Is your CEMS and/or COMS QA/QC Manual up to date?
A key component of owning a Continuous Emissions Monitoring System (CEMS) and/or Continuous Opacity Monitoring System (COMS), and something often overlooked, is the QA/QC Manual required by the Federal Regulations. Often a new system is purchased, and a manual is not included, or a manual has gotten very old and out of date (maybe it was not updated when an upgrade or equipment replacement was done).
In this article we will outline the requirement from the regs and discuss the elements a good QA/QC Manual typically includes. In many cases the original equipment supplier addresses and supplies the QA/QC Manual as it includes a great many specific and technical details about the equipment itself. Plant personnel can also develop a QA/QC Manual, but it would most likely require a lot of input from the supplier/manufacturer to include all the proper details, and a firm understanding of the regs.
Where is the Requirement in the Regulations?
For Continuous Emissions Monitoring System (CEMS) the QA/QC Manual is called out in 40 CFR Part 60 Appendix F. Here is an excerpt taken from that document describing the requirement:
Appendix F to Part 60 - Quality Assurance Procedures
Procedure 1. Quality Assurance Requirements for Gas Continuous Emission Monitoring Systems Used for Compliance Determination
3. QC Requirements
Each source owner or operator must develop and implement a QC program. As a minimum, each QC program must include written procedures which should describe in detail, complete, step-by-step procedures and operations for each of the following activities:
1. Calibration of CEMS.
2. CD determination and adjustment of CEMS.
3. Preventive maintenance of CEMS (including spare parts inventory).
4. Data recording, calculations, and reporting.
5. Accuracy audit procedures including sampling and analysis methods.
6. Program of corrective action for malfunctioning CEMS.
As described in section 5.2 (Author: Section 5.2 details “Excessive Audit Inaccuracy”), whenever excessive inaccuracies occur for two consecutive quarters, the source owner or operator must revise the current written procedures or modify or replace the CEMS to correct the deficiency causing the excessive inaccuracies.
These written procedures must be kept on record and available for inspection by the enforcement agency.
In a following section, the QA/QC Manual is called out again:
9.1 What QA/QC documentation must I have? You are required to keep the written QA/QC procedures on record and available for inspection by us, the State, and/or local enforcement agency for the life of your CEMS or until you are no longer subject to the requirements of this procedure.
For Continuous Opacity Monitoring System (COMS) the QA/QC Manual is called out in 40 CFR Part 60 Appendix F, Procedure 3. Here is an excerpt taken from that document describing the requirement:
Appendix F to Part 60 - Quality Assurance Procedures
Procedure 3—Quality Assurance Requirements for Continuous Opacity Monitoring Systems at Stationary Sources
9.0 What quality control measures are required by this procedure for my COMS?
You must develop and implement a QC program for your COMS. Your QC program must, at a minimum, include written procedures which describe in detail complete step-by-step procedures and operations for the activities in paragraphs (1) through (4):
(1) Procedures for performing drift checks, including both zero and upscale drift and the status indicators check,
(2) Procedures for performing quarterly performance audits,
(3) A means of checking the zero alignment of the COMS, and
(4) A program of corrective action for a malfunctioning COMS. The corrective action must include, at a minimum, the requirements specified in section 10.5.
9.1 What QA/QC documentation must I have? You are required to keep the QA/QC written procedures required in section 9.0 on site and available for inspection by us, the state, and/or local enforcement agencies.
What are the Typical Elements of a QA/QC Manual?
A typical QA/QC Manual can be anywhere from 70 – 100 pages and contains many sections with a lot of detailed information. Here is a breakdown of the typical sections:
- Introduction: this section defines the objective of the manual and a company’s QA/QC policy along with the scope of the plan and document control information. Things like the applicable regulations are called out along with possible references to a facility’s permit.
- Description of Facility and Equipment (CEMS and/or COMS): this section describes the facility and the organization (personnel) and the individuals responsible for carrying out the QA/QC activities included. This is a section that would likely need updating over the course of 10-20 years of equipment life as people move in and out of a company. It also details the equipment including model and serial numbers. It discusses the overall measurement process and the technology involved.
- Quality Assurance Activities: this is the heart of the manual and describes all the QA/QC activities that insure a CEMS or COMS remains a compliance instrument that meets the regulations. It details things like daily calibrations, quarterly audits, and annual testing. It goes into detail on the methods and limits of drift and errors and the timing of each test.
- Quality Control Activities: this section details the actions taken to address issues with the QA activities and also the maintenance activities and schedules. It can include things like training, spare parts inventory and more.
- Data Recording and Reporting: this section outlines the way data is recorded and reported. It details notifications, record keeping and can also include component addition, maintenance, or replacement.
- Glossary of Terms and Acronyms
- Attachments: typically, a copy of each type of report the system generates is included along with any equipment certificates of compliance.
The bottom line:
If you have a compliance system (Continuous Emissions Monitoring System (CEMS) and/or Continuous Opacity Monitoring System (COMS)) make sure to have a QA/QC Manual to go alongside it and check it once every couple of years. And if any changes are made to the system, make sure to update it.
Besides being a requirement of the regulations, it is also a great training tool and documentation for the people who are maintaining the equipment.