quality assurance project plan for the shelby county ......schd qapp revision no: 0 revision date:...

Quality Assurance Project Plan for the

Shelby County Health Department Ambient Air Monitoring Program

Pollution Control Section

Air Monitoring Branch 814 Jefferson Ave. Room 438R

Memphis, TN 38105

SCHD QAPP Revision No: 0 Revision Date: 01/31/2019 of 156

QUALITY ASSURANCE PROJECT PLAN List of Acronyms AADT annual average daily traffic AMB Air Monitoring Branch AMTIC Ambient Monitoring Technology Information Center API Advanced Pollution Instrumentation APTMD Air, Pesticides & Toxics Management Division AQI Air Quality Index AQS Air Quality System CAA Clean Air Act COC Chain of Custody CO Carbon Monoxide CBSA Core-Based Statistical Area CFR Code of Federal Regulations CV Coefficient of Variation DAS Data Acquisition System DQA Data Quality Assessment DQI Data Quality Indicators DQO Data Quality Objective DV Design Value EDAS Electronic Data Acquisition System EEMS Environmental, Engineering & Measurement Services, Inc. EPA United States Environmental Protection Agency ESC Environmental Systems Corporation FEM Federal Equivalent Method FRM Federal Reference Method ftp File Transfer Protocol FTS Flow Transfer Standard hr hour IML Inter-Mountain Laboratories, Inc. IP internet protocol IT information technology km kilometer lpm liters per minute µg microgram µg/m3 microgram per cubic meter m meter mm millimeter mmHg millimeter of mercury MQO Measurement Quality Objectives MSA Metropolitan Statistical Area NAAQS National Ambient Air Quality Standards

SCHD QAPP Revision No: 0 Revision Date: 01/31/2019 of 156 nm nanometer NPAP National Performance Audit Program NIST National Institute of Standards and Technology NO Nitric Oxide NO2 Nitrogen Dioxide NOx Oxides of Nitrogen NOy Total reactive oxides of nitrogen OAQPS Office of Air Quality Planning and Standards OSHA Occupational Safety and Health Administration O3 Ozone PAMS Photochemical Assessment Monitoring Stations pb Lead PCS Pollution Control Section pdf portable document format PEP Performance Evaluation Program PM Particulate Matter POC parameter occurrence code ppb parts per billion ppm parts per million PQAO Primary Quality Assurance Organization psi pounds per square inch PTFE polytetrafluoroethylene QA Quality Assurance QAPP Quality Assurance Project Plan QC Quality Control sccm standard cubic centimeters per minute SCHD Shelby County Health Department SESD Science and Ecosystem Support Division SLAMS State and Local Air Monitoring Station slpm standard liters per minute SOP Standard Operating Procedures SO2 Sulfur Dioxide SPM Special Purpose Monitoring SQI Service Quality Indicator TAD Technical Assistance Document TEOM Tapered Element Oscillating Microbalance TDEC Tennessee Department of Environment and Conservation TSA Technical Systems Audit TTP through the probe UV ultraviolet VSCC very sharp cut cyclone


1.0 Project Management

Title: Quality Assurance Project Plan for the Shelby County Health Department Ambient Air Monitoring Program, Revision No. 0

1.1 Approval Sheet


2.0 Table of Contents

Quality Assurance Project Plan Cover Page ………………………………………………………..1 Quality Assurance Project Plan List of Acronyms ………………………………………………..2 1.0 Project Management ........................................................................................ 4

1.1 Approval Sheet ...................................................................................... 4 2.0 Table of Contents .............................................................................................. 5 3.0 Distribution List ............................................................................................... 10

4.0 Project/Task Organization .............................................................................. 10 4.1 Air Monitoring Branch ........................................................................ 12

4.1.1 Technical Manager, PCS........................................................ 12 4.1.2 Assistant Manager, PCS ........................................................ 13 4.1.3 Supervisor ............................................................................. 13 4.1.4 Lead Technical Specialist ...................................................... 15 4.1.5 Technical Specialists ............................................................. 16 4.1.6 IML Air Science, a division of Inter-Mountain

Laboratories, Inc .............................................................. 17 4.1.7 Environmental, Engineering & Measurement

Services, Inc ...................................................................... 18 4.1.8 State of Tennessee Department of Environment and Conservation (TDEC)………………………………………………………….19 4.1.9 Shelby County Information Technology (IT) Department…..19 4.1.10 Shelby County Support Services Division ….…………………….20 5.0 Problem Definition/Background ..................................................................... 20 6.0 Project/Task Description ................................................................................. 24 6.1 Description of Work to be Performed ................................................. 28 6.2 Field Activities ...................................................................................... 28 6.3 Laboratory Activities ............................................................................ 29 6.4 Project Assessment Techniques .......................................................... 29 6.5 Project Records .................................................................................... 30 7.0 Quality Objectives and Criteria for Measuring Data Quality ......................... 31 7.1 Data Quality Objectives ....................................................................... 33 7.1.1 Intended Use of Data ........................................................... 33 7.1.2 Type of Data Needed ........................................................... 34 7.1.2.1 Carbon Monoxide ………………………………………...........35 7.1.2.2 Nitrogen Dioxide …………………………………………………..35 7.1.2.3 Ozone ……………………………………………………….…….…….36 7.1.2.4 Particulate Matter (PM10) …………………………………..….36 7.1.2.5 Particulate Matter (PM2.5) …………………………………..…37 7.1.2.6 Sulfur Dioxide ……….……………………………………….………38 7.1.2.7 Total Reactive Oxides of Nitrogen …………………….……38 7.1.2.8 Ambient Temperature …………………………………………..38 7.1.2.9 Barometric Pressure ………………………………………………39

SCHD QAPP Revision No: 0 Revision Date: 01/31/2019 of 156 7.1.2.10 Relative Humidity ……………………………………………….39 7.1.2.11 Wind Direction ……………………………………………………39 7.1.2.12 Wind Speed…………………………………………………………39 7.1.3 Tolerance Error Limits ......................................................... 39 7.2 Measurement Quality Objectives ....................................................... 40 7.3 Network Scale ..................................................................................... 75 8.0 Training/Certification .................................................................................... 75 8.1 Personnel Qualifications for Technical Specialists .............................. 76 8.2 Continuing Education and Training ..................................................... 77 9.0 Documentation and Records .......................................................................... 78 9.1 Program Policy and Procedure Documentation .................................. 79 9.2 Sample Collection Records .................................................................. 79 9.3 Chain of Custody Forms ...................................................................... 80 9.4 QA/QC Records .................................................................................... 81 9.5 Reference Materials ............................................................................ 82 9.6 Archiving and Retrieval........................................................................ 82 10.0 Network Description .................................................................................... 84 10.1 Network Objectives ........................................................................... 84 10.2 Monitoring Objectives and Spatial Scales ......................................... 85 10.3 Site Selection ..................................................................................... 86 10.3.1 Site Location ...................................................................... 86 10.3.2 Monitor Placement ............................................................ 88

10.4 Probe Siting Criteria for Pollutant Sampler/Analyzer ........................ 89 10.5 NCore Monitoring Station……………………………………………………………….89

10.5.1 Meteorological .................................................................. 90 10.5.1.1 Towers ................................................................. 91 10.5.1.2 Wind Velocity Sensors ........................................ 91 10.5.1.3 Temperature and Humidity Sensors ................... 91 10.5.1.4 Barometric Pressure Sensors .............................. 92 10.6 Near-Road Monitoring Station ......................................................... 92 10.7 Sampling Frequency ......................................................................... 93 11.0 Sampling Methodology ................................................................................. 94 11.1 Monitoring Technology/Methodology ............................................. 95 11.1.1 Sample Collection ………………………………………………96 11.2 Sample Collection Methodology ...................................................... 97 11.2.1 Physical Collection ............................................................. 97 11.2.2 Electronic Data Collection.................................................. 97 11.2.3 Support Facilities ............................................................... 97 11.2.3.1 Monitoring Station Design .................................. 97 11.2.3.2 Shelter Criteria .................................................... 98 11.2.4 Sampling/Measurement System Correction Action .......... 99 12.0 Sample Handling and Custody ..................................................................... .99 12.1 PM Filters ....................................................................................... .102 13.0 Analytical Methods ................................................................................... .104

SCHD QAPP Revision No: 0 Revision Date: 01/31/2019 of 156 14.0 Quality Control Requirements ................................................................... .105 14.1 Quality Control Procedures ............................................................. 106 14.1.1 Calibrations ....................................................................... 106 14.1.2 Multi-Point Verifications................................................... 108 14.1.3 Precision Checks ............................................................... 109 14.1.3.1 Gaseous Analyzers ............................................. 109 14.1.3.2 Particulate Samplers .......................................... 111 14.1.4 Accuracy and Bias Checks ................................................. 113 14.1.5 Performance Evaluation (PE) Audits ................................. 113 14.1.6 External Agency Audits ………………………………………………….114 14.1.7 Corrective Actions............................................................. 114 15.0 Instrument/Equipment Testing, Inspections, and Maintenance Requirements………………………………………………………………………………………..114 16.0 Instrument Standards, Certifications, and Frequency .............................. 118 16.1 Ozone Transfer Standard................................................................. 120 16.2 Flow Rate Standards ........................................................................ 120 16.3 Temperature Standards .................................................................. 121 16.4 Gas Protocol Standards ................................................................... 121 16.5 Other Devices .................................................................................. 122 17.0 Inspection/Acceptance of Supplies and Consumables …………………………....122 18.0 Non-Direct Measurements ......................................................................... 123 19.0 Data Management ...................................................................................... 123 19.1 Data Transformation ....................................................................... 125 19.2 Data Collection and Recording ........................................................ 125 19.3 Data Reduction ................................................................................ 126 19.4 Data Transmittal .............................................................................. 127 19.5 Data Verification and Validation ..................................................... 128 19.6 Data Analysis ................................................................................... 128 19.7 Data Storage and Retrieval .............................................................. 129 20.0 Data Assessments and Oversight ............................................................... 129 20.1 Assessment and Response Actions ................................................. 129 20.1.1 Network Plans/Assessments ............................................ 130 20.1.2 Technical Systems Audits.................................................. 131 20.1.3 External Performance Audits ............................................ 132 20.1.4 Internal Performance Audits ............................................ 133 20.1.5 Data Quality Audits ........................................................... 133 20.1.6 Data Quality Assessment .................................................. 134 20.1.7 Annual Data Certification ................................................. 135 20.1.8 Reporting and Resolution of Issues .................................. 136 21.0 Reports to Management ............................................................................ 137 21.1 Frequency, Content, and Distribution of Reports ........................... 137 21.2 Response/Corrective Action Reports .............................................. 138 22.0 Data Validation and Usability ..................................................................... 140 22.1 Data Review, Verification, and Validation ....................................... 140

SCHD QAPP Revision No: 0 Revision Date: 01/31/2019 of 156 22.2 Data Usability .................................................................................. 141 22.2.1 Sample Collection Procedures ......................................... 142 22.2.2 Quality Control ................................................................. 142 22.2.3 Calibration ……………………………………………………………………144 22.2.4 Data Reduction and Processing …………………………………… 144 22.2.5 Exceptional Events ……………………………………………………….144 23.0 Verification and Validation Methods .......................................................... 146 23.1 AQS Null Codes and Descriptions .................................................... 148 23.2 AQS QA Qualifier Flags .................................................................... 151 23.3 AQS Informational Flags……………………………………………………………….152 23.4 AQS Request Exclusion Qualifier Flags ………………………………………...152 24.0 Reconciliation with Data Quality Objectives (DQOs)……..…………………..…..153 25.0 References …………………………………………………………………………………………….156

List of Tables Table 3-1 Distribution List …………………………………………………………………………………………...10 Table 5-1 National Ambient Air Quality Standards ......................................................... ..22 Table 6-1 Assessment Schedule ........................................................................................ 30 Table 6-2 Critical Documents and Records …………………………………………………………………..31 Table 7-1 O3 Validation Template ..................................................................................... 43 Table 7-2 CO Validation Template .................................................................................... 46 Table 7-3 NO2, NOx, NO, NOy Validation Template .......................................................... 49 Table 7-4 SO2 Validation Template ................................................................................... 52 Table 7-5 PM2.5 Filter-Based Local Conditions Validation Template ................................ 55 Table 7-6 Continuous PM2.5 Local Conditions Validation Template ……………………………...60 Table 7-7 PM10C for PM10-2.5 Low-Volume, Filter-Based Local Conditions Validation Template ……………………………………………………………………………….….….64 Table 7-8 Continuous PM10 STP Conditions Validation Template ……………………………..….69 Table 7-9 Meteorological Measurement Methods Validation Criteria ………………………….71 Table 9-1 Documentation and Records ............................................................................ 83 Table 10-1 Summary of Spatial Scales for State and Local Air Monitoring Stations (SLAMS)....................................................................................... 86 Table 10-2 Probe Siting Criteria …………………………………………………………………………………..89 Table 10-3 Requirements for Calculating Summary Statistics .......................................... 93 Table 10-4 Pollutant Sampling Schedule and Frequency ................................................. 94 Table 11-1 SCHD SOPs …………………………………………………………………………………………………95 Table 11-2 Ambient Air Monitoring Network of Instrumentation ................................ ….96 Table 14-1 Frequency of Multi-Point Verifications……………………………………………………...107 Table 14-2 Authoritative Standards Used For Each Type of Flow Measurement ……..….108 Table 14-3 Summary of Multi-Point Check Procedures……………………………………………….109

SCHD QAPP Revision No: 0 Revision Date: 01/31/2019 of 156 Table 14-4 Summary of Precision & Accuracy Procedures …………………………………….…….111 Table 21-1 SCHD AMB Ambient Monitoring Program Reports …………………………….…......138 Table 23-1 AQS Null Value Codes ………………………………………………………………………..…......150 Table 23-2 AQS QA Qualifier Flags …………………..………………………………………..……….….……151 Table 23-3 AQS Informational Flags ………………………………………………………..……….….………152 Table 23-4 AQS Exclusion Flags ……………………………………………………………..………..…………..153

List of Figures Figure 4-1 Organizational Chart for the Shelby County Air Monitoring Branch………………11 Figure 4-2 Organizational Chart for Contractors for the Shelby County Air Monitoring Branch ………………………………………………………………………………………………….....……17 Figure 6-1 Map of Site Locations.........................................................................................25 Figure 12-1 Chain of Custody (COC) Record Form for PM2.5 Filters……………………….…..….100 Figure 12-2 Chain of Custody (COC) Record Form for PM10 Filters ………………………..……..101 Figure 12-3 IML’s Post-Exposure Analysis Flow Diagram for PM Filters ……………….......….103 Figure 19-1 Quality Control Flow Chart ……………………………………………………………….…….…124 Figure 21-1 Sample Corrective Action Form…………………………………………………………..……..139


3.0 Distribution List

The following organizations (Table 3-1) will receive paper copies of the approved Quality Assurance Project Plan (QAPP) and any subsequent revisions. Individuals taking part in the project may request additional copies of the QAPP from personnel listed under Section 4.0. A hard copy of this document is maintained in the office of the Shelby County Health Department (SCHD) Air Monitoring Branch (AMB) and available at all times to any staff involved in the ambient air monitoring program. A PDF version of the document is also available on the SCHD’s local area network (i.e. AMB shared drive) with the location accessible and known to all air monitoring staff.

Table 3-1. Distribution List

Shelby County Health Department/Pollution Control Section (Technical Manager, Assistant Manager, Air Monitoring Branch Supervisor, Lead Technical Specialist and Technical Specialists) 814 Jefferson Ave., 4th Floor Memphis, TN 38105

Inter-Mountain Laboratories, Inc. (IML) P.O. Box 661 Sheridan, WY 82801

Environmental, Engineering & Measurement Services, Inc. (EEMS) P.O. Box 357593 Gainesville, FL 32635

U.S. EPA Region 4 Air, Pesticides, and Toxics Management Division Air Data & Analysis Section Sam Nunn Atlanta Federal Center 61 Forsyth St., SW Atlanta, GA 30303-8960

U.S. EPA Region 4 Science and Ecosystem Support Division 980 College Station Rd. Athens, GA 30605-2720

4.0 Project/Task Organization

The EPA is responsible for developing the National Ambient Air Quality Standards (NAAQS), defining the quality of data necessary to make comparisons to the NAAQS, and identifying a minimum set of quality control samples from which to judge the data quality. The State and Local air monitoring organizations are responsible for taking this information and developing and implementing a quality assurance program that will



Technical Manager


Assistant Manager

Ambient Air Monitoring Branch Supervisor A

(Air Monitoring QA Officer)

Technical Specialists (3)

Lead Technical Specialist

meet the data quality requirements. It is the responsibility of the EPA and the monitoring organizations to assess the quality of the data and take corrective action, when appropriate. The SCHD PCS’s mission is to promote and protect the health and environment for the citizens of Shelby County while providing for sustainable development through protection of air and groundwater resources. This is achieved by meeting and maintaining compliance with the NAAQS for the air resources, as well as providing air quality forecasting to the Metropolitan Statistical Area (MSA), which includes Desoto County, Mississippi and Crittenden County, Arkansas. The SCHD AMB operates within the jurisdiction of the EPA Region 4 to ensure that the SCHD’s ambient air monitoring network meets or exceeds regulatory requirements.

The SCHD’s PCS is organized into 5 main divisions: Air Planning, Field Services, Title V Major Sources, Minor Sources and the Air Monitoring Branches.

The organizational structure of the SCHD AMB is shown in Figure 4-1. The organizational chart for contractors for the SCHD AMB is shown in Figure 4-2. The following information lists the specific roles and responsibilities of each significant position within the SCHD’s AMB Ambient Air Monitoring Program.

Figure 4-1. Organizational Chart for the Shelby County Air Monitoring Branch


4.1 Air Monitoring Branch

The AMB is responsible for coordinating all aspects of the SCHD’s air monitoring program, such as quality assurance activities, ambient air quality data collection, and data processing. The AMB also has the responsibility of ensuring that there is an appropriate and standardized quality assurance program within the monitoring program. In January 2015, the Shelby County AMB became its own Primary Quality Assurance Organization (PQAO) as defined by 40 CFR Part 58, Appendix A, Section 1.2. It is the responsibility of the SCHD’s AMB to implement quality assurance aspects into all phases of the environmental data collection process. Ensuring data quality is the responsibility of all AMB personnel. Technical Specialists are responsible for maintaining and operating instrumentation at their specific site locations. But, in the event of a leave of absence, another Technical Specialist within the AMB should be able to fill in and operate the instruments. Most personnel within the AMB are cross-trained and are able to operate continuous or fixed- frequency instrumentation.

4.1.1 Technical Manager, PCS The Technical Manager has the overall responsibility for managing each division

according to Shelby County policies. The Technical Manager maintains the overall responsibility for the management and administrative aspects of the QA program. The Technical Manager is responsible for establishing the QA policy and for resolving any QA issues identified through the QA program. The Technical Manager has the “stop work authority” and will make the final decisions regarding any monitoring issues. Key responsibilities of the Technical Manager include, but are not limited to the following:

Managing each Branch within the PCS

Managing and reviewing budgets, contracts, grants, and proposals

Reviewing, overseeing, and evaluating the overall air monitoring activities

Assuring that the PCS develops and maintains a current quality system

Acquiring resources and maintaining budgets pertinent to the collection of environmental data and

Maintaining an active line of communication with all Branch Supervisors The Technical Manager delegates the responsibility and authority to develop, organize,

and maintain air monitoring quality programs to the AMB Supervisor.

The Technical Manager of the PCS has direct access to the SCHD Director on all matters relating to the PCS’s operation.


4.1.2 Assistant Manager, PCS The Assistant Manager performs the Administrative duties of the Section and fulfills the

duties of the Technical Manager in his/her absence. This person maintains the Section 103 and 105 grants that provide much of the funding provided by the U.S. EPA to support the SCHD’s PCS and air quality monitoring network. This position also works with the AMB Supervisor to ensure that all reporting requirements and time frames are met to maintain grant funding. The Assistant Manager also oversees the supporting staff that assist with the financial services and budgetary requests needed to maintain the monitoring program.

4.1.3 Supervisor

The Supervisor of the AMB provides technical, quality assurance and analytical support

to the Lead and Technical Specialists in the AMB. The AMB Supervisor reports to either the Technical Manager or Assistant Manager, depending on the topic to be discussed, and serves as the AMB’s Quality Assurance officer, as well as the monitoring liaison to the EPA Region 4. The AMB Supervisor consults with the Technical Manager and Assistant Manager typically via email on QA-related issues and makes recommendations, when appropriate. The Supervisor oversees the SCHD’s ambient monitoring network and manages data submittal into the EPA Air Quality System (AQS) database. The Supervisor is also responsible for developing and implementing routine quality assurance and quality control activities of the Branch, including performing monitoring performance audits and documenting the required corrective actions. The responsibilities of the Supervisor are:

Supervising the activities of the Branch staff

Ensuring the monitoring network is operated in accordance with 40 CFR Parts 50, 53, and 58

Ensuring the monitoring program incorporates QA elements into the Standard Operating Procedures (SOPs) and Quality Assurance Project Plans (QAPPs)

Ensuring implementation of the AMB’s QA program

Assigning corrective actions to the Technical Specialists

Following up and ensuring that implemented corrective actions are appropriate and effective once they are completed

Managing and reviewing grants, budgets, proposals and allocation of resources related to monitoring

Purchasing equipment, including supplies/consumables, and issuing contracts necessary for the implementation of the monitoring program

Providing support for data reporting by reviewing, collecting (i.e., retrieving sampled PM filters from the sites, as needed), calculating, and submitting environmental and QA data into the AQS database within the appropriate time


schedule. With the exception of periodic filter collection, the Supervisor is independent of the personnel who generate data.

Assessing software and hardware needs by assuring they comply with the technical systems requirements

Ensuring all field and QA equipment are certified quarterly or annually against certified national standards

Providing guidance or assistance to field staff

Facilitating the resolution of disputes arising from discrepancies in audit findings and QA/QC issues on monitoring data

Overseeing that all necessary preventative maintenance and equipment certification activities are completed in accordance with the schedules established within the QAPP

Communicating with the EPA Region 4 personnel on issues related to monitoring and QA activities

Serving as the designated AQS administrator for the Branch and maintaining communication with the EPA Region 4 on AQS-related issues

Maintaining and submitting the Annual Network Plan and the 5-year Network Assessment to TDEC, who then submits these documents to the EPA

Developing and maintaining this QAPP and associated SOPs

Training staff on the requirements of the QAPP and SOPs

Ensuring timely updates to the QAPP and SOPs

Managing the retention of the SCHD AMB quality documents and other QA/QC records

Coordinating, reviewing and validating the collection of air quality data, which includes performing data quality assessments and flagging suspect data

Reviewing QA/QC data files prepared for AQS upload to ensure overall accuracy and completeness and generating subsequent AQS reports to verify successful and accurate upload

Conducting 40 CFR Part 58, Appendix E siting criteria evaluations

Certifying ambient air monitoring data on an annual basis according to 40 CFR 58.15

Performing PM2.5 and low-volume PM10 FRM-related QC duties, which includes ensuring data collection and handling meets the requirements of the Branch’s QAPP and SOP

Acts as the liaison with the PM2.5 and low-volume PM10 gravimetric lab IML and communicates any issues or concerns to the AMB

Acts as the liaison to EEMS for independent through-the-probe audits of the gaseous analyzers and independent audits of the PM samplers and communicates any issues or concerns to the AMB

Acts as the liaison to TDEC and communicates any issues or concerns to the AMB

Ensuring staff receive training by other providers (such as the EPA) as resources and the budget allow, as well as participating in various training and


certification activities in order to stay current on ambient air monitoring and QA requirements.

4.1.4 Lead Technical Specialist The Lead Technical Specialist is responsible for performing the activities of the

Supervisor in his/her absence. The Lead Technical Specialist reports directly to the AMB Supervisor. The Lead Technical Specialist is also responsible for carrying out the required tasks and ensuring that data quality is adhered to by following the guidance and protocols specified by the QAPP and SOPs for the field activities. Responsibilities include:

Assisting the Technical Specialists of the Branch with reports and grounds maintenance, when requested

Assisting with the development of SOPs in accordance with the EPA regulations and guidelines

Developing technical reports, assists staff in the interpretation of technical data and ensures that the fellow Technical Specialists follow the QAPP

Performing the calibrations of the monitors and samplers as specified by the QAPP and SOPs

Serving in a supportive role to the Technical Specialists to ensure that the air monitoring network of analyzers/samplers are diagnosed, operated, maintained, and calibrated according to this QAPP and applicable SOPs

Monitoring and submitting requisitions for the necessary supplies, parts, and equipment to operate the air monitoring stations

Using the data management system AirVision to collect, store, and report air quality data to the EPA

Diagnosing, investigating, and certifying the transfer standards against the primary standards in the laboratory for use in the calibration of field analyzers

Assisting the AMB Supervisor to review and input environmental data in the AQS database

Assisting the AMB Supervisor with coordinating and performing the QA activities of the monitoring program

Assisting the AMB Supervisor with conducting internal audits of the monitors/samplers operated by the SCHD network if TDEC or the contractor EEMS are not available to perform quarterly audits

Assisting the AMB Supervisor with data validation responsibilities. If there is a disagreement on how to flag/code a specific data point, the resolution is made by the AMB Supervisor

Scheduling, conducting and tracking standards’ certifications in accordance with the QAPP requirements

Assisting with submitting finalized, validated data into the AQS database on the frequency prescribed within this QAPP


Performing preventative maintenance and any necessary corrective actions on the Branch’s independent audit equipment and the PM2.5 and low-volume PM10 field equipment, as needed

Providing support to the Branch’s databases, including AirVision, EDAS, and the EPA AQS database

Assisting in training the Branch staff on QA/QC activities, as well as participating in EPA-sponsored training and certifications to keep current on technology and data handling procedures

The Lead Technical Specialist has the authority to carry out these duties and the responsibility to bring any monitoring issues to the attention of the AMB Supervisor.

4.1.5 Technical Specialists The Technical Specialists (3 positions) report to the AMB Supervisor and are responsible

for conducting routine air quality monitoring and QC activities. They are responsible for most of the equipment troubleshooting and repairs, in addition to the monitoring site (building and grounds) maintenance. Their duties include, but are not limited to the following:

Diagnosing, operating, maintaining, and calibrating (i.e. performing multi-point verifications/calibrations) an air monitoring network of continuous analyzers and fixed-frequency samplers according to this QAPP and applicable SOPs

Performing weekly precision checks and verifying that performance specifications as defined in the SOPs are met

Performing and documenting all monitoring equipment maintenance activities

Performing troubleshooting on equipment and implementing corrective actions when necessary

Certifying the transfer standards against the primary standards in the laboratory for use in the calibration of field analyzers

Maintaining QC records and documentation

Monitoring and submitting requisitions for the necessary supplies, parts, and equipment to operate the air monitoring stations

Assisting with the development of SOPs in accordance with the EPA regulations and guidelines

Verifying that all QC activities are performed and that measurement quality objectives are met as prescribed in the QAPP

Documenting deviations from the established procedures and methods listed in the QAPP and SOPs

Reporting nonconforming conditions and corrective actions to the AMB Supervisor


Ambient Air Monitoring Branch

Supervisor A

(Liaison or Point of Contact)

IML Air Science, a division of

Inter-Mountain

Laboratories, Inc. (IML)

Environmental, Engineering and

Measurement Services, Inc. (EEMS)

Collecting, calculating, and reviewing environmental data, including the set-up and collection of PM2.5 and low-volume PM10 samples

Assisting in the acquisition of resources and maintenance of equipment and inventories

Participating in training and certification activities and, in some instances, training fellow Technical Specialists

The Technical Specialists have the authority to carry out these duties and the responsibility to notify the AMB Supervisor of any issues related to carrying out these responsibilities. Figure 4-2. Organizational Chart for Contractors for the Shelby County Air Monitoring Branch

4.1.6 IML Air Science, a division of Inter-Mountain Laboratories, Inc.

The SCHD AMB has an agreement with IML for particulate matter [particles with an average aerodynamic diameter of 10 micrometers or less (PM10) (low-volume) or 2.5 micrometers or less (PM2.5) or between 10 micrometers and 2.5 micrometers (PM10-2.5) (coarse)] filter analysis. The goal of IML is to determine the concentration, in units of micrograms per cubic meter (µg/m3), of particulate matter with an average aerodynamic diameter of 2.5 micrometers (µm) and less (PM2.5). This determination follows 40 CFR Part 50, Appendix L. Filters with low-volume PM10 concentrations are analyzed the same as the PM2.5 filters. The method is a manual one in which a sample is collected on a filter by passing a low volumetric flow rate of ambient air through the filter for a period of 24 hours. The filter is 46.2 mm in diameter and typically constructed of a polytetrafluoroethylene (PTFE) membrane. The filter is analyzed


gravimetrically, with a weighing balance sensitivity of ±1 µg, before and after the sample collection to determine the net mass gain. IML has several levels of management that oversee the laboratory process. The Vice President of IML provides the assistance and management of the services at the corporate level. The Section Manager of IML is responsible for the staffing and performance reviews. The Data Manager maintains the data management system. The QA/QC Manager is responsible for the QA/QC activities. IML operates under its own QAPP and SOPs. These documents can be provided to the SCHD AMB upon request. IML has provided the opportunity for any monitoring agency to audit their laboratory. This has not been conducted by the SCHD AMB, but can occur when budgets and resources allow, and when each organization agrees that it would be beneficial. Officials from the EPA Region 4 have conducted audits of IML with satisfactory results. Reports have been provided to the SCHD AMB. The Laboratory Supervisor is responsible for the laboratory services and for data reporting. The Laboratory Supervisor assists with laboratory operation and sample analysis. The Supervisor’s duties include:

Adhering to the guidance and protocols prescribed by the QAPP for laboratory activities. The IML Supervisor has provided a copy of the latest QAPP which is awaiting approval by the EPA to the SCHD AMB

Directing the activities of laboratory personnel

Ensuring the implementation of laboratory SOPs and sections of the QAPP as they pertain to filter processing

Preparing and updating laboratory SOPs and good laboratory practices documents

Verifying that all required QA activities are performed and that measurement quality standards are met

Maintaining QA records, flagging suspect data, and assessing and reporting on laboratory data quality

Performing and documenting all maintenance of laboratory equipment

Providing training and certification to laboratory personnel

In the event that IML cannot complete PM sample analyses, the SCHD does not have a back-up laboratory in place.

4.1.7 Environmental, Engineering & Measurement Services, Inc.

The SCHD AMB has an agreement with Environmental, Engineering & Measurement Services, Inc. (EEMS) to perform quarterly performance audits of the SCHD monitoring network analyzers/samplers. Priority is given to the ozone analyzers, then the gaseous


pollutants at the NCore and Near-Road monitoring sites, and finally the PM samplers. The trained and certified EEMS field scientist follows the NPAP procedures while performing audits of all of the gaseous air quality monitors. The field scientist also performs the flow, temperature, barometric pressure, leak and clock checks of the PM samplers. The NPAP is a QA program implemented by the EPA Office of Air Quality Planning and Standards (OAQPS) to conduct audits of the gaseous air pollutant analyzers by standard methods throughout each region of the U.S. The method includes introduction of National Institute of Standards and Technology (NIST) traceable audit gases to the station analyzers through the ambient sample inlet, including all filters and fittings. This method evaluates the entire sample train. The audit gas concentrations are also measured and verified with an audit analyzer on-site which is calibrated at the time of the audit. The calibration performed verifies the zero value before and after the audit of the analyzers. This information is documented in the audit report provided by EEMS. EEMS performs the Through-the-Probe (TTP) gas analyzer audits following EPA’s Quality Assurance Guidance Document – Method Compendium – Field Standard Operating Procedures (SOP). EEMS also performs flow verification, temperature, barometric pressure, time and leak checks for the PM samplers similar to the guidance provided for the Federal PM2.5 Performance Evaluation Program. The NPAP-TTP Audit SOP is also used as a guidance document. All procedures and guidance documents used to perform these audits can be found at the following EPA website: https://www.epa.gov/amtic.

4.1.8 State of Tennessee Department of Environment and Conservation (TDEC)

TDEC schedules and performs infrequent biannual audits of the SCHD AMB’s gaseous pollutant analyzers and PM samplers. These audits are performed supplementary to the EEMS audits.

4.1.9 Shelby County Information Technology (IT) Department

The IT Department is a separate entity within Shelby County Government, but serves in a supporting role to the SCHD AMB ambient air monitoring program. Their duties include:

Assuring site computers are networked to the County servers to assure the proper transport and storage of air monitoring data

Assisting with telecommunication services at the air monitoring sites

Assisting with the backup and security of all data used by the SCHD AMB

Supporting workstation configurations to assure appropriate access to the EPA database AQS and other on-line reporting

Maintaining servers and data security

https://www.epa.gov/amtic


4.1.10 Shelby County Support Services Division

The Support Services Division is also a separate entity of the SCHD PCS. They provide assistance to the SCHD AMB in the construction, maintenance and repairs of the monitoring sites (buildings and grounds).

5.0 Problem Definition/Background

In 1970, the Clean Air Act (CAA) was signed into law. Sections 108 and 109 of the CAA govern the establishment of and revision of the NAAQS (40 CFR Part 50) for certain air pollutants (i.e., criteria pollutants) that are determined to contribute to air pollution that is harmful to public health and welfare. The NAAQS establish limits for each of these pollutants as shown in Table 5-1. Primary standards are set at a level adequate to protect public health within an acceptable margin of safety, while secondary standards are set at a level that is requisite to protect public welfare. The CAA and its amendments provide the framework for the monitoring of these criteria pollutants by state, local, and tribal air monitoring organizations. Under the area designations process, data from ambient air monitors are typically used to characterize air concentrations for identification of areas that are either meeting or violating a particular pollutant standard. Monitors used for comparisons against a NAAQS are typically designated as State and Local Air Monitoring Stations (SLAMS) monitors and must meet the requirements stipulated in 40 CFR Parts 50, 53, and 58. For most of the criteria pollutants, three years of valid, quality-assured data are needed for comparison against the NAAQS. In the late 1960’s, a program was initiated by the Memphis and Shelby County Health Department to determine the nature and extent of air pollution in Memphis and Shelby County and to make recommendations concerning steps necessary to protect the air resources. Information was obtained by questionnaires, interviews with representatives of industry, inspection of industrial plants, and study of the meteorological data of the area and air sampling data. The objective of the SCHD Air Monitoring Program is to protect the health and sustainability of Shelby County by identifying any violations to the NAAQS, locating the highest ambient pollution concentrations across the area, and determining the general background concentration. The SCHD AMB has continuously operated, maintained, and updated the Air Monitoring Program since the late 1960’s, in accordance with county, state, and federal monitoring requirements. The ambient air monitoring data collected are used to support the local, state, regional, and federal air monitoring programs, County organizations, and the general population. The SCHD ambient air monitoring program is established to assure the most applicable and highest quality data are collected to provide a basis for establishing rules,


guidelines, and procedures to provide this protective environment to Shelby County and its residents. The SCHD AMB air monitoring program currently includes monitoring and data reporting for the following criteria pollutants: carbon monoxide (CO), nitrogen dioxide (NO2), ozone (O3), particulate matter [particles with an average aerodynamic diameter of 10 micrometers or less (PM10) (low-volume), 2.5 micrometers or less (PM2.5) or between 10 micrometers and 2.5 micrometers (PM10-2.5) (coarse)], and sulfur dioxide (SO2). The SCHD AMB also monitors for a non-criteria pollutant, total reactive oxides of nitrogen (NOy), as part of the trace-level NCore monitoring requirements. The SCHD AMB no longer monitors for lead due to the small sources of lead-emitting facilities (less than 0.5 ton per year) operating in Shelby County. Non-source lead monitoring ended in June 2017 at the NCore site due to the EPA’s 2016 revisions to 40 CFR Part 58.

In 2005, the U.S. EPA implemented the National Ambient Air Monitoring Strategy (NAAMS). The goal of the NAAMS was to include improvement of the scientific and technical competency of the nation’s air monitoring networks and increase the value in protecting public health and the environment. While the obvious problems of widespread elevated concentrations have been largely solved for some of the criteria pollutants, problems related to particulate matter (PM), ozone (O3), and toxic air pollutants remained. As emissions reductions were realized and concentrations shifted downward, high sensitivity monitors in urban areas would support the detection of trends. One of the major areas of investment in the NAAMS was the use of highly sensitive commercial air pollutant monitors for the characterization of the precursor gases CO, SO2, and total reactive oxides of nitrogen (NOy) in a new national core monitoring network (NCore). NCore is designed to meet a number of important data needs: improved flow and timely reporting of data to the public, including supporting air quality forecasting and information systems such as AIRNow; continued determination of NAAQS compliance; improved development of emissions control strategies; enhanced accountability for the effectiveness of emission control programs; and more complete information for scientific, public health, and ecosystem assessments. The overarching objective of the high sensitivity precursor gas monitoring in NCore is to determine concentrations in well-mixed representative rural and urban atmospheres. In 2009, the SCHD AMB received approval from the U.S. EPA Region 4 to establish the NCore station at the Shelby Farms site location. The Shelby Farms site location is an urban NCore site, and it meets the monitoring requirements in 40 CFR Part 58, Appendix D, Section 3 (a) for the State of Tennessee. The NCore sites must measure, at a minimum, PM2.5 particle mass using continuous and integrated/filter-based samplers, speciated PM2.5, PM10-2.5 particle mass, O3, SO2, CO, NO/NOy, wind speed, wind direction, relative humidity, and ambient temperature. The carbon and speciation monitors located at the NCore station are operated in accordance with the EPA QAPP for PM2.5 Chemical Speciation Sampling at Trends, NCore, Supplemental and Tribal Sites (EPA-454/B-12-003, June 2012), which can be referenced in the following link: https://www3.epa.gov/ttnamti1/files/ambient/pm25/spec/CSN_QAPP_v120_05-2012.pdf. A hard copy of this EPA QAPP is also available in the SCHD AMB lab.

https://www3.epa.gov/ttnamti1/files/ambient/pm25/spec/CSN_QAPP_v120_05-2012.pdf

https://www3.epa.gov/ttnamti1/files/ambient/pm25/spec/CSN_QAPP_v120_05-2012.pdf


In February 2010, the US EPA promulgated a revised 1-hour NAAQS for nitrogen dioxide (NO2). With the new minimum monitoring requirements associated with this revised 1-hour NAAQS, state and local air monitoring agencies are required to install near-road NO2 monitoring stations at locations where peak hourly NO2 concentrations are expected to occur within the near-road environment in larger urban areas. In the rulemaking process leading to the NO2 NAAQS revision, it was established that the combination of higher urban population densities with increased vehicle miles traveled, which correspond to on-road mobile source emissions, can result in an increased potential for exposure and associated risks to human health and welfare. The primary objective of the required near-road NO2 network is to focus monitoring resources on near-road locations where peak, ambient NO2 concentrations are expected to occur as a result of on-road mobile source emissions. In addition to NO2 monitoring, the SCHD AMB measures for CO and PM2.5 at the site location approved by the U.S. EPA in 2013 on the campus of Southwest Tennessee Community College. The SCHD AMB is operating the Near-Road site in accordance with 40 CFR Part 58, Appendix D, Section 4.3.2. The SCHD AMB is required to operate the Near-Road site because of the population criteria listed in 40 CFR Part 58, Appendix D, Section 4.3.2. The CO analyzer and PM2.5 sampler are required to be collocated at this Near-Road site pursuant to 40 CFR Part 58, Appendix D, Sections 4.2.1 and 4.7.1(b)(2). Table 5-1. National Ambient Air Quality Standards

Pollutant Primary/Secondary Averaging Time Level Form

Carbon Monoxide (CO) Primary 8 hours 9 ppm Not to be exceeded more than once per year 1 hour 35 ppm

Lead (Pb) Primary and Secondary Rolling 3-month average

0.15 μg/m3 (1)

Not to be exceeded

Nitrogen Dioxide (NO2) Primary 1 hour 100 ppb 98th percentile of 1-hour daily maximum concentrations,

averaged over 3 years

Primary and Secondary 1 year 53 ppb (2)

Annual Mean

Ozone (O3) Primary and Secondary 8 hours 0.070 ppm (3)

Annual fourth-highest daily maximum 8-hour

concentration, averaged over 3 years

Particulate Matter (PM)

PM2.5 Primary 1 year 12.0 μg/m3 annual mean, averaged over 3

years

Secondary 1 year 15.0 μg/m3 annual mean, averaged over 3

years

Primary and Secondary 24 hours 35 μg/m3 98th percentile, averaged over

3 years

PM10 Primary and Secondary 24 hours 150 μg/m3 Not to be exceeded more than

once per year on average over 3 years

Sulfur Dioxide (SO2) Primary 1 hour 75 ppb (4)

99th percentile of 1-hour daily maximum concentrations,

averaged over 3 years

Secondary 3 hours 0.5 ppm Not to be exceeded more than once per year

(1) In areas designated nonattainment for the Pb standards prior to the promulgation of the current (2008) standards, and for which implementation plans to attain or maintain the current (2008) standards have not been submitted and approved, the previous standards (1.5 µg/m3 as a calendar quarter average) also remain in effect.

https://www.epa.gov/criteria-air-pollutants/naaqs-table


(2) The level of the annual NO2 standard is 0.053 ppm. It is shown here in terms of ppb for the purposes of clearer comparison to the 1-hour standard level. (3) Final rule signed October 1, 2015, and effective December 28, 2015. The previous (2008) O3 standards additionally remain in effect in some areas. Revocation of the previous (2008) O3 standards and transitioning to the current (2015) standards will be addressed in the implementation rule for the current standards. (4) The previous SO2 standards (0.14 ppm 24-hour and 0.03 ppm annual) will additionally remain in effect in certain areas: (1) any area for which it is not yet 1 year since the effective date of designation under the current (2010) standards, and (2)any area for which implementation plans providing for attainment of the current (2010) standard have not been submitted and approved and which is designated nonattainment under the previous SO2 standards or is not meeting the requirements of a SIP call under the previous SO2 standards (40 CFR 50.4(3)), A SIP call is an EPA action requiring a state to resubmit all or part of its State Implementation Plan to demonstrate attainment of the required NAAQS.

The U.S. EPA regulations require that all projects involving the generation, acquisition, and use of environmental data are planned, documented and have an approved QAPP. The QAPP is the critical planning document for any environmental data collection operation because it documents how QA and QC activities will be implemented during the project’s life cycle. Adherence to the requirements set forth in this QAPP will ensure consistent, repeatable results and improve the reliability and comparability of all data collected. The SCHD AMB’s QAPP was developed to implement QA and QC policies and procedures. The QAPP incorporates standard procedures to be followed in all air monitoring projects. The SCHD will adhere to the principles and procedures herein, unless a special project requires more stringent requirements. If any special project requires more stringent requirements, the QAPP will be revised or, depending on the purpose and scope of the project, a separate QAPP will be developed to address the requirements of the special project. Additional details and technical specifications are set forth in separate SOPs utilized by the SCHD AMB for each aspect of the monitoring program, such as instrument operations (see Section 11.1). The SCHD’s AMB QAPP and SOPs will be reviewed annually and revised if procedures have changed or updates are needed. A form is provided by the AMB Supervisor and rotated among all staff members in the AMB. Each Technical Specialist in the AMB will initial and date the form indicating that a copy of the document was received and reviewed. This log sheet is filed with the respective QAPP or SOP. The QAPP will be revised and updated every 5 years, at a minimum. The changes in the QAPP are subject to the approval of the EPA’s Region 4 QA staff. Prior to the development of this QAPP in 2018, the SCHD AMB operated under the QAPP established and maintained by TDEC. Due to the SCHD AMB becoming a separate PQAO in January 2015, the SCHD AMB developed this QAPP for its air monitoring program to be more aligned with its current operations. This document presents the state of the SCHD’s Air Monitoring Program’s QAPP. The purpose of the SCHD AMB’s QAPP is to describe requirements, procedures, and guidelines for the Air Monitoring QA program. It is intended to serve as a reference document for implementing and expanding the QA program and provides detailed operational procedures for measurement processes used by the monitoring staff. The


QAPP should be particularly beneficial to operators, project officers, and program managers responsible for implementing, designing, and coordinating air pollution monitoring projects. The QAPP is a compilation of QA requirements, procedures, and guidelines that are applicable to air pollution and meteorological measurement systems. They are designed to achieve a high percentage of valid data samples (>75%) while maintaining integrity and accuracy. This QAPP clearly and thoroughly establishes QA protocols and QC criteria required to successfully implement and maintain the SCHD’s Ambient Air Monitoring program. The SCHD is recognized as its own PQAO, and thus, it has the responsibility to ensure that the quality assurance programs for the field, laboratory, and data processing phases of the monitoring program are implemented. Quality assurance is a system of management activities designed to ensure that the data produced by the operation will be of the type and quality needed and expected by the data user. Quality control defines the procedures implemented to assure that acceptable precision, bias, sensitivity, completeness, representativeness, and comparability are obtained and maintained in the generated data set. Quality control procedures, when properly executed, provide data that meet or exceed the minimally acceptable quality criteria established to assist management in making confident decisions. It is the policy of the SCHD AMB to implement a QA program and QC procedures to assure that data of known and acceptable precision, bias, sensitivity, completeness, comparability, and representativeness are collected in all monitoring projects.

6.0 Project / Task Description

This QAPP was developed to ensure that the SCHD’s ambient air monitoring network collects ambient pollutant and meteorological data that meet or exceed the requirements set forth in 40 CFR Parts 50, 53, and 58. Criteria pollutant data collected by the SCHD AMB is used for regulatory decision-making purposes (i.e., determining compliance with the NAAQS) and will be submitted to the EPA via the Air Quality System (AQS). Other uses of the data include determining trends over time, determining effects on air quality from adjustments to source emissions, developing algorithms based on historical air quality and other conditions which will forecast air quality, and providing real-time monitoring data to the public. The SCHD AMB operates 5 ambient air monitoring stations in the Shelby County area. The locations and information for each ambient monitoring site maintained and operated by the SCHD AMB are shown in Figure 6-1.


Figure 6-1. Map of Site Locations

1. Alabama Ave. (47-157-0024) – This SLAMS station monitors for fixed-frequency PM2.5, continuous low-volume PM10 and the National Radiation Radnet program. This site is located at 416 Alabama Ave. This site is approximately 25 meters south of Interstate 40 and 50 meters north of apartment complexes. This is a neighborhood scale site with the objective of monitoring population exposure.

2. Edmund Orgill Park (47-157-1004) – This SLAMS station monitors for ozone (from March to October) and is located in the City of Millington at 6855 Mudville Rd. This is an urban scale site with the objective of monitoring the population exposure.

3. Frayser Blvd. (47-157-0021) – This SLAMS station currently supports monitoring for ozone from March to October. It is located at 1330 Frayser Blvd. It is located downwind of the Metro-Memphis area in a heavily populated area. This is a neighborhood scale site with the objective of monitoring population exposure.


4. Shelby Farms (NCore) (47-157-0075) – This SLAMS and NCore station supports monitoring for carbon monoxide (CO) (trace), ozone (O3) (year-round), total reactive oxides of nitrogen (NOy) (trace), particulate matter (PM) [2.5 (fixed-frequency, collocated FRM, and continuous), and fixed-frequency low-volume 10, 10-2.5, carbon, and chemical speciation], sulfur dioxide (SO2) (trace), and meteorological data (ambient temperature, barometric pressure, relative humidity, wind direction and wind speed). The carbon and chemical speciation monitors operate as part of the Chemical Speciation Network. This station is located at 6388 Haley Rd. The placement of the site is east of the urban core and provides the best location for measuring transport and secondary pollutant formation from that area. This site is located downwind of the more industrialized areas. This is a neighborhood and urban scale site with the objective of measuring population exposure.

5. Southwest Tennessee Community College (SWTCC) (Near-Road) (47-157-0100) – This SLAMS and Near-Road station monitors for carbon monoxide (CO) (trace), nitrogen dioxide (NO2) (trace) and fixed-frequency PM2.5. This site is located at 5767 Macon Cove on the campus of SWTCC. This site was established in 2014 as part of the second phase of the core-based statistical area Near-Road NO2 monitoring. This is a neighborhood and urban scale site with the objective of measuring the highest pollutant concentration.

In accordance with 40 CFR Part 58, Appendix D, Section 1.1, SLAMS monitoring networks must be designed to meet three basic monitoring objectives: provide air pollution data to the general public in a timely manner; support compliance with ambient air quality standards and emissions strategy development; and support for air pollution research studies. The SCHD AMB ambient air monitoring network is designed to support these objectives. Additional specific goals of the SCHD ambient air monitoring program include:

Determining concentrations in a well-mixed representative urban atmosphere through high sensitivity precursor gas monitoring.

Contributing to a representative report on air quality across the nation, capable of delineating differences among geographic and climatological regions.

Providing multi-pollutant monitoring data which can be used in health studies, air quality models and source attribution methods to separate confounding effects, particularly in the face of varying ambient concentrations and particulate matter composition.

Determining the highest concentrations expected to occur in the area covered by the monitoring network

Determining representative concentrations in areas with high population density and/or heavily congested areas


Determining the impact on ambient pollution levels of significant sources emitting pollutants in the area

Determining the general background concentration levels

Providing data to the State of Tennessee and the EPA to assist these agencies in determining regional transport of specific pollutants and in support of secondary standards and visibility impairment issues

Determining the extent of regional pollutant transport among populated areas and in support of secondary standards

Determining the welfare-related impacts in rural and remote areas (such as visibility impairment and effects on vegetation)

Data will be reported to the AQS in accordance with the requirements stated in 40 CFR 58.16. The SCHD’s monitoring network will operate and collect samples in accordance with the schedules in 40 CFR 58.12. The ambient air monitoring criteria pollutant concentration data will be collected by monitors and samplers that have been designated as Federal Reference Method (FRM) or Federal Equivalent Method (FEM), in accordance with 40 CFR Part 58, Appendix C, Section 2.1. Collocation of monitors will occur in accordance with 40 CFR Part 58, Appendix A requirements. The types of data collected by the SCHD AMB monitoring network will include:

Continuous hourly-averaged pollutant concentration data collected by FRMs and FEMs

Continuous hourly-averaged pollutant concentration data collected by the NOy analyzer which is not a FRM or FEM

Continuous five-minute averaged SO2 concentration data collected by FRMs and FEMs

24-hour particulate matter samples collected by FRMs or FEMs in the field, and subsequently analyzed at the laboratory using the appropriate analytical method

Continuous hourly-averaged PM2.5 concentration data collected by non-FEMs in order to report data to the Air Quality Index (AQI)

Continuous hourly-averaged ambient temperature, barometric pressure, relative humidity, wind direction and wind speed data collected by meteorological equipment

Continuous shelter temperature measurements for ensuring conformity to environmental requirements of the air monitoring equipment

Precision measurements

Bias measurements

Geographic measurements (e.g. locational, demographic, topographical)

Monitor and site metadata for AQS


6.1 Description of Work to be Performed The planning and execution required to collect, document, and report this data includes, but is not limited to:

Establishing a monitoring network for: o appropriate density, location, and sampling frequency o applicable chemical species monitors o associated meteorological monitoring o accurate and reliable data recording equipment, procedures, and

software

Developing encompassing documentation for: o data and report format, content, and schedules o quality objectives and criteria

Establishing standard operating procedures, which provide activities and schedules for:

o equipment operation and preventative maintenance o instrumentation calibrations, zero and span checks of gaseous analyzers,

and precision and accuracy evaluations

Establishing assessment criteria and schedules

Verifying and validating the data produced by network monitors in accordance with the criteria and schedules established herein.

6.2 Field Activities

The SCHD air monitoring staff will perform those activities that support continued successful operation and expansion of the ambient air monitoring network. Staff will perform field activities that include, but are not necessarily limited to the activities listed:

Conducting calibrations and routine QC checks on SLAMS monitors/samplers

Conducting periodic preventative maintenance and servicing of equipment located at SLAMS sites within Shelby County.

Performing building/grounds maintenance activities to assure appropriate climate conditions within the monitoring stations

Performing routine site operations and servicing activities that include, but are not limited to:

o Verifying analyzer status and diagnostics to ensure continuous data collection

o Recording pertinent field data and measurements in site logbooks and on required SCHD AMB quality control check forms

o Restocking consumables, such as calibration gases


Locating suitable monitoring sites for relocation of existing monitoring equipment or the location of new monitoring stations, when needed, and

Collecting filter-based PM2.5 FRM and low-volume PM10 samples and shipping them to IML for subsequent analysis

Also, EEMS, TDEC staff, and/or the Lead Technical Specialist and Supervisor may perform quarterly instrument performance audits which include visiting and accessing monitoring stations in the field.

6.3 Laboratory Activities

The SCHD AMB does not operate a gravimetric laboratory in support of the criteria pollutant program. The laboratory activities for particulate matter filter analysis are completed by IML. The activities performed by IML include PM2.5 and low-volume PM10

filter conditioning, weighing, shipping, preparing filter analysis reports, and archiving, among others. IML prepares and emails a data package to the SCHD AMB on a monthly basis (approximate) that contains the results of the gravimetric analyses in the form of a detailed spreadsheet along with electronic copies of the site’s chains of custody. The AMB Supervisor reviews and processes these data packages for the SCHD AMB, and completes the final validation of particulate matter data in accordance with this QAPP. Any issues observed with the laboratory data packages received will be discussed with the AMB as well as communicated to IML. Specific details and procedures for the IML gravimetric laboratory can be found in the IML QAPP. The draft IML Low Volume PM QAPP Rev. 14 is saved on the AMB shared drive. The SCHD AMB communicates with IML on an ongoing basis regarding the gravimetric analysis of the Branch’s PM samples. IML has weighed filters for the SCHD AMB since 2014. Prior to IML, TDEC performed the analysis of the filters for the SCHD AMB since the inception of the Branch’s PM program. The SCHD AMB also performs certification of the field calibrators in the AMB laboratory. The goal is to complete this certification quarterly. This entails the Technical Specialist bringing the Level 3 ozone or gas dilution calibrators back to the lab once a quarter and comparing these field calibrators against the Level 2 ozone transfer standard or factory certified/calibrated mass flow controllers. The specifics of the certification are documented in the SOP for ozone transfer standard or mass flow controllers (see Table 11-1).

6.4 Project Assessment Techniques

An assessment is an evaluation process used to measure the performance or effectiveness of a system and its elements. As used here, “assessment” is an all-inclusive term used to denote any of the following: audit, performance evaluation, peer


review, inspection, or surveillance. Information on the parties implementing assessments and their frequencies is provided in Table 6-1.

Table 6-1. Assessment Schedule

Assessment Type Assessment Agency Frequency

Technical Systems Audit EPA Region 4 Every 3 years

Network Plan/Network Review (including site evaluations for 40 CFR Part 58, Appendix E criteria)

EPA Region 4 SCHD AMB

Annually

Data Qualifiers/Flags Review SCHD AMB Monthly

Standard Operating Procedures Reviews

SCHD AMB Annually

Data Quality Assessment SCHD AMB Quarterly

Network Assessment SCHD AMB Every 5 years

QAPP Review SCHD AMB Annually; Revised every 5

years, minimally

Instrument Performance Audits

EEMS TDEC

SCHD AMB

Quarterly by EEMS, Biannually by TDEC, As needed by SCHD

AMB

PM2.5 Performance Evaluation Program (PEP)

EPA-Designated Contractor

5 valid performance evaluation audits per year; 100% of sites

every 6 years

PM10-2.5 Performance Evaluation Program (PEP)


As needed

National Performance Audit Program (NPAP)


20% of sites per year; 100% every 6 years

Data Certification SCHD AMB Annually

6.5 Project Records The SCHD AMB will establish and maintain procedures for the timely preparation,

review, approval, issuance, use, control, revision, and maintenance of documents and records. The categories and types of records and documents that are applicable to document control for ambient air quality information are presented in Table 6-2. Information on key documents in each category is explained in more detail in Section 9.


Table 6-2. Critical Documents and Records

Categories Record/Document Type

Site Information

Network Descriptions Site Files Site Maps Site Pictures

Environmental Data Operations

Quality Assurance Project Plans Standard Operating Procedures Field Logbooks Sample Handling/Custody Records Inspection/Maintenance Records

Raw Data Any Original Data (routine and quality control) including Data Entry Forms IML data packages

Data Reporting Air Quality Index Reports Annual AQS Reports Data/Summary Reports

Data Management Data Algorithms Data Management Plans/Flowcharts Data Management Systems

Quality Assurance

Network Reviews & Assessments Data Quality Assessments Quality Assurance Reports (i.e. flow

verification, QC check) EPA Technical Systems Audit Reports Response/Corrective Action Reports Site Audits (SCHD performance audits, EEMS performance evaluation reports and TDEC performance evaluation reports) NIST traceability certification forms/certificates

7.0 Quality Objectives and Criteria for Measuring Data Quality

The SCHD PCS’s Quality Management Plan (QMP) was approved by the EPA Region 4 on July 3, 2018. The AMB is operating under this approved QMP. This QMP describes the system for communicating and implementing quality within the SCHD PCS. A quality system is a structured and documented set of management activities in which an organization applies sufficient quality control practices in order to ensure that the data produced by an operation will be of the type and quality needed and expected by the data user. Quality control defines the procedures implemented to assure that acceptability is obtained and maintained in the generated data set. Quality control


procedures, when properly executed, provide data that meet or exceed the minimally acceptable quality criteria established to assist management in making confident decisions. The policy of the SCHD AMB is to implement a QA program to assure that data of known and acceptable precision, bias, sensitivity, completeness, comparability, and representativeness are collected within its Ambient Air Monitoring Program.

Defined in Sections 7.2 and 7.3, precision, bias, sensitivity, completeness, comparability, and representativeness are the principal Data Quality Indicators (DQIs) that provide qualitative and quantitative descriptions used in interpreting the degree of acceptability of data. Establishing acceptance criteria for these DQIs sets quantitative goals for the quality of data generated in the measurement process. Of the six principal DQIs, precision, bias, and sensitivity are the quantitative measures, representativeness and comparability are qualitative measures, and completeness is a combination of both qualitative and quantitative measures. The specific requirements of these six DQIs are established before data collection commences. The goal is to locate and eliminate (or minimize) bias, so the data collected show the true conditions of the area being sampled. This includes consideration of siting criteria, spatial scales, monitoring objectives, climatic changes, source configurations, and the duration of the study. Accuracy is a combined metric that represents the closeness of an individual measurement, or the average of a number of measurements, to the true value. Components of accuracy are random error, represented by the metric precision, and systematic error, represented by the metric bias. These error components result from sampling and analytical operations. The SCHD AMB uses high sensitivity equipment for NCore trace-level precursor gas data collection. There are three mass flow controllers in the gas dilution calibrator that can generate very low gas concentrations. The ranges of the three mass flow controllers are: 0-10 SLPM, 0-100 SCCM, and 0-20 SCCM. Each of these mass flow controllers in the calibrator is verified quarterly against NIST-traceable flow meters certified yearly by Mesa Labs. The preventative maintenance for zero air units includes replacing the zero air generator’s filters and scrubbers annually or more often if needed and cleaning or checking the tubing, as necessary. Zero checks are performed daily for those instruments that have nightly checks or weekly for those instruments that do not have nightly checks. If the zero reading is beyond the acceptance criteria provided in the MQO Tables 7-1 thru 7-4, maintenance procedures will be performed to correct the problem. For the zero air unit, this may include checking the power supply, checking for leaks, checking the pressure regulator setting, or checking for any loose connections. If the problem still exists, the manufacturer may need to be contacted. At this time, the SCHD AMB has not yet performed method detection limit (MDL) studies of precursor gas analyzers operated at the NCore site as stated in the NCore TAD and


has relied on the manufacturers’ MDLs. Moving forward, the SCHD AMB will look into implementing an MDL study for such analyzers. The written procedures and methodologies in this QAPP for operating air monitoring instrumentation and handling data must be adhered to by all individuals to assure quality data for purposes of Shelby County’s air quality designations with regards to attainment of the NAAQS. EPA-approved FRMs are the designated methodologies and basis for operating pollutant monitoring equipment, although FEMs may be used as well; however, the NOy monitor is not a designated FRM or FEM.

7.1 Data Quality Objectives

This section provides a description of the data quality objectives (DQOs) for Shelby County’s Ambient Air Monitoring Program. DQOs are qualitative and quantitative statements that:

Clarify the intended use of the data

Define the type of data needed

Specify the tolerable limits on the probability of making a decision error due to uncertainty of data

The valid data recovery objective for the SCHD AMB is ≥75% per calendar quarter for all parameters. Measurement uncertainty is controlled through daily data reviews via daily summary reports from the data management system AirVision, weekly Technical Specialist site visits, nightly or weekly zero/span and 1-point QC checks, quarterly multipoint QC checks, monthly/annual maintenance, and monthly data validation. Achieving a ≥75% collection objective allows users to be confident when comparing collected data, for instance ozone, to other nearby monitoring stations which use the same instrumentation and same data validation procedures for the same period of time.

7.1.1 Intended Use of Data The data collected in the SCHD AMB monitoring network will be used to:

Establish a historical baseline concentration of air pollutants

Monitor the current dynamic concentrations of NAAQS pollutants

Evaluate compliance with the NAAQS

Monitor progress made toward meeting ambient air quality standards

Support daily forecasting efforts, including activating burn bans when high levels of ozone are observed (i.e., AQI color orange or higher) in accordance with Tennessee state laws

Provide data upon which long-term control strategies can be reliably developed


Observe pollution trends throughout Shelby County, as well as throughout the region and nation and

Provide a database for researching and evaluating effects of air pollutants

7.1.2 Type of Data Needed

The type of data needed is determined by its intended use. Because the primary use of the SCHD AMB monitoring data is for comparison to the NAAQS, data must be collected in accordance with 40 CFR Parts 50, 53, and 58 requirements, and be of such quality that decision-makers can make comparisons to the NAAQS with confidence and certainty. The monitoring data compiled by the SCHD AMB is a combination of criteria pollutant, non-criteria pollutant, and meteorological data including: trace-level carbon monoxide (CO), trace-level nitrogen dioxide (NO2), trace-level nitric oxide (NO), trace-level oxides of nitrogen (NOx), trace-level total reactive oxides of nitrogen (NOy), ozone (O3), particulate matter (PM2.5, low-volume PM10, PM10-2.5, chemical speciation), trace-level sulfur dioxide (SO2) and meteorological data (ambient temperature, barometric pressure, relative humidity, wind direction and wind speed). 40 CFR 58.16 specifies the data reporting requirements that the SCHD AMB will follow, and the appendices to 40 CFR Part 50 explain the data handling conventions and computations necessary for determining whether the NAAQS are met for each criteria pollutant. The criteria pollutant data will be collected for comparison to the NAAQS using hourly concentration data (with each hour considered valid if at least 45 valid 1-minute readings have been obtained), 5-minute data (SO2) and 24-hour particulate samples. For each of these pollutants, quarterly data capture will need to be ≥75% completeness. The collection of precision and bias data is also required. In addition to these requirements, the data needed for the SCHD AMB monitoring program will meet the following principal quality objectives:

All data should be traceable to a National Institute of Standards and Technology (NIST) primary standard.

All data shall be of a known and documented quality. The level of quality required for each specific monitoring project shall be established during the initial planning stages of the project and will depend upon the data’s intended use. Two major requirements used to define quality are precision and bias.

All data shall be comparable. This means all data shall be produced in a similar and scientific manner. The use of the standard methodologies for sampling, calibration, auditing, etc. found in the QAPP should achieve this goal.

All data shall be representative of the parameters being measured with respect to time, location, and the conditions from which the data are obtained. The use of the standard methodologies contained in the QAPP should ensure that the data generated are representative.


The QAPP and its associated SOPs must be dynamic to continue to achieve its stated goals as techniques, systems, concepts, and project goals change.

The following subsections provide more detail regarding the specifications on the types of data needed in order to compare the SCHD AMB design values to the NAAQS (excluding NOy and meteorology).

7.1.2.1 Carbon Monoxide

Keep each hourly data point (at least 45 valid minutes of the hourly data is needed) with at least 3 decimal places in units of ppm, with additional digits to the right truncated with no further rounding.

Calculate 24 hourly average values for a day and determine the maximum. Daily maximum 1-hour values are not rounded.

Calculate average values for every rolling 8-hour period

An 8-hour average shall be considered valid if at least 6 of the hourly averages for the 8-hour period are available

If the 1-hour value does not exceed 35 ppm, the NAAQS has been achieved

If the 8-hour value does not exceed 9 ppm, the NAAQS has been achieved Specific information on CO NAAQS calculations is found in 40 CFR 50.8.

7.1.2.2 Nitrogen Dioxide

Keep each hourly data point (at least 45 valid minutes of the hourly data is needed) with at least one decimal place in units of ppb, with additional digits to the right truncated with no further rounding.

Calculate 24 hourly average values for a day and determine the maximum. Daily maximum 1-hour values are not rounded.

The 1-hour design value (DV) is the mean of the three consecutive annual 98th percentile daily maximum values, rounded to the nearest whole number.

When the data for a site and year meet the data completeness requirements found in 40 CFR Part 50, Appendix S, Section 3.1(b) or if the EPA Administrator exercises the discretionary authority in 40 CFR Part 50, Appendix S, Section 3.1(c), the annual mean (annual design value) is simply the arithmetic average of all of the reported 1-hour averages rounded to the nearest whole number.

Specific information on NO2 NAAQS calculations is found in 40 CFR Part 50, Appendix S.


7.1.2.3 Ozone Keep each hourly data point (at least 45 valid minutes of the hourly data is

needed) with at least three decimal places in units of ppm, with additional digits to the right truncated.

Calculate average values for every rolling 8-hour period of the day.

An 8-hour average shall be considered valid if at least 6 of the hourly concentrations for the 8-hour period are available.

Determine the highest 8-hour average from each day (there might be some 8-hour averages that overlap through midnight but it’s unlikely).

Daily maximum 8-hour average O3 concentrations are determined for each day with ambient O3 monitoring data. The daily maximum 8-hour average O3 concentrations for a given day is the highest of the 17 consecutive 8-hour averages beginning with the 8-hour period from 7:00 a.m. to 3:00 p.m. and ending with the 8-hour period from 11:00 p.m. to 7:00 a.m. the following day (i.e., the 8-hour averages for 7:00 a.m. to 11:00 p.m.).

A daily maximum 8-hour average O3 concentration shall be considered valid if valid 8-hour averages are available for at least 13 of the 17 consecutive 8-hour periods starting from 7:00 a.m. to 11:00 p.m.

The highest 8-hour averages in each year are ranked, and the fourth-highest value is used in each year.

The 4th-highest values in 3 consecutive years are averaged.

The resulting design value is compared with the standards.

Specific information on the O3 NAAQS calculation, as well as incomplete hours and days, is found in 40 CFR Part 50, Appendices I, P, and U.

7.1.2.4 Particulate Matter (PM10) Specific information on PM10 NAAQS calculations is found in 40 CFR Part 50, Appendix K. The CFR appendix explains the computations necessary for analyzing PM10 data to determine attainment of the 24-hour standard specified in 40 CFR 50.6, using the reference method based on 40 CFR Part 50, Appendix J, or a designated equivalent method per 40 CFR Part 53. In accordance with Appendix K, a PM10 exceedance means a daily value that is above the level of the 24-hour standard after rounding to the nearest 10 µg/m3 (i.e., values ending in 5 or greater are rounded up). The information in Appendix K is based on high-volume sampling. In the SCHD AMB network, the PM10 samplers are FEMs which collect low-volume, filter-based or continuous (hourly) PM10 data. Therefore, the SCHD AMB will utilize the protocols of the low-volume PM2.5 method found in 40 CFR Part 50, Appendix L, for general guidance, which follows. As an alternative method when the continuous PM10 sampler operated at the Alabama Ave. site is inoperable for an extended period of time and to minimize the amount of data loss, the low-volume, filter-based PM10 sampler will be


utilized. IML will perform the lab analysis of the filters according to their QAPP. The SCHD AMB will utilize the Standard Operating Procedure for PM2.5 and PM10 (low- volume) document and the MQO table (See Table 7-7) in operating and validating the samples collected by the low-volume, filter-based PM10 samplers. Sample data collected by the low-volume, filter-based PM10 sampler operated at the Alabama Ave. site while the continuous sampler is inoperable will be reported to AQS in standard temperature and pressure for NAAQS comparisons. For PM10 NAAQS-comparison purposes, the continuous PM10 data collected at the Alabama Ave. site is reported at standard temperature and pressure. The filter-based, low-volume PM10 data collected at the Shelby Farms NCore site is reported at local ambient conditions for PM10-2.5 coarse samples as well as standard temperature and pressure for NAAQS comparison.

7.1.2.5 Particulate Matter (PM2.5)

For continuous PM2.5 sampling, keep each hourly data point (at least 45 valid minutes of the hourly data is needed) with at least one decimal place in units of µg/m3 with additional digits to the right of the tenths decimal place truncated.

For continuous PM2.5 sampling, calculate a 24-hour period in a day from midnight to midnight (local standard time) for the daily average.

A 24-hour average concentration shall be considered valid if at least 75 percent of the hourly averages (i.e., 18 hourly values) for the 24-hour period are available for continuous PM2.5 sampling.

Twenty-four hour periods with seven or more missing hours shall also be considered valid if, after substituting zero for all missing hourly concentrations, the resulting 24-hour average daily value is greater than the level of the 24-hour PM2.5 NAAQS.

Twenty-four hourly average PM2.5 mass concentrations that are averaged in AQS from hourly values will be truncated to one decimal place, consistent with the data handling procedure for the reported hourly (and also 24-hour filter-based) data.

For 24-hour filter-based samples, the sampler must have operated for 23 to 25 hours or the day will not be valid (unless a sample with less than 23 hours of run time has a concentration that exceeds the NAAQS).

The 3-year average of PM2.5 annual mean mass concentrations for each eligible monitoring site is referred to as the “annual PM2.5 NAAQS DV” and compared to the annual standards.

The 3-year average of annual 98th percentile 24-hour average PM2.5 mass concentration values recorded at each eligible monitoring site is referred to as the “24-hour (or daily) PM2.5 NAAQS DV” and compared to the daily standards.


Specific information on the PM2.5 NAAQS calculations is found in 40 CFR Part 50, Appendix N.

7.1.2.6 Sulfur Dioxide Keep each hourly data point (at least 45 valid minutes of the hourly data is

needed) with at least one decimal place in units of ppb, with additional digits to the right truncated with no further rounding.

Calculate 24 hourly average values for each day and determine the maximum. Daily maximum 1-hour values (and therefore the 99th percentile of those daily values) are not rounded.

The 1-hour design value, which is the mean of three consecutive annual 99th percentile daily maximum values, rounded to the nearest whole number, is used to compare to the primary standard.

The level of the 3-hour secondary standard is 0.5 parts per million (ppm), not to be exceeded more than once per calendar year. The 3-hour averages shall be determined from successive non-overlapping 3-hour blocks starting at midnight each calendar day and shall be rounded to 1 decimal place (fractional parts equal to or greater than 0.05 ppm shall be rounded up).

To demonstrate attainment, the second-highest 3-hour average must be based upon hourly data that are at least 75 percent complete in each calendar quarter. A 3-hour block average shall be considered valid only if all three hourly averages for the 3-hour period are available. If only one or two hourly averages are available, but the 3-hour average would exceed the level of the standard when zeros are substituted for the missing values, subject to the rounding rule of the previous bullet, then this shall be considered a valid 3-hour average. In all cases, the 3-hour block average shall be completed as the sum of the hourly averages divided by 3.

Specific information on SO2 NAAQS calculations is found in 40 CFR Part 50, Appendix T and 40 CFR 50.5.

7.1.2.7 Total Reactive Oxides of Nitrogen

Keep each hourly data point (at least 45 valid minutes of the hourly data is needed) with at least one decimal place in units of ppb, with additional digits to the right truncated with no further rounding

7.1.2.8 Ambient Temperature

Keep each hourly data point (at least 45 valid minutes of the hourly data is needed) with at least one decimal place in units of degrees Fahrenheit, with additional digits to the right truncated with no further rounding


7.1.2.9 Barometric Pressure Keep each hourly data point (at least 45 valid minutes of the hourly data is

needed) with at least one decimal place in units of millibars, with additional digits to the right truncated with no further rounding

7.1.2.10 Relative Humidity Keep each hourly data point (at least 45 valid minutes of the hourly data is

needed) with whole digits in units of percent

7.1.2.11 Wind Direction Keep each hourly data point (at least 45 valid minutes of the hourly data is

needed) with whole digits in degrees

7.1.2.12 Wind Speed

Keep each hourly data point (at least 45 valid minutes of the hourly data is needed) with at least one decimal place in units of knots, with additional digits to the right truncated with no further rounding

7.1.3 Tolerance Error Limits

The DQO process defines tolerable limits on the probability of making a decision error due to uncertainty in the data; that is, limits on the probability of measuring a false positive or false negative error. With regards to air quality data, a false positive error occurs when data indicates that an emissions limit has been exceeded when in fact, due to random deviations in the data, it has not been exceeded. Alternatively, a false negative error occurs when data indicate that no emissions limit has been exceeded when in fact, due to random deviations in the data, it has been exceeded. Utilizing the formal DQO process, the EPA established the tolerable error limits for ambient air monitoring precision and bias data in order to reduce the probability of decision errors. With the exception of PM10 and CO, 40 CFR Part 58, Appendix A, Section 2.3.1 sets the DQOs for the criteria pollutants measured within the SCHD AMB network, which are as follows:

Measurement Uncertainty for Automated and Manual PM2.5 Methods – The goal for acceptable measurement uncertainty is defined for precision as an upper 90% confidence limit for the coefficient of variation of < 10% and < ±10% for total bias.


Measurement Uncertainty for Automated O3 Methods – The goal for acceptable measurement uncertainty is defined for precision as an upper 90% confidence limit for the coefficient of variation of < 7% and for bias as an upper 95% confidence limit for the absolute bias of < 7%.

Measurement Uncertainty for NO2 and NOY – The goal for acceptable measurement uncertainty is defined for precision as an upper 90% confidence limit for the coefficient of variation of <15% and for bias as an upper 95% confidence limit for the absolute bias of < 15%.

Measurement Uncertainty for SO2 – The goal for acceptable measurement uncertainty for precision is defined as an upper 90% confidence limit for the coefficient of variation of <10% and for bias as an upper 95% confidence limit for the absolute bias of < 10%.

Measurement Uncertainty for CO – The goal for acceptable measurement uncertainty for precision is defined as an upper 90% confidence limit for the coefficient of variation of <10% and for bias as an upper 95% confidence limit for the absolute bias of < 10%.

EPA has not completed a formal 7-step DQO process for CO at this time; however, the EPA has provided DQOs for CO in the Quality Assurance Handbook for Air Pollution Measurement Systems, Volume II. The SCHD AMB doesn’t have a DQO for PM10. We will adhere to the MQOs in Tables 7-7 and 7-8 and with that the SCHD AMB will have confidence that the uncertainty in the data set is low enough for the data to be used for decision making. The SCHD AMB formally adopts EPA’s DQOs (listed above) and establishes DQOs for NOy precision and bias data using the EPA’s DQOs for NO2 precision and bias data.

7.2 Measurement Quality Objectives

As air pollution and meteorological measurement systems increase in both cost and complexity, it becomes essential that the SCHD’s Ambient Air Monitoring Program has a methodology that will, in a cost-effective manner, increase the completeness and precision and decrease the bias of the data generated. Once a DQO is established, the quality of the data must be evaluated and controlled to ensure that it is maintained within the established acceptance criteria. Measurement quality objectives (MQOs) are designed to evaluate and control various phases (sampling, preparation, analysis) of the measurement process to ensure that total measurement uncertainty is within the range prescribed by the DQOs. The MQOs for the SCHD’s Ambient Air Monitoring Program will be defined in terms of the following DQIs, including accuracy and representativeness, which are defined elsewhere in Section 7:


Precision – Precision is a measure of agreement between two replicate measurements of the same property, under prescribed similar conditions. This agreement is calculated as either the range or as the standard deviation. (U.S. EPA QA/G-5, Appendix B). This is the random component of error.

Bias – Bias is the systematic or persistent distortion of a measurement process that causes errors in one direction. (U.S. EPA QA/G-5, Appendix B). Bias is determined by estimating the positive and negative deviation from the true value as a percentage of the true value.

Comparability – Comparability is the qualitative term that expresses the confidence that two data sets can contribute to a common analysis and interpolation. Comparability must be carefully evaluated to establish whether two data sets can be considered equivalent in regard to the measurement of a specific variable or groups of variables. (U.S. EPA QA/G-5, Appendix B)

Completeness – Completeness is a metric quantifying the amount of valid data obtained from a measurement system compared to the amount that was expected to be obtained under correct, normal conditions. Completeness can be expressed as a ratio or a percentage. Data completeness requirements are included in the reference methods (40 CFR Part 50).

Sensitivity – Sensitivity is the capability of a method or instrument to discriminate between measurement responses representing different levels of the variable of interest. (U.S. EPA QA/G-5, Appendix B)

For each of these attributes, acceptance criteria have been developed using various parts of 40 CFR Parts 50, 53, and 58 and the EPA-supplied guidance documents. Specifically, the MQOs for the pollutants and meteorological parameters have been compiled into “validation templates” found in the EPA Quality Assurance Handbook for Air Pollution Measurement Systems, Volume II (EPA-454/B-17-001) (i.e., QA Handbook) and Volume IV (EPA-454/B-08-002). The validation templates have been reproduced here and are included as Tables 7-1 thru 7-9. The SCHD AMB adopts these tables with minor revisions and establishes them as the MQOs for the Branch’s Ambient Air Monitoring Program. More detailed descriptions of these MQOs and how they will be used to control and assess measurement uncertainty are described in other elements of the QAPP, as well as in the SOPs for each individual pollutant (see Table 11-1). As described in the QA Handbook and implemented here, for each pollutant and meteorological parameter listed in the tables that follow, three validation criteria are listed: critical, operational, and systematic. The tables discriminate between criteria that must be met to ensure the quality of the data (i.e., critical criteria), criteria that indicate that there may be issues with the quality of the data and further investigation is warranted before making a determination about the validity of the sample or samples (i.e., operational criteria), and criteria that indicate a potentially systematic problem with the environmental data collection activity, that may impact the ability to make decisions with the data (i.e., systematic criteria). For each criterion, the tables include:


(1) the requirement, (2) the frequency with which compliance is to be evaluated, (3) the acceptance criteria, and (4) information where the requirement can be found or additional guidance on the requirement. The SCHD AMB’s implementation of these tables – how they will be used to validate data and drive data quality decision-making – will be described in more detail in Section 23 of this QAPP.

SCHD QAPP Revision No: 0

Revision Date: 01/31/2019 of 156

Table 7-1. O3 Validation Template 1) Requirement (O3) 2) Frequency 3) Acceptance Criteria Information /Action

CRITICAL CRITERIA-OZONE

Monitor

N/A Meets requirements listed in FRM/FEM

designation

1) 40 CFR Part 58 App C Sec. 2.1 2) NA 3) 40 CFR Part 53 & FRM/FEM method list

One Point QC Check

Single analyzer

Every 14 days

The SCHD AMB’s goal is to

perform nightly and weekly checks.

< ±7.1% (percent difference) or < ±1.5 ppb

difference whichever is greater

1 and 2) 40 CFR Part 58 App A Sec. 3.1 3) Recommendation based on DQO in 40 CFR Part 58

App A Sec. 2.3.1.2. QC Check Conc. range 0.005 - 0.08 ppm and 05/05/2016 Technical Note on AMTIC

Zero/span check Every 14 days


perform nightly and weekly checks.

Zero drift < ± 3.1 ppb (24 hr.) < ± 5.1 ppb (>24hr-14 day)

Span drift < ± 7.1 %

1 and 2) QA Handbook Volume 2 Sec. 12.3 3) Recommendation and related to DQO

OPERATIONAL CRITERIA -OZONE

Shelter Temperature Range

Daily

(hourly values)

20.0 to 30.0o C. (Hourly avg.)

or

per manufacturers specifications if designated

to a wider temperature range

1, 2 and 3) QA Handbook Volume 2 Sec. 7.2.2

FRM/FEM list found on AMTIC provides temp. range

for given instrument.

FRM/FEM monitor testing is required at 20-30o C range

per 40 CFR Part 53.32

Shelter Temperature Control Daily (hourly values) < 2.1o C SD over 24 hours 1, 2 and 3) QA Handbook Volume 2 Sec. 7.2.2

Shelter Temperature Device Check

Every 182 days and 2/calendar year The SCHD AMB’s goal is to

perform monthly checks.

< ± 2.1o C of standard 1, 2 and 3) QA Handbook Volume 2 Sec. 7.2.2

Annual Performance

Evaluation Single analyzer

Every site every 365 days and

1/calendar year within period of

monitor operation


perform quarterly performance

evaluations.

Percent difference of audit levels 3-10

< ±15.1%

Audit levels 1&2 < ± 1.5 ppb difference or

< ± 15.1%, whichever is greater

1 and 2) 40 CFR Part 58 App A Sec. 3.1.2 3) Recommendation- 3 audit concentrations not including

zero. AMTIC guidance 2/17/2011

AMTIC Technical Memo

Federal Audits (NPAP) 20% of sites audited in calendar

year

Audit levels 1&2 < ± 1.5 ppb difference all

other levels percent difference < ± 10.1%

1 and 2) 40 CFR Part 58 App A Sec. 3.1.3

3) NPAP QAPP/SOP

Verification/Calibration

Upon receipt/adjustment/repair/

installation/moving and repair and

recalibration of standard of higher

level

Every 365 days and 1/calendar year if continuous zero/span performed

daily

The SCHD AMB’s goal is to perform

quarterly multi-point verifications.

All points < ± 2.1 % or ≤ ±1.5 ppb difference

of best-fit straight line whichever is greater

and Slope 1 ± .05

Verification: all points < ± 7.1%

1) 40 CFR Part 50 App D

2) Recommendation 3) 40 CFR Part 50 App D Sec 4.5.5.6

Multi-point calibration (0 and 4 upscale points)

Slope criteria is a recommended goal.

Zero Air/Zero Air Check

Every 365 days and 1/calendar year

Concentrations below LDL 1) 40 CFR Part 50 App D Sec. 4.4.1 2 and 3) Recommendation. Preventative Maintenance includes zero checks. Zero points are done during ZSP to verify.

Ozone Level 2 Standard



1) Requirement (O3) 2) Frequency 3) Acceptance Criteria Information /Action

Certification/recertification to

Standard Reference

Photometer (Level 1)


single point difference < ± 3.1%

1) 40 CFR Part 50 App D Sec. 4.5 2 and 3) Transfer Standard Guidance EPA-454/B-13-004

Level 2 standard (formerly called primary standard) usually transported to EPA Regions SRP for comparison

Level 2 and Greater Transfer

Standard Precision


Standard Deviation less than 0.005 ppm or

3.0% whichever is greater

1) 40 CFR Part 50 Appendix D Sec. 4.3.1

2) Recommendation, part of reverification 3) 40 CFR Part 50 Appendix D Sec. 4.3.1

(if recertified via a transfer

standard) Every 365 days and 1/calendar year

Regression slopes = 1.00 ± 0.03 and two

intercepts are 0 ± 3 ppb

1, 2 and 3) Transfer Standard Guidance EPA-454/B-13-004

Ozone Transfer standard

(Level 3 and greater)

Qualification Upon receipt of transfer standard < ± 4.1% or < ± 4 ppb (whichever greater) 1, 2 and 3) Transfer Standard Guidance EPA-454/B-13-004

Certification After qualification and upon

receipt/adjustment/repair

RSD of six slopes ≤ 3.7%

Std. Dev. of 6 intercepts ≤ 1.5


Recertification to higher

level standard

Beginning and end of O3 season or

every 182 days and 2/calendar year

whichever less


perform

certifications/recertifications

quarterly.

New slope = ± 0.05 of previous and RSD of

six slopes ≤ 3.7%

Standard Deviation of 6 intercepts ≤ 1.5


Detection (FEM/FRMs) Noise and Lower Detectable Limits (LDL) are part of the FEM/FRM requirements. It is recommended that monitoring organizations perform the LDL test to

minimally confirm and establish the LDL of their monitor. Performing the LDL test will provide the noise information.

Noise

Every 365 days and 1/calendar year ≤ 0.0025 ppm (standard range)

≤ 0.001 ppm (lower range)

1) 40 CFR Part 53.23 (b) (definition & procedure) 2) Recommendation-info can be obtained from LDL 3) 40 CFR Part 53 Table B-1

Lower detectable limit

Every 365 days and 1/calendar year ≤ 0.005 ppm (standard range)


1) 40 CFR Part 53.23 (c) (definition & procedure) 2) Recommendation 3) 40 CFR Part 53 Table B-1

SYSTEMATIC CRITERIA-OZONE Standard Reporting Units All data ppm (final units in AQS) 1, 2 and 3) 40 CFR Part 50 App U Sec. 3(a)

Rounding convention for design

value calculation

All routine concentration data 3 places after decimal with digits to right

truncated

1, 2 and 3) 40 CFR Part 50 App U Sec. 3(a) The rounding

convention is for averaging values for comparison to NAAQS not for reporting individual hourly values.

Completeness (seasonal)

3-Year Comparison ≥ 90% (avg.) daily max available in ozone

season with min of 75% in any one year.

1,2,3) 40 CFR Part 50 App U Sec 4(b)

8- hour average at least 6 of the hourly concentrations for the

8-hour period are available

1) 40 CFR Part 50 App U 2 and 3) 40 CFR Part 50 App U Sec. 3(b)

Valid Daily Max

valid 8-hour averages are available for at

least 13 of the 17 consecutive 8-hour periods

starting from 7:00 a.m. to 11:00 p.m.

local standard time

1) 40 CFR Part 50 App U 2,3) 40 CFR Part 50 App U Sec. 3(d)



1) Requirements (O3) 2) Frequency 3) Acceptance Criteria

Information /Action

Sample Residence Time

Verification Every 365 days and

1/calendar year ≤ 20 Seconds 1) 40 CFR Part 58 App E, Sec. 9 (c)

2) Recommendation

3) 40 CFR Part 58 App E, Sec. 9 (c)

Sample Probe, Inlet, Sampling

train

All sites

Borosilicate glass (e.g., Pyrex®) or Teflon®

1) 40 CFR Part 58 App E, Sec. 9 (a) 2) Recommendation 3) 40 CFR Part 58 App E, Sec. 9 (a)

FEP and PFA have been accepted as an equivalent material to Teflon. Replacement is suggested as 1/year and more frequent if pollutant load or contamination dictate

Siting


Meets siting criteria or waiver documented

1) 40 CFR Part 58 App E, Sec. 2-6

2) Recommendation 3) 40 CFR Part 58 App E, Sec. 2-6

EPA Standard Ozone Reference

Photometer (SRP)

Recertification (Level 1)


Regression slope = 1.00 ± 0.01

and intercept < 3 ppb


This is usually at a Regional Office and is compared

against the traveling SRP

Precision (using 1-point QC

checks)

Calculated annually and as

appropriate for design value estimates

90% CL CV < 7.1%

1) 40 CFR Part 58 App A 2.3.1.2 & 3.1.1

2) 40 CFR Part 58 App A Sec. 4 (b) 3) 40 CFR Part 58 App A Sec. 4.1.2

Bias (using 1-point QC checks)


appropriate for design value estimates

95% CL < ± 7.1%

1) 40 CFR Part 58 App A 2.3.1.2 & 3.1.1




Table 7-2. CO Validation Template 1) Requirement (CO) 2) Frequency 3) Acceptance Criteria Information /Action

CRITICAL CRITERIA-CO

Sampler/Monitor

N/A

Meets requirements listed in FRM/FEM

designation

1) 40 CFR Part 58 App C Sec. 2.1

2) NA

3) 40 CFR Part 53 & FRM/FEM method list

One Point QC Check

Single analyzer

Every 14 days


perform nightly (i.e. Near-Road) and

weekly checks.

< ± 10.1% (percent difference) 1 and 2) 40 CFR Part 58 App A Sec. 3.1.1

3) Recommendation based on DQO in 40 CFR Part 58

App A Sec. 2.3.1. QC Check Conc. range 0.5 – 5 ppm

Zero/span check

Every 14 days


perform nightly (i.e. Near-Road) and

weekly checks.

Zero drift < ± 0.41 ppm (24 hr.)

< ± 0.61 ppm (> 24hr-14

day) Span drift < ±10.1%

1 and 2) QA Handbook Volume 2 Sec. 12.3

3) Recommendation

OPERATIONAL CRITERIA-CO

Shelter Temperature range

Daily

(hourly values)


or

per manufacturers specifications if designated to a

wider temperature range


FRM/FEM list found on AMTIC provides temp. range

for given instrument. FRM/FEM monitor testing is

required at 20-30 o C range per 40 CFR Part 53.32







Annual Performance

Evaluation Single Analyzer

Every site every 365 days and 1/

calendar year


perform quarterly

performance

evaluations.

Percent difference of audit levels 3-10 < ±15.1%

Audit levels 1&2 < ± 0.031 ppm difference or

< ± 15.1%, whichever is greater

1 and 2) 40 CFR Part 58 App A Sec. 3.1.2

3) Recommendation- 3 audit concentrations not

including zero. AMTIC Technical Memo

Federal Audits (NPAP) 20% of sites audited in a calendar

year

Audit levels 1&2 < ± 0.031 ppm difference all


1 and 2) 40 CFR Part 58 App A Sec. 3.1.3 3) NPAP QAPP/SOP



1) Requirement (CO) 2) Frequency 3) Acceptance Criteria Information /Action



installation/moving


if continuous zero/span performed

daily (i.e. Near-Road)

Every 182 days and 2/calendar year (i.e. NCore)

The goal of the SCHD is to perform


All points < ± 2.1 % or ≤ ± 0.03 ppm difference

of best-fit straight line. whichever is greater

and Slope 1 ± .05

1) 40 CFR Part 50 Appendix C Sec. 4

2 and 3) Recommendation

See details about CO2 sensitive instruments Multi-point

calibration (0 and 4 upscale points)


Gaseous Standards

All gas cylinders

NIST Traceable

(e.g., EPA Protocol Gas)

1) 40 CFR Part 50 Appendix C Sec. 4.3.1 2) NA Green Book

3) 40 CFR Part 50 Appendix C Sec. 4.3.1 See details

about CO2 sensitive instruments

Gas producer used must participate in EPA Ambient Air

Protocol Gas Verification Program

40 CFR Part 58 App A Sec. 2.6.1



< 0.1 ppm CO

1) 40 CFR Part 50 App C Sec. 4.3.2

2) Recommendation 3) 40 CFR Part 50 App C Sec. 4.3.2

Gas Dilution Systems


or after failure of 1 point QC check or

performance evaluation


perform quarterly

calibrator MFC

certifications.

Accuracy < ± 2.1 %

1, 2 and 3) Recommendation based on SO2 requirement in 40 CFR Part 50 App A-1 Sec. 4.1.2

Detection (FEM/FRMs) Noise and Lower Detectable Limits (LDL) are part of the FEM/FRM requirements. It is recommended that monitoring organizations perform the LDL test to minimally confirm and establish the LDL of their monitor. Performing the LDL test will provide the noise information.

Noise

Every 365 days and 1/ calendar year ≤ 0.2 ppm (standard range)


1) 40 CFR Part 53.23 (b) (definition & procedure)

2) Recommendation- info can be obtained from LDL 3) 40 CFR Part 53 Table B-1

Lower detectable level

Every 365 days and 1/ calendar year ≤ 0.4 ppm (standard range)


1) 40 CFR Part 53.23 (c) (definition & procedure)

2) Recommendation 3) 40 CFR Part 53 Table B-1

SYSTEMATIC CRITERIA-CO Standard Reporting Units All data ppm (final units in AQS) 1, 2 and 3) 40 CFR Part 50.8 (a)


value calculation

All routine concentration data

1 decimal place

1, 2 and 3) 40 CFR Part 50.8 (d) The rounding

convention is for averaging values for comparison to

NAAQS not for reporting individual hourly values.



1) Requirement (CO) 2) Frequency 3) Acceptance Criteria Information /Action

Completeness

8-hour standard

75% of hourly averages for the 8-hour period

1) 40 CFR Part 50.8(c)

2) 40 CFR Part 50.8(a)(1) 3) 40 CFR Part 50.8(c)


Verification

Every 365 days and 1/ calendar year

< 20 Seconds 1, 2, and 3) Recommendation. CO not a reactive gas but

suggest following same methods as other gaseous

criteria pollutants.


train

All Sites

Borosilicate glass (e.g., Pyrex®

) or Teflon®

1, 2, and 3) Recommendation. CO not a reactive gas

but suggest following same methods as other gaseous

criteria pollutants. FEP and PFA have been accepted as

an equivalent material to Teflon. Replacement is

suggested as 1/year and more frequent if pollutant load dictate.

Siting





Precision (using 1-point QC checks)

Calculated annually and as appropriate for design value

estimates

90% CL CV < 10.1%

1) 40 CFR part 58 App A Sec. 3.1.1 2) 40 CFR part 58 App A Sec. 4 (b) 3) 40 CFR part 58 App A Sec. 4.1.2

Bias (using 1-point QC checks)


appropriate for design value

estimates

95% CL < ± 10.1%

1) 40 CFR Part 58 App A Sec. 3.1.1




Table 7-3. NO2, NOx, NO, NOy Validation Template 1) Requirement (NO2) 2) Frequency 3) Acceptance Criteria Information /Action

CRITICAL CRITERIA- NO2

Sampler/Monitor

N/A Meets requirements listed in FRM/FEM

designation


One Point QC Check

Single analyzer

Every 14 days


nightly and weekly checks.

< ± 15.1% (percent difference) or < ± 1.5

ppb difference whichever is greater

1 and 2) 40 CFR Part 58 App A Sec. 3.1.1 3) Recommendation based on DQO in 40 CFR Part 58

App A Sec. 2.3.1.4 QC Check Conc. range 0.005 -

0.08 ppm and 05/05/2016 Technical Note on AMTIC

Zero/span check

Every 14 days


nightly and weekly checks.

Zero drift < ± 3.1 ppb (24 hr.)

< ± 5.1 ppb (>24hr-14 day)



Converter Efficiency

During multi-point calibrations, span and

audit

Every 14 days

(≥ 96%)

96% – 104.1%

1) 40 CFR Part 50 App F Sec. 1.5.10 and 2.4.10 2) Recommendation

3) 40 CFR Part 50 App F Sec. 1.5.10 and 2.4.10

Regulation states ≥ 96%, 96 – 104.1% is a recommended goal.

OPERATIONAL CRITERIA- NO2


Daily

(hourly values)


or

per manufacturers specifications if designated

to a wider temperature range


Generally, the 20-30.0 o C range will apply but the

most restrictive operable range of the instruments in

the shelter may also be used as guidance. FRM/FEM

list found on AMTIC provides temp. range for given

instrument. FRM/FEM monitor testing is required at 20-30 o C range per 40 CFR Part 53.32





monthly checks.


Annual Performance



1/calendar year

The SCHD AMB’s goal is to have

quarterly performance

evaluations.

Percent difference of audit levels 3-10

< ±15.1% Audit levels 1&2 < ± 1.5 ppb difference or

< ±15.1%, whichever is greater

1) 40 CFR Part 58 App A Sec. 3.1.2

2) 40 CFR Part 58 App A Sec. 3.1.2 3) Recommendation - 3 audit concentrations not




1) Requirement (NO2) 2) Frequency 3) Acceptance Criteria Information /Action

Federal Audits (NPAP)

20% of sites audited in calendar year Audit levels 1&2 < ± 1.5 ppb difference all

other levels percent difference < ± 15.1% 1 & 2) 40 CFR Part 58 App A Sec. 3.1.3

3) NPAP QAPP/SOP



installation/moving

Every 365 days and 1/calendar year if

continuous zero/span performed daily



Instrument residence time ≤ 2 min

Dynamic parameter > 2.75 ppm-min

All points < ± 2.1 % or ≤ ±1.5 ppb difference


and Slope 1 ± .05

1) 40 CFR Part 50 App F



Slope criteria is a recommended goal

Gaseous Standards

All gas cylinders

NIST Traceable

(e.g., EPA Protocol Gas) 50-100 ppm of NO in Nitrogen with < 1 ppm

NO2

1) 40 CFR Part 50 App F Sec. 1.3.1

2) NA Green Book

3) 40 CFR Part 50 App F Sec. 1.3.1. A technical

memo may change the concentration

requirement.

Gas producer used must participate in EPA Ambient

Air Protocol Gas Verification Program 40 CFR Part 58 App A Sec. 2.6.1

Zero Air/ Zero Air Check Every 365 days and 1/calendar year Concentrations below LDL 1) 40 CFR Part 50 App F Sec. 1.3.2 2 and 3) Recommendation

Gas Dilution Systems

Every 365 days and 1/calendar year or

after failure of 1 point QC check or performance evaluation


perform quarterly

calibrator MFC

certifications.

Accuracy < ± 2.1 % 1, 2 and 3) Recommendation based on SO2

requirement in 40 CFR Part 50 App A-1 Sec. 4.1.2

Detection (FEM/FRMs) Noise and Lower Detectable Limits (LDL) are part of the FEM/FRM requirements. It is recommended that monitoring organizations perform the LDL test to

minimally confirm and establish the LDL of their monitor. Performing the LDL test will provide the noise information.

Noise


< 0.005 ppm

1) 40 CFR Part 53.23 (b) (definition & procedure) 2) Recommendation- info can be obtained from LDL 3) 40 CFR Part 53 Table B-1



< 0.01 ppm

1) 40 CFR Part 53.23 (c) (definition & procedure) 2) Recommendation 3) 40 CFR Part 53 Table B-1

SYSTEMATIC CRITERIA- NO2 Standard Reporting Units All data ppb (final units in AQS) 1, 2 and 3) 40 CFR Part 50 App S Sec. 2 (c)

Rounding convention for data

reported to AQ S


1 place after decimal with digits to right

truncated

1, 2 and 3) 40 CFR Part 50 App S Sec. 4.2 (a) The

rounding convention is for averaging values for

comparison to NAAQS not for reporting individual hourly values.



1) Requirement (NO2) 2) Frequency 3) Acceptance Criteria Information /Action

Completeness

Annual Standard ≥ 75% hours in year 1) 40 CFR Part 50 App S Sec. 3.1(b) 2) 40 CFR Part 50 App S Sec. 3.1(a) 3) 40 CFR Part 50 App S Sec. 3.1(b)

1-hour standard

1) 3consecutive calendar years of complete

data

2) 4 quarters complete in each year

3) ≥75% sampling days in quarter

4) ≥ 75% of hours in a day

1) 40 CFR Part 50 App S Sec. 3.2(b)

2) 40 CFR Part 50 App S Sec. 3.2(a)

3) 40 CFR Part 50 App S Sec. 3.2(b)

More details in 40 CFR Part 50 App S


Verification


≤ 20 Seconds


2) Recommendation 3) 40 CFR Part 58 App E, Sec. 9 (c)


train

All sites


1, 2 and 3) 40 CFR Part 58 App E Sec. 9 (a)

FEP and PFA have been accepted as equivalent

material to Teflon. Replacement is

suggested as 1/year and more frequent if pollutant load

or contamination dictate

Siting



1) 40 CFR Part 58 App E, Secs 2-6 2) Recommendation 3) 40 CFR Part 58 App E, Sec. 2-6


checks)

Calculated annually and as appropriate

for design value estimates

90% CL CV < 15.1%

1) 40 CFR Part 58 App A Sec. 2.3.1.4 & 3.1.1


Bias (using 1-point QC checks) Calculated annually and as appropriate


95% CL < ± 15.1%

1) 40 CFR Part 58 App A Sec. 2.3.1.4 & 3.1.1




Table 7-4. SO2 Validation Template 1) Requirement (SO2) 2) Frequency 3) Acceptance Criteria Information /Action

CRITICAL CRITERIA- SO2

Sampler/Monitor N/A Meets requirements listed in FRM/FEM

designation


One Point QC Check

Single analyzer

Every 14 days


perform weekly checks.

< ±10.1% (percent difference) or < ± 1.5 ppb

difference whichever is greater

1 and 2) 40 CFR Part 58 App A Sec. 3.1.1 3) Recommendation based on DQO in 40 CFR Part 58

App A Sec. 2.3.1.5 QC Check Conc. range 0.005 - 0.08

ppm and 05/05/2016 Technical Note on AMTIC

Zero/span check

Every 14 days


perform weekly checks.

Zero drift < ± 3.1 ppb (24 hr.) < ± 5.1 ppb (>24hr-14 day)



OPERATIONAL CRITERIA- SO2


Daily

(hourly values)


or

per manufacturers specifications if designated to

a wider temperature range


Generally, the 20-30.0 o C range will apply but the most

restrictive operable range of the instruments in the

shelter may also be used as guidance. FRM/FEM list

found on AMTIC provides temp. range for given

instrument. FRM/FEM monitor testing is required at 20- 30 o C range per 40 CFR Part 53.32







Annual Performance



1/calendar year


have quarterly

performance

evaluations.

Percent difference of audit levels 3-10 < ± 15.1%

Audit levels 1&2 < ± 1.5 ppb difference or < ± 15.1%, whichever is greater

1 and 2) 40 CFR Part 58 App A Sec. 3.1.2 3) Recommendation - 3 audit concentrations not


Federal Audits (NPAP)

20% of sites audited in calendar year Audit levels 1&2 < ± 1.5 ppb difference all


1&2) 40 CFR Part 58 App A Sec. 3.1.3

3) NPAP QAPP/SOP



1) Requirement (SO2) 2) Frequency 3) Acceptance Criteria Information /Action



installation/moving

Every 182 days and 2/calendar year if

manual zero/span performed biweekly



All points < ± 2.1 % or < ± 1.5 ppb difference


and Slope 1 ± .05

1) 40 CFR Part 50 App A-1 Sec. 4




Gaseous Standards

All gas cylinders

NIST Traceable

(e.g., EPA Protocol Gas)

1) 40 CFR Part 50 App A-1 Sec. 4.1.6.1

2) NA Green Book

3) 40 CFR Part 50 App F Sec. 1.3.1 Producers must participate in Ambient Air Protocol Gas Verification Program 40 CFR Part 58 App A Sec. 2.6.1



Concentrations below LDL < 0.1 ppm aromatic

hydrocarbons

1) 40 CFR Part 50 App A-1 Sec. 4.1.6.2 2) Recommendation 3) Recommendation and 40 CFR Part 50 App A-1

Sec.4.1.6.2

Gas Dilution System

Every 365 days and 1/calendar year or

after failure of 1 point QC check or

performance evaluation


quarterly calibrator MFC certifications.

Accuracy < ± 2.1%

1) 40 CFR Part 50 App A-1 Sec. 4.1.2 2) Recommendation 3) 40 CFR Part 50App A-1 Sec. 4.1.2

Detection (FEM/FRMs) Noise and Lower Detectable Limits (LDL) are part of the FEM/FRM requirements. It is recommended that monitoring organizations perform the LDL test to minimally confirm and establish the LDL of their monitor. Performing the LDL test will provide the noise information.

Noise

Every 365 days and 1/calendar year < 0.001 ppm (standard range)

< 0.0005 ppm (lower range)

1) 40 CFR Part 53.23 (b) (definition & procedure)

2) Recommendation- info can be obtained from LDL 3) 40 CFR Part 53Table B-1


Every 365 days and 1/calendar year < 0.002 ppm (standard range)

< 0.001 ppm (lower range)

1) 40 CFR Part 53.23 (c) (definition & procedure)

2) Recommendation 3) 40 CFR Part 53 Table B-1

SYSTEMATIC CRITERIA- SO2

Standard Reporting Units All data ppb (final units in AQS) 1, 2 and 3) 40 CFR Part 50 App T Sec. 2 (c)


value calculation


1 place after decimal with digits to right

truncated

1, 2 and 3) 40 CFR Part 50 App T Sec. 2 (c) The


comparison to NAAQS not for reporting individual hourly values.

Completeness

1 hour standard

Hour – 75% of hour Day- 75% hourly conc.

Quarter- 75% complete days

Years- 4 complete quarters 5-min value reported only for valid hours

1, 2 and 3) 40 CFR Part 50 App T Sec. 3 (b), (c)

More details in CFR on acceptable completeness.

5-min values or 5-min max value (40 CFR part 58.16(g))

only reported for the valid portion of the hour reported. If the hour is incomplete no 5-min or 5-min max reported.


Verification


< 20 Seconds


2) Recommendation 3) 40 CFR Part 58 App E, Sec. 9 (c)



1) Requirement (SO2)

2) Frequency

3) Acceptance Criteria

Information /Action

Sample Probe, Inlet, Sampling train

All sites


1, 2 and 3) 40 CFR Part 58 App E Sec. 9 (a) FEP and PFA have been accepted as equivalent material

to Teflon. Replacement is suggested as 1/year and more

frequent if pollutant load or contamination dictate

Siting Every 365 days and 1/ calendar year


1) 40 CFR Part 58 App E, Sec. 2-5 2) Recommendation 3) 40 CFR Part 58 App E, Sec. 2-5


checks)

Calculated annually and as appropriate


90% CL CV < 10.1%

1) 40 CFR Part 58 App A Sec. 2.3.1.5 & 3.1.1


Bias (using 1-point QC checks) Calculated annually and as appropriate


95% CL < ±10.1%

1) 40 CFR Part 58 App A Sec. 2.3.1.5 & 3.1.1 2) 40 CFR Part 58 App A Sec. 4 (b) 3) 40 CFR Part 58 App A Sec. 4.1.3



Table 7-5. PM2.5 Filter-Based Local Conditions Validation Template

1) Criteria (PM2.5 LC)

2) Frequency

3) Acceptable Range

Information /Action

CRITICAL CRITERIA- PM2.5 Filter-Based Local Conditions

Field Activities

Sampler/Monitor

NA Meets requirements listed in FRM/FEM/ARM

designation


Filter Holding Times

Pre-sampling all filters ≤ 30 days before sampling 1, 2 and 3) 40 CFR Part 50, App. L Sec. 8.3.5

Sample Recovery all filters ≤ 7 days 9 hours from sample end date

The SCHD AMB’s goal is to retrieve sampled filters

within 96 hours from the sample end date.

1, 2 and 3) 40 CFR Part 50, App. L Sec. 10.10

Sampling Period (including

multiple power failures)

all filters

1380-1500 minutes, or

if value < 1380 and exceedance of NAAQS 1/

midnight to midnight local standard time

1, 2 and 3) 40 CFR Part 50 App L Sec. 3.3 and 40 CFR

Part 50 App N Sec. 1 for the midnight to midnight local

standard time requirement

See details if less than 1380 min sampled

Sampling Instrument

Average Flow Rate every 24 hours of op average within ±5% of 16.67 liters/minute 1, 2 and 3) 40 CFR Part 50 App L Sec. 7.4.3.1

Variability in Flow Rate every 24 hours of op CV ≤ 2% 1, 2 and 3) 40 CFR Part 50, App L Sec. 7.4.3.2

One-point Flow Rate Verification every 30 days each separated

by 14 days


perform weekly

flow verifications.

< ± 4.1% of transfer standard < ± 5.1% of flow rate design value

1, 2 and 3) 40 CFR Part 50, App L, Sec. 9.2.5 and 7.4.3.1 and 40 CFR Part 58, Appendix A Sec. 3.2.1

Design Flow Rate Adjustment After multi-point calibration or

verification < ± 2.1% of design flow rate

1, 2 and 3) 40 CFR Part 50, App. L, Sec. 9.2.6

Individual Flow Rates every 24 hours of op no flow rate excursions > ± 5% for > 5 min. 1/ 1, 2 and 3) 40 CFR Part 50, App. L Sec. 7.4.3.1

Filter Temp Sensor every 24 hours of op no excursions of > 5o C lasting longer than 30

consecutive min

1, 2 and 3) 40 CFR Part 50, App. L Sec. 7.4.11.4

External Leak Check

Before each flow rate verification/calibration and

before and after PM2.5 separator

maintenance

≤ 25 mmHg/min 1) 40 CFR Part 50 App L Sec. 7.4.6.1

2) 40 CFR Part 50 App L Sec. 9.2.3 and Method 2.12

Sec. 7.4.3

3) 40 CFR Part 50, App L Sec. 7.4.6.1



1) Criteria (PM2.5 LC)

2) Frequency

3) Acceptable Range

Information /Action

Internal Leak Check

If failure of external leak check

≤ 140 mmHg/min

1) 40 CFR Part 50, App. L, Sec. 7.4.6.2 2) Method 2.12, Sec. 7.4.4 3) 40 CFR Part 50, App. L, Sec. 7.4.6.2

Laboratory Activities

Post-sampling Weighing

all filters

Protected from exposure to temperatures above

25C from sample retrieval to conditioning

≤ 10 days from sample end date if shipped at

ambient temp, or

≤ 30 days if shipped below avg. ambient (or 4o C or

below for avg. sampling temps < 4o C ) from sample end date

1, 2 and 3) 40 CFR Part 50 App. L Sec. 8.3.6 and App.

L Sec. 10.13.

See technical note on holding time requirements at :

https://www3.epa.gov/ttn/amtic/pmpolgud.html

Filter Visual Defect Check

(unexposed) all filters

Correct type & size and for pinholes, particles or

imperfections


Filter Conditioning Environment

Equilibration all filters 24 hours minimum 1, 2 and 3) 40 CFR Part 50, App. L Sec. 8.2.5

Temp. Range all filters 24-hr mean 20.0-23.0o C 1, 2 and 3) 40 CFR Part 50, App. L Sec. 8.2.1

Temp. Control all filters < 2.1o C SD* over 24 hr.

1, 2 and 3) 40 CFR Part 50, App. L Sec. 8.2.2 SD use is a recommendation

Humidity Range all filters

24-hr mean 30.0% - 40.0% RH or

Within ± 5.0 % sampling RH but ≥ 20.0%RH

1, 2 and 3) 40 CFR Part 50, App. L Sec. 8.2.3

Humidity Control all filters < 5.1 % SD* over 24 hr.


Pre/post Sampling RH all filters difference in 24-hr means < ± 5.1% RH 1, 2 and 3) 40 CFR Part 50, App. L Sec. 8.3.3

Balance all filters located in filter conditioning environment 1, 2 and 3) 40 CFR Part 50, App. L Sec. 8.3.2

Microbalance Auto-Calibration

Prior to each weighing session

Manufacturer’s specification

1) 40 CFR Part 50, App. L, Sec. 8.1 2) 40 CFR Part 50, App. L, Sec. 8.1 and Method 2.12

Sec. 10.6 3) NA

OPERATIONAL EVALUATIONS TABLE PM2.5 Filter-Based Local Conditions

Field Activities

One-point Temp Verification

every 30 days

< ± 2.1oC

1) 40 CFR Part 50, App. L, Sec. 9.3

2) Method 2.12 Sec. 7.4.5 and Table 6-1 3) Recommendation

Pressure Verification

every 30 days

< ± 10.1 mm Hg 1) 40 CFR Part 50, App. L, Sec. 9.3


Annual Multi-point Verifications/Calibrations

Temperature multi-point


on installation, then every 365 days and once a calendar year

< ± 2.1oC 1) 40 CFR Part 50, App. L, Sec. 9.3 2 and 3) Method 2.12 Sec. 6.4.4 and Table 6-1



1) Criteria (PM2.5 LC) 2) Frequency 3) Acceptable Range Information /Action

Pressure Verification/Calibration on installation, and on one-

point verification failure < ± 10.1 mm Hg 1) 40 CFR Part 50, App. L, Sec. 9.3

2 and 3) Method 2.12 Sec. 6.5

Sampler BP verified against independent standard verified against a lab primary standard that is certified as NIST traceable 1/year

Flow Rate Multi-point Verification/

Calibration

Electromechanical maintenance

or transport or every 365 days and once a

calendar year

< ± 2.1% of transfer standard

1) 40 CFR Part 50, App. L, Sec. 9.2. 2) 40 CFR Part 50, App. L, Sec. 9.1.3, Method 2.12

Sec. 6.3 & Table 6-1 3) Recommendation

Other Monitor Calibrations per manufacturers’ op manual per manufacturers’ operating manual 1, 2 and 3) Recommendation

Precision

Collocated Samples every 12 days for 15% of sites

by method designation


collect collocated samples

every 6 days.

CV < 10.1% of samples ≥ 3.0 µg/m3

1) and 2) 40 CFR Part 58 App A Sec. 3.2.3

3) Recommendation based on DQO in 40 CFR Part

58 App A Sec. 2.3.1.1

Accuracy

Temperature Audit every 180 days and at time of

flow rate audit < ± 2.1oC

1, 2 and 3) Method 2.12 Sec. 11.2.2

Pressure Audit every 180 days and at time of

flow rate audit < ± 10.1 mm Hg

1, 2 and 3) Method 2.12 Sec. 11.2.3

Semi Annual Flow Rate Audit Twice a calendar year and

between 5-7 months apart

The SCHD AMB’s goal is

to have quarterly flow rate

audits

< ± 4.1% of audit standard < ± 5.1% of design flow rate

1 and 2) 40 CFR Part 58, App A, Sec. 3.2.2 3) Method 2.12 Sec. 11.2.1

Monitor Maintenance

PM2.5 Separator (VSCC) every 30 days cleaned/changed 1, 2 and 3) Method 2.12 Sec. 8.3.3

Inlet Cleaning every 30 days cleaned 1, 2 and 3) Method 2.12 Sec. 8.3

Downtube Cleaning every 90 days cleaned 1, 2 and 3) Method 2.12 Sec. 8.4

Filter Housing Assembly Cleaning every 30 days cleaned 1, 2 and 3) Method 2.12 Sec. 8.3

Circulating Fan Filter Cleaning every 30 days cleaned/changed 1, 2 and 3) Method 2.12 Sec. 8.3

Manufacturer-Recommended Maintenance

per manufacturers’ SOP per manufacturers’ SOP

Laboratory Activities Filter Checks

Lot Blanks

9 filters per lot

< ± 15.1 µg change between weighings 1, 2, 3) Recommendation and used to determine filter

stability of the lot of filters received from EPA or vendor. Method 2.12 Sec. 10.5

Exposure Lot Blanks 3 filters per lot < ± 15.1 µg change between weighings 1, 2 and 3) Method 2.12 Sec. 10.5 Used for preparing a subset of filters for equilibration

Filter Integrity (exposed) each filter no visual defects 1, 2 and 3) Method 2.12 Sec. 10.7 and 10.3

Lab QC Checks

Field Filter Blank 10% or 1 per weighing session < ± 30.1 µg change between weighings 1) 40 CFR Part 50, App. L Sec. 8.3.7.1 2 and 3) Method 2.12 Table 7-1 & Sec.10.5



1) Criteria (PM2.5 LC) 2) Frequency 3) Acceptable Range

Information /Action

Lab Filter Blank

10% or 1 per weighing session

< ± 15.1 µg change between weighings 1) 40 CFR Part 50, App. L Sec. 8.3.7.2


Balance Check (working standards) beginning, 10th sample, end < ± 3.1 µg from certified value 1, 2 and 3) Method 2.12 Sec. 10.6 Standards used should meet specifications in Method 2.12, Sec. 4.3.7

Routine Filter re-weighing 1 per weighing session < ± 15.1 µg change between weighings 1, 2 and 3) Method 2.12 Sec. 10.8

Microbalance Audit every 365 days and once a

calendar year

< ± 0.003 mg or manufacturers specs, whichever is tighter

1, 2 and 3) Method 2.12 Sec. 11.2.7

Lab Temp Check Every 90 days < ± 2.1oC 1, 2 and 3) Method 2.12 Sec. 10.10

Lab Humidity Check Every 90 days < ± 2.1% 1, 2 and 3) Method 2.12 Sec. 10.10


Microbalance Calibration

At installation every 365 days

and once a calendar year

Manufacturer’s specification 1) 40 CFR Part 50, App. L, Sec. 8.1 2) 40 CFR Part 50, App. L, Sec. 8.1 and Method 2.12

Sec. 9.3 3) NA

Lab Temperature Certification every 365 days and once a year < ± 2.1oC 1, 2 and 3) Method 2.12 Sec. 4.3.8 and 9.4

Lab Humidity Certification every 365 days and once a year < ± 2.1% 1, 2 and 3) Method 2.12 Sec. 4.3.8 and 9.4

Calibration & Check Standards -

Working Mass Stds. Verification Compared to primary standards

Every 90 days < ± 2.1 µg 1, 2 and 3) Method 2.12 Sec. 9.7

Primary standards certification every 365 days and once a

calendar year 0.025 mg tolerance (Class 2) 1, 2 and 3) Method 2.12 Sec. 4.3.7

SYSTEMATIC CRITERIA -PM2.5 Filter-Based Local Conditions

Siting every 365 days and once a

calendar year




Data Completeness Annual Standard ≥ 75% scheduled sampling days in each quarter 1, 2 and 3) 40 CFR Part 50, App. N, Sec. 4.1 (a) (b)

24- Hour Standard ≥ 75% scheduled sampling days in each quarter 1, 2 and 3) 40 CFR Part 50, App. N, Sec. 4.2 (a) (b)

Reporting Units all filters µg/m3 at ambient temp/pressure (PM2.5) 1, 2 and 3) 40 CFR Part 50 App N Sec. 3.0 (b)


value calculation

all filters

to one decimal place, with additional digits to the

right being truncated

1, 2 and 3) 40 CFR Part 50 App N Sec. 3.0 (b) The


comparison to NAAQS not for reporting individual values

Annual 3-yr average

all concentrations nearest 0.1 µg/m3 (≥ 0.05 round up)

1, 2 and 3) 40 CFR Part 50, App. N Sec. 3 and 4

Rounding convention for data reported to AQS is a recommendation

24-hour, 3-year average

all concentrations nearest 1 µg/m3 (≥ 0.5 round up)



Detection Limit



1) Criteria (PM2.5 LC) 2) Frequency 3) Acceptable Range Information /Action

Lower DL all filters ≤ 2 µg/m3 1, 2 and 3) 40 CFR Part 50, App. L Sec. 3.1

Upper Conc. Limit all filters ≥ 200 µg/m3 1, 2 and 3) 40 CFR Part 50, App. L Sec. 3.2

Precision

Single analyzer (collocated monitors) every 90 days Coefficient of variation (CV) < 10.1% for values

≥ 3.0 µg/m3

1, 2 and 3) Recommendation in order to provide early (quarterly) evaluation of achievement of DQOs.

Primary Quality Assurance Org. Annual and 3 year estimates 90% CL of CV < 10.1 % for values ≥ 3.0 µg/m3 1, 2 and 3) 40 CFR Part 58, App A, Sec. 4.2.1 and

2.3.1.1

Bias

Performance Evaluation Program

(PEP)

5 audits for PQAOs with ≤ 5

sites

< ± 10.1% for values ≥ 3.0 µg/m3

1, 2 and 3) 40 CFR Part 58, App A, Sec. 3.2.4, 4.2.5 and

2.3.1.1

Field Activities Verification/Calibration Standards Recertifications – All standards should have multi-point certifications against NIST Traceable standards

Flow Rate Transfer Std. every 365 days and once a

calendar year

< ± 2.1% of NIST Traceable Std.

1) 40 CFR Part 50, App. L Sec. 9.1 & 9.2

2) Method 2.12 Sec. 4.2.2 & 6.3.3 3) 40 CFR Part 50, App. L Sec. 9.1 & 9.2

Field Thermometer every 365 days and once a

calendar year ± 0.1o C resolution, + 0.5o C accuracy

1, 2 and 3) Method 2.12 Sec. 4.2.2

Field Barometer every 365 days and once a

calendar year ± 1 mm Hg resolution, ± 5 mm Hg accuracy

1, 2 and 3) Method 2.12 Sec. 4.2.2

Clock/timer Verification Every 30 days ± 1 min/mo 1 and 2) Method 2.12 Sec. 4.2.1 3) 40 CFR Part 50, App. L Sec. 7.4.12

Laboratory Activities Microbalance Readability At purchase ± 1 µg 1, 2 and 3) 40 CFR Part 50, App. L Sec. 8.1

Microbalance Repeatability

At purchase

1 µg 1) Method 2.12 Sec. 4.3.6

2) Recommendation 3) Method 2.12 Sec. 4.3.6

Primary Mass/Working mass Verification/Calibration Standards

At purchase 0.025 mg tolerance (Class 2) 1, 2 and 3) Method 2.12 Sec. 4.3.7



Table 7-6. Continuous PM2.5 Local Conditions Validation Template 1) Criteria (PM2.5 Cont) 2) Frequency 3) Acceptable Range Information /Action

CRITICAL CRITERIA- PM2.5 Continuous, Local Conditions

Sampler/Monitor Designation

N/A

Meets requirements listed in FRM/FEM/ARM

designation

Confirm method designation on front panel or just inside instrument.

1) 40 CFR Part 58 App. C Sec. 2.1

2) NA

3) 40 CFR Part 53 & FRM/FEM method list

Firmware of monitor

At setup

1. Must be the firmware (or later version) as identified

in the published method designation summary.

2. Firmware settings must be set for flowrate to

operate and report at “local conditions” (i.e., not

STP).

40 CFR Part 50 App. N. sec. 1 (c)

Data Reporting Period

Report every hour

1. The calculation of an hour of data is dependent on the

design of the method.

2. A 24-hour period is calculated in AQS if 18 or more

valid hours are reported for a day 1/.

See operator’s manual. Hourly data are always

reported as the start of the hour on local standard

time

40 CFR Part 50 App. N. Sec 3 (c)

Sampling Instrument

PM10 Inlet (if applicable to method designated)

At Setup Must be a Louvered PM10 size selective inlet as specified in 40 CFR Part 50, Appendix L, Figures L-2 through L-19

PM2.5 second stage separator

(if applicable to method

designated)

At Setup

Must be a BGI Inc. Very Sharp Cut Cyclone (VSCCTM) or

equivalent second stage separator approved for the method.

The other approved second stage separator option

for select FEMs is the Dichot. Only the GRIMM

180 and Teledyne T640 and T640X are known to

not have a second stage separator as part of the method.

Average Flow Rate

every 24 hours of operation;

alternatively, each hour can be

checked

average within ± 5% of 16.67 liters/minute at local

conditions

1, 2 and 3) 40 CFR Part 50 App. L, Sec. 7.4.3.1

Variability in Flow Rate every 24 hours of op CV ≤ 2% 1, 2 and 3) 40 CFR Part 50, App. L, Sec. 7.4.3.2


by 14 days


perform weekly flow

verifications.


< ± 5.1% of flow rate design value

1, 2 and 3) 40 CFR Part 50, App. L, Sec. 9.2.5, 40 CFR Part 58, Appendix A, Sec. 3.2.1



1,2 and 3) 40 CFR Part 50, App. L, Sec. 9.2.6



1) Criteria (PM2.5 Cont)

2) Frequency

3) Acceptable Range

Information /Action


Leak Check

every 30 days

± 0.15 lpm Main Flow (TEOM)

± 0.60 lpm Aux Flow (TEOM)

1) 40 CFR Part 50 App L, Sec. 7.4.6.1

2) Recommendation



on installation, then every 365 days and 1/ calendar year

< ± 2.1oC 1) 40 CFR Part 50, App. L, Sec. 9.3 2) and 3) Method 2.12 Sec. 6.4.4


every 30 days

< ± 2.1oC



Pressure Verification/Calibration on installation, then every 365

days and 1/calendar year


perform 1 pt. checks monthly

< ± 10.1 mm Hg 1) 40 CFR Part 50, App. L, Sec.9.3

2) and 3) Method 2.12 Sec. 6.5

BP verified against independent standard verified

against a lab primary standard that is certified NIST

traceable 1/year

Flow Rate Multi-point

Verification/ Calibration

Electromechanical maintenance

or transport or Every 365 days and 1/ calendar

year


1) 40 CFR Part 50, App. L, Sec. 9.2.

2) 40 CFR Part 50, App. L, Sec. 9.1.3, Method

2.12 Sec. 6.3 & Table 6-1 3) Recommendation

Precision


by method designation CV < 10.1% of samples ≥ 3 µg/m

3


3) Recommendation based on DQO in 40 CFR

Part 58 App A Sec. 2.3.1.1

Accuracy



1, 2 and 3) Method 2.12 Sec. 11.2.2



1, 2 and 3) Method 2.12 Sec. 11.2.3

Semi Annual Flow Rate Audit Twice a calendar year and 5-7

months apart

The SCHD AMB’s goal is to perform these

quarterly.

< ± 4.1% of audit standard < ± 5.1% of design flow rate


Shelter Temperature

Temperature range At setup Between 2° to 40° C (TEOM)

Temperature Control Daily (hourly values) < 2.1o C SD over 24 hours 1, 2 and 3) QA Handbook Volume 2 Sec. 7.2.2

Temperature Device Check every 180 days and twice a

calendar year The SCHD AMB’s goal is to


< ± 2.1o C 1, 2 and 3) QA Handbook Volume 2 Sec. 7.2.2



1) Criteria (PM2.5 Cont)

2) Frequency 3) Acceptable Range

Information /Action

Monitor Maintenance

PM2.5 Separator (VSCC) every 30 days cleaned/changed 1, 2 and 3) Method 2.12 Sec. 8.3.3







TEOM-FDMS Specific Operational Criteria

Total Flow Verification every 30 days Sum of flow rates from 3 paths equal design

flow rate < ± 5.1%

Bypass leak check (TEOM) every 30 days ± 0.60 lpm TEOM Operating Manual Sec. 3

Replace TEOM filters as needed Change TEOM filter as filter loading approaches 90%, but

must be changed before reaching 100%.

Replace the 47-mm FDMS (Purge)

filters

Every 30 days or any time

TEOM filters are replaced

Replaced

Internal/External Data Logger Data

Every 30 days

10 randomly selected values

agree exactly (digital) and ± 1 µg/m3

(analog). Note:

digital is expected and should be used unless there is no

capacity to utilize digital in the monitoring agencies’ data system.

Replace In-line filters every 180 days and twice a

calendar year replaced

Clean cooler assembly every 365 days and once a

calendar year cleaned

Clean/Maintain switching valve every 365 days and once a


Clean air inlet system of mass transducer enclosure

every 365 days and once a calendar year

cleaned

Replace the dryers 1/yr. or due to poor performance Review dryer dew point data to determine acceptable

performance of dryer

Calibration (KO)

constant verification

every 365 days and once a

calendar year

Pass or Fail

(≤ 2.5%)

1) 1405-DF operating guide. Verification software

either passes or fails the verification. Acceptance

criteria is ≤ 2.5 %

Rebuild sampling pump 18 months < 66% of local pressure

SYSTEMATIC CRITERIA- PM2.5 Continuous, Local Conditions

Siting every 365 days and once a

calendar year


1) 40 CFR Part 58 App. E, Sec. 2-6 2) Recommendation 3) 40 CFR Part 58 App. E, Sec. 2-6

Data Completeness

Annual Standard ≥ 75% scheduled sampling days in each quarter 1, 2 and 3) 40 CFR Part 50, App. N, Sec. 4.1 (a) (b)

24- Hour Standard ≥ 75% scheduled sampling days in each quarter 1, 2 and 3) 40 CFR Part 50, App. N, Sec. 4.2 (a) (b)



1) Criteria (PM2.5 Cont) 2) Frequency 3) Acceptable Range

Information /Action

Reporting Units all concentrations µg/m3 at ambient temp/pressure (PM2.5) 1, 2 and 3) 40 CFR Part 50 App. N Sec. 3.0 (b)

Rounding convention for

data reported to AQS all concentrations to one decimal place or as reported by instrument

1, 2 and 3) 40 CFR Part 50 App. N Sec. 3.0 (b)

Annual 3-yr average

all concentrations nearest 0.1 µg/m3 ( ≥ 0.05 round up)




all concentrations nearest 1 µg/m3 ( > 0.5 round up)


Rounding convention for data reported to AQS is a

recommendation

Verification/Calibration Standards Recertifications - All standards should have multi-point certifications against NIST Traceable standards


calendar year

< ± 2.1% of NIST Traceable Std. 1) 40 CFR Part 50, App. L Sec. 9.1 &9.2

2) Method 2.12 Sec. 4.2.2 & 6.3.3 3) 40 CFR Part 50, App. L Sec. 9.1 & 9.2


calendar year ± 0.1o C resolution, + 0.5o C accuracy

1, 2 and 3) Method 2.12 Sec. 4.2.2


calendar year ± 1 mm Hg resolution, + 5 mm Hg accuracy

1, 2 and 3) Method 2.12 Sec. 4.2.2

Clock/timer Verification Every 30 days ± 1 min/month** 1 and 2) Method 2.12 Sec. 4.2.1 3) 40 CFR Part 50, App. L Sec. 7.4.12

Precision

Single analyzer

(collocated monitors)

every 90 days Coefficient of variation (CV) < 10.1% for values ≥ 3.0

µg/m3

1, 2 and 3) Recommendation in order to

provide early (quarterly) evaluation of

achievement of DQOs.

Primary Quality Assurance Org. Annual and 3 year estimates 90% CL of CV < 10.1 % for values ≥ 3.0 µg/m3

1, 2 and 3) 40 CFR Part 58, App A, Sec. 4.2.1 and 2.3.1.1

Bias

Performance Evaluation

Program (PEP)

5 audits for PQAOs with ≤ 5

sites

< ± 10.1% for values ≥ 3 µg/m3

1, 2 and 3) 40 CFR Part 58, App A, Sec. 3.2.4, 4.2.5

and 2.3.1.1

1/ 24 hour average value must be flagged if not meeting criteria SD= standard deviation , CV= coefficient of variation

** = need to ensure data system stamps appropriate time period with reported sample value



Table 7-7. PM10c for PM10-2.5 Low-Volume, Filter-Based Local Conditions Validation Template 1) Criteria (PM10c) 2) Frequency 3) Acceptable Range Information /Action

CRITICAL CRITERIA- PM10c Filter-Based Local Conditions

Field Activities

Sampler/Monitor

N/A Meets requirements listed in FRM/FEM/ARM

designation

1) 40 CFR Part 58 App. C Sec. 2.1

2) NA 3) 40 CFR Part 53 & FRM/FEM method list

Filter Holding Times

Pre-sampling all filters ≤ 30 days before sampling 1, 2 and 3) 40 CFR Part 50, App. L Sec. 8.3.5

Sample Recovery all filters ≤ 7 days 9 hours from sample end date

The SCHD AMB’s goal is to retrieve sampled filters

within 96 hours from the sample end date.

1, 2 and 3) 40 CFR Part 50 App. L Sec. 10.10

Sampling Period (including

multiple power failures)

all filters

1380-1500 minutes, or

value if < 1380 and exceedance of NAAQS1/

midnight to midnight local standard time

1, 2 and 3) 40 CFR Part 50 App. L Sec. 3.3

See details if less than 1380 min sampled

Sampling Instrument

Average Flow Rate every 24 hours of op average within ± 5% of 16.67 liters/minute 1, 2 and 3) 40 CFR Part 50 App. L Sec. 7.4.3.1

Variability in Flow Rate every 24 hours of op CV ≤ 2% 1, 2 and 3) 40 CFR Part 50, App. L Sec. 7.4.3.2


by 14 days


perform weekly

flow verifications.

< ± 4% of transfer standard

< ± 5% of flow rate design value

1, 2 and 3) 40 CFR Part 50, App. L, Sec. 9.2.5, 40 CFR

Part 58 App A Sec. 3.3.1



1, 2 and 3) 40 CFR Part 50, App. L, Sec. 9.2.6

Individual Flow Rates every 24 hours of op no flow rate excursions > ± 5% for > 5 min.1/


Filter Temp Sensor every 24 hours of op no excursions of > 5o C lasting longer than 30

consecutive min 1/


External Leak Check

Before each flow rate verification/calibration and

before and after PM2.5 separator maintenance

≤ 25 mmHg/min

1) 40 CFR Part 50 App L, Sec. 7.4.6.1 2) 40 CFR Part 50 App L Sec. 9.2.3 and Method 2.12

Sec. 7.4.3 3) 40 CFR Part 50, App. L, Sec. 7.4.6.1

Internal Leak Check If failure of external leak check ≤ 140 mmHg/min 1) 40 CFR Part 50, App. L, Sec. 7.4.6.2

2) Method 2.12, Sec. 7.4.4

3) 40 CFR Part 50, App. L, Sec. 7.4.6.2



Laboratory Activities

1) Criteria (PM10c) 2) Frequency 3) Acceptable Range Information /Action

Post-sampling Weighing

all filters

Protected from exposure to temperatures above

25°C from sample retrieval to conditioning

≤ 10 days from sample end date if shipped at

ambient temp, or

≤ 30 days if shipped below avg. ambient (or 4o C or

below for avg. sampling temps < 4o C ) from sample end date

1, 2 and 3) 40 CFR Part 50 App L Sec. 8.3.6

Filter Visual Defect Check

(unexposed) all filters

Correct type & size and for pinholes, particles or imperfections


Filter Conditioning Environment

Equilibration all filters 24 hours minimum 1, 2 and 3) 40 CFR Part 50, App. L Sec. 8.2.5

Temp. Range all filters 24-hr mean 20.0-23.0o C 1, 2 and 3) 40 CFR Part 50, App. L Sec. 8.2.1

Temp.Control all filters < 2.1o C SD* over 24 hr.


Humidity Range all filters

24-hr mean 30.0% - 40.0% RH or within

± 5.0% sampling RH but > 20.0%RH


Humidity Control all filters < 5.1% SD* over 24 hr.


Pre/post Sampling RH all filters difference in 24-hr means < ± 5.1% RH


Balance all filters located in filter conditioning environment 1, 2 and 3) 40 CFR Part 50, App. L Sec. 8.3.2

OPERATIONAL EVALUATIONS TABLE- PM10c Filter-Based Local Conditions

Field Activities Sampling Instrument

Routine Verifications


every 30 days

< ± 2.1oC 1) 40 CFR Part 50, App. L, Sec. 9.3


Pressure Verification

every 30 days

< ± 10.1 mm Hg 1) 40 CFR Part 50, App. L, Sec. 9.3





on installation, then every 365 days and once a calendar year

< ± 2.1oC 1) 40 CFR Part 50, App. L, Sec. 9.3 2 and 3) Method 2.12 Sec. 6.4.4 and Table 6-1

Pressure Verification/Calibration

on installation, then every 365

days and once a calendar year

< ± 10.1 mm Hg



Sampler BP verified against independent standard

verified against a lab primary standard that is certified as NIST traceable 1/year



1) Criteria (PM10c)

2) Frequency

3) Acceptable Range

Information /Action

Flow Rate Multi-point Verification/

Calibration

Electromechanical

maintenance or transport or every 365 days and once a

calendar year


1) 40 CFR Part 50, App. L, Sec. 9.2.

2) 40 CFR Part 50, App. L, Sec. 9.1.3, Method 2.12

Sec. 6.3 & Table 6-1 3) Recommendation

Other Monitor Calibrations

Per manufacturers’ op manual

Per manufacturers’ op manual

1, 2 and 3) Recommendation

Precision


by method designation CV < 10.1% of samples ≥ 3.0 µg/m

3


3) Recommendation based on DQO in 40 CFR Part

58 App A Sec. 2.3.1.1

Accuracy



1, 2 and 3) Method 2.12 Sec. 11.2.2



1, 2 and 3) Method 2.12 Sec. 11.2.3

Semi Annual Flow Rate Audit Twice a calendar year and 5-7

months apart


perform quarterly

audits.

< ± 4.1% of audit standard

< ± 5.1% of design flow rate


Monitor Maintenance

PM2.5 Separator (VSCC)(for the PM2.5 sampler)

every 30 days cleaned/changed 1, 2 and 3) Method 2.12 Sec. 8.3.3







Laboratory Activities Filter Checks

Lot Blanks

9 filters per lot

< ± 15.1 µg change between weighings 1, 2, 3) Recommendation and used to determine filter

stability of the lot of filters received from EPA or vendor. Method 2.12 Sec. 10.5

Exposure Lot Blanks 3 filters per lot < ± 15.1 µg change between weighings 1, 2 and 3) Method 2.12 Sec. 10.5 Used for preparing a subset of filters for equilibration

Filter Integrity (exposed) each filter no visual defects 1, 2 and 3) Method 2.12 Sec. 10.7 and 10.3

Lab QC Checks

Field Filter Blank 10% or 1 per weighing session < ± 30.1 µg change between weighings 1) 40 CFR Part 50, App. L Sec. 8.3.7.1 2 and 3) Method 2.12 Table 7-1 & Sec.10.5

Lab Filter Blank 10% or 1 per weighing session < ± 15.1 µg change between weighings 1) 40 CFR Part 50, App. L Sec. 8.3.7.2 2 and 3) Method 2.12 Sec. 10.5



1) Criteria (PM10c)

2) Frequency

3) Acceptable Range

Information /Action

Balance Check (working standards)

beginning, 10th sample, end

< ± 3.1 µg from certified value 1, 2 and 3) Method 2.12 Sec. 10.6

Standards used should meet specifications in Method

2.12, Sec. 4.3.7

Routine Filter re-weighing 1 per weighing session < ± 15.1 µg change between weighings 1, 2 and 3) Method 2.12 Sec. 10.8

Microbalance Audit every 365 days and once a

calendar year < ± 0.003 mg or manufacturers specs, whichever is

tighter 1, 2 and 3) Method 2.12 Sec. 11.2.7

Lab Temp Check Every 90 days < ± 2.1oC 1, 2 and 3) Method 2.12 Sec. 10.10

Lab Humidity Check Every 90 days < ± 2.1% 1, 2 and 3) Method 2.12 Sec. 10.10


Microbalance Calibration

At installation every 365 days

and once a calendar year

Manufacturer’s specification 1) 40 CFR Part 50, App. L, Sec. 8.1 2) 40 CFR Part 50, App. L, Sec. 8.1 and Method 2.12

Sec. 9.3 3) NA

Lab Temperature Certification every 365 days and once a year < ± 2.1oC 1, 2 and 3) Method 2.12 Sec. 4.3.8 and 9.4

Lab Humidity Certification every 365 days and once a year < ± 2.1% 1, 2 and 3) Method 2.12 Sec. 4.3.8 and 9.4

Calibration & Check Standards -

Working Mass Stds. Verification Compared to primary standards

Every 90 days < ± 2.1 ug 1, 2 and 3) Method 2.12 Sec. 9.7

Primary standards certification every 365 days and once a

calendar year 0.025 mg tolerance (Class 2) 1, 2 and 3) Method 2.12 Sec. 4.3.7

SYSTEMATIC CRITERIA - PM10c Filter-Based Local Conditions

Siting Every 365 days and 1/ calendar

year


1) 40 CFR Part 58 App E, Sec. 2-6 2) Recommendation 3) 40 CFR Part 58 App E, Sec. 2-6

Data Completeness

NA

≥ 75% scheduled sampling days in each quarter 1, 2 and 3) Recommendation based on PM2.5

requirements in 40 CFR Part 50, App. N, Sec. 4.1 (b) 4.2 (b)

Reporting Units all filters µg/m3 at ambient temp/pressure (PM2.5) 1, 2 and 3) 40 CFR Part 50 App N


value calculation

all filters

to one decimal place, with additional digits to the

right being truncated

1, 2 and 3) 40 CFR Part 50 App N Sec. 3.0 (b) The


comparison to NAAQS not for reporting individual

values.

Lower DL all filters ≤ 3 µg/m3 1, 2 and 3) 40 CFR Part 50, App O Sec. 3.1

Upper Conc. Limit all filters ≥ 200 µg/m3 1, 2 and 3) 40 CFR Part 50, App O Sec. 3.2



1) Criteria (PM10c) 2) Frequency 3) Acceptable Range Information /Action Precision

Single analyzer

(collocated monitors)

every 90 days and 4 times a

calendar year.

Coefficient of variation (CV) < 10.1% for values

≥ 3 µg/m3

1, 2 and 3) Recommendation in order to provide early

evaluation of achievement of DQOs.

Primary Quality Assurance Org. Annual and 3 year estimates 90% CL of CV < 10.1% for values ≥ 3 µg/m3

1, 2 and 3) Recommendation in order to provide early evaluation of achievement of DQOs.

Bias

Performance Evaluation Program (PEP)

Once every 6-7 years < ± 10.1% for values ≥ 3 µg/m3

1, 2 and 3) Recommendation based on pending guidance.

Field Activities Verification/Calibration Standards Recertifications – All standards should have multi-point certifications against NIST Traceable standards


calendar year

< ± 2.1% of NIST-traceable Std.

1) 40 CFR Part 50, App. L Sec. 9.1 & 9.2

2) Method 2.12 Sec. 6.3.3 3) 40 CFR Part 50, App. L Sec. 9.1 & 9.2


calendar year ± 0.1o C resolution, ± 0.5o C accuracy

1, 2 and 3) Method 2.12 Sec. 4.2.2



1, 2 and 3) Method 2.12 Sec. 4.2.2

Verification/Calibration Clock/timer Verification

every 30 days ± 1 min/mo. 1 and 2) Method 2.12 Sec 4.2.1 3) 40 CFR Part 50, App. L, Sec. 7.4.12

Laboratory Activities Microbalance Readability at purchase ± 1 µg 1, 2 and 3) 40 CFR Part 50, App. L, Sec. 8.1

Microbalance Repeatability

at purchase

1 µg 1) Method 2.12 Sec. 4.3.6

2) Recommendation 3) Method 2.12 Sec. 4.3.6

Primary Mass. Verification/Calibration Standards

at purchase 0.025 mg tolerance (class 2) 1, 2 and 3) Method 2.12 Sec. 4.3.7

Comment #1

The associated leak test procedure shall require that for successful passage of this test, the difference between the two pressure measurements shall not be greater than the number of mm

of Hg specified for the sampler by the manufacturer, based on the actual internal volume of the sampler, that indicates a leak of less than 80 mL/min.

1/ value must be flagged, SD= standard deviation, CV= coefficient of variation



Table 7-8. Continuous PM10 STP Conditions Validation Template 1) Criteria (PM10 Cont) 2) Frequency 3) Acceptable Range Information /Action

CRITICAL CRITERIA- PM10 Continuous

Sampler/Monitor

NA Meets requirements listed in

FRM/FEM/ARM designation

1) 40 CFR Part 58 App. C, Sec. 2.1 2) NA 3) 40 CFR Part 53 & FRM/FEM method list

Sampling Period all filters 1440 minutes ± 60 minutes

midnight to midnight local standard time 1, 2 and 3) 40 CFR Part 50 App J, Sec. 7.1.5

Average Flow Rate every 24 hours of op Average within < ± 5.1% of design recommendation



by 14 days


perform weekly flow verifications

< ± 7.1% of transfer standard 1 and 2) 40 CFR Part 58, App. A. Sec. 3.3 3) Method 2.10 Table 3.1

OPERATIONAL EVALUATIONS TABLE PM10 Continuous Verification/Calibration

System Leak Check Every 30 days ± 0.15 lpm Main Flow (TEOM) ± 0.60 lpm Aux Flow (TEOM)

1) 40 CFR Part 50 App. L, Sec. 7.4.6.1 2) Recommendation

Flow Rate Multi-point


Electromechanical maintenance, transport or every 365 days and once a

calendar year

< ± 2.1% of transfer standard 1) 40 CFR Part 50, App. L, Sec. 9.2 2) 40 CFR Part 50, App. L, Sec, 9.1.3, Method 2.12 Sec. 6.3 & Table 6-1 3) Recommendation

Audits

Semi Annual Flow Rate Audit Twice a calendar year and 5-

7 months apart


perform quarterly

audits.

< ± 10.1% of audit standard 1, 2) 40 CFR Part 58, App. A, Sec. 3.3.3 3) Method 2.10 Sec. 7.1.5

Monitor Maintenance

Inlet/downtube Cleaning every 90 days and 4 times a


1, 2 and 3) Method 2.10 Sec. 6.1.2



SYSTEMATIC CRITERIA - PM10 Continuous

Siting Every 365 days and 1/

calendar year


1) 40 CFR Part 58 App. E, Sections 2-6

2) Recommendation 3) 40 CFR Part 58 App, E, Sections 2-6

Data Completeness 24-hour quarterly

≥ 75% 1, 2 and 3) 40 CFR Part 50 App. K, Sec. 2.3b & c



1) Criteria (PM10 Cont) 2) Frequency 3) Acceptable Range Information /Action

Reporting Units all concentrations µg/m3

at standard temperature and pressure

(STP)

40 CFR Part 50 App. K


value calculation


quarterly nearest 10 µg/m3 (≥ 5 round up)

1, 2 and 3) 40 CFR Part 50 App K Sec. 1 The rounding

convention is for averaging values for comparison to NAAQS

not for reporting individual values.

Verification/Calibration Standards and Recertifications - All standards should have multi-point certifications against NIST Traceable standards


calendar year

< ± 2.1% of NIST-traceable Std.

1) 40 CFR Part 50, App. J Sec.7.3

2) Method 2.11 Sec. 1.1.3 3) 40 CFR Part 50, App. J Sec. 7.3


calendar year ± 0.1o C resolution, ± 0.1o C accuracy

1, 2 and 3) Method 2.10 Sec. 1.1.2



1, 2 and 3) Method 2.10 Sec. 1.1.2

Clock/timer Verification every 180 days and twice a

calendar year

± 15 min/day

1) 40 CFR Part 50, App. J Sec. 7.1.5

2) Recommendation 3) 40 CFR Part 50, App. J Sec. 7.1.5



Table 7-9. Meteorological Measurement Methods Validation Criteria

CRITICAL CRITERIA TABLE - METEOROLOGICAL MEASUREMENT METHODS

S-single instrument hourly value, G- group of hourly values from 1 instrument

Parameter Criteria Acceptable Range Frequency Samples

Impacted

EPA-454/R-

99-005 Feb

2000

EPA

Regula-

tion and

Guidance

Method Measurement Method Characteristics

Reporting

Units Range Accuracy Resolution

Starting

Speed

Distance

Constant

Sampling

Frequency

Raw Data

Collection

Frequency

Wind Speed

(WS)

Cup, blade, or heated

sonic anemometer m/s

0.5 m/s - 50

m/s ± 0.2 m/s 0.25 m/s ≤ 0.5 m/s

≤ 0.5 m @

1.2 kg/m3 hourly 1 minute All Data

Chapter 2 Sec

1 & 8, Chapter

5 Sec 1 & 2,

Chapter 8 Sec

1

QA

Handbook

Vol IV

Section 0

Tables 0-

3, 0-4, 0-

5, 0-6

Damping

Ratio

Wind

Direction

(azimuth &

elevation)

vane or heated sonic

anemometer Degrees (°)

1° - 360° or

540° ± 5 degrees 1.0 degree

≤ 0.5 m/s

@ 10

degrees

0.4 to 0.7

@ 1.2

kg/m3

hourly 1 minute All Data

Time

Constant

Spectral

Response

Ambient

Temp Thermistor 10m - 2m

Degrees

Celsius (°C)

-40°C to

+40°C ±0.5°C 0.1°C

≤ 1

minute hourly 1 minute All Data

Chapter 2 Sec

3 & 8, Chapter

3 Sec 6,

Chapter 5 Sec

1 & 2, Chapter

8 Sec 1

Relative

Humidity

Psychrometer/

Hygrometer % % 0-100% ±7% 0.50%

≤ 30

minutes hourly 1 minute All Data

Chapter 2 Sec

4 & 8, Chapter

5 Sec 1 & 2

Barometric

Pressure Aneroid Barometer mb

950 mb to

1050 mb

Hg

± 3 mb Hg

(0.3 kPa) 0.5 mb Hg hourly 1 minute All Data

Chapter 2 Sec

6 & 8, Chapter

5 Sec 1 & 2



CRITICAL CRITERIA TABLE - METEOROLOGICAL MEASUREMENT METHODS



Impacted

EPA-454/R-99-

005 Feb 2000

EPA

Regulation

and Guidance

Reporting

Intervals

All parameters Hourly average Quarterly All Chapter 5 Sec 1

Data

completeness

All parameters valid data

capture ≥ 75% Hourly G

Chapter 5 Sec 3

& 4

QA Handbook

Vol IV Section

0 Tables 0-3,

0-4, 0-5, 0-6

OPERATIONAL EVALUATIONS TABLE - METEOROLOGICAL MEASUREMENT METHODS



Impacted

EPA-454/R-99-

005 Feb 2000

EPA

Regulation

and Guidance

Siting & Exposure

Criteria

All met

parameters Representativeness

Site must be representative for the intent of the monitoring scale. No prescribed

quantitative criteria See references All All Chapter 3 Sec 1

QA Handbook

Vol IV, Sec.

0.12 All met

parameters Probe Siting

See references for specific siting criteria for simple, complex, coastal, and urban

terrain locations All All

Chapter 3 Sec 2 &

3

Visual QC Checks - Field

Sky Check Note & Record sky conditions (cloud cover, temp/WS/WD, etc. estimates) Each site

visit G QA Handbook

Vol IV Section

10.2

WS WS Sensor Moving freely, no visual damage Each site

visit G



OPERATIONAL EVALUATIONS TABLE - METEOROLOGICAL MEASUREMENT METHODS



Impacted

EPA-454/R-99-

005 Feb 2000

EPA

Regulation

and Guidance

WD WD sensor Moving freely, no visual damage Each site

visit G

Temperature

Temperature sensors and

aspirated temperature

shields

No visual damage or obstruction, Motor in aspirated shield working Each site

visit G

BP Pressure Sensor No visual damage or obstruction Each site

visit G

RH RH sensor, aspirated shield No visual damage or obstruction, Motor in aspirated shield working Each site

visit G

DAS Data Acquisition System DAS time ≤ 1 minute NIST Standard Each site

visit G

Data Screening Criteria

WS Hourly Recorded WS 0 m/s ≤ WS ≤ 25 m/s0, WS varies ≥ 0.1 m/s/3 consecutive hours, WS varies ≥ 0.5

m/s/12 consecutive hours, or per site specific climatology criteria

1/week or

more

frequent

G Chapter 8, Table

8-4

WD Hourly Recorded WD 0 ≤ WD ≤ 360°, WD varies ≥1°/3 consecutive hours, or per site specific

climatology criteria

1/week or

more

frequent

G Chapter 8, Table

8-4

Temperature Hourly Recorded Ambient

Temperature

Local record low ≤ Temp ≤ local record high, Temp ≤ 5°C from previous hourly

record, Temp varies ≥0.5 C/12 consecutive hours, or per site specific climatology

criteria

1/week or

more

frequent

G Chapter 8, Table

8-4

RH/Dew

Point

Hourly Recorded Relative

Humidity

Dew Point Temp ≤ Amb. Temp for time period, Dew Point Temp ≤5°C change

from previous hour, Dew Point Temp ≥ 0.5°from previous hour, and Dew Point

Temp < Amb. Temp for 12 consecutive hours

1/week or

more

frequent

G Chapter 8, Table

8-4

Barometric

Pressure

Hourly Recorded

Barometric Pressure

BP < 1050 mb (sea level), BP > 945 mb (sea level), or Per site specific climatology

criteria

1/week or

more

frequent

G Chapter 8, Table

8-4

Maintenance

WS Sensor bearings Replace 1/6 months G

WD Sensor bearings Replace 1/6 months G



SYSTEMATIC ISSUES TABLE - METEOROLOGICAL MEASUREMENT METHODS



Impacted

EPA-454/R-99-

005 Feb 2000

EPA

Regulation

and Guidance

Data Completeness

All Met

Parameters ≥75% NCore, SLAMS quarterly G

QC Checks

DAS Clock/timer

Verification ≤ ± 1 minute

Each site

visit G

Bias/Accuracy

All Met

Parameters Technical Systems Audit NCore/SLAMS 1/3 years G

QA Handbook

Vol IV Section

10 and

Appendix A


7.3 Network Scale

Representativeness is defined as a measure of the degree to which data accurately and precisely represent a selected characteristic of a monitoring system. Support in achieving representativeness is provided through adhering to the requirements provided in:

40 CFR Part 58, Appendix D (Network Design Criteria for Ambient Air Quality Monitoring)

40 CFR Part 58, Appendix E (Probe and Monitoring Path Siting Criteria for Ambient Air Quality Monitoring)

Each monitor operated is assigned a scale of representativeness based on the definitions of 40 CFR Part 58, Appendix D.

Micro Scale - describes air volumes associated with area dimensions ranging from several meters up to about 100 meters (m)

Middle Scale – describes air volumes associated with area dimensions up to several city blocks in size with dimensions ranging from about 100 m to 500 m (0.5 kilometer [km])

Neighborhood Scale – describes air volumes associated with an area of a city that has relatively uniform land use with dimensions in the 500 m to 4,000 m (0.5 to 4.0 km) range

Urban Scale – describes air volumes within cities with dimensions on the order of 4,000 m to 50,000 m (4.0 km to 50 km). This scale would usually require more than one site for definitions

Regional Scale – describes air volumes associated with rural areas of reasonably homogeneous geography that extends for tens to hundreds of kilometers

As described in Section 6.0, the SCHD’s sites are Neighborhood or Urban Scale sites.

8.0 Training/Certification

Adequate education and training are integral to any monitoring program that strives for reliable and comparable data. Training is aimed at increasing the effectiveness of employees and their organization. Personnel working in the AMB will meet the educational requirements, accountability standards, and training requirements for their positions. All SCHD AMB staff are required to take specific mandatory governmental training courses, such as safety training, operation of government vehicles, and ethics training, among other courses. Records on personnel qualifications and training may be maintained in a number of locations, such as the PCS or Human Resources offices.


The development of operational procedures for training is a valuable step to a good quality assurance program. These procedures should include information on:

Personnel qualifications – general and position-specific

Training requirements – by position

Training frequency

8.1 Personnel Qualifications for Technical Specialists

Personnel qualifications and training are major support elements of the quality system. Qualifications of air monitoring personnel are assured through the requirements and operation of the Shelby County Government job hiring process. If the applicant meets the minimum criteria for the Technical Specialist position, then he/she is notified of his/her eligibility for a job interview. The SCHD PCS receives a list of applicants who have been rated and approved by the Human Resources Department for that job classification. The SCHD Human Resources Department notifies the qualified candidates via phone or email. Interviews are conducted by the SCHD PCS Management and AMB Supervisor and a candidate is selected, offered the position and is hired. During the interview process, the applicants are questioned not only about their technical expertise but also about their organizational, interpersonal, and communication skills as well as work habits. References are contacted for confirmation of work experience. This competitive hiring process ensures that the most qualified personnel will be considered in the SCHD AMB. Each employee has Service Quality Indicators (SQIs) for implementation of his/her job-specific responsibilities for completing air monitoring work activities. The SQIs include the activities the employee is expected to complete and states that work should be complete, thorough, submitted on time and of professional quality. This ensures that environmental data collected or decisions made are to the EPA standards. The SCHD AMB Supervisor shall ensure that personnel performing work activities have the required education, training, and experience. Formal qualification or certification of personnel performing certain specialized activities should be evaluated and implemented when necessary. Areas of training required by the AMB are:

Reading and understanding the SCHD AMB QAPP for Ambient Air Monitoring

Reading and understanding the EPA QA Handbook, NCore and Near-Road NO2 TADs

Reading and understanding the monitoring-specific SOPs associated with the equipment the Technical Specialist is responsible for maintaining, operating, and troubleshooting (see Section 11.1)

Reading and understanding the manufacturer’s operating manuals and guides, and participating in supplemental vendor-offered training via webinars or


instrumentation factory training on site or at facilities, provided funding is available

Applicable safety and health training provided by the SCHD PCS or other related vendors

8.2 Continuing Education and Training

Training is required in the SCHD AMB because the SCHD’s air monitoring network is growing with new equipment and procedures. All employees are actively encouraged to pursue training opportunities, especially in job-related fields, to meet the project quality requirements. The goals of training are to achieve initial proficiency, maintain proficiency, and adapt to changes in technology, methods, or job responsibilities. Training provides an understanding of the fundamentals of the work and the correct performance of work, including education in theories and principles and education to enhance an employee’s skills and practices. Quality system training provided to project management personnel is to ensure that personnel have the necessary skills and knowledge to meet the project quality requirements and can effectively implement the QAPP requirements. Quality system training provided to technical personnel and other staff is designed to enhance their understanding of and contribution to the quality system. When new Technical Specialists are hired into the AMB, they are required to read the QAPP, SOPs and shadow senior Technical Specialists on the operation, maintenance, and troubleshooting of instrumentation. The new Technical Specialist learns about the operation of the instrument with hands-on training with Senior Technical Specialists. They continue to perform this hands-on training until they are deemed proficient in the area of operating the equipment. The other Technical Specialists who don’t operate the instruments on a day-to-day basis are encouraged to shadow and observe the Technical Specialists who operate the instrumentation on a more routine basis. This allows the other Technical Specialists to become more proficient in operating other instrumentation and become a backup when other staff is unavailable. Continuing education and training are a critical component of a quality assurance program. Training is offered as needed or required to maintain and improve the skills and knowledge of both new and senior staff. All training is tracked and documented in individual personnel files by the AMB Supervisor or his/her designee. Staff may be required to submit a memorandum to the Supervisor outlining training received or may be required to present a summary of training received at meetings and conventions. Technical training will be conducted by the EPA experts and instrument manufacturers when new instruments are purchased. It includes, but is not limited to fundamentals of air monitoring, which introduce air monitoring terminology, network design, station setup and operation, and how monitoring is performed. There is quality assurance and data management training which covers the basics of quality assurance, quality assessment, quality control, SOPs, quality control check forms, calibration and routine


checks, documentation, and data management procedures. The training is usually provided by the AMB Supervisor or Lead Technical Specialist. There is also instrumentation operation training which covers operation, maintenance, and troubleshooting of the SCHD air monitoring instruments and methodologies. This is provided by the AMB Supervisor, Lead Technical Specialist or by viewing information or training videos on the link: https://www.epa.gov/amtic. Additionally, personnel are encouraged to periodically identify, request, and attend pertinent courses and seminars. These courses and seminars may be provided as web-based real-time interactive formats, and/or live instruction. Organizations that provide these training opportunities include the Air and Waste Management Association, The Southeastern Local Air Pollution Control Agencies and Southeastern States Air Resources Managers, Inc. (Metro4, Inc. - SESARM), and the EPA. New employees are partnered with senior employees so that new employees understand their job responsibilities, both the quantity and quality of work to be completed. All monitoring personnel have accessibility to SOPs, operation manuals, and technical services contracts. The monitoring field staff will also follow the specific directions within the Operations Manual supplied by the instrument vendor when servicing or performing QC and/or remedial checks on the instruments. Employees may also search the EPA website https://www.epa.gov/amtic where QA/QC and technical guidance documents can be obtained. All air monitoring personnel have or will have sufficient training to perform the necessary functions at an acceptable level. Additional training procedures will be documented in the QMP.

9.0 Documentation and Records

The following information describes the SCHD AMB’s document and records management procedure for the Ambient Air Monitoring Program. The majority of the documentation and records produced by the SCHD AMB consist of data and information gathered to support the pollutant concentration and meteorological data reported to the EPA. These documents and records include:

1. QAPP and SOPs 2. Sample collection records in electronic and written format 3. Logbook entries in electronic and written format 4. Quality control check and flow verification forms in electronic and written

format 5. Instrument and equipment certification/calibration information 6. Quality assurance documentation in electronic and written format 7. Documentation that supports data review, validation, and certification activities

https://www.epa.gov/amtic


In Section 19 of this QAPP, more detailed information regarding how data will be managed in the SCHD AMB’s network will be provided. This includes information on data recording, transmittal, storage, and retrieval. In addition to storage within the AQS database, the criteria/non-criteria pollutant concentration and meteorological data and its associated QC data will be archived in the SCHD AMB’s in-house databases for future references by the PCS, the EPA, and other interested parties.

9.1 Program Policy and Procedure Documentation

The SCHD AMB maintains records or program policy and procedure documentation. Documents in this category are published with the date and revision information notated in a header. Documents in this category include:

1. Quality Assurance Project Plans (QAPPs) 2. Standard Operating Procedures (SOPs)

Some of these documents contain a distribution list that itemizes the intended recipients of the documentation. Hard copies are provided by the AMB Supervisor. The Technical Specialists are required to date and initial the cover sheet. This cover sheet is the receipt/review form that documents that the Technical Specialists received a copy of the document. This cover sheet stays with the document and is filed with other documents in the AMB. If an older version of the document is available, the most current document is clearly identified as the most recent version and the older version is archived in the AMB office by the Supervisor of the AMB.

9.2 Sample Collection Records

Each Technical Specialist is responsible for completing the site logbook, Quality Control Check or Flow Verification form, Corrective Action Forms or Chain of Custody for the tasks he or she conducts. The site logbooks contain information on the instrumentation’s diagnostics, weekly zero, span, precision check results, maintenance logs, audit results, and any anomalies that may occur during a site visit. The results of the weekly zero, span, precision check and flow verification are documented on a Quality Control Check form and submitted to the AMB Supervisor within 24 hours of the visit. Graphs from AirVision are also provided displaying the weekly zero, span, precision check that was performed from the day’s site visit. This graph will document the site name, parameter, AQS identification number, date and time of the event. These AirVision graphs may also be provided when any anomalies occur with the instruments. All forms must be completed in indelible ink. If mistakes are made on hardcopy forms, the Technical Specialist is to cross out the mistake with a single line through the incorrect entry, and initial and date the correction. The correct information is to be written next to the incorrect entry or in a space near the incorrect information. Any blank spaces on a page are to be marked with a X. When the Technical Specialists


are at a site and notice any events that may impact the data, he/she is instructed to document this event in the site logbook. If the event is of significant impact and he/she is not at the site, he/she can document the event in the site logbook during his/her next site visit. This information should be documented on the day the Technical Specialist visits the site and the date of the event should be referenced at this time. The site logbooks remain at the site until the end of the month or until it is completed. The completed logbook is returned to the AMB office and archived in a file cabinet maintained by the SCHD AMB. At the end of the month, all site logbooks are brought back to the AMB office. Copies of the logbook entries from the month’s activities are made. These copies will be included in a monthly data package for the site and parameter. The data will be reviewed and edited prior to submittal to AQS. After the data is submitted, all paper copies of logbook entries, quality control check forms, flow verification forms, graphs of QC checks and anomalies, and certificates of analysis of gas cylinders used, if applicable, are scanned and saved to the AMB shared drive. Hardcopies are filed in file cabinets in the AMB office. The network drive is maintained by the SCHD IT Department and backed up nightly. PM2.5 and low-volume PM10 filters are listed in a logbook kept at the AMB office. Information documented in the logbook includes sample date of the filter, cassette number, filter number, and whether the filter is a field sample, field blank or trip blank. All filter information is kept in the logbook until it is filled at which time a new numbered logbook will begin. All completed logbooks are archived in the AMB office.

9.3 Chain of Custody Forms

Most ambient air monitoring data is collected via real-time monitoring equipment and stored on the AirVision server maintained by the SCHD IT Department. However, some monitoring, specifically filter-based particulate matter monitoring, involve the collection of a physical sample that is collected and shipped to IML. Any samples collected for analysis then packaged and transported to another location, such as IML, are required to be accompanied with a Chain of Custody (COC) form that includes specific information regarding the sample. The form assists with tracking the integrity of the sample through the various stages of transportation and receipt. While the COC forms themselves may vary by laboratory and the analysis required, the general content on the form includes:

1. The Technical Specialist’s initials, date, and time the sample is relinquished to

the lab 2. The initials of the Technical Specialist who retrieved the sampled filter from the

sampler along with the date, time, and ambient temperature at the time of pickup

3. The site name, sample date, cassette identification number and filter identification number


4. Any comments (such as sample time out of limits, machine malfunction, power failure) from the Technical Specialist are documented in the appropriate section of the form

The COCs are mainly used for PM FRM sampling and PM2.5 speciation sampling. COCs are submitted with the filter shipments every two weeks. IML will document on the PM FRM COC the date, time, and temperature of the filters upon arrival at the lab. The completed COC will then be scanned by IML and emailed to the SCHD AMB Supervisor monthly when the filter results are submitted. These COCs and IML data packages are stored on the AMB shared drive.

9.4 QA/QC Records

Quality assurance and quality control are achieved through the performance of periodic activities such as:

One-point QC checks

Zero/span/precision checks

Verification/calibration procedures

Maintenance activities

Corrective Actions

One-point flow rate verifications

Semi-annual flow rate audits

Other performance audits (i.e., internal, EEMS, TDEC, PEP, NPAP)

Collocated sampling

Technical Systems Audits

Traceability certification/calibrations

The SCHD AMB uses a variety of methods to collect and document QA/QC data, some of which are described in Section 9.2 above. Documentation methods include:

Quality control check worksheets

PDF records

Data management systems (i.e., AirVision from Agilaire, EDAS) The use of these records is described in associated SCHD SOPs (see Section 11.1). The records are retained and archived according to the procedures identified in Section 9.6 below. However, some of the QA/QC activities described above are maintained in the SCHD AMB office in a hardcopy format in a 3-ring notebook. These forms include traceability certifications, certificates of analysis that accompany gas cylinders, and certificates of


calibrations that accompany flow meters, DeltaCal, TetraCal, and Streamline Pros. Where possible, these hardcopies are scanned and saved on the AMB shared drive.

9.5 Reference Materials

Because of the technical nature of ambient air monitoring, a number of reference materials are necessary to effectively operate the program. Documentation such as instrument operation manuals, troubleshooting guides, addendums to equipment, EPA guidance documentation, EPA technical memoranda, the NCore TAD, the Near-Road NO2 TAD and various other reports are included in this category. The SCHD AMB maintains access to these applicable reference materials as long as they are useful and valuable to the program. These documents are maintained in the SCHD AMB office or AMB shared drive.

9.6 Archiving and Retrieval

Documentation is classified according to its intended use, future applicability, and regulatory requirement for retention. Information listed in Table 9-1 will be retained for at least three years from the date of collection. However, in most instances, records will be retained for a period of up to five years to allow a period of overlap for end-of-cycle reporting and TSAs. Records will be discarded if space is not available. Additionally, if any litigation, claim, designation, audit, or other action involving the records has been started before the expiration of the three-year period, the records will be retained until completion of the action and resolution of all issues which arise from it, or until the end of the regular (three-year) period, whichever is later. Electronic records are stored on the SCHD IT file server for the AMB or within the Data Acquisition System (i.e., EDAS/Agilaire AirVision). Data stored on the SCHD AMB file server is backed up nightly by the SCHD IT Department and stored off-site. The SCHD AMB central polling for daily data is housed on a server located at and backed up nightly by the SCHD IT Department.


Table 9-1. Documentation and Records Categories Record/Document Type File Locations

Management and Organization

Reporting Agency Information Organizational Structure Personnel Qualifications and Training Training Certification Quality Management Plan Grant Allocations/Work Plans Support Contracts (for equipment certification services)

SCHD Pollution Control Section / Air Monitoring Branch

File cabinets

3-ring notebooks

AMB share drive

Site Information

Network Descriptions Site Files Site Maps Site Pictures


File cabinets

AMB share drive

Raw Data Any Original Data (routine and quality control) including Data Entry Forms IML data packages


AMB share drive

Environmental Data Operations

Quality Assurance Project Plans (QAPPs) Standard Operating Procedures (SOPs) Field and Laboratory Notebooks Sample Handling/Chains of Custody Records Inspection/Maintenance Records Certification Records/Reports

SCHD Pollution Control Section / Air Monitoring Branch and Air Monitoring Sites

File cabinets

AMB share drive

Data Reporting

Air Quality Index Reports Annual Network Report Data/Summary Reports Journals/Articles/Papers/Presentations


File cabinets

AirVision server

AMB share drive

Data Management

Data Algorithms Data Management Plans/Flowcharts Data Management Systems Pollutant Data Meteorological Data


File Cabinets

AMB share drive

AirVision server

Quality Assurance

Network Reviews Network Assessments Data Quality Assessments Quality Assurance Reports (i.e. flow verification and QC check forms) Technical Systems Audit Reports Response/Corrective Action Reports Site Audits (i.e. SCHD performance audits, EEMS performance evaluation reports, TDEC performance evaluation reports) Certificates of Analysis for Gas Cylinders Certificates of Calibration for Audit Devices (i.e., DeltaCal, TetraCal, Flow Meters)


File Cabinets

AMB share drive

3-ring notebook


The AMB Supervisor maintains these records. Access to these records is permitted by personnel in the AMB.

10.0 Network Description The purpose of this section is to:

Identify the functions associated with the SCHD’s Ambient Air Quality Monitoring Network

Outline the network’s objectives

Establish the criteria for the sampling network design and monitoring site selection

Identify the intended sampling frequency

The primary function of the Air Monitoring Program is to verify compliance with the NAAQS. Other purposes include determining trends over time, determining effects on air quality from adjustments to source emissions, developing algorithms based on historical air quality and other conditions which will forecast air quality, verifying air quality modeling programs, providing real-time ozone and continuous PM data to the public, and correlating health effects to air quality. Sampling network design and monitoring site selection comply with the following appendices of 40 CFR Part 58:

40 CFR Part 58, Appendix A – Quality Assurance Requirements for Monitors used in Evaluations of National Ambient Air Quality Standards

40 CFR Part 58, Appendix D – Network Design Criteria for Ambient Air Quality Monitoring

40 CFR Part 58, Appendix E – Probe and Monitoring Path Siting Criteria for Ambient Air Quality Monitoring

10.1 Network Objectives

The SCHD AMB provides air quality monitoring services for Shelby County, Tennessee. Our air quality monitoring services are conducted to measure concentrations of the criteria air pollutants (particulate matter, ozone, sulfur dioxide, carbon monoxide and nitrogen dioxide) and other non-criteria pollutants (PM Speciation, NOy, etc.), as well as meteorological parameters of interest. The ambient air quality monitoring network is designed to meet three basic objectives. These basic objectives, per 40 CFR Part 58, Appendix D, are:

1) Provide air pollution data to the general public in a timely manner.


2) Support compliance with national ambient air quality standards (NAAQS) and emissions strategy development.

3) Support air pollution research studies.

Other goals and objectives are described in Section 6.0 of this QAPP.

10.2 Monitoring Objectives and Spatial Scales

Each monitor within the SCHD’s Ambient Air Quality Monitoring Network is assigned one of the following monitoring objective designations:

Population exposure – the monitor is located in an area associated with high population density

Background – the monitor is located where manmade pollutant emissions are minimal

Transport – the monitor is located to measure pollutants transported from other areas

Maximum concentration – the monitor is located where a high concentration of the pollutant is expected (often based on results of receptor models)

Comparison study – the monitor is located adjacent to other instrumentation measuring the same pollutant to compare different sampling/monitoring methodologies

Air Quality Index – the monitor provides data primarily for reporting to the Air Quality Index

The specific monitoring objectives for the SCHD AMB’s monitoring sites are listed in Section 6.0.

Data collected within the network must be representative of the spatial area under study. The goal in siting a monitoring station is to match the spatial scale represented by the samples obtained with the spatial scale most appropriate for the monitoring objective of the station. For a description of representative measurement scales, see Section 7.3. For a table of spatial scales for SLAMS, please reference Table 10-1. The spatial scales for the monitoring stations in Shelby County are either Neighborhood or Urban Scales.


Table 10-1. Summary of Spatial Scales for State and Local Air Monitoring Stations (SLAMS)

Scales Applicable for SLAMS

SO2 CO O3 NO2 Pb PM10 PM2.5

Micro X X X X X X

Middle X X X X X X

Neighborhood X X X X X X X

Urban X X X X

Regional X X

The national ambient air monitoring system includes several types of monitoring stations, each targeting a key data collection need and each varying in technical specification. The SCHD AMB’s monitoring sites are either: 1) NCore Multi-pollutant Station- site that measures multiple pollutants in order to

provide support to integrated air quality management data needs. 2) State and Local Air Monitoring Stations (SLAMS) – sites intended to address specific

air quality management interests.

The specific monitoring site types for the SCHD AMB’s monitoring stations are listed in Section 6.0.

10.3 Site Selection The selection of a specific monitoring site includes the following activities:

Developing and understanding the monitoring objective and appropriate data quality objectives

Identifying the spatial scale most appropriate for the monitoring objective of the site

Identifying potential locations where the monitoring site could be placed

Identifying the specific monitoring site Each monitoring site is evaluated to assure it adheres to the site selection criteria specified in 40 CFR Part 58, Appendix D.

10.3.1 Site Location

Four criteria should be considered when evaluating potential sites. Monitoring sites should be oriented to measure the following (singly or in combination, as appropriate for the sampling objective):


Impacts of known pollutant emission categories on air quality

Population density relative to receptor-dose levels, both short and long-term

Impacts of known pollutant emission sources (area and point) on air quality

Representative air quality

Selection according to these criteria requires detailed information concerning the location of sources, geographic variability of ambient pollutant concentrations, meteorological conditions, and population density. Selection of the number, geographic locations, and types of sampling stations is, therefore, a complex process. The sampling site selection process also involves consideration of the following factors:

Economics – The quantity of resources required to accomplish all data collection activities, including instrumentation, installation, maintenance, data retrieval, data analysis, QA, and data interpretation, must be established.

Security – In some cases, a preferred location may have associated problems that compromise the security of monitoring equipment (i.e. high risk of theft, vandalism, etc.). If such problems cannot be remedied through the use of standard measures such as additional lighting, fencing, etc., then an attempt to locate the site as near to the preferred location as possible shall be made.

Logistics – This process includes procurement, maintenance, and transportation of material and personnel for the monitoring operation. The logistics process requires full knowledge of all aspects of the data collection operation: planning, reconnaissance, training, scheduling, safety, staffing, procuring goods and services, communications, and inventory management.

Atmospheric Considerations – These considerations may include spatial and temporal variability of pollutants and their transport. Effects of buildings, terrain, and heat sources or sinks on air trajectories can produce localized anomalies of pollutant concentrations. Meteorology must be considered in determining the geographic location of a site as well as the height, direction, and extension of sampling probes. Evaluation of a local wind rose is essential to properly locate many monitoring sites (e.g., siting either to detect or avoid emissions from specific sources).

Topography – Evaluation of the local topography based upon land use maps, U.S. Geological Survey topographic maps, and other available resources must be completed. Minor and major topological features that impact both the transport and diffusion of air pollutants must be identified and evaluated. Minor features may consist of tall structures either upwind or downwind of a point source, which may exert small influences on pollutant dispersion patterns. Major


features include river canyons, deep valleys, and large lakes. Major features significantly impact the prevailing wind patterns or create their own local weather such as katabatic or anabatic winds.

Pollutant Considerations – The monitoring site location for a specific pollutant may or may not be appropriate for another pollutant. Evaluation of the changes that pollutants undergo temporally and spatially must be considered in order to determine the applicability of each particular site for a specific pollutant. An example would be the temporal delay in peak concentrations of NOx and volatile organic compounds (VOCs), compared to the peak concentration of resulting O3. A micro scale site used to monitor CO may be appropriate for measuring O3 precursors, such as VOCs and NOx, but entirely inappropriate for measuring O3 itself. Due to the time delay in the creation of the secondary pollutant, O3, a more distant neighborhood or urban scale monitoring site may be appropriate for directly monitoring O3.

Interdependence exists between all of the factors listed above. Consequently, an iterative procedure must be employed in order to successfully select appropriate sites that can provide the data necessary to accomplish the project’s stated objectives. In situations where the sites do not specifically meet the requirements necessary to obtain the project objectives, reassessment of the sampling site must occur. Operation of air quality measurement systems; estimates of air quality; field and theoretical studies of air diffusion; and considerations of atmospheric chemistry and air pollution effects make up the required expertise needed to select the optimum sampling site for obtaining data necessary to fulfill the monitoring objectives. The AMB Supervisor and Lead Technical Specialist are assigned these tasks.

10.3.2 Monitor Placement The placement of each monitor is generally determined by the defined monitoring

objective. Monitors are, thus, usually placed according to potential exposure to pollution. Due to the various factors discussed above, tradeoffs are often necessary to locate a site for collection of optimally representative data. Final placement of a particular monitor at a selected site is dependent on physical obstructions and activities in the immediate area. Monitors must be placed away from obstructions such as trees and fences in order to avoid their effects on airflow. To prevent sampling bias, airflow around monitor sampling probes must be representative of the general airflow in the area. In addition, the availability of utilities (i.e. electricity and telephone services) is critical.


10.4 Probe Siting Criteria for Pollutant Sampler/Analyzer

General probe and monitoring path siting criteria for criteria pollutants shall adhere to the requirements listed in 40 CFR Part 58, Appendix E and outlined below in Table 10-2. Table 10-2. Probe Siting Criteria

Probe Siting Criteria for Pollutant Sampler/Analyzer

Pollutant Scale Height from

Ground to Probe or Inlet

Horizontal and Vertical Distance from Supporting

Structures to Probe or Inlet

Spacing from Obstructions

Distance from Trees to Probe or

Inlet

Distance from Roadways

CO

Neighborhood (NCore)

2 to 15 meters

> 1 meter

See 40 CFR Part 58,

Appendix E, Section 4

> 10 meters

See 40 CFR Part 58,

Appendix E, Table E-2

Microscale (Near-Road)

2 to 7 meters ≤ 50 meters

NO, NOy, NO2

Urban (NCore) 2 to 15 meters > 1 meter

See 40 CFR Part 58,


> 10 meters

See 40 CFR Part 58,



2 to 7 meters ≤ 50 meters

O3

Urban (NCore)

2 to 15 meters > 1 meter

See 40 CFR Part 58,


> 10 meters

See 40 CFR Part 58,


Neighborhood

PM (10 and 2.5)

Urban (NCore) 2 to 15 meters

> 2 meters (collocated low-volume sampler

inlets must be at least 1 meter but not

greater than 4 meters away from each

other)

See 40 CFR Part 58,


> 10 meters

See 40 CFR Part 58,

Appendix E, Figure E-1

Neighborhood


2 to 7 meters ≤ 50 meters for Near-Road

SO2 Urban (NCore) 2 to 15 meters > 1 meter

See 40 CFR Part 58,


> 10 meters N/A

10.5 NCore Monitoring Station

Ambient concentrations of several of the criteria pollutants [i.e. lead (Pb), carbon monoxide (CO), sulfur dioxide (SO2), and nitrogen dioxide (NO2)] are now well below the National Ambient Air Quality Standards (NAAQS). While the obvious problems of widespread elevated concentrations have been largely solved for some criteria pollutants, problems related to particulate matter (PM), ozone (O3), and toxic air pollutants remain. It is now clear that even very low air pollution levels can be


associated with adverse environmental and human health effects. As a result, new approaches in air monitoring are needed to measure these low levels and to incorporate these measurements with other data into comprehensive assessments of human and environmental health. One of the major investments in the determination of the low-level pollution is the use of highly sensitive commercial air pollutant monitors for the characterization of the precursor gases CO, SO2, and total reactive oxides of nitrogen (NOy) in a national core monitoring network (NCore). The NO/NOy measurements will produce conservative estimates for NO2 that can be used to ensure tracking continued compliance with the NO2 NAAQS. NO/NOy monitors are used at these sites because it is important to collect data on total reactive nitrogen species for understanding O3 photochemistry. The NOy converter box is mounted on the meteorological tower at 10 meters in height at the NCore station to avoid the physical removal of nitric acid (HNO3) from the atmosphere. The high sensitivity CO and SO2 analyzers are fundamentally the same as those designated as Federal Reference and Equivalent methods (https://www.epa.gov/amtic/air-monitoring-methods-criteria-pollutants) but with modifications to improve sensitivity and accuracy or reduce interferences. The use of such precursor gas analyzers in the NCore network will still allow determination of compliance with the NAAQS, but will provide measurements at much lower detection limits than are achievable by traditional monitors. The capability for accurate measurements at low concentrations will support long-term epidemiological studies, reduce uncertainties in data for modeling of air pollution episodes, and support source apportionment and observational analyses. The SCHD AMB began the operation of the NCore station in 2011 at the Shelby Farms NCore station. The pollutants measured at the NCore station are listed in Section 6.0.

10.5.1 Meteorological

The siting criteria for meteorological sensors vary greatly from parameter to parameter. Because of the variations, the siting criteria are discussed below on a parameter-by-parameter basis. Instruments shall be mounted on booms at the top of or projecting horizontally from the tower. The booms shall be securely fastened to the tower and shall be strong enough so that they will not sway or vibrate in strong winds. Wind instruments shall be mounted on a boom so that the sensors are twice the maximum diameter or diagonal of the tower away from the tower. Wind sensors shall be mounted on booms or cross-arms so that a sensor’s wake does not impact adjacent sensors. Usually, this means mounting the sensors a minimum of 2 m apart. If the wind sensors are to be mounted on top of a tower, they shall be mounted at a height and distance from the tower so that the diagonal distance between the sensor and the tower is equal to twice the maximum diameter or diagonal of the tower.

https://www.epa.gov/amtic/air-monitoring-methods-criteria-pollutants


The SCHD AMB measures for these meteorological parameters: ambient temperature, barometric pressure, relative humidity, wind direction, and wind speed. The meteorological sensors are mounted on a 10-meter tower.

10.5.1.1 Towers

The sensors should be securely mounted on a mast (tower or pole) that will not twist, rotate, or sway. The tower shall be of an open grid-type construction and of sufficient strength (steel or other suitable material) to be climbed safely in order to install, service, and audit the sensors. A tower must be rigid enough to maintain all mounted instruments in proper alignment and orientation in high winds. Since the instruments are located on a cross-arm projecting out from the tower, the cross-arms shall be securely fastened to the tower and shall be strong enough so that the sensors do not sway or vibrate in high winds. The sensors shall be securely fastened to the cross-arm at a distance of two tower diameters or widths, measured from the edge of the tower to the sensor, to avoid any influence of tower-induced turbulence on the sensors. The cross-arm shall be installed so that it is horizontally level and the sensors shall be installed so that they are vertical. The cross-arm shall be mounted and aligned so that the wind direction sensor is correctly aligned. (The correct alignment varies on a sensor-by-sensor basis. Consult the appropriate section of the manufacturer’s operator’s manual for the correct alignment.)

10.5.1.2 Wind Velocity Sensors

If the wind sensors are to measure surface level winds, the sensors should be located on a 10-meter tower in open terrain. Open terrain is defined as an area where the distance between the tower base and any obstruction is at least ten times the height of that obstruction. This applies to manmade (buildings) and natural (trees, rocks or hills) obstructions. All distances are to be measured from the edge of the obstruction nearest the tower. Trees and shrubs shall be measured from the outside edge of the crown or drip line, and not the trunk.

10.5.1.3 Temperature and Humidity Sensors

The temperature and humidity sensors shall be mounted over an open plot of short grass or natural earth (not concrete or asphalt) at least 9 m in diameter. For the SCHD AMB, the sensors are mounted on the 10-meter tower approximately 3 meters above the ground.


The sensors shall be no nearer any obstructions than a distance of four times the height of the obstruction. This applies to both manmade and natural obstructions. The distance to trees or shrubs shall be measured from the edge of the crown or drip line of the vegetation, not the trunk. The sensors shall be positioned at a minimum of 30 m from large paved areas (streets, parking lots, etc.), steep slopes, ridges, hollows, or bodies of standing water. Temperature probes shall be located so that they are not influenced by heat leakage from the shelter containing the electronics and recorders for the meteorological equipment.

10.5.1.4 Barometric Pressure Sensors

Barometric pressure sensors are usually mounted inside the shelter housing meteorological instruments and recorders since barometric pressure is not affected by indoor installations. The installation of the barometric pressure sensors inside the stable shelter environment protects the instruments from exposure to extreme climatological events that may impact the sensors or recorders. However, when a sensor is mounted inside a shelter, it should be placed inside the building on an interior wall and removed from drafts from the heating/ventilating/air conditioning system, doors, and windows. The instrument should be mounted to minimize vibration and be vented to eliminate shelter interior pressurization.

10.6 Near-Road Monitoring Station

A revised 1-hour NAAQS for nitrogen dioxide was promulgated in February 2010. In this rule, the EPA required changes to the monitoring network that will focus monitoring resources to capture short-term NO2 concentrations near heavily trafficked roads. The primary objective of the project was to locate a near-road NO2 monitoring site that utilizes six factors: annual average daily traffic (AADT), fleet mix, congestion patterns, roadway design, terrain, and meteorology. For near-road NO2 monitoring stations, the monitor probe shall have an unobstructed air flow, where no obstacles exist at or above the height of the monitor probe, between the monitor probe and the outside nearest edge of the traffic lanes of the target road segment. The SCHD AMB began the operation of the near-road monitoring station in July 2014. This site is within 20 m of the target road, in accordance with the Near-Road NO2 TAD. The pollutants measured at the monitoring station are listed in Section 6.0.


10.7 Sampling Frequency

Minimum sampling frequencies are established by the EPA and are followed accordingly (Table 10-4). The sampling frequencies of monitors are based on the EPA’s requirements in 40 CFR 58.12. In instances requiring every third and sixth-day sampling, specific days must be sampled in order that the entire nation is sampling on the same day. This intermittent sampling is accomplished in accordance with a national sampling schedule published annually by the EPA. The minimum number of samples required for appropriate summary statistics should be taken. At least 75% of the total possible observations must be present before summary statistics are calculated. The exact requirements appear in 40 CFR Part 50 and in Table 10-3. Table 10-3. Requirements for Calculating Summary Statistics

Pollutant Completeness Requirement (%) Time Frame

Carbon Monoxide 75% Per hour, 8-hour, quarter, day, and annual

Nitrogen Dioxide 75% Per hour, quarter, day, and annual

Total Reactive Oxides of Nitrogen

75% Per hour, quarter, and day

Ozone 75% Per hour, 8-hour, quarter, day, and annual

Ozone 90% Daily maximum 8-hour averages, on average, for each season over a 3-year period

Particulate Matter (10 and 2.5) continuous

75% Per hour, quarter, and day

Particulate Matter (10, 10-2.5, and 2.5) filter-based

75% of the scheduled days per calendar quarter

24 ± 1 hour

Sulfur Dioxide 75% Per hour, 3-hour, quarter, day, and annual

Ambient Temperature 75% Per hour and quarter

Barometric Pressure 75% Per hour and quarter

Relative Humidity 75% Per hour and quarter

Wind Direction 75% Per hour and quarter

Wind Speed 75% Per hour and quarter


Table 10-4. Pollutant Sampling Schedule and Frequency Pollutant Time Frame (local

standard time) Frequency Monitor Type

Carbon Monoxide Midnight to midnight 24/7 continuous

Nitrogen Dioxide Midnight to midnight 24/7 continuous

Total Reactive Oxides of Nitrogen

Midnight to midnight 24/7 continuous

Ozone (NCore operates year-round, non-NCore operates from March 1 thru October 31)


Particulate Matter (10 and 2.5) continuous


Particulate Matter (10, 10-2.5 and 2.5) filter-based

Midnight to midnight 1 in 3 Filter-based

Particulate Matter (2.5) (collocated)

Midnight to midnight 1 in 6 Filter-based

Sulfur Dioxide Midnight to midnight 24/7 continuous

Ambient Temperature Midnight to midnight 24/7 continuous

Barometric Pressure Midnight to midnight 24/7 continuous

Relative Humidity Midnight to midnight 24/7 continuous

Wind Direction Midnight to midnight 24/7 continuous

Wind Speed Midnight to midnight 24/7 continuous

11.0 Sampling Methodology

The purpose of this section is to:

Identify the sampling methods

Identify the procedures for collecting the required environmental samples

Describe the: o Equipment used in the data collection network o Necessary support facilities o Sample preservation requirements o Implementation requirements o Required material

Identify the: o Corrective actions necessary to reestablish network data integrity o Responsible parties to implement the corrective actions o Methods required to verify corrective action effectiveness


11.1 Monitoring Technology/Methodology

In accordance with 40 CFR Part 58, Appendix C, Section 2.1, a criteria pollutant monitoring method used for making NAAQS decisions at a SLAMS site must be a reference or equivalent method (i.e., FRM or FEM). The SCHD AMB uses only EPA-approved FRM or FEM instrumentation to determine pollutant concentrations for NAAQS compliance determinations in the monitoring network. The sampling methods used by the SCHD are equivalent to the reference methods provided in 40 CFR Part 50. For the detailed specifications upon which a specific monitoring method has received its FRM/FEM status, see the “List of Designated Reference and Equivalent Methods”, issued by the EPA Office of Research and Development, which is found on the AMTIC website https://www.epa.gov/amtic/air-monitoring-methods-criteria-pollutants. The SCHD AMB will operate the instrumentation in accordance with these designation specifications. See Table 11-2 for the specific instrument models used in the SCHD AMB network. The scientific measurement principles of the differing sampling methods utilized by the air monitoring instrumentation are not described here. However, detailed descriptions of these principles for the specific pollutant instrumentation, including theories of operation, can be found in the specific instrument manuals. The manuals can be found online, in the SCDH AMB lab and are also maintained by the Shared (S:) drive.

Specific SOP titles used in the network are available for the different measured pollutants. The SCHD AMB has the following SOPs: Table 11-1. SCHD SOPs

Title Revision Number Date Standard Operating Procedure for CO Monitoring 0 01/16

Standard Operating Procedure for Mass Flow Controller Calibration 0 01/16

Standard Operating Procedure for NO, NOy, NO2 Monitoring 0 01/16

Standard Operating Procedure for O3 Monitoring 0 01/16

Standard Operating Procedure for Ozone Transfer Standard Verification

0 01/16

Standard Operating Procedure for PM2.5 and low-volume PM10 Sampling

0 11/15

Standard Operating Procedure for PM2.5 and low-volume PM10 TEOM 0 01/16

Standard Operating Procedure for SO2 Monitoring 0 01/16

AirVision Error Graph Protocol 0 01/14

Some SOPs have been submitted for review to the EPA and are under revisions.

https://www.epa.gov/amtic/air-monitoring-methods-criteria-pollutants


Table 11-2. Ambient Air Monitoring Network of Instrumentation

Pollutant Manufacturer Models Reference or Equivalent

Method Number

SO2 Teledyne Advanced Pollution

Instrumentation 100A EQSA-0495-100

NO2, NO, NOx (trace level)

Teledyne Advanced Pollution Instrumentation

T200U RFNA-1194-599

CO Teledyne Advanced Pollution

Instrumentation 300, 300E

RFCA-1093-093

O3 Teledyne Advanced Pollution

Instrumentation 400E, 400A, T400 EQOA-0992-087

Continuous PM10 mass

Thermo Fisher Scientific TEOM 1405 EQPM-1090-079

PM2.5 Rupprecht & Patashnick Partisol Plus 2025 and

2025i EQPM-0202-145

Multi gas calibrator Teledyne Advanced Pollution

Instrumentation 700, 700EU, T703

PM10 (low-volume) Rupprecht & Patashnick Partisol Plus 2025 RFPS-1298-127

PM10-2.5 FRM mass Rupprecht & Patashnick Partisol Plus 2025 RFPS-0509-176

Continuous PM2.5

mass Rupprecht & Patashnick TEOM 1400

Trace levels (CO) Teledyne Advanced Pollution

Instrumentation 300EU, T300U RFCA-1093-593

Trace levels (SO2) Teledyne Advanced Pollution

Instrumentation 100EU EQSA-0495-600

Trace levels (NO) Teledyne Advanced Pollution

Instrumentation 200EU

Trace levels (NOy) Teledyne Advanced Pollution

Instrumentation 200EU

Surface Meteorology Climatronics

Data Logger ESC 8816, 8832

11.1.1 Sample Collection

All samples for criteria pollutants will be collected using the Federal Reference Method (FRM) or Federal Equivalent Method (FEM) according to testing in 40 CFR Part 53. The SCHD AMB may use alternative non-FEM or non-FRM methods for NOy measurement and AQI reporting. Procedures set forth in the approved SOPs will be used.


11.2 Sample Collection Methodology

11.2.1 Physical Collection

The physical collection of particulate filter samples, sample transport, and sample preservation techniques adhere to the requirements of 40 CFR Part 50, Appendices J, L, O, and the QA Handbook.

Sampling methods may be categorized into two general categories:

1) Intermittent sample collection (non-continuous or static) - A physical sample is collected using a monitoring device that passes ambient air through a filter, collects a sample in a container, or exposes a sample collection media to a sample stream. The sample-containing media (i.e., filter) is then removed and analyzed via laboratory methods to identify and/or quantify the pollutant of interest.

2) Real-time or near real-time sample analysis (continuous) – Physical samples are not collected. “In situ” analysis of the composition of the sample is performed within the analyzer itself using a specific methodology.

11.2.2 Electronic Data Collection

Electronic data collection is possible through the network’s data acquisition system AirVision and modems. This equipment is located in the shelters where the data loggers record the data history and the modems provide a path to download the data for analysis. The SCHD’s data management system AirVision is on a server housed at the Shelby County Information Technology’s (IT) office. Each piece of instrument has its own Internet Protocol (IP) address assigned by the IT Department. These instruments are polled hourly to retrieve data for analysis. The ozone and continuous PM2.5 data is also sent to AIRNOW tech. Monitoring personnel can also link to the stations manually via AirVision to retrieve data or determine the status of the systems.

11.2.3. Support Facilities

11.2.3.1 Monitoring Station Design

The monitoring station design must encompass the operational needs of the equipment, provide an environment that supports sample integrity, and allow the operator to safely and easily service and maintain the equipment. The SCHD AMB currently uses aluminum shelters provided by Morgan Building, a prefabricated concrete building and corrugated container shelters provided by Consolidated Analytical Systems.


11.2.3.2 Shelter Criteria

Air pollution analyzers, with the exception of intermittent, filter-based PM samplers, must be housed in a shelter capable of fulfilling the following requirements:

The shelter temperature must be maintained at a temperature that meets the reference or equivalency method requirements for all instrumentation that it contains.

The power supply should not vary more than ± 10% from 115 alternating current voltage (VAC). It is best to provide some type of voltage regulation to accomplish this.

The shelter must protect the instrumentation from precipitation and excessive dust and dirt, provide third-wire grounding as in modern electrical codes, meet federal Occupational Safety and Health Administration (OSHA) regulations, and be cleaned regularly to prevent a buildup of dust.

The shelter must protect the instrumentation from any environmental stress such as vibration, corrosive chemicals, intense light, or radiation.

Single sample lines wrapped in pipe insulation are used to provide sample air from the outside. The NOy sample transfer lines are protected from light with opaque conduit, which are provided by Teledyne API, in accordance with the NCore TAD. The analyzers draw samples from the probe. Criteria pollutant and NOy analyzers require that the probe material must be either borosilicate glass or an acceptable inert plastic, such as polytetrafluoroethylene (PTFE or TFE), perfluoroalkoxy (PFA), or other Teflon®-type materials.

Other designs are possible. However, any design must ensure that the probe and sample line tubing’s material be non-reactive with the pollutant of interest. The probe, intake vent, and interconnecting tubing design must provide a minimum number of bends to avoid particles impacting onto surfaces. Impacted particles may provide surfaces on which pollutants may absorb. Additionally, the probe must prevent rainwater from entering the analyzers. A glass funnel at the probe is used to prevent the rainwater from entering the analyzers. Any liquid water will absorb pollutants, impacting the pollutant concentration by removing pollutants from the sample and consequently, yielding inaccurate environmental data. Dirt buildup on the inside of the probe and tubing will absorb pollutants from the air stream during high concentration periods and release pollutants during low concentration periods skewing the data collected. The probes are cleaned and the tubing is replaced yearly or when the line is dirty or contaminated.

The residence time in the probe and sample line tubing must be 20 seconds or less. The residence time (T) is defined as the time the sampling gas is spent in the sampling tube.


It can be calculated from the total sample flow (Q), tubing length (L), and internal radius (R) of the tubing. The equation for the calculation is:

T = (L X πR2)/Q

More details about residence time calculations are provided in the gaseous SOPs.

If the physical configuration of the probe restricts the flow, then modify the physical configuration to rectify this deficiency. This may be accomplished by reducing the length of interconnecting tubing, increasing the tubing and / or decreasing the number of tube bends between the probe and the analyzer, or other alterations that allow the system to meet the residence time requirements.

The SCHD’s Ambient Air Quality Monitoring Network is currently using Teflon® tubing as a sample line between the probe and analyzer. Particulate filters are placed in the sample train behind the analyzers. The weekly QC checks are performed behind the analyzers through the particulate filters.

11.2.4 Sample/Measurement System Corrective Action

Corrective action measures in the Ambient Air Quality Monitoring Network will be taken to ensure the data quality objectives are attained. There is the potential for many types of sampling and measurement system corrective actions. Each approved SOP details some expected problems and corrective actions needed for a well-run monitoring network.

The SCHD AMB has a backup plan to deploy a spare monitor/analyzer into the field if the original monitor/analyzer has to be taken off-line for service. The spare instrument undergoes a flow verification or multi-point verification and calibration before it is placed in service. The information is documented in the site logbook and on the QC check or flow verification form. This information will also be documented on a Corrective Action Form (Figure 21-1). All of this information will be documented in the respective locations by the Technical Specialist and provided to the AMB Supervisor. Consent is not required by the AMB Supervisor as long as he/she is notified of the method change. The original monitor/analyzer will undergo the same procedures once it has been repaired and placed back into service.

12.0 Sample Handling and Custody

Due to the potential use of PM data for comparison to the NAAQS and the requirement for extreme care in filter-based sample collection, sample custody procedures must be followed. An example of the Chain of Custody (COC) Record Form that will be used to track the stages of PM2.5 and PM10 filter handling throughout the data collection operation is presented in Figures 12-1 thru 12-2. These forms shall be supplied to the


Technical Specialists when necessary. Custody procedures are detailed in the SOP for PM2.5 and low-volume PM10 sampling.

Figure 12-1. Chain of Custody (COC) Record Form for PM2.5 Filters


Figure 12-2. Chain of Custody (COC) Record Form for PM10 Filters


12.1 PM Filters

The filters used in the PM program are provided by the EPA. Upon receipt of the new filter lot each year, the boxes are then shipped to IML for inspection, testing and storage until the filters are needed for sampling. A Technical Specialist or Lead Technical Specialist from the SCHD AMB receives conditioned and pre-weighed PM2.5 and low-volume PM10 filters from the contracted lab Inter-Mountain Laboratories, Inc. (IML). The filters are inspected by the Technical Specialists upon receipt and checked against the packing list. Any filters damaged or compromised during the shipping process will not be used and will be returned to IML. IML will follow their QAPP “For Laboratory and Data Management Support of the Determination of Fine Particulate Matter as PM2.5, PM10 and Coarse Particulate Matter as PM10-2.5 in the Atmosphere, Revision 14 March 2017”. After the filters are received from IML, the Technical Specialist will inspect the filters for any damage or unusual conditions then prepare the PM filters for use in the field, including any field or trip blanks. The filters have a 30-day span from the time the filter is tared until it can be used for sampling. The filters are marked with expiration dates and cannot be used for sampling after this date. The specific procedures are outlined in the SOP for PM2.5 and low-volume PM10 sampling. Since IML places the filters in cassettes at the lab, the Technical Specialists will place the filter cassettes into sample magazines in the SCHD AMB lab. The filters are transported to the site locations for the scheduled sampling days. The Technical Specialists will collect the sampled filters according to the procedures established in the SOP for PM2.5 and low-volume PM10 sampling. The SCHD AMB’s goal is to collect the exposed PM samples from the FRM samplers in the field within 96 hours of the sample collection but the sampled filters can remain in the samplers for up to 177 hours. The samples are removed from the samplers in the protective magazines and transferred into a cooler containing frozen ice packs and a thermometer. The cooler with the samples is transported back to the SCHD lab for storage in the refrigerator until shipment to IML every two weeks. The Technical Specialists observe the exposed filters for possible instrument processing or sample handling damage. Any compromised or damaged filters are notated on the respective sample chain of custody. When the Technical Specialists prepare the filters for shipment to IML, the filters which are in the antistatic bags, along with the Chains of Custody and ice packs surrounding the filters are placed inside of the cooler. The filters are securely packed, and the cooler is taped and shipped via UPS Next Day Air Saver. IML will check the temperature of the cooler upon arrival to their lab and document this information on the COC. The SCHD AMB does not include a thermometer in the cooler. The electronic data download and Chains of Custody are emailed by the AMB Supervisor to the Laboratory Supervisor at IML the day the filters are shipped. The electronic copies and copies of the COCs are


retained in the SCHD AMB lab. The IML Laboratory Supervisor will contact the AMB Supervisor if any issues occur during the shipping process. IML will have 10 or 30 days from the end of the sample period to complete the final weigh analyses on the filters. Laboratory analytical holding time is determined by the IML lab analyst based upon the cooler shipment temperature, which is documented by the lab analyst upon receipt at IML. Below is a flow diagram of the post-exposure analysis of the filters that IML adheres to when sampled filters are received in their lab. This information is also provided in IML’s QAPP. IML weigh session information is emailed to the AMB Supervisor in a spreadsheet on a monthly basis. Figure 12-3. IML’s Post-Exposure Analysis Flow Diagram for PM Filters


Following the post-sampling weigh analysis, low-volume PM filters must be kept in cold storage for 1 year followed by storage at room temperature for at least 4 additional years. For the first year, the filters are stored at IML. For the remaining 4 years, the filters are stored at the SCHD AMB lab. After this time frame, the filters will be disposed of if storage is not available. Scheduled PM2.5/PM10 samples may be missed due to a variety of situations including: sampler malfunction, power outages, and filter problems, among others. An adequate number of PM2.5/PM10 measurements are important to maintain a high data capture rate, in accordance with 40 CFR Part 50, Appendices K and N. Specifically, 75% of scheduled samples per quarter are required to show that a site meets the standard. The use of replacement samples or make-up runs is allowed by the EPA to assist monitoring agencies with achieving the desirable data capture goals. The SCHD AMB collects PM2.5/PM10 samples in accordance with the schedule specified in 40 CFR 58.12. The national sampling schedule is established by the EPA each year. The number of make-up samples permitted by the EPA in a calendar quarter is limited to 5 samples. When make-up samples are necessary, the Technical Specialists are required to document the reason the original sample was invalidated. A sample scheduled to run within 7 days of the missed sample run, but after the next regular sample date, may not be considered a valid make-up sample. Ideally, the missed sample should be scheduled before the next sample run or exactly 7 days after the missed sample run.

13.0 Analytical Methods

The equipment required for the AMB network is listed in Table 11-2 of this QAPP. With regards to the gaseous pollutant equipment, the analyzers are designed as completely contained monitoring units that do not require additional analytical methods to establish the pollutants’ environmental concentrations. Similarly, PM2.5 (for AQI reporting with a non-FEM monitor) and PM10 monitoring are also accomplished by means of continuous monitors in the SCHD network. Continuous PM analysis occurs in situ using the TEOM method and does not require any separate analyses in a laboratory. As previously stated, the criteria pollutant monitors/analyzers used within the SCHD AMB network must have a FRM or FEM designation for regulatory purposes. The following appendices of 40 CFR Part 50 can be referenced to find the detailed regulatory method requirements for each of the continuous criteria pollutant FRM and FEM monitors in the SCHD AMB network:

Appendix A-1 – Sulfur Dioxide

Appendix C – Carbon Monoxide

Appendix D – Ozone


Appendix F – Nitrogen Dioxide

Appendix J – PM10 For the NOy sample collection method, the NCore TAD should be referenced.

For filter-based PM2.5 and PM10 (low-volume) sampling, sample collection occurs in the field using a sampler that has been designated as a FRM, but the final sample analysis of the collected filters occurs in the laboratory. The gravimetric analysis of the PM 2.5 and low-volume PM10 filters must also be completed in accordance with the federal reference method. These method requirements for PM2.5 and low-volume PM10 sampling, which include both the field and laboratory (analytical) components, are detailed in 40 CFR Part 50, Appendices L and O. The analytical instrument that will be used for the gravimetric analysis of the FRM PM2.5 and low-volume PM10 samples is the microbalance. The required filter media is a 46.2 millimeter polytetrafluoroethylene (PTFE Teflon) filter. As stated in Section 12.1 above, the EPA supplies the filter media to the monitoring agencies, including the SCHD AMB. The gravimetric laboratory at IML will conduct the gravimetric analysis of the PM samples in accordance with the IML SOP for PM2.5 and PM10 (low volume) sampling and in accordance with the filter weighing requirements specified in 40 CFR Part 50, Appendix L, Section 8 and 40 CFR Part 50, Appendix 0.

14.0 Quality Control Requirements

Quality control (QC) is the overall system of technical activities that measure the attributes and performance of a process, item, or service against defined standards to verify that they meet the stated requirements established by the customer (e.g. data users). In the case of the Ambient Air Quality Monitoring Network, QC activities are used to ensure that measurement uncertainty, as discussed in Section 7, is maintained within acceptance criteria for the attainment of the DQOs. Lists of pertinent QC checks are provided in the standard operating procedures and instrument manuals.

To assure the quality of data from air monitoring measurements, two distinct and important interrelated functions must be performed. One function is the control of the measurement process through broad QA activities, such as establishing policies and procedures, developing DQOs, assigning roles and responsibilities, conducting oversight and reviews, and implementing corrective actions. The other function is the control of the measurement process through the implementation of specific quality control procedures, such as performance and/or systems audits, calibrations, checks, replicates, routine self-assessments, etc. QC procedures for each pollutant type are addressed (and discussed in more detail) in the pollutant-specific SOPs (see Section 11.1). Calculations and formulas related to the


QC checks are defined in the individual SOPs. Associated Excel forms utilized by the SCHD AMB contain these formulas embedded in cells, and generate values for the Technical Specialists immediately. Similarly, EPA’s AQS database provides statistical software that evaluates the DQIs of precision, bias, and completeness, once the SCHD AMB data is uploaded into the database. The SCHD AMB does not post-process monitoring data to “correct” for a failing quality control check. Based upon the calibration data and the validation criteria, the monitoring data is either reported as collected, and appropriately qualified, or the data is invalidated. If an instrument is found to not meet the MQOs, the instrument may require correction actions, including a possible calibration. The following summarizes the QC procedures performed by the SCHD AMB staff. With the exception of visual inspections during site visits and routine maintenance (see Section 15.0), the SCHD AMB does not complete routine QC procedures on meteorological equipment operated in the air monitoring network at this time.

14.1 Quality Control Procedures

14.1.1 Calibrations

Calibration is the process employed to verify and rectify an instrument’s measurements in order to minimize deviation from a standard. This multi-phase process begins with certifying a calibration or transfer standard against an authoritative, NIST-traceable standard. The sampling or analytical instrument’s measurements are then compared to this calibration/transfer standard. If significant deviations exist between the instrument’s measurements and the calibration/transfer standard’s measurements that are beyond the acceptance criteria provided in Tables 7-1 thru 7-8, corrective action is implemented to rectify the analytical instrument’s measurements. This corrective action is in the form of an instrument adjustment. Henceforth, the term calibration will be used to mean adjustment. In general, analyzers are to be calibrated upon receipt, when installed, when physically moved from the current location, and when certain repairs are made. A calibration may be necessary if power is lost for more than 24 continuous hours at a site. The calibration consists of adjustments made to the analyzer at a zero concentration and at an upscale “span” concentration, followed by 3 additional verification points spaced along the calibration scale. The span point is typically performed at 80 - 90% of the calibration scale of the analyzer. In the SCHD AMB, CO analyzers are calibrated on a 0 to 5 parts per million (ppm) calibration scale; O3 analyzers are calibrated on a 0 to 250 parts per billion (ppb) calibration scale; the SO2 analyzer is calibrated on a 0 to 100 ppb calibration scale; the NO/NOy analyzer is calibrated on a 0 to 200 ppb calibration scale and the NO2 analyzer is calibrated on a 0 to 200 ppb calibration scale. Although the


Teledyne API analyzers utilized in the AMB network can operate on a larger range, ambient concentrations in Shelby County have been steadily decreasing in recent years. Because of this decrease in concentrations, the SCHD AMB decided to reduce the calibration scales such that calibrations can occur across a range that is more representative of the pollutant concentrations seen in ambient air. The calibration scales for the NCore precursor CO, SO2, and NOy analyzers have been reduced to capture low-level pollutant concentrations in support of the NCore site’s monitoring objectives, as well. Calibration acceptance criteria include limits on slope and intercept, in addition to percent differences for each concentration point generated during the calibration. These requirements are specified in Tables 7-1 through 7-4 of this QAPP, as well as in the individual pollutant SOPs. Calibrations put the instrumentation in good standing for future data collection. For particulate matter samplers, the calibration is considerably different from that described for the gaseous analyzers. For these samplers, flow rate is adjusted when performing a calibration. The design (targeted) flow rate of low-volume PM2.5 and PM10 samplers, including the TEOM, is 16.67 liters per minute (lpm). After the flow rate has been adjusted – using the procedures described in the respective SCHD AMB SOPs – the flow rate is verified to ensure the calibration is successful. Using a certified flow transfer standard (FTS), the flow rate is measured and a comparison between the known (transfer standard) and the measured (sampler) is calculated using a percent difference. This calibration verification must be within ± 2.1% for the calibration to be successful (see Tables 7-5 thru 7-7). See the appropriate SOP for field QC checks that include frequency and the acceptance criteria and references for calibration and verification tests of sampler flow rates, temperature, pressure, and time. Table 14-1 lists the pollutant, frequency and calibration/verification standard used for each of the pollutants. Table 14-2 lists the authoritative standards used for each type of flow measurement.

Table 14-1. Frequency of Multi-Point Verifications

Pollutant Frequency Name of Calibration/Verification

Standard

SO2 Quarterly API Model 700

CO Quarterly API Model 700

O3 Quarterly API Model 703

NO2, NOy Quarterly API Model 700U, API Model 700

PM2.5, PM10 (low-volume) Quarterly or as needed Flow Transfer Standard, Streamline Pro,

Delta Cal, Tetra Cal


Table 14-2. Authoritative Standards Used For Each Type of Flow Measurement.

Flow Device Primary Standard Frequency of Certification

Streamline Pro Chinook Engineering Yearly

Tetra Cal Mesa Labs Yearly

Delta Cal Mesa Labs Yearly

Other Miller and Weber (thermometers)

Mesa Labs (Definer for high and low flows)

Yearly

14.1.2 Multi-Point Verifications

A multi-point verification is conducted quarterly on gaseous analyzers and consists of 4 upscale points and a zero concentration, similar to calibrations. A multi-point verification is not routinely completed immediately prior to a calibration (adjustment) of the analyzer. A ZPS will be completed prior to a calibration (adjustment) of the analyzer. A multi-point (a zero and 4 upscale points) verification will be done after a calibration of the analyzer. Verifications do not make any adjustments to the analyzer or data, but rather verify (confirm) the analyzer is in good working order, which supports the defensibility of the data collected. For each concentration point, a percent difference is calculated between the known (standard) and the indicated (analyzer) concentrations, and the results are then compared to the acceptance criteria in Tables 7-1 thru 7-4. The slope/intercept is also assessed in comparison to the MQO table requirements to ensure the analyzer’s calibration curve has not drifted. A summary of the multi-point verification points are listed in Table 14-3.

An adjustment (calibration) must be performed if the multi-point verification fails (i.e., exceeds acceptance criteria) and the analyzer itself is determined to be in good working order. Before the recalibration is performed, all typical troubleshooting techniques should be applied to verify the complete system is in good working order (which, in turn, verifies the failed verification is valid).

Invalid QC checks could occur due to several reasons that need attention; therefore, confirming the equipment/calibration system status before proceeding to recalibration can help the Technical Specialists avoid conducting unnecessary calibrations or any incorrect flagging of the data. The situations that could result in an invalid QC check may include, but are not limited to the following:

Faulty zero-air being supplied to the calibrator

Sample/calibration line connections developing leaks


Calibrator problems (malfunction) causing poor concentrations to be produced

Internal electronic problems for the calibration equipment

External weather conditions causing problems, such as excessive humidity

Operator error, including incorrect documentation in logbooks

Table 14-3. Summary of Multi-Point Check Procedures

Points CO (ppm)* O3 (ppb) SO2 (ppb)* NO (ppb)**

1 0.00 0.0 0.0 0.0

2 1.00 50.0 20.0 40.0

3 2.00 100.0 40.0 80.0

4 3.00 150.0 60.0 120.0

5 4.00 200.0 80.0 160.0

*Trace Level ** for NOy/NO2 measurements

14.1.3 Precision Checks

Precision is the measure of mutual agreement among individual measurements of the same property, usually under prescribed similar conditions. In order to meet the DQOs for precision, the SCHD AMB will ensure that the entire measurement process is within statistical control. Various tools will be employed in evaluating and monitoring precision measurements. To evaluate precision, the following checks will be performed for the gaseous analyzers and the particulate samplers.

14.1.3.1 Gaseous Analyzers

One-point QC checks

Pursuant to 40 CFR Part 58, Appendix A, Section 3.1.1, a one-point QC check must be performed at least once every 14 days on each continuous analyzer used to measure the gaseous criteria pollutants. The QC check is made by challenging the analyzer with a QC check gas of known concentration between the prescribed range of 5 and 80 ppb for SO2, NO2, NO, NOy, and O3 and between the prescribed range of 0.5 and 5 ppm for CO analyzers. The statistics of the measured concentrations at our sites indicate that one-point check values larger than 0.5 ppm for CO and larger than 10 ppb for SO2 could not reflect the precision and bias at our routine concentration ranges. The one-point check values (0.5 ppm for CO, 10 ppb for SO2 and 20 ppb for NO) were chosen based on the SCHD AMB measurement data. For trace-level


monitoring at the NCore site, the 1-point QC check concentrations are selected to represent the mean or median concentrations observed at the site. The SCHD AMB performs automated and manual checks. The automated 1-point QC checks are performed nightly for the O3 analyzers, the NOy analyzer at the Shelby Farms NCore site, and for the CO and NO2 analyzers at the Near-Road site. Manual checks are performed weekly at all of the sites. The Technical Specialists typically refer to the automated checks as “auto-cals”, which is referred to in the instrument SOPs. The automated checks which are programed to perform nightly on all O3 analyzers, the NOy analyzer at the NCore site and the CO and NO2 analyzers at the Near-Road site must include a precision measurement but also include another upscale concentration point and a zero (see Table 14-4 and Section 19.1). For each 1-point QC check, a percent difference is calculated, the results of which are compared to the acceptance criteria established in Tables 7-1 thru 7-4, and as specified in the SOPs.

Zero/Precision/Span (ZPS) Checks

These precision checks are performed manually by the Technical Specialists on each gaseous analyzer every 14 days (weekly, if possible) and must include 2 upscale concentration points (precision and span points) and a zero. For the ZPS checks, the percent difference is calculated for each upscale concentration point; each ZPS point must be within the specifications in Tables 7-1 thru 7-4 for the check to pass. The calculation for the precision measurement (i.e., percent difference) is found in 40 CFR Part 58, Appendix A, Section 4.1.1. Table 14-4 provides a summary of the precision and accuracy procedures.

Precision checks (1-pt QC and ZPSs) verify (confirm) the analyzer is in good working order, and, therefore, support the defensibility of the data.

A calibration must be performed if the 1-point QC check or ZPS fails and the instrument is found to be in good working order. Normally, if either of these checks fail, there is a problem within the monitoring system that needs addressing (i.e., results in equipment maintenance and/or repair). If the zero check or span check exceed the specifications in Tables 7-1 thru 7-4 then a calibration will be done after the equipment failure is diagnosed, repaired, and the instrument is cleared for normal operation. However, if a typical slow drift causes the check to fail, no routine maintenance may be necessary. It simply indicates the analyzer needs recalibrating. The SCHD AMB does not adjust ambient concentration data to correct for zero drift. If the investigation determines the analyzer is at fault, then the data will be invalidated based on the failed check, including failed zeros.


Note: The SCHD AMB does not post-process monitoring data to “correct” for a failing QC check. Based upon calibration data and validation criteria, monitoring data is either reported as collected, and appropriately qualified, or the data is invalidated. Table 14-4. Summary of Precision & Accuracy Procedures

CO (ppm) O3 (ppb) SO2 (ppb) NO

(NOy)/NO2 (ppb)*

Purpose

Zero 0.00 0.0 0.0 0.0/0.0 Identify drift

1-point QC Concentration

0.50 70.0 10.0 20.0/50.0 Precision

check

Span Concentration

3.00 160.0 70.0 140.0/140.0 Accuracy

check

Frequency

Nightly at Near-Road

and Weekly at Near-Road and NCore

Nightly and

Weekly Weekly

Nightly and Weekly

* Produce NO2 gas using GPT process

14.1.3.2 Particulate Samplers

Flow Rate Verifications

In accordance with 40 CFR Part 58, Appendix A, Sections 3.2 and 3.3, a one-point flow rate verification check must be performed at least once every month on each sampler used to measure PM2.5 and low-volume PM10. In the SCHD AMB network, the goal is to complete these flow verifications weekly. The verification is made by checking the operational flow rate of the sampler. If the verification is made in conjunction with a flow rate adjustment (calibration), it must be made prior to the adjustment. The flow rate of the transfer standard is compared to the flow rate measured by the sampler. The percent difference between the flows indicated by the monitor and certified check device is calculated and the results are compared to the acceptance criteria in Tables 7-5 thru 7-8 of this QAPP, as well as in the SCHD AMB PM2.5 and low-volume PM10 and TEOM SOPs. The percent difference is also calculated between the design flow rate of the sampler (i.e., 16.67 LPM) and the flow rate measured by the certified check device during the check for PM2.5. These QC checks verify (confirm) the particulate sampler remains in good working order and, therefore, support the defensibility of the data.


In addition to the QC checks performed by the Technical Specialists, precision is also determined in the SCHD AMB network by employing collocated PM2.5 samplers. The SCHD AMB collocates PM2.5 samplers, as discussed in Section 6.0, and operates them in accordance with the schedules codified in 40 CFR 58.12. Currently, the primary sampler is set to a 1-in-3 day sampling schedule and the collocated sampler is set to a 1-in-6 day sampling schedule. For the precision estimate, data pairs are considered valid if both concentrations are greater than or equal to 3 µg/m3. The precision data is aggregated quarterly, annually, and at the 3-year level, and compared to the requirements in Tables 7-5 and 7-6 of this QAPP.

Note: Regulations do not require gaseous analyzers to be collocated.

Quality Control Samples

Collecting field blanks is required under 40 CFR Part 50, Appendix L, §8.3.7.1. As such, the SCHD AMB will collect field and trip blank samples as a QC check for the PM2.5 and low-volume PM10 samplers. A field blank is a filter that is pre-weighed with routine samples, installed in the field sampler without any flow passing over the filter, re-weighed with routine samples, and then initial/final weights compared. The purpose of field blanks is to provide an estimate of total measurement system contamination, including laboratory and field activities. Through a comparison of laboratory blanks against field blanks, contamination from field activities can be assessed. The acceptance criterion for field blanks is ±30 µg between weighings. Field blanks are to be collected in the SCHD AMB network at a frequency of ~10% of the sampling runs scheduled per site. For example, for a sampler operating on a 1-in-6 day operating schedule, 6 field blanks would be collected over the course of a year. Field blanks are taken throughout the duration of the sampling schedule (spaced evenly across the year) and not concentrated in a short period of time.

As an additional QC check, the SCHD AMB will also collect trip blank filters. Collecting trip blanks is not a requirement under 40 CFR Part 50, Appendix L; however, collecting trip blanks is a best practice. A trip blank is a filter that is treated exactly as a field blank, but it is never placed into the sampler or exposed to the ambient environment. The purpose of the trip blank is to assess possible contamination to filters during packing and transport to and from the laboratory to the sampling location. The acceptance criterion for trip blanks is ±15 µg between weighings. If the weight change exceeds 15 µg, contamination in the laboratory or during shipping may be occurring. As with field blanks, trip blanks are collected in the SCHD AMB network at a


frequency of ~10% of the sampling runs. A trip blank will be taken to the station after each 8th regularly-scheduled field sample is collected.

Field blanks and trip blanks are used from the allotment of filters shipped every two weeks from IML.

14.1.4 Accuracy and Bias Checks

Accuracy is defined as the degree of agreement between an observed value and an accepted reference value. Accuracy is a combination of random error (precision), and systematic error (bias). Although collocated monitors are primarily used for evaluating and controlling precision, they can also be used to determine accuracy or bias. By employing percent difference calculations and monitoring patterns of collocated PM2.5 samplers, viewing the plots of the data generated on the data management system AirVision, trends can be observed that indicate bias occurring within the measurements. These measurements (using flow rates in lieu of concentrations, obtained during flow rate verifications) are used to assess the bias as described in 40 CFR Part 58, Appendix A, Section 4.2.2. In addition to collocated monitors, ZPS checks can also provide data capable of identifying bias. Performance audits are also an indicator of accuracy/bias and are discussed below.

14.1.5 Performance Evaluation (PE) Audits

Audits are performed by comparing analyzer or sampler measurements to independent standards (or references). The standard used for auditing must not be the same standard used to calibrate the analyzer. However, both the calibration standard and the audit standard can be referenced to the same primary standard. Personnel conducting audit procedures should be designated staff that is not normally involved in routine operational activities of equipment that is under evaluation. In the SCHD AMB network, the AMB Supervisor and Lead Technical Specialist use dedicated, independent audit equipment to conduct the performance audits on the network equipment if an external independent contractor is not available.

The requirements and frequency for performance audits are specified in 40 CFR Part 58,

Appendix A. In general, for the gaseous analyzer audits, the audits are required annually per Section 3.1.2 of Appendix A. The SCHD AMB’s goal is to conduct these audits quarterly, as a way of ensuring continued compliance with EPA QA requirements and ensuring the quality of data produced. For NCore, audits may be at levels 1 and 2 to challenge the trace-level accuracy of the instrumentation. For low-volume particulate samplers, performance audits are discussed in Sections 3.2 and 3.3 of Appendix A for PM 2.5 and PM10, respectively. In general, these flow rate audits are to be performed twice per year, with the audits spaced, ideally, between 5-7 months apart. Like the


gaseous analyzers, the SCHD AMB’s goal is to conduct these flow rate audits every quarter. Performance audit acceptance criteria may be found in Tables 7-1 thru 7-8.

14.1.6 External Agency Audits

The SCHD AMB participates in performance audits from multiple organizations (see Table 6-1 for information regarding the frequencies of such audits):

SCHD AMB participates in the EPA Performance Evaluation Program (PEP) and the EPA National Performance Audit Program (NPAP). Information on EPA’s Performance Evaluation Program, including PEP and NPAP, can be found at: http://www.epa.gov/ttn/amtic/npepqa.html

Environmental, Engineering and Measurement Services, Inc. (EEMS)

The Tennessee Department of Environment and Conservation

14.1.7 Corrective Actions Corrective action measures within the network are taken as necessary to ensure the MQOs are attained. Given the number of monitors, the diversity of monitoring activities, and the complexity of the instruments, there is a potential that issues may arise with the air monitoring measurement systems. In a properly functioning monitoring network, issues may be anticipated in advance and staff should be prepared and equipped to address issues as they arise.

Corrective actions may also be implemented on an “as-necessary” basis when unexpected or unforeseen circumstances are encountered, such as a failed QA/QC check. The SCHD AMB SOPs, which are in progress, contain examples of corrective actions that may need to be completed under certain circumstances. The Technical Specialists should consult the appropriate pollutant-specific SOP for technique-specific checks, required frequency of checks, acceptance criteria, and additional corrective action guidance.

15.0 Instrument/Equipment Testing, Inspection, and Maintenance Requirements

Preventative maintenance is a foundational element to an effective QA program. Any maintenance or repair is performed at the AMB office lab or at the monitoring station. This work is performed by the Technical Specialists. However, as discussed in Sections 4 and 8, staff is strongly encouraged to share knowledge and equipment experience, such that the SCHD AMB continuously maintains these imperative technical skills. With that in mind, these equipment maintenance responsibilities are shared, to some degree, amongst all AMB staff.

http://www.epa.gov/ttn/amtic/npepqa.html


The SCHD AMB uses established procedures to verify that all instruments and equipment are maintained in sound operating condition and are capable of operating at acceptable performance levels. Refer to the specific instrument SOPs (see Table 11-1) for more details on the specific preventative maintenance activities. In general, the following acceptance/testing activities are performed upon receipt of new analyzers and samplers, and/or after an analyzer/sampler has undergone significant repair. If the equipment is new and fails to meet the field readiness certification described below, the vendor will be contacted.

Verify that the instrument contains its EPA equivalent or reference method decal and meets the specifications of the purchase request.

Verify that all expected parts arrived with the instrument and that nothing is physically broken. Contact the vendor if there are issues.

Perform field readiness “certification” testing, summarized as follows. Although the designation of the FRM/FEM status ensures the make/model of the instrument meets EPA requirements for use in a SLAMS network, the SCHD AMB staff must still ensure individual instruments perform as expected before deployed in the field.

For the gaseous analyzers (At this time, the SCHD AMB has not yet performed MDL studies of precursor gas analyzers operated at the NCore site as stated in the NCore TAD and has relied on the manufacturers’ MDLs. Moving forward, the SCHD AMB will look into implementing an MDL study of such analyzers.)

o Check and document the diagnostics of the analyzer, looking for any fault lights or warnings. Ensure that parameters such as sample flow rate, pressure, temperatures, and so forth are within specifications (see user manuals). Perform a leak check(s) on the analyzer.

o Perform verification check(s). Generate a zero concentration, followed by 4 upscale concentrations across the calibration scale of the analyzer, as would be completed for a typical multi-point verification. For example, for O3, this test would include 0, 50, 100, 150, and 200 ppb concentrations. If all points fall within the acceptance criteria (see SOPs), the analyzer is deemed “field ready”. If any point fails, the verification fails, and troubleshooting has to be done. A field logbook will be used to document the results of the testing. This field logbook will travel with the instrument until the logbook is completely filled at which time it will be archived at the SCHD AMB office.

o Allow the analyzer to run in its normal sampling mode in the lab for several days before deployment.


For particulate samplers:

o Check the diagnostics of the sampler, looking for any fault lights or warnings, and document the status.

o Check, and if needed, calibrate the temperature and pressure sensors. o Perform flow rate checks and make sure they fall within the acceptance

criteria (see Tables 7-5 thru 7-8). o Run the intermittent particulate sampler in the lab for a short period of time

(e.g., ~ 1 week) and track the sampler’s operational performance. For example, these tests confirm the functionality of the filter exchange mechanism in the sampler and verify that the software is working appropriately. For continuous particulate samplers, the sampler is run in the lab (~1 week) and the ambient concentration values are observed. They should be low (as this is indoor air) and track steadily.

o After this testing in the lab, the sampler is deployed to the field where final testing is performed. The sampler is “run” in the field, collocated with the existing particulate sampler on site for multiple days. (Note: The ambient data produced by the test sampler is not reported to AQS). The results between these two samplers are compared; if acceptable, the data collection can officially begin.

o The testing information and any diagnostics or troubleshooting performed are documented in a field logbook for each particular piece of equipment. This field logbook for the equipment travels with the instrument until the logbook is completely filled at which time it will be archived at the SCHD AMB office.

If an instrument has undergone significant repair and fails to meet the field readiness

certification (testing), the vendor will be contacted. If after working with the vendor, the instrument cannot be repaired such that it passes performance testing, then the instrument will be returned (if under warranty) or shelved (i.e., discontinued from service, if the warranty has expired). If the instrument is inoperable, it will be tagged and will be used for spare parts. If the instrument that was shelved and tagged was a back-up instrument, then the process will begin to purchase a new instrument to replace that back-up. This will allow a spare instrument to become available when needed. The spare equipment is inspected and tested in the SCHD AMB laboratory upon arrival and stored in the laboratory until it is ready to use. Any findings of the new equipment will be documented in a logbook created for this specific piece of equipment. This logbook travels with the instrument until it is completed and archived. In general, the following inspection activities are used:

Monitoring shelters, sample inlets, and other enclosures are inspected quarterly to ensure conditions do not adversely affect monitor operation or


data integrity. This information is documented in the field logbook and on a weekly QC form.

Data collection and data quality is reviewed each business day and trends are inspected for signs of problems. Data trends that signal inspection would include such issues as frozen numbers for multiple consecutive hours, or erratic spikes or valleys in the concentrations obtained.

Inspections on equipment also occur during site visits to verify the entire system is in good working order. Site visit checklists are available to the Technical Specialists and on the QC check forms.

The shelter temperature probe is verified against a NIST-certified source at least once a month and during quarterly QA audits. Any deviations are immediately recorded, reported to the AMB Supervisor, and corrective action is initiated to resolve the deviation. Any issues should be documented and filed in the site logbook and QC form.

Weekly inspection of the sample inlet funnel manifold for obstructions

Monthly replacement of particulate in-line gaseous analyzer filters

Weekly observations of cylinder gas remaining

Monthly general interior cleaning

Weekly check of the ambient sample line for cleanliness and moisture

Weekly check that the grass has been cut around the site

Annual replacement of the inlet tubing

Servicing the zero air supply and pump as needed

Replacing charcoal scrubbers annually or more often as needed

Replacing desiccant materials monthly or when the color has changed from orange to clear/white

Biannual replacement of wind sensor bearings

All information is documented in the site logbooks and the weekly QC forms.

With regard to routine maintenance, the following are general protocols:

A limited supply of critical spare parts is maintained in the SCHD AMB lab to aid in response to repair issues. For example, pump rebuild kits, spare pumps, o-rings, photometer lamps, filters, ozone scrubbers, and Teledyne API expendable kits are routinely on hand.

Preventive maintenance is scheduled ahead of time, so all parts/tools can be easily available to complete the tasks so data loss is kept at a minimum.

Preventive maintenance activities are typically performed in the field, although some activities are completed in the AMB lab.

The routine preventive activities and schedules are detailed in the specific equipment SOPs and supplemented by the equipment operator manuals. Particulate filters located behind the analyzers are generally changed monthly, followed by a post-maintenance


check. All particulate matter inlet heads, down tubes and very sharp cut cyclones (VSCCs) are serviced according to the frequencies prescribed in Tables 7-5 through 7-8 or sooner depending on the cleanliness. All gaseous equipment, including analyzers, calibrators, and zero air supplies, undergoes a comprehensive annual preventive maintenance regimen (detailed in the SOPs). Two Teledyne API 701H zero air generators are used as zero air sources at the NCore site. Since all high sensitivity analyzers at the NCore site are set at lower ranges, the SCHD AMB requires that the lower detectable limits of these analyzers are 0.2 ppb for SO2, 0.6 ppb for O3, 0.10 ppb for NO and 40 ppb for CO. An independent zero air source (Teledyne API T751H) is compared quarterly with these two zero air generators to test their zero air quality. IML will maintain their lab equipment according to their Quality System documents.

Follow-Up Actions

The AMB Supervisor or a member of Management will be informed of any problems or issues that could affect the data. The Technical Specialist will correct the problem and notify the AMB Supervisor that the issue has been corrected by completing a Corrective Action Form (Figure 21-1). The AMB Supervisor will confirm that the corrective action was completed appropriately by reviewing the documentation on the Corrective Action Form and reviewing the data in AirVision. The AMB Supervisor will determine if flags should be applied to any affected data and apply the appropriate flags.

16.0 Instrument Standards, Certifications, and Frequency

Calibration is defined as the comparison of a measurement standard, instrument, or item with a standard or instrument of higher accuracy to detect and quantify inaccuracies and to report or eliminate those inaccuracies by adjustment. Use of the term “calibration” indicates that an adjustment either in the instrument or the software occurred. The EPA recommends that adjustments be minimized to prevent introducing measurement uncertainty and that verifications (i.e., checks without correction (adjustment)) be used to confirm whether or not an instrument is operating within its acceptance range. Thus, the purpose of calibration is to minimize bias. Calibrations are discussed in more detail in Section 14.1.1 of this QAPP. Calibration procedures for each specific pollutant analyzer/sampler are described in the applicable SCHD SOP. (see Section 11.1) 40 CFR Part 58, Appendix A, §2.6 requires that gaseous standards (i.e., gas cylinders), photometers, and flow rate standards used in the ambient air monitoring network be traceable to the National Institute of Standards and Technology (NIST). As such, instrument calibrations performed in the SCHD network are conducted using traceable standards to ensure that the ambient air quality data meets the SCHD AMB and the EPA quality objectives.


Traceable is defined in 40 CFR Parts 50 and 58 as meaning that a local standard (i.e., one maintained by a monitoring organization) has been compared and certified, either directly or via not more than one intermediate standard, to a primary standard such as a NIST Standard Reference Material (NIST SRM) or an EPA/NIST-approved Certified Reference Material (CRM). Similarly, traceability is the property of a measurement result whereby the result can be related to a stated reference through a documented unbroken chain of calibrations, each contributing to the measurement uncertainty. Standard traceability, therefore, is the process of transferring the accuracy or authority of a primary standard to a field-usable standard, resulting in a documented unbroken chain of calibrations/certifications. Recommended timeframes for certifications of the various calibration standards used in the SCHD AMB network are defined in Tables 7-1 thru 7-8 of this QAPP and within the SCHD AMB SOPs. To achieve and ensure traceability, the SCHD AMB adheres to the following principles:

Most standards used for calibration are purchased and re-certified by vendors with accredited NIST-traceable calibration processes. Devices are re-certified at least annually. Records of these certifications are located in a 3-ring binder notebook located in the SCHD AMB lab and on the Air Monitoring Branch S: drive for access by all SCHD AMB staff.

Primary and transfer standard calibration certificates are retained as part of the QC documentation process (see Section 9 of this QAPP).

Where applicable, in-house certification procedures (i.e., certifying a transfer standard against a certified primary standard – i.e., one of a higher authority) are performed using the SCHD SOPs. Documentation of these procedures is maintained in the monitor logbook, on QC forms, and on the Air Monitoring Branch S: drive.

Documentation exists that provides a documentation trail that links all SCHD AMB calibrations back to NIST. The following summarizes the standards used in the SCHD AMB network and their recertification process. All certification periods are monitored to ensure that equipment or certified materials are not used beyond the documented certification expiration dates. Tracking these certifications – those performed in-house, as well as those performed by vendors – is the responsibility of the Lead Technical Specialist. However, the certifications are performed by the Technical Specialists and Lead Technical Specialist. This shared responsibility ensures redundancy in skill sets and knowledge and ensures the continuity of operations in case of unexpected turnover.


16.1 Ozone Transfer Standard

The SCHD AMB’s Level 2 ozone transfer standard is compared to the Standard Reference Photometer (SRP # 10) located at the EPA Region 4 laboratory in Athens, GA annually. The SRP is the highest-authority ozone standard, equivalent to NIST, and is considered a Level 1 standard. The EPA maintains SRPs to set the standard for all ambient air O3 measurements made nationwide. The bench reference or Level 2 standards serve as the NIST-traceable reference instruments for all ambient air O3 measurements made by the SCHD AMB. The SCHD AMB currently has one analyzer that serves as the bench standard or Level 2. This Level 2 is a Teledyne Advanced Pollution Instrumentation (API) T400. All site/field or Level 3 calibrators (Teledyne API 700, 700EU or T703) are certified against the Level 2 in the AMB lab every quarter. These certifications are performed by the Technical Specialists and Lead Technical Specialist. The SCHD AMB also has a Teledyne Advanced Pollution Instrumentation (API) T750U gas dilution calibrator and T751H zero air generator used to perform independent audits if quarterly audits are not able to be performed by TDEC or EEMS. The Teledyne API T750U is verified against the Level 2 quarterly by the AMB Supervisor, Lead Technical Specialist or Technical Specialists.

16.2 Flow Rate Standards

The SCHD AMB uses multiple types of flow standards within the air monitoring program (e.g., DeltaCal with temperature and barometric pressure sensors, Definer, TetraCal with temperature and barometric pressure sensors, or Streamline Pro). These devices are certified annually by an accredited organization or the manufacturer that provides a certificate of traceability to NIST standards. It is the SCHD AMB’s policy to rotate the certifications of the flow standards when sent to vendors, so that a certified device remains available in-house at all times.

Currently, the SCHD AMB uses the Definer 220 High Flow and Definer 220 Low Flow as the local primary flow standards. These devices are used to perform the certifications of the mass flow controllers in the site/field gas dilution calibrators (see Table 11-2). This certification is performed in the SCHD AMB lab quarterly by the Technical Specialists or Lead Technical Specialist. The devices have the advantage of providing volumetric flow rate values directly, without requiring a conversion for mass flow measurements, temperature, pressure, or water vapor content. A calibration relationship for the flow rate standard, such as an equation, curve, or family of curves, is established by the manufacturer (and verified if needed) as accurate within ±2% over the expected range of ambient temperatures and pressures at which the flow rate standard is used.


The SCHD AMB has independent flow transfer standards (Mesa Labs TetraCal, Mesa Labs Definer 220H, Mesa Labs Definer 220L, an independent zero air generator Teledyne API T751H, and an independent gas dilution calibrator Teledyne API T750U) used for independent SCHD audits, when necessary. The TetraCal and Definer Standards are sent to the manufacturer MesaLabs annually for certification. The gas dilution calibrator is certified in the SCHD AMB lab by the Supervisor, Lead Technical Specialist or Technical Specialists against the Definer flow meters quarterly. The independent zero air generator is maintained and checked annually under the guidance of 40 CFR 53.20 and 40 CFR 53.23 and verified quarterly by comparing with other zero air generators.

16.3 Temperature Standards

The SCHD AMB maintains NIST-traceable digital or PerformaTherm blue liquid thermometers which are used to verify shelter temperature probes. These thermometers are returned to the vendor annually for recertification against a NIST-traceable standard.

16.4 Gas Protocol Standards

The SCHD AMB purchases commercially prepared EPA Protocol Gas from contracted vendors for use in the field for the gas dilution calibrators and the independent audit calibrator. All cylinders are directly traceable to NIST reference standards and contain a known concentration of carbon monoxide, sulfur dioxide or nitric oxide gases. The concentration of the cylinder is documented on the cylinder’s label, as well as on the cylinder’s certification of analysis document. While the certification of a Protocol cylinder is usually valid for years, the gas use demand at a site may require more frequent replacements. The cylinders of gases should contain the following information:

Cylinder serial number

Gas (CO, NO, or SO2) concentration

Recertification status

Gas type

PSI (the EPA recommends cylinder replacement at 200 psi)

Impurity

Expiration date

See Tables 14-1 and 14-2 for the list of calibration, standards and frequency of certification.


16.5 Other Devices

A voltage multi-meter, such as the Fluke 87-5, is used for data logger certifications, and is certified annually by the vendor. The vendor will provide a certificate of traceability to NIST standards. An atomic clock is used as a primary time standard. This clock is verified with the WWV NIST atomic clock in Boulder, CO. Note: The calibration/certification of laboratory standards for the PM2.5/PM10 (low-volume) program are the responsibility of IML. The microbalance, mass reference standards, and other laboratory standards will be certified in accordance with IML’s QAPP and SOP. These devices are typically certified on an annual basis.

17.0 Inspection/Acceptance of Supplies and Consumables

The SCHD AMB’s SOPs (see Section 11.1) itemize the apparatus, equipment, materials, and supplies required for various monitoring equipment. In general, supplies and consumables are procured directly from the vendor manufacturing the analyzers/samplers used by the SCHD AMB. Parts lists, including recommended replacement schedules, are itemized in most manufacturers’ operating manuals as well. The SCHD AMB uses this information to determine the appropriate procurement schedule and volume of consumables required to support continuing operations. Supplies and consumables (such as TEOM and gas analyzer in-line particulate filters) are tracked by the Technical Specialists. When replacements are needed, a Purchase Request is submitted to the AMB Supervisor by the Technical Specialists. A requisition is completed by the AMB Supervisor and submitted to the PCS Management for approval. This will then be forwarded to the Purchasing Department for processing. Supplies are inventoried in the AMB lab for later distribution. The received materials are inspected by the Technical Specialist who requested the parts to ensure the proper part number was received as ordered. General inspection to identify any damaged products is also performed. Parts received are dated so that storage duration can be easily determined. A revolving inventory system (first in, first out) is used to ensure that storage times do not affect the material’s integrity. If a manufacturer or the EPA requirement indicates a specific expiration period for supplies, those supplies exceeding the expiration dates are discarded if not used within the acceptable period. Sample lines and fittings are important supplies. If used in the sampling train of a reactive gaseous analyzer, they must be FEP Teflon or equivalent. Air sampling filters used to collect PM2.5 and PM10 (low-volume) samples are also considered supplies. Filter handling, conditioning, and integrity is of primary concern. The EPA provides vendor lot certification of filters used to support the ambient air quality monitoring


programs prior to distribution to monitoring organizations. These filters are shipped to IML for inspections and conditioning. Filters that do not meet the initial quality control specifications are removed from service. A consumable that is critical to the successful operation of the gaseous monitoring network is that of gas cylinders used for calibrations and QC checks of SO2, CO, NO, NOy, and NO2 analyzers, as well as gas cylinders used for conducting internal performance audits, when necessary. The gas cylinders ordered by the SCHD AMB are EPA Protocol Cylinders. Certificates of Analyses are reviewed upon receipt of new gas cylinders to ensure the cylinder meets purchase specifications. The certificates indicate the expiration date of the gases contained within the cylinders. The SCHD AMB abides by these expiration dates. The dates and usage are tracked on the QC check forms. The cylinders will be replaced before they expire or when the pressure is lower than 300 psi. Note: In general, calibrations, QC checks, or performance audits conducted with expired gases would not be considered valid calibrations or QA/QC checks, unless compelling, empirical evidence was available to justify using the expired cylinders. Otherwise, the data from such checks would not be used for data validation purposes.

18.0 Non-Direct Measurements

This section addresses data not obtained by direct measurement from the Ambient Air Quality Monitoring Program that may be used to support the monitoring program. This includes data from outside sources and historical monitoring data. Possible databases and types of data and information that might be used include:

Chemical and physical properties data

Sampler manufacturers’ operational literature

Geographic location data

Historical monitoring information

Traffic Count Data

Census Data

Speciated particulate data

National Weather Service data

Any use of outside data will be quality-controlled and documented to the extent possible following QA procedures outlined in this document and in applicable EPA guidance documents.

19.0 Data Management

The primary work product of the SCHD’s Ambient Air Quality Monitoring Program is data. Accordingly, formalized procedures are required to ensure successful data


management. Data management describes an inter-related set of standardized processes used to acquire, transmit, transform, reduce, analyze, store, and retrieve data. When documented and followed, a data management system helps maintain the integrity and validity of the data throughout its entire life cycle. The SCHD AMB’s air monitoring data follows a documented flow path. The data life-cycle starts before sample collection actually begins and ends with the use of the data. The major components of the SCHD’s AMB data management process are summarized here.

The following sections will identify the processes and procedures that are to be followed to acquire, transmit, transform, reduce, analyze, store, and retrieve data. These processes and procedures will maintain the data integrity and validity through application of the identified data custody protocols. Figure 19-1 provides a flow chart of the quality control procedures for the SCHD AMB. Figure 19-1. Quality Control Flow Chart


19.1 Data Transformation

The inherent accuracy of an instrument is incorporated into the system accuracy when the instrument is calibrated. Each pollutant-monitoring instrument has its own internal potentiometers, whether digital or analog, adjusted to accurately reflect the concentration at which the instrument is tested. Each instrument is assumed to be linear within the range of 10% to 90% of full scale. At a minimum, all instruments measuring gaseous pollutants must undergo a 14-day 1-point quality control check to maintain accuracy. The SCHD AMB performs these checks on a weekly basis. All PM instruments (continuous and intermittent) undergo at least a 30-day flow verification check to maintain accuracy. External leak checks, ambient sensor and clock verifications are performed to coincide with the flow verification checks. All ozone, NOy, NO2, and CO (i.e., at the Near-Road station) analyzers run nightly automated zero-precision-span sequences that can be remotely viewed to ensure correct operation.

19.2 Data Collection and Recording

Ambient air monitoring analyzers and samplers which have been designated by the EPA as reference or equivalent methods (FRMs or FEMs, respectively) will be used to collect the criteria pollutant data in the SCHD AMB network used for NAAQS compliance. Non-FEM analyzers will also be used to collect NOy data as part of the NCore monitoring requirements. Upon installation and at regular intervals as specified, ambient air monitoring instrumentation is calibrated in accordance with the SCHD AMB’s SOPs (see Section 11.1). Calibration of the analyzer or instrument establishes the quantitative relationship between the actual value of a standard, whether it’s a pollutant concentration, a temperature, or a mass value, and the analyzer’s response. The relationship is used to convert subsequent analyzer response values to corresponding concentrations. Each pollutant monitoring instrument has internal adjustments. During the calibration process, the settings are adjusted to accurately reflect the concentration at which the instrument is tested. Instrument output is transformed from measurement engineering units to pollutant concentrations either by the instrument itself, the data logger, the data management system, or a combination of these elements. The end result is the reporting of the pollutant concentration data in the unit specified in the appropriate SOP. Continuous monitoring sites and non-continuous instruments (i.e., particulate samplers) are equipped with data recording capabilities. The data logging function may be internal to the monitoring instrument (e.g. PM2.5 2025i samplers) or an external device (i.e., Agilaire 8832 data logger and a site computer with AirVision Trend) connected to the instrument (e.g., continuous analyzer). The data logger records the monitoring instrument outputs. It may also perform specific data reduction and/or format data in


preparation for downloading to the data management system AirVision. AirVision is located on its own individual server housed at the Information Technology offices. The server is maintained and backed up nightly by the Information Technology staff. Manual data collection consists of transferring PM2.5 and PM10 (low-volume) sampler data to the office and recording results of the weekly QC checks. For the weekly QC checks, the response of the continuous analyzers is captured by the site data loggers and can be seen or retrieved using the AirVision software. When independent SCHD audits are performed, the results are documented by the AMB Supervisor or Lead Technical Specialist on a QC check form and also documented in the site logbook. Also, the diagnostics of the analyzers are recorded in the site logbook and on the QC check forms. For the intermittent particulate matter samplers, all data capture is either recorded manually or downloaded to a flash drive. Care must be taken in order to ensure all data that is recorded manually is accurate and complete. The manual data calculations are checked by the Supervisor when the weekly QC check forms are submitted.

19.3 Data Reduction Data reduction occurs throughout the data management process. An analyzer is scanned by a data logger once per second. Each block of sixty, one-second readings are then averaged (or reduced) to produce one-minute averages, which is the base-unit stored by the data logger. The data logger further processes the minute data to produce one-hour averages, as well as 5-minute averages. The air monitoring site’s data logger stores the hourly and five-minute averages from each monitor and transmits them (in response to a poll) via the Ethernet connection to the data management system AirVision. Filter samples are physically measured by a laboratory and mathematically reduced into weights (i.e., mass measurements), and then into weights per unit volume, once the analytical data is combined with the field sampling data. This is calculated by IML and emailed to the SCHD AMB Supervisor in a data package every 30 to 60 days. Ultimately, the data reduction activities aggregate raw data into averages that are required to compare against the NAAQS criteria pollutant limits (see Section 7.1.2). These values obtained from reducing these data sets establish whether or not the NAAQS have been exceeded. Technical Specialists provide the quality control check forms from the instruments. The quality control check forms are reviewed by the AMB Supervisor and Lead Technical Specialist and an unedited version of the monthly report is generated from the data management system. The quality control check forms are reviewed and data is validated or invalidated according to the data sets. Flags indicating the validity of the data are provided with each data point.


The AMB Supervisor reviews the data sets for invalid data flags. If the data are deemed invalid, they are disqualified from the data set, and consequently, not used in the calculation. Criteria for the quantity of valid data points required within a data set are defined in the appendices to 40 CFR Part 50 and in Table 10-3 of this QAPP. These criteria are adhered to when performing the data reduction operations. Retaining copies of all data sets electronically recorded provides a data audit trail. These data sets are archived on backup systems in addition to being retained on computers.

19.4 Data Transmittal Data transmittal is accomplished using wired internet or dial-up modems to access the sites’ modems, which are linked to the data logger. Downloading of collected data does not delete the data from the data logger. Data are removed from the data logger continuously by overwriting data on a first-in, first-out basis. This configuration requires that the data be extracted from the data logger on a regular basis, thus preventing any loss of data. If communication problems arise, the data will have to be retrieved either by going to the site and directly accessing the data logger, or retrieving the data remotely once the communication problems have been rectified. A site visit is mandatory if the communication problems are not expected to be corrected in time to prevent data from being overwritten. AirVision Trend, which is located on the site computers, is used to simultaneously record the analog output of the particular pollutant analyzer/monitor. This allows the Technical Specialists to view the real-time data and is used to augment the data integrity and to verify suspect data points in the digital database. AirVision is configured to poll the stations hourly to retrieve the data for analysis. The O3 and PM2.5 (TEOM) data is submitted to the AIRNOW site hourly via a file transfer protocol (FTP) link. This information can be used for forecasting purposes. The transmittal of intermittent particulate sampler data from the field to the SCHD AMB office by the Technical Specialists is accomplished through the use of external storage devices (i.e., hand-held flash drives) or manual documentation on a field data chain of custody. Data is downloaded directly from the sampler to the external storage drive or recorded onto the field data chain of custody. This information is transported to the office and uploaded onto a PM file database. This data represents the results of the field sampling run. However, the physical sample that is collected by the PM2.5 or low-volume PM10 sampler must be analyzed by IML. Therefore, analytical data is produced at a separate facility (IML) and maintained using the data management system at that location. The results of the gravimetric analysis, along with the pertinent laboratory and conditioning data, are later provided by the gravimetric laboratory to the SCHD AMB


Supervisor in the form of an Excel spreadsheet. Data from the spreadsheet are then stored on the S: drive by the AMB Supervisor and reviewed before being combined with the field data for subsequent data reduction, verification and validation processes. All transmitted raw data sets are stored electronically. The DAS is designed to prevent alteration of the raw data file. Raw data sets are retained in unalterable form before any reduction or validation is performed. Data validation operations (e.g., AirVision database) use replicate versions of the raw data to avoid violating the integrity of the original raw dataset. Data stored in the “edit” database can be added, changed, flagged, or voided. An edit history is recorded and available to track changes made to the editable database.

19.5 Data Verification and Validation

Each analyzer or sampler used to measure ambient pollutant concentrations undergoes precision and bias checks on a prescribed frequency, in order to verify the instrument’s calibration. Together with performance evaluations and QC checks as described in Section 14.1 of this QAPP, the precision, bias, accuracy, and repeatability of each instrument can be ascertained. The Technical Specialists verify the data collected when reviewing the graphs from AirVision Trend throughout the sample collection process. Data verification also occurs when the Lead Technical Specialist and AMB Supervisor review the monthly report for a specific pollutant from AirVision during data validation. The data generated by the continuous instruments are stored on-site in the data logger. When the data are accessed through the Ethernet connection via the Shelby County network, they are downloaded to a database (AirVision) where they will undergo verification, reduction, and analysis. Data verification is performed by the AMB Supervisor and Lead Technical Specialist electronically by searching the data for status flags and comparing reported values to criteria that identify whether the data are within acceptable range criteria. Once data have been flagged as questionable, the AMB Supervisor and Lead Technical Specialist evaluate the associated data to identify underlying causes and make the decision whether the data are valid. If the data are invalid, they are not used in calculations. If the data are valid, but flagged due to some extenuating circumstances, then the data will be used in calculations, accompanied by a comment documenting the situation.

19.6 Data Analysis

Data is analyzed periodically throughout the data collection and validation process. It is the responsibility of the AMB Supervisor to certify data collected within a calendar year


as usable for NAAQS comparisons. The SCHD AMB relies primarily on the AQS-calculated metrics of precision, bias, and completeness, via the AQS-generated reports (discussed in more detail in Section 20 of this QAPP) to complete assessments of the data. AQS will also estimate the design values for each of the criteria pollutants, based upon the concentrations entered for each monitor in the network.

19.7 Data Storage and Retrieval

The storage and retrieval of the air quality monitoring data shall be possible through the AMB’s archiving system. The data shall be stored for a period of three years, unless any litigation, claim, negotiation, audit, or other action involving the records has been started before the expiration of the three-year period. If this happens, the records will be retained until completion of the action and resolution of all issues that arise from it, or until the end of the regular three-year period, whichever is later. The data shall be stored on electronic media or in hard copy, whichever proves most advantageous. All data is stored according to Section 9.6. After the storage period has passed, the storage media may be disposed of or recycled. However, the validated dataset is uploaded to AQS for long-term storage.

20.0 Data Assessments and Oversight

Assessments or evaluations are designed to determine whether the ambient air quality monitoring program is being implemented in conformance with its approved QA Project Plan. These activities are conducted to increase confidence in the information obtained, and ultimately to determine whether the information may be used for their intended purpose. Table 6-1 provides a summary of the relevant assessments performed in the SCHD AMB ambient air quality monitoring network.

20.1 Assessment and Response Actions

In order to ensure the adequate performance of the quality system, the SCHD AMB performs and/or participates in the following assessments. These assessments are used to measure the performance and effectiveness of the quality system, the ambient air quality monitoring network design and operation, and various measurement phases of the data operation.

Network Plans and Assessments

Technical Systems Audits

External Performance Audits

Internal Performance Audits Data Quality Assessments

Data Quality Audits


Annual Data Certification

20.1.1 Network Plans/Assessments

40 CFR §58.10 provides the requirements for annual network plans and the more intensive 5-year assessment. In the SCHD AMB air monitoring network, these assessments are completed primarily by the AMB Supervisor in conjunction with other AMB staff, when necessary. The Annual Network Plan must contain the following information for each monitoring station in the network:

The Air Quality System (AQS) site identification number (for existing stations)

The location, including the street address and geographical coordinates, for each monitoring station

The sampling and analysis method used for each measured parameter

The operating schedule for each monitor

Any proposal to remove or move a monitoring station within a period of eighteen months following the plan submittal

The monitoring objective and spatial scale of representativeness for each monitor

The Metropolitan Statistical Area (MSA), Core-Based Statistical Area (CBSA), Combined Statistical Area (CSA), or other area represented by each monitor

In summary, the annual monitoring network plan provides documentation of the establishment and maintenance of the SCHD AMB air monitoring network, which consists of SLAMS, NCore, and Near-Road monitoring stations that include FRM and FEM monitors. The goal of the network plan is to determine conformance with network requirements as set forth in 40 CFR Part 58, Appendices A, C, D, and E. This includes site evaluations for 40 CFR Part 58, Appendix E siting criteria completed by the AMB Supervisor. This information will be included in the network review and submitted as part of the plan to TDEC then EPA. Any proposed changes to the monitoring network are detailed in the annual plan; proposed additions and discontinuations of SLAMS monitors are subject to the EPA approval in accordance with 40 CFR §58.14. The SCHD AMB submits an Annual Network Plan to TDEC by April or May of each year. TDEC then compiles a network plan that encompasses all of the plans from the local air monitoring programs in Tennessee. The document undergoes a 30-day public comment period prior to submission to the EPA for approval by July 1 of each year. The submitted plan addresses, as appropriate, any received comments. Annual network plans, in accordance with 40 CFR §58.10, began July 1, 2007. Annual network plans are due to EPA Region 4 on July 1 of each year. This is submitted to the EPA by the State of Tennessee.


EPA approval of the Annual Network Plan is provided by the Region 4 Administrator, who is required to give his/her approval within 120 days of submission by the air agency. Any deviations from the required SLAMS monitoring outlined in the Annual Network Plan must be reported to the EPA Region 4 immediately. Deviations from the required SLAMS monitoring may require either an additional site description or an updated monitoring plan. The documents may require an additional 30-day public comment period prior to submittal to the EPA.

The 5-year network assessment is a more extensive evaluation of the air monitoring network. The assessment determines, at a minimum, if the network meets the monitoring objectives defined in 40 CFR Part 58, Appendix D, whether new sites are needed, whether existing sites are no longer needed and can be terminated, and whether new technologies are appropriate for incorporation into the ambient air monitoring network. During the network assessment, the SCHD AMB, and other staff, when necessary, consider the ability of existing and proposed sites to support air quality characterization for areas with relatively high populations of susceptible individuals (e.g., children with asthma), as well as the potential impact any sites proposed for discontinuance may have on other data users. The 5-year network assessment may also include information related to applicable waivers for the SCHD AMB monitoring stations. The SCHD AMB submits a copy of the 5-year assessment, along with a revised annual network plan, to TDEC, who then submits it to the EPA Region 4. These assessments began in 2010, and are due to EPA every five years on July 1. See Section 6.0 of this QAPP for more information about the monitoring locations in the SCHD AMB network.

20.1.2 Technical Systems Audits

A Technical Systems Audit (TSA) is a thorough, independent, and systematic on-site qualitative assessment, where facilities, equipment, personnel, training procedures, protocols, and recordkeeping are examined for conformance with regulatory requirements and this QAPP. EPA Region 4 QA staff conducts a TSA of the SCHD AMB program every 3 years, in accordance with 40 CFR Part 58, Appendix A, §2.5. The EPA reports its findings to the SCHD AMB senior management (e.g., Technical Manager and Assistant Manager). EPA TSA auditors may segregate the TSA activities into multiple categories, which may include field, laboratory, and data management activities. The categories may be audited independently or they may be combined. Key personnel with responsibilities


for planning, field operations, laboratory operations, QA/QC, data management, and reporting are included in TSA audit activities and are often interviewed during the process. Upon completion of the audit, EPA verbally alerts the SCHD PCS management of any deficiencies/findings during an on-site TSA exit briefing. This briefing allows the SCHD AMB staff to begin formulating or implementing corrective actions. A draft TSA Report is typically distributed within 30 days of the completion of the audit. EPA Region 4 allows a brief comment period of the draft report for factual accuracy; after comments are received (if necessary), the TSA report will be finalized and resubmitted to the SCHD AMB. A formal response to address the TSA findings must be completed and resubmitted to EPA Region 4 within 30 days. The response is in the form of a Corrective Action Plan. The AMB Supervisor will communicate with EPA routinely after the Corrective Action Plan has been submitted and provide progress updates on a periodic basis until the corrective actions have been completed.

20.1.3 External Performance Audits

The SCHD AMB participates in the EPA Performance Evaluation Program (PEP) and the EPA National Performance Audit Program (NPAP) for performance audits of monitoring equipment. Information about these audits, which are part of the EPA National Performance Evaluation Program, is detailed in 40 CFR Part 58, Appendix A, Section 2.4. In general, the NPAP is a performance evaluation where quantitative data are collected independently in order to evaluate the accuracy of the monitoring equipment. In Region 4, a mobile laboratory arrives at a SCHD AMB site and generates known concentrations of pollutant-specific audit gases, used to challenge the specific SCHD AMB analyzer on site. Results of the comparison are immediately available to the SCHD AMB Technical Specialists and Supervisor. More information about NPAP can be found in 40 CFR Part 58, Appendix A, §3.1.3. Similarly, the PEP is an independent assessment used to estimate total measurement system bias. During PEP audits, an EPA contractor sets up a PM2.5 sampler such that it is collocated with the SCHD AMB sampler. Both samplers are programed to collect 24-hour samples during the same time period. Afterwards, the samples are analyzed – the independent sample will be analyzed by the EPA Region 4 laboratory, whereas the SCHD AMB sample will be analyzed by IML. The results of these samples are later compared, after the gravimetric analyses have been completed. Because of the nature of the PM2.5 program, and need for sample analysis in a laboratory, the results of PEP audits are not immediate. PM10-2.5 PEP audits are also completed on a periodic “as-needed” basis. More information about PEP audits can be found in 40 CFR Part 58, Appendix A, §3.2.4. The SCHD AMB also participates in other independent assessments of the network. EEMS has been contracted by the SCHD AMB to perform quarterly independent audits


of the network. The trained and certified EEMS field scientist follows the NPAP procedures while performing audits of all of the continuous gaseous air quality monitors. EEMS performs the through-the-probe (TTP) gas analyzer audits and PM audits. TDEC also performs biannual audits of the network monitors. When completed, a written report of the audit findings is submitted to the Technical Manager and AMB Supervisor via email. Any findings may be verbally communicated to the AMB as well. The results from the audits are submitted into AQS by the AMB Supervisor.

20.1.4 Internal Performance Audits As stated in Sections 4.1.3, 4.1.4 and 14.1.5 of this QAPP, the AMB Supervisor and Lead Technical Specialist conduct quarterly performance audits of the SCHD AMB monitoring equipment, if audits are not performed by EEMS or TDEC. To complete these audits, the AMB Supervisor and Lead Technical Specialist use dedicated, independent, NIST-traceable audit equipment to challenge the instrumentation on site. The results of the performance audits are communicated to the AMB Technical Specialists, who then are instructed by the AMB Supervisor to complete corrective actions (when necessary). The results of the performance audits are documented on quality control check forms and in the site logbook for the instrument. This information is then compiled with the monthly data package for each site and parameter, scanned and stored on the AMB shared drive (S:). The results of these audits, if necessary, are compiled and uploaded to the AQS database on a quarterly basis.

20.1.5 Data Quality Audits

An audit of data quality (ADQ) reveals how data are handled, what judgements were made, and whether mistakes were made and never corrected. An ADQ can often identify the means to correct systematic data reduction errors. An ADQ is performed every three years in conjunction with the TSA. Sufficient time and effort will be devoted to this activity so that the auditors have a clear understanding and complete documentation of data flow. Pertinent ADQ questions appear on the TSA check sheets, which shall be used in executing an ADQ. The TSA check sheets shall be used to ensure that the data collection and handling integrity is maintained. The ADQ will serve as an effective framework for organizing the extensive amount of information gathered during the audit and field monitoring and support functions within the agency. The ADQ will have the same reporting/corrective action requirements as the TSA. Any relevant documentation required before a TSA are completed by the AMB Supervisor or Lead Technical Specialist. In an effort to assess data quality effectively, the SCHD AMB performs data review on a monthly basis. These activities are performed by the AMB Supervisor and Lead Technical Specialist. Quality control checks of the gaseous and ozone analyzers and flow verification forms of the particulate samplers are usually reviewed by the AMB


Supervisor within a week of the QC activity being performed. Any discrepancies are addressed as soon as the occurrence and corrective actions are performed when necessary. The Technical Specialists and Lead Technical Specialist review the data for continuity and accuracy, while documenting all edits and coding for the month on the Air Vision monthly report that is generated from the data management system. The AMB Supervisor reviews and verifies the data and documentation to further validate the data before it is submitted into AQS. Details for this process are further described in Section 23 of this QAPP.

20.1.6 Data Quality Assessment A data quality assessment (DQA) is the statistical analysis of environmental data to determine whether the data meet the assumptions that the DQOs and data collection design were developed under, and whether the total error in the data is tolerable. Calculations of measurement uncertainty are carried out by the EPA according to the procedures and equations identified in 40 CFR Part 58, Appendix A, §4. The DQIs are used to assess how well the monitoring data compare to the established DQOs and MQOs. AQS provides statistical software that evaluates the DQIs of precision, bias, and completeness for the monitoring organizations. With that in mind, the PQAOs (including the SCHD AMB) must report the data for QA/QC checks (per Section 14.1 of this QAPP) to AQS. Measurement uncertainty will be estimated for both automated and manual data recording methods. The statistical estimates of the data quality will be calculated in AQS on the basis of single monitors, as well as aggregated for monitors within the PQAO for a specific pollutant. The precision estimate (calculation) used to assess the precision checks for the gaseous analyzers is found in 40 CFR Part 58, Appendix A, §4.1.2; the bias estimate is found in the §4.1.3. The precision estimate (calculation) for particulates is found in 40 CFR Part 58, Appendix A, §4.2.1; the bias estimate is found in the §4.2.5. Other DQA calculations are also detailed in 40 CFR Part 58, Appendix A, §4. To complete the DQAs, the AMB Supervisor will generate a series of standard AMP reports from AQS to review and assess the SCHD AMB data quality quarterly. For this quarterly assessment, the AQS AMP600 (Certification Evaluation and Concurrence) and/or AMP256 (QA Data Quality Indicator) reports are generated, evaluated, and then kept as a record to document the review. These reports provide the results of the statistical analyses, which are compared to the DQOs in Section 7.0 of this QAPP. If the monitoring data are found to meet the DQOs, the data are considered to be “in control” and no further action is needed. However, if issues are observed in the data during these assessments such that DQOs are not met, the issues will be investigated to determine root cause and then corrective actions implemented.


Also, during these quarterly data assessments, the AMB Supervisor will generate AMP430 (Data Completeness) and AMP251 (QA Raw Assessment) reports. The NOy quality data is reviewed through generating the AMP251 also. The results of these reports are compared to the MQOs in Section 7.0 of this QAPP, documented in Tables 7-1 thru 7-9. If issues are observed in the data, the AMB Supervisor will discuss these issues with the Technical Specialists and determine the necessary course of action. If data completeness requirements have not been met, the AMB Supervisor will communicate this issue to EPA Region 4, in accordance with grant commitments. Design Value Reports are generated yearly after all data has been submitted into AQS.

20.1.7 Annual Data Certification

In accordance with 40 CFR §58.15, an annual air monitoring data certification letter is required to certify that the data collected by the FRM and FEM monitors at SLAMS (and special purpose monitoring (SPM) sites, if applicable) sites within the SCHD AMB network meet criteria in 40 CFR Part 58, Appendix A from January 1 to December 31 of the previous year. Along with the certification letter, the SCHD AMB must submit to the EPA an annual summary report of all the ambient air quality data collected by the monitors, as well as a summary of the precision and accuracy data, for the previous year. Data certification is the final process of assessing the PQAO’s data for the previous calendar year. Data is verified and validated monthly, as discussed in Section 19.5 of this QAPP. Additionally, data is assessed on a quarterly basis by the AMB Supervisor when specific AQS reports are generated to assess the DQIs (as described in Section 20.1.6 above). With these assessments ongoing throughout the year, annual data certification, then, serves as the last assessment of the data – looking at it from an all-inclusive, annual perspective – to see if any unidentified anomalies or trends exist in the data that were not previously identified. The annual data certification process starts with running and reviewing AMP reports contained in AQS. Typical reports queried include the following:

AMP350 Raw Data

AMP251 QA Data

AMP430 Data Completeness

AMP600 Certification Evaluation

AMP256 Data Quality Indicator

AMP504 Extract QA Data

AMP450 Quicklook Criteria Parameters

AMP450NC Quicklook All Parameters

AMP 480 Design Value Report


The AMB Supervisor reviews these reports and confirms everything is accurate and complete. The reports are also reviewed to ensure the statistical results indicate that the monitoring data were “in control” over the course of the entire year and met the DQOs. If problems are identified, they are investigated in accordance with Section 24 of this QAPP. Ultimately, this process verifies that the SCHD AMB monitoring data submitted to AQS is complete and accurate. Once any necessary corrections/additions/deletions have been completed in AQS and the data set is finalized, the AMB Supervisor officially recommends the data for certification to the EPA Region 4. The data certification package provided to EPA includes a signed copy of the AMP 600 report, along with a letter signed by the Technical Manager that attests that the previous year of ambient concentration and quality assurance data in AQS are complete and accurate, taking into consideration the quality assurance findings, to the best of his/her knowledge. The annual data certification package is due to EPA Region 4 by May 1 of each year.

20.1.8 Reporting and Resolution of Issues

An important function of a quality system is a communication structure that ensures corrective actions, when needed, are implemented in a timely manner and their effectiveness is confirmed. In order to address the findings from the assessments described above, the following structure and associated protocols shall be employed to identify and implement corrective actions. All SCHD AMB Technical Specialists are responsible for identifying the need for corrective actions. Identifying the need for corrective actions can occur during site visits, audits, data review activities, or other monitoring activities. This shared responsibility, coupled with diligent attention to detail and accuracy, will assure that the SCHD ambient air monitoring network consistently collects quality data, and that the data is reduced, analyzed, and presented in an accurate and representative manner. Any Technical Specialist who perceives a need for corrective action(s) shall present the situation/concern to the AMB Supervisor. In most cases, the AMB Supervisor will assess the need for corrective action, although occasions may arise where the Lead Technical Specialist is delegated this responsibility; if one is deemed necessary, a suitable corrective action will be selected and disseminated to the Technical Specialist. If the issue is of major significance, the situation will be communicated by the AMB Supervisor to the Assistant Manager or Technical Manager, who may determine that the issue is of such import that work must stop until corrective action(s) can be implemented and the situation completely resolved.


The Technical Specialists are primarily responsible for implementing corrective actions; however, any AMB staff may initiate the corrective action process. The corrective action must be implemented within 24 hours of the occurrence, notwithstanding extenuating circumstances. An implementation notice will be supplied to the AMB Supervisor upon completion of the corrective action. The AMB Supervisor determines the efficacy and success of corrective actions. After a corrective action, the procedure will be documented on a Corrective Action Form (see Figure 21-1). This form is submitted to the AMB Supervisor for further review to verify the corrective procedure. For tracking purposes, the Corrective Action Form is classified and kept based on site location and instrument type and not on types of corrective action. Following implementation of a corrective action, the AMB Supervisor may require a follow-up review to verify the efficacy of the corrective action. Both the action of implementing the corrective action and the influence of the corrective action on the operations of the ambient air monitoring network must be appraised. Any deficiencies in the correction must be noted and the procedure updated to completely correct the discrepancy.

21.0 Reports to Management

This section describes the quality-related reports and communications to management necessary to support SLAMS, NCore and Near-Road network operations and the associated data acquisition, validation, assessment, and reporting. Unless otherwise indicated, all reports will contain monitoring data for criteria pollutants, including SO2 maximum 5-minute average and PM10-2.5. Examples of reports that are reported to the SCHD Management staff are performance audit reports from TDEC and EEMS, yearly data certification reports, and EPA TSA reports.

21.1 Frequency, Content, and Distribution of Reports

Reports to management required for the SLAMS, NCore, and Near-Road program in general are discussed in various sections of 40 CFR Parts 50, 53, and 58. Guidance for management report formats and content are provided in reports developed by EPA’s Air Quality Assessment Division within the Office of Air Quality Planning and Standards (OAQPS). The reports are summarized in Table 21-1. Refer to Section 20 for more information concerning these reports.


Table 21-1. SCHD AMB Ambient Monitoring Program Reports

Report Type Frequency Projected Delivery Date

Report Preparation

Recipients

Technical Systems Audit

Every 3 years Per EPA schedule EPA SCHD PCS Management &

SCHD AMB

Monthly Reports Continual 5th day of every month

SCHD AMB SCHD AMB Supervisor

Data Certification

Package

Annually May 1 SCHD AMB Supervisor

EPA

Annual Monitoring

Network Plan

Annually July 1 SCHD AMB Supervisor

TDEC, EPA

5-year Network Assessment

Every 5 years July 1, starting in 2010

SCHD AMB Supervisor

TDEC, EPA

Corrective Action Reports

Continual After each occurrence

Technical Specialists

SCHD AMB Supervisor

EEMS audit reports

Quarterly 60 days after completion of

the audit

EEMS QA auditor SCHD AMB Supervisor

TDEC audit reports

Biannually 60 days after completion of

the audit

TDEC QA auditor SCHD PCS Technical

Manager and AMB Supervisor

21.2 Response/Corrective Action Reports

The response/corrective action report procedure will be followed whenever a problem is found such as a safety defect, an operational problem, or a failure to comply with procedures. A separate report will be required for each problem identified. The response/corrective action report is one of the most important ongoing reports to management because it documents primary QA activities and provides valuable records of QA activities that can be used in preparing other summary reports. Copies of response/corrective action reports will be distributed twice: first when the problem has been identified and the action has been scheduled, and second when the correction has been completed. The Technical Specialist assigned will generate the response/corrective action reports. The report will be kept in a Corrective Action Report binder for review. A copy of the Corrective Action Form is provided in Figure 21-1.


Figure 21-1. Sample Corrective Action Form



22.0 Data Validation and Usability

22.1 Data Review, Verification, and Validation

Each of the network’s analytical instruments are employed to measure ambient concentrations of specific pollutants. In order to be useful the data must undergo evaluation to determine the degree to which each data point has met its quality specifications. The AMB Supervisor and Lead Technical Specialist evaluate the data to establish that data collection is consistent with QAPP and SOP requirements. Then, the AMB Supervisor and Lead Technical Specialist estimate the potential effect any deviation from the QAPP or SOP requirements may have on the usability of the associated data item, its contribution to the quality of the reduced and analyzed data, and its effect on decisions. Data review is the in-house examination to ensure that the data has been recorded, transmitted, and processed correctly. It includes completeness checks to determine if there are any deficiencies such as missing data or lost integrity. The data under evaluation should be compared to actual events, as per guidance (Guidance on Environmental Data Verification and Data Validation (EPA QA/G-8)). In addition, it is expected that some of the QC checks will indicate that the data fail to meet the acceptance criteria. Data identified as suspect, or does not meet the acceptance criteria, shall be flagged with AQS codes prior to upload to AQS. The review of the routine data and the associated QC data will be verified and validated on a monthly basis. Continuous data is downloaded to the central DAS (i.e. AirVision) daily and examined daily to ensure the data is acquired according to requirements. Continuous data is later reviewed in batches during the data validation process. Non-continuous data is reviewed and verified by the Technical Specialist during collection and retrieval and is reviewed and verified in batches as part of the data reduction and validation process. Corrective action is taken if errors or anomalies are found. In cases when data does not meet quality goals, it may be flagged or invalidated. Data verification is the process of evaluating the completeness, correctness, and conformance/compliance of the data set against method, procedural and contractual specifications. Verification can be further defined as confirmation, through provision of objective evidence, that specified requirements have been fulfilled. The verification process also involves the inspection and acceptance of the field samples. The Technical Specialists verify the gaseous data collected when reviewing and generating graphs from the data on AirVision throughout the sample collection process. The Technical Specialists verify intermittent data when downloading/transferring files from filter-based PM samplers and checking/documenting the sampler’s “as found”/”as left” status. Also, the Technical Specialists inspect the intermittent samples – pre and post-sampling – to ensure they are intact and undamaged. Data verification also occurs when the Lead Technical Specialist assists the AMB Supervisor in reviewing the monthly



data. Any missing data (gaps) are reviewed and accounted for, and unacceptable or questionable data will be flagged by the AMB Supervisor and Lead Technical Specialist during this monthly process. All flagged data will be re-verified by the AMB Supervisor. Once the monthly reports from AirVision are complete, the data are reviewed for routine data outliers and conformance to acceptance criteria. Data validation is a routine process designed to ensure that reported values meet the quality goals of the environmental data operations. Data validation is further defined as examination and provision of objective evidence that the particular requirements for a specific intended use are fulfilled. The primary intended use for the SCHD AMB data set is NAAQS compliance. A progressive, systematic approach to data validation must be used to ensure and assess the quality of data. Data validation includes the review of the SCHD AMB data sets against the individual pollutant MQOs (see Section 7 of this QAPP), which is completed by the Lead Technical Specialist and AMB Supervisor. It also includes the review of data against the QC reports, QA reports, graphs of weekly QC checks from AirVision, as well as the comparison of the data against basic statistics (such as completeness). Reviewing data long-term (over a monthly or quarterly time-frame) provides information about the structure of the data and may identify patterns, relationships, or potential anomalies. The AMB Supervisor also spot-checks comparisons between graphs from AirVision and data summary reports from the polling central processing unit (CPU) data system to ensure data consistency. If a problem/discrepancy is found, further investigations must be done to find the source of the error and then correct it. Invalidated data are replaced with AQS Null Data codes prior to upload to AQS. Deviations from operational procedures or quality assurance requirements that do not result in data invalidation may require that data be qualified with QA qualifier flags prior to upload to AQS.

22.2 Data Usability

The location of all SCHD AMB sites have received EPA approval; thus, data from each monitor will be considered spatially representative as long as the sites continue to meet the requirements set forth by 40 CFR Part 58, Appendix E – Probe and Monitoring Path Siting Criteria for Ambient Air Quality Monitoring. Additional guidance is provided in Guidance on Choosing a Sampling Design for Environmental Data Collection, (EPA QA/G-5S). Any deviations from the minimum siting criteria (e.g., shelter location, probe placement, and/or monitor site path requirements) shall be thoroughly documented in the site logbook and on the yearly Site Evaluation Report. Examples of deviations include, but are not limited to insufficient distance from roadways (i.e., marginal terrain criteria) and insufficient distance from influencing objects (e.g., drip line of an adjacent tree or a cell phone tower that was installed after the monitoring site was established). Measured



deviation from the siting criteria will require data to be flagged in the AQS database (i.e., “SX” qualifier) until such time as corrective actions can be implemented, or an approved waiver from EPA Region 4 must be obtained. The impact of any deviations shall be evaluated by the AMB Supervisor, in consultation with EPA Region 4, prior to the use of the data for calculation of summary statistics.

22.2.1 Sample Collection Procedures

Sample collection procedures are outlined in Section 11 of this QAPP and further referenced in Table 11-1. Sampling methodologies and acceptable technologies are outlined in Sections 11.1 and 11.2. The monitors and samplers used by the SCHD AMB for the collection of criteria pollutant data are designated as FRM/FEM; thus, the methodologies/technologies are considered acceptable for regulatory decision-making purposes. Additionally, the SCHD operates a non-FEM, high sensitivity gaseous analyzer in accordance with the NCore TAD for the collection of NOy data. Any deviation from the established sample collection procedures must be documented in the appropriate site pollutant logbook. The impact of any deviations shall be evaluated during data validation by the AMB Supervisor and Lead Technical Specialist prior to upload of the data to AQS.

22.2.2 Quality Control

Quality control activities are outlined in Section 14 of this QAPP and further detailed in the SOPs listed in Table 11-1. Prior to upload of sample data to AQS, the impact of any deviations shall be evaluated by the AMB Supervisor and Lead Technical Specialist during the data validation process. While not exhaustive, the following list contains some examples of data loss/invalidation and the associated methods of data handling.

All periods of missing concentration and meteorological data (e.g. during QC activities, maintenance, and power failures) will be replaced with the appropriate AQS Null Data codes.

Each hour of pollutant concentration and meteorological data is composed of at least 45 minutes of valid minute data. Hours of data with less than 45 minutes of valid data collection will require invalidation of the hourly data. For SO2, both the hourly and five-minute averaged data will require invalidation. The affected data will be replaced with AQS Null Data codes.

The shelter temperature must be maintained within a temperature range that meets the FRM or FEM requirements for all instrumentation that the shelter contains. All data collected outside of this temperature range will be invalidated and replaced with AQS Null Data codes. The manual or automated zero and span points of all zero and span checks must be within the acceptance criteria limits specified in Tables 7-1 thru 7-4. The



precision point during manual or automated, overnight “auto-cal” checks must meet the MQO for the 1-point QC checks for each pollutant also. These MQOs serve as the “control limits” in the SCHD AMB – meaning, the maximum threshold for which data is considered acceptable, and above which data is considered “out of control” and must be invalidated. For example, the calculated difference for the precision point for ozone must be <±7.1% difference. If the point exceeds the allowable criteria, all ozone data will be invalidated back to the point of the last acceptable QC check or a known point of analyzer malfunction and forward to the point where the monitor is replaced or repaired and recalibrated/re-verified to effectively “bracket” the data. The affected data will be replaced with AQS Null Data codes.

Precision and bias check data uploaded to AQS as QC data must actually quality-assure the applicable concentration data within AQS. Examples include:

o If a 1-point QC check provides valid concentrations and exceeds the acceptance criteria, this is a valid but failed check. This QC check will be reported to AQS, and consequently, the routine data will be invalidated (coded “EC”) back to the last acceptable 1-point QC check. However, compelling evidence (e.g., multi-point verification, independent performance evaluation) may help to validate some routine data collected between the failed check and the last acceptable 1-point QC check. Such routine data are considered valid and will be reported and qualified in AQS (flagged “1V”).

o If a 1-point QC check exceeds the acceptance criteria, but there is compelling evidence to consider the analyzer’s routine data to be valid, this check is invalid and will not be reported to AQS. A “1C” null code will be reported to AQS in place of the invalid check.

o If a 1-point QC check occurs during a period of a machine malfunction, this is considered an invalid check and will not be reported to AQS. A “1C” null code will be reported to AQS in place of the invalid check. The routine data will be invalidated (flagged “AN”).

The calculated percent difference during a QA Performance Evaluation must meet the MQO (see Tables 7-1 thru 7-4) guidance for each pollutant. If the Performance Evaluation exceeds the MQO differences, the validity of the failed audit will be verified by performing a zero/span/precision check with the independent audit calibrator (Teledyne API T750U). If the failed audit results are verified, then the concentration data will be qualified or invalidated back to the last known acceptable QA/QC check or known point of analyzer malfunction and forward to the point where the monitor is replaced or repaired and recalibrated/re-verified to effectively “bracket” the data. The affected data will be qualified with AQS QA qualifier flags or be replaced with AQS Null Data codes.



Performance Evaluation data uploaded to AQS as QA data must actually quality-assure the applicable concentration data within AQS. Examples include:

o If concentration data are invalidated due to unacceptable results during a Performance Evaluation (i.e. quarterly QA audit), the results of the failed Performance Evaluation will not be uploaded into AQS.

o If the QA auditor’s equipment is malfunctioning during a Performance Evaluation, resulting in unacceptable audit results, no ambient concentration data will be invalidated and the results of the Performance Evaluation will not be uploaded to AQS.

It is the responsibility of the AMB Supervisor and Lead Technical Specialist to ensure

that all invalidated concentration data is coded appropriately, and then correctly uploaded into AQS. With the exception of “data completeness” statistics, invalidated concentration data, and its related QA/QC data, are not used in the calculation of the annual and three-year summary statistics. Therefore, the data uploaded into AQS must be properly validated and coded to ensure that summary statistics are calculated accurately.

22.2.3 Calibration

Sections 14 and 16 address the calibration of instruments and equipment and the information that should be presented to ensure that the calibrations are performed correctly, and the results are acceptable. When calibration problems are identified, any data produced between the suspect calibration event and any subsequent recalibration should be flagged to alert data users.

22.2.4 Data Reduction and Processing

As mentioned in the above sections, technical systems audits will be performed to ensure the data reduction and processing activities mentioned in the QAPP are being followed. Periodically, raw data will be reviewed and final concentrations will be calculated by hand. The final values submitted to AQS should match the hand calculations. The data will also be reviewed to ensure that associated flags or any other data qualifiers have been appropriately associated with the data and the appropriate corrective actions were taken. The AMB Supervisor will make the final decision on the data validation.

22.2.5 Exceptional Events

40 CFR 50.14 allows the EPA Administrator to exclude certain data from being used for determinations of exceedances and violations of a NAAQS, so long as a State/Local air



monitoring organization demonstrates to the Administrator’s satisfaction that the exceedance or violation was caused by an “exceptional event”. 40 CFR 50.1 defines an “Exceptional Event” as an event or events, in which:

The resulting emissions affect air quality in such a way that there exists a clear causal relationship between the specific event(s) and the monitored exceedance(s) or violation(s);

The event(s) is not reasonably controllable or preventable; and,

The event(s) is caused by a human activity that is unlikely to recur at a particular location or is a natural event(s).

An Exceptional Event does not include:

Air pollution relating to source noncompliance;

Stagnation of air masses or meteorological inversions; and,

Meteorological events involving high temperatures or lack of precipitation.

Note: Conditions involving high temperatures or a lack of precipitation may promote occurrences of particular types of exceptional events, such as wildfires or high wind events, which do directly cause emissions. Data impacted by an Exceptional Event is not considered “representative” of air quality for NAAQS-comparison purposes, or calculation of certain summary statistics. All concentration data impacted by an Exceptional Event should be flagged with an AQS Request Exclusion code and linked within AQS to an event description. Exceptional Event codes and descriptions are typically due by July 1 of the following year, but alternative schedules may be established during Federal rulemaking. It is the responsibility of the AMB Supervisor to review the data and work with the PCS Meteorologist to analyze the data for potential Exceptional Events. It is the responsibility of the AMB Supervisor to add the necessary flags and descriptions into AQS by July 1 of the following year (or by applicable regulatory deadlines). A State seeking concurrence must notify and cooperate with the appropriate EPA Regional Office (i.e. EPA Region 4) to prepare a demonstration package for the Administrator. Exceptional Event data in AQS must receive concurrence from the EPA Administrator. Data that does not receive a concurrence is still eligible for NAAQS comparisons, regardless of the application of Request Exclusion flags.



23.0 Verification and Validation Methods 40 CFR Part 58, Appendix A, states the following in Section 1.2.3:

Each PQAO is required to implement a quality system that provides sufficient information to assess the quality of the monitoring data… Failure to conduct or pass a required check or procedure, or a series of required checks or procedures, does not by itself invalidate data for regulatory decision making. Rather, PQAOs and the EPA shall use the checks and procedures required in [Part 58, Appendix A] in combination with other data quality information, reports, and similar documentation that demonstrate overall compliance with Part 58. Accordingly, the EPA and PQAOs shall use a “weight of evidence” approach when determining the suitability of data for regulatory decisions…Consensus built validation templates or validation criteria already approved in QAPPs should be used as the basis for the weight of evidence approach. As stated in Section 7.2 of this QAPP, the SCHD AMB has adopted the consensus-built data validation templates in the EPA QA Handbook and modified them, where appropriate, to reflect the SCHD AMB network. The templates are included in this QAPP in Section 7.2 and will be used for the weight of evidence approach afforded to PQAOs within the regulation. The QA Handbook provides the following guidance regarding the use of the templates, which the SCHD AMB will follow when validating data.

Critical Criteria – Deemed critical to maintaining the integrity of a sample (or ambient air concentration value) or group of samples. Observations that do not meet each and every criterion on the critical criteria table should be invalidated unless there are compelling reason and justification for not doing so. Basically, the sample or group of samples for which one or more of these criteria are not met is invalid until proven otherwise. In most cases the requirement, the implementation frequency of the criteria, and the acceptance criteria are found in CFR and are therefore regulatory in nature.

Operational Criteria – Important for maintaining and evaluating the quality of the data collection system. Violation of a criterion or a number of criteria in the operational criteria table may be cause for invalidation. The data validator should consider other quality control information that may or may not indicate the data are acceptable for the parameter being controlled. Therefore, the sample or group of samples for which one or more of these criteria are not met is suspect unless other quality control information demonstrates otherwise and is documented. The reason for not meeting the criteria should be investigated, mitigated or justified.

Systematic Criteria – include those criteria which are important for the correct interpretation of the data, but do not usually impact the validity of a sample or



group of samples. An example systematic criterion is that at least 75% of the scheduled samples for each quarter should be successfully collected and validated. The DQOs are also included in this table. If the data quality objectives are not met, this does not invalidate any of the samples but it may impact the confidence in the attainment/non-attainment decision.

The designation of QC checks or QC samples as Operational or Systematic does not imply that these quality control checks need not be performed. Not performing an operational or systematic QC check that is required by regulation can be a basis for invalidation of all associated data. The validation templates are meant to be applied to small data sets (single values or a few weeks of information) and should not be construed to allow a criterion to be in non-conformance simply because it is operational or systematic.

The following levels of data review describe the overall data verification and validation process, including the individuals responsible for the stated activities. RAW – Level 0 (All Staff): These data are obtained directly from the data loggers that acquire the data in the field. Averaging times represent the minimum intervals recorded by the data logger. Raw data may have been reduced, but are unedited, not reviewed, and are not adjusted. Raw data has not been edited for instrument downtime, but may be flagged with pre-programmed, user-defined status flags that the logger will apply to data points when excursions occur. Raw data are consulted on a regular basis to ascertain instrument functionality and to identify potential episodes prior to the monthly data validation process. In the SCHD AMB, a Daily Summary Report from the previous day’s activity is generated, printed on a common Section printer and emailed to each Technical Specialist, Lead Technical Specialist and Supervisor in the AMB. The Staff reviews the printouts/emails daily for any anomalies that may have occurred from the previous day(s) activities. Any anomalies that occurred that were not a part of the weekly quality control checks will be reviewed on the AirVision data management system. A graph and any associated documentation will be generated in AirVision that illustrates the anomaly. This graph will be provided to the Supervisor of the AMB and saved with all associated monthly reports, weekly quality control check forms, and logbook entries. This information will be used in the next step of the verification and validation process. REVISED – Level 1 (Lead Technical Specialist and AMB Supervisor): This is the next step in the verification process that occurs after the Level 0 data review. Data are revised (in the edited database only; original data remains intact in the unedited database). Verification and associated data edits are documented on the monthly report generated in AirVision for each respective pollutant. The edits include the following:



Removal of values when monitoring instruments fail specified validation criteria.

Verifying computer file entries against data sheets/logbooks, where appropriate.

Replacement of data from a backup data acquisition system in the event of failure of the primary system.

Identification and flagging of data that are beyond reasonable bounds, significantly deviate from measurement assumptions, or that may be deemed unrepresentative.

Identification of data collected during periods of maintenance or malfunction.

In the SCHD AMB, the verification process is completed by the Lead Technical Specialist and Supervisor. This process begins with an unedited raw data monthly report generated from AirVision for all respective parameters. This report will have no “mark-ups”. The Lead Technical Specialist will generate a separate monthly report from AirVision which will be “marked-up”. All minute data in AirVision, the QC check forms and the logbook entries are reviewed.

QA REVIEW- Level 2 – (Lead Technical Specialist and AMB Supervisor): QA validation is the next step in data analysis. In addition to a review of the revised data, the Lead Technical Specialist and AMB Supervisor verify the Technical Specialists’ logbooks and quality control check forms for completeness and accuracy and ensure the data results meet the MQOs found in Tables 7-1 thru 7-9. Data that do not meet the requirements of the critical criteria elements will be invalidated, unless compelling evidence and justification exists for not doing so. In the case of the latter, the reason(s) for not invalidating the data will be documented on the monthly report generated from AirVision. Qualifier flags may be applied to data that are found to not meet the operational or systematic criteria. This will be documented on the monthly AirVision report. If multiple operational criteria flags are applied to the data, the Lead Technical Specialist and AMB Supervisor may deem that the data should be invalidated instead of qualified. AQS READY – Level 3 (AMB Supervisor or Lead Technical Specialist): Data is prepared for AQS submission and text files are created via AirVision. AQS-Ready files will be reviewed by the AMB Supervisor before submittal approval is granted. Once submitted successfully, AQS AMP reports will be reviewed and stored on the S: drive to verify data upload (transfer) was successful. The data will also be spot-checked for accuracy.

23.1 AQS Null Codes and Descriptions

Table 23-1 provides a list of common AQS Null Value Codes and gives a brief description of what the codes mean. Null value codes invalidate data. Their use indicates the data they replace do not meet quality specifications. It is the SCHD AMB policy to select the null value code that most closely describes the reason for the data to be invalidated. Only one null code can be used to replace a single hour of data loss. If there are



multiple reasons why an hour of data is lost (such as a Technical Specialist performing routine maintenance during a portion of the hour, and then beginning a zero/span/precision check in that same hour), the code that best reflects the majority of that hour’s data loss will be selected. In some cases, the AMB Supervisor may be consulted to help select a code when multiple null value codes could be used to describe the event (such as data loss due to both a power failure and a subsequent machine malfunction).



Table 23-1. AQS Null Value Codes

Qualifier Code

Qualifier Description Actions

AA Sample Pressure Out of Limits Invalid Data are Replaced with Null Codes

AB Technician Unavailable

AC Construction/Repairs in Area

AD Shelter Storm Damage

AE Shelter Temperature Outside Limits

AF Scheduled but Not Collected

AG Sample Time Out of Limits

AH Sample Flow Rate or CV Out of Limits

AI Insufficient Data (cannot calculate)

AJ Filter Damage

AK Filter Leak

AL Voided By Operator

AM Miscellaneous Void

AN Machine Malfunction

AO Bad Weather

AP Vandalism

AQ Collection Error

AR Lab Error

AS Poor Quality Assurance Results

AT Calibration

AU Monitoring Waived

AV Power Failure

AW Wildlife Damage

AX Precision Check

AY Q C Control Points (zero/span)

AZ Q C Audit

BA Maintenance/Routine Repairs

BB Unable to Reach Site

BC Multi-Point Calibration

BD Auto Calibration

BE Building/Site Repair

BF Precision/Zero/Span

BG Missing Ozone Data Not Likely to Exceed Level of Standard

BH Interference/Co-elution/Misidentification

BI Lost or Damaged in Transit

BJ Operator Error

BK Site Computer/Data Logger Down

BL QA Audit

BM Accuracy Check

BN Sample Value Exceeds Media Limit

BR Sample Value Below Acceptable Range

CS Laboratory Calibration Standard

DA Aberrant Data (Corrupt Files, Aberrant Chromatography, Spikes, Shifts)

DL Detection Limit Analyses

FI Filter Inspection Flag



Qualifier Code


MB Method Blank (Analytical) Invalid Data are Replaced with Null Codes

MC Module End Cap Missing

SA Storm Approaching

SC Sampler Contamination

ST Calibration Verification Standard

TC Component Check & Retention Time Standard

TS Holding Time or Transport Temperature is Out of Specs.

1C A 1-Point QC check exceeds acceptance criteria but there is compelling evidence that the analyzer data is valid

EC Exceeds Critical Criteria

23.2 AQS QA Qualifier Flags

Table 23-2 provides common AQS QA Qualifier Flags. This list is not all-inclusive. QA qualifier flags do not invalidate data. Rather, the flags are a way of adding additional narrative to a data point(s) to better explain things/events that may have impacted them. The data are still considered valid and acceptable for their intended use, but need to be qualified in order to have a more complete record in AQS as to “what occurred”. These flags are used sparingly, but when needed allow the SCHD AMB to document a more complete story about the data. Table 23-2. AQS QA Qualifier Flags

AQS Qualifier


1 Deviation from a CFR/Critical Criteria Requirement 1. 2. 3. 4. 5. 6. 7. 8. Flag Indicating the Quality

of the Data

2 Operational Deviation

3 Field Issue

4 Lab Issue

5 Outlier

6 QAPP Issue

7 Below Lowest Calibration Level

9 Negative Value Detected - zero reported

FB Field Blank Value Above Acceptable Limit

FX Filter Integrity Issue

HT Sample Pick-Up Hold Time Exceeded

LB Lab Blank value Above Acceptable Limit

MD Value Less Than MDL

SX Does Not Meet Siting Criteria

TB Trip Blank Value Above Acceptable Limit

V Validated Value

VB Value Below Normal; No Reason to Invalidate



23.3 AQS Informational Flags Table 23-3 contains AQS informational flags. These are types of qualifier flags that the SCHD AMB will add to data believed to be impacted by an exceptional event, but where more information may be needed in order to determine if a request for exceptional event exclusion will be made. Like the QA qualifier flags in Section 23.2, these flags do not invalidate data, but rather allow the SCHD AMB to tell a more complete story about the events which may have impacted the data. Table 23-3. AQS Informational Flags

Qualifier Code


IA African Dust Flag Indicating Information about the Data

9. 10. 11. 12.

IB Asian Dust

IC Chemical Spills & Industrial Accidents

ID Cleanup After a Major Disaster

IE Demolition

IF Fire – Canadian

IG Fire – Mexico/Central America

IH Fireworks

II High Pollen Count

IJ High Winds

IK Infrequent Large Gatherings

IL Other

IM Prescribed Fire

IN Seismic Activity

IO Stratospheric Ozone Intrusion

IP Structural Fire

IQ Terrorist Act

IR Unique Traffic Disruption

IS Volcanic Eruptions

IT Wildfire – U.S.

J Construction

23.4 AQS Request Exclusion Qualifier Flags

Table 23-4 lists the available qualifier flags used for requesting data to be excluded from NAAQS determinations. Only after a discussion with EPA Region 4 that results in a determination to submit an exceptional event demonstration, but before the demonstration event is submitted, the SCHD AMB will apply a Request Exclusion flag to the AQS data. The SCHD AMB may also decide to change an informational flag to a Request Exclusion flag upon further investigation and after discussing with EPA. Exceptional events are discussed further in Section 22.2.5 of this QAPP.



Table 23-4. AQS Exclusion Flags

Qualifier Code


RA African Dust Flag indicating data that may have been influenced by an exceptional event that will be excluded

RB Asian Dust

RC Chemical Spills & Industrial Accidents

RD Cleanup After a Major Disaster

RE Demolition

RF Fire - Canadian

RG Fire – Mexico/Central America

RH Fireworks

RI High Pollen Count

RJ High Winds

RK Infrequent Large Gatherings

RL Other

RM Prescribed Fire

RN Seismic Activity

RO Stratospheric Ozone Intrusion

RP Structural Fire

RQ Terrorist Act

RR Unique Traffic Disruption

RS Volcanic Eruptions

RT Wildfire – U. S.

RU Wildfire Fire Use Fire – U. S.

24.0 Reconciliation with Data Quality Objectives (DQOs) The SCHD AMB follows procedures that verify data collected by the PQAO comply with the pollutant DQOs. Actions will be taken based upon assessment of the DQOs to maintain compliance. To reiterate, the data collected by the SCHD AMB will be used to:

Monitor the ambient concentrations of criteria/non-criteria pollutants within Shelby County, TN;

Evaluate compliance with the NAAQS;

Observe pollution trends; and,

Alert the public when unhealthy pollution levels are detected or predicted.

The quantitative DQOs are established in 40 CFR Part 58, Appendix A, and stated in Section 7.1 of this QAPP. To review the results of required statistical analyses (codified in Section 4 of 40 CFR Part 58, Appendix A), various AQS reports will be generated (see Section 20.1.6 of this QAPP). Since the SCHD AMB implements EPA’s critical criteria for precision checks – the SCHD AMB should not have to directly calculate confidence intervals annually because all data should, statistically, meet the DQOs.



While DQOs will be assessed quarterly throughout the year, the SCHD AMB will evaluate whether these objectives are achieved on an annual basis as well. Evaluation of measurement uncertainty will occur in conjunction with Annual Data Certification (Section 20.1.7), which is to be completed by May 1 of each year. The evaluation will be conducted by the AMB Supervisor. The data used to calculate measurement uncertainty will be obtained from AQS, which will have been previously quality-assured, coded, qualified, and evaluated based upon applicable MQOs. If and when the data from at least one of the monitors violates the DQIs bias and/or precision limits, then the AMB Supervisor and Lead Technical Specialist will conduct an investigation to uncover the cause of the violation. If all of the monitors in the network of a similar type or pollutant violate the DQI, the cause may be at the agency level (Technical Specialist training) or higher (problems with method designation). If only one monitor or site violates the DQI, the cause is more likely specific to the site (particular Technical Specialist, problem with the site). Tools for determining the cause include reviewing:

Data from a collocated network (e.g., state, other local program, national)

Data from performance audits (e.g., other agency or NPAP), and,

QC checks,

Once the cause(s) of non-conformance has been determined, the SCHD AMB will institute and document corrective actions to correct quality system deficiencies. Corrective actions may include revising the following:

Pollutant MQOs (e.g., to make them more stringent)

This QAPP; and

Specific SOPs.

When multiple Technical Specialists will be involved in such an investigation, the AMB Supervisor will be responsible for oversight of the investigation. Modification of the SCHD AMB’s MQOs, QAPP, and related SOPs will be the responsibility of the SCHD AMB Supervisor, Lead Technical Specialist and Technical Specialists, with revisions subsequently approved by the EPA Region 4. The AMB Supervisor will contact EPA Region 4 for guidance during this process, when/if necessary. Ultimately specifying tolerable error limits reduces the probability of making a decision error due to uncertainty in the data. Decision-makers, such as EPA, need to determine if the data collected within the SCHD AMB monitoring network will be less than, equal to, or greater than the level of the NAAQS for each specific criteria pollutant. The annual data certification process and reports generated as part of the certification provide a quantitative assessment of the measurement uncertainty with the SCHD AMB criteria pollutant data set. By controlling uncertainty in the data to the extent prescribed by the



DQOs, decision makers can use the SCHD AMB’s ambient air monitoring data with confidence.



25.0 References

1) Environmental Protection Agency. 2002. Guidance for Quality Assurance Project Plans (QA/G-5) (EPA/240/R-02/009). Washington, D.C.

2) Environmental Protection Agency. 2001a. EPA Requirements for Quality Assurance

Project Plans (QA/R-5) (EPA/240/B-01/003). Washington, D.C. 3) Environmental Protection Agency. 2017. Quality Assurance Handbook for Air

Pollution Measurement Systems Volume II Ambient Air Quality Monitoring Program (EPA-454/B-17-001). RTP, North Carolina. January 2017.

4) Environmental Protection Agency. 2008. Quality Assurance Handbook for Air

Pollution Measurement Systems Volume IV Meteorological Measurements Version 2.0 (EPA-454/B-08-002). RTP, North Carolina. March 2008.

5) Environmental Protection Agency. 2006. Data Quality Assessment: A Reviewer’s

Guide (QA/G-9R) (EPA/240/B-06/002). Washington, D.C. 6) Environmental Protection Agency. 2015. List of Designated Reference and

Equivalent Methods. RTP, North Carolina. Updated routinely; at the time of this QAPP, it was last published on December 15, 2018.

7) Environmental Protection Agency. 2005. Technical Assistance Document (TAD) for

Precursor Gas Measurements in the NCore Multi-Pollutant Monitoring Network Version 4. (EPA-454/R-05-003). RTP, North Carolina. September 2005.

8) Environmental Protection Agency. 2012. Near-Road NO2 Monitoring Technical Assistance Document. (EPA-454/B-12-002). RTP, North Carolina. June 2012.

9) IML Air Science (a division of Inter-Mountain Laboratories, Inc.). 2017. For Laboratory and Data Management Support of the Determination of Fine Particulate Matter as PM2.5, PM10 and Coarse Particulate Matter as PM10-2.5 in the Atmosphere Quality Assurance Project Plan. Sheridan, Wyoming. (Revision 14, March 2017).