EPA-AA-TSS-83-8-A
          Technical Report
      EPA RECOMMENDED PRACTICE
  FOR NAMING I/M CALIBRATION  GAS:
   A DISCUSSION FOR  I/M PROGRAMS
           September 1983
       Technical  Support  Staff
Emission Control Technology Division
      Office of Mobile Sources
    Office  of  Air  and  Radiation
U.S. Environmental Protection Agency
     Ann Arbor, Michigan  48105

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                           Abstract
This  report  explains how  calibration  gases are  used  in  I/M
programs,  and  introduces  a  Recommended  Practice  for  gas
manufacturers   to   use  when   naming   I/M  calibration   gas
cylinders.  Details of the  Recommended  Practice  are presented
in  a  separate  report  entitled  "RECOMMENDED  PRACTICE  FOR
NAMING  I/M  CALIBRATION  GASES"   (EPA-AA-TSS-83-8-B).   States
are  encouraged  to  procure gases  named  according  to  this
Recommended  Practice  for  their  own  use,  and  to  require
licensed  inspection  stations to  procure  them  to  ensure  that
they  are  obtaining accurate calibration gases which  meet  the
terms  of the  Emission Control  System Performance  Warranty,
and to improve the general quality of their I/M programs.

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                      Table of Contents

                                                       Page
1.0   BACKGROUND                                         1
1.1   EPA Regulations Concerning Calibration
      Gas Accuracy                                       1
1.2   What are NBS Standards, and How Are They
      Used to Make Accurate Gases?                       2
1.2.1 NBS Weight Standards                               2
1.2.2 NBS Gas Standards                                  2
1.3   EPA Efforts to Help States Obtain
      Accurate Gases         .                            4

2.0   DISCUSSION                                         5
2.1   Selecting Components                               5
2.1.1 Propane and Hexane                            .6
2.1.2 Diluents                                           8
2.2   Concentration of I/M Calibration Gases             9
2.2.1 Warranty Requirements                              9
2.2.2 State Requirements - C02 Concentration            10
2.2.3 State Requirements - Carbon Monoxide -
      Propane Interference                              10
2.3   Cylinders and Hardware                            11
2.4   Cylinder Labels and State Audits                  12
2.5   EPA Audits                                        13

3.0   RECOMMENDATIONS                                   13
                          Appendices

Appendix 1 Emission Performance Warranty Regulations
           Pertaining to Calibration Gases

Appendix 2 Carbon Monoxide - Propane Interference

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1.0 BACKGROUND

Inspection  and  Maintenance  (I/M)   programs  are  now  fully
operating in  seventeen  States,  and other States  are  expected
to  implement  I/M  programs, in  the  coming  months.   Many  I/M
managers  are  concentrating  on   implementing   and  refining
program  quality  assurance  procedures  so  that  motorists  .can
obtain fair and accurate tests of their cars' emissions.

One of  the  benchmark quality assurance procedures  which  will
be used  by  every I/M program is  the periodic check  of every
inspection  analyzer  with   a   calibration   gas  of   known
concentration.   This  is  the   only  method  of  checking  how
accurately  a  given  analyzer   is   reading  vehicle   exhaust
emissions.  The calibration check is performed by flowing the
calibration gas into the analyzer and  determining whether the
analyzer  is  reading this  calibration  gas correctly.    If  the
analyzer  is not reading  this  calibration  gas accurately,  then
a simple  adjustment  of  the analyzer can  usually  be performed
which will result in the analyzer being accurate  again.

For gas calibration  checks  and  related adjustments  to be done
properly,  the  accuracy   of  the   calibration   gas  used  is
critical.  However,  because of  a lack of standard procedures
in  the  gas blending industry,   it  is not   safe  for   the  I/M
manager  to assume  that  calibration  gases  have  been  named
properly  and  are  traceable to known standards  (NBS).   If the
labeled concentration of the  calibration  gas is  significantly
different  from the  true concentration  in  the  cylinder,  the
analyzer    could    become     significantly    misadjusted.
Furthermore,  an  operator  who  had  performed the calibration
would  be unaware  that  he/she  had  actually misadjusted  the
analyzer, since  he/she trusted  the  label  on  the calibration
cylinder  to be correct.

In light  of  its  potential   significance,   EPA  has  been working
with the  gas  industry  over the  past several years to  identify
a  way   to   resolve  this   problem.   The   result  of  these
activities  is the Recommended  Practice  which is  referred to
in this  report and  discussed  in detail in the parallel report
("EPA Recommended  Practice  for  Naming  I/M Calibration Gases,"
EPA-AA-TSS-83-8-B).                     .

1.1 EPA Regulations Concerning Calibration Gas Accuracy

In  1980  the  EPA  promulgated  Emission  System  Performance
Warranty  Regulations  for  1981  and   later  vehicles  which
entitle  a vehicle  owner  to  emission-related repairs  at  the
manufacturer's  expense  if, among  other  things,  the  vehicle
fails  an "approved"  emission  short test.   One   condition is
that  the analyzer  used  to conduct the  emission  short  test

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                             — e.

must be checked with gases  "traceable  to  NBS  [National Bureau
of  Standards]  standards +2%"  at  least once  per week.   (See
Section  85.2217,  45 FR 34808, May 22,  1980.   The  relevant
portion  of  this  page  is  provided  in  Appendix  1  to  this
document.)   Many  States implementing  I/M programs will  want
to  meet  the  quality  assurance requirements  of the  Warranty
regulations  so that eligible  consumers participating  in their
I/M  programs  will  have  the  benefit  of receiving  warranty
repairs from  the automobile manufacturers.  These  States  must
make  sure  that  the  gases  used   to  periodically  calibrate
analyzers  used  in  their  I/M  programs  meet  the  regulatory
requirement of having an accuracy of +2% to NBS standards.

1.2 What  Are NBS  Standards and  How  Are They  Used   to  Make
    Accurate Calibration Gases?

A  standard  is an  object  to which  other  similar  objects are
compared.   The National Bureau of  Standards takes  the utmost
care  in  maintaining   in-house standards of  many  different
kinds.   The  standards  of   concern  in   obtaining  accurate
calibration  gases   are  weight  standards  and  gas  standards.
These standards can be  used in a  variety  of ways in obtaining
accurate calibration gases.  Some of these ways  are better at
obtaining accurate calibration gases than others.

1.2.1 NBS Weight Standards

NBS   weight  standards  can   be   used   in  making   accurate
calibration   gases  by  weighing   in   certain  masses   of
calibration  gases  into a cylinder.   For  example,  a  cylinder
with a desired concentration  of 1000 ppm  carbon monoxide   (CO)
in  nitrogen might  require  300 grams of CO  to achieve  that
concentration.   The  cylinder  is   first  emptied  and  then
weighed  with a  scale  calibrated  with  the  NBS  weights.   The
300  grams  of  CO are  then pumped   into  the  cylinder.   Then
nitrogen  is  added  to  the  cylinder  in  a  certain weight  to
yield the  1000 ppm CO  with  an appropriate pressure.   The CO
mixture  might then be considered  partly "traceable  to  NBS"
via  the  NBS weight standards.  At  least  some members  of the
gas  manufacturing   industry  do not consider   a  mixture  made
with  this method  to  be  entirely  "traceable  to NBS".   They
feel  that  the  mixture should be  compared  to  some   NBS  gas
standards   using   a  gas   analyzer  before  the  mixture  is
considered  "traceable   to  NBS".   EPA  agrees   that a  mixture
made  solely using  the  weight-based method  is  not  "traceable
to  NBS",  particularly  as  that phrase  was  intended  in  the
Warranty regulations.

1.2.2 NBS Gas Standards

The  National  Bureau  of  Standards  tries to  make  available
standard  gases  in  commonly requested  concentrations.   Until

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                             -3-

1981, the  only NBS standards  available  were called  Standard
Reference Materials (SRM's).  SRM's have a  maximum analytical
uncertainty of +1%  to  the  true value of the  concentration  in
the  cylinder.   The  analytical  uncertainty  is  usually  less
than j+0.5% of true value.

EPA has  required  SRM's  as  the  standards to which  calibration
gases used in many mobile and  stationary source  programs have
to  be  traced.   This created  a  large  demand for  SRM's  since
the  tracing  process consumes  the  SRM's.   Also, the  analysis
procedures  for SRM's  are  very  detailed  and lengthy.   These
two factors have  resulted in SRM's being in short  supply.   To
alleviate  this  problem,  the  EPA  Emission  Monitoring  and
Support  Laboratory  at   Research  Triangle  Park  (EMSL-RTP)  and
NBS  jointly   developed procedures   that  would   allow  gas
manufacturers  to  make  a   new   kind  of  standard,  called  a
Certified  Reference Material  (CRM),  which  if  made  properly
has  a   maximum uncertainty  of  about +1.3%  to   true  value.
These CRM's can be  made in  batch quantities,  but  a limitation
of  these CRM's is  that their  concentrations cannot be more
than about  +1%  different  from  current  SRM concentrations.
These CRM's  are  themselves NBS standards,  and a  gas mixture
which is traceable to a CRM is  "traceable to NBS".

NBS  gas  standards can   be used  in making I/M calibration  gas
by  comparing  the standards  to an I/M  gas  mixture  after  the
I/M  gas mixture  has been  blended into  a  cylinder.   Usually
the  instrument being used  to analyze a mixture  is calibrated
or  checked with  NBS gas standards first, then .the instrument
is  used   to   determine the   concentration  of   the  subject
mixture.   The  mixture   is then  considered   "traceable to NBS"
since  NBS  standards   were  used  to   calibrate  or check  the
instrument used in analyzing the I/M gas.

Generally,   gas   manufacturers  agree  that  the   method   of
demonstrating  traceability  between a gas mixture  and NBS  gas
standards  is  a  better  method   than  the weighing technique,
when  NBS  gas  standards exist  for  a  given  gas  mixture,*
because  of  several  possible sources  of errors  in  the latter.
(For instance,  in the   weighing  method  improper  evacuation of
the  cylinder prior  to  filling can cause the concentration of
the  cylinder  to  be significantly different  from  its intended
concentration.    Errors  can   also   occur    in  the   filling
process.)   However,  even though  there  is  agreement  that  the
gas  standard  comparison procedure is probably best,  there is
*  There  are  no  NBS  gas   standards  for  hexane,  therefore
traceability  to  NBS within  the  Recommended  Practice  can only
be  obtained  with   the  weighing  technique.   The  Recommended
Practice  requires  hexane gases  to  be   checked  with  a  gas
analyzer   against  the   manufacturers'   gravimetric    (i.e.,
weighed-in) primary hexane standards.

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                             -4-

little  agreement  among  manufacturers about  what  analytical
techniques  are  best  when  comparing  NBS gas  standards  with
other  gas  mixtures.   These  different  analytical  procedures
and  methods of handling  data  may  cause differences  in  the
concentrations of  identically labeled calibration  gases  made
by different  manufacturers  or even by the  same  manufacturer.
I/M  managers  would   find   it  difficult  to   detect   these
differences and  identify which  gas  cylinders were  correctly
labeled,  unless  they  maintain a  sophisticated  gas  analysis
program of  their own.

1.3 EPA  Efforts  to Help States  Obtain  Accurate  Calibration
    Gases

In order  to improve the general  quality of I/M programs  and
to  help  States  in  meeting  the  calibration  gas  accuracy
requirement of the Warranty  regulations,  EPA  has  developed  a
standard  procedure which   can be  used  to  accurately  name
calibration  gas   traceable   to NBS.    In a  separate  report,
entitled."EPA RECOMMENDED PRACTICE FOR NAMING  I/M  CALIBRATION
GASES"  (EPA-AA-TSS-83-8-B) ,  the  "Recommended  Practice,"  which
individual  States  can require gas manufacturers to  follow in
naming  and  labeling calibration gas  for their  I/M programs,
is outlined in detail.   A  State requirement could  be  imposed
by the  State  in  its own purchases of gas and  by establishing
rules  and  regulations  which  require  other  I/M  gas  users
(contractors or licensed inspection stations)  to buy only gas
that  the  manufacturer  certifies  to  be  named  and  labeled
according  to the  Recommended Practice.   Such  a  requirement
would assure  consistent gas quality among  both  manufacturers
and  inspection stations.

Because  of  the lack  of agreement among gas  manufacturers as
to the  analytical  procedures for tracing gas  mixtures  to NBS
standards,  EPA has  taken the initiative  in  selecting a  single
set  of   procedures   which   it  believes  represents  a   good
compromise  between cost and quality.   A  special   effort  has
been  made  to make  these   procedures  workable  from  a  gas
manufacturer's  viewpoint.    A meeting of  representatives  of
the  gas  manufacturing  industry,  the  National   Bureau  of
Standards  and the  EPA  was  held  to  decide  on  the  original
framework  of the  procedures.  Manufacturers  have also  been
allowed  to  comment  on  the  draft  forms of   the  Recommended
Practice, and  many of  their comments have been incorporated
into the procedures.

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                             -5-

2.0 DISCUSSION

2.1 Selecting Components of I/M Calibration Gases

The primary  criterion for  the user  to  consider  in  deciding
which  components  to  include  in  the  calibration  gas is  the
kinds  of  pollutants measured  in  the I/M  program.   Some  I/M
programs measure only  for  CO  emissions;  most measure both  HC
and CO; and  a few measure  HC,  and/or CO,  and  C02«   Whenever
a  particular  pollutant   is   measured,    then   the   analyzer
accuracy  for  that pollutant  should be periodically  verified
with a calibration gas.

In those  I/M programs  which  measure only CO,  the State  may
feel that  it  is  necessary  only to  calibrate analyzers with  a
CO  calibration gas.   However,  because  inspection  analyzers
also measure  the HC  in  the  exhaust, and  because mechanics  use
these  HC  measurements along with CO  measurements  for tune-up
adjustments   and    for   diagnosing   problems   causing   high
emissions  and/or  poor fuel economy,  EPA  recommends  that  the
State  also  require periodic  calibration  checks  of the  HC
channel of the analyzer.   EPA feels that the  extra  cost  of
calibrating  for  both HC and  CO is not  significantly greater
than the  the cost  of  calibrating  for only  CO  and that  this
cost is greatly  outweighed  by the  benefits  of  better quality
of service to the public.

Some  States  are  also  requiring  the measurement of C02  in
order  to  ensure  that emission measurements are  not  biased  by
improper  probe  insertion  depth  or  exhaust  system  leakage,
both of which may  cause dilution of  exhaust gases and,  thus,
lower  emission  readings.    Whenever C02  measurements   are
required,  the State should also  require periodic  calibration
checks  of the C02  channel with  a C02  calibration  gas.   In
this  case,  the   issue  arises as  to  whether  the  C02  gas
should be  included  along  with HC and CO  (and diluent)  in  the
same cylinder or  whether  the C02  gas  should  be  obtained  in
a  separate cylinder.   At the  heart  of this issue is  the  basic
traceability  issue.   Introducing C02 into  the HC/CO/diluent
blend  greatly changes  the  viscosity of   the mixture thereby
confounding   analysis  of   the  HC  component   by   the  flame
ionization  technique  (which  is  currently  the  best  technique
for  traceability  for HC) .   There  is   also  an. interference
effect  between   measurements  of  CO   and  C02  using   the
non-dispersive infrared  technique,  thus confounding  analysis
of  these  two components.   These  problems  can  be  overcome  by
performing gas analysis using gas chromatography.

Some  proponents  of  C02   inclusion  in  the  calibration  gas
mixture  argue that  because C02  is  a  normal   constituent  of
auto  exhaust, there  is  some  degree  of  C02 interference  in
the  I/M  analyzer's  CO readings.   They  conclude,  therefore,
that it  would be  beneficial  to  have C02  in the  calibration

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                             -6-

gas so  that the calibration  gas  would more closely  simulate
auto exhaust.  Again,  establishing  traceability,  as discussed
above,  is a  basic problem.   Another  consideration  here  is
that the  amount  of C02 in auto exhaust varies between  6  and
14%, depending on  the  condition of  the  vehicle and  whether an
air pump  and/or  catalytic converter  is used on  the  vehicle.
Because  this  variability is  unpredictable  among  vehicles,
including   CC-2    (one   specific    concentration)    in   the
calibration gas  is just  as  likely to introduce new errors as
it is to correct existing ones.

In  light  of  the above,   EPA  recommends  that  all  States  use
calibration gases  which  include HC and CO.  For  those  States
which  require  CC>2  measurements,  EPA  recommends  that  the
C02  calibration  gases  be  obtained  in  separate  cylinders
unless  the   traceability  issues  discussed  above  can   be
adequately addressed.

Two   side  issues  related   to  selecting  calibration   gas
components are discussed  below.  Section  2.1.1 discusses  the
hexane  versus  propane  issue,  and Section  2.1.2 discusses  the
issue surrounding  the  choice of diluents.

2.1.]. Propane versus Hexane

Even  though  analyzers  measure  HC  emissions  in  terms  of
hexane,  analyzers  have   traditionally  been  calibrated  with
propane.   This  is because propane  is  an  easier  gas to  work
with and  is more commercially available.

Because  propane  is  the   traditional  calibration  gas and  the
analyzer  actually measures  only the  "hexane equivalent"  of
all non-hexane  gases,  analyzer manufacturers  must  establish,
during  the  manufacturing  process, a  ratio called  the propane
equivalency  factor  (PEF)  for  each  analyzer  they  build.   An
analyzer's  PEF   defines   the  optical  relationship  between
propane  and  hexane  for  that  particular  analyzer's  optical
bench.  PEF values generally  range  from 0.48.to  0.56  for good
quality  I/M  analyzers.  An analyzer  which has  a PEF of  0.52
will  provide  a  reading  of  520 ppm  HC  (measured  as  hexane)
when  calibrated  properly and  checked  with a  calibration  gas
with  a  concentration  of 1000 ppm  propane.   (The  general
formula  is:   Analyzer  Response  (hexane)  = PEF x  Calibration
Gas Concentration  (propane).)  This  kind of calculation  has
to  be  performed  each   time  an   analyzer   is   checked  for
calibration.

Some  I/M  program  officials feel  that it  is  more  appropriate
to  use hexane  as  the calibration  gas and,  thus, to  avoid
having  to  perform  the   PEF   calculations  and  the  possible

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arithmetic errors associated with them.   In  addition,there  is
concern  that  the  PEF  value  for  a particular  analyzer may
change during the analyzer's useful life.

There are  two  constraints  which make the use  of hexane as  a
calibration gas  more  difficult than using  propane.   First,
hexane has a  low vapor pressure which  causes  it to  condense
on the cylinder  walls at certain combinations of  temperature
and   concentration   levels.     Table   1   illustrates  the
relationship  of  temperature  and  concentration  at  a  normal
cylinder pressure (for a class 1-A cylinder)  of 2000 psi.

                           Table 1

            Theoretical Dew Point Temperatures  of
          Certain Hexane Concentrations  at 2000 psi

        Dew Point Temperature     Hexane Concentration

                81°F                  1600 ppm
                61°F                  1000 ppm
                43°F                   600 ppm
                28°F                   400 ppm
                 7°F                   200 ppm
               -15°F                   100 ppm

The  proper  interpretation  of  the  information  in  Table 1  is
that,  theoretically,  a mixture  of  600  ppm  will  begin  to
condense  if  the temperatures  falls below 43°F.   Conversely,
at   a  temperature   of  43°F,   mixtures   of  hexane   with
concentrations  greater than  600 ppm  will  condense  to  some
extent.   The  cylinder pressure  is  also a   factor  in  this
relationship.   If  the  cylinder pressure  is  less  than  2000
psi,   as   assumed   to   develop  Table   1,   the   dew   point
temperatures  would   be  lower  for   the  hexane  concentrations
listed in Table  1, and  the  concentrations would  be  higher for
the temperatures listed.

For  instance, a  mixture of  1000 ppm hexane at 1000 psi would
have  a  theoretical  dew point  of  about  34°F.   A  mixture  of
1600  ppm  hexane  at  500 psi would  have  theoretical dew point
of about  28°F.   Thus,  by limiting cylinder  pressure  to these
values  and   maintaining   constant  temperatures   above the
freezing  point  of  water, gas  manufacturers  can blend  stable
mixtures  of  hexane  at  these  higher   concentrations.  The
trade-off, however,  is  a reduced amount of calibration  gas  in
each  cylinder  purchased,   since  the  volume   of  gas  in   a
cylinder  is  directly proportional  to  the cylinder  pressure.
At 500 psi, for  example, only  one-quarter as much  calibration
gas  can  be stored in  a cylinder as  in  the  same cylinder  at
2000 psi.

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                             -8-

The condensation effects of hexane are not as  troublesome  for
the  smaller,  disposable  cylinders,   which   have  a   maximum
cylinder pressure  of  300 psi  or less.   At  this pressure,  a
mixture  of  1600 ppm  hexane has  a theoretical  dew point  of
about 10°F,  and  lower  concentration mixtures would have  even
lower dew points.   Of  course,  the cost  per  volume  of gas  is
higher for these smaller cylinders.

If hexane calibration gases are used,  it  is  necessary  to  take
adequate precautions during gas shipments, storage  and use  to
make   sure   that   the  cylinders   are  never   exposed   to
temperatures  below  their  dew  point   level.    If a   lower
temperature  limit   of  43°F  were  set,  the   working range  of
hexane calibration  gases  in  the field would  be about  200  ppm
to 500  ppm  hexane  (in  1-A  cylinders) .   However,  many  areas
around  the  country  typically  have  temperatures below  43°F.
For such areas  the lower temperature  limit  would need to  be
less than 43°F,  thus  restricting  the working  range of hexane
concentration  even  more.   The  exact  hexane  value  for   a
particular  State  would depend  on  the State's climate during
the season  of  interest.   In general,  very few problems  would
be encountered  during  the summer months  in  any  place in  the
country.  However,  during  winter  months, the use  of hexane
calibration gases in many States may be very  risky.

The  second  constraint  regarding  the  use of hexane is  that,
unlike  propane,  there  are  no  NBS  gas  standards for  hexane.
Consequently, hexane traceability  must  be established  through
the  use  of  weight   standards   (sometimes   referred  to  as
gravimetrics)  and  the  manufacturer's  in-house hexane  gas
standards  which  are  developed from  the  weight  standards.
Traceability to NBS can be  established  in this manner  through
careful analysis.   (At  least one gas  manufacturer has  already
developed in-house  gas standards for hexane,  but others  have
not.)    Because   of   this   more  complex   analysis,  hexane
calibration gases may  be  slightly  more  expensive  in the  short
run  (for those manufacturers which  not  yet developed  in-house
hexane  gas   standards) .   However,  over  the  long  run,   cost
differences should  disappear as  the gas manufacturers  perfect
and streamline the hexane analysis process.

2.1.2 Diluents  (Balance Gases)

The  diluent  is  by  far  the  largest  component  of  the  gas
mixture.  It is  the carrier  or  balance  gas in  which the  gases
of interest are mixed  to  get the  desired concentrations.   The
diluent must be'  chosen with care to  avoid chemical reactions
with  the  other  gas  components  and  contamination   due  to
impurities which may confound gas analysis.

Nitrogen  is the  easiest gas  to  use as  a   diluent  for  I/M
calibration gases  since  it  is  readily available  in very  pure

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                             — 9 —

forms.   Nitrogen  is  also  the  best diluent  to use  for  two
reasons.   First,  nitrogen  does not  react  with HC,  CO,  or
CC>2.   Second,   it  creates  no  interference  problems  in  the
gas  analysis   (naming)   process.    Purified   air,   the  other
possible diluent, on  the other  hand,  is not recommended  as  a
diluent  for  CO because  the  oxygen  in air  causes  biases  in
naming the HC component with  a  process  type  total  hydrocarbon
analyzer.   This type  of  analyzer  is  commonly used  by  gas
manufacturer  to name  HC  gases.    Because  of  this  problem,
purified  air   is  not  recommended  as  a  diluent   for   I/M
calibration gases.

The I/M  gas  user  needs to be aware of the problems  with air
as a diluent for one  other reason.  NBS has  available propane
gas  standards  in  either  nitrogen or purified  air  as  the
diluent.  In ordering calibration gases, I/M users need  to be
careful  to  stipulate  that  NBS  propane  gas  standards  in
nitrogen are  to be  used in  the analysis  of  the HC  component
of  the  I/M  calibration gas  in order  to prevent  errors  in
analysis.

2.2 Concentrations of I/M Calibration  Gases

2.2.1 Emission  Performance Warranty Requirements

In  addition  to  the  accuracy  requirement  for  gases used  .to
check  emission  analyzers  (i.e.,  +2%   to  NBS  standards),  the
Warranty regulations  also  require  the  calibration  gas to be
within  certain  concentration ranges.   Section  85.2217  states
that "span gases shall have concentrations either:

    (i)  Between the  standards  specified  in this subpart and
         the  jurisdiction's  inspection  standards  for  1981
         model  year light duty vehicles, or

    (ii) Be  within  -50% to   +100%  of  the  standards in  this
         subpart."

The standards  specified  in the Warranty regulations  are  1.0%
CO and  200 ppm  HC  (measured  as  hexane)  for  the two-speed  idle
test  and 1.2%  CO and 220 ppm  HC  for  the  idle  test or the
two-mode loaded test.  Some  States  are  using  these  cutpoints,
although  many  States are  choosing  standards  for  1981  and
later  vehicles  which are  less  stringent.   At  this  time, the
most lenient standards likely to be chosen for 1981+ vehicles
are  4.0% for  CO  and  400  ppm  for  HC  (measured as  hexane).
Table  2  indicates the  required  calibration  gas concentrations
for each of these cases.

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                            -10-

                           Table 2

                  Required Calibration Gas
          Concentrations for  Selected I/M Cutpoints
        Outpoints
        (CO/HC*)
      1.0%/200 ppm


      1.2%/220 ppm


      4%/400 ppm
      Cal.  Gas Concentration
 CO (%)
0.5-2.0
0.6-2.4
                            0.5-4.0
      HC (ppm)
100-400 (if hexane)
200-800 (if propane)

110-440 (if hexane)
220-880 (if propane)

100-400 (if hexane)
200-800 (if propane)
*HC outpoints are  always expressed as hexane,  and  vehicular
HC emissions are always measured as hexane in I/M programs.
Based on  the  information in Table  2,  it is clear  that  users
can  meet  the gas  concentration  requirement  in the  Warranty
regulations by limiting  their gas orders  to concentrations in
the ranges of 1.0-2.0% CO and 200-800  ppm propane  (or 100-400
ppm hexane).

2.2.2 State Requirements - CO?  Concentration

In those  cases  where a  CC>2  calibration  gas is  required,  the
C02  concentration  of the calibration  gas  should  approximate
the C02 cutpoint  used in the I/M program.   Unlike HC and CO
where cutpoints generally vary  by model year,  there  is  often
only  one  C02   cutpoint  applied   to   all   model   years.
(Sometimes  a  State  may choose  different  C02  cutpoints  for
vehicles   with   and  without   air   pumps.)    Typical   State
cutpoints for C02 are from 4 to 6%.

2.2.3 State Requirements - CO/Propane Interference

In addition  to  meeting  the  Warranty requirements for HC  and
CO calibration  gas  concentrations,  some States  may wish to
use  other   concentrations   of   HC  and  CO   (and   C02)   in
performing multipoint  calibrations  on analyzers  used in  the
I/M programs.   In  these cases,  the State would need several
cylinders of calibration gases  at varying concentrations,  all
with accuracies  of  +2%  to  NBS  standards  for  best  results.
However,  States  should  be  aware  of   certain   aspects   of
ordering  high  concentration  (i.e.,  propane greater  than  500
ppm and  CO greater  than 4.0%)   blends  of  calibration  gases.
There is  a small interference  effect  between CO  and propane
at high concentration  levels on certain  instruments  that  are

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                            -11-

used to  name these components.   This  interference effect  is
described   in   detail   in   Appendix   2.    To   avoid   this
interference, when  high concentration  calibration gases  are
being blended, gas chromatographic analysis of  the components
should be used by the gas manufacturer  to  label  the gas  after
mixing.   This  is  required  by  the  Recommended  Practice  for
cylinders containing greater than 500 ppm  propane  (or  250  ppm
hexane) and  4.0%  CO.   Failure of  the  gas  manufacturer  to  do
this could result in gases not meeting  the accuracy limits  of
+2%  traceable to  NBS.   Although there have  been no  known
studies of  the degree  of interference between CO  and  hexane,
it would be  advisable to require  gas chromatographic  analysis
of   hexane/CO   mixtures  of   similar   concentrations   as   a
precaution.  Of  course,  such mixtures  will  often  not  exceed
500 ppm hexane because of the  condensation problems discussed
earlier.

2.3 Cylinders and Hardware

Gas manufacturers have many different  sizes of  cylinders they
can  use  for I/M calibration  gas  mixtures, ranging from very
large  size  9 1/4"  by  60"  high  pressure  cylinders*  to  the
low-pressure  disposable  cylinders.    The   major  cost  of  a
mixture  of  calibration  gas  is not for  the raw  gases  that  go
into making  it, but for  the analyses required  to make  sure it
is  labeled  correctly.   Consequently, the  large  cylinders  are
much  more   economical  per  cubic  foot  of  calibration  gas
mixture  than the small disposables,  although  the disposables
have a lower cost per cylinder.

The  Recommended  Practice requires  that the  large 9  1/4"  by
60"  size  cylinders  be  equipped with CGA-350 valves,  and that
the   disposable   cylinders   be   equipped   with   1/4-inch
flare-fitting  valves.   The  Recommended  Practice  does  not
specify  valves for  other size cylinders because  there  are so
many different sizes.  Furthermore, the 9  1/4" by 60"  and the
disposables   will   probably   be  most  commonly  used.    The
Compressed  Gas  Association   (CGA) makes   recommendations  for
valves for  other  cylinders, consequently,  there  is uniformity
between manufacturers on valve usage in other size cylinders.

Users  of  the I/M mixtures  will need regulators  to adjust the
delivery  pressure  of the gas mixture  to  the analyzer.   The
uniform  specifications  for  valve  sizes  for  the large  and
disposable   cylinders   will   allow   users   to   change  gas
manufacturer   suppliers   without  having   to   purchase  new
 *  The Department  of  Transportation  (DOT)  has  specifications
 for  all  cylinders  used  to hold  pressurized  gases.   The  DOT
 designation  for  this  cylinder  is 3AA2400.  Some manufacturers
 call  this a  "K"  cylinder; others call it a  "1-A" cylinder.

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                             -12-

regulators, as long as the same size cylinder  is  ordered  from
the   new   supplier.    Regulators   may   or   may   not    be
interchangeable among different size cylinders.

EPA highly  recommends  the use  of  dual-stage  regulators  with
all calibration gas  mixtures and cylinders  instead  of  single
stage regulators.  The dual  stage  regulators allow gas to  be
delivered to the analyzer at a  constant pressure,  even  though
the pressure  in the  gas cylinder  declines as  gas  is used.
The single  stage  regulators do  not have  this  feature.   This
feature  is  important  because  it  helps   ensure  that   the
instrument  is  neither   starved   nor   over-pressurized   with
calibration gas, when gas is introduced through the probe.

Users may  also need  additional hardware  to connect the  gas
cylinder  to  the   instrument   through  the  sample  cell  port
and/or probe.   However, different  analyzer  manufacturers  have
different  ways  of  handling  this.   Users  should  discuss  with
their analyzer  suppliers what  additional  hardware  is  needed
to perform these hook-ups.

To conform to the Recommended  Practice,  the  inside  surfaces
of  all  cylinders  must  conform   to   the   NBS  CRM  or   SRM
requirements  for  preparation,  cleanliness,  trace  materials,
composition,  coatings,  etc.  for  the  gas  composition   and
concentrations  used.   Also, cylinder  valves must  conform  to
the  NBS  CRM or  SRM  requirements  for  preparation,  packing
materials,   cleanliness,   composition,  etc.   for   the   gas
composition and concentrations used.

2.4 Cylinder Labels and State Audits

The Recommended  Practice  requires gas manufacturers  to  label
gases with the following information:

   (i)    Cylinder  number  (except  in  the  use  of  disposables,
         where the batch number is required)

   (ii)   Concentration of  propane  or hexane  (in  ppm),  CO  (in
         mol%) ,    and    C02     (in    mol%)     and    accuracy
         specification (i.e., +2%, +1.0%,  etc.)

   (iii)  Balance gas

   (iv)   Analysis date

   (v)    Cylinder  numbers   of   NBS  standards  (and  primary
         standards if  hexane is present)  used in determining
         instrument calibration curves

   (vi)   Vendor name

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                             -13-

  (vii)   The  statement  that  "This  gas  has  been  named  in
         accordance  with  the  EPA  Recommended  Practice  of
         September 1983 for Naming I/M Calibration Gas".

In  most  decentralized  programs,  State  auditors   will  be
visiting all inspection facilities once per month  in  order  to
check the facility's inspection analyzer, calibration gas and
records.   The  check  of  the  accuracy  of   the  facility's
calibration gas  will probably be  conducted  as follows.  The
auditor will check the facility's  analyzer with the  auditor's
calibration gas.   If the analyzer  cannot  read the  auditor's
calibration   gas   within   about    +5%   of    its    labeled
concentration, the  auditor  will check  the  analyzer  with the
facility's calibration gas.   If the  analyzer  reads  that gas
within  about  +3%,  it  may  be  concluded   that  either the
facility's  gas  or  the  auditor's  gas  has  been  improperly
labeled.  If the  former, then  the  information  present on each
cylinder  of  gas  named according  to the Recommended  Practice
will  allow  auditors  to  trace  that  cylinder  back  to its
manufacturer.  Gas  manufacturers  are  required  to   keep the
records  of  the  naming  process for  each batch of gas  named
according  to  the  Recommended  Practice  for  at  least two
years.   Through   this  process,  it   is  possible  that  other
cylinders   that   had   been    improperly   labeled  could  be
identified and recalled.

2.5 EPA Audits

EPA  does not  think  it  is  necessary  to check  samples   of  a
batch of  calibration gas named according  to  the Recommended
Practice  prior to the  sale  and delivery of cylinders of the
batch.  However,   EPA may from  time-to-time order  gas mixtures
named    according   to   the   Recommended    Practice   from
manufacturers  through  a  third party  for audit purposes.  The
results of  such  audits are  likely to be published for public
inspection.

3.0 SUMMARY

EPA  recommends that States  should  require  .all  gases  to  be
named with  the  EPA  Recommended Practice in  order  to ensure
consistent,    traceable    calibration   gases    among   gas
manufacturers  and inspection  stations.  This  should  be  done
by  specifying   the  EPA  Recommended   Practice  by   name  in
licensing  regulations,  contract  provisions,   and/or  purchase
orders.

As pointed  out in previous  sections  of this  report,  EPA has
the  following' additional  recommendations  on  I/M calibration
gases:

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                            -14-

1.   Gas   components   should   include   CO   and   HC.    CC>2
    calibration gas,  where  needed,  should  be  purchased  in
    separate cylinders unless the  related  traceability  issues
    are adequately  addressed,  in  which  case the  C02  can  be
    obtained in the same cylinder as  the  CO and  HC.

2.   The HC  component  of  the gas  should  be propane,   unless
    adequate precautions are identified and  taken  to overcome
    the climatological factors related to  hexane condensation
    and the  traceability issues  related  to  the  lack  of NBS
    gas standards for hexane.

3.   The   diluent   for   I/M  calibration  gases  should   be
    nitrogen.  The diluent  for  the NBS gas  standards used  in
    analysis should also be specified as  nitrogen.

4.   Gas concentrations should be as follows:

    a.   CO:  1.0-2.0%.

    b.   HC:  200-800 ppm propane or 100-400  ppm hexane.

    c.   C02:  about the same as C02 cutpoint.

5.   For calibration  gases  with  gas concentrations  of  greater
    than 500 ppm propane  (or 250 ppm hexane) and 4.0% CO, gas
    chromatographic  analysis  should  be   used   in  the  naming
    process to avoid interference problems.

6.   Users  may purchase  I/M  calibration  gases in  any  size
    container they  choose.  However, corresponding  gauges and
    other    hardware    should    be    selected    accordingly.
    Dual-stage   regulators   are   recommended.    All   inside
    cylinder surfaces  and valves  must  conform to  the NBS CRM
    or   SRM   requirements   for   preparation,    cleanliness,
    composition,     etc.   for    the    gas    composition  and
    concentrations used.

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Appendices

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                        Appendix  1
EXCERPT  FROM:     45  FR  34808,  MAY  22,  1980,

 EMISSION PERFORMANCE  WARRANTY REGULATIONS
            . § B5-2217  Calibrations, adjustments.
               (a) Equipment shall be calibrated in
             accordance with the manufacturers'
           .  instructions...-    -
               (b) Within one hour prior to a test, the
             analyzers shall be zeroed and spanned.
           :  Ambient  air is acceptable as a zero gas; .
            • an electrical span  check is acceptable.  .
             Zero and span checks shall be made on
             the lowest range capable of reading the.
           -. short test standard.
               (c) Within eight  hours prior to a •    -..••
             loaded test the dynamometer shall be -'
             checked for proper power absorber
           . settings.            •
               (d)(l) The analyzers shall have been "'•
           •  spanned  and adjusted, if necessary.-  V'
             using gas traceable to NBS standards ±
             2% within one week of the test These
             span gases shall have concentrations- .:'"'"-;
            . either.   .    -  .: ••'•.* .          •  : -
               (i) Between the  standards specified tn~ '
             this subpart and the jurisdictions
             inspection standards for 1981 model
            • year light duty vehicles, or
            •  • (ii) Be within -50% to +100% of the '
             standards in this subpart
               (2) For analyzers with a separate
             calibration or span port CO readings
              using calibration gas through the probe
              and through the calibration port shall be
              made: discrepancies of over 3% shall
              require repair of leaks. No analyzer
              adjustments shall be permitted during
              this check.

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                         Appendix  2

                CO-HC Interference Discussion

The EPA and the National Bureau  of Standards  (NBS)  have found
that a  small amount  of  interference  exists  in infrared  and
total hydrocarbon  analyzers between  CO and  propane at  high
concentration levels.*  NBS conducted  a  test  program in which
two tri-blend calibration  gases, one at a  high concentration
and  one   at   a   lower   concentration,   were  checked   for
interference.   The   concentrations   ordered   for   the  high
concentration  cylinder  were  8.0%  CO,  2500  ppm  propane  in
nitrogen.     The   concentrations   ordered   in   the   lower
concentration cylinder were 2.0% CO,  500 ppm propane.

NBS used a  gas  chromatograph  (GC) to  check  the concentration
of.  each   component  in   both   cylinders.    Then   a   total
hydrocarbon  (THC)  analyzer  was  used  to   check  the  propane
values,  and a  non-dispersive . infrared  analyzer  was used  to
determine  the  CO  values.   The  assumption  in  this  technique
was  that   the  GC  values   were  closest  to  the true  values.
Interference between  CO and propane  would  be  seen  on the THC
and  NDIR  analyzers,   if  the values  they gave  were  different
from the GC values.

The  results  of the  study are  presented   in the  following
table,  which   shows   the  differences  between   methods  of
analyses.
*  "A  Study of  Interference  in Trinary  Span  Gases Calibrated
With  Binary  SRM's",  available   by  writing  the  Technical
Support  Staff,   U.S.   EPA,   2565   Plymouth  Road,  Ann  Arbor,
Michigan, 48105.

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                   Levels of  Interference
                   Between CO and Propane

                  Hydrocarbon Concentration
                      As Determined By

         Sample        G.C.              THA         % Diff

        XA4450      496  +lppm       501 +lppm        1%
        A-013329    2474 +lppm       2541 +lppm      2.6%
                Carbon Monoxide Concentration
                      As Determined By

      Sample          G.C.             NDIR        % Diff

     XA4450       1.997 +.004%    2.002 +.004%       .25%
     A-013329     7.91 +.01%      8.04 +.02%        1.6%
G.C. = Gas Chromatograph
NDIR = Non-Dispersive Infrared Analyzer
THA = Total Hydrocarbon Analyzer


The  data  in  the  table  indicate  that,  for  the HC  readings,
there  is  a  substantial  amount  of interference  (2.6%)  caused
by the high concentration  (8.0%)  of CO.  For  the  CO readings
the  degree  of interference caused  by the high  concentration
(2500 ppm) of propane is less (1.6%)  but still significant.

The  Recommended  Practice   assumes   that  there  is   a   +1%
interference  level  between  propane and  CO for  gases intended
to  be  traceable  to NBS +2%,  and controls  other  sources  of
errors so that overall accuracy remains  within  +2%.   From the
information  in the table,  it  appears  that  this  level  of
interference  can  only  be assumed  at propane levels  equal to
500  ppm  or less,  and CO  levels  equal  to about  4.0% CO  or
less.  If States order higher concentration  calibration gases
with intended  accuracies of +2%  NBS, gas manufacturers  must
use  gas chromatographs  to  overcome  interference in  their gas
analysis  in   order  to  be   in   accordance  with   the   EPA
Recommended Practice.

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