Here's a short ambient air quality audit guideline to help you and other professionals understand what's in the Alberta Air Quality Monitoring Directive (AMD). Chapter 8 of the AMD is the focus of this article.
If you need a Practical Guidance for Compliance:
You might be an environmental compliance officer or facility manager responsible for maintaining air quality standards. How can you ensure your operations comply with regulations by conducting these audits?
Understanding the Process:
You should gain insight into what an air quality audit entails by understanding the general process.
The Ambient Audit is part of Alberta's Air Monitoring Directive (AMD). The document outlines the purpose and procedures for auditing continuous ambient air monitoring equipment in the province. Air quality audits make sure monitoring practices follow AMD guidelines, so data is comparable and high-quality.
The chapter covers how to prepare monitoring stations, verify calibration systems, and respond to audit reports. Basically, it's for anyone responsible for continuous ambient air monitoring in Alberta, emphasizing corrective action for unacceptable instruments. Since September 2015, the person in charge has been required to comply with these requirements.
1.1 History of Amendments
The document was amended in October 2018. These changes included providing guidance on audits of specific analyzers, clarifying the purpose of the annual cross-check of gases, adding guidance on response letters and action plans, allowing auditors to flag data as questionable, and allowing third party reviewers to reject recommendations. The document's design was updated in August 2016, with clarifications about ambient monitoring equipment audits. In addition, references to electronic checklists on the AMD website were added to Appendices C and D. The title page was updated to reference AMD-1989 in 2016.
Preparation for an audit involves coordinating with the station operator. Except for scheduled calibrations or emergencies, the person responsible shouldn't change or calibrate the monitoring station after receiving notification of an audit other than scheduled or emergency actions. Make sure the station is ready for inspection without any last-minute changes.
During the audit, the person responsible or station operator must be present at key stages, like the pre-audit meeting, providing access to the monitoring station, and discussing findings. Make sure the station is in good shape and take care of any immediate problems. During the air quality audit, metadata should be available, and the auditor may ask for calibration documents, maintenance records, site documentation, and wind sensor calibration records. In some analyzers, SO2 gas is delivered simultaneously to check internal scrubbers, and no measurable response is expected. Addressing deficiencies promptly also requires the presence of the responsible person or operator.
The auditor will return the monitoring station to its original setup after the audit and meet with the station operator to discuss the results. A checklist must be signed by the person responsible or station operator verifying the station is back to pre-audit. The person responsible must address the issue as soon as possible if immediate action is needed. They have to fix the deficiency within the specified timeframe and report back to the auditor. The person responsible or station operator will get a written report with results and failures. Appendix A has an example of an ambient air quality audit report.
Aside from station audits, the responsible person has to make sure calibration systems and gases meet standards every year. Including checking new, unverified gases against audit standards and verifying continuous monitoring station calibration systems. Gases don't need to be cross-checked every year once they're verified. The person in charge should schedule an appointment with the auditor. The Calibration Chapter (Chapter 7) of the AMD outlines this process for ensuring accurate and reliable data.
3.1 Calibration Systems Audit
Calibration systems (equipment used for calibration) need to be audited by the person in charge. The systems must be delivered to the auditor on time, so everything is working. You have to stay at the lab during the audit. Calibration systems should challenge the auditor's equipment. The person in charge should stop using the system if any criteria aren't met. After an audit, a written report on actions taken to address operational concerns should be provided within one month. Monitoring stations in Alberta benefit from this process.
3.2 Calibration Gas Audit
In order to perform a calibration gas audit, the person in charge or station operator needs to deliver the calibration gas cylinders in advance. This keeps the gas at room temperature during the audit. Each gas cylinder must come with the right regulator and the manufacturer's gas certificate. Monitoring stations use calibration gases to verify accuracy.
A person in charge must start correcting the issues outlined in their Quality Assurance Plan if an audit fails in ambient air monitoring stations, calibration systems, or calibration gas. Also, they have to report the corrective actions taken to the auditor within a month. A written report detailing actions to address the failure or non-compliance must be submitted within one month of the auditor's notification. The person in charge must stop using a calibration system or calibration gas until the auditor says they're okay. Calibration requirements must be met by changing procedures or calculations.
4.1 Data Handling
Data collected from the affected analyzer(s) must be invalidated if an audit fails in ambient air monitoring stations or if calibration systems or calibration gas fail. The invalidation should go back to the last documented time of proper operation and last until corrective actions have been taken. Unless the data has been reviewed, validated, or corrected, and evidence of validity is provided, the person in charge should invalidate the data until the last calibration is conducted with a verified, functioning system. Invalidated data must be flagged according to data quality requirements, and if acceptable, corrected data can be resubmitted to the Regulator. Validated data can be corrected depending on the cause of the audit failure, and the regulator decides whether to accept corrected data.
A follow-up audit will be conducted if an ambient air monitoring station audit finds that certain criteria or current requirements have not been met. In Section 2.0 of the Audit Chapter (above), you'll find the procedures for the follow-up air quality audit.
5.1 On-Site Checklist
Station operators and auditors should work together to investigate and identify the causes of an ambient air monitoring station audit failure or operational issues during an audit. Whenever an audit fails or operational problems are detected, the person responsible must fill out the On-site Checklist in Appendix C. The AMD website has a checklist that helps determine the reasons behind audit findings. Rather than trying to recreate the situation later, complete the checklist right away to understand the causes.
5.2 Data Review Checklist
During audit closure, if the auditor believes that the audit exposes operational issues that cast doubt on the data's integrity, they must fill out the Data Review Checklist in Appendix D. This should be used along with draft audit field sheets, On-site Checklist, draft summary audit report, and any other relevant documents. You can find the Data Review Checklist on AMD's website.
5.3 Response Letters and Reports
Depending on the situation, the person responsible might have to provide response letters or reports to the auditor. Here's what you need to know:
Here's instructions for the first response letter you must provided as outlined in instruction coded "Aud 5-C", by the date the auditor asks for it.
You'll need details like the monitoring station ID, the audit findings, what steps were taken to fix it, a timeline for corrections, the On-site Checklist (Aud 5-A), the amount of data affected, the Data Review Checklist (Aud 5-B), and how data was handled.
Dispute audit findings (Aud 5-E):
The First Response Letter should explain why the person responsible disagrees with the audit findings and provide additional evidence.
Closing the audit:
- A Meeting Letter acknowledges receipt of the First Response Letter.
- The auditor may close the audit and issue a Closure Letter if he's satisfied.
- If not, a Meeting Letter is sent with reasons and/or explanations, asking for a meeting and specifying a response date.
Action plan and meeting:
- We meet to develop an Action Plan.
- Action plans should outline what needs to be done, who will do it, and when it's going to be done.
The second response letter (Aud 5-F):
- This will also have a deadline.
- The letter covers the same stuff as the First Response Letter, including the monitoring station ID, audit findings, corrective steps, a timeline for the correction, an On-site Checklist, the amount of data affected, the Data Review Checklist, and any data handling (if applicable).
Here's what happens after the Second Response Letter:
Letter of acknowledgement and second meeting:
- With a Second Meeting Letter, the auditor acknowledges the Second Response Letter.
- There's a meeting request, reasons if the response doesn't close the audit, and a response deadline.
Closing the audit or pursuing a resolution:
- A Closure Letter is issued if the actions in the Second Response Letter are adequate. Follow the steps outlined.
- In that case, a Second Meeting Letter is sent. Maybe the auditor and person responsible decide a third party review is needed.
Review by a third party (Aud 5-H):
- As required by the auditor, the person responsible prepares and submits an Implementation Plan.
- Implementation Plan includes monitoring station ID, audit findings, contracted third party report, and actions with timelines.
- When the auditor asks, write an Action Report.
- It shall include monitoring station IDs, audit findings, Implementation Plan progress, data flagging recommendations, and data corrections.
Letter of closure:
- The auditor sends the person responsible a Closure Letter.
- If the audit is deemed complete and satisfactory, this letter acknowledges receipt of the response.
Consequences of non-compliance:
- Data can be flagged as invalid or questionable if actions aren't completed.
5.4 Third Party Review
Review by a third party:
- A third party can sometimes be brought in to review audit findings and suggest fixes, especially for data issues.
- The auditor and responsible person agree on hiring a third party.
Here's what we know (Aud 5-L):
- Plans, reports, checklists, data, logs, and various records related to the audit must be shared with the third party.
The Terms of Reference (ToR) are:
- It's like a third-party review plan, decided by both the auditor and the person responsible.
- The plan covers what's going to happen, who's involved, how it'll work, and when.
Setting up the details (Aud 5-L):
- ToR meetings set the details, decide what areas to review and what improvements to make.
Data to flag:
- Air Quality Data Warehouse marks data under investigation as 'Under Investigation' when a third party is involved.
Acceptance and recommendations:
- The auditor might not always accept the third party's suggestions. If they don't think they're right, the auditor can reject them.
5.5 Timeline and Late Reports
- From start to finish, the audit process should take no more than three months.
- It usually takes 30 days for an ordinary audit without issues.
Third party involvement:
- A maximum of six months is allowed for problems that need to be resolved by a third party (an independent party).
Here's the timeline:
- AMD's Audit Process Flow Chart shows the specific timeframes for the auditor and person responsible.
- It shortens the time for the next steps if the station operator (person responsible) sends responses late.
Extending and terminating:
- Exceptionally, the audit process might be extended, but if late replies cause a delay beyond 30 business days without a valid reason, the process might end and the data might be flagged as questionable.
Here's a summary of Chapter 8's appendices.
Are you an industrial facility in Alberta that is required to report air quality? An Air Monitoring Directive (AMD) Quality Assurance Plan (QAP) is required to comply with the Alberta Environmental Protection and Enhancement Act (EPEA). Over 200 AMD QAPs have been crafted by Calvin Consulting Group Ltd., a seasoned expert since 2007.
Get in touch with Calvin Consulting Group Ltd. Barry can assist you with AMD QAP and audit needs. Reach him at:
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Explore air quality audits, from the basics of compliance to mastering the process.
Learn how to PREPARE stations, AUDIT calibration systems, and HANDLE failures. Explore the role of quick corrective action and other response strategies. Learn also about data handling, follow-up audits, and third-party reviews. This guide will help you manage air quality better.
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