Custom Quality Assurance Quality Control Plan

CEMS Experts offers its expertise in the development and maintenance of the
Quality Assurance Quality Control Plans (QAQC). This document describes the quality
assurance plan (QAP) for the continuous emissions monitoring systems (CEMS) in
detail.

BACKGROUND
The U.S. Environmental Protection Agency (EPA) developed quality assurance
procedures for CEM systems used to determine compliance. These procedures
were promulgated on June 4, 1987 as Appendix F, and apply to facilities since the
US EPA uses CEM data for compliance determinations. Appendix F requires facilities
to implement a quality control (QC) program to perform the following activities:

Develop a Quality Control Program with written step-by-step procedures
for each of the following CEM tasks:

• Calibration
• Calibration Drift (CD) determination and adjustment
• Preventive maintenance (including a spare parts inventory)
• Data recording, calculations, and reporting
• Accuracy audits
• Corrective actions for malfunctions

Perform daily calibration (“Zero/Span”) drift checks as required by 40 CFR
Part 60.13(d):

• If the daily zero/span calibration drift exceeds twice the applicable
  Performance Specification drift limits for five consecutive days, or if the drift
  exceeds four times the applicable performance specification drift limits in a
  single daily drift check, the CEM (analyzer or channel, as appropriate), is “out-
  of-control”. An out-of-control CEM must be repaired immediately and the
  calibration drift check must then be repeated.
• CEM data acquired during an out-of-control period cannot be used in
  emissions compliance determinations nor can they be counted toward
  meeting the requirements for minimum data availability.

Conduct quarterly accuracy audits that include the following criteria and
actions:

• Conduct a relative accuracy test audit (RATA) at least once per year using
  relative accuracy test procedures contained in Performance Specifications 2,
  3 and 4.
• Conduct cylinder gas audits (CGA) or relative accuracy audits (RAA) for the
  remaining three calendar quarters. (The GK Associates CEM system permits
  injection of calibration gases; therefore, a CGA will be conducted.)
• If the NOx RATA result exceeds 20% (10% for CO) of the reference
  method mean (or 5% of the applicable emissions standard, whichever is less
  restrictive), the CEM is out-of-control, and should be repaired immediately. If
  the CGA accuracy exceeds 15%, the CEM is out-of-control.
• Corrective actions must be taken when the CEM is found to be out-of-
  control. The out-of-control state is ended only after a subsequent accuracy
  audit of the same type as the initial one indicates acceptable accuracy (e.g.,
  an out-of-control period instigated by a failed CGA is ended by passing a
  subsequent CGA).
• CEM data acquired during an out-of-control period cannot be used in
  emissions compliance determinations nor can they be counted toward
  meeting the requirements for minimum data availability.

Submit QA Data Reports as Follows:

• Quarterly accuracy audit data must be submitted to the US EPA and to EPA
  Region IX in a quarterly emissions compliance report. The quarterly report
  must contain source and CEM identification information, as well as accuracy
  data, periods when any CEM was out-of-control due to excessive calibration
  drift or inaccuracy, and corrective actions taken.