Exhibit_1_GPMP_QAP_29Oct24.pdf

Gaseous Pollutant Monitoring Program Quality Assurance Project Plan (QAPP)

Prepared for the

NATIONAL PARK SERVICE

AIR RESOURCES DIVISION

12795 West Alameda Parkway

Denver, CO 80228

Revision 4 October 2020

Gaseous Pollutant Monitoring Program QAPP Section A

Revision 4

ACRONYMS AND ABBREVIATIONS

AQS Air Quality System (EPA) CASTNET Clean Air Status and Trends Network CD Compact Disc CFR Code of Federal Regulations

CI Checklist Instruction COR Contracting Officer’s Representative DCS Data Collection System DQI Data Quality Indicator DQO Data Quality Objective

EPA Environmental Protection Agency GPMP Gaseous Pollutant Monitoring Program IMC Information Management Center IMPROVE Interagency Monitoring of Protected Visual Environments IT Information Technology

MDN Mercury Deposition Network MOU Memorandum of Understanding NAAQS National Ambient Air Quality Standards NADP National Atmospheric Deposition Program NAMS National Air Monitoring Stations

NIST National Institute of Standards and Technology NPAP National Performance Audit Program (EPA) NPS ARD National Park Service Air Resources Division OAQPS Office of Air Quality Planning and Standards (EPA) PAMS Photochemical Assessment Monitoring Stations

PM2.5 Particulate Matter less than 2.5 Micrometers PSD Prevention of Significant Deterioration QA Quality Assurance QAPP Quality Assurance Project Plan

QC Quality Control QMP Quality Management Plan SLAMS State and Local Air Monitoring Stations SOP Standard Operating Procedure TI Technical Instruction TSA Technical Systems Audit

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A PROJECT MANAGEMENT

This section describes project management for the National Park Service Gaseous Pollutant Monitoring Program (NPS GPMP), including project history and objectives, roles and responsibilities of the participants, and document disposition. This section includes the following subsections:

A1 Title and Approval Sheet A2 Table of Contents A3 Distribution List A4 Project/Task Organization A5 Problem Definition and Background A6 Project Description and Schedule A7 Quality Objectives and Criteria for Measurement Data A8 Special Training Requirements/Certification A9 Documentation and Records

The following guidance has been used in the development of this Quality Assurance Project Plan (QAPP):

40 CFR 50, National Primary and Secondary Ambient Air Quality Standards

40 CFR 50, Appendix A-1. Reference Measurement Principle and Calibration Procedure for the Measurement of Sulfur Dioxide in the Atmosphere (Ultraviolet Fluorescence Method)

40 CFR 50, Appendix C. Measurement Principle and Calibration Procedure for the

Measurement of Carbon Monoxide in the Atmosphere (Non-Dispersive Infrared Photometry)

40 CFR 50, Appendix D. Measurement Principle and Calibration Procedure for the

Measurement of Ozone in the Atmosphere

40 CFR 50, Appendix F. Measurement Principle and Calibration Procedure for the

Measurement of Nitrogen Dioxide in the Atmosphere (Gas Phase Chemiluminescence)

40 CFR 50, Appendix L. Reference Method for the Determination of Fine Particulate

Matter as PM2.5 in the Atmosphere

40 CFR 53, Ambient Air Monitoring Reference and Equivalent Methods

40 CFR 58, Appendix A. Quality Assurance Requirements for Monitors Used in the

Evaluation of National Ambient Air Quality Standards

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40 CFR 58, Appendix C. Ambient Air Quality Monitoring Methodology

40 CFR 58, Appendix D. Network Design Criteria for Ambient Air Quality

Monitoring

40 CFR 58, Appendix E, Probe and Monitoring Path Siting Criteria for Ambient Air

Quality Monitoring

40 CFR 58, Appendix G. Uniform Air Quality Index (AQI) and Daily Reporting

EPA Quality Assurance Handbook for Air Pollution Measurement Systems:

- Volume I, A Field Guide to Environmental Quality Assurance (EPA/600/R-94/038a, April 1994)

- Volume II, Ambient Air Quality Monitoring Program (EPA-454/B-13-003, May 2013)

- Part 2.12 Monitoring PM2.5 in Ambient Air Using Designated Reference or Class I Equivalent Methods. (November 1998)

- Volume IV, Meteorological Measurements (EPA-454/B-08-002, March 2008)

EPA Meteorological Monitoring Guidance for Regulatory Modeling Applications

(EPA-454/R-99-005, February 2000).

EPA Guidance for Quality Assurance Project Plans (QAPPs) EPA QA/G-5

(EPA/240/R-02/009, December 2002).

EPA Guide to Writing Quality Assurance Project Plans for Ambient Air Monitoring Networks (EPA-454/B-18-006, August 2018).

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A2 TABLE OF CONTENTS

Section Page

A PROJECT MANAGEMENT 3

A1 Title and Approval Sheet 1 Acronyms and Abbreviations 2 A2 Table of Contents 5 A3 Distribution List 7 A4 Project/Task Organization 7 A5 Problem Definition and Background 8 A6 Project Description and Schedule 9 A6.1 Network Description 9 A6.2 Task Descriptions 10 A6.3 Schedule 13 A6.4 Reporting Requirements 13 A6.5 Resource Constraints 14 A7 Quality Objectives and Criteria for Measurement Data 14 A7.1 Data Quality Objectives 14 A7.2 Data Quality Indicators 14 A8 Special Training Requirements/Certification 15 A9 Documentation and Records 16

B MEASUREMENT/DATA ACQUISITION 1

B1 Sampling Process Design 1 B2 Sampling Methods Requirements 2 B3 Sample Handling and Custody Requirements 3 B4 Analytical Methods Requirements 4 B5 Quality Control Requirements 4 B5.1 Ozone Monitors 4 B5.2 Other Gaseous Monitors 5 B5.3 Particulate Monitors 6 B5.4 Meteorological Monitors 7 B6 Instrument/Equipment Testing, Inspection, 7 and Maintenance Requirements B6.1 Inspection and Acceptance Testing 7 B6.2 Maintenance of Measurement Systems 7 B6.3 Replacement Parts Inventory 8 B7 Instrument Calibration and Frequency 8 B8 Inspection/Acceptance Requirements 9 for Supplies and Consumables B9 Data Acquisition Requirements for Non-Direct Measurements 10 B10 Data Management 10

C ASSESSMENT/OVERSIGHT 1

C1 Assessments and Response Actions 1 C2 Reports to Management 2

D DATA VALIDATION AND USABILITY 1

D1 Data Review, Validation, and Verification Requirements 1 D2 Validation and Verification Methods 1 D3 Reconciliation with User Requirements 3

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A2 TABLE OF CONTENTS (continued)

REFERENCES

APPENDIX A – Standard Operating Procedures, Technical Instructions and Checklist Instructions

APPENDIX B – IMC New Site/Site Relocation Form

LIST OF TABLES

Table Page

1 Key Personnel and Responsibilities 1

2 Program Schedule 3

3 Program Site Specifications 4

4 Monitoring Sites and Parameters Measured 5

5 Ozone Monitoring Sites for Data Certification 6

6a Equipment and Measurement Methods – Ozone 7

6b Equipment and Measurement Methods – Other Gaseous Parameters 8

6c Equipment and Measurement Methods – Particulate Parameters 9

7 Equipment and Measurement Methods – Meteorological Parameters 10

8a Data Quality Objectives (Ozone) 12

8b Data Quality Objectives (Other) 12

9 Data Quality Indicators 13

10a Calibration and Acceptance Criteria – Ozone 15

10b Calibration and Acceptance Criteria – Other Gaseous Parameters 16

10c Calibration and Acceptance Criteria – Particulate Parameters 17

11 Calibration and Acceptance Criteria – Meteorological Parameters 19

12 Maintenance Procedures – Gaseous Instrumentation 20

13 Maintenance Procedures – Particulate Instrumentation 21

14 Maintenance Procedures – Meteorological Sensors 21

15 Maintenance Procedures – Data Acquisition Systems 22

16a Audit Ranges and Acceptance Criteria – Ozone 22

16b Audit Ranges and Acceptance Criteria – Other Gaseous Parameters 23

LIST OF FIGURES

Figure Page

1 Program Organizational Chart 1

2 Data Validation Flowchart 2

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A3 DISTRIBUTION LIST

The following individuals and/or organizations will receive copies of the approved Quality Assurance Project Plan and any subsequent revisions:

NPS park units with monitoring sites Park air quality supervisors NPS site operators

* Indicates individual who will maintain an official, approved QAPP.

The QAPP will also be distributed and available on the National Park Service Web site, at http://www.nature.nps.gov/air

. The QAPP will be reviewed at least annually, or at any time that major network changes are implemented, and updated as necessary.

A4 PROJECT/TASK ORGANIZATION

The U.S. Department of the Interior, National Park Service, established and manages the Gaseous Pollutant Monitoring Program (GPMP). ( is the prime contractor for this monitoring effort, the primary objective of which is to measure existing levels of air pollution in National Park Service (NPS) units. The principle components are the measurements of ozone and meteorological parameters representative of the ambient air quality in NPS units; however, other gases, particulates, deposition, and other air quality-related parameters are measured at specific sites throughout the network. A project organizational chart is provided as Figure 1 and responsibilities of the key project participants are listed in Table 1.

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A5 PROBLEM DEFINITION AND BACKGROUND

The primary objective of the Gaseous Pollutant Monitoring Program is to measure existing levels of air pollution in National Park Service units. This objective is mandated by the Clean Air Act of 1963 (including the 1970, 1977, and 1990 amendments) and the Organic Act of 1916, which assign the Federal Land Managers the responsibility of protecting the natural resources in national parks. Data on the concentrations of air pollutants in the parks are needed to support the permit review, biological effects, and research functions of the National Park Service Air Resources Division and to assist parks in evaluating their resource management needs.

Accordingly, the Air Resources Division (ARD) has established a network of stations to monitor ozone (O3) and meteorological conditions in a large number of parks, with additional monitoring of other gaseous pollutants including sulfur dioxide (SO2), carbon monoxide (CO), and oxides of nitrogen (NOx); and fine particulate matter (PM2.5) in selected parks. This QAPP specifically addresses these longer-term trend GPMP monitoring sites. Many of these sites are also designated as Clean Air Status and Trends Network (CASTNET) sites. The NPS and CASTNET have cooperated since the early 1990s to provide broader coverage of rural air quality, particularly in the western United States. Note that the NPS ARD also conducts shorter-term air quality monitoring including portable ozone and special studies monitoring in selected parks. In addition, ARD cooperates with other national and state programs that monitor ambient gases, meteorology, deposition chemistry, particulate matter, ultraviolet radiation, and visibility. The GPMP monitoring sites in each park are selected to represent the air within the park. Other monitoring objectives of the network are to:

Establish existing, or baseline, concentrations in NPS units;

Assess trends in air quality in NPS units;

Judge compliance with national air quality standards for ozone;

Assist in the development and revision of national and regional air pollution control policies for rural areas;

Provide data for national and regional pollution control policies;

Provide data for atmospheric model development and evaluation;

Provide data to primary national EPA data repositories and presentation media including AIRNow and the Air Quality System (AQS);

Cooperate with other national, regional, and state air monitoring and analysis programs related to park resource issues; and

Identify those air pollutants with the potential to injure or damage park biological resources, monitor these pollutants, and correlate measurable effects to these resources to existing ambient levels of these pollutants.

These objectives are the foundation of a network design in accordance with EPA regulations 40 CFR, Part 50, Appendix D (ozone) as well as Appendices A-1, C, F, J and L.

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Although addressing primarily health-effects based monitoring in areas of high population, these protocols are generally pertinent to the Gaseous Pollutant Monitoring Program.

A6 PROJECT DESCRIPTION AND SCHEDULE

A6.1 Network Description

The gaseous, particulate, and meteorological parameters measured by the NPS Gaseous Pollutant Monitoring Program are listed below. Nearly all sites collect meteorological parameters. Selected sites monitor other atmospheric gases and particulate matter concentrations.

Gaseous - Ozone, sulfur dioxide, carbon monoxide, and oxides of nitrogen data are collected and validated using documented protocols to yield a quality assured digital data set. Ozone is the primary pollutant measured throughout the network and is the only gas monitored specifically in accordance with EPA protocols and certified annually by the NPS to the EPA. This QAPP supports the certification of the ozone measurements conducted using EPA reference or equivalent methods. Note that the GPMP also collects ozone data using non-equivalent instrumentation at selected portable ozone monitoring (POMs) sites for air pollution screening purposes. In addition, sulfur dioxide, carbon monoxide, and oxides of nitrogen are monitored in selected park units primarily for research purposes, but may or may not meet EPA reference or equivalent methods. On occasion, selected data sets for these parameters may be submitted to the EPA by the NPS for certification. Table 4 presents collected parameters at each site, along with the sponsoring agency and pollutant certification status.

Particulate Matter - At selected park units, both EPA equivalent method and non-equivalent method monitors are used to measure fine particulates (PM2.5). Data are validated and reported as 1-hour concentrations.

Meteorology - Ambient temperature, relative humidity, wind speed, wind direction, precipitation, wetness, and solar radiation data are collected and validated using documented protocols to yield a quality assured digital data set.

This QAPP specifically addresses the procedures used by the NPS to operate and certify ozone measurements at NPS-operated sites with EPA-certified analyzers. Methods and procedures for measuring other pollutants of interest are included for informational purposes.

Table 3 lists the site specific location information and AQS site identification codes.

Table 4 presents all parameters monitored at each site, and Table 5 presents which parameters are certified in AQS annually. Note that the number and location of sites in all categories may change slightly from year to year.

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A6.2 Task Descriptions

Work performed for the program has been divided into six (6) tasks as detailed below:

1) Equipment Procurement and Inventory – Ambient air quality and meteorological instrumentation, data logging and communication systems, monitoring shelters, and support systems including towers are employed at the monitoring sites. is responsible for acquiring all necessary monitoring equipment. Equipment purchased for this project meet the following guidelines:

Compatible with network objectives and existing systems

Meets established acceptance criteria where appropriate, such as EPA equivalency

Proven durability and reliability

Cost-effective through all project phases

Upon receipt, equipment orders are verified for completeness and any inconsistencies are resolved with the supplier. Prior to installation in the field, equipment components are assembled in the air quality laboratory and tested to ensure proper operation. Instrumentation is calibrated using certified standards. A record of all purchased capital items is kept by and maintained in a site-specific equipment inventory database. All purchase, testing, calibration, and inventory procedures are documented in standard operating procedures (SOPs).

2) Site Selection and Installation – works closely in conjunction with the National Park Service to select appropriate monitoring sites and coordinate the installation of necessary utilities. Sites are generally located within NPS park units. Select sites are not located within or near park units, but operate under separate site-specific Quality Assurance Plans in cooperation with NPS and other federal or state agencies. See Table 4 for more information. These sites are selected to be:

Representative of the study area

Accessible and secure

Well-exposed to regional air flow

Isolated from nearby pollution sources

Available for long-term use

3) Network Operations – All routine on-site servicing operations are performed by NPS site operator(s) or contract site operator(s) on a weekly basis. Site operators receive training on equipment operation, maintenance, and data collection/documentation, including the use of DataView1, Operational SOPs, technical instructions (TIs), and checklist instructions (CIs).

collects data daily and reviews the operational status of the network daily, including data quality assurance indicators (zeros, spans, and precisions), provides site operator technical support, initiates corrective actions to address any identified inconsistency, and performs and tracks any

1 DataView – Internal proprietary software developed by to access site status logs and other site specific operations dedicated for the site operator(s) and field specialist.

Revision 4 required remedial maintenance on all program monitoring instrumentation and support equipment.

All semiannual maintenance and calibration activities are performed by field specialists at each site every six months. All transfer standards used to perform these verification checks are maintained, handled, stored and managed in a manner that maintains their integrity (i.e. certified annually and traceable to NIST). Following the initial verification checks, all systems receive required maintenance and are fully calibrated in accordance with EPA guidance, including fully documented and traceable multipoint calibrations of all gas analyzers. The calibrations are verified to ensure they meet network acceptance criteria and the as-left performance is documented.

4) Data Management and Reporting – A custom designed data collection system automatically retrieves air quality and meteorological data and system documentation from the monitoring systems by IP or satellite modem every hour. The data analysts and the field specialist (assigned technician-of-the-week) independently review the incoming data to verify proper operation of the monitoring systems. Suspected instrument malfunctions are investigated immediately and corrective actions are implemented. All network data are managed in an Oracle database (IMC database). The comprehensive database includes monitoring site metadata, raw data, validated data, associated validity codes, quality assurance references, and other important data. Reports and other data deliverables are generated from this database. All raw and validated data are archived in the IMC database and on CD. Additionally, data for the previous month is added to one of two external hard drives containing all historical data. The hard drive is provided to the GPMP Program Manager monthly. All validated data are also uploaded monthly to the EPA national Air Quality System (AQS) database and are made available on the NPS Data Request Web page. In addition, raw hourly gaseous, particulate, and meteorological data are automatically retrieved and uploaded to EPA’s AIRNow Web site. Raw data are also uploaded hourly on the NPS data request Web page for near real-time display.

5) Quality Assurance and Control – GPMP QA/QC procedures are used to assess the various components of the program and their compliance with the QAPP and referenced QA documents.

These project assessments include:

Quality Assurance/Quality Control documentation, prepared and maintained by includes but is not limited to: Quality Management Plan (QMP), Quality Assurance Project Plan (QAPP), Standard Operating Procedures (SOPs), Technical Instructions (TIs) and Checklist Instructions (CIs). also maintains all transfer standards and equipment used in semi-annual maintenance visits.

Quality Control Field Operations Assessments performed by Data (including automatic gaseous zeros, precisions, and spans) are reviewed each business day by to assess instrument operation at every site. Site operators visit the station once each week and complete the digital DataView documentation. If an operator notices a problem they immediately call and the problem is addressed and logged in the electronic Site Status Log. Corrective actions are instituted in response to any noted

Revision 4 problem. Supplemental training occurs during each semiannual field visit by as required.

Quality Control Data Management Assessments performed by Monthly plot reviews, attended by the GPMP program manager, and section managers serve as a monthly assessment of data management and validation procedures. During the plot reviews, data summaries of all gaseous and particulate data for each site, as well as weather summaries for the month are reviewed on a project-specific data review web site. A detailed discussion about network-related actions and plans follows the actual plot review.

Independent Field Performance Audits – It is a network goal to have independent performance audits performed on all network sites each calendar year. These audits will generally be performed by:

- State Agencies – Generally, units where ozone levels are near or above standards receive state independent audits as often as annually.

- CASTNET Program Auditor – All NPS sites that participate in the CASTNET program receive an independent audit by the CASTNET auditor annually.

- EPA National Performance Audit Program (NPAP) – The NPS GPMP sites are suitable for participation in the NPAP. Visits are periodically scheduled to perform a full independent performance audit, to be conducted at least once every five (5) years.

All of the independent audits noted above follow EPA performance audit protocols and apply traceable audit standards that yield consistent results. The results of all audits made available to the NPS are reviewed, filed, and incorporated into the validation process. All independent audit results are also entered into the EPA AQS as a quality assurance reference for network accuracy and to meet data certification requirements.

Technical Systems Audits (TSAs) – The NPS will work with EPA (either EPA

Regions or the Office of Air Quality Planning and Standards (OAQPS)) to ensure that the GPMP receives an independent TSA a minimum of every three years.

6) Program Management and Administration – Overall program coordination is provided by the GPMP program manager who communicates directly with management staff. Monthly meetings in conjunction with the plot review establish and define near and long-term project objectives and actions. Day-to-day coordination of overall project management and reporting requirements are performed by the network operations section manager, IMC manager, and program manager. Weekly e-mail progress reports are sent to the GPMP program manager, Research and Monitoring Branch Chief, and staff. Monthly data reports, twice-annual contract status reports, and annual data reports are sent to the GPMP program manager and Research and Monitoring Brach Chief, the program manager, the network operations section

Revision 4 manager, the IMC manager, site operators, and park air quality supervisors. In addition, each of these reports, along with a variety of other network documentation, is posted on the GPMP project Web site.

Coordination with the CASTNET program occurs annually at the CASTNET Summit Meeting and in monthly conference calls or otherwise as needed. Coordination with cooperating agencies is performed as needed by telephone, e-mail, or written communications. In addition, all validated NPS data collected at CASTNET-configured sites are sent monthly by to the CASTNET contractor.

All contract administration between the NPS and is performed by the NPS Contracting Office. The NPS Contracting Office also coordinates memorandums of understanding (MOUs) with cooperating agencies and distributes funding to individual parks for site operations.

A6.3 Schedule

The Gaseous Pollutant Monitoring Program schedule is presented in Table 2.

A6.4 Reporting Requirements

Reporting requirements for the program are summarized in the project schedule in Table 2. In general, reporting products include:

Hourly Data Uploads to AIRNow

Status Log Updates as Needed

Weekly Progress Reports

Data Reports (monthly and annual)

Monthly Data Uploads to AQS

Monthly Ozone Exceedance Tables

Monthly CASTNET Data Uploads

Quarterly Precision and Accuracy Uploads to AQS

Annual Network Performance Summary Report

Annual Data Summary Tables and Maps

Twice-Annual Contract Status Reports

Site Visit Reports

Quality Assurance Documentation

Data Archives

Annual AQS Ozone Data Certification Packet

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A6.5 Resource Constraints

The NPS Air Resources Division is the principal source of funding for this network.

Limited additional funding is occasionally available from individual parks for special projects.

The NPS ARD provides funding directly to park units to support site operators. is the prime contractor for the monitoring program. An interagency agreement exists between NPS and EPA related to the CASTNET components of the monitoring program. Agreements with state agencies generally consist of memorandums of understanding with no direct exchange of funding. The program budget is developed yearly by NPS ARD and is dependent on agency funding levels and priorities. In addition, the NPS cooperates with state agencies to both operate additional in-park monitoring sites and to perform independent audits at selected sites.

A7 QUALITY OBJECTIVES AND CRITERIA FOR MEASUREMENT DATA

A7.1 Data Quality Objectives

The GPMP data quality objectives (DQOs) are comprised of quantitative and qualitative statements that define performance measures and goals to ensure that the type, quantity, and quality of collected data meet the objectives of the network, as specified in Section A5. The DQOs specify that the highest quality defensible data be available from NPS park units to support air quality related decisions and policies of the National Park Service. The GPMP DQOs are summarized in Tables 8a through 8b.

The valid data recovery objective for the GPMP is 75% per calendar quarter for all parameters. Measurement uncertainty is controlled through daily data reviews, weekly operator visits, semi-annual calibration and maintenance, and monthly data validation. Achieving a 75% collection objective allows users to be confident when comparing collected data to other, nearby monitoring stations which use the same instrumentation and same data validation procedures, for the same period of time. Collected data are representative of local conditions in the area, as documented on the IMC New Site/Site Relocation Form provided in Appendix B.

A7.2 Data Quality Indicators

Data quality indicators (DQIs) describe the general framework for ensuring that network data are of known and documented quality and available in a timely manner to meet the DQOs.

These indicators are discussed below. The DQIs specific to the GPMP are detailed in Table 9.

Zero and Span All gas analyzers are automatically subjected to a zero and span sequence to provide routine checks on instrument performance. Pollutant-free zero air generated by an on-site zero air system establishes the zero point. The span value is generated by the gas dilution system using EPA-protocol gas cylinders or use of an ozone transfer standard.

Precision Precision is a measure of mutual agreement among individual measurements of the same property usually under prescribed similar conditions. Precision is an estimate by various

Revision 4 statistical techniques calculated as either the range or as the standard deviation. This calculation is performed on aggregated 1-point QC checks, which are performed in a similar manner to span checks.

Bias Bias is the systematic or persistent distortion of a measurement process which causes error in one direction. Bias will be determined by estimating the positive and negative deviation from the true value as a percentage of the true value. This calculation is performed on aggregated 1-point QC checks, which are performed in a similar manner to span checks.

Detection Limit The detection limit is the determination of the low range critical value of a characteristic that method specific procedures can reliably discern.

Representativeness The representativeness of measurements is the degree in which data accurately and precisely represents a characteristic of a population, parameter variation at a sampling point, a process condition, or an environmental condition.

Completeness Completeness is a measure of the amount of valid data obtained from a measurement system compared to the amount that was expected to be obtained under correct, normal conditions.

Comparability Comparability is a measure of confidence with which one data set can be compared to another.

The GPMP DQIs for precision, bias, accuracy and completeness are detailed in Table 9.

Representativeness is determined qualitatively by siting and exposure conditions of the monitoring site(s) described in Section B1, and in consultation with The National Park Service.

Comparability and detection limit objectives are achieved by using USEPA-approved methods and equivalent method instrumentation (detailed in the Standard Operating Procedures listed in Appendix A) and by following USEPA monitoring guidance as described in this QAPP.

Appropriate calibration and validation levels for the air quality and meteorological instrumentation, as well as EPA acceptance criteria, are listed in Tables 10 through 11.

A8 SPECIAL TRAINING REQUIREMENTS/CERTIFICATION

staff members working on this project are experienced in ambient air quality and meteorological monitoring systems. Members of the Information Management Center (IMC) hold at least a Bachelor’s degree from an accredited university in a physical science, mathematics or engineering discipline. IMC data analysts are trained on all data collection, Revision 4 validation, and reporting software tools used in data management as part of their routine job duties.

field specialists also hold at least a Bachelor’s degree from an accredited university in a physical science, mathematics or engineering discipline. Field specialists are trained on all maintenance, calibration and troubleshooting responsibilities specific to equipment and procedures utilized for this project. Field specialists are required to undergo annual tower training and maintain current First Aid and CPR certifications. Junior field staff are trained by senior field staff on routine operations. Field technicians must also complete Air Pollution Training Institute on-line courses (https://www.apti-learn.net/LMS/EPAHomePage.aspx.). This training is documented in the Field Technician Technical Training Checklist and kept in the employee files.

Site operators are trained by field specialists on routine maintenance and troubleshooting procedures during site initialization and during quarterly maintenance visits. All instrumentation and support equipment function is thoroughly explained and all required site operator procedures are discussed, as detailed in the on-site quality assurance documents (QAPP, SOPs, TIs, and CIs). Site operators are encouraged to ask questions during these training sessions, and are advised to call anytime a question or problem arises that needs solving or clarification.

A9 DOCUMENTATION AND RECORDS

All hardcopy records, digital data, DataView documentation, and other documents for the current and previous monitoring years reside in the IMC database and archive files. The current and most recent past year of hard copy records are housed in the IMC. The preceding five years of hardcopy records are housed in an off-site storage facility. The GPMP program manager has the final authority for the storage, access to, and final disposition of all data and records. The following types of documentation and records are used in the program:

Field documentation, including DataView documentation files, log sheets, daily summaries, audit results, calibration results, quality control checks, records of procedures and maintenance performed, and site equipment inventories.

- DataView documentation files are archived in the project database and used for operational checks and data validation. Files are archived with network data.

- Manual site documentation including manual log sheets and hard copies of independent audit results are filed by site and archived annually.

- Documentation of corrective action reports including problem identification and resolution is recorded by site and time in the network Site Status Log, a computer record of network operations. Manual notes, plots, data listings, written operator correspondence, and other hard copy products associated with problem resolution are filed by site.

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- Equipment inventory is tracked in the GPMP Equipment Inventory Database. The inventory is checked and updated after each semiannual visit. Inventory reports are submitted to the GPMP program manager twice annually. The database can also yield reports on demand.

- Standards certification documentation for all calibration systems are maintained in hardcopy files, organized by instrument type, in the IMC.

Project data (raw and validated) resides in the IMC database and is available for use during the life of the project. The database also tracks all actions performed on all data and assigns validation level codes and action codes to all entries. The database contains a series of validation screens which allow the data analyst to code validation levels, apply corrections, or invalidate data. For example, if the database must be supplemented by digital or manual entry of data from a non-network source, the data are entered, time-tagged, and coded appropriately. All actions are logged and coded to ensure a traceable, reproducible path back to the raw data files. All raw data are also kept independently in the database. All raw and validated data are automatically backed up nightly and raw and validated data are archived quarterly on CD, and delivered to the National Park Service Air Resources Division, and stored on- and off-site at The NPS ARD has the ultimate responsibility for ensuring the security of all data. Raw and validated data are uploaded hourly and monthly respectively to the NPS Data Request Web site .

Additionally, data for the previous month is added to one of two external hard drives containing all historical data. The hard drive is provided to the GPMP Program Manager monthly. Final validated data are also uploaded monthly to the EPA AQS database for public access and archive and to the CASTNET contractor for use in the deposition model.

Weekly project status reports are brief, written weekly reports that summarize network status, actions, and reports that occurred during the previous week and are planned to the current week. The report is e-mailed to the GPMP program manager, Research and Monitoring Branch Chief, QA manager, and all staff participating in the project. The report references network products and Web sites where additional information is available.

A project Web site is maintained as a communication tool among project participants

. The Web site includes copies of project schedules, project reports, contact information, and other documentation.

Twice-Annual Contract Status Reports are generated to document the history of contract task orders and modifications and delivered to the GPMP program manager and network quality assurance manager. No technical information is included in these reports.

The Monitoring History Database contains the metadata for all NPS units over time.

The metadata includes site names, abbreviations, AQS codes, coordinates, elevations, Revision 4 monitoring start and stop times, monitored parameters, responsible agencies, and other pertinent information. The database is reviewed and updated twice annually (spring and fall). The contents are accessible through the GPMP Data Request Web site.

Monthly and annual data reports summarize the validated data and network performance criteria. Monthly reports only include data from NPS-operated sites.

Annual reports include data summaries from NPS and cooperating agency sites.

Monthly and annual data reports are provided according to the schedule defined in Table 2.

Ozone exceedance tables are generated monthly during the period from April through October and forwarded to NPS ARD for public display on the NPS Web site.

An Annual Operational Performance Summary Report is generated each year to summarize how the network performed as compared to overall network performance goals.

Project-related standard operating procedures, technical instructions, and checklist instructions are controlled documents that are maintained in the Quality Assurance Documentation Library. A copy of the documents is maintained at each monitoring site (in both hardcopy and digitally on DataView). This Quality Assurance Project Plan (QAPP) and the Quality Management Plan (QMP) are also controlled documents. The quality assurance manager is responsible for keeping the document current and maintaining a distribution list (see Section A3). Parties on the distribution list receive updated versions of the plan as they are made.

Section B

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B MEASUREMENT/DATA ACQUISITION

This section describes the project design and implementation, including collecting, handling, analyzing, managing, and validating the data. This section includes the following subsections:

B1 Sampling Process Design B2 Sampling Methods Requirements B3 Sample Handling and Custody Requirements B4 Analytical Methods Requirements B5 Quality Control Requirements B6 Instrument/Equipment Testing, Inspection, and Maintenance Requirements B7 Instrument Calibration and Frequency B8 Inspection/Acceptance Requirements for Supplies and Consumables B9 Data Acquisition Requirements for Non-Direct Measurements B10 Data Management

B1 SAMPLING PROCESS DESIGN

The sampling procedures have been designed according to National Park Service Gaseous Pollutant Monitoring Program protocols for gaseous, particulate, and meteorological monitoring. The sampling frequencies and instrumentation are described in Tables 6 through 7.

The program is designed to collect gaseous, particulate, and meteorological data in selected national park units throughout the United States, including Alaska and Hawaii.

The NPS ARD has the ultimate responsibility for selecting which national parks receive monitoring stations and specifying what will be monitored within the selected parks. This selection process, however, involves cooperation among the NPS ARD, park units, and cooperating agencies, to consider:

1) Clean Air Act designation of park units

2) Existing air quality conditions

3) Potential for changes in air quality

4) Ecological region representativeness

5) Park/state/regional priorities

6) Park special designations

7) Participation in other NPS research programs

8) Other monitoring networks

These considerations are also influenced by funding levels, logistics, technology, and other factors.

This strategy and the resulting monitoring program has evolved over the years and the current configuration and direction is presented on the NPS Web site (http://www.nature.nps.gov/air/monitoring/). The network objectives, design, and current configuration of the ozone and meteorology components are described on the Web site. The

Revision 4 overall guidance for network design is to collect data throughout the U.S. to serve as the primary source of air quality information to guide NPS air resource management decisions.

Selection of a site or sites within a park unit must address EPA siting criteria and park-specific considerations. The primary guidance for siting and monitoring systems is to adhere to 40 CFR Part 58 Appendix E requirements, and follow SOP F_SITING_AQSITE_F_1.0, Siting an Ambient Air Quality Monitoring Station. This is generally possible, but some sites present challenges resulting from power availability, resource impacts, site access, logistics, and other considerations, particularly in heavily vegetated park units with rugged terrain. All GPMP regulatory sites currently meet the EPA siting criteria, unless a special case waiver has been granted.

The monitoring sites selected within park units are considered to be representative of overall park air quality. This can pose certain challenges in park units that have multiple ecozones and extend across several air basins. In general, funding levels restrict most park units to one monitoring site, which is chosen to be most representative of the unit. However, some of the larger park units, those with sensitive resources requiring additional information, or those needing to support broader research programs may operate more than one station.

B2 SAMPLING METHODS REQUIREMENTS

Sampling methods for gaseous, particulate, and meteorological monitoring, based on 40 CFR Part 58 Appendix E requirements, are fully detailed in the network SOPs, TIs, and CIs. The primary parameters monitored and sampling methods applied are:

Gaseous – Ozone data are collected at nearly all GPMP sites and are certified in the EPA’s AQS.

Other gaseous data including sulfur dioxide, carbon monoxide, and oxides of nitrogen are collected at a limited number of sites to support NPS research. These data may or may not be collected to meet EPA primary or equivalent protocols and are generally not certified by the NPS in AQS. Ozone and other gaseous data are collected hourly via IP or satellite modem from the on-site datalogger. Data from site-specific raw data files are uploaded and stored in the IMC database. If communications service is not available, data are manually downloaded weekly via the on-site laptop computer using DataView and transferred to Raw data stored on the datalogger and in the database include hourly and 1-minute averages for gaseous parameters.

Although in some cases, 5-minute, or 15-minute data are collected and stored in the database along with hourly averages.

Particulate Matter – Continuous particulate data are collected at selected GPMP sites using a range of instrumentation. These data generally include hourly average concentrations of PM2.5 which are further compiled into 24-hour averages. These data may or may not be collected to meet EPA equivalent protocols and are generally not certified by NPS in AQS. Data are stored in site-specific daily raw data files are uploaded and stored in the IMC database. If communications service is not available, data are manually downloaded weekly from the instrument’s memory or DataView files and forwarded to Data are retrieved hourly via IP or satellite modem.

Speciated aerosol samples collected from the CASTNET filter packs are analyzed and reported by the CASTNET program. Flow data from the 7-day integrated samples are collected and

Revision 4 validated under the GPMP program, and validated data files are provided to the analytical laboratory for use in aerosol concentrations calculations.

Meteorology - Meteorological data are retrieved hourly via IP or satellite modem from the on-site datalogger. Data are stored in site-specific daily raw data files are uploaded and stored in the IMC database. If communications service is not available, data are manually downloaded weekly from the on-site laptop using DataView and transferred to Raw data can include ambient temperature (ºC), ambient relative humidity (%), scalar wind speed (m/s), vector wind speed (m/s), wind direction (º), standard deviation of wind direction (º), precipitation (mm/hr), solar radiation (W/m2), and/or barometric pressure (mmHg). Raw data stored on the datalogger and in the database are hourly averages.

DataView stores one-minute and hourly gaseous and hourly meteorological and particulate data raw data for up to 90 days. These data can be accessed remotely to support site troubleshooting and data validation decisions.

In the event of prolonged communication failure at a site, the operator (upon direction from the IMC) can download all digital hourly average raw data from the DataView computer to an external storage device. The DataView computer can store 90 days or more of hourly average data. DataView continuously backs up the datalogger. The operator can periodically (generally weekly) transfer the data files to the IMC for processing. If there is a prolonged power outage at the site, the operator can ship the DataView laptop computer to the IMC for data retrieval up to the time of the power outage. A backup laptop is shipped to the site in exchange.

Note that the NPS also participates in the AIRNow program which requires hourly raw data uploads, displays and provides hourly raw data from a number of the GPMP sites on the NPS Web site, and allows selected users to access hourly data via an FTP site. Once data collection is complete, an automated process creates a file of the most recent data for transfer to AIRNow. This process occurs every hour and is a part of the automated data collection process.

Any proposed changes to sampling procedures are thoroughly reviewed and tested. If approved by the GPMP program manager, procedural changes are made to the appropriate quality assurance references, SOP, TI, and CI. field specialists are trained in the new procedure. Hardware, datalogger programs, DataView programs, data management programs, and other required changes are made. Network-wide implementation of field-related procedural changes primarily occur in two ways:

1) Implementation and operator training during semiannual site visits.

2) Direct communication and telephone training of each site operator by

Centralized data management of field specialist-related procedures are implemented when all staff are trained and the procedural change is technically ready to be implemented and approved by the GPMP program manager.

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B3 SAMPLE HANDLING AND CUSTODY REQUIREMENTS

All sample handling is performed automatically via IP or satellite modem from the on-site datalogger to Data files are backed up each business day and are stored at each Friday tape is stored off-site in a fireproof vault. Data are also stored on the on-site computer for 90 days, and may be retrieved via cellular modem or written to a USB flash drive. These methods are discussed in SOP “I_IMC_DATACOLL_F_1.0”, Information Management Center – Data Collection.

Handling and custody of CASTNET filters, NADP, MDN, IMPROVE, or other media collocated at GPMP sites are addressed in independent, project-specific QAPPs and SOPs.

B4 ANALYTICAL METHODS REQUIREMENTS

There are no analytical laboratory methods applied in the GPMP. Laboratory methods of CASTNET filters, NADP, MDN, IMPROVE, or other samples collocated at GPMP sites are addressed in independent, project-specific QAPPs and SOPs.

B5 QUALITY CONTROL REQUIREMENTS

Quality control requirements for data collected at GPMP sites are discussed below. Site operator visits are scheduled to occur on a weekly basis for routine operations. Tables 10a through 10c present data validation and action level criteria for each monitored parameter.

Action level criteria are generally set lower than validation criteria to indicate when an instrument may require recalibration or other maintenance before the loss of data occurs. Quality control checks are performed according to the instrument manufacturer’s recommendations.

B5.1 Ozone Monitors

Verification and Calibration of Ozone Systems Calibration of the ozone analyzers will be performed upon initial installation and during routine calibrations visits according to the schedule presented in Table 2. Additional calibrations will be performed on an as-needed basis, such as in the event of equipment repair or replacement.

Calibrations will be performed in accordance with manufacturer’s recommendations and consistent with USEPA guidance. The calibration method and acceptance criteria for ozone are summarized in Table 10a. In general, action level criteria are set to one-half the acceptance criteria listed in Table 10a.

The ambient analyzer and Level 3 station reference photometer are checked against a Level 2 transfer standard twice-annually for CASTNET sites. The Level 2 standard is certified annually against the NIST standard reference photometer at EPA’s RTP laboratories.

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The ozone analyzer and Level 3 station reference photometer are verified by using five test concentrations and the zero value. A calibration on the ozone analyzer and station reference is then performed (if warranted) at the 0 and 80% of full-scale levels, followed by another multi-point verification check.

Certification of the Level 2 transfer standards occurs annually at EPA laboratories.

Routine calibration verification checks on the Level 2 transfer standards are performed in the laboratory to verify the instruments continue to operate within expected limits. The process involves a six-point verification check (1-by-6 calibration verification). If certification is unsuccessful, the instrument undergoes troubleshooting, corrective action, and the certification process is repeated.

Calibration of the 2B ozone analyzer used at the Portable Ozone Monitoring Systems (POMS) is performed at the laboratory prior to deployment. Site verification visits are performed in a similar fashion to standard sites, without the presence of a station reference. The on-site ambient analyzer is verified using the Level 2 transfer standard. If the instrument does not meet acceptance criteria in the field it is replaced with a recently serviced unit.

Performance Audits Independent network performance assessments are performed by cooperating air quality agencies, (including state agencies or local air quality districts, who perform annual independent field performance audits), or the CASTNET auditor. Audit equipment and reference standards are provided by the auditor and will be traceable to NIST standards. Audit acceptance criteria are summarized in Table 10a. Audit procedures and techniques follow established EPA audit guidelines. Audit challenge ranges and acceptable criteria for the analyzers are presented in Table 16a.