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Other U.S. QA Procedures

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QA requirements for acid rain Part 75 CEM systems were promulgated along with the implementing rule and are found in 40 CFR 75 Appendix B (U.S. EPA 2020h). The requirements include procedures for SO2 and NOx monitoring systems, O2 and CO2 diluent monitors, and flow monitors. The flow monitoring procedures are especially important because none are given in Part 60 Appendix F. It is obvious from Equation 2‐1 that the flow measurement is as equally important in pollutant mass emission rate determinations as is the gas measurement. The flow monitoring performance audit procedures such as the “flow‐to‐load ratio test” and semiannual/annual relative accuracy test audits are valuable, if not necessary for assuring accurate flow measurements.

The acid rain program, NSPS, and air toxics monitoring programs all include requirements for writing a plant‐specific CEM QA plan and periodic performance testing. Although Appendix F applies only to those NSPS sources that use CEM systems for compliance, many states have viewed CEM quality assurance as integral to their own programs and have patterned QA requirements after those of Appendix F. Even if not required to implement a QA program, a source should develop a QA plan if it wishes its CEM data to be legally defensible.

Continuous Emission Monitoring

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