Illinois Administrative Code
Title 35 - ENVIRONMENTAL PROTECTION
Part 225 - CONTROL OF EMISSIONS FROM LARGE COMBUSTION SOURCES
Subpart F - COMBINED POLLUTANT STANDARDS
Appendix B - Continuous Emission Monitoring Systems for Mercury
Exhibit B - Quality Assurance and Quality Control Procedures
Current through Register Vol. 48, No. 38, September 20, 2024
1. Quality Assurance/Quality Control Program
Develop and implement a quality assurance/quality control (QA/QC) program for the continuous emission monitoring systems and their components. At a minimum, include in each QA/QC program a written plan that describes in detail (or that refers to separate documents containing) complete, step-by-step procedures and operations for each of the following activities. Upon request from regulatory authorities, the source must make all procedures, maintenance records, and ancillary supporting documentation from the manufacturer (e.g., software coefficients and troubleshooting diagrams) available for review during an audit. Electronic storage of the information in the QA/QC plan is permissible, provided that the information can be made available in hardcopy upon request during an audit.
Keep a written record of procedures needed to maintain the monitoring system in proper operating condition and a schedule for those procedures. This must, at a minimum, include procedures specified by the manufacturers of the equipment and, if applicable, additional or alternate procedures developed for the equipment.
Keep a written record describing procedures that will be used to implement the recordkeeping and reporting requirements in subparts E and G of 40 CFR 75, incorporated by reference in Section 225.140, and Sections 1.10 through 1.13 of Appendix B, as applicable.
Keep a record of all testing, maintenance, or repair activities performed on any monitoring system or component in a location and format suitable for inspection. A maintenance log may be used for this purpose. The following records should be maintained: date, time, and description of any testing, adjustment, repair, replacement, or preventive maintenance action performed on any monitoring system and records of any corrective actions associated with a monitor's outage period. Additionally, any adjustment that recharacterizes a system's ability to record and report emissions data must be recorded (e.g., changing of flow monitor or moisture monitoring system polynomial coefficients, K factors or mathematical algorithms, changing of temperature and pressure coefficients and dilution ratio settings), and a written explanation of the procedures used to make the adjustments must be kept.
The requirements in Section 6.1.2 of Exhibit A to Appendix B must be met by any Air Emissions Testing Body (AETB) performing the semiannual/annual RATAs described in Section 2.3 of this Exhibit and the mercury emission tests described in Sections 1.15(c) and 1.15(d)(4) of Appendix B.
Keep a written record of the procedures used for daily calibration error tests and linearity checks (e.g., how gases are to be injected, adjustments of flow rates and pressure, introduction of reference values, length of time for injection of calibration gases, steps for obtaining calibration error or error in linearity, determination of interferences, and when calibration adjustments should be made). Identify any calibration error test and linearity check procedures specific to the continuous emission monitoring system that vary from the procedures in Exhibit A to Appendix B.
Explain how each component of the continuous emission monitoring system will be adjusted to provide correct responses to calibration gases, reference values, and/or indications of interference both initially and after repairs or corrective action. Identify equations, conversion factors and other factors affecting calibration of each continuous emission monitoring system.
Keep a written record of procedures and details peculiar to the installed continuous emission monitoring systems that are to be used for relative accuracy test audits, such as sampling and analysis methods.
The owner or operator shall keep a written (or electronic) record including a list of operating parameters for the add-on mercury emission controls, as applicable, and the range of each operating parameter that indicates the add-on emission controls are operating properly. The owner or operator shall keep a written (or electronic) record of the parametric monitoring data during each mercury missing data period.
Include procedures for inscribing or otherwise permanently marking a unique identification number on each sorbent trap for tracking purposes. Keep records of the ID of the monitoring system in which each sorbent trap is used and the dates and hours of each mercury collection period.
Explain the procedures used to perform the leak checks when sorbent traps are placed in service and removed from service. Also explain the other QA procedures used to ensure system integrity and data quality, including, but not limited to, gas flow meter calibrations, verification of moisture removal, and ensuring air-tight pump operation. In addition, the QA plan must include the data acceptance and quality control criteria in Section 8 of Exhibit D to Appendix B. All reference meters used to calibrate the gas flow meters (e.g., wet test meters) must be periodically recalibrated. Annual, or more frequent, recalibration is recommended. If a NIST-traceable calibration device is used as a reference flow meter, the QA plan must include a protocol for ongoing maintenance and periodic recalibration to maintain the accuracy and NIST-traceability of the calibrator.
Explain the chain of custody employed in packing, transporting, and analyzing the sorbent traps (see Sections 7.2.8 and 7.2.9 in Exhibit D to Appendix B). Keep records of all mercury analyses. The analyses must be performed in accordance with the procedures described in Section 10 of Exhibit D to Appendix B.
The QA Plan must include documentation that the laboratory performing the analyses on the carbon sorbent traps is certified by the International Organization for Standardization (ISO) to have a proficiency that meets the requirements of ISO 17025. Alternatively, if the laboratory performs the spike recovery study described in Section 10.3 of Exhibit D to Appendix B and repeats that procedure annually, ISO certification is not required.
State, and provide the rationale for, the minimum acceptable data collection period (e.g., one day, one week, etc.) for the size of the sorbent trap selected for the monitoring. Include in the discussion such factors as the mercury concentration in the stack gas, the capacity of the sorbent trap, and the minimum mass of mercury required for the analysis.
Keep records of the procedures and details peculiar to the sorbent trap monitoring systems that are to be followed for relative accuracy test audits, such as sampling and analysis methods.
2. Frequency of Testing
A summary chart showing each quality assurance test and the frequency at which each test is required is located at the end of this Exhibit in Figure 1.
Perform the following daily assessments to quality-assure the hourly data recorded by the monitoring systems during each period of unit operation, or, for a bypass stack or duct, each period in which emissions pass through the bypass stack or duct. These requirements are effective as of the date when the monitor or continuous emission monitoring system completes certification testing.
Except as provided in Section 2.1.1.2 of this Exhibit, perform the daily calibration error test of each gas monitoring system (including moisture monitoring systems consisting of wet- and dry-basis O2 analyzers) according to the procedures in Section 6.3.1 of Exhibit A to Appendix B, and perform the daily calibration error test of each flow monitoring system according to the procedure in Section 6.3.2 of Exhibit A to Appendix B. When two measurement ranges (low and high) are required for a particular parameter, perform sufficient calibration error tests on each range to validate the data recorded on that range, according to the criteria in Section 2.1.5 of this Exhibit.
For units with add-on emission controls and dual-span or auto-ranging monitors, and other units that use the maximum expected concentration to determine calibration gas values, perform the daily calibration error tests on each scale that has been used since the previous calibration error test. For example, if the pollutant concentration has not exceeded the low-scale value (based on the maximum expected concentration) since the previous calibration error test, the calibration error test may be performed on the low-scale only. If, however, the concentration has exceeded the low-scale span value for one hour or longer since the previous calibration error test, perform the calibration error test on both the low- and high-scales.
Except as provided in Section 2.1.1.2 of this Exhibit, all daily calibration error tests must be performed while the unit is in operation at normal, stable conditions (i.e., "on-line").
Daily calibrations may be performed while the unit is not operating (i.e., "off-line") and may be used to validate data for a monitoring system that meets the following conditions:
Perform the daily flow monitor interference checks specified in Section 2.2.2.2 of Exhibit A to Appendix B while the unit is in operation at normal, stable conditions.
When a monitoring system passes a daily assessment (i.e., daily calibration error test or daily flow interference check), data from that monitoring system are prospectively validated for 26 clock hours (i.e., 24 hours plus a 2-hour grace period) beginning with the hour in which the test is passed, unless another assessment (i.e., a daily calibration error test, an interference check of a flow monitor, a quarterly linearity check, a quarterly leak check, or a relative accuracy test audit) is failed within the 26-hour period.
The following specific rules apply to the invalidation of data with respect to daily assessments:
For the purpose of quality assuring data with respect to a daily assessment (i.e., a daily calibration error test or a flow interference check), a start-up grace period may apply when a unit begins to operate after a period of non-operation. The start-up grace period for a daily calibration error test is independent of the start-up grace period for a daily flow interference check. To qualify for a start-up grace period for a daily assessment, there are two requirements:
If both of the above conditions are met, then a start-up grace period of up to 8 clock hours applies, beginning with the first hour of unit operation following the outage. During the start-up grace period, data generated by the monitoring system are considered quality-assured. For each monitoring system, a start-up grace period for a calibration error test or flow interference check ends when either:
Record and tabulate all calibration error test data according to month, day, clock-hour, and magnitude in either ppm, percent volume, or scfh. Program monitors that automatically adjust data to the corrected calibration values (e.g., microprocessor control) to record either:
For each primary and redundant backup monitor or monitoring system, perform the following quarterly assessments. This requirement applies as of the calendar quarter following the calendar quarter in which the monitor or continuous emission monitoring system is provisionally certified.
Perform a linearity check, in accordance with the procedures in Section 6.2 of Exhibit A to Appendix B, for each primary and redundant backup, mercury monitor and each primary and redundant backup CO2 or O2 monitor (including O2 monitors used to measure CO2 emissions or to continuously monitor moisture) at least once during each QA operating quarter, as defined in 40 CFR 72.2, incorporated by reference in Section 225.140. For mercury monitors, perform the linearity checks using elemental mercury standards. Alternatively, you may perform 3-level system integrity checks at the same three calibration gas levels (i.e., low, mid, and high), using a NIST-traceable source of oxidized mercury. If you choose this option, the performance specification in Section 3.2(c) of Exhibit A to Exhibit B must be met at each gas level. For units using both a low and high span value, a linearity check is required only on the ranges used to record and report emission data during the QA operating quarter. Conduct the linearity checks no less than 30 days apart, to the extent practicable. The data validation procedures in Section 2.2.3(e) of this Exhibit must be followed.
For differential pressure flow monitors, perform a leak check of all sample lines (a manual check is acceptable) at least once during each QA operating quarter. For this test, the unit does not have to be in operation. Conduct the leak checks no less than 30 days apart, to the extent practicable. If a leak check is failed, follow the applicable data validation procedures in Section 2.2.3(g) of this Exhibit.
Within 14 unit operating days of the end of the calendar quarter for which the Ef value is above the applicable limit, investigate and troubleshoot the applicable flow monitors. Evaluate the results of each investigation as follows:
Perform a single-load RATA (at a load designated as normal under Section 6.5.2.1 of Exhibit A to Appendix B) of each flow monitor for which Ef is outside of the applicable limit. If the RATA is passed hands-off, in accordance with Section 2.3.2(c) of this Exhibit, no further action is required and the out-of-control period for the monitor ends at the date and hour of completion of a successful RATA, unless the option to use conditional data validation was selected under Section 2.2.5(c)(8) of this Exhibit. In that case, all conditionally valid data from the monitor are considered to be quality-assured, back to the first unit operating hour following the end of the calendar quarter for which the Ef value was above the applicable limit. If the RATA is failed, all data from the monitor will be invalidated, back to the first unit operating hour following the end of the calendar quarter for which the Ef value was above the applicable limit. Data from the monitor remain invalid until the required RATA has been passed. Alternatively, following a failed RATA and corrective actions, the conditional data validation procedures of Section 1.4(b)(3) of Appendix B may be used until the RATA has been passed. If the corrective actions taken following the failed RATA included adjustment of the polynomial coefficients or K factors of the flow monitor, a 3-level RATA is required, except as otherwise specified in Section 2.3.1.3 of this Exhibit.
For each primary and redundant backup monitoring system, perform relative accuracy assessments either semiannually or annually, as specified in Section 2.3.1.1 or 2.3.1.2 of this Exhibit for the type of test and the performance achieved. This requirement applies as of the calendar quarter following the calendar quarter in which the monitoring system is provisionally certified. A summary chart showing the frequency with which a relative accuracy test audit must be performed, depending on the accuracy achieved, is located at the end of this Exhibit in Figure 2.
Relative accuracy test audits of primary and redundant backup CO2 or O2 diluent monitors used to determine heat input, moisture monitoring systems, flow monitors may be performed annually (i.e., once every four successive QA operating quarters, rather than once every two successive QA operating quarters) if any of the following conditions are met for the specific monitoring system involved:
The owner or operator may perform as many RATA attempts as are necessary to achieve the desired relative accuracy test audit frequencies. However, the data validation procedures in Section 2.3.2 of this Exhibit must be followed.
Affected units may be subject to relative accuracy test audits at any time. If a monitor or continuous emission monitoring system fails the relative accuracy test during the audit, the monitor or continuous emission monitoring system will be considered to be out-of-control beginning with the date and time of completion of the audit, and continuing until a successful audit test is completed following corrective action. Alternatively, the conditional data validation procedures and associated timelines in Sections 1.4(b)(3)(B) through (I) of Appendix B may be used following the corrective actions.
For each mercury concentration monitoring system (except for a mercury monitor that does not have a converter), perform a single-point system integrity check weekly, i.e., at least once every 168 unit or stack operating hours, using a NIST-traceable source of oxidized mercury. Perform this check using a mid- or high-level gas concentration, as defined in Section 5.2 of Exhibit A to Appendix B. The performance specifications in subsection (3) of Section 3.2 of Exhibit A to Appendix B must be met, otherwise the monitoring system is considered out-of-control, from the hour of the failed check until a subsequent system integrity check is passed. If a required system integrity check is not performed and passed within 168 unit or stack operating hours of last successful check, the monitoring system will also be considered out of control, beginning with the 169th unit or stack operating hour after the last successful check, and continuing until a subsequent system integrity check is passed. This weekly check is not required if the daily calibration assessments in Section 2.1.1 of this Exhibit are performed using a NIST-traceable source of oxidized mercury.
[Note: The following TABLE/FORM is too wide to be displayed on one screen. You must print it for a meaningful review of its contents. The table has been divided into multiple pieces with each piece containing information to help you assemble a printout of the table. The information for each piece includes:
Figure 1 for Exhibit B of Appendix B - Quality Assurance Test Requirements
Test |
Basic QA test frequency requirements [FN*] |
|||||
Daily [FN*] |
Weekly |
Quarterly [FN*] |
Semiannual [FN*] |
Annual |
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Calibration Error Test (2 pt.) |
/ |
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Interference Check (flow) |
/ |
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Flow-to-Load Ratio |
/ |
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Leak Check (DP flow monitors) |
/ |
|||||
Linearity Check or System Integrity Check [FN**] (3 pt.) |
/ |
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Single-point System Integrity Check [FN**] |
/ |
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RATA (SO2, NOx, CO2, O2, H2O) [FN1] |
/ |
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RATA (All Hg monitoring systems) |
/ |
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RATA (flow) [FN1] [FN2] |
/ |
[FN*] "Daily" means operating days, only. "Weekly" means once every 168 unit or stack operating hours. "Quarterly" means once every QA operating quarter. "Semiannual" means once every two QA operating quarters. "Annual" means once every four QA operating quarters. [FN**] The system integrity check applies only to Hg monitors with converters. The single-point weekly system integrity check is not required if daily calibrations are performed using a NIST-traceable source of oxidized Hg. The 3-point quarterly system integrity check is not required if a linearity check is performed.
[FN1] Conduct RATA annually (i.e., once every four QA operating quarters), if monitor meets accuracy requirements to qualify for less frequent testing. [FN2] For flow monitors installed on peaking units, bypass stacks conduct all RATAs at a single, normal load (or operating level). For other flow monitors, conduct annual RATAs at two load levels (or operating levels). Alternating single-load and 2-load (or single-level and 2-level) RATAs may be done if a monitor is on a semiannual frequency. A single-load (or single-level) RATA may be done in lieu of a 2-load (or 2-level) RATA if, since the last annual flow RATA, the unit has operated at one load level (or operating level) for [GREATER THAN OR EQUAL TO] 85.0 percent of the time. A 3-level RATA is required at least once every five calendar years and whenever a flow monitor is re-linearized, except for flow monitors exempted from 3-level RATA testing under Section 6.5.2(b) of Exhibit A to Appendix B.
Figure 2 for Exhibit B of Appendix B - Relative Accuracy Test Frequency Incentive System
RATA |
Semiannual [FNW] (percent) |
Annual [FNW] |
SO2 or NOX [FNY] |
7.5% < RA [LESS THAN OR EQUAL TO] 10.0% or ± 15.0 ppm [FNX] |
RA [LESS THAN OR EQUAL TO] 7.5% or ± 12.0 ppm [FNX] |
SO2-diluent |
7.5% < RA [LESS THAN OR EQUAL TO] 10.0% or ± 0.030 lb/mmBtu [FNX] |
RA [LESS THAN OR EQUAL TO] 7.5% or ± 0.025 lb/mmBtu =G5X |
NOX-diluent |
7.5% < RA [LESS THAN OR EQUAL TO] 10.0% or ± 0.020 lb/mmBtu [FNX] |
RA [LESS THAN OR EQUAL TO] 7.5% or ± 0. 015 lb/mmBtu [FNX] |
Flow |
7.5% < RA [LESS THAN OR EQUAL TO] 10.0% or ± 2.0 fps [FNX] |
RA [LESS THAN OR EQUAL TO] 7.5% or ± 1.5 fps [FNX] |
CO2 or O2 |
7.5% < RA [LESS THAN OR EQUAL TO] 10.0% or ± 1.0 CO2/O2 [FNX] |
RA [LESS THAN OR EQUAL TO] 7.5% or ± 0.7% CO2/O2 [FNX] |
Hg [FNX] µg/scm |
N/A |
RA < 20.0% or ± 1.0 [FNX] |
Moisture |
7.5% < RA [LESS THAN OR EQUAL TO] 10.0% or ± 1.5% H2O [FNX] |
RA [LESS THAN OR EQUAL TO] 7.5% or ± 1.0% H2O [FNX] |
[FNW] The deadline for the next RATA is the end of the second (if semiannual) or fourth (if annual) successive QA operating quarter following the quarter in which the CEMS was last tested. Exclude calendar quarters with fewer than 168 unit operating hours (or, for common stacks and bypass stacks, exclude quarters with fewer than 168 stack operating hours) in determining the RATA deadline. For SO2 monitors, QA operating quarters in which only very low sulfur fuel as defined in 40 CFR 72.2, incorporated by reference in Section 225.140, is combusted may also be excluded. However, the exclusion of calendar quarters is limited as follows: the deadline for the next RATA will be no more than 8 calendar quarters after the quarter in which a RATA was last performed.
[FNX] The difference between monitor and reference method mean values applies to moisture monitors, CO2 and O2 monitors, low emitters of SO2, NOX, or Hg, or and low flow, only. The specifications for Hg monitors also apply to sorbent trap monitoring systems.
[FNY] A NOX concentration monitoring system used to determine NOX mass emissions under 40 CFR 75.71, incorporated by reference in Section 225.140.