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 2 2814 

I am writing to transmit the findings from the U.S. Environmental Protection Agency's (EPA's) 

2013 Technical System Audit (TSA) of the Maricopa County Air Quality Department's 

(MCAQD) 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 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 of the findings in the report. 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 of this audit significantly contribute to EPA's overall understanding of ambient 

monitoring in Arizona. 

Please contact me if you have questions, or your staff may contact Meredith Kurpius at ( 415) 

947-4534 or Michael Flagg at (415) 972-3372. 

Director, Air Division 

Enclosure 

cc: Ben Davis, MCAQD 

Printed on Recycled Paper 

Technical System Audit 

Maricopa County Air Quality Department 

Ambient Air Monitoring Program 

September 25 - September 27, 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: December 2014 
INDEX 

GLOSSARY OF ACRONYMS ........................................................................................ 1 

EXECUTIVE SUMMARY ............................................................................................... 2 

TSA ACTIVITIES ............................................................................................................. 4 

OVERVIEW OF AIR MONITORING PROGRAM .................................................... 7 

FINDINGS ................................................................................................................ 11 

APPENDIX A: Summary of Findings ....................................................................... 33 

APPENDIX B: Organizational Chart ....................................................................... 36 

11 
GLOSSARY OF ACRONYMS 

AQAO .......................................... Air Quality Analysis Office 

AQCD .......................................... Air Quality Control Department 

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

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

CFR .............................................. Code of Federal 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 Air Toxics Trends Stations 

NBS .............................................. National Bureau of Standards 

NCORE ........................................ National Core multipollutant monitoring stations 

NOx/NOy ...................................... Nitrogen Oxides 

03 ......... .-....................................... Ozone 

PCAQCD ..................................... Pinal County Air 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. ............................................... Quality Assurance 

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

QAO ............................................. Quality Assurance Office 

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

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

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

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

S02 ............................................... Sulfur Dioxide 

STN .............................................. Specia1ion Trends Network 

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

2 
EXECUTIVE SUMMARY 

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 Maricopa County Air Quality 

Department (MCAQD) 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 MCAQD monitoring 

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

The TSA was conducted by EPA Region 9 staff September 25 - 27, 2013. 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. The audit team also inspected some of the monitoring sites operated 

by MCAQD. 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. The laboratory inspection included a review of the particulate matter (PM) 

program for mass determinations of PM2.s. 

The TSA is part of the system by which 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 

MCAQD will be determined through negotiations with EPA and will be documented in a 

corrective action plan prepared by MCAQD. 

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

cooperation during the audit. 

A. Program Strengths: 

MCAQD has a robust ambient air monitoring program that is generally well-run. Specifically: 

• Data completeness for all pollutants is very high. 

• The data validation process is divided into a number of multi-layered steps that include 

spatial and statistical evaluations of the ambient data. 

• Station logbook entries are well maintained and very detailed, and are scanned and 

available to staff for data review and validation. 

3 
• The Quality Assurance Unit performs independent one-point QC checks for gaseous 

instruments and flow checks for continuous PM instruments on a bi-weekly basis, which 

essentially doubles the amount of checks performed on any instrument with an 

independent standard. 

• All staff and management have a high level of technical 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 of PM laboratory operations is not being performed. 

3. Formal internal audits of the air monitoring program activities are not being performed. 

The individual findings are presented in detail in the topic sections of this 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 that produces reliable, defensible, 

valid data for regulatory use. 

4 
TSA 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 TSA reviews one part ofMCAQD's program responsibility: the 

collection and analysis of ambient air quality data. 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 for PM 

Routine operations 

Quality control 

Laboratory preventive maintenance 

Laboratory record keeping 

Laboratory data acquisition and handling 

Specific pollutants: 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 - 2012. 

Michael Flagg of the Region 9 Air Quality Analysis Office conducted the TSA. In addition to the 

EPA Audit Team, Meredith Kurpius, Manager of the Air Quality Analysis Office participated in 

the opening and closing meetings. Participating directors, managers, and supervisors included 

William Wiley, Director, Ben Davis, Air Monitoring Division Manager, Robert Dyer, 

Monitoring Supervisor, Gary Ensminger, Quality Assurance (QA) Coordinator, and Hugh Tom, 

QA Officer. 

5 
The findings and recommendations in this report are grouped by program area and listed in 

priority order. Recommended actions to resolve findings are provided to give some indication of 

the EPA' s expectations as to how they may be addressed. If MCAQD has other approaches or 

alternatives to address the concerns identified, EPA will consider them, provided the corrective 

action adequately addresses the finding. 

Network Management 

EPA interviewed Ben Davis and reviewed MCAQD's 2012 Annual Network plan. MCAQD also 

submitted a five-year Annual Network Assessment as required by 40 CFR part 58.10. Generally, 

the monitoring network meets or exceeds the requirements for the minimum number of 

monitoring sites designated as SLAMS for all of the criteria pollutants. 

Field Operations 

In addition to Ben Davis, EPA interviewed Robert Dyer, Quality Control Operation Unit 

Supervi~or. All staff demonstrated a thorough knowledge of the monitoring equipment for which 

they are responsible. 

EPA visited three monitoring sites (Durango Complex, North Phoenix, West Phoenix). All sites 

generally meet the siting criteria of 40 CFR part 58, appendix E, with the exception of potential 

issues with the distance to trees at the Durango Complex site. The evaluation included inspection 

of the inlet manifolds, examination of station 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 contain relevant information on operations and maintenance activities. 

Generally, the site operators are very knowledgeable and maintain a comprehensive 

understanding of the monitoring responsibilities required. 

Particulate Matter Laboratory 

EPA visited the particulate matter (gravimetric) laboratory and interviewed Larry Seals and 

Hugh Tom. The particulate matter laboratory is well maintained and organized. Generally, the 

PM2.s laboratory measurements reflects MCAQD's high level of technical expertise, but 

increased oversight of the PM laboratory operations and better documentation procedures will 

help to improve the defensibility of the data generated by the 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 data management staff provide for multiple levels of data review on a regular basis, which 

ensures an excellent level of data capture. 

6 
Quality 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 of other sections of the technical system. Generally, the MCAQD system 

conforms to the data quality objectives and/or the systematic planning developed by EPA for 

criteria po.llutants. EPA also performs national performance and technical evaluations of the 

monitoring network. 

7 
OVERVIEW 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 Air Act 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 of ambient air monitoring 

stations operated by the Arizona Department of Environmental 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 Data Management Unit. Quality Control 

Operation Unit staff are responsible for the collection and QC of ambient 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 of both the 

QC and QA activities. 

Quality Management 

Quality management is the system put in place to oversee QA, QC and quality improvement 

activities. EPA requires that ambient air monitoring agencies have a quality management system 

that conforms to 40 CFR part 50 Appendix A and EPA's quality policy (EPA Order CIO 

2105 .0). Additionally, EPA grant regulations specifically require each grantee to provide for QA 

activities ( 40 CFR part 31.45). Specifically, 40 CFR part 50 Appendix A, §3 requires that each 

ambient air monitoring Primary Quality Assurance Organization (PQAO) conform to certain 

quality management practices. These include: 

• A documented quality system in place that meets EPA requirements for QMPs and 

QAPPs. 

• A quality management function that is independent of air monitoring operations. 

• Defined Data Quality Objectives (DQOs), or equivalent systematic planning procedures, 

for all monitoring programs. 

• Participation in National Performance Evaluation Programs, which consist of 

performance audits used to independently determine program adequacy, national 

monitoring network performance, and national consistency. 

• Participation in Technical Systems Audits by EPA at a frequency of at least once every 

three years. 

• Use of certified 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 

8 
may undermine the ability of EPA to make NAAQS designation decisions due to data of 

insufficient or indeterminate quality for program needs. 

The organization of the Monitoring Division divides QA/QC responsibility among units and 

personnel. For example, the Quality Assessment Unit performs audits and PM laboratory 

oversight, the Quality Control Operation Unit performs routine QC, and the Data Management 

Unit performs data validation. 

Network Management 

The MCAQD ambient air monitoring network throughout Maricopa County consists of 

24 SLAMS sites that utilize a variety of ambient air monitors. The following table summarizes 

the SLAMS sites operated by MCAQCD. 

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 

Deer Valley x 

Durango Complex x x x 

Dysart x x x 

Falcon Field 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 by the Quality Control Operation 

Unit with support for instrument calibrations and audits by the Quality Assessment Unit. Quality 

Control Operation Unit staff handle 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 

Data management involves data collection, data validation process, and a data management 

system, which is maintained by the Data Management Unit. MCAQD manages continuous data, 

and data produced PM laboratory in AirVision DAS. MCAQD has defined procedures for 

handling data from the time of acquisition to the time it is submitted to EPA' s Air Quality 

System (AQS). The procedures are well known to the principal data providers and reviewers and 

SOPs are maintained for multiple levels of data 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 on MCAQD's 

servers. Quality Control Operation Unit technicians review continuous data from their sites on a 

daily ~asis. Mike Perkins of the Data Management Unit also produces a daily surmnary report 

(Daily Data Quality Assurance: Data Completeness Report), which includes a review of all the 

incoming data from operational sites for completeness, missing values, and problematic trends. 

On a monthly basis, the Data Coordinator produces a "Level I" data validation report that is 

reviewed by the QA Officer. The Level I review includes an assessment of missing, negative, or 

unusual maximum or minimum data and a review of all QA/QC flags entered by QA and QC 

technicians. The data coordinator reviews all hardcopy "equipment downtime sheets" against the 

data in Air Vision. The Data Coordinator also performs a "Level II" review, which consists of a. 

statistical check of the dataset against monthly values of each site parameter with historical 

values and with similar sites with the s~me parameter. After final validation and review by the 

QA Officer, data are uploaded from the ADEQ database to the AQS system. 

10 
PM Laboratory 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 on the MCAQD server and uploaded to Sarto Software where it is 

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 

Data Management/Data Validation 4 M. Flagg 

Quality Assurance/Quality Control 3, 6, 10 M. Flagg 

*Findings are numbered in order of importance. 

12 
Finding# 1 

Aeencv: MCAQD 

Date of Audit: 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 of ambient pollutant being 

measured and a Quality Management Plan (QMP) with policy and program information. The QAPP 

integrates all technical and quality aspects of a project, including planning, implementation and 

assessment. It documents planning activities for collecting environmental data operations and provides 

project-specific blueprints for obtaining the type and quality of environmental 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 of the type and quality needed and 

expected. The QMP, on the other hand, describes program organization, procedures, and policies. 

At the time of the audit, MCAQD staff were working on a completing various updates to a draft QMP 

for EPA review and approval. 

References: 

40 CFR part 58, appendix A, §2.1 

Recommendation to Address Findine: 

Submit a QMP to EPA for review and approval as soon as possible. 

13 
Findin2 # 2 

A!!ency: MCAQD 

Date of Audit: September 25-27, 2013 

Program Area: Particulate Matter (Gravimetric) Laboratory 

Findin2: 

Adequate oversight of PM laboratory operations is not being performed. 

Discussion: 

Multiple layers ofreview of data collection activities are critical to establishing an appropriate quality 

system. The PM laboratory staff are technically under the Quality Assessment Unit, but the PM 

laboratory produces data similar to the Quality Control Operation Unit and does not have the same 

level of oversight. The Particulates Lab Specialist is responsible for all pre- and post- weighing 

activities, review of Chain of Custody (COC) forms, mass standards certification, microbalance 

QAJQC checks, and is almost single-handedly responsible for data transfer, management, and 

validation of filter based PM data. Also, the Data Management Unit does not perform an in-depth or 

formalized review of the data produced by the PM laboratory. 

For example, data from each PM weigh session are manually transferred 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 of oversight, numerous discrepancies existing between the AQS data and the raw data 

files maintained by the Particulates Lab Specialist could not be resolved. Increased oversight of all PM 

laboratory activities by the QA Officer or the Data Management Unit is needed to ensure the data 

produced the PM lab meets the same standards as the rest of the air monitoring program. 

References: 

40 CFR part 58, appendix A, §2.2 

Recommendation to Address Findin2: 

Increase the oversight of all aspects of PM laboratory activities. 

14 
Findin2 # 3 

Ae:ency: MCAQD 

Date of Audit: September 25-27, 2013 

Pro2ram Area: Quality Assurance/ Quality Control 

Findin2: 

MCAQD does not perform formal internal audits of the air monitoring program activities. 

Discussion: 

EPA recommends that MCAQD perform internal audits as a part of a robust quality management 

system. Independent evaluations of all aspects of air monitoring activities performed by MCAQD staff 

or contractors are an important component of the agency's overall quality management system. The 

agency should maintain an independent QA management function that conducts "independent 

oversight" and assures the implementation of the organization's air monitoring program is functioning 

appropriately. 

Internal program audits are integral to a QA system. EPA guidance for QMPs states that the adequacy 

of the quality system must be assessed at least annually. 

References: 

40 CPR part 58, appendix A, §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 of the air monitoring program. 

15 
Finding# 4 

Agency: MCAQD 

Date of Audit: September 25-27, 2013 

Program Area: Data Management/Data Validation 

Finding: 

The data validation process does not include a review of systematic criteria. 

Discussion: 

EPA recommends validating data using critical, operational, and systematic criteria. Critical criteria 

must be met for data to be reported as valid to AQS. Operational criteria failures indicate that data may 

need to be invalidated or flagged. Systematic criteria, which are often related to pollutant specific data 

quality objective (DQOs), indicate that the entire monitoring system should be evaluated. Consistent 

failures of any of these criteria may cause entire data sets to be questionable. 

While the MCAQD data validation process includes a comprehensive multi-layered review that ensures 

that data meet critical and operational criteria, the validation does not consider systematic criteria or the 

adequacy of the data sets based on these criteria. 

References: 

40 CFR part 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 of whether pollutant specific DQOs are being met. 

16 
Findin2 # 5 

Ai?:ency: MCAQD 

Date of Audit: 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 of temperature and humidity during the 

previous 24 hours nor are they checked prior to the initiation of a weighing session. As a result, it is 

difficult to determine whether the specific pre- and post- conditioning requirements have been met. 

References: 

40 CFR part 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-hour temperature and relative humidity 

conditioning criteria. 

17 
Finding# 6 

Agency: MCAQD 

Date of Audit: 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. At the time of the 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-point flow rate verifications for filter based PM2.s FRMs in MCAQD's 

monitoring network. 

18 
Finding# 7 

Aeencv: MCAQD 

Date of Audit: September 25-27, 2013 

Program Area: Particulate Matter (Gravimetric) Laboratory 

Finding: 

The PM laboratory does not perform regular internal verifications of the working weights against the 

primary weights. 

Discussion: 

Mass reference standards (or balance check weights) should be used to verify proper microbalance 

operation as pai1 of normal QC operations. These standards should be ASTM Class 1 or 1.1, traceable 

to NIST and should be selected so as to bracket the maximum and minimum expected filter weights 

(e.g., 100 to 200 mg). 

PM laboratory staff should verify the mass of the working standards every 3 to 6 months or after any 

incident of rough handling against the primary standard weights and record the certified and measured 

values of these standards on the laboratory data form and in the laboratory QC notebook or database. 

Differences between these two values may indicate a problem with the working standards or the 

micro balance. 

References: 

Quality Assurance Guidance Document 2.12, Monitoring PM2.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 Findine: 

Implement appropriate working weight verification schedule and procedures. 

19 
Finding# 8 

Agency: MCAQD 

Date of Audit: September 25-27, 2013 

Program Area: Particulate Matter (Gravimetric) Laboratory 

Finding: 

The microbalance is not checked against a fonnal set of independent weights. 

Discussion: 

Internal accuracy assessment of each microbalance should be performed on an annual basis. A 

performance audit of the micro balances used to weigh PM2.s filters requires the use of an 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 of the 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 check the performance of the balance 

during a particular weigh session, but does not have formal procedures for audits of the microbalance 

against an independent set of weights. PM laboratory staff infonnally check the microbalance using 

small pieces of glass 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, Monitoring PM2.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 of the microbalance using Class I 

standards traceable to NIST that are different from the working standards. 

20 
Finding# 9 

Agency: MCAQD 

Date of Audit: September 25-27, 2013 

Program Area: General 

Finding: 

Documentation of some aspects of MCAQD ambient air monitoring activities should be improved. 

Discussion: 

Accurate and complete documentation is essential for air quality data that are to be used for regulatory 

purposes. While the MCAQD maintains adequate documentation of most ambient air monitoring 

activities, some areas need improvement, for example: 

• Residence times are not calculated on a routine basis. Documentation of the 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 report review is performed but not documented by the QA Officer via 

a signature and date sign off. 

• PM instrument 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 CFR part 5 8, appendix E, §9( c) 

Recommendation to Address Finding: 

Improve documentation practices in the areas identified. 

21 
Findin2 # 10 

A!!encv: MCAQD 

Date of Audit: 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 challenging the analyzer with a QC check gas of known 

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 related to 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 staff perform 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 of being compared to National 

Ambient Air Quality Standards (NAAQS). One-point QC checks should be performed at the level a 

level that captures concentrations relevant to the implementation of the current 03 NAAQS of 0. 75 

ppm. 

References: 

40 CFR part 58, appendix A, §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. 

22 
APPENDIX A: SUMMARY OF FINDINGS 

FINDINGS 

Finding 1: MCAQD does not have an approved QMP for ambient air monitoring activities. 

Finding 2: Adequate oversight of PM laboratory operations is not being performed. 

Finding 3: MCAQD does not perform formal internal audits of the air monitoring program activities. 

Finding 4: The data validation process does not include a review of systematic 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 of the working weights 

against the primary weights. 

Finding 8: The microbalance is not checked against a formal set of independent weights. 

Finding 9: Documentation of some aspects of MCAQD ambient air monitoring activities should be 

improved. 

Finding 10: One-point QC checks are not being performed at "routine concentrations." 

23 
24 
I 

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 

lnsturment Technicians 

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 

lnsturment Tec!:micians 

Chris Hernandez 

16485 

Charles Miller 

- 61355 

Thomas Shorb 

16489 

Reynaldo Santillana 

I 

QA Officer 

Hugh Tom 

04127