ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY 

AMBIENT AIR MONITORING PROGRAM 

TECHNICAL SYSTEM AUDIT 

DECEMBER 6 - 8, 2004 

FINAL 

REPORT ON FINDINGS

October, 2005
Arizona Department of Environmental Quality 2 

Technical System Audit, U.S. EPA Region 9 

October 2005 

INDEX 

PAGE 

INTRODUCTION............................................................................................ .3

EXECUTIVE SUMMARY................................................................................4 

GLOSSARY OF ACRONYMS.........................................................................7 

A. GENERAL FINDINGS......................................................................................8 

B. NETWORK MANAGEMENT........................................................................12 

C. FIELD OPERATIONS.....................................................................................15 

D. LABORATORY OPERATIONS....................................................................19 

E. DATA AND DATA MANAGEMENT............................................................23 

F. QUALITY ASSURANCE AND QUALITY CONTROL..............................26 

APPENDIX A, Summary of Recommended Corrective Actions.................32 
Arizona Department of Environmental Quality 3 

Technical System Audit, U.S. EPA Region 9 

October 2005 

INTRODUCTION

The Arizona Department of Environmental Quality (ADEQ) is the State level 

agency charged with implementing environmental programs throughout the State. In the 

State of Arizona there are four governmental agencies responsible for collecting ambient 

air quality data. The Maricopa County Environmental Services Department operates the 

ambient air quality network in the Phoenix Metropolitan Area, Pima County Department 

of Environmental Quality operates the ambient monitoring network in the Tucson 

Metropolitan Area, Pinal County Air Pollution Control District operates the ambient 

monitoring network in Pinal County, and ADEQ operates the ambient monitoring 

network in the rest of the State as well as supplemental sites in the urban areas of Phoenix 

and Tucson. 

responsibility, that of collecting and analyzing ambient air quality data. The task of 

collecting, validating, and submitting ambient air quality data to EPA is the responsibility 

of the Air Assessment Section of the ADEQ Air Quality Division. Within the Air 

quality data. 

The Air Monitoring Unit is responsible for operating the equipment that collects 

gaseous, particulate matter, and air toxic pollutants. The Air Monitoring Unit installs and 

maintains all monitoring equipment and performs basic quality control checks. The Air 

Monitoring Unit is also in charge of the particulate matter filter weighing laboratory. The 

Special Projects Unit is responsible for performing quality assurance audits, developing 

and implementing the quality assurance program, performing monitoring network 

reviews, and the review and preparation of data for submittal to EPA. 

U.S. EPA Region 9 conducted a TSA of the ADEQ ambient air monitoring 

program on December 6 through December 8, 2004. The regional staff who conducted 

Technical Support Office and Mathew Plate of the Regional Quality Assurance Office. 

This report is divided into eight sections. The first section is an introduction that 

EPA audit team, and the report organization. The next section is an executive summary 

that describes the purpose of the TSA and a summary of the most significant findings. 

The third section discusses our general findings on the ADEQ air monitoring program as 

a whole. The remaining five sections address specific aspects of the air monitoring 

program: network management, field operations, laboratory operations, data 

management and quality assurance/quality control. Appendix A is a listing of the 

recommended actions contained in this report. The findings and recommendations in this 

report are, for the most part, listed in priority order. Recommendations are provided to 

ADEQ has other approaches or alternatives to address the concerns identified, the Region 

will consider them, provided the corrective action adequately addresses the finding. 
Arizona Department of Environmental Quality 4 

Technical System Audit, U.S. EPA Region 9 

October 2005 

EXECUTIVE SUMMARY

This document is a report on the findings made by the U.S. EPA Region 9 after 

conducting a Technical Systems Audit (TSA) on the air monitoring program of the 

Arizona Department 

TSA is an onassess its compliance with established regulations governing the collection, analysis, 

validation, and reporting of ambient air quality data. 

The TSA was conducted by U.S. EPA Region 9 staff in December 2004. The 

audit team interviewed the management and staff on various aspects of the air monitoring 

program including such areas as network design, field operations, laboratory operations, 

data handling, and quality assurance and quality control procedures. The audit team also 

inspected a number of the monitoring sites operated by ADEQ. The site inspections 

consisted of an interview with the site operator, reviewing station and instrument 

logbooks, and evaluating the station siting with respect to EPA requirements for probe 

siting1. 

The TSA is one of the ways that EPA provides oversight to ensure that data 

collected by state and local agencies meets certain minimum data quality objectives. 

Other assessments such as network reviews and performance evaluations are also used to 

collect information on the overall quality of ambient air data. These assessments also 

enable agencies to identify and correct those program elements which may be adversely 

affecting the quality of ambient air data. 

The TSA uncovered some deficiencies within the agency which are discussed in 

detail in this report. Outdated Quality Assurance plans and Standard Operating 

Procedures an

most serious weaknesses in the ADEQ program. 

Program strengths

GENERAL FINDINGS

1. ADEQ sponsors and leads training events for new monitoring methods for their 

own staff, as well as for County and Tribal air agencies.

2. ADEQ has a policy statement which clarifies how the State will support Tribal 

monitoring. 

3. ADEQ plays a vital role in providing leadership among the various local and 

tribal agencies in Arizona that implement air monitoring programs. 

 

1
Arizona Department of Environmental Quality 5 

Technical System Audit, U.S. EPA Region 9 

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NETWORK MANAGEMENT

4. ADEQ is proactive in assessing pollutant monitoring networks in the State in 

anticipation of changing program needs. Specifically, ADEQ, in cooperation with 

Maricopa County and Tribal air agencies, recently evaluated the Phoenix area 

Quality Standard from a one-hour to an eight-hour standard. ADEQ also recently 

evaluated the Statewide PM network.

5. s a robust visibility monitoring network that 

greatly enhances the federally run IMPROVE network. 

FIELD OPERATIONS

6. ADEQ volunteers and participates in national programs to assess new monitoring 

methodologies. This enables the State to stay current with new technologies as 

they are being developed. The JLG Supersite in Phoenix is routinely selected as a 

testing platform for EPA due to its representativeness as well as the expertise and 

cooperative nature of ADEQ staff.

LABORATORY OPERATIONS

7. ADEQ has invested in an automated weighing system for its PM filter weighing 

laboratory. This system has simplified the weighing process and promotes better 

electronic documentation and data consistency.

8. PM filter samples are bar coded and sampling locations and dates are pre-planned 

well in advance by the laboratory. The bar codes are used to track filters through 

this process. This system reduces the likelihood of filter mix-ups. 

DATA AND DATA MANAGEMENT

9. ADEQ provides the public with access to ambient air quality data, visibility data 

and air pollution forecasting through their website http://www.azdeq.gov/. 

10. ADEQ performs extensive data analysis in order to gain greater understanding of 

their ambient monitoring and what the measured levels mean to air quality in 

Arizona. 

QUALITY ASSURANCE AND QUALITY CONTROL

11. The ADEQ Air Program has an independent staff person that oversees general 

QA management and oversees QA audits. This individual reports to a manager 

that is independent of the primary monitoring functions. 
Arizona Department of Environmental Quality 6 

Technical System Audit, U.S. EPA Region 9 

October 2005 

12. ADEQ has an overall QA management plan, a QA Program Plan for PM10 (draft) 

and gaseous pollutants (draft), a QA Project Plan for PM2.5, and a QA Project Plan 

for air toxics (draft). These plans generally cover the majority of EPA funded 

ambient air monitoring operations. 

13. The lead QA staff person understands the concepts of Quality Management and 

has an excellent plan to for continued quality system maintenance and 

improvement, if given the proper resources and management support. 

14. The ADEQ air monitoring audit program is setup to provide the required 

performance audits with independent staff and instrumentation. 

Program Weaknesses

GENERAL FINDINGS 

1. Overall, there is insufficient documentation for tracking agency operations. 

2. Staffing levels in some areas, such as the in Data Management Team should be 

increased and existing vacant positions, such as in the Gas Monitoring Team, 

should be filled. 

LABORATORY OPERATIONS 

3.

adversely impacting effectiveness, efficiency, and defensibility. Many steps of 

the analytical process are not documented. 

QUALITY ASSURANCE AND QUALITY CONTROL

4. QA Program and pollutant specific Project Plans need to be 

updated. 

As a follow up to this TSA, U.S. EPA Region 9 and ADEQ will negotiate an 

appropriate schedule to finalize and implement the corrective actions required or 

recommended in this report. 
Arizona Department of Environmental Quality 7 

Technical System Audit, U.S. EPA Region 9 

October 2005 

GLOSSARY OF ACRONYMS

ADEQ................................... Arizona Department of Environmental Quality 

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

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

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

DCS/AAAD.......................... Data Collection System/Air Assessment Ambient Database 

GMT..................................... Gas Monitoring Team 

IMPROVE............................ Interagency Monitoring of Protected Visual Environments 

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

NAMS.................................. National Air Monitoring Station 

NMHC.................................. Non-Methanated Hydrocarbon 

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

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

PM........................................ Particulate matter 

PM2.5..................................... Particulate matter 2.5 microns or less in aerodynamic 

diameter 

PM10...................................... Particulate matter 10 microns or less in aerodynamic 

diameter 

PMT...................................... Particulate Monitoring Team 

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

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

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

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

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

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

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

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

U.S. EPA.............................. United States Environmental Protection Agency 
Arizona Department of Environmental Quality 8 

Technical System Audit, U.S. EPA Region 9 

October 2005 

A. GENERAL FINDINGS

 

The ADEQ is the air pollution control agency primarily responsible for the 

development and implementation of the State Implementation Plan required by the 

Federal Clean Air Act. Within ADEQ, the Air Assessment Section of the ADEQ Air 

monitoring activities in the Phoenix metropolitan area, the Tucson metropolitan area and 

in Pinal County are the responsibility of the Maricopa, Pima, and Pinal county air 

pollution control agencies respectively. ADEQ does have an oversight role in these 

agencies activities and performs quality assurance audits of the their monitoring 

instrumentation. 

ADE

for the separation of routine monitor and laboratory operations and quality control checks 

from the quality assurance and audit functions. The routine operations are performed by 

the Air Monitoring Unit, managed by Michael Sundblom. This unit is further divided 

into a Particulate Monitoring Team, a Gas Monitoring Team, and an Air Toxics and Filter 

Laboratory Team. 

The Special Projects Unit, managed by Shawn Kendall, includes an QA/Audit 

Team, a Data Management Team and a Data Collection/QA Team. The Unit Managers 

report separately to the Air Assessment Section Manager, Steven Peplau. 

Finding A1: 

ADEQ needs to better document all aspects of the monitoring program. 

Discussion: 

Overall, we found ADEQ staff to be well versed in how to run a monitoring 

program. The largest deficiency we found was a lack of updated Quality 

Assurance/Quality Control documentation. Most SOPs, when available, were 

outdated. There were not controlled copies of QAPPs kept at the monitoring 

sites. While station documentation was up to date and complete, there was no 

formal process for archiving station and instrument logs. 

Recommendation: 

As will be discussed in detail later in this report, ADEQ should develop a time 

line for updating its SOPs, create QAPPs for each of the air pollutants for which it 

collects data, and develop a system for ensuring that all monitoring personal have 

the most recent copies of QA documentation. While monitoring station records 

are archived in a central location, a formal procedure should be in place for 

archiving of records such as instrument and station log books. 
Arizona Department of Environmental Quality 9 

Technical System Audit, U.S. EPA Region 9 

October 2005 

Finding A2:

While ADEQ has staff assigned to perform all aspects of the monitoring program, 

i.e. network design and management, station operations, data processing and 

management, and quality control/quality assurance, the current staffing level 

leaves little room for fluctuations in workload or absences. 

Discussion:

As discussed previousl

program adequately addresses all of the elements needed in a monitoring 

program. However, in interviewing staff and management it was made clear that 

the current staffing level makes it difficult for ADEQ to deal with variations in 

workload which could occur from time to time. For example, there are only two 

whom is the gaseous pollutant team leader. This network consists of 20 

instruments at 10 monitoring sites located throughout the State. If one of these 

technicians were to become unavailable, it would put an extreme burden on the 

remaining technician to operate and maintain the entire gaseous network. 

Similarly, there is only one staff technician to perform quality assurance audits 

and one staff person responsible for managing all of the data produced by the 

ADEQ monitoring networks. 

Having a minimal number of staff also makes it difficult for the agency to respond 

to special monitoring studies or data analysis projects which may arise from time 

to time. 

Recommendation:

ADEQ should consider hiring more staff so that there is better back-up capability 

for those areas of the program that rely on a single person to staff that portion of 

the program. At a minimum, technical staff should be cross trained so they can 

provide back up to each other. 

Finding A3:

ADEQ has had continuing problems in submitting PM data to the EPA AQS 

database on time. 

Discussion: 

Criteria pollutant data must be submitted to the EPA AQS database within 90 

days of the end of the calendar quarter2

. In its revision to the monitoring 

 

2

40 CFR 58.35, paragraph (c)(2)
Arizona Department of Environmental Quality 10 

Technical System Audit, U.S. EPA Region 9 

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regulations, due to be proposed in December 2005, EPA is proposing to change 

this to within 60 days of the end of the calendar quarter. From past discussions of 

this issue with ADEQ management and staff, ADEQ indicated that the reasons for 

the delay in data submittal was initially attributed to a turnover in staff and a need 

to review much of the PM data that had been previously submitted. More 

recently, delays were attributed to throughput problems in the PM weighing 

laboratory and workload issues on the part of data reviewers. This is one of the 

st 2005, 

ADEQ has not submitted PM data to the AQS database. At a minimum, data 

from January through March 2005 should have been in the database by June 30, 

2005. 

Recommendation:

ADEQ needs to clearly identify the obstacles which prevent the submittal of PM 

data to EPA by the appropriate deadlines. Unless resolved, this problem will only 

submittal following the end of the calendar quarter3. 

Finding A4: 

The ADEQ organizational chart is not current. 

Discussion: 

The responsibility for various aspects of the data management system should be 

clearly described in an up-to-date organization chart, which is an effective way to 

delineate the division of responsiblities. 

Recommendation: 

Create an updated organizational chart. 

GOOD PRACTICES

Finding A5:

ADEQ plays a vital role in providing leadership among the various local and 

tribal agencies in Arizona that implement air monitoring programs. 

 

3

EPA is developing a proposed rule to revise the monitoring requirements at 40 CFR 58. 

One of the proposed changes will require submittal of air quality data within 60 days 

from the end of the calendar quarter. This proposed rule is scheduled to be published in 

the Federal Register in December 2005.
Arizona Department of Environmental Quality 11 

Technical System Audit, U.S. EPA Region 9 

October 2005 

Discussion:

The staff at ADEQ coordinates many monitoring activities in Arizona that require 

the cooperation and participation of the many local and tribal agencies in the State 

of Arizona. The monitoring staff provide their support and expertise to the county 

and tribal air agencies by sharing equipment, providing training forums and, when 

necessary, assisting other agencies in QA activities. The State also assists other 

agencies in repairing instrumentation as well as providing surplus equipment 

when available. 
Arizona Department of Environmental Quality 12 

Technical System Audit, U.S. EPA Region 9 

October 2005 

B. NETWORK MANAGEMENT

ADEQ operates a network of monitors designated as State and local air 

monitoring stations (SLAMS) and special purpose monitors (SPM). All National Air 

Monitoring Stations (NAMS) are operated by the local agencies in Maricopa and Pima 

Counties. The following table shows the type and number of monitors operated by 

ADEQ: 

Pollutant SLAMS NAMS PAMS SPM Other Total

CO 1 - - - - 1

NOx* 2 - - 1 - 3

Ozone* 6 - - 1 - 7

PM10 13 - - 5 - 18

PM10 - Continuous - - 3 - 3

PM2.5 (FRM) 11 

7 - ADEQ 

4 - Counties

- - - - 11 

PM2.5- Speciated - 1 - 2 - 3

PM2.5 - Continuous - - - 2 - 2

SO2 2 - - 1 - 3

Trace NOy* - - - 3 - 3

Urban Haze/Neph. - - - 7 - 7

Transmissometer - - - 3 - 3

Camera - - - 5 - 5

Class I - - - 16 - 16

PAMS - - 3 - - 3

NATTS 1 - - - - 1

Surface Meteorology 1 - - 16 8 (study) 25

Total 36 1 3 64 8 114

*Ozone, NOx, and Trace NOy are operated year round at the JLG Supersite. Ozone, NOx, and Trace NOy are operated seasonally 

(April - October) at all other sites. 

All the gaseous pollutant monitors (this includes CO, NOx, O3, SO2, and Trace 

NOy) are operated by the Gas Monitoring Team. The Gas Monitoring Team (GMT) 

consists of two technicians. There is third technician position in the GMT but it is 

currently vacant. At the time of this audit the GMT was responsible for the monitors at 

ten monitoring stations. Since then one site has been discontinued. Of the current nine 

monitoring sites operated by the GMT, five are operated on a seasonal basis (April 

through October) and the remaining four are operated year round. 

The particulate matter and visibility networks are operated by the Particulate 

about 40 monitoring stations equipped with either PM monitoring instruments, visibility 

monitoring instruments or both. There are four technicians in the PMT. The 
Arizona Department of Environmental Quality 13 

Technical System Audit, U.S. EPA Region 9 

October 2005 

PM/visibility network is primarily operated by the PMT technicians with some assistance 

from contractors. Contract staff is used for filter changing at some of the more remote 

PM monitoring sites and at some of the visibility monitoring sites. 

Monitors for the Photochemical Assessment Monitoring (PAMS) Network, three 

sites, and the National Air Toxic Trends (NATTS) site are the responsibility of the Air 

Toxics and Filter Laboratory Team. While the NATTS site is operated year round, the 

PAMS sites are operated only during the ozone season, April through October. 

ADEQ provides a description of its monitoring networks to the public in the form 

of its Annual Air Quality Report. As implied by the title, this document is updated 

annually and is available to view or download on the ADEQ website or it can be mailed 

upon request. The Annual Air Quality Report includes discussions on each of the 

pollutant monitoring networks operated by ADEQ, monitor identification codes, 

sampling methods, a discussion on monitoring objectives and spatial scale of 

representativeness and indicates past and future changes to the network. 

Another document prepared by ADEQ and submitted annually to EPA is the 

Annual Monitoring Network Review. This document contains more detailed information 

on the monitor locations and their compliance with siting criteria in EPA regulation. 

Based on this report and individual site visits made during the audit (see section C of this 

s to meet all of the network 

design and probe siting requirements in EPA regulations at 40 CFR 58, Appendices D & 

E. 

While the Annual Monitoring Network Report includes information on which 

instruments operate on a seasonal basis, there is no discussion on the operating schedule 

of the instrumentation when it is in use as there is in the Annual Air Quality Reports (e.g. 

sampling frequency of PM monitors, i.e. one in six days, continuous, etc.). Based on 

information available to EPA in its Air Quality System Database, ADEQ does in fact 

operate all equipment in compliance with EPA operating schedule regulations at 40 CFR 

58.13. The instruments that do run seasonally operate from April through September. 

10 and PM2.5 networks both meet the collocation requirements for 

precision in 40 CFR 58, Appendix A, section 3.3 and 3.5.2. 

FINDINGS

Finding B1: 

The Annual Monitoring Network Review submitted to EPA (40 CFR 58.20) 

should include a discussion on the day to day and seasonal sampling frequency of 

its monitoring stations. 
Arizona Department of Environmental Quality 14 

Technical System Audit, U.S. EPA Region 9 

October 2005 

Recommendation:

Include information on monitoring schedules and sampling frequency in the next 

Annual Monitoring Network Review. 

GOOD PRACTICES

Finding B2:

ADEQ has recently conducted assessments of the ozone monitoring network in 

the Phoenix and the Statewide particulate monitoring network. 

Discussion: 

The largest and most critical ozone monitoring network in Arizona is the Phoenix 

metropolitan area ozone network. When the one hour ozone NAAQS was revised 

to an eight hour standard, many of the State and local ozone networks needed to 

be reassessed to ensure that they were properly characterizing the extent and 

severity of ozone air pollution as measured by an eight hour standard. ADEQ 

worked with the Maricopa County Environmental Services Department and many 

tribal agencies to expand the boundaries of the ozone network while also reducing 

the number of sites in the urban core. 

The Statewide PM10 network was assessed using dual processes. One review, the 

ADEQ 2001 Phase II Network Review, was performed with input from all of the 

local and tribal agencies. The second review was an assessment conducted by 

Sonoma Technology in 2003. These assessments provided information on which 

PM10 sites provided data of low value yet required resources to operate and 

maintain. Low value sites were discontinued, resulting in a more resource 

efficient network of monitors that provided adequate information on PM10 air 

quality in Arizona. 
Arizona Department of Environmental Quality 15 

Technical System Audit, U.S. EPA Region 9 

October 2005 

C. FIELD OPERATIONS

regulations, examined the instrumentation at the site, reviewed onsite documentation, and 

interviewed the site operators. The sites we used in this evaluation were located at Tonto 

National Monument, Queen Valley, Hayden, and the JLG Supersite.

All monitoring sites evaluated in this audit met the requirements of EPA 

consistently evaluates a portion of its monitoring sites to demonstrate that they meet the 

requirements of this appendix. 

 

The monitoring technicians interviewed, Fred Strasser (team leader) and Harold 

Monteith, from the gaseous monitoring team, and Brant Englund, from the particulate 

monitoring team, all exhibited extensive and thorough knowledge of instrument operation 

and quality control procedures. All station and instrument logbooks on site were 

complete and up to date. All certification gases were current. The stations were all clean 

and well kept. Stations were all maintained at the appropriate temperature. 

All criteria pollutant monitoring uses instruments designated as either EPA 

reference or equivalent methods. Instrument certification standards are maintained by the 

monitoring team leaders. All maintenance is performed either in the field or, if 

necessary, equipment is brought back to the workshop at the ADEQ office. Some 

instruments have extended warranties but ADEQ does not have any formal service 

agreements with instrument manufacturers. ADEQ maintains an adequate supply of 

consumables and spare parts for all equipment. 

Technical staff do not attend any formal training in monitor operations. New 

technicians are trained by experienced staff. ADEQ does host periodic training events 

with specific equipment manufacturers. These events are attended by ADEQ staff, 

county and tribal agency staff. 

For gaseous equipment, zero-span checks are conducted every two weeks. While 

+10% criteria as an action level, unofficially the technicians will 

make documented adjustments to the instruments if the instruments drift beyond +5%. 

Zero-span reports are completed for each precision check of an instrument and filed at 

ADEQ monitoring offices. 

For the PM10 and PM2.5 networks, ADEQ meets the precision requirements by 

having two of their 13 PM10 sites and two of the seven PM2.5 monitors are collocated 

with a second 
Arizona Department of Environmental Quality 16 

Technical System Audit, U.S. EPA Region 9 

October 2005 

monitor. The operators perform flow checks of PM monitors every four weeks at nearby 

sites and every six weeks at more distant sites. These flow rate checks are in addition to 

the annual flow rate audits performed by the QA team. 

Finding C1: 

Standard operating procedures for gaseous instruments are outdated. 

Discussion: 

As sta

updated. This is a program weakness which would become evident in the event 

that new technicians were hired who did not have access to the senior technicians 

expertise and experience. As stated in the introduction to this section, the current 

technical staff have clearly demonstrated their ability to operate and maintain the 

equipment for which they are responsible. However, this knowledge and the 

procedures they use needs to be documented in order to ensure that new staff are 

performing operations in a consistent manner. 

Recommendation: 

SOPs for all instrument operations, quality control procedures, equipment 

maintenance, and station operations should be updated using the following 

heading type: 

Project no. or name 

Element or section no. 

Revision no. 

Revision date 

Section/Element Page ___ of ___ (this comment is applicable for all SOPs 

(new/revised) 

Updated SOPs should be distributed to all operators, with training provided where 

needed. 

 

Finding C2: 

Controlled copies of QAPPs and SOPs are not maintained at all monitoring sites. 

Discussion:

While the technical staff have access to existing QA documentation, controlled 

copies of pollutant specific QAPPs and instrument and station SOPs, once 

updated, should be maintained at each monitoring site. This ensures that station 
Arizona Department of Environmental Quality 17 

Technical System Audit, U.S. EPA Region 9 

October 2005 

operators or anyone else visiting the monitoring station can have access to all 

relevant documents without having to bring said documentation to the site. 

Recommendation: 

Once QA documentation is updated, provide controlled copies of pollutant 

specific QAPPs and instrument and station SOPs at each monitoring station.

Finding C3:

Gaseous instruments vent inside monitoring stations. 

Recommendation:

For health and safety reasons, outlet flow from gaseous instruments should be 

vented outside of the monitoring station. While venting to the outdoors is not an 

absolute requirement, it is strongly suggested especially for monitoring stations 

with ozone instruments, since ozone is a very strong oxidant. EPA recommends 

venting any ozone or calibration gas to the atmosphere rather that into the shelter 

or other immediate sampling area. If this is impossible, it is recommended that 

operators limit their exposure to ozone y getting fresh air every 10 to 15 minutes. 

(See the draft document "DETERMINATION OF OZONE BY 

ULTRAVIOLET ANALYSIS, A New Method for Volume II, Ambient Air 

Specific Methods, Quality Assurance Handbook for Air Pollution Measurement 

Systems", Final Draft, May 1, 1997, section 4.0, available on the web at 

http://www.epa.gov/ttn/amtic/files/ambient/qaqc/ozone4.pdf. 

Finding C4: 

During a review of ADEQ's database, there was a 2-week data gap at Hillside for 

ozone during the ozone season. 

Discussion:

The review of data from the Hillside station for ozone season 2004 showed a data 

gap from 7/24 through 8/3. This period represents a period when elevated levels 

of ozone could occur. With the monitor not operating, EPA considers this a 

serious lapse in data collection, because Hillside was an important monitor in the 

ozone network for assessing transport and background levels of ozone. Since 

ADEQ monitors ozone seasonally, with the exception of the JLG Supersite, EPA's 

expectation is that ADEQ would have back-up monitors on hand that could 

replace a malfunctioning instrument in a more timely fashion. While we 

understand that the Hillside site was in a rural area and difficult to travel to, 

ADEQ has not explained why a replacement monitor could not have been 

installed, or the existing monitor repaired, in a shorter period of time than two 
Arizona Department of Environmental Quality 18 

Technical System Audit, U.S. EPA Region 9 

October 2005 

weeks. See also finding E5. 

Recommendation:

Monitors which fail, or are in need of maintenance, should be restored to full 

operation as a priority and as soon as possible, particularly during the season of 

possible high values. 
Arizona Department of Environmental Quality 19 

Technical System Audit, U.S. EPA Region 9 

October 2005 

D. LABORATORY OPERATIONS

The ADEQ laboratory is used primarily for the pre and post weighing of PM 

filters for both PM10 and PM2.5. The Laboratory team leader is Bridget Gonzalez. The 

laboratory performs all pre and post weighing of filters for its PM monitoring network as 

well as PM2.5 filters for the Maricopa County Air Quality Department. They have 

invested in an automated weighing system. This system has simplified the weighing 

process and promotes better electronic documentation and data consistency. Samples are 

bar coded and sampling locations and dates are pre-planned well in advance by the 

laboratory. The bar codes are used to track filters through this process. This system 

reduces the likelihood of filter mix-ups. 

As with other activities, the QA Program Plan and PM2.5 QA project do not reflect 

current laboratory operations (see finding F2). There are several informal documents that 

do help to fill this void that could be incorporated as part of revised standard operating 

procedures (SOPs). 

Finding D1:

The transfer of data between data collection systems and databases is inefficient 

and increases the occurrence of reporting errors. 

Discussion:

At a minimum, three separate data systems are used for routine weighing. First 

data is collected and processed by the automated weighing system. The data from 

this system is then transferred by manual entry into a spreadsheet that processes 

and stores weighing laboratory data. The spreadsheet data is then transferred to 

The spreadsheet developed by the laboratory is not a validated software program. 

The audit team found errors in some of the entries into the system. The 

calculations in th

protected. Even with the password protection, the calculations should be locked 

so there is no chance for potentially miscalculated and misreported data. Finally, 

archived lab data is not secure. 

Recommendation:

Take steps to make the current transfer process more secure and consistent. This 

could be done by implementing a process to validate spreadsheets, lock validated 

calculations, secure and lock completed data, and have all entries and some 

calculations double checked by a second person. A SOP should be developed that 

addresses these issues and would ensure consistency of the process in the future. 
Arizona Department of Environmental Quality 20 

Technical System Audit, U.S. EPA Region 9 

October 2005 

Review all data produced by the current system to ensure that all data reported to 

AQS is correct. 

Work to establish a system that electronically transfers data to improve efficiency, 

consistency, and minimize errors associated with data entry. 

Finding D2:

The logging of manual weighing data is not being done electronically or being 

recorded in a defensible manner. 

Discussion:

Occasionally filters are weighed using a manual micro-balance. The data 

collected from this system is recorded into a logbook. The balance data could be 

logged into a computer system as a defensible electronic record, however, this is 

not being done. Additionally, the information included in the manual balance 

logbook, the type of logbook being used, and the manner in which the logbook is 

kept up are not consistent with the collection of defensible and reproducible data. 

Recommendation:

The manual balance documentation and procedures need to be improved. 

Finding D3:

Discussion:

Some events are not logged including filter lot receipt, pre-conditioning, filter 

disposal, and out of the ordinary events. This lack of documentation for out of the 

ordinary events was evident because supporting data for some of the data points 

that EA tracked could not be easily recovered by laboratory staff. 

Recommendation:

not being tracked. 

Finding D4:

The sample control process needs to be improved. 
Arizona Department of Environmental Quality 21 

Technical System Audit, U.S. EPA Region 9 

October 2005 

Discussion:

Some samples were held in the field for an extended time before being submitted 

to the laboratory. The sample logbook for PM filters needs to have more 

information such as initials of person receiving samples and receipt temperature. 

The canisters stored for air toxic sampling need to be handled in a more organized 

manner. 

Recommendation:

Improve communication with field personnel and offices. Improve the sample 

control logbook and better organize the sample control area. 

Finding D5:

Laboratory tasks are somewhat compartmentalized without sufficient cross 

training and knowledge. As a result there is insufficient knowledge of the 

laboratory procedures by the lab staff. 

Discussion:

The staff present during the first day of the audit were not aware of many of the 

tasks completed by the main weigh room technician. This was somewhat 

troubling because weighing and processing of filters is primarily done by a parttime intern. There should be sufficient cross training and internal QC review of 

work areas so that laboratory personnel are familiar with each others task areas. 

Recommendation:

Develop a program of cross training and regular communication (e.g. weekly or 

monthly meetings) and QC checks within the laboratory. 

 

Finding D6:

The temperature of the refrigerators and freezers used for sample storage are not 

regularly checked and recorded. 

Discussion:

In order to maintain sample integrity, samples may be required to be stored at 

specified temperatures. Without regular checks and documentation of sample 

storage conditions, there is no proof that sample integrity has been maintained. 
Arizona Department of Environmental Quality 22 

Technical System Audit, U.S. EPA Region 9 

October 2005 

Recommendation:

At a minimum, the temperature of each refrigerator and freezer should be checked 

with a traceable thermometer and recorded in a logbook daily. Alternatively, an 

automated system could log these temperatures and alert laboratory staff to 

temperature violations. 
Arizona Department of Environmental Quality 23 

Technical System Audit, U.S. EPA Region 9 

October 2005 

E. DATA AND DATA MANAGEMENT

-designed to accomplish the tasks of 

acquiring, validating, storing, quality assuring and reporting ambient monitoring data to 

EPA and to the public under the requirements of the Clean Air Act and EPA regulations. 

related systems, both purchased and developed in-house, are designed to allow station 

operators remote access to their sites, to poll stations for continuous data, to conduct data 

validation electronically through review Levels I, II and III, to allow for data 

visualization as part of the Levels II and III validation steps, and provide backup to avoid 

loss of data due to power interruptions. 

In general, with the continuing and growing reliance on electronic record-keeping 

by state and local air monitoring districts, EPA acknowledges the need to establish 

authority for database integrity over time. While no explicit guidance exists, EPA 

encourages monitoring agencies to continue to maintain hardcopy logbooks of routine 

operations and maintenance, 

-

estionnaire, is not fully applicable to a thorough review of the current generation 

EPA commends ADEQ for making much of the ambient air data collected in the 

state readily available to the public through links at their website. EPA also commends 

ADEQ for their extensive data analysis efforts to gain greater understanding of their 

ambient monitoring data and what the measured levels mean to air quality in Arizona. 

ics Data 1994-1998", ADEQ has set a 

high standard for monitoring agencies to mine the ambient data collected. 

Finding E1:

Documentation of software developed in-house or purchased is not complete. 

Discussion:

In a complex data management system, operation of the software should be 

documented for current and future users. Software instructions or manuals used 

by operators should be readily available. Documentation of database version, 

structure and function should be part of the electronic record keeping of a 

computer-based data management system. 

Recommendation: 

documented to show how the system works and how to operate it successfully. 
Arizona Department of Environmental Quality 24 

Technical System Audit, U.S. EPA Region 9 

October 2005 

Finding E2:

ines for data management and data validation are 

not complete. 

Discussion:

procedures are conducted in the same way by all operators. SOPs and currentlyuld reflect all procedures. 

Recommendation: 

monitoring data using the following heading type: 

Project no. or name 

Element or section no. 

Revision no. 

Revision date 

Section/Element Page ___ of ___ 

Finding E3: 

The QAPPs, including the PM2.5 QAPP, have not been updated for actual data 

validation procedures and for existing computer systems. 

Discussion:

hese 

sections were not included in the QAPP version submitted to EPA. During the 

audit, it became clear that some of the data validation procedures have been 

developed since the new (Oracle and Access database) data system was put in 

place in 2002. The QAPP for data assessment and validation should include 

procedures for operators to follow in validating data. 

Recommendation: 

Update the QAPP to include current data validation and data assessment 

procedures. 

Finding E4:

The data review exercise found a 2-week data gap at Hillside for ozone during the 
Arizona Department of Environmental Quality 25 

Technical System Audit, U.S. EPA Region 9 

October 2005 

ozone season. 

Discussion:

The review of data from the Hillside station for ozone season 2004 showed a data 

gap from 7/24 through 8/3. This period represents a period when elevated levels 

of ozone could occur. With the monitor not operating, EPA considers this a 

serious lapse in data collection, because Hillside was an important monitor in the 

ozone network for assessing transport and background levels of ozone. Since 

ADEQ monitors ozone seasonally, with the exception of the JLG Supersite, EPA's 

expectation is that ADEQ would have back-up monitors on hand that could 

replace a malfunctioning instrument in a more timely fashion. While we 

understand that the Hillside site was in a rural area and difficult to travel to, 

ADEQ has not explained why a replacement monitor could not have been 

installed, or the existing monitor repaired, in a shorter period of time than two 

weeks. See also Finding C4. 

Recommendation:

Monitors which fail, or are in need of maintenance, should be restored to full 

operation as a priority and as soon as possible, particularly during the season of 

possible high values. While we understand that this is not an issue to be 

addressed by the Data Management Team, it is included in this section of the 

report because the problem was discovered while reviewing the data management 

process. 

Finding E5:

Level I data review is not being done by site operators, i.e. the technicians who 

operate the air pollution measurement instruments. 

Discussion:

Data review is an ongoing process that should be performed by the site operators. 

Reviewing calibration information, hourly data and applying flags is optimally 

done by the person working most closely to the measuring instrument. 

Recommendation: 

Site operators should be trained to conduct Level I data review. 
Arizona Department of Environmental Quality 26 

Technical System Audit, U.S. EPA Region 9 

October 2005 

F. QUALITY CONTROL AND QUALITY ASSURANCE

Quality control and quality assurance are the two components of a monitoring 

program which allow agencies to have confidence that the data they collect represent the 

true air quality of the area. They are the means by which an organization manages its 

quality aspects in a systematic, organized manner and provides a framework for planning, 

implementing, and assessing work performed by an organization. A properly developed 

QA/QC program encompasses a variety of technical and administrative elements, 

including policies and objectives, organizational authority, responsibilities, 

accountability, and procedures and practices. 

Quality assurance is a management or oversight function; it deals with setting 

policy and running an administrative system of management controls that cover planning, 

implementation, review of data collection activities, and the use of data in decision 

making. Quality control is a technical function that includes all the scientific precautions, 

such as calibrations and duplications, that are needed to acquire data of known and 

adequate quality. 

ADEQ has a QA Program Supervisor that manages the ADEQ QA Unit and 

oversees all 

Supervisor position was vacant at the time of the audit. The ADEQ Air Quality Division 

has an independent staff person that oversees general QA management and oversees QA 

audits. This individual reports to a manager that is independent of the primary 

monitoring functions. ADEQ also has an overall QA management plan, a QA Program 

Plan for PM10 and gaseous pollutants, a QA Project Plan for PM2.5, and a QA Project Plan 

for Air Toxics. These plans generally cover the majority of EPA funded ambient air 

monitoring operations. 

The lead QA staff person understands the concepts of Quality Management and 

has an excellent plan for continued quality system maintenance and improvement, if 

given the proper resources and management support. Additionally, the audit program is 

set up to provide the required performance audits with independent staff and 

instrumentation. 

QA Management

Finding F1:

The ADEQ QA/QC Unit has had very little interactions with the ADEQ Air 

Quality Division, including routine oversight, QA meetings, QA training, and 

periodic audits. 

Discussion: 

According to the ADEQ Quality Assurance Program Plan for Air Monitoring, the 
Arizona Department of Environmental Quality 27 

Technical System Audit, U.S. EPA Region 9 

October 2005 

ADEQ QA Program Supervisor should provide management oversight (plan 

reviews, QA management audits, and involvement in major corrective actions) to 

the ADEQ air programs. Additionally the Air QA staff person should have an 

unimpeded line of communication to the ADEQ QA Manager. This issue was 

already identified by ADEQ and the agency has been working toward improving 

the interactions and communications between the QA program supervisor and the 

Air Quality Division's QA staff. 

Recommendation:

The ADEQ should continue to foster a level of oversight and cooperation between 

Agency and Program QA which meets and is consistent with their Quality 

Management Plan. 

Finding F2:

The standard operating procedures (SOPs), where available, are generally 

outdated and often not consulted by monitoring staff. 

Discussion:

As discussed previously in this report, ADEQ needs to update many of the 

existing SOPs and develop others that are currently not in place. In some cases 

there are procedural outlines that are used to aid staff. However, these have not 

undergone formal QA and management review and approval. 

Recommendation:

ADEQ should update and/or formally review and approve all SOPs that are 

exist, these should be formally adopted and included in SOPs. 

Finding F3:

The Air Quality Division QA Program Plan and QA Project Plans for PM2.5 and 

Air Toxics Monitoring need to be updated. 

Discussion:

While these plans are periodically updated and are not much outside of what 

would be considered a regular update cycle, they do not reflect current ADEQ 

organization and quality practices in many cases. 
Arizona Department of Environmental Quality 28 

Technical System Audit, U.S. EPA Region 9 

October 2005 

Recommendation:

 

ADEQ should provide updated air monitoring Quality Project and Program plans 

as soon as possible. EPA and ADEQ will negotiate an appropriate due date, to be 

included in the Corrective Action Plan, for these documents. 

Finding F4:

level, audited quality operations. (Note required instrument performance audits 

have been implemented.) 

Discussion:

 

Internal technical system audits (TSAs) and data quality audits are required in the 

ADEQ Air Monitoring Program Plan and are standard QA practices to ensure that 

QA procedures are effective, efficient, and have been properly implemented. 

These audits should also include formal evaluations of the quality systems and 

data quality of ADEQ air monitoring support contractors (especially laboratories). 

Recommendation:

ADEQ should develop and submit to EPA a schedule for conducting data quality 

support conducted by the ADEQ Northern and Southern regional offices. 

Finding F5:

The ADEQ Air Quality Division does not provide sufficient QA oversight of 

other Agencies that operate equipment that either directly supports and/or is 

funded through ADEQ grant funds. 

Discussion:

EPA grant regulations specifically require each grantee to provide for QA 

activities (40 CFR Part 31.45). As the EPA funded agency, ADEQ is responsible 

for ensuring that Quality Assurance activities are undertaken for work funded 

through its grant. This includes monitoring activities conducted by Pinal County, 

as the County does not have an independent QA system. ADEQ staff also 

indicated that Pima County and Maricopa County may be acting as operators for 

certain ADEQ monitoring programs. Oversight should similarly be performed on 

these county programs if they are providing support to ADEQ in its data 

collection activities. By oversight we mean that ADEQ needs to ensure that other 

agencies and contractors who perform activities that contribute to the data 

collection efforts of the State are meeting the Quality Assurance and Quality 
Arizona Department of Environmental Quality 29 

Technical System Audit, U.S. EPA Region 9 

October 2005 

Control standards that ADEQ has established for its program. ADEQ should 

ensure that contract site or instrument operators, whether private or county, have 

controlled copies of all applicable QAPPs and SOPs. Any laboratories 

performing analyses for ADEQ also need to have QA plans that are developed 

and provided by ADEQ or ADEQ can adopt the laboratory's QA plan if they 

determine that it meets their requirements. ADEQ's QA Program should also 

conduct audits of agencies or laboratories that are performing tasks for them. 

Recommendation:

 

The ADEQ Air Program should document and provide QA oversight where other 

agencies or contractors are operating equipment for the ADEQ program. In some 

cases, EPA or other agencies may be already doing parallel oversight of these 

contractors and may be able to support ADEQ in this task. 

Finding F6:

There should be a single, consistent corrective action procedure in place to 

address QA/QC findings. 

Recommendation: 

The QA auditor has a corrective action sheet and there is also a separate 

corrective action process between the QA/Data group and the Monitoring group. 

These processes should be combined and formalized with QA and Management 

sign-off. Additionally, there should be criteria established for when corrective 

actions will be elevated to the Agency QA Manager (i.e. significant amount of 

data impacted, fraudulent data discovered, and unresolvable disagreements 

between Air Program QA and Monitoring groups). 

Finding F7:

The QA group did not provide or track QA related training. 

Discussion/Recommendation:

The QA group should attend general QA training given by EPA QA staff or 

attend the national EPA QA conference. The types of training would include, but 

are not limited to, training on QA systems, Quality Assurance Project Plans, 

Quality Management Systems, and proper documentation techniques. Better 

knowledge of the specific requirements of the EPA QA system would benefit 

ADEQ QA staff in meeting EPA regulatory requirements. The regular training 

and annual conference put on by the EPA QA staff are the best opportunities to 

get this type of training. 
Arizona Department of Environmental Quality 30 

Technical System Audit, U.S. EPA Region 9 

October 2005 

QA Audits

Finding F8:

While the ADEQ has established an acceptance criterion for individual audits and 

audit points, the statistical criterion for Reporting Organization acceptance 

defined in 40CFR Part 58 Appendix A Section 5.2 is not being evaluated. 

Discussion:

The required Federal QC criterion4 for QA audits is statistically derived from all 

audits performed in a given quarter. This statistic is available in AQS from an 

agencies develop a simple QC criterion for individual audits. ADEQ uses +/- 5% 

but does not base this on the Federal criterion. Additionally, ADEQ does not 

calculate and track the federal criterion and issue quarterly audit reports. These 

would be internal reports to specify corrective action to remove system bias. 

Because the 20% of the 95% confidence level is the audit criterion specified by 

federal regulation, this criterion must be evaluated and should be clearly 

specified. This is significant because, if the federal criteria are exceeded there 

must be data corrective action. The 5% audit criterion used by ADEQ seems to 

be sufficient to meet the 20% of 95% confidence interval but should be 

considered as a warning limit. 

Recommendation: 

Create audit warning and control limits based on the federal criteria and track 

audit results quarterly for compliance with the federal criteria. 

Finding F9:

The zero air cylinder used by the audit program has not been certified for the 

gaseous pollutants audited. 

Discussion:

Although zero standards are not required to be traceable to a primary standard, 

care should be exercised to ensure that zero standards are indeed adequately free 

of all substances likely to cause a detectable response from the analyzer. 

Periodically, several different and independent sources of zero standards should 

be compared. The one that yields the lowest response can usually (but not always) 

be assumed to be th independent zero standards 

produce exactly the same response, it is likely that all the standards are adequate. 

 

4

40 CFR Part 58 Sections 3.2 and 5.2.
Arizona Department of Environmental Quality 31 

Technical System Audit, U.S. EPA Region 9 

October 2005 

Recommendation:

Develop a procedure to ensure and certify that the zero air used in instrument 

audits is free of contaminants. 

Finding F10:

The Auditor does not bring copies of the audit gas and instrumentation 

certification in the field. 

Discussion:

equipment should be kept with the equipment 

Recommendation:

A copy, or other verification, of transfer standard certification (including date 

certified) should be kept in the same location as the standard. 
Arizona Department of Environmental Quality 32 

Technical System Audit, U.S. EPA Region 9 

October 2005 

Appendix A

Summary of Recommended Corrective Actions

A. GENERAL FINDINGS

Finding A1: ADEQ should develop a time line for updating its SOPs, create QAPPs for 

each of the air pollutants for which it collects data, and develop a system for ensuring that 

all monitoring personal have the most recent copies of QA documentation. While 

monitoring station records are archived in a central location, a formal procedure should 

be in place for archiving of records such as instrument and station log books. 

Finding A2: ADEQ should consider hiring more staff so that there is better back-up 

capability for those areas of the program that rely on a single person to staff that portion 

of the program. At a minimum, technical staff should be cross trained so they can 

provide back up to each other. 

Finding A3: ADEQ needs to clearly identify the obstacles which prevent the submittal 

of PM data to EPA by the appropriate deadlines. Unless resolved, this problem will only 

submittal following the end of the calendar quarter. 

Finding A4: Create an updated organizational chart.

B. NETWORK MANAGEMENT

Finding B1: Include information on monitoring schedules and sampling frequency in the 

next Annual Monitoring Network Review. 

C. FIELD OPERATIONS

Finding C1: SOPs for all instrument operations, quality control procedures, equipment 

maintenance, and station operations should be updated using the following heading type: 

Project no. or name 

Element or section no. 

Revision no. 

Revision date 

Section/Element Page ___ of ___ (this comment is applicable for all SOPs (new/revised) 

Updated SOPs should be distributed to all operators, with training provided where 

needed. 
Arizona Department of Environmental Quality 33 

Technical System Audit, U.S. EPA Region 9 

October 2005 

Finding C2: Once QA documentation is updated, provide controlled copies of pollutant 

specific QAPPs and instrument and station SOPs at each monitoring station. 

Finding C3: For health and safety reasons, outlet flow from gaseous instruments should 

be vented outside of the monitoring station. While venting to the outdoors is not an 

absolute requirement, it is strongly suggested especially for monitoring stations with 

ozone instruments, since ozone is a very strong oxidant. EPA recommends venting any 

ozone or calibration gas to the atmosphere rather that into the shelter or other immediate 

sampling area. If this is impossible, it is recommended that operators limit their exposure 

to ozone y getting fresh air every 10 to 15 minutes. (See the draft document 

"DETERMINATION OF OZONE BY ULTRAVIOLET ANALYSIS, A New Method 

for Volume II, Ambient Air Specific Methods, Quality Assurance Handbook for Air 

Pollution Measurement Systems", Final Draft, May 1, 1997, section 4.0, available on the 

web at http://www.epa.gov/ttn/amtic/files/ambient/qaqc/ozone4.pdf.

Finding C4: Monitors which fail, or are in need of maintenance, should be restored to 

full operation as a priority and as soon as possible, particularly during the season of 

possible high values. 

D. LABORATORY OPERATIONS

Finding D1: Take steps to make the current transfer process more secure and consistent. 

This could be done by implementing a process to validate spreadsheets, lock validated 

calculations, secure and lock completed data, and have all entries and some calculations 

double checked by a second person. A SOP should be developed that addresses these 

issues and would ensure consistency of the process in the future. 

Review all data produced by the current system to ensure that all data reported to 

AQS is correct. 

Work to establish a system that electronically transfers data to improve efficiency, 

consistency, and minimize errors associated with data entry.

Finding D2: The manual balance documentation and procedures need to be improved. 

Finding D3: 

currently not being tracked. 

Finding D4: Improve communication with field personnel and offices. Improve the 

sample control logbook and better organize the sample control area. 

Finding D5: Develop a program of cross training and regular communication (e.g. 

weekly or monthly meetings) and QC checks within the laboratory. 
Arizona Department of Environmental Quality 34 

Technical System Audit, U.S. EPA Region 9 

October 2005 

Finding D6: At a minimum, the temperature of each refrigerator and freezer should be 

checked with a traceable thermometer and recorded in a logbook daily. Alternatively, an 

automated system could log these temperatures and alert laboratory staff to temperature 

violations. 

E. DATA AND DATA MANAGEMENT

Finding E1: 

adequately documented to show how the system works and how to operate it 

successfully. 

Finding E2: U

monitoring data using the following heading type: 

Project no. or name 

Element or section no. 

Revision no. 

Revision date 

Section/Element Page ___ of ___ 

Finding E3: Update the QAPP to include current data validation and data assessment 

procedures. 

Finding E4: Monitors which fail, or are in need of maintenance, should be restored to 

full operation as a priority and as soon as possible, particularly during the season of 

possible high values. While we understand that this is not an issue to be addressed by the 

Data Management Team, it is included in this section of the report because the problem 

was discovered while reviewing the data management process. 

Finding E5: Site operators should be trained to conduct Level I data review. 

F. QUALITY CONTROL AND QUALITY ASSURANCE

Finding F1: The ADEQ should continue to foster a level of oversight and cooperation 

between Agency and Program QA which meets and is consistent with their Quality 

Management Plan. 

Finding F2: ADEQ should update and/or formally review and approve all SOPs that are 

should be formally adopted and included in SOPs. 

Finding F3: ADEQ should provide updated air monitoring Quality Project and Program 

plans as soon as possible. EPA and ADEQ will negotiate an appropriate due date, to be 

included in the Corrective Action Plan, for these documents. 
Arizona Department of Environmental Quality 35 

Technical System Audit, U.S. EPA Region 9 

October 2005 

Finding F4: ADEQ should develop and submit to EPA a schedule for conducting data 

support conducted by the ADEQ Northern and Southern regional offices. 

Finding F5: The ADEQ Air Program should document and provide QA oversight where 

other agencies or contractors are operating equipment for the ADEQ program. In some 

cases, EPA or other agencies may be already doing parallel oversight of these contractors 

and may be able to support ADEQ in this task. 

Finding F6: The QA auditor has a corrective action sheet and there is also a separate 

corrective action process between the QA/Data group and the Monitoring group. These 

processes should be combined and formalized with QA and Management sign-off. 

Additionally, there should be criteria established for when corrective actions will be 

elevated to the Agency QA Manager (i.e. significant amount of data impacted, fraudulent 

data discovered, and unresolvable disagreements between Air Program QA and 

Monitoring groups). 

Finding F7: The QA group should attend general QA training given by EPA QA staff or 

attend the national EPA QA conference. The types of training would include, but are not 

limited to, training on QA systems, Quality Assurance Project Plans, Quality 

Management Systems, and proper documentation techniques. Better knowledge of the 

specific requirements of the EPA QA system would benefit ADEQ QA staff in meeting 

EPA regulatory requirements. The regular training and annual conference put on by the 

EPA QA staff are the best opportunities to get this type of training. 

Finding F8: Create audit warning and control limits based on the federal criteria and 

track audit results quarterly for compliance with the federal criteria. 

Finding F9: Develop a procedure to ensure and certify that the zero air used in 

instrument audits is free of contaminants. 

Finding F10: A copy, or other verification, of transfer standard certification (including 

date certified) should be kept in the same location as the standard.