APPENDIX B 

Guidelines for Rule 218 

Continuous Emission Monitoring System 

~uali'ty Assurance and Quality Control Plan 

TABLE OF CONTENTS 

Title Page 

I . INTRODUCTION ........................................................................ C-4 

n . OVERVIEW . ........................................................................ c-5 

I11 . QUALITY ASSURANCEIQUALITY CONTROL PROGRAM .................. C-7 

IV . QAQC . A WNTTEN PLAN ...................................................... C-9 

INTRODUCTION ................................................................ C-10 

QUALITY ASSURANCE QUALITY CONTROL OVERVIEW .......... C-12 

ORGANIZATION AND PERSONNEL RESPONSIBILITY .................. C-12 

CONTINUOUS EMISSION MONITORING SYSTEM DESCRIPTION .... C-16 

DATA HANDLING. VALIDATION AND REPORTING .................. C-16 

OPERATION AND MAINTENANCE PROGRAM ........................... C-1. 7 

QUALITY ASSURANCE AUDITS AND QUALITY CONTROL 

ACTIVITIES ..................................................................... C-22 

RECORDKEEPING AND REPORTING REQUIREMENTS ................... C-25 

CORRECTIVE ACTIONS ....................................................... C-31 

V . LIST OF REFERENCES AND SOURCE MATERIALS ............................ C-33 

VI . ATTACHMENTS .......................................................................... C-33 

ATTACHMENT A . REQUIREMENTS FOR RULE 21 8 CEMS 

CERTIFICATION TESTING 

ATTACHMENT B . SUPPLEMENT FOR CEMS CERTIFICATION TESTING 

ATTACHMENT C . NO2 TO NO CONVERSION TEST PROCEDURE 

ATTACHMENT D . ANALYZER ENVIRONMENTAL ENCLOSURE 

ATTACHMENT E . FUEL FLOW MONITORS RELATIVE ACCURACY TEST 
Guidelines for Rule 21 8 CEMS QAQC Plan 

LIST OF TABLE AND FIGURES 

Table 1 - RESPONSIBILITIES OF LEVELS I, 11, AND I11 

IN A SOLRCE QAQC PROGRAM ......................... C-14 

. . 

Figure 1 - RULE 2 1 8CEMS 

QUALITY ASSURANCEIQUALITY CONTROL PLAN 

(SAMPLE OUTLINE) ............................................ C-1 1 

Figure 2 - CEMS QAQC PROGRAM 

PARTICIPANTS & RESPONSIBILITIES 

(SAMPLE) ........................................................ C- 15 

Figure 3 - CEMS TROUBLE REPORTIWORK REQUEST FORM 

(SAMPLE FORM) ............................................. .C-20 

Figure 4 - QAQC PROGRAM 

CEMS MAINTENANCE TIMETABLE 

(SAMPLE ) .................................................... .C-21 

Figure 5 - CEMS LOGBOOK 

(SAMPLE) ....................................................... C-26 

Figure 6 - CEMS PROBLEM COMMUNICATION MEMO 

(SAMPLE) ....................................................... C-27 

Figure 7 - PRECISION CALCULATION FORM 

Figure 8 - DATA ASSESSMENT REPORT PAR) 

(SAMPLE FORM) ............................................ C-30 

Figure 9 - CEMS QNQC ACTIVITIES ON PRECISION & ACCURACY 

(SAMPLE FORM) ........................................... .C-32 
Guidelines for Rule 218 CEMS QAQC Plan 

The primary objective of a Quality Assurance (QA) program for a Continuous 

Emission Monitoring System (CEMS) is to ensure that all data collected and 

reported are meaningful, precise and accurate within a stated acceptance criteria. 

The program should be strong, but flexible enough to allow continuing evaluation 

of its adequacy and effectiveness. Once a quality assurancelquality control plan is 

written and implemented, assessment procedures will evaluate the plan's 

effectiveness and may result in revisions to the plan. This assessment provides an 

on-going corrective action system. 

Rule 2 1 8 - "Continuous Emission Monitoring" (R2 1 8) provides an option to the 

facility to comply with either the requirements of Rule 21 8.1 - "Continuous 

Emission Monitoring Performance Specifications" (R2 1 8.1) or the requirements 

of 40CFR60, Appendices B and F. R218 requires the CEMS owner or operator to 

prepare, submit and have approved by the District, a Quality AssuranceIQuality 

Control Plan (QAQCP). The QAQCP is intended to ensure that the quality of 

R218 CEMS generated data is known and is adequate for accurately quantifying, 

recording and reporting volumetric flow, pollutant concentration andlor mass 

emission rates, as applicable. 

This document was developed to provide guidance to R218 facilities in preparing 

and developing the required QAQC plan for the certification, operation, 

assessment and corrective action for R218 CEMS. CEMS certification is 

included since it is considered to be the first quality assurance activity for any 

CEMS. The certification is intended to provide a high degree of assurance that 

the installed CEMS is capable of producing data of sufficient quality for the -- .. . bbg 

practice. Once the CEMS is certified, the facility must maintain good data quality 

through proper QAJQC program. An assessment is performed on how well the 

quality control (QC) program is working to maintain data of known and adequate 

quality. QAQC functions are performed to enable the source to determine the 

precision and accuracy of an installed CEMS. This may involve a simple walkthrough check, observing gauges, valves, temperature settings, etc. or it may 

involve a complete relative accuracy check. Performing each activity enables the 

facility owner to evaluate the CEMS performance, and, if need be, perform a 

higher level of QAQC checks if deficiencies are noted. If QC is not working to 

expectation, corrective actions or measures that are to be accomplished must be 

identified for implementation, both to bring a situation under control and to better 

assure that the situation will not occur again. 
Guidelines for Rule 21 8 CEMS QAQC Plan 

Consequently, a QAQC plan describes the activities to be used in assessing the 

validity of installed, certified CEMS. An essential underlying principle of the 

implementation of the QAQC is that it must provide procedures to identifl, 

prevent and correct situations that would adversely affect the quality and validity 

of the CEMS data. Further, it will address steps to modifl those procedures when 

they fail to accomplish their intended purpose. Two facilities may achieve quality 

data in different ways. One may choose to implement a preventative maintenance 

program that stresses frequent change of a sensor with a new (or re-calibrated) 

sensor and have spot audits of the system. Another may choose to leave sensors 

in longer and have frequent calibration checks of all units. The key is that both 

must have "trigger limits" and procedures in place to, as mentioned above, both 

correct a data quality problem and modifl the QC to prevent problem from 

reoccurring in the future. 

11. OVERVIEW 

Quality assurance is a system for integrating the quality planning, assessment and 

improvement efforts or corrective actions to prove that operations are within 

desired requirements. Quality control is the system of activities designed and 

implemented to provide continuous quality data. Hence, quality assurance can be 

further defined as the system of activities to provide assurance that the quality 

control system is performing adequately. 

QAQC activities involve both routine and periodic evaluation. Historically, these 

activities have been performed by subject facilities as part of their own quality 

assurance program. CEMS QAQC activities vary from source to source. It is 

within a set of certification tests that the CEMS must pass minimum criteria 

o+a~M&+FdeFfo~-&-d&~. A 9, ME?-- 

requirements for Rule 2 18 CEMS certification tests. These initial tests evaluate 

the performance characteristics of the installed CEMS to standard reference 

methods. It is the intended purpose of these certification tests to ensure reliable 

operation of a CEMS once it was installed on the source. The certification 

requirements in R2 1 8.1 provide information concerning the operation of the 

CEMS as compared to the reference method. As such, the certification test was a 

quality assessment check of the CEMS. Likewise, the certification testing 

provided the operator or owner of the CEMS a means of evaluating the system to 

determine its applicability to that specific source and conditions. Under R218.1 

QA provisions, continued periodic quality checks of the CEMS after certification 

is required of the CEMS to be considered "certified". 
. - 

Guidelines for Rule 218 CEMS QAQC Plan 

The intent of R218.1. QA provisions is to require owners of CEMS to evaluate 

periodically the CEMS precision and accuracy. The rule requires the CEMS 

owner or operator to develop and implement a quality control program that 

includes written procedures for key 'CEMS operations and to perform a periodic 

accuracy assessment of the CEMS. The CEMS data accuracy is determined by a 

relative accuracy test audit (RATA), using reference methods (RM) as specified in 

Section 4.0 of Attachment A to this document or in Table 1 of R218.1 

Likewise, R218.1 QA requirement was designed to assess CEMS data precision 

and accuracy on an established frequency. If, through the audit evaluation, the 

data becomes questionable, then increased quality control checks are required to 

be performed on the CEMS until data quality improves to within acceptable 

limits. Consequently, the responsibility of maintaining the CEMS within an 

acceptable range is solely upon the responsibility of the regulated facility. 

Quality control involves "those activities which will provide a quality product." 

R218 is addressing this by requiring sources to develop and implement a source 

specific CEMS QAQC program. The objective of a source QAQC is to delineate 

the activities necessary to ensure that CEMS data are complete, representative, 

precise and accurate. The QAQC provides the framework for implementing 

quality assurance and quality control activities. QC procedures ensures that the 

data required is precise and accurate within established limits and if found outside 

those limits, provider, procedures for corrective action to bring the system back 

within limits. Those activities that should be addressed in the QAQC program are: 

Calibration techniquelfiequency; 

Calibration drift determination and adjustment procedures; -- -- - -- - - ---9----Preventi-ve-maintenance procedures; - 

Data recording and reporting procedures; and 

Program of corrective action for malfimctions or system failures. 

The QAQC outlines the QA program using an orderly assembly of management 

policies, objectives, principles and general procedures for producing data of 

acceptable quality. Within this QAQC, there may also be one or more quality 

assurance project, an orderly assembly of detailed and specific procedures by 

which a facility delineates how it produces quality data for a specific item (i.e., 

calibration and relative accuracy tests for low level pollutant concentration). 

Facilities are required to take reasonable steps to monitor and assure 

i.mplementation of such specific guidelines. Such reasonable steps may include 
Guidelines for Rule 218 CEMS QAQC Plan 

periodic audits, issuance of periodic reminders, implementing training classes, 

and other appropriate measures. Steps that a CEMS owner or operator commits to 

take to monitor and assure implementation of the specific guidelines are to be set 

forth in the written plan which constitute binding requirements under the written 

plan. 

111. OUALITY ASSURANCEIOUALITY CONTROL PROGRAM 

As stated in the earlier section, the primary objective of a CEMS QAQC program 

is to ensure that all data collected and reported are meaningful, precise and 

accurate within a stated acceptance criteria. The program should be strong 

enough to ensure strict adherence to all established procedural requirements, but 

flexible enough to allow continuing evaluation of its adequacy and effectiveness. 

The objectives, therefore, of a CEMS QAQC program are to: 

Provide routine performance of personnel and/or equipment; 

Provide for prompt detection and correction of conditions that contribute to 

the collection of poor or invalid quality data; and 

Collect and supply information necessary to describe the quality of the data. 

To accomplish the above objectives, a QAQC plan should be developed ,and 

implemented to contain the following components: 

Routine training andfor evaluation of operators; 

Routine monitoring of the variables and/or parameters which may have a 

significant effect on data quality; 

Development of techniques to detect defects; - .- - - -- - - - - - - - --- * -- -Developmentofmethods written-proceduresto-qualifyb; and--- -- - - - -- - - -- - 

Action strategies to increase the level of precision in the reported data andfor 

to detect equipment defects or degradation. 

The development of a QAQC program deals not only with daily zerolspan checks, 

annual audit techniques on precision/accuracy, but also involves the development 

and implementation of four (4) general categories. They are: 

Management -The first step in developing a QAQC program is the 

development of a written policy stating the objectives of QA as part of the 

management effort. In addition, administrative procedures applicable to all 

measurement systems must be developed. QA reports addressing data 

quality of each CEMS should be routinely summarized for internal 
Guidelines for Rule 21 8 CEMS QAQC Plan 

distribution by the QA coordinator. Cost related items should be reviewed 

and changes made to obtain high quality data for the least cost. 

Measurement - the second QAQC program development step is the 

preparation of a QA document that illustrates step-by-step procedures for 

CEMS start-up and calibration, internal CEMS QA checks (daily, weekly, 

monthly, etc.), performance audits, system audits, calibration standards 

certification, data validation, maintenance (non-routine and scheduled) and 

intra-laboratory quality assessment activities. 

Documentation - a document control system should be an integral part of the 

QAQC. This involves proper identification and noted revisions of all 

quality assurance documents associated with the CEMS. All log books 

should be numbered and identified as part of the document control system. 

Users should maintain log books to document all QAQC activities 

associated with the CEMS. 

The document control system should maintain records on all monitoring 

equipment (manufacturer's serial number, location), spare parts inventory, 

all components and their status (repair shop, manufacturer or discarded) and 

QA audit standards (expiredlrecertified date). A document distribution 

system should be established in order to provide the latest written 

procedures to all concerned personnel. 

Statistics - data reduction and calculation are necessary to express the data in 

units of applicable standard. Statistics are essential to any adequate quality 

assurance program because they provide information concerning CEMS 

performance (short and long term) and data validity. Corrective action 

- - - - -- -- - -- - - -- - - begins with sta~iStical-evaluation, -- -. - ----- - - -- --- 

From the statistical evaluation of the CEMS data, charts can be developed. 

These charts are used to detect long-term trends and establish the control 

chart so that future data values can be plotted to detect any significant 

changes from past performance. 

A source specific QAQC program can be divided into two major functional 

groups: Quality Assurance and Quality Control. Quality control has historically 

been defined as "those activities which will provide a quality product", whereas 

quality assurance is "the system of activities to provide assurance that the quality 

control program is performing adequately." Quality control involves routine 
--- 

Guidelines for Rule 218 CEMS QAQC Plan 

checks included in normal internal procedures. Quality assurance may be viewed 

as "external" quality control involving system audits, statistical evaluations and 

other functions which are outside the normal routine functions. 

The purpose of developing and implementing a CEMS QAQC is: (1) to assure 

acceptable precise CEMS data quality, and (2) to assure acceptable CEMS data 

recovery and system operating availability. QAQC requirements not only define 

data precision, accuracy, and system availability goals, but also specify that 

comprehensive operation and maintenance (O&M) program, and, QA audits and 

measurements to be conducted. . A QC program defining CEMS calibration, 

maintenance, and corrective action must also be developed. The requirements 

further stipulate corrective action and alternative measurement methods when the 

QA checks indicate that the CEMS QAQC and availability goals are not achieved 

Documentation of all phases of a company's QAQC is required. Included are all 

QA, QC, O&M, and recordkeeping and reporting activities. The QAQC should 

also address other activities such as certification testing, QAQC organization, and 

personnel responsibilities. A standard operating procedures (SOP) manual 

defining all activities, responsibilities, communication, and documentation 

procedures should be developed to serve as the working reference of the QAQC. 

After a QAQC is written and implemented, procedures within the plan should 

point our necessary corrective action which, in effect, revises the plan. This 

would provide an on-going corrective action system. 

QAQC - A WRITTEN PLAN 

A written QAQC plan is necessary to implement quality assurance in a consistent 

and logical manner and identify problem areas. The plan is a living document that 

must be continually updated as often as needed and the updated or revised 

portions are to be submitted to the District for review and approval. It should be 

readily accessible, available and current. The plan must have the following 

information on the cover for identification: 

Document Title 

Source Test ID Number 

Facility Name, ID Number and Address 

Name of Designated Representative, Title and Telephone Number 

Plan Coverage 

Approval Date 

Revision Date 
-. 

Guidelines for Rule 218 CEMS QAQC Plan 

At a minimum, the following elements must be addressed in the QAQC: 

Quality assurance policy statement 

Detailed CEMS description 

Organization and responsibility 

Perso~lnel qualifications and training 

Document control 

Data quality objectives 

Certification requirements 

Preventive maintenance procedures and schedules 

Calibration of monitors and sensors with procedures and schedules 

Data recording, calculations and reporting procedure 

Data validation procedures 

Data quality assessment procedures and specifications 

Corrective action to be taken 

Quality reports to management 

As discussed earlier, a CEMS QAQC program involves a written document 

containing all aspects of the CEMS program. It defines organization and 

responsibility, QAQC activities, maintenance and corrective action procedures 

and other activities associated with the complete CEMS program. 

A typical outline of a document addressing aspects of CEMS QAQC is illustrated 

in Figure 1 and the sections are briefly discussed below. 

1.0 Introduction 

The introduction contains language affirming corporate policy to operate and 

maintain its facilities in strict adherence to all applicable environmental rules and 

regulations. Likewise, a commitment to obtaining all data to demonstrate 

necessary activities dealing with the CEMS are being performed to ensure that all 

emission measurements are of high quality. 

The written plan, in addition to a list of distribution, also contains a document 

control indexing system that tracks changes from the original QAQC document to 

subsequent revisions to assure that all staff are using the same and current version 

of a procedure. Each page is labeled an indexing information. The following is an 

example of a document control system: 

SectionNo. 

Date 

Page No. 

Revision No. 

Revision Date 
- - 

Guidelines for Rule 218 CEMS QAQC Plan 

Figure 1 

RULE 21 8 CEMS 

QUALITY ASSURANCEIQUALITY CONTROL PLAN 

(SAMPLE OUTLINE) 

1.0 Introduction 

2.0 Quality Assurance Quality Control Overview 

2.1 Data Quality Objectives 

2.2 Document Control 

2.3 General Facility Description 

2.4 Equipment and Process Description 

3.0 Organization and Personnel Responsibility 

3.1 Organization and Program Management 

3.2 Personnel Qualifications and Responsibilities 

3.3 QAQC Responsibilities 

4.0 Continuous Emission Monitoring System (CEMS) Description 

4.1 General Description and Measurement Principle 

4.2 CEMS Component Descriptions 

5.0 Data Handling, Validation and Reporting 

5.1 Data Handling and Statistical Analysis 

5.2 Control Charts 

5.3 Data Validation Criteria 

5.4 Data Reporting 

5.5 Data Forms 

6.0 Operation and Maintenance Program 

6.1 Routine Maintenance 

6.2 Preventive Maintenance 

6.3 Spare Parts Inventory 

6.4 Maintenance Documentation 

7.0 Quality Assurance Audits 

7.1 . Daily Calibration Test 

7.2 Relative Accuracy Test Audits 

7.3 System Bias Test 

7.4 Other Quality Assurance Audit Activities 

8.0 Recordkeeping and Reporting Requirements 

8.1 Quality Reports to Management 

9.0 Corrective Actions 

9.1 Periods of CEMS Failure 
Guidelines for Rule 21 8 CEMS QAQC Plan 

( .,-. 

2.0 Oualitv Assurance and Qualitv Control Overview 

Provide a quality assurance policy statement including the purpose and coverage 

of the QAQC. The QA policy statement sets the framework within which the 

QAQC program is developed and implemented. It must emphasize the 

requirements and activities needed to ensure that all data obtained are of known 

quality. 

Data quality objectives show what needs to be accomplished in order to achieve 

good and acceptable quality data. To administer QAQC program, the following 

data quality objectives must be written and available to all individuals involved in 

the activities that affect the quality of the data. Data quality objectives must be 

sufficient to meet the completeness, accuracy, precision and timeliness 

requirements of Rule 2 1 8. 

Completeness - Data is considered to be complete if the percent valid data 

acquisition requirement is met. 

Precision - The difference between the measured value and the measured 

average must be minimal. 

Accuracy - Data must be unbiased, where there is minimal difference 

between the true value and the measured average. 

Comparability - To compare data, all data should be corrected to the same 

standard conditions of temperature and pressure and should be in consistent 

units. 

Representativeness - The data must be representative of the operating 

conditions including load, time-of operation, and fuel and process materials. 

Timeliness - Data should be current and reported in a timely manner. 

Describe the facility and its general operation. List the sources and CEMS 

covered by this QAQC, including the specific description of the process, the basic 

equipment and control (as applicable) being served by the each CEMS, 

identifying each CEMS associated with each source, including District device 

number. Also provide a map of the facility showing the location of sources, 

location of all monitors and sensors that are a part of the CEMS. 

3.0 Organization and Personnel Responsibility 

The facility QAQC provides an overview of the overall management and 

operational organization for CEMS operation. The personnel responsible for 

managing the CEMS program including those responsible for quality assurance 

coordination should be identified in the plan. Designate a representative who has 
-. 

Guidelines for Rule 218 CEMS QAQC Plan 

authority and responsibility to ensure that the data submitted to the District is 

accurate and of known quality. However, the authorized representative should not 

be directly involved or related to the maintenance of the monitoring system in 

order to maintain an objective viewpoint. The plan should also speci@ any other 

responsibilities and authority of the quality assurance coordinator. 

Historically, the management of QAQC programs has incorporated, at a 

minimum, three organizational levels. Level I, Manager of Environmental 

Engineering, is responsible for the implementation of and continued support to the 

QAQC program. Company QA policy, administrative support, local assistance, 

development of strategies, system analysis, promulgation of permit requirements 

and interface between source and regulatory agencies are some of the other 

functions of Level I. 

Level 11, Quality Assurance Coordinator, is responsible for the implementation of 

QAQC program. The QA coordinator develops and carries out the QC Programs, 

including statistical procedures and techniques, which will help the facility meet 

Rule requirements. In addition, the QA coordinator schedules and performs nonroutine audits and quarterly audits, evaluates new QA procedures for applicability, 

evaluates data quality and maintains related QC charts and records. It is the QA 

coordinator's responsibility to respond to QC problems and coordinate those 

activities with Level I. In addition, the QA coordinator schedules and performs 

non-routine audits and quarterly audits, evaluates new QA procedures for 

applicability, evaluates data quality and maintains related quality control charts 

and records. It is the QA coordinator's responsibility to respond to quality control 

problems and coordinate those activities with Level I. In addition, the QA 

coordinator prepares periodic reports to summarize elements and this information 

is then submitted to Level I, Manager of Environmental Engineering, for approval 

and distribution. The elements are as follows: 

Reliability of the CEMS and its components; 

Quality of data generated; 

CEMS problem areas; 

Corrective actions taken and their results; and 

Quarterly excess emission reports. 

Level 111 involves the CEM operator who ensures that good quality data is 

obtained from the CEM system. Daily quality assurance zero and span checks 

with associated documentation, preventative maintenance procedures, sample 

collection, and data reporting all fall within the responsibility of the CEM 

operator. 
. . - - . -- . ---- 

Guidelines for Rule 21 8 CEMS QAQC Plan 

i -- Table 2.0 summarizes the quality assurance elements associated with each level of 

responsibility. A key element to the successful implementation of the CEMS 

QAQC plan is the organization of personnel and activities, such that a QAQC 

should also contain a table identifying CEMS program participants, name, title, 

address and telephone number along with responsibilities. An example is given in 

Figure 2. 

Table 1 

RESPONSIBILITIES OF LEVELS I, 11, AND I11 

IN A SOURCE QAQC PROGRAM 

In addition, Standard Operating Procedures (SOP) manual should define all 

QAQC, maintenance, data reduction, documentation (recordkeeping), and 

communication activity responsibilities and identify the personnel (by job 

category and by name) assigned each of these responsibilities. Personnel involved 

in the operation, maintenance, repair (if on site) and calibration of the CEMS must 

be identified along with each person's qualifications, training, experience and 

scope of duties. Training schedules and training needs for each individual should 

also be identified. 

Level I and Level I1 

Supervisor and QA 

Coordinator 

Document 

Control/Revisions; 

QA Policy & Objective; 

Organization; 

Quality Planning; 

Training; 

Quality Cost; 

Interlaboratory Testing; 

Audit Procedures; 

Data Validation ; and 

Quality Reports to 

Management 

If all or part of the operation, maintenance, data quality assessment is contracted 

out, provide a list of individuals involved and their qualifications from the 

contracting company and the training history and the training policy of the 

contracting company. 

I .- 

Level I1 and Level I11 I Level I11 

Supervisor and Operator Operat or 

Corrective Action; and 

Procurement Quality 

Control 

Preventive Maintenance; 

Data Reporting; 

Calibration; and 

Document Control 
i 

b~lidelines for Rule 218 CEMS QAQC Plan 

f 

Figure 2 

CEMS QAQC PROGRAM 

PARTICIPANTS & RESPONSIBILITIES 

(SAMPLE) 

- 

Level 

11 

12 

1, 

111 

112 

111 

Plant Manager 

Plant Operations 

Supervisor 

Environmental 

Engineering 

CEM Supervisor 

CEM-QA Coordinator 

CEM Instrument 

Specialist 

John E. Mission 

Comply Manufacturing Co. 

Diamond Bar, CA 

(909) 396-0000 (ext. 2267) 

Steve Source 

Clean Utility Co. 

Diamond Bar, CA 

(909) 396-0000 (ext. 2243) 

Ram Monitor 

Comply Manufacturing Co. 

Diamond Bar, CA 

(909) 396-0000 (ext. 2229) 

Roy Exact 

Comply Manufacturing Co. 

Diamond Bar, CA 

(909) 396-0000 (ext. 2268) 

Tom Compute 

Comply Manufacturing Co. 

Diamond Bar, CA 

(909) 396-0000 (ext. 2270) - 

Karin W. Process 

Comply Manufacturing Co. 

Diamond Bar, CA 

(909) 396-0000 (ext. 2281) 

Responsible for total plant operation 

Data review & verification 

Maintain compliance status (modify operations if necessary) 

Ensures compliance with environmental regulations 

Directs activities over engineering department, including 

implementation of QA program 

Responsible for all operation & maintenance activities for 

installed CEMs 

Responsible for implementation of the QAS Program 

May also be responsible for Quality Assurance activities 

Responsible for all QA source activities associated with the 

CEM program 

Implements & performs weekly, monthly, & quarterly QA 

checks 

CEMS maintenance &-calibration 

Maintain instrument logs 

Report instrument 
- --- 

Guidelines for Rule 21 8 CEMS QAQC Plan 

A matrix of all personnel and activities associated with each major element of the 

plan (O&M, QAQC, data reduction) should be prepared. Within this matrix, each 

individual activity should have associated documentation and communication 

responsibility defining what information is to be documented, where it will be 

filed, and who must be informed, verbally or in writing, of the results of the 

activity. 

The mechanisms, which initiate each activity, should be identified within the 

matrix as scheduled, as well as within the malfunction mechanisms. The 

frequency of scheduled activities such as preventative maintenance and QA audits 

should be specified. Malfunction initiated activities such as repair maintenance, 

QA audits following maintenance, and operating alternative measurement 

methods should be ordered or requested. The requesting person or organization 

should be specified within the matrix. In addition, flow charts should be 

constructed indicating "flow" of information between individuals within the CEM 

program 

4.0 CEMS Description 

Provide both a description of the CEMS and the measurement principle involved 

for each analyzer. Also, provide a complete detailed description of each major 

component of the CEMS, including the model number and serial number. The 

serial numbers for CEMS equipment will be limited to the major subsystems such 

as: sample interface and conditioning, individual pollutant and diluent analyzers, 

in-stack flow monitors, data acquisition system and chart recorders. Specifically 

not required are serial numbers for transducers associated with fuel flow 

transmitters that are a part of the facility process equipment. The flow transmitter 

serial number itself should be included as part of the CEMS. Furthermore, 

describe the sample probe and its location, the sampling interface, heated sample 

line, condenser , metering systems, data acquisition system and/or chart recorders 

Provide sample calculations and/or algorithm, including all constants and 

parameters. All testing and analytical methods associated with the CEMS data 

generation must be identified and described. 

5.0 Data Handling;, Validation and Reverting, 

The criteria for CEMS invalid data are addressed in Rule 21 8 and are defined in 

relation to two CEMS conditions: system failure and shutdown. Excessive span 

drifts and errors in relative accuracy are cited as causes of CEMS in system failure 

or shutdown. Accordingly, the QAQC should provide for identification of these 

criteria. Many CEMS and data recording systems incorporate aids to data 

validation such as flagging operational parameters, and, CEMS calibrations 

flagged items daily for reasonableness and communicate with the quality 
- ---- ..-- . - - - - - - - - . - - - - - - - - - - - 

Guidelines for Rule 21 8 CEMS QAQC Plan 

assurance coordinator on questionable items. Control charts for CEMS 

calibration should validate CEMS pollutant results and should be checked weekly 

by the QA coordinator. Describe the mechanism that allows any or all of these 

functions, as applicable. 

Describe the procedures used to validate data from CEMS to assure that only data 

of known and acceptable quality remain in the Rule 21 8 data base at the end of 

each reporting quarter and at the end of each reporting year. Include validation of 

the correct use of generating alternative monitoring data and/or data calculations 

in lieu of missing data. Describe the procedure and documentation submittals for 

invalidating data and substitution of valid data alternatives. 

To validate the Data Acquisition System @AS) calculations of results, 10% of the 

first month's strip chart CEMS data should be reviewed and evaluated. If the 

results compare within 3% of the DAS, the DAS should be considered correct. 

On a continuing basis, 5% to 10% of the overall data output of each CEM system 

should be evaluated in this manner. 

Describe how you will record and tabulate all calibration error test data according 

to the month, day, clock-hour and magnitude in ppm, DSCFH and/or percent 

volume, as it applies. Set or program monitors that automatically adjust data to 

the calibrated corrected calibration values (for example, microprocessor control) .. 

to record either the unadjusted concentration or flow rate measured in the 

calibration error test prior to resetting the.calibration , or, the magnitude of any 

adjustment. Record my applicable flow monitor interference check data such as 

sample linelsensing port pluggage. 

6.0 Operation and Maintenance Program 

A comprehensive operation and maintenance (O&M) program coupled with 

routine QA checks are vital elements of a successful CEMS program. They 

provide the necessary documentation to evaluate the precision, accuracy and 

representativeness of the source measurement system. The gathering and 

processing of invalid data is historically coupled with improper operation and/or 

lack of maintenance of CEMS. This, in turn, leads to excessive CEMS downtime. 

Under Rule 218, CEMS availability percentage is 95 percent, as a specified 

minimum valid data capture requirement. Consequently, a well documented 

O&M and QAQC program serves both industry and regulatory agencies. 

The appropriate procedures for O&M and QAQC program are CEMS-specific and 

site-specific. The program should include the following basic elements: 

Documentation of instrument system operating parameters using 

standardized forms and control charts; 

Daily zero and span calibration checks for confirming that the instrument 

calibrations are maintained wihn control limits; 
---- - - - .- - . - - .- - . - - - 

Guidelines for Rule 21 8 CEMS QAQC Plan 

Validation of data reduction process from raw data collection through 

reporting; 

Determination of the accuracy and precision of collected data; 

Performance of quarterly independent audits; and 

Documentation involving CEMS log book for routine entry and 

routinelmajor maintenance entries. 

Appropriate quality assurance checks must be CEMS specific and source specific. 

Documentation should involve a step-by-step approach to the daily quality 

assurance checks with instructions for action to be taken if the appropriate 

response is not obtained. At a minimum, routine quality assurance checks should 

address the following topics: 

Set of procedures for CEMS specific daily zerolspan function; 

Guidance for corrective action; 

Control charts; and 

Documentation involving CEMS log book for routine entry and 

routinelmajor maintenance entries. 

Figure 3 is a sample form illustrating a CEMS trouble reportlwork request. 

The same individual who performs the daily zerolspan checks should be 

responsible for routine adjustments to the CEMS when discrepancies are noted. 

Long-term CEMS performance should determine the appropriate frequency of 

various QC activities. Adequate records must be maintained to document these 

activities. 

6.1 Routine Maintenance 

Periodic checks of the CEMS and its operation are mandatory. Even though a 

system may provide excellent quality data initially, without routine maintenance 

and system checks, the quality of the data will undoubtedly degenerate with time. 

Maintenance checklists are one of the tools management can use to ensure that the 

proper preventive maintenance is being completed. The checklist should provide 

a place to record all settings and indicators of proper operation, indicate the items 

to be checked and provide a place to document repairs and replacement of parts. 

The checklist should list daily, weekly and monthly checks of various 

maintenance items, and it should be CEMS specific because each system will 

require slightly different gauge settings and meter readings for proper operation. 

The proper recording of maintenance items provides a history to correlate outages 

and potential problem areas. Figure 4 illustrates an example of a CEMS QAQC 

maintenance timetable. 
- -. . -- . - . - 

Guidelines for Rule 218 CEMS QAQC Plan 

6.2 Preventive Maintenance 

The maintenance program section of a QAQC plan should contain the following: 

A concise, simplified trouble shooting guide and diagnostic chart to assist 

operators in identifying CEMS problems; 

Established verbal and written lines of communication to assure prompt 

notification . to maintenance, . physical plant and environmental 

management of CEMS operating problems; 

A maintenance request form with routing priority assignment, and job 

completion follow-up and failing to assure management awareness of 

CEMS operational status; 

An on-going training program to ensure that the maintenance staff is 

technically capable of instrument repair; 

Develop a spare parts inventory and stock replenishment program based on 

suppliers' recommendations and available information on likely modes 

of failure; and 

Review major repair and parts supply service available from vendors, parts 

distributors, repair centers, etc. and implement the best available. 

The QAQC must describe the facility CEMS preventive maintenance procedures 

and associated operational inspections. It must provide for an adequate 

maintenance and inspection schedule for all major components of CEMS, 

including but not limited to, monitors and sensors, environmental enclosures, the 

sample acquisition, conditioning and handling system, and the data acquisition 

and recording system. Manufacturer's maintenance specifications alone may not 

be sufficient to assure data quality under Rule 218, and is a part of the over all 

assessment of need. The QAQC should incorporate by reference manufacturer's 

instrument operation and repair manuals if they are used in conjunction with the 

facility QAQC; and such manuals are to be kept on site at all times. Also identify 

how system downtime will be minimized due to maintenance and repair activities. 

CEMS parts that are routinely replaced should be listed. 

The QAQC must include a detailed description of how the calibration of the 

CEMS pollutant and diluent monitors is conducted, including the equipment used 

and schematic flow diagram. (At the facility's option, this may be covered in the 

Data Quality Assessment section of the QAQC.) Any corrections to the CEMS 

zero and/or span settings after a calibration check must be recorded by the system 

in some manner such that the adjustments can be observed through inspection. 
--- . ---- - -. - --- . - - - - - - - - - - - - - - - - 

Guidel~nes for Rule 218 CEMS QAQC Plan 

FIGURE 3 

CEMS Trouble ReportJWork Request Form 

(SAMPLE FORM) 

Level 3 Safetv ? 

(Use Ball Point Pen Press Firmly) 

I Shut Down Area Operations ? I Authorized Signature Date I 

To: Priority TR No. 

Summary . I 

Requestor Name/Sign-off 

Account Number Supv 

Maintenance Signature Date 

Dept. Section Mgr Signature Date 
- - - - . - - --- - - - - - . - - - - - . - . - - . - -- - - - - - - - - - . - 

Guidelines for Rule 21 8 CEMS QAQC Plan 

Figure 4 

QAQC PROGRAM 

CEMS MAINTENANCE TIMETABLE 

(SAMPLE 

Zerolspan check & adjustment 

(internal 

Clean windows; inspect air filters; 

verify operation of motors & blowers 

Zerolfull-scale check of chart 

recorders 

Check optical alignment 

cell 

Daily 

Twice Weekly 

Weekly 

Electronics check (including optical 

path length ratio) 

Opacity calibration with neutral 

density filters 

SO, calibration with certified gas cells 

Operations Supervisor 

& Instrument Foreman 

Instrument S pecialist 

Instrument Specialist 

Weekly 

Corporate Audit 

Opacity audit 

Review plant records 

Additional preventive maintenance 

checks : 

Inspect power supply box mounted 

beiow analyzer 

Check power supplies for correct 

voltages & filtering 

Check CO, detector for correct 

temperature 

Instrument Specialist 

Monthly 

Monthly 

Quarterly 

Orsat analysis (CO,) 

inspect source & analyzer optics 

for dust build up & general 

Instrument Specialist 

Instrument Specialist 

Instrument Specialist 

Quarterly 

Quarterly 

Semi-Annually 

Instrument Specialist 

Assistant Program 

Manager 

Instrument Specialist 

condition 

Certification of SO, gas cells & neutral 

density filters 

QAIQC Plan updates 

Every two Instrument Foreman 

years 

As-needed Assistant Program 

Manager 
.. - - - - -- .- -- - - - . - - - - --- 

Guidelines for Rule 218 CEMS QAQC Plan 

6.3 Spare Parts Inventory 

Provide a list of spare parts and where they are stored. Minor or "wear" parts are 

usually kept in the CEMS station storage and may be retrieved immediately 

whenever necessary. Major parts are normally requested following company 

purchasing procedures if not available in a central warehouse. Generally, spare 

parts are available though CEMS local suppliers or manufacturers. As mentioned 

above, a spare parts inventory and stock replenishment program based on 

suppliers' recommendations and available information on likely modes of failure 

will be very helpful in sustaining CEMS uptime. 

6.4 Maintenance Documentation 

The QAQC should include example forms used in recording maintenance and 

inspection activities. They should be maintained at the facility in an easily 

retrievable and reviewable form, such as in a binder for each CEMS. Also include 

problem communication forms, such as, work order forms, alert forms and 

maintenance request forms. 

Unannounced self inspections and audits of maintenance and repair records and 

activities are one means of assuring that these aspects of the QAQC are being 

implemented. It is highly recommended that such audits be conducted by 

personnel not involved in the daily CEMS operation or the CEMS QC functions. 

7.0 Oualitv Assurance Audits and Qualitv Control Activities 

The data quality assessment activities determine the effectiveness of a QC 

program and provide quantitative information on data quality (accuracy, 

precision, valid data return). They are also the keys upon which the corrective 

action activities are based. The results of data quality assessment must feed back 

into modifying QC andlor QA activities to assure that data quality objectives are 

being met. 

7.1 Quality Assurance Audits 

Quality assurance audits are independent checks made by the auditor to evaluate 

the quality of data generated by the CEMS (sample collection, sample analysis 

and data processing). These audits are performed independent from and in 

addition to normal quality control. 
.. . . . .. . . _ _ _ _ _ ._ ............. . - - . ... . .. . .... -. . 

Guidelines for Rule 218 CEMS QAQC Plan 

7.1.1 Annual Relative Accuracy Test Audit (RATA) 

RATA must be conducted on each CEMS for pollutant concentration, diluent 

concentration, volumetric stack flowrate andor pollutant mass emissions, as 

applicable, annually. Provide the RATA schedule for each monitor, volumetric 

flow measurement systems, and emission rate measurement system. RATA must 

be performed by a testing firm approved by the District Laboratory Approval 

Program (LAP). Submit protocol 30 days prior to the test date. However, as long 

as there are no changes to the equipment, process or testing contractor , the earlier 

protocol may be referenced. RATA results and supporting documents must be 

submitted to the District within 45 days after the test in a written report form. 

Refer to Attachment B - Supplement Requirements for CEMS Certification 

Testing for details on protocol, test and report requirements. 

7.1.2 Cylinder Gas Audit (CGA) 

CGA must be conducted once every quarter, in three of four calendar quarters, but 

in no more that three quarters in succession. 'The procedures and specifications 

must be according to the provisions of 40CFR60, Appendix F 

7.2 Quality Control Activities 

7.2.1 System Bias Test 

A system bias test must be performed annually in conjunction with RATA or at 

time of replacement of specific parts of CEMS as specified in the technical 

guidance document for modifications. 

7.2.2 Daily Calibration Error Test 

Each unit operating day the CEMS must perform a calibration error' test. The 

QAQC must describe how the calibration error test for the monitors will be 

performed, including, but not limited to, the type and concentration of calibration 

gases used and how they are injected, and calculation of the calibration error. It 

must also identify calibration error test procedures specific to the CEMS that 

have multiple ranges, as applicable.. Any differences between these procedures 

and the CEMS calibration procedures need to be identified, as well as those that 
-.-.-- -- - - - - 

Guidelines for Rule 21 8 CEMS QAQC Plan 

might be different fiom the procedures used during certification. If the calibration 

error check is done in conjunction with normal CEMS calibration, the QAQC 

must describe how the calibration error is integrated into any calibration 

adjustments. 

The QAQC must provide a CEMS specific description of how pollutant and 

diluent concentration monitors are designed and equipped for the daily calibration 

error check. The type of system (extractive, dilution type and in-situ) may have a 

bearing on how the calibration error test will be conducted, and this also must be 

addressed in the QAQC. 

7.2.3 NO2 to NO Converter Efficiency Check 

The converter check is to be done at certification and during every RATA, and the 

results submitted to the District. The facility will designate a lower acceptable 

efficiency for their system and a trigger level where corrective action will take 

place in an on-going preventative maintenance program. Describe how the. NOx - 

converter efficiency will be determined. (See Attachment C.) 

7.2.4 halyzer Temperature Stability 

Information that the temperature of the analyzers does not exceed their 

manufacturer's operating specification is required upon certification. This may be 

instrument and environmentally controlled enclosure coolingheating capacity 

versus calculated heat load on a typical hot day or actual higMow temperature 

measurements or other equivalent alternative. The facility will designate the 

preventative maintenance and corrective action steps it will take to ensure 

acceptable "climate control" for the analyzers. 

7.2.5 Sample Conditioning System Exit Gas Temperature Monitoring 

A verification of the effectiveness of the moisture removal system in reducing 

water content of the sample gas to an acceptable level is done at certification. The 

facility will designate the preventative maintenance and corrective action steps it 

will take to identify and correct moisture problems. The facility will also identify 

to what extent the moisture is a potential problem for their analyzers relative to 

interference. 
- . -- - ------ 

Guidelines for Rule 21 8 CEMS QAQC Plan 

7.2.6 Linearity Error Check 

A three-point linearity check is required for initial certification. For the long-term 

assessment of linearity (and indirectly, system bias), the QAQC must address 

linearity error check as required and performed during annual RATA. 

8.0 Recordkeeping and Reporting 

Rule 218 requires that a quarterly report be submitted to the District. Unless 

otherwise specified by permitting or enforcement sections, the report is a 

summary of all CEMS data such as concentration, flow, emission rates (as 

applicable), calculation, shutdown, system failure, calibration, maintenance and 

repair information among others. Activities for each CEMS, including associated 

sensors, must be documented in a logbook using indelible ink. Activities include, 

but are not limited to, preventive maintenance, unusual occurrences, repairs and 

replacements of parts, and failures. Each log must be signed and must include the 

date, the time and a description of the activity. Provide sample pages of the 

logbooks in the QAQC Plan. 

As part of a QAQC program, the following CEMS associated records should be 

maintained: 

e CEMS Logbook - an instrument logbook should be maintained at the CEMS 

site by the Instrument Specialist. All activities related to the CEMS 

(maintenance, calibration, shutdown, etc.) should be recorded on the 

logbook form, as illustrated in Figure 5.. Each entry in the logbook should 

include the date, a brief description of the activity, and the individual's 

initials. If corrective action is needed, then the operator completes a CEMS 

Problem Communication Memo. A sample memo form is in Figure 6. This 

is then submitted to the CEM QA Coordinator or the CEM Supervisor for 

corrective action. The CEM QA Coordinator should maintain these records 

chronologically. This provides documentation on when a problem was first 

detected and the need for corrective action to resolve the problem. It is 

highly recommended that a separate log book be available for use for each 

of the following: calibration standards, laboratory results, excess emissions, 

daily and periodic audits, procurement and maintenancelrepair. 

Calibration Forms - unless automatically or electronically stored, each time 

a calibration is performed the operator completes the Precision Calculation 
-- -- .- - . - . . - - . .- -. - -- - - - -- - - - - - - - . - - - - -- - - 

Guidelines for Rule 218 CEMS QAQC Plan 

Form (refer to Table 8 for a sample of this form). The form documents when 

calibrations are conducted and whether adjustments were made. The 

completed form is submitted to the CEM QA Coordinator who maintains a 

chronological record of the forms. 

a Precision Assessment Forms - an assessment of the CEMS precision is made 

by the CEM QA Coordinator each quarter (refer to Table 9). The precision 

calculations are performed using the form shown in Table 8. The completed 

forms should be maintained by the CEM Supervisor and available for 

review. 

Audit Forms - as discussed earlier, a corporate self-audit should be 

conducted quarterly by the CEM QA Coordinator. Records of the quarterly 

audits should be maintained at the corporate offices by the Assistant 

Program Manager. The audit records would include the accuracy 

calculation forms and any notes or comments about the audit. 

a Strip Charts and Computer Printouts - all information regarding CEMS 

continuous activity are permanently recorded on strip charts andor 

computer data storage. Zero and span calibrations, converter checks, audits, 

adjustments, time and duration of CEMS failure and downtime (or uptime) 

including the measured levels of concentration (andor mass emission rates) 

are some of the information that are recorded and stored that may prove 

invaluable when necessary data are sought. 

Keep copies of written reports received fiom testing firms/laboratories of 

procedures and details specific to the installed CEMS that were to be used by the 

LAP approved testing laboratories for RATA, such as sampling and analysis 

methods. 
- - - - - - - - . . - -- .- -- . - . - -.. 

Guidelines for Rule 218 CEMS QAQC Plan 

Figure 5 

CONTINUOUS EMISSION MONITORING SYSTEM LOGBOOK 

(SAMPLE) 
-- . -- - .- - 

Guidelines for Rule 218 CEMS QAQC Plan 

Figure 6 

CEMS PROBLEM COMMUNICATION MEMO 

(SAMPLE) 

From: 

To: Date: 

Problem Definition and Recommendation 

Signed 

Corrective Action Taken 

Completion Date Signed 
Guidelines for Rule 218 CEMS QAQC Plan 

8.1.1 Quality Reports to Management 

The QAQC will also identify what reports are routinely sent to management 

regarding the quality of the data fiom the CEMS. Such reports are typically 

prepared quarterly. Examples of quality reports are: 

Data Quality Assessment Reports - summarize the precision, accuracy, 

system uptime, percent valid data (refer to Figure 8 for a sample form) 

Performance and System Audit Reports - summarizes the audit and present 

the results to the auditee with recommendations for corrective action 

Data Validation Report - includes the number 'of values flagged as 

questionable, the result of follow-up investigations of these anomalies, the 

final number of data values .rejected or corrected as a result of the 

procedure, corrective action recommended, and effectiveness of the data 

validation procedures 

Quality Cost Report - summarizes costs of prevention, appraisal and 

correction 

Instrument or Equipment Downtime - records equipment performance in 

terms of failures, cause of failures, repair time and total downtime. 

All management reports concerning the quality of CEMS data shall be maintahed 

on site for inspection. Examples of routine reports for the facility must be 

included as attachments to the QAQC. 

8.1.2 CEMS Report to the District 

R218 requires CEMS operators to submit a summary of CEMS data and 

information once every quarter. Refer to R21 Section (0 for CEMS reporting 

requirements. 
,- 

Guldr p for Rule 218 CEMS QAQC Plan 

Figure 7 

PRECISION CALCULATION FORM 

(SAMPLE) 

Period Parameter 

Draft 
for Rule 218 CEMS QAQC Plan i 

Figure 8 

DATA ASSESSMENT REPORT (DAR) 

CONTINUOUS EMISSION MONITORING SYSTEMICEMS) 

(SAMPLE FORM) 

Period Ending Date Year 

General Information 

Co~npany Name Plant Name 

Source Unit No. Monitor Location 

Mon~tor TypeIModel No. Monitor Serial No. 

Quality Assessment 

2.1 Precision ([or each month in quarter) 

2.1.1 Month of Quarter I 2 3 

2.1.2 95 Percent Probability Limit 

2.1.2.1 Upper (UPL) 

2.1.2.2 Lower (LPL) 

Accuracy (fill in either 3.1 or 3.2) 

3.1 Relative Accuracy Audit (RAA) 

3.1.1 Date of Audit 

3.1.2 Reference Method (RM) 

3.1.3 Average RM Value 

3.1.4 Absolute Value of Mean Difference (d I 

3.1.5 Absolute Value of Confidence Coefficient I CC I 

3.1.6 Relative Accuracy (RA), percent 

Audit Point I (low conc.) Audit Point 2 (high conc.) 

3.2 Calibration Error (CE) 

3.2.1 Date of Audit 

3.2.2 Cylinder ID# 

3.2.3 Cylinder Certification Date 

3.2.4 Certification Method 

3.2.5 Cylinder Concentration 

3.2.6 Monitor Response -- 

3.2.7 Difference, percent -- 

Corrective Action 

4.1 Excessive Span Drift 

4.1.1 No. of Times Monitor was "Out-of-Control" 

4.1.2 Corrective Action Taken 

4.1.3 Results of Audit after Corrective Action 

4.2 Excessive Inaccuracy 

4.2.1 Corrective Action Taken 

4.2.2 Results of Audit after Corrective 

Authority 

5.1 Name 5.2 Title 

5.3 Address 

5.4 Telephone No. 

5.5 Signature 
Guidelines for Rule 218 CEMS QAQC Plan 

9.0 Corrective Actions 

Describe the mechanisms to be used when corrective actions are necessary. Activities 

that may initiate corrective action include unacceptable performance and system audits, 

failure to adhere to a QAQC program, and failure to adhere to standard operating 

procedures. Figure 9 is a sample form regarding CEMS QAQC activities, the purpose of 

such activity, the limits and the general corrective action whenever the limits are 

exceeded. 

It is highly recommended to provide a tabulated summary for the last two years of all 

calibration results and other QAQC activities in order to note degradation of component 

performance that may lead to system failure. This information may be used as a basis 

for extending periodic maintenance schedules. 

In addition to the periods of system failures below, define other system failures or outof-control situations and describe what mechanisms are in place to assure that system 

failure situations are addressed in a timely manner. Also, explain how any CEMS 

which is deemed out-of-control or any CEMS system failure will be corrected, retested 

by the appropriate audit procedure, and restored to in-control status within 24 hours 

after being deemed in system failure. It is suggested that if the CEMS is not in control 

at the end of the 24-hour period, explain how concentration or emission data will be 

gathered or calculated. 

9.1 Periods of CEMS Failure 

9.1.1. Daily Calibration Error Check 

A pollutant concentration monitor is in system failure, or out-of-control, when the 

calibration error exceeds 5%, and a diluent concentration monitor is in failure when the 

calibration error exceeds 1.0% absolute. Data substitution is required during periods 

when a system failure occurs. The QAQC shall describe the procedure as to how 

system failure periods will be flagged to the operator, corrected and recorded. In 

addition, performance criteria must be identified such that if system failure periods 

exceed the criteria, then corrective action beyond the adjustment of span or zero will be 

taken. 
Guideline /r Rule 218 CEMS QAQC Plan 1 

I 

I Figure 9 

Relative Accul.acy 

Cylinder as 

Check -1 

(Single Point 

Cylinder Gas 

Check -2 

(Multipoint) 

System Appraisal 

Walkthrough Check 

CEMS QAlQC ACTIVITIES on PRECISION & ACCURACY 

(SAMPLE FORM) 

Assess relative accuracy 

Assess calibration error 

Assess response time 

Assess calibration error 

Assess linearity error 

Assess general condition of gas 

monitoring systems 

. .. 

. ; :< 

... . 

, . 

k 20% 1. CEM O&M group repairs as required. 

2. CEM Data Service evaluates effect on data. 

3. CEM QA group performs repeat audit (RAA) after 

corrective action. 

corrective action. 

k2.5 % 

5 minutes 

1. CEM O&M group repairs as required. 

2. CEM Data Service evaluates effect on data. 

3. CEM QA group performs repeat audit after 

corrective action. 

1. CEM O&M group repairs as required. 

2. CEM Data Services evaluates effect on data. 

3. CEM QA group performs repeat audit after 

+ 2.5% 1. CEM O&M group repairs as required. 

2. CEM Data Services evaluates effect on data. 

3. CEM QA group performs repeat audit after 

NO readily 

corrective action. 

1. CEM QA Coordinator establishes need for & 

apparent . 

problems 

implements appropriate correction action. 

2. CEM QA Coordinator may initiate another 

appropriate audit. 
Guidelines for Rule 21 8 CEMS QAQC Plan 

A pollutant concentration'monitor is out-of-control when the RATA exceeds 20% RA. A 

diluent monitor is in system failure or out-of-control when the RATA exceeds 20% or 

1.0% absolute. Data substitution is required during periods when an analyzer is out-ofcontrol. The QAQC must describe the procedure as to how periods of out-of-control or 

system failure will be flagged to the operator, corrected and recorded. 

9.1.3 System Bias Test 

The CEMS system bias must not exceed 5.0 percent of the full span range for pollutant 

analyzers. Since sample system bias can be a cause of drift aside from many other 

possibilities, QAQC must address the criteria for excessive drift, such as control limits on 

cumulative drift, including the appropriate diagnostic techniques to identify the sources of 

the analyzer drift and system bias when control limits are exceeded. 

V. LIST OF REFERENCES AND SOURCE MATERIALS 

A Quality Assurance Perspective, Midwest Research Institute, 1996 

Code of Federal Regulations, Title 40, Part 60, Appendix B and Appendix F 

-- Draft Guidance Document for RECLAIM CEMS QA Plan, SCAQMD, 1996 

Initial Certification/Modification of Continuous Emission Monitoring Systems, 

Supplements to Certification Tests, SCAQMD, 1994 

Quality Assurance Handbook for Air Pollution Measurement Systems, Volume I, USEPA, 

March 1976, EPA-60019-76-005 

Quality Control Handbook, Third Edition, J.M. Juran, McGrawhill Book Company, 1979 

VI. ATTACHMENTS 

ATTACHMEl'JT A - REQUIREMENTS FOR RULE 2 18 CEMS 

CERTIFICATION TESTING 

ATTACHMENT B - SUPPLEMENT FOR CEMS CERTIFICATION TESTING 

ATTACHMENT C - NO2 TO NO CONVERSION TEST PROCEDURE 

ATTACHMENT D - ANALYZER ENVIRONMENTAL ENCLOSURE 

ATTACHMENT E - FUEL FLOW MONITORS RELATIVE ACCURACY TEST 

'- 
Requirements for 

Rule 218 

Continuous Emission Monitoring System 

Certification Testing 

Note: This attachment is a modified version of a District document, "Requirements 

for Certification Testing of Continuous Emission Monitoring Systems". 

Date: September 25, 1998 
The purpose of the following requirements are to assist the applicant and the testing 

contractor in the preparation of a Certification Test Protocol, in conducting the certification 

tests and the preparation of a Certification Test Report in a manner acceptable to the 

District. 

The CEMS testing contractor must have received approval from the District, through the 

Laboratory Approval Program. 

The location of the CEMS sampling probe tip and the Reference Method sampling ports 

must be determined in accordance with District Method 1.1 for representative sampling. 

Care must be exercised so that neither sampling site interferes with the other. In order to 

determine the acceptability of the CEMS and the Reference Method sampling locations, 

verification tests for stratified or cyclonic flow must be conducted in addition to 

concentration stratification tests. 
Test Requirements Test Procedure Reference 

1.0 CEMS 

1.1 Seven Day Calibration Error 

Contaminants +/-2.5 Percent Analyzer Span 40 CFR, Part 60, Appendix B 

@ 0-20 and 80-100 Percent Span Performance Specification 2 

O2 and COz +I-2.5 Percent Analyzer Span 40 CFR, Part 60, Appendix B 

@ 0-20 to 80-1 00 Percent Span Performance Specification 3 

Drift tests are to be performed at.the same time or within two weeks of the Reference method 

Certification Tests. 

1.1.1 Calibration Error Testing Requirements for Pollutant Concentration monitors and O2 Monitors 

Test, record and compute the calibration error of each monitor once on each of seven operating days. 

Conduct calibration error checks, to the extent practicable, approximately 24 hours apart. Perform the 

daily calibration error test according to the procedure in Paragraph 1.1.3 

1.1.2 Design Requirements for Calibration Error Testing of Monitors 

Design and equip each pollutant concentration monitor and O2 monitor with a calibration gaq injection 

port that allows a check of the entire measurement system when calibration gases are introduced. For 

extractive and dilution type monitors, all monitoring components exposed to the sample gas, (for 

example, sample lines, filters, scrubbers, conditioners, and as much of the probe as practical) are 

included in the measurement system. For in situ type monitors, the calibration must check against the 

injected gas for the performance of all electronic and optical components (for example, transmitter, 

receiver, analyzer). 

Design and equip each monitor to allow daily determinations of calibration error (positive or negative) 

at the zero-level(0-20 percent of each span range) and high-level (0 to 20 percent of each span range) 

and high-level (80 to 100 percent of each span range) concentrations. 

1.1.3 Calibration Error Test for Monitors 

Measure the calibration error of each monitor once each day according to the following procedures: 

If any manual or automatic adjustments to the monitor settings are made, conduct the calibration error 

test in a way that the magnitude of the adjustments can be determined and recorded. 

Perform calibration error tests at two concentrations: (1) zero-level and (2) high level. Zero level is 0 

to 20 percent of each span range, and high level is 80 to 100 percent of each span range. a gas mixture 

manufactured, analyzed and certified according to the Environmental Protection Agency (EPA) 

Traceability Protocol, "Procedure GI: Assay and Certification of a Compressed Gas Calibration 

Standard Without Dilution" or "Procedure G2: Assay and Certification of a Compressed Gas 

Calibration Standard Using Dilution", if Procedure G1 is not available. This incorporates by 

reference Procedures G1 and G2 contained in the "EPA Traceability Protocol for Assay and 

Certification of Gaseous Calibration Standards" - EPA-600R971121, September 1997 Revision.. 

Introduce the calibration gas at the gas injection port as specified above. Operate each monitor in its 

normal sampling mode. For extractive and dilution type monitors, pass the audit gas through all 

filters, scrubbers, conditioners, and other monitor components used during normal sampling and 

through as much of the sampling probe as practical. For in situ type monitors, perform calibration 

checking all active electronic and optical components, including the transmitter, receiver, and 

analyzer. Challenge the monitors once with each appropriate gas. Record the monitor response from 
Test Requirements Test Procedure Reference 

the data acquisition and handling system. Use the following equation to determine the calibration 

error for pollutant gases at each concentration once each day: 

Where: 

C = The percentage calibration error based on the span range. 

R = The reference value of zero or high-level calibration gas introduced into the 

monitoring system. 

A = The actual monitoring system response to the calibration gas. 

S = The span range of the instrument. 

For diluent gases, omit the denominator in the above equation. 

1.2 Cycle Response Time 

NOx, SO,, O2 Conc. 2 5 minutes 

Response time is the amount of time required for the measurement system to display 95 percent of a 

step change in gas concentration on the data recorder. Introduce the upscale calibration gas and record 

the stabilized reading. Then introduce the zero gas and record the gas concentration displayed on the 

recorder. Then alternately introduce the upscale and zero gases until a stable condition is achieved. 

Record the times required. Repeat the procedure several times. Note the longer of the two times as 

the response time. 

1.3. NOx Converter Efficiency 

Average Converter Efficiency >90 Percent 

Please refer to the attachment for the procedure for determining NOx converter efficiency. 

1.4 . Analyzer Span Range All data points to be within 

10-95 percent of full scale 

Rule 2 18.1 (b)(l)(c) 

1.5. Sampling System Bias Check 

All Gas Analyzers +I-% Analyzer Range District Method 1 00.1 

The Sampling System Bias is the difference between the gas concentrations exhibited by the 

measurement system when calibration gas is introduced at the sampling probe tip filter and when the 

same calibration gas is introduced directly to the analyzer. A bias check of the sampling system is 

mandatory. 

1.5.1 Procedure 

Backflush gas through the probe as necessary to prevent particulate buildup on the probe filter. 

Perform the sampling system bias check by introducing calibration gases into a baffled sample 

chamber around the probe tip filter. A zero gas and either the mid-range or high-range gas, whichever 

most closely approximates the effluent concentrations, should be used for this check as follows: 

1.5.1.1 Introduce the upscale calibration gas and record the gas concentration displayed by the 

analyzer. Introduce the zero gas and record the gas concentration displayed by the analyzer. During 

the sampling system bias check operate the system at the normal sampling rate and make no 

adjustments to the measurement system other than those necessary to achieve manufacturer 

recommended calibration gas flow rates at the analyzer. 
Test Requirements Test Procedure Reference 

1.5.2. Calculation 

The sampling system bias check shall be considered invalid if the difference between the gas 

concentrations exhibited by the measurement system when a known concentration gas is introduced at 

the sampling probe tip and when the same gas is introduced directly to the analyzer, exceeds +I- 5 

percent of the analyzer range. If an invalid calibration is exhibited, take corrective action and repeat 

the sampling system bias check until acceptable performance is achieved. 

If adjustment to the analyzer is required, first repeat the analyzer calibration error check, then repeat 

the sampling system bias check. 

2.0 Flow Monitor 

Seven Day Calibration +I- 3 percent of instrument pan 40 CFR Part 75 

Error at 0-20 and 80-100 percent span 

Seven Day Calibration Error Test for Flow Monitors 

Measure the calibration error of each flow monitor according to the following procedures. 

Introduce the reference values to the probe tip (or equivalent) or to the transducer. The reference - values must have at least two reference values: (1) 0 to 20 percent of span range or an equivalent 

reference value (for example, pressure pulse or electronic signal), and (2) 50 to 70 percent of span 

range or an equivalent reference value. 

During the seven day certification test period, conduct the calibration error test once each day while 

the unit is operating (as close to 24 hour intervals as practicable). In the event that extended unit 

outages occur after the commencement of the test, the seven consecutive operating days need not be 

seven consecutive calendar days. Record the flow monitor responses by means of the data acquisition 

and handling system. Calculate the calibration error using Equation C-2. Both flow and concentration 

data must be on the same wet or dry basis. 

Do not perform any corrective maintenance, repair, replacement of manual adjustment upon the flow 

monitor during the seven day certification test period other than that required in the monitor operation 

and maintenance manual. If the flow monitor operates within the calibration error performance 

specification, (i.e., less than or equal to 3 percent error each day and does not require corrective 

maintenance, repair, replacement or manual adjustment during the seven day test period) the flow 

monitor passes the calibration error test portion of the certification test. Wherever automatic 

adjustments are made, record the magnitude of the adjustments. Record all maintenance and required 

adjustments. Record output readings fiom the data acquisition and handling system before and after 

all adjustments. 

(Eq. c-2) 

Where: 

CE = The percentase calibration error based on the span range. 

R = The reference value of zero or high-level impulse introduced into the 

monitoring system 

A = The actual monitoring system response to the reference value impulse. 

S = The span range of the instrument. 
Test Requirements Test Procedure Reference 

3.0 Relative Accuracy Test Audit (RATA) 

3.1. Number of Tests . Minimum of nine sets of tests Rule 2 1 8 (b)(2)(C) 

data to be used for RA. 

No data can be rejected 

without justification. 

3.2 Moisture Sampling Done for each RM test. District Method 4.1 

3.3 NOx Concentration 20 Percent or 40 CFR, Part 60, 

1.0 ppm De-minimus Appendix B PS 2 

3.4 SO2 Concentration 20 Percent or 

2.0 ppm De-minimus 

(4.0 ppm for TRD) 

40 CFR, Part 60, 

Appendix B 

Performance Spec 2 

3.5 CO Concentration 20 Percent or 40 CFR, Part 60, 

2.0 ppm De-minimus Appendix B PS 4a 

3.6 02 or COz 10 percent of mean value of 40 CFR, Part 60, 

Reference Method or Appendix B 

1.0 percent O2 or C02 Performance Spec. 3 

3.7. Flue Gas Flow Rate 15 percent of mean value of 40 CFR, Part 60, 

Reference Method or flow rate at Appendix B 

2 fps, whichever is greater Performance Spec. 6 

3.6 Flue Gas Flow Rate 20 percent of mean value of 40 CFR, Part 60, 

Reference Method or emission Appendix B 

Rate at 2 fps, whichever is greater Performance Spec. 6 

Note: a. Flue gas flow rate and emissions R4 tests are to be done at the same time. 

3.7 Test the relative accuracy test data sets and the relative accuracy test audit data sets for 

pollutant concentration monitors, 02 monitor, fuel gas sulfur content monitors, flow monitors, and 

emission rate measurement systems using the procedures outlined below. 

3.8 Calculate the mean of the difference using Equation 2-1 of 40 CFR, Part 60, Appendix B, 

Performance Specification 2. To calculate RA for a pollutant concentration monitor of 02, "d" shall, 

for each paired data point, be the difference between the concentration values (in ppm) or percent 

obtained fiom the reference method and the monitor. To calculate RA for a flow monitor, "d" shall, 

for each paired data point, be the difference between the flow rate values (in dscfh) obtained fiom the 

reference method and the monitor to calculate R4 for an emission rate measurement system "d" shall, 

for each paired data point, be the difference between the emission rate values (in lbh) obtained fiom 

the reference method and the monitoring system. 

Summarize the results on a data sheet. Examples are shown in Figures 2-2 thru 2-5. Calculate the mean 

of the RM values. Calculate the arithmetic differences between the RM and the CEMS output sets. 

Then calculate the mean of the difference, standard deviation and confidence coefficient, using 

Equations 2- 1,2-2 and 2-3. 

3.9 Equations 

3.9.1 Arithmetic means 

Calculate the arithmetic mean of the difference, d, of a data set as follows: 
Test Requirements Test Procedure Reference 

(Eq. 2-1) 

Where: 

n = Number of data points 

n 

C di , = Algebraic sum of the individual differences dl 

i= I 

When the mean of the differences of pairs of data is calculated, be sure to correct the 

data for moisture, if applicable. 

3.9.2 Standard Deviation 

Calculate the standard deviation, Sd, as follows: 

(Eq. 2-2) 

3.9.3 Confidence Coefficient 

Calculate the 2.5 percent error confidence coefficient (one-tailed), CC, as follows 

Where: 

f0.975 = t-value 

Table 2- 1 -t Values 

3.9.4 Relative Accuracy 

Calculate the RA of a set of data as follows: 
Test Rea uirements Test Procedure Reference 

Where: 

Id1 = Absolute value of the mean of differences (fiom Equation 2-1). 

( CC ( = Absolute value of the confidence coefficient (fiom Equation 2-3). 

RM = Average RM value or applicable standard. 

3.10. Reporting 

All certification data must be submitted in the format designated in Figures 2-1 thru 2-5. 

4.0. Reference Methods for Rule 218 

District Method 1.1 - Sample and Velocity Traverses for Stationary Sources 

District Method 1.2 - Sample and Velocity Traverses for Stationary Sources with Small Stack or Ducts 

District Method 2.1 - Determination of Stack Gas Velocity and Volumetric Flow Rate (S-type Pitot tube) 

District Method 2.2 - Direct Measurement of Gas Volume through Pipes and Small Ducts 

District Method 2.3 - Determination of Gas Velocity and Volumetric Flow Rate fiom Small Stacks or Ducts 

District Method 3.1 - Gas Analysis for Dry Molecular Weight and Excess Air 

District Method 4.1 - Determination of Moisture Content in Stack Gases 

District Method 6.1 - Determination of Sulfuric Acid and Sulfur Oxides From Stationary Sources 

District Method 7.1 - Determination of Nitrogen Oxide Emissions for Stationary Sources 

District Method 10.1 - Determination of Carbon Monoxide and Carbon Dioxide by Gas Chromatograph/NonDispersive Infiared Detector (GCMDIR) and Oxygen by Gas Chromatograph-thermal Conductivity 

(GCITCD) 

District Method 100.'1 - Instrumental Analyzer Procedures for Continuous Gaseous Emission Sampling 

District Method 307.91 - Determination of Sulfur in a Gaseous Matrix 

EPA Method 6 - Determination of Sulfur Dioxide Emissions fiom Stationary Sources 

EPA Method 19 - Determination of Sulfur Dioxide Removal Efficiency and Particulate, Sulfur Dioxide and 

Nitrogen Oxides Emission Rates fiom Electric Utility Steam Generator (40 CFR Part 60 Appendix 

A) 

ASTM Method D 4294 or D 2622-82 - Determination of Sulfur in Liquid Fuels 
Test Requirements Test Procedure Reference 

Figure 2-1 

Example of Pollutant Calibration Error Calculation 

Span Gas = 80 ppm 

Calibration Gas Value 80.0 ppm 

Span Range 100 ppm 

Since all calibration error tests were less than plus or minus 2.5 percent, the monitor passes the calibration 

error test. 

i' -- 

*This column should inched page numbers or figure numbers. 
Test Requirements Test Procediire Reference 

Figure 2-2 

Example of Relative Accuracy Calculations 

SO2 Concentration 

RM Average 

Average Difference 

Number 

Standard Deviation 

t-value 

Confidence Coefficient 

95% Confidence Interval 

Relative Accuracy 

1 13.83 ppm 

0.53 ppm 

9 

5.70 ppm 

2.306 

4.38 ppm 

4.91 ppm 

4.3% 

*RM (Reference Method) Data is Source Test Data. 

**This column should include page numbers or figure numbers of all raw data and calculation sheets. 
Test Requirements Test Procedure Reference 

Figure 2-3 

.Example of Relative Accuracy Calculations 

SO2 Emission Rate (Ibhr) 

RM Average 

Average Difference 

Number 

Standard Deviation 

T. Value 

i - Confidence Coefficient 

95% Confidence Interval 

Relative Accuracy 

27.73 ppm 

-0.82 ppm 

9 

1.95 ppm 

2.306 

1.50 ppm 

2.32 ppm 

8.4% 

*RM (Reference Method) Data is Source Test Data. 

**This column should include page numbers or figure numbers of all raw data and calculation sheets. 
Test Requirements Test Procedure Reference 

Figure 2-4 

Example of Relative Accuracy Calculations 

O2 Concentration 

RM Average 

Average Difference 

Number 

Standard Deviation 

T. Value 

Confidence Coefficient 

95% Confidence Interval 

Relative Accuracy 

*RbI (Reference Method) Data is Source Test Data. 

**This column should include page numbers or figure numbers of all raw data and calculation sheets. 
Test Requirements Test Procedure Reference 

Figure 2-5 

.Example of Relative Accuracy Calculations 

Stack Gas Flow Rate (DSCFlM) 

RM Average 

Average Difference 

Number 

Standard Deviation 

T. Value 

Confidence Coefficient 

95% Confidence Interval 

Relative Accuracy 

24665.7 dscfin 

-1 16.2 dscfin 

9 

342.1 dscfm 

2.306 

263.0 dscfm 

379.2 dscfm 

1.5% 

*RM (Reference Method) Data is Source Test Data. 
ATTACHMENT B 

Supplement 

Requirements 

for 

Rule 218 CEMS 

Certification Testing 

(Test Protocol, Certification Test, and Test Report) 

Note: This attachment is a modified version of a District document," Supplement 

Requirements for CEMS Certification Testing". 

Date: September 25, 1998 
Supplement 

Requirements for CEMS Certification Testing 

(Test Protocol, Certification Test, and Test Report) 

The following is a list of requirements for CEMS certification testing. For more detailed 

requirements and procedures, please refer to District Rule 218 and other supporting 

documents: 

I. Requirements for CEMS Certification Test Protocol 

The CEMS certification test protocol submitted to the District shall include, but 

not be limited to, the following items: 

Description of all testing techniques, procedures, and type and number of 

tests for CEMS certification testing. 

Description of all reporting procedures. 

Statement indicating no conflict of interest between parties involved in the 

CEMS certification program per District RuIe 304. 

Statement indicating any changes in basic equipment, air pollution control 

devices, and facility CEMS design after the issuance of CEMS Initial 

Approval. 

Notification of certification test dates to the District by the facility permit 

holder. 

Test protocols for gas concentration monitors and flue gas flow rate 

monitoring systems. 

Format for reporting of process data during certification tests. 

Copy of SCAQMD LAP approval letter issued to the testing company. 

11. Requirements for CEMS Certification Testing 

i General CEMS Testing Requirements 

The following items are applicable both to facility CEMS and reference 

method testing: 

a. Approval of CEMS testing contractors by the District's Laboratory 

Approval Program. 

b. Demonstration of operational period greater than or equal to 168 

hours. 
Compliance of CEMS and reference method sampling probe tip 

locations with District Method 1.1, and cyclonic flow and 

stratification tests for these locations. 

Zero and span calibration drifts. 

Calibration error. 

CEMS response time. 

NO, to NO conversion efficiency for NOx analyzer. 

Sampling and analytical interference tests. 

System bias tests before and after each reference method test. 

Relative accuracy tests. 

Determination of bias and bias adjustment factor. 

Moisture content of the sample gas exiting sample conditioner 

maintained at a dew point less than 37 OF. 

Moisture content of the flue gas determined for reference method 

tests. 

Full span range of pollutant and diluent gas analyzers set so that all 

data points gathered by the facility CEMS lie within 10-95 percent 

of the full-scale span range. 

Submittal of chain of custody forms. 

Submittal of calibration gas certificates. 

Within two weeks of all relative accuracy testing, the above analyzer 

performance specification tests shall be conducted without any CEMS 

adjustments made during this period. 

Reference method tests shall be conducted at the same location as the 

facility CEMS. The mass emission rate relative accuracy shall be 

determined from the same set of data as that used to determine the flow 

rate relative accuracy. 

ii. Testing of Flue Gas Flow Monitoring System 

a. Adequate testing and calculation procedures. 

b. Calibration. 

c. Precision and relative accuracy. 

d. Determination of flue gas flow rate. 

e. Determination of moisture content of flue gas. 

iii. Testing of Fuel Gas Flow Monitoring System 

a. Adequate testing and calculation procedures. 

b. Tests for fuel gas composition monitor: 

1. Calibration drift. 
2. Precision and relative accuracy. 

3. F-factor, heating value, density, compressibility, etc. 

c. Fuel gas flow monitor: 

1. Calibration error. 

2. Linearity. 

3. Precision and relative accuracy. 

d. Determination of flue gas flow rate: 

1. Relative accuracy. 

iv. Determination of Pollutant Mass Emission Rate 

a. Concentration and flue gas flowaate. 

b. Pollutant mass emission rate. 

c. Relative accuracy. 

111. Certification Test Report 

After the completion of all certification testing, the facility permit holder shall 

submit a certification test report no later than 45 days from the date of the 

certification tests.. 

IV. Issuance of Final Approval 

If the requirements of all the above sections are satisfied, Final Approval for the 

CEMS will be issued. Prior to the issuance of the Final Approval, Provisional 

Approval is issued based on the submittal of test results, Quality 

AssurancelQuality Control Plan, and a statement by the permit holder attesting 

that the facility has met all Rule 2 18 requirements. 
ATTACHMENT C 

NO2 TO NO CONVERSION TEST PROCEDURE 

(Alternative to O, Titration Method-40 CFR 50.1, Appendix F) 

NO, Analyzer Requirements 

a. Full span range 0-20 pprn or 0-25 pprn 

b. Equipped with NO and NO, modes 

Auditing Gas Requirements 

a. NO, in air (or N,): Use NO, in air for a stainless steel converter. 

b. Concentration of NO,: 15 to 18 ppm (C0, PPm) 

c. Recertification: An audit gas should be recertified after six months. 

Calibration Gas Requirements 

a. Concentration: NO (1 7 to 19 ppm) with less than 0.1 ppm NO, - High Span 

NO (1 0 to 13 ppm) with less than 0.1 pprn NO, - Mid Span 

b. Zero Gas: High purity N, 

Calibration of Analyzer: 

a. Calibrate NO mode with the NO calibration gases. 

b. Calibrate NO, mode with the same gases without any gain adjustment. 

bl . If the analyzer is equipped with two independent gain adjusting circuits, skip 4.b., then 

repeat 4.a. for the NO, mode. 

Conversion Effkiency (CE) Test 

a. Analyze the audit gas with NO mode. Read and standardize concentration. (C,, PPm) 

b. Analyze the audit gas with NO, mode. Read and standardize concentration. (C, ppm) 

Calculation for Conversion Efficiency (CE): 

Criteria for Acceptability of CE 

a. %CE must be larger than 90%. 

b. C, must be less than 5 % of total NO, (NO + NO,) in the NO, audit gas (Section 2b). 

i - NOTE: NO, audit gas concentration of higher value than what is specified in Section 2 may be required 

where NO, present in the exhaust gas being measured is greater than 30 pprn. Select the NO, gas within 

10% of the expected NO, concentration in the exhaust. 
ATTACHMENT D 

Analyzer Enclosure 

CEMS analyzers must be housed in temperature controlled cabinets that meet the 

temperature requirements specified by the analyzer manufacturer. However, even in these 

temperature controlled cabinets, the temperature can fluctuate depending on outside 

temperature, cooling capacity of the air conditioning unit, and the rate of heat transfer 

through the CEMS cabinet surfaces. If the temperature fluctuations inside these cabinets 

exceed the operating range recommended by the manufacturer's instrument specifications 

analyzers can drift significantly. 

Based on the above, 2-hour CEMS analyzer drift tests shall be performed during CEMS 

semiannual RATA.. These tests do not replace or supersede any of the current RULE 21 8 

requirements. The 2-hour drift tests shall be conducted at low land high level of the full 

span range. Low level is defined as 0 to 20 percent of full scale and high level is defined 

as 80 to 100 percent of full span range. A set of thirteen tests (providing twelve data 

points) shall be conducted at each level. The results of the drift tests shall be expressed in 

terms of the mean value of the difference and the 95% confidence coefficient. For a 

detailed explanation of this statistical analysis, please refer to 40 CFR Part 60, Appendix 

D. 

The limits for the 2-hour drift tests are as follows: 

1. Pollutant gas @Ox, SOX) 

Low level and high level: - <2.5% of full span range 

2. Diluent gas (02, C02) 

Low level and high level: - <2.5% of full span range 
ATTACHMENT E 

Fuel Flow Monitors Relative Accuracy Test 

Fuel flow measuring devices used for obtaining stack flow in conjunction with F-factors 

shall be tested as installed for relative accuracy using reference methods to determine stack 

flow. 

If the flow device manufacturer has a method or device that permits the fie1 flow 

measuring device to be tested as installed for relative accuracy, the Facility Permit holder 

shall request approval from the Executive Officer. Approval will be granted in cases 

where the Facility Permit holder can demonstrate to the satisfaction of the Executive 

Officer that no suitable testing location exits in the exhaust stacks or ducts and that it 

would be an inordinate cost burden to modify the exhaust stack configuration to provide a 

suitable testing location. The method or device used for relative accuracy testing shall be 

traceable to NlST standards. This method shall be used only if natural gas, fuel oil, or 

other fuels which the Facility Permit holder can show to the satisfaction of the Executive 

Officer have stable F-factors and gross heating values, or if the Facility Permit holder 

measures the F-factor and gross heating value of the fuel. 

A. Design and equip each fuel flow meter used to meet the requirements of this protocol 

to demonstrate a flow meter accuracy of 2.0 percent of the upper range value 

(maximum calibrated fuel flow rate) as designed or measured under laboratory 

conditions by the manufacturer, operator, contractor or owner. Prior to performing 

this QAIQC procedures, the responsible parties must obtain approval from the 

Executive Officer. The following procedures must be used as appropriate to the type 

of flow meter: 

1. ASME MFC-3M- 1989 with September 1990 Errata (Measurement of Fluid Flow 

in Pipes Using Orifice, Nozzle and Venturi) 

2. ASME MFC-5M-1985 (Measurement of Liquid flow in Closed conduits Using 

Transit-Time Ultrasonic Flow Meters) 

3. ANSIIAPI 2530-92 (Orifice Metering of Natural Gas and Other Related 

Hydrocarbons) 

4. ASME MFC-6M-1987 with June 1987 Errata (Measurement of Fluid Flow in 

Pipes Using Vortex Flow Meters) 

5. ANSIIASC B 109.2-1 986ASO 83 16(E) (Measurement of Liquid Flow in Closed 

Conduits - Method by Collection of the Liquid in a volumetric Tank), or for all 

other flow meter types 

6. ASME MFC-9M-1988 with December 1989 Errata (Measurement of Liquid 

Flow in Closed conduits by Weighing Method). 

The District will also approve other standard methods that use equipment 

( - traceable to NIST standards. The Facility Permit holder shall obtain approval 
fiom the Executive Officer prior to using an alternative method. Using these 

methods, if the flow meter accuracy exceeds 2.0 percent of the upper range 

value, the flow meter does not qualify for certification. 

B. Alternatively, the fuel flow meter used for Rule 218 facilities may be calibrated or 

recalibrated to a flow meter accuracy of 2.0 percent of the upper range value at least 

annually by comparing the measured flow of the flow meter to the measured flow 

fiom other flow meter which has been calibrated or recalibrated during the previous 

365 days using the procedures in Paragraph A. Perform the comparison over a 

period of no more than seven consecutive unit operating days. Compare the average 

of three fuel flow readings for each meter at each of three different flow levels as 

listed below: 

1. A frequently used low operating load level selected within the range between the 

minimum safe and stable operating level and 50 percent load. 

2. A fiequently used high operating load level selected within the range between 80 

percent of the maximum operating level and the maximum operating level. ' 

3. The normal operating level. 

If the normal operating level is within a specified range (10% of the maximum 

operating level) of either i or ii above, use a level that is evenly spaced between 

the low and high operating levels used. The maximum operating level shall be 

equal to the nameplate capacity less any physical or regulatory limitations or 

other deratings. Calculate the flow meter accuracy using at each of the three 

flow levels using the following equation: 

ACC=- IR - A'~lOO 

URV 

Where, 

ACC = Flow meter accuracy as a percentage of the upper range 

value. 

R = Average of the three low, mid or high level flow measurements 

of the reference flow meter. 

A = Average of the three measurements 

URA = Upper range value of fuel flow meter being tested (i.e., 

maximum measurable flow). 

If the flow meter accuracy exceeds 2.0 percent of the upper range 

value at any of the three flow levels, either recalibrate the flow 

meter until the accuracy is within the performance specification or 

replace the flow meter with another one that is within the 

performance specification.