MEMORANDUM

TO:     Docket No. EPA‐HQ‐OAR‐2012‐0918

    Air Quality Designations for the 2012 PM2.5 Standards

FROM: Liz P. Naess

    Air Quality Assessment Division, OAQPS

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

PM2.5National Ambient Air Quality Standards  

The purpose of this memorandum is to discuss PM2.5 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 PM2.5 samples

did not meet all of the requirements of the federal reference method for PM2.5 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 PM2.5 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 PM2.5 sites in question from parameter code 88101 (PM2.5 at

local conditions; used for regulatory data) to parameter code 88501 (PM2.5 raw data). This

change will clarify to data users that data from these sites should not be compared to the PM2.5
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, 9th Floor

401 Church Street 

Nashville, TN 37243-1531 

SESD Project No. 10-0730

Mr. Stephens:

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 Tennessee Department of Environment and Conservation (TDEC), 

Division of Air Pollution Control’s (DAPC) ambient air monitoring program. The data 

collection period covered by the audit were calendar years 2007 through 2010. The Technical 

Systems Audit Form Questionnaire, Air Quality Systems data reports, and prior years’ audit 

reports were used in conducting the audit. The Technical Systems Audit Form Questionnaires 

completed for this audit are attached.

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

the issues that 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, TDEC w/attachment

Jackie Waynick, TDEC w/attachment
Tennessee Department of Environment and Conservation

Division of Air Pollution Control

Ambient Air Monitoring Program

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 monitoring as a whole. 

The audit confirms that the monitoring data is complete and is of good quality. However, 

there are a few recommendations identified that must be addressed. Most significantly, 

there are several key staff members who are soon to be eligible 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 monitoring program. The audit was 

conducted according to the provisions of 40 CFR Part 58. Using the National Ambient Air 

Systems (NAAS) Technical 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 were 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 criteria monitors in 

operation are: 12-O3, 3-PM10, 12-PM2.5, 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 PM2.5 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 Tennessee Valley Authority Kingston Ash 

Recovery Project. No deficiencies were found in the network with respect to network 

design.
Page 4 of 12

The Hendersonville monitoring site (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, 9th 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. The 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 Knoxville 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 monitoring 

objectives. The 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 trained 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 local 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 from Air Quality System (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 offices and at the monitoring sites indicated that the monitoring 

data was appropriately validated. TDEC data recovery was outstanding with all National 
Page 5 of 12

Ambient Air Quality Standard (NAAQS) pollutants posting greater than 75% data 

completeness in all quarters 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 processes well. The organization of data was an area 

of marked improvement from the last EPA technical systems audit. However, some areas 

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 logger 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 can 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 network. 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. EPA 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 recommends 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 confusion 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 conducted as 

required. EPA recommends that TDEC review the list of AQS null codes and 

properly code null data.

In the review of the continuous tapered element oscillating microbalance (TEOM) 

maintenance form, EPA observed that there were no places on the form 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 recommends 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 submittal 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 required 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 investigate 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 Plans (QAPP) for the gaseous criteria pollutants 

and the PM2.5 Federal Reference Method (FRM) network have been approved by EPA 

Region 4. These documents were complete, well written, and available to all staff. 

The independent 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 

auditors and a supervisor.

During FY2010, EPA conducted TSAs of the state of Tennessee’s local 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 agencies 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 the TDEC technical services group expand 

the scope of its audits to include elements of TSAs. At a minimum, EPA 

recommends 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 assurance 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 that 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 recommends 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 been 

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 frequent 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 process.

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 replaced 

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 errors 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 control. 
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 PM2.5 filter weighing and high volume 

TSP/PM10 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 the 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 standard weights, EPA found that the weights have not 

always been recertified 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 due 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 ensure 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 delayed. 40 CFR Part 50 App L Sec 8.3.6 allows 30 days for 

PM2.5 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 

recommends 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 past 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 laboratories 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 independent quality assurance 

review of the weighing data before the data is sent to Nashville.

Air Toxics Monitoring Program

Currently, TDEC operates a co-located (along with Exide facility monitors) high-volume 

sampler to measure lead emissions from the Exide battery plant located in Bristol, TN. 

Flow audits of the Exide and TDEC 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 schedule. 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, TDEC has contracted with an independent state lab 

located in Indiana; to check the Exide, Knoxville and Nashville laboratories lead analysis. 

This is done by supplying 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

TDEC also operates a co-located (along 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.

Both of the labs; Nashville and Knoxville subtract the blank filter background 

concentrations of metals along with reagent background from samples reported to DAPC. 

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 Determination 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 at 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 REPORT

Page 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 30605-2720

Page 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 pages

 
Page 4 of 9

SESD Project ID# 13-0544 

1. Introduction 

During the week of September 9-12, 2013, Richard Guillot, Mike Crowe, and Michael Roberts with 

EPA Region 4’s Science and Ecosystem Support Division (SESD) conducted 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 maintains the ambient air pollution monitoring network 

in Tennessee and the TDOH-DLS analyze filters for the fine particulate matter (PM2.5) pollutant 

program. The TDOH-DLS also analyze filters for the Memphis-Shelby County Health Department, 

Metropolitan Health Department of Nashville Davidson County and the Knox County Health 

Department. This TSA was conducted to meet requirements 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 network 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 major concerns and several other concerns with 

respect to the ambient air monitoring program. The first major concern was the significant portion of 

PM2.5 data flagged with a “1” in the AQS during 2011-2012. The State operated two PM2.5 weigh 

laboratories at the timeof this audit. Both of these labs began experiencing environmental control 

problems (temperature and relative humidity). Efforts 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 all of the weigh laboratory duties 

until replacement of the environmental systems could 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” for this pollutant measurement method not being met. EPA guidance recommends 

data not meeting a critical criteria be invalidated. EPA Region 4 has consistently followed this guidance 

and will recommends the State invalidate this data unless it can present 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 approximately 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 assurance information for monitors in AQS classified as 

“Industrial”. For 2010-2012, AQS shows 29 monitors meeting this classification, two of these monitors 

are used in the State monitoring plan to meet EPA minimum monitoring requirements. These two 
Page 5 of 9

SESD Project ID# 13-0544 

monitors should meet all of the requirements of a State and Local Air Monitoring Station (SLAMS). 

The state was unable to provide any documentation regarding quality management plans, quality 

assurance project plans or standard operating procedures for these monitoring sites. EPA recommends 

that the remaining “Industrial” monitors be reclassified as “non-regulatory” to avoid confusion in AQS 

as to the purpose of these monitors. 

Concerns noted in the TSA included: pending staff retirements and the need for additional staff in the 

areas of data handling, maintenance and quality assurance, the age of the site calibration equipment 

throughout the monitoring network, extended oversight of the local agencies – EPA would like to see 

the State take a stronger role in performing TSA’s. 

 

3. Findings and Recommendations 

3.1 Program and Data Management 

1. Finding: A significant portion of the PM2.5 raw data for the 2011 and 2012 monitoring years 

are flagged in the AQS with a “1” flag indicating a critical criteria has not been met. 

Discussion: During 2011-2012 the State of Tennessee’s Department of Health (TDOH) 

operated two PM2.5 weighing laboratories located in Nashville and Knoxville. The TDOH 

weighs filters for the following ambient air monitoring agencies: the State of Tennessee, the 

Metropolitan Health Department of Nashville-Davidson County, the Memphis Shelby 

County Health Department and the Knox County Health Department. In 2011, each of these 

laboratories began experiencing environmental 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 responsibilities. The Department of Health has since replaced 

the environmental control system for the Nashville weigh laboratory. The Nashville 

laboratory began processing filters again in July 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 “critical criteria” for the measurement of PM2.5. The 

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

Critical Criteria Table should be invalidated unless there are compelling reasons and 

justification for not doing so.” 

Recommendation(s): All of the fine particulate monitoring data (PM2.5) from 2011 through 

2012 currently flagged in the AQS with a “1” flag indicating an unmet critical criteria should 

be invalidated. Invalidation of the data would mean removal of the concentration data and 

replacement with the appropriate null data code. This will impact the PM2.5 data collected 

by: the State of Tennessee, Memphis-Shelby County, Nashville-Davidson County and 

Knoxville-Knox County air monitoring programs. Chattanooga-Hamilton County did not 
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SESD Project ID# 13-0544 

utilize the State of Tennessee’s weighing laboratory for its PM2.5 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 identifying and flagging the data consistently in 

the AQS. A post audit review of the 2010 data shows the possibility these laboratory issues 

may have extended beyond the 2011-2012 timeframe. EPA Region 4 recommends the 2010 

PM2.5 data be reviewed and invalidated as necessary. 

In addition, EPA recommends the TDEC-DAPC) take a more active quality assurance role in 

the oversight of the PM2.5 weighing laboratory. The DAPC should conduct an annual 

technical systems audit of the PM2.5 laboratory and review the quality 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 monitors 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 industrial monitors located at 16 separate 

monitoring sites. Each industry is responsible for all quality assurance procedures for their 

respective monitoring network. The State of Tennessee submits this quality assurance data to 

the AQS for the industry but does not conduct a review of this information. The State of 

Tennessee does not review or approve any Quality Assurance Project Plans (QAPP’s) or 

Standard Operating Procedures (SOP’s) the industries may use in the operation of their 

monitoring network. The State of Tennessee does conduct quarterly performance audits on 

these industrial monitors. 

The State of Tennessee has utilized two of these industrial monitors to meet EPA’s minimum 

regulatory requirements for the number of monitors 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 (SO2) 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 monitors adjacent to the industry monitors 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 requirements. Ultimately, the State must be able 
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SESD Project ID# 13-0544 

to demonstrate that the data collected for any of the monitors used for regulatory decision 

making purposes meets all of the EPA requirements. 

The State of Tennessee should also reclassify 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 requirements and should not be used for decision 

making purposes. 

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

Discussion: Tennessee operates its ambient air program with a small staff. Currently the 

data management area has three staff members, maintenance has two staff and quality 

assurance has two staff members. As with many 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 entail hiring new staff to work and train with 

experienced staff prior to any retirements. EPA also recommends additional staff for each of 

the areas of data management, maintenance and quality assurance. These staff would 

provide the state with the resources needed to meet the challenge of increased oversight of 

the local agencies and the industrial monitoring networks as well. 

4. Finding: Continue Updating Standard Operational Procedures 

Discussion: Tennessee has begun a process of updating its standard operating procedures. 

As noted above with the personnel changes occurring and the potential loss of knowledge 

through retirements the updating of the SOP’s would 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 calibration 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 in 
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SESD Project ID# 13-0544 

operation spare parts for these monitors are becoming 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 have saved data in the past when quality 

assurance questions have arisen. As noted above the loss of personnel in the local agencies 

and potential loss in the state raises 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 expand 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 PM2.5 data in 2010-2012 should have been addressed more in a more timely 

manner. Tennessee should make every effort to ensure this cannot be repeated, better communication 

between the TDOH-DLS and the TDEC-DAPC and the local 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 monitoring data represent air quality used for regulatory 

decision making purposes and must comply with all 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. 
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SESD Project ID# 13-0544 

Appendix A

Technical Systems Audit Questionnaire 
SESD 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 Form 

SESD Project ID # 13-0554
SESD 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 PM10, Low Vol PM10, PM2.5, PM10-2.5 & Pb) 

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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 Pugh

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Page 4 of 50

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

SESD Project ID # 13-0554
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. 

O3) at multiple sites, or a combination of the two? 

List available personnel and select their 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 NonAmbient 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 X

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List personnel who have authority or are responsible for:

Activity Name Title

QA Training Field/Lab Cathy Stoecker/ Craig 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 Director

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 

renewed?

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,

Chattanooga, 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, John

Marston, Bart

Williams, Carol

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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

Wilhoit, 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 Sturgill

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, John

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c) Training 

Question Yes No Comments

Does the agency have a training program 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 documented? 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 the 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 training

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 

Allen

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d) Facilities 

Identify the principle facilities where the agency conducts work related to air monitoring. Do not include monitoring stations, 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

Records 

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, Tennessee 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? If not, please explain and give suggested improvements or recommendations. 

 Facilities are adequate. 

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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 Comments

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 have separate auditing 

equipment and standards (specifically 

intended for sole use) for audits?

X

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Page 11 of 50

Do you conduct biweekly precision point checks? 

Are they automated or conducted manually? 

Select which of the following additional QC you conduct at your 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) Audits 

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? X

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SESD 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.,

 performance or systems audit)?

Performance/ although both are performed on local, 

private industry, 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 calibrations 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 audit 

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Page 13 of 50

Question Yes No Comments

Does your agency participate in NPAP, PM2.5 

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 conducted (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) The National Performance Audit Program (NPAP)? 

 Robert Brawner 

 (2) PM2.5 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 Audit

CO DNA

O3

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 20100826

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Page 14 of 50

SO2 None reported for 2013.

NO2 DNA

PM2.5

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 Comments

Has the QMP been approved by EPA within the last 

five years? X

Date of Original Approval: 5/13/1999

Date of Last Revision: 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 EPA 

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 staff (e.g.., 

electronically, hard copies at site, etc.) Electronic copies.

SOP Questions 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 are 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 Project ID # 13-0554
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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 

SO2 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 SizeSelective 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

TEOM Flow Check Data Sheet PM 

2.5 or PM 10 Instruments 11/13/1998 EPA Ltr. PM10

SESD Project ID # 13-0554
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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 EPA 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 Toxics

SESD Project ID # 13-0554
SESD 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 media 

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 maintained on a PC used for data 

polling activities and is backed up periodically to DVD/CD 

media.

SESD Project ID # 13-0554
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 documented?

 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 action 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 Audit 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 Project ID # 13-0554
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 Action Level Corrective Action (if exceeded) Redbook Guidance 

Action Level Reference

O3

< +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, Appendix D Revision 

No. 1 Page 3 of 30

CO DNA

QA Handbook Volume 

II, Appendix D Revision 

No. 1 Page 5 of 30

NO2 DNA

QA Handbook Volume 

II, Appendix D Revision 

No. 1 Page 7 of 30

SO2

< +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

O3

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

NO2 DNA

QA Handbook Volume 

II, Appendix D Revision 

No. 1 Page 7 of 30

SO2

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 9 of 30

At what point do you invalidate data?

When the results of the level one check’s indicate the instrument response is in excess of 

the invalidation criteria for that parameter. For gaseous parameters the maximum 

allowable is +-15%. 

SESD Project ID # 13-0554
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 plans 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 Project ID # 13-0554
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 number 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 Name

Pb

CO

SO2

NO2

O3

Manual Collo

cated

Contin

uous

PM

Meteorology

2.5

PM10

PM2.5

speciation

PM2.5

Carbon

PM2.5

PM10

PM2.5

PM10

470090101

470090011

470450004

470990002

471050108

471071002

471130006

471192007

471251009

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 GOLF 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 PROPERTY ON DONAHUE ROAD

1 1 2

471633004

and POC2 364 Exide Dr 2

SESD Project ID # 13-0554
SESD 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 SO2 NO2 O3

Manual Collocated Continuous

Meteorology PM2.5 PM10

PM2.5

speciation

PM2.5

Carbon PM2.5 PM10 PM2.5 PM10

4 NA 1 NA 9 5 3 3 1

4 

TEOMS TEOMS 2

SESD Project ID # 13-0554
SESD 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

Perm 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

Uninterrupted 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:______________

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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 X

SESD Project ID # 13-0554
SESD 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 

Question 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. Photographs/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 monitoring 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 collocated monitoring 

stations meet the requirements of 40 CFR 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 (Final to EPA for Review)

Is it available for public inspection? X

SESD Project ID # 13-0554
SESD Version #7.1 

Page 26 of 50

b) Changes to the Network since the Last Audit

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 reason 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 

Question 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? X

SESD Project ID # 13-0554
SESD Version #7.1 

Page 27 of 50

i) Instrument Inventory 

Please list instruments in your inventory:

Pollutant Manufacturer Models Reference or Equivalent 

Method Number

SO2 TEI 100E EQSA-0495-100

NO2 NA

CO NA

O3

Teledyne API

Thermo

400A, 400E

49C, 49I

EQOA-0992-087

EQOA-0880-047

PM10 Graseby RFPS-1287-063

PM2.5 R&P/Thermo Partisol Plus 2025 

PM2.5 Seq RFPS-0498-118

Pb Graseby

Tisch

Ref Method (High 

Volume)

Multi gas calibrator Teledyne T700

PM2.5 speciation Met One

URG

SASS

3000N

PM10-2.5 speciation

PM10-2.5 FRM mass

Continuous PM2.5 mass R&P/Thermo TEOM 1400a

Trace levels (CO) NA

Trace levels (SO2) NA

Trace levels (NO) NA

Trace levels (NOy) NA

Surface Meteorology Climatronics

Data Logger ESC

ESC

8832

8816

Others

Continuous PM10 R&P/Thermo TEOM 1400a EQPM-1090-079

SESD Project ID # 13-0554
SESD Version #7.1 

Page 28 of 50

ii) Calibration 

Please indicate the frequency of multi point calibrations:

Pollutant Frequency Name of Calibration Method

O3 Quarterly (during O3 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 credibility:

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

Tetracal Returned to manufacturer Once per year (flow device)

SESD Project ID # 13-0554
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 certification 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

NO2 NA

SO2 1

Manufacturer certified 

cylinder

1/28/2013 (initial 

certification)

O3 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 Project ID # 13-0554
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 section 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?

SO2 obtained from manufacturer of EPA protocol 

certified gases.

O3 from transfer standard (Dasibi 1008PC)

Are those standards certified 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 SO2

 5. Other (describe) X

O3 – calibrator certified against 

reference photometer in shop

How are the gas standards verified after receipt? SO2 -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

O3 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 maintained 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 Services

SESD Project ID # 13-0554
SESD 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 Project ID # 13-0554
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 known 

SESD Project ID # 13-0554
SESD Version #7.1 

Page 33 of 50

iv) Logbooks and Records 

Question Yes No Comments

What type of station 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 site

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 prepared 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. Control 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 Project ID # 13-0554
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 

collection 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 charts, 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 do 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 Continuous 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 operator 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)?

X

SESD Project ID # 13-0554
SESD 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 reporting 

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 

names 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 documentation

SESD Project ID # 13-0554
SESD 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 the 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 data

 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 monitors.

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 

submittal.

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 monitor 

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 Project ID # 13-0554
SESD Version #7.1 

Page 37 of 50

d) Data Processing 

Question Yes No Comments

Does the agency generate data 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 coding 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 PM10 concentrations corrected to EPA standard 

temperature and pressure conditions (i.e. 298 ̊K, 

760 mm Hg) before input to AQS? 

X

Are PM2.5 and Lead concentrations reported to AQS 

under actual (volumetric) conditions? X

Are audits on data reduction procedure 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?

X

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e) Internal Reporting 

What internal reports 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 precision 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 corrective 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 Haskin Environmental Specialist AQS submittal of NonContinuous 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 Operators

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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 

report (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

 described in Section 4 of Appendix A? X

 2. Location, date, pollution source and duration of 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 monitoring network? Add other 

pollutants not listed to the table.

Pollutant Analysis Name or Description of Method

PM10

PM2.5 40 CFR Part 50, App. L

Reference Method for the 

Determination of Fine Particulate 

Matter as PM2.5in the Atmosphere

Pb EQL-0710-192

Heated Nitric Acid Block 

Digestion and ICP/MS Analysis 

For Lead (Pb) on TSP High 

Volume Filters

PM10-2.5

Please describe areas where there have been difficulties meeting the regulatory 

requirements for any of the above analytical methods. 

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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

PM10

PM2.5

Gravimetric Analysis for Measurement of Fine Particulate Matter as PM2.5 in Air 

(Env-Inorg PM2.5 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)

PM10-2.5

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 sufficient 

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 Recertification 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

Other

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**Please have certifications of standards available for viewing during the audit 

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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

Title: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 blank level exceeds acceptance criteria run 

is rejected and corrective action taken.

PM2.5: Blanks used to determine potential crosscontamination in the clean room. If lab blanks 

exceed +/-15 ug then corrective action is taken.

Are criteria established to determine 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 10th 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 range 

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corrective action must be taken. Corrective action can include redigestion and 

reanalysis. 

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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 real 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:

Acceptance 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 preventative 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? X

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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 and 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 cases 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 envelope 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 log 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 6th floor or on server

 2. Who has the 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 Environmental Samples 

for Analysis, August 21,2013

Revision Number:6

Location: Y: drive

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e) Laboratory Data Acquisition and Handling 

Question Yes No Comments

Identify those laboratory instruments which 

make use of computer interfaces directly to 

record data. 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 capability 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. Printouts 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. 

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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. 

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f) Specific Pollutants: Particulate Matter 

High Vol PM10

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 protection 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?

Are chemical analyses performed on filters?

 If yes, what analysis is performed?

PM10-2.5 / Low Vol PM10 / PM2.5

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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 conditioning, 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) Humidity 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 

transporting 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 after 

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?

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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 agency 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 digested 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 grand HNO3 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 method and 

standard ICP/MS calibration 

practices

Is the stability of the calibration curve checked by 

alternately re-measuring every 10th sample a 

concentration 1 g Pb/ml; 10 g Pb/ml?

X

Stability of the curve is checked 

after every 10th sample.

END OF REPORT 

SESD Project ID # 13-0554