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:

..,.. , .... -=" nvr.=' r : · .,t:, t: .... APR 0?. 2012

r-\.1-'.C. O. . r-n t.aqr :"'-p "JlON •. '· > 1 r-', I

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,

~0t;-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

980 College Station Road Athens, Georgia 30605-2720

2011 Technical Systems Audit Report

Jefferson County, Kentucky Louisville Metro Air Pollution Control District

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. AOM~~W3TP.~T!ON

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Richard Guillot Environmental Engineer Superfund & Air Section

Laura Ackerman Chief Superfund & Air Section

Report prepare~tiy:

, .a.~---··/} 1 Uclt~d/ Signature l

Signature

Date

Date

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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 Novem~er 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 #21-111-101 9) 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 PM2.s Collocated, 4 PM2.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.

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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 PM2.5 filter weighing facilities. No deficiencies were noted in the APCD's laboratory facilities.

DATA AND DATA MANAGEMENT

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' ' 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 A§3.2.1 & §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) & PM2.5 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.

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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.

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APPENDIX 1

United States Environmental Protection Agency

Region 4

Science & Ecosystem Support Division 980 College Station Road

Athens, Georgia 30605

Ambient Air Monitoring Technical System Audit Form

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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 PM10, Low Vol PM10, PMz.5, PM10_2_5 & Pb)

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1) GENERAL INFORMATION

a) Program Organization

Organization N arne: • Louisville Metro Air Pollution Control District

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

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

Executive Director I Law·en 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 Pollution Environmental Specialist I Air Pollution Technician ll

Susan Bowman I Daniel Durrett

Air Pollution Environm~tntal Specialist I Air Pollution Technician lJ Terry Carby I Steve Oswald

Air Pollution Environmental Specialist I I Ai1 Pollution Technician II Ron Jacobs

J I Deborah Vavrek

Air Pollution Technician 11 I Mario Beeler

J

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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

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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.

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List personnel who have authority or are responsible for:

Activity Name Title

QA Training Field/Lab Billy DeWitt Environmental Supervisor

Grant~anagement Cynthia Lee Environmental ~anager

Purchases Greater than $500 Billy DeWitt Environmental Supervisor

Equipment and Service Contract Billy DeWitt Environmental Supervisor

~anagement

Staff Appointment Billy DeWitt Environmental Supervisor

~onitoring 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

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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

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d) Facilities

Identify the principle facilities where the agency conducts work related to air monitoring. Do not include monitoring stations, but include facilities where work is performed by contractors or other organizations. Select which purpose(s) each facility serves. Add additional lines as necessary

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

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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?

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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?

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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

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Does your agency participate in NPAP, PM25 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) PM2.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

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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

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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


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


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

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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

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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.

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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.

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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


QA Handbook Volume co any audit level


> 15% % difference> 15%, then multi-point

No. 1 Page 5 of 30 calibration.

Operator notified and performs multi-QA Handbook Volume

% difference at point precision check. If operator check

II, Appendix D Revision N02 any audit level

% difference> 15%, then multi-point No. I Page 7 of 30

> 15% calibration.

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QA Handbook Volume so2 any audit level


>15% % difference> 15%, then multi-point

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.

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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.

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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

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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

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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 A venue, Louisville, Relocated

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

A venue, Louisville, Relocated 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

PM2.5 speciation Met One SASS

PM10.2.5 speciation N/A N/A N/A

PM10-2.5 FRM mass N/A N/A N/A

Continuous PM2.5 mass Met One BAM1020 EQPM -0308-170

Trace levels (CO) TECO 48i-TLE RFCA-0981-054

Trace levels (S02) 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., d ilution 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 ~enerated, includin~ 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

Question Yes No Comment

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 PM2.5 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

Question Yes No Comments 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

Question Yes No Comments 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

·Question Yes No Comment

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

.. Question Yes No Comments

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 Is·c-3o·c X N/A

(3) Temperature control is ±3·c 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

PM10•2.5 / Low Vol PM1ol 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 2o·c-23•c for the X

24-hr mean

(3) Temperature control is ±2·c 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 at ~ 4 ·c from the field to the

X laboratory?

Are filters post-weighed in ~30 days? X

Are filters post-weighed in S l 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 HN03 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

2011 technical systems audit report

Documents

air monitoring network

air section cc

technical systems audit

audit results

sesd epa region

state ofkentucky sesd

auditors doug jager

quality assurance program