___________________________________________________________ (2025)

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___________________________________________________________

Southern Ute Indian Tribe

Air Quality Division

Quality Assurance Project Plan

Fiscal Year 2025

___________________________________________________________

Prepared for:

United States Environmental Protection Agency

Region VIII

1595 Wynkoop Street

Denver, Colorado 80202

Prepared by:

Southern Ute Indian Tribe

Environmental Programs Department

Air Quality Division

P.O. Box 737, MS# 84

Ignacio, Colorado 81137

(970) 563-0135

Operating Period October 1, 2024 to September 30, 2025

SOUTHERN UTE INDIAN TRIBE

AMBIENT AIR MONITORING PROGRAM

QUALITY ASSURANCE PROJECT PLAN APPROVAL FORM

October 1, 2024 to September 30, 2025

Document approved by:

Digitally signed by Danny

Danny Powers Powers

Date: 2025.04.28 15:18:41

-06'00'

_____________________________

Daniel Powers

Air Quality Division Head

Southern Ute Indian Tribe

_______________

Date

Digitally signed by Mitchell

Mitchell Dorsk Dorsk

Date: 2025.04.29 08:53:10

-06'00'

_____________________________

Mitchell Dorsk

QA Manager

Southern Ute Indian Tribe

_______________

Date

Digitally signed by JASON

JASON

DEARDORFF

Date: 2025.04.28 13:37:13

DEARDORFF

-06'00'

_____________________________

Jason Deardorff

Tribal Program Manager

EPA Region VIII

_______________

Date

Digitally signed by KYLE

KYLE OLSON OLSON

Date: 2025.04.28 14:07:51

_____________________________

-06'00'

Kyle Olson

Delegated Approving Officer

EPA Region VIII

_______________

Date

Final Tribal approval authority for the FY2025 QAPP is delegated to the Tribal QA Manager,

Mitchell Dorsk, and the Air Quality Division Head, Danny Powers. Final EPA approval for the

FY2025 QAPP is delegated to Delegated Approving Officer, Kyle Olso, and Tribal Program

Manager, Jason Deardorff.

ACRONYMS AND ABBREVIATIONS

AIRS

AQP

AQS

CAA

CFR

COC

DQA

DQOs

EPA

ESC

FEM

FRM

LPM

MFC

MQOs

NAAQS

NIST

NO2

NOx

OAQPS

PM2.5

QA/QC

QAPP

SLAMS

SOP

SPM

SRM

SUIT

ZSP

Aerometric Information Retrieval System

Air Quality Program

Air Quality System

Clean Air Act

Code of Federal Regulations

Carbon Monoxide

Chain of Custody

Coefficient of Variation

Data Quality Assessment

Data Quality Objectives

Environmental Protection Agency

Environmental Systems Corporation

Federal Equivalent Methods

Federal Reference Method

Liters per Minute

Mass Flow Controller

Measurement Quality Objectives

National Ambient Air Quality Standards

National Institute of Standards and Technology

Nitrogen Dioxide

Nitrogen Oxides

Ozone

Office of Air Quality Planning and Standards

Percent Difference

Particulate Matter less than or equal to 2.5 microns

Sampler flow rate at ambient (actual) conditions of temperature and

pressure

Quality Assurance/Quality Control

Quality Assurance Project Plan

State and Local Air Monitoring Stations

Standard Operating Procedure

Special Purpose Monitor

Standard Reference Method

Southern Ute Indian Tribe

Temperature, at ambient or actual conditions

Air volume, at ambient or actual conditions

Zero/Span/ Precision

iii

GROUP A

Table of Contents

PROJECT MANAGEMENT ................................................................... 1

A3 Distribution List ................................................................................................... 1

A4 Project/Task Organization ................................................................................... 1

Figure 1. Administrative Organization of the SUIT Air Quality Monitoring

Program ...................................................................................................................... 2

A5 Problem Definition – Background ....................................................................... 2

A6 Project/Task Description ..................................................................................... 3

A7 Data Quality Objectives ....................................................................................... 5

A7.1 Automated Span and Precision Checks for Gas Species .............................. 5

A7.2 Reserved ....................................................................................................... 6

A7.3 Continuous Light Scatter/Visibility Data ..................................................... 6

A7.4 Meteorological Data ..................................................................................... 6

A7.5 Particulate Data ............................................................................................. 7

A8 Special Training Requirements............................................................................ 7

A9 Documentation and Records ................................................................................ 8

GROUP B

MEASUREMENT/DATA ACQUISITION............................................. 9

B1 Sampling Process (Network) Design ................................................................... 9

B2 Sampling Method Requirements........................................................................ 10

B2.1 Continuous Gas Monitors ........................................................................... 10

B2.2 Continuous Visibility Monitor .................................................................... 11

B2.3 Meteorological Instruments ........................................................................ 12

B2.4 T60 & T640x PM Mass Monitor ................................................................ 13

B2.5 Reserved ...................................................................................................... 14

B3 Sample Handling and Custody Requirements ................................................... 14

B3.1 Continuous Parameters ............................................................................... 14

B4 Analytical Method Requirements ...................................................................... 14

B4.1 Instrumentation quality control requirements ............................................. 14

B4.2 Nephelometer detection limits and operation ............................................. 15

B4.3 Meteorological monitoring sensors............................................................. 15

B4.Reserved .......................................................................................................... 15

B5.1 Continuous gas monitors............................................................................. 15

B5.2 Particulate Sampler ..................................................................................... 17

B5.3 Meteorological Instruments ........................................................................ 18

B5.4 Continuous Visibility Monitor .................................................................... 18

B5.5 System Audits ............................................................................................. 19

B6 Instrument Maintenance Requirements/Configuration Control......................... 19

B6.1 Preventative and Routine Maintenance ...................................................... 19

B6.2 Configuration Control for Logbooks .......................................................... 20

B6.3 Instrument Repair........................................................................................ 20

B7 Instrument Calibration and Frequency............................................................... 20

B7.1 Continuous Gas Monitors ........................................................................... 20

B7.2 Continuous Visibility Monitor .................................................................... 22

B7.3 Meteorological Instruments ........................................................................ 23

B7.4 T640 & T640x Particulate Continuous Samplers ....................................... 24

B7.5 Reserved ...................................................................................................... 24

B8 Inspection and Acceptance of Supplies and Consumables ................................ 24

B9 Data Acquisition Requirements ......................................................................... 25

B10 Data Management ............................................................................................ 26

B10.1 Data Entry/Formatting .............................................................................. 26

B10.2 Raw data.................................................................................................... 26

B10.3 Data transfer .............................................................................................. 26

B10.4 Data Validation ......................................................................................... 26

B10.5 Data transmittal ......................................................................................... 27

B10.6 Data reduction ........................................................................................... 28

B10.7 Data analysis ............................................................................................. 28

B10.8 Data flagging ............................................................................................. 28

B10.9 Data storage and retrieval ......................................................................... 28

GROUP C ASSESSMENT/OVERSIGHT.................................................................. 28

C1 Assessments and Response Actions................................................................... 28

C2 Reports to Management ..................................................................................... 29

GROUP D

DATA VALIDATION AND USABILITY ........................................... 30

D1 Data Review, Validation, and Verification Requirements ................................ 30

D1.1 Continuous Gas Monitors ........................................................................... 30

D1.2 Reserved ..................................................................................................... 30

D1.3 Continuous Visibility Monitor.................................................................... 30

D1.4 Meteorological Instruments ........................................................................ 30

D2 Validation and Verification Methods ................................................................ 30

D2.1 Data Collection/Quality Control Procedures .............................................. 30

D2.2 Data Reduction and Processing .................................................................. 32

D3 Reconciliation with Data Quality Objectives .................................................... 33

References ................................................................................................................ 34

LIST OF FIGURES

Figure 1. Administrative Organization of the SUIT Air Quality Monitoring Program 2

Figure 2. Sampling Site Locations ................................................................................. 3

LIST OF TABLES

Table 1. Ambient Air Quality and Meteorological Instrumentation ............................. 4

Table 2. Gas Species Measurement Quality Objectives ................................................ 6

Table 3. Aurora-1000 Environmental Sensors Precision and Accuracy Objectives ..... 6

Table 4. Meteorological Data Precision and Accuracy Objectives .............................. 7

Table 5. PM10 & PM2.5 Continuous Measurement Quality Objectives ...................... 7

Table 6. Air Quality Monitoring Staff Minimum Training Requirements ..................... 8

Table 7. List of Documentation and Records ................................................................ 9

Table 8. Zero and Span Checks for Continuous Visibility Monitor ............................ 18

Table 10. Requirements for Continuous Gas Monitor Standards ............................... 21

Table 11. Critical Supplies and Consumables............................................................. 25

APPENDIX A Forms

List of Appendices

AirVision Instrument Maintenance Log

Monthly AQS Data Changes and Code Justifications

APPENDIX B Summary of Probe and Monitoring Path Siting Criteria

APPENDIX C Gaseous Monitoring Standard Operating Procedures

o API T700E MFC Verification/Calibration SOP

o Calibration Gas Cylinder Regulator Purge SOP

o Gas Regulator Installation and Leak Check

o O3/NO/NO2/NOX ZSP SOP

o O3/NO/NO2/NOX/ Multi-Point Calibration SOP

o Photometer Verification/Calibration SOP

o Routine Operations SOP

APPENDIX D Meteorological Standard Operating Procedures

o Meteorological Routine Maintenance SOP

o Meteorological Parameter Verification/Calibration SOP

APPENDIX E Data Collection/AQS Submittal Standard Operating Procedure

o AirVision Station Manual Polling SOP

o AQS Audit Data Formatting SOP

AQS Data Submittal SOP

AQS Data Certification SOP

Continuous Data Weekly Trend Check SOP

Continuous Data Monthly QA-QC SOP

Format Continuous Data for Monthly AQS Submission SOP

APPENDIX F Nephelometer Standard Operating Procedures

o Ute 3 Nephelometer Maintenance

o Ute 3 Nephelometer Direct Polling for Minute Data Collection

o Ute 3 Nephelometer Environmental Sensors & Zero/Span Calibration

o Ute 3 Nephelometer Calibration

APPENDIX G Southern Ute AQP Ambient Monitoring Record Retention and Filing SOP

APPENDIX H Data Validation Chart/Templates

o Data Validation Flow Chart

o Data Validation Templates

APPENDIX I Air Resource Specialists, Inc. Standard Operating Procedures – Gaseous,

PM2.5 and Meteorological Audit Methods

APPENDIX J Air Resource Specialists, Inc. Standard Operating Procedure – Ecotech

Aurora 1000 Nephelometer Audit Procedure

APPENDIX K Model T640x T640 PM Mass Monitor Training Manual

APPENDIX L Model T640x PM Mass Monitor SOP

APPENDIX M Model T640x PM Mass Monitor Operation Manual

vii

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Revision for FY2025

GROUP A

PROJECT MANAGEMENT

A3 Distribution List

Key individuals and their organizations are listed on page ii, the signature page. These individuals will

receive copies of the approved FY25 Southern Ute Indian Tribe (SUIT) Air Quality Division (AQD)

Quality Assurance Project Plan (QAPP) and any subsequent revisions. Below is a general list of the

organizations receiving a copy of this QAPP.

Southern Ute Indian Tribe:

Environmental Programs Department Director

Air Quality Division Head

Air Quality Program Manager

Air Quality Specialist

EPA Region VIII:

Tribal Program Manager

Air Program Officer

A4 Project/Task Organization

Overall project responsibility for the SUIT AQD rests with the Southern Ute Indian Tribe as represented

by the Tribal Council and its designated representatives.

Program management and administration is the responsibility of the Air Quality Division Head. The

Division Head reports directly to the Environmental Programs Department Director. The Departmenet

Director’s responsibility is to review work performed and to provide Division direction. The

Environmental Programs Director reports to the Tribal Executive Officer, who then reports to the Tribal

Chairman and Tribal Council.

The Air Quality Program Manager duties include all network reviews/modifications, AQS ambient data

submittals/certifications, QAPP revisions, maintenance, and distribution. Additionally, the Air Quality

Program Manager shall ensure that the QAPP is implemented as approved; and that all personnel

involved in the work have direct access to a current version of the QAPP (electronically on the tribal

network server) and all other necessary planning, implementation, and assessment documents. All

personnel involved in ambient air monitoring will be appropriately trained in the requirements prior to

the start of data generation activities. The Air Quality Program Manager also reviews all the duties

conducted by the Air Quality Specialist. The Program Manager reports to the Air Quality Division

Head. Routine operation of the monitoring sites, including data collection and data reduction, is the

responsibility of the Air Quality Specailist who reports directly to the Program Manager.

The Quality Assurance Manager or their delegate, reviews the data and does not participate in the data

gathering process. Consultants are retained by the AQD to conduct performance audits, data quality

assurance reviews and provide general assistance and training as necessary for AQD personnel. Figure

1 illustrates the administrative organization of the Southern Ute Ambient Air Quality Program.

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Revision for FY2025

Tribal Council

Tribal Executive Officer

Lindsy Box

Environmental Programs

Department Director

Mark Hutson

Air Quality Division Head

Danny Powers

Air Quality Program

Manager

Andrew Switzer

Contractors

Ambilabs LLC.

Quality Assurance

Manager

Mitchell Dorsk

Air Quality Specialist

Reyes Shendo

Figure 1. Administrative Organization of the SUIT Air Quality Monitoring Program

A5 Problem Definition – Background

The prime considerations of the AQD are (1) the determination of the general background pollutant

concentration levels on the Southern Ute Indian Reservation (Reservation) and (2) issuance in realtime

of pollutant concentrations and EPA Air Quality Index (AQI) health alerts. Because of current and

projected energy development in the region, the program is concerned with monitoring areas of the

Reservation that could potentially be impacted by significant sources of air pollution. Additionally, the

Reservation is frequently impacted by high concentration of particulate matter resulting from local and

regional forest fires and dust storms, and informing Tribal members and the public of the health impacts

of these events in realtime using EPA AQI alerts, is a primary goal of the monitoring program.

It is the AQD’s goal to:

 Protect the health and welfare of all residents within the exterior boundaries of the

Southern Ute Indian Reservation

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Revision for FY2025

 Determine if criteria pollutants of interest are in compliance with the National Ambient

Air Quality Standards

 Maintain a reliable continuous ambient air monitoring network, and/or special studies

that meet the requirements of the Code of Federal Regulations, particularly, but not

limited, to appendix A in 40 CFR Part 58

If it is determined that criteria pollutants recorded by regulatory monitors within the SUIT monitoring

network indicate potential non-compliance with a National Ambient Air Quality Standard (NAAQS),

the AQD will work with the EPA and State of Colorado to determine if exceptional events contributed

to or caused exceedances and will pursue the appropriate pathway for either (1) development of an

exceptional event justification in accordance with the EPA Exceptional Events rule or (2) if the

Reservation were designated as non-attainment by the EPA, development and EPA approval of a

Tribal Implementation Plan by the applicable deadlines to bring the air shed back in to compliance.

A6 Project/Task Description

This QAPP has been updated for fiscal year 2025. The program currently operates three monitoring

stations: Ute 1, Ute 3, and MMS (Figure 2).

Figure 2. Sampling Site Locations

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Revision for FY2025

The Ute 1 monitoring station is located approximately one mile north of Ignacio, Colorado. The station

is situated in the Pine River Valley, the most densely populated area of the Reservation. The Ute 1

station meets all siting criteria for an urban SLAMS. This station is in a secured area within the Southern

Ute Indian Tribe Forestry complex and is thought to be representative of the air quality around the

Ignacio community.

The Ute 3 station is located approximately twenty miles west of Ignacio, near Bondad, Colorado. The

station is situated along the eastern rim of the Animas River Valley near Highway 550, a major roadway

that connects southwestern Colorado with northwestern New Mexico. The area surrounding this

monitoring site is comprised of dispersed homes, agricultural activities, and oil and gas production sites,

so the site is influenced by both stationary and mobile sources of air pollution. The station meets all

siting criteria for an urban SLAMS. The Ute 3 monitoring station is located on Tribal land within a

locked perimeter fence, and the area is regularly patrolled by Tribal Rangers.

The Mobile Monitoring Station (MMS) is located on the eastern portion of the Reservation near Lake

Capote. This location is further removed from the oil and gas development than the Ute 1 and Ute 3

stations on the western portion of the Reservation and is well suited to assess ambient background

concentrations prior to proposed development of shale gas resources on the eastern portion of the

Reservation. The current location of the MMS meets all siting criteria for an urban SLAMS; however,

it is operated as a Special Purpose Monitor (SPM). The MMS site is located within a locked perimeter

fence and the area is regularly patrolled by Tribal Rangers, as well as and visited weekly by ambient air

quality monitoring program staff.

In addition to the three air monitoring stations, the AQD has added two low-cost PurpleAir particulate

matter sensors to the monitoring network. The sensors will be located at two different locations in the

town of Ignacio, Colorado and used to help inform the public of health risks associated with fire

smoke and seasonal dust storms. Data from the sensors will be polled in real-time to the PurpleAir

map layer and linked to the AQD’s ambient monitoring website to provide EPA Air Quality Index air

quality health risk information to the public. The data will not be QA/QC reviewed, retained by AQP,

or submitted to AQD. Because the PurpleAir sensors are not FRM, the AQD does not guarantee the

validity of the data and only recommends the use of the data to help the public decide about actions

they can take to protect themselves from particulate matter health-risks during regional fire smoke and

dust storm events. PurpleAir sensor locations and associated information have not been added to Table

1 to allow the AQD flexibility in where instruments are located and how data is used.

The specific monitors in operation at each site within the AQP monitoring network will be determined

by criteria listed in 40 CFR Part 58. Monitors in current possession of the program, their sampling

schedules and their locations of operation are listed in Table 1.

Parameter

NO, NO2, NOX

Table 1. Ambient Air Quality and Meteorological Instrumentation

Initial Start Date

Number of

Sampling

Location

Ute 1 / Ute 3 /

Instruments

Schedule

MMS

Ute 1

10/18/2005

Continuous

01/01/2001

Ute 3

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Revision for FY2025

MMS

Ute 1

Ute 3

MMS

Ute 1

Ute 3

MMS

Ute 1

Ute 3

MMS

Ute 1

Ute 3

MMS

Ute 1

Ute 3

MMS

Ute 1

06/01/2017

06/01/1982

04/01/1997

06/01/2017

01/01/2001

06/01/2017

01/01/2001

06/01/2017

01/01/2000

06/01/2017

01/01/2000

06/01/2017

01/01/2000

Ute 3

09/13/2007

01/01/2000

02/26/2008

07/01/2010

Continuous

Wind Direction

Continuous

Wind Speed

Continuous

Temperature

Continuous

Relative Humidity

Continuous

Solar Radiation

Continuous

Precipitation

Continuous

Visibility

(nephelometer)

Ute 1

Ute 3

Continuous

Ute 3

PM2.5

Continuous

PM10

Continuous

Ute 3

Ute 1

Ute 3

Ute 1

03/01/2013

10/01/2021

03/01/2013

10/01/2021

A7 Data Quality Objectives

The primary objective of the ambient air quality monitoring network is to measure criteria pollutants of

interest within the Reservation’s airshed. The AQD may utilize AQS certified data from the region to

explore air quality issues connected to industrial activities through spatial and temporal analysis of

measured parameters.

All data generated from the AQD monitoring network will be subject to the quality assurance practices

summarized in Table 2.

A7.1 Automated Span and Precision Checks for Gas Species

The precision and accuracy objectives during automated checks for instruments that measure gas phase

species, using EPA designated methods, are summarized in Table 2. As an example, the measurement

precision goal for automated ozone check events is defined by a coefficient of variation (CV) of less

than or equal to 7% at the upper 90% confidence limit (CL). The measurement bias goal for automated

ozone checks is defined as ≤7% of the CV at the upper 95% CL (see Appendix A, section 2.3.1.2 to 40

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Revision for FY2025

CFR Part 58). Precision warning levels have been established for each gas species to alert to potential

issues prior to exceeding the requirements in Appendix A, section 2.3.1.2 to 40 CFR Part 58.

Table 2. Gas Species Measurement Quality Objectives

Parameter

Reference Method

Conditions

NO2

NOx

Teledyne T200

Chemliluminescence

Synthetic

Atmosphere

Teledyne T400 UV

Absorption

NO2

NOx

Thermo

Model 42i

RFNA-1289-074

Thermo

Model 49i

EQOA-0880-047

Precision

Level

50ppb

Span

level

180ppb

100ppb

180ppb

Precision

Bias

Synthetic

Atmosphere

50ppb

Synthetic

Atmosphere

Synthetic

Atmosphere

Precision

Warning

90% CL

CV≤10%

95% CL ≤

±10%

PD ≤7%

180ppb

90% CL

CV≤7%

95% CL ≤

±7%

PD≤5%

50ppb

180ppb

100ppb

180ppb

90% CL

CV≤10%

95% CL ≤

±10%

PD ≤7%

50ppb

180ppb

90% CL

CV≤7%

95% CL ≤

±7%

PD≤5%

A7.2 Reserved

A7.3 Continuous Light Scatter/Visibility Data

The AQD employs an Ecotech Aurora Single Wavelength Integrating Nephelometer to measure light

scatter and to estimate visibility. Uncertainty in the measurement of the nephelometer light scatter and

influential environmental parameters are summarized below in Table 3. Nephelometer and

meteorological measurements are an important indicator of air quality during the increasing prevalence

of smoke from fires across the western United States and regional emission reductions required by the

State of New Mexico and State of Colorado State Implementation Plans for meeting Regional Haze Rule

objectives.

Table 3. Aurora-1000 Environmental Sensors Precision and Accuracy Objectives

Parameter

Measurement Resolution

System Accuracy

Barometric Pressure

0.1 mmHg

±10 mmHg of observed

Temperature

0.1° C

± 2° C

Relative Humidity

0.1%

± 10% of observed

-1

Measurement

< 0.25 – 2000 Mm

< 0.3Mm-1

A7.4 Meteorological Data

The measurement precision and accuracy objectives for meteorological parameters are summarized in

Table 4. Meteorological data may be used to assist the AQP in better understanding atmospheric

transport of pollution within the Reservation’s airshed, by constraining models like NOAA Hybrid

Single-Particle Lagrangian Integrated Trajectory model (HYSPLIT).

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Revision for FY2025

Table 4. Meteorological Data Precision and Accuracy Objectives

Parameter

Measurement Resolution

System Accuracy

Wind Speed

0.1 mph

± 5% of observed

Wind Direction

1.0°

± 5.0°

Temperature

0.1° C

± 0.5° C

Precipitation

0.01inches

± 10% of observed

Solar Radiation

0.01 L/M

± 5% of observed

Relative Humidity

0.1%

± 10% of observed

A7.5 Particulate Data

The continuous non-regulatory measurements of PM2.5 and PM10 at Ute 1 and Ute 3 is conducted for

the purpose of helping inform individual decision making that will lead to reduced PM exposure in the

region from wildfire smoke and dust storms. The continuous measurements for PM10 and PM2.5 may

be used to help inform the relationships between PM concentrations, visibility, and atmospheric

transport within the Reservation’s airshed. The precision and bias objectives for continuous

measurements of fine particulate (PM2.5) are summarized in Table 5.

Parameter

PM10

PM10-2.5 LC

PM2.5

PM10

PM2.5

Table 5. PM10 & PM2.5 Continuous Measurement Quality Objectives

Reference Method

Precision

Bias

Teledyne API T640x

(16.71 L/min)

EQPM-0516-239

Teledyne API T640x

(16.71 L/min)

EQPM-0516-240

Teledyne APIT640x

(16.71L/min)

EQPM-0516-238

Teledyne APIT640

(5.0 L/min)

≤15% CV

±15%

≤15% CV

±15%

≤10% CV

±10%

≤15% CV

±15%

Teledyne APIT640

(5.0 L/min)

EQPM-0516-236

≤10% CV

±10%

Precision

Warning

PD ≤10%

A8 Special Training Requirements

AQD personnel will attend courses and workgroups offered by EPA’s Air Knowledge, Western

Regional Air Partnership, Western States Air Resources Council and the, Northern Arizona University

(NAU) Intitue for Tribal Environmental Proffesionals , equipment manufacturers, and other

environmental training providers that offer the necessary training to effectively implement the Southern

Ute Air Quality Monitoring Program. Personnel who attend training will store a copy of their training

report and certification in a training file on the internal server. Training reports will include training

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Revision for FY2025

dates, topics covered, and certificate of completion. The Air Quality Division Head will document all

trainings in annual EPA grants report. Copies of training certifications will be maintained in personnel

files. The annual report will be submitted to the EPA Region VIII.

New employees will be given an AQD orientation and evaluated after a 90-day probationary period.

Employees will be evaluated annually thereafter to identify deficiencies that can be addressed through

additional training. The Air Quality Division Head will be responsible for the personnel performance

evaluation of the Air Quality Program Manager and identification of areas in which training is necessary

to support performance of appointed tasks. The Air Quality Program Manger will performing the

personnel evaluation for the Air Quality Specialist.

The orientation and training of new employees will be conducted by AQD managers and staff and the

training institutions mentioned above. Employees will at minimum be required to have sufficient

knowledge in areas detailed in Table 6 for each position, or attend trainings listed. These trainings will

be completed in the first 12 months of employment or as as scheduling allows. The Air Quality Division

Head and Program Manager will be responsible for determining if an employee has sufficient knowledge

or requires further training.

Table 6. Air Quality Monitoring Staff Minimum Training Requirements

Position

Minimum Trainings (or sufficient knowledge)

AQD Division Head

Management of Tribal Air Programs and Grants

Clean Air Act and Permitting

Air Pollution Compliance & Enforcement

Quality Assurance Project Plans (QAPP)

Basic Budgets

Air Quality Program

Air Quality Computations

Manager

Air Pollution Technology

Air Quality System (AQS)

Quality Assurance Project Plans (QAPP)

ARC View/ GIS

Quality Assurance/Control for Air Monitoring

Basic Budgets

Air Quality Specialist

Air Quality Computations

Air Pollution Technology

Air Quality System (AQS)

Meteorological Monitoring

Gaseous Pollutant/PM2.5 Monitoring

A9 Documentation and Records

Documentation and records maintained by the AQD are listed below in Table 7. Records will be

documented either electronically, in bound notebooks, and/or in forms designated for specific

applications. Air quality and meteorological data will be transmitted from Agilaire Dataloggers at each

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Revision for FY2025

station to a central AirVision sever, where it will be backed-up and archived. All records will be stored

on the Tribe’s internal drive or at the Environmental Programs Department office and retained according

to the AQD’s Record Retention and Filing Protocol (Appendix G). All relevant air monitoring

information will be documented and retained electronically on the tribal network server where it will be

accessible to AQD staff for future use and reference. Examples of relevant information include, but are

not limited to, instrument manuals, field data sheets, log books, calibration/verification records, NIST

certifications, audit reports, as well as hourly and minute data.

Table 7. List of Documentation and Records

Record

Employee Responsibility

Approved QAPP

Program Manager

Raw Data

Specialist

QA/QC Data

Specialist

Site Logs

Specialist

Calibrations

Specialist

QC Checks

Specialist

Maintenance/Repair

Specialist/Program

Manager

Traceability

Specialist

Audits

Specialist/Program

Manager

Annual Reports

Program Manager

Network Review/

Modifications

Data Submittals

Data Certification

GROUP B

Specialist/Program

Manager

Program Manager

Quality Assurance

Manager/Division Head

Brief Description

Signed Project Plan

Raw Data

Data Precision and Accuracy records

All site activities

Calibration values and tolerances

Zero/Span/Precision values

Maintenance/Repair records

Chain of custody forms

Schedule audits and review audit reports

Percent data capture and air monitoring

program highlights for the year

Network description and proposed

monitoring changes (if any)

Submit QA/QC data to AQS

Annual AQS Ambient Data Certification

MEASUREMENT/DATA ACQUISITION

B1 Sampling Process (Network) Design

Probe siting information for all monitoring stations is included in Appendix B of this QAPP. The site

configurations of all stations are in accordance with Appendix E to 40 CFR Part 58. The AQD submitted

the current Annual Network Review to EPA in August 2023 after the required 30 days public comment

period from June 30 to July 30, 2023.

The pollutants and meteorological parameters measured within the AQD network assist the program in

developing accurate atmospheric representation of the air quality within the Reservation airshed. This

representation allows for detailed interpretations of the potential impacts of stationary, area, and mobile

sources operating in and around the Reservation area. The oil and natural gas exploration and production

activities and the Ignacio community within the Reservation were key considerations in establishing air

monitoring locations. Stations were sited to represent regional background air quality conditions as well

as the air quality community members experience in Ignacio. Additionally, the location of each

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Revision for FY2025

monitoring station was selected based on the AQD’s best understanding of regional transport patterns

for pollution throughout the Four Corners area and the resulting potential for exposure to air pollution

on the Reservation.

The Ute 1 station is located directly northeast of the town of Ignacio, CO. This location is the best

available site for an air quality monitoring station to inform exposure to air pollution in the town of

Ignacio, while meeting the siting requirements in 40 CFR Part 58. The Ute 3 station is situated on the

eastern ridge of the Animas River valley near Bondad, CO. This river valley is believed to be a main

corridor for the transport for pollutants from the Farmington, New Mexico area into the Reservation.

The MMS station is currently located at Lake Capote on the eastern portion of the Reservation in an area

that is not as heavily influenced by nearby natural gas production activities as the stations on the western

portion of the Resevation The specific site location is a quarter mile south of Highway 160, two miles

east of Chimney Rock National Monument. The station is secured by a locked perimeter fence and

within the main Lake Capote access gate.

Continuous measurements of all gaseous and meteorological parameters are reported to AQS in hourly

averages.

The AQD will measure visibility as a proxy of light scatter, employing a nephelometer at the Ute 3 site.

Visibility data is collected on a continuous basis and reported in hourly averages to AQS. This data will

be used to inform trends in visibility on the Reservation.

The AQD will employ continuous particulate mass monitors at the Ute 1 and Ute 3 sites. Data will be

collected from these instruments on a continuous basis and hourly averages will be reported to AQS.

All continuous PM data will be considered informational and will assist the AQD by informing visibility

trends, in documentation of exceptional events, and to provide real-time PM data to the public, enabling

informed action during dust storms or forest fires.

B2 Sampling Method Requirements

The AQD will maintain all three monitoring stations in accordance with 40 CFR Part 58 and all other

associated guidance pertaining to instrument manufacture specifications/operations. Measured gaseous,

particulate, meteorological, and visibility parameters will meet and/or exceed the 75% data completeness

requirement. Data excluded from the annual data completeness will be a direct result of properly

conducted QA/QC operations pertaining to routine field operations, power failures and other instrument

errors, and variations in meteorological conditions that introduce irregular atmospheric conditions.

Examples of irregular atmospheric conditions that can occur, include but are not limited to, stratopheric

ozone intrusions, flooding events, high wind and dust events, and wildfire smoke. Additionally, there

could be possible influences on the sampling system from nearby sources. Data subject to these

conditions will be properly null coded and/or supplied with the correct qualifier code that adequately

describes the conditions upon collection prior to AQS submittal.

B2.1 Continuous Gas Monitors

The sampling probe used for ambient air sample collection meets the requirements of Appendix E,

section 9 to 40 CFR Part 58. Standard Operating Procedures for each instrument/monitor/sensor can be

found in Appendix C of this QAPP. The instruments and calibration equipment that will be used to

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measure gas phase species by the network are summarized below.

Ozone will be measured using UV light absorption, EPA designated method EQOA-0992-087. The

analyzer model used will be the Teledyne Model T400 03 analyzer, with Thermo Scientific 49i

instruments being available as a backup under EPA designated method EQOA-0880-047, if the Teledyne

instruments are needed to be taken out of service.

Nitrogen oxides will be measured using chemiluminescence, EPA reference method RFNA-1194-099.

The analyzer model used will be the Teledyne Model T200 NOx analyzer, with the Thermo Scientific

42i instruments being available as a backup under EPA designated method RFNA-1289-074, if the

Teledyne instruments are needed to be taken out of service.

Teledyne API T700 dynamic dilution calibrators with internal ozone generation capacity and ozone

photometers will be used to perform zero/span/precision (ZSP) checks and calibrations of the ozone

analyzers (EPA designated method EQOA-0992-87).

Teledyne API T700 dynamic dilution calibrators will be used to perform ZSP checks and calibrations

of the nitrogen oxides monitors using NIST-certified gas cylinders containing known concentrations of

nitric oxide.Known concentrations of gas from the multi-blend gas cylinders will be diluted with zero

air with mass flow controllers (MFCs) in the T700 calibrators. Zero air will be sourced by Teledyne

API T701H Zero Air Generators. During normal operation, automated ZSP check events will be

performed on a weekly basis or more frequently. Calibration and certification of MFCs will be

performed every six months using NIST-traceable Bios 220H and 220L Standardized Mass Flow meters.

Method, frequency, and equipment that will be used to certify the Bios 220H and 220L flow meters are

detailed in Table 9 of this QAPP.

Calibration gas purchased through a third-party supplier will possess documentation supplied by the

manufacturer containing a description of contents and traceability to a NIST-SRM in accordance with

EPA’s QA Handbook Volume II (19). Calibration gas cylinders will be verified and inspected by the

manufacturer on a bi-annual basis and/or before the cylinder pressure drops below 300PSI. All shipping

performed by the AQD will be conducted in accordance with Department of Transportation regulations

included in Title 49 CFR.

The digital voltage meter (DVM) used is a Fluke Multimeter, Model 117. The DVM shall be annually

certified and verified against a NIST-traceable standard at the manufacturer.

B2.2 Continuous Visibility Monitor

Ute 3 will utilize the Ecotech Aurora-1000 single wavelength integrating nephelometer to measure

visibility as a function of the scattering coefficient (resulting from the absorption and scattering of light

due to particles and/or molecules in the atmosphere). A 520nm wavelength is used for nephelometer

measurements. The nephelometer uses internal filters for generating particle free air while performing

zero checks. Automated zero/span calibration checks will be conducted every 24 hours for the duration

of 15 minutes, using a NIST-traceable gas cylinder containing pure CO2 as a span gas. These calibrations

values will not be applied to the nephelometer calibration curve unless a user set stability level (95%) is

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achieved for a duration of five minutes within the user set time limit (15min) for each calibration set

point (zero, span).

The Ecotech Aurora nephelometer measures barometric pressure, sample temperature and relative

humidity continuously. Calibration of the nephelometer’s environmental sensors will be performed at

least every three months using the following verification equipment:

1. Barometric pressure verifier: DPI 705S Barometer, Manufacturer: Druck, Model 705

Series.

2. Temperature verifier: Fluke Traceable Digital Thermometer Model 51 Series II.

3. Relative humidity verifier: Mannix Digital Sling Psychrometer, Model SAM 990D.

Certification and calibration of the verification equipment will be performed annually against NISTtraceable standards.

B2.3 Meteorological Instruments

Temperature, wind speed, wind direction, solar radiation, precipitation and relative humidity will be

measured continuously.

Temperature:

Fan aspirated radiation shield, Model 8152;

Thermistor temperature sensor, Model 4481, Manufacturer: RM Young.

Thermistor temperature sensor, Response One Model 92500, Manufacturer: RM Young.

Wind Speed and Direction:

Wind Monitor-AQ, Model 05305, Manufacturer: R.M. Young.

Ultrasonic, Response One Model 92500, Manufacturer: RM Young.

Solar Radiation:

Silicon cell pyranometer, Model LI-200RSMV-15, Manufacturer: Li-Cor.

Precipitation:

Tipping Bucket Rain Gauge, Model 52202, Manufacturer: R.M. Young.

Relative Humidity:

Capacitive relative humidity sensor, Model HUMICAP 180, Manufacturer: Vaisala.

Meteorological verification equipment:

Temperature verifier

Fluke Traceable Digital Thermometer, Model 51 Series II

Wind speed verifier

Anemometer Drive, Model 18801

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Torque Disc, Model 18310

Wind direction verifier

Vane Angle Fixture, Model 18212

Vane Torque Gauge, Model 18331

Vane Angle Bench Stand, Model 18112

Vane Alignment Rod, Model 18301

Solar radiation verifier

Solar radiation pyranometer verifier, Li-Cor Biosciences, Model LI-200SA

Precipitation verifier

Calibration bottle, Nova Lynx, Model 260-2595

Relative Humidity verifier

Mannix Digital Sling Psychrometer, Model SAM 990D

Calibration and/or verification of the site’s meteorological equipment will be performed at least every

three months using the meteorological verification equipment listed above. Certification and calibration

of the meteorological verification equipment will be performed annually against NIST-traceable

standards. The Meteorological standard operating procedures are available in Appendix D.

B2.4 T60 & T640x PM Mass Monitor

The Teledyne API T640 & T640x PM Mass Monitors are specifically designed to comply with the FEM

requirements of the NAAQS for Automated Particulate Matter (40 CFR Part 50) and to facilitate

sampling as specified in that document. The AQP has selected the T640 & T640x instruments to

measure PM on a continuous basis in compliance with the EPA Class III PM2.5 and PM10 FEM

certifications. The T640 & T640x instruments monitor the operational parameters continually during

the sampling cycle. The logged information is available to the field operator during and at the end of

each sample cycle in electronic data format and stored on the master CPU. The TCP/IP Modbus (digital

data output) port provides the capability for T640x instrument communication with the in-station

Agilaire 8832 data logger.

The sample inlet of the T640x will operate at a total nominal flow rate (sample flow plus bypass flow)

of 1.00m3/hr (16.67L/min). The sampler will meet the following requirements listed in the operation’s

manual for EPA Class III FEM compliance for PM10 and PM2.5 sampling. The T640 will operate with a

single flow rate at 5.0 L/min.

•

Sample line heaters on, and set to activate at 40% RH and deactivate at 30% RH

The T640 & T640x flow rate, thermocouples, RH sensors, and pressure sensors will be verified and/or

calibrated every four weeks using these transfer standards:

a. Fluke Traceable Digital Thermometer Model 51 Series II. Manufacturer: Fluke

Incorporated

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DPI 705S Barometer, Manufacturer: Druck, Model 705 Series

Delta Cal D1 flow meter, Manufacturer: MesaLabs

FP-25 Portable Flow Calibrator, Manufacturer: Alicat

Leak check filter assembly designed for the T640 & T640x inlet from Teledyne API

Additional guidance regarding the formal sampler specifications is available in Appendix K of 40 CFR

Part 50. Additional guidance regarding operational aspects and quality assurance is available in US

EPA QA Guidance Document Section 2.12 and the Operator’s Manual for the T640 & T640x.

B2.5 Reserved

B3 Sample Handling and Custody Requirements

B3.1 Continuous Parameters

All parameters are measured on a continuous basis. These include all gas species, PM10 and PM2.5,

visibility, and metrological measurements. Hourly average data that are representative of ambient

conditions will be reported to the EPA AQS database and will be subject to QC operations associated

with section five of the Ambient Air Quality Assurance Handbook for Pollution Measurement Systems

Volume II, detailed operations pertaining to the instrument operations manual, and the AQP SOP’s.

Minute averages of all continuous parameters are stored on the Agilaire 8832 datalogger locally for three

months and on the central Air Vision server for two years. Hourly averages of gaseous, meteorological,

particulate, and visibility are stored locally and on the central Air Vision server indefinitely. The AQP

has initiated an automated routine in the Air Vision software to poll data from each site to the central

server every few minutes to ensure maximum data capture during unexpected events that can contribute

to significant data loss. Significant data loss can arise from shelter temperatures exceeding requirements,

power failures, and electronic instrument communication failure. Measurements from continuous

parameters are also shared on the AQD monitoring webpage each time the central server polls data from

the three stations, in close to real time.

B4 Analytical Method Requirements

B4.1 Instrumentation quality control requirements

Gas analyzers and the T640 & T640x PM Mass Monitor must be operated in climate-controlled

environments. The monitoring shelter temperatures must always remain between 20° - 30°C. Air

conditioners and heaters will be used to maintain this tight temperature range inside the monitoring

shelters. The monitoring shelters will be maintained in such a way as to minimize dust contamination

and external vibrations from the instruments. Each monitoring shelter will be visited at a minimum of

one time per week. During each site visit the operator will inspect the shelter temperature; check that

the gas analyzers are operational and producing concentrations typical for the region. The operator will

verify that data from each instrument and sensor are being recorded accurately by the data acquisition

system. The operator will check the sample lines for any contamination, such as water or dust, and will

ensure that the inlet to the sample line is positioned correctly to accomplish ambient monitoring. Gas

analyzers and meterological instruments will be monitoried daily remotely as well as data anlyzed for

reasonableness.

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B4.2 Nephelometer detection limits and operation

The nephelometer is operated inside the Ute 3 air quality monitoring station. During each site visit, the

operator will verify that the light scattering coefficient on the nephelometer display is being recorded

accurately by the data acquisition system. The operator will examine the nephelometer for any

contamination and perform maintenance checks in accordance with the Nephelometer Maintenance SOP

(Appendix F).

B4.3 Meteorological monitoring sensors

All meteorological monitoring equipment (with the exception of precipitation) will be mounted to a 10meter tilt-over tower. Quarterly verification will be performed along with maintenance of meteorological

equipment (including changing bearings and other parts as needed) every three months. The

precipitation gauge will be cleaned monthly. All dust and debris will be removed from the funnel,

screen, and bucket assembly.

B4.Reserved

B5.1 Continuous gas monitors

The dilution systems, reference photometers, zero air generators, and gas cylinders that will be used for

gas analyzer calibration are detailed in section B2.1. Zero air delivered to gas analyzers will additionally

pass through a filter in order to remove any PM which could potentially contaminate reflecting surfaces

or react with measured gas species. Known concentrations of each measured gas species will pass

through as much of the sampling line as is practical toward equivalent treatment of calibration mixtures

and ambient air sampled. Furthermore, all QC requirements pertaining to continuous gas monitor

accuracy and precision measurements will comply with section 3.2.2 part 58 of the 40 CFR. Zero/span

and precision check descriptions herein are listed separately and are referred to as either zero/span,

precision, or level 1 weekly checks.

B5.1.1 Zero and span checks

Continuous gas monitors will be subject to level 1 zero/span checks weekly. The upper range limit

(URL) for the T200, T400, 49i, and 42i instruments is set to 200 ppb. URLs are specified by the

instrument manufacturer (Thermo Scientific and Teledyne API) and are able to be adjusted. Level 1

span checks will be performed using an artificial test atmosphere at concentrations between eighty and

ninety percent of the instrument URL, approximately 160–180 ppb for the T200, T400, 49i, and 42i

instruments.The exact concentration for each level 1 span check conducted at all three monitoring

stations on a weekly basis are as follows: 180 ppb for the instruments. The frequency of zero/span

checks will be based on instrument drift rates associated with interference occurring from the

accumulation of particulates on inline filters and various chemical interference originating from the

continuous operation of the sampling assembly at each station. Automated zero/span checks will be

performed using calibration gas of a known concentration. For nitrogen dioxide measurement

verification and converter efficiency assessment, gas phase titration using 200 ppb nitric oxide and set

points between 30 and 170 ppb ozone will be used to establish percent converter efficiency on a monthly

basis. Additionally, gas phase titration using 200 ppb nitric oxide and 50 ppb ozone will be used to and

assess NO2 GPT precision values and estimate converter efficiency on a weekly basis (Appendix C).

Ozone zero/span checks will be conducted using automated events at concentration levels of 0 ppb and

180 ppb. All zero/span values will be documented.

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B5.1.1.1 Zero and Span Check Procedure

1. Allow sufficient time for the calibration system and the analyzer (if applicable) to warm-up and

stabilize.

2. Deliver zero air to instrument and allow sufficient time for analyzer stabilization, by reviewing

the AV-Trend real time data trending time series. Record the observed zero reading (Z).

3. Deliver span gas test concentration and allow sufficient time for analyzer stabilization, by

reviewing the AV-Trend real time data trending time series. Record the observed span reading

(S1).

4. Calculate zero deviation (Dz):

Dz = (Z-b), b = intercept of recent multipoint calibration curve, ideally should be zero ppb.

(Definition of zero drift is an adaptation of the definition given in Section 12 of the Quality

Assurance Handbook for Air Pollution Measurement Systems, Volume II 1998.)

5. Calculate span drift (Ds):

Ds = ((S1-S)/S) x 100 where: Ds = span drift (%)

S1 = unadjusted span reading S = actual span gas concentration

(Definition of span drift is an adaptation of the definition given in Section 12 of the Quality

Assurance Handbook for Air Pollution Measurement Systems, Volume II 1998.)

6. Calculate quarterly average percent zero drift.

7. Zero and span drift values as calculated above are to be analyzed in AirVision. If the following

zero or span tolerances are exceeded for an analyzer, a calibration followed by a multi-point

calibration check will be performed.

O3/NOX/ Analyzers:

zero drift ±2% of full scale (4 ppb)

span drift ±7%

B5.1.2 Precision Checks

Continuous gas analyzers will be subject to a precision check at least once per week. The precision

checks inform instrument linearity. The frequency of precision checks will be based on possible drift

rates associated with interference occurring from the accumulation of particulates on inline filters and

various chemical interference originating from continuous measurements. Precision checks will be

accomplished through automated events and will use calibration gas of known concentration. For ozone,

and nitrogen oxide analyzers, precision checks will be performed at 50 ppb. All precision check values

will be documented. Precision checks, if performed in conjunction with zero/span adjustments, will be

performed prior to any such adjustments.

B5.1.2.1 Precision Check Procedure

1. Allow sufficient time for the calibration system and analyzer (if applicable) to warm-up and

stabilize.

2. Connect the calibration delivery system to the analyzer’s sample inlet line. Be sure delivery

system is properly vented and sufficient flow exists.

3. Deliver zero air and allow sufficient time for analyzer stabilization by reviewing the AV-Trend

real time data trending time series. Record the observed zero reading.

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4. Deliver a precision gas concentration (xi) to analyzer and allow sufficient time for analyzer

stabilization by reviewing the AV-Trend real time data trending time series. Record the

observed precision reading (yi).

5. Calculate percent precision (di): di = ((yi-xi)/xi) x 100.

6. Calculate quarterly average percent deviation (davg): davg = (di) x/n

a. n = number of percent precision (di) values which are valid.

b. (di) x = sum of all valid percent precision values for the quarter

7. If quality control charts indicate an out-of-control situation, the percent precision value for that

period will be considered invalid.

8. Calculate the standard deviation (sj) of percent precision.

a. (di): sj = [(Σ(di)2 – (Σ di)2/n)/(n-1)]1/2. The precision goal of ± 15% should be

reflected in davg and sj, both being ±15%.

B5.1.3 Performance Audits

Continuous gas monitors will be externally audited on a quarterly basis. Audits will be conducted by

an outside contractor and in accordance with reference methods documented in the EPA Quality

Assurance Handbook for Air Pollution Measurements, Volume II. Audit levels will be representative

of typical atmospheric conditions measured at each monitoring station and consistent with section 3.2.2

to 40 CFR part 58. Audit equipment will be independently supplied by the contractor. The contractor

will provide gas standards traceability documentation in the audit report and maintain a file of all

calibration data in relation to the span gas test source used in an audit (Appendix I). The report will

include accuracy probability intervals as described in 40 CFR Part 58 and in the Quality Assurance

Handbook for Air Pollution Measurement Systems, Volume II (19).

B5.2 Particulate Sampler

B5.2.1 T640 & T640x Particulate Continuous Sampler Precision and Accuracy

The precision of the T640 & T640x PM measurements will be subject to four-week verification checks

for each sensor (e.g., barometric pressure, temperature, relative humidity, and flow rate) in the sampler.

The T640 & T640x will be challenged with span dust every four weeks. The accuracy of T640x will be

estimated by routine verification checks, calibrations, and audits. Audit results should be within 10%

as compared to the recent calibration and within 10% of the design flow rate of 16.7 l/m for the T640x

and 5.0 l/m for the T640. If the sampler does not meet these requirements, then calibration, repair,

and/or data invalidation will be performed as required after the issue for the deviation has been inspected

by the external auditor, Air Quality Specialist, and the Air Quality Manager. If the final recommendation

pertains to data validation, this will be determined by the QA Manager (AQ Program Manager or

delegate) as noted in Section B10.5.

B5.2.2 T640 & T640x PM Mass Monitor Performance Audits

The T640 & T640x audits will be conducted by a third-party auditing contractor on a quarterly basis and

will be performed using equipment other than that routinely used for station QC by the AQD. The thirdparty contractor will conduct audits on all auxiliary parameters and the flow rate on a quarterly basis.

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B5.3 Meteorological Instruments

B5.3.1 Meteorological Instruments Precision and Accuracy

Routine maintenance checks and calibrations are specified in SOPs (Appendix D) and in instrument

manuals to ensure good accuracy and precision. The calibration equipment, which will be used for

meteorological instrument/sensor calibration and verification are listed in section B2.3 of this QAPP.

Equipment used for all meteorological parameter verifications/calibrations are annually verified by the

manufacturer and returned with a calibration certificate. Meteorological sensors in the AQD network

are verified on a quarterly basis by the AQD. If any meteorological instrument or sensor is reporting

outside of the accuracy and precision goals detailed in Table 4, or outside of manufacturer specifications,

calibration will be performed by the AQD and/or the manufacturer.

B5.3.2 Performance Audits

Meteorological instruments and sensors will be externally audited every six months. Instruments and

sensors will be verified by an artificial field or by the co-location with transfer standards. An outside

contractor will conduct the audits. The audit report will include audit methods/procedures, equipment

used to conduct the audit, and audit results (Appendix I).

B5.4 Continuous Visibility Monitor

The calibration equipment and gas standards, which will be used for nephelometer calibration and

quality assurance, are listed in section B2.2 of this QAPP. Routine maintenance checks and calibrations

procedures are specified in the SOPs (Appendix F) and in the nephelometer user manual.

B5.4.1 Aurora-1000 Environmental Sensors Precision and Accuracy

Verification equipment used for the Aurora-1000 environmental sensors are annually verified by the

manufacturer and returned with a calibration certificate. Aurora-1000 environmental sensors’ precision

and accuracy objectives are presented in Table 4. The Aurora-1000 environmental sensors are verified

every three months by the AQD. If any of the environmental sensors report outside of the guidelines

specified Table 4, corrective action will be initiated. Calibration of these environmental sensors will be

performed by the AQD and/or the manufacturer.

B5.4.2 Aurora-1000 Zero and Span Checks

A NIST-traceable gas cylinder containing CO2 will be used for auto span calibration conducted once

every 24 hours for the duration of 15 minutes. The zero air is generated in the instrument internally

using a zero air pump and an internal fine particulate filter providing particle free air. The automated

zero calibration will be conducted once every 24 hours for the duration of 15 minutes. Each zero/span

auto calibration will have a stability setting of 95%. If this stability reading is not obtained within the

15-minute interval allotted by the programmed sequence the, the Aurora-1000 will not apply an updated

calibration coefficient. Table 9 details the zero/span check procedure and action for the continuous

visibility monitor.

Table 8. Zero and Span Checks for Continuous Visibility Monitor

Daily check

Calibration Tolerance Action required

Zero Check

± 2 Mm-1

Do zero adjust

-1

± 4Mm

Invalidate data

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Span Check

± 5% of span point*

± 10% of span point*

Do zero adjust

Do full calibration

Invalidate data

Do full calibration

B5.4.3 Aurora-1000 Precision Checks

The nephelometer will be subject to a precision check at least every 24 hours. Precision checks will be

performed manually using NIST-traceable gas cylinder containing CO2 (100% purity), which includes

a zero and span checks detailed in section B5.4.2 of this QAPP.

B5.4.4 Aurora-1000 Performance Audits

The visibility monitor will be externally audited quarterly. Audits will be conducted in accordance with

reference methods used for continuous gas monitors. Audit equipment will be independently supplied

by the auditor. The auditor will provide gas standards traceability documentation in the audit report and

maintain a file of all calibration data in relation to the span gas test source used in an audit (Appendix

J).

B5.5 System Audits

The U.S. EPA Region VIII has performed a systems audit on the Southern Ute Indian Tribe’s Air

Monitoring Network and will conduct systems audits every three years. The Southern Ute Air Quality

Program will conduct an internal systems audit every year that there is not a systems audit performed

by the U.S. EPA.

B6 Instrument Maintenance Requirements/Configuration Control

B6.1 Preventative and Routine Maintenance

Preventative maintenance schedules recommended by all instrument manufacturers will be followed and

are included on each instrument maintenance log sheet, along with some additional procedures added

by the AQD (Appendix A). All maintenance performed on air monitoring instruments that could affect

the instrument’s calibration will be followed by a multipoint calibration check. Maintenance performed

on calibration equipment will be followed by a re-certification of the device if the manufacturer regards

the maintenance as affecting the calibration. All preventative maintenances performed will be

documented. Additionally, the following station checks (routine operating procedures) will be

performed by the AQ Specialist per station visit, ensuring that:

1. that the analyzers are drawing in ambient air at their appropriate flow rates;

2. sample lines are returned to the manifold after any lines are disconnected for flow

checks or other purposes;

3. fittings are snug but not over-swaged;

4. analyzers, data acquisition systems, computers, calibrators, valves, and other

equipment are in their normal operating modes;

5. air conditioning and heating systems are working properly;

6. power cords and adaptors are connected properly and the electrical power supply is

stable;

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7. the indicated time according to the data acquisition system or other system clocks is

accurate, local standard time; and all other items in the Routine Operations SOP are

carried out (Appendix C).

Any issues identified will be documented and resolved.

B6.2 Configuration Control for Logbooks

A standardized format will be utilized to ensure that all necessary information is obtained in the digital

site logbook, located on the AirVision software. This information determines credibility of the data and

should not be erased or altered. Recording of the data should be concise and include all relevant

information. The format should clearly identify the effected parameters, the date and time, circumstance,

purpose of any significant change in the configuration of the air monitoring station, and operating

personnel. Logbook entries will be made during any site maintenance including but not limited to:

1. If tubing is re-routed, or new fittings or other components are added or removed in

any stream of sample air or calibration gas between analyzers, calibrators, or

sampling ports on the station manifold,

2. the relative positions of the analyzer sample ports on the manifold are changed,

3. a new blower is added,

4. the location of a sampler or sampling port is moved, or

5. any similar change in the air monitoring station’s configuration.

B6.3 Instrument Repair

In the event of instrument malfunction or failure, a calibrated replacement shall be installed, if available,

while the downed unit is repaired. Spare parts shall be kept in stock to cover predictable failures as

determined by the instrument maintenance and repair logs. Troubleshooting procedures provided in the

instrumentoperations manual will be followed to diagnose the problem. When a problem cannot be

resolved by these methods, the manufacturer’s technical personnel will be consulted for further

guidance. Once the problem is isolated, corrective action will be taken immediately to minimize data

loss. All resultant information from troubleshooting checks and technical personnel shall be recorded

in the site logbook. The maintenance and repair logs will be used to signal the need for more frequent

maintenance activities to reduce the occurrence of failure resulting in lost data.

B7 Instrument Calibration and Frequency

B7.1 Continuous Gas Monitors

All continuous gas monitors will be subject to a multi-point calibration at least quarterly. The calibration

equipment and gas standards discussed in section B2.1 of this QAPP will be used. Requirements for

continuous gas analyzer calibration standards are presented in Table 9.

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Table 9. Requirements for Continuous Gas Monitor Standards

Equipment Used to Calibrate

Monitoring Equipment

Regional Standard Reference

Photometer (Level One Ozone

Transfer Standard)

Level Two Ozone Transfer Standard

(Ute 1 Teledyne API T700)

Level Three Ozone Transfer

Standard (Ute 3 and MMS Teledyne

API T700)

Acceptance Criteria

Regression slope = 1.00 ± 0.01ppb

Intercept ≤ 1.00ppb

±4% or ±4ppb (whichever is greater)

Frequency

1/yr

EPA Protocol Gases have a 36month certification period and

must be recertified to extend the

certification.

Standardized Mass Flow Calibrator

1/yr

±2% of NIST-traceable standard

BIOS Dry Cal220 H and 220 L

Bios International Corporation

*Acceptance criteria of standards: A certificate or laboratory results from the organization providing additional quality

assurance information pertaining to the traceability of the AQP monitoring standards will provide documentation containing

the following information: verification results, date, operator initials, and whether these requirements were met.

Cylinder of Compressed Gases

Gas standard

NIST Traceable

(e.g., EPA Protocol Gas)

Zero air used for zero checks and dilution of the calibration gas cylinders will be dry and free of

contaminants that may cause a response from the monitor or which may react with the gases being

monitored.

During calibration, span gas will pass through as much of the sampling train as is practical to ensure a

high degree of similarity between treatment of ambient air and simulated atmosphere used for calibration

and quality assurance purposes. For the nitrogen dioxide measurements, calibrations will be performed

utilizing gas phase titrations and a cylinder containing a NIST gas standard that contains a known

concentration of NO. The Ute 1, Ute 3, and MMS Teledyne API T700 calibrators will be cycled as as

the level two transfer standard for O3 and will be used to calibrate the level three transfer standard

(Teledyne API T700 calibrators) When available, an approved level 2 transfer standard from a verified

third party contractor will be used.The level two reference photometer will be annually

calibrated/verified using EPA Region VIII’s level one SRP and laboratory facilities. Each Teledyne

API T700 calibrator contains an internal ozone generator and photometer which will be used to calibrate

and verify the ozone analyzers at the corresponding stations. The appropriate gaseous calibration sheet

(Appendix C) will be completed during the calibration of the monitor.

B7.1.1 Calibration Procedures and Multipoint Calibration Check Procedure

1. Allow sufficient time for the calibration system and analyzer (if applicable), to warm-up and

stabilize.

2. Connect calibration gas delivery system to the monitor’s sample inlet line. Be sure delivery

system is properly vented and that sufficient flow exists.

3. Increase analyzer averaging time to 300 seconds.

4. Deliver zero air to analyzer, allowing sufficient time for analyzer to stabilize by reviewing AVtrend real-time data trending time series. Record the unadjusted zero reading.

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5. Adjust the monitor output to zero, if necessary (see Section B5.1.1.1). Allow sufficient time for

monitor to stabilize as indicated on the AV-trend real-time data trending time series.

6. Ensure analyzer has a nice steady zero response, centered on zero.

7. Record the zero adjustment.

8. Deliver span gas test concentrations to analyzer, allowing sufficient time for the monitor to

stabilize as indicated on the AV-trend real-time data trending time series. Record the observed

span reading.

9. Adjust monitor span output to the span gas test concentration value, if necessary. Allow

sufficient time for monitor to stabilize as indicated on the AV-trend real-time data trending time

series.

10. Ensure the instrument has a steady response centered on the span value.

11. Record the adjusted span reading and the span adjustment (see Section B5.1.1.1).

12. Generate five targeted concentration points which cause a monitor response of twenty, thirty,

forty, sixty, and eighty percent of the operating range, and record calibrator delivery and

analyzer response for each.

13. Plot the calibrator delivery concentrations (y-axis) against the analyzer response values (x-axis)

and apply a simple linear regression.

14. The correlation coefficient® for the linear equation listed in step 8, r should be ≥0.998.

15. Return analyzer averaging time to 30 seconds.

A calibration and multi-point calibration check will be performed whenever any of the following

conditions occur.

1. Quality control charts illustrate excessive drift and or instrumental noise exceeding or

equal to zero and/or span drifts of the targeted QC concentration (see Section

B5.1.1.1).

2. A monitor is initially installed or re-installed.

3. A monitor is relocated.

4. A monitor undergoes maintenance or repairs.

5. Monitor operation is interrupted for more than a few days.

6. Upon any indication of monitor malfunction or change in calibration.

B7.2 Continuous Visibility Monitor

The continuous visibility monitor will be subject to auto zero/span calibration every 24 hours for

duration of 15 minutes. The calibration equipment and gas standards used will be as discussed in Section

B2.2. Standards used to calibrate the visibility monitor require calibration against NIST-traceable

standards and its calibration frequency are summarized in Section B2.2. NIST-traceable compressed

CO2 gas will be re-certified when the cylinder pressure drops below 200PSI. The zero-air used for

setting the zero will be free of particulate matter as it passes through the instrument and measured as a

reference. A full calibration procedure is accomplished through an automatic sequenced event and is

accessed from the calibration menu. Refer to Appendix F, section 4.2.2 to this QAPP for the Aurora1000 single wavelength integrating nephelometer user manual for further menu operations.

The Aurora-1000 environmental sensor calibrations will be conducted in the field using a co-location

method, employing the AQD’sNIST-traceable verification equipment listed in Section B2.2. A record

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of verification results will be maintained in the site logbook and documented on the appropriate

instrument maintenance log sheet. If any of the environmental sensors fail the verification check, the

sensor will be returned to the manufacturer to be recalibrated and certified. The Aurora-1000

environmental sensors will meet the following criteria:

1. Barometric Pressure: Accuracy of ±10% of observed.

2. Temperature: Accuracy of ±2°C.

3. Relative Humidity: Accuracy of ±10% of observed.

Certification and calibration of the verification equipment will be performed annually against NISTtraceable standards.

B7.3 Meteorological Instruments

All meteorological instruments at each monitoring site will be verified at least quarterly using the AQD’s

meteorological verification equipment listed in Section B2.3 and/or equipment used during an external

audit. All meteorological verification will be conducted in the field using a co-location method between

the AQD’s NIST-traceable verification equipment and the site’s meteorological instruments/sensors. A

record of verification results will be maintained in the AirVision digital logbook and documented on the

appropriate verification forms (Appendix D). If any of the site’s meteorological instruments fail the

verification check, the instrument will be returned to the manufacturer to be recalibrated and certified.

Meteorological instruments at each site will meet the following criteria:

Wind Direction.

1. Ensure that wind direction monitor is properly aligned towards north.

Wind Speed:

1. Zero reading must be less than 0.5 mph.

2. Accuracy of ± [0.4 mph (0.2m/s) + 0.5% of observed].

Ambient Air Temperature.

1. Accuracy of ±0.5 °C.

Precipitation:

1. Resolution of 0.01 inches (0.3mm) at precipitation rates up to 7.6 cm/hr (3 in/hr).

2. Heating system to assure accurate measurement of frozen precipitation.

3. Suitable windscreen.

Solar Radiation:

1. Accuracy of ±5% of observed.

Relative Humidity:

1. Accuracy of ±2% between 0 and 90% RH.

Certification and calibration of the meteorological verification equipment will be performed

annually against NIST-traceable standards.

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B7.4 T640 & T640x Particulate Continuous Samplers

The sensors and pneumatics of the T640 & T640x will be verified every four weeks. Calibrations will

be completed on an annual basis or after an unsatisfactory verification is conducted by the Air Quality

Program Manager or Air Quality Specialist. Leak tests will be performed every four weeks as part of

the verification process.

B7.5 Reserved

B8 Inspection and Acceptance of Supplies and Consumables

The Air Quality Program Manager is responsible for ordering and maintaining supplies. Acceptance

criteria must be consistent with overall project technical and quality criteria. Some of the acceptance

criteria are specifically detailed in 40 CFR Part 50. Other acceptance criteria, such as observation of

damage due to shipping, can only be performed once the equipment has arrived on site. Critical supplies

will be purchased as needed from the specific instrument manufacturer or other acceptable suppliers.

Table 11 shows the supplies that are considered critical and are associated with the AQD monitoring

network, along with established vendors for these and suggested quantities.

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Point of Use

Documentation

Item

Table 10. Critical Supplies and Consumables

Description

Vendor

Site logbook

AirVision digital

logbook

In analyzers & PM2.5

samplers

Analyzer/sampler

Fuses

Data retrieval

Analyzer/Calibrator

Flash drive

Replacement parts

USB

In analyzer

Meteorological

instruments

Replacement parts

In instrument

Zero Air Supplies

Purafil or Charcoal

columns

Stainless Steel

Fittings and tubing

Instrument Plumbing

Analyzer

Teflon tubing and

fittings

GAST Compressor

Field operation use

T640 & T640x

Teflon particulate

filters

Replacement parts

Low-lint wipes

Filters

T640 & T640x

Calibration

Vacuum pump kit

Calibration Gas

Flow Verification

Temp/RH

Verification

Flow Meters

Temperature,

Pressure, and RH

Transfer Standards

DI water filtration

and separation

Teflon tubing

manifold and

supporting fittings

and items

H2 Generator

Manifold

Refillable cartridges in

the front of the machine

For plumbing upstream

of calibrator and

downstream of

instruments

For plumbing

downstream of the

calibrator and upstream

of instruments

Analyzer/sample line

filters

In compressor

Cleaning wipes

47 mm Glass fiber

whatman filter

Rotary vane rebuild kit

NO/

CO2

Alicat

Druck DPI 105

Barometer, SAM 990

DW RH

Parker H2 generator

service kit

Teflon tubing, gaskets,

fittings

Agilaire

Thermo Scientific,

Teledyne API, local

electronic store

Electronics store

Thermo Scientific,

Teledyne API

Campbell Scientific, RM

Young, Vaisala,

Weathertronics, Nova

Lynx, LI-COR, Ecotech

Teledyne API

Quantity

Swagelok

Savillex

Savillex, American

Ecotech

FIERO Fluid Power, Inc.

Local hardware store

Teledyne API, American

Ecotech

Teledyne API

Praxair

Alicat

Chinook

Engineering/InterMountain Labs

Webster Associates

3 boxes

1 per station

Savillex

B9 Data Acquisition Requirements

The data used, which are not obtained from direct measurement, will be obtained from reputable, quality

assured sources such as the National Weather Service, National Oceanic and Atmospheric

Administration, the National Institute of Standards and Technology, or other similar sources. The data

will consist of physical constants, weather data, housing information, and other such data.

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B10 Data Management

Due to the potential use of all data collected for comparison to the NAAQS, extreme care in handling

the raw data will be followed.

B10.1 Data Entry/Formatting

All data will be transferred to the EPA Air Quality System (AQS) database. Formatting data for

submission to the AQS will be performed promptly and carefully. All gaseous and meteorological data

are automatically polled from each Agilaire 8872 datalogger to a central Air Vision server via a wireless

router/ modem with serial numbers and IP address information controlled by the Air Quality Program

Manager and the Air Quality Specialist.

Any data manually entered by the AQD staff will be subjected to additional quality assurance

procedures. Manually entered data is defined as data that is manually polled for discrete parameters.

Precision and accuracy data resulting from four-week verifications and quarterly audits are considered

manually entered data and are submitted to AQS using the precision/accuracy setting in the transaction

generator. All discrete data collected will be subjected to additional quality assurance practices ranging

from double entry checks that calculate differences in values entered for the parameter values and third

party “AQD Manager” review prior to AQS submittal. The AQD Division Head may choose to delegate

the third-party review to a qualified SUIT Environmental Programs Division staff member.

B10.2 Raw data

Raw data are worksheets, records, memoranda, notes, or exact copies and are the result of original

observations and activities of a monitoring project. Raw data include data from automated routines, data

entered into a system directly by keyboard or automatically.

B10.3 Data transfer

The gaseous, meteorological, particulate, and visibility instrument hourly average values are recorded

by Agilaire dataloggers and stored locally and on the central Air Vision server indefinitely. Minute

averages of all continuous parameters are stored on Agilaire datalogger locally for three months and on

the central Air Vision server for two years. The AQD has initiated an automated routine in the Air

Vision software to poll data from each site to the central server every few minutes to ensure maximum

data capture during unexpected events that can contribute to significant data loss. Significant data loss

can arise from shelter temperatures exceeding requirements, power failures, and electronic instrument

communication failure.

Precision and accuracy data will be entered manually into an appropriate transaction generator for

formatting or exported directly from Air Vision for AQS submittal and will be subjected to all data

validation requirements (Section B10). The AQD monitoring data is filed in chronological order and in

accordance with the air quality record retention and filing protocol (Appendix G). All data generated at

each monitoring station is quality assured and formatted for submission to the AQS by the Air Quality

Progrqam Manager using Air Vision and/or transaction generators for all discrete parameters within the

AQD monitoring network.

B10.4 Data Validation

Data validation encompasses correct data processing operations stemming from field procedures

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conducted in a manner consistent with the AQD SOPs by the Air Quality Specialist and the Air Quality

Program Manager. Proper data validation can identify problems in field operations and issues with

instrument performance. Once problems are identified, the data can be corrected or invalidated with the

appropriate corrective actions determined by the responsible laboratory facility and/ or AQD monitoring

staff. Data validation for the AQD field operations consist of internal audits conducted by the Air

Quality Program Manager on all field operations performed by the Air Quality Specialist. The internal

audit conducted will be held to the same quality assurance practices as external quarterly audits using

the AQD internal transfer standards, SOPs, and instrumental operator manual performance procedures.

In the event of suspect data resulting from an internal audit, external audit and/or out of range

instrumental response, the Air Quality Program Manager will be responsible for reviewing field

notebooks, electronic AirVision logbook, previous modifications and general maintenance procedures

conducted by the Air Quality Specialist and possibly invalidating data that correlates to changes and

previous modification indicated by or directly noted in the field notebook or by the Air Quality

Specialist. Data subject to possible invalidation will be reviewed up to or prior to, the most recent

applicable precision and/or accuracy data that has been previously submitted to the EPA AQS database

that meets minimal percent difference values indicated within the selected AMP reports and corresponds

to the subjected data range in question. If the Air Quality Technical Manager deems it necessary that

the data within the suspected range is indeed out of instrumental manufacturer performance

specifications and/or falls below the EPA Quality Assurance guidelines, indicated in the validation tables

of the EPA Quality Assurance Handbook for Ambient Air Monitoring, the data range under question

will be invalidated in AQS, following additional AQD discussions with the Air Quality Division Head,

Air Quality Program Manager and detailed review of the suspected data by a Region VIII quality

assurance representative.

The Air Quality Division Head will make the final decision on suspect data and corrective actions.

Secondly, if data within the suspected range is not consistent with the validation criteria listed within

the AQD QAPP based on instrumental communication error, data controller storage failure, shelter

temperature requirements, or power failures caused by adverse weather conditions the suspect data will

be reviewed by the respective parties listed above. All actions pertaining to relevant data invalidation

documentation will be handled in accordance with the AQD record retention and filing protocol. The

Air Quality Division Head will be notified prior to the time data subject to invalidation is removed from

or resubmitted to AQS. Additionally, station trend analyses will be conducted on the reported

parameters in question to confirm if any significant differences among the Ute 1, Ute 3, and MMS

stations are present.

B10.5 Data transmittal

Data transmittal occurs when data is transferred from one person or location to another or when data is

copied from one form to another. Some examples of data transmittal are copying raw data from a

notebook onto a data entry form for keying into a computer file and electronic transfer of data over a

telephone or computer network. The AQD will report all ambient air quality data and information in

accordance with the AQS User Guide. The data will be coded in the AQS format. The AQD gaseous

and metrological data will be validated as per section B10.4 of this QAPP and will be submitted directly

to the AQS via electronic transmission, in the AQS format, and in accordance with the monthly schedule

(Appendix E-AQS Data Submittal SOP).

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B10.6 Data reduction

The data reduction process involves aggregating and summarizing results so that they can be understood

and interpreted in different ways. 40 CFR 58.16 Data Submittal and Archiving Requirements require

certain summary data to be computed and reported regularly to EPA.

B10.7 Data analysis

The AQD will implement the data summary and analysis requirements contained in appendix A to 40

CFR Part 58. Single analyzer accuracy (based on performance audits), single analyzer precision

(precision check data) and data completeness will be tracked and reported for the monitoring network.

B10.8 Data flagging

The AQD will flag a data value that: (a) did not produce a numeric result, (b) produced a numeric result

but is qualified in some respect related to the type or validity of the result, or (c) produced a numeric

result but for administrative reasons is not to be reported. Qualifiers will be used to signify samples that

may be suspect due to contamination, special events, or failure of QC limits. Qualifiers can also be used

to determine if reported gaseous, meteorological and/or visibility reported values are of suspect due to

contamination, special/exceptional events, or failure of QA/QC limits. In all cases, the sample or

reported data values will be thoroughly reviewed prior to any invalidation. The AQD will keep a record

of the flags on the appropriate forms and/or logbooks that result in data invalidation. Null data codes

will be generated for invalid data as they are entered into the AQS database.

B10.9 Data storage and retrieval

Duplicate data electronic copies are stored and backed up on the SUIT central server consistent with

appendix G.

GROUP C ASSESSMENT/OVERSIGHT

C1 Assessments and Response Actions

A network review will be performed at least every year for each monitoring station. Based on the

network review, adjustments to the monitoring network shall be made. Performance audits will be

performed as outlined in Section B5. Audit results will be used to evaluate the performance of field

staff in maintaining the monitoring network within the quality control goals of the program.

Listed below are the Tribe’s expectations regarding the roles of the auditors, AQD staff, and the QA

Manager (who is the Air Quality Division Head or their delegate):

A performance audit should be conducted only if calibration data are available for the

analyzers or samplers being audited.

A performance audit should be conducted only if the site or operator or representative

is present, unless written permission (i.e., email) is given to the auditor before the

audit.

Before the audit, a general procedures protocol including the audit policy and special

instructions from the auditor should be provided to the Southern Ute Indian Tribe Air

Quality Division.

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f. d. The auditor should discuss the audit results with the site operator or representative

at the conclusion of the audit. If the site operator or representative is not on-site at the

conclusion of the audit, the auditor should contact the AQD before leaving the area

or property when returning to the base of operations. A brief summary, can be an email, should be provided listing the most important findings from the audit and should

indicate that the results are not official until the final report is issued.

g. If the AQD has written comments or questions concerning the audit report, the auditor

should review and incorporate them as appropriate, and subsequently prepare and

resubmit a report in final form within thirty (30) days of receipt of the written

comments. Copies of this report should be sent to the AQP for internal distribution.

The transmittal letter for the amended report should indicate official distribution and

again draw attention to the agreed-upon schedule for corrective action

implementation.

A corrective action form should be completed when a problem requires either immediate or long-term

action to correct a safety defect, an operational problem, or a failure to comply with procedures.

The form is initially completed to identify the date, the person reporting the issue, the person the

resolution is assigned, the station/equipment impacted and a description of the issue. Upon completion

the form documents what was corrected, the impact to any data, the date completed and is signed by an

approver verifying the resolution. The form is maintained on the SUIT network server.

The EPA may conduct an audit on the environmental data collection activities conducted by the AQD.

All additional QA practices/activities associated with external auditing procedures and/or additional

QA/QC procedures conducted by contractors or subcontractors will be the responsibility of the AQD.

40 CFR 58.15 requires the AQP to submit an annual air monitoring data certification letter to certify

data each year that covers the previous calendar year. The certification letter shall be accompanied by

three AQS summary reports (AMP450,AMP255, and AMP450NC) and addressed to the EPA Regional

Administrator.

C2 Reports to Management

This section describes the quality-related reports and communications to management necessary to

support network operations and the associated data acquisition, validation, assessment, and reporting.

Periodic assessments of data quality are required to be reported to the EPA. This is done through semiannual and annual reports. These reports will be submitted to the EPA Region VIII Tribal Program

Manager as indicated in section A8 of this QAPP. The reports also provide for the review of the air

quality surveillance system on an annual basis to determine if the system meets the monitoring objectives

defined in appendix D to 40 CFR Part 58. Such review will identify needed modifications to the network

such as termination or relocation of unnecessary stations or establishment of stations that are necessary.

The reports will include information for each ambient air pollutant in the Air Quality Division

monitoring network.

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GROUP D

DATA VALIDATION AND USABILITY

D1 Data Review, Validation, and Verification Requirements

D1.1 Continuous Gas Monitors

Continuous gas monitors, the T640, and the T640x will be calibrated as outlined in section B7 of this

QAPP. Calibrations followed by multi-point calibration checks, flow rate, auxiliary parameters and

audit data will be used to provide an accuracy assessment of the pollutant gas data collected.

Precision and accuracy criteria given in appendix A to 40 CFR Part 58 will be followed. The application

and definitions of the program criteria are given in section B5.1 of this QAPP. Data collected during

periods when system response indicates precision and bias goals (Table 2 and Appendix H) have been

achieved will be considered valid.

D1.2 Reserved

D1.3 Continuous Visibility Monitor

The visibility monitor will be calibrated as outlined in Section B7.2 of this document. Full calibration

procedures and audit data will be used to provide an accuracy assessment of the visibility data collected.

The data collected during periods when the system response indicates precision and accuracy goals

(Table 3 and Section B5.4) have been achieved will be considered valid.

D1.4 Meteorological Instruments

All meteorological instruments will be calibrated as outlined in Section B7.3 of this document. The

calibration procedures, parameters, and all associated information will be recorded in the site logbook

and instrument maintenance log sheets shown in Appendix D to this QAPP. Meteorological data that is

collected during periods when the system response indicates precision and accuracy goals (Table 4 and

Section B5.3) have been achieved will be considered valid.

D2 Validation and Verification Methods

Data verification is conducted by checking that the SOPs were followed and that QC limits were met.

One of the major objectives for the AQD is for comparison to the NAAQS and therefore, this is identified

as the intended use. This section will describe the verification and validation activities that occur at a

number of the important data collection phases. Earlier elements of this QAPP describe in detail how

the activities in these data collection phases are implemented to meet the Data Quality Objectives

(DQOs) of the AQD. Review and approval of this QAPP by the personnel listed on the approval page

provide initial agreement that the processes described in the QAPP, if implemented, will provide data

of adequate quality. In order to verify and validate the phases of the data collection operation, the AQD

uses qualitative assessments (e.g., technical systems audits, network reviews) to verify that this QAPP

is being followed, and relies on the various quality control samples, inserted at various phases of the

data collection operation, to validate that the data will meet the DQOs.

D2.1 Data Collection/Quality Control Procedures

The Air Quality Specialist will be the first to validate and verify the data. Visual review of raw data will

be performed to identify atypical or suspect data values that warrant further investigations and these

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values will be flagged. The review of QC data such as the precision/bias data, audits (accuracy data),

and equipment verification checks that are described in Section B5 are used to verify that the data meet

the objectives. The Air Quality Specialist will also use the data validation templates provided in the

Quality Assurance Handbook for Air Pollution Measurement Systems, Volume II (Final Draft-August

2008). These data validation templates contain the list of criterions for criteria pollutants that must be

met to ensure the quality of the data and are found in appendix H of this QAPP. Also, the Air Quality

Program Manager will review the appropriate logs/forms, AV-Trend, Air Vision, and quality control

charts to determine the following:

- Is the suspect value due to instrument failure?

- Is the suspect value a result of atypical instrument response during

QC checks, maintenance, or repair?

- Is the suspect value a result of improper data collection or handling?

- Is the suspect value a result of data transmittal error?

- Is the suspect value a result of an exceptional event?

- Does collected data meet precision, accuracy, and bias goals?

The Air Quality Specialist will document any evidence in support of or against the occurrence of any of

the above using the station logbook, located in the AirVision software. The Air Quality Specialist will

make a recommendation based on the evidence and present data to the Air Quality Program Manager

for review.

The Air Quality Specialist will review all data values. Non-flagged values will be reviewed for suspect

values that may have been overlooked. The Air Quality Specialist will flag these values for further

investigation. Values passing the Air Quality Program Manager’s review will be deemed valid. Flagged

values will be reviewed and either invalidated or validated based upon the supporting evidence or

flagged by the Air Quality Specialist for further investigation. The Air Quality Program Manager will

investigate and review any new supporting evidence and make a validity determination. If a value

remains suspect, the Air Quality Program Manager will present the data and evidence to the Air Quality

Division Head, who is the QA Manager, or their delegate, for review, recommendation, and final validity

determination on the questionable data. The dates and reasons for data that is assigned an AQS Null

Code, Flag, or Qualifier code will be documented monthly per the Continuous Monthly Data QA/QC

SOP.

Data can be invalidated for the following reasons:

• Data value is due to instrument malfunction.

• Data value is due to Z/S/P or calibration procedures.

• Data value is lost or damaged during transmission from the Agilaire datalogger to the

AQ laptop, in the event manual uploading of the data is required .

• Data value is due to maintenance/routine repairs.

Validation of QC procedures will also require a review of the documentation of the corrective actions

that were taken when QC samples failed to meet the acceptance criteria, and the potential effect of the

corrective actions on the validity of the routine data. Section B5 of this QAPP describes the techniques

used to document QC review/corrective action activities.

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D2.2 Data Reduction and Processing

As part of the quality assurance practices associated with data quality, discussed in section B.10 of this

QAPP, all parameters will be investigated in a station trend analysis every month prior to data validation

procedures and submittal to AQS using AirVision by the Air Quality Program Manager. An example

of an investigation would include review of verifications/calibration records, QC documentations for the

parameter or parameters in question, and instrument specific auxiliary parameters such as sample flow

rate, analog output, converter efficiency, UV lamp voltage, and reaction cell temperature. All raw data

files associated with these records, including the following are reviewed:

•

Sampling information

Calibration - the calibration information that is relevant to that sampling period

Sample handling/custody

Corrective action

Data reduction

All raw data that is manually entered on data sheets will be independently verified by the Air Quality

Program Manager and the Air Quality Division Head as discussed in Section B10, prior to final submittal

to the AQS database. The entries are compared to reduce the possibility of entry and transcription errors.

Once the data is entered into AQS, the system will review the data for routine data outliers and data

outside of acceptance criteria. These data are flagged appropriately. All flagged data are re-verified

that the values are entered correctly. Details of these activities are discussed in Section B10 and the

AQS Data Submittal SOP (Appendix E). The following QC functions are incorporated into the Agilaire

datalogger and AQS Database to ensure quality of data entry and data processing operations:

•

Range Checks - all monitored parameters have simple range checks programmed either

in Agilaire datalogger or the analyzers. For example, valid times must be between

00:00 and 23:59, summer temperatures must be between 10°C and 50°C, etc. The data

entry operator is responsible for noting when an entry is out of range. The operator has

the option of correcting the entry or overriding the range limit. The specific values

used for range checks may vary depending on season and other factors.

Completeness Checks – during processing the Agilaire datalogger completeness certain

criteria checks. For example, each data point must have a start time, an end time, an

average flow rate, date and technician name(s). The person making the data entry is

notified if an incomplete record has been entered before the record is considered valid

and can be included in any report.

Internal Consistency and Other Reasonableness Checks - Several other internal

consistency checks are made by the Air Quality Specialist and Air Quality Program

Manager reviewing the data. For example, the end time of a data set must be greater

than the start time. Additional consistency and other checks are implemented as the

result of problems encountered during data validation.

Data Retention - Raw data sheets are retained on file in the AQD Office for a minimum

of five years and are readily available for audits and data verification activities. After

five years, the AQP staff will follow the record retention and filing protocol detailed in

Appendix G of this QAPP.

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Validated data surpassing all quality assurance criteria will be converted electronically into the AQS

format. The data will then be submitted to the AQS database by the AQD.

D3 Reconciliation with Data Quality Objectives

The Measurement Quality Objectives (MQOs) are listed in Tables 2, 3, 4, and 5 of this QAPP.

Possible questions that can be considered during this “Reconciliation with Data Quality Objectives”

process include:

•

Were the NAAQS exceeded?

Were all QA/QC check completed?

Were all Quarterly audits conducted?

The AQD’s purpose for ambient air data collection is to protect the health and welfare of all residents

within the Reservation’s airshed by collecting reliable ambient air monitoring data that is quality assured

in accordance with this QAPP. The AQD will extend the quality assurance through the development of

station trend reports. The annual station trend reports will compare current emissions inventory data

with AQS certified ambient air monitoring data from the regional area.

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2. Ecotech Environmental Monitoring. Aurora-1000 Single Wavelength Integrating

Nephelometer User Manual. Version 1.3. May 2009.

3. R.M. Young Meteorological Instruments. Wind System Calibration Instruction Manual. Model

18860-90 June 2009.

4. R.M. Young Meteorological Instruments. Tipping Bucket Rain Gauge Model 52202/ 52202H/

52203 Instruction Sheet. Rev K042417 April 2017.

5. Teledyne Advanced Pollution Instrumentation Division. Model T700 Dynamic Dilution

Calibrator P/N 05621B4. June 2015.

6. Teledyne Advanced Pollution Instrumentation. Model T640 PM Mass Monitor. April 2021

7. Teledyne Advanced Pollution Instrumentation Model T200 NO-NO2-NOx Analyzer Instruction

Manual. August 2015.

8. Teledyne Advanced Pollution Instrumentation Model T400 O3 Analyzer Instruction Manual.

August 2022.

9. Thermo Electron Corporation. Model 42i Chemiluminescence NO-NO2-NOx Analyzer

Instruction Manual P/N 101350. July 2015.

10. Thermo Electron Corporation. Model 48iQTL Gas Filter Correlation CO Analyzer Instruction

Manual P/N 119014. September 2018.

11. Thermo Electron Corporation. Model 49i UV Photometric O3 Analyzer Instruction Manual P/N

102434-00. September 2017.

12. AQS Data Coding Manual. Version 3.5. Date Revised: June 2, 2015.

13. U.S. EPA. Meteorological Monitoring Guidance for Regulatory Modeling Applications.

February 2000.

14. U.S. EPA. National Ambient Air Quality Standards for Particulate Matter. Final Rule 40 CFR

Parts 50, 53, and 58 Federal Register.

15. U.S. EPA. Office of Research and Development. List of Designated Reference and Equivalent

Methods. December 2022.

16. U.S. EPA Quality Assurance Handbook for Air Pollution Measurement Systems Volume II

January 2017.

17. U.S. EPA Quality Assurance Guidance Document 2.12: Monitoring PM2.5 in Ambient Air

Using Designated Reference or Class I Equivalent Methods. January 2016.

18. U.S. EPA. Transfer Standards for Calibration of Air Monitoring Analyzers for Ozone technical

assistance document. October 2013

19. Thermo Electron Corporation. Model 55i Direct Methane, Non-Methane Hydrocarbon

Analyzer Instruction Manual P/N 103962. August 2012

20. Thermo Electron Corporation. Model 42i Chemiluminescence NO-NO2-NOx Analyzer

Addendum. October 2022.

21. Thermo Electron Corporation. Model 49i Ozone Analyzer Addendum. October 2022.

22. Thermo Electron Corporation. Model 55i Direct Methane, Non-Methane Hydrocarbon

Analyzer Addendum. October 2022.

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.