### MEMORANDUM

TO: Docket No. EPA

‐ HQ

‐ OAR

‐ 2012

‐ 0918

Air Quality Designations for the 2012 PM 2.5 

### Standards

FROM: Liz P. Naess

Air Quality Assessment Division, OAQPS

SUBJECT: Data Quality Issues in Tennessee Affecting Air Quality Designations for the 2012

PM 2.5 

### National Ambient Air Quality Standards

The purpose of this memorandum is to discuss PM 2.5 

### data quality issues identified in Tennessee

as a result of a technical systems audit (TSA) of the Tennessee Department of Environment and

Conservation (TDEC) ambient air monitoring program. TSAs are systematic and objective

examinations of a monitoring program to determine whether environmental data collection

activities and related results comply with the project's Quality Assurance Project Plan and other
planning documents, are implemented effectively, and are suitable to achieve its data quality
goals.

EPA Region 4 conducted TSAs in 2010 and 2013 on the State of Tennessee laboratories in

Nashville and Knoxville, and identified problems with the temperature and humidity control

systems at both laboratories (see Attachments 1 and 2). A large portion of the PM 2.5 

### samples

did not meet all of the requirements of the federal reference method for PM 2.5 

### found in 40 CFR

Part 50, Appendix L. Specifically, the TSA found that environmental control problems in both

laboratories caused filters to be weighed under temperature and humidity conditions outside

of the allowable ranges. Temperature and humidity control ranges are among parameters

identified as "critical criteria" in the federal reference method for PM 2.5 

### found in 40 CFR Part 50, Appendix L. Accordingly, when filters are weighed outside of these allowable ranges, the

associated data should be considered invalid for regulatory purposes unless there is a compelling reason and justification for not doing so.

These issues are further discussed in EPA Region 4’s August 8, 2014, letter to TDEC (see

Attachment 3). Please note that these findings do not affect samples collected by the
Chattanooga

‐ Hamilton County Air Pollution Control Bureau, as these samples were analyzed by

a different laboratory.

EPA Region 4 has made a preliminary determination regarding the data from those laboratories

for the period 2008 through 2012. EPA is waiting to evaluate the final report for TDEC's filter
study and supporting materials before completing our analysis and making a final data validity

determination. Until a final determination has been made, EPA has moved the data in the Air
Quality System database for the PM 2.5 

### sites in question from parameter code 88101 (PM 2.5 

### at

local conditions; used for regulatory data) to parameter code 88501 (PM 2.5 

### raw data). This
change will clarify to data users that data from these sites should not be compared to the PM 2.5

### National Ambient Air Quality Standards until EPA has made a final validity determination. No

other changes to this dataset have been made at this time.

Attachments:

1. Tennessee Technical Systems Audit 2010

2. November 21, 2013, letter from Laura Ackerman, Chief, Superfund and Air Section, US

EPA Region 4, to Barry Stephens, Tenessee Department of Environment and

Conservation, transmitting a copy of EPA Region 4’s Technical Systems Audit. September

2013 audit attached.

3. August 8, 2014, letter from Beverly H. Banister, Director, Air Pesticides and Toxics

Management Division, US EPA Region 4, to Barry R. Stephens, Tenessee Department of

Environment and Conservation, regarding data completeness issues for Tennessee.

### 08/07/2014

Note to File: SESD Project 10

- 0730

This is an unsigned copy of the TSA Report issued on 03/03/2011. The Tennessee Department of Environmental and Conservation (TDEC) TSA was conducted during September 22

- 24, 2010.

Tim Simpson

### March 3, 2011

Barry R. Stephens, Director Tennessee Department of Environment and Conservation

Division of Air Pollution Control
L&C Annex, 9 th 

### Floor

401 Church Street Nashville, TN 37243

- 1531

SESD Project No. 10

- 0730

Mr

. Stephens :

On Septemb er 22

- 24, 2010 , Greg Noah , Tim Slagle, and José Rios , Environmental Protection Agency, Region 4, Science and Ecosystems Support Division (SESD), conducted a technical systems audit (TSA) of the Tennessee Department of Environment and Conservation (TDEC),

Di vision of Air Pollution Control ’s (DAPC) a mbient a ir m onitoring p rogram

. The data

collection period covered by the audit were calendar year s 2007 through 2010 . The Technical Systems Audit Form Questionnaire , Air Quality Systems data reports, and prior years ’ audit

report s were used in cond ucting the audit

. The Technical Systems Audit Form Questionnaire s completed for this audit are attached.

I appreciate your agency’s participation in this audit as well as your resolve to rapidly address

t he issues th at were identified. Please provide a written response with corrective action or comment within 30 days. If you have any questions regarding the attached audit report, please

contact Greg Noah at (706) 355

- 8635

.

Sincerely,

Mike Bowden

, Chief Superfund and Air Section

cc: Doug Neeley , APTMD w/attachment Todd Rinck , APTMD w/attachment Quincy Styke

, TD EC w/attachment Jackie Waynick, TDEC w/attachment

# Tennessee Department of Environment and Conservation

Divisi on of Air Pollution Control

Ambient Air M onitoring P rogram

2010 TECHNICAL SYSTEMS AUDIT

Project 10

- 0730

CONDUCTED BY

Greg Noah

, José Rios , and Tim Slagle U.S. Environmental Protection Agency, Region 4

September 22

- 24, 2010

### Page 2 of 12

Title and Approval Sheet

Title: Tennessee Department of Environment and Conservation, Division of Air Pollution Control, Ambient Air Monitoring Program

, Technical Systems Audit

Document Type: Technical Systems Audit, Final Report

Approving Official:

Mike Bowden, Chief Date Superfund and Air Section Enforcement and Investigations Branch

SESD Project Leader:

Greg Noah, Technical Authority Date Air and Superfund Section Enforcement and Investigations Branch

### Page 3 of 12

EXECUTIVE SUMMARY

The monitoring staff at the Tennessee Department of Environment and Conservation (TDEC) , Division of Air Pollution Control (DAPC) operates an excellent ambient air monitoring program. The agency has a wealth of technical expertise, produces good data completeness, and the monitoring group shows excellent skill in monitori ng as a whole. The audit confirms that the monitoring data is complete and is of good quality. However,

there are a few recommendation s identified that must be addressed. Most s ignificant ly, there are several key staff members who are soon to be eligibl e for retirement, and succession planning should be a high priority for continued monitoring success

. TDEC has an immediate need to expand the role of their quality assurance audit program to investigate and resolve issues which EPA has identified in the local agencies. Both weighing laboratories visited during this audit need to revisit their quality assurance procedures to ensure that they maintain good data quality. EPA observations and recommendations are noted and identified in bold in the report.

INTRODUCTION

On September 22

- 24, 2010

, Greg Noah, Tim Slagle, and José Rios , Environmental Protection Agency, Region 4, Science and Ecosystems Support Division (SESD), conducted a technical systems audit (TSA) of the TDEC DAPC

, ambient air m onitoring p ro gram

. The audit was conducted according to the provisions of 40 CFR Part 58. Using the National Ambient Air Systems (NAAS) Technic al Systems Audit Questionnaire

, the EPA Air Quality System (AQS) data reports for calendar year 2009 , the technical systems audit, field, laboratory , and data review procedures w ere reviewed during the audit of the TDEC office and monitoring sites. TDEC staff

interviewed for the audit included : Jackie Waynick, Robert Brauner , and Billy Pugh in program oversight; Larry Killebrew and Radford Strong in quality assurance; Dr. Bob Read, Craig Edwards, and Dr. Susan Birchfield in the environmental laboratory

. The auditors also visited the

Hendersonville ( 471650007 ) ambient air monitoring site

.

AUDIT RESULTS AND RECOMMENDATIONS

Network Design and Siting

The TDEC staff operates a network of over 30 active monitors. The criter ia monitors in operation are: 12

- O 3 

### , 3

- PM 10 

### , 12

- PM 2.5 

### , and 1

- Pb. The 2009 network review was completed and available for review. In addition to monitoring for the National Ambient Air Quality Standards, the agency samples for PM 2.5 

### speciation in the Chemical Speciation Network and has the capability for monitoring air toxics

. TDEC also has a quality assurance and oversight role in the T ennessee V alley A uthority Kingston Ash Recovery Project. No deficiencies were found in the network with respect to network design

.

### Page 4 of 12

The Hendersonville monitoring si te (471650007) was visited during this audit. The monitoring site was well organized , and the operators are cross trained on several

different samplers and analyzers throughout the state. The samplers and monitors were

well maintained and the monitor logbooks were available for review.

Resources and Facilities

The TDEC DAPC offices are located at the L&C Annex, 9 th 

### Floor, 401 Church Street in Nashville, TN and include the program oversight and data review responsibilities. The environmental laboratory is located on 630 Hart Lane

, Nashville, TN and includes the particulate filter weighing laboratory and the toxics laboratory. T he Environmental Field

Office is located on 711 R

. S

. Gass Blvd

, Nashville, TN and includes the technical services group who conduct quality assurance audits for the network. TDEC also maintains laboratories in Jackson, TN and Knoxville, TN which both support the ambient air monitoring network. The Kn oxville laboratory was visited during this audit and

observations and recommendations are included on page 7 of this report

. Spare equipment and parts for the network are stored at the environmental field office. All maintenance and calibration of monitoring equipment is conducted at this location. The

space assigned for monitoring appears to be sufficient for program operation

.

The TDEC staff is well trained and cross trained in operating a variety of analyzers and samplers. Operators are experienced and have a good understanding of mo nitoring objectives

. T he group displays good teamwork and has good communication overall.

TDEC DAPC has had excellent leadership and technical expertise over the years. Presently, there are several staff members, including some senior leadership, who are approaching retirement. During the audit, EPA did not see evidence of any succession planning to train staff to move into these positions. While TDEC has done a good job cross training on equipment, the training of staff to manage the network needs to be its highest priority at this point. Without train ed staff in leadership roles, the strong monitoring program that TDEC has developed and maintained could falter. EPA strongly recommends that TDEC consider succession planning in anticipation of retirements. EPA also recommends that TDEC encourage its lo cal programs to begin succession planning as well since there are several positions that could become open due to retirements.

Data and Data Management

Reports for Raw Data (AMP 350) & Data Completeness (AMP 430) for 2009 were retrieved fr om A ir Q uality S ystem (AQS) for the SLAMS network of TDEC

. The review

of this information shows good data recovery and good null coding of missing data events. Logbook entries, maintenance records, and quality assurance documentation reviewed in the agency o ffices and at the monit oring sites indicate d that the monitoring data was appropriately validated. TDEC data recovery was outstanding with all N ational

### Page 5 of 12

A mbient A ir Q uality Standard (NAAQS) pollutants posting greater than 75% data completeness in all quart ers of 2009.

Precision and accuracy ranges were investigated by the operators prior to the audit. The ranges for precision checks and audits seen in the AQS AMP 255 report for the continuous gaseous pollutants met the data quality objectives.

The data management staff has good knowledge of data review requirements, excellent record keeping, and follows review process es well

. The organization of data was an area of marked improvement from the last EPA technical systems audit. However, some are as for improvement were noted. The audit findings and EPA recommendations are

described below.

TDEC presently uses the Agilaire ESC 8816 data loggers to store and transmit data from monitors throughout the network. The ESC 8816 is an older model data lo gger and Agilaire is no longer supporting these devices with parts or service. The data logger is a critical component of a monitoring site because it allows for the collection and transmittal of data. Without a data logger and vendor support, a site c an cease to operate. Therefore, TDEC expressed to EPA that they need to upgrade to the newer ESC 8832 model as soon as possible. The 8832 model has broadband connectivity capability which would be a valuable and cost saving enhancement for the TDEC netwo rk. Broadband connectivity allows an operator to monitor an analyzer’s performance from the office without traveling to a site which saves time and money. TDEC can negotiate a discount rate for volume, but additional funding will be required from EPA. E PA supports the move to

the 8832 model especially considering the lack of vendor support with this older model. TDEC will need to work with the regional office to determine if funding is available for the upgrade.

In conducting the data review, TDEC does not routinely review the electronic data traces from the monitors. In reviewing the traces, specifically the minute data, the reviewer can identify trends in the data and verify that calibrations and quality control checks are being completed according to procedure. In reviewing electronic traces, issues such as malfunctioning equipment can be identified quickly minimizing data loss, and quality assurance activities can be monitored in detail remotely. EPA recommen ds that TDEC add this check to their data review procedure to view trends and better assess whether calibrations and quality control checks are being completed appropriately.

While reviewing the raw data from AQS, EPA observed that there was some confus ion in null coding zero/precision/span checks. TDEC had been giving these activities the code for a zero/span check giving the impression that no precision check was completed. A review of the field sheets revealed that the precision point was being cond ucted as required. EPA recommends that TDEC review the list of AQS null codes and properly code null data.

I n the review of the continuous tapered element oscillating microbalance (TEOM)

maintenance form , EPA observed that there were no place s on the for m to derive a

### Page 6 of 12

percent difference for the temperature and barometric pressure checks. Without calculating a percent difference, there is no way for the auditor or operator to determine whether the instrument is operating within specifications. EPA recomme nds that TDEC revise the TEOM maintenance form allowing the operator to calculate the percent differences.

EPA included facility operated monitoring sites in the data review. Though TDEC does not operate these sites on a daily basis, the validation and s ubmittal of the data to AQS

resides with TDEC. TDEC does not have the same documentation for these sites as for its NAAQS monitoring sites, so the routine TDEC data review process does not occur with facility operated monitoring sites. The facility is re quired to subject their data through their own data review and submit to TDEC. TDEC was questioned about the facility data review process and was not certain of their process. In order to confirm the data review process, EPA recommends that TDEC investig ate the data review process for all facilities submitting data to TDEC. The TDEC and facility data review should cover the same general elements to ensure the data is of good quality.

Quality Assurance & Quality Control

The TDEC Quality Assurance Project Plan s (QAPP) for the gaseous criteria pollutants

and the PM 2.5 

### F ederal R eference M ethod (FRM) network have been approved by EPA Region 4. These documents were complete

, well written, and available to all staff.

The independen t quality assurance audits for the TDEC ambient air monitoring network are conducted by the technical services group. This group is responsible for auditing not only the state monitoring sites but the local agencies as well. This group consists of two

au ditors and a supervisor.

During FY2010, EPA co nducted TSAs of the state of Tennessee’s loc al ambient air monitoring local agencies including the Nashville Metropolitan Health Department, Knox County Health Department , Chattanooga/Hamilton County Air Pollution Control Bureau

, and Memphis/Shelby County Health Department . In the EPA TSAs, several issues were

discovered which EPA believes that the routine TDEC audits should have found and

addressed beforehand

. The audit reports for the local agenci es have been distributed to TDEC, and copies are available from EPA. Findings and recommendations for the technical services group are discussed below.

The TDEC quality assurance audits have typically been limited to performance audits of

the analyzers on site and related maintenance activities. By limiting the scope of the audits, the audit group can overlook systemic issues which can significantly affect data quality. EPA strongly recommends that t he TDEC technical services group expand

the scope of its audits to include elem ents of TSAs

. At a minimum, EPA

r ecommend s that TDEC add the following elements to its audit scope: completion of required quality assurance checks, data completeness, and siting compliance.

### Page 7 of 12

When the TDEC quality assu rance audits have identified issues in the local agencies

, there has been slow response by the locals to address the findings. Knox County, in particular, has been slow in responding to issues found in both TDEC and EPA audits. EPA strongly recommends th at TDEC find ways to work with the local agencies to leverage corrective action when issues are identified from audits. EPA is willing to assist in ensuring that important issues that are found during audits are addressed in a timely manner. EPA also rec ommends that TDEC communicate audit reports with EPA SESD and the regional office.

Particulate Matter Filter Weighing Laboratory

- Nashville

The TDEC environmental laboratory provides particulate matter filter weighing activities for the central part of the state. Filters are inspected, weighed, and delivered to the monitoring sites in the region. The laboratory has a climate controlled room where weighing is conducted and dedicated space for shipping and receiving. The climate control in the weighing room has been an issue for TDEC, and TDEC has tried to resolve the issues with limited success. Climate control in weighing laboratories has b een troublesome around the region, and EPA is willing to share information to help resolve problems. Overall, the laboratory operates well, but several important findings must be

addressed.

The weighing room quality control was reviewed by EPA during the audit, and revealed that lab blanks showed high trends during parts of the year unknown to the analyst and supervisor. This is indicative of a lack of attention to the quality control data. EPA recommends that TDEC develop a procedure that requires freq uent review of quality control data to identify trends and implement control strategies. EPA identified two areas that may help reduce the high laboratory blanks which include daily cleaning of the weighing station and a different filter inspection proce ss.

EPA reviewed the weighing laboratory calibration records during the audit. The balance check standards were found to be out of date and the polonium strips used for static control were also out of date. The check standards must be recertified or rep laced annually and the polonium strips must be replaced every six months. The check standards did not demonstrate a shift in weight and there was no evidence of static problems; therefore, the data seems to be unaffected. EPA requires that TDEC recertify or replace the check standards and the replace the polonium strips

.

During the weighing process, the analyst must record the weight from the microbalance and transfer the number into a spreadsheet. This activity increases the chance of transcription e rrors and problems in the database. TDEC has software that will allow the electronic transfer of data from the microbalance into the spreadsheet eliminating the risk of transcription. EPA recommends that TDEC install the new software to improve quality c ontrol.

### Page 8 of 12

Particulate Matter Filter Weighing Laboratory

- Knoxville

TDEC operates a particulate matter filter weighing laboratory facility in Knoxville,

Tennessee located at 1522 Cherokee Trail, Knoxville, TN 37920 . This laboratory contains a climate controlled weighing room that provides analytical services for the ambient air monitoring programs including PM 2.5 

### filter weighing and high volume

TSP/PM 10 

### filter weighing. In general, this laboratory serves Knox County and the

eastern TDEC monitoring sites.

When inspecting the filter conditioning area of the laboratory, EPA discovered that the laboratory blanks are not being equilibrated with the sample batches. The laboratory blanks are stored capped until time for the weighing of th e sample filter batches. The purpose of the laboratory blank is to provide an assessment of laboratory contamination which could affect the sample filters during the weighing process. EPA recommends that TDEC expose the laboratory blanks at the same time that the sample filters are exposed for conditioning. EPA also recommends that TDEC specifically note this in an update to the PM2.5 filter weighing standard operating procedure.

Upon review of the balance stand ard weights, EPA found that the weights have not always been r ecertified annually as required in the EPA Quality Assurance Guidance Document 2.12, Section 4.3.7. The documentation showed that there were instances where the weights have been two months past d ue their re

- certification date. The weighing session data did not show any evidence of any shifts in the standard weights that may affect the data. EPA requires that TDEC review the annual certification criteria for the balance weight standards, and ensu re the certifications occur on a timely basis.

EPA observed a filter shipping issue with Knox County during the audit. Prior to EPA’s arrival, the laboratory had received a large shipment of filters from Knox County which appeared to be significantly del ayed. 40 CFR Part 50 App L Sec 8. 3.6 allows 30 days for

PM 2.5 

### filters to be weighed. Many of the filters in this shipment were already well past two weeks old. This delay in shipping does not leave much time for the laboratory to prepare and analyze the filters or provide a buffer any problems the weighing room may encounter. This situation puts the laboratory in an unacceptable position where samples may have to be invalided if the weighings cannot be completed in the 30 day window. EPA requires that TDEC address the issue of timely sample delivery with Knox County to ensure that samples can be weighed within the 30 day holding time

.

Cassettes used to hold filters during the sampling process were left out in the open unprotected. While there was no indication of contamination, the laboratory should use best laboratory practices to protect these cassettes from contamination. EPA

recom mends that TDEC store the cassettes in a protected environment to minimize

the risk of contamination.

When weighing filters, the analyst must manually input the weight from the balance readout into a spreadsheet used to record weighing session information . This practice

### Page 9 of 12

introduces the risk of transcription errors into the system. EPA recommends that TDEC employ software to electronically transfer the weight from the balance into the spreadsheet.

The filter weighing room has exhibited issues over the p ast couple of years. A review of AQS data flags indicated that humidity problems have been present, and the analyst confirmed the problem. Typically, the humidity runs in the upper end of the 30 to 40 degree Celsius operating range . Filter weighing labo ratories should operate under positive pressure to reduce the entrainment of particulate matter. A quick test indicated that the TDEC Knoxville laboratory is under negative pressure which indicates an issue

with the climate control system. The laboratory blanks did not seem to indicate that contamination was an issue, but the blanks have been kept covered as discussed previously. Field blanks did not indicate any issue with contamination. EPA recommends that TDEC investigate the HVAC system to ensure it is functioning properly.

After the filter weighing is completed, the analyst reviews the weighing data. The analyst was not aware of anyone else involved in the review process of the weighing data. EPA recommends that TDEC implement institute an indepe ndent quality assurance review of the weighing data before the data is sent to Nashville.

Air Toxics Monitoring Program

Currently, T DEC operates a co

- located (along with Exide facility monitors) high

- volume sampler to measure lead emissions from the Exi de battery plant located in Bristol, TN.

Flow audits of the Exide and T DEC monitors in March, June and August 2010 showed a flow variance of less than 6% which is under the limit of 10% adopted by SESD. The samples are collected on a 1 in 6 sampling sch edule. Field blanks are collected every 60 days. The site was not visited, nor the lab personnel interviewed due to distance and time

constraints.

The Bristol Exide high volume filters collected for lead analysis are submitted to the Knoxville Regional Laboratory for lead analysis. Since, November 5, 2010 the analysis of these filters has been by Inductively Coupled Plasma/ Mass Spectrometry (ICP/MS)

. Prior to November 5, 2010 the filters were analyzed at the Knoxville Regional Laboratory by graphite furnace Atomic Absorption. During the transition period of converting from graphite furnace Atomic Absorption to ICP/MS (August 4, 2010 to September 27 , 2010), the filters were analyzed in Nashville by ICP/MS.

For quality assurance purposes

, T DEC has contracted with an independent state lab located in Indiana; to check the Exide, Knoxville and Nashville laboratories lead analysis. This is done by sup plying 2 filter strips for analysis; one high concentration and one low

concentration. All of the laboratories were within 14% of the reference lead concentration for 5 filter sets analyzed from January to June 2010.

### Page 10 of 12

T DEC also operates a co

- located (a long with TVA monitors) high

- volume sampler to measure ambient air metals concentrations in total suspended particulate (TSP) from the Kingston TVA fly ash removal project. The Kingston TVA site is audited by SESD on a quarterly basis.

The Kingston TVA high volume filters collected for metals analysis are submitted to the State Lab in Nashville for metals analysis by ICP/MS

.

B oth o f the labs ; Nashville and Knoxville subtract the blank filter background concentrations of metals along with reagent backgr ound from samples reported to D APC.

This analysis is conducted on the filter as it is taken out of its original box and not transported to the field

. Lab filter blank subtraction is acceptable provided that the lab

blank filter is from the same lot or box as filters used in the field. Lab filter blank

subtraction is used to account for the trace amounts of metals found in the filter matrix and laboratory reagents. In addition, filter blank subtraction is discussed in EPA Compendium Method IO

- 3.2 Determin ation of Metals in Ambient Particulate Matter using Atomic Absorption (AA) Spectroscopy

, June 1999 and EPA Compendium Method

IO

- 3. 5 Determination of Metals in Ambient Particulate Matter using Inductively coupled

Plasma/Mass Spectroscopy

, June 1999

. Field blanks are reported as analyzed. The Method Detection Levels (MDLs) and Minimum Quantitation Levels (MQLs) for the analysis of metals by ICP/MS as calculated by the Nashville Lab are tabulated below. The Knoxville lab was not analyzing filters for lead a t the time of the audit; however, their MDLs and MQLs for lead should be similar.

Tennessee Department of Health Laboratory Services

2010 Kingston Air Filter Metals, MDL and MQL

Metals MDL in

ug/m3 MQL in

ug/m3

Aluminum (Al) 0.0022 0.0074
Arsenic (As) 0.0006 0.0037
Barium (Ba) 0.00019 0.0037
Beryllium (Be) 0.00015 0.00074
Cadmium (Cd) 0.00037 0.00074
Chromium (Cr) 0.00066 0.0037
Lead (Pb) 0.0038 0.00074
Manganese (Mn) 0.0043 0.00074
Selenium (Se) 0.0014 0.0037
Thallium (Tl) 0.00018 0.00074
Vanadium (V) 0.0015 0.0037
Mercury (Hg) 0.000021 0.00015

### Page 11 of 12

The QAPP for the analysis of the filters submitted by the Nashville lab is currently under review by SESD.

The auditors recommend that the site logbooks should be “site specific” that is; if a site or monitor is moved such that a new AIRS number is generated then a new logbook should be started. In addition, a logbook should be finished with a diagonal line followed by “End of Logbook” then signed and dated.

### Page 12 of 12 END OF REPORTPage 1 of 9 SESD Project ID# 13-0544 

# United States Environmental Protection Agency Region 4

Science and Ecosystem Support Division 980 College Station Road Athens, Georgia 30605-2720



# Technical Systems Audit

On the 

# State of Tennessee’s
Department of Environment & Conservation

Division of Air Pollution Control

Nashville, Tennessee September 9-12, 2013

SESD Project Identification Number: 13-0544

Requestor: CFR Requirement SESD Project Leader: Richard Guillot U.S. EPA/R4/APTMD SESD Organization 61 Forsyth St. SW 980 College Station Road Atlanta, Georgia 30303-8960 Athens, Georgia 30605-2720Page 3 of 9 SESD Project ID# 13-0544 

## Table of Contents

1. Introduction

............................................................................................................................... ............................ 4

2. Summary

............................................................................................................................... ................................. 4

3. Findings and Recommendations

............................................................................................................................. 5

3.1 Program and Data Management

.............................................................................................................................. 5

3.2 Field and Maintenance Operations

........................................................................................................................... 7

3.3 Quality Assurance

............................................................................................................................... ....................... 8

4 Conclusions

............................................................................................................................... ............................. 8

Appendix A

............................................................................................................................... ....................................... 9

Technical Systems Audit Questionnaire.................................................................................................................... 50 pagesPage 4 of 9 SESD Project ID# 13-0544 

## 1. Introduction

During the week of September 9-12, 2013, Richard Gu illot, Mike Crowe, and Michael Roberts with EPA Region 4’s Science and Ecos ystem Support Division (SESD) conduc ted a technical systems audit (TSA) on the State of Tennessee’s Department of Environment & Conservation, Division of Air Pollution Control (TDEC-DAPC) and the Department of Health, Division of Laboratory Services (TDOH-DLS). The TDEC-DAPC operates and mainta ins the ambient air pollu tion monitoring network in Tennessee and the TDOH-DLS analyze filt ers for the fine particulate matter (PM 2.5 

### ) pollutant program. The TDOH-DLS also analyze filters fo r the Memphis-Shelby County Health Department, Metropolitan Health Department of Nashville Davidson Count y and the Knox County Health Department. This TSA was conducted to meet requi rements found in 40 CFR Part 58 Appendix A. The TSA focused on data collected during the three year period of 2010 – 2012. Data from EPA’s Air Quality System (AQS) was used to evaluate netw ork performance along with an audit questionnaire included as appendix A of this report. Tennessee staff interviewed during the TSA included personnel

from the areas of:

Monitoring Maintenance / Quality Assurance Laboratory Barry Stevens Cathy Stoecker Dr. Bob Read Quincy Styke Rex Bracy Craig Edwards

Robert Brawner Lance Allen Dr. Susan Burchfield Billy Pugh Radford Strong Tim Morris Evelyn Haskin Anthony Wilson Susan Aldridge

Shannon Miller



## 2. Summary

The TSA for the State of Tennessee revealed two ma jor concerns and several other concerns with respect to the ambient air monito ring program. The first major c oncern was the significant portion of PM2.5 data flagged with a “1” in the AQS during 2011-2012. The State operated two PM 2.5 

### weigh

laboratories at the timeof this audit. Both of th ese labs began experiencing environmental control problems (temperature and relative humidity). Effo rts were made by the State to repair the failed environmental systems. These repair efforts were unsuccessful, with a cycle of repair and failure until

the decision was made to contract a private laboratory to take over al l of the weigh laboratory duties until replacement of the environmental systems coul d be accomplished. The State decided to close one of its laboratories (Knoxville) and focus all efforts into the Nashville lab. The “1” flag is an indicator of

a “critical criteria” fo r this pollutant measurement method not being met. EPA guidance recommends data not meeting a critical criteria be invalidated. EPA Re gion 4 has consistently followed this guidance

and will recommends the State inva lidate this data unless it can pr esent evidence as why it should be retained. The data impacted was collected from mid 2011 through mid 2012 for the State, Memphis, Nashville and Knoxville agencies and totals approxi mately 30% of the data set for each of these agencies. EPA Region 4 is recommending the TDEC -DAPC review data back through 2010 for this

issue.

The second major concern is the lack of quality assura nce information for monitors in AQS classified as “Industrial”. For 2010-2012, AQS shows 29 monitors meet ing this classification, two of these monitors are used in the State monitoring plan to meet EPA minimum monitoring requirements. These twoPage 5 of 9 SESD Project ID# 13-0544 

### monitors should meet all of the re quirements of a State and Local Air Monitoring Station (SLAMS). The state was unable to provide any documentati on regarding quality management plans, quality assurance project plans or standard operating proce dures for these monitoring sites. EPA recommends that the remaining “Industrial” moni tors be reclassified as “non-regul atory” to avoid confusion in AQS as to the purpose of these monitors.

Concerns noted in the TSA included: pending staff re tirements and the need for additional staff in the areas of data handling, maintenance and quality assu rance, the age of the si te calibration equipment throughout the monitoring network, ex tended oversight of th e local agencies – EPA would like to see the State take a stronger ro le in performing TSA’s.



## 3. Findings and Recommendations

3.1 Program and Data Management

1. Finding : A significant portion of the PM 2.5 

### raw data for the 2011 and 2012 monitoring years are flagged in the AQS with a “1” flag indica ting a critical criteria has not been met.

Discussion : During 2011-2012 the State of Tenness ee’s Department of Health (TDOH) operated two PM 2.5 

### weighing laboratories located in Nashville and Knoxville. The TDOH weighs filters for the following ambient air m onitoring agencies: the State of Tennessee, the Metropolitan Health Departme nt of Nashville-Davidson County, the Memphis Shelby County Health Department and the Knox County Health Department. In 2011, each of these laboratories began experiencing environmen tal control problems – primarily humidity control. A cycle of equipment failure and repair began in the laboratories until August 2012 at which point a decision was made by the DOH to temporarily contract a private laboratory to handle the filter weighing res ponsibilities. The Department of Health has since replaced the environmental control system for the Nashville weigh laborat ory. The Nashville laboratory began processing filters again in Ju ly 2013. Due to resource limitations the weigh laboratory in Knoxville was permanently closed and those duties transferred to the Nashville laboratory.

EPA specifies a 30-40% mean relative humidity with a ±5 relative humidity percent control range over 24 hours, these specifications can be found in 40 CFR Part 50 Appendix L §8.2.3, 8.2.4. EPA’s Quality Assurance Handbook for Air Pollution Measurement Systems identifies these specifications as a “c ritical criteria” for th e measurement of PM 2.5 

### . The

Handbook further states that “Observations that do not meet each and every criterion on the

Critical Criteria Table should be invalidat ed unless there are compelling reasons and justification for not doing so.”

Recommendation (s): All of the fine particulate monitoring data (PM 2.5 

### ) from 2011 through 2012 currently flagged in the AQS with a “1” flag indicating an unmet cr itical criteria should

be invalidated. Invalidation of the data woul d mean removal of the concentration data and replacement with the appropriate null data code. This will impact the PM 2.5 

### data collected by: the State of Tennessee, Memphis-Sh elby County, Nashville-D avidson County and Knoxville-Knox County air monitoring programs. Chattanooga-Hamilton County did notPage 6 of 9 SESD Project ID# 13-0544 

### utilize the State of Tennessee’s weighing laboratory for its PM 2.5 

### monitoring program so is not required to take any of these actions. The State of Tennessee and the impacted local agencies should coordinate their efforts in id entifying and flagging the data consistently in the AQS. A post audit review of the 2010 data shows the possibility th ese laboratory issues may have extended beyond the 2011-2012 timefra me. EPA Region 4 recommends the 2010

PM 2.5 

### data be reviewed and i nvalidated as necessary.

In addition, EPA recommends the TDEC-DAPC) ta ke a more active quality assurance role in the oversight of the PM 2.5 

### weighing laboratory. The DAP C should conduct an annual technical systems audit of the PM 2.5 

### laboratory and review the qua lity assurance data for lab operations quarterly.

2. Finding : The State of Tennessee does not have sufficient quality assurance procedures

and/or documentation to demonstrate that the mon itors classified as “Industrial” in the AQS meet EPA regulatory requirements.

Discussion : The State of Tennessee submits criteria pollutant data to the AQS which is collected by industries operating in Tennessee under the States permit authority. For 2010- 2012, data were submitted to the AQS for 29 i ndustrial monitors located at 16 separate monitoring sites. Each industry is responsible for all quality assuranc e procedures for their respective monitoring network. The State of Tenn essee submits this quality assurance data to the AQS for the industry but does not conduct a re view of this information. The State of Tennessee does not review or approve any Qu ality Assurance Project Plans (QAPP’s) or Standard Operating Procedures (SOP’s) the i ndustries may use in the operation of their monitoring network. The State of Tennessee do es conduct quarterly performance audits on

these industrial monitors.

The State of Tennessee has utilized two of thes e industrial monitors to meet EPA’s minimum regulatory requirements for the number of monito rs required in its network design plan. These monitors are the lead (Pb) monitor (AQS # 47-163-3001) located in Sullivan County and a sulfur dioxide (SO 2 

### ) monitor (AQS# 47-163-0007) located in Sullivan County. These two monitors must meet all EPA regulatory requirements found in 40 CFR Parts 50, 53, 58.

A review of the precision and accuracy data in AQS for the industrial monitors shows potential issues with the data. The State did not have any documentation available to demonstrate the data quality.

Recommendation (s): The State of Tennessee must take steps to ensure that the two monitors used to fulfill network design requirements meet all of the EPA regulatory requirements found in 40 CFR Parts 50, 53, 58. The State of Tennessee can accomplish this by either establishing state owned monito rs adjacent to the industry m onitors and operating them according to an EPA approved QAPP and SOP; or by require the industry to submit a QAPP and SOP to the State for review and approval. In addition, TSAs must be conducted on those industries to ensure compliance with EPA require ments. Ultimately, the State must be ablePage 7 of 9 SESD Project ID# 13-0544 

### to demonstrate that the data co llected for any of the monitors used for regulatory decision making purposes meets all of the EPA requirements.

The State of Tennessee should also reclas sify the 27 remaining monitors as “NonRegulatory” in the AQS. This will make it clear to all data users that the data collected by these monitors do not meet EPA regulatory requ irements and should not be used for decision making purposes.

3. Finding : Staffing Levels for Data Manageme nt, Maintenance, Quality Assurance

Discussion : Tennessee operates its ambient air program with a small staff. Currently the data management area has three staff member s, maintenance has two staff and quality

assurance has two staff members. As with ma ny of the ambient air monitoring programs in Region 4, most of the staff is approaching the point where retirement is an option. Once these senior staff begins to retire they will be taking a great deal of knowledge concerning the ambient monitoring program with them. In addition, each of the local programs in Tennessee have already experienced “turnover” in their respective ambient air monitoring staff.

Recommendation (s): EPA strongly recommends the State begin succession planning for any pending retirements. Ideally, this would enta il hiring new staff to work and train with experienced staff prior to any retirements. EP A also recommends additional staff for each of the areas of data management, maintenance and quality assurance. These staff would provide the state with the resour ces needed to meet the challe nge of increased oversight of the local agencies and the industr ial monitoring networks as well.

4. Finding : Continue Updating Standa rd Operational Procedures

Discussion : Tennessee has begun a process of updati ng its standard operating procedures. As noted above with the personnel changes occurring and the potenti al loss of knowledge through retirements the updating of the SOP’s w ould provide a basis for new employees to recover some of that knowledge.

Recommendation (s): EPA recommends completing the updating of the SOP’s as soon as possible.

3.2 Field and Maintenance Operations

1. Finding : Need to replace the aged cali bration equipment currently in use

Discussion : The auditors found that the calibration equipment in the state network is aged and in need of replacement. Tennessee utilizes Dasibi ® 

### brand calibration equipment in the network, Dasibi ® 

### has been out of business since the early 1990’s. While Tennessee has done an excellent job of maintaining this aged equipment and keeping the various models inPage 8 of 9 SESD Project ID# 13-0544 

### operation spare parts for these monitors are beco ming difficult to get. This will eventually

result in increased data loss unless the calibration equipment is updated.

Recommendation (s): EPA recommends purchasing new equipment as resources are

available.

3.3 Quality Assurance

1. Finding : More extensive quarterly audits are needed.

Discussion : The audit team would like to commend Tennessee’s efforts for conducting performance audits on all of the monitoring network instrumentation in each monitoring agency each quarter versus the required once per year for each instrument. These performance audits help bound the data and ha ve saved data in the past when quality assurance questions have arisen. As noted a bove the loss of personnel in the local agencies and potential loss in the state ra ises concerns about the quality of the data being collected by these inexperienced agencies. EPA technical systems audits are conducted on the three year

schedule.

Recommendation (s): EPA recommends the state expa nd its audit capabilities of the local agencies by incorporating an annual technical systems audit into one of the quarterly performance audit visits.



## 4 Conclusions

The significant loss of PM 2.5 

### data in 2010-2012 should have been addressed more in a more timely manner. Tennessee should make every effort to en sure this cannot be rep eated, better communication

between the TDOH-DLS and the TDEC-DAPC and the loca l monitoring agencies is needed as well as expanded oversight by the TDEC-DAPC quality assurance staff.

Tennessee must address the lack of quality assurance oversight with respect to the industrial classified monitors operating within the State. These monito ring data represent air qu ality used for regulatory decision making purposes and must comply with a ll CFR requirements. Tennessee should coordinate how they intend to address this issue with EPA Region 4.

The problems noted in the audit indicate a strong need for more resources and oversight of local agencies by state personnel. EPA Region 4 believes that expanded oversight of the local programs will help ensure the generation of quality data throughout the state and local programs.Page 9 of 9 SESD Project ID# 13-0544 

## Appendix A

Technical Systems Audit QuestionnaireSESD Version #7.1 Page 1 of 50



# APPENDIX 1

United States Environmental Protection Agency

Region 4

Science & Ecosystem Support Division 980 College Station Road Athens, Georgia 30605

Ambient Air Monitoring Technical System Audit FormSESD Version #7.1 Page 2 of 50



### Table of Contents

1) GENERAL INFORMATION a) Program Organization b) Personnel c) Training d) Facilities

2) QUALITY MANAGEMENT a) Quality Assurance and Quality Control i) Status of Quality Assurance Program ii) Audits b) Planning Documents (including QMP, QAPP ’ s, & SOP ’ s) c) General Documentation Policies d) Corrective Action(s) e) Quality Improvement

3) NETWORK MANAGEMENT / FIELD OPERATIONS a) Network Design b) Changes to the Network since the last audit c) Proposed changes to the Network d) Field Support i) Instrument Inventory ii) Calibration iii) Repair iv) Logbooks and Records

4) DATA MANAGEMENT a) Data Handling b) Software Documentation c) Data Validation and Correction d) Data Processing e) Internal Reporting f) External Reporting

5) LABORATORY OPERATIONS a) Routine Operations b) Laboratory Quality Control c) Laboratory Preventative Maintenance d) Laboratory Record Keeping e) Laboratory Data Acquisition and Handling

f) 

### Specific Pollutants: Particulate Matter (Including High Vol PM 10 , Low Vol PM 10 , PM 2.5 , PM 10 -2.5 & Pb)SESD Version #7.1 Page 3 of 50



### 1) GENERAL INFORMATION

a) Program Organization

Organization Name:

 Tennessee Air Pollution Control division

Address: (include physical and mailing addresses if different)



###  Tennessee Department of Environment and Conservation

 Air Pollution Control Division

 William R. Snodgrass Tennessee Tower 15th Floor

 312 Rosa L. Parks Avenue

 City, State, and Zip Code:

 Nashville, TN 37243

Phone:

 615 -532 -0554 (Div. Main Office)

 615 -532 -0573 (Technical Services Program)

 615 -532 -0525 (APCD Director)

Agency Director:

 Barry Stephens, PE Ambient Air Monitoring (AAM) Network Manager:

 Robert Brawner Quality Assurance Manager:

 Lance Allen QA Auditors:

 Lance Allen, Radford Strong Field Operations Supervisor / Lead:

 Cathy Stoecker Laboratory Supervisor:

 Lab Director: Dr. Bob Read

 Section Manager: Craig Edwards

 PM2.5 Supervisor: Dr. Susan Burchfield

 Metals Supervisor: Anthony Wilson QA Laboratory Manager:

 QA Officer: Tim Morris Data Management Supervisor / Lead:

 Billy Pugh AQS Submitter:



##  Billy PughSESD Version #7.1 Page 4 of 50



### Insert an Organizational Chart (or provide a hard copy during the audit) 

### :SESD Version #7.1 Page 5 of 50



### b) Personnel

In your agency, are site operators responsible for running all of the instruments at their assigned sites, certain instruments (ex.

O 3 

### ) at multiple sites, or a combination of the two? List available personnel and select the ir primary duties:

Name Network

Design and Siting QC

Activities QA

Activities Equipment

Repair &

Maintenance Data & Data

Management Financial

Management Site

Operation (PM,
Gaseous, Met) Other Non

Ambient Air Monitoring

Duties

Robert Brawner X X X X X

Billy Pugh X X

Evelyn Haskin X X

Cathy Stoecker X X X

Rex Bracy X X X

Lance Allen X X

Radford Strong X X

(Field office staff) X

Lab Support X X XSESD Version #7.1 Page 6 of 50

List personnel who have authority or are responsible for:

Activity Name Title

QA Training Field/Lab Cathy Stoecker/ Cr aig Edwards Env. Spec. 6/Chemist

Grant Management Robert Brawner Env. Spec. 6

Purchases Greater than $500 Robert Brawner Env. Spec. 6

Equipment and Service Contract Management Robert Brawner Env. Spec. 6

Staff Appointment Barry Stephens Program Directo r

Monitoring Operations Cathy Stoecker/ Robert Brawner Env. Spec. 6/ Env. Spec. 6

Questions Yes No Comments

Does your agency utilize any contractors in your air monitoring program? If no, skip to

the next table. X

Who is responsible for oversight of contract personnel? DNA

What steps are taken to ensure contract personnel meet training and experience

criteria? DNA

Does the contractor follow an EPA approved QAPP?

- Where/how is this documented?

How often are contracts reviewed and/or

ren ewed?



### Comment on the need for additional personnel, if applicable :



List your district /regional offices and associated staff below (State Agencies Only)

Name Address Staff

Chattanooga EFO 540 McCallie Avenue

, Suite 550,

5th Floor State Office Bldg

, C hattanooga, TN 37402 Phone: (423) 634

- 5745 | FAX: (423) 634

- 6389 Davis, Don Kent, Jeff Poe, Amelia Dyer, Stephanie

Columbia EFO 1421 Hampshire Pike, Columbia, TN 38401 | Phone: (931) 380

- 3371 | FAX: (931) 380

- 3397 Horne, Dorsey Hartsfield, Ben Koroll, Joh n Marston, Bart Williams, CarolSESD Version #7.1 Page 7 of 50

Cookeville EFO 1221 South Willow Avenue, Cookeville, Tennessee 38506 | Phone: (931) 432

- 4015 | FAX: (931) 432

- 6952 Cales, Jeff Cannon, Joey Vestal, Patrick

Jackson EFO 1625 Hollywood Drive | Jackson,

TN 38305 Phone: (731) 512

- 1300 | FAX: (731) 661

- 6283 Garrett, Brad Norville, David Cox, Mike Ledsinger, Terri Keel Thompson, Wilson Hartley, Jessica

Johnson City EFO 2305 Silverdale Road, Johnson City, TN 37601

- 2162 | Phone: (423) 854

- 5400 | FAX: (423)

854

- 5401 Davis, Vera

Wil hoit, Ron Pierce, Preston Justice, Candace Cutshall, Tiffany

Knoxville EFO 3711 Middlebrook Pike, Knoxville, TN 37921 | Phone: (865) 594

- 6035 | FAX: (865)

594

- 6105 Carpenter, Martie Dalton, Tom Smrz, Richard
Barnett, Sam Rudd, Jarrett Justin Long

Erin Stu rgill

Nashville EFO 711 R.S. Gass Blvd, Nashville, TN 37216 | Phone: (615) 687

- 7000 | FAX: (615) 687

- 7078 McCabe, Bill Stubblefield, Ray Cooper, Ken Stimson, Brandi Helton, JohnSESD Version #7.1 Page 8 of 50



### c ) Training

Question Yes No Comments

Does the agency have a training pr ogram and training plan? X X Field staff receives training from the CAM field support program located in the NFO and from the trained site operators. There is no formal training program except for the EPA Reg 4 training they attend.

Where is it documente d? Receipt of training is documented during the annual refresher training provided to FO site operators.

Does it make use of seminars, courses, and/or EPA sponsored courses? X

Are personnel cross

- trained for other ambient air monitoring duties? X To t he extent practical, staff and backups are trained to support each other.

Are training funds specifically designated in the annual budget? X Yes, via SESARM

Does the Training Plan Include: 1. Training requirements by position X The site operators are trained based on their assigned EFO duties.

2. Frequency of Training X A yearly ambient monitoring refresher training class is provided for field staff.

3. Training for contract personnel DNA

4. A list of core QA related courses

Indicate below the three most recent training events and identify the personnel participating in them:

Event Date(s) Participant(s)

1. SO2 monitor training for FO staff. 01/23/2013

02/06/2013 Erin Sturgill and Sam Barnett

2. Annual FO staff train ing 03/31/2011

03/28/2012

03/21/2013 All field office site operators and backups

.

Material covered may vary each year.

3. Reg. 4 Air Monitoring Workshop 03/20 to

22/2012

3/25 to

29/2013 Robert Brawner and Radford Strong

Robert Brawner, Cathy Stoecker and Lance

AllenSESD Version #7.1 Page 9 of 50



### d) Facilities

Identify the principle facilities where the agency conducts work related to air monitoring. Do not include monitoring statio ns, but include facilities where work is performed by contractors or other organizations. Select which purpose(s) each facility serves. Add additional lines as necessary

Facility Address General Office Space Data

Verification

and Processing Criteria Gas

Instrument

Maintenance and Storage Standards

Certification

/ Calibration PM Filter

Weighing Recor ds

Storage Air Toxics

Maintenance and Storage Air Toxics

Laboratory

William R. Snodgrass

Tennessee Tower 15th Floor

312 Rosa L. Parks Avenue X X X

711 R.S. Gass Blvd, Nashville, TN 37216 | X X X

Laboratory Services

630 Hart Lane Nashville, Ten nessee 37243 X X X



### Are monitoring sites ever used for storage of equipment, spare parts or supplies?

 Backup monitoring equipment and/or data loggers.

Identify any facilities that should be upgraded. Identify by function and any suggested improvements or recommendations.

 Laboratory recently completed repairs on PM2.5 weighing room HVAC equipment.

Are facilities adequate concerning safety? I f not, please explain and give suggested improvements or recommendations.

 Facilities are adequate.SESD Version #7.1 Page 10 of 50

Are there any significant changes likely to be implemented to agency facilities within the next three years?

Facility Function Proposed Change

- Date

None



### Comment on the agency’s need for additional physical space (laboratory, office, storage, etc.)

 Additional space for records storage will diminish as the electronic data records conversion and storage program is implemented.

2) QUALITY MANAGEMENT

a) Quality Assurance and Quality Control

i) Status of Quality Assurance Program

QA activities are performed and supported by sources uniquely different from those used in routine QC activities. Independent / dedicated equipment, different personnel and calibration methodologies are purposely used in performing QA audits, performance checks, etc.

Question Yes No Comment s

Does the agency perform QA activities with internal personnel? If no, skip this table. X

Does the agency maintain a separate laboratory to support quality assurance

activities? X Space shared with Technical Services

Has the agency documented and implemented specific audit procedures separate from monitoring procedures? X

Are there two levels of management separation between QA and QC operations? Please explain: X No Currently neither staff or funds.

Does the agency hav e separate auditing equipment and standards (specifically intended for sole use) for audits? XSESD Version #7.1 Page 11 of 50



### Do you conduct biweekly precision point checks?

Are they automated or conducted manually?

Select which of the following additional Q C you conduct at yo ur gaseous sites

Precision Checks Typically

Performed? How? Frequency

Manually Automated

Precision Point X X Quarterly

Zero Precision Span X X Daily

Zero Precision X X Quarterly

Probe Line Integrity Checks No

Other: _________



### ii) Au dits

Question Yes No Comments

Does the agency have separate facilities to support

audits and calibrations? X

If the agency has in place contracts or agreements with another agency/contractor to perform audits/calibrations, please name the organization and briefly describe the type of agreement. None are inplace except where EPA provides

contracted audits.

Does the agency maintain independence of audit standards and personnel? X

Do any site operators audit their own sites? X

Does the agency have a certified source of zero air for performance audits? X

How do you generate your zero air? CSI1204 Zero Air Supply

Does the agency have procedures for auditing and/or validation performance of meteorological monitoring? X

Has the agency established and documented criteria to define agency

- acceptable audit results? XSESD Version #7.1 Page 12 of 50

Question Yes No Comments

Are your sites regularly reviewed for Appendix E siting criteria? X Frequency: Quarterly

Do you conduct internal audits of your air monitoring agency? X

(1) How frequently? Quarterly

(2) What type of audit is conducted (e.g.,

p erformance or systems audit)? Performance/ although both are performed on local, private indust r y, TVA, and Federal Park Services.

(3) Who receives the results of these audits? EPA, Technical Services, and State Quality Assurance

(4) Do you report these results to EPA? X

Please provide a list of internal audit standards currently being used (these do not include standards

used for calibrat ions and/or biweekly checks). Add additional lines as necessary.

Name Model Number Date of Last

Certification Approximate Age (years)

API 400 1

- 30

- 13 21

Roots Meter SM125 32

Cal Bench 4

- 28

- 11 20



### **Please have certifications of standards available for viewing during the auditSESD Version #7.1 Page 13 of 50

Question Yes No Comments

Does your agency participate in NPAP, PM 2.5 PEP, Pb PEP and other performance audits performed by an external party and/or using

external standards? X

If the agency does not participate, please explain why:

Are NPAP audits performed by QA staff, site operators, calibration staff, and/or another group? X

Is your agency audited by the State (if you are a local agency)?

(1) How frequently?

(2) What type of audit is cond ucted (e.g., performance or systems audit)?

(3) Who receives the results of these audits?

(4) Do you report these results to EPA?



### Who is primarily responsible for coordinating participation in: (1) T he National Performance Audit Program (NPAP)?

Robert Brawner (2) PM 2.5 

### Performance Evaluation Program (PEP)?

Robert Brawner (3) Lead Performance Evaluation Program (PEP)?

Robert Brawner

Please complete the table below:

Parameter Audited Date of Last NPAP and/or PEP Audi t

CO DNA

O 3 47

- 001

- 0101

- 44201

- 1 20101027

47

- 105

- 0109

- 44201

- 1 20101027

47

- 121

- 0104

- 44201

- 1 20110707

47

- 149

- 0101

- 44201

- 1 20100825

47

- 149

- 0101

- 44201

- 1 20120615

47

- 149

- 0101

- 44201

- 1 20120716

47

- 165

- 0101

- 44201

- 1 20101026

47

- 165

- 0101

- 44201

- 1 20110928

47

- 187

- 0106

- 44201

- 1 20100826

47

- 187

- 0106

- 44201

- 1 20110928

47

- 187

- 0106

- 44201

- 1 20120614

47

- 189

- 0103

- 44201

- 1 20100826SESD Version #7.1 Page 14 of 50

SO 2 None reported for 2013.

NO 2 DNA

PM 2.5 47

- 045

- 0004

- 88101

- 1 2011/10/18

47

- 099

- 0002

- 88101

- 1 2010/08/18

47

- 099

- 0002

- 88101

- 1 2012/02/ 09

47

- 105

- 0108

- 88101

- 1 2012/07/26

47

- 107

- 1002

- 88101

- 1 2012/03/07

47

- 113

- 0006

- 88101

- 1 2011/10/18

47

- 125

- 1009

- 88101

- 1 2010/08/12

47

- 125

- 1009

- 88101

- 1 2012/09/06

47

- 163

- 1007

- 88101

- 1 2012/12/05

47

- 165

- 0007

- 88101

- 1 2010/12/01

Pb 47

- 163

- 3004

- 14129

- 1 2010 /11/22 (4)

47

- 163

- 3004

- 14129

- 1 2011/04/21 (2)

47

- 163

- 3004

- 14129

- 1 2012/06/02 (2)



### b) Planning Documents

QMP Questions Yes No Comment s

Has the QMP been approved by EPA within the last five years? X Da te of Original Approval: 5/13/1999

Da te of Last Revis ion: 07/29/2005

Date of Last Approval : 10/06/2011

QAPP Questions Yes No Comments

Has the QAPP been reviewed by EPA ? X Date of Original Approval:

Date of Last Revision: Date of Last Approval: 02/05/2007

Does the State review your QAPP prior to E PA review? (local agencies only)

Does your agency have any revisions to your QAPP pending?

How does the agency verify the QAPP is fully implemented? Through training and following the policies in the

document.

How is the QAPP available to the sta ff (e.g.., electronically, hard copies at site, etc.) Electronic copies.

SOP Q uestions Yes No Comments

How does the agency verify that the SOPs are implemented as provided (e.g., staff are regularly observed for correct implementation of SOPs) ? X

How ar e revisions to the SOP distributed? Electronically

How are SOPs available to the staff (e.g.., electronically, hard copies at site, etc.) Electronically

Are any new monitoring SOPs needed? If yes, please list in comments section. X The new SO2 monitor SOP.

List all of the agencies current SOPs :SESD Version #7.1 Page 15 of 50

Title Date of Last EPA Approval Pollutant of Concern (if applicable)

CALIBRATION OF

CHEMILUMINESCENSE AND UV

OZONE MONITOR WITH DASIBI

MODEL 1008 PC U.V.

PHOTOMETER 01/18/1996 EPA Ltr.

CN

- 1100 02/2010 Ozone

PROCEDURE FOR
INSTALLATION, OPERATION

AND MAINTENANCE OF

RECORDERS 01/18/1996 EPA Ltr. Ozone or SO2

RECORDER MAINTENANCE 01/18/1996 EPA Ltr. Ozone or SO2

STATE CONTINUOUS MONITORS DATA QUALITY CONTROL AND

INVALIDATION CRITERIA 02/24/2002 EPA Ltr. Ozone or SO2

INSTALLATION AND OPERATION

OF A MONITOR LABS 8810

OZONE ANALYZER 01/18/1996 EPA Ltr. Ozone

INSTRUCTIONS FOR

CONDUCTING MAINTENANCE

CHECKS ON THE 8810 MONITOR

LABS OZONE ANALYZER 01/18/1996 EPA Ltr. Ozone

INSTRUCTIONS FOR

COMPLETING ML 8810 CHECK

SHEET 01/18/1996 EPA Ltr. Ozone

Installation and Operation of an API

Model 400 Ozone Analyzer 02/01/2000 Ozone

Installation and Operation of an API Model 400E Ozone Analyzer 01/11/2010 Under

revision. Ozone

Installation and Operation of an API Model 400A Ozone Analyzer 02/01/2000 Under

revision. Ozone

Installation and Operation of a TEI Model 49C Ozone Analyzer 02/01/2000 Under

revision. Ozone

INSTALLATION AND OPERATION

OF THE TELEDYNE API M100E

SO 2 MONITOR Submitted to EPA for approval 2013 SO2

CALIBRATION OF SULFUR

DIOXIDE MONITOR WITH

TELEDYNE API T700 DYNAMIC

DILUTION CALIBRATOR Submitted to EPA for approval 2013 SO2

TOTAL SUSPENDED

PARTICULATES 10/02/2009 Submitted to EPA for approval. TSP/Lead

Particulate Matter As PM 10 Size

Selective High Volume Sampler 01/18/1996 EPA Ltr. PM10

Volumetric Flow Controller with Pressure Tap in Filter Holder 01/18/1996 EPA Ltr. With update 6/01/1997 PM10

Standard Operating Procedure for

R&P Model 1400a TEOM®

Continuous PM10 Monitor 11/13/1998 EPA Ltr. PM10

TEO M Flow Check Data Sheet PM

2.5 or PM 10 Instruments 11/13/1998 EPA Ltr. PM10SESD Version #7.1 Page 16 of 50

Standard Operating Procedures For the Rupprecht and Patashnick Model 2025 Sequential Sampler 11/24/1999 EPA Ltr PM2.5

Standard Operating Procedure for the

MetOne SASS 01/07/2002 E PA Ltr Speciated PM2.5

Standard Operating Procedure (SOP)

for the URG

- 3000N Sequential Particulate Speciation System (Interim Version 1.0) 4/13/2007 EPA SOP Speciated carbon sampling

Standard Operating Procedures For the ATEC Model 2200 Toxic Air Sampler 01/29/2003 EPA Ltr Air ToxicsSESD Version #7.1 Page 17 of 50



## c ) General Document Policies

Question Yes No Comments

Does the agency have a documented records management plan? X

Does the agency have a list of files

considered official records and their med ia type? ( i.e. , paper, electronic ) X

Does the agency have a schedule for retention and disposition of records? X

Are records maintained for at least three years? X

Who is responsible for the storage and

retrieval of records? Billy Pugh/Evelyn Haskin CO APCD Craig Edwards DOH Lab Services

What security measures are utilized to protect records? Maintained on a state networked PC and/or server with only employee access to the records.

Where/when does the agency rely on electronic files as primary record? For long term storage of ambient data older than 3

- 5 years

What is the system for storage, retrieval and backup of these files? Local data is stored and maint ained on a PC used for data polling activities and is backed up periodically to DVD/CD

media.SESD Version #7.1 Page 18 of 50



### g) Corrective Action(s)

Question Yes No Comments

Does the agency have a comprehensive corrective action program in place ? X

Have the procedures been d ocumented?

1. As a part of the QA project plan? X

2. As a separate standard operating procedure? X Corrective actions when necessary, are required to be performed in the SOP’s.

Does the agency have established and documented

corrective act ion limits for QA and QC activities? X In the approved QAPP

Are procedures implemented for corrective actions based on results of the following which fall

outside of established limits:

1. Performance Evaluations

2. Precision Goals X

3. Bias Goals

4. NPAP Audits X

5. PEP Audits X

6. Validation of one point QC Check Goals X

7. Completeness Goals X

8. Data Audits X

9. Calibrations and Zero Span Checks X

10. Technical Systems Aud it X When they are performed and

a need identified.

Have the procedures been documented?



### How is responsibility for implementing corrective actions assigned? Briefly discuss Audit reports are forwarded to site operators and to NFO CAM field support staff for implementation of actions recommended.

How does the agency follow up on implemented corrective actions?SESD Version #7.1 Page 19 of 50



### CAM field support follows up on the implementation of needed corrective

actions.

Please fill out the table below for precision

Pollutant A ction Level Corrective Action (if exceeded) Redbook Guidance

Action Level Reference

O 3 < +7% (percent

difference)

90% CL CV <

7% Perform follow

- up Lv1 Pck, verify

deviation and perform multi

- point calib

and re

- calib as necessary. QA Handbook Volume II, Ap pendix D Revision No. 1 Page 3 of 30

CO DNA QA Handbook Volume II, Appendix D Revision No. 1 Page 5 of 30

N O 2 DNA QA Handbook Volume II, Appendix D Revision No. 1 Page 7 of 30

S O 2 < +10% (percent

difference)

90% CL CV <

10% Perform follow

- up Lv1 Pck, verify

deviation and perform multi

- point calib

and re

- calib as necessary. QA Handbook Volume II, Appendix D Revision No. 1 Page 9 of 30

Please fill out the table below for accuracy

Pollutant Action Level Corrective Action (if exceeded) Redbook Guidance

Action Level

O 3 Percent

difference of

each audit level

< 15% Perform follow

- up Lv1 Pck, verify

deviation and perform multi

- point calib

and re

- calib as necessary. QA Handbook Volume II, Appendix D Revision No. 1 Page 3 of 30

CO DNA QA Handbook Volume

II , Appendix D Revision No. 1 Page 5 of 30

NO 2 DNA QA Handbook Volume II, Appendix D Revision No. 1 Page 7 of 30

SO 2 Percent

difference of

each audit

level < 15% Perform follow

- up Lv1 Pck, verify

deviation and perform multi

- point calib

and re

- calib as nec essary. QA Handbook Volume II, Appendix D Revision No. 1 Page 9 of 30



### At what point do you invalidate data?

When the resul ts of the level one check’s indic ate the instrument response is in excess of the invalidation criteria for that parameter. For gaseous parameters the maximum

allowable is +-15%.SESD Version #7.1 Page 20 of 50



### h) Quality Improvement

Question Yes No Comments

Have all deficiencies indicated on the previous TSA been corrected? If not, explain. X Training of staff has been documented

for the new and current field staff.

What actions were taken to improve the quality system since the last TSA?

Since the last TSA, do your control charts indicate that the overall data quality for each pollutant steady or improving? The results are indicating a steady

state. The results also are comparable with the previous year’s results.

For areas where data quality appears to be declining

, has a cause been determined? We have experienced issues with the

lab weighing operations which have

been resolved. Are there pending pl ans for quality improvement such as purchase of new or improved equipment, standards, or

instruments? X We are planning on replacement of the strip chart recorders with an electronic data storage system.SESD Version #7.1 Page 21 of 50



### 3 ) NETWORK MANAGEMENT/FIELD OPERATIONS

a) Network Design

Complete the table below for each of the sites in your air monitoring network (active in the last three years) with the numbe r of instruments measuring each pollutant (including NCore low level instruments

– e.g. 1 low level CO + 1 regular CO = 2 CO instruments).

AQS ID Common Site NamePbCOSO2NO2O3 Manual Collo

cated Contin

uousMeteorologyPM2.5PM10PM2.5speciationPM2.5CarbonPM2.5PM10PM2.5PM10

470090101

470090011

470450004

470990002

471050108

471071002

471130006

471192007

471 251009

471410005

471450004

471631007

471650007 GREAT SMOKY MOUNTAINS NP LOOK ROCK

2007 SEQUOYAH AVENUE

175

- B GREENWOOD STREET

BUSBY RD

130 WEBB DRIVE
SAINT MARK AME ZION CHURCH, 707 NORTH JA

1371

- A NORTH PARKWAY JACKSON, TN 38301

1600 NASHVILLE HWY

1514 G OLF CLUB LANE

630 EAST 20TH STREET

HARRIMAN HIGH 1002 N. ROAN ST MOVED FRO

1649 D STREET

ROCKLAND RECREATION AREA

- OLD HICKORY DAM 12 2 2 2 10

470111002

471451001

471730107 2850 Keith Street NW

199 Lake Shore Rd, Kingston TN 37763

DONAHUE PROPER TY ON DONAHUE ROAD 1 1 2

471633004

and POC2 364 Exide Dr 2SESD Version #7.1 Page 22 of 50

The Shelby Co Local Air program operates an NCore site. An NCore like site is also operated by the NPS and TVA at LookRock. 470010101

470090102

470890002

471050109

471210104

471490101

471632002

471632003

471650007

471650101

471870106

471890103 FREELS BEND_STUDY AREA MELTON LAKE Oak R

GREAT SMOKY MOUNTAINS NP

- CADES COVE

2393 Forrester Road

1703 ROBERTS RD

8401 HIGHWAY 60

EAGLEVILLE PUCKETT'S FARM

HILL ROAD

KETRON MIDDLE SCHOOL ON BLOOMINGDALE RD.

ROCKLAND RECREATION AREA

- OLD HICKORY DAM

COTTONTOWN WRIGHT'S FARM

FAIRVIEW MIDDLE SCHOOL CROW CUT ROAD

CEDARS OF LEBANON STATE PARK 12

470010101 FREELS BEND_STUDY AREA MELTON LAKE (2013) 1

Complete the table below with the number of spare monitor (s) you have on hand for measuring each pollutant (including NCore low level instruments).

Pb CO SO 2 NO 2 O 3 Manual Collocated Continuous
Meteor

ology PM 2.5 PM 10 PM 2.5 speciation PM 2.5

Car bon PM 2.5 PM 10 PM 2.5 PM 10

4 NA 1 NA 9 5 3 3 1 4

TEOMS TEOMS 2SESD Version #7.1 Page 23 of 50

Select which of the following are typically found at your Gaseous and PM sites

Equipment/ Supplies Gaseous PM

Data Logger X X

Calibrator X X

Gas Blender

Zero Air System X

Per m Tube Oven

Paper Strip Chart X

Permanent Site Computer

Phone X

Modem X X

DSL Connection

Cellular Modem Connection

Meteorological Station

Interior Temperature Probe X X

Interior Min/Max Thermometer

Air Conditioner / Heater X X

Unin terrupted Power Supply or Backup Power

Instrument Manuals X

Instrument Logbooks

Site Logbook X (for each monitor) X (for each monitor)

SOP’s X X

Other:______________

Other:______________SESD Version #7.1 Page 24 of 50



### If none of the above is applicable, please describe your probe system.



How often do you clean / replace your probe lines?

 Yearly

What material are your probe lines made of?

 FEP Teflon

What material are your inlet funnels made of (e.g. glass, Teflon, plastic)?

 Stainless Steel

How often do you change the particulate filter on the back of the instrument?

 Monthly

How often do you clean your glass manifold (if applicable)?

NA

How do you connect your instrument to your data logger (analog, RS232, or Ethernet)? Analog Select which of the following are typical of your Probe System

Tee’d Probe System X

Retractable Probe System

Glass Manifold within Probe System

Heat Tape for Moisture Control XSESD Version #7.1 Page 25 of 50



### Has EPA granted waivers for any of your monitoring sites?

DNA

Are you aware of any sites that are not currently meeting the requirements of 40 CFR Part 58 Appendix D & E?

None

Questio n Yes No Comment

Are hard copy site information files retained by the agency for all air monitoring stations within

the network? X

Does each station have the required information including:

1. AQS Site ID Number? X

2. Photogra phs/slides to the four cardinal compass points? X

3. Startup and shutdown dates? X

4. Documentation of instrumentation? X

Who has custody of the current network

documents? Name: Evelyn Haskin

Title: Env. Spec. 3

Does the current level of moni toring effort, station placement, instrumentation, etc., meet requirements imposed by current grant

conditions? X

How often is the network siting reviewed? Yearly

Do any sites vary from the required frequency in

40 CFR 58.12? X

Does the number of co llocated monitoring stations meet the requirements of 40 C FR 58 Appendix A? X

Is each method for PM monitoring collocated with the same method type? ( 40 CFR 58 Appendix A Section 3.2.5.2 paragraph (a) ) X

Question Yes No Comments

What is the date of the most current Monitoring

Network Plan? 07/01/2013 (F inal to EPA for Review)

Is it available for public inspection? XSESD Version #7.1 Page 26 of 50



### b) Changes to the Network since the Last Aud it

Please provide information on any site changes since the last audit:

Pollutant Site ID Site Address Site

Added/Deleted/

Relocated Reason (Assessment, lost lease , etc.)

Provide documentation of rea son for

each site change

* 

### * * * *

*See details contained in the previous and current annual network reviews. c) Proposed Changes to Network

Please provide information on proposed site changes, including documentation of the need for change and any required approvals:

Pollutant Site ID Site Address Site to be

Added/Deleted/

Relocated Reason (Assessment, lost lease, etc.)

Provide documentation of reason for

each site change

* 

### * * * *

* See details contained in the previous and current annual network reviews.

d) Field Support

Q uestion Yes No Comments

On average, how often are most of your stations visited by a field operator?

___ 1 ___ per ___ week

____

Is this visit frequency consistent for all reporting organizations within your agency? XSESD Version #7.1 Page 27 of 50



### i) Instrument Inventory

Please l ist instruments in your inventory:

Pollutant Manufacturer Models Reference or Equivalent

Method Number

SO 2 TEI 100E EQSA

- 0495

- 100

NO 2 NA

CO NA

O 3 Teledyne API

Thermo 400A, 400E
49C, 49I EQOA

- 0992

- 087 EQOA

- 0880

- 047

PM 10 Graseby RFPS

- 1287

- 063

PM 2 .5 R&P/Thermo Partisol Plus 2025 PM2.5 Seq RFPS

- 0498

- 118

Pb Graseby

Tisch Ref Method (High Volume)

Multi gas calibrator Teledyne T700

PM 2.5 speciation Met One

URG SASS

3000N

PM 10

- 2.5 speciation

PM 10

- 2.5 FRM mass

Continuous PM 2.5 mass R&P/The rmo TEOM 1400 a

Trace levels (CO) NA

Trace levels (SO 2 ) NA

Trace levels (NO) NA

Trace levels (NO y ) NA

Surface Meteorology Climatronics

Data Logger ESC

ESC 8832

8816

Others

Continuous PM10 R&P/Thermo TEOM 1400 a EQPM

- 1090

- 079SESD Version #7.1 Page 28 of 50



### ii ) Calibration

Please indicate the frequency of multi point calibrations:

Pollutant Frequency Name of Calibration Method

O 3 Quarterly (during O 3 season) UV Photometry Method

PM 2.5 Yearly Streamline Pro Method

SO2 Quarterly Gas Dilution Method

PM10 Quarterly Streamline Pro or Orifice (as appropriate)

Pb Quarterly Orifice Method

Please list the authoritative standards used for each type of flow measurement, indicate the certification frequency of standards to maintain field material/device credibili ty:

Flow Device Primary Standard Frequency of Certification

HiVol Orifice Rootsmeter Once per year (flow device)

Streamline Returned to manufacturer (Streamline Pro) Once per year (flow device)

Trical NA

Bios Stands as Primary Standard

(Manufacturers certificate)

DeltaCal NA

Gilibrators NA

Tetraca l Returned to manufacturer Once per year (flow device)SESD Version #7.1 Page 29 of 50

Please list the authoritative standards and frequency of each type of dilution, permeation and ozone

calibrator and indicate the certificatio n frequency:

Calibrator Primary Standard Frequency of Certification

Permeation Calibrator Flow

Controller NA

Permeation Calibrator Temperature NA

Dilution Calibrator air and gas

Flow Controllers Sierra Calbench Quarterly (dilution calibrator)

Field /Working Standard

Photometer Dasibi 1008PC Prior to the ozone season for the calendar year and again at end of

season

Ozone Generator QA Ref. Photometer API 400 referenced against Region 4 photometer Once per year

Please identify station standards for gaseous pollutants at representative air monitoring stations

Parameter Station(s) Identification of Standard(s) Recertification Date(s)

CO NA

NO 2 NA

SO 2 1 Manufacturer certified cylinder 1/28/2013 (initial certification)

O 3 9 Dasibi 1008PC Various dates in February 2013



### If an instrument goes down, at what length of time would you recalibrate the instrument before bringing it back online (24 hours, 48 hours, etc.)?

According to SOP Section No. A.2.9.2 paragraph 15 ‘data following an analyzer malfunction or period of non-operation should be regarded as invalid until the next subsequent level one check unless unadjusted zero and span readings at that time can support its validity’. Therefore we would recalibrate if the zero and span readings show a problem. Also, level 1 and precision checks are performed weekly.SESD Version #7.1 Page 30 of 50

Question Yes No Comments

Are field calibration procedures included in the

document SOPs? X Location (site, lab, etc.): Site

Are calibrations performed in keeping with the guidance in s ection Vol II of the QA Handbook for Air Pollution Measurements Systems? X If no, why not?

Are calibration procedures consistent with the operational requirements of Appendices to 40 CFR 50 or to analyzer operation/instruction manuals? X If no, why not?

Have changes been made to calibration methods based on manufacturer’s suggestions for a particular

instrument? X

Do standard materials used for calibrations meet the requirements of appendices to 40 CFR 50 (EPA reference methods) and Appendix A to 40 CFR 58 (traceability of materials to NIST

- SRMs or CRMs)? X

Where do field operations personnel obtain gaseous

standards? SO 2 obtained from manufacturer of EPA protocol certified gases.

O 3 from transfer standard (Dasibi 1008PC)

Are those standards certi fied by: 1. The agency laboratory?

2. EPA/NERL standards laboratory?

3. A lab separate from this agency’s but part of the same reporting organization?

4. The vendor? X SO 2

5. Other (describe) X O 3 – cali brator certified against reference photometer in shop

How are the gas standards verified after receipt? SO 2 - Against previous standard

Are you involved in the EPA protocol gas certification program? X

What equipment is used to perform calibrations (e .g., dilution devices) and how is the performance of this equipment verified? Dilution calibrator is certified against Sierra Calbench every 3 months

O 3 calibrators are certified against reference photometer in shop at beginning and end of season

Does the documentation include expiration date of

certification? X

1. Reference to primary standard used? X

2. What traceability is used? Records kept of calibrator response vs primary standard, including %

difference

Is calibration equipment ma intained at each station? X

How is functional integrity of this equipment

documented? Calibration records kept on file

Who has responsibility for maintaining field

calibration standards? Technical ServicesSESD Version #7.1 Page 31 of 50



### iii ) Repair

a) Who is responsible for performing preventative maintenance? Some PM is performed by site operators. Tech Services staff perform other

PM.

b) Is special training provided to them for performing preventative maintenance? Briefly comment on background or courses. New personnel are trained by experienced personnel on site. Personnel attend training courses when available. Had training class for operators 03/21/2013.

c) Is this training routinely reinforced? If no, why not?

Yes

d) What is your preventative maintenance schedule for each type of field

instrumentation? Most preventative maintenance is done per manufacturer’s

recommendations.

O3: Weekly checks, monthly replace particulate filter SO2 Weekly checks, monthly replace particulate filter PM2.5 Monthly checks and maintenance TEOM Monthly checks and maintenance SASS Monthly checks and maintenance URG Monthly checks and maintenance

Pb Quarterly maintenance PM10 Quarterly maintenance

e) If preventative maintenance is MINOR, it is performed at (check one or more):

_ X__ Field Station ___ Headquarters Facilities ___ Equipment is sent to Manufacturer

f) If preventative maintenance is MAJOR, it is performed at (check one or more): ___ Field Station

_ X__ Headquarters Facilities ___ Equipment is sent to Manufacturer

g) Does the agency have service contracts or agreements in place with

instrument manufacturers? Indicate below which instrumentation is

covered.

No service contracts.SESD Version #7.1 Page 32 of 50



### h) Comment briefly on the adequacy of availability of the supply of spare parts, tools and manuals available to the field operator to perform any necessary maintenance activities. Do you feel that this is adequate to prevent any significant data loss? Yes, a supply of the more commonly used spare parts are available. Manuals are available. Spare parts include lamps, scrubbers, filters,

pumps, etc.

i) Is the agency currently experiencing any recurring problem with equipment or manufacturer(s)? If so, please identify the equipment manufacturer, and comment on steps taken to remedy the problem.

None

j) Have you ever lost any data due to repairs in the last 2 years?

More than 24 hours? Yes

More than 48 hours? Yes

More than a week? Yes An incident that took over a week to resolve involved loss of electrical power to the entire site due to vandalism (Freels Bend). Other incidents (24, 48 hrs) often relate to the time involved to respond when a site visit from Technical Services personnel is required. Tech Services personnel strive to bring to the site any item needed to resolve the problem, including replacing the equipment if necessary.

k) Explain any situations where instrument down time was due to lack of preventative maintenance or unavailability of parts.

None knownSESD Version #7.1 Page 33 of 50



### iv) Logbooks and Records

Question Yes No Comments

What type of sta tion logbooks are maintained at each monitoring station? (Maintenance logs, calibration logs, personal logs, etc.) One logbook for each type of monitor at the station to include maintenance and calibration and anything that happens with that monitoring sit e

What information is included in the station logbooks? Date, time, initials of person(s) on site, description of work (calibration checks, filter changes, maintenance, etc)

Who reviews and verifies the logbooks for adequacy of station performance? QA Auditors.

How often are logbooks reviewed? During periodic audits.

How is control of logbook maintained? Station operators maintain custody.

Where is the completed logbook archived? In the CO files.

What other records are retained? All other records pr epared or generated and supplied for

review.

1. Zero span record? X

2. Gas usage log? X SO2

– operator notes cylinder pressure on L1PC form (not a separate log)

3. Maintenance log? X

4. Log of precision checks? X

5. Con trol charts X

6. A record of audits? X

Please describe the use and storage of these

documents. Reviewed and checked/corrected as needed, used to input

needed data then stored/archived.

Are calibration records, or at least calibration

constants, available to field operators? X

Are logbooks backed up regularly to ensure against theft/vandalism? X Site operators are to make a copy of the logbook and submit to CO each year.SESD Version #7.1 Page 34 of 50



### 3) DATA MANAGEMENT

a) Data Handling

Question Yes No Comments

Is there a procedure, description, or a chart which shows a complete data sequence from point of acquisition to point of submission of data to EPA? X Data handling SOP. The Electronic copy on H drive.

Please describe or provide a data flow diagram from

co llection to submittal of data. Please include detail regarding data review and validation. Data is retrieved hourly each day by Tech Services of TN APCD via AgilaireVision software. It is reviewed each work day to establish the validity and

to ensure all edits are performed. The operator is sent a report each month that includes the Level 1 Precision checks, the Hourly reports for each parameter, and Cover Letter. The operator reviews the data and sends it all back to Tech Services along with the strip cha rts, the Report of Missing data, the Monitor Checksheets and any comments concerning

the data. Are procedures for data handling (e.g. data reduction, review, etc.) documented? X

In what media (e.g., diskette, data cartridge, or telemetry) and formats d o data arrive at the data processing location? Please list below:

Category of Data (by Pollutant) Data Media and Formats

Ozone Telemetry retrieval

SO2 Telemetry retrieval

Continuous Particulates PM10 and PM2.5 Telemetry retrieval

Metals, Non Continuo us Particulates Lab report via email

How often are data received at the processing location from the field sites and laboratory? Field site reports Monthly. Lab reports Quarterly or

bi

- Quarterly. Is there documentation accompanying the data regarding any media changes, transcription, or flags which have been placed into the data before data are released to agency internal data processing? X

- Describe the type of documentation Cover letter has a legend of the null flag codes and a place for the opera tor to recommend changes.

How is data actually entered into the computer system (e.g. computerized transcription (copy from disk or data transfer device), manual entry, digitization of strip charts, or other)? Manual entry for making the needed changes to the data that were telemetrically retrieved.

For manual data, is a double

- key entry system used (e.g., a second pair of eyes double checking for transcription errors)? XSESD Version #7.1 Page 35 of 50



### b) Software Documentation

Question Yes No Comments

Does your agency submit data directly to AQS? X

Does your agency participate in AirNow? X

How does your agency process P/A data? Yes, precision is handled in house and the Accuracy is handled through our field office QA auditor. Does the agency have information on the rep orting of precision and accuracy data available? X

What software is used to prepare air monitoring data for release into the AQS and AirNow database?

Please list the documentation for the software currently in use for data processing, including the

nam es of the software packages, vendor or author, revision numbers, and the revision dates of the

software. “Airvision “ by Agilaire, Version 2.8.14

What is the recovery capability in the event of a significant computer problem (i.e. how much time

and data would be lost)? Data should be 100% recoverable as the database is regularly backed up.

Has your agency tested the data processing software to ensure its performance of the intended function is consistent with the QA Handbook, Volume II, and

Section 14. 0? We do not know. We have compared the collection of the data from our original AQS

software database EDAS before going live with Airvision.

Does your agency document software tests? x If yes, provide the documentationSESD Version #7.1 Page 36 of 50



### c) Data Validation and Correction

Question Yes No Comments

Has your agency established and documented the

validation criteria? X

Does documentation exist on the identification and applicability of flags (i.e., identification of suspect values) within the data as recorded with t he data in the computer files? X

Does your agency document the data validation criteria including limits for values such as flow rates, calibration results, or range tests for ambient

measurements? X

1. If yes, please describe what action the da ta
validator will take if he/she find data with limits exceeded (e.g., flags, modifies, deletes, etc.) Based on the difference from known tolerance limits for the response of the monitor, the data is subject to invalidation. Each monitor type has established ranges of performance for the data to be acceptable to use in population of the AQS

database.

2. If yes, give examples to illustrate actions taken

when limits are exceeded. Monitor is replace or repaired and any data is flagged appropriately from the last available valid performance checks.

How does the agency track missing data? Daily logs are kept of each continuous monitor. Lab reports and field operator reports document missing

data for non

- continuous monitor s.

Please describe how changes made to data that were submitted to AQS and AirNow are documented. A monthly report that the operator reviews and then makes comments upon are used in conjunction with the daily log. The database is then updated prior to

sub mittal.

Who has signature authority for approving

corrections? Name: Billy Pugh Program Function: AQS Data Coordinator

What criteria are used to determine a data point should be deleted? Discuss briefly Items such as invalid temperature ranges or monito r flow checks that provide evidence that the monitor was not properly functioning. Water in the lines and sporadic noisy responses are also things that we may use to justify invalidating a data point.

What criteria are used to determine if data need to

be reprocessed? Discuss briefly

Are corrected data resubmitted to the issuing group

for cross

- checking prior to release? X During the review of the operator’s monthly reports.SESD Version #7.1 Page 37 of 50



### d) Data Processing

Question Yes No Comments

Does the agency generate da ta summary reports? X Report of Monthly data to Operators, Quick Look etc Please list at least three reports routinely generated, including the information requested below.

Report Title Distribution Period Covered

Quick Look Report EPA and

TDEC Yearly

Data Completeness Report TDEC Quarterly

P&A report EPA and

TDEC Yearly

Question Yes No Comment

How often are data submitted to AQS and AirNow? Air now is daily. AQS is quarterly.

Briefly comment on difficulties the agency may

have encountered in co ding and submitting data following the guidance of AQS guidelines Does the agency routinely request a hard copy printout on submitted data from AQS? X

Are records kept for at least 3 years by the agency in an orderly, accessible form? X Five years

If yes, does this include:

1. Raw Data? X

2. Calculation? X

3. QC Data? X

4. Reports? X

If no, please comment

Are PM 10 concentrations corrected to EPA standard temperature and pressure conditions (i.e. 298 ̊K, 760 mm Hg) before input to AQS? X

Are PM 2.5 and Lead concentrations reported to AQS under actual (volumetric) conditions? X

Are audits on data reduction proced ure performed

on a routine basis? X Frequency

- monthly

Are data precision and accuracy checked each time they are calculated, recorded, or transcribed to

ensure incorrect values are not submitted to EPA? XSESD Version #7.1 Page 38 of 50



### e) Internal Reporting

What internal repor ts are prepared and submitted as a result of the audits required under 40 CFR 58, Appendix A?

Report Title Frequency

Quality Assurance Audit Quarterly

Audit Flow Check sheet monthly

What internal reports are prepared and submitted as a result of p recision checks also required under 40 CFR 58, Appendix A?

Report Title Frequency

Level 1 Precision Check sheet Weekly or Bi

- weekly

Question Yes No Comments

Do either the audit or precision check reports

indicated include a discussion of correc tive actions initiated based on audit or precision check results? X When applicable.

Who has the responsibility for the calculation and preparation of data summaries? To whom are

such summaries delivered?

Name Title Type of Report Recipient

Evelyn H askin Environmental Specialist AQS submittal of Non

Continuous PM 2.5. Billy Pugh

Site Operators Environmental Specialist Level 1 Precision Check Sheets, Monthly Reports Billy Pugh

Billy Pugh Environmental Specialist, AQS Data Coordinator Monthly reports of the Raw readings and

Precision data retrieved Telemetrically. Site OperatorsSESD Version #7.1 Page 39 of 50



### f) External Reporting

For the past 3 calendar years, please list all quarters that data were submitted beyond the 90 day requirement:

None

Identify the individual within the agency with the responsibility for reviewing and submitting the data to AQS.

Billy Pugh, ES IV

Question Yes No Comments

Does your agency report the Air Quality Index? X Using AIRNOW

Has your agency submitted its annual data summary

repor t (as required in 40 CFR 58.26)? X

If yes, did your agency’s annual report include the following:

1

. Annual precision and accuracy information

d escribed in Section 4 of Appendix A? X

2

. Location, date, pollutio n source and duration o f all episodes reaching the significant harm levels? X

Is Data Certification signed by a senior officer of your agency? X



### 4) LABORATORY OPERATIONS

a) Routine Operations

What analytical methods are employed in support of your air monitor ing network? Add other pollutants not listed to the table.

Pollutant Analysis Name or Description of Method

PM 10

PM 2.5 40 CFR Part 50, App. L Reference Method for the

Determination of Fine Particulate

Matter as PM 2.5 in the Atmosphere

Pb EQL

- 0710

- 192 Heated Nitric Acid Block Digestion and ICP/MS Analysis For Lead (Pb) on TSP High

Volume Filters

PM 10

- 2.5



### Please describe areas where there have been difficulties meeting the regulatory requirements for any of the above analytical methods.SESD Version #7.1 Page 40 of 50

Please identify the current versions of written methods, supplements, and guidelines that are used in your agency. Add other pollutants not listed to the table.
Analysis Documentation of Method

PM 10

PM 2.5 Gravimetric Analysis for Measurement of Fin e Particulate Matter as PM 2.5 in Air

(Env

- Inorg PM 2.5 SOP 201 Revision 6; EPA Quality Assurance Guidance Document

2.12

Pb Digestion Procedure For Metals Analysis (SOP 275.1 R

- 08) ICP

- MS Analysis For

Lead (Pb) on TSP High Volume Filters (SOP 284.1

- R.01)

PM 10

- 2.5

Question Yes No Comments Were procedures for the methods listed above included in the agency’s QA Project Plan or SOPs and reviewed by EPA? X

Are the SOPs easily/readily accessible for

use and reference? X

Does your lab have suff

icient instrumentation to conduct analyses? X



### Please describe needs for laboratory instrumentation

b) Laboratory Quality Control

Please identify laboratory standards used in support of the air monitoring program, including standards which may be kept in an analytical laboratory and standards which may be kept in a field support area or quality assurance laboratory that is dedicated to the air monitoring program (attach additional sheets if appropriate):

Parameter Type ID / Serial Number Last Recer tification Date

Weights Class 1 May 6, 2013

Temperature Dickson D200 data logger

- NIST Traceable May 2013

Relative Humidity Dickson D200 data logger

- NIST Traceable May 2013

Barometric Pressure

Balance Sartorius MC5

Microbalance 8/27/2013

Ot herSESD Version #7.1 Page 41 of 50



### **Please have certifications of standards available for viewing during the auditSESD Version #7.1 Page 42 of 50

Question Yes No Comments Are all chemicals and solutions clearly

marked with an indication of shelf life? X

Are chemicals removed and properly disposed of when shelf life expires? X

Are only ACS grade chemicals used by the laboratory? X



### Comment on the traceability of chemicals used in the preparation of calibration standards. Stock standards and working standards are logged and identified with a unique number. These ID numbers are entered on run logs and digestion logs.

Question Yes No Comment

Does the laboratory purchase standard solutions such as those for use with lead or other metals analysis? X

Are all calibration procedures documented? X Tit le:SOP 284.1

Revision Number:01

Document Location: Y: drive
Are at least one duplicate, on blank, and one standard or spike included with a given analytical batch? X

Briefly describe the laboratory’s use of data derived from blank analyses: Pb: if blan k level exceeds acceptance criteria run is rejected and corrective action taken. PM2.5: Blanks used to determine potential cross

contamination in the clean room. If lab blanks

exceed +/

- 15 ug then corrective action is taken.

Are criteria established to d etermine whether blank data is acceptable? X Pb

– if value of the LRB is 2.2

times the MDL value fresh aliquots must be analyzed

PM2.5

– Criteria set forth in the

FRM of +/

- 15 ug



### How frequently and at what concentration ranges does the lab perform duplicate analysis? What constitutes an acceptable agreement? Pb: 10% of the batch size or at a minimum one duplicate per batch. Acceptable agreement is 20 % between sample result and its duplicate result.

PM2.5: Reweigh one filter per each batch of ten. The first filter in the batch is reweighed after the 10 th 

### filter is weighed. Acceptable agreement is +/-15 ug between the first and second weighings.

Please describe how the lab uses data obtained from spiked samples, including the acceptance criteria (e.g., acceptable percent recovery). Pb: Recommended acceptance criteria is 80% to 120%. If the recovery falls outside this rangeSESD Version #7.1 Page 43 of 50



### corrective action must be taken. Corrective action can include redigestion and reanalysis.SESD Version #7.1 Page 44 of 50

Question Yes No Comments
Does the laboratory routinely include samples of reference material within an analytical batch? X

If yes, indicate frequency, level, & material

Used Pb: second source standard spiked at 50 ppb in each batch analyzed (spiked Pb filter strip)

Are mid

- range standards included in analytical

batches? X

Please describe the frequency, level, and compound

used in the comments section. Pb: second source standard spiked at 50 ppb in each batch analyzed (spiked Pb filter strip)

Are criteria for rea l time quality control established

that are based on results obtained for the mid

- range standards discussed above? X

If yes, briefly discuss them in the comments

section or indicate the documentation in which they can be found: Acceptanc e is +/

- 10% of spike concentration

Are appropriate acceptance criteria for each type of analysis documented? X



### c) Laboratory Preventative Maintenance

Question Yes No Comments

For laboratory equipment, who has the responsibility for performing pre ventative maintenance? Supervisor and chemist responsible for analysis and service engineer

Is most maintenance performed in the lab? X

Is a maintenance log maintained for each major laboratory instrument? X

Are service contracts in place for major analytical

instruments? XSESD Version #7.1 Page 45 of 50



### d) Laboratory Record Keeping

Question Yes No Comments

Are all samples that are received by the laboratory logged in? X

If appropriate, is sample shipping temperature recorded upon arrival? X

Discuss sample routing an d special needs for analysis (or attach a copy of the latest SOP which covers this). Attach a flow chart if possible. PM2.5: Tared filters are prepared and shipped to the various site operator field offices. Exposed filters are returned in protective c ases and at proper transport temperature. Chain of custody

information is included. Pb: Filters are prepared, placed in filter envelopes, and shipped to the site operator field office. Filters are returned with chain of custody

information on filter enve lope completed. Are log books kept for all analytical laboratory

instruments? X

Are there log books or other records that indicate the

checks made on materials and instruments such as weights, humidity indicators, balances, and

thermometers? X

Are l og books maintained to track the preparation of

filters for the field? X

1. Are they current? X

2. Do they indicate proper use of conditioning? X

3. Weighings? X

4. Stamping and numbering? X

Are log books kept which track filters returning from the field for analysis? X

How are date records from the laboratory archived? Hard copy records are placed in archive boxes:

records also scanned to server

1. Where? In laboratory on 6 th floor or on server

2. Who has t he responsibility? Title? Supervisors; Susan Burchfield, Chemist III and Anthony Wilson, Chemist III

3. How long are records kept? Five years

Does a chain

- of

- custody procedure exist for laboratory samples? Title & Date: Procedure for Receiving Env ironmental Samples for Analysis, August 21,2013

Revision Number:6

Location: Y: driveSESD Version #7.1 Page 46 of 50



### e) Laboratory Data Acquisition and Handling

Question Yes No Comments

Identify those laboratory instruments which make use of computer interfaces directly to

record d ata. Which ones use strip charts? Integrators? Sartorius MC5 balance: Computer interface Perkin Elmer ELAN 9000 ICP/MS: computer interface

Are QC data readily available to the analyst during a given analytical run? X

What is the laboratory’s capabil ity with regard to data recovery? In case of problems, can they recapture data or are they dependent on computer operations? Discuss briefly. PM2.5 data is maintained on a server and is backed up nightly.

Pb raw data resides on instrument hard drive. Pri ntouts are
scanned to the server and Pb results are entered into the LIMS. Additionally the client reports are stored on the server. The server is backed up nightly. Has a user’s manual been prepared for the automated data acquisition instrumentation? X



### Please provide below a data flow diagram which establishes, by a short summary flow chart: transcriptions, validations, and reporting format changes the data goes through before being released by the laboratory.

PM2.5

1. Weights are transmitted from microbalance using Wedge software on the PC to weighing templates located on the server for both tare and exposed weighing sessions.

2. After weighing the templates are printed and the data is entered into the PM2.5 Access database. Printed weighing templates are filed.

3. Chain of custody information is entered into the database as the exposed

filters are returned.

4. All data including weighing session data and chain of custody information are peer reviewed or second checked for correctness in the database. Any mistakes are returned to the PM2.5 lab tech for correcting.

5. Reports are generated monthly from the database into Excel.

6. Ten percent of the data included in the report is checked for correctness. This includes checking weighing session data and chain of custody information. Any deficiencies are corrected before emailing the reports.

7. Excel reports are emailed to the clients and stored on the server.

Pb

1. Filters are digested and analyzed by ICP/MS

2. Data is captured by instrument software and stored on PC hard drive; a printout is generated in real time

3. The run is reviewed for acceptability. LRB, LFB, spikes, duplicates, QCS, and calibration curves are all checked to ensure that they are in tolerance.

4. The run is also peer reviewed.SESD Version #7.1 Page 47 of 50



### 5. The filter results are entered into an Excel calculation sheet to calculate the results in required units, i.e. ug/m3

6. The results are entered into the LIMS and into the client requested Excel

format.

7. The client report is reviewed by the analyst, supervisor, and section manager.

8. The report is emailed to the client and the Excel file is stored on the server.

9. The printout of the raw data is scanned to the server.SESD Version #7.1 Page 48 of 50



### f) Specific Pollutants: Particulate Matter

High Vol PM

10 Question Yes No Comments

Does the agency use filters supplied by EPA?

Do filters meet the specifications in 40 CFR 50?

Are filters visually inspected for defects before exposure? Where does the laboratory keep records of the serial

numbers of filters? Are the temperature and humidity monitors

calibrated?

Are balances checked with Class S or Class M weights each day when they are used?

To what sensitivity are filter weights recorded?

What method of documentation is used to record filter weighing sessions? (e.g., logbook, computer software, etc.)

During conditioning, are the following true:

(1) Filters equilibrate for a minimum of 24 hours

(2) The temperature range is from 15 ̊C

- 30 ̊C

(3) Temperature control is ±3 ̊C SD over 24 hrs

(4) Humidity range is 20%

- 45% RH

(5) Humidity control is ± 5% SD over 24 hrs

(6) Pre/post sampling RH difference in 24

- hr
means is ≤± 5% RH (7) Balance is located in the conditioning

environment Are filters packaged for protectio n while transporting to and from the monitoring stations? Are filters shipped at ambient temperature to the monitoring stations? Are filters shipped at ambient temperature from the field to the laboratory? Are exposed filters reconditioned for at least 24 hrs in the same conditioning environment as for unexposed filters? Briefly describe how exposed filters are prepared for conditioning Briefly describe how exposed filters are stored after being weighed

Are blank filters reweighed?

A re chemical analyses performed on filters?

If yes, what analysis is performed?

PM 10

- 2.5 / Low Vol PM 10 / PM 2.5SESD Version #7.1 Page 49 of 50

Question Yes No Comments

Does the agency use filters supplied by EPA? X

Do filters meet the specifications in 40 CFR 50? X

Are filters visually inspected via strong light from a view box for defects before exposure? X

Where does the laboratory keep records of the serial

numbers of filters?

Are temperature and humidity monitors calibrated? X

Are balances checked with Class 1 weights each day when they are used? X

To what sensitivity are filter weights recorded? 1 ug

What method of documentation is used to record filter weighing sessions? (e.g., logbook, computer software, etc.) Computer Wedge software

During conditioni ng, are the following true:

(1) Filters equilibrate for a minimum of 24 hours X

(2) The temperature range is 20 ̊C

- 23 ̊C for the

24

- hr mean X

(3) Temperature control is ±2 ̊C SD over 24 hrs X

(4) Humidity range is 30%

- 40% RH for 24

- hr mean OR ≤5% sampling RH but >20% RH X

(5) Humid ity control is ± 5% SD over 24 hrs X

(6) Pre/post sampling RH difference in 24

- hr
means is ≤± 5% RH X

(7) Balance is located in the conditioning

environment X

Are filters packaged for protection while transportin g to and from the monitoring stations? X

Are filters shipped at ambient temperature to the monitoring stations? X

Are filters shipped at ≤ 4 ̊C from the field to the laboratory? X

Are filters post

- weighed in ≤30 days? X

Are filters post

- weighed in ≤10 days if they arrive

>4 ̊C? X

Are exposed filters reconditioned for at least 24 hrs in the same conditioning environment as for unexposed filters? X

Briefly describe how exposed filters are prepared for conditioning Filter/Cassette combinations are placed in the clean room and filters are removed. The filters are placed uncovered in their corresponding analyslides. The

filters are allowed to condition in the clean room for

at least 24 hours. Briefly describe how exposed filters are stored afte r being weighed Exposed filters are stored in analyslides at 4 degrees C or less for at least one year.

Are blank filters reweighed? X

Are chemical analyses performed on filters? X

If yes, what analysis is performed?SESD Version #7.1 Page 50 of 50

Lead

Question Yes No Comments

Does the agency use filters supplied by EPA? X

Is analysis for lead being conducted using atomic absorption spectrometry with air acetylene flame? X Analysis is conducted using EPA equivalent method utilizing

ICP/MS

If not, has the agen cy received an equivalency designation for their procedure? X

Is either the hot acid or ultrasonic extraction procedure being followed precisely? X Which? Hot acid

Is Class A borosilicate glassware used throughout the analysis? X Samples digeste d and contained in polypropylene tubes. Standards made up in class A borosilicate

volumetrics and stored in polypropylene vessels.

Is all glassware cleaned with detergent, soaked and

rinsed three times with distilled or deionized water? X

If extracted samples are stored, are linear polyethylene bottles used? X

Are all batches of glass fiber filters tested for background lead content? X

At a rate of 20 to 30 random filters per batch of 500 or greater? X Indicate Rate

-

Are ACS reagent g rand HNO 3 and HCl used in the analysis? X Optima grade

Is a calibration curve available having concentrations that cover the linear absorption range of the atomic absorption instrumentation? Concentration range is covered as defined by equivalent metho d and

standard ICP/MS calibration practices Is the stability of the calibration curve checked by alternately re

- measuring every 10 th sample a

concentration 1 g Pb/ml; 10 g Pb/ml? X Stability of the curve is checked after every 10 th sample.



### END OF REPORT