A key component of owning a Continuous Emissions Monitoring System (CEMS) and/or Continuous Opacity Monitoring System (COMS) is the QAQC manual required by Federal Regulations. Often a new system is purchased, and a manual is not included, or a manual has become outdated (maybe it was not updated when an upgrade or equipment replacement was done).
In this article, we will outline requirements and discuss the elements a good QAQC manual typically includes. In many cases, the original equipment supplier addresses and supplies the QAQC manual as it includes many specific and technical details about the equipment itself. Plant personnel can also develop a QAQC manual, but it would most likely require a lot of input from the supplier/manufacturer to include all the proper details and a firm understanding of the regs.
QAQC Manual Guidance
To learn about requirements for QAQC manuals, please reference the Environmental Protection Agency guidelines:
To learn more about keeping your QAQC plans up to date, read our blog post to stay audit ready!
You’ll also find useful Monitoring Plan checklists for QAQC and more here.
What are the Typical Elements of a QAQC Manual?
A typical QAQC manual contains many sections with a lot of detailed information. Here is a breakdown of the typical sections:
- Introduction: This section defines the objective of the manual and a company’s QAQC policy, along with the scope of the plan and document control information. Details such as the applicable regulations are called out, along with possible references to a facility’s permit.
- Description of Facility and Equipment (CEMS and/or COMS): This section describes the facility, organization (personnel), and the individuals responsible for carrying out the QAQC activities included. This is a section that would likely need updating over the course of 10-20 years of equipment life as people move in and out of a company. It also details the equipment, including model and serial numbers. It discusses the overall measurement process and the technology involved.
- Quality Assurance Activities: This is the heart of the manual and describes all the QAQC activities that ensure a CEMS or COMS remains a compliance instrument that meets the regulations. It details things like daily calibrations, quarterly audits, and annual testing. It goes into detail on the methods, limits of drift, errors, and the timing of each test.
- Quality Control Activities: This section details what actions are taken to address issues with the QA activities along with the maintenance activities and schedules. It can include things like training, spare parts inventory, and more.
- Data Recording and Reporting: This section outlines the way data is recorded and reported. It details notifications and record keeping and sometimes includes component addition, maintenance, or replacement.
- Glossary of Terms and Acronyms
- Attachments: Typically, a copy of each type of report the system generates is included, along with any equipment certificates of compliance.
The Bottom Line For QAQC Manuals
If you have a CEMS or COMS compliance system, make sure to have a QAQC manual to go alongside it. It is essential to review the plan and ensure regular updates are made as your CEMS and COMS change. Besides being a requirement of the regulations, it is also a great training tool and documentation for the people who are maintaining the equipment.
ESC Spectrum can assist you with your manual, a permit or QAQC plan review, and make sure that your StackVision, Prism, and/or CEMDAS Evolution Data Acquisition Sytsem (DAS) is in alignment with those plans. Please contact us to schedule a consultation with our Regulatory Services team.
