2011 Technical Systems Audit Report

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION4
Ms. Lauren Anderson
Science and Ecosystem Support Division
Enforcement and Investigations Branch
980 College Station Road
Athens, Georgia 30605-2720
March 28,2012
Louisville Metro Air Pollution Control District
850 Barret Avenue, Suite 205
Louisville, Kentucky 40204
SESD Project#: 12-0044
Dear Ms. Anderson:
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APR 0?. 2012
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This letter is to forward to you the final report concerning the Technical Systems Audit conducted
November 29-30, 2011 by Doug Jager and Richard Guillot, U.S. Environmental Protection Agency,
Region 4, on the Louisville Metro Air Pollution Control Districts' ambient air monitoring program.
The data collection period covered by the audit was January 2008- December 2010. The "Technical
Systems Audit Form Questionnaire" was used as a guide in conducting the audit and is attached. Based
on the audit results, it is concluded that all EPA requirements for the operation and quality assurance of
an air monitoring network were met. The quality assurance program and documentation were sufficient
to support the agency's operation.
If you have any questions regarding the audit, please call Richard Guillot at (706) 355-8737.
Sincerely,
~ 0 t ; -
Superfund and Air Section
cc: Stephanie McCarthy, State ofKentucky
SESD Project #: 11-0044
. '
United States Environmental Protection Agency
Region 4
Science and Ecosystem Support Division
Athens, Georgia 30605-2720
2011 Technical Systems Audit Report
Jefferson County, Kentucky
CONDUCTED
November 29-30, 201-1
Requestor:
Required by Code of Federal Regulations
40 CFR Part 58, Appendix A, 2.5
Auditor(s)
Doug Jager, SESD
Project Leader
Richard Guillot, SESD
EPA Region 4, SESD
Enforcement & Investigations Branch
Superfund and Air Section
RECEIVE[
APR 0 2 Z012
1-\.PC.D.

Page 1 of 55
Richard Guillot
Environmental Engineer
Superfund & Air Section
Laura Ackerman
Chief
Superfund & Air Section
Report
,
1
Signature l
Signature
Date
Date
Page 2 of 55
. \
INTRODUCTION
The purpose for this technical systems audit (TSA) was to evaluate the current operation and
performance of the ambient air monitoring program for the Louisville Metro Air Pollution
Control District (LM-APCD). Under 40 CFR Part 58, Appendix A, 2.5, EPA Region 4 is
required to conducted a TSA for each ambient air monitoring organization at least every three
years. The scope of the TSA included the last three complete years of ambient monitoring data
(2008-2010). These data were retrieved using EPA's Air Quality System (AQS) database. The
audit was conducted o v e m ~ e r 29-30,2011 at the APCD offices located at 850 Barrett Avenue
in Louisville and included visits to each of the seven monitoring site locations. APCD staff
interviewed during the audit included Cynthia Lee, Billy DeWitt, Mary Layman, Ron Jacobs,
Mario Beeler, Terry Carby and Susan Bowman. Auditors from EPA Region 4's Science and
Ecosystem Support Division (SESD) included Doug Jager and Richard Guillot. A questionnaire
was completed by the APCD prior to the TSA which was used a guide for the audit and is
included at the end of this report.
During the TSA, SESD responded to a request from EPA Region 4's Air, Pesticides and Toxic
Management Division (APTMD) for the review of the Wyandotte (AQS #21- 111-0044) monitoring
site and surrounding area for a possible replacement location. This review was prompted due to
pending construction plans at the current monitoring site location.
NETWORK DESIGN AND SITING
Network Size:
The APCD is a local monitoring agency for the State of Kentucky, operating seven monitoring
sites within Jefferson County. These sites are Bates Elementary (AQS #21-111-0027), Southwick
(AQS #21-111-0043), Wyandotte (AQS #21-111-0044), Watson Lane (AQS #21-111-0051), Cannons Lane (AQS
#21-lll-0067), Fire Station 20 (AQS #21-111-1019) and Firearms Training (AQS #21-111-1041). The
Cannons Lane site serves as the only National Core (NCore) monitoring location within the state.
At these seven sites the APCD operates individual monitors/samplers for a total of 2 carbon
monoxide (CO), 3 sulfur dioxide (S02), 2 nitrogen dioxide (N02), 3 ozone (03), 4 manual fine
Particulate Matter (PM2.s), 1 manual Particulate Matter (PMw), 2 PM2.s Speciation, 2 PM2.s
Carbon, 2 PM
2
.s Collocated, 4 PM
2
.s Continuous and 4 PM10 Continuous monitors. In addition,
4 sets of meteorological instruments are operated within the monitoring network. More detailed
information concerning the distribution of these monitors is available in the attached
questionnaire at the end of this report.
Network Design and Siting:
No deficiencies were noted with respect to network design and siting. The APCD utilizes
Teflon tubing for its probe systems as required under 40 CFR Part 58 Appendix E 9(a).
Additionally, all of the probes were well within the required residence time of 20 seconds as
required under 40 CFR Part 58 Appendix E 9(b). APCD staff did express concerns that the
Bates Elementary (AQS #21-111-0027) monitoring site may need to be relocated in the next few
years. The cause for this relocation is the large amount of growth in that area and the current
location of the monitor may be used for roadway development.
Page 3 of 55
The Wyandotte (AQS #21-111-0044) monitoring site is located in Wyandotte Park and situated on the
roof of a closed recreation building. The city of Louisville has announced plans to revitalize the
park and as a result the building on which the samplers are located is targeted for demolition. A
review of the Wyandotte (AQS #21-111-0044) site and the surrounding area was conducted during the
TSA. A number of possible site locations were visited at nearby churches and schools - none of
these were found to meet siting requirements. One location was found at a facility known as the
Hazelwood Center; this facility is located on state property just within a 1 mile radius from the
current Wyandotte site. Due to the limited availability of replacement sites, EPA encouraged the
APCD to work with the city in obtaining an area in the new park space for the sampling
equipment.
Network Audit:
The previous TSA was conducted in 2007; the concerns identified in that audit have been
addressed by the APCD.
Non-criteria Pollutants:
The APCD does not currently operating any non-criteria based pollutant monitoring. A toxic
monitoring study was completed prior to the TSA and sampling discontinued; data analysis for
the study was scheduled beginning shortly. The APCD was coordinating these efforts with the
University of Louisville. No further toxics studies I monitoring were planned at the time of the
TSA.
RESOURCES AND FACILITIES
Instruments and Methods:
Instrumentation in use by the APCD, namely the analyzers and samplers for the criteria pollutant
network were found to meet the requirement under 40 CFR Part 58, Appendix A, l.lc that
these instruments be federal reference (FRM) or equivalent methods (FEM).
Staff and Facilities:
The primary facilities for the APCD are located at the Urban Government Center, 850 Barrett
A venue, Louisville, Kentucky, 40204. These facilities are adequate to support the function of
the ambient monitoring program. These include the staff offices, maintenance and repair, data
processing and filter handling and storage areas.
The APCD conducts cross training for each of the monitoring positions in the program. This
cross training is documented in the personnel records for each employee. APCD staff regularly
attends the annual Region 4 Air Monitoring Workshop as well as national conferences when
available and monitoring instrument training as needed.
Laboratory Facilities:
The APCD has its own PM
2
.
5
filter weighing facilities. No deficiencies were noted in the
APCD's laboratory facilities.
DATA AND DATA MANAGEMENT
Page 4 of 55
I'
' '
Data Processing and Submittal:
The APCD submits data directly to EPA's AQS database. Data are typically reviewed and
submitted on a monthly basis. The computer equipment currently in use meets the needs of the
program. APCD staff is well trained in the use of the data handling software as well as being
familiar with the AQS database. Implementation of the new AirVision software is ongoing.
Data Review:
Data completeness reports from the three years of data (2008-2010) show recovery to be in the
mid -90 percentile. The agency is doing an excellent job in this area and is commended on its
efforts.
The APCD is responsible for conducting the biweekly performance checks and the annual
performance audits under 40 CFR Part 58 Appendix A3.2.1 & 3.2.2. The State of Kentucky
does conduct quarterly audits on the APCD, but these are only a representative sample of the
monitoring instruments.
Data Correction:
Documentation was inspected for missing data handling and corrective actions within the
monitoring program operations. These documents were found to be in good order and in
accordance with the quality assurance project plan and the standard operating procedures.
Data coding in EPA's AQS database was found to be complete and consistent within the data
reviewed period.
Annual Data Certification:
The APCD is responsible for the submission of the annual certification letter to EPA. For the
2008-2010 time period this submission was timely and in accordance with EPA requirements.
QUALITY ASSURANCE/QUALITY CONTROL
Status of Quality Assurance Plan:
The APCD operates under its own quality assurance project plan; this plan has been approved
and is up-to-date. The standard operating procedures (SOP's) have been reviewed and approved
by EPA. No deviations from the QAPP or SOP' s were noted during the TSA.
Audit Participation:
The APCD regularly participates in the National Performance Audit Program (NPAP) & PM
2
.
5
Performance Evaluation Program (PEP) as required by 40 CFR Part 58 Appendix A, 2.4. The
latest dates for these audits can be found in the attached questionaire.
Standards and Traceability:
Flow standards and reference material standards documentation were reviewed during the TSA.
This documentation was found to demonstrate the standards in use by the APCD were within
required time limitations.
Page 5 of 55
CONCLUSIONS AND RECOMMENDATIONS
Discussion:
The APCD is doing an excellent job operating and maintaining the ambient air monitoring
program. The staff is well trained in their respective duties and cross trained to cover for each
other. The APCD's data recovery and completeness is in the mid 90% range, far above EPA's
required 75%. The program's records were complete and up-to-date; the quality assurance
documentation was readily available and current. Data submissions to EPA' s AQS database
were timely as well as the annual certification of its monitoring data.
Page 6 of 55
''
APPENDIX 1
United States
Environmental Protection Agency
Region 4
Science & Ecosystem Support Division
Athens, Georgia 30605
Ambient Air Monitoring
Technical System Audit Form
Page 7 of 55
Table of Contents
1) GENERAL INFORMATION
a) Program Organization
b) Personnel
c) Training
d) Facilities
2) QUALITY MANAGKMENT
a) Quality Assurance and Quality Control
i) Status of Quality Assurance Program
ii) Audits
b) Planning Documents (including QMP, QAPP's, & SOP's)
c) General Documentation Policies
d) Corrective Action(s)
e) Quality Improvement
3) NETWORK MANAGEMENT I FIELD OPERATIONS
a) Network Design
b) Changes to the Network since the last audit
c) Proposed changes to the Network
d) Field Support
i) Instrument Inventory
ii) Calibration
iii) Repair
iv) Logbooks and Records
4) DATAMANAGEMENT
a) Data Handling
b) Software Documentation
c) Data Validation and Correction
d) Data Processing
e) Internal Reporting
f) External Reporting
5) LABORATORY OPERATIONS
a) Routine Operations
b) Laboratory Quality Control
c) Laboratory Preventative Maintena.IJ.ce
d) Laboratory Record Keeping
e) Laboratory Data Acquisition and Handling
f) Specific Pollutants: Particulate Matter
. .
(Including High Vol PM
10
, Low Vol PM
10
, PMz.
5
, PM
10
_
2
_
5
& Pb)
Page 8 of 55
. '
1) GENERAL INFORMATION
a) Program Organization
Organization N arne:
Address: (include physical and mailing addresses if different)
850 Barret Avenue
City, State, and Zip Code:
Louisville, KY 40204
Phone:
502-57 4-6000
Agency Director:
Lauren Anderson
Ambient Air Monitoring (AAM) Network Manager:
Cynthia Lee
Quality Assurance Manager:
Marty Layman
QA Auditors:
Ron Jacobs, Mario Beeler, Terry Carby
Field Operations Supervisor I Lead:
Billy DeWitt
Laboratory Supervisor:
Susan Bowman
QA Laboratory Manager:
Terry Carby
Data Management Supervisor I Lead:
Billy DeWitt
AQS Submitter:
Marty Layman
Page 9 of 55
Insert an Organizational Chart (or provide a hard copy during the audit):
Executive Director
I
Lawen Anderson
I
Quality Assurance Officer
Many Layman
Environmental Programs & Planning Manager
Cynthia Lee
Air Quality Unit Supervisor
Billy DeWitt
[
Air Quality Environmental Coordinator
l I
Air Pollution Tedmician ll
Bryan Jones
J
Claudea Betcne.r
[
Air Poll ution Environmental Specialist
I
Air Pollution Technician ll
Susan Bowman
I
Daniel Durrett
Air Pollution Specialist
I
Air Pollution Technician lJ
Terry Carby
I
Steve Oswald
Air Poll ution Environmental Specialist
I I
Ai1 Pollution Technician II
Ron Jacobs
J I
Deborah Vavrek
Air Pollution Technician 11
I
Mario Beeler
J
Page 10 of 55
b) Personnel
List available personnel and select their primary duties:
Site
Other Non-
Network
QC QA
Equipment
Data & Data Financial
Operation
Ambient Air
Name Design and
Activities Activities
Repair &
Management Management
(PM,
Monitoring
Siting Maintenance Gaseous,
Met)
Duties
Bryan Jones X X X X
Susan Bowman X X X X
Deborah Vavrek X X X X X
Daniel Durrett X X X X X
Ron Jacobs X X X
Terry Carby X X X
Claudea Belcher X X X X X
Mario Beeler X X X X
Steve Oswald X X X X X
Marty Layman
X
X X X X
Billy DeWitt X X X X X X
Cynthia Lee X X X X X X
X
Page 11 of 55
In your agency, are site operators responsible for running all of the instruments at their assigned sites, certain instruments (ex.
0
3
) at multiple sites, or a combination of the two?
Our operators are assigned to certain instruments at multiple sites.
Page 12 of 55 _
List personnel who have authority or are responsible for:
Activity Name Title
QA Training Field/Lab Billy DeWitt Environmental Supervisor
Cynthia Lee Environmental
Purchases Greater than $500 Billy DeWitt Environmental Supervisor
Equipment and Service Contract
Billy DeWitt Environmental Supervisor

Staff Appointment Billy DeWitt Environmental Supervisor
Operations Billy DeWitt Environmental Supervisor
Questions Yes No Comments
Does your agency utilize any contractors in
your air monitoring program? If no, skip to X
the next table.
Who is responsible for oversight of contract
personnel?
What steps are taken to ensure contract
personnel meet training and experience
criteria?
Does the contractor follow an EPA approved
QAPP?
- Where/how is this documented?
How often are contracts reviewed and/or
renewed?
Comment on the need for additional personnel, if applicable:

List your district/regional offices and associated staff below (State Agencies Only)
Name Address Staff
Page 13 of 55
c) Training
Question Yes No Comments
Does the agency have a training program and
X
Training is specific to job duties and standard
training plan? operating procedures.
Where is it documented?
Our training documents are located on a network drive
available to all of our associates.
Does it make use of seminars, courses, and/or
X
EPA sponsored courses?
Are personnel cross-trained for other ambient
X
air monitoring duties?
Are training funds specifically designated in
X
the annual budget?
Does the Training Plan Include:
X
1. Training requirements by position
2. Frequency of Training X
3. Training for contract personnel X
4. A list of core QA related courses X
Indicate below the three most recent training events and identify the personnel participating in them:
Event Date(s) Participant(s)
I. National Air Quality Conferences
March 7-10,
Billy DeWitt
2011
2. Region 4 Air Monitoring Conference May, 2011 Larry Garrison
3. Met-One BAM instrument training June, 2011 Entire Section
Page 14 of 55
d) Facilities
Identify the principle facilities where the agency conducts work related to air monitoring. Do not include monitoring stations, but include facilities
where work is performed by contractors or other organizations. Select which purpose(s) each facility serves. Add additional lines as necessary
Data Criteria Gas
Standards Air Taxies
Facility Address
General Verification Instrument
Certification
PM Filter Records
Maintenance
Air Taxies
Office Space and Maintenance Weighing Storage Laboratory
Processing and Storage
I Calibration and Storage
Urban Government Center
850 Barret A venue X X X X X X X
Louisville, KY 40204
Are monitoring sites ever used for storage of equipment, spare parts or supplies?
Yes, some spare and routine spare parts or supplies are stored at monitoring sites.
Identify any facilities that should be upgraded. Identify by function and any suggested improvements or recommendations.
None
Are facilities adequate concerning safety? If not, please explain and give suggested improvements or recommendations.
Yes
Page 15 of 55
Are there any significant changes likely to be implemented to agency facilities within the next three
years? No
Facility Function Proposed Change - Date
Comment on the agency's need for additional physical space (laboratory, office,
storage, etc.)
None required
2) QUALITY MANAGEMENT
a) Quality Assurance and Quality Control
i) Status of Quality Assurance Program
QA activities are performed and supported by sources uniquely different from those used
in routine QC activities. Independent I dedicated equipment, different personnel and
calibration methodologies are purposely used in performing QA audits, performance
checks, etc.
Does the agency perform QA activities with
X
internal personnel? If no, skip this table.
Does the agency maintain a separate
laboratory to support quality assurance X
activities?
Has the agency documented and
implemented specific audit procedures X
separate from monitoring procedures?
Are there two levels of management
separation between QA and QC operations? X
Please explain:
Does the agency have separate auditing
equipment and standards (specifically X
intended for sole use) for audits?
Page 16 of 55
Do you conduct biweekly precision point checks?
Yes
Are they automated or conducted manually?
All bi-weekly precision points are conducted manually.
Select which of the following additional QC you conduct at your gaseous sites
Typically
How?
Precision Checks Frequency
Performed?
Manually Automated
Precision Point Yes X Bi-Weekly
Zero Precision
Yes
Span
X Daily
Zero Precision Yes X Daily
Probe Line
Yes Bi-Weekly
Integrity Checks
X
Other:
ii) Audits
Does the agency have separate facilities to support
X
audits and calibrations?
If the agency has in place contracts or agreements
with another agency/contractor to perform The Kentucky Division of Air Quality performs
audits/calibrations, please name the organization quarterly audits of our instruments.
and briefly describe the type of agreement.
Does the agency maintain independence of audit
X
standards and personnel?
Do any site operators audit their own sites? X
Does the agency have a certified source of zero air
X
for performance audits?
How do you generate your zero air? Both zero air tanks and zero air generators.
Does the agency have procedures for auditing
and/or validation performance of meteorological X
monitoring?
Has the agency established and documented criteria
X
to define agency-acceptable audit results?
Page 17 of 55
Axe your sites regularly reviewed for Appendix
X
Frequency: Annually by QAJQC
E siting criteria? coordinator and KY DAQ
Do you conduct internal audits of your air
X
monitoring agency?
(1) How frequently? Annually
(2) What type of audit is conducted (e.g., Instrument performance audits are conducted quarterly.
performance or systems audit)? Systems audits are conducted annually.
(3) Who receives the results of these audits?
Supervisor of the Air Monitoring section and agency
QAJQC coordinator.
(4) Do you report these results to EPA? X Report performance audits to AQS.
Please provide a list of internal audit standards currently being used (these do not include standards
used for calibrations and/or biweekly checks). Add additional lines as necessary.
Name Model Number
Date of Last Approximate Age
Certification (years)
TECO 70020-364 02/24/2011 12
Bios International DC-2B 10/17/2011 6
Scott Gas ALM046091 08/01/2011 0.25
Chinook SLP203 07112/2011 4
Chinook SLP203 07/13/2011 7
BIOS DCL-H Rev. 1.08 06/06/2011 10
Vaisala Humidity and
HM141
Temperature Indictor
Ser#X3810013
02/08/2011 12
and Probe set
**Please have certifications of standards available for viewing during the audit
Page 18 of 55
Does your agency participate in NPAP, PM
25
PEP, Pb PEP and other performance audits
X
performed by an external party and/or using
external standards?
If the agency does not participate, please
explain why:
Are NPAP audits performed by QA staff, site
operators, calibration staff, and/or another X EPA auditors
group?
Is your agency audited by the State (if you are a
X
local agency)?
(1) How frequently? Quarterly, Annually
(2) What type of audit is conducted (e.g.,
Performance quarterly, Systems audit annually
performance or systems audit)?
(3) Who receives the results of these audits?
Air Monitoring Supervisor, QA/QC coordinator, Agency
Director, EPA
(4) Do you report these results to EPA? X Reported to AQS
Who is primarily responsible for coordinating participation in:
1) The National Performance Audit Program (NPAP)?
Supervisor- Billy DeWitt
(2) PM
2
.s Performance Evaluation Program (PEP)?
Supervisor - Billy DeWitt
(3) Lead Performance Evaluation Program (PEP)?
Supervisor- Billy DeWitt
Please complete the table below:
Parameter Audited Date of Last NP AP and/or PEP Audit
co
09/06/2007
03
02/24/2011
so2
09/06/2007
N02
09/05/2007
PM2.s
07114/2010
Pb N/A
Page 19 of 55
b) Planning Documents
QMP Questions Yes No Comments
Has the QMP been approved by EPA within the last
Date of Original Approval:
X Date of Last Revision: 0112007
five years?
Date of Last Approval: 0112007
QAPP Questions Yes No Comments
Date of Original Approval:
Has the QAPP been reviewed by EPA?
01131/2007
X
Date of Last Revision: 06/01/2011
Date of Last Approval: 0113112007
Does the State review your QAPP prior to EPA
review? (local agencies only)
X
Does your agency have any revisions to your QAPP
N-Core revisions submitted to EPA,
X more revisions involving changes to
pending?
NAAQS at end of 2011.
How does the agency verify the QAPP is fully Supervisor and Manager implement procedures
implemented? outlined in QAPP
How is the QAPP available to the staff (e.g .. , Electronically on shared network drive, hard copy
electronically, hard copies at site, etc.) in main office.
SOP Questions Yes No Comments
How does the agency verify that the SOPs are
Official copies of SOPs are maintained in the office
implemented as provided (e.g., staff are regularly
of the supervisor and network drive. Staff observed
for correct implementation and sign approval on
observed for correct implementation of SOPs)?
SOP signature page.
How are revisions to the SOP distributed?
Revisions are electronic and once approved a hard
copy is archived in supervisor's office.
How are SOPs available to the staff (e.g .. ,
Electronically, hard copies, and at site.
electronically, hard copies at site, etc.)
N-Core Lead SOP waiting on shipping
Are any new monitoring SOPs needed? If yes,
X
specific information. Currently
please list in comments section. revising Non-TL CO SOP and
URG3000 Speciation SOP
List all of the agencies current SOPs:
Title
Date of Last EPA
Pollutant of Concern (if applicable)
Approval
Issuance of Air Quality Alerts and
Reporting of Exceedances
Data Handling and Custody
Gravimetric Analysis for
Measurement of Fine Particulate 11/2007 PM2.5
Matter as PM2.5
Field Operations for Measurement of
Fine Particulate Matter as PM2.5 - Ol/2009 PM2.5
Using Rupprecht & Patashnick or TEl
Page 20 of 55
Partisol-Plus 2025
Field Operations for the Speciated
Measurement of Fine Particulate 2008 PM2.5
Matters as PM2.s
Sequential Particulate Speciation
System Operation Manual- Under Development PM2.5
URG3000N
Standard Operating Procedure
For
Monitoring of Ozone in Ambient Air
Unknown 03
Utilizing Thermo Environmental
Instruments Model 49 Ozone
Analyzers
For
Monitoring Trace Level
Sulfur Dioxide Pending- Submitted to
S02
In Ambient Air EPA 07/2011
Utilizing Thermo Electron
Corporation
Model 43i-TLE S02 Analyzer
Standard Operating Procedure For
Nitrogen Oxides Monitoring
Performance Testing
Unknown NOx
Utilizing Thermo Environmental 42C
Series NOx Analyzer
For
Monitoring Trace Level Unknown co
Carbon Monoxide
In Ambient Air
Standard Operating Procedures for Pending - Submitted to
PMlO, PM2.5, PMl0-2.5
Met One BAM l 020 EPA 07/2011
Standard Operating Procedures for the Pending - Submitted to
NOy
TECO 42i-Y NOy Analyzers EPA07/20l1
Page 21 of 55
Standard Operating Procedures for Pending- Submitted to
Meteorological Measurements EPA 07/2011
Standard Operating Procedures for
Unknown PM10,PM2.5
R&P/Thermo TEOM Series 1400
Page 22 of 55
c) General Document Policies
Does the agency have a documented
X
Data Handling and Custody
records management plan?
Does the agency have a list of files
considered official records and their media X
type? (i.e., pap_er, electronic)
Does the agency have a schedule for
X
retention and disposition of records?
Are records maintained for at least three
years?
X
Who is responsible for the storage and
Cynthia Lee, Environmental Manager
retrieval of records?
What security measures are utilized to Records are kept in secure file room or secure electronic
protect records? database.
Where/when does the agency rely on
Data retrieval from air monitoring instruments.
electronic files as primary record?
What is the system for storage, retrieval Utilize Agilaire EDAS software on a secure server. Backup
and backup of these files? occurs daily to secure Louisville Metro servers.
Page 23 of 55
g) Corrective Action(s)
Does the agency have a comprehensive corrective action
X
program in place?
Have the procedures been documented? X
1. As a part of the QA project plan? X
2. As a separate standard operating procedure? X
Does the agency have established and documented
X
corrective action limits for QA and QC activities?
Are procedures implemented for corrective actions based on results of the following which fall
outside of established limits:
l. Performance Evaluations X
2. Precision Goals X
3. Bias Goals X
-
4. NP AP Audits X
5. PEP Audits X
6. Validation of one point QC Check Goals X
7. Completeness Goals X
8. Data Audits X
9. Calibrations and Zero Span Checks X
10. Technical Systems Audit X
Have the procedures been documented? X
How is responsibility for implementing corrective actions assigned? Briefly discuss
Corrective Action Reports created by the instrument operator are documented and
reviewed by Environmental Specialists, Environmental Supervisor, and QA/QC
Coordinator. The Environmental Supervisor verifies that corrective procedures
are implemented.
Page 24 of 55
''
How does the agency follow up on implemented corrective actions?
By documentation of both the Corrective Action Reports and Chart Audits the agency
is able to track corrective action effectiveness.
Please fill out the table below for [!recision
Pollutant Action Level Corrective Action (if exceeded)
Redbook Guidance
Action Level Reference
Precision Point
or Span drift > QA Handbook Volume
03
7% difference, Multipoint Calibration II, Appendix D Revision
Zero drift> No. 1 Page 3 of 30
2% difference.
Precision Point
or Span drift >
QA Handbook Volume
co
10%
Multipoint Calibration II, Appendix D Revision
difference, Zero
drift> 2%
No. 1 Page 5 of 30
difference.
Precision Point
or Span drift >
10%
QA Handbook Volume
N02 difference, Zero
Multipoint Calibration II, Appendix D Revision
drift> 3%
No. 1 Page 7 of 30
difference.
Precision Point
or Span drift >
LO% QA Handbook Volume
so2 difference, Zero Multipoint Calibration II, Appendix D Revision
drift> 3% No. I Page 9 of 30
difference.
Please fill out the table below for accuracy
Pollutant Action Level Corrective Action (if exceeded)
Redbook Guidance
Action Level
% difference at
Operator notified and performs multi-
QA Handbook Volume
0 3 any audit level
point precision check. If operator check
II, Appendix D Revision
% difference> 15%, then multi-point
> 15%
calibration.
No. 1 Page 3 of 30
% difference at
QA Handbook Volume
co any audit level
> 15%
No. 1 Page 5 of 30
calibration.
QA Handbook Volume
% difference at
N02 any audit level
%difference> 15%, then multi-point
No. I Page 7 of 30
> 15%
calibration.
Page 25 of 55
% difference at
QA Handbook Volume
so2 any audit level
>15%
No. I Page 9 of 30
calibration.
At what point do you invalidate data?
Data invalidated whenever precision point or zero/span checks are outside of acceptable
tolerance levels. Data invalid from point of last successful precision point check.
Page 26 of 55
h) Quality Improvement
Have all deficiencies indicated on the previous
X
TSA been corrected? If not, explain.
What actions were taken to improve the quality SOPs and QAPP updated. Data management system
system since the last TSA? upgraded.
Since the last TSA, do your control charts
indicate that the overall data quality for each X
pollutant steady or improving?
For areas where data quality appears to be
Any areas of declined data quality are
X generally due to aging instrumentation
declining, has a cause been determined?
or lack of vendor responsiveness.
Are there pending plans for quality Purchase of new instruments to
improvement such as purchase of new or
X
modernize PM and gaseous network.
improved equipment, standards, or Purchase new data acquisition system
instruments? and move to digital acquisition of data.
Page 27 of 55
3) NETWORK MANAGEl\1ENT/FIELD OPERATIONS
a) Network Design
Complete the table below for each of the sites in your air monitoring network (active in the last three years) with the number of instruments measuring
each pollutant (including NCore low level instruments- e.g. 1 low level CO + 1 regular CO = 2 CO instruments).
Manual Collocated Continuous
>-.
0()
0
0
N N
=
e
AQSID Common Site Name
~
0 0
,., .,.,
0 V1 .9 .,., =
.,.,
0
.,.,
0
u
z
0
"'

i ~
N_.8 <-<
i "'

0 Cl)
~ ~ a
~
~
2
~ 8 . ~ ~ Q)
"' ~
21-111-0027 Bates Elementary 1 1 1
21-111-0043 Southwick 1 1 1 2 1
21- 111-0044 Wyandotte 1 1
21-111-0051 Watson 1 1 1 1 1
21-111-0067 Cannons Lane I I 2 1 I 1 2 2 I I 1 1
21-111-1019 Fire 20 1
21-111- 1041 Firearms Training 1
Page 28 of 55 _
Complete the table below with the number of spare monitor(s) you have on hand for measuring each pollutant (including NCore low level instruments).
Manual Collocated Continuous
Pb co so2 NOz 0 3
Meteor-
PM2.s PM2.s ology
PMz.s PM10
speciation Carbon
PMz.s PMIO PM2.s PM10
3 2 2 3 1 1 1 1
Page 29 of 55
Select which of the following are typically found at your Gaseous and PM sites
Equipment/ Supplies Gaseous PM
Data Logger X X
Calibrator X
Gas Blender
Zero Air System X
Perm Tube Oven
Paper Strip Chart
Permanent Site Computer X X
Phone X X
Modem X X
DSL Connection
Cellular Modem Connection
Meteorological Station X X
Interior Temperature Probe X X
Interior Min/Max Thermometer
Air Conditioner I Heater X X
Uninterrupted Power Supply or
Backup Power
Instrument Manuals X X
Instrument Logbooks X X
Site Logbook X X
SOP's X X
Other:
Other:
Page 30 of 55
Select which of the foUowing are typical of your Probe System
Tee'd Probe System X
Retractable Probe System X
Glass Manifold within Probe System
Heat Tape for Moisture Control
If none of the above is applicable, please describe your probe system.
How often do you clean I replace your probe lines?
Twice Annually
What material are your probe lines made of?
Teflon
What material are your inlet funnels made of (e.g. glass, Teflon, plastic)?
Teflon
How often do you change the particulate filter on the back of the instrument?
Bi-Weekly
How often do you clean your glass manifold (if applicable)?
N/A
How do you connect your instrument to your data logger (analog, RS232, or
Ethernet)?
Analog and Ethernet
Page 31 of 55
Question
Yes 1
No
I
Comments
What is the date of the most current Monitoring
June 30,201 1
Network Plan?
Is it available for public inspection? X
I I
Has EPA granted waivers for any of your monitoring sites? No
Are you aware of any sites that are not currently meeting the requirements of 40
CFR Part 58 Appendix D & E? No
Question Yes No Comment
Are hard copy site information files retained by
the agency for all air monitoring stations within X
the network?
Does each station have the required information including:
l. AQS Site ID Number? X
2. Photographs/slides to the four cardinal
X
compass points?
3. Startup and shutdown dates? X
4. Documentation of instrumentation? X
Who has custody of the current network Name: Billy DeWitt
documents? Title: Environmental Supervisor
Does the current level of monitoring effort,
station placement, instrumentation, etc., meet
X
requirements imposed by current grant
conditions?
How often is the network siting reviewed? Annually by QNQC coordinator and KYDAQ
Do any sites vary from the required frequency in
X
40CFR58.12?
Does the number of collocated monitoring
stations meet the requirements of 40 CFR 58 X
Appendix A?
Is each method for PM monitoring collocated
with the same method type? (40 CFR 58 X
Appendix A Section 3.2.5.2 paragraph (a))
Page 32 of 55
b) Changes to the Network since the Last Audit
Please provide infonnation on any site changes since the last audit:
Site Reason (Assessment, lost lease,
Pollutant Site ID Site Address Added/Deleted/ etc.) Provide documentation of
Relocated reason for each site change
PM2.5, PM10,
PMl0-2.5,
Speciation,
21-111-
2730 Cannons Lane,
Louisville implemented N-Core
Lead, Carbon, Louisville, KY Added
NOx, NOy, 03,
0067
40205
site.
S02, CO, Met,
Radiation
21-1 11-
1918 Mellwood
Moved instruments to N-Core site
NOx
1021
A venue, Louisville, Relocated
on 111/2010.
KY 40206
21-111-
1918 Mellwood
Moved instruments to N-Core site
03
1021
on l/l/2010.
KY 40206
21-111-
3510 Goldsmith
co
0046
Lane, Louisville, Relocated Moved toN-Core site on 1/1/2009
KY 40220
21-111-
850 Barret A venue,
Moved to N-Core site on
PM2.5
0048
Louisville, KY Relocated
l/1/2009.
40204
PM2.5 21-111-
3621 Southern
Moved to N-Core site on
Speciation 0043
l/1/2009.
KY 40211
c) Proposed Changes to Network
Please provide information on proposed site changes, including documentation of the need for
change and any required approvals:
Site to be Reason (Assessment, lost lease, etc.)
Pollutant Site ID Site Address Added/Deleted/ Provide documentation of reason for
Relocated each site change
Safety Concerns, Vandalism,
1104 Beecher
Redundancy. Request to discontinue
PMIO, PM2.5
21-111-
St. , Louisville, Deleted
submitted to EPA on 10-18-2011. See
0044
KY 40215
Attachment I to this questionnaire,
"Formal Request to EPA to
discontinue site 21-111-0044".
1735
21-111-
Bardstown This instrument will be moved to
co
1019
Road, Deleted Near-Road Monitoring Site upon
Louisville, KY implementation (20 13).
40205
Page 33 of 55
d) Field Support
On average, how often are most of your stations
3 times _ per __ week_
visited by a field operator?
-
Is this visit frequency consistent for all
X
reporting organizations within your agency?
Page 34 of 55
i) Instrument Inventory
Please list instruments in your inventory:
Pollutant Manufacturer Models
Reference or Equivalent
Method Number
S02 TECO 43C EQSA-0486-060
NOz
TECO 42C RFNA-1289-074
American Ecotech Serinus 40 RFNA-0809-186
co TECO 48C RFCA-0981-054
03 TECO 49C, 49i EQOA-0880-047
PM10 R&P
Partisol Plus 2025 RFPS-1298-127
TEOM 1400 EQPM -1090-079
PM2.5 R&P Partisol Plus 2025 RFPS-0498-118
Pb N/A N/A N/A
Teledyne API 700E
Multi gas calibrator Environics 6100
TECO 146C, 146i
PM
2
.
5
speciation Met One SASS
PM
10
.
2
.
5
speciation N/A N/A N/A
PM10-2.5 FRM mass N/A N/A N/A
Continuous PM
2
.
5
mass Met One BAM1020 EQPM -0308-170
Trace levels (CO) TECO 48i-TLE RFCA-0981-054
Trace levels (S0
2
)
American Ecotech EC 9850 EQSA-0 193-092
TECO 43i-TLE EQSA-0486-060
Trace levels (NO) N/A N/A N/A
Trace levels (NOy) TECO 42i-y EQOA-0880-047
Surface Meteorology
Met One
RMYoung
Data Logger A gil a ire
8816
8832
Others IMACC
FfiR
UV-DOAS
Page 35 of 55
ii) Calibration
Please indicate the frequency of multi point calibrations:
Pollutant Frequency Name of Calibration Method
S02 Quarterly or as needed Dilution System
N02 Quarterly or as needed Dilution System
co Quarterly or as needed Dilution System
03 Quarterly or as needed Dilution System
PMlO Quarterly or as needed Flow Calibration to Standard
PM2.5 Quarterly or as needed Flow Calibration to Standard
Please list the authoritative standards used for each type of flow measurement, indicate the
certification frequency of standards to maintain field materiaVdevice credibility:
Flow Device Primary Standard Frequency of Certification
HiVol Orifice N/A N/A
Streamline Certified by Vendor Annually
Trical N/A N/A
Bios Certified by Vendor Annually
Delta Cal Certified by Vendor Annually
Gilibrators N/A N!A
Environics/TECO
Bios DC-2B Quarterly
Calibrators
Page 36 of 55
..
Please list the authoritative standards and frequency of each type of dilution, permeation and ozone
calibrator and indicate the certification frequency:
Calibrator Primary Standard Frequency of Certification
Permeation Calibrator Flow
Bios DC-2B
Calibrate quarterly, Bios certified
Controller annually
Permeation Calibrator
Vaisala Temp Probe
Calibrate quarterly, Temp.
Temperature standard certified annually
Dilution Calibrator air and gas
Bios DC-2B
Calibrate quarterly, Bios certified
Flow Controllers annually
Field/Working Standard
TEC049C Standard is certified annually
Photometer
Ozone Generator TEC049C Standard is certified annually
Please identify station standards for gaseous pollutants at representative air monitoring stations
Parameter Station(s)
Identification of
Recertification Date(s)
Standard(s)
Primary- Air Liquide Tri-
Fire 20
Blend - EPA Protocol Expires 08/0 l/20 13
co
Cannon' s Lane
Secondary - Liquid Expires 03/03/2012
Technology - EPA Protocol Expires 06/28/2014
Airgas - EPA Protocol
Primary - Air Liquide Tri-
N02 Cannon's Lane
Blend- EPA Protocol Expires 08/0 l/20 13
Secondary - Airgas- EPA Expires 06/09/2013
Protocol
Primary- Air Liquide Tri-
Watson Lane
Blend- EPA Protocol Expires 08/01/2013
so2 Firearms Training
Secondary - Airgas (2) - EPA Expires 03/22/2013
Protocol Expires 08/06/2012
Cannon's Lane
Welder's Supply- EPA Expires 04/04/2012
Protocol
Watson Lane Primary - TECO 49CPS
0 3 Bates Elementary
Secondary - TECO 49CPS
Quarterly
Cannon' s Lane
If an instrument goes down, at what length of time would you recalibrate the
instrument before bringing it back online (24 hours, 48 hours, etc.)? 24 hours
Page 37 of 55
Question . Yes No Comments
Are field calibration procedures included in the
X Location (site, lab, etc.): Site, Office
document SOPs?
Are calibrations performed in keeping with the
guidance in section Vol II of the QA Handbook for X If no, why not?
Air Pollution Measurements Systems?
Are calibration procedures consistent with the
operational requirements of Appendices to 40 CFR X If no, why not?
50 or to analyzer operation/instruction manuals?
Have changes been made to calibration methods
based on manufacturer's suggestions for a particular X
instrument?
Do standard materials used for calibrations meet the
requirements of appendices to 40 CFR 50 (EPA
X
reference methods) and Appendix A to 40 CFR 58
(traceability of materials to NIST -SRMs or CRMs)?
Where do field operations personnel obtain gaseous
Standards delivered by vendor to main office.
standards?
Are those standards certified by:
X
l. The agency laboratory?
2. EPA/NERL standards laboratory? X
3. A lab separate from this agency' s but part
of the same reporting organization?
X
4. The vendor? X
5. Other (describe)
How are the gas standards verified after receipt?
Inspect certification and expiration dates. Perform
pressure check.
Are you involved in the EPA protocol gas
X
certification program?
What equipment is used to perform calibrations Environics 4000, Environics 6100, TECO 146C,
(e.g., dilution devices) and how is the performance TECO l46i, API 700E- all are certified with flow
of this equipment verified? standard Bios DC-2B
Does the documentation include expiration date of
X
certification?
l. Reference to primary standard used? X
2. What traceability is used? Bios DC-2B certified annually.
Is calibration equipment maintained at each station? X
How is functional integrity of this equipment Traceability documentation, logbooks, corrective
documented? action reports.
Who has responsibility for maintaining field
Environmental Specialists.
calibration standards?
Page 38 of 55
..
iii) Repair
a) Who is responsible for performing preventative maintenance?
The instrument operator.
b) Is special training provided to them for performing preventative
maintenance? Briefly comment on background or courses.
Yes, training from previous operator or current staff. Also provided with
preventative maintenance schedule from manuals & SOPs. When available,
EPA and vendor training also implemented.
c) Is this training routinely reinforced? If no, why not?
Yes.
d) What is your preventative maintenance schedule for each type of field
instrumentation?
We follow technical guidance from the manufacturer for specific
instrumentation. If some cases we implement a more stringent
schedule or increase frequency of maintenance.
e) If preventative maintenance is MINOR, it is performed at (check one
or more):
_x_ Field Station
_Headquarters Facilities
_ Equipment is sent to Manufacturer
f) If preventative maintenance is MAjOR, it is performed at (check one
or more):
_x_ Field Station
_x_ Headquarters Facilities
_x_ Equipment is sent to Manufacturer
g) Does the agency have service contracts or agreements in place with
instrument manufacturers? Indicate below which instrumentation is
covered.
No service contracts.
h) Comment briefly on the adequacy of availability of the supply of spare
parts, tools and manuals available to the field operator to perform any
necessary maintenance activities. Do you feel that this is adequate to
prevent any significant data loss?
In most cases spare parts are adequately stocked and available.
Page 39 of 55
i) Is the agency currently experiencing any recurring problem with
equipment or manufacturer(s)? If so, please identify the equipment
manufacturer, and comment on steps taken to remedy the problem.
We are experiencing problems with some of the TECO i-series
gaseous analyzers. TECO has generally acknowledged
instrumentation flaws but have supplied no reasonable guidance to
address the problems. Combined with the terrible customer service
from TECO we have decided to discontinue purchasing from this
company for the foreseeable future.
j) Have you ever lost any data due to repairs in the last 2 years?
More than 24 hours? yes
More than 48 hours? yes
More than a week? yes
k) Explain any situations where instrument down time was due to lack of
preventative maintenance or unavailability of parts.
We have experienced brief occurrences of instrument downtime
with continuous PM monitors due to lack of preventative maintenance from
the operator. Once this issue was discovered, the operator was counseled on
the necessity and importance of preventative maintenance. In addition, the
operator was supplied with a preventative maintenance schedule that is to be
strictly followed.
The section also lost one quarter of data from our NOy analyzer
due to the unavailability of a part. This was due the coincidence of the part
malfunction and a sole source vendor contract negotiation snag between our
government purchasing department and the vendor. This issue has been
resolved.
Page 40 of 55
iv) Logbooks and Records
What type of station logbooks are maintained
Site visits, maintenance, calibration, bi-weekly checks,
at each monitoring station? (Maintenance
audits are all recorded in logbooks.
logs, calibration logs, personal logs, etc.)
What information is included in the station Site visits, maintenance, calibration, bi-weekly checks,
logbooks? audits are all recorded in logbooks.
Who reviews and verifies the logbooks for
Environmental Supervisor, QNQC coordinator
adequacy of station performance?
How often are logbooks reviewed? Quarterly, Annually
How is control of logbook maintained? Audited by QNQC coordinator and KYDAQ
Where is the completed logbook archived? Archived in our main office.
What other records are retained?
1. Zero span record? X
2. Gas usage log? X
3. Maintenance log? X
4. Log of precision checks? X
5. Control charts X
6. A record of audits? X
Please describe the use and storage of these
Site visits, maintenance, calibration, bi-weekly checks,
audits are all recorded in logbooks. Digital charts are
documents.
utilized.
Are calibration records, or at least calibration
X
constants, available to field operators?
Are logbooks backed up regularly to ensure
X
Operators create a digital version for
against theft/vandalism? backup or scan physical logbooks.
Page 41 of 55
3) DATA MANAGEMENT
a) Data Handling
Is there a procedure, description, or a chart which
shows a complete data sequence from point of X Data Handling & Custody SOP
acquisition to point of submission of data to EPA?
Please describe or provide a data flow diagram from
See attachment 2 to this questionnaire, "LMAPCD
collection to submittal of data. Please include detail
regarding data review and validation.
Data Flow for Continuous Monitors/Sensors".
Are procedures for data handling (e.g. data
X
reduction, review, etc.) documented?
In what media (e.g., diskette, data cartridge, or telemetry) and formats do data arrive at the data
processing location? Please list below:
Category of Data (by Pollutant) Data Media and Formats
Gaseous and PM continuous monitor data Telemetry
PM Speciation data Laptop Computers
How often are data received at the processing
Hourly
location from the field sites and laboratory?
Is there documentation accompanying the data
regarding any media changes, transcription, or flags
X
which have been placed into the data before data are
released to agency internal data processing?
Data loggers are routinely programmed to supply
- Describe the type of documentation data warning or alarm flags. Also operators
document notes via digital logbooks.
How is data actually entered into the computer
Computerized transcription and digitized strip
system (e.g. computerized transcription (copy from
charts. If there is a failure in the telemetry system
disk or data transfer device), manual entry,
digitization of strip charts, or other)?
operators transcribe instrument data manually.
For manual data, is a double-key entry system used Auditors must be provided with
(e.g., a second pair of eyes double checking for X electronic instrument data to
transcription errors)? validate operator entry.
Page 42 of 55
b) Software Documentation
Does your agency submit data directly to AQS? X
Does your agency participate in AirNow? X
Precision/Accuracy check data entered into
How does your agency process PIA data? spreadsheet and provided to Specialist. Specialist
enters data into AQS spreadsheet.
Does the agency have information on the reporting
X
of precision and accuracy data available?
What software is used to prepare air monitoring data
for release into the AQS and Air Now database?
Use Microsoft Excel spreadsheets for PIA checks
Please list the documentation for the software
currently in use for data processing, including the
and use Agilaire data acquisition system to verify.
names of the software packages, vendor or author,
AQS provided spreadsheet used to convert PIA
revision numbers, and the revision dates of the
checks to AQS format.
software.
What is the recovery capability in the event of a One or two day's worth of data could potentially be
significant computer problem (i.e. how much time lost. Because hard and electronic back-up copies
and data would be lost)? are maintained there would likely be no data lost.
Has your agency tested the data processing software
to ensure its performance of the intended function is
X
consistent with the QA Handbook, Volume II, and
Section 14.0?
Does your agency document software tests? X If yes, provide the documentation
Page 43 of 55
c) Data Validation and Correction
Has your agency established and documented the
X
validation criteria?
Does documentation exist on the identification and
applicability of flags (i.e., identification of suspect
X
values) within the data as recorded with the data in
the computer files?
Does your agency document the data validation
criteria including limits for values such as flow
X
rates, calibration results, or range tests for ambient
measurements?
1. If yes, please describe what action the data
validator will take if he/she find data with Flags the data and applies any appropriate codes to
limits exceeded (e.g., flags, modifies, deletes, data that is invalid due to exceeded limits.
etc.)
If a limit is exceeded it will be reported on PIA
2. If yes, give examples to illustrate actions taken
forms created by the operator or auditor. These
forms along with digitized charts can be used as a
when limits are exceeded.
basis for the data validator to place any appropriate
flags or codes on invalid data.
How does the agency track missing data?
Documented in 3 level chart audits and in data
acquisition software.
Please describe how changes made to data that were Documented in 3 level chart audits and in data
submitted to AQS and AirNow are documented. acquisition software.
Who has signature authority for approving Name: Marty Layman
corrections? Program Function: QNQC Coordinator
What criteria are used to determine a data point PIA limits exceeded, data Jogger flags, operator
should be deleted? Discuss briefly observed irregularities or errors.
Data would be reprocessed if a data logger problem
What criteria are used to determine if data need to was found that inaccurately transmitted analyzer
be reprocessed? Discuss briefly data. The data would be extracted directly from
instrument.
Are corrected data resubmitted to the issuing group
for cross-checking prior to release?
X
Page 44 of 55
d) Data Processing
Does the agency generate data summary reports? X
Please list at least three reports routinely the information requested below.
Report Title Distribution Period Covered
Raw Data Report Monthly l Month
Data Completeness Report Monthly 1 Month
Precision and Accuracy Report Monthly l Month
How often are data submitted to AQS and AirNow? Monthly to AQS, Hourly to AirNow.
Briefly comment on difficulties the agency may
have encountered in coding and submitting data None.
following the guidance of AQS guidelines
Does the agency routinely request a hard copy
X
printout on submitted data from AQS?
Are records kept for at least 3 years by the agency
X
in an orderly, accessible form?
If yes, does this include:
X
1. Raw Data?
2. Calculation? X
3. QC Data? X
4. Reports? X
If no, please comment
Are PM
10
concentrations corrected to EPA standard
temperature and pressure conditions (i.e. 298.K, X
760 mm Hg) before input to AQS?
Are PM
2
.
5
and Lead concentrations reported to AQS
X
under actual (volumetric) conditions?
Are audits on data reduction procedure performed
X Frequency - Monthly
on a routine basis?
Are data precision and accuracy checked each time
they are calculated, recorded, or transcribed to X
ensure incorrect values are not submitted to EPA?
Page 45 of 55
e) Internal Reporting
What internal reports are prepared and submitted as a result of the audits required under 40 CFR
58, Appendix A?
Report Title Frequency
Quarterly Agency Audit Form Quarterly
Precision and Accuracy Report Quarterly
What internal reports are prepared and submitted as a result of precision checks also required under
40 CFR 58, Appendix A?
Report Title Frequency
Bi-Weekly Agency Precision Form Bi-Weekly
Precision and Accuracy Report Monthly
Do either the audit or precision check reports
indicated include a discussion of corrective actions X
initiated based on audit or precision check results?
Who has the responsibility for the calculation and preparation of data summaries? To whom are
such summaries delivered?
Name Title Type of Report Recipient
Ron Jacobs Environmental Specialist Data Completeness Billy DeWitt
Marty Layman
Environmental Precision and Accuracy
Billy DeWitt
Coordinator Report
Marty Layman
Environmental AQS Final Review
Billy DeWitt
Coordinator Summary
Page 46 of 55
f) External Reporting
For the past 3 calendar years, please list all quarters that data were submitted
beyond the 90 day requirement:
No submittals late.
Identify the individual within the agency with the responsibility for reviewing and
submitting the data to AQS.
Marty Layman- QNQC Coordinator
Does your agency report the Air Quality Index? X
Has your agency submitted its annual data summary
X
report (as required in 40 CFR 58.26)?
If yes, did your agency's annual report include the following:
1. Annual precision and accuracy information
X
described in Section 4 of Appendix A?
2. Location, date, pollution source and duration of all
X
episodes reaching the significant harm levels?
Is Data Certification signed by a senior officer of your
X
agency?
4) LABORATORY OPERATIONS
a) Routine Operations
What analytical methods are employed in support of your air monitoring network? Add other
pollutants not listed to the table.
Pollutant Analysis Name or Description of Method
PM10
PM2.s
Weigh Filters, Speciation Gravimetric Analysis, RTI
Pb
PM10.2.s
Please describe areas where there have been difficulties meeting the regulatory
requirements for any of the above analytical methods.
Please identify the current versions of written methods, supplements, and guidelines that are used in
our a enc . Add other ollutants not listed to the table.
Page 47 of 55
Analysis Documentation of Method
PM10
PM2.s
Gravimetric Analysis for Measurement of Fine Particulate Matter as PM2.5
Pb
PMJ0.2.s
Were procedures for the methods listed
above included in the agency's QA Project X
Plan or SOPs and reviewed by EPA?
Are the SOPs easily/readily accessible for
X
use and reference?
Does your lab have sufficient
X
instrumentation to conduct analyses?
Please describe needs for laboratory instrumentation
b) Laboratory Quality Control
Please identify laboratory standards used in support of the air monitoring program,
including standards which may be kept in an analytical laboratory and standards which
may be kept in a field support area or quality assurance laboratory that is dedicated to the
air monitoring program (attach additional sheets if appropriate):
Parameter Type ID I Serial Number Last Recertification Date
Weights Troemner IGDL 4-7-11
Temperature Vaisala - wall X0840020 12-21-10
Relative Humidity V aisala - wall X0840020 12-21-10
Barometric Pressure N/A N/A N/A
Balance Mettler Toledo 1118070040 2-24-11
Other Vaisala - hand held 023155 2-8-11
**Please have certifications of standards available for viewing during the audit
Page 48 of 55
Are all chemicals and solutions clearly
X N/A
marked with an indication of shelf life?
Are chemicals removed and properly
X N/A
disposed of when shelf life expires?
Are only ACS grade chemicals used by
X N/A
the laboratory?
Comment on the traceability of chemicals used in the preparation of calibration standards.
NIA
Does the laboratory purchase standard solutions such
X
as those for use with lead or other metals analysis?
Title:
Are all calibration procedures documented? X Revision Number:
Document Location:
Are at least one duplicate, on blank, and one standard
X N/A
or spike included with a given analytical batch?
Briefly describe the laboratory's use of data derived
N/A
from blank analyses:
Are criteria established to determine whether blank
N/A
data is acceptable?
X
How frequently and at what concentration ranges does the lab perform duplicate analysis?
What constitutes an acceptable agreement?
N/A
Please describe how the lab uses data obtained from spiked samples, including the
acceptance criteria (e.g., acceptable percent recovery).
NIA
SESD Project #: 11-0044 Page 49 of 55
..
Does the laboratory routinely include samples of
X N/A
reference material within an analytical batch?
If yes, indicate frequency, level, & material
Used
Are mid-range standards included in analytical
X N/A
batches?
Please describe the frequency, level, and compound
N/A
used in the comments section.
Are criteria for real time quality control established
that are based on results obtained for the mid-range X N/A
standards discussed above?
If yes, briefly discuss them in the comments
section or indicate the documentation in which
they can be found:
Are appropriate acceptance criteria for each type of
X N/A
analysis documented?
c) Laboratory Preventative Maintenance
For laboratory equipment, who has the responsibility
Susan Bowman
for performing preventative maintenance?
Is most maintenance performed in the lab? X
Is a maintenance log maintained for each major
X
laboratory instrument?
Are service contracts in place for major analytical
X
Scales and Weights
instruments? certified/calibrated by vendor.
d) Laboratory Record Keeping
Are all samples that are received by the laboratory
All Filters are scanned in the data
X base using bar code scanners to
logged in?
document serial numbers.
If appropriate, is sample shipping temperature
When sampled filters are received,
X the temp and date is recorded on the
recorded upon arrival?
filter custody form.
Discuss sample routing and speci.al needs for analysis
Field and Lab SOPs for Gravimetric Analysis
(or attach a copy of the latest SOP which covers this).
attached to this questionnaire.
Attach a flow chart if possible.
Are Jog books kept for all analytical laboratory
X
instruments?
Are there log books or other records that indicate the
All weighing specs are written in the
checks made on materials and instruments such as
weights, humidity indicators, balances, and
X logbook and also kept in the
thermometers?
database for that session.
Are log books maintained to track the preparation of
X Utilize Ambient Database.
filters for the field?
I. Are they current? X
2. Do they indicate proper use of condi tioning? X
3. Weighings? X
4. Stamping and numbering? N/A N/A N/A
Are log books kept which track filters returning from
Logbooks are kept at each site with
the field for analysis?
X the filter number and the sample
dates.
How are date records from the laboratory archived? Data base- custody forms- filters
I. Where?
Data base- Susan Bowman's office- storage
refrigerator.
Bryan Frazar (Programmer) - data base, Susan
2. Who has the responsibility? Title? Bowman (Environmental Specialist) - filters &
custody forms.
3. How long are records kept? Custody forms 5 years, filters indefinitely.
Does a chain-of-custody procedure exist for laboratory Title & Date: Gravimetric Analysis
samples? for Measurement of Fine Particulate
X Matter as PM2.5 - 11/08/2007
Revision Number: 1.4
Location: Office, Network
SESD Project#: ll-0044 Page 51 of 55
e) Laboratory Data Acquisition and Handling
Question
Yes I No I
Comments
Identify those laboratory instruments which
Scales used in gravimetric analysis report results directly
make use of computer interfaces directly to
record data. Which ones use strip charts?
through computer interface. Barcode scanner used to
Integrators?
directly relay filter IDs to database.
Are QC data readily available to the analyst
X
I I
during a given analytical run?
What is the laboratory's capability with
regard to data recovery? In case of problems, All data maintained by the Ambient Database is backed-up
can they recapture data or are they dependent daily to Network Servers.
on computer operations? Discuss briefly_.
Has a user 's manual been prepared for the
X
I I
automated data acquisition instrumentation?
Please provide below a data flow diagram which establishes, by a short summary flow
chart: transcriptions, validations, and reporting format changes the data goes through
before being released by the laboratory.
.(
Start
)
~

Retrieve filters
Inspect filters.
from field.
~ ..
Condition filters Condition
24 hrs. filters 24 hrs .
+
...
Weigh clean
Weigh filters
filters.
again.
...

Send filters to.
Enter data in
field.
database.
...

Sampler runs
Archive
24 hrs.
filters
i_
+ .
Stop
Figure 1: Flowchart of PM2.s
measurement process
f) Specific Pollutants: Particulate Matter
High Vol PM10
Does the agency use filters supplied by EPA? X N/A
Do filters meet the specifications in 40 CFR 50? X N/A
Are fil ters visually inspected for defects before
X N/A
exposure?
Where does the laboratory keep records of the serial
N/A
numbers of filters?
Are the temperature and humidity monitors
X N/A
calibrated?
Are balances checked with Class S or Class M
weights each day when they are used?
X N/A
To what sensitivity are filter weights recorded? N/A
What method of documentation is used to record
filter weighing sessions? (e.g., logbook, computer N/A
software, etc.)
During conditioning, are the following true:
(l) Filters equilibrate for a minimum of 24 hours X N/A
(2) The temperature range is from Isc-3oc X N/A
(3) Temperature control is 3c SD over 24 hrs X N/A
(4) Humidity range is 20%-45% RH X NIA
(5) Humidity control is 5% SD over 24 hrs X N/A
(6) Pre/post sampling RH difference in 24-hr
X N/A
means is < 5% RH
(7) Balance is located in the conditioning
X N/A
environment
Are filters packaged for protection while
X N/A
transporting to and from the monitoring stations?
Are filters shipped at ambient temperature to the
X N/A
monitoring stations?
Are filters shipped at ambient temperature from the
X N/A
field to the laboratory?
Are exposed filters reconditioned for at least 24 hrs
in the same conditioning environment as for X N/A
unexposed filters?
Briefly describe how exposed filters are prepared
N/A
for conditioning
Briefly describe how exposed filters are stored after
N/A
being weighed
Are blank filters reweighed? X N/A
Are chemical analyses performed on filters? X N/A
If yes, what analysis is performed? N/A
PM
10
2
.
5
/ Low Vol PM
1
ol PMz.s
Does the agency use filters supplied by EPA? X
Do filters meet the specifications in 40 CFR 50? X
Are filters visually inspected via strong light from a
X
view box for defects before exposure?
Where does the laboratory keep records of the serial
Ambient Database and Logbooks.
numbers of filters?
Are temperature and humidity monitors calibrated? X
Are balances checked with Class 1 weights each day
X
when they are used?
To what sensitivity are filter weights recorded? IOOmg - 200mg.
What method of documentation is used to record
filter weighing sessions? (e.g., logbook, computer Logbook, Ambient Database.
software, etc.)
During conditioning, are the following true:
(1) Filters equilibrate for a minimum of 24 hours X
(2) The temperature range is 2oc-23c for the
X
24-hr mean
(3) Temperature control is 2c SD over 24 hrs X
(4) Humidity range is 30%-40% RH for 24-hr
X
mean OR <5% sampling RH but >20% RH
(5) Humidity control is 5% SD over 24 hrs X
(6) Pre/post sampling RH difference in 24-hr
X
means isS 5% RH
(7) Balance is located in the conditioning
X
environment
Are filters packaged for protection while
X
transporting to and from the monitoring stations?
Are filters shipped at ambient temperature to the
X Placed into cooler with ice packs.
monitoring stations?
Are filters shipped a t ~ 4 c from the field to the
X
laboratory?
Are filters post-weighed in 3 0 days? X
Are filters post-weighed in Sl 0 days if they arrive
X
>4.C?
Are exposed filters reconditioned for at least 24 hrs
in the same conditioning environment as for X
unexposed filters?
Briefly describe how exposed filters are prepared
Filters are spaced out on a tray inside the
for conditioning
conditioned environment for at least 24 hours. They
are then removed from rings and placed in a dish.
Briefly describe how exposed filters are stored after They are moved to a refrigerator for long term
being weighed storage.
Are blank filters reweighed? X
Are chemical analyses performed on filters? X
If yes, what analysis is performed?
SESD Project#: ll-0044 Page 54 of 55
Lead
Does the agency use filters supplied by EPA? X N/A
Is analysis for lead being conducted using atomic
X N/A
absorption spectrometry with air acetylene flame?
If not, has the agency received an equivalency
X N/A
designation for their procedure?
Is either the hot acid or ultrasonic extraction
procedure being followed precisely?
X Which? N/A
Is Class A borosilicate glassware used throughout
X N/A
the analysis?
Is all glassware cleaned with detergent, soaked and
X N/A
rinsed three times with distilled or deionized water?
If extracted samples are stored, are linear
X N/A
polyethylene bottles used?
Are all batches of glass fiber filters tested for
X N/A
background lead content?
At a rate of 20 to 30 random filters per batch of
X Indicate Rate - N/ A
500 or greater?
Are ACS reagent grand HN0
3
and HCI used in the
X N/A
analysis?
Is a calibration curve available having
concentrations that cover the linear absorption range X N/A
of the atomic absorption instrumentation?
Is the stability of the calibration curve checked by
alternately re-measuring every lOth sample a X N/A
concentration ~ l,ug Pb/ ml; s 10 ,ug Pb/ml?
END OF REPORT
SESD Project #: J 1-0044 Page 55 of 55

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

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