Transcript TEI VIM-DAS TRAINING UNLOCKING THE CEMS DOOR

Data QA/QC Techniques
VIM’s 10-Step Program
To Compliance Success
Copyright 2009.
VIM Technologies, Inc. All Rights Reserved.
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Step 1
Identify Compliance Parameters
• Determine compliance averages:
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NSPS, Permit, Local District Rules, Part 75, etc.
• Define operating conditions:
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Is it in the permit?
SU/SD – duration, mode change, fuel type
• Define (and document!!) compliance averages:
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How to calculate a valid hour, 3-hr roll, 24-hr, etc.
See example provided in handout
Copyright 2009.
VIM Technologies, Inc. All Rights Reserved.
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Step 2
Review emissions data
• Print out automatically each morning
• Configure and review the following types:
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Hourly operational data (raw and calculated)
Hourly compliance data (downtime and EE)
Daily calibration
• Verify values fall within acceptable ranges
for source type
• Verify operating conditions
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VIM Technologies, Inc. All Rights Reserved.
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Step 3
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Track and Triage Alarms
Eliminate nuisance alarms!
Do alarms show a pattern of systemic trouble?
(i.e., does analyzer x fail the cal check every
morning?)
Is a trouble alarm issued every night on
component y?
Does the startup cal check always fail?
Copyright 2009.
VIM Technologies, Inc. All Rights Reserved.
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Step 4
Identify and Perform Ongoing QA Testing
• Fuel analysis and sampling
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Part 60 vs. Part 75 vs. Custom Fuel Schedules
• Fuel meter tests (P75)
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Primary element, flow meter accuracy and transmitters
• CEM related tests
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RATA, Linearity, CGAs, Flow to Load
Part 60 vs. Part 75 (see handout)
Flow probe leak checks (Δp probes)
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VIM Technologies, Inc. All Rights Reserved.
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Step 5
Schedule and Perform Hardware Preventive
Maintenance
• Develop a schedule based on manufacturer’s
recommendations (modify based on experience)
• Record the schedule in the QA Plan
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Along with Spare Parts list!
• Implement the schedule as developed
• Follow EPA’s Recertification and Diagnostic Testing
Policy
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VIM Technologies, Inc. All Rights Reserved.
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Step 5, continued
• Be sure you’ve covered these maintenance
activities (if appropriate for your installation):
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Opacity 3-filter checks
Analyzer zero checks
Calibration & sample line cleaning
• Have a procedure in place for managing the gas
cylinders and the certification sheets
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VIM Technologies, Inc. All Rights Reserved.
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Step 6
Generate and Evaluate Part 75 Reports
• Does data pass the “red face” test
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Do hourly averages and calculations look reasonable?
Do you have data for every hour of operation?
Do you have a cal check for every day of operation?
Does PMA transition properly?
• Can you account for every period of missing data
with a maintenance log entry?
• Have all tests been completed and reported?
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VIM Technologies, Inc. All Rights Reserved.
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Step 7
Generate and Evaluate Part 60 Reports
• Does data pass the “red face” test
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Do hourly averages and calculations look reasonable?
Are all Downtime and EE Events accounted for?
• Can you account for every period of missing data
with a maintenance log entry?
• Were proper notifications made for EE events?
• Do alarm events for excess emissions translate to
an entry on the EER?
Copyright 2009.
VIM Technologies, Inc. All Rights Reserved.
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Step 8
Compliance Tools
• Use DAHS or export data to MS Excel and
graph key reporting elements
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See Trend Analysis and CO2 control chart
• Track all (non-daily) QA events required and
performed
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See QA Status report
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VIM Technologies, Inc. All Rights Reserved.
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Step 9
Submit reports & organize paperwork
• Maintain emission reports, evaluations and
submittal transactions in same place
• Organize and file QA test field sheets
• Confirm submissions took place
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Part 75 – by reviewing the submission log and
the submission receipt (i.e. make sure it’s
loaded on the EPA host!!)
Part 60 – return receipt
Copyright 2009.
VIM Technologies, Inc. All Rights Reserved.
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Step 10
Stay ahead of the curve
• Schedule QA tests to maximize operational
flexibility and minimize monitor downtime
• Watch EPA CAMD’s “what’s new page”
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PQA’s ECMPS Support website – register to get
announcements
• EPA applicability determination index
• Conduct internal audits (using Part 75 field audit
manual)
• Vendor newsletter and announcements
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VIM Technologies, Inc. All Rights Reserved.
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Resources
• EPA Field Audit Manual
http://www.epa.gov/airmarkets/emissions/audits.html
• PQA ECMPS Support Website and Blog:
http://ecmps.pqa.com/
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Client Tool software downloads and tutorials
Monitoring Plan, QA/Certification, and Emissions
Reporting Instructions
• Policy Manual
http://www.epa.gov/airmarkets/emissions/monitoring.html
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VIM Technologies, Inc. All Rights Reserved.
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