UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX 75 Hawthorne Street San Francisco, CA 94105-3901

Phil McNeely, Director Maricopa County Air Quality Department 1001 North Central Avenue Suite #500

### Phoe~**zona** 85004 

# DeFly: DEC 1 22814

I am writing to transmit the findings from the U
.S
.Environmental Protection Agency's (EPA's) 2013 Technical System Audit (TSA) ofthe Maricopa County Air Quality Department's (MCAQD) ambient air monitoring program. This audit was performed in accordance with 40 CFRPart 58, Section 2
.5, whichrequires that EPA conduct TSAs ofprimary quality assurance organizations every three years. EPA reviewed MCAQD's ambient air monitoring program, including network management, field operations, laboratory operations, quality assurance, and data management procedures
. Generally, we found that MCAQD's air monitoring program is robust and meets EPA requirements. As with any audit, this TSA uncovered some program areas within the agency that can be improved. Your agency has been very responsive to the audit findings and has already begun to address many ofthe findings in the report. 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 Arizona
. Please contact me ifyou have questions, or your staffmay contact Meredith Kurpius at ( 415) 947-4534 or Michael Flagg at (415) 972-3372.

Director, Air Division
Enclosure
cc: Ben Davis, MCAQD

Printed on RecycledPaper

# Technical System Audit Maricopa CountyAir QualityDepartment AmbientAirMonitoring Program September25

- September27, 2013

Air QualityAnalysis Office AirDivision 

## Conducted by
QualityAssurance Office Management and Technical Services Division

US EPARegion 9 75 Hawthorne Street San Francisco, California 94105

Final Report: December 2014

### INDEX
GLOSSARY OFACRONYMS
........................................................................................1 EXECUTIVE SUMMARY
...............................................................................................2 TSAACTIVITIES
.............................................................................................................4 OVERVIEW OFAIRMONITORING PROGRAM
....................................................7 FINDINGS
................................................................................................................11 APPENDIXA: Summary ofFindings
.......................................................................33 APPENDIXB: Organizational Chart
.......................................................................36

11

### GLOSSARY OF ACRONYMS AQAO
..........................................Air Quality Analysis Office AQCD
.......................................... Air Quality Control Department AQS
............................................. Air Quality System CO
................................................CarbonMonoxide CFR
..............................................Code ofFederal Regulations DMS
.............................................Data Management System DQO
.............................................Data Quality Objective EPA
..............................................Environmental Protection Agency FEM
............................................. Federal Equivalent Method FRM
.............................................Federal Reference Method NAAQS
........................................National Ambient Air Quality Standard NATTS
.........................................National AirToxics Trends Stations NBS
..............................................National Bureau ofStandards NCORE
........................................National Core multipollutant monitoring stations NOx/NOy
......................................Nitrogen Oxides 03
..........-....................................... Ozone PCAQCD
..................................... Pinal CountyAir Quality Control District PM
............................................... Particulate Matter PM2.s
............................................ Particulate Matter with aerodynamic diameter<= 2.5 μm PM10
.............................................Particulate Matter with aerodynamic diameter <= 10 μm PQAO
...........................................Primary Quality Assurance Organization QA.
...............................................QualityAssurance QAPP
........................................... Quality Assurance Project Plan QAO
.............................................QualityAssurance Office QC
................................................Quality Control QMP
.............................................Quality ManagementPlan SOP
.............................................. Standard Operating Procedure SLAMS
........................................ State or Local AirMonitoring Station S02
............................................... Sulfur Dioxide STN
.............................................. Specia1ion Trends Network TSA
..............................................Technical System Audit

2EXECUTIVE SUMMARY This document is a report onthe findings ofthe United States Environmental ProtectionAgency (EPA) made during a Technical Systems Audit (TSA) ofthe Maricopa County Air Quality Department (MCAQD) 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 governingthe collection, analysis, validation, and reporting ofambient air quality data
.. This TSAmeets the requirements for EPA audits ofthe MCAQD monitoring organizationrequired by 40 CFRpart 58, appendix A, §2.5. The TSAwas conductedbyEPARegion 9 staffSeptember 25

- 27, 2013. The audit team interviewed management and staffon specific aspects ofthe air monitoring program including network design, field operations, laboratory operations, datahandling, quality assurance and quality control procedures. The auditteam also inspected some ofthe monitoring sites operated by MCAQD. The site inspections consisted ofan interview withthe site operator whenpossible, review ofstation and instrument logbooks, and evaluation ofthe station siting withrespect to EPArequirements. The laboratory inspection included a review ofthe particulate matter (PM) programfor mass determinations ofPM2.s. The TSA is part ofthe system by which EPAprovides oversightto ensure that data collected by state, local, and tribal agencies meetrequired minimum data quality objectives. Other assessments, such as network reviews and performance evaluations, also provide information aboutthe overall quality ofambient 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 ofthe TSA are summarizedhere and fully described inthis report, along with recommended actions to address the findings. The specific actions to be takenby MCAQD will be determined through negotiations with EPA and will be documented in a corrective action planprepared by MCAQD. EPA would like to thank all the staffand management ofMCAQD for their assistance and cooperation during the audit. A. Program Strengths: MCAQD has a robust ambient airmonitoring programthat is generally well-run. Specifically:
• Data completeness for all pollutants is very high.
• The data validation process is divided into a number ofmulti-layered steps that include spatial and statistical evaluations ofthe ambient data.
• Station logbook entries are well maintained and very detailed, and are scanned and available to stafffor data review and validation.

3

### • The Quality Assurance Unit performs independent one-point QC checks for gaseous instruments and flow checks for continuous PMinstruments on a bi-weekly basis, which essentially doubles the amount ofchecks performed on any instrument with an independent standard.
• All staffand management have a high level oftechnical expertise in all aspects of ambient air monitoring and data collection.
• Instrumentation for mobile monitoring and short-term studies is readily available and very well maintained.
B. 

### Program Major Findings: During the TSA, EPA identified areas where MCAQD's monitoring program should be strengthened. The major findings are: 1. MCAQD does not have an approved QMP for ambient air monitoring activities. 2. 

### Adequate oversight ofPM laboratory operations is not being performed. 3. 

### Formal internal audits ofthe air monitoring program activities are not being performed. 

### The individual findings are presented in detail in the topic sections ofthis document and are summarized in Appendix A. It

### has been EPA Region 9's experience that all monitoring programs have areas that could be improved. Unless otherwise noted, EPA's findings are not cause for data invalidation. As stated previously, MCAQD has a robust air monitoring program thatproduces reliable, defensible, valid data for regulatory use.

4TSA ACTIVITIES EPA Region 9 Air Quality Analysis Office (AQAO) and the Region 9 Quality Assurance Office (QAO) conducted a Technical System Audit ofMCAQD's ambient air monitoring program from September 25 to 27, 2013. The TSAreviews one part ofMCAQD'sprogramresponsibility: the collection and analysis ofambient air quality data. The TSA coveredthe following program areas:
• General 

### I Quality Management Program organization Facilities Independent quality assurance and quality control Planning documents (including QMP, QAPPs, & SOPs) General documentationpolicies 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 for PM Routine operations Quality control Laboratory preventive maintenance Laboratory record keeping Laboratory data acquisition and handling Specific pollutants: PM2.s • Data and DataManagement Datahandling Software documentation Datavalidation and correction Dataprocessing Internal reporting External reporting EPAtracked supporting documentation for datapoints from calendar years 2010

- 2012. Michael Flagg ofthe Region 9 Air Quality Analysis Office conducted the TSA. In addition to the EPA Audit Team, Meredith Kurpius, Manager ofthe Air Quality Analysis Office participated in the opening and closing meetings. Participating directors, managers, and supervisors included William Wiley, Director, BenDavis, Air Monitoring Division Manager, Robert Dyer, Monitoring Supervisor, Gary Ensminger, Quality Assurance (QA) Coordinator, and Hugh Tom, QA Officer.

5The findings and recommendations inthis report are grouped byprogram area and listed in priority order. Recommended actions to resolve findings are provided to give some indication of the EPA's expectations as to howthey maybe addressed. IfMCAQD has other approaches or alternatives to address the concerns identified, EPAwill considerthem, provided the corrective action adequately addresses the finding. 

### NetworkManagement EPA interviewed BenDavis and reviewed MCAQD's 2012 Annual Networkplan. MCAQD also submitted a five-year Annual Network Assessment as required by40 CFRpart 58.10. Generally, the monitoring network meets or exceeds the requirements for the minimum number of monitoring sites designated as SLAMS for all ofthe criteriapollutants. 

### Field Operations In addition to BenDavis, EPA interviewed Robert Dyer, Quality Control Operation Unit**Supervi~or.** All staffdemonstrated a thoroughknowledge ofthe monitoring equipment for which they are responsible. EPAvisitedthree monitoring sites (Durango Complex, North Phoenix, West Phoenix). All sites generally meetthe siting criteria of40 CFRpart 58, appendix E, withthe exception ofpotential issues withthe distance to trees at the Durango Complex site. The evaluation included inspection ofthe inlet manifolds, examination ofstation and instrument logbooks, and observation as to whether appropriate Quality Control (QC) checks and QA audits are being performed. All monitoring sites are well organized and maintained. Station logbooks and instrument logbooks are up to date and containrelevant information on operations and maintenance activities. Generally, the site operators are very knowledgeable and maintain a comprehensive understanding ofthe monitoring responsibilities required. 

### Particulate Matter Laboratory EPAvisited the particulate matter (gravimetric) laboratory and interviewed Larry Seals and Hugh Tom. Theparticulate matter laboratory is well maintained and organized. Generally, the PM2.s laboratory measurements reflects MCAQD's high level oftechnical expertise, but increased oversight ofthe PM laboratory operations and better documentation procedures will help to improve the defensibility ofthe data generated bythe laboratory. 

### Data Management EPA reviewed the MCAQD data management system and interviewed Ron Pope and Mike Perkins. Generally, data are handled in a manner that is secure, traceable, and well documented. The datamanagement staffprovide for multiple levels ofdata review on a regular basis, which ensures an excellent level ofdata capture.

6Quality Assurance/Quality Control EPA interviewed Gary Ensminger, Robert Dyer, and Hugh Tom and reviewed the available quality management documents. In addition, EPA collected information about QA/QC activities during interviews ofother sections ofthe technical system. Generally, the MCAQD system conforms to the data quality objectives and/or the systematic planning developed by EPA for criteriapo.llutants. EPA also performs national performance and technical evaluations ofthe monitoring network.



### 7OVERVIEW OF AIR MONITORING PROGRAM General Program 

### MCAQD is the governmental agency delegated under Arizona state law with the authority and responsibility for collecting ambient air quality data in Maricopa County, Arizona as directed by the Clean AirAct 1977 and Clean Air Act Amendments 1990. MCAQD operates ambient monitoring stations in Maricopa County, Arizona and is the Primary Quality Assurance Organization (PQAO) for Maricopa County with the exception ofambient air monitoring stations operated by the ArizonaDepartment ofEnvironmental Quality (ADEQ).
The Air Monitoring Division is managed by Ben Davis, who reports directly to the Director of MCAQCD. The Monitoring Division is further organized into three units: Quality Control Operation Unit, Quality Assessment Unit, and DataManagement Unit. Quality Control Operation Unit staffare responsible for the collection and QC ofambient air monitoring data. The Quality Control Operation Unit is supervised by Robert Dyer, who oversees the operation of monitoring sites, and QC procedures. The Quality Assessment Unit is supervised by Gary Ensminger, who oversees all QA activities, instrument repair, calibrations, and PM lab operations. Hugh Tom serves as the QA Officer, who provides independent review ofboth the QC and QA activities. Quality Management 

### Quality management is the system put inplace to oversee QA, QC and quality improvement activities. EPArequires that ambient air monitoring agencies have a quality management system that conforms to 40 CFRpart 50 Appendix A and EPA's quality policy (EPA Order CIO 2105.0). Additionally, EPA grant regulations specifically require each grantee to provide for QA activities (40 CFRpart 31.45). Specifically, 40 CFRpart 50 Appendix A, §3 requires that each ambient air monitoring Primary Quality Assurance Organization (PQAO) conform to certain quality managementpractices. These include:
• A documented quality system in place that meets EPA requirements for QMPs and QAPPs. • A quality management function that is independent ofair monitoring operations. • Defined Data Quality Objectives (DQOs), or equivalent systematic planning procedures, for all monitoring programs. • Participation inNational Performance Evaluation Programs, which consist of performance audits used to independently determine program adequacy, national monitoring networkperformance, and national consistency. • Participation in Technical Systems Audits by EPA at a frequency ofat least once every three years. • Use ofcertified reference materials to standardize monitoring equipment. EPA views the application of these quality management system components as integral to satisfying federal monitoring program requirements. Insufficient quality management and control
8may undermine the ability of EPA to make NAAQS designation decisions due to data of insufficient or indeterminate quality for program needs. The organization ofthe Monitoring Division divides QA/QC responsibility among units and personnel. For example, the Quality Assessment Unitperforms audits and PM laboratory oversight, the Quality Control Operation Unit performs routine QC, and the DataManagement Unitperforms data validation. 

### NetworkManagement The MCAQD ambient air monitoring networkthroughout Maricopa County consists of 24 SLAMS sites that utilize a variety ofambient air monitors. The following table summarizes the SLAMS sites operated byMCAQCD. Site Name 

## co S02 N02 03 PM10 PM2.s Pb Blue Point x Buckeye x x x x Cave Creek x Central Phoenix x x x x x DeerValley x Durango Complex x x x Dysart x x x FalconField x Fountain Hills x Glendale x x x x Greenwood x x x Higley x Humboldt Mountain x Mesa x x x x North Phoenix x x x x Pinnacle Peak x Rio Verde x South Phoenix x x x x South Scottsdale x x x Tempe x x x x West Chandler x x x West 43rd Avenue x West Phoenix x x x x x Zuni Hills x

9

### Field Operations Field operation duties for monitoring are primarily managed bythe Quality Control Operation Unit with supportfor instrument calibrations and audits bythe Quality AssessmentUnit. Quality Control Operation Unit staffhandle all day-to-day operations, including instrument installation, instrument maintenance, sample collection, quality control activities, and general field site maintenance. Laboratory Operations The gravimetric laboratory operations are performed by Larry Seals, Particulates Lab Specialist. The Quality Assessment Unit's Project Manager/QA Coordinator, Gary Ensminger, oversees laboratory operations. The laboratory is in an enviromnentally controlled room located within MCAQD's main offices. The particulate matter laboratory is responsible for handling filters, which includes preparation, weighing, tracking, and storing PM2.s filters. Data Validation and Data Management Datamanagement involves data collection, data validationprocess, and a data management system, which is maintained by the DataManagement Unit. MCAQD manages continuous data, and dataproduced PM laboratory in AirVision DAS. MCAQD has defined procedures for handling data from the time ofacquisition to the time it is submitted to EPA's Air Quality System (AQS). The procedures are well knownto the principal data providers and reviewers and SOPs are maintained for multiple levels ofdata review. Generally, data management at the MCAQD follows three separate tracks: continuous data (gaseous pollutants and continuous PM10 and PM2.s), and filter based PM2.s data. Continuous Data Continuous data collected at field stations are stored in MCAQCD data loggers and station computers. Each station is polled on a 5-minute and hourly basis and the data are transmitted to the MCAQD AirVision Data Acquisition System (DAS) and backed-up weekly onMCAQD's servers. Quality Control Operation Unit technicians review continuous data from their sites on a daily**~asis.** 

### Mike Perkins ofthe DataManagement Unit also produces a daily surmnary report (Daily Data Quality Assurance: Data Completeness Report), which includes a review ofall the incoming data from operational sites for completeness, missing values, and problematic trends. On a monthly basis, the Data Coordinatorproduces a "Level I" data validation report that is reviewed by the QA Officer. The Level I review includes an assessment ofmissing, negative, or unusual maximum or minimum data and a review ofall QA/QC flags entered by QA and QC technicians. The data coordinator reviews all hardcopy "equipment downtime sheets" against the data in AirVision. The Data Coordinator also performs a "Level II" review, which consists ofa. statistical check ofthe dataset against monthly values ofeach site parameter with historical values and with similar sites with the**s~me** 

### parameter. After final validation and reviewby the QA Officer, data are uploaded from the ADEQ database to the AQS system.

10PMLaboratory Data PM2.s Teflon filters are manually weighed with an electronic Sartorius balance and results are transferred to an Excel spreadsheet on the weigh laboratory computer. These data are then uploaded to a shared drive onthe MCAQD server and uploaded to Sarto Software where itis combined with metadata from the weigh session for review. The data is transferred into Air Vision by the Data Coordinator and follows a similar procedure for the continuous data described above.

11

### FINDINGS Proe:ram Area Findine: Numbers* EPA Contact General 1, 9 M. Flagg Particulate Matter (Gravimetric) Laboratory 2, 5, 7, 8 M.Flagg DataManagement/Data Validation 4 M. Flagg Quality Assurance/Quality Control 3, 6, 10 M. Flagg *Findings are numbered in order ofimportance.

12Finding# 1 Aeencv: MCAQD Date ofAudit: September 25-27, 2013 Proeram Area: General Finding: MCAQD does not have an approved QMP for ambient air monitoring activities. Discussion: EPA requires that organizations develop QAPPs to cover each type ofambient pollutant being measured and a Quality Management Plan (QMP) with policy and program information. The QAPP integrates all technical and quality aspects ofa project, including planning, implementation and assessment. It documents planning activities for collecting environmental data operations and provides project-specific blueprints for obtainingthe type and quality ofenvironmental data needed for a specific decision or use. Finally, it defines the quality assurance and quality control that are applied to environmental data operations to assure the results obtained are ofthe type and quality needed and expected. The QMP, on the other hand, describes program organization, procedures, and policies. Atthe time ofthe audit, MCAQD staffwere working on a completingvarious updates to a draft QMP for EPA review and approval. References: 40 CFRpart 58, appendix A, §2.1 Recommendation to Address Findine: Submit a QMP to EPA for review and approval as soon as possible.

13Findin2 # 2 A!!ency: MCAQD Date ofAudit: September 25-27, 2013 Program Area: Particulate Matter (Gravimetric) Laboratory Findin2: Adequate oversight ofPM laboratory operations is not being performed. Discussion: Multiple layers ofreview ofdata collection activities are critical to establishing an appropriate quality system. The PM laboratory staffare technically under the Quality Assessment Unit, butthe PM laboratory produces data similar to the Quality Control Operation Unit and does not have the same level ofoversight. The Particulates Lab Specialist is responsible for all pre- and post- weighing activities, review ofChain ofCustody (COC) forms, mass standards certification, microbalance QAJQC checks, and is almost single-handedly responsible for data transfer, management, and validation offilter based PM data. Also, the DataManagement Unit does not perform an in-depth or formalized review ofthe data produced by the PM laboratory. For example, data from each PM weigh session are manuallytransferred into a blank spreadsheet or verbally dictated to an audio recording for later data entry. These data are uploaded to another spreadsheet within the Sarto data management software for validation by the Particulates Lab Specialist and saved to the local server without any independent review or verification. The Particulates Lab Specialist is able to override the raw data without any additional oversight or data review. Due to the lack ofoversight, numerous discrepancies existing betweenthe AQS data and the raw data files maintained by the Particulates Lab Specialist could not be resolved. Increased oversight ofall PM laboratory activities by the QA Officer or the DataManagement Unit is needed to ensure the data produced the PM lab meets the same standards as the rest ofthe air monitoring program. References: 40 CFRpart 58, appendixA, §2.2 Recommendation to Address Findin2: Increase the oversight ofall aspects ofPM laboratory activities.

14Findin2# 3 Ae:ency: MCAQD Date ofAudit: September 25-27, 2013 Pro2ram Area: Quality Assurance/ Quality Control Findin2: MCAQD does not perform formal internal audits ofthe air monitoring program activities. Discussion: EPA recommends thatMCAQD perform internal audits as a part ofa robust quality management system. Independent evaluations ofall aspects ofair monitoring activities performed by MCAQD staff or contractors are an important component ofthe agency's overall quality management system. The agency should maintain an independent QA management function that conducts "independent oversight" and assures the implementation ofthe organization's air monitoring program is functioning appropriately. Internal program audits are integral to a QA system. EPA guidance for QMPs states thatthe adequacy ofthe quality system must be assessed at least annually. References: 40 CPR part 58, appendixA, §2.2 EPA Requirements for Quality Management Plans, EPA QA/R-2, March 2001, §3.10 ADEQ Quality Management Plan, August 2010, §9.2 QA Handbook for Air Pollution Measurement Systems, Volume II, EPA-454/b-08-002, §1.2.4 & 1.3.3 Recommendation to Address Findin2: Develop procedures for formal internal audits ofthe air monitoring program.



### 15Finding# 4 Agency: MCAQD Date ofAudit: September 25-27, 2013 Program Area: DataManagement/DataValidation Finding: The data validation process does not include a review ofsystematic criteria. Discussion: EPA recommends validating data using critical, operational, and systematic criteria. Critical criteria must be met for datato be reported as valid to AQS. Operational criteria failures indicate that data may need to be invalidated orflagged. Systematic criteria, which are often related to pollutant specific data quality objective (DQOs), indicate thatthe entire monitoring system should be evaluated. Consistent failures ofany ofthese criteria may cause entire data sets to be questionable. While the MCAQD data validation process includes a comprehensive multi-layered reviewthat ensures that data meet critical and operational criteria, the validation does not consider systematic criteria orthe adequacy ofthe data sets based on these criteria. References: 40 CFRpart 58, appendix A, §2.3 QA Handbook for Air Pollution Measurement Systems, Volume II, EPA-454/b-08-002, §5 & 17 Recommendation to Address Finding: Implement a validation process that considers overall QA/QC performance, specifically a systematic assessment ofwhether pollutant specific DQOs are being met.



### 16Findin2# 5 Ai?:ency: MCAQD Date ofAudit: September 25-27, 2013 Pro2ram Area: Particulate Matter (Gravimetric) Laboratory Findin2: PM laboratory environmental conditioning criteria are not being appropriately checked and documented. Discussion: As there are specific requirements for temperature and RH in the conditioning and weighing environment, a process should be in place to check and document these measurements, particularly in environments where RH can fluctuate dramatically. The MCAQD PM lab does measure temperature and relative humidity in the weigh room and weigh box environments with multiple sensors that are certified annually. While these measurements are being recorded on a continuous basis, the information is not formally documented and retained on the MCAQD server. The temperature and relative humidity fluctuations are only recorded in the lab logbook during the weigh session. There is no documentation oftemperature and humidity during the previous 24 hours nor are they checked priorto the initiation ofa weighing session. As a result, it is difficult to determine whetherthe specific pre- and post- conditioning requirements have been met. References: 40 CFRpart 50, appendix L, §8.2 Quality Assurance Guidance Document 2.12, Monitoring PM2.s in Ambient Air Using Designated Reference or Class I Equivalent Methods, November 1998 Recommendation to Address Findin2: Implement procedures for checking and documenting 24-hourtemperature and relative humidity conditioning criteria.



### 17Finding# 6 Agency: MCAQD Date ofAudit: September 25-27, 2013 Pro2ram Area: Quality Assurance/Quality Control Findin2: Monthly one-point flow rate verifications for filter based PM2.s·FRMs are not performed on the appropriate schedule. Discussion: One-point flow rate verifications are an important quality control measures used to assess the bias of the monitoring data collected. These verifications must be performed at least monthly on each automated or manual low-volume PM2.s instrument. Atthetime ofthe audit, one-point flow verifications for filter based FRMs were performed on a 45-day schedule. References: 40 CFR part 58, appendix A, §2.6, 3.2.3, & 3.3.2 QA Handbook for Air Pollution Measurement Systems, Volume II, EPA-454/b-08-002 Recommendation to Address Finding: Implement monthly one-pointflow rate verifications for filter based PM2.s FRMs in MCAQD's monitoring network.



### 18Finding# 7 Aeencv: MCAQD Date ofAudit: September 25-27, 2013 Program Area: Particulate Matter (Gravimetric) Laboratory Finding: The PM laboratory does not perform regular internal verifications ofthe working weights againstthe primary weights. Discussion: Mass reference standards (orbalance checkweights) should be used to verify proper microbalance operation as pai1 ofnormal QC operations. These standards should be ASTM Class 1 or 1.1, traceable to NIST and should be selected so as to bracketthe maximum and minimum expected filter weights (e.g., 100 to 200 mg). PM laboratory staffshould verifythe mass ofthe working standards every 3 to 6 months or after any incident ofrough handling againstthe primary standard weights and record the certified and measured values ofthese standards on the laboratory data form and inthe laboratory QC notebook ordatabase. Differences between these two values may indicate a problem with the working standards or the microbalance. References: Quality Assurance Guidance Document 2.12, Monitoring PM2.s in AmbientAirUsing Designated Reference orClass I Equivalent Methods, November 1998, §4.3.7, 7.3, 7.9, 10.2.6 Recommendation to Address Findine: Implement appropriate working weight verification schedule and procedures.



### 19Finding# 8 Agency: MCAQD Date ofAudit: September 25-27, 2013 Program Area: Particulate Matter (Gravimetric) Laboratory Finding: The microbalance is not checked against a fonnal set ofindependent weights. Discussion: Internal accuracy assessment ofeach microbalance should be performed on an annual basis. A performance audit ofthe microbalances used to weigh PM2.s filters requires the use ofan independent set Class I standard weights traceable to NIST and must not be the same ones used as working standards for the day-to-day operation ofthe microbalance but may be tr.aceable to the same primary standard used to trace the working standards. The MCAQD PM laborato1y only uses working weights to checkthe performance ofthe balance during a particular weigh session, but does not have formal procedures for audits ofthe microbalance against an independent set ofweights. PM laboratory staffinfonnally checkthe microbalance using small pieces ofglass that have a known weight. These checks should be performed with Class I standards that are traceable to NIST and formally documented in the lab notebook or other relevant forms. References: Quality Assurance Guidance Document 2.12, MonitoringPM2 .s in Ambient Air Using Designated Reference or Class I Equivalent Methods, November 1998, §4.3.7, 7.3, 7.9, 10.2.6 Recommendation to Address Finding: Implement appropriate procedures for annual performance audits ofthe microbalance using Class I standards traceable to NIST that are different from the working standards.



### 20Finding# 9 Agency: MCAQD Date ofAudit: September 25-27, 2013 Program Area: General Finding: Documentation ofsome aspects ofMCAQD ambient air monitoring activities should be improved. Discussion: Accurate and complete documentation is essential for air quality datathat are to be used for regulatory purposes. While the MCAQD maintains adequate documentation ofmost ambient air monitoring activities, some areas need improvement, for example: 

## • Residence times are not calculated on a routine basis. Documentation ofthe calculation of residence time should occur after manifold or probe line maintenance and maintained on site. 

## • In one instance, during data tracking, flow check information was not recorded in the logbook 

## • The monthly level I data reportreview is performed but not documented by the QA Officer via a signature and date sign off. 

## • PMinstrument maintenance (i.e. inlet, down tube, and VSCC cleaning) schedule and documentation are not consistently maintained. 

## • In some instances, the PM filter COC forms were not signed as required References: QA Handbook for Air Pollution Measurement Systems, Volume II, EPA-454/b-08-002 40 CFRpart 58, appendix E, §9(c) Recommendation to Address Finding: Improve documentation practices in the areas identified.



### 21Findin2 # 10 A!!encv: MCAQD Date ofAudit: September 25-27, 2013 Pro2ram Area: Quality Assurance/Quality Control Findin2: One-point QC checks are not being performed at "routine concentrations." Discussion: One-point QC checks mustbe performed at least once every two weeks on each automated analyzer used to measure 03. The QC check is made by challengingthe analyzer with a QC check gas ofknown concentration between 0.01 and 0.10 parts per million (ppm). These ranges allow for appropriate QC check levels for SLAMS sites that may be sampling for different objectives. The QC check concentration used should be relatedto the routine concentrations normally measured at sites within the monitoring network in order to appropriately reflect the precision and bias at these routine concentration ranges. Currently, MCAQD staffperform one-point QC checks for 03 at 0.90 ppm, which is within the allowable range defined by the CFR, but may not reflect "routine concentrations". For MCAQD, all the 03 sites in the monitoring network are SLAMS with the objective ofbeing compared to National Ambient Air Quality Standards (NAAQS). One-point QC checks should be performed at the level a level that captures concentrations relevantto the implementation ofthe current 03NAAQS of0.75 ppm. References: 40 CFR part 58, appendixA, §3.2.1 QA Handbook for Air Pollution Measurement Systems, Volume II, EPA-454/b-08-002 Recommendation to Address Findin2: Implement one-point QC checks at levels that are consistent with the "routine concentration" measured in the area.



### 22APPENDIXA: SUMMARY OF FINDINGS FINDINGS Finding 1: MCAQD does not have an approved QMP for ambient air monitoring activities. Finding 2: Adequate oversight ofPM laboratory operations is not being performed. Finding 3: MCAQD does not perform formal internal audits ofthe air monitoring program activities. Finding 4: The data validation process does not include a review ofsystematic criteria. Finding 5: PM laboratory environmental conditioning criteria are not being appropriately checked and documented. Finding 6: Monthly one-point flow rate verifications for filter based PM2.s FRMs are not performed at the appropriate schedule. Finding 7: The PM laboratory does not perform regular internal verifications ofthe working weights againstthe primary weights. Finding 8: The microbalance is not checked against a formal set ofindependent weights. Finding 9: Documentation ofsome aspects ofMCAQD ambient air monitoring activities should be improved. Finding 10: One-point QC checks are not being performed at "routine concentrations."



### 23

### 24I Data Coordinator

Ron Pope

18566 

### APPENDIX B: ORGANIZATIONAL CHARTS

I Operation Unit Manager Del Hawkins

11563

QC I Department Director BILL WILEY

Division Manager BEN DAVIS

04116

I I Lab Specialist Engineering

Larry Seals Specialist

04128 John Neff

lnsturmentTechnicians Alex Herrera 14702 Bob Dyer

64558 

# - Dan Spiegelberg 61373 Michael Gardner 16488 Thomas Dubishar 13152



### 25 I Projects Manager/QA Coordinator Gary Ensminger 31348

QA lnsturmentTec!:micians Chris Hernandez 16485 Charles Miller 

# - 61355 Thomas Shorb 16489 Reynaldo Santillana I QA Officer Hugh Tom

04127