Do Your Continuous Emission Monitors Need to be PG/7 Compliant?

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By: Tina Sanderson

Does your facility have Continuous Emission Monitors (CEMs) installed to analyze or monitor:

·         combustion gases including carbon monoxide, carbon dioxide, nitrogen oxides, oxygen and sulphur dioxide;

·         pollutants such as ammonia, hydrogen chloride, particulate matter, total reduced sulphur and volatile organics;

·         volumetric flowrate;

·         moisture; and/or

·         temperature? 

If you have CEMs, do you know if you have compliance analyzers or process monitors? And why does it matter?

The Issue

In most cases it is easy to determine if your facility has compliance analyzers; the facility is required through their environmental permit to install and operate CEMs for the parameters listed in the permit. 

But what about those analyzers that measure parameters not specifically listed in the permit, such as carbon dioxide, volumetric flowrate or moisture?  Or monitors used to optimize the process?  Many facilities regard these components of the system as process monitors.  However, if the data generated from the process monitor is being used to determine annual emissions for reporting to the National Pollutant Release Inventory (NPRI), Greenhouse Gas Reporting or other reporting initiatives then the expectation is that you are operating the analyzers to a compliance quality standard.

Unfortunately some facilities find out too late, usually after an unfavourable audit, that the CEMs they are using are not being operated and maintained appropriately.  In most cases, it is expected that analyzers being used to generate data for federal and provincial reporting initiatives are installed and operated in accordance with Environment Canada Report EPS 1/PG/7, “Protocols and Performance Specifications for Continuous Monitoring of Gaseous Emissions from Thermal Power Generation”, December, 2005 (PG/7) (Note: regulators commonly apply this protocol to a wide range of industrial facilities, not just thermal power generation).

What are the requirements of PG/7?

PG/7 details installation requirements and performance specifications that must be met to ensure the data is of the highest quality possible.  At a minimum the analyzers must pass the following performance specifications:

·         daily zero and span calibration drift using either protocol gases or gases certified to an accuracy of 2% for each component measured;

·         quarterly Cylinder Gas Audit (CGA) using protocol gases for each component measured and a quarterly Stack Gas Flow Test if volumetric flowrate is measured;

·         semi-annual Relative Accuracy Test Audit (RATA) for each component measured (may be waived to an annual basis if certain relative accuracy and availability requirements are met);

·         annual availability for each component; and

·         annual independent inspection of the CEMs. 

 In addition to the performance specifications listed above, the facility must have a Quality Assurance/Quality Control Manual that details the activities that must be implemented to ensure that the data generated by the CEMs will be complete, accurate and precise.  The manual should be reviewed and updated on an annual basis typically after the independent inspection.

What happens next?

Your environmental consultant should ensure that your facility is meeting or exceeding the requirements of PG/7 including:

·         Preparation of Quality Assurance/Quality Control Manuals.

·         Managing a facility’s performance evaluation requirements to ensure that quarterly, semi-annual and annual evaluations are scheduled and conducted to meet the requirements of PG/7.

·         Conducting Relative Accuracy Test Audits, Flow Audits and Cylinder Gas Audits.

·         Conducting Annual Independent Inspections to ensure that facilities are meeting the Quality Assurance objectives of PG/7 and identifying areas of improvement.

·         Conducting on-site training to ensure facility personnel understand the requirements of PG/7 and the importance of the Quality Assurance/Quality Control Manual.

·         On-going technical support to aid facilities in interpreting PG/7 and understanding how it applies to their facility.

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