What Is a Quality Assurance Quality Control (QAQC) Plan?
Listed in the EPA’s Part 60 and 75 regulations, Quality Assurance and Quality Control (QAQC) Plans describe the facility’s operation and the monitoring systems therein. In Part 63, similar plans are called Continuous Monitoring System plans (CMS). These two sets of plans are essentially the same, including the procedures that define the initial certifications of the monitoring systems and the ongoing activities required to prove systems are functioning correctly. These systems must successfully pass regular and repeatable checks validating the accuracy of the data produced.
QAQC Plans are the Cornerstone of Field Audits
It is essential to keep your QAQC plan up to date because it describes the steps and actions the facility must take to follow the conditions of the permit. The plan serves as the cornerstone for field audits conducted by local air quality agencies or the Environmental Protection Agency. Routine air permit inspections often review these plans and associated documents. A daily Continuous Emissions Monitoring System inspection form can be “low-hanging fruit” for anyone assessing air compliance at a facility. An auditor/inspector will also use the plan to verify whether or not your facility’s employees know and understand its commitments.
Keep Your QAQC Plans Up-to-Date
Without an update, don’t let your QAQC plan sit on the shelf for too long. Be aware that many states include the plan on file with the air permit, which means plans are open to the public for review and comment. Third parties can access the plan and second guess the plant’s operation. We recommend reviewing the plan annually or whenever a change is made to your CEMS (e.g., a new monitor or updated DAS.) Read our blog post “Recommend Monitoring Plan Checklists” for some helpful information for guidelines and checklists to ensure your facility is compliant and audit-ready.
How ESC Spectrum Can Help With QAQC Plans
ESC Spectrum can assist you with a permit or QAQC plan review and make sure that your StackVision, Prism, and/or CEMDAS Evolution DAS is in alignment with those plans. Please contact us to schedule a consultation with our Regulatory Services team.
Susan Kennedy, QEP - Regulatory & Reporting Manager
Susan joins ESC Spectrum from the Power Industry sector where she spent 25+ years helping power plants and associated facilities comply with environmental laws and regulations. During her tenure at Progress Energy (now Duke Energy Florida) and Gulf Power Company, she supported various environmental programs covering all media. Her technical background includes permitting, compliance and reporting for wastewater, water use, groundwater, remediation, Title V, Title IV, CEMS, Green House Gas, Florida Annual Operating Reports, Air Testing, Reciprocal Internal Combustion Engine (RICE), Risk Management Plans and Toxic Release Inventory. She received both her Bachelor of Science (’92) and Master of Science (’96) degrees from Auburn University.
