Technical System Audit 

South Coast Air Quality Management District 

Ambient Air Monitoring Program 

September 24-25, 2013 

Conducted by 

Air Quality Analysis Office Quality Assurance Office 

Air Division Management and Technical 

Services Division 

US EPA Region 9 

75 Hawthorne Street 

San Francisco, California 94105 

Final Report: September 29, 2014 
 

INDEX 

GLOSSARY OF ACRONYMS........................................................................................i 

EXECUTIVE SUMMARY...............................................................................................1 

TSA ACTIVITIES.............................................................................................................3 

OVERVIEW OF AIR MONITORING PROGRAM ....................................................6 

FINDINGS................................................................................................................13 

APPENDIX A: Summary of Findings.......................................................................30 

APPENDIX B: Good Practice Recommendations........................................................31 

APPENDIX C: Organizational Chart.......................................................................32 
i 

GLOSSARY OF ACRONYMS 

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

AQIS.................................Air Quality Instrument Specialist 

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

BAM ............................................Beta Attenuation Monitor 

CA................................................California 

CARB.......................................... California Air Resources Board 

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

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

DQO.............................................Data Quality Objective 

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

EPA..............................................Environmental Protection Agency 

FEM............................................. Federal Equivalent Method 

FID...............................................Flame Ionization Detector 

FRM............................................. Federal Reference Method 

GC................................................Gas Chromatograph (Gas Chromatography) 

ICP-MS ........................................Inductively Coupled Plasma- Mass Spectroscopy 

IO .................................................Inorganic Compendium 

LTE..............................................less than or equal to 

MATES........................................Multiple Air Toxics Exposure Study 

MDL.............................................Method Detection Limit 

MS................................................Mass Spectrometer 

MSD.............................................Mass Selective Detector 

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

NATTS.........................................National Air Toxics Trends Stations 

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

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

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

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

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

PAMS...........................................Photochemical Assessment Monitoring Stations 

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

PE.................................................Performance Evaluation 

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

PM2.5............................................ Particulate Matter with aerodynamic diameter LTE 2.5 μm 

PM10............................................. Particulate Matter with aerodynamic diameter LTE 10 μm 

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

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

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

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

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

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

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

RTI...............................................Research Triangle Institute (EPA Contractor) 

SCAQMD ....................................South Coast Air Quality Management District 

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

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

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

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

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

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

STP...............................................Standard Temperature and Pressure 

TAD .............................................Technical Assistance Document 

TEOM..........................................Tapered Element Oscillating Microbalance 

TO................................................Toxic Organic Compendium 

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

TSP...............................................Total Suspended Particles 

XRF..............................................X-ray Fluorescence 
3 

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 South Coast Air Quality 

Management District (SCAQMD) 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 SCAQMD monitoring 

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

The TSA was conducted by EPA Region 9 staff from September 24-25, 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 two of the monitoring sites and three 

prospective SLAMS near-roadway sites operated by SCAQMD. 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 (40 CFR 58, 

Appendix E). The laboratory inspection included a limited review of the particulate matter (PM) 

program for mass determinations of PM10 and PM2.5 and Pb-TSP analysis. As this TSA was 

completed in two days, it was focused in scope while still exceeding the TSA requirements in 40 

CFR 58 Appendix A. As timing, resources, and needs dictate, EPA will tailor the scope and 

duration of TSAs accordingly. 

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 SCAQMD will 

be documented in a corrective action plan prepared by SCAQMD. 

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

cooperation during the audit. 

A. Program Strengths: 

SCAQMD management and staff are extremely knowledgeable. They are working on systems to 

address the highest priority issues first, and have improved communication and collaboration 

between Quality Assurance, Atmospheric Measurements, and the Laboratory management and 

staff. SCAQMD demonstrates an overall, collective understanding of how individual 

responsibilities fit together to produce defensible, quality data, which is resulting in better 

recognition of significant issues and stronger Quality Assurance (QA) across the board. 
4 

B. Program Major Findings: 

During the TSA, EPA identified areas where SCAQMD’s monitoring program should be 

strengthened. The major findings are: 

- SCAQMD is not evaluating or implementing potential short-term fixes for existing siting 

issues in some instances. 

- SCAQMD continues to face challenges covering all activities associated with producing 

quality data due to staff turnover, unfilled positions and increased responsibilities. 

- The SCAQMD Photochemical Assessment Monitoring Stations (PAMS) program does 

not have an approved Quality Assurance Project Plan (QAPP). 

- The QA program oversight of all data-related activities is narrow and not applied 

consistently. Overall documentation procedures are not completely articulated and 

SCAQMD lacks a process for updating and implementing Standard Operating Procedures 

(SOPs). 

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, SCAQMD has a robust air monitoring program that produces reliable, defensible, 

valid data for regulatory use.
5 

TECHNICAL SYSTEM AUDIT ACTIVITIES 

From September 24-25, 2013 the EPA Region 9 Air Quality Analysis Office (AQAO) and 

Quality Assurance Office (QAO) conducted a Technical System Audit of SCAQMD’s ambient 

air monitoring program. The TSA reviews one part of SCAQMD’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 / 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 / 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: PM10, PM2.5, Toxics, PAMS, and Lead 

· 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 year 2012. 

The EPA TSA was conducted by Gwen Yoshimura (AQAO) and Mathew Plate (QAO). 

Meredith Kurpius and Eugenia McNaughton, managers of the AQAO and QAO, respectively, 

participated in the opening and closing meetings. 
6 

Participating managers and supervisors of the SCAQMD Air Quality Assessment Section 

included Philip Fine, Rudy Eden, Jason Low, Andrea Polidori, Solomon Teffera, Steve Barbosa, 

and Rene Bermudez. 

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 SCAQMD’s Air Monitoring Program. 

· Findings – collection of positive, major, minor findings, and recommendations that 

includes details associated with each finding. 

· Appendix A – summarized list of findings with priority ranking. 

· Appendix B – SCAQMD organizational chart. 

The Findings section includes positive findings and those that require corrective action. They are 

grouped by program area. Recommendations to resolve findings are provided for each one that 

requires corrective action to give some indication of EPA expectation as to how they may be 

addressed. If SCAQMD has other approaches or alternatives to address the concerns identified, 

EPA will consider them, provided the corrective action adequately addresses the finding. 

Appendix A is a summarized list of findings excluding positive findings, listed according to 

priority. Higher priority findings are those that: (1) are over-arching issues, (2) have a greater 

impact on regulatory decisions, and/or (3) affect data quality. All findings should be addressed in 

a corrective action report. 

General 

For this TSA, the audit team interviewed management and staff, focusing 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 management 

and staff from Atmospheric Measurements, including Operations, Support, Data Management, 

and Special Monitoring, as well as management and staff from the Quality Assurance Branch 

and the Laboratory, and reviewed SCAQMD’s procedures, quality assurance documents, 

performed data tracking, and reviewed findings from the previous TSA conducted in 2010. 

Network Management 

EPA interviewed SCAQMD, including Jason Low, Andrea Polidori, Rene Bermudez, and 

reviewed SCAQMD’s July 2013 Annual Network Plan. SCAQMD also submitted a five-year 

Annual Network Assessment in July 2010 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 State or Local Air Monitoring Station 

(SLAMS) for all of the criteria pollutants. 
7 

Field Operations 

In addition to those individuals previously mentioned, EPA interviewed several Air Quality 

Monitoring Unit staff. All staff demonstrated a thorough knowledge of the operation of the 

monitoring equipment for which they were responsible. 

EPA visited Crestline (AQS ID 06-071-0005), South Long Beach (06-037-4004), the prospective 

new near roadway monitoring site at Etiwanda Ave. off the I-10 West in the Riverside-San 

Bernardino-Ontario MSA, and the prospective sites in Anaheim off the I-710 E at Long Beach 

Boulevard in the Los Angeles-Long Beach-Santa Ana MSA. 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 

and QA audits were being performed. See findings A1 and C2 for additional comments about 

monitor siting. EPA also notes that the Crestline and South Long Beach station operators 

maintained well-organized, clean station with high-quality documentation, and tracking of 

typical site operation, issues and resolutions. 

Laboratory Operations 

Particulate Matter Laboratory (Gravimetric Laboratory) 

EPA visited the particulate matter (gravimetric) laboratory and interviewed Steve Taw and 

Solomon Teffera. SCAQMD recently lost the person whose responsibility it was to weigh the 

PM2.5 filters. Current staff are quickly coming up to speed, however, it is difficult to trace certain 

void or QA qualifier codes entered earlier. This issue highlights the importance of clear 

procedures and documentation. 

EPA also interviewed Yang Song, the interns responsible for filter processing, and Sandra Hom 

about Pb-TSP data processing. The Pb-TSP sample handling, processing and analysis was well 

run. 

Data and Data Management 

This section covers data management for criteria pollutants (O3, CO, NO2, SO2, PM2.5, PM10, and 

Pb). Brian Vlasich and Michael Hamdan were interviewed. SCAQMD collects a large amount of 

data each day. The data validators are doing an exceptional job of working to find areas where 

the process, including documentation, could be improved. The level of understanding of the 

entire system and ability to identify and investigate possible reasons for data issues was most 

impressive. While data tracking showed that improvements could be made, SCAQMD is doing 

well considering how few staff are performing data validation in relation to the large volume of 

data to be processed. 
8 

Quality Management 

EPA interviewed Andrea Polidori and Raul Dominguez and reviewed quality management 

documents. In addition, EPA collected information about Quality Assurance and Quality Control 

(QA/QC) activities during interviews of other sections of the technical system. 

 
9 

OVERVIEW OF AIR MONITORING PROGRAM 

General Program 

Federal and California State laws require that clean air standards be met and maintained 

throughout the nation and the State of California. Authority and responsibility for air quality 

monitoring has been delegated to SCAQMD by the US EPA pursuant to the Clean Air Act of 

1977 and the Clean Air Act Amendments of 1990. The SCAQMD is defined in the California 

Health and Safety Code, Division 26, Air Resources, Section 40412 as the “Sole and exclusive 

agent having responsibility for air pollution control within the District.” The State defines the 

geographic extent of the SCAQMD as “portions of Counties of Los Angeles, Orange, Riverside, 

and San Bernardino included within the area of the South Coast Air Basin, as described in 

Section 60104 of the Title 17 of the California Administrative Code.” 

The SCAQMD currently has 40 active monitoring stations for criteria pollutants. The criteria 

pollutants measured include: 

· Carbon Monoxide (CO) 

· Nitrogen Dioxide (NO2) 

· Sulfur Dioxide (SO2) 

· Lead (Pb) 

· Ozone (O3) 

· Particulate Matter (PM10 and PM2.5) 

Barry Wallerstein is the SCAQMD’s Executive Officer. Matt Miyasato, Deputy Executive 

Officer, heads the Science & Technology Advancement Division. At the time of the TSA, Philip 

Fine was the Assistant Deputy Executive Officer, leading the Monitoring & Analysis subDivision, which is the primary organization in Science & Technology Advancement responsible 

for air monitoring. The Monitoring & Analysis group has three functional areas (branches): 

Laboratory Services & Source Test Engineering (Rudy Eden, manager), Atmospheric 

Measurements (Jason Low, manager), and Quality Assurance (Andrea Polidori, manager). 

Atmospheric Measurements (Monitoring), Laboratory Services & Source Test Engineering 

(Laboratory), and Quality Assurance (QA) each have a role in the collection and evaluation of 

ambient air data as defined by the SCAQMD Quality Management Plan (QMP). The Monitoring 

group is responsible for most of the ambient air data collection, including sampling and data 

processing of continuous air monitors. The Laboratory is responsible for preparation of sampling 

media, analysis of analytical samples from the non-continuous monitors, and processing of data 

from these samples. Both groups are responsible for implementing routine QA/QC procedures. 

The QA group is responsible for tracking and oversight of training, corrective actions, and data 

handling. The QA group also implements performance and technical audits and coordinates and 

participates in the preparation of QA planning documents. 
10 

Network Management 

The SCAQMD ambient air monitoring network currently consists of 40 State/Local Air 

Monitoring Stations (SLAMS) plus several source oriented lead monitors, special studies and 

Special Purpose Monitoring (SPM) sites that utilize a variety of air pollutant measuring 

instruments. The following table summarizes the SLAMS sites in the SCAQMD. 

 
11 

Table 1: Air Monitoring Sites in the SCAQMD (Source: SCAQMD 2013 Air Monitoring 

Network Plan) 

Station O3 CO SO2 NO2

PM2.5

FRM

PM10

FRM

PM2.5

Cont.

PM10

Cont. TSP 

Anaheim X X X X X X X 

ATSF (Exide) X 

Azusa X X X X X X 

Banning X X X X 

Big Bear X 

Burbank X X X X X X X X 

Closet World (Quemetco) X 

Compton X X X X X 

Costa Mesa X X X X 

Crestline X X X 

Fontana X X X X X X X 

Glendora X X X X X 

Indio X X X X 

La Habra X X X 

Lake Elsinore X X X X X 

LAXH X X X X X X 

Long Beach (North) X X X X X X X X X 

Long Beach (Hudson) 

Los Angeles X X X X X X X X X 

Mira Loma (Van Buren) X X X X X X X 

Mission Viejo X X X X 

Norco X 

Ontario F.S. X X 

Palm Springs X X X X X X 

Pasadena X X X X X 

Perris X X 

Pico Rivera X X X X X 

Pomona X X X 

Redlands X X 

Rehrig (Exide) X 

Reseda X X X X X 

Riverside-Magnolia X X X X X X 

Rubidoux X X X X X X X X X 

San Bernardino X X X X X X X 

Santa Clarita X X X X X 
12 

So. Long Beach X X X X 

Temecula X 

Uddelholm (Trojan) X 

Upland X X X X X X 

West L.A. X X X X 

SCAQMD also operates several sites for the following SPM projects and source-oriented lead 

sampling: 

· Multiple Air Toxics Exposure Study (MATES) IV 

· Pb at Exide: Rehrig in Vernon, and ATSF in City of Commerce 

· Pb at Quemetco (Closet World) in City of Industry 

· Pb at Trojan Battery (Uddelholm) in Santa Fe Springs 

In addition, SCAQMD operates a network of air toxics stations, including National Air Toxics 

Trends Stations (NATTS) at the Los Angeles (Main) and Rubidoux sites. This audit addressed 

air toxics activities that support the NATTS, including both field and laboratory operations. 

These two sites are also designated as National Core (NCore) multi-pollutant monitoring sites. 

SCAQMD operates a network of Photochemical Assessment Monitoring Stations (PAMS). The 

PAMS network consists of seven sites. LAX/Hastings is a Type 1 (upwind, background, and 

transport) PAMS site; Azusa, Burbank, Los Angeles (Main), and Pico Rivera are Type 2 

(maximum precursor emission/central business district) sites; Rubidoux and Santa Clarita are 

Type 3 (maximum O3 concentration) sites. EPA has approved the SCAQMD’s PAMS network, 

operating schedule and forecasting scheme. 

Field Operations 

Field operations are performed by the Atmospheric Measurements Division, which is managed 

by Jason Low. This division is divided into two work groups: Ambient Monitoring and Special 

Monitoring. Routine ambient monitoring is conducted by the Ambient Monitoring Group. The 

Special Monitoring Group undertakes special projects and seasonal monitoring as needed. The 

Ambient Monitoring Group is subdivided into Operations, Support, and Data Management 

sections. Day-to-day monitoring station operations are performed by the Operations section, 

which has sub-sections. Each sub-section has at least one Senior Air Quality Instrument 

Specialist (AQIS) and five AQISs. Repairs and calibrations are performed by AQISs in the 

Support section. 

Laboratory Operations 

Analytical laboratories provide support for measurement methods that are either too complex or 

too sensitive to perform in the field. In order to provide these services, the laboratories have 

specialized instrumentation and employ staff specifically trained in their use. 
13 

For ambient air samples to provide useful information or evidence, laboratory analyses must 

meet the following basic requirements: 

1. The laboratory must maintain a suitable facility for sample receipt, storage, analysis, and 

reduction and storage of data. 

2. The laboratory must have sufficient and appropriate equipment that must be calibrated and 

maintained frequently. 

3. The laboratory must have an adequate number of qualified staff. 

4. Analytical procedures must be in accordance with official guidance, EPA methods and 

accepted practice. 

5. Complete and accurate records must be kept. 

SCAQMD has a clean, modern, expansive laboratory facility located at its headquarters office in 

Diamond Bar, California. The laboratory supports the many chemical analyses necessary to 

understand a large complex air basin and its diverse source mix. One of the primary 

responsibilities of the laboratory is the handling of PM filters, which includes preparation, 

weighing, tracking and storing of PM2.5, PM10 and total suspended particle (TSP) filters. In 

addition to PM responsibilities, the laboratory is also responsible for the analyses of Speciation 

Trends Network (STN), PAMS, NATTS and special projects samples collected by SCAQMD, 

including samples collected for the Multiple Air Toxics Exposure Study (MATES) series. The 

compounds SCAQMD routinely analyzes for include: 

· PAMS VOCs (SCAQMD SOP00007: “Standard Operating Procedure for TO-14”) 

· NATTS VOCs (SCAQMD SOP00008B: “Standard Operating Procedure for TO-15”) 

· PAMS and NATTS Carbonyls (SCAQMD SOP00006: “Determination of Carbonyl 

Compounds Using Waters 600E High Pressure Liquid Chromatograph and 996 

Photodiode Array Detector”) 

· STN PM2.5 metals by X-ray Fluorescence (XRF) (SCAQMD SOP 00004: “Analysis of 

PM2.5 Filter Samples by Energy dispersive X-Ray Fluorescence spectrometry”) 

· NATTS PM10 metals by Inductively Coupled Plasma-Mass Spectroscopy (ICP-MS) 

(SCAQMD SOP 00005: “Determination of Metals in Ambient Particulate Matter by 

Inductively Coupled Plasma - Mass Spectrometry”) 

· TSP-Pb by ICP-MS (SCAQMD SOP 00005: “Determination of Metals in Ambient 

Particulate Matter by Inductively Coupled Plasma - Mass Spectrometry”) 

· NATTS Acrolein (SCAQMD SOP00008B: “Standard Operating Procedure for TO-15”) 

· NATTS Hexavalent Chromium by ion chromatography (SCAQMD SOP 0046: “Analysis 

of Hexavalent Chromium in Ambient Air by Ion Chromatography”) 

· STN PM2.5 Anions (SCAQMD SOP 00003 “Analysis of PM2.5 filters for Anions by Ion 

Chromatography”) 

There are a number of additional activities the laboratory undertakes to support the collection 

and analysis of air pollutants. These include canister cleaning and preparation, data validation 

and sample storage. 
14 

Particulate Matter Laboratory (Gravimetric Laboratory) 

SCAQMD possesses a PM dedicated humidity and temperature controlled gravimetric laboratory 

(weighing room) located south of the main laboratory. All filter conditioning and weighing takes 

place in this weighing room. Humidity and temperature for the room are computer controlled, 

accessed, control charted, and recorded during each weighing session. The temperature and 

relative humidity meet the requirements contained in the EPA Reference Quality Assurance 

Handbook for Air Pollution Measurement Systems, Volume II, May 2013. 

Toxicology Laboratory 

SCAQMD toxics analyses, such as those performed in support of the NATTS Program, are 

conducted at the main agency laboratory. This approximate 20,000-square-foot laboratory has 

room ventilation meeting a minimum of six air changes per hour, with good air distribution and 

has a slightly negative pressure (a minimum of 100 cubic feet per minute per door) relative to 

hallways and other non-laboratory areas. Toxics analyses are performed on six of 16 benches 

adjacent to three fume hoods within the main laboratory (two benches each for gas 

chromatography–mass spectrometry (GCMS), high performance liquid chromatography (HPLC), 

and gas chromatography-flame ionization detection (GCFID) analyses). In addition, a small room 

containing one PAMS canister cleaning and two NATTS canister cleaning ovens is accessed from 

the main laboratory. 

Data and Data Management 

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

system. Data management at SCAQMD follows two separate tracks: one for continuous (i.e., 

non-laboratory) data and one for laboratory data. 

SCAQMD has defined procedures for handling data from the time of acquisition to the time it is 

submitted to the EPA Air Quality System (AQS). The procedures are well known to the principal 

data providers and reviewers. Responsibility for managing ambient monitoring data is divided 

between the Atmospheric Measurements Branch operators, data validators, and Senior and 

Principal AQISs. 

The Quality Assurance Manager records and documents activity associated with QA audits and 

evaluation results to a Quality Assurance Alert Log, AQS Event Flag Summary, and Corrective 

Action Request Log. These reports are incorporated into the review processes of Atmospheric 

Measurements and the Laboratory. 

SCAQMD has four separate data management and validation processes in place for different data 

streams reported to AQS. Atmospheric Measurements handles continuous monitoring data while 

the laboratory conducts these processes using three data streams: 1) filter-based PM2.5; 2) filterbased PM10, TSP, Pb, and non-NAAQS metals; and 3) organic analyses. 
15 

Continuous Monitoring for Gaseous Pollutants and Particulates 

Continuous analyzer air quality data collected at field stations are stored in SCAQMD data loggers 

and station computers. Each station is polled minute-by-minute and the data are transmitted to 

SCAQMD’s central computer database. Electronic chart recorders (Eurotherm Chessels) located 

at each station serve as a back-up system and provide a supplemental record for data validation. 

Data may also be transferred manually using various devices, including laptop computers and flash 

drives. 

SCAQMD performs four levels of validation for continuous data. The station data loggers and 

the FORTRAN-based data system perform automated checks. Also, FORTRAN automatically 

reviews data completeness and backfills any missing hourly data-points on a monthly basis. 

FORTRAN is an additional backup data source that can be used if the main data acquisition 

system (DAS) fails at any point. Field Operation staff review data and recommend flags. Data 

validators review quality control parameters. Data validators then evaluate data in relation to 

concurrent, corresponding data sets. 

Data Flow Diagram for continuous data: 
16 

Laboratory Data Systems: Filter-Based PM2.5 Particulate Monitoring; Monitoring of Lead and 

non-NAAQS Metals; and Monitoring of Organic Compounds 

The laboratory uses a Promium Element® LIMS Data System, put in operation in January 2010. 

Data for each analyzed sample is exported into the LIMS database. Laboratory analytic data is 

combined with field data in the LIMS, where it is reviewed by a Senior AQ Chemist who also 

reviews chain of custody sheets, investigates and flags missing data, investigates and flags data 

outliers, flags data for exceptional events, and produces quarterly reports and a pipe delimited text 

document that is submitted to AQS. Sample information is recorded on sample logs, chain of 

custody sheets, sampler printouts, and sampler digital outputs and transferred to the laboratory 

LIMS database (SOP00108). The LIMS database also tracks prepared samples, samples deployed 

to the field, and samples returned and awaiting analysis. PM data is processed, verified and 

validated according to SOP00121. 

Data Flow Diagram for Filter-Based data: 

Quality Management 

Quality management is a system for overseeing quality assurance (QA), quality control (QC) and 

quality improvement activities. EPA requires that ambient air monitoring agencies receiving 

federal funding have a quality management system that conforms to 40 CFR 50 Appendix A and 

the EPA quality policy (EPA Order CIO 2105.0). Additionally, EPA grant regulations require each 

grantee to provide for QA activities (40 CFR 31.45). Specifically, 40 CFR 50 Appendix A, §3 

requires that each ambient air monitoring Primary Quality Assurance Organization (PQAO) 

conforms to certain quality management practices including: 
17 

· A documented quality system that meets EPA requirements for Quality Management Plans 

(QMPs) and Quality Assurance Project Plans (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 

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

insufficient or indeterminate quality for program needs. 

SCAQMD has a well-defined quality management system that includes a quality management plan 

(QMP) and oversight by an independent quality assurance manager and robust audit program. 

SCAQMD has a QA group (QA Branch) led by a QA Manager, Andrea Polidori, having 

organizational parity with the Ambient Monitoring and Laboratory Managers. Two staff members 

report directly to the QA Manager; a QA Senior AQ Instrument Specialist responsible for field 

auditing and a QA Senior AQ Chemist responsible for laboratory QA activity as well as tracking 

of P&A documentation. The QA group also manages a support contract to perform additional 

QA/QC audits of the monitoring network. 

EPA regulations require independent performance audits of gaseous pollutants and flow audits of 

PM2.5 and PM10 air samplers and monitors. For gaseous pollutants, regulation requires that 25% 

of each pollutant monitoring network be audited per calendar quarter, thus ensuring that each 

instrument is audited once per year. Prior to 2007, flow audits of these monitors were also required. 

Additionally, quarterly independent flow audits of PM2.5 samplers were required. Beginning in 

calendar year 2007, semi-annual flow audits of each PM2.5, PM10, and TSP sampler were required 

(40 CFR, Part 58, Appendix A, Sections 3.2.4 and 3.3.3.). This is in addition to the required 

monthly flow evaluations as per 40 CFR, Part 58, Appendix A, Sections 3.2.3 and 3.3.2. 

The Quality Assurance Branch is responsible for conducting required gaseous pollutant audits as 

well as PM10 and PM2.5 flow audits. An independent contractor performs flow audits of filter-based 

samplers and provides audit results to the QA Branch and site operators. This same contractor also 

performs meteorological audits. 
18 

FINDINGS 

Program Area Finding Numbers EPA Contact 

General 

A1, A2, A3, A4, A5 (positive), A6 

(positive) 

A1, A2 – Gwen Yoshimura 

A3, A4 – Mathew Plate 

Network Management None 

Field Operations C1, C2, C3 Mathew Plate 

Laboratory Operations D1, D2, D3 

D1, D2 – Mathew Plate 

D3 – Gwen Yoshimura 

Data and Data 

Management E1 (EPA-directed) Gwen Yoshimura 

Quality Management F1, F2 Mathew Plate 

 
19 

Finding # A1 

Agency: SCAQMD 

Date of Audit: September 24-25, 2013 

Program Area: General 

Finding: 

SCAQMD is not evaluating or implementing potential short-term fixes for some of the 

existing siting issues. 

Description: 

During the TSA it was apparent that SCAQMD was aware of siting issues at some of their 

stations. Their auditors were not consistently documenting these issues, and while long-term 

solutions were contemplated, the data were not being flagged in the meantime. It is therefore 

unclear how SCAQMD’s planning group and other data users would know that the data may 

need to be qualified. South Long Beach and Pomona are two sites that are known to have 

problems. 

SCAQMD is in the process of evaluating long-term siting issues as part of the 5-year network 

assessment process. This process will help SCAQMD to develop a plan to correct these issues 

in the future. 

References: 

40 CFR part 58, appendix E 

Recommendation to Address Finding: 

1. Siting issues should be consistently documented, whether or not they have been 

documented in previous audits or if there is a plan in place to address them in the 

future. 

2. The QA group should evaluate siting of each existing monitoring station, taking new 

measurements, and performing independent siting evaluations. 

3. When siting issues arise, SCAQMD should: 

· Determine how to address the issue 

· Document the siting issues in the annual network plan 

· Based on its extent, determine for which regulatory decisions the data should not be 

used, if any. 

· Determine how to address previously collected and currently collected data. 

Possible approaches might be to request a siting waiver from EPA, include a data 

qualifier code in AQS, or invalidate the data. 

· If there is a long-term solution, consider developing a contingency plan in case it is 

delayed or does not occur. 
20 

Finding # A2 

Agency: SCAQMD 

Date of Audit: September 24-25, 2013 

Program Area: General 

Finding: 

Staff turnover, unfilled positions and increased responsibilities may result in loss of data or 

compromised data quality. 

Description: 

SCAQMD has very capable, knowledgeable management and staff. Recently, they have had a number 

of retirements and lost staff in critical positions. While the organization covers normal operations 

adequately, resources are not currently sufficient to manage additional needs (e.g., new projects, new 

requirements such as EPA Near Roadway monitoring, instrument repair, troubleshooting DMS, etc). 

Some examples were noted where the lack of additional staff might impact data quality: 1) SCAQMD 

is behind in submitting data to AQS; 2) an instance was found where data that did not automatically 

upload was not backfilled; 3) key staffing vacancies in the laboratory hindered process flow; 4) some 

data validation is not currently reviewed. 

SCAQMD recognizes this challenge and is addressing it by prioritizing the most critical positions to be 

filled. They also prioritize the order in which monitoring issues are addressed. While this is a logical 

and appropriate solution given the existing resource constraints, it should be noted that additional staff 

would allow SCAQMD to maintain normal functions as well as address new issues and requirements 

as they arise, instead of having to choose which resources to allocate where and deferring or not 

addressing some program elements. SCAQMD plans to fill critical vacancies in the Air Monitoring 

group in 2014, including three Senior Chemist positions that have been recently approved. Also, 

SCAQMD is in the process of recruiting both an AQIS I and AQIS II position within the Air 

Monitoring group. As changes in staffing, resources, and workload shift, SCAQMD should continue to 

evaluate whether adjustments to the air monitoring program, such as site consolidation, are necessary 

to align workload with available resources. 

References: 

EPA Requirements for Quality Management Plans, EPA QA/R-2, EPA/240/B-01/002, March 2001, 

Section 3.2 

SCAQMD Quality Management Plan for Environmental Measurement Program, January 2009, Section 

3.2 

40 CFR part 58.16 Data submittal and archiving requirements. 

Recommendation to Address Finding: 

1. Fill key positions and obtain more resources when possible. 

2. SCAQMD should evaluate whether there are options to improve efficiency and/or reduce 

workload. For example, low priority or redundant sites/monitors could be closed or sampling 

schedules adjusted to reduce the resource burden. 
21 

Finding # A3 

Agency: SCAQMD 

Date of Audit: September 24-25, 2013 

Program Area: General 

Finding: 

SCAQMD does not have an approved QAPP for PAMS monitoring. 

Description: 

All required QAPPs have been submitted by SCAQMD except PAMS (2010 TSA finding A1). 

All environmental measurements funded by EPA require an approved QAPP. Because EPA 

has been working with state and local agencies to “reinvent” the PAMS program over the last 

several years, SCAQMD has been hesitant to develop a PAMS QAPP. However, if SCAQMD 

has very specific programmatic needs for PAMS data, a District-specific program and QAPP 

that addresses data needs and anticipates programmatic changes would be appropriate. 

The data quality objectives developed in the QAPP should dictate the level of quality control 

needed, especially where there are deviations from the PAMS Technical Assistance Document 

(TAD) (2010 TSA finding D3). 

References: 

“Technical Assistance Document for Sampling and Analysis of Ozone Precursors”, EPA/600-

R-98/161, September 1998 

40 CFR parts 31 and 35 

40 CFR 58, appendix A, §2.1. 

“EPA Requirements for Quality Management Plans (QA/R-2)”, EPA/240/B-01/002, March 

2001. 

“EPA Requirements for QA Project Plans (QA/R-5)”, EPA/240/B-01/003, March 2001 

Recommendation to Address Finding: 

SCAQMD should develop a PAMS QAPP that reflects the work currently being performed. 

If SCAQMD has specific programmatic needs, the QAPP could be used to develop a 

District-specific program. 

 
22 

Finding # A4 

Agency: SCAQMD 

Date of Audit: September 24-25, 2013 

Program Area: General 

Finding: 

Documentation procedures for logbooks and forms should be improved. 

Description: 

SCAQMD does a relatively good job of documenting data collection activities. Several 

discrepancies were noted during the audit that should be improved. 

Most significantly: 

· Signatures/initials and dates do not always accompany entries or changes to 

documents. Sometimes this is the result of forms used over a period of time (i.e., 

weekly) that do not have sufficient blocks for signature/initials and/or dates. 

EPA also noted: 

· Incorrect calibration documentation 

· Forms / logbooks with no documented management or peer review 

· Station logbooks not transmitted to data review/validation staff on a regular basis 

References: 

QA Handbook for Air Pollution Measurement Systems, Volume II, EPA-454/B-13-003, May, 

2013, Section 6 

EPA’s APTI Course 444, Air Pollution Enforcement Student Manual, Chapter 8 

Recommendation to Address Finding: 

1. Evaluate and revise documentation procedures with the goal of eventually moving to 

electronic documentation that is traceable and available to operations, calibration, data 

review, and quality assurance staff and management. 

2. Include documentation as a part of routine training programs. 

3. Ensure all documentation is routinely reviewed by a second staff person or manager for 

accuracy. 

 
23 

Finding # A5 

Agency: SCAQMD 

Date of Audit: September 24-25, 2013 

Program Area: General 

Positive Finding: 

Communication between the laboratory, quality assurance (QA), ambient monitoring, and 

management levels has improved since the last TSA. 

Description: 

Past TSAs have noted disconnects between operations and support, QA and the laboratory. 

SCAQMD now holds regular meetings between the three managers (Jason Low, Andrea 

Polidori, and Rudy Eden), as well as monthly meetings with staff. Furthermore, managers and 

principals meet on a weekly basis to discuss impending issues. 

As an example of the effective communication that is now in place, when a new instrument is 

brought in, a task force made up of representatives from operations, support, and others who 

are involved with the operations and maintenance of the instrument is convened. Involving 

those who need to use and understand the SOP from the beginning makes it more useful for its 

target audience and ensures that members of the respective groups know the changes and 

details. 

References: 

N/A 

Recommendation to Address Finding: 

N/A 

 
24 

Finding # A6 

Agency: SCAQMD 

Date of Audit: September 24-25, 2013 

Program Area: General 

Positive Finding: 

Staff and management are extremely knowledgeable and are working to proactively 

implement improvements, as well as effectively troubleshooting issues as they arise, as time 

allows. 

Description: 

SCAQMD has been going through a number of transitions with staff and management 

changes, as well as changes to their data systems. There is also a very high workload. 

SCAQMD has been working collaboratively across groups to discuss issues, prioritize 

workload, and identify ways to improve or increase efficiency. EPA was impressed with 

staff’s general knowledge and understanding of the monitoring system as a whole, and the 

ability for this high-functioning group to keep things running despite staffing and 

technological challenges. Several staff and managers have been cross-trained or have 

experience in other branches, which lends additional strength to the overall program. 

References: 

N/A 

Recommendation to Address Finding: 

N/A 

 
25 

Finding # C1 

Agency: SCAQMD 

Date of Audit: September 24-25, 2013 

Program Area: Field 

Finding: 

There is insufficient room at many monitoring sites for EPA PM2.5 and Pb PEP audit samplers. 

Description: 

EPA is required to perform collocated sample collection at all PM2.5 and Pb TSP monitors that 

might be used for regulatory decisions. Collocated PEP samplers must be within four meters 

of each other horizontally and at least one meter apart for low flow instruments or at least two 

meters apart for high flow instruments, to preclude airflow interference. Also, it is a general 

practice for the vertical distance between the PE sampler inlet and the audited site sampler 

inlet to be ≤1 meter. 

In current site configurations, there may be insufficient room for EPA PM2.5 PEP or Pb PEP 

audit samplers to meet these general requirements. This applies specifically to sites where 

monitors are mounted on platforms at ground level and equivalent height platforms within 4 

meters of the primary sampler (permanent or temporary platforms) have not been provided for 

PEP samplers. 

Note that the EPA contractor has been setting up the NPEP audit samplers in the space 

available at the stations, however, in many cases the collocation siting is not ideal. PEP PM2.5 

samplers set-up at ground level only marginally meet the 2 meter height siting requirement and 

PEP Pb sampler do not meet this requirement. 

References: 

40 CFR 58, appendix A, §3.2.7, 3.3.1.2 and 3.3.4.4 

“Quality Assurance Project Plan for the Federal PM2.5 Performance Evaluation Program”, 

March 2009 

Field Standard Operating Procedures for the Federal PM2.5 Performance Evaluation Program, 

2009

Recommendation to Address Finding: 

Provide appropriate accommodation for EPA PM2.5 and Pb PEP audit samplers. 

 
26 

Finding # C2 

Agency: SCAQMD 

Date of Audit: September 24-25, 2013 

Program Area: Field 

Finding: 

The South Long Beach site has several siting issues. 

Description: 

The South Long Beach monitoring site is located on a border strip in a community college 

parking lot. There are TSP, PM10 (high volume), PM2.5 FRM, PM2.5 BAM and meteorological 

monitors at this site. The site was visited on a Tuesday afternoon while the college was in 

session. The parking lot was full and extremely busy. The monitoring site is located near one 

of the main entrances to the parking lot. There is also a tree several meters east of the 

monitoring site (6.4 meters from the closest monitor (PM2.5 BAM)). 

On the day of the visit, EPA observed a storage container in the four parking spaces adjacent 

to the monitors. Based on information from an aerial photograph, this container has not been 

consistently adjacent to the monitors and cars park adjacent to the site. The nearest parking 

space was less than three meters from the inlet of the PM2.5 BAM. 

The condition of the metal mesh at several of the sampling platforms was quite rusted and 

unstable. This was particularly noticeable on the platform used for the PM10 sampler. This is a 

potential safety hazard. Additionally, a moderate wind caused the PM10 sampler to oscillate 

strongly. This vibration/movement may impact proper sampler operations 
27 

References: 

40 CFR 58, appendix E 

Recommendation to Address Finding: 

1. Ensure compliance with distance from trees and obstructions siting requirements. 

2. If this site is still operating when SCAQMD develops its 2015 Network Assessment, 

address scale of representation in the assessment. 

3. Evaluate the platforms being used in the monitoring network and replace or re-enforce 

the platforms as needed. 

 
28 

Finding # C3 

Agency: SCAQMD 

Date of Audit: September 24-25, 2013 

Program Area: Field 

Finding: 

Field blanks for TSP Pb are not routinely performed for all monitoring sites. 

Description: 

Blanks controls are essential to demonstrate that contamination has not been introduced into 

sampling process. 

The QA Handbook Volume II recommends that one field blank be collected quarterly for each 

instrument. 

References: 

QA Handbook for Air Pollution Measurement Systems, Volume II, EPA-454/B-13-003, May, 

2013 

Recommendation to Address Finding: 

Implement field blank collection for TSP Pb on at least a quarterly basis for each instrument. 
29 

Finding # D1 

Agency: SCAQMD 

Date of Audit: September 24-25, 2013 

Program Area: Laboratory 

Finding: 

The microwave digestion vessels are not being labeled, which creates the potential to confuse 

samples during the Pb filter preparation process. 

Description: 

The microwave digestion vessels are not being labeled and are moved between the microwave 

digestion rack and a test tube rack to prepare and remove sample aliquots. This process 

introduces the potential that samples may be confused and subsequently misreported at some 

frequency. Additionally, there is no way to track which samples may have been impacted by a 

contaminated or defective extraction vessel. The analyst stated that the Teflon vessels are not 

intended to be labeled. However, these vessels could be permanently marked and tracked. 

References: 

QA Handbook for Air Pollution Measurement Systems, Volume II, EPA-454/B-13-003, May, 

2013, Section 8.1.1 

Pb Equivalent Method EQL-0710-182, Section 8.3.1 Filter Handling Procedure 

Recommendation to Address Finding: 

Utilize microwave extraction vessels that are marked and tracked in the extraction process. 

 
30 

Finding # D2 

Agency: SCAQMD 

Date of Audit: September 24-25, 2013 

Program Area: Laboratory 

Finding: 

Raw electronic laboratory data are not consistently organized and indexed to allow them to be 

easily recalled from the data storage system. 

Description: 

2010 SCAQMD finding A2 noted significant issues with electronic record storage by the 

laboratory. The SCAQMD laboratory has centralized, secured and backed up records, 

including instrument data files, to respond to this concern. In order to complete this process, 

the laboratory should ensure that all instrument-generated records and related metadata are 

consistently organized and indexed so that they can be recalled and reanalyzed as needed by 

staff other than the primary analyst. Currently, data is not consistently accessible for reanalysis 

and validation by laboratory staff and quality assurance staff, without assistance by the 

primary analyst. 

References: 

Basic Requirements of an Electronic Recordkeeping System at EPA, 

http://www.epa.gov/records/tools/erks.htm

Recommendation to Address Finding: 

Develop and follow a procedure for indexing electronic laboratory instrument records so that 

individuals other than the primary analyst may have access to this data. 

 
31 

Finding # D3 

Agency: SCAQMD 

Date of Audit: September 24-25, 2013 

Program Area: Laboratory 

Finding: 

Some Pb-TSP filters and the associated official Chain of Custody forms could not be located. 

Description: 

During data tracking, EPA reviewed data from a number of Pb-TSP filters. While some were 

easily located in LIMS and the actual Pb-TSP filter in the envelope (the envelope is the COC 

and provides validation information) were quickly found, SCAQMD was unable to locate two 

filters. The technician explained that these missing filters were recently sent out to a 

researcher, but was not able to verify this during the audit. It was later determined that the 

chain of custody forms were sent to EPA Region 9 as part of the Pb PEP program. 

The filters and the information contained on the filter envelopes should be consistently 

organized, indexed, and tracked. 

References: 

QA Handbook for Air Pollution Measurement Systems, Volume II, EPA-454/B-13-003, May, 

2013, Section 6 

EPA’s APTI Course 444, Air Pollution Enforcement Student Manual, Chapter 8 

Recommendation to Address Finding: 

1. Develop the laboratory records management system to include tracking of the Pb-TSP 

filters post analysis. 

2. Do not remove the official documentation from the original filter envelope and send it 

to an outside entity. If the filters are sent offsite, prepare a second envelope and retain 

the original, as it constitutes official documentation. See finding A4. 

 
32 

Finding # E1 

Agency: SCAQMD 

Date of Audit: September 24-25, 2013 

Program Area: Data Management

EPA-Directed Finding: 

SCAQMD requested guidance and/or training on how to apply AQS codes to data. 

Description: 

Previously, DMS only allowed four flags to be entered. It now allows multiple flags. 

SCAQMD has found that some flags cannot be applied to certain parameters (for example, 

AQS would not accept the flag “SX – does not meet siting criteria” for gaseous parameters at 

the West Lost Angeles site, August 2012 – October 2012). SCAQMD has requested that EPA 

provide flagging guidance or training. 

References: 

N/A 

Recommendation to Address Finding: 

EPA will investigate what trainings or guidance currently exist, and work to develop 

additional materials if those are insufficient. 

 
33 

Finding # F1 

Agency: SCAQMD 

Date of Audit: September 24-25, 2013 

Program Area: QA/QC 

Finding: 

The QA program does not provide consistent oversight of all data-related activities of the 

organization. 

Description: 

Finding A4 and general deficiencies from the 2010 TSA highlighted the need to strengthen the quality 

management function of the Quality Assurance Branch. 

In the last three years, the SCAQMD QA program has submitted critical planning documents 

(QAPPs/SOPs) to EPA, strengthened the audit program, implemented corrective actions, and supported 

the data certification process. The program should continue to develop and implement a comprehensive 

and consistent quality management process for the organization. 

It was noted during the audit that: 

· Tracking of data quality trends at individual sites, as performed by the SCAQMD station 

operators using the Chessell data recorders (or an equivalent system), was not being utilized by 

the QA program. Internal technical systems audits and audits of data quality are not performed 

on a routine basis. 

· Field evaluations of monitoring stations do not identify siting and other on-going issues that 

may compromise the representativeness of data. Where these deficiencies exist, the QA 

program should evaluate impacts on data quality and vulnerabilities to data defensibility. 

· Monitoring staff should have additional QA training so that they fully understand the 

relationship of their work to the quality assurance process. 

· The QA program should balance its role in the laboratory that includes both technical support 

and independent QA oversight of laboratory activities. This may require that QA program staff 

take on different responsibilities with respect to the laboratory to promote engagement with 

and independence from the laboratory. 

In sum, the QA program must provide sufficient oversight in order to effectively evaluate the quality of 

the organization’s data collection activities in relation to identified data objectives. 

References: 

40 CFR 58, appendix A, §2.2 Independence of Quality Assurance 

Recommendation to Address Finding: 

Develop a strategy to improve documentation and understanding of the quality of the District’s 

monitoring data, and to strengthen quality management and oversight. 

 
34 

Finding # F2 

Agency: SCAQMD 

Date of Audit: September 24-25, 2013 

Program Area: QA/QC 

Finding: 

There is currently no detailed schedule for updating SOPs. 

Description: 

SCAQMD has completed work on SOPs that cover most of the ambient air monitoring 

tasks/methods performed. 

Several SOPs were also being updated or developed at the time of the audit. SCAQMD QA is 

working with the monitoring and laboratory groups to plan, write, finalize, and implement 

these new procedures. The process that identifies the need for a new SOP or a significant 

procedural update and the SOP development procedures should be formalized by the QA 

group. 

SCAQMD SOP0100 notes that SOPs will be reviewed every two years. The QA group should 

work with monitoring group and the laboratory to develop a specific schedule for review and 

updating of SOPs. 

References: 

Guidance for Preparing Standard Operating Procedures, EPA QA/G-6, EPA/600/B-07/001, 

April 2007, Section 2.0 SOP Process 

SCAQMD, SOP0100, Guidance for Preparing SOPs

Recommendation to Address Finding: 

Develop a schedule and procedure for reviewing and updating SOPs. 
35 

APPENDIX A: SUMMARY OF FINDINGS 

FINDINGS 

A1: SCAQMD is not evaluating or implementing potential short-term fixes for some of the 

existing siting issues. 

A2: Staff turnover, unfilled positions and increased responsibilities may result in loss of data or 

compromised data quality. 

A3: SCAQMD does not have an approved QAPP for PAMS monitoring. 

A4: Documentation procedures for logbooks and forms should be improved. 

C1: There is insufficient room at many monitoring sites for EPA PM2.5 and Pb PEP audit 

samplers. 

C2: The South Long Beach site has several siting issues. 

C3: Field blanks for TSP Pb are not routinely performed for all monitoring sites. 

D1: The microwave digestion vessels are not being labeled, which creates the potential to 

confuse samples during the Pb filter preparation process. 

D2: Raw electronic laboratory data are not consistently organized and indexed to allow them to 

be easily recalled from the data storage system. 

D3: Some Pb-TSP filters and the associated official Chain of Custody forms could not be 

located. 

F1: The QA program does not provide consistent oversight of all data-related activities of the 

organization. 

F2: There is currently no detailed schedule for updating SOPs. 
36 

APPENDIX B: GOOD PRACTICE RECOMMENDATIONS 

GENERAL RECOMMENDATION 1: 

SCAQMD station operators and auditors do not receive siting training. As EPA has emphasized 

the importance of meeting siting requirements, SCAQMD has requested guidance or training to 

better equip their staff to recognize when something is an issue, as the regulations are often 

difficult to interpret. EPA recommends SCAQMD attend ARB siting training. If none is 

immediately available, SCAQMD should work with ARB and/or EPA to set up training 

opportunities. 

 
37 

APPENDIX C: ORGANIZATIONAL CHART 
38