Questions and Answers on Ambient Air Monitoring Data Certification for CY 2020 Data


Questions and Answers on
Ambient Air Monitoring Data Certification for CY2020 Data

OAQPS realizes that the CY2020 data, including data completeness and QA/QC
completeness, for many organizations may have been impacted due to COVID-19. Data
should be appropriately validated, flagged, and submitted to AQS. If a monitoring
organization requires assistance in determining appropriate flags or actions pertaining
to their data (including QA/QC) please work with your Regional Office to determine the
best course of action. Checks of analyzers that produced a measurement to test
technical functionality (e.g., precision check, flow check, etc) of an analyzer or sampler
and are specified as critical criteria in Appendix D, Measurement Quality Objectives and
Validation Templates, of the Quality Assurance Handbook for Air Pollution
Measurement Systems Volume II or in an approved QAPP, were not subject to change.
However, QA/QC checks and data validity are subject to 40 CFR Part 58, Appendix A,
Section 1.2.3, including failure to conduct QA/QC, "weight of evidence", and use of data
submitted.

1.	What does it mean for a monitoring agency to certify its data?

Certification signals that the monitoring agency has loaded all of its data for the year
and has completed the monitoring agency's normal validation process. The responsible
official certifies that (i) the ambient concentration data and the quality assurance data
are completely submitted to AQS, and that (ii) the ambient data are accurate to the best
of his or her knowledge taking into consideration the quality assurance findings. The
first part means that all of the ambient data and all of the quality assurance data that
were collected, and that have completed and passed the monitoring agency's data
validation process have been submitted to AQS. The second part means that the
responsible agency official has considered the results of all periodic quality control
checks and other relevant performance assessments and has determined that the
ambient data, quality assessment (QA) and quality control (QC) data meets EPA
regulatory requirements and the data quality requirements specified in their agency's
QAPP(s).

EPA does NOT certify a monitoring agency's data as submitted to AQS. The ambient
concentration and quality assurance data is considered certified once the designated
certifying agency submits a complete data certification package to EPA. No approval
from EPA or the setting of the EPA evaluation flags changes that. Part of the
certification process is for the certifying agency to set the certification flags in AQS.
There are three flag columns in the AMP600, the AQS recommended flag (which cannot
be changed by the certifying agency or EPA), the certifying agency flag, and the EPA
evaluation flag (which can only be changed by EPA).

2.	What types of monitoring organizations must certify their data?

Per 40 CFR Part 58.15, state and local government monitoring organizations must
certify their ambient concentration data and QA/QC data. A state official should certify
all data submitted for all monitors specified in 40 CFR §58.15 within the Primary Quality
Assurance Organization (PQAO), except where responsibility for compliance with 40
CFR Part 58 requirements has been delegated to a local or tribal monitoring agency or

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Questions and Answers on
Ambient Air Monitoring Data Certification for CY2020 Data

other PQAO. Note that even if multiple monitoring organizations are within the same
PQAO, the certification may come from the state certifying agency or from each local
agency which has delegated responsibilities for compliance with 40 CFR Part 58.
Specific data certification responsibilities on a monitor by monitor basis are documented
through the AQS Certifying Agency Code.

A Tribe must certify its data if the Tribe is monitoring for regulatory purposes and is
identified as the certifying agency and/or PQAO. A Tribe may also be required to certify
its data under terms of a grant from EPA. Tribes should consult with the appropriate
Regional office on questions regarding regulatory monitoring and the certification
process.

3. What monitoring data must agencies certify by May 1, 2021 ?1

Only data collected by FRM, FEM, and ARM monitors at SLAMS and SPM monitoring
stations that meet Appendix A of 40 CFR Part 58 must be certified.2 In practice, this
refers to monitoring data for CO, NO2, SO2 (hourly and 5-minute average data), ozone,
lead, PM10, PM10-2.53, and PM2.5. Please refer to Question 2 for tribal data certifications.
This also includes any data that needs to be re-certified. For example, data that has
been changed in previous years and is now flagged with an "M".

Data is certified when a monitoring agency has entered the certification flags in AQS
and submitted the certification package with the required signed letter and reports to
EPA. An "N" or "Y" flag, entered into AQS by the certifying agency, indicates which data
is being certified. An "N" flag does not mean the data is not certified. It indicates that
caution is needed when using the data since it may not meet certain requirements, such
as data completeness or regulatory QA/QC requirements. The meanings of the data
certification flags can be found in the response to the last question or on the AQS Code
List website.

Data no longer needing certification include:

• Non-FRM/FEM/ARM continuous PM monitors

• PM2.5 speciation data - (total mass and speciated components)

• NCore/PAMS data including NOy, VOC, carbonyl, NH3, and HNO3 if collected

• Meteorological data

• Air Toxics data

• Monitors generating data considered not NAAQS comparable

1 The final ambient monitoring rule was signed on March 10, 2016 and was effective on
April 27, 2016, revising these requirements. Monitoring Regulations on AMTIC.

2 Data certification requirements may also be included in auxiliary agreements such as
MOA's between states and operators of industrial networks, for example, SO2 monitors
being installed to comply with the Data Requirements Rule.

3 The AMP600 report is not configured to handle PM coarse data or 5-minute S02 data
that is reported under a separate POC or parameter code. See AQS Guidelines for
Reporting 5-minute SO2 Data from January 3, 2011.

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Questions and Answers on
Ambient Air Monitoring Data Certification for CY2020 Data

Monitoring agencies are not required or expected to certify data from CASTNET
program samplers located within their jurisdiction. In most other cases, CASTNET data
will be certified by the responsible Federal agency (e.g., National Park Service or EPA
Office of Atmospheric Programs) and subsequently reviewed by the Regions or
OAQPS.

4.	What documents need to be provided by May 1, 2021?

These documents are required:

•	A data certification letter signed by the head air pollution monitoring official in
each monitoring agency, or his or her designee, sent to the applicable EPA
Regional Administrator or the delegated official, addressed to the attention of the
primary AQS contact noted at the end of this document. Certifying agencies
should check with their Regional contact to determine the appropriate official
recipient for the transmittal. The letter must include the specific statements given
in the response to Question 1 above. The letter must be clear regarding what
combinations of site, monitor, pollutant, and POC are the subject of the
certification statement.

•	AMP600 data certification report

•	AMP450NC for PM10-2.5 (PMcoarse) and 5-min SO2 data4 Although these
parameters do not appear in the AMP600, certification flags can still be entered
for these parameters using the AQS Certification Form within AQS.

•	Monitoring agencies can choose to submit an AMP450NC for any non-criteria
data. Some agencies may choose to do this for PAMS data being used for
designations or other pollutant data used for exceptional events.

Certifying agencies must use the AMP600 driven process for CY2020 data. Follow
these steps:

o Run the AMP600 report to review and make changes to the ambient monitoring
and QA/QC data as needed.

o Add the Monitoring Agency Certification flag for each monitor using the AQS
Data Certification form within AQS for the pollutants required to be certified that
were identified in Question 3.

o Run the AMP600 report a second time to generate a copy for submittal to EPA,
sign the summary page, and send it in with the 2020 data certification letter and
AMP450NC Reports.

5.	Who will be responsible for reviewing submitted certification packages?

EPA regional staff will be reviewing the certification packages with the exception of the
CASTNET or NPS monitors. The CASTNET or NPS monitors will be certified by the
responsible Federal Agency, as noted in Question 3. The evaluation criteria utilized in
the AMP600 report are updated annually.

Once the certification packages are received, EPA may or may not perform a rigorous

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Questions and Answers on
Ambient Air Monitoring Data Certification for CY2020 Data

review of the certified data. This should have been performed by the certifying agency
throughout the year and prior to the data certification submittal. EPA may only perform a
cursory review of the information provided in the data certification package and the Data
Certification Form within AQS before placing the EPA evaluation flag in AQS. More
thorough data reviews may be performed by EPA on a quarterly basis throughout the
year, during TSAs, and during other data review processes.

6. When will the AQS evaluation flags start appearing?

EPA regional staff will commence the review process after the May 1 deadline (or
earlier in the case of state-requested early certification packages), following the review
of certification package submittals to assure completeness and adherence to CFR
requirements. There is no explicit deadline for the insertion of evaluation flags. As with
previous years, the flag is displayed on both the AMP450 Quick Look summary report
and AMP450NC reports.

The AQS Team will apply a U-Flag for any data uncertified after July 1, 2021. This will
happen if the certifying agency did not submit the required certification letter and
summary reports, did not run an AMP600 report, did not apply a Monitoring Agency
Certification flag to a listed monitor within the Data Certification Form, or the state's
certification letter states that a given monitor is not part of the certification process for
that year. The EPA Evaluation Value flag field will display an S-flag until the EPA
regional office takes action.

7. How does data certification affect how ambient air monitoring data are used by
EPA and others?

EPA presumes that before the May 1 deadline, monitoring agencies may still be
reviewing and validating their data, making the data subject to change. After the
deadline has passed, EPA may move ahead and use both certified and uncertified data
to propose and make designations or findings of attainment. OAQPS usually advises
outside data users to be cautious about using data before the certification deadline has
passed. EPA typically does not use AQS data in broadly distributed publications until
the deadline for certification has passed.

"N" flags do not mean the data is not certified. It indicates that caution is needed when
using the data since it may not meet certain requirements, like data completeness or
QA/QC requirements. The meanings of the data certification flags can be found in the
response to the last question or on the AQS Code List website.

8. Why is a monitor's certification flag reset if a monitoring agency modifies the
data for that monitor after EPA first sets the flag? How can a monitoring agency
get a "Y" value restored?

AQS will automatically reset the certification flag to "M" if any deletion, revision, or
addition of concentration data causes a change in the reporting of the value or a

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Questions and Answers on
Ambient Air Monitoring Data Certification for CY2020 Data

summary statistic. AQS is programmed to reset the data certification flag because the
data within AQS are no longer what was originally submitted and certified. The
certifying agency should repeat the normal procedure of submitting a signed certification
letter, including submission of a new signed AMP600 report as soon as possible, but no
later than with the next May 1st certification submittal. This will allow the Regional Office
to repeat their review and reset the certification flag to an appropriate value, thus
informing all data users that the monitoring organization considers the new data set to
be accurate and complete.

A best practice is to run the AMP600 for the year being certified and for the previous 2-3
years to ensure data has not been flagged with "M" and would need re-certification by
the May 1st deadline. This ensures DVs are calculated from certified data. If re-
certification is needed for a previous year the state should submit a re-certification of the
data with an explanation to EPA.

9. How can I learn more about the AMP600 report and the data certification
process?

A wealth of information is available on the AQS training page. Data certification specific
training is also available. You can also find a detailed explanation of the meaning of
each certification flag which is also located in the table in Question 11.

Other questions or requests for assistance should be directed to your EPA Regional
Office point(s) of contact located in Question 10 or Trisha Curran.

10. Who are the designated EPA Regional Office point(s) of contact for the data
certification process?

An updated list of the AQS regional contacts can be found on the AQS User Support
webpage.

Region

Primary POC

Secondary POC

Mary Jane Cuzzupe

Robert Judge

Gavin Lau

Pauline Devose

Clinton McCrowey

Darren Palmer

Daniel Garver

Jacqueline Nwia

Michael Compher

Suzanne Apodaca

Cindy Parker

Stephen Krabbe

James Regehr

Ethan Brown

Joshua Rickard

Fletcher Clover

Dena Vallano

Chris Hall

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Questions and Answers on
Ambient Air Monitoring Data Certification for CY2020 Data

11. What are the meanings of the data certification indicator flags?

Flag
Value

Application

Comments

X

Certification is not required by 40 CFR 58.15
and no conditions apply to be the basis for
assigning another flag value.

Originally this was a blank (no flag).
However, the use of "X" makes it
definitive and therefore a flag will be
associated with all criteria pollutant data.

U

Uncertified. The certifying agency did not
submit a required certification letter and
summary reports for this monitor even though
the due date has passed, or the state's
certification letter specifically did not apply the
certification to this monitor.

EPA will need to determine the fields or
parameters necessary to identify this
data for flagging. The "U" Flag will be
entered for any un-certified data after
July 1st.

S

The certifying agency has submitted the
certification letter and required summary
reports. A value of "S" conveys no EPA
Regional assessment regarding data quality per
se. This flag will remain until the EPA Regional
Office provides an "N" or "Y" evaluation flag.

For the reporting process, the monitoring
organization officially submits the data
flagged with an EPA "S" in all cases,
even when there appears to be data that
need to be flagged as "N". This signifies
that EPA processing for a set of data
can start and it also helps to identify
what data is in the EPA evaluation
process.

N

The certifying agency has submitted the
certification letter and required summary
reports, but the certifying agency and/or EPA
has determined that issues regarding the quality
of the ambient concentration data cannot be
resolved due to data completeness, the lack of
performed quality assurance checks or the
results of uncertainty statistics shown in the
AMP256 report or the certification and quality
assurance report.

Signifies that the certifying agency
and/or EPA has determined there are
issues regarding the quality of the
ambient concentration and/or QA/QC
data which cannot be resolved.

Y

The certifying agency has submitted a
certification letter, and EPA has no unresolved
reservations about data quality (after reviewing
the letter, the attached summary reports, the
amount of quality assurance data submitted to
AQS, the quality statistics, and the highest
reported concentrations).

Signifies that the certifying agency
and/or EPA has determined there are no
reservations about the data quality.

M

The monitoring organization has revised data
from this monitor since the most recent
certification letter received.

When data is changed and needs to be
re-certified. Once the agency updates
the certifying agency flag the EPA flag
will be an "S".

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