Environment and
Sustainable Resource Development
Air Monitoring Directive Questions and Responses
June 20, 2014 AMD Information Webcast
Q#
Question
ESRD Response
1
Please don't overlap public input of too many
chapters at once. Many organizations have to
be consulted in preparing feedback on behalf
of an airshed. Can you wait till after Aug 20th
for Chapter 4 or 9 public feedback?
We are sending out three chapters for review now (Chapters 3, 7 and 8) because they have similar content
and intent and are fairly short in length.
2
For airsheds where their monitoring activities
are influenced by JOSM and AEMERA
planning/ budget reviews, how should these
airsheds deal with the requirements of the
monitoring plan as outlined in Chapter 2?
The requirements of Chapter 2 do not apply to those airsheds operating under the JOSM process and do
not need to submit a monitoring plan (applies to WBEA and LICA). Chapter two states that:
Alberta airsheds must be in compliance with the Planning Chapter of the AMD on or before February 1,
2015 unless written authorization is received from the Director
JOSM airsheds would have this authorization.
3
Will you make this Power point presentation
available?
Yes. Just email [email protected] to request a copy of the slides. Note that this entire webcast
was recorded and is posted online. You can access it from the AMD website.
4
If an Airshed or Industry is the person
responsible, does the new Chapter relieve a
contractor of having a QAP? Do they only
require one if an airshed wants them to have
one?
Any contractors conducting air monitoring or reporting for airsheds or industry need to have a QAP, as
contractors need to comply with the AMD (Chapter 5). The airshed or industry are accountable for the
contractor doing the work on their behalf and therefore should know what is contained in their contractor's
QAP. The industry, airshed and contractor should all have a QAP that reflects the monitoring, reporting and
maintenance activities that THEY conduct, and include reference to any work conducted by a contractor
(including how they will ensure that the contractor complies with the AMD). Industry and airshed QAPs can
reference a contractor's QAP. It is suggested that the requirement for contractors to develop and maintain a
QAP that complies with the AMD be included as part of their contract requirements.
Jun 20, 2014
Chapters 4 and 9 will not be released for 60-day public review until after the review period for chapters 3, 7
and 8 - that is after August 20th.
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© 2014 Government of Alberta
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AMD Questions and Reponses
5
When you say that equipment and software
needs to be validated would that be an
internal or an external validation?
The requirement in the 2006 AMD is to validate any monitoring method that is outside standard methods or
AMD methods, or methods use outside of their intended scope. This adds equipment and software to the
requirement. Equipment or software used outside of their original intended use needs to be validated to
confirm suitability and record the results of the validation. This could be an internal or external validation
(up to person responsible), as long as it is documented and results are recorded.
6
For monitoring activities conducted by
“AESRD/ Regulator” or airshed conducting
monitoring activities on behalf of “AESRD/
Regulator”, will AESRD/ Regulator be
responsible for preparing a QAP and share
the plan with affiliated airsheds or public?
ESRD has a QAP for the monitoring conducted by ESRD (now AEMERA). For monitoring done on behalf
of airsheds, or when airsheds take over monitoring stations from ESRD/AEMERA, the QAP can be
provided to the airshed. A QAP however is not necessarily transferrable and should be unique to the
person responsible doing monitoring/reporting.
7
What is the difference between independent
data validation and annual validation (last
slide)?
The independent validation is final cursory review of validated data by someone independent of both field
operations and primary data validation. The intent of this level of review is not to repeat primary validation
tasks, but rather to assure that data have undergone a final independent QA review and endorsement
before data are submitted.
The annual validation is more of a high level review of the monitoring and validation that occurred
throughout the entire year. This review should include a cursory inspection of annual charts, and basic
statistics including comparisons to historical mean, maximum and minimum values, or review for any
baseline shift than may be more apparent when comparing months. The annual validation can highlight
data issues which were not clear on a monthly basis, and should look at audit results that may have
identified issues after initial submission.
8
What form must the "sign off" on data take? A
copy of a signature on a pdf file? A wet
signature on paper? an email string?
Currently, sign-off on ambient data by airsheds is being done electronically during submission to the CASA
Data Warehouse. For industry, Monthly and Annual Reports currently require sign-off.
The 2014 AMD Reporting Chapter will provide a sign-off/certification form for ambient data validation and
certification. There will also be a report certification form to accompany submitted reports.
9
For the independent data review, how far
removed does one have to be to be
considered as independent from the data?
This is quite vague.
Jun 20, 2014
According to the definition in the Ambient Data Quality Chapter, independent validation means an
assessment of the validated data by someone independent of both field operations and primary data
validation. This independent review of data would need to be done by someone that has the necessary
background and technical ability to perform the review. It needs to be someone that is not involved with the
day to day qa/qc operations. Independent review does not mean a third party needs to be hired.
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AMD Questions and Reponses
10
Recommendation: It would be helpful to
include a definition of what "independent"
means for data reviewers in all pertinent
sections.
If an airshed has a QAP, contractor has QAP,
does industry also need QAP?
A definition is provided in the AMD Chapter 1 (Introduction) and guidance is included in Chapter 6 (Ambient
Data Quality). See comment #9 above.
12
For industry source testing (stack testing)
does the contractor require a QAP?
Yes. Anyone doing monitoring subject to the AMD needs a QAP. Facilities with Continuous Emission
Monitoring Systems (CEMS) must also have a QAP as per the requirements of the Alberta CEMS Code.
Note that the QAP requirements of the CEMS Code are consistent with the QAP requirements of the AMD
Chapter 5, and a single QAP for the CEMS monitoring can satisfy both CEMS Code and AMD QAP
requirements.
13
Airsheds may change contractors, so do both
an Airshed and the contractor need a QAP?
The airshed is required to have a QAP to cover what monitoring and reporting activities the airshed
conducts and may refer to a contractors QAP. Both the original contractor and the new contractor would
require a QAP to cover their aspect of monitoring, reporting and maintenance work. The airshed is
responsible for the contractor's compliance with the AMD, including a QAP that covers all monitoring,
reporting and maintenance activities conducted.
14
At some point will Airsheds and others be
submitting their reports to AEMERA or will
they continue to be sent to ESRD or AER. If
so, will references to ESRD and/or AER be
replaced or adjusted to include AEMERA?
Currently any air quality data or reports related to the AMD are submitted to ESRD or the AER, depending
on the industrial sector. It has yet to be determined if any of the airshed or ambient data or reports will
eventually be submitted to AEMERA. If there is a change in submission of reports or data, the AMD will be
revised accordingly.
15
Still not clear on the difference between
independent and annual data review in the
last slide, if data is reviewed monthly why is
an annual needed or is this just for annual
reports?
These validations are different in that they look at different aspects and timescales of information.The
independent validation is final cursory review of validated data by someone independent of both field
operations and primary data validation. The intent of this level of review is not to repeat primary validation
tasks, but rather to assure that data have undergone a final independent QA review and endorsement
before monthly data are submitted.The annual validation is more of a high level review of the monitoring
and validation that occurred throughout the entire year. This review should include a cursory inspection of
annual charts, and basic statistics including comparisons to historical mean, maximum and minimum
values, or review for any baseline shift than may be more apparent when comparing months. The annual
validation can highlight data issues which were not clear on a monthly basis, and should look at audit
results that may have identified issues after initial submission.
11
Jun 20, 2014
Yes. If the industrial facility is required to monitor or report, subject to an approval, they must have a QAP.
The contents of the QAP will depend on the activities that the industry conducts. Facilities actually carrying
out all the monitoring will need the most detailed QAPs, including Standard Operating Procedures.
Facilities contracting out most of their monitoring and reporting may require a briefer QAP that refers to a
contractors QAP and outlines how they will ensure that the AMD is complied with. Ultimately, the industrial
facility is responsible for contractors meeting the requirements of the AMD.See also comment #4 above.
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AMD Questions and Reponses
16
Where data is prepared by a contractor, must
someone else then submit it to satisfy the
review. Or if the report cover letter contains
the independent reviewers signature - does
that suffice?
Someone other than the person doing the monitoring and initial validation must undertake the independent
validation. However, this does not necessarily require a separate third party organization. For example, an
individual contractor cannot do his/her own independent validation, but another qualified individual at the
consulting firm or the airshed itself can do the independent validation. Yes, the independent reviewer would
provide their signature on the report.
17
The revised AMD appears to be biased
towards regulator and compliance-type
relationships or relationship as part of EPEA
Approval process. How does the revised AMD
deal with regional monitoring plans which are
outside of a regulatory framework?
The 2014 AMD expands from the 1989 and 2006 versions to include both regulated industry and airsheds that is all air monitoring conducted in the province.
In the light of AQMS(national Air Quality
Management System), shouldn't "air zones"
be included as responsible person?
No. Air zones do not actually undertake any monitoring. They are geographic regions for reporting and
summarizing air data from monitoring done at individual sites. Air zones are provincial management units,
not monitoring organizations (like airsheds) or regulated industry.
18
Jun 20, 2014
The AMD does not have specific requirements for regional monitoring plans or assessments, as these
focus on air quality management rather than monitoring and reporting of data. The AMD covers how to
monitor and report at all stations in the province, and ensures that data are of known quality and
comparable from site to site. Regional reports and assessments take the data that is reported from
individual stations and performs analyses and determines trends used for managing air quality.
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