QUALITY ASSURANCE PROJECT PLAN FOR THE STATE OF FLORIDA AMBIENT AIR QUALITY LEAD MONITORING PROGRAM

Transcription

1 QUALITY ASSURANCE PROJECT PLAN FOR THE STATE OF FLORIDA AMBIENT AIR QUALITY LEAD MONITORING PROGRAM Prepared For: US EPA Region 4 Submitted by The Florida Department of Environmental Protection

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3 2 TABLE OF CONTENTS 1 Quality Assurance Project Plan Identification and Approval Table of Contents Distribution List... 4 Project / Task Organization Bureau of Air Monitoring and Mobile Sources... 5 Problem Definition and Background... 6 Project / Task Description Description of Work to Be Performed Field Activities Lead Laboratory Activities Project Assessment Techniques Project Records... 7 Data Measurement Quality Objectives and Criteria Data Quality Objectives Measurement Quality Objectives Network Scale... 8 Training Requirements... 9 Documentation and Records Information Included in the Reporting Package Data Reporting Package Format and Documentation Control Data Reporting Package Archiving and Retrieval Network Description Network Objectives Site Selection Siting Criteria for Lead Monitors Sampling Frequency Rationale for Florida s Lead Monitoring Network Sampling Methods Requirements Purpose Monitoring Technology/Methodology...

4 11.3 Sample Collection Methodology Support Facilities State of Florida s Ambient Air Lead Monitoring Network Samplers and Analysis Methods Sample Collection Sampling / Measurement System Corrective Action Analyzer Audits Sample Custody Procedure Analytical Methods Requirements Purpose / Background Preparation of Filters Analysis Method Internal Quality Control and Corrective Actions for Measurement Systems Quality Control Requirements Quality Control Procedures Equipment Testing, Inspection, and Maintenance Requirements Purpose / Background Testing Inspection Maintenance Instrument Calibration and Frequency Calibration of Local Primary Standards Calibration of Transfer Standards Calibration of Laboratory / Field Equipment Calibration Frequency and Documentation Inspection and Acceptance Criteria for Supplies and Consumables Data Acquisition Requirements Acquisition of Meteorological Data Acquisition of Non-Direct Measurement Data Data Management Background and Overview Data Recording...

5 19.3 Data Validation and Verification Data Transformation Data Transmittal Data Reduction Data Analysis Data Flagging Sample Qualifiers Data Tracking Data Storage and Retrieval Assessments and Response Actions Systems Audits Monitoring Network Plans and Network Assessments Audit Documentation Reporting and Resolution of Issues Reports to Management Frequency, Content, and Distribution of Reports Annual Monitoring Network Plan and Periodic Assessments Quarterly Data Reporting Systems Audit Reports Response / Corrective Action Reports Data Validation and Usability Sampling Design Data Review, Validation, and Verification Requirements Sampling Design Sample Collection Procedures Sample Handling Analytical Procedures Quality Control Calibration Data Reduction and Processing Reconciliation with Data Quality Objectives Reconciliation Results with DQOs...

6 Appendix A Acronyms and Abbreviations Appendix B Index of SOPs Appendix C Lead SOP Appendix D Hi-Vol SOP Appendix E FDEP Quality Assurance Systems Audit Protocol Appendix F FDEP Systems Audit Checklist Appendix G FDEP Site Review Checklist Appendix H Annual Air Quality Report Forward and Table of Contents Appendix I Annual air Monitoring Report Executive Summary and Table of Contents

7 LIST OF TABLES Table 3 Table 4-1 Table 4-2 Table 5-1 Table 6-1 Table 6-2 Table 7-1 Table 9-1 Table 10-1 Table 11-1 Table 19-1 Table 22-2 Distribution List Ambient Air Quality Lead Monitoring Program Organizational Structure Ambient Air Quality Monitoring Program Organizational Structure National Ambient Air Quality Standards Assessment Schedule Critical Documents and Records Lead Measurement Quality Objectives Reporting Package Information Summary of Spatial Scales for Lead State and Local Air Monitoring Stations (SLAMS) State of Florida s Ambient Air Lead Monitoring Network Samplers and Analysis Methods Data Archive Policies Data Qualifier Codes and Null Code Flags

8 3 DISTRIBUTION LIST U.S. EPA Region 4 Air Toxics and Monitoring Branch 61 Forsyth Street SW Atlanta, GA FDEP Northwest District 160 Government Center Pensacola, FL FDEP Southwest District 3804 Coconut Palm Dr Tampa, FL City of Jacksonville Environmental Resource Management Dept 407 N Laura Street Suite 300 Jacksonville, FL Pinellas County Dept of Environmental Management 300 South Garden Ave Clearwater, FL Broward County Pollution Prevention, Remediation and Air Quality Division One North University Drive Ste. 203 Plantation, FL Collier County Pollution Control and Prevention Dept Health Bldg. H 3301 Tamiami Trail Naples, FL U.S. EPA Region 4 Science and Ecosystem Support Division 980 College Station Road Athens, GA FDEP Northeast District 7825 Baymeadows Way Suite200B Jacksonville, FL FDEP South District 2295 Victoria Ave Suite364 Fort Myers, FL Orange County Environmental Protection Dept 800 Mercy Dr Suite 4 Orlando, FL Manatee County Environmental Management Dept th Avenue East Bradenton, FL Palm Beach County Health Dept; Division of Environmental Health & Engineering 800 Clematis Street P.O. Box 29 West Palm Beach, FL Ambient Air Services, Inc. 106 Ambient Air Way Starke, FL FDEP Central District 3319 Maguire Blvd Suite232 Orlando, FL FDEP Southeast District 400 North Congress Ave West Palm Beach, FL Environmental Protection Commission of Hillsborough Co 3629 Queen Palm Dr Tampa, FL Sarasota County Environmental Services 1303 Cattlemen Road Bldg E Sarasota, FL Miami-Dade County Dept of Environmental Resource Management 33 SW Second Ave Suite 900 Miami, FL Florida Sugar Cane League P.O. Drawer 1208 Clewiston, FL 33440

9 4 PROJECT / TASK ORGANIZATION The Florida Department of Environmental Protection s (FDEP) Division of Air Resource Management (DARM) is organized into two bureaus and one staff office: the Bureau of Air Regulation (BAR); the Bureau of Air Monitoring and Mobile Sources (BAMMS); and the Office of Policy Analysis and Program Management (OPAPM). The director of DARM has the overall responsibility for managing these bureaus and office according to stated policy. The director delegates the responsibility and authority to develop, organize, and maintain quality programs to the chiefs of the bureaus and office. The director also delegates the responsibility and authority to implement quality programs and procedures to the administrators of each section, in accordance with the Quality Management Plan. The direct responsibility for assuring data quality rests with these administrators and the line managers under them. The organizational structure for the implementation of the monitoring program is shown in Figure 4-1. Section 4.1 lists the specific responsibilities of each significant position within the Bureau of Air Monitoring and Mobile Sources. The Lead Filter Weighing Laboratory is operated by XXXXX. The laboratory s project / task organization is therefore not included in this document. However, the laboratory is included in Figure 4-1 for informational purposes. 4.1 Bureau of Air Monitoring and Mobile Sources The Bureau of Air Monitoring and Mobile Sources contains the Ambient Monitoring, Emissions Monitoring, and Mobile Source Control sections and is responsible for coordinating all aspects (quality assurance, data collection, and data processing) of Florida s Lead Ambient Air Quality Monitoring Program. For the purposes of this document, only the Ambient Monitoring Section will be covered. Chief The chief of the Bureau of Air Monitoring and Mobile Sources has direct access to the director on all matters relating to the bureau s operation. The chief s duties include, but are not limited to the following: maintaining oversight of all monitoring and general permitting activities reviewing budgets, contracts, grants and proposals Ambient Monitoring Section Administrator The administrator reports to the chief of the Bureau of Air Monitoring and Mobile Sources and coordinates all of the activities of the section. The administrator s duties include the following: maintaining oversight of the QA activities related to the statewide lead ambient monitoring program maintaining overall responsibility for the statewide monitoring network design and review reviewing budgets, contracts, and proposals related to the statewide lead ambient monitoring program specifying funding for present and future network needs

10 chairing the Florida Air Monitoring Advisory Committee (FAMAC) which is made up of voting members from each of the DEP District and local air programs FAMAC is an internal committee of DARM and local program personnel which sets the minimum requirements by which all agencies shall run their quality assurance programs Data Analysis and Processing Supervisor The supervisor reports to the administrator and is responsible for coordinating the activities of the statewide lead monitoring program. The supervisor s duties include the following: organizing the collection, verification, and reporting of all lead ambient air quality monitoring and quality assurance data to the EPA s Air Quality System (AQS) assessing the effectiveness of the network system ensuring training availability and utilization as it relates to the data reporting function responding to public records requests ensuring timely and appropriate standard operating procedure (SOP) and Quality Assurance Project Plan (QAPP) updates Audit/Standards Laboratory Manager The manager reports to the administrator and is responsible for coordinating the quality assurance audit functions related to the statewide lead ambient monitoring program. The supervisor s duties include the following: coordinating the performance and management systems audits for all agencies operating within the statewide lead ambient monitoring network supervising the operation of the Ambient Monitoring Section s Standards Laboratory which supports the statewide lead monitoring operations reviewing all standard operating procedures to ensure they meet the latest federal and state policies and procedures Calibration, Maintenance, and Repair (CMR) Shop Supervisor The supervisor reports to the administrator and is responsible for coordinating the operation of the Shop. The supervisor s duties include the following: coordinating the installation of new monitoring sites required by the division or district lead monitoring programs coordinating the repair and/or replacement of field instrumentation required for the district lead monitoring programs maintaining the lead monitoring program s inventory system of equipment and parts providing technical support via phone and/or to the district and local lead air monitoring programs

11 Figure 4-1 Lead Ambient Air Quality Monitoring Program Organizational Structure FDEP QAPP-004 XXXXX Laboratory Division Director [Lab Structure?] Office of Policy Analysis and Program Management (OPAPM) Bureau of Air Monitoring and Mobile Sources (BAMMS) Bureau of Air Regulation (BAR) Northeast District Northwest District Central District Southeast District South District Southwest District City of Jacksonville Local Air Program Orange County Local Air Program Broward County Local air Program Collier County Local air Program Pinellas County Local Air Program Miami-Dade Local Air Program Sarasota County Local Air Program Palm Beach County Local Air Program Hillsborough County Local Air Program Manatee County Local Air Program

12 Figure 4-2 Ambient Air Quality Monitoring Program Organizational Structure FDEP QAPP-004 DIVISION OF AIR RESOURCE MANAGEMENT (DARM) BUREAU OF AIR REGULATION (BAR) BUREAU OF AIR MONITORING AND MOBILE SOURCES (BAMMS) OFFICE OF POLICY ANALYSIS AND PROGRAM MANAGEMENT (OPAPM) EMMISSIONS MONITORING SECTION AMBIENT MONITORING SECTION MOBILE SOURCE CONTROL SECTION QUALITY ASSURANCE SECTION CALIBRATION, MAINTENANCE & REPAIR SHOP DATA ANALYSIS & PROCESSING SECTION AIR STANDARDS LAB MANAGEMENT SYSTEMS AUDITS ========================= PERFORMANCE AUDITS ========================= SOP REVIEW FIELD MONITORING NETWORK DESIGN TECHNICAL WRITING

13 5 PROBLEM DEFINITION AND BACKGROUND In 1970, the Clean Air Act was signed into law. The Clean Air Act and its amendments provide the framework for protecting air quality. In order to protect air quality, active environmental data collection operations must be established and operated in a manner that assures the most applicable and highest quality data are collected. The National Ambient Air Quality Standards (NAAQS) establish limits for lead as shown in Table 5-1. Only lead concentrations collected by federal reference methods (FRMs) or federal equivalent methods (FEMs) are used in NAAQS comparisons and attainment/non-attainment designations. Table 5-1 National Ambient Air Quality Standards Lead (Pb) Averaging Standard Value Standard Type Rolling 3- month Average 0.15 µ g/m 3 Primary and Secondary US EPA regulations require all projects involving the generation, acquisition, and use of environmental data be planned, documented and have an approved Quality Assurance Project Plan (QAPP). The QAPP is the critical planning document for any environmental data collection operation because it documents how quality assurance (QA) and quality control (QC) activities will be implemented during the project s life cycle. The State of Florida s Quality Assurance Plan (QAP) was originally developed and approved in 1979 to implement QA and QC policies and procedures for the pollutants considered criteria pollutants: ozone, NO 2, CO, SO 2, lead, and PM 10. The Quality Assurance Project Plan for the State of Florida Ambient Air Quality Monitoring Program was written in 2007 to replace to QAP. It contains the QA and QC activities related to the same pollutants. In 1998, the EPA added PM 2.5 to the list of criteria pollutants. The Quality Assurance Project Plan for the State of Florida s PM 2.5 Ambient Air Quality Monitoring Program at State and Local Air Monitoring Stations was written in 1998 to implement the state of Florida s QA and QC policies and procedures for PM 2.5 monitoring. It was later revised in 2003 and 2009 as the regulations governing PM 2.5 monitoring were changed by the EPA. The PM 2.5 QAPP was the first official QAPP written by the state of Florida. On January 12 th of 2009, the EPA promulgated a revision to the lead (Pb) NAAQS decreasing the standard to 0.15 µ g/m 3, in the form of a three-month rolling arithmetic mean, from 1.5 µ g/m 3, in the form of a quarterly average, and altering the monitoring and analysis methodologies. This Quality Assurance Project Plan for the State of Florida s Ambient Air Quality Lead Monitoring Program was written in the same year as a stand-alone QAPP in response to the recent changes in lead monitoring. The lead QAPP was written solely for the revised standard of 0.15 µ g/m 3. This lead QAPP documents the implementation of QA and QC policies and procedures for lead monitoring. It is reviewed annually and revised as needed, subject to approval of the EPA s Region 4 QA Officer.

14 This version of the Quality Assurance Project Plan for the State of Florida s Ambient Air Quality Lead Monitoring Program, developed in 2009, is a based on the most recent revisions as of the date of its writing of the Quality Assurance Project Plan for the State of Florida s Ambient Air Quality Monitoring Program and the Quality Assurance Project Plan for the State of Florida s PM 2.5 Ambient Air Quality Monitoring Program. This document presents the state of Florida s Ambient Air Quality Lead Monitoring Program s QAPP, and shall be referred to simply as the QAPP for the remainder of the document. The QAPP incorporates standard procedures to be followed in all lead monitoring projects for comparison to the NAAQS. All of the district and local air monitoring programs will adhere to the principles and procedures herein, unless a special project requires more stringent requirements. The purpose of the QAPP is to prescribe requirements, procedures, and guidelines for the statewide ambient air quality lead monitoring QA program. It is intended to serve as a reference document for implementing and expanding the QA program and provides detailed operational procedures for measurement processes. The QAPP should be particularly beneficial to operators, project officers, and program managers responsible for implementing, designing, and coordinating lead monitoring projects. The QAPP is a compilation of QA requirements, procedures, and guidelines that are applicable to lead air pollution monitoring and meteorological measurements systems. They are designed to achieve a high percentage of valid data samples (>75 %) while maintaining integrity and accuracy. This QAPP clearly and thoroughly establishes QA protocols and QC criteria required to successfully implement and maintain the statewide ambient air quality lead monitoring program. The statewide monitoring program is administered by the department through the district offices and contracts and agreements with the local air programs. It is the responsibility of each of the participating agencies to ensure that the quality assurance programs for the field, laboratory, and data processing phases of the monitoring program are implemented. Quality assurance is a system of management activities designed to ensure that the data produced by the operation will be of the type and quality needed and expected by the data user. Quality control defines the procedures implemented to assure that acceptable precision, bias, completeness, representativeness, and comparability are obtained and maintained in the generated data set. Quality control procedures, when properly executed, provide data that meet or exceed the minimally acceptable quality criteria established to assist management in making confident decisions. It is the policy of the department to implement a QA program and QC procedures to assure that data of known and acceptable precision, bias, completeness, comparability, and representativeness are collected from all monitoring projects. Precision, bias, completeness, comparability, representativeness, and sensitivity are the principle Data Quality Indicators (DQI) that provide qualitative and quantitative descriptions used in interpreting the degree of acceptability of data. Performance and acceptance criteria [for data collection efforts] are often expressed in terms of data quality indicators [DQIs]. The principal indicators of data quality are precision, bias, accuracy, representativeness, comparability, completeness, and sensitivity Measurement quality objectives (MQOs) are the acceptance thresholds or goals for [the data collection effort s] data, usually based on the individual DQIs for each matrix and analyte group or analyte. (Guidance for Quality Assurance Project Plans, US EPA QA/G-5, EPA/240/R-02/009, Section 2.1.7) Precision and bias are quantitative measures; representativeness, comparability, and sensitivity are qualitative measures; and completeness is a combination of both qualitative and quantitative measures. Definitions of the DQIs are provided in Section 7.2.

15 Accuracy is a combined metric which represents the closeness of an individual measurement, or the average of a number of measurements, to the true value. Components of accuracy are random error, represented by the metric precision, and systematic error, represented by the metric bias. These error components result from sampling and analytical operations. The specific requirements of these seven DQIs are established beforehand, on a project by project basis, so that the goals of each project are met. The goal is to locate and eliminate or minimize bias, so the data collected show the true conditions of the area being sampled. This goal includes consideration of siting criteria, spatial scales, monitoring objectives, climatic change, source configuration, and duration of the study.

16 6 PROJECT / TASK DESCRIPTION 6.1 Description of Work to Be Performed This QAPP was developed to ensure that Florida s lead ambient air quality monitoring network collects ambient lead data that meet or exceed EPA quality assurance requirements. These data are entered into the EPA AQS database. The work required to collect, document, and report these data includes, but is not limited to: establishing a monitoring network that has: appropriate density, location, and sampling frequency; and accurate and reliable data recording equipment, procedures, and software. developing encompassing documentation for: data and report format, content, and schedules; quality objectives and criteria. standard operating procedures providing activities and schedules for: equipment operation and preventative maintenance, instrument calibrations, and precision and accuracy evaluations. establishing assessment criteria and schedules. 6.2 Field Activities All monitoring personnel perform those activities that support the continued successful operation and expansion of the statewide lead ambient air quality monitoring network. Personnel perform field activities that include, but are not necessarily limited to, conducting periodic preventative maintenance and servicing equipment located at State and Local Air Monitoring Stations (SLAMS), special purpose monitoring (SPM) stations, and National Core Monitoring Network (N-Core) stations located within the State of Florida. Operational servicing activities include, but are not limited to, collecting samples, recording pertinent field data, and restocking consumables at the monitoring sites. Additional field activities include relocating sites and/or locating suitable monitoring sites for possible expansion of the network.

17 6.3 Lead Laboratory Activities Section Under Construction Lead laboratory personnel perform those activities that support continued successful operation of the statewide ambient air quality lead monitoring network. Additionally, where analysis of samples is required, the laboratory personnel perform those duties such that the data quality provided meets or exceeds EPA QA requirements. Laboratory personnel are responsible for preparing consumables for field use. This includes, but is not limited to, performing assays on materials prior to and after exposure to the ambient atmosphere, preparing and analyzing control samples, maintaining consumable inventories, shipping and receiving activities, and performing instrument audits. Laboratory personnel are also responsible for writing all standard operating procedures which pertain to laboratory operations. 6.4 Project Assessment Techniques An assessment is an evaluation process used to measure the performance or effectiveness of a system and its elements. As used here, assessment is an all-inclusive term used to denote any of the following: audit, performance evaluation, management systems review (MSR), peer review, inspection, or surveillance. Section 20 will discuss the details of assessments. Information on the parties implementing assessments and their frequency is provided in Table 6-1. Table 6-1 Assessment Schedule Assessment Type Assessment Agency Frequency Technical System Audit Network Planning Data Qualifiers/Flags Review EPA Region 4 & State EPA Region 4 & State State Every 3 Years Annually (Network Assessment on a 5 year cycle) Annually Standard Operating Procedures Reviews State As Required Data Quality Assessment State Annually Performance Evaluation Program EPA As Scheduled National Performance Audit Program State/EPA As Scheduled

18 6.5 Project Records Each agency establishes and maintains procedures for the timely preparation, review, approval, issuance, use, control, revision, and maintenance of documents and records. The categories and types of records and documents which are applicable to document control for lead ambient air quality information are presented in Table 6-2. Information on key documents in each category is explained in more detail in Section 9. Table 6-2 Critical Documents and Records Categories Site Information Environmental Data Operations Raw Data Data Reporting Data Management Quality Assurance Network Descriptions Site Files Site Maps Site Pictures Record/Document Type Quality Assurance Project Plans Standard Operating Procedures Field and Laboratory Notebooks Sample Handling/Custody Records Inspection/Maintenance Records Any Original Data (routine and quality control) Including Data Entry Forms Air Quality Index Reports Data/Summary Reports Data Algorithms Data Management Plans/Flowcharts Data Management Systems Good Laboratory Practices Network Reviews Data Quality Assessments Quality Assurance Reports Technical System Audits Response/Corrective Action Reports Site Audits

19 7 DATA AND MEASUREMENT QUALITY OBJECTIVES AND CRITERIA The material presented in this QAPP is an ideal QA program for lead air pollution measurement systems. A special project may require different procedures depending on the purpose and scope of the project, resulting in a QAPP specific to that project that addresses the QA areas or elements as required. However, the specific written procedures or methodologies for operating instruments and handling data must be adhered to by all individuals, firms, or agencies producing air quality data for enforcement purposes or under the terms of an air quality permit. Preferably, the designated methodologies shall comply with EPA approved Federal Reference Methods (FRM) or Federal Equivalent Methods (FEM). 7.1 Data Quality Objectives This section provides a description of the data quality objectives (DQOs) for the ambient air quality lead monitoring program for the State of Florida. Data quality objectives are qualitative and quantitative statements that: clarify the intended use of the data, define the type of data needed, and specify the acceptable limits on the probability of making a decision error due to uncertainty in the data. In general, the goal of the Ambient Air Quality Lead Monitoring Program is to: determine the impact on ambient pollution levels of significant sources or source categories; determine representative concentrations in areas of high population density; and produce ambient monitoring data that are legally defensible.

20 7.1.1 Intended Use of Data These data are used to: evaluate compliance with the NAAQS, monitor progress made toward meeting lead ambient air quality standards, establish a historical baseline concentration of natural and anthropogenic air pollutants, monitor the current dynamic concentrations of these air pollutants, activate emergency control procedures that prevent or alleviate air pollution episodes, provide data to outside entities for health and other research, provide data upon which long term control strategies can be reliably developed, and provide a database for researching and evaluating effects Type of Data Needed The data compiled are a combination of meteorological, parameter (i.e., average pressure, minimum temperature, etc.), and pollutant data. The criteria pollutant lead is monitored at designated SLAMS, N- Core, and SPM stations. Specific information on the sampling design, including how to identify monitoring locations, is presented in Section Tolerable Error Limits In the development of the EPA model QAPP, EPA utilized the formal DQO process (see: Guidance for the Data Quality Objectives Process, EPA QA/G-4, EPA/240/B ) to specify tolerable limits on the probability of making a decision error due to uncertainty in the data. That is, limits on the probability of coming up with false positive or false negative errors. A false positive error is encountered when the data indicate that an emissions limit has been exceeded when in fact, due to errors in the data, it has not been exceeded. Alternately, a false negative error is encountered when the data indicate that no emissions limit has been exceeded when in fact, due to errors in the data, an emissions limit has been exceeded. Utilizing the DQO process determines the objectives regarding the quality of the lead ambient air measurement system to control precision and bias in order to reduce the probability of decision errors. The State of Florida s ambient air quality lead monitoring program establishes an acceptable precision of 20% for a 90% confidence limit coefficient of variation and an acceptable bias of ± 15%. By controlling precision and bias at these levels, the decision error probability limit will be 10%.

21 7.2 Measurement Quality Objectives As air pollution and meteorological measurement systems increase in both cost and complexity, it becomes essential that we have a methodology that will, in a cost-effective manner, increase the completeness and precision and decrease the bias of the data produced by the State of Florida s measurement systems. Once a DQO is established, the quality of the data must be evaluated and controlled to ensure that it is maintained within the established acceptance criteria. Measurement quality objectives (MQOs) 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 prescribed by the DQOs. The MQOs for the State of Florida s lead ambient air quality monitoring program are defined in terms of the following DQIs: Precision - The measure of agreement among repeated measurements of the same property under identical, of substantially similar, conditions (US EPA QA/G-5, Section 2.1.7, Table D-3). Precision is the random component of error. Bias - [T]he systematic or persistent distortion of a measurement process that causes errors in one direction (US EPA QA/G-5, Section 2.1.7, Table D-3). Bias is determined by estimating the positive and negative deviation from the true value as a percentage of the true value. Comparability - A qualitative term that expresses the measure of confidence that one data set can be compared to another and can be combined for the decision(s) to be made (US EPA QA/G-5, Section 2.1.7, Table D-3). Representativeness - A qualitative term that expresses the degree to which data accurately and precisely represent a characteristic of a population, parameter variations at a sampling point, a process condition, or an environmental condition (US EPA QA/G-5, Section 2.1.7, Table D-3). 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 (40 CFR Part 58, Appendix A, Section 1.2). Sensitivity The capability of a method or instrument to discriminate between measurement responses representing different levels of the variable of interest (US EPA QA/G-5, Section 2.1.7, Table D-3). For each of these attributes, acceptance criteria have been developed using various parts of 40 CFR and EPA supplied guidance documents. The MQOs for the State of Florida s lead ambient air quality monitoring program are listed in following tables. More detailed descriptions of these MQOs and how they are used to control and assess measurement uncertainty are described in other sections, as well as in the SOPs used as part of this QAPP.

22 Table 7-1 Lead (Pb) Measurement Quality Objectives Criteria Frequency Acceptable Range CRITICAL CRITERIA Pb in TSP Information (CFR or Method 2.2 or 2.8 Filter Holding Times Sample Recovery all filters ASAP Part 50, App B Sampling Period all filters 1440 minutes ± 60 minutes midnight to midnight Part 50, App B, Sec 8.15 Sampling Instrument Average Flow Rate every 24 hours of op m 3 /min (varies with instrument) Part 50, App B, Sec 8.8 Filter Visual Defect Check (unexposed) Collection Efficiency Pressure Drop Range ph Pb Content Verification/Calibration One-point Flow Rate Verification Calibration Reproducibility Checks Reagent Blank Daily Calibration Verification/Calibration System Leak Check FR Multi-point Verification/Calibration Precision Collocated Samples Audits Semi Annual Flow Rate Audit Lead Strip Analysis all filters all filters all filters all filters all filters pre-sampling batch check 1/3 mo Beginning, every 10 samples and end Every analytical batch Daily see reference 99 % mm Hg 6-10 <75 µg/filter ±7% from design transfer standard ±10% from design ± 5% of value predicted by calibration curve < LDL Until good agreement is obtained among replicates OPERATIONAL EVALUATIONS TABLE Pb in TSP During precalibration check After receipt, after motor maintenance or failure of 1-point check and 1/yr 15% of each method code in PQAO Frequency - every 12 days 2/yr 6 strips/quarter, 3/conc. Auditory inspection with faceplate blocked 5 points over range of 1.1 to 1.7 m 3 /min within ± 5% limits of linearity Part 50, App B, Sec 7.1 Part 50, App B, Sec 8.2 Part 50, App B, Sec Part 50, App B, Sec Part 50, App B, Sec Part 50, App G, Sec 6.1.1; Method 2.8 Sec Part 58, App A; Method 2.2 Sec 2.6 Part 50, App G, Sec 9.3 recomendation Method 2.8 Sec Method 2.2 Sec 2.0 Method 2.2 Sec 2.6 CV 20% of samples > 0.02 µg/m 3 (cutoff value) Part 58, App A, Sec ± 10% of audit standard and design value 10% (percent difference) Part 58, App A, Sec Part 58, App A, Sec Blanks Field Filter Blank 1/quarter < LDL recommendation

23 Table 7-1 Lead (Pb) Measurement Quality Objectives (continued) Criteria Frequency Acceptable Range Monitor Maintenance Inlet cleaning Motor/housing gaskets Blower motor brushes Manufacturer-recommended maintenance 1/3 mo ~400 hours hours Per manufacturer s SOP cleaned Inspected replaced Replace Per manufacturer s SOP Information (CFR or Method 2.2 or 2.8 recommendation Method 2.2 Sec 7 Method 2.2 Sec 7 N/A SYSTEMATIC CRITERIA Pb Filter-Based Hi-Vol Data Completeness Quarterly Three-month mean (i.e., the three-month data capture Part 50, App A, Sec 4 rate) 75% Reporting Units All Filters µg/m3 at local temperature and pressure. Part 50, App R Rounding Convention 3-month arithmetic mean quarterly Report data to 3 decimal places (data after 3 are truncated. Part 50, App R Lower Detectable Limit Atomic Absorption 0.07 µg/m3 Part 50, App G, Sec 2.3 Verification/Calibration Standards and Recertifications All standards should have multi-point certifications against NIST-traceable standards Flow Rate Transfer Std. Field Thermometer Field Barometer 1/yr 1/yr 1/yr Resolution 0.02 m3/min ± 2% reproducibility 2 C resolution ± 5 mm Hg resolution Part 50, App B, Sec 7.8 Part 50, App B, Sec 7.5 Part 50, App B, Sec 7.6 Analytical Standards Reagents (HNO 3 and HCL) Pb nitrate Pb (NO 3) 2 ACS reagent grade ACS reagent grade (99.0% purity) Part 50, App G, Sec.6.2 Part 50, App G, Sec.6.2 Verification/Calibration Clock/timer Verification 4/year 5 min/mo recommendation Precision Single analyzer Single analyzer Primary Quality Assurance Org. Bias Performance Evaluation Program (PEP) SD = Standard Deviation CV = Coefficient of Variation 1/3 mo. 1/ yr Annual and 3 year estimates 5 audits for PQAOs with < 5 sites 8 audits for PQAOs with > 5 sites Coefficient of variation (CV) 20% CV 20% 90% CL of CV 20% recommendation recommendation Part 58, App A, Sec % CL Absolute bias ± 15% Part 58, App A, Sec 2.3.1

24 7.2.1 General Data Quality Objectives All criteria data should be traceable to a National Institute of Science and Technology (NIST) primary standard. All data shall be of a known and documented quality. The level of quality required for each specific monitoring project shall be established during the initial planning stages of the project and will depend upon the data s intended use. Two major measurements used to define quality are precision and bias. Refer to Section 7.2 for definitions of the metrics precision and bias. All data shall be comparable. This means all data shall be produced in a similar and scientific manner. The use of the standard methodologies for sampling, calibration, auditing, etc. found in the QAPP should achieve this goal. All data shall be representative of the parameters being measured with respect to time, location, and the conditions from which the data are obtained. The use of the standard methodologies contained in the QAPP should ensure that the data generated are representative. Ideally, a 90% confidence level of the coefficient of variation for precision and a ±20% difference or better between the actual amount of an introduced parameter (to a measurement system) and the indicated response of the measurement system for bias should be maintained. The QAPP must be dynamic to continue to achieve its stated goals as techniques, systems, concepts, and project goals change Specific Data Quality Objectives (NAAQS) The purpose regarding ambient air lead monitoring in Florida is to determine whether or not the primary and secondary rolling three month average NAAQS of 0.15 µg/m 3 are exceeded. 7.3 Network Scale Representativeness is defined as a measure of the degree to which data accurately and precisely represent a selected characteristic of a monitored system. Support in achieving representativeness is provided through adhering to the requirements provided in: 40 CFR Part 58, Appendix D (Network Design Criteria For Ambient Air Quality Monitoring); and 40 CFR Part 58, Appendix E (Probe and Monitoring Path Siting Criteria for Ambient Air Quality Monitoring).

25 Each monitor operated is assigned a scale of representativeness based on the definitions of 40 CFR Part 58, Appendix D. The following scales are used in the ambient air quality lead monitoring network: Micro Scale - describes air volumes associated with area dimensions ranging from several meters up to about 100 meters (m). Middle Scale - describes air volumes associated with area dimensions up to several city blocks in size with dimensions ranging from about 100 m to 500 m (0.1 to 0.5 kilometers [km]). Neighborhood Scale - describes air volumes associated with an area of a city that has relatively uniform land use with dimensions in the 500 m to 4,000 m (0.5 to 4.0 km) range.

26 8 TRAINING REQUIREMENTS Adequate education and training are integral to any monitoring program that strives for reliable and comparable data. Training is aimed at increasing the effectiveness of employees and their organization. As part of a QA program, 40 CFR Part 58, Appendix A requires the development of operational procedures for training. These procedures should include information on: Personnel qualifications general and position-specific Training requirements by position Training frequency Air monitoring personnel training consists of required reading prior to implementing the requirements of this QAPP. Documents required to be read shall include this QAPP, manufacturer-supplied manuals, and the standard operational procedures (SOPs) specific to the equipment personnel will be working with or servicing. All employees are actively encouraged to pursue training opportunities whenever possible and as needed. Because Florida s ambient air monitoring network is growing, new equipment, procedures, and personnel are added periodically. The department provides training for its personnel when new equipment is obtained. Additionally, personnel are encouraged to periodically identify, request, and attend pertinent courses and seminars. These courses and seminars may be provided as videotapes, closed circuit transmission, web based real-time interactive formats, and/or live instruction. Organizations that provide these training opportunities include local and regional universities, the Air and Waste Management Association, the Division of Air Resource Management, the Southeastern States Air Resource Managers (SESARM), and the EPA. Air monitoring personnel have sufficient training to currently perform necessary functions at an acceptable level. Existing monitoring staff provides new monitoring personnel and local station operators the necessary onthe-job training related to their individual monitoring tasks.

27 9 DOCUMENTATION AND RECORDS For the ambient air monitoring program, there are numerous documents and records that need to be retained. A document, from a records management perspective, is a volume that contains information which describes, defines, specifies, reports, certifies, or provides data or results pertaining to environmental programs. As defined in the Federal Records Act of 1950 and the Paperwork Reduction Act of 1995, records are...books, papers, maps, photographs, machine readable material, or other documentary materials, regardless of physical form or characteristics, made or received by an agency of the United States Government under Federal Law or in connection with the transaction of public business and preserved or appropriate for preservation by that agency or its legitimate successor as evidence of the organization, functions, policies, decisions, procedures, operations, or other activities of the Government or because of the informational value of the data in them... The following information describes the department s document and records procedure for the ambient air quality lead monitoring program. The documents and records pertaining to all data required to be collected and all other data deemed necessary, including documents and records required to support the concentration data reported to the EPA, are listed in Table Information Included in the Reporting Package Routine Data Activities Florida agencies maintain records in appropriate files that allow for the efficient archival and retrieval of said records. Lead ambient air quality information is included in this system. Table 9-1 includes the documents and records that are filed according to the statute of limitations discussed in Section Quarterly Data Submittal to EPA Florida submits quarterly data, as specified in 40 CFR Part 58, to the EPA directly via AQS data entry. These data shall be submitted no later than 90 days following the close of each calendar quarter, as specified in 40 CFR Section The quarterly data submittal shall contain the following data: the city name (if applicable), county name, site location street address, and measurement scale of each monitoring station; the AQS site code, monitoring method code, and POC; the results of all valid precision, bias, and accuracy tests performed during the quarter; all ambient air quality data obtained on lead; and information specified by the AQS Users Guide, Volume II, Air Quality Data Coding, and Volume III, Air Quality Data Storage, and the location, date, pollution source, and duration of incidents of ambient level exceedances.

28 9.1.3 Annual Summary Reports Submitted to EPA Florida shall submit to the EPA an annual summary report of all the lead monitoring data from all monitoring stations designated as SLAMS, in accordance with 40 CFR Section The report will be submitted by May 1 of each year for the data collected from January 1 through December 31 of the previous year. The report shall be certified accurate, to the best of his/her knowledge, by Florida s senior air pollution control officer or his/her designee, as specified in 40 CFR Section This certification is based on the various assessments and reports performed by the organization, in particular, the annual QA report discussed in Section 21 that documents the quality of the lead data and the effectiveness of the quality system. The report contains the following information: lead monitoring data; the city name (if applicable), county name, site location street address, and measurement scale of each monitoring station; the AQS site code, monitoring method code, and POC; a list, by pollutant, of all monitoring sites in the state; the location, date, pollution source, and duration of each incident of air pollution during which ambient levels of a pollutant reached or exceeded the levels specified by 40 CFR Part 51, Appendix L, as a level which could cause significant harm to the health of persons. 9.2 Data Reporting Package Format and Documentation Control Table 9-1 lists the documents and records that must be included in the reporting package. The details of these various documents and records will be discussed in the appropriate sections of this document. All raw data required for calculations, the submissions to the AQS database, and QA/QC data shall be collected electronically or on data forms that are included in the field and analytical methods, see Section 11. All hardcopy information shall be filled out in indelible blue or black ink. Corrections shall be made, also in ink, by inserting one line through the incorrect entry, initialing and dating this correction, and placing the correct entry alongside the incorrect entry, if this can be accomplished legibly, or by providing the information on a new line if the above is not possible Logbooks / Electronic Folders Each field and laboratory technician is responsible for obtaining the appropriate field documents. These documents will be numbered and associated with a specific monitor and monitoring site. The documents will be used to record information about the site and laboratory operations, as well as to document routine operations. Documents in paper form will be organized by specific monitor, monitoring site, and/or program in Field Logbooks. Documents in electronic form will be organized by specific monitoring site, monitor, and/or program in electronic folders. Data Entry Form Data entry forms will be used for each monitor, monitoring site, or specific program.

29 Paper (Hard) Copies Each set of paper (hard copy) data entry forms should be bound in a binder and kept with the associated monitor, at the associated monitoring site, or with the associated program as appropriate. Electronic Copies Each set of electronic data entry forms should be kept on the site computer, if available, at the location of the monitor. If not available, the electronic copies will be kept in a central repository on a computer or, preferably, network at an office of the associated program. Field Logbooks Logbooks will be used for each monitor, monitoring site, or program. Each logbook should be a three-ring binder. Each logbook will contain the appropriately associated data entry forms. Lab Logbooks Laboratory-related Section Under Construction 9.3 Data Reporting Package Archiving and Retrieval All the information listed in Table 9-1 will be retained for a minimum of ten (10) years from December 31 st of the year of collection or production in accordance with applicable state regulations. However, if any litigation, claim, negotiation, audit, or other action involving the records has been started before the expiration of the ten-year period, the records will be retained until completion of the action and resolution of all issues which arise from it, or until the end of the regular ten year period, whichever is later. Any and all of these reports may be retained as or in protected electronic format.

30 Table 9-1 Reporting Package Information Categories Record/Document Type File Locations Management and Organization Site Information Environmental Data Operations Raw Data Data Management Quality Assurance State Implementation Plan Reporting Agency Information Organizational Structure Quality Management Plan Document Control Plan EPA Directives Grant Allocations Support Contracts Site Files Site Maps Site Pictures Quality Assurance Project Plans Standard Operating Procedures Field and Laboratory Notebooks Sample Handling/Custody Records Inspection/Maintenance Records Any Original Data (routine and quality control) Including Data Entry Forms Data Management Systems Pollutant Data Meteorological Data Good Laboratory Practices Network Reviews Control Charts Data Quality Assessments Quality Assurance Reports Technical System Audits Response/Corrective Action Reports Site Audits

31 10 NETWORK DESCRIPTION The purpose of this section is to: identify all of the relevant components of the SLAMS lead monitoring network to be operated within the State of Florida, including the network design for evaluating the quality of the data; outline the network s objectives; establish the criteria for: sampling network design and monitoring site selection; identify the intended sampling frequency; identify the types of samplers used at each site; and identify the location and frequency of the FRM performance evaluations (this latter area is to be formally conducted by the EPA Region 4 as part of the Performance Evaluation Program). The primary function of the air monitoring program is to verify compliance with the NAAQS. Other purposes include determining trends over time, determining effects on air quality from adjustments to source emissions, developing algorithms based on historical air quality and other conditions which will allow forecasting of air quality, verifying air quality modeling programs, providing real-time pollutant data to the public, and correlating health effects to air quality levels. Sampling network design and monitoring site selection comply with the following: 40 CFR Part Monitoring Network Completion 40 CFR Part 58, Appendix A - Quality Assurance Requirements for SLAMS, SPMs and PSD Air Monitoring 40 CFR Part 58, Appendix D - Network Design for Ambient Air Quality Monitoring 40 CFR Part 58, Appendix E Probe and Monitoring Path Siting Criteria for Ambient Air Quality Monitoring 10.1 Network Objectives The ambient air quality lead monitoring network is designed to meet the following two basic monitoring objectives: determine representative concentrations in areas of high population density and determine the impact of significant sources or source categories on ambient pollution levels The department utilizes the network design criteria specified in 40 CFR Part 58, Appendix D, to establish the appropriate network configuration necessary to meet these objectives.