Additionally, EPA's quality 

policy (EPA Order CIO 2105.0) along with grant regulations (40 CFR Part 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 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. 

9 
FINDINGS 

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 of Audit: 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 of the organizational structure, functional 

responsibilities of management and staff, lines of authority, 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 

of the QAPP (February 2013) and conditional approval of the QMP (August 2013). 

References: 

• 40 CFR Part 58, Appendix A, Section 2 

• EPA Requirements for Quality Management Plans, EP A/240/B-0 1/002, 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 of Audit: September 4-6, 2013 

Pro2ram Area(s ): General 

Several procedures were found either not documented or in need of updating. 

Discussion: 

EPA was unable to find AQMD-documented procedures for the following activities: 

• Use of PM 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 of the lab: 

o Receipt of new shipments. 

o Sample deployment and return from the field. 

o Archival and disposal. 

• Use of the 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 specify the following instructions: 

• Cleaning of cassettes. 

• Re-weighing of filters conducted prior to field deployment. 

• Use of anti-static spray when cleaning the weighing area. 

• Action to take if Quarterly Weight Standard Verification, Temperature, or relative 

humidity audits fail. 

• Frequency for conducting temperature and relative 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 of a 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 prior to weighing, whereas section M.2.1.1 #7 states that it should be a 

minimum of three months. 

• Section M.5.1#4 incorrectly references Figure 4 as the Quarterly Weight 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 of 300 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 for Air Pollution Measurement Systems, Vol II: Ambient Air Quality 

Monitoring Program, EPA-454/B-13-003, December 2013. (Section 5) 

Recommendation to Address Findin~: 

AQMD should ensure that all procedures in support of regulatory monitoring are documented 

and up to date. 

13 
3 

Washoe Count AQMD 

Examples of inadequate or incomplete documentation were found. 

Discussion: 

Several instances of inadequate documentation practices were found on a PM2.s Quarterly 

Weight Standard Verification form dated 06/27/13 (Figure 3a). Examples circled in red on the 

form below include: use of scribbling or multiple lines to cross out an entry, illegible 

handwriting, and the use of an 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 for Air Pollution Measurement Systems, Vol II: Ambient Air Quality 

Monitoring Program, EPA--454/B-13-003, December 2013. (Section 5) 

15 
Recommendation to Address Finding: 

AQMD should ensure staff are trained on and practice proper documentation. All audit results 

should be clearly indicated as "PASS" or "FAIL" on relevant forms. 

16 
Steel was found as part of the 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 of the 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 of the 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. 

17 
Discussion: 

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 of this siting 

deficiency at the time of the 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. 

18 
6 

Washoe Count AQMD 

The Galletti site spatial scale for PM measurements was listed as neighborhood despite the 

presence of a nearby minor PM source. 

Discussion: 

During a visit to the Galletti site, EPA found a dirt pile nearby (see picture) that may have 

been impacting the neighborhood-scale PM measurements taken at the site. Given the 

proximity to nearby sources observed at the time of the audit, the middle or micro scales may 

be more appropriate for PM measurements at this location. 

Picture of nearby 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 they pertain to the scale of representativeness per 40 CFR 58, Appendix D, Section 4.6. 

19 
Finding# 7 

Agency: Washoe County AQMD 

Date of Audit: 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 of the 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 of the 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 by AQMD 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, or regional 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 and reflects 

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 of Audit: 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 of updated SOPs are maintained on the server for staff 

access. When EPA asked staff to access SOPs from the field, some were not able to gain 

access. 

References/Guidance: 

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

Monitoring Program, EPA-454/B-13-003, December 2013. (Section 5) 

Recommendation to Address Findin~: 

AQMD should ensure that all staff have access to the most recent electronic or hard copy 

SOPs from the field. 

21 
Finding# 9 

Agency: Washoe County AQMD 

Date of Audit: 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 staff noted that field technicians had not yet received manufacturer training on the 

operation of recently acquired BAM units. This training had been planned for some time in the 

fall of 2013. 

References/Guidance: 

• DRAFT SOP for the Met One BAM -1 020; 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 be provided if maintenance recommendations are 

not adopted. Staff should be trained prior to field deployment of new instruments, whenever 

possible. 

22 
Finding# 10 

Agency: Washoe County AQMD 

Date of Audit: September 4-6, 2013 

Program Area(s): Field Operations 

Finding: 

Some instrument maintenance checks were not being conducted at the recommended schedule. 

Discussion: 

EPA found two examples of instrument 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, EPA recommends a multi-point calibration once per year. 

2. AQMD indicated that cleaning of the Capstan Shaft for BAM units 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 for Air Pollution Measurement Systems, Vo/11: Ambient Air 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 of the 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 County AQMD 

Date of Audit: September 4-6,2013 

Program Area{s): Data Management 

Finding: 

PM filter concentrations and accompanying supporting information is not backed up in a 

timely manner. 

Discussion: 

After weighing PM filters, AQMD field staff compile and generate a data package containing 

concentrations and QA/QC information for the Data Manager to 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 of the audit, the Data Manager had been occupied with 

wildfire response activities and estimated that approximately 3 weeks of data packages had not 

yet been entered. 

References/Guidance: 

QA Handbook for Air Pollution Measurement Systems, Vol II: Ambient Air 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 of Audit: 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 of the 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 BAM unit 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 or poor 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 

had to be taken off-line, due to a shared manifold, during a calibration of a separate 

gaseous instrument. In these cases, use of available 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. 

25 
Finding# 13 

Agency: Washoe County AQMD 

Date of Audit: September 4-6, 2013 

Program Area(s): Data Management 

Finding: 

A significant amount ofPM2.s data was lost during a time of expected high concentrations. 

Discussion: 

EPA found that the PM2.s POC 1 at the Sparks site reported a completeness of 56% for the 

month of January 2013 due to invalidation that occurred because of a failed flow audit 

between 12/31114 to 01/14/14. Data capture during this time of the year is critical for 

implementation of the NAAQS given that higher concentrations are often observed during the 

winter months and around the holidays. 

It is worth noting that AQMD's robust practice of conducting bi-weekly flow checks, rather 

than the minimally required 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 of Audit: 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: 

• Staff were unclear on the types of situations in which to generate a formal corrective 

action using the form. 

• The corrective action form may require a corrective action to be taken within a matter 

of hours, however a time stamp field for the requestor and responder is not specified. 

27 
Corroctivo Action Request \~ '--!!i· 

Part A (to be completed by requestor) 

To: (Sile~lngfruntent Operat;,r} """· i)e.Jey~~ r? A J { ·(l2...,•3 \ 

-J 

Urgency: {chock <Wf.l) 

OE:nargenty (tailuro tiJ taka acliO!llmmc;;ilatoly may· rc~mlt ln ir.jmyc; prop!ll'!y :fAm119et 

~~mmodisfc (4 nourn) 

ourgent(2t hourl:) 

nRoutinf! (7 :Jay;;} 

0Ae, rescuro~ allow 

0For infcrmation only _,--;) . .....--. 00 

From: (Hoq.Jestcr) \,. (f<../'1\ ~ ~~ I \ ·fl,/\ V'V\{? "l~ .. :> 

Prol)totn ldontlllcallon 

Site 

S~'lltem: @{'7;t;_.5.L~.:!:LLc,Ui.Jlt1 0 b C

1

(J Dato· ,., ··t ••• I ·: 

Natur~cfPm'.:-lem: •.. ~ A JJ;(.;t;",?. <J1~·.f· 1 [A..~ : 1 #' ~- .~-~~tt::.;·-~~ 'f(<( ~ .... k,::~<.y;, ~,J ld~::t.ii~~- ..... ~ ~~.:;~5;-;~, as: -r-l...- (l,"" ,,,. 

Reoorr..meneed Aot!Otr ~~~~~ ~ !2L.J~· ·En ~~-lt~ r .r.·l'":.~;·t3· r ~ cr.r j-, z~ ~·A ·J 0 {. '• .,.. ·<'!'lA+ ft.., oi:.lo1/"IC:• f tj ~I ~ I ' 

r'-. ~"") I, '• \I I "C I () .. Signature: ~,J.&-' v~ Dnte ()fl.!.> t ( ;; 

'/ 7 ( 

(f 

Part B (to be cotnpletl:."d by site/instrument operator) 

Problem Resol utlon; 

Date cl'..'frccli\iO ~cti:m taken: I ·I .. - .)~/?.·"> _, ';> 

C::m::;LvoAt:Liun Surt!llli:!lf:, .It'> -r fj,·oJ.(j,-- ,;:i.d! ifcf-- "il tf:o;r.; '1 0·:,;..1..'0 

_(l:~~"!~· ~ {}_._'l} Q(:. :'"'0 -- r.l· t "L- - f~_.,.--:--f!.~#~ 

'2. t. ... :.a -t '"""~c'(•• - f:'\'.,. ... ~ ' -~~~-~-------

-.---~w~-

/1' -::-'"''h:.::~~--" I i S!gntttum: </ • .... ..,.,.."$ .. , DAte: t.?t-1~--:~:;.~;._;? 

.(.. ... ~ l. ,_ ' 

S.:p~rvtsor srgnaLUm: ~~~( _(~ .... ,.."' 11ate; ...... ~. 'i ·'~ ·' ~ 

AQMD Sample Corrective Action Form. 

References/Guidance: 

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

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

Recommendation to Address Finding: 

AQMD should work with staff to identify the 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. 

28 
Findin2 # 15 

A2ency: Washoe County AQMD 

Date of Audit: 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 significantly past their expiration date. These included: 

• Primary Ozone T API 400E (Serial#:607) expired for approximately five months 

between April-September 2011. 

• Audit MFC Environics 6103 (Serial#: 4259) expired for approximately three 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 

Standard ~l$trwmmt Model Serial# Date Completoo ··:--::--- Last Due --· r A4ltual 

PrimaJY Ozone TAPI 4001:': 607 0412.1/10 ~ ..... .L 00130/11 >•M•••>>,••• • ••> 

Audit Ozone Environics 6103 4259 06109111 Jun-12 1·JI21t1T~ 

AudiiMFC Environ icc 6103 4259 08112110 Au~-11 11101111 

F. ow Generol Metals Calibrated or;fice E21 (Juanita) o4122i1o ~-AP'r=11 01/28/11 

Chl,toOk Stteamlne FTS 11110 1.)4/29/10 Apr-11 05103!11 

Chinook swam! nc FTS 117 07130110 Jul·11 05;'23/11 

G]?an Git'brator2 809036 05/13110 :Ytay-11 05t31/11 

Temperature rlux& (oocit} Jf1 ll 17400085 New OtliUU/11 

~ E!!f<.!=. (!~l{\~tio:nt . . ~1A. 17400070 Now 00108/11 

Temperat1retRH Co11trol Compa-,y 61161·:!B·:l 98080162.3 04126110 L~~-11 03i00.111 

Balance (Lab) Smtor!u!; AC-i21S 60805()39 04119110 Apr-11 04f~0/11 

Sartorius MEu5 16210916 04i1Q/10 Apr-11 0!91'20!-11 

Cahn C-2t- C-2Jf/7 04/19/10 Aor-11 04!'20111 

Mas& IPtlmaiy ~~~~~--· 29385 05103/10 May-1 .. 05i11J11 

Primaq_ 29359 05103/10 Ma\1-1' Oti/11/11 I ' 

staoomamcrs Thornas Sciontific 500 ,!C 3620A30 041()1/10 AD!-11 1 --ooK>5/n~-i 

NOx Scrubber Thermo 42C 3~ 03/30/10 l\1ar-11 Of./1 H11 

TAPI 20·JEU 109 0313C/1C r.1ar-11 06/11f11 ·~ '-"""*~"'""-*"'" 

29 
Annual Traceability/Maintenance Schedule 

Standard rnstru•ile•if~·N, __ Modal !Sodal_f! .. { 

Primary ozone TAPI 4031;; I6D7 

>4-" ,, .. ~ 

Aur~it 07.0ne F.rwir(lnir;s 61:13 1425& 

/\uclitMFC Em!ironlcs 6103 14259 

Flow General Metals Calibrated Orifi::e 1:::2~ (Juanila) 

Chinook 

Chinook 

Gillan 

Temperature fluke (aucit) 

Flukn t.vorlfr..ation) 

TemperstureiRH Got~trol Companv 

RatA nee (I ab) S~rtorius 

Sartorius 

Mass Primal)' 

Prim aN 

S1a':icmasters I Thomas Scie:1tific 

NOt. ~=~-b.:".~J~:: Vasala 

Me: one 

References/Guidance: 

StreamlinG F'TS 

Streamline FTS 

Gi lltorator 2 

51 II 

5111 

61161-380 , ..... , 

~[~~~21S 

500mg 

401) Ill-;] 

500uc 

200EU 

?.OOrU 

40 CPR Part 58, Appendix A, Section 2.6 

Recommendation to Address Findin : 

1•110 

1':7 

aogo3s 

l~;:~~: 

.. J980501823 

60805039 

167.10916 

~8539 

72809 

. ~f3620A30 

213 

109 

E023C001 

0566£1 

Year: 2012 

... Date Oon.nl~ed 

last Du!!:. J., Ach1al 

09130/'1 I sev2 I 08/031'12 

1012.1r 1 

10f21/~1 ·~---- g~:}~·~···l~-~~~~~~~li_ 

' o4&6i11 

I 

Apr-12 O!i/33!12 

J 05i03/11 May-12 07/1Sl·l2 

Q5/~3i11 Ma;•-1:2. •JB/30/12 

05l51£1L+·~·!Jiay-12 ~6/~0/12 

09108i'!1 Sep-12 :J9178f'l?. 

0010811 Sep-12 09/2.8112 

<~---~ 

I 06/·J6i11 Jun-12 07.108112 

0412~ Apr-1~ fW10!12 

04!23. Aor-12 04/10112 

NQW o-:!191'2 

New O'.f19!' 2 

05/05/11 MaV'~12 U4/Hll'•2 

05/11/11 May-12 08/01112 

05/11/11 Mav-12 oaro1i12 

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 County AQMD 

Date of Audit: 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 of ambient 

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 and by contractors. 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. 

31 
APPENDIX A: Summary of Findings 

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 of inadequate or incomplete documentation were found. 

Finding 4 (Major): Steel was found as part of the 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 of a nearby minor PM source. 

Finding 7: The middle spatial scale assigned for 03 at the Toll site should be neighborhood scale 

. based on traffic counts available at the time of the audit. 

Finding 8 (Major): SOPs were not always accessible from the field. 

Finding 9: Some recommended instrument maintenance checks were not being 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 of expected 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. 

32 
APPENDIX B: Good Practice Recommendations 

1. Safety rails should be installed on all sides of monitoring sites requiring rooftop access 

and all staff should be trained on how to prevent falls when visiting the rooftop of sites. 

2. Transcription of the same information across various QA/QC forms should be minimized 

wherever possible in order to eliminate redundancies, save time, and decrease the chance 

ofhuman transcription error. Information should still maintain its integrity and be easily 

accessible. Consideration might be given to expanding the use of electronic systems to 

maintain and enter data. 

3. An SOP should be developed for operation of the eBAM unit. 

4. In order to add additional levels of security 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 
t: 

~ l 

u 

L _ltJ 
APPENDIX D: Status of Findings from 9/16/2010 TSA 

Finding Corrective Action 

A. General 

Program 

AI AQMD's Quality Assurance program QAPP was approved by EPA February 

documentation, including the Quality Management 2013 and QMP conditionally approved 

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

Plan (QAPP), was not complete and was not 

approved by EPA at the time of the audit. 

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

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 

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 

AQS. AQS. 

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

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 

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. 

C. Field 

Operations 

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

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. 

35 
C2 Logbooks are not being consistently tracked and A consistent tracking and labeling 

labeled. system was implemented July 2013. 

C3 AQMD's Toll site does not appear to meet The Toll site spatial scale appears to be 

neighborhood scale siting requirements. shifting from year to year. 

C4 The organization ofQA audits and oversight tasks This is now documented in AQMD's 

is not sufficiently documented. approved QAPP. 

D. 

Laboratory 

Operations 

D1 The procedure AQMD uses to test PM blanks is Consistent with EPA guidance, AQMD 

inconsistent with EPA guidance. has started using lot blanks in its testing 

of filter blanks. 

D2 Pre- and post-sample weights are transcribed onto Quality control checks on 10% ofthe 

field sample reports from weigh logs, and are then transcriptions are being conducted as of 

manually entered into excel spreadsheets. July 2013. A revised SOP containing 

this step has been prepared by AQMD. 

E. Data and 

Data Management 

E1 Handwritten changes made in record books and Logbook changes are now initialed and 

log books are not entered in a consistent manner. dated. Documentation practices can still 

be improved. 

F. Quality 

Assurance 

and Quality 

Control 

Fl The ozone audit standard and calibration transfer AQMD has started certifYing both the 

standard reference the same primary standard. primary and audit standards 

independently of one another. 

36