data qa/qc techniques. copyright 2009. vim technologies, inc. all rights reserved. vim’s 10-step...
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Data QA/QC Techniques
Copyright 2009.VIM Technologies, Inc. All Rights Reserved.
VIM’s 10-Step Program To Compliance Success
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Copyright 2009.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
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Copyright 2009.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
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Copyright 2009.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?
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Copyright 2009.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 (Δp probes)
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Copyright 2009.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
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Copyright 2009.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
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Copyright 2009.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?
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Copyright 2009.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?
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Copyright 2009.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 CO2 control chart
• Track all (non-daily) QA events required and performed See QA Status report
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Copyright 2009.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
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Copyright 2009.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
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Copyright 2009.VIM Technologies, Inc. All Rights Reserved.
Resources
• EPA Field Audit Manualhttp://www.epa.gov/airmarkets/emissions/audits.html
• PQA ECMPS Support Website and Blog: http://ecmps.pqa.com/
Client Tool software downloads and tutorials Monitoring Plan, QA/Certification, and Emissions
Reporting Instructions
• Policy Manualhttp://www.epa.gov/airmarkets/emissions/monitoring.html
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