Review of Compliance Test Methods for Determining Formaldehyde Emissions from IC Engines and Turbines with Potential Application to Other Combustion Sources INTRODUCTION This is a review of techniques that are being used for measuring formaldehyde emissions from IC engines and turbines. Since the source operators could use the procedures for data gathering in the EPA rule-making process, a clear understanding of the strengths and deficiencies of these methods is necessary. Although the comparisons are based upon engines and turbine measurements, the observations are potentially applicable to other combustion sources. The following methodologies are reviewed: 1. The extractive FT-IR method 2. The aqueous acetylacetone impinger method (NCASI or Celanese Method). 3. The DNPH impinger methods (CARB 430 and EPA Method 0011). 4. The dry DNPH method (the Ashland Method). SUMMARY The extractive FT-IR is currently the best of the EPA recognized methods for measuring formaldehyde concentrations in engine combustion exhaust gas. FT-IR might also be the least expensive method where formaldehyde, other aldehydes, and criteria pollutant emissions will be measured over a range of operating conditions or on multiple units at the same site. But measurement costs are expensive when only one or a few formaldehyde measurements at a single source are required. The acetylacetone method can be applied at a low cost and it has shown promise as an accurate and reliable method. The Gas Research Institute (GRI) and Radian plan to perform an EPA Method 301 validation for the acetylacetone method in the coming months and expect EPA approval for its use at natural gas fired units within six months to a year. In the meantime, we recommend that comparative tests using this method should be conducted whenever the opportunity exists within EPA and ICCR source group source test plans. The DNPH impinger and the dry DNPH methods are less reliable than the other two methods for engine combustion gas measurements. DTSCUSSTON August 28, 1998, FORMALD2.WPD ------- 1. The Extractive FT-IR Method The extractive FT-IR is currently the most accurate and reliable measurement technique. It has been reviewed by the EPA and has been approved for natural gas fired combustion sources. However, the extractive FT-IR method is presently relatively expensive and complex procedure. Field measurements require a trailer or van with expensive equipment and highly trained personnel. Once on the site, however, the instrument and the personnel can make many measurements quickly. We believe that FT-IR will likely be the least expensive alternative for field tests where formaldehyde and other aldehydes will be measured over a range of operating conditions along with criteria pollutant emissions (CO, NO, N02), or if there are multiple units at the same site. The highly trained testing personnel at the site can recognize test interference problems, make on site adjustments in measurement procedures, and provide the operators with real time emissions data. The FT-IR measurement procedure might be simplified to specifically address measurement of formaldehyde and criteria pollutant emissions from combustion sources. In the future, field-ready instruments might be pre-tuned to give direct concentration readings. This will enable the use of less specialized instrument operators and lower the testing costs. However, since such instruments are not yet available, the cost for measuring only formaldehyde emissions at a single field source will likely be high relative to the other three methods. Accurate cost comparison data are needed and these will depend upon the specific test program details. 2. The Aqueous Acetylacetone Method ("AAA Method") This is a method that was published in the National Council of the Paper Industry for Air and Stream Improvement, Inc., Technical Bulletin No. 684 and has been widely used by the Celanese Corp. The source gas is drawn through midget impingers containing chilled water. The formaldehyde concentration in the impingers is determined by the AAA procedure. This involves the reaction of the acetylacetone with formaldehyde to produce a colored derivative which is then measured by colorimetric analysis. The sampling procedure is inexpensive and measurements can be carried-out by most environmental contract laboratories. The GRI has recently funded Radian to carry out a series of comparative studies between this technique and the FT-IR on emissions from a gas fired internal combustion engine and got excellent agreement. No evidence was found of interference from nitrogen oxides or acetaldehyde. The GRI plans to proceed with EPA 301 validation test and obtain EPA approval within 6 months to a year. After validation is obtained, we believe that this method will be an excellent alternative method to the already validated FT-IR method when only formaldehyde concentrations August 28, 1998, FORMALD2.WPD ------- are of interest and no criteria pollutant data are needed. For such applications, it will be an accurate, precise, and least-cost alternative. 3. The DNPH Impinger Methods Most of the current formaldehyde emissions data have been gathered by DNPH impinger methods. The DNPH method was initially developed for analysis of ambient air and vent streams and subsequently applied to combustion gases without extensive validation tests. The GRI research program has identified inaccuracies with the method when they tested IC engines using the FT-IR and DNPH impinger methods. The problem was initially traced to a competitive reaction of nitrogen dioxide with DNPH that depleted the DNPH reagent and appeared to be limited to measurements on sources with relatively high nitrogen dioxide concentrations. Subsequent laboratory tests indicated that high NO levels may also be a problem. However, it is incorrect to assume that all data collected by DNPH procedures are invalid. GRI and Radian are in the process of analyzing data from a laboratory study on DNPH method interferences and intend to present their findings in a GRI Topical Report planned for release in October, 1998. With the advent of the AAA Method, the potential need for the DNPH methodology for combustion source measurements is greatly diminished since the AAA Method will be suitable for testing on all IC engine types. 4. The Dry DNPH Method (Ashland Method). This method consists of sampling the emissions gases using a proprietary sorbent resin that has been coated with DNPH. It has been used by Radian in a series of tests sponsored by GRI and the American Petroleum Institute (API) together with the validated FT-IR method. Measurements were made on both engine and turbine emissions. Although special sampling procedures were used to cool the sorbent tubes to achieve the proper moisture content on the DNPH tubes, poor agreement was found in both instances. Because the analyses of the tube had to be carried out at a designated laboratory, costs for this procedure were higher than that for the AAA Method. No further tests of this method are planned in GRI or API sponsored research programs. 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