Greenhouse Gas (GHG)
Verification Guideline
Series
Parametric Emissions Monitoring
System (PEMS)
Version 1.1
  Greenhouse Gas Technology Center
     Southern Research Institute
        September 2001

   Under a Cooperative Agreement With
U.S. Environmental Protection Agency

-------
                                          EPA REVIEW NOTICE

This report has been peer and administratively reviewed by the U.S. Environmental Protection Agency, and approved for
publication. Mention of trade names or commercial products does not constitute endorsement or recommendation for use.

-------
 Greenhouse  Gas Technology Center
A U.S. EPA Sponsored Environmental Technology Verification ( ^I'l/ ) Organization
        Greenhouse Gas Verification Guideline Series

          Parametric Emissions Monitoring System
                             (PEMS)
                            Prepared by:
                    Greenhouse Gas Technology Center
                       Southern Research Institute
                            PO Box 13825
                  Research Triangle Park, NC 27709  USA
                        Telephone: 919/806-3456
            Under EPA Cooperative Agreement  CR 826311-01-0
                  U.S. Environmental Protection Agency
                   Office of Research and Development
              National Risk Management Research Laboratory
               Air Pollution Prevention and Control Division
                Research Triangle Park, NC 27711  USA

                EPA Project Officer: David A. Kirchgessner
                           September 2001
                             Version 1.1

-------
                                              FOREWARD

The  U.S.  Environmental Protection Agency  (EPA) has created the Environmental Technology Verification
(ETV) program to facilitate the deployment of promising environmental technologies.  Under  this  program,
third-party performance  testing  of environmental technology is conducted  by  independent verification
organizations under strict EPA quality  assurance guidelines.  Southern Research Institute (SRI) is one of six
independent verification organizations operating under the ETV program, and SRI operates the Greenhouse Gas
Technology Center (GHG Center).  With full participation from technology providers, purchasers, and other
stakeholders, the GHG Center develops testing protocols and conducts technology performance evaluation in
field and laboratory settings.  The testing protocols are developed and peer-reviewed with input from a broad
group of industry, research, government, and other stakeholders.   After their development, the protocols are
field-tested, often improved, and then made available to interested users via guideline series reports such as this
one.   Typically, verifications  conducted by the center  involve substantial  measurements, so an effort is made
here  to recommend only the most important measurements for the guideline.

Guidelines for verifying an alternative method of monitoring exhaust  emissions in gas-fired 1C engines are
presented here.  This guideline was based upon a verification test conducted by the GHG Center on a parametric
emissions  monitoring system (PEMS) developed by ANR Pipeline Company (ANR) of Detroit, Michigan.  The
ANR PEMS approach to monitoring exhaust emissions is based on relationships  established between engine
operating parameters,  as reported by existing  engine sensors, and exhaust emissions.  The PEMS approach to
monitoring can be applied to other source categories and industry sectors, but the guidelines presented here were
developed specifically for PEMS installations on gas-fired 1C engines.

In the natural gas industry, interstate gas  pipeline  operators use gas-fired engines to provide the mechanical
energy needed  to drive pipeline gas compressors. The patented  PEMS  approach to emissions  monitoring
provides an alternative to  instrumental continuous  emissions  monitoring  systems  (CEMS),  and is potentially
more cost effective.  1C engine PEMS  can be designed to predict emissions of carbon dioxide (CO2), carbon
monoxide (CO), total hydrocarbons (THCs), oxygen (O2), and nitrogen oxides (NOX).  The parametric approach
to determining air emissions is provided for in 40 CFR Part 64.

The  purpose of this guideline is to describe specific procedures for evaluation  and verification of 1C engine
PEMS.  It is not the intention of the  GHG  Center that these guidelines become accepted as  a national  or
international  standard. Rather, a significant  effort has  been devoted to  their  development,  field trial, and
improvement; and this experience  and data are recognized as potentially valuable  to others.  Instrument
descriptions and recommendations presented in this document do not constitute an endorsement by the GHG
Center or the EPA.  Readers should be aware that use of this guideline is voluntary, and that the GHG Center is
not responsible for liabilities that result from its use.

Finally, the GHG Center continues to conduct verifications, and will update this guideline with new findings as
warranted.  Updates can be obtained on-line at the GHG Center's Web site (www.sri-rtp.com) or at the  EPA
ETV Web site (www. epa. gov/etv).

-------
                                     ACKNOWLEDGEMENTS
The Greenhouse Gas Technology Center wishes to thank all participants in the field verifications used to prepare
this guideline.  The GHG Center wishes to thank the staff and employees of Coastal Corporation and its member
company, ANR Pipeline Company, for their invaluable  service in hosting the test used in the development of
this guideline.  They provided the compressor station to  test this technology, and gave technical support during
the setup and  field testing of the PEMS technology.   Key ANR personnel who should be recognized for
contributing to the success of the testing include Curtis Pedersen, Joseph  Weisbrod, Michael Scudder, Ron
Bickel, Mike Haller, Jeff Beach, and George Jirkos.

-------
                                  TABLE OF CONTENTS
FORWARD	ii
ACKNOWLEDGMENTS	iii
ACRONYMS/ABBREVIATIONS	v
FOREWARD
1.0   BACKGROUND AND INTRODUCTION [[[ 1-1
     1.1.  ETV PROGRAM DESCRIPTION [[[ 1-1
     1.2.  VERIFICATION SCOPE [[[ 1-2

2.0   PEMS TECHNOLOGY DESCRIPTION [[[ 2-1
     2.1.  PRINCIPLES OF PEMS TECHNOLOGY [[[ 2-1
     2.2.  PEMS DESCRIPTION [[[ 2-1

3.0   VERIFICATION GUIDELINE [[[ 3-1
     3.1.  INTRODUCTION [[[ 3-1
     3.2.  RELATIVE ACCURACY DETERMINATIONS [[[ 3-1
     3.3.  OPERATIONAL PERFORMANCE EVALUATIONS [[[ 3-5
          3.3.1.  PEMS Prediction Capabilities During Abnormal Engine Operation ............................ 3-5
          3.3.2.  PEMS Response to Sensor Failure [[[ 3-8

4.0   FIELD TESTING AND CALCULATION PROCEDURES [[[ 4-1
     4.1.  OVERVIEW [[[ 4-1
          4.1.1.  Determination of Relative Accuracy [[[ 4-1
     4.2.  SAMPLE HANDLING AND TESTING METHODS [[[ 4-3
          4.2.1.  Sample Conditioning and Handling [[[ 4-3
          4.2.2.  Calibrations [[[ 4-5
          4.2.3.  Reference Method 3 A - Determination of Oxygen & Carbon Dioxide

-------
                                 ACRONYMS/ABBREVIATIONS
ANR
ATDC
BHp
BTDC
CEMS
cfh
CFR
CH4
CO
CO2
DQO
DP
EPA
ETV
ft3
Ft-lbs
g
GHG Center
H2O
Hp
hr
inches Hg
KV
Lb
MMBtu
Msec
NOX
02
PEMS
ppm
ppmvd
PSIG
QA
RA
RATA
RPM
SCF
SRI
THCs
WC
°F
ANR Pipeline Company
after top dead center
brake horsepower
before top dead center
continuous emissions monitoring system
cubic feet per hour
Code of Federal Regulations
methane
carbon monoxide
carbon dioxide
data quality objective
differential pressure
United States Environmental Protection Agency
Environmental Technology Verification
cubic feet
foot-pounds
gram
Greenhouse Gas Technology Center
water
horsepower
hour
inches mercury
kilovolt
pounds
million British thermal units
milli second
nitrogen oxides
oxygen
parametric (also Predictive)  emissions monitoring system
parts per million
parts per million volume dry
pounds per square inch gauge
quality assurance
relative accuracy
relative accuracy test audit
revolutions per minute
standard cubic feet
Southern Research Institute
total hydrocarbons
water column
degrees Fahrenheit

-------

-------
                            1.0      BACKGROUND AND INTRODUCTION
1.1.   ETV PROGRAM DESCRIPTION

The U.S.  Environmental Protection Agency's  Office of Research and Development (EPA-ORD) operates a
program to facilitate  the  deployment  of innovative technologies  through  performance verification  and
information dissemination. The goal of the Environmental Technology Verification (ETV) program is to further
environmental protection by  substantially accelerating the  acceptance  and use of improved  and innovative
environmental technologies.  ETV is funded by Congress in response to the belief that there are many viable
environmental technologies that are not being used for the lack of credible third-party performance data.  With
performance data developed under ETV, technology buyers,  financiers, and permitters in the United States and
abroad will be better equipped to make  informed decisions  regarding environmental technology purchase and
use.

The Greenhouse Gas Technology Center (GHG Center) is one of six verification organizations operating under
ETV. The GHG Center is managed by the EPA's partner verification organization, Southern Research Institute
(SRI), which conducts verification testing of promising GHG mitigation and monitoring technologies.   The
GHG Center's  verification  process consists  of developing verification  protocols, conducting field  tests,
collecting and interpreting field and other test data,  obtaining independent peer review input, and reporting
findings. Performance evaluations are conducted  according to externally reviewed verification Test and Quality
Assurance Plans and established protocols for quality assurance.

The GHG Center is guided by volunteer groups  of stakeholders. These stakeholders offer advice on  specific
technologies most appropriate for  testing, help  disseminate results,  and review Test Plans and verification
reports.   The GHG Center's  stakeholder groups  consist of national and international experts  in the areas of
climate  science  and  environmental  policy,  technology,  and regulation.  Members include  industry  trade
organizations,  technology purchasers, environmental technology finance groups, governmental organizations,
and other interested groups.  In certain cases, industry specific stakeholder  groups and technical panels are
assembled for technology areas where specific expertise is needed.  The GHG Center's Oil  and Gas Industry
Stakeholder Group offers advice on technologies  that have the potential to improve operation and efficiency of
natural gas transmission activities.   They also  assist in selecting verification factors and provide guidance to
ensure that the performance evaluation is based on recognized and reliable field measurement and data analysis
procedures.

In a June 1998 meeting in Houston, Texas, the Oil and  Gas  Industry Stakeholder Group voiced support for the
GHG Center's  mission,  identified  a  need  for independent  third-party  verification,  prioritized  specific
technologies for testing,  and identified  verification test parameters that are  of most interest to technology
purchasers. At this meeting, ANR Pipeline Company, of Detroit, Michigan, requested the GHG Center conduct
a verification test on a parametric (or sometimes referred to as predictive) emissions monitoring system (PEMS)
they had developed. Verification of the PEMS was conducted in August 1999.  Details on the verification test
design,  measurement  test procedures, and Quality Assurance/Quality  Control  (QA/QC) procedures  for the
PEMS verification can be found in the test plan titled Testing and Quality Assurance Plan for the ANR Pipeline
Company Parametric Emissions Monitoring System (PEMS) (SRI 1999).  It can be downloaded from the GHG
Center's Web site (www.sri-rtp.com) or the EPA's ETV  Web site (www.epa.gov/etv).   Results of the ANR
verification can be found in the test report titled  Environmental Technology  Verification Report for the ANR
Pipeline Company Parametric Emissions Monitoring System (PEMS) (SRI 2000) which is  available at the same
Web sites.   The  verification guidelines  presented  in this document  were developed  in support  of that
performance verification test.
      1-1

-------
The  purpose of this  guideline is to describe specific procedures for evaluation and verification of 1C engine
PEMS.   It is not the intention of the GHG Center that these guidelines become accepted as a national  or
international  standard. Although the guidance  has  been field tested, it may not be applicable  to all gas-fired
internal combustion engines and installations.  This guideline should also be considered dynamic, because the
GHG Center continues  to conduct  technology verifications, and this document may be updated  regularly  to
include new  findings and procedures as warranted. Updates of this document can be obtained on-line at the
GHG Center's Web site or EPA's ETV Web site as referenced above

Following the planning, execution,  and post-test analysis phases of each field verification, the GHG Center
identifies field or other procedures  that  performed poorly or were marginally necessary, and then revises the
protocol. All procedural changes instituted from this effort are included here.

1.2.   VERIFICATION SCOPE

Natural gas transmission companies  often use large gas-fired 1C engines to drive gas compressors that transport
gas through the transmission network in the United States.  There are several approaches to  monitoring the
exhaust emissions from these gas-fired engines, one of which is the PEMS. The PEMS approach to monitoring
exhaust emissions is  based upon establishing relationships between engine operating parameters, as determined
by commonly used sensors, and exhaust emissions.

PEMS provides a potentially more  cost-effective alternative to instrumental continuous emissions monitoring
systems (CEMS).  1C engine PEMS can be designed to predict emissions of nitrogen oxides (NOX), carbon
monoxide (CO), total hydrocarbons (THCs), oxygen (O2), and carbon dioxide (CO2).  The parametric approach
to determining air emissions is provided for in 40CFR64.

This guide recommends an approach to evaluate the functionality and accuracy of a PEMS on a gas-fired 1C
engine.  Basically, the PEMS is evaluated by  comparing its emission predictions to emissions data collected
simultaneously using instrumental procedures.  There are two classes of verification parameters recommended:
(1)  emission  monitoring   relative accuracy  determinations,  and  (2)  PEMS  operational  performance
determinations. The relative accuracy determinations provide a statistical  comparison between PEMS emission
prediction values and emissions measurements obtained using EPA Reference Methods  during normal engine
operations. PEMS operational performance evaluations include determination of the PEMS ability to respond to
adverse engine operating conditions and sensor drift or failure.  The following specific verification parameters
should be considered during the PEMS evaluation and are described individually in the following sections:

        •   PEMS relative accuracy for emissions of each pollutant predicted
        •   PEMS prediction capabilities during abnormal engine operation
        •   PEMS ability to respond to sensor failure

The  remainder of this guideline provides descriptions and  explanations  of PEMS functions and a proposed
verification methodology. The document is organized as follows:

        •   Section 2 provides an  overview of PEMS  principals  and describes a typical  1C  engine
           PEMS design, set-up, and operation;

        •   Section 3 discusses  verification parameters and approach;

        •   Section 4 describes  testing and analytical procedures to be used;

        •   Section 5 describes  data validation process and quality assurance goals;

-------
        •   Section  6,  the Bibliography, provides references relevant to this  Guideline,  including
            references to detailed, step-by-step procedures for the recommended Reference Methods.

Certain limitations of this guideline must be stated.  First, the verification test described in this guideline is not
intended to characterize PEMS  accuracy when the monitored engine  is operating abnormally.  Also, these
verification guidelines may not be applicable to  all types of engines operating under a wide range of conditions.
The verification that was used to develop these  guidelines was conducted on a 6,000 hp Ingersoll-Rand engine
fired with pipeline quality natural gas.
      1-1

-------

-------
                             2.0      PEMS TECHNOLOGY DESCRIPTION
2.1.   PRINCIPLES OF PEMS TECHNOLOGY

The PEMS approach to monitoring exhaust emissions is based upon establishing relationships between engine
operating parameters, as determined by commonly used engine sensors, and exhaust emissions. As such, PEMS
are fundamentally computerized algorithms that describe the relationships between operating parameters and
emission rates, and which estimate emissions  without the use  of continuous  emission monitoring systems.
Advantages that the PEMS approach to monitoring provides over CEMS applications include eliminating costs
associated with monitoring instrumentation and  the cost of maintaining the sampling and analysis systems, and
procurement of analyzer calibration gases. Some sensors may be needed for installation  of a PEMS, but many
engines are already equipped with the sensors needed.  Disadvantages associated with the PEMS are that they
are currently not widely  accepted  in many industries, and setup and engine mapping (i.e., determination  of
engine emissions using conventional methods over a wide range of engine operating regimes) costs may  be
high.

2.2.   PEMS DESCRIPTION

Each  engine produces unique  relationships between emissions and  engine operational functions, so initial
parameterization of a PEMS must be engine specific.  Engine and  emission relationships established for a site
can be a function  of engine speed and engine load (as torque), but other operational parameters that may be used
include: engine efficiency (calculated fuel consumption/actual fuel consumption), ignition timing, combustion
air manifold temperature,  and combustion air manifold pressure.  Relative humidity may not be applicable to
reciprocating engines, and therefore may be an operational parameter not considered in some PEMS.

Figure 2-1 illustrates several important PEMS prediction features for gas-fired 1C engines. The figure indicates
that engine speed and torque may  be primary determinants of emissions,  and that with values  for  speed and
torque, the baseline emissions for an engine can  be defined. Baseline emissions are representative of a normally
functioning and well-tuned engine, but as engine operational changes occur, indicators of engine efficiency,
ignition timing, air manifold temperature, and  air manifold pressure may be used to adjust emission values.
Within a given type of PEMS, monitored and estimated values for these five key parameters may be used to
increase or decrease predicted emission from the baseline level as shown  in Figure 2-1. Table 2-1 describes
typical engine sensors from which values for these operational parameters might be derived.

Figure 2-2 illustrates general PEMS operational steps and outputs.   The PEMS evaluated by the GHG Center
contained several  different functions including  the  prediction of continuous emissions,  the reporting of total
emissions and high emission alarms/alerts, the monitoring of engine sensor performance, and the reporting of
potential sensor malfunctions.  Other PEMS may offer different features.
      ?-/

-------
                 Figure 2-1.  PEMS Operations Features
Alarm Level
                       Alarm Level
                                                  Emissions Adjusted or
                                                  Biased Based on Key
                                               Engine Operational Parameters
                        Engine Speed and Torque
Table 2-1. Example Engine Parameters/Sensors Used by the PEMS
Verified by the GHG Center
Sensor
Ignition timing
feedback
Fuel DP (flow)
Fuel temperature
Air manifold
pressure
Air manifold
temperature
Model
Altronic
#DI-1401P
Rosemount #1151DP-4-S-12-
MI-B1 transducer
Rosemount
#444RL1U11A2NA RTD
Electronic Creations #EB-
010-50-1-0-40/N transducer
Rosemount 0068-F-11-C-30-
A-025-T34 RTD
Specified
Accuracy
+ 1 % of full
scale
+ 1 %
+ 0.25 %
+ 0.25 %
+ 0.25 %
Calibration
Check
Annual
Annual
Annual
Annual
Annual
Operating
Range
45° BTDC
to 45° ATDC
0-100" we
0-125 °F
0-25 PSIG
0-150°F

-------
                                  Figure 2-2. Example PEMS Diagram
                            Sensor Outputs
                            for all Monitored
                           Engine Parameters
                             No
Outputs from Redundant
Sensors for all Monitored
  Engine Parameters
                                    Is the Output for
                                     all Monitored
                                  Parameters Reliable?
                  PEMS Reports a
                  Potentially Faulty
                   Sensor Alarm
Engine Speed and
 Torque Settings
               PEMS Calculates
                 Values for all
              Monitored Parameters
                                                             Comparison of
                                                             Calculated and
                                                            Monitored Values
       PEMS Reporting:

      • Emissions Values
      • Emissions Alerts
      • Out of Limit Alarms
             PEMS Determines
                Baseline
                Emissions
                                     PEMS Adjusts
                                    Baseline  Emissions
A PEMS may also use redundant engine monitoring sensors.  Redundant sensors can be used for those engine
parameters that the PEMS vendor or engine operator expect to influence emissions the  most or are  expected to
fail  most frequently  (including fuel  flow,  combustion  air  temperature,  and  combustion  air pressure).
Incorporating  sensor redundancy on PEMS  applications  can facilitate assessments of sensor  drift and the
identification of failed or malfunctioning sensors.

Alarms and alerts may be set to give the engine operator knowledge when one or more key operating parameters
is out of specification.  These alarms/alerts are set by the PEMS vendor and station operator specific to  each
engine.  Key parameters that have alarm/alert functions might include efficiency (high and low), ignition timing
deviation from set point, air fuel  deviation from set point, and exhaust gas temperature absolute value (high and
low).  On the ANR PEMS  tested,  redundant sensors were  used on three key engine monitoring parameters
including air manifold temperature,  air manifold pressure, and fuel DP.

-------

-------
                                 3.0      VERIFICATION GUIDELINE
3.1.   INTRODUCTION

This section recommends an approach for evaluating the functionality of a PEMS and verifying the accuracy of
its  emissions  predictions.   Specific testing strategies and  matrices  are presented,  and  calculations  and
instrumental testing methods are identified.  Section 4 details the instrumental methods used to verify PEMS
predictions.

The PEMS should be tested over a full range of normal and off-normal engine operating conditions. There are
two classes  of verification parameters: emission  prediction  relative  accuracy, and  PEMS  operational
performance.  In the relative accuracy determinations, PEMS emission prediction values  are compared to
emissions measurements obtained using  EPA  Reference Methods for  emission rate determinations.   PEMS
operational performance evaluations  include determination of the PEMS  ability to respond to adverse engine
operating conditions and sensor drift  or failure.  PEMS  predictions during these activities are  also compared to
Reference Method  values.  The  following specific verification parameters  are  described individually in the
following sections and should be determined during the PEMS evaluation:

       •  PEMS relative accuracy for emissions of each pollutant predicted
       •  PEMS prediction capabilities during abnormal engine operation
       •  PEMS ability to respond to sensor failure

The parameters listed above should be assessed through observation, collection and analysis of emissions data
generated by the PEMS, comparative instrumental gas measurements collected on-site, use of engine data logs,
and evaluation of  data used  to characterize  engine  operations.  PEMS  emission prediction  performance
capabilities should be assessed  under normal engine operating conditions, and then challenged by simulating
episodes  of substandard engine performance and evaluating PEMS emission predictions during these episodes.

3.2.   RELATIVE ACCURACY DETERMINATIONS

Because  the PEMS approach to air emissions monitoring is  a new technology it is in limited use.  As such,
formalized performance demonstration procedures specific to PEMS have not yet been promulgated by  EPA
(although EPA has developed a draft performance  specification for PEMS, and  several  states  have specific
performance evaluation procedures in place for PEMS).  CEMS have been developed to the level that they  are a
primary means for monitoring gaseous emissions from industrial processes for regulatory compliance purposes.
This recognition has led to EPA's development of Performance Specification Test procedures to confirm the
precision and accuracy  of CEMS by conducting a relative accuracy test audit (RATA).  A RATA is a series of
tests during  which CEMS outputs are compared to data collected using an independent sampling system and
following EPA's Reference Methods for emission rate determinations.

The EPA Performance Specification Tests can  also be used to evaluate  PEMS performance.  Therefore, the
Performance Specification Tests are the primary  bases used in this PEMS verification guideline.  After a RATA
is  conducted, a statistical comparison is developed on  the PEMS emission  predictions and the corresponding
Reference Method data collected during the testing.  This statistical comparison is defined in Section 4.1.1 and
determines the relative accuracy (RA) of the PEMS for each pollutant.

The Performance Specifications generally require a relative  accuracy  of 20 percent  of  the mean reference
method value for a CEMS to be considered functional and able to report accurate emissions for compliance
purposes. A relative accuracy of 20 percent of the mean reference method value is also used to evaluate PEMS.
      1-1

-------
EPA's Performance Specification Tests require the use of EPA Reference Test Methods to collect measured
emissions data for comparison with PEMS  values.   The  list below identifies the individual Performance
Specification Tests to be used, and their accompanying Reference Test Method.

       •   Performance Specification Test 2  for NOX          Reference Method 7E
       •   Performance Specification Test 3  for CO2 & C>2      Reference Method 3A
       •   Performance Specification Test 4  for CO           Reference Method 10
       •   Performance Specification Test 8  for THCs         Reference Method 25A

Documentation of these  Reference Methods is  available in  the  Code of Federal Regulations,  (40CFR60,
Appendices  A and B).  In general  PEMS  emission predictions should be compared with the EPA Reference
Method values obtained by an independent gas sampling system.  The Reference Method values are obtained
using extractive sampling systems that analyze pollutant concentrations in the exhaust gas using instrumentation
housed in a mobile laboratory.  These comparisons should be made after the predicted PEMS and measured
Reference Method values are placed on a  common basis (e.g., common moisture and temperature), and after
each have been carefully time-matched.  To  facilitate time-matching,  synchronization of the PEMS and EPA
Reference Method data acquisition  clocks should  be done daily, and sampling system lags associated with the
Reference Method Sampling Train response  time should be measured and integrated into the time-matching.
The  Reference Method values are  also corrected for sampling system bias and instrument drift before being
compared to PEMS predictions.  More detail regarding the methods is provided in Section 4.

The first step in conducting a RATA is to determine the engine operating conditions  at which the testing should
occur.  Collection of the emissions and other data needed to perform  a RATA should occur while the engine
operates under normal speed and torque conditions, and when it is in a well-tuned state. Engine operators at the
site should determine when these conditions are met, and thus, when relative accuracy testing can begin.  For the
ANR PEMS verification, engine speed and torque were the primary  determinants  used by PEMS to predict
engine emissions, and therefore the RATA was conducted while  operating the  engine at a minimum of four
speed and torque regimes within the normal  operating  range of the engine.  For other PEMS or engine  types,
other engine parameters may be the primary factors for PEMS function.  The primary engine parameters for a
specific PEMS must be identified prior to designing a verification strategy and evaluating the system.

For example, the test engine used in the ANR PEMS  verification test normally operated at torque and speed
values that ranged between  75 to  100 percent of the maximum  values for each  parameter.  Although the
engine/compressor was capable of operating  with loads and speeds as low as 50 percent, operation at loads
and/or speeds of less  than 70 percent occurred only during start-up  or severe process interruption.  This engine
operated at loads/speeds of 85 to 100 percent approximately  90 percent of its  operating time. The  other  10
percent of the time it operated at 70  to 85 percent of rated maximum load and speed.

Using historical operational data for the engine to be tested,  a  series of normal operating conditions should be
specified for the RATA. The normal operating conditions established for the ANR verification test are shown in
the matrix presented  in Table 3-1.  The individual speed/load  values in  the matrix  were considered to be the
nominal values that should be attempted in the field. As a practical matter, varying demand on the engine under
test and other conditions can cause slight variations in these normal test conditions to  occur.

-------
Table 3-1. Example Relative Accuracy Test Matrix
Nominal Engine Speed (%)
50-75
75-90
90 - 100
Nominal Engine Load (%)
50-75
Not normal
Not normal
Not normal
75-90
Not normal
3 runs
3 runs
90 - 100
Not normal
3 runs
3 runs
Once the engine operating conditions at which the testing will be conducted are identified, the RATA can be
initiated. A minimum of 12 individual test runs  should be conducted to constitute a complete RATA.  In this
example, a series  of 3 runs  were  conducted  at each  of four operating  conditions.   The  Performance
Specifications for CEMS allow for 3 test results to be discarded, and relative accuracy to be determined on the
best 9 results obtained. This practice is not recommended for PEMS because the verification is not intended for
compliance or enforcement purposes.  More than 12 runs can be conducted and used to determine  relative
accuracy, but repetitions (single test runs) should be evenly distributed over the number of engine operating
conditions selected (e.g., if 5 operating regimes are tested, 3 replicates should be conducted at each for a total of
15 individual runs). Each run should be 21 to 30 minutes in duration after stable emissions readings have been
observed using the Reference Method monitors.  A more rigorous RATA can be conducted by conducting 12
individual test runs at each of the engine operating points.  The draft EPA performance specification requires
this level of testing for PEMS that will be used for compliance monitoring.

At the completion of the series of test runs, emission data from the Reference Methods and the PEMS should be
compiled for each  pollutant predicted by the PEMS.    Results  should be presented in  the reporting  units
predicted by the PEMS; typically on a concentration basis (ppm or percent), and on an emission factor  basis
(usually gram/brake horsepower-hour (g/Bhp-hr)).  This  should result  in two sets  of results with at least 12
replicates each.  The relative accuracy for each PEMS pollutant should be determined for each set of reporting
units. The procedures and instrumentation associated with the execution of specific Reference Methods,  other
sampling tasks, and relative accuracy calculations are described in Section 4.   Data should be summarized in
tabular form similar to the example provided in Table 3-2.
Table 3-2. Example Relative Accuracy Test Results

Parameter
NOX
CO2
CO
THCs
Emission Rates as g/BHp-hr
Mean Diff.
0.60
10.9
-0.07
-0.06
Std. Dev.
0.14
7.41
0.05
0.02
RA (%)
11.1
3.90
6.78
3.42
Concentrations as ppmvd (% for CO2)
Mean Diff.
71.4
-0.36
-12.9
-22.0
Std. Dev.
26.9
0.08
9.61
9.20
RA (%)
11.2
8.18
6.38
3.36
It can also be useful to summarize the RATA results graphically as in the example provided in Figures 3-la and
Figure 3-lb.   The figures present results  as a function of percent  difference between PEMS and Reference

-------
Method values, and as absolute values.  The figures also show the engine operating conditions during the runs as
percent speed and torque using the right vertical axes.

                 Figure 3-la.  Example RATA Results as Percent Difference (g/BHp-hr)
                                   RATA Results- NQx  (grams/BHp-hr)
40
30
9n


10
0
-10
-20
-30

-50
•




•










1








1 1 •








1








1





r~ii— ii~~ir~i


i i • i

—





i=
i

-—



| |

13 %Diff
Toque
RPM


•
-



•



90
80
70


60
50
40
30
20

0
                          19  20   21   22   23   24   25   26  27

                                              Run Number
                                                                    29   30
                  Figure 3-lb.  Example RATA Results as Absolute Values (g/BHp-hr)
                                   RATA Results- NQx   (grams/BHp-hr)
14

12

10
.n
Q_
m 8


6

4

2



— •— -•-•- —  _ ____ 	 ,_

~




-


-





























































"



,— -















— 1



—























-











-











—











	 .
















Tonque (%)
	 RPM (%)
' ' RM
1 ' PEMS






—







—







—







0

-


m

-

~



~
~


100
90

80
70


60
50


40
30
20

10
0
                           19   20   21   22   23   24   25   26  27

                                              Run Number
                                                               28  29   30

-------
Figure 3-2 presents an example graphic representation of each Reference Method and corresponding PEMS
prediction data point collected during the RATA conducted on the ANR PEMS. This plot allows a reader to
evaluate the PEMS ability to track large and small emission rate changes  and trends in the emissions over all of
the engine operating conditions tested.   The different engine speed settings observed during the tests are  also
plotted.
            Figure 3-2. Predicted and Measured NOX Concentrations During RATA Testing
iuuu •
1400 •
-i onn -
Q. -innn .
in
c
• onn
in ouu •
in
E
LJJ
finn .
0
/inn
onn .
n -


V^A.r/-








Reference Method
i Data 1
VnJ/^JL
/
PEMS Predictions

j"U/\ . A/
wW

fcw




	 PEM,
Ref f
^— Engir




-WJ/
v-r
3
Method
ie Speed
t»sv^fr\i*\ ..
N^PA^^,,


• ouu
• 340
. ^on
. ^nn

. ofin
o/in
. oon
. onn
                                                                                        Q.
                                                                                        V)
                                                                                        
-------
The first step needed to evaluate the effects of abnormal conditions is to select the engine parameters that are
most likely to have an effect on true emissions, and determine the methods for forcing these changes to occur.
Typically, engine operating features affecting emissions are pollutant specific.  From a general perspective, the
most significant parameters include (in approximate order):  (la) air manifold pressure, (Ib) exhaust manifold
pressure, (2) ignition  timing, (3)  engine  efficiency,  (4)  air manifold  temperature, (5) exhaust  manifold
temperature, and (6) relative humidity.  The operating parameters that should be used for perturbation include
those  parameters  that can be  physically  perturbed on the  engine.  This excludes ambient  humidity, where
perturbations can not be easily  simulated, and exhaust gas pressure and temperature, which generally can not be
altered in a predictable manner.  The parameters that were varied in ANR PEMS verification are summarized
below along with the physical methods used to vary them, and the measurements used for  each condition. Note
that other procedures may be better suited for the test conditions of a given PEMS verification.  Consultation
with the  operators  and vendors involved is recommended to determine the best way to perturb the engine in a
representative and safe manner.

       •  Combustion air manifold temperature  and pressure - Air manifold temperatures can be
           varied by manually changing the temperature setting,  causing the engine to increase or
           decrease  air flow through the heat exchanger.   Both high and low temperatures that are
           close to the upper and  lower air temperature alarm levels should be  established prior to
           testing. Manifold pressure changes should be accomplished by increasing and decreasing
           combustion air flow.


       •  Engine  efficiency -  Engine  efficiency  is  generally  determined  as  calculated  fuel
           consumption/actual measured fuel consumption.  Where an engine computer is available,
           overriding it and manually changing the engine horsepower value should vary this operating
           parameter.  This should cause the engine to change fuel flow without a true need for a fuel
           change (e.g., when actual  demand  on the engine is changed).  On  carbureted engines,
           manual adjustments can be made.  With the engine consuming non-optimal fuel, efficiency
           should be changed.   By increasing and  decreasing the horsepower  setting (or the gas
           supplied by the carburetor), efficiency can be raised to an optimum level,  and then reduced
           to a point where the engine efficiency or some other related engine alarm occurs.

       •  Ignition timing - Ignition timing can be manually adjusted.  As above, values just short of
           upper and lower alarm values should be established.

After the engine parameters and methods of perturbing operations are identified, tests should be conducted by
changing each of the  engine operating parameters both above and below normal operation. After reaching each
of the desired abnormal conditions,  emissions should be allowed to stabilize by observing real-time Reference
Method data, and then test runs of approximately 15 to 30 minutes should be conducted.  Depending on the
engine torque and speed, emission changes occurring as a result of changes in operating parameters may vary in
significance.  Thus, the evaluations  should be conducted at two or three different torque and speed conditions.
Evaluation of off-normal operations should focus  on specific speed and torque operating ranges that occur most
often  for the engine.   As an  example, the matrix summarizing the tests used for the ANR verification is
presented as Table 3-3.
              Table 3-3.  Example Off-Normal Engine Operating Conditions to be Tested

-------
Operational Parameter/Alarm Condition
Efficiency
Ignition Timing
Air Manifold Temperature
Air Manifold Pressure
High
Low
High
Low
High
Low
High
Low
Nominal Engine Speed/Torque (% capacity)
100/100
X
X
X
X
X
X
X
X
75/100
X
X
X
X
X
X
X
X
100/75
X
X
X
X
X
X
X
X
X indicates one test run of 15 to 30 minutes.
The adequacy of the PEMS response to off-normal conditions should be evaluated by comparing the emission
rates obtained from the Reference Method with the emission rates predicted by the PEMS during each of the
tests.   The absolute difference and percent difference between these two values should  be summarized and
reported. Figure 3-3 is an example of data collected during off-normal engine operation tests.  Interpretation of
results of these tests can expose  conditions where PEMS predictions of one or more pollutants can become
inaccurate as operating conditions change.  These tests can also be used to determine if PEMS predictions are
conservative, or higher than actual, for certain pollutants when abnormal operations are evident.  During the
ANR PEMS verification, NOX emission predictions were most affected by abnormal engine operation, primarily
due to changes to engine efficiency.
                    Figure 3-3.  Example Off-Normal Engine Operating Test Results
                   20
                 I -15
                 E 10
                            Torque
                            RPM (%)
                            RM
                            PEMS
Off Normal Operation Results - NOx
                    o                                                          o
                       35 36 43 44 49 50 39  40 47 48 55 56 33 34 41 42 53 54 37 38 45 46 51 52

                                              Run Number
      1-7

-------
3.3.2.    PEMS Response to Sensor Failure

Engine sensor signals are the primary basis of PEMS functions.  Therefore a series of tests should be conducted
to demonstrate the performance of PEMS when engine sensor drift or failure occurs, and to document PEMS
ability to identify potentially failed engine sensors.  As a first step in doing this evaluation, the vendor-designed,
failure-mode operational procedures should be determined (for example, use of redundant sensors).  The failure
mode operation should be reviewed  first for its thoroughness (are  enough contingencies  provided for) and for
applicability (are the procedures appropriate for the application).

As an example of this, the ANR PEMS that was  tested was designed to provide conservative NOX  emission
predictions when sensor drift or failure occurred.  When failure occurred, and redundant  sensors were used to
monitor the engine parameter, the ANR PEMS defaulted to the sensor input that resulted in the highest predicted
NOX  emission.   If the predicted emissions were higher than a pre-set maximum emission level, usually the
maximum permitted  emissions for  the operating engine, the PEMS alarmed.  When sensor failure occurred, the
operators used the PEMS  alarm to  diagnose and resolve failed sensors.  For engine parameters that do  not have
redundant sensors (e.g., energy efficiency and ignition timing), erroneous readings from failed sensors can also
result in high emissions indications and alarms at some point within the failure period.

To evaluate PEMS performance during sensor failure,  the PEMS emission predictions should be compared to
Reference Method data while simulating engine sensor outputs  that correspond to  a failed or drifting sensor.
The process should start by collecting and reviewing sensor calibration data for the test engine prior to testing to
document sensor accuracy.  Then  the sensor inputs to be tested should be identified along with a method of
electronically inhibiting sensor signals.  These typically  include ignition timing, exhaust manifold  pressure,
engine efficiency (fuel flow related sensors), air manifold temperature, and air manifold pressure. Other PEMS
applications may use additional engine monitoring sensors in determining emission bias factors and in these
cases, those sensors  should  also be  perturbed and the PEMS tested.   During the ANR  test, control  software
included the ability to put sensor signals in a control inhibit mode  that allowed the operator to simulate sensor
failure.

Testing should be conducted by establishing steady state  engine operation at torque and speed levels that are
within 75 to  100  percent of engine capacity.  Steady-state Reference Method and PEMS  emission rates should
be  reached to establish  comparability  prior to sensor perturbations.   Next,  sensor perturbation  should be
simulated by manually adjusting sensor output signals for each PEMS sensor.  Sensors should be perturbed one
at a time, and each should be changed by slowly adjusting the sensor output signal until the transmitter alarm
level  is reached.   Up to  three levels of sensor drift should be simulated whenever possible by periodically
incrementing perturbations to the sensor.  In some cases, engine alarms or upsets can be reached quickly and test
runs should be aborted to  avoid stalling or damaging the engine.  Test durations should be 15 to 30 minutes, or
as needed  to achieve stable PEMS  concentrations at multiple sensor  settings (up  to 3  sensor settings when
possible).  Throughout each perturbation period, the data below should be recorded.

        •   PEMS concentrations and emission rates for all pollutants,
        •   Reference Method concentrations and emission rates for all pollutants,
        •   Perturbed sensor signal values,
        •   All other sensor values, and
        •   Alarm/alert conditions  reported by the PEMS and engine computer.

The data should be used to verify how PEMS predictions change as sensors drift toward the alarm level, and, if
appropriate information is available for operators to identify if a sensor has failed.  The simultaneous reference
method data should allow  a  direct comparison  of actual  emissions with  PEMS  predictions, and should
demonstrate how the two values diverge as sensor failure approaches.  The entire procedure should be repeated

-------
for low- and high-level alarm regimes, and with all of the sensors that are used by a specific PEMS to predict
emissions.

The difference and percent difference between these two values should be summarized and reported. Figures 3-
4a and b provide examples of data presentation. During the ANR PEMS  verification, perturbations to certain
sensor signals did have  a significant affect on the accuracy of PEMS  predictions, especially cases where
redundant sensors are in use.   As shown  in these figures, perturbations to the air manifold pressure and
temperature sensors had a large impact on NOX emission predictions.
      1-Q

-------
Figure 3-4a. Example Single Sensor Perturbation Test Results as Percent Difference
                           Single Sensor Perturbation - NOx
50 "
40 "
o 30'
O
E 20 "
^
Q^
(f) 10 "
E
^ ° .
E
£ -10 .
0)
1 -20 "
it
2 -30 .
0)
e -40
0)
D_
-50 "
-60 '


	 ^^ ^^ \
— 1. 	 .
1 	 1 , 	 ,1 	 1
r nnn
n n
llflllllL nn

Q. Q. Q Q
§§§§§§§§JJJJ
llllllllllll


| 	 |

Q. Q.
1 1
1 1



[
1 1 1 1
-70
1234









«,
1
1




|

5

— • •-







s
£
1















S
£
1








— 	 	 ^

1—
nf
n
n DDnJ 1

y>
£
1





«,
1
1






Q Q Q Q Q Q
"OS "ai "ai "ai "ai 1





*^.


n

II






Q Q
15 15




1 ' % Difference
^^^^ Sensor Readina
• • i

678


' 110
' 100
' 90
c
g
' 80 ^
c
8
70 ra
c1 *£
60 '-a g_
S O
'50 | |
£ o
'40 ro 2
o
•E
30 g
oj
D_
20
' 10

0

Run Number
 Figure 3-4b.  Example Single Sensor Perturbation Test Results as Absolute Values
                          Single Sensor Perturbation - NOx
12 "
11
10 "
90 o o o
:•= :•= :•= :•=
•8,8,8,8,

1-1
•^ '

s7: ii
36" I
w
c
•i 5"
w
E
m 4

•
3

2 _ ^^

1 I
• II I II I II
0

~--\___ " \ — ' ---

= = = = EEEEEE SSS ii

Q Q Q Q Q Q
IIIIllllll 111 11 | | | | | |





1 n









-I




r




Sensor Reading (%)
3 RM
] PEMS
	

-i















"I r

n
i















i



r









r
















-, - '














" 110
	 " 100
" 90

Q Q c
1 1 " 80 i
T C
O
n 70 o
D)
p §
60~2
ro Q.
1 " 50 ? ro
S §

40 co J
'o
• "c
30 g

OJ
• Q_
20

10

0
12345678
Run Number

-------
                     4.0
                             FIELD TESTING AND CALCULATION PROCEDURES
4.1.   OVERVIEW

The procedures described in this section provide a framework for testing a PEMS during both normal and off-
normal engine operation.  They are based on EPA Performance Specification Test guidelines for CEMS (40
CFR 60, Appendix B), EPA Reference Methods for determination of emission rates (40 CFR 60, Appendix A),
and the document "Example Specifications and Test Procedures for Predictive Emission Monitoring Systems"
provided by EPA's Emission Measurement Center (Emission Measurement Center,  1999).

4.1.1.    Determination of Relative Accuracy

For each of the gases for which concentrations and/or emission rates are predicted by a PEMS, the parameter
that should be used to represent the result of the PEMS/Reference Method comparison is Relative Accuracy.
Relative Accuracy should be calculated in accordance with the four-step process outlined below.

First, calculate the arithmetic mean of the difference, d, for all runs conducted as in Equation 1 below:

                              1      n
                ~d~  —     	 X     d i
                             n    i = l                                         (Eqn. 1)
Where:
               n = number of runs
               d; = difference between Reference Method and PEMS output for a run
Second, calculate the standard deviation associated with all runs, Sd, as shown in Equation 2 below:
               S  d
                                  7
                                                   <
     I
n
                                          n  - i
                             (Eqn. 2)
Third, calculate the 2.5 percent error confidence coefficient (one-tailed), cc, as shown in Equation 3 below:

                                     S
               cc    -   t
                           0 .975
                             (Eqn. 3)
Where:
               to 975 = t-value (see Table 4-1).
     4- 1

-------
Table 4-1. t- Values
n*
2
3
4
5
6
tfl.975
12.706
4.303
3.182
2.776
2.571
n*
7
8
9
10
11
tfl.975
2.447
2.365
2.306
2.262
2.228
n*
12
13
14
15
16
Tfl.975
2.201
2.179
2.160
2.145
2.131
* The values in this table are already corrected for n-1 degrees of freedom. Use n equal to the number of
individual runs.
Fourth, calculate the Relative Accuracy, RA, for all runs as shown in Equation 4
below:
 Where:
RA   =    d
+
                                      cc
100
~RM~
               d\ = Absolute value of the mean differences (from Eqn. 1)

               cc\ = Absolute value of the confidence coefficient (from Eqn. 1)
              RM= Average Reference Method value
                                                                                (Eqn. 4)
The  test procedures  suggested  for utilization in this  guideline are Federal  Reference Methods. Reference
Methods are well documented in the  Code of Federal Regulations, include detailed procedures, and generally
address the elements listed below (40CFR60, Appendices A and B).

       •   Applicability and principle
       •   Range and sensitivity
       •   Definitions
       •   Measurement system performance specifications
       •   Apparatus and reagents
       •   Measurement system performance test procedures
       •   Emission test procedure
       •   Quality control procedures
       •   Emission calculations
       •   Bibliography

-------
Each of the selected testing methods utilizing an instrument measurement technique includes performance-based
specifications  for  the  gas analyzer used.  These  performance specifications cover span, calibration error,
sampling system bias, zero drift, response time, interference response, and calibration drift requirements.  An
overview of each  test  method suggested for use is presented in this section, with emphasis on the type of
monitors to be used, the monitor range, the sampling system configuration, and general calibration plans.  The
entire method  reference will not be repeated here, but should be available to site personnel during testing, and
can be viewed in  Appendix A of 40CFR60  (www.epa.gov/cfr40.htm).  Field log forms that can  be used to
conduct calibrations and other field activities  are presented in Appendix A.  Sample Reference Method  output
formats and summaries are also presented in Appendix A.

4.2.   SAMPLE HANDLING  AND  TESTING METHODS
4.2.1.    Sample Conditioning and Handling

A schematic of the sampling system used for the ANR test is presented as Figure 4-1. In order for some of the
instruments used to operate properly and reliably, the flue gas must be conditioned prior to introduction into the
analyzer if conditions are outside acceptable instrument parameters. The gas conditioning system shown in this
figure is designed to remove water vapor and/or particulate from the  sample. All interior surfaces of the gas
conditioning system are made of stainless steel, Teflon™, or glass to avoid or minimize any reactions with the
sample gas components. Gas is extracted from the gas stream through  a heated stainless steel probe, filter, and
sample  line  and transported to two ice bath condensers on each side of the sample pump.  The  condensers
remove moisture from the gas stream.  The clean, dry sample is then transported to a flow distribution manifold
where sample flow to each analyzer is controlled. Calibration gases can be routed through this manifold to the
sample probe by way of a Teflon™ line.  This allows  calibration and bias checks to include all components of
the  sampling system. The distribution manifold also  routes calibration gases directly to the analyzer when
linearity checks are made on each of the analyzers (other than the THC analyzer).

-------
                           Figure 4-1.  Gas Sampling and Analysis System
                                         Sample line and
                                        calibration gases
                                                                     B^S^B^E^S*
The time required for sample gas to travel from the probe tip to the analyzers and obtain a stable response (i.e.,
the system response time) must be determined to ensure that time-matched comparisons of PEMS and Reference
Method outputs are made.   The sampling system response time should be measured at the beginning of field
testing.  The procedure should include the following stepwise process for each analyzer used:

    1.  Initiate a flow of zero concentration calibration gas at the probe and wait for stable readings to occur,


    2.  Introduce a high concentration calibration gas at the probe while simultaneously recording the start time,


    3.  Record  the time at which the gas concentrations due to the step increase  are at 95 percent of their
       expected level, and


    4.  Repeat the procedure going from high range gas to zero gas, record that time, and record the system
       response time for that pollutant as the longer of the two.


The final system response time is the longest response time recorded for an individual test parameter over the
whole range of analyzers in use.

In addition to the system response time test, a flue gas stratification test should be conducted prior to the start of
testing to determine the most representative location to position  the reference method sampling probe.  The
     4-4

-------
procedures specified in Reference Method 20 for determination of NOX emissions from gas turbines should be
followed.   Since most engine exhaust ducts are less than  16 square feet in diameter,  8 traverse points are
sufficient to check for stratification.  Using a calibrated sampling system, measure the O2 or CO2 concentration
in the exhaust gas stream at each of the 8 traverse points selected.  If the concentrations are consistent at each of
the 8 points, position the probe tip near the GHG Center of the duct for sampling.  If the concentrations vary by
5 percent or more at one or more of the points, position the probe at the point where the value nearest to the
average O2 or CO2 concentration was measured.

4.2.2.    Calibrations

Calibrations should be conducted on all monitors using Protocol No. 1 calibration gases. Protocol No. 1 gases
comply with requirements for traceability to the National Institute of Standards and Technology.

Each monitor should be calibrated with a zero concentration gas.  In addition, each should be calibrated with a
suite of gases, selected to cover the monitor operating ranges specified later in Section 4. The NOX, CO2, and O2
monitors should be calibrated with two additional gas concentrations each. One concentration should be 40 to 60
percent of  span and one should be 80 to 100 percent of span. Maximum and actual pollutant concentrations
anticipated for the test engine should be  determined prior to the test to aid in  selecting appropriate calibration
gases and setting instrument ranges.  The CO and THC  monitors should be calibrated with three additional gas
concentrations.  For CO, the concentrations should include one each at approximately 30 , 60 , and 90 percent of
span.  For THCs, methane should be used if this is consistent with the basis that PEMS uses to report THCs (i.e.,
THC  concentrations quantified  as methane).   The calibration concentration ranges for THCs includes the
following: 25 to 35 percent, 45 to 55 percent, and 80 to 90 percent of span.

All monitor calibrations should be conducted daily, before sampling begins.  Calibrations should start by routing
calibration  gases directly to each monitor using the sample gas manifold, and then adjusting the monitors to read
the appropriate  calibration gas values. Note that the THC monitor calibrations are conducted through the entire
system only, not directly to the analyzer.  After adjustments  are made to the  analyzers, a final linearity test
should be  conducted by introducing each gas  to  the  analyzers and recording  responses  while  making  no
adjustments.  In accordance with Reference Method Criteria,  an analyzer response within two percent  of the
span (range) of the analyzer is acceptable.  Following this and after each test run, zero  concentration and mid-
span gases should be passed through the entire sampling  system, and  the values  that are measured should be
recorded.  Differences between the initial calibration and these system calibrations should be used to determine
system bias and drift values for each  run  and analyzer drift over the duration of each run.  After field operations
are complete, these bias and drift values should be used to  adjust measured Reference Method concentrations
before comparing  the values to PEMS predictions.  Details regarding the equations  used  to  calculate these
corrections are provided in the corresponding Reference Method.

Regarding  engine  sensor calibrations, the testing  entity should obtain copies  of the  most  recent calibration
records for all of these sensors. If PEMS  predictions do not agree well with Reference Method values during the
testing, these records may help in determining if the problem is related to sensor accuracy, or PEMS algorithm
problems.

4.2.3.    Reference Method 3A - Determination of Oxygen & Carbon Dioxide Concentrations

For CO2 and O2,  a continuous sample  should be extracted  from  the  emission source and passed through
instrumental  analyzers.  For determination  of CO2  a non-dispersive infrared  (NDIR)  analyzer or equivalent
should be used. This type of instrument measures the amount infrared light that passes  through the sample gas
versus a reference cell. As CO2 absorbs light in the infrared region,  the light attenuation is proportional to the
CO2 concentration in the sample. The CO2 monitor range should be set at 0 to 20 percent CO2.

-------
Oxygen should be analyzed using a fuel cell, electrochemical cell, or paramagnetic analyzer or equivalent. The
fuel cell and electrochemical cell analyzers use electrolytic concentration cells that contain a solid electrolyte to
enhance electron flow to the O2 as it permeates through the cell. The technology used by this type of instrument
determines levels of O2 based on partial pressures. The electrode is porous (zirconium oxide) and serves as an
electrolyte and as a catalyst.  The sample side of the reaction  has a lower  partial pressure than the  partial
pressure in the reference  side. The current produced by the flow  of electrons is directly proportional to the O2
concentration in the sample.   The paramagnetic technology used by this instrument determines levels of O2
based on the level of physical deflection of a diamagnetic material caused by exposure to the stack gas.  The
higher the O2 concentrations,  the greater the material is deflected.  An  optical system with an amplifier detects
the level of deflection, which is linearly proportional to the O2 level in the gas.  The O2 monitor range should be
set at 0 to 25 percent O2.

4.2.4.    Reference Method 7E - Determination of Nitrogen Oxides Concentration

Nitrogen oxides should be determined on a continuous basis, utilizing a chemiluminescence analyzer. This type
of analyzer catalytically reduces nitrogen  oxides in the sample gas to NO. The gas is then converted to excited
NO2 molecules by oxidation with O3 (normally generated  by ultraviolet light irradiation of air or oxygen). The
resulting NO2 luminesces in the infrared region.  This emitted light is measured by an infrared detector and
reported as NOX.  The intensity of the emitted energy from the excited NO2 is proportional to the concentration
of NO2 in the sample.  The efficiency  of the catalytic converter in making the changes in chemical  state for the
various nitrogen oxides is checked as an element of instrument set up and checkout.   The appropriate NOX
monitor range should be set based on preliminary site-specific data collected before starting the test.  More than
one range may be needed if measured NOX concentrations  vary widely between different engine load and speed
operations. In any case, measured NOX concentrations should be greater than 30 percent of the analytical range
selected, and no readings  should be higher than the selected range.

4.2.5.    Reference Method 10  - Determination of Carbon Monoxide  Concentration

For Reference  Method 10, a gas filter correlation analyzer utilizing an optical filter arrangement and NDIR
detection or equivalent should be used. The method chosen should provide high specificity for CO.

In the instrument suggested gas filter correlation utilizes a constantly rotating filter with  two  separate 180-
degree sections (much like a pinwheel.) One section of the filter contains a known concentration of CO, and the
other section contains an inert gas without CO. The sample gas is passed through the sample chamber containing
a light beam in the region absorbed by CO.  The sample is then measured for CO absorption with  and without
the CO filter in the light  path. Based upon the known concentrations of CO in the filter, these two values are
correlated to determine the concentration of CO in the sample gas.  An appropriate CO analyzer operating range
should be selected as described in Section 4.2.4.

4.2.6.    Reference Method 25A - Determination of Total Gaseous Organic Concentration

Total hydrocarbon vapors in the exhaust gas should be measured  using a flame ionization (FID)  analyzer.  The
method used by the FID passes the sample through a hydrogen flame. The intensity of the resulting ionization is
amplified, measured, and then converted to a signal  proportional to the concentration of hydrocarbons in the
sample.  Unlike the other reference methods, the sample stream going to the FID analyzer does not pass through
the condenser system, so it can be kept heated until it is  analyzed.  This is  necessary to avoid loss of the less
volatile hydrocarbons in the gas sample. Because all combustible hydrocarbons are being analyzed and reported,
the emission value must be calculated to some base (methane or propane). The calibration gas for THCs should
be either methane or propane; which ever is consistent with the basis on which the PEMS reports THC values.
An appropriate THC analyzer operating range should be selected as described in Section 4.2.4.

-------
4.2.7.    Determination of Emission Rates

If the PEMS predicts emissions in units  of mass per unit time, use Reference Method 19 to convert measured
concentration values of the exhaust gases to emission rate values.  This is accomplished by determining the
volumetric flow rate of the exhaust gas and then calculating the emission rate from the concentration and
volume data.   The fundamental  principle of this method  is  based  upon  F-factors, which are the ratio  of
combustion gas volume to the heat content of the fuel.  F-factors are calculated as a volume/heat input value,
(e.g.,  standard cubic feet per million Btu).  This method applies only to  combustion sources for which the
heating value  for the fuel  can be determined.   The F-factor can be calculated from measured CO2 or O2
concentrations.  This method includes all calculations required to compute the F-factors and guidelines on their
use.   The  F-factor for natural gas should be calculated from gas  compositional measurements  (elemental
analyses and lower heat content).  Many  facilities can provide these analyses using pipeline gas chromatograph
(GC)  data.  If not,  gas samples can  be  collected  and submitted to  a laboratory for analysis, or the  F-factors
published in Reference Method 19 can be used.

Other parameters needed  to complete the Method  19 conversions to mass rate include fuel flow rate measured
by a fuel flow monitoring system (pressure and temperature based),  and calculated engine brake horsepower
(can be calculated  from  engine speed and torque readings  per  operator based methods).  The step-by-step
calculations involved are listed below.

Step 1. Normalize measure pollutant concentrations to heat input.

        Concentration (Ib/MBtu) = measured concentration (Ib/scf) x  F-factor (scf/MBtu)

Step 2. Calculate the engine heat consumption rate in million Btu per hour.

        Heat consumption (MBtu/hr) = measured fuel flow (scfh) x fuel heating value (MBtu/ft3)

Step 3. Calculate emission rate as pounds per hour of pollutant.

        Emission rate (Ib/hr) = concentration (Ib/Mbtu)  x engine heat  consumption (Mbtu/hr)

Step 4. Normalize emission rates to engine output as grams per brake horsepower hour (g/BHp-hr).

        Emission rate (g/BHp-hr = (emission rate (Ib/hr) x 453.59 gms/lb) / engine output (BHp-hr)


As an alternative to Method 19 for determination of emission rates,  exhaust gas volumetric flow rate can be
determined using actual  stack gas measurements.  This testing  is  done in accordance with EPA Reference
Methods 1 through 4 and involves  determining exhaust gas velocity and  molecular weight, and using these
measurements along with the measured  stack cross-sectional area to calculate gas volumetric flow rate.  This
procedure is fully documented in the Reference Methods and not repeated here.  However, this procedure can
only be conducted  on engine exhaust stacks that have sufficient straight run of pipe, acceptable test ports with
safe access, and laminar flow characteristics.
4.3.   DATA ACQUISITION


Output from each of the instruments should be transmitted to a data acquisition system, typically a personal
computer-based data acquisition system.  The system clock should be synchronized with the PEMS  and the
engine control systems.  This system should be configured to receive signals from all of the instruments every
     4-7

-------
two seconds, and integrate those values over a pre-specified  averaging period.  During all tests, a 30-second
averaging period should be used for each monitored parameter,  and these  values should be stored for later
analysis and reporting purposes. Average values should also be determined over the time associated with each
run, and these values should be stored and used to determine run-average emissions for Relative Accuracy and
other determinations. Computer spreadsheets (Excel™ or other) can be used to calculate calibration results, and
make corrections to the data for calibration, system bias, and drift values.

Data should also be collected on engine performance parameters, and these data should be provided by either the
operator or PEMS  data  acquisition systems.   These data  will be needed to calculate some  verification
parameters, identify alarm/alert conditions, and interpret verification results.  Data should be recorded at 30-
second intervals, and then averaged for each test period.
     d-R

-------
               5.0       DATA VALIDATION, QUALITY ASSESSMENT, AND REPORTING
5.1.   DATA VALIDATION

Quality control checks for the Reference Method measurements were presented in Section 4.2.2. Upon review,
all data collected should be classified as valid, suspect,  or invalid.  In general,  valid results are based on
measurements that meet data quality goals, and that were  collected when an instrument was verified as being
properly calibrated.

Often anomalous data are identified in the process of data review.  All outlying or unusual values  should be
investigated daily in  the field using test  records,  test crew and engine operator interviews, and  log forms.
Anomalous data may  be considered suspect if no specific operational  cause to invalidate the data is found. All
data, whether valid, invalid, or suspect, should be included in the final report.   However,  report conclusions
should be based on valid data only.  The reasons for excluding any data should be justified in the report. Suspect
data may be included in the analyses, but may be given special treatment as specifically indicated.

All engine sensor and Reference Method data should be reviewed in the field by a designated field team leader
on a daily basis including those listed below.

        •   Run average comparison of Reference Method and PEMS  data for agreement based on
           arithmetic mean, standard deviation, and Relative Accuracy for each measured parameter

        •   Daily Reference Method calibration results and run-specific zero and mid-span  calibration
           results
5.2.   DATA QUALITY

As a consequence of using EPA Reference Methods to verify PEMS performance, measurement methodologies
and  data quality  determinations  are  defined.   Reference  Method  procedures  ensure  that  run-specific
quantification of instrument and sampling system drift and bias occurs, and that runs are repeated if specific
performance goals are  not  met.  Furthermore,  the  Reference Methods require adjustments be made to all
measured concentrations based on run-specific measurements of instrument and sampling system responses to
calibration checks. Normally, measurements of these data quality indicators would be used to quantify the data
quality achieved during testing, but in this case,  these data are used to adjust measured values to ensure that the
highest possible representativeness and quality exists in the final results.  Therefore, the Relative Accuracy and
other determinations  conducted are considered to be of acceptable quality if all Reference Method  calibrations,
performance checks,  and concentration corrections specified in the Reference Methods have been  successfully
conducted. As such,  the Data Quality Objective  (DQO) for all runs is to ensure that this has occurred.  Evidence
of the successful execution of these requirements should be documented in the verification report, along with
run- and pollutant-specific calibration results.

Specific data quality  indicators are discussed below including indicators for completeness, precision, and bias.
These apply to all of the verification parameters that should be assessed.   A  summary of the  data quality
indicator goals is shown in Table 5-1.

1.   Completeness should be 100 percent for the Relative Accuracy determinations.  This means that data must meet
    the DQOs (analyzer and system calibration criteria) for all RATA runs conducted.  Runs that don't meet the

-------
    DQO should be repeated.  The completeness goal for the  off-normal engine operating tests should be  85
    percent.  This goal is  lower than 100 percent to account  for potential difficulties that may occur in (1)
    establishing abnormal engine operating conditions planned for this series of tests, and (2) measuring potentially
    large and dynamic pollutant concentration profiles in a manner that meets the DQO.  Finally, the completeness
    goal for the sensor drift tests is 100 percent, which means that all runs should be conducted, as outlined in 3.3.2,
    that meet the DQO above, or be repeated. During the verification of the ANR PEMS, all of these completeness
    goals were met.

2.   System accuracy or bias assessments should be conducted at the beginning of each day using the  protocols
    defined in each Reference Method. This should be accomplished by routing a suite of calibration gases directly
    into each monitor. For each calibration gas concentration examined, a data quality indicator goal of ±  2 percent
    of the analyzer span value should be used for O2, CO2, NOx, and CO.  A goal of ± 5 percent of the calibration
    gas value should be used for THCs.  Daily accuracy values  determined from these  evaluations should  be
    reported in  the final verification report to document the ability of the testing entity to achieve the accuracy
    indicator goals specified above. These accuracies should be determined in the field, and if deviations from the
    goals are observed, sampling should be halted by the testing entity until corrective action is taken. A corrective
    action is the process that occurs when the result of an audit or quality control measurement is shown to  be
    unsatisfactory, as defined by the data quality objectives or by the measurement objectives for each task.  The
    corrective action process involves the Field Team Leader,  Project Manager,  and QA Manager.  In cases
    involving the analytical process, the correction action will also involve the analyst. A written Corrective Action
    Report is required on all corrective actions (Example in Appendix A).

3.   System precision or bias should be determined  for the combined sampling system and  analyzer at the
    beginning and end of each run using the protocols defined in each Reference Method. This is accomplished
    by routing zero concentration and mid-span gases through the sample collection lines and monitor systems,
    and comparing the measured concentrations with  the certified calibration values.  System bias,  determined
    in this manner, should be measured before and after each run to determine if the run is acceptable for use.  A
    drift  of greater than ±  3 percent of analyzer span (difference between the before and after system bias)
    should be considered unacceptable, and the  run  should be repeated.  If a drift of less than 3 percent occurs,
    which is the data quality indicator goal for precision, the average of the before and after system  bias values
    should be used to correct the measured concentrations  in each of the Reference Methods.  All system bias
    values  and calculated drift values should be  reported in the final verification report on a run-specific and gas
    specific basis as a means of documenting that this data quality indicator goal has been achieved.
Table 5-1. Data Quality Indicator Goals
Data Quality
Indicator
Completeness
Precision
Accuracy
Type of Verification Test
Relative Accuracy
100 %
Drift <± 3% of span
±2% of span3
±5 % of cal. conc.b
Off-Normal Engine
85%
Drift <± 3% of span
±2% of span3
±5 % of cal. conc.b
Sensor-Failure
100 %
Drift <± 3% of span
±2% of span3
±5 % of cal. conc.b
a 02, C02, NOX, and CO
b THCs
In addition to these quality control measures, independent systematic checks to determine the quality of the data
should be performed on the activities of this type of evaluation.  Under the ETV Program, these checks consist

-------
of a performance evaluation audit and data audit as described below.  In addition, the internal quality control
measurements are used to  assess the performance of the analytical methodology.  The combination of these
audits and the evaluation of the internal quality control data allow the assessment of the overall quality of the
data for the evaluation.

Under the ETV program, a designated QA Manager is responsible for ensuring the audits are conducted as
required by the site specific Test/QA Plan.   Audit reports that describe problems and deviations from the
procedures are prepared and distributed to the Field  Team Leader.  Any problems or deviations need to be
corrected. The Field Team Leader is responsible for evaluating corrective action reports, taking appropriate and
timely corrective actions, and informing the  QA  Manager of the  action taken.  The  QA Manager is  then
responsible for ensuring that the corrective action was taken.  A summary report of the findings and corrective
actions is prepared and distributed to the Project Manager and Center Director.

Performance Evaluation Audit

The performance evaluation audit (PEA) is designed to check the operation of the emissions testing analytical
system.  The method of performance will be based on  internal audits performed by the Field Team Leader. For
an evaluation of this type,  a blind audit of one or more of the analyzers can represent the PEA.  Calibration
gases can be obtained with  known (certified) concentrations of NOX, CO, and/or THCs and be presented to the
Entech analyst in such a manner as to have the concentration of the PEA unknown (blind) to the analyst. Upon
receiving the analytical data from the analyst, the  Field Team Leader will evaluate the performance data for
compliance with the requirements of the project.  The PEA must occur on-site during the field test.


Audit of Data Quality

The audit of data quality  (ADQ) is  an evaluation of the  measurement, processing, and evaluation steps to
determine if systematic errors have been introduced.   During the ADQ, the QA  Manager, or designee, will
randomly select approximately  10 percent of the data to be followed through the analysis and processing the
data.  The scope of the ADQ is to verify that the data-handling system is correct and to assess the quality of the
data generated.

The ADQ, as part of the system audit, is not an evaluation of the reliability of the data presentation.  The review
of the data presentation is the responsibility of the Project Manager and the technical peer reviewer.
5.3.   REPORTING

At the  completion of the evaluation, a draft verification report  and Statement is  prepared by the Project
Manager. Under the ETV Program, the final verification report contains a verification  statement, which is a 3 to
4  page summary  of the  PEMS  tested,  the test strategy used, and  the  verification results obtained.   The
verification  report summarizes the results  for each  verification parameter discussed in this  guideline and
contains sufficient raw data to support findings and allow others to assess data trends, completeness, and quality.
Clear statements should be provided  which characterize the performance  of the verification  parameters.   An
example outline of the report is shown below.

                                  Example Verification Report Outline

Verification Statement
      5-3

-------
Section 1:      Verification Test Design and Description
               Identification of Participants
               PEMS system and site description
               Overview of the verification parameters and evaluation strategies

Section 2:      Results
               Relative Accuracy Determinations
               PEMS Prediction Capabilities During Abnormal Engine Operation
               PEMS Response to Sensor Failure

SectionS:      Data Quality Assessment

Section 4:      Additional Technical and Performance Data (optional)

Appendices:    Raw Verification and Other Data

-------
                                     6.0      BIBLIOGRAPHY

Buchop,  Thomas  Robert,  et al.   "Parametric  Emissions  Monitoring System  Having Operating Condition
Deviation Feedback." United States Patent Number 5,703,777.  United States Patent Office.  Washington, DC.
December 30, 1997.

Code of Federal Regulations, Title 40, Part 60 (Appendices A and B).  United States Environmental Protection
Agency.  Washington, DC.  1999.

Code of Federal  Regulations, Title  40,  Parts  64 (Appendix C) and  75  (Appendix E).  United  States
Environmental Protection Agency. Washington, DC. 1999.

"Example Specifications  and Test Procedures  for Predictive  Emission Monitoring  Systems."   Emission
Measurement Center.  United States Environmental Protection Agency.  Research Triangle Park, NC. 1999.
Document can be obtained from the following Internet location www.epa.gov/ttn/emc/cem.html.

-------

-------
              APPENDIX A
                   Sample
              Field Data Log Forms
                     and
           Data Acquisition System Outputs
A-l

-------
              SAMPLE
             FIELD DATA
             LOG FORMS
A-

-------
              PEMS INSTALLATION/SET-UP CHECKLIST

Completed by:	                        Date:
 Complete
  Y/N/na
ACTIVITY/ITEM
            REMARKS
(if needed, continue on reverse side by item)
             Software installation and
               checkout completed
          Verify critical sensors - number,
                     model
           Sensor input present on engine
              computer, correct range
           Procure sensor calibration data
          Verify PEMS printouts available
            and include identification of
           engine, date, time, all emission
                values, and alarms
          Verify and document engine ID.
NOTES:
     A -

-------
         TESTING SET-UP/PREPARATION CHECKLIST
Completed by:
Date:
Complete
Y/N/na










ACTIVITY/ITEM
Identify test team participants and
team leader
Identify contact person for PEMS
and engine operation
Identify test team Reference
Method system - model, serial
number, wet or dry basis
Identify operating range and
calibration gases - contents,
concentrations, cylinder s/n
calibration certificate
Verify interference tests
documented or completed
Verify and document results of
NC>2 to NO conversion test
Verify DAS printout is complete
Verify stratification testing and
document results
Verify integrity of the sampling
system, multi-point sampling, and
document location of calibration
gas injection
Document system leak check
REMARKS
(if needed, continue on reverse side by item)










NOTES:
   A-4

-------
            TESTING SET-UP/PREPARATION CHECKLIST
                                    (continued)
 Complete
  Y/N/na
ACTIVITY/ITEM
            REMARKS
(if needed, continue on reverse side by item)
         Document system response times

         Synchronize PEMS and Reference
         Method Clocks
         Manually check DAS calculations
         Document any data points
         requiring manual data collection
         and transfer list to "Test Run
         Observation Checklist"
NOTES:

-------
                    TEST RUN OBSERVATION CHECKLIST
                           (Note: Complete a checklist for each test run)
Completed by:
Date:
Complete
Y/N/na















ACTIVITY/ITEM
Document planned test conditions
(from test matrix)
Pre-test calibrations on sampling
systems completed? Documented?
Atmospheric conditions



Start time for test run

Document actual test conditions
Verify PEMS and Reference Method
System are collecting required data
points
Verify all manually collected data
are documented
End time for test run

Post-test calibration of sampling
systems completed
Bias determined and applied to data
REMARKS
(if needed, continue on reverse side by item)


Temperature Barometric
Press. RH
Wind speed/direction /

Test Start




Test end



NOTES:
     A-fi

-------
                     TEST RUN OBSERVATION CHECKLIST
                                        (continued)
 Complete
  Y/N/na
ACTIVITY/ITEM
             REMARKS
(if needed, continue on reverse side by item)
          Copy of Reference Method test run
          data obtained
          Verify completeness
          Copy of PEMS test run data obtained
          Verify completeness
          Document all anomalies and
          unexpected events/conditions
          DAS output obtained?
          Obtain gas composition data?
NOTES:
     A-7

-------

Verification
Verification
Description
Corrective Action Report
Title:
Description:
of Problem:



Investigatic
Originator: Date:
>n and Results:




Investigator: Date:
Corrective Action Taken:





Carbon copy
Originator: Date:
Approver: Date:

Project Manager, Center Director, Center QA Manager, Pilot Manager

Pnae> A-R

-------
                 SAMPLE
           REFERENCE METHOD
         DATA ACQUISITION SYSTEM
                OUTPUTS
Pnae> A-Q

-------
      PLANT NAME:
                 UNIT # :
             LOCATION:
                   DATE:
RUN*
1
2
3
4
5
6
7
8
9
* 10
* 11
* 12
START END
TIME TIME
0:00
12:01
12:47
13:30
14:15
15:00
15:45
16:30
17:30



0:30
12:31
13:17
14:00
14:45
15:30
16:15
17:00
18:00



REFERENCE METHOD
IbNOx/
ppmd NOx %w CO2 mmBffl
268.80 13.28 0.435
274.23 13.34 0.442
279.63 13.21 0.455
275.21 13.35 0.443
272.02 13.27 0.441
272.58 13.27 0.441
268.34 13.25 0.435
271.52 13.28 0.439
268.61 13.28 0.435



CONTINUOUS MONITORING
IbNOx/
ppmd NOx %w CO2 mmBtu
265.05 13.08 0.436
264.45 13.05 0.436
261.90 13.03 0.432
264.50 13.03 0.436
262.85 12.97 0.436
259.75 13.03 0.428
253.40 12.94 0.421
254.50 12.94 0.423
252.75 12.99 0.418



DIFFERENCE
IbNOx/
ppmd NOx %w CO2 mmBtu
3.75 0.20 -0.001
9.78 0.29 0.006
17.73 0.18 0.023
10.71 0.32 0.007
9.17 0.30 0.005
12.83 0.24 0.013
14.94 0.31 0.014
17.02 0.34 0.016
15.86 0.29 0.017



Test Mean: 272.33 13.28 0.441 259.91 13.01 0.430
MEAN DIFFERENCE: 12.42 0.27 0.01
NOx Conversion Factor: 1.194E-07 Ib NOx / SCF - ppm NOx
Fc- Factor: 180° SCF/mmBtu STANDARD DEVIATION: 4.52 0.06 0.01
CONFIDENCE COEFFICIENT: 3.47 0.04 0.01
Bias Adjustment Factor = (1 + d/CEM) RELATIVE ACCURACY (%): 5.84 | 2.39 3.81
WHERE: d = Meanof the Differences BIAS ADJUSTMENT FACTOR: 1.026
GEM = Mean of the Source Monitor's Data Values
T - VALUE: 2.306
Run not included in Relative Accuracy Calculations

-------
                              Reference Method Values Corrected for Bias & Drift
                      PLANT NAME:
                            UNIT*:
                            RUN #:
                       START TIME:
                         END TIME:
                                                                     DATE:
CAL GAS
0.00
443.00
0.00
463.60
0.00
12.12
0.00
11.50
VALUE
ppm SO2
ppm SO2
ppm NOx
ppm NOx
%02
%02
% CO2
% CO2
INITIAL CAL
4.15
435.41
1.22
437.36
0.18
12.15
0.15
11.38
FINAL CAL
2.69
439.80
0.73
439.80
0.43
12.27
-0.05
11.48
AVERAGE CAL
3.42
437.61
0.98
438.58
0.31
12.21
0.05
11.43
                                            Raw Data:  223.11 ppm SO2
                                                      257.27 ppm NOx
                                                        6.41 % 02
                                                       13.19 % CO2
                                            	0.000 % H20
                                   CORRECTED VALUES:  224.15 ppmw SO2
                                                      271.52 ppmw NOx
                                                       13.28 %w CO2
                                                       0.439 IbNOx/mmBtu
                                                        6.22 %d O2
                                      	13.7.8 Q/.H rm	
                     CONVERSION FACTORS:
                                   NOx =  1.194E-07  IbNOx /  SCF - ppm NOx
                             Fc - FACTOR =       1800  SCF / mmBtu

                     SAMPLE CALCULATIONS:

                      CORRECTED VALUES = Cma * (C - Co) / (Cm - Co)

                                   WHERE: C    = MEAN REFERENCE MEASUREMENT
                                         Co  = MEAN ZERO CALIBRATION RESPONSE
                                         Cm  = MEAN MID OR UPSCALE CALIBRATION RESPONSE
                                         Cma = ACTUAL MID OR UPSCALE CAL GAS CONCENTRATE

                          EMISSION RATE = (ppm)(Conversion Factor)(Fc-Factor)(100 / % CO2)
A-l 1

-------
                                    System Bias & Drift Calculations
                     PLANT NAME:
                            UNIT #:
                            RUN  #:
                       START TIME:
                         END TIME:
                                                                                 DATE:
ANALYZER SPAN: 1000.00
1000.00
25.00

3 VALUE

ppm SO2
ppm SO2
ppm SO2
ppm NOx
ppm NOx
ppm NOx
% O2
% O2
% O2
% CO2
% CO2
% CO2

CAL ERROR
RESPONSE
1.10
451.53
956.04
0.73
468.13
860.81
-0.18
12.15
20.70
0.05
11.67
17.53
20.00
CAL ERROR
( % OF SPAN )
-0.11
-0.85
0.01
-0.07
-0.45
0.00
0.72
-0.12
-0.24
-0.25
-0.85
-0.15
ppm SO2
ppm NOx
% O2
% CO2
INITIAL
SYSTEM BIAS CHECK
RESPONSE (% BIAS)
4.15 0.31
435.41 -1.61

1.22 0.05
437.36 -3.08

0.18 1.44
12.15 0.00

0.15 0.50
11.38 -1.45





FINAL
SYSTEM BIAS CHECK
RESPONSE
2.69
439.80

0.73
439.80

0.43
12.27

-0.05
11.48

(% BIAS)
0.16
-1.17

0.00
-2.83

2.44
0.48

-0.50
-0.95



DRIFT
(% OF SPAN)
-0.15
0.44

-0.05
0.24

1.00
0.48

-1.00
0.50

      IION ERROR = (( R-A ) / S ) * 100
                                                          R = CALIBRATION GAS VALUE
                                                          A = REFERENCE ANALYZER RESPONSE
                                                          S = ANALYZER SPAN VALUE
      3IAS = (( C - A) / S) * 100
                                                          C = SYSTEM CAL RESPONSE
                                                          A = ANALYZER CAL RESPONSE
                                                          S = ANALYZER SPAN VALUE
                                                          Cf = FINAL SYSTEM CAL RESPONSE
                                                          Ci = INITIAL SYSTEM CAL RESPONSE
                                                          S = ANALYZER SPAN VALUE
A-17

-------
                                Volumetric Flow Rate Determination
      PLANT NAME:
             UNIT #:
             RUN  #:
        START TIME:
          END TIME:
              DATE:
                                             TEST DATA
Test
Beiat
A-l
A-2
A-3
A-4
A-5
A-6
A-7
A-8
B-l
B-2
B-3
B-4
B-5
B-6
B-7
B-8
MAX.
MTN
Delta P
fin H2O)
0.530
0.520
0.530
0.490
0.530
0.520
0.500
0.450
0.530
0.530
0.520
0.470
0.540
0.520
0.510
0.440
0.540
0 440
Temperature
(Dog. F)
126
126
127
129
128
128
123
125
128
129
128
125
125
125
125
125
129
1 7^
                                                               Stack Diameter (D):
                                                                   Stack Area (A):
                                                         Barometric Pressure (Pbar):
                                                               Static Pressure (Pg):
                                                               Percent O2 (% O2):
                                                             Percent CO2 (% CO2):
                                                           Percent Nitrogen (% N2):
                                                         Pilot Tube Coefficient (Cp):
                                                            Meter Box Delta H (dH):
                                                              Meter Box Factor (Y):
                                                         Average Meter Temp. (Tm):
                                                           Gas Meter Volume (Vm):
                                                                    Impinger (V):
                                                                    Silica Gel (W):
                                                       Root Mean Sq. Delta P (Pavg):
                                                       Mean Stack Temperature (Ts):
               367.00
              105,784
                29.70
               -0.480
                 6.22
                13.28
                80.50
                 0.84
                 1.94
               0.9800
               67.300
               23.838
                   62
                  3.6
       inches
       sq. inches
       inches Hg
       inches H2O
       %O2
       % CO2
       %N2
       degrees F
       cubic feet
       ml
       grams
               0.5077 inches H2O
               126.38 degrees F
                                            CALCULATIONS
 Vm(std) = (Vm)(Y)(17.64((Pbar)/(Tm + 460))
 Vwc(std) = (V)(.04707) + (W)(.04715)
 % H2O = [Vwc(std) / (Vwc(std) + Vm(std))] x 100
 Mfd = 1 - (%H2O / 100)
 Ps = Pbar + (Pg/ 13.6)
 Md = 0.44(% CO2) + 0.32(% O2) + 0.28(% N2)
 Ms = (Md)(Mfd) + 0.18(% H2O)
 Vs = 85.49 (Cp) x SQRT[(Pavg)(Ts + 460) / (Ps)(Ms)]
 Qsd = (60 / 144)(Mfd)(Vs)(A)(Ps / Pstd)(Tstd / (Ts +  460))
 Qs = (3600 /  144)(Vs)(A)(Ps / Pstd)(Tstd / (Ts + 460))
 Qaw = (60 / 144)(Vs)(A)
 Vm(std) =
Vwc(std) =
  % H2O =
    Mfd =
     Ps  =
     Md =
     Ms  =
     Vs  =
23.211 dscf
3.0834 cubic ft.
11.726 %H2O
 0.883
29.665 in. Hg
30.374 Ib/lb-mole
28.931 Ib/lb-mole
 42.29 ft/sec
    Qsd =  1.469E+06 DSCFM
     Qs =  9.985E+07 SCFH
    Qaw =  1.864E+06 ACFM
               1664.1 Kscfm
A-ll

-------