CASTNET Plan for Part 58 Compliance Version 1.013 1. Overview CASTNET is coordinated by two federal agencies, the Environmental Protection Agency (EPA) and the National Park Service (NPS); additionally there are numerous other participants including the Cherokee Nation, the Bureau of Land Management, and others. Both EPA and NPS each have their own contractor; EPA's contractor is AMEC, Inc. and the NPS' contractor is ARS, Inc. The EPA manages 58 sites and NPS manages 25 sites for a total of 83 CASTNET sites. Environmental, Engineering & Measurement Services, Inc (EEMS) performs independent audits at every CASTNET site. RTI International performs technical system audits (TSAs) at both the EPA contractor's and NPS contractor's facilities. For the remainder of this document contracted groups will be referred to in the following manner: AMEC as EPA contractor, ARS as NPS contractor, EEMS as independent auditor, and RTI International as 3rd party auditor. CASTNET completed upgrading and updating ozone monitoring equipment at all EPA sites to comply with the requirements in 40 CFR Part 58 in FY 2011. This document summarizes the site and equipment audit schedules and quality assurance methods that the CASTNET program will follow to meet the regulatory requirements. The procedures laid out in this document were adapted from the requirements placed on the States to meet the needs of an EPA national monitoring network. This document is a detailed interpretation of information as described in the CASTNET QAPP Version 8.0 Appendix 1 Field SOP Section 3.3; there currently is no mention of this document within the CASTNET QAPP Version 8.0 Appendix 8 Quality Management Plan. Both the EPA and NPS contractor submit hourly ozone data to AQS on a monthly basis. Annual data certification will be completed by the CAMD QA officer (currently Larry Kertcher of CAMD) by May 1st of each year for all of the CASTNET sites provided that all data certification information from the EPA and NPS contractors are supplied on time; otherwise NPS sites will be responsible for this data certification at the NPS CASTNET sites. States will work with regional EPA offices on assigning exceptional event informational qualifier codes to CASTNET ozone data housed within AQS. State agencies have the responsibility, according to the Exceptional Events Rule, to demonstrate to their EPA region that an exceptional event occurred and should be flagged. CASTNET will work with the states to provide supporting information. CASTNET will use the monitoring quality objectives shown in Table 1 to ensure that the highest quality data are being submitted to AQS. This table has been reviewed by OAQPS, NPS, CAMD, the EPA contractor, and the NPS contractor. The AQS QA qualifier table which includes qualifier codes, descriptions, and valid/invalid status codes is available in Appendix C. 1 ------- Table 1 originated from the Quality Assurance Handbook for Air Pollution Measurement Systems QA Handbook Volume II, Appendix D Revision 1, December 2008. EPA, NPS, the EPA contractor, and the NPS contractor added comments to this table to further explain actions to be taken regarding data validation. Table 1 Monitoring Quality Objectives Ozone Validation Template - CASTNET Requirement Minimum Frequency Acceptance Criteria Information/Action Comments CRITICAL CRITERIA One Point QC Check Single analyzer 1/ 2 weeks < ±7% (percent difference) 0.01 - 0.10 ppm Relative to routine concentrations 40 CFR Part 58 App A Sec 3.2 (10-100ppb) Relative to routine concentrations This problem doesn't say the 03 analyzer data is bad, just that the transfer standard has a problem. Zero/span check 1/2 weeks Zero drift < ± 2% of full scale Span drift < ± 7 % CASTNET protocol requires daily checks. Invalidate all data associated with a failure - from the last check that met the criterion to the next meeting the criterion. If the problem can be verifiably traced to a system or subsystem that does not affect reported data, the associated data may be treated as valid. Missing checks will not automatically require invalidation until they drop below the minimum EPA-required frequency of once every 2 weeks. Drift in ozonator concentrations should be treated as an operational criterion. If reference concentrations (those generated by the transfer standard) are not within 2% of full scale, investigate the problem. When evaluating zero drift, apply the criterion to direct readings and to comparisons with the onsite transfer standard. Take action if either fails to meet the criterion. OPERATIONAL CRITERIA Shelter Temperature 2 ------- Ozone Validation Template - CASTNET Requirement Minimum Frequency Acceptance Criteria Information/Action Comments Temperature Range Daily (hourly values) 20 to 30° C. (Hourly average) or per manufacturer's specifications if designated to a wider temperature range Generally the 20-30° C range will apply, but the most restrictive operable range of the instruments in the shelter may also be used as guidance. Investigate data associated with temperatures outside of 18 to 32° C window: Review data for reasonableness+. If temperature is outside of this window for 3 or more consecutive hours or outside of a 15 to 35° C window for any recorded hour, verify that the analyzer internal temperature is between 25 and 40° C during the excursion. Invalidate data deemed unreasonable+ for ambient conditions or per site history and any data collected while analyzer internal temperatures were not between 25 and 40° C. This is an example of the AMEC specifics in the table that might cause confusion. This is the advisory range from Thermo. Any of these ranges could change with use a different equivalent method. Temperature Control Daily (hourly values) < ± 2° C SD over 24 hours If a 24 hr period is outside of the criterion, review associated data for reasonableness'. Treat hourly temperature readings that are out of range as described above. Temperature Device Check 2/year ± 2° C of standard CASTNET requirement for device field calibration is ± 0.5° C of standard. Data associated with a failure of ± 2° C or greater must be reviewed as described above. If the failure is linear 2° C may be added or subtracted as appropriate to determine which periods require further investigation. If the failure is non-linear orthe temperature device is otherwise non-functional, the temperature probe is replaced and the entire period must be reviewed for reasonableness+ and to verify internal analyzertemperatures. [Applies to routine calibration visits] Precision (using 1-point QC checks) Calculated annually and as appropriate for design value estimates 90% CL CV < 7% (monitor level) 90% of Confidence Limit of coefficient of variation. 40 CFR Part 58 App A sec 4.1.2 This metric is reviewed as part of the annual review screening procedure. Exceeding the criterion will trigger additional review including data from nearby sites (including SLAMS), site narrative logs, and the analyzer's internal systems monitoring (a.k.a "housekeeping") data. [Calculation performed by Data Manager and results reviewed by Data and OA Managers] 3 ------- Ozone Validation Template - CASTNET Requirement Minimum Frequency Acceptance Criteria Information/Action Comments Bias (using 1-point QC checks) Calculated annually and as appropriate for design value estimates 95% CL CV < ± 7% (monitor level) 95% of Confidence Limit of coefficient of variation. 40 CFR Part 58 App A sec 4.1.3 [Calculation performed by Data Manager and results reviewed by Data and QA Managers] Annual Performance Evaluation Single Analyzer Every site 1/year or 25 % of sites quarterly Percent difference of audit levels 3- 10 <_+15% [Audit levels 1&2 + 1.5 ppb difference or +15%] 3 consecutive audit concentration not including zero. 40 CFR Part 58 App A sec 3.2.2 Reviewed as part of the annual review screening procedure. Exceeding the criterion will trigger additional review as noted above. [EPA Responsibility] Primary QA Organization (PQAO) Annually 95% of audit percent differences fall within the one point QC check 95% probability intervals at PQAO level of aggregation Same as above. 40 CFR Part 58 App A sec 4.1.4 Federal Audits (NPAP) 1/year at selected sites 20% of sites audited Mean absolute difference < 10% 40 CFR Part 58 App A sec 2.4 State audits 1/year State requirements Verification/Calibration Upon receipt/adjustment/repa ir/ installation/moving -1/6 months if manual zero/span performed biweekly -1/year if continuous zero/span performed daily All points within ± 2% of full scale of best fit straight line Linearity error < 5% Multi-point calibration (0- 4 upscale points) 40 CFR Part 58 App D sec 5.2.3 If verification results are outside of the listed criteria, review the calibration forms, problem tickets and repair logs to confirm proper operation of the analyzer and onsite transfer standard. If a starting point for the problem can be determined and documented, use this period as that to be invalidated. If the problem can be verifiably traced to a system or subsystem that does not affect reported data, the associated data may be treated as valid. Otherwise, invalidate all associated data. Ensure confirmation of the onsite transfer standard and the "calibration standard." [Applies to routine calibration visits] Zero Air Concentration below LDL If the criterion is exceeded (± 0.003 ppm), correlate with any zero/span results that exceed critical criteria. If the zero air system is implicated, report this finding immediately to the project manager, field operations manager, and QA manager. [Applies to routine calibration visits] Replacing traps would seem to make for sense than reporting it to somebody far far away. Applies to 6-month duration; 6- month calibration will not invalidate all 6-months of data. Action item: review calibration results. 4 ------- Ozone Validation Template - CASTNET Requirement Minimum Frequency Acceptance Criteria Information/Action Comments Gaseous Standards NISTTraceable (e.g., EPA Protocol Gas) 40 CFR Part 58 App A sec 2.6.1 Zero Air Check l/year Concentrations below LDL Ozone Level 2 Standard Cert ification/recertifi cation 1/year single point Primary Standards usually If the standard exceeds the to Standard Reference difference < ± 3% transported to EPA criterion and its authority has been Photometer Regions SRP for comparison used at any sites for re-verification or calibration the associated site analyzers must be re-verified with a properly certified standard. (if recertified via a transfer l/year Regression slopes = See above. Additionally, the standard) 1.00 ± 0.03 and two intercepts are 0 and ± 3 ppb travelling transfers are audited with a stationary standard 2x/calendar quarter to verify proper calibration w/o applying the certification calculation. The audit results must meet the criteria listed below: • New slope=± 0.05 of previous and RSD of six slopes < 3.7% • Std. Dev. of 6 intercepts < 1.5 Failure to meet these criteria will require servicing and/or recertification as appropriate. Ozone Transfer Standard Qualification Upon receipt of transfer ±4% or ±4 ppb Transfer Standard Doc EPA All analyzers are on the list of standard (whichever greater) 600/4-79-056 Section 6.4 USEPA Designated Equivalent Methods and are therefore qualified by their manufacturer. To maintain designation, they must not be modified or operated contrary to manufacturer's instructions or QA requirements. Certification After qualification and RSD of six slopes < Transfer Standard Doc EPA If the analyzer has been used at upon 3.7% 600/4-79-056 Section 6.6 any sites for re-verification or receipt/adjustment/repair Std. Dev. Of 6 intercepts < 1.5 calibration, the associated site analyzers must be re-verified with a properly certified analyzer. Recertification to local Beginning and end of 03 New slope = ± 0.05 1 recertification test that Recertification to Level 2 standard. primary standard season or 1/6 months of previous and RSD then gets added to most See above. This applies to onsite whichever less of six slopes < 3.7% recent 5 tests. If this does stationary Level 3 transfer Std. Dev. Of 6 not meet acceptability standards. intercepts < 1.5 certification fails Lower Detectable Level l/year 0.003 ppm If the standard exceeds (3 ppb) (LDL) the criterion and its authority has been used at any sites for re-verification or calibration the associated site analyzers must be re-verified with a properly certified standard. Ref. 40 CFR Part 136 App B. If the standard exceeds the criterion and its authority has been used at any sites for re-verification or calibration, the associated site analyzers must be re-verified with a properly certified standard. SYSTEMATIC CRITERIA Standard Reporting Units All data ppm (final units in AQS) Data must be converted to correct units. Completeness (seasonal) Daily 75% of hourly averages for the 8- hour period 8-hour average If the criterion is exceeded, data may not be used for reporting 8- hour averages. 5 ------- Ozone Validation Template - CASTNET Requirement Minimum Frequency Acceptance Criteria Information/Action Comments Sample Residence Times < 20 seconds Report any sites found to exceed this criterion to the project manager, field operations manager, and OA manager. Indicates a problem that should be checked at site. Tubing? Pump? Leaks? Sample Probe, Inlet, Borosilicate glass 40 CFR Part 58 App E See above. Sampling train (e.g., Pyrex ) or Teflon Siting Un-obstructed probe inlet 40 CFR Part 58 App E See above. EPA Standard Ozone l/year Regression slope = This is usually at an EPA Standard Reference Level 2. There 1.00 ±0.01 Regional Office and is is a traveling standard (Level 2) Reference Photometer and intercept < 3 compared against the which is deployed to the field and 2 (SRP) Recertification ppb traveling SRP standard reference level 2 devices that stay in the lab to verify the traveling standards to eliminate the need for sending traveling standards back to NIST after field deployment. Both lab and field SRPs are level 2. If the standard exceeds the criterion and its authority has been used at any sites for re-verification or calibration the associated site analyzers must be re-verified with a properly certified standard. tReview for reasonableness may include: CL = Confidence RSD = Relative • Synoptic meteorological conditions (where available) Limit Standard • Calibration schedule Deviation • Site Visit Log CV = Coefficient SD = Standard • Data from nearby sites (including SLAMS sites, where of Variation Deviation applicable) LDL = Lower Detectable Level All transfer standards at the EPA-sponsored CASTNET sites are NIST traceable at Level 3. The EPA contractor performs routine calibrations at each CASTNET site twice a year. During the calibration, ozone equipment is audited with a traveling transfer standard (Level 2), the data logger is tested and the shelter temperature device is placed in a temperature bath for accuracy. Calibration results are submitted monthly to and stored within an Oracle database of their respective federal agency. The transfer standards at NPS-sponsored CASTNET sites are NIST traceable at Level 4. NPS will update their calibration method to ensure all NPS-sponsored CASTNET sites have Level 3 transfer standards by January 1, 2013. Calibration results from NPS-sponsored sites are submitted monthly by ARS to NPS. The network audit requirements for 40 CFR Part 58 compliance are summarized in Table 2. CAMD intends to reach out to States and Regions prior to the Technical Systems Audits (TSA) and provide the schedules at least 6 months in advance to ensure they have enough time to arrange for travel if they chose to participate in the audits. 6 ------- Table 2 Summary c dit requirements. Calibration information is not included in this table Required Audits Performed Site Audit Audit Results Funding Audits By Selection Frequency Submitted Organization Independent Independent auditor CAMD/NPS Every other Submitted to CAMD CAMD Audit year (all /NPS independent (includes PE CASTNET sites) (a) spot report auditor audit, (monthly) metrological (b)database sensors and (quarterly) flow for filter pack) Performance Independent auditor CAMD/NPS Annually (All AQS CAMD/NPS Audit (PE) CASTNET sites) CAMD/NPS independent auditor National OAQPS (Mark OAQPS 20% of the AQS CAMD/NPS Performance Shanis) will sites (both EPA OAQPS Audit coordinate with the and NPS Regional Office Program regional offices sponsored ESAT (NPAP) CASTNET sites) each year Technical Independent auditor CAMD/NPS 10% of the CAMD/NPS CAMD/NPS System + CAMD/NPS + network each OAQPS independent Audits (TSA) Regions/States year auditor Field Audit Regions may visit site along with auditor Technical 3rd party CAMD/NPS Every 3 years EPA contractor/NPS CAMD (Base System auditor/CAMD/ contractor Funding) Audits (TSA) Independent AQS NPS Facilities Auditor/NPS Audit 2. Daily Quality Assurance Checks Each CASTNET ozone analyzer is connected to a data logger which records daily zero/span/precision (z/s/p) checks. The z/s/p scans are performed nightly, but can also be run manually if needed. A summary of the daily verifications calibrations is included in Table 1. If the automated span and precision differ by more than 7 % of the target value it is considered a failure. If the zero reading is outside of ±10 ppb, this is considered a failure. The site operator is instructed to call the Field Operations Manager to troubleshoot the problem if a failure occurs, although federal contractors generally know about failures first. 7 ------- 3. Independent Audits (at sites) Independent audits are performed every other year by a contractor (currently EEMS). The purpose of the audits is to provide an independent assessment of the site, the equipment performance, and the proficiency of the site operator. The auditor will test flow, ozone, and meteorological equipment at the site for any errors in precision or accuracy. The auditor will also complete a performance evaluation (PE) for ozone (see below). In addition the auditor will acknowledge if the CASTNET siting criteria is being violated. During the independent audit, EEMS will discuss any issues related to equipment, siting criteria, or operator handling with the operator and/or site supervisor. 4. Performance Evaluations (PE) (at contractor's facility) Annual ozone PE will be conducted in accordance with EPA's Quality Assurance Handbook for Air Pollution Measurement Systems: Volume II - Ambient Air Specific Methods, 40 CFR Parts 53 and Parts 58 Revisions to Ambient Air Monitoring Regulations: Final Rule. Results of the ozone PE will be submitted to AQS quarterly by EEMS. The proposed PE audit schedule is shown in Table 3 below. Site IDs in blue are NPS-sponsored CASTNET sites. Auditing equipment will be NIST certified twice a year, or more often if necessary. Table 3 Field Site Audit and Ozone PE Schedule PE and TSA visits are not differentiated within this table. One independent audit performed at each site annually. States may perform site audits when possible as coordinated with the independent auditor. Odd years: 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec ALC188 CDZ171 CKT136 CAN407 CNT169 DEN417 ALH157 ABT147 ARE128 CDR119 BBE401 COW137 DCP114 CHA467 GRB411 GLR468 ANA115 ACA416 BEL116 CTH110 CAD 150 CVL151 OXF122 GRC474 GTH161 KNZ184 BVL130 ASH 135 BFT142 KEF112 CHE18B ESP127 QAK172 JOT403 LAV410 PET427 PIN414 SEK430 YOS404 PND165 MOR409 HOX148 GRS420 BWR139 LRL117 GAS 153 MAC426 ROM406 SAN 189 PRK134 HOW132 CND125 MKG113 IRL141 MCK131 YEL408 THR422 SAL133 HWF187 PSU106 PAR107 PAL190 MCK231 WNC429 STK138 PED108 WSP144 SHN418 SND152 PNF126 UVL124 VPI120 SUM156 SPD111 VIN140 VOY413 WST109 Even years: 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec 8 ------- CAD 150 ALC188 CAN407 GRB411 CNT169 ALH157 ABT147 CAT175 CDR119 ARE128 CHE18B BBE401 CHA467 JOT403 CTH161 ANA115 ACA416 HWF187 CTH110 BEL116 EVE419 CDZ171 CKT136 LAV410 DEN417 BVL130 ASH 135 THR422 EGB181 BFT142 GAS 153 COW137 DCP114 PIN414 GLR468 HOX148 HOW132 VOY413 GRS420 BWR139 IRL141 ESP127 GRC474 SEK430 KNZ184 PRK134 PED108 WNC429 KEF112 CND125 PAL190 MAC426 MEV405 OXF122 PET427 YOS404 MOR409 SAL133 VPI120 WST109 LRL117 PS U106 SND152 MCK131 PND165 STK138 MKG113 WSP144 SUM156 MCK231 ROM406 UVL124 PAR107 PAL190 SAN 189 VIN140 SHN418 PNF126 QAK172 YEL408 SPD111 Color scheme: blue font = NPS sites operated by IMPS, red font = NPS sites operated by states, underlined font = sites where PE audits have been performed by States in the past and may do so again in the future. The verification of the ozone analyzer during the PE audit requires that the zero/span be within 2% of the full scale of the best fit linear line. Per the memorandum from OAQPS in February 2011, ten audit levels are included, but a minimum of three audit levels are necessary for CASTNET compliance to represent the routine concentration of the site. See Table 4 for acceptable audit ranges. The lowest two audit levels must be within ±1.5 ppb or a 15% difference, whichever is greater to meet the acceptance criteria. Levels 3-10 levels must be within 15% to meet the acceptance criteria. The audit levels must bracket 85% of a site's data. Table 4 Audit Levels for Independent, Annual Audit Audit Level Concentration Range, ppm Acceptance Criteria 1 0.004-0.0059 ±1.5 ppb or ±15%, whichever is greater 2 0.006-0.019 ±1.5 ppb or ±15%, whichever is greater 3 0.020-0.039 ±15% 4 0.040-0.069 ±15% 5 0.070-0.089 ±15% 6 0.090-0.119 ±15% 7 0.120-0.139 ±15% 8 0.140-0.169 ±15% 9 0.170-0.189 ±15% 10 0.190-0.259 ±15% Table from US EPA OAQPS dated Feb 17, 2011; "Guidance on Statistics for Use at Audit Levels 1 and 2 of the Expanded List of Audit Levels for Annual Performance Evaluation for S02, N02, 03, and CO as Described in 40 CFR Part 58 Appendix A Section 3.2.2" 5. National Performance Audit Program The CASTNET Team will work with Mark Shanis, in OAQPS, to coordinate with regional offices and the Environmental Services Assistance Team (ESAT) to fulfill the requirements under the National Performance Audit Program (NPAP). The goal for the CASTNET program is to complete NPAP audits at 20% of the sites each year. OAQPS will be responsible for selecting the sites that will be audited. Special priority will be given to those sites documented or expected to have concentrations near 0.075 9 ------- ppm. The audit results will be submitted to AQS by the NPAP auditor. CAMD and NPS will incur all costs/fees associated with the audits. The purpose of the NPAP is to assess the proficiency of the monitoring organization. The ozone audits will be performed through the probe using a NIST certified gas, which has been validated at least quarterly. The on-site analyzer will be tested at 3-4 known concentrations for accuracy by the auditor. The acceptable ranges can be found in 40 CFR Part 58, Appendix A, Section 3.2.2.1. 6. Technical Systems Audit (TSA) a. Facilities rd CAMD will use a 3 party auditor to conduct the facilities portion of the TSA at EPA contractor's facility and at the NPS contractor's facility. Provided travel funds are available, CAMD staff will be present at the facility audit. EPA will also provide the date of the scheduled audit to the States, Regions at least 6 months prior to the visit. This audit will be performed once every three years. A site systems audit will be conducted at the EPA contractor's and NPS contractor's facility to provide a qualitative appraisal of the total measurement system. Site planning, organization, and operation will be evaluated to ensure that good Quality Assurance/Quality Control (QA/QC) practices are being applied. The audit will consist of an assessment of the staff, facilities, data and document control, and the quality control programs. The CASTNET contractor's project manager, database manager, laboratory manager, and QA manager will be present during the audit. CAMD or the independent auditor will officially accept and summarize the findings and present them to the facility management. A report of the network TSA results will be prepared for each the facilities and submitted to OAQPS with copies to the Regions. Results from the facility TSA may be shared with the states through a NACAA call or email. b. Field For the TSA field audit, CAMD and NPS will use their independent auditor to conduct the field TSAs. The contractor, EEMS, also performs the independent field audits and performance evaluations for ozone at all CASTNET sites. Prior to field TSAs, announcement letters to site operators and parks, list of visitors, and purpose of visit should be sent 2-4 weeks prior to ensure all parties involved are prepared and eliminate park entrance fees when possible. If and when travel funds permit, a CAMD or National Park Service (NPS) representative will be present at the field TSA. States and Regions will have 6 months notice prior to the field TSA and their participation in the field TSA's will be encouraged. Ten percent of all CASTNET sites will have a field TSA completed each year. A sample schedule is shown in Table 5. Results from the field TSA's will be written up with the facilities TSA results by CAMD or NPS staff. An outline of the TSA report layout is shown in Appendix A. 10 ------- Table 5 Proposed TSA schedule for 2012 TSA audit schedule 2012 S ponsoring Agency Site ID Site Name State Region Audit Month EPA NPS Sponsor attending? Region Contact State Contact BEL116 Beltsville MD 3 Nov X y BWR139 Blackwater NWR MD 3 Oct X GRS420 Great Smokey Mtns NP TN 4 Sept X JOT403 Joshua Tree CA 9 May X PIN414 Pinnacles NM CA 9 May X ROM406 Rocky Mtn NP CO 8 Jun X SEK430 Sequoia NP - Ash Mountain CA 9 May X WSP144 Washington Crossing NJ 2 Oct X YOS404 Yosemite NP - Turtleback Dome CA 9 May X 7. Annual Monitoring Network Plans and Network Assessment CAMD will prepare an annual CASTNET (EPA and NPS-sponsored sites) monitoring network plan for public review. The network plan will focus on the ozone component of CASTNET and will address the ozone monitoring requirements of 40 CFR 58.10(b), including any anticipated new CASTNET ozone sites or ozone sites that are in jeopardy of being shut down. The NPS will need to have final say whether ozone monitoring at an NPS site is discontinued. A given NPS site may no longer meet the needs of CASTNET, but still be considered of value to NPS. The annual monitoring network plan will be posted for 30 days of public inspection on approximately May 15. The plan and response to any comments received during the inspection period will be distributed to OAQPS and all EPA Regional Office contacts, and submitted to the CAMD Division Director for approval no later than July 1. The schedule for these activities is outlined in Table 6. OAQPS will provide comments within 120 days on any plans proposing changes to the ozone network, and the final plan will be posted on the CAMD and TTNS web sites. Table 6 Network Plan Schedule Date Network Plan Steps March 30th Final data submitted to AQS April 30th Submit network plan to NPS for review May 15st Posted for public review - TTNS site, CASTNET site June 15st CAMD begins response to public comments July 1st Submitted to EPA/CAMD division director for 11 ------- approval CAMD will complete a network assessment every 5 years in accordance with 40 CFR 58.10(d) and send to NPS for review/coordination prior to submittal. The network assessment shall be submitted to the CAMD Division Director, OAQPS, and all EPA Regional Office contacts. The next assessment is due July 1, 2015, and every 5 years thereafter. 8. Ozone Network Modification CAMD and NPS will consult with OAQPS and applicable EPA Regional Offices before discontinuing any ozone monitor in accordance with the requirements of 40 CFR 58.14. The implications arising from a monitor discontinuation will be reviewed, involving affected state monitoring agencies if appropriate. Although no formal approval will be required, CAMD and NPS will consider pertinent comments on the network modification before making the change. It is preferable that such network modifications be documented in the annual monitoring network plan process described above. If resource constraints dictate that an ozone-monitoring CASTNET site should be removed from the network; then this site may not be removed as network modifications are not allowed without OAQPS approval. 9. Data Reporting and Certification CAMD and NPS will comply with the annual air monitoring certification requirements in accordance with 40 CFR 58.15. The certification process will be completed by May 1 of each year for the prior calendar year's ambient and quality assurance data. The certification materials will be signed by designated senior managers in CAMD and NPS for their respective CASTNET sites and submitted to OAQPS for review. CAMD can certify for all CASTNET sites provided that NPS submits pertinent information in a timely manner. CAMD's Division Director will approve with input from States and Regions. After certification, this information will be public for 30 days. CAMD and NPS will comply with the data submittal requirements in accordance with 40 CFR 58.16. Applicable ambient and quality assurance data will be submitted to AQS within 90 days after the end of each quarterly reporting period. 12 ------- Appendix A Outline for TSA Report 1. Executive Summary 2. Introduction 3. General Program and Quality Management (Audit of EPA contractor's office and NPS contractor's office) a. Complete General/Quality Management Forms b. Findings, Discussions, Recommendations 4. Network Management a. Complete Network Management, Field Support, Instrument Certification/Testing, Standards and Calibrations, and Instrument Repair Forms b. Table listing the site locations, number of monitors at each location, type of monitor (SLAMS, SPM, etc...), what is measured c. Findings, Discussions, Recommendations 5. Field Operations a. Complete Field Overview Forms b. Table that list site name, AQS ID, and pollutants monitored c. Findings, Discussions, Recommendations 6. Laboratory Operations a. Complete Laboratory Operations Forms b. Findings, Discussions, Recommendations 7. Data and Data Management a. Complete Data and Data Management Forms b. Findings, Discussions, Recommendations 8. Quality Control and Quality Assurance ------- Appendix B Regional Contacts Information for TSA Report Region Name Position Phone Email Region 1 Judge, Bob 617-918-8387 judge.robert@epa.gov Region 2 Ruvo, Richard A. Mgr 212-637-4014 ruvo.richard@epa.gov Region 3 Hass, Drew 215-814-2049 hass.andrew@epa.gov Region 4 Rinck, Todd Mgr 404-562-9062 rinck.todd@epa.gov Region 5 McGrath, Jesse 312-886-1532 mcgrath.jesse@epa.gov Region 6 Sather, Mark 214-665-8353 sather.mark@epa.gov Region 7 Nichols, Robert Mgr 913-551-5266 nichols.robert@epa.gov Region 8 Payton, Richard 303-312-6439 payton.richard@epa.gov Region 9 Clover, Fletcher 415-972-3991 clover.fletcher@epa.gov Region 10 Hall, Christopher 206-553-0521 hall.christopher@epa.gov ------- Appendix C AQS Qualifier Codes and Descriptions Codes with Status = I are not valid for reporting new data 18-AUG-10 Qt Qualifier Type Qualifier Type Desc Qualifier Code Qualifier Desc INFORM Informational Only A High Winds Informational Only B Stratospheric Ozone Intrusion Informational Only C Volcanic Eruption Informational Only D Sandblasting Informational Only F Structural Fire Informational Only G High Pollen Count Informational Only H Chem. Spills & Indust. Accidents Informational Only 1 Unusual Traffic Congestion Informational Only IA African Dust Informational Only IB Asian Dust Informational Only IC Chem. Spills & Indust Accidents Informational Only ID Cleanup After a Major Disaster Informational Only IE Demolition Informational Only IF Fire - Canadian Informational Only IG Fire - Mexico/Central America Informational Only IH Fireworks Informational Only II High Pollen Count Informational Only IJ High Winds Informational Only IK Infrequent Large Gatherings Informational Only IL Other Informational Only IM Prescribed Fire Informational Only IN Seismic Activity Informational Only 10 Stratospheric Ozone Intrusion Informational Only IP Structural Fire Informational Only IQ Terrorist Act Informational Only IR UniqueTraffic Disruption Informational Only IS Volcanic Eruptions Informational Only IT Wildfire-U. S. Informational Only IU Wildland Fire Use Fire-U. S. Informational Only J Construction/Demolition Informational Only K Agricultural Tilling Informational Only L Highway Construction Informational Only M Rerouting of Traffic Informational Only N Sanding/Salting of Streets Informational Only 0 Infrequent Large Gatherings Informational Only P Roofing Operations Informational Only Q Prescribed Burning 15 ------- Informational Only R Cleanup After a Major Disaster Informational Only S Seismic Activity Informational Only U Sahara Dust Informational Only Z Other event QA Quality Assurance Qualifier 1 Deviation from a CFR/Critical Criteria Requirement Quality Assurance Qualifier 2 Operational Deviation Quality Assurance Qualifier 3 Field Issue Quality Assurance Qualifier 4 Lab Issue Quality Assurance Qualifier 5 Outlier Quality Assurance Qualifier 6 QAPP Issue Quality Assurance Qualifier 7 Below Lowest Calibration Level Quality Assurance Qualifier 8 QA/QC Unknown Quality Assurance Qualifier 9 Negative value detected - zero reported Quality Assurance Qualifier CB Values have been Blank Corrected Quality Assurance Qualifier CC Clean Canister Residue Quality Assurance Qualifier CL Surrogate Recoveries Outside Control Limits due to analytical interferences Quality Assurance Qualifier EH Estimated; Exceeds Upper Range Quality Assurance Qualifier FB Field Blank Value Above Acceptable Limit Quality Assurance Qualifier HT Sample pick-up hold time exceeded; data questionable Quality Assurance Qualifier LB Lab blank value above acceptable limit Quality Assurance Qualifier U Identification Of Analyte Is Acceptable; Reported Value Is An Estimate Quality Assurance Qualifier LK Analyte Identified; Reported Value May Be Biased High Quality Assurance Qualifier LL Analyte Identified; Reported Value May Be Biased Low Quality Assurance Qualifier MD Value less than MDL Quality Assurance Qualifier MX Matrix Effect Quality Assurance Qualifier ND No Value Detected Quality Assurance Qualifier NS Influenced by nearby source Quality Assurance Qualifier PQ Values Between PQL And MDL Quality Assurance Qualifier SQ Values Between SQL and MDL Quality Assurance Qualifier SS Value substituted from secondary monitor Quality Assurance Qualifier SX Does Not Meet Siting Criteria Quality Assurance Qualifier T Multiple PM2.5 Validity Flags Quality Assurance Qualifier TB Trip Blank Value Above Acceptable Limit Quality Assurance Qualifier V Validated Value Quality Assurance Qualifier VB Value below normal; no reason to invalidate Quality Assurance Qualifier W Flow Rate Average out of Spec. Quality Assurance Qualifier X FilterTemperature Difference out of Spec. Quality Assurance Qualifier Y Elapsed Sample Time out of Spec. REQEXC Request Exclusion E Forest Fire Request Exclusion RA African Dust Request Exclusion RB Asian Dust 16 ------- Request Exclusion RC Chem. Spills & Indust. Accidents Request Exclusion RD Cleanup After a Major Disaster Request Exclusion RE Demolition Request Exclusion RF Fire - Canadian Request Exclusion RG Fire - Mexico/Central America Request Exclusion RH Fireworks Request Exclusion Rl High Pollen Count Request Exclusion RJ High Winds Request Exclusion RK Infrequent Large Gatherings Request Exclusion RL Other Request Exclusion RM Prescribed Fire Request Exclusion RN Seismic Activity Request Exclusion RO Stratospheric Ozone Intrusion Request Exclusion RP Structural Fire Request Exclusion RQ Terrorist Act Request Exclusion RR UniqueTraffic Disruption Request Exclusion RS Volcanic Eruptions Request Exclusion RT Wildfire-U. S. Request Exclusion RU Wildland Fire Use Fire-U. S. URLfor AQS Table: http://www.epa.gov/ttn/airs/airsags/manuals/Qualifiers Code.xls AQS Exceptional Event Tutorial: http://www.epa.gov/ttn/airs/airsaqs/manuals/ExceptionalEventTutorial.pdf 17 ------- |