Ozone_QAPP_FINAL.pdf

DEQ-AQD QAPP for Ozone Revision 4.0, November 2025

Title Page

Wyoming Department of Environmental Quality – Air Quality Division

Quality Assurance Project Plan for the

Ozone Ambient Air Monitoring Program

November 2025

Revision 4

Section 1

Section A. Project Management

1.0 Quality Assurance Project Plan Identification and Approval

Title: Wyoming Department of Environmental Quality, Air Quality Division (WDEQ-AQD) Quality Assurance Project Plan (QAPP) for the Ozone Ambient Air Monitoring Program.

This QAPP for the Ozone Ambient Air Quality Monitoring Program is hereby recommended for approval and commitment from the Department to follow the elements described within.

Wyoming Department of Environmental Quality, Air Quality Division

Air Pollution Monitoring Program Supervisor, Leif O. Paulson Date

Quality Assurance Coordinator, Ty Hysell Date

Air Pollution Monitoring Program Manager, Mark R. Gagen Date

11/24/2025

11/26/2025

11/24/2025

Section 2

2.0 Table of Contents

Section A. Project Management

1.0 Quality Assurance Project Plan Identification and Approval

2.0 Table of Contents

List of Tables

List of Figures

Acronyms

3.0 Distribution List

4.0 Project/Task Organization

4.1 Air Pollution Monitoring Program Manager

4.2 Air Pollution Monitoring Program Supervisor

4.3 Quality Assurance Coordinator

4.4 Project Managers

4.5 Monitoring Specialists

4.6 Site Operator

4.7 Data Manager

5.0 Problem Definition/Background

5.1 Supporting Documentation

6.0 Project Task Description

6.1 Ozone Measurements

6.2 Sampling Frequency

6.3 Project Schedule

6.4 Project Reports

7.0 Quality Objectives and Criteria for Measurement of Data

7.1 The DQO Process

7.2 Data Quality Indicators

7.3 Representativeness of the Ozone Measurements

8.0 Special Training/Certifications

9.0 Documents and Records

Section B. Data Generation and Acquisition

10.0 Network Description

11.0 Sampling Method

11.1 Ozone Analyzers

11.2 Support Monitoring Equipment

11.3 Data Acquisition System

11.4 Telecommunications

11.5 Climate-Controlled Shelter

11.6 Zero Air System

11.7 Multi-Gas Dilution Calibrator

11.8 Standard Operating Procedures

Section 2

12.0 Sample Handling and Custody

13.0 Analytical Method

14.0 Quality Control Requirements

14.1 Instrument/Equipment Calibration and Frequency

14.2 Visual Inspection of Equipment

14.3 Remote Interrogation of Monitoring Station and Inspection of Data

14.4 Equipment Calibration

14.5 Calibration Reference Standard Certification

14.6 Zero and Span Checks

14.7 One-Point QC Checks

15.0 Equipment Maintenance

16.0 Instrument Equipment Testing and Inspection

16.1 Acceptance Testing of Instrumentation and Equipment Integration

16.2 Site Surveillance and System Check Procedures

16.3 Site and Equipment Maintenance

17.0 Inspection/Acceptance of Supplies and Consumables

17.1 Spare Parts

17.2 Inspection/Acceptance of Supplies and Consumables

18.0 Non-Direct Measurements

19.0 Data Management

19.1 Data Retrieval

19.2 Raw Data

19.3 Data Transfer

19.4 DAS Data Review

19.5 Data Validation

19.6 Data Transmittal

19.7 Data Processing

19.8 Data Analyses

19.9 Data Flagging

19.10 Data Submittal to the AQS

Section C. Assessment and Oversight

20.0 Assessment and Response Actions

20.1 Data Quality Audits

20.2 Corrective Actions

20.3 QAPP Revisions

21.0 Reports to Management

Section D. Data Validation and Usability

22.0 Data Review, Validation, and Verification Requirements

22.1 Data Acceptance Limits for Ozone

23.0 Data Validation and Verification Methods

23.1 Level 0 Data Validation

Section 2

23.2 Quality Control Checks for Data Validation

23.3 Level 1 Data Validation

23.4 Minimum Acceptable Data Recovery Percentage

23.5 Data Report QA Checklist

24.0 Reconciliation with User Requirements

References

APPENDIX A: Standard Operating Procedures for Ozone Analyzers

Appendix A.1: Standard Operating Procedure for Ozone Analyzers

Appendix A.2 - Standard Operating Procedure For Performance Evaluations of Gaseous Analyzers

APPENDIX B: Ancillary Information

APPENDIX C: Revision Summary

Section 2

List of Tables

Table 1. QAPP Distribution List Table 2. Project Reports Table 3. DQO Seven-Step Decision Tree Process Table 4. Documentation and Reports Table 5. Ozone Analyzer QC Procedures Table 6. Critical Criteria for Ozone Analyzers Table 7. Operational Criteria for Ozone Analyzers Table 8. Systematic Criteria for Ozone Analyzers Table 9. Systematic Criteria for Ozone Support Equipment Table 10. Site Maintenance Activities Table 11. Equipment Maintenance Activities Table 12. Ozone Audit Levels Table 13. Reports to Management Table 14. Data Flags

List of Figures

Figure 1. WDEQ-AQD Organizational Chart Figure 2. WDEQ-AQD Ozone Monitoring Site Locations, 2004-2025 Figure 3. Configuration of Monitoring Equipment in the Instrument Rack

Section 2

Acronyms

AGL Above Ground Level AMTIC Ambient Monitoring Technology Information Center APE Annual Performance Evaluations APMP Air Pollution Monitoring Program APTI Air Pollution Training Institute AQD Wyoming Air Quality Division AQS Air Quality System

ASQ American Society for Quality AWMA Air & Waste Management Association CFR Code of Federal Regulations

DAS Data Acquisition System DQIs Data Quality Indicators DQOs Data Quality Objectives E-log Electronic Logbook EPA U.S. Environmental Protection Agency FEM Federal Equivalent Method HVAC Heating, Ventilation, and Air Conditioning IMPACT Inventory, Monitoring, Permitting, And Compliance Tracking system IMS Industrial Monitoring Stations

MFC Mass Flow Calibrator MQOs Measurement Quality Objectives NAAQS National Ambient Air Quality Standards NPAP National Performance Audit Program NIST National Institute of Standards and Technology NCore National Core Air Measurement Network O3 Ozone OAQPS Office of Air Quality Planning and Standards ORD Office of Research and Development PEs Performance Evaluations PEP Performance Evaluation Program PFA Perfluoroalkoxy alkane PQAO Primary Quality Assurance Organization PTFE Polytetrafluoroethylene QA Quality Assurance QAPP Quality Assurance Project Plan QC Quality Control QMP Quality Management Plan SLAMS State and Local Air Monitoring Stations SLT State/Local/Tribal SOP Standard Operating Procedure SPMS Special Purpose Monitoring Stations SRP Standard Reference Photometer TAD Technical Assistance Document TTP Through-the-Probe UV Ultraviolet WAAQS Wyoming Ambient Air Quality Standards WDEQ Wyoming Department of Environmental Quality

Section 3

3.0 Distribution List

The following individuals listed in Table 1 have been provided a copy of this Quality Assurance Project Plan (QAPP).

Table 1. QAPP Distribution List

Wyoming Department of Environmental Quality, Air Quality Division

Name Position

Amber Potts Administrator

Mark Gagen Air Pollution Monitoring Program Manager

Leif Paulson Air Pollution Monitoring Program Supervisor

Ty Hysell Quality Assurance Coordinator

Jacob Berreth CEMS/SLAMS Coordinator

Lauren Deverse Exceptional Events Analyst/Project Manager

Ardyss Thai Data Manager

Jack Kokkinen Project Manager

Grayson Rotter Project Manager

Jackson Sansone Project Manager

Paul Bailey Monitoring Specialist

Trevor Hale Monitoring Specialist

EPA Region VIII

Name Position

Joshua Rickard Wyoming Monitoring Contact

YeChan Lim Supervisor, Monitoring and Program Support Section

Section 4

4.0 Project/Task Organization

Since the early 1970s, the Air Pollution Monitoring Program (APMP) has been committed to monitoring the air quality of Wyoming to protect, conserve, and enhancing the quality of Wyoming’s environment for the benefit of current and future generations. The APMP provides the WDEQ-AQD with valuable information that allows for determination of future policy considerations.

The WDEQ-AQD plans, operates, and maintains a number of different types of ambient monitoring stations, including National Core (NCore), State and Local Air Monitoring Stations (SLAMS), Special Purpose Monitoring Stations (SPMS), Interagency Monitoring of Protected Visual Environment (IMPROVE) monitoring stations, and Industrial Monitoring Stations (IMS).

The SLAMS are sited in populated areas to monitor public health and demonstrate compliance with the National Ambient Air Quality Standards (NAAQS) but may serve other purposes, such as:

• Providing air pollution data to the general public in a timely manner

• Supporting compliance with air quality standards and emissions strategy development

• Supporting air pollution research studies

The SPMs have multiple collective objectives. These objectives include:

• Providing air pollution data to the general public in a timely manner

• Monitoring public health

• Investigating pollutant concentrations downwind of sources

• Determining background pollutant concentrations

Since 2011, the WDEQ-AQD has operated a fleet of mobile monitoring stations (“mobile stations”) to investigate questions or concerns about air quality on a short-term basis (typically one year).

Additionally, the WDEQ-AQD administers an NCore station as part of the national network to evaluate long-term trends in air quality. The IMS are independently operated stations that meet the requirements of their permits. Although WDEQ-AQD has oversight authority for the permit-required monitoring networks, the IMS operate as independent Primary Quality Assurance Organizations (PQAOs).

The WDEQ-AQD is committed to the quality and the implementation of the procedures and practices found in this QAPP. Quality assurance (QA) is an integrated system of management activities involving planning, implementation, assessment, reporting, and quality improvement to ensure that a process, item, or service is of the type and quality needed and as expected. Quality control (QC) is the overall system of technical activities that measures the attributes and performance of a process, item, or service against defined standards to verify that they meet the stated requirements established by the customer. The QC system includes the operational techniques and activities that are used to fulfill requirements for quality.

Quality control is largely implemented through the QAPP and the standard operating procedures (SOPs).

Each instrument in the various monitoring programs has unique requirements, statutory standards, and support equipment that must be in place in order for the instrumentation to be operated according to the guidelines, rules, and policies that must be followed. This QAPP incorporates the unique qualities that are specific to ozone within the WDEQ-AQD monitoring network.

Implementation of the WDEQ-AQD monitoring program requires an investment by the entire

Section 4 management team all the way to the Air Pollution Monitoring Program Manager. WDEQ-AQD management recognizes and accepts this responsibility to identify the QA requirements that will meet the needs and expectations of the monitoring program. Any worthwhile monitoring program focuses on preventing quality problems.

Since the WDEQ has an overarching Quality Management Plan (QMP) in place, this and all QAPPs will be mandated by the WDEQ QMP. The QMP describes the quality system in terms of the organizational structure, functional responsibilities of management and staff, lines of authority, and required interfaces for those planning, implementing, assessing, and reporting activities involving environmental data operations.

The following subsections describe the project participants and the roles and responsibilities of each participant. Figure 1, which is in the last portion of this section, illustrates that management structure.

4.1 Air Pollution Monitoring Program Manager

The APMP Manager has overall responsibility for managing the AQD according to WDEQ-AQD policy.

The direct responsibility for assuring data quality rests with line management. Ultimately, the APMP Manager is responsible for establishing QA policy and for resolving QA issues identified through the QA program.

Major QA related responsibilities of the APMP Manager include:

● Participating in the budget and planning processes.

● Assuring that the WDEQ-AQD develops and maintains a current and germane quality system.

● Assuring that the WDEQ-AQD develops and maintains current QAPPs.

● Assuring adherence to the QA documents by staff and, where appropriate, other extramural cooperators establishing policies to ensure that QA requirements are incorporated in all environmental data operations.

● Maintaining an active line of communication with the Monitoring Supervisor, QA Coordinator, and Project Managers conducting management systems reviews.

The WDEQ-AQD APMP Manager delegates the responsibility of QA development and implementation in accordance with WDEQ-AQD policies. Oversight of the WDEQ-AQD's QA program is delegated to the Quality Assurance Coordinator.

4.2 Air Pollution Monitoring Program Supervisor

The APMP Supervisor is the delegated manager of the routine monitoring programs, which includes the QA/QC activities that are implemented as part of normal data collection activities.

Responsibilities of the Monitoring Supervisor include:

● Communicating with EPA Project Officers and QA Personnel regarding sampling and quality assurance activities.

● Understanding EPA monitoring and QA regulations and guidance to ensure subordinates understand and follow the regulations and guidance.

● Understanding the WDEQ-AQD's QA policy and ensuring subordinates do as well.

● Understanding and ensuring adherence to the QAPP.

Section 4

● Reviewing acquisition packages (contracts, grants, cooperative agreements, and interagency agreements) to determine the necessary QA requirements.

● Developing budgets and providing program costs necessary for EPA allocation activities.

● Ensuring that all personnel involved in environmental data collection have access to any training or QA information needed to be knowledgeable in QA requirements, protocols, and technology.

● Certifying to EPA that data are true, correct, and reported to EPA per Title 40 Code of Federal

Regulations (CFR) Part 58.151.

4.3 Quality Assurance Coordinator

The QA Coordinator is the delegated manager of the WDEQ-AQD's QA Program. The QA Coordinator has direct access to the Administrator, APMP Manager, and APMP Supervisor on all matters pertaining to QA. The QA Coordinator’s main responsibility is QA oversight and ensuring that all personnel understands the WDEQ-AQD's QA policy and all pertinent EPA QA policies and regulations specific to the APMP. The QA Coordinator provides technical support and reviews and approves QA products.

Responsibilities include:

● Developing and interpreting WDEQ-AQD QA policy and revising it as necessary.

● Developing a QA Annual Report for the Administrator.

● Assisting Monitoring Specialists and Project Managers in developing QA documentation and in providing answers to technical questions.

● Ensuring that all personnel involved in environmental data operations have access to any training or QA information needed to be knowledgeable in QA requirements, protocols, and technology.

● Ensuring that environmental data operations are covered by appropriate QA planning documentation (e.g., QAPPs, data quality objectives, etc.).

● Ensuring that reviews, assessments, performance evaluations, and audits are scheduled and completed and, if needed, conducting or participating in QA activities.

● Tracking the QA/QC status of all programs.

● Recommending required management-level corrective actions.

● Serving as the program's QA liaison with EPA Regional QA Managers or QA Officers and the

Regional Project Officer.

● Uploads Quality Assurance data to EPA’s AQS System.

The QA Coordinator has the authority to carry out these responsibilities and to bring to the attention of the APMP Manager any issues associated with these responsibilities. The QA Coordinator either performs or delegates the responsibility of QA development and implementation.

4.4 Project Managers

Project Managers are responsible for project coordination; oversight of contractor activities;

maintaining the official, approved QAPP; and QAPP distribution. Responsibilities include:

● Ensuring the day-to-day operation and upkeep of all monitors are maintained.

● Overseeing data processing, reporting, and assuring data collection is performed in a timely fashion.

● Understanding EPA monitoring, QA regulations, and guidance, and ensuring contractors, Monitoring Specialists, and Site Operators understand and follow those standards.

● Understanding WDEQ-AQD QA policy and ensuring subordinates understand and follow the policy.

Section 4

● Understanding and ensuring adherence to the QAPP as it relates to program support activities.

● Participating in the development of data quality requirements with the appropriate QA staff.

● Writing and modifying QAPPs and SOPs.

● Verifying that all required QA activities were performed and quality standards were met as required in the QAPP.

4.5 Monitoring Specialists

The field personnel, either WDEQ-AQD or contractor, are responsible for carrying out required tasks and ensuring the data quality results of the tasks by adhering to the guidelines and protocols specified by the QAPP and SOPs for the field activities. Responsibilities include:

● Change PM filters (gravimetric and speciation) on the filter-based instruments (weekly or as needed).

● Participating in the implementation of standards, as laid out in the QAPP.

● Keeping up-to-date in training and certification activities.

● Verifying that all required QA activities are performed and quality standards are met (as required by the QAPP).

● Following manufacturer specifications for any equipment used.

● Documenting deviations from established procedures and methods.

● Thoroughly document and keep all routine maintenance activities performed at the stations all problems and report corrective actions to the Site Operator and Project Manager.

● Preparing and delivering reports to the Project Manager.

● Reviewing data and assessing and reporting on data quality.

4.6 Site Operator

For the Particulate Matter network, the Site Operators visit the monitoring station once a month. The Site Operators role is to do routine maintenance on the monitoring station and instrumentation. Responsibilities include:

● Change PM filters (gravimetric and speciation) on the filter-based instruments (weekly or as needed).

● Perform unexpected tasks such as running manual calibration (if necessary after a repair).

● Replace electronic or pneumatic components at the direction of a Monitoring Specialist.

● Reporting all problems and corrective actions to the Contractor, Monitoring Specialist, or Project

Manager.

● Thoroughly documents all activities performed at a station and reports activities and results to the Project Manager.

● Reviewing data and assessing and reporting on data quality.

4.7 Data Manager

The Data Manager reports to the Air Monitoring Manager and is in charge of the WyVisNet website and the AirVision data management system, which runs WyVisNet. Responsibilities include:

● The Data Manager is in charge of uploading data to the EPA’s Air Quality System (AQS), which is the National database for all air pollution and meteorological data.

● Ensures data are moved to/from the IMPACT system, AirVision, and shared drives per our WDEQ

Records Management Plan.

Section 4

● Performs data queries within the central database in Cheyenne headquarters.

● Works with the vendors that supply and maintain the WyVisNet software system.

● Performs data analyses as described in Sections 22 and 23 of this QAPP.

Please note that an annual review of the QAPP will be performed and, if no changes are needed, the WDEQ-AQD will document that no changes were necessary. If changes are required, revised pages with the revisions will be inserted/changed, revisions will be tracked, and a new revision number will be assigned to the document.

Section 4

Figure 1 illustrates the organizational structure for the WDEQ-AQD. For a list of project participants, please see Appendix B.

Figure 1. WDEQ-AQD Organizational Chart

Section 5

5.0 Problem Definition/Background

This QAPP pertains strictly to the collection and analysis of ozone within the WDEQ-AQD monitoring network and details the methodologies to establish precise and accurate ozone measurements at all the stations within the WDEQ-AQD monitoring network, regardless of the type of monitoring that is performed.

The objective of the ozone monitoring network is to provide the necessary information for developing a representative air quality data set capable of delineating differences among geographical and climatological regions. The monitored data are used to characterize and monitor trends in air quality and ensure compliance to air quality standards and may be used for national health assessments, model evaluations, and comparison with other ambient air monitoring data. The procedures outlined in this QAPP have been developed to meet the goals and objectives of the monitoring project. Revisions to the QAPP are made, as necessary, to reflect changes to the regulations or goals of the monitoring project. At a minimum, the QAPP is reviewed and revisions are made as necessary on an annual basis.

As of December 31, 2020, The WDEQ-AQD monitored for ozone (O3) at 16 stations in Wyoming. Hourly ozone readings from a monitor are used to compute the daily maximum 8-hr ozone average at the station. These daily maximum 8-hr ozone averages are ranked throughout the calendar year. The fourth highest annual value in a calendar year is then averaged with the fourth-highest annual values from two more years to compute a three-year average, referred to as the design value. The design value must not exceed 0.070 ppm. On December 28, 2015, the EPA promulgated the new ozone NAAQS in 40 CFR Part 50.19(a)2. In addition to the new NAAQS, the EPA updated the calculation methodology to compute the design value. The exact methodology can be found in 40 CFR Part 50, Appendix U3.

On July 20, 2012, the EPA designated all of Sublette County and parts of Lincoln and Sweetwater Counties as a marginal nonattainment area for ozone using the 2008 Ozone NAAQS of 0.075 ppm. The remaining portion of Wyoming is designated Attainment/Unclassifiable for the 2008 Ozone NAAQS.

After the 2015 Ozone NAAQS was made effective, Wyoming Governor, Matt Mead, recommended to the EPA that Wyoming’s 23 counties be designated as Attainment for this standard. The Federal Register (82 FR 54232)4 designated 21 of Wyoming’s counties as Attainment/Unclassifiable according to the 2015 Ozone NAAQS. This rule was made effective on January 16, 2018. The remaining counties—Albany County and Laramie County—were designated Attainment/Unclassifiable on August 3, 2018 (83 FR 25776)5.

Figure 2 illustrates the WDEQ-AQD ozone monitoring stations, past and present. As shown in the map, the WDEQ-AQD monitoring network covers the entire state.

Section 5

Figure 2. WDEQ-AQD Ozone Monitoring Site Locations, 2004-2025

5.1 Supporting Documentation

The information collected for this monitoring program will meet requirements as found in the following documents:

• EPA’s Technical Assistance Document (TAD) for Calibration of Air Monitoring Analyzers for Ozone, October 20137

• EPA’s Technical Assistance Document (TAD) for Calibration of Air Monitoring Analyzers for Ozone, July 20208

• EPA’s TAD for Calibration of Air Monitoring Analyzers for Ozone, January 20239

• Quality Assurance Handbook for Air Pollution Measurement Systems, Volume II: Ambient Air Quality Monitoring Program, EPA‐454/B‐17‐001, January 20179

• 40 CFR Part 58, Appendices A-E 10

• 40 CFR Part 50, Appendix D11

The guidance presented in the above-listed documents will be followed for this monitoring program and are intended to ensure that the data collected and technical information are documented and of appropriate quality and usability.

Section 6

6.0 Project Task Description

6.1 Ozone Measurements

The analytical principle is based on the absorption of ultraviolet (UV) light by the ozone molecule and subsequent use of photometry to the measure reduction of the quanta of light reaching the detector at 254 nm. The degree of reduction depends on the path length of the UV sample cell, the ozone concentration introduced into the sample cell, and the wavelength of the UV light, as expressed by the Beer-Lambert law. An air sample is drawn into an optical absorption cell where it is irradiated by a low-pressure, cold cathode mercury vapor lamp fitted with a sheath to filter out radiation with a wavelength of less than 254 nm. A photodetector, located at the opposite end of the sample cell, measures the reduction in UV intensity at 254 nm caused by the presence of ozone in the sample cell.

6.2 Sampling Frequency

Data from the ozone analyzers are sampled every second by the Data Acquisition System (DAS). The DAS then stores the data in 1-minute and hourly increments (at a minimum). This data is then transmitted and reviewed by WDEQ-AQD Contractors on a defined interval at their central location.

6.3 Project Schedule

Personnel working on this project are fully qualified, trained, and capable of performing their assigned duties. Work schedules include: daily data review, quarterly and semi-annual air quality equipment calibrations, quarterly data summaries within sixty (60) days of quarter completion, annual reports within ninety (90) days of year completion, and maintenance and corrective action.

Section 6

6.4 Project Reports

Table 2 presents the reports that will be produced as part of this project.

Table 2. Project Reports

Reports Frequency Content Responsible Position

Quarterly Air Quality Reports

Quarterly Summarizes data following EPA guidelines, includes accuracy and precision

Contractors with review by Project Managers or AQD Data Validator with review by Project Manager.

Air Quality Annual Data Report

Annually Summarizes data following EPA guidelines Contractors with review by

Project Managers

Performance Audit Reports*

Semi‐annually Summarizes audit results following

EPA guidelines

WDEQ‐AQD QA Coordinator with review by Project

Manager

Corrective Action Reports

As Needed Summarizes corrective actions taken to return the monitoring station to compliant status

Contractors with review by Project Managers or

Monitoring Specialists with review by Project Managers

Response to Corrective Action Reports

As Needed Reports the results of the corrective actions taken

Contractors with review by Project Managers or

Monitoring Specialists with review by Project Managers

*Boulder and Cheyenne NCore are audited quarterly.

Section 7

7.0 Quality Objectives and Criteria for Measurement of Data

This section discusses the Data Quality Objectives (DQOs), Measurement Quality Objectives (MQOs), and Data Quality Indicators (DQIs) that are mandatory for all monitoring programs.

Generally, the DQOs for any program are created by the stakeholders. The DQO process is a seven-step decision tree that allows the stakeholders of the WDEQ-AQD to define parameters for the program. The DQO process has been in existence for many years, first by the EPA and then utilized by the State, Local and Tribal governments that are required to collect data on behalf of the EPA. Please note that it is outside the scope of this document to discuss whether or not the State of Wyoming, or parts of the state, are in attainment. Please refer to the WDEQ-AQD 2025 Network Plan6 for the discussion of attainment for Ozone.

As mentioned, the DQO is a seven-step process that takes the form of a discussion of the important aspects of the program. It is encouraged and useful that the DQO process is performed from time to time to ensure that the objectives are clear and concise.

7.1 The DQO Process

On August 12, 2020, the WDEQ-AQD and its Contractor met to discuss the DQOs for the programs and define the objectives. Table 3 below outlines the discussion and the outputs of the DQO process in each step.

In order for the DQOs to be fulfilled, MQOs are designed to evaluate and control various phases (sampling, preparation, and analysis) of the measurement process to ensure that total measurement uncertainty is within the range prescribed by the DQOs. MQOs can be defined in terms of the following DQIs: precision, bias, representativeness; detectability; completeness; and comparability.

Table 3. DQO Seven-Step Decision Tree Process

DQO Step Output to Discussion by Decision Makers

Step 1. State the Problem

The State of Wyoming, being within the bounds of the United States, must adhere to the Clean Air Act Amendments. The Code of Federal Regulations 40 part 50 set the NAAQS and the State of

Wyoming measures for the NAAQS pollutants. In addition, the State of Wyoming promulgated their own Wyoming Ambient Air

Quality Standards (WAAQS), which are nearly identical to the NAAQS. The State of Wyoming must comply with these standards and thus measure in various locations to meet the requirements.

Step 2. Identify the Goal of the Study

Not only does the State of Wyoming have to measure for these NAAQS pollutants, but they must also adhere to the level of the standard (attainment vs. nonattainment as promulgated in 40

CFR Part 50).

Step 3. Identify Information Input The input information is the hourly ozone data that are collected at the locations where ozone is monitored (see Appendix B).

Step 4. Define the Boundaries of the Study

The boundary of the study is the entire State of Wyoming. This study only applies to the WDEQ‐AQD Primary Quality Assurance

Organization (PQAO).

Section 7

DQO Step Output to Discussion by Decision Makers

Step 5. Develop the Analytical Approach

The WDEQ‐AQD will collect ozone data at all of the monitoring locations stated in Appendix B. At the end of the year, the WDEQ‐AQD will review, analyze, and certify that the data collected within the WDEQ‐AQD network are valid within the parameters laid out in this QAPP.

Step 6. Specify Performance Criteria

The performance criteria are described in this QAPP under the MQOs and thus the DQIs. If the data collected adhere to these performance criteria, then the data can be used to ascertain if the State of Wyoming is within nonattainment or attainment status. The results of the decisions on attainment are discussed in detail within the Annual Network Plan and Network

Assessment.

Step 7. Develop the Plan for Obtaining Data

Having developed these DQOs, the WDEQ‐AQD has developed this ozone QAPP and SOP for ozone analyzers to ensure that the QA and QC procedures are documented and followed by WDEQ‐

AQD staff and their Contractors.

7.2 Data Quality Indicators

The data quality indicators (DQIs) are a set of indicators that can be easily measured. For instance, precision and bias can be calculated using statistical methods on the data. The other DQIs are either inherent in the ozone analyzer, i.e. detection limit, or indicate how the samples are handled and analyzed.

Here is a discussion of each DQI:

• Precision - a measure of agreement among repeated measurements of the same property under identical, or substantially similar, conditions. This is the random component of error. Precision is estimated by various statistical techniques typically using some derivation of the standard deviation. Precision is determined based on the three-day zero, span, and precision checks.

• Bias - 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. Bias is determined by using the paired data from the 1-in-3 day QC checks.

• Detection Limit - the lowest concentration or amount of the target analytic that can be determined to be different from zero by a single measurement at a stated level of probability.

For the high-sensitivity instruments, this is an important DQI. The EPA specifies how and how often this test is performed, which is recommended annually. The specific procedures are detailed in the SOP for ozone analyzers, which is a companion document to this QAPP.

• Completeness - the amount of valid data obtained from a measurement system compared to the amount that was expected to be obtained under normal conditions. Data completeness requirements are included in the reference methods or NAAQS (40 CFR Part 50).

• Comparability - generally falls under the auspice of equipment specifications and monitoring methods. For ozone, only Federal Equivalent Method (FEM) instruments are used for data collection. The methodology used is to draw the air samples into the instrument using federally approved glassware and/or Teflon tubing.

• Representativeness - this DQI deals with whether or not the location of the ozone analyzer represents the type of monitoring that is necessary, i.e., if the station is sited appropriately for the objective.

• Accuracy - a measure of the overall agreement of a measurement to a known value, including a

Section 7 combination of random error (precision) and systematic error (bias) components of sampling.

This is accomplished using the annual performance evaluations (APEs). In addition, the EPA or its designee will also perform through-the-probe (TTP) audits (as part of the National Performance Audit Program (NPAP)). These QA procedures are discussed in more detail in Section 20 of this

QAPP.

The goal for acceptable measurement uncertainty (precision) for ozone is an upper 90 percent confidence limit for the coefficient variation (CV) of <7.1 percent (%). The bias for ozone is expressed as an upper 95 percent confidence limit for the absolute bias of <7.1%.

7.3 Representativeness of the Ozone Measurements

Site selection and probe placement follow guidelines from the following EPA documents to ensure that measurements are representative of meteorological and air quality monitoring conditions near the monitoring station:

• EPA’s Quality Assurance Handbook for Air Pollution Measurement Systems, Volume I:

Principles12

• EPA’s Quality Assurance Handbook for Air Pollution Measurement Systems, Volume II: Ambient Air Quality Monitoring Program, EPA-454/B-17-001, January 20179

• 40 CFR Part 58, Appendices A, C, and E 10

The monitoring sites that were selected to house the ozone analyzers were selected to be as representative as possible to the general region of interest. The placement of a shelter considers local interferences, distance to structures, trees, and roadways, and height of probe above ground. The network was set up in accordance with EPA-defined ambient air quality siting criteria.

Section 8

8.0 Special Training/Certifications

Personnel assigned to the ambient air monitoring programs will meet the educational, work experience, responsibility, and training requirements for their positions. Records on personnel qualifications and training will be maintained in personnel files and will be accessible for review during audit activities. All WDEQ-AQD staff will follow the WDEQ-AQD Monitoring Section’s training plan and provide proper documentation and tracking.

Adequate education and training are integral to any monitoring program that strives for reliable and comparable data. It is recommended that WDEQ-AQD maintains some requirements for personnel qualifications (combination of education and experience). Training is aimed at increasing the effectiveness of employees and their organization.

As part of a quality assurance program, the procedures should include information on:

• Personnel qualifications (general and position-specific)

• Training requirements (based on position)

• Frequency of training

Appropriate training should be available to employees supporting the Air Pollution Monitoring Program and commensurate with their duties. Such training may consist of classroom lectures, workshops, web-based courses, teleconferences, and vendor-provided and on-the-job training. Training should also include appropriate reading materials, such as the CFR, EPA guidance documents, and the WDEQ-AQD QAPPs and SOPs, to name a few.

EPA encourages monitoring organizations to maintain documentation that details the training provided to all monitoring staff, along with documentation that illustrates the successful completion of those training requirements. Along with suggested training, some EPA programs require mandatory training and/or certifications. These programs include, but are not limited to, the National Performance Audit Program (NPAP) and the Performance Evaluation Program (PEP). All personnel performing audits in these projects or programs are required to possess mandatory training or a current certification issued by the EPA office responsible for the monitoring program. Over the years, several courses have been developed for personnel involved with ambient air monitoring and quality assurance aspects.

Formal QA/QC training is offered through the following organizations:

• Air Knowledge (https://airknowledge.gov/)

• Air & Waste Management Association (AWMA) https://www.awma.org/

• American Society for Quality (ASQ) https://asq.org/

• EPA Quality Staff (QS) https://www.epa.gov/quality/

• EPA Regional Offices https://www.epa.gov/aboutepa/regional-and-geographic-offices

• EPA Ambient Monitoring Technology Information Center (AMTIC) https://www.epa.gov/amtic

WDEQ-AQD should consider adding manufacturer-provided training to the equipment purchase cost.

Persons with experience in the subject matter described in the courses would select courses according to their appropriate experience level. Courses not included in the core sequence would be selected according to individual responsibilities, preferences, and available resources.

Section 9

9.0 Documents and Records

The WDEQ-AQD is committed to fully documenting all activities related to data collection, analysis, validation, and reporting. Table 4contains a list of the records maintained by the air monitoring program. These records can be electronic, bound in notebooks, and/or forms that are used for specific applications. Electronic records will be stored on main office storage drives and archived by the Contractors and ultimately, the WDEQ-AQD office servers. All project files are backed up daily. In addition, weekly network backup occurs. The weekly backup network files are stored onto external hard drives which are stored off-site. The WDEQ-AQD has several of these backup hard drives and copies of the field logbook are archived in the WDEQ-AQD Cheyenne office for five (5) years.

Table 4. Documentation and Reports

Documentation Type

Frequency Report

Submission Archive Retention Period

Monitoring Data Daily Downloads Contractors

WDEQ‐AQD and Contractor’s Server (with backup)

5 years

QAPP and SOPs Annually or more frequently, as needed

QA Coordinator WDEQ‐AQD 5 years

Copies of Field Logbooks

After each site visit

Site Operators and Contractors

WDEQ‐AQD and Contractors

5 years

Quarterly Reports Quarterly Contractors WDEQ‐AQD and

Contractors 5 years

Annual Data Report

Annually Contractors WDEQ‐AQD and

Contractors 5 years

Performance Audit Summaries

Semi‐Annually QA Coordinator or

Contractor WDEQ‐AQD 5 years

All monitoring data, reports and program documentation will be retained by WDEQ-AQD for a minimum of five (5) years. The WDEQ-AQD will review and approve changes to the QAPP given updates or changes to the Records Management Plan.

Section 10

Section B. Data Generation and Acquisition

10.0 Network Description

This section describes the project design and implementation of the ozone monitoring network. For the list of current locations of the Ozone Monitoring Network, please see Appendix B, Instrument Locations.

Section 11

11.0 Sampling Method

Ozone photometry is a spectrophotometric method that has been in use since the early 1970s. The reference method utilizes chemiluminescence with ethylene oxide. However, the reference method was replaced by the UV light spectrophotometric method. All instruments in the WDEQ-AQD network use UV photometry. This method is considered to be an EPA FEM.

Amongst all of the pollutant gases measured, ozone is unique in that it is the only gaseous pollutant that cannot be placed in a compressed cylinder because it will oxidize the interior lining of the cylinders and thus change the concentration within the cylinder. Therefore, there are no National Institute of Standards and Technology (NIST)-traceable standards for ozone.

In the late 1970s, the EPA Office of Research and Development (ORD), along with the Office of Air Quality Planning and Standards (OAQPS), designed a system by which ozone measurements could indeed be measured to a level of confidence. This system is known as the Standard Reference Photometer (SRP) system. These “standard reference primary standards” are placed at the laboratory in Research Triangle Park, North Carolina, and in or near EPA offices in each of the ten regions. They are intercompared annually. State, Local, and Tribal (SLT) PQAOs can set up intercomparisons with the SRPs and thereby transfer the certification of the SRPs to the SLTs. This system is described in detail in the Ozone Transfer Standard Guidance Document, October 20157 and was recently updated in July 20208. It is not within the scope of this QAPP to describe these systems, so it is referenced here.

Ozone analyzers operated by the WDEQ-AQD are placed in monitoring shelters across the state. The samples are drawn into the instrument, as described in Volume II of EPA’s Quality Assurance Handbook for Measurement Systems9. Ozone is measured by sampling ambient air from either a borosilicate glass manifold or sample lines that are made of polytetrafluoroethylene (PTFE) or Perfluoroalkoxy alkane (PFA) Teflon. For O3 measurements, the sampling inlet is on the roof of the shelter, approximately four

(4) meters above ground level (AGL). The Teflon sampling line is protected by a pipe with a Teflon-coated cover protecting the inlet probe. A Teflon particulate filter also protects the sampling line.

Inside the shelter, the analyzer may be connected with a Teflon line to the coated “green hat” manifold or, at older stations, a borosilicate glass manifold. The ozone analyzer uses a Teflon line to connect to a port on the manifold. A pump is connected to the end of the manifold to keep the residence time as low as possible. The residence time of the analyzers is less than seven (7) seconds, which is within the 20-second residence time requirement. Ozone probe siting information and site configuration for the monitoring is in accordance with 40 CFR Part 58 Appendix E11. On an annual basis, the flows of the instruments and manifold pumps are measured to ascertain whether or not the flow rates can keep the residence time to less than twenty (20) seconds.

11.1 Ozone Analyzers

For a list of the current analyzers utilized throughout the WDEQ-AQD network, please see Appendix B, Types of Instruments.

11.2 Support Monitoring Equipment

This section summarizes the ozone instrumentation used at the WDEQ-AQD ozone network. The operating range of the sensors and monitors easily brackets the range of environmental conditions expected at the site.

The supporting equipment used at the monitoring stations are discussed in the following sections. The SOP for ozone analyzers details the calibration and operation of the equipment.

Section 11

11.3 Data Acquisition System

Instantaneous data from the ozone analyzers are transferred once per second to the DAS, usually by a serial cable. The DAS is a self-contained box with the ability to measure and control electronics and communicate with on-site computers or remote systems. Data are generally stored in a table format.

Please note that the DAS stores 1-minute and hourly data (at a minimum). The one-second data is not stored. In addition, the DAS communicates with the multi-gas dilution calibrator and initiates automated zero, precision and span checks. The DAS records the response to the checks and then can compare that response to the expected value.

11.4 Telecommunications

Telecommunication services are used for high-speed remote communication to all on-site equipment, including the DAS. Additionally, each analyzer on-site is configured with a unique internet protocol (IP) address for remote maintenance and control purposes. The gateway has all of the firewall protection and routing protocols necessary for protection, isolation, and security.

11.5 Climate-Controlled Shelter

The shelter temperature is maintained by a heating, ventilating, air conditioning (HVAC) system. The temperature is controlled by a thermostat located within the shelter. The temperature is maintained at 20-30 °C at all times. The shelter houses the analyzers, calibration equipment, sample intake manifold, DAS, and cylinders.

11.6 Zero Air System

In order to determine the baseline of the analyzer and its detection limit, a zero air system is used. The zero air system is a fully self-contained source of high purity zero air for dilution calibrators. It is ideal for use with highly sensitive analyzers in ambient background and trace level applications. The zero air system includes a dew point sensor, an oil and diaphragm-free pump, and scrubbers to remove all pollutants measured.

The regenerative, heatless dryer removes water and produces output with a dew point less than -40°C (up to a flow rate of 30 standard liters per minute (SLPM)). The system's pressure, temperature, and dew point values are all continuously monitored, which allows a microcontroller to adjust the pump cycling frequency, valve timing, and heater power for optimal performance. The WDEQ-AQD Contractors will perform an annual zero air test. This is performed by substituting the zero air generator with a compressed gas zero air cylinder from a verified gas vendor. The gas cylinder is hooked up to the Mass Flow Controller unit and all analyzers are allowed to sample the zero air from the cylinder. The zero response of the ozone analyzer is then compared to the zero air response from the zero air generator.

11.7 Multi-Gas Dilution Calibrator

The multi-gas dilution calibrator is an integrated gas flow controlling device that contains mass flow controllers (MFC) that can flow and mix pressurized gases and zero air in very precise and accurate amounts to be shunted to the analyzers. For ozone, high pressure from its source is then shunted through a solenoid valve that allows a small portion of air to flow past a UV lamp that converts oxygen to ozone. This “ozonated” air is then remixed with the original air and flows through lines to the manifold and thus to the ozone analyzer. Verification and calibration of the ozone mixture from the

Section 11 dilution calibrator are measured by both the on-site ozone analyzer and an ozone transfer standard.

Figure 3 illustrates the configuration of the monitoring equipment and the placement of this equipment at a typical monitoring site.

Figure 3. Configuration of Monitoring Equipment in the Instrument Rack

11.8 Standard Operating Procedures

An SOP has been developed to provide instructions to the Site Operators regarding the routine operation of the ozone equipment. This SOP for ozone analyzers covers equipment inspection and acceptance testing, visual inspections, preventive maintenance, manual zero, span, precision checks, and calibrations. The SOP for ozone analyzers, located in Appendix A, is an independent document that is a companion to this QAPP.

The identification, cause, and corrective action for conditions adverse to quality will be documented on the Corrective Action Report form (example found in the SOP for ozone analyzers). Follow-up action will be taken by the Contractor and Project Manager to verify the corrective action was taken.

Section 12

12.0 Sample Handling and Custody

Ozone ambient air samples are collected through Teflon tubing, which extends to the outside of the shelter. Teflon is considered acceptable by the EPA for use as intake sampling material for all reactive gaseous pollutants. The residence time is defined as the amount of time it takes for a sample of air to travel from the opening of the cane to the inlet of the analyzer and is required to be twenty (20) seconds or less (recommended ten (10) seconds or less).

Section 13

13.0 Analytical Method

The ozone analyzer is a microprocessor-controlled instrument that uses a system based on the Beer- Lambert law for measuring low ranges of ozone in ambient air. The ozone analyzer is a self-contained instrument that does not require any laboratory analyses. The WDEQ-AQD only utilizes FEMs, which have been rigorously challenged by the EPA in the Research Triangle Park, North Carolina, laboratory to operate within the parameters set by the EPA. For a list of the US EPA Federal Method Equivalency Designations utilized throughout the WDEQ-AQD network, please see Appendix B, Types of Instruments.

Section 14

14.0 Quality Control Requirements

This section describes the routine quality control procedures used for the ozone monitoring program. All procedures have been specifically designed to provide the appropriate quality control and ensure that valid data recovery meets or exceeds the WDEQ-AQD data recovery objective of 90 percent per quarter for ozone monitoring.

The WDEQ-AQD monitoring program will follow the QC guidelines as stated in the following documents:

• 40 CFR 58, Appendix A – E10

• EPA’s Quality Assurance Handbook for Air Pollution Measurement Systems, Volume II: Ambient Air Quality Monitoring Program, January 20179

• EPA’s Technical Assistance Document for Calibration of Air Monitoring Analyzers for Ozone, October 20137

• EPA’s Technical Assistance Document for Calibration of Air Monitoring Analyzers for Ozone, July 20208

• EPA’s TAD for Calibration of Air Monitoring Analyzers for Ozone, January 20239

14.1 Instrument/Equipment Calibration and Frequency

Table 5 illustrate the QC procedures, calibration and audit requirements, and frequencies for ozone instruments.

Table 5. Ozone Analyzer QC Procedures

Procedure Frequency Requirement

Visual inspection of equipment Each site visit;

Typically once a month As needed

Remote interrogation of the monitoring station and inspection of data Daily QC checks for data screening

Calibration Quarterly Meets MQO

Zero/span checks Once every 3 days Meets MQO

Precision checks Once every 3 days Meets MQO

Level II transfer standard verification

Annual verification/re‐ verification against the EPA

Region 8 Level I Level I‐SRP traceable

Equipment maintenance As needed or as the…