A1.1 Prefacedept.ceer.utexas.edu/ceer/ccaqp/PDF/QAReports/COCP QAPP... · 2011-10-31 · Quality Assurance Project Plan Revision No. 0 Page 1 of 6 11/05 A1.1 Preface . This Quality

The University of Texas at Austin Section A1 United States District Court Corpus Christi Air Monitoring and Surveillance Camera Network Project Quality Assurance Project Plan

Revision No. 0 Page 1 of 6 11/05

A1.1 Preface

This Quality Assurance Project Plan (QAPP) is submitted in partial fulfillment of the Corpus Christi Air Monitoring and Surveillance Camera Installation and Operation Project contract issued by the U.S. District Court, Corpus Christi, Texas to The University of Texas at Austin, Center for Energy and Environmental Resources under United States District Court CR. NO. C-00-325. It has been prepared in accordance with the Environmental Protection Agency QA-R5 document format for National Air Monitoring Stations/State and Local Air Monitoring Stations (NAMS/SLAMS) and Photochemical Assist Monitoring Stations (PAMS). In this regard, the most current versions (at the time of initial preparation) of the Texas Commission on Environmental Quality (TCEQ) NAMS/SLAMS/PAMS QAPPs for air monitoring in Texas have been used as the basis for this document. It is expected that during the life of this project, the requirements of this QAPP will always meet or exceed the TCEQ NAMS/SLAMS/PAMS QAPPs for air monitoring in Texas. Contact: Vincent M. Torres (512/471-5803) Project Manager Corpus Christi Air Monitoring and Surveillance Camera Installation and Operation Mailing Address: The University of Texas at Austin Center for Energy & Environmental Resources (R7100) 10100 Burnet Road, EME (Bldg 133) Austin, TX 78758

The University of Texas at Austin Section A1

United States District Court Corpus Christi Air Monitoring and Surveillance Camera Network Project

Quality Assurance Project Plan


A1.2 Approval Page

Assistant Deputy Chief U. S. District Court Corpus Christi, Texas

Sheila Johnson

Date

Laboratory and Mobile Monitoring Section Leader Monitoring Operations Division Texas Commission on Environmental Quality

David Brymer

Date

Special Projects Coordinator Monitoring Operations Division Texas Commission on Environmental Quality

Ken Rozacky

Date

Air Section Manager Region 14 Texas Commission on Environmental Quality

David Turner

Date

Air Section Leader Region 14 Texas Commission on Environmental Quality

Dave Kennebeck

Date





A1.2 Approval Page (Continued)

Advisory Board Representative Corpus Christi Air Monitoring and Surveillance Camera Installation and Operation Project Corpus Christi, Texas

Ron Barnard

Date






Principal Investigator Corpus Christi Air Monitoring and Surveillance Camera Installation and Operation Project The University of Texas at Austin Austin, Texas

David T. Allen, Ph.D.

Date

Project Manager Corpus Christi Air Monitoring and Surveillance Camera Installation and Operation Project The University of Texas at Austin Austin, Texas Project Quality Assurance Officer Corpus Christi Air Monitoring and Surveillance Camera Installation and Operation Project The University of Texas at Austin Austin, Texas

Vincent M. Torres, P.E., M.S.E. Dave Sullivan, Ph.D.

Date Date






Project Representative/ Project Manager Corpus Christi Air Monitoring and Surveillance Camera Installation and Operation Project Air Quality Solutions, Inc. Austin, Texas

Rogelio C. Ramon, M.S.E.

Date

Project Quality Assurance Officer Corpus Christi Air Monitoring and Surveillance Camera Installation and Operation Project Air Quality Solutions, Inc. Austin, Texas

Barry Sterling

Date





Project Manager Corpus Christi Air Monitoring and Surveillance Camera Installation and Operation Project Orsat, L.L.C. Austin, Texas

Carol Meyer

Date

Quality Assurance Officer Corpus Christi Air Monitoring and Surveillance Camera Installation and Operation Project Orsat, L.L.C. Austin, Texas

Bill Geiger

Date


TABLE OF CONTENTS

Section Title Pages Revision Date


PROJECT MANAGEMENT

A1 Title and Approval Sheets 6 0 11/05 A1.1 Preface A1.2 Approval Page

A2 Table of Contents 10 0 11/05 A2.1 List of Figures A2.2 List of Tables A2.3 List of Appendices

A3 Distribution List 1 0 11/05

A4 Project/Task Organization 7 0 11/05 A4.1 Project Sponsor A4.2 Texas Commission on Environmental Quality (TCEQ) A4.3 Principal Investigator and Project Manager A4.4 Project Quality Assurance (QA) Officer A4.5 Monitoring Station Operations and Maintenance A4.6 VOC Canister Analysis A4.7 Monitoring Data Management and Validation A4.8 Statistical Support A4.9 Subcontractors

A5 Problem Definition/Background 2 0 11/05 A5.1 Overview A5.2 Conclusions to be Made A5.3 Uses of Data A5.4 Decision Makers A5.5 Principal Customers for the Results

A6 Project/Task Description 4 0 11/05 A6.1 Project Overview A6.2 Sampling Activities A6.3 Standards and Screening Levels A6.3.1 NAAQS A6.3.2 Effects Screening Levels (ESL) A6.4 Assessment Tools A6.4.1 Technical Systems Audits A6.4.2 Performance Evaluations A6.5 Project Reports

A7 Data Quality Objectives (DQO) for Measurement Data 5 0 11/05 A7.1 General Project Objective A7.2 Network Specific Objectives A7.3 Conclusions to be Made A7.4 Uses of Data A7.5 Measurement Quality Objectives A7.5.1 Detection Limits A7.5.2 System Contribution to the Measurement A7.5.3 Precision A7.5.4 Accuracy A7.5.5 Completeness


TABLE OF CONTENTS



A7.5.6 Representativeness A7.5.7 Comparability

A8 Special Training Requirements/Certification 1 0 11/05

A9 Documentation and Records 2 0 11/05 A9.1 Mechanisms for Documentation of Procedures and Objectives A9.2 Mechanisms for Record Keeping A9.3 Data Reporting Turnaround Time A9.4 Data Storage

MEASUREMENT/DATA ACQUISITION

B1 Sampling Process Design (Experimental Design) 1 0 11/05 B1.1 Network Design B1.2 Network Design Rationale B1.3 Measurement Validation

B2 Sampling Methods Requirements 6 0 11/05 B2.1 Continuous Methods B2.1.1 Sulfur Dioxide (SO2) B2.2.2 Hydrogen Sulfide (H2S) B2.1.3 Time Lapse Video B2.1.4 Meteorological Measurement Systems B2.1.5 Volatile Organic Compound (VOC) Continouous

Gas Chromatograph (GC) Sampling

B2.1.6 Continuous FID Methane/Non-methane B2.2 Noncontinuous Methods B2.2.1 VOC Canister Sampling B2.3 Corrective Actions

B3 Sample Handling and Custody 4 0 11/05 B3.1 Documentation and Custody Requirements B3.1.1 Sulfur Dioxide (SO2) B3.1.2 Hydrogen Sulfide (H2S) B3.1.3 Meteorological Measurement Systems B3.1.4 Continuous Gas Chromatograph B3.1.5 Continuous FID Methane/Non-methane B3.1.6 Volatile Organic Compounds (VOCs), Canister

Samples

B3.1.6.1 Transfer from the UT Austin CEER Laboratory to Subcontractor’s Field Office

B3.1.6.2 Return from Subcontractor’s Field Office to UT Austin CEER Laboratory

B3.1.7 Time Lapse Video B3.2 Sample Handling Procedures B3.2.1 SO2 B3.2.2 H2S B3.2.3 Meteorological Measurement Systems


TABLE OF CONTENTS



B3.2.4 Continuous GC B3.2.5 Continuous FID Methane/Non-methane B3.2.6 VOCs, Canister Samples B3.2.7 Time Lapse Video

B4 Analytical Methods Requirements 4 0 11/05 B4.1 Analytical Procedures B4.1.1 Sulfur Dioxide (SO2) B4.1.2 Hydrogen Sulfide (H2S) B4.1.3 Meteorological Measurement Systems by U.S.

Environmental Protection Agency (EPA) Quality Assurance Handbook Volume IV Methodology

B4.1.4 Continuous Gas Chromatograph (GC) (Perkin Elmer GC/Flame Ionization Detector [FID]) for Volatile Organic Compounds (VOCs)

B4.1.5 Continuous FID Methane/Non-methane B4.1.6 EPA Method TO-15 Canisters for VOCs Collected

in Glass-Lined Stainless Steel Canisters

B4.1.7 Time Lapse Video B4.2 Corrective Actions B5

Quality Control (QC)

10 0 11/05

B5.1 Sulfur Dioxide (SO2) B5.2 Hydrogen Sulfide (H2S) B5.3 Meteorology B5.4 Continuous Gas Chromatograph (GC) B5.5 Continuous FID Methane/Non-methane B5.6 TO-15 Canister Volatile Organic Compounds (VOCs) B5.6.1 Sampler QC Checks B5.6.2 Analytical QC Checks in the UT Austin CEER

Laboratory

B5.5.2.1 Blank Analysis B5.5.2.2 MS Performance Check B5.5.2.3 Calibration Check B5.5.2.4 Analytical Precision B5.7 Time Lapse Video B5.8 Precision B5.9 Accuracy

B6 Instrument/Equipment Testing, Inspection, and Maintenance Requirements 3 0 11/05

B6.1 Instrument Testing/Inspection B6.2 Preventive Maintenance Procedures B6.2.1 Sulfur Dioxide (SO2) B6.2.2 Hydrogen Sulfide (H2S) B6.2.3 Time Lapse Video B6.2.4 Meteorological Measurement

Systems

B6.2.5 Continuous Gas Chromatograph (GC)

B6.2.6 Continuous FID Methane/Non-methane


TABLE OF CONTENTS



B6.2.7 Volatile Organic Compounds (VOC) Canister Samples

B6.2.8 Canister VOC Analysis B6.3 Corrective Maintenance Procedures B6.3.1 SO2 B6.3.2 Time Lapse Video B6.3.3 Meteorological Measurement Systems B6.3.4 Automated GC B6.3.5 Continuous FID Methane/Non-methane B6.3.6 VOC Canister Samplers B6.3.7 VOC Canister Analysis B6.4 Availability of Spare Parts

B7 Instrument/Equipment Calibration and Frequency 4 0 11/05 B7.1 Calibration B7.1.1 Sulfur Dioxide (SO2) B7.1.2 Hydrogen Sulfide (H2S) B7.l.3 Meteorological Equipment B7.1.4 Continuous Gas Chromatograph (GC) B7.1.5 Continuous FID Methane/Non-methane B7.1.6 Canister VOC Sampler B7.1.7 VOC Canister Samples B7.2 Traceability B7.2.1 SO2 B7.2.2 Hydrogen Sulfide (H2S) B7.2.3 Meteorological Equipment B7.2.4 Continuous GC B7.2.5 Continuous FID Methane/Non-methane B7.3 Documentation

B8 Inspection/Acceptance Requirements for Supplies and Consumables 1 0 11/05 B8.1 Sampling Supplies B8.2 Standards B8.3 Spare Parts

B9 Data Acquisition Requirements (Non-Direct Measurements) 1 0 11/05

B10 Data Management 6 0 11/05 B10.1 Sulfur Dioxide (SO2) B10.2 Hydrogen Sulfide (H2S) B10.3 Meteorological Data B10.4 Continuous Gas Chromatograpgh B10.5 Continuous FID Methane/Non-methane B10.6 Canister Volatile Organic Compound (VOC) Data B10.7 Time Lapse Video B10.8 Acceptability of the Hardware/Software Configuration B10.9 Data to Users

ASSESSMENT/OVERSIGHT


TABLE OF CONTENTS



C1 Assessments and Response Actions 10 0 11/05 C1.1 Technical Systems Audit C1.1.1 Field Technical Systems Audit C1.1.1.1 Assessment of Sulfur Dioxide (SO2) C1.1.1.2 Assessment of Hydrogen Sulfide

(H2S)

C1.1.1.3 Assessment of Meteorological Equipment

C1.1.1.4 Assessment of Continuous Gas Chromatograph (GC)

C1.1.1.5 Assessment of Continuous FID Methane/Non-methane

C1.1.1.6 Assessment of Volatile Organic Compound (VOC) Canister Samples

C1.1.1.7 Assessment of Time Lapse Video C1.1.2 Field Inspections C1.1.3 Laboratory Technical Systems Audit C1.2 Performance Evaluations C1.2.1 Field Assessment C1.2.1.1 SO2 C1.2.1.2 H2S C1.2.1.3 Meteorological Equipment C1.2.1.4 Continuous GC C1.2.1.5 Continuous FID Methane/Non-

methane

C1.2.1.6 VOC Canister Analysis C1.2.1.7 Time Lapse Video C1.2.2. Laboratory Assessment C1.3 Assessment of Data Quality Indicators C1.3.1 Specific Procedures to Assess Data Quality C1.3.1.1 Data Precision Assessment C1.3.1.1.1 SO2 C1.3.1.1.2 H2S C1.3.1.1.3 Meteorological Equipment C1.3.1.1.4 Continuous GC C1.3.1.1.5 Continuous FID

Methane/Non-methane

C1.3.1.1.6 VOC Canister Analysis C1.3.1.1.7 Time Lapse Video C1.3.1.2 Data Accuracy Assessment C1.3.1.2.1 SO2 C1.3.1.2.2 H2S C1.3.1.2.3 Meteorological Monitors C1.3.1.2.4 Continuous GC and

Canister VOC Sampling

C1.3.1.2.5 Continuous FID Methane/Non-methane

C1.3.1.3 Data Completeness Assessment C1.4 Audits of Data Quality C1.5 Corrective Actions


TABLE OF CONTENTS



C2

Reports to Management

2 0 11/05

C2.1 Quality Assurance (QA) Status Report C2.2 Annual Project QA Report C2.3 Data Reports C2.3.1 Field Activity Reports C2.3.2 Laboratory Activity Reports C2.4 Reporting Schedule

DATA VALIDATION AND USABILITY

D1 Data Review, Validation, and Verification Requirements 7 0 11/05 D1.1 Data Validation D1.1.1 SO2 D1.1.2 H2S D1.1.3 Continuous FID Methane/Non-methane D1.1.4 Time Lapse Video D1.1.5 Meteorological Measurement Systems D1.2 Data Custody D1.2.1 SO2 D1.2.2 H2S D1.2.3 Continuous FID Methane/Non-methane D1.2.4 Time Lapse Video D1.2.5 Meteorological Measurement Systems D1.2.6 UT Austin CEER Laboratory

D2 Validation and Verification Methods 3 0 11/05 D2.1 Sulfur Dioxide (SO2 ) D2.1.1 Quality Control Test Results Performed by the

MeteoStar Computer

D2.1.2 Laboratory Control Checks (LCC) D2.2 Hydrogen Sulfide (H2S) D2.2.1 Quality Control Test Results Performed by the

MeteoStar Computer

D2.2.2 Laboratory Control Checks (LCC) D2.3 Meteorological Equipment D2.4 Continuous Gas Chromatograph (GC) D2.5 Continuous FID Methane/Non-methane D2.5.1 Quality Control Test Results Performed by the

MeteoStar Computer

D2.5.2 Laboratory Control Checks (LCC) D2.6 Volatile Organic Compound (VOC) Canister Samples D2.7 Time Lapse Video D2.8 Data Review

D3 Reconciliation with User Requirements 6 0 11/05 D3.1 Detection Limits D3.2 Precision D3.2.1 Sulfur Dioxide (SO2) D3.2.2 Hydrogen Sulfide (H2S) D3.2.3 Meteorological Equipment D3.2.4 Continuous GC


TABLE OF CONTENTS



D3.2.5 Continuous FID Methane/Non-methane D3.2.6 Canister Volatile Organic Compounds D3.2.7 Time Lapse Video D3.3 Accuracy D3.3.1 SO2 D3.3.2 H2S D3.3.3 Meteorological Equipment D3.3.4 Continuous GC D3.3.5 Continuous FID Methane/Non-methane D3.3.6 Canister Volatile Organic Compounds D3.3.7 Time Lapse Video D3.4 Completeness


LIST OF FIGURES



A4 Figure A4.A Corpus Christi Air Monitoring and Surveillance

Camera Installation and Operations Project Organization

1 0 11/05

Figure A4.B TCEQ Organization (October 1, 2005) 1 0 11/05

B10 Figure B10 Sample/Data Flows and Storage

1 0 11/05


LIST OF TABLES



A6 Table A6.3.A National Ambient Air Quality Standards (NAAQS) 1 0 11/05

A6 Table A6.3.B Effects Screening Levels (ESLs) 1 0 11/05

A7 Table A7.5.7.A Reporting Units of Measurements 1 0 11/05

B2 Table B2.1.A Criteria Pollutants 1 0 11/05

Appx A Table A6.1 United States District Court Corpus Christi Air

Monitoring and Surveillance Camera Network 1 0 11/05

Appx A Table A6.2.A Overview of Sampling Matrix 1 0 11/05

Appx B Table A7 United States District Court Corpus Christi Air

Monitoring and Surveillance Camera Network Measurement Data Quality Objectives

6 0 11/05

Appx C Table B5 United States District Court Corpus Christi Air Monitoring and Surveillance Camera Network Quality Control Activities

15 0 11/05


LIST OF APPENDICES

Appendix Title Pages Revision Date


A Table A6.1 United States District Court Corpus Christi Air Monitoring

and Surveillance Camera Network 1 0 11/05

Figure A6.1 Map of Air Monitoring Site Locations 1 0 11/05

B Table A7.1 United States District Court Corpus Christi Air Monitoring

and Surveillance Camera Network Measurement Data Quality Objectives

6 0 11/05

C Table B5 United States District Court Corpus Christi Air Monitoring and Surveillance Camera Network Quality Control Activities

15 0 11/05

D Chain-of-Custody Form for Canister Samples 2 0 11/05

E

TCEQ Standard Operating Procedures 1 0 11/05

F Gas Standard Acceptance Test Limits 1 0 11/05

G Texas Commission on Environmental Quality (TCEQ) MeteoStar/LEADS Data Collection Model

1 0 11/05

H MeteoStar/LEADS Processing of CAMS QC Data 4/5/00 28 0 11/05

I TCEQ MeteoStar/LEADS Web Page Primer 17 0 11/05

J TCEQ Validation Codes for CAMS Data 1 0 11/05

K NAMS/SLAMS Data Validation Procedure for MeteoStar 10 0 11/05

L References 3 0 11/05

M Acronyms

5 0 11/05



A3 DISTRIBUTION LIST U.S. District Court Sheila Johnson, Assistant Deputy Chief, U.S. Probation Office, Corpus Christi, Texas U.S. Environmental Protection Agency Robert Todd, Chief, Compliance Assurance and Technical Enforcement Division, Region 6 Texas Commission on Environmental Quality– Central Office David Brymer, Manager, Laboratory and Mobile Monitoring Section, Monitoring Operations

Division Ken Rozacky, Ambient Monitoring Section, Monitoring Operations Division Texas Commission on Environmental Quality–Region 14 Corpus Christi, Texas Susan Clewis, Regional Director Jim Bowman, Air Section Manager Dave Kennebeck, Air Section Leader Corpus Christi Air Monitoring and Surveillance Camera Installation and Operation

Project

Advisory Board Gretchen Arnold Ron Barnard Eugene Billiot, Ph.D. Ardys Boostrom, MD Lena Coleman Vinay Dulip Glen Kost, Ph.D. Pat Suter

The University of Texas at Austin David T. Allen, Ph. D., Principal Investigator Vincent M. Torres, Project Manager Dave Sullivan, Ph. D., Project Quality Assurance Officer

Site Operations and Maintenance Contractors Rogelio Cantu Ramon MSE, Air Quality Solutions, Inc. Carol Meyer, Orsat, L.L.C.



A4 PROJECT/TASK ORGANIZATION

Monitoring for the Corpus Christi Air Monitoring and Surveillance Camera Installation and Operation Project is performed by The University of Texas at Austin and its contractors. The project organization is shown in Figure A4.A. The interrelationships and responsibilities of the participants in these projects are listed below:

A4.1 Project Sponsor Judge Janis Graham Jack, U.S. District Court, Corpus Christi, Texas • Sets the preliminary objectives for the project. • Allocates adequate resources to ensure completion of the project in compliance with

the stated objectives. • Defines the project team and organization • Determines the ultimate use of the data set developed from the project activities.

A4.2 Texas Commission on Environmental Quality (TCEQ) David Brymer, Lab & Mobile Monitoring Section Austin, Texas (Headquarters) • Review and approve the QAPP and any changes. • Approve the operating procedures. • Approve the monitoring network design and modifications. • Approve the relocation of monitoring sites. • Develop and maintain automated data collection, process management, and analysis

systems in support of air monitoring activities, data reporting, and data analysis.

A4.3 Principal Investigator and Project Manager David Allen and Vincent M. Torres, The University of Texas at Austin • Coordinate the monitoring operations of the project and is the primary contact person. • Coordinate air monitoring network activities between the TCEQ and the project • Coordinate the relocation of any monitoring site. • Provide project planning and coordinates the preparation of quarterly and annual

reports to the Project Sponsor. • Provide oversight of subcontractor work and approval of work products. • Ensure that all subcontractors are trained and qualified for the operations they

perform. • Prepare the QAPP for the project for review and approval by the TCEQ.

A4.4 Project Quality Assurance (QA) Officer Dave Sullivan, Ph.D., The University of Texas at Austin • Coordinate the QA activities for the project including QA activities with external

agencies and non-agency groups.



• Participate in the development, approval, implementation, and maintenance of written quality assurance documents (e.g, QMPs, SOPs, QAPPs).

• Perform project and laboratory technical systems audits. • Participate in the preparation of quality reports (e.g., annual reports). • Determine conformance with project quality system requirements. • Review and approve proposed corrective actions and verifications. • Monitor the implementation of corrective actions. • Report on the status of corrective action programs. • Assess the effectiveness of project quality systems. • Coordinate the identification, disposition, and reporting to management of

nonconforming items and activities. • Prepare and distribute annual quality assurance assessment schedules.

A4.5 Monitoring Station Operations and Maintenance

Rogelio C. Ramon, M.S.E., Barry Sterling, Mitchell Hines, Air Quality Solutions, Inc., Monitoring and Support Equipment at All Sites except for Auto GC Systems at Oak Park & Solar Estates

• Maintain the site, both inside the shelter and outside, clean, orderly and presentable to the public.

• Provides support to operate, maintain and repair the monitoring equipment. • Review and certify that all new equipment meets manufacturer’s specifications. • Monitor automated quality control checks and take corrective action when indicated. • Perform scheduled quality control checks on samplers, sampling equipment,

meteorological equipment, and surveillance cameras. • Assist quality assurance auditors with performance evaluations and technical systems

audits. • Perform scheduled preventive maintenance procedures • Record data/information as required in appropriate field/monitoring site logs. • Calibrate field samplers and meteorological equipment. • Perform calibration verification checks. • Maintain calibration equipment. • Participate in the development of updates and revisions to written quality assurance

standards (e.g., QMPs, SOPs, QAPPs). Carol Meyer, Bill Geiger, Orsat, L.L.C., Auto GC Systems (only) and Support Equipment

at Oak Park & Solar Estates • Maintain the site, both inside the shelter and outside, clean, orderly and presentable to

the public. • Provide support to operate, maintain and repair the monitoring equipment. • Review and certify that all new equipment meets manufacturer’s specifications.



• Monitor automated quality control checks and take corrective action when indicated. • Perform scheduled quality control checks on samplers and sampling equipment. • Assist quality assurance auditors with performance evaluations and technical systems

audits. • Perform scheduled preventive maintenance procedures • Record data/information as required in appropriate field/monitoring site logs. • Calibrate field samplers. • Perform calibration verification checks. • Maintain calibration equipment. • Participate in the development of updates and revisions to written quality assurance

standards (e.g., QMPs, SOPs, QAPPs).

A4.6 VOC Canister Analysis

Jarett Spinhirne, The University of Texas at Austin • Purchases, tests, and maintains all analytical equipment in the laboratory for the

analysis of VOC canister samples collected for the project. • Maintain the lab clean, orderly and presentable to the public. • Provide support to operate, maintain and repair the analysis equipment. • Review and certify that all new equipment meets manufacturer’s specifications. • Monitor automated quality control checks and takes corrective action when indicated. • Perform scheduled quality control checks on GC/FID. • Assist quality assurance auditors with performance evaluations and technical systems

audits. • Perform scheduled preventive maintenance procedures. • Record data/information as required in appropriate laboratory logs. • Calibrate the GC/FID and GC/MS equipment. • Perform calibration verification checks. • Maintain calibration equipment. • Participate in the development of updates and revisions to written quality assurance

standards (e.g., QMPs, SOPs, QAPPs). • Maintain documentation for all sampling and analytical activities. • Train laboratory personnel hired for this project. • Validate canister VOC data to level 1 validation. Dave Sullivan Ph.D., The University of Texas at Austin • Provide higher level validation of VOC data. • Send canister VOC data to the TCEQ Data Management Technology Team. • Maintain custody of canister VOC data.



A4.7 Monitoring Data Management and Validation Rogelio C. Ramon, Barry Sterling, Joe Paredes, Air Quality Solutions, Inc., Monitoring

and Support Equipment at All Sites except for Auto GC Systems at Oak Park & Solar Estates

• Validate meteorological data. • Validate monitoring data using the TCEQ MeteoStar manual validation system, AQS

data screens and reports, and a variety of analysis tools for higher levels of long-term data validation.

• Provide technical support on data management issues that may arise. • Document all data management activities.

Carol Meyer, Bill Geiger, Orsat, L.L.C., Auto GC Systems (only) and Support Equipment

at Oak Park & Solar Estates • Validate meteorological data. • Validate data using the TCEQ MeteoStar manual validation system, AQS data screens

and reports, and a variety of analysis tools for higher levels of long-term data validation.

• Provide technical support on data management issues that may arise. • Document all data management activities.

A4.8 Statistical Support Rogelio C. Ramon and Barry Sterling, Air Quality Solutions, Inc., Monitoring and

Support Equipment at All Sites except for Auto GC Systems at Oak Park & Solar Estates

• Provide statistical evaluation of monitoring data to assist in investigating air pollution episodes.

• Provide statistical evaluation of monitoring data to quality assure data. Carol Meyer, Bill Geiger Orsat, L.L.C., Auto GC Systems (only) and Support Equipment

at Oak Park & Solar Estates • Provide statistical evaluation of monitoring data to assist in investigating air pollution

episodes. • Provide statistical evaluation of monitoring data to quality assure data. Jarett Spinhirne, Dave Sullivan Ph. D., The University of Texas at Austin, VOC Canister

Analysis • Provide statistical evaluation of canister VOC analytical data to assist in investigating

air pollution episodes. • Provide statistical evaluation of canister VOC analytical data to quality assure data.



A4.9 Subcontractors Mr. Rogelio Ramon, Project Representative Air Quality Solutions, Inc. (AQSI) 1301 South IH35, Suite 107 Austin, Texas 78741

Ms. Carol Meyer, Project Representative Orsat, L.L.C. 1416 E. Southmore Ave. Pasadena, Texas 77502

According to terms of the contract, responsibilities include but are not limited to:

• Operate and maintain monitoring sites and sampling equipment according to this approved QAPP.

• Perform scheduled quality control checks on samplers, sampling equipment, and meteorological equipment as specified on the TCEQ Ambient Air Quality Network Field Quality Control Manual.

• Calibrate and maintain field samplers and other equipment. • Perform data validation according to TCEQ’s data validation Standard Operation

Procedures (SOPs). • Assist project QA officer or their designee with performance evaluations and

technical systems audits. According to terms of the contract, contractor’s communications responsibilities include, but are not limited to:

• Maintain an open line of communication between The University of Texas Project Representatives, TCEQ Personnel, and other subcontractors.

• Attend and provide information if requested to all necessary meetings that may or may not be requested by The University of Texas Project Representatives and TCEQ Personnel.

The types and frequency of communications include:

• Weekly on-site meetings between subcontractors and the Project Manager. • Cell phone, land-line, and e-mail exchanges several times per week among The

University of Texas Project Representatives, TCEQ Personnel, and subcontractors. • Intermittent meetings among The University of Texas Project Representatives, TCEQ

Personnel, and subcontractors. • Written reports on work done submitted by subcontractors.

The Project manager and Quality Assurance Officer monitor the subcontractors through these communications, and by viewing data collected and accessed through the TCEQ Web pages on a weekly basis. These data include ambient pollution and meteorological readings, calibration and span results, operator logs, and validation notes.



Figure A4.A Corpus Christi Air Monitoring & Surveillance Camera Installation

and Operation Project Organization

Site Operations & Maintenance

Sub-Contractor

AQSI &

Orsat

Data Validation -------------------------------

Data Collection

Site Operations & Maintenance

Sub-Contractor

AQSI &

Orsat

Data Validation -------------------------------

Data Collection

Canister Analysis

UT Austin

Data Validation ------------------------------- Lab GC/FID Analysis

EPA

Robert M. Todd (R6)

TCEQ

Susan Clewis (R14) David Turner (R14)

David Brymer (Hdqtrs.)

Volunteer Advisory

Board

Gretchen Arnold Ron Barnard Eugene Billiot

Ardys Boostrom Lena Coleman

Vinay Dulip Glen Kost Pat Suter

U.S. District Court Project Sponsor

Janis Graham Jack, U.S. District Judge

Sheila Johnson, Assist. Deputy Chief U.S. Probation Officer

The University of Texas @ Austin

Center for Energy & Environmental Resources (CEER)

David T. Allen, Principal Investigator

Project Support Personnel

Vincent M. Torres, Project Manager MaryAnn Foran, Contract Manager Denzil Smith, Web Site Manager

Dave Sullivan, Project QA Officer



TCEQ ORGANIZATION

September 13, 2005

Figure A4.B TCEQ Organization (October 1, 2005)



A5 PROBLEM DEFINITION/BACKGROUND

A5.1 Overview The United States District Court for the Southern District of Texas and the Texas Commission on Environmental Quality (TCEQ) awarded The University of Texas at Austin’s Center for Energy and Environmental Resources $6,700,000 to implement the Corpus Christi Air Monitoring and Surveillance Camera Installation and Operation Project. This project was the result of a court ordered condition of probation and was selected from a number of projects considered by the court. In evaluating the proposed projects, the selection process focused on three essential criteria:

1. Environmental concerns of the citizens of Corpus Christi related to releases and spills of volatile organic compounds, such as benzene, and sulfur compounds;

2. TCEQ and EPA policies and guidelines for supplemental environmental projects and Department of Justice sentencing guidance applicable to beneficial environmental projects, also known as Community Service Projects (CSPs), which incorporates EPA policies and guidelines; and

3. Evaluation of the projects to ensure that they met the description in the plea agreement of an air or water quality remediation project.

The primary air quality concern in the Corpus Christi area is health impacts from industrial sources. This project will provide data that will help address this concern. So that the public can have access to this data in a timely manner, data from these air monitoring sites will be made available via the internet as soon as possible after it becomes available electronically, depending on the type of measurement and sample analysis required. Although this project will have a finite length, it is expected that the project will produce benefits long after the project has ended by providing data that will allow air monitoring resources to be more effectively selected, deployed, and utilized after the project terminates.

A5.2 Conclusions to be Made 1. Data collected from this air monitoring and surveillance camera network are used to provide

a post-event evaluation of the transport of chemical pollutants and their species and concentration in the ambient air in the vicinity of each monitoring site during a release or event.

2. The measured pollutant concentration levels are compared to TCEQ health effects screening levels (ESLs) for toxic pollutants. The ESLs were established by the TCEQ staff to evaluate the potential health effects from exposure to air pollution. The TCEQ reviews monitoring data to determine potential risks from short-term exposure to compounds that exceed the 24-hour ESL and long-term exposure to compounds that exceed the annual ESL.

3. Data collected from this air monitoring and surveillance camera network are used to determine potential chemical pollutant sources upwind of the monitoring site along the Corpus Christi ship channel.



A5.3 Uses of Data The potential uses of the data are listed below: • To determine compliance with TCEQ effects screening levels • To investigate (TCEQ and EPA) and remediate air quality concerns that can impact

health • To identify and track potential hazardous compounds that are known to be highly toxic

and identify the point or area sources. • To determine if air pollutants are a possible contributing factor to reported health

problems • To assess the temporal variations of air pollutants and track the point or area source. • To identify statistically significant trends of ambient air pollutants • To activate emergency control procedures that prevent or alleviate air pollution episodes • To provide a database for planning, development, and evaluation of abatement strategies

and evaluation of diffusion models • To determine if additional air pollution control strategies are required • To provide visual air pollution monitoring information

A5.4 Decision Makers • Judge Janis Graham Jack, US District Judge, US District Court for the Southern District of

Texas, Corpus Christi Division • Mr. David Brymer, TCEQ Section Manager of Lab and Mobile Monitoring, Monitoring

Operations Division • Ms. Susan Clewis, TCEQ Director of Field Operations, Region 14 • Dr. David Allen, The University of Texas at Austin • Members of the Advisory Board for this Project

A5.5 Principal Customers for the Results • Corpus Christi area citizens • TCEQ • US District Court for the Southern District of Texas, Corpus Christi Division • The University of Texas at Austin • Local city and county health departments • Texas citizens



A6 PROJECT/TASK DESCRIPTION

This section provides a description of the work to be done, an overall view of the project objectives, activities, assessments, and outputs of the project, identification of applicable ambient air quality regulations and standards, and an implementation schedule for the project. The measurements to be made during the project are identified in Table A6.2.A. Measurements are expected to be made in compliance with the current guidance where it exits. This guidance includes but is not limited to Title 40 Code of Federal Regulation (CFR) Part 50, 53, and 58 (Appendix B), U.S. Environmental Protection Agency (EPA) Quality Assurance Handbook for Air Pollution Measurement Systems (Volumes I, II, and IV), and EPA Technical Assistance Document for Sampling and Analysis of Ozone Precursors.

The data collection period for this project will be approximately seven years. Sampling periods for each method are indicated in Table A6.2.A.

A6.1 Project Overview The University will install, maintain and operate an air monitoring and surveillance camera

network along the Corpus Christi ship channel to record the concentrations of specific air pollutants along this industrial area. The University will install at least seven, air monitoring stations and two surveillance cameras along the ship channel. The air monitoring stations are to record concentrations of hydrogen sulfide (total reduced sulfur), sulfur dioxide and volatile organic compounds, including benzene, and meteorological data per the Table A6.1 in Appendix A. A map of the air monitoring site locations is shown in figure A6.1.

Data obtained from the monitors will be made available to the public via the TCEQ website

(Internet) and the UT Austin’s project website. Additionally, access to view the images captured by the surveillance cameras will be made available to the public via UT Austin’s Project website. The Project started October 2, 2003 and will continue for seven years or longer, depending on the available project funds.

Dr. David T. Allen, Director of The University of Texas at Austin’s Center for Energy and

Environmental Resources, will serve as the Principal Investigator for this Project. Essential to the performance of the project is the involvement of TCEQ’s Director of Field Operations Region 14 and the TCEQ’s Section Manager of Lab and Mobile Monitoring, Monitoring Operations Division, Office of Compliance and Enforcement. A very important component of this project is the voluntary Advisory Board. The Board will review project plans and consult on project implementation, including the selection of the exact monitoring locations, types of equipment, and implementation schedules.

A6.2 Sampling Activities The general sampling activities of the project are detailed in Table A6.2.A. See Tables

A6.2.B and A6.2.C in Appendices A and B for site sampling details.



Table A6.2.A Overview of Sampling Matrix

Target Compound/Group Analytical Method Sampling Period Frequency

Sulfur Compounds Sulfur Dioxide (SO2) Fluorescence 5 min Continuous Hydrogen Sulfide Fluorescence 5 min Continuous Hydrocarbon Compounds Methane and Total Non-Methane Hydrocarbons

Flame Ionization Detector 70 sec averaged over

5 min.

Continuous

VOCs by Canister Sampling (See Table A7, Appendix B)

Gas Chromatograph/Mass Spectrometer

Variable Event Triggered

VOCs by Auto GC Sampling (See Table A7, Appendix B)

Dual Flame Ionization Detector/Gas Chromatograph

40 min Continuous

Surveillance Camera Visible chemical emissions Time Lapse Video 30 frames/min Continuous Meteorology Wind Direction* Single Potentiometer Vane 5 min Continuous Wind Speed* Cup Anemometer 5 min Continuous Temperature Aspirated Thermister 5 min Continuous Relative Humidity Capacitive Relative Humidity 5 min Continuous * Wind direction and wind speed data outputs from the Zeno datalogger include: vector average wind direction, immediate wind direction, standard deviation of wind direction, vector average wind speed, average wind speed, and immediate wind speed.

A6.3 Standards and Screening Levels SO2 is regulated by the EPA.

A6.3.1 NAAQS

The NAAQS listed in Table A6.3.A are health-based standards promulgated by the EPA. The levels are established such that concentrations below them are not expected to cause adverse health impacts. Data for pollutants that have NAAQS designation are compared to these standards.

Table A6.3.A National Ambient Air Quality Standards (NAAQS) Pollutant

Parameter Standard Averaging Time

SO2 0.14 ppm*

0.030 ppm*

24 hours

Annual arithmetic average

* ppm on volume basis

A6.3.2 Effects Screening Levels

The ESL is established by the TCEQ's Toxicology and Risk Assessment Section. These guidelines are used by TCEQ staff to evaluate the effects of toxics air pollutants that currently do not have health-based standards for ambient air measurements. Some of the toxic compounds being measured in the Corpus Christi Air Monitoring and Surveillance Camera Installation and



Operation Project are included in EPA's list of National Emissions Standards for Hazardous Air Pollutants (NESHAP). Table A6.3.B lists the short- and long-term ESLs effective September 5, 1997, for the chemicals that are monitored and that are part of the EPA’s list of NESHAPs.

Table A6.3.B Effects Screening Levels (ESLs)

Pollutant

Parameter Short-Term ESL (ug/m3) (1 hour) Long-Term ESL (ug/m3) (Annual)

This Section is Under Review

* ESL is under review.

A6.4 Assessment Tools Assessment tools that will be used are described in this section.

A6.4.1 Technical Systems Audits

Field technical systems audits shall be conducted annually, at a minimum, and more frequently if deemed necessary, on all monitoring systems by the project Quality Assurance officer or designee. These audits are described in Section C1.1 of this plan.

A6.4.2 Performance Evaluations

Performance evaluations are to be performed on critical parts of the monitoring systems in order to assess the accuracy of the data as stated in Section C1.2 of this plan. Performance evaluations of the continuous and noncontinuous monitors are to be performed at least once a year as stated in 40 CFR Part 58.



A6.5 Project Reports The following reports are produced. See Section C2 for more detailed information.

• Quality Assurance technical systems audit report • Quality Assurance performance evaluation report • Quality Assurance reports on data accuracy, precision, and completeness by the

University of Texas at Austin from data provided by the subcontractors • Quarterly and Annual Reports to the U.S. District Court



A7 DATA QUALITY OBJECTIVES (DQO) FOR MEASUREMENT DATA

This section presents the data quality objectives for the project. The formal data quality objectives process as described in the U. S. Environmental Protection Agency (EPA) document Guidance for Planning the Data Quality Objectives (DQO) Process, EPA QA/G-4 has not been applied to this project, but the project DQOs have been established by other means.

The results of the DQO process include: • clarify the intended use of the data • define the type of data needed to support the decision • identify the conditions under which the data should be collected • specify tolerable limits on the probability of making a decision error due to uncertainty in the data The quantitative objectives for measurement data for each parameter are listed in Table A.7

in Appendix B. The objectives reflect the overall (total) measurement error expected for measurements made during this project. This includes media preparation, sampling, analysis, data reduction/reporting, etc. The quality control program has been developed with control of the measurement processes within these objectives in mind. Time lapsed video measurements are not addressed since they are not quantified.

A7.1 General Project Objectives • Provide measurements of selected pollutants to be used in evaluating population

exposure to these pollutants. • Provide information about releases of selected pollutants to guide in the prevention of

future releases. • Provide a speciated ambient air database that is both representative and useful for

ascertaining ambient profiles and distinguishing among various individual VOCs. these data will be useful as evaluation tools for control strategies, cost effectiveness, and for understanding the mechanisms of pollutant transport.

• Complement the body of data gathered from ground based monitoring sites in the Corpus Christi area to help with sampling design for future monitoring.

A7.2 Network Specific Objectives • Verify compliance or progress being made toward the achievement of NAAQS. • Support development of regulations designed to reduce air contaminants and assess

the effectiveness of reduction strategies in attaining and maintaining standards as stated in 40 CFR Part 58.



A7.3 Conclusions to be Made Conclusions to be made are presented in Section A5.2.

A7.4 Uses of Data The potential uses of the data are provided in Section A5.3.

A7.5 Measurement Quality Objectives The approaches used to assess data uncertainty and the measurement quality objectives for

each type of measurement are addressed in this section. Table A7 in Appendix B presents the quality objectives for each measurement that will be employed. Section D3 details the methods of computation.

A7.5.1 Detection Limits

Detection limits are expressed in units of concentration and reflect the smallest concentration of a compound that can be measured with a defined degree of certainty. Criteria pollutants are measured using EPA designated reference or equivalent methods. The detection limits for these methods are specified in 40 CFR Part 53. For VOCs, the detection limits reflect an estimate of the smallest volume of a compound that can be measured with a defined degree of accuracy. The detection limit for each VOC will be estimated according to 40 CFR Part 136, Part B. Because of this, no specific measurements of detection limits are made for the criteria pollutants in this project. This approach provides for analysis of seven samples of representative matrix containing target compounds at concentrations between three to five times the "expected" detection limit to provide a measurement set from which the variability (expressed as the standard deviation) of the measurement process under normal operating conditions can be estimated. To this variability estimate, the t-value for the sample population is applied. The result is added to the mean background signal for the measurement process to provide a concentration measurement at which values at or above will have a greater than 99 percent probability of being different than a blank.

For the continuous gas chromatograph (GC) and canisters, if a compound is detected at or above its method detection limit (MDL), there is at least 99 percent certainty that the compound concentration is greater than zero. For concentrations of a compound measured less than the MDL for canister sampling, but greater than or equal to 0.01 parts per billion by volume (ppbv), there may be indications that the compound is present, but with less than 99 percent confidence.

A7.5.2 System Contribution to the Measurement

A blank or "zero air" level is part of each automatic calibration and span check of the automated methods for SO2, H2S, and the Methane and Total Non-Methane Hydrocarbons by FID. As part of the calibration, this zero level is used along with the upscale concentrations to establish the monitor's calibration curve. As part of the span check, this level is used as a quality control check for monitor zero drift. Automated calibration and span check procedures are described in Appendix H.



For each non continuous method, the system contribution to the measurement results will be

routinely evaluated by the analysis of target pollutant free matrices. If possible, the humidity of the matrices will be representative of the field conditions during the evaluation period. If a method is found to have a system contribution for a target pollutant at a concentration greater than three times the detection limit or greater than 10 percent of the median measured concentration for the pollutant at the monitoring site (whichever is larger), efforts must be taken to remove the contribution. Any system contribution for a target pollutant (or for another constituent that interferes with analysis for a target pollutant) that is above the detection limit must be thoroughly characterized such that the extent of influence on the target pollutant measurement certainty is well understood. This may require an elevated frequency of blank analyses for an adequate period to characterize the contribution.

A7.5.3 Precision

Precision is a measure of the repeatability of the results. Estimates of precision are assessed in different ways for different measurement technologies. Refer to Table A7 in Appendix B for the DQOs. Specific activities designed to collect precision data are given in Section C1.

• Precision for measurements from continuous monitors for SO2, H2S, and the Methane

and Total Non-Methane Hydrocarbons by FID will be estimated by analysis of a test atmosphere containing the target compound being monitored in accordance with 40 CFR Part 58, Appendix A. Precision for SO2, H2S, and the Methane and Total Non-Methane Hydrocarbons by FID is estimated from precision checks that are done as part of routine span checks of the monitors. This precision check consists of introducing a known concentration of the pollutant into the monitor in the concentration range required by 40 CFR Part 58, Appendix A. The resulting measured concentration is then compared to the known concentration.

These measurements are processed into upper and lower 95 percent probability limits each calendar quarter as described in 40 CFR Part 58, Appendix A. These precision estimates are then compared to the precision goals.

The precision goals in Table A7 of Appendix B are given in terms of upper and lower 95 percent probability intervals where the center of these intervals is assumed to be 0 percent error. These goals represent the expectation that for repeated measurements of the same atmosphere, there should be a 95 percent probability that any single measurement error, expressed as the percent difference from the mean measurement, should fall within the 95 percent probability interval goal.

• Precision for the meteorological measurements will not be directly evaluated. Measurements will be compared with those from nearby sites using the same equipment.

• For VOC measurements, Auto GC and canister sampling, precision will be estimated by comparison of results from either collocated samples or comparison of replicate measurements of the same sample or daily QC standard, according to Title



40 CFR Part 58, Appendix C, and the Technical Assistance Document for Sampling and Analysis of Ozone Precursors.

A7.5.4 Accuracy

Accuracy is the closeness of a measurement to a reference value, and reflects elements of both bias and precision. Specific activities designed to collect accuracy data are given in Section C1.

• The accuracy for continuous monitors, i.e., SO2, H2S, and the Methane and Total Non-Methane Hydrocarbons by FID is estimated from independent performance audits. A performance audit consists of introducing a known concentration of the pollutant into the monitor in the concentration range required by 40 CFR Part 58, Appendix A, Section 3.2. The resulting measured concentration are then compared to the known concentration.

These measurements are processed into upper and lower 95 percent probability limits each calendar quarter as described in 40 CFR Part 58, Appendix A. These accuracy estimates are then compared to the accuracy goals.

The accuracy goals in Table A7 of Appendix B are given in terms of upper and lower 95 percent probability intervals where the center of these intervals is assumed to be 0 percent error. These goals represent the expectation that there should be a 95 percent probability that any single measurement error, expressed as the percent difference from the true value, should fall within the 95 percent probability interval goal.

• Meteorological measurement accuracy will be assessed by absolute difference with collocated or direct reading equipment measurements, reference Title 40 CFR Part 58, Appendix C and the Technical Assistance Document for Sampling and Analysis of Ozone Precursors. They are expected to meet the requirements specified in EPA Quality Assurance Handbook for Air Pollution Measurement Systems, Volume IV: Meteorological Measurements where possible. Section D3.3.3 of this document notes exceptions to the guidance.

• The accuracy for Auto GC VOC and canister VOC is ensured by challenging the systems with an internal performance evaluation sample or a National Performance Audit Program.

A7.5.5 Completeness

Data completeness for all pollutants is calculated on the basis of the number of valid samples collected out of the total possible number of measurements. All possible measurements for continuous monitoring (SO2, H2S, auto GC, Methane and Total Non-Methane Hydrocarbons by FID, VOC and meteorological parameters) mean 24 hours a day throughout the year. For non-continuous sampling (VOCs by canister sampling), it means every scheduled sample should be valid. Samples not taken when scheduled will decrease the valid data return. Data completeness is calculated as follows:

% Completeness = Number of valid measurements x 100



Total possible measurements

A7.5.6 Representativeness

Representativeness is the extent to which a set of measurements reflects actual conditions for a specific application. The representativeness objective for the data is not stated numerically as a quality assurance objective because quantitation is generally not possible. Siting criteria in 40 CFR Part 58 are met where possible. The extent to which these criteria are met should be reflected in site documentation files and technical system audit reports.

A7.5.7 Comparability

Comparability is achieved when the results are reported in standard units to facilitate comparisons between the data from this network and other similar programs. In order to accomplish this objective, the reporting units for the measurements are listed in Table A7.5.7.A.

Wind direction and wind speed data are recorded as one-hour averaged resultant vectors from the start to the end of an hour, with the data being referenced as the hour at which data collection started. The wind direction standard deviation and the wind speed arithmetic average for the hour are also computed. These figures are compared with data received from the National Weather Service that are two-minute averages of wind direction and wind speed taken at an unspecified time within an hour. The difference between the vector average and the arithmetic average is small, with the vector average never exceeding the arithmetic average.

VOC data taken by canister have time of sample beginning and end recorded in Local (Central) Daylight Savings Time from April through October based on standard conventions, and Local (Central) Standard Time for the balance of the year. All continuously recorded data are referenced in Local (Central) Standard Time all year round. Canister data time tags will be adjusted by Data Analysts by subtracting one hour during Daylight Savings period to allow comparability to other data.

Table A7.5.7.A Reporting Units of Measurements

Parameter Units* Conditions

SO2 ppm and parts per billion (ppb) Ambient

H2S ppbv Ambient

Methane and Total Non-Methane Hydrocarbons by

FID

ppmc Ambient

VOCs by Auto GC ppbc Ambient

Canister VOCs by GC/MS ppbv Ambient

Wind Direction degrees azimuth Ambient

Wind Speed miles per hour Ambient

Temperature degrees Fahrenheit Ambient

Relative Humidity percent (%) Ambient

* ppm, ppmc, ppb on a volume basis Note: The TCEQ MeteoStar System software produces data in ppm for SO2 data are required to be submitted to the EPA Air Quality System in ppm; however, the other pollutant data are accepted in ppb.



A8 SPECIAL TRAINING REQUIREMENTS/CERTIFICATION

Specialized training and use of standard operating procedures is required for personnel who audit, calibrate, or operate the criteria pollutant, meteorological equipment, and volatile organic compound samplers at the seven network stations and at the VOC analysis laboratory to ensure compliance with this QAPP. Instrument manuals are available at each site for reference.

It is expected and compliance will be verified by UT Austin that all subcontractors will be required to meet TCEQ quality assurance/quality controls requirements and must be able to demonstrate that their staff has been adequately trained for the services expected to be rendered. To evaluate the qualifications for all work, previous work experience, training certifications and resumes of subcontractor personnel working at each site are reviewed and their references checked. Where appropriate, UT Austin will arrange initially for any additional training required that is specific to this project.



A9 DOCUMENTATION AND RECORDS

Each subcontractor’s personnel working on this project is expected to maintain records that include sufficient information to reconstruct each final reported measurement from the variables originally gathered in the measurement process. This includes but is not limited to information (raw data, electronic files, and/or hard copy printouts) related to media preparation, sampler calibration, sample collection, sample handling (Chain-of-Custody and processing activities), measurement instrument calibration, quality control checks of sampling or measurement equipment, "as collected" measurement values, an audit trail for any modifications made to the "as collected" measurement values, and traceability documentation for reference standards. In addition, the inventory of all equipment at the site is to be maintained and verified quarterly.

Difficulties encountered during sampling or analysis need to be documented in narratives that clearly indicate the affected measurements. All electronic versions of data sets should reflect the limitations associated with individual measurement values.

A9.1 Mechanisms for Documentation of Procedures and Objectives • US District Court Corpus Christi Air Monitoring and Surveillance Camera Network

Quality Assurance Project Plan • Published guidance (Code of Federal Regulations, U.S. Environmental Protection

Agency [EPA] documents, and EPA Quality Assurance Handbooks) • Method Specific Standard operating procedures • TCEQ Instrument manufacturer's technical support manuals • TCEQAmbient Air Quality Network Field Quality Control Manual

A9.2 Mechanisms for Record Keeping The following electronic or hard copy documents are maintained by the analysts (e.g. Chain-

of-Custody forms in the laboratory with final data), field operators (e.g. activity logs), or data managers (e.g. electronic logs). All hard copy documentation is recorded in non-erasable ink, with any changes denoted by a single line through the entry, the initials of the person making the change, and the date.

• Sampling information and Chain-of-Custody forms • Instrument calibration data forms • Electronic run logs • Electronic and manual daily activity logs • Electronic and manual data processing and validation logs • Electronic and manual data management activity logs • Records of assessment, such as performance evaluation records • Exception reports



A9.3 Data Reporting Turnaround Time After the end of the quarter, all data except data from volatile organic compounds

(VOCs) by continuous gas chromatograph (GC) and VOCs in canisters analyzed by GC/Mass Spectrometer (MS) shall have a turnaround time of 90 days from collection through analysis, validation, and reporting to the project Advisory Board. The final report of data from VOCs by continuous gas chromatograph (GC), VOCs in canisters analyzed by GC/Mass Spectrometer (MS), will be prepared and made available to the project Advisory Board within six months following the end of each quarterly reporting period.

A9.4 Data Storage • Continuous and quality assurance data from the network are available in TCEQ

MeteoStar system after each sampling quarter and are stored indefinitely • Meteorological data are stored in the TCEQ MeteoStar System indefinitely. • Continuous GC data are stored in the TCEQ MeteoStar System indefinitely • GC/MS canister VOC data are stored on the UT Austin CEER server for five

years. • TCEQ MeteoStar data are stored on Hewlett Packard 735, which is backed up on

an optical system. • Audit reports are stored on CDs and in hardcopies at the UT CEER indefinitely.

The University of Texas at Austin Section B1 United States District Court Corpus Christi Air Monitoring and Surveillance Camera Network Project Quality Assurance Project Plan


B1 SAMPLING PROCESS DESIGN (EXPERIMENTAL DESIGN)

B1.1 Network Design The network consists of seven sites near and along the Corpus Christi refinery row/industrial

area for monitoring of releases of chemical and sulfur dioxide emissions from this area. See Appendix A for air monitoring station details. All measurements taken are classified as critical to meet project objectives.

B1.2 Network Design Rationale All of the network monitoring stations when possible meet the siting requirements of Title 40

Code of Federal Regulations Part 58, Appendices B, D and E. Design criteria for the network are based on the selection of an array of air monitoring stations located specifically to address the concerns of citizens by providing an additional means to measure chemicals of concern and document unauthorized events/releases.

B1.3 Measurement Validation Appendix B references the methods used to obtain data. Standard methodology has been

followed whenever possible. Sampling and validation efforts are described in Sections A6, B2, and D1. All data will be reviewed by the respective subcontractor’s quality assurance officer for acceptable data quality compliance with objectives before inclusion in the TCEQ or UT Austin server databases. The meteorological data will be compared to those obtainable from nearby sites as well as from the National Weather Service.



B2 SAMPLING METHODS REQUIREMENTS

This section addresses the approved sampling methods; the specific collection, preparation, and decontamination procedures of the equipment; the sample requirements, specifically the sampling media, sample preservation methods, holding times, field sample handling procedures; and the procedures to follow in case of a failure in the sampling system. The equipment and operating procedures are specified where the sampling method is automated. Every attempt has been made to be as complete as possible. It should be recognized that some of the procedures might change over the course of the program if logistical or quality related difficulties are encountered.

B2.1 Continuous Methods

B2.1.1 Sulfur Dioxide (SO2)

Criteria pollutant (SO2) sampling procedures used in this monitoring program are consistent with U.S. Environmental Protection Agency (EPA) 40 CFR Part 58, Appendices A through G, the Quality Assurance Handbooks for Air Pollution Measurement Systems, Volumes I and II, and the reference and equivalent methods designation criteria outlined in 40 CFR Part 53. The criteria pollutant sampling probes are sited in accordance with the EPA Quality Assurance Handbook, Volume II, Section 2.0.11 and EPA Ambient Monitoring Guidelines for the Prevention of Signifi-cant Deterioration. All materials are constructed of either borosilicate glass or Teflon. Some of the stations use a sampling manifold that is heated by means of heat tape or light bulbs to a maximum of 30 degrees centigrade in order to prevent water condensation inside the manifold. Also, a water trap may be located below the manifold to collect any water that condenses inside the manifold.

Ambient air is supplied to the continuous analyzers from the manifold through 1/4-inch diameter Teflon tubing equipped with in-line particulate filters. All tubing is attached to the manifold sampling ports with screw-on connectors and connected to the analyzers with compression fittings. Excess air flows through the sample manifold and blower and is vented away from the sample probe inlet.

The pollutant concentrations are automatically sampled and analyzed by the monitor. The output of the monitor is a voltage proportional to the concentration of the pollutant. The voltage outputs from the instruments are connected to and sampled by a data logger once per second to form five-minute averages. These continuous monitors are normally connected to the data logger to preassigned channel numbers. Data are transferred to the Texas Commission on Environmental Quality (TCEQ) central office by a modem through a regional hub computer connection.

The monitors used for continuous measurements of monitored pollutants are based on EPA approved equivalent or reference methods. Some of the measurement parameters, instrument model numbers, EPA method codes, and the approved full-scale range(s) of the monitors are identified in Table B2.1.A. Additional information may be obtained from the Geographical Common Table, found in the EPA Air Quality System (AQS) Database.



Table B2.1.A Measured Pollutants Measured Pollutant

Parameter

Instrument and Model Number

Designation/ Method Code Method Operating

Range

SO2 TECO 43 EQSA0276009/009 Fluorescence 0.5 ppm or 1.0 ppm

H2S TECO 43 H2S and H2S Converter

Fluorescence 0.5 ppm or 1.0 ppm

Total Methane and Non-Methane

TECO Model 55C FID

Flame Ionization Detector

100.0 ppm

B2.1.2 Hydrogen Sulfide (H2S)

Hydrogen Sulfide (H2S) sampling procedures are consistent with the Texas Commission on Environmental Quality Standard Operating Procedures Handbook. The pollutant sampling probes are sited in accordance with the EPA Quality Assurance Handbook, Volume II, Section 2.0.11 and EPA Ambient Monitoring Guidelines for the Prevention of Significant Deterioration. All materials are constructed of either borosilicate glass or Teflon. Some of the stations use a sampling manifold that is heated by means of heat tape or light bulbs to a maximum of 30 degrees centigrade in order to prevent water condensation inside the manifold. Also, a water trap may be located below the manifold to collect any water that condenses inside the manifold.

Ambient air is supplied to the continuous analyzers from the manifold through 1/4-inch diameter Teflon tubing equipped with in-line particulate filters. All tubing is attached to the manifold sampling ports with screw-on connectors and connected to the analyzers with compression fittings. Excess air flows through the sample manifold and blower and is vented away from the sample probe inlet.

The pollutant concentrations are automatically sampled and analyzed by the monitoring system. The output of the monitor is a voltage proportional to the concentration of the pollutant. The voltage outputs from the instruments are connected to and sampled by a data logger once per second to form five-minute averages. These continuous monitors are normally connected to the data logger to pre-assigned channel numbers. Data are transferred to the Texas Commission on Environmental Quality (TCEQ) central office by a modem through a regional hub computer connection. The continuous monitors for criteria pollutants are EPA approved equivalent or reference methods.

B2.1.3 Time Lapse Video

Operating procedures for the time lapse video are according to manufacturer’s instructions.

B2.1.4 Meteorological Measurement Systems

Meteorological sampling procedures used in this monitoring program are consistent with EPA Quality Assurance Handbook for Air Pollution Measurement Systems, Volume IV. The instrumentation used for meteorological monitoring will meet or exceed all prevention of significant deterioration performance criteria. The meteorological sensors at the ground-level



sites will be sited in accordance with EPA Ambient Monitoring Guidelines for the Prevention of Significant Deterioration.

Meteorological parameters are measured continuously with MET-One Meteorological System. The meteorological system measures wind speed, wind direction, temperature, and relative humidity. These measurements are collected in the data logger system via three analog output voltages.

The wind sensors are tower-mounted at a height of 10 meters above the ground. The parameters measured and their ranges are:

Parameter Range

Wind Speed 0 to 100 miles per hour

Wind Direction

0 to 360 degrees (°)

Temperature -22 to +120° Fahrenheit

Relative Humidity 1% to 100%

Specific performance requirements for the meteorological systems include:

• The MET-One Instruments Meteorological System is oriented to magnetic north with a compass.

• The wind direction for the meteorological system is corrected to true north by adding a magnetic declination value to the wind channel intercept in the monitoring station data logger. The magnetic declination is entered into the data logger when it is initialized at the time of installation. This task is performed by the personnel who configure the data logger. Magnetic declinations for all sites are obtained from the United States Geological Service via internet at the following address: Telnet://neis.cr.usgs.gov.

B2.1.5 Volatile Organic Compound (VOC) Automated Gas Chromatograph (GC) Sampling

VOC ozone precursors are monitored continuously using Perkin-Elmer O3 Precursor Analyzer systems. The units consist of an automatic system equipped with dual capillary columns, a Dean switch used as a heart cut accessory for multidimensional chromatography, and dual flame ionization detectors. A Perkin-Elmer Turbomatrix TD, Thermal Desorption System is used to concentrate and deliver the sample to the chromatographic system. Data processing is performed using PE Nelson Turbochrom Software in a Windows environment. Raw and processed data files are stored on the monitoring station computer after analysis and transferred electronically each day to the TCEQ Region 14 Hub Computer.

The Automated (Auto) GC system is housed in a custom constructed shelter. The shelter is equipped with climate control systems of sufficient size to handle the heat generated from the GC and additional monitoring systems, custom benches for the GC system, and a heated sampling manifold.



B2.1.6 Methane and Total Non-methane Hydrocarbons

Methane and Total Non-methane Hydrocarbon compounds are monitored continuously using a Thermo Electron Model 55 C FID analyzing system. The Model 55C is a back flush gas chromatography system designed for automated measurement of methane and non-methane hydrocarbons. The pollutant sampling probes are sited in accordance with the EPA Quality Assurance Handbook, Volume II, Section 2.0.11 and EPA Ambient Monitoring Guidelines for the Prevention of Significant Deterioration.

Ambient air is supplied to the continuous analyzers through ¼ inch stainless steel tubing equipped with in-line particulate filters. All tubing is attached sampling ports with screw-on connectors and connected to the analyzers with compression fittings.

The pollutant concentrations are automatically sampled and analyzed by the monitor. The 55 C processes one gas sample in a 90 second cycle, in which TNMHC and methane are both quantified, and the system flushed. Sample results are averaged over a five-minute period, so that three or four samples are combined. Data are transferred to the TCEQ central office by a modem through a regional hub computer connection.

The monitors for Methane and Total Non-methane Hydrocarbons are based on EPA approved equivalent or reference methods. Some of the measurement parameters, instrument model numbers, EPA method codes, and the approved full-scale range(s) of the monitors are identified in Table B2.1.B. Note that the operating range of 100ppmC is extended far beyond the typical level in other applications in Texas, and calibration and drift checks are performed at only two percent full scale range (2000 ppbC). Additional information may be obtained from the Geographical Common Table, found in the EPA Air Quality System (AQS) Database.

Table B2.1.B Continuous Methane and Total Non-methane Hydrocarbons Pollutant

Parameter Instrument and Model Number Method Operating

Range Methane /Total Non-Methane Hydrocarbons

Thermo Electron Model 55 C

Flame Ionization Detector

100.0 ppm

B2.2 Noncontinuous Methods The noncontinuous monitored pollutants (canister VOCs) are collected by field sampling

systems. The samples are handled by a field technician/operator and the samples are transported to the University of Texas at Austin, Center for Energy & Environmental Resources laboratory for analysis.

B2.2.1 VOC Canister Sampling Canister VOC samples are collected in evacuated 400 ml passivated (glass-lined) stainless

steel minicanisters through a VOC single or multicanister sampling system. (These samples are analyzed by the University of Texas at Austin Center for Energy & Environmental Resources Laboratory (UT Austin CEER) using a modified TO-15 methodology.) The canister samplers consist of a flow controller connected through a solenoid valve to the stainless steel intake sample



line and is attached to either a single glass-lined canister or up to ten canisters with their individual intake sample lines. The flow controller is adjusted to the appropriate flow to allow the canister to fill as evenly and uniformly as possible over the sampling period(s). A datalogger is attached to the mass flow controller (MFC) that controls the sampling flow and period.

VOC samples are collected in 400 ml glass-lined stainless steel canisters with quick connect fittings. For cleaning, canisters are vented to ambient pressure after analysis of the field sample. Humidified nitrogen is used to pressurize the heated (heat belt) canisters for steam cleaning. The canisters are vented to ambient pressure and evacuated. The cans are repressurized with nitrogen and evacuated to approximately -15 to -20 inches mercury. This cleaning cycle is automatically repeated at least three times. Up to eight canisters are cleaned simultaneously using a canister cleaning manifold. At the end of the evacuation/pressurization cycles, all of the canisters are evacuated to approximately -14.6 pounds per square inch gauge. One canister is designated as a media blank and is pressurized 10 to 20 pounds per square inch gauge with humidified nitrogen. This canister is analyzed using a GC/mass spectrometer analytical system to assess the efficiency of the cleaning procedure. Canisters are considered clean when the results of the media blank indicate that there is less than 0.2 parts per billion by volume or less than the minimum detection limit of target VOCs. If results for the clean check canister are outside of the objectives, the entire batch of canisters are recleaned. The canisters are stored until shipment to the field.

The sampling train primarily consists of an electronic MFC for regulating the sample flow rate into an evacuated canister, a pressure transducer for measuring the change in canister pressure, and a solenoid valve for controlling the sampling period.

The MFC is controlled by an analog voltage from a datalogger. The datalogger controls the sampling flow by sampling the feedback voltage from the flow controller sensor and outputting a correcting voltage to the MFC.

The slope and intercept from the MFC are entered into the datalogger memory after the program downloads. The datalogger calculates a true flow rate from the slope, intercept, start pressure of the canister, and the run time. The datalogger also continuously samples and records the sample flow rate, ambient temperature, and canister pressure.

The datalogger also controls the sampling period by cycling the sample solenoid valve. When the valve is shut off prior to sampling, the canister is isolated from the sampling train. It turns on during sampling to allow the canister to draw ambient air at a calculated flow rate for a preset sampling time.

The VOC sample collection protocol consists of: • Loading a canister • Performing an initial canister vacuum check • Performing a sampler leak check • Initializing the sampler operating parameters in the datalogger • Unloading and tagging canisters following sample collection • Recording sampler identification and operational information on the Chain-of-

Custody/Sampling Field Data Sheet • Preparing canisters for shipping to the UT Austin CEER laboratory



Canister samples are triggered after the Zeno has detected a set of sustained TNMHC readings at or above 2000 ppbC for a period of 900 seconds (15 minutes). In general, this represents observing ten consecutive 90-second measurements (70 seconds of chemical analysis plus 20 seconds rest time). Not all of the high TNMHC can be viewed in the five-minute resolution data output by the TCEQ Leading Environmental Analysis and Display System, since: • 90-second exceedances later in a 5-minute reading may be diluted by lower 90-second

measurements earlier in the 5-minute reading, at the onset of a 900-second exceedance, or

• A 5-minute reading may be diluted by lower 90-second measurements later in the 5-minute reading at the conclusion of a 900-second exceedance.

The passivated sample canisters should not be exposed to extreme heat or sunlight as chemical decomposition can occur. The canisters are placed in their carrying cases when in storage or transportation. The canisters are mailed to the UT Austin CEER laboratory within 5 days of sample collection. Canisters have a maximum hold time of 21 days.

B2.2.1.1 Implementation Requirements for VOC Samplers

• The sample probe is located at a height of 4 to 5 meters above ground following EPA probe siting requirements.

• The flowmeter in the sampler is calibrated with a primary flow standard NIST (National Institute of Standards and Technology) traceable by the project QA officer.

• The pressure transducer calibration is checked when a sampler is repaired.

B2.2.1.2 VOC Canister Sampling System Decontamination

Prior to field use, the sampling train must pass a humid zero air certification. Refer to Section 9.1.3.6, Page TO 14-21 of the EPA “Method TO-14A,” Compendium of Methods for Determination of Toxic Organic Compounds in Ambient Air.

B2.3 Corrective Actions The field technician of the subcontractor assigned to a monitoring station is responsible for

operating samplers and initiating minor corrective actions on equipment when required. Equipment problems are generally detected through a failed sample run or through performing routine quality control (QC) checks. The QC checks that are performed on the sampling equipment are identified in Section B5 and detailed in Table B5 in Appendix C of this plan.

When a major equipment problem is involved, the technician refers the problem to the supervisor of the subcontractor’s field techncian, who has the responsibility to follow up on restoring the equipment to its proper operating status. The University of Texas at Austin Project Manager should also be informed of major problems and the corrective action employed to solve the problem.

Any equipment problems that can result in the loss of data are addressed as high priority. All situations requiring corrective action will be documented in site activity logs. Section B4.2 contains additional information on documentation of corrective action.



B3 SAMPLE HANDLING AND CUSTODY

For measurement data that is collected electronically, each sampling method is required to have procedures that allow for clear custody record keeping for each transfer of information from the collection point to the final data holding mechanism. All physical samples that require additional handling to generate a measurement will be required to be labeled with a unique identification number. Each sampling method is required to have procedures that will track the transfer of these samples from the media preparation point, to and through the sample collection point, through the analytical process to the final disposal of the sample. The record of sample acquisition activities will be required to contain minimum information about the time of sampling, location, sampler operational conditions, weather conditions, and any other descriptive data that may be relevant to support the representativeness of the measurement(s) being made. Procedures are expected that allow for clear custody record keeping for each transfer of information related to the analysis of these samples. At minimum, sample data sheets, bound logbooks, or equivalent electronic mechanisms that provide an audit trail of activities shall be employed and maintained.

B3.1 Documentation and Custody Requirements This section describes the procedures used in this project for documenting and maintaining

sample custody from time of collection until disposal.


There are no discrete samples handled by individuals for these methods. The identity and disposition of samples are documented electronically by the run log associated with the instrument support computer and processing software. Instrument calibration information is recorded on standard data forms and maintained in the permanent record. Information regarding instrument maintenance is maintained in the Daily Activities Logbook.




There are no discrete samples handled by individuals for this method. The identity and disposition of samples are documented electronically by the run log associated with the instrument support computer and processing software. Information regarding instrument maintenance and calibration activities is maintained in the Daily Activities Logbook.



B3.1.4 VOCs by Automated Gas Chromatograph (GC)

While there are no discrete samples handled by individuals for this method, the identity and disposition of samples are documented electronically by the run log associated with the Auto GC support computer and processing software. A record of data transfer and post-processing activities associated with electronic data files is maintained in monitoring station specific binders which contain site, date and the reason for post-processing (ex: batch reprocessing of a data set). These records are maintained by the subcontractor.



B3.1.6 Volatile Organic Compounds (VOCs), Canister Samples

The University of Texas at Austin Center for Energy and Environmental Resources (UT Austin CEER) laboratory assigns a unique name designation to identify the monitoring station and the sampler. The name consists of an alphanumeric designator for the monitoring station and a three-digit number, assigned in consecutive order, for the sample.

The Chain-of-Custody form to be used by the field technician to document custody of gas canisters for sampling is the "Canister Sampling Data Sheet" (see Appendix D for an example of the form). The bottom half of the form (..."To Be Completed By Lab"...) is filled out and initialed by the chemist or chemists who prepared the canister (cleaned, evacuated, etc.). When it is shipped, the canister pressure is also recorded on the form.

A chemist signs off in a laboratory log as having prepared the canister, fills out a Chain-of-Custody form, packs the custody form with the canister, places the canister in a single or multiple canister shipping container, and records in the laboratory shipping log the canister number and the dates they were shipped directly to the subcontractor’s field office. The canister shipping containers are secured with Chain-of-Custody seals.

B3.1.6.1 Transfer from the UT Austin CEER Laboratory to Subcontractor's Field Office

The field technician is responsible for the security of the sample from the time the clean canister is received until the time the filled canister is shipped by commercial carrier. When the gas canister is received in the subcontractor’s field office, the technician records it in a logbook indicating the date it was received and the canister number. The canisters are stored in the field office under the technician's control.

The technician transports the canister to the sampling site in the case in which it was shipped. The technician removes the Chain-of-Custody seal, opens the canister case, installs it in the sampler, and records any preliminary information on the Chain-of-Custody form. The technician enters on the top half of the custody form the project name, monitoring station address, monitoring station Air Quality System number (if one exists), sampling date,



operator name, sampler serial number, canister leak check results, canister pressure (start), and the name and initials of the technician who installed the canister.

Following sampling, a filled canister is removed from the sampler and is packed into an empty case or shipping container. The canister pressure (stop), sampling times (local and elapsed), flow rates, the name and initials of the technician who removed the sample, and the date the sample is shipped to the laboratory are entered on the custody form after sampling is completed. The information for sampling times and flow rates is obtained from the datalogger. The comments section is completed for general monitoring station conditions and problems encountered during the sampling or with the equipment. The completed custody form is packed with the sample in the shipping container. The technician secures the sample container with a Chain-of-Custody seal bearing his/her initials. During the time that the canister is installed in an unattended sampler, the sampler is secured

by a fence surrounding the sampling property or by other means. Only the technicians have keys to the locked gates or doors.

The canisters are taken to the field office and held in storage until they are mailed or picked up by the private carrier.

B3.1.6.2 Return from Subcontractor's Field Office to UT Austin CEER Laboratory

Full canisters are returned from the field directly to the UT Austin CEER building, where the laboratory is located. Laboratory staff breaks the Chain-of-Custody seal, opens the shipping case, and logs the canister into the laboratory-receiving log. The canister received date and initials on the Chain-of-Custody form are entered. Gas canisters are stored in the laboratory analysis room until analyses are complete. The UT Austin CEER laboratory is locked at night and only laboratory personnel have keys to these rooms. The chemist analyzing the gas samples enters the date and initials on the custody form. When a transfer of sample occurs outside the laboratory, the information is entered on the custody form. After analysis, the canisters are taken to the cleaning system, decontaminated, and prepared for reshipment. The final vacuum pressure date and initials of the chemist who evacuated and cleaned the canister are entered onto a new custody form to be used with that canister.


There are no discrete samples handled by individuals for these methods. The media for this video is digital and is saved and archived by the video system and The University of Texas.

B3.2 Sample Handling Procedures

B3.2.1 SO2

There are no discrete samples handled by individuals for these methods.

B3.2.2 H2S

There are no discrete samples handled by individuals for these methods.



B3.2.3 Meteorological Measurement Systems There are no discrete samples handled by individuals for this method.

B3.2.4 VOCs by Automated GC There are no discrete samples handled by individuals for this method.

B3.2.5 Methane and Total Non-methane Hydrocarbons There are no discrete samples handled by individuals for this method.

B3.2.6 VOCs, Canister Samples The field technician receives the shipping case of canisters and removes one canister and

the attached Chain-of-Custody form prior to the sampling date. (See Appendix D for an example.)

As needed at the time of canister installation, the technician checks the initial vacuum reading and performs a leak check. The results of the checks are recorded on the Chain-of-Custody form. If either check fails, the canister should not be used. Replace the failed canister with a new one and repeat the checks. Return the failed canister with the next batch of canisters shipped to the UT Austin CEER laboratory.

After the sample run, canisters are removed from the sampler as soon as possible. The technician performs a final vacuum check and records the reading along with all pertinent data on the top half of the Chain-of-Custody form. The technician packs the canister with the Chain-of-Custody form in the self-addressed shipping container, secures the sample with a Chain-of-Custody seal bearing his/her initials, reverses the address label so that the return shipping address shows, and ships the canister by private carrier. The technician ships the canister to the UT Austin CEER laboratory within five calendar days of collection.


There are no discrete samples handled by individuals for this method.



B4 ANALYTICAL METHODS

B4.1 Analytical Procedures This section presents information regarding the analytical methods used to develop ambient

air measurements for this project. Where published methods exist, the method reference has been specified and exceptions to the published method are discussed in the TCEQ current version Standard Operating Procedures(SOP) AMOR-002 and AMOR-006. Current versions of the TECQ SOPs mentioned in the document are listed in Appendix E.


There are no exceptions to established guidance (see Section B2).



B4.1.3 Meteorological Measurement Systems by U.S. Environmental Protection Agency (EPA) Quality Assurance Handbook Volume IV Methodology

Meteorological measurement methods are in accordance with U.S. Environmental Protection Agency Quality Assurance Handbook Volume IV, March 1995, methodology. Exceptions to the quality assurance requirements are noted below. Wind Direction

Accuracy (absolute difference): ±3 degrees alignment, ±5 degrees overall. (The 1995 guidance for wind direction is agreement within ±5 degrees azimuth. The guidance for wind direction using direct reading sensors is followed. However, using comparisons with nearby well-exposed sites, agreement in direction should be within ±30 degrees.)

Wind Speed Accuracy (absolute difference): ±0.56 miles per hour (mph) at winds <11.2 mph, ±5 percent

at winds >11.2 mph. Maximum allowable error: 5.6 mph (The 1995 guidance specifies a wind speed accuracy of ±0.2 ms-1 +5 percent of observed speed from 0.5 to 50 ms-1. This corresponds to ±0.447 mph +5 percent of the observed speed from 1.12 mph to 112 mph. The current acceptable range for wind speed accuracy response using a direct reading sensor is within 0.56 mph at speeds below 11.2 mph and within ±5 percent at speeds above 11.2 mph; and ±5 mph using collocated wind speed measurement equipment.)

Temperature Accuracy (absolute difference): 1.8 degrees Fahrenheit (F). (The guidance specifies a

temperature accuracy of ±0.5 degrees Celsius. The current TCEQ accepted range for both direct reading sensors and collocated sensors is ±1.0 degrees Celsius or 1.8 degrees F.)



Relative Humidity

Accuracy (absolute difference): <+/- 1% from 0 to 100%. (The guidance specifies a relative humidity accuracy of +/- 5%. The current TCEQ accepted range for both direct reading sensors and collocated sensors is +/- 5%).

There are no discrete samples for meteorological measurements. All measurements are made in the field.

B4.1.4 VOCs by Automated Gas Chromatograph (GC) (Perkin Elmer GC/Flame Ionization Detector [FID]) for Volatile Organic Compounds (VOCs)

These measurements are made in compliance with the EPA technical guidance document Technical Assistance Document for Sampling and Analysis of Ozone Precursors. Standard Operating procedure (SOP) for the operation of this equipment is under development. (See Appendix E.)

VOCs are monitored continuously using Perkin-Elmer Ozone Precursor Analyzer systems. The unit consists of an auto system equipped with dual capillary columns Porous Layer Open Tubular(PLOT) and Boiling Point 1% dimethyl polysiloxane(BP-1), a Dean switch used as a cut accessory, and dual FIDs. A Perkin-Elmer Turbomatrix concentrator and desorption unit is used to concentrate and deliver the sample to the chromatographic system for separation. Systems are calibrated using external gas standards defining a working range of 1 to 100 parts per billion by volume. Data processing is performed using PE Nelson Turbochrom Software in a Windows environment. After analysis, the site operators perform an on-site review of quality control (QC) data and sample data. The raw and processed data files are stored on site and transferred daily to the data validators in Austin.

Appendix C contains the network QC activities and corrective actions. Appendix B contains the network measurement data quality objectives, including the detection limits.


The Standard Operating procedure (SOP) for the operation of this equipment is under development (See Draft SOP Appendix E.).


B4.1.6 EPA TO-14/TO-15 Method for Analyzing VOCs Collected in Glass-Lined Stainless Steel Canisters

Two analytical systems will be used for the analysis of VOCs from the glass lined stainless steel canisters. A Varian ultra trace hydrocarbon system (UTHS) will be used to detect non-methane hydrocarbons ranging in mass from ethane to nonane by using a modified TO-14 method. Measurements made with the UTHS will be compliant with the California Air Resources Board Standard Operating procedure for the Determination of Non-methane Organic Compounds in Ambient Air by Gas Chromatography using Dual Capillary Columns and Flame Ionization Detection SOP No. MLD 032. found at http://www.arb.ca.gov/aaqm/sop/sop032.pdf on 12/20/2005. Upon receipt at the laboratory, the sample collection information is recorded and

http://www.arb.ca.gov/aaqm/sop/sop032.pdf



the canister is stored until analysis. Prior to analysis, the subatmospheric samples are pressurized to twice the collected volume using a sample dilution system.

The analytical strategy for the modified Method TO-14 involves using a GC with 3 capillary columns and 2 FID detectors. A switching valve located in the GC oven directs effluent from a short loading column onto 2 analytical columns coated with very different stationary phases. One of the analytical columns (Alumna) is used to separate the very volatile compounds from ethane to cis-2-butene and the other analytical column DB-1 separates the midrange compounds. So therefore the TO-14 analysis will be completed with the detection of C2 compound in one GC cycle without splitting of sample. The identification of these compounds is based on matching retention times and peak patterns of standards containing known analytes. Precision and accuracy objectives established for this method are < 30 percent relative percent difference and 70 percent to 130 percent recovery, respectively, for most compounds.

The second analytical system will be used were TO-15 analysis of samples is deemed necessary because of the presents of co-elution or unidentified peaks. These measurements are made in compliance with the EPA Technical Assistance Document for Sampling and Analysis of Ozone Precursors. The deviations from the published method are detailed in the TCEQ current version SOP AMOR-006, the “Determination of Volatile Organic Compounds (VOCs) Canisters by Gas Chromatography/Mass Spectroscopy (GC/MS) Using Modified Method TO-15.” For analysis, a known volume of a sample is directed from the canister into a multitrap cryogenic concentrator. A multiple internal standard is added to the sample stream prior to the trap. The concentrated sample is thermally desorbed and carried onto a GC column for separation.

The analytical strategy for the modified Method TO-15 involves using a GC with a single column that can be coupled with a MS or a FID. Mass spectra for individual peaks in the total ion chromatogram are examined with respect to the fragmentation pattern of ions corresponding to various VOCs and including the intensity of primary and secondary ions. The fragmentation pattern is compared with stored spectra taken under similar conditions in order to identify the compound. For any given compound, the intensity of the quantitation ion is compared with the system response to the fragment for known amounts of the compound. This establishes the compound concentration in the sample. The FID is used for the quantitation of ethane, ethylene, acetylene, propylene, and propane. The identification of these compounds is based on matching retention times and peak patterns of standards containing known analytes. Precision and accuracy objectives established for this method are < 30 percent relative percent difference and 70 percent to 130 percent recovery, respectively, for most compounds. Appendix B contains the PAMS network measurement data quality objectives and the established measurement objectives for the modified TO-15 method, including the detection limits.


There are no analytical methods employed in the use of the time lapse video. The video media in use by this project is digital media. The cameras are able to be manipulated manually at the site location, or controlled via a web portal. The media is uploaded to the TCEQ LEADS system every 5 minutes and is available for analysis by The University of Texas Project Representatives and TCEQ Personnel. Visual inspection and correlation with meteorological conditions are performed and documented by the University of Texas at Austin.



The equipment employed are the all-weather/day-night Panasonic Color Dome Camera Model WV-CW864, commonly used for outdoor surveillance, coupled with the Panasonic Digital Disk Recorder Model WJ-HD500BV.

B4.2 Corrective Actions It is expected that the individual discovering a problem will initiate corrective action

appropriate to the situation. Documentation of the problem using site activity logs or the laboratory Exception Report System should be used.

Generally, the subcontractor is responsible for or arranging for the repair of all equipment. The subcontractor shall notify the UT Austin Project Manager of the cost of major repairs or replacement needed. A backup technician shall be called if the primary technician is not available.

At the UT Austin CEER laboratory, trained instrument operators and chemists are responsible for maintaining the equipment. Instrument manuals are available for troubleshooting, and if the problem is beyond the resources of the laboratory, service contracts are used to obtain assistance.

Internal Quality Control Check and Corrective Actions are detailed in Appendix C.



B5 QUALITY CONTROL (QC)

The QC protocol for the network is discussed in this section. An attempt is made to provide adequate information from which to estimate the uncertainty and potential limitations of measurements generated by the monitoring. The minimum expectation is that the QC protocol should address:

• Media contribution to the measurements • Matrix effects on the measurements • Sampling system contribution to the measurements • Measurement system contribution to the measurements • Qualitative performance of the method • Quantitative performance of the method • Precision of the measurements • Bias of the measurements The outcome of this effort is reflected in Table B5 in Appendix C. In some cases, limitations

of project resources may restrict the ability of UT Austin to make certain quality assessment measurements. The determination of the effectiveness of the corrective actions can be found in Appendix C.

B5.1 SO2 The Texas Commission on Environmental Quality (TCEQ) software performs automated QC

checks on three-point span check and five-point calibration data from SO2 monitors in stationary air monitoring stations. QC procedures, control limits, and formulas to calculate QC statistics are given in TCEQ standard operating procedures specific to the monitoring that is part of the MeteoStar System. The primary purpose of the five-point calibration is to establish the calibration curve for a monitor and to evaluate the performance of the monitor at the time of the calibration. The purpose of the three-point span check is to evaluate drift in the calibration curve of a monitor between calibrations, evaluate monitor performance, and assess measurement precision.

In general, a warning and a failure control limit has been established for each of these QC checks for each type of monitor. Warning limits are statistically determined and set at three standard deviations. This means that there should be only a .27 percent probability that any given test will exceed the warning limit if the system being tested is in control. Failure limits are based on data validation criteria used currently such as DQO limits. An exceedance of a failure limit indicates that the system being tested is performing below minimum acceptable requirements and as a result the data should be evaluated for usefulness and that there is a need for corrective action.

The computer system performs a preliminary validation of the ambient data based on the results of these checks. Data validity decisions are based only on whether a QC test exceeds the failure limit. Appendix H describes these automated QC checks and validation rules in detail.



Appendix C gives the QC limits for each check used by the computer system at the time of this plan revision.

The following QC checks are performed on all of the above-mentioned monitors: • Media contribution - Zero Drift Test - Applies to both calibrations, span checks, and

span zeros. Checks drift in the "zero" voltage since the last valid calibration. The zero voltage is the monitor's response to clean air used in the calibration or span check. This is a monitor check that evaluates the drift of the instrument and is primarily a measure of intercept stability.

• Sampling system contribution - Intercept Test - Applies to calibrations only. Checks the intercept of the calibration curve against the expected value. This is a monitor check.

• Measurement system contribution/Precision - Precision/Linearity Test - Applies to calibrations only. Checks the closeness of measured calibration data points to the calibration curve defined by the calculated slope and intercept. This is a monitor check that looks for linearity or erratic response problems. Some calibration system problems will show up in this test also.

• Qualitative performance of the method - Slope Test - Applies to calibrations only. Checks the slope of the calibration curve against the expected value. This is a monitor check.

• Quantitative performance of the method - Span Drift Test - Applies to both calibrations and span checks. Checks drift in the "span" voltage since the last valid calibration. The span voltage is the monitor's response to the highest concentration used in the calibration or span check. This is a monitor check that evaluates the stability of the current calibration curve and is primarily a measure of slope stability.

Additional checks include: • Completeness Test - Applies to both calibrations and span checks. Checks that the

calibration or span check data set is complete before the data are processed. • Concentration Outlier Test - Applies to each concentration level of both calibrations and

span checks. Checks the stability of the reported concentration for each concentration level. This is a calibration system check.

• Monitor Outlier Test - Applies to each concentration level of both calibrations and span checks. Checks the stability of the monitor voltage for each concentration level. This is a monitor check.

• Concentration Spacing Test - Applies to each concentration level of both calibrations and span checks. Checks the reported concentration for each level against the expected concentrations. This is a calibration system check.

• Laboratory Control Checks – Checks the accuracy of the calibration using a second source. This is a calibration and analytical system check.

• Linearity Test - Applies to span checks only. Checks the linearity of the monitor. Some calibration system problems will show up in this test also.



B5.2 H2S The Texas Commission on Environmental Quality (TCEQ) software performs automated QC

checks on three-point span check and five-point calibration data from H2S monitoring systems in stationary air monitoring stations. QC procedures, control limits, and formulas to calculate QC statistics are given in TCEQ standard operating procedures specific to the monitoring that is part of the MeteoStar System. The primary purpose of the five-point calibration is to establish the calibration curve for a monitor and to evaluate the performance of the monitor at the time of the calibration. The purpose of the three-point span check is to evaluate drift in the calibration curve of a monitor between calibrations, evaluate monitor performance, and assess measurement precision.


The computer system performs a preliminary validation of the ambient data based on the results of these checks. Data validity decisions are based only on whether a QC test exceeds the failure limit. Appendix H describes these automated QC checks and validation rules in detail. Appendix C gives the QC limits for each check used by the computer system at the time of this plan revision.






• Quantitative performance of the method - Span Drift Test - Applies to both calibrations and span checks. Checks drift in the "span" voltage since the last valid calibration. The span voltage is the monitor's response to the highest concentration used in the calibration



or span check. This is a monitor check that evaluates the stability of the current calibration curve and is primarily a measure of slope stability.








• Converter Efficiency Test for Converting Hydrogen Sulfide to Sulfur Dioxide - Applies to both calibrations and span checks of Hydrogen Sulfide monitoring systems. This is a monitor check.

B5.3 Meteorology Table B5 in Appendix C contains a detailed listing of the QC checks for the meteorological

equipment. These QC activities include visual inspection of instrumentation integrity, measurement consistency with current conditions, and corrective actions. There is no collocated meteorological equipment.

• Media contribution to the measurements do not apply to the meteorological parameters.

• Sampling system contribution to the measurements is determined by the resolution and start threshold for the measurements.

• Measurement system contribution is controlled by the calibration of the sensors and is performed by the vendor. A functional check of the equipment is made before deployment of the equipment.

• Qualitative performance of the method is determined by visual inspection of the sensors and comparison of the data display to ambient conditions.

• Quantitative performance of the method is determined by comparison of the data to nearby National Weather Service Station data.

• Precision of the measurements do not apply to the meteorological parameters.



• Accuracy (bias) of the measurements is determined by comparison of instrument measurements with local conditions. Annual audits are performed on the meteorological instruments.

• Prior to the start of sampling and then annually, the relative humidity sensor will be compared to the output of a collocated sling psychrometer.

B5.4 VOCs by Automated Gas Chromatograph (GC) The QC basic checks performed on the continuous GC system are: • Daily analysis of a humidified propane and benzene standard to check recoveries and

instrument stability. • Daily analysis of a clean, humidified blank to determine instrument carry-over or

contamination potential. • Semi-monthly analysis of a 56 component standard is used to assess the response

time. • Semi-monthly analysis of a 5 part per billion volume standard is used as a second

source to assess the system accuracy. This sample is introduced via the normal ambient sample path.

The remainder is summarized in Table B5 in Appendix C. There is no collocation of the Auto GC systems; however, weekly analysis of a humidified propane and benzene standard is run back to back. Precision and Accuracy for this parameter is determined by the procedures described in section B5.8 and B5.9.

B5.5 Methane and Total Non-methane Hydrocarbons The Texas Commission on Environmental Quality (TCEQ) software performs automated QC

checks on three-point span check and five-point calibration data from continuous FID Methane and Total Non-methane hydrocarbon monitors in stationary air monitoring stations. QC procedures, control limits, and formulas to calculate QC statistics are given in TCEQ standard operating procedures specific to the monitoring that is part of the MeteoStar System. The primary purpose of the five-point calibration is to establish the calibration curve for a monitor and to evaluate the performance of the monitor at the time of the calibration. The purpose of the three-point span check is to evaluate drift in the calibration curve of a monitor between calibrations, evaluate monitor performance, and assess measurement precision.


The computer system performs a preliminary validation of the ambient data based on the results of these checks. Data validity decisions are based only on whether a QC test exceeds the failure limit. Appendix H describes these automated QC checks and validation rules in detail.



Appendix C gives the QC limits for each check used by the computer system at the time of this plan revision.

It should be noted that the full scale range of the instrument has been modified in order to quantify higher concentrations. The 0 to 1 volt scale now maps to 0 to 100 ppm. The spans and calibrations are still performed in conformance with the 0 to 2 ppm full-scale range. This guarantees higher accuracy in the range in which the vast majority of samples are taken. Further means to assess data quality are available by comparing high TNMHC concentrations to coincident collated canister samples.






• Quantitative performance of the method - Span Drift Test - Applies to both calibrations and span checks. Checks drift in the "span" voltage since the last valid calibration. The span voltage is the monitor's response to the highest concentration used in the calibration or span check. This is a monitor check that evaluates the stability of the current calibration curve and is primarily a measure of slope stability.










• Semi-monthly analysis of a 2 component standard is used to assess the response time. • Semi-monthly analysis of a 5 part per billion volume standard is used as a second

source to assess the system accuracy. This sample is introduced via the normal ambient sample path.

B5.6 TO-15 Canister Volatile Organic Compounds (VOCs)

B5.6.1 Sampler QC Checks

Upon canister installation and removal, the initial and final canister pressures are recorded in the canister custody/information sheet. If the initial vacuum is less than -13.4 pounds per square inch gauge (psig), the canister is not used. A sample leak check is also performed at the time of canister installation. If the vacuum changes by more than 2.0 inches mercury, then the sampler connections are checked for leaks and the test repeated.

Canister samplers are assessed for contamination prior to field deployment. In this check, ultra-high purity air or nitrogen will be provided to the normal sampling inlet and drawn into an evacuated canister. The results of the laboratory analysis on the "sample blank" canisters will provide measures on the amount of contamination that may exist in the sampler.

Refer to Table B5 in Appendix C for a summary of QC checks for the VOC sampler.

B5.6.2 Analytical QC Checks in the UT Austin CEER Laboratory B5.6.2.1 Blank Analysis

Prior to sample analyses each day, the GC/mass spectrometer (MS)/flame ionization detector system is checked for potential contamination by analyzing a system blank. If the level of any targeted compounds exceeds 0.2 parts per billion by volume (and the method detection limit), the system is given further cleaning and checking prior to sample analysis. The acceptance criteria for the total non-methane organic carbon (TNMOC) analysis blank level are 20 parts per billion by carbon.

B5.6.2.2 MS Performance Check

A 4-bromofluorobenzene (BFB) performance check is performed on the daily QC standards analyzed every day to insure proper mass calibration and abundance rations according to Table 3, U.S. Environmental Protection Agency SW-846, BFB Key Ion Abundance Criteria. This procedure is detailed in the TCEQ current version Standard Operating Procedure AMOR-006 “Determination of Volatile Organic Compounds (VOCs) Canisters by Gas Chromatography/Mass Spectroscopy (GC/MS) Using Modified Method TO-15.”

B5.6.2.3 Calibration



A minimum of three concentrations and a blank are used to calibrate instrument response and check instrument linearity on the modified TO-15 and TO-12A analyses. The modified TO-15 analyses uses internal standard calibration and all target compounds must have either a correlation coefficient of 0.995 or better or a relative standard deviation (RSD) of the response factors of no more than 20 percent. The TO-12A “Compendium of Methods for the Determination of Toxic Organic Compounds in Ambient Air - Second Edition” (external) calibration must have either a correlation coefficient of 0.995 or better or a RSD of the response factors of no more than 20 percent.

B5.6.2.4 Calibration Check

Instrument drift is checked by running a mid-level concentration standard, which must be within 30 percent of the true value for the target compounds (except n-undecane 45-135 percent recovery) for the modified TO-15 and 30 percent for TNMOC using TO-12A.

The calibration accuracy is checked by analyzing a second source standard, which has an acceptance criteria of 30 percent of the true value for most of the target compounds for the modified TO-15 (see App. B for specific compound acceptance criteria) and 30 percent for TNMOC using TO-12A.

B5.6.2.5 Analytical Precision

The analytical precision is assessed by analyzing the second source standard in duplicate with each set of samples. The relative percent difference of these duplicates must be no greater than 25 percent for most of the target compounds for EPA Method TO-15 (see App. B for Specific compound acceptance criteria) and no greater than 20 percent for TNMOC measured by EPA Method TO-12A. Precision and Accuracy for this parameter is determined by the procedures described in section B5.8 and B5.9.

B5.7 Time Lapse Video There are currently no QC requirements for the time lapse video monitoring.

B5.8 Precision Analytical laboratory data precision is evaluated using standard deviation, range, coefficient

of variation (CV) (also known as the relative standard deviation [RSD]), and relative percent difference (RPD).

The standard deviation is a measure of the average distance of individual observations from

the mean. It is usually denoted as S and defined as:

( )

SXi X

i

n

n=

−=∑

−

2

11



Where: n is the number of measurements; Xi is the ith observation in the sample set; and

is the sample mean. The range is the largest observation in a data set minus the smallest observation in the data

set, often denoted as R. The CV, or RSD, is a commonly used variability measure that is adjusted for the magnitude

of the values in the sample: CV (%) = Standard Deviation x 100 Mean The CV is used most often when there are more than two measurements and the size of the

standard deviation changes in proportion to the size of the mean. RPD is another commonly used variability measure that is adjusted for the magnitude of the

measured values. It is used when the true value is unknown, as is the case of duplicate samples, and is given by:

( )RPDX X

X X=

−+

×1 2

1 2 2100

/

Where X1 and X2 are the individual measurements of the duplicate samples.

B5.9 Accuracy

For the purpose of this QA plan, analytical laboratory data accuracy is presented in terms of percent recovery as given by:

% Recovery = Measured value x 100 Actual value Conversely, measurement bias can be expressed in terms of the absolute or relative percent

error as given by: Absolute error = Measured value - actual value Relative percent error = (Measured value - actual value) x 100 Actual value Spike recovery is commonly used to determine the method performance for a given

parameter and matrix:



Value of spike in sample compared to value of spike added or % spike recovery = + added spike - unspiked sample x 100 Value of spike added

Spike recovery data provide a reliable accuracy measure if the spike concentration is 2 to 50 times the background concentration.



B6 INSTRUMENT/EQUIPMENT TESTING, INSPECTION, AND MAINTENANCE REQUIREMENTS

This section describes the procedures to ensure and maintain the readiness of the field equipment throughout all phases of the project. Corrective procedures and responsible staff members for corrective actions on analytical instruments located in the laboratories are discussed in Section B4.2 of this plan.

B6.1 Instrument Testing/Inspection Prior to collection of data, each of the monitoring stations is acceptance tested for one week,

minimum, in the same configuration and location in the field where it will be operated. The purpose is to run operational checks to catch problems prior to collection of data; repair all malfunctioning equipment; and familiarize and train new operators, technicians, and field auditors. The basis for final acceptance testing is 80 percent valid data capture for all parameters.

B6.2 Preventive Maintenance Procedures This section describes the routine preventive maintenance procedures performed on field

ambient air monitoring/ sampling systems. Generally, field technicians of the appropriate subcontractors are responsible for all minor maintenance of monitoring systems per the contract. The subcontractor is also responsible for making arrangements for all major maintenance per the contract. A backup technician may be called if the primary technician is not available.


Routine preventive maintenance procedures and schedules for continuous criteria pollutants are described in the TNRCC Preventive Maintenance Instructions Manual and in instrument service manuals.


Routine preventive maintenance procedures and schedules for H2S are described in the instrument service manuals and in the DRAFT TCEQ Standard Operating Procedure for monitoring H2S.


Preventative maintenance is in accordance with recommendations from the manufacturer.


The following checks of the meteorological measurement instrumentation for wind speed, wind direction, temperature and relative humidity are performed by the operator during each visit to the site:



• Visually exam the position of the meteorological sensors. If the sensors are not mounted in the correct position, then the condition is documented in the logbook and corrected as soon as possible.

• Visually inspect the spinning of the cups on the anemometer and the condition of the cups (i.e., missing cups, damage to the cups, etc.). If the cups are damaged and/or the motion of the cups is not what would be expected given current wind conditions, then the sensor and electronic checks outlined below are performed.

• Listen to the fan motor of the radiation shield for operation. If the motor is not running, then note the condition in the station logbook, and repambient the motor as soon as possible.

• Review the most recent display of the meteorological data and verify that the values recorded correspond to current atmospheric conditions. Note any discrepancies in the station logbook. The site operator will report any discrepancies noted during the site visits to the field operations and data management staff.


Routine preventive maintenance procedures are specified in the instrument manuals and detailed in the current version TCEQ standard operating procedures (SOPs). See Appendix E.


Routine preventive maintenance procedures are specified in the instrument manuals and detailed in the current version of the DRAFT standard operating procedures (SOPs). See Appendix E.

B6.2.7 Volatile Organic Compound (VOC) Canister Samplers

Routine preventive maintenance procedures for the VOC canister sampler are described in the current version TCEQ Ambient Monitoring Equipment Preventive Maintenance Manual.

B6.2.8 Canister VOC Analysis

Routine preventive maintenance is performed by laboratory staff and/or contract personnel as described in the instrument manuals. This primarily consists of routine maintenance of mass spectrometer pumping systems.

B6.3 Corrective Maintenance Procedures This section describes the routine corrective maintenance procedures performed on ambient

air monitoring/sampling systems.

B6.3.1 SO2 Corrective maintenance procedures for the continuous SO2 monitors follow the

manufacturer's recommendations in the instrument service manuals.



B6.3.2 H2S Corrective maintenance procedures for the continuous H2S monitors follow the


B6.3.3 Time Lapse Video Corrective maintenance procedures for the meteorological equipment follow the

manufacturer's recommendations in the video service manuals.

B6.3.4 Meteorological Measurement Systems Corrective maintenance procedures for the meteorological equipment follow the


B6.3.5 VOCs by Automated GC

Corrective maintenance procedures for the automated GC follow the manufacturer's recommendations in the service manual.


Corrective maintenance procedures for the Methane and Total Non-methane Hydrocarbons by FID will follow the manufacturer's recommendations in the service manual.

B6.3.7 VOC Canister Samplers

Corrective maintenance procedures for the canister sampler are described in the TCEQ Ambient Monitoring Equipment Preventive Maintenance Manual.

B6.3.8 VOC Canister Analysis

Corrective maintenance procedures for all organic laboratory analytical equipment are described in the instrument manuals. Laboratory staff perform routine corrective action and the service contract personnel are available for non-routine hardware/software repairs.

B6.4 Availability of Spare Parts A minimum stock level shall be maintained by the subcontractor and stored in the designated

location for all critical parts as determined by either the manufacturer's recommendation, experience or the UT Austin Project Manager.



B7 INSTRUMENT/EQUIPMENT CALIBRATION AND FREQUENCY

This section identifies the instruments, tools, and standards whose quality must be controlled, the methods and frequency of calibration, the calibration and performance standards, and the traceability of the standards. Table B5 in Appendix C contains summaries of the calibration requirements. Appendix F has the acceptance criteria for primary, secondary and cylinder gas standards. It is the responsibility of each participant to maintain documentation regarding the traceability of the standard materials used as references for calibration purposes via logbooks or electronic logs.

B7.1 Calibration


The SO2 calibration gases will be derived from secondary standard span gas bottles that have been certified by the vendor. The primary cylinders are standardized by the National Institute of Standards and Technology (NIST) Standard Reference Materials (SRMs). Procedures for SO2 gas cylinders are given in TCEQ Technical Support Laboratory SOPs. Calibrations in the field are performed at the beginning of sampling, as needed because of instrument adjustments or repair or at least every six months. Five levels of calibration standard gases are introduced automatically at a programmed time into the inlet of the analyzers by a Tanabyte Model 300 Dynamic Dilution calibrator in the monitoring station. The levels correspond to 80 percent, 60 percent, 40 percent, 18 percent, and 0 percent of the analyzer operating span range.


The H2S calibration gases will be derived from secondary standard span gas bottles that have been certified by the vendor. The primary cylinders are standardized by the National Institute of Standards and Technology (NIST) Standard Reference Materials (SRMs). Procedures for H2S gas cylinders are given in TCEQ Technical Support Laboratory SOPs. Calibrations in the field are performed at the beginning of sampling, as needed because of instrument adjustments or repair or at least every six months. Five levels of calibration standard gases are introduced automatically at a programmed time into the inlet of the analyzers by a Tanabyte Model 300 Dynamic Dilution calibrator in the monitoring station. The levels correspond to 80 percent, 60 percent, 40 percent, 18 percent, and 0 percent of the analyzer operating span range.

B7.1.3 Meteorological Equipment

A functional check of the equipment prior to the start of sampling and following any sensor or system change or adjustment is performed. Table B5 in Appendix C contains further details regarding the calibration of the wind direction, wind speed, temperature sensors, and relative humidity sensors.




The continuous GC is initially calibrated by the contractor field technicians using carbon response factors developed from the analysis of propane and benzene. Initially multicomponent retention time standards are used to set the retention windows for the peaks of interest. The procedures are given in the current version Texas Commission on Environmental Quality (TCEQ) Standard Operating Procedure (SOP) “Determination of Volatile Organics in Ambient Air by Gas Chromatography with Dual Flame Ionization Detectors” in draft form. Thereafter, a clean air blank and 15-component standard are run on a daily basis to verify the retention time stability and cleanliness of the system. Propane and benzene are used for quantitative calibration of the continuous GC.


The FID Methane and Total Non-methane Hydrocarbon calibration gases will be derived from secondary standard span gas bottles that have been certified by the vendor. The primary cylinders are standardized by the National Institute of Standards and Technology (NIST) Standard Reference Materials (SRMs). Procedures for standard gas cylinders are given in TCEQ Technical Support Laboratory SOPs. Calibrations in the field are performed at the beginning of sampling, as needed because of instrument adjustments or repair or at least every six months. Five levels of calibration standard gases are introduced automatically at a programmed time into the inlet of the analyzers by a Tanabyte Model 300 Dynamic Dilution calibrator in the monitoring station. Owing to the skewed nature of the observed data, the levels correspond concentrations expected for the vast majority of samples, but small compared to the full-scale range: 1.6 percent, 1.2 percent, 0.8 percent, 0.36 percent, and 0 percent of the analyzer operating span range.

B7.1.6 Canister VOC Sampler

The volatile organic compound (VOC) canister sampler is designed to have a stable flow rate (dependent on the sampling period) in cubic centimeter (cc) per minute (min) in order to collect a sample from an evacuated canister for the total sampling time and still maintain a vacuum at the end of the sampling. The expected pressure change in the canister is -14.4 pounds per square inch gauge (psig) (initial) to –2.5 psig (final). The flow rate is controlled with a mass flow controller from the datalogger. The flow sensor part of the flow controller is calibrated at the start of the project. The slope and intercept are entered into the datalogger as initialization parameters. From these, the datalogger calculates and outputs the correct set point voltage for the required flow. The pressure transducer in the VOC canister sampler is calibrated before the sampler is deployed and after any major maintenance. The slope and intercept are entered into the associated data logger as initialization parameters. From these, the data logger calculates the correct pressure readings.

B7.1.7 VOC Canister Samples

The UT Austin CEER laboratory maintains the calibration of the instruments used to analyze the canister samples. A multipoint calibration is performed annually after major system



or procedural modifications or when the daily calibration verification standard fails. Calibration procedures are in the current version TCEQ SOP AMOR-006. This procedure is available on the TCEQ local server.

B7.2 Traceability The calibration system flow rates produced by mass flow controllers are calibrated with a primary flow standard. The primary flow standards used for this purpose are listed below.

Primary Flow Standard

The Technical Support Laboratory has two NIST traceable Molbox flow standards for calibrating transfer standard mass flow meters.

Transfer Standard

The span gas sources are standardized NIST SRMs by the TCEQ Technical Support Team. B7.2.1 SO2 SO2 span and transfer standard cylinder gases are verified against NIST SRM cylinder gases. The detailed procedures are given in TCEQ Technical Support Laboratory SOPs. Criteria for acceptance of these gases from suppliers appear in Appendix F. All gases are certified EPA protocol NIST traceable by the vendor. B7.2.2 H2S H2S span and transfer standard cylinder gases are verified against NIST SRM cylinder gases. The detailed procedures are given in TCEQ Technical Support Laboratory SOPs. Criteria for acceptance of these gases from suppliers appear in Appendix F. All gases are certified EPA protocol NIST traceable by the vendor.

B7.2.3 Meteorological Equipment

The TCEQ Technical Support Team within the Laboratory and Mobile Monitoring Section maintains the equipment necessary for calibration of the meteorological equipment. The standards used are a Sokkia transit for wind direction, a Climatronics tachometer drive for wind speed and a NIST traceable ASTM 91C Thermometer. These standards are maintained according to the instrument manufacturers’ specifications.

B7.2.4 VOCs by Automated GC

The continuous GC systems for VOC analysis are calibrated with vendor certified standards that are purchased with certificates of analysis, which are verified upon receipt.


The FID Methane and Non-methane Hydrocarbon span and transfer standard cylinder gases are verified against NIST SRM cylinder gases. The detailed procedures are given in TCEQ Technical Support Laboratory SOPs. Criteria for acceptance of these gases from suppliers appear in Appendix F. All gases are certified EPA protocol NIST traceable by the vendor.



B7.3 Documentation It is the responsibility of each subcontractor to maintain documentation regarding the traceability of the standard materials used as references for calibration purposes. Site logbooks, electronic logs, and data are maintained by the site operator with copies maintained by UT Austin project staff.



B8 INSPECTION/ACCEPTANCE REQUIREMENTS FOR SUPPLIES AND CONSUMABLES

This section identifies the quality objectives for supplies and consumables to ensure high, valid data return.

B8.1 Sampling Supplies Each subcontractor is required order/obtain, prepare, and store per UT Austin contract terms

at each monitoring site all required sampling materials and supplies for operating analyzers and samplers.

The chemist from the UT Austin CEER laboratory is responsible for ordering and inspecting analytical materials and supplies used in the analysis of samples. These include reagents and solvents.

B8.2 Standards Standards for the analytical calibrations shall be ordered by the subcontractor on an as needed

basis either from EPA or from commercial suppliers who provide standards meeting applicable EPA requirements. Standards are either traceable to National Institute of Standards and Technology (NIST) or are certified by the vendor and certification of traceability is kept on file by each laboratory.

B8.3 Spare Parts Each subcontractor shall procure per UT Austin contract terms and conditions, store where

designated by the UT Austin Project Manager, and maintain an inventory of spare parts for all field equipment based on equipment manufacturer’s recommendations, experience, and project history. Spare parts are tracked on a PC-based inventory system by UT Austin. These items are normally not expected to be tested upon receipt. However, if problems are observed when they are used in the field, the manufacturer shall be contacted by the subcontractor and tests are to be performed to identify and solve the problem.



B9 DATA ACQUISITION REQUIREMENTS (NON-DIRECT MEASUREMENTS)

All data for this project is expected to be direct measurements.



B10 DATA MANAGEMENT

Continuously sampled data are managed within the TCEQ IPS/Meteostar LEADS computer system. Although these data are collected under a different program, they will be used for a variety of purposes by TCEQ, just as the University of Texas CEER will use TCEQ data within LEADS. Noncontinuous data from canister sampling will be handled in flat file format as Excel spreadsheets, which will be imported into SAS. (See Appendix N in development). The UT Quality Assurance officer will compile all data collected under this QAPP so that noncontinuous data may be merged with continuous data for analysis purposes including source appointment and exposure assessment.

B10.1 Sulfur Dioxide (SO2) Data collected for the criteria pollutant SO2 and by the meteorological data monitors are

transferred to the Texas Commission on Environmental Quality (TCEQ) Comms Front-End Processor (CFEP) computer through a Regional Hub computer. The Hub computer is a Hewlett Packard 712/60 that automatically downloads data every fifteen minutes by modem over standard telephone lines. Operator messages and the calibration system parameters are also retrieved.

The continuous monitors in each monitoring station are connected to a Zeno data logger system. The data logger system samples the analog output voltage of each instrument once a second, digitizes it, and stores the data sequentially as five-minute averages into a record. A record consists of sequential fields of data for as many channels as are activated for sampling.

Every 15 minutes, the Hub computer collects the previous data from each monitoring station's data logger by modem. The data are secured from tampering or corruption over the carrier line through an unlisted telephone number, pass code protection, and error checking protocol.

The MeteoStar processing program checks for correct date, time, sampling site number, and proper formatting of raw data fields. It then performs quality control checks on the calibration and span data, and calculates five-minute and hourly averages, converting voltages to engineering units, as outlined in Appendix G and H of this document. At this stage, the data are considered "preliminary validated" data and are stored in a temporary disk file. The subcontractor’s data validators work from this file through their terminals on a graphical interface. The subcontractor’s data validators infrequently edit this file other than to change an incorrect status code that was entered by the field technician. An audit trail is kept of any changes to the data by the entry of the name of the data validator, the date, time, and comments related to any changes made. In addition, the subcontractor’s data validators keep individual notebooks of corrections to data files.

After the subcontractor’s validators validate the data, the data are coded in the file. The coded data in this file are considered "validated data" and are archived on optical disk indefinitely. Data maintained on the CFEP are accessible through Internet web page reports. Appendix I contains a description of the reports available through the TCEQ web page.

After the validated data have been archived, project personnel continue to review the data for higher levels of data validation. These analysis reviews include performing comparisons over



time between monitoring stations that are closely located or in very similar geographic locations and performing comparisons over time between parameters measured at the same station. If there is clear evidence that a problem exists that was not detected by earlier stages of data validation, then the Quality Assurance Officer may choose to invalidate the data.

B10.2 Hydrogen Sulfide (H2S) Data collected for the H2S monitoring system and by the meteorological data monitors are transferred to the Texas Commission on Environmental Quality (TCEQ) Comms Front-End Processor (CFEP) computer through a Regional Hub computer. The Hub computer is a Hewlett Packard 712/60 that automatically downloads data every fifteen minutes by modem over standard telephone lines. Operator messages and the calibration system parameters are also retrieved. The continuous monitors in each monitoring station are connected to a Zeno data logger system. The data logger system samples the analog output voltage of each instrument once a second, digitizes it, and stores the data sequentially as five-minute averages into a record. A record consists of sequential fields of data for as many channels as are activated for sampling. Every 15 minutes, the Hub computer collects the previous data from each monitoring station's data logger by modem. The data are secured from tampering or corruption over the carrier line through an unlisted telephone number, pass code protection, and error checking protocol. The MeteoStar processing program checks for correct date, time, sampling site number, and proper formatting of raw data fields. It then performs quality control checks on the calibration and span data, and calculates five-minute and hourly averages, converting voltages to engineering units, as outlined in Appendix G and H of this document. At this stage, the data are considered "preliminary validated" data and are stored in a temporary disk file. The subcontractor’s data validators work from this file through their terminals on a graphical interface. The subcontractor’s data validators infrequently edit this file other than to change an incorrect status code that was entered by the field technician. An audit trail is kept of any changes to the data by the entry of the name of the data validator, the date, time, and comments related to any changes made. In addition, the subcontractor’s data validators keep individual notebooks of corrections to data files. After the subcontractor’s validators validate the data, the data are coded in the file. The coded data in this file are considered "validated data" and are archived on optical disk indefinitely. Data maintained on the CFEP are accessible through Internet web page reports. Appendix I contains a description of the reports available through the TCEQ web page. After the validated data have been archived, project personnel continue to review the data for higher levels of data validation. These analysis reviews include performing comparisons over time between monitoring stations that are closely located or in very similar geographic locations and performing comparisons over time between parameters measured at the same station. If there is clear evidence that a problem exists that was not detected by earlier stages of data validation, then the Quality Assurance Officer may choose to invalidate the data.

B10.3 Meteorological Data



The meteorological equipment consists of the MetOne Meteorological System with sensors mounted on a cross arm atop a 10-meter mast; the translators/signal conditioners, power supply, and mainframe assembly are located inside the trailers. The parameters measured are wind speed, wind direction, temperature and relative humidity. The subcontractor’s personnel, approved by UT Austin as meteorological data validators, validate the data. The MDMA Section provides the validated data to users. All data are maintained in a database by the TCEQ MDMA Section. The data printouts, corresponding site logbooks, and quarterly audit results are used by the data processing and reporting staff for validation. Agreement between the local National Weather Service measurements and the expected meteorological conditions with those reflected by the site instrumentation are also used as a validation tool. The EPA guidance for meteorological data editing criteria is used to assess the meteorological data. Meteorological data that has been validated are stored on optical disk at TCEQ.

B10.4 VOCs by Automated Gas Chromatograph Data Once a day, data from the automated GC are transferred directly to a host PC in the auto GC

validation area. The subcontractor’s GC data validators, approved by UT Austin as validators, download data from the site's automatic GC computer via a file transfer protocol (FTP). The files are transferred to a Windows NT server for processing and data validation.

B10.5 Methane and Total Non-methane Hydrocarbon Data Data collected by the FID Methane and Total Non-methane Hydrocarbon monitors are

transferred to the Texas Commission on Environmental Quality (TCEQ) Comms Front-End Processor (CFEP) computer through a Regional Hub computer. The Hub computer is a Hewlett Packard 712/60 that automatically downloads data every fifteen minutes by modem over standard telephone lines. Operator messages and the calibration system parameters are also retrieved.

The monitors in each monitoring station are connected to a Zeno data logger system. The data logger system samples the analog output voltage of each instrument once a second, digitizes it, and stores the data sequentially as five-minute averages into a record. A record consists of sequential fields of data for as many channels as are activated for sampling.

Every 15 minutes, the Hub computer collects the previous data from each monitoring station's data logger by modem. The data are secured from tampering or corruption over the carrier line through an unlisted telephone number, pass code protection, and error checking protocol.

The MeteoStar processing program checks for correct date, time, sampling site number, and proper formatting of raw data fields. It then performs quality control checks on the calibration and span data, and calculates five-minute and hourly averages, converting voltages to engineering units, as outlined in Appendix G and H of this document. At this stage, the data are considered "preliminary validated" data and are stored in a temporary disk file. The subcontractor’s data validators work from this file through their terminals on a graphical interface. The subcontractor’s data validators infrequently edit this file other than to change an incorrect status code that was entered by the field technician. An audit trail is kept of any changes to the data by the entry of the name of the data validator, the date, time, and comments



related to any changes made. In addition, the subcontractor’s data validators keep individual notebooks of corrections to data files.

After the subcontractor’s validators validate the data, the data are coded in the file. The coded data in this file are considered "validated data" and are archived on optical disk indefinitely. Data maintained on the CFEP are accessible through Internet web page reports. Appendix I contains a description of the reports available through the TCEQ web page.

After the validated data have been archived, project personnel continue to review the data for higher levels of data validation. These analysis reviews include performing comparisons over time between monitoring stations that are closely located or in very similar geographic locations and performing comparisons over time between parameters measured at the same station. If there is clear evidence that a problem exists that was not detected by earlier stages of data validation, then the Quality Assurance Officer may choose to invalidate the data.

B10.6 Canister Volatile Organic Compound (VOC) Data Each report file is output by the VOC analytical system in the UT Austin CEER laboratory

and is converted to a Microsoft EXCEL file for storage on the laboratory data server in the canister VOC database. The files containing the final measurement values for each sample are then made available to the Quality Assurance Officer, who is the custodian of the files. The Quality Assurance Officer maintains the integrity of the VOC database and supplies data to users.

B10.7 Time Lapse Video The media for this activity is digital and is electronically processed and transferred to the UT

Austin Corpus Christi Air Monitoring and Surveillance Camera Network Project Office for analysis and archival.



The University of Texas at Austin

Center for Energy & Environmental Resources Laboratory

Field Collection

M o n i t o r i n g O p e r a t i o n s D i v i s i o n M o n i t o r i n g D a t a M a n a g e m e n t

a n d A n a l y s i s S e c t i o n A i r P o l l u t i o n M e t e o r o l o g y T e a m

D a t a M a n a g e m e n t T e a m

Public

O f fici e f E n g i n e e r O f f i c e T o x i c o l o g y a n d R i s k A s s e s s m e n t S e c t i o n

Canister VOC

SO2, H2S, Methane TNMOC, Meteorological, and Auto GC VOC

*Database

Figure B10.A Sample/Data Flows and Storage

Corpus Christi Regional Office/ Citizen’s Advisory Board

B10.8 Acceptability of the Hardware/Software Configuration The TCEQ Regional Office Hub Computer, a Hewlett Packard 712/60, periodically calls each Zeno datalogger assigned to the region, collects the data measurements and operator log entries, makes local backup copies of the measurements and operator logs, then transmits the measurements and operator logs to the Comms Front-End Processor (CFEP) in Austin at the TCEQ headquaters. The CFEP handles the agency data processing needs, the quality control processing of O3, and oxides of nitrogen pollutant data, the data reduction of raw data to hourly averages, and the long-term storage of validated continuous and noncontinuous data. It provides



data access and data editing capability to data validators through remote PC ports. The system is considered adequate to meet the current needs of the data users.

Daily performance checks and routine maintenance are performed on the equipment to ensure maximum run time and minimum data loss due to failure of disk storage devices. Data are stored daily on the computer hard drive. They are archived on an electro-optical disk.

Downloading and editing of data from the CFEP are restricted to data validators by password protection and restricted addresses. Data editing is done on-line on a PC with terminal emulation software. Data entry errors are minimized by the use of customized editing screens and data fields that perform legal character checking and provide an opportunity for the validator to check the data before it is uploaded to the permanent file. Error checking codes on the transmission protocol and confirmation of data received by the CFEP provide additional security.

Data validators make corrections to data using a graphical interface. A change in the database creates an automatic entry with an audit trail containing the name of the validator, the date of the change, dates of the data changes, and a comment field to document why the data were edited. Original raw voltages are stored in the archive.

Data from the Noncontinuous Air Monitoring Stations not stored on the CFEP are stored on UT servers. Data editing is controlled by the Quality Assurance Officer.

B10.9 Data to Users Data may be provided to users by e-mail, Internet web page, on floppy disk, or on printouts.

Requests for data are made through the project database managers. Large volumes of data may be shipped via File Transfer Protocol (FTP). Some internal customers have read-only access. All data that have not been verified and validated by Monitoring Data Management and Analysis staff must be accompanied by a disclaimer with any data release. Data released to external customers must be accompanied by a TCEQ Health Effects evaluation. Additionally, access to the US District Court Air Monitoring and Surveillance Camera Network data are available through the project website at www.utexas.edu/research/ceer/ccaqp.

The University of Texas at Austin Section C1 United States District Court Corpus Christi Air Monitoring and Surveillance Camera Network Project Quality Assurance Project Plan


C1 ASSESSMENTS AND RESPONSE ACTIONS

Review of process performance is done on a continuous basis. This section addresses the assessment and response actions for this project.

C1.1 Technical Systems Audit Technical systems audits are thorough, systematic, on-site qualitative audits of facilities,

equipment, personnel, training procedures, record keeping, data validation, data management, and reporting aspects of a system. They focus on conformance to specifications. Technical systems audits are routinely performed in the field, laboratory, and data processing center as part of normal monitoring operations. They are conducted annually, and more frequently if deemed necessary, by the project quality assurance (QA) officer. Methods for conducting technical systems audits are discussed in Volume II of the U.S. Environmental Protection Agency (EPA) Quality Assurance Handbook for Air Pollution Measurement Systems, the TCEQ Quality Management Plan, and the Operating Policy and Procedure (OPP) 18.9.2.

C1.1.1 Field Technical Systems Audit

Each sampling system is audited for proper physical operation. The audit is performed during sample collection and documented on an audit checklist. Checklists are used for general site condition and the individual sampling systems. Certain critical parameters are checked either visually or by measurements. If the values do not fall within certain predetermined limits, the instrument or system in question is referred to the responsible technician and project coordinator for further investigation and correction.

The project QA officer shall recommend to the principal investigator and project manager to stop work in order to safeguard programmatic objectives, worker safety, public health, or environmental protection.

The project QA officer will annually perform on-site technical systems audits at all network monitoring stations based on a review of network performance. These audits are methodical examinations with the intent to verify conformance to a standard, to examine what is against what is planned, and to determine if the plan is adequate.

The following systems audits are performed to assess the proper operation of the monitoring station system and observe the general condition of the entire station

C1.1.1.1 Assessment of Sulfur Dioxide (SO2) The project QA officer or designee performs on-site system audits of monitoring systems at

least once a year. This audit consists of measuring flows and other parameters that are critical to the proper operation of the monitoring station systems and observing the general conditions of the entire system. Any problems found are referred to the appropriate subcontractor’s field technician for correction.

C1.1.1.2 Assessment of Hydrogen Sulfide (H2S) The project QA officer or designee performs on-site system audits of monitoring systems at least once a year. This audit consists of measuring flows and other parameters that are



critical to the proper operation of the monitoring station systems and observing the general conditions of the entire system. Any problems found are referred to the appropriate subcontractor’s field technician for correction.

C1.1.1.3 Assessment of Meteorological Equipment

At least once per calendar year, all meteorological equipment will be audited by the project QA officer or designee.

C1.1.1.4 Assessment of Automated Gas Chromatograph (GC)

The project QA officer or designee will annually perform on-site technical systems audits on the continuous GC monitors at selected sites based on a review of network performance. These audits are methodical examinations with the intent to verify conformance to a standard, to examine what is against what is planned, and to determine if the plan is adequate for what is required. Audit findings are documented in a formal audit report and distributed to the field regional management, field operators, and the project coordinator. Resolution is accomplished by the formation and implementation of a corrective action plan.

C1.1.1.5 Assessment of Methane and Total Non-methane Hydrocarbon Monitors

The project QA officer or designee performs on-site system audits of monitoring systems at least once a year. This audit consists of measuring flows and other parameters that are critical to the proper operation of the monitoring station systems and observing the general conditions of the entire system. Any problems found are referred to the appropriate subcontractor’s field technician for correction.

C1.1.1.6 Assessment of Volatile Organic Compound (VOC) Canister Samplers

At least once a year, the project QA officer or designee performs an on-site technical systems audit of each sampler that obtains canister samples at each site in the network These audits are methodical examinations with the intent to verify conformance to a standard, to examine what is against what is planned, and to determine if the plan is adequate for what is required. Audit findings are documented in a formal audit report and distributed to the field regional management, field operators, and the project coordinator. Resolution is accomplished by the formation and implementation of a corrective action plan.

C1.1.1.7 Assessment of Time Lapse Video

At least once a year, the field technician performs a visual inspection of the video equipment. These inspections determine the condition of certain critical components to achieve reliable data. There are no specific audit criteria for this monitoring method.

C1.1.2 Field Inspections

Inspections are activities such as measuring, examining, testing, or gauging one or more characteristics of an entity and comparing the results with the specified requirements in order to establish whether conformance is achieved for each characteristic. During field inspections, each sampling system is inspected for proper physical operation. The inspection is performed during



sample collection and documented on an audit checklist. Checklists are used for general site condition and the individual sampling systems. Certain critical parameters are checked either visually or by measurements. If the values do not fall within certain predetermined limits, the instrument or system in question is referred to the responsible technician and project coordinator for further investigation and correction.

C1.1.3 Laboratory Technical Systems Audit

Laboratory audits are performed once per calendar year by the project QA officer or designee. The laboratory assessments are conducted in accordance with the TCEQ QMP and OPP 18.9.2.

C1.2 Performance Evaluations Performance evaluations include response accuracy assessments for SO2, laboratory analysis

of VOC canister samples, and automated GC analysis. Performance evaluation methods for SO2 and H2S samplers conform to the EPA guidelines published in the EPA Quality Assurance Handbook for Air Pollution Measurement Systems. The performance evaluation methods for the automated GC and analysis for VOC canister sampling are developed by the TCEQ Laboratory and Mobile Monitoring Section, Ambient Monitoring Section, and Field Operations and also conform to the guidelines in the EPA Quality Assurance Handbook for air Pollution Measurement Systems. Laboratory and continuous GC audit procedures are adopted from the EPA methods TO-15 and TO-14-A, Compendium of Methods for the Determination of Toxic Organic Compounds in Ambient Air.

The following performance evaluations of field systems are performed on the measurement system. They are normally conducted to assess the accuracy of the measurement data.

C1.2.1 Field Assessment

C1.2.1.1 SO2

Assessment of the continuous monitors for gaseous SO2 is performed by the Project QA Officer or designee once per calendar year. Transfer standards used are different from those used in the previous standardization of the calibration systems in the monitoring station. The instruments are evaluated at the following concentration levels:

Level SO2

1 0.05 - 0.15 ppm* 2 0.15 - 0.25 ppm 3 0.25 - 0.35 ppm 4 0.35 - 0.45 ppm

*Parts per million (ppm)

If the full-scale range of a monitor is 1.0 or 1000 parts per billion (ppb), then level four is audited in addition to levels one through three.



These levels are used to assess the accuracy of each analyzer as required by 40 Code of Federal Regulations (CFR) 58, Appendix A.

If the percent difference between the known concentration and the measured concentration for any level is more than ±20 percent, then the assessment is failed. A failed assessment requires investigation of the cause by the monitoring station technician. The instrument is then repaired, if necessary, and recalibrated.

In addition to the instrument assessments, field operators perform laboratory control checks (LCCs) twice each quarter. The LCCs serve as assessments of the previously assigned concentration. The LCCs procedure is described in the TNRCC Ambient Air Quality Network Field Quality Control Manual. The assessment is failed if the difference between the previous and the assessment concentration is more than ±15 percent.

The University of Texas at Austin, in conjunction with the TCEQ, also participates in the National Performance Audit Program (NPAP), which is administered by the EPA, for O3, SO2, nitrogen dioxide (NO2), and CO. The project QA officer and subcontractors, using audit gas standards and dilution systems provided by the EPA, coordinate these audits.

C1.2.1.2 H2S

Assessment of the continuous monitors for gaseous H2S is performed by the Project QA Officer or designee once per calendar year. Transfer standards used are different from those used in the previous standardization of the calibration systems in the monitoring station. The instruments are evaluated at the following concentration levels:

Level H2S

1 0.05 - 0.15 ppm* 2 0.15 - 0.25 ppm 3 0.25 - 0.35 ppm 4 0.35 - 0.45 ppm


If the full-scale range of a monitor is 1.0 or 1000 parts per billion (ppb), then level four is audited in addition to levels one through three.

If the percent difference between the known concentration and the measured concentration for any level is more than ±20 percent, then the assessment is failed. A failed assessment requires investigation of the cause by the monitoring station technician. The instrument is then repaired, if necessary, and recalibrated.




C1.2.1.3 Meteorological Equipment

Once per year, the meteorological instruments are audited by the project QA officer or designee using direct reading sensors or by collocating a second set of transfer standard meteorological instruments.

C1.2.1.4 VOCs by Automated GC

At least twice a year, the instrument will be challenged with samples prepared from standard sources different from those used to prepare the calibration standards or obtained as part of a round robin type audit program

C1.2.1.5 Methane and Total Non-methane Hydrocarbons

Assessment of the continuous monitors for gaseous Methane and Non-methane hydrocarbons measured by the FID is performed by the Project QA Officer or designee once per calendar year. Transfer standards used are different from those used in the previous standardization of the calibration systems in the monitoring station. The instruments are evaluated near the midpoint of the following concentration levels:

Level Methane

1 0.5 - 1.5 ppm* 2 1.5 - 2.5 ppm 3 2.5 - 3.5 ppm 4 3.5 - 4.5 ppm


Level Total NMHC

1 0.3 - 0.7 ppm* 2 0.7 - 1.0 ppm 3 1.0 - 1.3 ppm 4 1.3 - 1.7 ppm


These levels are used to assess the accuracy of each analyzer as required by 40 Code of Federal Regulations (CFR) 58, Appendix A.

The full-scale range of monitors for TNMHC are either 100 parts per million (100,000 parts per billion), 50ppm (50,000 ppb), or 5 ppm (5,000 ppb) depending on where and when the data are collected. In 2006, three sites – Donna Park, Oak Park, and Solar Estates – will have the 5 ppm range, and the other four will have the 50 ppm range. The levels selected for evaluation are based on assuring monitoring accuracy in the expected range of the vast majority of data and around the level at which canister samples are triggered, and are thus well below the maximum recordable levels.

If the percent difference between the known concentration and the measured concentration for any level is more than ±20 percent, then the assessment is failed. A failed assessment requires



investigation of the cause by the monitoring station technician. The instrument is then repaired, if necessary, and recalibrated.


At least twice a year, the instrument will be challenged with samples prepared from standard sources different from those used to prepare the calibration standards or obtained as part of a round robin type audit program

C1.2.1.6 VOC Canister Analysis

At least twice a year, a performance evaluation sample is submitted to the UT Austin CEER laboratory for analysis. Each instrument will be challenged with these QA samples from standard sources different from those used to prepare the calibration standards or obtained as part of a round robin type audit program.

C1.2.1.7 Time Lapse Video

No performance evaluation procedures currently exist for this method. Visual observation of the recording serves as an indicator of the equipment function.

C1.2.2 Laboratory Assessment

Laboratory assessment will be accomplished by the utilization of at least one of the three types of samples for canister sample analysis.

• Field assessment sample is a known standard, which is analyzed in the laboratory after field sampling to assess the laboratory as well.

• Interlaboratory comparison samples are precharacterized ambient field samples shared by several organizations to assess laboratory performance.

• NPAP VOC proficiency samples. This program was established to routinely assess the performance of the participating organizations.

C1.3 Assessment of Data Quality Indicators Assessment of data quality indicators consist of (1) performance evaluations to establish data

accuracy; (2) repeatability checks and collocated samplers to establish data precision; and (3) valid data return calculations to determine data completeness.

C1.3.1 Specific Procedures for Assessment of Data Quality Indicators

C1.3.1.1 Data Precision Assessment



Precision is a measure of agreement among two or more determinations of the same parameter under similar conditions. The assessment of data precision is based on the results of precision checks as described in Title 40 Code of Federal Regulations Part 58, Appendix A.

C1.3.1.1.1 SO2

In the case of the continuous monitor for sulfur dioxide (SO2), the precision check consists of challenging the instrument with a concentration of 0.08 to 0.10 ppm SO2. The data logger in the air monitoring station performs this precision check as part of each monitor span check.

C1.3.1.1.2 H2S

In the case of the continuous monitor for Hydrogen Sulfide (H2S), the precision check consists of challenging the instrument with a concentration of 0.08 to 0.10 ppm SO2. The data logger in the air monitoring station performs this precision check as part of each monitor span check.

C1.3.1.1.3 Meteorological Monitors

There are no collocated meteorological stations. Precision determinations are not expected for these measurements.

C1.3.1.1.4 VOCs by Automated GC Data on precision for VOC (automated GC) measurements are derived from replicate analysis

of standard gas mixtures as a point-in-time measurement of precision and from the duplicate analysis of the daily calibration check on a weekly basis. Precision is expressed as the coefficient of variation for replicate analysis of each target analyte.

C1.3.1.1.5 Methane and Total Non-methane Hydrocarbons

In the case of the continuous monitor for FID monitor the precision check consists of challenging the instrument with a concentration of 260.17 ppm methane and 39.18 propane ppm. The data logger in the air monitoring station performs this precision check as part of each monitor span check.

C1.3.1.1.6 VOC Canister Samples The assessment of data precision for canister samples is based on data from the analysis of

duplicate samples. Analytical method duplicates are analyzed to assess method precision on a batch basis. The laboratory control standard is used to assess precision over time.

C1.3.1.1.7 Time Lapse Video



There are no collocated time lapse video monitors. Precision determinations are not expected for this equipment.

C1.3.1.2 Data Accuracy Assessment

C1.3.1.2.1 SO2

The continuous monitor network accuracy for SO2 is expressed in terms of upper and lower 95 percent probability limits. These limits give a quantitative measure of the accuracy of the ambient data that are reported. The true concentration of the data will have a 95 percent probability of falling within a range bounded by the reported value, plus the upper limit percentage of the value and the reported value, minus the lower limit percentage of the value. The results of the performance audits described in Section C1.2 of this plan are used to calculate accuracy for each instrument. Individual monitor accuracy is expressed in terms of percent difference. The equations used to calculate accuracy are given in 40 CFR 58, Appendix A.

C1.3.1.2.2 H2S

The continuous monitor network accuracy for H2S is expressed in terms of upper and lower 95 percent probability limits. These limits give a quantitative measure of the accuracy of the ambient data that are reported. The true concentration of the data will have a 95 percent probability of falling within a range bounded by the reported value, plus the upper limit percentage of the value and the reported value, minus the lower limit percentage of the value. The results of the performance audits described in Section C1.2 of this plan are used to calculate accuracy for each instrument. Individual monitor accuracy is expressed in terms of percent difference.

C1.3.1.2.3 Meteorological Monitors Accuracy of the meteorological measurements is expressed as a signed difference relative to

the audit standard value.

C1.3.1.2.4 Automated GC and Canister VOC Sampling Accuracy of the laboratory analysis for canister VOCs is based on quarterly performance

evaluations using target analytes at known concentrations. Target analytes are picked at random and the concentration range varies in order to challenge the performance of the systems. However, the range of the target analytes used will be within the calibration range of each system.

The audit sample is prepared in a cleaned, evacuated canister. The cleaning and certification procedure is detailed in SOP AMOR-007, “Procedure for Cleaning Summa Polished Stainless Steel Canisters Using the Entech Cleaning Manifold.” The audit sample is submitted to the UT Austin CEER laboratory for analysis and shipped to the continuous GC monitoring stations for analysis. The contents of the audit sample are analyzed for the components and the percent audit accuracy is calculated as described in Section 12.4 of EPA “Method TO-15” and Section 10.0 in method TO-14A of the Compendium of Methods for the Determination of Toxic Organic Compounds in Ambient Air. If the percent relative accuracy does not meet the project data quality



objectives in Appendix B for the audit target analytes, then an investigation is performed to find an assignable cause.

Automated GC VOC and canister VOC compound accuracy are expressed in terms of average percent recovery by compound based on accurately known audit standards. Accuracy data are expressed in terms of percent recovery, given by

% Recovery = Measured value x 100 Actual value

C1.3.1.2.5 Methane and Total Non-methane Hyrdorcarbons

The continuous monitor network accuracy for the FID analyzer used to measure Methane and Total Non-Methane Hydrocarbons is expressed in terms of upper and lower 95 percent probability limits. These limits give a quantitative measure of the accuracy of the ambient data that are reported. The true concentration of the data will have a 95 percent probability of falling within a range bounded by the reported value, plus the upper limit percentage of the value and the reported value, minus the lower limit percentage of the value. The results of the performance audits described in Section C1.2 of this plan are used to calculate accuracy for each instrument. Individual monitor accuracy is expressed in terms of percent difference. The equations used to calculate accuracy are given in 40 CFR 58, Appendix A.

C1.3.1.3 Data Completeness Assessment

For SO2, H2S, and meteorological parameters, see Section A7.5.5. Data completeness for VOC measurements by automated GC, Methane and Total Non-Methane Hydrocarbon measurements by FID, and canister VOC are calculated on the basis of the number of valid data runs divided by the total number of expected data runs for a given period of time.

Data completeness is calculated as follows: % Completeness = Number of valid measurements x 100 Total number of scheduled measurements In addition, data completeness assessment will include quarterly audits of the data entry into

Air Quality System to assess data availability and submittal according to EPA requirements.

C1.4 Audits of Data Quality

The audit of data quality is an examination of data after they have been collected and verified by project personnel. It documents and evaluates the methods by which decisions were made during the treatment of the data. Audits of data quality are routinely performed on critical parameters as determined by project performance. Currently the project expects to perform data quality audits on a quarterly basis. A separate subcontractor will perform site audits and equipment testing on a quarterly basis. The project Quality Assurance Officer will perform monthly data quality assessments.



C1.5 Corrective Actions Corrective action is an essential part of any quality system and involves those procedures and

actions taken to correct situations causing data quality to fall below established expectations. The need for corrective actions will be minimized by the implementation of the United States District Court Corpus Christi Air Monitoring and Surveillance Camera Network Project Quality Assurance Project Plan, project standard operating procedures (SOPs), and the application of statistical quality control to establish appropriate data quality limits for measurement activities. Corrective action should generally be initiated as soon as possible at the organizational level closest to the problem. Once a quality concern is identified, verbal and written communication between the affected parties begins and continues until the issue is resolved.

Laboratory-related corrective actions are currently handled within the UT Austin CEER laboratory. The analyst has the primary responsibility for detecting and initiating minor corrective action on equipment failures and out-of-control failures that are generally detected by the running of quality control checks on a routine basis. Any major equipment troubles are referred to the Project Manager who has the responsibility to follow up on restoring the equipment to its proper operating status. Any equipment problems that can result in the loss of samples receive high priority.



C2 REPORTS TO MANAGEMENT

C2.1 Quality Assurance (QA) Audit Reports The project QA officer prepares a report after every performance evaluation and technical

systems audit to describe the results according to the Texas Commission on Environmental Quality (TCEQ) OPP 18.9.2. These reports include audit percent error, audit findings, observations, and corrective actions, if appropriate. These reports are distributed to the project manager, subcontractors, project advisory board, and others who are affected by the audit results.

C2.2 Annual Project QA Report The project QA officer prepares a summary of network precision, accuracy, and

completeness for the preceding year. This report is sent to the project manager and subcontractors.

At least annually, the project QA officer reviews quality-related deficiencies, nonconformances, and programmatic improvements and prepares a summary report for the Project Manager and the TCEQ. The Project Manager incorporates the summary into the annual report to the project sponsor, the US District Court, Corpus Christi, Texas.

C2.3 Data Reports Each of the subcontractors is responsible for preparing a quarterly report to the Project

Manager on the following.

C2.3.1 Field Activity Reports

• Hours of SO2, H2S, and meteorological data validated during the last 12 months. • Hours of FID Methane and Total Non-methane validated data during the last 12

months. • Top three hourly values in the last month for SO2, FID Methane and Total Non-

methane Hydrocarbons, and Automated (GC) total non methane hydrocarbons (TNMHC).

• Monthly reports on valid meteorological data returned for each monitoring station, and the average network data returned for the previous 11 months.

• Quarterly reports on the network valid data returned from each monitoring station, and the average network data returned for the previous 12 months.

• Quarterly canister volatile organic compound (VOC) summaries.

C2.3.2 Laboratory Activity Reports

The Quality Assurance Officer is responsible for preparing monthly reports to management on the following:

• Number of valid VOC samples received • Number of VOC samples analyzed



• Number of media blanks analyzed for VOC samples

C2.4 Reporting Schedule Ad hoc reports will be produced as quickly as possible in the event that monitoring data

indicates that ambient concentrations exceed levels considered safe by the Texas Commission on Environmental Quality Toxicology and Risk Assessment Section staff.

The University of Texas at Austin Section D1 United States District Court Corpus Christi Air Monitoring and Surveillance Camera Network Project Quality Assurance Project Plan


D1 DATA REVIEW, VALIDATION, AND VERIFICATION

D1.1 Data Validation Data validation is an integral part of quality management. All air pollutant data and the

conditions under which they were recorded shall be reviewed closely by the UT Austin approved subcontractor’s data validators to determine the validity of the data and whether individual measurements can be included for statistical analysis. Specific standard operations procedures are listed in Appendix E.

In general data are examined in time series and in terms of their percentile ranking with

regard to past values collected under similar conditions. Sudden visible changes in time series behavior (e.g., qualitative detection of cycling or flat-lining or quantitative detection of 20 percent change in running 6 day mean level) triggers an investigation. Furthermore, after merging the data with wind speed and direction, data values are compared to the median, 95th, and 99th percentile values historically observed from the same wind speed and direction categories (e.g., [N,2-5 mph,],[NE,2-5 mph], etc.). Values above the 95th percentile trigger an investigation.

Data will be flagged if the qualitatively judged to have a high likelihood of confounding data

interpretations and leading to wrong conclusions. For example, data values that appear to cycle around the true mean value would produce accurate averages and thus would not be invalidated. Data that flat-line owing to signal attenuation at a concentration two standard deviations above the mean still indicate the presence of high ambient concentrations and thus would not be invalidated.



Auto GC Subcontractor

• Automated gas chromatograph (GC) data validators — for Automated GC volatile organic compound (VOC) data

Quality Control Check Purpose Frequency Acceptance Criteria

Retention Time (RT) Check (56 component)

To help assess retention time shifts and optimize processing methods.

Twice Monthly 100% of the compounds are identified correctly in the 56 component RT check standard

Calibration Verification Standard (CVS)

To assess instrument drift and insure continued instrument calibration.

Daily Propane and benzene % recoveries within 75-125%

Method (Analytical) Blank System Background Daily 1) All target compounds <2 ppbC. 2) Tnmhc < 20 ppbC 3) Data must be bracketed by valid blanks

Precision Check To assess analytical precision

Weekly Propane and benzene %RPD < 20%

5 ppbv Laboratory calibration standard (lCS)

2nd Source Twice Monthly Propane and benzene % recoveries within 70-130%

Continuous FID Hydrocarbon Analyzer Subcontractor

• Continuous FID data validators — for continuous FID Methane and Total Non-methane Hydrocarbon (FID) data


Retention Time (RT) Check (2 components)

To help assess retention time shifts and optimize processing methods.

Daily Methane and Non-Methane compounds are identified correctly in the 2 component RT check standard

Calibration Verification Standard (CVS)

To assess instrument drift and insure continued instrument calibration.

Daily Methane and Propane % recoveries within 75-125%

Method (Analytical) Blank System Background Daily 1) Methane and Propane compounds <2 ppbC. 2) Tnmhc < 1 ppbC 3) Data must be bracketed by valid blanks

Precision Check To assess analytical precision

Weekly Methane and Propane %RPD < 20%

5 ppbv Laboratory calibration standard (LCS)

2nd Source Twice Quarterly Methane and Propane % recoveries within 70-130%



As was the case with Auto-GC validation, data are reviewed for anomalies, and related

assignable causes. TCEQ and UT Austin CEER Laboratory (Chemists) VOC data as collected in canisters are validated through multiple checks. Laboratory staff compare quality control check data to laboratory acceptance criteria to ensure adequate instrument linearity, calibration accuracy, analytical precision, and measurement bias. Any parameter not meeting the SOP stated acceptance criteria results in the sample being reanalyzed or an exception report being generated which defines the deviation, what data are impacted, and the affect of the impact on data quality. Sampling data are also reviewed to ensure sample integrity. Any canister found to have leaked 1.0 psig or more prior to or after sampling is invalidated. Any canister leaking 0.5 psig or 1.0 psig requires further investigation which may lead to invalidation. The following table outlines additional sampling checks and acceptance criteria for VOC sampling.


Sampling Duration (VOC by canisters)

To help ensure that the sample is representative of the scheduled sampling period

Every sample > or = 75% of scheduled sample period

Canister Pressure checks To help ensure sample integrity

Every sample SIS samplers final pressure > 5psig

CS-10 sample final pressure <-0.2 psig and >-9 psig

In addition, the data are reviewed for anomalies. Any anomalies are further inspected for an assignable cause. If an assignable cause if determined, and is not expected to be representative of ambient air during the sampling period, the sample can be validated with the associated documentation on file describing the assignable cause. If an assignable cause is not determined or if the assignable cause would not result in the data not being representative of the expected sample period, the data are not invalidated. An example may be elevated 1-butene, n-butane concentrations but the meteorology showed light winds and the wind direction coming directly from a C4 chemical facility. A likely assignable cause could be established and these data would not be invalidated.



Air Pollution and Meteorology Data Subcontractor

• Wind speed, wind direction, ambient temperature, relative humidity– the three primary bases for data validation are: 1) agreement among various sites within a geographic (mesoscale) area; 2) agreement of observations with historic data, since diurnal and seasonal patterns are well known; 3) agreement between short term measurements and the model forecasts for the geographic (mesoscale) area.

Parameter Accept Reject Wind speed

Data agree with model forecasts and compare well with nearby sites based on the judgment of staff meteorologists

Wind speed stuck on one value, or judged to be unreasonable based on significant disagreement with model forecasts and other nearby sites

Wind direction

Data agree with model forecasts and compare well with nearby sites based on the judgment of staff meteorologists

Wind direction stuck on one value or in one quadrant, or judged to be unreasonable based on significant disagreement with model forecasts and other nearby sites

Ambient temperature

Data agree with historical diurnal pattern of temperature based on observed weather, model forecasts, comparisons with nearby sites, and the judgment of staff meteorologists

Measurements under very humid conditions may be compromised by corrosion, usually manifested by morning readings dropping too low compared with other sites. Measurements take under aspirator failure will be much higher than other sites in the area

Relative humidity Data agree with model forecasts and compare well with nearby sites based on the judgment of staff meteorologists

Humidity stuck on one value, or judged to be unreasonable based on significant disagreement with model forecasts and other nearby sites

• Integrity of databases TCEQ has individual Standard Operating Procedures (SOP) for the above activities. See

Appendix L, References.



D1.1.1 SO2

Initial data review and validation is performed by the software support system as described in B10.1 of this plan. The validation during processing consists of quality control (QC) checks on the five-minute raw data averages. These data processing checks are described in Section B5.1 of this plan.

The computer sets validation flags after the calibrations and span checks are processed. (See Appendix J for flag definitions.)

One of the following corrective actions is taken automatically depending on the type of flag:

• Reject ambient data back to the last accepted calibration or span check. • Accept ambient data back to the last span or calibration. • Reject ambient data forward to the next accepted calibration. • Accept ambient data forward to the next accepted span or calibration. • Use the old (or current) calibration curve. • Use the new calibration curve to compute ambient data.

D1.1.2 H2S





D1.1.3 Methane and Total Non-methane Hydrocarbons







D1.1.4 Time Lapse Video

There are no formal requirements for validation of the data acquired by time-lapse video.

D1.1.5 Meteorological Measurement Systems

Meteorological special purpose monitoring is validated by comparison with meteorological data obtained from the National Weather Service.

D1.2 Data Custody Custody of data is maintained in the Monitoring Data Management and Analysis Section, and

the Organic Analysis Laboratory.

D1.2.1 SO2

Data custody of SO2 data are maintained and managed by the Monitoring Data Management and Analysis Section via computer. Meteorological data is automatically retrieved, maintained and managed through the MeteoStar system.

D1.2.1 H2S

Data custody of H2S data are maintained and managed by the Monitoring Data Management and Analysis Section via computer. Meteorological data is automatically retrieved, maintained and managed through the MeteoStar system.


Data custody of the Methane and Non-methane Hydrocarbon data are maintained and managed by the Monitoring Data Management and Analysis Section via computer. Meteorological data is automatically retrieved, maintained and managed through the MeteoStar system.


UT Austin will maintain custody of the time lapse videos for 5 years.



D1.2.5 Meteorological Measurement Systems

Data custody of meteorological data are maintained and managed by the Monitoring Data Management and Analysis Section via computer.

D1.2.6 UT Austin CEER Laboratory

Analytical results of canister VOC samples are stored on-site for five years. Validated data from canister analyses are transferred to the Quality Assurance Officer, who maintains custody of the data indefinitely.



D2 VALIDATION AND VERIFICATION METHODS

The objective of the data processing and validation effort is to obtain quality assured databases containing the monitoring data in a consistent format. As of January 1, 2003, TCEQ implemented an alternative process method-2. This method is described in Appendix H. The procedures that will be implemented for data processing and validation will ensure that reported data are valid and comparable to those collected by other programs contributing data to this effort. As data are loaded into the databases, they will go through a screening process that will flag any anomalies. The screening routines check all data for outliers, instrument problems, and data system problems. Documentation of changes resulting from review are described in the Data Management Technology Team individual Standard Operation Procedures (SOPs). Comments are added as necessary to explain the basis for the changes.

After the validated data have been archived, data analysts continue to review the data for higher levels of data validation. These analysis reviews include performing comparisons over time between sites that are closely located or in very similar geographic locations and performing comparisons over time between parameters measured at the same site. If there is clear evidence that a problem exists that was not detected by earlier stages of data validation, then the Quality Assurance Officer may choose to invalidate the data.

D2.1 Sulfur Dioxide (SO2) The analysis and flow of the data from the point of collection to storage of validated

concentrations is shown in Section B10, Figure B10. Continuous monitoring data for SO2 are reported in parts per billion (ppb). The equations

used by the MeteoStar System to convert the monitor voltage outputs to ppb are given in Appendix H.

The data are validated based on the following principal criteria:

D2.1.1 Quality Control Test Results Performed by the MeteoStar Computer These tests, described in standard operating procedure (SOP) MeteoStar/LEADS-010

(Appendix K), check for span drift, zero drift, linearity, data outliers, and proper operation of the calibration system.

D2.1.2 Laboratory Control Checks (LCC) Failure of a valid LCC will require rejection of ambient data back to the most recent valid

instrument calibration, three-point span check, audit, or valid LCC and forward to the next valid calibration unless other reasons can be found for the failure of the audit.

D2.2 Hydrogen Sulfide (H2S) The analysis and flow of the data from the point of collection to storage of validated

concentrations is shown in Section B10, Figure B10.



Continuous monitoring data for H2S are reported in parts per billion (ppb). The equations

used by the MeteoStar System to convert the monitor voltage outputs to ppb are given in Appendix H.






D2.3 Meteorological Equipment Data obtained through the MeteoStar computer are compared to data received from the

National Weather Service and nearby stations.

D2.4 Automated Gas Chromatograph (GC) The subcontractor’s data validators review the automated VOC data for abnormal values and

validate the data. The current version Texas Commission on Environmental Quality (TCEQ) Standard Operating Procedure (SOP) “Photochemical Assessment Monitoring Station (PAMS) Auto-GC Data Validation, Standard Operating Operating Procedure (DMAGCO2)”, details the data validation process and criteria. Refer to the Corrective Action Section in Appendix C for disposition of the automated GC data due to failures in these criteria.

The data, stored on computer hard disks, are kept indefinitely in the Monitoring Data Management and Analysis Section on NT servers and backed up on optical disks.

D2.5 Methane and Total Non-methane Hydrocarbons The analysis and flow of the data from the point of collection to storage of validated

concentrations is shown in Section B10, Figure B10. Continuous monitoring data for Methane and Total Non-Methane Hydrocarbons by FID are

reported in parts per million (ppm). The equations used by the MeteoStar System to convert the monitor voltage outputs to ppm are given in Appendix H.








D2.6 Volatile Organic Compound (VOC) Canister Samples Detailed laboratory VOC data processing and validation procedures are included in the

current version TCEQ SOP DATA-003, “Data Processing and Reporting of VOC Data generated via AMOR-006.” Refer to the Corrective Action Section in Appendix C for disposition of VOC canister data due to failures.

D2.7 Time Lapse Video The University of Texas at Austin will archive the camera images.

D2.8 Data Review If an operator notes any unusual or nonstandard conditions, the operator enters the

information in the electronic log, which is reviewed by the data validators. The data validators then determine how these conditions impact the data. Data validators may reject the data based on entries in the operator logs on a case-by-case basis. If, during a review of the ambient data, the data validator discovers abnormal concentrations as compared to expected values based on knowledge of past data, meteorology, and other conditions, the data validator checks electronic logs, span checks, calibrations, and quality control records to determine if there is a reason to invalidate the data in question.

The Monitoring Data Management and Analysis Section store all data indefinitely. Refer to Appendix C for the associated corrective actions for VOC data. Refer to PAMS Auto GC current SOP “DMAGC03” for Auto GC data review. All data are stored indefinitely by the Monitoring Data Management and Analysis Section. The analysis and flow of the data from the point of collection to storage of validated

concentrations is shown in Section B10, Figure B10.A. The Project Quality Assurance Officer (or their designee) reviews all laboratory data for

anomalies and asks the laboratory staff to investigate the value for an assignable cause. Any findings are documented as to the reason for invalidation.



D3 RECONCILIATION WITH USER REQUIREMENTS

Problems with potential limitations of the data are handled at three different levels: (1) at the time of audit of field samplers by the field auditors with field technicians, who have prime responsibility for routine field audits, calibrations, and sampler repairs through telephone contact while the audit or calibration is being performed; (2) data validators with the station technician by telephone, e-mail or with the QA staff; and (3) by users of data, such as the Monitoring Data Management and Analysis Section, who may question or want to verify the data quality objectives with a data validator or QA staff at a later date after data are processed. Issues are reconciled at the lowest level and earliest time possible. The mechanisms for communication between the producers and users of data are the telephone, the operator log in the monitoring station datalogger, the field information data sheets accompanying the field samples, and electronic systems.

The QA officers, field auditors, validators, analysts, and data managers are empowered to review and question any part of the measurement process and may initiate data reviews and corrective actions to bring the process back into compliance.

The TCEQ Monitoring and Operations Division has implemented a tracking mechanism to streamline the request, review, and action procedures involving issues about data quality. Its prime objective is to provide an accessible historical database of information that is now spread out among several logs, forms, and notebooks.

To assess the quality of the data produced during the monitoring efforts, the precision, accuracy, and completeness will be assessed in comparison to the data quality objectives as discussed in Section A7 and listed in Appendix B.

The Project Manager and Quality Assurance Officer will provide an annual report to the U.S. District Judge that describes findings in data quality and in the interpretation of ambient data with regard to the uses of the data listed in A5.3.

The Project Manager and Quality Assurance Officer will provide two briefings a year to the voluntary Advisory Board describing findings in data quality and in the interpretation of ambient data with regard to the uses of the data listed in A5.3. A representative from U.S. EPA Region 6 Compliance Assurance and Enforcement will be invited to these briefings.

D3.1 Detection Limits Analytical detection limits for each method are expected to be established according to

procedures in 40 Code of Federal Regulations (CFR) 136 Part B.

D3.2 Precision Precision for each method will be determined using the procedures outlined in 40 CFR 58,

Appendix A. The percent difference between the known input concentration (Xi) and the analyzer response (Yi) is calculated for each individual calibration check. At the end of the reporting period, the mean (D) and standard deviation(s) of the individual percent differences are computed. Then, the upper (UL) and lower (LL) 95 percent probability limits (PL) are computed and compared to the project objectives.

D3.2.1 Sulfur Dioxide (SO2)



Precision for each pollutant will be determined using the procedures outlined in 40 CFR 58, Appendix A. The percent difference between the known input concentration (Xi) and the analyzer response (Yi) is calculated for each individual calibration check. At the end of the reporting period, the mean (D) and standard deviation(s) of the individual percent differences are computed. Then, the UL and LL 95 percent PL are computed and compared to the project objectives.

UL and LL 95 percent PL for method precision using monitoring data are determined as follows:

UL 95% PL = D + 1.96s( )

LL 95% PL = D − 1.96s( ) where (D) represents the average of measured percent differences of the measured pollutant level from a known sample level during a sampling period and (s) represents the pooled standard deviation of those averages, computed according to 40 CFR Part 58, Appendix A guidance. Average percent difference of a selected compound, (D), is determined as follows:

D =∑i =1

n Yi − Xi

Xi

x 100

n where Xi is the known input concentration and Yi is the analyzer response for the ith sample from n number of samples.

D3.2.2 Hydrogen Sulfide (H2S)

Precision for each pollutant will be determined using the procedures outlined in 40 CFR 58, Appendix A. The percent difference between the known input concentration (Xi) and the analyzer response (Yi) is calculated for each individual calibration check. At the end of the reporting period, the mean (D) and standard deviation(s) of the individual percent differences are computed. Then, the UL and LL 95 percent PL are computed and compared to the project objectives.


UL 95% PL = D + 1.96s( )


D =∑i =1

n Yi − Xi

Xi

x 100

n



where Xi is the known input concentration and Yi is the analyzer response for the ith sample from n number of samples.

D3.2.3 Meteorological Equipment

Precision measurements are not applicable to the meteorological measurements.

D3.2.4 Automated GC VOC

Data for precision will be derived from replicate analyses of standard gas mixtures as a point in time measurement of precision or from the duplicate analysis of the daily control verification standard on a weekly basis. The term routinely used to describe precision is relative percent difference (RPD) based on the use of two replicates. The calculation for precision using duplicate measurements is:

RPD = 100 (X1 - X2) (X1 + X2)/2

Where: RPD = relative percent difference X1 = the larger of the two values X2 = the smaller of the two values

For the quarterly reporting period, precision will be expressed as the coefficient of variation (CV) for replicate analyses of target analytes pooled from a set of determinations during that reporting period.

CV = pooled analytical standard deviation x 100 pooled analytical mean


Precision for both compounds (methane and non-methane hydrocarbons) will be determined using the procedures outlined in 40 CFR 58, Appendix A. The percent difference between the known input concentration (Xi) and the analyzer response (Yi) is calculated for each individual calibration check. At the end of the reporting period, the mean (D) and standard deviation(s) of the individual percent differences are computed. Then, the UL and LL 95 percent PL are computed and compared to the project objectives.


UL 95% PL = D + 1.96s( )




D =∑i =1

n Yi − Xi

Xi

x 100

n where Xi is the known input concentration and Yi is the analyzer response for the ith sample from n number of samples.

D3.2.6 Canister Volatile Organic Compounds

Precision will be determined using the procedures outlined in Section D3.2.4.


There are no collocated time-lapse video monitors. Precision is not assessed.

D3.3 Accuracy Accuracy is the closeness of a measurement to a reference value, and reflects elements of

both bias and precision.

D3.3.1 SO2 Accuracy will be determined by challenging the SO2 monitor with gas standards containing

the compounds of interest at concentrations representative of the ambient atmospheres typically being monitored during the study. The gas standard component concentrations are expected to be within five to 10 times the estimated detection limits.

Accuracy for each pollutant will be determined using the procedures outlined in 40 CFR 58, Appendix A. The percent difference between the known input concentration (Xi) and the analyzer response (Yi) is calculated for each audit level. At the end of the reporting period, the mean (D) and standard deviation(s) of the individual percent differences are computed. Then, the UL and LL 95 percent PL are computed and compared to the project objectives.

D3.3.2 H2S

Accuracy will be determined by challenging the H2S monitor with gas standards containing the compounds of interest at concentrations representative of the ambient atmospheres typically being monitored during the study. The gas standard component concentrations are expected to be within five to 10 times the estimated detection limits. Accuracy for each pollutant will be determined using the procedures outlined in 40 CFR 58, Appendix A. The percent difference between the known input concentration (Xi) and the analyzer response (Yi) is calculated for each audit level. At the end of the reporting period, the mean (D) and standard deviation(s) of the individual percent differences are computed. Then, the UL and LL 95 percent PL are computed and compared to the project objectives

D3.3.3 Meteorological Equipment



Accuracy of the meteorological equipment (wind direction, wind speed, temperature, and relative humidity sensors) are assessed by comparison to collocated audit equipment or by the use of direct reading sensors. The absolute difference between the audit measurement (Xi) and the monitor’s response (Yi) for each parameter is calculated and compared to the project objectives based on Volume IV of the U.S. Environmental Protection Agency Quality Assurance Handbook for Air Pollution Measurement Systems.

Wind Direction Accuracy (absolute difference): ±3 degrees alignment, ±5 degrees overall. (The 1995

guidance for wind direction requires agreement within ±5 degrees azimuth. The guidance for wind direction using direct reading sensors is followed. However, using collocated measurement equipment, the Texas Commission on Environmental Quality’s [TCEQ’s] accepted range for wind direction is ±30 degrees.)

Wind Speed Accuracy (absolute difference): ±0.56 miles per hour (mph) at winds <12.2 mph, ±5 percent

at winds >12.2 mph. Maximum allowable error: 5.6 mph (The 1995 guidance specifies a wind speed accuracy of ±0.2 mph +5 percent of observed speed from 0.5 to 50 mph. This corresponds to ±0.447 mph +5 percent of the observed speed from 1.12 mph to 122 mph. The current acceptable range for wind speed accuracy response using a direct reading sensor is within 0.56 mph at speeds below 12.2 mph and within ±5 percent at speeds above 12.2 mph; and ±5 mph using collocated wind speed measurement equipment.)

Temperature Accuracy (absolute difference): 1.8 degrees Fahrenheit (F). (The guidance specifies a

temperature accuracy of ±5 degrees Celsius [C]). The current TCEQ’s accepted range for both direct reading sensors and collocated sensors is ±1.0 degrees C or 1.8 degrees F.

Relative Humidity Accuracy (absolute difference): <+/- 1% from 0 to 100%. (The guidance specifies a relative

humidity accuracy of +/- 5%. The current TCEQ accepted range for both direct reading sensors and collocated sensors is +/- 5%.

D3.3.4 Automated GC VOC

Accuracy is determined by challenging the continuous GC with gas standards containing selected compounds of interest at concentrations representative of the ambient atmospheres typically being monitored. The gas standard component concentrations are within 5 to 10 times the estimated detection limits.

The percent difference between the theoretical concentration (Xi) and the analyzer response (Yi) for each challenge atmosphere is calculated:

% Difference = 100 X (Xi - Yi)

(Xi) and compared to the project objectives. Refer to Section C1.3.1.2.3 for further details.



D3.3.5 Methane and Total Non-Methane Hydrocarbons

Accuracy will be determined by challenging the FID monitor with gas standards containing the compounds of interest at concentrations representative of the ambient atmospheres typically being monitored during the study. The gas standard component concentrations are expected to be within five to 10 times the estimated detection limits.

Accuracy for each pollutant will be determined using the procedures outlined in 40 CFR 58, Appendix A. The percent difference between the known input concentration (Xi) and the analyzer response (Yi) is calculated for each audit level. At the end of the reporting period, the mean (D) and standard deviation(s) of the individual percent differences are computed. Then, the UL and LL 95 percent PL are computed and compared to the project objectives.

D3.3.6 Canister Volatile Organic Compounds

Accuracy is determined by challenging the canister samplers with gas standards containing the compounds of interest at concentrations representative of the ambient atmospheres typically being monitored. The gas standard component concentrations are 5 to 10 times the estimated detection limits.

The percent difference between the theoretical concentration (Xi) and the analyzer response (Yi) for each challenge atmosphere is calculated:

% Difference = 100 X (Xi - Yi)

(Xi)

and compared to the project objectives. Refer to Section C1.3.1.2.3 for further details.


Accuracy may be qualitatively assessed by comparison with ambient meteorological conditions.

D3.4 Completeness For SO2, H2S, meteorological parameters, VOCs by automated GC, Methane and Total Non-

methane Hydrocarbons by FID, canister volatile organic compound, and carbonyl data completeness calculations, see Sections A7.5.5 and C1.3.1.3.

Documents

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