F. Annual Auditing Requirements for COMS

Regulatory references:
Appendix F to Part 60 – Procedure 3, Section 10.3 (What are the annual auditing requirements for my COMS?), and Performance Specification 1 (PS-1), of Appendix B.

Pre-Audit Activities:
As you can imagine, this annual check requires you to remove the opacity system from the stack and set it up in a clean environment, mimicking the monitor path length and correct optical alignment of the COMS components. Removing the COMS from the stack or duct is no easy task and probably involves several people and should be scheduled and coordinated carefully.
Some people prefer to perform this check while the stack or duct is out of service to avoid taking or letting downtime become an issue. Other people feel because it is a required QA activity, that any downtime associated with this activity is unavoidable. ESC recommendation is to follow the in-house procedure that has been developed, and hopefully has the approval of the management team at your facility.

Post-Audit Activities:
After completing the optical alignment check, there is a place to check a box and record the date on the Opacity Test record that this check has been performed. [Section 10.4 (3) (i).]

10.3   What are the annual auditing requirements for my COMS?

(1) You must perform the primary zero alignment method under clear path conditions. The COMS must be removed from its installation and set up under clear path conditions. There must be no adjustments to the monitor other than the establishment of the proper monitor path length and correct optical alignment of the COMS components. You must record the COMS response to a clear condition and to the COMS's simulated zero condition as percent opacity corrected to stack exit conditions. For a COMS with automatic zero compensation, you must disconnect or disable the zero compensation mechanism or record the amount of correction applied to the COMS's simulated zero condition. The response difference in percent opacity to the clear path and simulated zero conditions must be recorded as the zero alignment error. You must adjust the COMS's simulated zero device to provide the same response as the clear path condition as specified in paragraph (3) of section 10.0.

(2) As an alternative, monitors capable of allowing the installation of an external zero device may use the device for the zero alignment provided that: (1) The external zero device setting has been established for the monitor path length and recorded for the specific COMS by comparison of the COMS responses to the installed external zero device and to the clear path condition, and (2) the external zero device is demonstrated to be capable of producing a consistent zero response when it is repeatedly (i.e., three consecutive installations and removals prior to conducting the final zero alignment check) installed on the COMS. This can be demonstrated by either the manufacturer's certificate of conformance (MCOC) or actual on-site performance. The external zero device setting must be permanently set at the time of initial zeroing to the clear path zero value and protected when not in use to ensure that the setting equivalent to zero opacity does not change. The external zero device response must be checked and recorded prior to initiating the zero alignment. If the external zero device setting has changed, you must remove the COMS from the stack in order to reset the external zero device. If you employ an external zero device, you must perform the zero alignment audits with the COMS off the stack at least every three years. If the external zero device is adjusted within the three-year period, you must perform the zero alignment with the COMS off the stack no later than three years from the date of adjustment.

Download the pdf document here.

Jon Konings, Senior Regulatory and Reporting Engineer, ESC    Published: 9/9/2016 5:10:39 PM

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