Tribal Model PM2.5 using MiniVols QAPP

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09/27/18 DRAFT

DRAFT Thursday, June 18, 2009

Model Quality Assurance Project Plan

for Tribal PM2.5 Ambient Air Monitoring Programs USING MINIVOLS

Acronyms and Abbreviations

AIRSAerometric Information Retrieval System

ANSIAmerican National Standards Institute

ASTM American Society for Testing and Materials

CAAClean Air Act

CVcoefficient of variation, or sample standard deviation divided by the mean

CFRCode of Federal Regulations

COCchain of custody

DQAdata quality assessment

DQOsdata quality objectives

EPAEnvironmental Protection Agency

GISgeographical information systems

ITEPInstitute for Tribal Environmental Professionals, Northern Arizona University

LANlocal area network

MQOsmeasurement quality objectives

MSAmetropolitan statistical area

MSRmanagement system review

NAAQSNational Ambient Air Quality Standards

NISTNational Institute of Standards and Technology

OAQPSOffice of Air Quality Planning and Standards

PDpercent difference

PEperformance evaluation

PM2.5particulate matter 2.5 microns

PTFE polytetrafluoroethylene

Qa sampler flow rate at ambient (actual) conditions of temperature and pressure.

QA/QCquality assurance/quality control

QAPPquality assurance project plan

RPDrelative percent difference

SLAMSstate and local monitoring stations

SOPstandard operating procedure

SPMSspecial purpose monitoring stations

TAMSTribal Air Monitoring Support Center

Ta temperature, ambient or actual

TSAtechnical system audit

TSP total suspended particulate

Va air volume, at ambient or actual conditions

ADD ACKNOWLEDGEMENTS, DISCLAIMERS, AS APPROPRIATE FOR YOUR NEEDS

Instructions for using this template:

All of this material is guidance only. Information that must be completed with your particular Tribal Air Office's relevant terms and names is indicated in strikeout text, and BACKGROUND INFORMATION IS GIVEN IN ALL CAPS. Material that is particularly sensitive to your instrument specifications is highlighted in yellow. This and all other text and tables may be revised, deleted or added as you deem appropriate. (To delete strikeout format select the text, go to Format, Font, then uncheck the strikeout box; to change the background color select the text or box and then go to Format, Borders and Shading, Shading.)

This model QAPP is based on the Quality Assurance Project Plan developed after months of work by John Castillo of the Spokane Tribe. Melinda Ronca-Battista used that document to create this QAPP specifically for tribal organizations and is grateful to John and his management for their generosity in sharing their knowledge with other tribal air organizations.

1.0 QA Project Plan Identification and Approval (Element A1)

Title: The tribal air office QA Project Plan for the Tribal Air Monitoring Program. This QAPP commits the tribal air office to follow the procedures described and referenced in this plan. If appropriate: Plan development funded by grant #insert # from the U.S. Environmental Protection Agency. Technical assistance received from xxx and xxx.

Tribal air office Officials

Signature: ______Date:______

Name - Technical Manager, or the title of the manager

Signature: ______Date:______

Name - Field Technician, or the title of the person doing most of the field work

If there are others working on the project, add their names, titles, and their signatures here

Signature: ______Date:______

Name – Tribal Quality Assurance Coordinator, or the title and organization of the person who reviews QC data (at least some portion every month), final and interim data reports, and serves as an independent reviewer of the quality of the project to assist the field technician and technical manager, and may be available to the project for consulting on procedures, data management, and reporting.

Weighing Laboratory

Signature: ______Date:______

Name - Technical Manager, or the title of the manager

Contractors or consultants

Signature: ______Date:______

EPA Region Y (if using EPA grant)

1) Signature: ______Date:______

name, title, and organization (branch or division) of the EPA official who approves the QAPP

2.0Table of Contents (Element A2)

3.0Distribution List (Element A3)

Paper copies of this QAPP have been distributed to the people listed in Table 3-1. As portions of this QAPP are revised, revised sections or the entire QAPP are sent to these people.

Table 3-1 Distribution List

Name / Position / Address and email
tribal air office
Name / Title
Name / Title
Name / Title
Add more rows to include all people getting copies of this QAPP
EPA Region Y
Name / Title
Name / Title
Add more rows to include all people getting copies of this QAPP

(INCLUDE EVERYONE WHO SIGNED ON SIGNATURE PAGE)

4.0 Project/Task Organization (Element A4)

4.1The Role of the Tribal Air Office

This tribal agency incorporates quality assurance activities as an integral part of any program that gathers environmental data, from work in the field, from their own data analysis and reporting, and from any consulting and contractor laboratories which they may use.

The following sections list the responsibilities of each individual in the Tribal Air Office.

Supervisor Title - Name

The Supervisor Title, name has overall responsibility for managing the tribal air office air monitoring program. Ultimately, the Supervisor Title is responsible for establishing QA policy and for resolving QA issues identified through the QA program. Major QA-related responsibilities of the Supervisor Title include:

Reviewing acquisition packages (contracts, grants, cooperative agreements, inter-agency agreements) to determine the necessary QA requirements;

Assuring that the tribal air office develops and maintains this QAPP and ensures adherence to the document by staff, and where appropriate, outside contractors and consultants;

Maintaining regular communication with the field, and other technical staff;

Developing QA documentation and providing answers to technical questions;

Ensuring that all personnel involved in this program have access to any training or QA information needed to be knowledgeable in QA requirements, protocols, and technology of that activity;

Reviewing and approving this QAPP;

Ensuring that this program is covered by appropriate QA planning documentation (e.g., QA project plans and data quality objectives);

Ensuring that reviews, assessments and audits are scheduled and completed, and at times, conducting or participating in these QA activities;

Recommending required management-level corrective actions; and

Serving as the program QA liaison with EPA regional QA Managers or QA Officers and the EPA regional Project Officer.

Field Personnel - Names of Field Personnel (and describe each ones’ duties if they are responsible for different activities)

The tribal field personnel are responsible for carrying out the work in the field and ensuring that the data they gather meet the requirements of this QAPP. Their responsibilities include:

$Providing comments and assistance in the development and implementation of the QAPP;

Participating in training and certification activities;

Writing and modifying standard operating procedures (SOPs);

Verifying that all required QA activities are performed and that measurement quality standards are met as required in this QAPP;

Following all manufacturer's specifications;

Performing and documenting preventative maintenance;

Documenting deviations from established procedures and methods;

Reporting all problems and corrective actions to their supervisor;

Assessing and reporting data quality;

Preparing and delivering reports to their supervisor; and

Flagging suspect data.

Quality Assurance Coordinator

The Quality Assurance Coordinator (QAC) conducts and reviews quality assurance, quality assessment, and quality control activities and ensures that ambient air quality data meet or exceed the data quality objectives of the tribe. The QAC is responsible for assessing the acceptability of the air quality data prior to its use, purchasing NIST-traceable standards (if relevant to your program), certifying flow standards used in the field and generating QC reports. The QAC also serves as the program QA liaison with EPA regional QA Managers or QA Coordinators (NOTE THAT THIS ACTIVITY OF COORDINATING WITH THE EPA REGIONAL OFFICE MAY NOT BE APPLICABLE IF NOT OPERATING UNDER AN EPA GRANT, OR THE COMMUNICATION WITH THE EPA REGION MAY BE CONDUCTED BY THE PROJECT MANAGER).

4.2The Role of the EPA Region Y Office

EPA Regional Offices have been developed to address environmental issues related to the tribal air offices within their region. EPA's Region Y Office is responsible for the following activities in support of this program:

Reviewing, providing assistance with, and approving this QAPP;

Responding to requests for technical and policy information and interpretations;

Evaluating quality system performance through technical systems audits, performance evaluations and network reviews, as appropriate for each grant and the tribal air office; and

Making available the technical and quality assurance information developed by EPA to the tribal agencies, and making the tribe aware of any unmet quality assurance needs of the tribal agencies;

4.3 Contractor Support

Insert descriptions of contractor support, including to whom they report, the length of their contract, and their responsibilities.

5.0Problem Definition/Background (Element A5)

5.1Problem Statement and Background

The xxx Tribe of Indians, through a CAA Section 103 Grant from EPA, has established a PSD Tribal Air Quality Program; to establish baseline data, document trends about air quality on the xxx Indian Reservation, to design and implement an ongoing air quality program which will conduct a continuous surveillance program to monitor the quality of the ambient atmosphere as to concentrations and movements of air contaminants; to facilitate the protection of public health and welfare from the effects of air pollution and, to generate data for a possible TIP.

6.0Project Description (Element A6)

6.1Description of Work to be Performed

The Air Quality Program will monitor PM2.5 conditions. The department will use the MiniVol Portable Air Sampler, following the national one in six day schedule, to obtain ambient air samples. The exposed filters will be sent to the xxx lab for weighing. As the data are returned to the Air Quality office, the Air Quality Manager will review and validate the data, and the Air Quality Technician will enter the data into the computer. The data will then be analyzed for concentrations and trends in concentrations. This will then be reported to the Natural Resource Director, the Tribal Council and EPA, Region 10.

The sampler is equipped to operate from either AC or DC power sources. In the DC operational mode, the sampler operates from a battery pack, thus making the sampling site independent of line power. Air Quality operates the MiniVol Portable Air Sampler exclusively in DC mode. The MiniVol comes with two battery packs to accomplish continuous field sampling. A charged battery pack is capable of operating the sampler for up to 24 sampling hours on a single charge.

6.2 Schedule

Insert a brief overview of the schedule of the project, with estimates of the dates of the first measurements and how often measurements will be made.

7.0Quality Objectives and Criteria for Measuring Data (Element A7)

7.1Data Quality Objectives (DQOs)

The objectives for data quality are qualitative. Most important for this project are the measurement quality objectives, which are the guidelines for the quality of the data that are actually gathered, and are listed in Table 7-1. The data will be used to establish a baseline of understanding of the PM concentrations in the ambient air in the location(s) selected for the project. To do this, the data must be comparable to data that may be gathered in the future, and must have a minimum and known level of quality. Since the results will not be used to compare with the NAAQS, the strict conditions of 40 CFR 58 Appendix A can be used as guidance rather than mandatory requirements.

7.2Measurement Quality Objectives (MQOs)

Measurement quality objectives are designed to evaluate and control various phases (sampling, preparation, analysis) of the measurement process to ensure that total measurement uncertainty is within the range established during the planning. MQOs can be defined in terms of the following data quality indicators:

Precision - a measure of mutual agreement among individual measurements of the same property usually under prescribed similar conditions, or how well side-by-side measurements of the same thing agree with each other. Sometimes, as in the case of environmental measurements such as temperature in the weighing lab, precision can be estimated by repeated measurements of the same thing over time. It is important that the measurements be as similar as possible, using the same equipment or equipment as similar as possible, and that what they measure is as similar as possible. Precision represents the random component of uncertainty. This random component is what changes randomly high or low, and which, try as you might, you cannot control with the equipment and procedures you are using. Precision is estimated by various statistical techniques using the standard deviation or, if you only have two measurements, the percent difference between them.

Precision will be estimated for this project by collocating samplers and running them for the same time periods. All samplers used in the project will be collocated for periods of time sufficient to gather at least three valid duplicates.

Bias - the systematic or persistent distortion of a measurement process that causes uncertainty in one direction. This means that the result is generally higher than it should be, or lower than it should be. These types of systematic errors are caused by poor calibration, or doing the same thing "wrong" for each of the measurements that makes each result either always higher or always lower than it should be. Bias is estimated by evaluating your measurement results against some known standard that you use as the "true" value. It is generally expressed as a positive or negative percentage of the "true" value.

Bias is estimated two ways during this project. First, a flow check device has been purchased from Airmetrics and is used at least every month on each sampler to verify that the flow rate is stable and within four percent of the design flow rate. Second, an independent assessments of flow rate of all samplers at least once during the project is conducted (this may be done simultaneously in the office when all samplers are available—for example before they are sent for their annual calibration to Airmetrics—using a flow check device other than the one used for the monthly checks. This may be a device used by another agency (nearby tribe, state). The results of both of these checks will be reported and used when the PM data are interpreted in reports. Finally, sending each sampler to the manufacturer for calibration at least once every year minimizes bias.

Representativeness - a measure of the degree which data really represent some characteristic of a population, parameter variations at a sampling point, a process condition, or an environmental condition. For example, if you are trying to estimate the population exposed to PM2.5 within a tribal boundary, representative measurements would be those that measure what the people breathe, rather than emissions from an industry on the land.

For this project Representativeness will be ensured via careful siting of the samplers and at least annually assessing the siting and determining if they are suitable for the purposes of the project.

Detectability- The determination of the low range critical value of a characteristic that a method specific procedure can reliably discern. In other words, that level below which the instrument (e.g., scale) cannot tell the difference from zero. Because there is always variation in any measurement process (precision uncertainty), even when weighing the clean filters, for example, the level of detectability depends on how much precision error is in the process.

Detectability for these samplers is determined by the analysis laboratory and is not a critical issue.

Completeness - a measure of the amount of valid data obtained from a measurement system compared to the amount that was expected to be obtained under correct, normal conditions. Data completeness requirements are included in the reference methods (40 CFR Pt. 50). EPA has assumed levels of completeness of at least 75% per quarter when estimating how well your measurements can be used to make decisions about attainment in your area.

Completeness is determined by dividing the number of valid, usable values by the number scheduled.

Comparability - a measure of confidence with which one data set can be compared to another. Good comparability is very important so that data sets from one part of the country can be compared to data from another part of the country, or so that your data from one year can be compared to data from another year. Because we are not using FRM instruments for this project, we understand that the data cannot be used to make NAAQS compliance determinations, however, the data can be used as an initial assessment of local air conditions and to help determine the need for further studies.

Accuracy has been a term frequently used to represent closeness to truth and includes a combination of precision and bias uncertainty components. This term has been used throughout the CFR. In general, we will follow the conventions of the NIST and, more recently, of EPA (ref. NIST Report 1297 and EPA G-9) and will not use the term accuracy, but will describe measurement uncertainties as precision, bias, and total uncertainty (total uncertainty is the combination of both precision and bias).

Table 7-1 lists the MQOs for our PM2.5 program

Requirement / Frequency / Acceptance Criteria / Reference
Data Completeness / Quarterly / 75%
Filter
Visual defect check / All Filters / No holes, tears, folds, dirt
Verification
Clock/timer Verification
Temperature verification
Pressure verification / Every sample start
Every sample start
Every sample start / Adjust to minute
Within 2 degrees C
Within 10 mm Hg / Cite operations manual page numbers
Bias in Flow Rate
Flow Rate performance evaluation (internal—conducted by this tribal air office)
Flow Rate performance evaluation (external—conducted with a different flow check device than the one used for the monthly checks) / Flow rate checked before and after each run
Once each year for each sampler / +10% of 5 liters/min NOTE THAT YOU MAY WANT TO CHANGE THIS TO BETWEEN 4 AND 6 lpm, DEPENDING ON YOUR USE OF THE DATA AND HOW WELL YOUR MINIVOL IS OPERATING
+ 4% of the flow rate shown by the external flow rate check device / Mini vol operations manual (cite year and revision number and page number)
Precision
Collocated samples. / At least three for each location / Relative Percent Difference 14% for all side-by-side measurements / N/a

References