Continuous Emissions Monitoring System Quality Assurance and Quality Control Plan

The document titled “Continuous Emissions Monitoring System Quality Assurance and Quality Control Plan” is a comprehensive guide developed by the University of Colorado. It outlines the procedures and policies to ensure the effective operation and maintenance of Continuous Emissions Monitoring Systems (CEMS) at their Boulder, Colorado facility. Here are the key elements of the document:

1. Introduction: The document begins with an introduction to the purpose and significance of the QA/QC Plan. It mentions that the plan supports the operation of CEMS for measuring NOx and O2 in flue gas, in accordance with EPA requirements and Title 40 Code of Federal Regulations Part 60.
2. Quality Assurance and Control Definitions and Policies: The document defines Quality Assurance (QA) and Quality Control (QC), explaining their roles in ensuring the accuracy and reliability of CEMS data. It emphasizes regular evaluation and control efforts to maintain data quality.
3. Facility and CEMS Description: It provides a detailed description of the University of Colorado’s facility, including the equipment and technologies used in the CEMS. This section covers components like the sample probe, gas conditioners, analyzers, and data acquisition systems.
4. Quality Assurance Activities: This section lists the various QA activities, such as calibration gas audits, Relative Accuracy Test Audits (RATAs), and analyzer summaries. It specifies the frequency of these activities and what they entail.
5. Quality Control Activities: It covers the QC aspects, including training for personnel, maintenance activities, spare parts inventory, and specific procedures for ensuring the quality of CEMS data.
6. Data Recording and Reporting: The document outlines the general requirements for data recording, reporting, and notification processes. This includes component addition, maintenance, or replacement, and how these should be recorded and reported.
7. Glossary and Attachments: A glossary of terms and acronyms is provided for clarity. The document also includes several attachments, such as sample reports and printouts that illustrate the types of data and reporting formats used in the CEMS.
8. Comprehensive Details on Equipment and Procedures: Detailed descriptions and maintenance schedules for various components of the CEMS, such as the sample probe, gas conditioners, umbilical systems, and analyzers, are thoroughly covered.

Overall, the document serves as a detailed guide for maintaining the integrity and accuracy of the Continuous Emissions Monitoring Systems at the University of Colorado, ensuring compliance with environmental regulations and standards.

The “Continuous Emissions Monitoring System Quality Assurance and Quality Control Plan” from the University of Colorado outlines several maintenance recommendations for their CEMS equipment. Here’s an overview of the types of maintenance recommended and their frequency:

1. Daily Maintenance: This includes routine checks to ensure the normal operation of the system. Activities could include visual inspections, checking for any error messages or alerts, and ensuring that the system is operating within the normal range.
2. Weekly Maintenance: These tasks may involve more detailed inspections and minor adjustments or cleaning. It could include checking and cleaning filters, inspecting tubing for leaks or blockages, and verifying calibration gas flows.
3. Monthly Maintenance: Monthly tasks are more comprehensive, potentially including more thorough cleaning of components, replacing parts that are subject to wear and tear, and conducting more detailed system checks to ensure accurate readings.
4. Quarterly Maintenance: This might involve in-depth inspections of the entire system, recalibration of sensors and analyzers, and replacement of parts that have longer service intervals. This is also a time to conduct quality control tests such as Cylinder Gas Audits (CGAs).
5. Semi-Annual and Annual Maintenance: These maintenance activities are typically the most comprehensive. They might include complete system overhauls, detailed inspections of all components, complete recalibrations, and conducting Relative Accuracy Test Audits (RATAs). These are critical for ensuring the long-term reliability and accuracy of the CEMS.
6. Ad Hoc Maintenance: Apart from scheduled maintenance, the plan also recommends ad hoc maintenance in response to system alerts, malfunctions, or deviations from expected performance metrics. This ensures timely resolution of any issues that could affect data quality or system performance.
7. Documentation and Record Keeping: Each maintenance activity, whether routine or unscheduled, should be documented meticulously. This ensures a reliable maintenance history and aids in regulatory compliance.
8. Training and Competence of Maintenance Personnel: The plan emphasizes the importance of having trained and competent personnel carry out maintenance activities, ensuring that the CEMS operates reliably and within compliance requirements.

The specific frequencies and types of maintenance activities can vary depending on the specific equipment, technology, and operational environment of the CEMS. Regular and systematic maintenance is crucial for ensuring the accuracy and reliability of emissions monitoring, thereby maintaining compliance with environmental regulations.

In the “Continuous Emissions Monitoring System Quality Assurance and Quality Control Plan” from the University of Colorado, the document provides a detailed Quality Control Checklist that includes specific daily and quarterly maintenance activities. This checklist is found on page 37 of the document. Here are the key activities outlined:

Daily Quality Control Activities:

1. Check DAS (Data Acquisition System) alarms status.
2. Check analyzer alarms status.
3. Ensure zero value calibration checks have passed and are recorded.
4. Ensure span value calibration checks have passed and are recorded.
5. Verify that calibration gas cylinders have pressures greater than 250psi.
6. Conduct a walk-through audit.
7. Clean or replace filters on analyzers.
8. Clean or inspect the sample conditioner.
9. Replace or clean filters on the probe.
10. Change filters/scrubbers on the air system.
11. Clean the interior of the enclosure/rack.
12. Conduct printer maintenance.

Quarterly Quality Control Activities:

1. Conduct walk-through audits.
2. The other activities listed under the daily activities are to be performed as required.

These activities are essential for ensuring the continuous and accurate functioning of the CEMS at the University of Colorado. The daily activities focus on routine checks and maintenance to prevent any immediate issues, while the quarterly activities include both routine and as-needed maintenance to ensure long-term reliability and accuracy of the system【29†source】.

In the “Continuous Emissions Monitoring System Quality Assurance and Quality Control Plan” from the University of Colorado, specific semi-annual and annual maintenance tasks are outlined on page 10 of the document. These tasks include:

• Semi-Annual Maintenance: Replacement of the peristaltic tubing on both peristaltic pump heads.
• Annual Maintenance: Rebuild of the sample pump.

These maintenance activities are part of the preventative maintenance schedule and are crucial for the proper functioning of the CEMS【35†source】.