The Measuring Sticks of Air Monitoring
Guest Speaker:
Jeremy Howe
Little River Band Of Ottawa Indians
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April 7: QA Systems, EPA definitions, PQAOs and
common sense – Mike Papp
April 14: Routine Quality Control and Data
Management (1-pt QC, flow rate, and instrument
stability checks) – Travis Maki
April 21: Audits Overview (NPAP, PEP, Annual PE, Flow
Rate Audits) – Jeremy Howe
April 28: Calculating Bias and Precision and AQS
reports – Bill Frietsche
May 5: 40 CFR 58 App. A- Gaseous Pollutants – Glenn
Gehring
May 12: 40 CFR 58 App. A- Ozone – Brenda Jarrell
May 19: 40 CFR 58 App. A- PM filter and continuous
methods –Brandy Toft
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Audit – “a systematic and independent
examination to determine whether quality
activities and related results comply with
planned arrangements and whether these
arrangements are implemented effectively
and are suitable to achieve objectives”
Independent means using a device other than
the one you use routinely at a minimum, and
in some cases a completely independent
system of instrument and operator
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 Basically
compare
◦ What is actually being done in the
field and the office
◦ Against what is stated in the QAPP
and SOPs
◦ Are done by you or someone
outside your office, depending on
the type of audit
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Number and types of assessments
 People or organizations doing the
assessments
 Schedule
 Criteria for assessments (we will
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compare what we do against the SOP or
QAPP)
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Reporting and responsibility for
follow-up (e.g., we will revise the SOP in
pen for now, and retype it with changes
within a month)
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Program: CLOSE THE LOOP
(fix problems and take action to make sure
they do not happen again)
And make sure it is documented
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1. Six-month flow rate audits you make with
non-routine standards (PM)
2. Annual Performance Evaluations (gas)
3. NPAP and PEP audits conducted by
certified auditors
4. Technical Systems Audits conducted by
EPA regions (every 3 years)
To see how many/often of the 1st three types
you need for NAAQS-comparable data, see
Calculations for Tribes Interested in Joining a Tribal
PQAO - 2011-02-08A.xls
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Method
Pollutants
Frequency
MQO
One-Point QC
SO2, NO2, O3, CO
Every 2
Weeks
O3 :
Precision = 7%
Bias = 7%
SO2, NO2, CO :
Precision = 10%
Bias = 10%
Annual Performance
Evaluation (Audit)
SO2, NO2, O3, CO
Once per Year
<= 15% for each audit concentration
Flow Rate Verification
(QC check)
PM10 (lo-Vol),
PM2.5
Once every 4
weeks
<= 4% of Standard & 5% of Design Value
Flow Rate Verification
(QC check)
PM10 (high-Vol),
TSP
Once per
quarter
<= 7% of Standard & 10% of Design Value
Semi-Annual Flow Rate
Audit
PM10, PM2.5
Every 6
Months
<= 4% of Standard & 5% of Design Value
Semi-Annual Flow Rate
Audit
PM10 (high-Vol),
TSP
Every 6
Months
<= 10% of Standard & 10% of Design Value
Collocated Sampling
PM10, TSP, PM2.5
15% of
Network Every
12 Days
PM2.5, TSP, PM10 :
Precision = 10%
PM2.5 PEP Program
NPAP
PM2.5
SO2, NO2, O3, CO
Quarter *!
Year (see
Calculations…
spreadsheet)
Bias = 10%
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Method
Pollutants
Frequency
Who? With What?
One-Point QC
SO2, NO2, O3,
CO
Every 2 Weeks
Site operator
Annual
Performance
Evaluation
SO2, NO2, O3,
CO
Once per Year
Preferably not site operator, no
national certification required, not the
same standard that is used for routine
QC checks
Flow Rate
Verification (not
required to be
reported to AQS)
PM10, PM2.5
Every 4 weeks
Can be site operator, no national
certification required, not the same
standards that are used to calibrate
your analyzer
Semi-Annual
Flow Rate Audit
PM10, PM2.5
Every 6 Months
Preferably not site operator, no national
certification required, not the same
standards that are used for monthly QC
checks
PM PEP, NPAP
PM2.5,
All gaseous
See
OAQPS/TAMS
certified auditor
Calculations…sprea
dsheet
Annual calibration
standard, owned by
tribe
OAQPS/TAMS
equipment
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Flow Rate
Verification
PM10, PM2.5
Flow Rate
Verification
PM10
(high-Vol),
TSP
Every 4 weeks
automated and
manual
Can be site operator, no national
certification required, the flow rate
standard used must be certified
annually
Once per
quarter
manual
Semi-Annual Flow
Rate Audit
PM10, PM2.5
automated and
manual
Every 6 Months Preferably not site operator, no
national certification required, not
the same standards that are used to
calibrate the analyzer, but can be
calibrated to the same primary stnd
as your cal stnd
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Discussed in more detail in PM webinar
Rely on owner’s manuals
EPA guidance available:
2.12 "Monitoring PM2.5 in Ambient Air Using
Designated Reference or Class I Equivalent
Methods" 1998
http://www.epa.gov/ttn/amtic/files/ambient
/pm25/qa/m212covd.pdf
See docs in course webpage and AMTIC and
CARB SOPs
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check the operational flow rate of the
analyzer, before any flow rate adjustment
Randomize the time and day
Use a flow rate transfer standard certified to
be traceable to an authoritative volume or
other applicable standard (within 2% of NIST –
Traceable Standard Part 50, App L Sec 9.2)
Reported to AQS as RA (bias) because it is
made with a non-routine standard (the ones
with your routine stnd are precision (RP)
%
diff =[ (meas-audit)/audit ]*100
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3.2.2 Annual performance evaluation for SO2,
NO2, O3, or CO
…The gas standards and equipment used for
evaluations must not be the same as the
standards and equipment used for calibration
or calibration span adjustments…the auditor
should not be the operator or analyst who
conducts the routine monitoring, calibration,
and analysis.
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40 CFR 58 App A sec 3.2.2:
If there are fewer than four analyzers for a
pollutant within a PQAO, P.E. annually
(preferably in different quarters)
The evaluation should be conducted by a
trained experienced technician other than the
routine site operator
Current CFR guidance will change soon
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use…audit gas from at least three
consecutive audit levels. The audit levels
selected should represent or bracket 80
percent of ambient concentrations measured
by the analyzer being evaluated:
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New guidance for audit levels:
Ten levels, the lowest as low as 4-6 ppb for
O3
Consecutive audit levels no longer required
See memo:
http://itep68.itep.nau.edu/itep_downloads/Q
A101_Resources/EPA%20guidance%20and%20
other%20reference%20material/TechMemofor
PEAuditLevels.pdf
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3.2.2…Report both the audit and measured
concentration
The % differences (di ) between these
concentrations are used to assess the quality
of the monitoring data, and to confirm your
biweekly QC check results:
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Allow…the audit gas to pass through all
filters, scrubbers, conditioners, and other
sample inlet components used during
normal ambient sampling and as much of
the ambient air inlet system as is
practicable
< 15 % for each audit concentration, and
EPA uses these (RA) values you report to
AQS to generate probability limits for your
bias
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2.4 National Performance Evaluation Programs.
….the consent of the monitoring organization for
EPA to apply an appropriate portion of the grant
funds, which EPA would otherwise award to the
monitoring organization for monitoring activities,
will be deemed by EPA to meet this requirement.
For clarification and to participate, monitoring
organizations should contact either the
appropriate EPA Regional Quality Assurance (QA)
Coordinator…
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PEP- $2000/audit
◦ 5 audits/yr for PQAO with < 5 sites = 10K/year
◦ All sites audited at least once every 6 years
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NPAP- $2200/audit
◦ Each site audited at least once every 5 yrs
◦ At least 1 NPAP audit per PQAO network that
includes even 1 gas analyzer
◦ Would need 10 sites for 2 audits a year
◦ Each NPAP audit covers all gas analyzers at a site
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These (rough) costs are for EPA contractors
doing the audits
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Auditors (including tribal folks) can take
training and exam
Equipment must be approved/provided as
audit-specific equipment
SOPs available on AMTIC,
http://www.epa.gov/ttn/amtic/npepqa.html
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• Separate from Cradle to Grave
• For Gaseous Pollutants
• O3 + CO + SO2 + NOX
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• Separate from Cradle to Grave
• For Filter Based Pollutants
• PM 2.5 + Lead
PEP Audit
Collocation
PEP
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2.5 Technical Systems Audit Program. Technical
systems audits of each ambient air monitoring
organization shall be conducted at least every 3
years by your EPA regional office
Review of siting, documentation, procedures’
implementation
Assessment of whether the “QA function is
independent”
Checklists that the region will use are available as
QA Handbook Volume II, Appendix H
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At least 3 months notice, with written
audit plan
 Checklist sent ahead of time, see
NAAM Technical Systems Audit Form
in:
http://itep68.itep.nau.edu/itep_downl
oads/QA101_Resources/EPA%20guida
nce%20and%20other%20reference%20
material/
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All audits are “friendly” and intended to
improve the quality of the data
Findings will always include insufficient
documentation
Site visits are included
Some AQS data are pulled, then records of all
the QC and original data are looked for in
office
Important for small organizations: the
“independency of the QA function”
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CFR App. A: 2.2 …a quality assurance
management function…includes strategic
planning, allocation of resources and …assessing
and reporting…
must have sufficient technical expertise and
management authority to conduct independent
oversight…
should be organizationally independent of
environmental data generation activities (e.g.,
NOT the site operator or their manager)
Ideal QA manager is described at:
http://www.epa.gov/ttn/amtic/files/ambient/mo
nitorstrat/qamroles2.pdf
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Adds necessary quantitative and qualitative
(TSAs) yardsticks for data defensibility
Adds value by exchanging information
Course website:
http://itep68.itep.nau.edu/itep_downloads/
QA101_Resources/
Consider joining the TAMS Steering
Committee to help develop national tribal
training to address these complicated issues
(email us)
◦ Jeremy Howe: jhowe@lrboi.com
◦ Melinda.ronca-battista@nau.edu
◦ Christopher.lee@nau.edu
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