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Example CMC Solutions

PEMS QA/QC Manual March 1, 2016

Quality Assurance Plan


40 CFR Part 60 Predictive Emissions Monitoring for
Example using SmartCEMS®

EXAMPLE

Prepared For:

EXAMPLE

Prepared by:

CMC Solutions, LLC


23560 Haggerty Road
Farmington Hills, Michigan 48335

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TABLE OF CONTENTS

SECTION 1 QA/QC OVERVIEW ...................................................................................................................................1


1.1 INTRODUCTION ..................................................................................................................................................1
1.2 SYSTEM OVERVIEW .............................................................................................................................................2
1.2.1 PEMS Operational Flow Chart ..............................................................................................................3
1.3 USING THE QA/QC MANUAL ............................................................................................................................... 3
1.4 QUALITY ASSURANCE PLAN QUALITY CONTROL ........................................................................................................6
1.4.1 Regulatory Requirements .....................................................................................................................6
1.4.2 Organization and Responsibilities ........................................................................................................6
SECTION 2 SYSTEM DESCRIPTION ............................................................................................................................9
2.1 PEMS FUNCTIONAL DESCRIPTIONS ........................................................................................................................9
2.2 SOURCE DESCRIPTION........................................................................................................................................ 10
SECTION 3 PEMS QUALITY ASSURANCE PROCEDURES .......................................................................................... 11
3.1 QUALITY ASSURANCE OBJECTIVES ........................................................................................................................ 11
3.2 QUALITY CONTROL ACTIVITIES............................................................................................................................. 14
3.3 QUALITY ASSURANCE CRITERIA ............................................................................................................................ 16
3.4 PEMS OPERATING ENVELOPE ............................................................................................................................. 17
3.5 REPORTING REQUIREMENTS................................................................................................................................ 18

TABLES
Table 1 - Organization Chart and Phone Numbers ........................................................................................................8
Table 2 – PEMS Quality Assurance Objectives ............................................................................................................. 13
Table 3 – Quality Control Activities (Boiler EXAMPLE) ................................................................................................ 15
Table 4 – PEMS Maintenance Activities ...................................................................................................................... 16
Table 5 - Compliance Parameters (Boiler EXAMPLE) ................................................................................................... 17

SYSTEM DOCUMENTATION TABS

EQUIPMENT…..……………………………………... Monitoring System Failure Log


CORRESPONDENCE LOG………………………… Correspondance Log
CALIBRATION…………………………………......... Calibrations Log
AUDITS……………………………..………………….… RATA/Audit Log
MAINTENANCE…………………………………....... Maintenance and Troubleshooting Log

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PROCEDURES

Procedure 1…………………………………PEMS Startup/Shutdown


Procedure 2…………………………………Acknowledge Alarms
Procedure 3…………………………………Watchdog Shut down and Manual PEMS Start
Procedure 4…………………………………PEMS Maintenance
Procedure 5…………………………………PEMS RATA Test
Procedure 6…………………………………PEMS RAA Test
Procedure 7…………………………………PEMS Server Reboot
Procedure 8…………………………………PEMS Recertification Test Audit
Procedure 9…………………………………Conducting Mobile CEMS Audits
Procedure 10……………………………….Manual Data Recovery

APPENDICES

Appendix A: Operating Permit


Appendix B: U.S. EPA 40 CFR Part 60, PS-16
Appendix C: U.S. EPA 40 CFR Part 60, Appendix F

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SECTION 1 QA/QC Overview

1.1 Introduction

Example Complex owns and operates the Boiler Example at their Example facility with capacity
of 200 tons per hour (T/h) feed of natural gas. The Boiler combusts natural gas (NG) from
process streams. The Boiler is covered by permit number issued by the Example.

This unit is subject to regulations which incorporate by reference U.S. EPA regulations 40 CFR
part 60, for new source performance standards. These regulations require installation,
calibration, maintenance, and operation of a continuous emission monitoring system for
measuring and documenting SO2, NOx, CO and O2 (or CO2) emissions discharged to the
atmosphere.

The exhaust gas is discharged to the atmosphere through one stack. Emissions are monitored
using a statistical hybrid predictive emissions monitoring system (PEMS) and data acquisition
system. The PEMS installed is a SmartCEMS® Analyzer and is provided by CMC Solutions, L.L.C.
Quality assurance procedures under 40 CFR Part 60, Appendix F will be followed and are
outlined in this document.

Model training data was collected with an existing certified continuous emission monitoring
system (CEMS). Data used in the model was collected in the fourth quarter of 2015. The
SmartCEMS®-60 PEMS was installed December, 2015. The PEMS reads data from the PI system
at the plant and write the data back to PI for generating trends and reports.

The purpose of this manual, the QA plan, and the QC activities described herein is to accurately
document the pollution emission rates and verify compliance with the emission limitations
specified in the applicable regulations. This QA/QC manual has been prepared to assist
personnel in the assessment of the quality of PEMS data and specify corrective actions should
the system malfunction. The continuing accuracy of the data acquisition system and
compliance with 40 CFR Part 60 is primarily dependent on the operating personnel and this QA
program.

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1.2 System Overview

The objective of the predictive emissions monitoring system and the reporting subsystems is to
document compliance with the regulations pertaining to the primary pollutant sulfur dioxide.
The PEMS accomplishes this by continuously monitoring the Boiler operating parameters and
utilizing a statistical hybrid data model to predict SO2, NOx and CO concentrations and emission
rates (mg/m3) data in real-time during Boiler operations.

The PEMS at the EXAMPLE site consists of three major subsystems: the interface to the Boiler
control system and its sensors that provide input parameters for the model, the statistical
hybrid PEMS model, and the PEMS server with its associated operating system software and
applications (namely the PI system with customer reporting application and operator interface).
A description of these components and their location is as follows:

1. Interface to the Boiler Controls and Analytical Components (Field Devices) consisting of
transmitters and transducers located on the Boiler or Boiler ancillary equipment. The only
critical input is the Flow Fuel Gas Line to EXAMPLE. There are additional Boiler parameters that
are used by the model if available, but are not critical to the model’s performance under the
standard.

2. Statistical Hybrid PEMS Model (SmartCEMS®) consists of a software module that runs
for a Boiler. SmartCEMS™ acquires the process data in real-time and generates predictions
based on the data that has been stored in the historical training dataset. There is a unique
SmartCEMS™ for each combustion unit that contains Boiler specific data for modeling
purposes.

3. PEMS Hardware and Software consists of a Server class machine with 2 processors,
2.20GHz CPU, 8GB memory, 1TB hard drive capacity. The operating system software is
Windows Server 2008 R2 Standard with Service Pack 1 to support the applications including the
Pi reporting package.

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1.2.1 PEMS Operational Flow Chart

The system is installed, certified, and operated as depicted in the diagram below. The
calculated emission rates are used to assess compliance with the standards, and reports are
generated for submittal to the regulatory agencies.

Draft Develop Model, Conduct


Alternative Input Failure Analysis,
Monitoring Configure PEMS
Plan
(optional) Operate PEMS

Collect Develop QA Plan


Data
PEMS Quarterly
Install Data Compliance
PEMS Reports

Drift Checks & Annual RATA

Develop Submit Reports


Monitoring
Plan Approval for the source

PEMS Development Flow Chart

1.3 Using the QA/QC Manual

This QA/QC manual is to be kept in the TES1 office at all times. This manual is intended to be a
working or 'living' document and an integral part of the continuing operation of the Boiler.
Under no conditions should the manual leave the plant.

This manual is to be used to document all QC activities including routine preventative


maintenance, calibrations and adjustments, correspondences, troubleshooting, and other
actions associated with the operation and calibration of the PEMS. Trained maintenance
personnel and operators should make entries when necessary. This manual should be updated
as needed. The QA/QC manual is a critical component of the PEMS and a requirement of the

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regulations. The manual and plan should be reviewed periodically (every three years at a
minimum) to address any performance issues.

PEMS Block Diagram – Data Acquisition Schematic

Section 1 of the QA/QC manual contains a general overview of the QA program and the PEMS,
organizational structure and responsibilities to assist in locating appropriate personnel, a PEMS
operational flow chart identifying the steps in developing and certifying a PEMS model.

Section 2 contains a detailed description of the PEMS system. This section describes the
subsystems and PEMS components and the PEMS hardware and software.

Section 3 contains the QA/QC objectives, PEMS quality assurance procedures on the process
inputs for the model, QA criteria, and PEMS operating envelope.

In the back the system documentation is divided into the following five tabs:

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EQUIPMENT
Behind this tab is the “Monitoring System Failure Log” which is used to document all failures of
any component of the PEMS system.

Also contained are excerpts from the PEMS manual introductory and theory of operation
sections, this subsection describes the process sensors used by the model, subsystem
components, and configurations. Drawings and diagrams are included at the end of the
subsection. See associated manufacturers maintenance and QA recommendations behind the
Maintenance tab, if available.

CORRESPONDENCE LOG
This tab is used to document applicable correspondences with vendors, regulatory agencies,
and testing teams.

CALIBRATION
Behind this tab is the “Calibrations Log” which is to be used to document manual calibrations
and all adjustments.

All instruments/sensors are calibrated annually. Hard copies of these records are maintained in
the TES1 office at PEMS Server. Also contained is a description of the automatic daily
calibrations that are performed on the PEMS. A table is included of equipment for which
calibrations are performed with frequencies.

AUDITS
Behind this tab is the “Audit Log” which is used to document all RATAs, RAAs and audits of the
PEMS.

Data from the initial performance specification testing is included in this subsection. Also
included are the requirements and procedures for annual RATAs, monthly RAAs, reduction and
validation of audit data, and reporting.

MAINTENANCE
Behind this tab is the “Maintenance Log” which is to be used to document all routine
preventative maintenance (QC) and troubleshooting activities.

Also contained are excerpts directly from the monitor manual, this subsection describes the
specific steps recommended by the manufacturer to be routinely carried out for preventative
maintenance. Included in this subsection is a list of spare parts to be kept in stock.

Excerpted directly from the monitor manual, this subsection is used to address monitor
performance problems. Also included in this subsection are the corrective actions to be taken
in case of equipment failure.

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1.4 Quality Assurance Plan Quality Control

Introduction

Quality assurance (QA) is necessary to ensure reliability of the PEMS data. The minimum QA
requirements for assessment of the quality of PEMS data used for compliance determination
are described in 40 CFR 60, Appendix F. The quality assurance program detailed in this manual
includes operational checks (automatic daily and manual calibrations, observations, and
adjustments), routine maintenance (periodic preventative maintenance), and performance
audits. These activities are collectively referred to as quality control (QC) activities. All QC
activities are documented in this QA/QC manual. Additional activities resulting from system
component failures are documented in this manual, as well as all correspondences to
equipment vendors, regulatory agencies, and testing teams.

1.4.1 Regulatory Requirements

The minimum QA/QC requirements for all continuous emission monitoring systems are detailed
in 40 CFR 60, Appendix F. Additional specification and test procedures and QA/QC
requirements are contained in 40 CFR Part 60, Appendix B, Performance Specification 16. The
regulations require an initial 27-run relative accuracy test audit (RATA) with nine tests at each
of three load levels. After this, an annual 9-run RATA is to be conducted at the normal load with
a quarterly relative accuracy audit (RAA) in each quarter that a RATA is not performed (see
Procedures 5 and 6). In the event of a failed RATA or RAA or if changes occur that result in a
significant change in the emission rate relative to the previous PEMS training conditions (e.g.
process modification, new process operating modes, or changes to emission controls), then
recertification will be conducted (see Procedure 8).

1.4.2 Organization and Responsibilities

A chart of the organizational structure of the Example Plant and the operations/maintenance
staff as it relates to the operation of the data acquisition system (DAS) is presented on the
following page. Also included on the chart is phone numbers for the various personnel. A
description of the individual responsibilities follows:

SYSTEM SUPPORT
He/she is responsible for communication with maintenance supervisors concerning PEMS/DAS
functionality and abnormal or failure conditions also monitoring the operations of the DAS.

EMERGENCY SUPPORT
He/she is responsible for maintenance and upgrade of the DAS system, the PEMS models, and
network integration. These are reported to the Local Support.

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INSTRUMENTATION SUPPORT
Responsible for all calibration checks, observations, adjustments, maintenance, and other QC
activities. Responsible for maintaining the QA/QC manual including calibration, maintenance,
equipment failure, and correspondence logs. They report system failures to maintenance
supervisors. They are responsible for acknowledging PEMS/DAS alarms and entering reason
codes for exceedances and are responsible for observation of process and PEMS/DAS
functionality and documentation of any abnormal or failure conditions.

PROCESS/PROCESS CONTROL SUPPORT


He/she is responsible for maintenance of PEMS readings in PI system.

LOCAL SUPPORT
He/she is responsible for supporting the emergency support and supervises the Audit team
(RAA & RATA)

PIMS SUPPORT
He/she is responsible for maintenance and validates PEMS/DAS of the PI interface system from
PEMS server to PIMS.

MANUFACTURER REPRESENTATIVES
He/she is responsible for supporting the deployed technology including PEMS software and
mechanics for obtaining data from the DCS and outputting data to the report generation
system.

SOFTWARE SPECIALIST
He/she is responsible for support any upgrading or system failure of the PEMS software.

ENVIRONMENTAL COMPLIANCE COORDINATOR


He/she is responsible for the QA program, updating QA/QC manual, for scheduling and
administration of QC activities and for assembling reports for submittal to regulatory agencies.
He/she is responsible for communication with regulatory agencies and for administration of
environmental compliance program.

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Table 1 - Organization Chart and Phone Numbers

Description Name Telephone


System Support - -

Emergency Support - -

Instrumentation Support - -

- -
Process Support
Process Control Support - -

Local Support - -

PIMS Support - -

Manufacturer's Representative CMC Solutions - Brian Swanson 248 939 7391

Software Specialist CMC Solutions - Jacob Donajkowski 248 960 1632

Environmental Compliance - -
Coordinator

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SECTION 2 System Description

2.1 PEMS Functional Descriptions

The SmartCEMS®-60 PEMS application is designed to execute on a standard workstation


operating system (Windows Server 2008) and utilizes a standard OPC-compliant database (MS
SQL Server 2008) with a compatible data acquisition input device. The application itself actually
consists of three independent components that interact with the database. The database is
secured and contains the compliance data (both raw collected data that is not editable and
historical data formatted as specified by the applicable regulations), as well as, a message
archive of system error messages and operator comments.

The first application is the data acquisition module that runs on startup of the system and
collects data continuously in a protected mode from the configured I/O. This data acquisition
service reads, scales, averages, and inserts minute records into the historical database archive.
The data acquisition service is the only component that can write to the historical database
archive and stamps each record with the current date and time.

Two other independent SmartCEMS®-60 components work with the data acquisition service.
The first application provides the operator interface for display of real-time data, display and
acknowledgement of compliance alarms, and input of operator data including gas sampling
results and certification test results. The second application provides the reporting and XML
generation capacities. Both of the applications that support the data acquisition service can be
run from any workstation on the local area network.

The system hardware is entirely contained within the Dell Poweredge™ server supplied by
ASMA that is located in the TES1 office. The system requires an uninterruptible power supply
that will ensure that power fluctuations and momentary lapses in power will not cause a loss of
data or damage to the hard drive storage.

Upon startup of the PEMS, the software is monitored by a CMC application called “Watchdog”.
This service which runs on the server continuously monitors the PEMS, restarts it automatically
as needed.

The system software utilizes multiple levels of security to protect the data and the application
software itself. The system is provided in an ‘open’ environment readily networked to other
process and control machines. Although the system is configurable and flexible such that
additional I/O points can be added, the data that is collected is also protected in its raw form
indefinitely. The system is designed to efficiently collect data into the secure database and
also to make that data available for use in real-time optimization strategies. The system utilizes
a compliance database that allows the user to make certain approved edits to the data such as

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process operating conditions and quality assurance test results. The edits are maintained in the
compliance database leaving the raw data intact. All network cabling and connections are via
Ethernet including the interface to the I/O device.

The data is made available for display as real-time trends or tabular displays and for generation
of reports. Report generation is initiated through the operator interface and includes
generation of Part 60 compliance reports, excess emission reports, and custom reports
configurable by the end user. Electronic data reports are generated using the custom PI
reporting component for 40 CFR Part 60 compliance.

The system utilizes a training dataset to generate predicted emission rates. The system can
predict any process or CEMS input in real-time utilizing the training dataset. Training data for
compliance systems in SmartCEMS®-60 PEMS are fixed during performance testing. The data
has been quality assured and placed into a training database table for use by the data
acquisition service.

2.2 Source Description

The source identification under the regulations is:

EXAMPLE

Unit Name Emissions Unit Maximum Capacity


- Boiler 200 Tons per hour

The Boiler combusts pipeline natural gas from the process. The resulting stack gas exhaust
stream is discharged to the atmosphere.

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SECTION 3 PEMS Quality Assurance Procedures

3.1 Quality Assurance Objectives

Quality assurance (QA) is necessary to ensure reliability of the PEMS data. The quality
assurance program detailed in this manual includes operational checks (automatic daily and
manual calibrations, observations, and adjustments), routine maintenance (periodic
preventative maintenance), and performance audits. These activities are collectively referred
to as quality control (QC) activities. All QC activities are documented in this QA/QC manual.
Additional activities resulting from system component failures are documented in this manual,
as well as, applicable correspondence to equipment vendors, regulatory agencies, and testing
teams. Table 2 summarizes the regular QA objectives that are to be conducted.

Each day, the PEMS is subjected to an automatic daily calibration test (see objectives 3 & 4 listed in
Table 2). A zero vector representing the process inputs when the unit is offline (no fuel gas flow) is
used to generate a zero prediction which is recorded in the zPEMS_Output.dat file. This file will
contain a zero value for each predicted pollutant and 20.9 for the oxygen. A second vector
representing the unit at normal load (this is a vector selected from the RATA testing representing
the process input values at normal load) is presented to the PEMS and a prediction is generated.
This daily (span) calibration prediction is contained in the sPEMS_Output.dat file and contains
predicted values for each pollutant and oxygen at normal load. The PEMS calibration can be
evaluated similarly to a CEMS calibration record, however, the target value is the reference
method value recorded during the RATA test at normal load corresponding to the input vector that
was used. This daily calibration should yield a response that is very close to the reference method
and the prediction should not change at all day to day. This calibration checks the historical
training dataset and the prediction mechanism from inputs to outputs. The data acquisition
system is configured to look for any change in this daily calibration record and to generate an
alarm if any deviation is detected. If any change is made to the database or a corruption occurs
that affects the prediction, the daily calibration value will change. This change will be detected by
the data acquisition system and an alarm will be generated.

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In addition, there are written procedures for operating and maintaining the PEMS. These are
included following this section. The procedures include the following:

Procedure 1: PEMS Startup/Shutdown


Procedure 2: Acknowledge Alarms
Procedure 3: Watchdog Shutdown and Manual PEMS Start
Procedure 4: PEMS Maintenance
Procedure 5: PEMS RATA Test
Procedure 6: PEMS RAA Test
Procedure 7: PEMS Server Reboot
Procedure 8: PEMS Recertification Test Audit
Procedure 9: Conducting Mobile CEMS Audits
Procedure 10: Manual Data Recovery

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Table 2 – PEMS Quality Assurance Objectives

No. OBJECTIVE Performance Specification Frequency


1 QA Program Update QA manual as needed Annually at a minimum
Any PEMS input parameter cannot go below the
minimum or above the maximum value otherwise the
PEMS data is not acceptable (see PS16 section 6.1.2).
2 Operating Envelope Operations outside the envelope or other PEMS failure Ongoing
will result in status 11 (invalid PEMS data) and/or
monitor downtime. Monitor downtime must not
exceed 10% each quarter.
2 X the applicable drift specification for five,
Daily (This is done
consecutive, daily periods or 4 X the applicable drift
3 Zero Level Calibration Drift automatically by the
specification for any daily calibration drift the PEMS is
PEMS software).
out of control (see 40 CFR 60, Appendix F, 4.3).
2 X the applicable drift specification for five,
Daily (This is done
consecutive, daily periods or 4 X the applicable drift
4 Span Value Calibration Drift automatically by the
specification for any daily calibration drift the PEMS is
PEMS software).
out of control (see 40 CFR 60, Appendix F, 4.3).
Perform automatic or manual determination of
5 Sensor Evaluation Daily
defective sensors.
3-run Relative Accuracy Audit The same performance specifications as for the RATA. Quarterly1
6
(RAA) See number 7 below. Three 30 minute tests.
RA ≤ 10.0% if the PEMS measurements are greater
than 100 ppm or 0.2 lbs/mmBtu. RA ≤ 20% if the PEMS
Initial
measurements are between 100 ppm (or 0.2
≥ 27 test runs at each
lb/mmBtu) and 10 ppm (or 0.5 lb/mmBtu). For
of three normal loads
measurements below 10 ppm, the absolute mean
Relative Accuracy Test Audit Annual
7 difference between the PEMS measurements and the
(RATA) ≥ 9 test runs at normal
RM measurements must not exceed 2 ppm (except for
operating level.
CO which must be within 5 ppmv under100 ppm). For
diluents PEMS, an alternative criterion of ± 1 %
absolute difference between the PEMS and RM may
be used if less stringent.
To be conducted whenever a RAA or a RATA is failed ≥ 9 test runs are
8 Recertification RATA or when operating conditions change. required at each of 3
operating levels.
if davg ≤ |cc|, bias test is passed After each RATA.
9 Bias Correction Perform at the mid
operating level
PEMS Training r ≥ 0.8, and Fcritical ≥ F Optional after initial
10
(Linear correlation and F-test) and subsequent RATAs
Sensor Evaluation Alert Test See Section 6.1.8 of PS-16 in Appendix B. After each PEMS
11
(optional) training

1
A relative accuracy audit (RAA) will be performed in every calendar quarter, except for the quarter in which a full
9-run RATA or PEMS recertification is performed in the first year. The second year and after, only one RAA is
required per year.

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3.2 Quality Control Activities

Each of the devices providing inputs utilized by the PEMS model is included in the plant's
process control system quality assurance program (see Table 3). The major components are
evaluated on an annual basis at a minimum using a three point sensor calibration that is
recorded by the data acquisition system downstream of all transmitters and other signal
conditioning equipment. This annual primary quality control check is documented by the plant
staff. Any deviation of greater than 10% is noted and adjustment is made. Plant staff typically
makes minor adjustments at this time; however, typical deviations for this instrumentation
(temperature, pressure, and other sensors) are less than 3% per year.

Additional quality control activities are scheduled when sensor data appears to be inconsistent
or is suspected by plant operations or maintenance staff. The QA program is reviewed on an
annual basis. This plan contains log sheets to record the results of QC activities and as a guide
to troubleshooting. The data is backed up each quarter (incrementally) and annually
completely (see Table 4).

EXAMPLE is currently operating one model onsite for EXAMPLE Boiler. The model is optimized
for all parameters pollutant which is SO2, NOx, CO, O2 and CO2.

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Table 3 – Quality Control Activities (Boiler EXAMPLE)


Quality Assurance Programming

INPUT DESCRIPTION Units INTERVAL QC ACTIVITY

Calibration Check
63 A4140 FLOW FUEL GAS LINE CTRL T/HR Annual

A4140 COMBUSTION AIR FLOW


1 T/HR Annual Calibration Check
CTRL
4 A4140 FLOW HP STEAM LINE MBAR Annual Calibration Check

5 A4140 FLOW INL DUCT FD FAN MBAR Annual Calibration Check


A4140 LVL HP STEAM DRUM
9 % Annual Calibration Check
CTRL
15 A4140 PRES FURNACE MBARG Annual Calibration Check

A4140 QLTY SAMPLE LN HP STM


28 µS/CM Annual Calibration Check
DRUM
A4140 TEMP INL DUCT EXT
39 DEGC Annual Calibration Check
ECONMSR
A4140 TEMP SPHTR CONN TO
43 DEGC Annual Calibration Check
DESPHTR
4140 FLW HP BLR FDWTR LINE
60 T/HR Annual Calibration Check
CTRL
4140 FLW HP BLR FDWTR LINE
61 % Annual Calibration Check
CTRL
64 A4140 FLOW FUEL GAS LINE CTRL % Annual Calibration Check
75 H20 IN FEED GAS TO U1100 PPM Annual Calibration Check
 Input 63 is the only primary input for the SmartCEM®-60 model. Other inputs listed
herein are used by the model if available.
 Annual Periodic calibration of analyzers may trigger adjustment (if a greater than 5%
deviation is found); however, annual calibration checks verify that the flow, pressure,
and temperature inputs do not require periodic adjustment or more frequent QC
checks. Faulty performance on an annual calibration check will typically lead to a
replacement of the sensor or transmitter (or both)

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3.3 Quality Assurance Criteria

The SmartCEMS®-60 PEMS interfaces directly with the process control system for data
acquisition. The plant currently maintains a Quality Assurance program in accordance with 40
CFR Part 60, Appendix F. A copy of the Quality Assurance Manual is located near the
SmartCEMS®-60 PEMS workstation. The QA Manual with the log will be maintained in TES1
office. System maintenance, database maintenance, and data backup procedures have been
instituted onsite and are conducted (See Table 4). All PEMS quality control activities are
documented in the Quality Assurance Manual.

At a minimum, one each year, the PEMS is evaluated at startup, each hour during any given
load condition, and during shutdown or transition to new load. The PEMS is evaluated for
concurrence with the Boiler control system display using each of the following ‘critical
compliance’ parameters (natural gas flow and oil flow). These inputs are used by the PEMS to
determine the SO2, NOx & CO emissions rate.

Table 4 – PEMS Maintenance Activities

Description Interval
Perform diagnostic tests on each drive - see procedure 4. Annually
Defrag each hard drive – see procedure 4. Annually
Perform incremental database backup Quarterly
Backup the database and archive – see procedure 4. Annually
Perform PEMS hardware maintenance – see procedure 4 Quarterly

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3.4 PEMS Operating Envelope

The inputs used in the models for the critical compliance parameters as identified in Tables 5
are provided with alarms and set-points that are used to define the envelope of the currently
certified model. These alarms are configured with the data provided in the historical training
dataset at the time of certification. When critical compliance parameters are not in line with
the data collected in the historical training database, the data is flagged as invalid and missing
data substitution procedures are applied wherever applicable.

Table 5 - Compliance Parameters (Boiler EXAMPLE)


SmartCEMS™-60 Model Limits

MODEL
INPUT DESCRIPTION TAG NAME Units MIN MAX
LEVEL
63 1 A4140 FLOW FUEL \\EXAMPLEPIMS\44_FIC904.ME T/HR 2.26 26.64
GAS LINE CTRL AS
1 2 A4140 COMBUSTION \\EXAMPLEPIMS\41_FICA904.M T/HR 229.43 388.88
AIR FLOW CTRL EAS
4 2 A4140 FLOW HP \\EXAMPLEPIMS\41_FT902.PNT MBAR 220.37 334.6
STEAM LINE
5 2 A4140 FLOW INL \\EXAMPLEPIMS\41_FT904.PNT MBAR 1.74 2.97
DUCT FD FAN
9 3 A4140 LVL HP STEAM \\EXAMPLEPIMS\41_LICSA904. % 200.91 334.47
DRUM CTRL OUT
15 3 A4140 PRES \\EXAMPLEPIMS\41_PIA907.PNT MBARG 4.61 14.25
FURNACE
28 3 A4140 QLTY SAMPLE \\EXAMPLEPIMS\41_QIA903.PN µS/CM 0.06 4.08
LN HP STM DRUM T
39 3 A4140 TEMP INL \\EXAMPLEPIMS\41_TI917.PNT DEGC 348.37 406.31
DUCT EXT ECONMSR
43 3 A4140 TEMP SPHTR \\EXAMPLEPIMS\41_TIA901.PN DEGC 441.72 464.3
CONN TO DESPHTR T
60 3 4140 FLW HP BLR \\EXAMPLEPIMS\47_FICSA916. T/HR 200.26 335.5
FDWTR LINE CTRL MEAS
61 3 4140 FLW HP BLR \\EXAMPLEPIMS\47_FICSA916. % 46.48 59.69
FDWTR LINE CTRL OUT
64 3 A4140 FLOW FUEL \\EXAMPLEPIMS\44_FIC904.OU % 19.63 29.57
GAS LINE CTRL T
75 3 H20 IN FEED GAS \\EXAMPLEPIMS\O10_QR1.PNT PPM 111.8 284.09
TO U1100

 Fuel flow rate to the Boiler is the only critical input for the SmartCEMS®-60 model presented in this manual. Other
inputs listed herein are used by the model if available.

17
Example CMC Solutions
PEMS QA/QC Manual March 1, 2016

 Annual calibration may trigger adjustment (if a greater than 5% deviation is found), however, annual calibration
checks have verified that the flow, pressure, and temperature inputs do not require adjustment or more frequent QC
checks. Faulty performance on an annual calibration check will typically lead to a replacement of the sensor or
transmitter (or both).

3.5 Reporting Requirements

The operating envelopes for the PEMS are part of the hardcopy monitoring. Any time changes
are made to the PEMS operating envelope, the complete, revised PEMS operating envelope will
be placed in this plan and in the monitoring plan.

18
Quality Assurance Plan
MLNG PETRONAS

Appendix A

Operating Permit
Quality Assurance Plan
MLNG PETRONAS

Appendix B

U.S. EPA 40 CFR Part 60, PS-16


Quality Assurance Plan
MLNG PETRONAS

Appendix C

U.S. EPA 40 CFR Part 60, Appendix F


Quality Assurance Plan
MLNG PETRONAS

Appendix D

PEMS and Site Drawings