Development of Quality Assurance Plans for Continuous Emission Monitoring Systems at Georgia Pacific's Woodland, Maine Pulp and Paper Mill, 1993 Environmental Conference Proceedings

Sarah Hood, Mark Hanson

Federal regulations contained in 40 CFR Part 60 - Appendix F “Quality Assurance Procedures,” 40 CFR Part 75 - Appendix B “Quality Assurance and Quality Control,” and individual state legislation dictate that utilities and industrial facilities operating Continuous Emission Monitoring Systems (CEMS) must develop and implement a Quality Assurance Plan (QAP) which will ensure a complete and accurate CEMS data base. At a minimum the QAP should include:

- Calibration Error Test Procedures

- Calibration Adjustment Procedures

- Preventative Maintenance Procedures

- Audit Procedures

- Record Keeping and Reporting Procedures

The QAP is developed as a complete, comprehensive document which defines all aspects and interpretations of the CEMS program. As such, the QAP should be treated as the facility’s “Operational Law.” The QAP must be developed and designed with direct input from the facility’s management and technical staff and formatted to allow for flexibility to be adjusted as operations change. The QAP should be routinely reviewed and modified to reflect plantwide operating experience and technical changes in the CEMS and support procedures. The QAP should also include practical checklists, reference sheets, and forms to assist in the day-to-day implementation of the quality assurance procedures.

Georgia Pacific Corporation’s (GP’s) approach to QAP development described in this paper is based on a multiple-volume document which addresses the typical source configuration of a pulp and paper mill. Volume I of the QAP is an Overview of all the CEMS and facility descriptions and policies as they apply to all mill sources. Subsequent volumes are source specific and are designed to directly assist mill staff responsible for the implementation of the CEMS quality assurance program. These source specific volumes emphasize routine maintenance, corrective action, record keeping, and inventory control procedures.