Data QA/QC Techniques

Copyright VIM Technologies, Inc. All Rights Reserved. VIM’s 10-Step Program To Compliance Success 2

Copyright VIM Technologies, Inc. All Rights Reserved. Step 1 Identify Compliance Parameters Determine compliance averages:  NSPS, Permit, Local District Rules, Part 75, etc. Define operating conditions:  Is it in the permit?  SU/SD – duration, mode change, fuel type Define (and document!!) compliance averages:  How to calculate a valid hour, 3-hr roll, 24-hr, etc.  See example provided in handout 3

Copyright VIM Technologies, Inc. All Rights Reserved. Step 2 Review emissions data Print out automatically each morning Configure and review the following types:  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 4

Copyright VIM Technologies, Inc. All Rights Reserved. Step 3 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? 5

Copyright VIM Technologies, Inc. All Rights Reserved. Step 4 Identify and Perform Ongoing QA Testing Fuel analysis and sampling  Part 60 vs. Part 75 vs. Custom Fuel Schedules Fuel meter tests (P75)  Primary element, flow meter accuracy and transmitters CEM related tests  RATA, Linearity, CGAs, Flow to Load  Part 60 vs. Part 75 (see handout)  Flow probe leak checks ( Δ p probes) 6

Copyright VIM Technologies, Inc. All Rights Reserved. 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  Along with Spare Parts list! Implement the schedule as developed Follow EPA’s Recertification and Diagnostic Testing Policy 7

Copyright VIM Technologies, Inc. All Rights Reserved. Step 5, continued Be sure you’ve covered these maintenance activities (if appropriate for your installation):  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 8

Copyright VIM Technologies, Inc. All Rights Reserved. Step 6 Generate and Evaluate Part 75 Reports Does data pass the “red face” test  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? 9

Copyright VIM Technologies, Inc. All Rights Reserved. Step 7 Generate and Evaluate Part 60 Reports Does data pass the “red face” test  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? 10

Copyright VIM Technologies, Inc. All Rights Reserved. Step 8 Compliance Tools Use DAHS or export data to MS Excel and graph key reporting elements  See Trend Analysis and CO 2 control chart Track all (non-daily) QA events required and performed  See QA Status report 11

Copyright VIM Technologies, Inc. All Rights Reserved. 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  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 12

Copyright VIM Technologies, Inc. All Rights Reserved. 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”  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 13

Copyright VIM Technologies, Inc. All Rights Reserved. Resources EPA Field Audit Manual PQA ECMPS Support Website and Blog:  Client Tool software downloads and tutorials  Monitoring Plan, QA/Certification, and Emissions Reporting Instructions Policy Manual 14