Business Objective

ALG was requested to provide assistance in reviewing and updating continuous emissions monitoring system (CEMS) and continuous opacity monitoring system (COMS) quality assurance plans (QAPs) for several of the client's power generation facilities.

Technical Approach

ALG worked closely with the client's CEMS/COMS contractor to develop/update the QAPs and supporting documents to fulfill individual facility obligations under their respective Operating Permits. Primary tasks included evaluating the monitoring software and the key assumptions used for data analysis and downtime calculations. ALG was also tasked to ensure that the QAPs properly addressed all applicable rule/permit requirements and the associated monitoring and recordkeeping provisions (e.g. data recording, calculations, reporting requirements and procedures, emissions test methods/alternatives, calibration drift set points used and general corrective actions, preventative maintenance procedures and required inspections, etc...).

Results

ALG identified out-of-control and availability calculation errors in the client's monitoring software programming and provided the appropriate methods to be used under various regulatory programs. ALG also identified several areas of the QAPs that did not adequately document data recording, calculations, and reporting procedures and recommended updates that would bring the facility into compliance with their Operating Permit obligations.