U. S. EPA Ambient Air Monitoring
Protocol Gas Verification Program
Implementation Plan
2nd DRAFT 7/2009
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AA-PGVP DRAFT 7/2009
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U. S. EPA Ambient Air Protocol Gas Verification Program
Implementation Plan
DRAFT 7/2009
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Air Quality Assessment Division
Research Triangle Park, NC
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Table of Contents
Acknowledgements v
Acronyms and Abbreviations vi
1.0 Introduction 1
1.1 Background and Program Goals 1
1.2 Program Summary 3
1.3 Purpose of This Document 5
2.0 Roles and Responsibilities 6
2.1 AA-PGVP Advisory Group 6
2.2 National Association of Clean Air Agencies 6
2.3 Tribal Air Monitoring Support Center Steering Committee 6
2.4 EPA Office of Air Quality Planning and Standards 7
2.5 Region 7 and 2 RAVL 8
2.6 Monitoring Organizations 9
2.7 U.S. EPA Office of Research and Development 10
2.8 Specialty Gas Producers 10
3.0 Resources 11
3.1OAQPSCosts 11
3.2 RAVL Costs 11
4.0 Logistics 12
4.1 Acquisition of Protocol Gases 12
4.2 Shipments of EPA Protocol Gases to the RAVL 12
4.3 Shipments of EPA Protocol Gases to Monitoring Organizations 13
5.0 Quality System Development 14
5.1 The AA-PGVP Quality Assurance Project Plans and SOPs 14
5.2 Quality Control Activities 14
5.3 Other QA Activities 16
6.0 Information Management/Reporting 17
6.1 Information Needed for AA-PGVP 17
6.2 Verification Reports 18
7.0 Annual AA-PGVP Timeline 20
8.0 References 23
9.0 Appendices 24
Appendix A- Monitoring Organization Annual Survey 25
Appendix B- Chain of Custody Form 26
Appendix C- Protocol Gas Verification Cylinder Tracking Form 27
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ACKNOWLEDGEMENTS
The following individuals are acknowledged for their contributions to this project:
Mark Shanis US EPA, Office of Air Quality Planning and Standards
Joe Elkins US EPA, Office of Air Quality Planning and Standards
Bob Wright US EPA, Office of Research and Development
Michael Davis US EPA Region 7
Lorenzo Sena US EPA Region 7
James Regehr US EPA Region 7
Leland Grooms US EPA Region 7
Thien Bui US EPA Region 7
Avi Teitz US EPA Region 2
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ACRONYMS AND ABBREVIATIONS
AA-PGVP Ambient Air Protocol Gas Verification Program
AQS Air Quality System
CAMD Clean Air Markets Division
CFR Code of Federal Regulations
COC chain-of-custody
EPA Environmental Protection Agency
EPRI Electric Power Research Institute
GMIS Gas Manufacturer's Internal Standard
1C AC Institute of Clean Air Companies
NAC AA National Association of Clean Air Agencies
NBS National Bureau of Standards
NERL National Exposure Research Laboratory
NIST National Institute of Standards and Technology
NMi Netherlands Measurement Institute
NPAP National Performance Audit Program
NTRM NIST Traceable Reference Material
OAQPS Office of Air Quality Planning and Standards
OAP Office of Atmospheric Programs
ORD Office of Research and Development
QA quality assurance
QAPP quality assurance project plan
QC quality control
RAVL Regional Analytical Verification Laboratory
SOP standard operating procedure
SRM Standard Reference Material
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1.0 INTRODUCTION
1.1 Background and Program Goals
The basic principles of the U.S. Environmental Protection Agency (EPA) Traceability Protocol
for the Assay and Certification of Gaseous Calibration Standards (EPA, 1997) were developed
jointly by EPA, the National Bureau of Standards (now National Institute of Standards and
Technology [NIST]), and specialty gas producers over 30 years ago (Scott Environmental
Technology, 1977a and b). At the time, commercially-prepared calibration gases were perceived
as being too inaccurate and too unstable for use in calibrations and audits of continuous source
emission monitors and ambient air quality monitors (Decker et al., 1981). The protocol was
developed to improve their quality by establishing their traceability to NIST Standard Reference
Materials (SRMs) and to provide reasonably priced products. This protocol established the gas
metrological procedures for measurement and certification of these calibration gases for EPA's
Acid Rain Program under 40 Code of Federal Regulations (CFR) Part 75, for the Ambient Air
Quality Monitoring Program under 40 CFR Part 58, and for the Source Testing Program under
40 CFR Parts 60, 61, and 68. EPA required monitoring organizations implementing these
programs ("the regulated community") to use EPA Protocol Gases as their calibration gases.
The protocol has never specified that EPA Protocol Gases would have any given uncertainty and
it has never established acceptance criteria for the uncertainty. In 1997, EPA revised the
protocol to establish detailed statistical procedures for estimating the total uncertainty of these
gases (EPA, 1997). The total uncertainty can be less that +/- 2.0 percent relative, which is the
acceptance criterion that is required for EPA's Acid Rain Program (EPA, 1993).
Specialty gas producers prepare and analyze EPA Protocol Gases without direct governmental
oversight. EPA chooses to assure the quality of these gases by conducting independent accuracy
assessments of representative gases that are sold by the producers as part of their routine
production. In the 1980s and 1990s, EPA conducted a series of EPA-funded accuracy
assessments of EPA Protocol Gases sold by producers (Wright et al., 1987 and 1989, Coppedge
et al., 1992, Hines et al., 1992 and 1993, Shores et al., 1994). The intent of these audits was to:
increase the acceptance and use of EPA Protocol Gases as calibration gases;
provide a quality assurance (QA) check for the producers of these gases; and
assist users to identify producers who can consistently provide accurately certified gases.
Either directly or through third parties, EPA procured EPA Protocol Gases from the producers,
assessed the accuracy of the gases' certified concentrations through independent analyses, and
inspected the accompanying certificates of analysis for completeness and accuracy. The
producers were not aware that EPA had procured the gases for these audits.
The accuracy of the EPA Protocol Gases' certified concentrations was assessed using SRMs as
the analytical reference standards. If the difference between the audit's measured concentration
and the producer's certified concentration was more than +/- 2.0 percent or if the documentation
was incomplete or inaccurate, EPA notified the producer to resolve and correct the problem.
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The results of the accuracy assessments were published in peer-reviewed journals and were
posted on EPA's Technology Transfer Network website (http://www.epa.gov/ttn/).
The accuracy assessments were discontinued in 1998. In 2002, there was interest by the
specialty gas producers and EPA to reestablish this program. EPA-OAQPS and EPA Region's 7
and 2 are working together to develop an Ambient Air Protocol Gas Verification Program (AA-
PGVP). This program is expected to:
ensure that producers selling EPA Protocol Gases participate in the AA-PGVP and
provide end users with information about participating producers and verification results.
The EPA Ambient Air Quality Monitoring Program's QA requirements 40 CFR Part 58,
Appendix A require:
2.6 Gaseous and Flow Rate Audit Standards. Gaseous pollutant concentration
standards (permeation devices or cylinders of compressed gas) used to obtain test
concentrations for CO, SO 2, NO, and NO 2 must be traceable to either a National
Institute of Standards and Technology (NIST) Traceable Reference Material (NTRM),
NIST Standard Reference Materials (SRM) and Netherlands Measurement Institute
(NMi) Primary Reference Materials (valid as covered by Joint Declaration of
Equivalence) or a NIST-certified Gas Manufacturer's Internal Standard (GMIS),
certified in accordance with one of the procedures given in reference 4 of this appendix.
Vendors advertising certification with the procedures provided in reference 4 of this
appendix and distributing gases as "EPA Protocol Gas" must participate in the EPA
Protocol Gas Verification Program or not use "EPA " in any form of advertising.
These requirements give assurance to end users that all specialty gas producers selling EPA
Protocol Gases are participants in a program that provides an independent assessment of the
accuracy of their gases' certified concentrations. The participating producers will be contacted
by EPA when the Region 2 or 7 analytical verification laboratory (RAVL) has measured their
gases and they may expect to see the verification results reported in peer-reviewed journals and
on EPA website(s).
This program is considered a verification program because its current implementation level does
not allow for a large enough sample of EPA Protocol Gases to be measured to yield a statistically
rigorous assessment of the accuracy of any producer's gases. It will not provide end users with a
scientifically defensible estimate of whether gases of acceptable quality can be purchased from a
specific producer. Rather, the results provide information to end users that may inform their
purchasing decisions. The final verification results will be reported with and explanation on how
the results should be interpreted.
Figure 1 provides a comprehensive description of the processes by which the program will be
implemented and will be used throughout this document to describe the processes in the sections
that follow. Important functions are identified by the lines of different colors or line type.
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Planning
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Figure 1 Ambient Air Protocol Gas Verification Program Flowchart
1.2 Program Summary
Goal
Each year, EPA will attempt to compare gas cylinders from every specialty gas supplier being
used by ambient air monitoring organizations. Regions 7 and 2 have agreed to provide analytical
services to provide verifications of 40 cylinders/lab or 80 cylinders total/year. Cylinders will be
verified at a pre-determined time each quarter.
Yearly Selection
A Protocol Gas Advisory Group composed of OAQPS, NACAA, a tribal representative from the
Tribal Air Monitoring Support (TAMS) Center Steering Committee and Region 7 and 2 will
decide the number, composition and concentration of the EPA Protocol Gases that will be
verified in a given year. NACAA will assist in advertising and selecting ambient air monitoring
organization participants. The selection goal in the following order would be:
1) Minimum one gas standard from every specialty gas vendor being used by the monitoring
community
2) Selection of a minimum of 3 standards per specialty gas vendor
3) Weight additional standards by vendor market share in ambient air monitoring
community.
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Analysis
The verification laboratories will set up a 2-3 week period each calendar quarter for cylinder
verification analysis. Generally it is assumed that the analysis would be scheduled around the
end of each quarter. Monitoring organizations would work with EPA each quarter in order to get
the appropriate cylinders sent to EPA in time for the analysis. The analytical technique will be
forthcoming in the form of standard operating procedures and a quality assurance project plan.
Funding
Federal Funding ~
OAQPS will cover the majority of the costs for the AA-PGVP. Costs will cover the purchase of
standard reference materials (SRMs) and equipment as necessary.
Monitoring Organizations
In order to maintain the "blind" nature of the AA-PGVP, EPA will receive cylinders from the
monitoring organizations after they have purchased them from the specialty gas vendors.
Monitoring organizations participating in the program will be expected to fund the
shipping/transporting of the gaseous standards from their monitoring facility to the Region 7 or 2
RAVL. EPA will cover the costs of shipping cylinders back to the appropriate monitoring
organization.
NOTE: In order to ship cylinders to EPA, monitoring organizations will need to
trained/certified for shipping have hazardous materials under 49 CFR Part 172.704
Verification Results
The RAVL will provide results from its analyses of the gases and will determine the uncertainly
between its measured concentration and the producers' certified concentration (tag value) as
described in EPA Traceability Protocol for Assay and Certification of Gaseous Calibration
Standards (EPA, 1997). This information, once validated, will be sent to OAQPS which will
directly notify the specialty gas producers, the monitoring organization providing the cylinder,
and will indirectly notify all interested parties by posting the verification results on an
appropriate EPA web site(s).
Protocol Revisions
EPA, in consultation with the producers, will assess the need to revise EPA Traceability Protocol
for Assay and Certification of Gaseous Calibration Standards (EPA, 1997) from time to time
and will revise this document as deemed necessary. These revisions will ensure that the protocol
includes any new gas metrological techniques and statistical analysis procedures.
Technical Assistance
The RAVL may need to communicate with the participating producers in order to determine how
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specific EPA Protocol Gases were prepared or certified. OAQPS will initiate and be included in
any communication needed with participating producers.
1.3 Purpose of This Document
The purpose of this document is to provide the necessary technical, logistical, and administrative
information to successfully implement the program. The specific purposes include identifying:
- each phase of the program and explaining how it will be implemented;
- roles and responsibilities of all participating organizations;
specific lines of communication between and among all participants and stakeholders;
pertinent milestones involved with this program;
- resources required for successful implementation;
- identifying the logistical elements required for this program;
QA and quality control (QC) procedures; and
reporting components.
Once this document has been finalized, all participants are expected to implement the program as
set forth in this document unless there is a consensus decision by the AA-PGVP Advisory Group
that changes are required. The AA-PGVP Advisory Group is responsible reviewing this
document from time to time and for making any subsequent changes to this program.
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2.0 ROLES AND RESPONSIBILITIES
See Figure 1 for a graphic representation of the relationships between and among the various
AA-PGVP stakeholders.
2.1 AA-PGVP Advisory Group
The AA-PGVP Advisory Group consists of representatives from OAQPS, National Association
of Clean Air Agencies (NACAA), Tribal Air Monitoring Support (TAMS) Center Steering and
Regions 7 and 2 management and laboratory staff and is responsible for facilitating and
coordinating communications and agreements among the various stakeholder organizations (e.g.,
specialty gas producers) involved in the AA-PGVP.
The AA-PGVP Advisory Group is responsible for reviewing this document from time to time
and for making any needed changes to this program.
The AA-PGVP Advisory Group is responsible for selecting, on a yearly basis, the number,
composition, and concentration of the EPA Protocol Gases to be verified. It will come to a
consensus decision via meetings, teleconferences, and/or e-mails as appropriate.
The AA-PGVP Advisory Group is responsible for the development of the verification reports
(see Section 6)
2.2 National Association of Clean Air Agencies (NACAA)
NAACA is responsible for selecting a representative to the AA-PGVP Advisory Group to serve
for a defined term. The NACAA representative is responsible for appropriate communication
about the AA-PGVP with the members of that organization and advertising for participation in
the program among the monitoring community (including Tribal monitoring organizations).
NAACA will help implement an annual survey of all specialty gas vendors providing gaseous
standards to the monitoring organizations. From this list the AA-PGVP Advisory group will
attempt to select cylinders that cover all specialty gas producers and identify the monitoring
organizations willing to participate in the PVGP.
2.3 Tribal Air Monitoring Support (TAMS) Center Steering Committee
The mission of the TAMS is to develop tribal capacity to asses, understand, and prevent
environmental impacts that adversely affect health, culture, and natural resources. Fundamental
to the TAMS mission is technical training of tribal professionals and technical assistance is air
quality measurements. The TAMS Steering is responsible for selecting a representative to the
AA-PGVP Advisory Group to serve for a defined term. The TAMS representative is responsible
for appropriate communication about the AA-PGVP and advertising for participation in the
program among the tribal monitoring community
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2.4 EPA Office of Air Quality Planning and Standards (OAQPS)
OAQPS has overall technical oversight responsibilities for the AA-PGVP. It has the
responsibility for disseminating information about the program and verification results to other
government entities, producers, the regulated community, other interested parties, and the
general public.
OAQPS is responsible for forming the AA-PGVP Advisory Group. It is responsible for
identifying representatives of government, and the ambient air monitoring community who can
serve in the group. The EPA point of contact will coordinate a yearly conference call/meeting of
the AA-PGVP Advisory Group in which the number, composition, and concentration of the EPA
Protocol Gases to be verified will be selected. The EPA point of contact will be identified on
appropriate EPA websites. The EPA point of contact will also coordinate quarterly conference
calls to discuss program progress and issues.
A unique identification number will be assigned by EPA to each manufacturing location that
participates in the program. The unique identification number may be used by EPA's National
Performance Audit Program (NPAP) when it performs audits of ambient air monitoring
organizations and may be used in reporting this data to AQS.
Upon receipt from the AA-PGVP Advisory Group the list of cylinders and their producers for
the current year, OAQPS is responsible for publishing and disseminating a list of the
participating manufacturing locations and the associated identification numbers on an EPA
website so that all end users can identify which manufacturing locations are participants in the
program and so that they can record the identification numbers in their monitoring records as
needed.
OAQPS is responsible for notifying each participating producer about whether that producer's
certified concentrations (tag value) and the RAVL's corresponding calculated measured
concentrations for a specific EPA Protocol Gas differ by more than the acceptable value, but it
will not disclose the specific values of the measured concentrations to the producer. It will
notify each producer separately. The draft verification results for a producer will not be shared
with anyone but that producer. Verification results will include time and date of the verifications
and the analyzers used in the test as well as any supporting information (e.g QC results) needed
by the producer.
OAQPS is responsible for publishing and disseminating the final verification results with
appropriate caveats and the certificate inspection results by posting them on an EPA website that
is accessible to the public. Any producer-reanalyzed concentrations will be posted by EPA in a
separate column of the final verification results adjacent to the producers' original certified
concentrations with a footnote indicating which manufacturing location performed the
reanalysis. EPA will send the final verification results directly to the AA-PGVP Advisory
Group, and the participating producers. It may prepare papers concerning the verification results
for presentation at professional meetings and for publication in the professional literature.
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OAQPS is responsible for establishing and maintaining the archives of all AA-PGVP
verifications. OAQPS will determine whether AQS can accept this information.
OAQPS is responsible for preparing a quality assurance project plan (QAPP) for its respective
portion of the AA-PGVP. The QAPP will conform to EPA Requirements for Quality Assurance
Project Plans (EPA, 2001). This document will be submitted to the AA-PGVP Advisory Group
for comment and EPA OAQPS and Regional verification laboratories for joint review and
approval.
OAQPS is responsible for establishing tracking and chain of custody procedures for shipment of
EPA Protocol Gases to and from monitoring organizations.
2.5 Region 7 and 2 Regional Analytical Verification Laboratories
The RAVL are responsible for negotiating resource needs with OAQPS, to accept and log
gaseous cylinders arriving at the lab, analyze these cylinders within 3 weeks of receipt, report the
verification results and certificate inspection results to OAQPS, and to ship these gases back to
the monitoring organizations.
To ensure the validity of the verification, the monitoring organizations gaseous standards must
be delivered to the laboratory in the same condition as when they were delivered to the
monitoring organizations. The AA-PGVP must be able to document that the gases are delivered
to the laboratory without being altered in any manner. Any use of or tampering with the gases
prior to their measurement would render the verification results as questionable. The RAVL are
responsible for the receipt and custody of EPA Protocol Gases received from monitoring
organizations using the chain of custody form in Appendix B and entering the appropriate fields
into the AA-PGVP Database. It is responsible for quarantining these gases securely to prevent
tampering until they are measured. The laboratory is responsible for communications associated
with receipt and custody of EPA Protocol Gases from the monitoring organizations.
The RAVL are responsible for preparing a QAPP for its respective portion of the AA-PGVP.
The QAPP will conform to EPA Requirements for Quality Assurance Project Plans (EPA,
2001). The laboratory's QAPP will contain a description of its plan for attaining its project
objectives, project organization, chain-of-custody procedures, the analytical instrumentation, the
gas metrological techniques, the analytical reference standards, laboratory record-keeping
procedures, and the mathematical and statistical procedures that were used in the calculation of
the measured concentrations and their estimated total uncertainties as described in Appendix B
of EPA Traceability Protocol for Assay and Certification of Gaseous Calibration Standards
(EPA, 1997). The QAPP will be submitted to EPA for review and approval.
The RAVL is responsible for determining the composition and concentration of EPA Protocol
Gases that are sent from the monitoring organizations. It will use analytical instrumentation and
gas metrological procedures that are interference-free and NIST standard reference material
(SRM) for its analyses of these gases. It will calculate the difference between its' measured
concentration and the specialty gas producer's certified concentrations for these gases and
estimate total uncertainty using accepted and documented statistical techniques. The laboratories
will operate all year round but will set up a schedule each quarter for analysis.
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The RAVL is responsible for inspecting the EPA Protocol Gases' certificates of analysis to
determine their conformance with the documentation requirements of the EPA traceability
protocol, including verification of the NTRM or SRM numbers used in the analysis against the
NIST inventory of these standards. If a GMIS is used in the analysis, it's traceability to NIST
must be indicated on the certificate of analysis. This information will be included in the AA-
PGVP database.
Upon completion of its measurements, the RAVL will prepare draft verification results (see
Section 6.2) for OAQPS and monitoring organization review.
The RAVL may elect to provide technical assistance to those producers that request such
assistance or to those whose EPA Protocol Gases have differences that exceed the +/- 2.0 percent
accuracy acceptance criterion of 40 CFR Part 75. Upon receipt of the results of the producers'
reanalysis, the RAVL will report the reanalyzed concentrations, along with the original RAVL
results, to EPA in its final verification results. It is responsible for sending the certificates and
its inspection results with the final verification results to OAQPS.
Upon completion of its analyses and the resolution of any verification-related issues, the RAVL
will ship the EPA Protocol Gases using chain of custody procedures back to the monitoring
organization. The RAVL will be responsible for the cost of these shipments.
2.6 Monitoring Organizations
The monitoring organizations that are conducting monitoring under 40 CFR Parts 58 are
responsible for purchasing EPA Protocol Gases only from those specialty gas producers who
participate in the AA-PGVP. Their monitoring documentation will include the manufacturing
location's unique identification number.
Monitoring organizations will work with NAACA to identify the universe of specialty gas
producers providing protocol gases. This will entail providing information on a survey (see
Appendix A) and posted on an appropriate website. The survey will also be used for monitoring
organizations to indicate whether it plans to purchase protocol gas in the upcoming calendar year
and whether it would like to be an active participant in the program (shipping cylinders for
verification).
The participating monitoring organizations will be placed on a list that includes the approximate
timeframe of cylinder purchase and will be required to notify the RAVL one month prior to the
monitoring organizations receipt of cylinder in order to set up a reasonable timeframe for the
laboratory to set up a verification schedule. It is anticipated that the labs will set up a quarterly
analysis schedule. Therefore, the monitoring organizations must work within that schedule and
in general be able to have the protocol gas cylinder be at the verification lab for a maximum of 6
weeks.
The monitoring organizations will send a chain of custody form (see Appendix B), the stamped
cylinder numbers, the composition, the certified concentrations and certified cylinder pressures
to the RAVL. This information will be used by the laboratory to help to ensure that it receives
and analyzes all the gases that are intended to be verified and no others.
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The monitoring organizations will notify the RAVL the day that the protocol gases are shipped.
The gases must be delivered with the same internal pressure as indicated on their certificates of
analysis. They must have at least 6 months left in their certification periods.
As mentioned is Section 1, in order to ship cylinders to EPA, monitoring organizations
will need to be trained/certified for shipping have hazardous materials under 49 CFR
Part 172.704. As part of the participation survey, EPA will ask monitoring
organization whether they have this training certificate. For those who do not but
would like to participate in the AA-PGVP, EPA is looking into the costs associated
with on-line or web based training seminars.
Monitoring organizations will receive results of verifications within 3 weeks of the analysis. If
results are outside the acceptance windows, the analytical lab will attempt to verify/ensure that
its analytical activities were appropriate (see QA Section). The RAVL will work with the
monitoring organization on other reasonable trouble shooting techniques but it is not responsible
for any specific corrective action. The monitoring organizations will be responsible for
determining further corrective action steps once cylinders are sent back to the monitoring
organizations.
Primary Quality Assurance Organizations and Reporting Organizations
For QA purposes EPA defines the primary quality assurance organization (PQAO) as a
monitoring organization or a coordinated aggregation of such organizations that is responsible
for a set of stations that monitors the same pollutant and for which data quality assessments can
logically be pooled. Each criteria pollutant sampler/monitor at a monitoring station in the
SLAMS network must be associated with one, and only one, primary quality assurance
organization. However, there are a number of local reporting organizations that have
consolidated to fewer PQAOs. These reporting organizations may use different gaseous
standards even though they are associated with the same PQAO. EPA will survey participation
in the AA-PGVP at the PQAO level. It will be the responsibility of the PQAO to survey the
reporting organizations within the PQAO.
2.7 U. S. Environmental Protection Agency (EPA) Office of Research and
Development (ORD)
ORD, in consultation with the specialty gas producers, is responsible for revising the EPA
Traceability Protocol for Assay and Certification of Gaseous Calibration Standards from time to
time to reflect technological advances in gas metrology and statistics. It has the responsibility
for publishing the revised protocol and posting it on an appropriate EPA website that is
accessible to the public.
2.8 Specialty Gas Producers
Specialty gas producers must prepare and analyze EPA Protocol Gases according to the current
version of the EPA Traceability Protocol for Assay and Certification of Gaseous Calibration
Standards. The producer's unique identification number for the manufacturing location preparing
an EPA Protocol Gas, if one exists, must be included in the certificate of analysis for the gas. If
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a unique code does not exist EPA will designate codes for each producers manufacturing site.
If a producer has been informed by EPA that the draft verification results for a specific EPA
Protocol Gas and the producer's corresponding certified concentrations differ by more than the
acceptable uncertainty, then it may choose to have that gas reanalyzed by its manufacturing
location or by another laboratory at its own expense. The producer must report the results of the
reanalysis to EPA by February 1 of the year following verification in order to include this
information in final reports by March of the year following verification.
There may be cases where, based on the survey results, specialty gas producers will not be used
by monitoring organizations for a particular year. In addition, the specialty gas producers may
want to provide cylinders for verification as a way of testing the verification process. If
resources permit, EPA will try to accommodate these verifications by setting up a specific
timeframe when these verifications can be implemented.
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3.0 RESOURCES
It is expected that the majority of the resources needed for this program will be covered by
internal EPA base QA funding. This section will explain the funding sources, funding
mechanisms, and program cost estimates needed to implement the AA-PGVP.
3.1 OAQPS Costs
It is not anticipated that OAQPS will need additional in-house resources for this program. EPA
will provide for regional costs through internal base QA funds that support regional activities.
EPA will devote 0.15 FTE for the planning year and 0.10 FTE in out years.
3.2 RAVL Costs
Table 3-1 provides an estimate cost to the Region 7 and Region 2 analytical laboratory. This
estimate assumes approximately 40 cylinders/lab verified each year.
Table 3.1 Estimated AA-PGVP Costs
Startup Cost:
Region 7
Region 2
Comments
NIST SRM Gas Standards
$9,000
9,000
3 NIST SRM cylinders/lab
Gas Calibrator
$14,500
Data Logging System
4,500
Regulators
$1,000
$1,000
Miscellaneous Supplies
$2,000
$4,000
Startup Total
$31,000
$14,000
Annual Operating Cost
Shipping (40X$80)
NIST SRM Standard replacement
Equipment replacement
Miscellaneous Supplies
Repair parts
Annual Operating Cost Total
$3,200
$9,000
$4,500
$2,000
$1,000
$19,700
$3,200
$9,000
$4,500
$2,000
$1,000
$19,700
Purchase of new instrument every 3 year.
It is currently anticipated that the analytical verification lab analysis will be implemented by
federal employees at an estimate of 0.20 FTE/year/lab.
NIST Standard Reference Materials (SRMs)
The Regional verification laboratories will purchase the NIST SRMs listed in Table 3-2. The
verification laboratories will work with NIST at appropriate timeframes to ensure an
uninterrupted supply of gases are available for the program.
Table 3-2 NIST SRMs used in AA-PGVP
Analyte
CO
NO
SO2
SRM Number
SRM 2639a
SRM 1683b
SRM 1693a
Concentration 1
10,000 ppm 1
50 ppm 1
50 ppm |
SRM Number
SRM 2637a
SRM 1684b
SRM 1694a
Concentration
2500 ppm
100 ppm
100 ppm
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4.0 LOGISTICS
The AA-PGVP objective, from a logistics standpoint, involves shipping the EPA Protocol Gases
from the producers to the monitoring organizations, from the monitoring organizations to the
RAVL, and finally the RAVL shipping the standards back to the monitoring organizations.
4.1 Acquisition of Protocol Gases
The monitoring organizations are responsible for purchasing of EPA Protocol Gases to be
analyzed by the RAVL. The goal of the AA-PGVP is to ensure that the acquisition of the
protocol gas from the specialty gas producer appears as a routine purchase and is the reason the
monitoring organizations will purchase the cylinders and ship them new and unused to the
RAVL.
The RAVL will purchase NIST SRM standards to be used for the verification process. Dates of
certifications and recertification will be included in the AA-PGVP database.
4.2 Shipments of EPA Protocol Gases to RAVL
RAVL Identification
Since 2 laboratories (Regions 2 and 7) will participate in the program, during the annual planning
activity, the participating monitoring organizations will be identified with a particular RAVL.
The pairing will most likely be made by geographic location but the pairing may be based on
types and concentrations of standards needing certifications and the SRMs at a particular RAVL.
Verification Scheduling
Each calendar quarter, a two or three week window will be identified for the cylinder
verifications. Initial scheduling of a monitoring organization for a particular quarter will be
based on the annual monitoring organization survey which includes information on when a
monitoring organization participant plans to purchase protocol gasses. The RAVL will contact
the monitoring organization at the beginning of each quarter to determine if they still plan on
purchasing protocol gasses within that quarter and participating in the verification. If so, the
monitoring organization will be confirmed for verification and information in regards to the
actual verification schedule and when cylinders should be sent to the EPA Region will be
distributed to the monitoring organization participants.
Protocol Gas Shipments from Monitoring Organizations to Verification Laboratories
The EPA Protocol Gases, its associated certificates of analysis and the chain of custody will be
shipped directly from the monitoring organizations to the RAVL. Monitoring organizations are
responsible for the cost of shipping the gases to the laboratory. The monitoring organization will
notify the RAVL minimally one week ahead of the expected shipping day and the actual day of
shipment. Contact can be voice or email but must include the shipping tracking number in order
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for tracking by the RAVL. The gases must be delivered with the same internal pressure as
received from the producers and must have at least 6 months left in its certification periods. The
RAVL will inform the monitoring organization of receipt of cylinders/information the day the
cylinder arrives.
Chain of Custody and Tracking of Shipments
The monitoring organizations will initiate a chain of custody record (see Appendix B) for
cylinder shipments to the RAVL. This information will be used by the laboratory to ensure that
it receives and analyzes all the gases that are intended to be verified and will be used to develop
the AA-PGVP database.
4.3 Shipments of EPA Protocol Gases to Monitoring Organization
Upon completion of its analyses and the resolution of any verification-related issues, the RAVL
will ship the EPA Protocol Gases, final results and the completed chain of custody form back to
the monitoring organization. The RAVL is responsible for the cost of the return shipment. EPA
Regions will have the appropriate safety training for handling/shipping of hazardous materials as
required by 49 CFR Part 172.704.
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5.0 QUALITY SYSTEM DEVELOPMENT
This section addresses the quality assurance (QA) and quality control (QC) activities for the
processes and resulting products in the AA-PGVP. Because the purpose of the program is to
assess the accuracy of EPA Protocol Gases' certified concentrations, it is important to also
determine how well the program's QA and QC activities have been performed. These activities
are performed to assure stakeholders that the program's results can be trusted. They include the
activities as described below. They should be carried out according to each organization's
documented quality system.
5.1 The AA-PGVP Quality Assurance Project Plan and SOPs
The complete details of the AA-PGVP quality system will be detailed in the AA-PGVP Quality
Assurance Project Plan. Due to the importance of the data and its use, EPA identifies this as a
category 1 (most stringent) QAPP and as such, will address all QAPP elements that are relevant
to the AA-PGVP. This document will be reviewed by all stakeholders (EPA, monitoring
organizations, specialty gas producers) and approved prior to implementation of the formal
program.
The SOPs at a minimum will cover the requirements in procedure G-l andG-2 of the EPA
Protocol Gas Document1. In most cases procedure G-2 will be used. The RAVLs will follow
the G-l/G-2 requirement but be more specific in the SOPs as they relate to the labs particular
instrumentation.
5.2 Quality Control (QC) Activities
Three are basically three facets of the program that are important to control: cylinder integrity,
cylinder analysis and information collection/assessment/reporting. Each will briefly be
discussed below. Much more detail on quality assurance activities will be covered in the AA-
PGVP QAPP.
5.2.1 Cylinder Integrity
To ensure the validity of the verification, the gases must be delivered to the laboratory in the
same condition as when they were delivered to the monitoring organization. Any use of or
tampering with the gases prior to their measurement would render the verification results as
questionable. Cylinders must be handled in such a manner that there integrity is beyond question.
Handling includes maintenance from: shipping to the RAVL, laboratory storage, the verification
process, and shipping back to the monitoring organization. The QAPP will provide detailed
requirements for each phase. Maintaining and documenting the chain of custody for the EPA
Protocol Gases being verified is an important responsibility for the RAVL. The monitoring
organization will send the important cylinder information as described in Section 4.2 and
Appendix B to the RAVL. This information will be used by the laboratory to help to ensure that
it receives and analyzes all the gases that are intended to be verified and no others. The RAVL
1 EPA Traceability Protocol For Assay And Certification Of Gaseous Calibration Standards September 1997(EPA-
600/R-97/121
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will store cylinders in a secure laboratory location with limited access and by all EPA laboratory
safety standards. Upon completion of analysis it will complete appropriate section of the chain of
custody form which will accompany the cylinder and verification results that are sent back to the
monitoring organizations.
5.2.2 Cylinder Verification (Analysis)
The RAVL will be responsible for establishing and implementing internal QC procedures for the
measurement of the EPA Protocol Gases, along with associated documentation such as:
SOPs, laboratory notebooks and maintenance records
Analytical and support equipment selected to conduct the analyses
Calibration and configuration of analytical instruments
Documentation of the measurements including zeros, spans, linearity checks, time to
stable response, interferences, precision, accuracy, specificity
Written procedures for calculation of measured concentrations
Estimated total uncertainty of the measured concentrations
Table 5-1 provides some of the QC checks that will be included in the QAPP for this program.
Table 5-1 Example of some of the QC checks for the AA-PGVP
Requirement
Calibration
Zero and Span Check
Mass Flow Controller
Calibration
Mass Flow Meter
Regulator cleaning
Frequency
On day of cylinder verification
After each pollutant verification
Within 1 week of verification
I/year
I/year
Acceptance Criteria
+ 1% at each point
+ 1%
+ 1% at each point
+ 1%
Comments
Multi-point calibration
Drift accountability
5.2.3 Information Collection, Assessment and Management
The following information will be tracked by the RAVL:
EPA Protocol Gases received;
Original producer's certificate of analysis for each gas;
Chain of custody forms;
Description of the analytical methods;
Analytical reference standards used in the measurements;
Identification of the verified cylinders, their producers, and their certified concentrations;
Raw measurements and a summary of the measured concentrations for the gases; and
Comparison of the measured concentrations with the certified concentrations.
The raw data from the analyses of the cylinders and the reference standards will be presented in
sufficient detail to allow reconstruction of the calculations. The statistical analysis of the
verification results will follow the requirements in appendices A and C of the Protocol Gas
Document1. The report will also describe the mathematical and statistical procedures that were
used in the calculation of the measured concentrations and the estimated total uncertainties.
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5.3 Other QA Activities
There are a number of quality assurance activities that will be implemented to provide
confidence in the results of the AA-PGVP.
5.3.1 Verification Laboratory Personnel Certification:
The EPA OAQPS QA Officer will certify personnel who are capable of performing the AA-
PGVP cylinder verifications. Certification will be established through an audit of the laboratory
technician's implementation of the AA-PGVP standard operating procedures. The RAVLs will
maintain a listing of these personnel.
5.3.2 NIST Technical System Audits (TSA) and Proficiency Tests (PTs) of RAVL
NIST will be invited to review/comment on the AA-PGVP QAPP and SOPs. NIST will also be
invited to audit the verification activities and challenge the system with an independent set of
proficiency test standards. OAQPS will invite personnel from the Office of Research and
Development (ORD) to perform a TSA on the RAVLs every 3 years. All results of PTs and
TSAs will be posted on an EPA Website.
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6.0 INFORMATION MANAGEMENT/ REPORTING
This section will discuss the important AA-PGVP information that needs to be collected, stored
and reported. A database will be developed that will collect vital information from a number
reports that will be generated throughout the implementation phase of the AA-PGVP.
6.1 Information Needed for AA-PGVP
6.1.1 Identification of AA-PGVP Producers/Participants
The identity of those specialty gas producers who will participate in the AA-PGVP each year
will be based on the monitoring organizations use of those specific specialty gas producers
and/or specialty gas producers not currently being used by monitoring organizations that may
want to provide cylinders for verification. Each year NAACA, with the assistance of EPA, will
survey the monitoring organizations for the following information:
Annual AA-PGVP Pre-implementation Survey
Monitoring organization name
Monitoring Org Point of Contact (POC)
Names of specialty gas producers (SGP)
used
General cylinder concentrations
Primary Quality Assurance Organization
code
POC phone #
SGP address (city, state)
Anticipated purchase in 12 months
Reporting Organization Code
POC Email
SGP code**
Willingness to participate in AA-PGVP
verification
** if there is no code, EPA will establish a coding system for specialty gas producers.
EPA will use AQS to generate a list of all primary quality assurance organizations (PQAOs) that
will be used to ensure that all monitoring organizations are surveyed. NAACA and EPA Regions
will work together to ensure a representative from each PQAO completes the survey by Mid-
November of each year. Information from this survey will be the first level of information
reported to the AA-PGVP data base. Upon completion of this survey, EPA will report a
complete list of only the specialty gas producers that are currently being used by monitoring
organizations. This report will not include, at this time, how many monitoring organizations
or which monitoring organizations are using specific specialty gas producers. The list will
be useful for specialty gas producers to confirm they are being used by monitoring organizations
and if not, to contact EPA if they would like to participate during an agreed upon time period
where the specialty gas producers could ship protocol gas directly to the verification labs.
Specialty gas producers sending standards directly to EPA will be indentified as such in final
reports.
6.1.2 Selected Specialty Gas Producers/Monitoring Organizations
The Pre-implementation survey information will be used to select a representative number of gas
cylinders from every specialty gas producer being used for the year. The AA-PGVP data base
will identify the subset list of specific specialty gas producer/monitoring organizations that will
participate in the upcoming AA-PGVP implementation year. Additional data needed to be
collected other than data from the AA-PGVP Pre-implementation survey include:
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Anticipated date for cylinder shipment to verification laboratory
Anticipated concentration ranges of gases
6.1.3 Chain of Custody Information
Chain of custody is discussed in Section 4 and the chain of custody form can be found in
Appendix B. The AA-PGVP data base will capture all information on this form. Many of the
variables will be captured/transferred from the AA-PGVP pre-implementation survey
information.
6.1.4 Verification Data
The Regional verification laboratory will capture the following information:
Standard reference materials (SRM)
o Concentration results,
o certification date,
o cylinder ID number
QC Data (see Table 5-1)
Monitoring organization standard
o chain of custody information (Appendix B)
o Concentration results
6.2 Verification Reports
The information described in the above sections will allow for the generation of the following
reports:
6.2.1 Initial Draft Report
Within two to three weeks of completion of its analyses, the RAVL will report its draft
verification results in the form of a database to OAQPS and the appropriate monitoring
organization. At a minimum, the draft verification results shall include:
(a) a description of the gas metrological techniques, analytical method and analytical
instrumentation, and the statistical procedures that were used in the calculation of the
measured concentrations and their estimated total uncertainties;
(b) the analytical reference standards that were used with their compositions, certified
concentrations, stamped cylinder numbers and expiration dates;
(c) a description of the EPA Protocol Gases that were analyzed, including their compositions,
original certified concentrations and uncertainties, stamped cylinder numbers and expiration
dates;
(d) the raw measurement data, measured concentrations, and estimated total uncertainties;
(e) the percent difference between original certified concentrations and calculated measured
concentrations;
(f) a documentation checklist for each certificate of analysis with any non-conformances
identified;
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(g) documentation of whether appropriate chain-of-custody procedures were followed; and
(h) written documentation showing the calculations that the RAVL used to convert the raw
measurement data into the measured concentrations and their estimated total uncertainties.
The raw measurement data from the analyses of the EPA Protocol Gases and the analytical
reference standards will be presented in sufficient detail to allow reconstruction of the
calculations. The draft verification results may include a footnote indicating that EPA's
accuracy criteria of + 2.0 percent as required for EPA Protocol Gases that are used for
compliance with the Acid Rain Program's QA requirements in 40 CFR Part 75.
OAQPS is responsible for notifying each participating producer about whether the verification
results for a specific EPA Protocol Gas that the producer prepared and the producer's
corresponding certified concentrations differ by more than +/- 2.0 percent, but it will not indicate
the measured concentrations that the laboratory has determined. It will notify each producer
separately. The verification results for a specific producer will not be shared with anyone but
that producer.
Any disputes about the verification results will be resolved prior to their final dissemination. If a
producer has been informed by OAQPS that the measured concentrations for a specific EPA
Protocol Gas and the producer's corresponding certified concentrations differ by more than +/-
2.0 percent, then it may choose to have that gas reanalyzed by its manufacturing location or by
another laboratory at its own expense. The producer must report the results of the reanalysis to
the RAVL who will transmit them to OAQPS with the final verification results.
6.2.2 Final Verification Results
Upon receipt of the final verification results from the RAVL, OAQPS is responsible for
publishing and disseminating the final verification results (with appropriate caveats associated
with how they should be interpreted) and the certificate inspection results by posting them on an
EPA website that is accessible to the public. The AA-PGVP advisory group will develop
examples of this final report for review/comment by stakeholders.
The final verification results will include a list of the AA-PGVP participants for that year, the
number, composition, and certified concentrations of the EPA Protocol Gases that were verified,
summaries of the laboratory's measured concentrations, the estimated total uncertainties, and a
comparison of the measured concentrations with the participants' certified concentrations. The
reanalyzed concentrations will be posted by EPA in a separate column of the verification results
next to the original certified concentrations with a footnote indicating which manufacturing
location performed the analysis.
EPA may prepare papers concerning the final verification results for presentation at professional
meetings and for publication in the professional literature.
The EPA website will include results from the most recent verification as well as the verification
results from previous years.
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7.0 ANNUAL AA-PGVP TIMELINE
The purpose of this Section of the AA-PGVP Implementation Plan is to provide the necessary
time line sequence for a yearly cycle in the Protocol Gas Verification Program as shown in
Figure 7.1 2. Tasks 1-3 will be performed primarily in 2009 while the remaining tasks will be
performed each year.
ID Task Name 2Q09 2010 12011
Novi Dec Jan Fet Mar Apr Ma> Jun Jul Aucj Sep Oct Nov Dec Jan Fetj Mar Apr Ma^ Jun Jul Auc Sep Oct Nov Dec Jan Fetj Mas Af
IIZiEPA
2
J
4
__
__
1
8
___.
Develop/Approve QAPP/SC
j Develop PGVP Database
1 Soliciting Program Participa
[Selection producers/particip
Participation Finalized
IPGVP Implementation
Offical Data Posting
PGVP Conference Calls
"i
i i bHA
i IEPA
{'""""""""""""""""I-PGVP Advisory Group
.PGVP Advisory Group
|OEGVP Advisory Group
H
00000 i i
m EPA
Figure 7.1. Annual Time Line for Protocol Gas Verification Program
Task 1 - Complete Draft AA-PGVP Implementation Plan
Date: April 30, 2009
Party: EPA
Action: OAQPS and the RAVL will develop an Implementation Plan for stakeholder review.
Reviews will include NAACA, the monitoring organizations and the specialty gas producers.
Task 2 - AA-PGVP QA Project Plan and Standard Operating Procedures
Date: October 30, 2009
Party: EPA
Action: OAQPS and the RAVL will develop a QA Project Plan and Standard Operating
Procedures for stakeholder review. Reviews will include NAACA, the monitoring organizations
and the specialty gas producers. The QAPP will be co-signed for approval by OAQPS, and
Regions 2 and 7.
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Task 3 - Develop AA-PGVP Database
Date: November, 2009
Party: EPA
Action: It is proposed that an Access data base (or something similar) be developed to help
report and track the following types of data:
List containing monitoring organizations and who they use for specialty gas producers
List of specialty gas producers and monitoring organizations that will participate in the
current implementation year
Chain of custody form information
Verification Analysis Results
Summary results
Task 4 - Soliciting Participation
Date: Aug -November 1 each year
Party: AA-PGVP Advisory Group
Action: The AA-PGVP Advisory Group will post a survey as described in Appendix A .This
information will provide EPA with the information it needs to select a representative number of
cylinders from each producer within the constraint of a maximum of 80 cylinders/year.
NOTE: Some of this information will be restricted to the public until verification is
completed since gas producers could determine from the list what organizations
might be receiving gasses and potentially be used for verifications.
Task 5 - Selection of Producers/Participants.
Date: November 15 each year
Party: AA-PGVP Advisory Group
Action: The AA-PGVP Advisory Group will make selections of producers and participants.
From this information EPA will work with selected monitoring organizations to set up a
verification implementation schedule based on anticipated purchase dates of cylinders by the
selected monitoring organizations.
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Task 6 - Participation Finalized
Date: November 30 each year
Party: AA-PGVP Advisory Group
Action: EPA will complete discussions with monitoring organizations and publish a final list
that will remain internal to the AA-PGVP Advisory Group until completion of verification for
the calendar year. At a minimum, specialty gas vendors can be informed whether or not they will
have cylinders verified and if not they can determine whether they would like to send cylinders
to the verification labs within a window of opportunity offered them.
Task 7 - AA-PGVP Implementation
Date: Jan 1, -December 30, each year
Party: RAVL
Action: The RAVL will implement the routine verification activities and communicate results to
OAQPS and monitoring organizations within 5 days of valid analysis.
Task 8 - Official Posting of Results
Date: Jan 30, each year
Party: EPA
Action: Upon completion of verification and rectification of issues, final results will be posted
on AMTIC. Results will include complete lists of surveys and monitoring organization
participants. If cylinders are re-verified, these results will also be reported either as final results
(if re-verified before Jan. 30) or as an update to the report.
Task 9 - Quarterly AA-PGVP Advisory Group Conference Calls
Date: Quarterly- Starting June 2009
Party: AA-PGVP Advisory Group
Action: The AA-PGVP Advisory Group will meet quarterly to discuss program progress and
issues. As experience is gained in the program the AA-PGVP Advisory Group will determine if
changes in program documentation (Implementation Plan, QAPP, SOPs) needs modification.
These modifications will be made as soon as needed but documented, at a minimum, before the
start of the next calendar year.
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8.0 REFERENCES
Coppedge, E.A. et al., 1992. "Accuracy Assessment of EPA Protocol Gases Purchased in 1991,"
Journal of the Air and Waste Management Association.
Decker, C.E. et al., 1981. "Analysis of Commercial Cylinder Gases of Nitric Oxide, Sulfur
Dioxide, and Carbon Monoxide at Source Concentrations," Proceedings oftheAPCA Specialty
Conference on Continuous Emission Monitoring-Design, Operation, andExperience, APCA
Publication No. SP-43.
Hines, A.P., 1992. Analysis of Commercial Nitric Oxide Protocol Gases: A Quality Assurance
Audit, U.S. EPA Publication No. EPA-600/R-92/225.
Hines, A.R. et al., 1993. EPA's QA Program on the Suppliers of Protocol Gases, EPA
Publication No. EPA-600/A-93/110.
Scott Environmental Technology, 1977a. Protocol for Establishing Traceability of Calibration
Gases used with Continuous Source Emission Monitors, Publication SET 1500 05 0277.
Scott Environmental Technology, 1977b. Discussion of Comments Received on Draft Protocol
for Establishing Traceability of Calibration Gases used with Continuous Source Emission
Monitors, Publication SET 1500 05 0277.
Shores, R.C. et al., 1994. "Stability Evaluation of Multicomponent EPA Protocol Gases,"
Measurement of Toxic and Related Air Pollutants, Air and Waste Management Association
Publication No. VIP-39, U.S. EPA Publication No. EPA-600/R-94/136.
U.S. Environmental Protection Agency, 1978. "Traceability Protocol for Establishing True
Concentrations of Gases Used for Calibration and Audits of Continuous Source Emissions
Monitors (Protocol No. 1)," Quality Assurance Handbook for Air Pollution Measurement
Systems, Volume III, Stationary Source Specific Methods, Section 3.0.4, U.S. EPA Publication
No. EPA-600/4-77-027b.
U.S. Environmental Protection Agency, 1993. "Continuous Emission Monitoring," Code of
Federal Regulations, Title 40, Part 75.
U. S. Environmental Protection Agency, 1997. EPA Traceability Protocol for Assay and
Certification of Gaseous Calibration Standards, U.S. EPA Publication No. EPA-600/R-97/121.
U. S. Environmental Protection Agency, 2001. EPA Requirements for Quality Assurance Project
Plans. EPA QA/R-5, U.S. EPA Publication No. EPA/240/B-01/003.
Wright, R.S. et al., 1987. "Performance Audits of EPA Protocol Gases and Inspection and
Maintenance Calibration Gases," Journal of the Air Pollution Control Association.
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Wright, R.S. et al., 1989. "Accuracy Assessment of EPA Protocol Gases in 1988," Journal of the
Air and Waste Management Association.
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9.0
APPENDICIES
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Appendix A
AA-PGVP Monitoring Organization Survey
This Survey would be sent to all primary quality assurance organizations (PQAOs) currently
submitting SLAMS/SPM/PSD data to AQS. It will provide EPA with information on:
1. Specialty gas producers currently being used, and
2. Monitoring organizations willing to participate in the AA-PGVP
Monitoring organization willing to participate would be required to meet Implementation Plan
requirements which include covering the cost of shipping to the Regional Analytical Verification
Laboratory and allowing the laboratory to hold the cylinder for approximately 6 weeks.
For QA purposes EPA defines the primary quality assurance organization (PQAO) as a
monitoring organization or a coordinated aggregation of such organizations that is responsible
for a set of stations that monitors the same pollutant and for which data quality assessments can
logically be pooled. Each criteria pollutant sampler/monitor at a monitoring station in the
SLAMS network must be associated with one, and only one, primary quality assurance
organization. However, there are a number of local reporting organizations that have
consolidated to fewer PQAOs. These reporting organizations may use different gaseous
standards even though they are associated with the same PQAO. EPA will survey participation
in the AA-PGVP at the PQAO level. It will be the responsibility of the PQAO to survey the
reporting organizations within the PQAO.
The participation form will be provided in Word and as an Excel spreadsheet. It is expect that
each PQAO/Reporting Organization combination would provide a separate form.
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AA-PGVP Monitoring Organization Survey
PQAO Orqanization Name:
Reporting Orq. Name1:
Point Of Contact (PC
Specialty Gas Producers Us(
1) Primary:
2) Secondary:
3) Other:
)C):
;d Manufacturer Address
City: State:
PQAO Code:
Reporting Org.
Code:
POC Email
Address:
Gas Producer Code
(if available)
City: State:
City: State:
Do you plan on purchasing gasses from a producer fv/ivM Approximate date of
in the next 12 months? ' ' purchase
Month (numhfir)-
Pollutant Concentr
Pollutants you plan to purchase and their concentrations
ation Multi-Blend Pollutant
Y/N
Would you be willing to participate in the PGVP?
Is your Org. trained/ certified to ship gas cylinders2?
Concentration
(Y/N)
Multi-Blend
Y/N
-Due to consolidation of PQAOs there may be more than one reporting organization using the same PQAO. EPA is
requesting that the "Primary" PQAO provide information on all reporting organizations using the PQAO code.
Therefore, if a unique PQAO supports 3 reporting organizations, EPA would expect to receive three survey forms
2
- Per 49 CFR Part 172.704 Training for shipment of hazardous material
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Appendix B - Example AA-PGVP Chain-of-Custody Form
TO BE COMPLETED BY MONITORING ORGANIZATION
Cylinder Information
Monitoring Organization: Point of Contact:
Primary Quality Assurance Organization Code :
Producer Name: Producer Point of Contact:
Manufacturing Location Address:
Contact Phone Number: Contact E-Mail:
Specialty gas vendor has verified the standard by comparison to: SRM NTRM GMIS (circle one)
Stamped Cylinder #: Pressure psig Certification Expiration Date
Constituents SO2 (ppm) NO (ppm) CO2 (%) O2 (%) CO (ppm)
Certified Concentration
Analytical Uncertainty
Agent Receipt Date: Received By:
Date Shipped to Laboratory: Shipping Mode & Carrier:
Shipping Tracking #:
Send this COC form with cylinder, and email form to the laboratory.
TO BE COMPLETED BY RAVL
Upon Receipt:
Laboratory Receipt Date: Received by:
Integrity Acceptable: Yes No Contents Information Correct: Yes No_
Cylinder valve shrink wrapped: Yes No CGA shrink wrap is intact: Yes No_
Certification Expiration Date: Confirm cylinder pressure: psig
Shipping to Monitoring Organization:
Confirm cylinder pressure: psig (post verification)
Date Shipped to Monitoring Org: Shipping Mode & Carrier:
Shipping Tracking #:
Send this COC form to EPA upon completion of the measurements and resolution of all verification-related issues
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Appendix C
Protocol Gas Verification Cylinder Tracking Form
The following information will be automatically assembled from the AA-PGVP Data Base as
data is entered from the chain of custody forms and undergoes verification. It will then be posted
in a manner (AMTIC) that will be available to the monitoring organizations.
PQAO
Cylinder ID
Date Shipped
From MO
Date Received
By Lab
Date Verified
Date Shipped
back to MO
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