ambient audit program protocol · referenced where applicable to primary standards in the esrd...

AMBIENT AUDIT PROGRAM PROTOCOL Purpose of this Document This document outlines the procedures used by Alberta Environment and Sustainable Resource Development (ESRD) in its Ambient Air Audit Program. Field and laboratory audit procedures, audit failure criteria and consequences are covered in this document. Also included are quality assurance measures and the maintenance of standards for the ambient air audit program. March 2014

Environmental Assurance Environmental Monitoring and Evaluation Air Monitoring

Table of Contents Page 1 Summary of Audit Services .................................................................................................................... 1

1.1 Program Goal ............................................................................................................................ 1 1.2 Scope of Ambient Audit Program .............................................................................................. 1 1.3 Glossary of Terms ..................................................................................................................... 1 1.4 Audit Program Quality Assurance Procedures .......................................................................... 2

1.4.1 Primary Reference Standards ....................................................................................... 2 1.4.2 Transfer Standards - Cylinder Gas ............................................................................... 2 1.4.3 Flow Measurement Standards ...................................................................................... 3 1.4.4 Portable Zero Air Units .................................................................................................. 4 1.4.5 Meteorological Transfer and Calibration Standards...................................................... 4 1.4.6 Audit Lab Analyzers ...................................................................................................... 4 1.4.7 Audit Calibrators ............................................................................................................ 5 1.4.8 Air Monitoring Station Audits ......................................................................................... 5 1.4.9 Calibration System and Calibration Gas Audits ........................................................... 5

2 Air Monitoring Station Audits .................................................................................................................. 6 2.1 Purpose ..................................................................................................................................... 6 2.2 Station Audit Delivery ................................................................................................................ 6

2.2.1 Planning ........................................................................................................................ 6 2.2.2 Preparation .................................................................................................................... 6 2.2.3 Delivery ......................................................................................................................... 7 2.2.4 Post Audit ...................................................................................................................... 9

2.3 Audit Assessment Criteria ......................................................................................................... 9 2.3.1 Continuous Analyzers ................................................................................................... 9 2.3.2 Other Sensors ............................................................................................................. 10

2.4 Post Audit Procedure ............................................................................................................... 10 2.4.1 Audit Lab Procedure ................................................................................................... 10 2.4.2 Reporting Procedure ................................................................................................... 11 2.4.3 Corrective Actions (Operational Concerns and Audit Failures) .................................. 11

2.5 Follow-up on Audit Failures ..................................................................................................... 12 2.5.1 Audits .......................................................................................................................... 12 2.5.2 Data ............................................................................................................................. 12

3 Calibration System and Gas Audits ...................................................................................................... 13 3.1 Purpose ................................................................................................................................... 13 3.2 Calibration System and Cylinder Gas Audit Delivery .............................................................. 13

3.2.1 Planning ...................................................................................................................... 13 3.2.2 Preparation .................................................................................................................. 13 3.2.3 Calibration Systems Audit Delivery ............................................................................. 14 3.2.4 Calibration Gas Audit Delivery .................................................................................... 15

3.3 Audit Assessment Criteria ....................................................................................................... 15 3.3.1 Calibration Systems .................................................................................................... 15 3.3.2 Calibration Gas............................................................................................................ 16

3.4 Post Audit ................................................................................................................................ 16 3.4.1 Audit Lab Procedure ................................................................................................... 16 3.4.2 Reporting Procedure ................................................................................................... 16 3.4.3 Corrective Actions ....................................................................................................... 17

4 Documentation...................................................................................................................................... 17 4.1 Data ......................................................................................................................................... 17

4.1.1 Forms and Storage ..................................................................................................... 17 4.1.2 Cylinder Gas Audits .................................................................................................... 18 4.1.3 Calibrator Audits .......................................................................................................... 18 4.1.4 Storage ........................................................................................................................ 18 4.1.5 Additional Documents ................................................................................................. 19

Purpose of this Document This document outlines the procedures used by Alberta Environment and Sustainable Resource Development (ESRD) in its Ambient Air Audit Program. Field and laboratory audit procedures, audit failure criteria and consequences are covered in this document. Also included are quality assurance measures and the maintenance of standards for the ambient air audit program. 1 Summary of Audit Services The Ambient Audit Services Section delivers audits in two components: A. Conduct audits of all ambient air monitoring stations operating within Alberta. B. Conduct audits of third party calibration systems used by operators of ambient air

monitoring stations. 1.1 Program Goal The audit function is in place to verify all air monitoring operations in Alberta are conducted in accordance with ESRD requirements. This will ensure that the data submitted to ESRD, its partnership organizations, and industry, is of consistent and high quality. 1.2 Scope of Ambient Audit Program All continuous ambient air monitoring systems in Alberta as well as equipment used by operators and third parties to calibrate them are audited under this program. The ESRD ambient audit program also verifies standards used in these calibrations. 1.3 Glossary of Terms ESRD: Alberta Environment and Sustainable Resource Development AMD: ESRD’s Air Monitoring Directive CASA: Clean Air Strategic Alliance in Alberta NIST: National Institute of Standards and Technology VSL: Dutch Metrology Institute PRM: Primary Reference Material PSI: Pounds per Square Inch SRM: Standard Reference Material US EPA: Unites States Environmental Protection Agency

ESRD Ambient Audit Program Protocol Page 1 of 19

and Sustainable Resource Development

1.4 Audit Program Quality Assurance Procedures The audit program will maintain the highest quality standards available and has adopted the following quality assurance and quality control procedures for equipment used in the audit program: 1.4.1 Primary Reference Standards 1.4.1.2 All NIST SRM gases, VSL PRM gases, NIST traceable temperature sensors,

relative humidity standards, barometric pressure sensors and primary flow standards will be kept in the ESRD Audit Lab.

1.4.1.3 All regulators are to be kept on the SRM and PRM gases. Cylinder valves are to

be closed when not in use and pressure maintained or a vacuum placed on the output stage of the regulator when not in use.

1.4.1.4 When the gas has expired or is no longer useable, the regulator is removed and

stored in a clean environment. The regulator connector will be inspected and replaced as needed and any washer (seal), if present, replaced.

1.4.1.5 All original gas concentration certificates are stored in the appropriate binder in the

ESRD Audit Lab. 1.4.1.6 SRM or PRM gases that have less that 150 PSI remaining in the cylinder are not

used in the audit program. Cylinders no longer used or expired must be returned to the manufacturer or disposed of properly.

1.4.2 Transfer Standards - Cylinder Gas 1.4.2.1 The primary standards kept at the Monitoring and Audit Centre lab will be used for

certification of transfer standards used in station audits and calibration of the Monitoring and Audit Centre lab audit analyzers.

1.4.2.2 For ammonia gas, the Dutch Metrology Institute (VSL) will be the primary standard. 1.4.2.3 Transfer standards used in field audits will be gases that meet US EPA Protocol

specifications of +/- 2% accuracy. 1.4.2.4 Transfer standards will be referenced to the NIST SRM or VSL PRM standards at

least every six months.

o All transfer standards will be traceable to NIST or VSL standards or best available standard. All certification documents will be stored on the shared drive with paper copies in the appropriate binder. Certification documents will also be attached to the transfer standards themselves.



o Ensure regulator gauges are functioning properly and that the regulator connector is in good condition. If a washer (seal) is in place ensure it is in good condition. Replace washer (seal) if it appears to be compressed too much or is damaged.

o Ensure gas delivery line attached to the regulator and to the dilution calibrator

is in good condition.

1.4.2.5 Primary Reference Materials or Standard Reference Materials used in the audit program that have passed the manufacturers certification expiry date can be used as transfer standards. They must be verified against a PRM or SRM that has not expired.

1.4.2.6 Cylinder gas transfer standards that have less that 150 pounds per square inch

(P.S.I.) remaining in the cylinder are not used. Cylinders no longer used or expired must be returned to the manufacturer or disposed of properly

1.4.3 Flow Measurement Standards 1.4.3.1 Any tubing used with flow measurement devices is inspected for wear and

replaced as necessary.

1.4.3.2 Battery voltage is checked to ensure it is sufficient to conduct flow audits. Batteries are recharge 24 hours prior to conducting the audit, if required.

Note: the battery charger must be removed at least one hour before measuring flows to avoid internal temperature being biased due to battery heat generated during re-charging.

1.4.3.3 The temperature sensor of the flow measurement device is checked against NIST traceable standard to verify that it is within manufacturer’s specification. If not re-calibrate with NIST traceable standard.

1.4.3.4 Flow measurement devices are calibrated against a primary standard at least

once per year. This recertification can be done at Environment Canada or the manufacturer. Devices should be sent to the manufacturer for any necessary repairs as needed.

1.4.3.5 All device calibration certificates are to be stored in the appropriate binder in the

ESRD Audit Lab. Copies of certificates are to be kept with the auditor. ESRD Ambient Audit Program Protocol Page 3 of 19


1.4.4 Portable Zero Air Units 1.4.4.1 Scrubber material is inspected and replaced when a colour change is noted or

pollutant breakthrough is observed during the zero air challenge to audit lab analyzers. Replacement frequency for charcoal is at a minimum every six months or as required.

1.4.4.2 All tubing is inspected for cleanliness, crimps or possible leaks. Fittings are

checked for good condition and that all connections are tight. 1.4.4.3 The air supply pump is checked for excessive noise and heat output. The air

supply pump is verified to deliver in excess of the maximum pressure required for auditing purposes.

1.4.4.4 Dates that any new scrubber material is installed and put into service is

documented by labelling scrubbers with the replacement date. 1.4.5 Meteorological Transfer and Calibration Standards 1.4.5.1 Temperature measurement sensors are referenced to NIST devices. 1.4.5.2 All meteorological transfer standards which include temperature, barometric

pressure, wind orientation (compass), humidity and radiation sensors will be referenced where applicable to primary standards in the ESRD Audit Lab.

1.4.5.3 When a standard does not exist, any certificates that are applicable will be

maintained in the Audit Lab and copies kept with the auditor. 1.4.5.4 All equipment requiring calibration or servicing will be performed yearly or more

frequently as needed. 1.4.5.5 The condition of any calibration filters to be used for particulate auditing is verified.

Filters must not be used more than manufacturer’s recommendations and must be stored in a secure and suitable container at all times when not in use.

1.4.6 Audit Lab Analyzers 1.4.6.1 Audit lab analyzers are maintained as per manufacturer’s specifications and

current ESRD Air Monitoring Directives (AMD). 1.4.6.2 Prior to a calibrator or calibration gas audit at ESRD’s Audit Lab, audit lab

analyzer(s) are calibrated using a NIST SRM or VSL PRM or a best available standard traceable to a NIST SRM or VSL PRM. Calibrations must occur one day prior to or the day of the audit.

1.4.6.3 Electronic copies of all audit lab analyzer calibrations are stored in the appropriate

ESRD electronic folder.



1.4.7 Audit Calibrators 1.4.7.1 Mass Flow Controllers (MFC)’s are recalibrated every year by either ESRD or

Environment Canada using a primary flow calibrator or flow transfer standard. 1.4.7.2 Audit calibrator ozonators are calibrated on a yearly basis or as required.

Calibration is performed using a primary reference standard at Environment Canada lab in Ottawa.

1.4.7.3 Audit calibrator photometers are calibrated on a yearly basis or as required.

Calibration is performed using a primary reference standard at Environment Canada lab in Ottawa.

1.4.7.4 Calibrator maintenance is performed as per manufacturer’s specifications. 1.4.7.5 All original certificates are stored in the appropriate binder in the ESRD Audit Lab.

Copies of certificates are to be kept with the auditor. Maintenance records are stored in the appropriate ESRD electronic folder.

1.4.8 Air Monitoring Station Audits 1.4.8.1 The accuracy of transfer standards to be used in the audit is verified by

challenging audit lab analyzers that have been previously calibrated with a NIST SRM or VSL PRM. This is verification done as close as possible to the departure date but not more than five working days prior to audit.

1.4.8.2 Calibrators that will be used for the audits are checked for proper function, and that

documentation for the calibrators is up to date. 1.4.8.3 All support equipment used to conduct the audit is checked for proper function. 1.4.9 Calibration System and Calibration Gas Audits 1.4.9.1 The ESRD audit analyzers to be used are calibrated fully using NIST SRM or VSL

PRM standards and ESRD audit equipment the day immediately prior to, or the day of the audit. Flows are verified with the primary flow standard to generate the most accurate analyzer calibration.

1.4.9.2 The analyzer must be calibrated as close to 1:1 ratio as possible. Any deviation

requires analyzer maintenance to be performed. The analyzer must be re-calibrated if maintenance has been done.

1.4.9.3 All support equipment used to conduct an audit and checked for proper function. 1.4.9.4 All calibrators used for the audits are calibrated, is checked for proper function. 1.4.9.5 All documentation is kept up to date.



2 Air Monitoring Station Audits Performance audits are conducted on all ambient air monitoring stations in Alberta. These stations can be part of networks operated by Airshed Zones, ESRD or Industrial Alliances that provide data to the CASA data warehouse or compliance stations operated by an approval holder for all or part of a year. Audits are also conducted on ambient air monitoring equipment mounted on self-contained mobile platforms or vehicles that may be used for air monitoring during air quality emergency events in Alberta. 2.1 Purpose To determine if ambient monitoring stations operated by Airshed Zones, Industrial Alliances, ESRD and other operators are operating within ESRD specified guidelines. 2.2 Station Audit Delivery The following is a description of the audit process. 2.2.1 Planning 2.2.1.1 Audits will be conducted unannounced or with minimum notification. Ambient air

monitoring stations are unmanned and prior arrangement must be made with the operators to gain access to the station.

2.2.1.2 Prior arrangement will be made no earlier than the business day immediately prior

to the audit day. In the event a week-long audit trip is planned within the same network, notification is given the owner/operator Friday afternoon.

2.2.1.3 The station operator is to make no changes to, or calibrate the station(s) after

notification of the audit and prior to its start. This does not include regularly scheduled calibrations or an emergency situation requires that work be done.

2.2.2 Preparation 2.2.2.1 Quality assurance procedures and checks on all equipment and standards are

performed. 2.2.2.2 The following will be checked prior to departure:

o Sufficient supplies are available to complete all audits planned.

o All audit equipment and related documentation is current and copies are available to provide to the owner/operator upon request.

o An inventory of equipment required for the audit during loading onto the

vehicle.



2.2.3 Delivery 2.2.3.4 Audits will be conducted against the criteria as specified in Chapter 8 of the AMD

as amended from time to time. The US EPA and/or Environment Canada methods will be used in the absence of methods specified by ESRD. Where conflicts exist, the AMD will supersede.

2.2.3.5 The operator responsible for day-to-day operation of the station or a representative

of the Owner/Operator or Airshed being audited, as applicable, must be present at minimum during the initial and final stages of the audit of each ambient air monitoring station. This is for quality assurance and to answer all questions during the audit.

o A pre audit meeting is conducted with the owner/operator of the station(s).

Attendance at the commencement of the audit is required to give the auditor access to the shelter and the on-site data acquisition system to obtain data readouts during the audit.

o The station is examined prior to the audit to ensure all equipment is operating

and that the audit equipment can be accommodated inside the station.

o The operator is requested to mark down all channels for the analyzer(s) being audited on the data acquisition system and display the data for the analyzer(s).

o Attendance at the completion of an audit provides opportunity to discuss the

audit findings and allows the operator to verify that the auditor leaves the station in an as-found condition. If an operator chooses to leave during an audit, opportunity for immediate on-site correction of any minor deficiencies is forgone.

2.2.3.3 Mobile monitoring vehicles are required to be parked indoors if at all possible in

order to conduct an audit. If auditing a mobile vehicle or stand-alone sampler where audit equipment must remain out of doors, inclement weather or excessive heat or cold that can affect the performance of the audit equipment is avoided if possible.

2.2.3.4 Audits of any equipment producing data may be conducted. This includes all

continuous monitoring analyzers, intermittent sampling equipment and other equipment such as meteorological sensors. Where possible these audits will use transfer standards traceable to NIST standards.

2.2.3.5 Continuous ambient air analyzers will be challenged with the gases they are

designed to measure.

o Total reduced sulphur analyzers will be challenged with hydrogen sulphide gas.

o Nitrogen dioxide (NO2) channel of a nitric oxide (NO) analyzer will be

challenged using the gas phase titration (GPT) method.



o Non-methane hydrocarbon (NMHC) analyzers will be challenged using

methane and propane mixtures. o Either methane or methane and propane mixtures can be used to challenge

total hydrocarbon analyzers. 2.2.3.6 During the audit, one-minute data averaging on the outputs of equipment being

audited is preferred, but instantaneous data is acceptable. Data averages must be directly available at the station while conducting the audit. Equipment responses will be taken from the on site data acquisition system including correction factors, if any, as applied by the data acquisition system. Discrepancies between the data logger readings and the front panel readings of an analyzer will be noted.

2.2.3.7 All data logger responses are recorded and a draft copy of the audit report(s)

prepared for the analyzer(s) audited. 2.2.3.8 Performance characteristics of equipment providing data that cannot be

challenged with gas standards will be examined and compared to manufacturers specifications. E.g. continuous particulate samplers, intermittent samplers, or meteorological sensors.

2.2.3.9 Output readings of meteorological sensors will be noted for quantitative and

qualitative comparison. 2.2.3.10 An inspection will be conducted of the monitoring station to determine if the siting

and operations are in compliance with the current revision of the AMD as amended from time to time.

2.2.3.11 During the audit, the following documentation may be requested from the

owner/operator for review:

o The calibration document(s) for the analyzer(s) being audited. Calibration documentation must be retained for three years.

o Maintenance record or station logbook. Note: The date, time and nature of

the audit visit are recorded in the logbook at the time of the audit. o Site documentation for each station. A copy of completed site documentation

must be kept at the station. o Wind sensor calibration record. Wind sensor calibration records must be

retained for 3 years



2.2.4 Post Audit 2.2.4.1 The station(s) will be restored to the original configuration as prior to the

commencement of the audit. The owner/operator onsite will sign the post audit checklist verifying that the station(s) has been returned to original condition.

2.2.4.2 A post-audit meeting will be conducted on site, as soon as possible following the

audit, to review the audit results with the owner/operator. If immediate action is required to correct an audit finding, the auditor will remain onsite until the deficiency is corrected or confirmation it has been completed will be requested.

2.2.4.3 A preliminary written audit report including station inspection and station summary

forms will be provided at the end of an audit. Any non-compliant issues are noted on these forms.

2.2.4.4 Any audit failures will be brought to the attention of the station owner/operator of

industrial compliance stations, or Airshed zone manager/director for Airshed network stations, as soon as possible.

2.3 Audit Assessment Criteria 2.3.1 Continuous Analyzers 2.3.1.1 Continuous analyzers will be deemed to have failed an audit if any one of the

following are demonstrated in its response to audit gas(es):

o The least squares regression analysis of the analyzer response results in a Slope of less than 0.900.

o Or the least squares regression analysis of the analyzer response results in a

Slope of greater than 1.100. o Or the comparison of the audit gas to the analyzer response results

correlation coefficient of less than 0.995. o Or the least squares regression analysis of the analyzer output results in an

intercept being greater than ± 3% of the operating full scale of the analyzer. o Or the least squares regression analysis of the analyzer response results in

any one upscale point (excluding the first or high point) that deviates more than ±5% from the Slope.

o Or any single upscale response point (excluding the zero) of the analyzer

deviates from the audit gas by more than 10%.

2.3.1.2 Results very near the failure criteria will be considered marginal. The operator should investigate the causes of these marginal results in order to minimize future failures.



2.3.2 Other Sensors 2.3.2.1 Meteorological (except wind) and other sensors can be considered to have failed if

their outputs deviate more than 15% from the audit reference. 2.3.2.2 Wind direction sensors can be considered to have failed if the recorded output

deviates more then 20 degrees from compass observation. Wind monitors can also be deemed to have failed if not within +/- 5 degrees of True North based on compass observation.

2.3.2.3 Wind speed sensors can be considered as failed if the recorded output is outside

the observed wind speed range. 2.3.2.4 Particulate or other samplers that cannot be challenged with standards will be

considered to have failed an audit if the operating parameters such as flow, temperature or programmed settings are outside the manufacturer’s specified limits.

2.3.2.5 Results very near the failure criteria will be considered marginal. The operator

should investigate the causes of these marginal results in order to minimize future failures.

2.4 Post Audit Procedure 2.4.1 Audit Lab Procedure 2.4.1.1 Upon return to audit lab, all audit findings are reviewed and uploaded from the

laptop to the proper electronic file location. 2.4.1.2 When audit failures have occurred:

o The accuracy of the audit gasses used will be verified against NIST SRM or VSL PRM gases.

o All calibrator(s) and support equipment used for the audit will be rechecked to

determine if there is a deviation in performance from what was originally verified during the pre-audit findings.

o This rechecking will be done as soon as possible and not more than 3

working days after return from the audit trip. If changes to standards or equipment performance have occurred, the cause will be determined and any audit findings revised if applicable. The draft copies of the audit report(s) will be re-issued.

2.4.1.3 An audit summary report will be prepared discussing the audit finding(s).

Recommendation(s) to aid in operational and regulatory needs will be included in the summary report.



2.4.2 Reporting Procedure 2.4.2.1 A final written audit report will be prepared within two weeks (five working days) of

completion of the audit trip. This report will include the results of audits at all the stations that were audited in the particular trip. The report will be sent to the attention of the station owner/operator of industrial compliance stations, or Airshed zone manager/director for Airshed network stations.

2.4.2.2 Summary reports will be sent to the District Compliance Manager, the District

Approvals Manager in the appropriate regional office, the ESRD representative to the Airshed Zone and the Air and Water Quality Data Management division.

2.4.3 Corrective Actions (Operational Concerns and Audit Failures) If an audit fails to meet specified criteria or performance limits the following levels of action will be employed, depending on the audit/inspection findings. Note: In the case of any audit failure, immediate corrective action must be taken with written notification of corrective actions taken supplied to the auditor as soon as they are completed and proven successful. The following timelines are intended for the communications about the actions taken. 2.4.3.1 When operational concerns are identified during an audit where an analyzer has

not failed or station operation could be improved so that rectifying these would improve data quality:

o Verbal communication of concerns at the time of the audit and a written

response of actions taken will be required within one month. o A follow up will be conducted at the next scheduled audit/inspection.

2.4.3.2 When an audit failure is determined or operation not in compliance with the AMD

occurs:

o Verbal communication of failure or non-compliance at the time of audit and written communication from the auditor will be provided within 5 working days.

o Upon receipt of the written communication, a written response must be

supplied to the auditor within one month (or time specified by the auditor) detailing actions taken.

o A follow-up audit/inspection may be conducted.



2.5 Follow-up on Audit Failures 2.5.1 Audits 2.5.1.1 Follow-up audits may be conducted on any analyzer(s) for which the Audit

Assessment Criteria indicates a failure or if the station operations did not meet with current AMD requirements during a station audit.

2.5.1.2 The follow-up audit will be conducted as soon as practicable upon receipt of

notification that the analyzer failure has been addressed and is in compliance with the current version of the AMD as revised from time to time.

2.5.1.3 The follow-up audit planning, preparation, delivery, assessment and reporting will

be conducted in accordance with sections 2.2, 2.3 and 2.4 of this document. 2.5.1.4 Verbal communication of failure or non-compliance at the time of audit and written

communication from the auditor will be provided within 5 working days. 2.5.1.5 Upon receipt of the written communication, a written response must be supplied to

the auditor within one month (or time specified by the auditor) detailing actions taken.

2.5.2 Data 2.5.2.1 An audit failure will result in data being deemed as invalid back to the time it can

be demonstrated to be valid data and up to the time the audit failure has been corrected.

2.5.2.2 It will remain the responsibility of the operator to determine at what point the data

became invalid after the last documented time of proper operation. 2.5.2.3 Once this point of invalidation has been determined, and depending on the reason

for audit failure, data must be resubmitted either as invalid or with justifiable corrections together with an explanation of what changes were made and why. ESRD will then consider whether this corrected data can be accepted.

Note: A follow-up audit/inspection failure may be reported to the appropriate ESRD Regional Compliance Section as “Followed-up Audit Failure”. An investigation by the regional ESRD Compliance Section may be requested as a result of this failure.



3 Calibration System and Gas Audits An important component of the ambient air monitoring audits is the Calibration System and Calibration Gas Audit Program. This proactive program is a complement to the field audits of air monitoring stations. It helps to minimize audit failures and ultimately contributes to better data quality from all continuous ambient air monitoring operations. This service is offered within the Monitoring and Audit Centre lab for industry, consultants and government operators of air monitoring stations in Alberta. These operators bring their calibration equipment and gases to the ESRD facility and challenge them against ESRD audit analyzers that have been previously calibrated with audit standards. This serves as a verification of their entire calibration system. 3.1 Purpose To ensure that all operators of ambient air monitoring sites in Alberta are calibrating analyzers with verified standards, calibration equipment is operating within acceptable limits and accepted procedures are being used. 3.2 Calibration System and Cylinder Gas Audit Delivery The following is a description of the audit process for calibration systems. 3.2.1 Planning 3.2.1.1 It is the responsibility of the operator of the calibration system to contact ESRD,

Monitoring and Audit Section to schedule appointments to have their calibration systems or gases verified.

3.2.1.2 These appointments are set up at a minimum once per year and at the availability

of ESRD Audit program staff rather than by a firm calendar period elapsing. 3.2.2 Preparation 3.2.2.1 Quality assurance procedures and checks on all audit equipment and standards

are performed as described in 1.4.9 (Calibration System and Calibration Gas Audits) of this document.

3.2.2.2 The following will be checked prior to the calibration system audit:

o Sufficient supplies are available to complete all audits planned. o All audit equipment related documentation is current and copies are available

to provide to the owner/operator upon request. 3.2.2.3 On the morning of the audit, the ESRD audit analyzer to be used is challenged

with zero air and, at minimum, a single upscale point to verify its operation. ESRD Ambient Audit Program Protocol Page 13 of 19


Note: ESRD does NOT certify calibrator and support equipment or calibration standards for use. 3.2.3 Calibration Systems Audit Delivery 3.2.3.1 Operators are to deliver equipment to be audited with sufficient time in advance in

advance of the audit that it will be fully up to operational specifications and all gases are at room temperature by the scheduled audit start time.

3.2.3.2 Audits will be assessed using the criteria as specified in 3.3.1.1 3.2.3.3 Operators are required to remain at the lab for the duration of the audit. In this

way they can be queried and potential procedural problems addressed. 3.2.3.4 Operators are to use their own complete systems and documentation. Calibration

systems include calibrators, standards, gas cylinder regulators, zero air systems, and flow measurement devices, calculations, laptops, calculators and procedures.

3.2.3.5 Operators are required to challenge the ESRD audit lab ambient analyzer with a

zero and 3 upscale points they provide using their calibration system. 3.2.3.6 Audit Lab analyzer responses are recorded. The performance of the calibrator is

documented based on current AMD guidelines as amended from time to time.

o If the calibrator performance meets the assessment criteria a “Verified” label with the date and auditor’s name will be applied to the calibrator.

o If any of the assessment criteria are not met, a “Do Not Use” label with the

date and auditor’s name will be applied to the calibrator. o If the results show a marginal or failure result, an effort will be made at the

time of the audit to determine the reason for failure by examining the flow measurement, calculations, procedures or other factors.

o It is the responsibility of the equipment owner to trouble-shoot and correct

calibration system deficiencies.

Note: If any of the assessment criteria are not met, the calibration system must not be used for calibrations in Alberta until the owner has rectified the problem and a follow-up audit demonstrates that system is within acceptable tolerances. 3.2.3.7 A summary report of the performance audit is prepared at the time of the audit, a

printed copy is provided to the operator upon completion and an electronic copy is filed in the appropriate file.



3.2.4 Calibration Gas Audit Delivery Note: This audit is not intended to be a substitute for certification of the standard by its supplier. 3.2.4.1 Operators are to deliver gas to be verified with sufficient time in advance of the

audit that it will be at room temperature by the scheduled audit start time. 3.2.4.2 Cylinder(s) to be audited must be accompanied with the proper regulator for the

gas in the cylinder and the cylinder gas certificate provided by the manufacturer. 3.2.4.3 The compressed gas cylinder to be audited is connected to the audit calibrator.

The auditor will generate three upscale points to challenge the audit lab ambient analyzers. Analyzer responses for all three points are recorded to determine the cylinder gas concentration.

o If the determined cylinder gas concentration meets the audit assessment

criteria, the cylinder gas is acceptable for use. A “Verified” label with the date and auditor’s name will be applied to the cylinder. The manufacturers stated gas concentration can be used.

o If the determined cylinder gas concentration does not meet the audit

assessment criteria, the cylinder gas is not acceptable for use. A “Do Not Use” label with the date and auditor’s name will be applied to the cylinder.

Note: The cylinder must not be used for calibrations in Alberta until it has been recertified and the concentration verified. 3.2.4.4 The audit result will be given as a percentage variance from the stated certified

concentration. 3.2.4.5 A summary report of the performance audit is prepared at the time of the audit, a

printed copy provided to the operator upon completion. 3.3 Audit Assessment Criteria 3.3.1 Calibration Systems 3.3.1.1 A calibration system will be deemed to have failed the audit if the audit lab

analyzer(s) demonstrated response results in any one of the following:

o The least squares regression analysis of the analyzer response results in a Slope of less than 0.900.

o Or the least squares regression analysis of the analyzer response results in a

Slope of greater than 1.100.



o Or the comparison of the audit gas to the analyzer response results

correlation coefficient of less than 0.995. o Or the least squares regression analysis of the analyzer output results in an

intercept being greater than ± 3% of the operating full scale of the analyzer. o Or the least squares regression analysis of the analyzer response results in

any one upscale point (excluding the first or high point) that deviates more than ±5% from the Slope..

o Or any single response point of the analyzer (excluding the zero) deviates

from the calibration gas value by more than 10%. 3.3.1.2 Results very near the failure criteria will be considered marginal. The operator

should investigate the causes of these marginal results in order to minimize future failures.

3.3.2 Calibration Gas 3.3.2.1 A calibration gas will be deemed to have failed the audit if the audit lab analyzer(s)

demonstrated response results in:

o The deviation between the manufacturer's stated cylinder gas concentration and the determined cylinder gas concentration of greater than 5% outside the tolerances specified by the manufacturer’s certificate.

3.4 Post Audit 3.4.1 Audit Lab Procedure Note: In the case of a calibration system or cylinder gas audit failure, a “Do Not Use” label will be applied to the calibrator or gas cylinder. Note: The operator cannot use that calibration system or cylinder gas to calibrate any equipment in Alberta until the problem has been rectified and a follow-up audit confirms that the system or gas is within an acceptable range. 3.4.2 Reporting Procedure In the case of a calibration system or cylinder gas audit failure: 3.4.2.1 The owner/operator of the calibration system or cylinder gas must provide the

auditor with a list of stations and analyzers where these were used.



3.4.2.2 A cover letter is prepared by ESRD within 5 working days of the audit and sent to the Industry or Airshed manager, the ESRD District Compliance Manager(s) where the equipment was used and Air and Water Quality Data Management division.

3.4.3 Corrective Actions 3.4.3.1 Any calibration system or gas that has failed an audit and has been labeled with

“Do Not Use” must not be used for calibrations in Alberta until the owner has rectified the problem and a follow-up audit demonstrates that system or gas is within acceptable tolerances.

3.4.3.2 Data from any analyzer calibrated with a failed calibration system or gas is

considered invalid back to the last calibration performed with a verified functioning calibration system unless the data has been reviewed and it has been demonstrated to ESRD that the data is valid or corrected to be valid.

Note: It is the responsibility of the operator to provide an explanation as to why the data should not be considered invalid. 3.4.3.3 Procedures or calculations used by the operator that contribute to a failure must be

changed to comply with accepted procedures. 4 Documentation 4.1 Data 4.1.1 Forms and Storage 4.1.1.1 All electronic forms used to document any and all work will be copies of original

blank forms. They will be appropriate for the type of audit or calibration conducted and stored accordingly in the proper electronic folders.

4.1.1.2 Data and results must not be overwritten onto electronic or paper forms containing

results from previous calibrations or audits. A new blank form must be used for each audit

4.1.1.3 Entries should be made into all form blanks on paper forms and/or data cells on

electronic forms. Where data does not apply, N.A. should be entered. 4.1.1.4 All field data forms will be hand written copies of original blank forms stored on the

computer. These written field copies are not given to owner/operator and are kept with the final report copy stored in the appropriate paper file folder associated with that client.



4.1.1.5 Any calibrations performed on audit equipment prior to conducting field audits (pre and post), cylinder gas audits or calibrator audits must be documented on the proper form. These forms will be stored in the proper electronic folder.

4.1.1.6 Any field audits conducted must be documented on the proper forms labeled as

“Draft Copy”. These printed draft copies are left with the owner/operator of the station(s).

4.1.1.7 Draft copies of field audit(s) reports will up-loaded to the network computer,

verified and corrected if required, remove the wording “Draft Copy” and be re-submitted to the owner/operator along with a final report. All field audits will be stored in the electronic folder associated to the client audited and a printed copy stored in a file folder with the auditor.

4.1.2 Cylinder Gas Audits 4.1.2.1 All cylinder gas audits will have supporting calibrations documented and stored in

the electronic folder. 4.1.2.2 All cylinder gas audits will be documented on the proper form, a printed copy given

to the client and an electronic copy stored in the electronic folder associated to the client audited.

4.1.3 Calibrator Audits 4.1.3.1 All calibrator audits will have supporting calibrations documented and stored in the

proper electronic folder. 4.1.3.2 All calibrator audits will be documented on the proper form, a printed copy given to

the client and an electronic copy stored on the computer in the electronic folder associated to the client audited.

4.1.4 Storage 4.1.4.1 Copies of originals will be kept with the auditor. 4.1.4.2 All supporting audit or calibration original equipment certificates will be stored in

the Audit Lab only.



4.1.5 Additional Documents 4.1.5.1 In addition to the above the following documents are followed as part of ESRD’s

Ambient Air Monitoring Audit Program:

o The ESRD Air Monitoring Directive (AMD) and any amendments that may be released.

o EPA Quality Assurance Handbook for Air Pollution Measurement Systems,

Volume II: Part 1, Ambient Air Quality Monitoring Program, Quality System Development (1998), Sections 15.2.1 National Performance Audit Program, Appendix 3 Measurement Quality Objectives, Appendix 12 Calibration of Primary and Secondary Standards for flow Measurement
