QAQC
Custom Quality Assurance Quality Control Plan
GK Associates 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.
QAQC
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