Part 60 (P60) – Lessons Learned from Jon Konings at ESC -
Section B: Reviewing Monthly QA and Hourly Emission Files
These recommendations have no origin in the regulations. In today’s air emission monitoring world, CEM operators usually have only 30 days at the end of a calendar quarter to prepare and submit several different sets of reports to their local, state and federal agencies.
There is nothing to prevent a CEM system operator from time to time during the calendar quarter (say monthly) to review the existing emission reports and begin preparing those quarterly reports. By breaking up the calendar quarter into smaller and more manageable pieces, it will make it easier and less stressful at the end of the quarter to compile those final quarterly reports.
1. The first step is to use your in-house procedure for preparing the quarterly reports. This procedure should contain or reflect the understanding your company has regarding the expectations for acceptable results for the Quality Assurance (QA) checks and tests.
2. Be aware that some states might require the quarterly QA checks to be performed even if your unit operated or combusted a fuel for only one hour, or a similar short period of time.
3. Be aware that some states might expect a quarterly NDFA (Neutral Density Filter Audit) to be performed on your COMS (Continuous Opacity Monitoring System) even if the unit did not operate at all during a calendar quarter.
4. The second step is to evaluate the QA records for your unit first. These are the records of the data and results from either a Cylinder Gas Audits (CGA) or the NDFA. The results of these checks can cause “out of control” (OOC) periods, which triggers downtime for these monitoring systems.
5. For the month (or period of time you are going to review), look over the daily operating reports (see tip A earlier in this document), looking for any error messages associated with these report. Also, look at the data values. Do they look normal or typical? Besides using these reports, sometimes looking at a graph in SV of load (MWs or steam flow), concentrations of NOx, CO2, SO2 or flow rates can be helpful. If similar operating conditions (load or steam flow) are roughly duplicated, then roughly the same emission concentrations and readings should be recorded.
6. Breaking up the calendar quarter into smaller pieces makes it much easier to manage and less stressful at the end of the quarter.
Download the pdf document here.
Jon Konings, Senior Regulatory and Reporting Engineer, ESC Published: 9/25/2016 5:10:39 PM
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