Standard Operating Procedure (SOP) for Compliance Monitoring ...

SOP for Compliance Monitoring Using CEMSs
precise. Appropriately, all QA/QC program elements should be incorporated into a facility QA
Manual. An outline for a CEMS QA Manual is provided in Annex 2.
The QA program, which is typically specified in a plant- or source-specific QA Plan, is the basis for
assessing and maintaining the quality of CEMS data. A QA program has the following two distinct
and equally important functions:
1. Assessment of data quality (accuracy and precision)
2. QC, which involves activities used to maintain or improve data quality.
These two functions form a control loop. When the assessment function indicates that data quality is
inadequate, the QC function should be applied until data quality is acceptable. The quality and
quantity of valid data dictate the amount or degree of QC to be used in the monitoring program.
The QA Plan is a valuable tool for the evaluation and improvement of the monitoring system by the
source and regulatory personnel. The QA Plan should provide detailed written descriptions of all
current QC activities. In this plan, the procedures used to set up the QA program should be stated as a
clearly defined set of activities. These activities, or standard operating procedures (SOPs), should also
be incorporated into the QA Plan. SOPs provide monitoring descriptions, company QA policies,
monitoring system QC procedures, audit procedures, and recordkeeping and reporting requirements.
A well-written QA Plan, along with the equipment manufacturer’s operation manuals, provides the
CEMS Owner or Operator with most of the necessary information needed for proper monitor
operation, maintenance, and QC. Additional information, such as the plant personnel’s experience
with the system, should also be incorporated into the QA Plan.
When updates or changes to any activities are necessary, the QA Plan should be revised to reflect
those changes. This plan should be reviewed and revised by the CEMS Owner or Operator when
changes are made to the CEMS procedures (ranging from operation to reporting).
7. Quality Control Requirements
A CEMS will provide valid, reliable data when the system is properly maintained and operated. This
system should be maintained at regular intervals to ensure that it is operating within prescribed limits.
Accordingly, each source Owner or Operator should develop and implement written QC protocols
that describe in detail, complete, step-by-step procedures and operations for each of the following
activities:
• Calibration of the CEMS
• Calibration drift determination and adjustment of the CEMS
• Preventive maintenance of the CEMS, including a spare parts inventory
• Data recording, calculations, and reporting
• Accuracy audit procedures, including sampling and analysis methods
• Program of corrective action for a malfunctioning CEMS.
QC activities are generally performed on a routine basis by the CEMS Operator or are automatically
initiated by the CEMS. In either case, the Operator or some other designated individual should
promptly review the results of all QC checks and take appropriate follow-up actions to correct any
problems. The QA/QC evaluations of CEMS typically include the following:
• Daily checks
− Calibration drift assessment—This type of assessment is used for zero/low-level and
upscale/high-level calibration checks of the monitoring system.
• Periodic checks
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