Annual Air Monitoring Data Concurrence Certification and …€¦ · SLAMS and SPMs - that meet 40 CFR Part 58 Appendix A Includes CO, NO 2, SO 2 (hourly AND 5-min), O 3, Pb, PM 10,

Annual Air Monitoring Data Certification and Concurrence Process (EPA Certification Evaluation)EPA REGION 1, AND OAQPS

NAAMC- Portland, OR- QA 101 August 13, 2018

Agenda➢What is Certification and EPA’s Certification Evaluation*Requirements

➢Certification Flags and AQS Flagging Criteria

➢Process➢Run report and data review

➢Setting certification flags

➢EPA “certification evaluation”

➢Re-certification of modified data

➢Summary Points

2NAAMC- Portland, OR- QA 101 August 13, 2018

*Certification Evaluation and EPA Concurrence have been used fairly interchangeably. As a technical matter, States certify the data, and EPA reviews the data (with the AMP600) and evaluates whether or not we identify significant QA or completeness issues. We are not concurring, we are evaluating the data the State has certified against a pre-defined subset of parameters.

What is Annual Data Certification and EPA Certification Evaluation (concurrence)

➢Formal statement attesting to ambient data completeness and accuracy

➢Submitted by certifying agencies to EPA on annual basis

➢Process that combines a required action followed by an EPA review and setting Certification Evaluation (concurrence) flags.


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➢The agency shall submit to the EPA Regional Administrator (RA) an annual air monitoring data certification letter to certify data collected by FRM, FEM, and ARM monitors at SLAMS and SPM sites that meet criteria in Appendix A from January 1 to December 31 of the previous year

➢The head official shall certify that the previous year of concentration and QA data are completely submitted to AQS and are accurate

➢The annual data certification letter is due by May 1 of each year.

40 CFR 58.15Annual Data Certification


40 CFR 58.15

➢Along with each certification letter, the agency shall submit to the RA:◦ An annual summary report (AMP600) of all the ambient air quality

data collected by FRM, FEM, and ARM monitors at SLAMS and SPM sites.

◦ The AMP600 shall be submitted for data collected from January 1 to December 31 of the previous year.

◦ The AMP600 serves as the record of the specific data that is the object of the certification letter.

◦ The AMP600 contains a summary of the precision and bias data for all ambient air quality data collected by FRM, FEM, and ARM monitors at SLAMS and SPM sites


Certification Submission by May 1, Each Year


The AMP600 and signed summary report

Which data are “certified”?

Data to be certified:

All data from FRM/FEM/ARM -SLAMS and SPMs - that meet 40 CFR Part 58 Appendix A

Includes CO, NO2, SO2 (hourly AND 5-min), O3, Pb, PM10, PM2.5, and PM10-2.5

Data that do not require certification:

Non FRM/FEM/ARM continuous PM monitors

PM2.5 speciation data

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

Meteorological data

Air Toxics Data

NOTE: SLTs are not required to certify data from CASTNET monitors


Validation versus CertificationTECHNICAL REVIEW, IN THE WEEDS

DAILY & MONTHLY REVIEW PROCESS*

10,000-FT VIEW OF DATA

ANNUAL REVIEW PROCESS


*States/ locals perform these reviews regularly. Many EPA Regions provide some daily reviews, and detailed quarterly AQS reviews.

Data certification is a “big picture” assessment

If data validation has been robust and thorough each quarter, data certification is a quick, easy process!

Signed, certification letter

Required AQS Reports

◦ AMP 600 Report

◦ AMP450NC for PM10-2.5 data (NCore)

Should not be the time when an agency is “validating” their data in AQS!

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EPA Concurrence / certification evaluation

Does not mean that EPA has completed any “validation” of the agency’s data!

Data validation is the sole responsibility of the monitoring organization!

Concurrences indicates that EPA has reviewed the data certification package and agrees with the AQS cert-flags applied to the data


Data Certification Information On AMTIC


Data Certification Qualifier Values


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1.Dark blue shaded rows are evaluations that will be reported (when data is available) but not used in certification flag setting

2.One Red for any monitor will elicit a AQS recommended “N” flag

3.Three warnings (yellow) for any monitor will elicit an AQS recommended “N” flag

4. AQS outlier reports under development

Criteria that Generate Green (Acceptable) Warning (Yellow) and “N” Qualifiers (Red)

Guidance document provides requirements for all criteria pollutants.


https://www3.epa.gov/ttn/amtic/qacert.html

https://www3.epa.gov/ttn/amtic/qacert.html

The example

Step #1 Review AMP600 Summary Report to Identify Major Issues


Data Review


Data Completeness Report

➢ Data for site meets completeness for ozone Season (Mar-Sept.) (PAMS req. monitor)➢ A separate check of the AMP 251/256 shows appropriate number of QC checks for season➢ Conclusion: Data was appropriate for the time the site was required to be operated

Step #2 Certify the Data

1. Go to AQS; pull up certification form

2. Select Agency, State and Parameter

3. Form includes AQS Recommended Flags

4. Time to certify and/or edit



1. Certifying Agency applies flags

2. Flags can be applied singly or as a batch

3. Any change in AQS flag must include a comment

4. Once completed save work.

5. Once saved it will show up as a “S” submission in EPA Evaluation Column

Step #2 Certifying the Data

Step #2 AMP 600 After Certifying Agency Certification

Certifying Agency comment added to AMP600



1. Similar to Certifying Agency flagging

2. EPA should comment on any change to AQS flag

3. EPA saves concurrence which will set final concurrence flag

Step #3 EPA Review and Concurrence/

Cert. Eval

Certifying Agency comment added to AMP600


Step #3AMP 600 After EPA Concurrence

AMP 450 Report

Only EPAconcurrence flags show up in final AMP reports

Modified data


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Modifying a Sample Measurement Will Remove Concurrence Flag

• EPA Concurrence flag turned to “M”

• Certifying agency would need to recertify data and submit to EPA for concurrence

EPA did norationale a

“M” flag o


t agree with certifying agency nd did not concur

n site where data was modified

Data Recertification

➢If any agency modifies sample measurement concentrations in AQS after certification, the cert-flag will automatically change to “M” – to alert data users and EPA that changes have been made

➢Recertification of data is needed after such changes (for example, as “may” have happened as a result of OIG audit and ozone p-checks)

➢A recertification package can be for a single pollutant, site monitor etc.➢Example: Revised AMP 600 & signed letter for ozone only


Data Certification Summary Points-Region 1

➢Region 1 runs quarterly AMP251, AMP256, AMP430 and AMP504 reports to ensure no surprises in AMP600

➢Run AMP600 as soon as complete year of data reported to AQS, typically as soon as we get word from our States that all 4th quarter data is in.

➢AQS recommended “N” flags need thorough review and a good rationale if you want to reverse AQS recommended flag. In Region 1, if AQS recommends an “N”, pretty much, you get an “N.”

➢A best practice would be to run AMP600 for the year being certified, and the previous 2 years, to ensure data does not need to be re-certified by that May 1st date. If so, State should re-certify at that time, along with an explanation. This will ensure the full years of record are “certified” for DV purposes.


Data Certification Summary Points➢ Certification is not data validation. Validation occurs before data submitted to

AQS but certification may catch things missed during data validation

➢Suggest running quarterly reports to ensure no surprises in AMP600

➢Run AMP600 as soon as complete year of data reported to AQS. Don’t wait till April

➢AQS recommended “N” flags need thorough review and a good rationale if you want to reverse AQS recommended flag

➢Although a non-concurrence by EPA does not invalidate the data, data invalidation may be discussed. Good communication between certifying agency and EPA is necessary


Agency RolesAnalyzing Laboratory- Laboratory performing the analysis of samples

Certifying agency- a state, local, or tribal agency responsible for meeting the data certification requirements in accordance with §58.15 for a unique set of monitors. A certifying agency can certify monitor from multiple monitoring agencies or PQAOs.

Monitoring agency- a state, local or tribal agency responsible for meeting the requirements of this 40 CFR part 58

Primary quality assurance organization (PQAO) means a monitoring organization, a group of monitoring organizations or other organization that is responsible for a set of stations that monitor the same pollutant and for which data quality assessments can be pooled. Each criteria pollutant sampler/monitor at a monitoring station must be associated with only one PQAO.

Reporting organization a state, local, or tribal monitoring agency, that reports air quality data to the EPA.


Questions?Bob Judge

[email protected]

617-918-8387


mailto:[email protected]

Documents

Annual Air Monitoring Data Concurrence Certification and …€¦ · SLAMS and SPMs - that meet 40 CFR Part 58 Appendix A Includes CO, NO 2, SO 2 (hourly AND 5-min), O 3, Pb, PM 10,