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WÄRTSILÄ TECHNICAL JOURNAL 02.

2008

Quality assurance of automated


emission monitoring systems
A U T H O R : J a n To r r k u l l a , S e n i o r D e v e l o p m e n t E n g i n e e r, W ä r t s i l ä Po w e r P l a n t s i n F i n l a n d

Assuring high quality emission Purpose of monitoring in situations where critically high
monitoring is not only about ensuring Monitoring of a process or an activity should emissions, which endanger the health
accurate analyzers. It is the whole not be performed for the pure pleasure of and safety of people, can occur.
process, from the reason for creating data. The General EHS Guidelines 2) Process feedback: The emission
monitoring, to the implementation, by IFC/WB recommend a systematic data is used to control the process,
to assuring the quality of the data. planning process to ensure that the data for example to control the amount
collected are adequate for their intended of combustion air in a boiler.
Table 1 below lists three quality purpose (and to avoid collecting unnecessary 3) Emission verification: Emission
assurance steps, the consideration of which data)1. When choosing between different monitoring is used to verify emission
is a prerequisite for successful emission approaches to emission monitoring, there compliance or to quantify emissions as
monitoring. This article will give some must be a balance between the availability part of an emission trading scheme.
guidance on aspects to consider when of the method, its reliability, the level of
evaluating the monitoring needs, and also confidence, the costs and the environmental The nature of a process very much
look into the quality assurance of monitoring benefits2. determines the need for emission
data. The relatively new EN 14181 standard monitoring. The different emission profip les
is presented and a procedure for cost Reasons for monitoring emissions from shown in Figure 1, clearly call for different
efficient quality assurance is proposed. a power plant or process include: types of monitoring and monitoring
The monitoring equipment itself is handled 1) Emergency response: The emission frequency. For those emission sources that
in the following article. monitoring is used to avoid and alarm may exhibit excursions with very high p

1
Careful evaluation of the purpose of the monitoring
to choose the correct monitoring approach.

2
Selection of equipment recognizing the specific
features and requirements of the application.

3
On-going assurance of the quality of
the monitoring system and of the monitoring data.

Table 1 – Three steps in ensuring monitoring quality.

1
IFC: Environmental, Health, and Safety (EHS) Guidelines. GENERAL EHS GUIDELINES, p. 10.
2
European Commission: Integrated Pollution Prevention and Control (IPPC) – Reference document on the general principles of monitoring, p. 7.

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[ ENERGY / IN DETAIL ]
[ ENERGY / IN DETAIL ]

Risk Unstable Stable


process process process

Fig. 1 – Three processes with different emission profiles calling for different types of monitoring.

emissions and for unstable processes, it is Quality assurance is obtained by an extensive set of at
typically justified to apply a high level of according to EN 14181 least 15 data pairs of standard reference
monitoring. The current diesel engine is As of today, implementing the EN14181 method results and monitoring system
a stable process with only small variations and EN13284-2 directives is mandatory data, spread out over at least three days.
in emission levels, and excursions in only for plants which are covered by the - The statistical variability of the data is
operating conditions with very high Waste Incineration Directive (WID)6 and calculated and is used to verify that
emissions do not occur. Source testing the Large Combustion Plant Directive the monitoring system fulfils
supported by parametric monitoring is (LCP)7. Note that engine driven plants are the requirements set on the monitoring
a powerful tool for validating that plants specifically excluded in the LCP directive, system.
are being operated in accordance with even when the plant size is above the trigger This procedure is to be repeated every
requirements. For stable processes, time- of 100 MWth. 5 years, or when triggered by the AST
sharing of analyzers is also a natural way of The EN 14181 standard specifies how or by a significant process change or
providing more cost-efficient monitoring. the selection of equipment, installation modification to the monitoring system.
verification and calibration, as well as
Assuring quality of data on-going and yearly quality checks shall QAL-3
Recognizing the fact that the monitoring be performed. The procedures are outlined QAL-3 is a procedure to maintain and
of emissions involves a lot of potential in Figure 2. The main features of the demonstrate the required quality of the
error sources, it is crucial that the quality different parts of the quality process are measurement results during the normal
of the measured data is assured and described below. operation of a monitoring system, It
that sources of errors can be identified works by checking that the zero and
and corrected. In the United States, QAL-1 span characteristics are consistent with
standards of performance for continuous The monitoring has to be performed by those determined during QAL-1.
emission monitoring systems are given equipment suited to the purpose. The
by US EPA 40 CFR 60 and 753. The suitability of a measurement procedure is AST
EN 141814 standard and EN 13284-25 evaluated by comparison with the required The purpose of the annual surveillance
standards unify the quality assurance of measurement uncertainty. This procedure tests (AST) is to evaluate that the
automatic monitoring systems within the is described in the EN ISO 14956. monitoring system functions correctly
European Union. The quality assurance and that its performance remains valid.
requirements of the EN 14181 standard QAL-2 It also verifies that the calibration
will be discussed more in detail here. A This is the onsite validation of the function and variability remain as
simplified quality assurance process is also measurement equipment after installation. previously determined during QAL-2.
proposed. This approach will enable cost- The main steps in the process are:
efficient quality assurance, especially in - Validation of the installation. A simplified and cost-efficient
projects where there is not an adequate - Calibrating the monitoring system quality assurance process
infrastructure to support the relatively using standard reference methods. The requirements set forward by
demanding EN or US requirements. A calibration curve for the instruments standards such as the EN 14181, are

3
EPA TITLE 40 – Protection of Environment: Part 60 Standards of Performance for New Sources and Part 75 Continuous Emission Monitoring.
4
EN 14181: Stationary source emissions. Quality assurance of automated measuring systems.
5
EN 13284-2: Stationary source emissions. Determination of low range mass concentration of dust. Part 2: Automated measuring systems.
6
DIRECTIVE 2000/76/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 4 December 2000 on the incineration of waste.
7
DIRECTIVE 2001/80/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 23 October 2001 on the limitation of emissions of certain
pollutants into the air from large combustion plants.
8
UK Environment Agency: Technical Guidance Note (Monitoring) M20. Quality assurance of continuous emission monitoring systems - application
of BS EN 14181 and BS EN 13284-2.

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WÄRTSILÄ TECHNICAL JOURNAL 02.2008

Correct
Suitable Continuing
installation &
CEMs functionality
calibration

QAL-3
QAL-1 QAL-2
Annual
surveillance test

Fig. 2 – The sequence of quality assurance levels in EN 14181 .

typically very demanding. Even though II – Functional checks who is performing the verification of
the need for quality assurance of data is A functional test of the system is the plant emission compliance. It is
obvious, requiring the implementation performed to verify the monitoring recommended that the evaluating party
of the standards in all projects involving performance of the system. The provides a written statement that an
continuous emission monitoring is not demanding QAL-2 procedure described adequate quality system has been put
always the correct medicine. The quality in EN 14181 is replaced by: in place. If required, the inspection can
assurance requirements need to take 1. Verification of zero and span calibrations. be witnessed by the relevant authority.
into consideration the properties of the 2. The function of the monitoring system
plant, as well as the infrastructure and can be verified by a simplified Quality assurance for
the conditions where the monitoring comparison to reference method data. time-shared analyzers
system is installed. Overambitious Measurements recorded during Time-sharing of one or several analyzers
quality procedures may even draw compliance plant performance can be used as a means of reducing
the attention away from assuring that testing can be used for this purpose. the monitoring burden of plants with
the basic requirements are in place. multiple units. If all are operating under
Engine driven plants typically involve III – Continuous quality assurance equal conditions resulting in equal flue
multiple relatively small units, and are The successful operation of a monitoring gas properties, it shall be considered
often installed in locations where the system relies very much on everyday adequate to perform a more in-depth
infrastructure for continuous quality routines. To facilitate this, a follow-up calibration for one complete path per
assurance and maintenance is only system shall be put in place to ensure that: analyzer, including sampling, sample
developing. It is obvious that there is 1. There are assigned and trained conditioning and analyzer. For the other
a clear need to develop a simplified resources at the plant to manage same type of sources being monitored
procedure for assuring the quality of the monitoring equipment. by the same analyzer, a functional check
the monitoring systems. This kind 2. The service and maintenance of the of the sampling system, including a
of validation has been performed on system is performed regularly leak check, is to be performed.
a voluntary basis by conscientious by trained personnel.
plant and process owners/operators. 3. There is a procedure in place for CONCLUSION
The number one priority should be to performing regular calibration checks. Successful monitoring needs to be
ensure that the system is working, and The interval for this may depend supported by quality assurance procedures
to maintain it in working order. If the on the type of monitoring which take the specific features of the
long term maintenance of the system is system and plant. plant or process into consideration.
neglected, putting a lot of resources into 4. There is a system in place for Engine driven power plants often include
an exhaustive calibration and validation documenting the quality assurance of multiple, relatively small, units and
process is not justified. Below, the the monitoring system. This includes are delivered to locations lacking the
main features of a simplified and cost documenting maintenance actions, infrastructure for, and a tradition of,
efficient QA/QC process are outlined: performed calibrations, malfunctions quality assurance. An approach for cost-
and reasons for these. Specifically efficient quality assurance in this type
I – Verification of the installation note that checks when everything of project has been presented in the
The correct installation of the system was OK should also be documented. text. It is recommended that a similar
is evaluated. This includes checking quality assurance is applied in projects
the physical installation as well as Parts I & II can be performed by the where quality assurance is not directly
verifying measurement ranges, etc. monitoring system supplier or by an specified by some other standard.
external consultant, e.g. the same party

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