Project: NPAP QAPP
Element No.: 1.0
Revision No.:
Date: 1/08/2015
f/EPA
United States Office of Air Quality EPA
Environmental Protection Planning and Standards
Agency Research Triangle Park. NC 27711 January 8. 2015
Air
Quality Assurance Document
Quality Assurance Project Plan
for the Federal National
Performance Evaluation Program
(NPAP) for NAAQS Gasses
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Project: NPAP QAPP
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Foreword
U.S. Environmental Protection Agency (EPA) policy per EPA Order CIO 2105 requires that all
projects involving the generation, acquisition, and use of environmental data be planned and
documented and have an Agency-approved Quality Assurance Project Plan (QAPP) before the
start of data collection. The primary purpose of the QAPP is to provide a project overview,
describe the need for the measurements, plan, and define quality assurance/quality control
(QA/QC) activities to be applied to the project, all within a single document.
The following document represents the QAPP for the environmental data operations involved in
EPA's National Performance Evaluation Program for the National Ambient Air Quality system
(NAAQS) Gas Monitoring Network: the National Performance Audit Program(NPAP) for
mailed and Through the Probe (TTP) audit methods. This QAPP was generated by using the
following EPA monitoring and QA regulations and guidance:
• 40 CFR Part 50, Appendices A,C,D, and F
• 40 CFR Part 58, Appendices A, C, and E.9
• EPA QA/R-5, EPA Requirements for Quality Assurance Project Plans
• EPA QA/G-5, Guidance for Quality Assurance Project Plans
• EPA QA/G-9, QA00 update, Guidance for Data Quality Assessment: Practical Methods for
Data Analysis.
All pertinent elements of the QAPP regulations and guidance are addressed in this QAPP.
This document and related NPAP-TTP (or Mailed) SOPs are accessible in PDF format on the
Internet on the Ambient Monitoring Technology Information Center (AMTIC) Bulletin Board
(available at http://www.epa.gov/ttn/amtic/amticpm.html) under the QA area of the PM2.5
Monitoring Information. The document may be read and printed using Adobe Acrobat Reader
software, freeware that is available on many Internet sites, including the U.S. Environmental
Protection Agency's (EPA) Web site. The Internet version is write-protected. Hardcopy versions
are available by writing to or calling:
Mark Shanis
Office of Air Quality Planning and Standards
MQAG (C3 04-06)
Research Triangle Park, NC 27711
Phone: (919)541-1323
E-mail: shanis.mark@epa.gov
This is a living document, which means it may be revised as program objectives and
implementation procedures evolve. Comments about technical content and the presentation of
this document may be sent to Mark Shanis.
The document mentions trade names or brand names. Any mentions of corporation names,
trade names, or commercial products do not constitute endorsement or recommendation
for use.
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1.0 QA Project Plan Approval
Title: NPAP Performance Evaluation Program Quality Assurance Project Plan
The attached Quality Assurance Project Plan «,Q>\PP) lor the NAAQS (Ciasscs) National
Performance Audit Program (NPAP) is hereby recommended lor approval and commits the
participants oi'the program to tipow the^ele^ats de^crilvd within
OAQI'S Signature; L^L'UL Date:
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Acknowledgments
This QAPP is the product of the combined efforts of EPA's Office of Air Quality
Planning and Standards (OAQPS); EPA Regional offices; and State, Local, and Tribal
(SLT) organizations. Mark Shanis of OAQPS led and directed the 2013 update and the
NPAP QA Workgroup reviewed the material in this document. The following individuals
are acknowledged for their contributions.
SLT Organizations
EPA Regions
Region:
1 Robert Judge, Chris St Germain
2 Avraham Teitz
3 Loretta Hyden, Colleen Walling
4 Greg Noah, Mike Crowe
5 Scott Hamilton
6 John Lay
7 Thien Bui and Lorenzo Sena
8 Joseph Delwich, Joshua Rickard
9 Mathew Plate, Larry Biland
10 Chri stopher Hall
Office of Air Quality Planning and Standards
Mark Shanis, Dennis Crumpler, and Michael Papp
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A.2.1 Document Control List - Updated 8/07/2006
1. Converted to R-5 format
(A) See Table of Contents
2. Change from NERL to OAQPS in 1998
(A) Coordinator to Manager
(1) Shifted some coordinator's duties to contractor
(a) Move procedures from the QA Plan and SOP 001 to the
contractor
(2) NERL laboratory to EPA Region 7 laboratory
3. Modified to include NATTs Proficiency Testing Program in 2005
4. Modified 2006 to include Through-theProbe (TTP) (vs. Mailed) NPAP Audit
Delivery for Gaseous Criteria Pollutants
5. Deleted Mailed and NA TTS June 2014; TTP only
A.2.2 Abbreviations:
ORD Office of Research and Development
NERL: National Environmental Research Laboratory. Part of EPA ORD (Office
of Research and Development)
OAQPS Office of Air Quality Planning and Standards
AQAD: Air Quality Analysis Division
NPAP: National Performance Audit Program
AMTIC: Ambient Monitoring Technology Information Center, Website on the EPA
TTN
TTN: Technology Transfer Network
NIST: National Institute of Standards and Technology
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A.2.3 Table of Contents
Group Page
A Project Management
A1 Title and Approval Sheet 1
A2.1 Document Control List 2
A2.2 Abbreviations 2
A2.3 Table of Contents 3
A3 Distribution List 5
A4 Project/Task Organization 6
A5 Project Definition/background
A5.1 NPAP-Mailed 8
A5.2 NPAP -TTP
A6 Project Task Description 8
A7 Quality Objectives and Criteria for Measurement Data 14
A8 Special Training Requirements/Certification 15
A9 Documentation and Records 15
B Measurement/Data Acquisition
B1 Sampling Process Design (Experimental Design) 16
B2 Sampling Methods Requirements 16
B3 Sample Handling and Custody Requirements 16
B4 Analytical Methods Requirements 17
B5 Quality Control Requirements 17
B6 Instrument/Equipment Testing, Inspection, and
Maintenance Requirements 19
B7 Instrument Calibration and Frequency 22
B8 Inspection/Acceptance Requirements for Supplies
And Consumables 23
B9 Data Acquisition Requirements (Non-direct Measurements) 23
BIO Data Management 23
C Assessment/Oversight
CI Assessments and Response Actions 26
C2 Reports to Management 30
D Data Validation and Usability
D1 Data Review, Validation, and Verification Requirements 32
D2 Validation and Verification Methods 32
D3 Reconciliation with User Requirements 32
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Tables
A4-1 Project Structure 7
A6-2 NPAP Audit Schedule 13
B5-1 NPAP Table of Internal Quality Control Acceptance Values 18
B6-1 Preventive Maintenance Procedures 19
BIO.5-1 NPAP Audit Acceptance Limits 25
C1.1 -1 NPAP Schedule for Performance Audits 28
CI.2-1 Verification Procedure for Systems Audit 29
C2-1 List of Reports Required by Contractor 30
APPENDICES
Appendix A: Table of Contents of the TTP SOP Compendium-The Compendium is
posted on AMTIC, as is this QAPP
Appendix B: QAPP and SOPs for Evaluation (Verification) by EPA Region 7 of NPAP
Contractor Performance - These will be posted on AMTIC
Appendix C: NPAP TTP QA/QC Summary tables
% of Complete TTP PE out of 100% in 5 Years, and in most Recent Year
Regional Exceedance Summaries for 5 Years and Most Recent Year
NPAP TTP Whole System Verifications 2004-2014
Blended Gas Cylinder Verifications
Ozone Analyzer Verifications
Annual NPAP TTP Personnel Certification/Recertification Training; Remote and Hands-
on Sessions: Ozone Checklists, Blended Gas Checklists, and Everything
Else Checklists
Critical Highlight (PP Slides)
SOP Slides
Appendix D:
NPAP SOPs: Data Validation for Data Bases of the NPAP:
Procedure for Checking the Data in the EXCEL Workbooks:
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1) Check to be sure all of the following information is included or selected on the
information (1st) page/worksheet of the workbook:
a) AQS site ID (for correctness: i.e., missing digits, too many zeroes, remove dashes
if included)
b) Date of audit
c) NPAP TTP Audit or Certification Data
d) Method Code/POC
2) Check AQS transactions page (last page/EXCEL worksheet in the workbook) for
data and concentration separators, and that they are in the correct places
Directions for Entering Audit Data into the Intermediate (Access) Data Base:
1.0) Processes (Audit and Verification results)
1.1) Load new data via spreadsheets to AQS staging area
1.2) Enter Staging area data by hand
1.3) Process staging area data
1.4) Edit Cylinder Assays
1.5) Edit processed audits
2.0) Report (Query)
2.1) Audit Details —* Query by Region; view 1 page at a time
2.2) Audit Summaries—* Query by Region; Summary of Regions audits
2.3) Failed Audits Report—* Query by Date, where Failed
2.4) Certification Report—* Query by beginning and ending date
2.5) Tanks Certifications—* Query by beginning and ending date
Appendix E: SRP: Schedule, SOP Table of Contents, & Guidance Document
Appendix F: NPAP TTP Audit EXCEL Workbook
Appendix G: TTP SOP Section 6 Table of Contents
A3 - Distribution List
Role
Audit Support Contractor(s)
Contractor's Program Manager
Contract Project Officer
NPAP WorkAssignment
Manager (NPAP)
AAMG Group QATeam Leader
OAQPS QA Manager
Organization
C ontractor (A1 ion)
EPA, OAQPS-OD, COR Contracts
EPA, Work Assignment
EPA,
EPA,
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A4 - Project/Task Organization
The Audit Support Program is conducted by EPA OAQPS, and an RTP audit
development, testing, and training, and, as available, certification, support contractor; in
the ten EPA Regions, by the EPA Regional Laboratory Staff, and their ESAT contractors
who are trained and certified by EPA for NPAP TTP audits, with third party, independent
verification support provided as needed through an MOU with EPA region 7 (NPAP).
The EPA RTP Work Assignment Manager (WAM) or TOPO/COR is Mark Shanis
(NPAP). He reports to Group Leader, OAQPS/AQAD/AAMG (currently Lewis
Weinstock). The EPA Work Assignment Manager is responsible for overseeing the
activities program. EPA also performs systems and performance audits on the contractor.
The NPAP OAQPS WAM/TOPO/COR works with the ten EPA Regional NPAP
Contacts to ensure the participation of the state, local, private, and tribal agency
participants in their respective Regions.
Contractor personnel consist of a Program Manager and staff. The contractor's
responsibilities are listed in section A6.
The EPA Region 7 Laboratory conducts performance evaluations of the Regional audit
systems and materials provided to NPAP participants by OAQPS and used by the
Regions. The details for responsibility of the Region 7 NPAP Laboratory are provided in
the QAPP for that laboratory. See Appendix B.
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EPA Region 2 and 7
Verification Labs
EPA NPAP Lead
(RTP)
RTP Contract
Support
EPA Regional Office
NPAP Contacts
Regional Office
Contract
Support
Technical
Contractual
Monitoring
Organizations
ESAT Field
Scientists
Figure A 4-1 NPAP Program Structure
A5 - Problem Definition/Background
A5.1 NPAP
The National Performance Audit Program (NPAP) the means to by which EPA
assesses the proficiency of agencies that are operating monitors in the State and Local Air
Monitoring System (SLAMS) and Tribal networks, and the Prevention of Significant
Deterioration (PSD) permits and the CASTNET programs. The NPAP is a quality
assurance audit program required under Section 2.4 of 40 Code of Federal Regulations
Part 58, Appendix A (SLAMS and PSD, now combined in the October 2006 promulgated
revision). The monitoring data from these networks are of critical importance in
gathering information to make decisions about protecting public health. They are used to
determine if an area is in attainment or non-attainment of the NAAQS, and for trends
assessment and modeling projections. If, in reviewing the data, an area is found to be in
non-attainment the State and Local agencies must develop a control strategy in a State
Implementation Plan (SIP) to come into attainment. The economic impact of this decision
can be in the millions of dollars and the integrity of the data to make this decision is
essential. Similarly, Tribes may use their data work with sources to better control the
pollution they generate that impacts tribal members.
NPAP is a key regulatory requirement to ensure and maintain the integrity of these data,
especially as regards comparability of data sets (sufficiently or acceptably low amount of
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systematic variability) in monitoring programs across cities, states, air sheds, regions, and
nationally; and in maintaining the traceability of measurement standardization to NIST.
NPAP delivers Performance Evaluation/audit gas samples to the ambient air monitors in
two programs:
1) The mailed program, started in the 1970's by the Office of Research and
Development (ORD). Until 2005, gas samples were generated centrally to
supply audits from the back of the analyzer (BOA) sample intake.
2) The Through-the-Probe (TTP) program (2003), which is operated regionally.
The TTP audit system generates enough audit test gas to challenge most
ambient air monitoring stations starting at the sample inlets. This larger test
flow capacity can go up to a high of 20 or 30 1pm, vs the low mailed flow of
from 4-6 1pm, This higher capacity enables evaluation of the entire sampling
flow path, from the sampling station inlet up to and through the BOA into the
analyzer. The program was based on a model operated for 20 years by the
California Air Resources Board (CARB)to address limitations of the mailed
program, and was made more economically feasible by the PM2.5 Performance
Evaluation Program, developed by OAQPS for the 1998 PM2.5 standard.
The equipment of both mailed and TTP audit systems generate concentrations in the
ranges agencies are required to operate at for attainment and related decision-making.
The required audit ranges are specified in 40 CFR Part 58, Appendix A and in guidance,
and are intended to give appropriate flexibility to the EPA (Regional and CASTNET) and
agency (State, Local, and Tribal) staff charged with conducting the audits. As NPAP does
not specify audit ranges, the auditors will use the same ranges that agencies use to
perform their own internal audits as specified in 40 CFR part 58, App. A. Until October,
2006, the CFR-required FRM or FEM monitors for gases were set at most sites at from
zero to 50 ppm full-scale for carbon monoxide (CO) and from zero to 50 ppb ozone (O3),
sulfur dioxide (SO2), and nitrogen dioxide (NO2). An updated table of audit ranges was
published in October, 2006 for the agency-required audits. These ranges acknowledged
the addition over the years of a small network of gas analyzers that perform more reliably
and accurately for CO, SO2 and NO2 at a lower full scale range; and for a lower O3
standard. The NPAP audit SOP and audit data Workbooks have been modified to reflect
this change.
A5.2 NPAP MAILED & NPAP TTP
The mailed program devices and NPAP TTP audit systems for gaseous audits
only generate proficiency test samples of NAAQS gases (O3, CO, SO2, and NO2).
In the mailed program, settings were provided to the agency's station calibrator or
operator, who performed the audit. EPA values for the blind settings, used by the
operator per instructions, were provided after the agency's data and the audit devices
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were returned to the contractor in RTP. This lead to significant time delays in notification
of results. These delays were of concern even if the results were within the EPA
acceptance limit (15%), but especially if the acceptance limit was approached or
exceeded. However, the cost was much lower than if the devices were delivered and the
audits done by an qualified, independent person.
In the TTP program, first four (2004), then six (2005-6), and now eight (2007-2012)
regionally-based mobile TTP laboratories are in operation and the audits are delivered by
regionally-based, EPA-trained and certified EPA and/or contractor audit personnel. By
2013, all ten Regions had their own, complete TTP audit systems to deploy. The mobile
laboratories contain a carefully assembled system of high quality and high capacity
(volume/flow) audit gas support, generation, and analysis equipment. The stability and
ranges of the concentrations are independently certified to be traceable to NIST standards
by the on-board analyzers. Once this information is available, staff may start monitoring
the audit gas sample. The results are automatically calculated and the audit reports
generated in the EPA data entry forms. OAQPS asks that the Regional auditors provide
copies to the station operator that day, before the TTP auditor leaves the site.
The generating, analytical and delivery equipment are transported to the audit sites in at
least three different mobile "platforms." The platform with the largest capacity and
greatest maneuvering challenges is the tow vehicle and trailer combination. The truck
platform is more maneuverable but carries less cargo. The most flexible and portable
arrangement is the case-based system, which is delivered in vehicles from "bread truck"
size on down to medium and small vans,
These transport vehicles are modified for transporting compressed gas cylinders and can
provide power to the audit system instruments for warm-up and to allow for audit gas
flow path conditioning during transport.
The latest TTP development is the Precursor Gas analyzer TTP audit system and method,
for CO, SO2, and NOx monitors and the national network of NCORE sites. The first
system was assembled and initially tested in RTP (from 2007/8 to the present). A second
one is based out of the EPA Region 9 lab in Richmond, CA.
The reduced mailed audit program's GDS devices have been tested with the RTP PG
TTP system cylinders and found to be useable for that level of concentrations in the
Regions to generate supplementary QC and/or QA information, especially during the
initial development of the NCORE network and given the currently very limited NPAP
TTP PG mobile laboratory capacity.
A6 Project Description and Schedule
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The NPAP audits all of the gaseous pollutants for which there are NAAQS.
Specifically, the following criteria air pollutants will be audited under the NPAP during
the period of this contract: SO2, NO2, carbon CO, O3.
In the past, there were 5000-plus air pollution monitors in the ambient air network
comprised of SLAMS and PSD sites. In 1997, the monitors were distributed as follows:
S02 (645); CO (540); N02 (373); O3 (943). In 2004, there were 733 sites for O3, 339 for
SO2, 284 for CO, and 213 for NO2. The SLAMS monitors are operated by approximately
170 State and Local agencies, all of whom are eligible to be audited in the NPAP. Also
included in the NPAP are approximately 135 governmental and private that operate air
monitors at PSD sites, for a total of approximately 305 participating organizations.
A 6.1 Mailed NPAP
The NPAP mailed audits were accomplished using a variety of systems. The
participants, i.e., the personnel of the monitoring organization being audited used these
audit systems to generate pollutant concentrations and flowing air streams, which they
introduced into their sampling system. The pollutant concentrations were unknown to the
audit participants. The outputs from the sampler that resulted from the use of the audit
systems were recorded on a data form, returned to EPA, and compared to the
concentration or flow rate that should have been generated by the audit system under the
environmental conditions at the site where it was used. The differences between the EPA
expected (certified) values and the NPAP participants reported values were calculated
and returned to the participant within two to four weeks of the audit. Summaries of the
results within the NPAP acceptable limits of 15%, the results that were not within these
limits, as well as corrective action responses, were reported monthly to the WAM and
designated NPAP contacts in the ten EPA Regional Offices. Currently, a number of the
Regions have taken a few of the mailed devices to be used to measure the NAAQS gasses
and a few of them are being kept in RTP. In the future, they will be used by the Regions,
or their SLT agencies.
A 6.2 TTP NPAP
The NPAP TTP audits, currently only provided for the gaseous criteria pollutants
(O3, CO, SO2, and NO2) are performed in ten mobile laboratories, containing the safest,
most accurate, reliable, and cost-effective gas generating, analysis, and support
instrumentation available. The mobile labs are located in the ten EPA Regions. Before
2014, in order to give all Regions the opportunity to use these labs, two of the eight were
shared between adjacent Regions. The Region 9 mobile lab was shared for about a
month/year with Region 10 and Region 7 shares its mobile lab with Region 8 for two
weeks.
The mobile laboratories in Regions 5, 6, and 9 are based in trailers that must be towed by
a tow vehicle. The mobile labs in Regions 4 and 7 are based in truck-type vehicles that do
not require towing. In Region 2, support, generation and analysis equipment was first
mounted in a case-based system and a second case-based system was developed and
provided to Region 3. Region 1 assembled its own case-based system, based on the
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Region 2 design. Region 9 changed to a case-based system in 2008. Recently, OAQPS
provided the equipment for two new case-based audit systems, Regions 8 and Region 10.
Case-based systems are used in Regions 1, 2, 3, 8, 9, and 10.
Personnel independent of the audited monitoring organizations use these audit systems to
generate pollutant concentrations and flowing air streams, which they analyze onsite with
independent analyzers calibrated onsite using NIST-traceable standards. If the on-board
analysis and recording system document the stability and correct concentration of the
generated gases, the TTP operator tells the site operator to start analyzing the TTP gases
using the site's monitors and procedures. The introduction of the TTP audit gases into the
inlet of the monitoring station's sampling system (TTP) is the critical step in the process.
EPA auditors may choose to provide trouble-shooting and/or perform a re-audit after
problems are found initially. A typical trouble-shooting procedure is a BOA audit. If
the problem is resolved before the EPA auditor has left the site, s/he may choose to do
the re-audit. If not, the Region will work with the agency to arrange a re-audit. All
valid re-audits are to be reported and the results distributed in the same way as the
initial audits. If the auditor is a contractor, s/he may not take the time to provide
trouble-shooting services or re-audit unless approved by the EPA WAM.
NOTE: No auditor may in any way change the audited system, before, during, or after
the audit. No auditor may stop the audit before completion of the audit to allow agency
staff to trouble-shoot if audit limits are exceeded, or if findings, such as dirt in
manifolds, are identified before or during the audit process.
The Regionally-based TTP program began as a pilot program in three Regions in 2004
with EPA Program funds. Currently all regions are now served by eight mobile lab
systems, with Regions 8 and 10 sharing management. In 2014, Regions 8 and 10 will
have their own audit systems.
The NPAP program has been funded with State, Local, and Tribal grant funds since
2007. Agencies wishing to implement their own TTP audit programs were provided with
guidance and independent certification support. The certification indicates that the
agency TTP audit data are equivalent to the data obtained by a Regional TTP auditor. The
certification process includes a side-by-side performance audit at no less than one site by
both TTP systems, and a review of the critical elements of the audit.
The gaseous TTP pollutant concentrations are unknown to the audit participants. The
outputs from the agency analyzers that result from the use of the audit systems are
recorded on a data form, returned to EPA, and compared to the concentrations that were
generated by the audit system .
The TTP program is more flexible than that of the mailed BOA program. The TTP
concentrations may be adjusted onsite as needed and the audit data are recorded in an
EPA EXCEL spreadsheet-type workbook of individual audit worksheets, which
automatically generates a preliminary audit report for each pollutant, and a summary for
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the site visit. The workbook and /or the summary report, reviewed by both site operator
and TTP operator, should be given to the site operator before the TTP operator leaves the
audit site. The workbooks and TTP operator's electronic log notes are emailed to EPA
(Region and OAQPS) within two work days of the completion of the audit. Similarly to
what was done for the mailed program, summaries of the results that are within the NPAP
acceptable limits of 15%, for CO, SO2, and NO2, and 10% for O3 and the results that are
not within these limits, as well as corrective action responses, may also be reported
monthly to the WAM and, if different people, the designated NPAP contacts in the EPA
Regional Offices.
NOTE: Re-audits should be treated as separate audits. Auditors should not offer to
resolve an issue for the agency before the audit is completed, unless the failure and
request for help comes from the agency and the auditor's management approves the
time. Since a number of auditors are contractors, they would have to be notified in
writing before they arrive, or get legal authorization after they are at the
site location.
A.6.3 The TTP Program NAAQS Gas Audit Support Contractor and the Regional EPA
and ESAT contractor or State, Local or Tribal auditor staff responsibilities are listed
below:
1.0 Preparation, calibration of Audit Systems and Execution of Technical
Systems Audits
The EPA, State, Local agency, Tribe or contract shall provide support for the
preparation, calibration of audit systems and the execution of technical systems
audits as described below:
1.1 Preparation and Calibration of Audit Systems.
NPAP Gas (O3, CO, S02,N02) audits: The auditor or audit support
contractor shall prepare/calibrate the audit systems/materials according to
the NPAP TTP Standard Operating Procedures (SOPs) Compendium. The
mailed program compendium and the TTP Program compendium are
posted on the EPA's Technical (Information) Transfer network (TTN),
accessible to the public through the internet. The EPA auditor or audit
support contractor shall check each audit system and component device
and standards for cleanliness, operational fitness and calibration prior to
use in the NPAP. The specific internal quality control guidelines are
located in Section A7, Quality Objectives and Criteria for Measurement
Data.
The EPA shall select, and the EPA or contractor auditor shall use the
system for NPAP audits based on the types of monitors to be audited, cost-
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effectiveness, and audit quality needed in calibrating, delivering (by
shipping, driving, or carrying), connecting, and using the system. For
example, when only O3 monitors are to be audited, the equipment needed
for doing the CO, SO2, and NO2 audits may or may not be taken on the
audit trip. When only SO2, NO2 and CO monitors are to be audited, the O3
analyzer may not need to be brought to the site. The contractor shall
follow procedures in EPA SOPs for these monitors.
EPA provides TTP audits for NAAQS gas monitors at the sites for which
an agency is required by EPA to report data to AQS, within the limit of the
number of sites that resources allow, taken from the State's 105 grant
funds for that year. The allowed exceptions include when access or other
logistical practicality makes TTP cost ineffective or inappropriate. In that
case, mailed devices, and. if absolutely necessary, BOA audits will be
allowed. NPAP TTP SOPs that must be used by the national program
auditors are available at the EPA AMTIC website, along with the mailed
program SOPs, and this QA Project Plan, The SOPs and this QA Plan are
updated as time and other resources allow.
1.2 Technical System Audits (TSA) Conducting TSAs at the same time as
PEs are performed may be cost effective. Therefore, at times and on
request of the EPA Work Assignment Manager (WAM) or Task Order
Project Officer (TOPO), the contractor shall perform technical systems
audits of State, Local or Tribal agencies as required in 40 CFR 58
Appendix A in accordance with the guidance in Quality Assurance
Handbook for Air Pollution Measurement Systems Volume II; Part 1,
Ambient Air Quality Monitoring Program Quality system Development
Section 13.
If requested, a contractor shall accompany the EPA WAM, COR, or
TOPO of the TTP programs of the Regions, States, Local, or Tribal
agencies. The qualifications and experience of the TSA team members
should be independent and adequate, as indicated in the criteria listed in
the independence and adequacy appendices of the annual NPAP and PEP
implementation decision memos sent out each year to the Regions and
their State, Local, and Tribal agencies. The EPA NPAP TOPO, as
resources allow, will periodically perform a TSA of the Region 7 NPAP
Verification Laboratory. Prior to the TSA trip, the supporting contractor
shall provide the WAM, TOPO, or COR with any recommendations for
modifications to the Technical Systems Audit checklist in the NPAP QA
Plan. Within one week following the trip, the contractor shall provide
written recommendations to the EPA WAM/TOPO/COR to use in
preparing the Audit Report, and comments on the NPAP Program
manager's draft report.
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See also Section CI.2 (former p.35, Systems Audits)
2.0 Annual Planning, Scheduling and Delivery of Audit Systems.
2.1 NPAP Annual Planning The EPA NPAP Manager will determine the
eligibility of any potential new participant in the NPAP, based on
discussions with and priorities of the EPA Regional Office NPAP
Contacts. The mailed audits will primarily be provided from the Regions
in which they will occur. The audit support resources in each region for
the four NPAP TTP gasses are now sufficient to check the output of the
mailed devices. Also, a few mailed devices have been provided to the
Regions that have asked for them. A few will be maintained in RTP, NC.
2.2 Audit Funding Currently the level of funding and use of the mailed
program is so minimal that all communications from NPAP participants
either go through the Regions, if the audits are TTPs, or through the EPA
OAQPS NPAP Program Manager for either program. The annual letter
inviting past (current and immediately previous years) audit requestors to
communicate their contact information and annual audit needs now comes
from the EPA AQAD Division Director. The agencies indicate their
intention to participate in the next year's audits, as required by 40 CFR
Part 58, Appendix A, by completing and returning the attached forms,
indicating the number of sites with monitors of the NAAQS criteria gases
and particulates.
2.3 Audit Planning The responses are accumulated into an annually updated
contact list and distributed to the Regional NPAP contacts by the OAQPS
NPAP Program Manager. From this list, both annual withholds from State
Air Grant (STAG 105) funds are prepared by OAQPS, and Regional
NAAQS gas audit site plans for the coming FY are prepared by the ten
EPA Regional Office contacts for the NPAP TTP program in their Region.
Funding and site planning are initiated and provided for CASTNET and
National Park Service (NPS). O3 site planning is done by a contact in the
EPA Clean Air Markets Division (CAMD).
2.4 Identifying Required Sites
As early as circumstances allow before the beginning of each calendar
year (CY), the EPA NPAP manager proposes lists of selected agencies and
required sites for each pollutant. The EPA Manager works with the EPA
Regional NPAP contacts to develop these lists.
These lists are organized by EPA Region, State, Local or Tribal agency
and by site. The list is limited to the number of agencies for which
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anticipated funds will be withheld, and then provided through OAQPS (or
in the case of CAMD funds, provided directly) to the Regions to allow
NPAP gas audits or materials to be provided in the next calendar year.
Each selected agency gets only one TTP audit, one mailed audit device or
set of materials that year. Each mailed device may be used to audit more
than one site. TTP cost estimating and funding will be based only on the
number of sites, since the major cost determinant for site delivery of the
mobile lab is the trip time and associated expenses traveling to and from
the base to the site.
For the TTP program selections of sites, the EPA required SLAMS site list
must be completed as is, and allows for no other sites, except as
determined by the EPA Region. The funding by the state grants (STAG
105), may at times be supplemented by other resources, such as
CASTNET/Park Service, Tribal and NCORE STAG 105, or as a result of
circumstances of site operation, such as equipment failure or sudden
closure decision due to power failure. The proposed lists of agencies and
required sites are sent to each region with a request that the Region get
feedback from the state and local agencies and provide OAQPS with any
resulting corrections for errors and/or recommendations for changes of
sites or selected agencies.
The proposed required lists are amended based on the feedback from the
regions, if possible by mid-November, after the annual budget (fiscal year
or FY) has been determined, so that they (one for SLAMS/NCORE, one
for Tribes one for CASTNET) may be sent to the DC staff who do the
withholds.
Since the limit of the number of agencies to be funded in one year is
always based on the FY budget, and on what is requested (estimated #
sites x estimated rate/ site), if an agency has not been audited for a
pollutant for four years, an audit for that agency becomes a priority.
The revised, proposed, funded lists are then provided to the EPA Regional
Office NPAP TTP contacts for the NPAP program contractors to be
incorporated into the requested schedule for the year.
Late in each CY prior to the next audit, EPA sends out invitations for
NPAP participation to the registered organizations that have taken part
during that or the previous year, inviting them for the next year's audits, as
required by 40 CFR part 58, Appendix A. They are asked to complete and
return forms for each audit of each criteria pollutant that they should audit.
Each summer, states are required to decide if they would rather would do
the TTP audits at their sites in the next C Y. If a state chooses to do the
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audits, the Region in which they are located will be required to review the
state's TTP audit program and determine if it meets the national program
adequacy criteria, so that the state audits can be demonstrated to be
equivalent to the national audits. This review and certification has to
include at least one annual side-by-side comparison of the two systems,
and at least one more, depending on the size of the network. The
difference between the two sets of results are required to be within an
agreed upon acceptance limit.
The goal for this annual decision is currently set at 20% each CY, with an
expected 100% evaluation of all network sites reporting to AQS within
five years. Exceptions are allowed for high priority repeat audits, for those
that exceed the acceptance limits, and especially for exceedances at sites
near to the NAAQS or where the state audits are found to exceed the
state's own acceptance limits.
2.5 Scheduling Audits with Agency Operators
The Regional EPA Auditors (Regions land 2 and some in Region 7) or
Regional ESAT TTP contractors shall develop an audit schedule. The
contractors' schedules will be approved by the EPA Regional ESAT
WAM or TOPO. The list of agencies and sites for which the Regions plan
to provide audits in the coming CY will be submitted electronically to the
EPA NPAP Program manager in RTP as soon as possible before the audit
season starts for the upcoming year.
3.0 Data Base Maintenance, Processing, and Distribution
3.1 NPAP Database Background:
3.1.1. The NPAP data are currently contained in two paper and two
electronic data bases. The data from the mailed program have been
kept by the EPA contractor since EPA requested that a data base be
established in 1989. The electronic mailed data base was created in
FOXPRO, and operated and maintained by a mailed program
contractor. The mailed paper data base has been archived. The
oldest paper data sheets are scheduled to be or already have been
disposed of according to EPA procedures. EPA has an electronic
copy of the mailed data base.
3.1.2. The second paper and electronic data base, which contains the
initial NPAP TTP audit and certification data, was created in
EXCEL in 2003-2004 by EPA Regional personnel. A central
OAQPS-developed, operated, and maintained intermediate
database for the critical audit and certification data was created in
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ACCESS by AQS staff. The critical audit and certification data
were moved from the central OAQPS CDs of individual EXCEL
workbooks and associated certification files into the intermediate
data base. In 2007, screening QC procedures were performed to
ensure that the intermediate audit data were acceptable for entry
into AQS. About 75% of the data were acceptable and entered into
AQS.
NOTE: A procedure for using AQSQA to check for invalid AQS codes, and a related
procedure to be conducted by the EPA Regional or contractor staff to check for valid
but incorrectly used codes, has been developed with assistance from the AQS staff and
presented to the NPAP Regional network.
3.1.3. The TTP field data are collected by Regional EPA personnel, but
mostly by EPA Regional ESAT contractor personnel. The EXCEL
workbooks are printed out and provided on site, at least as
Preliminary Reports, to the station operator staff, on the day of the
audit, prior to the TTP operator leaving the site. They are given to
the EPA Regional NPAP TTP contact staff, who are responsible
for sending the final reports, with requests for any follow-up
action, to the appropriate audited agency lead personnel and to
OAQPS.
3.1.4. OAQPS has been entering the workbooks into the central OAQPS
Intermediate ACCESS database., Until 2012, AQS staff entered
the last worksheet in the workbook, the AQS transaction sheet, into
AQS. As of 2013, AQS entering is no longer available. OAQPS
TTP or Regional staff will have to do the attempted entering.
Some entering errors do occur for some transaction pages. Most
need to be corrected by Regional staff, so, with limited help from
OAQPS, entering TTP results into AQS will need to be done by
the Regions. A brief Region 5 "how-to" procedure has been tested
and provided to several Regions to try out. All the Regions will
need to use it to enter the TTP results from 2014 on.
An improved entering application is being developed by AQS.
A7 Quality Objectives and Criteria For Measurement
The quality objectives and criteria for measurement are to provide audit materials
and devices that will enable EPA to assess the proficiency of agencies that are operating
monitors in the SLAMS/NAMS/PAMS/PSD/ networks. Based on performance data for
all of the EPA Regional network of NPAP mobile audit systems, and quality objectives
for their use, EPA has established acceptance limits or criteria for each of the audit
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systems and their component materials and devices. Each audit system, material, or
device is tested following established SOPs (see Appendix). Quality criteria for each
audited parameter are discussed in Section "B5 Quality Control requirements" below and
in referenced SOPs. Any audit system, device or material not meeting these pre-
determined criteria are not used in the programs.
A7.1 Audit Devices/Materials
All audit devices and materials used in NPAP will be certified as to their
true value and that certification will be traceable to NIST standard materials or devices
unless not available or applicable. Accuracy and precision will be determined by the
NIST-traceable material or device but in all cases will be known. Control charts showing
the trends of critical parameters will be maintained. SOPs for the calibration of all
instruments, devices, and the analysis of performance audit/proficiency test samples will
be maintained and kept up to date.
The materials used in the NPAP will be as representative and comparable as possible to
the calibration materials and actual air samples used/collected by the
SLAMS/NAMS/PAMS/PSD networks.
A7.2 Audits
The objectives for the NPAP audits are two-fold: (1) to complete at least 95
percent of the scheduled audits by the end of the year and (2) to determine if the
participant's performance exceeds the limits shown in Table A7 Accepted Limits.
A7.3 Data Base
All NPAP TTP program results will be entered into the intermediate data base by
OAQPS personnel as received from the Regional EPA NPAP contact staff or contractor
field operators. Screening QC checks to catch entry errors are built into the intermediate
ACCESS data base. They are also being incorporated into the new ACCESS field data
entry and reporting software. The errors or systematic program problems that are
identified by these checks are used in a process of continual program process quality
improvement.
A8. Special Training Requirements/Certification
Training may involve self-training and seminars/classes, as available. On-the job
training will occur as an audit is performed and experience gained. In-house training will
be conducted by personnel presenting the principles and techniques used in similar
audits.
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As resources allow, EPA provides TTP personnel audit system training and certification
at least annually for both new and trained personnel. This scheduled recertification allows
auditors to share their knowledge and share real-world experiences with one another.
EPA is now using phone and PC and, where resources allow, Internet Conferencing to
provide the initial non-hands-on sessions for new auditors. All auditors must take the
written exam session and the hands-on sessions together. However, as travel resources
may become tighter, as the Regional EPA NPAP contact staff are able, some of these
latter sessions may be given by the Regional staff, or at least at the Regional locations.
Continually updated training materials are available.
In addition to the initial and recertification classroom and hands-on training, all
auditors must complete at least three supervised audit trips, each trip consisting of two to
three audit sites. This must be done before the new auditor may perform an audit alone.
The on-board trip supervisor should be an experienced NPAP TTP auditor,
A9 Documentation and Records
Before leaving the audited station, EPA or EPA contractor NPAP TTP auditor
should give the agency station operator a report showing the results of the audit compared
to EPA values.
The site operator should co-initial or co-sign a paper copy of the cover page of the NPAP
TTP EXCEL Audit Workbook/report for the auditor to give to the NPAP Regional Office
Contact for their files. A copy should be made to send to OAQPS.
When the Regional Office contact for NPAP TTP gets the copy of the audit workbook
from the auditor, the Regional contact sends a letter to the agency to the effect that 1) the
audit results were satisfactory, or 2) that the agency needs to carry out corrective action,
and then notifies the Regional contact of these actions and any results. The SOP includes
a form letter template.
EPA OAQPS is also planning to prepare a tool that will show where an agency's results
fall in a distribution based on the cumulative results of the audits from all the Regions for
the previous year.
Data and records from participants are maintained on site for at least one year by the
contractor. The data is then turned over to EPA where it is maintained for five years and
is then archived by EPA.
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GROUP B. MEASUREMENT/DATA ACQUISITION
B1 Sampling Process Design (Experimental Design
For the TTP audit program, the sampling design objectives are to meet the
requirements for stability, accuracy, completeness, representativeness, and comparability
of the test gas provided to the station's analyzer. There are two areas of sampling
performance to control and check in TTP auditing: sampling of the generated audit gas
test concentrations by the auditor's analysis system and sampling of the test audit gasses
delivered to the analyzers via the inlet and manifold. The sampling quality controls are
incorporated into the required EPA TTP SOPs. The reasons for these control choices may
be listed in the SOPs, or are available by contacting the EPA Regional NPAP contacts or
the EPA OAQPS TTP network manager.
B2 Sampling Methods Requirements
The term "critical" or "non-critical" can be applied to data received from
the field audits as well as the calibration/verification data for audit devices and analyzers.
Whether data are critical varies from audit to audit. Flow is not as important to the
accuracy of the audit gas test concentrations as the analyzers receive a partial, non-
dilution-based calibration just before the audit gasses are added. Most agencies check
their calibrator's mass flow controllers to make sure that the calibration and audits are
correct. This check does not pick up flow issues such as leaks in other parts of the
sampling system flow path, and does not check for chemical interference or reaction
issues. Also, for example, the ambient barometric pressure reading is taken during the CO
audit, but it is not critical since the analysis is not affected by this entry. However, the
barometric pressure reading is critical to the O3 audit since it is used in the calculations.
The specific sampling design issues are addressed and documented in the SOPs,
Implementation Plans, and Quality Assurance documents developed for each of the
sampling networks served by NPAP. For NPAP TTP audits, the test gas generation and
analysis sampling requirements for flow path materials, flow rates, residence times,
temperature, pressure, etc. are addressed in 40 CFR part 50 in the method appendices and
in 40 CFR part 58 in Appendices A and E and in appropriate parts of the TTP SOP
Compendium.
B3 Sampling Handling and Custody Requirements
B3 .1 Data Custody
Data custody follows standard QA procedures to ensure all data
generated or received is traceable. This includes the tracking of
results from shipment or direct delivery of audit materials/devices
to the audit participants; receiving data results from participants at
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the site on the audit delivery date; validating data results; and
storing the results in the appropriate data base. Records are also
kept on acceptance testing of audit materials and calibration of
audit devices. These records allow the tracking of an audit
material/device from its initial acceptance through to the storage of
the audit results in AQS and in associated program QC and QA
data in the NPAP data bases.
B3 .2 Sample Custody and Handling
Since NPAP support is a directly delivered audit program, not a
sampling project, there are no specific agency sampling handling
and custody requirements. These may include directions to the data
system that they are not sampling ambient air, but are being
audited. For the auditor, audit test sample generation, analytical,
and delivery requirements are detailed in the SOP Compendium.
As the Criteria Pollutant gas auditors generate dynamic reactive
samples that are continuously analyzed, the TTP equipment and
standards do require custody and control. Procedures and
equipment needed to keep the test samples technically and legally
intact, safe, and secure are detailed in the SOPs. Documentation of
the process is also required and addressed in the SOPs. The critical
TTP parameter for sample handling is stability of the generated test
sample, which is determined first for the generating system by the
TTP auditor and then for the sampling station systems by the
station operator.
B4 Analytical Methods
There will be no analytical procedures other than those used to certify the
quality of the audit materials or devices and the test samples they are used to generate.
These analytical and certification procedures are discussed in "Section B7. Instrument
Calibration and Frequency."
B5 Quality Control Requirements
The adequacy of the internal SOPs and adherence to these SOPs will be
annually reviewed by the contractor's Quality Assurance officer and the EPA Work
Assignment Manager/COR or TO (Task Order) PO (Project Officer). All audit devices or
materials will be checked prior to each use for cleanliness, operational fitness, and
calibration. A five-point calibration will be done at least once a year, no later than at the
beginning of the quarter in which it will be used in an audit, and prior to the use of the
audit device in an NPAP TTP audit. Checks on calibrations will be performed using
alternative materials from a different manufacturer or lot number. Control charts will be
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prepared for each critical NPAP parameter. Initial values will be assigned according to
the individual SOPs. Changes in the acceptable range will be documented with the reason
for the change in the appropriate mobile audit laboratory notebook. Specific internal QC
guidelines follow in Table B5-1.
For the Internal Quality Control of the NPAP TTP generation system, as detailed in the
SOP Compendium, section 6, subsections 7.3 and 7.4, analyzed concentration of the
Zero air for the TECO CO analyzer must be no greater than plus or minus 0.1 ppm. For
the independent comparison between the Continuous Zero Air Generator and the UP Air
Cylinder, the difference must be no greater than 0.5 ppm on the TECO CO analyzer or
proven equivalent, or corrective action must be taken. As required by the CFR, the
analysis of station's NOx(N02) Converter Efficiency (CE) must be 96% or greater. The
performance of the CO analyzer must be as specified in order to measure the CE and low
NO2 audit points.
The acceptance limit for the O3 analyzer performance should be close enough to allow for
the new 10% audit result acceptance limit (down from 15%), and the new 7% warning
limit.
B5-1. NPAP Table Internal Quality Control Acceptance Values
Device/Material
Frequency of Checks
QC Check
Compressed Gas cylinders
except VOC cylinders
Prior to use in a TTP
audit
± 3% of certified value
TECO 48C Analyzer
Prior to use in a TTP
audit
O&Lo/Hi Span: within +/-0.1ppm
O;,Standard (TECO 49C or
API)
Prior to use in a TTP
audit
± 4% or 4 ppb of the calculated concentration
+/- l%more than for the SRP
B6 Instrument/Equipment Testing, Inspection, And Maintenance Requirements
B6.1 All instrumentation used to calibrate or analyze audit devices or materials
will be maintained in accordance with the manufacturer's guidelines for
routine maintenance of that instrument. Instrument/equipment testing,
inspection, and other maintenance checks and procedures for each TTP
audit system component are listed in the Maintenance Section 9, of the
TTP SOP Compendium on AMTIC. See Appendix B. Critical Quality
Control limits for the audit system analyzers and standards are included in
the SOP and in "Table B5-1. NPAP Table Internal Quality Control
Acceptance Values" above.
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B6.2 Preventive maintenance is performed as in Table B6-1.
Table B6-1. Preventive Maintenance Procedures
TABLE OF CONTENTS FOR SUBSECTION (Preventive Maintenance)
For Instruments and Equipment
Manufacturer, SubSect. Page#
Page # in Operator's
Manual
See NPEP TTP
SOP Section 9.7.2
Gas Filter Correlation CO Analyzer
TECO Model 48C
THERMO Environmental Instruments (TEI,
TECO), p. 10
Chapter 5,
P 5-1
See NPEP TTP
SOP Section 9.7.2
Primary Standard UV Photometric
Ozone Calibrator- TECO Model 49C-
PS
THERMO Environmental Instruments p. 10,
11
Chapter 4,
p. 4-1
See NPEP TTP
SOP Section 9.7.2
Continuous zero Air Generator-Model
701
Advanced Pollution Instruments (API), p. 11 -
13
Sect,
p. 5-13
See NPEP TTP
SOP Section 9.7.2
UPS + Power Line Conditioner
Powerware 9125, p.14
Sect. 7, p.45
See NPEP TTP
SOP Section 9.7.2
ONAN 6.8K Auxiliary Generator
Commercial Mobile Power, p.15,16
p. 15-21
See NPEP TTP
SOP Section 9.7.2
Roof Top Air Conditioner
Duo-Therm 579 Series BRISK AIR, p.16,17
p. 9
See NPEP TTP
SOP Section 9.7.2
WELLS CARGO 18' Express Wagon
WELLS CARGO, p. 17-19
p. 12-19
See NPEP TTP
SOP Section 9.7.2
DEXTER AXLE
DEXTER AXLE, p. 19-21
Inside Front Cover.
Also pages 12, 31, 38,
40,44,49, 50,51
See NPEP TTP
SOP Section 9.7.2
Carbon Monoxide Alarm
Atwood p. 21
p. 25,26
See NPEP TTP
SOP Section 9.7.2
B6.3 Corrective Maintenance
Gas Filter Correlation CO Analyzer - TECO
Model 48C8
See NPED TTP SOP Section 9.7.2
Primary Standard UV Photometric Ozone
See NPED TTP SOP Section 9.7.2
8Thermo Environmental Instruments, Inc. Instruction Manual for Model 48C,
Chapter 6, Page 6-1.
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Calibrator - TECO Model 49C-PS 9
Computerized Ambient Monitoring Calibration
Svstem -Environics Series 9100
See NPED TTP SOP Section 9.7.2
B6.4 Initial Cleaning of Presentation Line
The new 150-foot NPAP TTP Presentation Line may arrive with fluid or viscous oil
inside. Before installation of the 150 foot line, clean as follow:
¦ Pour enough alcohol into the line to allow complete washing of the inside of the
line.
¦ Cap both ends and allow the alcohol to stay in the line overnight.
¦ Empty the alcohol.
¦ Shoot ten alcohol-soaked cotton balls through the line with pressurized air to remove any
contaminates.
¦ Shoot ten cotton balls soaked in deionized or ultrapure water.
¦ Run clean dry air through the line for at least an hour.
¦ Install the Presentation Line, generate 500 ppb of O3 and condition for 24 hours.
¦ Perform O3 line loss and verify it is less than 1.5%. If O3 line loss is more than
1.5%, condition the line for 24 hours and repeat O3 line loss.
B7. Instrument Calibration And Frequency
B7.1 Calibration Procedures
The field calibration procedures for audit devices/materials used in the NPAP TTP
program are detailed in the NPAP TTP SOP Compendium. Two copies are contained in
the EPA's Technology Transfer Network (TTN) under NPAP for the TTP program, and
are accessible from the TTN/AMTIC website. One copy is for experienced operators. The
other is outdated, but is used for training of new auditors, as it contains more options and
explanations. The laboratory calibration versions are contained in the various instrument
manuals, and follow the EPA calibration procedures in 40 CFR part 50 Appendices for
9Thermo Environmental Instruments, Inc. Instruction Manual for Model 49C-PS,
Chapter 5, Page 5-1.
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the four pollutants. The procedures are carried out at the beginning of the quarter in
which the audit systems are to be used to do audits.
B7.2 Generation of Audit Sample Materials
SO2, NO and N02, CO, and O3. A range of concentrations of these gasses are generated
from compressed gas cylinders containing a blend of SO2, CO and NO; for Audits of
agency analyzers using a relatively portable device called a calibrator, which includes a
dilution system, containing two or three mass flow controllers, feeding gasses at different
flow rates into a mixing chamber; an O3 generation system, and the ability to combine the
outputs of the dilution system and the O3 generator to generate NO2 from NO and O3, by
the process called gas phase titration (NO2 by GPT),
B7.3 Frequency
The frequency of calibrations and acceptance testing is detailed in the SOPs. See NPAP
TTP SOP compendium, Section 3.
B8. INSPECTION/ACCEPTANCE REQUIREMENTS FOR SUPPLIES AND
CONSUMABLES
To minimize sources of variability within each audit system and between audit systems,
the equipment and materials come from the most reliable vendors for use in audits as it is
equivalent, in most cases, to a blind calibration application though not in a monitoring
application; and meet the critical specifications EPA requires for reactive gasses (see
materials required in 40 CFR Part 58, appendix E, section 9, in particular). The NPAP
TTP workgroup agreed to follow the CARB model and use the same vendor since 2002.
The inspection or acceptance requirements for supplies and consumables are specified in
the purchase documents, which are kept on hand for reference to insure that we get the
comparable items.
B9. DATA ACQUISITION REQUIREMENTS (NON-DIRECT
MEASUREMENTS)
No data used for project implementation are obtained from non-direct measurement
sources, but the agency station operators are asked for the station system measurement
for each delivered concentration. The EPA NPAP auditors do not participate in the
agency measurement process. The NPAP auditors only record agency audit response
measurement data on the NPAP data recording system.
B10. DATA MANAGEMENT
B10.1 Overview of Data Management. A listing of a subset of each agency's
total network of ambient air monitoring sites is drafted each fall, based on the listing from
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the year before. A copy is sent to all ten EPA Regions for confirmation. A list of sites to
be audited in the coming calendar year is developed. A table of STAG funding withholds
is created from this list and sent to the Regions for confirmation or corrections.
NPAP TTP audit gas samples are directly delivered to the agency measurement
system through the agency sampling inlet, or probe.
For the gaseous TTP program, the critical, certified audit standard and approximate
ranges ("levels") of concentration values to be delivered at the agency audit site are
entered into the TTP field data entry software by the TTP audit operator. This person is
either an EPA Regional employee or an EPA Regional contractor.
This step is done at least at the beginning of the audit quarter, and always before leaving
the home base. The TTP field operator performs the audit and enters the TTP and station
data into the TTP data entry software. The software calculates the results and prepares a
report, which is provided to the station operator by the TTP operator before leaving the
station at the end of the audit. The station operator confirms the station data by signature
before the audit operator leaves.
If the Regional auditor is a contractor, the auditor gives the Regional EPA TTP lead, who
may also be the contractor's WAM/TOPO/COR, a copy of the EXCEL workbook and
copies of and /or access to any TTP audit lab logbook, either paper or electronic, or both.
The Regional EPA audit lead either has the workbook sent to OAQPS or has the AQS
transaction page entered into AQS. If sent to OAQPS, the transaction page is entered by
an OAQPS staff member into the TTP Intermediate ACCESS database (See Appendix).
An EPA OAQPS or Regional staff member will have the audit transaction page of the
workbook (or any future equivalent) entered into AQS. If the AQS screening process
finds errors that prevent entry, a list is generated of the type of errors, and the enterer
and/or Regional auditor will have to identify and correct the cause of the error.
B10.2 Data processing and reporting.
Final Closing Date. The current year's audits close on December 31.
B10.3 Unacceptable Results
Audit data results that exceed the EPA determined limits (see below) are
considered unacceptable and follow-up measures are initiated. Currently, the EPA
Regional Office contacts for NPAP are responsible for reviewing the monthly audit
results and corrective action summaries for their Region and following up on potential
problems identified by the audit results to be outside of the acceptance limits. As needed,
follow up calls are made by OAQPS to the Point of Contact for the relevant EPA
Regional Office. The NPAP Manager prints out a list from the NPAP data base of Audit
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Data Exceedance Results. Data issues not resolved after a 30-day period can be identified
and follow-up calls made using this list.
Audit
11 PA Determined Acceptance Limits
S02
Mean Absolute % difference > 15% *
N02
Mean Absolute % difference > 15% *
03
Mean Absolute % difference > 10 % *
CO
Mean Absolute % difference > 15% *
Note: EPA has reduced some of the DQO acceptance limits listed in the QA regulations
in the revision of 40CFR part 58, Appendix A, promulgated in October of2006. EPA has
reviewed the acceptance limits for the NPAP TIP audit results, andfound that the
gaseous acceptance limit for O3 could be reduced to 10% and the warning limit to 7%.
B10.4 Data Reports
As indicated above, the provider of the audit distributes the data results to the
participants. If a contractor is the provider, the contractor distributes the data results to
the audit participants and the results and/or data summaries to the Contract Work
Assignment Manager or Contract Office Representative (COR), who may be the EPA
Regional NPAP Points of Contact. Audit results that are unacceptable are handled as
described in BIO.5 of this plan.
Reports about the individual audit results are provided by the Regions to the agency and
any requests for follow up accompanies the final report. OAQPS asks the Regions to
provide OAQPS with agency follow up responses for audit reports with exceedances of
the NPAP TTP acceptance limits.
Summary tables of the Regional and National Completeness Results for the NPAP TTP
audit program are entered (posted) onto the AMTIC/QA NPAP site of EPA Technology
Transfer Network (TTN).
Summary Audit Exceedance/Follow up tables are in preparation for posting.
A variety of reports can be obtained from AQS, and/or from the related EPA data bases.
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Group C - Assessment/Oversight
Cl. ASSESSMENTS AND RESPONSE ACTIONS
Cl.l Performance Audits
C.l.1.1 NPAP TTP Program
The objective of this activity is to provide an independent assessment of the
quality of the performance of the TTP audit support contractors and any EPA or state
staff who are performing TTP audits. Revised ambient air QA requirements were
promulgated in October 2006, and include some revisions to the ranges of audit levels
required to be performed by ambient air monitoring organizations once a year on each
monitoring site that reports NAAQS gaseous monitoring data to EPA's AQS.
In order to meet the objectives of the NPAP, the NPAP TTP SOPs and audit result,
recording and reporting software have been revised to reflect and accommodate the new
performance audit ranges/levels and versions made to carry out audits during the
development and initial use of the new precursor gas audit system. This system has been
made to audit the NCORE precursor gas analyzers, over the multi-year phase-in period
provided for by the October 2006 regulations.
Regarding QA for the TTP program, the EPA NPAP Manager will, as needed, request
and fund the cost of performance verifications of the Regional NPAP TTP mobile audit
laboratories and personnel transported by audit vehicle, or if necessary, by shipping, from
the Regional base or from an audit trip, from the contractor's facility to the EPA Region
7, or the EPA Region 2 NPAP Verification Laboratories. The NPAP Manager will be
notified by the EPA NPAP Verification Laboratory lead analyst and team leader via e-
mail when the selected audit verification has been started, and will send OAQPS the
verification documentation when the activity has been completed. The difference results
will be compared to the acceptance limits for these comparisons. Unless a problem is
found, the comparisons are usually within 5% of the Verification Laboratory values, with
the possible exception of very low level ranges. These records will be entered into the
NPAP TTP Intermediate ACCESS database, if compatible, or into separate Summary
tables, if not compatible with the ACCESS database. The report to the EPA NPAP
Manager will also contain an assessment of the condition of the mobile audit lab (i.e.,
external appearance).
The TTP mobile laboratory generation, analysis, and delivery system outputs will be
considered acceptable if an agreement of ±5 % is achieved between the NPAP
contractor's determined values and the R7 NPAP Laboratory determined values, for the
current analyzer range of audit levels.
EPA OAQPS has reviewed the available audit data, and then prepared and posted
guidance addressing the need for and providing audit result point difference acceptance
limits (ppb), in addition to and, as appropriate, instead of percent difference acceptance
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limits, for the difference between agency and NPAP audit points. This action responds to
the need to use absolute rather than percent difference acceptance limits for the lowest
precursor gas analyzer ranges and associated levels.
If the results are unacceptable, the NPAP TTP Regional Verification Laboratory will run
the audit a second time to confirm the initial results.
C.l.1.2 Combination of Personnel and Audit System Verification When Possible
The Region 7 Mobile NPAP TTP laboratory and additional Region 7 gas
standards and equipment from the Region 7 Criteria Pollutant NPAP support laboratory
will be used, as resources permit, for hands-on training of personnel and certification of
the Regional Mobile TTP labs, and/or associated equipment or standards. The
requirement for personnel certification or recertification is annual.
Either directly or indirectly, but by no more than one comparison step, the Region 7
support laboratory or the NPAP audit support lab in RTP will independently certify all of
the TTP Regional Mobile laboratories at least once every two years, if possible,
preferably every year. A mobile TTP laboratory, properly certified within six months,
and supported by equipment and standards from an EPA audit support laboratory (Region
7, Region 2, RTP audit support contractor), could be used, in the absence of other
resources, to certify a Regional TTP system not properly recertified in (1-2) years. In
addition, at other times of the year, certification is accomplished by shipping standards,
or whole mobile audit labs , to Region 7, RTP, or Region 2. The frequency of whole TTP
mobile laboratory recertification has been resource dependent, and has allowed most labs
to be certified at least once in two years, on average. A table of these QA checks will be
posted on AMTIC.
C1.2 Systems Audit of NPAP Contractor
At least once a year, as resources allow and frequency of NPAP audits require, a
systems audit will be performed by the Regional EPA NPAP Work Assignment Manager
(WAM)/TOPO/COR and appropriate EPA technical staff member to ensure that the
contractor is adhering to the SOPs that cover conducting audits, entering data,
distributing data, and maintaining files. The systems audit will follow a set format based
on the information contained in NPAP SOPs. The systems audit will be coordinated with
the contractor manager. The results of the systems audit will be forwarded in writing
within five working days to the contractor manager for review. The contractor will
determine the cause of deficiencies, if any, and report to the EPA Manager within five
working days the cause and corrective action taken. EPA can use the annual
certification and recertification training to address the SOP's initial ("New cert") and
subsequent periodic ("recert") updated NPAP TTP training requirement
Cl.2.1 Independent Verification of Audit Support Contractors
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A memorandum of understanding (MOU) with EPA Region 7 provides for
support to the NPAP program through independent verification of the RTP
and Regional audit support contract audit services for the NPAP TTP
program. A systems audit of this program, consistent with the Level of
Effort, should include review of the Region 7 component and whole
system performance audit check, and of the documentation of that
program. As resources allow, the OAQPS will perform and report on an
independent systems audit (TSA) of the Region 7 support to the NPAP
TTP program.
Cl.2.2 TTP Program Independent Verification of Regional Audit Support
Contractors
The Regional or State-based audit staff, including contractors supporting
Regional NPAP TTP audits, and the verification activities they carry out
for the program, should be reviewed in a TSA, annually if possible, by
OAQPS, and/or by the Region 7 MOU audit support staff, and/or by one
of the other experienced Regional TTP auditors or auditor program
managers/trainers.
The program element documentation that should be reviewed includes all
the documentation of QA and QC checks and the associated acceptance
criteria that are listed in the TTP SOP Compendium, section 3:
1) The comparison of the Regional TTP O3 analyzer standard to the Regional SRP, done
each quarter in which audit trips are made and before any trips are made;
2) Line loss tests, performed at the same time each audit quarter as the SRP comparison;
3) Cylinder standard verifications, done annually, if possible;
4) Personnel certifications (initial or re-certifications) done annually;
5) Whole Regional TTP system compared to the Region 7 TTP system, or to one that has
recently been compared to the Region 7 whole system.
Table Cl.2-1 Verification Procedure for Systems Audit
Pollutant
Responsible Party
S02
R7 Laboratory
CO
R7 Laboratory
N02
R7 Laboratory
03
R7 Laboratory
C1.3 Audit of NPAP
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The EPA NPAP Manager will arrange an independent management system
review of the total NPAP program once every two years (in odd years). This could be
done at the same time as the TSA.
CI.4 Corrective Action
When results of the internal quality control checks or the external quality
assurance audits exceed the limits specified in the Quality Assurance Project Plan or in
the individual SOPs, appropriate action will be instituted by the EPA NPAP Manager
and/or the contractor manager for problems that are determined to be in the
implementation of the NPAP TTP Program. For those problems that are determined to be
in the implementation of the auditee's program, Regional Program oversight staff will
prepare and send the audit workbook reports, with a cover letter that may be made from
one of the SOP template versions in section 7 of the TTP SOP Compendium. This cover
letter includes requests for any recommended corrective action.
Note: If the auditor detects a problem or potential problem, at the beginning of an
audit, that audit is to be completed without any corrective action by the Agency staff
After the audit is completed, agency staff may do corrective action and request that the
auditor carry out some additional activities. If the auditor is authorized to do this, that
may be done. However, the initial audit results must stand, and be reported,
communicated, and distributed.
Follow up and corrective action will be documented in the annual summary reports and
/or tables. In an appropriate amount of time after a corrective action plan has been
implemented, a follow up audit should be done. For exceedances, especially of more than
one audit point, and for the higher level range points, a follow up audit should be
performed after completing corrective action required by an initial audit. For corrective
action of questionable results, see BIO.5. Note: Repeat or re-audits at the same site for
the same pollutant will be reported, communicated, and distributed.
CI.5 Reports
OAQPS and Regional NPAP TTP Managers will receive copies of the reports of
all systems and performance audits, MSRs, and follow-up activities, if any.
C2. REPORTS TO MANAGEMENT
The EPA NPAP Manager and the EPA NPAP Contractor will prepare a
comprehensive yearly quality assurance summary report by March 15 for the previous
CY, depending on the size of the program and the resources available. The report will
include the internal quality control reviews and assessments and will incorporate any
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independent (non-contractor) quality audit reports of the latest independently performed
audits on the entire NPAP system.
Table C2-1. List of Reports Requiret
of Contractor
Types of Reports
Frequency
Authors / Recipients
Due Date
Progress Report
Monthly
Contractor/EPA
3/15/20_
QA Summary Report
Annually
Contractor/EPA NPAP Manager
3/15/20_
NPAP Data Summary
Annually
OAQPS / EPA Regional NPAP
Contacts
4-5/20_
AIRS Sites Report
Annually
C ontractor/NP AP
participants/EPA Regions/NPAP
points of contact/NPAP Manager
9/31/20
If requested, the contractor will submit:
Written recommendations to the EPA Manager for the manager to use in
preparing the audit report, and comments on the NPAP Program Manager's draft
report for a TSA, in particular of Region 7 or 2 audit support lab(s), and any
recommendations for modifications to the current Technical Systems Audit
checklist prior to the trip, within one week following the trip.
Three copies of the combined monthly technical and financial progress report on
or before the 15th of each month, following the first complete reporting period of
the contract should be sent to the EPA Administrative Contract Specialist, EPA
Project Officer, and the EPA Work Assignment Manager.
Contractors may be tasked to support the following work by the OAQPS NPAP TTP
National program manager:
An Annual Update of the AQS Sites Report for EPA's National Performance
Audit Program for the year just completed. The contractor shall prepare and
distribute this report to all NPAP participants, EPA Regional NPAP points of
contact, and the EPA NPAP Work Assignment Manager.
An annual NPAP Data Summary Report or Table(s) of all the NPAP data to all
NPAP participants, EPA Regional NPAP points of contact, and the NPAP
Manager by May 31 or each year. The contractor may be asked to support
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presentation of the NPAP Data Summary Report at the National Air
(Management) Meetings.
National schedule for the coming calendar year, incorporating participant requests
with EPA Regional and OAQPS scheduled agency site lists, based on when last
audited and approved criteria queries from AQS.
In addition, the contractor and the EPA Work Assignment Manager shall also
communicate by phone and/or in person on an as needed basis.
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Group D - Data Validation and Usability
Dl. DATA REVIEW, VALIDATION, AND VERIFICATION
REQUIREMENTS
The criteria used to validate the data entered into the initial EXCEL NPAP TTP
data forms (workbooks) is listed in the EPA NPAP TTP SOP Compendium section
addressing data validation. The criteria used to validate data for the NPAP TTP database
(EPA developed, tested, operated and maintained) have been in development along with
the database. Many of the criteria, and guidance for using audit and other QC/QA data
are contained in the data validation templates that are now included in the most recent
update of the 1998 Vol II of the EPA OA Handbook for Ambient Air Monitoring
Measurements, posted on www.epa.gov/ttn/amtic/qa.html
D2. VALIDATION AND VERIFICATION METHODS
The process for the NPAP TTP program is found in the NPAP TTP SOP
Compendium. These SOPs are accessible through the Ambient Air QA menu choices at
the TTN website at http://www.epa.gov/ttn/amtic/QA/ page. Audit support data custody
follows standard QA procedures to ensure all data generated or received can be tracked
and retrieved as needed. This includes the tracking of data results from transport and
delivery of audit system materials and devices to the audit participants; receiving data
results from the participants, or from Regional EPA, contractor lab or field audit support
staff. It also includes the validation of data results, and storing results in the EPA NPAP
and AQS data bases. The TTP audit result reports are, in part, checked automatically (for
example, for non-existing AQS codes) when the auditors enter the Audit Workbook's
AQS transaction Worksheet into AQSQA.
Records are also kept on acceptance testing and initial and recertification of all the
Regional and RTP audit system materials and calibration of audit devices. These records
allow for the tracking of an audit system's materials and devices from their acceptance
testing or calibration through to the storage of the audit results in the data base.
Additional details on tracking audit results data, acceptance test data and calibration
results are contained in the NPAP TTP SOP Compendiums posted on AMTIC.
Verification of participant's data occurs during data entry. The data in the reporting data
systems are checked for completeness and that they are in the proper units. However, data
validation, which is a formally defined process, involves checking the accuracy of the
data entry and is conducted following the sections in the NPAP TTP SOP Compendium
that address audit work book pre-audit preparation (section 2 and 3), use (section 5 & 6)
and audit data validation (section 7 and 10).
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D3. RECONCILIATION WITH USER REQUIREMENTS
The contractor or EPA field and/or lab audit staff will examine all data prior to
submitting them to EPA data reviewers and managers to ensure that the requirements
defined are met. Procedures in the section in the NPAP TTP SOP Compendium that
address data validation will be followed. The EPA QA Work Group has created a data
validation template for each NAAQS criteria pollutant. They have been put into the QA
Handbook revision that is on AMTIC at http://www.epa.gov/ttn/amtic/QA
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APPENDIX A
TABLE OF CONTENTS
THROUGH-THE-PROBE (TTP) PROCEDURES FOR EPA'S NATIONAL
PERFORMANCE EVALUATION (PE) PROGRAM (NPEP) FOR GASEOUS
CRITERIA POLLUTANTS
SECTION SOP Number
1.0 Overview of Performance Evaluation (PE) Field Activities NPEP TTP
1.01
PE PROCEDURES
2.0 Planning and Preparing for Site Visits
2.1. Equipment Inventory and Storage NPEP TTP
2.01
2.2. Communications NPEP TTP
2.02
2.3 Site Visit Preparation NPEP TTP
2.03
PRE/POST PE PROCEDURES
NOTE: From Sections 3 to 10, the Procedure Sub-Section heading numbers and
titles are given below the SOP Section title.
3.0 Calibration Checks (Verifications) and Procedures NPEP TTP
3.01
3.7.0 PROCEDURE
3.7.1. Quarterly "OZONE LINE LOSS" Start-up Procedure
3.7.2. Quarterly "OZONE LINE LOSS" Test
3.7.3. Quarterly Ozone Instrument and Semi-Annual Gas
Cylinder Re-certification
3.7.4. Annual (to Quarterly, if needed, & Resources)
Cross-check with Standards or Mobile Laboratory
3.7.5. Annual Recertification Procedures
4.0 Mobile Lab Start-up Procedures NPEP TTP
4.01
4.7.0 PROCEDURE
4.7.1. Mobile PE Lab Exterior
4.7.2 Mobile PE Lab Interior
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SECTION SOP Number
5.0 Site Set-Up NPEP TTP
5.01
5.7.0 PROCEDURE
5.7.1. Initial Site Set-up
5.7.2. Mobile PE O3 Instrument Operational Check
5.7.3. Final Site Set-up
6.0 Through-the-Probe (TTP) or Back-Of-the-Analyzer NPEP TTP
6.01
(BOA-If necessary) Performance Evaluation (PE)
6.7.0 PROCEDURE
6.7.1. Mobile Lab/Station Data Retrieval/Recording
6.7.2. O3 PE Procedure
6.7.3. CO Analyzer Pre-Calibration Procedure
6.7.4. CO, S02, NO/NOxPE Procedure
6.7.5. Carbon Monoxide Analyzer Post-Calibration Procedure
CO, SO2, NO2 PE Procedure
6.7.6. Calculations of Converter Efficiency/True Pollutant
Concentrations
6.7.7. PE Failures/Troubleshooting
Alternative Procedure for 7.3 - CO Pre Calibration
Alternative Procedure for 7.5 - CO Post Calibration
7.0 Post PE Results Procedures NPEP TTP
7.01
7.7.0 PROCEDURE
7.7.1. Preliminary PE Data Results Report
7.7.2. Final PE Data and Recommended Corrective
Action Report
.0 Shut-down Procedures NPEP TTP
8.01
8.7.0 PROCEDURE
8.7.1. Interior
8.7.2. Exterior
9.0 Maintenance Checks and Procedures NPEP TTP-
9.01
9.7.0 PROCEDURE
9.7.1. Spare Parts
9.7.2. Preventive Maintenance and Schedules
9.7.3. Limited Corrective Maintenance
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SECTION SOP Number
10.0 Quality Assurance/Quality Control NPEP TTP
10.0
10.7.0 PROCEDURE
10.7.1. Completeness
10.7.2. Manifold Delivery System
10.7.3. Field QC Checks
10.7.4. Accuracy for O3, CO, SO2, NO/NO2
10.7.5. Standards Recertification
10.7.6. Collocated Accuracy
10.7.7. Data Validation Process
10.7.8. Annual Bi-Annual Reports
11.0 Information Retention NPEP TTP-11.01
11.2.0 PROCEDURE
11.2.1. Information Included in the Reporting Package
11.2.2 .Reports to Management
APPENDICES
D. Glossary
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APPENDIX B
QA Project Plan For EPA Region 7 Verification Lab
Support for NPAP
Will be posted on AMTIC; until then, request from EPA NPAP Manager.
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Appendix C
NPAP TTP QA/QC Summary Tables:
% of Complete TTP PE out of 100% in 5 Years, and Most Recent Year
Regional Exceedance Summaries for 5 years and Most Recent Year
NPAP TTP Whole System Certification 2004 - 2014
(Table, as of 2/10/2014)
Blended Gas Cylinder Certifications
Ozone Analyzer Certifications
Annual NPAP TTP Certification/Recertification Training, Remote and
Hands-on Sessions:
Power Point SOP slides
Powerpoint Critical Highlights
Hands-On Checklists:
a) Ozone, b) Blended gas and c) "Everything Else"
Appendix D
NPAP SOP-Data Validation for Data bases of the National Performance
Audit Program:
Procedure for Checking the Data in the Excel Workbook:
1) Check to be sure all of the following information is included or
selected on the information (1st) page of the workbook;
a) AQS site ID (for correctness: i.e., missing digits, too many 0s,
remove dashes if included)
b) date of audit
c) NPAP TTP or Certification Audit
d) Method Code/POC
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2) Check AQS transactions page (last page) for data
Directions for Entering Audit Data into the Intermediate TTP Database
Intermediate Access Data Base:
1.0) Processes (Audit and Verification results)
1.1) Load New Data via Spreadsheets to AQS Staging Area
1.2) Enter Staging Area Data by Hand
1.3 Process Staging Area Data
1.4) Edit Cylinder Assays
1.5) Edit Processed Audits
2) Report (Query)
2.1) Audit Details —~ Query by Region; view 1 page at a time
2.2) Audit Summaries —~ (Query by Region; Summary of Regions
audits)
2.3) Failed Audits Report —~ (Query by Date)
2.4) Certification Report —~ (Query by date, beginning and ending
date)
2.5 Tank Certifications —~ (Query by beginning and ending date)
Procedure to Follow for Checking Data in the Excel Workbook:
1) Check to be sure all of the info is included or selected on the info (1st) page of the
workbook
2) Always check the AQS transaction page for data and concentration separators,
and that they are in right places.
Appendix E:
SRP: SOP Table of Contents
1.0 Introduction
1.1 Definitions
1.2 O3 Photometers Classified
1.3 EPA's SRP Network
2.0 NIST Standard Reference Photometer (SRP) History
2.1 Development of the SRP
2.2 Hardware Upgrades
2.3 Software Upgrades
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3.0 Theory of Photometric Measurement
3.1 Physical Basis of the Photometry Equation
3.2 Sources of Error in the Photometry Principle
3.3 International Photometric Measurements for O3
4.0 SRP-07 Initial Setup
4.1 Receiving and Setting Up SRP-07
4.2 Connecting the Electronic Signal Cables
4.3 Pneumatics Connection Setup
5.0 SRP-07 Standard Operating Procedure
5.1 Procedure and SRP Control Software
5.1.1
QA/QC Checks
5.1.2
Qualifications
5.1.3
Verification
5.1.4
Re-verification
5.1.5
Audit Level Comparisons
5.1.6
Calibrations for Scientific Research
5.1.7
Zero-Span Check
5.1.8
Running Multiple Guests at One Time
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Appendix F:
NPAP TTP Audit EXCEL Workbook
Link: http://www.epa.gov/ttn/amtic/QA/
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Appendix G:
Excerpt from the TTP SOP, Section 6
Link: http://www.epa.gov/ttn/amtic/QA/
TABLE OF CONTENTS OF THE TTP SOP COMPENDIUM
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Table of Contents
Page
1. Scope and Applicability 3
2. Summary of Method 3
3. Definitions 4
4. Personnel Qualifications 4
5. Cautions 4
6. Equipment and Supplies 4
7. Procedure
7.1. Mobile Lab/Station Data Retrieval /Recording 5
7.2. Ozone PE Procedure 7
7.3. Carbon Monoxide Analyzer Pre-Calibration Procedure 10
7.4. CO, S02, NO/NOx PE Procedure 15
7.5. Carbon Monoxide Analyzer Post-Calibration Procedure 22
7.6 Calculations of Converter Efficiency/True Pollutant Concentrations 23
7.7 PE Failures/Troubleshooting 26
Alternative Procedure for 7.3 - CO Pre Calibration 28
Alternative Procedure for 7.5 - CO Post Calibration 32
Table of Tables
Table 6.1- Audit Levels 25
Table 6.2 - Multi Blend Audit Points Pollutant Concentrations 25
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