vvEPA
United States     Environmental Monitoring and Systems EPA-600/4-83-023
Environmental Protection Laboratory           June 1983
Agency        Research Triangle Park NC 27711
Research and Development
Guideline on  the
Meaning and Use of
Precision and Accuracy
Data Required by
40 CFR Part  58,
Appendices A and  B

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                                               EPA-600/4-63-023
                                               June  1933
GUIDELINE ON THE MEANING AND USE OF PRECISION AND  ACCURACY
    DATA REQUIRED BY 40 CFR PART 58, APPENDICES A AND  B
                            by
                   Raymond C. Rhodes
               Quality Assurance Division
     Environmental  Monitoring Systems Laboratory
         U.S.  Environmental Protection Agency
       Research Triangle Park, North Carolina 27711
         U.S.  ENVIRONMENTAL PROTECTION AGENCY
          OFFICE  OF  RESEARCH AND DEVELOPMENT
     ENVIRONMENTAL MONITORING SYSTEMS LABORATORY
    RESEARCH TRIANGLE  PARK, NORTH CAROLINA  27711
              U.S. Environmental Protection Agency
              Region 5, library (PL-12J)
              77 West Jackson BoufevajjJ. 12th floor
              Chicago, 11  60604-3590

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                      NOTICE

This document has been reviewed in accordance with
U.S. Environmental Protection Agency policy and
approved for publication.   Mention of trade names
or commercial products does not constitute endorse-
ment or recommendation for use.
                       11

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                                   FOREWORD

     Measurement and monitoring research efforts are designed to anticipate
potential environmental problems, to support regulatory actions by develop-
ing  an  in-depth  understanding  of  the  nature and  processes  that  impact
health and  the  ecology,  to provide innovative  means  of monitoring compli-
ance  with  regulations  and  to evaluate  the effectiveness  of  health  and
environmental protection efforts through the monitoring of long-term trends.
The  Environmental  Monitoring  Systems  Laboratory,  Research  Triangle Park,
North  Carolina,  has the  responsibility for:   assessment  of environmental
monitoring  technology  and  systems;  implementation of  agency-wide quality
assurance  programs  for  air  pollution  measurement systems;  and supplying
technical  support  to other  groups  in  the  Agency including  the Office of
Air,  Noise  and Radiation,  the Office  of  Pesticides and  Toxic Substances
and the Office of Enforcement Counsel.

     Knowledge  of  the   quality  of  air  pollution  measurements  from  the
national   monitoring networks  is  important in  determinating  air  quality
trends, assessing  compliance  to  air   quality standards,  and  developing
control  strategies.   Federal regulations for  ambient  air  quality surveil-
lance were revised May 10, 1979 to require the states to develop and conduct
quality assurance programs  approved  by the EPA Regional Offices.  In addi-
tion,  the states are  required to submit  to  EPA  the  results  of specific
tests and comparisons to assess the precision and accuracy of their measure-
ment systems.  This  document is  intended to help states and local agencies
achieve the maximum benefits from the new requirements.
                                   Thomas R. Hauser, Ph.D.
                                          Director
                         Environmental Monitoring Systems Laboratory
                           Research Triangle Park, North Carolina

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                                   ABSTRACT

     Federal regulations for  ambient  air quality surveillance were revised
May 10, 1979, tc include requirements  that states perform certain specified
tests to assess  the  precision and accuracy of their air pollution measure-
ment systems and to report the results to EPA routinely.
     This report  discusses the  concepts and definitions  of  precision and
accuracy as  they  relate to ambient air pollution measurement systems.  The
rationale  used  in  developing  the  specified  procedures  for  acquiring
precision and accuracy  assessments  is explained for both  manual  and auto-
mated measurement methods.  The  computational  procedures specified for the
handling of the  precision and  accuracy data and  the development  of the
statistical  assessments to be  reported to EPA are reviewed.
     Particular emphasis  is given  to the potential  use of  the  precision
and accuracy data by  the states and  local agencies  as an adjunct to their
routine  quality  assurance  programs.   A number  of  statistical  quality
control  charts  are  recommended for  routine  use by  the states  and local
agencies.
     Finally, answers  are  provided  for many questions  concerning  inter-
pretation of the requirements  of the regulation and procedures for handling
special  case situations   not  specifically  detailed  in  the  regulations.
                                    IV

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                                   CONTENTS
Number                                                                Page

1    General Background  	      1

2    Overview of Quality Assurance Requirements  	     13

3    Conditions for Precision Checks  	     15

4    Conditions for Accuracy Audits  	     20

5    Statistics of Precision 	     22

6    Statistics of Accuracy  	     31

7    Use of Precision and Accuracy Data	     38

8    Summary Analysis of Precision and Accuracy Data   	     40

9    Comparison of SLAMS and PSD Requirements  	     42

10   Questions and Answers   	     45

11   References    	     65

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                                   FIGURES

Number                                                                Page

 1   Multiple reporting organizations with central laboratory
          and separate field operations typical of manual
          methods  	     9

 2   Multiple reporting organizations with central field
          operations and separate laboratories and data analysis
          functions for manual methods 	    10

 3   Multiple reporting organizations with central field
          operations and data analysis and with separate cali-
          bration systems for automated methods  	    11

 4   Multiple reporting organizations with separate field
          operations and central  calibration and analysis labora-
          tories and data analysis unit typical of large-scale
          automated methods  	    12

 5   Graphical interpretation of  precision data  	    31

 6   Graphical interpretation of  accuracy data 	    37

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                                   TABLES

Number                                                                Page

 1     Automated Analyzer Audit Concentrations  	         22

 2     Computed Probability Limits for Precision for Manual
       Methods and Automated Analyzers  	         28

 3     Summary of 95 Percent Probability Limits for Precision
       and Their Meanings for Manual Methods and Automated
       Methods	         29

 4     Computed Probability Limits for Accuracy for Manual
       Methods and Automated Analyzers  	         34

 5     Summary of 95 Percent Probability Limits for Accuracy
       and Their Meanings for Manual Methods and Automated
       Analyzers	         36

 6     Recommended Control Charts and Control Limits for
       Precision Checks and Accuracy Audits for State and
       Local  Agencies	         41

 7     Comparison of QA Requirements for Appendix A (SLAMS)
       and Appendix B (PSD)	         43

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          GUIDELINE ON THE MEANING AND USE OF PRECISION AND ACCURACY
              DATA REQUIRED BY 40 CFR PART 58, APPENDICES A AND 8
APPENDIX A:  QUALITY ASSURANCE  REQUIREMENTS FOR STATE AND LOCAL AIR
             MONITORING STATIONS (SLAMS)
APPENDIX  B:   QUALITY  ASSURANCE  REQUIREMENTS FOR  PREVENTION OF
             SIGNIFICANT DETERIORATION (PSD) AIR MONITORING
1.   GENERAL BACKGROUND
1.1  Need for Mandatory Quality Assurance (QA)
     Prior  to  the May  10,  1979 promulgation of the  Regulations set forth
in 40  CFR Part  58,  (44 FR 27558-27604), the  quality  assurance and quality
control  practices of  State  and  local  agencies  were  strictly voluntary,
although many  forms of  guidance  and  assistance  had been  provided by the
EPA  Regional  Offices and the  Environmental  Monitoring  Systems Laboratory,
Research Triangle Park, North Carolina (EMSL/RTP).   Consequently, there was
a  wide diversity  among  the  State  and local  agencies  in  the  scope  and
effectiveness of their QA program.  As described below,  numerous indications
pointed to  the  need for more extensive and more uniform QA programs of the
state and local  agencies.
1.2  Need for Quality Data
     Many important  EPA decisions  are  based on  the  nationwide monitoring
data obtained by the State and local agencies.   Data collected and reported
to the National  Aerometric  Data Bank (NADB) in Durham,  North Carolina are
used by  EPA  to  aid in planning the Nation's air pollution control strategy
and to measure  achievement  toward meeting  national air  quality standards.
In addition,  the data  are  used locally for determining  attainment  of the
standards.    Further,  the data  in  the NADB are made  available  to numerous
requestors,   who  may use  the  data  for  various  research  projects,  special
studies,  or other purposes.

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     Unfortunately, none  of  the  data in the  NADB  prior to January 1, 1981
is  accompanied  by estimates  of  its  quality.    Although the  capability
(accuracy and precision) of the EPA-developed measurement methods have been
determined in inter!aboratory collaborative studies, those levels of method
precision and  accuracy  are  seldom achieved in the real world of day-to-day
routine monitoring.  To  assure  the most knowledgeable use of the data, the
quality  of  the  national  monitoring  data  should  be  determined and  made
known to all data users.
     Further, many  of  the monitoring methods used in the past by State and
local  agencies  were  not reference,  equivalent,  or approved methods,  so
designated  by  EPA  after  careful  and thorough evaluation.  Because  of the
likelihood  of  different methods producing  differing results,  all  national
monitoring  should  be  performed  using  reference,  equivalent, or  approved
methods.

1-3  Regulation of May 10, 1979
     The ambient  air  monitoring  regulations,  as revised  on May 10,  1979,
contain a new  Part 58 (1) that includes various requirements  for the tech-
nical improvement of the national  monitoring.   Some of the new requirements
are the specification of:
     0    Monitoring methods;
     0    Instrument siting and probe location;
     0    Scheduling of monitoring;
     0    Network design;
     0    Air quality reporting.

     Part 58 contains  several appendices, two of which specify requirements
for quality assurance (QA) and data quality assessment:

     1.   Appendix A.     Quality  Assurance   Requirements   for   State  and
                         Local Monitoring Stations (SLAMS);
     2.   Appendix B.     Quality Assurance  Requirements for Prevention  of
                         Significant  Deterioration  (PSD)  Air  Monitoring.

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The QA requirements of these appendices  involve two separate areas:

     1.   Documentation of each agency's Quality Control Program.
     2.   Assessment  and  reporting  of  the quality  of each  agency's air
          monitoring data.

     Documentation  of  each  agency's  Quality Control  Program  is to cover.
as a minimum, the following:

     1.   Selection of methods, analyzers,  or samplers;
     2.   Installation of equipment;
     3.   Calibration;
     4.   Zero/span checks and adjustments  of automated analyzers;
     5.   Control checks and their frequency;
     6.   Control limits for zero, span, and other control checks,
          and respective corrective actions when such  limits are
          surpassed;
     7.   Calibration and zero/span checks  for multiple range
          analyzers;
     8.   Preventive and remedial maintenance;
     9.   Quality control procedures for air pollution episode
          monitoring;
     10.   Recording and validation of data; and
     11.   Documentation of quality control  information.

     For the data  quality assessment,  specific procedures are delineated
using special quantitative  checks,  to determine the precision and accuracy
of each  of  the  automated  and  manual  methods used to  measure  the criteria
pollutants.
     These  latter  procedures were  developed to measure the  precision and
accuracy  under  operating   conditions   as  nearly  typical  as  possible.
Furthermore, the precision  and  accuracy (P and A) data  are required to be
reported to  EPA for several  important  reasons.   First,  the P  and  A  data
are appropriately filed by EPA so that users of the routine monitoring  data
filed in the National  Aerometric Data Bank (NADS)  receive the corresponding
P and A  data  for the particular network(s) and the particular  time periods

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involved.   Second, the P and A data are evaluated from Regional  and National
standpoints  to  identify    (a)   regions,  states,  or  local  agencies  that
require improvement  in their  data  quality  (i.e., improvement  in  their QA
system)  and  (b)  pollutant  measurement  methods  that may  need  remedial
changes in  the methodology  to improve the precision  and/or accuracy of the
methods in the real  monitoring world.
     In addition  to the  above  documentation and  assessment  requirements,
the regulations require the following:

     1.    All  criteria  pollutant  measurement  calibration  standards  and
          flow  measurement  calibration  standards must  be  traceable  to
          National Bureau  of Standards (NBS) Standard Reference Materials
          (SRM) or other primary standards;

     2.   All agencies must participate in  National  EPA performance audits
          and must permit EPA system audits  of their  monitoring  and QA pro-
          cedures.

     3.  All  methods used  for  measurements of criteria air  pollutants in
          SLAMS must be reference,  equivalent, or approved  methods.

     A recent amendment to 40 CFR Part 58, promulgated on September 3, 1981
(46 FR 44159-44172)  (2),  makes the  requirements  for assessing  precision and
accuracy  applicable  to  monitoring  for  lead  (Pb)   and  includes  several
corrections  to  the  40 CFR  Part 58 regulations.   A separate  EPA guideline
document has been issued  concerning the monitoring for  Pb  in the vicinity
of point sources (3).

1-4  Measures of Data Quality
     The  quality   of  monitoring   data  can  be  expressed  in  terms  of
representativeness,   comparability,  completeness,  precision  and  accuracy.
     Aspects  of   representativeness  have  been  strongly considered  in the
portions  of Part  58  which deal  with network  design,  siting,  and probe
location—factors that relate  to   the  representativeness  of the  samples.
The extent  to  which the samples represent the ideal  locations,  conditions,

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and times  of sampling are measures of representativeness, and have meaning
with respect to the objective or purpose of the monitoring.
     Comparability  of data obtained across the  entire  Nation is achieved,
to a large extent, by the use of the standardized (designated) sampling and
analysis methods  specified by  the regulations,  along  with  consistency in
reporting units.
     Completeness  of  data sets   is  an  important  concern   in  monitoring
because  of  the adverse effects of gaps  or "holes"  in  the data  base.   The
statistical  validity  of  sets  of  monitoring  data is a  direct function of
the extent  and pattern  of missing data.   Although the  completeness  of a
given data  set is a major concern  to  the  data user, and  its importance is
emphasized  in  the regulation,  the regulation does  not  require any special
reporting with respect to data completeness.  The number of individual  data
values reported to  the NADB for each monitoring site can  be determined and
are reported with data for specific sites.
     The measures of data  quality which  are required to be obtained and
reported by the  States  and local  agencies beginning January 1,  1981, are
those for precision and accuracy.   When one speaks of precision and accuracy
of  measurment data,  one really  means  the precision  and accuracy  of the
measurement process from which the measurement data are obtained.   Precision
is  a  measure  of the  "repeatability  of   the   measurement  process  under
specified conditions."  Accuracy  is a measure of "closeness to the truth."
The definitions  and concepts  of  precision and accuracy  as  they  relate to
the requirements  of  Appendices A  and  B  of  the regulation  are  discussed
further in the next section.

1.5  Precision and Accuracy
     As defined above,  the  accuracy of a  measurement  is  its "closeness to
the truth."   Deviations  from  the  truth result  from  both  random  errors and
systematic errors.  Precision,  the repeatability of a measurement process,
is associated  with  the  random errors.   The average inaccuracy, or bias, of
a  measurement process over  some  period of time or  set   of  conditions  is
associated  with  the  systematic   error.    Deviation  that appears  to  be
constant, or systematic, under one set of conditions may actually be random

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 under  a  set  of  conditions  of wider  scope.   For example,  the systematic
 error  of a given instrument is associated with  average  accuracy  for that
 instrument over some specified period of time.  However, the variability of
 average  inaccuracies  from a number of  instruments in  a network may appear
 to  be  random  and can,  therefore,  be  associated  with  the  "precision"
 for the  network.*

 1.5.1     Precision - Precision is used in 40 CFR Part 58, Appendices A and
 B,  in  the sense  of "repeatability of  measurement values  under  specified
 conditions."   Since  specified conditions may vary considerably,  there are
 many levels of repeatability or precision.   For example,  with an automated
 continuous air pollution sensor,  the random  fluctuations  in  response over
 a short  time,  e.g.,  within a minute,  when an instrument is measuring a gas
 of constant pollutant  concentration  is a very "local"  measurement  of pre-
 cision.   Another  measure of  repeatability  would  be  the variability  of
 span measurements made each day on an instrument over some longer period of
 time.   The  measure of  precision  (repeatability) used  in  40 CFR  Part 58,
 Appendices  A   and B,  for automated  methods is  the  variability  of  one-
 point  precision  checks made  at  biweekly intervals on  the same instrument
 (Instrument  Precision).   Agency*  precision,   however,   is   the   average
 repeatability  of  all  the instruments  of the  agency  during the  calendar
 quarter.   A  given precision  check  may be considered  as  representative  of
 an hourly average value  that would have been obtained  from  the instrument
 if the air pollution  concentration  remained at the same  level  as  that for
the precision  check.
     Throughout this  guideline,  agency or  network is  used  in a  general
sense  corresponding  to  the  definition  of a  "reporting organization"  as
defined  in  Section 3  of  Appendix A, 40 CFR  Part 58,  and as  discussed  in
Section  1.6  of this guideline.   A reporting  organization  may consist  of
one  or more  governmental  air  pollution agencies  (networks),  or  in  some
special  cases  there may  be more  than  one reporting  organization in  the
same governmental  air pollution agency (network).

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Because the  lack  of  precision from hour to  hour  is generally proportional
to concentration,  it may  be  further assumed  without much  error  that the
same percentage variation  exists  at other concentration levels, except for
very low or very high concentrations.

1.5.2     Accuracy - Accuracy is used in Appendices A and B in the sense of
"closeness  to  the truth."  Although  the ultimate  truth cannot be  known,
accepted  as  the closest to the truth  are the values determined by  NBS or
other  nationally  recognized measurement standards  body.   In assessing the
accuracy  of  measurements of  an  air pollution monitoring  agency,  measure-
ments are made  through  the mechanism or procedure of independent audits in
which  the measurement systems are challenged with  standards (materials or
devices)  having traceability  as  directly  as possible  to  NBS standards.
     Some  error  or   uncertainty  exists  even  in  NBS   Standard  Reference
Materials  (SRM's),  which  are labeled  with  computed tolerances  based on
empirical  data and   which  are  applicable  only   under  certain  specified
conditions  and  procedures  for use.   Obviously, some  errors  are introduced
in  the use  of secondary  standards  that have  been prepared  by  reference
against NBS  SRM's.   Further,  if  the use of secondary standards in conduct-
ing  independent audits  involves  other measurements,  such  as flow  measure-
ments when diluting audit gases,  additional  errors are introduced.
     Nevertheless, when  measurements are  made at State and local  agencies,
through  the  independent audits  described  in  Appendices  A   and  B,  the
auditors' assessed values  are considered  as the "truth."  Their values are
considered as "true"  values  in the metrology sense—not in any statistical
sense.   As  described in sections  3.1.2 and 3.2.2  of Appendix A,  periodic
independent sample audits  are made  using known materials,  or using devices
having known properties.   These  independent audits are  used as a  check on
the  routinely-used   calibration  materials,   equipment,  and  procedures.
Because  of   the  independence  and  infrequent and  special  nature of  the
audits,  the  audit  materials  and  assessments must be  considered as  the
"known" or true value and  any consistent lack of agreement  is due to bias
of the  routine  calibration process  and/or drift  (change  of  bias)  in the
routine measurement process.

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     Measurements at a given agency may, ori the average, be biased from the
true audit  values  due  to some systematic errors in the local routine cali-
bration  process.   These average  biases over a given  time  period (e.g.,  a
calendar  quarter)  may  be  considered  as  the  inaccuracy  of the agency's
measurement  system for  that calendar  quarter.   There  will also  be  some
variability  in the  inaccuracy  of measurements* made at  an  agency during a
calendar  quarter.   This variability  of inaccuracy may  be  considered  as  a
hgiher level of imprecision when considering a measurement chosen at random
from the  given agency  during the quarter.  Carrying the extension in time
a  step   further,  biases which  exist  from quarter to  quarter  at  a  given
agency may also vary in a random way.   Therefore,  the annual average of the
quarterly biases  may  be considered  as the  bias  or average inaccuracy of
the agency's measurement system  for  the year.   And the  variability of the
bias  from quarter  to   quarter  may be  considered  a  part  of  the  overall
within-year imprecision for the agency.

1.6  Reporting Organization
     The  Regulation,  Section 3  of  Appendix A, requires that  measures  of
data quality,  i.e.,  precision and accuracy,  be "reported on the basis  of
'reporting  organization.1  A reporting organization is defined  as  a  State
or subordinate organization  within a  State which  is responsible  for  a set
of stations  which monitor the  same  pollutant and for which precision and
accuracy  assessments  can  be pooled.   .   .  .   and  can  be  expected to  be
reasonably homogeneous as a result of common factors."
*The concept  of a variable  component of systematic error  is  discussed by
 Dr.  Churchill  Eisenhart's  lengthy  article,  "Realistic Evaluation  of the
 Precision  and Accuracy  of  Instrument  Calibration  Systems," Journal  of
 Research  of  the  National  Bureau of Standards,  Vol.  67C,  No.  2,  April-
 June,  1963.  See also "Systematic Measurement Errors",  by Rolf B.F.
 Schumacher, Journal of Quality  Technology,  Vol.  13, No. 1,  January 1981.
 pp.  10-24.

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     "Common factors which should be considered ... include:

          "(1) operation by a common team of field operators,
           (2) common calibration facilities, and
           (3) support by a common  laboratory or headquarters."

     Several examples  of reporting organizations  are  presented  in Figures
1 through 4.
FIELD OPERATIONS
 LABORATORY
 CALIBRATION ANALYSIS
REPORTING                           1     2
ORGANIZATIONS
     Figure 1.  Multiple  reporting  organizations with  central  laboratory
               and separate  field  operations  typical  of manual  methods.

     In Figure 1,  the field  operations,  which may be spread over  a  wide
geographical area,  are  handled by  two  different working  groups,  each
using  their separate  procedures,  field calibration (flow) equipment  and
standards,  preventive   maintenance  schedules,  etc.    The   samples   are
analyzed,   however,   in  a  central  laboratory  with  central  laboratory
personnel,  procedures,   calibration  chemicals,  calibrated balances,  etc.
In this example,  there  are two  separate  reporting  organizations  as indi-
cated by lines  1  and  2.

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     Figures  2  and  3 illustrate  situations  where  the  field  operations
carried out by  a single  group; however, two  different  chemicals  labora-
tories are involved,  each of which performs all  functions associated  with
calibration and  analysis.   Further  data  are analyzed  and processed  by
separate units  in  Figure  2,  but  in  Figure  3,  the data  handling  is  per-
formed  by  one  unit.   In  each  case,  there  are  two  separate  reporting
organizations, defined by the two lines.
    FIELD OPERATIONS
     LABORATORY
     CALIBRATION ANALYSIS
    DATA HANDLING
     REPORTING
     ORGANIZATIONS
     Figure 2. Multiple reporting organizations with central  field
              operations  and  separate   laboratories  and  data  analysis
              functions for manual  methods.
                                  10

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FIELD OPERATIONS
CALIBRATION
DATA HANDLING
REPORTING
ORGANIZATIONS
   Figure 3. Multiple reporting organizations with central  field
            operations and data analysis and with separate
            calibration systems for automated methods.
                               11

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 FIELD
 OPERATIONS
 MAINTENANCE
 CALIBRATION
 LABORATORY
 DATA HANDLING
 REPORTING
 ORGANIZATIONS
CDC
                  —>
          (,
             1  2 3
Figure 4.  Multiple reporting organizations with separate field
        operations   and   central   calibration  and   analysis
        laboratories and data  analysis unit typical  of  large-
        scale automated methods.
                     12

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     Figure  4 represents three reporting  organizations,  each with its own
field  operations  for sampling and instrument maintenance.  In such a  large
operation, the field operation functions are performed by different sets of
personnel  at widely separated locations.   However,  each organization uses
the same calibration and analysis laboratories and data handling facilities.
     As  can  be deduced  from these  examples,  the definition of  reporting
organization  does  not relate  to  which  agency  or organization reports the
routine monitoring or to which agency or organization reports the  precision
and accuracy  data,  but rather to the  total  operational  system involved in
sampling, calibration, analysis, and reporting for routine monitoring  for a
specific pollutant.
     It  is  important to  emphasize that the definition of reporting organi-
zation  is  pollutant-specific.   It  is  possible  that  a  given  sampling site
may  be  identified  with  different   reporting  organizations  for   different
pollutants.   The  concept  or definition of reporting organization  has  no
meaning, of  course,  for  PSD monitoring.   For  PSD monitoring, the measure-
ment and reporting of precision and accuracy data are accomplished for each
site or sampling location.

2.   OVERVIEW OF QUALITY ASSURANCE REQUIREMENTS
     Before  discussing  the details  of the  requirements  for  precision and
accuracy determination for  SLAMS  and PSD,  it is desirable to summarize the
general  requirements  of  the  regulations relative to  quality assurance.
     The  precision  and   accuracy  determinations  are  made  by  performing
specified internal checks made by or for the reporting organization (SLAMS)
or by  the  owner/operator (PSD).   Closely  related  to  these  internal  checks
are the  external  performance  audits and  system audits conducted by  EPA.
     The  responsibility   for  obtaining  and  reporting  the  precision and
accuracy  data belongs   to  the  reporting  organization  and   is  therefore
considered as "internal"  to  it.   The  conduct  of  the Performance  Audit
program by EMSL/RTP  and  the conduct of the Quality System Audit program by
the EPA  Regional   Offices  are  considered  as  "external"  to  the  reporting
organization, because  the programs  are  conducted by EPA,  even  though the
reporting organizations  are  involved by their participation in the audits.
                                   13

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     Precision for each of the manual methods (except for Pb) is determined
from the  results of  collocated  samplers  located at two  sites  expected to
have a measurable concentration of the pollutant.   The precision checks for
Pb are made by analyzing duplicate strips  (or duplicate aliquots for equiv-
alent  methods)  from  a  single  site  of  expected  high  Pb  concentration.
Accuracy  is  determined from  the  results  of  local  independent  audits  for
the  flow  or analytical measurement  portion of the methods.   The accuracy
checks are essentially internal-but-independent checks on the local routine
calibration process.
     The external audits  for  accuracy are EPA performance audits, in which
reference samples or  devices  from EMSL/RTP are distributed as blinds on an
annual  or semi-annual  frequency to the organizations involved.  The results
from these  "unknowns" are  transmitted to EMSL/RTP,  which then  sends  the
"true"   value  to the  organizations.   Each year  an  annual  summary report,
prepared by EMSL/RTP,  provides  an overall analysis  by EMSL/RTP through the
dissemination of (a)  simulated bubbler samples for the S02 and N02 methods,
(b)  reference  flow devices  for the high-volume TSP method,  and (c) refer-
ence flow devices and spiked  high-volume  filter  strips  for Pb.   Note that
only the  chemical analysis  portion of the bubbler  methods  is audited;  the
flow  measurement is  not  audited.   For   the TSP  method,  only  the  flow
measurement portion of  the  method is audited; the  sample handling,  sample
conditioning,   and weighing  portions  of  the method  are not  audited.   For
Pb,  the chemical analysis portion of the method is audited,  and the flow
measurement is audited.
     Annual systems  audits  of  each  state agency may be  conducted  by  the
EPA  Regional  Offices.  These  audits  should cover  all  the  aspects  of  the
State QA  program, with  particulate emphasis on the eleven items listed in
Section 2.2 of Appendix A to  Part 58 and repeated  in  Section  1.3 of this
document.   See also Section 2.0.11 of Reference 5.
2.2  Automated Analyzers
     Precision of automated analyzers is determined  from biweekly precision
checks.   The   precision checks  are actually  measurements of  the analyzer
response at a concentration level near the national  average for ambient air.
     Accuracy  is determined  from the  results of  local  audits  using  in-
dependently  prepared  standards.   The  accuracy  checks  are  essentially
internal-but-independent  checks  on the local  routine  calibration process.
                                   14

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     The  external  performance and system audits  for  automated methods are
similar  to  those  for  the  manual  methods, except that  at  the current time
(December, 1982),  reference materials are available only for the CO and SCL
measurement  systems.   Audit  materials/devices  are  being  developed  by
EMSL/RTP  for automated N02 and 03 methods.  When developed,  the reporting
organizations  will  be  required to participate  in these performance audits
also.

2.3  PSD Requirements
     The  requirements  for  precision  and  accuracy  assessment  for  PSD
monitoring methods are very similar to those for SLAMS.  In those instances
where the  requirements differ,  special  note will be  made.   Otherwise, the
reader  should  assume   that   the  requirements  are  the  same.   A  separate
section,  Section  9,  summarizes  the  major  similarities  and  differences
between  the  requirements  for SLAMS and PSD.  EPA has issued other guidance
concerning the monitoring for PSD (6,7).

2.4  Reporting Precision and Accuracy Data
     The  procedures  for obtaining  precision and accuracy  data, including
the  necessary  computations,  are  included in Appendicies A  and B of 40 CFR
Part 58.   For reference, a  copy  of  the  reporting form, Form 1 (front and
back),  is given on the following page.
3.    CONDITIONS FOR PRECISION TESTS
3.1  Typical Conditions
     It  is  very important  that the  estimates  of precision  for the above
purposes be obtained under conditions that are as typical as possible.  The
measurements from  which the  estimates  are made  should be  obtained under
conditions of operation, maintenance, and calibration that are representa-
tive of  normal  routine activities of the monitoring agencies.  The follow-
ing  precautions  should  be observed  by  the  State  and local  agencies  in
obtaining the data used to estimate precision.
                                   15

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     In preparation for the performance of the precision checks, no special
adjustments,  calibrations, or  maintenance  of  the  instruments should  be
performed.  For example, the biweekly precision checks should be made prior
to any  routine or  special  checks or  adjustments  made  in  connection with
zero/span,  calibration,  or maintenance  scheduled  on the  same day  as  the
precision  checks.    If  routine  zero  or span  checks,   adjustments,  cali-
brations  or maintenance  are  performed  at  some  scheduled  frequency,  the
biweekly  precision  checks should  be  made  at various random  times  in
between  these  scheduled  operations.   In other words,  the  special  checks
for precision  should  be made  at times which, as a  sample,  are representa-
tive of  the  typical  conditions  existing within the  calendar quarter.   From
practical,  logistic  considerations,  the precision  checks  could  be  made
just prior  to  (a)  scheduled zero/span checks that may result in instrument
adjustment, (b) scheduled calibrations, or (c) scheduled maintenance.

3.2  Manual Methods
     As previously pointed  out  (Section  1.5.1), the conditions under which
precision  is  determined must be  very specifically  stated.   The  intent  of
the regulation  is  to  obtain  precision estimates that  reflect the  repeat-
ability of the entire measurement process.   The best known way  of measuring
the repeatability  of the  entire  process is through the  use of collocated
samplers.  In  this way,  most  of the  variables acting throughout the entire
measurement process are independently involved for each  of the  two  separate
samplers.   Even  so,  there will  be   commonalities  of  conditions  for  the
paired data from the collocated  samplers  that will enhance better agreement
than would be  achieved if the  two  samplers  and  samples were completely
independent.   For  example, the paired samples will  be handled under  the
same conditions,  and  will be analyzed  under the  same conditions  in  the
laboratory.   Because   of   such   commonalities,   the  precision  estimates
obtained will be somewhat optimistic, i.e.,  they will  tend to underestimate
the  true  inherent  variability  (imprecision)  of  the  total   measurement
process.
     Internal  (local)  precision  checks are made using  collocated  samplers
at a  minimum of two  sites of  high  concentration.   One  of  the collocated
                                   18

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samplers  is  randomly  designated  as  the  official   sampler  for  routine
monitoring;  the  other  is  considered the  duplicate.   After the designated
sampler  is  so  identified,  its designation should  not  be changed.   Results
from  the duplicate  sampler  are  to  be obtained  each  day  the  designated
sampler  is  operated  unless the samplers are  operated  more frequently than
every sixth  day,  in  which case at  least  one collocated sample is required
each week.
     Ideally, collocated samplers should also be required for Pb.   However,
because  of  the  added  expense  of  establishing duplicate  samplers  at  Pb
sites,  resort  has been  made to  analyses  of duplicate  strips  or aliquots
from  filters from a  single  sampler at a  high  concentration  Pb  site.  The
estimates  of precision from  the  duplicate  strips will  not  include  vari-
abilities   from   sampler   to  sampler  and  thus  will  underestimate  the
imprecision  of the total measurement process.

3.3  Automated Analyzers
     For automated analyzers, the use of collocated analyzers would be best
to measure repeatability; however, the cost would be prohibitive.   The next
most  desirable  technique  is to  perform  response checks  at  approximately
ambient  concentration  levels  at  random times between successive instrument
adjustments.  In  this  way,  the precision  is  a  measure of instrument drift
from  the time of  the most recent  instrument adjustment or calibration  to
the time of the  precision check.   The  regulations require  the  precision
checks to  be made at two-week intervals or  more frequently.   Although not
stated  in  the regulations,  an  average of the  instrument  output  should  be
obtained  over  some  relatively short  period of time,  e.g.,  five  minutes
following  introduction  of  the "precision" gas  and after reaching equilib-
rium.   Thus, the  precision estimates have meaning only with respect to the
time-averaging period over which the average values are obtained.   Precision
estimates for other  time-averaging  periods would  have to  be  determined  by
knowing  or  assuming  a drift pattern between  successive  instrument  adjust-
ments  and calibrations.
                                   19

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     Precision checks  are conducted  at  least biweekly  and are  made  with
concentrations of test gases in the following ranges:
               0.08 - 0.10  ppm for  S02>  03>  N02;
                  8 -   10 ppm for CO.
These precision checks may use the same materials, equipment,  and personnel
routinely used for instrument calibration or span checks.
4.    CONDITIONS FOR ACCURACY AUDITS
4.1  Typical Conditions
     Data  for  estimating accuracy  should  be obtained  under  conditions as
typical  as  possible,  i.e.,  under  normal,  routine activities  of  the moni-
toring  agencies.    Thus,  consistent  with  the  previous  discussion  under
Section  3.1  for  precision,  no  special   adjustments,  calibrations,  or
maintenance of the instruments should be performed immediately prior to the
internal accuracy audits.
     To  measure  the  closeness  of  an  observed  measurement  value to  the
truth, some material  or  condition  of known (true) property (standard) must
be  measured  by  the  measurement  system  being  checked.   The  measurement
system is "challenged" with the  "known" to obtain the observed measurement.
The difference between the  observed value and the known value is  a measure
of  the  bias or  inaccuracy  of the observed value.   Standard  convention is
to  obtain  a  signed  difference  by  subtracting  the  known value  from the
observed  value  so that  the sign  indicates  the  direction  of  the  bias.
More  specific  details concerning  the  conduct of accuracy audits is given
in Reference 1.

4.2  Manual Methods

     For manual methods,  it is difficult to challenge the total measurement
system  with  "knowns".   Therefore,  an  accuracy  audit  is  made of  only
a  portion  of  the measurement  system.   The  two  major portions  of  manual
measurement systems are  the flow measurements and the analytical measure-
ments.   The flow  measurement portion of the  TSP  and Pb reference methods,
                                   20

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and  the analytical  measurement  portion of  the  Pb  and  the NOp  and SCL
bubbler  methods  are audited  for accuracy.   The flow  rate  audits for the
TSP  and  Pb  methods are made at  a flow rate  near the normal  operating flow
rate.  Twenty-five  percent of  the combined total sites for TSP and Pb must
be audited  internally  each quarter, so as to represent a  random sample for
the  entire  network.    However,  at  least one  site must  be  audited each
quarter, and all sites  must be audited internally each year.
     For the  N02  and S02 methods, analytical audit samples  (standards) in
the  following ranges are used:
          1.   0.2-0.3 ug/ml;
          2.   0.5-0.6 ug/ml;
          3.   0.8-0.9 ug/ml.
For  the Pb method, the  standards are spiked strips  containing 100-300 ug/Pb
strip and 600-1000 ug/Pb strip are used.   An  internal audit at each concen-
tration  level  must be  made  on each day  of analysis  of routine monitoring
samples, and the audits must be made at least twice each quarter.

4.3  Automated Analyzers
     For  automated analyzers,   "known"  gaseous   pollutant  standard concen-
trations,  independently certified  and  obtained with  equipment different
from that  used for  routine  calibration  and  spanning,  are introduced into
the  measurement  instruments.    In  this  way,   two different  calibration
systems  are  involved:   the one  used  for  routine  monitoring and  the one
used to  establish  the  audit standards.   For SLAMS, the accuracy audits may
be conducted  by  the same personnel who normally calibrate the instruments.
However, in the case of PSD, different personnel must be used.
     Automated  analyzers  are   challenged (audited)  with  known  pollutant
concentration standards  at  three levels   (four  levels in  the  case of high-
range analyzers)  in accordance with Table  III.   The  internal,  independent
accuracy audits  are the responsibility of  each reporting  organization and
can  be performed  by personnel  of the reporting organization.   However, the
reporting  organization  could,   if   desired,  have  the  accuracy  audits
conducted by a contractor,  or they could, by mutual agreement, be performed
by  a  Regional   team,   a  contractor  of  EPA,  or  some  other  independent
organization.
                                   21

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          Table I.  Automated Analyzer Audit Concentrations
Audit
Level
1
2
3
4
Concentration range, ppm
S02, Nl
0.03 -
0.15 -
0.35 -
0.80 -
D2' °3
0.08
0.20
0.45
0.90

3
15
35
80
CO
- 8
- 20
- 45
- 90

     External  audits  of  automated analyzer  measurement systems  are con-
ducted  by EPA.   Semiannual  performance  audits  for  CO and  S02  automated
methods  are  conducted  by  EMSL/RTP  through  the  dissemination   of  small
cylinders  containing  CO  gas  and  through  the  dissemination  of  small
cylinders containing  S02  gas  used in conjunction with  a  dilution system.
Materials or  devices  for  conducting performance audits for the measurement
systems for N02  and  03  are being  developed by  EMSL/RTP.   Participation in
these latter  audits will  be  required of the  State/local  agencies when the
audit materials become available.
     The annual  systems audits  conducted  by the  EPA  Regional  Offices were
previously discussed.

5.    STATISTICS   OF   PRECISION
     The  choice  of  the  particular  statistics   used for  precision  are
described in  the  following section.   However, it  should be  stated at this
point that the  statistical procedures  and computations specified in 40 CFR
Part 58, Appendices A and B  represent a tradeoff or compromise between (a)
the amount of  effort  and  data that would  be "nice to have"  for statistical
analysis,  and  (b)  the amount  of effort that can be reasonably expected and
(c) the amount  of data  that  can be efficiently  and  effectively handled by
State and  local  agencies.   Thus,  the statistics  of  Appendices A  and  B
represent a  compromise  between (a) theoretical statistical  exactness,  and
(b) simplicity and uniformity  in computational procedures.
                                   22

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5.1  Signed Percentage Differences
     The reason  for  using percentage differences instead of actual differ-
ences  is  that errors  in precision  are  generally proportional  to concen-
tration  levels.   In the  case of the biweekly precision  checks,  which are
made  at  one  fixed  level, either actual  differences  or percentage differ-
ences  could  be  used.   However, since  other comparisons  are  made  on  a
percentage basis, percentage differences are used throughout for simplicity
and  consistency.   It  is recognized  that  the  percentage  errors  may  be
somewhat higher at very low concentrations.
     To  obtain  signed differences,  the  measurement  associated  with one
identified  factor  is  always  subtracted  from  the measurement  associated
with  the other  identified factor.    For example, for  collocated samplers
the  value  from   the  designated  sampler  is  always   subtracted   from the
value  for  the  duplicate sampler.   Therefore,   each  difference will  be
either positive or negative in sign.
     The  reason  for using  signed percentage  differences  instead of  abso-
lute  percentage   differences   is  to  obtain important  information  on the
possible  presence of  systematic errors.   The  calculation of  the average
difference values using signed percentage differences reveals or highlights
any  systematic errors which  may need  investigation  and  corrective  action
to improve  the precision of the monitoring data.  Further, the statistical
significance  of  these  systematic errors can be determined with the average
and  the  standard  deviation  of  the  signed percentage  difference values.
With absolute  percentage  differences,  it would not be possible to separate
the systematic errors  from the random errors.  Ideally, the average,  signed
percentage  difference  values   obtained  for each  instrument  or site  should
be zero.   Where  these  values are  significantly  different from  zero, the
resulting probability  limits   will  be noticeably  asymmetrical  about zero.

5.2  Manual  Methods
     For manual  measurement methods, precision  or  repeatability  is  deter-
mined  from  the discrepancy between measurements  from  collocated samplers
presumably sampling  the  same  air parcel over the same time period (Instru-
ment or Site Precision).
                                   23

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     Because  it  is  desired  to  obtain  a  measure of  precision associated
with a  result  from a single  sampler,  the  variability  (standard deviation)
of  percentage   differences  between  the  collocated instruments  is  divided
by  J2,  since both  instruments  are  assumed  to be equally  imprecise.   The
division  by J2  compensates  for  the  fact  that the variability (standard
deviation)  of percentage  differences from two measurement systems of equal
imprecision  is  increased  by a factor of ^2 over the error variability of a
single  measurement  system.   After  division  by  V2,  the  repeatability
represents  the  variation  in results  which  would be  obtained  if  a  large
number  of  like  instruments of  the  same  imprecision  as  those  at  the
collocation  site  were  located at  the same site sampling  the  same air over
the same period.
     Because of  the  additional  cost  of establishing  collocated  samplers
for  the  estimation  of  precision  for  Pb,  resort has been  made  to  the
measurement  of  agreement  between  the  analysis of duplicate strips  from a
single filter or analyses  of duplicate aliquots of the  extracts.  Whichever
method  is  used,  the V?  factor should  be  used in  the calculation  of  the
probability  limits.  The  precision  includes  only  the  analytical portion of
the method  and  does  not  include the sampling and  flow  measurement portions
of the method.
5.3  Automated Analyzers
     A  given  precision  check may  be considered  as  representative of  an
hourly  average  which would  have  been obtained from the  instrument  if  the
air pollution  concentration  were the  same as  the concentration  level  of
the gas  used  for  the  precision check.   Because  the lack of  precision  is
generally  proportional  to   concentration,   nearly   the  same  percentage
variation  exists  at  other   concentration  levels,  except  for  very  low
concentrations  for  a given measurement system and quality control  system.

5.4  Probability Limits
     Throughout Appendices A and  B, "probability" limits* are  computed  to
measure  the  expected spread  or  variability  of the data  from  a particular
                                   24

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population.  These  expected limits are expressed  simply  as  a mean plus or
minus a constant (1.96) times the standard deviation as follows:
                         L = x ± ks                              (1)
          where:
                L =  probability  limits  (upper limit,  L.;  lower limit, L)
                x = mean value
                k = 1.96, a constant
                s = standard deviation
     Under  the assumptions  of  (a)  an  underlying normal  population, (b)
the  mean x,  being  the  estimate of  the true mean,  u, of  the underlying
population,  and (c) the  standard  deviation, s, being  the  estimate of the
true   standard  devication,  a,  of   the   underlying   distribution,   then
x  ±  1.96s  represents  the expected limits which  should include 95 percent
of all  the  individual  measurement of the population.   Under the assemption
given,  x  ±  1.96s limits  are  the  expected  95 percent  probability limits,
regardless of the sample size.**
     The  requirement for the  computation  of "probability"  limits (rather
than  confidence limits)  is to provide  the  State and  local  agencies with
limits  which will  be  of  practical  meaning and  usefulness  for  internal
control  applications without  involving overly  complicated  and sophisti-
cated statistics.   The selection of the 95  percent  level  was made because
even  for non-statisticians,  the  chance  or  probability  of  obtaining one
value out of twenty exceeding the limits has practical  meaning.
     Note  that the  limits  are  not  "confidence   limits,"  which  could  be
computed  if  one desired  to determine  limits  that would  include  the true
mean, u,  with   a specified  confidence probability.  With  a  given  average,
x, and  standard deviation,  s,  confidence limits on the "true"* statistical
mean would be:

                         x ± ts/Vn                               (2)
 *See O.L.  Davies, "Statistical Methods in Research and Production,"
  Oliver and Boyd (1949), p.  249 for a discussion of probability limits.
**See A. Hald, "Statistical  Theory with Engineering Applications," Wiley
  (1952), pp.  311-312.
                                   25

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     where:
          t = a value from the t-distribution
          n = number of sample values

With  the  limits  computed  for  an  instrument,   site,   analysis-day,  or
agency,  along  with the  appropriate  sample size,  confidence  limits  on the
true mean could be computed, if so desired.
     Note also that  the  limits,  x ±  1.96s,  are  not "tolerance"  limits
according to  the usual  definition  of  "limits which will  include  at least
a fraction P  of  the individual values  of a population with a stated degree
of confidence  y."  Such  two-sided  tolerance limits  are  expressed  in the
same  form  as  equation  1,  x ±  ks,  but  the  value of  k  here  is  different
from that in  equation  1 and depends on  the  specified values of population
fraction, P,  and confidence  coefficient,  y.   Tabulated  values for  k are
often given**  for  values  of P of 0.75 and  above,  and values of y of 0.75
and above.   For  example,  for sample size,  n,  of 13,  P =  0.95 and y = 0.75,
the k value is 2.424.   Thus, the tolerance limits, x ± 2.424s, will include
at  least 95  percent of  the  individual  values  of  the  underlying  normal
distribution with a confidence of 75 percent.
     In  a sense,  the  x ± 1.96s "probability" limits  are  a special type of
tolerance  limit  where  the  confidence  level  is  at  the  "expectation,"  or
near the 50 percent confidence  level.   (It is  not exactly  the 50 percent
confidence level  because the  distributions  of  x +  ks and x -  ks are not
normal for small  sample sizes.)    In other words, approximately 50 percent
of the time, the probability limits will  include 95 percent of the individ-
ual values of the underlying distribution.
 *The "true" mean in the statistical sense is a quantity the confidence
  limits for which includes considerations for the variations due to
  random sampling and random measurement repeatability.   The "true" mean
  in the statistical sense is not the same as the "true" mean in the
  meteorological sense.
**Handbook 91, "Experimental Statistics," U.S. Dept.  of Commerce,
  National Bureau of Standards, pp.  2-13 through 2-15 and Table A-6;
  see also A. Hald, "Statistical Theory with Engineering Applications,"
  pp. 313-315.
                                   26

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     A summary of the various probability limits for precision, computed as
outlined  in  Appendix A,  is presented  in  Table 2  for manual  methods  and
automated  analyzers.   Note  that  a  condition  and  measure   of  bias  or
systematic error is always  associated with  the  d.'s and  the D's,  and  a
                                                   J
condition and measure of  repeatability or random error  is  associated with
the ± 1.96 S. and the ± 1.96 S3 terms of the limits.
            J                 a

5.5  Meaning of Precision
     Table 3 summarizes and interprets the probability limits for precision.
The d.'s  and  the S.'s  are the means and standard deviations, respectively,
for  the  calendar  quarter  for particular  instruments,  particular  sites,
particular  instrument-site  combinations,  or  particular  analysis  days.
     S.  represents   the  variability of the  measurement  process  under  the
      J
most similar  conditions  and may be considered  as the statistical  "error."
d,  can be  considered  in  a statistical sense  as   a  local,  within-quarter
 •J                                              —
instrument bias  or   inaccuracy.   However,  the  d.'s may  not  necessarily be
statistically different from zero.  If the d.'s are significantly different
from zero, a  persistent  drift in instrument response is  occurring, and the
cause must be identified and corrected.  Whether or not the d.'s are signi-
                                                             \J
ficantly different from zero, for a particular  instrument,  site, or analysis
day, the  d.'s will  probably vary in  a random way  among  instruments, among
          J                                                            —
sites,  and  among analysis  days;  therefore, the  variability of  the  d.'s
                                                                        J
may  be considered  as  another  level  of  precision,  when  considering  the
agency monitoring system as an entity.
     For  a specific  agency S  represents the "averaged" or  pooled within-
                             a
instrument,   within-site,  or  within-analysis-day   variability.   In  other
words,  it is the agency  estimate for the calendar quarter  of the within-
instrument,   within-site,   or within-analysis-day   variability—an  average
error term.
     The  D's  may be considered  as  a within-quarter agency bias  or  in-
accuracy.   However,  the  D's may not  necessarily be statistically signifi-
cant from zero.   A part of the EPA analysis of the data includes a test for
significance  of  the D's.   (Such  a test  should also  be performed  by eacn
agency.)  If  the D's are  significantly different  from  zero,  a persistent
                                   27

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        Table 2.   Computed Probability Limits for Precision for
                   Manual Methods and Automated Analyzers
Manual methods
  Precision (from daily signed percentage differences between collocated
            instruments for SO^, NO^, and TSP, or from signed percentage
            differences between duplicate strips or duplicate analyses
di
for Pb).
    Single Site*
    Agency
                    bias between samplers,
                    strips or analyses
                    (systematic error)
                    agency bias
                    (systematic error)
                                                      1.96 S
                                                            j
                                            V2

                                      within-site variability,
                                      individual daily value basis
                                      (random error)

                                            1.96 S
                                      average within-site variability
                                      (random error)
Automated analyzers
  Precision (from biweekly precision checks at one fixed level)
    Single Instrument*
    Agency
                    instrument bias
                    (systematic error)
                    agency bias

                    (systematic error)
                                            1.96 S.
                                                  J
                                      within-instrument variabi1ity
                                      (random error)

                                            1.96 S
                                                  a

                                      average within-instrument
                                      variability
                                      (random error)
^Limits for each instrument,  site,  or analysis day are not required to be
 reported to EPA.   However, they should be computed for internal  agency use.
                                             28

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                  Table 3.   Summary of 95  Percent Probability  Limits  for Precision and Their
                            Meaning for Manual  Methods  and  Automated  Methods.
95 percent
probability
limits
Meaning of limits
Manual methods

     Single site*



     Agency
d. ± 1.96
D  ±1.96 -
Expected variability (imprecision) during the calendar
quarter of an individual air pollution measurement from
the particular site.

Expected variability (imprecision) during the calendar
quarter of an individual air pollution measurements from
any site within the agency.
Automated analyzers


     Single Instrument*  d.  ± 1.96 S.
                          J          J
     Agency
D  ± 1.96 S
Expected variability (imprecision) during the calendar
quarter of air pollution measurements at the precision
check concentration from the particular instrument.

Expected variability (imprecision) during the calendar
quarter of air pollution measurements at the precision
check concentration from any instrument operated by
the agency.
^Limits for each instrument,  site,  or analysis  day are not required to  be  reported  to  EPA.
 However, they should be computed for internal  agency use.

-------
drift in the same direction very likely exists for most of the instruments.
Whether or  not the  D's  are significant  from zero,  the D's may  vary  in a
random way  among  quarters  for  the same agency;  therefore,  the variability
of the  D!?  may  be  considered as  a  third  level  of imprecision.   The EPA
analyses  of the  data for  each  calendar year  include a  test of  D,  the
average of  the  four quarterly  D's   for  a given  agency against  zero,  to
detect any persistent drifts throughout the entire year for all instruments
of the same type.
     From the  probability  limits  reported by an  agency,  one  could back-
calculate the agency average, D, and the agency standard deviation, Sa-  As
discussed   previously,   if   the   computations  were  made  using  unsigned
percentage  differences,  it  would not be possible to determine the D and S
values; thus,  it would  not be possible to determine  the possibly signifi-
cant  systematic  agency  errors.   In  other words, it would  not be possible
to separate the systematic errors from the random errors.
     Figure 5  graphically  illustrates the meaning of the calculated values
of d., S.,  D, S  , and the 95 percent probability limits for precision.   The
    J   J      a
individual  x's represent the individual d values for  each  of four instru-
ments or  sites of the example.   For  each of  the instruments or sites, the
d.,  the  average  of  the  d's,   represents  the  bias   from  zero,   and  S,
represents  the  variability  of  the d  values.   The pair  of short parallel
lines in the tails of the distribution represent the 95 percent probability
limits  for  the   assumed underlying  normal   distribution  of  individual  d
values.
     The normal distribution shown in Figure 5 under Quarterly Report shows
D  (the  weighted  average of the d.'s), and $a,  representing the pooled or
weighted  "average"  of the individual S.  values.  The  short parallel  lines
in  the  tails  of the distribution represent  the corresponding  95 percent
probability limits.
                                    30

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                      INSTRUMENTS OR SITES
                                                            QUARTERLY
                                                              REPORT
en
IV
u
c
Ol

-------
     Also,  as with  precision discussed  previously,  the reason  for using
signed  percentage  differences for accuracy  instead  of absolute percentage
differences  is  to  obtain  important  information  on possible  systematic
errors.   The  calculation of the difference  values  using signed percentage
differences  reveals  or  highlights any  systematic  errors  which  may need
investigation  and  corrective  action  to further improve the accuracy of the
monitoring  data.   Using  the  average  and  the  standard  deviation  of  the
signed  percentage  difference  values,  the statistical significance of these
systematic errors can be determined.   With absolute percentage differences,
it would  not  be  possible to separate the systematic errors from the random
errors.   Ideally,  the  average signed percentage difference values obtained
for each  analyzer  should be zero.   Where the average difference values are
significantly  different  from  zero,  the  resulting probability  limits will
be noticeably asymmetrical about zero.

6.2  Manual Methods
     The accuracy of manual  sampling methods is assessed by auditing a por-
tion  of the  measurement  process.   For  TSP  and Pb,  the flow  rate  during
sampling  is audited.   For S02>  N02,  and  Pb.  the  analytical  measurement is
audited.  For  single samplers,  the accuracy is the  signed  percentage dif-
ference  value,  which  is the observed or measured  value minus  the known
value  divided  by the  known value and  converted  to a percentage.   For an
agency,  the  accuracy  is  the  mean of  the  signed  percentage  difference
values from the samplers.

6.3  Automated Analyzers
     The audit is  performed by  challenging the analyzer with known concen-
trations at three  levels  (four  levels  for analyzers  with extended ranges).
The accuracy  at  each  level is  calculated as described  previously for the
manual method (Section  6.2).

6.4  Probability  Limits
     The  statistical concepts discussed previously for  precision  are also
applicable to the computation  of probability limits for accuracy.
                                   32

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     Table  4  summarizes  the  various  probability  limits  for  accuracy


computed as  outlined in 40 CFR Part 58, Appendix A, for manual methods and


automated analyzers.   The  bias or systematic error  is  associated with the


single-instrument  and agency  signed percentage  differences,  d.'s and D's,
                                                               J

respectively.  Repeatabi1ity  or  random error is associated with  the ± kS
                                                                          a

terms of the probability limits.
6.5  Meaning of Accuracy



     Table  5  summarizes  and  interprets  the  aforementioned  probability


limits  for  accuracy  for  manual  methods  and  automated  analyzers.   The D's


and the  S ,'s  are  the means and  standard  deviations,  respectively, for the
          a

calendar quarter for the agency.


     For  accuracy,  S   represents  the  variability of  inaccuracies across
                      a

instruments,  sites,   or  analysis-days.    In  a sense, this  S  may  be  con-
                                                             a

sidered a precision estimate.   For automated methods with a well-controlled


calibration system,  and with  good linearity and  stability  over  time, the


S   for  accuracy and  the  S   for precision should  be  approximately equal.
 a                         a

(Whereas, the  S,  for  precision measures  the  average variation  at a single
               a

concentration  at   biweekly  intervals,  the  S  for  accuracy measures  the
                                              a

variation at given  concentration levels but at only one  time each quarter


for a given  instrument).   A part of the EPA analysis includes a comparison


of the S  for precision and the S  for accuracy for continuous instruments.
        a                        a

If the  S   for  accuracy at the lowest concentration level  is significantly
         a

larger than the S   for precision, there  is  likely to  be some uncontrolled
                  a

variable existing within  the  calibration  process, which should be investi-


gated.


     For  integrated  sampling  methods,  the logic  of  the  comparison between


the S A/2 for  precision  and the S  for accuracy is not as straight-forward
     a                            a

as  for  automated  analyzers.   For TSP,  since the  S  for  accuracy includes
                                                    a
variation only from  the  flow rate portion of the measurement process, this


S  should  be less than  the S./-/2 for precision,  which  includes variation
 a                            J

from the entire  measurement process.   For the S0? and NCL bubbler methods,


a similar  situation  exists  as  for the  TSP,  in  that  the S   for accuracy
                                                            a

includes variation only from the chemical analysis portion of the
                                   33

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          Table 4.   Computed Probability Limits for Accuracy For
                    Manual Methods and Automated Analyzers
Manual Methods

     Accuracy (TSP and Pb)(from flow rate checks at a fixed level, once
                           per quarter, 25% of sites each quarter)

          Single Site      d.

                      sampler inaccuracy
                      (combined systematic
                      and random errors)
          Agency           5              ±              1.96 S
                                                               a
                      agency bias                   total variability
                      (systematic error)            including between
                                                    sampler inaccuracies


     Accuracy (NO.,. SO., and Pb). Each Level (from analytical checks at
                 ^*least twice per quarter)
          Single Analysis Day       d^

                      daily inaccuracy
                      (combined systematic
                      and random errors)
          Agency           D              ±               1.96  S
                                                                a
                      agency bias                   total  variability,
                      (systematic error)            including  between-
                                                    day  inaccuracies
                                 34

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               TABLE 4.   (Contd.)
Automated Analyzers

     Accuracy, Each Level (from calibration audits once per quarter,
                           25% of instruments each quarter)
          Single Instrument         d.
                           instrument inaccuracy
                           (combined systematic
                           and random errors)
          Agency         D                ±              1.96 S,
                                                               3
                    agency bias                     total  variability
                    (systematic error)              including between
                                                    instrument inaccuracies
                                35

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                                    Table 5.   Summary of 95 Percent Probability Limits for Accuracy and
                                              Their Meanings for Manual Methods and Automated Analyzers
           Manual  Methods

                TSP and Pb

                     Single Site


                     Agency
D ± 1.96 S.
Expected bias (Inaccuracy) during the calendar quarter of flow rate
portion of the measurement process for the particular site.

Expected variation in bias (inaccuracy) during the calendar quarter
of flow rate portion of the measurement process for all sites In
the agency.
GO
CTl
                S02,  N02,  and Pb

                     Single Analysis
                         Day
                Agency                   D ± 1.96  S,
                                                   a



           Automated Analyzers

                Single Instrument        d.



                Agency                   D ± 1.96  S
               Expected bias  (inaccuracy)  during the  calendar quarter of the chemical
               analysis portion  of  the measurement  process  for the  particular
               analysis day at each concentration level.
               Expected  variation in bias  (inaccuracy)  during  the  calendar quarter
               of the chemical  analysis  portion of the  measurement process for all
               analysis  days  at each concentration level.
               Expected bias  (inaccuracy)  during the calendar  quarter of air pollu-
               tion measurements at each audit concentration from the particular
               instrument.

               Expected variation in bias  (Inaccuracy)  during  the calendar quarter
               of air pollution measurements  at each audit  concentration from all
               Instruments  in the agency.

-------
 measurement  method  but  the  S ./V2  includes  variation  from  the  entire
 measurement  process.   If S   for accuracy  significantly exceeds  S /V2 for
                            o                                       3
 precision,  the  calibration process  for the  method  involved is  not well-
 controlled.   For Pb,  both the  flow rate  and  analytical portions  of the
 method  are audited.   But  the flow  rate  audits are  combined with the TSP
 data and not reported individually for lead.

      Figure  6 graphically  illustrates the meaning of the calculated values
 of d, 6,  and Sa, and the 95  percent probability limits for accuracy.   For
                Q
 accuracy  at  a   given  level,   the  individual audit   results,  d,   for  four
 instruments  or  sites are  represented by the x's.  In  accordance with the
 minimum requirements of  the  regulations,  only one audit value (for a given
 level) is shown for each instrument or site.

      Under  Quarterly Report   is  shown the  same  four   individual  x  or  d
 values,  with the D  and  S   calculated from the  individual values.   The 95
                          a
 percent probability  limits  are  shown by the short  parallel lines  in the
 tails of the distribution.
                   INSTRUMENTS OR SITES
QUARTERLY
  REPORT

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7.   USE OF PRECISION AND ACCURACY DATA

     The precision and  accuracy  data obtained by the networks and reported
to EPA are of considerable value to various organizations.   These estimates
will be  helpful  to  the user of  routine monitoring data  by  providing the
user with  information on  the quality of the data with which he is working.
The estimates are  valuable  to EPA in obtaining "real world" information on
the  precision and  accuracy  of  the reference,  equivalent,  and  approved
methods.   The data should also  be of particular  interest  and value to the
originating agencies as a supplement to the routine quality control system.

7.1  Originating Agencies
7.1.1     Supplement to Internal Quality Control - The measures of precision
and accuracy  are  obtained  by each  network  in the  form of probability or
control chart-type limits that can and should be used within each agency as
supplementary information for internal  quality control.   The precision and
accuracy information obtained within a network on a given site or instrument
can be used  for  local  quality control purposes  for  the  particular site or
instrument.   It  is important to emphasize, however,  that the precision and
accuracy checks  required  by Appendix A do not obviate the need to maintain
a  routine  quality control  system.   The precision and accuracy  checks are
too  infrequent   to be  adequate   for  day-to-day control.    Furthermore,  the
precision  and accuracy  results  should  not  normally be  used to  make any
after-the-fact adjustments  or corrections to the measurement  system or to
monitoring data.    Excessive deviations,  however, should not be ignored and
should trigger investigative action.
7.1.2     Control  Charts - The  results  of the  precision  and  accuracy data
can be plotted on various control charts.  As stated above, the results of
the precision and  accuracy  checks,  if used in a timely way, can constitute
a  valuable  supplement   to  normal  routine  internal quality control checks.
With  the  increased installation and  use  of  computers   for  acquisition
and/or up-to-date  storage of monitoring data, the computers  could also be
used for the acquisition and/or storage of the precision and accuracy data.
Further,  the  computers could be programmed to  perform  the necessary cal-
culations for precision and accuracy reporting and could also be programmed
to plot the control  charts  in real (or near-real) time.
                                   38

-------
      In general, the control  chart  limits  will  be similar  to  the computed
 probability limits  except  that the 1.96 value  will  be replaced  by  a  3.0.
 (The  1.96 corresponds to an  expected  95 percent probabi1ity--the  3.0  cor-
 responds  to an  expected 99.7  percent  probability.)   The  ± 1.96  S  limits
                                                                    o.
 could also be  used as  "2-sigma"  warning  limits  along with the  "3-sigma"
 control   limits.   In the  case of manual  method precision,  the -fe  factor
 is  not included  because the  points  to be  plotted will be the percentage
 differences,  which  include   variability   from  the   imprecision   of  both
 samplers.   Also, since  the intuitively expected  values for  d. and 5  are
                                                                J
 zero  for  precision and  accuracy, the  center!ine for  the  control  charts
 should  be  zero.    Table  6  describes control  charts  which  can be plotted
 for the individual  precision checks and  accuracy audits.

      Although the prime  objective of the precision and accuracy audits  it
 to  obtain an assessment of data  quality,  a  number of statistical control
 charts  can be  maintained  to  provide  some  supplemental long-term  internal
 control.   With  control  limits established on the basis of past  history  (at
 least  one quarter  for  precision,  at least one  year  for accuracy),  future
 data  values  can   be  plotted  to  detect  significant  changes from past
 experience.   Control charts could be  plotted with the  5  values to  detect
 within  quarter   biases.   Similarly,  the quarterly values  of  S   could be
                                                                 a
 plotted to control   or  display the variability  aspects  of the measurement
 systems.
     Consult Appendix H of the Quality Assurance Handbook for Air Pollution
 Measurement  Systems, Volume  I, Principles,  EPA 600/9-76-005  for further
 details on  the  construction and use of control charts.  Also, the  analysis
 and  interpretation  of   the  results from   individual  accuracy  audits  are
 given  on  pages  86-9,  Section  2.0.12  of Volume  II,  Ambient  Air   Specific
 Methods,  EPA 600/4-77-027a.
7.2  States and Regional Offices

     The precision  and accuracy  reports  will  be helpful to  the  states in
comparing  these  measures  of data  quality  from the  networks within  the
States.   Similarly,  the EPA Regional Offices will be able to make
                                   39

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comparisons  within and  between  States.   These  comparisons may  point  out
particular organizations  or  States  in need of further improvement in their
quality assurance programs.

7.3  Environmental Protection Agency (EPA)

     Evaluation  of the  precision and  accuracy data  is  important  to  EPA
(EMSL,  Research  Triangle  Park,  North  Carolina) in  its  role  of  responsi-
bility  for quality assurance of  air pollution measurements.  The precision
and  accuracy  data will  be used  to  (a) determine possible  needs  for addi-
tional  research  efforts  related  to  the technical or procedural  aspects of
particular  measurement  methods,  (b)  indicate  measurement  methods,   or
portions  thereof,   which  may  require  improved  quality  control,   and
(c)  indicate  particular  agencies,  States,   or  Regions  that may  require
technical assistance  or  improved quality  control.    In  other words,  the
precision  and accuracy   information  will enable  comparisons  to be  made
among  measurement  methods,  and  among  networks or  other  organizational
entities for  purposes  of identifying possible areas  in need of improvement
of data quality.
     With knowledge  of the  precision  and accuracy information,  EPA could
consider  appropriate  statistical  allowances  or  risks   in  setting  and
enforcing the standards,  and  in developing  control  strategies.

7.4  The User

     Users of monitoring data maintained  in the National  Aerometric  Data
Bank  (NADB)   receive,  along  with  the monitoring data,  the  precision  and
accuracy  data  for  the   corresponding reporting  organizations  and  time
periods.  Knowledge  of the  precision  and accuracy data assists  the users
in their interpretation,  evaluation,  and  use  of the  routine monitoring data.

8.    SUMMARY  OF  ANALYSIS OF PRECISION AND  ACCURACY DATA

     To assist Regions and  States  in  making the above comparisons  and in
performing other analyses of  the  reported   precision  and  accuracy data,
EMSL/RTP  prepares  evaluation  and summary reports  covering  each  calendar
                                   40

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Table 6.   Recommended Control Charts and Control Limits for Precision
          Checks and Accuracy Audits for State and Local Agencies

Pollutant
measurement method
Manual methods
so2
NO?
TSP
Pb

TSP (flow rate)
Pb (flow rate)
SO, (analysis)
NO^ (analysis)

Pb (analysis)
Automated methods
so2
or
NO,
°3


Type of
Control charts

Precision-Single
Site



Accuracy-Single
Site
Accuracy for
each audit level


Precision-Single
Site


Accuracy for
each audit
level
Number of
control charts Control limits

One control Zero ± 3 S
chart for each
collocated site
(the single
site for Pb)
One control Zero ± 3 S
chart per agency
One control Zero ± 3 S
chart for each
audit level

One control Zero ± 3 S
chart for each
Instrument.

One control Zero ± 3 S
chart for each
audit level
Frequency of plotting
and values to be plotted

Each day, plot d. for
each site J



After each audit, plot each
Individual d.
After each audit, plot each
Individual d.,
J

After each biweekly pre-
cision check, plot each
Individual d. value
J
After each audit check, plot
each Individual d. value
J
Variability or
Inaccuracy to
be controlled

Excessive lack of
agreement between
collocated samplers


Excessive Inaccuracy
of each Instrument
Excessive Inaccuracy
for each audit


Excessive varia-
bility and drift
of each Instrument

Excessive Inaccuracy
of each Instrument


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quarter, as well as an annual  summary.   Samples of these reports are avail-
able upon request.
9.    COMPARISON OF SLAMS AND PSD REQUIREMENTS

     Table  7  summarizes  the  major  similarities  and  differences  of  the
requirements  for  SLAMS  and PSD.

     As  indicated,  the  requirements  are  the same  in  that  both  require:

     (a)  The  development,  documentation,  and implementation  of  approved
          quality control programs.
     (b)  The assessment of data quality for precision and accuracy.
     (c)  The  use  of   reference,  equivalent,  or  approved  methods.
     (d)  The use of calibration standards traceable to NBS SRM's or other
          primary standards.
     (e)  The participation  in  EPA performance  audits  and  the permission
          for EPA to conduct system audits.

     The  monitoring  and QA  responsibilities for SLAMS are  with  the  State
or  local  agency,  whereas  for  PSD they are  with the source owner/operator
seeking  the  permit.    The  monitoring  duration  for  SLAMS  is  indefinite,
whereas  for PSD  the  duration   is  usually up  to  12  months.  Whereas,  the
reporting period  for precision and accuracy data is  on a calendar quarter
basis  for SLAMS, it  is on  a  continuing  sampling  quarter  basis  for PSD,
since  the  monitoring   may  not  commence  at  the  beginning  of  a  calendar
quarter.   For example,  the reporting  quarters for PSD  might be  March,
April, May; June, July, August;  etc.

     The  performance  audits for PSD  must  be  conducted by  personnel  dif-
ferent  from  those  who  perform  routine  span  checks and calibrations,
whereas  for  SLAMS,  it  is  the  preferred  but  not  the  required condition.
For  PSD,  the audit  rate is 100  percent of the sites per reporting quarter,
whereas for  SLAMS it is 25 percent of the sites or  instruments.  Note that
monitoring  for  SO,  and NO,, for  PSD must be  done with automated analyzers--
                  &.        £
the  manual bubbler methods are  not permitted.
                                   42

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         Table  7.   Comparison  of  QA  Requirements  for Appendix A
                      (SLAMS) and  Appendix 6  (PSD)
   Topic
     Appendix A
                                                     Appendix B
 Requirements   1.  Develop and  implement an approved quality control
                   program.
               2.  Assess data  quality  in terms of precision and accuracy.
               3.  Use reference, equivalent, or approved methods.
               4.  Use traceable standards.
               5.  Participate  in EPA performance audits and permit EPA
                   to perform system audits.
Monitoring
and QA
Responsibility
State/Local Agency
                                             Source Owner/Operator
Monitoring
Duration
Indefinitely
                                             Up to 12 months
QA Reporting
Period

Accuracy
Assessment
Audits
Audit Rate
 -Automated
 -Manual
               Calendar quarter
               Standards and equipment
               different from those used
               for spanning and cali-
               bration.  Prefer different
               personnel.
25% per quarter
Hi-vol and Pb - 25% per
quarter.
SO  & NO. - Each analysis
day, at feast twice per
quarter.
                              Sampling quarter
                              Personnel, standards, and
                              equipment different from
                              those used for spanning and
                              calibration.
                                             100% per quarter
                                             100% per quarter
                                             (No manual  !
                                             permitted).
                                                            or N0
Precision
Assessment

 -Automated
  (precision
  gas check)

 -Manual
 (collocated
  sampling)
One point precision check biweekly - more
frequent encouraged. Independence not required.
Two sites, every sixth day,
or at least once per week
for NO,, SO, and TSP.
Duplicate strips or ali-
quots for Pb.
                                             One site:   at least once per
                                             week or every third day for
                                             daily monitoring (TSP
                                             and Pb).
Reporting
By reporting organization.     By site.
                              43

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     The requirements  for precision  assessment  for the  automated methods
are the same for both SLAMS and PSD.   However,  for manual  methods, only one
collocated  site  is  required  for PSD and  the  frequency  is  once  per  week
instead of every sixth day as is usual for SLAMS.

     The precision  and accuracy data for PSD  is reported  separately for
each  sampler  (site),  whereas  for  SLAMS,  the   report  is  by  reporting
organization.

     It  should  be   recognized  that  the  requirements  of Appendix A and
Appendix  B  are   minimum  requirements.    The  permit-granting  authority
for  PSD may  require  more  frequent  or  more  stringent  requirements  than
stated in Appendix B.  Also, the Regional Offices  may require more frequent
or more stringent requirements for SLAMS than those stated in Appendix A.
                                   44

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10.  QUESTIONS AND ANSWERS

     A  series  of workshops was conducted  in  each of the 10  EPA  regions to
review  the  background,  rationale,  and requirements  of the  May 10, 1979
regulation  (40  CFR Part 58) with  region,  state  and  local agency  personnel.
During  the  conduct of the workshops  numerous  questions were raised  by the
regional,  state  and  local  agency personnel  concerning interpretations of
the  requirements  and guidance  for   implementing  the  requirements  of the
regulation  in  special cases and  circumstances.   This section presents the
questions raised and  the answers given.

     1.   Q.   What  is the relation  between the Quality Assurance Criteria
(QAC)  program  and  the  Precision  and Accuracy Reporting  System  (PARS)?

          A.    The QAC  program  was  designed  as a qualitative means  of
"scoring"  data  quality from knowledge  of  siting,  probe location, measure-
ment  method,  etc.   (i.e.,  technical   criteria)  with  judgmental weights.
The QAC  program  was  intended as as  interim method of judging data quality
for past  periods  until the PARS system became  effective,  January 1, 1981.
Unless  required  to be continued  by  the Regional  Offices,  the QAC program
has been terminated.

     2.   Q.   Are video tapes available of the Regional Workshops conduct-
ed by EPA (EMSL/RTP and OAQPS) on regulation 40 CFR  Part 58?

          A.    Yes,   a  series  of  color  video  tapes   on  the   regulation
covering  condensations of the  material presented at workshops  by members
of the  EMSL/RTP  and  OAQPS at each of the  ten Regions is available on loan
from   the   Air  Pollution  Training    Institute,  EPA   (MD-17),   Research
Triangle  Park,  North  Carolina 27711.   These  tapes provide  a   systematic
review  of  the requirements  of the  regulations,  including  those portions
dealing with the precision and accuracy reporting (7).

     3.   Q.   The regulations (CFR  Part  58,  section  58.23) require that
SLAMS  be  fully implemented,  including  the requirements of  Appendix  A,  by
January  1,  1983.   The  regulations  (section 58.34) require that  NAMS  be
                                45

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fully implemented, including the  requirements  of Appendix A,  by January 1,
1981.   Further,  Appendix A specifies  the minimum requirements  for SLAMS.

     Section 4.1.1 of Appendix  A,  requires precision  data from all  approved
SLAMS analyzers.  Section 4.1.2 of  Appendix A requires  accuracy  data from
all approved  SLAMS  analyzers.   The  instructions for  Form 1  (Appendix A,
Section 5.3,  Block  No.  15-17)  state that  only  approved  analyzers in the
network be  counted  and reported.   (1)  What,  if any,  is the  difference
between   approved  and   reference   or   equivalent   methods?;   (2)   What
analyzers/methods are  to be  included in the precision checks  and accuracy
audits and reported?; and (3) How does the difference in  the implementation
dates (January  1, 1983 for SLAMS and January  1,  1981 for NAMS) affect the
requirements  for precision  checks  and accuracy  audits  and  the  reporting
thereof?

          A.    (1)    An approved  analyzer  is a  reference  or  equivalent
method or an  analyzer otherwise approved under 40 CFR Part 58, Appendix C.
                (2)   Reporting  of precision  and  accuracy  data is  required
for all reference, equivalent or approved methods used at designated,  fully
approved, and operational SLAMS sites.
                (3)   The results  of the  special  checks  for  precision and
accuracy  for  both automated analyzers  and manual methods are intended to
represent the  precision and  accuracy for the entire reporting organization
for  the  SLAMS  network.   Since the  NAMS  is  a  part of  SLAMS,  the  same
precision and  accuracy data  represent the NAMS as well  as SLAMS.   Further,
the  intent  of the regulation is that the documented QA  system (see section
2.2,  40 CFR Part 58)  applies  equally to NAMS and SLAMS.   In other  words,
the QA system  for NAMS  is to be no different from that for all other  SLAMS.
NAMS  sites  are  to receive no special treatment with respect to QA.

      4.   Q.    Will  EPA certify commercial  supplier cylinders or permation
tubes  for users?

          A.    Yes.  EMSL/RTP currently  provides  a service  of  certifying gas
cylinders,  permeation  tubes,   and   flow  measurement  devices at  no  cost.
                                 46

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      5.   Q.    What quality  assurance requirements  apply  to the  meteoro-
 logical  monitoring systems  used to  obtain  data for modeling purposes  for
 PSD?

          A.    No  requirements  are  given  in  the  regulations.    However,
 Ambient  Monitoring Guidelines  for Prevention of Significant  Deterioration
 (PSD)  EPA-450/2-78-019, May  1978,  includes  some recommendations (6).   The
 QA  for  the  meteorology  measurement  systems   should  be included  in  the
 documented  QA plan.   A guideline  document,  "Quality Assurance Manual  for
 Meteorological Monitoring  Systems"  is  currently  in preparation.

      6.    Q.    Where  in  the  regulation is  the form  for  reporting  PSD
 precision and accuracy  data?

          A.   There  is no special form  included in the regulation.  How-
 ever,  Form  1 could be modified for  use.  A  separate form,  however, would
 be  required for  each  site.   The  permit-granting authority should  specify
 the format  for reporting PSD  data.

      7.   Q.    If SLAMS data are used  for PSD purposes,  must  the precision
 and accuracy requirements  for PSD (Appendix B) be met?

          A.   If it is planned  in  advance by the permit-granting authority
 to  use data from a SLAMS  site for  PSD  purposes,   i.e.,  the  same site is
 used  for  both  SLAMS and PSD, then  it must meet  the precision and accuracy
 requirements  for both.   Special considerations  or  decisions may  be made
 by the permit-granting  authority to use data from SLAMS sites.

     8.   Q.    (a)  Can the  flow  rate audit  for TSP be  performed in  the
 laboratory  or  must it  be  performed in the field?   (b)   Can the precision
 checks and  audits for automated analyzers be  performed in the laboratory?

          A.    (a)   The  flow  rate audit must  be  performed in the field
with  different  equipment  than  used  for  calibration,  (b)   All  precision
and accuracy data are to represent  field monitoring  results.   Consequently,
precision and accuracy  checks for  automated analyzers must be made  in the
                                47

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field under monitoring conditions.
     NOTE:   By  definition,  precision data  for manual methods  result  from
field sampling.   Only  the  accuracy  audits for the SO^,  N0?,  and Pb manual
methods are performed in the laboratory.

     9.     Q.    Can  the results of  the precision and  accuracy  checks  be
used as a basis  for invalidating routine monitoring data?

          A.    The  intended use of  the precision and  accuracy  checks  is
not for  use as  data validation or  invalidation checks.   Each agency should
have developed  and implemented  a  separate  system for routine  use  in  per-
forming  the   data   validation  function   and  which should  include  various
types of checks  with associated validation/invalidation  criteria.
               It is possible  that  after a  sufficient history of precision
and accuracy  data   (e.g.,  after a  year) have been accumulated,  these  data
could,   with  appropriate statistical  analysis, provide  a  basis  for being
used as  validation/invalidation criteria, as  a part of (in  addition  to)
the routine data validation system.
               If,   however,  precision   and  accuracy  data  are  used  to
invalidate routine  monitoring data,  all  of the  monitoring  data  from  the
particulat site  or  sites  (instrument or  instruments)  involved  should  be
invalidated back to  the  last  "acceptable"  check of  the  same  type.   In
such a  case,  the results of the precision check or accuracy audit involved
should  not be  included in  the calculations  for reporting  precision  and
accuracy data.

    10.    Q.     Precision checks and/or  accuracy audits may  have been  per-
formed  during a  period for which routine monitoring data have been  invali-
dated for  cause.   Should the results of  the precision  checks and accuracy
audits be  reported?

           A.     Not  if routine  monitoring data  obtained  immediately before
and  after  the precision checks and  accuracy  audits, were  invalidated for
reasons  that could  have  adversely  affected  the  precision  and accuracy
results.   The audits  should be repeated as  soon as practical  after  the
invalidation of the monitoring data.
                                48

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    11.    Q.    Although  the regulations  require  only one  accuracy audit
for the  selected  automated analyzers each quarter, an agency may decide to
audit  a  given analyzer  more than  once  during a  quarter.   In  equations 8
and 9  (section 4.1.2 of  Appendix  A of the regulation),  k  is  indicated as
the  number of  analyzers  audited  during  the quarter.   If more  than  one
audit is performed on an analyzer, what is the value of k?

          A.   With  more  than  one  audit  on a given  analyzer,  k  is  the
number of  audits  performed.   For example, if two analyzers are  audited--
one twice  and the other  three times—the total  number of  audits  is five.
Therefore,  k  is  5,  which  should be used  in  the calculations  and  reported
in  Blocks   36-38  on  Form  1  (front).   The  same  procedure  would  also be
used for audits of manual methods.

     12.   Q.   On  Form  1, the upper portion  of  the leftmost block in each
group of blocks used for the reporting of the probability  limits  contains
small  +/-  signs.   Are  the + or  -  signs,  whichever applies, to be  circled,
or should a larger + or - sign be written or typed in?

          A.   The intent  of the +/- signs was  to remind those completing
the form  that either a  + or  a -  sign  must be entered  preceding  the  two
digit  value.   On  some of the  forms,  the +/- is  very faint.  It  is best
to  enter a  large + or  -  sign in  the  block,  rather  than to circle  the
appropriate sign,  or to delete the inappropriate sign.

    13.   Q.   Does  EPA  provide any guidance on the conduct of independent
performance audits?

          A.   Yes.   Details concerning the  conduct  of  performance audits
for the  TSP  flow measurement  and  for  automated  continuous  methods  for
sulfur dioxide, nitrogen  dioxide,  carbon  monoxide, and ozone  are  provided
in the EPA Quality Assurance Handbook for Air Pollution Measurement Systems,
Volume II, Section 2.0.12 (5).

    14.   Q.   Exactly  how are precision  and accuracy data  to  be  computed
when the samplers  or analyzers may be changed at a given site?
                                49

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          A.    Precision Checks
                 Automated methods - Compute results  individually  for each
analyzer-site combination  in  actual use  to obtain monitoring  data  during
each  quarter.    Determine  d  and  s for  each  analyzer-site  combination.
Combine the  results  as specified by the  formulas  in  Appendix A or  B.   In
formulas 4, 4a,  5, and 5a,  k is  the number  of  analyzer-site combinations.
                 Manual methods  -  Compute  results individually  for  each
collocated site, whether or  not changes or replacements have  been  made in
the samplers during the quarter.  Compute  d and  s  for  each  collocated site.
Combine the  results  as specified by the  formulas  in  Appendix A or  B.   In
formulas 4, 4a, 5,  and 5a,  k is the number of collocated sites.

               Accuracy Checks
                 Automated methods  - Ideally,  each analyzer-site  combina-
tion  in actual  use  to  obtain  monitoring  data  during the calendar  year
should  be  audited.   Due  to  changes of analyzers at given  sites,  this will
result in more combinations  than there  are sites.
                 In  practice,   by  the  end  of  each  calendar  year,  each
analyzer  which  has  been  used  for routine  monitoring should have  been
audited and each site should have been  audited.
                 In  planning  for  auditing,  the  "25  percent  rule"  should
take the above into account.

                 Manual methods (TSP) - Although samplers  or motors may be
changed at given sites during the calendar year, it is considered necessary
only to audit 25 percent of the sites each quarter, as a minimum.   Ideally,
each  sampler-motor  combination  used  to  obtain   routine  monitoring  data
during  the year  should be  audited.   Normally,  because of motor brush wear,
motors  or brushes  are replaced  approximately  3  times per year,  with  a
once-every-sixth-day schedule.

    15.   Q.    In addition to the audit levels  specified in the regulation,
an agency desires,  for its own purposes, to audit  at other  levels.   Are the
audit results at these other levels to  be  reported to  EPA?
                                50

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          A.   No.  Only the results at the levels specified in the regula-
tion are to be reported to EPA.

    16.   Q.   How are  the  precision and accuracy data applicable to moni-
toring data with respect to compliance to the ambient air standards?

          A.   The  precision   and  accuracy data  (probability  limits)  re-
ported  to  EPA cannot  be used  directly  in relation  to compliance  to  air
quality  standards  or   to  attainment/non-attainment  for several  reasons.
First, compliance  standards are determined from site specific information.
Any consideration  of precision  and accuracy data would be  limited to  the
specific sites  and time  periods involved.   Such  data would  be  available
only at the local agency.
               Further,  to  be  relatable  to a  standard, any precision  and
accuracy data  would have  to  be appropriately  transformed  to  (a) the same
time-averaging basis  as that  of the  air  quality standard  and  (b) to  the
same  pollutant   concentration  level   as  the  standard  on  measurements
obtained.
               In  the   determination  of  attainment/non-attainment,  other
related information may need to be considered, such as
                    a.    Time  series history  and  continuity of the pollut-
                         ant measurements at the site(s) involved
                    b.    Aggregate  frequency  distribution of the  pollutant
                         measurements  on  the  same time-averaging basis as
                         the standards at the site(s) involved
                    c.    Meteorology
                    d.    Frequency of non-compliance to standards
                    e.    Magnitude  of exceedance  of  the  monitoring  data
                         above the standard.
               The requirements for quality assurance data on precision and
accuracy were  not  established for purposes of  relating  the  information to
standards  or  to  attainment/non-attainment,   but rather  to  obtain  some
measure of  data  quality and to  improve the data  quality from the nation's
monitoring  networks,  where indicated  by  the precision  and  accuracy data.
               Until appropriate  statistical  procedures  are developed,  the
probability limits on  precision and accuracy can not be used directly with
                                51

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relation  to  meeting standards  or determining  attainment/non-attainment.
The  probability  limits  for  precision  and  accuracy  are   not  confidence
limits on true pollutant concentration levels.

    17.   Q.   Section 5.2  of  Appendix A of  the  regulation  specifies that
"simple unweighted arithmetic averages of the probability limits for
precision  and accuracy  from the  four  quarterly  periods of  the  calendar
year"  be  computed  and  reported  with  the  annual  SLAMS report.   Why are
the results  of  the  precision checks not weighted  using formulas 4a and 5a
of  section  4.1.1 (b) as  is required  for  quarterly reporting?  Also,  why
are the results of the accuracy audits not weighted?

          A.   The major reason for computing the annual limits in this way
was  the  simplicity  of  the computations—aimed  particularly  for  agencies
without sophisticated computing capability.
               For annual  precision limits,  it  may be  more statistically
correct to   compute  the  limits  weighting  the  results  from each  site  or
instrument  for  the   entire  year by  the number of precision  checks  made  on
each site or instrument by using formulas 4a and  5a.  However,  it is doubt-
ful that,  from a practical  standpoint, there will be  appreciable  differ-
ences  between  the   limits  calcualted  by  the  more  complicated  weighted
procedure and the limits calculated by simple averaging.
               For  the  more  complicated  weighted  procedure   to   be  more
correct statistically, it must be  assumed that the ratios of the numbers of
precision checks  at  given sites  or  instruments  during the  year  to the
number of ambient pollutant data  values reported from the sites or instru-
ments during the year, are essentially the same.
               For the annual  accuracy probability limits, it would be most
correct statistically  to compute the  limits by  using  the  results of all
audit checks made during the  year whether or not multiple audits have been
made  for  a  given  instrument or  site during the  year.  The  computations
would be made  using  equations 8  and 9 (not  equations 4a  and 5a) using all
of  the  audit  data   for  the year.   Here  again,  it  is doubtful that the
results will be, from  practical  standpoints,  appreciably  different  from
those using  the simple  averaging  method.   The results  of  accuracy checks
are aimed primarily  at  measuring  the correctness of the calibration system
                                52

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used  throughout  the  reporting  organization,  even  though  during  a given
quarter,  only  about one-fourth of the instruments or sites  may be audited.
If  multiple audits  are  made during  a  given  quarter  (as  some reporting
organizations  may desire to do) presumably the multiple audits of the same
instrument  or  site would  not  be performed  during the  same  month,  and
therefore,  the multiple audits would represent different audits j_n time of
the reporting  organization's calibration  system.
               Therefore,  each audit is  considered  as  a separate audit of
the calibration  system, whether or not multiple audits of the same site or
instrument  are  performed  during  any  given  quarter,  or during  the year.
               In  effect,  the sites  or instruments which have been audited
more  than  once  are given  additional weight  by  including  the  individual
results of  each  audit.

Manual Methods

    18.   Q.    For results  of the  manual  methods,  it is  stated  that at
least  25  percent of the high-volume and  Pb  samplers (Section 3.2.2 (a) of
Appendix  A) be  audited each  quarter.   Is  it required  that the duplicate
sampler in  the case of  collocated sites be included in the accuracy audits?

          A.    No.  It  is  not  required that  the  duplicate  sampler  be
audited.   Since  the designated  sampler  will be audited,  paired data from
the  two   samplers  are   available  from the  precision  check  for  accuracy
comparison.   However,  the local agency might consider it desirable to audit
the duplicate sampler.

    19.   Q.   Section  2.3.3,  Appendix A, 40 CFR Part 58,  states that flow
measurement equipment must be traceable to an authoritative volume or other
standard.    Will   the  use  of  Class A  volumetric  glassware  satisfy  this
requirement?

          A.    Yes,  if  it  is  of  sufficient   size.    For  example,  when
checking  a  wet  test meter having a 1  liter  per  revolution dial, a 2 liter
(or larger) volumetric  flask  should  be used.  Other  means  of satisfactory
traceability are (a)  commercial NBS-traceable  bubble  meters, or  (b) mass
                                53

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flowmeters calibrated with wet  or  dry test meters which are NBS-traceable.

    20.    Q.   How  are  flow  audits conducted for  the  TSP method when flow
controllers are used?  How are the  results calculated?

          A.   A  filter is  used with the orifice plate  or reference flow
device.    The  flow  rate determined by  use of  the flow  transfer  standard
considered  the  true value  (the X  value),  and the  observed level  (the  Y
value)  is  the flow  rate  indicated by the sampler's flow  indicator  or the
flow rate setting (assumed flow rate)  of the flow control device.

    21.    Q.   Can  the  collocated  high-volume  samplers use the same timers
for automatic start and stop?

          A.    Ideally,  they  should  be  operated  as  independently  as
possible to involve  all  of the variables in the measurement process.  Some
Regions require that the  collocated samplers be  independent  to the degree
that  they  are plugged  into  different electrical  outlets.   However, since
timer variation should  be  small,  a common timer  may  be permissible by the
Regional office or permit-granting authority.

     22.   Q.    In  some  cases,  for PSD  sampling, as  many as  4 (or more)
high-volume  samplers may  be used with  automatic start-stop  timers  at  a
given  site in order that the  samplers  may operate  unattended for  4 (or
more) successive  days.   Must the  collocated (duplicate)  sampler always be
used with the same designated sampler?

          A.  No.

     23.   Q.    Must the  duplicate sampler,  in such a  case,  always be the
same sampler?

          A.    No,  but  it  would  be desirable.   If  different duplicate
samplers  are  used during a report  quarter, the  results should  be examined
separately  for each  duplicate sampler.
                                54

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      24.   Q.    Can the  collocated  bubbler  samplers  use  the same  vacuum
 pump?

           A.     Ideally,  they  should  have  separate  vacuum  pumps  and  be
 independent  to the degree that  they  are plugged into  different  electrical
 outlets.   However,  from practical considerations,  a  common  vacuum pump may
 be  permissible by  the  Regional office.

      25.   Q.     For  manual  methods,  Form  1 (back)  requires the number  of
 samplers  of  each type which  are  operational  in the  network to be reported
 in  Blocks 15-17.   Are  the  duplicate  samplers  for  each  collocated site
 included?

           A.     No,  the  duplicate  samplers  are  not  counted.   The   intent
 is  to  obtain  the  number  of  SLAMS  sites  at which the  manual samplers
 (reference, equivalent, or approved methods) are being  operated.

    26.    Q.     Can the sites selected  for collocation be  changed  at any
 time?

           A.     Yes,  although  it would be  best  to  change  only  at the
 beginning  of  a  calendar quarter  or  a calendar year.   If  a  change  is made
 within  a  calendar  quarter,  the  new  site,   or sites,  shall be  treated
 separately for calculation and  reporting  purposes.   Thus,  if one  of two
 collocated sites  is  changed during a quarter, the results shall be treated
 and calculated as three separate sites.
               For  local  quality  control  purposes,  different  biases (and
 variabilities) might be expected at the new site compared to the old site.
 Therefore, the results should not be combined when calculating the averages
 and  standard   deviations  for  the  quarter.   Similarly,  if  quality  control
 charts  are maintained—as  they  should  be--at the local agency,  it  may  be
 necessary to  establish new control limits for the results from the new site.

    27.   Q.    In the case of collocated samplers, if either the designated
or  duplicate  sampler gives results  that are  below the minimum  detection
 limits, should the precision data be reported?
                                55

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               The minimum detection limits  are:

                    TSP       1 |jg/m3
                    N02      15 pg/m3 (TGS-ANSA)
                              9 (jg/m3 (sodium arsenite)
                              9 ug/m3  (sodium  arsenite  with Technicon  II)
                    S02      25 ug/m3 (for a 30 liter sample  in 10 ml  of
                                      KM absorbent)
                    Pb     0.07 ug/m3

          A.    No,  the precision data must not  be reported if  either  the
designated sampler  result  or the  duplicate sampler result  is  below  the
detection  limit.   Also note  that  if a  pair of  values  are  not  reported,
it is not to  be counted in the "No.  of valid collocated  data  pairs" entered
in blocks  58-60,  Form 1 (back).   Further,  the entry  for  blocks 30-23 "No.
of collocated  samplers  <  limit"  must include only those  readings from the
designated sampler  that have  been  used  in the computation  for precision.
precision.  Note  that the  limits  given on  Form 1  in the  block and applic-
able to data  blocks 20-23 are not the detection limits.
               The determination of the  95 percent  probability  limits  for
precision  in   no  way   changes  the   reporting  requirements of  SAROAD.   All
data,  regardless  of  concentration,   shall  continue to  be reported  in  the
standard manner.

    28.   Q.     If past  precision  results  from collocated  sites  are used
to  establish   data  validation limits,*  and the  precision  results  for  a
given  day exceed  the  established  limits,   should  the  precision  data  be
reported?

          A.     If the established  data validation limits are  exceeded due
to  excessive  lack of agreement  between  the  results  of  the  collocated
samplers  and  the  result from the designated sampler is  not reported (i.e.,
the  value  has  been invalidated),  then the  results must not  be included in
the  computations  for   reporting  precision.   The monitoring  data from both
the  designated sampler  and the duplicate  sampler should be  invalidated,
i.e., neither  should  be reported as  routine monitoring data.
                                56

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           In  some  instances,  the  excessive  difference  may  be  due  to a
 known  cause affecting only  the  duplicate (or designated) sampler  results,
 in  which case  the  result  from  the designated  (or duplicate) sampler  may
 be  reported as  monitoring data.

    29.   Q.    Is a high-volume  sampler  with an automatic flow controller
 a reference or  equivalent method?

          A.    It is considered  as  a reference method.

     30.  Q.    For  collocated high-volume  samplers,  how  should  the roofs
 of  the  two instruments be oriented?

          A.    The  high-volume   reference  method  does   not  restrict  or
 specify  the  orientation of the  ridge  of the  roof  with  respect to compass
 direction,  with  respect  to  the direction  of  predominate  wind,   or  with
 respect  to  any  other  reference.   Unless  the  region,   state,  or  local
 agency  has stipulated  some  requirement  on  the roof orientation,  as   for
 any  individual   high-volume  sampler,  then  the   roof  orientations  of   the
 collocated  samplers  should  not  be  restricted.   The   roof  orientations
 should  occur  in whatever  (random) direction  results from  the installation.
 In  other  words,  roof  orientation  variability  is  a part  of the method
 variability,  and  the  two   collocated  samplers  should   not  be made  more
 alike  than  would result  if they were  installed separately  as  individual
 samplers without regard to the other.

     31.  Q.    Will EMSL/RTP  supply excess  bubbler solutions (QC reference
 samples used in EPA performance audits) for use as audit materials?
*NOTE:   Any such data validation limits should be specified in the agency's
documented quality control  program subject to approval by the EPA Regional
Office.   Further, the  occurrence  of an excessive  lack  of  agreement should
raise questions  concerning the validity  of data  acquired  previously,  and
should initiate some corrective action investigation.
                                57

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          A.   Yes, but only if extra (spare) solutions are available.
However, it  is  not EMSL's practice to procure  a  large number of excess QC
reference samples for this purpose.   Further, the concentrations may not be
in the ranges required by the regulations.

    32.    Q.  (a)  When  monitoring  for lead in particulate matter, can the
flow audits  for  TSP  automatically be used as the flow audit data for lead?
As an example, suppose a network has a total of 16 hi-vols, 12 of which are
used for TSP and 4 of which are  used  for lead.  Must one of the 4 hi-vols
used to monitor  lead be audited each quarter?  Or could the 4 hi-vols used
to monitor lead be grouped with the 12 hi-vols used to monitor TSP, so that
each quarter,  4 of the  total  hi-vols  are audited, the ones  used  for lead
being audited randomly within the year?
              (b)  In  some  cases,  the  same hi-vol sampler  may  be  used for
both TSP  and lead.  Does this  mean  that  such samplers must  be  audited at
least twice each year, once for TSP and once for lead?

          A.  (a)  According to Section  3.22 (d) of the Pb regulation (2),
the  Pb  sites  are to  be grouped with  the TSP  sites.   The  sites  audited
should be selected at random from the entire group of sites, such that 25
percent of  the  sites  are audited each quarter.   The  results obtained from
these  audits will  be  reported  as  for   TSP  but  will  be  considered  as
representative measures  of  the  precision  of flow measurements for both TSP
and Pb.
              (b)  No.   If  a sampler is  used for  both  TSP and Pb, it need
be considered only as a single  site for auditing purposes.

     33.   Q.   Since  the  requirements  of  the regulation are considered as
minimum requirements,  some  agencies may  decide, or  some  Regional  Offices
may require,  the  use  of collocated samplers to  estimate  precision for Pb.
If so,  how will  this  fact be indicated?

          A.   It should be  indicated  by  entering a written note on Form 1
beneath data blocks 24-29 (for  Pb) stating "dup. samplers."
                                58

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      34.   Q.    Signed percentage differences of the results from collocated
 samplers  are used  for  precision estimates for N02,  S02,  and  TSP.   How are
 the signs  of  the  percentage differences  for Pb  results to be  assigned?

           A.    For  duplicate strips, one  of  the  strips,  by location of the
 strip  within the filter,  can  be considered the  "designated11  value  and the
 other,  the  duplicate.   Once the  designations are made,   the  same  designa-
 tions  should continue to be used.
                In   the  case of  duplicate  analyses of the  extract from  a
 single  strip, the  first  analysis  should  be considered as  the "designated"
 value,  and the  second,  as the  duplicate.

     35.   Q.     For  lead monitoring, some  states  and  local  agencies  prepare
 and analyze composite samples formed by  combining strips from a  number of
 filters.   In  such cases  how should  the precision  data be  obtained?

           A.    The  recommended  procedure  would be to prepare two separate
 composites  and  analyze  each  independently.   The  signed percentage  differ-
 ences  would  be obtained  by subtracting  the  first  analysis  result  from
 the  second  and  dividing  by  the first value.  The  first analysis value would
 be  considered as  the designated and reportable value.  Equations 10 and 11
 of  section  4.2.1(b),  Appendix A, would be  used in  computing the appropriate
 probability limits.   If  such  a  compositing  procedure is  used,  that  fact
 should be  indicated by entering  a written  note on  Form 1 beneath data blocks
 24  - 29 (for  Pb) stating  "duplicate composites".

     36.   Q.    Some agencies have automated analyzers  (03,  S02,  N02) with
 ranges as  high  as  5  ppm, and  some  use  ranges as  low as  0.5 ppm.   At what
 levels  should the  precision  check and the accuracy  audits  be  performed?

          A.    The  levels  of  the  precision check  and the accuracy audits
must conform  to the levels specified in the regulation.   Therefore, if the
range of  03,  S02,  or N02 analyzers  equals or exceeds 0.08  ppm  (8 ppm for
CO), the  precision  check  can be  performed within the specified  0.08 to
0.10 ppm level (8 to 10 ppm for CO).
                                59

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          It is assumed  that  most  SLAMS sites for  routine  monitoring will
have 03, S02,  and  N02  analyzers with a full-scale range of 0.50 to 1.0 ppm
(50-100 ppm  for CO).  It  is  further assumed that analyzers will  be cali-
brated  over  their  range  (or  ranges,  if  equipped  with a  range  selector
switch) of  intended use.  For  example,  if  a S02 analyzer  equipped  with  a
range selector switch is  operated with a 0.50 ppm range for routine monitor-
ing and a 1.00 ppm range for episode monitoring  and is intended to be used
at both range  settings,  then  the analyzer should be  calibrated separately
on  each range  setting.   In  this  case,  the analyzer  is audited  at three
levels  (0.03-0.08  ppm,  0.15-0.20  ppm,  and  0.35-0.45 ppm)  on the  0.50 ppm
range setting  and  it will  be audited at four  levels (0.03-0.08 ppm, 0.15-
0.20 ppm, 0.35-0.45  ppm,  and  0.80-0.90 ppm) on the 1.00 ppm range setting.
Thus,  it  will  be  audited  at  seven conditions, and  the  results will  be
reported accordingly.   If  the  range  for 03>  S02, or NOp exceeds  0.90 ppm
(even as high  as 5 ppm or 10 ppm),  or if  the range for CO exceeds 90 ppm,
then the audits are  required  at the  four levels  specified.  No audits are
required to  be reported at levels higher than 0.90 ppm for 0-,  S02, or NO,,,
or higher than  90  ppm  for CO.  However, it  would seem reasonable that the
local  agency  should for  its  own  internal  quality assurance,  calibrate
their high-range instruments  and perform audits at higher levels of expected
concentrations.

     Automated Methods

    37.    Q.     For  automated  analyzers,   Form   1  (front)  requires  the
number  of analyzers  of each  type  which are operational  in the network to
be  reported  in Blocks 15-17.   If the  state or  local  agency  is operating
a  non-reference,   non-equivalent,  or  non-approved  analyzer  at a  special
purpose site, should the  results of this analyzer be reported?

          A.     No.   The  report   applies   only  to  SLAMS  sites  which,
beginning on January 1,  1981, must  use reference,  equivalent,  or approved
methods.  If,  for  some  reason,  a state or  local  agency is permitted by the
Region  to  use  a   non-reference,  non-equivalent,  or  non-approved  analyzer
at a  SLAMS  site,   it should then  be  included.   The  same  rules  would apply
to manual  methods  as well.
                                60

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      38.   Q.    When performing  precision  checks or performance audits  for
 automated  analyzers,  the average output should  be obtained over what time
 period  of  equilibrium  response?

           A.    The  time  to  reach  equilibrium  conditions  and  the time
 period  over  which the  response should be  averaged will  depend  upon  the
 instrument and level  of the  standard being  used.   As a  rule,  it should be
 the  same  as is used to  obtain calibration data points at  the  same levels.

     39.    Q.    In some  cases,  due to  instrument replacement or scheduled
 start-up  at  a given  site,   only  one precision check may  have  been made
 on   an  automated  instrument during the  quarter.   In  such  cases,  the
 standard   deviation  is  zero  for   that  instrument.   Should  the  zero  be
 included  in the calculation  of  the pooled  standard deviation,  S ?  How is
                                                                 cl
 the  precision  result reported?

           A.    It  can be handled in one of two ways.
                1.    If precision checks are made  on the instrument during
                    the  succeeding  quarter, the  single  result  can  be held
                    over  and combined  (calculated and reported)  with the
                    results of the  succeeding quarter.
                2.   If,  for  some reason, no precision checks are performed
                    or planned to be  performed during the succeeding
                    quarter,  the single  value  could be  included in  the
                    calculation  of  the  average,  D, but not included in the
                    calculation  of   the  pooled   standard  deviation,  S .
                                                                         a

    40.    Q.    Auditing  must be  conducted with  a different standard than
that  used  for  routine  multipoint   calibration.   What  relationship  must
exist between  the  standard  used  for accuracy  auditing and the  standard
used for routine multipoint calibration?

          A.    The general  rule is:   The working  standard used  for  the
accuracy audit  must be  different from the working standards used for cali-
bration, but  both may  be  certified  (referenced)  against the same  NBS SRM
or CRM.   A protocol for certifying the working calibration or audit
                                61

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standard against  an SRM or CRM  is  given  in Section 2.0.7  in  Reference  5.
(CRM's  were  authorized  for use  as traceable  standards  by amendments  to
40 CFR Parts 50 and 58 on January 20,  1983 (48 FR 2528-2530)).

     41. Q.    Can the NBS  SRM traceability  requirement  be met if  I  use a
NBS "traceable" cylinder gas or permeation tube from a commercial  supplier?

          A.    Yes,  but  caution  should be exercised and  complete  certifi-
cation  documentation  should  be  received  with  the NBS-traceable  items.

     42.  Q.    The regulations  state  the "Direct  use  of an NBS  SRM  as a
working  standard  is  not prohibited  but  is  discouraged  because  of  their
limited  supply  and expense."  Should  NBS SRM's  be used  for  the  accuracy
audits?

          A.    No.  As  stated  in the  regulations, NBS SRM's are in limited
supply,  and  should be  used only sparingly as references  to which working
calibration  standards  (and  accuracy audit standards) are  assessed.   CRM's
may also be used  in  lieu  of  NBS SRM's;  see answer to  previous  question.

     43.  Q.    In some networks,  the output from automated analyzers is fed
into a data logger or minicomputer or  transmitted by telemetry  to a central
station or computer.  When conducting  a performance audit, at what point in
the total  measurement  system  should  the  observed or  measured   value  be
obtained?

          A.    The  observed or  measured  value  should  be obtained at the
same  point  and  in the  same  manner  that  routine monitoring  data  are
obtained.  In other words,  the performance audit should be an  audit of the
entire   routine  measurement  system—not   just  the analyzer.    (The  same
conditions should apply for the calibration process.)  If the normal output
of an  analyzer  is measured  and reduced by  a  computer in another location,
the performance audit  result  (and calibration data) should  be  obtained in
the same way.   Since  there is  usually a major  concern  for the  analyzer,
however, it would be good practice to  also check its output with a (digital)
voltmeter or recorder.   It  is possible that the analyzer could  be
                                62

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functioning perfectly but  the  rest of the  system  could  be malfunctioning,
or vice versa.

     44.  Q.    Some automatic instruments have daily (i.e., every 24-hours)
automatic injections  for  zero.   In the normal  reduction  of  data,  the data
between  successive automatic  zero injection checks  are corrected  by  the
average  of  the "before"  and "after"  zero  drifts.   Since the  regulations
state  that  the  precision check  should  be made  prior to any  adjustment,
what should  be the  procedure  for calculating the  result  of the precision
check for this type of instrument?

          A.    The  procedure is  the  same as that  used for routine ambient
measurements:   the  precision check reading  should  be  processed  exactly  the
same as  it  would be  if it  were  an ordinary ambient  reading.   If  the zero
injections occur  on  a  fixed schedule, then,  to the  extent possible,  the
precision checks should be randomly timed,  i.e., at various times of day or
at various times  with respect  to the automatic cycle.  The same would also
apply to  automatic  span cycles.   See also the answer to the next question.
In either case,  do not make any  adjustments  to the instrument until after
the above checks have been performed.

     45.   Q.     Some  instruments (Beckman  866)  have  built-in  automatic
electronic stabilizers  which readjust zero and span every 8 hours based on
the  automatically  performed zero  and span checks.   When should precision
checks and accuracy audits be performed?

          A.    Ideally, the  precision checks  and accuracy audits should be
performed at random  times  between instrument adjustments.  If the schedule
of the  automatic adjustments  is known to  those performing  the precision
checks and accuracy audits, the precision checks and accuracy audits should
be scheduled at  random times between  the  adjustments.   If the schedule of
the automatic adjustments is not  known to these persons,  then the precision
checks  and  accuracy  audits could be  performed at  any  time of  the day.
(See also the answer  to the previous question.)
                                63

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     46.  Q.    Some ozone  analyzers  are operated  only  six months  of the
year.    How  shall  precision and  accuracy data  be  obtained and  reported?

          A.    Precision  checks will  be made on all  operating monitoring
instruments  on the  minimum biweekly  frequency  specified;  no  special  con
siderations need to be made; except in the unlikely case  where only a single
precision  check is  made  in  a  quarter.   Because  the standard  deviation
cannot be computed from the single value, the result of the precision check
should  be  held and  combined  with  data  for the  previous or  subsequent
quarter,  as appropriate.    Therefore,  if no  precision check (or  only one
precision check)  is made  in  a  given  calendar quarter,   no precision data
will be reported.
               The   purpose  of  obtaining   the   precision  data  is  to
relate  it to  scheduled  monitoring  data, there would be  no purpose  in ob-
taining precision data when no monitoring data are being obtained.
               The  regulations  require  that all  operating analyzers  be
audited during the  year.    If ozone analyzers  are  operated only six months
(e.g.,  two  quarters),  then 50  percent of  the  analyzers  must  be audited
each  quarter.    If  the  six-month  period  covered  more  than two  quarters
(e.g.,  May  through  October),  some analyzers  could  be scheduled for audit
in  each of  the three quarters.  If  only one audit  is performed in a given
quarter,  the audit  results should be  reported with  audits of the previous
or  following quarter,  since a  standard  deviation  cannot  be calculated for
a single  value.

     47.   Q.    Philips S0? instruments  require  a  new calibration whenever
the reagent is changed—approximately every  90 days.  When should accuracy
audits  be performed?

          A.    Accuracy audits  (and  precision checks) should be  performed
at  random times  between  multipoint calibrations or other  adjustments  of the
analyzer.    Consequently,   neither  accuracy  audits  nor   precision   checks
should  be performed immediately after  such calibrations or  adjustments.  To
minimize  costs, (i.e., to  eliminate  extra  trips  to sites)  accuracy  audits
and precision  checks  could be  performed  just before such  calibrations or
adjustments.   Since  the  Phillips  S02  instrument  may  have has  automatic
                                 64

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daily  zero  and   span  checks  and  adjustments,  the  precision checks  and
accuracy  audits   should  be made  at  random  times  between such  automatic
adjustments (or immediately before such adjustments).

11.  REFERENCES

     1.    Code of Federal  Regulations,  Title  40, Part  58,  "Ambient  Air
          Quality  and  Surveillance,"  promulgated  on  May  10,  1979  (44  FR
          27571).

     2.    Code of Federal Regulations, Title 40,  Part  58,  as amended Septem-
          ber 3,  1981,  (46 FR 44159-44172).

     3.    Guideline for  Lead  Monitoring  in the Vicinity of  Point Sources,
          EPA-450/4-81-006, January 1981.

     4.    Summary of Audit Performance,  Measurement of S02, N02,  Sulfate,
          Nitrate, Lead,  Hi-Vol  Flow Rate—1978,  EPA-600/4-80-017, Environ-
          mental  Monitoring Systems Laboratory,  Research Triangle  Park,  NC.,
          June 1980.

     5.    Quality Assurance Handbook for  Air Pollution Measurement Systems,
          Volume   II, Ambient  Air  Specific  Methods, EPA-600/4-77-027a,  U.S.
          Environmental   Protection  Agency,  Research  Triangle  Park,   NC,
          June 1977.

     6.    "Ambient  Monitoring  Guidelines  for  Prevention  of   Significant
          Deterioration  (PSD), EPA-450/2-78-019,  May 1978.

     7.    Implementation  of Air Quality Monitoring  Regulations, Color Video
          Tapes,  4 hours  (condensed  version  of workshops  conducted at  each
          Regional Office,  April-June,  1979,  on  Section  319  of   the  1977
          Amendments to  the Clean Air Act and  40 CFR  58).   On  free  loan
          from USEPA Air Pollution  Training Institute, Research  Triangle
          Park, North Carolina.
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8.    "A  Procedure  for  Establishing Traceability  of Gas  Mixtures  to
     Certain  National   Bureau  of  Standards SRMs."  EPA-600/7-81-010,
     U.S.  Environmental  Protection Agency,  Research Triangle  Park,
     North Carolina 27711.  May, 1981.
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