TECHNICAL ASSISTANCE DOCUMENT
FOR THE

NATIONAL AIR TOXICS TRENDS STATIONS PROGRAM

Revision 3

Prepared for:

U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards (C3 04-06)
Research Triangle Park, NC 27711

Prepared by:
Battelle
505 King Avenue
Columbus, OH 43201

October 2016


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DISCLAIMER

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

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CONTENTS

LIST OF FIGURES	xi

LIST OF TABLES	xi

ACRONYMS AND ABBREVIATIONS	xiii

1.0: INTRODUCTION	1

1.1	Background	1

1.2	Target Analytes: Analytes of Critical Concern/Risk Drivers	1

1.3	Importance of Adherence to Guidelines	4

1.4	Overview of TAD Sections	5

1.5	Critical Changes and Updates from Revision 2 of the NATTS TAD	6

1.6	Good Scientific Laboratory Practices	7

1.6.1 Data Consistency and Traceability	7

1.7	NATTS as the Model for Air Toxics Monitoring	7

1.8	References	8

2.0: IMPORTANCE 01 DATA CONSISTENCY	9

2.1	Data Quality Objectives and Relationship to the Quality Assurance Project

Plan 	9

2.1.1	Representativeness	11

2.1.2	Completeness	11

2.1.2.1 Make-up Sample Policy	11

2.1.3	Precision	12

2.1.4	Bias	13

2.1.4.1	Assessing Laboratory Bias - Proficiency Testing	13

2.1.4.2	Assessing Field Bias	14

2.1.5	Sensitivity	14

2.2	NATTS Workplan	15

2.3	Quality System Development	15

2.4	Siting Considerations	17

2.4.1	Sampling Instrument Spacing	17

2.4.2	Interferences to Sampling Unit Siting	18

2.4.3	Obstructions	18

2.4.4	Spacing from Roadways	19

2.4.5	Ongoing Siting Considerations	19

2.5	References	20

3.0: QUALITY ASSURANCE AND QUALITY CONTROL	21

3.1	NATTS Quality Management Plan	21

3.2	NATTS Main Data Quality Objective, Data Quality Indicators, and
Measurement Quality Objectives	21

3.3	Monitoring Organization QAPP Development and Approval	21

3.3.1 Development of the NATTS QAPP	22

3.3.1.1	NA TTS QAPP - Program DQOs, DQIs, andMQOs	22

3.3.1.2	NA TTS QAPP - Performance Based Method Criteria	22

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3.3.1.3 NA TTS QAPP - Incorporating Quality System Elements	23

3.3.1.3.1	Standard Operating Procedure Documents	23

3.3.1.3.2	Corrective Action Process	24

3.3.1.3.3	Quality Assurance Unit and Internal Audit
Procedures	26

3.3.1.3.4	Calibration of Instruments	27

3.3.1.3.4.1 Calibration Verification (Checks)	31

3.3.1.3.5	Document Control System	31

3.3.1.3.6	Training Requirements and Documentation, and
Demonstration of Capability	32

3.3.1.3.6.1	Initial Demonstration of Capability	33

3.3.1.3.6.2	Ongoing Demonstration of Capability	33

3.3.1.3.7	Sample Custody and Storage	34

3.3.1.3.8	Traceability of Reagents and Standard Materials	34

3.3.1.3.9	Labeling	35

3.3.1.3.10	Early Warning Systems - Control Charts	35

3.3.1.3.11	Spreadsheets and Other Data Reduction Algorithms	36

3.3.1.3.12	Software Validation, Testing, Updating, and
Upgrading	36

3.3.1.3.12.1	Software Validation	36

3.3.1.3.12.2	Software Testing	37

3.3.1.3.12.3	Software Updating and Upgrading	37

3.3.1.3.13	Review of Records	37

3.3.1.3.14	Data Verification and Validation	38

3.3.1.3.14.1Data Verification	38

3.3.1.3.14.2Data Validation	39

3.3.1.3.15	Reporting of Results to AQS	40

3.3.1.3.15.1 Corrections to Data Uploaded to AQS	45

3.3.1.3.16	Records Retention and Archival, and Data Backup	45

3.3.1.3.17	Safety	45

3.3.2 Standard Operating Procedures	45

3.4 References	47

4.0: COLLECTION AND ANALYSIS METHODS	48

4.1	Method Detection Limits	48

4.1.1	Frequency of Method Detection Limit Determination	51

4.1.2	MDL Measurement Quality Objectives	51

4.1.3	Determining MDLs	52

4.1.3.1	MDLs via 40 CFR Part 136 Appendix B - Method Update Rule	53

4.1.3.2	MDLs via DQ FA C Single Laboratory Procedure v 2.4	59

4.1.4	References	61

4.2	VOCs - Overview of EPA Compendium Method TO-15	62

4.2.1	General Description of Sampling and Analytical Methods	62

4.2.1.1	Sampling Pathway	65

4.2.1.2	Particulate Filtration	65

4.2.2	Precision - Sample Collection and Laboratory Processing	65

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4.2.2.1	Sample Collection and Analysis Precision	66

4.2.2.2	Laboratory Analytical Precision	67

4.2.3	Sample Collection Procedures	68

4.2.3.1	Sampling Equipment Specification	68

4.2.3.2	Sample Collection, Setup, and Retrieval	68

4.2.3.2.1	Sample Setup	68

4.2.3.2.2	Subambient Sample Collection	69

4.2.3.2.3	Superambient (Positive) Pressure Sampling	69

4.2.3.2.4	Sample Retrieval	70

4.2.3.3	Sampling Schedule and Duration	70

4.2.3.4	Sampling Train Configuration and Pre sample Purge	70

4.2.3.5	Sampling Unit Non-Biasing Certification	70

4.2.3.5.1	Zero Check	71

4.2.3.5.2	Known Standard Challenge	72

4.2.4	Canister Hygiene	72

4.2.4.1	Qualification of Canisters	73

4.2.4.1.1 Canister Bias	73

4.2.4.1.1.1	Canister Integrity and Zero Air Check	73

4.2.4.1.1.2	Known Standard Gas Check	74

4.2.4.2	Canister Cleaning	75

4.2.4.2.1	Heated Canister Cleaning	75

4.2.4.2.2	Cycles of Evacuation and Pressurization	76

4.2.4.2.3	Gas Source for Canister Cleaning Pressurization	76

4.2.4.2.4	Verification of Canister Cleanliness	77

4.2.4.3	Canister Maintenance and Preventive Maintenance	78

4.2.4.3.1	Collection of Whole Air Samples into Canisters	78

4.2.4.3.2	Overtightening of Valves	78

4.2.4.3.3	General Canister Handling	78

4.2.5	Method Detection Limits	79

4.2.6	Canister Receipt	79

4.2.7	Dilution of Canisters	80

4.2.8	GC/MS Tuning, Calibration, and Analysis	80

4.2.8.1	Interferences	80

4.2.8.2	Specifications for the Preconcentrator and GC/MS	81

4.2.8.3	Standards and Reagents	82

4.2.8.3.1	Calibration Standards	82

4.2.8.3.2	Secondary Source Calibration Standards	82

4.2.8.3.3	Internal Standards	82

4.2.8.3.4	Diluent Gases	83

4.2.8.3.5	MS Tuning Standard - BFB	83

4.2.8.3.6	Reagent Water for Humidification of Gases	83

4.2.8.4	Preparation of Calibration Standards and Quality Control
Samples	84

4.2.8.4.1	Calibration Standards	84

4.2.8.4.2	Second Source Calibration Verification Sample	85

4.2.8.4.3	Method Blank	85

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4.2.8.4.4 Laboratory Control Sample	85

4.2.8.5 Analysis via GC/MS	86

4.2.8.5.1	Tuning of the MS	86

4.2.8.5.2	Leak Check and Calibration of the GC/MS	86

4.2.8.5.2.1	Leak Check	86

4.2.8.5.2.2	Initial Calibration of the GC/MS	87

4.2.8.5.2.3	Secondary Source Calibration
Verification	88

4.2.8.5.2.4	Continuing Calibration Verification	89

4.2.8.5.2.5	Analysis of Laboratory QC Samples

and Field Samples	89

4.2.8.5.3	Compound Identification	89

4.2.8.5.4	Internal Standards Response	91

4.2.9	Data Review and Concentration Calculations	92

4.2.10	Summary of Quality Control Parameters	93

4.2.11	References	95

4.3 Carbonyl Compounds via EPA Compendium Method TO-1 la	96

4.3.1	General Description of Sampling Method and Analytical Method	96

4.3.2	Minimizing Bias	96

4.3.3	Carbonyls Precision	97

4.3.3.1	Sampling Precision	97

4.3.3.1.1	Collocated Sample Collection	97

4.3.3.1.2	Duplicate Sample Collection	98

4.3.3.2	Laboratory Precision	99

4.3.4	Managing Ozone	99

4.3.4.1	Copper Tubing Denuder/Scrubber	99

4.3.4.2	Sorbent Cartridge Scrubbers	100

4.3.4.3	Other Ozone Scrubbers	101

4.3.4.3.1	Cellulose Filter Ozone Scrubbers	101

4.3.4.3.2	Modified Dasibi™ Ozone Scrubber	101

4.3.5	Collection Media	101

4.3.5.1	Lot Evaluation and Acceptance Criteria	102

4.3.5.2	Cartridge Handling and Storage	102

4.3.5.3	Damaged Cartridges	103

4.3.5.4	Cartridge Shelf Life	103

4.3.6	Method Detection Limits	103

4.3.7	Carbonyls Sample Collection Equipment, Certification, and

Maintenance	104

4.3.7.1	Sampling Equipment	104

4.3.7.1.1	Sampling Unit Zero Check (Positive Bias Check)	104

4.3.7.1.2	Carbonyls Sampling Unit Flow Calibration	105

4.3.7.1.3	Moisture Management	107

4.3.7.2	Sampling Train Configuration andPresample Purge	108

4.3.7.3	Carbonyl Sampling Inlet Maintenance	108

4.3.8	Sample Collection Procedures and Field Quality Control Samples	108

4.3.8.1 Sample Collection Procedures	108

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4.3.8.1.1	Sample Setup	109

4.3.8.1.2	Sample Retrieval	109

4.3.8.1.3	Sampling Schedule and Duration	110

4.3.8.2 Field Quality Control Samples	110

4.3.8.2.1	Field Blanks	110

4.3.8.2.2	Trip Blanks	Ill

4.3.8.2.3	Collocated Samples	Ill

4.3.8.2.4	Duplicate Samples	112

4.3.8.2.5	Field Matrix Spikes	112

4.3.8.2.6	Breakthrough Samples	112

4.3.9	Carbonyls Extraction and Analysis	113

4.3.9.1	Analytical Interferences and Contamination	113

4.3.9.1.1	Analytical Interferences	113

4.3.9.1.2	Labware Cleaning	113

4.3.9.1.3	Minimizing Sources of Contamination	113

4.3.9.2	Reagents and Standard Materials	114

4.3.9.2.1	Solvents	114

4.3.9.2.2	Calibration Stock Materials	114

4.3.9.2.3	Secondary Source Calibration Verification Stock
Materials	114

4.3.9.2.4	Holding Time and Storage Requirements	114

4.3.9.3	Cartridge Holding Time and Storage Requirements	114

4.3.9.4	Cartridge Extraction	115

4.3.9.4.1	Laboratory Quality Control Samples	115

4.3.9.4.2	Cartridge Extraction Procedures	116

4.3.9.5	Analysis by HPLC	116

4.3.9.5.1	Instrumentation Specifications	116

4.3.9.5.2	Initial Calibration	117

4.3.9.5.3	Secondary Source Calibration Verification

Standard	118

4.3.9.5.4	Continuing Calibration Verification	118

4.3.9.5.5	Replicate Analysis	118

4.3.9.5.6	Compound Identification	118

4.3.9.5.7	Data Review and Concentration Calculations	119

4.3.10	Summary of Quality Control Parameters	121

4.3.11	References	123

4.4 PMio Metals Sample Collection and Analysis	124

4.4.1	Summary of Method	124

4.4.2	Advantages and Disadvantages of High Volume and Low Volume

Sample Collection	125

4.4.2.1	Low Volume Sampling	125

4.4.2.2	High Volume Sampling	125

4.4.3	Minimizing Contamination, Filter Handling, and Filter Inspection	126

4.4.3.1	Minimizing Contamination	126

4.4.3.2	Filter Handling	126

4.4.3.3	Filter Inspection	127

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4.4.4	Precision - Sample Collection and Laboratory Processing	127

4.4.4.1	Sample Collection Precision	127

4.4.4.2	Laboratory Precision	127

4.4.4.2.1	Low Volume Teflon® Filter Laboratory Precision	127

4.4.4.2.2	High Volume QFF Laboratory Precision	127

4.4.5	Field Blanks	128

4.4.6	Labware Preparation for Digestion and Analysis	128

4.4.7	Reagents for Metals Digestion and Analysis	129

4.4.8	Method Detection Limits	129

4.4.8.1	Teflon® Filter MDL	129

4.4.8.2	QFF MDL	129

4.4.9	Low Volume Sample Collection and Digestion	130

4.4.9.1	Air Sampling Instruments	130

4.4.9.2	Flow Calibration	130

4.4.9.3	Filter Media	131

4.4.9.3.1 Lot Background Determination	131

4.4.9.4	Filter Sampling, Retrieval, Storage, and Shipment	131

4.4.9.4.1 Sampling Schedule and Duration	131

4.4.9.5	Teflon® Filter Digestion	131

4.4.9.5.1	Laboratory Digestion QC Samples	131

4.4.9.5.2	Digestion Procedure	132

4.4.9.5.2.1	Hot Block Digestion	132

4.4.9.5.2.2	Microwave Digestion	133

4.4.9.5.2.3	AcidSonication	134

4.4.10High Volume Sample Collection and Digestion	135

4.4.10.1	Air Sampling Instruments	135

4.4.10.2	Flow Calibration	135

4.4.10.3	Filter Media	135

4.4.10.3.1 Lot Background Determination	135

4.4.10.4	Filter Sampling, Retrieval, Storage, and Shipment	136

4.4.10.4.1 Sampling Schedule and Duration	137

4.4.10.5	QFF Digestion	137

4.4.10.5.1	Laboratory Digestion QC Samples	137

4.4.10.5.2	Digestion Procedure	138

4.4.10.5.2.1 Hot Block Digestion	139

4.4.10.5.2.2High Volume QFF Microwave

Digestion	139

4.4.10.5.2.3High Volume QFF Acid Sonication	139

4.4.11 PMio Metals Analysis by ICP/MS - EPA 10-3.5	139

4.4.11.1	ICP/MS Instrumentation	139

4.4.11.2	ICP/MS Interferences	139

4.4.11.3	Preparation of Calibration Standards for ICP/MS Analysis	140

4.4.11.3.1	Primary Calibration Standards	140

4.4.11.3.2	Secondary Source Calibration Verification

Standard	140

4.4.11.4	Internal Standards	141

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4.4.11.5	Tuning Solutions	141

4.4.11.6	ICP/MS Warm Up, MS Tuning, and Setup	141

4.4.11.7	ICP/MS Calibration and Analytical Sequence Batch	142

4.4.11.7.1	Initial Calibration	142

4.4.11.7.2	Initial Calibration Verification	143

4.4.11.7.3	Initial Calibration Blank	143

4.4.11.7.4	Interference Check Standard	143

4.4.11.7.5	Continuing Calibration Verification	143

4.4.11.7.6	Continuing Calibration Blank	144

4.4.11.7.7	Laboratory Digestion Batch Quality Control

Samples	144

4.4.11.7.8	Serial Dilution	144

4.4.11.7.9	Replicate Analysis	144

4.4.11.8	ICP/MS Data Review and Concentration Calculations	144

4.4.11.8.1	Concentration Calculations for Low Volume

Sampling	145

4.4.11.8.2	Reporting of Concentrations for High Volume
Sampling	145

4.4.12	Summary of Method Quality Control Requirements	146

4.4.13	References	149

4.5 Collection and Analysis of PAHs via EPA Compendium Method T0-13A	150

4.5.1	Summary of Method	150

4.5.2	Sample Collection Equipment	150

4.5.2.1	Sampler Flow Calibration and Verification	151

4.5.2.2	Sampling Unit Maintenance	151

4.5.3	Sampling Media and Their Preparation	152

4.5.3.1	Glassware Cleaning	153

4.5.3.2	Cartridge Preparation	153

4.5.3.3	Field Surrogate Addition	153

4.5.4	PAH Sampling	154

4.5.4.1a Sampling Schedule and Duration	154

4.5.4.1b Retrieval, Storage, and Transport of QFFs and Cartridges	154

4.5.4.2	Field Blanks	155

4.5.4.3	Collocated Sampling	155

4.5.5	PAH Extraction and Analysis	156

4.5.5.1	Reagents and Standard Materials	156

4.5.5.1.1	Solvents	156

4.5.5.1.2	Calibration Stock Materials	156

4.5.5.1.2.1 Secondary Source Calibration

Verification Stock Material	156

4.5.5.1.3	Internal Standards	156

4.5.5.1.4	Surrogate Compounds	156

4.5.5.1.4.1	Field Surrogate Compounds	157

4.5.5.1.4.2	Extraction Surrogate Compounds	157

4.5.5.2	Hold Times and Storage Requirements	157

4.5.5.3	Extraction, Concentration, and Cleanup	157

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4.5.5.3.1	Soxhlet Extraction	157

4.5.5.3.2	Accelerated Solvent Extraction	157

4.5.5.3.3	Extract Concentration and Cleanup	158

4.5.5.3.3.1	Extract Concentration	158

4.5.5.3.3.1.1	Concentration via Kuderna-Danish	158

4.5.5.3.3.1.2	Concentration via Nitrogen Blowdown	159

4.5.5.3.3.2	Extract Cleanup	159

4.5.5.4	PAH Method Detection Limits	159

4.5.5.5	PAH Analysis via GC/MS	160

4.5.5.5.1	GC/MS Instrumentation	160

4.5.5.5.2	Tuning of the MS	160

4.5.5.5.3	Calibration of the GC/MS	160

4.5.5.5.4	Secondary Source Calibration Verification	162

4.5.5.5.5	Continuing Calibration Verification	162

4.5.5.5.6	Analysis of QC Samples and Field Samples	162

4.5.5.5.7	Compound Identification	162

4.5.5.5.8	Internal Standards Response	163

4.5.5.5.9	Surrogate Evaluation	163

4.5.5.5.10	Data Review and Concentration Calculations	163

4.5.6	Summary of Quality Control Parameters	164

4.5.7	References	166

5.0: METEOROLOGICAL MEASUREMENTS	 167

6.0: DATA HANDLING	168

6.1	Data Collection	168

6.2	Data Backup	168

6.3	Recording of Data	169

6.3.1	Paper Records	169

6.3.2	Electronic Data Capture	169

6.3.3	Error Correction	169

6.3.3.1 Manual Integration of Chromatographic Peaks	169

6.4	Numerical Calculations	170

6.4.1	Rounding	170

6.4.2	Calculations Using Significant Digits	170

6.4.2.1	Addition and Subtraction	170

6.4.2.2	Multiplication and Division	171

6.4.2.3	Standard Deviation	171

6.4.2.4	Logarithms	171

6.5	In-house Control Limits	171

6.5.1	Warning Limits	172

6.5.2	Control Limits	172

6.6	Negative Values	172

6.6.1	Negative Concentrations	172

6.6.2	Negative Physical Measurements	172

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7.0: DATA VALIDATION TABLES	173

7.1	VOCs via EPA Compendium Method TO-15	174

7.2	Carbonyls via EPA Compendium Method TO-11A	181

7.3	Metals via EPA Compendium Method 10 3.1 and 10 3.5	187

7.4	PAHs via EPA Compendium Method TO-13A	196

LIST OF FIGURES

Figure 3.1-1. Example Corrective Action Report	26

Figure 4.1-1. Graphical Representation of the MDL and Relationship to a Series of Blank

Measurements in the Absence of Background Contamination	48

Figure 4.1-2. Graphical Representation of the MDL and Relationship to a Series of

Measurements at the MDL Value	49

Figure 4.2-1. Collocated and Duplicate VOC Canister Sample Collection	67

Figure 4.2-2. Qualitative Identification of GC/MS Target Analytes	90

Figure 4.2-3. Determination of Chromatographic Peak Signal-to-Noise Ratio	91

Figure 4.4-1. Portioning of QFF Strips for Digestion	138

LIST OF TABLES

Table 1.2-1. Analytes of Principle Interest for the NATTS Program	3

Table 2.1-1. Assessments of Precision through Field and Laboratory Activities	13

Table 2.4-1. Sampling Unit Inlet Vertical Spacing Requirements	18

Table 2.4-2. Sampling Unit Inlet Required Minimum Distances from Roadways	19

Table 3.3-1. Calibration and Calibration Check Frequency Requirements for Standards

and Critical Instruments	28

Table 3.3-2. AQS Qualifier Codes Appropriate for NATTS Data Qualification	42

Table 3.3-3. Required AQS Quality Assurance Qualifier Flags for Various

Concentrations Compared to an Agency's MDL and SQL	43

Table 4.1-1. Concentrations of the NATTS Core Analytes Corresponding to a 10"6

Cancer Risk, a Noncancer Risk at a HQ of 0.1, and to the MDL MQO	52

Table 4.1-2. One-sided Student's T Values at 99% Confidence Interval	55

Table 4.1-3. K-values for n Replicates	60

Table 4.2-1. VOC Target Compounds and Associated Chemical Abstract Service (CAS)

Number via Method TO-15	64

Table 4.2-2. Required BFB Key Ions and Ion Abundance Criteria	86

Table 4.2-3. Summary of Quality Control Parameters for NATTS VOCs Analysis	93

Table 4.3-1. Carbonyl Target Compounds and Associated Chemical Abstract Service

(CAS) Number via Method TO-11A	96

Table 4.3-2. Maximum Background per Lot of DNPH Cartridge	102

Table 4.3-3. Carbonyls Field Blank Acceptance Criteria	Ill

Table 4.3-4. Summary of Quality Control Parameters for NATTS Carbonyls Analysis	121

Table 4.4-1. NATTS Program Metals Elements and Associated CAS Numbers	125

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Table 4.4-2. Example ICP/MS Analysis Sequence	142

Table 4.4-3. Method Criteria Parameters for NATTS Metals Analysis	147

Table 4.5-1. PAHs and Associated Chemical Abstract Numbers (CAS)	151

Table 4.5-2. DFTPP Key Ions and Abundance Criteria	160

Table 4.5-3. Summary of Quality Control Parameters for NATTS PAH Analysis	164

APPENDICES

Appendix A Draft Report on Development of Data Quality Objectives (DQOs) For The

National Ambient Air Toxics Trends Monitoring Network	202

Appendix B NATTS AQS Reporting Guidance for Quality Assurance Samples	235

Appendix C EPA Rounding Guidance Provided By EPA Region IV	243

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ACRONYMS AND ABBREVIATIONS

ACN

acetonitrile

ADQ

audit of data quality

AIRS

Aerometric Information Retrieval System

amu

atomic mass unit

ANP

annual network plan

ANSI

American National Standards Institute

AQS

Air Quality System

ASE

accelerated solvent extraction

ASQ

American Society for Quality

BFB

bromofluorobenzene

CAA

Clean Air Act

CAL

calibration

CAR

corrective action report

CARB

California Air Resources Board

CAS

Chemical Abstracts Service

CCB

continuing calibration blank

CCV

continuing calibration verification

CDCF

canister dilution correction factor

CDS

chromatography data system

CFR

Code of Federal Regulations

COA

certificate of analysis

COC

chain of custody

Cr6+

hexavalent chromium

CV

coefficient of variation

DART

Data Analysis and Reporting Tool

DB

dilution blank

DFTPP

decafluorotriphenylphosphine

DL

detection limit

DNPH

2,4-dinitrophenylhydrazine

DOC

demonstration of capability

DQI

data quality indicator

DQ FAC

Federal Advisory Committee on Detection and Quantitation Approaches and Uses in



Clean Water Act Programs

DQO

data quality obj ective

ECTD

extended cold trap dehydration

EPA

United States Environmental Protection Agency

ESMB

extraction solvent method blank

eV

electron volt

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FAA
FAEM
FID
FRM

g

GC

GC/MS

GFAA

GPRA

HAP
HCF
Hg

HPLC
HQ

IB
IC

ICAL
ICB

ICP/AES

ICP/MS

ICS

ICV

ID

IDCF

in.

IS

K-D
KI

L

LCS

LCSD

LFB

LIMS

LPM

M
m

3

m
m/z
MB
MDL

flame atomic absorption

flexible approaches to environmental measurement
flame ionization detector
federal reference method

gram(s)

gas chromatograph

gas chromatograph/mass spectrometry
graphite furnace atomic absorption spectrometry
Government Performance Results Act

hazardous air pollutant

hydrocarbon-free

mercury

high performance liquid chromatograph
hazard quotient

instrument blank
ion chromatograph
initial calibration
initial calibration blank

inductively coupled plasma/atomic emission spectroscopy
inductively coupled plasma/mass spectrometer
interference check standard
initial calibration verification
identifier

instrument dilution correction factor
inch(es)

internal standard

Kuderna-Danish
potassium iodide

liter(s)

laboratory control sample
laboratory control sample duplicate
laboratory fortified blank
laboratory information management system
liter(s) per minute

molar
meter(s)
cubic meter(s)
mass to charge
method blank
method detection limit

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MFC	mass flow controller

mg	milligram(s)

min	minute(s)

mL	milliliter(s)

mm	millimeter(s)

mM	millimolar

MPT	microscale purge and trap

MQO	measurement quality objective

MS	mass spectrometer or matrix spike

MUR	method update rule

|ig	microgram(s)

|iL	microliter(s)

|im	micrometer(s)

n	number

NAAQS	national ambient air quality standards

NATTS	National Air Toxics Trends Station

ng	nanograms(s)

nm	nanometer(s)

02	oxygen molecule

03	ozone molecule

OAQPS	Office of Air Quality Planning and Standards (EPA)

OH"	hydroxide ion

PAH	polycyclic aromatic hydrocarbon

PM	particulate matter

PM2.5	particulate matter with aerodynamic diameter < 2.5 microns

PM10	particulate matter with aerodynamic diameter <10 microns

POC	parameter occurrence code

ppb	part(s) per billion

ppbv	part(s) per billion by volume

ppm	part(s) per million

ppmv	part(s) per million by volume

psi	pound(s) per square inch

psia	pound(s) per square inch absolute

psig	pound(s) per square inch gauge

PT	proficiency test

PTFE	polytetrafluoroethylene

PUF	polyurethane foam

QA	quality assurance

QAPP	quality assurance project plan

QC	quality control

QFF	quartz fiber filter

QL	quantitation limit

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QMP

quality management plan

QSA

quality systems audit

RB

reagent blank

RBS

reagent blank spike

RH

relative humidity

RPD

relative percent difference

RRF

relative response factor

RRT

relative retention time

RSD

relative standard deviation

RT

retention time

SB

solvent blank

SIM

selective ion monitoring

SLT

state, local, or tribal agency

SMB

solvent method blank

SOP

standard operating procedure

SQL

sample quantitation limit

sscv

second source calibration verification

STP

temperature and pressure

SVOC

semi-volatile organic compound

TAD

technical assistance document

TOF

time of flight

TSA

technical systems audit

HP

through the probe

UATS

urban air toxics strategy

UV

ultraviolet

VOC

volatile organic compound

v/v

volume per volume

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1.0: INTRODUCTION

1.1	Background

Hazardous air pollutants (HAPs), or air toxics, are regulated under the Clean Air Act (CAA) as
amended in 1990 and include a list of 189 toxic pollutants associated with adverse health effects.
Such HAPs are emitted by numerous stationary and mobile sources. The U.S. Environmental
Protection Agency (EPA) Government Performance Results Act (GPRA) commitments specify a
goal of reducing air toxics emissions by 75% from 1993 levels to significantly reduce the
potential for human health risk.

The National Air Toxics Trends Station (NATTS) Program was developed to fulfill the need for
long-term ambient air toxics monitoring data required to assess attainment of GPRA
commitments. The NATTS network was designed to generate data of a known, consistent, and
standardized quality sufficient to enable the identification of spatial, and, more importantly,
long-term temporal trends in the concentrations of air toxics. This technical assistance document
(TAD) presents best practices and sets forth requirements for the collection and reporting of
NATTS network air toxics data and is intended as an aid to the agencies responsible for
implementing the NATTS Program. EPA recognizes that the partnership between the EPA and
state and local air monitoring agencies is intrinsic to attaining the goal of the NATTS Program to
generate high quality data needed to accomplish the end goal of trends detection. This TAD
includes information on the implementation and maintenance of the necessary quality system, on
the collection and analysis of air samples, and on the reporting of results to EPA's Air Quality
System (AQS) database.

1.2	Target Analytes: Analytes of Critical Concern/Risk Drivers

While it is impractical to measure all HAPs at all monitoring sites, HAPs have been assigned by
analyte class to a tiered system according to their relative toxicity. The 1990 CAA amendments
required EPA to develop a subset of the 189 toxic pollutants identified in Section 112 that have
the greatest impact on the public and the environment in urban areas. The resulting subset of air
toxics consisted of 33 HAPs which are identified in the Integrated Urban Air Toxics Strategy
(UATS)1, commonly referred to as the Urban HAP List. This subset of 33 HAPs covers a
variety of inhalation exposure periods (acute/chronic), exposure pathways (inhalation, dermal,
ingestion), and associated adverse health effects (cancer/non-cancer). However, the NATTS
Program is primarily concerned with traditional inhalation pathway exposures of more
ubiquitous HAPs, and is focused on measuring HAPs which have available and cost-effective
measurement methods. As such, 18 of the 33 UATS HAPs were selected as core HAPs for the
NATTS Program. HAPs omitted from the UATS list include those for which analysis methods
are less cost-efficient or less reliable and those HAPs deemed to have a lesser impact on
inhalation exposure but a greater impact on the welfare of watersheds and water bodies through
airborne deposition. Also omitted from the NATTS program were those HAPs which are
categorized as persistent bio-accumulative compounds (PBTs) such as pesticides, mercury,
polychlorinated biphenyls (PCBs), and dioxins.2

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Hexavalent chromium was removed from the list of NATTS core HAPs due to it being a local
source-driven pollutant (and not ubiquitous) and due to the preponderance of non-detect results
on a national scale which provided little useful data. Sites are not required to, but may elect to,
collect and report hexavalent chromium data. With the removal of hexavalent chromium, the 17
remaining UATS HAPs included polycyclic organic matter (POM), which was added later (in
2007) as speciated polycyclic aromatic hydrocarbons (PAHs). The replacement of POM with
naphthalene and benzo(a)pyrene brought the list of required NATTS core HAPs to 18.

Sixty of the 189 HAPs have been selected as "Analytes of Principle Interest" for the NATTS
Program; these 60 belong to one of four different analyte classes according to the method by
which they are typically measured, i.e. volatile organic compounds (VOCs), carbonyls, metals,
and (PAHs). These 60 "Analytes of Principle Interest" include 17 (18 when replacing POM with
naphthalene and benzo(a)pyrene) of the UATS HAPs (mentioned previously) and are listed in
Table 1.2-1 along with their analyte classes and concentrations corresponding to a 10"6 cancer
risk and a noncancer risk at a hazard quotient (HQ) of 0.1. Of these 60 HAPs, 18 have been
identified as major risk drivers based on a relative ranking performed by EPA and have been
designated NATTS Core, or Tier I, analytes; these compounds must be measured at all NATTS
sites. The remaining 42 Tier II HAPs are highly desired and should be measured and reported.
EPA recognizes that additional resources are required to provide quality-assured data for the
additional Tier II analytes; however, given that these methods are already conducted to measure
the Tier I Core analytes, data for many of Tier II analytes can be reported with modest additional
resource input.

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Table 1.2-1. Analytes of Principle Interest for the NATTS Program

HAP

Analyte Class and

Collection and
Analysis Method

Tier

106 Cancer Risk
Concentration

(jig/m3)

Noncancer Risk
[Hazard Quotient = 0.1]
Concentration (jig/m3)

acrolein



I (UATS)

-

0.002

tetrachloroethylene



I (UATS)

3.8 a

4 a

benzene



I (UATS)

0.13

3

carbon tetrachloride



I (UATS)

0.17

19

chloroform



I (UATS)

-

9.8

trichloroethylene



I (UATS)

0.21a

0.2 a

1,3-butadiene



I (UATS)

0.03

0.2

vinyl chloride



I (UATS)

0.11

10

acetonitrile



II

-

6

acrylonitrile



II (UATS)

0.015

2

bromoform



II

0.91

-

carbon disulfide



II

-

70

chlorobenzene



II

100

-

chloroprene



II

-

0.7

p-dichlorobenzene



II

0.091

80

cis-1,3 -dichloropropene

VOCby

II (UATS)

0.3

2

trans-1,3 -dichloropropene

TO-15

II (UATS)

0.3

2

ethyl acrylate



II

0.071

-

ethyl benzene



II

-

100

hexachloro -1,3 -butadiene



II

0.0022

9

methyl ethyl ketone



II

-

500

methyl isobutyl ketone



II

-

300

methyl methacrylate



II

-

70

methyl tert-butyl ether



II

3.8

300

methylene chloride



II (UATS)

2.1

100

styrene



II

-

100

1,1,2,2 -tetrachloroethane



II (UATS)

0.017

-

toluene



II

-

40

1,1,2 -trichloroethane



II

0.063

40

1,2,4-trichlorobenzene



II

-

20

m&p-xylenes



II

-

10

o-xylene



II

-

10

formaldehyde

carbonyl by

I (UATS)

0.08 a

0.08 a

acetaldehyde

TO-11A

I (UATS)

0.45

0.9

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Table 1.2-1. Analytes of Principle Interest for the NATTS Program (Continued)

HAP

Analyte Class
and Collection
and Analysis
Method

Tier

106 Cancer Risk
Concentration

(jig/m3)

Noncancer Risk
[Hazard Quotient
II. 11 Concentration
frig/m3)

nickel



I (UATS)

0.0021

0.009

arsenic



I (UATS)

0.00023

0.003

cadmium



I (UATS)

0.00056

0.002

manganese



I (UATS)

-

0.005

beryllium

metal by IO-3.1

I (UATS)

0.00042

0.002

lead

and 10-3.5

I (UATS)

-

0.015

antimony



II

-

0.02

chromium



II (UATS)

0.00008

0.01

cobalt



II

-

0.01

selenium



II

-

2

naphthalene



I (UATS b)

0.029

0.029

benzo(a)pyrene



I (UATS b)

0.00091

0.3

acenaphthene



II (UATS b)

-

0.3

acenaphthylene



II (UATS b)

-

0.3

anthracene



II (UATS b)

-

0.3

benz(a)anthracene



II (UATS b)

0.0091

0.3

benzo (b)fluoranthene



II (UATS b)

0.0091

0.3

benzo(e)pyrene

PAH by T0-13A

II (UATS b)

-

0.3

benzo (k)fluoranthene

II (UATS b)

0.0091

0.3

chrysene



II (UATS b)

0.091

0.3

dibenz(a,h)anthracene



II (UATS b)

0.0091

0.3

fluoranthene



II (UATS b)

-

0.3

fluorene



II (UATS b)

-

0.3

indeno( 1,2,3 -cd)pyrene



II (UATS b)

0.0091

0.3

phenanthrene



II (UATS b)

-

0.3

pyrene



II (UATS b)

-

0.3

a These values are per the NATTS Workplan Template, March 2015 3
b PAHs compounds included in the UATS list as polycyclic organic matter (POM)

1.3	Importance of Adherence to Guidelines

The overall data quality objective (DQO) of the NATTS Program is to detect trends in HAP
concentrations covering rolling three-year periods with uniform certainty across the 27-site
network with a coefficient of variation (CV) not to exceed 15 percent.4 Stated another way, the
DQO is to be able to detect a 15% difference (trend) in non-overlapping three-year periods
within acceptable levels of decision error. This is accomplished by generating representative
concentration data for the various HAPs with appropriate sensitivity within acceptable limits of
imprecision and bias. For overall trends to be discernable, concentration data must be generated
with methods which meet minimum performance criteria. The DQO, data quality indicators

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(DQIs), and their associated measurement quality objectives (MQOs), or acceptance criteria, are
presented in detail in Sections 2.1 and 3.2. EPA recognizes there is a disconnect in the NATTS
bias MQO, which may not exceed 25%, and bias criteria in individual methods, notably TO-13A
and TO-15, which exceed 25%. These methods are currently undergoing refinement by EPA's
Office of Research and Development (ORD). For information regarding the determination of the
DQO, DQIs, and MQOs, please refer to the following background reports and 2013 DQO
reassessment report:

•	Air Toxics Monitoring Concept Paper, Revised Draft February 29, 2000:
https://www3.epa.gov/ttnamtil/files/ambient/airtox/cncp-sab.pdf

•	Draft Report on Development of Data Quality Objectives (DQOs) for the National
Ambient Air Toxics Trends Monitoring Network, September 27, 2002
(Appendix A of this TAD)

•	Analysis, Development, and Update of the National Air Toxics Trends Stations
(NATTS) Network Program-Level Data Quality Objective (DQO) and Associated
Method Quality Objectives (MQOs), Final Report, June 13, 2013
https://www3.epa.gov/ttnamtil/files/ambient/airtox/nattsdqo20130613.pdf

Together, these documents provide a roadmap for determining and verifying the NATTS DQO
and supporting MQOs.

A review of data during Phase I of the NATTS pilot project identified that variations in
sampling, analysis, data reporting, and quality assurance resulted in a large amount of data
inconsistency.2 This TAD was developed and revised to increase consistency across the network
and facilitate attainment of the NATTS DQO. Failure to attain the prescribed NATTS MQOs
limits the ability to detect trends. Trends must be assessed so that EPA, as outlined in the EPA's
Integrated Urban Air Strategy, may verify that the cumulative health risks associated with air
toxics are in fact decreasing.5

1.4	Overview of TAD Sections

This document is organized so as to present guidance and requirements in the likely order in
which they are needed when establishing a network site or network sites and laboratory, i.e.,
planning, implementation, and data verification. Background information, the NATTS DQO,
and the framework and requirements for quality systems are addressed first, followed by
collection and analysis of air samples, with data handling and validation tables completing the
document. Each section is briefly described below.

1.	Background - Brief overview of the history of the NATTS Program, NATTS
analytes, and critical changes from Revision 2

2.	Metrics Defining Data Quality for the NATTS Program - Importance of data
consistency, NATTS monitoring objectives, quality systems, and siting criteria

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3.	Quality Assurance and Quality Control - Quality Assurance Project Plan (QAPP)
development, QAPP elements including standard operating procedures (SOPs),
corrective action, equipment calibration, document control, training, chain of custody
(COC), traceability, labeling, control charting, software, records review, data
verification and validation, and air quality subsystem (AQS) reporting

4.	Collection and Analysis Methods - method detection limit (MDL) procedures, VOCs,
carbonyls, PMio metals, and PAHs

5.	Meteorology - Brief description of required meteorological measurements

6.	Data Handling - Procedures and policies for collection, manipulation, backup,
archival, and calculations

7.	Data Validation Tables - A series of tables detailing method specific critical criteria

1.5	Critical Changes and Updates from Revision 2 of the NATTS TAD

With this revision, the NATTS TAD has not only been reorganized and streamlined, but it has
been substantially updated compared to Revision 2. Specific changes include:

Specification of detailed requirements and recommendations for quality system
development and implementation

Specification of calibration requirements and recommendations for all instruments,
including support equipment

Recommendations for conducting and documenting of training

Revision to the MDL determination procedure to be inclusive of the contribution
from the collection media background

Clarification of precision for sample collection and analysis

Relaxation of certain VOCs sample collection requirements

Provision of updated guidance on collection and analysis of VOCs, carbonyls, PMio
metals, and PAHs

Exclusion of hexavalent chromium sampling and analysis methods
Clarification on data handling practices
Provision of data validation templates

Updating the guidance and requirements for the air sampling and analysis methods is the primary
goal of this TAD revision. The secondary goal is to provide a more user-friendly guidance
document with discrete sections organized in a manner so as to allow users to quickly locate the
desired information. Of note, data validation template tables have been provided as an appendix
in Section 7.

With the removal of hexavalent chromium as a NATTS core HAP in June 2013, guidance for
sample collection and analysis for this analyte are not provided within this TAD revision.

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1.6

Good Scientific Laboratory Practices

Good scientific practices, including instalment calibration and proper recording of observations,
measurements, and instrument conditions, are equally important in both the field and in the
laboratory. Such practices are necessary to generate data which are consistent, comparable,
standardized, traceable, and defensible. Appropriate aspects of good laboratory and field
practices are to be detailed in each agency's NATTS quality system. The need for, and examples
of such practices are given below and in Section 2.

1.6.1 Data Consistency and Traceability. To be able to verify that the NATTS network
generates data of quality sufficient to evaluate the main NATTS Program DQO, data collection
and generation activities must be traceable to calibrated instruments, certified standards, and to
activities conducted by individuals with the appropriate and documented training. Traceability
in this case refers to ensuring the existence of a documentation trail which allows reconstruction
of the activities performed to collect and analyze the sample and to the certified standards and
calibrated instrumentation employed to determine analyte concentrations. To specifically ensure
attainment of overall network bias requirements, each reported concentration must be traceable
to a measurement of known accuracy, be it from an analytical balance, volumetric flask, gas
chromatography/mass spectrometer (GC/MS), mass flow controller, critical orifice calibration
plate, etc. Maintaining this traceability from sample collection to final results reporting assures
that NATTS data are credible and defensible, and that the root cause of nonconformances may be
found and corrected which thereby enables continuous improvement in NATTS program
activities. Instrument calibration specifications and frequencies are provided in Section 3.

1.7	NATTS as the Model for Air Toxics Monitoring

Air toxics monitoring is an important, but often secondary, consideration for many air quality
agencies. One reason for such is that there are no national ambient air quality standards
(NAAQS) for air toxics for which regulatory compliance efforts would be required. Guidance
for conducting air toxics sample collection and analysis is not as widely available as for criteria
pollutants and is limited to performance-based compendium methods as compared to Federal
Reference Methods (FRMs). This TAD is intended to primarily provide guidance and delineate
requirements for NATTS sites and their associated laboratories; however, aspects of sampling,
analysis, and quality assurance could be applied by agencies conducting air toxics monitoring
outside of the NATTS network. This TAD incorporates feedback provided by the air toxics
community with vast and varied experience conducting air toxics measurements. Feedback and
input provided by the air toxics community were carefully reviewed and considered by a small
workgroup of EPA and state/local/tribal (SLT) stakeholders in reviewing and revising this TAD.
The NATTS network is a collaboration of SLT monitoring organizations with EPA. With an
extensive network of experienced site operators and laboratory staff, the NATTS network strives
to be the exemplar of air toxics monitoring.

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1.8	References

1.	Smith, R.L.; French, C.L.; Murphy, D.L.; Thompson, R. Selection ofHAPs under Section
112(h) of the Clean Air Act: Technical Support Document, Integrated Urban Air Toxics
Strategy (UATS), July 28, 1999.

2.	National Monitoring Strategy Air Toxics Component, Final Draft. United States
Environmental Protection Agency, July 2004. Available at (accessed October 18, 2016):
https://www3.epa.gov/ttnamtil/files/ambient/monitorstrat/atstrat804.pdf

3.	National Air Toxics Trends Station Work Plan Template. United States Environmental
Protection Agency, Revised: March 2015. Available at (accessed October 18, 2016):
https://www3.epa.gov/ttn/amtic/files/ambient/airtox/nattsworkplantemplate.pdf

4.	Quality Management Plan for the National Air Toxics Trends Stations. Quality Assurance
Guidance Document, EPA 454/R-02-006. September 2005. Available at (accessed October
18,2016): https://www3.epa.gov/ttnamtil/files/ambient/airtox/nattsqmp.pdf

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2.0: IMPORTANCE OF DATA CONSISTENCY

As the main goal of the NATTS Program is to detect long-term trends in ambient air toxics
concentrations across the continental United States, sample data collected at each site must be
comparable over time and from one site to the next. The ability to detect and evaluate trends on
a nationwide basis requires the standardized operation of the NATTS Program based upon four
key components:

-	Known and specific MQOs for the program;

Specified measurement (collection and analysis) methods performed in a standardized
and consistent manner across the network;

-	Known and specific acceptance criteria for various aspects of the specified
monitoring methods; and

Stability of monitoring sites including location and operation over the required period
of time.

In short, each site's concentration data must meet the MQOs and be generated with standardized
methods that are appropriately sensitive, show minimal bias, and are sufficiently precise.
Moreover, the collected samples taken together must be representative of the ambient conditions
at the site over the course of a year and the annual dataset must be adequately complete. If
program MQOs are not attained at each site, the network data will not be consistent across all
sites and the ability to detect concentration trends will be compromised. MQOs related to each
of the specific DQIs are discussed in more detail in Section 2.1.

This TAD is written such that requirements are described as "must" and recommendations are
described as "should." It is expected that monitoring agencies will make good faith efforts to
comply with the requirements and adopt recommendations, where feasible.

2.1	Data Quality Objectives and Relationship to the Quality Assurance Project Plan

The DQO process ensures that the type, quantity, and quality of data used in decision making are
appropriate to evaluate the overall DQO of the NATTS Program. Discussion of the
determination of the NATTS DQO is addressed in the NATTS Quality Management Plan
(QMP)1 and is not reproduced here. Background information on the development of the NATTS
DQO process is detailed in the initial DQO report2 and a follow up assessment was completed in
20133 to verify that the DQO and supporting MQOs remained applicable and suitable to attain
network goals.

Each monitoring organization must develop a QAPP that describes the framework of the
resources, responsible individuals, and actions to be taken to attain the NATTS DQO. QAPP
development is described further in Section 3.3.

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There is a single main DQO for the NATTS Program, which is:

To be able to detect a 15% difference (trend) between two successive 3-year annual mean

concentrations (rolling averages) within acceptable levels of decision error.

This main DQO is directly related to demonstrating a reduction in health-based risk related to air
toxics inhalation exposure. To achieve this main DQO, the NATTS Program network was
designed to meet the following primary monitoring objectives, which are to:

•	Measure concentrations of the NATTS Tier I core analytes and Tier II analytes of
interest in ambient air at each NATTS site. These analytes are listed in Table 1.2-1.

•	Generate data of sufficiently high and known quality that are nationally consistent.
Such requires the implementation and maintenance of a robust and functional quality
system, the proper execution of the applicable sampling and analysis methods, and
that the specified methods provide sufficient sensitivity to obtain a limit of detection
at or lower than that at which adverse health effects have been determined.

•	Collect sufficient data to represent the annual average ambient concentrations of air
toxics at each NATTS site. Collection of one sample every six days results in 60 or
61 samples per year exclusive of additional quality control (QC) samples such as
blanks, collocated samples, duplicates, etc.

In addition to these primary monitoring objectives, the NATTS network was designed to address
the following secondary monitoring objectives, which are to:

•	Complement existing programs. The NATTS network is integrated with existing
programs such as criteria pollutant monitoring, Photochemical Assessment
Monitoring Stations (PAMS), National Core (NCore), etc., and to take advantage of
efficiencies of scale to the extent that methodologies and operations are compatible.
Establishment of NATTS sites at existing sites leverages the existing resources of
experienced operators and infrastructure to achieve program objectives.

•	Reflect community-oriented population exposure. Stationary monitors are sited to be
representative of average concentrations within a 0.5- to 4-kilometer area (i.e.,
neighborhood scale). These neighborhood-scale measurements are more reflective of
typical population exposure, can be incorporated in the estimation of long-term
population risk, and are the primary component of the NATTS Program. Note that
some NATTS sites may no longer truly represent neighborhood scale due to source or
infrastructure changes. While new near-field sources may impact the measured
concentrations, stability of the site location is necessary to detect trends which may
still be discernable even when sites are impacted by such sources.

•	Represent geographic variability. A truly national network must represent a variety
of conditions and environments that will allow characterization of different emissions
sources and meteorological conditions. The NATTS Program supports population
risk characterization and the determination of the relationships between emissions and
air quality under different circumstances, and allows for tracking of changes in
emissions.4 National assessments must reflect the differences among cities and

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between urban and rural areas for selected HAPs, so the network:

o Includes cities with high population risk (both major metropolitan areas and other

cities with high or potentially high anticipated air toxics concentrations);
o Distinguishes differences within and between geographic regions (to describe
characteristics of areas affected by high concentrations (e.g. urban areas) versus
low concentrations (e.g. rural areas);
o Reflects the variability among pollutant patterns across communities; and
o Includes background monitoring (i.e., sites without localized sources).

The above monitoring objectives are supported by the DQIs as described in the following
subsections:

2.1.1	Representativeness. To adequately characterize the ambient air toxics
concentrations over the course of a year, sample collection must occur every six days per the
national sampling calendar for a 24-hour period beginning and ending at midnight local standard
time (without correction for daylight savings time, if applicable). This sample collection
duration and frequency provides a sufficient number of data points to ensure that the collected
data are representative of the annual average daily concentration at a given site. Collection
methods are designed to efficiently capture airborne HAPs over this time period in order to
measure concentrations representative of the ambient air during sample collection.

2.1.2	Completeness. Comparison of concentration data across sites and over time requires
that a minimum number of samples be collected over the course of each calendar year. The
MQO for completeness prescribes that > 85% of the annual air samples must be valid, equivalent
to 52 of the annual 61 expected samples (51 during years when there are only 60 collection
events).

A valid sample is one that was collected, analyzed, and reported to AQS without null flags. If a
collected sample is voided or invalidated for any reason, a make-up sample collection should be
attempted as soon as practical according to the make-up sampling policy below.

2.1.2.1 Make-up Sample Policy. Samples and sample results may be invalidated for a
number of reasons. In all cases, the concentration data are entered in AQS flagged with a null
code indicating the data are invalid. In order to increase the likelihood of attaining the
completeness MQO of > 85%, make-up samples should be collected when a sample or sample
result is invalidated.

A replacement sample should be collected as close to the original sampling date as possible, and
preferably before the next scheduled sampling date. When scheduling make-up sample
collection, consideration should be given to minimize bias introduced to the annual concentration
average due to differences in concentration from the originally scheduled sample date. Such
considerations include concentration differences due to sample collection on a particular day of
the week (weekday versus weekend) and potential seasonal effects. If it is not feasible to collect
the make-up sample prior to the next scheduled sampling date, the sample should be collected
within 30 days of the original sampling date. In all cases, the make-up sample should be

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collected within the calendar year averaging period that starts January 1 and ends December 31.
Note: For sampling units employing six-day timers, failure to reset the timer following a make-
up sample can result in mistakenly collecting samples on dates that do not follow the national
sampling calendar.

To summarize, make-up samples should be collected as close to the original sampling date as
possible, and should be collected according to the following, in order of most preferable to least
preferable:

1.	Before the next scheduled sampling date

2.	Within 30 days of the missed collection date

3.	Within the calendar year.

In order to be temporally representative of the annual concentration at a given site, the sample
dates must be as evenly distributed as possible to capture concentrations that fluctuate seasonally
or according to weather patterns. It is not acceptable to delay make-up sampling until the end of
the calendar year, as this may bias the data to be more seasonally than annually representative.

2.1.3 Precision. Reproducibility is a key component of ensuring concentration results at
one site are comparable to those at other sites and are comparable over time. For the NATTS
Program, precision of field and laboratory activities (inclusive of extraction and analysis) may be
assessed by collection of collocated and/or duplicate field samples; the precision of laboratory
handling and analysis may be estimated by the subdivision of a collected sample into preparation
duplicates which are separately taken through all laboratory procedures (digestion or extraction
and analysis) and includes instances in which target analytes may be added to a subsample to
prepare matrix spike duplicates; and analytical precision is assessed by the replicate analysis of a
sample or sample extract/digestate. Note that the previous revision of this TAD required that
collocated and duplicate samples be analyzed in replicate. This has been relaxed to permit
replicate analysis on any sample chosen by the laboratory. A summary of possible precision
assessments is shown in Table 2.1-1. Precision sample collection and replicate analysis
requirements will be detailed in each site's annual NATTS workplan.

The network MQO is based on an evaluation of at least an entire year's data. In all cases a
coefficient of variance (CV) of < 15% must be met. For more information on how the CV is
calculated, see the 2011-2012 NATTS Quality Assurance Annual Report.5 Note that this
precision MQO is different than the precision acceptance criteria for the individual collection
and analysis methods; imprecision of the latter may be permitted to be larger than 15%. Such
method-specific precision requirements apply to comparing two measurements and do not apply
to larger (N > 2) sample sets.

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Table 2.1-1. Possible Assessments of Precision through Field and Laboratory Activities

HAP Class

Collocation

A

Duplicate

Field
Samples *

Preparation
(Digestion/
Extraction)
Duplicate

Matrix
Spike
Duplicate

Analysis
Replicate

VOCs

yes

yes

no

no

yes

Carbonyls

yes

yes

no

no

yes

PMio metals -











high volume
collection

yes

no

yes

yes

yes

PMio metals -











low volume

yes

no

no

no

yes

collection











PAHs

yes

no

no

no

yes

*Note: Collection of collocated and duplicate field samples is highly desired, but not required, and
will be detailed in the site's annual workplan.

2.1.4 Bias. Bias is the difference of a measurement from a true or accepted value and can
be negative or positive. As much as possible, bias should be minimized as biased data may
result in incorrect conclusions and therefore incorrect decisions. Bias may originate in several
places within the sample collection and analysis steps. Sources of sample collection bias
include, but are not limited to, incorrectly calibrated flows or out-of-calibration sampling
instruments, elevated and unaccounted for background on collection media, poorly maintained
(dirty) sampling inlets and flow paths, and poor sample handling techniques resulting in
contamination or loss of analyte. Sources of sample analysis bias include, but are not limited to,
poor hygiene or technique in sample preparation, incorrectly calibrated or out of tolerance
equipment used for standard materials preparation and analysis, and infrequent or inappropriate
instrument maintenance leading to enhanced or degraded analyte responses.

2.1.4.1 Assessing Laboratory Bias - Proficiency Testing. Each laboratory analyzing
samples generated at NATTS sites must participate in the NATTS proficiency testing (PT)
program. PT samples for each of the four sample classes, VOCs, carbonyls, PMio metals, and
PAHs, are generated at a frequency determined by EPA Office of Air Quality Planning and
Standards (OAQPS), typically twice annually for each class. Participating laboratories are blind
to the spiked concentrations and analyze the PT samples via methods and procedures identical to
those employed for field-collected air samples.

PT target analytes, which include all Tier I analytes, among others, are identified in the following
tables in Section 4:

VOCs
Carbonyls
PMio Metals
PAHs

Table 4.2-1
Table 4.3-1
Table 4.4-1
Table 4.5-1

Each laboratory's PT results, on an analyte-by-analyte basis, must be within ± 25% of the
assigned target value, defined as the NATTS laboratory average, excluding outliers. In the event

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there is a problem with the NATTS laboratory average such as a contamination issue, the
assigned target value may be changed to the nominal concentration or referee laboratory average,
as applicable, and will be detailed in the PT results. Laboratories which fail to meet the bias
acceptance criterion on an analyte-by-analyte basis must identify the root cause of the bias for
the failed analyte, take corrective action, as appropriate, to eliminate the cause of the bias, and
must evaluate the potential for bias in reported field sample data going back to last acceptable PT
result. In the event of two consecutive failed PTs for a given analyte, laboratories must qualify
field collected sample results as estimated when reported to AQS. EPA recognizes that the
NATTS MQO bias criterion of ± 25% established through the DQO process is narrower than the
bias criteria for some of the analytical methods, namely TO-15 and TO-13 A. In order for the
main NATTS DQO to be achieved, the bias MQO criterion must be achieved.

2.1.4.2 Assessing Field Bias. The direction of the flow rate bias in carbonyls, PMio metals,
and PAHs samplers is opposite that to the bias introduced in the reported concentrations. That is,
flow rates which are biased low result in overestimation of air concentrations whereas flow rates
which are biased high result in underestimation of air concentrations. As VOCs collection
methods involve collection of whole air into the canister, the flow rate accuracy is of less
importance and does not directly correlate to errors in measured concentrations. Rather, it is
important that the flow rate into the canister be constant over the entire 24-hour collection period
so as to best characterize the average burden of VOCs over the entire sampling duration.

Indicated flow rates for carbonyls and PAHs must be within ± 10% of both the flow transfer
standard and the design flow rate (where applicable). The indicated flow rate for the low volume
PMio metals method must be within ± 4% of the flow transfer standard and within ± 5% of the
design flow rate. The indicated flow rate for the high volume PMio metals method must be
within ± 7% of the transfer standard and within ± 10% of the design flow rate. Failure to meet
these criteria must result in corrective action including, but not limited to, recalibration of the
sampling unit flow or resetting of flow linear regression response, where possible. Sampling
units which cannot meet these flow accuracy specifications must not be utilized for sample
collection. Additionally, following a failing calibration or calibration check, agencies must
evaluate sample data collected since the last acceptable calibration or calibration check, and such
data may be subject to invalidation. Corrective action is recommended for flow calibration
checks which indicate flows approaching, but not exceeding the appropriate flow acceptance
criterion. Calibration flow checks must be performed at minimum quarterly; however, to
minimize risk of invalidation of data, monthly flow calibration checks are recommended.

Sampling bias for VOCs and carbonyls is also characterized by evaluating sample media
collected by providing analyte-free zero air or nitrogen to the sampling unit (zero checking) and
by providing a known concentration analyte stream to VOCs sampling units (known standard
check). These zero checks and known standard checks are discussed further in Sections 4.2.5.5
and 4.3.7.1.1, for VOCs and carbonyls, respectively.

2.1.5 Sensitivity. Following promulgation of the CAA and its amendments, ambient air
toxics concentrations have been decreasing. As concentrations decrease, they become
increasingly difficult to measure and, as a result, measurement methods must become
increasingly sensitive. Concurrent with decreases in ambient air toxics concentrations, health

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risk assessments for exposures to air toxics are driving health risk-based concentrations lower,
which also precipitates a need to increase method sensitivity. In order to ensure that methods are
sufficiently sensitive, MDL MQOs have been established which prescribe the maximum
allowable MDL for each required NATTS core/Tier I analyte. As concentrations for HAPs
decrease in the ambient atmosphere and are measured closer to the MDL or below the MDL, this
results in a decrease in the accuracy (decrease in precision and increase in bias) of the percent
change estimate in evaluating a trend.

The MDL and sample quantitation limit ([SQL], defined as 3.18 times the MDL concentration)
provide information on the concentration at which both positive identification and accurate
quantification is expected, respectively. While all measured concentrations (even those less than
the MDL) must be reported to AQS, the confidence associated with each reported concentration
is correlated to its relationship to the corresponding MDL and SQL.

The SQL is equivalent to ten-fold the standard deviation of seven measurements of MDL
samples, which was defined in draft EPA guidance in 19946 as the minimum level (ML). The
3.18-fold was derived by dividing 10 standard deviations by 3.14 (the student's T value for 7
replicates). The MDL process in 40 Code of Federal Regulations (CFR) Part 136 Appendix B is
protective against reporting false positives such that 99% of the measurements made at the
determined MDL value are positively detected (determined to be different from the detectors
response in the absence of the analyte), but does not attempt to characterize precision or address
accuracy at the determined MDL concentration. The SQL (ML) concentration provides more
confidence to the accuracy of the measurement with precision that is well-characterized.

MDL MQOs that must be met (as of the promulgation of this document in October 2016) are
given in Table 4.1-1. Further discussion of MDL background, determination, and importance are
discussed in in Section 4.1.

2.2	NATTS Workplan

Each year the EPA will submit a workplan to each agency conducting NATTS Program work
covering the grant period from July 1 through June 30 of the following calendar year. This
workplan details the sample collection, sample analysis, and data reporting responsibilities and
the associated budget with which each agency must comply. The workplan briefly describes the
NATTS main DQO and associated outputs and outcomes as related to the EPA's strategic goals.
The workplan will prescribe the quantity of quality assurance samples (collocated, duplicate, or
analysis replicate) to be collected at each site for the grant funding year. The workplan also
specifies the required MDL MQOs for the Tier I Core analytes.

2.3	Quality System Development

There are 11 quality management specifications defined in EPA Order CIO 2105.0
(https://www.epa.gov/sites/production/files/2015-09/documents/epa order cio 21050.pdf)
for all EPA organizations covered by the EPA Quality System. It is EPA policy that each agency
conducting NATTS Program work must have a quality system that conforms to the minimum
specifications of the American National Standards Institute (ANSI)/American Society for

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Quality (ASQ) E4 "Specifications and Guidelines for Quality Systems for Environmental Data
Collection and Environmental Technology Programs.7 ASQ E4 is based on the general principle
that the quality system provides guidelines for quality assurance (QA) and quality control (QC)
based on the continuous cycle of planning, implementation, documenting, and assessment.8
Each agency's quality system must also comply with the requirements as given in this TAD,
which complements the requirements in ASQ E4. The purpose of defining the quality systems
requirements in this manner is to provide a single source for developing or revising quality
systems for NATTS Program work. Quality systems documents, including QAPPs and SOPs,
must be revised to reflect the requirements. The quality system and associated functions are
described in the plan-do-check-act feedback loop to ensure continuous improvement to ensure
NATTS MQOs are met.

Plan - The planning portion of the quality system incorporates development of quality systems
documents such as a QMP, QAPP, and SOPs which define the activities to be conducted, who
they are conducted by, when activities are conducted, and how they must be documented. These
documents must adapt and incorporate adjustments to procedures and policies when changes are
needed or when procedures and policies become obsolete. Quality systems documents serve a
dual purpose in that they describe how activities will be conducted and serve to document
policies and procedures for reconstructing past activities.

Do - Activities described in the quality systems documents must be implemented and executed as
prescribed. Staff training is a necessary element of a functional quality system, ensuring that
each individual conducting activities has the experience and skills required to generate work
product of a known and adequate quality. Appropriate training combined with up-to-date quality
systems documents ensure that staff have both the skills and procedures to conduct activities as
required.

Check - Assessments are conducted during and after planning and implementation to ensure that
work products meet the objectives and needs of the program as defined during planning.
Additionally, assessments ensure that quality systems documents sufficiently describe the
activities to be performed, that measurements and calculations are accurate, that staff perform
activities per the current quality systems documents, that staff training is up to date, and that
nonconformances are communicated to those ultimately responsible for the program.

Act - Following assessments, root cause analysis is performed and corrective action is taken to
address nonconformances such that the NATTS program may be continuously improved.

Each agency must have a robust and fully-functioning quality system to ensure that NATTS
Program MQOs for the various DQIs are met. When MQOs are met across the entire network,
the NATTS program DQO will be attained. A fundamental part of a functional quality system is
the QAPP, which each agency must develop and maintain for NATTS program work. Details
and specific quality system elements that must be incorporated in the NATTS QAPP are
presented in Section 3.

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2.4

Siting Considerations

Urban concentration data are needed to address the range of population exposures across and
within urban areas. Conversely, rural concentration data are needed for characterization of
exposures of non-urban populations, to establish non-source impacted concentrations (as
practicable), and to better assess environmental impacts of emissions of air toxics. The NATTS
network at the time of this TAD revision consists of 20 urban sites and seven rural sites. Each of
these sites has been established since 2008, and only modest modifications involving relocation
within a small geographic area have occurred over the past several years. Long-term monitoring
needed to measure average concentrations over successive three-year periods requires that sites
are maintained at, or in very close proximity to, their current location. This long-term data
generation from each site is integral to discerning trends in air toxics concentrations.

For each of the 27 sites currently in the NATTS network, sampling unit siting may have changed
little, if at all, from when sample collection for the NATTS Program began at the specific site.
Nonetheless, site operators should evaluate instrument siting annually to ensure that
requirements continue to be met consistently across the network. Siting criteria to consider
relate to changes at the site such as tree growth, construction or development on property near
the site, new sources, and other changes which may impact sample collection and the resulting
measured concentrations. Particular attention should be paid to vertical placement of inlets,
spacing between sampling inlets, proximity to vehicle traffic (especially where traffic levels have
increased due to housing or business development), and proximity to obstructions or other
interferences. Additionally, monitoring agencies should be aware of changes in sources,
population, and neighborhood make-up (businesses, industry, etc.) which may impact sampler
siting or sample concentrations.

Monitoring unit inlet placement must conform to the specifications listed in 40 CFR Part 58
Appendix E and the additional guidance given below.

2.4.1 Sampling Instrument Spacing. Requirements for sampler spacing are relative to the
sampling unit inlet (edge) and must conform to the criteria listed in Table 2.4-1.

As an example, per the table above, an inlet to a carbonyls sampler must be no less than 2 m and
no more than 15 m above the ground and it may be no closer than 2 m to any high volume
sampler. Moreover, the inlets of collocated samplers may be no further than 4 m in the
horizontal direction, and no more than 3 m apart vertically.

Note that for gaseous HAPs (VOCs and carbonyls) there is no minimum collocation distance as
gases are much more homogeneous in the ambient air than particulate matter, and are not likely
to influence one another, particularly at the low flow rates utilized.

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Table 2.4-1. Sampling Unit Inlet Vertical Spacing Requirements

Parameter

Flow Rate

Inlet Above Ground
Level Height
Requirementa

Horizontal
Collocation
Requirement

Vertical
Collocation
Requirement

VOCs

Low volume
(< 1000 mL/min)

2-15 m

0-4 m

< 3 m

Carbonyls

Low volume
(~ 1 L/min)

2-15 m

0-4 m

< 3 m

PMio Metals

Low volume
(-16.7 L/min)

2-15 m

1-4 mb

< 3 m

High volume 0
(~ 1.1 m3/min)

2-15 m

2-4 mb

< 3 m

PAHs

High volume "•d
(>0.139 m3/min)

2-15 m

2-4 m

< 3 m

a Many standalone sampling unit inlets do not meet the minimum height and must be installed on a support
structure such as a riser or rooftop to elevate the inlet to the proper height.
b 40 CFRPart 58 Appendix A Section 3.3.4.2(c).

0 These high volume sampling units must be minimally 2 m from all other sampling inlets.
d 40 CFR Part 58 Appendix E states that high volume sampling units are those with flow > 200 L/minute.
However the regulations are silent on high volume PAHs sampling units, which operate >139 L/minute; in this
TAD they are conservatively being treated as high volume sampling units such that they must minimally be 2 m
horizontally from other instrument inlets.

2.4.2	Interferences to Sampling Unit Siting. Interference from other samplers,
particularly high volume sampling units for PAHs and PMio metals, must be avoided by ensuring
that all inlets are minimally 2 meters from any high volume inlet. Additionally, to eliminate
recollection of already sampled "scrubbed" air, exhausts (when so equipped) from high volume
sampling units must be directed away from air samplers in the primary downwind direction via
hose that terminates minimally 3 meters in distance from any sampler.

PMio metal sampling unit sites must not be in an unpaved area unless covered by vegetation year
round, so the impacts of wind-blown dusts are kept to a minimum.9

Tarred or asphalt roofs should be avoided for the install of inlets for carbonyls, VOCs, and PAHs
air samplers as these materials may emit target analytes during warmer sampling periods. If
installation is performed on such a roof, it is recommended that the tar or asphalt be encapsulated
or sufficiently weathered and that collected samples be evaluated for marker compounds
indicative of contamination or influence from the tar or asphalt.

2.4.3	Obstructions. An inlet of standalone sampling units and inlet probes must be at least
1 meter vertically or horizontally away from any supporting structure, wall, parapet, or other
obstruction. If the probe is located near the side of a building, it should be located on the
windward side relative to the prevailing wind direction during the season of highest
concentration potential.

Inlets must have unrestricted airflow and be located away from obstacles so that the distance
from the obstacle to the inlet is at least twice the height difference the obstacle protrudes above
the inlet. For instance, if a monitoring trailer is 4 meters above the inlet of a PMio metals
sampling unit, the inlet must be minimally 8 meters from the monitoring trailer.

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All sampling inlets must be minimally 10 meters from the dripline (end of the nearest branch) of
any tree.

2.4.4 Spacing from Roadways. Sampling unit inlets for VOCs, carbonyls, PMio metals,
and PAHs must meet or exceed the minimum distance from roadways according to Table 2.4-2.

Table 2.4-2. Sampling Unit Inlet Required Minimum Distances from Roadways

Roadway Average Daily Traffic (ADT), Vehicles
per Day

Minimum Distance to Inlet (m)a

< 15,000

15

20,000

20

40,000

40

60,000

60

80,000

80

> 100,000

100

a Distance from the edge of the nearest traffic lane. The distance for intermediate traffic counts should be
interpolated from the table values based on measured traffic counts. Values in this table taken from 40 CFR
Part 58 Appendix E, Figure E-l for neighborhood scale sites.

2.4.5 Ongoing Siting Considerations. Agencies must be mindful of conditions at the site
that may impact siting criteria.

Infrequent, non-characteristic, or non-representative sources such as road and building
construction may impact measured sample concentrations due to increased dust, emissions from
materials utilized (paints, paint strippers, asphalt, etc.), and heavy machinery operation. Other
such sources include demolition operations (e.g. buildings or roadways) generating dust which
may impact PMio metals concentrations. Application of fresh pavement and painting of traffic
lanes generates substantial concentrations of PAHs and VOCs. For sites in residential areas,
storage of fuels, operation of charcoal grills, backyard fire pits, and fireplaces can contribute to
elevated measured concentrations of PAHs and PM. Concentrations of HAPs measured at rural
sites may be affected by forest fires, logging operations, etc. Observation of such conditions
must be noted on the sample collection records or site log and may require qualification of
results.

Fast growing trees, newly constructed buildings or traffic routes, and other interferences must be
noted and recorded in the site log and data must be qualified, as appropriate. When these items
negatively impact the siting criteria, the obstruction or interference must be addressed. Such
necessary changes to instrument siting should be included in each site's annual network plan.
For unavoidable impacts to the site (such as a business acting as a significant source), these
should be addressed in the network plan and may require relocation of the site. Such
interferences and potential relocation should be discussed and addressed in concert with the EPA
Region office.

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5 References

Quality Management Plan for the National Air Toxics Trends Stations. Quality Assurance
Guidance Document, EPA 454/R-02-006. September 2005. Available at (accessed October
18,2016): https://www3.epa.gov/ttnamtil/files/ambient/airtox/nattsqmp.pdf

Draft Report on Development of Data Quality Objectives (DQOs) for the National Ambient
Air Toxics Trends Monitoring Network, September 27, 2002
(Appendix A of this TAD)

Analysis, Development, and Update of the National Air Toxics Trends Stations (NATTS)
Network Program-Level Data Quality Objective (DQO) and Associated Method Quality
Objectives (MQOs), Final Report, June 13, 2013. Available at (accessed October 18, 2016):
https://www3.epa. gov/ttnamti l/files/ambient/airtox/nattsdqo20130613 .pdf

National Air Toxics Program: The Integrated Urban Strategy, Report to Congress, EPA
453/R-99-007, July 2000. Available at (accessed October 18, 2016):
https://www.epa.gOv/sites/production/files/2014-08/documents/072000-urban-air-toxics-
report-congress.pdf

National Air Toxics Trends Stations Quality Assurance Annual Report, Calendar Years 2011
and2012, Final, December 12, 2014. Available at (accessed October 18, 2016):
https://www3.epa.gov/ttnamtil/files/ambient/airtox/NATTS20112012QAARfinal.pdf

National Guidance for the Permitting, Monitoring, and Enforcement of Water Quality-based
Effluent Limitations Set Below Analytical Detection/Quantitation Levels, Draft Report.
United States EPA, 1994

Specifications and Guidelines for Quality Systems for Environmental Data Collection and
Environmental Technology Programs, American National Standards Institute
(ANSI)/American Society for Quality (ASQ) E4, 2004.

Overview of the EPA Quality System for Environmental Data and Technology.
EPA/240/R-02/003; U.S. Environmental Protection Agency: Office of Environmental
Information. Washington, DC. November 2002. Available at (accessed October 18, 2016):
https://www.epa.gov/sites/production/files/2015-08/documents/overview-final.pdf

Ambient Air Quality Surveillance, Probe and Monitoring Path Siting Criteria for Ambient
Air Quality Monitoring, 40 CFR § 58 Appendix E, 201

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3.0: QUALITY ASSURANCE AND QUALITY CONTROL

3.1	NATTS Quality Management Plan

EPA OAQPS developed the NATTS Program QMP to provide a set of minimum requirements
that must be followed by all monitoring organizations (state, local, or tribal organization; or
company) conducting NATTS Program work. Development of the QMP began in 2002 and was
completed, approved, and implemented in 2005. Essential QA and QC elements are defined
within the NATTS QMP1 and are excerpted and presented in this document.

3.2	NATTS Main Data Quality Objective, Data Quality Indicators, and
Measurement Quality Objectives

There is a single main DQO for the NATTS Program, which is stated as:

To be able to detect a 15% difference (trend) between two successive 3-year annual mean
concentrations (rolling averages) within acceptable levels of decision error.

To achieve this primary DQO, the DQIs of representativeness, completeness, precision, bias, and
sensitivity must meet specific MQOs, or acceptance criteria. The MQOs for each of the DQIs
are as follows:

•	Representativeness: Sampling must occur at one-in-six day frequency, from
midnight to midnight local time, over 24 ± 1 hours

•	Completeness: At least 85% of all data available in a given quarter must be reported

•	Precision: The CV must be no more than 15%

•	Bias: Measurement error must be no more than 25%

•	Sensitivity: MDLs must meet the network requirements.

Each entity supporting NATTS Program data collection must ensure that these MQOs are met
for each of the DQIs. Implementation of a robust quality system is part of the process to attain
such.

3.3	Monitoring Organization QAPP Development and Approval

As discussed in Section 2.3, the monitoring organization quality system is the framework that
ensures that defensible data of appropriate quality - those that meet the network MQOs for the
various DQIs - are generated and reported to EPA so that the NATTS DQO is attained. The
NATTS QAPP is the roadmap for design of each organization's quality system.

Given the importance of the QAPP, each monitoring organization operating a NATTS
monitoring site and/or laboratory performing analysis of NATTS Program samples must have an
up-to-date and fully approved QAPP which covers all aspects of the sample collection, analysis,

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and QA/QC activities performed by the specific agency and at the associated laboratory at which
samples are analyzed. All major stakeholders involved in the monitoring organization's and/or
laboratory's NATTS Program work should provide input to and review the QAPP to ensure that
aspects of the QAPP for which they are responsible are accurately and adequately described.
The QAPP must minimally be approved and signed by the monitoring organization's NATTS
Program Manager (however named) and the EPA Regional office (or EPA Regional office
delegate as defined in the grant language) in which the monitoring site and/or laboratory exists
and the QAPP must be on-file.

The NATTS QAPP must provide an overview of the work to be conducted, describe the need for
and objectives of the measurements, and define the QA/QC activities to be applied to the project
such that the monitoring objectives are attained. The QAPP should include information for staff
responsible for project management, sample collection, laboratory analysis, QA, training, safety,
data review, and data reporting.

The NATTS QAPP for each monitoring organization is the starting point or roadmap to ensure
that the NATTS MQOs, and therefore NATTS monitoring objectives, are achieved. Review of
the NATTS QAPP on an annual basis (or as required by the Region), conduct of audits and
assessments, and implementation of effective corrective action ensure that NATTS sites and
supporting labs are in fact achieving NATTS program objectives, and, if not, are implementing
corrective actions, as needed.

The NATTS QAPP for each monitoring organization must include the NATTS DQO, DQIs, and
MQOs listed above in Section 3.2, and should include elements listed in Section 3.3.1.3 to ensure
that data of sufficient quality are generated over time such that concentration trends may be
successfully detected and that monitoring data of comparable quality are generated across the
entire NATTS network. The NATTS Program DQO, DQIs, and MQOs take precedent over
regional, state, local, or tribal monitoring objectives for the associated air toxics sampling that is
performed unless the SLT requirements are more stringent than those indicated for NATTS.
Monitoring agencies are free to prescribe more conservative acceptance criteria (e.g. lower blank
acceptance concentrations, tighter recovery ranges, etc.).

3.3.1 Development of the NATTS QAPP. EPA has developed a model QAPP as
described in EPA QA/R-5, EPA Requirements for Quality Assurance Project Plans2 and the
accompanying document, EPA QA/G-5, Guidance for Quality Assurance Project Plans31 This
model QAPP may be a useful starting point in the development of the QAPP for each monitoring
agency conducting NATTS Program work.

3.3.1.1	NATTS QAPP —Program DQOs, DQIs, and MQOs. The NATTS DQOs, DQIs, and
MQOs, which are given in Section 3.2 of this TAD, must be included in the NATTS QAPP.

3.3.1.2	NA TTS QAPP — Performance Based Method Criteria, NATT S Program work must
comply with the requirements listed in this TAD and with the collection and analysis methods
specified in Section 4. Acceptance criteria specified in the methods must be met as prescribed;
however, method deviations are permitted provided the acceptance criteria for precision and bias
are met and can be demonstrated to be scientifically sound and defensible. The NATTS Program

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is designed according to the EPA's Flexible Approaches to Environmental Measurement
(FAEM). The FAEM is a performance-based measurement systems approach which prescribes
specific methods or approaches to be implemented, but permits deviations in the manner in
which the specified methods are performed provided that the resulting data meet the data quality
acceptance criteria for precision and bias.

Planned method deviations must be described in the monitoring organization's QAPP and must
be approved by the cognizant EPA regional office (or delegate as detailed in the grant language).
Adjustments to storage conditions and holding times are not permitted, nor are deviations which
permit exceedances to the specified method acceptance criteria or to NATTS MQOs as such
would allow data of a quality lower than, and not comparable to, that required to be generated in
the NATTS network per the NATTS QMP and per this TAD. Agency QAPPs should
incorporate much of the guidance listed in this TAD.

3.3.1.3 NA TTS QAPP - Incorporating Quality System Elements. In addition to the
example information contained in the model QAPP listed in Section 3.3.1, monitoring
organizations should develop and prescribe within the QAPP the following quality system
elements which are described in more detail in the following sections:

•	Pertinent SOP documents

•	Corrective action procedures

•	QA unit and internal audit procedures

•	Calibration of instruments

•	Document control

•	Training requirements and documentation, and demonstration of capability

•	Sample custody and storage

•	Traceability of reagents and standard materials

•	Labeling

•	Early warning systems - control charts

•	Spreadsheets and data reduction algorithms

•	Software validation, updating, and upgrading

•	Review of records

•	Data verification and validation

•	Reporting of results to AQS

•	Records retention and archival

•	Safety

3.3.1.3.1 Standard Operating Procedure Documents. The NATTS QAPP must list
the pertinent SOPs, however named, to be followed to conduct all NATTS Program work. SOPs
must prescribe the details of the activities applicable to sample collection in the field, preparation
and analysis of the samples in the laboratory, and data review, reduction, and reporting. SOPs
must minimally cover the following aspects of the NATTS program:

•	Sample collection for VOCs, carbonyls, PMio metals, and PAHs;

•	Sample preparation and analysis for VOCs, carbonyls, PMio metals, and PAHs;

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•	Calibration, certification, and maintenance of each type of sample collection and
analysis instrument;

•	Calibration of critical support equipment; and

•	Data review.

Additional SOPs should be prepared as necessary to cover routine procedures and repetitive
tasks which, if performed incorrectly, could affect data quality such as COC and performing
numerical calculations (describing rounding, significant figures, etc.).

Refer to Section 3.3.2 for further guidance on preparation of SOPs.

For portions of the sample collection and analysis which are contracted or otherwise performed
elsewhere (not by the cognizant NATTS monitoring agency), the monitoring organization must
reference the SOP of the third party in its NATTS QAPP and if the laboratory is other than the
national contract laboratory (which are maintained by EPA), must maintain a current, approved
copy of the third party's SOP(s) on file. Monitoring agencies must ensure that third-party
laboratory QAPPs and SOPs are available.

3.3.1.3.2 Corrective Action Process. Each monitoring organization must have a
corrective action process in place that is executed upon discovery of nonconformances to the
NATTS TAD, NATTS agency QAPP, and/or applicable agency SOPs. Each monitoring
organization should ideally have a corrective action tracking procedure so that all corrective
actions are available in a single location (e.g., binder, database, etc.) and may be readily
referenced. Corrective actions are taken to remedy nonconformances found during audits or
assessments; however, corrective action must also be performed and documented for
nonconformances or problems noted during routine, everyday operations.

For each nonconformance, a corrective action report should be prepared which includes the
following components:

•	Unique corrective action report (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., PMio metals 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

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•	Immediate and long-term (if needed) remedial corrective actions (and documentation
of when completed)

•	Due date for remedial action completion

•	Impact assessment of nonconformance

•	Assessment of corrective action effectiveness

•	Demonstration of return to conformance

•	Follow up audit to ensure corrective actions were effective (with date completed)
Situations which would require a corrective action report include, but are not limited to:

•	Repeated calibration failure

•	Incorrect sample storage conditions

•	Blank contamination

•	Incorrect procedures followed

•	Repeated QC acceptance criteria failures

Root cause analysis should 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 should 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.

An example CAR form is shown below in Figure 3.1-1.

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Corrective Action Report





Corrective Action Report ID ((" \R-YYYYM\tDIWW r





Initiated By:





Area(s) or Procedures) Affected:





Description of Nonconformance:





Investigation of Nonconformance:





Root Cause:





Investigation for Similar Instances of Nonconformance:





Immediate Corrective Aetion(s):

Datefs) completed





Impact Assessment of Nonconformance:





Long-term Corrective Action(s):

Date(s) completed





Assessment of Effectiveness of Corrective Action:





Additional Corrective Action Necessary:
(optional - Provide CAR ID)

Date(s) completed





Return To Conformance (if applicable):

Date(s) eompleted





Follow-up Actions (if any):
Date(s) completed





Corrective Action Completion Date:





Approval of Corrective Action Completion





QA Manager Representative:







Figure 3.1-1. Example Corrective Action Report

3.3.1.3.3 Quality Assurance Unit and Internal Audit Procedures. Each
monitoring organization should have a QA group, or, minimally, an individual quality assurance
officer (however named). This quality assurance unit is typically responsible for performing
assessments (audits) of sample collection procedures, sample analysis procedures, data records,
and the quality system as well as managing and overseeing the corrective action process,
managing document control, performing QA training, and reviewing QC data as applicable.
Monitoring organizations which contract laboratory analysis should ensure that the laboratory
operates a QA program to oversee and conduct audits of these aspects for which the laboratory is
responsible.

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QA staff should be independent from project management to best ensure that nonconformances
are addressed and remedied and to maximize the likelihood that data of sufficient quality are
generated. Moreover, independent QA oversight is integral to ensuring that internal audits are
objective. For agencies which may not have sufficient resources to dedicate an independent QA
staff member, an individual not affiliated with a given activity may serve to perform QA
functions. The quality assurance staff should conduct three types of audits:

•	Technical systems audits (TSAs): An onsite review and inspection of the monitoring
agency's monitoring program to assess compliance with the established regulations
governing the collection analysis, validation, and reporting of ambient air quality
data.4 The auditor observes staff conducting sample collection and analysis activities
and compares the activities performed against procedures codified in the agency
QAPP and applicable SOPs, ensures proper documentation practices, verifies staff
training records, verifies proper data reporting, and ensures all operations are
performed in accordance with appropriate safety practices.

•	Audits of Data Quality (ADQs): The auditor reviews reported data to ensure
traceability of all measurements and calculations from initial receipt of sample
collection media through to the final reported results. Calculations and data
transformations are verified to be accurate.

• Quality Systems Audits (QSAs): The auditor reviews quality systems documents
such as the agency QMP, QAPP, and SOPs to ensure they are current and to assess
compliance with program requirements, such as those stipulated in this TAD.

The monitoring organization QAPP, SOP, or other suitable controlled document should define
the schedule for audit frequency, the scope of each type of audit (i.e., which operational areas
must be observed, which records must be reviewed, etc.), the timeline for following up on audit
nonconformances, the timeline for conducting follow-up audits that ensure that
nonconformances are being remedied in a satisfactory and timely manner, and the method for
reporting audit outcomes to agency management and staff. For monitoring organizations which
utilize contract laboratory analysis services, the laboratory QAPP, QMP, or similar controlled
document should define these frequencies.

3.3.1.3.4 Calibration of Instruments. Each agency must define in the NATTS
QAPP, SOP, or similar controlled document the frequency at which critical instruments must be
calibrated and the acceptable tolerance for such calibrations. Critical instruments are defined as
those whose measurements directly impact the accuracy of the final reported concentrations.
The calibration of such instruments must be traceable to a certified standard and a standard
calibration process. Critical instruments include, but are not limited to:

•	Flow transfer standards

•	Mass flow controllers, mechanical flow controllers, and meters generating flow
readings for calculating total collected sample volumes and diluting standard gases

•	Thermometers and barometers

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•	Volumetric delivery devices such as fixed and adjustable pipettes, bottletop
dispensers, etc.

•	Balances

•	Pressure gauges and transducers when measuring pressures for dilution or standard
preparation

Such critical instruments must be calibrated initially and the calibration verified (checked)
periodically to ensure the calibration remains valid. Instruments must be recalibrated (or
removed from service and replaced with a properly calibrated unit) when calibration verifications
fail. Data generated with the failing equipment since the last acceptable calibration or calibration
verification must be examined and considered for qualification. Monitoring agencies are
encouraged to perform more frequent calibration checks (identified as recommendations) to limit
the amount of data subject to qualification when calibration checks fail acceptance criteria.
Frequency of calibration verifications must conform to Table 3.3-1 and must be addressed within
the agency NATTS QAPP, SOPs, or similar controlled document.

Table 3.3-1. Calibration and Calibration Check Frequency Requirements for Standards

and Critical Instruments

Instrument or
Standard

Area of Use

Required Calibration Checka
Frequency and Tolerance

Required
Calibration b Frequency

Balances

Laboratory - Weighing
standard materials, calibration
of pipettes, determining mass
loss for microwave metals
digestion, weighing PAHs
sorbent resin (XAD-2)

Each day of use with certified
calibration check weights
bracketing the balance load;
Must be within manufacturer-
specified tolerance covering the
range of use

Initially, annually, and when
calibration checks
demonstrate an out of
tolerance condition

Certified Weights

Laboratory - Calibration
verification of balances

Check not required.

Annual certification by
accredited metrology
laboratory; Must be within
manufacturer-specified
tolerance

Mechanical
Pipettes

Laboratory - Dispensing
liquid volumes

Minimally quarterly,
recommended monthly, by
weighing delivered volumes of
deionized water bracketing
those dispensed; Must be within
manufacturer-specified
tolerance covering the range of
use

Initially and when calibration
checks demonstrate an out of
tolerance condition

Bottletop
Dispensers

Laboratory - Dispensing
critical liquid volumes

Each day of use by delivery
into a To Contain (TC)
graduated cylinder
Must be within ± 5%

When delivery volumes are
set and when calibration
checks fail criteria

Thermometers -
Laboratory

Laboratory - Temperature
monitoring of water baths,
metals digestion, refrigerated
storage units, canister
cleaning ovens, and water for
pipette calibration

Check not required.

Annual at temperature range
of use or at not-to-exceed
temperature - Correction
factors applied to match
certified standard

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Table 3.3-1. Calibration and Calibration Check Frequency Requirements for Standards

and Critical Instruments (Continued)

Instrument or
Standard

Area of Use

Required Calibration Checka
Frequency and Tolerance

Required
Calibration b Frequency

Thermometers -
Meteorological

Field - Recording
environmental conditions
during sample collection

Minimally quarterly, monthly
recommended

Must be within

± 0.5°C of certified standard at
working temperature

Initially and when calibration
checks indicate readings out
of tolerance

Barometers

Field - Recording
environmental conditions
during sample collection

Laboratory - Recording
environmental conditions
during instrument calibration

Minimally quarterly, monthly
recommended

Must be within
±10 mm Hg of certified
standard at typical barometric
pressure

Initially and when calibration
checks indicate readings out
of tolerance

Flow Transfer
Standards

Field - Critical flow orifices
and volumetric flow meters
for calibrating and verifying
sampling unit flows

Built-in thermometers and
barometers must be calibrated

Check not required.

Annual; Must be within
manufacturer-specified
tolerance and cover the range
of use

Pressure Gauges
or Transducers

Field and Laboratory -
Measure canister
pressure/vacuum before and
after collection, measure final
canister vacuum following
cleaning

Annual. Must be within 0.5 psi
or manufacturer-specified
tolerance and cover the range of
use

Initially and when calibration
checks show out of tolerance.
Must cover the range of use

Flow Controllers
and Meters -
Laboratory

Laboratory - Mass flow
controllers (MFCs), flow
rotameters, or similar devices
for measuring/metering gas
flow rates for critical
measurements (standard gas
mixing)

Minimally quarterly, monthly
recommended

Flow within ± 2% of certified
standards

Initially and when calibration
checks demonstrate flows are
out of tolerance

VOCs Sampling
Units

Field - Collection of VOCs in
canisters

Flow control (such as MFC)
Pressure gauge/transducer

If performed, minimally
quarterly, for flow control,
annually for pressure
gauge/transducer

Flow control (check is optional)
within ±10% of certified flow

If needed for critical
measurements (canister
starting/ending pressure),
pressure gauge/transducer
within ±0.5 pounds per square
inch (psi) of certified standard

Flow control - Initially and
when components affecting
flow are adjusted or replaced,
or when calibration checks
demonstrate flows are out of
tolerance

Pressure gauges/transducers -
initially and when calibration
checks demonstrate flows are
out of tolerance

Carbonyls
Sampling Units

Field - Collection of
carbonyls on 2,4-
dinitrophenylhydrazine
(DNPH) sorbent cartridges

Flow control (such as MFC)

Minimally quarterly, monthly
recommended

Flow within ±10% of certified
flow and design flow

Initially, when calibration
checks demonstrate flows are
out of tolerance, and when
components affecting flow
are adjusted or replaced

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Table 3.3-1. Calibration and Calibration Check Frequency Requirements for Standards

and Critical Instruments (Continued)

Instrument or
Standard

Area of Use

Required Calibration Checka
Frequency and Tolerance

Required
Calibration b Frequency

PMio Metals
Sampling Units

Field - Collection of PMio on
filter media for metals
analysis

Flow control must be within
tolerance

If equipped, thermometer and
barometer must be within
field tolerances specified
above

Minimally quarterly, monthly
recommended

Low volume flows within ±4%
of transfer standard and ±5% of
design flow

High volume flows within ±7%
of transfer standard and ±10%
of design flow

Initially, when calibration
checks demonstrate flows are
out of tolerance, and when
components affecting flow
are adjusted or replaced

PAHs Sampling
Units

Field - Collection of
carbonyls on QFF, PUF, and
XAD-2 media sampling
modules

Flow control must be within
tolerance

If equipped, thermometer and
barometer must be within
field tolerance specified
above

Minimally quarterly, monthly
recommended

Flow within ±10% of certified
flow and design flow

Initially, when calibration
checks demonstrate flows are
out of tolerance, and when
components affecting flow
are adjusted or replaced

GC/MS for
VOCs analysis

Laboratory - Analysis of
VOCs from stainless steel
canisters

Refer to Table 4.2-3

Initially, following failed
continuing calibration
verification (CCV) check,
following failed
bromofluorobenzene (BFB)
tune check, or when
changes/maintenance to the
instrument affect calibration
response

HPLC for
carbonyls
analysis

Laboratory - Analysis of
carbonyl-DNPH extracts

Refer to Table 4.3-4

Initially, following failed
continuing calibration
verification (CCV) check, or
when changes/maintenance to
the instrument affect
calibration response

ICP/MS for
metals analysis

Laboratory - Analysis of
PMio digestates for metals

Refer to Table 4.4-3

Each day of analysis

GC/MS for
PAHs analysis

Laboratory - Analysis of
polyurethane foam
(PUF)/resin/quartz fiber filter
(QFF) extracts for PAHs

Refer to Table 4.5-3

Initially, following failed
continuing calibration
verification (CCV) check,
following failed
decafluorotriphenylphosphine
(DFTPP) tune check, or when
changes/maintenance to the
instrument affect calibration
response

a Calibration verification checks are a comparison to a certified standard, typically at a single point at which the
instrument is used, 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 replaced.
b Calibration refers to resetting the reading or setting or applying a correction factor to the instrument or standard
to match a certified standard, typically at three or more points bracketing the range of use.

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3.3.1.3.4.1 Calibration Verification (Checks)

Following instrument calibration, critical instruments must undergo periodic calibration
verification (check) to ensure bias meets the assigned acceptance criterion. Calibration checks
typically challenge the instrument at a single point typical of use or toward the middle of the
calibration range. Calibration checks may also include multiple points bracketing the range of
use. Instruments for which calibration checks are required include, but are not limited to:

•	Mass flow controllers, mechanical flow controllers, and meters generating flow
readings for calculating total collected sample volumes and diluting standard gases

•	Volumetric delivery devices such as fixed and adjustable pipettes, bottletop
dispensers, etc.

•	Balances

•	Analytical instruments generating concentration data (e.g. GC/MS, HPLC, ICP-MS)

3.3.1.3.5 Document Control System. Each monitoring organization must have a
prescribed system defined in its NATTS QAPP or QMP for control of quality system documents
such as QMPs, QAPPs, and SOPs. A properly operating document control system ensures that
all documents integral in defining performance criteria and prescribing procedures are current,
and that outdated or superseded documents are not available for inadvertent reference. All such
controlled documents must minimally be approved by a cognizant manager (however named)
who is ultimately responsible for the conduct of the work (e.g., monitoring agency director for an
agency QMP, NATTS program manager for the NATTS QAPP, monitoring manager or
laboratory manager for a field or analytical SOP, etc.), and by a QA staff member responsible for
overseeing the work. Current versions of controlled documents must be readily available to each
staff member conducting NATTS Program work.

To increase the likelihood that all applicable NATTS activities are performed according to
current, approved procedures, the distribution of controlled documents should be managed and
tracked such that only the current, approved versions are available in areas in which such
documents are needed (for example, at field sites and in laboratories) and that outdated versions
are removed once superseded. With the proliferation of networked computers at monitoring sites
and within laboratories, it is convenient to have electronic versions of controlled documents
available which are write-protected. Printing privileges of such read-only electronic documents
should be disallowed, or, if printing is permitted, such documents should be identified via
watermark with the date of printing and their expiration.

Procedures and frequency for changing and updating controlled documents should be clearly
described in the QAPP, SOP, or similar controlled document. Preparing amendments is an
efficient way to address minor changes to controlled documents. An amendment describes the
change and rationale for the change, and may be appended to the document without requiring a
complete revision of the document. Such amendments should be approved minimally by the
cognizant manager (field operations manager or laboratory manager) responsible for the conduct
of the work, and by a member of QA staff responsible for the document and overseeing the

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work. For major changes to controlled documents, such as those required for a new sampling
unit or updated laboratory information management system (LIMS), a new revision should be
prepared and approved by all required signatories. A system for identifying revisions should be
prescribed to allow tracking of versions. A typical example system uses whole numbers to
designate major revisions and decimals to indicate minor revisions. For example, the first
version of a QAPP would be version 1.0, a minor revision would update to version 1.1, and the
next major revision would be version 2.0, and so on.

An effective date must be included on all controlled documents and they should include an issue
date if this is different from the effective date. A period between the issue date and effective
date permits staff to become familiar with the SOP prior to its becoming effective. A header or
footer should indicate the effective date, version number, page number, and total number of
pages included in the document. A best practice is to include a revision history section for each
controlled document so that readers can quickly and efficiently ascertain changes from the
previous version of the document.

Monitoring agencies (and laboratories) should forbid uncontrolled excerpts to be printed from
controlled documents such as operation instructions or calibration standard preparation tables.
These excerpts are then uncontrolled and may inadvertently be referenced when the version of
origin is no longer effective. For the same reason, unless permitted by the agency's controlled
document policy, uncontrolled shortcut procedural summary documents (summarizing SOP
procedures) similarly should not be permitted. Such procedure summaries may be included in
the NATTS QAPP or applicable SOP to ensure they are updated when the document is revised.
Similarly, notes should not be recorded on controlled document hard copies unless permitted by
the monitoring organization's controlled document revision or amendment process.

The review frequency for controlled documents should be described within the QMP, QAPP, or
similar controlled document. Periodic review of controlled documents must be performed to
ensure that they adequately describe current agency policies and procedures. Each such review
and outcome of the review (e.g., adequate, minor revision needed, major revision needed, etc.)
should be documented. The agency NATTS QAPP must be reviewed annually and associated
SOPs are recommended to be reviewed annually, but must minimally be reviewed every three
years. SOPs must be reviewed following major changes to network guidance to ensure they are
compliant with the updated guidance.

3.3.1.3.6 Training Requirements and Documentation, and Demonstration of
Capability. The training required for each staff member who conducts NATTS Program work
must be prescribed in the agency NATTS QAPP, SOP, or similar controlled document, and the
completion of each required training element must be documented. Specifically, staff must read,
and document that they have read and understood, the most recent versions of the NATTS
quality system documents (QAPP, SOPs, etc.) pertaining to their responsibilities.

Each monitoring organization must have minimum requirements for staff position experience
including a combination of education and previous employment experience. In addition to
documented experience, each staff member must be approved by cognizant management to
conduct the activities for which they are responsible. Such approval should be granted initially

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before beginning work and periodically thereafter, and should be minimally based on successful
completion of a demonstration of capability (DOC) process. DOCs are described in the
subsections below.

Each staff member must have training documented which indicates the staff member's training is
current for each procedure performed, as required by the agency QMP, NATTS QAPP, SOP, or
similar controlled document. Training documentation can consist of hard copy or electronic
documentation and may be located in numerous files or locations, provided it can be retrieved for
auditing purposes. In addition to relevant DOC documentation, the training records should
include items related to experience such as a resume or curriculum vitae, certificates from
training coursework, and a job description specific to the monitoring organization.

3.3.1.3.6.1	Initial Demonstration of Capability

Once the staff member has read the relevant current SOP, and documented such, the staff
member must demonstrate proficiency with a given procedure prior to performing activities to
generate or manipulate NATTS program data. One method by which such could be
accomplished is as follows. First, the staff member observes an experienced staff member
performing the procedure. Next, the trainee conducts the activity under the immediate
supervision of and with direction from an experienced staff member. Finally, the trainee
performs the activity independently while being observed by an experienced staff member. To
ensure all aspects of a procedure are captured in the initial DOC, it is recommended that a
checklist be developed that includes all required steps consistent with the applicable quality
system document(s) to perform the activity. Regardless of the actual initial DOC process
selected for implementation, the process to be implemented and its acceptance criteria must be
defined in the QAPP, SOP, or similar controlled document.

3.3.1.3.6.2	Ongoing Demonstration of Capability

Each staff member performing NATTS Program field work must demonstrate continued
proficiency with tasks for which they are responsible, minimally every three years, but
recommended to be annually. The staff member should be observed by a QA staff member (as
part of an audit), experienced staff member, or responsible manager.

Laboratory staff must annually demonstrate continued proficiency by completing one of the
following:

•	Repeat of the IDOC procedure.

•	Acceptable performance on one or more blind samples (single blind to the analyst)
following the approved method for each target analyte. Acceptable performance is
indicated by demonstrating recovery within limits of the method LCS for each target
analyte.

•	Analysis of at least four consecutive LCSs with acceptable levels of bias. Acceptable
performance is indicated by demonstrating recovery within limits of the method LCS
for each target analyte.

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• Acceptable performance on a PT sample. Acceptable performance is defined by the
provider of the PT sample, as indicated by no results marked as "Unacceptable" or
equivalent, for target analytes.

As with the initial demonstration of capability, the continuing DOC process and its applicable
process acceptance criteria must be prescribed in the agency NATTS QAPP, SOP, or similar
controlled document.

3.3.1.3.7	Sample Custody and Storage. Procedures and details related to sample
custody and sample storage must be included in each monitoring organization's NATTS QAPP
or similar document such as a sample handling SOP.

The COC is a documented trail of who had possession of a sample or group of samples at any
specific point from collection through receipt at the laboratory. Custody records must include
details of transfers of possession between individuals, between individuals and shippers (when
applicable), and to storage at the laboratory and any pertinent details such as storage location and
conditions. It is strongly recommended to maintain sample integrity that samples be protected
and access to the samples be limited to those responsible for the samples.

Sample custody begins when media are readied for dispatch to the field monitoring site. At this
point, a COC form, sample collection form with portions dedicated to documenting custody
transfers, or other form as defined by the monitoring agency, must accompany the sampling
media until they are received at the laboratory for analysis. Each time the sampling media are
transferred, the individual relinquishing the sample and receiving the sample, the date and time,
and the storage conditions (for carbonyls and PAHs samples) should be documented so the
history of the sample is traceable and can be reconstructed. Storage conditions for carbonyls and
PAHs samples must be monitored with a calibrated thermometer and storage records should
include unique identifiers for the thermometers monitoring the storage units.

Sample collection forms or other forms as defined by the monitoring agency may double as a
COC form provided they include sufficient space for documenting all sample transfers and
storage conditions.

If not already assigned prior to dispatching to the field, upon receipt at the laboratory each
specific field-collected sample medium (cartridge, filter, canister, etc. including all field QC)
must be uniquely identified for tracking within the laboratory. This unique identifier allows each
sample to be tracked to ensure proper storage within the laboratory and to avoid switching of
samples which can invalidate sample data.

3.3.1.3.8	Traceability of Reagents and Standard Materials. Each monitoring
organization must prescribe in its NATTS QAPP, or similar controlled document, the
information to be recorded and maintained for traceability of reagents and standard materials and
must codify the requirements for their labeling.

All reagents and standard materials utilized in the preparation and analysis of NATTS Program
samples must be of known concentration or purity as documented by a certificate of analysis

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(COA) or similar certification. Such certification documents must be retained. The one
exception to this is for deionized water which is sourced from a water polisher, for which records
of the maintenance must be maintained to demonstrate that the water is of appropriate quality.
When prepared in the laboratory, the source of all reagents must be documented (in a logbook or
similar) and be traceable to the certificates of analysis. Lot or batch numbers for each reagent
(acid, solvent, etc.) must be documented for all preparations. Critical volume measurements
(e.g. delivered volumes of stock standards, final volumes of diluted standards) must be
documented in the preparation log when used for reagent or standard preparation, including
unique identifiers (where applicable) for measurements by way of volumetric syringes,
mechanical pipettes, and volumetric flasks, among other methods. The conditions at which the
reagents and standards are stored must be documented, particularly for those reagents and
standards which require special conditions such as refrigeration or protection from light. If
maintenance of a specific temperature range or not-to-exceed temperature is required, the
temperature(s) of storage container(s) must be measured and documented at a prescribed
frequency (recommend minimally daily during normal working hours) and the calibration of
thermometers must be certified and traceable at the critical temperature (e.g. for a carbonyls
sample storage refrigerator, the thermometer must be calibrated at 4°C). A calibrated min-max
type thermometer or continuous monitoring is recommended to ensure that the not-to-exceed
temperature is maintained.

Expiration dates must be assigned to reagents and standards and must be set as the earliest
expiration date among any component comprising the reagent or standard. If the expiration date
is given as a month and year, the date after which the reagent or standard may not be used is
understood to be the last day of the indicated month. For reagents or standards which were not
assigned an expiration by the supplier, the monitoring agency may assign an expiration
(recommended not to exceed five years). The policy for assigning the expiration date when not
provided by the manufacturer must be prescribed in the monitoring agency QAPP, SOP, or
similar controlled document.

3.3.1.3.9	Labeling. Each NATTS monitoring organization must have a prescribed
procedure for labeling of all samples, standards, and reagents. Each must be uniquely identified
and the identifier clearly labeled on the applicable container (e.g., VOCs canister tag, DNPH
cartridge foil pouch, metals filter holder, PAHs cartridge transport jar, GC vial containing
solvent, etc.).

Standards and reagents must be minimally labeled to identity the contents (e.g., 69-component
VOC blend in nitrogen, 2 |ag/m L benzo(a)pyrene in hexane, 2% v/v nitric acid, etc.), and should
include the preparation date and expiration date. All standards and reagents prepared or mixed in
the laboratory must be traceable to a preparation log.

3.3.1.3.10	Early Warning Systems — Control Charts. Laboratories should employ
control charting where practical to track QC parameters. If used, the process of control charting
should be described in the NATTS QAPP, SOP, or similar controlled document. Parameters
suitable for control charting include concentrations measured in QC samples such as blanks,
laboratory control spikes, matrix spikes, secondary source calibration standards, internal
standards, and proficiency test results. Control charts may be prepared with spreadsheets and

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many LIMS incorporate control charting capabilities. Once implemented, control charts are
simple to maintain and are a valuable tool for evaluating trends and may provide an alert before
nonconformances occur. Control charts should be periodically updated and reviewed to ensure
data inputs are current and that associated control limits meet method-specified criteria. The
update frequency should be prescribed in the applicable controlled document.

3.3.1.3.11	Spreadsheets and Other Data Reduction Algorithms. While spreadsheets
and other automated or semi-automated data reduction algorithms, for instance, those contained
in LIMS software, are valuable tools for transforming and reducing data generated by sampling
and analysis instruments, they have limitations and may be sources of error. If a NATTS agency
in fact employs such processes it should prescribe the NATTS QAPP, SOP, or similar controlled
document the details for preparation, review, and control of data reduction spreadsheets or of
other non-commercial automated and/or semi-automated data transformation and reduction
algorithms and processes. Implementation of such processes will require an initial time
investment, but should minimize errors and subsequently increase the efficiency and speed of
data reporting. If an agency were to implement such processes, it should codify the relevant
procedures into its QAPP or other quality system document and may consider adoption of the
following best practices.

Where possible, manual entry of instrument data into spreadsheets and/or non-commercial
automated data transformation/reduction algorithms must be minimized. Rather, the direct
importation of data outputs from instruments into such systems is preferable so as to avoid
transcription errors. Furthermore, data reduction spreadsheets or other non-commercial
algorithms must be validated and locked/non-editable to ensure that critical formulas are not
inadvertently altered. The process of validation of the spreadsheet or non-commercial algorithm
must be codified in the quality system document such that it is known and verifiable that all
critical aspects of the data reduction procedure have been confirmed to be technically defensible,
valid, and error-free. This validation should be performed when the spreadsheet or non-
commercial algorithm is revised.

3.3.1.3.12	Software Validation, Testing, Updating, and Upgrading. Each agency
performing NATTS Program work should have prescribed within the agency NATTS QAPP,
SOP, or similar controlled document policies and procedures for testing, updating, and upgrading
computer software systems employed for data generation and manipulation such as
chromatography data systems (CDSs), LIMS, and other instrument software where applicable.
The policies and procedures should detail the responsible individuals, testing required, and
documentation to be maintained.

3.3.1.3.12.1 Software Validation

Off-the-shelf software packages such as spreadsheet programs are presumed to be validated. It is
strongly recommended that individual spreadsheets should be validated as described in Section
3.3.1.3.11. Other software packages such as CDS should undergo validation by manually
calculating values to ensure that software outputs match the expected result. Due to the
differences in algorithms or limitations to how software packages handle calculations, there may
be slight differences between commercial software package outputs and spreadsheets or other

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software systems. Such differences should be noted and addressed where possible if they impact
digits which are significant in the calculations. Records of software validation must be
maintained.

3.3.1.3.12.2	Software Testing

Once validated, software packages should be tested minimally annually and when updated or
upgraded to ensure that calculations are being performed as expected. This may be performed by
processing a previous dataset through the software and comparing the outputs for parity. The
rationale behind such testing is to ensure that software systems and calculation regimes have not
become corrupted. Discrepancies in outputs must result in corrective action to rectify the
discrepancies.

3.3.1.3.12.3	Software Updating and Upgrading

Software manufacturers periodically release software updates to correct bugs, improve the user
interface, or include new functionality, etc. Updates or upgrades installed should be documented
in a log and be verified for proper operation by the testing regime prescribed in Section
3.3.1.3.12.2. Agencies should verify that upgrades were performed and the date they were
performed.

3.3.1.3.13 Review of Records. To ensure that sample collection and analysis
activities were performed as prescribed, are documented completely and accurately, and to
identify potential nonconformances that may invalidate data, all logbooks, forms, notes, and data
must be reviewed by a second individual who has familiarity with the procedure but who did not
generate the record. Field site notebooks, site equipment maintenance logs, sample collection
forms, COC forms, laboratory preparation logs, analysis instrument logs, storage temperature
logs, and all other critical information must be reviewed on a periodic basis by an individual who
did not record the documentation. Each record should minimally be reviewed for legibility,
completeness, traceability, and accuracy (including hand calculations not performed by a
validated spreadsheet). It is also recommended that reviews should determine if the procedures
followed were codified and appropriate. These reviews must be documented, either within the
records themselves, or in a separate review notebook or form indicating the individual
performing the review, the materials reviewed, and when the review was performed. Details of
the review scope, schedule, responsible individuals, and required documentation must be
described in the NATTS QAPP, SOP, or similar controlled document. These reviews should
occur minimally quarterly and a best practice would be to conduct reviews monthly.

If documentation errors are noted during review, they should be corrected as soon as practical.
Correction of handwritten entries must be performed with a single line, the correct entry must be
made nearby or be traceable to an annotated footnote, the individual making the correction must
be identified by signature or initials, the notation must include the date the correction was made,
and the notation should include the rationale for the correction. Corrections to electronic logs
must likewise not overwrite the original record, must identify the individual making the
correction, must include the date of the correction, and should include the rationale for the

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correction. Further guidance on maintaining electronic logs is available in the EPA Technical
Note - Use of Electronic Logbooks for Ambient Air Monitoring.5

Note that reviewing records as described in this section is a component of the data verification
process described in the next section, but should not be substituted for the data verification
process.

3.3.1.3.14 Data Verification and Validation. Data verification is the systematic
process for evaluating objective evidence (data) for compliance with requirements for
completeness and for correctness as stipulated by a specific method. Objective evidence consists
of the records such as sample collection forms, sample storage records, laboratory preparation
records, calibration records, analysis results, etc. Validation is the confirmation that verified data
have met specific intended use requirements, i.e., meeting DQO requirements prescribed in the
NATTS QAPP.6

Spurious data have an outsized influence on statistical analysis and modeling; thus, data must be
closely examined to ensure that concentration values accurately reflect air quality conditions at
the monitoring site through verification and validation. Monitoring organizations must not
censor (invalidate) data they consider to be anomalous or spurious. Data should only be
invalidated if they do not meet the critical specifications in the validation tables in Section 7 or
when there is a known problem with the data which would invalidate them. For data suspected
to be spurious or anomalous, they should be qualified appropriately when entered into AQS so
the end data user can decide the most suitable manner for handling the data.

Each monitoring organization must have processes and policies which must be described within
its NATTS QAPP or other quality systems document for data verification, data validation, and
the associated documentation that is generated and retained during the processes of verification
and validation of data. It is a best practice that NATTS agencies perform data verification in
accordance with the tables in Section 7 of this TAD where method-specific criteria may be
found. Additional information on implementing and structuring data validation and verification
policies and procedures is available in Guidance on Environmental Data Verification and Data
Validation, EPA QA/G-8, EPA/240/R-02-004 6

3.3.1.3.14.1 Data Verification

The data verification process begins when sample media are dispatched to the field for collection
and ends following final review of a completed data package. Verification includes many of the
aspects of data review discussed in Section 3.3.1.3.13 as well as additional QC checks such as
verification of proper sample handling and verification of calculations. Once data verification is
completed, data validation is conducted. Given in this section is a generic data verification
process that a NATTS agency may adopt. Data verification is not required, but is strongly
recommended.

Upon retrieval of samples in the field, the field operator verifies that sample collection
parameters comply with SOPs and documents the collection details on the field sample
collection form. At the laboratory, custody documentation is reviewed to ensure that sample

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collection documentation meets specification and does not exhibit anomalies which would
invalidate the collected sample. Laboratory analysts ensure that media have been stored properly
and that QC samples are prepared according to method specifications. Following acquisition of
the analytical data, the analyst reviews QC results as well as the acquired data to ensure proper
analyte identification and to verify that method-specified acceptance criteria are met. A peer
then reviews the entire data package beginning with sample collection and custody
documentation through preparation, analysis, and concentration calculations so as to ensure that
method procedures were properly followed, calculations are correct, and method-specific
acceptance criteria are met. At any point during the initial and/or peer review, errors must be
corrected and additional notes added to describe problems or anomalies in the sample collection
and analysis processes. QC failures or method deviations must be documented and appropriate
flags applied to the results so staff performing data validation may be alerted regarding data
which may be compromised or require invalidation.

3.3.1.3.14.2 Data Validation

Data validation is performed following the data verification process and is a separate process
from the network-wide assessments made by data users to evaluate trends and assess whether
data meet MQOs. During validation data are evaluated by the monitoring agency for compliance
with specific use requirements which may include comparison of collocated sample results,
examination of meteorology data, sample collection notes, and custody forms, and review of
historical data for trends analysis and identification of outlier data. Attainment of the NATTS
MQOs should also be assessed by monitoring agencies to determine if the data will support
attainment of the NATTS DQO. Failure to attain the NATTS MQOs must prompt corrective
action. Given in the remainder of this section is a generic data validation process that a NATTS
agency may adopt. Note that data are not being validated if the monitoring agency is not
performing data validation since he EPA does not perform subsequent data validation.

An appropriate starting point for validating data involves preparing summary statistics by
calculating the central tendency of the dataset along with the standard deviation and relative
standard deviation of the concentrations of each HAP. The central tendency may be calculated
as the arithmetic mean, geometric mean, median, or mode:

•	Arithmetic mean: The sum of the measured concentration values divided by the total
number of samples in the dataset.

•	Geometric mean: The nth root of the product of n concentration values.

•	Median: The concentration value represented by the midpoint of the dataset when the
concentration values are placed in numerical order. Fifty percent of the resulting
concentration values will be above this value and 50% will be below.

•	Mode: The concentration value with the highest frequency.

Once the summary statistics have been prepared, each HAP and combination of HAPs may be
evaluated using graphical techniques to identify anomalous data and outliers. Graphical
techniques permit comparison of concentrations of each HAP to the expected concentrations and

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relative concentrations of other HAPs to inspect for values which stand out. Time series plots,
scatter plots, and fingerprint plots, described below, are valuable tools for validating data.

•	Time series plots: Concentrations are plotted on the y-axis against collection date
(time) on the x-axis. Extreme or anomalous values are immediately identifiable in
individual HAP plots, and may be more powerful when multiple HAPs are plotted
together. HAPs which are typically emitted from the same type of source (i.e.,
benzene and toluene from mobile sources) and from different sources (i.e.,
formaldehyde and PMio nickel) can provide insight on whether concentration
anomalies are realistic to the collected sample or may be an artifact of the collection
or analysis of the sample.

•	Scatter plots: Concentrations of pairs of HAPs are plotted such that each HAP (e.g.,
benzene and toluene) is dedicated to the y-axis or x-axis such that the coordinates of
each plotted point are set by the benzene and toluene concentrations measured during
a given sampling event. The resulting plots generally show points which are clumped
together such that they have a well-defined relationship. Points which lie outside of
the well-defined area are then generally identifiable and can be further investigated.

•	Fingerprint plots: Concentrations of all HAPs within a given class (e.g., VOCs,
carbonyls, etc.) are plotted on the y-axis against the molecular weight, alphabetical
order, or some other consistent order on the x-axis which enable discerning patterns
or identifying anomalies. Fingerprints prepared for each sampling event are
compared and will typically be very similar among events. Plots which show
markedly different patterns may indicate anomalous results. For instance, during a
specific sampling event a HAP may be observed at a concentration much higher or
much lower than expected given the typically observed pattern between concentration
and molecular weight (alphabetical order, etc.), and such is evidence of a spurious
result for this HAP for this sampling event.

Confidence is increased for concentration data which do not appear anomalous when plotted
using these graphical tools. For data which appear to be anomalous, they should be flagged for
follow up and the root cause investigated.

The free Data Analysis and Reporting Tool (DART) software was developed with EPA funding
and incorporates preparation of the graphical displays mentioned above. DART is available at
airnowtech.org at the following URL: http://airnowtech.org/dart/dartwelcome.cfm (all users must
have an account with username and password).

3.3.1.3.15 Reporting of Results toAQS. Each monitoring organization must
prescribe procedures and policies for the reporting of all applicable information generated in the
conduct of the NATTS Program to the EPA AQS database. AQS is a repository of data from
state, local, and tribal agencies as well as federal organizations. The stored data consist of
descriptions of monitoring sites and associated monitoring equipment, reported concentrations of
air pollutants, data flags, and calculated summary and statistical information.

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This section discusses reporting of data to AQS and provides details on the following monitoring
agency requirements. Monitoring agencies must:

•	Report NATTS data to AQS within 180 days from the end of the calendar quarter in
which samples were collected

•	Report concentration data for all Tier I NATTS required HAPs

•	Verify and validate data according to the monitoring agency policies

•	Report QA data (field blanks, trip blanks, collocated, duplicate, replicate analysis, and
lot blanks)

•	Qualify data appropriately in relation to the MDL (EPA plans to implement automatic
flagging for measured concentrations)

•	Add other qualifiers as necessary when data do not meet acceptance criteria

•	Report MDLs with the sample data

•	Report data in appropriate units in standard conditions (except PMio metals)

•	Verify data were input to AQS properly

The concentrations of all HAPs measured during the execution of the NATTS Program must be
input into AQS within 180 days from the end of the calendar quarter during which the applicable
air samples were collected. All data uploaded to AQS must have been previously verified and
validated per the requirements codified in the cognizant monitoring agency's quality system.

Data preparation and entry are also the responsibility of each participating monitoring
organization.

AQS permits entry of qualifier codes consisting of the following four different types:
Informational Only, Null Data Qualifier, QA Qualifier, and Request Exclusion. Request
Exclusion qualifiers do not apply to NATTS data. All uploaded data must be appropriately
qualified, as necessary, in AQS. More than one qualifier may be reported with a concentration
value to provide additional information regarding the applicable concentration result. However,
the null data qualifier flag must not be entered with other flags, as such a flag indicates that no
concentration data are reported. Invalidation of concentration results and the subsequent
assignment of a null qualifier code in AQS require careful consideration and should be consistent
with data review and reporting procedures in the monitoring agency QAPP. Data which do not
meet method QC requirements may still be of use and should be entered with the appropriate QA
qualifier code. AQS qualifier codes appropriate for qualification of NATTS data are listed in
Table 3.3-2 (excludes Null Data Qualifier codes).

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Table 3.3-2. AQS Qualifier Codes Appropriate for NATTS Data Qualification

Qualifier Code

Qualifier Description

Qualifier Type Code

1

Deviation from a CFR/Critical Criteria Requirement

QA

2

Operational Deviation

QA

3

Field Issue

QA

4

Lab Issue

QA

5

Outlier

QA

6

QAPP Issue

QA

7

Below Lowest Calibration Level

QA

CC

Clean Canister Residue

QA

CL

Surrogate Recoveries Outside Control Limits

QA

DI

Sample was diluted for analysis

QA

EH

Estimated; Exceeds Upper Range

QA

FB

Field Blank Value Above Acceptable Limit

QA

FX

Filter Integrity Issue

QA

HT

Sample pick-up hold time exceeded

QA

IC

Chem. Spills & Indust Accidents

INFORM

ID

Cleanup After a Major Disaster

INFORM

IE

Demolition

INFORM

IH

Fireworks

INFORM

II

High Pollen Count

INFORM

IJ

High Winds

INFORM

IK

Infrequent Large Gatherings

INFORM

IM

Prescribed Fire

INFORM

IP

Structural Fire

INFORM

IQ

Terrorist Act

INFORM

IR

Unique Traffic Disruption

INFORM

IS

Volcanic Eruptions

INFORM

IT

Wildfire-U. S.

INFORM

J

Construction

INFORM

LB

Lab blank value above acceptable limit

QA

LJ

Identification Of Analyte Is Acceptable; Reported Value Is An Estimate

QA

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

MX

Matrix Effect

QA

ND

No Value Detected

QA

NS

Influenced by nearby source

QA

QX

Does not meet QC criteria

QA

SQ

Values Between SQL and MDL

QA

ss

Value substituted from secondary monitor

QA

sx

Does Not Meet Siting Criteria

QA

TB

Trip Blank Value Above Acceptable Limit

QA

IT

Transport Temperature is Out of Specs

QA

V

Validated Value

QA

VB

Value below normal; no reason to invalidate

QA

W

Flow Rate Average out of Spec.

QA

The most up-to-date AQS codes and descriptions, including qualifier codes and definitions, are
available at the following URL:

https://www.epa.gov/aqs/aqs-code-list

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Concentrations of HAPs uploaded to AQS must be flagged according to whether they are above
or below the sample quantitation limit (SQL) or method detection limit (MDL) thresholds.
Concentration data less than the laboratory MDL must be flagged with the QA qualifier code
MD, data greater than or equal to the MDL but less than the SQL (3.18-fold the MDL) must be
flagged using the QA qualifier code SQ. All concentration values for qualitatively identified
analytes, even those less than MDL, must be reported to AQS and must not be censored by
substitution of one half the MDL, by replacement with 0, or by any other method. Negative
concentrations must not be translated to zero for reporting purposes. Where qualitative
identification acceptance criteria are not met for a given HAP, its concentration must be reported
as zero and flagged as ND. The convention for reporting concentration data and the associated
QA flags are shown in Table 3.3-3.

Table 3.3-3. Required AQS Quality Assurance Qualifier Flags for Various
Concentrations Compared to a Laboratory's MDL and SQL

Concentration Level

Reported Value

Associated QA Flag

> SQL

measured concentration

no flag

> MDL but < SQL

measured concentration

SQ

< MDL

measured concentration

MD

HAP not qualitatively identified

0

ND

The MDL for a given HAP must be reported to AQS along with the HAP's concentration or
AQS will reject the submission. The reported MDL should ideally be normalized to the
collected air volume for the respective air sample. Normalization of the MDL to the collected air
volume is required when the collected air volume for the sample is greater than 10% different
from the target collected air volume. If the total collected air volume is not within 10% of the
target collected air volume, the monitoring organization should take corrective action which may
involve troubleshooting the sampling unit and verifying calculations. For example, the target
collected air volume for carbonyls sampling at 0.75 L/min is 1.08 m3 and the formaldehyde
MDL is 0.052 |ig/m3 for this target volume. For a total collected sample volume of 0.95 m3, the
collected volume is —12% lower than the target, and requires normalization of the formaldehyde
MDL as follows (MDL increases by the —12% to account of the reduced sample volume):

0.052 ug/m3 • 1.08 m3 = 0.059 |ig/m3
0.95 m3

Reporting units must be consistent across the NATTS network to ensure that data may be
statistically combined with minimal manipulation. HAPs must be reported in the following unit
conventions:

•	VOCs - parts per billion by volume (ppbv)

•	Carbonyls - mass per unit volume (e.g. |ig/m3 or ng/m3)

•	PAHs - mass per unit volume (e.g. |ig/m3 or ng/m3)

•	Metals - mass per unit volume (e.g. |ig/m3 or ng/m3)

All concentrations, with the exception of those for PMio metals, must be reported to AQS
corrected to the standard conditions of 760 mm Hg and 25°C. PMio metals data must minimally

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be reported in local conditions but may also be reported in standard conditions at the discretion
of the monitoring organization. Except for PMio metals, this requires that sites calibrate
sampling unit instruments in standard conditions or that conversion to standard conditions is
performed with average temperature and barometric pressure readings taken during sample
collection.

Sample collection must be performed from midnight to midnight local standard time (no
correction for daylight savings time) which may require adjustment of recorded collection times
generated by sampling unit clocks to ensure values are accurately input into AQS. Clock timers
controlling sampling unit operation must be adjusted so that digital timers are within ±5 minutes
of the reference time (cellular phone, GPS, or similar accurate clock) and mechanical timers
within ±15 minutes.

NATTS agencies are required to report data for each of the Tier I analytes listed in Table 1.2-1
and are also encouraged to report data collected for Tier II analytes. Careful attention must be
paid to coding of data uploaded to AQS to ensure that the five-digit parameter code is accurate
and that the associated units comply with those listed above.

NATTS sites may have numerous monitors collecting data for programs besides NATTS. Each
individual monitor of a given type (VOCs, carbonyls, PMio metals, and PAHs) and duplicate
samples collected from a single monitor are to be assigned a parameter occurrence code (POC)
by the state, local, or tribal agency (SLT). There is no guidance on how POCs are assigned by
SLTs and a survey of NATTS sites indicates that several monitors can be assigned the same
POC. Data uploaded to AQS indicate the assigned POC, but the POC does not indicate whether
the associated data are from a primary monitor, duplicate sample from the primary monitor,
duplicate sample from a duplicate monitor, or collocated sample. Due to the ambiguous nature
of POC assignment, each NATTS agency must prescribe and maintain a legend of POCs for
minimally each of the four monitor types required for NATTS in the annual network plan (ANP)
or other controlled document. The recommended convention is to assign a lower POC to the
primary monitor and a higher POC to the duplicate and/or collocated monitor.

QA data including, but not limited to, field QA samples such as field and trip blanks and
collocated and duplicate test samples, laboratory QA results from replicate analyses (as required
by the workplan), and lot blanks must be reported to AQS. AQS also accepts laboratory blanks
and laboratories are not required to, but may, report method blank data to AQS. Guidance for
reporting QA samples (blanks and precision samples - collocated, duplicate, and replicate
samples) is included in Appendix B.

Prior to submission of data to AQS, all data must be reviewed to ensure the parameter code,
POC, unit code, method code, and any associated qualifier or null codes are properly assigned. In
addition, the reported parameters should specify the NATTS network affiliation.

AQS instructions for data upload are described in the AQS User Guide and additional AQS
manuals and guides available at the following URL:

http://www3.epa.gov/ttn/airs/airsaqs/manuals/

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Additional assistance is available by calling the AQS help line at (866) 411-4372.

3.3.1.3.15.1 Corrections to Data Uploaded to A QS

If it discovered during data validation, as a result of corrective action, or through other means
that erroneous data have been reported to AQS, the erroneous data must be deleted, and the
corrected data uploaded to AQS. EPA Region staff must be notified when the erroneous data are
discovered and SLTs must notify the EPA Region to correct the records in AQS when changes
are needed to large swaths of data (e.g. a calendar quarter) or data from previous calendar years
are to be altered. Monitoring agencies should also notify data users which may have provided
notification of data query (as is done for AQS data pulls for conducting the NATTS assessments
and data analysis for preparing the NAT A), as the updated data may impact the data user's
analysis outcomes.

3.3.1.3.16	Records Retention and Archival, and Data Backup. All records required
to reconstruct activities to generate the concentration data for NATTS Program samples must be
retained for a minimum of six years. The basis for the six-year retention period is that this
covers the two successive three-year periods over which trends in HAP concentrations are
determined. If problematic or anomalous data are observed during trends analysis, the archived
records will be available for review to investigate the suspicious data. Quality system documents
such as QMPs, QAPPs, and SOPs, sample collection and analysis records, maintenance logs,
reagent logs, etc. must also be retained for at least six years. Requirements for records retention,
including electronic records, must be prescribed in the QMP, agency NATTS QAPP, or similar
controlled policy document.

Electronic data must also be retained for a minimum of six years. Data generated by sampling
and analysis instruments, including all QA/QC data, as well as data stored in databases and/or in
a LIMS must be backed up on a periodic basis as defined in an applicable quality system
document such as the QAPP. Archived electronic data must be stored in a manner such that they
are protected from inadvertent alteration. Additionally, monitoring agencies must maintain
accessibility to the archived data which may include maintaining legacy software systems or
computers or may involve conversion of the data to a format which is compatible with current
computers and software systems. Monitoring agencies should consider the compatibility of the
archived data when upgrading or replacing computer systems and software to ensure the
archived data remain accessible.

3.3.1.3.17	Safety. While not strictly a quality system element, safety is integral in
ensuring the continued collection of quality data. Each monitoring organization must codify
appropriate safety requirements and procedures within the NATTS QAPP or similar controlled
policy document. For monitoring organizations with existing safety plans or programs, these
may be referenced within the QAPP. Safety plans should include information regarding safety
equipment, inspection frequency of safety equipment, and safety training frequency.

3.3.2 Standard Operating Procedures. Each monitoring organization conducting
NATTS Program work must develop and maintain SOPs, however named, which must describe
in detail the procedures for performing various activities needed to execute air sampling, sample

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analysis, data reduction, and data reporting, among others, for the NATTS program. It is not
acceptable to simply cite a method document (e.g., EPA Compendium Method TO-11 A) or
instrument manual as the SOP, although these documents may serve as the basis for an SOP and
may be referenced in the SOP. Instrument manuals and the compendium methods do not include
sufficient detail on the specific procedures and/or equipment information necessary to perform
the procedures and generally offer several different procedures or conventions for performing
activities or operating equipment. SOPs must reflect current practice and the work performed
must be in accordance with SOPs. SOPs must be written with sufficient detail to enable an
individual with limited experience with or knowledge of the procedure, but with basic
understanding of the procedure, to successfully perform the procedure when unsupervised.
Production, review, revision, distribution, and retirement of SOPs must conform to the
requirements prescribed by the monitoring organization's document control system as discussed
in Section 3.3.1.3.5.

SOPs can be developed in many formats but should minimally contain information regarding the
following, where applicable:

•	Title (e.g., Collection of Ambient VOCs Samples in Stainless Steel Canisters)

•	Scope and Objectives (e.g., covers sample collection but not analysis)

•	References (e.g., EPA Compendium Method TO-11 A)

•	Definitions and Abbreviations

•	Procedures - instructions (usually step-by-step) for performing activities within the
scope of the SOP including information on required materials, reagents, standards,
and instruments; sample preparation; instrument calibration and analysis, and data
analysis and reporting procedures, among other information, as required

•	Interferences

•	Calculations

•	Quality control acceptance criteria with associated corrective actions

•	Safety information

•	Revision history

The author of each SOP must be an individual knowledgeable with the activity and the
organization's internal structure who has the responsibility for the veracity and defensibility of
the document's technical content. A team approach may be followed to develop the SOP,
especially for multi-tasked processes where experience of a number of individuals is critical to
the procedure. SOPs must be approved in accordance with Section 3.3.1.3.5 of this TAD and
must be revised when they no longer reflect current practices. At a minimum, SOPs are to be
reviewed by the author and a member of QA to determine if revisions are needed and these
reviews and revisions must be documented. The frequency for review is recommended to be
annually, but must not exceed three years, and the period must be prescribed in the monitoring
agency's NATTS QAPP, QMP, or similar controlled document. Once a new version is effective,
the previous version must be retired and may not be referenced for conducting procedures.

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3.4 References

1.	Environmental Protection Agency. (September 2005). Quality Assurance Guidance
Document. Quality Management Plan for the National Air Toxics Trends Stations. (EPA
Publication No. EPA/454/R-02-006). Office of Air Quality Planning and Standards.
Emission, Monitoring, and Analysis Division. Research Triangle Park, North Carolina.
Available at (accessed October 19, 2016):
https://www3.epa.gov/ttnamtil/files/ambient/airtox/nattsqmp.pdf

2.	Environmental Protection Agency. (March 2001). EPA Requirements for Quality Assurance
Project Plans. EPA QA/R-5 (EPA Publication No. EPA/240/B-01-003). Office of
Environmental Information, Washington, DC. Available at (accessed October 19, 2016):
https://www.epa.gov/sites/production/files/2016-06/documents/r5-final O.pdf

3.	Environmental Protection Agency. (December 2002). Guidance for Quality Assurance
Project Plans. EPA QA/G-5 (EPA Publication No. EPA/240/R-02-009). Office of
Environmental Information, Washington, DC. Available at (accessed October 19, 2016):
https://www.epa.gov/sites/production/files/2015-06/documents/g5-final.pdf

4.	Environmental Protection Agency. (May 2013). Quality Assurance Handbook for Air
Pollution Measurement Systems, Volume II. (EPA Publication No. EPA-454/B-13-003).
Office of Air Quality Planning and Standards, RTP, NC. Available at (accessed October 19,
2016): https://www3.epa.gov/ttnamtil/files/ambient/pm25/qa/OA-Handbook-Vol-II.pdf

5.	Environmental Protection Agency. (April 20, 2016). Technical Note - Use of Electronic
Logbooks for Ambient Air Monitoring. Office of Air Quality Planning and Standards, RTP,
NC. Available at (accessed October 19, 2016):

https://www3.epa.gov/ttnamtil/files/policv/Electronic Logbook Final %204 20 16.pdf

6.	Environmental Protection Agency. (November 2002). Guidance on Environmental Data
Verification and Data Validation. EPA QA/G-8 (EPA Publication No. EPA/240/R-02-004).
Office of Environmental Information, Washington, DC. Available at (accessed October 19,
2016): https://www.epa.gov/sites/production/files/2015-06/documents/g8-final.pdf

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4.0: COLLECTION AND ANALYSIS METHODS

4.1	Method Detection Limits

The MDL as prescribed in 40 CFR Part 136 Appendix B was initially developed and applied to
wastewater analyses.1 Since then, this procedure has been applied to a variety of other matrices
and analysis methods to approximate the lowest concentration (or amount) of analyte that can be
reported with 99% confidence that the actual concentration (or amount) is greater than zero. As
can be seen below in Figure 4.1-1, the Gaussian curve represents analysis of contamination-free
method (matrix) blanks and the distribution of their concentration values around zero. The small
area of the blank values to the right of the MDL value (indicated by the vertical dashed line)
represent the 1% of values which would be considered false positives.

Figure 4.1-1. Graphical Representation of the MDL and Relationship to a Series of Blank
Measurements in the Absence of Background Contamination

(Credit: Reference 2 as adaptedfrom Reference 3)

In practical terms, this MDL procedure provides a conservative detectability estimate and aims to
ensure that there is a 1% false positive rate - incorrectly reporting the presence of an analyte
when it is in fact absent - at the determined MDL concentration. In many cases the analyte will
be qualitatively identified (per, for example, the criteria given for the various analytical methods
in Section 4.2) at concentrations below the MDL with a signal distinguishable from instrumental

48


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noise. That is to say, the MDL procedure is not protective of false negatives, which is
incorrectly concluding that the analyte is absent when it is in fact present; in fact, 50% of the
time the analyte present at the MDL concentration will be measured at less than the MDL (the
compound will not be 'detected').4 This can be seen in Figure 4.1-2 - the solid Gaussian curve
represents a series of measurements at the MDL concentration. The measurements in the shaded
portion of the curve to the left of the MDL value are false negatives or values measured at less
than the MDL. Such values may be properly qualitatively identified despite being less than the
MDL value. Therefore, if an analyte is measured at the MDL concentration, the analyte is
present 99% of the time; however, for analytes measured at or less than the MDL concentration,
50% of the time the analyte may also be present.

Figure 4.1-2. Graphical Representation of the MDL and Relationship to a Series of

Measurements at the MDL Value

(Credit: Reference 2 as adaptedfrom Reference 3)

•	99% of the results measured > MDL are in fact greater than zero (there is a 1% false
positive rate, or chance that such measurements are not actually greater than zero)

•	50% of actual concentrations at the MDL will be reported as > MDL

•	50% of actual concentrations at the MDL will be reported as < MDL (they will be
false negatives) even though they may still be qualitatively identified and may still in
fact be valid identifications

sxt 50% chance of
<	~] false negative

~

l

0 MDL
Concentration

In summary:

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The MDL as described in 40 CFR Part 136 App B and in Reference 1 is a statistical estimate of
the lowest concentration at which there is a 99% chance that the concentration is greater than
zero. The MDL procedure is not simply a characterization of the noise of the instrument nor is it
a known level of accuracy ensured at the MDL concentration. The MDL is also not an estimate
of the precision or variability of the method. Moreover, the MDL is not simply a representation
of the analysis instrument sensitivity, also known as the instrument detection limit (IDL), as the
latter does not incorporate the potential effect of the matrix for samples taken through the
preparation process (such as extraction or digestion). The IDL establishes the lowest
concentration that may be measured with a defined confidence by the instrument, and knowing
the IDL is particularly helpful when troubleshooting the MDL process; however, the IDL does
not, and must not, replace the MDL.

There are known limitations to the 40 CFR Part 136 Appendix B MDL procedure, not the least
of which is that it is a "compromise between statistical respectability and requirements of cost
and time."2'3 More specifically for the NATTS program, the MDL procedure prescribed in this
TAD of spiking sample collection media in the laboratory does not explicitly take into account
the functionality of all portions of the method from collection through analysis. In particular,
conducting an MDL study through the probe is impractical for gases and not currently possible
for PMio metals and PAHs. To the extent feasible the impact of the sampling process on
detectability is minimized by strongly recommending that bias checks (zero and known standard
checks) are performed for carbonyls and VOCs field samplers.

The MDL concentration, as defined in 40 CFR Part 136 Appendix B, is determined statistically
by preparing and analyzing minimally seven separate aliquots of a standard spike prepared in the
method matrix. All portions of the method and matrix are to be included in the preparation and
analysis such that any matrix effects and preparation variability are taken into account. The
MDL procedure is an iterative process and, to be meaningful, the MDL procedure must be
performed as prescribed.

The MDL procedure adopted for the NATTSs program, which is described in detail in Section
4.1.3.1, builds upon the 40 CFR Part 136 Appendix B by adding some aspects of the proposed
method update rule (MUR).5 The MUR recognizes that the CFR procedure assumes that blank
values are centered around a concentration of zero and does not take into account the potential
for background contamination to be present in the sample collection media. If there is a
consistent background level of contamination on the sample collection media, as is typical for
carbonyls on DNPH cartridge media and metals elements on QFF media, measured blank values
will not be centered around zero; rather, they will be centered on the mean blank value. In such
cases the MDL must be defined as the value that is statistically significantly greater than the
blank value and the 40 CFR Part 136 Appendix B procedure will underestimate the MDL. This
occurs since the resulting standard deviation of the MDL replicates (and thus the calculated
MDL concentration) prepared in the presence of background contamination will not be different
than if there was no discernable background (standard deviation simply evaluates the difference
in the spread of the values, not the magnitude of the individual values). The MUR takes into
account the media background and adjusts for matrix blanks levels that are not centered around
zero.

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The MDL procedure prescribed in Section 4.1.3.1 adds few additional steps than those required
in the 40 CFR Part 136 Appendix B procedure. The net effect is that if there is little or no
contribution of background contamination on the sampling media, the MDL will be no different
than that determined previously by 40 CFR Part 136 Appendix B. If the sampling media (or
other aspects of the standard preparation of instrumental analysis procedures) contributes blank
contamination, the determined MDL will incorporate this average blank background
concentration. In all cases, the new MDL will be the concentration at which there is a 99%
chance that the actual reported concentration is statistically greater than the mean levels found in
blanks.

The DQ FAC Single Laboratory Procedure v 2.4 described in Section 4.1.3.2 is a similar
procedure to determine the MDL which takes into account the media background and other
potential background contributions. This procedure is more involved and is better suited to
laboratories with high sample throughput; however, laboratories may opt to determine MDLs via
this procedure.

The MUR-modified 40 CFR Part 136 Appendix B method still has a 50% false negative rate,
which is generally recognized as unacceptable for the purposes of environmental monitoring.2'3
As a result, concentrations measured at less than the MDL, so long as the qualitative
identification criteria have been met, are valid and necessary for trends analysis and substituting
or censoring concentrations measured at less than MDL is not permitted. EPA recognizes that
many laboratories are not comfortable reporting concentrations measured less than the MDL as
these concentrations are outside of the calibrated range of the instrument and are associated with
an unknown and potentially large uncertainty. However, actual values reported at less than the
MDL are more valuable from a data analyst's standpoint and far superior than censored or
substituted values. Addition of qualifiers as prescribed in Section 3.3.1.3.15 and in Table 3.3-1
indicates when values are near, at, and below detection limits and are therefore associated with
larger uncertainties.

4.1.1	Frequency of Method Detection Limit Determination. MDLs must be determined
minimally annually or when changes to the instrument or preparation procedure result in
significant changes to the sensitivity of the instrument and/or procedure. Examples of situations
where redetermination of the MDL is required include, but are not limited to:

-	Detector replacement

-	Replacement of the entire analytical instrument

-	Replacement of a large (e.g. > 50%) portion of an agency's canister fleet
Changing the cleaning procedure for sample collection media or labware which
results in a marked reduction in contamination levels

4.1.2	MDL Measurement Quality Objectives. In order to ensure that measurements of
air toxics in ambient air are sufficiently sensitive to assess trends in concentrations which may
result in health effects due to chronic exposures, a minimum required method sensitivity, or
MDL MQO, has been established for each of the core NATTS analytes. Though few changes
have been made to MDL MQOs since the beginning of the NATTS Program, as new toxicology
data are available, MDL MQOs may be adjusted. The annual NATTS network workplan

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template includes the most up-to-date MDL MQO for each core analyte. Laboratories must meet
(be equal to or less than) the MDL MQO listed in the most recent NATTS workplan.

The NATTS MDL MQOs are based on concentrations to which chronic exposures may result in
unacceptable health risks. While analytical methods prescribed in this TAD are capable of
meeting the MDL MQOs, MDLs may be elevated above the MDL MQOs due to background
contamination. The convention listed in 40 CFR Part 136 Appendix B accounted for
instrumental limitations during the determination of MDLs but did not consider the background
or interferences, which, in certain instances, may be several-fold higher than the MDL MQO. As
a result, the MUR MDL procedure has been adopted by the NATTS program to provide a more
realistic threshold of detection given the limitations of the method and background
concentrations attributable to the collection media and analytical instrumentation. The decision
to include portions of the MUR for MDL determination for the NATTS Program was carefully
weighed by examining historical data from the NATTS network and comparing typical media
background levels to evaluate the percentage of data which would additionally be coded as less
than the laboratory MDL. The results of the examination indicated that a minimum additional
amount of concentration data would be marked as less than the MDL when reported to AQS.6

NATTS Tier I core analytes and the concentrations as of March 2015 that correspond to 10"6
cancer risk levels, to noncancer risk hazard quotients (HQs) of 0.1, and to MDL MQOs are listed
in Table 4.1-1. Refer to the latest NATTS workplan template for the most up-to-date values.

Table 4.1-1. Concentrations of the NATTS Core Analytes Corresponding to
a 10"6 Cancer Risk, a Noncancer Risk at a HQ of 0.1, and to the MDL MQO

Core Analyte

Cancer Risk 10 6
(ug/m3)

Noncancer Risk at
HQ = 0.1

(ug/m3)

MDL MQO

(Ug/m3)

(ppbv)

Acrolein

-

0.0020

0.090

0.039

Benzene

0.13

3.0

0.13

0.041

1,3-Butadiene

0.030

0.20

0.10

0.050

Carbon tetrachloride

0.170

19

0.17

0.027

Chloroform

-

9.8

0.50

0.10

T etrachloroethylene

3.8

4.0

0.17

0.025

T richloroethylene

0.21

0.20

0.20

0.037

Vinyl chloride

0.11

10

0.11

0.043

Acetaldehyde

0.45

0.90

0.45

0.25

Formaldehyde

0.080

0.080

0.080

0.065

Benzo(a)pyrene

0.00091

0.30

0.00091

NA

Naphthalene

0.029

0.029

0.029

NA

Arsenic (PMio)

0.00023

0.0030

0.00023

NA

Beryllium (PMio)

0.00042

0.0020

0.00042

NA

Cadmium (PMio)

0.00056

0.0020

0.00056

NA

Lead (PMio)

-

0.015

0.015

NA

Manganese (PMio)

-

0.0050

0.0050

NA

Nickel (PMio)

0.0021

0.00081

0.0021

NA

4.1.3 Determining MDLs. MDLs may be determined via one of two procedures. The first
procedure in Section 4.1.3.1 is adopted from updates pending at the time this document was
revised, an update to the MDL procedure described in 40 CFR Part 136 Appendix B, the MUR. 5

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The second procedure in Section 4.1.3.2 is to determine MDLs via the procedure described in the
December 2007 Report of the Federal Advisory Committee on Detection and Quantitation
Approaches and Uses in Clean Water Act Programs.1 Both methods incorporate media blank
background levels in the determination of analyte-specific MDLs.

MDL studies must be determined for each instrument employed to analyze samples for the
NATTS Program. For laboratories utilizing multiple instruments for a given method, MDL
studies must be performed for each instrument (the same samples or extracts may be used for all
instruments). In instances where multiple instruments are employed for reporting NATTS
Program results for the same analyte class (e.g., two or more HPLC-ultraviolet [UV]
instruments), there are two conventions for how to report the MDLs. The preferred convention
is to maintain an MDL for each instrument and report the respective MDL from the instrument
on which a given sample was analyzed. Alternatively, the most conservative (highest) MDL
from the multiple instruments can be reported - though this may not reflect the MDL associated
with the sample analysis. It is not appropriate to average the MDL values for reporting.

4.1.3.1 MDLs via 40 CFR Part 136 Appendix B -Method Update Rule. The MDL

procedure described in this section is adopted from the procedure as given in 40 CFR Part 136
Appendix B with several changes, based on those proposed in the CFR on February 19, 2015, to
explicitly include in the MDL the background (i.e. contamination) contribution of the sample
collection media and to incorporate temporal variability in laboratory preparation and instrument
performance.5 The preliminary work on the MUR identified measuring metals on air filters as an
example of where the 40 CFR Part 136 Appendix B method did not generate a realistic
concentrations level for the MDL value due to the elevated background contamination on the
filter media.

A minimum of seven spiked samples and seven method blanks must be prepared in matrix over
the course of a minimum of three different preparation batches. A batch is defined as a group of
samples prepared on one day, therefore three different preparation batches would require
preparation on three separate days. To properly characterize the variability in preparation, the
dates of preparation should be spread out such that they are not consecutive. Analysis of these
blanks and spikes must similarly be conducted over the course of three different analysis batches
where each sample is only analyzed once. Again, a batch is defined as a group of samples
analyzed on one day. Spreading the preparation and analysis over multiple preparation batches
and across analysis days is intended to incorporate the variability of both sample preparation and
analytical instrumentation that occurs over time. It is preferable to determine an MDL that is
representative of the laboratory's capability than to have an unrealistically low MDL determined
by selecting the best sampling media (i.e. canisters) and attempting to generate the lowest MDL
value possible. Two MDL values are calculated, one MDL for the spiked samples according to
the convention in 40 CFR Part 136 Appendix B (MDLsp) and one MDL for the method blanks
which includes the media background contribution (MDLb).

The first step is to select a spiking level for preparing the MDL spiked samples. If too low of a
spiking level is chosen, the analyte may not be reliably detected. If too high of a spiking level is
chosen, the variability of the method near the actual limits of detection may not be properly

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characterized. An appropriate spiking level may be selected by considering the following (in
order of importance):

1.	The concentration at which the instrument signal to noise ratio is three- to five-fold
for the analyte.

2.	The concentration at which qualitative identification criteria for the analyte are lost
(note that this will be approximately the concentration determined from the MDL
process absent of blank contamination).

3.	Analysis of a suite of blank samples - calculate the standard deviation of the
measured concentration and multiply by 3.

4.	Previously acceptable MDL studies and related experience.

Note that the MDL spiking level should not be within the calibration curve; rather, the MDL
spiking level should be less than the lowest calibration standard in order to best approximate the
MDL. Concentrations within the calibration curve are required to meet precision and bias
acceptance criteria and are of a high enough concentration that qualitative identification is
certain.

The second step is to prepare the seven or more separate spiked samples (at the level determined
in the first step) and seven or more method blank samples. In order to best mimic field-collected
samples, each spiked and blank sample must include, to the extent feasible, all portions of the
sample matrix and be subjected to the same procedures performed to process field samples in
preparation for analysis. Prepare method blanks and spiked samples over the course of three
different preparation batches preferably on non-consecutive days.

An efficient method to determine the MDL following this convention is to prepare and analyze
an MDL sample on a continuous basis with typical sample batches prepared over the course of
several weeks or months. In this scenario, one (or up to three) spikes would be prepared at the
time of sample batch preparation and after seven or more data points have been collected for the
MDL spikes and for the associated method blanks (which are already required with each
analytical batch), the MDL could be calculated. This would alleviate the need to dedicate a
significant contiguous block of time to preparing and analyzing MDL samples and method
blanks. The following must be taken into consideration during preparation of the MDL samples:

1.	Spiked samples must be prepared in matrix (DNPH cartridge, canister, PAH cartridge
with quartz fiber filter, or metals Teflon® filter or QFF strip).

2.	Selection of media should include as much variety as possible (e.g., different canister
manufacturers or individual DNPH cartridges selected from different boxes or lots) to
best characterize the variability of the method attributable to the use of media
representative of field-collected samples.

3.	Blank media which do not meet cleanliness criteria for a given analyte should trigger
root cause analysis to determine the source of the contamination and should not be
used to determine the method blank portion of the MDL. Cleanliness criteria are
given in Tables 4.2-3, 4.3-4, 4.4-2, and 4.5-3 for VOCs, carbonyls, metals, and PAHs

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collection media, respectively. Of particular concern are background levels of
contaminants in canisters and on PUF/XAD cartridges resulting from insufficient
cleaning. For DNPH cartridges, media background levels should meet the criteria
specified in Method TO-11A (duplicated in Table 4.3-2). Metals quartz fiber filter
media typically show elevated background levels of certain elements such as
chromium, nickel, manganese, and lead. It is not possible to decrease the background
levels of these three elements on QFFs, though EPA is working with manufacturers to
reduce the amount of background contamination on the filter media.

The third step is to analyze the samples against a valid calibration curve. QC criteria for the
analytical sequences must be met (blanks, laboratory control sample [LCS], calibration checks,
etc.). Analyze the samples over the course of minimally three different analytical batches.

1.	Perform all MDL calculations in the final units applicable to the method.

2.	Calculate the MDL of the spiked samples, MDLsp:

a.	Following acquisition of the concentration data for each of the seven or more
spiked samples, calculate the standard deviation of the calculated
concentrations for the spiked samples (%,). Include all replicates unless a
technically justified reason can be cited (faulty injection, unacceptably low
internal standard response, etc.), or if a result can be statistically excluded as
an outlier.

b.	Calculate the MDL for the spiked samples (MDLsp) by multiplying .vsp by the
one-sided student's T value at 99% confidence corresponding to the number
of spikes analyzed according to Table 4.1-2. Other values of T for additional
samples (n > 13) may be found in standard statistical tables.

MDLsp = -Vsp' T

Table 4.1-2. One-sided Student's T Values at 99% Confidence Interval

number of MDL
samples (n)

degrees of
freedom
v (n-1)

student's T
value

7

6

3.143

8

7

2.998

9

8

2.896

10

9

2.821

11

10

2.764

12

11

2.718

13

12

2.681

c. Compare the resulting calculated MDLsp value to the nominal spiked amount.
The nominal spiked level must be greater than MDLsp and less than 10-fold
MDLsp, otherwise the determination of MDLsp must be repeated with an
adjusted spiking concentration. For MDLsp values greater than the nominal
spike level, the MDL spiking level should be adjusted higher by

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approximately two or three-fold. For nominal spike levels which are greater
than the 10-fold the MDLsp, the MDL spiking level should be adjusted lower
by approximately two or three-fold.

3.	Calculate the MDL of the method blanks, MDLb:

a.	If none of the method blanks provide a numerical result for the analyte, the
MDLb does not apply. A numerical result includes both positive and negative
results for analytes which are positively identified. Non-numeric values such
as "ND" would result when the analyte is not positively identified. Only
method blanks that meet the specified qualitative criteria for identification
(signal to noise, qualifier ion presence, etc.) are to be given a numerical result.

b.	If the method blank pool includes a combination of non-numeric (ND) and
numeric values, set the MDLb to equal the highest of the method blank results.
If more than 100 method blank results are available for the analyte, set the
MDLb to the level that is no less than the 99th percentile of the method blanks.
In other words, for n method blanks where n > 100, rank order the
concentrations. The value of the 99th percentile concentration (n 0.99) is the
MDLb. For example, to determine MDLb from a set of 129 method blanks
where the highest ranked method blank concentrations are ... 1.10, 1.15, 1.62,
1.63, and 2.16, the 99th percentile concentration is the 128th value (129 0.99 =
127.7, which rounds to 128), or 1.63. Alternatively, spreadsheet programs
may be employed to interpolate the MDLb more precisely.

c.	If all concentration values for the method blank pool are numeric values,
calculate the MDLb as follows:

i.	Calculate the average concentration of the method blanks (xb).

ii.	Calculate the standard deviation of the method blank concentrations, 5b.

iii.	Multiply 5b by the one-sided student's T value at 99% confidence
corresponding to the number of blanks analyzed according to Table 4.1-2.
Other values of T for additional samples (n > 13) may be found in
standard statistical tables.

iv.	Calculate MDLb as the sum of Xb and the product of 5b and the associated
student's T value:

MDLb = xb+5b-T

4.	Compare MDLsp and MDLb. The higher of the two values is reported as the
laboratory MDL for the given analyte.

5.	If the MDL is determined as the MDLsp, laboratories should perform verification of
the determined MDL by:

a. Preparing one or more spiked samples at one to five-fold the determined MDL
and analyze the sample per the method to ensure the determined MDL is
reasonable. Recall that at the MDLsp concentration there is a 50% chance that the

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analyte will not be detected; however, the analyte should be detected at two- to
five-fold the determined MDL.

b.	Developing reasonable acceptance criteria for the MDL verification. For
example, an MDL verification that recovers 2% of the nominal amount is not
realistic, nor is one that recovers 300%. An appropriate starting point for
acceptance limits is to double or triple the acceptance window prescribed by the
method for the given analyte. For example, TO-15 normally permits benzene
LCS recoveries to be 70 to 130% (± 30% error), therefore doubling the MDL
verification acceptance limits would permit 40 to 160% recovery. Note that for
collection media with a significant background contamination, blank subtraction
may be necessary to evaluate the recovery of the MDL verification sample.

c.	Examining the MDL procedure for reasonableness if the verification sample is
outside of the laboratory-defined acceptance criteria. Such an examination might
include investigating the signal-to-noise ratio of the analyte response in the spiked
samples, comparing the MDL to existing instrument detection limits (if known -
discussed below), and relying on analyst experience and expertise to evaluate the
MDL procedure and select a different spiking level. The MDL study should then
be repeated with a different spiking level.

Troubleshooting may include determination of the instrument detection limit
(IDL) to evaluate whether the poor or elevated recovery is due to the instrument.
The IDL is determined by analyzing seven or more aliquots of a standard,
calculating the standard deviation of the measurements, and multiplying the
standard deviation by the appropriate student's T value. IDL samples are to be
prepared in the same matrix as calibration standards and are not processed
through sample collection media as is done for MDL spiked samples (e.g. for
TO-11A and TO-13A, the standard would be in solvent, for TO-15 the standard
would be typically in a single canister, and for 103.5 metals analysis the standard
would be prepared in the aqueous acid matrix).

Example calculation:

A laboratory is determining the MDL for formaldehyde by TO-11A by spiking commercially-
prepared DNPH cartridges. The analyst spiked eight cartridges with formaldehyde-DNPH at
0.030 |ig/cartridge (in terms of the amount of the free formaldehyde) over three separate
preparation batches. These eight spiked cartridges and eight additional method blank cartridges
were extracted over three different dates. Results were analyzed over three different analysis
batches per Method TO-11A yielding the following results:

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Method

Cartridge
Number

Preparation Batch
and Date

Analysis Batch
and Date

Spikes
(jig/cartridge)

Blanks
(jig/cartridge)

1

A - September 12, 2015

QR9 - September 13

0.1685

0.1412

2

A - September 12, 2015

QR9 - September 13

0.1651

0.1399

3

A - September 12, 2015

QR9 - September 13

0.1701

0.1402

4

B - September 19, 2015

QR12 - September 21

0.1673

0.1405

5

B - September 19, 2015

QR12 - September 21

0.1692

0.1408

6

C - September 28, 2015

QR16 - September 29

0.1686

0.1403

7

C - September 28, 2015

QR16 - September 29

0.1705

0.1402

8

C - September 28, 2015

QR16 - September 29

0.1696

0.1410

The average (x) and standard deviation (5) of measured formaldehyde mass were determined for
both the spikes and the method blanks (all in units of |ig/cartridge):

xsp = 0.1686
Xb = 0.1405
sSp = 0.0017
5b = 0.0004

To calculate the MDLsp, the standard deviation of the spiked aliquots is multiplied by the
associated student's T. The student's T value for eight aliquots is 2.998, corresponding to seven
degrees of freedom (8-1=7):

MDLsp = 0.0017 |ig/cartridge • 2.998

= 0.0051 |ig/cartridge

The MDLsp is subsequently verified to be less than the spike level, and the spike level is
confirmed to be less than 10-fold the MDLsp:

MDLsp < spike level < 10-fold MDLsp

0.0051 |ig/cartridge < 0.030 |ig/cartridge < 0.051 |ig/cartridge

Observe that the determinedMDLsp is less than the background level of formaldehyde (xb =
0.1405 ng/cartridge) on the DNPH cartridge media; such indicates that the MDLsp is biased low
and that background levels must be taken into account.

To calculate the MDLb, the standard deviation of the blank measurements is multiplied by the
associated student's T and this product is added to the average blank value, Xb:

MDLb = 0.0004 |ig/cartridge • 2.998 + 0.1405 |ig/cartridge

= 0.1417 |ig/cartridge

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The MDLsp and MDLb are compared to determine which is greater, and the greater of the two
values is reported as the laboratory MDL for the specific analyte.

0.1417 |ig/cartridge > 0.0051 |ig/cartridge

In this case, the formaldehyde MDLb of 0.1417 |ig/cartridge is greater than the MDLsp of 0.0051
|ig/cartridge, and is reported as the laboratory MDL for formaldehyde as measured by Method
TO-11A.

4.1.3.2 MDLs via DQ FAC Single Laboratory Procedure v 2.4 J The MDL procedure
described in this section involves examination and manipulation of historical method blank data
to derive the MDL. This procedure must be performed only with method blanks that include all
media contributions and processing procedure elements. Also, method blank analyses which
were the result of laboratory preparation or analysis errors must not be included.

The DQ FAC procedure requires that historical method blank data be examined to verify that at
least 50% of the results are a numerical value (zero, positive concentration, or negative
concentration). If fewer than 50% of the method blank values are numerical, or, stated another
way, if 50% or more of the values are reported as nondetects, use the procedure described above
in Section 4.1.3.1. Once it is determined that the DQ FAC method is applicable, assign method
blanks without a numerical value (i.e., non-detect) as zero. Calculate the standard deviation of
the included method blanks. A minimum of seven method blanks meeting these criteria is
required within the calendar year. If results of more than seven method blanks within the year
meet these criteria, all such method blank data should be included in the evaluation.

Calculate the MDL as follows:

MDL = xmb + s K

where:

xmb = mean result of the method blanks
5 = standard deviation of the method blanks

K = is a multiplier for a tolerance limit based on the 99th percentile for n-1
degrees of freedom according to Table 4.1-3.

Note that if ocmb is a negative value, substitute zero for this value.

If 5%> or more of the blank results are greater than the MDL, raise the MDL as follows:

1.	To the highest method blank result if less than 30 method blank results are available.

2.	To the next to highest method blank result if 30 to 100 method blank results are
available.

3.	To the 99th percentile, or the level exceeded by 1% of all method blank results, if there
are more than 100 method blank results available.

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Only method blanks that meet the specified qualitative criteria for identification (signal to noise,
qualifier ion presence, etc.) are to be given a numerical result.

Table 4.1-3. K-values for n Replicates

n

K

n

K

n

K

n

K

7

6.101

30

3.317

53

2.993

76

2.855

8

5.529

31

3.295

54

2.977

77

2.851

9

5.127

32

3.273

55

2.970

78

2.847

10

4.829

33

3.253

56

2.963

79

2.843

11

4.599

34

3.234

57

2.956

80

2.839

12

4.415

35

3.216

58

2.949

81

2.836

13

4.264

36

3.199

59

2.943

82

2.832

14

4.138

37

3.182

60

2.936

83

2.828

15

4.031

38

3.167

61

2.930

84

2.825

16

3.939

39

3.152

62

2.924

85

2.821

17

3.859

40

3.138

63

2.919

86

2.818

18

3.789

41

3.125

64

2.913

87

2.815

19

3.726

42

3.112

65

2.907

88

2.811

20

3.670

43

3.100

66

2.902

89

2.808

21

3.619

44

3.088

67

2.897

90

2.805

22

3.573

45

3.066

68

2.892

91

2.802

23

3.532

46

3.055

69

2.887

92

2.799

24

3.494

47

3.045

70

2.882

93

2.796

25

3.458

48

3.036

71

2.877

94

2.793

26

3.426

49

3.027

72

2.873

95

2.790

27

3.396

50

3.018

73

2.868

96

2.787

28

3.368

51

3.009

74

2.864

97

2.784

29

3.342

52

3.001

75

2.860

98

2.782

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4.1.4

References

1.	Glaser, J. A., Foerst, D. L., McKee, G. D., Quave, S. A., & Budde, W. L. (1981). Trace
analyses for wastewaters. Environmental Science and Technology, 75(12), 1426-1435.

2.	Boyd, R. K., Basic, C., & Bethem, R. A. (2008). Trace Quantitative Analysis by Mass
Spectrometry. West Sussex, England: John Wiley and Sons.

3.	Childress, C. J. O., Foreman, W. T., Connor, B. F., & Maloney, T. J. (1999). New Reporting
Procedures Based on Long-Term Method Detection Levels and Some Considerations for
Interpretations of Water-Quality Data Provided by the U.S. Geological Survey National
Water Quality Laboratory - Open-File Report 99-193. US Geological Survey. Available at
http://water.usgs.gov/owq/OFR 99-193A accessed October 12, 2016.

4.	Keith, L.H. (1992). Environmental Sampling and Analysis: A Practical Guide. Chelsea, MI:
Lewis Publishers, pp. 93-119.

5.	Proposed Method Update Rule to 40 CFR Part 136, Federal Register Volume 80, No. 33,
February 19, 2015. Available at https://www.gpo.gov/fdsvs/pkg/FR-2015-02-19/pdf/2015-
02841.pdf accessed October 12, 2016.

6.	Turner, D. J. and MacGregor, I. C., (2016). How Adoption of the Method Detection Limit
Method Update Rule Will Impact the Reporting of Concentrations of Air Toxics in Ambient
Air. Paper presented at the Air and Waste Management Association Air Quality
Measurement Method and Technology Conference, Chapel Hill, NC, March 15, 2016.

7.	Report of the Federal Advisory Committee on Detection and Quantitation Approaches and
Uses in Clean Water Act Programs, Submitted to the US Environmental Protection Agency,
Final Report 12/28/07. Appendix D, pages D-l through D-9.

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4.2

VOCs - Overview of EPA Compendium Method TO-15

Each agency must codify in an appropriate quality systems document, such as an SOP, or
equivalent, its procedures for performing VOC sampling, canister cleaning, and analysis.

Various requirements and best practices for such are given in this section. Note that regardless
of the specific procedures adopted, the method performance specifications as given in Section
4.2.12 must be met.

Of the 188 HAPs listed in Title III of the CAA Amendments of 1990, 97 of these are VOCs.
VOCs are defined as organic compounds having a vapor pressure greater than 10"1 Torr at 25°C.1
VOC air toxics ambient air concentrations are typically measured at the single part per trillion
(ppt) to single ppb level. Measurement of these VOCs is based on the techniques described in
EPA Compendium Method TO-151'2, which describe collection of whole air samples into
evacuated stainless steel canisters followed by preconcentration of the volatiles for analysis via
GC/MS. When initially released, TO-15 indicated the lower limit for concentration
measurement was approximately 0.5 ppbv. However, with newer more sensitive mass
spectrometer detectors, much lower detection limits are achievable such that the MDL MQOs
listed in Table 4.1-1 can be attained. Due to the lack of current and specific guidance for
measuring low (sub-ppbv) levels of VOCs in ambient air, at the time of this TAD's release, EPA
was collecting public comments to revise TO-15 to include techniques and instrumentation that
permit sub-ppbv measurements of VOCs in ambient air. Much of the guidance listed in this
section are anticipated to be included in EPA's update of TO-15.

4.2.1 General Description of Sampling and Analytical Methods. An MFC and/or
critical orifice regulates the flow of ambient atmosphere into an evacuated passivated stainless
steel canister at a known, constant rate over the course of 24 hours. Following completion of
collection, the canister is transported to a laboratory for analysis within 30 days of collection.
Previous studies suggest that most compounds analyzed via TO-15 are stable for up to 30 days in
passivated stainless steel canisters;3'4 however, the condition of the wetted surfaces of each
individual canister is likely to influence the stability of the VOCs. Analysis of the sample as
soon as possible after collection is strongly recommended to minimize changes of the collected
sample, especially for HAPs such as acrolein, 1,3-butadiene, and carbon tetrachloride, among
others.

VOCs are identified and quantified via cryogenic preconcentration GC/MS and a typical analysis
scheme is as follows. A known volume of the whole air (an air parcel from which gases have not
been removed and are completely captured for sample collection) is passed through and the
VOCs are cryogenically trapped onto a sorbent bed while N2, O2, Ar, CO2, and to the extent
possible, H2O are selectively removed. The volume trapped is measured via MFC or by the
change in pressure of a known volume downstream of the sorbent trap. The sample introduction
pathway and sorbent bed are then swept with dry inert gas (such as helium) to remove water,
while the VOCs are retained on the cold sorbent. After the preconcentration and dehydration,
the sorbent is heated to desorb the VOCs and the VOCs entrained in a carrier gas stream where
they are refocused and subsequently introduced onto the GC column for separation. After
separation on the column, VOCs are ionized in a quadrupole, ion trap, or time of flight (TOF)
MS which detects the ion fragments according to their mass to charge (m/z) ratio. The responses

62


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of the ion fragments are plotted against the retention time and compared to the standard
chromatogram to identify the compounds in the sample based on retention times and ion
fragments of standards analyzed under the same chromatographic and MS conditions.

Method TO-15 addresses sampling of VOCs such that integration of the sample results in a final
canister pressure is subambient (< 14.7 psia, or less than the typical ambient atmospheric
pressure at the field location) or above ambient (> 14.7 psia, or above the typical ambient
atmospheric pressure at the field location). Previous versions of this TAD have disallowed
superambient sampling since such is thought to result in depressed recoveries of hydrophilic
polar VOCs due to their dissolution into condensed water. However, many of the sites in the
NATTS network collect canisters at superambient pressures. Due to a lack of definitive studies
demonstrating one method to be superior, this revision of the TAD permits pressurized sampling
but strongly recommends that collected canister pressures remain less than or equal to 3 psig
(-17.7 psia) to minimize the potential for water condensation. Regardless of the chosen final
canister pressure, each agency is responsible for ensuring that method performance specifications
are met, and specifically that method precision and bias are acceptable for their selected
combination of sampling instrument; final canister pressure; canister type; and preconcentration,
water management, and analysis techniques.

A previous study by McClenny et al.5 indicates that ambient air samples collected above
atmospheric pressure may exhibit condensation on the interior canister surfaces. Liquid water
inside the canister decreases precision from canister reanalysis since the amount of condensation
decreases as air is removed from the canister, and the pressure decreases, which changes the
equilibrium of analytes between the liquid and gas phases. For monitoring agencies collecting
samples to superambient pressure, samples should not be pressurized above 3 psig to minimize
the condensation of liquid water inside the canister.

The calibration and tuning of the MS must be monitored and compensated for by the analysis of
internal standards (IS) with each injection and analysis of continuing calibration standards
minimally every 24 hours of analysis (recommended every 10 sample injections and concluding
each sequence).

The VOCs including, but not limited to, those in Table 4.2-1 may be determined by this method.

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Table 4.2-1. VOC Target Compounds and Associated Chemical Abstract
Service (CAS) Number via Method TO-15

Target Compound

CAS#

acetone

67-64-1

acroleina b

107-02-8

acrylonitrile

107-13-1

benzene a b

71-43-2

benzyl chloride

100-44-7

bromodichloro methane

75-27-4

bromoform (tribromomethane)

75-25-2

1,3-butadiene a b

106-99-0

2-butanone (methyl ethyl ketone)

78-93-3

carbon disulfide

75-15-0

carbon tetrachloride (tetrachloromethane)a b

56-23-5

chlorobenzene

108-90-7

chloroform (trichloromethane)a b

67-66-3

cyclohexane

110-82-7

dibromochloro methane

124-48-1

1,2-dibromoethane b

106-93-4

1,2 -dichlorobenzene

95-50-1

1,3 -dichlorobenzene

541-73-1

1,4 -dichlorobenzene

106-46-7

dichlorodifluoromethane (Freon-12)

75-71-8

1,1-dichloroethane

75-34-3

1,2-dichloroethane b

107-06-2

1,1 -dichloroethene

75-35-4

cis-1,2-dichloroethene

156-59-2

trans-1,2-dichloroethene

156-60-5

1,2-dichloropropane b

78-87-5

cis-l,3-dichloropropene b

10061-01-5

trans-l,3-dichloropropene b

10061-02-6

1,2-dichlorotetrafluoroethane (Freon-114)

76-14-2

1,4-dioxane

123-91-1

ethanol

64-17-5

ethyl acetate

141-78-6

ethyl chloride (chloroethane)

75-00-3

ethylbenzene

100-41-4

4-ethyl toluene

622-96-8

heptane

142-82-5

hexachloro-1,3 -butadiene

87-68-3

hexane

110-54-3

2-hexanone (methyl butyl ketone)

591-78-6

isoprene

78-79-5

isopropyl alcohol

67-63-0

methanol

67-56-1

methyl bromide (bromomethane)

74-83-9

methyl chloride (chloromethane)

74-87-3

methyl isobutyl ketone (4-methyl-2-pentanone)

108-10-1

methyl methacrylate

80-62-6

methyl tert-butyl ether

1634-04-4

methylene chloride (dichloromethane)b

75-09-2

propene

115-07-1


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Table 4.2-1. VOC Target Compounds and Associated Chemical Abstract Service (CAS)

Number via Method TO-15 (Continued)

Target Compound

CAS#

styrene

100-42-5

1,1,1,2-tetrachloroethane

630-20-6

1,1,2,2-tetrachloroethane b

79-34-5

tetrachloroethene a b

127-18-4

tetrahydrofuran

109-99-9

toluene

108-88-3

1,2,4-trichlorobenzene

120-82-1

1,1,1 -trichloroethane

71-55-6

1,1,2-trichloroethane

79-00-5

trichlorofluoromethane (Freon 11)

75-69-4

l,l,2-trichloro-l,2,2-trifluoroethane (Freon-113)

76-13-1

1,2,4-trimethylbenzene

95-63-6

1,3,5 -trimethy lbenzene

108-67-8

trichloroethene a b

79-01-6

vinyl acetate

108-05-4

vinyl bromide

593-60-2

vinyl chloride (chloroethene)a b

75-01-4

m&p-xylene

108-38-3 (m)/106-42-3 (p)

o-xylene

95-47-6

a NATTS Tier I core analyte
bNATTS PT target analyte

4.2.1.1	Sampling Pathway. All wetted sampling surfaces that contact the sampled
atmosphere, including the inlet probe, must be of chromatographic grade stainless steel or
borosilicate glass. Stainless steel tubing may be additionally fused silica lined which increases
the inertness of the flow path. While PTFE Teflon is permitted, its use is not recommended as
high molecular weight compounds may adsorb to the surface. Use of other materials such as
copper, FEP Teflon®, or rubber is not permitted, as they have active sites or provide
opportunities for VOCs to adsorb and later desorb.

4.2.1.2	Particulate Filtration. A 2-|im pore size sintered stainless steel particulate filter
must be installed on the sampling unit inlet for all VOC collection. If employing a standalone
VOC inlet probe, a particulate filter placed further upstream in the sampling pathway may permit
a longer period between sampling inlet pathway cleaning. Failure to install a particulate filter
allows particulate residue such as dust and pollen to adhere to the interior of the sampling unit
(to valves, MFC, etc.) and to be pulled into the evacuated canister during sample collection.

Once inside the canister, particulate matter can form active sites, adsorb analytes, and/or provide
reactants which may degrade and form target analytes or interferants, potentially rendering the
canister irreversibly contaminated. The particulate filter must be replaced minimally annually or
more frequently if in areas with high airborne PM levels which may result in decreased flows or
decreased collected pressures.

4.2.2 Precision - Sample Collection and Laboratory Processing. Each agency must
prescribe procedures that it will follow to assess VOCs precision in the NATTS QAPP, SOP, or
similar controlled document. Given below are the various types of precision and associated
frequency requirements for VOCs.

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Precision between duplicate, collocated, and replicate analysis samples must be < 25% relative
percent difference (RPD) for target compound concentrations > five-fold the laboratory MDL.
Both sample results must be qualified when entered into AQS for instances in which collocated
or duplicate samples fail this precision specification. For precision criteria failures of replicate
analyses, the value reported as the RD transaction must be qualified. Root cause analysis must
be performed to investigate and correct the failure. If a root cause cannot be identified, results
should be qualified as estimated. Please refer to the list of qualifiers in Table 3.1-1.

4.2.2.1 Sample Collection and Analysis Precision. Collocated and duplicate samples are
compared to the primary sample to determine the precision inclusive of all sample collection and
analysis procedures.

For samples to be collocated, each sampling unit must have its own pathway to the ambient
atmosphere. If collected from a manifold, each sampling unit must have a dedicated manifold
for it to be collocated; otherwise this configuration is defined as duplicate. The rationale behind
this distinction is that there is potential non-homogeneity of the sampled atmosphere in the
manifold when compared to the ambient atmosphere. Any effect of the manifold impacts both
sampling units and they are not sampling truly independently from the ambient atmosphere. If
both sampling unit inlets connect to the same inlet manifold, the samples are duplicate, not
collocated, as shown in Figure 4.2-1. To summarize,

•	Collocated samplers must have two separate flow control devices and two separate
discrete inlet probes to the ambient atmosphere. If applicable, each sampling unit
must connect to a separate manifold. Collocated sampling inlet probes must be
within 1 to 4 meters of the primary sampling inlet probe.

•	Duplicate sampling is performed in situations where two canisters are collected
through a single inlet probe, which includes a common inlet manifold.


-------
Collocated or duplicate VOC sampling, if performed (as detailed in the workplan), must be
conducted at a minimum frequency of 10%. This is equivalent to a minimum of six collocated
samples per year, or roughly one every other month, for sites conducting one-in-six days
sampling for a total of 61 primary samples annually. More frequent collocated sample collection
provides additional sample collection precision and is encouraged where feasible.

4.2.2.2 Laboratory Analytical Precision. Several analysis aliquots can be removed from a
collected canister which affords replicate analysis to evaluate analytical precision. The same

67


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sample is injected twice and the results are evaluated for precision as RPD. The required
frequency for replicate analyses reported to AQS is prescribed in the workplan, but is
recommended to be performed on a one-per-batch frequency or one-in-20 sample injections,
whichever is more frequent. Monitoring organizations are encouraged to report all replicate
analysis results to AQS.

4.2.3 Sample Collection Procedures

4.2.3.1	Sampling Equipment Specification. Various sampling instruments are commercially
available. Such systems may permit simultaneous collection of VOCs canisters and carbonyl
cartridges or include secondary channels for collection of duplicate VOCs canister samples.
Regardless of the additional features, each sampling unit must minimally include the following
options:

•	Elapsed time indicator

•	Multi-day event control device (timer)

•	Latching solenoid valve with a low temperature rise coil

•	Pressure gauge or pressure transducer to perform leak checking of canister
connection

•	MFC (preferred) or critical orifice to control sampling flow

All wetted surfaces of the flow path in the sampling unit must be constructed of chromatographic
grade stainless steel or borosilicate glass. Stainless steel may be additionally deactivated with
fused silica linings. Use of PTFE Teflon is discouraged as it can behave as a sorbent for high
molecular weight VOCs. Inclusion of glass-lined stainless steel is discouraged as it is prone to
breakage which can cause flow restrictions.

4.2.3.2	Sample Collection, Setup, and Retrieval

4.2.3.2.1 Sample Setup. It is strongly recommended that the initial canister
pressure be checked prior to sample collection by measurement of the canister vacuum with a
calibrated pressure gauge or pressure transducer. If a built-in gauge on the sampling unit cannot
be calibrated, a standalone gauge should be employed for this measurement. This initial pressure
should be documented on the sample collection form. Canisters must show > 28 inches Hg
vacuum to conduct sampling.

Once vacuum is verified, the canister is connected to the sampling unit and a leak check is
performed. A leak check may be performed by quickly opening and closing the valve of the
canister to generate a vacuum in the sampling unit. The vacuum/pressure gauge in the sampling
unit should be observed for a minimum of 5 minutes to ensure that the vacuum does not change
by more than 0.2 psi. Commercially-available canister sampling units may include a leak check
routine. For onboard leak check routines, the leak check criteria should be equivalent or better
than those listed above. If a leak is detected, fittings should be tightened to locate the source of

68


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the leak. Sample collection must not commence until a successful leak check is attained. Leak
check pressure change and duration is documented on the field collection form.

Following successful leak check, the sample collection program is verified and the canister valve
is opened.

4.2.3.2.2	Subambient Sample Collection. Subambient pressure sample collection
results in a canister pressure that is approximately 10 to 13 psia (2 to 10 inches Hg vacuum).
Sample collection must be performed at a constant flow rate over the 24-hour collection period.
Flow rates are typically 2.5 to 3.5 mL/minute for 6-L canisters.

As discussed earlier in Section 4.2.1, the management of water in sample collection is important
to the ability to remove air from the canister that is representative of the atmosphere initially
collected. At subambient pressures, the partial pressure of water vapor does not typically exceed
the equilibrium vapor pressure at the typical analysis temperature, thus water generally will not
condense on the interior surfaces of the canister.

Subambient sample collection does not include a pump in the sampling pathway. With fewer
components, moving parts, seals, and surfaces, there is generally less risk of contaminating a
collected sample. A less complex sampling system has fewer parts to wear out and break,
simplifying maintenance.

Two disadvantages with subambient sample collection relate to contamination due to leaking and
a smaller overall volume of collected gas for analysis. A canister leak on a subambient pressure
sample will cause ambient air to enter the canister and contaminate the sample, invalidating the
sample. Moreover, a canister at subambient pressure contains less air than an equivalent
superambient sample, which limits the number of aliquots that may be effectively removed from
the canister before there is insufficient gas remaining for analysis.

4.2.3.2.3	Superambient (Positive) Pressure Sampling. Superambient pressure
sampling (positively pressurized sampling) involves collection of samples above atmospheric
pressure utilizing a pump to push air into the canister. As discussed earlier in Section 4.2.1,
sample collection at pressures above ambient pressure may result in water condensation on the
interior walls of the canister.5 It is theorized that this condensation may lead to poor
representation of hydrophilic polar compounds in the aliquot of gas removed from the canister
for analysis. An advantage of superambient pressure sample collection is that if the canister
leaks slightly, the sample will not become contaminated so long as the canister pressure remains
greater than atmospheric pressure.

A disadvantage of superambient sample collection is that it requires incorporation of a pump and
additional valves in the sampling pathway, which provide additional opportunities for
contamination over time when compared to subambient sampling methods which do not require
the additional pumps and valves.

Some sampling systems are susceptible to condensation in the flow pathway during high-
dewpoint conditions. This condensation manifests in the high pressure area between the pump

69


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and the bypass valve and is evidenced by rough pressure responses when the bypass valve is
operating. To alleviate this condensation, the bypass valve should be kept as open as possible to
maximize the air flow through the sampler and minimize the condensation.

4.2.3.2.4 Sample Retrieval. Following completion of sample collection, it is
strongly recommended that the final canister pressure be measured with a calibrated pressure
gauge and recorded on the sample collection form. If an on-board gauge on the sampling unit
cannot be calibrated, a standalone calibrated gauge should be used. The sample start and stop
times as well as the elapsed collection time must also be recorded on the sample collection form.
The sample custody form must be completed and accompany the collected sample at all times
until relinquished to the laboratory. COC documentation must comply with Section 3.3.1.3.7.

Sampling units which incorporate computer control of the sampling event with associated data
logging may provide the above information which should be printed and attached to the sample
collection form or transcribed. If transcribed, the transcription must be verified by another
individual. For such sampling units, the data logged should be reviewed to ensure the sample
collected appropriately and there are no flags or other collection problems that may invalidate the
collected sample. Collected data should be downloaded and provided to the analysis laboratory.

4.2.3.3	Sampling Schedule and Duration. VOC sample collection must be performed
according to the national sampling schedule at one-in-six days for 24 ± 1 hours beginning at
midnight and concluding on midnight of the following day, standard local time, unadjusted for
daylight savings time. For missed or invalidated samples, a make-up sample should be
scheduled and collected per Section 2.1.2.1. Clock timers controlling sampling unit operation
must be adjusted so that digital timers are within ±5 minutes of the reference time (cellular
phone, GPS, or similar accurate clock) and mechanical timers within ±15 minutes.

4.2.3.4	Sampling Train Configuration andPresample Purge. Sampling unit inlets may be
connected to a standalone inlet probe or may be connected to a sampling inlet manifold with a
single inlet probe. If connected to a manifold inlet, the VOC sampling line must be connected to
the port closest to the manifold inlet probe. Inlet manifolds must incorporate a blower to pull
ambient air through the manifold; the manifold flow rate should be minimally two times greater
than the total demand of the systems connected to the manifold. An exit flow meter should be
installed to ensure excess air flow which reduces residence time and ensures that a fresh supply
of ambient air is available for sampling. Refer to Section 2.4 for sampler siting requirements.

For either inlet system listed above, the inlet line to the sampling unit must be purged with
ambient air such that the equivalent of a minimum of 10 air changes is completed just prior to
commencing sample collection. This purge eliminates stagnant air and flushes the inlet line.

4.2.3.5	Sampling Unit Non-Biasing Certification. Prior to field deployment and annually
thereafter, each VOC sampling unit must be certified as non-biasing by collection over 24 hours
of both a sample of hydrocarbon-free (HCF) zero air (or equivalent VOC- and oxidant-free air)
or zero grade nitrogen and known concentration VOC standard in air.

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This certification may be performed as part of an internal audit, however, this certification is best
performed following annual maintenance which includes calibration (or calibration checks) of
MFCs and pressure gauges and other preventive maintenance, as needed, to ensure the sampling
unit is non-biasing prior to field deployment. Equipment such as dynamic dilution systems,
connecting tubing, and MFCs should be purged with humidified zero air or nitrogen for
sufficient time (typically one hour) to ensure the challenge delivery system is clean.

A best practice is to perform this procedure through the probe (TTP) where the entire sampling
train is assessed for bias. Conducting the TTP procedure requires equipment such as portable
zero air generators and portable gas-phase dynamic dilution systems and staff familiar with their
operation. While the TTP procedure is the best practice, each sampling unit must minimally be
bench tested. Suitable test procedures are described below.

Recommended certification check procedures are described below. For agencies which cannot
perform the annual maintenance and challenge in-house, manufacturers, the national contract lab,
or third party vendors may offer certification services. Regardless of the exact procedure
adopted, the performance specifications listed below must be met.

4.2.3.5.1 Zero Check. The zero check is performed by simultaneously providing
humidified (50 to 70% RH) hydrocarbon- and oxidant-free zero air (must meet the cleanliness
criterion of < 0.2 ppbv or < 3x MDL, whichever is lower) or UHP nitrogen to the sampling unit
for collection into a canister and to a separate reference canister connected directly to the
supplied HCF zero air gas source. The reference canister collects the challenge gas directly and
is the baseline for comparison of the challenge sample. Compounds which show increased
concentrations in the challenge sample compared to the reference sample indicate contamination
attributable to the sampling unit.

The humidified zero gas flow is provided to a challenge manifold constructed of
chromatographic stainless steel. The manifold should include three additional ports for
connections to the sampling unit inlet, reference MFC, and a rotameter which acts as a vent to
ensure that the manifold remains at ambient pressure. The reference MFC flow is set to
approximately the same flow rate as the sampling unit. Zero gas is to be supplied such that there
is excess flow to the manifold as indicated by the rotameter on the vent port. Sampling is
performed over 24 hours, to simulate real world conditions, into the reference canister and
through the sampling unit into the zero challenge canister. Sampling for 24 hours best replicates
conditions in the field, however, shorter sampling durations for these challenges are also
acceptable.

Analysis by GC/MS for target compounds must show all Tier I core compounds in the zero
challenge canister are not greater than 0.2 ppbv or 3x MDL (whichever is lower) higher than the
reference canister and the remaining core compounds should also meet these criteria. Where
exceedances are noted in the zero challenge canister for Tier I core compounds, corrective action
must be taken to remove the contamination attributable to the sampling unit and the sampling
unit zero challenge repeated to ensure criteria are met before sampling can be conducted.
Subsequent collected field sample results for non-Tier I compounds that fail this criterion must
be qualified when input to AQS.

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4.2.3.5.2 Known Standard Challenge. The known standard challenge is performed
by simultaneously providing a humidified (50 to 70% RH) known concentration standard of
target VOCs (at approximately 0.3 to 2 ppb each) in air or UHP nitrogen to the sampling unit for
collection into a canister and to a separate reference canister connected directly to the supplied
standard gas stream. The reference canister collects the challenge gas directly and is the baseline
for comparison of the challenge sample. Compounds which show enhanced or decreased
concentrations in the challenge sample compared to the reference sample indicate bias
attributable to the sampling unit.

It is recommended that the challenge gas contain all target VOCs, however, a smaller subset of
compounds is sufficient provided that each target compound type is represented in the gas
mixture (e.g. low molecular weight, fluorinated, chlorinated, brominated, high molecular weight,
etc.).

The standard challenge gas is supplied to the challenge manifold by dilution of a gas mixture of
VOCs via dynamic dilution with humidified HCF zero air. The manifold should be constructed
of chromatographic stainless steel and should include three additional ports for connections to
the sampling unit inlet, reference canister, and a rotameter acting as a vent to ensure that the
manifold remains at ambient pressure. The reference canister may be collected via MFC, other
constant flow device, or a grab sample to characterize the plenum manifold concentrations.
Challenge gas is to be supplied such that there is excess flow supplied to the challenge manifold
as indicated by the rotameter on the vent port. Samples are collected simultaneously for 24
hours to simulate real world conditions. Sampling for 24 hours best replicates conditions in the
field, however, shorter sampling durations for these challenges are also acceptable.

Analysis by GC/MS for target compounds must demonstrate that each VOC in the challenge
sample is within 15% of the concentration in the reference sample. All Tier I core compounds in
the challenge gas must meet this criterion. For Tier I core compounds exceeding these criteria,
corrective action must be taken to address the bias in recovery attributable to the sampling unit.
Subsequent collected field sample results for non-Tier I compounds that fail this criterion must
be qualified when input to AQS.

Following completion of the known standard challenge, the sampling unit should be flushed with
humidified HCF zero air or ultra-high purity (UHP) nitrogen for a minimum of 24 hours.

Once shown as non-biasing, a best practice to assess ongoing bias is to compare fingerprint plots
(discussed in Section 3.3.1.3.14.2) of each sample from the site.

4.2.4 Canister Hygiene. At the time of this TAD revision, measuring VOCs in ambient air
using passivated stainless steel canisters is approximately a 40-year old technology. While
measurement systems have become more sensitive with the advent of selected ion monitoring
(SIM) and TOF detection, many agencies are unable to achieve sufficient sensitivity to measure
VOCs at ambient concentrations in collected air samples due to the inability to properly clean
and maintain canisters. The following sections present requirements and best practices for
assessing background levels in canister media and maintaining sufficiently low background
levels to the measurement of VOCs in ambient air.

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4.2.4.1 Qualification of Canisters. When new canisters are received, it is strongly
recommended that they be qualified appropriately prior to use for sample collection or for
preparation of standards and blanks. New canisters may contain residues such as cutting oils,
pump oils, or coating byproducts from the manufacturing process and/or residual contamination
from compounds added by manufacturers to perform QC checks on the canisters prior to release
to customers. Additionally, new canisters may have defects making them unsuitable for use even
after the canisters have been cleaned and treated for the residual contaminants. Such defects may
relate to poor valve sealing, active sites from incomplete coating or surface deactivation, or poor
canister integrity due to inadequate welds.

Following new canister receipt and before use and annually thereafter, it is strongly
recommended that canisters be properly cleaned, tested for leaks, and evaluated for bias such that
the requisite canister performance specifications are met. As with new canisters, existing
canisters in agency fleets may exhibit some of the same problems over time and it is strongly
recommended that they be qualified on an annual basis to verify they are non-biasing. All
canisters in a given fleet need not be qualified at the same time, rather a subset can be qualified
on a rolling basis such that all canisters are qualified within the period of a year. For monitoring
agencies with large canister fleets, it may not be feasible to assess each canister within a year. In
such cases, the monitoring agency should prepare a schedule to assess canisters in a reasonable
timeframe (e.g. every 18 months). Suitable procedures are described in the following sections.

4.2.4.1.1 Canister Bias. It is strongly recommended that all canisters be evaluated
for bias when newly purchased (prior to use for field sample collection or use for laboratory QC
sample preparation) and annually thereafter. Assessment for bias of newly purchased canisters
or canisters from an existing fleet is performed identically. Canisters which exhibit a positive or
negative bias exceeding the criteria below should be segregated and reconditioned before reuse
or discarded. Some commercial canister manufacturers offer reconditioning services for their
canisters. Consult the manufacturer for methods to clean or recondition cans which fail these
bias criteria.

4.2.4.1.1.1 Canister Integrity and Zero Air Check

Within two days following cleaning, preferably the same day, canisters should be pressurized
with humidified HCF zero grade air (or UHP N2). This short duration following cleaning is
intended to characterize the canister condition before analytes have a chance to "grow" in the
canister. In order to assess leak tightness of the canisters and to best represent the contamination
potential from collected field samples, pressurization should be performed so that the final
canister pressure closely matches that of the typical pressure of field sample canisters.
Subambient pressurization provides less diluent and may provide more measurable target
compound mass per injection aliquot. Pressurization above ambient pressure permits removal of
larger aliquots of sample gas, and as such affords more opportunities for reanalysis. In either
case, canisters must be approximately 2 psi above or below ambient pressure to permit
assessment of canister leaks. The leak check process given here is one example for a method to
determine canister leak tightness. Other equivalent methods can be performed provided they
meet the leak criteria of < 0.1 psi/day. Leak checks are recommended to be performed annually,

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however the frequency of performing leak checks must be prescribed in the NATTS QAPP,
SOP, or similar controlled document.

Immediately upon pressurization, each canister's pressure is measured with a calibrated gauge
for establishment of a baseline. After a minimum of 7 days and after as long as 30 days, each
canister's pressure is again measured. Canisters with leak rates >0.1 psi/day must be removed
from service and repaired. This leak rate permits 5% of the sample volume to leak over 7 days
and a 20% sample volume leak over 30 days.

The canister should be analyzed within two days of initial pressurization and all Tier I core
analytes must be < 3x MDL or < 0.2 ppb, whichever is lower, and non-Tier I compounds should
meet this criterion. Note that following this analysis, the canister pressure must be remeasured
to accurately assess the canister leak rate as the aliquot removed for analysis changes the canister
pressure. Subsequent analysis may be performed minimally at 14 days after pressurization and is
highly recommended to be performed at 30 days after initial pressurization. Laboratories may
tailor this later timepoint to be representative of the maximum holding time experienced by the
laboratory (e.g. 21 days if all samples are analyzed within this time frame from sample
collection). Analyses at these later timepoints must show all Tier I core analytes < 3x MDL or
< 0.2 ppb, whichever is lower, and non-Tier I compounds should meet this criterion.

Intermediate timepoints less than 30 days will likely indicate if there is a problem with a
particular canister. Canisters which meet criteria at intermediate timepoints should be analyzed
at the 30-day timepoint to verify they are bias free for the 30-day period. If analysis can be
performed at only one timepoint after initial pressurization, it is recommended to be at 30 days.

Laboratories have reported growth of oxygenated compounds (e.g. ketones, alcohols, aldehydes)
in canisters. Of particular concern in the canister zero air checks is acrolein, which evidence
suggests may "grow" in canisters that are stored for extended periods. The mechanism for
acrolein growth is not well understood; however, such is widely regarded as problematic in
performing ambient concentration analysis. Suggested pathways of acrolein growth are
decomposition of particulate residue, slow time-release of acrolein from interstitial spaces within
the canister, breakdown of cutting oil residues in valves, or decomposition of other volatile
constituents within the canister. Concentrations of target compounds above twice the laboratory
MDL should be closely scrutinized as they indicate the presence of canister background
concentrations which may cause issues with future sample collection measurements.

4.2.4.1.1.2 Known Standard Gas Check

Following the canister zero air check in Section 4.2.6.1.1.1, it is strongly recommended that
canister bias be assessed by filling a cleaned canister with a low-level (0.3 to 2 ppb) humidified
standard gas and analyzed 30 days following the initial pressurization. Intermediate timepoints
minimally 14 days after pressurization may be added and may indicate a bias problem,
eliminating the need to perform the 30-day timepoint analysis. Canisters which meet criteria at
intermediate timepoints should be analyzed at the 30-day timepoint to verify they are bias free
for the 30-day period. Laboratories may tailor this later timepoint to be representative of the
maximum holding time experienced by the laboratory (e.g. 21 days if all samples are analyzed
within this time frame from sample collection). The initial analysis should show that target

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analytes are within 30% of nominal and not show significant degradation beyond 30% of
nominal for subsequent timepoints over the 30-day evaluation period.

While not a substitute for performing canister bias checks, an additional method to assess
canister bias is to collect an ambient air sample, analyze it immediately, and analyze it again
following an extended period (e.g. 30 days) and look for changes in analyte concentration which
exceed 30% from the initial analysis.

4.2.4.2 Canister Cleaning. Cleaning of canisters for ambient sample collection may be
performed in a variety of ways which may result in acceptably low background levels in the
canister. Systems are commercially available from a variety of manufacturers or may be custom-
built. Many incorporate the following elements:

1.	Manifold for connection of several canisters (typically 4 to 8)

2.	Rough vacuum pump to achieve vacuum of approximately 1 inch Hg

3.	High vacuum pump (such as a molecular drag pump) to achieve a final canister
vacuum of approximately 50 mTorr or less

4.	Heating oven, heating bands, or heating jackets

5.	Humidification system

6.	Automated switching between evacuation and pressurization

7.	A pressure release valve to minimize the likelihood of system overpressurization

8.	Trap (cryogenic or molecular sieve) to eliminate backstreaming of contaminants
into canisters (only necessary for systems with a non-oil free vacuum pump - note
use of such pumps is not recommended)

9.	Chromatographic grade stainless steel tubing and connections - recommend
minimizing system dead volume to minimize pressurization/evacuation time and
provide less surface area for contaminants

10.	Source of clean purge gas such as zero air or UHP nitrogen

11.	Absence of butyl rubber, Teflon®, or other materials that may adsorb and/or
offgas compounds of interest or other potential interferences

Regardless of how canisters are cleaned, canister cleanliness criteria must be met.

Monitoring agencies must prescribe a policy for holding time for cleaned canisters, which must
not exceed 30 days unless objective evidence indicates that the additional time does not
negatively impact measured sample concentrations.

4.2.4.2.1 Heated Canister Cleaning. Heating of canisters during cleaning is
strongly recommended. Various methods of heating canisters during cleaning may be employed.
The temperature applied to the canister should depend on whether the canister is silica-lined or
electropolished, the temperature rating of the valve and vacuum gauge (if so equipped), and the
heating method employed.

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Heating bands often cause hot spots on the canister, do not evenly heat canister surfaces further
from the bands, and may not adequately heat the valve. Heating jackets and ovens heat the
canister evenly, but may not be able to isolate the valve from the heat source, which may cause
damage to the valve if cleaning is performed at high heat (> 80°C). Some heating j ackets or
ovens allow the valve to protrude from the jacket or oven and allow the valve to only be exposed
to radiant heat.

If employing humidified HCF zero grade air during canister cleaning (specifically the canister
pressurization steps), silica-lined canisters should not be heated above 80°C as oxidation of the
surface may occur which leads to active sites within the canister.6

Heating is recommended for cleaning of ambient concentration canisters, however higher
temperatures are not always better. For canisters of known history used for ambient sample
collection, heating to approximately 75°C during cleaning is generally sufficient. Canisters used
for collection of source level (part per million) samples or samples with matrices including high
molecular weight compounds with high boiling points should be heated to a higher temperature
(100°C or higher), if permitted by the canister and valve. Typically such canisters cannot be
sufficiently cleaned and should be sequestered from use for collecting ambient samples.

4.2.4.2.2	Cycles of Evacuation and Pressurization. Canisters containing standards
or unknown contents with pressures above ambient pressure should be vented into a fume hood
or other exhaust outlet prior to connection to the canister cleaning manifold. In general, the
greater the number of evacuation and pressurization cycles, the more effective the cleaning.

Also, longer holds of vacuum generally result in more effective cleaning. Canisters should be
evacuated to > 28 inches Hg vacuum during each evacuation cycle.

While TO-15 recommends three cycles of evacuation and pressurization, minimally five cycles
of evacuation and pressurization are recommended and ten or more have been shown to be
effective in removing stubborn oxygenated compounds (e.g. acetone, methyl ethyl ketone, and
isopropanol). 7 Following the principle of extraction efficiency where each cycle recovers a
specific percentage of each compound (i.e. 85%), additional evacuation and pressurization cycles
(up to 20) are highly recommended to achieve sufficiently clean canisters. Vacuum of > 28
inches Hg should be maintained for minimally 5 minutes before the pressurization step. Final
evacuation to < 50 mTorr and maintaining this vacuum for minimally 5 minutes is
recommended. Longer final vacuum holds up to approximately an hour are recommended if
feasible. Automated canister cleaning systems may be advantageous as including additional
cycles or extending vacuum hold times can easily be programmed.

An alternative to performing the final evacuation at the end of the cleaning cycles, canisters may
be stored pressurized with humidified zero air or other clean purge gas. When stored
pressurized, canisters are evacuated to < 50 mTorr just prior to field deployment.

4.2.4.2.3	Gas Source for Canister Cleaning Pressurization. If canisters are heated
during cleaning, pressurization of canisters to approximately 5 psig is recommended to avoid
rupture of the canister when heat is applied. For canisters which are not heated during cleaning,
pressurization up to approximately 30 psia is recommended. The purge gas for canister cleaning

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should be high purity zero air or nitrogen. Scrubbing of purge gas with additional hydrocarbon
traps, moisture traps, and/or catalytic oxidation may be necessary to obtain sufficiently clean
purge gas which should be < 0.2 ppbv or < 3x MDL, whichever is lower. When using zero air as
the purge gas, lower temperatures should be maintained during the cleaning process (as
compared to temperatures possible with UHP N2) in order to avoid oxidation of interior canister
surfaces. UHP nitrogen may be sourced from cylinders or may be the headspace gas from a
liquid nitrogen dewar. Regardless of the purge gas selected, its cleanliness should be verified by
analysis to ensure that contaminants are not introduced into the canisters during the cleaning
process.

The source gas should be humidified to approximately 30 to 70% as practical, generally higher
humidity levels are considered to be more effective. The water assists in removal of polar
compounds which may otherwise remain adsorbed to interior canister surfaces. Most
commercial canister cleaning systems incorporate a type of humidifier, however these typically
do not provide a sufficient level of humidity. Humidification systems may be constructed which
incorporate a diptube in deionized water which humidifies by bubbling the purge gas through the
deionized water or via an impinger placed above the surface of the water in the humidifying
chamber. If a bubbler type humidifier is employed, care should be taken to ensure the
downstream pressure is lower than the humidifier upstream pressure to avoid backflow of the
water. It is recommended that the RH of the purge gas be measured with a calibrated hygrometer
to ensure the desired RH is attained.

4.2.4.2.4 Verification of Canister Cleanliness. Following completion of canister
cleaning activities, minimally one canister per batch cleaned must be pressurized to
approximately the pressure of field collected samples with humidified purge gas, held minimally
overnight, and analyzed to ensure all target compounds are < 3x MDL or < 0.2 ppbv, whichever
is lower. Cleanliness criteria must be lowered for agencies which dilute field samples such that
the cleanliness criteria are met for undiluted samples. For instance, if a laboratory dilutes all
samples by two-fold by addition of gas to the collected sample canister, the cleanliness criteria
are not doubled, but are cut in half. A detected concentration of benzene at 0.15 ppbv (assuming
3x MDL is higher) at the instrument would not pass criteria, as the concentration adjusted for
dilution is 0.30 ppbv which exceeds the 0.2 ppbv criterion.

Analysis of more than one canister from each batch is highly recommended and should be no
less than one out of every ten canisters. A best practice is to survey every canister in a cleaning
batch. Following analysis, canisters are re-evacuated to < 50 mTorr. If only a subset of the
canisters in the batch is able to be analyzed, the selected canisters should be those which
indicated the highest total VOC concentration or the highest single target compound
concentration in the previous sample. Other conventions for selecting the batch blank canister
include random selection or evaluating high molecular weight compounds or oxygenated
compounds which are more difficult to completely remove from canisters.

A composite batch blank sample may be prepared by closing the valve of a chosen canister
(which is still under vacuum). The manifold is then pressurized with clean purge gas such that
the other connected canisters are pressurized. The chosen batch blank canister is then opened to
fill the canister with the composite gas from all of the canisters connected to the manifold.

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Actions must be taken to further investigate failure of batch blanks to meet the cleanliness
criteria. If each cleaned canister from the batch is surveyed, only those canisters which fail the
criteria must be recleaned. If one canister representing the batch fails, either the entire batch can
be recleaned (recommended) or two canisters from the batch can be selected and analyzed to
confirm the batch does not pass criteria. If both of these canisters pass, only the failing canister
must be recleaned, otherwise, the batch must be recleaned. Continued failure of batch blanks
may indicate that the manifold or other parts of the system has become contaminated.

4.2.4.3 Canister Maintenance and Preventive Maintenance. Maintenance of cani sters
involves a combination of preventive actions and best practices related to initial canister
qualification, sample collection, cleaning, and general handling.

4.2.4.3.1	Collection of Whole Air Samples into Canisters. Whole air sampling into
canisters must be performed with a particulate filter as discussed in Section 4.2.3.3 as once
particulates have been drawn into a canister, they are difficult to remove. Particulate residue
inside of a canister creates active sites and adsorption sites which may have a detrimental effect
on sample compound recovery. Particulates may deposit into canister valves, potentially leading
to the damage of the threads and seals, resulting in leaks. Furthermore, general cleaning of
canisters does little to remove particulate residue interferences which may be indistinguishable
from degradation of the interior surface of the canister. For canisters which cannot be
remediated successfully, the canister may require retirement. Alternatively, canister
manufacturers offer canister reconditioning services which can restore canisters to brand new
condition.

When not connected to a system for cleaning, sample collection or analysis, the canister opening
should always be capped with a brass cap to ensure particulates do not deposit into the valve
opening. To avoid galling the threads of the connection, the brass cap should be installed finger
tight then snugged gently, no more than 1/8 turn with a wrench.

4.2.4.3.2	Overtightening of Valves. The amount of torque required to close a valve
depends on the particular type of valve and overtightening will likely damage the valve. Canister
valves should never be closed with excessive force or by using a wrench. Damaged valves may
not seal appropriately resulting in leaks. Valves with damaged threads or seals should be
replaced.

4.2.4.3.3	General Canister Handling. Canisters should be handled with care to
ensure that weld integrity is maintained, that the interior canister surface is not compromised,
and that the valve-to-canister connection remains intact. Shocks to the surface of the canister
may damage welds or create small cracks in the interior canister surface which may expose
active sites. Excessive pressure on the canister valve may cause leaks in the seal between the
canister valve and canister stem.

Shipment of canisters in protective hard-shell boxes and/or sturdy cardboard boxes is
recommended to ensure canister longevity. Care should be taken to replace any boxes which
have lost integrity or rigidity.

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4.2.5	Method Detection Limits. MDLs for VOCs must be determined minimally annually
by following the procedures in Section 4.1. To ensure that the variability of the media is
characterized in the MDL procedure, separate spiked canisters (it does not suffice to simply
analyze a low-concentration level standard) and method blanks must be prepared, carried out
with canisters in use for field collection. It is recommended that canisters are chosen randomly
and that each type of canister employed for field sample collection be represented. It is not
acceptable to "cherry pick" the best performing canisters for determining MDLs. For example,
laboratories determining the MDL following Section 4.1.2.1 must prepare a minimum of seven
method blank canisters and a minimum of seven spiked canisters over the course of three
different batches (different calendar dates - preferably non-consecutive). These samples must be
analyzed in three separate analytical batches (different calendar dates - preferably non-
consecutive). The MDL is then determined by calculating the MDLsp and MDLb and selecting
the higher of the two concentrations as the laboratory MDL. Please refer to section 4.1.2 for
specific details on selecting a spiking concentration, procedures, and calculations for determining
MDLs.

While the MDL capabilities of each laboratory may vary due to a number of factors (canister
hygiene, condition of equipment, cleanliness of diluent gases, etc.), spiking concentrations for
VOCs MDLs of approximately 0.05 to 0.125 ppbv are typical to achieve the required MDL
MQOs.

All steps performed in the preparation and analysis of field sample canisters (such as dilution)
must be included in the MDL procedure. Canisters must be prepared at the selected spiking
concentration with humidified diluent gas. It is not appropriate to prepare a higher concentration
spike and analyze a smaller aliquot than analyzed for field collected samples. For example, for
laboratories which analyze 500 mL of field collected sample, a spike concentration of 0.06 ppbv
was chosen. The spiked canisters should be prepared at 0.06 ppbv with humidified diluent gas
and 500 mL analyzed. It would not be acceptable for the laboratory to prepare spikes at 0.30
ppbv and analyze only 100 mL of the sample as this would not be representative of the procedure
for field collected samples.

Note that at very low levels approximating the MDL, the qualitative identification criteria related
to qualifier ion abundance ratio and/or signal-to-noise ratio listed in Section 4.2.10.5.3 may not
be strictly met when determining the MDL. As the MDL spikes are prepared in a clean matrix
with standard materials, the presence of the analyte is expected.

Determined MDLs for Tier I core analytes must meet (be equal to or lower than) those listed in
the most current workplan template.

4.2.6	Canister Receipt. When received at the laboratory, canister samples must be
accompanied by a COC form. The sample custodian must sign and date the custody form
indicating transfer of custody and examine the sample collection documentation. Sample
custody is further described in Section 3.3.1.3.7.

Canister pressure for canisters collected to subambient pressure must be measured with a
calibrated gauge or pressure transducer when received at the laboratory to ensure that the sample

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has not leaked. This is a best practice for canisters collected to pressures above ambient
pressure. An acceptable pressure change for subambient pressure samples between the measured
pressure at sample retrieval in the field and the pressure upon receipt in the laboratory must be
defined in an SOP or similar quality systems document. The recommended tolerance is a
pressure change of < 0.5 psia (ensure the measurement is in absolute pressure to account for
differences in altitude which contribute to error when measured in psig). Pressurized samples
must be measured prior to analysis to ensure that they have not leaked down to atmospheric
pressure. Subambient pressure samples which demonstrate pressure changes exceeding criteria
should be invalidated.

4.2.7	Dilution of Canisters. Canister samples collected at subambient pressures may
require pressurization with HCF zero air or UHP nitrogen to provide sufficient pressure for
analysis. When such dilution is performed, the diluent gas must be collected in a separate
certified clean canister as a dilution blank (DB) and analyzed to ensure that the dilution process
does not contaminate collected samples.

The canister pressure must be measured with a calibrated pressure gauge or pressure transducer
just prior to dilution and immediately following dilution. A canister dilution correction factor
(CDCF) is calculated from the two absolute pressure readings as follows:

Pd

CDCF = y

where:

Pd = The pressure of the canister following dilution (psia)

Pi = The pressure of the canister immediately preceding dilution (psia)

Diluted canisters should be allowed to equilibrate minimally overnight, and preferably 24 hours
before analysis.

4.2.8	GC/MS Tuning, Calibration, and Analysis

4.2.8.1 Interferences. Moisture in the sample gas may interfere with VOC analysis by
GC/MS. Poor water management can cause peak broadening and retention time shifts resulting
in peak misidentification, particularly for hydrophilic polar compounds. Carbon dioxide in the
collected sample can coelute with more volatile VOCs and interfere with their quantitation. A
properly configured moisture management system (as discussed below) can reduce or eliminate
the interference of water and carbon dioxide.

Preconcentration systems employ moisture management techniques to eliminate most of the
water in the concentrated sample. Instrument manufacturers utilize different methods to manage
water removal as well as carbon dioxide such as extended cold trap dehydration (ECTD) or
microscale purge and trap (MPT) techniques.

ECTD removes most of the water in the sampled gas by passing the sample gas through an
empty first trap cooled to approximately -50°C. This low temperature immediately freezes the

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water and allows the VOCs to pass through to a second trap consisting of a weak adsorbent
where the VOCs are then trapped. To ensure complete transfer of the VOCs, the first trap is
warmed to just above the freezing point of water and a small volume of dry inert gas is employed
to sweep any higher boiling point VOCs to the second trap while retaining the water on the first
trap.8

MPT typically permits a larger amount of water to pass through to the second trap and ultimately
to the analytical column than ECTD, potentially resulting in peak broadening and retention time
shifts. For MPT, the first trap containing sorbent and/or deactivated glass beads is cooled to
approximately -160 to -110°C where all the water and VOCs are retained. The first trap is then
heated to several degrees above the freezing point of water and purged with dry inert gas to
sweep the VOCs to the second sorbent trap.8 The purge of the first trap at a higher temperature
may permit more water onto the column compared to ECTD.

Artifacts in chromatograms such as silanol compounds formed from the breakdown of fused
silica linings of canisters and siloxane compounds from the breakdown of the stationary phase in
an analytical column can interfere with quantitation of less volatile VOCs.

4.2.8.2 Specifications for the Preconcentrator and GC/MS. The analysis instrument must
employ detection via mass spectrometer (MS). The MS may be a quadrupole, ion trap, TOF
detector. Detection via flame ionization detector (FID) does not permit positive compound
identification. Flame ionization detection may be performed by way of splitting the column
effluent with the MS and quantitation can be performed from the FID signal. However due to
the non-specific nature of FID detectors, analytes must be qualitatively identified via the MS.

Sample introduction and concentration should be handled by an automated cryogenic
preconcentration system capable of cooling to as low as -190°C and capable of quantitatively
transferring target analytes to the GC column. For cryogenic systems, the target VOCs are
isolated from the whole air matrix by passage of the matrix onto a series of traps packed with
deactivated glass beads or with a polymer or graphitized sorbent; in some systems, water
management is performed by passage of the gas stream through a cryocooled, empty trap.
Typically the final step in the cryogenic preconcentration routine is to refocus the VOCs onto
another low-volume trap for introduction as a tight band onto the head of the GC column.

The GC should be temperature programmable with cryogenic cooling capabilities. VOCs should
be separated with a 60 m by 0.32 mm capillary column with 1 |im lining of 100%
dimethylpolysiloxane (e.g., DB-1), or with a column capable of separating the target analytes
and ISs so that method performance specifications are attained. The transfer line to the MS
should be capable of maintaining 200°C.

The MS detector is operated in electron ionization mode at 70 electron volt (eV) in full scan,
SIM, or SIM/scan mode. If operated in full scan or SIM/scan mode, the MS must be capable of
completing an entire scan in < 1 second. The MS must be capable of scanning from 45 to 250
atomic mass unit (amu) and producing a mass spectrum of BFB compliant with the ion
abundances listed in Table 4.2-2 (for instruments operating in SCAN or SIM/SCAN mode). For
laboratories performing analysis of lower molecular weight analytes such as acetonitrile (ACN),

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methanol, acetylene, etc., a lower MS scan range capable of 25 to 250 amu may be necessary.
Note that the lower scan range often increases the presence of low mass interferences in the
chromatogram.

Sample and standard introduction to the preconcentrator is preferably performed via autosampler
which allows connection of many canisters that permits unattended analysis of anywhere from
four to 16 or more canisters and permits unattended operation. Ports are also typically available
on the preconcentrator for internal standard and/or standard introduction.

4.2.8.3	Standards and Reagents

4.2.8.3.1	Calibration Standards. Stock calibration gases may be procured at
concentrations ranging from approximately 50 to 1000 ppb of each target VOC in UHP nitrogen.
Target VOCs in this concentration range are generally stable in high pressure passivated
cylinders for at least one year, although some vendors certify their mixtures for longer time
periods. Calibration gases should be recertified by the supplier or third party annually unless a
longer expiration period is assigned by the supplier. Alternatively, a new stock standard or set of
stock standard gases may be procured; however, this is typically several-fold more expensive
than recertification. Dilution of the stock calibration gas by approximately 400-fold permits
preparation of working range calibration standards in canisters at single digit ppb concentrations.

Off-the-shelf stock mixes are available containing approximately 65 target VOCs including the
NATTS core VOCs at 1 ppm, and gas mixtures with tailored compound lists and concentrations
are available as custom orders from certain suppliers. It may be necessary to procure multiple
stock gases to acquire all desired VOCs.

Calibration stock gases must be purchased from a supplier that provides a COA stating each
target VOC's concentration with associated uncertainty. An expiration must be assigned to each
standard gas mixture. Uncertainty of the certified concentrations must be specified as within no
more than ± 10%.

4.2.8.3.2	Secondary Source Calibration Standards. Secondary source stock
calibration gases must be procured from a separate supplier and meet the criteria listed above in
Section 4.2.10.3.1. A standard prepared with a different lot of source material from the same
supplier as the primary calibration stock is only acceptable if it is unavailable from another
supplier. As with the calibration stock gases, the secondary source stock must be recertified
annually.

4.2.8.3.3	Internal Standards. IS gases should be procured including a minimum of
three VOCs covering the early, middle, and late elution range of the target VOC elution order.
At minimum a single IS compound must be used. ISs must either be deuterated VOCs or VOCs
which behave chromatographically similarly to, but are not, target VOCs. Three typical VOCs
internal standards are 1,4-difluorobenzene, chlorobenzene-ds, and bromochloromethane.

IS stock gases are commercially available at 100 ppb in UHP nitrogen, or may be purchased with
a custom suite of compounds at desired concentrations. IS stock gases should be evaluated upon

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receipt for the presence of contaminants. Compounds whose response increases with an
increasing volume of IS analyzed are present in the IS mixture. IS gas standards which
contribute unacceptable levels of target VOCs, such that, for instance, system blanks fail
acceptance criteria, must not be employed for analysis and must be replaced. Typical
contaminants in IS mixtures include methylene chloride and carbon disulfide.

The IS must be added to and analyzed with each injection at the same concentration in order to
monitor instrument sensitivity and assess potential matrix effects. ISs are not added directly to
the sample canister, rather they are introduced through a different dedicated non-sample port in
the preconcentrator and trapped along with the sample aliquot on the first trapping module in the
preconcentrator. The concentration of IS added to each injection should be chosen such that the
IS compounds provide a peak which is onscale and approximates the area response of the highest
calibration standard.

4.2.8.3.4	Diluent Gases. Diluent gases may consist of zero air or UHP nitrogen.
Zero air is typically sourced from a zero air generator and may be further scrubbed by treatment
with activated carbon scrubbers or oxidizers. Zero air is also commercially available in
cylinders, however may be cost prohibitive to procure meeting cleanliness specifications or may
require further cleanup to remove impurities which affect analysis. Nitrogen gas must be from
an UHP source (purity > 99.999%) or from the headspace of a liquid nitrogen dewar. Regardless
of which gas is chosen as a diluent, it must be analyzed to demonstrate to verify that levels of
target VOCs are acceptably low (< 3x MDL or 0.2 ppb, whichever is lower). For diluent gas
contained within a cylinder or from discrete liquid nitrogen tanks, the gas must be analyzed prior
to preparing dilutions with the gas. For zero air generators or replenished onsite fixed liquid
nitrogen Dewars, the diluent gas must be analyzed monthly.

4.2.8.3.5	MS Tuning Standard — BFB. 4-bromofluorobenzene (BFB) may be
purchased as a standalone gas at approximately 30 to 100 ppb in UHP nitrogen or may be
purchased as a component in the IS mixture.

4.2.8.3.6	Reagent Water for Humidification of Gases. Reagent water for
humidification of gases must be ASTM Type I (> 18 MQcm). Additional purifying steps, such
as sonication, helium sparging, or boiling may be necessary to reduce or eliminate dissolved
gases potentially present in the water.

Humidification is most efficiently performed by bubbling the gas to be humidified through a
bubbler via a diptube submerged in the reagent water or passing the gas across the surface of the
reagent water via an impinger. Analysts should be aware of the potential for water to enter the
bubbler tube and be sucked into the gas supply tubing if the pressure downstream of the bubbler
becomes greater than the upstream pressure. Passing of the gas to be humidified through the
headspace of a vessel containing water typically achieves a RH of 20 to 30%, which is
insufficient to maintain the desired RH level of approximately 50% for serving as a diluent gas in
standards preparation or as a humidified blank. Laboratories should measure the RH of the
resulting humidified gas stream to ensure it reaches approximately 50%. If this RH level cannot
be reached with an inline humidification system, liquid water should be added to the canister.
Approximately 75 |iL of deionized water can be added to the canister to increase the RH to

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approximately 40-50% at room temperature and 30 psia. Adding water to canisters with a
syringe via rubber septum is not recommended, as the syringe needle can core the septum
resulting in deposits of rubber into the canister and valve, leading to later bias problems with the
canister. For direct injection of water into a canister with a syringe, a high pressure Teflon
sealed septum (such as a Merlin Microseal®) should be installed on the canister. For canisters
which are connected to a gas source for pressurization via a dynamic or static dilution system,
the water can be added to the valve opening prior to connecting the outlet tubing. Once the
tubing is connected, the valve is opened and the water is pulled into the canister along with the
diluted standard gas.

4.2.8.4 Preparation of Calibration Standards and Quality Control Samples

4.2.8.4.1 Calibration Standards. Working calibration standards are typically
prepared by diluting the calibration stock gas with humidified zero air by dynamic dilution or
calibrated automated static dilution. In these types of dilution, flows of the stock gas(es) and
diluent gas are carefully metered and the gases may be blended in a mixing chamber to ensure
complete mixing. Such systems are commercially available which permit the mixing of multiple
standard gases with a diluent gas. The homogenous, diluted gas mixture is then collected into a
cleaned canister. Working level concentrations are tailored to provide standards covering
approximately 0.1 to 5 ppb.

Calibration standard canisters may be prepared according to two conventions for calibrating the
GC/MS. The first convention consists of preparing a separate canister for each calibration
concentration level such that a total of five different calibration standard canisters are prepared to
establish the calibration curve with the required minimum five points. For this procedure, the
same volume is analyzed from each canister to establish the calibration curve. The second
convention consists of preparing two separate canisters at a low and high concentration.

Different volumes of each of the two canisters are analyzed to prepare the five-point calibration
curve. It is also acceptable to prepare the calibration curve by injecting different volumes from a
single canister provided the calibration curve is verified with an independent second source
quality control standard.

MFCs in dynamic dilution systems must be calibrated initially and the calibration verified
minimally quarterly. Mass flow controllers which fail the calibration check criterion of 2% must
be calibrated. Removal of the MFC from the dynamic dilution system to be calibrated by the
manufacturer is inconvenient and expensive. Instead, a regression calibration can be generated
by challenging the MFC with gas and recording the MFC setting and measuring the flow with a
flow calibrator for a minimum of five points covering the 10% to 100% of the flow range of the
MFC. The resulting regression slope and intercept is then employed to provide the MFC setting
for a given desired flow.

Dynamic dilution systems should be powered on and diluent and stock gases flowing through the
MFCs for minimally one hour prior to use. Warm-up flows should be the desired settings
necessary to prepare the working calibration standards. This warm-up period allows passivation
and equilibration of gases to ensure the concentration of the blended gas is stable prior to
transferring to the canister. When changing stock gas flow rate to prepare a different

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concentration, calibration gas should flow through the system for a minimum of 30 minutes prior
to preparation of the working calibration canister. These warm-up and equilibration times are
particularly important for laboratories analyzing compounds with higher boiling points such as
hexachlorobutadiene and 1,2,4-trichlorobenzene. Extended equilibration times may be necessary
to fully passivate the flow path and mixing chamber of the dynamic dilution system when these
compounds are desired.

Note that final pressures of calibration standard canisters must not exceed the maximum pressure
permitted by the preconcentrator unit. Closely matching the pressure of the calibration standard
canisters to the expected pressure of the collected field samples is recommended when analysis is
performed with preconcentrators that measure volumes with MFCs. Consult the preconcentrator
instrument manual for further guidance on matching canister pressures.

The preferred procedure for preparing calibration standards is dynamic dilution; however, static
dilution by way of syringe injection of calibration stock gases may also be employed. Syringe
dilution requires excellent technique to accurately and reproducibly prepare calibration
standards.

Calibration standard canisters must be humidified to approximately 50% RH by either
humidifying the diluent or by addition of liquid water to the canister. For diluent gases which
are humidified to approximately 25% RH, approximately 100 |iL of reagent water should be
added to the canister prior to pressurization with standard gas to approximately 30 psia. For
standard canisters prepared at lower pressures, a smaller volume of water should be added.
Standard canisters must be allowed to equilibrate minimally overnight (recommended 24 hours)
before analysis.

4.2.8.4.2	Second Source Calibration Verification Sample. A second source
calibration verification (SSCV) is prepared in a canister at approximately the mid-range of the
calibration curve by dilution of the secondary source stock standard. The SSCV verifies the
accuracy of the calibration curve. The SSCV must minimally contain all Tier I core compounds
and it is recommended that the SSCV also contain at least one compound representative of each
type of compound in the calibration (e.g. low molecular weight, chlorinated, fluorinated,
brominated, high molecular weight, etc.). It is strongly recommended that the SSCV contain all
compounds in the calibration mix.

4.2.8.4.3	Method Blank. The MB canister is prepared by filling a cleaned canister
with humidified diluent gas. For laboratories using a dilution system (dynamic or automated
static), the method blank should be pressurized with the dilution system. The MB verifies the
diluent gas is sufficiently clean. To best represent canisters which are sent to the field for sample
collection, the MB should be prepared in a clean canister which was verified by batch blank
analysis. Analysis of a canister cleaning batch blank as the MB complicates the corrective action
process to locate the source if the MB canister analysis indicates contamination.

4.2.8.4.4	Laboratory Control Sample. The LCS is prepared at approximately the
lower third of the calibration range by dilution of the calibration stock gas. While not required,
preparation and analysis of the LCS is recommended. The LCS may serve as the CCV and the

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volume of LCS analyzed should be the same volume as that taken from sample canisters for
routine analysis. The LCS serves to both verify that calibration standards were prepared
correctly and that the instrument remains in calibration.

4.2.8.5 A nalysis via GC/MS

4.2.8.5.1 Tuning of the MS. Prior to initial calibration and every 24 hours of
analysis thereafter, the MS tune of quadrupole MS detectors must be verified to meet the
abundance criteria in Table 4.2-2 by injection and analysis of approximately 50 ng of BFB when
operating in SCAN or simultaneous SIM/SCAN mode.

Failure to meet the BFB tuning criteria requires corrective action which may include adjusting
MS tune parameters or cleaning of the ion source. The instrument must be recalibrated
following adjustments or maintenance which impacts the MS tune.

To the extent possible for ion trap and TOF MS detectors, tune the MS such that the m/z
abundance sensitivities are maximized for the lower mass range, m/z < 150. TOF and ion traps
should be tuned per the manufacturer specifications.

Table 4.2-2. Required BFB Key Ions and Ion Abundance Criteria

Mass (m/z)

Ion Abundance Criteria *

50

8.0 to 40.0% of m/z 95

75

30.0 to 66.0% of m/z 95

95

Base peak, 100% relative abundance

96

5.0 to 9.0% of m/z 95 (see note)

173

Less than 2.0% of m/z 174

174

50.0 to 120.0% of m/z 95

175

4.0 to 9.0% of m/z 174

176

93.0 to 101.0 of m/z 174

177

5.0 to 9.0% of m/z 176

* All abundances must be normalized to m/z 95, the nominal base
peak, even though the ion abundance of m/z 174 may be up to
120% of m/z 95.

4.2.8.5.2 Leak Check and Calibration of the GC/MS
4.2.8.5.2.1 Leak Check

Prior to beginning an analytical sequence, including an initial calibration (ICAL) sequence, each
canister connection must be verified as leak-free through the preconcentrator. During the leak
check, canisters are connected to the autosampler or sample introduction lines and the canister
valves are kept closed. Each port of the autosampler or sample introduction line is evacuated
and the pressure monitored over 30 seconds or 1 minute for a change in pressure. Connections

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which show a pressure change of > 0.2 psi/minute or exceed manufacturer criteria must be
corrected by tightening the fittings. Leak check criteria in automated leak check routines should
be equivalent to or better than those listed above and should be prescribed in the analysis SOP.
Analysis must not be performed on any canister connection which does not pass the leak check.
Canisters which do not pass leak check may leak to atmospheric pressure allowing laboratory air
into the analyzed sample stream. Many preconcentration control software systems include a leak
check function which provides standard QC reports. Following the leak check all autosampler
ports or sample introduction lines are evacuated and the canister valves are opened. Leak checks
must be documented in the analysis records.

4.2.8.5.2.2 Initial Calibration of the GC/MS

The GC/MS instrument must be calibrated initially, following failure of CCV checks, and
following adjustments or maintenance which impact the performance of the GC/MS system
including, but not limited to: cleaning of the ion source, trimming or replacing the capillary
column, or adjustment of MS tune parameters.

The MS must meet BFB tune criteria listed in Section 4.2.10.5.1 before calibration may begin.
An instrument blank (IB) is recommended to be analyzed prior to analysis of calibration
standards to demonstrate the instrument is free of target VOCs and potential interferences. The
IB is an injection of carrier gas taken through the preconcentration steps without introduction of
sample gas into the preconcentrator. Analysis of the IB must show all target compounds are < 3x
MDL or < 0.2 ppb, whichever is lower.

The ICAL curve is prepared by analysis of different concentration levels covering approximately
0.03 to 5 ppbv. At minimum five levels must be included in the ICAL and more are
recommended, especially in the lower end of the calibration curve if the lowest standard
concentration is in the tens of pptv. Calibration curves may be established on the instrument by
two conventions. The first convention is to prepare a separate canister for each level of the
calibration curve and inject the same volume from each canister. The second convention
involves preparation of one to three canisters at different concentrations from which different
volumes are analyzed to establish the calibration curve. An example of this second convention
with two separate canisters follows:

For a typical analysis volume of 400 mL, an eight-point calibration curve is constructed
utilizing two standard canisters prepared at 0.25 ppbv and 5.0 ppbv. The curve is
established at 0.03, 0.05, 0.075, 0.1, 0.25, 0.75, 1.5, and 5.0 ppb by analysis of 48, 80,
120, 160, and 400 mL from the 0.25 ppb canister and analysis of 60, 120 and 400 mL
from the 5.0 ppb canister.

For measuring low (tens of pptv) levels of VOCs as is needed for ambient air analysis, it is
important to characterize the lower end of the calibration curve by loading the number of
calibration points toward the bottom of the curve (as shown in the example above). Including
more points in the lower end of the curve minimizes calibration error at the low end of the curve
as the upper end of the curve has an outsized influence on the curve model when calibration
levels are evenly distributed across the calibration range.

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When the second calibration convention is utilized (analyzing different volumes out of one to
three canisters), checking the calibration of the MFC quarterly is recommended to ensure
accurate volumes are metered for analysis.

Following analysis of all calibration standards, a calibration curve is prepared for each target
analyte by determining the relative response factor of each concentration level. Following data
acquisition for the calibration standards, the relative response factor (RRF) of each target
compound in each calibration level is determined as follows:

where:

As =	peak area for quantitation ion of the target compound

Ais =	peak area for quantitation ion of the assigned internal standard compound

Cs =	concentration of the target compound

Cis =	concentration of the assigned internal standard compound

If the method of RRFs is selected for construction of the calibration curve, the relative standard
deviation (RSD) of the RRFs for each Tier I Core target VOC must be < 30% and all other
compounds should meet this specification. For Tier II compounds which do not meet this
criterion, results should be qualified when reported to AQS. Alternatively, a calibration curve
may be prepared by linear or quadratic regression of the ratios As/Ais as the dependent variables
and the ratios Cs/Cis as the independent variables. The correlation coefficient for linear or
quadratic curves must be > 0.995 for target VOCs. Irrespective of the curve fit method selected,
the calculated concentration for each VOC at each calibration level must be within 30% of the
nominal concentration when quantitated against the resulting calibration curve. Exclusion of
calibration standard levels is not permitted unless justifiable (for example, a known error in
standard preparation). Sample analysis must not be performed, and if performed, results must
not be reported when calibration acceptance criteria are not met for Tier I core analytes. Rather,
corrective action, possibly including recalibration, must be taken.

Relative retention times (RRTs) are calculated for each concentration level of each target
compound by dividing the target compound retention time (RT) by the associated IS compound
RT. The RRTs of each target compound are then averaged to determine the mean RRT (RRT) of
the ICAL. RRT at each concentration level must be within ± 0.06 RRT units of RRT.

4.2.8.5.2.3 Secondary Source Calibration Verification

Following each successful initial calibration, a SSCV standard must be analyzed to verify the
ICAL. Each target VOC in the SSCV must recover within ± 30% of nominal or the RRF must
be within ± 30% of the mean ICAL RRF. Periodic reanalysis of the SSCV is recommended once
the ICAL has been established.

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4.2.8.5.2.4	Continuing Calibration Verification

Once the GC/MS instrument has met tuning and calibration criteria, a CCV must be analyzed
after every 24 hours of analysis immediately following the BFB tune check and is recommended
to be analyzed after every ten sample injections and at the end of each analytical sequence. Each
target VOC's concentration in the CCV must be within ± 30% of nominal or the RRF must be
within 30% of the average RRF from the ICAL. Corrective action must be taken to address CCV
failures, including, but not limited to, preparing and analyzing a new CCV, trimming or
replacing the column, retuning the MS, or preparing a new ICAL.

4.2.8.5.2.5	A nalysis of Laboratory QC Samples and Field Samples

The following laboratory QC samples are required with each analysis batch containing 20 or
fewer field-collected canisters:

-	MB

-	Replicate sample analysis

Each target VOC's concentration in the MBs must be < 3x MDL or < 0.2 ppb, whichever is
lower. The precision of the replicate analysis must be such that < 25% RPD is achieved for each
target VOC having a concentration > 5x MDL. Samples should be reanalyzed to confirm the out
of criteria result(s) and if confirmed, should be a trigger for corrective action. Sample data
associated with these failures must be qualified appropriately when reported to AQS.

An LCS is recommended to be analyzed with each analysis batch, and must recover within 70 to
130%.

4.2.8.5.3 Compound Identification. Four criteria must be met in order to positively
qualitatively identify a target compound:

1.	The signal-to-noise ratio of the target and qualifier ions must be > 3:1, preferably
> 5:1.

2.	The target and qualifier ion peaks must be co-maximized (peak apexes within one
scan of each other).9

3.	The RT of the compound must be within the RT window as determined from the
ICAL average.

4.	The abundance ratio of the qualifier ion response to target ion response for at least
one qualifier ion must be within ± 30% of the average ratio from the ICAL.

Please refer to Figure 4.2-2 for an example of the qualitative identification criteria listed above
and the following discussion. The RT is within the retention time window defined by the
method (red box A), and the abundance ratios of the qualifier ions are within 30% of the ICAL
average ratio (red box B). The signal-to-noise ratio of the peak is shown to be greater than 5:1
(red oval C) and the target and qualifier ion peaks are co-maximized (dotted purple line D).

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Abundance Scan 1043 (7.660 mini: 03191404.D\data.ms (-1032) (-)
84

RefSO

O'll FflHl | I N l|'fl II |l II I | II II | I II I | II II |, M I | II II ! > I I I | H M | I II l| M I, | I II I |

m/z-> 40 60 80 100120140160180200220240260280300

Abundance

102

175

Rawi

50

49

84

84

100





49

141.1

97 . 9

181. 7

86

64 .1

45 . 1

83.7

„ bl.ll i 107 133 163 198 227247 282 308

U M I pTll \1 I'l I |" I'l I I I III | I I ff | I I I ¦ I I I I I | I III | 11 11 | I 1 I 11 11 I I I IIII | I I I I | I I I I I

m/z—> 40 60 80 100120140160180 200 220 240 260 280300

Abundance

Sub,

50

49

84

107 133 163 198 227247	308

U^n-tfrrt Tyrm-fl mrprrrpn 1-pTrrpTTi-pTTT fn-rrp-iTTp-i ,, |,, I 11 , >., ,, fr-rj-

m/z-> 40 60 80 100120140160180 200220240260 280 300

#19

methylene chloride
Concen: 0.94 ppb
tii-in

I Delta R.T. 0.015 min

L041

Lab File: 09141501.D f\
Acq: 14 Sep 2015 1:33 pm

Tgt Ion: 84 Resp: 65009

B

Abundance
30000

20000

10000

0-,

\

Time-> 7.50

Figure 4.2-2. Qualitative Identification of GC/MS Target Analytes

Please refer to Figure 4.2-3 for the following example for determining the signal-to-noise ratio.
To determine signal-to-noise, the characteristic height of the noise of the baseline (A) just before
the peak and the height of the analyte peak (B) are measured. The ratio of the analyte peak
height (B) is divided by the noise height (A) to calculate the S:N ratio. In the example below,
the peak at 17.0 minutes is discernable from the noise, but is not well-resolved and is very close
to a S:N of 3. In the example, the peak heights of the noise and analyte peak (at approximately
17.0 minutes) are approximately 700 units and 1700 units, respectively, for a S:N of 2.4.

Determination of the S:N is somewhat subjective based on the individual analyst and their
characterization of the noise and analyte peak. Some chromatography systems include S:N
functions which require the analyst to assign the noise and target peak. For well-resolved peaks,
the S:N will greatly exceed 5:1, and does not need to be measured. For peaks with low S:N that
are questionable as to whether they meet the criteria in item #1 above, the 3:1 S:N criterion is a
guideline; it is unnecessary to measure each peak, rather the experienced analyst's opinion
should weigh heavily on whether the peak meets the S:N criterion.

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As with the S:N determination, evaluation of whether target and qualifier ion peaks are co-
maximized does not need to be rigorously evaluated with each peak. Rather the interpretation of
the experienced analyst should weigh heavily on whether the qualifier ion peaks are co-
maximized with the target ion. Items 3 (retention time) and 4 (relative ion abundances) above
may be automated by the analysis software such that they are automatically flagged. It is
important that the RT windows and ion abundances be updated with each new ICAL.

If any of these criteria are not met, the compound may not be positively identified. The only
exception to this is when in the opinion of an experienced analyst the compound is positively
identified. The rationale for such an exception must be documented.

4.2.8.5.4 Internal Standards Response. The response of the ISs must be monitored
for each injection (except for the instrument blank immediately preceding the ICAL or daily
CCV). Area responses of each IS must be within ± 40% of its mean area response in the five-
point ICAL. Each IS must elute within 0.33 minutes of its average RT from the five-point ICAL.

Note: Comparing the IS response to the most recent CCV is not appropriate as this permits the
IS response to drift by as much as 64% from the five-point ICAL before corrective action is
necessary. For example, if the average IS response in the ICAL is 10000 area counts, the CCV
IS response may decrease to as low as 6000 area counts (a decrease of -40% from the five-point
ICAL average) and still meet criteria. Comparing sample IS response to this CCV permits the IS
to drift as low as 3600 area counts (a decrease of -40% from the CCV response), a drift of -64%
from the five-point ICAL average IS response.

The IS response tends to decrease over time as the MS ion optics age and become dirty. If an IS
response is nonconformant and appears to be isolated to a specific sample, the possibility of a
matrix interference should be investigated by analysis of a smaller volume of the air sample. If
an IS response in the dilution remains nonconformant, corrective action should be taken which

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may include investigating problems with the preconcentrator, autosampler, or other parts of the
sample introduction path. The MS tune should also be evaluated for a degradation or
enhancement of sensitivity.

4.2.9 Data Review and Concentration Calculations. Each chromatogram must be
closely examined to ensure chromatographic peaks are appropriately resolved and integration
does not include peak shoulders or inflections indicative of a coelution.

The concentrations of target compounds detected in the analyzed aliquot are quantitated by
relating the area response ratio of the target compound and assigned IS in the unknown sample to
the average RRF (RRF) of the initial calibration curve as follows:

r _ At ¦ CIS
D ~ AIS ¦ RRF

where:

Cd = instrument detected analyte concentration (ppb)

At = area response of the target compound quantitation ion

Cis = concentration of assigned internal standard (ppb)

Ais = area response of the assigned internal standard quantitation ion

RRF = average relative response factor from the initial calibration

If a smaller aliquot was analyzed from the sample canister than the typical analysis volume, an
instrument dilution correction factor (IDCF) must be calculated:

where:

IDCF =

Vinj

Vnom = nominal volume of sample injected (typical volume analyzed)

Vinj = reduced volume of the sample injected

The final in air concentration (Cf) of each target compound is determined by multiplying the
instrument detected concentration by the canister dilution correction factor and the instrument
dilution correction factor:

CF = CD ¦ CDCF-IDCF

where:

Cf =	concentration of the target compound in air (ppb)

CDCF = canister dilution correction factor
IDCF = instrument dilution correction factor

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MDLs reported with the final concentration data must be corrected by multiplying the MDL by
the canister and instrument dilution correction factors applied to the sample concentrations. For
example, if the benzene MDL is 0.0091 ppbv for an undiluted sample and the sample was diluted
by 2.5, the MDL becomes 0.023 ppbv.

4.2.10 Summary of Quality Control Parameters. A summary of QC parameters is shown
in Table 4.2-3.

Table 4.2-3. Summary of Quality Control Parameters for NATTS VOCs Analysis

Parameter

Description and Details

Required Frequency

Acceptance Criteria

Instrument Blank (IB)

Analysis of swept carrier gas
through the preconcentrator to
demonstrate the instrument is
sufficiently clean to begin analysis

Prior to ICAL and daily
beginning CCV

Each target VOC's
concentration < 3x MDL or
0.2 ppb, whichever is lower

BFB Tune Check

50 ng injection of BFB for tune
verification of quadrupole MS
detector

Prior to initial calibration
and every 24 hours of
analysis thereafter

Abundance criteria listed in
Table 4.2-2

Initial Calibration
(ICAL)

Analysis of a minimum of five
calibration levels covering
approximately 0.1 to 5 ppb

Initially, following failed
BFB tune check, failed
CCV, or when
changes/maintenance to
the instrument affect
calibration response

Average RRF < 30% RSD
and each calibration level
must be within ± 30% of
nominal

For quadratic or linear
curves, r> 0.995, each
calibration level must be
within ± 30% of nominal

Secondary Source
Calibration
Verification (SSCV)

Analysis of a secondary source
standard at the mid-range of the
calibration curve to verily ICAL
accuracy

Immediately after each
ICAL

Recovery within
± 30% of nominal or RRF
within ±30% of the mean
ICAL RRF

Continuing
Calibration
Verification (CCV)

Analysis of a known standard at
the mid-range of the calibration
curve to verily ongoing instrument
calibration

Following each daily
BFB tune check and
every 24 hours of
analysis; recommended
after each ten sample
injections and to
conclude each sequence

Recovery within
± 30% of nominal or RRF
within ±30% of the mean
ICAL RRF

Canister Cleaning
Batch Blank

A canister selected for analysis
from a given batch of clean
canisters to ensure acceptable
background levels in the batch of
cleaned canisters

One canister from each
batch of cleaned
canisters - Canister
chosen must represent no
more than 10 total
canisters.

Each target VOC's
concentration < 3x MDL or
0.2 ppb, whichever is lower
(All Tier I Core analytes
must meet this criterion)

Internal Standards
(IS)

Deuterated or not naturally
occurring compounds co-analyzed
with samples to monitor
instrument response and assess
matrix effects

Added to all calibration
standards, QC samples,
and field-collected
samples

Area response for each IS
compound within
± 40% of the average
response of the ICAL

Preconcentrator Leak
Check

Pressurizing or evacuating the
canister connection to verify as
leak-free

Each standard and
sample canister
connected to the
instrument

< 0.2 psi change/minute or

manufacturer

recommendations

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Table 4.2-3. Summary of Quality Control Parameters for NATTS VOCs

Analysis (Continued)

Parameter

Description and Details

Required Frequency

Acceptance Criteria

Method Blank (MB)

Canister filled with clean diluent
gas

One with every analysis
batch of 20 or fewer
field-collected samples

Each target VOC's
concentration < 3x MDL or
0.2 ppb, whichever is lower

Laboratory Control
Sample (LCS)

Canister spiked with known
amount of target analyte at
approximately the lower third of
the calibration curve

(Recommended) One
with every analysis batch
of 20 or fewer field-
collected samples

Each target VOC's recovery
must be 70 to 130% of its
nominal spiked amount

Duplicate Sample

Field sample collected through the
same inlet probe as the primary
sample

10% of primary samples
for sites performing
duplicate sample
collection (as prescribed
in workplan)

Precision < 25% RPD of
primary sample for
concentrations
> 5xMDL

Collocated Sample

Field sample collected through a
separate inlet probe from the
primary sample

10% of primary samples
for sites performing
collocated sample
collection (as prescribed
in workplan)

Precision < 25% RPD of
primary sample for
concentrations
> 5xMDL

Replicate Analysis

Replicate analysis of a field-
collected sample (chosen by
analyst)

Once with every analysis
sequence (as prescribed
in workplan)

Precision < 25% RPD for
target VOCs with
concentrations
> 5xMDL

Retention Time (RT)

RT of each target compound and
internal standard

All qualitatively
identified compounds
and internal standards

Target VOCs within
± 0.06 RRT units of mean
ICALRRT

IS compounds within
± 0.33 minutes of the mean
ICALRT

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4.2.11	References

1.	Spicer, C. W., S. M. Gordon, et al. (2002). Hazardous Air Pollutants Handbook:
Measurement Properties, and Fate in Ambient Air. Boca Raton, Lewis Publishers.

2.	Determination of Volatile Organic Compounds (VOCs) in Air Collected in Specially
Prepared Canisters and Analyzed by Gas Chromatography/Mass Spectrometry (GC/MS);
EPA Compendium Method TO-15; U.S. Environmental Protection Agency: 1999. Available
at (accessed October 19, 2016):

https://www3 .epa.gov/ttnamti 1/files/ambient/airtox/to-l 5r.pdf

3.	Standard Operating Procedures for the Determination of Acrolein and other Volatile Organic
Compounds (VOCs) in Air Collected in Canisters and Analyzed by Gas Chromatography/
Mass Spectrometry (GC/MS), U.S. Environmental Protection Agency, Office of Air Quality
Planning & Standards, Research Triangle Park, NC, November 2006.

4.	Herrington, J.S.: Storage Stability of 66 Volatile Organic Compounds (VOCs) in Silicon-
Lined Air Canisters for 30 Days. Literature Catalog # EVAN2066-UNV, Restek Corporation.
2015. Available at (accessed October 19, 2016):
http://www.restek.com/pdfs/EVAN2066-UNV.pdf

5.	McClenny, W.A.; Schmidt, S.M.; Kronmiller, K.G. Variation of the Relative Humidity of
Air Released from Canisters After Ambient Sampling. In Proceedings of the Measurement of
Toxic and Related Air Pollutants International Symposium, Research Triangle Park, NC,

1997.

6.	Restek Technical Guide: "A Guide to Whole Air Canister Sampling. Equipment Needed
and Practical Techniques for Collecting Air Samples." Literature Catalog # EVTG1073A.
Available at (accessed October 19, 2016): http://www.restek.com/pdfs/EVTG1073A.pdf

7.	EPA NATTS Proficiency Testing Results Calendar Year 2016 Quarter 1 - Referee Results
from EPA Region V

8.	Entech Application Guide: "3-Stage Preconcentration is Superior for TO-14A and TO-15 Air
Methods." August 25, 2015. Available at (accessed October 19, 2016):

http ://www. entechinst. com/3 -stage-preconcentrati on-i s-superior-for-to-14a-and-to-15 -air-
methods/#

9.	Identification and Confirmation of Chemical Residues in Food by Chromatography-mass
Spectrometry and Other Techniques. Lehotay, S. J., et al, TrAC Trends in Analytical
Chemistry. December 2008. pp. 1070-1090


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4.3	Carbonyl Compounds via EPA Compendium Method TO-11A

Each agency must codify in an appropriate quality systems document, such as an SOP, or
equivalent, its procedures for collection of airborne carbonyls onto cartridges, extraction of the
cartridges, and analysis of the extracts. Various requirements and best practices for such are
given in this section. Note that regardless of the specific procedures adopted, method
performance specifications as given in Section 4.3.10 must be met.

4.3.1 General Description of Sampling Method and Analytical Method. Carbonyl
compounds such as aldehydes and ketones may be collected and analyzed via EPA Compendium
Method TO-11 A. The atmosphere to be characterized is drawn at a known flow rate for a known
duration of time through an ozone denuder and through a sorbent cartridge coated with DNPH,
where the carbonyl compounds react with the DNPH and are derivatized to form carbonyl-
hydrazones. These carbonyl-hydrazones are solids at typical ambient temperatures and are
retained on the cartridge sorbent bed until eluted with acetonitrile (ACN). Eluted extracts are
analyzed by HPLC with a UV detector at a wavelength 360 nm.1

The carbonyls including, but not limited to, those in Table 4.3-1 may be determined by this
method.

Table 4.3-1. Carbonyl Target Compounds and Associated Chemical
Abstract Service (CAS) Number via Method TO-11A

Target Carbonyl

CAS#

acetaldehyde ab

75-07-0

acetone

67-64-1

benzaldehyde b

100-52-7

butyraldehyde

123-72-8

crotonaldehyde

4170-30-3

2,5 -dimethylbenzaldehyde

5779-94-2

formaldehyde ab

50-00-0

heptaldehyde

111-71-7

hexaldehyde

66-25-1

isovaleraldehyde

590-86-3

m&p-tolualdehyde

(m) 620-23-5/(p) 104-87-0

methyl ethyl ketone

78-93-3

methyl isobutyl ketone

108-10-1

o-tolualdehyde

529-20-4

propionaldehyde b

123-38-6

valeraldehyde

110-62-3

a NATTS required core analytes
b NATTS PT analytes

4.3.2 Minimizing Bias. The sampling of airborne carbonyls onto DNPH cartridges is
potentially affected by a variety of interferences. For example, nitrogen oxides react with the
DNPH derivative to form compounds which may coleute with carbonyl-hydrazone derivatives.
Moreover, ozone reacts with DNPH to form possible coeluting interferences and also reacts with
and causes negative bias in the measurement of various carbonyl-hydrazones. (More
information on ozone management is given in Section 4.3.4.) To minimize introduction of

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contamination and to keep bias to a minimum, manage ozone per Section 4.3.4 and handle
cartridges as in Section 4.3.5.2. Clean labware and select high-purity reagents as in
Section 4.3.9.

The cartridge inlet and outlet caps must be installed when the cartridge is not in use so as to
isolate it from the ambient atmosphere where carbonyl compounds and interfering compounds
may be passively sampled. Further, cartridges must be stored sealed in the foil pouch or similar
opaque container, as light may degrade the DNPH derivatives. Finally, DNPH cartridges must
be stored at < 4°C after sampling as such slows the reaction of contaminants. Cartridges should
only be handled while wearing powder-free nitrile or vinyl gloves.

4.3.3 Carbonyls Precision

4.3.3.1 Sampling Precision. Depending on the configuration of the sampling unit or units at
the monitoring site, sampling precision may be assessed by way of the collection and analysis of
collocated or duplicate cartridges. Sampling precision is a measure of the reproducibility in the
sampling, handling, extraction, and analysis procedures. Monitoring agencies are encouraged to
collect collocated and duplicate samples. For monitoring agencies collecting collocated and/or
duplicate samples (as detailed in each site's workplan), they must be collected at a minimum
frequency of 10% of primary samples.

4.3.3.1.1 Collocated Sample Collection. A collocated sample is a sample for which
air is drawn through a co-collected cartridge from an independent inlet probe via a separate
discrete sampling unit. If two cartridges are collected together with a single sampling
instrument, to be collocated the air passing onto each cartridge must flow through wholly
separate channels, where each channel must have a discrete inlet probe, plumbing, pump, and
flow controller such as an MFC or rotameter. For sites which employ a manifold inlet to which
one or more carbonyl sampling unit inlets is connected, samples co-collected with the primary
sample will be designated as duplicate, as shown in Figure 4.3-1.

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COLLOCATED

standalone inlet probes

sampling unit
A

sampling unit
B

manifold A

manifold B





sampling unit
A

sampling unit
B



DU PLICATE

Figure 4.3-1. Collocated and Duplicate Carbonyls Sample Collection

More information on collocated samples is given in Section 4.3.8.2.3.

4.3.3.1.2 Duplicate Sample Collection. Duplicate sampling assumes that both the
primary and duplicate sampling inlets are connected to the same inlet probe to the atmosphere
whether connected to a manifold or a standalone inlet probe.

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A duplicate sample may be collected, for example, by splitting (with a tee, or similar) the
primary sample flow path onto two separate cartridges, where each cartridge has its own discrete
and separate flow channel and/or flow control device (MFC, orifice, or rotameter) located within
a single sampling unit.

More information on duplicate samples is given in Section 4.3.8.2.4.

4.3.3.2 Laboratory Precision. Laboratory precision for field-collected carbonyls cartridges
is limited to replicate analysis of a single extract. Each DNPH cartridge is extracted as a discrete
sample which does not permit assessing precision through the extraction process. Replicate
analysis of a given extract is required with each analysis sequence and must show < 10% RPD
for concentrations >0.5 |ig/cartridge.

Precision incorporating both the extraction and analysis procedures may be assessed by
preparation, extraction, and analysis of duplicate LCSs. An LCS and LCS duplicate (LCSD)
must be prepared minimally quarter, and are recommended with each extraction batch at a
concentration in the lower third of the calibration range. The LCS/LCSD pair must show
precision of < 20% RPD.

4.3.4 Managing Ozone. Ozone is present in the atmosphere at various concentrations
ranging from approximately 20 ppb at rural sites to as much as 150 ppb at peak times in urban
environments. Ozone is a strong oxidant and may impact the sampling and analysis in various
ways. Ozone which is not removed from the sampled air stream may react directly with the
DNPH reagent thereby making the DNPH unavailable for derivatizing carbonyl compounds.
Ozone may also react with carbonyl-hydrazones on the sampled cartridge to degrade these
compounds, leading to underestimation of carbonyl concentrations. These degradation
byproducts may also be difficult or impossible to separate chromatographically from desired
target compounds, resulting in overestimation or false positive detection of target compounds.

In order to mitigate the impact of ozone on carbonyl measurements, an ozone denuder/scrubber
must be installed in the sampling unit flow path upstream of the DNPH cartridge(s). Typically,
the removal of ozone by potassium iodide (KI) is effected by the oxidation of the iodide ion to
iodine in the presence of water, as follows:

O3 —> 02 + 0

+ 2KI + H20 + 0 -> 2KOH + I2
03 + 2KI + H20 -> I2 + 02 + 2KOH

Several different KI ozone scrubbers are described in the following sections. For the NATTS
program, ozone must be removed during the collection of carbonyls with the denuder in
Section 4.3.4.1.

4.3.4.1 Copper Tubing Denuder/Scrubber. Method TO-11A describes an ozone
denuder/scrubber and this is the preferred ozone removal method for the NATTS program. The
scrubber is fashioned from coiled copper tubing whose interior has been coated with a saturated
KI solution and which is heated to approximately 50°C or above to eliminate condensation.

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Heating prevents the deposition of liquid water to the denuder walls which may both dissolve the
KI coating and may clog the silica gel pores in the DNPH cartridge with KI as it recrystallizes.
As this type of scrubber/denuder operates via titration, its efficacy over time is related to the
amount of deposited KI, the total volume of sampled air, and the average ozone concentration of
the sampled air. In general, it is presumed that this type of denuder/scrubber should be effective
for up to 100,000 ppb-hours at flow rates of less than 1 L/minute.1 A study not yet published at
the time of this TAD's release has found that such copper tubing ozone scrubbers are effective
for the 100,000 ppb-hours cited in TO-11 A; they were able to efficiently remove 150 ppb O3
over 30 consecutive days when operated at a flow rate of 1 L/min at relative humidities ranging
from 10 to 85% at a nominal temperature of 25°C.2 Given an average ozone concentration of
approximately 70 ppb, this type of denuder/scrubber should effectively scrub ozone from the
sampled air stream for all 61 annual 24-hour samples required by the NATTS Program without
depleting the KI reagent. If the average concentration of ozone is greater than 70 ppb over the
course of the year or the sampling frequency is increased from one-in-six days, or if duplicate
sampling is performed more frequently than every other month such that the flow rate through
the denuder is doubled during most sampling events (thereby exposing the scrubber to twice the
burden of ozone), the life span of the KI denuder/scrubber will be proportionately reduced.

The denuder/scrubber must be replaced or recharged with KI minimally annually to ensure there
is sufficient KI substrate to eliminate co-sampled ozone; they should also be recharged if ozone
breakthrough is observed as decomposition products of O3 attacking the DNPH and the
formaldehyde hydrazone derivative (see reference 1 for more information). Denuders are
commercially available or they may be recharged by recoating the copper tubing with a saturated
solution of KI in deionized water (144 grams KI in 100 mL deionized water). The solution is
maintained inside the copper tubing for minimally 15 minutes (some agencies suggest 24 hours
or more), then the solution drained. The emptied tubing is then dried by a gentle stream of dry
UHP nitrogen for minimally one hour.

When a sampling instrument is removed from service for recharging the KI denuder/scrubber
and/or for calibration/maintenance, a best practice is to challenge the denuder with ozone at
120% of the maximum measured ozone concentration for several hours and measure the
resultant downstream concentration. Such will demonstrate the ozone scrubber's efficacy prior
to removal from the field. For denuders shown to be less than fully effective upon removal from
the field, defined as downstream ozone concentration >10 ppb or a breakthrough > 5%,
chromatograms from recent sampling events should be examined for indications of ozone
interference. Following recharge/replacement of the KI denuder/scrubber, the 120% ozone
concentration challenge should be repeated to demonstrate effective ozone removal prior to its
deployment for field use. The zero challenge of the sampling unit prescribed in Section 4.3.7.1.1
must be performed following recharging of the denuder/scrubber.

4.3.4.2 Sorbent Cartridge Scrubbers. Sorbent cartridges, such as silica gel, coated with KI
are commercially available, but their use is not permitted due to their sorption of water vapor.
Sampling in humid environments results in the sorbent bed becoming saturated with water,
resulting in clogging of the cartridge substrate which substantially reduces or eliminates sample
flow. While inexpensive and convenient for use, sorbent bed KI cartridges must not be
employed for the NATTS Program sampling.

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4.3.4.3 Other Ozone Scrubbers. Agencies may opt to develop custom-made KI ozone
scrubber/denuders. The efficiency of ozone removal must be demonstrated for such custom
systems. To demonstrate efficiency of ozone removal, the homemade scrubber/denuder must be
challenged over a contiguous 24-hour period with a minimum of 100 ppb ozone at the flow rate
for the carbonyl instrument sampler (typically approximately 1 L/min) and demonstrate
breakthrough of < 5%. Agencies must also quantify the capacity of such scrubbers (for example,
in ppb-hours) and with such data they must determine and codify in their quality system the
minimum required recharge/replacement frequency of the scrubbers.

4.3.4.3.1	Cellulose Filter Ozone Scrubbers. The California Air Resources Board
(CARB) removes ozone with cellulose filters coated with KI on the RM Environmental Systems
Incorporated 924 and Xonteck 924 sampling units. These samplers are standalone and not
installed in a separate shelter, so do not allow the ready installation of a heated copper tubing
ozone scrubber. The DNPH cartridge is installed in close proximity (several millimeters) from
the inlet probe, which is open to the atmosphere. The Kl-coated filter is installed at the inlet
probe, just upstream of the DNPH cartridge.

4.3.4.3.2	ModifiedDasibi™ Ozone Scrubber. In the Dasibi™ scrubber fifteen 2-
inch diameter copper mesh screens are arranged in a stacked formation. The magnesium oxide
coated screens provided with the unit are exchanged for copper screens which are coated with
KI. To coat the screens, they are immersed in a saturated KI solution in deionized water and air
dried. The coated screens are assembled in the Dasibi enclosure with a fiberglass particulate
filter at each end, the O-rings installed, and the enclosure secured with the supplied screws. This
procedure imparts approximately 4 mmoles or 700 mg of KI over the fifteen 2-inch diameter
screens. With this mass of KI, the scrubber should effectively remove ozone for approximately
300 sampling dates assuming 24 hours of sampling at 1 L/minute with ozone concentrations of
100 ppb.

In order to ensure that condensation does not impact the scrubber's performance, it should be
maintained at a minimum temperature of 50°C.

4.3.5 Collection Media. EPA Compendium Method TO-11A specifies DNPH-coated
silica gel sorbent cartridges for the collection of carbonyl compounds from ambient air. These
DNPH cartridges may be prepared in house or purchased from commercial suppliers. Most
NATTS sites utilize one of two commercial brands of media, specifically the Waters
WAT037500 or Supelco S-10 cartridges. These cartridges are specified to meet the background
criteria of TO-11A and typically exhibit proper flow characteristics. Examination of background
concentrations and proficiency test data do not indicate an obvious difference in the performance
between the two brands of cartridges. Laboratories may prepare DNPH cartridges in house;
however, preparation is a time- and labor-intensive process which requires meticulous detail to
cleanliness to ensure the resulting media are contaminant-free. The expense and resources
involved in preparation of DNPH media in house is generally greater than the cost of purchasing
commercially-available DNPH cartridge media. Regardless of the type of cartridge selected, the
method performance specifications in Section 4.3.10 must be met.

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4.3.5.1 Lot Evaluation and Acceptance Criteria. For each lot or batch of
purchased or prepared DNPH cartridge, a representative number of cartridges must be analyzed
to demonstrate that the lot or batch is sufficiently free of contamination. Most commercially-
available DNPH cartridges are accompanied by a COA indicating the lot or batch background of
various carbonyls. While a COA provides a level of confidence that the lot or batch is
sufficiently clean, laboratories must verify the background levels of carbonyls in each batch or
lot of cartridges.

For commercially-purchased cartridges, a minimum of three cartridges, or 1% of the total lot,
whichever is greater from each lot or batch, must be extracted and analyzed. For cartridges
prepared in house, a minimum of three cartridges per each preparation batch must be extracted
and analyzed. Each cartridge tested in the lot or batch must meet the criteria listed in
Table 4.3-2. Ongoing analysis of method blanks permits continual assessment of the lot's
contamination levels.

Additionally, agencies may elect to perform flow evaluations of the lot(s) to ensure cartridges do
not overly restrict sampling flows.

Table 4.3-2. Maximum Background per Lot of DNPH Cartridge

Carbonyl Compound

Not-to-Exceed Limit (ng/cartridge)

Acetaldehyde

<0.10

Formaldehyde

<0.15

Acetone a

<0.30

Other Individual Target Carbonyl Compounds

<0.10

a Acetone is not a target compound and should not be grounds for lot disqualification unless it interferes with

other target analytes in the chromatogram.

If any cartridge tested exceeds these criteria, an additional three cartridges, or 1% of the total lot,
whichever is greater, must be tested to evaluate the lot. If the additional cartridges meet the
criteria, the lot or batch is acceptable for sampling. If any of the additional cartridges fail
criteria, the lot or batch must not be used for NATTS sampling and should be returned to the
provider.

4.3.5.2 Cartridge Handling and Storage. DNPH sampling cartridge media are typically
shipped unrefrigerated by the supplier. DNPH cartridges must be stored refrigerated at < 4°C
upon receipt. Unsampled cartridges must be maintained sealed in their original packaging and
protected from light (foil pouch or similar opaque container) until installed for sample collection
or prepared as QC samples as light may degrade the DNPH derivatives. Cartridges which are
not stored appropriately may suffer from degradation of the DNPH reagent and may show
increased levels of contaminants from passive sampling of target compounds and interferants.

DNPH cartridges should only be handled by staff wearing powder-free nitrile or vinyl gloves or
equivalent. Measures must be taken to avoid exposure of DNPH cartridges (unsampled or
collected samples) to exhaust fumes, sunlight, elevated temperatures, and laboratory
environments where carbonyl compounds such as acetone may contaminate sampling media.

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As soon as possible after sample collection, cartridges must be capped (if caps are provided),
sealed in the foil pouch (to protect from light and the ambient atmosphere), and transported
(shipped) and stored refrigerated at < 4°C. Cartridges must be transported in coolers with ice,
freezer packs, or equivalent method for providing refrigeration during transport to and from the
laboratory. Monitoring the shipping temperature with a calibrated min-max type thermometer is
a best practice.

4.3.5.3	Damaged Cartridges. DNPH cartridges are susceptible to water damage and to
physical damage. Unused or sampled cartridges, including blanks, must not indicate clumping of
the silica gel sorbent which is indicative of water condensation inside the cartridge sorbent bed.
Physical damage to cartridges such as cracks, broken inlet or outlet fittings, or openings into the
sorbent bed are pathways for the ingress of contamination. Cartridges which indicate such
damage must not be used in the NATTS Program, or if already used for sample collection, must
be voided and a make-up sample should be collected per Section 2.1.2.1, where possible.

4.3.5.4	Cartridge Shelf Life. DNPH cartridges that are commercially purchased typically are
provided with an expiration from the manufacturer specifying storage conditions. Agencies must
comply with the manufacturer expiration, if given. Degradation of the DNPH reagent or silica
gel sorbent bed which may reduce collection efficiency to unacceptable levels may occur after
the assigned expiration date. Additionally, as DNPH cartridge media age, their levels of
background contamination are likely to have increased, perhaps to unacceptable levels, due to
passive sampling and uptake from the ambient atmosphere. For cartridges which are not
assigned an expiration date or are assigned an arbitrary expiration date (i.e. six months from time
of receipt) by the manufacturer, agencies should work within this expiration period as practical.
For such cartridges which have exceeded the arbitrary expiration period, they may be shown to
be acceptable if levels of contaminants meet the criteria in Table 4.3-2 and there remains
sufficient DNPH to conduct sampling and ensure excess DNPH levels remain following sample
collection. This level of DNPH on unsampled cartridges is recommended to be a reduction of
DNPH area counts of no more than -15% from the original lot acceptance analysis.

4.3.6 Method Detection Limits. MDLs for carbonyls must be determined minimally
annually by following the procedures in Section 4.1. To ensure that the variability of the media
and the extraction process is characterized in the MDL procedure, separate cartridges must be
spiked and extracted (it does not suffice to simply analyze a low-concentration solution of
derivatized carbonyls). For example, laboratories determining the MDL following Section
4.1.2.1 must prepare a minimum of seven method blank cartridges and a minimum of seven
spiked cartridges over the course of three different batches (different calendar dates - preferably
non-consecutive). These samples must be analyzed in three separate analytical batches (different
calendar dates - preferably non-consecutive). The MDL is then determined by calculating the
MDLsp and MDLb and selecting the higher of the two concentrations as the laboratory MDL.
Please refer to section 4.1.2 for specific details on selecting a spiking concentration, procedures,
and calculations for determining MDLs.

All steps performed in the preparation and analysis of field sample cartridges (such as dilution of
extracts) must be included in the MDL procedure. Cartridges should be spiked and the solvent
permitted to dry prior to extraction.

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Determined MDLs for Tier I core analytes must meet (be equal to or lower than) those listed in
the most recent workplan.

4.3.7 Carbonyls Sample Collection Equipment, Certification, and Maintenance.

Carbonyls are collected by drawing the ambient atmosphere through a DNPH cartridge at a
known flow rate of approximately 0.25 to 1.25 L/minute over the 24-hour collection period. An
ongoing EPA funded study not yet published at the time of this TAD's release indicated that at
1.25 L/minute there was no breakthrough at aldehyde concentrations of 5 ppbv. Collection of
samples with flow rates of approximately 1 L/minute represents an appropriate compromise
between maximizing collection efficiency and sensitivity.

4.3.7.1 Sampling Equipment. The sampling unit may control flow rate by a MFC or by a
combination critical orifice and flow rotameter. Advantages of MFCs include that they provide
real-time control of a specified flow, adjusting for changes in backpressure and sampling
conditions. Additionally, MFC flow data may be continuously captured and recorded so as to
permit calculation of a total sampled volume. Such is in contrast with sampling units with
rotameters for which only beginning and ending flow rate measurements are available for total
volume calculations. Another limitation of rotameters is that their indicated flows must be
manually corrected to standard conditions using the barometric pressure and temperature at the
site on the day of sample collection. Rotameters are less complicated and expensive than MFCs.

A variety of commercial and custom-built sampling instruments is available. These range from
simple flow pumps controlled via critical orifice and flow rotameter to multi-channel/multi-
pump systems connected through multiple MFCs and operated by touch screen control. Some
units are also able to simultaneously collect VOC canisters or allow remote computer login to
monitor sampling events and download sample collection data. Note that such options are
advantageous, but not required.

Regardless of the additional features, each sampling unit must minimally include the following
options:

•	Elapsed time indicator

•	Multi-day event control device (timer)

•	MFC (preferred) or critical orifice and flow rotameter to control sampling flow

•	Ozone denuder

Each sampling unit must be flow calibrated annually and shown to be free of positive bias.

4.3.7.1.1 Sampling Unit Zero Check (Positive Bias Check). It is required that prior
to field deployment and minimally annually thereafter each carbonyl sampling unit be certified
to be free of positive bias by collection over 24 hours of a sample of humidified HCF zero air (or
equivalent carbonyl- and oxidant-free air) or UHP nitrogen. Each channel of each carbonyl
sampling instrument should be so verified. A best practice is to perform this procedure TTP
where the entire in-situ sampling train is tested. As many agencies do not possess the resources
to perform TTP procedures, the zero check may be performed in the laboratory where as much of
the flow path as possible must be included. Minimally the portion of the flow path comprising

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the ozone denuder/scrubber and sampling unit into which the DNPH cartridge is installed should
be verified as non-biasing. The positive bias check should be performed following the recharge
or replacement of the ozone scrubber/denuder, is ideally performed following the annual
recalibration of the flow control device, and ideally includes the length of tubing that connects
the instrument to the manifold or the entire new or cleaned inlet probe.

A recommended zero check procedure is described below. For agencies which cannot perform
the annual maintenance (ozone scrubber/denuder recharge, flow control calibration) and
challenge in house, manufacturers, the national contract laboratory, or third party laboratories
may perform this service. Regardless of the exact procedure adopted, when performed, the
performance specifications listed below must be met.

The zero check is performed by simultaneously providing humidified (50 to 70% RH)
hydrocarbon- and oxidant-free zero air or UHP nitrogen to the sampling unit for collection onto a
cartridge and to a separate reference cartridge connected directly to the supplied zero gas source.
As closely as possible, sample collection parameters for the ozone scrubber/denuder, flow rate,
etc., should mimic those for field sample collections.

The humidified zero gas flow is provided to a challenge manifold constructed of
chromatographic stainless steel. The manifold should include three additional ports for
connections to the sampling unit inlet, reference sample, and a rotameter to serve as a vent to
ensure that the manifold remains at ambient pressure during sample collection. The reference
sampling flow is set to approximate the flow rate of the sampling unit with an MFC, mechanical
flow device, or needle valve downstream from the reference cartridge. Zero gas is supplied such
that there is excess flow to the manifold as indicated by the rotameter on the vent port. Sampling
is performed over 24 hours to simulate real world conditions, into the reference cartridge and
through the sampling unit and into the zero challenge cartridge.

Another method to provide the sampling unit with carbonyl-free gas is to install a DNPH
sampling cartridge on the inlet to sampling unit. This cartridge traps the carbonyl compounds
and replaces the zero gas source. A zero challenge cartridge collected in this manner should be
compared to a field blank as the reference cartridge.

Analysis for target compounds in the zero challenge cartridge must show that each compound is
< 0.2 ppbv greater than the reference cartridge. Comparison to the reference cartridge permits
evaluating the contribution of the sampling unit irrespective of cartridge background
contamination. Where exceedances are noted for the zero challenge cartridge, corrective action
must be taken to remove the contamination attributable to the sampling unit and the sampling
unit zero challenge repeated to ensure criteria are met before sampling may be conducted.

4.3.7.1.2 Carbonyls Sampling Unit Flow Calibration. Initially prior to field
deployment and whenever independent flow verification indicates the flow tolerance has been
exceeded, the flow control device (MFC or flow rotameter) must be calibrated against a
calibrated flow transfer standard and the flow control device (or regression for a flow rotameter)
adjusted to match the transfer standard (or the regression characterizing its response must be
reset to match the transfer standard).

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Note that manufacturer procedures for calibration may be followed if flows can be calibrated at
standard conditions. A suitable calibration procedure for MFCs is as follows. The sampling unit
pump(s) and MFC should be warmed up and run for approximately five minutes to ensure the
MFC is stable. A blank DNPH cartridge should be installed into the air sampler to provide a
pressure drop to the pump, and airflow through the cartridge commenced. The calibrated flow
transfer standard should be connected at the upstream end of the sampling unit so as much of the
flow path is included as possible in order to identify potential leaks in the flow path that may not
otherwise be evident. MFC calibration should be performed at minimally three flow rates: the
typical flow rate for sample collection, approximately 30% less than the typical flow of sample
collection, and approximately 30% higher than the typical flow of sample collection. Particular
attention should be paid to ensure that the correct calibration conditions are compared - that both
the reading on the flow transfer standard and MFC are in standard (25°C and 760 mm Hg)
conditions.

Calibration of flow rotameters is more complex than calibration of MFCs. The temperature and
barometric pressure both at the time of calibration and during sample collection are needed to
correct the indicated rotameter flow rate to the actual flow rate.3 A suitable rotameter calibration
procedure is given below.

The flow rotameter should be challenged with a flow of air which is simultaneously measured by
a calibrated flow transfer standard. At each flow rate set point, the flow reading from the flow
transfer standard and the corresponding reading from the flow rotameter are recorded. The
challenged flow range should include a minimum of five flow rates that span the useful scale of
the flow rotameter and include the expected indicated flow rate during field operation. A linear
regression is then generated by plotting the flow transfer (known) readings on the x-axis and the
flow rotameter readings (unknown) on the y-axis. The resulting linear regression equation
allows the rotameter's indicated flow (on the y-axis) to be related to the known calibrated flow of
the rotameter on the x-axis at the specific conditions of ambient temperature and barometric
pressure at which the flow calibration is performed.

To calculate the actual flow rate during operation of the rotameter in the field, the rotameter flow
rate during calibration is found by way of cross reference with the indicated flow from the
rotameter calibration plot. Stated another way, the rotameter is read, and this indicated flow is
found on the y-axis of the calibration plot and the corresponding flow rate during calibration is
read from the x-axis (or the regression equation is solved for x). This flow rate during
calibration, Qc, along with the ambient temperature and pressure during calibration and during
sample collection are input into the following equation to calculate the flow during sample
collection:

where:

Qa = volumetric flow rate at ambient (or local) conditions where the rotameter is
operated

Qc = volumetric flow rate at ambient (or local) conditions during rotameter calibration
Pc = barometric pressure during rotameter calibration

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Pa = barometric pressure at ambient (or local) conditions where the rotameter is operated
Ta = absolute temperature at ambient (or local) conditions where the rotameter is
operated

Tc = absolute temperature during rotameter calibration

For flow rotameters which are calibrated by delivery of a known flow measured at standard
conditions, the calculation of the ambient flow at standard conditions is performed according to
the following equation:

p t

ct c

Qa,std ~ Qc,std p j,

where:

Qa,std = flow rate where the rotameter is operated, in standard conditions (760 mm Hg,
25°C)

Qc.std = flow rate where the rotameter was calibrated, in standard conditions
Tc, Pc, Ta, and Pa are as above.

As an example, assume that a rotameter is calibrated - its indicated flow is cross-referenced to a
calibrated flow - by delivery of known flows measured at standard conditions. Assume as well
that the calibration is performed near sea level at a typical laboratory temperature such that Pc =
750 mm Hg and Tc = 20° C = 293.15 K, and that a field sample is collected in the summer in
Grand Junction, Colorado, such that Pa = 650 mm Hg, Ta = 35° C = 308.15 K. Assume the
indicated rotameter flow is 800 mL/min, which from the calibration plot corresponds to a known
flow rate at standard conditions of 750 mL/min. The actual flow rate, in standard conditions, for
this carbonyl sample in Grand Junction is equal to 750 mL/min • V (650/750 • 293.15/308.15) =
681 mL/min.

To perform a flow calibration verification on the sampling unit flow, the sampling unit pump(s)
should be warmed up and run for approximately five minutes to ensure flows are stable. A blank
DNPH cartridge should be installed into the air sampler to provide a pressure drop to the pump,
and airflow through the cartridge commenced. The calibrated flow transfer standard should be
connected at the upstream end of the sampling unit so as much of the flow path is included as
possible in order to identify potential leaks in the flow path that may not otherwise be evident.
The sample flow is then set to the flow setting of typical sample collection and the flow
compared to the transfer standard. Ensure that both the sampling unit and flow transfer standard
are set to report flows at standard conditions of 25°C and 760 mm Hg. Rotameter flows must be
converted to standard conditions (Qa, std) with the temperature and barometric pressure measured
at the time of the calibration check via the equation above. The sampling unit flow in standard
conditions must be within 10% of the flow indicated by the transfer standard. If outside of this
range, the MFC must be recalibrated or the regression equation for the flow rotameter must be
re-established.

4.3.7.1.3 Moisture Management. Humidity plays several roles with regard to
sample collection. Water vapor can condense on interior portions of the sample flow path

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potentially resulting in a low measurement bias due to carbonyls dissolving in the liquid water.
To minimize the condensation of liquid water onto the interior surfaces of the flow path, the
ozone scrubber is maintained at a minimum of 50°C. Additionally, connecting tubing may be
insulated to maintain the elevated temperature and discourage condensation. High humidity in
sampled atmospheres may also lead to somewhat lower carbonyl collection efficiencies due to
the possible back reaction of the DNPH-carbonyl derivative with water to form the free carbonyl.
The reverse reaction is less likely for aldehydes due to their higher reactivity, however can lead
to lower collection efficiencies for ketones. 4

4.3.7.2	Sampling Train Configuration and Presample Purge. The carbonyl sampling inlet
probe may be standalone or connected to a manifold inlet. For either configuration, components
comprising the wetted surfaces of the flow path must be constructed of borosilicate glass, PTFE
Teflon, or chromatographic grade stainless steel. Due to the reactivity of materials such as
copper or adsorptive/desorptive properties of materials such as FEP Teflon®, rubber, or plastic
tubing, these materials must not be utilized within the flow path.

For sites having a common inlet manifold, it must be constructed of borosilicate glass. A bypass
pump is connected to the manifold to continuously pull ambient air though the manifold. The
flow rate of the bypass pump must be minimally double the total maximum sampling load for all
sampling units connected to the manifold. Where the carbonyls sampling unit has its own inlet
probe separate from the manifold, no additional bypass pump is necessary.

Regardless of how the ambient air is introduced into the sampling instrument, it is strongly
recommended that the inlet line to the sampling unit be purged with ambient air such that the
equivalent of a minimum of 10 air changes is completed just prior to commencing sample
collection. This purge eliminates stagnant air and flushes the inlet line.

4.3.7.3	Carbonyl Sampling Inlet Maintenance. Over time, the carbonyl inlet probe and
connecting tubing will become laden with particulate residue. This particulate residue may scrub
target analytes from the gas stream and may act as sites for adsorption/desorption. Wetted
surfaces of inlet probes and connecting tubing must be cleaned and/or replaced minimally
annually, and preferably every six months, particularly if operated in an urban environment
where there is a higher concentration of PM.

Only deionized water should be used to clean inlet lines. If the lines are short enough, a small
brush can be employed in concert with the deionized water to effectively clean the interior of the
tubing. It may be more effective to simply replace the tubing on a prescribed basis. Many
carbonyl sampling units utilize Teflon® particulate filters upstream of the denuder to alleviate
particulate loading of internal parts (valves and MFCs) of sampling units. Such particulate filters
must be replaced periodically, recommended to be replaced after six months but must not exceed
annually.

4.3.8 Sample Collection Procedures and Field Quality Control Samples

4.3.8.1 Sample Collection Procedures. Prior to beginning sample collection, all DNPH
cartridge lot characterization must be completed as described in Section 4.3.5.1. The sampling

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unit must have passed the zero check in the previous 12 months, the sampling inlet line cleaned
or replaced in the previous 12 months, the flow control device calibrated within the past 12
months, and, if so equipped, the particulate filter must have been changed in the previous year.

In addition to the procedures described below, all cartridges must be handled as prescribed in
Section 4.3.5.2.

4.3.8.1.1	Sample Setup. Blank DNPH cartridge media are transported to the site in
a cooler on ice packs where they are either stored on site in a refrigerator or freezer (with
calibrated temperature monitoring), or installed into the sampling unit for sample collection.

Appropriate blank, non-exposed DNPH cartridge(s) are installed into the sampling unit and the
sample collection program verified to comply with Section 4.3.8.1.3. The flow rate of collection
should be set to a known calibrated flow rate of approximately 0.7 to 1.5 L/minute (at standard
conditions) for a total collection volume of 1.0 to 2.2 m3 at standard conditions. Method
sensitivity is linearly proportional to the total collection volume, and the latter should be adjusted
within the specified range so that MDL MQOs are attained. An ongoing EPA funded study not
yet published at the time of this TAD's release indicated that at these flow rates there was no
breakthrough at aldehyde concentrations of 5 ppbv. Flow rates greater than 1.5 L/minute may
result in decreased in collection efficiency.

For sampling units which permit a leak check function on the sample pathway, a leak check must
be initiated prior to sample collection. A successful leak check indicates no flow through the
sampling unit.

The initial flow rate, date and time of sample initiation, and cartridge identification information
must be recorded on the sample collection form.

4.3.8.1.2	Sample Retrieval. The collected cartridges must be retrieved as soon as
possible after the conclusion of sampling in order to minimize degradation of the carbonyl-
DNPH derivatives, preferably within 72 hours of the end of sample collection. The ending flow
rate, total flow (if given), and sample duration must be documented on the sample collection
form. The cartridges are removed from the sampling unit, the caps installed on the inlet and
outlet of each cartridge, each cartridge sealed in its separate foil pouch, and the pouches
immediately placed in cold storage. The sample must be kept cold during shipment such that the
temperature remains < 4°C, and the temperature of the shipment must be determined upon
receipt at the laboratory. A best practice to minimize contamination is to transport the sealed foil
pouch in an outer zipperlock bag containing activated carbon.

Sampling units which incorporate computer control of the sampling event with associated data
logging may provide the above information which must be printed and attached to the sample
collection form or transcribed. For such sampling units, the data logged should be reviewed to
ensure the sample was collected appropriately and there are no flags or other collection problems
that may invalidate the collected sample. Collected data should be downloaded and provided to
the analytical laboratory. The sample custody form must be completed and accompany the

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collected sample at all times until relinquished to the laboratory. COC documentation must
comply with Section 3.3.1.3.7.

4.3.8.1.3 Sampling Schedule and Duration. Carbonyl sample collection must be
performed on a one-in-six days schedule per the national sampling calendar for 24 ± 1 hours
beginning at midnight and concluding on midnight of the following day, local time unadjusted
for daylight savings time. For missed or invalidated samples, a make-up sample should be
scheduled and collected per Section 2.1.2.1. Clock timers controlling sampling unit operation
must be adjusted so that digital timers are within ±5 minutes of the reference time (cellular
phone, GPS, or similar accurate clock) and mechanical timers within ±15 minutes.

4.3.8.2 Field Quality Control Samples. QC samples co-collected with field samples include
field and trip blanks, collocated and duplicate samples, field matrix spikes, and breakthrough
samples. Blank cartridges provide information on the potential for field-collected samples to be
subjected to positive bias, whereas spiked cartridges assess the potential for the presence of both
positive and negative bias.

4.3.8.2.1 Field Blanks. Field blanks must be minimally collected once per month;
however, it is a best practice to increase this frequency, ideally to collect a field blank with each
collection event. Field blanks must be handled in the same manner as all other field-collected
samples, transported in the same cooler and stored in the same refrigerator/freezer storage units.
Field blanks are exposed to the ambient atmosphere for approximately five to ten minutes by
installation of the blank cartridge into the sampling position on the primary sampling unit with
no air drawn through the cartridge. The field blank cartridge is then removed from the sampling
unit and placed immediately into cold storage. Collection of the field blank in this manner
characterizes the handling of the blank cartridge in the sampling position in the primary sampling
unit and standardizes field blank collection across the NATTS network for carbonyls and with
metals and PAHs field blank collection.

An exposure blank is similar to a field blank, but is not required, and may be collected via
several protocols. The exposure blank includes opening the cartridge pouch, removing the caps
exposing the cartridge to the ambient atmosphere briefly, and exposing it to the temperature
conditions of the primary sampling cartridge for the same duration as the co-collected field
samples. Like a field blank, air is not drawn through the exposure blank cartridge. Some
sampling units have a dedicated "field blank" channel for installation of the exposure blank
through which air is not permitted to flow. For multi-channel sampling units, the exposure blank
may be installed in channel which is not activated for sample flow. For sampling units which
have neither a dedicated blank channel nor unused channel available on the sampling unit, the
exposure blank cartridge may be removed from the foil pouch, installed in the sampling unit for
five to ten minutes, the cartridge uninstalled and the end caps reinstalled, and the cartridge
placed near the sampling unit for the duration the primary sample is installed in the sampling
unit.

Field blanks and exposure blanks may passively sample ambient air throughout the time of
exposure, and as a result may have somewhat higher background levels as compared to lot

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blanks, trip blanks, or laboratory method blanks. Field blanks must meet and exposure blanks
should meet the following criteria listed in Table 4.3-3.

Table 4.3-3. Carbonyls Field Blank Acceptance Criteria

Carbonyl Compound

Not-to-Exceed Limit (|ig/cart ridge)

Acetaldehyde

<0.40

Formaldehyde

<0.30

Acetone a

<0.75

Sum of Other Target Carbonyls

<7.0

a Acetone is not a target compound and should not be grounds for field blank criteria failure unless it interferes

with other target analytes in the chromatogram.

Failure to meet the field blank criteria indicates a source of contamination and corrective action
must be taken as soon as possible. For agencies which collect associated trip blanks, comparison
of the field blank to trip blank values may provide meaningful insight regarding the
contamination source. Field-collected samples associated with field blanks which do not meet
these criteria must be flagged/qualified when input to AQS. For field blanks which fail criteria
and are collected with each sampling event, the co-collected field sample results must be
flagged/qualified when input to AQS. For failing field blanks which are collected on a less
frequent basis (i.e. monthly basis), field collected samples since the last acceptable field blank
must be flagged/qualified when input to AQS.

Field samples must not be corrected for field blank values. Field blank values must be reported
to AQS so that data users may estimate field and/or background contamination.

4.3.8.2.2	Trip Blanks. Trip blanks are a useful tool to diagnose potential
contamination in the sample collection and transport of carbonyl samples. Trip blanks are not
required, but are a best practice. A trip blank consists of a blank unopened cartridge which
accompanies field sample cartridges at all times to and from the laboratory. The trip blank
cartridge is stored in the same refrigerator/freezer, transported in the same cooler to and from the
site, and kept at ambient conditions during sample collection. The cartridge must remain sealed
in the foil pouch and not removed from its pouch until extracted in the laboratory.

Background levels on the trip blank should be comparable to the lot blank average determined as
in Section 4.3.5.1 and must not exceed the values listed in Table 4.3-2. Exceedance of these
thresholds must prompt corrective action and the results of the associated field-collected samples
must be appropriately qualified when input to AQS.

4.3.8.2.3	Collocated Samples. Collocated sampling is described in detail in
Section 4.3.3.1.1. Where such is performed, it must be done at a frequency of no less than 10%,
meaning approximately one collocated sample every other month.

Following extraction and analysis the collocated cartridge results are compared to evaluate
precision. Precision must be < 20% RPD for results >0.5 |ig/cartridge. Root cause analysis
must be performed for instances in which collocated samples fail this precision specification and
the results for both the primary and collocated samples must be qualified when entered into
AQS.

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4.3.8.2.4 Duplicate Samples. Duplicate sampling is described in detail in
Sections 4.3.3.1.1 and 4.3.3.1.2. Where such is performed, it must be done at a frequency of no
less than 10%, meaning approximately one duplicate sample every other month.

Following extraction and analysis the duplicate cartridge results are compared to evaluate
precision. Precision must be < 20% RPD for results >0.5 |ig/cartridge. Root cause analysis
must be performed for instances in which duplicate samples fail this precision specification and
the primary and duplicate results must be qualified when entered into AQS.

4.3.8.2.5 Field Matrix Spikes. Performance of field matrix spiked sample
collection is a best practice, but is not required. Field matrix spikes are prepared by spiking a
blank DNPH cartridge with a known amount of analyte (either derivatized or underivatized)
prior to dispatching to the field for collection. The field matrix spike is handled identically to
field samples; sample storage, transport, and extraction are identical. Field matrix spiked
samples are collected concurrently with a non-spiked primary sample as a duplicate sample per
Section 4.3.8.2.3 via duplicate channel or split sample flow.

The primary field sample and matrix spiked sample analysis results are evaluated for spike
recovery based on the amount spiked prior to shipment to the field as follows:

(Field Matrix Spike Result — Primary Sample Result)

d / r~)	v	1	y	i	7	a a

%Recovery =			;—, „ ——	 ¦ 100

Nominal Spiked Amount

Spike recovery should be within ± 20% (80 to 120% recovery) of the nominal spiked amount. In
the event of an exceedance, root cause analysis should be performed to determine sources of
negative or positive bias, as needed, for example, sources of contamination or reasons for the
loss of analyte. High recoveries may indicate contamination in the matrix spike sample
collection channel or loss in the primary sample collection channel. Low recoveries may
indicate a poorly functioning ozone denuder, which permits ozone to pass through the sample
collection flow path and degrade the spiked analytes.

4.3.8.2.6 Breakthrough Samples. While not required, collection of breakthrough
samples is a best practice. A breakthrough sample is a second DNPH cartridge connected
immediately downstream of the primary sample cartridge. Periodic collection of breakthrough
samples provides a level of assurance that the primary sample cartridge is efficiently trapping
target carbonyls. For sites conducting breakthrough sampling the recommended frequency is
once per month which should be described in the agency NATTS QAPP, SOP, or similar
controlled document.

Note that this breakthrough cartridge will increase the pressure drop in the sampling system and
may require an adjustment in the operation of the sampling unit to achieve the desired flow rate.

Breakthrough sample results must meet the field blank criteria listed in Table 4.3-3.

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4.3.9 Carbonyls Extraction and Analysis. Target carbonyls collected on the DNPH
cartridges are extracted and analyzed per EPA Compendium Method TO-11 A1 according to the
following guidance.

4.3.9.1 A nalytical Interferences and Contamination

4.3.9.1.1	Analytical Interferences. The carbonyl-hydrazone derivatives are
separated with a HPLC system and are typically detected at 360 nm with a photodiode array or
similar detector operating at UV wavelengths. Identification is based on retention time matching
with known standards. MS and photodiode array (PDA) detectors are also an option if more
definitive identification and quantification are desired or required. Minimally, analysis by
HPLC-UV must be performed.

Interferences from co-eluting peaks may result from hydrazones formed by co-collected
compounds or reactions with co-collected compounds which form artifacts. Such co-eluting
peaks may form as dimers or trimers of acrolein or be the result of chemical reactions with
nitrogen oxides. Target analyte peaks which indicate shoulders, tailing, or inflection points
should be investigated to ensure these chromatographic problems are not related to a co-eluting
interference.

4.3.9.1.2	Labware Cleaning. Labware must be thoroughly cleaned prior to use to
eliminate potential interferences and contamination. Regardless of the specific procedures
implemented, all method performance specifications for cleanliness must be met. Volumetric
labware used for collection of cartridge eluent can show buildup of silica gel residue over time,
requiring aggressive physical cleaning methods with laboratory detergent and hot water. Clean
all associated labware by rinsing with ACN, washing with laboratory detergent, rinsing with
deionized water, rinsing with ACN or methanol, and air drying or drying in an oven at no more
than 80 to 90°C. 5 Heated drying of volumetric ware at temperatures > 90°C voids the
manufacturer volumetric certification.

4.3.9.1.3	Minimizing Sources of Contamination. Several target analytes in this
method are typically present in ambient air and may contaminate solvents and the DNPH reagent
if appropriate preventive measures are not in place. ACN used for sample extraction, standards
preparation, and mobile phase preparation must be carbonyl-free HPLC grade or better (as
indicated by the supplier or on the COA) and must be stored tightly capped away from sources of
carbonyls. DNPH cartridges must be handled properly per Section 4.3.5.2.

Laboratories which process environmental samples for organic compounds such as pesticides
typically employ extraction with acetone or other solvents which may contaminate DNPH
cartridge media and carbonyl extraction solvents. Laboratory areas in which cartridges are
stored, extracted, and analyzed should be free of contaminating solvent fumes. Carbonyls
handling areas should have heating, ventilation, and air conditioning systems separate from such
laboratory operations.

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4.3.9.2	Reagents and Standard Materials

4.3.9.2.1	Solvents. Solvents employed for extraction, preparation of standards
solutions, and preparation of mobile phase must be high-purity carbonyl-free, HPLC grade, and
shown by analysis to be free of contaminants and interferences. Such solvents include ACN,
methanol, and deionized water. Deionized water must be ASTM Type I (18 MQcm).

4.3.9.2.2	Calibration Stock Materials. Calibration source material must be of
known high purity and must be accompanied by a COA. Calibration materials should be neat
high purity solids or sourced as certified single component or component mixtures of target
compounds in an appropriate solvent (i.e., ACN or methanol).

Neat solid material must be weighed with a calibrated analytical balance with the appropriate
sensitivity for a minimum of three significant figures in the determined standard mass. The
calibration of the balance must be verified on the day of use with certified weights bracketing the
masses to be weighed. Calibration standards diluted from stock standards must be prepared by
delivering stock volumes with mechanical pipettes or calibrated gastight syringes and the
volumes dispensed into Class A volumetric labware to which ACN is added to establish a known
final dilution volume.

4.3.9.2.3	Secondary Source Calibration Verification Stock Materials. A

secondary source standard must be prepared to verify the calibration of the HPLC on an ongoing
basis, minimally immediately following each ICAL. The secondary source stock standard must
be purchased from a different supplier than the calibration stock material or, only if unavailable
from a different supplier, may be of a different lot from the same supplier as the calibration
material.

4.3.9.2.4	Holding Time and Storage Requirements. Unopened stock materials are
appropriate for use until their expiration date provided they are stored per manufacturer
requirements. Once opened, stock materials may not be used past the manufacturer
recommended period or, if no time period is specified, not beyond six months from the opened
date. To use the standard materials past this time period, standards must have been demonstrated
to not be degraded or concentrated by comparison to freshly opened standards. Unopened stock
materials must be stored per manufacturer recommendations. All stock and diluted working
calibration standards must be stored at < 4°C in a separate refrigeration unit from sample
cartridges and sample extracts.

4.3.9.3	Cartridge Holding Time and Storage Requirements. All field-collected cartridges
must be stored at < 4°C and extracted within 14 days of the end of collection. These conditions
similarly apply to laboratory-prepared QC samples, which must be stored at < 4°C and extracted
within 14 days of preparation. Extracts must be analyzed within 30 days of extraction. Results
input to AQS must be appropriately qualified for failure to meet the holding time and/or storage
criteria.

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4.3.9.4 Cartridge Extraction

4.3.9.4.1 Laboratory Quality Control Samples. With each extraction batch of 20 or
fewer field-collected cartridges, which may include the various field QC samples such as those
listed in Section 4.3.8.2, the following negative and positive laboratory QC samples must be
prepared (except LCS/LCSD which must be prepared/analyzed minimally quarterly -
recommended with each batch). For batch sizes of more than 20 field-collected cartridges, n
such QC samples of each type must be added to the batch, where n = batch size / 20, and where n
is rounded to the next highest integer. Thus for batch sizes of 30, two of each of the following
QC samples would be included in each batch. A best practice would be to process field-
collected cartridges in batches of no more than 20 at a time.

-	Extraction Solvent Method Blank (ESMB): An ESMB is prepared by transferring the
extraction solvent into a flask just as an extracted sample. The purpose of this
negative control is to demonstrate that the extraction solvent is free of interferences
and contamination and that the labware washing procedure is effective. Analysis
must show target compound responses are less than the laboratory MDLsp for MDLs
determined via Section 4.1.3.1 or the s K portion of the MDL for MDLs determined
via Section 4.1.3.2.

-	Method Blank (MB): The MB is a negative control that may also be referred to as the
cartridge blank. The MB is a blank unopened cartridge (that has not left the
laboratory) which is extracted identically to field samples. All target analytes must
meet criteria specified in Table 4.3-2.

-	Laboratory Control Sample (LCS): The LCS, also referred to as the laboratory
fortified blank (LFB), is a positive control prepared by spiking a known amount of
underivatized or derivatized DNPH-carbonyl target analyte onto a cartridge such that
the expected extract concentration is in the lower third of the ICAL range. The
spiked cartridge is allowed to sit for minimally 30 minutes to allow the solvent to dry
following addition of the DNPH-carbonyl in solution. The LCS is then extracted with
the same extraction solvent and method employed for field samples to assess bias in
matrix of the extraction and analysis procedures. Recovery of the LCS must be
within 80 to 120% of nominal for formaldehyde and 70 to 130% of nominal for all
other target carbonyls.

-	Laboratory Control Sample Duplicate (LCSD): The LCSD is prepared and extracted
identically to the LCS. The LCSD assesses precision through extraction and analysis.
Recovery of the LCSD must be within 80 to 120% of nominal for formaldehyde and
70 to 130%) for all other target carbonyls. The LCS and LCSD results must show
RPD of <20%.

All field-collected and laboratory QC samples in a given extraction batch must be analyzed in
the same analysis batch (an analysis batch is defined as all samples analyzed together within a
24-hour period).

Laboratories must take corrective action to determine the root cause of laboratory QC
exceedances. Field-collected sample results associated with failing QC results (in the same

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preparation batch or analysis batch) must be appropriately qualified when input into AQS. In
order to simplify troubleshooting when experiencing QC failures, QC sample cartridge media
and extraction solvent lots should be the same, where possible.

4.3.9.4.2 Cartridge Extraction Procedures. Cartridges are extracted with carbonyl-
free HPLC grade ACN. Field-collected cartridges must be removed from cold storage and
allowed to equilibrate to room temperature, approximately 30 minutes, prior to extraction.
Cartridges are removed from the foil pouch, the end caps are removed, and the cartridges are
installed in a holding rack with the inlet of the cartridge pointed down to facilitate elution. Field-
collected samples and associated field and laboratory QC samples discussed in Section 4.3.9.4.1
must be extracted in the same batch.

The ACN extraction solvent must be added to the cartridge so that elution occurs in the direction
opposite of sample air flow (unless the laboratory can demonstrate that reverse elution is not
necessary). Luer syringe barrels or other commercially-available funnels are available for use as
solvent reservoirs for extraction, if needed. Elution may be performed by gravity or vacuum
methods. The cartridge eluent is collected in a clean volumetric flask or other appropriate
volumetrically certified vessel. Once the eluent is collected, the extract is brought to a known
final volume with ACN extraction solvent.

A minimum 2-mL extraction volume is necessary to ensure complete elution of the target
analytes from the sorbent bed. An extraction volume up to 5 mL may be employed, however
larger volumes do not increase the extraction efficiency and may overly dilute the extract.

Once brought to volume, it is highly recommended that an aliquot of the extract is transferred to
an autosampler vial for analysis and the remaining extract stored in a sealed vial protected from
light at < 4°C. The stored extract affords reanalysis if there are problems during analysis (up to
40 days from extraction).

4.3.9.5 Analysis by HPLC

4.3.9.5.1 Instrumentation Specifications. For separation of the DNPH-carbonyls
by HPLC, the analytical system must have the following components:

Separations module capable of precise pumping of ACN, methanol, and/or deionized
water at 1 to 2 mL/min

Analytical column, CI8 reversed phase, 4.6 x 50-mm, 1.8-|im, or equivalent
Guard column

Absorbance detector set to 360 nm or mass selective detector capable of scanning m/z
range of 25 to 600

Column heater capable of maintaining 25-35 ± 1 °C
- Degassing unit

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4.3.9.5.2 Initial Calibration. On each day that analysis is performed, the
instrument must be calibrated (meaning an ICAL must be performed) or the ICAL must be
verified by analysis of a CCV according to the following guidance.

ICAL of the HPLC must be performed initially, when continuing calibration checks fail criteria,
and when there are major changes to the instrument which affect the response of the instrument.
Such changes include, but are not limited to: change of guard or analytical column (if analyte
retention times change), backflushing of the analytical column (if analyte retention times
change), replacement of pump mixing valves and/or seals (if analyte retention times change,
replacement of the detector and/or lamp, and cleaning of the MS source (if HPLC/MS).

Working calibration standards are prepared in ACN at concentrations covering the desired
working range of the detector, typically from approximately 0.01 to 3.0 |ag/m L of the free
carbonyl. In order to avoid confusion or error in concentration calculation, it is recommended
that all concentrations be expressed as the free carbonyl and not the DNPH-carbonyl. The ICAL
must consist of a minimum of five calibration standard levels which cover the entire calibration
range.

Prior to calibrating the HPLC, the instrument must be warmed up and mobile phase should be
pumped for a time sufficient to establish a stable baseline. All solutions to be analyzed must be
removed from cold storage and equilibrated to room temperature prior to analysis.

Once a stable baseline is established, minimally one solvent blank (SB, an aliquot of extraction
solvent dispensed directly into a vial suitable for the HPLC autosampler, or similar) must be
analyzed to demonstrate the instrument is sufficiently clean, after which analysis of calibration
standard solutions may commence. The SB must show target compound responses are less than
the laboratory MDLsp for MDLs determined via Section 4.1.3.1 or the sK portion of the MDL
for MDLs determined via Section 4.1.3.2.

To establish the ICAL, each standard solution must be injected minimally once and preferably in
triplicate. The instrument response (area units) is plotted on the y-axis against the nominal
concentration on the x-axis and the calibration curve generated by linear regression for each
target compound. The calibration curve correlation coefficient (r) must be > 0.999 for linear fit
and the curve must not be forced through the origin. The calculated concentration of each
calibration solution must be within 20% of its nominal concentration.

The absolute value of the concentration equivalent to the intercept of the calibration curve
(|intercept/slope|) converted to concentration units (by division by the slope) must be less than
the laboratory MDLsp for MDLs determined via Section 4.1.3.1 or the sK portion of the MDL
for MDLs determined via Section 4.1.3.2. When this specification is not met, the source of
contamination or suppression must be corrected and the calibration curve reestablished before
sample analysis may commence.

RT windows are calculated from the ICAL by determining the mean RT for each target
compound. For positive identification the RT of a derivatized carbonyl must be within three
standard deviations (3.s) or ± 2%, whichever is smaller, of its mean RT from the ICAL. Note that

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heating the column to a constant temperature of approximately 25 to 30°C promotes consistent
RT response by minimization of column temperature fluctuations.

4.3.9.5.3	Secondary Source Calibration Verification Standard. Following each
successful ICAL, a second SSCV must be analyzed to verify the accuracy of the ICAL. The
SSCV is prepared in ACN at approximately the mid-range of the calibration curve by dilution of
the secondary source stock standard. Alternatively, two or more concentrations of SSCV may be
prepared covering the calibration range. All SSCVs must recover within ± 15% of nominal.

4.3.9.5.4	Continuing Calibration Verification. Once the HPLC has met ICAL
criteria and the ICAL verified by the SSCV, a CCV must be analyzed prior to the analysis of
samples on days when an ICAL is not performed, and minimally every 12 hours of analysis. The
CCV is also recommended to be analyzed after every 10 sample injections and at the end of the
analytical sequence. On days when an ICAL is not performed, a SB must be analyzed prior to
the CCV to demonstrate the instrument is sufficiently clean to commence analysis.

At a minimum, a CCV must be prepared at a single concentration recommended to be at
approximately the mid-range or lower end of the calibration curve, must be diluted from the
primary stock or secondary source stock material, and CCV recovery must be 85 to 115% for
each target compound. As a best practice, two or more concentrations of CCV may be prepared
and analyzed so as to better cover instrument performance across the range of the calibration
curve.

Corrective action must be taken to address CCV failures, including, but not limited to, preparing
and analyzing a new CCV, changing the guard or analytical column, backflushing of the
analytical column, replacement of the detector and/or lamp (if HPLC/UV), and cleaning of the
MS source (if HPLC/MS).

4.3.9.5.5	Replicate Analysis. For each analytical sequence of 20 or fewer field-
collected samples, at least one field-collected sample extract should be selected for replicate
analysis (as prescribed in the workplan). For sequences containing more than 20 field-collected
samples, n such replicates must be analyzed, where n = batch size / 20, and where n is rounded to
the next highest integer. Thus, for batch sizes of 30, two replicate analyses would be performed.
Replicate analysis must demonstrate precision of < 10% RPD for concentrations >0.5

|ig/cart ridge.

4.3.9.5.6	Compound Identification. The following criteria must be met in order to
positively identify a target compound:

1.	The signal-to-noise (S:N) ratio of the target compound peak must be > 3:1, preferably
> 5:1. Refer to Section 4.2.5.10.3 for more information on S:N.

2.	The RT of the compound must be within the acceptable RT window determined from
the ICAL average (see Section 4.3.9.5.2).

3.	**HPLC-MS only ** - The target and qualifier ion peaks must be co-maximized
(peak apexes within one scan of each other). Refer to Section 4.2.5.10.3 for more
information on co-maximization.

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4. **HPLC-MS only ** - The abundance ratio of the qualifier ion response to target ion
response for at least one qualifier ion must be within ± 30% of the average ratio from
the ICAL. Refer to Section 4.2.5.10.3 for more information on ion abundances.

Item 1 above does not need to be evaluated closely with each identified peak. Rather the
interpretation of the experienced analyst should weigh heavily on whether the peak meets the
minimal signal-to-noise ratio. Item 2 above may be automated by the analysis software such that
it is automatically flagged. RT windows must be updated with each new ICAL.

If any of these criteria (as applicable) are not met, the compound may not be positively
identified. The only exception to this is when in the opinion of an experienced analyst the
compound is positively identified. The rationale for such an exception must be documented.

4.3.9.5.7 Data Review and Concentration Calculations. Each chromatogram must
be closely examined to ensure chromatographic peaks are appropriately resolved and integration
does not include peak shoulders or inflections indicative of a coelution. The HPLC method may
require modification to employ mobile phase gradient programming or other methods to resolve
coeluting peaks.

Each chromatogram of an extracted cartridge (MB, LCS, LCSD, or any field-collected sample)
must be examined to ensure a DNPH peak is present. Chromatograms in which the DNPH peak
area is < approximately 50% of the typical peak area of the laboratory QC samples must be
investigated for potential compound misidentification due to the likely appearance of additional
chromatographic peaks as a result of formation of side products from the consumption of the
DNPH. This verification can be estimated and should be prescribed within the SOP or similar
controlled document. Once sample identification is confirmed, field-collected samples must be
qualified as estimated concentrations when entered into AQS since depletion of the DNPH to
below 50% of typical levels indicates the potential for negative bias in the measured
concentrations.

The concentrations of target carbonyls in unknown samples are calculated by relating the area
response of the target carbonyl to the relationship derived in the calibration curve generated in
Section 4.3.9.5.2.

Concentration results which exceed the instrument calibration range must be diluted and
analyzed such that peak within the calibration range. The diluted result must be reported and the
associated MDL adjusted accordingly by the dilution factor (the MDL multiplied by the dilution
factor).

While TO-11A allows for blank subtraction, this is not an acceptable practice and results must
not be corrected for solvent blank or MB levels. Concentrations exceeding acceptance criteria
for these blanks must prompt investigation as to the source of contamination and associated field
collected sample results may require qualification.

For sampling units which do not provide an integrated collection volume, the beginning and
ending flows are averaged to calculate the collected air volume. For computer controlled

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sampling units, the integrated collected volume is typically available from the data logging
system. Sampled air volumes must be in standard conditions of temperature and pressure (STP),
25°C and 760 mm Hg. Sampling unit flows should be calibrated in flows at standard conditions
so conversion from local conditions to standard flows is not necessary.

The air concentration in |ig/m3 of each target carbonyl is determined by multiplying the
concentration in the extract by the final extract volume and dividing by the collected sample air
volume at standard conditions of 25°C and 760 mm Hg:

Ca =	concentration of the target carbonyl in air (|ig/m3)

Ct =	concentration of the target carbonyl in the extract (|ig/mL)

Ve =	final volume of extract (mL)

Va =	volume of collected air at STP (m3)

Carbonyls concentrations can also be calculated in ppbv by multiplying by a conversion factor
based on the molecular weight of the target carbonyl at STP is calculated as follows:

where:

MW

0.082059-298.15

where:

CF = conversion factor (iigm^ppb"1)

MW = molecular weight of the target carbonyl (g/mol)

The air concentration of the target carbonyl in ppb is then calculated as follows:

CA

r — —-

WV,ppb - Cp

where:

concentration of the target carbonyl in air (ppb)
concentration of the target carbonyl in air (|ig/m3)
conversion factor (|igm~3ppb~')

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4.3.10 Summary of Quality Control Parameters. A summary of QC parameters is shown
in Table 4.3-4.

Table 4.3-4. Summary of Quality Control Parameters for NATTS Carbonyls Analysis

Parameter

Description and Details

Required Frequency

Acceptance Criteria

Solvent Blank
(SB)

Aliquot of ACN analyzed to
demonstrate instrument is
sufficiently clean to begin
analysis

Prior to ICAL and daily
beginning CCV

All target carbonyls
< MDLSp (refer to Section
4.1.3.1) ors-K (refer to
Section 4.1.3.2)

Initial Calibration
(ICAL)

Analysis of a minimum of five
calibration levels covering
approximately 0.01 to 3.0
Hg/mL

Initially, following failed
CCV, or when changes to the
instrument affect calibration
response

Linear regression
r> 0.999, the concentration
of each target carbonyl at
each calibration level must be
within ± 20% of nominal

Second Source
Calibration
Verification
(SSCV)

Analysis of a second source
standard at the mid-range of the
calibration curve to verify
curve accuracy

Immediately following each
ICAL

Recovery of each target
carbonyl within
± 15% of nominal

Continuing
Calibration
Verification
(CCV)

Analysis of a known standard
at the mid-range of the
calibration curve to verify
ongoing instrument calibration

Prior to sample analysis on
days when an ICAL is not
performed, and minimally
every 12 hours of analysis.
Recommended following
every 10 sample injections,
and at the conclusion of each
analytical sequence

Recovery of each target
carbonyl within
± 15% of nominal

Extraction Solvent
Method Blank
(ESMB)

Aliquot of extraction solvent
analyzed to demonstrate
extraction solvent is free of
interferences and contamination

One with every extraction
batch of 20 or fewer samples,
at a frequency of no less than
5%

All target carbonyls
< MDLSp (refer to Section
4.1.3.1) ors-K (refer to
Section 4.1.3.2)

Method Blank
(MB)

Unexposed DNPH cartridge
extracted as a sample

One with every extraction
batch of 20 or fewer samples,
at a frequency of no less than
5%

Criteria in Table
4.3-2 must be met

Laboratory
Control Sample
(LCS)

DNPH cartridge spiked with
known amount of target analyte
at approximately the lower
third of the calibration curve

Minimally quarterly.
Recommended: One with
every extraction batch of 20
or fewer samples, at a
frequency of no less than 5%

Formaldehyde recovery 80-
120% of nominal spike

All other target carbonyls
must recover 70-130% of
nominal spike

Laboratory
Control Sample
Duplicate (LCSD)

Duplicate LCS to evaluate
precision through extraction
and analysis

Minimally quarterly.
Recommended: One with
every extraction batch of 20
or fewer samples, at a
frequency of no less than 5%

Must meet LCS recovery
criteria

Precision < 20% RPD of LCS

Replicate Analysis

Replicate analysis of a field-
collected sample

Once with every analysis
sequence of 20 or fewer
samples, at a frequency of no
less than 5% (as required by
workplan)

Precision < 10% RPD for

concentrations

>0.5 |ig/cartridge

Retention Time
(RT)

RT of each target compound in
each standard and sample

All qualitatively identified
compounds

Each target carbonyl within
± 35 or ± 2% of its mean
ICAL RT

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Table 4.3-4. Summary of Quality Control Parameters for NATTS
Carbonyls Analysis (Continued)

Parameter

Description and Details

Required Frequency

Acceptance Criteria

Lot Blank
Evaluation

Determination of the
background of the DNPH
cartridge media

Minimum of 3 cartridges or
1% (whichever is greater) for
each new lot of DNPH
cartridge media

All cartridges must meet
criteria in Table 4.3-2

Zero Certification
Challenge

Clean gas sample collected
over 24 hours to demonstrate
the sampling unit does not
impart positive bias

Annually

Each target carbonyl in the
zero certification < 0.2 ppb
above reference sample

Field Blank

Blank DNPH cartridge exposed
to field conditions for
minimally 5 minutes in the
primary sampling location

Monthly

Must meet criteria in Table
4.3-3

Duplicate Sample

Field sample collected through
the same inlet probe as the
primary sample

10% of primary samples for
sites performing duplicate
sample collection (as
required by workplan)

Precision < 20% RPD of
primary sample for
concentrations
>0.5 |ig/cartridge

Collocated Sample

Field sample collected through
a separate inlet probe from the
primary sample

10% of primary samples for
sites performing collocated
sample collection (as
required by workplan)

Precision < 20% RPD of
primary sample for
concentrations
>0.5 ng/cartridge

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4.3.11

References

1.	Determination of Formaldehyde in Ambient Air using Adsorbent Cartridges Followed by
High Performance Liquid Chromatography (HPLC) [Active Sampling Methodology]; EPA
Compendium Method TO-11A; U.S. Environmental Protection Agency: January 1999.
Available at (accessed October 19, 2016):
https://www3.epa.gov/ttnamtil/files/ambient/airtox/to-llar.pdf

2.	MacGregor, I. C., Hanft, E. A., and Shelow, D. M. (2015). Update on the Optimization of
U.S. EPA Method TO-11A for the Measurement of Carbonyls in Ambient Air. Paper
presented at the National Ambient Air Monitoring Conference, St. Louis, MO, August 10,
2016.

3.	Urone, P., & Ross, R. C. (1979). Pressure change effects on rotameter air flow rates.
Environmental Science & Technology, 13{6), 732-734. doi: 10.1021/es60154a003

4.	Steven Sai Hang Ho, Ho Sai Simon Ip, Kin Fai Ho, Wen-Ting Dai, Junji Cao, Louisa Pan
Ting Ng. "Technical Note: Concerns on the Use of Ozone Scrubbers for Gaseous Carbonyl
Measurement by DNPH-Coated Silica Gel Cartridge." Aerosol and Air Quality Research, 13:
1151-1160, 2013.

5.	Care and Safe Handling of Laboratory Glassware. Corning Incorporated. RG-CI-101-REV2.
2011. Available at (accessed October 19, 2016):

http://csmedia2.corning.com/LifeSciences/media/pdf/Care and Safe Handling Lab Glassw
are RG-CI-101Rev2.pdf


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4.4

PMio Metals Sample Collection and Analysis

Each agency must codify in an appropriate quality systems document, such as an SOP, or
equivalent, its procedures for performing PMio metals sampling, filter digestion, and digestate
analysis. Various requirements and best practices for such are given in this section. Note that
regardless of the specific procedures adopted, method performance specifications as given in
Section 4.4.13 must be met.

4.4.1 Summary of Method. PMio metals are collected onto a filter by either a low volume
or high volume air sampling method. Following completion of either sampling procedure, the
filter, or portion thereof, is digested to liberate (dissolve) the desired elements by heating in acid,
and the digestate is analyzed via ICP/MS per EPA Compendium Method IO-3.5.1 Briefly,
digestates are introduced to the ICP/MS through pneumatic nebulization into a radio frequency
argon plasma where the elements in solution are desolvated, atomized, and ionized. The ions are
extracted from the plasma by vacuum and separated on the basis of their mass-to-charge ratio by
a quadrupole or TOF MS capable of a resolution of 1 amu at 5% peak height. An electron
multiplier is applied to the ions transmission response and the resulting signal information
recorded and processed by the data system.

The particle-bound metals in the air are collected with a commercially-available standalone air
sampler fitted with a size-selective inlet (SSI) such that only particulate matter (PM) with a mass
median aerodynamic diameter less than 10 |im is captured. Particles are deposited on either
47-mm Teflon® filter (low volume) or 8 inch x 10 inch QFF media over the 24-hour collection
period. The low volume sampling method flow is set to 16.7 liters per minute (LPM; at local
conditions) for a total collection volume of 24.05 m3. The high volume method flow is set to
approximately 1.13 m3/min (at local conditions) for a total collection volume of approximately
1627 m3. For both low volume and high volume methods, the SSIs require a closely regulated
flow rate to ensure PM cut points are accurate and temporally stable.

Following the completion of any desired gravimetric measurements for determining total PMio
gravimetric concentration, the filters are digested for metals analysis. Following collection,
filters should be stored at ambient conditions and must be digested and analyzed within 180
days.

The target metals of interest to the NATTS Program are listed in Table 4.4-1.


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Table 4.4-1. NATTS Program Metals Elements and Associated CAS Numbers

Element

CAS Number

Antimony b

7440-36-0

Arsenic a b

7440-38-2

Berylliuma b

7440-41-7

Cadmiuma b

7440-43-9

Chromium

7440-47-3

Cobaltb

7440-48-4

Leada b

7439-92-1

Manganese a b

7439-96-5

Nickela b

7440-02-0

Seleniumb

7780-49-2

a NATTS Tier I core analyte
b NATTS PT target analyte

4.4.2 Advantages and Disadvantages of High Volume and Low Volume Sample

Collection. Summarized below are some of the advantages and disadvantages of the high and

low volume air sampling for PMio metals.

4.4.2.1	Low Volume Sampling

Advantages

•	Many low volume samplers are already in use at PM monitoring sites to assess
compliance with the National Ambient Air Quality Standards. As a result, many
monitoring agencies are familiar with and have the infrastructure to support low
volume PM sampling.

•	Teflon® filters, as compared to QFFs, typically have lower background levels of
metals such as chromium, nickel, manganese, and cobalt. As a result, MBs are
cleaner and MDLs that account for MB levels are lower.

•	Low volume instruments are available into which several filters may be
simultaneously loaded so as to permit collection of several sampling events in
sequence without the need for operator intervention.

Disadvantages

•	The extraction and analysis method must have greater sensitivity and background
contamination must be more strictly limited in order to achieve MDLs equivalent to
high volume sampling, due to the lower total sample volume collected.

•	The entire Teflon® filter is digested for analysis, thus error in preparation may require
invalidation of results, and it not possible to prepare duplicate and/or spike duplicate
field collected samples for QC purposes.

4.4.2.2	High Volume Sampling

Advantages

•	At the listed flow rates, the high volume sampling method collects approximately 67
times more mass on the filter than low volume sampling, thereby providing greater

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sensitivity (approximately seven-fold) for metals analysis even after taking into
consideration that only a portion (typically approximately 1/9) of the QFF is digested
for analysis.

•	In the event of loss of the primary sample and when assessment of method precision
and bias is desirable, duplicate and spike duplicate samples may be readily prepared
by extraction and analysis of another filter field collected sample strip.

Disadvantages

•	QFFs typically have higher background levels of target metals, such as chromium,
nickel, manganese, and cobalt.

•	Sequential sampling is not possible with high volume filter sampling instruments.
4.4.3 Minimizing Contamination, Filter Handling, and Filter Inspection

4.4.3.1	Minimizing Contamination. Careful handling of the filter media is required to
ensure that metals measured on the filter are present as a result of sampling the ambient
atmosphere, rather than due to contamination. Each agency must codify into an appropriate
quality system document, such as an SOP, procedures that it will follow to minimize the
introduction of metals contamination during filter handling, processing, extraction, and
subsequent analysis of digestates. What follows in this section are practices either that are
required or are recommended for adoption into an agency's quality system.

See also Section 4.4.6 for guidance on minimizing contamination during the preparation of
lab ware.

4.4.3.2	Filter Handling. Filters must only be handled with gloved hands or plastic or
Teflon®-coated forceps, and filter media must not be manipulated with metal tools. Tools for
portioning filter strips must be ceramic or plastic. Forceps and work areas should be routinely
decontaminated using a dilute nitric acid solution followed by rinses with deionized water. Use
of volumetric syringes with metal needles must be avoided.

Teflon® filter media should be transported to and from the field in non-metallic cassettes which
must be kept tightly capped except during installation of filters into sampling units. Placement
of filters into, and subsequent removal of filters from cassettes should be performed in the
laboratory in a clean area where measures are taken to control the levels of airborne particulate
matter, such as a conditioning room for filter weighing. Such filter weighing rooms typically
employ dust-reduction methods such as high efficiency particulate air (HEPA) filtration to
minimize potential deposition contamination.

QFFs should be transported and maintained in manila or glassine envelopes which protect the
filter from dust deposition and from physical damage. The filter should be placed into, and
subsequently removed from, the cassette while the cassette is in a clean area, one without
obvious dust contamination, away from visible sources of PM, and with minimal air movement.
Following removal from the cassette after the conclusion of sampling, the filter must be folded
lengthwise in half (with gloved hands) with the particulate matter inward, and placed into a

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protective manila envelope or folder, or within a glassine envelope to protect the filter from loss
of PM or from deposition of dust.

4.4.3.3 Filter Inspection. Filter media must be inspected for pinholes, discolorations,
creases, thin spots, and other defects which would make them unsuitable for sample collection.
Teflon® filters must additionally be inspected for separation of the support ring. Filters should
be inspected on a light table or similar apparatus which allows backlighting of the filter to aid in
the identification of defects. Any surface (such as the light table) coming into contact with the
filter media must be decontaminated from dust and residue prior to use with deionized water and
lint-free wipes. All filter handling requirements given in Section 4.4.3.2 must be followed.

4.4.4 Precision - Sample Collection and Laboratory Processing. Each agency must
codify in an appropriate quality systems document, an SOP, or similar, procedures that it will
follow to assess precision. Given below are the various types of precision and guidance on how
to measure each.

4.4.4.1	Sample Collection Precision. Given that each PMio metals instruments consists of a
discrete inlet and sampling pump, collection of duplicate samples is not possible. Thus,
evaluation of the precision of the entire PMio metals sampling technique, from collection through
extraction and analysis, may only be performed by way of collocated sampling.

For monitoring sites conducting collocated PMio metals sampling, collocated samples must be
collected as minimally 10% of the primary samples collected (as prescribed in the workplan).
This is equivalent to a minimum of six collocated samples for sites conducting one-in-six days
sampling for a total of 61 primary samples annually. More frequent collocated sample collection
provides additional sample collection precision and is encouraged where feasible.

Collocated sample results must show precision of < 20% RPD compared to the primary sample
for concentrations > 5x MDL. Root cause analysis must be performed for instances in which
collocated samples fail this precision specification and the results of the primary and collocated
sample must be qualified when entered into AQS.

4.4.4.2	Laboratory Precision

4.4.4.2.1	Low Volume Teflon® Filter Laboratory Precision. Teflon® filters must
be extracted in their entirety. As a result, duplicate samples may not be prepared by subdividing
a filter. However, the precision of filter digestion and analysis should be assessed by the
preparation and analysis of duplicate LCSs. A sample digestate may be selected with each
digestion batch to be analyzed in replicate to determine analytical precision. To summarize,

•	A duplicate LCS informs the precision of digestion and analysis procedures, and

•	Replicate analysis of a sample digestate provides precision for the analysis only.

4.4.4.2.2	High Volume QFFLaboratory Precision. Sample processing and
analysis precision may be evaluated in several different ways with QFFs. For example, to
evaluate the precision of the filter preparation, digestion, and analysis processes, duplicate strips

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may be portioned from a field collected QFF filter and digested separately and duplicate LCSs
may be prepared. Preparation, digestion, and analysis of a matrix spike (MS) and matrix spike
duplicate (MSD) duplicate pair can additionally be performed to evaluate the matrix effects on
precision of field collected samples. Finally, to determine analytical precision, a sample
digestate may be analyzed in replicate. To summarize:

•	Duplicate sample filter strips and duplicate LCSs provide precision of digestion and
analysis procedures;

•	Duplicate matrix spike filter strips provide information on the precision of digestion
and analysis procedures, and include an assessment of potential matrix effects of that
specific sample; and

•	Replicate analysis of a sample digestate provides precision for the analysis only.

4.4.5	Field Blanks. For both high volume and low volume sampling methods, field blank
samples must be collected minimally monthly for each primary sampling unit (total of 12 per
year for a total of 18% of samples [12 out of 61]). For collocated sampling units, field blank
samples should be collected minimally twice per year (two out of six) or for 18% of collocated
samples collected, whichever is greater.

Field blanks must be generated by installing the field blank filter into the sampling unit to
simulate a field sample, however the field blank does not experience sample flow. After
minimally 5 minutes have elapsed (or the duration of sample switching required by the sampling
unit, as applicable), the filter is retrieved and stored at the field site until the associated field
sample can be retrieved and transported to the laboratory.

Field blank analysis must demonstrate all target elements < MDL.

An exposure blank is similar to a field blank, but is not required, and may be collected via
several protocols. The exposure blank includes exposing the filter to the ambient conditions by
installation in a sampling unit, and just like a field blank, air is not drawn through the exposure
blank cartridge. The exposure blank filter sample may be installed in the primary sampling unit
on non-sample collection days or could be installed in a collocated sampling unit during
collection of the primary sample.

4.4.6	Labware Preparation for Digestion and Analysis. Regardless of how filters are
digested, labware cleaning is essential to ensure background contamination is minimized. As
with other contamination minimization procedures, each agency must codify in an appropriate
quality systems document, such as an SOP, or equivalent, its procedures for effective cleaning
and decontamination of labware. Regardless of the procedures adopted, method performance
specifications as given in Section 4.4.13 must be met.

Labware for hot block digestions is typically single use; however, labware for microwave
digestion and volumetric labware for preparation of standards and reagents must be effectively
cleaned before each use. To do so, labware should be rinsed with tap water to remove as much
of the previous contents as possible. Following this tap water rinse, labware should be soaked
minimally overnight in a > 10% HNO3 (v/v) aqueous solution. Soaking should be followed by a

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minimum of three rinses with deionized water and air drying. Alternatively, labware cleaning
instruments are commercially available which may be programmed to provide washing, rinsing,
and soaking cycles in various detergent and acid solutions.

Volumetric labware must not be heated above 80 to 90°C as this voids the volumetric
certification. 2 Clean labware should be stored in a contaminant-free area, upside down or capped
to minimize introduction of contamination. Elevated levels in calibration blanks and digested
reagent blanks indicate the presence of contamination. Additional cleaning and acid rinsing
steps should be considered when blanks exceed the specified acceptance criteria.

4.4.7	Reagents for Metals Digestion and Analysis. Due to the sensitivity of ICP/MS
instruments, the purity of reagents and standards is paramount. Reagents and standards must be
certified and traceable with COAs, and it is recommended that all reagents and standards be of
the greatest purity possible and have minimal background levels of target elements. Regardless
of the reagents and standards selected, calibration and reagent blanks must be meet method
specifications as given in Section 4.4.13.

Reagent water for the preparation of digestion solutions and for dilution of standard materials
should be ASTM Type I or equivalent (having an electrical resistivity greater than 18 MQcm).
Acids should be trace metals grade, ACS spectroscopic grade, UHP grade, or equivalent. Further
polishing of reagent water and redistillation of acids may be necessary to achieve blank
acceptance criteria. Borosilicate glass volumetric flasks and storage containers should be
avoided. Teflon® or plastic (polyethylene, polypropylene, etc.) certified volumetric flasks and
storage bottles are preferable as they do not leach contaminants into stored solutions. Solutions
prepared in borosilicate glass volumetric flasks should be transferred as soon as possible to a
Teflon® or plastic storage container.

4.4.8	Method Detection Limits. MDLs must be determined per the guidance provided in
Section 4.1. Furthermore, MDLs must be determined with reagents, media, and sample handling
techniques identical to those employed for the processing of field samples. Determined MDLs
for Tier I core analytes must meet the requirements listed in the most recent workplan.

4.4.8.1	Teflon® Filter MDL. If the 40 CFR Part 136 Appendix B guidance in Section 4.1.3.1
is followed, Teflon® filter MDLs must be determined by digesting minimally seven spiked filters
and seven method blank filters (all selected from the same lot of filters) in three temporally-
separated and unique digestion and analytical batches. Both the MDLsp and MDLb must be
tracked and documented. QC blanks, which are not prepared with the filter matrix, are compared
to the MDLsp regardless of whether it is reported as the laboratory MDL. Alternatively, MDLs
may be determined following the procedure in Section 4.1.3.2. For laboratories determining
MDLs according to Section 4.1.3.2, laboratories must track the portion of the MDL determined
by s-K for comparison to QC blanks which are not prepared with the filter matrix.

4.4.8.2	QFF MDL. If the updated 40 CFR Part 136 Appendix B procedure in Section 4.1.3.1
is followed, QFF MDLs must be determined by digesting seven spiked filter strips and seven
method blank filter strips in three temporally-separated and unique digestion and analytical
batches. The filter strips should be from a different filter (from the same lot of filters) for each

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batch. Both the MDLsp and MDLb must be tracked and documented. QC blanks, which are not
prepared with the filter matrix, are compared to the MDLsp regardless of whether it is reported as
the laboratory MDL. Alternatively, MDLs may be determined following the procedure in
Section 4.1.3.2. For laboratories determining MDLs according to Section 4.1.3.2, laboratories
must track the portion of the MDL determined by s-K for comparison to QC blanks which are
not prepared with the filter matrix.

4.4.9 Low Volume Sample Collection and Digestion

4.4.9.1	Air Sampling Instruments. Low volume sample collection instruments must comply
with the Low-Volume PMio FRM requirements as listed in 40 CFR Part 50 Appendix L, i.e.,
they must operate at the design flow rate of 16.67 L/min (at local conditions), utilize 47-mm
Teflon® filter collection media, and be fitted with the "pie plate" PMio inlet or the louvered inlet
specified in 40 CFR 50 Appendix L, Figures L-2 through L-19, configured as in the PMio
reference method. The following instruments are among those that comply with these
specifications:

•	Andersen Model RAAS10-100

•	Andersen Model RAAS 10-200

•	Andersen Model RAAS 10-300

•	BGI Incorporated Model PQ100

•	BGI Incorporated Model PQ200

•	Opsis Model SM200

•	Thermo Scientific or Rupprecht and Pataschnick Partisol Model 2000

•	Thermo Scientific Partisol 2000-FRM

•	Thermo Scientific Partisol or 2000i

•	Rupprecht and Patashnick Partisol-FRM 2000

•	Thermo Scientific Partisol-Plus Model 2025

•	Thermo Fisher Scientific Partisol 2025i

•	Rupprecht and Patashnick Partisol-Plus 2025

•	Tisch Environmental Model TE-WilburlO

Sampler siting requirements are listed in Section 2.4.

4.4.9.2	Flow Calibration. Sampling unit flow calibration must be performed minimally
annually against a traceable calibrated flow transfer standard by adjusting the sampling unit flow
to match the certified standard.

Moreover, the instrument flow should be checked minimally quarterly, recommended to be
monthly, and per 40 CFR Part 50 Appendix L, the flow adjusted if it is not within ± 4% of the
transfer standard or within ± 5% of the design flow rate. Prior to performing flow checks,
sampling units should be leak checked to ensure that flow path integrity is maintained. A leak
check should be performed minimally every five sample collection events. A successful leak
check indicates a total flow of less than 80 mL or loss of less than 25 mm Hg.

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4.4.9.3	Filter Media. Low volume PMio metals must be collected onto a 46.2-mm Teflon®
filter substrate with a polypropylene support ring, 2-\im pore size, and a particle deposit area of
11.86 cm2. Filters must be stamped or printed with a unique identifier on either the support ring
or on the filter substrate.3 EPA typically annually sends agencies the filter media.

4.4.9.3.1 Lot Background Determination. For each lot of filters, the concentration
of metals in the lot background must be determined by digesting and analyzing five separate
filters from a given lot.

While there is no prescribed threshold for the lot background concentration for each element, the
lot blank concentrations must be reported to AQS. Note that the previous version of this TAD
permitted lot blank subtraction provided results were flagged in AQS with the QA data qualifier
"CB", however lot blank subtraction is not permitted. AQS guidance is provided in Section
3.3.1.3.15.

4.4.9.4	Filter Sampling, Retrieval, Storage, and Shipment. Teflon® filters will likely arrive
at the field site already installed in a cassette. The filter must be installed per the requirements of
the specific low volume instrument. A leak check may then be performed followed by
verification of the correct sampling date, duration, and target flow rate.

Upon sample retrieval, instrument performance information including the average temperature,
barometric pressure, average flow, total collected volume, collection duration, and any flags
indicating a problem during collection should be recorded, downloaded, or otherwise recorded,
as appropriate. Following removal from the instrument, the covers are placed back onto the filter
cassette, and the cassette sealed into a resealable plastic bag. Filters need not be shipped or
stored refrigerated. Filters must be handled per the procedures in Section 4.4.3.1. The sample
custody form must be completed and accompany the collected sample at all times until
relinquished to the laboratory. COC documentation must comply with Section 3.3.1.3.7.

4.4.9.4.1 Sampling Schedule and Duration. Metals sample collection must be
performed on a l-in-6 days schedule for 24 ± 1 hours beginning at midnight and concluding at
midnight of the following day, standard time (unadjusted for daylight savings time), as per the
national sampling calendar. For missed or invalidated samples, a make-up sample should be
scheduled and collected per Section 2.1.2.1. Clock timers controlling sampling unit operation
must be adjusted so that digital timers are within ±5 minutes of the reference time (cellular
phone, GPS, or similar accurate clock) and mechanical timers within ±15 minutes.

4.4.9.5	Teflon® Filter Digestion

4.4.9.5.1 Laboratory Digestion QCSamples. Each sample digestion batch must
consist of 20 or fewer field-collected filters (primary samples, collocated samples, and field
blanks). The following laboratory QC is required with each digestion batch:

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-	Negative Control Samples (Blanks), one each:

o Reagent Blank (RB) - digestion solution with no filter
o MB - blank filter with digestion solution

-	Positive Control Samples (Spikes), one each:

o Reagent Blank Spike (RBS) - spiked digestion solution with no filter
o LCS - spiked blank filter with digestion solution
o LCSD - duplicate spiked blank filter with digestion solution

Laboratory QC samples must be processed, digested, and analyzed identically to field-collected
samples, including, if applicable, filtration and/or centrifugation of digestates.

4.4.9.5.2 Digestion Procedure. Filter must be digested with one of three possible
methods: hot block digestion, microwave digestion, or heated sonication. The three different
techniques are described in the following sections.

4.4.9.5.2.1 Hot Block Digestion

The hot block digestion wells must be checked to ensure each reaches and is able to maintain the
target digestion temperature initially when put into use and annually thereafter. To do so, the hot
block is set to the target temperature (typically 95°C) and, after the temperature has been
reached, a digestion vessel filled with deionized water, known as a temperature blank, is placed
into each well. After approximately 5 minutes (or long enough for the temperature to stabilize),
the temperature of the water in each temperature blank is measured. Temperatures across the
block should be within ± 5°C of the target temperature setting.

To perform digestion of Teflon® filters, each is placed into a separate digestion vessel. Certified
single-use metals-free vessels with certified volumetric graduations are commercially available
for hot block digestions and other vessels may be utilized provided they meet the required blank
specifications. The lot and manufacturer of the digestion vessels must be documented with each
batch. Sufficient digestion solution must be added to each vessel so as to completely submerge
the filter. Digestion solutions typically consist of approximately 2% (v/v) nitric acid (HNO3) and
0.5% (v/v) hydrochloric acid (HC1). To assist in the recovery of antimony, it may be necessary
to add 0.1% hydrofluoric acid (HF) to the digestion solution.

The hot block digester is powered on and warmed to the desired temperature (~95°C) prior to
placing each digestion vessel into a digestion well. Each digestion vessel should be covered with
a precleaned ribbed watch glass and the batch of filters should be digested for a recommended
for 2.5 hours, though digestion must be for a minimum of 30 minutes. Note that this duration of
digestion must be consistent from batch to batch. An automatic shutoff timer can ensure
consistent digestion duration. A temperature blank must be included with each batch to ensure
that the proper temperature is reached during the digestion period. Digestion vessels should be
observed periodically throughout digestion to ensure none go to dryness and that the filters
remain submerged. Deionized water should be added to digestion vessels to avoid going to
dryness. Filters which float should be resubmerged with a clean plastic or Teflon® stirring rod.

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Once digestion has completed, digestion vessels are removed from the block and cooled to room
temperature (approximately 30 minutes). Once cooled, the walls of the digestion vessel should
be rinsed down with approximately 10 mL of deionized water and the digestates should be
allowed to settle for minimally 30 minutes. Following settling, digestates must be brought to
their final volume with deionized water. The final volume may be measured with the
graduations on the volumetrically-certified digestion vessel. Otherwise, digestates must be
transferred to a Class A volumetric vessel and the digestion vessel must be rinsed several times
with small (2 to 3 mL) volumes of deionized water to ensure a quantitative transfer. The
transferred digestates must be then brought to volume with deionized water.

For transfer of aliquots for analysis, filtration or centrifugation may be necessary to eliminate
particulate interference on the ICP/MS. All such processing steps must be performed on both the
field-collected and laboratory batch QC samples.

4.4.9.5.2.2 Microwave Digestion

Microwave digestion has several disadvantages when compared to hot block digestion. For
example, microwave digestion equipment and accessories are expensive. Digestion vessels and
associated caps must be cleaned and decontaminated after each use. Microwave oven power
must be calibrated on a specified, periodic basis to ensure that the digestion energy is
appropriate, comparable, and stable from batch to batch. Calibration frequency should not
exceed six months and a best practice is to verify microwave power monthly. To ensure the
appropriate amount of heat is imparted to vessels in an incompletely filled digestion rack, blank
vessels may need to be added or the microwave power may need to be reduced. Due to the
higher pressure and temperature, digestion vessels may overpressurize and explode, resulting in
loss of sample and possible injury to laboratory staff. While such is possible, modern microwave
digestion units typically employ temperature and pressure monitoring to adjust the power to
reduce the likelihood of explosion.

The advantages of microwave compared to hot block digestion are that digestion may be
performed more quickly (in approximately 30 minutes), digestions are more reproducible due to
the even heating, the closed digestion vessels ensure no loss of volatile analytes such as mercury
and lead and decrease the likelihood of the introduction of external contamination, and digestions
are more complete as a result of the increased temperature and pressure.

To digest air filter samples by microwave digestion the microwave program should permit
ramping the temperature to 180°C over 10 minutes and holding at 180°C for 10 minutes
followed by a 5-minute cool down. Other programs are also acceptable provided the requisite
batch QC criteria are met.

For digestion, each Teflon® filter must be placed into a separate microwave digestion vessel.
Sufficient digestion solution must be added to each vessel so as to completely submerge the
filter. Digestion solutions typically consist of approximately 2% (v/v) HNO3 and 0.5% (v/v)
HC1. Addition of a small amount (-0.1%) of hydrofluoric acid (HF) to the digestion solution
may be needed to maintain antimony in solution.

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The vessel caps and pressure relief valves are installed on the microwave digestion vessels and
each vessel weighed to the nearest 0.01 g with a calibrated analytical balance. Weighed
digestion vessels are then installed in the carousel in the microwave. The microwave digestion
program is run concluding with a cool down. At the end of the program, the microwave status
should be checked to verify the program completed appropriately and the digestion vessel
carousel is carefully removed from the microwave oven and allowed to cool in a fume hood.
Once cooled, vessels must be weighed to the nearest 0.01 g to ensure no loss of sample. Vessels
which exhibit mass loss of > 0.01 g must be invalidated or, minimally, their analysis results must
be flagged. Once cooled and weighed, vessels may be opened. Caution must be used when
opening vessels as the contents may still be under pressure.

After cooling, the walls of the digestion vessel should be rinsed down with approximately 10 mL
of deionized water and the digestates should be allowed to settle for minimally 30 minutes.
Following settling, digestates must be transferred to a Class A volumetric vessel and the
digestion vessel rinsed several times with small (2 to 3 mL) volumes of deionized water to
complete the quantitative transfer. The digestates are brought to volume with deionized water.

For transfer of aliquots for analysis, filtration or centrifugation may be necessary to eliminate
particulate interference on the ICP/MS. All such processing steps must be performed on both the
field-collected and laboratory batch QC samples.

4.4.9.5.2.3 A cid Sonication

Each filter is placed into a separate digestion vessel. Certified single-use metals-free vessels
with certified volumetric graduations are commercially available and other vessels may be
utilized provided they meet the required blank specifications. The lot and manufacturer of the
digestion vessels must be documented with each batch. Sufficient 4% (v/v) HNO3 digestion
solution is added to each vessel so as to completely submerge the filter. Addition of a small
amount (~0.1%) of hydrofluoric acid (HF) to the digestion solution may be needed to maintain
antimony in solution.

The sonication bath is powered on and warmed to the desired temperature (~69°C) prior to
placing the digestion vessels into the bath. Each digestion vessel should be capped and sonicated
for a minimum of 3 hours. Digestion vessels should be observed periodically throughout
digestion to ensure the filter remains submerged. Filters which float should be resubmerged with
a clean plastic or Teflon® stirring rod.

Once the digestion program has completed, digestion vessels are removed from the bath and
cooled. Once cooled, the walls of the digestion vessel should be rinsed down with
approximately 10 mL of deionized water and the digestates should be allowed to settle for
minimally 30 minutes. Following settling, digestates must be brought to their final volume with
deionized water. The final volume may be measured with the graduations on the volumetrically-
certified digestion vessel. Otherwise, digestates are transferred to a Class A volumetric vessel
and the digestion vessel are rinsed several times with small (2-3 mL) volumes of deionized water
to ensure a quantitative transfer. The transferred digestates are then brought to volume with

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deionized water.

For transfer of aliquots for analysis, filtration or centrifugation may be necessary to eliminate
particulate interference on the ICP/MS. All such processing steps must be performed on both the
field-collected and laboratory batch QC samples.

4.4.10 High Volume Sample Collection and Digestion

4.4.10.1	Air Sampling Instruments. High volume sample collection instruments must comply
with the High-Volume PMio FRM requirements in 40 CFR Part 50 Appendix J, i.e., they must
operate at a design flow rate of 1.13 m3 (at local conditions), utilize 8 inch x 10 inch QFF
collection media, and be fitted with the PMio inlet per EPA Reference Method RFPS-0202-141,
RFPS-1287-063, or equivalent. The following sampling units are among those that comply with
these specifications:

•	Ecotech Model 3000

•	Graseby Andersen/GMW Model 1200

•	Graseby Andersen/GMW Model 321-B

•	Graseby Andersen/GMW Model 321-C

•	Tisch Environmental Model TE-6070 or New Star Environmental Model NS-6070

•	Wedding and Associates or Thermo Environmental Instruments Inc. Model 600

Sampler siting requirements are listed in Section 2.4.

4.4.10.2	Flow Calibration. Sampling unit flow calibration must be performed minimally
annually against a traceable calibrated flow transfer standard by adjusting the sampling unit flow
to match the certified standard.

Moreover, the instrument flow should be checked minimally quarterly, recommended to be
monthly, and the flow adjusted if it is not within ± 7% of the transfer standard or within ± 10%
of the design flow rate. Prior to performing flow checks, sampling units should be leak checked
to ensure that flow path integrity is maintained. Leak checks are performed by installing a piece
of polycarbonate or other suitable substrate to seal off the filter plate and briefly operating the
sampling unit motor. If a high-pitched whistle is heard, there is a leak in the flow path which
must be remedied before sample collection can commence. Leak checks should be performed
approximately every fifth sample collection event.

4.4.10.3	Filter Media. Sampling media consist of 8 inch x 10 inch QFF substrate with a 2-|im
pore size, capable of 99% particle sampling efficiency for particles 0.3 |im in diameter or larger.
Filters must be stamped or printed with a unique identifier on the corner of the filter and are
typically provided annually by EPA.4

4.4.10.3.1 Lot Background Determination. For each lot of filters, the concentration
of metals in the lot background must be determined by digesting and analyzing five filter strips,
each cut from a separate filter from a given lot of filters. For monitoring agencies contracting

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analysis, filters for lot blanks should be supplied to the laboratory to determine the lot
background.

QFFs typically have background levels higher than Teflon® filters; chromium, cobalt, lead,
manganese, and nickel may be routinely found. Note that the previous version of this TAD
permitted lot blank subtraction provided results were flagged in AQS with the QA data qualifier
"CB", however lot blank subtraction is not permitted.

While there is no prescribed threshold for the lot background concentration for each element, the
lot blank concentrations must be reported to AQS. Information on reporting to AQS may be
found in section 3.3.1.3.15.

4.4.10.4 Filter Sampling, Retrieval, Storage, and Shipment. Filter media may be installed in
a sampling cassette at the laboratory before shipment to the field, or the site operator may be
required to install the filter into the cassette. Installation of the filter into the cassette must be
performed in a clean (minimal dust) indoor environment, preferably protected from air
movement, with the filter identifier oriented downward. A cover should be attached to the top of
the cassette to protect the filter sampling surface. Storing the assembled filter and cassette in a
sealed plastic bag during transport and storage is a best practice.

The cam-lock bolts of the size-selective inlet on the sampling unit are loosened to allow the inlet
to open on the hinge and the inlet locked open using a prop. The swing bolts are then loosened
to allow the assembled cassette and filter to be installed. Installation must be performed
carefully to ensure that the rubber gasket on the base of the sampling unit forms a tight seal
around the cassette. The swing bolts are then tightened in a diagonal pattern to ensure even
pressure is applied to the cassette. Each time a sample is set up, the inside of the sampling head
and mating surfaces should be given a quick visual inspection for loose debris or corrosion
which could impact the filter and the integrity of the gasket on the size-selective inlet. Once the
cassette is installed, the inlet is closed and secured to the body of the sampling unit using the
cam-lock bolts.

If the sampling unit is equipped with electronic flow control to automatically adjust flow rate
based on ambient temperature and pressure, the sample schedule program must be verified
before the sampling unit is ready for collection. If the sampling unit is not equipped with
electronic flow control, the sampling unit must be powered on and allowed to run for minimally
five minutes (ten minutes are recommended) before a reading of the pressure drop across the
flow venturi, which must be cross-referenced to a corresponding calibrated flow. The unit is
then powered off and the sample schedule program verified.

Upon sample retrieval, instrument performance information including the average temperature,
barometric pressure, average flow, total collected volume, collection duration, and any flags
indicating a problem during collection should be recorded, downloaded, or otherwise recorded,
as appropriate. For sampling units without electronic flow control, the sampling unit must be
powered on and allowed to run for minimally five minutes (ten minutes are recommended)
before recording the reading of the pressure drop across the flow venturi. The filter sample
cassette is then removed from the sampling unit and the cover placed on the cassette (it is a best

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practice to place the filter cassette into a resealable plastic bag) until the filter may be removed
from the cassette in a clean area, free of obvious contamination, and with minimal air movement.

When removed from the cassette, the filter must be folded in half, lengthwise, with the
particulate matter inward. Folding the filter lengthwise is the best way to ensure that the
portioned filter strips include a portion of the fold. The folded filter must then be placed within a
manila or glassine envelope for transportation to the laboratory. Alternatively, the cover may be
replaced on the filter cassette and the cassette placed in a resealable plastic bag for transportation
to the laboratory where the filter is removed. Filters need not be shipped or stored cold. Filters
must be handled per the procedures in Section 4.4.3.1. The sample custody form must be
completed and accompany the collected sample at all times until relinquished to the laboratory.
COC documentation must comply with Section 3.3.1.3.7.

4.4.10.4.1 Sampling Schedule and Duration. Metals sample collection must be
performed on a l-in-6 days schedule for 24 ± 1 hours beginning at midnight and concluding at
midnight of the following day, standard local time (unadjusted for daylight savings time), per the
national sampling calendar. For missed or invalidated samples, a make-up sample should be
scheduled and collected per Section 2.1.2.1. Clock timers controlling sampling unit operation
must be adjusted so that digital timers are within ±5 minutes of the reference time (cellular
phone, GPS, or similar accurate clock) and mechanical timers within ±15 minutes.

4.4.10.5 QFF Digestion

4.4.10.5.1 Laboratory Digestion QC Samples. Each sample digestion batch must
consist of 20 or fewer field-collected filters (primary samples, collocated samples, and field
blanks). The following laboratory QC is required with each digestion batch:

-	Negative Control Samples (Blanks), one each:

o Reagent Blank - digestion solution only (no filter strip)
o Method Blank - blank filter strip with digestion solution

-	Positive Control Samples (Spikes), one each:

o RBS - spiked digestion solution only (no filter strip - ensures proper spike

recovery without the filter matrix)
o LCS - spiked blank filter strip with digestion solution (evaluates proper spike

recovery with blank filter matrix)
o LCSD - (optional) duplicate spiked blank filter strip with digestion solution
(evaluates precision of proper spike recovery with blank filter matrix)

-	Matrix QC Samples, one each:

o Duplicate Sample Strip - An additional strip cut from a collected field sample

(evaluates precision of the sample result and digestion process)
o Matrix Spike - An additional strip cut from a collected field sample which is
spiked at the same concentration as the LCS (provides information on matrix
effects on spike recovery)

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o Matrix Spike Duplicate - An additional strip cut from a collected field sample
which is spiked at the same concentration as the LCS (provides precision
information on matrix effects on spike recovery)

4.4.10.5.2 Digestion Procedure. Prior to digestion, filter samples must be examined
for damage to the filter or other defects (presence of insects, large visible particulates, etc.)
which may affect sample integrity or analysis results. Following inspection, the requisite
number of filter strips is to be cut from each filter to complete the digestion batch as listed above
in Section 4.4.10.5.1.

Sampled 8 inch x 10 inch QFF media have an exposed filter area of 7 inch x 9 inch, leaving a
'/2-inch border of unsampled area around the entire filter. Strips for digestion should be cut
perpendicular to the fold line for filters folded lengthwise as shown in Figure 4.4-1 and must not
include the unsampled V2 inch x 8 inch border section at each end (left and right in Figure 4.4-1).
This results in a 1 inch x 7 inch exposed section of the filter for each strip, equivalent to 1/9 of
the 63 in2 exposed filter area. Other conventions for portioning filter strips are acceptable so
long as they include 7 in2 of exposed filter area and a portion of the fold.

filter strips for digestion (1" x 8")
exposed area = 1" x 7"

Figure 4.4-1. Portioning of QFF Strips for Digestion

Filter sample strips may be digested using one of three methods: hot block digestion, microwave
digestion, or heated sonication.

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4.4.10.5.2.1 Hot Block Digestion

Each filter strip must be accordion folded or coiled and placed into separate digestion vessels.
Otherwise follow procedures as given in Section 4.4.9.5.2.1. Note that HF acid is not
recommended for digestion of QFFs.

4.4.10.5.2.2	High Volume QFF Microwave Digestion

Each filter strip must be accordion folded or coiled and placed into separate digestion vessels.
Otherwise follow procedures as given in Section 4.4.9.5.2.2. Note that HF acid is not
recommended for digestion of QFFs.

4.4.10.5.2.3	High Volume QFF Acid Sonication

Each filter strip must be accordion folded or coiled and placed into separate digestion vessels.
Otherwise follow procedures as given in Section 4.4.9.5.2.3. Note that HF acid is not
recommended for digestion of QFFs.

4.4.11	PMio Metals Analysis by ICP/MS - EPA IO-3.5

4.4.11.1	ICP/MS Instrumentation. In order to achieve the necessary sensitivity, PMio metals
for NATTS Program work must be analyzed via ICP/MS. Analysis via ICP-atomic emission
spectroscopy (ICP-AES), graphite furnace atomic absorption (GFAA), or flame atomic
absorption (FAA) is insufficiently sensitive and not permitted. ICP/MS instruments may be
equipped with either a quadrupole MS or a TOF MS. For either system of MS, the general
operation of the ICP is common and subject to the same interferences. The chosen instrument
must have the capability to minimally scan for masses ranging from 7 to 238 amu.

4.4.11.2	ICP/MS Interferences. ICP/MS instruments are susceptible to interferences which
can result in bias or saturation effects which overload the detector and require an extended period
to bring detector response back into the acceptable sensitivity range. Such interferences are
explained in more detail below.

Isobaric interferences are caused by isotopes of different elements which have the
same mass number as a target element. This results in a high bias for the target
element, but such biases may be corrected with standard equations in ICP/MS
software.

- Polyatomic, or molecular interferences are caused by combination of ions to form
molecular ions which have the same mass as a target element. These interferences
can result in high or low bias depending on the target element. Use of a collision
reaction cell to remove polyatomic interferences upstream of the MS detector can
greatly reduce or completely eliminate the effect of the interference.

Transport interferences are a result of matrix effects which alters aerosol formation
and results in changes to solution nebulization at the plasma. These interferences are
typically not an issue with air filter analysis as the concentration of dissolved solids in
digestates is fairly consistent from sample to sample.

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-	Matrix interferences are due to a chemical component in the solution which causes
suppression or enhancement of the measured signal. This interference can be
addressed by utilization of an internal standard or by diluting the sample digestate to
minimize the impact of the interference.

-	Memory, or carryover, interferences can occur when solutions of very high
concentrations are analyzed. The high concentration may be difficult to effectively
rinse from the ICP/MS sample introduction pathway resulting in contamination of
subsequent solutions or in the electron multiplier becoming saturated resulting in a
"burn in" where response factors of the ICP/MS are affected requiring substantial
time for sensitivity to return. Extensive rinsing times and/or recalibration may be
necessary to resolve such interferences.

4.4.11.3 Preparation of Calibration Standards for ICP/MS Analysis. Due to the instrument
sensitivity effects of dissolved solids, the matrix of standard solutions must exactly match that of
the final analyzed digestates. For example, if the final concentrations of acids in the analyzed
digestates are 2% (v/v) nitric acid, 0.5% (v/v) hydrochloric acid, and 0.1% (v/v) hydrofluoric
acid when samples are brought to volume, the acid concentrations in standard solutions must also
be 2%>, 0.5%), and 0.1%, respectively.

Aliquots of the stock standard solutions must be delivered with a Class A pipette or calibrated
mechanical pipettor. All standard solutions must be brought to final volume in a Class A
volumetric flask or equivalent Class A labware.

Stock single or multi-element solutions may be purchased commercially at certified
concentrations in dilute nitric acid (typically 3% v/v) which are conveniently diluted to working
concentration levels. Alternatively, stock solutions may be prepared gravimetrically by
weighing appropriate amounts of high purity element solids and dissolving them into dilute nitric
acid.

4.4.11.3.1	Primary Calibration Standards. Multi-element calibration standard
solutions are prepared by diluting primary certified stock standard solutions in dilute nitric acid
(typically 2% v/v). Calibration standard levels must cover a minimum of three non-zero
concentrations spanning the desired concentration range (typically 0.1 to 250 |ig/L depending on
the element), however five levels are strongly recommended. These standard solutions are
analyzed to generate the ICAL.

4.4.11.3.2	Secondary Source Calibration Verification Standard. A SSCV standard
solution, also referred to as the QC sample, must be prepared by dilution of the secondary source
stock standard solution with nitric acid (typically 2% v/v) to minimally a single concentration
approximately at the mid-range of the curve. Preparation of the SSCV at three different
concentrations covering approximately the lower third, mid-range, and upper third of the
calibration range is a best practice and is recommended. This secondary source standard must be
purchased from a different supplier. The SSCV stock may only be a different lot from the same
supplier if unavailable from another supplier.

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4.4.11.4	Internal Standards. ICP/MS analysis must include the evaluation of ISs to monitor
ion response of analyzed solutions and to correct for instrumental drift and matrix interferences.
A minimum of three IS elements must be co-analyzed with each solution. Suggested IS elements
include Bi, Ge, In, 6Li, Sc, Tb, 69Ga, Rh, and Y.

As relative responses of the target elements and IS elements are used to determine the final
concentration of the elements in solution, the concentration of the IS must be the same for each
analyzed solution. To achieve such, a known volume of the IS at a known concentration may be
added to a known volume of each solution to be analyzed, or the IS may be added to each
analyzed solution via a mixing coil on the ICP/MS sample introduction system. Further, IS
concentrations should approximate those in the analyzed samples. A concentration of no more
than 200 |ig/L is recommended.

As with the calibration stocks, acids, and reagent water, the IS stock solution must be from a
high purity source so as to minimize background levels of target elements.

IS responses must be monitored throughout the analysis and must be within 60 to 125% of the
response of the initial calibration blank (ICB). For samples or solutions which show responses
outside of this range, the instrument should be investigated to be sure the response change is not
due to instrument drift. Instrument drift causing failures in IS response require retuning of the
instrument and recalibration prior to continuing sample analysis.

4.4.11.5	Tuning Solutions. A tuning solution must contain elements covering the mass range
of interest so that the ICP/MS may be tuned and mass calibration and resolution checks may be
performed. A typical tuning stock solution contains isotopes of Li, Mg, Y, Ce, Tl, and Co at
approximately 10 mg/L and is diluted so that final concentrations are approximately 100 |ig/L or
less for each element.

4.4.11.6	ICP/MS Warm Up, MS Tuning, and Setup. The ICP/MS must be warmed up for a
minimum of 30 minutes, or a duration prescribed by the manufacturer, prior to use. The tuning
solution must be analyzed to perform mass calibration and resolution checks, which may be
performed during the warm up period. The MS must be optimized to provide a minimum
resolution of approximately 0.75 amu at 5% peak height and mass calibration within 0.1 amu of
unit mass. At a minimum five aliquots of the tuning solution must be analyzed and absolute
signal relative standard deviation for each analyte of < 5% must be achieved. Manufacturer
tuning recommendations may also be followed.

Standard, blank, and sample solutions should be aspirated for a minimum of 30 seconds to
equilibrate the ICP/MS response prior to acquiring data. Accelerated sample introduction
systems may lessen this equilibration time. The ICP/MS must be set up such that three replicate
integrations are performed for each analyzed solution. Each analysis result must be the average
of these replicate integrations.

A rinse blank of 2% nitric acid in deionized water should be used to flush the system between
analyzed solutions. The rinse blank solution should be aspirated for a sufficient time to ensure
complete return to baseline before the next sample, standard, or blank introduction. Depending

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on the sample introduction system, this may take approximately 60 seconds. Sample
introduction systems that increase the rinse blank speed are available to decrease rinse times.

4.4.11.7 ICP/MS Calibration and Analytical Sequence Batch. On each day that analysis is
performed, the instrument must be calibrated and the analysis batch QC samples listed in the
following subsections must be analyzed. Calibration acceptance criteria are given in the
following sections and are summarized in Section 4.4.13.

An example analysis sequence is given in Table 4.4-2.

Table 4.4-2. Example ICP/MS Analysis Sequence

Sequence
Number

Solution Analyzed



Sequence
Number

Solution Analyzed

1

Tuning solution



26

field sample 6

2

ICB



27

field sample 7

3

ICAL 1 (lowest concentration)



28

field sample 8

4

ICAL2



29

field sample 9

5

ICAL 3 (highest concentration)



30

field sample 7

6

ICV



31

field sample 8

7

ICB



32

field sample 9

8

ICS B



33

field sample 10

9

ICS A



34

field sample 11

10

ccv



35

field sample 12

11

CCB



36

field sample 13

12

RB



37

CCV

13

MB



38

CCB

14

LCS



39

field sample 14

15

LCSD



40

field sample 15

16

field sample 1



41

field sample 16

17

duplicate (field sample 1)



42

field sample 17

18

matrix spike (field sample 1)



43

field sample 18

19

matrix spike duplicate (field
sample 1)



44

field sample 19

20

field sample 2



45

replicate analysis (field sample 16)

21

field sample 3



46

1:5 serial dilution (field sample 19)

22

CCV



47

ICS B

23

CCB



48

ICS A

24

field sample 4



49

CCV

25

field sample 5



50

CCB

4.4.11.7.1 Initial Calibration. Once the mass calibration and tuning have met the
criteria listed in Section 4.4.11.6, the response of the instrument must be calibrated for the
elements of interest. Analyze the initial calibration blank (ICB, an undigested reagent blank)
followed by the calibration standard solutions. The calibration curve must include the ICB as the
zero concentration standard. Linear regression must be performed on the calibration solution
responses and must show appropriate linearity and the curve fit must have a correlation
coefficient (r) of 0.995 or greater. Replicate analyses of the calibration standards must show
%RSD < 10%.

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4.4.11.7.2	Initial Calibration Verification. Once the calibration curve is established,
the SSCV (or QC sample) must be analyzed as the initial calibration verification (ICV) and must
recover within ± 10% of the nominal value.

4.4.11.7.3	Initial Calibration Blank. The ICB is again analyzed following the ICV;
all element responses must be less than the laboratory's established MDLsp for MDLs determined
via Section 4.1.3.1 or the portion of the MDL represented by s K for MDLs determined via
Section 4.1.3.2. If the ICB does not meet this criterion, the analysis sequence must be stopped
and the source of the contamination found before analysis may continue.

4.4.11.7.4	Interference Check Standard. Once the instrument has been calibrated,
the calibration verified by analysis of the ICV, and the system shown to be free of contaminants
by analysis of the ICB, the instrument must be shown to be free of interferences by analysis of an
interference check standard (ICS). The ICS must be analyzed immediately following the ICB,
every 8 hours of continuous operation, and at the conclusion of the analysis sequence just prior
to the final CCV.

Analysis of the ICS allows for the explicit demonstration that known isobaric and/or polyatomic
interferences do not impact concentration results. Two types of ICS should be analyzed. A Type
A ICS contains elements known to form interferences, and a Type B ICS consists of a standard
solution of target elements subject to interferences from elements in ICS Type A. ICS Type A
solutions should contain high levels of elements such as Al, Ca, CI, Fe, Mg, Mo, P, K, Na, S, and
Ti at 20 to 20,000 mg/L which are known interferences to target elements such as As, Cd, Cr,
Co, Cu, Mn, Ni, and Se. These target elements should be present in ICS Type B solutions at
concentrations of approximately 10 to 20 mg/L, or lower concentrations, as appropriate,
anticipated to interfere with the analysis.

Analysis of ICS Type A must demonstrate that concentrations of all target analytes are less than
3x MDLsp (for MDLs determined by Section 4.1.3.1) or three-fold the portion of the MDL
represented by s K for MDLs determined via Section 4.1.3.2. Note that ICS Type A solutions
typically contain target analytes at quantifiable concentrations. ICS certificates of analysis
should be examined to determine whether observed concentrations above this criterion are due to
contaminant levels in the ICS Type A solution. Background subtraction of these levels may be
necessary if observed concentrations exceed the acceptance criterion. The ICS Type B solution
must show recovery of target elements of 80 to 120%. Concentrations of target elements in
samples which exceed the concentrations in ICS Type B solutions should be diluted and
reanalyzed.

ICP/MS equipped with reaction collision cells are less susceptible to isobaric and polyatomic
interferences than those without and may demonstrate little to no measureable interferences
when analyzing Type A ICS solutions. However, to ensure the collision reaction cell is
operating properly, the ICS Type A and Type B solutions must be analyzed minimally once each
day of analysis to ensure proper operation of the cell.

4.4.11.7.5	Continuing Calibration Verification. At a minimum, a CCV must be
prepared at a single concentration at approximately the mid-range of the calibration curve, must

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be diluted from the primary stock or secondary source stock solution, and must be analyzed
following the ICS, prior to the analysis of samples, after the analysis of every 10 digestates, and
at the end of the analytical sequence. CCV recovery must be 90 to 110% for each target element.
As a best practice, two or more concentrations of CCV may be prepared and analyzed so as to
better cover instrument performance across the range of the calibration curve.

4.4.11.7.6	Continuing Calibration Blank. The CCB is from the same solution as the
ICB and must be analyzed after each CCV to ensure the instrument background remains
acceptably low. A CCB is not required after the CCV concluding the analysis sequence. CCB
analysis must show that the absolute value of the instrument concentration response for each
target element is less than the laboratory's established MDLsp for MDLs determined via Section
4.1.3.1 or the portion of the MDL represented by s K for MDLs determined via Section 4.1.3.2.
If the CCB does not meet this criterion, the analysis sequence must be stopped and the source of
the contamination found before analysis may continue. Samples analyzed since the last
acceptable CCB require reanalysis.

4.4.11.7.7	Laboratory Digestion Batch Quality Control Samples. Laboratory
digestion batch QC samples for low volume Teflon® and high volume QFF media described in
Sections 4.4.9.5 and 4.4.10.5, respectively, are analyzed with each analysis batch. Laboratory
QC samples (consisting of RBs, MBs, RBSs, and LCSs) are analyzed after the first CCV and
CCB pair and should be analyzed prior to the analysis of field samples in the same digestion
batch. Duplicate digested samples, matrix spikes, and matrix spike duplicates similarly should
be analyzed immediately following their parent field sample. In order to minimize reanalysis if
more than one digestion batch is included in an analysis batch, each digestion batch should be
analyzed altogether and separated by a CCV and CCB prior to analysis of the next digestion
batch.

4.4.11.7.8	Serial Dilution. A sample must be chosen for each analysis batch for
serial dilution. A sample digestate should be diluted five-fold and fortified with IS (so that the
concentration of the IS is the same as in the parent sample). Element concentrations for elements
> 5x MDL in the serially diluted sample must recover within 90 to 110% of the undiluted
sample.

4.4.11.7.9	Replicate Analysis. A replicate of digestate from a field-collected sample
must be analyzed at the minimum rate of one for every 20 field-collected samples in the analysis
batch. Precision of the replicate analysis must be < 10% RPD for elements > 5x MDL.

4.4.11.8 ICP/MS Data Review and Concentration Calculations. The concentration for each
field-collected sample must be reported in ng/m3 in local conditions. Results may additionally
be reported by correction to standard atmospheric conditions of 25°C and 760 mm Hg.
Conversion of collected volume in local conditions to standard conditions is performed as
follows:

n _ Pa " Qa " Ts

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where:

Qs =	flow at standard conditions (760 mmHg and 25°C)

Ps =	standard barometric pressure = 760 mmHg

Ts =	standard temperature in K = 298.15K

Qa =	flow at ambient conditions

Pa =	ambient barometric pressure in mmHg

Ta =	ambient temperature in K

Results must not be corrected for calibration blank or MB levels. Concentrations exceeding
acceptance criteria for these blanks must prompt investigation as to the source of contamination.

Concentration results which exceed the instrument calibration range must be diluted and
analyzed within the calibration range. The diluted result must be reported and the associated
MDL adjusted accordingly by the dilution factor. For example, if the sample is diluted by a
factor of two to analyze nickel within the calibration curve, the MDL should be increased by a
factor of two when reporting to AQS.

Negative concentration results which exceed the absolute value of the laboratory's established
MDLsp for MDLs determined via Section 4.1.3.1, or the portion of the MDL represented by sK
for MDLs determined via Section 4.1.3.2. MDLsp for field-collected samples indicate the likely
existence of contamination problems in the reagents, standards, or labware used to prepare the
calibration curve. Negative concentrations should not be qualified as "9" when entered in AQS
as this qualifier indicates that negative concentrations were replaced with zero. Overly negative
concentrations are further discussed in Section 6.6.1.

4.4.11.8.1 Concentration Calculations for Low Volume Sampling. To calculate the
airborne concentration of each element measured on the Teflon® filter, the ICP/MS measured
concentration in |ag/m L is multiplied by the sample digestate final volume in mL and by the
dilution factor (if dilution of the digestate was performed), and is divided by the sampled air
volume in m3, as follows:

_ Cicp/ms 1 Vdig 1 DF

^air —

1000 -vair

where:

Cair = Concentration of the element in air at local conditions (ng/m3)

Cicp/ms = Concentration measured in the sample digestate (|ig/mL)

Vdig = Volume of digestate (mL)

DF = Dilution factor

Vair = Volume of air sampled (m3)

4.4.11.8.2 Reporting of Concentrations for High Volume Sampling. To calculate
the airborne concentration of each element measured on the QFF, the ICP/MS measured
concentration in |ag/m L is multiplied by the final digestate volume in mL, by the fraction of the

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filter digested for analysis, and by the dilution factor (if dilution of the digestate was performed),
then is divided by the sampled air volume in m3, as follows:

_ CICp/ms ' Vdig ' DF 1 Ff
air ~ 1000 ¦ Vair

where:

Cair =

Concentration of the element in air at local conditions (ng/m3)

ClCP/MS =

Concentration measured in the sample digestate (ng/mL)

Vdig =

Volume of digestate (mL)

DF =

Dilution factor

Ff =

Fraction of exposed filter digested a

Vair —

Volume of air sampled (m3)

a For a 1 inch x 8 inch strip portioned as described in Section 4.4.11.5.2, this is equivalent to 1/9 by dividing the
exposed area of the portioned strip by the area of the exposed filter.

(1 inch x 7 inch = 7 in.2)/(7 inch x 9 inch = 63 in.2) = 1/9

4.4.12 Summary of Method Quality Control Requirements. QC requirements are
summarized in Table 4.4-3.

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Table 4.4-3. Method Criteria Parameters for NATTS Metals Analysis

Parameter

Description and Details

Required Frequency

Acceptance Criteria

ICP/MS Tuning

ICP/MS mass calibration and
resolution checks

Analysis of a minimum of
five aliquots of the tuning
solution each day of
analysis prior to ICAL

Absolute signal of five replicates
RSD < 5%

Mass calibration within 0.1 amu
of unit mass

Resolution check within
0.75 amu at 5% peak height

Alternatively, must meet
manufacturer tuning criteria

Internal Standards
Addition

Elements other than target
elements used to monitor
instrument performance and
correct for matrix effects

Added to each analyzed
solution

Recovery within 60-125% of the
response of the initial calibration
blank

Rinse Blank

2% (v/v) HNO3 aspirated to
eliminate memory effects
between solutions

Following each analyzed
solution

Duration of aspiration sufficient
to eliminate element carryover
as evidenced by successful
CCVs and CCBs

Initial Calibration
(ICAL)

Minimum of three levels
covering the desired
concentration range plus the
calibration blank

Each day analysis is
performed

Correlation coefficient (r)
>0.995

Initial Calibration
Verification (ICV)

Second source calibration
verification (SSCV) or QC
standard analyzed to verily the
ICAL

Each day of analysis
immediately following the
ICAL

Recovery within 90-110% of
nominal for all target elements

Initial Calibration
Blank (ICB)

Calibration blank analyzed to
ensure instrument is sufficiently
clean to continue analysis

Each day of analysis
immediately following the
ICV

All target elements
< MDLSp (refer to Section

4.1.3.1)	or s-K (refer to Section

4.1.3.2)

Interference Check
Standard (ICS) A

Solution containing known
interferences analyzed to
demonstrate that the effect of
such interferences is
sufficiently low

Following the ICB, after
every 8 hours of analysis,
and just prior to the
concluding CCV

Once daily for ICP-MS
equipped with collision
reaction cell

All target elements
< MDLSp (refer to Section

4.1.3.1)	or s-K (refer to Section

4.1.3.2)	- may be subtracted for
ICS A certificate of analysis

Interference Check
Standard (ICS) B

Solution containing target
elements at high concentrations
to demonstrate acceptable
recovery

Following the ICB, after
every 8 hours of analysis,
and immediately
preceding ICS A

Once daily for ICP-MS
equipped with collision
reaction cell

Recovery within 80-120% of
nominal for all target elements

Continuing Calibration
Verification (CCV)

Calibration or second source
standard analyzed to verily
instrument remains in
calibration

Immediately following
the initial ICS, after every
10 samples and at the
conclusion of the analysis
sequence

Recovery within 90-110% of
nominal for all target elements


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Table 4.4-3. Method Criteria Parameters for NATTS Metals Analysis (Continued)

Parameter

Description and Details

Required Frequency

Acceptance Criteria

Continuing Calibration
Blank (CCB)

Analysis of the calibration
blank solution to ensure
instrument is sufficiently clean
to continue analysis

After each CCV except at
the conclusion of the
analysis sequence

All target elements
< MDLSp (refer to Section

4.1.3.1)	or s-K (refer to Section

4.1.3.2)

Reagent Blank (RB)

Aliquot of digestion solution
taken through the digestion
process

One per digestion batch of
20 or fewer field-
collected samples

All target elements
< MDLSp (refer to Section

4.1.3.1)	or s-K (refer to Section

4.1.3.2)

Method Blank (MB)

Blank filter or filter strip taken
through the digestion process

One per digestion batch of
20 or fewer field-
collected samples

All target elements
< MDL

Reagent Blank Spike
(RBS)

Aliquot of digestion solution
spiked with known amount of
target elements and taken
through the digestion process

One per digestion batch of
20 or fewer field-
collected samples

Recovery within 80-120% of
nominal for all target elements

Laboratory Control
Sample (LCS)

Filter or filter strip spiked with
a known amount of each target
element and taken through the
digestion process

One per digestion batch of
20 or fewer field-
collected samples

Recovery within 80-120% of
nominal for all target elements,
Sb recovery 75-125%.

Laboratory Control
Sample Duplicate
(LCSD)

Duplicate filter or filter strip
spiked with a known amount of
each target element and taken
through the digestion process

(Optional) One per
digestion batch of 20 or
fewer field-collected
samples

Recovery within 80-120% of
nominal for all target elements,
Sb recovery 75-125%,
precision < 20% RPD of LCS

Duplicate Sample
Strip

Additional strip from a field-
collected filter taken through
the digestion process

*QFF only*

One per digestion batch of
20 or fewer field-
collected samples

Precision < 20% RPD for
elements > 5x MDL

Matrix Spike

Strip from a field-collected
filter spiked with a known
amount of each target element
and taken through the digestion
process

*QFF only*

Once per analysis batch of
20 or fewer samples

Recovery within 80-120% of the
nominal spiked amount for all
target elements, Sb recovery 75-
125%.

Matrix Spike
Duplicate

Additional strip from the same
field-collected filter as the MS,
and spiked with the same
amount of each target element
as the MS, and taken through
the digestion process

*QFF only*

One per digestion batch of
20 or fewer field-
collected samples

Recovery within 80-120% of the
nominal spiked amount for all
target elements, Sb recovery 75-
125%,

precision < 20% RPD of MS

Collocated Sample

Sample collected from a
separate sampling unit
concurrently with the primary
sample

10% of primary samples
for sites conducting
collocated sampling (as
required by workplan)

Precision < 20% RPD of primary
sample for elements > 5x MDL

Serial Dilution

Five-fold dilution of a sample
digestate to assess matrix
effects

One per digestion batch of
20 or fewer field-
collected samples

Recovery within 90-110% of
undiluted sample for elements >
25x MDL

Replicate Analysis

Second aliquot of a sample
digestate chosen for replicate
analysis

One per digestion batch of
20 or fewer field-
collected samples

Precision < 20% RPD for
elements > 5x MDL

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4.4.13	References

1.	Determination of Metals in Ambient Particulate Matter Using Inductively Coupled
Plasma/Mass Spectrometry (ICP/MS); EPA Compendium Method 10-3.5; Compendium of
Methods for the Determination of Inorganic Compounds in Ambient Air, EPA/625/R-
96/010a; U.S. Environmental Protection Agency: Center for Environmental Research
Information. Office of Research and Development. Cincinnati, OH. June 1999. Available at
(accessed October 19, 2016):

https://www3.epa.gov/ttnamtil/files/ambient/inorganic/mthd-3-5.pdf

2.	Care and Safe Handling of Laboratory Glassware. Corning Incorporated. RG-CI-101-REV2.
2011. Available at (accessed October 19, 2016):

http://csmedia2.corning.com/LifeSciences/media/pdf/Care and Safe Handling Lab Glassw
are RG-CI-101Rev2.pdf

3.	Sampling of Ambient Air for PM10 Concentration using the Rupprecht and Pataschnick
(R&P) Low Volume Partisol ® Sampler; EPA Compendium Method 10-2.3; Compendium of
Methods for the Determination of Inorganic Compounds in Ambient Air, EPA/625/R-
96/010a; U.S. Environmental Protection Agency: Center for Environmental Research
Information. Office of Research and Development. Cincinnati, OH. June 1999. Available at
(accessed October 19, 2016):

https://www3.epa. gov/ttnamti l/files/ambient/inorganic/mthd-2-3 .pdf

4.	Section, Preparation, and Extraction of Filter Material; EPA Compendium Method 10-3.1;
Compendium of Methods for the Determination of Inorganic Compounds in Ambient Air,
EPA/625/R-96/010a; U.S. Environmental Protection Agency: Center for Environmental
Research Information. Office of Research and Development. Cincinnati, OH. June 1999.
Available at (accessed October 19, 2016):

https://www3.epa.gov/ttn/amtic/files/ambient/inorganic/mthd-3-l.pdf

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4.5	Collection and Analysis of PAHs via EPA Compendium Method TO-13A

Each agency must codify in an appropriate quality systems document, such as an SOP, or
equivalent, its procedures for performing PAHs sampling, media extraction, and extract analysis.
Various requirements and best practices for such are given in this section. Note that regardless
of the specific procedures adopted, method performance specifications as given in Section 4.5.6
must be met.

4.5.1	Summary of Method. PAHs, which are semivolatile organic compounds (SVOCs),
are collected per the guidance given in EPA Method TO-13A 1 and ASTM D6209.2 These two
methods are similar and share collection media specifications: utilizing a quartz fiber particulate
filter and glass thimble containing PUF and styrene-divinylbenzene polymer resin sorbent
(XAD-2 or equivalent) to collect PAHs from ambient air.

Approximately 200 to 350 m3 of ambient air is drawn through a quartz fiber particulate filter and
cartridge containing a "sandwich" of PUF-resin-PUF over 24 hours. The QFF and contents of
the cartridge are extracted by way of accelerated solvent extraction (ASE)3 or in a Soxhlet
apparatus, and the extract is analyzed by GC/MS. Concentrations of PAHs in ambient air are
generally low (0.02 to 160 ng/m3), thus a large volume of air must be collected to ensure
sufficient mass is present for quantification with a typical quadrupole MS in SIM mode.

The more volatile PAHs, such as naphthalene, are subject to potential loss from the cartridges
due to, for example, volatilization and decomposition from exposure to light. 4'5 Thus, PAH
cartridges should be collected from the sampling unit, protected from light, and brought to < 4°C
as soon as possible after the end of the sampling period. Shipment and storage at refrigerated
temperatures will further minimize evaporative losses of the more volatile PAHs. PAHs with
higher volatility may also be lost from the sorbent cartridge during sampling due to migration out
of the cartridge outlet (breakthrough) or from volatilization from the QFF, especially during
warm weather.6'7

The PAHs including, but not limited to, those in Table 4.5-1 may be determined by this method.

4.5.2	Sample Collection Equipment. A high volume PS-1 style sampler, or equivalent,
which is able to maintain a minimum flow rate of 140 L/min over a 24-hour sampling period is
required. Such sampling units are commercially available with various conveniences. The most
basic units are equipped with an event timer and an elapsed time counter to control and indicate
duration of sample collection. Flow rate is controlled by the fan motor speed, ball valve, or
combination. A manometer (such as a magnehelic) is attached to the ports on a venturi located
between the sampling inlet and the fan motor to indicate the pressure differential which
correlates to the flow rate. Computer control is available on more expensive systems; such units
have an automatic start/stop timer, indicate elapsed sampling time, monitor and record flow rates
over the course of the collection event, indicate start and stop times, and monitor the pressure
differential and adjust the blower speed to ensure a user defined flow setpoint is maintained.

Each high volume sampler should have an extension tube for the motor exhaust to ensure that the
sampled atmosphere is not resampled. If so equipped, the exhaust tube must terminate in the

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predominant downwind direction minimally 3 meters away from the unit. Care should be taken
to ensure that the exhaust does not interfere with other sampling units at the site. The sampling
unit inlet must minimally be 2 meters from all other sampling inlets. Sampler siting
requirements are listed in Section 2.4.

Table 4.5-1. PAHs and Associated Chemical Abstract Numbers (CAS)

Target Compound

CAS Number

Acenaphthene b

83-32-9

Acenaphthylene

208-96-8

Anthracene b

120-12-7

Benzo(a)anthracene

56-55-3

Benzo(a)pyrene a b

50-32-8

Benzo(e)pyrene

192-97-2

Dibenzo(g,h,i)perylene

191-24-2

Benzo(b)fluoranthene

205-99-2

Benzo(k)fluoranthene

207-08-9

Chrysene

218-01-9

Coronene

191-07-1

Dibenzo(a,h)anthracene

53-70-3

Fluoranthene b

206-44-0

Fluorene b

86-73-7

9-Fluorene

486-25-9

Indeno( 1,2,3 -cd)pyrene

193-39-5

Naphthalene a b

91-20-3

Perylene

198-55-0

Phenanthrene b

85-01-8

Pyrene b

129-00-0

Retene

483-65-8

a NATTS Tier I core analyte
b NATTS PT target analyte

4.5.2.1	Sampler Flow Calibration and Verification. Sampler flow must be calibrated
initially and when flow verification checks indicate flows deviate by more than 10% from the
flow transfer standard flow or design flow. Flow verification checks must be performed
quarterly, and are recommended to be performed monthly. Flow verifications must be
performed at approximately the setting utilized to collect field samples.

Flow calibration of a non-mass flow controlled sampler (those without computer control) must
be performed with a traceable, calibrated flow transfer standard capable of inducing various
backpressures to generate different sampling unit flow rates that bracket the target flow rate.
Such may be accomplished with an electronic flow meter, a variable orifice, or a series of fixed
plate orifices, or similar. The known inlet flows must then be correlated to the measured
manometer readings at the flow venturi. Computer controlled units must be electronically
adjusted so the flow settings correlate to the calibrated flow rate as indicated by the flow transfer
standard.

4.5.2.2	Sampling Unit Maintenance. Each site must have a defined maintenance schedule
for the PAHs sampling units, recommended to be monthly, but may not exceed quarterly.
Included in this maintenance must be the schedule for the periodic cleaning of the sampling

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heads. Sampling heads should be washed with chromatographic grade hexane, acetone, or other
suitable solvent to ensure subsequent samples are not contaminated. Use of such solvents should
be performed with proper ventilation (e.g. fume hood) and with proper personal protective
equipment (PPE - such as solvent impermeable gloves, lab coat, and safety glasses). Other
maintenance items should include: inspection of sampling unit electrical connections, check of
timers for proper operation, replacement of motors and motor brushes, removal of debris from
underneath the gable and inside the upper portion of the sampling unit, and inspection of sealing
gaskets.

4.5.3 Sampling Media and Their Preparation. Regardless of the source of materials or
the specific cleaning procedures each agency adopts, the QFF and PUF/XAD-2/PUF present in
cartridges must meet the batch blank acceptance criteria of < 10 ng each for all target
compounds. A batch blank is a complete cartridge (including a QFF) selected from among those
purchased in a single lot or from among each batch of cartridges prepared with a specific batch
of cleaned media. Note that media components may be analyzed separately, but must meet the
cleanliness criterion.

Particulate filters for sample collection are quartz fiber, 102 to 104 mm diameter with 2-\im pore
size. All filters must be inspected on a light table or similar for pinholes, discolorations, tears, or
other defects such as thin spots; air samples must not be collected with those found to be
unsuitable. After inspection, filters should be baked (in a muffle furnace) at 400°C for a
minimum of 4 hours to remove potential impurities and interferences. Once cooled, the filters
should be stored in a sealed container to ensure they do not become contaminated prior to sample
collection.

PUF plugs are available commercially, or they may be prepared by cutting plugs of the proper
diameter (2 3/8 inch) from PUF sheets of 1.5-inch thickness. PUF plugs may be purchased raw
and cleaned by the laboratory prior to use, or may be purchased precleaned. Some precleaned
PUF plugs do not meet cleanliness criteria for target analytes or may contain interferences which
require subsequent cleaning procedures prior to use for sample collection. Precleaned PUF plugs
are typically shipped with a certificate of analysis listing the contaminant levels for common
PAHs. Following sample extraction, used PUF plugs may be cleaned for reuse, if so desired.

Styrene-divinylbenzene polymer resin, such as XAD-2, is commercially available and may be
purchased with or without precleaning. As with precleaned PUF, some precleaned resins do not
meet cleanliness criteria for target analytes or may contain interferences which require
subsequent cleaning procedures before use for sample collection. Precleaned resin sorbent is
generally shipped with a certificate of analysis listing the contaminant levels for common PAHs.
Following sample extraction, used resin may be cleaned for reuse. The resin physically degrades
and disintegrates over time, requiring periodic replacement.

PUF and/or resin sorbents should be cleaned before reuse with a specialized solvent extraction
program that is slightly different than the method by which the QFF, PUF, and resin from a
sample cartridge are extracted. A more aggressive solvent or combination of solvents such as
methylene chloride (not suitable for PUF cleaning), toluene, hexane, and/or acetone should be

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employed to remove target analytes and interferences from the PUF and resin media for
cleaning.

All clean media should be stored in sealed containers protected from light (aluminum foil, amber
glass, etc.).

4.5.3.1	Glassware Cleaning. Glass thimbles, extraction glassware, and volumetric glassware
for preparing standard solutions must be thoroughly cleaned and contaminant-free prior to use
such that blank criteria are met as given in Section 4.5.6. Aggressive washing with hot water and
laboratory grade soap, tap water rinsing, deionized water rinsing, acid or base rinsing, and
solvent (methylene chloride) rinsing may be necessary to ensure that contaminants and
interferences are removed from labware prior to use. Non-volumetric glassware may be baked at
400°C for 4 hours. Volumetric glassware must not be heated above 80 to 90°C unless otherwise
indicated by the manufacturer as such heating voids the volumetric certification.8 Following the
final solvent rinse, clean labware should be capped or covered (as appropriate) with solvent
rinsed foil to prevent contamination with dust, etc.

4.5.3.2	Cartridge Preparation. If cartridges are assembled in house, they must be assembled
in batches, and the lots of media contained in the cartridges must be traceable so as to maintain
the ability to track potential contamination. One assembled cartridge from each batch of 20 or
fewer assembled cartridges must be extracted as a batch blank. The batch blank ensures the
cleaned media and preparation results in acceptably low background levels of target PAHs.

The following procedure should be followed to prepare cartridges. Tools contacting sampling
media are solvent rinsed and technicians must wear gloves during cartridge preparation. One
1.5-inch thick PUF plug is placed into the inlet of the cartridge and pushed down to contact the
support screen. Note that glass thimble cartridges equipped with a glass frit support are not
suitable for NATTS sample collection. The glass frit creates an excessive flow restriction
resulting in pre-mature wear and failure of motors and brushes. A 15-gram aliquot of clean resin
is then added to the cartridge on top of the PUF plug and distributed evenly. The second 1.5-
inch thick PUF plug is then placed on top of the resin layer to retain the resin layer in place.

For storage, cartridges should be wrapped in solvent rinsed foil, sealed in a resealable plastic bag
or other container, and kept at < 4°C.

4.5.3.3	Field Surrogate Addition. Prior to dispatching sample cartridges to the field, field
surrogate compounds must be added to the sorbent media. The recovery of field surrogate
compounds is evaluated to assess the retention of PAHs during air sampling as well as the
performance of the sample media handling, extraction, and analysis procedures.

Field surrogates should be added by spiking 1 |ig (e.g., 100 |iL of a 10 |ig/mL solution in
methylene chloride, toluene, hexane, or other suitable solvent) of, for example, fluoranthene-dio
and benzo(a)pyrene-di2 directly into the PUF and resin sorbent. Field surrogates are added no
sooner than two weeks prior to the scheduled sample collection date.

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4.5.4 PAH Sampling. Sample media must be installed into the sampling unit as close to
the sampling date as possible to minimize positive bias due to passive sampling of the sorbent
media. At the time of installation, sampling units without computerized flow control must be
allowed to warm up for minimally five ten minutes (ten minutes are recommended) prior to
recording the initial flow rate, i.e., the manometer reading. Computer-controlled sampling
instruments do not require this warm-up period to record the initial flow. The ambient
barometric pressure and temperature must be measured with calibrated instruments and recorded.

The QFF and cartridge are loaded into a sampling head. At the head's outlet is a cam-lock
connection which connects the head to the PS-1 sampling unit, and at the head inlet is a threaded
ring filter holder to accept the QFF. The head may be unscrewed in the middle such that the
glass cartridge may be inserted inside into a cartridge body. Inert gaskets (such as silicone
rubber) are placed in the top and bottom of the cartridge body inside the sampling head. A filter
is placed onto the support screen of the filter holder, and an inert gasket (such as
polytetrafluoroethylene [PTFE]) seals the filter to the top filter retaining ring. The filter is
protected during handling by a cover secured to the filter holder with three swing bolts.

4.5.4.1a Sampling Schedule and Duration. PAHs sample collection must be performed
on a l-in-6 days schedule for 24 ± 1 hours beginning at midnight and concluding on midnight of
the following day, local time unadjusted for daylight savings time, per the national sampling
calendar. For missed or invalidated samples, a make-up sample should be scheduled and
collected per Section 2.1.2.1. Clock timers controlling sampling unit operation must be adjusted
so that digital timers are within ±5 minutes of the reference time (cellular phone, GPS, or similar
accurate clock) and mechanical timers within ±15 minutes.

4.5.4.1b Retrieval, Storage, and Transport of QFFs and Cartridges. The QFF and glass
cartridge must be retrieved as soon as possible after the conclusion of sampling in order to
minimize the evaporative loss of the more volatile PAHs, preferably within 24 hours, but not to
exceed 72 hours of the end of collection. Such is particularly important during warm weather.
As with sample setup, units without computerized flow control must be allowed to warm up for
minimally five minutes (ten minutes are recommended) prior to recording the manometer
reading, which is recorded as the ending flow setting. Computer-controlled sampling units do
not require this warm-up period. The ambient barometric pressure and temperature must be
measured with calibrated instruments and recorded.

To retrieve a sample, the following procedure should be followed. It is recommended that the
operator dons non-latex powder-free gloves to place the filter cover onto the filter inlet and
secure the cover with the swing bolts. The operator then releases the cam-locks, disconnects the
sampling head from the sampling unit, and covers the outlet end of the sampling head with foil
or suitable plug. The assembled sampling head is transported to a clean indoor environment, free
of obvious PAHs sources, for disassembly. If the disassembly is to occur more than 10 minutes
following sample retrieval, the sampling head is stored and transported refrigerated.

For sampling head disassembly, gloves must be donned, the filter cover removed, and the filter
carefully retrieved and folded into fourths with the particulate matter inward. The folded filter is
then inserted into the glass thimble cartridge with the sorbent media. It is not acceptable to place

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the folded filter into a secondary container such as a petri dish, as jostling of the filter inside the
petri dish may result in loss of PM to the inside of the dish. Storage inside the glass cartridge
minimizes disturbance of PM to ensure that PM is either on the filter or within the PUF inside
the glass thimble. The glass thimble cartridge is removed from the sampling head, wrapped in
solvent-rinsed foil, and placed within a protective jar or case for shipment.

The protective jar or case containing the cartridge must be stored at < 4°C until shipment to the
laboratory. The sample should be kept cold during shipment such that the temperature remains
< 4°C, and the temperature of the shipment must be determined upon receipt at the laboratory.
For transport of samples which are retrieved at a site and delivered to the laboratory on the day
of retrieval, it may be difficult to sufficiently cool samples to < 4°C by the time they are received
at the laboratory. It is imperative that samples be placed into cold storage for transport as soon
as possible after retrieval, so samples arrive at the laboratory chilled. Samples which are shipped
overnight should be packed with sufficient cold packs or ice to ensure they arrive at the
laboratory at < 4°C. The sample custody form must be completed and accompany the collected
sample at all times until relinquished to the laboratory. COC documentation must comply with
Section 3.3.1.3.7. If cartridges are broken, resin has escaped, or the sampling media otherwise
compromised, the sample must be voided.

4.5.4.2	Field Blanks. Field blanks must be collected minimally monthly. A field blank is a
complete blank cartridge and QFF fortified with field surrogates and assembled in a sampling
head identically to a field-collected sample except that there is no sample flow. To collect a field
blank, the assembled sampling head is minimally installed into the sampling unit and the filter
cover removed for minimally 5 minutes. The field blank is then retrieved as a regularly collected
field sample and placed into cold storage until the co-collected field sample is
transported/shipped to the laboratory for analysis.

Field blanks must show that all target PAHs are < 5x MDL. Results for field collected samples
associated with the failing field blank and collected since the last acceptable field blank must be
appropriately qualified when entered into AQS.

An exposure blank is similar to a field blank, but is not required, and may be collected via
several protocols. The exposure blank includes exposing the filter and sorbent media to the
ambient conditions by installation in a sampling unit, and just like a field blank, air is not drawn
through the exposure blank sampling head. The exposure blank sample may be installed in the
primary sampling unit on non-sample collection days or may be installed in a collocated
sampling unit during collection of the primary sample.

4.5.4.3	Collocated Sampling. Collocated samples must be collected at a frequency of 10%
of the primary samples for sites conducting collocated sampling (as required by the workplan).
A collocated sample is a second assembled sampling head (cartridge and QFF) collected via a
separate PAHs sampling unit. The collocated sampling unit inlet must be between 2 to 4 meters
from the primary sampling inlet.

Collocated samples must demonstrate precision < 20% RPD for instrument measured
concentrations > 0.5 |ig/mL. Root cause analysis must be performed for instances in which

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collocated samples fail this precision specification and the results of the primary and collocated
samples must be qualified when entered into AQS.

4.5.5 PAH Extraction and Analysis

4.5.5.1 Reagents and Standard Materials

4.5.5.1.1	Solvents. Solvents employed for extraction and preparation of standards
solutions must be high-purity chromatographic grade, and shown by analysis to be free of
contaminants and interferences. Suitable solvents include dichloromethane, n-hexane, methanol,
diethyl ether, and acetone.

4.5.5.1.2	Calibration Stock Materials. Calibration source material must be of
known high purity and must be accompanied by a COA. Calibration materials should be neat
high purity solids or sourced as certified single component or component mixtures of target
compounds in solvent.

Neat solid material must be weighed with a calibrated analytical balance with the appropriate
sensitivity for a minimum of three significant figures in the determined standard mass. The
calibration of the balance must be verified on the day of use with certified weights bracketing the
masses to be weighed. Calibration standards diluted from stock standards should be prepared by
delivering stock volumes with mechanical pipettes (preferably positive displacement) or gastight
syringes calibrated and the volumes dispensed into Class A volumetric glassware to which
solvent is added to establish a known final dilution volume.

4.5.5.1.2.1 Secondary Source Calibration Verification Stock Material

A secondary source standard must be prepared to verify the calibration of the GC/MS on an
ongoing basis. This secondary source stock standard must be purchased from a different supplier
than the calibration stock. The SSCV stock may only be a different lot from the same supplier if
unavailable from another supplier.

4.5.5.1.3	Internal Standards. ISs are required to correct for both short-term
variability in GC/MS performance and for potential matrix effects. ISs must be added to all
analyzed solutions at the same concentration. IS compounds should be chemically and
chromatographically similar to the target compounds.

Deuterated analogs of target compounds are recommended as ISs. Suggested deuterated
standards include: naphthalene-ds, acenaphthene-dio, perylene-di2, phenanthrene-dio, and
chrysene-di2. These ISs should be purchased as high purity single or multi-component mixtures
in solvent. Note that deuterated standards also contain small amounts of the target compound
which may appear as contamination if the concentration of IS added is too high.

4.5.5.1.4	Surrogate Compounds. Surrogate compounds are required to monitor and
assess the retention of PAHs on the adsorbent media and the performance of the sample media
handling, extraction, and analysis procedures. Two types of surrogate compounds are prescribed

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for the subject method, field surrogates and extraction surrogates. As with ISs, deuterated
analogs of target compounds are recommended for surrogate compounds.

4.5.5.1.4.1	Field Surrogate Compounds

Field surrogates are required and were previously described in Section 4.5.3.3. Fluoranthene-dio
and benzo(a)pyrene-di2 are the recommended field surrogate compounds. Stock standard
solutions of these two surrogate compounds in solvent are commercially available and are
diluted to working concentrations in suitable solvent (i.e., hexane).

4.5.5.1.4.2	Extraction Surrogate Compounds

Extraction surrogate compounds must be added to the sample media just prior to extraction and
their recoveries are evaluated to assess the performance of the extraction and analysis
procedures. Fluorene-dio and pyrene-dio are the recommended extraction surrogate compounds
and 1 |ig should be added to the media (e.g., 10 |iL of 10 |ig/mL solution). Stock standard
solutions of these two surrogate compounds in solvent are commercially available and are
diluted to working concentrations in suitable solvent (i.e., hexane).

4.5.5.2	Hold Times and Storage Requirements. Collected samples must be transported and
stored at < 4°C until extraction, and must be extracted within 14 days of collection. Extracts
must be stored in amber or foil-wrapped vials at < 4°C, however storage in a freezer at < -10°C is
preferable. Extracts must be analyzed within 40 days of extraction. Working standards and open
ampules of stock standards must be stored protected from light at < -10°C in Teflon sealed amber
vials in a storage unit separate from sampled cartridges and sample extracts.

4.5.5.3	Extraction, Concentration, and Cleanup. Extraction of samples may be performed
by Soxhlet or ASE; these techniques are described in more detail below.

4.5.5.3.1	Soxhlet Extraction. Each Soxhlet extraction batch must include 20 or
fewer field-collected samples and a MB. An LCS, and LCSD are required quarterly, but
recommended with each extraction batch. Prior to extraction, each field-collected sample and
QC sample must be fortified with extraction surrogate standards (typically fluorene-dio and
pyrene-dio). Extraction should be performed by combining the QFF, PUF plugs, and resin
sorbent into the soxhlet extraction vessel and extracting with sufficient 90:10 hexane:diethyl
ether to cover the sample media. Extraction should be performed for a minimum of 18 hours and
the temperature of heating mantle should be set such that reflux occurs at a rate of at least three
cycles per hour.

Extracts must be capped, protected from light, and stored refrigerated at < 4°C if they are not to
be concentrated immediately following extraction.

4.5.5.3.2	Accelerated Solvent Extraction. To perform ASE, a 100 mL ASE cell
should be packed as follows: QFF, top PUF plug, resin, bottom PUF plug, and clean Ottawa
sand to fill the cell. Each extraction batch must include 20 or fewer field-collected samples and
an MB. An LCS and LCSD are required quarterly, and recommended with each batch. Prior to

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extraction, each field sample and quality control sample must be fortified with extraction
surrogate standards (typically fluorene-dio and pyrene-dio). To ensure the cell seals properly,
stray resin grains should be removed from the threads with a horsehair brush or compressed air.

The following procedure should then be followed: install the cells into the extractor, install the
clean extract collection bottles, verify that the solvent reservoirs are full, and start the extraction
program. A recommended solvent combination for ASE is 2:1 or 3:1 hexane:acetone (v:v).3 An
example ASE program follows:

temperature:
cycles:
purge:
static time:
flush:

60°C

minimum of 3
60 seconds
5 minutes
50%

Extracts must be capped, protected from light, and stored refrigerated at < 4°C if they are not to
be concentrated immediately following extraction.

4.5.5.3.3 Extract Concentration and Cleanup

4.5.5.3.3.1 Extract Concentration

Refrigerated extracts are equilibrated to room temperature prior to concentration. It is
recommended that extracts be dried by passage through approximately 10 g of sodium sulfate,
where the eluate is collected into a concentration flask or tube. The extraction flask and sodium
sulfate are then rinsed three times with extraction solvent and the rinsate collected into the
concentration vessel.

Prior to use, sodium sulfate should be solvent rinsed and placed in an oven at 400°C for a
minimum of 4 hours to remove impurities. Muffled sodium sulfate should be cooled and stored
in a desiccator to minimize contact with humidity in ambient air.

Extracts should be concentrated by either Kuderna-Danish (K-D) or nitrogen blowdown
techniques. The extracts must not be allowed to evaporate to dryness.

4.5.5.3.3.1.1 Concentration via Kuderna-Danish

To concentrate via K-D, the following procedure should be followed. Attach a Snyder column to
the K-D apparatus and concentrate to approximately 5 mL on a water bath set to 30 to 40°C.
Rinse the Snyder column and concentrator flask with several mLs of n-hexane and allow the
solvent to drain into the concentrator tube. Concentrate to < 1 mL final volume via nitrogen
blow-down or via micro-Snyder column. Bring the extract to 1.0 mL final volume via syringe,
rinsing the concentration tube with n-hexane as the extract is drawn into the syringe.

Following concentration to 1 mL, the extract is ready for analysis unless further cleanup is
required. Extract cleanup is explained in Section 4.5.5.3.3.2.

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4.5.5.3.3.1.2 Concentration via Nitrogen Slowdown

Several nitrogen blowdown evaporator concentrator instruments are commercially available. As
the release of large volumes of solvent is detrimental to air quality, systems which capture the
evaporated solvent are preferable.

The solvent should be concentrated to < 1 mL final volume in a water bath set to 30-40°C and
the final volume of the extract should be established as 1.0 mL with a calibrated syringe. The
concentration tube should be rinsed with GC-grade n-hexane as the extract is drawn into the
syringe.

Following concentration to 1 mL, the extract is ready for analysis unless further cleanup is
required. Extract cleanup is explained in Section 4.5.5.3.3.2.

4.5.5.3.3.2 Extract Cleanup

A cleanup step may be required in order to clarify cloudy extracts or remove interfering
compounds from extracts showing significant chromatographic interferences.

To clarify cloudy extracts, they are passed through a packed column of 10 g of silica gel as
detailed in EPA Compendium Method TO-13A and ASTM D6209. Ambient air matrices
typically do not result in cloudy extracts and therefore likely do not require additional cleanup.

4.5.5.4 PAH Method Detection Limits. MDLs for PAHs must be determined minimally
annually by following the procedures in Section 4.1. To ensure that the variability of the media
and the extraction process is characterized in the MDL procedure, cartridges and QFFs must be
extracted (it does not suffice to simply analyze a low-concentration solution of PAHs) and blank
and spiked cartridges with QFFs must be prepared. For example, laboratories determining the
MDL following Section 4.1.2.1 must prepare and extract a minimum of seven method blank
cartridges and QFFs and a minimum of seven spiked cartridges and QFFs over the course of
three different dates (preferably non-consecutive). The resulting extracts must be analyzed in
three separate analytical batches (three different calendar dates - preferably non-consecutive).
All steps performed in the preparation and analysis of field sample cartridges must be included in
the MDL procedure.

Note that at very low levels approximating the MDL, the qualitative identification criteria related
to qualifier ion abundance ratio and/or signal-to-noise ratio listed in Section 4.5.5.5.7 may not be
strictly met when determining the MDL. As the MDL spikes are prepared in a clean matrix with
standard materials, the presence of the analyte is expected.

As discussed in Section 4.1.3.1, one MDL spike sample can be added to analysis periodically.
Together with the MB from each batch, once results for seven or more MDL spike samples and
method blanks are available, the MDL can be calculated.

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4.5.5.5 PAH Analysis via GC/MS

4.5.5.5.1	GC/MS Instrumentation. The GC should be capable of temperature
programming such that the temperature may be ramped from 25°C to 290°C at a rate of
8°C/minute or faster. A 30 to 50 m by 0.25 mm fused silica capillary column coated with 0.25
|im crosslinked or bonded 5% phenyl methylsilicone film, or equivalent suitable column capable
of separating the target analytes, surrogates, and ISs with appropriate resolution, should be
installed in the GC. The carrier gas should be helium or hydrogen. Injector and transfer line
should be capable of maintaining 275-300°C. GC injection volume should be 1.0 |iL.

Electron ionization should be performed at 70 eV and the MS should be operated in SIM mode
to maximize sensitivity to ions of the target compounds of interest. Alternatively, for
instruments which are capable, operation in combination SIM/scan mode is preferred.
Spectrometers operating in full scan mode may lack sufficient sensitivity. If full scan is
performed, the MS should be capable of scanning from 35-500 amu in < 1 second.

4.5.5.5.2	Tuning of the MS. The GC/MS must be tuned prior to calibration and
every 12 hours of analysis thereafter via analysis of 5 to 50 ng of DFTPP.

If operated in full scan mode or SIM/scan mode, the MS tune must be optimized to achieve the
ion abundances below in Table 4.5-2.

For instruments operated in SIM mode, the above ion abundance criteria do not apply. Tuning
for SIM instruments is optimized to maximize the signal for DFTPP masses greater than 150
amu. The SIM MS tune must maximize the signal for masses 198, 275, 265, and 442 while
maintaining unit resolution between masses 197, 198, and 199 as well as 441, 442, and 443.

Table 4.5-2. DFTPP Key Ions and Abundance Criteria

mass

ion abundance criteria

51

30-60% of mass 198

68

< 2% of mass 69

70

< 2% of mass 69

127

40-60% of mass 198

197

< 1% of mass 198

198

base peak, assigned 100% relative abundance

199

5-9% of mass 198

275

10-30% of mass 198

365

> 1% of mass 198

441

present, but < mass 443

442

> 40% of mass 198

443

17-23% of mass 442

4.5.5.5.3 Calibration of the GC/MS. All solutions to be analyzed, including
calibration standards, should be removed from refrigerated storage for sufficient time (typically
one hour) to equilibrate to ambient temperature prior to analysis.

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Calibration standard solutions must be prepared at minimally five separate concentration levels
in hexane covering approximately 0.1 to 2.0 |ag/m L and must contain surrogate compounds at
concentrations bracketing those expected in the sample extracts.

ICAL must be established initially, when continuing calibration criteria are not met, or when an
instrument change (ion source cleaning, column trim or change, etc.) may affect instrument
calibration (including alteration of retention times). Calibration is recommended every six
weeks.

An SB which is not fortified with IS must be analyzed just prior to calibration to ensure the
instrument is sufficiently clean to continue analysis. Analysis of the SB must show all target
compounds, IS, and surrogate compounds are not detected.

A known volume of each standard should be transferred to a GC analysis vial and fortified with
IS just prior to analysis. Recommended quantitation and secondary ions are listed in Table 5 of
method TO-13 A. Each compound must be assigned to the IS compound with the nearest
retention time.

Following data acquisition for the calibration standards, the relative response factor (RRF) of
each surrogate and target compound in each calibration level is determined as follows:

Ag " CIS

RRF =

Ais 1 Cs

where:

As =	peak area for quantitation ion of the surrogate or target compound

Ais =	peak area for quantitation ion of the assigned internal standard compound

Cs =	concentration of the surrogate or target compound

Cis =	concentration of the assigned internal standard compound

The RSD of the RRFs for each surrogate and target compound must be < 30%. Alternatively, a
calibration curve may be prepared by linear or quadratic regression. The correlation coefficient
for linear or quadratic curves must be > 0.995 for target compounds. Irrespective of the curve fit
method selected, the calculated concentration of each calibration level must be within 30% of the
nominal concentration when quantitated against the resulting calibration curve. Exclusion of
calibration standard levels is not permitted unless justifiable (for example, a known error in
standard preparation). Sample analysis must not be performed, and if performed, results must
not be reported when calibration acceptance criteria are not met. Rather corrective action,
possibly including recalibration, must be taken.

The absolute value of the concentration equivalent to the intercept of the calibration curve
(|intercept/slope or equivalent]) converted to concentration units (by division by the slope or
equivalent) must be less than the laboratory MDL. When this specification is not met, the source
of contamination or suppression must be corrected and the calibration curve reestablished before
sample analysis may commence.

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RRTs are calculated for each concentration level of each surrogate and target compound by
dividing the surrogate or target RT by the associated IS compound RT. The RRTs of each
surrogate or target compound across the ICAL are then averaged to determine the ICAL RRT.
All RRTs must be within ± 0.06 RRT units of RRT.

4.5.5.5.4	Secondary Source Calibration Verification. Following each successful
initial calibration, a SSCV must be analyzed to verify the initial calibration. The SSCV is
prepared at approximately the mid-range of the calibration curve. Alternatively, two or more
concentrations of SSCV may be prepared covering the calibration range. All SSCVs must
recover within ± 30% of nominal or demonstrate an RRF within ± 30% of the average RRF of
the calibration curve.

4.5.5.5.5	Continuing Calibration Verification. Once the GC/MS instrument has
met tuning and calibration criteria, a CCV must be analyzed every 12 hours of analysis following
the 12-hour DFTPP tuning check standard. The CCV must recover within ± 30% of nominal or
demonstrate RRF within 30% of the mean ICAL RRF for all target PAHs. Corrective action
must be taken to address CCV failures, including, but not limited to, preparing and analyzing a
new CCV, cleaning or replacing the injector liner, trimming or replacing the column, retuning
the MS, or preparing a new initial calibration.

4.5.5.5.6	Analysis of QC Samples and Field Samples. The MS must be tuned and
the calibration determined or verified prior to the analysis of field samples. ISs should be added
to each extract just prior to analysis. Note that a best practice is not to add IS to the entire 1 mL
of extract. An aliquot of the extract should be taken for fortification with ISs to preclude loss of
the entire extract in the event of IS spiking errors.

The following QC samples are required with each analysis sequence:

Solvent method blank (SMB)

-	MB

-	Replicate extract analysis

Prior to analysis of laboratory QC samples or field-collected samples, a SMB consisting of an
aliquot of the batch extraction solvent fortified with IS must be analyzed and demonstrate target
compounds are < MDL.

Target PAHs must not be present in MBs at concentrations > 2x MDL. Replicate analysis must
demonstrate precision of < 10% RPD for all measured concentrations >0.5 |ig/mL.

An LCS/LCSD pair is required quarterly and recommended with each extraction batch to
monitor recovery and precision in matrix. Target PAHs in the LCS and LCSD must recover
within 60 to 120% of nominal and the LCSD must demonstrate precision of < 20% RPD for all
target PAHs.

4.5.5.5.7	Compound Identification. Four criteria must be met in order to positively
identify a surrogate compound or target PAH:

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1.	The signal-to-noise ratio of the target and qualifier ions must be > 3:1, preferably >
5:1.

2.	The target and qualifier ion peaks must be co-maximized (peak apexes within one
scan of each other).

3.	The RT of the compound must be within the acceptable RT window determined from
the ICAL average.

4.	The abundance ratio of the qualifier ion response to target ion response for at least
one qualifier ion must be within ± 15% of the average ratio from the ICAL.

If any of these criteria are not met, the compound may not be positively identified. The only
exception to this is when in the opinion of an experienced analyst, the compound is positively
identified. The rationale for such an exception must be documented. For examples of the
qualitative identification criteria and calculation of S:N, refer to Section 4.2.10.5.3.

4.5.5.5.8	Internal Standards Response. IS response must be monitored for each
injection (except for the SB immediately preceding the initial calibration or 12-hour tune check).
Area responses of the IS must be 50 to 200% of the area responses in the initial calibration mid-
level standard and they must elute within ± 20 seconds (± 0.33 minute) of the mean RT of the
initial calibration. Extracts which do not meet these response acceptance criteria should be
diluted, and the dilution analyzed to examine for matrix interferences. If the IS still does not
meet criteria in the dilution, the MS tune should be evaluated for a degradation or enhancement
of sensitivity and corrective action taken to address the failure. Sample results calculated from
IS criteria failures must be appropriately qualified when entered into AQS.

4.5.5.5.9	Surrogate Evaluation. Following calibration, each analyzed extract
should be evaluated to ensure the recovery of each surrogate compound is within 60 to 120% of
the nominal spiked value. Results which fall outside of these limits indicate potential analyte
loss or enhancement either through sample collection and handling and/or extraction process and
must be qualified appropriately when reported to AQS.

4.5.5.5.10	Data Review and Concentration Calculations. For sampling units
without computerized flow control, the beginning and ending flows are averaged to calculate the
collected air volume. For computer controlled sampling units, the integrated collected volume is
typically available from the data logging system. Sampled air volumes must be in STP, 25°C
and 760 mm Hg. Sampling unit flows should be calibrated in flows at standard conditions so
conversion from local conditions to standard flows is not necessary. For units which do not have
computerized flow control, temperature and barometric pressure at sample setup and take down
must be recorded.

Each chromatogram must be closely examined to ensure chromatographic peaks are
appropriately resolved and integration does not include peak shoulders or inflections indicative
of a coelution.

The concentrations of target PAHs in unknowns are calculated by relating the area response ratio
of the target PAH and internal standard in the unknown to the relationship derived in the

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calibration curve selected in Section 4.5.5.5.3. The final air concentration of each target PAH is
determined by multiplying the concentration in the extract by the final extract volume and
dividing by the collected sample air volume at standard conditions of 25°C and 760 mm Hg:

1000 ¦ ct ¦ ve

where:

Ca =	concentration of the target compound in air (ng/m3)

Ct =	concentration of the unknown sample in the extract (|ig/mL)

Ve =	final volume of extract (mL)

Va =	volume of collected air volume at STP (m3)

4.5.6 Summary of Quality Control Parameters. A summary of QC parameters is shown
in Table 4.5-3.

Table 4.5-3. Summary of Quality Control Parameters for NATTS PAHs Analysis

Parameter

Description and Details

Required Frequency

Acceptance Criteria

Solvent Blank
(SB)

Aliquot of solvent (without IS)
analyzed to ensure the GC/MS is free
of interferences and of compounds of
interest (target PAHs, internal
standards, and surrogates)

Prior to each DFTPP tune
check

No target compound, IS,
or surrogates
qualitatively detected

DFTPP Tune
Check

5 to 50 ng injection of DFTPP for
tuning of MS detector

Prior to initial calibration
and every 12 hours of
analysis thereafter

Abundance criteria listed
in table 4.5-2 must be
met

Initial Calibration
(ICAL)

Analysis of a minimum of five
calibration levels covering
approximately 0.1 to 2 ng/mL

Initially, following failed
DFTPP tune check, failed
CCV, or when changes to
the instrument affect
calibration response.
Recommended every six
weeks.

Average RRF
< 30% RSD and each
calibration level must be
within ± 30% of nominal

For quadratic or linear
regression, r > 0.995,
each calibration level
must be within ± 30% of
nominal

Secondary Source
Calibration
Verification
(SSCV)

Analysis of a second source standard
at the mid-range of the calibration
curve to verily curve accuracy

Immediately after each
ICAL

Recovery within
± 30% of nominal or
RRF within 30% of
mean ICAL RRF

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Table 4.5-3. Summary of Quality Control Parameters for NATTS PAHs

Analysis (Continued)

Parameter

Description and Details

Required Frequency

Acceptance Criteria

Continuing
Calibration
Verification
(CCV)

Analysis of a known standard at the
mid-range of the calibration curve to
verify ongoing instrument calibration

Following each DFTPP
tune check not followed by
ICAL and recommended at
the conclusion of each
sample sequence

Recovery within
± 30% of nominal or
RRF within 30% of
mean ICAL RRF

Cartridge Batch
Blank

A cartridge (and QFF) selected for
analysis to ensure acceptable
background levels in the batch of
cartridges

One cartridge for each
batch of 20 or fewer
prepared cartridges

All target compounds
each <10 ng/cartridge

Field Surrogate
Compounds

Deuterated PAHs which assess
recovery during sample collection,
handling, and analysis

Added to every cartridge
prior to field deployment

Recovery 60-120% of
nominal spiked amount

Internal Standards
(IS)

Deuterated PAHs added to extracts to
assess the impact of and correct for
variability in instrument response

Added to all calibration
standards, QC samples,
and field sample extracts
except the SB

Area response within 50-
200% of the response of
the mid-level calibration
standard in the ICAL.

Extraction

Surrogate

Compounds

Deuterated PAHs which assess
recovery during sample extraction
and analysis

Added to media before
extraction

Recovery 60-120% of
nominal spiked amount

Solvent Method
Blank (SMB)

Aliquot of extraction solvent fortified
with IS to ensure extraction solvent is
free of interferences and target
compounds

One with every extraction
batch of 20 or fewer field-
collected samples

Target compounds
< MDL

Method Blank
(MB)

Blank cartridge and QFF taken
through all extraction and analysis
procedures

One with every extraction
batch of 20 or fewer field-
collected samples

Target analyte amounts
< 2x MDL

Laboratory
Control Sample
(LCS)

Cartridge spiked with known amount
of target analyte

Minimally quarterly.
Recommended as one with
every extraction batch of
20 or fewer field-collected
samples

Recovery 60-120% of
nominal spiked amount

Laboratory
Control Sample
Duplicate (LCSD)

Duplicate cartridge spiked with
known amount of target analyte

Minimally quarterly.
Recommended as one with
every extraction batch of
20 or fewer field-collected
samples

Recovery 60-120% of
nominal spiked amount
and precision
< 20% RPD compared to
LCS

Replicate Analysis

Replicate analysis of a field sample
extract

Once with every analysis
sequence

Precision < 10% RPD
for concentrations
> 0.5 ng/mL

Field Blank (FB)

Blank cartridge and QFF assembly
exposed to ambient atmosphere for
minimally five minutes

One per month

Target analyte amounts
< 5xMDL

Collocated
Samples

Sample collected concurrently with
the primary sample

10% of primary samples
for sites conducting
collocated sampling (as
required by workplan)

Precision < 20% RPD
for concentrations
> 0.5 ng/mL

Retention Time
(RT)

RT of each target PAH, surrogate
compound, and internal standard

All qualitatively identified
compounds

Target analytes within ±
0.06 RRT units of mean
ICALRRT

Internal standards within
±0.33 minutes of mean
ICAL RT

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4.5.7

References

1.	Determination of Polycyclic Aromatic Hydrocarbons (PAHs) in Ambient Air Using Gas
Chromatography/Mass Spectrometry (GC/MS); EPA Compendium Method

TO-13 A. In Compendium of Methods for the Determination of Toxic Organic Compounds in
Ambient Air (Second Edition); EPA 625/R-96/010b; U.S. Environmental Protection Agency,
Center for Environmental Research Information. Office of Research and Development.
Cincinnati, OH, January 1999. Available at (accessed October 19, 2016):
https://www3.epa.gov/ttnamtil/files/ambient/airtox/to-13arr.pdf

2.	ASTM D6209-13, Standard Test Method for Determination of Gaseous and Particulate
Polycyclic Aromatic Hydrocarbons in Ambient Air (Collection on Sorbent-Backed Filters
with Gas Chromatographic/Mass Spectrometric Analysis), ASTM International, West
Conshohocken, PA, 2013, www.astm.org.

3.	Accelerated Solvent Extraction for Monitoring Persistent Organic Pollutants in Ambient Air.
White Paper 71064. Aaron Kettle, Thermo Fisher Scientific, Sunnyvale, CA. 2013.

4.	Chuang, J.C.; Hannan, S.W.; Koetz, J. R. Stability of Polynuclear Aromatic Compounds
Collectedfrom Air on Quartz Fiber Filters andXAD-2 Resin; EPA-600/4-86-029; U.S.
Environmental Protection Agency, Environmental Monitoring Systems Laboratory, Methods
Development and Analysis Division: Research Triangle Park, NC, September 1986.

5.	Feng, Y.; Bidleman, T.F. Influence of Volatility on the Collection of Polynuclear Aromatic
Hydrocarbon Vapors with Polyurethane Foam. Environ. Sci. Technol. 1984, 18, 330 -333.

6.	Yamasaki, H.; Kuwata, K.; Miyamoto, H. Effects of Ambient Temperature on Aspects of
Airborne Polycyclic Aromatic Hydrocarbons. Environ. Sci. Technol. 1982, 16, 89-194.

7.	Galasyn, J.F.; Hornig, J.F.; Soderberg, R.H. The Loss of PAH from Quartz Fiber High
Volume Filters. J. Air Pollut. Contr. Assoc. 1984, 34, 57-59.

8.	Care and Safe Handling of Laboratory Glassware. Corning Incorporated. RG-CI-101-REV2.
2011. Available at (accessed October 19, 2016):

http://csmedia2.corning.com/LifeSciences/media/pdf/Care and Safe Handling Lab Glassw
are RG-CI-101Rev2.pdf


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5.0: METEOROLOGICAL MEASUREMENTS

A goal of the NATTS network is to leverage existing monitoring sites (such as those conducting
criteria pollutant monitoring, PAMS sites, and NCore sites, etc.) to conduct NATTS Program
sample collection. Many of the existing 27 NATTS sites conduct site-specific meteorological
measurements.

While such site-specific meteorological measurements such as wind speed, wind direction, solar
radiation, precipitation, etc. are highly desirable and complement collected NATTS data, only
temperature and barometric pressure measurements are required for NATTS sample collection
events. If temperature and barometric pressure measurements are not recorded from calibrated
temperature and barometric pressure functions on sampling units themselves, they must be
recorded from site-specific calibrated meteorological instruments. If site-specific meteorological
monitoring is not performed, each site must acquire the applicable temperature and barometric
pressure from the closest off-site meteorological monitoring station (i.e., National Weather
Service, local airport, etc.). For sites collecting additional meteorological parameters beyond
temperature and barometric pressure, please consult EPA's Quality Assurance Handbook for Air
Pollution Measurement Systems, Volume IV Meteorological Measurements for more
information, available at (accessed October 19, 2016):
https://www3.epa.gov/ttnamtil/files/ambient/met/draft-volume-4.pdf

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6.0: DATA HANDLING

6.1	Data Collection

All records must be documented in detail sufficient to reconstruct the activities and
transformations to generate reported concentration data. If such records are not available,
validity of the data cannot be determined. Such records minimally include observations,
laboratory measurements, and photographs as well as instrument calibration records and COAs.
Records related to manipulation of data such as through data reduction spreadsheets, peak
integrations, hand calculations, or calculations handled by a LIMS must be maintained and must
be transparent so the transformations may be verified.

6.2	Data Backup

Electronic data acquired from laboratory instruments, field instruments, databases, and data
manipulation software in support of NATTS Program work must be maintained for a minimum
of six years following acquisition. As previously discussed, this six-year period is needed to
cover two consecutive three-year periods needed to assess trends for the NATTS DQO. In order
to maintain electronic records for this duration, it is necessary to prevent data loss and corruption
by ensuring data redundancy. Each NATTS agency must prescribe data redundancy policies and
procedures, which may be included in the NATTS QAPP, SOP, or similar controlled document.

For data acquisition software systems such as CDSs, ICP-MS control and operation software,
and environmental control tracking software systems which are connected via computer network,
a best practice is to enable automated nightly backups of data to a separate physical hard drive or
server, preferably one at a different physical location. Backing up of data to a separate partition
on the same hard drive provides little additional security if the hard drive fails. For software
systems which are not networked to a server, a best practice is to manually back up the data after
completion of each day's activities to removable media (thumb drive, external hard drive, etc.)
for transfer to a networked computer or server.

These daily backups must be protected from inadvertent alteration and compiled on a regular
frequency, recommended weekly but not to exceed monthly, to an archival system such as a tape
drive, DVD, additional external server, cloud storage, etc. This archival must be access-limited
by password and/or other security means to a select few individuals as deemed responsible by
cognizant management.

Archived electronic data must remain accessible such that retired computer or software systems
must be maintained to access data, or archived data converted such that it remains accessible and
legible until the archival period has lapsed.

Once archived, archived data should be reviewed or tested to ensure complete records are
maintained and data have not been corrupted. Such a review is recommended every six months,
but should not exceed annually.

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6.3	Recording of Data

Data generated as in Section 6.1 must be recorded so that it is clear who performed the activity,
when the activity was performed, and, if applicable, who documented performance of the
activity.

6.3.1	Paper Records. Data entries created on paper records such as field collection forms,
COC forms, or laboratory notebooks, must be recorded in legibly in indelible ink and must
identify the individual creating the entry. Measurements must clearly indicate appropriate units.
Individuals creating paper data records must be identified by way of signature or initials unique
to the individual and in such a manner that unambiguous identification is possible. One method
by which such may be accomplished is to create a cross-reference for each staff person that
shows each staff person's printed name, signature, and initials.

6.3.2	Electronic Data Capture. Electronic data recording systems such as electronic
logbooks, LIMS, and instrumental data acquisition software generally require a user to log in
with a username and password to utilize the system. Each action (entry, manipulation,
instrument operation) recorded by such software systems must be attributable to an individual
and the corresponding date and time recorded. If so equipped, audit trails must be enabled on
software systems in order to record changes made to electronic records.

6.3.3	Error Correction. Changes to recorded data or data manipulation may be required
due to calculation errors, incorrectly recorded measurements, or errors noted during data
verification and validation. When records are amended, whether paper or electronic, the original
record must remain legible or otherwise intact, and the following information must be recorded:
the identity of the individual responsible for making the change, the date the change was made
and the rationale for the change. For example, hand-written data records may be corrected by a
single line through the entry with the correction, the initials of the responsible individual, the
date of correction, and the rationale for change documented in close proximity to the correction
or identifiable by annotated footnote. For common corrections such as those for incorrect date,
illegible entry, calculation errors, etc., a list of abbreviations may be developed to document
change rationale. Any such abbreviations must be defined in a quality systems document such as
an SOP, or in the front of a logbook, etc.

6.3.3.1 Manual Integration of Chromatographic Peaks. Automated functions for the
integration of chromatographic peaks are included in the chromatography data systems (CDS)
that control all GC/MS and HPLC instruments. These integration functions should be configured
such that little intervention or correction is needed by the analyst, so as to best ensure that peak
integration is as reproducible and introduces as little human error as possible. While these
functions ensure consistent integration practices, subtle differences in peak shape, coeluting
peaks, and baseline noise may result in inconsistent or incorrect peak integration.

Analysts must be properly trained to review and adjust peak integration performed by CDS
automated functions, and specific procedures must be codified into each agency's quality system.
All manual changes to automated peak integration must be treated as error corrections. Typical
corrections to peak integration may include: adjustment of the baseline, addition or removal of a

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vertical drop line, or peak deletion if the requisite compound identification criteria are not met.
The identification criteria for the chromatography methods are listed as follows:

VOCs:	Section 4.2.10.5.3

Carbonyls: Section 4.3.9.5.6
PAHs:	Section 4.5.5.5.7

Manual peak deletion, that is, effectively reporting that the compound was not detected, is not
permitted in instances in which the peak specified identification criteria are met.

For each adjustment to chromatographic peak integration (manual integration), the record of the
original automated integration must be maintained and it is strongly recommended that the
adjustment be justified with the documented rationale (signal-to-noise too low, incorrect
retention time, incorrectly drawn baseline, etc.), analyst initials, and date.

6.4	Numerical Calculations

Numerous calculations and manipulations are necessary to determine the target analyte
concentration of a given field-collected sample or QC sample or to determine evaluate whether
data generated during calibration verifications meet acceptance criteria.

6.4.1	Rounding. Rounding of values must be avoided until the final step of a calculation.
Rounding during intermediate steps risks the loss of fidelity of the calculation which may lead to
significant calculation error.

EPA Region IV SESD has developed guidance for rounding which is adopted into the revision of
the Volume II of EPA's QA Handbook. This guidance is included in Appendix C of this TAD.

6.4.2	Calculations Using Significant Digits. Final reported results should be rounded to
the correct number of significant digits per the rules below. To the extent feasible, carry the
maximum number of digits available through all intermediate calculations and do not round until
the final calculated result. Non-significant digits that are carried through calculations may be
represented using subscripted numerals. (For example, 2.32i has three significant figures, with
the final 1 being non-significant and carried through to avoid unnecessarily introducing
additional error into the final result.)

6.4.2.1 Addition and Subtraction. The number of significant digits in the final result is
determined by the value with the fewest number of digits after the decimal place. For example:

A 5.6
B 63.71
C +9.238
78.5

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The final result is limited to one decimal place due to the uncertainty introduced in the tenths
place by measurement A.

6.4.2.2	Multiplication and Division. The number of significant digits in the final result is
determined by the value with the fewest number of significant digits. For example, acrolein was
measured by the GC/MS at a concentration of 2.721 ppb from a canister that was diluted with
zero air resulting in a dilution factor of 1.41. The dilution factor is applied to the measured result
to calculate the in air concentration:

2.721 ppb • 1.41 = 3.837 ppb

3.84 ppb

The final result is limited to three significant digits due to the dilution factor containing three
significant digits.

6.4.2.3	Standard Deviation. Standard deviation in a final result must not display digits in a
place that the sample average does not have a significant digit. Take, for example, the following
average and standard deviation of the form x±s:

107.2 ± 2.3J_ is reported as 107.2 ±2.3

The standard deviation is rounded to the appropriate significant digit of the sample average.

6.4.2.4	Logarithms. For converting a value to its logarithm, retain as many places in the
mantissa of the logarithm (to the right of the decimal point in the logarithm) as there are
significant figures in the number itself. For example (mantissa underlined):

logio 24.5 = 1.389

For converting antilogarithms to values, retain as many places in the value as there are digits in
the mantissa of the logarithm. For example (mantissa underlined):

antilog (1.131) = 13.5
6.5	In-house Control Limits

The analysis methods detailed in Section 4 specify acceptance criteria for routine QC samples.
These acceptance criteria are the maximum allowable ranges permitted, however, laboratories
may find that they rarely or never exceed the acceptance criteria. As each laboratory and the
associated analyst, instruments, and processes are unique, development of in-house control limits
is recommended to evaluate trends and identify problem situations before exceedances to method
acceptance criteria occur.

In-house control limits may be generated to evaluate the bias of quality control samples such as
the LCS, CCV, SSCV, and to evaluate precision of LCSD, matrix spike duplicate, etc. Warning

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limits and control limits are established following acquisition of sufficient data points, generally
more than seven, per the guidance in the subsequent sections. Under no circumstances may data
be accepted which exceeds method specified acceptance criteria even if in-house warning or
control limits have not been exceeded.

6.5.1	Warning Limits. Warning limits are established as a window of two standard
deviations surrounding the mean (x ± 2s). Exceedance of the warning limit should prompt
monitoring of the parameter for values which remain outside the warning limits. For repeated
values exceeding the warning limits, corrective action should be taken to address the trend.

6.5.2	Control Limits. Control limits are established as a window of three standard
deviations surrounding the mean (x ± 3.s), Corrective action is required when control limits are
exceeded.

6.6	Negative Values

In general, negative values of small magnitude may be expected from certain analytical
platforms in the NATTS program, specifically those which do not apply calibration regressions
which are forced through the origin. However, depending on the situation, negative numbers can
be problematic and indicative of bias due to faulty sensors, contamination in reagents and
labware, improper calibration, or calculation errors.

Negative values must be evaluated to ensure that their magnitude does not significantly impact
the resulting measurements.

Minimum values will be updated in AQS to permit the reporting of negative values for NATTS
parameters. Negative values for all qualitatively identified analytes must be reported to AQS as-
is without censoring or replacing with zero.

6.6.1	Negative Concentrations. For analysis measurements, a negative concentration
result generated by a positive instrument response (i.e., positive area count) must be investigated
to ensure that the negative concentration is of small magnitude such that the absolute value of the
concentration is less than the MDLsp (for MDLs determined via Section 4,1,3,1) or v K for
MDLs determined via Section 4.1.3.2. Where negative concentrations fail this criterion,
corrective action must be taken to determine and remediate the source of the bias.

6.6.2	Negative Physical Measurements. For physical measurements such as mass,
absolute pressure, and flow, negative values generated by an instrument must be evaluated to
ensure they do not adversely impact future measurements.

For example, a VOCs sampling unit pressure transducer reads -0.4 psia upon connection to a
canister at hard vacuum. The acceptable canister pressure threshold is 0.5 psia. Since negative
absolute pressures are impossible, the -0.4 psia reading is significant, especially when compared
to an acceptance criterion of 0.5 psia. Due to the -0.4 psia bias, the pressure in another canister
at 0.8 psia would be read 0.4 psia and would incorrectly meet the acceptance criterion for sample
collection due to the incorrect calibration of the pressure transducer.

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7.0: DATA VALIDATION TABLES

The following tables are a distillation of the general quality control guidance and requirements in
Section 3 and of the individual methods described in Section 4. More information on each data
validation parameter can be located within the text identified in the reference column. Each
parameter is assigned a category of importance. The categories in order of decreasing
importance are:

1.	Critical - Criteria must be met for reported results to be valid - Samples for which
these criteria are not met are invalidated.

2.	MQO - Required NATTS Measurement Quality Objective which must be attained -
Failure to meet these criteria does not necessarily invalidate data, but may
compromise data and result in exclusion from trends analysis.

3.	Operational - Failure to meet criteria does not invalidate reported results; the results
are compromised and on a case-by-case basis may require qualification - refer to
Section 3.3.1.3.15 for the list of AQS qualifiers

4.	Practical - Failure to meet criteria does not invalidate reported results; results may be
compromised but do not require qualification.

The validation tables in the following sections will be available on AMTIC in Microsoft Excel®
format so the parameters may be sorted according to importance.

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7.1	VOCs via EPA Compendium Method TO-15

Parameter

Description and Required Frequency

Acceptance Criteria

Reference

Category

Field Readiness Checks and Collection Activities

Canister Cleaning
Batch Blank

Minimally one canister selected for analysis from a given
batch of clean canisters to ensure acceptable background
levels in the batch of cleaned canisters - must represent no
more than 10 canisters

Each target VOC's concentration
< 3x MDL or 0.2 ppb, whichever is
lower

Section 4.2.6.2.4
TO-15 Section
8.4.1.6

Critical

Canister Viability

All canisters

Canister must be used within 30
days from final evacuation

Section 4.2.6.2
TO-15 Section 1.3

Operational

Sampling Unit
Clock/Timer Check

Verified with each sample collection event

Clock/timer accurate to ±5 minute
of reference for digital timers, ±15
minutes for mechanical timers, set
to local standard time

Sample collection period verified
to be midnight to midnight

Section 4.2.5.3 and
Table 3.3-1

Operational

Canister Starting

Pressure

Determination

Each canister prior to collection of a field sample or
preparation of a calibration standard or laboratory QC sample

Vacuum > 28" Hg as determined
with calibrated pressure gauge or
transducer

Section 4.2.5.2.1

Critical

Sample Setup Leak
Check

Each canister prior to collection - draw vacuum on canister
connection

Leak rate must be < 0.2 psi over 5
minutes

Section 4.2.5.2.1

Critical

Sampling Frequency

One sample every six days according to the EPA National
Monitoring Schedule

Sample must be valid or a make-up
sample should be scheduled (refer
to Section 2.1.2.1)

Section 4.2.5.3

Critical and
MQO

Sampling Period

All field-collected samples

1380-1500 minutes (24 ± 1 hr)
starting and ending at midnight

Section 4.2.5.3

Critical and
MQO

Pre-Sample
Collection Purge

Each sampling event

Minimum of ten air changes just
prior to sample collection

Section 4.2.5.4

Practical

Field-collected
Sample Final
Pressure

All field-collected samples

Must be determined with a
calibrated pressure gauge or
transducer per agency quality
system specification

Section 4.2.5.2.4

Operational

Sample Recei

pt

Chain-of-custody

All field-collected samples including field QC samples

Each canister must be uniquely
identified and accompanied by a
valid and legible COC with
complete sample documentation

Sections 3.3.1.3.7
and 4.2.5.2.4

Critical


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7.1 VOCs via EPA Compendium Method TO-15 (Continued)

Parameter

Description and Required Frequency

Acceptance Criteria

Reference

Category

Sample Holding
Time

All field-collected samples, laboratory QC samples, and
standards

Analysis within 30 days of end of
collection (field-collected samples)
or preparation (QC samples or
standards)

Section 4.2.1
TO-15 Sections
1.3, 2.3, and 9.2.8.1

Operational

Canister Receipt
Pressure Check

All field-collected samples upon receipt at the laboratory -
measured with calibrated pressure gauge or transducer

Pressure change of < 0.5 psi from
the final pressure at retrieval

Section 4.2.8

Critical for

subambient

sample

collection,

operational

for

pressurized

sample

collection

GC/MS Analysis

Instrument Blank
(IB)

Analysis of swept carrier gas through the preconcentrator to
demonstrate the instrument is sufficiently clean prior to
analysis of ICAL or daily beginning CCV

Each target VOC's concentration
< 3x MDL or 0.2 ppb, whichever is
lower

Section
4.2.10.5.2.2

Operational

BFB Tune Check

50 ng injection of BFB for tune verification of MS detector
analyzed prior to initial calibration and every 24 hours of
analysis thereafter (for quadrupole MS only)

Must meet abundance criteria
listed in Table 4.2-2

Section 4.2.10.5.1
TO-15 Section
10.4.2

Critical

GC/MS Multi-Point
Initial Calibration
(ICAL)

Analysis of a minimum of five calibration levels covering
approximately 0.1 to 5 ppb

Initially and minimally every three months thereafter,
following failed BFB tune check, failed CCV, or when
changes to the instrument affect calibration response

Average RRF < 30% RSD and
each calibration level must be
within ± 30% of nominal

For linear regression (with either a
linear or quadratic fit),
r > 0.995 and each calibration level
must be within ± 30% of nominal

Section
4.2.10.5.2.2
TO-15 Section
10.5.5.1

Critical

Secondary Source
Calibration
Verification (SSCV)

Analysis of a secondary source standard at the mid-range of
the calibration curve to verily ICAL accuracy immediately
after each ICAL

Recovery within ± 30% of nominal

Section
4.2.10.5.2.3

Critical

Continuing
Calibration
Verification (CCV)

Analysis of a known standard at the mid-range of the
calibration curve to verily ongoing instrument calibration;
following each daily BFB tune check and at the conclusion of
each analytical sequence

Each target VOC must recover
within 70-130% of the nominal
spiked amount or the RRF must be
within 30% of the mean ICAL
RRF

Section
4.2.10.5.2.4
TO-15 Section
10.6.5

Critical


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7.1 VOCs via EPA Compendium Method TO-15 (Continued)

Parameter

Description and Required Frequency

Acceptance Criteria

Reference

Category

Internal Standards
(IS)

Deuterated or non-naturally occurring compounds co-
analyzed with all calibration standards, laboratory QC
samples, and field-collected samples so as to monitor
instrument response and assess matrix effects

Area response for each IS
compound within ± 40% of the
average response of the ICAL

Section 4.2.10.5.4
TO-15 Section
10.7.5

Critical

Preconcentrator
Leak Check

Pressurizing or evacuating each canister connection to the
preconcentrator to verify as leak-free prior to analysis

< 0.2 psi change/minute or
manufacturer specifications

Section
4.2.10.5.2.1

Operational

Method Blank (MB)

Canister filled with clean humidified diluent gas (gas
employed for dilution of standards and /or samples)

One with every analysis batch of 20 or fewer field-collected
samples

Each target VOC's concentration
< 3x MDL or 0.2 ppb, whichever is
lower

Section 4.2.10.4.3
TO-15 Section
10.7.5

Operational

Laboratory Control
Sample (LCS)

Canister spiked with known amount of target analyte at
approximately the lower third of the calibration curve

Recommended: One with every analysis batch of 20 or fewer
field-collected samples

Each target VOC's recovery must
be 70 to 130% of its nominal
spiked amount

Section
4.2.10.5.2.5

Operational

Retention Time
(RT)

RT of each target compound and internal standard for all
qualitatively identified compounds and internal standards

Each target VOC's RRT must be
within ± 0.06 RRT units of its
mean ICAL RRT

Each IS RT must be within ± 0.33
minutes of its mean ICAL RT

Sections
4.2.10.5.2.2 and
4.2.10.5.4
TO-15 Sections
10.5.5.2, 10.5.5.3,
and 10.5.5.4

Critical





Signal-to-noise >3:1









RT within prescribed window





Compound
Identification

Qualitative identification of each target VOC in each
standard, blank, QC sample, and field-collected sample
(including field QC samples)

Ion abundances of at least one
qualifier ion within 30% of ICAL
mean

Peak apexes co-maximized (within
one scan for quadrupole MS) for
quantitation and qualifier ions

Section 4.2.10.5.3

Critical

Replicate Analysis

A single additional analysis of a field-collected canister

Once with every analysis sequence (as prescribed in
workplan)

Precision < 25% RPD for target
VOCs with concentrations
> 5xMDL

Section
4.2.10.5.2.5
TO-15 Section
11.1.1

Operational


-------
7.1 VOCs via EPA Compendium Method TO-15 (Continued)

Parameter

Description and Required Frequency

Acceptance Criteria

Reference

Category

Duplicate Sample

Field sample collected through the same inlet probe as the
primary sample

10% of primary samples for sites performing duplicate
sample collection (as prescribed in workplan)

Precision < 25% RPD of primary
sample for concentrations
> 5xMDL

Sections 4.2.4;
4.2.4.1

Operational

Collocated Sample

Field sample collected through a separate inlet probe as the
primary sample

10% of primary samples for sites performing duplicate
sample collection (as prescribed in workplan

Precision < 25% RPD of primary
sample for concentrations
> 5xMDL

Sections 4.2.4 and
4.2.4.1

Operational

Laboratory Readiness and Proficiency

Method Detection
Limit

Determined initially and minimally annually thereafter and
when method changes alter instrument sensitivity

MDL determined via 4.1 must be:
Acrolein < 0.09 |ig/m3
Benzene <0.13 |ig/m3
1,3-Butadiene <0.10 |ig/m3
Carbon Tetrachloride <0.017
|ig/m3

Chloroform < 0.50 |ig/m3
Tetrachloroethylene < 0.17 |ig/m3
Trichloroethylene < 0.20 ng/m3
Vinyl Chloride <0.11 |ig/m3

These MDL MQOs current as of
October 2015. Refer to current
workplan template for up-to-date
MQOs.

Sections 4.1 and
4.2.7

MQO

Stock Standard
Gases

Purchased stock standard gases for each target VOC
All standards

Certified and accompanied by
certificate of analysis

Recertified or replaced annually
unless a longer expiration is
specified by the supplier

Section 4.2.10.3.1

Critical


-------
7.1 VOCs via EPA Compendium Method TO-15 (Continued)

Parameter

Description and Required Frequency

Acceptance Criteria

Reference

Category





Each target compound within
± 25% of the assigned target value





Proficiency Testing

Blind sample submitted to each laboratory to evaluate
laboratory bias

Two per calendar year1

Failure of one PT must prompt
corrective action. Failure of two
consecutive PTs (for a specific
core analyte) must prompt
qualification of the analyte in field
collected samples until return to
conformance.

Section 2.1.4.1

Operational
andMQO

Canister and Sampling Unit Testing and Maintenance



Testing of the leak tightness of each canister in the agency
fleet

Annually, may be performed simultaneously with canister
zero air check







Canister Leak Test

Leak rate must be < 0.1 psi/day

Section 4.2.6.1.1.1

Operational

Canister Zero Check

Verification that a canister does not contribute to positive
bias over an approximate 30-day period

Strongly Recommended: Each canister in the agency fleet
once annually (or as defined by agency policy) or after major
maintenance such as replacement of valve

All Tier I core target compounds
must be < 0.2 ppb or < 3x MDL,
whichever is lower

Section 4.2.6.1.1.1
TO-15 Section
8.4.3

Operational

Canister Known
Standard Gas Check

Verification that a canister does not contribute to bias over an
approximate 30-day period

Strongly Recommended: Each canister in the agency fleet
once annually (or as defined by agency policy) or after major
maintenance such as replacement of valve

All Tier I core target compounds
must be within ± 30% of nominal

Section 4.2.6.1.1.2

Operational

Sampling Unit Flow
Calibration

Calibration of sampling unit flow controller

Initially and when calibration checks demonstrate flows are
out of tolerance, or when components affecting flow are
adjusted or replaced

Flow set to match the certified
flow primary or transfer standard

Table 3.3-1
TO-15 Section
8.3.5

Practical


-------
7.1 VOCs via EPA Compendium Method TO-15 (Continued)

Parameter

Description and Required Frequency

Acceptance Criteria

Reference

Category

Sampling Unit Non-
biasing Certification

Verification that the sampling unit does not contribute to bias

Prior to field deployment and annually thereafter, or when
flow path components are repaired or replaced

Sampling units must be subject to a Zero Check and Known
Standard Challenge

Zero Check - All Tier I core target
analytes < 0.2 ppb or < 3x MDL,
whichever is lower

Known Standard Challenge - All
Tier I core target analytes within
±15% of the reference sample

Section 4.2.5.5

Operational

Sampling Unit Flow
Calibration Check or
Audit

Verification of sampling unit flow rate
Minimally quarterly, monthly recommended

Flow within ±10% of certified
primary or transfer standard flow
and design flow

Table 3.3-1

Practical

Site Specifications and Maintenance

Sampling Unit
Siting

Verify conformance to requirements
Annually

270° unobstructed probe inlet
Inlet 2-15 meters above-ground
level

>10 meters from drip line of
nearest tree

Collocated sampling inlets spaced
within 4 meters of primary
sampling unit inlet

Section 2.4

Operational

Sample Probe and
Inlet

Sample probe and inlet materials composition
Annually

Chromatographic grade stainless
steel or borosilicate glass

Section 4.2.3.2

Operational

Sample Inlet Filter

Particulate filter maintenance
Minimally annually

Clean or replace the 2-|im sintered
stainless steel filter

Section 4.2.3.3
TO-15 Section
7.1.1.5

Operational

Sampling Inlet and
Inlet Line Cleaning

Sample inlet and inlet line cleaning or replacement

Minimally annually - More often in areas with high airborne
particulate levels

Cleaned with distilled water or
replaced

Section 4.2.3.1

Operational

Data Reporting

Data Reporting to
AQS

Reporting of all results a given calendar quarter
Quarterly, within 180 days of end of calendar quarter

All field-collected sample
concentrations reported including
data less than MDL.

Field QC sample and laboratory
replicates must also be reported (as
required by workplan).

Section 3.3.1.3.15

Operational


-------
7.1 VOCs via EPA Compendium Method TO-15 (Continued)

Parameter

Description and Required Frequency

Acceptance Criteria

Reference

Category

AQS Reporting
Units

Units must be as specified with each submission to AQS

ppbv

Section 3.3.1.3.15

Critical

Data Completeness

Valid samples compared to scheduled samples
Annually

> 85% of scheduled samples

Section 3.2

MQO

Dependent upon EPA contract with PT provider


-------
7.2

Carbonyls via EPA Compendium Method TO-11A

Parameter

Description and Required Frequency

Acceptance Criteria

Reference

Category

Field Readiness Checks and Collection Activities

Collection Media

All field-collected samples and matrix quality control
samples

Cartridge containing silica gel solid
sorbent coated with DNPH

Section 4.3.5
TO-11A
Section 8.2

Critical





Sample retrieval as soon as possible, not
to exceed 72 hours post-sampling.

Sections

4.3.5.2,

4.3.5.3,	and
4.3.8.1.2
TO-11A
Sections 6.5
and 10.12



Media Handling

All field-collected samples and all quality control samples

Retrieved sample shipped and stored at
< 4°C, protected from light until
extraction.

Damaged cartridges (water damage or
cracked) must be voided.

Critical







Section



Cartridge Lot
Blank Check

Analysis of a minimum of 3 cartridges or 1% of the total lot,
whichever is greater, for each new lot

Formaldehyde < 0.15 (ig/cartridge,
Acetaldehyde < 0.10 (ig/cartridge,
Acetone < 0.30 (ig/cartridge,
all others <0.10 (ig/cartridge

4.3.5.1 and

Table

4.3-4

TO-11A

Section

9.2.5.17

Critical

Sampling Unit
Clock/Timer Check

Verified with each sample collection event

Clock/timer accurate to ±5 minute of
reference for digital timers and ±15
minutes for mechanical timers, set to
local standard time

Sample collection period verified to be
midnight to midnight

Table 3.3-1

Operational

Sampling Unit
Leak Check

Pressurization or evacuation of internal sampler flow paths
to demonstrate as leak-free

Prior to each sample collection

Must show no indicated flow

Section
4.3.8.1.1

Operational

Sampling
Frequency

One sample every six days according to the EPA National
Monitoring Schedule

Sample must be valid or a make-up
sample should be scheduled (refer to
Section 2.1.2.1)

Section
4.3.8.1.3

Critical and
MQO

Sampling Period

All field-collected samples

1380-1500 minutes (24 ± 1 hr) starting
and ending at midnight

Section
4.3.8.1.3

Critical and
MQO


-------
7.2 Carbonyls via EPA Compendium Method TO-11A (Continued)

Parameter

Description and Required Frequency

Acceptance Criteria

Reference

Category

Pre-Sample
Collection Purge

Each sampling event

Minimum of ten air changes just prior to
sample collection

Section
4.3.7.2

Practical

Sample Receipt

Chain-of-custody

All field-collected samples

Each cartridge must be uniquely
identified and accompanied by a valid
and legible COC with complete sample
documentation

Section
3.3.1.3.7

Critical

Sample Holding
Time

All field-collected samples, laboratory QC samples, and
standards

Extraction: 14 days from sample
collection (cartridge storage < 4 °C)

Analysis: 30 days from extraction
(extract storage < 4 °C)

Section

4.3.9.3

TO-11A

Sections

11.1.2 and

11.2.5

Operational







Section



Sample Receipt
Temperature Check

All field-collected samples upon receipt at the laboratory

Must be < 4°C

4.3.8.1.2
TO-11A
Section
10.12

Operational

HPLC Analysis

Solvent Blank (SB)

Prior to ICAL and daily beginning CCV

All target compounds < MDLsp (refer to
Section 4.1.3.1) ors-K (refer to Section
4.1.3.2)

Section
4.3.9.5.2

Operational

HPLC Initial
Multi-Point
Calibration (ICAL)

Initially, following failed CCV, or when changes to the
instrument affect calibration response

Injection of a minimum of 5 points covering approximately
0.01 to 3.0 (ig/mL

Correlation coefficient (r) > 0.999;
relative error for each level against
calibration curve < 20%. Absolute value
of intercept divided by slope must not
exceed MDLsp (MDLs determined by
Section 4.1.3.1) ors-K (MDLs
determined by Section 4.1.3.2)

Section

4.3.9.5.2

TO-11A

Section

11.4.3

Critical

Secondary Source
Calibration
Verification
(SSCV)

Secondary source standard prepared at the mid-range of the
calibration curve, analyzed immediately after each ICAL

85 to 115% recovery

Section

4.3.9.5.3

TO-11A

Section

11.4.4

Critical

Continuing
Calibration
Verification (CCV)

Prior to sample analysis on days when an ICAL is not
performed and minimally every 12 hours of analysis;
recommended following analysis of every 10 field-collected
samples and at the conclusion of each analytical sequence

85 to 115% recovery

Section

4.3.9.5.4

TO-11A

Section

11.4.5

Critical


-------
7.2 Carbonyls via EPA Compendium Method TO-11A (Continued)

Parameter

Description and Required Frequency

Acceptance Criteria

Reference

Category

Extraction Solvent
Method Blank
(ESMB)

An aliquot of extraction solvent delivered to a volumetric
flask. One with each extraction batch of 20 or fewer field-
collected samples.

Each target carbonyl's concentration
< MDLSp (refer to Section 4.1.3.1) or
s-K (referto Section4.1.3.2)

Section
4.3.9.4.1

Operational

Method Blank
(MB)

Unexposed DNPH cartridge extracted as a sample
One with every extraction batch of 20 or fewer field-
collected samples

Formaldehyde < 0.15 |ig/cartridge.
Acetaldehyde < 0.10 |ig/cartridge.
Acetone < 0.30 |ig/cart ridge,
all others <0.10 |ig/cart ridge

Section
4.3.9.4.1

Operational

Laboratory Control
Sample (LCS)

DNPH cartridge spiked with known amount of target analyte
at approximately the lower third of the calibration curve,
minimally quarterly, one recommended with every
extraction batch of 20 or fewer field-collected samples

Formaldehyde recovery 80-120% of
nominal spike

All others recovery 70-130% of nominal
spike

Section
4.3.9.4.1

Operational

Laboratory Control
Sample Duplicate
(LCSD)

Duplicate LCS to evaluate precision through extraction and
analysis, minimally quarterly, one recommended with every
extraction batch of 20 or fewer samples

Formaldehyde recovery 80-120% of
nominal spike

All others recovery 70-130% of nominal
spike

Precision < 20% RPD of LCS

Section
4.3.9.4.1

Operational

Retention Time
(RT)

Every injection

Each target carbonyl's RT within ± 35 or
± 2% of its mean ICAL RT

Section
4.3.9.5.2

Critical

Replicate Analysis

A single additional analysis of a field-collected sample
extract

Once with every analysis sequence of 20 or fewer samples

Precision < 10% RPD for concentrations
>0.5 |ig/cartridge

Section

4.3.9.5.5

TO-11A

Section

13.2.3

Operational

Field Blank

Minimally monthly, sample cartridge installed in primary
sampling position and exposed to field conditions for
minimally 5 minutes

Formaldehyde < 0.30 jig/cartridgc.

Acetaldehyde < 0.40 jig/cartridgc.

Acetone < 0.75 jig/cartridgc.

Sum of all other target compounds < 7.0

jig/cartridgc

Section

4.3.8.2.1

TO-11A

Section

13.3.1

Operational

Collocated Sample
Collection

Field sample collected through a separate inlet probe from
the primary sample

10% of primary samples for sites performing collocated
sample collection (as prescribed in workplan)

Precision < 20% RPD of primary sample
for concentrations >0.5 |ig/cartridge

Section

4.3.8.2.3

TO-11A

Section

13.4.1

Operational


-------
7.2 Carbonyls via EPA Compendium Method TO-11A (Continued)

Parameter

Description and Required Frequency

Acceptance Criteria

Reference

Category

Duplicate Sample
Collection

Field sample collected through the same inlet probe as the
primary sample

10% of primary samples for sites performing collocated
sample collection (as prescribed in workplan)

Precision < 20% RPD of primary sample
for concentrations >0.5 |ig/cartridge

Section

4.3.8.2.4

TO-11A

Section

13.4.1

Operational

DNPH

Chromatography
Evaluation

All cartridges

DNPH peak must be present

Section
4.3.9.5.7

Critical

For all field-collected cartridges

DNPH must be > 50% of the DNPH
area in the laboratory QC samples

Critical

Laboratory Readiness and Proficiency

Proficiency Testing

Blind sample submitted to each laboratory to evaluate
laboratory bias

Two per calendar year1

Each target compound within ± 25% of
the assigned target value

Failure of one PT must prompt
corrective action. Failure of two
consecutive PTs (for a specific core
analyte) must prompt qualification of the
analyte in field collected samples until
return to conformance.

Section
2.1.4.1

Operational
andMQO

Method Detection
Limit

Determined initially and minimally annually thereafter, and
when method changes alter instrument sensitivity

MDL must be:

Formaldehyde < 0.08 |ig/m3
Acetaldehyde < 0.45 |ig/m3

These MDL MQOs current as of
October 2015. Refer to current workplan
template for up-to-date MQOs.

Sections 4.1
and 4.3.6

MQO

Stock Standard
Solutions

Purchased stock materials for each target carbonyl
All standards

Certified and accompanied by certificate
of analysis

Section
4.3.9.2.2

Critical

Working Standard
Solutions

Storage of all working standards

Stored at < 4°C, protected from light

Section
4.3.9.2.4
TO-11A
Section 9.4.3

Critical


-------
7.2 Carbonyls via EPA Compendium Method TO-11A (Continued)

Parameter

Description and Required Frequency

Acceptance Criteria

Reference

Category

Sampling Unit Testing and Maintenance

Field Sampler Flow
Rate Calibration

Calibration of sampling unit flow controller

Initially and following failure of flow verification checks

Flow set to match a certified flow
transfer standard

Table 3.3-1
and 4.3.7.1.2

Critical

Ozone Scrubber
Recharge

Recharge ozone scrubber with KI
Minimally annually

Scrubber capacity sufficient to be
effective (ozone removal > 95%) for 12
months of 24-hour sampling every sixth
day

Section
4.3.4.1
TO-11A
Section 10.1

Critical

Sampling Unit

Non-biasing

Certification

Verification with humidified zero air or nitrogen that the
sampling unit does not contribute to positive bias

Prior to field deployment and annually thereafter, or when
flow path components are repaired or replaced

Difference between challenge and
reference cartridge <0.2 ppbv for each
target carbonyl

Section
4.3.7.1.1

Operational

Sampling Unit
Flow Calibration
Check or Audit

Verification of sampling unit flow rate
Minimally quarterly, monthly recommended

Flow within ± 10% of certified primary
or transfer standard flow and design
flow

Table 3.3-1

Critical

Site Specifications and Maintenance





270° unobstructed probe inlet





Sampling Unit
Siting

Verify conformance to requirements
Annually

Inlet 2-15 meters above-ground level
> 10 meters from drip line of nearest tree

Collocated sampling inlets spaced no
more than 4 meters from primary
sampling unit inlet

Section 2.4

Operational

Sample Probe and
Inlet

Sample probe and inlet materials composition
Annually

Chromatographic grade stainless steel,
PTFE Teflon, or borosilicate glass

Section
4.3.7.2

Critical

Sample Inlet Filter

Particulate filter maintenance
Minimally annually, if equipped

Clean or replace the inline particulate
filter (if equipped)

Section
4.3.7.3

Operational



Sample inlet and inlet line cleaning or replacement







Sampling Inlet and
Inlet Line Cleaning

Minimally annually - More often in areas with high airborne
particulate levels

Cleaned with distilled water or replaced

Section
4.3.7.3

Operational


-------
7.2 Carbonyls via EPA Compendium Method TO-11A (Continued)

Parameter Description and Required Frequency Acceptance Criteria

Reference

Category

Data Reporting

Data Reporting to
AQS

Reporting of all results a given calendar quarter
Quarterly, within 180 days of end of calendar quarter

All field-collected sample
concentrations reported including data
less than MDL.

All data must be in standard conditions.

Field QC sample and laboratory
replicates must also be reported.

Section
3.3.1.3.15

Operational

AQS Reporting
Units

Units must be as specified with each quarterly submission to
AQS

mass/volume (ng/m3 or |ig/m3)

Section
3.3.1.3.15

Critical

Data Completeness

Valid samples compared to scheduled samples
Annually

> 85% of scheduled samples

Section 3.2

MQO


-------
7.3	Metals via EPA Compendium Method IO 3.1 and IO 3.5

Parameter

Description and Required Frequency

Acceptance Criteria

Reference

Category

Field Readiness Checks and Collection Activities

Collection Media

All field-collected samples and matrix quality control
samples

Low volume collection:
47-mm Teflon filters with
polypropylene support ring and
2-\im pore size

Section 4.4.9.3
40CFR Part 50
Appendix Q
Section 6.2.3

Critical

High volume collection:
8"xl0" quartz fiber filter (QFF)
filters with 2-|im pore size

Section 4.4.10.3
103.1 Section 4.1.6

Critical

Media Inspection

Filters inspected for pinholes, tears, or other
imperfections unsuitable for sample collection

All filters

Filters with defects must be
discarded

Section 4.4.3.3
103.1 Section 4.2
102.3 Section 7.2

Critical

Media Handling

All field-collected samples and quality control samples

Low volume: Plastic or Teflon
coated forceps or powder-free
gloves

Section 4.4.3.2
103.1 Section
5.2.1.1

102.3 Section 7.2

Practical

High volume: Plastic or Teflon
coated forceps or powder-free
gloves

Practical

Lot Background
Determination

For each new lot of media:

•	As part of the MDL process when determining
MDLs via Section 4.1.3.1

or

•	Five separate filters digested and analyzed

Low volume: No acceptance
criterion

Lot blank subtraction is not
permitted

Section 4.4.9.3.1

Practical

High volume: No acceptance
criterion

Lot blank subtraction is not
permitted

Section 4.4.10.3.1
103.1 Table 9

Practical

Sampling Unit

Clock/Timer

Check

Verified with each sample collection event

Clock/timer accurate to ±5
minute of reference for digital
timers and within ±15 minutes
for mechanical timers, set to local
standard time

Sample collection period verified
to be midnight to midnight

Table 3.3-1

Operational


-------
7.3 Metals via EPA Compendium Method IO 3.1 and IO 3.5 (Continued)

Parameter

Description and Required Frequency

Acceptance Criteria

Reference

Category

Sampling Unit
Leak Check

Verification that sampling train is leak tight
Every five sample collection events

Low volume: Leak rate of < 25
mmHg over 30 seconds or 80
mL/min

Section 4.4.9.4
EPA QA
Handbook Vol II
Appendix D

Practical

High volume: absence of a
whistle

Section 4.4.10.4
102.1 Section
7.3.1.6

Practical

Sampling
Frequency

One sample every six days according to the EPA
National Monitoring Schedule

Sample must be valid or a make-
up sample should be scheduled
(refer to Section 2.1.2.1)

Sections 4.4.9.4.1
and 4.4.10.4.1

Critical and
MQO

Sampling Period

All field-collected samples

1380-1500 minutes (24 ± 1 hr)
starting and ending at midnight

Sections 4.4.9.4.1
and 4.4.10.4.1

Critical and
MQO

Pre-Sample
Collection Warm-
up

Only for high volume sampling units without computer
controlled flow

Minimum of five minutes (ten
minutes recommended) after
filter installation but before
sample collection

Section 4.4.10.4
102.1 Section
7.4.2.9

Operational

Post-Sample
Collection Warm-
up

Only for high volume sampling units without computer
controlled flow

Minimum of five minutes (ten
minutes recommended) before
filter retrieval

Section 4.4.10.4
102.1 Section
7.4.2.9

Operational

Sample Receipt

Chain-of-custody

All field-collected samples

Each filter must be uniquely
identified and accompanied by a
valid and legible COC with
complete sample documentation

Section 3.3.1.3.7

Critical

Sample Holding
Time

All field-collected samples and laboratory QC samples

Digestion: within 180 days from
sample collection or preparation

Analysis: within 180 days from
sample collection

Section 4.4.1
103.1 Section 6.1.2

Operational

Acid Digestion and ICP/MS Analysis

Microwave
Calibration

Standardization of microwave power output

Output calibration not to exceed six months; monthly
recommended

Level of output should differ by
no more than 10% across batches

Section 4.4.9.5.2.2

Operational


-------
7.3 Metals via EPA Compendium Method IO 3.1 and IO 3.5 (Continued)

Parameter

Description and Required Frequency

Acceptance Criteria

Reference

Category

Hot Block

Temperature

Verification

Reagent water blank with thermometer to ensure
digestion temperature consistent for all wells

Initially and annually thereafter for each well in the hot
block digester

Within ± 5°C of desired
temperature

Section 4.4.9.5.2.1

Operational

Hot Block

Temperature

Check

Reagent water blank with thermometer to monitor
digestion temperature

Each digestion batch

Within ± 5°C of desired
temperature

Section 4.4.9.5.2.1

Operational

ICP/MS Warm Up

Warm up of ICP torch and MS detector
Each day of analysis

Minimum of 30 minutes (or
according to manufacturer
specifications) prior to
performing initial calibration

Section 4.4.11.6
103.5 Section
10.1.1

Practical

ICP/MS Tuning

Analysis of tuning solution containing low (e.g. Li), and
medium (e.g. Mg), and high (e.g. Pb) mass elements

Each day of analysis during or immediately following
warm up

•	Minimum resolution of
0.75 amu at 5% peak
height

•	Mass calibration within
0.1 amu of unit mass

•	Five replicates of tuning
solution with %RSD <
5%

•	Manufacturer
specifications may be
followed

Section 4.4.11.6
103.5 Section
10.1.1

Critical

Initial Calibration
Blank (ICB)

Analysis of undigested reagent blank

Each day of analysis prior to initial calibration (ICAL)
and immediately following the initial calibration
verification (ICV)

ICB following ICV: each target
element's concentration
< MDLSp (refer to Section

4.1.3.1)	ors-K (refer to Section

4.1.3.2)

Sections 4.4.11.7.1
and 4.4.11.7.3
103.5 Section
11.3.3

Critical

ICP/MS Initial
Multi-Point
Calibration (ICAL)

Minimum of three standard concentration levels plus
ICB covering approximately 0.1 to 250 |ig/L

Each day of analysis, following failed CCV, or retuning
of the MS

Linear regression correlation
coefficient (r) > 0.995

Replicate integrations RSD <
10%

Section 4.4.11.7.1

Critical


-------
7.3 Metals via EPA Compendium Method IO 3.1 and IO 3.5 (Continued)

Parameter

Description and Required Frequency

Acceptance Criteria

Reference

Category

Initial Calibration
Verification (ICV)

Analysis of second source calibration verification
Each day of analysis immediately following ICAL

Within ± 10% of nominal

Section 4.4.11.7.2
103.5 Section
11.3.2

Critical

Interference Check
Standard (ICS)

Each day of analysis following the second ICB and
every 8 hours of analysis thereafter. Once daily for ICP-
MS with collision reaction cells

Analysis of two solutions which contain interferants
(ICS A) and target elements with known interferences
(ICS B)

ICS A: all target elements
< 3x MDLSp (refer to Section
4.1.3.1) or 3xsK (referto
Section 4.1.3.2) - may be
subtracted for background
indicated on certificate of
analysis

ICS B: 80 to 120% recovery

Section 4.4.11.7.4
103.5 Section
11.3.5

Operational

Continuing
Calibration
Verification (CCV)

Each day of analysis immediately following the ICS,
following every 10 sample injections, and at the
conclusion of each analytical sequence

90 to 110% recovery

Section 4.4.11.7.5
103.5 Section
11.3.6

Critical

Continuing
Calibration Blank
(CCB)

Each day of analysis immediately after each CCV

all target elements < MDLsp
(refer to Section 4.1.3.1) ors-K
(refer to Section 4.1.3.2)

Section 4.4.11.7.6
103.5 Section
11.3.7

Critical

Reagent Blank
(RB)

Digested reagent blank

Once with each extraction batch of 20 or fewer samples

Low volume: All target elements
< MDLsp (refer to Section

4.1.3.1)	or s-K (refer to Section

4.1.3.2)

Sections 4.4.9.5.1,
4.4.11.7.7, and
Table 4.4-3

Operational

High volume: All target
elements

< MDLSp (refer to Section

4.1.3.1)	or s-K (refer to Section

4.1.3.2)

Sections
4.4.10.5.1,
4.4.11.7.7, and
Table 4.4-3

Operational

Method Blank
(MB)

Low volume: Digested blank filter

Once with each extraction batch of 20 or fewer samples

High volume: Digested blank filter

Once with each extraction batch of 20 or fewer samples

Low volume: All target elements
< MDL

Sections 4.4.9.5.1,
4.4.11.7.7, and
Table 4.4-3

Operational

High volume: All target
elements
< MDL

Sections
4.4.10.5.1,
4.4.11.7.7, and
Table 4.4-3
103.5 Section
11.3.8

Operational

Reagent Blank
Spike (RBS)

Spiked digested reagent blank (no filter)

Low volume: Recovery within
80-120% of nominal for all target
elements

Sections 4.4.9.5.1,
4.4.11.7.7, and
Table 4.4-3

Operational


-------
7.3 Metals via EPA Compendium Method IO 3.1 and IO 3.5 (Continued)

Parameter

Description and Required Frequency

Acceptance Criteria

Reference

Category



Once with each digestion batch of 20 or fewer field-
collected samples

High volume: Recovery within
80-120% of nominal for all target
elements

Sections
4.4.10.5.1,
4.4.11.7.7, and
Table 4.4-3

Operational

Laboratory Control
Sample (LCS)

Low volume: Digested spiked filter

Once with each extraction batch of 20 or fewer field-
collected samples

High volume: Digested spiked filter strip

Once with each extraction batch of 20 or fewer field-
collected samples

Low volume: Recovery within
80-120% of nominal for all target
elements

Sections 4.4.9.5.1,
4.4.11.7.7, and
Table 4.4-3

Operational

High volume: Recovery within
80-120% of nominal for all target
elements

Sections
4.4.10.5.1,
4.4.11.7.7, and
Table 4.4-3
103.5 Section
11.3.9

Operational

Laboratory Control
Sample Duplicate
(LCSD)

Low volume: Duplicate digested spiked filter

Once with each extraction batch of 20 or fewer field-
collected samples

High volume: Duplicate digested spiked filter strip
Once with each extraction batch of 20 or fewer field-
collected samples

Low volume: Recovery within
80-120% of nominal for all target
elements and precision < 20%
RPD of LCS

Sections 4.4.9.5.1,
4.4.11.7.7, and
Table 4.4-3

Operational

High volume: Recovery within
80-120% of nominal for all target
elements and precision < 20%
RPD of LCS - Not required if
batch contains MSD

Sections
4.4.10.5.1,
4.4.11.7.7, and
Table 4.4-3

Operational

Duplicate Digested
Filter Strip

High volume only

Digested duplicate field-collected filter strip

Once with each extraction batch of 20 or fewer field-
collected samples

Precision < 20% RPD for
elements
> 5xMDL

Sections
4.4.10.5.1,
4.4.11.7.7, and
Table 4.4-3
103.5 Section
11.3.11

Operational

Matrix Spike (MS)

High volume only

Digested spiked field-collected filter strip

Once with each extraction batch of 20 or fewer field-
collected samples

Recovery within 80-120% of the
nominal spiked amount for all
target elements - 75-125% for Sb

Sections
4.4.10.5.1,
4.4.11.7.7, and
Table 4.4-3
103.5 Section
11.3.10

Operational


-------
7.3 Metals via EPA Compendium Method IO 3.1 and IO 3.5 (Continued)

Parameter

Description and Required Frequency

Acceptance Criteria

Reference

Category

Matrix Spike
Duplicate (MSD)

High volume only

Duplicate digested spiked field-collected filter strip

Once with each extraction batch of 20 or fewer field-
collected samples

Recovery within 80-120% of the
nominal spiked amount for all
target elements - 75-125% for Sb

and precision < 20% RPD of MS

Sections
4.4.10.5.1,
4.4.11.7.7, and
Table 4.4-3
103.5 Section
11.3.11

Operational

Serial Dilution

Five-fold dilution of a field-collected sample digestate

Once with every analysis sequence of 20 or fewer field-
collected samples

Recovery of 90-110% of
undiluted sample for elements >
25x MDL

Section 4.4.11.7.8
103.5 Section
11.3.12

Operational

Replicate Analysis

A single additional analysis of a field-collected sample
digestate

Once with every analysis sequence of 20 or fewer field-
collected samples

Precision < 10% RPD for
concentrations > 5x MDL

Section 4.4.11.7.9

Operational

Internal Standards
(IS)

Non-target elements added to each analyzed solution at
the same concentration

60 to 125% recovery

Section 4.4.11.4
103.5 Section 11.5

Critical

Field Blank

Sample filter installed in primary sampling unit for
minimally 5 minutes

Minimally monthly for primary sampling units, as 18%
(approximately 1 out of 5) of collocated samples

All target elements < MDL

Section 4.4.5

Operational



Field sample collected with a separate sampling unit
between 2 and 4 meters from primary sampling unit







Collocated Sample
Collection

10% of primary samples for sites performing collocated
sample collection (as prescribed in workplan)

Precision < 20% RPD of primary
sample for concentrations > 5x
MDL

Section 4.4.4.1

Operational


-------
7.3 Metals via EPA Compendium Method IO 3.1 and IO 3.5 (Continued)

Parameter

Description and Required Frequency Acceptance Criteria

Reference

Category

Laboratory Readiness and Proficiency

Proficiency
Testing

Blind sample submitted to each laboratory to evaluate
laboratory bias

Two per calendar year1

Each target compound element
within ± 25% of the assigned
target value

Failure of one PT must prompt
corrective action. Failure of two
consecutive PTs (for a specific
core analyte) must prompt
qualification of the analyte in
field collected samples until
return to conformance.

Section 2.1.4.1

Operational and
MQO

Method Detection
Limit

Determined initially and minimally annually thereafter,
with each new lot of filter media, and when method
changes alter instrument sensitivity

MDL must be:

Arsenic < 0.00023 |ig/m3
Beryllium < 0.00042 |ig/m3
Cadmium < 0.00056 |ig/m3
Lead <0.15 |ig/m3
Manganese < 0.005 |ig/m3
Nickel < 0.0021 |ig/m3

These MDL MQOs current as of
October 2015. Refer to current
workplan template for up-to-date
MQOs.

Sections 4.1 and
4.4.8

MQO

Stock Standard
Solutions

Purchased stock materials for each target element
All standards

Certified and accompanied by
certificate of analysis

Section 4.4.7

Critical

Working Standard
Solutions

Storage of all working standards

Stored in Teflon or suitable
plastic bottles

Section 4.4.7
103.5 Section
7.2.4

Practical

Sampling Unit Testing and Maintenance

Field Sampler
Flow Rate
Calibration

Calibration of sampling unit flow controller
Initially and when flow verification checks fail criteria

Flow set to match a certified
transfer flow standard

Table 3.3-1 and
4.4.9.2 and
4.4.10.2

Critical


-------
7.3 Metals via EPA Compendium Method IO 3.1 and IO 3.5 (Continued)

Parameter

Description and Required Frequency

Acceptance Criteria

Reference

Category

Sampling Unit
Flow Calibration
Check

Verification of sampling unit flow rate
Minimally quarterly, monthly recommended

Low volume:

Within ± 4% of certified transfer
standard flow and within ± 5% of
design flow

Table 3.3-1 and
40 CFR 58
Appendix A
Section 3.3.3 -
EPA QA Guidance
Document 2.12

Operational

High volume:

Within ± 7% of certified transfer
standard flow and within ± 10%
of design flow

Table 3.3-1 and
40 CFR 58
Appendix A
Section 3.3.3 EPA
QA Handbook
Section 2.11.7

Operational


-------
7.3 Metals via EPA Compendium Method IO 3.1 and IO 3.5 (Continued)

Parameter

Description and Required Frequency

Acceptance Criteria

Reference

Category

Site Specifications and Maintenance





270° unobstructed probe inlet









Inlet 2-15 meters above-ground
level

>10 meters from drip line of





Sampling Unit
Siting

Verify conformance to requirements
Annually

nearest tree

Low volume collocated sampling
inlets spaced 1-4 meters from
primary sampling unit inlet

High volume collocated sampling
inlets spaced 2-4 meters from
primary sampling unit inlet

Section 2.4
40 CFR Part 58
Appendix E

Operational

Data Reporting





All field-collected sample
concentrations reported including
data less than MDL.





Data Reporting to
AQS

Reporting of all results a given calendar quarter
Quarterly, within 1820 days of end of calendar quarter

All data must be in local
conditions and may additionally
be reported in standard
conditions

Field QC sample and laboratory
replicates must also be reported
(as prescribed in workplan)

Section 3.3.1.3.15

Operational

AQS Reporting
Units

Units must be as specified

With each quarterly submission to AQS

mass/volume (ng/m3 or |ig/m3)

Section 3.3.1.3.15

Critical

Data Completeness

Valid samples compared to scheduled samples
Annually

> 85% of scheduled samples

Section 3.2

MQO


-------
7.4	PAHs via EPA Compendium Method TO-13A

Parameter

Description and Required Frequency

Acceptance Criteria

Reference

Category

Field Readiness Checks and Collection Activities

Collection Media

All field-collected samples and matrix quality control
samples

Glass cartridge containing two PUF plugs
totaling 3" in height, 15 g styrene-divinyl
polymer resin, 104-mm quartz fiber filter
with 2-\im pore size

Section 4.5.3
TO-13A
Section 9.1

Critical

Media Handling

All field-collected samples and laboratory quality control
samples

Sample retrieval as soon as possible
recommended, preferably within 24 hours,
not to exceed 72 hours post-sampling

Retrieved sample shipped and stored at
< 4°C, protected from light until extraction

Damaged cartridges (leaking resin) must
be voided.

Section

4.5.4.1

TO-13A

Section

11.3.4.10

Operational

Cartridge Lot
Blank Check

Analysis of a cartridge from each lot to demonstrate
appropriate media cleanliness

Minimum of 1 cartridge for each new lot

All target PAHs <10 ng/cartridge

Section 4.5.3
TO-13A
Section
14.2.1

Critical

Sampling Unit

Clock/Timer

Check

Verified with each sample collection event

Clock/timer accurate to ± 5 minutes of
reference for digital timers, within ±15
minutes for mechanical timers, set to local
standard time

Sample collection period verified to be
midnight to midnight

Table 3.3-1

Operational

Sampling
Frequency

One sample every six days according to the EPA National
Monitoring Schedule

Sample must be valid or a make-up sample
scheduled (refer to Section 2.1.2.1)

Section
4.5.4.1

Critical and
MQO

Sampling Period

All field-collected samples

1380-1500 minutes (24 ± 1 hr) starting and
ending at midnight

Section
4.5.4.1

Critical and
MQO

Sample Flow Rate

All field-collected samples

0.140 to 0.245 m3/minute for total
collection volume of 200 to 350 m3 (at
standard conditions of P = 1 atm and T =
25°C)

Section 4.5.1

Critical

Pre-Sample
Collection Warm-
up

Only for sampling units without computer controlled flow

Minimum of five minutes (ten minutes are
recommended) after sampling head
installation but before sample collection

Section 4.5.4
TO-13A
Section
11.3.3.3

Practical


-------
7.4 PAHs via EPA Compendium Method TO-13A (Continued)

Parameter

Description and Required Frequency

Acceptance Criteria

Reference

Category

Post-Sample
Collection Warm-
up

Only for sampling units without computer controlled flow

Minimum of five minutes (ten minutes are
recommended) before sampling head
retrieval

Section
4.5.4.1

Practical

Sample Receipt

Chain-of-custody

All field-collected samples including field QC samples

Each cartridge/QFF must be uniquely
identified and accompanied by a valid and
legible COC with complete sample
documentation

Section
3.3.1.3.7

Critical

Sample Holding
Time

All field-collected samples and laboratory QC samples

Extraction: 14 days from sample
collection (cartridge storage < 4 °C)

Analysis: 40 days from extraction (extract
storage < 4 °C)

Section

4.5.5.2

TO-13A

Section

11.3.4.10

Operational

Sample Receipt

Temperature

Check

Verification of proper shipping temperature for all field-
collected samples upon receipt at the laboratory

Must be < 4°C unless delivery time from
field site is < 4 hours

Section
4.5.4.1

Operational

Extraction and GC/MS Analysis

DFTPP Tuning

5-50 ng injected to tune MS prior to ICAL and every 12
hours of analysis thereafter

For GC/MS operated in full scan or
SIM/full scan must meet criteria listed in
Table 4.5-2

GC/MS operated in SIM mode must tune
to meet criteria in Section 4.5.5.5.2

Section

4.5.5.5.2

TO-13A

Section

13.3.3

Critical

Solvent Blank
(SB)

Aliquot of solvent analyzed to demonstrate the instrument
is sufficiently clean to begin analysis

Prior to ICAL and daily beginning CCV

All target, surrogate, and IS compounds
not qualitatively detected

Section

4.5.5.5.3

TO-13A

Section

14.1.2

Critical

GC/MS Initial
Multi-Point
Calibration
(ICAL)

Minimum of 5 points covering approximately 0.1 to 2.0
(ig/mL

Initially, following failed CCV, following failed DFTPP
tune check, or when changes to the instrument affect
calibration response

Average RRF < 30% and each calibration
level must be within ± 30% of nominal

For linear regression (with either a linear
or quadratic fit) correlation coefficient (r)
> 0.995 and each calibration level within ±
30% of nominal

Section

4.5.5.5.3

TO-13A

Section

13.3.4.5

Critical

Secondary Source
Calibration
Verification
(SSCV)

Secondary source standard prepared at the mid-range of
the calibration curve, analyzed immediately after each
ICAL

70 to 130% recovery of nominal or RRF
within ±30% of ICAL average RRG

Section
4.5.5.5.4

Critical


-------
7.4 PAHs via EPA Compendium Method TO-13A (Continued)

Parameter

Description and Required Frequency

Acceptance Criteria

Reference

Category

Continuing
Calibration
Verification
(CCV)

Mid-range standard analyzed prior to sample analysis on
days when an ICAL is not performed, every 12 hours of
analysis following the DFTPP check, and at the conclusion
of each analytical sequence

70 to 130% recovery of nominal or RRF
within ±30% of ICAL average RRG

Section

4.5.5.5.5

TO-13A

Section

13.3.5.5

Critical

Method Blank
(MB)

Unexposed PUF/resin cartridge and QFF extracted as a
sample

One with every extraction batch of 20 or fewer field-
collected samples

All target PAHs < 2x MDL

Section

4.5.5.5.6

TO-13A

Section

13.3.6

Operational

Laboratory
Control Sample
(LCS)

PUF/resin cartridge and QFF spiked with known amount
of target analyte at approximately the lower third of the
calibration curve

Minimally quarterly; recommended one with every
extraction batch of 20 or fewer field-collected samples

All target PAHs 60-120% recovery of
nominal spike

Section

4.5.5.5.6

TO-13A

Section

13.3.7

Operational

Laboratory
Control Sample
Duplicate (LCSD)

Duplicate LCS to evaluate precision through extraction
and analysis

Minimally quarterly, recommended one with every
extraction batch of 20 or fewer field-collected samples

All target PAHs 60-120% recovery of
nominal spike

Precision < 20% RPD of LCS

Section
4.5.5.5.6

Operational

Internal Standards

Deuterated homologues of target PAHs added to every
injection except beginning SB

50-200% of the area response of the mid-
level ICAL standard from ICAL

Section

4.5.5.5.8

TO-13A

Section

13.4.7

Critical

Field Surrogate
Compounds

Deuterated homologues of target PAHs added to each
cartridge before field deployment, also added to cartridges
for laboratory and field QC

Recovery 60-120%

Sections

4.5.3.3 and

4.5.5.5.9

TO-13A

Section

13.4.6.3

Operational

Extraction

Surrogate

Compounds

Deuterated homologues of target PAHs added to each
extracted field sample, field QC sample, and laboratory
QC sample

Recovery 60-120%

Sections

4.5.5.1.4.2

and 4.5.5.5.9

TO-13A

Section

13.4.6.3

Operational


-------
7.4 PAHs via EPA Compendium Method TO-13A (Continued)

Parameter

Description and Required Frequency

Acceptance Criteria

Reference

Category

Retention Time
(RT)

Every injection

Target and surrogate compound RT within
±0.06 relative retention time units (RRT)
of mean ICAL RRT

Internal standard RT within ± 0.33 minute
of the most recent CCV

Section

4.5.5.5.3

TO-13A

Sections

13.4.6.3 and

13.3.4.5

Critical



A single additional analysis of a field-collected sample







Replicate
Analysis

extract

Once with every analysis sequence of 20 or fewer field-
collected samples (as required by workplan)

Precision < 10% RPD for concentrations >
0.5 ng/mL

Section
4.5.5.5.6

Operational

Field Blank

Blank sample cartridge installed in sampling unit for
minimally five minutes

Minimally monthly

All target PAHs < 5x MDL

Section

4.5.4.2

TO-13A

Section

11.3.4.9

Operational

Collocated

Sample

Collection

Field sample collected with a separate sampling unit
between 2 and 4 meters from primary sampling unit

10% of primary samples for sites performing collocated
sample collection (as required by workplan)

Precision < 20% RPD of primary sample
for concentrations >0.5 ng/mL

Section
4.5.4.3

Operational





Signal-to-noise >3:1









RT within prescribed window

Section



Compound
Identification

Qualitative identification of each target PAH in each
standard, blank, QC sample, and field-collected sample
(including field QC samples)

At least one qualifier ion abundance within
15% of ICAL mean

Peak apexes co-maximized (within one
scan for quadrupole MS) for quantitation
and qualifier ions

4.5.5.5.7
TO-13A
Section
13.4.3

Critical


-------
7.4 PAHs via EPA Compendium Method TO-13A (Continued)

Parameter

Description and Required Frequency

Acceptance Criteria

Reference

Category

Laboratory Readiness and Proficiency





Each target compound within ± 25% of the
assigned target value





Proficiency
Testing

Blind sample submitted to each laboratory to evaluate
laboratory bias

Two per calendar year1

Failure of one PT must prompt corrective
action. Failure of two consecutive PTs (for
a specific core analyte) must prompt
qualification of the analyte in field
collected samples until return to
conformance.

Section
2.1.4.1

Operational
and MQO

Method Detection
Limit

Determined initially and minimally annually thereafter and
when method changes alter instrument sensitivity

MDL must be:

Benzo(a)pyrene < 0.00091 |ig/m3
Naphthalene < 0.029 |ig/m3

These MDL MQOs current as of October
2015. Refer to current workplan template
for up-to-date MQOs.

Sections 4.1
and 4.5.5.4

MQO

Stock Standard
Materials

Purchased stock materials for each target PAH
All standards

Certified and accompanied by certificate of
analysis

Section
4.5.5.1.2

Critical

Working Standard
Solutions

Storage of all working standards

Stored at < -10°C, protected from light

Section
4.5.5.2

Critical

Sampling Unit Testing and Maintenance

Field Sampler
Flow Rate
Calibration

Calibration of sampling unit flow controller

Initially, when flow verification checks fail criteria, or
when instrument maintenance changes flow characteristics
of the sampling unit

Flow set to match a certified flow transfer
standard

Table 3.3-1
and 4.5.2.1

Critical

Sampling Unit
Flow Calibration
Check or Audit

Verification of sampling unit flow rate
Minimally quarterly, monthly recommended

Flow within ± 10% of certified primary or
transfer standard flow and design flow

Table 3.3-1

Critical

Site Specifications and Maintenance





270° unobstructed probe inlet





Sampling Unit
Siting

Verify conformance to requirements
Annually

Inlet 2-15 meters above-ground level
> 10 meters from drip line of nearest tree

Collocated sampling inlets spaced 2-4
meters from primary sampling unit inlet

Section 2.4

Operational


-------
7.4 PAHs via EPA Compendium Method TO-13A (Continued)

Parameter

Description and Required Frequency

Acceptance Criteria

Reference

Category

Data Reporting





All field-collected sample concentrations





Data Reporting to
AQS

Reporting of all results a given calendar quarter
Quarterly, within 180 days of end of calendar quarter

reported including data less than MDL.

All data must be in standard conditions.

Field QC sample and laboratory replicates
must also be reported.

Section
3.3.1.3.15

Operational

AQS Reporting
Units

Units must be as specified

With each quarterly submission to AQS

mass/volume (ng/m3 or |ig/m3)

Section
3.3.1.3.15

Critical

Data

Completeness

Valid samples compared to scheduled samples
Annually

> 85% of scheduled samples

Section 3.2

MQO


-------
NATTS TAD Revision 3
Appendix A

APPENDIX A
DRAFT REPORT
ON

DEVELOPMENT OF DATA QUALITY OBJECTIVES (DQOS) FOR
THE NATIONAL AMBIENT AIR TOXICS TRENDS
MONITORING NETWORK

SEPTEMBER 27, 2002

202


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NATTS TAD Revision 3
Appendix A

September 27, 2002

DRAFT REPORT
on

DEVELOPMENT OF DATA QUALITY OBJECTIVES (DQOS) FOR THE
NATIONAL AMBIENT AIR TOXICS TRENDS MONITORING NETWORK

Contract No. 68-D-98-030
Work Assignment 5-12

for

Sharon Nizich
Work Assignment Manager

Vickie Presnell
Project Officer

Office of Air Quality Planning and Standards
Emissions, Monitoring, and Analysis Division
U.S. ENVIRONMENTAL PROTECTION AGENCY
Research Triangle Park, North Carolina 27711

Prepared by

BATTEL LE
505 King Avenue
Columbus, Ohio 43201-2693

203


-------
NATTS TAD Revision 3
Appendix A

BATTELLE DISCLAIMER

This report is a work prepared for the United States Environmental Protection
Agency by Battelle Memorial Institute, In no event shall either the United States
Environmental Protection Agency or Battelle Memorial Institute have any
responsibility or liability for any consequences of any use, misuse, inability to
use, or reliance upon the information contained herein, nor does either warrant or
otherwise represent in any way the accuracy, adequacy, efficacy, or applicability
of the contents hereof.

DQOs for Trends - Draft Report	ii	September 27, 2002

204


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NATTS TAD Revision 3
Appendix A

TABLE OF CONTENTS

Page

EXECUTIVE SUMMARY	 v

1.0 INTRODUCTION	 1

2.0 THE GENERAL DQO PROCESS		1

2.1	State the Problem		2

2.2	Identify the Decision		3

2.3	Identify the Inputs to the Decision		3

2.4	Define the Study Boundaries		4

2.5	Develop a Decision Rule		4

2.6	Specify Tolerable Limits on the Decision Errors		5

2.7	Optimize the Design		6

3.0 DQOS FOR THE SIX STUDY COMPOUNDS	 6

3.1	DQOs for Measuring the Percent Decrease of Benzene at Urban Locations	 9

3.2	DQOs for Measuring the Percent Decrease of Benzene at Rural Locations	 10

3.3	DQOs for Measuring the Percent Decrease of 1,3-Butadiene at Urban Locations	11

3.4	DQOs for Measuring the Percent Decrease of 1,3-Butadiene at Rural Locations	12

3.5	DQOs for Measuring the Percent Decrease of Arsenic at Urban Locations	13

3.6	DQOs for Measuring the Percent Decrease of Arsenic at Rural Locations	14

3.7	DQOs for Measuring the Percent Decrease of Chromium	15

3.8	DQOs for Measuring the Percent Decrease of Acrolein	16

3.9	DQOs for Measuring the Percent Decrease of Formaldehyde at Urban Locations	17

3.10	DQOs for Measuring the Percent Decrease of Formaldehyde at Rural Locations	18

APPENDIX A: ESTIMATES OF THE DQO PARAMETERS MEASURING ENVIRONMENTAL

VARIABILITY	A-1

List of Tables

Table 3.1.1	DQO input parameters for benzene at urban locations	 9

Table 3.1.2	DQO output parameters for benzene at urban locations	 9

Table 3.2.1	DQO input parameters for benzene at rural locations	10

Table 3.2.2	DQO output parameters for benzene at rural locations	10

Table 3.3.1	DQO input parameters for 1,3-butadiene at urban locations	11

Table 3.3.2	DQO output parameters for 1,3-butadiene at urban locations	11

Table 3.4.1	DQO input parameters for 1,3-butadiene at rural locations	12

Table 3.4.2	DQO output parameters for 1,3-butadiene at rural locations	12

Table 3.5.1	DQO input parameters for arsenic at urban locations	13

Table 3.5.2	DQO output parameters for arsenic at urban locations	13

Table 3.6.1	DQO input parameters for arsenic at rural locations	14

Table 3.6.2	DQO output parameters for arsenic at rural locations	14

Table 3.7.1	DQO input parameters for chromium	15

Table 3.7.2	DQO output parameters for chromium	15

Table 3.8.1	DQO input parameters for acrolein	16

Table 3.8.2	DQO output parameters for acrolein	16

Table 3.9.1	DQO input parameters for formaldehyde at urban locations	17

Table 3.9.2	DQO output parameters for formaldehyde at urban locations	17

Table 3.10.1	DQO input parameters for formaldehyde at rural locations	18

Table 3.10.2	DQO output parameters for formaldehyde at rural locations	18

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List of Figures

Figure 3.1.1 Power curve for detecting a 15 percent decrease between 3-year means
of benzene concentrations based on the data verification found in urban

locations of the Pilot Study	

Figure 3.2.1 Power curve for detecting a 15 percent decrease between 3-year means
of benzene concentrations based on the data variation found in rural

locations of the Pilot Study	

Figure 3.3.1 Power curve for detecting a 15 percent decrease between 3-year means
of 1,3-butadiene concentrations based on the data variation found in urban

locations of the Pilot Study	

Figure 3.4.1 Power curve for detecting a 15 percent decrease between 3-year means
of 1,3-butadiene concentrations based on the data variation found in rural

locations of the Pilot Study	

Figure 3.5.1 Power curve for detecting a 15 percent decrease between 3-year means
of arsenic concentrations based on the data variation found in urban

locations of the Pilot Study	

Figure 3.6.1 Power curve for detecting a 15 percent decrease between 3-year means
of arsenic concentrations based on the data variation found in rural

locations of the Pilot Study	

Figure 3.7.1 Power curve for detecting a 15 percent decrease between 3-year means
of chromium concentrations based on the data variation found in

the Pilot Study	

Figure 3.8.1 Power curve for detecting a 15 percent decrease between 3-year means
of acrolein concentrations based on the data variation found in

the Pilot Study	

Figure 3.9.1 Power curve for detecting a 15 percent decrease between 3-year means
of formaldehyde concentrations based on the data variation found in urban

locations of the Pilot Study	

Figure 3.10.1 Power curve for detecting a 15 percent decrease between 3-year means
of formaldehyde concentrations based on the data variation found in rural
locations of the Pilot Study	

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10

11

12

13

14

15

16

17

18

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EXECUTIVE SUMMARY

The Data Quality Objective (DQO) process described in EPA's QA/G-4 document
provides a general framework for ensuring that the data collected by EPA meets the needs of
decision makers and data users. The process establishes the link between the specific end use(s)
of the data with the data collection process and the data quality (and quantity) needed to meet a
program's goals. This process was applied to one of the primary goals of the National Air
Toxics Monitoring Network, namely to establish trends and evaluate the effectiveness of HAP
reduction strategies. This report documents the results of the DQO process for the local
monitoring data requirements for: benzene, 1,3-butadiene, arsenic, chromium, acrolein, and
formaldehyde.

The technical approach used followed the conceptual model developed for the PM2.5
Federal Reference Method (FRM) DQOs, This conceptual model of simulating daily deviations
from a seasonal curve was followed mainly due to its success in use with PM^s and the
flexibility of the conceptual model. It is a quite general model for simulating the characterization
of ambient concentrations in terms of annual or multi-year averages from 1 in n day sampling.
The model incorporates several sources of variability: seasonal variability, natural day-to-day
variability, sampling incompleteness, and measurement error. The measurement error was
restricted to a precision component without a bias component, because the mathematical form of
the assessment of trends is robust to multiplicative bias. Pollutant specific parameters were used
in the modeling. The parameters describing the natural variation of the pollutants were based on
data analyses of the Pilot City data and EPA's Air Toxics Data Archive. Finally, separate urban
and rural DQOs were established for the pollutants that were sufficiently measured in rural
locations of the Pilot Study.

While there are pollutant specific requirements with respect to measurement detection
limits, the DQOs established all fall into the same framework. Each pollutant needs to be
measured on a schedule of at least once every six days with at least an 85 percent quarterly
completeness. The measurement precision needs to be controlled with a coefficient of variation
no more than 15 percent. Under these conditions, true decreasing trends of 30 percent or more
can be detected at least 90 percent of the time between successive three-year periods. Moreover,
the error rate for when there is no true change between successive three-year periods is
controlled to be at most 10 percent. Sampling frequency and natural or environmental
day-to-day variation are the primary factors affecting these error rates.

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1.0 INTRODUCTION

The Data Quality Objective (DQO) process described in EPA's QA/G-4 document
provides a general framework for ensuring that the data collected by EPA meets the needs of the
intended decision makers and data users. The process establishes the link between the specific
end use(s) of the data with the data collection process and the data quality (and quantity) needed
to meet a program's goals. This process was applied to one of the primary goals of the National
Air Toxics Monitoring Network, namely to establish trends and evaluate the effectiveness of
HAP reduction strategies. This report documents the results of the DQO process for the local
monitoring data requirements for: benzene, 1,3-butadiene, arsenic, chromium, acrolein, and
formaldehyde.

The technical approach used followed the conceptual model developed for the PM2.5
FRM DQOs. This conceptual model was followed mainly due to its success in use with PM2,s
and the flexibility of the conceptual model. It is a quite general model for simulating the
characterization of ambient concentrations in terms of annual or multi-year averages from
1 in n day sampling. The model incorporates several sources of variability: seasonal variability,
natural day-to-day variability, sampling incompleteness, and measurement error. The
measurement error was restricted to a precision component without a bias component because
the final mathematical form of the assessment of trends is robust to multiplicative bias. Pollutant
specific parameters were used in the modeling. The parameters describing the natural variation
of the pollutants were based on data analyses of the Pilot City data and the Air Toxics Archive.
Finally, separate urban and rural DQOs were established for the pollutants that were sufficiently
measured in rural locations of the Pilot Study.

A workgroup organized by EPA/QAQPS/EMAD provided representatives of data users,
decision makers, state and local parties, and monitoring and laboratory personnel. Battelle
provided technical statistical support throughout the process with examples and data analyses.
The workgroup guided the DQO development and made the decisions that were not driven by
data analyses in the DQO development during a series of conference calls. These decisions
included items such as establishing a specific mathematical form for measuring trends and
establishing limits 011 the sampling rate, Battelle and EPA also held a meeting in Research
Triangle Park, North Carolina, on June 17, 2002 to discuss the development details.

2.0 THE GENERAL DQO PROCESS

This section presents an overview of the seven steps in EPA's QA/G-4 DQO process as
applied to one of the primary goals of the National Air Toxics Monitoring Network, namely to
establish trends and evaluate the effectiveness of HAP reduction strategies (see
www.epa.gov/quality/qa_docs.html). The purpose of this section is to provide general discussion
on the specific issues that were used in developing the DQOs as they relate to the general DQO
process.

The DQO process is a seven-step process based on the scientific method to ensure that
the data collected by EPA meet the needs of its data users and decision makers in terms of the

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information to be collected, in particular the desired quality and quantity of data. It also provides
a framework for checking and evaluating the program goals to make sure they are feasible and
that the data are collected efficiently. The seven steps are usually labeled as:

State the Problem

Identify the Decision

Identify the Inputs to the Decision

Define the Study Boundaries

Develop a Decision Rule

Specify Tolerable Limits on the Decision Errors

Optimize the Design.

This section has general discussion for each of these items. The pollutant specific outcomes of
the DQO process are contained in Section 3.

2.1 State the Problem

Characterize the ambient concentrations in the region represented by the monitor to
establish any significant downward trend (measured by a percent, change between
successive 3-year means of the concentrations).

The ability to characterize the trends was statistically modeled. The statistical model was
designed by starting with a model similar to the one used for PM2.5 FRM data. The ambient
concentrations are modeled as deviations from a sine curve, where the sine curve represents
seasonality. This sine curve represents long-term daily averages of the concentrations that one
would observe at the site. The form used is as follows:

A 1 +

r — 11 I dm

—7 sin 7772 n

r +1 \365

where

A = the long term annual average and

r = the ratio of the highest point on the sine curve to the lowest point. A value of
r = 1 indicates no seasonality.)

The natural deviations from the sine curve are assumed to follow a lognormal distribution
with a mean that is given by the particular point on the sine curve. (For example, the value of the

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sine curve for Day 100 is the mean for all Day 100s across many years.) The coefficient of
variation (CV) of the lognormal distribution is assumed to be a constant. The general model
considered also allows for the day-to-day deviations from the sine curve to be correlated, but the
current DQOs are based on a correlation of zero. (The correlation effectively measures how
quickly the concentrations can change from one deviation from the sine curve to another. A
correlation of zero indicates that it can change fast enough that values measured oil consecutive
days would be completely independent. A value of 0.2 would say that a positive deviation from
the curve is somewhat more likely to be followed by another positive deviation than a negative
deviation. A value of 0.9 would indicate that positive deviations are almost always followed by
another positive deviation.) Finally, the measured values are modeled with a normally
distributed random measurement error with a constant coefficient of variation (CV). The
specific values for the various parameters are pollutant specific.

The population parameters (the degree of seasonality, the autocorrelation, and the CV of
the deviations from the sine curve) were estimated from the Pilot City data (and in the case of
benzene compared with estimates from the Air Toxics Data Archive). (See Appendix A.) A
near worst-case choice was made for each of the parameters. The power curves and decision
errors are established via Monte-Carlo simulation of the model with the particular parameters for
various combinations of truth and observed percent changes in three-year mean concentrations.
The power curves are plotted as functions of the true percent change in the three-year annual
means for compound specific combinations of the sampling frequency, completeness, and
precision. Decision errors are stated for these worst-case scenarios.

Note: It was decided by the workgroup from budgetary considerations that the proposed
DQOs should be constrained to no more than one in six day sampling.

2.2	Identify the Decision

The decision statement should provide a link between the principal study question and
possible actions. The potential actions associated with achieving or failing to achieve a
particular percent decrease in the observed three-year mean concentration were not defined by
the workgroup. However, it was decided that any decision would be based on whether or not a
15 percent decrease was observed. Hence the form of the decision was fixed, and may be
specified as follows;

Significant decreases (15 percent or more) between successive three-year mean

concentration levels will result in ... Insignificant decreases, (increases, or decreases of

less than 15 percent) will trigger alternate actions of.

2.3	Identify the Inputs to the Decision

Only six HAPs (benzene, 1,3-butadiene, arsenic, chromium, acrolein, and formaldehyde)
were considered in the DQO development. It is assumed that the other pollutants will be
represented by at least one of these six. The statements included here apply implicitly to the
other HAPs.

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It is assumed that the analytical techniques used in the Pilot study will be used throughout
the program. Most importantly for the DQOs the Method Detection Limits (MDLs) will not
increase. The pollutant specific MDLs assumed are listed in Section 3. Those values were
identified as pollutant-site maximums that were achieved by at least two of the pilot sites in each
pollutant's case.

Among the key decisions made as a part of the DQO process was that each pollutant will
need to be measured on a schedule of at least once every six days with a quarterly completeness
of 85 percent for six consecutive years. The completeness criterion was checked against the pilot
data, and was generally achieved. All valid measurements count toward the completeness goal,
including non-detects. The analysis of the trends at the site level will be based on a percent
difference between the mean of the first three annual concentrations and the mean of the last
three annual concentrations. Hence for each year the annual average concentration, Xi, needs to
be found, i = 1,2, ... 6. Next find the mean, X, for the first three years and the mean, Y, for
years 4 through 6 as follows:

v X!+X2 + X, xt+xs+x6

X = —i	±	i and Y = —	2	

3	3

Then the downward trend, T, is the percent decrease from the first three-year period to the
second three-year period. Namely,

X —¦ Y

r	ion.

x

The Action Level is the cutoff point that separates different decision alternatives. Based
on the assumed budgetary constraint of one in six day sampling and the natural variation
exhibited by the six compounds considered, an action level of 15 percent was chosen. Hence at
least a 15 percent decrease between the two distinct three-year mean concentrations will need to
be observed in order to be considered a significant decrease. This assumes that the mean
concentrations are above the health standards, and hence it makes sense to consider trends.

(Note that characterizing the mean concentrations is a separate goal of the Air Toxics program
that has not yet been considered and could result in different DQOs.)

2.4	Define the Study Boundaries

It is desired that the specific location of the monitors be constrained so that they represent
neighborhood scale assessment for each of the two three-year periods under consideration. The
details of how to ensure this goal have not yet been determined. Some guideline is provided by
the Air Toxics Monitoring Concept Paper (see http://www.epa.gov/ttn/antic/airtxfil.html).

2.5	Develop a Decision Rule

The decision rule is an "if... then" statement for how the various alternatives will be
chosen. As noted above the specific alternative actions have not been formalized yet, just the
form of the decision rule.

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If the percent change between successive three-year average concentration levels
is greater than or equal to 15percent, then ...Otherwise ...

2.6 Specify Tolerable Limits on the Decision Errors

Since the program will not generate complete, error-free data, there will be some
probability of making a decision error. The main goal of the DQO process is to find a workable
balance between how complete and error free the data are with acceptable levels of decision
errors. To find the balance, the possible errors need to be carefully defined. This usually needs
to be done with the recognition that there will be a range, often called the gray zone, where it is
impractical to control decision errors.

The QA/G-4 guidance recommends using 0.01 as the starting point for setting decision
error rates. However, such a limit would generally require a sampling rate that is not feasible.
The workgroup decided on the following limits:

If there is no true decrease in the three-year average concentrations, then the
probability of observing a mean concentration for years four through six that is at
least 15 percent below the observed mean concentration from years one through
three should be no more than 10 percent.

If there is a true decrease in the three-year average concentrations of at least 30
percent, then the probability of observing a mean concentration for years four
through six that is less than 15 percent, below the observed mean concentration
from years one through three should be no more than 10percent.

Equivalently, the second statement could read that:

If there is a true decrease in the three-year average concentrations of at least 30
percent, then the probability of observing a mean concentration for years four
through six that is at least 15 percent below the observed mean concentration
from, years one through three should be at least 90 percent.

The power curves shown in Section 3 show the probability of observing at least a
15 percent decrease as a function of the true decrease. In terns of the above goals this
means that the power curve graphs should start below 10 percent for a true percent
change of 0 and end above 90 percent for a true percent change of 30 percent. Since
there is a particular interest in the error rates for no true change and for a true change of a
30 percent decrease, this associated x-axis (horizontal axis) range is shown for each
curve. Also, it is sometimes useful to know when the two target error rates are achieved.
The range of "truth" between these values is referred to as the gray zone, i.e., the range of
true percent decreases that cannot be reliably detected by the sampling scheme. These
are also given for each curve (and indicated with vertical dotted lines).

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2.7 Optimize the Design

In each pollutant's case, a sampling schedule of once every six days is set forth with a
quarterly completeness criteria of 85 percent. Pilot City study participants were surveyed and
almost all were collecting and obtaining valid data values at a rate that exceeded 85 percent for
each of the six compounds considered (valid non-detects counted toward completeness). Hence,
the target rate of 85 percent was selected, instead of the more common 75 percent completeness
goal. This should make the power curves more representative of the network's expected
monitoring conditions.

3.0 DQOS FOR THE SIX STUDY COMPOUNDS

This section states the design values, namely it gives the expected maximum error rates,
gray zones, and power curves for each of the six compounds considered explicitly. The
parameters describing the natural state of the ambient conditions used to construct the power
curves, error rates and gray zone are compound specific based on data from the Pilot Study. (See
Appendix A.) In each case, the Pilot City data yielded a range of estimates. The specific values
used were the extremes (or nearly so) that would make detecting a downward trend more
difficult. Actual performance in almost all cases should be better than that indicated by the
power curves, since specific sites would not be characterized by these extremes in each of these
parameters. However, since the sensitivity to the different parameters is not the same, the DQOs
need to protect against a combined set of extremes. Hence, the use of extremes for network
design purposes is conservative.

Since the rural sites can be quite different from urban sites, separate DQOs are shown in
those cases where there were sufficient data to support investigating a separate set of DQOs. In
the case of formaldehyde, the urban and rural DQOs are essentially the same.

There are twelve input parameters shown in each section. They are:

1.	Tl. This is the target error rate for when there is no change. It is always 10 percent.

2.	T2. This is the target error rate for when there is a 30 percent decrease. It is always
10 percent.

3.	The action limit. This is the minimum observed percent change from the mean
concentration of the first three years to the mean concentration from the last three
years that would be used to indicate that the concentrations have decreased.

Decreases less than this amount would not be considered significant decreases in the
mean concentration.

4.	The sampling rate. It is set to one in six day sampling in each case.

5.	The quarterly completeness criterion. This was set to 85 percent based on the
recommendation of ERG and a review of the Pilot Study data completeness.

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6.	Measurement error Coefficient of Variation li'Vi. This was assumed to be

15 percent for each compound, (A sensitivity analysis showed that the DQOs are
robust to moderate changes in this value.)

7.	Seasonality ratio. This is a measure of the degree of seasonality. Specifically, it is
the ratio of the highest point on the seasonal curve to the lowest point. A value of 1
indicates no seasonality. Larger values make it more difficult to estimate an annual
or three-year mean concentration, and hence larger values make it more difficult to
measure the percent change.

8.	Autocorrelation. This is a measurement of how quickly day-to-day deviation from
the seasonal curve can occur. A value of 0 indicates that changes occur quickly
enough that each day is independent of the preceding day. Values greater than 0
indicate that the changes are generally slower, so that days with concentrations above
the seasonal curve are more likely to be followed by another day above the seasonal
curve. Values greater than 0 increase the precision of the three-year means and the
percent change between the three-year means. Hence, a value of 0 is the most
conservative choice for the DQOs. Zero was used in all cases, because many daily
measurements are required to obtain a reliable estimate of this parameter.

9.	Population CV. This is a measurement of the natural variation about the seasonal
curve. Larger values decrease the precision of the three-year mean concentration
estimates and the percent change between them. The power curves are strongly
dependent on this parameter, but the estimates can be strongly influenced by a few
outlier values. Generally the 90th percentile of the estimates from the Pilot study was
used as a balance between these competing forces. This value was then rounded up
to be a multiple of 5 percent for the urban DQOs. For the rural DQOs an additional
5 percent was added, since there were fewer rural sites on which to base the
estimates.

10.	MDL. This is the MDL used in the simulations. The value was chosen to be a
reasonably attainable maximum for a site and compound.

11.	Initial mean concentration. This is the mean concentration of the first three years in
the simulations. Values closer to the MDL decrease the precision of the percent
change estimate. The value chosen was approximately equal to the 25th percentile of
the site-compound means from the Pilot study.

12.	Health Risk Standard. This value is shown for reference only. It was not used in the
simulations.

In addition to the power curves, there are three sets of output values.

1, Erroro is the percent of the simulations with no change in the true three-year means
that in fact generated at least a 15 percent decrease in the observed three-year means.

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2.	Errorso is the percent of the simulations with a 30 percent decrease in the true three-
year means that generated less than a 15 percent decrease in the observed three-year
means.

3,	The gray zone is the interval of the true decreases that cannot be detected with
confidence by the study design. In this range, the probability of observing at least a
15 percent decrease is greater than 10 percent, but less than 90 percent.

In summary, based on variability and uncertainty estimates from the ten-city Pilot Study,
the following Sections 3.1 through 3.10 suggest that the specified air toxics trends DQOs will be
met for monitoring sites that satisfy the goals of 1 in 6 day sampling, 85 percent completeness,
and 15 percent measurement CV. These results were explicitly developed for benzene (urban
and rural); 1,3-butadiene (urban and rural); arsenic (urban and rural); chromium (urban only);
acrolein (urban only); and formaldehyde (urban and rural).

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3.1 DQOs for Measuring the Percent Decrease of Benzene at Urban Locations

Table 3.1.1 shows the input parameters used in the simulation model in developing the
DQOs for measuring the percent decrease between three-year mean concentrations of benzene at
urban locations. Table 3.1.2 shows the output values from the simulations. Figure 3.1.1 shows
the associated power curve, which is the probability of observing a 15 percent difference
between successive three-year means as a function of the true percent difference in the distinct
three-year means. In summary, based on variability and uncertainty estimates from the ten-city
Pilot Study data, Table 3.1.2 suggests that the specified air toxics trends DQOs will be met for
benzene at urban monitoring sites that satisfy the goals of one in six-day sampling, 85 percent
completeness, and 15 percent measurement CV. (See section 3.0 for definitions of the input
parameters and output values.)

Table 3.1.1 DQO input parameters for benzene at urban locations

T1

Action Limit

Sampling Rate

Seasonality

Population CV

Initial

Concentration (j.g/m3)

10%

15%

1 in 6 day

4.5

85%

1.0

T2

Measurement CV

Completeness

Autocorrelation

MDL (|ig/mJ)

Risk Standard (iig/mJ)

10%

15%

05%

0

0.044

0.128

Table 3.1.2 DQO output parameters for benzene at urban locations

Error rate for no true change

Error rate for 30% decrease

Gray zone

6%

97%

3% - 26%

Figure 3.1.1 Power curve for detecting a 15 percent decrease between successive

three-year means of benzene concentrations based on the data variation
found in urban locations of the Pilot Study

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3.2 DQOs for Measuring the Percent Decrease of Benzene at Rural Locations

Table 3.2.1 shows the input parameters used in the simulation model in developing the
DQOs for measuring the percent decrease between three-year mean concentrations of benzene at
rural locations. Table 3.2.2 shows the output values from the simulations. Figure 3.2.1 shows
the associated power curve, which is the probability of observing a 15 percent difference
between successive three-year means as a function of the true percent difference in the distinct
three-year means. In summary, based on variability and uncertainty estimates from the ten-city
Pilot Study data, Table 3.2.2 suggests that the specified air toxics trends DQOs will be met for
benzene at rural monitoring sites that satisfy the goals of one in six-day sampling, 85 percent
completeness, and 15 percent measurement CV. (See section 3.0 for definitions of the input
parameters and output values.)

Table 3.2.1 DQO input parameters for benzene at rural locations

T1

Action Limit

Sampling Rate

Seasonality

Population CV

Initial

Concentration (j.g/m3)

10%

15%

1 in 6 day

4.0

60%

1.0

T2

Measurement CV

Completeness

Autocorrelation

MDL (|ig/mJ)

Risk Standard (iig/mJ)

10%

15%

05%

0

0.044

0.128

Table 3.2.2 DQO output parameters for benzene at rural locations

Error rate for no true change

Error rate for 30% decrease

Gray zone

2%

99%

7% - 23%

Figure 3.2.1 Power curve for detecting a 15 percent decrease between successive

three-year means of benzene concentrations based on the data variation
found in rural locations of the Pilot Study

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3.3 DQOs for Measuring the Percent Decrease of 1,3-Butadiene at Urban
Locations

Table 3.3.1 shows the input parameters used in the simulation model in developing the
DQOs for measuring the percent decrease between three-year mean concentrations of 1,3-
butadiene at urban locations. Table 3.3.2 shows the output values from the simulations. Figure
3.3.1 shows the associated power curve, which is the probability of observing a 15 percent
difference between successive three-year means as a function of the true percent difference in the
distinct three-year means. In summary, based on variability and uncertainty estimates from the
ten-city Pilot Study data, Table 3.3.2 suggests that the specified air toxics trends DQOs will be
met for 1,3-butadiene at urban monitoring sites that satisfy the goals of one in six-day sampling,
85 percent completeness, and 15 percent measurement CV. (See section 3.0 for definitions of
the input parameters and output values.)

Table 3.3.1 DQO input parameters for 1,3-butadiene at urban locations

T1

Action Limit

Sampling Rate

Seasonality

Population CV

Initial

Concentration (t.q/m1)

10%

15%

1 in 6 day

7.0

100%

0.1

T2

Measurement CV

Completeness

Autocorrelation

MDL Lqm')

Risk Standard (uq/mJ)

10%

15%

85%

0

0 02

10°

Table 3.3.2 DQO output parameters for 1,3-butadiene at urban locations

Error rate for no true change

Error rate for 30% decrease

Gray zone

10%

94%

0% - 2B%

Figure 3.3.1 Power curve for detecting a 15 percent decrease between successive
three-year means of 1,3-butadiene concentrations based on the data
variation found in urban locations of the Pilot Study

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3.4 DQOs for Measuring the Percent Decrease of 1,3-butadiene at Rural
Locations

Table 3.4.1 shows the input parameters used in the simulation model in developing the
DQOs for measuring the percent decrease between three-year mean concentrations of 1,3-
butadiene at rural locations. Table 3.4.2 shows the output values from the simulations. Figure
3.4.1 shows the associated power curve, which is the probability of observing a 15 percent
difference between successive three-year means as a function of the true percent difference in the
distinct three-year means. In summary, based on variability and uncertainty estimates from the
ten-city Pilot Study data, Table 3.4.2 suggests that the specified air toxics trends DQOs will be
met for 1,3-butadiene at rural monitoring sites that satisfy the goals of one in six-day sampling,
85 percent completeness, and 15 percent measurement CV. (See section 3.0 for definitions of
the input parameters and output values.)

Table 3.4.1 DQO input parameters for 1,3-butadiene at rural locations

T1

Action Limit

Sampling Rate

Seasonality

Population CV

Initial

Concentration (t.q/m1)

10%

15%

1 in 6 day

6.0

75%

0.1

T2

Measurement CV

Completeness

Autocorrelation

MDL Lqm')

Risk Standard (uq/mJ)

10%

15%

85%

0

0 02

10°

Table 3.4.2 DQO output parameters for 1,3-butadiene at rural locations

Error rate for no true change

Error rate for 30% decrease

Gray zone

4%

98%

4% - 25%

Figure 3.4.1 Power curve for detecting a 15 percent decrease between successive
three-year means of 1,3-butadiene concentrations based on the data
variation found in rural locations of the Pilot Study

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Appendix A

3.5 DQOs for Measuring the Percent Decrease of Arsenic at Urban Locations

Table 3.5.1 shows the input parameters used in the si.mulati.cn model in developing the
DQOs for measuring the percent decrease between three-year mean concentrations of arsenic at
urban locations. Table 3.5.2 shows the output values from the simulations. Figure 3.5.1 shows
the associated power curve, which is the probability of observing a 15 percent difference
between successive three-year means as a function of the true percent difference in the distinct
three-year means. In summary, based on variability and uncertainty estimates from the ten-city
Pilot Study data, Table 3.5.2 suggests that the specified air toxics trends DQOs will be met for
arsenic at urban monitoring sites that satisfy the goals of one in six-day sampling, 85 percent
completeness, and 15 percent measurement CV. (See section 3.0 for definitions of the input
parameters and output values.)

Table 3.5.1 DQO input parameters for arsenic at urban locations

T1

Action Limit

Sampling Rate

Seasonality

Population CV

Initial

Concentration (j.g/m3)

10%

15%

1 in 6 day

5.0

85%

0.002

T2

Measurement CV

Completeness

Autocorrelation

MDL (|ig/mJ)

Risk Standard (iig/mJ)

10%

15%

05%

0

0.000046

0.0043

Table 3.5.2 DQO output parameters for arsenic at urban locations

Error rate for no true change

Error rate for 30% decrease

Gray zone

8%

95%

2% - 27%

True percent difference

Figure 3.5.1 Power curve for detecting a 15 percent decrease between successive
three-year means of arsenic concentrations based on the data variation
found in urban locations of the Pilot Study

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Appendix A

3.6 DQOs for Measuring the Percent Decrease of Arsenic at Rural Locations

Table 3.6.1 shows the input parameters used in the si.mulati.cn model in developing the
DQOs for measuring the percent decrease between three-year mean concentrations of arsenic at
rural locations. Table 3.6.2 shows the output values from the simulations. Figure 3.6.1 shows
the associated power curve, which is the probability of observing a 15 percent difference
between successive three-year means as a function of the true percent difference in the distinct
three-year means. In summary, based on variability and uncertainty estimates from the ten-city
Pilot Study data, Table 3.6.2 suggests that the specified air toxics trends DQOs will be met for
arsenic at rural monitoring sites that satisfy the goals of one in six-day sampling, 85 percent
completeness, and 15 percent measurement CV. (See section 3.0 for definitions of the input
parameters and output values.)

Table 3.6.1 DQO input parameters for arsenic at rural locations

T1

Action Limit

Sampling Rate

Seasonality

Population CV

Initial

Concentration (j.g/m3)

10%

15%

1 in 6 day

4.0

65%

0.001

T2

Measurement CV

Completeness

Autocorrelation

MDL (|ig/mJ)

Risk Standard (iig/mJ)

10%

15%

05%

0

0.000046

0.0043

Table 3.6.2 DQO output parameters for arsenic at rural locations

Error rate for no true change

Error rate for 30% decrease

Gray zone

3%

99%

5% - 24%

True percent difference

Figure 3.6.1 Power curve for detecting a 15 percent decrease between successive
three-year means of arsenic concentrations based on the data variation
found in rural locations of the Pilot Study

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Appendix A

3.7 DQOs for Measuring the Percent Decrease of Chromium

Table 3.7.1 shows the input parameters used in the simulation model in developing the
DQOs for measuring the percent decrease between three-year mean concentrations of chromium.
Table 3.7.2 shows the output values from the simulations. Figure 3.7.1 shows the associated
power curve, which is the probability of observing a 15 percent difference between successive
three-year means as a function of the true percent difference in the distinct three-year means. In
summary, based on variability and uncertainty estimates from the ten-city Pilot Study data, Table
3.7.2 suggests that the specified air toxics trends DQOs will be met for chromium at monitoring
sites that satisfy the goals of one in six-day sampling, 85 percent completeness, and 15 percent
measurement CV. (See section 3.0 for definitions of the input parameters and output values.)

Table 3.7.1 DQO input parameters for chromium

T1

Action Limit

Sampling Rate

Seasonality

Population CV

Initial

Concentration (jiq/m3)

10%

15%

1 in 6 day

5.0

90%

0.0015

T2

Measurement CV

Completeness

Autocorrelation

MDL (nq/m3)

Risk Standard (ng/m1)

10%

15%

85%

0

0 00018

0.012

Table 3.7.2 DQO output parameters for chromium

Error rate for no true change

Error rate for 30% decrease

Gray zone

7%

96%

2% - 27%

Figure 3.7.1 Power curve for detecting a 15 percent decrease between successive

three-year means of chromium concentrations based on the data variation
found in of the Pilot Study

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Appendix A

3.S DGOs for Measuring the Percent Decrease of Acrolein

Table 3,8,1 shows the input parameters used in the simulation model in developing the
DQOs for measuring the percent decrease between three-year mean concentrations of acrolein.
Table 3,8,2 shows the output values from the simulations. Figure 3.8,1 shows the associated
power curve, which is the probability of observing a 15 percent difference between successive
three-year means as a function of the true percent difference in the distinct three-year means. In
summary, based on variability and uncertainty estimates from the ten-city Pilot Study data, Table
3,8,2 suggests that the specified air toxics trends DQOs will be met for acrolein at monitoring
sites that satisfy the goals of one in six-day sampling, 85 percent completeness, and 15 percent
measurement C V, (See section 3,0 for definitions of the input parameters and output values.)

Table 3.8.1 DQO input parameters for acrolein

T1

Action Limit

Sampling Rate

Seasonality

Population CV

Initial

Concentration (nq/m5)

10%

15%

1 in 6 d&v

4.0

105%

0.4

T2

Measurement CV

Completeness

Autocorrelation

MDL (up/ml

Risk Standard (np/m5)

10%

15%

85%

0

0.14

-

Table 3.8.2 DQO output parameters for acrolein

Error rate for no true change

Error rate for 30% decrease

Gray zone

10%

91%

0% - 2S%

True percent difference

Figure 3.8.1 Power curve for detecting a 15 percent decrease between successive

three-year means of acrolein concentrations based on the data variation
found in the Pilot Study

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Appendix A

3.9 DQOs for Measuring the Percent Decrease of Formaldehyde at Urban
Locations

Table 3.9.1 shows the input parameters used in the simulation model in developing the
DQOs for measuring the percent decrease between three-year mean concentrations of
formaldehyde at urban locations. Table 3.9.2 shows the output values from the simulations.
Figure 3.9.1 shows the associated power curve, which is the probability of observing a
15 percent difference between successive three-year means as a function of the true percent
difference in the distinct three-year means. In summary, based on variability and uncertainty
estimates from the ten-city Pilot Study data, Table 3.9.2 suggests that the specified air toxics
trends DQOs will be met for formaldehyde at urban monitoring sites that satisfy the goals of one
in six-day sampling, 85 percent completeness, and 15 percent measurement CV. (See
Section 3.0 for definitions of the input parameters and output values.)

Table 3.9.1 DQO input parameters for formaldehyde at urban locations

T1

Action Limit

Sampling Rate

Seasonality

Population CV

Initial

Concentration (t.q/m1)

10%

15%

1 in 6 day

7.0

90%

2.5

T2

Measurement CV

Completeness

Autocorrelation

MDL (uq/mJ)

Risk Standard (uq/mJ)

10%

15%

85%

0

0.014

1.3 10a

Table 3.9.2 DQO output parameters for formaldehyde at urban locations

Error rate for no true change

Error rate for 30% decrease

Gray zone

8%

95%

2% - 27%

Figure 3.9.1 Power curve for detecting a 15 percent decrease between successive
three-year means of formaldehyde concentrations based on the data
variation found in urban locations of the Pilot Study

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Appendix A

3.10 DQOs for Measuring the Percent Decrease of Formaldehyde at Rural
Locations

Table 3.10.1 shows the input parameters used in the simulation model in developing the
DQOs for measuring the percent decrease between three-year mean concentrations of
formaldehyde at rural locations. Table 3.10.2 shows the output values from the simulations.
Figure 3.10.1 shows the associated power curve, which is the probability of observing a
15 percent difference between successive three-year means as a function of the true percent
difference in the distinct three-year means. In summary, based on variability and uncertainty
estimates from the ten-city Pilot Study data, Table 3.10.2 suggests that the specified air toxics
trends DQOs will be met for formaldehyde at rural monitoring sites that satisfy the goals of one
in six-day sampling, 85 percent completeness, and 15 percent measurement CV. (See
Section 3.0 for definitions of the input parameters and output values.)

Table 3.10.1 DQO input parameters for formaldehyde at rural locations

T1

Action Limit

Sampling Rate

Seasonality

Population CV

Initial

Concentration (uq/m3)

10%

15%

1 in 6 day

7.0

90%

2.1

T2

Measurement CV

Completeness

Autocorrelation

MDL (uq/m'')

Risk Standard (uq/mJ)

10%

15%

85%

0

0.014

1.3 10a

Table 3.10.2 DQO output parameters for formaldehyde at rural locations

Error rate for no true change

Error rate for 30% decrease

Gray zone

8%

95%

1%- 27%

Figure 3.10.1 Power curve for detecting a 15 percent decrease between successive
three-year means of formaldehyde concentrations based on the data
variation found in rural locations of the Pilot Study

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Appendix A

APPENDIX A:

ESTIMATES OF THE DQO PARAMETERS MEASURING
ENVIRONMENTAL VARIABILITY

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Appendix A

Appendix A: Estimates of the DQO Parameters Measuring Environmental

Variability

The DQO parameters that measure the natural environmental variability of a pollutant are
generally uncontrollable parameters that have a strong effect on the decision errors. The
simulation model described in Section 2.1 uses these parameters. This appendix describes both
the parameters and the method for estimating the parameters from the Pilot data. The basic
simulation model is that the true concentration levels vary about a sinusoidal curve with one full
oscillation in each year. Four parameters describe characteristics of the sine curve and the
natural deviations from the sine curve.

Seasonality Ratio

The ratio parameter is a measure of the degree of seasonality in the data. It is the ratio of
the high point to the low point on the sine curve. The model assumes that the amplitude of the
sine curve is proportional to the mean. The parameter was estimated by finding the monthly
averages and taking the ratio of the highest average to the lowest average. The site estimates are
restricted to those sites that had at least 3 measurements in each of at least six months.

Population CV

This parameter measures the amount of random, day-to-day variation of the true
concentration about the sine curve. This parameter was estimated as follows. Starting with
every 6th day measurements (deleting if needed), the natural log of each measurement was found.
Next, a new sequence of numbers was created equal to the differences of successive pairs in the
sequence of the log-concentrations that were from measurements taken six days apart. Finally,
terms were removed from this sequence so that each term in the remaining sequence was based
on distinct numbers. Let S be the standard deviation of this set of numbers. The estimate for the

population CV is ^ (o\p(\ 2 ) l ). The site estimates are restricted to those with at least ten
terms being used in the estimates.

Autocorrelation

The final parameter describing the natural variation of the true concentrations is
autocorrelation. This is a measurement of the similarity between successive days. Consider two
sets of measurements. First, suppose you had measured the concentrations on every July 15th for
the p ast five years. You would expect those five values to be rather spread out. The
population CV should capture how different these measurements are from each other. On the
other hand, suppose instead you measure the concentrations each day from July 15, 2002, to July
20, 2002. These values may not be as spread out as the other set, simply because they are nearer
in time to each other. Autocorrelation measures this effect. A good way to think of
autocorrelation is it measures how quickly the local concentrations can change. The value of the
autocorrelation ranges between 0 and 1. A value of 0 means that the local concentrations can
change very rapidly from day-to-day. A value of 1 means that the local concentrations are
constant.

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Appendix A

Estimating autocorrelation is more difficult than estimating the population C V, Unless a
site had daily measurements, a value of 0 was used. Realistically, 0 is the most conservative case
and can always be used. Assuming a site had daily measurements, let S6 be the standard
deviation computed as in the section on population CV, based on differences of the logs from
every 6th day measurements. Let SI be the same thing using differences of logs from daily
measurements. If S6 > 51, then the autocorrelation was estimated with (s62 - SI1)/S61. This
method adjusts for seasonality, but still tends to slightly over estimate the truth. There were too
few sites with .sufficient daily measurements to obtain distributions of the pollutant
autocorrelations, so a value of 0 was used for all pollutants.

Initial concentration.

This is simply the mean concentration for the site.

Table A-l gives the pollutant and site estimates for the seasonality ratio and the initial
mean concentrations. Table A-2 gives the pollutant and site population CV estimates.

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Appendix A

Table A-1. Estimates of the seasonality ratio and initial mean by pollutant and site

Pollutant

Site ID

Urban / Rural

Mean
(ng/m3)

Seasonality Ratio

1,3-BUTADIENE

2616300051

Urban

0.3190

3.60

1,3-BUTADIENE

4400700261

Urban

0.2600

3.15

1,3-BUTADIENE

2616300331

Urban

0.2067

2.65

1,3-BUTADIENE

2616300271

Urban

0.2032

2.03

1,3-BUTADIENE

2612500101

Urban

0.2027

1.36

1,3-BUTADIENE

4400700221

Urban

0.1789

5.86

1,3-BUTADIENE

1210300181

Urban

0.1732

4.41

1,3-BUTADIENE

4400700251

Urban

0.1431

4.07

1,3-BUTADIENE

1205710751

Urban

0.1382

5.43

1,3-BUTADIENE

1210310081

Urban

0.1272

3.31

1,3-BUTADIENE

5303300321

Urban

0.1250

6.51

1,3-BUTADIENE

1210350021

Urban

0.1164

2.50

1,3-BUTADIENE

5303300801

Urban

0.1148

5.76

1,3-BUTADIENE

5303300241

Urban

0.1141

7.10

1,3-BUTADIENE

4400700241

Urban

0,1041

4.64

1,3-BUTADIENE

4400710101

Urban

0.1019

5.35

1,3-BUTADIENE

5303300201

Urban

0.1010

10.03

1,3-BUTADIENE

5303300101

Urban

0.0916

10.39

1,3-BUTADIENE

5303300381

Urban

0.0809

5.51

1,3-BUTADIENE

4400300021

Urban

0.0358

5.38

1,3-BUTADIENE

0807700131

Rural

0.2192

6.00

1,3-BUTADIENE

0807700161

Rural

0.1810

4.06

1,3-BUTADIENE

1311300391

Rural

0.1182

3.23

1,3-BUTADIENE

1311300371

Rural

0.0886

1.22

ACROLEIN

4400700261

Urban

0.5904

2.04

ACROLEIN

4400700221

Urban

0.5866

3.36

ACROLEIN

4400700241

Urban

0.5366

2.36

ACROLEIN

4400700251

Urban

0.5366

2.18

ACROLEIN

4400710101

Urban

0.3637

3.34

ACROLEIN

4400300021

Urban

0.3509

3.69

ARSENIC TSP

1205710751

Urban

0.0038

5.01

ARSENIC TSP

2616300271

Urban

0.0033

2.06

ARSENIC TSP

2616300331

Urban

0.0028

3.13

ARSENIC TSP

1210350021

Urban

0.0027

2.94

ARSENIC TSP

1205700811

Urban

0.0027

1.59

ARSENIC TSP

1205710651

Urban

0.0026

1.40

ARSENIC TSP

2616300151

Urban

0.0024

2.68

ARSENIC TSP

1210300181

Urban

0.0024

2.41

ARSENIC TSP

2616300051

Urban

0.0023

2.82

ARSENIC TSP

1210310081

Urban

0.0022

1.56

ARSENIC TSP

2616300011

Urban

0.0021

4.50

ARSENIC TSP

2616300191

Urban

0.0019

2.97

ARSENIC TSP

5303300241

Urban

0.0015

4.48

ARSENIC TSP

2612500101

Urban

0,0014

14.99

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Appendix A

Table A-1. Estimates of the seasonality ratio and initial mean by pollutant and site (Cont'd.)

Pollutant

Site ID

Urban / Rural

Mean
|xg/m3)

Seasonality Ratio

ARSENIC TSP

5303300201

Urban

0.0010

3.80

ARSENIC TSP

5303300381

Urban

0.0009

3.13

ARSENIC TSP

5303300101

Urban

0.0008

4.94

ARSENIC TSP

0807700161

Rural

0.0016

2.11

ARSENIC TSP

0807700131

Rural

0.0008

3.54

BENZENE

2616300271

Urban

18.8411

12.42

BENZENE

2616300051

Urban

2.2038

1.92

BENZENE

2612500101

Urban

2.0860

1.59

BENZENE

2616300331

Urban

2.0710

1.55

BENZENE

5303300321

Urban

1.7124

3.97

BENZENE

5303300241

Urban

1.6500

2.76

BENZENE

4400700261

Urban

1.4416

2.43

BENZENE

1210300181

Urban

1.2763

3.09

BENZENE

4400700221

Urban

1.2648

3.49

BENZENE

5303300801

Urban

1.1697

1.71

BENZENE

5303300101

Urban

1.1466

2.08

BENZENE

5303300381

Urban

1.1161

2.30

BENZENE

4400700251

Urban

1.1123

3.30

BENZENE

1205710751

Urban

1.0364

2.98

BENZENE

5303300201

Urban

1.0229

2.03

BENZENE

1210310081

Urban

0.9283

2.62

BENZENE

1210350021

Urban

0.8940

1.94

BENZENE

4400700241

Urban

0.8849

3.06

BENZENE

1205710651

Urban

0.8791

2.47

BENZENE

4400710101

Urban

0.8006

4.15

BENZENE

1205700811

Urban

0.6451

2.37

BENZENE

4400300021

Urban

0.4190

5.05

BENZENE

0807700131

Rural

2.7088

2.36

BENZENE

0807700161

Rural

1.8649

3.16

BENZENE

1311300391

Rural

1.1701

2.68

BENZENE

0606530111

Rural

1.0166

3.10

BENZENE

1311300371

Rural

0.9221

1.66

BENZENE

0606530121

Rural

0.7622

2.71

CHROMIUM TSP

2616300271

Urban

0.0075

1.70

CHROMIUM TSP

2616300331

Urban

0.0061

1.68

CHROMIUM TSP

2616300151

Urban

0.0059

2.09

CHROMIUM TSP

2616300051

Urban

0.0049

1.90

CHROMIUM TSP

2616300011

Urban

0.0036

2.31

CHROMIUM TSP

2612500101

Urban

0.0034

1.79

CHROMIUM TSP

2616300191

Urban

0.0031

2.45

CHROMIUM TSP

1205710651

Urban

0.0019

1.62

CHROMIUM TSP

1210350021

Urban

0.0017

3.68

CHROMIUM TSP

5303300201

Urban

0.0017

6.25

CHROMIUM TSP

1210300181

Urban

0.0016

2.51

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Appendix A

Table A-1. Estimates of the seasonality ratio and initial mean by pollutant and site (Cont'd.)

Pollutant

Site ID

Urban / Rural

Mean
(jig/m3)

Seasonality Ratio

CHROMIUM TSP

1205700811

Urban

0.0014

1.87

CHROMIUM TSP

1210310081

Urban

0.0014

2.99

CHROMIUM TSP

1205710751

Urban

0.0014

1.88

CHROMIUM TSP

5303300241

Urban

0,0011

4.23

CHROMIUM TSP

5303300381

Urban

0.0009

3.02

CHROMIUM TSP

5303300101

Urban

0.0009

3.17

FORMALDEHYDE

2616300331

Urban

7.2980

70.55

FORMALDEHYDE

1210300181

Urban

4.1605

2.36

FORMALDEHYDE

4400710101

Urban

4.0325

2.80

FORMALDEHYDE

1205710651

Urban

3.8291

2.25

FORMALDEHYDE

4400700251

Urban

3.6958

2.53

FORMALDEHYDE

2616300271

Urban

3.5940

1.64

FORMALDEHYDE

4400700261

Urban

3.4373

2.36

FORMALDEHYDE

1205700811

Urban

3.4311

2.38

FORMALDEHYDE

4400700221

Urban

3.3888

2.01

FORMALDEHYDE

1210310081

Urban

3.2569

2.56

FORMALDEHYDE

1205710751

Urban

2.9991

2.73

FORMALDEHYDE

2612500101

Urban

2.8279

2.21

FORMALDEHYDE

1210350021

Urban

2.8150

2.31

FORMALDEHYDE

2616300191

Urban

2.7887

4.43

FORMALDEHYDE

4400700241

Urban

2.6769

3.25

FORMALDEHYDE

2616300011

Urban

2.4937

2.98

FORMALDEHYDE

5303300801

Urban

1.7148

2.97

FORMALDEHYDE

5303300321

Urban

1.4839

3.56

FORMALDEHYDE

5303300381

Urban

1.3536

2.53

FORMALDEHYDE

5303300201

Urban

1.3236

3.78

FORMALDEHYDE

5303300241

Urban

1.1373

2.48

FORMALDEHYDE

5303300101

Urban

1.0165

9.43

FORMALDEHYDE

0807700131

Rural

7.3046

6.72

FORMALDEHYDE

0807700161

Rural

7.0664

2.15

FORMALDEHYDE

1311300371

Rural

2.3401

5.10

FORMALDEHYDE

1311300391

Rural

2.1613

3.02

FORMALDEHYDE

0606530121

Rural

2.1246

2.83

FORMALDEHYDE

0606530111

Rural

1.6840

1.90

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Appendix A

Table A-2. Population CV estimates by pollutant and site

Pollutant

SITE ID

Urban /
Rural

State

County

Population
CV

1,3-BUTADIENE

530330032

Urban

WA

King County

109,2%

1,3-BUTADIENE

530330024

Urban

WA

Kinq County

106.7%

1,3-BUTADIENE

530330010

Urban

WA

King County

97.4%

1,3-BUTADIENE

530330038

Urban

WA

King County

85.8%

1,3-BUTADIENE

440070025

Urban

Rl

Providence County

84.2%

1,3-BUTADIENE

530330020

Urban

WA

King County

79.6%

1,3-BUTADIENE

261630027

Urban

Ml

Wayne County

78.0%

1,3-BUTADIENE

261250010

Urban

Ml

Oakland County

74.7%

1,3-BUTADIENE

440071010

Urban

Rl

Providence County

74.1%

1,3-BUTADIENE

530330080

Urban

WA

King County

72.4%

1,3-BUTADIENE

261630033

Urban

Ml

Wayne County

67.8%

1,3-BUTADIENE

121030018

Urban

FL

Pinellas County

67.5%

1,3-BUTADIENE

440070024

Urban

Rl

Providence County

64.5%

1,3-BUTADIENE

440070022

Urban

Rl

Providence County

63.8%

1,3-BUTADIENE

120571075

Urban

FL

Hillsborough County

62.9%

1,3-BUTADIENE

440070026

Urban

Rl

Providence County

61.7%

1,3-BUTADIENE

261630005

Urban

Ml

Wayne County

59.5%

1,3-BUTADIENE

121031008

Urban

FL

Pinellas County

57.9%

1,3-BUTADIENE

120571065

Urban

FL

Hillsborough County

57.6%

1,3-BUTADIENE

121035002

Urban

FL

Pinellas County

55.7%

1,3-BUTADIENE

440030002

Urban

Rl

Kent County

54.1%

1,3-BUTADIENE

120570081

Urban

FL

Hillsborough County

32.7%

1,3-BUTADIENE

080770013

Rural

CO

Mesa County

69.8%

1,3-BUTADIENE

080770016

Rural

CO

Mesa County

67.1%

1,3-BUTADIENE

131130039

Rural

GA

Fayette County

34.5%

1,3-BUTADIENE

131130037

Rural

GA

Fayette County

13.4%

ACROLEIN

440030002

Urban

Rl

Kent County

100.3%

ACROLEIN

440071010

Urban

Rl

Providence County

80.7%

ACROLEIN

440070024

Urban

Rl

Providence County

66.4%

ACROLEIN

440070022

Urban

Rl

Providence County

58.7%

ACROLEIN

440070026

Urban

Rl

Providence County

53.4%

ACROLEIN

440070025

Urban

Rl

Providence County

39.9%

ARSENIC TSP

530330024

Urban

WA

King County

99.6%

ARSENIC TSP

261630001

Urban

Ml

Wayne County

83.8%

ARSENIC TSP

261630019

Urban

Ml

Wayne County

78.2%

ARSENIC TSP

261630033

Urban

Ml

Wayne County

74.3%

ARSENIC TSP

530330010

Urban

WA

King County

72.1%

ARSENIC TSP

261630005

Urban

Ml

Wayne County

68.4%

ARSENIC TSP

530330038

Urban

WA

King County

67.2%

ARSENIC TSP

530330020

Urban

WA

King County

64.0%

ARSENIC TSP

261630027

Urban

Ml

Wayne County

64.0%

ARSENIC TSP

261630015

Urban

Ml

Wayne County

61.1%

ARSENIC TSP

121035002

Urban

FL

Pinellas County

47.3%

ARSENIC TSP

120571075

Urban

FL

Hillsborough County

44.3%

DQOs for Trends - Draft Report	A-6	September 27,2002

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Table A-2. Population CV estimates by pollutant and site (Cont'd.)

Pollutant

SITE ID

Urban /
Rural

State

County

Population
CV

ARSENIC TSP

120570081

Urban

FL

Hillsborough County

27.9%

ARSENIC TSP

121031008

Urban

FL

Pinellas County

27.2%

ARSENIC TSP

121030018

Urban

FL

Pinellas County

26.5%

ARSENIC TSP

120571065

Urban

FL

Hillsborough County

22.7%

ARSENIC TSP

080770016

Rural

CO

Mesa County

56.4%

ARSENIC TSP

080770013

Rural

CO

Mesa County

37.0%

BENZENE

261630027

Urban

Ml

Wayne County

221.2%

BENZENE

530330032

Urban

WA

King County

93.5%

BENZENE

530330020

Urban

WA

King County

82.2%

BENZENE

530330010

Urban

WA

King County

66.2%

BENZENE

530330024

Urban

WA

King County

64.7%

BENZENE

261630005

Urban

Ml

Wayne County

55.1%

BENZENE

121031008

Urban

FL

Pinellas County

49.8%

BENZENE

121030018

Urban

FL

Pinellas County

49.6%

BENZENE

261250010

Urban

Ml

Oakland County

48.7%

BENZENE

261630033

Urban

Ml

Wayne County

46.2%

BENZENE

440071010

Urban

Rl

Providence County

45.8%

BENZENE

121035002

Urban

FL

Pinellas County

41.9%

BENZENE

440070024

Urban

Rl

Providence County

41.6%

BENZENE

120571075

Urban

FL

Hillsborough County

41.6%

BENZENE

530330080

Urban

WA

King County

40.1%

BENZENE

530330038

Urban

WA

King County

39.4%

BENZENE

440070025

Urban

Rl

Providence County

37.7%

BENZENE

120571065

Urban

FL

Hillsborough County

36.1%

BENZENE

120570081

Urban

FL

Hillsborough County

35.8%

BENZENE

440030002

Urban

Rl

Kent County

34.6%

BENZENE

440070022

Urban

Rl

Providence County

33.9%

BENZENE

440070026

Urban

Rl

Providence County

29.1%

BENZENE

131130037

Rural

GA

Fayette County

54.2%

BENZENE

060653011

Rural

CA

Riverside County

53.7%

BENZENE

131130039

Rural

GA

Fayette County

52.1%

BENZENE

060653012

Rural

CA

Riverside County

49.1%

BENZENE

080770016

Rural

CO

Mesa County

45.8%

BENZENE

080770013

Rural

CO

Mesa County

32.2%

CHROMIUM TSP

530330010

Urban

WA

King County

98.5%

CHROMIUM TSP

530330020

Urban

WA

King County

87.0%

CHROMIUM TSP

530330038

Urban

WA

King County

84.9%

CHROMIUM TSP

530330024

Urban

WA

King County

84.6%

CHROMIUM TSP

121035002

Urban

FL

Pinellas County

61.5%

CHROMIUM TSP

120571065

Urban

FL

Hillsborough County

51.2%

CHROMIUM TSP

120571075

Urban

FL

Hillsborough County

44.6%

CHROMIUM TSP

261630033

Urban

Ml

Wayne County

43.9%

CHROMIUM TSP

261630019

Urban

Ml

Wayne County

42.7%

CHROMIUM TSP

261630005

Urban

Ml

Wayne County

42.0%

DQOs for Trends - Draft Report	A-7	September 27,2002

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Table A-2. Population CV estimates by pollutant and site {Cont'd.}

Pollutant

SITE ID

Urban /
Rural

State

County

Population
CV

CHROMIUM TSP

261630015

Urban

Ml

Wayne County

39.8%

CHROMIUM TSP

121031008

Urban

FL

Pinellas County

39,5%

CHROMIUM TSP

121030018

Urban

FL

Pinellas County

35.6%

CHROMIUM TSP

120570081

Urban

FL

Hillsborough County

34.5%

CHROMIUM TSP

261630027

Urban

Ml

Wayne County

33.0%

CHROMIUM TSP

261630001

Urban

Ml

Wayne County

31.8%

FORMALDEHYDE

121031008

Urban

FL

Pinellas County

84.9%

FORMALDEHYDE

120570081

Urban

FL

Hillsborough County

80.1%

FORMALDEHYDE

261630033

Urban

Ml

Wayne County

78.0%

FORMALDEHYDE

530330032

Urban

WA

King County

72.2%

FORMALDEHYDE

530330024

Urban

WA

King County

59.7%

FORMALDEHYDE

530330020

Urban

WA

King County

57.9%

FORMALDEHYDE

120571075

Urban

FL

Hillsborough County

55.8%

FORMALDEHYDE

530330010

Urban

WA

King County

53.9%

FORMALDEHYDE

440070024

Urban

Rl

Providence County

52.3%

FORMALDEHYDE

530330080

Urban

WA

King County

52,2%

FORMALDEHYDE

261630019

Urban

Ml

Wayne County

52.0%

FORMALDEHYDE

530330038

Urban

WA

King County

48.9%

FORMALDEHYDE

261630001

Urban

Ml

Wayne County

44.0%

FORMALDEHYDE

121035002

Urban

FL

Pinellas County

40.9%

FORMALDEHYDE

120571065

Urban

FL

Hillsborough County

38.2%

FORMALDEHYDE

440070022

Urban

Rl

Providence County

37.4%

FORMALDEHYDE

261630027

Urban

Ml

Wayne County

35.8%

FORMALDEHYDE

121030018

Urban

FL

Pinellas County

32.7%

FORMALDEHYDE

261250010

Urban

Ml

Oakland County

31.1%

FORMALDEHYDE

440070026

Urban

Rl

Providence County

28.3%

FORMALDEHYDE

440071010

Urban

Rl

Providence County

26.6%

FORMALDEHYDE

440070025

Urban

Rl

Providence County

26.6%

FORMALDEHYDE

060653011

Rural

CA

Riverside County

84.3%

FORMALDEHYDE

131130037

Rural

GA

Fayette County

57.2%

FORMALDEHYDE

060653012

Rural

CA

Riverside County

39.3%

FORMALDEHYDE

131130039

Rural

GA

Fayette County

35.1%

FORMALDEHYDE

080770013

Rural

CO

Mesa County

27.6%

FORMALDEHYDE

080770016

Rural

CO

Mesa County

23.7%

DQOs for Trends - Draft Report	A-8	September 27,2002

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Appendix B

APPENDIX B

NATTS AQS REPORTING GUIDANCE FOR
QUALITY ASSURANCE SAMPLES

BLANKS AND PRECISION SAMPLES
(COLLOCATED, DUPLICATE, AND REPLICATE REPORTING)

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NATTS QA Data Reporting to AQS

Blanks and Precision Samples (Collocated, Duplicate, and Replicate reporting)

Blank Sample Reporting

Blank samples in the NATTS program consist of field blanks, trip blanks, lot blanks, laboratory
method blanks, and exposure blanks. Monitoring agencies are required to report field blank, trip
blank, and lot blank data to AQS. Optionally, monitoring agencies may also report laboratory
method blanks and exposure blanks.

To report blank data, submit a raw blank (RB) transaction for each blank sample. The Blank
Type for the various blanks are:

To create an RB transaction for a field blank, the Blank Type field is entered as "FIELD" (bold
below) as in the following example:

RB|I|11|222|3333|44444|9|7|454|888IFIELDI20150101|00:00|0.0463||||||||||||0.0001|

Precision Sample Background

Duplicate and replicate analyses are defined and reported in the NATTS program. Collocated
data reporting is used in both the SLAMS and NATTS programs. The purpose of this section is
to clarify how data from these assessments should be reported to AQS using the new QA
transaction formats. (Please note, the old AQS "RA" and "RP" transactions have been retired
and can no longer be used to report data.) The goal is to provide consistent reporting terms and
procedures to allow the data to be universally understood.

Simplified schematics are included in this article for illustrative purposes and do not address
specifics related to different sampling approaches or methodologies.

The AQS transaction formatting descriptions are not repeated herein this document. Please refer
to the, but may be found on the AQS web site for those (accessed October 19, 2016):

https://aqs.epa.gov/aqsweb/documetits/Tratisaction.Formats.html

Field blank:
Trip blank:
Lot blank:

FIELD
TRIP
LOT
LAB

Laboratory Method Blank:
Exposure Blank:

FIELD 24HR

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Appendix B

Collocated Samples

Collocated samples are samples collected simultaneously at the same location using two
completely separate sampling systems, each with a separate inlet probe to the ambient sampled
atmosphere. The allowable distance between inlet probes is defined in regulations or in program
guidance. Both of the monitors (each designated by a separate AQS Parameter Occurrence Code
- POCs) have been established in AQS already. The samples are collected and analyzed
separately. Each is reported as a sample value for the appropriate monitor.

Schematic

Collocated Samples

T	

Collocated samples are samples collected simultaneously at the same
location using two completely separate sampling systems, each with a
separate inlet probe to the ambient sampled atmosphere.

Primary
Monitor N

Collocated
Monitor C

Q

Two completely separate sampling systems at same location, two different samples analyzed.

Collocated Sample Reporting Instructions

For AQS to automatically create the 'precision pair' for the primary and collocated samples, the
monitors must be identified to the system as QA collocated. One monitor must be designated as
the QA primary. If using transactions, the Monitor Collocation Period (MJ) transaction is used.
(If using the AQS application, the "QA Collocation" tab on the Maintain Monitor form may be
used to enter thesis data). The collocation data must be entered for both monitors, with one
indicated as the primary, and the other indicated as the collocated (not the primary). In the
example below, the primary monitor is indicated by the bolded ' Y' (yes, this is the primary) in
the Primary Sampler Indicator in the first MJ string and the collocated monitor by the bolded 'N'
(no, this is not the primary) in the Primary Sampler Indicator in the second MJ string.

Once the monitors have been identified as collocated this is done, there are no additional
reporting requirements; simply report the raw data from each monitor (From the schematic, value
'a' from the primary monitor 'N' and value 'b' from the collocated monitor 'C'). Once this is
done, AQS will know to pair data from these two monitors for the date range specified.

A set of transactions must be created for each time period the monitors are operating together.
The transactions have a begin date and end date for the operational period. The end date may be
left blank if the collocation period is still active (as indicated in the example below). To define a
collocation, submit two MJ transactions (example below with differences bolded and where
primary monitor 'N' is POC 5 and collocated monitor 'C' is POC 9):

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Appendix B

MJ|I|11|222|3333|44444|5|20150101 | |3|Y
MJ|I|11|222|3333|44444|9|20150101||3|N

Report two Raw Data (RD) transactions for each time sample data are to be reported from both
monitors; one for each monitor (POC). (In this example, sample 'a' is 0.0463 from monitor 'N'
(POC 5) and sample 'b' from monitor 'C' (POC 9) is 0.0458):

RD|I|11|222|3333|44444|5|7|454|:
RD|I|11|222|3333|44444|9|7|454|:

3 8|2015 0101|00:00|0.0463| |6| | | | | | | | | | | |0 . 0001 | 0 . 0005
)8I 2015 0101|00:00|0.0458| |6| | | | | | | | | | | |0.0001 | 0 . 0005

Since there are two monitors involved, each sample is reported for its appropriate POC and there
will be an RD transaction for every time there is a valid sample from each monitor (e.g., two per
day in this scenario). If the sample value from one POC is not available, report a null data code
for that monitor (that is, do not report the sample value from the collocated monitor as being
from the primary POC).

Duplicate Samples

Duplicate samples are two (or more) samples collected simultaneously using one or more
sampling units sharing a common inlet probe to the ambient atmosphere and the collected
samples are analyzed separately. This simultaneous collection may be accomplished by "teeing'
the line from the flow control device (sampling unit) to the media (e.g. canisters), and then
doubling the collection flow rate, or may be accomplished by collecting one discrete sample via
two separate flow control devices (sampling units) connected to the same inlet probe.

Schematic

Duplicate Samples



Duplicate samples are two (or more) samples collected simultaneously
using one or more sampling units sharing a common inlet probe to the
ambient atmosphere and the collected samples are analyzed separately

or

Primary
Monitor N

Collocated
Monitor C

t
&

One sampling system inlet probe, two different samples analyzed.

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Appendix B

Duplicate Sample Reporting Instructions

In this case, there is only one inlet probe involved but with multiple samples. Since only one
inlet probe is involved, all data should be reported for the same POC.

First, report the raw data as you normally would via the RD transaction. Report just one value,
the one for the sample obtained through the 'primary' hardware (the normal flow path or normal
canister, etc. as defined by the monitoring organization convention - typically this would be
sample 'a'). In this case, if sample 'a' comes from the primary hardware and has a value of
54.956, you would report:

RD|I|11|222|3333|44444|5|7|454|888|20150101|00:00|54.956||6||||||||||||0.0001|0.0005

If the primary value is null for some reason, the duplicate value may be reported as the sample
value for this POC in the RD transaction. In this case, there is not a valid duplicate assessment
to report. If all duplicates are null, an RD transaction with no sample value and a null data code
should be reported.

Each of the duplicate sample values is then also reported via the QA - Duplicate transaction.

This transaction has room for up to 5 duplicate sample values. Report them in any order, starting
with 1 and proceeding through the number of samples. In the schematic, there are two samples
(a 'primary' and a 'duplicate') so sample value 'a' would be reported as Duplicate Value 1 and
sample value 'b' would be reported as Duplicate Value 2. The same value reported on the Raw
Data transaction must be one of the values reported on the QA - Duplicate transaction.

Note that there is no sampling time reported on the QA - Duplicate transaction. Instead, there is
an Assessment Date and an Assessment Number. If multiple duplicate samples are performed on
the same day, label the first with Assessment Number = 1, the second with Assessment Number
= 2, and so on. Also note that all values must be reported in the same units of measure.

Here is an example QA - Duplicate transaction (with sample 'a' = 54.956 and sample 'b' =
51.443 - Assessment Number ' 1' bolded):

QA| I|Duplicate|999|11|222|3333|44444|5|20150101|11454|888|54.956|51. 443 | | | |

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Appendix B

Replicate Analysis

A replicate assessment is a separate analysis or multiple separate analyses of one discrete sample
(VOCs) or prepared sample (a sample extract [carbonyls or PAHs] or digestate [PMio metals]) to
yield multiple measurements from the same sample.

Schematic

Replicate Samples

Monitor N

A replicate assessment is a separate analysis or multiple separate
analyses of one discrete sample (VOCs) or prepared sample (a sample
extract [carbonyls or PAHs] or digestate [PM10 metals]) to yield multiple
measurements from the same sample.

One sampling system, one sample, multiple analyses.

Replicate Sample Reporting Instructions

Again in this case, there is only one AQS monitor (POC) involved and one single sample,
however multiple analyses of the sample.

First, report the raw data as you normally would via an RD transaction. Report just one value,
according to your laboratory's convention for reporting replicate data (e.g. the first replicate). In
this case, if you have chosen replicate 'a' as your raw data value and it has a value of 0.844, you
would report:

RD|I|11|222|3333|44444|5|7|454|888|20150101|00:00|0.844| |6| | | | | | | | | | | |0 . 000110.0005

If the normally reported value is null for some reason, one of the other replicate values may be
reported as the sample value for this POC in the RD transaction. If only one of the replicate
values remains valid, there is not a valid replicate assessment to report. If all replicates are null,
an RD transaction with no sample value and a null data code should be reported.

Once the RD transaction is completed, if two or more replicates are valid, these are reported via
the QA - Replicate transaction. This transaction has room for up to 5 replicate sample values.
Report them in any order, starting with 1 and proceeding through the number of samples. In the
schematic above there are three replicates 'a', 'b', and 'c', thus analytical value 'a' would be
reported as Replicate Value 1, analytical value 'b' would be reported as Replicate Value 2, and
analytical value 'c' would be reported as Replicate Value 3.

Note that there is no sampling time reported on this transaction. Instead, there is an Assessment
Date and an Assessment Number. If multiple replicate samples are collected on the same day,
label the first with Assessment Number = 1 (indicated below in bold), the second with

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Assessment Number = 2, and so on. Also note that all values must be reported in the same units
of measure.

Here is a sample QA - Replicate transaction (if sample values 'a', 'b', and 'c' are 0.844, 0.843,
and 0.792, respectively):

QA|I|Replicate|999|11|222|333|44444|5|2 0210101|1|454|888|0.844|0.843|0.7 92|||

Combining Duplicates and Replicate Analysis

It is possible to collect duplicate samples simultaneously and perform replicate analyses of these
duplicate samples. This is often referred to as a duplicate/replicate sample. In this case (see
schematic below), there are two duplicate samples, ' 1' and '2'. Duplicate Sample ' 1' has three
replicates: 'a', 'b', and 'c\ Duplicate Sample '2' has three replicates: 'd', 'e', and 'f.

Schematic

Duplicate / Replicate Samples



It is allowable (but not a requirement) to perform replicate analyses of
duplicate samples. In this case two duplicate samples are collected,
and each is "replicate" analyzed three times.

One sampling system, two samples, multiple analyses of each.

Duplicate/Replicate Reporting Instructions

This scenario requires the reporting of an RD transaction, a QA - Duplicate transaction, and a
QA - Replicate transaction to AQS.

For the RD transaction, follow the same rules to report the value from the primary (normal)
hardware (this would typically be sample ' 1', replicate 'a') and operations procedure path if
possible; follow the convention established by the laboratory. If the normal hardware path yields
sample 'la' you would report (in this case the value is represented by the "a" in the appropriate
place, with spaces for clarity):

RD|I|11|222|3333|44444|5|7|454|888|20150101|00:00| a | |6| | | | | | | | | | | |0 . 000110 . 0005

For the QA - Duplicate transaction: select one of the replicate analyses each from the primary
and duplicate sample (using the convention established by the laboratory) and report those on the
QA - Duplicate transaction. If the values to be reported are 'la' and '2d', the record would look
like this (again, values are represented by 'a' and 'd', spaces added for clarity):

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Appendix B

QA|I|Duplicate|999|11|222|333|44444 | 5|20210101 | 11 454 | 888 | a | d ||||

There are only two duplicate samples (one pair) in this case because only two paths were
assessed. (That is, you are not allowed to cross-multiply the replicate analyses to create
additional duplicate assessments [pairs].)

For the replicate transaction: report this as two assessments. Assessment Number 1 for the day
would include the values for replicates 'a', 'b', and 'c\ Assessment Number 2 for the day would
include values for replicates'd', 'e', and 'f.

The example transactions, using letters in place of the values:

QA|I|Replicate|999|11|222|333|44444|5|20210101|1| 454 | 888 | a | b | c |||
QA|I|Replicate|999|11|222|333|44444|5|20210101|2|454|888| d | e | f |||

Combining Collocated Samples and Replicate Analysis

It is also possible to make replicate analyses of collocated samples. Theseis is are sometimes
referred to as collocated replicate samples.

Schematic

Collocated Replicate Samples

It is also possible to make replicate analyses of collocated samples.

Primary
Monitor N

Collocated
Monitor C

Two completely separate sampling systems, two different samples analyzed multiple times.

Collocated Replicate Reporting Instructions

Since collocated monitors report all data independently, report these data for each monitor (e.g.,
under its own POC) according to the replicate reporting instructions.

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Appendix C

APPENDIX C
EPA ROUNDING GUIDANCE
Provided by EPA Region IV

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NATTS TAD Revision 3
Appendix C

Rounding Policy for Evaluating NAAQS QA/QC Acceptance Criteria

The following outlines EPA's Rounding Policy for evaluating Quality Assurance / Quality
Control (QA/QC) acceptance criteria. This policy is being provided to air monitoring
organizations in order to ensure consistency across the country in the validation of monitoring
data that is used for demonstrating compliance with the National Ambient Air Quality Standards
(NAAQS).

EPA's interpretation of standard rounding conventions is that the resolution of the measurement
device or instrument determines the significant figures used for rounding. The acceptance
criteria promulgated in the appendices of 40 CFR Part 50, or otherwise established in EPA
guidance documents, are not physical measurements. As an example, the quality control (QC)
acceptance criterion of ±5% stated in the fine particulate matter regulations (40 CFR Part 50,
Appendix L, Section 7.4.3.1) is not a measurement and, as such, does not directly contribute to
either the significant figures or to rounding. However, the flow rate of the sampler - measured
either internally by the flow rate control system or externally with a flow rate audit standard - is
a measurement, and as such, will contribute to the significant figures and rounding. EPA's
position is that it is not acceptable to adjust or modify acceptance criteria through rounding or
other means.

Example using PM2.5 Sampler Design Flow Rate

40 CFR Part 50, Appendix L, Section 7.4.3.1 defines the 24-hour sample flow rate acceptance
criterion as ±5% of the design flow rate of the sampler (16.67 liters per minute, LPM). The QC
acceptance criterion of ±5% stated in regulation is not a measurement and, therefore, does not
contribute towards significant figures or rounding. The measurement in this example is the flow
rate of the sampler. PM2.5 samplers display flow rate measurements to the hundredths place
(resolution) - e.g., 16.67 LPM, which has 4 significant figures. Multiplying the design flow rate
(16.67 LPM) by the ±5% acceptance criterion defines the acceptable flow regime for the
sampler. By maintaining 4 significant figures - with values greater than 5 rounding up - the
computations provide the following results:

•	The low range is-5% of the design flow: 0.95x16.67=15.8365-15.84

•	The upper range is+5% of the design flow: 1.05x16.67=17.5035-17.50

Rounding in this manner, the lower and upper acceptance limits for the flow rate measurement
are defined as 15.84 and 17.50 LPM, respectively.

40 CFR Part 58, Appendix A, Section 3.2.1 requires monthly PM2.5 flow rate verifications. The
verification is completed with an independent audit standard (flow device). The monthly check
includes a calculation to ensure the flow rate falls within ±5% of the design flow rate (see

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Method 2.12, Section 7.4.7). Therefore, flow rates obtained during monthly flow rate
verification checks should measure between 15.84 - 17.50 LPM, as defined above.

Measurements, in general, are approximate numbers and contain some degree of error at the
outset; therefore, care must be taken to avoid introducing additional error into the final results.
With regards to the PM2.5 sampler's design flow rate, it is not acceptable to round the ±5%
acceptance criterion such that any calculated percent difference up to ±5.4% is acceptable -
because rounding the acceptance criterion increases the error in the measurement. It is important
to note that the PM2.5 sampler must maintain a volumetric flow rate of approximately 16.67 LPM
in order for its inertial separators to appropriately fractionate the collected ambient air particles.
Flow rates greater than 5% of the nominal 16.67 LPM will shift the cut point of the inertial
separator lower than the required aerodynamic diameter of 2.5 microns and, thus, block the
larger fraction of the PM2.5 sample from being collected on the sample filter. Conversely, as the
sampler's flow rate drops below -5% of the nominal 16.67 LPM, the inertial separator will allow
particulate matter with aerodynamic diameters unacceptably larger than 2.5 microns to be passed
to the sample filter. Therefore, it is imperative that the flow rate of the sampler fall within the
±5% acceptance criterion.

A Note on Resolution and Rounding

Measurement devices will display their measurements to varying degrees of resolution. For
example, some flow rate devices may show measurements to tenths place resolution, whereas
others may show measurements to the hundredths place. The same holds true for thermometers,
barometers, and other instruments. With this in mind, rounding should be based on the
measurement having the least number of significant figures. For example, if a low-volume PM10
sampler displays flow rate measurements to the tenths place (3 significant figures), but is audited
with a flow device that displays measurements to the hundredths place (4 significant figures), the
rounding in this scenario will be kept to 3 significant figures.

Table 1 below lists some examples of NAAQS regulatory QA/QC acceptance criteria with
EPA's interpretation of the allowable acceptance ranges, as well as a column that identifies
results that exceed the stated acceptance limits. Table 1 is not a comprehensive list of ambient
air monitoring QA/QC acceptance criteria. Rather, Table 1 is provided to demonstrate how EPA
evaluates acceptance criteria with respect to measurement resolution.

The validation templates in the QA Handbook Vol II will be revised to meet this policy.

If you have any questions regarding this policy or the rounding conventions described, please
contact your EPA Regional Office for assistance.

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Appendix C

Table 1: Examples of Quality Control Acceptance Criteria

Regulatory

Method
Requirement

Method
Acceptance
Criteria

Typical
Measurement
Resolution

Acceptance Range
(Passing Results)

Exceeding
QA/QC Check

Shelter
Temperature

20 to 30°C or
FEM op. range

1 Decimal, 3
SF*

20.0 to 30.0°C or
FEM op. range

< 19.9°C
>30.1°C

PM2.5 Design
Flow (16.67 Ipm)

±5%

2 Decimal, 4 SF

15.84 to 17.50 Ipm

< -5.1%
> +5.1%

PM2.5 Transfer
Standard
Tolerance

±4%

2 Decimal, 4 SF

-4% Audit
Std

Sampler
Display

+4% Audit
Std

< -4.1%
> +4.1%



15.84

16.47

16.00

16.67

17.34

16.80

17.50



PM2.5 Lab:
Mean Temp
24-hr Mean

20 to 23°C

1 Decimal, 3 SF

20.0 to 23.0°C

< 19.9°C
> 23.1°C

PM2.5 Lab:
Temp Control
SD over 24-hr

±2°C

1 Decimal, 3 SF

±2.0°C

<-2.1°C
> +2.1°C

PM2.5 Lab:
Mean RH
24-hr Mean

30% to 40%

1 Decimal, 3 SF

30.0% to 40.0%

< 29.9%
>40.1%

PM2.5 Lab:
RH Control
SD over 24-hr

±5%

1 Decimal, 3 SF

±5.0%

< -5.1%
> +5.1%

PM2.5 Lab:
Difference
in 24-hr RH
Means

±5%

1 Decimal, 3 SF

±5.0%

< -5.1%
> +5.1%

*SF = Significant Figures

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