New EPA Quality Assurance Requirements
Posted on July 11, 2014
EPA announced this May, after several years of proposals, new changes regarding NSPS Opacity Monitors. The EPA finalized a new change to Appendix F Part 60. This new change is called Procedure 3, and it requires the implementation of a QC program that describes in detail a complete step-by-step procedure to include:
- Performing daily zero, upscale drift, and status indicator checks. Performing quarterly performance audits that include optical alignment, calibration error, and zero compensation.
- Checking the zero alignment annually which must be done by removing the COMS from the stack and setting it up under “clear stack” conditions with no adjustment other than establishing the proper monitor path length and correct optical alignment, and all of this must be documented.
- Submitting Data Assessment Reports at a frequency specified in the applicable NSPS that contains specified information, including the results of any audit showing that the COMS is out-of-control, the results of the follow-up audit showing it was operating within specifications, and a summary of all corrective actions taken when the COMS was determined out-of-control.
Daily calibrations are being performed already, so there is little change here. Quarterly audits are performed by many facilities but not all. Most facilities do perform quarterly PMs but do not incorporate the new procedure of utilizing a three point error calibration test. They must use attenuators that have been calibrated within the last 12 months, and the calibrations must be documented using the COMS data recording system and included on the DAR.
The new annual requirements are going to affect most facilities. Currently, some facilities do not perform annual off stack calibrations at all or believe they only need to be performed every five years. The new requirement states that it must be done annually unless there is an external calibration jig. If there is a calibration jig, they can perform the off stack every three years. Another new requirement is for the facility to document the zero reading, disable the auto compensation, and record that reading as well. The unit is considered out-of-control if there is a four percent error. This could catch a lot of facilities off guard, so they should have their QA/QC reviewed and updated to conform to the new regulations. Environmental 360 strongly recommends facilities to perform a certified quarterly audit as well as an off stack annually that includes recalibrating the calibration jig. Contact Rick Joyner for more information and to schedule your audit.
For more information on this new change, visit http://www.gpo.gov/fdsys/pkg/FR-2014-05-16/pdf/2014-11226.pdf.
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