united states environmental protection agency€¦ · sesd id: 16-0408 final report page 3 of 80....

SESD ID: 16-0408 FINAL REPORT Page 3 of 80

Table of Contents

1. Executive Summary .......................................................................................................................... 4

2. Introduction ....................................................................................................................................... 5

3. Commendations................................................................................................................................. 6

4. Findings and Recommendations ...................................................................................................... 7 4.1 FIELD OPERATIONS .................................................................................................................. 7 4.2 LABORATORY OPERATIONS .................................................................................................... 9 4.3 RECORDS MANAGEMENT ...................................................................................................... 12 4.4 DATA MANAGEMENT .............................................................................................................. 13 4.5 QUALITY ASSURANCE ............................................................................................................. 18

5. Conclusions ...................................................................................................................................... 21

Appendix A: KCDAQM Response – Technical Systems Audit Form .............................................. 24


1.0 Executive Summary

Environmental Protection Agency (EPA) Region 4 Science & Ecosystem Support Division (SESD) personnel conducted a Technical Systems Audit (TSA) of the Knox County Department of Air Quality Management (KCDAQM) ambient air monitoring program in July 2016. The purpose of the TSA was to evaluate the operation and performance of the KCDAQM air monitoring program, pursuant to 40 CFR Part 58, Appendix A, Section 2.5. Data from the 2013-2015 calendar years were reviewed during the TSA. KCDAQM operates a sizeable ambient air monitoring network consisting of seven monitoring stations and a PM10 gravimetric laboratory. During the TSA, six air monitoring stations were inspected. The PM10 laboratory was audited as well; the air monitoring manager, who acts as a backup, demonstrated the weighing procedure. KCDAQM staff demonstrated technical expertise in operating and maintaining air monitoring equipment. The KCDAQM has implemented numerous upgrades and enhancements to its ambient monitoring program in the past three years, which have resulted in marked improvements to the agency’s quality system. However, areas where further improvement is needed were observed. The findings and recommendations of this TSA indicate the need for an improved data review and validation process. Agency quality documents, including its Quality Assurance Project Plan (QAPP) and Standard Operating Procedures (SOPs), are outdated and in need of revision. The agency would benefit from assigning the role of a Quality Assurance (QA) officer to an individual whose responsibilities could include: keeping quality system documentation up to date, validating data, performing internal systems audits, maintaining training records, managing standard certifications, and reviewing contractual agreements and products to ensure they meet the required specifications.


2.0 Introduction On July 18-21, 2016, EPA Region 4 SESD personnel conducted a TSA of the KCDAQM ambient air monitoring program. The audit team included Keith Harris (lead auditor) and Stephanie McCarthy from SESD’s Field Services Branch, Superfund and Air Section. Sara Waterson attended the audit as a representative from the EPA Region 4 Air, Pesticides and Toxics Management Division (APTMD). The purpose of the audit was to assess KCDAQM’s compliance with established regulations governing the collection, analysis, validation, and reporting of ambient air quality data. Pursuant to 40 CFR Part 58, Appendix A, Section 2.5, TSAs are required to be conducted every three years. Data reviewed as part of this TSA included that generated during the 2013-2015 calendar years. Data was queried from EPA’s Air Quality System (AQS) database prior to the on-site audit. SESD’s Ambient Air Monitoring Technical Systems Audit Form was completed by KCDAQM staff prior to the on-site audit and is included as Appendix A of this report. The audit included a review of data, recordkeeping, documentation, and support facilities housed at the KCDAQM central office, located at 1403 Davanna Street, in Knoxville, Tennessee. Six of the seven monitoring stations operated by KCDAQM were visited during the audit as well. The six KCDAQM air monitoring stations visited during the audit are listed below. Common Site Name AQS Identification East Knox 47-093-0021 Spring Hill 47-093-1020 Air Lab 47-093-1013 Rule 47-093-1017 Ameristeel 47-093-0023 Burnside 47-093-0027 During the audit, the following KCDAQM personnel were interviewed.

• Lynne Liddington, Director • Amber Talgo, Program Manager • Rebecca Larocque, Field Technician/Quality Assurance Technician • Barron White, Field Technician/Laboratory Analyst • Daniel Tipton, Field Technician

The following AQS reports were reviewed in preparation for this TSA.

• AMP 251: QA Raw Assessment Report (2013-2015) • AMP 256: QA Data Quality Indicator Report (2013-2015) • AMP 350: Raw Data Report (2013-2015) • AMP 430: Data Completeness Report (2013-2015)


• AMP 480: Design Value Report (2015) • AMP 503: Extract Sample Blank Data (2013-2015) • AMP 504: Extract QA Data (2013-2015) • AMP 600: Certification Evaluation and Concurrence (2013-2015)

Additionally, the following KCDAQM documents were reviewed.

• Quality Assurance Project Plan for the Knox County, TN Ambient Air Quality Monitoring Program, October 2009.

• Quality Management Plan, Knox County Department of Air Quality Management, 2011. • Standard Operating Procedures for the Rupprecht and Patashnick Model 2025 Sequential

Sampler, Knox County Department of Air Quality Management, 2007. • Measurement of Ozone Standard Operating Procedure API 400E Analyzer, Knox County

Department of Air Quality Management, 2013. • Standard Operating Procedure for General Metal Works High Volume PM10 Monitors

Volumetric-Flow-Control (VFC), Knox County Department of Air Quality Management, 2011. • Standard Operating Procedure for General Metal Works Volumetric-Flow-Control (VFC) High

Volume TSP/Pb Monitors, Knox County Department of Air Quality Management, 2011. 3.0 Commendations KCDAQM staff interviewed by SESD auditors during this TSA appeared proficient in and knowledgeable of their roles and responsibilities. The KCDAQM staff demonstrated technical knowledge in operating, maintaining, and calibrating instrumentation. Staff (including the program manager) are cross-trained and serve as back-up to each other on the different technical aspects of the monitoring program. Staff members are motivated and innovative, each making recommendations on how to improve KCDAQM data collection procedures as well as documenting those changes in SOPs currently under revision. Auditors from SESD performed site visits at six of the seven monitoring stations within KCDAQM’s network. Each site was clean, well maintained, and met the siting requirements codified in 40 CFR 58 Appendix E. Significant improvements have been made to site logbook documentation including transparent audit data sheet inserts as well as transparent strip chart inserts from performance evaluations. The KCDAQM has made numerous changes and enhancements to its ambient air monitoring program in the past three years, some of which stemmed from corrective actions implemented as a result of the 2013 TSA. These improvements should enhance the agency’s long-term data capture, as well as bolster data quality. Examples of the improvements include the following:

• Acquired 2025i sequential samplers to upgrade aging equipment deployed in the field; • Created “how to” videos to help instruct staff how to properly perform routine tasks; • Improved logbook documentation in field and laboratory; • Developed a readiness assessment check sheet to monitor staff technical proficiency;


• KCDAQM staff vacancies have been filled, allowing time and resources to improve quality assurance;

• Procured new equipment for the PM10 gravimetric laboratory; and, • Robust certification program in excess of that required by CFR.

Overall, KCDAQM’s capture of quality-controlled, well-documented data has increased measurably since the last TSA, as shown by an improvement in statistical data quality indicators (i.e., precision, bias, completeness) calculated from the agency’s 2014-2015 data set.

4.0 Findings and Recommendations The observations from this TSA were compared to EPA regulations, technical policies and guidance, and the KCDAQM quality system documentation. Quality system deviations found through this TSA are classified into three categories: Findings, Concerns, and Observations. These quality system deviations are defined as follows:

Finding: Departure from or absence of a specified requirement (regulatory, QMP, QAPP, SOP, etc.) or guidance deviation which could significantly impact data quality.

Concern: Practices thought to have potential detrimental effect on the ambient air monitoring program’s operational effectiveness or the quality of sampling or measurement results.

Observation: An infrequent deviation, error, or omission which does not impact the output of the quality of the work product, but may impact the record for future reference.

For each of these categories, corrective action recommendations are provided. Corrective actions are required for all quality system deviations ranked as Findings or Concerns. Depending on the severity of the deviation, a specific data deliverable(s) may be requested to show that the corrective action recommendation has been successfully implemented. In these cases, the TSA report will specify the deliverable(s) that will be required for AQS and/or submitted to SESD. Observations do not require corrective actions. 4.1 FIELD OPERATIONS 4.1.1 Concern: KCDAQM is not performing thorough site evaluations nor documenting assessments

that are performed.


Discussion: Siting evaluations are an important quality assurance assessment, designed to ensure monitoring sites operate in compliance with regulatory requirements. Sites within the network are frequently assessed visually and maintained accordingly by staff; however, physical measurements are not taken and recorded as evidence that assessments were performed. SESD auditors performed site evaluations on six of the seven monitoring sites within the KCDAQM network. Each of the sites assessed currently met the siting requirements set forth in 40 CFR Part 58, Appendix E. While taking physical measurements at the KCDAQM monitoring stations, SESD auditors observed tree lines and tree driplines that could pose future obstructions or dripline violations. 40 CFR Part 58, Appendix E, Section 5(a) requires that inlets be 10 meters or more from the drip-line of trees. Vegetation can have a scavenging effect on pollutants and, resultantly, negatively impact the data collected by nearby samplers. Trees can also act as obstructions in cases where they are located between the air pollutant sources or source areas and the monitoring site, and where the trees are of a sufficient height and leaf canopy density to interfere with the normal airflow around the probe or inlet. At the Burnside site, the dripline to the closest tree was measured at 11.5 meters from the collocated and 13 meters away from the primary sampler inlet. Additionally, both East Knox and Spring Hill were bordered by tree lines that could potentially obstruct airflow around the monitoring inlet, if the vegetation continues to grow. 40 CFR Part 58, Appendix E requires unrestricted airflow 270 degrees around the probe or sampler. Section 4(a) of Appendix E further requires the distance from the obstacle to the probe/inlet be at least twice the height that the obstacle protrudes above the probe or inlet. The tree lines observed at both East Knox and Spring Hill would obstruct more than 90 degrees of airflow if the vegetation continues to grow; therefore, these sites should be closely monitored.

Recommendation: Siting evaluations should be conducted in the spring or summer of each year, when trees and vegetation are in their peak seasons. KCDAQM should document the critical measurements necessary to ensure each site meets the requirements of 40 CFR Part 58, Appendix E. Development of a form may be the most efficient way to capture all of the information. In addition, KCDAQM should acquire equipment capable of measuring distance to and height of objects, as well as a compass to measure the degrees of obstruction. A range finder or measuring wheel and tape coupled with a clinometer are two possible options. Finally, SESD recommends that the measurements taken during the Appendix E evaluations for all sites in the KCDAQM network be entered into the KCDAQM’s annual network plan as evidence that the sites meet Appendix E requirements, in accordance with 40 CFR 58.10(a).

4.1.2 Observation: Some logbook documentation lacked detail and/or did not adhere to best practice protocols.

Discussion: During the TSA, logbook records were reviewed while visiting field sites and also while reviewing data at the central office. SESD auditors observed blank spaces on a few pages


within the field logbooks, specifically when transparent forms or strip charts had been affixed to pages. Recommendation: In keeping with documentation best practices, SESD recommends field technicians place an ‘X’ in any blank spaces in logbooks in order to maintain transparency as well as prevent backfilling.

4.1.3 Observation: Unexposed PM10 filters were left uncovered in the field during flow verifications and maintenance filters were mishandled during loading into the sampler.

Discussion: During a site visit, SESD auditors observed an unexposed filter resting uncovered on a railing while the site operator was performing a flow rate verification. Also, when loading the maintenance filter on to the sampler, the site operator grasped the filter by placing his thumb within the sample area of the filter. Sample handling is critical to collecting quality data. Filters should remain protected from the environment when not installed onto samplers and care should be taken to avoid touching the sample media during handling. Recommendation: PM10 filters should remained capped until installed on the sampler to avoid passive contamination. Sample cassette caps also protect the sampling media during handling, preventing site operators from accidentally dislodging sample mass while handling filters.

4.2 LABORATORY OPERATIONS 4.2.1 Finding: Contractual laboratory performed lead analysis without a current SOP and may not have

accurately followed an approved federal reference or equivalent method. Data packages did not provide sufficient quality assurance/quality control (QA/QC) results; therefore, KCDAQM did not thoroughly validate its ambient lead data.

Discussion: During pre-audit activities, SESD auditors noted multiple contradictions and irregularities while reviewing information related to KCDAQM’s ambient lead analytical procedures. The following narrative summarizes the issues uncovered during the TSA. Per coding in the EPA Air Quality System (AQS) database, the collection and analysis method utilized by KCDAQM through 2015 for lead is reported as Method 107, Hi-Vol Flameless Atomic Adsorption (FAA), which is a FEM. The contract analytical laboratory, First Analytical Laboratory (FAL), switched from FAA to analysis by Inductively Coupled Plasma – Mass Spectroscopy (ICP-MS) due to equipment malfunction, according to KCDAQM’s written response to the 2013 TSA; however, the method cited in the response was “40 CFR 50, Appendix G, Method 12.” SESD notes that EPA Method 12 is a source-oriented method (40 CFR Part 60) and not an approved method for analysis of ambient lead. The Ambient Air Monitoring TSA Form submitted prior to this TSA (see Appendix A of this report) indicated that FAL was using Method 6020A to determine lead concentrations on the TSP filters. While the analytical method described in 40 CFR Part 50,


Appendix G is based on Method 6020A, differences occur such as the allowable internal standards used for lead analysis. A copy of the laboratory SOP was requested and reviewed by SESD auditors during this TSA. Within the Scope and Application Section of the FAL SOP, the following is stated:

Preparation and analysis of large filters for Lead. This procedure is intended to comply with the analysis requirements of 40CFR50 Appendix G, “Reference Method for the Determination of Lead in Suspended Particulate Matter Collected from Ambient Air.” Where necessary for clarification or definition of terms, refer to the original document. Analysis is to be performed according to the Federal Equivalent Method EQL-0895-107, “Determination of Lead Concentration in Ambient Particulate matter by Flameless (Graphite Furnace) Atomic Absorption (City of Houston, Texas). (FAL SOP # PB40CFR50AG)

This section represents a conflation of the federal methodology system, citing two distinct analytical methods: Appendix G, representing the reference method currently using ICP-MS for analysis, and Method 107, representing an equivalent method using Graphite Furnace Atomic Absorption (GFAA) for analysis. Later, in the Analysis Section of the FAL SOP, a “Note” states, “Per update to 40 CFR 50 Appendix G, dated Jan 9, 2014, analysis by ICP-MS is allowed.” As written, the SOP appears to be based on a previous method described in Appendix G where lead is extracted from filters with 3M HNO3 on a hotplate followed by extracts analyzed using GFAA. The current method described in 40 CFR Part 50 Appendix G no longer includes the 3 M HNO3 hotplate extraction; therefore, analysis of 3 M HNO3 extracts by ICP-MS would represent a deviation from the approved method. Auditors from SESD requested two FAL analysis reports for review (one prior to January 2014 and one after), to determine which method FAL was using during each time period. Both reports – FAL Project #130332, dated 04/02/2013, and Project #1603029, dated 03/22/2016 – reference 40 CFR 50 Appendix G as the method. The report from 2013 states that the analysis was performed by GFAA, while the report from 2016 states ICP-MS analysis with the caveat “40 CFR 50 Appendix G, dated Jan 9, 2014, allows for determination by ICP-MS.” Further inspection of the analysis reports revealed that sufficient quality control (QC) data was not included in the packages, which would allow KCDAQM to thoroughly verify and validate the ambient lead data prior to entering it into AQS. Appendix G requires that specific QC samples be run at a defined frequency and results must meet performance specification. For example, a Continuing Calibration Verification must be run every tenth sample and be within 10% of the expected value. Analysis reports from each quarter of the three year period of interest were requested along with all QC data, internal standard recoveries, and sample preparation logs. Calibration verification results, internal standard recoveries, and the correlation coefficient results were included in the submitted packages; however, other Appendix G Section 8 QC results were not included in the package, such as certified reference material recovery (Section 8.9) and five-


fold dilution results (Section 8.7). The analysis report also did not specify which internal standard was used during the analysis, a requirement of Section 7.6. The sample preparation logs submitted lacked sufficient detail to provide narrative describing how samples and QC samples were prepared and analyzed. For example, there was no clear indication of sample numbering, only numbers written off to the side of the Materials Transmittal Sheet with no heading. Also, the data packages did not include a sample sequence, indicating where QC samples were analyzed within the batch. This information is important because it allows data validators the ability to determine if QC samples were analyzed at the required frequency and order. KCDAQM received lead audit strips from EPA and included strips with each sample submission reviewed during this TSA. The results were entered into AQS by the KCDAQM when uploading ambient data. Audit strip results were reviewed by SESD auditors in preparation for the audit. Audit strip results appear to be acceptable, indicating that the associated data is accurate; however, the transparency and defensibility of the data is in question due to the potential deviation from the FRM, lack of a clear SOP, incomplete QC reporting, and insufficient documentation.

Recommendation: KCDAQM must correct the method code in AQS to reflect the extraction and analytical procedures implemented pre- and post-January 2014. In order to determine the correct method code, KCDAQM must acquire the source document on which the FAL SOP is based. This document should include a detailed method, including extraction and analytical procedures. Once all necessary information has been gathered, EPA will work closely with KCDAQM to accurately manage, code, and/or apply flags to existing data in AQS. Moving forward, KCDAQM must implement and strictly follow an approved FRM or FEM for lead extraction and analysis, while managing the data accordingly. The lab must follow an SOP that clearly defines the federal method followed, and provides detailed instructions that show strict accordance to the adopted method. Analysis reports must include all QC data required by the adopted method so that ambient lead data can be thoroughly verified and validated by KCDAQM prior to entry to AQS. Sample preparation logs should be of sufficient detail that sample preparation and analytical order can easily be determined if data quality ever comes into question in the future.

4.2.2 Observation: Exposed PM2.5 filters are being stored at temperatures below 0°C prior to shipment

to the analytical laboratory for post-weighing.

Discussion: After retrieval from the field, KCDAQM places exposed PM2.5 filters in a laboratory grade freezer/refrigerator inside the central office laboratory. A logbook recording the times filters are placed in and removed from the freezer is maintained; the temperature indicated on the freezer display is also recorded in this logbook. Upon review, SESD auditors noted negative Celsius temperature readings indicating exposed filters are frequently exposed to freezing temperatures prior to post-weighing. EPA recommends that exposed PM2.5 sample filters be chilled, but not frozen. Please see the recently revised EPA document Quality Assurance Guidance Document


2.12, Monitoring PM2.5 in Ambient Air Using Designated Reference or Class I Equivalent Methods (January 2016) for more information regarding sample handling.

Recommendation: The temperature of the refrigerator unit should be adjusted to maintain a consistent temperature above freezing but below 4°C.

4.2.3 Observation: The relative humidity (RH) sensor in the PM10 laboratory was not verified every six months.

Discussion: KCDAQM uses a Control Company hygro-thermometer in the PM10 gravimetric laboratory. The hygro-thermometer includes a certificate of traceability with the purchase of the sensor. The certificate states that the sensor’s accuracy/traceability is valid for two years. However, in keeping with recommended best practices, KCDAQM opts for an annual certification of the sensor. Towards that end, KCDAQM purchases a new certified hygro-thermometer annually, which is less expensive than recertifying the existing sensor. In addition to the annual recertification, semi-annual verifications of laboratory RH and temperature sensors are recommended in the EPA Quality Assurance Handbook for Air Pollution Measurement Systems, Volume II (QA Handbook). Please see Appendix D of the 2013 QA Handbook for more information. The PM10 regulatory method (40 CFR Part 50, Appendix J) requires PM10 filter conditioning within specified temperature and RH ranges. With that in mind, it is important that the temperature/ RH sensor in the gravimetric laboratory be verified on a routine basis in order to ensure the sensor continues to work properly and collect quality data. Although the Control Company hygro-thermometer is calibrated/certified by the vendor prior to purchase, the sensor should be verified in-house with an independent standard on a more frequent basis (i.e., every 6 months) as a quality assurance check. Recommendation: Semi-annual verifications of the temperature and RH sensors in the gravimetric laboratory should be conducted and documented, as recommended in the QA Handbook, and document these checks in their quality system.

4.3 RECORDS MANAGEMENT 4.3.1 Concern: The local area network (LAN) share drive for electronic records is not adequately

secured.

Discussion: On the KCDAQM LAN, there is a shared drive folder that serves as the final repository for ambient air monitoring files. However, the folder is not locked: all air monitoring staff have the ability to delete or edit files that have been uploaded to the share drive. This lack of security is a vulnerability to the agency, because staff could inadvertently modify or delete information within the folder.


Recommendation: The KCDAQM air monitoring share drive folder should be secured in such a manner that modifications cannot be made to any files without permission from a designated administrator (for example, the air program manager). SESD suggests that the share drive be configured such that all air monitoring staff have “read access” to the folder, as well as the ability to “add” files to the folder. However, “write” and “delete” access should be restricted to only a designated administrator. If a mistake is identified within a saved file by the responsible staff member or reviewer, an adequately labeled, corrected file should be saved in addition to the original in order to maintain transparency.

4.3.2 Observation: Site, monitor, and laboratory logbooks are not being backed up periodically.

Discussion: Logbooks are a valuable source of historical information and a necessary data validation tool. If logbooks are to be incorporated into the data validation process, they must be readily accessible to staff. KCDAQM currently stores logbooks at sites and in the lab. Each calendar year, logbooks are archived and replaced with new books; the archived logs are stored in boxes in the central office. The logbook policy currently utilized by KCDAQM prevents data validators from having immediate accesses to information critical to a robust data validation process. Additionally, logbooks are left vulnerable to damage or loss.

Recommendation: KCDAQM should periodically scan and store backup copies of logbooks on the network drive, or to another readily-accessible location, so that a secure backup exists in case of loss or damage. Scanning the logbooks in this capacity would allow for information to be more easily referenced during the data review process as well. The documents or files should be labeled such that needed ancillary information can be easily located by staff and data review personnel.

4.4 DATA MANAGEMENT 4.4.1 Finding: Ambient data was not invalidated when its associated QA/QC check did not meet

established acceptance limits.

Discussion: Upon review of the 2013-2015 data set, SESD auditors found a few instances where a QC check failed – but the associated ambient data was not invalidated. For example, on January 27, 2014, the PM2.5 sampler at the Spring Hill site failed a monthly flow rate verification at 7% difference (the acceptance criterion is ±4% difference). Logbook documentation states that the sampler was recalibrated to within acceptance limits (3.7% difference); however, the AQS AMP 350 (Raw Data Report) indicated that PM2.5 data was not invalidated back to the last known date/time when the instrument was operating properly – which would have been a semi-annual flow rate audit conducted on December 20, 2013. As another example, a similar issue occurred with the collocated PM2.5 sampler at the Bearden site the following year. A failed flowrate verification (15.59% difference) occurred on January 27, 2015. A passing semi-annual flow rate audit performed on December 18, 2014, was determined


to be the last instance when the sampler was shown to be in control. Despite this, AQS shows valid data reported between the failed check and the previous passing audit. During the audit, KCDAQM staff agreed that this data should have been invalidated. A third example, associated with PM10 data, occurred during August 2015 at the Air Lab site. While reviewing the AQS AMP 504 (Extract QA Data), SESD auditors noted six failed flow rate verifications performed between July 15, 2015, and September 17, 2015. During this period, data entered into AQS should have been invalidated. SESD auditors reviewed records associated with this time period and identified a passing flow rate audit performed on August 21, 2015, that was not entered into AQS. KCDAQM staff stated that logbooks where not used during the final validation process therefore they were unaware of the missing valid flow rate verification. Failed flow rate verifications were not identified due to the lack of a sound data verification/validation procedure, allowing invalid data into AQS. Additionally, not incorporating logbooks into the data review process allowed a passing flowrate verification to go unnoticed, jeopardizing valid data. Finally, a failed semi-annual flow rate audit was performed on a PM2.5 sampler at the Rule site on June 18, 2014 (16.41% difference). The previous passing flow check (0.89% difference) was performed on May 21, 2014, in conjunction with necessary maintenance. The AQS AMP 504 (Extract QA Data) shows that KCDAQM performed a flow rate verification on June 20, 2014, and an additional audit on June 23, 2014, both passing. The validity of data reported between May 21 and June 20 is in question due to the failing audit; therefore, KCDAQM must review the available documentation and determine whether the data collected during this period is valid. Only valid QA checks, associated with valid data, should be entered into AQS; therefore, the failed audit in question should be removed from AQS regardless of the decision made pertaining to the validity of the associated data. Recommendation: KCDAQM must correct the AQS reporting errors that were identified during the TSA. Additionally, KCDAQM must augment its data verification/validation process to ensure that ambient data associated with failed QC checks are appropriately invalidated in AQS. Logbook review should be incorporated into the review process to ensure that all verifications and audits are recognized, any failures are supported with sufficient detail pertaining to the validity of the data collected, and corrective actions are implemented. The EPA QA Handbook (May 2013) provides guidance on data handling techniques and procedures. SESD recommends KCDAQM implement additional peer-review of routine concentration data in combination with the associated QA/QC data, ideally by a designated quality assurance officer. Additionally, KCDAQM currently documents its data handling procedures within individual pollutant SOPs. The data handling sections of each SOP should be augmented to describe a more rigorous data validation process that clearly defines how to invalidate data, providing specific examples on how to bracket the data such that its quality is defensible. KCDAQM may choose to consolidate data handling procedures into a single Data Handling SOP.

4.4.2 Finding: Recording of PM10 laboratory data was inconsistent compared to information required by SOP and structure of data collection does not allow for efficient data review and validation.


Discussion: During inspection of the PM10 laboratory, SESD auditors made note of three repositories of PM10 laboratory data: initial conditioning data recorded in a conditioning logbook prior to pre-weighing filters; check weights and (as of June 2015) hygro-thermometer min/max readings in a balance logbook; and, finally, post-weighing conditioning data, filter mass, and QA reweigh information recorded on sample envelopes. Inconsistencies were discovered within these logbooks as well as missing information critical to data validation. The balance logbook showed inconsistent measurements of checks weights, where occasionally only one check weight was measured, other times three were measured. This inconsistent weighing of check masses does not follow the procedure set forth in the KCDAQM SOP for High Volume PM10 SOP (2011) where it states: “Before the first filter is weighed, the balance shall be checked by weighing a pair of working mass reference standards with weights between 1 and 5 g.” Additionally, there is no indication of where each weighing fell within the weighing session, preventing validators from verifying that a check weight was weighed every 15 samples. There were also no records of balance zero checks, also a requirement in the SOP. Vulnerabilities were also observed in the way that KCDAQM records PM10 filter conditioning data. Conditioning information for the pre weighed filters is recorded in the conditioning logbook, while the conditioning information for the final weighing is recorded on the filter envelope. The records for each appeared sufficient; however, recording this information in two separate locations makes it difficult for data validators to assemble all the necessary information to adequately validate PM10 data. SESD auditors also observed a perforated notebook with apparent hygro-thermometer min/max readings. After discussions with the lab analyst, it was determined that the notebook was used to record the readings and only transferred to the logbook or filter folder if the conditions allowed for weighing. Utilization of unbound, unnumbered perforated notebooks to record conditioning data, even temporarily, is not recommended. Finally, filter reweighs are performed each session in accordance to Section 3.5.3 of the KCDAQM SOP. As an added level of quality assurance, an independent laboratory analyst performs the reweighs and the results are recorded on the filter envelope. The acceptable difference between the two weighings of a clean filter is ± 2.8 mg from the original value and ±5 mg for exposed, according to the SOP. The filter envelope used to record this information did not contain a field to compute this difference, leaving it up to the analyst to mentally compute this value. SESD auditors noted instances on some of the envelopes reviewed where the analysts had entered this information into the margin; however, an official field is needed for the document to be easily interpreted and defensible. Additionally, reweigh information is to be reviewed by a QC supervisor, in accordance with the SOP. No records of QC review were found and the air monitoring manager stated that they are currently not performing the review.

Recommendation: KCDAQM staff must record all required information in accordance with the agency’s SOP. Also, given that reweigh and some conditioning information is only recorded on the filter envelope, while other critical information is recorded in separate logbooks, data validators


have no easy method to determine if all acceptance criteria for each filter has been met. Because of this, KCDAQM should develop a database or some central repository for all PM10 data that includes space for acceptance criteria so that the operators and analyst know what information is to be entered along with the associated acceptance criteria. A central repository will also allow data validators to efficiently and effectively validate PM10 data.

4.4.3 Finding: KCDAQM continued to use QA qualifier codes on PM10 data that did not meet critical criteria after laboratory control issues were resolved.

Discussion: During the previous TSA, SESD auditors discovered that KCDAQM was not collecting sufficient data to prove that 40 CFR 50, Appendix J filter conditioning criteria were being achieved. As a corrective action, KCDAQM was required to apply a “1” QA qualifier flag to data where this requirement was not being met. KCDAQM, in response to the 2013 TSA findings, purchased new equipment and bolstered documentation to ensure compliance with 40 CFR 50 Appendix J laboratory control requirements. In July 2015, application of “1” flags to the PM10 data set ceased. The air monitoring manager explained that, at that time, KCDAQM had become confident that all conditioning issues had been successfully resolved and sufficient documentation existed to demonstrate critical criteria were being met. In November 2015, however, SESD auditors noted the reappearance of “1” QA qualifier flags in the agency’s PM10 data set. The air monitoring manager stated that the PM10 laboratory once again began experiencing difficulty maintaining temperature/RH control. Staff recognized that Appendix J filter conditioning requirements were not being met; however, KCDAQM decided to apply “1” flags again, instead of invalidating the data that did not meet CFR requirements.

Recommendation: Once KCDAQM established an acceptable PM10 filter conditioning system, QA qualifier codes should no longer have been applied when data was found to not meet regulatory requirements. From July 2015 forward, any data that does not meet Appendix J filter conditioning requirements should be invalidated, as opposed to flagged.

4.4.4 Finding: Logbooks, field sheets, and strip chart data from continuous ozone monitors are not being utilized during data verification and validation, allowing invalid data to be entered into AQS.

Discussion: While reviewing AMP 350 (Raw Data Report) AQS reports prior to the TSA, SESD auditors made note of two instances where data coding indicated that repairs or calibrations were performed without any indication that a precision check was performed prior to the calibration or repair, effectively bracketing the data preceding the event. Upon further investigation into each incident, SESD auditors discovered that while the necessary information to accurately validate the data was available to data validators, the information was not utilized, allowing invalid data to be entered into AQS. The first noted instance occurred at the East Knox site on May 9, 2013, where a series of multi-point calibration (BC) null data codes appeared in the data set. SESD auditors requested to see the


strip chart for the calibration and, upon review, noticed several hours of zero being measured prior to the calibration. After referencing the logbooks, it was determined that a pump had failed necessitating repair and recalibration. SESD auditors asked to see the strip charts of the previous 24-hour period and observed a precipitous drop in measured ozone on May 8, 2013, at 1200 hours, an obvious sign of a pump failure. Referring back to the AMP 350 report, zero concentrations had been reported as valid data from the moment of pump failure to the recalibration the next day. A similar instance was identified at the Spring Hill site on April 23, 2015. Data coding within the AMP 350 indicated maintenance followed by a calibration and precision check. The coding did not, however, indicate that a precision point was performed prior to the maintenance, showing that the malfunction was not affecting the precision of the instrument. The absence of a bracketing precision point prior to maintenance raised concern that the instrument may have been collecting data while functioning outside of acceptable specifications. Further investigation revealed an issue with the sampler flow rate being out of specification compared to the analyzer’s equivalency designation which requires “Models 400E, T400 and TML-10: operated with a sample flow rate of 800 ±80 cm3/min (sea level).” KCDAQM was recording the sampler flow rate on the field sheet; however, the acceptance criterion was not displayed on the sheet nor did data validators review the data in accordance with this specification. Records were traced back to find that the last documentation of the analyzer functioning within specifications occurred on April 16, 2015. Recommendation: Acceptance criteria reflecting both federal reference and equivalence methods utilized by KCDAQM, as well as organizational critical, operational, and systematic criteria, should be clearly defined within the organization’s quality system documents, then integrated into field sheets and logbooks so that staff and data validators are able to easily identify data collected outside of these ranges. KCDAQM must also correct the errors identified during this TSA, as well as ensure that no other similar instances have allowed invalid data to be entered into AQS. Moving forward, KCDAQM should incorporate a rigorous data validation procedure to ensure that all data is sufficiently vetted prior to entry into AQS.

4.4.5 Concern: Data packages from contract lead and PM2.5 laboratories are not reviewed and incorporated into data review procedures to ensure that all critical criteria are being met.

Discussion: It is the responsibility of the reporting agency to ensure that all data entered into AQS meets the quality required by CFR and the agency’s QAPP. To meet the data quality objectives (DQO) set forth in the KCDAQM QAPP, and ultimately CFR, data must be thoroughly validated, taking into account each of the criteria established within the quality system documents. Laboratory activities play a vital role in determining if data collected is of sufficient quality. During the TSA, KCDAQM acknowledged that laboratory data packages are not incorporated in the data validation process. The air monitoring manager currently relies on the contract lab to notify them if certain criteria are not met. While spot checking data, SESD auditors found no evidence of data entered into AQS that failed to meet stated data quality goals; however, not validating data against laboratory information is a vulnerability that could jeopardize the validity of future data sets.


Recommendation: Laboratory data packages from contract laboratories must be incorporated into the data review process to ensure that all critical criteria are satisfied before reporting data to AQS.

4.5 QUALITY ASSURANCE

4.5.1 Finding: Existing KCDAQM air monitoring QAPP and SOPs need to be revised.

Discussion: QAPPs and SOPs are dynamic documents that require routine review and revision. Per EPA Region 4 grant commitments, QAPPs are to be reviewed and revised when changes occur in the network, but at a minimum, every five years. Additionally, SOPs are to be reviewed on an annual basis and revised whenever procedures have changed. The grant commitments further require the development of new SOPs within six months of instrument start-up. The EPA QA Handbook (May 2013) also recommends the routine review of SOPs – see Section 5.3 of the guidance for more detailed information. The QA Handbook recommends the development of a SOP master list, which contains the titles and document control numbers of each SOP maintained by the agency. A master list can be used to ensure the most recent versions of documents are being utilized by agency staff; the list can also be used to track the annual review of each document. The KCDAQM air monitoring documents reviewed in preparation of this TSA are listed in Section 2 of this report. The most recent revision of the documents reviewed for the TSA was in 2013, with the QAPP last being revised in 2009. The procedures described in some of these documents do not accurately reflect the work conducted by agency staff or the equipment currently in place. KCDAQM staff were aware of this issue during the TSA. Additionally, the agency’s Criteria Pollutant QAPP, dated 2009, does not adequately address the unique objectives of KCDAQM’s lead monitoring project, which is specific to a point source. As written, the QAPP addresses lead in the same context as other criteria pollutants. For example, Section 5 “Problem Definition and Background” lists lead with the other criteria pollutants, ignoring the unique purpose of the Knox County ambient lead monitoring project. The DQOs presented in Section 7.1 also do not meet those of KCDAQM’s ambient lead monitoring project. Recommendation: The Criteria Pollutant QAPP and SOPs need to be updated to represent the current procedures and instrumentation employed by KCDAQM. The Criteria Pollutant QAPP must be significantly augmented to reflect the background and stated objectives of KCDAQM’s lead monitoring project, or, preferably, a QAPP specific to the lead monitoring project could be written as a separate document. The QAPPs and SOPs also need to address areas where improvement within the agency’s network is needed (identified within the body of this TSA report). SESD requests KCDAQM develop a specific schedule for SOP development and revisions, detailing the order of priority, and projecting submission dates to EPA. SESD requests a copy of the revision schedule.


SESD further recommends that a master list of KCDAQM SOPs be compiled by the agency, which is managed by a designated member of the KCDAQM staff – ideally, a quality assurance officer. Once all KCDAQM SOPs have been officially revised, the quality assurance officer should be responsible for ensuring that necessary review of the SOPs occurs every year. The annual SOP review should be documented. If procedures or equipment have not changed, the SOP does not need to be revised that year; if changes have occurred, however, the SOP should be revised. Any new equipment procured by KCDAQM should have an SOP developed within six months of start-up; new SOPs should be added to the master list and tracked accordingly.

4.5.2 Concern: KCDAQM’s data validation and quality assurance system is insufficient and requires

significant improvement.

Discussion: During the data review portion of the TSA, auditors from SESD requested a wide range of information. KCDAQM staff were able to fulfill each request; however, locating the requested information was occasionally a challenge, in part due to organization. All the necessary information to accurately verify and validate ambient air monitoring data is currently being collected and archived by KCDAQM. The lack of a defined QA role, responsible for organizing the quality system and establishing a thorough data review process, prevents KCDAQM from collecting and reporting data of the highest quality. Specifically, as explained in Findings 4.4.1 and 4.4.4, SESD auditors were able to quickly identify data in AQS that should have been invalidated based on information available in the form of strip charts, field forms, and logbooks. Recommendation: These example findings, in addition to findings associated with the PM10 lab, all point to the need for KCDAQM to bolster the agency’s QA system. A final level of data verification must be incorporated into the data review process that consolidates all data and information supporting each data point and ensure that it meets all critical criteria set forth in 40 CFR 50, 53, and 58 as well as satisfies the DQOs established in the agency’s QAPP and SOPs. KCDAQM should utilize the findings and concerns identified within this audit report to help identify where data validation deficiencies occur then utilize resources such as Section 17 of the QA Handbook to develop a robust validation procedure. QAPPs and SOPs must be updated to reflect any changes made to the data validation procedure. In addition to revising the KCDAQM data review process, SESD recommends a role should be assigned within the monitoring staff with responsibilities towards QA oversight. Tasks could include:

• reviewing and improving data collecting and handling procedures; • ensure quality documents are continually updated; • ensuring staff are effectively implementing QA procedures set forth in the agency’s QAPP

and SOPs by performing system and data audits; and • ensuring all contractual agreements meet requirements of regulation and KCDAQM’s

quality system, and data generated by contract laboratories is of sufficient quality.


The addition of a defined QA officer role will not only improve overall data quality but will also provide stability by establishing clear, defined procedures that can easily be passed on to future employees if staffing turnover were to occur.

4.5.3 Concern: Gaps were identified in standard recertification frequency. Standard certificates are not being reviewed after certification.

Discussion: In addition to concerns identified in the data verification and validation process, SESD auditors noted other areas where improvements in the QA process would enhance KCDAQM data quality and defensibility. 40 CFR 50, Appendix L, Section 9.2.2 requires flow rate standards used to calibrate PM2.5 samplers be verified annually and must be within 2% difference of a higher standard, traceable to a National Institute of Standards and Technology (NIST) primary standard. During the TSA, SESD auditors reviewed standard certifications and found multiple gaps where standards exceeded the annual reverification frequency by up to five months. The air monitoring manager stated that some of the gaps were due to the assumption that the standard had to be recertified every 365 days but that the clock did not start until the certified standard was put into service, which occasionally occurred months after the standards came back from recertification. During discussions with the ambient air manager, it was revealed that there was one instance where a technician unknowingly took an expired standard to perform a verification in the field that resulted in data being invalidated. Further inspection of standard certificates revealed two instances of standards not meeting the 2% difference. TetraCal 187 and DeltaCal 94 were each sent to Mesa Labs in September 2015 for recertification. Each report indicated the standards produced flow errors greater than 5% at low flow rates, < 6 liters per minute (lpm). Both reports contained data from what appears to be a second verification with acceptable % error results at all levels of flow, indicating an adjustment or repair was made and the standards were recertified afterwards. No notation of maintenance or “as found” and “as left” status were observed on the certificates. The information provided in the certificates should have prompted follow up communication with the certifying laboratory. The air monitoring manager stated that the assumption was that if the standard was received from the lab, the device must have received passing results. Recommendation: A schedule should be established so that standards are recertified within 365 days, each calendar year. A spreadsheet is currently used to track standards within the agency and could be modified such that recertification due dates are conditionally formatted so that when deadlines approach, attention is drawn to the standard with ample time to have the standard sent for recertification prior to the deadline. Recertifications should be staggered so that a certified standard is always available, if needed. A field for certification expiration date should be added to field sheets so that site operators and data reviewers will have visual reinforcement that the standard utilized is within certification. If a standard does surpass the certification expiration date, the standard should be labeled or tagged, alerting operators that the standard is not to be used for critical calibrations or verifications until recertification has occurred.


Standard certificates should be thoroughly reviewed and approved by QA personnel prior to equipment being deployed to the field. To ensure that standards were not damaged or altered during shipping, or that no errors occurred during recertification, it is best practice to compare standards received from the recertification laboratory to other certified standards within the agency before use and document these results. If standards do not meet acceptance criteria and maintenance or recalibration is necessary, corrective actions should occur.

4.5.4 Observation: Required training curriculum for new hires should be established and completion of each requirement documented.

Discussion: KCDAQM provides on-the-job training (OJT) to field technicians; however, a specific training plan for each monitoring position, enumerating the specific QA and technical courses has not been established. Technology and regulations are continually evolving with air monitoring, and staff should be encouraged to continue to pursue training in order to guarantee data collection operations remain of high quality. For example, KCDAQM is in the process of upgrading its PM2.5 field equipment with 2025i samplers. Vendor-supplied training, while a significant immediate expense, can save resources in the future by preventing data loss due to unfamiliarity with new equipment. Recommendation: KCDAQM should formally document their training activities, taking credit for the OJT provided to staff. Additionally, individual training plans should be created for each air monitoring position, which define specific courses and training required to be completed before the employee is considered competent in their assigned roles. SESD further recommends that certificates of completion, indicating when staff successfully complete each training/course, be retained with the training plan. Training records will benefit KCDAQM by providing additional confidence in the quality and defensibility of the data produced by the agency.

5.0 Conclusions The KCDAQM has completed many upgrades and enhancements to its ambient monitoring program in the past three years. Areas of improvement are identified throughout the body of this TSA report. The dedication and commitment of the KCDAQM air monitoring staff were evident; their achievements in the past three years are commendable.

Corrective actions implemented as a result of the 2013 TSA have successfully addressed many of the areas in the KCDAQM network which needed renovation. During this 2016 TSA, the findings illustrate the need for the agency to fine-tune and standardize established procedures, especially regarding data handling activities. The findings also demonstrate the need for KCDAQM to streamline its records management practices, as well as further expand its quality assurance program.

KCDAQM operates a sizeable air monitoring network, which includes seven monitoring stations and a PM10 gravimetric laboratory. The operation of this network, thus, generates a large amount of data and


records that must be managed. Currently, KCDAQM employs a combination of electronic and hardcopy recordkeeping practices. During this TSA, SESD auditors observed that all requested records were available, but were not always easy to locate.

KCDAQM maintains multiple logbooks across its network, with logbooks dedicated to equipment, sites, and laboratory activities. Many of these logbooks are kept in the field or laboratory until the end of the calendar year, yet each contain vital information for data validation procedures. Additionally, PM10 laboratory data is recorded in multiple logbooks and the documentation was found to be inadequate in some instances. Although maintaining hardcopy and electronic records is acceptable, retrieving information from multiple locations – in multiple formats – can significantly slow the data validation process. Therefore, SESD recommends KCDAQM consolidate more of its ambient air monitoring records into a centralized repository. Towards that end, SESD suggests that KCDAQM consider digitizing more of its recordkeeping practices. Upgrading records in this manner should simplify data handling activities and save time. Utilizing more electronic data management tools – such as spreadsheets and databases – can augment the agency’s quality system by ensuring complete data entry, as well as automating more data verification processes, which will also save staff time and potentially minimize data validation errors.

Along those lines, some QA/QC data processing errors were identified by SESD auditors which were not identified by KCDAQM staff during the in-house data verification/validation process. Instances were identified during the audit where ozone, PM2.5, and PM10 data of insufficient quality were entered into AQS. When investigated, adequate information was provided for each data point, providing proof that the data were invalid; however, the lack of a thorough validation process allowed the invalid data into the official record. A few instances where the agency’s ambient data were not consistently compared to the results of QA/QC checks were also noted. These data handling errors (identified in Section 4 of this report) require corrections in AQS. SESD requests to be notified when all corrections have been made. Please note that any modification to data in AQS after it has been originally certified pursuant to 40 CFR 58.15 requires a recertification of the data. Ultimately, these data processing errors are indicative of limited resources available for quality assurance activities. KCDAQM should augment its data verification and validation procedures, add an additional layer of review for data that is manually prepared, and then standardize these procedures in the data handling sections of each pollutant SOP (or consolidate data handling procedures into a single Data Handling SOP).

Existing KCDAQM quality system documents are overdue for revision. Significant changes have occurred in the agency since the QAPP was last revised in 2009, as well as multiple revisions to monitoring regulations and EPA guidance. The QAPP does not address the specific nature of the source-oriented lead monitoring project, which may require a separate QAPP to address the unique objectives associated with that lead monitoring network. The SOPs in place do not accurately reflect the work performed by staff nor improvements made within the network. Therefore, SESD is requesting KCDAQM develop a revision schedule for its quality documents, and begin submitting those documents to EPA for approval. EPA Region 4 further recommends that QAPPs be frequently updated to reflect current agency operations or changes in regulation, with revisions happening at least every 5 years, per grant commitments. SOPs should be reviewed internally on an annual basis, to proactively assess whether the SOPs correctly


implement the agency’s QAPP and EPA regulatory requirements. The annual review of SOPs should be tracked and documented.

Finally, KCDAQM would benefit from assigning the role of a quality assurance officer to a staff member who will be dedicated to quality assurance activities. KCDAQM has recently become its own PQAO, which brings with it additional QA responsibilities. Areas where increased resources are needed in the QA program include QAPP/SOP oversight and maintenance, instrument certification, Appendix E siting evaluations, implementation of internal performance and systems audits, in addition to the data handling activities mentioned above. KCDAQM must develop a corrective action plan and timeline to address the findings and concerns identified in Section 4 of this report and respond back to SESD within 30 days of receipt of the final TSA report. Please note that the corrective actions do not have to be completed by this date, only a plan to address the findings and observations do not require a corrective action. If KCDAQM anticipates that the development of the corrective action plan will not be completed within 30 days after the receipt of the final TSA report, please contact SESD to request an extension.

SESDFORM-058-R0 Page 24 of 80 Ambient Air Monitoring TSA Form

APPENDIX A

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


Table of Contents 1) GENERAL INFORMATION

a) Program Organization b) Personnel c) Training d) Facilities

2) QUALITY MANAGEMENT

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 / 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) DATA MANAGEMENT

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 Maintenance d) Laboratory Record Keeping e) Laboratory Data Acquisition and Handling f) Specific Pollutants: Particulate Matter

(Including High Vol PM10, Low Vol PM10, PM2.5, PM10-2.5 & Pb)


1) GENERAL INFORMATION a) Program Organization Organization Name:

Knox County Department of Air Quality Management Address: (include physical and mailing addresses if different)

Physical: 1403 Davanna St. Mailing: 140 Dameron Ave.

City, State, and Zip Code: Knoxville, TN 37917

Phone: Main: 865-215-5900

Agency Director:

Lynne Liddington Ambient Air Monitoring (AAM) Network Manager:

Amber Talgo Quality Assurance Manager:

QA Auditors:

Al Iannacone Field Operations Supervisor / Lead:

Laboratory Supervisor:

QA Laboratory Manager:

Data Management Supervisor / Lead:

AQS Submitter:

Amber Talgo Rebecca Larocque Daniel Tipton


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

Al IannaconeEnvironmental HealthQA & Internal Auditor

Lynne LiddingtonDirector

Brian RiveraAir Program Manager

William SchaadEnvironmental Specialist

II

Coby WebsterEnvironmental Specialist

II

Steve EspositoEnvironmental Specialist I

Jared HeynsEnvironmental Specialist I

Amy MullikinEnvironmental Specialist I

Brad HuffstetlerEnvironmental Specialist I

Melanie DeFordOffice Manager

Mark HenrySecretary

Amber TalgoAir Monitoring Program

Manager

Barron WhiteEnvironmental Specialist I

Rebecca LarocqueEnvironmental Specialist I

Daniel TiptonEnvironmental Specialist I


b) Personnel

In your agency, are site operators responsible for running all of the instruments at their assigned sites, certain instruments (ex. O3) at multiple sites, or a combination of the two? Site operators are assigned specific instruments at multiple sites

List available personnel and select their primary duties:

Name Network

Design and Siting

QC Activities

QA Activities

Equipment Repair &

Maintenance

Data & Data Management

Financial Management

Site Operation

(PM, Gaseous,

Met)

Other Non-Ambient Air Monitoring

Duties

Amber Talgo X X X X X

Al Iannacone X X X

Barron White X X X X X

Daniel Tipton X X X X X

Lynne Liddington X X

Rebecca Larocque X X X X X X


List personnel who have authority or are responsible for:

Activity Name Title

QA Training Field/Lab Amber Talgo Monitoring Manager

Grant Management Lynne Liddington Director

Purchases Greater than $500 Lynne Liddington Director

Equipment and Service Contract Management Amber Talgo Monitoring Manager

Staff Appointment Lynne Liddington/ Amber Talgo Director/ AMM

Monitoring Operations Amber Talgo Monitoring Manager

Questions Yes No Comments

Does your agency utilize any contractors in your air monitoring program? If no, skip to the next table.

x Lead analysis –First Analytical(FAL) IML: PM 2.5 filter analysis

Who is responsible for oversight of contract personnel?

Oversight of contracts only, Lynne Liddington &Amber Talgo

What steps are taken to ensure contract personnel meet training and experience criteria?

Contract lab is responsible for their own training and experience criteria

Does the contractor follow an approved EPA QAPP? X

- Where/how is this documented?

IML- NELAP accreditation, EPA approved QAPP on file at KCDAQM. FAL- has NELAP & VELAP certifications, registered lab by the Pennsylvania DEP and participates in EPA audits through the state of NC. All certifications and accreditations can be found on the company’s websites.

How often are contracts reviewed and/or renewed? As needed

Comment on the need for additional personnel, if applicable: Starting in January 2015, we were fully staffed!!!!

List your district/regional offices and associated staff below (State Agencies Only)

Name Address Staff


c) Training

Question Yes No Comments

Does the agency have a training program and training plan? X

Where is it documented? “Annual Check sheet for KCDAQM Ambient Monitoring”

Does it make use of seminars, courses, and/or EPA sponsored courses? X

Are personnel cross-trained for other ambient air monitoring duties? X

Are training funds specifically designated in the annual budget? X

Does the Training Plan Include: 1. Training requirements by position X

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)

1. WebNet Training Monthly All staff

2. Awaiting approval from management for: Thermo webinar training for TEOM, BETA and 2025i

Varies All lab staff

3.


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

Facility Address General Office Space

Data Verification

and Processing

Criteria Gas Instrument

Maintenance and Storage

Standards Certification / Calibration

PM Filter Weighing

Records Storage

Air Toxics Maintenance and Storage

Air Toxics Laboratory

1403 Davanna St, Knoxville, TN 37917 X X X X X X N/A N/A

Are monitoring sites ever used for storage of equipment, spare parts or supplies?

Rarely Identify any facilities that should be upgraded. Identify by function and any suggested improvements or recommendations.

Are facilities adequate concerning safety? If not, please explain and give suggested improvements or recommendations.

Yes


Are there any significant changes likely to be implemented to agency facilities within the next three years?

Facility Function Proposed Change - Date

no

Comment on the agency’s need for additional physical space (laboratory, office, storage, etc.)

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 / dedicated equipment, different personnel and calibration methodologies are purposely used in performing QA audits, performance checks, etc.


Does the agency perform QA activities with internal personnel? If no, skip this table. X

KCDAQM utilizes an internal auditor who is employed by a separate department, Environmental Health.

Does the agency maintain a separate laboratory to support quality assurance activities?

Has the agency documented and implemented specific audit procedures separate from monitoring procedures?

Are there two levels of management separation between QA and QC operations? Please explain:

Does the agency have separate auditing equipment and standards (specifically intended for sole use) for audits?


Do you conduct biweekly precision point checks? Yes

Are they automated or conducted manually?

Manually

Select which of the following additional QC you conduct at your gaseous sites

Precision Checks Typically Performed?

How? Frequency

Manually Automated

Precision Point 75

Zero Precision Span

0/400 *no precision point BOA Nightly

Zero Precision

Probe Line Integrity Checks 400 TTP Monthly vs.

Nightly 400 BOA

Other: _________

ii) Audits


Does the agency have separate facilities to support audits and calibrations? X

If the agency has in place contracts or agreements with another agency/contractor to perform audits/calibrations, please name the organization and briefly describe the type of agreement.

IML- PM 2.5 analysis and data to AQS format FAL- Lead analysis of TSP HI-Vol filter

Does the agency maintain independence of audit standards and personnel? X

Do any site operators audit their own sites? X

Does the agency have a certified source of zero air for performance audits? X

How do you generate your zero air? Gast pump pulls air through two canisters of silica and 1 canister of charcoal.

Does the agency have procedures for auditing and/or validation performance of meteorological monitoring?

X

Has the agency established and documented criteria to define agency-acceptable audit results? X



Are your sites regularly reviewed for Appendix E siting criteria? X Frequency: Quarterly during internal

audits

Do you conduct internal audits of your air monitoring agency? X

(1) How frequently? Quarterly

(2) What type of audit is conducted (e.g., performance or systems audit)? Performance, site criteria,

(3) Who receives the results of these audits?

Director, Lab Manager, AQS Site operator (through log book)

(4) Do you report these results to EPA? X AQS performance results

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 Certification

Approximate Age (years)

BGI Delta Cal 94 9/21/2015 >10

BGI Tri Cal 187 9/16/15 >10

Hi-Vol Cal 96 921/12 3

Level II Ozone Transer standard Teledyne 703E (187) 12/18/15 6

**Please have certifications of standards available for viewing during the audit



Does your agency participate in NPAP, PM2.5 PEP, Pb PEP and other performance audits performed by an external party and/or using external standards?

X

If the agency does not participate, please explain why:

Are NPAP audits performed by QA staff, site operators, calibration staff, and/or another group?

X EPA contractors

Is your agency audited by the State (if you are a local agency)? X

Since KCDAQM is not certain of the validity of these audits, they are not entered into AQS by KCDAQM.

(1) How frequently? Twice a year

(2) What type of audit is conducted (e.g., performance or systems audit)? Performance

(3) Who receives the results of these audits?

State of TN, KCDAQM Director, Lab Manager and Site operators

(4) Do you report these results to EPA? X

Who is primarily responsible for coordinating participation in: (1) The National Performance Audit Program (NPAP)? Lab Manager (2) PM2.5 Performance Evaluation Program (PEP)?

Lab Manager (3) Lead Performance Evaluation Program (PEP)?

Lab Manager

Please complete the table below:

Parameter Audited Date of Last NPAP and/or PEP Audit

CO N/A

O3 9/30/14

SO2 N/A

NO2 N/A

PM2.5 4/21/16

Pb 2014

b) Planning Documents


QMP Questions Yes No Comments

Has the QMP been approved by EPA within the last five years? X

Date of Original Approval: 2/2/12 Date of Last Revision: 12/21/11 Date of Last Approval: 2/2/12

QAPP Questions Yes No Comments

Has the QAPP been reviewed by EPA ? X Date of Original Approval: 11/5/10 Date of Last Revision: Date of Last Approval: 11/5/10

Does the State review your QAPP prior to EPA review? (local agencies only) X

Does your agency have any revisions to your QAPP pending? X

How does the agency verify the QAPP is fully implemented?

QAPP is available to all staff in electronic copy form

How is the QAPP available to the staff (e.g.., electronically, hard copies at site, etc.)

QAPP is available to all staff in electronic copy form

SOP Questions Yes No Comments

How does the agency verify that the SOPs are implemented as provided (e.g., staff are regularly observed for correct implementation of SOPs)?

Part of the up and coming training program is the “Annual Check sheet for KCDAQM Ambient Air Monitoring”

How are revisions to the SOP distributed? Available electronically on the L drive. Usually discussed with staff and email is sometimes used as well

How are SOPs available to the staff (e.g.., electronically, hard copies at site, etc.) Electronically and hard copy

Are any new monitoring SOPs needed? If yes, please list in comments section. X

-Lead (pending internal review) -PM 10 Continuous (pending internal review) -Ozone (being written) -PM 2.5(being written -Audit (pending EPA approval) PM 2.5 continuous for AQI

List all of the agencies current SOPs:

Title Date of Last EPA Approval Pollutant of Concern (if applicable)

Standard Operating Procedure for General Metal Works High Volume PM 10 monitors VFC

11/23/10 PM 10

Standard Operating Procedure for General Metal Works VFC High Volume TSP.Pb monitors

11/23/10 Lead

Standard Operating Procedures for the Rupprecht and Patashnick Model 2025 Sequential Sampler

9/10/07 PM 2.5 Sequential

SOP for Internal Audit of Monitors and Technical Systems Pending EPA approval Audit


Measurement of Ozone Standard Operating Procedure Pending EPA approval Ozone

TEOM (Tapered Element Oscilating Microbalance) PM 2.5 or FEM PM10 Thermo 1405a Standard Operating Procedures

Pending final internal review PM 10 continuous

VOLUMETRIC-FLOW-CONTROL (VFC) HIGH VOLUME TSP/Pb MONITORS Standard Operating Procedures

Pending initial internal review Lead in TSP High-Vol


c) General Document Policies


Does the agency have a documented records management plan? X

Does the agency have a list of files considered official records and their media type? (i.e., paper, electronic)

X

Does the agency have a schedule for retention and disposition of records? X

Are records maintained for at least three years? X

Who is responsible for the storage and retrieval of records? Air Lab Staff

What security measures are utilized to protect records? Locked doors, limited entry

Where/when does the agency rely on electronic files as primary record? PM 2.5 monitor data, PM 2.5 lab reports,

What is the system for storage, retrieval and backup of these files?

PM 2.5 monitor data-backed up on external hard drives and a flash drive and a separate computer. The separate computer is backed up as well with an external hard drive. Continuous data come into the lab via AirVision. AirVision is backed up periodically on to the server. The server itself is located in another building. The ozone data is also stored on site lap tops using AV Trend.


d) Corrective Action(s)


Does the agency have a comprehensive corrective action program in place? X

Have the procedures been documented? X

1. As a part of the QA project plan? X

2. As a separate standard operating procedure?

Does the agency have established and documented corrective action limits for QA and QC activities? X

Are procedures implemented for corrective actions based on results of the following which fall outside of established limits:

1. Performance Evaluations X

2. Precision Goals X

3. Bias Goals X

4. NPAP 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

All corrective action starts with an investigation to why the problem occurred/is

occurring once it is reported to the lab manager. Most problems are the result of malfunctions and if that malfunction isn’t identified, it can become hidden by


calibrating it into the system. Once the malfunction is corrected, then the data needs to be evaluated. Verifications, audits and other local data are considered; as well as, knowing the cause of the problem are used to determine the last valid data point(s). Appropriate null data codes are applied to affected data and logbooks are filled out with explanations of the corrective action.

How does the agency follow up on implemented corrective actions? Once a problem is recognized, by either the site operator or management, it is discussed

between lab manager and site operator and corrective action is taken. The director is notified if need be.

Please fill out the table below for precision

Pollutant Action Level Corrective Action (if exceeded) Redbook Guidance Action Level Reference

O3 % difference > ± 5% investigate

±7% failure

Check for leaks and repeat test, 2nd failure= notify supervisor, note last successful QC activity and investigate problem. (Results ≤5% investigate, repeat test and consider recalibration

QA Handbook Volume II, Appendix D Revision

No. 1 Page 3 of 30

CO QA Handbook Volume

II, Appendix D Revision No. 1 Page 5 of 30

NO2 QA Handbook Volume


SO2 QA Handbook Volume


Please fill out the table below for accuracy

Pollutant Action Level Corrective Action (if exceeded) Redbook Guidance Action Level

O3

0: -5ppb≤ 7 ≥ 5ppb Concentration points:10% of TS concentration Slope of linear regession: .09< >1.1 Intercept of linear regression: -5ppb< > 5ppb

If any of the analyzer’s zero concentration or any of the concentration points acceptance criteria are not met, the environmental specialist will reconnect the site transfer standard and perform a calibration verification. The cause for failure should be determined prior to re-calibration. The data shall be entered into the Quarterly Audit Workbook. The slope, intercept, and correlation will be verified during the preparation of the Audit Report. The Auditor should note the date of the last acceptable zero/precision or calibration

QA Handbook Volume II, Appendix D Revision

No. 1 Page 3 of 30


Correlation2 of linear regression: >0.95

verification from the analyzer log book to add to the final report. Analyzer concentrations varying by >7% are considered marginal. Environmental specialist should perform a zero/precision/ span check with the site transfer standard and evaluate results for further actions.

CO QA Handbook Volume


NO2 QA Handbook Volume


SO2 QA Handbook Volume


At what point do you invalidate data? Precision: data is invalidated after 7% deviation. Accuracy: data is invalidated after 10 % deviation


e) Quality Improvement


Have all deficiencies indicated on the previous TSA been corrected? If not, explain. X

Updates to SOPs , QMP and QAPP are in process. 2.5 sequential and QAPP have been started, PM 2.5 continuous & QMP are outstanding. Pb&PM 10 continuous have been completed and are pending internal review Audit SOP and Ozone SOP are pending EPA approval

What actions were taken to improve the quality system since the last TSA?

Updating of forms, consistence in forms used, sticky labels for the logs, addition of a staff position, streamlining of QA data into AQS, more organization

Since the last TSA, do your control charts indicate that the overall data quality for each pollutant steady or improving?

x

For areas where data quality appears to be declining, has a cause been determined?

Are there pending plans for quality improvement such as purchase of new or improved equipment, standards, or instruments?

x 3 new 2025i’s are slated for purchase, 1 has already been purchased, a new URG 3000N is slated for purchase


3) NETWORK MANAGEMENT/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).

AQS ID Common Site Name Pb

CO

SO2

NO

2

O3

Manual Collocated Continuous

Met

eoro

logy

PM2.

5

PM10

PM2.

5 sp

ecia

tion

PM2.

5 C

arbo

n

PM2.

5

PM10

PM2.

5

PM10

47-093-0021 East Knox x

47-093-1020 Spring Hill x x x x

47-093-1013 Air Lab x x x x x

47-093-1017 Rule x x

47-093-0023 Ameristeel x

47-093-0027 Burnside x

47-093-0028 Bearden x x


Complete the table below with the number of spare monitor(s) you have on hand for measuring each pollutant (including NCore low level instruments).

Pb CO SO2 NO2 O3 Manual Collocated Continuous

Meteor-ology PM2.5 PM10 PM2.5

speciation PM2.5 Carbon PM2.5 PM10 PM2.5 PM10

3 1 2 3 0 1 0


Select which of the following are typically found at your Gaseous and PM sites

Equipment/ Supplies Gaseous PM

Data Logger x

Calibrator x

Gas Blender

Zero Air System internal

Perm Tube Oven

Paper Strip Chart

Permanent Site Computer x

Phone

Modem x x

DSL Connection x

Cellular Modem Connection

Meteorological Station

Interior Temperature Probe x Built in to monitor

Interior Min/Max Thermometer x Built in to monitor

Air Conditioner / Heater x Built in to monitor

Uninterrupted Power Supply or Backup Power x

Instrument Manuals x

Instrument Logbooks x x

Site Logbook x x

SOP’s

Other:______________

Other:______________


If none of the above is applicable, please describe your probe system.

How often do you clean / replace your probe lines?

yearly What material are your probe lines made of?

PTFE What material are your inlet funnels made of (e.g. glass, Teflon, plastic)?

Glass How often do you change the particulate filter on the back of the instrument?

Twice a year, external TTP bi-weekly How often do you clean your glass manifold (if applicable)?

How do you connect your instrument to your data logger (analog, RS232, or Ethernet)?

RS232

Select which of the following are typical of your Probe System

Tee’d Probe System x

Retractable Probe System

Glass Manifold within Probe System

Heat Tape for Moisture Control x


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?

Question Yes No Comment Are hard copy site information files retained by the agency for all air monitoring stations within the network?

x Part of AMP

Does each station have the required information including:

1. AQS Site ID Number? x

2. Photographs/slides to the four cardinal compass points? x electronic

3. Startup and shutdown dates? x In AQS & AMP

4. Documentation of instrumentation? x Part of AMP

Who has custody of the current network documents?

Name: Jason Stephens Title:TDEC Air Monitoring Manager

Does the current level of monitoring effort, station placement, instrumentation, etc., meet requirements imposed by current grant conditions?

x

How often is the network siting reviewed? 5 year plan

Do any sites vary from the required frequency in 40 CFR 58.12? x More than required

Does the number of collocated monitoring stations meet the requirements of 40 CFR 58 Appendix A?

x

Is each method for PM monitoring collocated with the same method type? (40 CFR 58 Appendix A Section 3.2.5.2 paragraph (a))

x


What is the date of the most current Monitoring Network Plan? 2016

Is it available for public inspection? x


b) Changes to the Network since the Last Audit

Please provide information on any site changes since the last audit: ?TSA Audit?

Pollutant Site ID Site Address Site

Added/Deleted/ Relocated

Reason (Assessment, lost lease, etc.) Provide documentation of reason for

each site change PM 2.5,10,

PM 2.5 continuous

1013 Stewart St Relocated Evicted from 1403 Davanna St.

Pb 0023 1526 New York Ave. Relocated Gerdau purchased land and closed

right of way@ 1584 Ely Ave

c) Proposed Changes to Network

Please provide information on proposed site changes, including documentation of the need for change and any required approvals:

Pollutant Site ID Site Address Site to be

Added/Deleted/ Relocated

Reason (Assessment, lost lease, etc.) Provide documentation of reason for

each site change

d) Field Support


On average, how often are most of your stations visited by a field operator? weekly

Is this visit frequency consistent for all reporting organizations within your agency? x


i) Instrument Inventory

Please list instruments in your inventory:

Pollutant Manufacturer Models Reference or

Equivalent Method Number

SO2

NO2

CO

O3 Teleydyne 400E EQOA-0992-087

PM10 Anderson/GMW PM 10 Hi-Vol RFPS-1287-063

PM2.5 R&P Partisol-Plus 2025 RFPS-0498-118

Pb Anderson/GMW TSP Hi-Vol

Reference Method for TSP Manual Reference Method: 40 CFR Part 50, Appendix B Reference Method for the Determination of Suspended Particulate Matter in the Atmosphere (High-Volume Method) Federal Register: Vol. 47, page 54912, 12/06/82 and Vol. 48, page 17355, 04/22/1983 Analytical method: The samples were prepared according to 40CFR50 Appendix G, “Reference Method for the Determination of Lead in Suspended Particulate Matter Collected from Ambient Air.” Analysis: Lead was determined by Inductively Coupled Plasma Spectroscopy (ICPMS). The most recent update to 40CFR50 Appendix G, dated Jan 9, 2014, allows for determination by ICP-MS.


Multi gas calibrator

PM2.5 speciation Metone URG

SuperSASS 3000N

na URG-These filters are analyzed for organic and elemental carbon using Thermal Optical

Analysis Method (TOA)

PM10-2.5 speciation

PM10-2.5 FRM mass

Continuous PM2.5 mass Thermo Beta 5014i EQPM0609-183

Trace levels (CO)

Trace levels (SO2)

Trace levels (NO)

Trace levels (NOy)

Surface Meteorology

Data Logger ESC 8832 na

Others(PM 10 continuous) Thermo TEOM 1405a EQPM-1090-079


ii) Calibration

Please indicate the frequency of multi point calibrations:

Pollutant Frequency Name of Calibration Method

PM 2.5 Annually or as needed 3 Point

Ozone Pre, mid and post season 5 point calibration /verification

PM 10 and Pb Annually Multi-point calibration verification

Please list the authoritative standards used for each type of flow measurement, indicate the certification frequency of standards to maintain field material/device credibility:

Flow Device Primary Standard Frequency of Certification

HiVol Cal

Sent to Mesa for recertification Serial #: Dresser Roots Meter S/N 1018407 Temp: Accu-Safe S/N 254881 BP: Vaisala Model PTB330(50-1100) S/N DH0850001 Manometers: Dwyer S/N 10DWY09-0015, 10DWY09-0016

Annually

Streamline

Sent to Chinook for recertification Flow: Critical Flow Venturi S/Ns 10961, 10963, 18491, 30421 BP: Precision Barometer S/N 913930-M1 Temp: NIST Traceable Hg-in-glass thermometers 2J3106, 2Y6027, 3L9452

Annually

Tetracal

Sent to Mesa for recertification Critical flow venture: CEESI NVLAP NIST Data File 07BGI-0001, CEESI NVLAP NIST Data File 07BGI-0003, CEESI NVLAP NIST Data File 07BGI-0004, CEESI NVLAP NIST Data File 07BGI-0002 BP: Vaisala Model PTB330(50-1100) S/N DH085001 Temp: S/N 254881

Annually

DeltaCal Sent to Mesa for Recertification

Critical Venturi Flow Meter: CESI NVLAP NIST Data File 04BGI151, 04BGI152, 04BGI153, 02BGI004

Annually


Temp: S/N 01607 BP: Vaisala Model PTB330(50-1100) S/N D4310002

Defender Sent to Mesa for recertification ML 500-44 S/N 113762 annually

Gilibrators

Other

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 Controller

Permeation Calibrator Temperature

Dilution Calibrator air and gas Flow Controllers

Field/Working Standard Photometer

Ozone Generator

Please identify station standards for gaseous pollutants at representative air monitoring stations

Parameter Station(s) Identification of Standard(s) Recertification Date(s)

CO

NO2

SO2

O3 Spring Hill East Knox

190 189

2/12/16 2/11/2016


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.)?


iii) Repair


Are field calibration procedures included in the document SOPs? x Location (site, lab, etc.):

Are calibrations performed in keeping with the guidance in section Vol II of the QA Handbook for Air Pollution Measurements Systems?

x If no, why not?

Are calibration procedures consistent with the operational requirements of Appendices to 40 CFR 50 or to analyzer operation/instruction manuals?

x If no, why not?

Have changes been made to calibration methods based on manufacturer’s suggestions for a particular instrument?

x

Do standard materials used for calibrations meet the requirements of appendices to 40 CFR 50 (EPA reference methods) and Appendix A to 40 CFR 58 (traceability of materials to NIST-SRMs or CRMs)?

x

Where do field operations personnel obtain gaseous standards?

NO CYLINDERS ARE USED, OZONE GENERATION VIA TRANSFER STANDARD

Are those standards certified by: 1. The agency laboratory? X Level III

2. EPA/NERL standards laboratory? X Level II

3. A lab separate from this agency’s but part of the same reporting organization? x

4. The vendor? x

5. Other (describe) x

How are the gas standards verified after receipt? Compared to level II

Are you involved in the EPA protocol gas certification program? x

What equipment is used to perform calibrations (e.g., dilution devices) and how is the performance of this equipment verified?

The Level II standard is certified by comparing it to EPA’S level I standard. Our level III standards are compared to our Level II standard.

Does the documentation include expiration date of certification? X For level II to level I certification

1. Reference to primary standard used? X

2. What traceability is used? Level II standard to Athens to be certified against Level I standard

Is calibration equipment maintained at each station? X

How is functional integrity of this equipment documented?

Routine precision checks and verifications recorded in logbooks and in QA/QC log

Who has responsibility for maintaining field calibration standards? A. Talgo


a) Who is responsible for performing preventative maintenance?

Site operator b) Is special training provided to them for performing preventative

maintenance? Briefly comment on background or courses. B. White has had no formal technical training with PM or Pb monitors. He did attend the Teledyne course and is provided with an SOP and operation manuals with specifics on preventative maintenance. He has had employee to employee training with A. Talgo on the PM 2.5 monitors. Through his experience, he has learned a great deal since the last TSA audit. A. Talgo has had R&P training on the 2025 and the TEOM 1400ab as well

as Teledyne training over the ozone equipment; she also attended the EPA’s QA training in Nashville in 2015 as well as the Region 4 Conferences in 2013-2015.

D. Tipton attended QA training in Nashville in 2015, but has not had any formal training other than OJT. He has worked extensively with Teledyne and other monitoring organizations to learn skills needed to run the ozone network. He also attended the 2016 Region 4 Conference. R. Larocque has had no formal training for air monitoring other than OJT. She attended the Region 4 2015 conference and has participated in various webinars for AQS. Web based training is being scheduled for all staff for the Thermo instrumentation. c) Is this training routinely reinforced? If no, why not?

No. Specific courses were taken on the 2025’s, the Teledyne ozone equipment, the chemical speciation equipment and the TEOM. This training has been disseminated through the staff through OJT. We have started a new “Annual Check Sheet for KCDAQM Ambient Air Monitoring”. This is being used to make sure each staff member is once a year being observed doing there back up duties, or learning a new procedure.

c) What is your preventative maintenance schedule for each type of field

instrumentation?

PM 2.5 sequential: Every 10 Runs: Install Field Blank. Monthly: Clean PM-10 inlet, first stage inlet and VSCC assembly, Perform single point Temp., Pressure, and Flow QC check plus an internal and external leak check, Check clock time (<+/-1min).


Quarterly: Inspect "V" Seals and O-Rings, and clean down tube Semi-annually: Exchange partical trap filter, test/replace batteries and clean/replace air intake filters. Annually: Perform Temp., Pressure and Flow calibration. Rebuild piston pumps every 18 months

Pb in TSP: 1. Power lines: checked for crimps or cracks on sample recovery days. Fittings, inspected periodically for cross-threading and tightness. 2. A filter screen and the throat of the choked-flow venturi: inspected on sample recovery days for any impacted deposits. 3. Filter cassette gaskets: checked each time a filter is installed. A worn cassette gasket is characterized on exposed filters by a gradual blending of the boundary between the collected particulates and the filter border. 4. Motor and housing gaskets: checked at 3-month intervals and replaced as necessary. 5. Blower motor brushes: checked every 6 months (3 months for AQI monitors). Change the brushes as needed according to manufacturer’s instructions, and perform the operator’s calibration verification as presented in Section 2.7. If the sampler’s indicated flow rate exceeds the manufacturer-specified design flow-rate range, recalibrate the sampler before the next run day. New brushes must be conditioned on a motor for 30 min at 50 percent of the normal line voltage before installation on monitors. PM 10: The impaction inlet shall be dismantled and cleaned once every 6 months to preclude problems with particle bounce. (The AQI HV PM10’s require cleaning once every 3 months due to their 5 in 7 run schedule.)


1. Power lines, checked for crimps or cracks on sample recovery days. Fittings, inspected periodically for cross-threading and tightness.


2. A filter screen and the throat of the choked-flow venturi, inspected on sample recovery days for any impacted deposits. 3. Filter cassette gaskets, checked each time a filter is installed. A worn cassette gasket is characterized on exposed filters by a gradual blending of the boundary between the collected particulates and the filter border. 4. Motor and housing gaskets, checked at 3-month intervals and replaced as necessary. 5. Blower motor brushes, replaced every 6 months (3 months for AQI monitors). Change the brushes according to manufacturer’s instructions, and perform the operator’s field-calibration check as presented in Section 2.7. If the sampler’s indicated flow rate exceeds the manufacturer-specified design flow-rate range, recalibrate the sampler before the next run day. New brushes must be conditioned on a motor for 30 min. at 50 percent of the normal line voltage before installation on monitors. TEOM

Procedure Frequency Filter Change Every 30 days or filterload ≥95% PM10 head cleaning Every 30 days Inline filter replacement 6 months Entire Sample line cleaning Annually Rebuild Pump As necessary

Beta

Procedure Frequency Filter Tape Change As needed PM10 head cleaning Every 30 days VSCC cleaning Every 30 Days Entire Sample line cleaning Annually Rebuild Pump As necessary

Site Maintenance – Change air filter every 6 months, as well as AC batteries. Also note Sample line cleaning is usually done every 6 months, but per SOP can be annually. Let me know if you want QA type stuff as well. Like Mass Calibration’s (annually but we haven’t in quite awhile) and the other verifications/ calibrations For example the Beta says Detector calibration annually and mass calibration annually. We do not currently have the kits to perform these.

O3:

Site Maintenance Schedule

1. Semi-Annually – Change shelter’s HVAC filters, change shelter’s thermostat batteries.


Semi-annual maintenance should be performed before the start of ozone season and midway (June or July) through ozone season.

2. Annually – Replace and condition sample and calibration gas lines. Change silica gel in both cylinders. Change external zero air system particulate filter. Annual maintenance should be performed before the start of ozone season.

Analyzer Maintenance Schedule

1. Daily – Check ozone minute data and nightly zero/span data with Agilaire AirVision software. This will help identify a potential problem regardless of the cause.

2. Weekly – Check the instrument test functions, the shelter’s minimum and maximum temperatures, and that the first silica gel canister is ≥ 25% blue.

3. Biweekly – Replace the in-line sample filter. Check the ambient sample line for cleanliness and moisture condensation.

4. Semi-Annually – Change analyzer’s internal particulate filter.

Semi-annual maintenance should be performed before the start of ozone season and midway (June-July) through ozone season.

5. Annually –Rebuild or replace sample pump. Replace and

condition the O3 scrubber. Perform a vacuum leak check, sample flow check, sample pressure check, and photometer UV lamp check. Annual maintenance should be performed before the start of ozone season.


Transfer Standard Maintenance Schedule

Annually – Rebuild or replace internal zero air system pump. Replace internal zero air system particulate filter. Replace internal zero air system charcoal filter. Annual maintenance should be performed before the start of ozone season.

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.

Thermo, Teledyne, Tish, Metone and URG are registered vendors with Knox County so we can get assistance if needed.

g) 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?

Knox County keeps a decent supply of spare parts on hand, also we have back up monitors for all parameters except the Super SASS and the TEOM. Manuals are readily available to all employees; on the shared network drive, on the book shelf and most even have their own copy. Each employee is assigned a set of tools to use and extra tools are available at the lab. If specialty tools are needed we will purchase them.

j) 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.

j) Have you ever lost any data due to repairs in the last 2 years? More than 24 hours? More than 48 hours?- URG Mass flow controller issues, temp prob issues More than a week?

k) Explain any situations where instrument down time was due to lack of

preventative maintenance or unavailability of parts.

We now keep extra mass flow controllers for the URG 3000N.


iv) Logbooks and Records


What type of station logbooks are maintained at each monitoring station? (Maintenance logs, calibration logs, personal logs, etc.)

PM 2.5 & CSN have site logs, maintenance logs and monitor logs. Pb & PM 10 have monitor and site logs (some sites use one log for both site and monitor) O3& PM 2.5 and 10 continuous monitoring Each piece of equipment has a logbook, each site has a log

What information is included in the station logbooks?

Weather conditions @ time of visit, what was done at visit, date and time of visit and who was there

Who reviews and verifies the logbooks for adequacy of station performance? A. Talgo

How often are logbooks reviewed? Annually if not more

How is control of logbook maintained?

Most logs are left on site. Pb and PM 10 logs are kept in the site bags and carried back and forth during filter changes. This is due to lack of storage space on the high-volume monitors

Where is the completed logbook archived?

Starting in 2016 each log is used for one year and then archived. Preciously, each year the log books are copied and archived. The year the book is completed will be where it is archived in its completeness.

What other records are retained? Filter tracking sheets, CoC’s, Pb and PM 10 filters, audit forms, lab reports and control charts

1. Zero span record? x

2. Gas usage log?

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 documents.

Documents are archived in archived boxes in the Data room and retained for 5 years

Are calibration records, or at least calibration constants, available to field operators?

x


Are logbooks backed up regularly to ensure against theft/vandalism? x

3) DATA MANAGEMENT

a) Data Handling


Is there a procedure, description, or a chart which shows a complete data sequence from point of acquisition to point of submission of data to EPA?

x

Please describe or provide a data flow diagram from collection to submittal of data. Please include detail regarding data review and validation.

These are in each SOP we have.

Are procedures for data handling (e.g. data reduction, review, etc.) documented? x

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

Ozone Electronically via logger to AirVision

PM 2.5 FRM Lab report emailed from IML as well as AQS data file

PB Lab report emailed from First Analytical Laboratory & filter envelops for times and pressures

PM 10 Filters weighed in house, filter envelopes used to record weight, pressures and time for

How often are data received at the processing location from the field sites and laboratory?

O3-Electronically via logger to AirVision PM 2.5- at least quarterly from IML, weekly from site PM 10 is done in house Pb- report monthly

Is there documentation accompanying the data regarding any media changes, transcription, or flags which have been placed into the data before data are released to agency internal data processing?

x

- Describe the type of documentation

PM 2.5:lab report Ozone: data come in to the AirVision software. This software flags data for operator review. The data is reviewed by the operator, as well as log books and QA/ QC charts. Appropriate flags are checked for accuracy or added. TEOM: Data comes into AirVision software and is reviewed by operator along with the logbook. Any void or flag codes are added as needed.


Pb: Data from the lab report is put into a spreadsheet along with information from the envelope needed to calculate the concentration. The envelope has site conditions or issues that could invalidate or cause flags to be added. The lab report would also list problems during analysis. PM 10 data has all needed data on the filter envelope. Operator notes could note void or flags

How is data actually entered into the computer system (e.g. computerized transcription (copy from disk or data transfer device), manual entry, digitization of strip charts, or other)?

Ozone, TEOM, Beta, PM 2.5 sequential data are all electronically entered. PM 10 and Pb data is entered manually

For manual data, is a double-key entry system used (e.g., a second pair of eyes double checking for transcription errors)?

x


b) Software Documentation


Does your agency submit data directly to AQS? x

Does your agency participate in AirNow? x

How does your agency process P/A data?

Does the agency have information on the reporting of precision and accuracy data available? x

What software is used to prepare air monitoring data for release into the AQS and AirNow database? Please list the documentation for the software currently in use for data processing, including the names of the software packages, vendor or author, revision numbers, and the revision dates of the software.

Software manuals and pollutant specific SOP’s are used. AirVision by Agilaire version 2.8.1 built 2/15/13 Spreadsheets for PM 10 and Pb TSP Pb Conc Calcs by K. Vaughn updated 2012 PM10 Conc Calcs by K. Vaughn updated 2012

What is the recovery capability in the event of a significant computer problem (i.e. how much time and data would be lost)?

Has your agency tested the data processing software to ensure its performance of the intended function is consistent with the QA Handbook, Volume II, and Section 14.0?

x

Does your agency document software tests? x Started in 2016, verified worksheets generated in house for accuracy


c) Data Validation and Correction


Has your agency established and documented the validation criteria? x

Does documentation exist on the identification and applicability of flags (i.e., identification of suspect values) within the data as recorded with the data in the computer files?

x

Does your agency document the data validation criteria including limits for values such as flow rates, calibration results, or range tests for ambient measurements?

x

This information is found in SOP’s and maintenance forms and guidance documentation from EPA

1. If yes, please describe what action the data validator will take if he/she find data with limits exceeded (e.g., flags, modifies, deletes, etc.)

The most appropriate flag or void code will be assigned. If there has been a typographical error that will be remedied. We do don’t routinely delete data. All data is important and should be evaluated and assigned a void code if invalid, not simply deleted. Deleting data just seem so so so very wrong!

2. If yes, give examples to illustrate actions taken when limits are exceeded.

Some PM 2.5 filters arrived at the lab above 4°C. the lab notifies us as soon it arrives. We look at average exposed temps in the field and compare them with the average run temp. If the exposed temps didn’t exceed the average run temp then the flag did not have to be applied.

How does the agency track missing data?

All data is accounted for with a null/void code. It is noted on the PM 2.5 sequential tracking sheet, the filter envelope for PM 10 and Lead, and in the missing data log for certain parameters

Please describe how changes made to data that were submitted to AQS and AirNow are documented.

If a void/null data code or value is changed in AQS a note of that change should be documented in the missing data log, filter tracking sheet or filter envelop.

Who has signature authority for approving corrections?

Name: Lynne Liddington Program Function: Director (This is if data has to be re-certified due to changes)

What criteria are used to determine a data point should be deleted? Discuss briefly

QA hand book and CFR are referenced for validity criteria. SOP’s are also used. *Deleted is a term we just don’t use. Data can be modified to reflect a null data code, but data should never just be deleted.

What criteria are used to determine if data need to be reprocessed? Discuss briefly

Comparison with other monitors in area Historical data Precision data

Are corrected data resubmitted to the issuing group for cross-checking prior to release? x


d) Data Processing


Does the agency generate data summary reports? x

Please list at least three reports routinely generated, including the information requested below.

Report Title Distribution Period Covered

AMP 600 Can stipulate in AQS

Data completeness Can stipulate in AQS

Raw data report Can stipulate in AQS

Question Yes No Comment How often are data submitted to AQS and AirNow?

Usually before the (90 day from end of quarter) requirement for AQS. Hourly for AirNow

Briefly comment on difficulties the agency may have encountered in coding and submitting data following the guidance of AQS guidelines

Does the agency routinely request a hard copy printout on submitted data from AQS? x

Are records kept for at least 3 years by the agency in an orderly, accessible form? x We think its orderly

If yes, does this include: 1. Raw Data? x

2. Calculation? x

3. QC Data? x

4. Reports? x

If no, please comment

Are PM10 concentrations corrected to EPA standard temperature and pressure conditions (i.e. 298˚K, 760 mm Hg) before input to AQS?

x

Are PM2.5 and Lead concentrations reported to AQS under actual (volumetric) conditions? x

Are audits on data reduction procedure performed on a routine basis? x Frequency -

Are data precision and accuracy checked each time they are calculated, recorded, or transcribed to ensure incorrect values are not submitted to EPA?

x By the person submitting it


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

No formal title, sent as a letter with Re: X Quarter Air Monitoring Audit and is dated Quarterly

Results are submitted to AQS 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

Ozone precision check control charts and field forms are printed and in a binder Bi-Weekly

Precision checks are submitted to AQS

Question Yes No Comments Do either the audit or precision check reports indicated include a discussion of corrective actions initiated based on audit or precision check results?

x

Who has the responsibility for the calculation and preparation of data summaries? To whom are such summaries delivered?

Name Title Type of Report Recipient

Rebecca Larocque Environmental specialist Bias for flow rate by site and by PQAO for Pb and PM 10

Reports deficiencies to Lab Manager

Rebecca Larocque Environmental specialist Ozone bias and CV by site and by PQAO

Reports deficiencies to Lab Manager


f) External Reporting

For the past 3 calendar years, please list all quarters that data were submitted beyond the 90 day requirement:

Identify the individual within the agency with the responsibility for reviewing and submitting the data to AQS.

Rebecca Larocque and Amber Talgo


Does your agency report the Air Quality Index? x

Has your agency submitted its annual data summary report (as required in 40 CFR 58.15)? x

If yes, did your agency’s annual report include the following:

1. Annual precision and accuracy information described in Section 4 of Appendix A? x

2. Location, date, pollution source and duration of all episodes reaching the significant harm levels?

x

Is Data Certification signed by a senior officer of your agency? x

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 Gravimetric 40 CFR 50, App J PM10 Continuous 40 CFR 50, App J PM2.5 Gravimetric 40 CFR 50, App L

Pb ICP-MS 40 CFR 50, App G: EQL-0896-107

PM10-2.5

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 your agency. Add other pollutants not listed to the table.

Analysis Documentation of Method PM10 40 CFR 50, App J, PM 10 SOP, Mfg Operator’s Manual, EPA QA handbook PM2.5 040 CFR 50, App L, PM 2.5 SOP, Mfg Operator’s Manual, EPA QA handbook

Pb 40 CFR 50, App G, Pb SOP, Mfg Operator’s Manual, EPA QA handbook

PM10-2.5

Question Yes No Comments Were procedures for the methods listed above included in the agency’s QA Project Plan or SOPs and reviewed by EPA?

x

Are the SOPs easily/readily accessible for use and reference? x

Does your lab have sufficient instrumentation to conduct analyses? x Only PM 10 is analyzed here

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 / Serial Number Last Recertification Date Weights Troemner Co K131141 1/9/2016

Barometric Pressure Balance Sartorius 5380200 1/6/2016

Thermo-hygrometers Desicator Control Company 15015824 3/09/15

Thermo-hygrometers lab Control Company 150095935 2/10/15

Other

**Please have certifications of standards available for viewing during the audit



Are all chemicals and solutions clearly marked with an indication of shelf life? na

Are chemicals removed and properly disposed of when shelf life expires? na

Are only ACS grade chemicals used by the laboratory? na

Comment on the traceability of chemicals used in the preparation of calibration standards.

Question Yes No Comment

Does the laboratory purchase standard solutions such as those for use with lead or other metals analysis? x FAL

Are all calibration procedures documented? Title: Revision Number: Document Location:

Are at least one duplicate, on blank, and one standard or spike included with a given analytical batch?

X

Briefly describe the laboratory’s use of data derived from blank analyses:

Are criteria established to determine whether blank data is acceptable? X

How frequently and at what concentration ranges does the lab perform duplicate analysis? What constitutes an acceptable agreement? EXCERT FROM lab report: “Lead was not detected above the reporting limit for the Lab Blank. The Laboratory Control Spike QC sample was within acceptance limits of 80% to 120%. The Matrix Spike QC sample was within acceptance limits of 75% to 125%. The relative percent difference between the prepared duplicates was within the acceptance limits of ≤ 20%, or could not be calculated due to the concentration being less than five times the reporting limit. All digestates were analyzed in at least duplicate.”

Please describe how the lab uses data obtained from spiked samples, including the acceptance criteria (e.g., acceptable percent recovery).

See above


Question Yes No Comments Does the laboratory routinely include samples of reference material within an analytical batch?

If yes, indicate frequency, level, & material Used

Are mid-range standards included in analytical batches?

Please describe the frequency, level, and compound used in the comments section.

Are criteria for real time quality control established that are based on results obtained for the mid-range 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 analysis documented?

c) Laboratory Preventative Maintenance


For laboratory equipment, who has the responsibility for performing preventative maintenance?

None needed, we send it out for calibration or have a contractor service our balance and weights

Is most maintenance performed in the lab? x By contractor

Is a maintenance log maintained for each major laboratory instrument? x We get service reports from

contractor Are service contracts in place for major analytical instruments? x


d) Laboratory Record Keeping


Are all samples that are received by the laboratory logged in? x

If appropriate, is sample shipping temperature recorded upon arrival? na

Discuss sample routing and special needs for analysis (or attach a copy of the latest SOP which covers this). Attach a flow chart if possible.

Barron pre and post weighs PM 10 filters. He logs them in the filter log and he gets another employee to reweigh 1:10.

Are log books kept for all analytical laboratory instruments? x

Are there log books or other records that indicate the checks made on materials and instruments such as weights, humidity indicators, balances, and thermometers?

x

Are log books maintained to track the preparation of filters for the field? x

1. Are they current? x

2. Do they indicate proper use of conditioning? x

3. Weighings? x

4. Stamping and numbering? na

Are log books kept which track filters returning from the field for analysis? x

How are date records from the laboratory archived? Archive box in data room

1. Where? In data room

2. Who has the responsibility? Title? Barron White

3. How long are records kept? 5 years

Does a chain-of-custody procedure exist for laboratory samples? x

Title & Date:PM 10 SOP & info on filter envelope Revision Number: Location:


e) Laboratory Data Acquisition and Handling

Question Yes No Comments Identify those laboratory instruments which make use of computer interfaces directly to record data. Which ones use strip charts? Integrators?

Are QC data readily available to the analyst during a given analytical run?

What is the laboratory’s capability with regard to data recovery? In case of problems, can they recapture data or are they dependent on computer operations? Discuss briefly.

Has a user’s manual been prepared for the 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. PM 2.5

Data file created in Monitor in a

delemeted text file

Text delemeted filte downloaded from

monitor to lab computer via

RPComm

Data file is uploaded into MTL software

for initial validataion to ensure all field

parameters were satisfactory.

Once all field parameters are

verified the data file is sent to IML Via email. The email includes any null

codes or flags found

IML processes data and combine it with the filter weigh data

and generate an AQS file which is sent to KCDAQM along with a filter

weigh report.

KCDAQM upload the AQS file to the

AQS data base


Pb

PM 10

All site identifying information is

recorded on the filter envelope in

addition to the filter number, run time and pre and post

run stagnation pressure.

Filter is shipped to the lab in the filter

envelope.

Filter section is digested and

analyzed via ICP-MS

Lab report is returned to

KCDAQM. The value listed on teh report is the µg of lead /

filter.

KCDAQM process the data through a

special spread sheet, "TSP Pb Conc

Calcs, date year" giving the

concentration results.

Data is entered in to AQS manually and checked over by a second set of eyes

All site identifying information is recorded on the filter envelope in

addition to the filter number, run time and

pre and post run stagnation pressure.

Filter is desicated and weighed

KCDAQM process the data through a special spread sheet, "PM 10 Conc Calcs, date year"

giving the concentration results.

Results from the PM 10 spreadsheet are input into AirVision and an

AQS text delemited file is generated and then

uploaded to AQS.


f) Specific Pollutants: Particulate Matter

High Vol PM10 Question Yes No Comments

Does the agency use filters supplied by EPA? x

Do filters meet the specifications in 40 CFR 50? x Are filters visually inspected for defects before exposure? x

Where does the laboratory keep records of the serial numbers of filters?

PM 10- logbook Pm 2.5 IML logs and data report

Are the temperature and humidity monitors calibrated? x

Are balances checked with Class S or Class M weights each day when they are used? x

To what sensitivity are filter weights recorded? 1/10000 of a gram What method of documentation is used to record filter weighing sessions? (e.g., logbook, computer software, etc.)

Logbook, filer envelope

During conditioning, are the following true: (1) Filters equilibrate for a minimum of 24 hours x

(2) The temperature range is from 15˚C-30˚C x

(3) Temperature control is ±3˚C SD over 24 hrs x

No more than a ±3˚C difference in desiccator temp during filter conditioning (pre and post)

(4) Humidity range is 20% - 45% RH x

(5) Humidity control is ± 5% SD over 24 hrs x Max humidity and Min humidity have to be within 5% of each other

(6) Pre/post sampling RH difference in 24-hr means is ≤± 5% RH x

(7) Balance is located in the conditioning environment x

Are filters packaged for protection while transporting to and from the monitoring stations? x

Are filters shipped at ambient temperature to the monitoring stations? x

Are filters shipped at ambient temperature from the field to the laboratory? x

Are exposed filters reconditioned for at least 24 hrs in the same conditioning environment as for unexposed filters?

x

Briefly describe how exposed filters are prepared for conditioning

Filters are removed from cassette with gloved hands and folded in half and placed in the desiccator.

Briefly describe how exposed filters are stored after being weighed

Filters are placed back into filter envelope and stored for at least 5 years

Are blank filters reweighed? x

Are chemical analyses performed on filters? x


If yes, what analysis is performed?

PM10-2.5 / Low Vol PM10 / PM2.5 Question Yes No Comments


Do filters meet the specifications in 40 CFR 50? x Are filters visually inspected via strong light from a view box for defects before exposure? x @ IML

Where does the laboratory keep records of the serial numbers of filters? Sent to us on filter bags and in data report

Are temperature and humidity monitors calibrated? x @ IML

Are balances checked with Class 1 weights each day when they are used? x @ IML

To what sensitivity are filter weights recorded? 1µg

What method of documentation is used to record filter weighing sessions? (e.g., logbook, computer software, etc.)

The filter weighing sessions are directly linked to the database thru software interfacing the microbalance to the computer database. Each filter has a Petri dish with a label containing the filter number and a barcode for the filter number. The barcode is scanned to enable the weight to be saved by filter number in the database weights table. Also, a hard copy of the weigh session is printed out after each weigh session for review and filed.

During conditioning, are the following true: (1) Filters equilibrate for a minimum of 24 hours x

(2) The temperature range is 20˚C-23˚C for the 24-hr mean x

(3) Temperature control is ±2˚C SD over 24 hrs x

(4) Humidity range is 30%-40% RH for 24-hr mean OR ≤5% sampling RH but >20% RH x

(5) Humidity control is ± 5% SD over 24 hrs x (6) Pre/post sampling RH difference in 24-hr means is ≤± 5% RH x

(7) Balance is located in the conditioning environment x

Are filters packaged for protection while transporting to and from the monitoring stations? x

Are filters shipped at ambient temperature to the monitoring stations? x

Are filters shipped at ≤ 4˚C from the field to the laboratory? x

Are filters post-weighed in ≤30 days? x Are filters post-weighed in ≤10 days if they arrive >4˚C? x


Are exposed filters reconditioned for at least 24 hrs in the same conditioning environment as for unexposed filters?

x

Briefly describe how exposed filters are prepared for conditioning

Filters are unloaded from the pink anti-static bag and cassette and inspected for any defects, then placed in a Petri dish with a label with the filter number and barcode for each filter. During this process each filter number is matched up with the correct Petri dish and the cassette number is also checked. Any discrepancies or defects are noted. The filters are counted to determine how many lab blanks are needed for the exposed weigh session. If lab conditions are in specification the filters are exposed by leaving the lids of the Petri dishes underneath the Petri dish and placed in sequential order in trays placed on racks in the conditioning rooms. The time is noted to begin the conditioning period.

Briefly describe how exposed filters are stored after being weighed

After all the filters are weighed, they are placed back in the Petri dish with the same filter number. The Petri dish is closed and put inside the pink anti-static bag. The pink bags are group together with a rubber band and then placed inside a plastic bag with the exposed weigh date written on the outside of the bag. The filters are taken to the archive walk in cooler (kept at <4˚C) and stored in a separate plastic tub labeled for each client for at least one year.

Are blank filters reweighed? x

Lab Blank filters are tared at the same time filters are tared and reweighed when the same group of exposed filters are returned to the lab for exposed weights.

Are chemical analyses performed on filters? @ IML

If yes, what analysis is performed?


Lead According to FAL



Is analysis for lead being conducted using atomic absorption spectrometry with air acetylene flame? x ICP-MS @ FAL

If not, has the agency received an equivalency designation for their procedure? AppG Part 50 now deems this

this method 6020A as acceptable

Is either the hot acid or ultrasonic extraction procedure being followed precisely? X Which? Hot acid

Is Class A borosilicate glassware used throughout the analysis?

?Every volume handling device in our analysis is Class A, such as a graduated cylinder, or calibrated on a quarterly basis, such as a pipette. Also, the containers used to dilute your samples to a 100mL final volume are class A.

Is all glassware cleaned with detergent, soaked and rinsed three times with distilled or deionized water?

glassware soaks in phosphate free detergent at least overnight, then is rinsed with tap water, followed by rinsing with DI water. The glassware then is washed with 5% HNO3 and rinses with DI water, which is then repeated two more times.

If extracted samples are stored, are linear polyethylene bottles used? x

Are all batches of glass fiber filters tested for background lead content? x

At a rate of 20 to 30 random filters per batch of 500 or greater? Indicate Rate -

Are ACS reagent grand HNO3 and HCl used in the analysis? All of our acids used are

trace metal grade

Is a calibration curve available having concentrations that cover the linear absorption range of the atomic absorption instrumentation?

ICP-MS


Is the stability of the calibration curve checked by alternately re-measuring every 10th sample a concentration # 1Φg Pb/ml; # 10 Φg Pb/ml?

ICP-MS

END OF REPORT