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Quality Assurance Project Plan for the
Photochemical Assessment Monitoring Stations
(PAMS) Required Site Network for Speciated
Volatile Organic Compounds, Carbonyls, and
Meteorological Parameters Including Mixing
Layer Height - Revision 1
Model QAPP
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Quality Assurance Project Plan for the Photochemical Assessment Monitoring Stations (PAMS)
Required Site Network for Speciated Volatile Organic Compounds, Carbonyls, and
Meteorological Parameters Including Mixing Layer Height - Revision 1
By:
Ningxin Wang, PhD
Crystal McClure, PhD
Jennifer DeWinter
Sonoma Technology, Inc.
1450 N. McDowell Blvd.
Petaluma, CA 94954
Prepared for:
OAQPS/AQAD
GSA Contract No. 47QRAA18D00D1
Work Order No. 3-10
Task Order No. 68HERH20F0357
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Air Quality Assessment Division
Research Triangle Park, NC
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Disclaimer
Mention of commercial products or trade names will not be interpreted as endorsement. Some
types of instruments currently in use may be described in text or in example figures or tables.
Sometimes these products are given as a typical and perhaps well-known example of the general
class of instruments. Other instruments in the class are available and may be fully acceptable.
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Revision History
Revision
Number
Theme
Description of Change(s)
Section(s)/Table(s)
1
General
Updated dates, links, and action items;
addressed inconsistencies; added flexibility
and clarifications where applicable;
removed outdated background information
about EPA's PAMS re-engineering plans
Throughout
1
Annual
Milestones
Updated to June 1 except system review
and revisions
A6.3
1
TSA
Frequency
Updated to every 4 years
CI.1.2
1
Ceilometers
Removed hard target test and bias
requirement
A7.3, A7.3.4,
B5.1.4
1
no2
Updated Gas Phase Titration (GPT) to be
the only method for generating known
concentrations of NO2
A6.3, B7.1.3, Cl.l
1
Auto-GC
CAS-specific: noted that gases should not
be humidified, MDLs cannot be calculated,
how to calculate TNMOC/PAMSHC,
guidance on ICAL. General: identified
more poor integration compounds, added
toluene as optional C6-C12 calibration
parameter, changed ICAL intercept/slope
criteria, added guidance on CCV, SYSB,
and SSCVs
B5.1, B7.1, D2.2,
Table A6-2,
Table B5-2
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Foreword
This document is the Quality Assurance Project Plan (QAPP) for monitoring operations for the
Photochemical Assessment Monitoring Stations (PAMS) Required Site Network for the parameters
of speciated volatile organic compounds (VOCs), carbonyls, and meteorological measurements
including mixing layer height (MLH). Any analysis performed by national contract laboratories will
be covered in contract QAPPs approved by the Environmental Protection Agency (EPA) and will
not need to be covered by the monitoring agency.
EPA developed this national QAPP to ease the burden on state and local air monitoring agencies
(see note below) in developing a QAPP for their PAMS Required Site Program as well as to
improve data quality and consistency in the PAMS data. This QAPP was developed in accordance
with the EPA quality assurance (QA) requirements described in EPA OA R-5, EPA Requirements
for Quality Assurance Project Plans and the guidance in the accompanying document EPA OA/G-5,
Guidance for Quality Assurance Project Plans.
Monitoring agencies may use this model QAPP or develop their own QAPP. If using this model
QAPP, monitoring agencies are expected to follow the QAPP as written, and only add pertinent
details where indicated in yellow highlight. Regardless of whether the model QAPP is used, or a
monitoring agency develops their own QAPP, the completed QAPP must be submitted to the
appropriate EPA Regional Office for review and approval.
Monitoring of the criteria pollutants O3 and NO2 for use in National Ambient Air Quality Standards
(NAAQS) attainment decisions will already be occurring at the PAMS Required Site or at other
sites operated by the responsible monitoring agency or primary quality assurance organization
(PQAO); as such, approved QAPPs governing required monitoring activities will already be
available. As the QA requirements for these criteria pollutants are described elsewhere, the scope of
this QAPP does not include QA requirements for the measurement of ozone (O3) nor the nitrogen
oxides NO, NOx, and NOy. NO and NOy are measured by monitoring agencies operating National
Core (NCore) sites and will also be covered by an existing QAPP. As true NO2 is a new parameter
specific to PAMS (though some monitoring agencies have replaced or opted for true NO2 analyzers
over NOx analyzers), QA requirements for measurement of true NO2 are covered for monitoring
agencies that do not have authority to modify the criteria gas pollutant QAPP to include true NO2
monitoring at the PAMS monitoring sites. These aspects are detailed in Monitoring
agencies that cannot refer to an existing QAPP for true NO2 measurements will adopt the QA
aspects of NO2 monitoring listed; however, monitoring agencies which have addressed QA
requirements for true NO2 monitoring in another QAPP (e.g., a QAPP governing criteria pollutant
monitoring) can satisfy the NO2 monitoring QA requirements by referring to their specific QAPP or
QAPPs in those sections highlighted red. Mention or inclusion of O3 and oxides of nitrogen in this
QAPP is in a manner that will not be in conflict with current EPA requirements or the monitoring
organizations' approved QAPPs. EPA Regional staff will ensure the QA requirements for true NO2
measurements are sufficiently covered in the PAMS monitoring QAPP or in the criteria pollutant
monitoring QAPP included by reference.
VOCs data collection for this QAPP focuses on the use of field automated instruments and the
companion technical assistance document provides details on this instrumentation. Although the
monitoring agency may submit a waiver for VOC canister sampling and laboratory analysis, this
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national QAPP will not cover those procedures and monitoring agencies will be required to submit
a QAPP to cover VOC canister sampling and analysis.
This QAPP covers the meteorological measurements made at the PAMS site. Although a waiver
is available for using meteorological data from nearby meteorology sites, this QAPP does not
attempt to address QA activities for such alternate meteorology measurement data.
As explained in the table below, it is important to differentiate between the terms shall/must,
should, and may in regulations and guidance documents.
Distinct Terms in this QAPP
Term
Description
Shall/Must
Used when the element is required.
Should
Used when the element is recommended.
• This term is used when extensive experience in monitoring
provides a recommended procedure that would help establish or
improve the quality of data or a procedure. The process that
includes the term is not required, but if not followed, an alternate
procedure should be developed that meets the intent of the
guidance.
May
Used when the element is optional or discretionary.
• The term also indicates that what is suggested may improve data
quality, that it is important to consider, but it is not as important as
those that have been suggested using the term "should."
NOTE: The Ambient Air Monitoring program uses the term "Monitoring Agency" and "Primary
Quality Assurance Organization" (PQAO) in many of its regulations and guidance documents. In
many cases the monitoring agency and the PQAO are the same entity; in a few cases, a PQAO may
represent a number of monitoring agencies. This document uses the term "monitoring agency"
throughout but is meant to cover both situations.
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A PROJECT MANAGEMENT
Al Title and Approval
EPA QAPP Category II
By signing below, the Environmental Protection Agency (EPA) Office of Air Quality Planning
and Standards (OAQPS) and EPA Regional technical and quality assurance (QA) leads for the
Photochemical Assessment Monitoring Stations (PAMS) program have found this quality
assurance project plan (QAPP) to be directly adoptable by any monitoring organization for the
purpose of conducting monitoring for the PAMS Required Site Network Program once the
monitoring organization specific details have been added. Signature by an EPA Regional
representative, such as a Regional Administrator, QA manager, air monitoring program manager,
or their delegated designee, signifies concurrence with all aspects of this QAPP.
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Title: Quality Assurance Project Plan for the Photochemical Assessment Monitoring
Stations (PAMS) Required Site Network for Speciated Volatile Organic Compounds,
Carbonyls, and Meteorological Parameters Including Mixing Layer Height - Revision 1
The attached QAPP for the EPA PAMS Required Site Network is hereby approved and commits
the participants of the program to follow the elements described within.
PQAO
Program
Manager
PQAO QA
Manager
EPA
Regional
Office
Other
Signature:
Name:
Signature:
Name:
Signature:
Name:
Signature:
Name:
Date:
Date:
Date:
Date:
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Al.l EPA Regional Approval of Monitoring Agency QAPP
The QA policies in EPA Order 5360.1 A2 require agencies that accept federal grant funding for
their air monitoring programs to have a QA program with certain elements including quality
management plans (QMPs), QAPPs, and the identification of a QA management function. To
reduce the burden on state, local, or tribal (SLT) monitoring agencies, EPA has produced this
National QAPP for PAMS Required Site Network monitoring agencies as a template and
requires that SLT monitoring agencies review and either:
(1) Revise this QAPP where indicated to reflect SLT policies and procedures; or
(2) Develop their own QAPP to be consistent with the procedures outlined here.
The appropriate EPA Region must approve the resulting monitoring agency QAPP for
conformance to the requirements of this national QAPP. SLT monitoring agencies will submit a
list detailing the deviations and departures from this QAPP to the Region and supply supporting
documentation to demonstrate that the quality aspects of this QAPP remain satisfied.
SLT monitoring agencies will complete the form in Appendix A which indicates whether the
SLT monitoring agency adopts this national QAPP (and has included the requested additional
detail, as required) or develops its own QAPP. The monitoring agency must submit the
completed form to its EPA Region with its PAMS QAPP. The form in Appendix A can also be
used for those monitoring agencies that have been delegated QAPP self-approval authority by
the EPA Region.
A1.2 Corrections to the National QAPP or Supporting SOPs
The PAMS Required Site monitoring agency staff and their supervisors are responsible for
implementing the applicable approved monitoring agency QAPPs and standard operating
procedures (SOPs) and are responsible for the quality of the data. If changes or corrections are
suggested for the approved national QAPP or supporting national SOPs, PAMS monitoring
agency personnel will notify the Regional Representative who may notify the PAMS QA Lead at
OAQPS. The PAMS QA Lead at OAQPS will review proposed changes with the EPA Regional
PAMS Leads and determine if revisions to the national QAPP and/or national SOPs are
appropriate. OAQPS will notify the PAMS monitoring agency site leads through a quality
bulletin detailing amendment to the document(s). This quality bulletin (refer to example in
Appendix B) will be distributed to the PAMS Required Site stakeholder e-mail list maintained by
EPA OAQPS. When appropriate, new versions of the document(s) will be provided to the PAMS
Required Site Network participants with instructions to discard the previous version.
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Acknowledgments
This QAPP revision is the product of the combined efforts of EPA's OAQPS; EPA Regional
offices; and SLT monitoring agencies. The following individuals are acknowledged for their
contributions:
EPA Regional PAMS Leads
Region:
1
Alysha Murphy and Tyler Way
2
Gavin Lau
3
Meighan Long
4
Darren Palmer
5
Jacqueline Nwia
6
David Anderson
7
Stephen Krabbe
8
Ethan Brown
9
Randall Chang
10
Will Wallace
Office of Air Quality Planning and Standards
Corey Mocka
Trisha Curran
Kevin Cavender
Sonoma Technology, Inc., under EPA Task Order 68HERH20F0357, Work Order 3-10
Ningxin Wang, PhD
Crystal McClure, PhD
Jennifer DeWinter
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Table of Contents
Disclaimer 4
Revision History 5
Foreword 6
A PROJECT MANAGEMENT 9
A1 Title and Approval 9
Al.l EPA Regional Approval of Monitoring Agency QAPP 11
A1.2 Corrections to the National QAPP or Supporting SOPs 11
A2 Acronyms and Abbreviations 18
A3 Distribution List 21
A4 Project/Task Organization 21
A4.1 EPA OAQPS 22
A4.2 EPA Regional Offices 23
A4.3 SLT PAMS Required Site Monitoring Agencies 24
A4.4 Analytical Support Laboratory 25
A4.5 PAMS Support Contractor 26
A4.6 PAMS Required Site Workgroup 26
A5 Problem Definition/Background 27
A5.1 Monitoring Agency PAMS Required Site(s) 29
A6 Project Task/Description 30
A6.1 Required Measurements 30
A6.2 Personnel to Accomplish Tasks 31
A6.3 Schedule for PAMS Required Site Activity Milestones 36
A6.4 Summary of Assessment Techniques 38
A7 Quality Objectives and Criteria 38
A7.1 Data Quality Objectives 38
A7.2 Data Quality Indicators 39
A7.3 Measurement Quality Objectives 39
A7.3.1 Representativeness 41
A7.3.1.1 Temporal Representativeness 41
A7.3.1.2 Spatial Representativeness - Chemical Measurement Probe Siting Criteria ...42
A7.3.1.3 Spatial Representativeness - Meteorology 43
A7.3.2 Completeness 45
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A7.3.3 Precision 45
A7.3.4 Bias 47
A7.3.5 Sensitivity 50
A8 Special Training/Certifications 51
A8.1 Site Operator Training 51
A8.2 Auditor Training 53
A8.3 Analytical Support Laboratory Analyst Training 53
A9 Documentation and Records 54
A9.1 Recording of Data 56
A9.1.1 Paper Records 56
A9.1.2 Electronic Records 56
A9.2 Chain-of-Custody Records 56
A9.3 QA/QC Records 57
A9.4 Records Archival and Retention 57
A9.5 Sample Retention 57
B DATA GENERATION AND ACQUISITION 59
B1 Sampling Process Design (Experimental Design) 59
Bl.l Sample Collection Schedule 60
B 1.1.1 Carbonyls by TO-11A 60
Bl.l.2 Speciated VOCs by Auto-GC 61
B1.1.3 Continuous Measurement Methods 62
Bl.1.3.1 True NO 62
B1.1.3.2 Meteorological Instruments 62
B1.2 Quality Control Measurements 62
B2 Sampling and Measurement Methods 63
B2.1 Chemical Parameters 63
B2.1.1 Carbonyls by TO-11A 64
B2.1.2 Speciated VOCs by Auto-GC 64
B2.1.3 True NO2 by CAPS or Photolytic Conversion to NO with
Chemiluminescent Detection 66
B2.2 Meteorology 66
B3 Sample Handling and Custody 67
B3.1 Carbonyls by TO-11A 67
B3.1.1 Chain of Custody 68
B4 Analytical Methods 69
B4.1 Carbonyls by TO-11A 69
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B4.2 Speciated VOCs by Auto-GC 69
B4.3 True NOi by FEM 69
B5 Quality Control 70
B5.1 Quality Control for Field Activities 70
B5.1.1 Quality Control for Carbonyls Sample Collection 70
B5.1.2 Quality Control for Speciated VOCs Collection and Analysis 72
B5.1.3 Quality Control for True NO2 Analysis 75
B5.1.4 Quality Control for Meteorology 77
B5.2 Quality Control for Laboratory Activities 78
B6 Instrument/Equipment Acceptance, Testing, Inspection, and Maintenance 81
B6.1 Instrument Acquisition for New Required PAMS Sites 82
B6.2 Instrument Acceptance Testing and Shakedown 82
B6.2.1 Initial Instrument Acceptance and Shakedown 82
B6.2.2 Annual Instrument Shakedown 83
B6.3 Equipment Inspections 83
B6.4 Instrument Maintenance 83
B7 Instrument/Equipment Calibration and Frequency 85
B7.1 Instrument Calibration 86
B7.1.1 Carbonyls Instrument Calibration 86
B7.1.1.1 Carbonyls Field Sampling Instrument Calibration and Calibration Verification
86
B7.1.1.2 Carbonyls Laboratory Instrument Calibration and Calibration Verification.... 86
B7.1.2 Calibration and Calibration Verification for Speciated VOCs by Auto-GC
86
B7.1.3 Calibration and Calibration Verification for True NO2 Analyzers 87
B7.1.4 Calibration and Calibration Verification for Meteorology Instruments ... 87
B7.2 Calibration Support Equipment 87
B8 Inspection/Acceptance of Supplies and Consumables 89
B8.1 Acceptance of Standard Materials 90
B8.2 Acceptance of Sampling Media - Carbonyls 91
B9 Non-direct Measurements 91
B9.1 Historical PAMS Data and Supplemental Measurement Data from Other
Monitoring Sites 92
B10 Data Management 92
C ASSESSMENT AND OVERSIGHT 93
CI Assessments and Response Actions 93
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Cl.l Types of Assessments 93
C1.1.1 Instalment Performance Audit 95
C1.1.1.1 Carbonyls Instrument Performance Audit 95
C1.1.1.2 Meteorology Instrument Performance Audits 95
CI. 1.2 Technical Systems Audit 96
C1.1.2.1 Shakedown Audits 97
C1.1.3 Audits of Data Quality 97
CI.1.4 Proficiency Testing 98
C1.1.5 Performance Evaluation 98
C1.2 Corrective Actions 99
C2 Reports to Management 100
C2.1 Assessment Reports 100
D DATA VALIDATION AND USABILITY 101
D1 Data Review, Verification, and Validation Requirements 101
Dl.l Data Verification and Validation Responsibilities 101
D1.2 Data Verification 102
Dl.2.1 Routine (Self) Review 102
Dl.2.2 Technical (Peer) Review 104
D1.3 Data Validation 105
D1.4 Reporting of Validated Data to AQS 107
D1.4.1 Reporting Values Below Method Detection Limits (Carbonyls and
Speciated VOCs) 107
D2 Data Verification and Validation Methods 108
D2.1 Data Verification Methods 108
D2.2 Data Validation Methods 108
D2.2.1 Data Visualization Methods 109
D2.2.2 Statistical Methods 109
D2.2.3 Examination of Supporting Data 109
D2.2.4 Treatment of Deviations from Requirements Ill
D2.2.4.1 Identifying Compromised Data in AQS Ill
D2.2.4.2 Corrective Action Process 114
D2.2.4.3 Notification of EPA or Other Stakeholders 114
D3 Reconciliation with User Requirements 115
D3.1 Reconciling Results with DQOs 115
D3.2 Interim Corrective Actions 115
REFERENCES 117
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Tables
Table A5-1. Required Sites in CBSAs with a Population Greater than 1,000,000 28
Table A5-2. PAMS Required Sites Covered by this QAPP 30
Table A6-1. Measurements and Associated Instruments for PAMS Required Sites 31
Table A6-2. PAMS Required Site Activity Annual Milestones 36
Table A7-1. PAMS DQIs and Associated MQOs 40
Table A7-2. Minimum Monitor Separation Distance from Roadways 43
Table A9-1. Pertinent Documents and Records for PAMS Required Site(s) 54
Table B1-1. PAMS Required Site Sampling Schedule by Parameter 60
Table B1-2. Carbonyls Sampling Schedule 61
Table B2-1. Priority and Optional PAMS Required Site Chemical Parameters 64
Table B2-2. Meteorological Parameters 66
Table B5-1. Carbonyls Field Quality Control Parameters 71
Table B5-2. Speciated VOCs Field Quality Control Parameters 73
Table B5-3. True NO2 Quality Control Parameters 76
Table B5-4. Quality Control Parameters for Meteorology Measurements 78
Table B5-5. Carbonyls Laboratory Quality Control Parameters 79
Table B6-1. Routine Instrument Maintenance Activities 84
Table B7-1. Calibration Requirements for Critical Support Instruments 88
Table B8-1. DNPH Cartridge Lot Blank Acceptance Criteria 91
Table Cl-1. PAMS Required Site Assessments 94
Table Dl-1. Routine Review Activities and Associated Frequency 103
Table Dl-2. Dataset Durations (Sizes) for Validation 107
Table D2-1. AQS Qualifiers and Null Codes for PAMS 112
Figures
Figure A4-1. PAMS Required Site Network Communication and Responsibility Structure 22
Appendices
APPENDIX A: SLT MONITORING AGENCY QAPP APPROVAL
APPENDIX B: EXAMPLE QUALITY BULLETIN
APPENDIX C: EXAMPLE CHAIN-OF-CUSTODY FORM
APPENDIX D: EXAMPLE STAFF PROFICIENCY TRAINING FORM
APPENDIX E: EXAMPLE SITE VISIT CHECKLIST
APPENDIX F: GUIDANCE FOR PAMS MONITORING AGENCIES TO INCORPORATE
PAMS REQUIREMENTS INTO ANNUAL MONITORING NETWORK
PLANS
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A2 Acronyms and Abbreviations
ADQ audit of data quality
AGL above ground level
AMNP annual monitoring network plan
AMTIC Ambient Monitoring Technology Information Center
API Advanced Pollution Instruments
AQAD Air Quality Assessment Division
AQS Air Quality System
ASL analytical support laboratory
auto-GC automatic gas chromatograph
C carbon
C2 compounds containing two carbon atoms
Ce compounds containing six carbon atoms
C12 compounds containing twelve carbon atoms
CAA Clean Air Act
CAP corrective action plan
CAPS cavity attenuated phase shift
CAR corrective action report
CAS Consolidated Analytical Systems
CBSA core-based statistical area
CCV continuing calibration verification standard
CDOC continuing demonstration of capability
CDS chromatography data system
CFR Code of Federal Regulations
COA certificate of analysis
COC chain of custody
CRM certified reference material
CTS collocated transfer standard
CV coefficient of variation
DART Data Analysis and Reporting Tool
DAS data acquisition system
DDC dynamic dilution calibrator
DNPH 2,4-dinitrophenylhydrazine
DQA data quality assessment
DQI data quality indicator
DQO data quality objective
DST daylight savings time
EMP enhanced monitoring plan
EPA Unites States Environmental Protection Agency
ESMB extraction solvent method blank
FEM Federal Equivalent Method
FEP fluorinated ethylene propylene
FID flame ionization detector
FRM Federal Reference Method
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GC
gas chromatograph
GPT
gas phase titration
HAP
hazardous air pollutant
HPLC
high performance liquid chromatograph
ICAL
initial calibration
IDL
instrument detection limit
I DOC
initial demonstration of capability
IP
implementation plan
IPA
instrument performance audit
ISO
International Organization for Standardization
LCS
laboratory control sample
LCSD
laboratory control sample duplicate
LIMS
laboratory information management system
m
meter(s)
MB
method blank
MDL
method detection limit
MFC
mass flow controller
min
minute(s)
MLH
mixing layer height
mm
millimeter(s)
MQO
measurement quality objective
MPV
multi-point verification
MS
monitoring staff
Hg
microgram(s)
NA
nonattainment area
NAAQS
national ambient air quality standard
NATTS
National Air Toxics Trends Stations
NCore
National Core
ng
nanogram(s)
NIST
National Institute of Standards and Technology
nm
nanometer(s)
NO
nitrogen oxide
no2
nitrogen dioxide
NOy
total reactive nitrogen
NPAP
National Performance Audit Program
NWS
National Weather Service
03
ozone molecule
OAQPS
Office of Air Quality Planning and Standards
OTR
Ozone Transport Region
PAMS
photochemical assessment monitoring station
PAMSHC
PAMS hydrocarbons
PBLH
planet boundary layer height
PDMS
polydimethylsiloxane
PE
performance evaluation
PFA
perfluoroalkoxy
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PGVP
Protocol Gas Verification Program
PLOT
porous layer open tubular
PM
particulate matter
ppb
part(s) per billion
ppbC
part(s) per billion carbon
ppm
part(s) per million
PQAO
primary quality assurance organization
PT
proficiency test
PTFE
polytetrafluoroethylene
QA
quality assurance
QAU
quality assurance unit
QAIP
quality assurance implementation plan
QAPP
quality assurance project plan
QC
quality control
QMP
quality management plan
QS
quality system
RF
response factor
RH
relative humidity
RPD
relative percent difference
RSD
relative standard deviation
RT
retention time
RTS
retention time standard
SB
solvent blank or system blank
SLAMS
state and local air monitoring stations
SLT
state, local, or tribal (monitoring organization)
SOAP
Secondary Organic Aerosols Precursor
SOP
standard operating procedure
SRM
standard reference material
sscv
secondary source calibration verification
SYSB
system blank
TAD
technical assistance document
TNMOC
total non-methane organic carbon
TOF
time-of-flight
TSA
technical systems audit
TTP
through-the-prob e
UHPLC
ultra-high performance liquid chromatograph
UV
ultraviolet
VOC
volatile organic compound
VSL
Van Swinden Laboratorium
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A3 Distribution List
An electronic version of this QAPP is available on EPA's Ambient Monitoring Technology
Information Center (AMTIC) PAMS website at the following link:
https://www.epa.gov/amtic/photochemical-assessment-monitoring-stations-pams
OAQPS will distribute this QAPP via e-mail to those individuals on its PAMS Required Site
Network e-mail contact list. The EPA PAMS Regional Leads will be responsible for ensuring
that this QAPP is distributed to the SLT monitoring agency Program Manager or Director of
each PAMS Required Network field site. SLT monitoring agencies will be responsible for
distributing this QAPP to analytical support laboratories (ASLs) conducting carbonyls and/or
speciated volatile organic compound (VOC) analysis, as appropriate. The EPA PAMS Regional
Leads will also provide a copy of this QAPP to their Regional QA Staff.
Required Distribution
• EPA PAMS Regional Leads
• SLT monitoring agency Program Manager or Director
• PAMS Required Site Network monitoring leads
• EPA Regional QA staff
• PAMS Required Site Network analytical support laboratories
Monitoring agencies will include the distribution list for their PAMS QAPP.
A4 Project/Task Organization
The PAMS Required Site Network will measure ozone, its precursors, and meteorological
variables, and will do so, unless otherwise authorized by EPA OAQPS. State and local
monitoring agencies are required to collect and report PAMS measurements at each National
Core (NCore) site that is located in a core-based statistical area (CBSA) with a population of
1 million or more based on the latest available census figures. SLT monitoring agencies are
required to collect and report PAMS measurements listed in 40 Code of Federal Regulations
(CFR) Part 58 Appendix D Section 5(b). These required measurements are detailed in Section
A6.1 of this QAPP.
Organizations essential to the execution of the PAMS Required Site monitoring program include
EPA OAQPS, EPA Regional Offices, SLT monitoring agencies and their ASL, and the PAMS
Support Contractor. The PAMS Required Site Network communication and responsibility
structure is depicted in Figure A4-1.
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r ^
EPA OAQPS
• Develops National Quality System
• Allocates CAA Section 105 grant
monies to Regions
• Provides training materials & opportunities
• Develops guidance documents
y* Assists in equipment acquisition l
.
EPA Region
• Administers Quality System
• Approves SLT monitoring agency quality system
• Conducts audits of PAMS Required Sites and
analytical support laboratories
^ -L
/- -\
SLT Monitoring Agency
• Acquires monitoring equipment
• Provides staff resources to conduct monitoring
• Calibrates and operates monitoring equipment
• Validates and reports monitoring data
V
X
%
. 1
PAMS QA Support Contractor
• Assists developing Quality System documents
• Provides audit support for Regions without
audit capability
• Facilitates communication with the Network
SLT monitoring agencies through conference
calls and webinars
Develops training modules and materials >
j
Analytical Support Laboratory
• Handles and stores collected samples according
to the SLT quality system
• Analyzes collected samples
(carbonyls and/or VOCs)
• Provides quality assured data to the SLT
monitoring agency
Figure A4-1. PAMS Required Site Network Communication and Responsibility Structure
A4.1 EPA OAQPS
OAQPS, with assistance from the EPA Regions, is responsible for defining and developing the
national quality system (QS) for the PAMS Required Site Network. OAQPS also allocates the
Clean Air Act (CAA) Section 105 grant monies to the EPA Regions according to the allocation
formula specified by Congress in the corresponding appropriations bill. The EPA Regions may
then decide to distribute a portion of their Section 105 funds to the SLT air monitoring agencies
for the execution of PAMS monitoring activities. OAQPS has the following responsibilities:
• Designating OAQPS technical and QA leads for the PAMS Required Site Network
• Ensuring national consistency across the PAMS Required Site Network
• Participating in the PAMS Required Site Workgroup
• Providing individual or group discussions with EPA Regions and SLT monitoring
agencies to help them determine and/or select appropriate instrumentation and ensure
consistent execution of the monitoring activities across the network
• Developing and finalizing the PAMS Technical Assistance Document (TAD), this
national QAPP, and other national SOPs, as needed
• Organizing and conducting training course(s) for automatic gas chromatograph (auto-
GC), ceilometer, and other pertinent instruments as well as technical and quality
assurance activities, as needed
• Developing and implementing the PAMS Technical Systems Audit (TSA) and
Proficiency Testing (PT) programs
• Setting TSA expectations and ensuring compliance
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• Managing the performance and PAMS contractual requirements of the National Contract
ASL, including:
o Approving QAPPs and SOPs from the National Contract ASL
o Conducting TSAs of the National Contract ASL and overseeing and approving
corrective actions resulting from TSAs and/or PTs
o Addressing inquiries and feedback regarding the National Contract ASL
communicated by SLT monitoring agencies and/or EPA Regions
OAQPS will use a support contractor to assist in the development of the quality system (QS)
guidance documents, provide audit support, and coordinate conference calls.
A4.2 EPA Regional Offices
The EPA Regions administer the QS for the SLT monitoring agencies in their Regions, ensuring
that the QS developed by each SLT monitoring agency complies with the national QS described
in this document. The EPA Regional Offices are the major communication link with monitoring
agencies and OAQPS; as such, they play an important role in the development and enforcement
of effective policies and programs. The Regional Offices have the following specific
responsibilities:
• Identifying a Regional PAMS Lead
• Participating in the PAMS Required Site Network Workgroup
• Reviewing and approving monitoring agency PAMS Required Site Implementation Plans
(IPs) and waiver requests
• Reviewing and approving the national PAMS Required Site QAPP, monitoring agency
specific QAPPs, and reporting approval of the monitoring agency QAPP to EPA's Air
Quality System (AQS)
• Performing TSAs of PAMS Required Sites and applicable ASLs or delegating TSA
conduct to the support contractor (per discretion of specific Region; unless informed
otherwise, OAQPS assumes that all PAMS TSAs will be conducted by the support
contractor)
o Attending the TSA with the support contractor, as time and EPA funding allows
o Identifying and communicating audit findings to OAQPS and SLTs
o Ensuring that SLTs and ASLs develop corrective action plans (CAPs) for audit (TSA
and/or PT) findings and that corrective actions are taken and are effective (i.e., that
findings are addressed)
o Recording TSA dates (i.e., occurrence and closeout) in AQS
• Providing QA oversight to PAMS Required Site monitoring agencies
• Providing technical assistance to PAMS Required Site monitoring agencies
• Serving as the communication liaison between OAQPS and PAMS Required Site
monitoring agencies
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A4.3 SLT PAMS Required Site Monitoring Agencies
SLT monitoring agencies are responsible for acquiring equipment, providing and training
appropriate staff, operating instruments and generating ozone precursor concentration and
meteorological data, verifying the quality of the measurements, and reporting the PAMS
measurements to AQS. The monitoring agencies have the following specific responsibilities:
• Collecting and reporting PAMS measurements at each NCore site that is located in a
CBSA with a population of 1 million or more based on the latest available census figures.
• Participating in the PAMS Required Site Network Workgroup
• Developing the monitoring agency's PAMS Required Site IP and submitting to the EPA
Region when establishing a new required PAMS site.
• Reviewing and providing input to the national PAMS QAPP, SOPs, and TAD
• Preparing waivers to PAMS requirements and submitting to the EPA Region, as needed
• Selecting and purchasing instruments to measure PAMS parameters
• Ensuring that the monitoring agency/PQAO identifies the independent QA personnel that
will oversee the QA Program of PAMS Required Site monitoring, including:
o Conducting annual internal audits of field and laboratory activities
[note - The national contract ASL will be responsible for ensuring internal audits are
conducted at the required frequency per their EPA-approved OAPP.]
o Reviewing data quality and performing data validation activities, including correcting
data when nonconformant data are identified
o Ensuring technical personnel are competent to perform monitoring tasks
• Installing and testing equipment to meet the implementation date
• Entering validated data into AQS in accordance with the protocols described in this
QAPP and the AQS Coding Manual unless the entry is performed by a delegated entity
(such as the national contract ASL)
• Developing the monitoring agency PAMS QAPP and submitting for EPA Regional
review and approval
• Reviewing the monitoring agency PAMS QAPP annually and revising this document as
necessary and within 5 years of previous approval
• Developing the monitoring agency PAMS SOPs, reviewing them annually, and
maintaining and revising these documents as necessary and within 5 years of previous
approval
• Reviewing SOPs for ASLs that are not part of a national contract for compliance with
this QAPP
• Implementing monitoring and analysis as described in the approved QAPPs and SOPs
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• Ensuring the quality of the data generated by ASLs, as appropriate, as negotiated between
the monitoring agency and ASL or described in national contracts
• Ensuring personnel attend training courses as necessary to ensure personnel have the
qualifications necessary to implement the PAMS Required Site program
• Developing and implementing CAPs based on nonconformances identified in internal and
EPA audits (including TSAs, audits of data quality [ADQs], PEs, and PTs)
The roles and responsibilities of specific monitoring agency personnel are described in Section
A6.2.
A4.4 Analytical Support Laboratory
The ASL is responsible for analyzing the carbonyls samples the SLT monitoring agency submits.
Its responsibilities include, but are not limited to:
• Complying with the PAMS Required Site SLT monitoring agency QAPP
[note - the national contract ASL QS will comply with the requirements in this national
QAPP per contractual requirements]
• Performing QA activities
o Conducting internal audits (such as TSA and ADQ)
o Participating in the PAMS PT program
• Following an approved SOP for receiving samples, extracting samples, and analyzing
sample extracts
o Notifying the SLT monitoring agency of problems with samples
o Extracting and analyzing carbonyls samples
o Maintaining reagents and standards for analyzing carbonyls samples
o Ensuring instrument and supporting equipment calibrations for carbonyls
extraction and analysis
o Taking corrective action when procedural or acceptance criteria deviations occur
• Reporting sample and quality control (QC) data to the SLT monitoring agency (unless
contracted otherwise)
o Verifying the laboratory data meet QA and QC acceptance criteria, are correct,
are complete, and comply with monitoring agency validation status readiness
o Flagging data with appropriate laboratory qualifiers when procedural or
acceptance criteria deviations are identified
• Developing and implementing CAPs based on nonconformances identified in internal and
EPA audits (TSAs, ADQs, and PTs)
• If the ASL is part of the national analytical support laboratory contract (i.e., which
typically also serves as the National Air Toxics Trends Stations [NATTS] ASL),
developing the laboratory QAPP governing PAMS carbonyls ASL support (which must
comply with the requirements in this national model QAPP) and submitting to the
OAQPS for approval in a timely manner, implementing the approved QAPP and SOPs,
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validating data, and reporting required data to AQS per arrangement with the SLT
monitoring agency.
A4.5 PAMS Support Contractor
A support contractor will perform specific tasks associated with the PAMS Required Site
program. While the exact tasks will be outlined in an annual EPA task order, the contractor
responsibilities are likely to include, but are not limited to:
• Facilitating PAMS Required Site Workgroup conference calls
o Developing agendas
o Participating and leading technical and QA-related discussions
o Summarizing conference call notes and identifying action items
• Developing nationwide PAMS TSA and proficiency test (PT) programs
o Submitting draft program design documents for the TSA and PT program to the
OAQPS and to the PAMS Required Site Workgroup to seek stakeholder feedback
o Incorporating PAMS Required Site Workgroup comments and finalizing the PT
program description document and TSA checklist
• Executing and participating in TSAs with EPA Regions
o Providing a yearly schedule of site evaluations for the EPA Regions
o Assisting Regional staff with the execution of TSAs to ensure national consistency in
the audit process
o Working with Regional PAMS Leads to review, evaluate, and closeout CAPs
resulting from TSAs
o Assisting monitoring agencies that require assistance implementing their CAPs
• Facilitating and executing the PT program
o Informing monitoring agencies of upcoming PTs
o Generating and distributing PT samples
o Collecting and reporting results to OAQPS, Regional staff, and monitoring agencies
o Reporting PT results to AQS
A4.6 PAMS Required Site Workgroup
The PAMS Required Site Workgroup was formed to address the technical and QA aspects of the
PAMS Required Site Program. Members of the group include personnel from the OAQPS, EPA
Regions, the monitoring agencies, and EPA's support contractor. The PAMS Required Site
Workgroup convened in May 2016 to start a dialogue on the aspects of the PAMS Required Site
Network and the steps necessary to ensure a national QS are in place by the June 2021
implementation date for the PAMS Required Site network. The workgroup meets approximately
monthly to discuss various technical and QA issues. The PAMS Required Site Workgroup will
have the following responsibilities:
• Participating in the development and review of the PAMS TAD, national QAPP, and
national SOPs
• Participating in the development and review of the PAMS TSA and PT programs
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• Assisting in the development of training and initial and continuing demonstration of
capability (IDOC and CDOC) programs
• Discussing PAMS Required Site network implementation
• Participating in the iterative data quality objective/data quality assessment (DQO/DQA)
process for QS improvement
It is expected that the workgroup will meet regularly to discuss issues, best practices, and items
pertinent to the PAMS Required Site Program to augment the overall quality system. The
frequency of meetings will be determined by the workgroup based on the stakeholder needs.
A5 Problem Definition/Background
Ozone is formed by the reaction of certain VOCs with oxides of nitrogen in the presence of solar
radiation. Reducing tropospheric ozone pollution requires reducing or eliminating emission
sources of VOCs and oxides of nitrogen. Modelers predict production of ground-level ozone by
running complex models which are continually refined to better estimate the ozone concentration
forecast under various meteorological conditions. Modelers assess model skill and refine model
functionality by comparison of model outputs to actual chemical and meteorological
measurements taken at PAMS sites. Modelers prefer the error in the collected measurement data
to be less than the error in the associated models.
The primary objective of the PAMS air monitoring program is to provide data to evaluate and
support the development of air quality models and measurement quality objectives (MQOs) were
developed with this objective in mind. The data will be used for other important purposes
including tracking trends in ozone precursor concentrations to aid ongoing efforts to attain the
ozone National Ambient Air Quality Standard (NAAQS). The PAMS program began in 1993
and was revised in 2006 by the EPA to permit PAMS to be more customized and aligned with
the needs of the responsible air quality agencies. On October 1, 2015, EPA further revised the
implementation of the PAMS program. The final rule in its entirety may be found elsewhere.1
The following are the highlights of the changes that occurred to the PAMS program as a result of
the promulgation of the new regulations:
• Network Design - The first part of the network design change involved EPA requiring
PAMS measurements during the PAMS (summer) sampling season, defined as June 1
through August 31, at all NCore sites in CBS As with a population of 1 million people or
more. The final network design will result in approximately 40 PAMS Required Sites, 14
of which are existing PAMS sites as shown in Table A5-116. The final requirements have
waiver provisions which allow monitoring agencies to make PAMS measurements at
alternative locations such as existing PAMS sites or at existing NATTS sites and to avoid
being required to make PAMS measurements in areas with historically low O3
concentrations. Therefore, the final site locations and network size may differ from what
is shown in Table A5-1.
The second part of the network design requires states with moderate or above ozone
nonattainment areas and states in the Ozone Transport Region (OTR - includes
Connecticut, Delaware, the District of Columbia, Maine, Maryland, Massachusetts, New
Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont, and Virginia)
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to develop and implement Enhanced Monitoring Plans (EMPs) for additional monitoring
of ozone precursors and meteorological conditions. These EMPs are intended to provide
monitoring agencies with the flexibility to implement enhanced monitoring to suit the
needs of their area. EMPs will not be further described within this document. If agencies
are conducting EMP activities, those details may be added to the agency specific PAMS
QAPP for EMPs. Additional information may be found in the following documents:
o Summary of Final Photochemical Assessment Monitoring Stations (PAMS) Network
Designs. September 25, 20152
° Federal Register. Environmental Protection Agency. October 26, 2015. 40 CFR Parts
50, 51, 52, 53, and 58; [EPA-HQ-OAR-2008-0699; FRL-9933-18-OAR]; RIN
2060-AP3 8 National Ambient Air Quality Standards for Ozone1
° U.S. Census Bureau. Metropolitan and Micropolitan Statistical Areas Population
Totals and Components of Change: 2020-202116
Table A5-1. Required Sites in CBSAs with a Population Greater than 1,000,000
Region
State
AQSID
CBSA
Population (as of July
1,2021)
1
MA
25-009-2006
Boston-Cambridge-Newton, MA-NH
4,899,932
1
NH
33-015-0018
Boston-Cambridge-Newton, MA-NH
4,899,932
1
RI
44-007-1010
Providence-Warwick, RI-MA
1,675,774
2
NJ
34-013-0003
New York-Newark-Jersey City, NY-NJ-PA
19,768,458
2
NY
36-081-0124
New York-Newark-Jersey City, NY-NJ-PA
19,768,458
2
NY
36-055-1007
Rochester, NY
1,084,973
3
DE
10-003-2004
Philadelphia-Camden-Wilmington, PA-NJ-DE
6,228,601
3
DC
11-001-0043
Washington-Arlington-Alexandria, DC-VA-MD
6,356,434
3
MD
24-033-0030
Washington-Arlington-Alexandria, DC-VA-MD
6,356,434
3
PA
42-101-0048
Philadelphia-Camden-Wilmington, PA-NJ-DE
6,228,601
3
PA
42-003-0008
Pittsburgh, PA
2,353,538
3
VA
51-087-0014
Richmond, VA
1,324,062
4
AL
01-073-0023
Birmingham-Hoover, AL
1,114,262
4
FL
12-011-0034
Miami-Fort Lauderdale-Pompano Beach, FL
6,091,747
4
FL
12-057-3002
Tampa-St. Petersburg-Clearwater, FL
3,219,514
4
GA
13-089-0002
Atlanta-Sandy Springs-Alpharetta, GA
6,144,050
4
KY
21-111-0067
Louisville/Jefferson County, KY-IN
1,284,566
4
NC
37-119-0041
Charlotte-Concord-Gastonia, NC-SC
2,701,046
4
NC
37-183-0014
Raleigh-Cary, NC
1,448,411
4
TN
47-157-0075
Memphis, TN-MS-AR
1,336,103
5
IL
17-031-4201
Chicago -Naperville -Elgin, IL -IN- WI
9,509,934
5
IN
18-097-0078
Indianapolis-Cannel-Anderson, IN
2,126,804
5
MI
26-163-0001
Detroit-Warren-Dearborn, MI
4,365,205
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Region
State
AQSID
CBSA
Population (as of July
1,2021)
5
MI
26-081-0020
Grand Rapids-Kentwood, MI
1,091,620
5
MN
27-003-1002
Minneapolis-St. Paul-Bloomington, MN-WI
3,690,512
5
OH
39-061-0040
Cincinnati, OH-KY-IN
2,259,935
5
OH
39-035-0060
Cleveland-Elyria, OH
2,075,662
6
OK
40-143-1127
Tulsa, OK
1,023,988
6
TX
48-113-0069
Dallas-Fort Worth-Arlington, TX
7,759,615
6
TX
48-201-1039
Houston-The Woodlands-Sugar Land, TX
7,206,841
7
KS
20-209-0021
Kansas City, MO-KS
2,199,490
7
MO
29-510-0085
St. Louis, MO-IL
2,809,299
8
CO
08-031-0025
Denver-Aurora-Lakewood, CO
2,972,566
8
UT
49-035-3006
Salt Lake City, UT
1,263,061
9
AZ
04-013-9997
Phoenix-Mesa-Chandler, AZ
4,946,145
9
AZ
04-019-1028
Tucson, AZ
1,052,030
9
CA
06-019-0011
Fresno, CA
1,013,581
9
CA
06-037-1103
Los Angeles-Long Beach-Anaheim, CA
12,997,353
9
CA
06-065-8001
Riverside-San Bernardino-Ontario, CA
4,653,105
9
CA
06-073-0003
San Diego-Chula Vista-Carlsbad, CA
3,286,069
9
CA
06-067-0006
Sacramento-Roseville-Folsom, CA
2,411,428
9
CA
06-085-0005
San Jose-Sunnyvale-Santa Clara, CA
1,952,185
9
NV
32-003-0540
Las Vegas-Henderson-Paradise, NV
2,292,476
10
HI
15-003-0010
Urban Honolulu, HI
1,000,890
10
OR
41-051-0080
Portland-Vancouver-Hillsboro, OR-WA
2,511,612
10
WA
53-033-0080
Seattle-Tacoma-Bellevue, WA
4,011,553
EPA modelers are the primary data users; however, it is expected that the chemical and
meteorological measurements will aid SLTs in identifying potential sources of ozone precursors
and will help inform emissions reduction strategies. The updated PAMS Required Site network
is spatially diverse, covering a variety of urban areas with varied and unique geographic,
topographic, and meteorological conditions. The resulting dataset will result in a better
understanding of ozone formation and emissions reductions that will be most impactful for a
specific area so as to increase the likelihood that ozone concentrations will come into attainment
with the ozone NAAQS.
A5.1 Monitoring Agency PAMS Required Site(s)
The monitoring agency will include the PAMS Required Sites covered by this QAPP in Table
A5-2.
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Table A5-2. PAMS Required Sites Covered by this QAPP
Site AQS ID
Site Name
Site Location
(Address)
County
XX-XXX-XXXX
A6 Project Task/Description
This section provides a summary of the work to be performed and the schedule for
implementation, including ambient air measurements, collecting samples, acquiring samples;
performing chemical analysis; carrying out QA/QC procedures to achieve data quality goals; and
meeting the schedules for continued network implementation, operation, and data reporting.
A6.1 Required Measurements
SLT monitoring agencies will operate and maintain the instruments and equipment needed to
make meteorological and chemical measurements for the PAMS Required Site program.
Instruments and methods are listed in Table A6-1. The monitoring agency will specify the
instrument models in its PAMS IP within its annual network monitoring plan. An example IP
suitable for documenting instruments to be deployed is included in Appendix F. The required
measurements are listed in 40 CFR Part 58 Appendix D Section 5 and are reproduced below:
• Hourly averaged concentrations of speciated VOCs;
• Three sequential 8-hour average concentrations of carbonyls determined on a l-in-3-day
schedule (refer to Table B1-2), or hourly averaged formaldehyde;
• Hourly averaged concentrations of O3 (not covered in this QAPP);
• Hourly averaged concentrations of nitrogen oxide (NO), "true" nitrogen dioxide (NO2),
and total reactive nitrogen (NOy) (NO and NOy are not covered in this QAPP);
• Hourly averaged ambient temperature;
• Hourly vector-averaged wind direction;
• Hourly vector-averaged wind speed;
• Hourly average atmospheric pressure;
• Hourly averaged relative humidity (RH);
• Hourly precipitation amount;
• Hourly averaged mixing layer height (MLH);
• Hourly averaged intensity of solar radiation; and
• Hourly averaged intensity of ultraviolet (UV) radiation.
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This QAPP covers the use of continuous GCs and meteorological measurements at the PAMS
site location only. Refer to 40 CFR Part 58 Appendix D Section 5(d) and 5(e) and Appendix F of
this QAPP, which describe options, with waivers, for collecting speciated VOCs using canisters
and using meteorological data from nearby locations (such as airports). The monitoring agency
will be required to submit alternative QAPP documentation to cover the options described in the
waiver.
Table A6-1. Measurements and Associated Instruments for PAMS Required Sites
Measurement
Parameter
Instrument and/or Method
Speciated VOCs
auto-GC with thermal desorption and dual FID
Carbonyls
Carbonyls-specific sampler capable of three sequential 8-hour samples -
Collection and analysis per EPA Compendium Method TO-11A
ASL will require a high-performance liquid chromatograph (HPLC) or ultra-
high performance liquid chromatograph (UHPLC) as described in Method
TO-11A and in PAMS TAD Revision 3 Section 5.0
Ozone
Federal Reference Method/Federal Equivalent Method (FRM/FEM) ozone
analyzera
True NO2
FRM/FEM True NO2 analyzer - photolytic conversion with
chemiluminescent detection or by cavity attenuated phase shift spectroscopy
NO/NOv
NOv analyzer3
Ambient Temperature
thermometer or thermistor
Wind Direction
cup and vane, propeller and vane, or sonic anemometer
Wind Speed
cup and vane, propeller and vane, or sonic anemometer
Atmospheric Pressure
aneroid barometer, pressure transducer
Relative Humidity
hygrometer
Precipitation
tipping bucket
Mixing Layer Height
ceilometer
Solar Radiation
pyranometer
Ultraviolet Radiation
pyranometer
a Ozone and NO/NOy are described in the appropriate monitoring agency criteria pollutant monitoring QAPP.
A6.2 Personnel to Accomplish Tasks
Monitoring agencies are expected to be organized with positions and roles (however named) to
accomplish PAMS monitoring tasks. Monitoring agencies will identify those individuals
participating in the PAMS Program within the monitoring agency PAMS Required Site QAPP.
An organization chart should be included that delineates the reporting structure.
NOTE: Monitoring agencies will identify personnel responsible for implementing the OA
Program in the monitoring network on the approval form in Appendix A. Such individuals
include the program lead, the OA lead, and monitoring staff receiving the approved OAPP.
Regardless of the organization of the monitoring agency, the roles are expected to be assigned
per the following, or similar, convention:
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Monitoring Agency Director (e.g., Program Director or similar): The Director has the overall
responsibility for managing the office according to monitoring agency policy. This individual
maintains overall responsibility for the management and administrative aspects of the technical
and QA programs; as such, he or she is responsible for establishing QA policy and for resolving
QA issues identified through the QA program. The Director has "stop work authority" and will
make final decisions regarding monitoring issues. Major responsibilities include, but are not
limited to:
• Managing and reviewing budgets, contracts, grants, and proposals
• Reviewing, overseeing, and evaluating overall air monitoring activities
• Assuring that the office develops and maintains a current QS
• Acquiring resources sufficient to enable the collection of required environmental data
• Maintaining an active line of communication with monitoring staff supervisor(s)
• Ensuring there are sufficient staffing resources to conduct the PAMS measurements
and supporting data processing activities
• Serving as the arbiter on final data quality/validity determinations and corrective
action effectiveness
Monitoring Staff Supervisor: The Monitoring Staff (MS) Supervisor reports to the Director and
serves as monitoring liaison to the EPA Region. The MS Supervisor consults with the Director
on monitoring and makes recommendations, when appropriate. The MS Supervisor's duties
include, but are not limited to:
• Supervising the activities of monitoring staff
• Communicating with EPA Regional personnel on issues related to routine monitoring
and QA activities
• Maintaining overall responsibility for the monitoring network design, review, and
assessment
• Maintaining oversight of QA/QC activities, which includes ensuring staff correctly
implement and complete regulatory and QS requirements as described in the
approved QAPP and SOPs, along with verifying that DQOs and MQOs prescribed in
the approved QAPP are met
• Documenting deviations from established procedures and methods
• Directing staff to implement corrective actions based on audit outcomes
• Developing and maintaining this QAPP
• Training staff in the requirements of the QAPP and supporting SOPs
• Facilitating technical training on instrument operations, maintenance activities, and
data management to ensure staff remain proficient and are cognizant of updates to
program requirements
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• Ensuring timely and appropriate updates to the QAPP and SOPs
• Assisting in acquiring equipment and maintaining equipment inventories
• Overseeing preventive maintenance and equipment certification activities are
completed in accordance with the schedules specified in the QAPP and SOPs
• Coordinating and reviewing collected data, which includes performing data quality
assessments and flagging suspect data
• Providing support for monitoring agency databases and data reporting to EPA AQS
• Reviewing AQS data QA/QC files to ensure overall data accuracy and completeness
• Generating AQS reports to verify successful and accurate upload of monitoring data
• Reviewing budgets, contracts, and proposals related to monitoring
Monitoring Staff (Site Operators): Staff calibrating and operating instruments and equipment
generating data for the PAMS Required Site Network must have the necessary training
commensurate with their job duties. Due to the complexity of the instruments needed for the
required measurements, site operators must be well-organized and capable of critical thinking to
successfully operate, maintain, and troubleshoot the instruments needed for PAMS
measurements. Monitoring agency monitoring staff consist of site operators, instrument
technicians, and support staff who conduct routine monitoring operations. Monitoring staff
report directly to the MS Supervisor and are responsible for implementing the PAMS Required
Site QS as described in this QAPP and the supporting SOPs. Responsibilities include, but are not
limited to:
• Maintaining proficiency with procedures applicable to their assigned duties
• Seeking training opportunities and attending training where needed
• Installing, calibrating, maintaining, and operating monitoring instruments
• Authoring, reviewing, and revising monitoring agency SOPs
• Reading, reviewing and contributing to the development of the monitoring agency
QAPP
• Following SOPs required to implement job responsibilities
• Documenting deviations from established SOPs, the QAPP, and monitoring agency
policies
• Recording monitoring activities promptly and traceably including instrument
calibration, maintenance, sample handling, and chain of custody
• Documenting unusual events that may impact measurement data
• Handling sampling media and instruments to maintain their integrity and avoid
contamination
• Verifying instrument calibrations by conducting ongoing QC checks
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• Taking and documenting corrective action when acceptance criteria are exceeded and
when nonconformances are identified whether in routine operations or during a TSA,
instrument performance audit (IPA), or audit of data quality (ADQ)
• Communicating site problems with the MS Supervisor
• Working with internal QA staff and external auditors to conduct TSAs, IP As, PEs,
and ADQs
• Ensuring a sufficient supply of resources such as spare parts, reference standards,
sampling media, and consumables are available to facilitate instrument repairs and to
minimize down time
• Performing first level review of measurement data and flagging suspect data
• Retrieving and shipping collected samples (carbonyls)
• Ensuring data from automated instruments are recorded and backed up to assure
redundancy
Quality Assurance Staff: Monitoring agencies/PQAOs will have QA personnel consisting of
staff independent of routine monitoring tasks. QA staff will include an overall lead (QA
manager, coordinator or officer) and possibly staff members who will report to the monitoring
agency Director or similar level of management, minimally two levels above the staff
responsible for routine monitoring activities. QA staff will typically be responsible for
overseeing the QA functions for numerous monitoring networks operated by the monitoring
agency. QA staff members will have the authority to independently report technical and QA
issues to management, identify audit findings, and oversee corrective actions on findings
affecting data quality. QA staff member (however named - specialists, auditors, officers, etc.)
duties include, but are not limited to:
• Ensuring that all QS documentation meets programmatic needs and is reviewed and
approved prior to the start of data collection
• Scheduling and performing internal TSAs on PAMS Required Site monitoring
activities. TSAs involve interviewing site operators and data validators, observing
processes to assess compliance with the approved QAPP and SOPs, and ensuring
siting requirements of the monitoring equipment are met
• Scheduling and performing internal IP As and PEs on monitoring agency sampling
equipment with reference standards independent of those employed to routinely
calibrate and verify calibration of the sampling instruments
• Scheduling and performing internal ADQs to assess the accuracy of data collection,
data transformation, data reduction, and data reporting operations to AQS, which
involves verification of the validity of a representative amount of collected
measurement data
• Reviewing PT results and ensuring corrective actions are taken for nonconformances
• Documenting the outcomes of internal IP As, PEs, TSAs, and ADQs and reporting the
outcomes to management
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• Managing the document control system
• Evaluating the quality of measurement data for compliance with the established DQO
(if any/as applicable) and MQOs for the various data quality indicators (DQIs)
• Ensuring corrective actions are taken as a result of QS nonconformances
• Assessing effectiveness of corrective actions and conducting follow-up audits to
demonstrate return to conformance
• Maintaining QA-related documents, files, and records
Data Validators: Monitoring agency data validation staff will have sufficient training to be
familiar with the PAMS measurement system data outputs, quality control of the measurement
systems, typical variations in measurement values, interactions and relationships between of
PAMS measurements (e.g., expected ratios of concentrations of various VOCs), chemical
constituents of greatest concern, and tools used to evaluate and investigate the technical validity
of PAMS measurement data. Data validators may consist of monitoring agency technicians, QA
staff, or other qualified individuals depending on what level of data validation is occurring. Final
validation must take place by personnel independent of technical monitoring staff. Data
validators will ultimately report to the monitoring agency Director, however named.
Analytical Support Laboratory (ASL): ASL staff will comply with the portions of this QAPP
which apply to the laboratory analysis of carbonyls and/or speciated VOCs in canisters. The
specific employee reporting hierarchy requirements of the ASL is outside of the scope of this
QAPP; however, each ASL will minimally have a structure similar to the monitoring agency
whereby there is a Director or Manager, an analyst and/or technician to perform laboratory
activities, and a QA staff member with authority to independently review and assess laboratory
operations for the PAMS Required Site program work. ASL technicians calibrating and
operating data generating laboratory instruments and equipment for the PAMS Required Site
Network will have the necessary training commensurate with their job duties. Due to the
complexity of the instruments needed for the required measurements, technical staff must be
well-organized and capable of critical thinking to successfully operate, maintain, and
troubleshoot the laboratory instruments needed for PAMS measurements. ASL QA staff will
similarly have experience and training necessary to properly perform independent assessment of
the instrument calibration and operation, data reduction, data verification, and data reporting
processes.
The monitoring agency will identify the ASL within this QAPP and will identify the ASL QAPP
(or equivalent), QMP, and SOPs to be followed for the ASL fulfilling the PAMS Required Site
program carbonyls analysis or VOC requirements. These documents may be indicated by
reference. If not identified within the ASL QAPP, the monitoring agency will identify in their
PAMS QAPP those individual(s) at the ASL responsible for:
- Performing analyses
Verifying data
- Providing QA oversight and assessments
- Providing overall oversight of the ASL's support to the PAMS Required Site monitoring
agency
Communicating with the monitoring agency director, however named.
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A6.3 Schedule for PAMS Required Site Activity Milestones
The monitoring agency will conduct the PAMS Required Site activities to meet the milestones as
described in Table A6-2. Note that start and completion dates for activities listed are specified
for agencies monitoring solely during the June 1 to August 31 PAMS season, and the dates may
be adjusted to accommodate agencies monitoring for periods extending beyond the default
PAMS season. Agencies intending to monitor following a schedule outside the three-month
PAMS season should adjust the dates in the table below to ensure activities are completed in
advance of the monitoring period.
Table A6-2. PAMS Required Site Activity Annual Milestones
Activity
Start Date
Completion Due Date
Details
Pre-sampling Season
Instrument and
Support Equipment
Maintenance
As needed to
ensure completion
by June 1
annually
Prior to June 1 annually
Complete annually prior to beginning
annual monitoring - Preventive
maintenance for measurement
instruments, sample collection
instruments, support equipment
Reference Standards
Acquisition,
Certification, or
Recertification
As needed to
ensure
instruments are
calibrated prior to
June 1 annually
Prior to June 1 annually
Complete annually prior to beginning
annual monitoring - Reference standard
materials (calibration stock gases or
carbonyls standards) and reference
standard instruments will be acquired,
certified, or recertified, as appropriate
Instrument warm up,
conditioning, and
calibration
Prior to June 1
annually for all
measurement
systems
Prior to June 1 annually
(to be completed prior
to receipt of PTs for
speciated VOCs and
carbonyls)
Shakedown period for each instrument
to ensure stable and accurate instrument
performance by the start of PAMS
season on June 1 - particularly
important for sites operating
instruments only for PAMS season
Quality Systems
Review and Revision
Once data are
validated and
reported to AQS
from the previous
year,
approximately
March 31, if not
earlier
April 15 annually
Review of the PAMS Required Site
QAPP and supporting SOPs to ensure
policies and procedures are accurate and
current - completed once validated data
from the previous year are reported to
AQS and prior to beginning monitoring
for the calendar year
Demonstration of
Capability
As convenient to
ensure completion
and approval
prior to June 1 -
or earlier if
PAMS
monitoring begins
prior to beginning
monitoring for the
calendar year
Prior to June 1 - or
earlier if PAMS
monitoring begins prior
to beginning
monitoring for the
calendar year
Approval by monitoring agency
management (i.e., immediate
supervisor) of the instrument operators,
data validators, and auditors to perform
their assigned duties - staff will
complete training and management will
approve by signature (Refer to example
training form in Appendix D)
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Activity
Start Date
Completion Due Date
Details
Shakedown Audit
Prior to June 1
annually
Prior to June 1 annually
- prior to PAMS season
for sites monitoring
earlier than June 1
readiness assessment to determine areas
requiring resources or correction to
ensure systems are online and calibrated
prior to commencing PAMS monitoring
Proficiency Test (PT)
for Speciated VOCs
and Carbonyls
Phase 1 - Prior to
June 1 annually
(for VOCs)
Phase 2 - August
15 annually (for
VOCs)
Prior to June 1 annually
(for VOCs)
August 31 annually (for
VOCs)
Sample with concentrations of target
speciated VOCs and carbonyls blind to
the site operator and/or support
laboratory - VOCs conducted prior to
and toward the end of each PAMS
season. Carbonyls conducted prior to
PAMS seasons.
PAMS Monitoring
June 1 annually
August 31 annually
Beginning and ending of Monitoring as
Required in 40 CFR Part 58 Appendix
D Section 5 and described in Section
A.7.3.1.1 of this QAPP - monitoring
agencies may monitor outside of these
dates if their ozone problem begins
earlier and/or lasts beyond this period
Internal Technical
Systems Audit (TSA)
June 1 annually
August 31 annually
Review of monitoring agency
compliance with PAMS Required Site
program requirements, QAPP, SOPs,
and best practices - conducted by
monitoring agency QA - conduct of the
TSA will occur during active
monitoring for agencies conducting
monitoring beyond June 1 to August 31
Performance
|igust 31 annual|
Conduct of the PE will occur durirB_
Evaluation (PE) l|
True NO2
active true NO2 monitoring for agencies
conducting monitoring beyond June 1 tc
August 31
Challenge of the true NO2 measurement
system with known NO2 concentrati^I
produced by GPT - conducted by
monitoring agency QA or independent
PQAO sl;B
Instrument
Performance Audit
(IP A)
June 1 annually
August 31 annually
Conduct of the IPA will occur during
active monitoring for agencies
conducting monitoring beyond June 1 to
August 31
Measurement of the carbonyls sampling
unit flow with a certified reference flow
transfer standard - conducted by
monitoring agency QA
Assessment of meteorological
measurements by comparison to a
certified reference standard - conducted
by monitoring agency QA
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Activity
Start Date
Completion Due Date
Details
Audit of Data Quality
(ADQ)
Not before data
are reported to
AQS
Prior to review and
revision of PAMS QA
documents for the
following year's
monitoring
Review of a representative amount of
PAMS measurement data for accuracy
from instrument calibration, sample
measurement, and final reporting to
AQS
Data Verification and
Validation
June 8 annually
Prior to data reporting
to AQS
Data verification and validation begins
approximately one week after start of
data collection to ensure data meet
acceptance criteria and ensure the
workload is manageable.
Data Reporting to
AQS
Not before data
validation is
completed
Within 180 days of the
end of the calendar
quarter in which the
measurement data were
collected
Input of validated measurement data to
AQS. Upload of all PAMS parameter
data to AQS and verification that data
were uploaded correctly
A6.4 Summary of Assessment Techniques
The monitoring agency and ASL will assess the performance of the PAMS Required Site
activities by conducting independent assessments. The monitoring agency and ASL QA staff will
perform these assessments as detailed in Section C.l.l.
A7 Quality Objectives and Criteria
The primary objective of the PAMS Required Site network is to provide data of known quality
for use by EPA modelers and scientists.
A7.1 Data Quality Objectives
DQOs are qualitative and quantitative statements derived from the DQO Planning Process that
clarify the purpose of a study, define the most appropriate type of information to collect,
determine the most appropriate conditions under which to collect that information, and specify
tolerable levels of potential decision errors. DQOs define the quality of and the acceptable levels
of uncertainty in the measurements and their associated uncertainty that can be tolerated to make
decisions regarding the measurements. Stated another way, DQOs are statements describing
"how good" the measurements need to be to provide data to control decision risk(s) meet the
project outcomes within a known certain levels of confidence and to ensure that collected data
are of sufficient quantity and quality to be fit for the stated purpose to objectively assess the risk
in the decisions to be made.
Although a formal DQO process was not undertaken on the PAMS Required Site Network to
determine a PAMS Required Site DQO, EPA solicited input on data needs from PAMS
monitoring agencies and EPA modelers, i.e., from the primary users of the PAMS information.
Measurement quality objectives (the MQOs) for the various data quality indicators (DQIs) were
established based on the expertise of EPA modelers and data analysts and their data quality
needs for ozone and ozone precursor model evaluation and model inputs. Modelers compare
their model outputs to observed concentrations. For such comparisons the measured
concentrations are considered to be the true value thus minimizing bias and imprecision was
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determined to be most important for the improvement of model skill. Monitoring agencies
measuring PAMS parameters and other experts in PAMS measurements reviewed the proposed
MQOs to ensure they were reasonable and attainable. Additionally, if more sensitive or accurate
measurement methods become available and are deemed to be necessary to meet modelers'
needs, the MQOs may be modified and refined to accommodate the updated methods.
A7.2 Data Quality Indicators
The DQIs of representativeness, completeness, precision, bias, and sensitivity are the
characteristics describing how good the data must be to meet the DQO. The DQIs are
characterized by prescribing an associated MQO for each DQI that details the specific criteria to
be met. These DQIs and associated MQOs are detailed further in Sections A7.3.1 through
A7.3.5.
A7.3 Measurement Quality Objectives
The MQOs for each of the DQIs are shown in Table A7-1. Since O3 and NO2 are criteria
pollutants and are used for designating compliance with the NAAQS, the MQOs in Table A7-1
duplicate those listed in the validation templates of the EPA QA Handbook Volume II. Note that
an MQO for precision is not specified for meteorology measurements. Precision for meteorology
would involve either measuring the same event with two separate instruments (collocation) or
measuring a standard condition in replicate. It is not practical to operate a full-time collocated
meteorology station due to the additional expense and logistics required to install a separate
meteorology tower, and challenging the meteorology instruments in situ to acquire replicate
measurements of a controlled meteorology condition is impractical. Additional details on the
various checks used to measure and assess the DQIs may be found in the Quality Control
Measurements Section B1.2.
EPA technical staff, their QA support contactors, monitoring equipment vendors, and the
monitoring agencies also provided feedback on the MQOs for various DQIs that would be
considered achievable under field conditions. These MQOs were then discussed with monitoring
agencies and other PAMS measurement subject matter experts to ensure that the MQOs were
attainable and reasonable, and if not, the MQOs were further refined as listed in Table A7-1.
EPA modelers found these to be acceptable.
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Table A7-1. PAMS DQIs and Associated MQOs
Method or Parameter
DQI
Chemical
Measurements
Representativeness
(Sampling
Frequency)3
Bias (%)
Precision
(%)
Sensitivity
(Detection
Limit)
Completeness
(%)
Auto-GC speciated
VOCs
Continuous, hourly
average
<25b
<25c
< 0.5 ppbC
>75
True NO2 and NO/NOy
Continuous, hourly
average
<±15.1% or
± 1.5 ppbd
whichever is
greater
< 15.1% or
1.5 ppbc
whichever is
greater
<0.001 ppm
>75
Ozone
Continuous, hourly
average
< ± 7.1% or
± 1.5 ppbd
whichever is
greater
<7.1% or 1.5
ppbc
whichever is
greater
< 0.002 ppm
> 90% (avg) daily
max available in
O3
season with min of
75% in any 1 year1
TO-11A (carbonyls)
Three sequential 8-
hour samples every
3rd daye>f
<25g
< 15h
<0.25 (ig/m3
>85
Meteorology
Representativeness
(Sampling
Frequency)3
Bias
Precision
Sensitivity
(Resolution)
Completeness
(%)
Ambient Temperature
Continuous, hourly
average
< ± 0.5 °C
not specified
<0.1 °C
>75
Relative Humidity
Continuous, hourly
average
< ± 5% RH
not specified
< 0.5% RH
>75
Barometric Pressure
Continuous, hourly
average
< ± 3 hPa
not specified
<0.1 hPa
>75
Wind Speed
Continuous, hourly
average
< ± 0.2 m/s
or ± 5%,
whichever is
greater
not specified
<0.1 m/s
>75
Wind Direction
Continuous, hourly
average
<±5
degrees
not specified
< 1 degree
>75
Solar Radiation
Continuous, hourly
average
<±5%
not specified
< 1 Watt/m2
>75
UV Radiation
Continuous, hourly
average
<±5%
not specified
< 0.01 Watt/m2
>75
Precipitation
Continuous, hourly
average
<± 10%
not specified
<0.25 mm/lir
>75
Mixing Layer Height
Continuous, hourly
average
Not
ApplicableJ
not specified
< 10 m
>75
a Spatial representativeness is addressed in monitor siting as specified in Section A7.3.1.2.
b Assessed with twice-annual PT samples and across the entire PAMS season as the upper bound of the mean
absolute value of the percent differences across all single-point QC checks. For functional form of the calculation,
see 40 CFR 58 Appendix A Section 4.1.3, Equations 3, 4 and 5.
0 Measured as the upper bound of the coefficient of variation (CV) across all single-point QC checks in the PAMS
season. For functional form of the calculation, see 40 CFR 58 Appendix A Section 4.1.2, Equation 2. Acceptance
criteria listed here for criteria pollutants duplicate those in the EPA QA Handbook validation templates. Changes
to the QA Handbook requirements will supersede those criteria listed here.
d Measured as the upper bound of the mean absolute value of the percent differences across all single-point QC
checks in the PAMS season. For functional form of the calculation, see 40 CFR 58 Appendix A Section 4.1.3,
Equations 3, 4, and 5. Acceptance criteria listed here for criteria pollutants duplicate those in the EPA QA
Handbook validation templates. Changes to the QA Handbook requirements will supersede those listed here.
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e Carbonyls sampling by TO-11A may be substituted with continuous formaldehyde monitoring and reporting of
the hourly average. MQOs for continuous formaldehyde monitors have not been established at the time this
document was written.
f Carbonyls sampling will follow the l-in-3 day sampling schedule as prescribed in Table B1-2 and the national
sampling calendar available at the following link on AMTIC: https://www.epa.gov/amtic/sampling-schedule-
calendar
g Assessed with twice-annual PT samples.
h Measured as the coefficient of variation of the RPDs across, as applicable, all (i) duplicate/collocated field-
collected cartridges; duplicate laboratory control samples (LCS), and (iii) replicate laboratory analyses in the
entire PAMS season. See Sections 2.5.1 and 2.5.2 of the NATTS 2011-2012 Quality Assurance Annual Report
available here: https://www3.epa.gov/ttnamtil/files/ambient/airtox/NATTS201120120AARfinal.pdf
1 Refer to 40 CFR Part 50 Appendix U, Section 4
J Agencies are not required to calculate bias for the mixing layer height.
EPA reserves the right to revise the prescribed MQOs as needed. Any such adjustments will be
communicated to the PAMS Required Site Network stakeholders and documented in a revised
QAPP.
A 7.3.1 Representativeness
A 7.3.1.1 Temporal Representativeness
To adequately characterize the concentrations of ozone and ozone precursors during PAMS
season (defined by default as June 1 to August 31 - though the period at a given site when ozone
production becomes problematic may be extended to begin before June 1 and end after August
31), the sampling frequency for each of the required parameters is prescribed as follows. The
sampling frequency for ozone, true NO2, NOy, speciated VOCs, and meteorological parameters
is for sampling to occur continuously daily, and the collected data averaged for each hour. Ozone
and NO/NOy measurements at the PAMS Required Site will be described in and comply with the
monitoring agency QAPP governing the NCore measurements of criteria pollutants at the site.
Due to the labor-intensive aspects of manual sample collection onto cartridge media and the
difficulty in achieving adequate sensitivity, carbonyls sampling is not required hourly, but
instead is required on a l-in-3-day schedule consisting of three sequential 8-hour samples (refer
to the sampling schedule in B 1.1.1 for start and stop times). Carbonyls samples will be collected
per the national sampling calendar available at the following link on AMTIC:
https://www.epa.gov/amtic/sampling-schedule-calendar
Carbonyls collection onto 2,4-dinitrophenylhydrazine (DNPH) cartridges may be substituted
with continuous formaldehyde measurements for which the concentration data are reported as the
hourly average (note that the QA requirements have not been established for continuous
formaldehyde measurements).
Monitoring agencies will specify the frequency and schedule for collection of VOCs if it has a
waiver to collect VOCs in canisters for laboratory analysis.
The average hourly measurement of ozone precursors collected continuously (with the exception
of the required compromise presently required for carbonyls) provide a sufficient number of data
points at a sufficient time resolution to ensure that the measurements characterize the
concentration patterns over the course of the PAMS season at a given PAMS Required Site.
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Incorporating the meteorological measurements reported as an hourly average provides a robust
dataset representative of the conditions at the site.
Monitoring agencies will specify the monitoring schedule for each monitoring method (such as
during the June 1 to August 31 PAMS season, year round, or other appropriate schedule).
A 7.3.1.2 Spatial Representativeness - Chemical Measurement Probe Siting Criteria
Sampling inlet probes and equipment must comply with the siting criteria in 40 CFR Part 58
Appendix E to ensure the collected atmosphere is representative of the ambient air in the
geographic area of the site. If there are any issues with meeting the requirements, the monitoring
agency must consult with the EPA Regional office to request a waiver.
The probe must be at least 1 meter vertically or horizontally away from any supporting structure,
walls, parapets, penthouses, etc., and away from dusty or dirty areas. Inlet probes must have
unrestricted airflow in a continuous 270-degree arc and the predominant wind direction must be
included in this arc. To the extent feasible, inlet probes must not be located on the side of a
building. However, if such is unavoidable, then the inlet must be located on the windward side of
the building or wall relative to the prevailing wind direction during PAMS season and must have
unrestricted airflow in an arc of at least 180 degrees. As most of the PAMS Required Sites will
be located at existing NCore sites, EPA does not expect that probes will be mounted on the side
of a building.
Inlet Probe Heights: Inlet probes must be placed at the following heights:
PAMS VOCs 2 to 15 m above ground level (AGL)
PAMS carbonyls 2 to 15 m AGL
True NO2 2 to 15 m AGL (neighborhood or larger spatial scale)
Obstructions: The inlet probe must be minimally twice the distance from the potential
obstruction as the potential obstruction extends above the inlet probe. For example, if a wall
extends 2 meters above the inlet probe, the inlet probe must be 4 meters or more from the wall.
Spacing from Trees: Trees can provide surfaces for O3 or NO2 adsorption or reactions and may
prevent the accurate measurement of other PAMS parameters when of a sufficient height and
leaf canopy density to interfere with airflow. To avoid such interferences, inlet probes must be
minimally 10 meters, and should preferably be 20 meters when measuring NO2, from the dripline
of the nearest tree.
Spacing from Roadways: Mobile sources represent a significant source of ozone precursors;
therefore, it is important to ensure that monitoring site inlet probes are sufficiently displaced
from roadways where they can be unduly impacted by motor vehicle emissions. Minimum
separation distances for monitor inlet probes from roadways assume PAMS sites are urban scale
and therefore must comply with Table E-l of 40 CFR Part 58 Appendix E, reproduced below in
Table A7-2. Note that these minimum separation distances must also be maintained from other
motor vehicle traffic areas such as parking garages and parking lots.
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Table A7-2. Minimum Monitor Separation Distance from Roadways
Roadway
average daily traffic (ADT),
vehicles per day
Minimum
distance a
(meters)
Minimum
distance a'b
(meters)
< 1,000
10
10
10,000
10
20
15,000
20
30
20,000
30
40
40,000
50
60
70,000
100
100
> 110,000
250
250
a Distance from the edge of the nearest traffic lane. The distance for intermediate traffic counts
will be interpolated from the table values based on the actual traffic count.
b Applicable for ozone monitors whose placement has not already been approved as of
December 18, 2006.
A 7.3.1.3 Spatial Representativeness - Meteorology
Siting of meteorology equipment for the required measurements is specific to each instrument
type. General siting criteria for the meteorology instruments follows.
Wind Speed and Wind Direction: The standard height for surface layer wind measurements is
10 m AGL.4-6-7 The location of the site for the wind measurements must ensure that the
horizontal distance to obstructions (e.g., buildings, trees) is at least 10 times the height of the
obstruction.4-7 An obstruction may be man-made (e.g., a building) or natural (a tree). A wind
instrument must be securely mounted on a mast on the tower that will not twist, rotate, or sway.
Sensor height and its height above the obstructions, as well as the character of nearby
obstructions, must be documented in the site characterization documentation.
An open lattice tower is the recommended structure for monitoring of meteorological
measurements at the 10-m level. In the case of wind measurements, certain precautions are
necessary to ensure that the measurements are not significantly affected by turbulence in the
immediate wake of the meteorological tower. To avoid such tower effects, the wind sensor will
be mounted on a mast a distance at least one tower width above the top of the tower, or if the
tower is higher than 10 m, on a boom projecting horizontally from the tower. In the latter case,
the boom will extend a distance at least twice the diameter/diagonal of the tower from the nearest
point on the tower. The boom will project into the direction which provides the least distortion
for the most important wind direction (i.e., into the prevailing wind).
Ambient Temperature and RH: The standard height for surface layer ambient temperature and
RH measurements is 2 meters AGL.6 Higher mounting is permitted; if a tower is used, the
temperature sensor will be mounted on a boom which extends at least one tower width/diameter
from the tower. The measurement will be made over a uniform plot of open, level ground at least
9 m in diameter centered on the sensor. The surface will be covered with non-irrigated or un-
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watered short grass or, in areas which lack a vegetation cover, natural earth. Concrete, asphalt,
and oil-soaked surfaces and other similar surfaces must be avoided to the extent possible. The
sensor will be at least 30 m horizontally from any such paved area. If these siting criteria (open
ground and distance from paved surfaces) cannot be achieved, it will be identified in site
characterization documentation. Other areas to avoid include extraneous energy sources (subway
entrances, rooftops, electrical transmission equipment), large industrial heat sources, roof tops,
steep slopes, hollows, high vegetation, swamps, snow drifts, standing water, tunnels, drainage
culverts, and air exhausts. The distance to obstructions for accurate temperature measurements
will be at least four times the obstruction height.8
Solar Radiation and Ultraviolet Radiation: Solar and UV radiation measurements will be
taken in a location with an unrestricted view of the sky in all directions. Locations where there
are obstructions that could cast a shadow or reflect light on the sensor, such as light-colored
walls or artificial sources of radiation, must be avoided. The elevation to the horizon as viewed
from the pyranometer must not exceed 5 degrees. Sensor height is not critical for pyranometers;
consequently, tall platforms or roof tops are typical locations.
Barometric Pressure: Barometric pressure instruments will be located in a ventilated shelter
about 2 m above ground level. The height of the station above mean sea level and the height of
the pressure sensor AGL will be documented in the site characterization records.
Precipitation: Precipitation gauges will be located on level ground in an open area. Obstructions
will not be closer than two times their height from the instrument. The area around the
precipitation gauge should be covered with natural vegetation and should not be located on a
paved or hard surface (e.g., the roof of a monitoring shelter) to minimize splashing. The mouth
of the gauge will be level and will not be lower than 30 cm above ground level (to avoid being
covered with snow). To ensure accessibility for technicians, the instrument should be mounted
not higher than 2 m above ground level. A wind shield/wind screen (such as an Alter-type wind
shield consisting of a ring with approximately 32 free-swinging separate metal leaves) will be
employed to minimize the effects of high wind speeds.
Mixing Layer Height (MLH): The ceilometer for determining MLH measurements is intended
for more macro-scale application than are the surface meteorological measurements.
Consequently, the location of the ceilometer need not be associated with any particular PAMS
surface site. Factors that will be considered in selecting a site for the MLH monitor include
whether the upper-air measurements for the proposed location are likely to provide the necessary
data to characterize the meteorological conditions associated with high ozone concentrations, and
the extent to which data for the proposed location of the ceilometer may augment an existing
upper-air network. The ceilometer must be securely installed on a stable level surface such as a
concrete pad or wooden platform suitably located to provide an unobstructed view of the sky. A
wide-open location is recommended where there are no tall trees, overhead lines, or antennas
nearby. Proximity to powerful radars should also be avoided. Any object in the cone projecting
upward created by an angle of 25° from vertical will impede the ability of the ceilometer to
properly measure atmospheric backscatter. Common interfering objects would include
powerlines, tree branches, tower support guidewires, flagpoles, or similar features which may be
permanently or transiently present above the ceilometer.
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A 7.3.2 Completeness
Generation of a dataset sufficient to characterize the daily concentrations of ozone, ozone
precursors, and parameters of interest to PAMS requires that a minimum number of the intended
measurements are valid. Completeness is defined as the percentage of the number of valid data
values compared to the number of values intended to be collected. The MQOs for completeness
are specified for each parameter as detailed in Table A7-1.
For continuous measurement methods reported as the hourly average, uncollected or invalidated
measurement results are lost, and cannot be made up. For hourly measurements, 45 minutes will
be considered a valid hour and 18 hours a valid day. Note that due to limitations with the
instrument cycling for sample collection and measurement, a valid sampling hour for speciated
VOCs is 40 minutes of sampling for the hour, for which 30 minutes of this 40-minute period
must occur during the sampling hour. The overall completeness listed in Table A7-1 will be
based on acquiring data for the entire PAMS season determined as the total valid samples out of
the samples possible. For continuous measurements, this will be based on approximately 2208
hours. For carbonyls samples, the total possible sampling days is 30 or 31 days, depending on the
sampling calendar for the year. For carbonyls sample collection, if a sample day is missed, a null
code "AF" (scheduled but not collected) will be reported to AQS for the sample run date; if the
sample is invalidated for a particular reason, an appropriate null code will also be reported to
AQS for the sample run date. A make-up sample must be collected as soon as practical according
to the make-up sampling policy below.
Carbonyls Make-Up Sample Policy: For invalidated or missed carbonyls sampling events, a
make-up sampling event will be conducted. As soon as a sampling issue is known, a replacement
carbonyls sample set (three 8-hour samples) will be collected as close to the original sampling
date as possible, should not exceed two weeks from the originally scheduled collection date, and
will be collected within PAMS season barring extenuating circumstances such as equipment
failure or if the sampling event is the last of the season, etc. Make-up samples will be collected
according to the following:
1. Before the next scheduled sampling date
2. Within two weeks of the missed collection date, with preference given that the
rescheduled date occurs on a weekday or weekend day to match that of the original
schedule
Recognizing that the laboratory analyses and/or reporting of carbonyls sample data may occur
after this period, make-up samples will most likely be collected for cartridge or instrument issues
that the site operator is able to identify soon after the original sampling date.
A 7.3.3 Precision
Precision is a measure of agreement among repeated measurements of the same property under
identical, or substantially similar, conditions. The lack of precision (imprecision) represents the
random component of error.
Precision for Continuous Measurements of Ozone and NOy: Precision assessments for NOy
and ozone are addressed in the monitoring agency NCore or State and Local Monitoring Stations
(SLAMS) QAPP for criteria pollutant monitoring.
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Precision for Continuous Measurements of true NO2: Precision for true NO2 is assessed by
calculating the upper 90% confidence limit (CL) for the coefficient of variation (CV) across all
single-point QC checks measured annually (or during PAMS monitoring if NO2 monitoring is
limited to PAMS season). For functional form of the calculation, see 40 CFR 58 Appendix A
Section 4.1.2, Equation 2.
Precision for Speciated VOCs: Precision is assessed by analysis of replicate calibration
verification standards. A sequential (back-to-back) analysis of the continuing calibration
verification (CCV) is performed for the speciated VOCs precision check. As an overall MQO,
the precision is evaluated as the upper bound of the coefficient of variation (CV) across all
single-point CCVs in the PAMS season. For functional form of the calculation, see 40 CFR 58
Appendix A Section 4.1.2, Equation 2.
Within run precision is evaluated by comparing replicate measurements in a pair-wise fashion to
determine the relative percent difference (RPD) between the two measurements which must be
< 25% for each assessed target compound. RPD is calculated by dividing the absolute value of
the difference between the two measurements by the average of the two measurements. Precision
will be further evaluated on an ongoing basis for groups of CCVs by calculating the relative
standard deviation (RSD) which is found dividing the standard deviation of the measurements by
the average of the measurements. RSD for n > 2 replicate measurements must be < 25%. When
determining RSD for speciated VOCs, all measurements in the desired time window (e.g.
including the precision CCVs for one month, two months, or all of PAMS season) will be
included unless there is a valid reason for exclusion (such as instrument problem or other
documented technical issue). Ambient sample data for target analytes failing precision criteria
will be appropriately qualified or invalidated, as appropriate, when reported to AQS. Monitoring
agencies must take corrective actions for precision acceptance criteria failures of priority
compounds and should take corrective actions for optional compounds failing precision criteria,
though they are not required. Monitoring agencies should evaluate precision on an ongoing basis
to determine whether precision criteria are in jeopardy and take corrective actions to ensure
precision across the monitoring season does not exceed criteria.
Precision for Meteorology Measurements: As discussed in Section A7.3, precision for
meteorological measurements is not practical and will not be assessed for the PAMS Required
Site Program.
Precision for Carbonyls: Field sampling precision must be assessed for carbonyls at minimally
10% of the PAMS Required Network Sites. Such precision assessments entail collection of
duplicate samples (a pair of samples collected through a common inlet probe) or collocated
samples (a pair of samples each collected through independent inlet probes) concurrently with
the primary sampling events. The monitoring agency can choose to assess precision by either the
duplicate or collocated method. Duplicate or collocated cartridges will be collected at a rate of
minimally 10%, equivalent to three per month. Precision of duplicate and collocated samples is
assessed as the RPD of the concentrations measured for the collocated or duplicate pair and must
be < 20% for samples for which both cartridges measure >0.5 |ig/cartridge. Duplicate or
collocated samples for which one or both cartridges measure < 0.5 |ig/cartridge are not required
to meet this acceptance criterion. Duplicate or collocated results that do not meet the precision
acceptance criterion will be qualified when entered in AQS and will prompt the ASL and field
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operations to perform corrective actions to investigate the precision sample result discrepancy for
priority compounds. Corrective actions should be taken for precision failures for optional
carbonyl compounds, but they are not required.
Precision of laboratory extraction and analysis procedures is to be assessed by preparation and
analysis of duplicate laboratory control samples (LCS) consisting of a pair of blank DNPH
cartridges spiked with target compounds at the laboratory and extracted and analyzed with
collected field samples. Precision of the LCS and LCS duplicate (LCSD) is assessed as RPD
which must be < 20%. An LCS/LCSD pair is to be prepared, extracted, and analyzed minimally
twice quarterly. Ambient sample results associated with LCS/LCSD results that do not meet the
precision acceptance criterion will be qualified when entered in AQS and will prompt the ASL to
perform corrective actions to correct the discrepancy for priority compounds. Corrective actions
should be taken for LCS/LCSD precision failures for optional carbonyl compounds, but they are
not required.
Precision of laboratory analysis is assessed by replicate analysis of an extract from a field-
collected cartridge (not a trip or field blank). Precision of the replicate analysis is assessed as
RPD which must be < 10% for samples that measure >0.5 |ig/cartridge. A replicate analysis is to
be performed with each analysis batch (defined as a sequence of samples extracted as a single
group over a finite time interval, typically 20 field-collected cartridges). Failures of priority
compound replicate sample results will prompt the ASL to take corrective action which should
include reanalysis of the sample extract to confirm the failure. If the analytical precision failure
cannot be corrected, associated ambient sample results will be qualified when entered in AQS for
affected compounds. Corrective actions should also be taken for replicate analysis failures for
optional carbonyl compounds, but they are not required.
The network MQO for carbonyls is based on an evaluation of the entire PAMS season's data. In
all cases a CV of < 15% must be met. For more information on how the CV is calculated, see the
2011-2012 NATTS Quality Assurance Annual Report, available at the following link:
https://www3.epa.gov/ttnamtil/files/ambient/airtox/NATTS20112012QAARfinal.pdf
Note that this precision MQO is different than the precision acceptance criteria for the individual
pairs of duplicate or collocated samples, the imprecision of which are permitted to exceed 15%.
Such method-specific precision requirements apply to comparing two measurements and do not
apply to larger (N > 2) sample sets.
A 7.3.4 Bias
Bias, the systematic (nonrandom) deviation of a measurement from a known or accepted value,
is minimized by using calibrated instruments and equipment, by checking that instruments
remain calibrated over time, and by minimizing sources of background contamination.
All instruments must be suitably calibrated before PAMS season and thereafter their calibration
must be periodically demonstrated to remain valid by comparison with a known traceable
certified reference standard or instrument. For chemical measurements, once calibration is
established for an instrument, the calibration is to be immediately verified against a known
traceable certified standard, typically a second source standard. The required frequency for
periodic ongoing checks for PAMS instruments is described below.
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Bias of continuous chemical analysis parameters is evaluated by challenging the instruments
with a known standard on a frequent basis, daily for VOCs and minimal^pve^B4 daj for
N02, typically during nighttime hours when ambient concentrations of the target analytes are
lower and the measurements are less critical in predicting ozone levels for the following day. The
known standard is analyzed to demonstrate the instrument calibration remains within tolerance
and is typically followed by a blank or "zero" immediately following the calibration check to
demonstrate that the instrument signal returns to background levels in the absence of target
analyte. The overall bias MQOs for the continuous parameters for the entire PAMS season are
shown in Table A7-1. The nightly continuing calibration checks and zero background checks for
the auto-GC and true NO2 analysis are described in Sections B5.1.2 and B5.1.3, respectively.
For carbonyls, bias resulting from field activities is assessed and minimized by a combination of
pre-deployment bias checks and flow calibration and calibration verification for sample
collection instruments and by periodic collection of field and trip blanks. Laboratory bias is
minimized by calibration and verification of detector response for the HPLC analysis instrument.
Following annual maintenance and prior to field deployment at the beginning of each PAMS
season, a positive bias verification and flow calibration are performed on the carbonyls sampling
unit. The positive bias verification is briefly described in Section B5.1.1 and is detailed in
Revision 3 of the PAMS TAD (https://www.epa.gov/amtic/photochemical-assessment-
monitoring-stations-pams) and in the carbonyls field sample collection standard operating
procedure (SOP). The positive bias verification procedure will be described in the agency
carbonyls field sample collection SOP and must demonstrate that the sampling unit contribution
for each target carbonyl is < 0.2 |ig/cartridge. This is evidenced by measurement of target
compounds on a challenge cartridge collected with humidified zero air being < 0.2 |ig/cartridge
greater than the co-collected reference cartridge for each individual target carbonyl compound.
The sampling unit must meet this specification before field deployment. Note: Monitoring
agencies are encouraged, but not required, to take corrective action to eliminate apparent
contamination from samplers even if the 0.2 jug cartridge threshold is not exceeded. Sampling
unit flow rates must be verified before field deployment and monthly thereafter against a
National Institute of Standards and Technology (NIST)-traceably certified reference flow
transfer standard. Indicated flow rates must be within ± 10% of the flow transfer standard. If the
flow is not within ±10%, ambient sample data since the most recent passing flow check will be
qualified or invalidated. Laboratory bias is controlled by establishing a multi-point calibration
curve with subsequent analysis of a CCV standard every 12 hours of analysis. This CCV must
demonstrate the instrument calibration remains within ±15% of the original response. If this
criterion is exceeded, corrective action will be performed to demonstrate appropriate calibration
response and the extracts since the last passing CCV will be reanalyzed. If reanalysis cannot be
performed, ambient sample data for affected target analytes will be qualified when reported to
AQS. The CCV is followed by a solvent method blank when additional samples are to be
analyzed to demonstrate that the instrument has returned to a stable baseline and that there is no
carryover or significant interferences in the instrument system.
Poor or infrequent instrument or instrument inlet maintenance will also cause bias in reported
concentrations for speciated VOCs and carbonyls. Instrument maintenance is described in
Section B6.4 of this QAPP and in the supporting instrument SOPs.
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Bias of speciated VOCs and carbonyls will be assessed annually just prior to PAMS season and
VOCs will also be assessed toward the end of PAMS season through analysis of PT samples.
Bias of speciated VOCs measurements will be additionally assessed by evaluation of the ongoing
single-point QC checks. For the functional form of this calculation, refer to 40 CFR Part 58
Appendix A, Section 4.1.3, Equations 3, 4, and 5.
Bias of true NO2 measurements will be independently assessed by conducting an annual
performance evaluation (PE) described in 40 CFR Part 58 Appendix A, Section 3.1.2. Additional
PE assessments will be conducted minimally every 5 years by EPA as part of the National
Performance Audit Program (NPAP) as described in 40 CFR Part 58 Appendix A, Section 2.4.
Bias of meteorological measurements is controlled by ensuring instruments are appropriately
calibrated prior to field deployment and by performing periodic comparison checks to a known
calibrated instrument exposed to the same conditions (whether controlled or ambient) or to
known reference conditions. Once calibrated, meteorological instrument calibration bias will be
verified annually. Note that this calibration verification is separate from the annual instrument
performance audit described in Section CI. 1.1.2. Bias assessment for meteorological instruments
is described below:
• Wind anemometers - bias is assessed for mechanical instruments by rotating the
anemometer shaft at several known rotational speeds and verifying the instrument output
is within the tolerance specified by the instrument manufacturer. The bias of sonic
anemometers is determined by collocation with a calibrated reference anemometer.
Measurement bias will be maintained to within ± 0.2 m/s or ± 5%, whichever is greater.
• Wind vanes - bias is assessed by ensuring the orientation pin is set within specification to
the compass azimuth of true north and that instrument outputs for several orientations
around the 360° compass are within ± 3° of the true setting; this requires determining true
north to within ±1° accuracy. The combined error in the system must be kept to < 5°.
True north can be determined by referencing the current magnetic declination. The
National Oceanic and Atmospheric Administration offers a current magnetic declination
calculator at the following website:
https://www.ngdc.noaa.gov/geomag-web/
• Temperature probes - bias is assessed by comparison to a NIST-traceably certified
thermometer or thermistor. The calibration check is performed at three different
temperatures spaced across the range of expected temperatures experienced at the site.
The temperature probe is to be within ± 0.5°C from the certified reference standard at
each comparison level.
• Precipitation gauges - bias is assessed by adding a known volume of water with a
volumetrically certified device (such as a graduated cylinder) and verifying the
instrument is reporting to within ± 10% of the known added volume.
• Hygrometers - bias is assessed by comparison of the hygrometer to a reference standard
at minimally two (typically four) different humidity levels covering a typical range of 35
to 90% RH. The dew point provided by the hygrometer must be within ± 1.5°C of the
reference standard for RH > 40% and within ± 5% for RH < 40%.
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• Pyranometers - bias is assessed by comparison of the pyranometer to a NIST-traceably
certified pyranometer for one diurnal cycle and must be within ± 5% of the reference
standard for both solar radiation and UV radiation.
• Barometers - bias is assessed by comparison of the barometer to a NIST-traceably
certified barometer or pressure transducer over the course of several consecutive hours.
The average measurements from the barometer over the comparison period must be
within ± 3 hPa of the reference standard.
• Ceilometers - bias is assessed by qualitative review of the derived data products through
visual plots and local user knowledge of expected meteorological conditions and
expected ranges in MLH/PBLH. Such an assessment can quickly identify functional
issues with the ceilometer, which would most likely be visible in unusual variations in the
aerosol backscatter profile plots.
Acceptably low bias in the measurements from each of the individual meteorological instruments
will be verified as described in Section B5.1.4.
Note that instrument bias will be additionally verified independently through assessments
(instrument performance audits - IP As) such as those described in Section CI. 1.1. These
assessments do not replace the routine bias checks described in this section.
A 7.3.5 Sensitivity
Sensitivity must be established for each of the chemical measurements (speciated VOCs and
carbonyls) by experimentally determining the method detection limit (MDL). For true NO2, there
are limitations in the ability to properly generate suitable concentration standards for monitoring
agencies to experimentally determine the MDL; however, monitoring agencies are encouraged to
experimentally determine the MDL when feasible. The MDL for speciated VOCs1 and carbonyls
is to be established annually by analysis of replicate standard samples prepared at a concentration
approximately two- to five-fold the expected MDL. MDLs should be determined for each
measurement method as described in Revision 3 of the PAMS TAD in Sections 4.3, 5.6, and
6.2.9 for speciated VOCs, carbonyls, and true NO2, respectively; the procedure is described
briefly below.
MDLs are determined according to the Method Update Rule revision of the MDL procedure
described in 40 CFR Part 136 Appendix B by analyzing a series of low concentration standard
sample replicates and a series of blanks. The spiked samples and blanks are prepared and
analyzed over the course of three or more different dates and an average and standard deviation
are calculated from the resulting spike data and blank data. The calculated spike standard
deviation is multiplied by an appropriate Student's T statistic according to the number of spiked
samples to calculate an MDL for the spikes, MDLsp. The blank standard deviation is multiplied
by an appropriate Student's T statistic according to the number of blanks and added to the
average blank value to calculate an MDL for the blanks, MDLb. The higher of the MDLsp and
MDLb is reported for the site MDL for the target analyte. Determined MDLs will be determined
annually prior to PAMS season and may not exceed those listed in Table A7-1. Note that for
1 It is understood that CAS auto-GC users will not be able to calculate MDL values without an external calibration
system, and should instead default to the manufacturer MDL of 0.5 ppbC.
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sites that operate year-round or extended monitoring seasons, the MDL will be determined each
year and applied to the subsequent measurements.
Meteorological instruments will meet the resolution specifications listed in Table A7-1.
Sensitivity for meteorology instrument measurements is fundamentally different than for
chemical measurement instruments for which the lowest concentration differentiable from
background is useful. For ambient meteorology measurements, sensitivity is better understood as
resolution, or the ability to differentiate between two similar measurements, since the conditions
to be quantified are not challenging to detect in the same way that low concentrations of a target
chemical analyte are. For example, the ability to discern between temperatures of 24.2°C and
24.6°C is important; however, it is not important to be able to measure the lowest temperature
possible since such is not a concern for ambient monitoring.
A8 Special Training/Certifications
Individuals conducting ambient measurements resulting in data generation (site operators,
laboratory analysts), data verification and validation, and audits/assessments must possess the
skills and education or experience to perform activities for which they are responsible. Specific
requirements are described in the following sections. Management, by way of signature approval
of training records, or equivalent, must verify that staff are competent to conduct all such
activities. Monitoring agencies will detail in this QAPP the requirements and certifications for
staff carrying out the duties described in Section A6.2. Individuals operating instruments,
performing data transformations, and conducting oversight (such as quality assurance and
management personnel) must minimally have read and documented attestation of compliance
with the appropriate quality system documents. Training can consist of attendance at seminars,
courses provided by instrument vendors, online training courses, training videos, and time spent
working with instruments with the intent to become familiar and learn the instruments and
associated software.
Monitoring agency staff must comply with all applicable quality system requirements and will
attest in their training records that they have read and will comply with pertinent quality systems
documents, such as the monitoring agency PAMS QAPP and SOPs describing the duties for
which they are responsible (refer to Section A9).
As PAMS monitoring is not typically conducted year-round, site operations staff should dedicate
time during the non-sampling season prior to PAMS season to refamiliarize themselves with the
pertinent procedures and operation of instruments and equipment. Staff will review and, as
necessary, revise quality systems documents, perform maintenance on equipment, seek training
to maintain skills and proficiency, and must demonstrate continuing proficiency to execute the
activities for which they are responsible.
A8.1 Site Operator Training
Site operators require special training to calibrate, operate, maintain, and troubleshoot
instruments and support equipment needed to make PAMS measurements. Each site operator
will possess the appropriate skills and education to perform their assigned tasks. At the discretion
of the monitoring agencies, instrument vendors may train site operators on how to set up,
calibrate, and operate auto-GCs, carbonyls samplers, and ceilometers during installation. Site
operators will receive training materials and will attend training sessions and online training
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webinars provided by instrument vendors, EPA, and/or experts. Any such training will be
documented (such as program completion certificates, course attendance records, etc.) and
maintained in the staff training records. Management will document their approval of the staff
member's competency to perform their assigned tasks as part of an IDOC process. The IDOC
must be completed before data collection activities may begin. A member of management
(supervisor or similar) and/or QA unit will observe the site operator performing the procedures
as described in the applicable SOP as part of the approval process. Annually thereafter, and
before the beginning of PAMS season, a member of management and/or a QA staff person will
observe site operators performing the procedures to complete a CDOC. An example training
form is included in Appendix D.
Calibration, operation, and maintenance for the various instruments require expertise gained
through training and practice. The operation of the auto-GC and associated equipment is
complex and requires an operator familiar with the fundamentals of gas chromatography and a
thorough understanding of the instrument systems to operate, maintain, and troubleshoot the
auto-GC. Staff will more quickly adapt to the intricacies of the auto-GC if they have prior
experience operating GC systems, generating and evaluating chromatographic data, and working
with VOCs. Auto-GC operators are encouraged to spend time prior to PAMS season with the
instrument and chromatography data system (CDS) to become familiar with the general
operation, calibration procedures, data outputs, and data handling.
The level of training required for conducting carbonyls sampling and operating ceilometers is
less rigorous than for auto-GC operation. Site operators will need to be familiar with the
instrument operation including troubleshooting, software menu navigation, data retrieval,
maintenance, and calibration routines. Operation of other meteorological instruments requires
site technicians to be familiar with instrument operation, maintenance, and typical data outputs.
Meteorological instruments require little intervention aside from regular inspection for proper
operation and lack of interferences (e.g., presence of bird or insect nests) and occasional
maintenance for cleaning or alignment. Maintenance requirements are listed in Table B6-1.
Once site operators are trained and approved by management to perform their assigned tasks,
they may train other staff members to perform similar tasks. Training new site operators will
involve a three-step process consisting of:
1. The trainee observing a trained staff member performing the task,
2. The trainee performing the task under the supervision and assistance of the trained staff
member, and
3. The trainee performing the task independently under observation of the trained staff
member.
As the PAMS Required Site network matures and evolves, procedures and equipment are
expected to be updated and refined. Site operators will seek opportunities for continuing
education and refinement of their skills to maintain competency in their assigned tasks. EPA will
conduct monthly calls and/or webinars in prior to and including the PAMS 2021 season with
PAMS Required Site network monitoring agencies during which training on technical issues and
questions may be covered and individuals may pose questions to the group and seek assistance in
instrument start up, shakedown, and troubleshooting. These training calls and/or webinars may
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be continued in out years following implementation based on training needs indicated by the
PAMS Required Site workgroup.
A8.2 Auditor Training
Monitoring agency quality assurance staff performing assessments (described in Section C) will
not need to be proficient in operating PAMS instruments; however, will be familiar with the
equipment and procedures employed to generate measurement data and with software and
procedures with which data are reviewed, verified, and validated. Auditors will read and
understand the quality system documents, minimally consisting of the monitoring agency PAMS
QAPP and SOPs governing the processes to be assessed, and will complete written attestation
signifying compliance with the quality system (an example form is provided in Appendix D).
EPA intends to provide training materials, audit checklists, and training sessions for auditors
prior to the 2021 implementation. Auditors will attend minimally one training session for PAMS
auditing, subject to training session availability. Staff performing audits need not be intimately
familiar with the operations of the instruments and software functions for generating, evaluating,
and validating measurement data; however, such staff must be able to follow the described
procedures and determine whether the activities as carried out comply with the established
procedures described in the QS documents. Auditors will maintain documentation for attendance
of training sessions (e.g., training classes, webinars, vendor training) and for materials reviewed
(e.g., audit checklists, instrument manuals, and training videos).
EPA expects to develop checklists for conducting TSAs of the PAMS sites and ASLs. These
checklists in concert with TSA training sessions (that EPA is expected to conduct) will be a
resource for auditors to build confidence in conducting PAMS TSAs, IP As, and ADQs.
A8.3 Analytical Support Laboratory Analyst Training
Once the ASL staff member has read the relevant QAPP and SOPs, and documented the
completion and intention of compliance with them, the staff member must demonstrate
proficiency prior to conducting analyses to generate PAMS program data. Individuals conducting
laboratory extraction and analysis for carbonyls will have demonstrated proficiency by
conducting an IDOC prior to performing the applicable laboratory activities. The IDOC will
consist of preparing a set of at least four LCSs and performing the extraction, calibration, and
analysis procedures under observation of a member of QA staff, management (direct supervisor,
or similar), or other trained analyst familiar with the procedure. The observer will ensure that the
procedures were performed properly and review the analysis results to ensure that each LCS
meets spike recovery acceptance criteria (±15% of nominal). The observer will document the
acceptable performance and laboratory management will approve the analyst to independently
perform the analysis by approval signature on the IDOC (checklist, approval form, or similar).
Once the IDOC is completed, the analyst will demonstrate continued proficiency with the
method on an annual basis by performing a CDOC. The CDOC will be met by the analyst in one
of three ways: achieving recovery within the method bias specification (±15% of nominal) for
analysis of an LCS (spiked cartridge) whose concentration of target analytes is blind to the
analyst; acceptable performance on all target analytes for a PT sample; or achieving recovery
within method bias specification (±15% of nominal) for all target analytes on four consecutive
LCSs. Laboratory management will approve the analyst CDOC by approval signature.
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A9 Documentation and Records
The monitoring agency will establish and maintain document control procedures for the timely
preparation, review, revision, approval, issuance, use, retirement, and archival of documents and
records. The categories and types of records and documents that are applicable to the PAMS
Required Site Program are presented in Table A9-1.
NOTE: Monitoring agencies can use this information if applicable but will add
and/or reference their specific document control policies and procedures in this
section.
Documentation and records generated and maintained include:
1. Monitoring agency PAMS QAPP
2. PAMSSOPs
3. Sample collection records in electronic and written format
4. Logbooks and data sheets in electronic and written format
5. Training records
6. Instrument and equipment calibration information
7. Quality assurance documentation (for example, outcomes of TSAs, IP As, and ADQs; and
corrective action plans and reports) in electronic and written format
8. Documentation that supports data review, validation, and certification activities.
Recorded data, whether hand recorded in ink on paper or through electronic entry or captured
through a computer system, will be maintained such that the activities can be reconstructed. The
monitoring agency will have an SOP, combination of SOPs, or similar controlled document that
describe how to execute routine procedures, including, but not limited to, instrument operation,
maintenance, sample collection, and analysis for each of the PAMS measurement methods, data
verification/validation/reporting, corrective action, training, and data management. As
applicable, each SOP will include information on equipment and instruments required,
calibration, quality control activities and acceptance criteria, calculations, and typical corrective
actions for routine nonconformances. Where activities involve a potential physical hazard, safety
precautions will be addressed.
Table A9-1. Pertinent Documents and Records for PAMS Required Site(s)
Category
Record/Document Type
Management and
Organization
Personnel qualifications and training
Quality management plan
Document control policy/procedure
Records retention and archival policies
Site Information
Site characterization file
Site maps/photographs
Annual siting re-evaluation
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Category
Record/Document Type
Environmental Data
Operations (Field and Lab)
QA Project Plan(s) (QAPPs)
Standard operating procedures (SOPs)
IDOC and CDOC records
Field and laboratory notebooks
Sample handling and management, incl. holding time/storage/number
of samples to be collected, etc.
Instrument inspection/maintenance records
Raw Data
Original data (routine and QC)
Sample collection forms
Chain of custody forms
Electronic instrument data (raw, processed, and reprocessed)
Certificates of analysis for standards materials
Calibration certificates for transfer standards
Original observations as recorded in field and laboratory notebooks
Instrument calibrations
Data Management
Validation of data collection, transformation, and reduction
algorithms
Data management plans/flowcharts
Transformed and reduced data
Data review, verification, and validation documentation
Data Reporting
AQS data submission summary reports
AQS data verification reports
Quality Assurance
Control charts
Calibration data, MDL/IDL data etc.
Audit reports for: IPAs, TSAs, ADQs
Corrective action reports and supporting documentation
Network reviews
The monitoring agency will maintain a system (such as a controlled electronic document in an
access-controlled network folder, internal website, or similar) that will list the most current
version of quality system documentation containing the information given in Table A9-1.
Superseded versions of controlled QS documents must be inaccessible such that only the most
up-to-date procedures are performed. All previous versions of QS documents will be archived
and maintained to ensure that measurement data are traceable to the policies and procedures in
place at the time the data were generated, transformed or reduced, and reported.
As the PAMS Required Site Network matures, the national QS documents will require revision
to accommodate lessons learned and best practices. Revisions to the national QS documents will
be handled in a manner that ensures only current approved procedures are available. In order to
ensure that PAMS Required Site monitoring agency and EPA Regional staff are aware of the
changes if a revision to the document cannot be completed and approved in a timely manner, a
quality bulletin (refer to Appendix B) or similar memorandum will be distributed to the PAMS
Required Site stakeholders as described in Section A1.2 to announce the changes and indicate
when the changes are effective. When revisions to the national PAMS Required Site guidance
and QS documents are announced, monitoring agencies will revise their QS documents
accordingly, where applicable.
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A9.1 Recording of Data
Activities conducted to generate reported measurements will be documented in sufficient detail
such that the measurements reported to AQS are traceable (i.e., an independent assessor can trace
a reported value back through collection of the data, transformation of the data, and the certified
standards used to calibrate the instruments). Instrument operators, data validators, and QA
personnel will record data within bound logbooks, on dedicated forms, or within electronic logs,
as appropriate per the monitoring agency document control program. Monitoring agencies will
include the document control program details here or include a reference to their location.
A9.1.1 Paper Records
Documentation requirements for the PAMS Required Site network will follow general good
scientific data recording practices. Observations will be recorded in sufficient detail to
reconstruct the activities and such that original data records are maintained and not obliterated or
erased when corrections or changes are made.
Measurements, observations, and activities will be recorded promptly in indelible ink and will be
attributable to the individual making the entry by signature or initials and include the date the
entry was made. Corrections must be by single line strikeout and must be dated and initialed.
Bound logbooks with consecutively numbered pages or forms specific to the intended use (e.g.,
chain of custody form, field sample collection form, flow verification form, etc.) will be utilized
to ensure the requisite information is captured and recorded. Such forms will be controlled
documents.
A9.1.2 Electronic Records
Original raw data acquired by electronic systems (e.g., instrument acquired raw area counts for
an auto-GC sample collection and analysis), data transformed or reduced within electronic
systems (e.g., adjusting integration parameters for carbonyls analysis by HPLC, or data reduced
within an electronic spreadsheet), and data recorded within electronic logbooks (such as is
available in some data acquisition systems) will be maintained so activities may be reconstructed
and calculations or transformations independently verified.9 Data recorded, transformed, or
reduced in electronic systems will be attributable to the individual recording or evaluating the
data and will indicate the date on which the activity was performed (and recorded, if different). If
so equipped, audit trails will be enabled on software systems in order to ensure modifications to
electronic records are recorded and that the original data are not overwritten.
A9.2 Chain-of-Custody Records
Samples collected for analysis that are packaged and transported to another location (carbonyls
samples) will be accompanied by a chain-of-custody (COC) form that documents how such
media are handled and tracks the integrity of the collection media through the various stages of
transportation and receipt. COC procedures will be described in SOPs specific to the media type
and the approved COC form will be a controlled document within the monitoring agency or
laboratory document control system. Completed COC forms (or a copy thereof) will be retained
by the laboratory as part of the official analytical record.
COC procedures and requirements are detailed in Section B3.1.1. An example COC form
(specific to PAMS carbonyls samples) is included in Appendix C.
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A9.3 QA/QC Records
In addition to documenting routine operations, QA and QC activities must also be appropriately
documented. Such QA/QC activities include:
• Instrument maintenance, calibration, and calibration verification
• Standards certification, recertification, or calibration
• IP As
• TSAs
• ADQs
• PEs
• Supplies and equipment acceptance testing
• Corrective actions
• Data verification and validation
The outcomes of these QA/QC-related activities must be recorded on hard copy forms, in
electronic spreadsheets, electronic pdfs, in data management software systems, or by another
appropriate means as defined in the monitoring agency-controlled document (e.g., QMP, QAPP,
or SOP) governing the activity. Documentation methods include spreadsheets, worksheets, and
data management systems, whether electronic or hard copy.
Records for some of the QA/QC activities described above may only be available as hard copies.
Where possible, these hard copy records will be scanned so that electronic versions can be filed
and maintained with associated electronic air monitoring records.
A9.4 Records Archival and Retention
Records described in Sections A9.1 through A9.3 will be retained minimally for three years as
per the statute of limitations codified in 2 CFR 200.333 and further clarified in Section 5.0 of the
EPA QA Handbook.10 This statute states that records will be maintained for a minimum of three
years from the date the grantee submits the final expenditure report unless otherwise noted or if
the records involve a legal action. Monitoring agencies may prescribe more stringent records
retention schedules provided they minimally meet the requirements in 2 CFR 200.333.
PAMS Required Site Network QAPPs and supporting SOPs will be archived for minimally
10 years following the date that they are superseded. Electronic data such as databases, raw and
processed electronic instrument data, electronic logbooks, etc., will be backed up minimally
monthly to a physically separate storage device (separate hard drive, server, or similar). Archived
electronic data will be stored in a manner such that they are protected from inadvertent alteration
(e.g., password protected, access limited). Once archived, archived data are reviewed or tested
minimally annually to ensure complete records are maintained and data have not been corrupted.
An individual or individuals will be assigned responsibility for records archival, and the person
or persons will be listed here.
A9.5 Sample Retention
The PAMS measurement methods are continuous and do not involve the collection of samples
on to discrete media except for carbonyls. Therefore, sample retention applies only to carbonyls
samples. Once carbonyls samples are extracted, the spent cartridge is no longer useful and can be
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discarded. To afford reanalysis in the event there are problems with the analysis, sample extracts
will be maintained in refrigerated storage until the analysis data are validated and approved or
the 30-day extract holding time has been exceeded. Expired extracts are of little value; however,
in the event expired extracts are analyzed, results reported from such expired extracts require
qualification as "QX" when reported to AQS. Extracts will not be archived and will be disposed
of properly according to hazardous waste procedures established by the laboratory.
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B DATA GENERATION AND ACQUISITION
B1 Sampling Process Design (Experimental Design)
The objective of the PAMS experimental design is to provide an air quality database for use in
ozone prediction model evaluation and refinement. A secondary objective is to characterize
ozone precursor concentrations and temporal patterns and associated meteorological conditions
to assist state and local air pollution control agencies in evaluating, tracking the progress of, and
if necessary, refining control strategies for attaining the ozone NAAQS. The rationale and
description for the sampling design of the approximately 40 Required PAMS sites can be found
in Section 1 of the PAMS Required Site Quality Assurance Implementation Plan (QAIP)
available at the following link on AMTIC:
https://www.epa. gov/ sites/default/files/2019-
11/documents/pams monitoring network and emp plan guidance.pdf
The QAIP describes procedures approved by EPA OAQPS and Regions for applying for
waivers. Waivers, if applicable to the monitoring agency, will be described in the monitoring
agency QAPP and approved by the Region. An example monitoring agency IP including an
example waiver is included in Appendix F.
The following parameters will be measured at PAMS Required Sites. This QAPP describes the
QS for those parameters in bold:
• carbonyls
• meteorological parameters:
• ambient temperature
• vector-averaged wind direction
• vector-averaged wind speed
• atmospheric pressure
• relative humidity
• precipitation
• mixing layer height
• solar radiation
• UV radiation
• speciated VOCs
• true NO2 (note that this parameter may be eliminated from this QAPP if QA
requirements are described in another QAPP)
• NO/NOy
• ozone
NO/NOy and ozone are described simply for convenience; however, the QS for these criteria
pollutant gases is covered under the appropriate monitoring agency QAPP which details gaseous
criteria pollutant monitoring for the NCore network. The submittal and approval dates of the
appropriate QAPP can be found in AQS. The approved QAPPs are to be maintained by the
monitoring agency and a copy is to be kept on file at the EPA Regional office.
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Bl.l Sample Collection Schedule
Sampling at PAMS Required Sites will be conducted June 1 through August 31 of each year, at a
minimum. Monitoring agencies may elect to extend monitoring for PAMS parameters to begin
before June 1 and end later than August 31 and will detail the monitoring period in Section
A7.3.1.1 Parameters will be measured according to the schedule shown in below in Table Bl-1.
Continuous instrument measurements (meteorology, speciated VOCs, O3, trueNCh, and
NO/NOy) will operate continually to measure ambient conditions except during QC checks or
maintenance. Note that meteorology instruments do not typically require ongoing daily QC
checks. However, for the continuous chemical measurement methods, automated routine QC
checks will be performed during the overnight hours and should rotate between specific times to
ensure that there will be a representative ambient measurement for each of the daily 24 one-hour
periods across all days of the week. For example, the nightly auto-GC CCV and blank require
two hours to perform. If always performed from 01:00 to 03:00, there will not be representative
ambient data for that two-hour period. An example rotation schedule would start the QC checks
on Monday at 23:00, Tuesday at 00:00, Wednesday at 01:00 and so on. An example schedule is
described in Section 4.6 of Revision 3 of the PAMS TAD and in the national auto-GC SOPs.
Table Bl-1. PAMS Required Site Sampling Schedule by Parameter
Parameter
Sampling Duration and Frequency
Value Reported
Ozone a
Continuously, daily
Hourly average
True NO2
Continuously, daily
Hourly average
NO/NOv a
Continuously, daily
Hourly average
Speciated VOCs by auto-GC
Hourly 40-minute sample, daily
Hourly average
Carbonyls (TO-11A)
3 sequential 8-hour samples on a l-in-3
days schedule
8-hour average
Formaldehyde (Continuous) b
Continuously, daily
Hourly average
Meteorological Parameters
Continuously, daily
Hourly average
a Monitoring for ozone and NO/NOy are not covered in this QAPP. Please refer to the monitoring agency criteria
pollutant QAPP for associated requirements.
b Continuous formaldehyde monitoring with hourly average concentration reporting can be substituted for the
carbonyl sequential collection of three 8-hour samples every 3rd day. Note that several manufacturers were
developing continuous formaldehyde monitoring instruments at the time of publication of this QAPP.
The time reported for the sample collection is to be the local standard time at the start of sample
collection or the start of the averaged hour, not adjusted for daylight savings time (DST). Hourly
averaging periods will include the beginning of the hour through the beginning of the following
hour. For example, the hourly average represented for 9:00 a.m. covers 09:00:00 through
09:59:59.
B 1.1.1 Carbonyls by TO-11A
Note: For the purposes of this OAPP, it is assumed that PAMS Required Sites will perform time-
integrated sampling for the measurement of carbonyls and will not perform near-real time
continuous monitoring. Instruments capable of continuous measurements are not yet
commercially available for routine monitoring. Further, OA criteria have not been established
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for these instruments for use at PAMS Required Sites. EPA will develop OA OC for continuous
formaldehyde monitors once such are available and have demonstrated appropriate
comparability with Compendium Method TO-11A for formaldehyde measurements.
Carbonyls samples will be collected as three sequential 8-hour samples every third day per the
national sampling calendar available at the following link on AMTIC:
https://www.epa.gov/amtic/sampling-schedule-calendar
These primary sequential carbonyls samples will be collected according to the schedule shown in
Table B1-2:
Table Bl-2. Carbonyls Sampling Schedule
Sequential Sample
Collection Start Time
(local standard time)
Collection End Time
(local standard time)
A
04:00
12:00 (noon)
B
12:00 (noon)
20:00
C
20:00
04:00 (the following day)
This schedule aims to characterize the morning commute in sample A, the evening commute in
sample B, and most of the overnight period in sample C, and will allow for the shifting of the
commuting periods due to DST at sites where DST is observed. Each 8-hour sample will be
collected for 8 hours ± 20 minutes and must begin and end within fifteen minutes of the
designated sampling start or stop time.
In cases where samples and/or sample results are invalidated, a replacement primary carbonyls
sample set (three 8-hour samples) will be collected as described per the make-up policy in
Section A7.3.2.
Target carbonyls analytes are those identified in bold and noted as "carbonyls" in Table B2-1.
All sites will measure and report formaldehyde and acetaldehyde (the two priority carbonyl
compounds) and are encouraged to analyze for benzaldehyde and acetone (optional compounds).
Note that the only exception to this is for sites operating continuous formaldehyde monitors
reporting hourly averages; in such instances only formaldehyde must be measured.
Bl.1.2 Speciated VOCs by Auto-GC
To ensure that 75% of each sample is collected during the scheduled hour, at least 30 minutes of
the 40-minute sampling period will occur during the hour. Sample collection should commence
at the beginning of the hour but must commence no earlier than 10 minutes before the beginning
of the hour and no later than 30 minutes after the beginning of the hour. For example, for sample
collection of the 10:00 hour, sample collection must commence between 09:50 and 10:30 for the
sample to be valid for the 10:00 hour. Sample collection beginning between 30 minutes and 50
minutes after the hour, between 10:30 and 10:50 in this example, must be invalidated.
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Target speciated VOCs analytes are listed in Table B2-1 and are classified as olefin, aromatic,
paraffin, halogenated, monoterpene olefin, alkyne, or alcohol. The site will measure and report
all compounds listed as priority compounds as well as total non-methane organic carbon
(TNMOC). Sites are encouraged to analyze and report the compounds listed as optional. Sites
will indicate in Table B2-1 which optional compounds will be measured and reported.
Bl.1.3 Continuous Measurement Methods
Data collection for continuous true NO2 and meteorological methods will include minimally 45
minutes of ambient data collection during the respective hour (75% of the hour) to be valid.
Hours with fewer than 45 minutes of data collection will not be considered valid hours for data
reporting.
B 1.1.3.1 TrueN02
Ambient true NO2 will be measured continuously except when the NO2 analyzer is undergoing
periodic QC checks (span/zero/precision checks), maintenance, and performance audits. During
these periods, the instrument may be taken offline or data may be flagged to indicate that the
measurements must not be reported as ambient measurement data.
Bl.1.3.2 Meteorological Instruments
Meteorological instruments will record ambient measurements continuously except when an
instrument is undergoing QC checks, maintenance, or performance audits, for which the
instrument will be taken offline or data may be flagged to indicate the measurements must not be
reported as ambient measurement data. QC checks or performance audits for which the
instrument is left in situ and continues to measure ambient conditions may be reported as valid
data; however, if a probe's conditions are altered from the typical measurement configuration,
the measurements will be invalidated.
B1.2 Quality Control Measurements
QC samples are collected and/or analyzed for the chemical measurement parameters (carbonyls,
speciated VOCs, and true NO2), and may be positive controls or negative controls. Positive
controls consist of a sample with a known amount of target analyte for challenging the
measurement method (instrument), such as CCVs, span and precision checks, secondary source
calibration verification (SSCV) standards, and LCS spikes. Negative controls challenge the
measurement method to demonstrate the instrument response remains sufficiently low in the
absence of the target analyte; negative controls include zero air blanks, solvent blanks, and field
QC blank samples such as field blanks and trip blanks. Both positive and negative controls are
prepared and analyzed to demonstrate that the measurement system remains in control on an
ongoing basis; that is, that the measurement system is acceptably calibrated and that
interferences and contamination are acceptably low.
QC activities and associated acceptance criteria are detailed in Section B5 and in Tables B5-1,
B5-2, B5-3, B5-4, and B5-5 for carbonyls field sample collection, speciated VOCs, true NO2,
meteorology, and carbonyls laboratory analysis, respectively.
SLT monitoring agencies and ASLs are encouraged to track QC sample performance with QC
charting. Inspection of QC charts permits the identification of trends or drifts in performance
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which can be addressed before an out-of-control condition occurs (before blanks are
unacceptably high, before positive control recoveries are unacceptably low, etc.).
B2 Sampling and Measurement Methods
This section describes the sampling instruments, procedures for collecting samples, identifies the
sampling methods and equipment including sample preservation requirements, and specific
method and instrument performance requirements such as maximum allowable sample pickup
times for carbonyl cartridges. Also described are actions to take when a failure in the sampling or
measurement system occurs, who is responsible for corrective action, and how corrective action
will be documented.
The monitoring agency will provide a list of makes and models for the measurement parameters
listed in Section Bl. This list can be included here or included by reference (such as an annual
network plan).
NOTE: This OAPP will refer to national SOPs developedfor the PAMS Required Site Network.
Monitoring agencies will follow these reference SOPs and or specify and submit the SOP(s) they
plan to use for the program daring the OAPP approval process. Monitoring agencies will detail
the SOPs the agency and ASL will follow within this OAPP, either within the body of the OAPP
or within a reference document or an appendix to this OAPP.
B2.1 Chemical Parameters
This section describes ambient air sample field collection methods and automated
analyzers/methods used for conducting measurements of chemical parameters in the field (i.e., in
situ). These parameters are listed below in Table B2-1. Three types of chemical parameters are
listed in the table: criteria pollutant gases (italicized), carbonyls (bolded), and speciated VOCs to
be measured by auto-GC (remaining unitalicized and unbolded). Ambient air samples will be
collected through one or more inlet probes. The materials comprising, the siting of, and the
configuration of the inlet probe will comply with 40 CFR Part 58 Appendix E and Section
A7.3.1.2 of this QAPP to ensure the sampled atmosphere is representative of the ambient air in
the geographic area intended to be represented by the site. Briefly, the inlet probe(s) will be
constructed of borosilicate glass or polytetrafluoroethylene (PTFE) or perfluoroalkoxy (PFA)
Teflon® for criteriaB>ollutantJases|For carbonyls and VOCs, inlet probe(s) will be of
borosilicate glass or chromatographic grade stainless steel, or their equivalent. Fluorinated
ethylene propylene (FEP) Teflon® is prohibited as a probe material in 40 CFR Part 58 Appendix
E Section 9(b); however, PTFE and PFA Teflon are not specifically prohibited and are permitted
for carbonyls sample collection. Monitoring agencies are strongly discouraged from employing
Teflon® in their sampling inlet pathways for speciated VOCs. Additional guidance for inlet probe
siting is included in Section 3.3.1.2 of Revision 3 of the PAMS TAD.
The air monitoring instrument inlet can be connected to an inlet probe dedicated to the
instrument or can be connected to an inlet manifold with connections for multiple instruments.
Consideration will be given to the length of the sampling inlet pathway (including the manifold,
if so equipped) and flow rate such that the sample residence time is kept to 20 seconds or less.
Consideration will also be given to minimize intrusion of particulate matter (PM) and condensed
water into the sampling inlet; one method for controlling the latter is by inverting the terminus of
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the inlet and installing a rain shield (such as inverted funnel) on the inlet probe. Air monitors
may be connected to any port on a manifold. Additional sample introduction and collection
guidance is included in Revision 3 of the PAMS TAD, Sections 4.2.2.1, 5.7.2, and 6.2.8 for
speciated VOCs, carbonyls and true NO2, respectively. Monitoring agencies will describe the
inlet composition and configuration for these measurements within this QAPP or within the
specific SOPs.
B2.1.1 Carbonyls by TO-11A
Sampling methods for the collection and analysis of carbonyl compounds by TO-11A are
described in detail in the national PAMS SOPs. The target carbonyl compounds are shown in
bold in Table B2-1. For this method, ambient air is pulled by a vacuum pump through an ozone
denuder to remove ozone. The sampled air scrubbed of ozone is then passed through a silica gel
sorbent cartridge impregnated with DNPH where carbonyls in the air stream react with DNPH to
form hydrazone derivatives. These hydrazones are maintained within the sorbent bed until
extraction at the analysis laboratory. Carbonyls sampling for the PAMS program involves
collecting three consecutive 8-hour samples on a l-in-3-day schedule as described in Table Bl-2.
It is preferable that samples are retrieved as soon as possible after the end of collection; however,
cartridges must be retrieved within 72 hours of completion of the last of the three sequential
samples. Samples must be stored and transported cold (< 4°C) and protected from light.
B2.1.2 Speciated VOCs by Auto-GC
Auto-GC systems will be used for the measurement of speciated VOCs. The auto-GC collects
and preconcentrates VOCs from the sampled atmosphere and subsequently separates the VOCs
for detection via a pair of flame ionization detectors (FIDs). Procedures for the setup, calibration,
operation, maintenance, and shut-down of auto-GCs are described in the following national
PAMS SOPs, which are intended to provide instruction for properly trained instrument
operators:
• SOP for the Analysis of PAMS VOCs in Ambient Air via the Consolidated Analytical
Systems (CAS)/Chromatotec AirmOzone Auto-GC-FID
• SOP for the Analysis of PAMS VOCs in Ambient Air via the Markes Unity-XR Thermal
Desorber with Agilent 7890B Auto-GC-FID
• SOP for the Analysis of PAMS VOCs in Ambient Air via the PerkinElmer TurboMatrix
TD300 Thermal Desorber with Clarus 580 Auto-GC-FID
Additional details on auto-GC sampling methods, including technical guidance regarding
moisture management, are provided in Section 4.2.3 of Revision 3 of the PAMS TAD.
Table B2-1. Priority and Optional PAMS Required Site Chemical Parameters
Priority Chemical
Parameters (Required)1
AQS
Parameter
Code
Compound Class
Optional Chemical
Parameters
AQS
Parameter
Code
Compound Class
1,2,3-trimethylbenzene
45225
aromatic
1,3,5-trimethylbenzene
45207
aromatic
1,2,4-trimethylbenzene
45208
aromatic
1-pentene
43224
olefin
1-butene
43280
olefin
2,2-dimethylbutane
43244
paraffin
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Priority Chemical
Parameters (Required)1
AQS
Parameter
Code
Compound Class
Optional Chemical
Parameters
AQS
Parameter
Code
Compound Class
2,2,4-trimethylpentane
43250
paraffin
2.3,4-trimethylpentane
43252
paraffin
Acetaldehyde
43503
carbonyl
2,3-dimethylbutane
43284
paraffin
Benzene
45201
aromatic
2,3-dimethylpentane
43291
paraffin
eis-2-butene
43217
olefin
2,4-dimethylpentane
43247
paraffin
ethane
43202
paraffin
2-methylheptane
43960
paraffin
ethylbenzene
45203
aromatic
2-methylhexane
43263
paraffin
ethylene
43203
olefin
2-methylpentane
43285
paraffin
formaldehyde
43502
carbonyl
3-methylheptane
43253
paraffin
isobutane
43214
paraffin
3-methylhexane
43249
paraffin
isopentane
43221
paraffin
3-methylpentane
43230
paraffin
isoprene
43243
olefin
acetone
43551
carbonyl
m&p-xylenes
45109
aromatic
acetylene
43206
alkyne
m-ethyltoluene
45212
aromatic
cis-2-pentene
43227
olefin
n-butane
43212
paraffin
cyclohexane
43248
paraffin
n-hexane
43231
paraffin
cyclopentane
43242
paraffin
n-pentane
43220
paraffin
isopropylbenzene
45210
aromatic
o-ethyltoluene
45211
aromatic
m-diethlybenzene
45218
aromatic
o-xylene
45204
aromatic
methylcyclohexane
43261
paraffin
p-ethyltoluene
45213
aromatic
methylcyclopentane
43262
paraffin
propane
43204
paraffin
n-decane
43238
paraffin
propylene
43205
olefin
n-heptane
43232
paraffin
styrene
45220
aromatic
n-nonane
43235
paraffin
toluene
45202
aromatic
n-octane
43233
paraffin
trans-2-butene
43216
olefin
n-propylbenzene
45209
aromatic
ozone
44201
criteria pollutant gas
n-undecane
43954
paraffin
true NO2
42602
criteria pollutant gas
p-diethylbenzene
45219
aromatic
total non-methane
organic carbon
43102
total VOCs, non-
methane
trans-2-pentene
43226
Olefin
a-pinene
43256
monoterpene olefin
fS-pinene
43257
monoterpene olefin
1,3 butadiene
43218
olefin
benz aldehyde
45501
carbonyl
carbon tetrachloride
43804
halogenated
ethanol
43302
alcohol
tetrachloroethylene
43817
halogenated
1 Bold indicates a carbonyl and italics indicates a criteria pollutant gas.
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B2.1.3 True NO2 by CAPS or Photolytic Conversion to NO with Chemiluminescent Detection
An FRM/FEM analyzer will be employed for measurement of true NO2 per the PAMS National
SOP:
• Standard Operating Procedure for the Analysis of True Nitrogen Dioxide (NO2) in
Ambient Air for the Photochemical Assessment Monitoring Stations (PAMS) Network
EPA has designated the following instrument methods as FEMs for NO2 analysis:
¦ FEM EQNA-0514-212 - Teledyne Advanced Pollution Instruments (API) Model T500U
CAPS NO2 Analyzer
¦ FEM EQNA-1013-210 - Environnement S.A. AS32M CAPS N02 Analyzer
¦ FEM EQNA-0217-242 - Ecotech Serinus 60 CAPS N02 Analyzer
¦ FEM designation available from supplier - Aerodyne Research, Inc. CAPS NO2 Monitor
¦ FEM EQNA-0320-256 - Teledyne API Model N500 CAPS N02/N0x/N0 Analyzer
¦ FEM EQNA-0512-200 - Teledyne API Model T200UP Photolytic Conversion NO2
Analyzer
The CAPS true NO2 analyzer ingests a sampled air parcel and using a specific wavelength of
light, determines the concentration of NO2 in the air parcel relative to the loss of signal in the
instrument optical cell. For photolytic conversion instruments, the instrument employs two
channels, one channel that converts NO2 to NO at a precise wavelength of light efficient for
converting NO2 to NO with few interferences, and one channel without conversion, and
measures the concentration of NO2 by difference using a chemiluminescent detector.
B2.2 Meteorology
Meteorology measurements will include the parameters listed in Table B2-2.
Table B2-2. Meteorological Parameters
Parameter
AQS
Parameter
Code
Duration
AQS
Duration
Code
Example
Reported Unit3
AQS
Unit
Code3
Ambient Temperature
62101
hourly average
1
°C
17
Relative Humidity
62201
hourly average
1
% relative humidity
19
Barometric Pressure
64101
hourly average
1
millibar (hPa)
16
Wind Speed
61103
hourly average
1
m/s
11
Wind Direction
61104
hourly average
1
degrees compass
14
Solar Radiation
63301
hourly average
1
Watt/m2
79
Ultraviolet Radiation
63302
hourly average
1
Watt/m2
79
Precipitation
65102
hourly average
1
mm
29
Mixing Layer Height
61301
hourly average
1
m
58
a Listed units are one of several standard units accepted by AQS for the given parameter. Monitoring agencies may
report measurement data in any standard unit accepted by AQS.
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These measurement methods will meet the criteria specified in Table 0-1 of Quality Assurance
Handbook for Air Pollution Measurement Systems. Volume IV - Meteorological Measurements
(EPA-454/B-08-002) available at the following link:
https://www.epa. gov/ sites/default/files/2021 -
04/documents/volume iv meteorological measurements.pdf
Results will be measured continuously and reported as the hourly average. Mixing layer height is
currently not covered in Table 0-1 of Quality Assurance Handbook for Air Pollution
Measurement Systems. Volume IV - Meteorological Measurements (EPA-454/B-08-002). At the
time of publishing this document, EPA is finalizing a QAPP for ceilometers and anticipates
revising the meteorological measurements handbook soon.
B3 Sample Handling and Custody
Sample handling procedures apply to chemical parameter measurements and must be
consistently followed to ensure reported concentrations meet the MQOs. Chemical analysis
methods for the PAMS Required Site measurements are continuous with the exception of
carbonyls by TO-11 A; therefore, custody requirements only apply to carbonyls sample
collection, handling, and analysis.
Sample custody procedures are required to avoid misplacement of samples or confusion of one
sample with another, and to provide documentation to assist in identification and resolution of
instances where sample identity or integrity is called into question. A sample is considered to be
in custody if it is in one's actual physical possession or stored in a secured area restricted to
authorized personnel. Monitoring agencies will specify the sample handling and custody policies
and procedures in their individual QAPP or will include by reference.
B3.1 Carbonyls by TO-11A
New cartridges will be stored at < 4°C upon receipt. New Waters cartridges are typically shipped
at ambient temperature and Supelco cartridges are typically shipped at sub-ambient temperatures.
Both cartridge types are typically provided sealed individually in a foil pouch. To maintain
cartridge integrity and limit potential contamination, the sealed foil cartridge storage pouch will
not be opened until the cartridge is to be used in the field or laboratory. Moreover:
• Cartridges should only be handled with gloved hands (chemicals from hand sanitizers,
lotions, etc., can contaminate sample cartridges).
• Markers containing volatile solvents (e.g., permanent markers such as Sharpie®) will not
be used for marking on foil storage pouches. Ball-point pens or printed stick-on labels are
preferred.
• Cartridges will be labeled in such a manner to uniquely identify the cartridge, i.e., to
permit the identification of the sampling date, time, and whether it is a primary sample or
field QC sample (precision sample [such as collocated or duplicate], field blank, or trip
blank).
• Cartridge storage areas will be free of carbonyls. Climate-controlled storage units will not
be used for storage of solvents or carbonyl-containing solutions or standards.
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Upon retrieval, each field-collected cartridge must be sealed in its individual foil pouch, and
placed immediately in refrigerated storage (e.g., refrigerator onsite or cooler with ice packs).
Collection details will be documented appropriately on the sample collection form (whether hard
copy or electronic) and sample storage information will be recorded on the COC form or similar
form or database (such as a laboratory information management system [LIMS]). To ensure that
samples arrive at the laboratory under refrigeration, samples will be hand-carried or shipped by
overnight courier/shipper. Experience has shown that extended shipping times will result in
samples arriving at the laboratory at elevated temperatures (> 4°C).
B3.1.1 Chain of Custody
Blank cartridge media may originate at the analysis laboratory; therefore, COC procedures may
be prescribed by the ASL. Regardless of the origin of the new cartridge media, each cartridge,
whether an ambient sample or field QC sample (such as a trip blank or field blank) will be listed
on a COC form documenting the transfer of the sample cartridges from their origin, through
collection, and transport to and receipt by the analysis laboratory. The following information
must minimally be recorded on the COC form (an example form is included in Appendix C):
• Origin of cartridges (e.g., analysis laboratory or field office)
• Transfer of cartridges between individuals - dates, times, and signatures of individuals
relinquishing and receiving cartridges
o Relinquishing cartridges to site operator (either by handoff or shipment by
courier)
o Receipt of cartridges by site operator
o Relinquishing of sampled cartridges by site operator following retrieval (for
handoff to analysis laboratory or shipment with courier)
Note: Shipping couriers are not expected to sign COC forms. The individual
relinquishing the samples to the shipper/courier will indicate
relinquishment to the shipper/courier on the COC form. Custody is
presumed to be with the courier until received at the laboratory.
o Receipt of field-collected cartridges by analysis laboratory
• Unique identifier(s) for each sample, sample collection date(s), and site(s) location
information
• Storage of cartridges at each point during transfer between individuals, including during
shipment
o Storage of field-collected cartridges at the monitoring site, if applicable (e.g.,
stored at < 4°C in onsite refrigerator, etc.)
o Shipping conditions (e.g., on ice packs) and associated information for tracking
or evaluating the shipping conditions - such as thermometers placed in a
shipping cooler
o Upon receipt at the laboratory - document thermometer used for measuring
temperature as received and location for storage within laboratory (e.g., uniquely
identified refrigerator)
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Note that the convention for recording custody information for the samples can include recording
transfers and storage on the field collection data sheet; however, it may be more convenient to
include a separate COC form for each shipment that encompasses all samples in the shipment. A
separate dedicated COC form reduces the number of instances where staff transferring cartridge
custody are required to sign (sample custodians need only sign one or two COC forms rather
multiple field collection forms).
Laboratory sample custodians, or designated individuals responsible for assuring sample
custody, will ensure that sample custody documentation is complete. Site operators will be
contacted, as appropriate, to complete missing information. COC documentation will be
maintained in accordance with Section A9.
B4 Analytical Methods
The analytical methods to be employed for the PAMS Required Site Network covered by this
QAPP include methods for the determination of carbonyls, speciated VOCs, and true NO2.
B4.1 Carbonyls by TO-11A
Samples collected for carbonyls analysis (refer to Section B2.1.2) will be extracted and analyzed
per EPA Compendium Method TO-11A and will meet the performance specifications listed in
Table B5-5. This method is described in the national SOPs for the collection of analysis of
carbonyls for the PAMS Required Site Network, which describe the procedures for solvent
extraction of derivatized carbonyl-hydrazones collected on the DNPH cartridge samples, analysis
of these extracts by HPLC or UHPLC with UV detection, and the necessary QC procedures.
Ambient air and QC samples must be extracted for analysis within 14 days of collection. Extracts
are then analyzed by HPLC or UHPLC with UV at 360 nanometers (nm) within 30 days of
extraction and the carbonyl concentrations in the ambient air sample calculated from the
measured concentrations in the sample extracts and the volume of air sampled onto the cartridge.
Alternative detectors (such as time-of-flight [TOF]) and alternative wavelengths (e.g., 365 nm)
may be employed, if method performance criteria (listed in Table B5-5) are met.
B4.2 Speciated VOCs by Auto-GC
Auto-GC systems will be used for the analysis of VOCs. The auto-GC systems collect and
preconcentrate VOCs from the ambient atmosphere and subsequently separate the VOCs for
detection by FID. Procedures for the setup, calibration, operation, and shutdown of auto-GCs are
described in PAMS Required Site SOPs listed in Section B2.1.2. Analysis of speciated VOCs by
auto-GC is considered a continuous method, therefore there are no discrete samples collected on
media which may be retained.
Additional details on auto-GC sampling methods, including technical guidance regarding
moisture management, are provided in Section 4.2.3 of Revision 3 of the PAMS TAD.
B4.3 True NO2 by FEM
True NO2 analyzers approved as FEMs will be employed for the analysis of true NO2. The
analyzers continuously sample ambient air routed through an in-line particulate matter (PM)
filte r; therefore no discrete samples are collected on media which may be retained.
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The analyzers are calibrated for NO2 response by providing the analyzer with a zero-
concentration gas and an upscale concentration of NO2 of approximately 80% of the desire
measurement range. A multi-point verification (MPV), which involves analysis of a ze:
concentration point and four upscale standard NO2 concentrations, is needed before an
instrument.
desired
zero
tnd
to establish "as-found" and "as-left" conditions of the
Following minimally every 14 days thereafter, the analyzer is subject to a zero/span
check to verify ongoing instrument calibration. See Table B5-3 for QC acceptance criteria
B5 Quality Control
QC is the overall system of technical activities that measures the performance of an ongoing
process against established standards to verify that such performance meets the stated
requirements established by the data user or stakeholder. In the case of the PAMS Required Site
Network, QC activities ensure that the quality objectives and criteria for measurement data, as
discussed in Section A7, are maintained so that the PAMS Required Site Program DQO can
ultimately be met. QC checks and procedures will be performed at a frequency sufficient to
ensure data of adequate quality are obtained while minimizing loss of data when
nonconformances occur.
B5.1 Quality Control for Field Activities
QC for field activities relate to carbonyls sample collection, speciated VOC analysis, true NO2
analysis, and meteorological parameters.
B5.1.1 Quality Control for Carbonyls Sample Collection
Carbonyls sample collection QC includes the performance of quality checks on the sampling
instrument to ensure the instrument is not imparting a positive bias (i.e., contaminating) to the
collected samples, the instrument flow control is accurate, and the instrument clock is accurate.
Carbonyl field QC samples include, as described in Table B5-1 and in the carbonyls sample
collection SOP, field blanks and trip blanks, which characterize the level of contamination
attributable to sample handling and transportation, and duplicate and/or collocated samples,
which characterize the precision between samples collected from the same air mass.
For flow controller calibration verification and clock accuracy, corrective action will be taken
immediately when nonconformances are observed. When clock setting deviations are noted, the
clock should be reset and the offset should be applied to the sample start and stop times. For
example, if the carbonyls sampler clock shows 11:06 a.m. when the time is 10:59 a.m., the
operator should reset the clock and subtract seven minutes from the sample start and stop times
recorded in the sample collection records. For the positive bias challenge (as described in Section
A7.3.4), compliance with acceptance criteria must be attained prior to deploying the sampling
instrument for sample collection. A positive bias challenge is recommended if instrument
contamination is suspected (such as would be indicated by poor precision for duplicate or
collocated samples or if unusually elevated concentrations are reported). The need for follow up
corrective action for field blank, trip blank, or collocated or duplicate sampling criteria failures
will not be apparent until analysis results are completed. Root cause analysis will be performed
as soon as possible for field QC sample nonconformances, and efficacy of corrective actions will
be evaluated by collection of follow-up field QC samples.
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Table B5-1. Carbonyls Field Quality Control Parameters
QC Parameter
Detail
Required
Frequency
Acceptance Criteria
Recommended
Corrective Action
Positive Bias
Challenge (zero
air challenge)
Collection of an 8-
hour sample of
humidified zero air
to investigate
contamination
contributed by the
sampler
Prior to the
beginning of every
PAMS season
following
instrument
maintenance
(ozone denuder
recharge/
replacement,
particulate filter
change, etc.)
All target compounds
<0.20 |ig/cartridge
greater than co-collected
reference sample for
acetaldehyde and
formaldehyde
Repeat bias challenge
following further
cleaning which could
include flushing with
humidified zero air,
replacement of flow
path components, etc.
Mass Flow
Controller
Calibration
Establishment of the
MFC slope and
intercept by
comparison to a
flow transfer
standard
Annually
(preferably at the
beginning of each
PAMS season) and
when flow
verification checks
fail criteria
Flow verification
immediately following
calibration must be
within ±10% of flow
transfer standard
Recalibrate flow
controller. If problem
persists, investigate for
leaks, blockage in flow
path, etc. May require
replacement of MFC or
other instrument parts.
Mass Flow
Controller
Calibration
Verification
Verify sampling
flow of each channel
at the sampling flow
setting
Minimally every
30 days during
PAMS season
Within ±10% of flow
transfer standard
Recalibrate flow
controller and verify
within proper
specification. Qualify
all previous samples
since the last acceptable
flow check or
calibration as "W" and
"LK" (reported
concentration biased
high for flow
verification results
biased low) or "LL"
(reported concentration
biased low for flow
verification results
biased high) as
appropriate in AQS.
Clock Accuracy
Verify clock
accuracy against a
known accurate time
standard
Each sampling
event
Within ±5 minutes of the
true reference time
Reset clock to correct
time. Apply offset to
sample start/stop times.
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QC Parameter
Detail
Required
Frequency
Acceptance Criteria
Recommended
Corrective Action
Field Blank
Blank cartridge
installed in a
sampling channel for
five to ten minutes
Twice monthly
(approximately
every 14 days)
during PAMS
season
Measured mass per
cartridge (|ig/cartridge):
- Acetaldehyde < 0.40
- Formaldehyde < 0.30
- Acetone < 0.75
- Sum of other
compounds <7.0
Investigate sources of
contamination in
handling and transport.
Qualify associated field
collected samples as
"FB" in AQS.
Associated samples are
those in the shipment
with the field blank and
since the most recent
acceptable field blank.
Trip Blank
blank cartridge
accompanying
collected samples to
and from the field
site
Not required,
recommended
monthly -
monitoring
agencies will
specify intent and
frequency for
collecting trip
blanks
Measured mass per
cartridge (|ig/cartridge):
- Acetaldehyde <0.10
- Formaldehyde < 0.15
- Acetone < 0.30
- Other individual
compounds <0.10
Investigate sources of
contamination in
handling and transport.
Qualify associated field
collected samples as
"TB" in AQS.
Associated samples are
those in the shipment
with the trip blank.
Sample Retrieval
samples are
retrieved, capped,
protected from light,
and stored at < 4°C
each sampling
event
within 72 hours of end of
3rd sequential sample
(whose sampling is
nominally completed at
4:00 a.m.)
Qualify associated data
as "HT" in AQS.
Duplicate Sample
Collection
collection of a
separate cartridge
through a common
inlet probe
concurrently with a
primary 8-hour
sample
Optional - 10% of
primary sampling
events -
monitoring
agencies will
specify intent and
frequency for
collecting duplicate
samples
Relative percent
difference < 20% for
compounds >0.5
Hg/cart ridge
Qualify both samples as
estimated "QX" in
AQS.
Collocated
Sample
Collection
collection of a
separate cartridge
through an
independent inlet
probe concurrently
with a primary 8-
hour sample
Optional - 10% of
primary sampling
events - monitoring
agencies will
specify intent and
frequency for
collecting
collocated samples
Relative percent
difference < 20% for
compounds >0.5
Hg/cart ridge
Qualify both samples as
estimated "QX" in
AQS.
B5.1.2 Quality Control for Speciated VOCs Collection and Analysis
QC processes for speciated VOC collection and analysis, as described in Table B5-2 and replicated
in the speciated VOCs measurement SOP, are designed to demonstrate that the instrument is
sufficiently free of contamination and interferences; to establish the carbon response calibration of
the two FIDs within the instrument; to independently verify the calibration for compounds
representing the molecular weight range of the PAMS priority VOCs; and to confirm that the
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instalment's performance is acceptable on an ongoing basis. System performance QC checks
involve verifying the bias criteria are met for representative compounds across the molecular
weight range and ensuring that instrument contamination and carryover are sufficiently low.
PAMS VOCs in ambient air are typically measured at concentrations less than 2 ppbC, therefore, it
is important for the calibration to include a low concentration level (approximately 1 ppbC) to
properly characterize the instrument response at such low concentration. The next highest
concentration will be approximately 5 ppbC. While approximately 25 ppbC should be sufficient to
capture the majority of measured PAMS VOCs, agencies have latitude to select the concentration
of the high calibration standard.
Table B5-2. Speciated VOCs Field Quality Control Parameters
QC
Description
Required
Acceptance
Recommended Corrective
Parameter
Frequency
Criteria
Action
Initial
Multi-point
Initially at the
Linear regression
Prepare new calibration. It may be
calibration
calibration of the
beginning of
with non-zero
necessary to investigate for system
(ICAL)
auto-GC with
PAMS season.
y-intercept must
contamination or interferences
minimally a
after maintenance
show r2 of > 0.99.
resulting in suppression or
representative
(such that response
Also
enhancement of analytes. System
hydrocarbon for each
is impacted).
intercept/slope
leaks and trap degradation may
GC column-FID
following failing
< l.OppbC,
impede a proper calibration as well
combination (e.g.
continuing
whichever is lower.
as carryover from samples or
propane and
calibration checks.
RSD of determined
standards. Improperly conditioned
benzene). Minimum
and at the
RFs must be <10%.
traps may contribute
of three
conclusion of
Each standard level
chromatographic artifacts. PAMS
concentrations
monitoring each
evaluated against
data must not be reported unless
covering
PAMS season.
the calibration curve
calibration meets criteria.
approximately 1.0 to
Agencies may
must be within 20%
25 ppbC. At their
analyze the
of the nominal
discretion, agencies
primary calibration
concentration. If all
may use other high-
standard weekly as
of the above criteria
level concentrations
an additional check
(r2.
(e.g., 50 or 80
to monitor system
y-intercept/slope,
ppbC).3
performance - not
required.
RF RSD, and
standard ±20% of
nominal) are met,
the calibration may
utilize the average
RF. Measurements
exceeding the
calibration range
will be qualified as
"EH".
System
Analysis of
Prior to ICAL, and
All target VOCs
Analyze another blank, if possible.
Blank (SB)
humidified zero airb
every 24 ± 4 hours
must be < the
to investigate potential carryover
to ensure the system
of operation
determined MDL or
from high concentration sample.
is sufficiently clean
following or
0.5 ppbC, whichever
Investigate system for
for continued
preceding the CCV
is lower.
contamination. Unless technical
analysis.
(preference is to
follow the CCV to
ensure absence of
carryover before
justification is provided to explain
nonconformance, qualify as "LB"
in AQS all samples for affected
compounds since the last passing
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QC
Parameter
Description
Required
Frequency
Acceptance
Criteria
Recommended Corrective
Action
analyzing ambient
samples).
SB.
Second
Source
Calibration
Verification
(SSCV)
Analysis of a known
standard prepared
from a stock gas
including target
analytes across the
molecular weight
range from a supplier
different from the
stock gas (primary
standard) for
preparing the ICAL.
This check
independently
verifies the quality of
the ICAL for
compounds across
the molecular weight
range.
Immediately
following ICAL
and minimally
weekly thereafter -
may serve as the
CCV.C
All primary
calibration target
VOCs must recover
within ±30% of the
expected nominal
concentration.
Analysis cannot commence if
propane (or butane) or benzene (or
toluene) fail in the SSCV
immediately following the ICAL.
Investigate for discrepancy
between ICAL and SSCV.
Investigate chromatogram for
retention time shifts which may
result in peak misidentification.
Investigate for instrument
contamination resulting in
co-eluting peaks. Investigate for
system leaks or trap malfunction
resulting in low recovery. Unless
technical justification is provided
to explain nonconformance,
minimally qualify as "QX" and
potentially invalidate as "AS"
samples for affected compounds
since the last acceptable SSCV.
Clock
Accuracy
Verify clock
accuracy against a
known accurate time
standard
Weekly,
recommended to
check each site
visit
Within ±5 minutes
of the time standard
Reset clock to correct time. Adjust
data timestamp accordingly where
possible. Ensure adjusted sampling
start times are no earlier than 10
minutes before the hour and no
later than 30 minutes after the
hour. Invalidate sample hours that
do not conform.
Continuing
Calibration
Verification
(CCV)
Analysis of a known
standard containing
compounds
representing the
molecular weight
range & prepared
within the calibration
curve to demonstrate
the instrument
calibration remains
within tolerance. Can
include multi-analyte
calibration gas or
single-analyte
permeation tubes.
Concentration of
CCV should be
approximately 2-5
ppbC for target
analytes.
Every 24 ± 4 hours
of operation
All target VOCs
must recover within
±30% of the
expected nominal
concentration.
Investigate chromatogram for
retention time shifts which may
result in peak misidentification.
Investigate for instrument
contamination resulting in co-
eluting peaks. Investigate for
system leaks or trap malfunction
resulting in low recovery. Unless
technical justification is provided
to explain nonconformance,
qualify as "QX" in AQS all
samples for affected compounds
since the most recent passing
CCV. Invalidation as "AS" may be
required at analyst discretion if
compound recovery is
exceptionally high or low.
Retention
Analysis of a 59-
Minimally weekly
All target VOCs
Review previous week's ambient
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QC
Parameter
Description
Required
Frequency
Acceptance
Criteria
Recommended Corrective
Action
Time
Standard
(RTS)
component blend of
VOCs in the ~2 to 60
ppbC range to verify
established retention
time windows.
must be within the
established retention
time windows.
and QC check sample data to
evaluate events resulting in
retention time shift. May require
reassigmnent or adjustment of
retention time windows and
reprocessing of data collected
since the most recent CCV or RTS.
Unless technical justification is
provided to explain
nonconformance, associated
ambient sample data will be
invalidated as "BH" for
compounds whose identities
cannot be confirmed.
Precision
check
Replicate analysis of
the CCV to evaluate
the reproducibility of
the analysis -
replicates are
analyzed sequentially
(back to back).
Weekly
Absolute relative
percent difference
for each target VOC
must be
< 25% on a week-
to-week basis.
Investigate system for carryover,
contamination, leaks, or
suppression, as indicated by trends
in compound behavior. Qualify
ambient sample data for affected
compounds since the last passing
precision check as "QX" in AQS.
a For CAS auto-GC users, it is suggested to use some combination of 4-, 5-, 7-, 9-, and 15-minute calibration gas
injections to meet the three minimum concentrations and stay within the required 1-25 ppbC concentration level.
Users will likely see the best results by performing blanks in between each calibration level.
b CAS auto-GC users should not humidify zero air and calibration gas streams, per manufacturer specification.
0 If using the SSCV source for CCV, only review CCV analytes.
While FID response has been established to be linear over large concentration ranges, instrument
preconcentration capture and desorption of the target compounds do not behave linearly at low
and high concentrations, particularly for very volatile (e.g., ethane, ethylene) compounds and
those with higher boiling points (1,2,4-trimethylbenzene, dodecane). Nonlinear performance may
be more pronounced when trap materials have aged. For this reason, the daily CCV will include
a suite of compounds representing the molecular weight range (C2 to C10). Several analytes are
known to be problematic (recovered less than 70% of the theoretical concentration) with the
carbon-response calibration method. Acetylene, alpha-pinene, and beta-pinene are known to
exhibit degradation in standard cylinders and/or suffer poor preconcentration performance.
Additional compounds that show poor integration include m & p-diethylbenzene,
1,2,3-trimethylbenzene, 1,3,5-trimethylbenzene, cis-2-butene, and 1,3-butadiene.
Styrene is known to show poor correlation with the certified concentration in standard cylinders.
Instrument operators need not take stringent corrective action if QC samples exhibit low
recovery for these four compounds. The agency will document the low recovery of these
compounds and will qualify the associated ambient concentration data when reporting to AQS.
B5.1.3 Quality Control for True NO2 Analysis
True NO2 analysis QC includes the performance of quality checks on the true NO2 analyzer
sampling instrument to ensure the analyzer calibration is within the defined specifications, the
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zero setting of the analyzer has not drifted outside the acceptance window, and that the flow
controllers, and, if so equipped, the ozone generator, of the dynamic dilution calibrator (DDC)
employed to calibrate the analyzer are operating properly and within the prescribed tolerances.
True NO2 QC activities include, as described in Table B5-3 and in the true NO2 analysis SOP, an
VIPV, zero/span checks, and zero/span/precision checks for the NO2 analyzer and flow
verification checks and ozone generator calibration verifications for the DDC.
Table B5-3. True NO2 Quality Control Parameters
QC Parameter
Description
Required
Frequency
Acceptance
Criteria
Recommended
Corrective Action
Calibration
Setting zero and span levels
on the true NO2 analyzer by
introducing zero air and an
NO2 standard at 80% of the
desired measurement range
covering the expected
range of ambient
measurements (e.g., 160
ppb NO2 for a
measurement range of 0 to
200 ppb NO2)
Initially when
deployed,
minimally every
365 days,
following
maintenance to
the instrument
expected to alter
the instrument
response,
following
operation
interruption of
several days (e.g.,
48 hours), and
following failing
span check or
zero check
None. Verified
by MPV.
Repeat calibration if
indicated by MPV. It
may be necessary to
investigate for system
contamination or
interferences resulting in
suppression or
enhancement (check
filters, perform leak
checks, clean mirrors,
etc.)
Multi-point
Verification (MPV)
Introduction of a zero and
four upscale NO2
concentration points
covering the measurement
range, (e.g., 0, 175, 125,
75, and 25 ppb)
Immediately
following
establishing a new
calibration.
Linear
regression of
the
measurements
plotted against
the theoretical
must show r2 of
> 0.995 and
have an
x-intercept
within ± 0.2 ppb
NO2 of the
origin. Percent
difference of
each standard
measurement
must be within
±15% of the
theoretical
concentration.
Repeat verification. It
may be necessary to
investigate for system
contamination or
interferences resulting in
suppression or
enhancement of analytes.
Recalibration may be
necessary.
Zero/Span Check
Analysis of zero air and
span NO2 standard (-80%
of measurement range) to
Reauired evervM
days. More
frequent chccfl
Zero drift must
be less than ±
0.3 ppb.
Repeat zero and span
checks to confirm.
Investigate svstem for
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QC Parameter
Description
Required
Frequency
Acceptance
Criteria
Recommended
Corrective Action
monitor for drift in zero
and span levels. Checks are
performed on analyzer in
as-is condition before
modifying instrument
settings.
are recommended.
Span level must
be within ±15%
of the
theoretical
concentration.
contamination, leaks, or
other causes of drift.
Qualify or invalidate
data since the last
passing QC check.
Perform calibration and
MPV.
Opti
Be
Zero/Span/Precision
Check
Verification performed by
analyzing a zero and two
standard NO2 concentration
levels - span point at
approximately 80% of the
measurement range and a
precision point in the lower
1/3 of the measurement
range (e.g., 160 and 50
ppb, respectively for a
measurement range of 0 to
200 ppb)
ional
commend
minimally ever
14 days or mor
frequently.
Zero drift must
be less than ±
0.3 ppb.
Span and
precision levels
must be within
±15% of their
theoretical
concentration.
Repeat
Zero/Span/Precision
Verification to confirm.
Investigate system for
contamination, leaks, or
other causes of drift.
Qualify or invalidate
data since the last
passing QC check.
Perform calibration and
MPV.
Dynamic Dilution
Mass Flow
Controller (MFC)
Check
Verification of diluent gas
and standard gas channel
MFC calibration against a
NIST-traceably certified
flow transfer standard
Quarte™
90 days)
(every
Flows covering
the 10 to 90%
of each MFC
(or bracketing
range of flows
employed) must
be within ±2%
of the flow
transfer
standard
Recalibrate (adjust) the
slope and intercept of the
MFC per the
manufacturer
instructions and repeat
verification. If
verification still cannot
meet acceptance, MFC
may require repair
DDC Ozone
Generator
Calibration
Verification
Verification of ozone
generator calibration
against a Level 1 or Level 2
ozone standard
Quarterly (every
90 days).
Required only
when conventior
of generation of
N02 standard ga
is accomplish
by gas pha
titration (GPT) (
ozone with NO.
Ozone generator
performance
will be
described in
QAPP
governing
ozone
monitoring.
Recalibrate (adjust) the
ozone generator slope
and intercept per the
manufacturer
instructions and repeat
verification. If
verification still cannot
meet acceptance, ozone
generator may require
repair.
B5.1.4 Quality Control for Meteorology
Meteorological instruments require minimal intervention and maintenance once configured and
calibrated, therefore it is anticipated that meteorology parameters will be measured at each PAMS
Required Site year-round. QC procedures for meteorology measurements consist of the initial
calibration and an annual calibration check. These calibration checks and the associated acceptance
criteria are shown in Table B5-4, which are replicated in the appropriate SLT monitoring agency
SOPs. For all measurements, if the indicated acceptance criteria are exceeded, the instrument
calibration will be adjusted to match the reference standard.
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Note: Table B5-4 is consistent with EPA's Quality Assurance Handbook for Air Pollution
Measurement Systems, Volume IV-MeteorologicalMeasurements. EPA recognizes that this
handbook was last revised in 2008 and may not be representative of current meteorological
instrumentation. Air agencies should consult with their EPA Regional Office regarding any potential
deviations from these acceptance criteria until the handbook is revised.
Table B5-4. Quality Control Parameters for Meteorology Measurements
Meteorology
Parameter
Calibration Check Standard
Required
Frequency
Acceptance Criteria
Recommended
Corrective
Action
Ambient
Temperature
Verification in a water bath or
dry well against a NIST-
traceable thermistor or
thermometer at three points
bracketing the temperature
range of use
Semi-annually
< ± 0.5°C at each of the three
temperatures checked
Inspect instrument
for damage or
worn components.
Correct data
where possible
(e.g. wind
direction).
Recalibrate
instrument.
Qualily all
collected data
since the most
recent calibration
or acceptable
calibration check
as "QX" in AQS,
as applicable.
Potentially
invalidate data
since last most
recent calibration
or acceptable
calibration check.
Relative Humidity
Compared to a NIST-traceable
psychrometer or standard
solutions
Semi-annually
< ± 5% RH of the hourly
average from the certified
standard over the duration of
comparison
Barometric
Pressure
Compared to a NIST-traceably
certified barometer or pressure
transducer over the course of
several consecutive hours
Semi-annually
< ± 3 hPa
Wind Speed
Compared to a NIST-traceable
synchronous motor or CTSa
method
Semi-annually
< ± 0.2 m/s or± 5%,
whichever is greater
Wind Direction
Compared to solar noon, GPS,
magnetic compass, or CTSa
method
Semi-annually
< ± 5 degrees
Solar Radiation
Compared to a NIST-traceable
pyranometer
Semi-annually
< ± 5% b
UV Radiation
Compared to a NIST-traceable
radiometer
Semi-annually
< ± 5% b
Precipitation
Add water at a constant rate
such that the gauge tips every
15 seconds and measure output
with a graduated cylinder
Semi-annually
< ± 10% of input volume
a CTS = collocated transfer standard
b Comparison should be made during sunny conditions.
B5.2 Quality Control for Laboratory Activities
QC procedures for laboratory activities cover laboratory extraction and analysis of carbonyls
cartridges as identified in Table B5-5, which are replicated in the ASL SOP. Laboratory QC samples
consist of extraction batch QC (extraction solvent method blanks [ESMB] and DNPH media method
blanks [MB] and known standard spikes - LCS/LCSD) and analysis batch QC samples including
solvent blanks (SB), SSCV standards, continuing CCV, and replicate analysis of an extract. Other
QC processes include establishing HPLC instrument calibration and adhering to proper cartridge
storage conditions and holding times.
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Table B5-5. Carbonyls Laboratory Quality Control Parameters
QC
Parameter
Detail
Required
Frequency
Acceptance Criteria
Recommend Corrective
Action
Solvent
Blank (SB)
Analysis of acetonitrile
solvent to demonstrate
the HPLC is
sufficiently clean
Prior to ICAL,
prior to first daily
CCV and after
each CCV when
additional samples
are to be analyzed
Target analyte
concentrations < MDLsp
Analyze several SBs and
pump mobile phase to flush
system. If contamination or
interference persists, further
investigation of source of
contamination is necessary.
Initial
Calibration
(ICAL)
Analysis of five or
more different
calibration standard
solutions covering the
concentration range of
interest
Prior to PAMS
season, after failed
continuing
calibration
verification, and
after changing
instrument
components or
maintenance which
impacts calibration
response
r > 0.999, back-
calculated
concentration of each
standard level within
± 20% of nominal,
intercept/slope <
MDLSp
Review chromatography for
co-eluting peaks or improper
integration. If problem is not
found, repeat calibration. If
still unable to meet criteria,
prepare new calibration
standards and reanalyze.
Analysis cannot commence
until calibration meets criteria.
Second
Source
Calibration
Verification
(SSCV)
Analysis of a known
standard prepared from
a stock solution sourced
from a vendor
independent of the
primary calibration
stock standard; verifies
the quality of the ICAL
Immediately
following ICAL
Target analyte
concentrations within
± 15% of nominal
Review preparation records,
calculations, procedures, and
chromatography to investigate
discrepancy with ICAL. If root
cause not found, prepare new
SSCV and/or ICAL and
reanalyze extracts analyzed
since the last passing SSCV.
Analysis cannot commence
until SSCV following ICAL
meets criteria.
Continuing
Calibration
Verification
(CCV)
Analysis of a known
standard solution to
verify the instrument
calibration remains
valid
At the beginning of
each day's analysis
when an ICAL is
not performed and
after every 12
hours of analysis
Target analyte
concentrations within
± 15% of nominal
Review chromatography for
co-eluting peaks or improper
integration. If problem is not
found, establish new ICAL
and reanalyze extracts
analyzed since the last passing
CCV. If associated samples
cannot be reanalyzed, and
unless technical justification is
provided to explain
nonconformance, qualify all
samples since most recent
acceptable CCV as "QX" in
AOS.
Holding
Times
Maximum duration
from end of sample
collection for sample
extraction
Maximum duration
from sample extraction
to analysis
All field-collected
and laboratory QC
cartridges
14 days from end of
sample collection to
extraction
30 days from sample
extraction to analysis
Qualify samples exceeding
holding times as "HT" in
AQS.
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QC
Parameter
Detail
Required
Frequency
Acceptance Criteria
Recommend Corrective
Action
DNPH Lot
Blank
Analysis
Extraction and analysis
of a representative
amount of each lot of
DNPH cartridge media
to demonstrate
acceptably low
background
With each new lot
of DNPH cartridge
media - 3
cartridges per lot or
1%, whichever is
larger
Measured mass per
cartridge (|ig/cartridge):
- acetaldehyde <0.10
- formaldehyde <0.15
- acetone <0.30
- other individual
compounds <0.10
Reject media lot and return to
vendor. If media must be used,
qualify results for compounds
with exceedances as "LB" in
AQS.
Method
Blank (MB)
Blank cartridge from
the lot of co-extracted
field-collected samples
- extracted to assess
cleanliness of media
and reagents
One per extraction
batch of 20 or
fewer field-
collected samples
Target analyte
concentrations < MDL
Review preparation records,
chromatography, and
procedures for sources of
contamination. Unless
technical justification is
provided to explain
nonconformance, qualify all
sample results in the
extraction batch as "LB' in
AQS.
Laboratory
Control
Sample
(LCS)
Blank cartridge spiked
with a known amount
of target analytes and
extracted
Minimally twice
quarterly,
recommended each
extraction batch of
20 or fewer field-
collected samples
Formaldehyde recovery
within 80 to 120%, all
other target analytes
recovery within 70 to
130% '
Review preparation records,
chromatography, and
procedures for sources of
contamination or suppression.
Unless technical justification
is provided to explain
nonconformance, qualify
sample results in the
extraction batch as "QX' in
AOS.
Laboratory
Control
Sample
Duplicate
(LCSD)
Duplicate blank
cartridge spiked with a
known amount of target
analytes and extracted
to assess precision of
the extraction and
analysis method
Minimally twice
quarterly,
recommended each
extraction batch of
20 or fewer field-
collected samples
Formaldehyde recovery
within 80 to 120%, all
other target analytes
recovery within 70 to
130%; precision with
LCS as RPD < 20%
Review preparation records,
chromatography, and
procedures for sources of
contamination or suppression.
Unless technical justification
is provided to explain
nonconformance, qualify
sample results in the
extraction batch as "QX' in
AOS.
Extraction
Solvent
Method
Blank
(ESMB)
Aliquot of solvent lot
used for extraction
contained within a
volumetric flask used
for extraction
Each extraction
batch of 20 or
fewer field-
collected samples
Target analyte
concentrations < MDLsp
Review preparation records,
chromatography, and
procedures for sources of
contamination. Qualify sample
results in the extraction batch
as "LB' in AQS.
Replicate
Analysis
Repeat analysis of a
routine sample extract
One each day of
analysis
Relative percent
difference < 10% for
compounds >0.5
Hg/cart ridge
Reanalyze extracts to confirm
disparate results. If confirmed,
qualify sample results in the
analysis batch as "QX' in
AOS.
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QC
Parameter
Detail
Required
Frequency
Acceptance Criteria
Recommend Corrective
Action
Field Blank
Blank cartridge
installed in a sampling
channel for five to ten
minutes
As submitted to the
laboratory by field
site(s)
measured mass per
cartridge (|ig/cartridge):
- acetaldehyde < 0.40
- formaldehyde <0.30
- acetone <0.75
- sum of other
compounds < 7.0
Investigate sources of
contamination in handling and
transport. Unless technical
justification is provided to
explain nonconformance,
qualify associated field
collected samples as "FB" in
AQS. Associated samples are
those in the shipment with the
field blank and the samples
since the most recent
acceptable field blank.
Trip Blank
Blank cartridge
accompanying collected
samples to and from the
field site
As submitted to the
laboratory by field
site(s)
measured mass per
cartridge (|ig/cartridge):
- acetaldehyde <0.10
- formaldehyde <0.15
- acetone <0.30
- other individual
compounds <0.10
Investigate sources of
contamination in handling and
transport. Unless technical
justification is provided to
explain nonconformance,
qualify associated field
collected samples as "TB" in
AQS. Associated samples are
those in the shipment with the
trip blank.
Sample
Storage
Cartridges stored
refrigerated and
protected from light
All samples
Storage in foil pouch at
<4°C
If temperature is exceeded,
qualify results as "TT" in
AOS."
Extract
Storage
Sample extracts stored
refrigerated and
protected from light
All extracts
Storage in amber vials
at < 4°C
If temperature is exceeded,
qualify results as "TT" in
AOS."
Duplicate
Sample
Analysis
Analysis of a separate
sample cartridge
collected concurrently
with a primary 8-hour
sample through a
common inlet probe
As submitted to the
laboratory by field
site(s)
Relative percent
difference < 20% of the
associated primary
cartridge for
compounds
>0.5 ng/cartridge
Unless technical justification
is provided to explain
nonconformance, qualify both
samples as "QX" in AQS.
Collocated
Sample
Analysis
Analysis of a separate
sample cartridge
collected concurrently
with a primary 8-hour
sample through an
independent inlet probe
As submitted to the
laboratory by field
site(s)
Relative percent
difference < 20% of the
associated primary
cartridge for
compounds
>0.5 ug/cartridge
Unless technical justification
is provided to explain
nonconformance, qualify both
samples as "QX" in AQS.
B6 Instrument/Equipment Acceptance, Testing, Inspection, and Maintenance
Instrumentation used to conduct PAMS measurements or to calibrate PAMS equipment will be
maintained in accordance with the manufacturer's guidelines regarding routine maintenance of
the specific instrument/equipment. Inspection and maintenance procedures will be followed as
described in the approved instrument SOPs. Routine instrument maintenance activities and their
prescribed frequencies are shown in Table B6-1.
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B6.1 Instrument Acquisition for New Required PAMS Sites
SLT air agencies are required to establish and begin operating additional PAMS networks
resulting from a new census (see 40 CFR 58.14(b)). EPA recommends that new field-related
equipment and samplers/monitors be installed by the October prior to the site's first PAMS
season for shakedown, testing, and training so as to be ready for full implementation before the
start of the season on June 1. Monitoring agencies will work with the Regional Representatives
to communicate issues or delays in installing or readying instruments or measurements. If there
are delays in instrument acquisition or measurement implementation, monitoring agencies are
expected to conform with the monitoring agency QAPP once the instruments are operational and
suitable for monitoring. Details and approvals will be described within the monitoring agency
QAPP or in a separate document and indicated by reference. Monitoring equipment (e.g., auto-
GCs, carbonyls samplers, true NO2 analyzers, and ceilometers) necessary to outfit the PAMS
Required Site will be selected and purchased so as to ensure sufficient time to receive, inspect,
install, calibrate, and become familiar with the operation of the instruments. While training on
instrument use will continue after the beginning of PAMS season, monitoring agencies will plan
for site operators and auditors to attend training sessions, when available, in the months leading
up to PAMS season.
B6.2 Instrument Acceptance Testing and Shakedown
The instruments and support equipment for PAMS monitoring are complex and typically require
a testing, conditioning, and shakedown period of minimally several weeks to ensure that
instrument operation is stable and that monitors are suitably free of contamination and ready for
the collection and analysis of the trace levels of pollutants in ambient air. Once equipment is
received and inspected and proper operation is verified, instruments require calibration and
independent verification of the calibration. Depending on instrument installation status, the
monitoring agency will plan to perform instrument conditioning and shakedown with sufficient
time prior to the 2021 PAMS season to ensure instruments are functioning properly and are
calibrated. During this shakedown period, site operators will treat the data as a "dry run" for
generating PAMS measurement data to work out instrument and data transformation problems
and become accustomed to the instrument operation and data outputs. Each monitoring agency
will conduct a shakedown assessment (a TSA) prior to the first PAMS Required Site monitoring
season and annually thereafter prior to PAMS season (unless the instruments are operated year-
round). Monitoring agencies will not report data to AQS during the shakedown period.
B6.2.1 Initial Instrument Acceptance and Shakedown
Once monitoring instruments and equipment are purchased and have been received, the
instruments and equipment will be inspected within one month of receipt (earlier if possible) to
ensure they are in good condition and include the necessary components required for installation.
Vendors will be contacted immediately if issues are discovered during this initial inspection.
Instruments will be installed in the monitoring shelter or laboratory (by the vendor, site operator,
or other qualified individual or 3rd party provider of such services), as appropriate, and monitoring
agencies will condition the instruments and ensure their proper functionality, which may include:
• Checking and documenting the diagnostics of the instrument, looking for error messages
or warnings
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• Ensuring that parameters such as sample flow rate, pressure, temperatures, etc., are
within specifications per instrument manuals
• Performing leak checks on the instrument
Once proper instrument operation has been confirmed, site operators will calibrate or verify the
calibration of the instruments, as appropriate, as part of the instrument shakedown. Known
aspects of instrument and support equipment operation which require several days to weeks to
complete include, but are not limited to, the purging and conditioning of zero air generators (for
auto-GC use); passivation and conditioning of calibration standard gas regulators, lines, and
calibrators; and flow calibration of carbonyls sampling instruments.
This initial shakedown and testing period will occur minimally three months prior to the 2019
PAMS season, preferably earlier, to ensure that problems and related troubleshooting and
corrective actions can be resolved prior to beginning required monitoring.
B6.2.2 Annual Instrument Shakedown
The monitoring agency may elect to operate all or some of the instruments year-round. In such
cases, the maintenance schedule prescribed for each instrument is to be followed and suitability
for each measurement will be evidenced by the QC procedures and checks required for PAMS
Required Site measurements. If, however, the monitoring agency opts to shutdown PAMS
monitoring at the conclusion of PAMS season, instruments will go through shakedown such that
the instruments are online, calibrated, and stable minimally four weeks prior to the start of
PAMS season and in sufficient time to demonstrate proper operation as evidenced by acceptable
performance in PTs. Note that auto-GCs and supporting equipment are typically less prone to
operational problems when operated year-round.
B6.3 Equipment Inspections
In general, the following routine inspections will be conducted:
• Monitoring shelters, sample inlets, and equipment facilities (such as pump or compressor
housings) must be inspected monthly to ensure conditions do not adversely affect
instrument operation or data integrity.
• Data collection and data quality are reviewed each business day to inspect for trends or
signs of problems. Data trends that indicate a need for further inspection include issues
such as identical ("frozen") numbers for several consecutive hours or erratic spikes or
dips in the measured concentration values.
• Equipment will be inspected during site visits to ensure instruments are in appropriate
working order. Site visit checklists will be developed and used to ensure a consistent level
of inspection for site operators. An example site visit checklist detailing typical items
inspected is included in Appendix E.
B6.4 Instrument Maintenance
Preventive maintenance minimizes instrument downtime and associated data loss. Routine
preventive maintenance will be conducted in accordance with the manufacturer's operation
manuals and applicable maintenance bulletins or updates issued by the manufacturer and
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according to procedures and frequencies described in the approved PAMS instrument SOPs.
Additional information on instrument maintenance can be found in Revision 3 of the PAMS
TAD. PAMS instrument and support equipment maintenance activities will be performed per the
frequency detailed in Table B6-1. Note the information in Table B6-1 is generic and that
monitoring agencies will update the information in the table below to specify the activities and
associated required frequencies in their QAPP specific to their instruments.
Monitoring agencies will maintain an appropriate supply of critical spare parts and ensure tools
are available prior to conducting routine maintenance. Components known to fail or require
frequent replacement should be readily available to address unforeseen events. A list of these
supplies will be detailed in the specific equipment SOPs.
Table B6-1. Routine Instrument Maintenance Activities
Instrument
Maintenance Activity
Frequency
Auto-GC
Maintenance activities are prescribed in the associated
SOP. They include replacing the Nafion dryer (if so
equipped), replacing preconcentrator trap(s), servicing
zero air generator, calibrating standard dilution
measurement equipment
Performed annually prior to
PAMS season
Carbonyls Sampler
Maintenance activities are prescribed in the associated
SOP. They include recharging/replacing the ozone
denuder, replacing the particulate filter, and performing
positive bias challenge
Performed annually prior to
PAMS season
True NO2 Analyzer
Maintenance activities are prescribed in the associated
SOP. These include replacement of particulate filter,
servicing zero air generator, calibrating standard dilution
equipment
Performed annually prior to
PAMS season
Precipitation Gauge
Weighing gauges: Routine visual check. Clean gauge by
soaking and wiping with a clean cloth and soapy water.
Change chart, chart pen, wind clock, or change batteries
Each site visit, or as
recommended by the
manufacturer
Tipping Bucket Gauge: Visually inspect and clean
apparatus of dirt and debris, as needed. Manually tip
bucket 10 times and verify that 10 tips were recorded by
the instrument.
Visually inspect during each site
visit; perform operational check
if necessary during each site
visit, or as recommended by the
manufacturer
Wind Speed/Direction
Instrument
Cleaning and lubricating per manufacturer
recommendations
Annually during calibration
verification
Thermometer
Inspect and clean radiation shield. Verify paint reflective
integrity.
Minimally every six months or
more frequently depending on
site conditions
Barometer
Inspect wiring integrity and instrument housing for proper
ventilation - remove dust from indoor sensors
Each site visit
Hygrometer
Inspect and clean radiation shield. Verify paint reflective
integrity. Replace screen as needed
Minimally every six months or
more frequently depending on
site conditions
Radiometer
(pyranometer)
Clean dome lens, verify level, and review data to verily
diurnal pattern, inspect and replace desiccant - realign
after servicing
Clean lens and inspect level,
unit, and data each site visit, or
as recommended by the
manufacturer - replace desiccant
monthly
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Instrument
Maintenance Activity
Frequency
Ceilometer
Check for alarms and warnings and confirm that the
ceilometer computer is recording data. If an air agency
uploads data to the Unified Ceilometer Network, confirm
that the data are being properly transferred.
Maintenance activities are prescribed in the associated
SOP. Clean laser window, check window blower
operation, check and clean (as needed) door gasket.
Each site visit
Each site visit, or as
recommended by the
manufacturer
HPLC for carbonyls
analysis
Maintenance activities are prescribed in the ASL QAPP
and associated SOP. Such includes servicing pumps,
replacing guard columns, replacing solvent frits, injector
needles, etc.
As prescribed in the ASL QAPP
(or equivalent) and SOP
Prior to each PAMS season, monitoring agencies will complete maintenance on the instruments
and support equipment necessary for PAMS measurements. Monitoring agencies will replace
worn items as needed, verify proper operation, and calibrate instruments such that the
instruments are readied for collecting and reporting PAMS measurements starting no later than
June 1 of each year. Note that for auto-GCs or continuous gaseous monitors, these instruments
may need to be readied several weeks in advance to accommodate PT sample analysis or
through-the-probe (TTP) audits as arranged with the EPA Regional representative or EPA's QA
contractor.
PAMS site operators will perform basic checks during each site visit which include visually
examining the instruments at the site and verifying communication with the data acquisition
system (DAS). An example site visit checklist is included in Appendix E. The intent of this
checklist is to serve as a comprehensive list of items for operators to verify when onsite such that
the risk of data loss is minimized and to demonstrate that equipment is operating normally. These
checklists are valuable data inputs for data verification and validation. Agencies may choose to
prepare their own checklist to capture different or additional aspects of monitoring when
operators are on site. Operators should pay particular attention to instruments outdoors, such as
meteorological instruments. A visual inspection will include verifying that instruments
temperature shields are present, free of damage, and not blocked (such as with a bird nest, insect
nest, etc.). Mechanical wind instruments should be verified to be operational if the wind is
blowing and precipitation gauges should be inspected for debris. In general, site operators should
compare current meteorological readings to nearby National Weather Service (NWS) site
conditions or other reliable nearby readings.
B7 Instrument/Equipment Calibration and Frequency
Calibration is defined as the comparison of a measurement standard, instrument, or item with a
standard or instrument of higher accuracy to detect and quantify inaccuracies and to report or
eliminate those inaccuracies by adjustment. Instruments and devices employed at PAMS
Required Network Sites will be calibrated prior to use and according to the schedule/frequency
described within this section, which are duplicated in the PAMS TAD and national SOPs. Note
that calibration checks which may involve verification of calibration at one or more different
levels ensure the calibration remains valid, but do not involve adjustment of the instrument.
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Calibration verification failures require adjustment of the calibration, or re-calibration, of the
instrument or monitor.
Instrument calibrations will be documented in logbooks dedicated to the instrument. Electronic
means of record keeping, e.g., calibration, verification forms, and datalogging programs with
annotation report capabilities, can serve in place of a physical logbook. The instrument will be
uniquely identified and the date of calibration, identification of standard(s) used for calibration
(including certification date), calibration outcome (such as slope, intercept, or other metric
indicating acceptable calibration), and any needed corrective actions will be documented in the
appropriate logbook. Standards will not be used past their expiration date.
B7.1 Instrument Calibration
Instrument calibration instructions are specified for the beginning of and conclusion (shutdown)
of PAMS season in the applicable SOPs.
B7.1.1 Carbonyls Instrument Calibration
Carbonyls instruments requiring calibration include field sampling instruments and laboratory
instruments.
B7.1.1.1 Carbonyls Field Sampling Instrument Calibration and Calibration Verification
Carbonyls sampling unit flow controller(s) will be calibrated initially prior to the beginning of
PAMS season and the flow calibration verified minimally monthly thereafter. Flow calibration
verification will be within ±10% of the flow indicated at standard conditions of 760 mmHg and
25°C against a NIST-traceably certified flow transfer standard.
B 7.1.1.2 Carbonyls Laboratory Instrument Calibration and Calibration Verification
Initially, following maintenance or repair that would reasonably impact the instrument response,
and following failure of CCV or SSCV, the HPLC or UHPLC will be calibrated for the target
compounds by analysis of a minimum of five concentration levels covering the concentration
range expected to bracket the concentrations of carbonyls in the cartridge extracts. Instruments
that are not operated continually (e.g., those shut down for several months at a time) will be
calibrated when returned to online status. Calibration will be verified immediately following the
ICAL by analysis of an independent SSCV and every 12 hours of analysis thereafter by analysis
of a CCV. The SSCV and CCV will be within ±15% of the nominal concentration or corrective
action must be taken.
B7.1.2 Calibration and Calibration Verification for Speciated VOCs by Auto-GC
Auto-GCs for measuring speciated VOCs will be calibrated as part of initial set-up and
shakedown, minimally at the start of the PAMS season, and when maintenance to the instrument
is reasonably expected to alter its calibration. Calibration is established by analysis of minimally
three concentration levels of a representative compound for each respective FID, typically
propane or butane for the light hydrocarbon (C2 to Cr, or porous layer open tubular - PLOT
column) channel and benzene or toluene for the heavy hydrocarbon (C6 to C12 or
polydimethylsiloxane - PDMS column) channel. The stock calibration gas (primary standard)
will be NIST-traceably certified for propane (or butane) and benzene (or toluene). [Toluene is
included as an option for the heavy hydrocarbon channel in the event that the benzene response
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factor is not consistent with the other hydrocarbons.] The calibration is then to be immediately
verified by analysis of a NIST-traceably certified SSCV containing compounds representing the
molecular weight range (C2 to C10). This SSCV is to be analyzed minimally weekly thereafter
and must be within ± 30% of the nominal concentration for the target compounds.
B7.1.3 Calibration and Calibration Verification for True NO2 Analyzers
True NO2 analyzer instruments require calibration initially when placed into service by
12
MPV
ntroduction of a zero and an upscale span point (approximately 80% of the intended
neasurement range. The calibration will be verified immediately thereafter by conducting the
VIPV described in Section B.5.1.3. The MPV will show the analyzer calibration response ha
een effectively established through linear regression of the theoretical concentrations anc
nstrument readings with a correlation coefficient of r2 > 0.995 and an x-intercept within ± 0.1
pb of the origin. Additionally, the percent difference of each standard measurement in the MP^
11 be within ±10% of the theoretical concentration. Once the MPV meets acceptance criteria,
e instrument calibration and zero must be verified minimally every 14 days. For the zero, the
zero drift must be less than ±0.3 ppb and the span level (a concentration approximately 80% of
the intended measurement range) must be within ±10% of the theoretical concentration. More
frequent verifications are encouraged, and operators are also encouraged to conduct
zero/span/precision checks which include verification of a zero concentration and two standard
concentration levels - a span point of approximately 80% of the measurement range, and
precision point in the lower 1/3 of the measurement range. Instruments which do not meet the
listed calibration verification acceptance criteria listed in Table B5-3 will be recalibrated by
adjusting the instrument response to match that of the zero and reference standard or may be
replaced with a known operable, calibrated instrument. Data collected since the most recelfl
acceptable MPV or zero/span check or zero/span/precision check will be qualified or invalidated,
To generate calibration gas, GPT is recommended since
no NIST-traceable NO2 standard gases are currently available.
B7.1.4 Calibration and Calibration Verification for Meteorology Instruments
Meteorological instruments require calibration initially prior to placement into service.
Instrument calibration will then be verified minimally annually thereafter by conducting the
calibration verification QC checks listed in Section B5.1.4. Instruments which do not meet the
listed calibration verification acceptance criteria listed in Table B5-4 will be recalibrated by
adjusting the instrument response (e.g., thermocouple or hygrometer) and/or orientation (e.g., for
wind direction) to match that of the reference standard, or may be replaced with known
calibrated instruments that meet the operational requirements given in Table A7-1. Data
collected since the most recent acceptable calibration or calibration verification will be qualified
or invalidated, as appropriate, when reported to AQS.
B7.2 Calibration Support Equipment
Calibration support equipment for PAMS measurement instruments includes, but is not limited
to, flow transfer standards, reference thermometers, reference barometers, volumetric labware,
and mass flow controllers. Calibration and calibration verifications will be performed by
comparison to such known standards which will be traceable to NIST standards. Such NIST
traceability will be evidenced on a calibration certificate by the metrology lab, standards
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provider, or certification provider attesting to the accuracy or uncertainty associated with the
standard. Such standard certification providers may be the manufacturer, in-house laboratory,
third-party laboratory, or other suitable certifier. Such metrology certification providers typically
operate under an International Organization for Standardization (ISO) quality standard or other
similar performance standard which requires their certifications to be traceable to a NIST
certification. Monitoring agencies will specify the certification provider, primary standards of
comparison, and approved method or SOP for each appropriate support instrument. These details
may be included here or may be included by reference.
Support equipment requiring calibration and the associated calibration frequency and acceptance
criteria are listed below in Table B7-1.
Table B7-1. Calibration Requirements for Critical Support Instruments
Critical Support
Equipment
Specifications and
Acceptable
Uncertainty
Area of Use
Calibration a
Frequency
Requirement
Calibration
Verification b
Check Frequency
Flow Transfer
Standard
< 2% of NIST-traceable
standard across its range
of flow rates
Calibration of flow
controllers for
carbonyls sampling
units and mass flow
controllers in gas
calibrators
Annual per
manufacturer
specifications
Calibration check
not required
Mechanical Pipette
Tolerance within
manufacturer
specifications
Delivery of known
liquid volumes -
preparation of
carbonyls
calibration
standards
Initially and every six
months thereafter or
when calibration
checks demonstrate an
out of tolerance
condition
Each day of use by
weighing delivered
volumes of
deionized water
bracketing those
dispensed; Must
cover the range of
use
Class A
Volumetric
Labware
Meets Class A
tolerances specific to the
labware designated
volume
Measuring final
volume of standard
solution preparation
Received with a
certification of
calibration
Calibration check
not required
Volumetric
Syringe
Tolerance within
manufacturer
specifications
Delivery of known
liquid or gas
volumes
Received with a
certification of
calibration or initially
calibrated
gravimetrically at 10%
and 100% of full
volume
Calibration check
not required
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Critical Support
Equipment
Specifications and
Acceptable
Uncertainty
Area of Use
Calibration a
Frequency
Requirement
Calibration
Verification b
Check Frequency
Thermometer (not
for reporting
meteorological
ambient
temperature data)
0.1°C resolution
± 0.5°C accuracy of a
NIST-traceably certified
standard thermometer
Laboratory and site
storage unit
monitoring for
carbonyls sample
and extract storage
- temperature
monitoring of
monitoring shelter -
note this is not a
thermometer for
rcDortina
meteorological data
Annual at temperature
range of use -
Correction factors
applied to match
certified standard
Annual calibration
is sufficient
Balance
Tolerance within
manufacturer
specifications
Laboratory -
Weighing standards,
calibration of
pipettes
Annually or when
calibration checks
demonstrate an out of
tolerance condition
Each day of use
with certified
calibration check
weights bracketing
the balance load;
Must cover the
range of use
Certified Weights
Tolerances within those
assigned to the class of
weights
Laboratory -
Calibration
verification of
balances
Annual or as required
by the manufacturer
Annual calibration
is sufficient
Pressure Gauges
or Transducers
Within ± 0.5 psi or
manufacturer-specified
tolerance, whichever is
smaller
Field and
Laboratory -
Measure canister
pressure/vacuum for
standards
preparation
Annual
Annual calibration
is sufficient; Must
cover the range of
use
Mass Flow
Controller - Gas
Calibrator
Within ±2% of certified
flow transfer standard
Precise metering of
standard and diluent
gases for calibration
of monitoring
instruments
Annual or when
calibration checks
demonstrate flows are
out of tolerance
Minimally quarterly
(before and at the
end of PAMS
season), monthly
recommended
a Calibration refers to resetting (adjusting) the reading or setting or applying a correction factor to the instrument or
standard to match a certified standard.
b Calibration verification checks are a comparison to a certified standard to ensure the instrument or standard
remains within a prescribed tolerance. Instruments or standards which exceed the tolerance must be adjusted to be
within prescribed tolerances or must be replaced.
B8 Inspection/Acceptance of Supplies and Consumables
Supplies and consumables include a wide variety of materials such as calibration gas standards,
particulate filters for inlets and instruments, stainless steel tubing, high pressure cylinder
regulators, auto-GC preconcentrator traps, ozone photometer lamps, ozone scrubbers, etc. Where
possible, supplies and consumables will be purchased from reputable vendors to ensure items
purchased meet the required specifications. The list of consumables and supplies is too extensive
to provide in its entirety in this QAPP; individual materials and the required specifications are
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listed in the applicable SOPs for the measurement methods. Materials will be inspected and
confirmed to meet the specifications detailed in the respective SOP before being used and/or
placed into service. Performance of the supply or consumable will be confirmed by verifying
proper instrument function or operation evidenced by meeting applicable QC criteria. Monitoring
agencies will specify their processes and procedures for inspection/acceptance of supplies and
consumables in their QAPPs.
B8.1 Acceptance of Standard Materials
On an annual basis PAMS monitoring agencies will inspect NIST-traceable transfer standard
equipment that is subject to wear and tear during use (for example, temperature, pressure, and
flow rate check devices). Such equipment will be returned annually to the vendor or an
appropriate accredited metrology laboratory (as specified in Section B7.2) for cleaning,
servicing, and recertification against NIST standards. Consult Table B7-1 for equipment
requiring such annual certification.
Stock gaseous standards for calibration of the PAMS analyzers will be sourced from reputable
certified gas vendors. Similarly, derivatized carbonyls calibration stock materials will be sourced
from reputable chemical suppliers. Standard gases and carbonyls stock materials will preferably
be NIST-certified or NIST-traceably certified and must be accompanied by a certificate of
analysis (COA) stating the purity (for neat materials or pure gases) or certified concentration
with associated uncertainty for each component as well as the expiration.
When available, standard NO2 gases for calibrating NO2 analyzers will be procured from a
reputable supplier and certified concentrations must be traceable to a reference material, such as
those prepared by the NIST or the Van Swinden Laboratorium (VSL). Such NO2 standard gases
will be accompanied by a COA indicating the levels of impurities, which will be less than 1 ppm
of residual NO. When employing GPT to calibrate NO2 analyzers, NO standard gases will be
Standard Reference Material (SRM) or Certified Reference Material (CRM) quality and
compliant with Protocol 2 of the EPA's Protocol Gas Verification Program (PGVP).11 Ozone
generators employed to produce standard NO2 gas by GPT with excess NO will be standardized
against a Level 1 or Level 2 ozone standard 12 as prescribed in the criteria gas monitoring QAPP.
Note that EPA employs a national contract laboratory to independently verify the concentration
of propane and benzene in speciated VOCs retention time standard (RTS) cylinders against a
NIST-certified standard. The verification laboratory provides a certificate of analysis for the
verification of each individual RTS cylinder, listing the average measured concentration of each
compound. The average of the concentrations measured by the verification laboratory must be
within ±10% of the value listed on the gas vendor certificate of analysis. The verification
laboratory values indicate the cylinder concentrations are accurate to within the vendor-listed
tolerance; however, these values do not indicate the measurement uncertainty or expiration and
will not be referenced for determining concentrations of calibration standards or calibration
verification standards. Rather, the concentrations and expiration date listed on the gas vendor
certificates of analysis will be referenced for standards preparation. Expired standards may not
be utilized for instrument calibration or calibration verification unless the expiration has been
extended following a process approved by the Regional Representative.
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COAs will be maintained by the monitoring agency or laboratory and be available for inspection
during TSAs. Gas standard expiration or recertification dates are typically one year or more and
several vendors offer recertification services in which traceable concentrations are updated such
that the useful life of the standard cylinder is extended. Recertification of standard gases may be
more cost effective than purchasing new standards and can be performed during the non-
sampling season (as applicable to the specific PAMS Required Site).
Prior to acceptance or use of a standard material for calibration, particularly for custom-ordered
materials, the COA will be inspected to ensure the correct compounds are included, that their
concentrations are as requested and within requested tolerances, and that listed impurities are
acceptably low. The new stock standards for VOCs analysis will be analyzed against a known
acceptable instrument calibration and known stable (acetylene, styrene, and pinene isomers are
not considered to be stable) compounds such as propane, benzene, toluene, ethylbenzene, and
xylenes will be within the method bias specification.
B8.2 Acceptance of Sampling Media - Carbonyls
Prior to use in the field for sample collection, each lot of DNPH cartridges will be tested to
ensure the background contamination is acceptably low. Minimally three cartridges per lot or 1%
of the received lot, whichever is greater, will be extracted and analyzed to determine the average
background concentration of each target carbonyl. Background concentrations vary within
manufacturer lots, therefore monitoring agencies are encouraged to select cartridges from
different boxes within a given lot to characterize the lot's background variability. Each tested lot
blank cartridge will meet the criteria in Table B8-1. It is expected that the ASL will perform this
lot blank analysis for each lot of media for use at supported sites.
If the criteria in the table are not met, the lot will not be used for sampling and will be returned to
the vendor.
Table B8-1. DNPH Cartridge Lot Blank Acceptance Criteria
Carbonyl Compound
Acceptance Limit (ug/cartridge)
Acetaldehyde
<0.10
Formaldehyde
<0.15
Acetone
<0.30
All Other Carbonyl Compounds
<0.10
B9 Non-direct Measurements
Non-direct measurement data will be used to support data validation activities, as described in
Section 10 of Revision 3 of the PAMS TAD on data verification and validation. Such data may
include historical PAMS data or reported concentrations and meteorological measurements from
other monitoring sites. Data acquired from non-direct measurements may also include site
operator observations.
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B9.1 Historical PAMS Data and Supplemental Measurement Data from Other
Monitoring Sites
PAMS data may be compared, for the purposes of verification and validation, to measurement
data from other monitoring sites including other PAMS sites, air toxics sampling sites,
meteorology stations, etc., and to historical PAMS data. While the data undergoing verification
and validation may be subjected to further scrutiny, adjusted by the addition of qualifiers, or
invalidated due to comparison with historical and/or other supplemental data, the monitoring
agency will not perform assessment (e.g., further validation) on the historical and/or
supplemental data. Adjustment or validation of such data is outside the scope of this QAPP.
General guidelines for data validation are given in the PAMS TAD Revision 3 Section 10 and it
is recommended that users of any such data confirm the data's fitness for the intended purpose of
comparison prior to use.
BIO Data Management
The monitoring agency will ensure that data are recorded, verified, validated, reported, managed,
and archived in a manner that permits reconstruction of activities throughout the data lifecycle.
The monitoring agency data management procedures will be described within this section of
their QAPP or included by reference.
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C ASSESSMENT AND OVERSIGHT
Cl Assessments and Response Actions
One of the major objectives of this QAPP is to specify the policies and establish procedures
necessary to ensure PAMS data are of sufficient quality and quantity to meet the Required Site
Network DQOs. Site operators and laboratory staff have the responsibility to prevent
nonconformances where possible and to minimize their impact to data quality and fitness for
purpose once identified. Every effort will be made to anticipate and resolve potential
nonconformances before the quality of PAMS data is compromised. Nonconformances
impacting data quality will be reported to the appropriate monitoring agency manager who will
work with the site operators and/or laboratory staff to take corrective action. Adherence to the
quality policies described in this QAPP will also be ascertained by way of various ongoing
assessments, as given below.
Cl.l Types of Assessments
As part of the PAMS Required Site Network QS, the following types of assessments will be
conducted to ensure that the resulting data quality meets the PAMS DQO and user needs:
IP As
TSAs
ADQs
PTs
PEs
Details regarding assessments are described in Section 15 of the EPA QA Handbook, Volume II
(EPA-454/B-17-001, January 2017), available by the following link on AMTIC:
https://www3.epa. gov/ttn/amtic/files/ambient/pm25/qa/Final%20Handbook%20Document%
201 17.pdf
Staff conducting assessments (auditors) will be independent of staff performing the functions and
will have authority to inform management of nonconformances to approved, established
procedures and policies. These staff members should be organized under the monitoring agency
quality assurance unit (QAU) as described in Section A6.2. Auditors will have authority to
suggest to management to stop work activities if nonconformances have a severe impact on the
quality of collected measurements or if staff safety is in jeopardy.
Refer to Table Cl-1 for a summary of PAMS Required Site assessments.
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Table Cl-1. PAMS Required Site Assessments
Assessment
Description
Responsible Party
Conducting Assessment
Frequency
Shakedown
Audit (TSA and
IP A)
Evaluation of PAMS Required
Site readiness
Monitoring agency QAU
Before the June 2019
implementation; additionally
recommended prior to each
PAMS season thereafter
Technical
Systems Audit
(TSA)
Review of compliance with
PAMS Required Site Program
requirements, QAPP, SOPs, and
best practices
Monitoring agency QAU
EPA Regional
Representative and
National QA Support
Contractor - note the
triennial TSA may also
include an IPA of the
carbonyls sampler(s)
and/or meteorological
instruments
Annually during active
PAMS monitoring
Once every three years,
preferably during active
PAMS monitoring
Instrument
Performance
Audit (IPA)
Measurement of carbonyls
sampling unit flow with a
certified flow transfer standard
independent of that used for
instrument calibration or
verification
Comparison of meteorological
instrument measurements by
comparison with a known
certified standard independent
of that used for instrument
calibration or verification
Monitoring agency QAU
Annually during active
PAMS monitoring
Annually during active
monitoring - during PAMS
season if meteorological
measurements are not made
year round
Audit of Data
Quality (ADQ)
Review of a representative
amount of measurement data
(-10%) from initial instrument
calibration, sample analysis, and
coding for reporting to AQS;
includes evaluating that data in
AQS were reported accurately
Monitoring agency QAU
and ASL QAU
Annually during active
PAMS monitoring and
before submittal of a site's
PAMS data to AQS -
Monitoring agencies are
encouraged to perform the
ADQ as early in the
monitoring season as
practical to catch issues to
minimize impact on data
Proficiency
Test (PT)'
Analysis of a sample with target
analytes at concentrations blind
to the monitoring agency and
ASL for both speciated VOCs
and carbonyls analysis
EPA through QA support
contractor
Twice annually, once prior
to PAMS season and once
just prior to the end of the
PAMS season
Performance
Evaluation (PE)
Analysis of known standard
concentrations of target analyte
Monitoring agency QAH
and EPA Regional staff or
EPA support contractor
Monitoring agency PE to be
conducted annually. EPA
NO2 gas provided to the
NPAP audit minimally every
Halvzcr by gas phase titration
through EPA
6 years
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CI. 1.1 Instrument Performance Audit
IP As are an independent check of instalment performance by an individual not involved in
routine operation and with reference standards independent from those used to calibrate the
instrument or to perform routine calibration checks. IP As involve comparing the output of an
instrument to an independent reference standard and quantifying the difference between the
measurement generated by the instrument undergoing assessment and the reference standard.
The monitoring agency QAU will conduct IP As at PAMS Required Sites at least once per PAMS
monitoring season for instruments operated only during PAMS season. Monitoring agencies are
encouraged to conduct IP As during PAMS season, however, are provided latitude to conduct
IP As during active monitoring. The EPA Regional Representative or delegate may conduct IP As
of the pollutant and meteorology instruments, as equipment and capabilities permit, during the
triennial TSA.
CI. 1.1.1 Carbonyls Instrument Performance Audit
Flow rate bias in ambient air sampling for carbonyls has an inverse relationship with the
resulting concentration bias. That is, flow rates that are biased low result in overestimation of air
concentrations whereas flow rates that are biased high result in underestimation of air
concentrations. Minimally once annually (assumed to be once per PAMS season unless the
PAMS carbonyls monitoring is conducted at the site outside of the June 1 to August 31 PAMS
season), an individual from the monitoring agency QA group independent from routine site
operations will verify the flow rate of the carbonyls sampling unit against a certified, reference
flow transfer standard independent of the standard utilized to calibrate or perform monthly
calibration verification of the sampling unit. This check will be performed at the flow rate at
which PAMS cartridges are collected and the flow measured by the flow transfer standard must
be within ±10% of the flow indicated by the sampling unit for each of the flow channels utilized
for sampling. The assessor will notify the site operator in the event of a nonconformance;
corrective action will be required (mass flow controller calibration, flow obstruction removed,
etc.) before cartridge collection may resume and previously collected sample data since the most
recent acceptable flow check will be appropriately qualified (flagged) or invalidated when
reported to AQS. Corrective action is also recommended for flow calibration assessments that
indicate flows are approaching, but not exceeding the appropriate flow acceptance criterion.
CI. 1.1.2 Meteorology Instrument Performance Audits
Typically, meteorological instruments will be operating year-round and can be audited during the
year when convenient for the monitoring agency QAU. For instruments operating year-round, it
is recommended that meteorological audits occur approximately six months after the annual
calibration check. Each meteorological instrument will be audited by comparison to a reference
standard. When possible, such IP As are best conducted with the instrument in-situ, as removal of
the instrument for audit may eliminate the ability to capture specific aspects of monitoring such
as wind-direction, for which the mounting position and compass alignment are critical. It may be
impractical to perform in-situ IP As if instruments must be removed for assessment, such as
temperature probes which are submerged in a water bath for assessment. Meteorological IP As
will meet the acceptance criteria listed in Table B5-4. Monitoring agencies with existing audit
programs for meteorological instruments may add reference to their existing quality documents
here or by reference.
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CI. 1.2 Technical Systems Audit
A TSA is an on-site review and inspection of a monitoring agency's ambient air monitoring
program to assess its compliance with established requirements governing the collection,
analysis, review, verification, validation, and reporting of ambient air quality data. 40 CFR Part
58, Appendix A, § 2.5 requires TSAs of each PQAO by the appropriate EPA Regional Office.17
Additionally, EPA Order CIO 2105.018 establishes policy and program requirements for an
Agency-wide Quality System that include assessments to determine if data are "of sufficient
quantity and adequate quality for their intended use."
EPA will conduct a TSA at each required PAMS site once every four years unless concerns
suggest that more frequent auditing is necessary.2 As described in 40 CFR Part 58, Appendix A,
§ 2.5, EPA Regional Offices are responsible for conducting TSAs; however, as of the date of this
QAPP, EPA has delegated the TSAs at each required PAMS required site to National QA
Support Contractor. Since not every site will have its own laboratory, laboratories supporting
multiple PAMS sites will be subject to audit in the calendar year that the supported PAMS sites
are audited, but will not be audited more than once every three years unless major concerns
suggest that more frequent auditing is necessary.
To increase the uniformity of TSAs, EPA has developed checklists for the PAMS Required Site
program for both monitoring agency and ASL operations, incorporating elements from the
PAMS Required Network TAD and national QAPP and SOPs. Monitoring agency TSAs will
focus on siting criteria, adequacy of QSs, compliance with QS documents, and interviews of staff
responsible for data generation, equipment and instrument calibration, day-to-day operations
including sample collection (handling and custody), meteorology, and data management (such as
records management and data verification, validation, and reporting). Monitoring agency QA
staff will perform a TSA annually during active PAMS monitoring (this will be between the June
1 and August 31 PAMS season unless the monitoring site is monitoring outside of this period).
Upon request from an EPA Regional Representative, monitoring agencies should be prepared to
submit the results of this annual TSA to EPA. As an option, QA staff may also elect to perform
an annual pre-PAMS season shakedown/readiness audit, as described in the section below.
Laboratory QA staff will conduct a TSA on the carbonyls sample handling, extraction, and
analysis procedures annually. Laboratory TSAs will focus on QSs, compliance with QS
documents, performance of analytical methods, sample handling and custody, and data review,
verification, and reporting. The ASL QAU will distribute the TSA report to the monitoring
agencies operating sites supported by the laboratory. The laboratory will notify supporting
monitoring sites of corrective actions, root cause analysis, and demonstrate return to
conformance for audit findings deemed to impact data quality. Such reports will identify the
affected data. The monitoring agency will subsequently notify the EPA Region of the outcomes
of the annual ASL TSA, including any corrective actions taken by the monitoring agency.
To reduce the personnel and cost burdens on all involved parties, EPA will attempt to schedule
PAMS TSAs concurrently with NATTS TSAs, when logistically feasible. Similarly, EPA
2 At the time of this document, the National QA Support Contractor is only responsible for auditing required PAMS
sites and associated laboratories; the contractor will not audit any PAMS-like site that an air agency may establish
(i.e., sites installed as part of an EMP).
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intends to reduce the redundancy of auditing certain parameters that overlap in the PAMS,
NATTS, and criteria pollutant TSAs by:
• Only auditing the sampling and analysis of data for the auto-GC, ceilometer,
precipitation, atmospheric pressure, solar radiation, and ultraviolet radiation during
PAMS TSAs.
• Only auditing carbonyl sampling and the associated analytical support laboratories during
the PAMS TSA if the air agency's carbonyls sampling and analysis processes are not
audited as part of the NATTS TSA process.
• Auditing the remaining required PAMS parameters (e.g., true NO2, ozone, ambient
temperature, wind speed, wind direction, and relative humidity) during the EPA regional
office criteria pollutant TSAs.
EPA may need to modify the target parameters of an air agency's specific PAMS TSA
depending on feasibility, logistics, and/or other specific concerns. Because each site is different,
EPA will discuss the PAMS TSA process and clarify the target parameters with the air agency
ahead of each audit.
CI. 1.2.1 Shakedown Audits
Prior to the June 1, 2021, implementation of the PAMS Required Site program, the monitoring
agency will conduct a shakedown audit of the PAMS monitoring program to evaluate readiness
for the upcoming PAMS season. This shakedown audit will consist of a TSA and include an IPA
of the carbonyls sampling instrument(s). The shakedown audit will focus on the readiness of the
site operators and data reviewers, the adequacy of their training, the availability of all required
QS documents (QAPP, SOPs, field collection forms, COCs) and the suitability and readiness
status of the instruments for officially beginning PAMS monitoring.
Shakedown audits are intended as a tool to identify compliance gaps and areas where additional
resources are required such that data of sufficient quality and quantity may be generated as of
startup on June 1, 2021 (and the beginning of each subsequent PAMS season). Formal corrective
action is not required as a result of shakedown audits. The shakedown audit is inherently
different than an independent audit (TSA and/or IPA) conducted during monitoring season to
assess the compliance of the PAMS operations with the monitoring agency's QS.
CI. 1.3 Audits of Data Quality
ADQs evaluate the methods used to collect, interpret, and report data by examination of a
representative amount of measurement data. The following activities and operations are
evaluated against the required procedures as given in the monitoring agency QMP, QAPP, and
SOPs:
• Recording and transfer of raw data
• Calculations and reductions or transformations of data
• Documentation of data handling procedures
• Reporting procedures for inputting data to AQS
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• Comparison of data contained within AQS to data intended for input
Monitoring agency and ASL QA staff will conduct ADQs for PAMS minimally annually and
prior to entering data into AQS for speciated VOCs, carbonyls, and meteorology parameters, for
those aspects of data collection and reporting for which they are responsible. Results of the ADQ
will be reported to the EPA Regional Representative. Monitoring agencies are encouraged to
conduct the annual ADQ as early in the monitoring season as possible to catch issues early where
their impact on subsequent data is minimized.
CI. 1.4 Proficiency Testing
PT is a quantitative evaluation of the bias introduced in a part, parts, or in the best-case scenario,
the entirety of a measurement process. It involves the analysis of a reference material of known
value and composition that is blind to the site or laboratory.
The PT program will evaluate the PAMS Required Network Sites and/or ASLs for measurement
bias, specifically for speciated VOCs and carbonyls. An EPA contractor will prepare VOCs and
carbonyls samples for shipment to either the field site (VOCs) or to the support laboratory
(carbonyls) on a biannual basis, both prior to and near the end of PAMS season. Samples are
spiked with target analytes at concentrations blind to the sites and laboratories. Sites or ASLs
will analyze the PT sample(s) on the auto-GC (VOCs) or via their TO-11A method (carbonyls)
and will report the concentrations to the PT provider who will compile the reported
concentrations for evaluation against the nominal value and against the overall PAMS Required
Network mean (with statistical outliers removed).
Auto-GC results for VOCs PT samples must be within ± 25% of the assigned target value for
each evaluated target compound. For carbonyls, each PAMS ASL must demonstrate PT analysis
results which are within ± 25% of the assigned target value for each evaluated target compound.
The assigned target value will be based on the network-wide performance. Sites or ASLs that do
not meet the bias acceptance criterion must take corrective action to address the cause of the
nonconformance and demonstrate the corrective action is effective. Corrective action necessity
will be based on the number of parameters and the severity of the unacceptable evaluations as
well as other details of the PT as provided by the PT provider for interpretation of the results.
These details are described in study-specific summary interpretations based on the circumstances
of each PT study.
CI. 1.5 Performance Evaluation
A PE is a test of the measurement system performed by providing a series of known standard
concentrations of NO2 gas to the monitoring station analyzer TTP and evaluating the bias of the
measurements at each provided concentration. PEs are required annually as prescribed in 40 CFR
Part 58 Section 3.1.2. Measured concentrations must be within ± 15% or ± 1.5 ppb, whichever is
greater, of the theoretical challenge concentration.
In addition to the annually required PE conducted by the monitoring agency or cognizant PQAO,
the EPA will conduct an audit of the NO2 measurement system TTP minimally every six years,
as prescribed in 40 CFR Part 58 Section 3.1.3.
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C1.2 Corrective Actions
The monitoring agency will have a corrective action process in place that is executed upon
discovery of nonconformances to the monitoring agency PAMS QAPP and/or applicable PAMS
SOPs. Each monitoring agency will have a corrective action tracking procedure so that corrective
actions are available in a single location (e.g., binder, database, etc.) and may be readily
referenced. Monitoring agencies may include their corrective action process here or include it by
reference.
For each nonconformance, a corrective action report (CAR) will be prepared which includes the
following components:
• Unique CAR identifier
• Identification of the individual initiating the CAR (staff person's name)
• Date of discovery of nonconformance
• Date of CAR initiation
• Area or procedure affected (e.g., carbonyls sample collection)
• Description of the nonconformance (what happened and how it does not conform)
• Investigation of the nonconformance (how discovered, what is affected by the
nonconforming work)
• Root cause analysis (what caused the nonconformance)
• Investigation for similar areas of nonconformance
• Immediate and long-term (if needed) remedial corrective actions (and documentation
of when completed)
• Due date for remedial action completion (immediate and long-term, as needed)
• Impact assessment of nonconformance (data flagging, invalidation, etc.)
• Assessment of corrective action effectiveness
• Demonstration of return to conformance
• Follow up audit to ensure corrective actions were effective (with date completed)
• Approval of closure of the CAR by the monitoring agency director and QA unit
Situations that require a CAR include, but are not limited to:
• Repeated calibration failure
• Incorrect sample storage conditions
• Persistent blank contamination
• Incorrect procedures followed
• Repeated QC acceptance criteria failures
• Unacceptable PT results
Root cause analysis will be performed as soon as possible so remedial actions may be taken to
correct the problem before it affects other procedural areas or additional samples and to
minimize recurrence of the problem. For problems where the root cause is not immediately
obvious, a stepwise approach will be taken to isolate the specific cause(s) of the
nonconformance(s). Incorrect conclusions may result if too many variables are altered at one
time, rendering the corrective action process ineffective. Monitoring agencies are encouraged to
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seek assistance from EPA Regions, EPA OAQPS, or instrument manufacturers in instances in
which a root cause is not evident.
The development and implementation of a CAP, the details of which may be captured in one or
several CARs, is an integral part of the assessment process and must be completed as a follow-up
to each internal and external TSA. The EPA support contractor and/or EPA Region may assist in
development of the CAP for TSAs conducted by EPA Region and/or support contractor;
however, the responsibility of implementing corrective actions lies with the monitoring agency.
A CAP generally addressed the following points:
identification of the root cause for each nonconformance
immediate corrective action(s) needed to correct each nonconformance
• determination of the existence of similar nonconformances elsewhere in the QS
corrective actions to preclude recurrence of the specific and similar nonconformances
assignment of responsibility for implementing each corrective action
completion dates for each corrective action
demonstration of return to conformance
Documenting the follow-up activities will ensure that a subsequent assessment team will be able
to track corrective activities, verify their efficacy, and confirm return to conformance.
If monitoring agency sites or ASLs do not meet PT acceptance criteria, the Regions and
monitoring agency may decide to perform additional PTs as part of their root cause analysis and
demonstration of return to conformance. Information on root causes and corrective actions will
be reported to the Regions and to OAQPS so that lessons learned may be shared and the PAMS
program may be continuously improved.
C2 Reports to Management
Monitoring agency management will be apprised of the results of all independent assessments
conducted on their sites and labs operating in support of the PAMS Required Site program.
Monitoring agency QA staff will report assessment outcomes to management in a timely manner.
The monitoring agency will define the required timeframe for reporting assessment outcomes in
their QAPP. Network summary reports should be generated minimally and reviewed upon
completion of data entry to AQS according to the requirements in 40 CFR Part 58.16.
C2.1 Assessment Reports
Monitoring agency QA staff will forward assessment reports to management upon completion of
the report (for an internal audit) or when received from an external assessor (e.g., EPA Regional
Representative or PT provider). Reports resulting from internal QA activities (e.g., TSA, IP A,
ADQ, PTs, PEs, etc.) will identify operational and data quality nonconformances, resource needs
(e.g., staff training, equipment), and results from relevant external assessments.
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D DATA VALIDATION AND USABILITY
D1 Data Review, Verification, and Validation Requirements
The verification and validation process determines the degree to which measurements have met
applicable data quality specifications provided in Section A7. Data generated for the parameters
listed in Table Bl-1 at PAMS Required Sites and associated ASLs will undergo verification and
validation prior to reporting to AQS. Data verification is the process of evaluating the
completeness, correctness, and conformance/compliance of data against established method,
procedural, or contractual specifications; verification is meant to ensure that data accurately
reflect the conditions at the site when the observations occurred. Data validation extends the
evaluation of data beyond data verification to determine the quality of a specific data set. The
goal of data validation is to evaluate whether the data quality goals established during the
planning phase have been achieved;13 for example, to determine if season-long precision and bias
met their respective MQOs. A critical component of data validation is also the comparison of the
data being validated to other co-collected or historical data to identify potential anomalies in the
data that may be concealed behind acceptable precision, bias, and completeness metrics (such as
in cases where transient sources bias concentrations temporarily high). Only after a given dataset
has been verified and validated can a DQA be performed to determine if it is fit for its intended
purpose,14 which for PAMS is to assist in the development and refinement of predictive models
for the formation of ground-level O3.
To meet the DQO for supporting ozone modeling efforts, data must meet the MQOs and will
have been verified and validated as described in Section 10 of Revision 3 of the PAMS TAD
which addresses data verification and validation. Data verification and validation are described
briefly in the next several sections.
Monitoring agencies will define and include data verification and validation responsibilities and
activities in this QAPP or in an SOP or combination of SOPs. Such responsibilities and activities
will identify the responsible individuals, detail the procedures, materials, and corrective actions
required at each waypoint in data verification and validation activities. Examples of aspects to
define and describe include (but are not limited to): amounts of data to inspect manually
(defining what comprises a data package for review, e.g., 4 complete hours for each day),
explicit common issues or problems staff need to be aware of (e.g., high concentrations of a
given set of analytes, known misidentified VOCs, VOCs for which automated integration
parameters require frequent adjustment or modification, common background interferences,
calibration drift tendencies, equipment failures, and meteorological events impacting
measurements), data verification and validation tools (e.g., software to evaluate measurements
and identify outliers or anomalous data, and types of visualizations to prepare, and data inputs
for these tools), and documentation to be prepared at each step during the data verification and
validation processes.
Dl.l Data Verification and Validation Responsibilities
Verification and validation of data for the PAMS Required Site Network is the responsibility of
the monitoring agencies that operate the field component of the program, with input from the
carbonyls ASL. The ASL will minimally verify the carbonyls data reported to ensure the data are
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correct and comply with the established laboratory QAPP and SOP(s). The monitoring agency
will include the ASL data verification and validation responsibilities for the PAMS Required Site
carbonyls data in their QAPP. Subsequent specific verification and validation activities will be
described in this QAPP or in an SOP or combination of SOPs. For activities described in the
ASL QAPP or SOPs, these may be included by reference.
Personnel performing data verification and validation activities will:
• Be familiar with the types of data each instrument system produces and the typical
measurement ranges produced by each for various parameters (e.g., typical solar radiation
levels, benzene concentrations, and true NO2 concentrations).
• Be familiar with typical diurnal concentration variations (e.g., the time daily maximum
concentrations occur and the interrelationship of pollutants.) For example, benzene,
toluene, and xylene concentrations usually increase and decrease together due to these
being attributed to mobile sources, whereas ozone typically follows a diurnal cycle with a
peak during the afternoon hours.
• Be familiar with the types of instrument malfunctions that cause characteristic
irregularities in reported data.
• Recognize that cyclical or repetitive variations (at the same time each day or at periodic
intervals during the day) in continuous measurements may be caused by excessive line
voltage or temperature variations. Emissions from nearby sources can also cause
erroneous or non-representative measurements.
D1.2 Data Verification
In the data verification process, PAMS measurement data will be evaluated for completeness,
correctness, and conformance/compliance according to the program requirements. The goal of
data verification is to ensure and document that the reported results reflect the activities
performed and measurements acquired meet the prescribed method performance criteria. Any
deficiencies in the data will be documented and, where possible, resolved by corrective action.
PAMS data verification applies to activities in the field as well as in the ASL performing
carbonyl cartridge extraction and analysis. Data verification includes routine (self) review of
collected data by the instrument operator and subsequent technical (peer) review.
Dl.2.1 Routine (Self) Review
The instrument operator(s) will perform the initial steps of routine (self) review portion of data
verification which include reviewing recorded data to ensure the records are complete and
comply with the acceptance criteria in the monitoring agency SOPs. It is typically most efficient
for this individual to make corrections to collected data and document these corrections such that
the impact of any subsequent problem is minimized immediately. Such reviews typically cover
100% of the collected data such that transcription errors (if applicable) are minimized and that
QC criteria are within acceptable limits.
Recorded data (measurements, observations, etc.) will be reviewed at a frequency that minimizes
the loss of data should errors or conditions be found that risk additional data loss if the problem
is not corrected. This routine (self) review is typically limited in scope to a particular phase of
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the data collection activities and is a first step in the overall data verification process, which
covers the generation of data from the "cradle to the grave." The frequency for the various
activities is specified in Table Dl-1. For example, if the site instrument operator has configured
the true NO2 instrument to automatically analyze a calibration check standard every week but
does not take the time to review the weekly check for several weeks, such a delay in reviewing
the collected data risks losing a week or more of sampling data in the event the instrument lamp
fails and the QC check does not meet acceptance criteria. Ideally depending on the measurement
system, the individual will conduct a cursory review daily when data are generated, preferably in
the morning (verifying nightly QC checks met criteria), to provide a status of the instrument's
present performance.
Table Dl-1. Routine Review Activities and Associated Frequency
Verification Activity
Frequency
Measurements did not exceed the alarm limits set in the DAS
Daily3
The rate of change observed for the analyte is consistent with ambient
data trends (specific to high frequency measurements - e.g. minute data)
Daily3
Measurement data that exceed the instrument calibration range
Daily3
Measurement data are complete (sample collection and COC forms are
not missing information, expected electronic files are recorded, and
logbook entries are complete)
Daily3
Samples/data were collected in accordance with the sample design and
approved SOP
Weekly
Sample collection and handling procedures were followed correctly
Weekly
Data files are properly identified
Weekly
Computer file entries match hand entered data sheets
Weekly
Analytical procedures used to generate data were implemented as
specified
Weekly
Instruments were calibrated properly (i.e., before sampling began, at the
specified frequency, included the proper number of points at levels that
bracketed the range of reported results)
Weekly, as
applicable
QC check criteria were met and corrective actions are taken when criteria
are not met
Daily3, as
applicable
Chromatography is acceptable (stable baseline, adequate peak separation,
etc.), integration parameters provide proper peak integration, and that
analyte identification is appropriate based on the established RT
windows
Daily3
Carbonyls sample holding times were met and the analysis laboratory
reviewed and verified carbonyl analysis data
When carbonyls
data are reviewed
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Verification Activity
Frequency
Deviations from stated procedures or acceptance criteria are documented
and impacted data are flagged or invalidated per monitoring agency
policy
Weekly
Measurements that are known to be invalid because of instrument
malfunctions are invalidated as per monitoring agency policy
Weekly
Data are substituted from a backup in the event of failure of the primary
data acquisition system
Weekly
Corrections and changes to the data records are documented
Continuously
a Daily on normal business days when staff are on duty.
Dl.2.2 Technical (Peer) Review
Once the data have undergone routine review by the instrument operator, the data are to be
comprehensively technically reviewed by an individual (a peer) not involved with the data
generation. The technical review serves to verify that the routine review was completed properly
and expands the routine review activities. The technical reviewer performs many of the same
activities performed by the instrument operator during routine review, but does not verify
instrument operation or status in real time. The technical reviewer verifies correctness of the data
generation process by ensuring that documentation is clear and traceable from the sample
measurement back through to the certified standards and verifies that the data comply with
governing SOPs and this QAPP. The technical reviewers will perform their activities at an
appropriate frequency to ensure technical reviews are completed within a month of the data
collection. More frequent reviews are recommended to maintain a manageable workload. The
technical reviewer will verify (where applicable):
• Measurements below the MDL are reported (not censored) and flagged appropriately
[note - EPA intends to add automatic flagging functions to AOS for data based on the
proximity to the MDL.']
• Concentration measurements exceeding the instrument calibration range were calculated
correctly and flagged appropriately
• Measurement data are complete (sample collection and COC forms are not missing
information, expected electronic files are recorded, and logbook entries are complete)
• Samples/data were collected in accordance with the sample design and approved SOP
• Sample collection and handling procedures were followed correctly
• Data files are properly identified
• Computer file entries match hand entered data sheets
• Analytical procedures used to generate data were implemented as specified
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• Instalments were calibrated properly (i.e., before sampling began, at the specified
frequency, included the proper number of points at levels that bracketed the range of
reported results)
Calibration standards were within expiration
Calibration standards and check standards preparation calculations are correct and that
the nominal (known or theoretical) value is input into the instrument, as appropriate
Supporting equipment to make critical measurements (mass flow controllers, adjustable
pipettes, pressure transducers, etc.) are within calibration and have passed the most recent
applicable calibration checks
Routine QC checks met acceptance criteria
Chromatography is acceptable (stable baseline, adequate peak separation, etc.) and that
analyte identification is appropriate based on the established retention time (RT)
windows
Chromatographic integration is performed correctly and consistently, and manual
integration changes are justified and appropriate
Carbonyls sample holding times were met and the ASL reviewed and verified carbonyl
analysis data
Deviations from stated procedures or acceptance criteria are documented and impacted
data are flagged or invalidated per monitoring agency policy
Measurements that are known to be invalid because of instrument malfunctions are
invalidated as per monitoring agency policy
Data have been substituted from a data backup (such as the instrument) in the event of
failure of the primary DAS
Changes to the data records have been documented and are attributable to the person
making the change
D1.3 Data Validation
Data validation is a process that investigates the individual data points within the context of other
co-collected data, historical data, or data collected at a similar location in proximity to the site to
determine the quality of the data relative to their expected end use. Only after a given dataset has
been verified and validated can a DQA be performed to address the PAMS-specific DQO.
Data validation activities build on the data verification processes described in Section D1.2 and
will not be conducted on data which have not been verified. Additional data review may be
required during data validation, including repeating some steps of the data verification process
such as reviewing QC data, calculations, or raw data. Data validation examines the dataset for
internal, historical, and spatial consistency:
• Level 0 Data Validation - Includes data verification activities discussed in Section D1.2.
Some of these activities can be automated by the use of pre-programmed criteria in DAS
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as an initial review of data. DAS programs may include programmed qualifiers that are
applied when a parameter rate of change or upper range limit is exceeded. These are
various evaluations that a monitoring agency prescribes at a specified frequency (i.e.,
every day, once a week) and comprise the first step in the evaluation of data validity.
• Level 1 Data Validation - Evaluates internal consistency of the dataset to identify values
that appear atypical when compared to the values of the entire dataset. Tests for internal
consistency are conducted to identify measurements that do not conform to expectations -
outliers and extreme differences within the dataset that warrant further investigation.
After tracing the path of the measurement, if nothing unusual is found, the value can be
assumed to be a valid result with an environmental cause. Unusual values are identified
during the data interpretation process as extreme values or outliers. Outliers and extreme
differences can be identified and confirmed by the use of statistical tests, or may be
identified by graphical and visual presentation of the data. Visualization tools (plots,
graphs, charts, etc.) are powerful as they allow the user to quickly identify values that are
atypically higher or lower or that do not conform to a typical or expected pattern, unlike
reviewing data in tabular format. Visualization tools include scatter plots, timeseries
plots, or fingerprint plots, among others, such as those listed in Section 10.4 of Revision
3 of the PAMS TAD.
• Level 2 Data Validation - Data that have undergone Level 1 validation for internal
consistency are then compared with historical data to evaluate temporal consistency of
the dataset with previous datasets. The historical data may be recent (e.g., one week or
one month prior) or may cover a longer period (e.g., the previous year or years). Simple
statistical analysis and visualization tools are useful here, as they enable identification of
values that do not conform to expectations.
• Level 3 Data Validation - Data that have undergone Level 2 validation for temporal
consistency may then be evaluated for spatial consistency against data collected at nearby
sites, i.e., those in the same airshed, regional network, or monitoring agency, to identify
systematic bias.
Levels 2 and 3 data validation will be performed when historical data at the site or nearby
comparable sites are available. The ability to conduct these validation levels is dependent on the
monitoring history (e.g., for PAMS, air toxics programs, criteria pollutant monitoring, etc.) at the
site or nearby sites within the airshed.
Data validation activities will be documented in sufficient detail such that a QA staff member
may recreate the validation as part of the annual ADQ. Data will be validated in portions of time
consisting of one to four weeks' worth of data, depending on the volume of data to be validated,
so that the dataset is manageable. For example, speciated VOCs data will be validated in one-
week portions that include the bracketing weekly precision QC checks. Validating four weeks of
speciated VOCs data in one dataset is unwieldy and is more appropriate for carbonyls data. Data
validation activities should be completed in sufficient time to allow for potential corrections to
data, uploading data to AQS, and confirming data uploads to AQS were successful and accurate.
Data validators are encouraged to begin validation on datasets as soon as data verification has
been completed on the appropriate size dataset as detailed in Table Dl-2.
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Table Dl-2. Dataset Durations (Sizes) for Validation
Parameter
Appropriate Duration (Size) of Data Set
Speciated VOCs
One week's worth - to include bracketing weekly QC checks
Carbonyls
Two to four weeks' worth - ensure concurrent speciated VOCs data are
available for validation
True NO2
Two to four weeks' worth - ensure that QC checks bracket the duration
undergoing validation
Meteorology
Two to four weeks' worth - ensure concurrent pollution data to prepare
pollution roses
D1.4 Reporting of Validated Data to AQS
After the data validation has been completed minimally through Level 1, measurement data may
be uploaded to AQS. As required in 40 CFR 58.16(d), "the state shall report VOC and if
collected, carbonyl, NH3, and HNO3 data from PAMS sites, and chemically speciated PM2.5
mass concentration data to AQS within 6 months following the end of each quarterly reporting
period..." Therefore, PAMS VOC and carbonyl data that are collected in June are due to AQS
by December 31, and data collected in July and August are due to AQS by March 31.
Prior to upload, the data validator will verify flagged data have been qualified appropriately,
which may involve performing automated parity checks on the data translated into AQS format
and performing spot checks on the transformed data. Chemical measurements for speciated
VOCs and carbonyls will include the associated MDL in the AQS coded data. Monitoring
agencies are encouraged to have an independent reviewer verify data have been appropriately
coded for AQS submission. Such verification checks will be documented.
Once reported to AQS, the monitoring agency will query AQS to verify the data were uploaded
properly and perform parity checks to verify there are no discrepancies. Such verifications will
be documented.
Dl.4.1 Reporting Values Below Method Detection Limits (Carbonyls and Speciated VOCs)
Instrument sensitivity for carbonyls and speciated VOCs for the PAMS Required Sites is
characterized by determining the MDL as described in Section 3.3.5.1 of Revision 3 of the
PAMS TAD. The determined MDL for each parameter represents the lowest concentration that
can be detected above background with 99% certainty. Concentrations measured at less than the
MDL, so long as the qualitative identification criteria have been met (analyte is positively
identified), are valid and the measured concentration will be reported to AQS. There will be no
substitution of the values (such as Vz MDL) or censoring (reporting as 0) concentrations
measured below the MDL. Alarms may be set in the DAS to alert users when low values are
recorded; however, the DAS will be configured to permit all data values to be recorded from the
instruments and will not censor data.
For speciated VOCs and carbonyls measurements for which the target analyte is not qualitatively
identified, the concentration will be reported as zero (0) and the QA Qualifier "ND" added when
coded for input to AQS. This combination of concentration and qualifier indicates to the data
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user that the measurement was made but the analyte was not identified and could not be
quantitated.
D2 Data Verification and Validation Methods
The monitoring agency will specify the software and procedures to validate data, where
applicable, within this QAPP. The procedures may be abbreviated within this QAPP provided
proper detail is included by reference in the supporting SOPs describing data verification and
validation. Tools, methods, criteria, and guidance on applying qualifiers to data that are
identified as being of inadequate quality are described in Section 10 of Revision 3 of the PAMS
TAD.
D2.1 Data Verification Methods
Instrument operators and technical reviewers will ensure data are complete and correct and
comply with this QAPP and supporting SOPs. The end result of the data verification is that all
data have been reviewed to ensure that data are traceable - that they were generated with
instruments that had been calibrated with certified standards according to an approved standard
process, that the instrument calibration and other QC checks were performed at the proper
frequency and met criteria, and that all calculations and transformations are correct. Data
verification activities are tailored to verify that data are error-free and are flagged (qualified) or
invalidated when data integrity is compromised.
The routine reviews and technical reviews will include examining data manually and using
automated tools to verify the data. Manual methods include, for example, direct examination of
chromatography data for auto-GCs, 1-minute data for continuous monitoring methods
(meteorology and certain chemical parameters such as true NO2), hand-transcribed data, hand
calculation of calibration data, and site and maintenance logs. Automated methods include
generation and review of summary reports for auto-GC, DAS summary reports and alarm
reports, data completeness reports, and similar reports that provide an aggregation of data to
provide efficient confirmation that data meet criteria for bias, precision, completeness, and
sensitivity.
Data verification activities are tailored to the specific parameter being verified. Specific details
for each parameter type are discussed in detail in Section 10 of Revision 3 of the PAMS TAD.
Monitoring agencies will describe the data verification activities, procedures, and tools in an
SOP or combination of SOPs to ensure that data are correct, complete, and meet technical
acceptance criteria, and when data integrity are impacted, the data are invalidated or flagged to
indicate the deficient aspects of the applicable data. The processes may be briefly summarized
here in this QAPP and will be included by reference (SOP).
The monitoring agency will create checklists to ensure that critical data verification elements are
reviewed, and their review documented during routine reviews and technical reviews. Checklists
will indicate whether each critical element was satisfied. Such checklists will be included in the
SOP(s) prescribing data verification and validation as specified in this QAPP.
D2.2 Data Validation Methods
This section describes general tools for conducting data validation for PAMS Required Site data.
These tools are useful in identifying anomalous data and increasing confidence in datasets;
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however, validators will use a combination of such tools to validate data, and not rely on one
specific tool to confirm or nullify data validity. As mentioned previously, each monitoring
agency will describe the PAMS Required Site data validation process and tools in an SOP or
similar controlled document.
D2.2.1 Data Visualization Methods
Graphical techniques permit comparison of concentrations of each PAMS parameter to the
expected concentrations/measurements and relative concentrations/measurements of other
datasets to inspect for values which stand out. These graphical techniques can combine and
contrast different parameters temporally and spatially to help accentuate data which may stand
out from the dataset and warrant further investigation. Some of the simplest of these graphical
tools are available in Data Analysis and Reporting Tool (DART) and in DAS software systems
and include the following:
• Time series plots
• Scatter plots
• Fingerprint plots
• Stacked bar charts
• Pollution roses
• Box plots
• Diurnal profiles
More information on these tools and methods is available in Section 10 of Revision 3 of the
PAMS TAD. PAMS monitoring agencies will incorporate these tools and methods, as
appropriate, in their data validation procedures and specify the checks and comparisons
applicable to the given parameter type(s). The processes will be included here or included by
reference (SOP).
D2.2.2 Statistical Methods
A critical part in validating data within a dataset and against external (historical and spatial)
datasets is to generate simple statistics. As with data visualization tools, DART and DAS
software packages include automated screening checks and statistical tools that aid in identifying
data that exceed user-defined criteria. Screening checks include performing comparisons of
related pairs or groups of parameters and identifying situations where criteria such as ratios,
sums, and presence or absence of parameters deviate from expected relationships or conditions.
D2.2.3 Examination of Supporting Data
Comprehensive data validation requires the data validator to examine materials and records that
support the reported parameter measurements but are not directly reported data. These
supporting data sources are integral in identifying data that may be compromised and require
qualification or invalidation. As part of Level 1 validation activities, validators will review these
supporting data sources and verify compromised data are appropriately flagged or invalidated, as
appropriate.
Technical Systems Audit Reports: TSAs may uncover nonconformances that can affect the
validity of data. For example, if it is found that a site maintenance worker has stored a gasoline
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container near the inlet probe, the associated speciated VOCs data impacted during that time
period would likely be invalidated. TSA reports and related CAPs will be reviewed during data
validation to ensure findings that impact measurement data quality have been addressed through
corrective action and data validators will assess the impact of any findings on acquired data
undergoing validation.
Audits of Data Quality Reports: Findings from ADQs directly impact reported data and
indicate errors or problems in data transformations, transcriptions, calculations, or reporting. The
findings may result in the need to recalculate or reprocess data, or if the error cannot be
corrected, to invalidate the affected data. For example, an ADQ may identify that the nominal
concentration was incorrectly input as 3.91 instead of 3.19 ppbC input to generate calibration
standards for benzene. Such a situation could probably be corrected and the data reprocessed
with an updated calibration curve for the parameters on the higher molecular weight hydrocarbon
channel (PDMS column) of the auto-GC.
Instrument Performance Audit, Performance Evaluation, and Proficiency Test Results:
Deviations from acceptance or advisory limits during IP As, PEs, or PTs indicate bias is present
in the measurement system. The validator will review IP A, PE, and PT reports for unacceptable
results, will verify that corrective actions have been taken to address the out-of-tolerance
condition, and may qualify or invalidate affected data based on the severity and scope of the
nonconformance. For example, an IPA identifies a flow rate 15% higher than the flow transfer
standard for a carbonyls sampling unit. After further evaluation, if the audit proves to be valid,
and the sampler flow rate is beyond the acceptance criterion, the monitoring agency would either
estimate the associated results with a QA qualifier or invalidate measurement data back to the
most recent passing flow check and invalidate the sample data from that sampling unit when
reporting to AQS.
Laboratory Analysis Result Reports: ASL results reports may include sample narratives or
include QC sample results that provide context for the sample measurements. Data provided by
the ASL will be verified with respect to the laboratory processes and method QC acceptance
criteria; the ASL will flag data when operational or QC criteria nonconformances occur and
notify the site monitoring agency. This will typically involve data flags or comments on
electronic data deliverables. It is the responsibility of the site monitoring agency to ensure that
subsequent sample measurement data transformations and calculations are appropriate, accurate,
and flagged properly.
Precision Sample Results: When available, validators will evaluate the precision of duplicate
and/or collocated sample results to ensure they meet acceptance criteria. Poor agreement
between duplicate or collocated and primary sample pairs is indicative of a problem with the
measurement system or data transformation/reduction process, and will be investigated. Results
for sample pairs will be minimally qualified when precision acceptance criteria are exceeded,
unless a technically justifiable rationale is determined and documented (such as one of the two
cartridges became disconnected during the sampling event). If a systemic problem is found to be
the root cause, affected data may be qualified or invalidated. For example, if collocated
carbonyls samples exceed precision acceptance criteria and corrective action uncovers a leak in
the primary sampling unit inlet, the data from the primary samples would be invalidated back to
the most recent acceptable precision pair.
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Operator Notes and Site-Specific Information: Data validators will review operator notes
recorded in the site logbook, maintenance logs, and on sample collection or COC forms to assess
unusual events or instrument problems that may impact measurement result validity or
representativeness. Examples include unusual events such as forest fires, temporary violations of
siting criteria such as nearby construction, or operational difficulties with the monitoring
instrumentation. The monitoring agency will use its best judgment about the impact of site
conditions on the acceptability of the data and may consult with the EPA PAMS Regional
Representative.
Corrective Action Reports: Data validators will review corrective action reports, whether in-
process or completed, to investigate corrective actions impacting collected measurements
undergoing validation. Conditions deemed to impact sample results may result in corrections to
data, qualification, or invalidation, as appropriate.
D2.2.4 Treatment of Deviations from Requirements
Deviations from procedural or QC criteria call for the monitoring agency to correct the data
where possible (e.g., if a wind direction sensor is installed 180 degrees out of phase), take
corrective action to limit the impact or recurrence of such deviations, appropriately flag or
invalidate affected data when reported to AQS, and notify EPA Regional representatives when a
significant amount of data (e.g., 10% of the quarterly values or the potential inability to meet the
completeness MQO) are affected.
D2.2.4.1 Identifying Compromised Data in AQS
If data affected by deviations cannot be appropriately corrected, the monitoring agency will
identify compromised data within AQS by addition of a qualifier or combination of qualifiers.
Qualifiers associated with PAMS data are indicated in Table D2-1 below. (This list does not
include all possible qualifiers, and monitoring agencies are encouraged to use additional
qualifiers if the PAMS-associated qualifiers do not accurately capture the event.) Note that at the
time this QAPP was published, qualifiers for specific deviations had not been defined and were
not available in AQS; however, EPA periodically updates the AQS qualifier list which is
published at the following link:
https://aas.epa.gov/aasweb/documents/codetables/qualifiers.html
Data compromised by QC criteria failures will either be flagged or invalidated in AQS as
described below and in Tables B5-1 and B5-5 for carbonyls, Table B5-2 for speciated VOCs,
|nd Table B5-3 for true N(J. In situations when no qualifier or combination of qualifiers exists
to adequately describe the valid compromised data, the data should be estimated by adding the
QA qualifier LJ to the data. When invalidating compromised data and no NULL qualifier exists
to describe the rationale for invalidation, the data should be invalidated with the NULL qualifier
AM.
Flagging Data in AQS: Compromised monitoring data will be flagged in AQS only if the data
are considered valid for most purposes and uses. AQS permits users to label each data point with
up to ten QA qualifiers and/or informational (INFORM) qualifiers.
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Invalidating Data in AQS: Data of uncertain origin, data with unacceptable levels of
uncertainty, or data which are known to not be an ambient measurement will not have an
associated measurement value included in AQS. Such data may be the result of instrument
failure, known instrument contamination, irrecoverable data, data corruption, or other issues. If
reported to AQS, data generated from routine QC checks (except auto-GC system blanks),
calibration, determination of MDLs, or instrument troubleshooting for continuous measurement
methods will be coded with a Null qualifier to ensure it is not inadvertently reported as ambient
data. Invalid data are reported to AQS with a Null (NULL) Code Qualifier which eliminates the
associated measurement parameter and indicates the reason for the invalidation. AQS accepts a
single NULL qualifier and does not permit addition of other qualifiers (QA or INFORM) to the
data point.
As discussed further below, data will be qualified and estimated with descriptive QA and
INFORM flags where the data are compromised but remain valid. In general, such qualification
is preferable to invalidation as there remains a measurement value for the data user to access.
The data user can then determine whether to use the data value based on the information
indicated by the associated qualifier(s). Invalidation removes the measurement entirely from the
data point and is therefore of minimal use to an end data user.
Table D2-1. AQS Qualifiers and Null Codes for PAMS
Qualifier
Code
Qualifier Description
Qualifier
Type
Comment
1
Deviation from a CFR/Critical
Criteria Requirement
QA
substitute a more descriptive QA qualifier where
possible
2
Operational Deviation
QA
substitute a more descriptive QA qualifier where
possible
3
Field Issue
QA
substitute a more descriptive QA qualifier where
possible
4
Lab Issue
QA
substitute a more descriptive QA qualifier where
possible
5
Outlier
QA
7
Below Lowest Calibration Level
QA
DI
Sample was diluted for analysis
QA
applies to carbonyls only
DN
DNPH peak less than NATTS TAD
requirement, reported value should be
considered an estimate
QA
applies to carbonyls only
EH
Estimated; Exceeds Upper Range
QA
FB
Field Blank Value Above Acceptable
Limit
QA
HT
Sample pick-up hold time exceeded
QA
applies to carbonyls only
LB
Lab blank value above acceptable
limit
QA
applies to carbonyls only
L.T
Identification of Analyte is
Acceptable; Reported Value is an
Estimate
QA
most common qualifier when an estimate is needed
LK
Analyte Identified; Reported Value
May Be Biased High
QA
LL
Analyte Identified; Reported Value
May Be Biased Low
QA
MD
Value less than MDL
QA
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Qualifier
Code
Qualifier Description
Qualifier
Type
Comment
ND
No Value Detected
QA
NS
Influenced by nearby source
QA
rare - in most situations such data should be invalidated
QX
Does not meet QC criteria
QA
SQ
Values Between SQL and MDL
QA
ss
Value substituted from secondary
monitor
QA
rare - most sites will not have collocated instruments
sx
Does Not Meet Siting Criteria
QA
should require invalidation, but no associated null code
exists
TB
Trip Blank Value Above Acceptable
Limit
QA
applies to carbonyls only
IT
Transport Temperature is Out of
Specs.
QA
applies to carbonyls only
V
Validated Value
QA
VB
Value below normal; no reason to
invalidate
QA
AC
Construction/Repairs in Area
NULL
AD
Shelter Storm Damage
NULL
AE
Shelter Temperature Outside Limits
NULL
AF
Scheduled but not Collected
NULL
AG
Sample Time out of Limits
NULL
AH
Sample Flow Rate out of Limits
NULL
AI
Insufficient Data (cannot calculate)
NULL
should be used in situations where the 75% of the hour
is not met or the sampling period for VOCs is not 40
minutes
AM
Miscellaneous Void
NULL
substitute a more descriptive code where possible
AN
Machine Malfunction
NULL
AP
Vandalism
NULL
AQ
Collection Error
NULL
AR
Lab Error
NULL
AS
Poor Quality Assurance Results
NULL
substitute a more descriptive QA qualifier where
possible
AT
Calibration
NULL
AU
Monitoring Waived
NULL
AV
Power Failure
NULL
AW
Wildlife Damage
NULL
AX
Precision Check
NULL
AY
QC Control Points (zero/span)
NULL
AZ
QC Audit
NULL
used for analysis of the VOCs PT sample & TTP for
ozone & NO2
BA
Maintenance/Routine Repairs
NULL
BB
Unable to Reach Site
NULL
BE
Building/Site Repair
NULL
BF
Precision/zero/span
NULL
BH
Interference/co-
NULL
applies to auto-GC parameters only
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Qualifier
Code
Qualifier Description
Qualifier
Type
Comment
elution/misidentification
BI
Lost or damaged in transit
NULL
applies to carbonyls only
B.T
Operator Error
NULL
BK
Site computer/data logger down
NULL
DA
Aberrant Data (Corrupt Files,
Aberrant Chromatography, Spikes,
Shifts)
NULL
DL
Detection Limit Aialyses
NULL
EC
Exceeds Critical Criteria
NULL
use a more descriptive NULL qualifier when possible
MC
Module End Cap Missing
NULL
applies to carbonyls only
QV
Quality Control Multi-Point
Verification
NULL
sc
Sampler Contamination
NULL
TC
Component Check & Retention Time
Standard
NULL
TS
Holding Time or Transport
Temperature Is Out of Specs.
NULL
recommend use of "HT" QA qualifier instead
XX
Experimental Data
NULL
used for troubleshooting, instrument conditioning, MDL
determination, etc.
IC
Chem. Spills & Indust Accidents
INFORM
rare
ID
Cleanup After a Major Disaster
INFORM
rare
IE
Demolition
INFORM
rare
IH
Fireworks
INFORM
rare
II
High Pollen Count
INFORM
rare
I.T
High Winds
INFORM
rare, may apply to wind speed and direction data
IK
Infrequent Large Gatherings
INFORM
rare
IM
Prescribed Fire
INFORM
rare
IP
Structural Fire
INFORM
rare
IQ
Terrorist Act
INFORM
rare
IR
Unique Traffic Disruption
INFORM
rare
IS
Volcanic Eruptions
INFORM
rare
IT
Wildfire-U. S.
INFORM
rare
J
Construction
INFORM
rare
D2.2.4.2 Corrective Action Process
The monitoring agency's corrective action process will be followed in cases of systematic
problems or problems affecting a significant amount of data. This process is described in Section
CI.2.
D2.2.4.3 Notification of EPA or Other Stakeholders
For serious or systematic problems impacting data, individuals within the monitoring agency
responsible for determining the impact of the data and determining the validation status of the
data will be notified. Stakeholders and users of the data that might be impacted by the validation
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status will also be notified. Monitoring agencies will contact the EPA PAMS Regional
Representative who may themselves notify or may instruct the monitoring agency to notify the
PAMS Program and EPA PAMS QA Leads to provide documentation of corrective actions
affecting the status of a significant amount of reportable data. Such would be the case if the data
impacted represented 10% or more of the season's data or jeopardized the ability to meet the
completeness MQO. These stakeholders will also be notified when corrective actions have been
completed and return to conformance has been demonstrated. Monitoring agencies will include
significant problems in their annual QA reports to management.
D3 Reconciliation with User Requirements
D3.1 Reconciling Results with DQOs
The DQOs and intended uses for the PAMS Required Site Network data are discussed in Section
A7.1. The DQO for the PAMS Required Site Network is to provide a database of ozone
precursors and associated meteorology data that modelers can use to evaluate ozone prediction
models. The MQOs listed in Section A7.3 were established to provide the expected data quality
modelers need. As needed, EPA modelers will evaluate the quality and suitability of the data and
may request revisions to the MQOs which may involve increasing sensitivity, decreasing bias, or
increasing precision, for example. Any such adjustments will be communicated to the PAMS
Required Site Network stakeholders.
As needed, EPA will perform a DQA to assess and characterize the overall network data quality.
EPA will prepare a report aggregating the PAMS QA/QC data for the year which may be
combined with EPA modelers' data quality and suitability evaluation. The report will attempt to
determine whether the PAMS Required Site DQOs are being achieved and whether revisions to
the program and QS are needed. Monitoring agencies will perform a DQA for each of their
PAMS sites to evaluate the site's attainment of the specified MQOs. Monitoring agencies will
include a description of their DQA and the outcomes in the annual QA report described in
Section D2.2.4.3.
D3.2 Interim Corrective Actions
EPA may review PAMS QA/QC data and collected measurements during the first year of the
PAMS Required Site network operation. If such an interim assessment indicates that the stated
MQOs need to be adjusted to meet the intended use, EPA may revise the sampling design for the
PAMS Required Site Network, which may include revising site selection, sampling frequency,
QC measurements frequency and acceptance criteria, and equipment maintenance frequency.
Changes in MQOs may result in the need to adjust PAMS monitoring procedures during
implementation of the program.
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REFERENCES
1. Review of the National Ambient Air Quality Standards for Ozone
https://www.govinfo.gov/content/pkg/FR-2020-12-31/pdf/2020-28871.pdf
2. Cavender, K.A. U.S. EPA OAQPS, Summary of Final Photochemical Assessment
Monitoring Stations (PAMS) Network Design. September 25, 2015. Available at
(accessed May 2023):
http://www3.epa.gov/ttn/naaqs/standards/ozone/data/20150925cavender.pdf
3. Standard Practice for Characterizing Surface Wind Using a Wind Vane and Rotating Cup
Anemometer, ASTM Designation: D 5741-96, Annual Book of ASTM Standards,
Section 11, 1996.
4. Holzworth, G.C. Estimates of Mean Maximum Mixing Depths in the Contiguous United
States .Monthly Weather Review, 92, 235-242, 1964.
5. Holzworth, G.C. Mixing Heights, Wind Speeds, and Potential for Urban Air Pollution
Throughout the Contiguous United States, Publication No. AP-101. Research Triangle
Park, NC: U.S. EPA, 1972.
6. Irwin, J.S., and J.O. Paumier. Characterizing the Dispersive State of Convective
Boundary Layers for Applied Dispersion Modeling. Boundary-Layer Meteorology, 53,
267-296, 1990.
7. Quality Assurance Handbook for Air Pollution Measurement Systems. Volume IV -
Meteorological Measurement, EPA-454/B-08-002, U.S. Environmental Protection
Agency, March 2008. Available at (accessed May 2023):
https://www.epa. gov/ sites/default/files/2021 -
04/documents/volume iv meteorological measurements.pdf
8. U.S. EPA. Technical Note - Use of Electronic Logbooks for Ambient Air Monitoring
04/20/2016. Available at (accessed May 2023):
https://www.epa.gov/sites/production/files/2017-
02/documents/electronic logbook final 4 20 16.pdf
9. Quality Assurance Handbook for Air Pollution Measurement Systems. Volume II -
Ambient Air Quality Monitoring Program, EPA-454/B-17-001, U.S. Environmental
Protection Agency, January 2017. Available at (accessed May 2023):
https://www3.epa.gov/ttn/amtic/files/ambient/pm25/qa/Final%20Handbook%20Documen
t%201 17.pdf
10. Center for Environmental Research Information, Office of Research and Development.
U.S. Environmental Protection Agency Compendium Method TO-11 A. Determination of
Formaldehyde in Ambient Air Using Adsorbent Cartridge Followed by High
Performance Liquid Chromatography (HPLC) [Active Sampling Methodology],
Available at (accessed May 2023):
https://www3.epa.gov/ttnamtil/files/ambient/airtox/to-llar.pdf
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11. U.S. EPA. EPA Traceability Protocol for Assay and Certification of Gaseous Calibration
Standards. EPA/600/R-12/531. May 2012. Available at (accessed May 2023):
https://cfpub.epa.gov/si/si public file download.cfm?p download id=522029&Lab=NR
MRL
12. U.S. EPA. Transfer Standards for Calibration of Air Monitoring Analyzers for Ozone.
Technical Assistance Document. EPA-454/B-13-004, October 2013. Available at
(accessed May 2023): https://www.epa.gov/sites/default/files/2020-
09/documents/ozonetransferstandardguidance.pdf
13. U.S. EPA. 2002. EPA QA/G-8, Guidance on Environmental Data Verification and
Validation. (EPA/240/R-02/004). Washington, DC. Available at
https://www.epa.gov/sites/production/files/2015-06/documents/g8-final.pdf accessed
May 2023.
14. U.S. EPA. 2006. EPA QA/G-9R, Data Quality Assessment: A Reviewer's Guide
(EPA/240/B-06/002). Washington, DC. Available at
https://www.epa.gov/sites/production/files/2015-08/documents/g9r-final.pdf accessed
May 2023.
15. U.S. EPA. 2023. Technical Assistance Document for Sampling and Analysis of Ozone
Precursors for the Photochemical Assessment Monitoring Stations Program. Revision 3.
Available at (accessed May 2023): https://www.epa.gov/amtic/photochemical-
assessment-monitoring-stations-pams
16. U.S. Census Bureau. Metropolitan and Micropolitan Statistical Areas Population Totals
and Components of Change: 2020-2021. Available at (accessed May 2023):
https://www.census.gov/data/tables/time-series/demo/popest/2020s-total-metro-and-
micro-statistical-areas.html
17. Code of Federal Regulations, Appendix A to Part 58—Quality Assurance Requirements
for Monitors Used in Evaluations of National Ambient Air Quality Standards. Available
at (accessed May 2023): https://www.ecfr.gov/current/title-40/chapter-I/subchapter-
C/part-58#Appendix-A-to-Part-58
18. U.S. EPA. 2000. EPA Order: Policy and Program Requirements for the Mandatory
Agency-Wide Quality System. Available at (accessed May 2023):
https://www.epa.gov/sites/default/files/2013-10/documents/2105Q.pdf
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APPENDIX A
SLT MONITORING AGENCY QAPP APPROVAL
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Approval of PAMS Required Site SLT Monitoring Agency QAPP
The SLT Monitoring Agency has added or edited the National PAMS Required Site Quality
Assurance Project Plan to specify details specific to the monitoring agency in the following
Sections (indicated in yellow in the National QAPP):
Section
Section Title
Section
Section Title
A3
Distribution List
B3
Sample Handling and Custody Requirements
A5.1
PAMS Required Site(s)
B5.1
Quality Control for Field Activities (QA Sample
Collection)
A6.2
Personnel and Organization
B6.1
Instrument Acquisition
A6.3
Schedule for PAMS Required Site Activities
B6.4
Instrument Maintenance
A7.3.1
Waiver for Speciated VOCs by Auto-GC
B7.2
Calibration Support Equipment
A8
Special Training Requirements/Certification
B8
Inspection/Acceptance Requirements for Supplies
and Consumables
A9
Documentation and Records
BIO
Data Management
A9.1
Recording of Data
C.1.1.1
Instrument Performance Audits
A9.4
Records Archival and Retention
CI.2
Corrective Actions
B1
Sampling Process Design (Waivers)
C2
Reports to Management
Bl.1.2
Speciated VOCs To Be Measured
D1
Data Review, Verification, and Validation
Requirements
B2
Sampling and Measurement Methods
Dl.l
Data Verification and Validation Responsibilities
B2.1
Chemical Parameters - Inlet Composition
D2
Data Verification and Validation Methods
By signing below, the signatories indicate that the SLT Monitoring Agency has provided the
appropriate details for the Sections listed above and has clearly identified all deviations from the
National PAMS QAPP Revision 1.0 and provided documentation that the revisions provide
equivalent or higher quality monitoring data.
Delegated QAPP Approval Authority
The has been delegated full QAPP Approval and signature
Agency Name
authority by EPA Region .
State/Local/Tribal Agency
Print Name: Signature:
Date: Director
Print Name: Signature:
Date: Quality Assurance Officer
EPA Regional Office Acknowledgment or Approval
Print Name: Signature:
Date: PAMS Regional Coordinator
Print Name:
Date:
Signature:
Quality Assurance Manager
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APPENDIX B
EXAMPLE QUALITY BULLETIN
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Example Quality Bulletin
Number:
Date:
Page of
Supersedes No,:_
Dated:
Background
Subject:
QA Lead
Y/N
Replace and Discard Original
Add Material to Document
Retain this bulletin until further notice
Discard this bulletin after noting
contents
This bulletin will be invalid after: Date:
This bulletin will be incorporated into
quality Procedure No. by Date:
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APPENDIX C
EXAMPLE CHAIN-OF-CUSTODY FORM
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PAMS REQUIRED SITE NETWORK SAMPLE CHAIN OF CUSTODY FORM
Sample ID
Presample
Storage1
Sample Type2
Sample Start
(date & time)3
Sample Stop
(date & time)3
Sample
Shipment
Temperature4
Sample Storage
at Laboratory5
1 Media storage location (e.g. refrigerator identifier) and storage temperature range {should be <4°C)
2 Ambient Primary (AP), Ambient Duplicate (AD), Ambient Collocated (AC), Field Blank (FB), Trip Blank (TB), Exposure Blank (EB)
3 Note the sample start and end times were recorded on the sample collection form and are transcribed to this form
4 Sample shipment temperature may indicate "in cooleron ice" and may include thermometer identifier
5 Sample storage location (e.g. refrigerator identifier) and storage temperature range (should be <4°C)
These
Transfer6*7
Date/Time
Transfer7
Date/Time
fields are
Relinquished by:
Received by
to be
Relinquished by:
Received by
completed
Relinquished by:
Received by
as
Relinquished by:
Received by
needed:
Relinquished by:
Received by
Relinquished by:
Received by
6 Collected samples were handled according to SOP.
7 Document transfer of collected samples to/from a shipper or courier, as appropriate, and record shipper and tracking information
page of
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APPENDIX D
EXAMPLE STAFF PROFICIENCY TRAINING FORM
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EXAMPLE PAMS REQUIRED SITE TRAINING FORM
Staff Member
The staff member has read the following PAMS Required Site quality system documents:
Document
Version
and
Effective
Date
Date
Read/Initials
Version
and
Effective
Date
Date
Read/Initials
Version
and
Effective
Date
Date
Read/Initials
Monitoring Agency
PAMS Required
Site QAPP
Determination of
Speciated VOCs by
Auto-GC
Collection of
Carbonyls Samples
Measurement of
True NO2
Measurement of
Mixing Layer
Height by
Ceilometer
Measurement of
Wind Speed and
Wind Direction
Measurement of
Solar Radiation and
UV Radiation
Measurement of
Precipitation
Measurement of
Temperature,
Relative Humidity,
and Barometric
Pressure
Data Verification
and Validation
Other SOPs as
defined by the
monitoring agency
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INITIAL DEMONSTRATION OF CAPABILITY
Staff will read the current version of the SOP governing the procedure(s) and complete an initial
demonstration of capability (IDOC) which will include either:
a. Observing a trained individual perform the procedure(s), performing the procedure with
assistance from a trained individual, and performing the procedure(s) independently
under the observation of a trained individual, or
b. Performance of the procedure(s) independently under the observation of a QA staff
member or supervisor
Procedure
Date Trainee
Observed
Trainer
Perform
Procedure(s)
Date Trainee
Performed
Procedure(s) with
Trainer
Date Trainee
Performed
Procedure(s)
Independently
Under
Observation
Approval by
Director to
Perform
Procedure
Independently
Determination of
Speciated VOCs by Auto-
GC
Collection of Carbonyls
Samples
Measurement of True NO2
Measurement of Mixing
Layer Height by
Ceilometer
Measurement of Wind
Speed and Wind Direction
Measurement of Solar
Radiation and UV
Radiation
Measurement of
Precipitation
Measurement of
Temperature, Relative
Humidity, and Barometric
Pressure
Other Procedures as
necessary
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CONTINUING DEMONSTRATION OF CAPABILITY
Once the IDOC is completed, staff will read the current version of the SOP governing the
procedure(s) and complete a continuing demonstration of capability (CDOC) which will include
performance of the procedure(s) independently under the observation of a QA staff member,
supervisor, or other trained staff member.
Procedure
Date Trainee Performed
Procedure(s) Independently
Under Observation
Approval by Director to Perform
Procedure Independently
Determination of Speciated
VOCs by Auto-GC
Collection of Carbonyls Samples
Measurement of True NO2
Measurement of Mixing Layer
Height by Ceilometer
Measurement of Wind Speed
and Wind Direction
Measurement of Solar Radiation
and UV Radiation
Measurement of Precipitation
Measurement of Temperature,
Relative Humidity, and
Barometric Pressure
Other Procedures as necessary
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ADDITIONAL AND SUPPLEMENTAL TRAINING
The staff member has received the following additional or supplemental training: (provide
documentation examples, such as attendance forms, certificates of course completion, etc.)
Training Title
Type of Training1
Initials/Date
1 ATS = Attended training sessions, ATW = Attended training webinars, RTV = Reviewed training videos, RTC = Received
training certifications - refer to attached certificates
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APPENDIX E
EXAMPLE SITE VISIT CHECKLIST
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Site operators should complete this checklist with each visit to the PAMS Required Site during PAMS
season. Observations recorded in the site log may be referenced as "RSL" (refer to site log).
Site ID: Date of Visit and Operator Initials:
Check
OK? (Y/N)
Comments
GENERAL
Vandalism
Operational Hazards (broken
decking, stinging insects,
snakes, icicles, etc.)
Nearby recent construction
Landscaping activities
(mowing, tree trimming,
etc.)
Weather damage
Shelter environmental
conditions within
specification
MANIFOLD INLET
Inlet probe clear (no insect
nests, debris, etc.)
Bypass fan operating
Manifold flow within spec
Connections to manifold
secure
Manifold cleaned within
prescribed frequency
SITE LOG
Visitors or events since last
visit?
Log updated with this visit?
DATA ACQUISITION
SYSTEM
Verify no DAS error
messages/alarms
Ensure DAS communication
with instruments
DAS clock is accurate to ± 1
minute
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Check
OK? (Y/N)
Comments
TRUE N02
Instrument display is on
No error messages/alarms
Instrument reading is
reasonable for scheduled
monitoring (ambient, span,
zero)
Calibration cylinders > 400 psi
Zero air generator cycling
properly
Calibrator does not show
errors/alarms
Instrument clock is accurate ±
1 minute
CARBONYLS
Instrument status correct for
sampling program
If sampling day, instrument is
sampling and flow is correct (1
LPM)
If non-sampling day, program
displays correct date for next
sample
Sample cartridges are installed
correctly
Sampling unit does not show
error messages/alarms
AUTO-GC
No error messages/alarms
Correct sequence line is active
(should be ambient sample
during daytime)
Correct part of the
measurement cycle is active
(sample collection, sample
desorption, GC analysis, GC
cooling, etc.)
Hydrogen generator has
sufficient water and does not
show error messages/alarms
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Check
OK? (Y/N)
Comments
Carrier gas, RTS, H2 cylinders
have sufficient pressure
Instrument clock is accurate ±
1 minute
Zero air generators) operating
properly
Compressor operating properly
METEOROLOGY
Complete weekly meteorology
sensor visual checklist
Temperature is reasonable
with ambient conditions and
recorded in DAS
Wind speed and direction
operation are reasonable for
conditions
Shrouds for thermometer and
hygrometer are clear of debris
Solar and UV data in DAS are
reasonable to conditions
(sunny, cloudy, etc.)
Precipitation gauge is
operational and has registered
precipitation events in DAS
Ceilometer lens is clean
Meteorology measurements
reasonable compared to nearby
NWS sites
COMMENTS:
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APPENDIX F
GUIDANCE FOR PAMS MONITORING AGENCIES TO INCORPORATE PAMS
REQUIREMENTS INTO ANNUAL MONITORING NETWORK PLANS
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Guidance for (1) New Photochemical Assessment Monitoring Stations
(PAMS) Required Network Implementation Plans (and waivers), and
(2) New Enhanced Monitoring Plans (EMPs).
Air agencies are required to establish and begin operating additional PAMS networks resulting
from a new census (see 40 CFR 58.14(b)). This guidance and the following two attachments
represent templates for consideration for implementation plans for the (1) Required Monitoring
Network PAMS site (at certain NCore sites) and (2) for the EMPs required for moderate or
higher nonattainment areas (NA) and states within the Ozone Transport Region (OTR). These
templates should help in the development of implementation plans that should be included in the
annual monitoring network plan as required by 40 CFR 58.10.
For higher population NCore sites (i.e., those in Core Based Statistical Areas (CBSAs) greater
than 1,000,000), the Required Monitoring Network Implementation Plan must include the final
site location, the types of instruments to be installed, and frequency of measurements that will be
made. The Required Monitoring Network Implementation Plans should state the methods and
procedures that will be followed as stipulated in the final PAMS rule, national PAMS Quality
Assurance Program Plans (QAPP), and the PAMS Technical Assistance Document (TAD). The
expected auto gas chromatograph (GC) monitoring systems will require a level of
expertise which may not be currently available to monitoring agencies. Early planning is crucial
to meeting deployment and measurement deadlines.
The final ozone national ambient air quality standards (NAAQS) rule has waiver provisions
which allow monitoring organizations which have low concentrations of ozone (as defined in the
rule) to request a waiver from implementing PAMS at an otherwise required NCore site entirely1,
or to make PAMS measurements at alternative locations such as existing PAMS sites or existing
National Air Toxics Trends Station (NATTS) sites11. In addition, while it is expected that auto
GCs will be used for VOC measurements in order to report hourly measurements, there is an
opportunity to seek a waiver and instead collect three 8-hour canister samples, once every three
days111. In addition, a monitoring organization may request that it utilize data from a nearby
meteorological station rather than establish its own™. Monitoring organizations must request a
waiver from any deviation described above. The waivers will be in the form of a one- or two-
page technical memo that describes the need and rationale for the waiver, and any other requisite
supporting information including alternative locations (such as existing PAMS sites), and/or
proposed alternative measurement procedures (see end notes to this memo in this regard). The
waiver will be submitted to the EPA Regional Administrator for review and approval. Waivers
may be submitted with the required Annual Monitoring Network Implementation Plan or as a
standalone document, if agreed to by the local EPA Regional Office.
• Monitoring organizations should submit the draft Implementation Plan for required
PAMS locations and any waivers to EPA Regional Offices by May 1 of the year prior to
the start of sampling, along with their draft Annual Monitoring Network Plan (AMNP).
This will ensure that a 30-day public notice is provided, and EPA may provide comments
during that time. Final Implementation Plans should be submitted by July 1 of the year
prior to the start of sampling along with the AMNP.
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• As with all AMNPs, the EPA Regions will have 120 days to review the waivers and the
proposed PAMS Implementation Plans, and provide a formal response to the state's plan
(and waiver if proposed) no later than October 31 of the year prior to the start of
sampling (based on the submission of the final AMNP by July 1).
All 03 moderate (and worse) NA areas and states in the OTR must develop and implement
EMPs. These EMPs must include the final site location, the types of instruments to be installed,
and the frequency of measurements that will be made at the site. They should also identify the
rational for proposed measurements, and in the case of EMP sites within the OTR, must take into
account interstate and interregional transport of ozone and ozone precursors.
• As required in 40 CFR 58.10(a)(l 1), an EMP for ozone shall be submitted to the EPA
Regional Administrator no later than two years following the effective date of a
designation to a classification of Moderate or above O3 nonattainment. Monitoring
organizations should submit the draft EMPs for areas in the OTR and moderate NAs to
EPA Regional Offices by May 1, along with their draft AMNP. This will ensure that a
30-day public notice is provided, and the EPA can provide comments during that time.
Final EMPs should be submitted by July 1 along with the AMNP.
• As with all AMNPs, the EPA Regions will have 120 days to review the proposed EMPs,
and provide a formal response to the state's plan, no later than October 31. (Based on the
submission of the final AMNP by July 1).
While not a comprehensive list, EMP may include additional 03 sites; additional NOx or NOy
sites; additional VOC/carbonyl measurements (different time periods, different locations and
different precursors); or enhanced upper air measurements. EPA encourages that all EMPs be
developed in consideration of and in coordination with other nearby PAMS/ EMPs. In the OTR,
EPA intends that this coordination should occur and include all states in the OTR. For the states
in the OTR, EPA encourages a comprehensive EMP with well-defined objectives.
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References
' Appendix D of 40 CFR Part 58, 5(f) allows an otherwise required NCore site from implementing PAMS if the
ozone design value is less than 85% of the NAAQS, and the area is not considered important regarding upwind or
downwind nonattainment areas. States/ locals which have such an area should consult with the local EPA Regional
Office. Such an area would need to submit a request to the EPA Regional Administrator and include a discussion of
design values in the area, and all areas nearby- including a discussion of the closest ozone nonattainment area(s),
and its relationship (or lack thereof) to air quality in the area seeking a waiver. That request should be part of the
AMNP described above, and EPA would approve (or disapprove) the request when it acts on the AMNP. Any
alternative method of seeking such a waiver should be agreed with the appropriate EPA Regional Office.
II Appendix D of 40 CFR Part 58, 5(c) allows for the collection for required PAMS measurements at an alternative
location. For areas considering such a request, it must be demonstrated that the alternate location will provide
representative and useful data for regional or national tracking of trends in ozone precursors. For example, it may be
a nearby location that has measured PAMS compounds in the past, and could be beneficial from a trends
perspective. Any request should meet the specific requirements of the rule, be included in the AMNP, and to be
acceptable, be approved by the EPA Regional Administrator.
III Appendix D of 40 CFR Part 58, 5(d) provides that the EPA Regional Administrator may grant a waiver from
continuous VOC measurements to allow for speciated VOC measurement as three 8-hour averages on every third
day during the ozone season. EPA will consider waivers where precursor concentrations are low, or for other
logistical or programmatic constraints. In considering approval of a waiver, the EPA Regional Administrator will
consider the ability to compare and utilize other nearby PAMS (and EMP) locations to ensure the data collected can
be used in a useful manner. Any request should meet the specific requirements of the rule, be included in the
AMNP, and to be acceptable, be approved by the EPA Regional Administrator.
IV Appendix D of 40 CFR Part 58, 5(e) provides that the EPA Regional Administrator may grant a waiver allowing
representative meteorological data from nearby monitoring stations to be used to meet the meteorological
measurements required. To be acceptable, a request must provide for the location of the alternative measurements, a
detailed description of the appropriateness and representativeness of the location relative to PAMS location,
assurance that the data will always be available, and ensure that the data meet appropriate EPA quality assurance
requirement for those measurements. Any request should meet the specific requirements of the rule, be included in
the AMNP, and to be acceptable, be approved by the EPA Regional Administrator.
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PAMS Monitoring Implementation Network Plan
Example
Monitoring Organizations Required to Operate at NCore Sites
(Insert monitoring organization) formerly operated two Photochemical Assessment Monitoring
Stations (PAMS) sites in the air monitoring network in 2015, at the (Insert Location) and (Insert
Location) sites. However, the recently revised monitoring rule (80 FR 65292; October 26, 2015)
requires PAMS measurements June 1 through August 31 at NCore sites that are located in
Core-Based Statistical Areas (CBSAs) with populations of 1,000,000 or more.
Network Decision
~ The NCore site located at (Insert Location) will serve as the location of the
required PAMS site and will measure the following parameters described
below. An Inventory of equipment used at the site(s) is provided in attachment 2
~ We request a waiver from implementing PAMS at an otherwise required NCore site
entirely, or to make PAMS measurements at alternative locations such as existing PAMS
sites or existing NATTS sites. Rationale for this waiver is provided in Waiver attachment
Auto GC Decision
Volatile organic compounds (VOCs) - A complete list of the targeted compounds is provided
in Table 1.
~ We will measure hourly speciated VOC measurements with an auto-gas chromatograph
(GC) using (insert manufacturer).
~ We request a waiver to allow three 8-hour samples every third day as an alternative to daily
hourly speciated VOC measurements at locations (insert locations). Rationale for this waiver
is provided in Waiver Attachment
Meteorology Measurements Decision - Note: EPA is suggesting the use of ceilometers
for determining mixing height, however other types of meteorological equipment that
provide for an indication of mixing height can be proposed
~ Will measure wind direction, wind speed, temperature, humidity, atmospheric pressure,
precipitation, solar radiation, UV radiation, and mixing height. We have elected to use the
following instrumentation to measure the parameters described above: (insert equipment
models and manufacturer).
~ We request a waiver to allow meteorological measurements to be obtained from other
nearby sites. Rationale for this waiver is provided in the Waiver attachment.
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Other Required Measurements
Carbonyls - Carbonyls sampling at a frequency of three 8-hour samples on a one-in-three-
day basis (-90 samples per PAMS sampling season) using (insert sampler and analytical
manufacturer). Sites will be required to measure and report formaldehyde and
acetaldehyde and are encouraged to measure and report acetone and benzaldehyde.
The TO-11A test method, as used in the National Air Toxics Trends (NATTS) program3
will be used.
Nitrogen Oxides - Will monitor for NO and NOy (total oxides of nitrogen) in addition to true
NO2. The true NO2 is required to be measured with a direct reading NO2 analyzer, cavity
attenuated phase shift (CAPS) spectroscopy or photolytic-converter NOx analyzer. We
have elected to use (insert type and manufacturer) for the true NO2 measurement. NO
and NOy will be measured using a (insert manufacturer).
Table 1 PAMS Target Speciated VOCs List
Priority Compounds
Optional Compounds
1,2,3-
trimethylbenzene a
m-ethyltoluene a
1,3,5-
trimethylbenzene
isopropylbenzene b
1,2,4-
trimethylbenzene a
n-butane
1-pentene
m-diethlybenzene
1-butene
n-hexane b
2,2-dimethylbutane
methylcyclohexane
2,2,4-
trimethylpentane b
n-pentane
2,3,4-
trimethylpentane
methylcyclopentane
benzene a b
o-ethyltoluene a
2,3-dimethylbutane
n-decane
cis-2-butene
o-xylene a b
2,3-
dimethylpentane
n-heptane
ethane c
p-ethyltoluene
2,4-
dimethylpentane
n-nonane
ethylbenzene a b
propane
2-methylheptane
n-octane
ethylene
propylene
2-methylhexane
n-propylbenzenea
isobutane
styreneab
2-methylpentane
n-undecane
isopentane
toluene a b
3-methylheptane
p-diethylbenzene
isoprene
trans-2-butene
3-methylhexane
trans-2-pentene
m&p-xylenes a b
total non-methane
organic carbon
(TNMOC)
3-methylpentane
a/p-pinene
acetylene
1,3 butadiene b
cis-2-pentene
carbon tetrachloride b
cyclohexane
ethanol
cyclopentane
tetrachloroethylene b
Source: Revisions to the Photochemical Assessment Monitoring Stations
Compound Target List. U.S. EPA, November 20, 2013
a Important SOAP (Secondary Organic Aerosols Precursor) Compounds
b HAP (Hazardous Air Pollutant) Compounds
c Non-reactive compounds, not considered to be VOC for regulatory purposes
3 See NATTS Technical Assistance Document for TO-11A method.
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PAMS Monitoring Implementation Network Plan
Example
Monitoring Organizations Not Required to Operate at NCore Sites
(Insert monitoring organization) formerly operated (x#) Photochemical Assessment Monitoring
Stations (PAMS) sites in its air monitoring network in 2015, at the (Insert Location) and (Insert
Location) sites. The recently revised ozone NAAQS rule1 requires PAMS measurements at
NCore sites that are located in Core-Based Statistical Areas (CBSAs) with populations of
1,000,000 or more. Since (Insert monitoring organization) NCore sites are located in CBSAs
with populations less than one million, this requirement does not apply (insert monitoring
organization). (In some cases, a state may have an NCore site that requires PAMS
measurements, but additional "Enhanced Monitoring" sites are necessary to adequately
characterize the problem.) States with moderate or above ozone nonattainment areas and
states within the Ozone Transport Region (OTR) are required to develop and implement
Enhanced Monitoring Plans (EMPs). These EMPs are intended to provide monitoring
organizations with the flexibility to implement additional monitoring to suit the needs of their area
such as additional ozone, ozone precursor, and/or meteorological monitoring activities. (For an
area in the OTR include the following: In developing this plan, we have coordinated with all
other states (and DC) in the OTR and EPA Regions 1, 2, and 3. As a contiguous area of
interregional transport, we have agreed to the spatial distribution of these monitoring locations,
as well as the type and frequency of the air quality (and other measurements).
(Insert monitoring organization) has determined the EMP measurement options will include (but
are not limited to) additional ozone air measurement at (insert location), upper air
measurements (insert location), measurements of total VOC or enhanced/reduced amount of
VOCs/carbonyl species (identify), additional nitrogen dioxide monitoring (insert location), and
additional meteorology/boundary layer measurements. This required EMP reflects local needs
within the context of interstate, interregional transport of ozone and ozone precursors.
180 FR 65292; October 26, 2015
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Attachment 1 Waiver Requests and Rationale
Waiver from implementing PAMS at an otherwise required NCore site (waiver
could be either in its entirety, or to be at a different location)
Rationale for this waiver
Auto GC Waiver Request
We request a waiver to allow three 8-hour samples every third day as an
alternative to daily hourly speciated VOC measurements at locations (insert
locations).
Rationale for this waiver
Meteorological Waiver Request
We request a waiver to allow meteorological measurements to be obtained from
other nearby sites.
Rationale for Waiver
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Attachment 2 Equipment Inventory
(Example)
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Region
2
State
New York
AQSID
36-081-0124
CBSA
ew York-Newark-Jersey City, NY-NJ-PA
Parameter
Category
Detail
Site
Is the AQS site ID listed above the expected PAMS Core site
location?
No
What is the status of the decision for the expected PAMS Core
site location (not started, draft, or final)?
Not Started
Is there an alternate PAMS Core site location selected?
Yes
Identify type of alternative site (existing PAMS, NATTS, etc)
Existing PAMs
Alternate site AQS ID (if known)
36-005-0133
Mixing Height
Is there an existing functional ceilometer or other similar
instrument available for use?
No but State Installing Network
current location (at future PAMS Core site, at other site, not
applicable)
instrument type (ceilometer, radar profiler, etc)
manufacturer
model
date purchased
comments
Mesonetwill include:
Auto GC
Is there an existing Auto GC available for use?
Yes
current location (at future PAMS Core site, at other site, not
applicable)
At Site
manufacturer
Agilent/Markes
model
7890A/Unity Air Server 2
date purchased
04/2016//07/2015
Does it have a service contract?
GC under warranty/Working on AC
for Markes now
comments
True N02
Is there an existing true N02 instrument available for use?
No
current location (at future PAMS Core site, at other site, not
applicable)
instrument type (photolytic conversion, cavity ringdown, CAPS,
etc)
manufacturer
model
date purchased
comments
NOx analyzer at site
Carbonyls Sampling
Is there an existing sequential carbonyls sampling unit or
similar instrument available for use?
Yes
current location (at future PAMS Core site, at other site, not
applicable)
In storage at Rensselaer, Site has
two channel unit now.
manufacturer
Atek
model
8000
date purchased
2012
comments
Carbonyls Analysis
Does the site currently have a support laboratory for
carbonylsor plans to use a support laboratory?
Yes, in house
laboratory name
NYSDEC Air Resources Laboratory
comments
Barometric Pressure
instrument type (aneroid barometer, etc)
Yes - Electronic
manufacturer
Vaisala
model
WT520
date purchased
comments
UV Radiation
instrument type (UV radiometer, etc)
No
manufacturer
model
date purchased
comments
Solar Radiation
instrument type (pyranometer, etc)
No
manufacturer
model
date purchased
comments
Precipitation
instrument type (tipping bucket, weighing, etc)
Electronic Gauge - Weighing
manufacturer
ETI Instrument Systems
model
NOAH IV
date purchased
2011
comments
Data in NADP Database
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United States Office of Air Quality Planning and Standards Publication No. EPA-454/R-23-003
Environmental Protection Air Quality Assessment Division May 2023
Agency Research Triangle Park, NC
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