Air Monitoring Quality Assurance Plan Air Quality Program

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1 Air Monitoring Quality Assurance Plan Air Quality Program (Rev. 4/2010)

2 If you need this publication in another format, please contact the Air Quality Program at (360) If you have a hearing loss, call 711 for Washington Relay Service. If you have a speech disability, call

3 0 Introduction The purpose of the Air Monitoring Quality Assurance Plan is to describe the Washington State Department of Ecology s Air Quality Program (Air Quality Program) quality system. The plan illustrates the organizational structure, functional responsibilities of management and staff, line of authority, and required interfaces for those planning, implementing, and assessing activities involving environmental data collected by the Air Quality Program. The Plan is written using guidance from EPA Requirements for Quality Assurance Project Plans for Environmental Data Operations (EPA QA/R5) and Quality Assurance Handbook for Air Pollution Measurement Systems, Volume II, Ambient Air Quality Monitoring Program (QA Handbook). One monitoring goal, as described in the 1990 Amendments to the Clean Air Act, is the: Establishment of a national network to monitor, collect, and compile data with quantification of uncertainty in the status and trends of air emissions, deposition, air quality, surface water quality, forest condition, and visibility impairment and to ensure the comparability of air quality data collected in different states and obtained from different nations. The Ambient Air Quality Monitoring Network is developed to collect vital air data. It is very important to people and organizations concerned with human health and the welfare of our communities and ecosystems or who use ambient data for planning, policy or research applications that the ambient air data collected from monitoring organizations are of known, acceptable and comparable quality. Many scientists, modelers and decision makers feel that data are unusable if it is of unknown quality. The QA regulations, set forth in 40 CFR Part 58 Appendix A have been developed to ensure that monitoring programs are well planned so that it is known what data quality is needed, that checks are included to assess data quality, and corrective actions are in place to improve quality systems when needed. The Air Quality Program quality system is designed to follow many of the quality assurance guidelines outlined in the QA Handbook in an effort to collect data that is comparable with other organizations while providing decision makers data of acceptable quality. 3

4 State of Washington Department of Ecology Air Quality Program Air Monitoring Quality Assurance Plan Prepared by: Donovan Rafferty The attached Quality Assurance Plan for the State of Washington Air Quality Program is recommended for approval and commits the State of Washington, Department of Ecology to follow the elements described within. 4

5 Table of Contents 0 INTRODUCTION PROJECT /TASK ORGANIZATION ECOLOGY QUALITY ASSURANCE OFFICER AIR QUALITY PROGRAM ORGANIZATION MONITORING ACTION COMMITTEE (MAC) AIR QUALITY LEADERSHIP TEAM (AQLT) AIR QUALITY PROGRAM QUALITY ASSURANCE COORDINATOR ORGANIZATIONAL RESPONSIBILITIES INTERACTION BETWEEN FEDERAL, STATE, TRIBAL AND LOCAL AGENCIES EPA NATIONAL EXPOSURE RESEARCH LABORATORY (NERL) OFFICE OF AIR QUALITY PLANNING AND STANDARDS (OAQPS) EPA REGION WASHINGTON STATE DEPARTMENT OF ECOLOGY ECOLOGY REGIONAL OFFICES WASHINGTON STATE CLEAN AIR AGENCIES TRIBAL LAND AND RESERVATIONS PRIMARY QUALITY ASSURANCE ORGANIZATION (PQAO) PROBLEM DEFINITION AND BACKGROUND QUALITY SYSTEM REQUIREMENTS FOR EPA FUNDED PROGRAMS QUALITY ASSURANCE PROJECT PLANS THE GRADED APPROACH FLEXIBILITY IN THE SYSTEMATIC PLANNING PROCESS AND DQO DEVELOPMENT PROJECT/TASK DESCRIPTION MONITORING GOALS OF THE AIR QUALITY PROGRAM NATIONAL AMBIENT AIR QUALITY NETWORK STATE AND LOCAL AIR MONITORING STATIONS (SLAMS) SPECIAL PURPOSE MONITORING STATIONS (SPMS) PM 2.5 CHEMICAL SPECIATION TRENDS NETWORK (STN) NATIONAL AIR TOXICS TREND STATIONS (NATTS)

6 4.7 NATIONAL CORE MONITORING NETWORK (NCORE) INTERAGENCY MONITORING OF PROTECTED VISUAL ENVIRONMENTS (IMPROVE) QUALITY OBJECTIVES AND CRITERIA FOR MEASURING DATA DATA QUALITY AND MEASUREMENT OBJECTIVES ECOLOGY AIR PROGRAM GOALS MONITORING PROJECT PROPOSAL AIR QUALITY PROGRAM OBJECTIVES PERSONAL QUALIFICATION AND TRAINING QUALIFICATIONS TRAINING CONFERENCES AND PROFESSIONAL ORGANIZATIONS VENDOR TRAINING DOCUMENTATION AND RECORDS ELECTRONIC RECORDS RECORD RETENTION SITE INFORMATION ENVIRONMENTAL DATA OPERATIONS QUALITY ASSURANCE PROJECT PLAN STANDARD OPERATING PROCEDURES MONITORING NETWORK DESIGN AIR QUALITY PUBLIC REPORTING NATIONAL AIR QUALITY INDEX (AQI) WASHINGTON AIR QUALITY ADVISORY (WAQA) FOR PM MONITORING FOR COMPLIANCE MONITORING BOUNDARIES MONITORING SITE LOCATION MONITOR PLACEMENT MINIMUM NETWORK REQUIREMENTS DESIGN VALUES FINE PARTICULATE MATTER PM 2.5 DESIGN CRITERIA NETWORK ASSESSMENTS LOCATIONS OF REFERENCE/EQUIVALENT METHOD INSTRUMENTS

7 8.13 LOCATION OF PARTICULATE MATTER (PM 2.5 ) FRM SAMPLERS OZONE ANALYZERS IN WASHINGTON STATE OZONE (O 3 ) DESIGN CRITERIA SLAMS MINIMUM O 3 MONITORING REQUIREMENTS CARBON MONOXIDE PRECURSOR GAS MONITORING METEOROLOGICAL MEASUREMENTS OPERATING SCHEDULES OPERATING SCHEDULE COMPLETENESS SAMPLING METHODS MONITORING PLACEMENT SAMPLING PROBES AND MANIFOLDS RESIDENCE TIME DETERMINATION PLACEMENT OF PROBES AND MANIFOLDS ANALYTICAL METHODS FEDERAL REFERENCE METHOD (FRM) FOR PM CONTINUOUS MONITORS FOR GASEOUS POLLUTANTS OZONE (O 3 ) MEASUREMENTS SULFUR DIOXIDE (SO 2 ) MEASUREMENTS CARBON MONOXIDE (CO) MEASUREMENTS REACTIVE NITROGEN COMPOUNDS (NO Y ) MEASUREMENTS TAPERED ELEMENT OSCILLATING MICROBALANCE (TEOM ) OPTICAL ABSORPTION (AETHALOMETER) LIGHT SCATTERING OF FINE PARTICULATES (NEPHELOMETER) SAMPLE HANDLING AND CUSTODY COURIERS LABORATORY METHODS LABORATORY ACTIVITIES QUALITY CONTROL DATA QUALITY ASSESSMENTS CFR RELATED QUALITY CONTROL SAMPLES SAMPLE HANDLING AND QUALITY CONTROL

8 13.4 SLAMS CFR RELATED QUALITY CONTROL SAMPLES USE OF COMPUTERS FOR QUALITY CONTROL PROCUREMENT OF EQUIPMENT MAINTENANCE OF EQUIPMENT STATION MAINTENANCE MAINTENANCE OF CALIBRATION/AUDIT STANDARDS AND EQUIPMENT INSTRUMENT/EQUIPMENT CALIBRATION AND FREQUENCY INSTRUMENTATION CALIBRATION VERIFICATIONS DATA REDUCTION USING CALIBRATION INFORMATION CALIBRATION STANDARDS CALIBRATION STANDARDS FOR OZONE FLOW STANDARDS MULTI-POINT CALIBRATION VERIFICATIONS DOCUMENTATION PHYSICAL ZERO AND SPAN ADJUSTMENTS FREQUENCY OF CALIBRATION AND ANALYZER ADJUSTMENT VALIDATION OF AMBIENT DATA BASED ON CALIBRATION INFORMATION INSPECTION/ACCEPTANCE OF SUPPLIES AND CONSUMABLES PARTICULATE SAMPLING FILTERS NON-DIRECT MEASUREMENTS CHEMICAL AND PHYSICAL PROPERTIES DATA GEOGRAPHIC LOCATION HISTORICAL MONITORING INFORMATION METEOROLOGICAL DATA FROM OTHER SOURCES DATA ACQUISITION AND INFORMATION MANAGEMENT ENVITECH LTD. ENVIRONMENTAL DATA MANAGEMENT SYSTEMS ASSESSMENTS AND RESPONSE ACTIONS AIR QUALITY PROGRAM MULTIPOINT AUDITS CORRECTIVE ACTION PERCENT VALID DATA INDEPENDENCE AND EPA PERFORMANCE EVALUATIONS INDEPENDENT ASSESSMENT

9 19.6 ADEQUACY REQUIREMENTS FOR THE PEP PROGRAM ADEQUACY REQUIREMENTS FOR THE NPAP PROGRAM TECHNICAL SYSTEMS AUDITS DATA QUALITY ASSESSMENTS REPORTS TO MANAGEMENT AQS DATA SUMMARY REPORT SINGLE POINT PRECISION AND BIAS GRAPHICS AIR QUALITY SYSTEM AMP255 SUMMARY REPORT DATA REVIEW, VERIFICATION, AND VALIDATION DATA REVIEW METHODS DATA VERIFICATION METHODS DATA VALIDATION METHODS AUTOMATED METHODS MANUAL METHODS VALIDATION TEMPLATES VERIFICATION AND VALIDATION METHODS SAMPLING DESIGN DATA COLLECTION PROCEDURES QUALITY IMPROVEMENT ANNUAL QUALITY SYSTEM REPORT

10 Tables Table 0-1 Ecology Air Program QAPP distribution list...15 Table 2-1 Counties under Air Quality Program authority...24 Table 2-2 Indian tribes located within the borders of Washington State...26 Table 3-1 List of criteria pollutants and standards...30 Table 3-2 QAPP/QMP project categories...34 Table 6-1 Suggested training courses for air monitoring personnel...47 Table 6-2 Suggest organizations and conferences for continued learning...49 Table 7-1 Air Program record storage locations...50 Table 7-2 List of Ecology Air Quality field monitoring procedures...54 Table 8-1 Large Metropolitan Statistical Areas in Washington State...57 Table 8-2 PM2.5 minimum number of sites required...60 Table 8-3 Federal Reference Samplers operated in Washington State...63 Table 8-4 Minimum number of ozone sites requirement...69 Table 8-5 Ozone design values for counties in Washington State...70 Table 8-6 Carbon monoxide sites supported by the Air Quality Program...77 Table 8-7 Accuracy criteria for towers in the PSD program...78 Table 13-1 Ambient air monitoring measurement quality samples...92 Table 13-2 CFR related quality control checks...96 Table 14-1 Standards maintained in the Air Quality Program laboratory

11 Figures Figure 2-1 Air Quality Program organizational structure...19 Figure 2-2 Air Quality Program positions and responsibilities...20 Figure 2-3 Organizational oversight and input to decisions...22 Figure 2-4 Local clean air agencies of Washington...25 Figure 2-5 Primary quality assurance hierarchy...28 Figure 2-6 Sharing technical knowledge with colleagues from other agencies...28 Figure 4-1 Graph illustrating improved air quality...34 Figure 4-2 Location of the National Air Toxic Trend Stations...39 Figure 4-3 Technician documenting site visit...39 Figure 5-1 The Data Quality Process...43 Figure 5-2 Elements of MAC project proposal...45 Figure 6-1 Training at Ecology...47 Figure 8-1 Example of an AIRNow AQI forecast...55 Figure 8-2 Example of near-real time color coded PM 2.5 WAGA...56 Figure 8-3 Station categories and how they are characterized...59 Figure 8-4 Declining numbers of FRM samplers...62 Figure 8-5 PM 2.5 FRM samplers in Washington State (red triangles)...63 Figure 8-6 Location of ozone monitoring sites...71 Figure 8-7 Example of the operating schedule for PM10, PM2.5, and VOC's...79 Figure 8-8 Completeness goals for data completeness...80 Figure 9-1 Types of monitoring structures in the Air Monitoring Network...81 Figure 9-2 DAS chart with room temperature...82 Figure 9-3 Station report in the DAS...82 Figure 9-4 Example of an ozone station configuration...83 Figure 10-1 A Radiance nephelometer...88 Figure 12-1 Summary of pollutants accepted analytical methods...90 Figure 13-1 PM2.5 filter weighing, collection and documentation...93 Figure 13-2 Example of PM 2.5 sample data sheet...93 Figure 13-3 Example of PM2.5 quality control check form

12 Figure 15-1 Electronic chart of daily zero and precision quality control check Figure 15-2 Frequency of data quality checks Figure 15-3 Ozone Hierarchy Figure 15-4 Example of electronic chart and calibration trace Figure 15-5 Example of electronic log book entry Figure 15-6 Example of an electronic log book entry Figure 15-7 Example of an Electronic Log Book Entry Figure 19-1 Washington Air Monitoring electronic data flow chart Figure 19-2 Ecology performance evaluation limits Figure 19-3 Accuracy Audit Concentration Levels Figure 19-4 Example of electronic chart and instrument response to audit levels Figure 19-5 Continuous Method Audit Report Figure 19-6 NPAP Audit Trailer in Seattle Figure 19-8 NPEP auditor at Beacon Hill site Figure 19-7 Minimum EPA requirements for quality assurance independence Figure 19-9 Performance evaluations in which the Air Quality Program participates Figure 21-1 Example of AMP255 summary report Figure 22-1 Example of a tabular electronic station report

13 Acronyms and Abbreviations AAMG AMTIC APTI AQI AQLT AQS ANSI ARM AT AWMA CAA CFR CO CRM DAS DDR DOP DQOs EAP Ecology EDO EPA FARR FEM FEP FRM HAP HQ IOS IR IUPAC MPROVE µg/m 3 MAC MQO MSA NAAQS NACCA Ambient Air Monitoring Group Ambient Monitoring Technology Information Center Air Pollution Training Institute Air Quality Index Air Quality Leadership Team Air Quality System American National Standards Institute approved regional method air toxics Air and Waste Management Association Clean Air Act Code of Federal Regulation carbon dioxide certified reference material data acquisition system Data Disposition Request dioctyl phthalate data quality objectives Environmental Assessment Program State of Washington Department of Ecology State of Washington Environmental data operation Environmental Protection Agency Federal Air Rules for Indian Reservations federal equivalent method fluorinated ethylene propylene federal reference method hazardous air pollutants Ecology Headquarters International Organization for Standardization infrared International Union of Pure and Applied Chemistry Interagency Monitoring of Protected Visual Environments Micrograms per cubic meter Monitoring Action Committee monitoring quality objective metropolitan statistical area National Ambient Air Quality Standards National Association of Clean Air Agencies 13

14 NATTS NCore NERL NIST NO 2 NPAP NPEP O 3 OAQPS QAU PE PEP PM ppb ppm PQAO PSD QA QAM QAPP QMP SLAMS SOP SPMS SRM SRP STN SO 2 TEOM UATS UTM UV VOC s WAQA WGS WRAP National Air Toxic Trends Sites National Core Network EPA National Exposure Research Laboratory National Institute of Standards and Technology nitrogen dioxide National Performance Audit Program National Performance Evaluation Program Ozone Office of Air Quality Planning and Standards quality assurance unit performance evaluation Performance Evaluation Program particulate matter parts per billion parts per million primary quality assurance organization prevention of significant deterioration quality assurance quality assurance manager quality assurance project plan quality management plan state and local air monitoring stations standard operating procedures special purpose monitoring stations standard reference material standard reference photometer PM 2.5 Speciation Trends Network sulfur dioxide tapered element oscillating microbalance Urban Air Trend Site Universal Transverse Mercator ultraviolet volatile organic compounds Washington Air Quality Advisory World Geodetic System Western Regional Air Partnership 14

15 A hard copy of Quality Assurance Project Plan for the State of Washington can be obtained from Ecology s Air Quality Program by contacting Stan Rauh stan.rauh@ecy.wa.gov at (425) It has been distributed to the individuals listed in Table 0.1. Name Position Contact Information Washington Department of Ecology Stu Clark Vacant Andrew Green Jeff Johnson Phyllis Baas Karen Woods Susan Billings William Kammin Program Manager Headquarters Lacey Section Manager Northwest Regional Office Bellevue Section Manager Headquarters Lacey Section Manager Headquarters Lacey Section Manager Headquarters Lacey Section Manager Eastern Regional Office Spokane Section Manager Central Regional Office Yakima Ecology Quality Assurance Officer Headquarters (360) scla461@ecy.wa.gov (360) angr461@ecy.wa.gov (360) jefj461@ecy.wa.gov (360) pbaa461@ecy.wa.gov (509) kwoo461@ecy.wa.gov (509) sbil461@ecy.wa.gov (360) wkam461@ecy.wa.gov U.S. Environmental Protection Agency Region 10 Chris Hall Quality Assurance Administrator (206) Hall.Christopher@epamail.epa.gov Keith Rose Air Monitoring Administrator (206) Rose.Keith@epamail.epa.gov Table 0-1 Ecology Air Program QAPP distribution list 15

16 1 Project /Task Organization This document presents the Quality Assurance Project Plan (QAPP) for the Ambient Air Monitoring and Quality Assurance Program that is implemented by the State of Washington Department of Ecology (Ecology). The Department of Ecology relies on its Environmental Assessment Program (EAP) to monitor quality assurance practices within the Agency and improve its scientific practices, especially those involving generation and assessment of environmental data. Ecology's QA system is based on requirements established by the U.S. Environmental Protection Agency and incorporates guidance and methodology from many standards-setting organizations world-wide. Ecology s Executive Polity 1-21 established an Agency Plan to implement, document and assess the effectiveness of the Quality System supporting environmental data operations. Ecology uses established QA principles to plan execute and assess all of its data-generation projects. 1.1 Ecology Quality Assurance Officer Ecology s Quality Assurance (QA) Officer updates the Environmental Assessment Program (EAP) Manager of QA accomplishments and issues throughout the Agency. The QA Officer brings issues related to QA directly to Program Managers or with designated Quality Assurance Coordinators within a program. 1.2 Air Quality Program Organization The Director of Ecology administers ten environmental programs, grouped into five categories. The Deputy Director (Deputy) assists in the direction of the programs and is responsible for the oversight of Program Managers. The Environmental Assessment Manager ensures that a satisfactory monitoring and quality assurance program is implemented for the field, laboratory, and data processing phases of each monitoring program with assistance from the Quality Assurance Officer. The Air Quality Program Manager is located at Ecology Headquarters (HQ) in Lacey, Washington with Section Managers located at HQ in Lacey and in satellite offices in Bellevue, Spokane and Yakima. Section Managers oversee units of staff members who have specific expertise in their fields and are assigned specific duties. 16

17 The Technical Support Services Manager, with advisement from the Monitoring Action Committee and the Air Quality Leadership Team, directs the Operations/ Quality Assurance Coordinator to take action on decisions dealing with the collection of air data and quality assurance. 1.3 Monitoring Action Committee (MAC) Monitoring policy questions are discussed in the Monitoring Action Committee (MAC). The MAC meets monthly to discuss current and future projects. The MAC follows a review process to assess what monitoring efforts are necessary to support national requirements and state program objectives. Members of the MAC assess where monitoring will be conducted, discuss monitoring issues and set data quality objectives and review collected data to determine if it meets the intended use. 1.4 Air Quality Leadership Team (AQLT) Monitoring decisions that cannot be resolved at the MAC level or which may have financial, political or staff concerns will be brought before the Air Quality Leadership Team. Team members include the: Program Manger Eastern Region Office Manager Policy Analyst Public Information Officer Program Development Section Manager Science/Engineering Section Manager Northwest Region Office Manager Budget Manager Technical Support Services Manager Central Region Office Manager The Program Manager has the final approval authority for any proposal. 1.5 Air Quality Program Quality Assurance Coordinator The Quality Assurance Coordinator is the person within the Air Quality Program who functions as the representative for quality assurance activities. The Quality Assurance Manager is defined as the person responsible for quality management - that aspect of the overall management system of the organization that determines and implements the quality policy. Quality management includes strategic planning, allocation of resources and other systematic planning 17

18 activities (e.g., planning, implementation, assessment and reporting) pertaining to the quality system. 2 Organizational Responsibilities The organizational structure of Ecology s Air Quality Program is made up of units within sections located in different regions of the State. Decisions on the collecting of air quality data and the implementation of those decisions are assigned to specific individuals within the Air Quality Program. 2.1 Interaction between federal, state, tribal and local agencies The collection of air monitoring data in Washington State requires interaction between Federal, State, Local agencies and Tribes. Good communication between organizations is critical to the clear understanding of the monitoring objectives and responsibilities. The monitoring objectives of the National Air Monitoring Program can differ greatly from individual states, tribes and local agencies. The EPA Office of Air Quality Planning and Standards provides national oversight with limited resources and invites agencies to participate in policy making activities. Ecology s Air Quality Program encourages staff to participate in OAQPS sponsored committees, workgroups and conferences to gain a greater understanding of how decisions are made. The Ambient Monitoring Technology Information Center AMTIC is operated by EPA's Ambient Air Monitoring Group (AAMG). AMTIC contains information and files on ambient air quality monitoring programs, details on monitoring methods, relevant documents and articles, information on air quality trends and nonattainment areas, and federal regulations related to ambient air quality monitoring. 18

19 I Air Quality Leadership Team Department of Ecology Director Deputy Director Chain of Command Lines of Communication Monitoring Action Committee Air Quality Program Manager Policy Analyst Budget Manager Public Information Officer Environmental Assessment Program Manager Technical Support Services Section Manager Olympia Program Development Section Manager Olympia Science Engineering Section Manager Northwest Regional Office Section Bellevue Eastern Regional Office Section Spokane Central Regional Office Section Yakima Manchester Laboratory Manager Quality Assurance Officer Information Technology Section Air Monitoring Coordinator Air Monitoring Station Operators Air Monitoring Station Operators Laboratory Scientist Air Quality System (AQS) Coordinator Local Clean Air Agencies Operations - Quality Assurance Coordinator Air Monitoring Station Operator Southwest Regional Office Figure 2-1 Air Quality Program organizational structure 19

20 Position Headquarter Managers/Specialists Air Quality Program Manager Environmental Assessment Program Manager Technical Support Services Section Supervisor Program Development Section Supervisor Information Management Supervisor Air Monitoring Coordinator Science/Engineering Section Supervisor Data Entry Specialist (Lacey) Quality Assurance/Repair and Calibration Coordinator Regional Managers Northwest (Bellevue) Regional Manager Central (Yakima) Regional Manager Eastern (Spokane) Regional Manager Air Monitoring Site Operators Northwest Regional Office Southwest Regional Office Eastern Regional Office Central Regional Office Responsibility Assures Ecology Air Quality Program policies are in place and effective so that state and federal clean air objectives are achieved. Responsible for overall program leadership. Guides AQLT decisions Assures Ecology Environmental Assessment policies are maintained statewide, including Manchester Environmental Lab Reviews individual program quality assurance plans Supervises IT Telemetry, Public Outreach and Implementation, SWRO and Air quality Operations Unit supervisors. AQLT and MAC member Supervises Program Development of plans, policies and rules that ensure air quality meets health and environmental objectives (Diesel reduction strategies, toxic inventory, SIP programs, etc). Supervises Air Monitoring Coordinator MAC and AQLT member Supervise data entry specialist Telemetry equipment evaluation, procurement and acceptance testing Telemetry calibration and quality control Telemetry system operation and maintenance Air monitoring data analysis Air monitoring data reports Leads Monitoring Action Team Air monitoring evaluation, design, budget and reports Air monitoring equipment amortization and procurement approval Station installation and operation coordination and status assessment Site, shelter and utility contracts Supervises meteorologists, toxicologists and engineers. MAC and AQLT member Coordinates data from PQAO members Inputs environmental data to the AIRS database Responsible for quality assurance activities Responsible for instrument repair and calibration Regional managers report directly to the program manager. Responsibilities include overseeing air monitoring projects and staff. Coordinate monitoring efforts in Northwest Washington Supervise air monitoring station operators Coordinate monitoring efforts in Central Washington Supervise air monitoring station operators Coordinate monitoring efforts in Eastern Washington Supervise air monitoring station operators Personnel from federal, state, county and tribal organizations operate air monitoring stations. Station site selection Station installation Station maintenance and repair Sample collection Quality control checks Figure 2-2 Air Quality Program positions and responsibilities 20

21 2.2 EPA National Exposure Research Laboratory (NERL) NERL conducts research and development that leads to improved methods, measurements and models to assess and predict exposures of humans and ecosystems to harmful pollutants and other conditions in air, water, soil, and food. The NERL provides the following activities relative to the Ambient Air Quality Monitoring networks: develops, improves, and validates methods and instruments for measuring gaseous, semi-volatile, and non-volatile pollutants in source emissions and in ambient air, supports multi-media approaches to assessing human exposure to toxic contaminated media analytical and method support for special monitoring projects for trace elements and other inorganic and organic constituents and pollutants, develops standards and systems needed for assuring and controlling data quality, assesses whether candidate sampling methods conform to accepted reference method specifications and are capable of providing data of acceptable quality and completeness for determining compliance with applicable National Ambient Air Quality Standards, assesses whether emerging methods for monitoring criteria pollutants are equivalent to accepted Federal Reference Methods and are capable of addressing the Agency s research and regulatory objectives, and provides an independent audit and review function on data collected by NERL or other appropriate clients. 2.3 Office of Air Quality Planning and Standards (OAQPS) EPA s responsibility, under the Clean Air Act (CAA) as amended in 1990, includes: setting National Ambient Air Quality Standards (NAAQS) for pollutants considered harmful to the public health and environment; ensuring that these air quality standards are met or attained through national standards and strategies to control air emissions from sources; and ensuring that sources of toxic air pollutants are well controlled. OAQPS is the organization charged under the authority of the CAA to protect and enhance the quality of the nation s air resources. OAQPS evaluates the need to regulate potential air pollutants and develops national standards; works with state, tribes and local agencies to develop plans for meeting these standards; monitors national air quality trends and maintains a database of information on air pollution and controls; provides technical guidance and training on air pollution control strategies; and monitors compliance with air pollution standards. 21

22 QA Handbook Committee EPA work groups AMTIC QA Conference NACAA Conference Calls National Conference Lines of communication Direction of funding/authority Figure 2-3 Organizational oversight and input to decisions Within the OAQPS Air Quality Assessment Division, the Ambient Air Monitoring Group (AAMG) is responsible for the oversight of the Ambient Air Quality Monitoring Network and its quality assurance program. AAMG, relative to quality assurance, has the responsibility to: develop a satisfactory quality system for the Ambient Air Quality Monitoring Network, ensure that the methods and procedures used in making air pollution measurements are adequate to meet the programs objectives and that the resulting data are of appropriate quality, manage the National Performance Evaluation Program (NPEP), perform data quality assessments of organizations making air pollution measurements of importance to the regulatory process, 22

23 ensure that guidance pertaining to the quality assurance aspects of the Ambient Air Quality Program are written and revised as necessary, and render technical assistance to the EPA Regional Offices and the air pollution monitoring community. 2.4 EPA Region 10 Staff at EPA Regional 10 plays a critical role in addressing environmental issues related to air monitoring in Washington State by overseeing regulatory and congressionally mandated programs. The major quality assurance responsibilities of EPA s Regional 10 Office in regards to the National Ambient Air Quality Program are the coordination of quality assurance matters between the Region 10 office and the Air Quality Program. This role requires that an assigned representative from the Regional Office: distribute and explain technical and quality assurance information to the Air Quality Program Quality Assurance Coordinator, identify quality assurance needs of the Air Quality Program to the Office of Air Quality Planning and Standards that are national in scope, provide the infrastructure to implement NPEP programs, be knowledgeable of QA regulations and with adequate technical expertise to address ambient air monitoring and QA issues, ensure the Air Quality Program have an approved quality management plans (QMPs) and quality assurance project plans (QAPPs) prior to routine monitoring, evaluate the capabilities of the Air Quality Program to measure the criteria air pollutants by implementing network reviews and technical systems audits, assess the data quality of the Air Quality Program, and assist SLT agencies in defining primary quality assurance organizations within their jurisdiction and in assigning sites to a primary quality assurance organization. 2.5 Washington State Department of Ecology The Department of Ecology (Ecology) is Washington's principal environmental management agency and was created in 1970 under Chapter 43.21A RCW and is located in Lacey, Washington. 23

24 RCW 43.21A.010: Legislative declaration of state policy on environment and utilization of natural resources. The legislature recognizes and declares it to be the policy of this state, that it is a fundamental and inalienable right of the people of the state of Washington to live in a healthful and pleasant environment and to benefit from the proper development and use of its natural resources. The legislature further recognizes that as the population of our state grows, the need to provide for our increasing industrial, agricultural, residential, social, recreational, economic and other needs will place an increasing responsibility on all segments of our society to plan, coordinate, restore and regulate the utilization of our natural resources in a manner that will protect and conserve our clean air, our pure and abundant waters, and the natural beauty of the state. The mission of the Agency is to protect, preserve and enhance Washington s environment, and promote the wise management of our air, land and water for the benefit of current and future generations. The fundamental focus is to protect both humans and the environment from pollution; restore and preserve important ecosystems that sustain life; and, find ways to meet human needs without damaging environmental resources and functions. 2.6 Ecology Regional Offices Ecology Regional Offices are located in western, central and eastern regions of the State. Air Quality Program staff provide information and address localized air quality issues in counties that do not support local clean air agencies. Ecology Regional Office Northwest Central Eastern Table 2-1 Counties under Air Quality Program authority 2.7 Washington State Clean Air Agencies County San Juan, Island Okanogan, Chelan, Douglas, Kittitas, Klickitat Ferry, Stevens, Pend Oreille, Lincoln, Grant, Whitman, Adams, Franklin, Garfield, Columbia, Walla Walla, Asotin Air quality in Washington State is protected primarily by seven local clean air agencies. The agencies are sponsored by one or more counties, funded by fees levied on air pollution sources within their jurisdictions and supplemented with federal and state grants. The agencies work together with the Air Quality Program to achieve specific goals of EPA and Ecology and often conduct additional air monitoring in their regions for additional information. These agencies include: 24

25 Benton Clean Air Agency - Benton County Northwest Clean Air Agency - Whatcom, Island, & Skagit counties Olympic Region Clean Air Agency - Thurston, Mason, Pacific, Grays Harbor, Jefferson, and Clallam counties Puget Sound Clean Air Agency - King, Snohomish, Pierce, & Kitsap counties Southwest Clean Air Agency - Lewis, Skamania, Clark, Cowlitz, & Wahkiakum counties Spokane Regional Clean Air Agency - Spokane County Yakima Regional Clean Agency - Yakima Figure 2-4 Local clean air agencies of Washington 25

26 2.8 Tribal Land and Reservations The Federal Air Rules for Indian Reservations (FARR) applies within the exterior boundaries of 39 Indian Reservations in Idaho, Oregon and Washington. Tribes have the authority involving air quality issues on their tribal lands and several tribes conduct air monitoring programs within these boundaries. Ecology contracts (or has contracted) directly with tribes or through EPA Region 10 to install, operate, audit and report data to the Air Quality System (AQS). These sites receive the same level of quality assurance and support as other sites operated by the Air Quality Program. Tribe 26 Air Monitoring conducted on Reservation (past or presently) Follows Ecology Procedures The Confederated Tribes and Bands of the Yakama Nation Yes Hoh Indian Tribe of the Hoh Indian Reservation No The Confederated Tribes of the Chehalis Reservation Yes The Confederated Tribes of the Colville Reservation Yes The Jamestown S Klallam Tribe of Washington No The Kalispel Indian Community of the Kalispel Reservation Yes Lower Elwha Tribal Community of the Lower Elwha Reservation No Lummi Tribe of the Lummi Reservation No Makah Indian Tribe of the Makah Indian Reservation Yes Muckleshoot Indian Tribe of the Muckleshoot No Reservation Nisqually Indian Tribe of the Nisqually Reservation Yes Nooksack Indian Tribe of Washington No Port Gamble Indian Community of the Port Gamble Reservation No Puyallup Tribe of the Puyallup Reservation Yes Sauk-Suiattle Indian Tribe of Washington No Quileute Tribe of the Quileute Reservation No Quinault Tribe of the Quinault Reservation Yes Shoalwater Bay Tribe of the Shoalwater Bay Indian Reservation No Skokomish Indian Tribe of the Skokmish Reservation Yes Spokane Tribeof the Spokane Reservation Yes Squaxin Island Tribe of the Squaxin Island No Reservation Stillaguamish Tribe of Washington No Suquamish Indian Tribe of the Port Madison Yes Reservation Swinomish Indians of the Swinomish Reservation Yes Tulalip Tribes of the Tulalip Reservation No Upper Skagit Indian Tribe of Washington No Yakama Tribe of the Yakama Reservation Yes Table 2-2 Indian tribes located within the borders of Washington State

27 2.9 Primary Quality Assurance Organization (PQAO) A PQAO is a monitoring organization or a group of monitoring organizations that share a number of common QA Factors. The Air Quality Program is recognized by EPA Region 10 as a PQAO. As a PQAO, the Air Quality Program goal is to create a reasonably homogeneous network to reduce measurement uncertainty among all stations in the network. This is achieved by: operation by a common team of field operators according to a common set of procedures, follow a common QAPP, common calibration facilities and standards, common makes and models of instruments, oversight by a common quality assurance organization, and support by a common management, laboratory or headquarters. Several air monitoring station operators who collect data for the Air Quality Program are employed by county, state and tribal agencies. All operators collecting data for the Air Quality Program (to be submitted to EPA AQS) must follow standard operating procedures (Section 7.6). For each pollutant, the number of monitoring sites in a PQAO is used to determine the number and frequency of quality control checks, including the number of collocated monitors and the NPAP/PEP audit frequencies. PQAO(s) are also used to aggregate data for assessments of completeness, precision and bias. EPA bases many of its data quality assessments at the PQAO level. QAPP(s) of the monitoring organizations must refer to the PQAO that the monitoring organization is affiliated with and EPA Region 10 must have documentation on file to this effect. Agencies or tribes (e.g. United States Forest Service) contracting with the Air Quality Program must have an EPA approved QAPP for the project if data is to be submitted to AQS. If no QAPP is provided, the agency must follow Air Quality Program procedures. All site/data receives the same level of quality assurance and support as other sites operated by the Air Quality Program. 27

28 Figure 2-5 Primary quality assurance hierarchy As a PQAO, the Air Quality Program has a responsibility to provide assistance to organizations while seeking their advice and counsel. The expertise gained from this collaboration and respect provides insight of regional and national monitoring objectives. Examples include round-robin filter checks, independent courtesy audits, lending of equipment and technical assistance. Makah Nation Oregon DEQ University of Washington Alaska DEC Figure Oregon 2-6 Sharing DEQ technical knowledge with colleagues from other agencies NPS 28

29 3 Problem Definition and Background The Clean Air Act Extension of 1970 (CAA) is federal law that requires the EPA develop and enforce regulations to protect the general public from exposure to airborne contaminants that are known to be hazardous to human health. The CAA, which was last amended in 1990, requires EPA to set National Ambient Air Quality Standards (40 CFR part 50) for pollutants considered harmful to public health and the environment. The CCA established two types of national air quality standards: Primary standards which set limits to protect public health, including the health of sensitive populations such as asthmatics, children, and the elderly. Secondary standards set limits to protect public welfare, including protection against decreased visibility, damage to animals and crops, vegetation, and buildings. The EPA Office of Air Quality Planning and Standards (OAQPS) has set National Ambient Air Quality Standards (NAAQS) for six principal pollutants, which are called criteria pollutants (listed below). Units of measure for the standards are parts per million (ppm) by volume, milligrams per cubic meter of air (mg/m 3 ), and micrograms per cubic meter of air (µg/m 3 ). EPA is charged with enforcing the CAA but allows individual states to take responsibility for compliance with and regulation of the CAA within their own borders in exchange for funding. In order to take over compliance with the CAA the states must write and submit a State Implementation Plan (SIP) to the EPA for approval. The SIP must meet the minimum criteria established by the EPA. The SIP becomes the state's legal guide for local enforcement of the CAA. Areas that have experienced persistent air quality problems are designated by EPA as nonattainment areas. The CAA requires additional air pollution controls in these areas. Each nonattainment area is declared for a specific pollutant; however, nonattainment areas for different pollutants may overlap each other or share common boundaries. In the past EPA designated 13 areas in Washington State as nonattainment based on air monitoring data. Only after air monitoring demonstrated these areas met health-based air quality standards did EPA re-designates the areas as attainment contingent on a maintenance plan. 29

30 National Ambient Air Quality Standards Carbon Monoxide Primary Standards Secondary Standards Pollutant Level Averaging Time Level Averaging Time 9 ppm (10 mg/m 3 ) 8-hour (1) 35 ppm 1-hour (1) (40 mg/m 3 ) Lead 0.15 µg/m 3 Rolling 3-Month Average Same as Primary Nitrogen Dioxide Particulate Matter (PM 10) Particulate Matter (PM 2.5) ppm (100 µg/m 3 ).100 ppm Annual (Arithmetic Mean) 1-hour None Same as Primary 150 µg/m 3 24-hour (2) Same as Primary 15.0 µg/m 3 Annual (3) (Arithmetic Mean) Same as Primary 35 µg/m 3 24-hour (4) Same as Primary Ozone ppm ( hour (5) Same as Primary std) Sulfur Dioxide 0.08 ppm ( hour (6) std) 0.12 ppm 1-hour (7) (Applies only in limited areas) 0.03 ppm Annual (Arithmetic Mean) 0.14 ppm 24-hour (1) 0.5 ppm (1300 µg/m 3 ) Same as Primary Same as Primary 3-hour (1) (1)Not to be exceeded more than once per year. (2) Not to be exceeded more than once per year on average over 3 years. (3) To attain this standard, the 3-year average of the weighted annual mean PM2.5 concentrations from single or multiple community-oriented monitors must not exceed 15.0 µg/m3. (4) To attain this standard, the 3-year average of the 98th percentile of 24-hour concentrations at each population-oriented monitor within an area must not exceed 35 µg/m3 (effective December 17, 2006). (5) To attain this standard, the 3-year average of the fourth-highest daily maximum 8-hour average ozone concentrations measured at each monitor within an area over each year must not exceed ppm. (effective May 27, 2008) (6) (a) To attain this standard, the 3-year average of the fourth-highest daily maximum 8-hour average ozone concentrations measured at each monitor within an area over each year must not exceed 0.08 ppm. (b) The 1997 standard and the implementation rules for that standard will remain in place for implementation purposes as EPA undertakes rulemaking to address the transition from the 1997 ozone standard to the 2008 ozone standard. (7) (a) The standard is attained when the expected number of days per calendar year with maximum hourly average concentrations above 0.12 ppm is < 1. (b) As of June 15, 2005 EPA revoked the 1-hour ozone standard in all areas except the 8-hour ozone nonattainment Early Action Compact (EAC) Areas. Table 3-1 List of criteria pollutants and standards 30

31 3.1 Quality System Requirements for EPA Funded Programs EPA s national quality system requirements can be found in EPA QA CIO2105. Any organization using EPA funds for the collection of environmental data are covered under CIO2105 must develop, implement, and maintain a quality system that demonstrates conformance to the minimum specifications of ANSI/ASQC E and that additionally provides for the following (excerpt from EPA Order CIO ): A quality assurance manager (QAM), or person/persons assigned to an equivalent position, who functions independently of direct environmental data generation, model development, or technology development responsibility; who reports on quality issues to the senior manager. Washington s Department of Ecology performs a multitude of data collection activities for different media (e.g., air, water, solid waste) where ambient air monitoring is only one branch in the organization. It is the responsibility of Ecology to have a Quality Management Plan that demonstrates an acceptable quality system and approved by the EPA Region 10. The Air Quality Program does not have a quality assurance manager who is independent of the direct environmental data generation. Ecology s Quality Assurance Officer is the quality assurance manager and ultimately responsible for the data. The SIP submitted to the EPA by the Washington State Department of Ecology (Ecology) SIP is a strategy designed to prevent pollution, clean up pollution, and support sustainable communities and natural resources. Ecology managers and staff depend on environmental data of sufficient quantity and quality to make informed decisions related to these goals. Other data is not for SI purposes and may have different quality objectives dependent on the ultimate use and nature of the data. However all data must have some degree of quality control consistent with its intended use. The development, practice and review of a Quality Management Plan (QMP) are critical in meeting these goals. Implementing a comprehensive Quality Management Plan is necessary to ensure that sufficiently accurate environmental data are available to support those decisions. If inaccurate data are collected, faulty decisions may be made. Other problems that may arise from inaccurate data include wasted resources, legal liability, increased risks to health and the environment, inadequate understanding of the state of the environment, and loss of credibility. Ecology is committed to developing sound quality assurance (QA) and quality control (QC) practices, and incorporating them into environmental studies and activities. These practices enable the staff to generate accurate data in a cost effective manner. 31

32 Ecology Executive Policy and Procedure 1-21 requires the consistent application of quality assurance principles to the planning and execution of all activities that acquire and use environmental measurement data. EPA requires that all projects involving the generation, acquisition, and use of environmental data are planned documented and have an agency-approved QAPP. The QAPP is the critical planning document for any environmental data collection operation as it documents how QA and QC activities will be implemented during the project s life cycle. 3.2 Quality Assurance Project Plans The QAPP is a blueprint for operators, project officers and program managers responsible for implementing, designing, and coordination air pollution monitoring projects to ensure that the data produced by the project will be the correct type, quality needed, and expected by the data user. The QAPP is a formal document describing, in comprehensive detail, the necessary QA/QC and other technical activities that must be implemented to ensure that the results of work performed will satisfy the stated performance criteria, which may be in the form of a data quality objective (DQO). The quality assurance policy of the EPA requires every Environmental Data Organization (EDO) funded by EPA to have written and approved quality assurance project plans (QAPPs) prior to the start of the EDO. The Washington Department of Ecology has an EPA approved QMP and reviewed every three years. The Plan delegates the authority to review and approve Quality Assurance Project Plans (QAPPs) to the Air Quality Program Quality Assurance Coordinator. It is the responsibility of the Air Quality Program Quality Assurance Coordinator to review and approve QA project plans. If the Coordinator gives permission to proceed without an approved QAPP, he/she assumes all responsibility. 3.3 The Graded Approach The term graded approach appears in the Quality Manual where it states that the level of detail in the quality management plan should be based on a common sense, graded approach that establishes QA and QC activities commensurate with the importance of the work, the available resources, and the unique needs of the organization. In referring to the QA Project Plan, the Quality Manual states that EPA organizations may tailor these QA Project Plan specifications in their own implementation documents to better fit their specific needs. 32

33 EPA Region 10 provides flexibility to the Air Quality Program implementing the policy of writing a detailed QAPP for every project, allowing for use of a graded approach. The four-tiered project category approach to the Ambient Air QA Program is provided in order to effectively focus on QA activities. Category I involves the most stringent QA approach, utilizing all QAPP elements as described in EPA QA/ R-5. The categories are listed in Table 3-2, whereas category IV is the least stringent, utilizing fewer elements. In addition, the amount of detail or specificity required for each element will be less as one moves from category I to IV. Table 1 provides information that helps to define the categories of QAPPs based upon the data collection objective. Each type of ambient air monitoring program EDO will be associated with one of these categories. The comment area of the table will identify whether QMPs and QAPPs can be combined and the type of data quality objectives (DQOs) required (see below). In EPA R5a, Table 2 identifies which of the 24 QAPP elements are required for each category of the QAPP. Based upon a specific project, the QAPP approving authority may add/delete elements for a particular category as it relates to the project but in general, this table will be applicable based on the category of the QAPP. Categories Programs QAPP/QMP Comments DQO Category 1 Projects include EDOs that directly support rulemaking, enforcement, regulatory, or policy decisions. They also include research projects of significant national interest, such as those typically monitored by the Administrator. Category 1 projects require the most detailed and rigorous QA and QC for legal and scientific defensibility. Category 1 projects are typically standalone; that is, the results from such projects are sufficient to make the needed decision without input from other projects. Category 2 Projects include EDO s that complement other projects in support of rulemaking, regulatory, or policy decisions. Such projects are of sufficient scope and substance that that their results could be combined with those from other projects of similar scope to provide necessary information for decisions. Category 2 projects may also include certain high visibility projects as defined by EPA management. Category 3 Projects include EDO s performed as interim steps in a larger group of operations. Such projects include those producing results that are used to evaluate and select options for interim decisions or SLAMS PSD NCore IMPROVE CastNet Speciation Trends Toxics Monitoring SPM One Time Studies Local Scale Air Toxics Grants 33 Most agencies implementing Ambient Air Monitoring Networks will have separate QMP s and QAPP s. However, a Region has the discretion to approve QMP/QAPP combination for small monitoring organizations (i.e., Tribes) Most agencies implementing Ambient Air Monitoring Networks will have separate QMP s and QAPP s. However, a Region has the discretion to approve QMP/QAPP combination small monitoring organizations (i.e., Tribes). EDO s of short duration, QMP and QAPP can be combined Formal DQO s Formal DQO s for national objective Flexible DQO s

34 Number of Days Department of Ecology Air Monitoring QA Plan April, 2010 to perform feasibility studies or preliminary assessments of unexplored areas for possible future work Category 4 Projects involving EDO s to study basic phenomena or issues, including proof of concepts, screening for particular analytical species, etc. Such projects generally do not require extensive detailed QA/QC activities and documentation. Education outreach Project objectives or goals Table 3-2 QAPP/QMP project categories 3.4 Flexibility in the systematic planning process and DQO development Table 3-2 describes four QAPP/QMP categories which require some type of statement about the program or project objectives. Three of the categories use the term data quality objectives (DQOs), but there is flexibility with the systematic planning process on how these DQOs are developed based on the particular category. For example, a category 1 project would have formal DQOs. Examples of category I projects, such as the State and Local Monitoring Stations (SLAMS), have DQOs developed by OAQPS. Category II QAPPS may have formal DQOs developed if there are national implications to the data (i.e., Speciation Trends Network) or less formal DQOs if developed by organizations implementing important projects that are more local in scope. Categories 3 and 4 would require less formal DQOs to a point that only project goals (category 4) may be necessary. 4 Project/Task Description Air pollution levels have declined in Washington State since the CAA was enacted, a result of air monitoring conducted and actions taken. However, recent health studies show that unhealthful levels of particulates and ozone occur at much lower levels. The studies were the basis of EPA lowering the NAAQS for PM 2.5 and Ozone in Days With Unhealthy Air Quality Source: Department of Ecology Carbon monoxide Fine particulate matter Ozone (smog) Sulfur dioxide Total August 31, 1999 Figure 4-1 Graph illustrating improved air quality 1998 Monitoring for particulate matter and ground level ozone is a primary monitoring goal of the Air Quality Program. Though particulate levels (PM 10 and PM 2.5 ) have steadily declined over the 34

35 years (due to education, cleaner stoves and burn bans), recent health studies demonstrate lowering NAAQS for fine particulates (PM 2.5 ) would lower risks of death attributed to the pollutant. In 2006, the NAAQS for PM 2.5 was lowered and South Tacoma was declared non-attainment (24 hour average) while data from communities in Marysville, Vancouver and Yakima showed the potential to exceed the NAAQS. The Air Quality Program began monitoring for ozone in Western Washington the 1970 s and found that the pollutant moved from urban areas toward rural areas near the Cascade foothills. Several communities downwind of Seattle, Tacoma, Vancouver and Spokane experience elevated ozone concentrations from May through September when temperatures rise above 30 º C. The Puget Sound and Portland/Vancouver regions have violated the NAAQS for ozone in the past but emission control efforts successfully reduced ozone levels in these region. In 2006, the NAAQS for ozone was lowered and the Puget Sound region slipped back into non-attainment with the highest ozone values occurring near Enumclaw. The U.S. Forest Service and National Park Service report that ozone has damaged trees, moss, and lichens in Mt. Rainier National Park and in Cascade forest and wilderness areas. Studies have shown that ozone accumulates in the Green, Carbon and White River drainages downwind of Seattle and Tacoma as well as in the Columbia River Gorge east of Portland/Vancouver. Climate change and increased threats of wildfires are predicted to increase ozone production in the Northwest. 4.1 Monitoring Goals of the Air Quality Program Goals of the Program include: provide air pollution data to the general public in a timely manner, judge compliance with and/or progress made towards meeting ambient air quality standards, observe pollution trends throughout the region, including non-urban areas; measure impacts from permitted/prescribed burning, monitor for criteria pollutants at locations where concentrations exceed sixty percent of the NAAQS. 35

36 To meet these goals, the network is designed to: determine where the highest concentration of ozone on PM 2.5 are expected to occur in the State, measure typical concentrations in the populated cities of Seattle, Tacoma, Bellevue, Vancouver and Spokane, determine the extent of regional pollutant transport among these populated cities, provide support in communities for real time particulate monitoring. 4.2 National Ambient Air Quality Network Through the process of implementing the CAA, six major categories of monitoring stations or networks that measure the air pollutants have been developed. The Air Quality Program participates in one interagency and five national programs. 4.3 State and Local Air Monitoring Stations (SLAMS) SLAMS consist of a network of monitoring stations whose size and distribution is largely determined by the monitoring requirements for NAAQS comparisons and the need for Washington State to meet the implementation plan requirements. The Puget Sound and Vancouver air sheds are two examples of maintenance areas where the implementation plan requires SLAMS for ozone attainment. Details on EPA required number of SLAMS can be found in Section 10. The majority of monitoring sites operating within the State are classified as SLAMS, supporting an instrument that measures for particulates or ozone. 4.4 Special Purpose Monitoring Stations (SPMS) A SPMS is designated for a special purpose in the monitoring network plan and in the Air Quality System. These sites are not established to monitor long term trends, instead, be moved to accommodate changing needs and priorities. As a SPM, the Air Quality Program does not count it when showing compliance with the minimum monitoring requirements for the number and location of monitors of various types. SPMs provide data for special studies needed by the Air Quality Program to support SIPs and other Air Quality Program activities. These monitors are not counted towards the monitoring organizations minimum requirements established in the CFR s for monitoring certain pollutants. 36

37 The SPMS are not permanently established and can be adjusted to accommodate changing needs and priorities. The SPMS are used to supplement the fixed monitoring network as circumstances (such as agricultural burning in Eastern Washington) require and resources permit. If the data from SPMS are used for SIP purposes, they must meet all QA, siting and methodology requirements for SLAMS monitoring. Any SPM data collected by the Air Quality Program using a Federal reference method (FRM), Federal equivalent method (FEM), or approved regional method (ARM) meets the requirements of 40 CFR Part 58.11, 58.12, and the QA requirements in 40 CFR Part 58 Appendix A or an approved alternative to Appendix A to this part. Compliance with the probe and monitoring path siting criteria in 40 CFR Part 58 Appendix E is followed. Data collected at an SPM using a FRM, FEM, or ARM meeting the requirements of Appendix A is submitted to AQS according to the requirements of 40 CFR Part The Air Quality Program submits to AQS an indication of whether each SPM reporting data to AQS monitor meets the requirements of Appendices A and E. 4.5 PM 2.5 Chemical Speciation Trends Network (STN) The EPA provides funding for states to monitor and gathers data on the chemical makeup of particulate matter. The Speciation Trends Network (STN) is a national network of sites used to determine, over a period of several years, trends in concentration levels of selected ions, metals, carbon species, and organic compounds in PM2.5. Ecology's Air Quality Program supports four speciation sites in Seattle, Vancouver, Yakima, Tacoma and Marysville. The STN is a component of the National PM2.5 SLAMS. Although the STN is intended to complement SLAMS activities, STN data will not be used for attainment or nonattainment decisions. The objectives of the STN network are: annual and seasonal spatial characterization of aerosols; air quality trends analysis and tracking the progress of control programs; comparing, aggregating and evaluating the chemical speciation data set to the data; collected from the IMPROVE network; and development of emission control strategies. 4.6 National Air Toxics Trend Stations (NATTS) There are currently 188 hazardous air pollutants (HAPs) or Air Toxics (AT) regulated under the CAA. These pollutants have been associated with a wide variety of adverse health and ecosystem effects. 37

38 In 1999, EPA finalized the Urban Air Toxics Strategy (UATS). The UATS states that emissions data are needed to quantify the sources of air toxics impacts and aid in the development of control strategies, while ambient monitoring data are needed to understand the behavior of air toxics in the atmosphere after they are emitted. Part of this strategy included the development of the National Air Toxics Trends Stations (NATTS). Specifically, it is anticipated that the NATTS data will be used for: tracking trends in ambient levels to evaluate progress toward emission and risk reduction goals, directly evaluating public exposure & environmental impacts in the vicinity of monitors, providing quality assured data for risk characterization, assessing the effectiveness of specific emission reduction activities, and evaluation and subsequently improving air toxics emission inventories and model performance. The NATTS program is made up of 23 monitoring sites representing urban and rural communities with an established quality assurance program. The Seattle Beacon Hill site is part of NATTS. 38

39 Figure 4-2 Location of the National Air Toxic Trend Stations Grants to conduct additional toxic monitoring is awarded through EPA Region 10. Additional monitoring has been conducted in Vancouver and Spokane and is expected to continue in Seattle and Tacoma. Separate QAPP s are required for these projects and must be submitted by the Project Manager to the Air Quality Program Quality Assurance Coordinator before the project begins. The QAPP must provide detailed monitoring objectives and how they will be obtained. It is the Quality Assurance Coordinator s responsibility to see that they are followed. If not, the AQLT must be alerted so that action can be taken. Figure 4-3 Technician documenting site visit 39

40 4.7 National Core Monitoring Network (NCore) The NCore Network is part of a national overall strategy to integrate multiple monitoring networks and measurements to enhance the foundation for future health studies, NAAQS revisions, validation of air quality models, assessment of emission reduction programs, and studies of ecosystem impacts of air pollution. Each state is required to operate at least one NCore site. The objective is to locate sites in broadly representative urban (about 55 sites) and rural (about 20 sites) locations throughout the country to help characterize regional and urban patterns of air pollution. The NCore network should be fully operational by The Seattle-Beacon Hill site is a designated Trends Site and therefore has been selected as an urban NCore station. Trends monitoring is characterized by locating a minimal number of monitoring sites across as large an area as possible while still meeting the monitoring objectives. The program objective is to determine the extent and nature of the air pollution and to determine the variations in the measured levels of the atmospheric contaminants in respect to the geographical, socio-economic, climatological and other factors. The data are useful in planning epidemiological investigations and in providing the background against which more intensive regional and community studies of air pollution can be conducted. The Cheeka Peak site on the tip of the Olympic Peninsula is designated a rural NCore station. Past work at Cheeka Peak by the University of Washington has shown its value in studies of long-range transport of pollutants from Asia, regional photochemistry and important boundary conditions for both regional and national scale models of air quality. This site is a collaborative effort between EPA, Olympic Region Clean Air Agency and the Makah Air Quality Program. The Ecology Air Quality Program is contracted to provide air quality system (AQS) and quality assurance support. 4.8 Interagency Monitoring of Protected Visual Environments (IMPROVE) The Interagency Monitoring of Protected Visual Environments (IMPROVE) program is a cooperative measurement effort governed by a steering committee composed of representatives from Federal and regional-state organizations. The IMPROVE monitoring program was established in 1985 to aid the creation of Federal and State implementation plans for the protection of visibility in Class I areas (156 national parks and wilderness areas) as stipulated in the 1977 amendments to the Clean Air Act. 40

41 The objectives of IMPROVE are: to establish current visibility and aerosol conditions in mandatory class I areas, to identify chemical species and emission sources responsible for existing man-made visibility impairment, to document long-term trends for assessing progress towards the national visibility goal, provided regional haze monitoring representing all visibility-protected federal class I areas where practical. IMPROVE has also been a key participant in visibility-related research, including the advancement of monitoring instrumentation, analysis techniques, visibility modeling, policy formulation and source attribution field studies. The Air Quality Program assists in the operation of an IMPROVE monitoring site at Beacon Hill in Seattle. Washington has eight Class 1 areas, totaling more than 3.3 million acres of land. They are: Alpine Lakes Wilderness Area Glacier Peak Wilderness Area Goat Rocks Wilderness Area Mt. Adams Wilderness Area Mt. Rainier National Park North Cascades National Park Olympic National Park Pasayten Wilderness Area Ecology is writing a regional haze State Implementation Plan (SIP). This plan will document current conditions at our Class 1 areas and define a strategy for returning visibility at these sites to natural conditions by 2064, as required by the Clean Air Act. Ecology is working closely with other states and organizations to write this plan, mostly through the Western Air Regional Partnership (WRAP). 5 Quality Objectives and Criteria for Measuring Data Air Quality Program decision makers realize that the air monitoring network contains a certain amount of error and will use specific data quality measurement indicators to reduce uncertainties. By setting acceptable limits on measurement indicators, the AQLT can take into account the quality of the data and reduce the risk of making wrong decisions. 41

42 EPA is responsible for developing NAAQS, defining the quality of the data necessary to make comparisons to the NAAQS, and identifying a minimum set of QC samples from with to judge data quality. The Air Quality Program is responsible for using this information to develop and implement a quality system that will meet the data quality requirements and following it. The Air Quality Program assesses the quality of the data and takes corrective action when appropriate. Before any monitoring is begun, the MAC determines the Data Quality Objectives (DQOs) for the population the monitoring is to target. The Data Quality Objectives define the data quality needed to make a correct decision an acceptable percentage of the time and are measured using Measurement Quality Indicators. Since errors will occur (uncertainty) the Quality Assurance Unit will prepare a quarterly Air Monitoring Data Quality Assessment Report for the review by the MAC to determine if the objectives are being met. 5.1 Data Quality and Measurement Objectives The Air Quality Program pays special attention to the DQO s when data values fall very close to the NAAQS, realizing there is a possibility uncertainty and error in the measurements may yield annual averages above NAAQS when the average is actually below it. Such uncertainties may require increased monitoring to give the AQLT greater confidence that their decision to declare an area in non-attainment is defensible and correct. Data collected for the Air Quality Program are used to make very specific decisions that can have an economic impact on the area represented by the data. The MAC and AQLT need to feel confident that the data used to make environmental decisions are of adequate quality Before monitoring is conducted, the MAC establishes overall criteria for how DQOs will be set for various types of monitoring projects. DQO s are created for the project to: clarify the study objective, identify the population that will be monitored, define the most appropriate type of data to collect, determine the most appropriate conditions from which to collect the data, and specify tolerable limits on decision errors which will be used as the basis for establishing the quantity and quality of data needed to support the decision. The AQLT makes decisions based on the data, therefore they must know the level of uncertainty they are willing to accept. The Quality Assurance Coordinator assists the MAC in determining appropriate Measurement Quality Objectives (MQOs) when proposing monitoring projects. MQO s are developed to help assure that activities occurring at various phases of the measurement process (field, lab etc.) maintain an acceptable level of data quality. 42

43 MQOs are identified as the various Quality Control (QC) samples or QC activities undertaken to ensure DQOs are met. Data verification/validation is the process of reviewing the information to ensure that data of unacceptable quality is identified and appropriately handled so that it cannot effect the decision making process (Appendix A). If one or several of the Objectives are not met, the MAC decides if adjustments to the project be made to reduce uncertainty. This is critical if the data is near to a violation of the NAAQS. The MAC is updated with reports from the Air Monitoring and Quality Assurance Coordinator at monthly meetings. These reports give a status of MQOs for the monitoring network and keep decision makers informed if decisions can be made with the quality of the data collected. Monitoring Action Committee Data Quality Objectives Uncertainty Population (Representativeness) Measurment Quality Objectives (Indicators) Precision Bias Detectability Completeness Comparability Figure 5-1 The Data Quality Process 43

44 5.2 Ecology Air Program Goals Collecting data of sufficient quality and quantity to meet program requirements and objectives consistent with its intended use is a primary goal of the Air Quality Program. The MAC and AQLT recognize that good decisions depend on data of good quality collected with an intended purpose. The quality system developed and followed by the MAC and AQLT is designed to produce results that will: meet a well defined use or purpose, satisfy the strategic goals of the Air Quality Program, comply with federal/state standards and specifications, reflect consideration of cost and economics, and match data quality needs and risks of inadequate data with intended uses for the data. 5.3 Monitoring Project Proposal Before any monitoring is conducted, the MAC will review monitoring proposals to determine if the proposed project meets Program Objectives. The MAC follows a Monitoring Proposal Outline listing specific criteria that must be addressed to determine if the proposed project meets the Program Objectives. The MAC uses the outline in Figure 5-2 to evaluate if the project has merits before committing resources. Monitoring Project Proposals are usually approved at the MAC level; however, the Program Manager has the final approval authority for any proposal. 44

45 Figure 5-2 Elements of MAC project proposal 5.4 Air Quality Program Objectives If decision makers are to decide on a course of action based on the data, they must be confident the data collected is of acceptable quality. Data from any study will not be error free and will contain levels of doubt (uncertainty). To provide Ecology s decision makers with data of acceptable quality, Measurement Quality Indicators will determine the accuracy of the data collected. 6 Personal Qualification and Training 6.1 Qualifications Air Quality Program monitoring personnel are hired from a list of candidates provided by the Department of Personnel after a screening process. A Bachelor's degree involving major study in environmental, physical, or one of the natural sciences, environmental planning or other allied field is desirable. 45

46 An entry-level environmental specialist in the Air Quality Program performs one or more of the following functions under close direction and supervision: assists in the installation, operation and maintenance of environmental monitoring/sampling equipment; assists in performing field and office surveys and studies; performs surveillance and other special projects, assists in routine repairs and calibrations of environmental monitoring/sampling equipment, in accordance with specifications and standard operating procedures, performs basic sampling data review for precision and accuracy, enters and maintains basic databases or inventories, responds to routine inquiries or requests for technical assistance regarding the scientific background and technical implementation of agency programs, reviews plans for technical accuracy and makes recommendations to higher level staff, conducts routine sampling and test, analyzes, evaluates and interprets data, writes reports, and assists higher level staff, and maintains and utilizes computerized environmental databases in support of technical projects. The primary responsibility for training rests with the individual s supervisor. Prior to installation of new equipment, support personnel will familiarize station operators with the calibration and maintenance of the new equipment. 46

47 6.2 Training Adequate education and training is integral to the Air Quality Program for collecting reliable and comparable data. Scheduled training is aimed at increasing employee knowledge in combination with opportunities to work with laboratory staff. All monitoring staff is encouraged to attend special training when available. Ecology s Environmental Assessment Program Quality Assurance Program provides additional information on fundamental quality assurance principals. Figure 6-1 Training at Ecology Course Field QA Supervisor Staff Staff Air Pollution Control Orientation Course APTI-SI:422 Principles and Practices of Air Pollution Control APTI-452 Mathematics Review for Air Pollution Control APTI-SI:100 Orientation to Quality Assurance Management QS-QA1 Introduction to Ambient Monitoring APTI-SI:434 General Quality Assurance Considerations for Ambient Air Monitoring APTI-SI:471 Basic Air Pollution Meteorology APTI-SI:409 Data Quality Objectives Workshop QS-QA2 Chain of Custody Procedures for Sample and Data APTI-443 Quality Assurance Project Plan QA3 Atmospheric Sampling APTI-435 Network Design for Monitoring PM 2.5 and PM 10 in Ambient Air APTI- 433 Analytical Methods for Air Quality Standards APTI-464 Beginning Environmental Statistical Techniques APTI-473A Quality Assurance for Air Pollution Measurement Systems APTI- 471 Management Systems Review QA5 Data Quality Assessment QA4 Quality Audits for Improved Performance QA6 Introduction to Environmental Statistics APTI-473B AQS Conference and Training Table 6-1 Suggested training courses for air monitoring personnel 47

48 Quality assurance information is provided through several organizations.. Seminars may be provided as videotapes, closed circuit transmission, web based real-time interactive formats, and/or live instruction. Several training opportunities are offered by the Air Pollution Training Institute (APTI). Air Quality Program personnel who audit PM 2.5 Speciation Trends Sites are required to possess mandatory training and a current certification issued by Office of Air Quality Planning and Standards (OAQPS). Courses are provided by OAQPS staff on a yearly basis. Air Quality System training (AQS training) is provided at the EPA Research Triangle Park, NC facility or at Regional Offices for specific instruction. The American Indian Training Program, located in Las Vegas at the Institute for Tribal Environmental Professionals (ITEP) provides a series of courses for tribal members. 6.3 Conferences and Professional Organizations Air monitoring personnel are encouraged to attend and contribute input to professional conferences taking advantage of the many opportunities these venues provide. Only by active participation and interaction with colleagues from other agencies and business will the participant experience professional growth. Several organizations provide information and professional development opportunities for staff to pursue. The Western States Air Resource Council (WESTAR), The National Association of Clean Air Agencies (NACAA) and Air and Waste Management Association (AWMA) are just of few of the many organizations staff can access to locate state and local air agencies across the nation, access the latest information on important air pollution topics, learn about the association's positions and initiatives or find links to other related web sites. 48

49 Conference Annual EPA Quality Conference Content EPA sponsors a national conference on managing quality systems for environmental programs every year. National Air Quality Conference Annual AQS Conference EPA sponsors a national conference on air quality forecasting, mapping, ambient air monitoring, air quality and your health, and innovative outreach programs. EPA sponsors a national conference EPA sponsors a national conference designed for State, Local, and Tribal agency staff responsible for providing data to the AQS database and for staff using the data from the AQS database. Air and Waste Management Conference American Meteorological Society The Air and Waste Management Association sponsors a national conference designed for air monitoring professionals. The American Meteorological Society promotes the development and dissemination of information and education on the atmospheric and related oceanic and hydrologic sciences and the advancement of their professional applications. Table 6-2 Suggest organizations and conferences for continued learning 6.4 Vendor Training Several vendors of air monitoring equipment offer training courses. Many of these courses are instrument specific ( e.g. Teledyne Advanced Pollution Instrumentation ) and provide technicians hands on instruction. Several offer custom training classes and off-site training for specific needs. 7 Documentation and Records The Program will submit to the EPA Administrator, through the Region 10 Office, an annual summary report of all the air quality monitoring data from monitoring stations designated as SLAMS. The report will be submitted by July 1 of each year for the data collected from January 1 to December 31 of the previous year. The Program Manager will certify that the annual 49

50 summary is accurate to the best of his/her knowledge. This certification will be based on the various assessments and reports performed by the organization. 7.1 Electronic Records The majority of the data collected by the Air Quality Program is collected electronically or is stored electronically. The electronic records are stored in a logical order for ease of access should it be necessary. The data is securely stored on a Microsoft SQL 2005 server. An incremental back up is done daily and full backups weekly. For historical reasons data is never deleted. Categories Record File Location Management and Organization State Implementation Plan Reporting agency information Organizational structure Personnel qualification and training Training certification Headquarters-Lacey Quality management plan EPA directives Grant allocations Support contracts Site Information Network description Site characterization file (site master) Site maps Site pictures Headquarters-Lacey Environmental Data Operations Raw Data QA Project Plans Standard Operating Procedures Electronic field notes Inspection/Maintenance records Laboratory notebooks Sampling handling/custody records Any original data (routine and QC data) including data entry forms Air quality index report Data Reporting Annual SLAMS air quality information data/summary Data algorithms Data Management Data management plans/flowcharts Data Management Systems Network reviews Data quality assessments QA reports Quality Assurance System audits Response/corrective action reports Site audits Table 7-1 Air Program record storage locations 50 Headquarters-Lacey Manchester Laboratory PSSCAA Manchester Laboratory Manchester Laboratory Headquarter-Lacey Puget Sound Clean Air Agency Headquarters-Lacey Headquarters-Lacey Headquarters-Lacey

51 The Air Quality Program utilizes the Envitech Ltd. Environmental Data Management System, Envista Air Resource Manager and DR DAS data acquisition system for electronic data retrieval and storage. 7.2 Record Retention The Air Quality Program maintains air monitoring records for a minimum of 3 years. As stated in 40 CFR Part 31.42, all information considered as documentation and records is retained for 3 years from the date the grantee submits its final expenditure report unless otherwise noted in the funding agreement. However, if any litigation, claim, negotiation, audit or other action involving the records has been started before the expiration of the 3-year period, the records will be retained until completion of the action and resolution of all issues that arise from it, or until the end of the regular 3-year period, whichever is later. For clarification purposes, the retention of samples produced as a result of required monitoring may differ depending on the program and/or purpose collected. 7.3 Site Information Site information is retained by the Air Quality Program to record physical changes and characterize the site through time. The Air Quality System (AQS) Site File is used to capture and retain site information. The Air Quality Programs Air Quality System Coordinator retains several records. Included in the site information file are maps and pictures of an individual site. This information is updated periodically as physical conditions around the site changes. Often referred to as the site master the information found in a site identification record includes: purpose of measurements (e.g., monitoring to determine compliance with air quality standards), station type, instrumentation and methods (manufacturer s model number, pollutant measurement technique, etc.), sampling system, spatial scale of the station (site category--i.e., urban/industrial, suburban/commercial, etc.; physical location--i.e., address, AQCR, UTM coordinates, etc.), influential pollutant sources (point and area sources, proximity, pollutant density, etc.), topography (hills, valleys, bodies of water, trees; type and size, proximity, orientation, etc., picture of a 360 degree view from the probe of the monitoring site), atmospheric exposure (unrestricted, interferences, etc.), site diagram (measurement flow sheet, service lines, equipment configuration, etc.), and 51

52 site audits. 7.4 Environmental Data Operations The Air Quality Program recognizes that ambient air monitoring results and in certain types of measurements, the sample itself, may be essential elements in proving the validity of the data or the decisions made using the data. Data will not be admitted as evidence unless it can be shown that they are representative of the conditions that existed at the time that the data (or sample) was collected. Therefore, the Air Quality Program follows several steps to assure the evidentiary phase of the quality assurance program is met. Failure to include any one of these elements in the collection and analysis of ambient air monitoring data will render the results of the program inadmissible as evidence, or seriously undermine the credibility of any report based on these data. QA Project Plans - Documents how environmental data operations are planned, implemented, and assessed during the life cycle of a program, project, or task. Standard Operating Procedures (SOPs)- Written documents that give detailed instruction on how Air Quality Program staff will perform daily tasks: field, laboratory and administrative. SOPs are a required element of a QAPP and therefore any EDO must include these. Field and laboratory notebooks- Any documentation that may provide additional information about the environmental data operation (e.g., calibration notebooks, strip charts, temperature records, site notes, maintenance records, etc.). Envidas Reporter Log- documentation in the Evidas for Windows Reporter Log Function provides storage for sampling comments for field and data personnel. These records provide a record of maintenance activities that were perform on the monitoring instruments or other notes that could affect data quality. Sample handling records- Records tracing sample and data handling from the site through analysis, including transportation to facilities, sample storage, and handling between individuals within facilities. (Section 11 provides more information on this activity.) 52

53 7.5 Quality Assurance Project Plan In the assistance agreement sections of 40 CFR parts quality assurance programs must be established. In addition to the grant requirements, 40 CFR Part 58 Appendix A states that each quality assurance program must be described in detail in accordance with the EPA Requirements for Quality Assurance Project Plans. 7.6 Standard Operating Procedures In order to perform sampling and analysis operations consistently, standard operating procedures (SOPs) are provided to personnel. The SOPs detail the method for each operation in the analysis, or action with thoroughly prescribed techniques and steps, and are officially approved as the method for performing certain routine or repetitive tasks. The SOPs are written in a step-by-step format to be readily understood by a person knowledgeable in the general concept of the procedure and should ensure consistent conformance with Air Quality Program practices, serve as training aids, provide ready reference and documentation of proper procedures, reduce work effort, reduce error occurrences in data, and improve data comparability, credibility, and defensibility. Each Procedure contains suggested maintenance, troubleshooting tips and QC check requirements. Procedures are revised on an as need basis or when new methods or instruments are used. Field Monitoring Procedures Last Update Ozone Monitoring Procedure Carbon Monoxide Monitoring Procedure PM 2.5 Single Channel Sampler Procedure PM 2.5 Tapered Element Oscillating Microbalance Procedure April 2008 March 2003 February 2000 May 2000 PM 2.5 Sequential Sampler Procedure March 1999 Nephelometer Procedure December 2008 Aethalometer Operating Procedure October 2003 Nitrogen Dioxide Operating Procedure October

54 PM 10 Tapered Element Oscillating Microbalance Operating Procedure March 2004 Meteorological Monitoring Procedure August 2000 Ecotech Nephelometer Operating Procedures March 2009 Table 7-2 List of Ecology Air Quality field monitoring procedures 8 Monitoring Network Design To meet the Air Quality Program objectives, air monitoring sites have been established to; provide air pollution data to the general public in a timely manner judge compliance with and/or progress made towards meeting ambient air quality standards observe pollution trends throughout the region, including non-urban areas measure impacts from permitted/prescribed burning 8.1 Air Quality Public Reporting According to Part of 40 CFR, all Metropolitan Statistical Areas (MSAs) with a population of 350,000 or greater are required to report daily air quality using the Air Quality Index (AQI) to the general public. The AQI is calculated from concentrations of five criteria pollutants: ozone (O3), particulate matter (PM), carbon monoxide (CO), sulfur dioxide (SO2), and nitrogen dioxide (NO2). The concentration data used in the calculation are from the State and Local Air Monitoring Stations (SLAMS) required under Part 58 of 40CFR. 8.2 National Air Quality Index (AQI) The U.S. EPA, NOAA, NPS, tribal, state, and local agencies developed AIRNow to provide the public with easy access to national air quality information. The Web site offers daily AQI forecasts for PM 2.5 and ozone as well as real-time AQI conditions for over 300 cities across the US, and provides links to more detailed State and local air quality Web sites. 54

55 Figure 8-1 Example of an AIRNow AQI forecast 8.3 Washington Air Quality Advisory (WAQA) for PM 2.5 The WAQA is very similar to the Environmental Protection Agency s (EPA s) national information tool, the Air Quality Index (AQI). Both use color-coded categories to show when air quality is good, moderate or unhealthy. The difference is that WAQA shows the health effects of PM 2.5 at lower levels than the AQI does. Ecology believes WAQA better protects public health. To provide PM concentrations to the general public in a timely manner and in rural, smaller populated areas, the Air Quality Program supports a large network utilizing techniques approved by EPA Region 10. This data is displayed on Washington Department of Ecology Air Quality Program web link. 55

56 Figure 8-2 Example of near-real time color coded PM 2.5 WAGA Although some preliminary data quality assessments are performed, the data as such are not fully verified and validated through the quality assurance procedures. Therefore, data used on the AIRNow and Ecology Web sites is only for the purpose of reporting the AQI and WAQA. 8.4 Monitoring for Compliance A major objective of the Air Quality Program is to monitor in areas where the highest pollution occurs and where the population is most densely populated. The data is used to judge compliance with and/or progress made towards meeting ambient air quality standards. Using past data the Program recognizes that; the Seattle-Tacoma-Bellevue region is a priority area due to the high population and pollution levels; the Duwamish Valley in Seattle is a highly industrialized neighborhood; communities southeast of the Seattle-Tacoma-Bellevue region such as Enumclaw suffers the greatest impact from ground level ozone during summer months due to predominate wind patterns and geography; 56

57 population in the region continues to grow; smoke from agricultural burning is a nuisance in Eastern Washington communities. Few of the stations are capable of fulfilling more than one of the objectives; however there are selected sites that are useful in determining not only population exposure but can also document the changes in pollutant concentrations resulting from mitigation strategies used in the area. The Air Quality Program has designated monitoring sites in selected regions to determine the extent and nature of air pollutants in respect to the geographical, socio-economic, climatological and other factors. The data are useful in planning epidemiological investigations and in providing the background against which more intensive regional and community studies of air pollution can be conducted. 8.5 Monitoring Boundaries The State of Washington is divided into statistical areas for use by Federal agencies in collecting, tabulating, and publishing Federal statistics. These areas are statistical geographic entities consisting of a county or counties associated with at least one urbanized area/urban cluster having at least a population of 10,000. Metropolitan (metro) statistical areas (MSA) is a category of geographic entities containing a core urban area of 50,000 or more population and consists of one or more counties. It includes counties containing a core urban area, as well as any adjacent counties that have a high degree of social and economic integration (as measured by commuting to work) with the urban core. These populated cores are of primary interest for measuring air pollution. Metropolitan Statistical Area Principal Cities Seattle-Tacoma-Bellevue, WA Spokane, WA Portland-Vancouver-Beaverton, OR-WA Seattle, Tacoma, Bellevue, Everett, Kent, Renton Spokane Portland, OR; Vancouver, WA; Beaverton, OR; Hillsboro, OR Table 8-1 Large Metropolitan Statistical Areas in Washington State 57

58 8.6 Monitoring Site Location The monitoring sites in the Air Quality Program Network are oriented to meet specific criteria to measure; impacts of known pollutant emission categories on air quality; population density relative to receptor-dose levels, both short and long term impacts of know pollutant emission sources (area and point) on air quality; representative area-wide air quality. Great care is given in the sampling site selection process involving; economics; security; logistics; and atmospheric conditions. 8.7 Monitor Placement Monitor placement is often delegated to the person responsible for monitor operation. A thorough survey of the area with careful detail to obstructions, activities in the immediate area. and access to the monitor will determine where the monitor is located. Importance is placed on air flow around the monitor to be representative of the general air flow in the area to prevent sampling bias. Placement of the monitor intake toward the direction of predominate winds is a priority. Sampling locations that might unduly influence the sample (e.g. a rooftop air inlet near a stack or a ground-level inlet near an unpaved road) are avoided. The EPA provides technical assistance documents that are specific to the pollutant that is to be measured. Due to the various physical and meteorological constraints, tradeoffs will be made to locate a site in order to optimize representativeness of sample collection. The consideration should include categorization of sites relative to their local placements. Suggested categories relating to sample site placement for measuring a corresponding pollution impact are identified in Figure 8.3. Specifics on probe locations are described in individual SOPs. 58

59 Station Category A (ground level) B (ground level) Characterization Heavy pollutant concentrations, high potential for pollutant buildup. A site 3 to 5 m (10-16 ft) from major traffic artery and that has local terrain features restricting ventilation. A sample probe that is 3 to 6 m (10-20 ft) above ground. Heavy pollutant concentrations, minimal potential for pollutant buildup. A site 2 to 15 m (15-50 ft) from a major traffic artery, with good natural ventilation. A sampler probe that is 3 to 6 m (10-30 ft) above ground. C (ground level) D (ground level) E (air mass) F (source oriented) Moderate pollutant concentrations. A site 15 to 60 m (5-200 ft) from a major traffic artery. A sampler probe that is 3 to 6 m (10-20 ft) above ground. Low pollutant concentrations. A site 60 m ( 200 ft) from a traffic artery. A sample probe that is 3 to 6 m (10-20 ft) above ground. Sampler probe that is between 6 and 45 m ( ft) above ground. Two subclasses: (1) good exposure from all side (e.g. on top of building) or (2) directionally biased exposure (probe extended from wall or window). A sampler that is adjacent to a point source. Monitoring that yields data directly related to the emission source. Figure 8-3 Station categories and how they are characterized 8.8 Minimum Network Requirements Minimum network requirements are required for PM 2.5 and Ozone. In 2007, the minimum network site requirements for the criteria pollutants CO, NO2 and SO2 were removed from CFR. Where SLAMS monitoring for these three criteria pollutants are ongoing, at least one site must be a maximum concentration site for that area under investigation. 40 CFR Part 58, Appendix D of the most current regulation is referenced to find the appropriate minimum monitoring network requirements. 8.9 Design Values A design value is a statistic that describes the air quality status of a given area relative to the level of the National Ambient Air Quality Standards (NAAQS). Design values are especially helpful when the standard is exceedance-based (e.g. 8-hour ozone, 24-hour PM 2.5, etc.) 59

60 because they are expressed as a concentration instead of an exceedance count, thereby allowing a direct comparison to the level of the standard. Design values are consistent with the NAAQS in CFR Part 50. As such, they are based on three years of data, ensuring a stable indicator. Design values are typically used to classify nonattainment areas, assess progress towards meeting the NAAQS, and develop control strategies. Design values are computed and published annually by EPA's Office of Air Quality Planning and Standards and reviewed in conjunction with the EPA Regional Offices Fine Particulate Matter PM 2.5 Design Criteria The Air Quality Program must operate a minimum number of required PM 2.5 SLAMS sites. MSA Population 1,2 Most recent 3-year design value concentrations 85% of any PM 2.5 NAAQS 3 Most recent 3-year design value concentrations 85% of any PM 2.5 NAAQS 3,4 Greater than 1 million ,000-1,000, ,000-<500, Minimum monitoring requirements apply to the Metropolitan statistical area (MSA). 2 Population based on latest available census figures. 3 The ozone (O 3) National Ambient Air Quality Standards (NAAQS) levels and forms are defined in 40 CFR part These minimum monitoring requirements apply in the absence of a design value. 5 Metropolitan statistical areas (MSA) must contain an urbanized area of 50,000 or more population. Table 8-2 PM2.5 minimum number of sites required All FRM PM 2.5 air monitoring sites are located in population-oriented areas of expected maximum concentration (where the worst air quality is expected to occur). Though many of the FRM PM 2.5 sites are classified as neighborhood or urban-scale, the EPA Region 10 Administrator considers these sites to represent community-wide air quality. 60

61 Each State shall install and operate at least one PM 2.5 site to monitor for regional background and at least one PM 2.5 site to monitor regional transport. These monitoring sites may be at community-oriented sites and this requirement may be satisfied by a corresponding monitor in an area having similar air quality in another State. State and local air monitoring agencies must use methodologies and QA/QC procedures approved by the EPA Regional Administrator for these sites. Methods used at these sites may include non-federal reference method samplers such as IMPROVE or continuous PM 2.5 monitors. Monitoring for PM 2.5 is conducted at Beacon Hill for regional transport and Enumclaw for regional background. Each State shall continue to conduct chemical speciation monitoring and analyses at sites designated to be part of the PM 2.5 Speciation Trends Network (STN). The selection and modification of these STN sites must be approved by the Administrator. The PM 2.5 chemical speciation urban trends sites shall include analysis for elements, selected anions and cations, and carbon. Samples must be collected using the monitoring methods and the sampling schedules approved by the Administrator. Chemical speciation is encouraged at additional sites where the chemically resolved data would be useful in developing State implementation plans and supporting atmospheric or health effects related studies Network Assessments The U.S. Environmental Protection Agency (EPA) finalized an amendment to the ambient air monitoring regulations on October 17, As part of this amendment, the EPA added the following requirement for state, or where applicable, local monitoring agencies to conduct a network assessments once every five years [40 CFR 58.10(e)]. This requirement is an outcome of implementing the National Ambient Air Monitoring Strategy (NAAMS, the most recent version is dated December 2005, U.S. Environmental Protection Agency, 2005). The purpose of the NAAMS is to optimize U.S. air monitoring networks to achieve, with limited resources, the best possible scientific value and protection of public and environmental health and welfare. A network assessment includes (1) re-evaluation of the objectives and budget for air monitoring, (2) evaluation of a network s effectiveness and efficiency relative to its objectives and costs, and (3) development of recommendations for network reconfigurations and improvements. EPA expects that a multi-level network assessment will be conducted every five years (U.S. Environmental Protection Agency, 2005). 61

62 8.12 Locations of Reference/Equivalent Method Instruments The Air Quality Program is required to have reference or equivalent methods at specific sites. This requirement, and any exceptions, is specified in 40 CFR Part 58, Appendix C. Requiring the use of reference or equivalent methods helps to assure the reliability of air quality measurements including the ease of specification, guarantee of minimum performance, better instruction manuals, and flexibility of application, and comparability with other data and increased credibility of measurements. However, designation as a reference or equivalent method provides no guarantee that a particular analyzer will always operate properly. 40 CFR Part 58 Appendix A requires the Air Quality Program to establish an internal QC program. All reference and equivalent methods must be officially designated as such by EPA under the provisions of 40 CFR Part 53. Notice of each designated method is published in the Federal Register at the time of designation. A current list of all designated reference and equivalent methods is maintained and updated by EPA whenever a new method is designated. This list can be found on AMTIC.. Moreover, any analyzer offered for sale as a reference or equivalent method after April 16, 1976 must bear a label or sticker indicating that the analyzer has been designated as a reference or equivalent method by EPA Location of Particulate Matter (PM 2.5 ) FRM Samplers EPA Region 10 recommends that PM 2.5 FRM samplers operate only in locations where design values are greater than 80% of the NAAQS. Past monitoring demonstrated that few areas in Washington State approach NAAQS levels, therefore FRM samplers in the State have been significantly reduced from 2001 levels. Figure 8-4 Declining numbers of FRM samplers In 2010, seven Federal Reference Method (FRM) PM 2.5 samplers operated in the State (red triangeles). Past monitoring indicates that these sites have a potential to exceed the NAAQS. 62

63 Figure 8-5 PM 2.5 FRM samplers in Washington State (red triangles) Sampler Location AQS Number Network Sampling frequency Darrington (1) SLAMS 1/3 Marysville-Marysville JHS (2) SLAMS 1/1 Seattle-Beacon Hill (3) NCore 1/3 Spokane-Augusta (4) SLAMS 1/3 collocated Tacoma-L.Street (5) SLAMS 1/3 Vancouver-Moose Lodge (6) SLAMS 1/1 Yakima-Yakima M H (7) SLAMS 1/3 Table 8-3 Federal Reference Samplers operated in Washington State 63

64 Darrington Fir Street Marysville 7 th Avenue 64

65 Seattle Beacon Hill Spokane Augusta Ave. Spokane Augusta Street Vancouver 4 th Plain 65

66 Vancouver 4 th Plain Blvd E Tacoma L Street 66

67 Yakima 4 th Avenue 67

68 Site Name AIRS# Monitoring Objective Aberdeen Real time data for public Bellevue Real time data for public Bellingham Real time data for public Darrington Real time data for public Enumclaw Real time data for public Kennewick Real time data for public Kent Real time data for public LaCrosse Agricultural burn calls Lake Forest Park Real time data for public Longview/Olympic School Real time data for public Lynnwood/Lynnwood PUD Real time data for public Marysville/Marysville JHS Real time data for public Shelton/Mason Gen. Hosp Real time data for public Mesa/Mesa Agricultural burn calls Moses Lake/Moses Lake Agricultural burn calls Mt. Vernon/Mt. Vernon Real time data for public North Bend/North Bend Real time data for public Olympia-Lacey/Mt. View ES Real time data for public Port Angeles/Pt. Angeles MS Real time data for public Pullman/Pullman Agricultural burn calls Puyallup-South Hill Real time data for public Woodinville Real time data for public Ritzville Agricultural burn calls Rosalia Agricultural burn calls Seattle-Beacon Hill Real time data for public Seattle-Duwamish Real time data for public Seattle-Olive Street Real time data for public Spokane-Augusta Real time data for public Spokane Real time data for public Spokane/Monroe Street Real time data for public Starbuck/Starbuck Agricultural burn calls Tacoma/Alexander Ave Real time data for public Tacoma/L. Street Real time data for public Vancouver/Moose Lodge Real time data for public Walla Walla Agricultural burn calls Yakima Real time data for public 68

69 8.14 Ozone Analyzers in Washington State The Air Quality Program supports ten ozone monitoring sites within the State. Two of the sites (Beacon Hill and Mt. Rainer) operate year round. Between May and September, an additional eight ozone analyzers are operated at strategically located sites. The Air Quality Program provides quality assurance support to the ozone analyzer at the Cheeka Peak air monitoring site which operates year round Ozone (O 3 ) Design Criteria EPA requires the Air Quality Program to operate a minimum number of SLAMS O 3 sites in areas where typical peak concentrations approach the NAAQS (8 hour average of.075 ppm). The requirement is dependent upon area size (in terms of population and geographic characteristics) and typical peak concentrations (expressed in percentages below, or near the O 3 NAAQS). MSA Population 1,2 Most recent 3-year design value concentrations > 85% of any O 3 NAAQS 3 Most recent 3-year design value concentrations < 85% of any O 3 NAAQS 3,4 350,000 to < 4 million ,000 to < 350, Minimum monitoring requirements apply to the Metropolitan statistical area (MSA). 2 Population based on latest available census figures. 3 The ozone (O 3 ) National Ambient Air Quality Standards (NAAQS) levels and forms are defined in 40 CFR part These minimum monitoring requirements apply in the absence of a design value. 5 Metropolitan statistical areas (MSA) must contain an urbanized area of 50,000 or more population. Table 8-4 Minimum number of ozone sites requirement 8.16 SLAMS Minimum O 3 Monitoring Requirements The total number of O 3 sites needed to support the basic monitoring objectives of public data reporting, air quality mapping, and compliance includes more sites than the minimum numbers required by EPA. The EPA Region 10 Administrator and the MAC work together to design and/or maintain the most appropriate O 3 network to service the variety of data needs in the State. Design values have been calculated in locations where ozone monitoring has been conducted in the past. 69

70 County 2008 Design Value % of NAAQS MSA Population Minimum Required Current Number in MSA Clark ,500, King ,303, Pierce ,303, Spokane , Clark County is included in the Portland-Vancouver-Beaverton MSA. Clackamas County, OR has design value of.067 ppm. 2 King and Pierce counties are in a Core Based Statistical Area. The highest design value (.074) is used to judge compliance. Table 8-5 Ozone design values for counties in Washington State Seattle-Tacoma-Bellevue MSA The highest ozone concentrations in the State occur in the Seattle-Tacoma-Bellevue MSA. The Beacon Hill (neighborhood scale) ozone site, located in a reasonable homogeneous geographical area near the center of Seattle, provides valuable information for developing, testing, and revising concepts and models that describe urban/regional concentration patterns. These data are useful to the understanding and definition of processes that take periods of hours to occur and hence involve considerable mixing and transport. The data from Enumclaw-Mud Mountain monitoring site is used to estimate concentrations over large portions of the Seattle-Tacoma-Bellevue MSA. The measurements are used for determining trends, and designing area-wide control strategies. The site, recognized has having the highest ozone design value ozone concentration, is located 30 miles downwind of Seattle s urban core where the highest precursor emissions originate. Spokane MSA Two ozone sites are located outside Spokane s city limits in Spokane County near the communities of Greenbluff and Cheney. The site locations were established to capture ozone concentration during the summer and fulfill minimum SLAMS requirements for ozone. Portland-Vancouver-Beaverton MSA Five ozone sites are located in the Portland Vancouver air shed. The Air Quality Program operates a site in East Vancouver. Oregon Department of Environmental Quality operates sites 70

71 at Sauvies Island (North of Portland), Sherwood (East of Portland), Spangler Road (South of Portland), South East Portland (Central Portland (NCore) Figure 8-6 Location of ozone monitoring sites AIRS # Site Name Est. Type Scale Seattle 4/1/97 SLAMS Urban Beacon Hill Reservoir (1) NCore Issaquah 12/1/75 SLAMS Urban Lake Sammamish S.P. (2) Enumclaw 7/8/98 SLAMS Rural Mud Mountain Dam (3) North Bend 6/1/98 SLAMS Rural USFS (4) La Grande 5/30/85 SLAMS Urban Pack Forest (5) Mt. Rainier 7/13/98 SLAMS Rural Jackson Visitor Center (6) Vancouver 4/1/90 SLAMS Neighborhood Mountain View H.S. (7) Yelm 5/9/97 SLAMS Urban Water Treatment Center (8) Cheney 4/1/99 SLAMS Rural 71

72 Turnbull Slough NWR (9) Spokane 4/1/90 SLAMS Rural Greenbluff Fire Station (10) Cheeka Peak (11) 5/17/06 NCore Rural Seattle - Beacon Hill Issaquah Lake Sammamish. 72

73 Enumclaw - Mud Mountain La Grande Pack Forest 73

74 North Bend- North Bend Way Yelm-Northern Pacific 74

75 Mount Rainier National Park - JVC Vancouver- Blairmount Dr Cheney Turnbull Spokane Greenbluff Rd 75

76 76

77 8.17 Carbon Monoxide The Air Quality Program supports two carbon monoxide sites. There are no minimum requirements for the number of CO monitoring sites, but are operated by the local agencies for maintenance plans and trend analysis. Continued operation of existing SLAMS CO sites using FRM or FEM is required until discontinuation is approved by the EPA Region 10 Administrator. Where SLAMS CO monitoring is ongoing, at least one site must be a maximum concentration site for that area under investigation. AIRS # Site Name Est. Type Scale Spokane/3 rd & 1/1/97 SLAMS Micro Washington Table 8-6 Carbon monoxide sites supported by the Air Quality Program 8.18 Precursor Gas Monitoring Precursor gas monitoring is a suite of continuous instruments that operate year round to provide valuable information for a national effort to support advanced multiple pollutant monitoring in urban and rural areas for the National Ambient Air Monitoring Strategy. The NCore multipollutant station in Seattle at Beacon Hill is part of an overall strategy to integrate multiple monitoring networks and measurements. The site measures particles (PM2.5, speciated PM2.5, PM10-2.5, speciated PM10-2.5), O3, SO2, CO, nitrogen oxides (NO/NO2/NOy), lead (Pb) and basic meteorology. Though concentration of these gasses occur at levels far below health standards, the data will be used to develop emission control strategies relating to air quality model evaluation, rural monitoring of precursors for background transport, source apportionment and other observationbased models. The monitoring effort will also support long-term health and epidemiology studies Meteorological Measurements Meteorological towers are collocated with the ozone monitoring network to support modeling and forecasting efforts. The Air Quality Program Quality Assurance Unit will audit the accuracy 77

78 of meteorological data at approved sites once per year using the methodology prescribed in the Quality Assurance Handbook for Air Pollution Measurement Systems - Volume IV: Meteorological Measurements Version 2.0. Measurement Ambient temperature Wind speed Type Acceptance Criteria 3 pt. Water Bath with NIST traceable thermometer ±0.5 ºC NIST- traceable Synchronous Motor ±0.2 m/s Wind speed threshold Anemometer torque disc 0.5 m/s Wind direction Wind direction threshold Barometric pressure Solar noon Vane torque gauge NIST-traceable aneroid barometer ±5 degrees includes orientation error degree deflection ±3 mb Relative humidity Standard solutions ±7% Table 8-7 Accuracy criteria for towers in the PSD program Frequency Within 60 days of startup and 6 month intervals Within 60 days of startup and 6 month intervals Within 60 days of startup and 6 month intervals Within 60 days of startup and 6 month intervals Within 60 days of startup and 6 month intervals Within 60 days of startup and 6 month intervals Within 60 days of startup and 6 month intervals Based on the results from quality control checks and performance audits, the accuracy must be within the following tolerances listed in table Operating Schedules Station operators are required to follow the 3-day, 6-day or 12-day monitoring schedule for PM 10, PM 2.5, and VOC s. 78

79 Figure 8-7 Example of the operating schedule for PM10, PM2.5, and VOC's 8.21 Operating Schedule Completeness Data required for comparison to the NAAQS have specific completeness requirements. These completeness requirements generally start from completeness at hourly and 24-hour concentration values. However, the data used for NAAQS determinations include 3-hour, 8- hour, quarterly, annual, and multiple year levels of data aggregation. Generally, depending on the calculation of the design value, EPA requires data to be 75% complete (the Air Quality Program goal is 80% completeness). All continuous measurements come down to what is considered a valid hour and currently all 24- hour estimates (manual PM) are based on a 24- hour sampling period. Table 9.9 provides the completeness goals for the various ambient Air Quality Program monitoring programs. 79

80 Completeness Goals and Associated Standards (highlighted) Pollutants 1-hour 3-hour 8-hour 24-hour Quarterly Annual 75% of CO 45, 1 min values hourly values 80% of hourly O 3 SO 2 PM 10 Cont. PM 2.5 Cont. 45, 1 min. values 45, 1 min. values 45, 1 min. values 45, 1 min. values All 3 hours 75% complete 75% of hourly values 75% of hourly values 75% of hourly values 23 hours 23 hours values 80% of hourly values 80% of hourly values 75% of hourly values per quarter 75% of hourly values per quarter PM 10 Manual PM 2.5 Manual Federal Requirements 23 hours 23 hours State Goals Figure 8-8 Completeness goals for data completeness The data cells highlighted in Table 9.9 refer to the standards that apply to the specific pollutant. Even though a highlighted cell lists the completeness requirement, CFR provides additional detail, in some cases, on how a design value might be calculated with less data than the stated requirement. Therefore, the information provided in Table 9.9 should be considered the initial completeness goal which should be attempted to be achieved. Completeness goals that are not highlighted, although not covered in CFR, are very important to the achievement of the CFR completeness goals. So, for example, even though there is only an 8-hour ozone standard, it s important to have complete 1-hour values in order to compare to the 8-hour standard. 80

81 9 Sampling Methods 9.1 Monitoring Placement Where the MAC decides to monitor is dependent on the sampling objective. Sites are established to measure any one of the following; impacts of known pollutant emission categories on air quality; population density relative to receptor-dose levels, both short and long term; impacts of known pollutant emission sources (area and point) on air quality; representative area-wide air quality. To select locations according to these criteria, it is necessary to have detailed information on the location of emission sources, geographical variability of ambient pollutant concentrations, meteorological conditions and population density. Therefore, selection of the number of sites, locations and types of sampling stations is a complex process. The variability of sources and their intensities of emissions, terrains, meteorological conditions and demographic features require that the Air Quality Program Network is based on the best available evidence and on the experience of the decision team. Figure 9-1 Types of monitoring structures in the Air Monitoring Network Establishment of the air monitoring site is dependent on unrestricted access by the station operator and their safety. A majority of the sites are enclosed in stand-alone shelters/ trailers, buildings (ie. rooms in schools and fire stations) or on roofs of structures. 81

82 Room temperature is exceeding range. Data is invalid. Room temperature is within range. Data is good. Figure 9-2 DAS chart with room temperature Data is recorded when the shelter temperature is within the temperature control range. No Data is recorded when shelter temperature drifts outside the control range. Figure 9-3 Station report in the DAS The goal of maintaining instrument enclosures at stable temperatures between 20 º - 30º C is critical to the Data Acquisition System components in the shelter. Though the monitoring instruments are designed to operate outside these temperature ranges, out of control temperature control may result in data loss though the instruments can operate outside these ranges (Section 12). 82

83 Data is sent to Lacey via wireless, cable or dial-up DSL Figure 9-4 Example of an ozone station configuration 9.2 Sampling Probes and Manifolds At air monitoring stations measuring criteria air pollutants, only FEP Teflon is used for sample probes. The Teflon material lessens the oxidation of gases as they enter the sampling train, through the tubing to the analyzer until it reaches the detector inside the monitor. However, Pyrex glass is used in a combination with FEP Teflon at the Seattle/Beacon Hill air monitoring site where several gas analyzers draw from a glass manifold used in the sampling train (from inlet probe to the back of the analyzer). 83

84 9.3 Residence Time Determination All gas monitors in the network are required to have a residence time of less than 10 seconds. Residence time is defined as the amount of time that it takes for a sample of air to travel from the opening of the sample probe to the inlet of the instrument. V = pi * (d/2) 2 * L Where: V = volume of the component, cm3 pi = L = Length of the component, cm d = inside diameter, cm ( cm is the inside diameter of the Teflon probe material commonly used) Once the total volume is determined, divide the volume by the flow rate of the instruments. This will give the residence time. Sites in the Air Quality Program have probe lengths averaging 600 cm. 9.4 Placement of Probes and Manifolds Probe location is a major concern in efforts to avoid introducing bias to the sample. Important considerations are probe height above the ground, probe length (for horizontal probes), and physical influences near the probe. Some general guidelines followed for probe and manifold placement are: probes should not be placed next to air outlets such as exhaust fan openings horizontal probes must extend beyond building overhangs probes should not be near physical obstructions such as chimneys which can affect the air flow in the vicinity of the probe height of the probe above the ground depends on the pollutant being measured Detailed requirements for the placement of probes are in 40 CFR Part 58 Appendix E 84

85 10 Analytical Methods 10.1 Federal Reference Method (FRM) for PM 2.5 The reference method for PM2.5 sampling employs a sampler to draw a measured quantity of ambient air at a constant volumetric flow rate (16.67 L/min) through a specially designed particle-size discrimination inlet. PM2.5 particles are those particles with an aerodynamic diameter less than or equal to a nominal 2.5 μm. Particles in the 2.5 μm and smaller size range are collected on a 46.2 mm diameter Teflon filter during the specified 23- to 25-hour sampling period. Each filter is weighed before use and after sampling. From these measurements, the mass of the collected PM sample can be calculated. The total volume of air sampled is determined from the measured volumetric flow rate and the sampling time. The mass concentration of PM in the ambient air is computed as the total mass of collected particles in the PM size range divided by the total volume of air sampled and measured under ambient (actual) conditions of temperature and pressure. The PM concentration is thus expressed as μg/m3 of air. The Rupprecht & Patashnick Partisol -Plus Model 2025 Sequential Air Sampler ( Manual Reference Method: RFPS ) operates at all Air Quality Program PM 2.5 established for NAAQS attainment. The Model 2025 is operated with any software version through , with either R&P specified machined or molded filter cassettes, for 24-hour continuous sample periods, in accordance with the Model 2025 Instruction Manual and with the requirements and sample collection filters specified in 40 CFR Part 50, Appendix L Continuous Monitors for Gaseous Pollutants EPA reference or equivalent methods monitors will be used for collection of data for comparison to the NAAQS. These analyzers are continuous monitors that have met EPA equivalency requirements for measuring specific pollutants. Each model analyzer will be installed with adherence to procedures, guidance, and requirements detailed in 40 CFR Parts 50, 53 and 58; EPA QA Handbook Volume II: Part 1, the analyzer manufacturer s operation manual, and the SOPs Ozone (O 3 ) Measurements All ozone analyzers in the network use the Ultraviolet (UV) absorption method to measure for ozone. The analytical principle is based on absorption of UV light by the ozone molecule and subsequent use of photometry to measure reduction of the quanta of light reaching the detector 85

86 at 254 nm. The degree of reduction depends on the path length of the UV sample cell, the ozone concentration introduced into the sample cell, and the wavelength of the UV light. The Teledyne Advanced Pollution Instrumentation, Inc. Model 400E (Automated Equivalent Method: EQOA ) operates at all Air Quality Program ozone monitoring sites. The instrument operates on a full scale range of 500 ppb, at any ambient temperature in the range of 5 C to 40 C, with a sample flow rate of 800 ± 80 cm3/min, and with a TFE filter Sulfur Dioxide (SO 2 ) Measurements The analytical principle used to measure SO 2 is based on measuring the emitted fluorescence of SO 2 produced by the absorption of ultraviolet (UV) light. The UV lamp emits ultraviolet radiation which passes through a 214 nm band pass filter, excites the SO 2 molecules producing fluorescence which is measured by a photomultiplier tube (PMT) with a second UV band pass filter. SO 2 absorbs in the 190 nm 230 nm region free of quenching by air and relatively free of other interferences. A Thermo Electron Model 43 SO 2 Analyzer (Automated Equivalent Method: EQSA ) operates at the Seattle Beacon Hill site. It is equipped with an aromatic hydrocarbon cutter, operating on a full scale range of 100 ppb with a 5-micron TFE filter element installed in a filter sample assembly Carbon Monoxide (CO) Measurements The analytical principle is based on absorption of infrared (IR) light by the CO molecule. The analyzer operates on the principle that CO has a sufficiently IR absorption spectrum such that the absorption of IR by the CO molecule can be used as a measure of CO concentration in the presence of other gases. CO absorbs IR maximally at 2.3 and 4.6 um. Since NDIR is a spectrophotometric method, it is based upon the Beer-Lambert law. The degree of infrared radiation reduction depends on the length of the sample cell, the absorption coefficient, and CO concentration introduced into the sample cell. A Teledyne Advanced Pollution Instrumentation, Inc. Models 300EU Automated Reference Method: RFCA ) operates at the Seattle Beacon Hill site on a full scale range of 1 ppm at any temperature range between 10 C to 40 C with a 5-micron Teflon filter installed in the sample filter assembly. 86

87 10.6 Reactive Nitrogen Compounds (NO y ) Measurements The analytical principle is based on the chemiluminescent reaction of NO with an excess of O3. This reaction produces a characteristic near infrared luminescence with an intensity that is linearly proportional to the concentration of NO present. The reaction results in electronically excited NO 2 molecules which revert to their ground state, resulting in an emission of light or chemiluminescence. A Thermo Environmental Instruments Model 42C NO/NO2/NOx Analyzer (Automated Reference Method: RFNA ) with a converter operates at the Seattle Beacon Hill site on a full scale range of 50 ppb at temperatures between 15 C and 35 C Tapered Element Oscillating Microbalance (TEOM ) Particle-laden air is drawn into the TEOM monitor through an air inlet followed by an exchangeable filter cartridge where the particulate mass collects. The inlet system may or may not be equipped with the optional sampling head which pre-separates particles at either a 2.5 μm or 10 μm diameter. The filtered air then proceeds through the sensor unit which consists of a patented microbalance system. As the sample stream moves into the microbalance system (filter cartridge and oscillating hollow tapered tube), it is heated to the temperature specified by the control unit. This is done to minimize the deposition of water due to changes in ambient humidity. A Thermo Scientific TEOM 1400a PM10 Monitor (Automated Equivalent Method: EQPM ) is operated at select sites. The unit consists of a TEOM Sensor Unit; TEOM Control Unit; Flow Splitter (3 liter/min sample flow); Teflon-Coated Glass Fiber Filter Cartridges; Rupprecht & Patashnick PM 2.5 Inlet (16.7 liter/min). Seasonal adjustments to sample inlet temperature are made to reduce volatilization of particles Optical Absorption (Aethalometer) The Aethalometer measures the optical absorption of carbon particles at two wavelengths: 880 nm (IR), quantitative for the mass of Black or Elemental Carbon; and 370 nm (UV), indicating the presence of aromatic organic compounds such as are found in wood smoke, biomass-burning smoke, and tobacco smoke. The Real-time measurements can be made with time resolution from one second to one hour. Performing the dual wavelength measurement is important in determining the sources of airborne black carbon particles (i.e. diesel exhaust vs. wood smoke combustion). The instrument is widely used in monitoring applications involving human exposure to localized, community-based sources of air pollution. 87

88 10.9 Light Scattering of Fine Particulates (Nephelometer) The Air Quality Program supports a large network (~ 50) of nephelometers used to report the AQI to the public in a timely manner. Nephelometers are used for real-time public information and require specific methodologies approved by the EPA Region 10 Administrator. They are not used to determine NAAQS attainment. A nephelometer measures particles that are suspended in an air mass. The nephelometer measures light scattering from fine particulates and is dependent upon the properties of the particles. Establishing a working correlation between size of the particles and their reflectivity must be established before the nephelometer can be used for public information purposes. The Air Quality Program follows guidance in Data Quality Objectives (DQOs) for Developing and Model Development, in determining the logarithms used for specific regions of Washington State in converting measurements from a nephelometer to PM 2.5 like concentrations. The near real time information is used to determine the Washington Air Quality Advisory (WAQA). Figure 10-1 A Radiance nephelometer The guidance document describes the use of continuous PM2.5 measurements for the purpose of reporting the WAQA through the establishment of a relationship between FRM and continuous PM2.5 measurement. According to Part 58 of 40 CFR, Appendix G, particle measurements from non-federal Reference Method (FRM) monitors may be used for the purpose of reporting the AQI if a linear relationship between these measurements and reference or equivalent method measurements can be established by statistical linear regression. 11 Sample Handling and Custody Custody records provide a reviewable trail for quality assurance purposes and as evidence in legal proceedings. 88

89 11.1 Couriers The Program contracts with a courier (Federal Express) to transport PM 2.5 samples from the Manchester Laboratory to air monitoring offices in Bellevue, Yakima, Vancouver and Spokane. A state employed courier makes a daily run to Manchester from Olympia and Seattle. The courier must provide a tracking number for each shipment between Manchester and the field offices. Information describing the enclosed samples is placed on the bill of lading and copies of the shipping receipt and tracking number are kept as a record. The container (ice cooler) is addressed to a specific person authorized to receive the package and secured with a wire custody lock. The filters are transported to the site and the sampler is programmed for the assigned run day. After the run day, the operator returns to the site (within 177 hours) to pick up the sample, place it in a cool container (4 º C) and returns to the Laboratory for weighing. Filters originating from the laboratory at Puget Sound Clean Air Agency are picked up by the monitoring technician at the laboratory. The filters are transported to the site and the sampler is programmed for the assigned run day. After the run day, the operator returns to the site (within 177 hours) to pick up the sample, place it in a cool container (4 º C) and returns to the Laboratory for weighing. 12 Laboratory Methods The Air Quality Program contracts with laboratories equipped to measure samples that require laboratory analysis. Two of the laboratories are located in Washington State and are inspected by the Air Quality Program Quality Assurance coordinator on a routine basis. Laboratory/Network Pollutant Acceptable Method Reference Manchester/SLAMS PM 10 Hi-Vol Gravimetric 40 CFR Part 50 App B Manchester/SLAMS Puget Sound Clean Air Agency/SLAMS NATTS PM 2.5 Gravimetric 40 CFR Part 50 App L Metals Inductively coupled plasma (ICP) IO 3.5 Aldehydes High Pressure Liquid TO

90 Chromatography VOC s Gas Chromatography TO-15 STN PM 2.5 Gravimetric 40 CFR Part 50 App L Elements EDXRF STN QAPP and SOPs Anions Cations Organic, elemental, Carbonate, Total Carbon Semi-volatile Organic Compounds Thermal Optical Carbon Analyzer Gas Chromatography/Mass Spectrometry (GC/MS) STN QAPP and SOPs STN QAPP and SOPs STN QAPP and SOPs STN QAPP and SOPs Figure 12-1 Summary of pollutants accepted analytical methods SLAMs network provides rigorous quality control requirements for the analytical methods. These methods are found in 40 CFR Part 50, as described in the references. Some of the NATTS methods are derived from the Toxics Organic Method Compendium 3. Others like the STN Network may be developed specifically for the program based on the national laboratory currently performing the analysis. The NATTS and STN networks follow the performance based measurement process paradigm. These Networks QA project plans or technical assistance documents suggest a method, but also allow some flexibility to use other methods that meet the network s measurement quality objectives. Various, independent proficiency test samples and technical systems audits are performed to ensure that the data quality within these networks remains acceptable Laboratory Activities For ambient air samples to provide useful information or evidence, laboratory analyses must meet the following four basic requirements: equipment must be frequently and properly calibrated and maintained, personnel must be qualified to make the analysis, analytical procedures must be in accordance with accepted practice, complete and accurate records must be kept. 90

91 For the Air Quality Program, laboratory activities are mainly focused on the pollutants with manual measurements for particulate matter. The Air Quality Program requires that each laboratory should define these critical activities and ensure there are consistent methods for their implementation before any data is collected. 13 Quality Control 13.1 Data Quality Assessments Data Quality Assessments are the statistical assessments that determine if the DQOs are met and to provide descriptions of data uncertainty. If the DQOs are not met, the DQAs are used to determine whether modifications to the DQO are necessary or tighter quality control is required. Within any phase or step of the data collection process, errors can occur CFR Related Quality Control Samples 40 CFR Part 58 Appendix A identifies a number of quality control samples that must be implemented for the SLAMS (and NCore) and SPM. By 2009, any special purpose monitors that use FRMs or FEMs will be required to follow these requirements unless granted a waiver by the Region 10 Administrator. Table 14.1 provides a summary of the QC checks for the criteria pollutants and the CFR reference where an explanation of each check is described. The reader should distinguish the requirements that are related to automated and manual methods since there are some differences. Sampling Methods for Criteria Pollutants Method CFR Reference Coverage (annual) 91 Minimum frequency Automated Methods One-Point QC: for SO 2, NO 2, O 3, CO Section Each analyzer Once per 2 weeks Annual Performance Evaluation for SO 2, NO 2, O 3, CO Section Each analyzer Once per year Flow rate verification PM 10, PM 2.5, PM Section Each sampler Once every month MQOs ±10% Precision, Bias 10% O 3 Precision 7%, Bias ± 7% 15% for each audit concentration 4% of standard and 5% of design value

92 Method CFR Reference Coverage Minimum Frequency MQO s Semi-annual flow rate audit PM 10, PM 2.5, PM Section Each sampler Once every 6 month 4% of standard and 5% of design value Collocated sampling PM 2.5, PM Section % Every twelve days PM Performance evaluation program PM 2.5, PM Section ) 5 valid audit for primary QA orgs. with 5 sites 2) 8 valid audits for primary AQ orgs with > 5 sites 3. All samplers in 6 years Over all 4 quarters PM % PM % PM 2.5 ± 10% bias PM ± 15% bias Manual Methods Collocated sampling and % Every 12 days PM 10, TSP, PM 2.5, PM PSD every 6 days Flow rate verification PM 10(low vol) PM Each sampler Once every month Flow rate verification PM 10 (high-vol), TSP Each sampler Once every quarter Semi-annual flow rate audit PM 10(low vol), PM , PM Each sampler, all locations Once every 6 months Semi-annual flow rate audit PM 10 (high vol), TSP Each sampler, all locations Once every 6 months Performance evaluation program PM 2.5,PM and QA orgs. with 5 sites 2) 8 valid audits for primary AQ orgs with > 5 sites 3. All samplers in 6 years Over all four quarters PM 10, TSP, PM % precision PM % precision 10% of standard and 10% of design value 10% of standard and design value 10%of standard and 10 % of design value 10% of standard and design value PM 2.5 ± 10% bias PM ± 15% bias Some of the MQOs are found in CFR and others in the QA Handbook Vol II Table 13-1 Ambient air monitoring measurement quality samples 13.3 Sample Handling and Quality Control Filters used in manual methods are pre weighed at laboratory s located at Manchester and Puget Sound Clean Air Agency (PSCAA). Each laboratory has standard operating procedures listing the proper handling of the containers/filters to ensure their integrity. Proper lab documentation is maintained that tracks the disposition of filters through the preparation. This includes scale calibration checks, room temperatures and humidity. Care is taken to properly mark all samples to ensure positive, unambiguous identification throughout the sample collection, handling, and analysis procedures. 92

93 Clean filters are weighed at the laboratory in Manchester (Ecology) and Seattle (PSCAA) then delivered to the station operator. The station operator loads the filters into the samper and sets it to run on a scheduled day. The filters are then recovered within 177 hours. Filters are shipped back to the laboratory in a cooler to be reweighed. Filter weight, run day, average temperature and flow data is entered into the DAS System. The data is reviewed by the Ecology Quality Assurance staff in Lacey where questionable data is invalidated before it is entered into the EPA Air Quality System. Figure 13-1 PM2.5 filter weighing, collection and documentation PM 2.5 filters are accompanied with a Sampler Run Data Sheet. Data (flows, temperature, run time, etc.) is sent electronically from the instrument to the laboratory. The Data Sheet accompanies the sample filter providing a backup document should the electronic data becomes lost or corrupt. When the filter is picked up by the operator, information from the instrument is recorded on the Data Sheet and placed in a transport cooler with the dirty filters and locked with a numbered wire custody tag that must be cut with wire cutters to open. If the lock is cut before it reaches the laboratory, the filters are invalidated. PM 10 samples are collected in much the same way as the PM 2.5 filters. However the filters are not required to be cooled nor does the instrument record the critical data in electronic form. Figure 13-2 Example of PM 2.5 sample data sheet 93

94 Operators are required to complete a monthly PM 2.5 Sampler QC Check Form and submit it to the Quality Assurance Unit. The operator is required to check the sampler for the correct; date and time, ambient temperature and pressure, filter temperature, flow rate, leak check. Figure 13-3 Example of PM2.5 quality control check form 94

95 13.4 SLAMS CFR Related Quality Control Samples 40 CFR Part 58 Appendix A identifies a number of quality control samples that must be implemented for the SLAMS, NCore, SPM and PSD networks. By 2009, any special purpose monitors that use FRMs or FEMs will be required to follow these requirements unless granted a waiver by the Regional Administrator. Table 13-2 provides a summary of the QC checks for the criteria pollutants and the CFR reference where an explanation of each check is described. The reader should distinguish the requirements that are related to automated and manual methods since there are some differences Use of Computers for Quality Control In 2006, the Air Quality Program invested in a computer system that can process and output information in a timely fashion. The DR DAS ENVITECH environmental Data Management System is able to: compute calibration equations: compute measures of linearity of calibrations (e.g., standard error or correlation coefficient), plot calibration curves, compute zero/span drift results, plot zero/span drift data, compute precision and bias results, compute control chart limits, plot control charts, automatically flag out-of-control results, maintain and retrieve calibration and, performance records, Some of these checks (e.g. calibrations) only need to be reviewed as needed or when the actual check is performed. Other checks like zero/span/one point QC checks, programmed routine data range or outlier checks that may occur every day are much more easily performed automatically by properly programmed computer systems. A good example of this is the zero/span and one-point precision checks for the gaseous criteria pollutants. Although CFR requires the check to be performed once every two weeks, the Air Quality Program DAS initiates checks every 24-hours (2 AM-3AM). Table 13-2 provides an list of quality control checks that are required for PM 2.5. Although 95

96 the validation templates provide guidance when data should be invalidated, it is up to the monitoring organization to provide the specific corrective actions for the failure of a specific QC check. Ecology s Air Program will invalidate samples that fail to meet the Critical Criteria requirements listed in Appendix E of this document (e.g. flow rates, run times, instrument malfunctions). Filters will be invalidated if they show damage (holes or rips) of the filter. QUALITY CONTOL CHECKS FOR PM 2.5 REQUIREMENT FREQUENCY ACCEPTANCE CRITERIA Calibration Standards Flow Rate Transfer Std. Field Thermometer Field Barometer 1/yr 1/yr 1/yr. ± 2% NIST-traceable Std ± 0.1 º C resolution ± 0.5 º C accuracy Calibration/Verification Flow Rate (FR) Calibration FR multi-point verification One point FR verification External Leak Check Internal Leak Check Temperature Calibration Temp multi-point verification One-point temp verification Pressure Calibration Pressure Verification Clock/time Verification if multipoint failure 1/yr 1/4 weeks Every 5 sampling events Every 5 sampling events If multi-point failure On installation, then 1/yr 1/4 weeks on installation, then 1/yr 1/4 weeks 1/4 weeks ± 2% of transfer standard ± 2% of transfer standard ± 4% of transfer standard 80 ml/min 80 ml/min ± 2% of standard ±2 º C of standard ±4 º C of standard ±10 mm Hg ±10 mm Hg 1 min Blanks Field Blanks See 2.12 reference ±30 µg Precision Checks Collocated samples Every 6 days CV 10% Audits (external assessments) FRM PEP Flow Rate Audit External Leak Check Internal Leak Check Temperature Audit Pressure Audit Table 13-2 CFR related quality control checks 8 sites/year 1/3 months 1/3 months If External Leak Check 1/3 months 1/3 months ± 10% ± 4% of audit standard < 25 mm/hg < 140 nnhg ± 2 º C ± 10 mmhg 96

97 14 Procurement of Equipment Prior to purchasing any monitoring instruments, equipment performance is evaluated by the Air Quality Operations and Quality Assurance unit. This may entail queries in regard to the performance, dependability and ease of operation. When items purchased required special performance criteria or certification, the purchase contract states the performance specifications that insure only equipment of the desired quality is obtained, require a one year warranty, and indicate payment not to be made until the equipment has passed an acceptance test. Instruments purchased and evaluated by local agencies must meet performance specifications before data is submitted to the AQS Less expensive items (tools, extension cords, fittings, etc) may be purchased by station operators with approval from their supervisor Maintenance of Equipment The Air Quality Program has developed a preventive maintenance program designed to prevent downtime and costly repairs and data loss. Station operators are responsible for performing routine preventive/corrective maintenance and recorded in the station electronic log book. Preventive maintenance is an ongoing element of quality control and is typically enveloped into the daily routine. Operators are encouraged to check the automatic calibrations to see if the instrument is operating properly In addition to the daily routine, scheduled activities must be performed bi-monthly, monthly, quarterly, semi-annually and annually. Preventive maintenance is the responsibility of the station operators and the supervisory staff. It is important that the supervisor review the preventive maintenance work and continually check the schedule. The supervisor is responsible for making sure that preventive maintenance is being accomplished in a timely manner. Preventive maintenance is not a static process; procedures must be updated for many reasons, including, but not limited to, new models or types of instruments and new or updated methods. The preventive maintenance schedule is changed whenever an activity is completed or performed at an alternate time. For instance, if a multipoint calibration is performed in February instead of on the scheduled date in March, then the subsequent six-month calibration date moves from September to August. On a regular basis, the supervisor should review the preventive maintenance schedule with the station operators. Following all repairs, the instruments must be verified (multi-point) or calibrated. Lists can facilitate the organization and tracking of tasks and improve the efficiency of preventive maintenance operations. A checklist of regular maintenance activities (e.g., periodic zero-span checks, daily routine checks, data dump/collection, calibrations, etc.) is recommended. A spare parts list, including relevant catalog numbers, is also recommended, as 97

98 it facilitates the ordering of replacement parts. Such a list should be readily accessible and should include the types and quantities of spare parts already on hand Station Maintenance Station maintenance is an element of preventive maintenance that does not occur on a routine basis; rather, these tasks usually occur on an as needed basis. Station maintenance items are checked monthly or whenever an agency knows that the maintenance needs to be performed. Examples of station maintenance items include: floor cleaning; shelter inspection; air conditioner repair; AC filter replacement; weed abatement and grass cutting; roof repair; general cleaning; inlet and manifold cleaning; manifold exhaust blower lube; desiccant replacement; and ladder, safety rails, and safety inspection, if applicable. Simple documentation of these activities, whether in station logs or electronic logs, helps provide evidence of continuous attention to data quality Maintenance of Calibration/Audit Standards and Equipment Standards used for the calibration of air monitoring instruments and quality control checks will be maintained within the recommended certification time period. Standards will be maintained within specified accuracy by the Air Quality Program Operations and Quality Assurance Units. The calibration standard is recertified, or recalibrated at the required frequency intervals listed in table EPA Protocol gases are purchased from commercial sources and are analyzed in accordance with "EPA Traceability Protocol for Assay and Certification of Gaseous Calibration Standards" document number EPA-600/R97/121 revised September All mixtures are traceable to the National Institute of Standards and Technology (NIST) gaseous Standard Reference Materials (SRM) using EPA procedures and meet or exceed the appropriate EPA Protocol specifications for accuracy. 98

99 A Certificate of Analysis (COA) is provided with each mixture. The COA contains the replicate analysis data, the NIST traceable reference standard and the analytical instrument used in the analysis. The Air Quality Program does not use any gas for calibration or auditing purposes that has expired certifications. Calibration and Audit Standards Standard Laboratory Frequency Carbon Monoxide cylinders Roots Meter Local Ozone Primary Standard Ultra pure air Multi-blend cylinder gas for Trace Gas Operations Unit Quality Assurance Unit NWRO Operations Unit Quality Assurance Unit Operations Unit Quality Assurance Unit Operations Unit Quality Assurance Unit NWRO QA NWRO 36 months Never Yearly 24 months NIST traceable thermometer (Agency primary) Barometer (Agency primary) QA Unit Operations Unit QA Unit Never Never Table 14-1 Standards maintained in the Air Quality Program laboratory 15 Instrument/Equipment Calibration and Frequency Calibration establishes the quantitative relationship between actual pollutant concentration input (in ppm, ppb, µg/m 3, etc.) and the analyzer's response (output volts, digital output, etc.). This relationship is used to convert subsequent analyzer response values to corresponding pollutant concentrations. The response of most analyzers has a tendency to change somewhat with time (drift) so the calibration must be up dated (or the analyzer's response must be adjusted) 99

100 periodically to maintain a high degree of accuracy. Each analyzer is calibrated as directed by the analyzer's operation or instruction manual. For reference methods for CO, NO 2, and O 3, detailed calibration procedures may also be found in the appropriate appendix to 40 CFR Part 50. Before any sampling is performed, each instrument is calibrated in the Air Quality Program Calibration and Repair Laboratory before it is taken out into the field to collect data. All data and calculations involved in these calibration activities are recorded in a calibration log book (paper or electronic). Routine calibration verifications (automated and manual) are performed on the instruments to assure they are appropriately calibrated. This function is carried out at the field monitoring location Instrumentation calibration verifications Calibration verifications are performed automatically or manually at the monitoring site by allowing the analyzer to sample test atmospheres containing known flows or pollutant concentrations. During the verification the analyzer/sampler is operated in its normal sampling mode and samples the test atmosphere through all filters, scrubbers, conditioners, and other components used during normal ambient sampling and through as much of the ambient air inlet system as is practicable. No adjustment to the instrument is done during the verification process. Automated calibration verifications are initiated at 2 AM (when pollutant concentrations are historically at their lowest) and includes a concentration of zero air and a precision point. 100

101 Zero air is measured by the analyzer for 15 minutes The target concentration is measured by the analyzer for 45 minutes Figure 15-1 Electronic chart of daily zero and precision quality control check Calibration checks are conducted on a routine basis. The analyzer response is recorded by the DAS system, calculated against a target concentration and a status message (valid/invalid) is recorded. Station operators are encouraged to check the status of the calibration Data Reduction Using Calibration Information Daily calibrations are flagged as valid or invalid dependent on daily calibration results. Calibration results are flagged invalid if the sample measured exceeds the Data Quality Measurement objective of the Air Quality Program. If during the daily calibration, the Sample Measured exceeds the Sample Referenced by a concentration greater than 7%. Data is scrutinized and may be invalidated. 101

102 Instrument (Automated) Flagged invalid Bi-Monthly (Manual) Ozone analyzer ± 7% CO analyzer/trace ± 10%/15% SO 2 analyzer trace ± 15% NO y analyzer trace ±15% PM 2.5 FRM PM 10 FRM Monthly (Manual) Nephelometer TEOMS Aethelometer Speciation Sampler Meteorological Yearly Figure 15-2 Frequency of data quality checks 15.3 Calibration Standards All ambient monitoring instruments in the Air Quality Program are calibrated and verified using calibration standards. Cylinders of compressed gas, ozone standards and flows standards are certified as traceable to a NIST primary standard. "Traceable" is defined in 40 CFR Parts and as meaning... that a local standard has been compared and certified, either directly or via not more than one intermediate standard, to a primary standard such as a National Institute of Standards and Technology Standard Reference Material (NIST SRM) or a EPA/NIST-approved Certified Reference Material (CRM). The certification procedure includes: establish the concentration of the working standard relative to the primary standard certify that the primary standard (and hence the working standard) is traceable to an NIST primary standard include a test of the stability of the working standard over several days specify a recertification interval for the working standard Certification of the working standard is established by the Repair/Calibration and QA units. 102

103 15.4 Calibration Standards for Ozone In ambient air monitoring applications, precise ozone concentrations called standards are required for the calibration of ozone analyzers. Ozone standards cannot be stored for any practical length of time due to the reactivity and instability of the gas. Therefore, ozone concentrations must be generated and measured on site. Qualification consists of demonstrating that the transfer standard is sufficiently stable (repeatable) to be useful as a transfer standard. Repeatability is necessary over a range of variables such as temperature, line voltage, barometric pressure, elapsed time, operator adjustments, or other conditions, any of which may be encountered during use of the transfer standard. After a transfer standard has been shown to meet the qualification requirements, certification is required before it can be used. EPA recommends that a transfer standard which remains at a fixed monitoring site be recertified once per quarter if it is sufficiently stable to avoid loss of certification over that time period. The Air Quality Program recertifies transfer standards before the ozone season (May-September). If the analyzer fails an automated calibration, the transfer standard is suspect and may be returned to the calibration laboratory for recertification. Test concentrations of ozone must be traceable to a Level 1 primary standard UV photometer as described in 40 CFR Part 50 Appendix D. Uncertainty increases with additional levels. The NIST Primary Ozone Standard is Located in Reserch Triangle Park (Level 1) 1% uncertainty NIST Primary SRP's are are referenced against Regional SRP's (Level 1) 1% uncertainty Ecology Air Program Level 2 Transfer Standards are verified against SRP #4 on an annual basis. Remains in local laboratory 3% uncertainty Ecology Air Program Level 3 Ozone Transfer Standards are compared/adjusted to match Level 2. Are used in the field. Figure 15-3 Ozone Hierarchy Worst case 5% uncertainty 103

104 15.5 Flow Standards The accuracy of flow measurements is critically important in many calibration procedures. Flow and volume measuring instruments are calibrated and certified at on a yearly basis against a primary flow meter. Those instruments that cannot be certified with the primary flow meter are sent to the manufacturer on a yearly basis for recertification Multi-point Calibration Verifications Multi-point calibrations consist of three or more test concentrations, including zero concentration, a concentration between 80% and 90% of the full scale range of the analyzer under calibration (illustrated in figure 15-4), and one or more intermediate concentrations spaced approximately equally over the scale range. Multi-point calibrations are used to establish or verify the linearity of analyzers upon initial installation, after major repairs and at specified frequencies. Most modern analyzers have a linear or very nearly linear response. Several of the analyzers used by the Air Quality Program have zero and span adjustments, which are adjusted based on the zero and highest test concentrations, respectively, to provide the desired scale range within the analyzer's specifications. For analyzers in routine operation, unadjusted (''as is") analyzer zero and span response readings are obtained prior to making any zero or span adjustments. Figure 15-4 Example of electronic chart and calibration trace After the zero and span adjustments have been completed and the analyzer has been allowed 104

105 to stabilize on the new zero and span settings, all calibration test concentrations should be introduced into the analyzer for the final calibration. The final, post-adjusted analyzer response readings are recorded by the DAS Documentation Documentation includes the date, time, station name, equipment calibrated, type of calibration and technician. A brief description of the results are recorded in the electronic log illustrated in Figure Figure 15-5 Example of electronic log book entry Figure 15-6 Example of an electronic log book entry 105 Figure 15-7 Example of an Electronic Log Book Entry

106 15.8 Physical Zero and Span Adjustments Ambient monitoring instruments have physical means by which to make zero and span adjustments. These adjustments are used to adjust the instruments' response to correct for calibration drift. Zero and span adjustments must always be followed by a calibration and sufficient time between the adjustments and the calibration for the analyzer to fully stabilize. This stabilization time may be substantial for some analyzers. Station operators are advised not to make frequent small zero and span adjustments after each calibration. It is recommended that only when the instrument span value drifts outside a predetermined range (listed in individual procedures) that adjustments be made Frequency of Calibration and Analyzer Adjustment Calibrations normally are 2-point zero and precision calibrations. However, a multi-point calibration can always substitute for a 2-point calibration. An analyzer should be calibrated (or recalibrated); upon initial installation, following physical relocation, after any repairs or service that might affect its calibration, following an interruption in operation of more than a few days, upon any indication of analyzer malfunction or change in calibration, and at some routine interval. Analyzers in routine operation are recalibrated periodically to maintain close agreement between the calibration relationship used to convert analyzer responses to concentration measurements and the actual response of the analyzer. The frequency of this routine periodic recalibration is a matter of judgment and is a tradeoff among several considerations including: the inherent stability of the analyzer under the prevailing conditions of temperature, pressure, line voltage, etc. at the monitoring site, the cost and inconvenience of carrying out the calibrations, the quality of the ambient measurements needed, 106

107 the number of ambient measurements lost during the calibrations, and the risk of collecting invalid data because of a malfunction or response problem with the analyzer that wouldn't be discovered until a calibration is carried out Validation of Ambient Data Based on Calibration Information When zero or span drift validation limits are exceeded, ambient measurements are invalidated back to the most recent point in time where such measurements are known to be valid. Usually this point is the previous calibration (or accuracy audit) unless some other point in time can be identified and related to the probable cause of the excessive drift such as a power failure or malfunction. Also, data following an analyzer malfunction or period of non-operation is regarded as invalid until the next subsequent verification unless unadjusted zero and span readings at that calibration can support its validity. 16 Inspection/Acceptance of Supplies and Consumables Acceptance criteria must be consistent with overall project technical and quality criteria. Some of the acceptance criteria are specifically detailed in 40 CFR Parts 50. Other acceptance criteria such as observation of damage due to shipping can only be performed once the equipment has arrived on site. Program employees who ordered supplies or consumables will be contacted by shipping and receiving personnel located within headquarters or regional offices. The employee receiving the items will perform a rudimentary inspection of the packages as they are received from the shipping and receiving personnel. Note any obvious problems with a receiving shipment such as crushed box or wet cardboard. The package is opened, inspected and contents compared against the packing slip. If there is a problem with the supplies or equipment, note it on the packing list, notify the supervisor of the receiving area and immediately call the vendor. If the supplies appear to be complete and in good condition, sign and date the packing list and send to accounts payable so that payment can be made in a timely manner. Stock equipment/supplies in an appropriate predetermined area. A list of supplies is posted on the cupboard door or shelf tracking the number of items received and used so that new items can be ordered in time for their use. All O 3, SO 2, CO and NO y analyzers used in this network are designated federal equivalent methods (FEM) that have been certified as such by U.S. EPA. Therefore, they are assumed to be of sufficient quality for the data collection operation. Testing of such equipment is accomplished by U.S. EPA through the procedures described in 40 CFR Part 50. The Air 107

108 Quality Program Calibration and Repair Unit will perform multi-point verification checks before the instrument is deployed to measure ambient air. If any of these checks are out of specification (the MQO is all points lying within ±2% of full scale of a best-fit straight line), corrective action will be taken. If the analyzer instrument meets the acceptance criteria, it will be assumed to be operating properly. These tests will be properly documented Particulate Sampling Filters Filters are used for the manual methods for criteria pollutants (e.g., PM10, PM2.5, PM10-2.5, total PM). EPA Headquarters has national contracts for acceptable filters that will be supplied to monitoring organizations. Some of the basic criteria that must be met regardless of the filter type follows: Visual inspection for pinholes, tears, creases, or other flaws that may affect the collection efficiency of the filter which may be consistent through a batch. This visual inspection would also be made prior to filter installation and during laboratory pre- and post-weighings to assure the integrity of the filter is maintained and, therefore, the ambient air sample obtained with each filter adequately represents the sampled pollutant conditions. Collection efficiency - Greater than 99% as measured by DOP test (ASTM 2988) with 0.3 micrometer particles at the sampler s operating face velocity. Integrity - (pollutant specific) Measured as the concentration equivalent corresponding to the difference between the initial and final weights of the filter when weighed and handled under simulated sampling conditions (equilibration, initial weighing, placement on inoperative sampler, removal from a sampler, re-equilibration, and final weighing). 17 Non-direct Measurements Non direct measurements are also called 'existing data'. They are data or information that is used but have not been directly generated by an Air Quality Program project. Several agencies perform additional monitoring within the State but do not submit it to the AQS. This data can alert the MAC of potential air quality issues. 108

109 17.1 Chemical and Physical Properties Data Chemical and physical properties data and conversion constants are often required in the processing of raw data into reporting units. This type of information that has not already been specified in the monitoring regulations will be obtained from nationally and internationally recognized sources. The following sources may be used in the Air Monitoring Program without extensive review of their QC requirements: National Institute of Standards and Technology (NIST) International Organization for Standardization (IOS), International Union of Pure and Applied Chemistry (IUPAC), American National Standards Institute (ANSI), and other widely recognized national and international standards organizations United States Environmental Agency (EPA) The current edition of standards handbooks may be used without prior approval 17.2 Geographic Location For identifying the location of sampling sites, conventional longitude and latitude coordinates, or Universal Transverse Mercator (UTM) will be reported using World Geodetic System 1984 (WGS 84) Historical Monitoring Information Historical monitoring data and summary information derived from previous data may be used in conjunction with current monitoring results to calculate and report trends in pollutant concentrations. In calculating historical trends, historical data is verified to assure that it is comparable to current monitoring data. When different methodologies are used to gather the historical data, the biases and other inaccuracies are described in trends reports based on that data Meteorological Data from Other Sources In addition to data collected from Air Quality Program meteorological sites, meteorological data are gathered from other sources such as the U.S. Weather Service, National Climate Data Center, and other Regional Climate Centers are used to provide information required when developing monitoring sites, computing corrections needed to convert form standard conditions to local conditions, and to support analysis and modeling efforts. 109

110 18 Data Acquisition and Information Management The success of the Air Quality Program objectives relies on data and its correct interpretation. It is critical that data be available to users and that these data are: reliable, of known quality, easily accessible to a variety of users; and aggregated in a manner consistent for prime use 18.1 Envitech Ltd. Environmental Data Management Systems Ecology monitoring stations, established to provide continuous measurements, use a data acquisition and control unit to control sample and calibration systems, log data values and determine data quality measurements such as calibration results. Envitech provides a PC-based Environmental Data Acquisition System EnviDAS for Windows. EnviDAS provides data collection, analysis, archiving and reporting. The software components are: Envista ARM database implemented in Microsoft SQL Server or Oracle, Network manager Setup to create and manage the Envista ARM database, Evista Air Resources manager data analysis and reporting software, CommCenter communications interface. These components are implemented in a client server environment operating under Microsoft windows. 19 Assessments and Response Actions To evaluate the performance of the Air Quality Program air monitoring network, site audits are conducted by the Air Quality Program Quality Assurance Unit on a routine basis and by an independent contractor coordinated through EPA Region 10 and the Office of Air Quality Planning and Standards. 110

111 Figure 19-1 Washington Air Monitoring electronic data flow chart 111

112 19.1 Air Quality Program Multipoint Audits During each calendar quarter, utilizing the procedures and calculations specified in 40 CFR 58, Appendix A, at a minimum the Quality Assurance Unit (QAU) audits SLAMS at least 25% of the sites or instruments quarterly. Continuous Methods Ecology Quality Assurance Multipoint Audit Limits TEOM PM % difference for flow 10% difference for design flow Ozone 7% difference from any audit concentration point Carbon Monoxide 10% difference from any audit concentration point Trace SO 2,CO,NO y 15% difference from any audit concentration point Manual Methods Flow Difference Design Flow Difference Ambient Temp. Diff Filter Temp. Diff Atmospheric Pressure Diff High Volume PM 10 10% 10% N/A N/A N/A Low Volume PM 2.5 4% 5% 2 0 C < 5 ⁰ C lasting no longer than 30 min 10 mmhg Figure 19-2 Ecology performance evaluation limits Multipoint audits are performed on all the O3 analyzers at the beginning and end of each ozone season. A transfer standard from the QAU and the monitoring station's O3 analyzer measure the same ozone concentrations at the same time. The responses of the on-site analyzer are then compared against the output of the transfer standard. The audit ( known ) O3 concentration and the corresponding concentration indicated by the analyzer must be within the 7% multipoint audit limit. If any audit points fall outside these limits, the cause of the failure must be determined. A multipoint audit entails a representative from the QAU physically going to the air monitoring site to make observations on how the site and equipments is being maintained. Audits may be conducted with or without the station operator in attendance. For CO, O 3, and Trace analyzers, the auditor challenges the station analyzer with gas concentrations that follow the Range Restrictions for the Single Point QC Checks listed in 40 CFR Part 58 Appendix A. 112

113 Biweekly Multipoint Audits Checks (PPM) Level 1 (PPM) Level 2 (PPM) Level 3 (PPM) Level 4 (PPM) Level 5 (PPM) CO O (1) (2) (3) NO y Trace SO Trace Figure 19-3 Accuracy Audit Concentration Levels Figure 19-4 Example of electronic chart and instrument response to audit levels Audit results (figure 19-5) are sent to the station operator, Quality Assurance Coordinator/Repair and Calibration Coordinator. Results of the audit are entered into AQS. 113

114 Audit levels must meet the MQO of ± 7 % Auditor inspects station and writes comments Figure 19-5 Continuous Method Audit Report 114

115 19.2 Corrective Action The Data Disposition Request (DDR) is a request for quality control information when data validity is questionable due to an audit failure. The site operator must investigate the cause for the questionable data, document the problem, perform corrective action and respond in writing to the Quality Assurance Coordinator. The Coordinator will make the final decision to accept or delete the data. In the absence of a response from the operator, the questionable data will be invalidated back to the last valid quality control check and future data will be invalidated until it can be shown to meet the Air Quality Program MQO s. Occasionally, audit instruments are damaged during shipment. If there is an audit failure, the auditors is required to confirm the accuracy of audit standards against primary standards located at the Quality Assurance Laboratory in Lacey Percent Valid Data Percent valid data is a gauge of the amount of certified valid data obtained from a monitoring instrument compared to the amount expected under ideal conditions (24 hours per day, 365 days per year). Exceptions are analyzers which had a short term or a seasonal sampling period, and manual method samplers that run every day, every other day, every third day, or every sixth day. The ozone network in Washington State has a required seasonal sampling period of May through September. The completeness of the data (explained in 11.17) is determined for each monitoring instrument, the sampling period and frequency taken into account and the results expressed as a percentage in Table 1. When the 80% certified data objective is not met, the result is highlighted and an explanation given. Data users should be cautious about using incomplete data to make conclusive statements, as violations of the State or National Ambient Air Quality Standards may have occurred during periods of incomplete data. When the sampling period is less than ideal, it is noted. The manual method sampling frequency is noted after the station identification number, such that 1/1, 1/3, 1/6, 1/12 denotes every day, every third day, every sixth day, and every twelfth day sampling frequency, respectively. 115

116 19.4 Independence and EPA Performance Evaluations Monitoring organization receiving funds from EPA are required to conduct independent assessments of their air monitoring networks. Federally implemented programs using State and Tribal Assistance Grant (STAG) funds are provided to those organizations unable to support such programs due to financial or organizational constraints. The Air Quality Program participates in The National Programs are administered Figure 19-6 NPAP Audit Trailer in Seattle by EPA, and supports QA efforts of the Air Quality Program to; determine data comparability and usability across sites, monitoring networks; (Tribes, States, and geographic regions), instruments and laboratories; provide a level of confidence that monitoring systems are operating within an acceptable level of data quality so data users can make decisions with acceptable levels of certainty; help verify the precision and bias estimates performed by monitoring organizations; identify where improvements (technology/training) are needed; assure the public of non-biased assessments of data quality; provide a quantitative mechanism to defend the quality of data; provide information to monitoring organizations on how they compare with the rest of the nation, in relation to the acceptance limits and to assist in corrective actions and/or data improvements Independent Assessment The organizational structure in Figure 19-6 is the minimum EPA requirement for QA independence in an organization. The Air Quality Program organizational structure displayed in Figure 3-1 illustrates the relationship between the Quality Assurance Unit and the routine field sampling. Due to the relationship, the Air Quality Program participates in EPA programs defined in figure Participation in these programs ensures evaluations that are independent, nonbiased and objective. 116

117 Organizational 3rd Level Supervisor Program Manager Organizational 2nd Level Supervisor Section Supervisor Section Supervisor Organizational 1st Level Supervisor Unit Supervisor Unit Supervisor Unit Supervisor Unit Supervisor QA Lab Analysis QA Field Sampling Routine Lab Analyzis Routine Field Sampling Figure 19-7 Minimum EPA requirements for quality assurance independence EPA implements several national performance evaluation programs for all of the ambient air monitoring activities. Table 22-1 provides more information on these activities. It is important that these performance evaluations be independent in order to ensure they are non-biased and objective. With the passage of the Data Quality Act, there is potential for EPA to receive challenges to the quality of the ambient air data. Independent audits help provide another piece of objective evidence on the quality of a monitoring organizations data and can help EPA and the State of Washington defend the quality of the data. Figure 19-8 NPEP auditor at Beacon Hill site 19.6 Adequacy Requirements for the PEP Program The PEP Program is designed to ensure that the National Program achieves the optimum level of accuracy, precision and bias in the required measurement. The PEP Program is required to perform 8 valid audits of the Air Quality Program per year distributed across the 4 quarters. 117

118 100 percent completeness (meaning whatever it takes to get 8 valid samples). All samplers are subject to an audit within 6 years. Data submission to AQS. Trained/certified by EPA to perform audits. Conforming to the important aspects of the federally implemented PEP Field and laboratory SOPs and quality assurance project plan requirements. Incorporation of PEP in the Air Quality Program Quality Assurance Project Plan 19.7 Adequacy Requirements for the NPAP Program The NPAP Program is designed to ensure that the National Program achieves the optimum level of accuracy, precision and bias in the required measurements. Performing audits at 20 percent of monitoring sites within a primary quality assurance each year with a goal of all sites audited in a 5-7 year period. Data submission to AQS. Development of a delivery system that will allow for the audit concentration gas to be introduced to the probe inlet where logistically feasible. Use of audit gas (CO, SO 2, and NO 2 ) that is NIST certified and validated once a year and an ozone generator that is verified quarterly. For national comparability, validation/certification with the EPA NPAP program through collocated auditing, at an acceptable number of sites each year. The comparison tests would have to be no greater than 5 percent different from the EPA NPAP results. Incorporation of NPAP in the Air Quality Program Quality Assurance Project Plan. NPAP OAQPS National Performance Audit Program provides audit standards for the gaseous pollutants either as devices that the site operator connects to the back of the instrument or through the probe in which case the audits are conducted by presenting audit gases through the probe inlet of ambient air monitoring stations. Flow audit devices and lead strips are also provided through NPAP. NPAP audits are required at 20% of a primary quality assurance organization s sites each year with a goal of auditing all sites in 5-7 years

119 SRP ORIA-LV PM2.5 PM PEP OAQPS The Standard Reference Photometer (SRP) Program provides a mechanism to establish traceability among the ozone standards used by monitoring organizations with the National Institute of Standards and Technology (NIST). Every year NIST certifies an EPA SRP. Upon certification, this SRP is shipped to the EPA Regions who use this SRP to certify the SRP that remains stationary in the Regional Lab. These stationary SRPs are then used to certify the ozone transfer standards that are used by the State, Local and Tribal monitoring organizations who bring their transfer standards to the Regional SRP for certification. Performance Evaluation Program. The strategy is to collocate a portable FRM PM2.5 or PM air sampling audit instrument with an established primary sampler at a routine air monitoring site, operate both samplers in the same manner, and then compare the results. Each year five PEP audits are required for primary quality assurance organizations (PQAOs) with less than or equal to 5 monitoring sites or eight audits are required for PQAOs with greater than five sites. These audits are not required for PM10 STN/IMPROVE Round Robins PTs and Audits ORIA-AL Pm 2.5 Speciation trends Network (STN) and IMPROVE round robins are a type of performance evaluation where the audit samples are developed in ambient air; therefore, the true concentration is unknown. The audit is performed by collecting samples over multiple days and from multiple samplers. These representative samples are then characterized by the ORIA lab and sent to the routine sample laboratories for analysis. In addition ORIA implements technical systems audits of IMPROVE and STN laboratories. Protocol Gas OAQPS EPA Protocol Gases are used in quality control activities (i.e. calibrations, audits, etc.) to ensure the quality of data derived from ambient air monitors used by every state in the country. The program is presently undergoing re-structuring with NIST performing the audit analysis function. An implementation plan has been developed to define the operations of the program and is currently under internal review. Figure 19-9 Performance evaluations in which the Air Quality Program participates Performance evaluations are a type of audit in which the quantitative data generated in a measurement system are obtained independently and compared with routinely obtained data to evaluate the proficiency of an analyst or laboratory. They may involve side-by-side intercomparisons of concentrations or flow rate. In general, the difference between the parameter from your instrument is compared against the parameter from the auditor's instrument and a statistic such as relative percent difference is calculated. A performance evaluation is a quantitative comparison of results between Ecology's equipment and equipment calibrated by another primary standard. This is done through the EPA regional office in the form of participation in the National Performance Audit Program (NPAP). Successful participation requires an agreement of less than 10% between the auditor s equipment and Ecology's equipment. This Air Quality Program will participate in NPAP as arranged and agreed to with the EPA regional office. 119

120 19.8 Technical Systems Audits A technical system audit is a thorough systematic, on-site, qualitative audit of facilities, equipment, personnel, training, procedures, record keeping, data validation, data management, and reporting aspects of the Air Quality Program monitoring system. Technical systems audits are ideally conducted by EPA Region 10 at least once every three years Data Quality Assessments Data quality assessments are statistical and scientific evaluations of the data set to determine the validity and performance of the data collection design and statistical test, and to determine the adequacy of the data set for its intended use. Original data will always be kept and archived with a note in a header or title or flag indicating that it contains data that should not be used. 20 Reports to Management The Quality Assurance Coordinator is responsible for conducting an ongoing review of the data. The field data sheets, computer files, and final reports will be assessed to make sure that the results have not been transcribed incorrectly and that any calculations can be reproduced with the same result. Any data that is found to contain errors is described in the quarterly Air Monitoring Data Quality Assessment Report to management. The quarterly report describes data completeness. The report is to alert the AQLT, local agencies and station operators of data quality problems, to propose viable solutions to problems and to procure necessary additional resources. The Air Quality Program Quality Assurance Coordinator to responsible to clearly communicating the measurement goals of the Air Quality Program to agencies submitting data through the Air Quality Program for submittal to the AQS. The Quality Assurance Coordinator provides quarterly reports to participating agencies detailing Measurement Quality Objectives (MQOs) results for the quarter. 120

121 21 AQS DATA SUMMARY REPORT The Air Quality Programs sampling program includes the regular collection of data quality indicators which is reported to the Air Quality System (AQS) database for the criteria pollutants (CO, O 3, PM 2.5, PM 10, Pb). The Air Quality Program also submits data quality indicators for the trace gas instruments (CO, SO 2, NO y ) The Air Quality Program sends two types of quality assurance data regularly reported in AQS for the gaseous pollutants. The first is referred to as single point QC check data. The data is generated by challenging the station analyzer with samples of known concentrations of the pollutants. For O 3 the quality control checks are done every other day and the CO is performed at least once every two weeks. The second type of quality assurance data reported for the gaseous pollutants is the performance evaluation (PE) data (formerly called the annual accuracy data). A predetermined number of SLAMS, and NAMS (and eventually NCore) monitors are required to have a performance evaluation check once a year. These data are similar to the precision checks, but with more rigorous requirements such as traceability of the concentration of the known gas. These data are collected less frequently (annually), but are collected at multiple concentration levels. Quality assurance data for PM 2.5 is comprised of collocated precision checks and quarterly flow rate audits. The collocated precision checks are required to be performed every twelve days on 15 percent of the Air Quality Program s SLAMS and/or NAMS monitors. Flow rate audits are performed each quarter at all PM 2.5 FRM sites. In 2009, the Air Quality Program reported 10 PM 2.5 FRM sites to the AQS. EPA reports on past PM 2.5 performance can be found at For PM 10, the quality indicator data are broken down into automated and manual method types. Automated methods are identified by the recording mode continuous, while manual methods are identified by the recording mode intermittent. For the automated samplers, the precision completeness is based on the flow rate verification checks that are required to be performed monthly. The precision of manual PM 10 samplers is based on collocated sampler data that are required to be collected once every six days. For both types of recording modes, accuracy is based on the annual flow rate audit that is required to be performed on 25 percent of the sites within the network each quarter such that all sites are checked at least once a year. In 2009, the Air Quality Program reported 3 PM 10 sites to the AQS. Three types of quality indicator data are supposed to be collected for lead. Precision data comes from collocated sampler data and bias data comes from two types of data. The first type 121

122 of bias data are annual flow rate audits that are required to be performed on 25 percent of the sites each quarter such that all sites are checked at least once a year. The second type are performance evaluations using filter strips (2 levels 3 strips = 6 total strips) that are required to be performed by the site s laboratory each quarter that lead samples are analyzed. The Air Quality Program currently does not monitor for lead but may in the near future. EPA s Air Quality Assessment Division distributes an annual report, Criteria Pollutant Quality Indicator Summary Report for AQS Data Report for each year which summarizes the completeness of the types of data described above based on data downloaded from AQS. Precision and bias summaries are also generated for the gaseous pollutants. Additionally, precision summaries are included for the collocated PM 10 and PM 2.5. The data for all pollutants are summarized at both the site and the agency level. The number of required checks is based on the number of weeks between the start and end dates. If there is a season for monitoring (e.g., O 3 ), then the appropriate season is used for the monitors and the required number of checks calculated by the season Single Point Precision and Bias Graphics To provide decision makers with data of adequate quality, OAQPS uses the DQO process to determine data quality needs for the ambient air criteria pollutants. There are some data quality indicators, such as precision, bias, and completeness that directly effects the attainment of the DQOs. These variables need to be in certain acceptable ranges (called measurement quality objectives) in order for OAQPS to make decisions (like comparison with the NAAQS) with specified levels of confidence. 40 CFR Part 58 Appendix A provides the minimum requirements for the collection and reporting of data to assess the data quality indicators of precision, bias, and completeness. On an annual basis, the Air Measurements and Quality Group (AMQG) develop summary reports on these data quality indicators. Estimates of both bias and precision for the four automated gaseous methods (CO, SO 2, NO 2, and O 3 ) are derived from the one-point QC (formerly called precision) checks Air Quality System AMP255 Summary Report The AMP255-P/A Quality Indicator Summary Report in AQS summarizes precision, bias, and completeness of the required QC data for each criteria pollutant. The data tables may be generated at any time within the AQS application using the standard reports. More details can be accessed at 122

123 Figure 21-1 Example of AMP255 summary report 22 Data Review, Verification, and Validation Data review, verification and validation are techniques used to accept, reject or qualify data in an objective and consistent manner. Verification can be defined as confirmation, through provision of objective evidence that specified requirements have been fulfilled. Validation can be defined as confirmation through provision of objective evidence that the particular requirements for a specific intended use are fulfilled. It is important to describe the criteria for deciding the degree to which each data item has met its quality specifications as described in an organization s QAPP. This section will describe the techniques used to make these assessments. In general, these assessment activities are performed by the station operator as well as by personnel independent of the operation, such as the Air Quality Program QA personnel and at some specified frequency. Sampling Design - How closely a measurement represents the actual environment at a given time and location is a complex issue that is considered during development of the sampling design. Each sample should be checked for conformity to the specifications, including type and 123

124 location (spatial and temporal). By noting the deviations in sufficient detail, subsequent data users will be able to determine the data s usability under scenarios different from those included in project planning. Sample Collection Procedures- Details of how a sample is separated from its native time/space location are important for properly interpreting the measurement results. Sampling methods and field SOPs provide these details, which include sampling and ancillary equipment and procedures. Acceptable departures (for example, alternate equipment) from the QAPP, and the action to be taken if the requirements cannot be satisfied, should be specified for each critical aspect. Validation activities should note potentially unacceptable departures from the QAPP. Comments from field surveillance on deviations from written sampling plans also should be noted. Sample Handling- Details of how a sample is physically treated and handled during relocation from its original site to the actual measurement site are extremely important. Correct interpretation of the subsequent measurement results requires that deviations from the sample handling section of the QAPP and the actions taken to minimize or control the changes, be detailed. Data collection activities should indicate events that occur during sample handling that may affect the integrity of the samples. At a minimum, investigators should evaluate the sample containers and the preservation methods used and ensure that they are appropriate to the nature of the sample and the type of data generated from the sample. Checks on the identity of the sample (e.g., proper labeling and chain of custody records) as well as proper physical/chemical storage conditions (e.g., chain of custody and storage records) should be made to ensure that the sample continues to be representative of its native environment as it moves through the analytical process Data Review Methods The flow of data from the field environmental data operations to the storage in the database requires several distinct and separate steps; initial selection of hardware and software for the acquisition, storage, retrieval and transmittal of data; organization and the control of the data flow from the field sites and the analytical laboratory input and validation of the data manipulation, analysis and archival of the data submittal of the data into the EPA s AQS database. 124

125 Both manual and computer-oriented systems require individual reviews of all data tabulations. The purpose of manual inspection is to spot unusually high (or low) values (outliers) that might indicate a gross error in the data collection system. In order to recognize that the reported concentration of a given pollutant is extreme, the individual must have basic knowledge of the major pollutants and of air quality conditions prevalent at the reporting station. Data values considered questionable should be flagged for verification. This scanning for high/low values is sensitive to spurious extreme values but not to intermediate values that could also be grossly in error. Operators and QA personnel check hourly minimum and maximum concentration for outliers. Figure 22-1 Example of a tabular electronic station report Manual review of data tabulations also allows detection of uncorrected drift in the zero baseline of a continuous sensor. Zero drift may be indicated when the daily minimum concentration tends to increase or decrease from the norm over a period of several days. For example, at most sampling stations, the early morning (2:00 a.m. to 3:00 a.m.) concentrations of ozone tend to reach a minimum. If the minimum concentration differs significantly from this, a zero drift may be suspected. Zero drift could be confirmed by review of the station one minute averages in the DAS electronic report. In an automated data processing system, procedures for data validation can easily be incorporated into the basic software. The computer can be programmed to scan data values for extreme values, outliers or ranges. 125

126 22.2 Data Verification Methods Verification can be defined as confirmation, through provision of objective evidence that specified requirements have been fulfilled. The data verification process involves the inspection, analysis, and acceptance of the field data or samples. These inspections can take the form of technical systems audits (internal or external) or frequent inspections by field operators and lab technicians. Questions that might be asked during the verification process include: Were the environmental data operations performed according to the SOP s governing those operations? Were the environmental data operations performed on the correct time and date originally specified? Many environmental operations must be performed within a specific time frame; for example, the NAAQS samples for particulates are collected once every six days from midnight to midnight. The monitor timing mechanisms must have operated correctly for the sample to be collected within the time frame specified. Did the sampler or monitor perform correctly? Individual checks such as leak checks, flow checks, meteorological influences, and all other assessments, audits, and performance checks must have been acceptably performed and documented. Did the environmental sample pass an initial visual inspection? Many environmental samples can be flagged (qualified) during the initial visual inspection. Have manual calculations, manual data entry, or human adjustments to software settings been checked? Automated calculations should be verified and accepted prior to use, but at some frequencies these calculations should be reviewed to ensure that they have not changed. Were the environmental data operations performed to meet data quality objectives designed for those specific data operations and were the operations performed as specified? The objectives for environmental data operations must be clear and understood by all those involved with the data collection Data Validation Methods Data validation is a routine process designed to ensure that reported values meet the quality goals of the Air Quality Program. Data validation is further defined as examination and provision of objective evidence that the particular requirements for a specific intended use are fulfilled. A progressive, systematic approach to data validation must be used to ensure and assess the quality of data. The purpose of data validation is to detect and then verify any data values that may not represent actual air quality conditions at the sampling station. Effective data validation procedures usually are handled completely independently from the procedures of 126

127 initial data collection. Because the computer can perform computations and make comparisons extremely rapidly, it can also make some determination concerning the validity of data values that are not necessarily high or low. Certain criteria, based upon CFR and field operator and laboratory technician judgment, may be used to invalidate a sample or measurement. These criteria should be explicitly identified in the organizations QAPP. The Air Quality Program relies on flags or result qualifiers to identify potential problems with data or a sample. A flag is an indicator of the fact and the reason that a data value (a) did not produce a numeric result, (b) produced a numeric result but it is qualified in some respect relating to the type or validity of the result, or (c) produced a numeric result but for administrative reasons is not to be reported outside the organization. Flags can be used both in the field and in the laboratory to signify data that may be suspect due to contamination, special events or failure of QC limits. Flags can be used to determine if individual samples (data), or samples from a particular instrument, will be invalidated. In all cases, the sample (data) should be thoroughly reviewed by the organization prior to any invalidation Automated Methods When zero, span or one-point QC checks exceed acceptance limits, ambient measurements are invalidated back to the most recent point in time where such measurements are known to be valid. Usually this point is the previous check, unless some other point in time can be identified and related to the probable cause of the excessive drift or exceedance (such as a power failure or malfunction). Also, data following an analyzer malfunction or period of non-operation is regarded as invalid until the next subsequent (level 1) acceptable check or calibration. Data is invalidated if the room temperature exceeds the temperature the instrument is designed to operate at optimum. These temperatures are listed in the individual instrument procedures Manual Methods For manual methods, the first level of data validation is to accept or reject monitoring data based upon results from operational checks selected to monitor the critical parameters in all three major and distinct phases of manual methods--sampling, analysis, and data reduction. In addition to using operational checks for data validation, the user must observe all limitations, acceptance limits, and warnings described in the reference and equivalent methods per se that may invalidate data. It is further recommended that results from performance audits/evaluations 127

128 required in 40 CFR 58 Appendix A not be used as the sole criteria for data invalidation because these checks (performance audits) are intended to assess the quality of the data Validation Templates In June 1998, a workgroup was formed to develop a procedure for monitoring organizations that would provide for a consistent validation of PM2.5 mass concentrations across the United States. The Workgroup developed three tables of criteria where each table has a different degree of implication about the quality of the data. The criteria included on the tables are from 40 CFR The Air Quality Program uses the validation templates during the validation process with include requirements found in Part 50 Appendices L and N, 40 CFR Part 58 Appendix A, Method 2.12, and a few criteria that are neither in CFR nor Method Verification and Validation Methods The Air Quality Program Quality Assurance Unit verifies and validates data collection and operations. Verification is confirmed by examination and provision of objective evidence that specified requirements have been fulfilled. Earlier elements of this QAPP describe in detail how the activities in these data collection phases are implemented to meet the data quality objectives of the program. Review and approval of this QAPP by the personnel listed on the approval page provide initial agreement that the processes described in the QAPP, if implemented, will provide data of adequate quality. In order to verify and validate the phases of the data collection operation, the Air Quality Program uses qualitative assessments (e.g. technical systems audits, network reviews) to verify that the QAPP is being followed, and relies on the various quality control samples, inserted at various phases of the data collection operation, to validate that the data will meet the DQOs Sampling Design The ambient air data is used to evaluate the adequacy of the sampling design. By continuously reviewing the data and whether it is consistent with the objectives of the network, the Air Quality Program can determine whether monitors should be relocated, new monitors or monitor types purchased, etc. This information is included in network review documentation. 128

129 22.9 Data Collection Procedures The use of QC checks throughout the measurement process helps validate the activities occurring at each phase. The review of QC data such as the precision data, the performance evaluation, and the equipment verification checks that are described in Section 14 are used to validate these activities. 23 Quality Improvement The main goal of the reconciliation with user requirements is to determine whether or not the Air Quality Program has achieved the goals it set out to achieve in its data quality objectives (DQOs) and measurement quality objectives (MQOs). The data used in decisions on attainment or non-attainment of the NAAQS are never error free and will always contain some level of uncertainty. Because of these uncertainties or errors, there is a possibility that the Air Quality Program may declare an area "nonattainment" when the area is actually in "attainment" (false positive error) or "attainment" when the area is actually in "nonattainment" (false positive error). There can be serious political, economic and health consequences of making such decision errors. Therefore, Air Quality Program understands and set limits on the probabilities of making incorrect decisions with these data. In order to set probability limits on decision errors, the Air Quality Program needs to understand and control uncertainty. Uncertainty is used as a generic term to describe the sum of all sources of error associated with a measurement result Annual Quality System Report The Washington State Department of Ecology is required to produce a quality system report, as specified in the agency s QMP. The quality system is a structured and documented management system that provides the framework for planning, implementing, documenting, and assessing environmental data operations, as well as for carrying out required quality assurance and quality control activities. The quality system encompasses both management and technical activities, and it requires the active participation of all employees. The intended audience for this report is the agency s deputy director, executive management team, and other interested parties. 129

130 Appendix A Measurement Quality Objectives and Validation Templates In June 1998, a workgroup was formed to develop a procedure that could be used by State and locals that would provide for a consistent validation of PM2.5 mass concentrations across the United States. The workgroup included personnel from the monitoring organizations, EPA Regional Offices, and OAQPS who are involved with assuring the quality of PM2.5 mass and was headed by a State and local representative. The workgroup developed three tables of criteria where each table has a different degree of implication about the quality of the data. The criteria included on the tables are from 40 CFR Part 50 Appendices L and N, 40 CFR Part 58 Appendix A, Method 2.12, and a few criteria that are neither in CFR nor Method 2.12 but included in the validation templates as recommendations. Upon completion and use of the table, it was decided that a validation template should be developed for all the criteria pollutants. One of the tables has the criteria that must be met to ensure the quality of the data. An example criterion is that the average flow rate for the sampling period must be maintained to within 5% of liters per minute. The second table has the criteria that indicate that there might be a problem with the quality of the data and further investigation is warranted before making a determination about the validity of the sample or samples. An example criterion is that the field filter blanks should not change weight by more than 30µg between weighings. The third table has criteria that indicate a potentially systematic problem with the environmental data collection activity. Such systematic problems may impact the ability to make decisions with the data. An example criterion is that at least 75% of the scheduled samples for each quarter should be successfully collected and validated. To determine the appropriate table for each criterion, the members of the workgroup considered how significantly the criterion impacts the resulting concentration. This was based on experience from workgroup members, experience from non-workgroup members, and feasibility of implementing the criterion. Criteria that were deemed critical to maintaining the integrity of a sample or group of samples were placed on the first table. Observations that do not meet each and every criterion on the Critical Criteria Table should be invalidated unless there are compelling reason and justification for not doing so. Basically, the sample or group of samples for which one or more of these criteria are not met is invalid until proven otherwise. The cause of not operating in the acceptable range for each of the violated criteria must be investigated and minimized to reduce 130

131 the likelihood that additional samples will be invalidated. Criteria that is important for maintaining and evaluating the quality of the data collection system is included on the second table, the Operational Evaluations Table. Violation of a criterion or a number of criteria may be cause for invalidation. The decision should consider other quality control information that may or may not indicate the data are acceptable for the parameter being controlled. Therefore, the sample or group of samples for which one or more of these criteria are not met is suspect unless other quality control information demonstrates otherwise. The reason for not meeting the criteria MUST be investigated, mitigated or justified. Finally, those criteria which are important for the correct interpretation of the data but do not usually impact the validity of a sample or group of samples are included on the third table, the Systematic Issues Table. For example, the data quality objectives are included in this table. If the data quality objectives are not met, this does not invalidate any of the samples but it may impact the error rate associated with the attainment/non-attainment decision. Following are the tables. For each criterion, the tables include the operational range that is acceptable, the frequency with which compliance is to be evaluated, the number of samples that are impacted if violation of a criterion occurs (possible values include single filters, a batch of filters, or a group of filters from a specific instrument), sections of 40 CFR and Method 2.12 that describe the criterion. The table also indicates whether samples violating the criteria must be flagged before entering them into AQS. 131

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