Correspondence reveals deceit of Evansville’s supposed environmental protection regime

November 17, 2012-by John Blair, valleywatch.net editor

Yesterday we complained that Evansville’s air quality was unhealthy but that the monitor which is supposed to verify particulate air quality was conveniently out of service, supposedly for preventative maintenance. Shortly, after our post the monitor returned to service showing fine particles nearing the level of violation of the 24 hour standard of 35µg/m3. Monitor data is supposed to be near real time at: http://leads.idem.in.gov/cgi-bin/idem/daily_summary.pl

This morning, levels reached a whopping 45.13µg/m3 in the 7 AM hour.

In the post yesterday I promised to post some correspondence between Valley Watch board member, Jean Webb and Director of Evansville’s Department of Sustainability, Energy and Environmental Quality, Dona Bergman. This correspondence shows how that department always has an excuse for high readings of the various monitors in and around Evansville which has come to be a tradition encompassing bi-partisan administrations all the way back to 1980. Then, Evansville EPA director, Joan Shelton always called exceedances of the health based standards, “a glitch in the equipment.”

This is a screen shot showing the near real time data provided by IDEM. Notice that during the period of really high levels that occurred on 11/16 AM are missing and only represented by PMA.

Later, the department claimed monitor bias as reason why ozone levels near Alcoa in Warrick County showed violations of the health based standard for that dangerous chemical.

Now it is the Indiana Department of Environmental Management’s monitor located on Buena Vista near First Avenue that Bergman claims exhibits a “high bias.”

Valley Watch’s purpose is to protect the Public Health and Environment of the lower Ohio RIver Valley. When we discern what we feel is misleading information from government officials, we call that out. In this case, both now and in the past, we feel that government officials at both the local agency and IDEM are not dealing with air quality in this region in a trustful manner, and often offer data, that, if biased, is done to give a false impression that air quality in the Evansville area is better than it actually is.

Correspondence is quoted in its entirety below:

Subject: RE: Evv Air Quality – PM2.5 Good vs Moderate days
From: <jwebb@quality-systems-assist.com>
Date: Thu, August 09, 2012 10:42 pm
To: “Bergman, Dona” <DBergman@evansvillegov.org>
Cc: “Ohning, Derrick” <DOhning@evansvillegov.org>, “Alexandrovich,
Joanne” <JAlexandrovich@vanderburghgov.org>

Dona,

Thanks so much for your reply.
I’m sure I did not invert the numbers.  I opened the archived map for each day and recorded the ones that showed our area in yellow.  I must admitted, that it seemed out of place that in November and December the majority of the days showed the entire eastern United States in the Green, except yellow over our area.
I’m really shocked that bad data could be recorded for so long!  As you can see from my company address, Quality Systems is what I do.  Whether it is Good Manufacturing Practices (cGMPs) in the Pharmaceutical Industry, or ISO 9001 regulations in manufacturing, Quality Systems would have prevented such a situation.
1)  When was the data found to be incorrect?
2)  When was an investigation into the noncompliance initiated?  Who conducted it?
3)  What procedures were found missing, or not followed?
4)  Are personnel adequately trained?
5)  Are the maintenance procedures for the equipment defined and documented?
6)  What calibrations must be performed on the equipment?  At what time intervals?  What standards are used to check the accuracy of the measurements?
Besides Quality Systems, I spent 8 years on a bench doing lab analyses, then another 3 years supervising an analytical lab.  I would welcome a tour or your equipment and to learn more if that could be arranged.
I am particularly concerned about the unreliability of the data since so much depends on it.  I have the American Lung Association app on my iphone  (State of the Air app), and I should be able to check current air quality, but mostly the Particulate data been absent.
Yes, it struck me as unusual when so many days over Evansville were yellow while the rest of the Eastern US was green.  So I believe there was a bias high.  However, I find the current situation of Orange warning days for Ozone, yet Green readings to be equally baffling.  Why such as discrepancy on so many days?  Either forecasting or the readings seem to be in error.
I would very much like an opportunity to the the investigation report and corrective actions for the aberrant readings.  I would like to better understand the situation, and I’m a details persons.  Throw me in a room with reports, procedures, and data, and I’ll get it.
Thanks so Much,
Jean
Jean Webb, QA Specialist
Quality Systems Assist
PO Box 8010, Evansville, IN 47716
812-204-8157
——– Original Message ——–
Subject: Evv Air Quality – PM2.5 Good vs Moderate days
From: “Bergman, Dona” <DBergman@evansvillegov.org>
Date: Wed, August 01, 2012 3:38 pm
To: <jwebb@quality-systems-assist.com>
Cc: “Ohning, Derrick” <DOhning@evansvillegov.org>, “Alexandrovich,
Joanne” <JAlexandrovich@vanderburghgov.org>, “Bergman, Dona”
<DBergman@evansvillegov.org>

Jean,
It was a pleasure talking with you at the July Traveling City Hall last week.  I appreciate your interest in air quality issues and the fact that you take time to study both the health information and monitoring data.
I do have some concerns regarding the community comment on air pollution and strokes you submitted.  The number of days where Evansville reached moderate or “yellow” PM2.5 levels you reported seemed quite high to me, so I requested Dr. Alexandrovich at the Vanderburgh County Health Department to review the data during the same time period (7/23/11 to 7/22/12).
First, it is important to recognize that the AirNow.gov site maps are based on the Evansville Buena Vista (BV) continuous monitor and other continuous monitors around the country.   The data from any of the continuous monitors used in AirNow maps are not final quality assured (1), but are the best data we have available until the Federal Reference Method (filter-based) monitoring data becomes available and has been quality assured, a process that lags behind by weeks to months.
Dr. Alexandrovich tracks the daily data, and by her reckoning counted 221 days when the continuous monitor at BV recorded PM2.5 air quality in the good range, 131 in the moderate range, 2 in the USG range, and 12 days were no data was collected (na).  On the 12 na days, air quality measured at the closest PM2.5 continuous monitor to Evansville at the Baskett site in Henderson County KY, was in the good range.  221 plus 12 = 233, the same number of days you counted as recording moderate PM2.5 air quality. We wonder if you inverted the counts of moderate days with your counts of good days.
We also believe the percent of good PM2.5 days is even better than the 64% (233/366) calculated based on the Buena Vista monitor.  Based on the year observed, actual PM2.5 air quality was in the good range approximately 90% of the time, because for some reason, the continuous monitor at BV has been plagued by technical problems that result in inaccurate measurements of PM2.5.
For much of the period you examined, the data from the BV continuous monitor had a high bias (see for example the chart below).  In fact, quite a bit of the Buena Vista monitor’s data were removed from IDEM’s websites because they were invalidated.   We hope that in the future, the technical issues (many of which are known to the monitoring community) can be resolved.  Currently, the monitor appears to be correctly recording changes in PM2.5 air quality, although the baseline calibration may be too low.
Knowing the Buena Vista monitor has reliability issues, we always check other regional monitors (particularly the Baskett, KY monitor) to help us assess whether the BV monitor is reporting dependably.  Many times, we must use other monitors to make our forecasts.
Using data obtained from U.S. EPA’s AIRNowTech website for the other continuous PM2.5 monitors in the region, we find the number of good days ranged from 324 (93.1%) (Bloomington) to 313 (88.7%) (Paducah), with ZERO days reaching the “Unhealthy for Sensitive Groups” level at any of the other monitors.  We believe that if the Buena Vista monitor had been working properly, it’s percentage of good days would fall in this range of approximately 90%.  That leaves only 10% of days in the moderate range (six times less often than what you presented).  I’ve attached the spreadsheet prepared by Dr. Alexandrovich.
I hope this information is somewhat reassuring to you.  Having said that, there is no such thing as air which is too clean, so we will continue to work to improve air quality and protect public health.
Thank you for your interest and your efforts, please feel free to contact me anytime you have a question, a concern or a suggestion.
Sincerely,
Dona
(1)          From AIRNOW’s website: The air quality data used in these maps and to generate forecasts are collected using either federal reference or equivalent monitoring techniques or techniques approved by the state, local or tribal monitoring agencies. Since the information needed to make maps must be as “real-time” as possible, the data are displayed as soon as practical after the end of each hour. Although some preliminary data quality assessments are performed, the data as such are not fully verified and validated through the quality assurance procedures monitoring organizations use to officially submit and certify data on the EPA AQS(Air Quality System). Therefore, data are used on the AIRNow Web site only for the purpose of reporting the AQI. Information on the AIRNow web site is not used to formulate or support regulation, guidance or any other Agency decision or position.
Dona J. Bergman
Director
Evansville Department of Sustainability, Energy & Environmental Quality (SEEQ)
100 E. Walnut St.  Suite 100
Evansville, IN  47713
ph:  812/435-6145
fx:  812/435-6155
“UBUNTU….I AM BECAUSE YOU ARE”
All you plant and nurture is part of what you are – D. Stone 2009

 

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