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VERG

Quality Assurance Project Plan for
SPod Monitoring at the Denka Performance
Elastomer Facility in LaPlace, Louisiana

QA Category: A / Measurement

Prepared for:

Office of Enforcement and Compliance Assurance (OECA)

Environmental Protection Agency
1200 Pennsylvania Avenue, N.W.

Washington, DC 20460

Prepared by:

Eastern Research Group, Inc.

601 Keystone Park Drive
Suite 700
Morrisville, NC 27560

Revision Number: 0
February 2020

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Contract No. EP-W-15-006
Contract No. EP-S5-17-02
Contract No. 68HERH19C0004


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Approval Sheet

Quality Assurance Project Plan for SPod Monitoring at the Denka Performance Elastomer

Facility in LaPlace, Louisiana

Daniel Hoyt, EPA Task Manager {Contract #EP-W-15-006)
Signature/Qase	g//?/Wo

V

Paul Buelfesbach. ERG Program Manager {Contract #EP-W-15-006)
Signature/Date:	/ // ,

2/19/2020

Andy Loll, ERG Program Manager (Contract #66HERH19C0004)
Signature/Date;

j Program Manager contract wsertcKm^uuu^

Q-/ ffl/JshP &
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Table of Contents	Page

Approval Sheet	2

Acknowledgments and Disclaimer	8

1.0 Introduction	9

2.0 Project Management Elements	9

2.1	Element A.3: Distribution List	9

2.2	Element A.4: Project Organization	10

2.3	Element A.5: Problem Definition/Background	12

2.3.1	Stochastic Industrial Sources	12

2.3.2	Chloroprene Emissions-Denka Performance Elastomer Facility	13

2.4	Element A.6: Project/Task Description	17

2.5	Element A.7: Quality Objectives and Criteria	18

2.6	Element BA.8: Special Training/Certification	19

2.7	Element A.9 Documents and Records	19

3.0 Data Generation and Acquisition	20

3.1	Element B. 1: Sampling Process Design	20

3.2	Element B.2: Sampling Methods	23

3.2.1	SPod Measurement Approach	23

3.2.1.1 General SPod Description	23

3.2.2	Initi al Phase	24

3.2.3	Sampling Phase	25

3.2.4	Triggered Sampling with Evacuated Canisters	25

3.2.5	Continuous Meteorology Measurements	26

3.3	Element B.3: Sample Handling and Custody	26

3.3.1	Canister Preparation	26

3.3.2	Canister Setup	27

3.3.3	Canister Sample Recovery and Shipping	28

3.4	Element B.4: Analytical Methods	29

3.4.1 Analysis of Canister Samples	29

3.5	Element B.5: Quality Control	30

3.5.1	Continuous SPod PID Measurements QC Checks	30

3.5.2	Continuous SPod Meteorological Measurements	33

3.5.3	Canister Sample QC Check	33

3.6	Element B.6: Instrument/Equipment Testing, Inspection, and Maintenance	35

3.6.1	Pre-deployment Isobutylene Testing	35

3.6.2	Pre-deployment Isobutylene and Chloroprene Bump Tests by ERG	35

3.6.3	SPod Operational Tests	35

3.6.4	Interferences	36

3.6.5	SPod Routine Quality Checks	37


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3.7	Maintenance and Troubleshooting	37

3.8	Equipment Retrieval	37

3.9	Element B.7: Instrument/Equipment Calibration and Frequency	38

3.10	Element B.8: Inspection/Acceptance of Supplies and Consumables	38

3.11	Element B.9: Non-direct Measurements	38

3.12	ElementB.lO: Data Management	38

3.12.1 SPod Data Processing	40

4.0 Assessment and Oversight	41

4.1	Element C.l: Assessments and Response Actions	41

4.2	Element C.2: Reports to Management	41

5.0 Data Validation and Usability	41

5.1	Elements D. 1: Data Review, Verification, and Validation and D.2: Verification
and Validation Methods	41

5.1.1	SPod Data Compilation and Reduction	41

5.1.2	Canister Results	42

5.1.3	Data Validation, Validation Methods and Verification	42

5.2	Element D.3: Reconciliation with User Requirements	44

6.0 References	44

Appendix A: Equipment List	46

Appendix B: MOP 3010	48

Appendix C: Remote Data Retrieval Procedure	85

Appendix D: Certificates of Analysis	86

Appendix E: Sensit SPOD Sensor Operational Manual	88

Appendix F: Copy of ERG's current National Environmental Laboratory Certification for EPA
Method TO-15 analysis	120

Appendix G: Sampling Plan	124

Appendix H: Health and Safety Plan	131

Figures

Figure 2-1. Project Organizational Chart	12

Figure 2-2. Location of the Facility with Respect to Monitoring Locations	15

Figure 2-3. Seasonal Wind Rose for February - March of 2019, for Louisiana ASOS at

MSY Airport (Iowa State University - Iowa Environmental Mesonet website)	16

Figure 2-4. Seasonal Wind Rose for April - July of 2019, for Louisiana ASOS at MSY

Airport (Iowa State University - Iowa Environmental Mesonet website)	16

Figure 3-1. Aerial image of planned SPod deployment around Facility	22

Figure 3-2. Sensit SPod system	23

Figure 3-3. Example of (a) raw and (b) processed SPod data	24

Figure 3-4. Evacuated Canister COC Form	27


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Figure 3-5. Flow diagram for Sensit SPod data retrieval	39

Tables

Table 2-1. Crosswalk Between Document Sections and EPA Quality Assurance Project
Plan Elements	9

Table 2-2. Key Individuals and Responsibilities	10

Table 2-3. Statistical Chloroprene Concentrations in LaPlace Post-RTO Implementation 14

Table 2-4. Statistical Chloroprene Concentrations in LaPlace Pre-RTO Implementation.. 14

Table 2-5. Distances from SPod Monitoring Sites to Denka Facility in LaPlace, LA	18

Table 2-6. Project Schedule	18

Table 2-7. Summary of Overall Project Measurement Quality Objectives	19

Table 3-1. ERG's Laboratory VOC MDL - Compendium Method TO-15	30

Table 3-2. Summary of Field SPOD QA/QC Procedures	32

Table 3-3. Summary of Field Canister Sample QA/QC Procedures	33

Table 3-4. Summary of Analytical Laboratory Method TO-15 QA/QC Procedures	34

Table 5-1. Summary of Post-Study Data Comparisons	42

Table 5-2. Summary of Data Validation and Auditing	43

Table 5-3. VOC Compound Performance Evaluation Audit Data	44

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Acronym List

AED	Air Enforcement Division

AMCD	Air Methods and Characterization Division

AOC	Administrative Order on Consent

ASOS	Automated Surface Observing System

BFB	Bromofluorobenzene

CAA	Clean Air Act

CCV	Continuing calibration verification

CEMM	Center for Environmental Measurement & Modeling

COC	Chain-of-custody

C OV	C oeffi ci ent of Vari ati on

DOJ	Department of Justice

EPA	U.S. Environmental Protection Agency

ERG	Eastern Research Group Inc.

GC	Gas chromatograph

GC/MS	Gas chromatography/mass spectrometry

GPS	Global positioning system

HAPs	Hazardous air pollutants

Hg	Mercury

Hz	Hertz

ICAL	Initial calibration

ICV	Initial calibration verification

ID	Identification

IS	Internal standard

kPa	Kilopascal

LDEQ	Louisiana Department of Environmental Quality

lpm	Liter per minute

m	Meter

MB	Method blank

MDL	Method detection limit

MET	Metrological station

MOP	Miscellaneous operating procedure

MQO	Measurement quality objective

NATA	National Air Toxics Assessment

NATTS	National Air Toxic Trends Stations

NEIC	National Enforcement Investigation Center

NIST	National Institute of Standards and Technology

NWS	National Weather Service

OAQPS	Office of Air Quality Planning and Standards

OCE	Office of Civil Enforcement

OECA	Office of Compliance and Enforcement

ORD	Office of Research and Development

PID	Photoionization detector

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ppbV

Parts per billion by volume

ppm

Parts per million

QA/QC

Quality Assurance/Quality Control

QAPP

Quality Assurance Project Plan

RH

Relative humidity

RPD

Relative percent difference

RRT

Relative retention time

RSD

Relative Standard Deviation

RT

Retention time

RTO

Regenerative Thermal Oxidizer

RTP

Research Triangle Park

SD

Secure digital

SIM

Selected-ion Monitoring

SIS

Stochastic Industrial Sources

SOP

Standard operating procedure

[j,g/m3

Micrograms per cubic meter

[j,m

Micrometer

voc

Volatile organic compound

WAM

Work assignment manager


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Acknowledgments and Disclaimer

This Quality Assurance Project Plan (QAPP) was prepared with input from the broad project team.
Portions of this document were prepared by ERG under contract EP-W-15-006 WA 2-1. Technical
information pertaining to SPods in this document was drawn from the EPA ORD CEMM/AMCD
SPod Procedure (MOP 3010, see references section) and the Sensit SPod Sensor Operational
Manual and Configuration Guide found in Appendix E. Any mention of trade names, products,
services, or enterprises does not imply an endorsement by the U.S. Government, or by EPA.

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1.0 Introduction

Denka Performance Elastomer LLC ("Denka") owns and operates a neoprene manufacturing
facility (the only neoprene production facility in the U.S.) at the Pontchartrain Works Site in
Laplace, Louisiana (the "Facility"). Denka acquired the Facility from E.I. du Pont de Nemours and
Company (DuPont) on November 1, 2015. On December 17, 2015, EPA released the results of the
2011 National Air Toxics Assessment (NATA). These results indicated the highest modeled cancer
risks in the country were associated with an area in St. John the Baptist Parish, Louisiana,
attributable to chloroprene (a likely human carcinogen) emissions from Denka's Facility. EPA
Region 6 began monitoring the air at six locations in the surrounding community in May 2016 (see
Figure 2-2), conducted a Clean Air Act (CAA) inspection of the Facility in June 2016, and
subsequently referred CAA violations to the Department of Justice (DOJ) for civil enforcement.

2.0 Project Management Elements

This section addresses project management, including project objectives, roles and
responsibilities, and project goals. In addition, this section discusses the mechanisms ERG will use
to ensure that all participants understand the goals and the approach used in the investigation of
stochastic industrial sources (SIS) from the Denka Facility in LaPlace, LA.

In its Requirements for Quality Assurance Project Plans QA/R-5 (1), EPA identified twenty-four
elements to be discussed in this document. Table 2-1 presents the elements and corresponding
document sections.

Table 2-1. Crosswalk Between Document Sections and EPA Quality Assurance Project

Plan Elements

Quality Assurance Project Plan Element

Document Section

A1 andA2

Title and Approval Sheet, Table of Contents

Title Page and Approval Sheet Table of
Contents

A3 through A9

Distribution List, Project Organization, Problem
Definition/Background, Project/Task Description,
Quality Objectives and Criteria, Special
Training/Certification, Documents and Records

2.0

B1 through B10

Sampling Process Design; Sampling Methods;
Sample Handling and Custody; Analytical Methods;
Quality Control; Instrument/Equipment Testing;
Inspection, Maintenance, and Calibration;
Inspection/Acceptance of Supplies and
Consumables, Non-Direct Measurements; Data
Management

3.0

CI andC2

Assessments and Response to Actions, Reports to
Management

4.0

Dl,D2,andD3

Data Review, Verification, and Validation;
Verification and Validation Methods; Reconciliation
with User Requirements

5.0

2.1 Element A.3: Distribution List

Copies of this plan and all revisions will be sent to the following individuals. It is the responsibility
of the U.S. Environmental Protection Agency (EPA) OECA Project Lead, EPA Region 6 contract
oversight, EPA NEIC technical leads, Weston Solutions, Inc., and Eastern Research Group, Inc.
(ERG) Task Managers to make copies of the plan available to all project personnel.

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EPA

Daniel Hoyt, EPA OECA/OCE/AED
James Leathers, EPA Region 6
Bill Squier, EPA NEIC
Brad Venner, EPA NEIC
Eben Thoma, EPA ORD/CEMM/AMCD
Shaun Burke, EPA OECA/OCE/AED
Jeffrey Kimes, EPA OECA/OCE/AED
Aunjanee Gautreaux, EPA Region 6
Weston Solutions, Inc.

David Bordelon
Eastern Research Group, Inc.

Scott Sholar, ERG
Jill Lucy, ERG

2.2 Element A.4: Project Organization

Table 2-2 provides a list of project personnel, their organization, and their responsibilities on this
project. Figure 2-1 presents the project organization and key personnel.

Table 2-2. Key Individuals and Responsibilities

Individual or Organization
Assigned

Role

Responsibility

Daniel Hoyt
EPA/OECA/AED

EPA OECA Project Lead

Responsible for the oversight, review, and acceptance/approval
of all project activities.

James Leathers
EPA/Region 6

Project co-leader for EPA
Region 6

Communications within EPA R6 and with other parties and
technical support for the effort

Bill Squier
EPA/NEIC

EPA NEIC SPod deployment
and training support

Responsible for SPod technical support

Brad Vernier
EPA/NEIC

EPA NEIC SPod data
analysis support

Responsible for management of SPod data analysis/summaries
for the project.

Eben Thoma
EPA/ORD/NRMRL

EPA ORD Scientist, lead for
SPod QA Testing

Lead for SPod measurement systems support, technical support,
and data processing support.

David Bordelon Weston
Solutions, Inc.

Weston Task Manager

Responsible for all aspects of Weston work that is tasked related
to this project. Responsibilities include onsite sample collection
and troubleshooting.

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Individual or Organization
Assigned

Role

Responsibility

Scott Sholar

Eastern Research Group, Inc.
(ERG)

ERG Task Manager

Responsible for all aspects of analytical lab work related to this
project. Responsibilities include management of the canister
sample analysis and reporting both canister and SPod data
retrieval, processing, comparison to 24-hr canister data, and
delivery to EPA.

Weston's role includes performing the SPod bump tests, collecting canister samples, filling out
chain of custody forms, and connecting clean canisters. Weston will communicate with the ERG
Task Manager or the EPA OECA Project Lead if there are any problems with the SPods, SPod
operation, canister leaks, or canister sampling.

ERG's roles include setting up the SPods, retrieving the raw SPod data remotely, conducting
quality assurance evaluations, processing raw SPod data, delivering the SPod data to the EPA
OECA Project Lead, and providing routine project data analyses to EPA OECA Project Lead.

ERG will also perform canister sample analysis for canisters triggered by the SPods. ERG will
perform comparisons of the processed SPod data to the 24-hour canister sample data to help
determine appropriate SPod canister trigger thresholds and verify the presence of chloroprene
when the threshold level has been exceeded. ERG will communicate with the EPA OECA Project
Lead if there are any problems with the SPods determined from the SPod or canister analysis data.
ERG will deliver canister analysis data to EPA OECA Project Lead.


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Figure 2-1. Project Organizational Chart
2.3 Element A.5: Problem Definition/Background

2.3.1 Stochastic Industrial Sources

Volatile organic compounds (VOC), hazardous air pollutants (HAPs), and odiferous species can
be emitted from a variety of sources in industrial facilities and commercial operations. Known
and/or permitted emissions can originate from stacks, tanks, vents, and other sources as part of
normal operations. These sources are typically well-understood and lend themselves to standard
emission inventory approaches. Some industrial emissions can be less predictable (randomly
occurring) and can originate from unanticipated sources or sources that are generally not well
understood.1

1 EPA, 2018


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In this Quality Assurance Project Plan (QAPP), these randomly occurring emissions are called
stochastic industrial sources (SIS), and they are broadly defined to include fugitive emissions and
equipment leaks, improperly vented emissions, variably emitting area sources and sewers, and
emissions from malfunctioning processes or improperly controlled operations. Compared to most
air pollution sources, emissions from SIS are more challenging to understand and manage.
Whereas traditional sources have a definite emission origin (e.g. a stack or tailpipe) and are
typically understandable through engineering models (e.g. fuel-based emission factors), SIS can
have an unknown location (or even unknown existence). Emissions from SIS can be
spatiotemporally heterogeneous and profoundly affected by environmental factors, making them
difficult to detect, measure, and model. For example, detection of SIS becomes more challenging
with increasing distance from the source. Information on facility SIS emissions can be obtained
from systems operating on a variety of spatial and temporal scales. Information from multiple
systems can provide additional diagnostic value for SIS detection and assessment.2

2.3.2 Chloroprene Emissions-Denka Performance Elastomer Facility

As presented in Section 1.0, Denka owns and operates a neoprene manufacturing facility (the only
neoprene production facility in the U.S.) at the Pontchartrain Works Site in Laplace, Louisiana
(the "Facility"). The 2011 National Air Toxics Assessment (NATA) results indicated the highest
modeled cancer risks in the country were associated with an area in St. John the Baptist Parish,
Louisiana, attributable to chloroprene (a likely human carcinogen) emissions from Denka's
Facility. EPA Region 6 began monitoring the air at six locations in the surrounding community in
May 2016 (see Figure 2-2), conducted a CAA inspection of the Facility in June 2016, and
subsequently referred CAA violations to the DOJ for civil enforcement.

Pursuant to a January 2017 Louisiana Department of Environmental Quality (LDEQ)
Administrative Order on Consent ("State AOC"), Denka installed a Regenerative Thermal
Oxidizer (RTO) and other controls, designed to achieve an 85% reduction in Denka-reported
chloroprene emissions. While the RTO's operation has decreased ambient concentrations of
chloroprene in the community, ongoing monitoring results, presented in Table 2-3, indicate that
ambient chloroprene concentrations remain higher than 0.2 microgram per cubic meter (|ig/m3),
the inhalation exposure concentration associated with an estimated 100-in-l million lifetime
cancer risk (based on the current inhalation unit risk value from EPA's Integrated Risk Information
System). A 100-in-l million lifetime cancer risk is generally described as the upper limit of
acceptability for purposes of risk-based decisions at EPA. The post-RTO implementation
monitoring results in Table 2-3 are based on the analysis of 24-hour time integrated canister
samples with a method detection limit (MDL) of 0.0469 |ig/m3 by TO-15 GC/MS (reference
method). Table 2-4 represents monitoring results of pre-RTO implementation for comparison.

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2 EPA, 2018


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Table 2-3. Statistical Chloroprene Concentrations in LaPlace Post-RTO Implementation

Site

Average
Concentrations*
(Hg/m3)

Median
Concentrations*
(Hg/m3)

Minimum
Concentrations*
(Hg/m3)

Maximum
Concentrations*
(Hg/m3)

Sample
Count
(N)

Sample
count above
MDL
(N)

238 Chad Baker

2.27

0.433

0.0156

37.4

171

59

Acorn and Hwy
44

1.40

0.0234

0.0156

77.3

171

88

East St. John
High School

0.494

0.0812

0.0156

5.51

171

79

Fifth Ward
Elem. School

1.74

0.222

0.0156

52.8

170

61

Levee

2.35

0.386

0.0156

98.7

171

53

Ochsner
Hospital

1.27

0.0642

0.0156

41.0

171

79

* Calculated after replacing non-detects with one-half the detection limit and includes results available
starting March 2, 2018 through December 25, 2019. The monitoring data collected followed the national
Quality Assurance Project Plan (QAPP) developed by EPA/OAQPS.

Table 2-4. Statistical Chloroprene Concentrations in LaPlace Pre-RTO Implementation

Site

Average
Concentrations*
(Hg/m3)

Median
Concentrations*
(Hg/m3)

Minimum
Concentrations*
(Hg/m3)

Maximum
Concentrations*
(Hg/m3)

Sample
Count
(N)

Sample
count above
MDL

(N)

238 Chad Baker

8.39

1.98

0.0180

70.0

213

55

Acorn and Hwy 44

3.52

0.0725

0.0180

153

213

101

East St. John High
School

1.84

0.297

0.0180

39.5

213

79

Fifth Ward Elem.
School

6.86

1.34

0.0180

150

213

63

Levee

5.64

0.932

0.0180

147

213

54

Ochsner Hospital

3.38

0.161

0.0180

89.2

213

88

* Calculated after replacing non-detects with one-half the detection limit and includes results available
starting May 26, 2016 through March 1, 2018. The monitoring data collected followed the national Quality
Assurance Project Plan (QAPP) developed by EPA OAQPS.

EPA believes there are unaccounted emissions at the Facility, likely attributable to SIS. The use
of a continuous monitoring system is essential in identifying and characterizing the sources of
emissions that could be controlled. Figure 2-3 is a seasonal wind rose for February through March
2019 using data from a Louisiana Automated Surface Observing System (ASOS) about 16 statute
miles from the Denka Facility. This wind rose is representative of the time period for the Initial
Phase of monitoring. Figure 2-4 is a seasonal wind rose for April through July 2019 and is
representative of the period when the Sampling Phase will likely occur. Accordingly, the
meteorological data presented may not be completely representative of the meteorological
conditions encountered at the preferred monitoring sites but will provide a general understanding
of patterns of wind flow.

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Ea'st St vJohn\High School

rOchsneriHospitail

rAtiornTandlftwvZ44i

^^CraaraaKerj

DenkalRaSility]



I SPod Sampling Locations in LaPlace, LA \

1°

0.2

0.4

0.8



Figure 2-2. Location of the Facility with Respect to Monitoring Locations


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[MSY] NEW ORLEANS/MOISANT

Windrose Plot [All Year]

Period of Record: 01 Feb 201g - 31 Mar 2019

Calm values are < 2.0 mph
Arrows Indicate wind direction.

Generated: 22 Jan 2020

Summary
obs count: 1892
Missing: 29
Avg Speed: 8.6 mph

Wind Speed [mph]

i^B 2-5 ¦ 5-7 B 7-10 Hi 10 - 15 M 15 - 20 H 20+

Figure 2-3. Seasonal Wind Rose for February - March of 2019, for Louisiana ASOS at
MSY Airport (Iowa State University - Iowa Environmental Mesonet website).

[MSY] NEW ORLEANS/MOISANT
Windrose Plot [All Year]

Period of Record: 01 Apr 201jj - 01 Aug 2019

Calm values are < 2.0 mph
Arrows Indicate wind direction.

Generated: 22 Jan 2020

Summary
obs count: 3476
Missing: 100
Avg Speed: 8.3 mph

Wind Speed [mphl

M 2-5 M 5 - 7 H7-10 ¦ 10-15 M 15 - 20 n 20+

Figure 2-4. Seasonal Wind Rose for April - July of 2019, for Louisiana ASOS at MSY
Airport (Iowa State University - Iowa Environmental Mesonet website).


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The overall objectives for the SPod monitoring project are:

1)	To field verify the effectiveness of continuous monitoring using the non-speciated
VOC concentration SPod photoionization detector (PID) measurements to detect
elevated chloroprene concentrations coming from Facility process areas at six discreet
locations.

2)	To better understand the relationship between PID measured VOC concentrations and
chloroprene concentrations measured in 24-hour canister samples.

3)	To better understand the data processing necessary to make useful determinations from
these characteristics.

4)	To help identify unknown or under-characterized emissions sources and activities in
the Facility.

5)	To evaluate suitability of each sampling location for SIS detection and the impact of
proximity of sampling location to the emissions source.

2.4 Element A.6: Project/Task Description

Work for this project will be accomplished in phases. Information gathered from each phase will
inform the next phase. This QAPP was written for SPod Monitoring to detect SIS emissions in
conjunction with canister sampling to measure SIS emissions surrounding the Denka Facility. The
first phase will be the field demonstration using Sensit Technologies' SPod systems for continuous
monitoring and collecting canister samples. Once the monitoring systems are operating, the data
obtained from the SPod monitoring will be used in conjunction with data obtained from SPod
triggered canister sampling to identify potential emissions.

Proximity to source from sampling locations for SIS detection will be evaluated throughout
monitoring. If it is determined that certain sampling locations are not suitable, alternative sampling
locations may be identified. The QAPP will be updated if alternative sampling locations are
identified.

The effectiveness of an SPod-type sensor to detect SIS emissions is impacted by the proximity of
potential emission sources. In this project, the SPod sensors will be deployed at a variety of
distances around the Denka Facility, at the locations of the ambient air sampling sites. To employ
the SPod systems, a field demonstration will verify the effectiveness of the sensors at the identified
locations. The relative distances from each site to the Denka facility are displayed in Table 2-5.

In addition to the commencement of this monitoring project, EPA will seek additional detailed
operational and maintenance information from Denka to assist assessment.

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Table 2-5. Distances from SPod Monitoring Sites to Denka Facility in LaPlace, LA



Distance

Distance

Distance

Site

(m)

(km)

(miles)

238 Chad Baker

943.20

0.94

0.59

Acorn and Hwy 44

1375.78

1.38

0.85

East St. John High School

2529.70

2.53

1.57

Fifth Ward Elem. School

941.59

0.94

0.59

Levee

530.34

0.53

0.33

Ochsner Hospital

1832.73

1.83

1.14

The expected project schedule is presented in Table 2-6 and may be subject to change. As
planned, the project will take approximately nine to ten months to complete.

Table 2-6. Project Schedule

Phase

Expected Initiation

QA Testing

January-February 2020

Initial Phase of Monitoring

March-April 2020

Sampling Phase of Monitoring

May-September 2020

Note: sampling phase could be delayed if the canister sampling automatic trigger software method needs further
development.

2.5 Element A.7: Quality Objectives and Criteria

Overall measurement quality objectives (MQOs) for this project can be defined in terms of the
following data quality indicators:

•	Precision - a measure of mutual agreement between individual measurements
performed according to identical protocols and procedures. This is the random
component of error.

•	Accuracy - in terms of bias is the systematic or persistent distortion of a measurement
process that causes error in one direction. Bias is determined by estimating the
positive and negative deviation from the true value as a percentage of the true value.

•	Detectability - the determination of the low range critical value of a characteristic that
a method-specific procedure can reliably discern.

•	Completeness - a measure of the amount of valid data obtained from a measurement
system compared to the amount that was expected to be obtained under correct,
normal conditions.

•	Comparability - a measure of the level of confidence with which one data set can be
compared to another.

Due to some known limitations in the SPod sensor's capability/environmental factors, the SPod is
not expected to provide 100% data completeness; 70% is the anticipated completeness target.

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There is a potential for project MQOs to change based on data collected in the Initial Phase. A
summary of the overall MQOs for this project is presented in Table 2-7.

Table 2-7. Summary of Overall Project Measurement Quality Objectives

Parameter

Method

Accuracy

Precision

Completeness

Comments

SPodPID

Determination of
plume detects by
analysis of PID sensor
data

±25%

±25%

70%

Indicative technique
supporting plume
detection/location based
on PID measurements
greater than five times
the MDL.

Temperature,
pressure, and
relative
humidity
measured by
SPod sensor

Determination of
5-min period plume
detects by analysis of

sensor data and
reasonableness check
against NWS*

±10°c®,±4
kPa, ±20%

±10°c®,±4
kPa, ±20%

70%

Reduced completeness
reflects use of solar-
powered units

Wind speed by
SPod

Post analysis
reasonableness check
against NWS

±1 m/s

±1 m/s

80%

Reduced completeness
reflects use of solar-
powered units

Wind direction
by SPod

Post analysis
reasonableness check
against NWS

±10°

±10°

80%

Reduced completeness
reflects use of solar-
powered units

Canister VOC

TO-15

±25%

±25% for
detects > 5 x
MDL

80%



@10°C SPod inlet heaters may affect comparisons.

*National Weather Service (NWS)

TO-15 Quality objectives based on ERG's EPA-approved QAPP for support of EPA's National Monitoring Programs7

2.6 Element BA.8: Special Training/Certification

Training for some roles is necessary. EPA ORD provided hands-on SPod training to the EPA
contractor, ERG, during ORD QA testing of the SPod units. However, further training is needed
as follows:

•	ERG will train Weston to perform bump tests, troubleshoot the SPod systems,
download data from secure digital (SD) cards, arm the canister trigger collection
systems, recover the collected samples, and ship samples to ERG's lab upon
deployment (and document training in project notebook).

•	ERG will process SPod data. As a quality check on SPod data processing, a second
ERG person will be trained and will process a percentage of data files, as specified by
the EPA OECA Project Lead.

2.7 Element A.9 Documents and Records

Interim data products, notes, and QA information produced by individual groups will be organized
and stored by those groups as per their office standard procedures. The EPA OECA Project Lead
is responsible for collecting all data and associated notes from all individual groups. During the
project, at the end of each day that on-site tasks are performed, the SPod data files will be backed
up from Sensit database by ERG. Log sheets, forms, and QC information will be photo-copied or


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photographed, and two independent copies will be maintained. These data will be sent to ERG
upon return from the field.

Data generated by the Sensit SPod will be stored on an internal SD card. The Sensit SPod data will
simultaneously be transmitted via cellular network to a password protected Sensit server. This
server will only be accessible by the ERG Task Manager or an appointed ERG personnel. ERG
will access the password protected Sensit server to retrieve data daily at the beginning of each
sampling effort and no less than twice weekly as the effort continues.

ERG will compile and process data as discussed in section 5.0 and transmit the data to the EPA
OECA Project Lead. Data summaries will also be transmitted. Data will be sent from ERG to the
EPA OECA Project Lead via a password-protected ERG ftp server. Only appointed ERG staff and
the EPA OECA Project Lead will have access to the password protected ERG ftp server.

ERG will retain all files and records for a period of at least five years after the close of the project
and for an extended duration per EPA's request.

3.0	Data Generation and Acquisition

This section discusses how project staff will ensure that data collection methods appropriate for
the Denka SIS investigation are employed and documented.

3.1	Element B.l: Sampling Process Design

The goals of this project are multipurpose, impacting air quality, public health, and emission
measurement methods. The SPod system is implemented to determine whether continuous SPod
PID VOC/HAP measurements at six discreet locations will be effective in identifying SIS of
chloroprene emissions from the Facility, which are believed to be the source of chloroprene
emissions currently unaccounted for. The SPod system "detects" where the emissions are
originating by instantaneously correlating elevated concentrations with wind direction. By
deploying the SPods at the community monitoring sites surrounding the Facility, a potential
emission event detected by the SPod PID sensor may be corroborated with chloroprene data from
associated SPod canister sampling, as available. This allows potential confirmation that the SPod
system is detecting a chloroprene plume, since the SPod PID cannot differentiate between VOCs
and the canister samples are analyzed by EPA Method TO-15, an established and validated VOC
method. By using the SPod PID sensor technology to identify potential elevated VOC/HAP
concentrations, along with information obtained from associated SPod canister samples or the
EPA's current 24-hour canister sampling, the efficacy of utilizing SPod systems for measurement
and detection of plume containing VOC/HAP such as chloroprene can be determined for this
application.

The project involves installing six Sensit SPods. These units are equipped with PIDs and with
event-triggered evacuated canister systems. The SPods will be installed at the current community
sampling sites surrounding the Facility, with the intent to detect elevated concentrations of total
VOCs in the air, which may include chloroprene. The SPod PIDs can detect VOCs with ionization
energies of 10.6 eV or below. Following the pre-deployment QA testing, field testing near the
Denka Facility will include two phases:

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1.	The Initial phase consists of six SPods deployed separately at the six current community
sampling sites surrounding the Facility (see Figure 3-1 for overhead photograph of facility
operations) for approximately two months. The data gathered in this phase will be
processed and used to assess the sampling equipment performance (see Table 3-2 for
performance criteria) and develop a trigger concentration for canister samples and
averaging period for that concentration. A seventh SPod may be added as a collocate at
one of the sites.

2.	The Sampling phase consists of six SPods deployed at the six current community sampling
sites surrounding the Facility for at least four months. The purpose of this phase is to collect
data and determine if SIS can be measured. During this phase, the plan is to collect
continuous SPod data and collect event-triggered 24-hour canister samples at the
previously determined trigger concentration. The determined trigger concentration is
subject to change as more data become available. The entire project will be evaluated at
four months to determine if it should continue for a longer duration and how much more
sample collection time will be required. A seventh SPod may be added as a collocate at
one of the sites.

The first phase of the project attempts to answer the following questions:

•	Can the SPod network accurately characterize and identify VOC/chloroprene plumes
as demonstrated by acceptance criteria in Table 3-2?

•	Do the SPod data processing procedures need modification to better determine the
characteristics of SIS?

The second phase of the project attempts to answer the following question:

•	Can the SPod network identify SIS of chloroprene emissions from the Facility as
demonstrated by acceptance criteria in Table 3-2?

•	Can the SPod network identify and characterize spatial/temporal chloroprene
concentrations and chloroprene emission sources at the Facility?

During this project, even data that do not meet acceptance criteria provide information that is useful
to the project. As the Sensit SPods are an emerging technology, data processing procedures may
need to be adapted from the procedures described in Section 4.7 of EPA's MOP 3010.

The SPods will be installed at each of the six current community sampling sites, shown in
Figure 3-1:

•	Ochsner Hospital (30.071420°, -90.515436°)

•	Acorn and Hwy 44 (30.058785°, -90.509599°)

•	Mississippi River Levee (30.051803°, -90.522571°)

•	5th Ward Elementary School (30.051938°, -90.531859°)

•	238 Chad Baker (30.057070°, -90.533381°)

•	East St. John High School (30.077830°, -90.532944°)

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Ea'st St XJohn'High .School,

[Qch'snerihlospitall

FAcornTanalnwv£44]

F238IEh'5a|Bak'er.

DenkalliaEilitYl

j5t!j^^^^lEJerner^ry^achoo|B^[v|iSgiggiggif^i?gfygg?gg^

| SPod Sampling Locations in LaPlace, LA (

10

0.2

0.4



08



Figure 3-1. Aerial image of planned SPod deployment around Facility

Weston Solutions field personnel will visit each site, once every six days. During the site visits the
sampling equipment will be checked, canister samples will be recovered or deployed, periodic
bump tests will be performed, and SD card data will be downloaded.

A seventh EPA ORD Sensit SPod will collocated at one of the locations as determined by EPA's
OECA Project Lead. This unit can also serve as a spare that could be used as a replacement of one
of the primary six SPod units.

The procedures for the SPod preparation, initial evaluation, deployment, and use are described in
MOP 3010 (Appendix B). Any changes made to SPod set-up will be recorded on a SPod Field
Deployment Form from Section 7 of MOP 3010. A copy of all forms completed on-site will be
sent to the ERG Task Manager.


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3.2 Element B.2: Sampling Methods

3.2.1	SPod Measurement Approach

3.2.1.1	General SPod Descripti on

The SPod is a low cost, solar-powered system that combines wind field and air pollutant
concentration measurements to detect emission plumes and help locate the source of emissions.
The Sensit SPods will be configured to collect 24-hour integrated air samples when a localized
high concentration is measured by the SPod. The SPod sensor technology is used along with the
established and validated canister method, to identify potential elevated chloroprene
concentrations. Figure 3-2 shows a Sensit SPod system without the canister trigger. The SPods are
equipped with sensors including PID sensors that provide a time-resolved indicator of VOC
compounds (estimated, nonspeciated) present in the air.

Figure 3-2. Sensit SPod system

A subset of air pollutants can be ionized by the Sensit SPod's 10.6 eV PID, an Ion Science Mini PID
2. The PID detection sensitivity ranges from less than 0.001 ppm to > 40 ppm and responds to
mixtures of VOCs usually present in fugitive plumes. When observed from a fixed single point
location, the plume from a proximate emission source produces a time-dependent concentration
signal that can be distinguished from the baseline through data analysis. If needed, the raw PID
data can be processed using a custom software program, such as "R". Figure 3-3 shows an example
of EPA SPod data from two co-deployed units near a refinery fence line, the red and black traces,
with (a) showing raw signal, and (b) showing signal after data analysis. A zoomed in view of (b)
shows peak events around 8:00 pm.3

3 EPA, 2018


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% ^ ^ % %
Time (hr:min AM/PM)

re
C
Q0
In

"O

o

Q_

IS)

to
+-<
c

=3
O

u

7d
c
op
on

"O

o

Q_

on

7d
c

2000
1800
1600
1400
1200
1000
800
600
400
200
0



After

Baseline

Removal

*<&/>, *<&/>, *<&/>, *<&/>, *<&/>, *<&/>,
"4, % % % % % % % % % % "i

Time (hr:min AM/PM)

Figure 3-3. Example of (a) raw and (b) processed SPod data4

The SPods will be set up by the EPA contractor, ERG, to run continuously. A data logging system
containing a micro SD card will be used, and wireless capability to connect the SPods for remote
data retrieval will be used during the project.

The SPod sensors will be mounted on a pole system so the sensors stand at approximately 2 m
above ground level. Further details for SPod setup, including pole or tripod, orientation,
connections, and syncing, are presented in Section 4.6.3 of MOP 3010. It is critical to select an
area with an unimpeded wind flow. ERG will orient the tripod so that the side of the anemometer
marked with a notch is facing toward the north as accurately as possible. Ideally a GPS should be
used to orient towards true north. ERG will note if a compass is used so the magnetic declination
can be accounted for in data processing. If using tripods, ERG will make fine adjustments to the
tripod legs (or other fixture) to achieve a level setup. ERG will verify using a bubble level placed
on the tripod top (not the sonic anemometer).

The SPods will be solar powered (a fully charged Sensit SPod can operate for three to five days
without sun). For solar powered deployments, the SPod should be oriented so that the solar panel
is facing south (this should be verified using a compass, GPS, or smart phone) in an area free of
shade for 8 hours daily.

3.2.2 Initial Phase

In the Initial phase sampling, SPods will be deployed at the six current community sampling sites.
The field contractor will visit each monitoring location site every six days initially for a potential
of up to four triggered canister samples per site every six days (see Section 3.2.4 for further
discussion of the triggered canister sampling). The data collected in the initial phase will allow
potential plume measurements to be compared between the SPods and the associated triggered
canister samples. A seventh SPod unit will be a spare that can be used to replace one of the SPods,
if one should need to be taken out of service.

4 EPA, 2018


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During the two-month Initial phase, the triggered 24-hour canister samples will be analyzed as
follows:

•	For the first two weeks, when an SPod detects a plume (i.e. a predetermined
concentration level has been exceeded), the automatically triggered canister sample
will be analyzed for fifty-nine VOCs by EPA Method TO-15 (including chloroprene).
Table 3-1 lists the compounds and ERG's current MDLs.

•	Thereafter, when an SPod detects a plume (i.e. a predetermined concentration level has
been exceeded), the automatically triggered canister sample will be analyzed for
chloroprene only. Other key VOCs may be analyzed for on a case-by-case basis, if it is
determined by the Project Lead to aid with detection of SIS.

•	When no plume is detected by the SPod no canister sample will be collected or
analyzed.

During the Initial phase, the following will be accomplished:

•	Determine a trigger concentration at each monitoring location site and averaging period
for the concentration.

•	Assess the sampling equipment performance for determining chloroprene plumes.

•	Update the SPod data processing/analysis method, if needed, to aid characterization.
The current data analysis method is described in section 4.7 of EPA's MOP 3010.

•	Demonstrate the automated canister sampling trigger and remote trigger adjustment
capabilities are functioning correctly. As such, the initial canister sampling trigger level
will be based on initial monitoring PID monitoring data, at a level a canister sample
would be expected to be triggered during the first week of deployment. The initial level
will be above the average baseline fluctuation and but within a low enough threshold it
should be triggered easily. After the initial collection at each monitoring location, each
trigger level will be adjusted higher to try and only capture plume events. Trigger levels
will be assessed throughout the project, including during the initial phase.

3.2.3	Sampling Phase

For the Sampling phase, the SPods will continue to be deployed at the six current community
sampling sites to collect continuous data for at least four months. The basic purpose of the
Sampling phase is to collect continuous SPod data, to collect event triggered canister samples, and
to determine if SIS can be detected.

3.2.4	Triggered Sampling with Evacuated Canisters

While the Sensit SPod PID sensor will provide a total VOC concentration, canister sampling will
provide the additional information of what species of VOCs contribute to the concentration
measured on the PID sensor.

Each SPod is equipped with a system that can collect 24-hour integrated gas samples in evacuated
canisters using an automated canister trigger system. When a concentration measurement by the
SPod exceeds a set threshold average concentration the trigger will be activated and a 24-hour
integrated canister sample will be collected. The automated canister trigger system can
accommodate up to four canisters at a time to allow multiple triggered events. The trigger values

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will be set during deployment by ERG and will be re-assessed by ERG and the EPA OEC A Proj ect
Lead throughout the project.

The Sensit SPod manual, found in Appendix E, states that the sample time can be set for 1-3600
seconds. The SPods used for this monitoring effort have been modified by Sensit to include a
latching valve and a program that will allow for collections between 0 and 86400 seconds.

The flowrate into the canister triggers will be controlled by Entech CS1200E Flow Controllers.
Each Entech flow controller has an internal calibrated flow orifice that allows enough air to pass
through to fill up a six-liter Summa canister over a 24-hour period. The canister triggers utilized
for this effort have been modified for four independent 24-hour samples to be collected.

3.2.5 Continuous Meteorology Measurements

The Sensit SPods for this project are fitted with an anemometer (Airmar WX-110 with humidity
option) to measure wind speed, wind direction, and temperature. The SPod also has a sensor to
measure pressure, temperature, and relative humidity. The SPod meteorological data are collected
simultaneously with the SPod PID data.

3.3 Element B.3: Sample Handling and Custody

3.3.1 Canister Preparation

Canisters, in batches of 12, will be cleaned in ERG's laboratory by heated cleaning systems using
three cycles of evacuation and pressurization with humidified ultra-pure nitrogen. Following
canister cleaning, one of the batches 12 canisters will be analyzed by gas chromatography/mass
spectrometry (GC/MS) using EPA Method TO-15 for target VOCs. The acceptance criterion for
the cleaned canister analysis is presented in Table 3-4.

Following the acceptance of the clean canister batch and prior to shipment to the site, the batch of
canisters will be evacuated to a vacuum of 50 millitorr. Prior to shipment each canister will be
tagged for field personnel to add field sample identification (ID) and then packaged with an
associated chain-of-custody (COC). An example COC is presented in Figure 3-4. The analytical
laboratory will ship prepared canisters in batches of twelve canisters and anticipates shipping at a
frequency of 12 canisters every 14 days during this project. ERG will ship the clean evacuated
canisters to:

David Bordelon
Weston Solutions, Inc.

13702 Coursey Blvd., Bldg 7
Baton Rouge, LA 70817
(225) 297-5403

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ERG Lab ID #

iOi Kzysone Part Drvr, Suae 7D0, UarsWlE, NC 275GO

AIR TOXICS SAMPLE CHAIN OF CUSTODY

f

is.

35
*

Site Cade:
City/State:
AQS Code:

Canister Number

Collection Date: 	

Optorrs:

SNMOC (Y/N):
TOXtCS (Y/N):
METHANE (Y/N):
Relinquished by:

Lab Initial Can. Press. ("Hg):

Cleaning Batch #: 	

Date Can. Cleaned:	

Duplicate Event (Y/N):
Duplicate Can #:

T3 OL

* s

Received by:

Operator 	

System #: 	

Setup Date:	

MFC Setting:

Field Initial Can. Press.:

Elapsed Timer Reset {Y/N):
Canister Valve Opened (Y/N): _
psig psia "Hg (Circle one)

Recovery Date:
Operator: 	

Sample Duration (3 or 24 hr): _
Elapsed Time: 	

Fteid Final Can. Press.: 	

Status: VALID VOID
Relinquished by:	

psig psia "Hg (Circle one)

(Circle one}	Canister Valve Closed {Y/N):

Date:

Received by:

Date:

Lab Final Can. Press.: 	

Status: VALID VOID
If vaki, why:	

	psig "Hg (Circle one) Converted to psia:	

(Code one)	Gauge: 1 2	{Circle one)

Sa™tesfitoredmAHbxl^(RMn^3W

sail

Comments;	

White: Sample Traveler	Canary: Lab Copy	Pint Field Copy

Figure 3-4. Evacuated Canister COC Form

3.3.2 Canister Setup

The Weston Solutions field personnel will visit the site once every six days during the project.
During the site visits the sampling equipment will be checked, canisters from triggered sampling
events will be retrieved, and new evacuated canisters attached to the automatic trigger device. Each
canister will be attached to the trigger device by inserting the canister's male Micro-QT™ fitting
into the female Micro-QT™ fitting attached to the trigger device.

Once the cleaned evacuated canister has been connected to the SPod canister trigger, Weston will
determine the initial canister vacuum (if initial vacuum is < 25 inches mercury ("Hg), the canister
has leaked and must not be used) and record the following information on the associated COC:


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•	Initial canister vacuum,

•	Canister ID,

•	SPod ID,

•	Any pertinent notes,

•	Whether the canisters valve has been opened,

•	The received date,

•	The setup date,

•	And the location where the sample was acquired.

The Weston Solutions field personnel will write the sample ID information specific to each
canister on the canister tag when taking canister samples. This information will also be recorded
on the COC documentation. The sample ID codes are as follows:

D-BB-MMDDYY
Where:

D = The fixed study site designation for this project (Denka = D)

BB = Sampling location (01, 02, etc.) link to field notes with GPS locations

MMDDYY = month, day, and year of grab sample acquisition

The canister trigger system will have equipment necessary to obtain a 24-hour canister sample
with an approximate final pressure of 5"Hg vacuum. The field QC checks are presented in Table
3-3.

3.3.3 Canister Sample Recovery and Shipping

When collecting triggered canister samples, Weston will record on the COC form:

•	Each final canister pressure;

•	Any notes related to the sample (potential interfering sources, local climatic
conditions, odors, observations), including if more evacuated canisters are
connected in preparation for the next triggered canister sampling events;

•	The operator's name;

•	The recovery date; and

•	And whether the canister valve has been closed.

After sampling, Weston will ship the canister samples to ERG's analytical laboratory with
associated COCs within two weeks of sample collection. The total hold time for canister samples
is 30 days from collection. Failure to ship canister samples to the laboratory within two weeks
could cause the samples to be invalidated due to missed hold time.

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If a canister sample is being collected at the time of the site visit, Weston staff will leave this
canister attached to the SPod so it can finish sampling. Weston staff will recovery any other
canister samples that collected and set up the next set of canister samples. The sample that is left
to collect will be recovered on the following site visit trip six days later. Weston staff will ship the
sampled canisters to:

ERG

601 Keystone Park Drive
Suite 700

Morrisville, NC 27560

3.4 Element B.4: Analytical Methods

3.4.1 Analysis of Canister Samples

After sampling, the canister samples will be shipped to ERG's laboratory for analysis by EPA
Method TO-15, the Technical Assistance Document for the National Air Toxics Trends Stations
(NATTS) Program, Revision 35, and ERG's EPA-approved QAPP for support of EPA's National
Monitoring Programs6. These documents provide guidance on analytical procedures for the
measurement of VOCs in ambient air. Initially, the analysis will be for a suite of VOCs including
chloroprene. As the study goes on, chloroprene will be the only analysis target compound.

The canister samples will be received at ERG's laboratory. ERG will pressure-check the canisters
and fill out the COC forms. ERG will analyze the canister samples within the 30-day hold time
provided the sample are shipped to ERG in a timely manner. ERG's Task Manager will inform
EPA OECA Project Lead if canister samples do not arrive within the 30-day hold time.

The canister samples will be analyzed using an Entech autosampler/Agilent GC/MS system in
Selected-Ion Monitoring (SIM) mode following ERG's laboratory's standard operating procedure
for EPA Method TO-15. The acceptance criteria for this analysis is presented in Table 3-4. The
analytical laboratory will deliver the canister sample data in Excel and pdf form.

If canister sample results are greater than 10 percent of the highest calibration point of the curve
used to calibrate the GC/MS used for analysis, the canisters will be diluted with air and reanalyzed.

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Table 3-1. ERG's Laboratory VOC MDL - Compendium Method TO-15

Target Compounds

ppbv

Hg/m3

Target Compounds

ppbv

Hg/m3

1,1,1 -Trichloroethane

0.0149

0.0815

Dibromochloromethane

0.0124

0.106

1,1,2,2-Tetrachloroethane

0.0165

0.114

Dichlorodilluoromethane

0.0371

0.184

1,1,2-Trichloroethane

0.0114

0.0623

Dichlorotetralluoroethane

0.0103

0.0722

1,1 -Dichloroethane

0.00728

0.0295

Ethyl Aery late

0.0145

0.0595

1,1 -Dichloroethene

0.0124

0.0493

Ethyl ferf-Butyl Ether

0.00742

0.0311

1,2,4-Trichlorobenzene

0.141

1.05

Ethylbenzene

0.0178

0.0775

1,2,4-Trimethy lbenzene

0.0330

0.163

Ethylene Oxide

0.0614

0.267

1,2-Dibromoethane

0.0132

0.102

Hexachloro-1,3-Butadiene

0.0727

0.777

1,2-Dichloroethane

0.00857

0.0348

w/,p-Xylene

0.0325

0.141

1,2-Dichloropropane

0.0111

0.0514

w;-Dichlorobenzene

0.0236

0.142

1,3,5-Trimethy lbenzene

0.0114

0.0562

Methyl Isobutyl Ketone

0.0102

0.0419

1,3-Butadiene

0.0110

0.0244

Methyl Methacrylate

0.0750

0.308

Acetonitrile

0.0746

0.126

Methyl ferf-Butyl Ether

0.0198

0.0715

Acetylene

0.110

0.117

Methylene Chloride

0.0512

0.178

Acrolein

0.144

0.331

w-Octane

0.0233

0.109

Acrylonitrile

0.0219

0.0476

o-Dichlorobenzene

0.0278

0.167

Benzene

0.00987

0.0316

o-Xylene

0.0225

0.0979

Bromochloromethane

0.0102

0.0541

p-Dichlorobenzene

0.0242

0.146

Bromodichloromethane

0.0111

0.0745

Propylene

0.141

0.243

Bromoform

0.0140

0.145

Styrene

0.0151

0.0645

Bromomethane

0.00994

0.0387

tert-Amyl Methyl Ether

0.0101

0.0423

Carbon Disulfide

0.0415

0.129

T etrachloroethy lene

0.0144

0.0979

Carbon Tetrachloride

0.0109

0.0687

Toluene

0.0182

0.0687

Chlorobenzene

0.0102

0.0471

trans-1,2-Dichloroethy lene

0.0116

0.0461

Chloroethane

0.0161

0.0426

trans-1,3 -Dichloropropene

0.0138

0.0571

Chloroform

0.00829

0.0406

Trichloroethylene

0.0123

0.0662

Chloromethane

0.0344

0.0712

Trichlorofluoromethane

0.0166

0.0935

Chloroprene

0.0222

0.0805

Trichlorotrifluoroethane

0.00982

0.147

cis-1,2-Dichloroethylene

0.0336

0.0777

Vinyl Chloride

0.0102

0.0250

cis-1,3-Dichloropropene

0.00994

0.0374







3.5 Element B.5: Quality Control

3.5.1 Continuous SPod PID Measurements QC Checks

In this study, SPods provide general information on concentration and direction of plumes. The
quality assurance/quality control (QA/QC) procedures for the SPod are described in MOP 3010 in
Appendix B and summarized in Table 3-2. Corrective action for data with unacceptable QA/QC
will be determined by ERG and the EPA OECA Project Lead.

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Total VOC measurements from the PID are known to be affected by atmospheric conditions.
Although a bump test will prove the PID is working and responding to gas properly, the PID is
also affected by rapidly changing conditions causing a "false detect". To properly identify a "false
detect" ERG will analyze temperature, humidity and pressure data during the time of spikes over
40 ppb, and all occurrences of a canister trigger that is analyzed over 5 pg/m3. ERG will flag this
data or verify that the data are valid.

To assess how data compare across methodologies and between SPods, relative percent difference
(RPD) and coefficient of variations (COVs) will be calculated based on Equations 1 and 2 below,
as defined in 40 CFR, Part 58, Appendix A, Section 4.2.1. Precision will be assessed between a
triggered canister sample and the associated PID measurement.

Equation 1	d{ - ————— ¦ 10Q|

(Xi+YO/2	1

where:

d< = the relative percent difference (%) for sample i
X,=the result from the primary sampler for sample i
}) = the result from the collocated sampler for sample i

Equation 2	COV =	L_

^	V	2n(n—1)

where:

di = the relative percent difference (%) for sample i

n - the number of valid data pairs being aggregated

X2g.i«-i = the 104 percentile of a chi-squared distribution with n-1 degrees of
freedom

For each triggered canister sample, an RPD between chloroprene, or other determined VOC in
sample, and the measured PID concentration will be calculated using Equation 1. A dilution factor
may have to be established based on the duration of the measured SPod reading to compare to the
24-hour integrated sample. Measured concentrations between canister measurements and the SPod
concentrations should match up within 50% RPD.

Measured concentrations from any collocated sets of Sensit SPods will be compared to establish a
COV. Initially, bump tests and concentrations measured on both systems above 40 ppb will be
considered. Concentrations from collocated measurement analysis should be within 40% COV. If
data do not fall within 40% COV an "estimate" or E flag will be assigned to the data from the last
collocated measurement that passes until the next collocated measurement that passes.

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As the Sensit SPods are an emerging technology and do not conform to a pre-established EPA
method, QA criteria will be reevaluated throughout the monitoring effort.


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Table 3-2. Summary of Field SPOD QA/QC Procedures

Parameter

Acceptance Criteria

Method Procedure / Corrective Action

Frequency

Verify proper
SPod set up

Completion of SPod
Field Deployment
Form, items 1-20

Execute MOP 3010 Section 4.6 / If during
installation test, specific sensors are found
to be non-operational, consult with field
lead on corrective actions

Once at installation, then
monthly during study

Periodic SPod
PID check (bump
tests)

Positive deflection of
baseline with each of 3
bump tests; agreement
in amplitude of baseline
deflection within
+25%*; completion of
SPod Field Deployment
Form or ERG generated
form

Execute MOP 3010 Section 4.6.3.7 / If
during check specific sensors are found to
be non-operational, consult with field lead
on corrective actions

Once at installation, monthly
during study, and at end of
study

Data Screen

Completion of SPod
Data Analysis Review
Form, items 1-11 (or
digital equivalent)

Execute MOP 3010 Section 4.6/No
corrective action is required

Daily (or other frequency
specified by project lead) for
days data is acquired

Wind

Measurement
Check

Reasonableness (±40%)
compared to
independent values

Perform reasonableness check by
comparing acquired data between SPods
and NWS / if found problematic, exclude
data or flag as an estimated measurement

10% review once per month

Method

Comparison

Check

Reasonableness of PID
data compared to
associated canister
sample values (±50%#)

Perform reasonableness check by
comparing elevated PID data to associated
canister samples, if applicable / if found
problematic, check for larger changes in
wind direction or RH, and PID drop out.

As available

Data Co-location
Check

Reasonableness of PID
data compared to any
co-located SPod values
(±40%COV)

Co-located:

Perform reasonableness check by
comparing SPod ppb PID data between
any collocated SPods.

During data processing perform
reasonableness check by:

•	Comparing Bump Test results
between paired SPods,

•	Comparing measured
concentrations where both paired
units measure concentrations
above 40ppb, or a later defined
value.

If values do not compare reasonably a
second comparison will be considered
using the raw mV readings between the
paired SPods. The next bump test or
another point of comparison will also be
considered to declare data back within
reason. All data from the point of the
failing comparison to the next passing
comparison will be flagged as an estimate.

As available per bump test or
weekly paired measurement
comparison. Only for
collocated SPods.

PID Check

Reasonableness
compared to other SPod
values (±50% COV)

Perform reasonableness check by
comparing calculated PID results (ppb)
across all Sensit SPod systems under
certain "calm" overnight atmospheric
conditions. This would help ensure the
PIDs are not being individually affected by
temperature or humidity.

Once per month


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Parameter

Acceptance Criteria

Method Procedure / Corrective Action

Frequency

Heater Check

Reasonableness check
that Sensit SPod PID
heater is controlling
temperature.

Determined during Pre-deployment testing
by assessing heater output in data.

Pre-Deployment or when heater
control is in question due to
data observation.

Can Trigger
Check

(Pre-

Deployment)

Leak check: <1.0" Hg
in 48 hrs

Verify system trigger
command works

Perform leak check on trigger system for
48 hours, and send manual trigger to verify
operation of system

Once before deployment

Can Trigger
Leak Check
(Deployed)

Leak check: <1.0" Hg
in 1 minute

Perform leak check on trigger system for 1
minute.

At each canister deployment in
the field.

Can Trigger
"False Trigger"

Assessment to ensure
canister trigger is
functioning
appropriately

Site operators would need to manually
trigger a canister collection at the site to
ensure the canister trigger is functioning
and can collect a canister sample.

In the event that the data file
denotes the SPod triggered a
canister collection but the
canister did not actually collect.
Only necessary on incident

*	25% from average of 3 SPod measurements; rolling average if baseline drift at site becomes an issue.

#	Difference between two methods; SPod PID concentrations will be determined based on the response of the most recent bump

test.

3.5.2	Continuous SPod Meteorological Measurements

The systems incorporate ultrasonic anemometers to measure wind speed, a sensor to measure
relative humidity, and a sensor to measure ambient temperature. Measurements will be made at a
height of approximately 2 meters above grade (to approximate breathing height without ground
level interferences). Post-analysis reasonableness checks will be performed against meteorological
data from the other SPods and/or NWS. The QC procedures for the anemometer are described in
Table 3-2.

3.5.3	Canister Sample QC Check

Table 3-3 summarizes the in-field QA/QC checks for canister sampling.

Table 3-3. Summary of Field Canister Sample QA/QC Procedures

Parameter

Acceptance Criteria

Method Procedure / Corrective Action

Frequency

Initial Canister
Vacuum

Between 25 and 29.9"
Hg vacuum

Read gauge and record initial vacuum on
COC, circle Valid or Void based on
vacuum criteria / select another canister if
Void and return Void canister with COC to
Lab

Immediately prior to canister
use for samples and upon
connecting to SPod for
triggered canister samples

Final Canister
Vacuum

Vacuum 8 ± 5" Hg

Read gauge and record final vacuum on
COC, circle Valid or Void based on
vacuum criteria and return canister (Valid
or Void) with COC to Lab

After a triggered canister
sampling event

Ship Sampled
Canister to Lab

Within 2 weeks of
sampling

Longer than 2 weeks reduces Lab hold
time (total hold time 30 days from sample
collection)

NA

NA - Not applicable

Table 3-4 summarizes the analytical QA/QC activities for canister sample analysis.

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Table 3-4. Summary of Analytical Laboratory Method TO-15 QA/QC Procedures

Parameter

Acceptance Criteria

Corrective Action

Frequency

Bromofluorobenzene
(BFB) Instrument Time
Performance Check

Evaluation criteria presented
in the lab SOP

Retune; clean ion source
and/or quadrupole

Daily prior to sample analysis

Initial calibration (ICAL)
consisting at least 5
points

1)	%relative standard
deviation (RSD) of response
factors < ±30% (with two
exceptions of up to ±40%)

2)	internal standard (IS)
response ±40% of mean curve
IS response

3)	relative retention time
(RRTs) for target peaks ±0.06
units from mean RRT

4)IS	retention time (RTs)
within 20 seconds of mean

Repeat individual sample
analysis; repeat ICAL;
prepare new calibration
standards and repeat
analysis

Following any major change,
repair or maintenance or if daily
QC is not acceptable.

Recalibration not to exceed three
months.

Second source initial
calibration verification
(ICV)

The response factor < ±30%
deviation from calibration
curve average response factor

Repeat ICV; repeat ICAL

Following the calibration curve

Continuing calibration
verification (CCV)

The response factor < ±30%
deviation from calibration
curve average response factor

Repeat CCV; repeat
ICAL

Before sample analysis on the days
of sample analysis

Method Blank (MB)

Targets <3x minimum
detection limit (MDL) or 0.2
ppbV, whichever is lower and
IS area response ±40% and IS
RT ±0.33 mill, of most recent
ICAL

Repeat analysis; repeat
analysis with new blank
canister; check system
for leaks, contamination

Daily following BFB and
calibration check; prior to sample
analysis

Replicate Analysis

<25% relative percent
difference (RPD) for
compounds greater than 5 x
MDL

Flag data

One per analytical sequence

Canister Cleaning
Certification

Targets <3x MDL or 0.2
ppbV, whichever is lower

Reclean canisters and
reanalyze

One canister analyzed on the Air
Toxics system per batch of 12

Preconcentrator Leak
Check

<0.2 pounds per square inch
(psi) change/min

Retighten and reperform
leak check; perform
maintenance; re-perform
leak check

Each standard and sample canister
connected to the
preconcentrator/autosampler

Retention Time (RT)

RT within ±0.06 RRT units
of most recent initial
calibration average RT

Repeat analysis

All qualitatively identified
compounds

Samples - Internal
Standards (IS)

IS area response within ±40%
and IS RT within ±0.33 mill,
of most recent ICAL average
IS response

Repeat analysis

All samples

Canister Sample Hold
Time

30 days from collection

Qualify samples over
total hold time of 30 days
from sample collection

NA

NA not applicable; TO-15 QA/QC procedures based on ERG's EPA-approved QAPP for support of EPA's National Monitoring
Programs7

7 ERG, 2019


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3.6 Element B.6: Instrument/Equipment Testing, Inspection, and Maintenance

3.6.1	Pre-deployment Isobutylene Testing

This study utilizes a commercially available SPod unit developed by Sensit Technologies. Once
procured and delivered to ERG's Morrisville, NC laboratory the seven units will be thoroughly
tested prior to deployment. This pre-deployment assessment will include the following:

•	Set up of seven SPods

•	Verify the operation of all sensors

•	Verify the solar panels and batteries for the SPods

•	Establish the baseline for the SPods over several days

•	Verify heated inlet operation

•	Verify each individual SPod's response to isobutylene gas standard bump tests

•	Verify each individual SPod's response to chloroprene gas standard bump tests

•	Assess logging in, downloading data, processing data, and remotely setting canister
triggers and thresholds

•	Leak check and test all SPod canister trigger systems to ensure all functions are
working properly

•	Test and analyze the canister trigger systems with nitrogen to identify potential bias
or contamination in the can systems components

The isobutylene cylinder needed for the PID bump test must be 0.5 to 2.0 ppm ± 5%. If using a
larger cylinder, a rotameter must be in line to regulate flow to 0.5 liters per minute (1pm). A vendor
and part number for the isobutylene cylinder and regulator are in the project equipment list located
in Appendix A. ERG will retain a copy of gas standard certification of analysis documentation for
the project file.

3.6.2	Pre-deployment Isobutylene and Chloroprene Bump Tests by ERG

Isobutylene and chloroprene bump tests will be performed by ERG prior to deploying the Sensit
SPods. The chloroprene bump test will follow the isobutylene bump test. Example certificates of
analysis for the two gas standards used are in Appendix D. The pre-deployment bump tests are
necessary to establish that each SPod is functional, to identify the response of each SPod PID to
both isobutylene and chloroprene, and to determine if there is a general relationship between the
response to each gas. The pre-deployment bump testing results will be compared to the Ion Science
published response factor for chloroprene (1.3).

3.6.3	SPod Operational Tests

Once the micro SD card is installed and power cable is attached, the SPod will begin acquiring
continuous data. ERG will perform and document the following operational tests at ERG's
Morrisville, NC laboratory prior to deployment and both after installation on-site in LaPlace, LA
and prior to take-down of the equipment on-site in LaPlace, LA:

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1.	SPod sensors are operational - PID on/off button is blinking, pressure, temperature,
RH, sonic anemometer data are recording to the SIM card and comparable to local
conditions.

2.	Data are being transmitted to the Sensit server via cellular connection (see list of
applicable data in Section 3.12).

3.	Canister trigger test - a threshold close to baseline will be set to initialize a 24-hour
canister collection within the first day of operation. This collection will verify the
canister trigger is working properly and provide a potential background or non-event
related canister sample.

Testing of PID response with an isobutylene bump test will be conducted by Weston Solutions
monthly to verify operation of each SPod. The bump test produces a quick spike in concentration
on the PID sensor, similar to an encountered plume, without changing the sensor's ambient state.
The bump test is described in detail in Section 4.6.3.7 of MOP 3010.

The SPod pressure, temperature, relative humidity, sonic anemometer sensors will be assessed by
cross comparing the SPod measurements with each other and with any available local
meteorological data. The wind direction and wind speed measurements will be checked by
comparing the measurements across all SPods and/or comparing to data obtained from the National
Weather Station (NWS). For additional information on the sensors used in the SPod, refer to the
Senist SPod Operational Manual found in Appendix E.

3.6.4 Interferences

Potential interferences may result in loss of operation of all or part of the SPod system. This loss
of operation (loss of data) may be temporary or permanent in nature. Possible interferences
include:

•	Physical interference, such as heavy rain or dew (condensation) may negatively
impact the PID sensor causing the SPod to enter a temporary nonoperational state.

•	Physical obstructions, such as accumulated dirt or insects may impact the inlet to the
sensors, and therefore operation.

•	Loss of power as may occur if the solar panel experiences many cloudy days.

•	Component malfunctions or operational issues with the SPod sensors or
communications systems. If a sensor ceases to operate or begins to operate in an
unstable fashion a physical fault is likely.

•	Analytical interference, such as PID baseline drifts may occur due to atmospheric
effects (particularly humidity changes) and real ambient air shed VOC concentration
trends. These signals (either real or artefactual) compete with the detection of
potential of near-field emissions plumes. Typically, the near-field emission plumes
have a different temporal character than interferences allowing mathematical
decoupling of the signals.

In the case of the analytical interference of the PID measurements, the signals can be examined as
discussed in Section 3.12.1.


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3.6.5 SPod Routine Quality Checks

Bump tests will serve as quality checks for the SPod PIDs. Weston will conduct in-field bump
tests on each SPod unit at monthly intervals and at the end of the deployment. ERG will perform
the pre-deployment bump tests on all the SPods.

Weston will perform canister leak checks and monthly bump tests, taking three isobutylene
measurements for each SPod. The bump test produces a quick spike in concentration on the PID
sensor, similar to an encountered plume, without changing the sensor's ambient state. Data from
these bump checks will be recorded in the field notebooks and on the SPod Field Deployment
Form (as shown in the SPod MOP in Appendix B or equivalent). The bump test is described in
detail in Section 4.6.3.7 of MOP 3010. Bump tests will last for 30 seconds in duration for each
measurement. The acceptance criteria for these tests are presented in Table 3-2.

At the end of the deployment, Weston will perform bump tests, taking nine isobutylene
measurements for each SPod (three measurements in triplicate performed over a 3-day period
totaling nine measurements). Data from these bump checks will be recorded in the field notebooks
and on the SPod Field Deployment Form (as shown in the SPod MOP in Appendix B).

The temperature, relative humidity, pressure, wind direction, and wind speed measurements of the
SPods are non-critical data. This will be documented and checked for reasonableness once a month
by comparing to the SPod measurements and/or the NWS. The acceptance criteria for these tests
are presented in Table 3-2.

3.7	Maintenance and Troubleshooting

If the PID bump tests indicate sensor malfunctions, Weston will communicate the issues to the
ERG Task Manager. If tests or repairs can be handled on-site, Weston will be given instructions
on repairs. PID data graphs can provide significant information on the PID operations. A large
variation in baseline, such as prolonged elevated spikes, below average readings or large diurnal
swings may require investigation.

During the field investigation, the only on-site maintenance possible to the SPod is a PID sensor
replacement. Any other maintenance must be handled by ERG or Sensit Technologies. If possible,
a supply of spare PID sensors, will be maintained during the project.

3.8	Equipment Retrieval

The following operational tests will be performed and documented after sampling prior to take-
down of the equipment by Weston:

1.	SPod sensors are operational - PID on/off button is blinking, pressure, temperature,
RH, sonic anemometer data are recording to the SIM card and comparable to local
conditions.

2.	Data are being transmitted to the Sensit server via cellular connection.

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3.9	Element B.7: Instrument/Equipment Calibration and Frequency

ERG's GC/MS instalments are calibrated with National Institute of Standards and Technology
(NIST)-traceable TO-15 standards minimally every 3 months and use internal standards to monitor
instrument performance. The TO-15 calibration gas stock cylinders are recertified annually by the
vendor. The initial calibration is verified daily with a second source continuing calibration
standard. The acceptance criteria for the GC/MS calibration is presented in Table 3-4.

3.10	Element B.8: Inspection/Acceptance of Supplies and Consumables

The ERG Task Manager is responsible for ensuring all materials meet project requirements
according to ERG's standard procurement procedures for project-related supplies and
consumables. This process includes inspection and acceptance criteria and procedures for tracking,
storage, and receiving supplies.

3.11	Element B.9: Non-direct Measurements

Secondary or supporting data will be gathered by the project team and used to inform aspects of
the SPod monitoring program. Examples of relevant supporting data include information on
Denka's operations and maintenance, Denka's monthly ambient air monitoring reports, and EPA's
off-site meteorological monitoring results.

3.12	Element B.10: Data Management

Data management for the canister samples will follow ERG's EPA-approved QAPP for support of
EPA's National Monitoring Programs8. This document provides guidance on analytical procedures
for the measurement of VOCs in ambient air.

SPod data are logged to a micro SD card located on the data logger board. These data are also
transmitted via cellular network to a password-protected server owned by Sensit. Only appointed
personnel will be able to access the server stored data. Data files will be downloaded by ERG
personnel via remote connection every day (or other frequency established by the project lead).
Appendix C presents the Standard Operating Procedure for SPod data retrieval. Figure 3-5 shows
the flow path of SPod project data.

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Sensit
Spod

• Cellular

r i

Sensit
Server

L A





¦

• Password-protected
FTP data interface

ERG

Password-protected
FTP data interface

Figure 3-5. Flow diagram for Sensit SPod data retrieval

ERG will inspect recovered data. The SPod Data Analysis Review Form or digital equivalent will
be completed by ERG during data review. The form is located in Section 7 of MOP 3010.

The data feed from each Sensit SPod node consists of:

•	Date/time stamp (MM/DD/YY HH:MM:SS - 24H),

•	Non-speciated VOC indicator by PID (ppb),

•	Non-speciated VOC indicator by PID (mV counts),

•	Temperature (°C),

•	Relative Humidity (%),

•	Pressure (mBar),

•	Wind Speed (mph),

•	Wind Direction (Degrees),

•	Sensor Temperature (Arb Units),

•	Sensor Heater Output (Arb Units),

•	Battery Voltage (Volts),

•	Charging Current (mA),

•	Operating Current (mA),


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•	Trigger Flag (0 or 1 if threshold exceeded),

•	Trigger Counter (Adjustable),

•	Sample Flag (0 or 1 if sample acquired),

•	GPS Latitude (Degrees), and

•	GPS Longitude (Degrees).

3.12.1 SPod Data Processing

To ensure data quality and to remove unacceptable data caused by physical and analytical
interferences of the SPod PID, ERG will follow the procedures listed in Section 5.0 of this QAPP,
which are based on Section 4.7 of MOP 3010. ERG will summarize and assess the SPod data.

Baseline removal algorithms will separate plume events from background changes and sensor drift.
The Sensit SPods output a ppb value that has removed the baseline internally. The Sensit SPods
use an exponential moving average that is determined by the output data rate. The SPod software
does not modify the baseline itself. The raw mV is filtered as well, and the Sensit SPod calculates
the ppb concentration based on the zero offset and the span for isobutylene.

ERG will use the "calculated" ppb value for all data processing techniques and may not have a
need for baseline removal. If the "calculated" value is in question, ERG will attempt to use the raw
mV output and use the baseline removal algorithm to compare to the SPod internal algorithm
output.

The following steps, discussed in greater detail in Section 5.0, will be used for SPod data analysis:

•	SPod data visual inspection and thresholding to protect against "off scale" conditions
where events are missed due to having the threshold set too high.

•	SPod data visual inspection to investigate rapid relative humidity swings to ensure
any measured events are not due to rapid climate changes which can affect the PID
sensors.

•	SPod data visual inspection to identify anomalous data drop-out conditions.

•	Use of concentration wind rose plots to understand source direction.

•	Review of 5-minute averaged PID data summary files for each SPod performed daily.

•	Review of all daily data (one full 24-hour period from 00:00 to 24:00) including met
sensors from each SPod, performed at least once per week.

Due to the calculations performed by the Sensit's SPod data processing algorithm, ERG will
likely not need to make use of baseline removal algorithms to separate plume events from
background changes and sensor drift (if SPod is fluctuating). This step discussed in MOP 3010
will most likely not be necessary. ERG will perform a visual check of the daily data to verify
there is no baseline drift due to sensor drift.

After the data are downloaded and sent to ERG, ERG will use "R" (or other equivalent software)
to evaluate baseline shift for each daily period of data and conduct monthly QA data
reasonableness checks. ERG will conduct monthly analyses using the PID and meteorological

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data to evaluate the location of the sources when any time integrated 24-hour sample's
chloroprene concentration exceeds 5 [j,g/m3. The processed SPod data will be delivered to the
EPA OECA Project Lead.

4.0	Assessment and Oversight

4.1	Element C.l: Assessments and Response Actions

Assessment of the canister sample data will follow ERG's EPA-approved QAPP for support of
EPA's National Monitoring Programs.9 This document provides guidance on analytical procedures
for the measurement of VOCs in ambient air.

Although this project uses continuous monitoring technology, it also relies on data retrieval on a
predetermined schedule. Communication is key to ensuring ongoing operation of the monitoring
and quality data. Project decisions, such as trigger level, may have to be made quickly in order to
ensure collection of the best data. Any pertinent information and/or potential issue will be brought
to the attention of the EPA OECA Project Lead immediately.

4.2	Element C.2: Reports to Management

ERG will prepare daily summary reports for SPod data for the EPA OECA Project Lead. ERG
will prepare weekly data summaries to compare data elements other than the PID data. The weekly
reports will also include any QA efforts conducted according to this QAPP.

ERG will report canister sample data, along with applicable MDLs, as available.

Any quality deficiencies detected by technical reviewers or QA Manager will be communicated to
the EPA OECA Project Lead. The EPA OECA Project Lead and ERG's Task Manager will then
determine the appropriate corrective action to be taken.

5.0	Data Validation and Usability

5.1	Elements D.l: Data Review, Verification, and Validation and D.2: Verification and
Validation Methods

5.1.1 SPod Data Compilation and Reduction

Data reduction procedures for this SPod monitoring project are discussed in MOP 3010. Data
reduction activities will be conducted during the study to:

1)	verify that the data have met the criteria in Table 3-2, and

2)	compare the results of techniques yielding repeat measurements, in order to verify the
observed sources.

These comparisons will help determine whether SPod systems can accurately characterize and
identify VOC/HAP emissions. These comparisons will be performed by ERG after compilation

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and delivery of the preliminary data to the EPA OECA Project Lead. Table 5-1 describes the
planned post-study data comparisons.

Table 5-1. Summary of Post-Study Data Comparisons

Measurement

Comparison

Comments

SPod:

VOC conc. (PID
output)

Comparisons of averages for plume detects with co-
deployed canister measurements

Indicative technique supporting
plume detection/location

Comparisons of downwind and upwind averages

Indicative technique supporting
plume detection/location

SPod:
temperature,
pressure,
relative humidity

Comparison with meteorological (MET) data from
NWS

Indicative technique supporting
plume detection/location

Wind speed by SPod

Comparison with secondary MET data (other SPods
and/orNWS)

Comparisons in open area
during stationary operation

Wind direction by
SPod

Comparison with secondary MET data (other SPods
and/orNWS)

Comparisons in open area
during stationary operation

GPS

Post-study comparisons to Google Earth
location/stationary precision test

Infield reasonableness check to
cell phone; GPS also performed

5.1.2	Canister Results

The data reduction procedures for canister data are specified in the analytical laboratory's standard
operating procedure for EPA Method TO-15. The ERG Task Manager will deliver the interim and
final canister sample data to the EPA OECA Project Lead, with supporting raw data.

5.1.3	Data Validation, Validation Methods and Verification

All persons participating in this project will adhere to the procedural requirements of the QAPP
including criteria to accept, reject, or qualify project data. Proper sample collection technique will
be verified by the surveillance audits as detailed in Table 5-2. In-process data validation includes
reviews of data reduction and storage activities to ensure that utilized procedures are being
followed and modified or adjusted, if required.

In addition, the datasets for the SPod systems will be compared to established and validated data
source (e.g., 24-hour canister sample data and meteorological data); ERG will perform this
comparison at least once a month during the field study, as data become available, with a goal of
checking at least one value for each comparable parameter.

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Table 5-2. Summary of Data Validation and Auditing

Type of Audit

Frequency

Details

Surveillance of field SPod and canister
sampling

Conducted during first two days of
sampling

Performed by ERG

Surveillance audit of laboratory
analyses

Conducted prior to analysis of samples

Performed by EPA under the National
Monitoring Program and the National
Environmental Laboratory Accreditation
Program (Appendix F)

Audit of lab data quality

Conducted prior to the analysis of
samples

Performed by ERG for EPA under the
National Monitoring Program

Audit of data reduction (SPod, canister,
MET data)

10% check of PID, canister, and
meteorological data at least once per
phase, for available parameters

Performed by Brad Venner, EPA NEIC

The canister sample data will be verified and validated by ERG using the procedures in ERG's
EPA-approved QAPP for support of EPA's National Monitoring Programs10. This document
provides guidance on analytical procedures for the measurement of VOCs in ambient air.

The audit of lab data quality for VOCs will be assessed by ERG analyzing independently generated
audit samples via Method TO-15. ERG manages and operates the National Monitoring Programs
for EPA; one of these programs is the NATTS Program. As part of the Technical Assistance
Document for this program, ERG regularly performs analyses to determine the presence and
concentration of multiple VOCs from ambient air samples. VOC analyses for these proficiency
samples are performed in the same laboratory, by the same staff, using the same instrumentation,
and following the same procedures as applied to the NATTS Program

ERG's most recent Method TO-15 audit occurred in March 2019. The audit included comparing
the percent difference between ERG's laboratory reported values for each VOC and the mean of
participating laboratories. A percent difference within ±25% of the relative target values is deemed
as acceptable. As shown in Error! Reference source not found.5-3, based on the results of this
audit, VOC measurement accuracy ranged from -18 percent difference for acrolein to 23.8 percent
difference for carbon tetrachloride. Not all VOC species are present in the audit sample, but they
are chosen to be representative of all VOC species currently analyzed for under the NATTS
program.

If another audit sample is analyzed by ERG during the duration of the project, results will be given
to EPA OECA Project Lead as a continued demonstration of proficiency.

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Table 5-3. VOC Compound Performance Evaluation Audit Data

Analyte

Reported Value

Mean of Participating
NATTS Laboratories

(ppbv)

(Mg/
cartridge)

RPD

1,1,2,2 -T etrachloroethane

0.191

0.175

9.1%

1,2 -Dibromomethane

0.632

0.545

16.0%

1,2 -Dichloroethane

0.494

0.454

8.8%

1,2 -Dichloropropane

0.543

0.485

12.0%

1,3-Butadiene

0.567

0.555

2.2%

1,3-Dichloropropene-cis

0.692

0.560

23.6%

1,3 -Dichloropropene- trails

0.595

0.489

21.7%

Acrolein

0.310

0.378

-18.0%

Benzene

0.597

0.504

18.5%

Carbon Tetrachloride

0.234

0.189

23.8%

Chloroform

0.545

0.490

11.2%

Dichlorometliane

0.356

0.339

5.0%

T etrachloroetliy lene

0.496

0.437

13.5%

Trichloroetliylene

0.463

0.427

8.4%

Vinyl Chloride

0.409

0.395

3.5%

5.2 Element D.3: Reconciliation with User Requirements

The ERG Work Assignment Manager will work with the EPA OECA Project Lead to determine
if data generated for this project are of known and documented quality and if they are fit for their
intended use. ERG will document data limitations in the summary reports for the project. The ERG
Task Manager will convey data quality issues to EPA OECA Project Lead.

6.0 References

EPA, 1999 Compendium Method TO-15 A, Compendium of Methods for the Determination of
Toxic Organic Compounds in Ambient Air, Second Edition; Determination of
Volatile Organic Compounds (VOCs) in Air Collected in Specially-Prepared
Canisters and Analyzed by Gas Chromatography/ Mass Spectrometry (GC/MS).
EPA/625/R-96/010b, https://www3.epa.gov/ttnamtil/files/ambient/airtox/to-
15r.pdf (accessed February 23, 2017).

EPA, 2016 Battelle/OAQPS Technical Assistance Document for the National Air Toxics

Trends Stations Program, C304-06 Revision Number: 3, October 2016. Available
at:

https://www3.epa.gov/ttnamtil/files/ambient/airtox/NATTS%20TAD%20Revisio
n%203 FINAL%20Qctober%202016.pdf. (accessed January 6, 2020).

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EPA, 2018 ORD/NRMRL/AEMD/DSBB NRMRL Quality Assurance Project Plan,

Rubbertown Next Generation Emission Measurement Demonstration Project QA
Category: B / Measurement Extramural Research G-AEMD-XXXXXX-QP-1-0
Revision Number: 0, February 2018.

EPA, 2018a ORD/NRMRL/AEMD/ECPB NRMRL Quality Assurance Project Plan, Region 6
Next Generation Emission Measurement Demonstration Project: VET and MPod
QA Category: B / Measurement Extramural Research G-AEMD-XXXXXX-QP-1-
0 Revision Number: 0, February 2018.

EPA, 2018b "Draft Design Package for U.S. EPA Beta Version SPod Fenceline Sensor",
Version January 2018.

EPA, 2019 EPA ORD NRMRL MOP 3010, EPA Prototype SPod Procedures (MOP 3010),
Revision 2.0, August 01, 2019.

ERG, 2019 ERG Support for the EPA National Monitoring Programs (UATMP, NATTS,
C SAT AM, PAMS, and NMOC Support) QA Category 1/ ERG-QAPP-0344-5,
EP-D-14-30, Revision 0, March 2019.


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Appendix A: Equipment List

Equipment List for SPod Monitoring









Number

Equipment

Description

Supplier

Part Number

Required

SPods



w/can trigger, has a
Ion Science







SPods

MiniPID2 PID sensor

Sensit

NA

6



w/can trigger, has a
Baseline Mocon®









PID Sensor or an Ion









Science Mini PID2







SPod

HS PID Sensor

Sensit

NA

1

Canister sampling

1 with each Sensit







triggers (also listed
above with SPods)

SPod,

Sensit

NA

7

Pole attachments for

ERG will







can trigger systems

manufacture

ERG

NA

6







MP3SHLHSC



PID sensors (spares)

lppb-40ppm, 10.6 eV

Sensit

U2

6

SPod shipping









containers (if









needed)



ERG

NA

6

Tripod for SPods (if
needed)

survey tripods

Grainger

1MM34

7

Attachment adaptors

manufactured by







for tripods

Sensit Technologies

Sensit

NA

7

Solar panel and
battery



Sensit

NA

7

Tools

Bubble level



Grainger

1UK57

1

Compass



ERG

NA

1

GPS



Grainger

464V19

1

Teflon tape



Grainger

4X227

1



open end 9/16"









wrench/needle-nosed









pliers/screwdriver, 4"







Miscellaneous tools

shank and 1/4" flat
head tip/6" adjustable
wrench

Grainger

4RPD3/4YU73
/53JR99/483J2
9

1/1/1/2

Isobutylene Bump Test

Isobutylene gas
standard

103 liter, 0.5 ppm

Grainger

103L-248-0.5

3

Regulator

C-10, 0.5 Lpm

Grainger

33V728

1

PID bump test

manufactured by







sensor cap

EPAORD

EPAORD

NA

1

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Number

Equipment

Description

Supplier

Part Number

Required

Canisters







01-29-









MC14LSV,



Canisters

6-liter, SUMMA,

Entech

MQT-ST400S

40



30-0 " Hg vacuum







Canister gauges

pressure gauge with
Micro-QT® fitting

Entech

01-29-
70010QT

2



Calibrated 24- hour







Flow regulator

integrated canister
flow orifice

Entech

01-39-
CS1200ES4

6

Micro-QT® Female









Fittings (for can
analysis)

Micro-QT® to 1/4"
Swagelok fitting

Entech

FQT-400S

14

SS tubing

SS, 1/8"

ERG

na

na

Equipment Used for SPod Testing at ERG

Equipment

Description

Supplier

Part Number

Number
Required

Isobutylene Bump Test

Isobutylene gas
standard, 0.5ppm

103 liter, 0.5 ppm

Grainger

20ME50
(103L-248-0.5)

1

Regulator for
isobutylene

C-10, 0.5 Lpm

Grainger

33V728

1

PID bump test
sensor cap

manufactured by
EPAORD

EPAORD

NA

1

Chloroprene Bump Test

Chloroprene gas
standard, 0.5ppm

98 liter, 0.5 ppm

Linde Gas

custom

1

Regulator for
chloroprene

CGA 180

Linde Gas

NA

1

PID bump test
sensor cap

manufactured by
EPAORD

EPAORD

NA

1

Rotameter



ERG

NA

1

Canisters

Micro-QT®) Female
Fittings

Micro-QT® to 1/4"
Swagelok fitting

Entech

FQT-400S

4

Canisters

6 liter SUMMA, true
seal valve, Micro-
QT®

EPAORD

NA

2


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Appendix B: MOP 3010

MOP #3010
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MISCELLANEOUS OPERATING PROCEDURE NO 3010

TITLE: EPA Prototype SPod Procedures

PURPOSE: This miscellaneous operating procedure (MOP) describes the setup, operation,
quality control (QC) procedures, and basic data analysis for the EPA prototype SPod Fenceline
Sensor with and without a Base Station (BS) communication package.

1 SCOPE

This MOP describes:

•	The physical set up and operation of the prototype SPod sensor package.

•	Installation and ongoing QC checks
Installation of SPod can trigger system

•	Basic data analysis procedures.

This MOP does not describe the operation of support equipment, such as generators, transport
trailers, meteorological stations, or distance measurement devices. The target audience for this
MOP is field personnel utilizing this technology.

Basic SPod Description: The EPA Sensor Pod (SPod) is a low-cost sensor system that combines
wind field and air pollutant concentration measurements to detect emission plumes and help
locate the source of emissions in facilities. The SPod uses a combination of custom parts and
commercially available components, such as air sensors, minicomputers, and communication
cards. The SPod has the capability to operate using solar power if required. The SPod package
contains a photoionization detector (PIL)) sensor that produces a non-speciated, uncalibrated
concentration measure of a subset of volatile organic compounds (VOCs) and hazardous air
pollutants (HAPs) that can be ionized with a 10.6 eV P1D, as well as sensors for measuring
temperature (temp), relative humidity (RH), and pressure (press). In the current configuration,
the effective PID detection sensitivity ranges from approximately 0.01 ppm to approximately 2
ppm under best operating conditions. Other components of the package include a sonic
anemometer, photovoltaic power source, onboard operating and data logging system containing a
secure digital (SD) flash memory card and wireless capability used to connect to aBS computer
used remote logging of one or more SPods and for cell phone modem remote communication.
Additional information on the design and use of the prototype SPod can be found in "Draft
Design Package for U.S. EPA Beta Version SPod Fenceline Sensor", version January 20181 and
"South Philadelphia Passive Sampler and Sensor Study"2.

The SPod is designed to detect emissions plumes. The current SPod design works only in "near-
fenceline" applications where localized emission plumes may be present. The unit is not useful
for ambient applications large distances away from sources. Since the SPod is not intrinsically
safe, it cannot be used in potentially explosive environments. Figures 1 and 2 show SPod
major components and configuration variants that use different sonic anemometers with a
description of common terms used in the MOP contained in Table 1.

Printed copies of this document are uncontrolled. All users are responsible for confirming version
status against the electronic version in the document control system.


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. 3-0 Sonic
Anemometer

Communications
*- Antenna

^ SUMMA Canister
Signal Connection

__ Sensor
Housing

Mounting

Pole/Base

Solar

Panel/Bateries

PID Sensor
| / Screen

_ Power Supply
Connection/Cord

Figure 1: Example of a 3-D sonic SPod fenceline sensor

Figure 2: 2D sonic anemometer SPod (left), 3D sonic anemometer (right)

Printed copies of this document are uncontrolled. All users are responsible for confirming version
status against the electronic version in the document control system.


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2 DEFINITIONS

Definitions and acronyms are listed in Table for terms used in this MOP that are non-standard.

Table I: Common terms used in this MOP listed in alphabetical order

Term

Definition

2D Sonic

Two-dimensional sonic anemometer SPod variant. 2D sonic measures

horizontal wind speed components



Three-dimensional sonic anemometer SPod variant. 3D sonic measures both

3D Sonic

horizontal and vertical wind speed components and provides future potential
for advanced inverse modeling.

BS

Base station, an optional communication module for an SPod network

BNC

A common type of coaxial cable used in the SPod for power connection from

the solar panel/battery

BT

Bump test, a quick in-field test that verifies the operation of the SPod PID
and sets a timing mark

cts

Counts produces by the SPod PID and RH, a unitless measure of signal level

De«C

Unit of temperature, degrees Celsius

DQI

Data quality indicator (DQI), a test or data check that helps in understanding
the operational state of the SPod

eV

Electron volt

GPS

Global Positioning System

HAP

Hazardous air pollutant

MOP

Miscellaneous Operating Procedure

Node

A single SPod location

Network

More than one SPod working in concert

PID

Photoionizalion detector, the sensor in the SPod that detects hydrocarbons

PPb

Part per billion by volume, a unit of measure of concentration, mixing ratio
units per billion units

ppm

Part per million by volume, a unit of measure of concentration, mixing ratio
in units per million units

Press

Atmospheric pressure measured by SPod sensor in units of mbar

PAC

Secure digital flash memory card for storage of SPod data

RH

Relative humidity measured by SPod sensor in arbitrary units counts (cts)

SD

Secure data card for storing SPod data

SPod

Sensor Pod, a low cost fenceline sensor system

Temp

Temperature of the air measured by a SPod sensor or conic anemometer in
degC

VOC

Volatile organic compound

3 ROLES AND RESPONSIBILITIES

The personnel roles and responsibilities of SPod field deployments are typically described in the
project specific quality assurance project plan (QAPP) and are therefore not described here.

Printed copies of this document are uncontrolled. All users are responsible for confirming version
status against the electronic version in the document control system.

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4 PROCEDURES

This section describes the procedures for an SPod system. Since the current version of the
prototype SPod does not produce laboratory samples, some sections of the MOP template are not
applicable.

4.1	Sample Preservation, Containers, Handling, and Storage

The SPod itself does not produce a laboratory sample. If the SPod can trigger system is deployed
along with the SPod, the operating procedures described in MOP 3090; Canister Field Grab
Sampling using 1.4 L canisters should be used. Ambient air grab samples will be collected
using 1.4 L Entech Silonite® coated stainless steel canisters. Cleaned, field ready canisters are
stored in the EPA VOC laboratory in room E-288 at the EPA-RTP facility. Before field
deployment, canisters are cleaned according to SOP ECAB-133.0 "Standard Operating
Procedure for Cleaning Air Sampling Canisters with the Entech 3100A Canister Cleaner" (US
EPA, 2011). Canisters are evacuated to a final pressure of 10 milliTorr(30 inhg) and shipped
within 48 hrs after cleaning in a carrying case to the field along with the chain of custody (COC)
forms. Canisters must be shipped back to EPA within 2 weeks of being received in the field.

Hold times in the laboratory upon return from field deployment is 2 weeks, within which time
samples must be analyzed. Hold times may change depending on requirements stated in project-
specific QAPP.

4.2	Health and Safety Precautions

The general health and safety precautions for field measurement activities are described in
separate health and safety plans and are not detailed in this MOP. The primary safety hazard
associated with SPod-deployment and use is the physical handling of heavy gas cylinders that
may be used on the EPA test range and the installation of SPod mounting poles and fixtures at
the deployment location. Proper safety precautions and safety equipment must be used for
handling and/or installation functions along with "dig safe" procedures and proper site
permitting. These safety and site permission functions should be covered in the project-specific
safety plan related to the deployment. In general, care must be taken to secure equipment, so it
does not produce a falling or tipping hazards under high wind or potentially interfere with
unrelated site equipment or operations. Caution must also be used when deploying near
roadways due to vehicle hazards and care must be taken to minimize or eliminate the possibility
of creating driver distraction hazards while selecting the deployment site. General precaution
with use of electrical equipment or in the field or installations near power lines must be followed
and all necessary site safety checks must be performed, and permissions acquired. Typically,
SPod P1D operation is checked with low concentrations (500 ppb) of isobutylene, but if other
gases are used, care must be taken with potentially hazardous aspects of these gases and details
should be described in project-specify safety plans.

4.3	Interferences

There are two types of method interferences for the current version of the prototype EPA SPod:
physical and analytical.

Physical interference refers to external conditions or component malfunctions that may
negatively affect SPod operation. Heavy rain or dew (condensation) may negatively impact the
PID sensor causing the SPod to enter into a temporary nonoperational state. Physical
obstructions, such as accumulated dirt or insects may impact the inlet to the sensors, and
therefore operation. Physical interference could also be loss of power as may occur if the solar

Printed copies of this document are uncontrolled. All users are responsible for confirming version
status against the electronic version in the document control system.


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panel is blocked by snow or experiences many cloudy days. Physical interferences additionally
include component malfunctions or operational issues with the SPod sensors or commutations
systems. If a sensor ceases to operate or begins to operate in an unstable fashion a physical fault
is likely. For the purposes of this MOP, physical interferences may result in loss of operation of
all or part of the SPod system. This loss operation (loss of data) may be temporary or permeant
in nature. In addition to the physical interferences affecting PID performance, the performance
of the SPod 3-D sonic may also be impacted by the presence of physical interferences (trees,
telephone poles, etc) in vicinity of the 3-D sonic anemometer. The 3D sonic (or any other sonic
anemometer used as part of the SPod sensor system) must be oriented correctly to ensure data
validity.

Analytical interferences refer to the issues that prevent the SPod from performing its design
function (detecting emission plumes), when no physical interferences are present. The most
notable analytical interference is associated with PID operational capability. Under normal
operation, the SPod PID produces an uncalibrated indicator of time-resolved plume
concentrations. In the current low-cost SPod design, there is no attempt to condition the inlet air
seen by the PID or other parameters. As a consequence, the baseline levels of the SPod PID may
drift by large amounts due to atmospheric effects (particularly RII changes) and also by real
ambient air shed VOC concentration trends. These signals (either real or artefactual) compete
with the detection of potential of near-field emissions plumes and represent analytical
interferences. Typically, the near-field emission plumes have a different temporal character than
these interferences allowing mathematical decoupling of the signals (Section 4.7).

4.4	Reagents and Supplies

This section of the MOP template section does not apply to the current version of the SPod.

4.5	Equipment/Apparatus

SPod installation requires the following primary equipment and supporting apparatus. For long-
term deployments, more robust mounting fixtures may be required.

•	One or more SPods fitted with 4-16 gigabyte SD data cards

•	Solar panel and battery for installations without electrical land power

•	A low voltage SPod power supply for installations with electrical land power

•	A base station (BS) - optional

¦ If BS is used, SPod logging software (VET v2.2) — available from EPA ORD
NRMRL, (thoma.eben@epa.gov)

•	If BS is used, Team Viewer™ (www.teamviewer.com) or equivalent remote
communication software

•	Tripod for mounting SPods for shorter term installations or other fixtures, such as
installed poles for longer term deployments

•	Safety equipment (as per safety plan)

•	Compass

•	GPS

•	Camera

•	Flathead screwdriver

•	Teflon Tape

•	Bubble level

•	If SPod can trigger system is deployed, the following components are required:

Current canister system design described in Prototype SPod Design Package

Printed copies of this document are uncontrolled. All users are responsible for confirming version
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-	Vt" Pipe clamp, adjustable wrench and flathead/Ph i I lips screwdriver.

¦ Equipment for PID Function Test

-	0.5 ppm +/- 5% Isobutylene tank, 58L (or other), with Regulator CGA C10/CGA
590 (or as specified)

-	PID Bump Test sensor cap

Rotameter, set at 0.5 1pm. (Or on-demand regulator set at 0.5 1pm)

-	Approximately 5 feet of 'A "Teflon tubing.

1' of .25" ID flexible tubing. (For on-demand regulator)

!4" Swagelok nut, ferrule, and union, (all should be attached to PID Bump Test
sensor cap and tubing)

V" Swagelok toggle valve (If not using on-demand regulator)

-	Two small adjustable wrenches

4.6 Procedures

The following procedure describes a basic SPod setup and operation for a version that uses a
solar panel/battery and tripod. Longer term deployments may employ permanent fixtures instead
of a tripod and may use land power instead of a solar-powered configuration, but the procedures
are the same except where noted. Some deployments may utilize a BS to allow remote
communication via cell modem our internet connection in addition to standard SPod data
recording on the SD card (described in Section 4.6.3.6).

4.6.1	SPod Deployment Location and Documentation

When choosing the deployment location for the SPod, it is critical to select an area with an
unimpeded wind flow. This is important to ensure that efficient transport of potential emission
plumes from the source to the sensor station and to collect wind data that is an accurate
representation of the site conditions. The SPod should be deployed in a location with relatively
flat terrain and away from local obstructions (e.g. trees, buildings, hills). If the monitoring
station must be near a potential obstruction, ensure that the station is located at a horizontal
distance that is two times the height of the obstruction if you are upwind, and six times the height
of the obstruction downwind. This will help ensure an accurate display of the sites wind
conditions. For solar powered deployments, the SPod should be oriented so that the solar panel is
facing south (this should be verified using a compass, GPS, or smart phone), and the area should
be free of shade for 8 hours.

• Complete data fields (1) through (8) of SPod Field Deployment
Form in Section 7

4.6.2	SPod SD data card install and check-

Prior to deploying the system, verify a 4 Gigabyte SD is installed in the drive located on the
microcontroller board (Figure 3). The microcontroller board (Figure 3 right) will be mounted
inside the sensor housing prior to deployment, and the SD card drive is accessed via a slot on the
underside of the sensor housing, as shown in (Figure 3 left). The SD card drive is spring-loaded.
After inserting the card into the drive, press the card until the drive clicks to secure the card
(install check).

Printed copies of this document are uncontrolled. All users are responsible for confirming version
status against the electronic version in the document control system.


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• Complete data fields (9) and (10) under SPod Field Deployment Form in
Section 7

Figure 3. Location of SD card drive on bottom of SPod and (left) and internal view (right)
4.6.3 SPod & Base Station Setup

4.6.3.1: Set up the tripod as shown in Figure 1 and adjust legs as necessary. Take the 'A""
threaded mounting pole and ensure each end is properly wrapped with Teflon tape to avoid
damaging the threads. Screw one end into the tripod as shown in in Figure 4 (left). Line-up the

hole on the bottom of the SPod housing, with the mounting pole on the base as shown in
Figure 4 (right). Look in the hole to be sure there are no wires in the path of the pole, and then
gently hand thread until tight.

Figure 4. SPod mounting example

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4.6.3.2: Without loosening the SPod from its mount, pick up the tripod and reorient (rotate) so
that the side of the anemometer marked "N" is facing toward the north as accurately as possible.
Ideally a GPS should be used to orient towards true north. If a compass is used, this must be
indicated in the deployment notes so the magnetic declination can be accounted for in data
processing. Make fine adjustments to the tripod legs (or other fixture) to achieve a level setup.
Verify using bubble level placed on the tripod top (not the sonic anemometer). A resource for
determining magnetic declination can be found at

https://ngdc.noaa.gov/geomag/declination.shtml (last accessed 3/9/2018). When deploying
multiple units' side-by-side verify that the anemometers all appear to be pointing the same
direction. When pole mounting the SPod tighten the SPod down on the %" pole, and then adjust
the pole with a pipe wrench to turn the SPOD orientation to north.

4.6.3.3: Deploy the solar panel/battery (if used) near the SPod as shown in Figure 1. Orient the
solar panel so that it is facing south. Before final setup, turn solar panel/battery on its side and
connect one end of the BNC power cable to the port located on the underside of the panel (Figure
5). Note that if the deployment does not use a solar panel but instead uses land power, connect
the BNC cable to the 12V supply used for the deployment.

Figure 5. Connecting BNC power cable to solar panel / battery

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4.6.3.4: Connect the other end of the BNC power cable to the sensor station port, located on the
underside of the sensor housing, as shown in Figure 6. At this point the SPod should be
automatically acquiring data and storing it to the SD card. The confirmation of operation is
discussed in Section 4.6.3.5 and tested in Section 4.6.3.7.

Figure 6. Connecting BNC Power Cable to Sensor Station

4.6.3.5: After the BNC power cable has been connected to the SPod power port, the sensor
station should have power and be operating. Confirm power is supplied to the unit by verifying
that an amber light is illuminated on the inside of the SPod housing. This should be visible by
looking inside the sensor housing from a vantage point below the station, as shown in Figure 7.
This provides first level confirmation of operation with further assurance provided in the
operation test described in Section 4.6.3.7.

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Figure 7. Illuminated lights confirming SPod is operating

4.6.3.6: (if applicable): An SPod deployment may include a BS which is a secondary computer
that communicates with one or more SPod nodes via short range wireless network and with the
outside world via a cell phone modem or internet connection. The BS uses a custom data
acquisition program [VET v2.2] written in LabVIEW (National Instruments, Inc. Austin, TX) to
sequentially acquire data from one or more SPod systems (max of 3). The BS is fitted with a cell
phone modem or direct internet connection allowing the data to be retrieved from offsite. Data
are still recorded on the SPod SD cards. The BS computer system can come in many forms
ranging from a rack mount computer, laptop installed in a monitoring shelter or a dedicated field
computer in a weather-proof box. Figure 8 shows examples of a three-unit SPod network with a
BS. In all cases, the BS requires land power (120vac). The installation and operation of the BS
will be deployment-specific but involves the following key steps (1) Build and configuration of
BS with proper software and wireless and remote communication systems, (2) Pre-deployment
confirmation of connection and data logging capability for the specific SPods to be deployed. (3)
Proper field installation and powering within wireless range of SPod nodes, (4) auto boot-up and
startup of logging software, (5) Verification of robust operation in the field before leaving the
site. Basic installation and operation of the VET v2.2 data logging and remote communication
software is described in Sections 4.6.3.6.1 to 4.6.3.6.6. Please see Section 4.6.3.7 for SPod
operational testing sequence.

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Figure 8: Three SPods (left). Close-up view of BS (right).

The VET v2.2 BS software for logging SPod data is based in a LabVlEW 2010 or later
environment (it is an executable file). The version of software currently used will function as
follows:

•	The BS will send a request to each SPod for a data line and wait for its response.

•	Data will be collected for all the SPods approximately once each second (sequentially).

•	The Options Page allows the user to:

o input/modify/delete expected SPod Addresses,
o Setup data transfer to EPA VTPER server,
o Add reading from an Auto-GC
o Route data to a specific folder on the hard drive

•	The 'Environ' Settings allows the user to send data to EnviroSuite

•	The SPod settings allows the user to change internal SPod settings (non base-station)

The following steps describe the process for setting up the BS software to record and visualize
the data.

4.6.3.6.1: Open the VET v2.2.0 BS program, click on Options and Input SPod addresses. Then
select the sonic type associated with that SPod configuration. (Figure 9).

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Figure 9: Options menu for initial SPod communication setup
4.6.3.6.2: Click reinitialize and exit out of options menu.

4.6.3.6.3: Verify that all SPods are communicating by moving the slider at bottom of data
section. Each address that has been inputted, along with data input from that SPod should be
visible (Figure 10).

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Figure 10: Example of initial few points of SPod data logging

4.6.3.6.4: Click the START button to begin logging. File name will show up in box next to
START button (Figure 10). To stop logging press the STOP button. To change file name and
auto-log on restart, navigate to options > APP Settings.

4.6.3.6.5: To download the data from the BS from a remote computer TeamViewer™
(https://www.teamviewer.us/or another remote link software must be installed on the BS and as
well as the computer you are remotely downloading from. For TeamViewer™ to work, both
computers must have an active internet communication. The BS has a cellular modem, so it
should always have an active connection. Be sure the computer in the remote location has an
active internet communication. For remote access the base station computer should be set to
never go to sleep. The power settings can be found in Control Panel -> Power Options. Change
these to "never". When TeamViewer™ is opened the display will look like Figure 11. To
access the remote computer type in the Partner ID (the partner ID will have to be established
prior to deployment) and hit connect to partner.

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Figure 11: Example of TeamViewer™ setup

4.6.3.6.6: Once the computers have successfully synced, a window containing the "desktop" of
the BS computer will appear (the standard startup desktop screen of any Microsoft Windows
computer). In order to download the data from the remote computer, navigate to documents
page on the BS computer and go to the VET data folder established in option > APP Data.
Highlight and copy the data files, and paste into your remote PC's documents folder.

4.6.3.7: Conduct SPod operations tests. After the installation of the SPod(s) and BS (if used), the
system installation operations test must be performed. These steps can also be used if a sensor
fails and needs to be replaced in the field. Data will not be valid until a valid bump test is
performed on the new sensor. This test is also performed at frequencies specified in the QAPP
and prior to the take down of the equipment at the end of the field deployment. This test
confirms: (1) the SPod sensors are nominally operational, (2) data are being recorded to the SD
card(s), and the BS (if used), (3) the BS is properly communicating with the SPod(s) and
remotely via cell phone modem or internet connection. The PTD, press, temp, and RH sensors
and sonic anemometer data acquired by each SPod are checked for reasonableness in this test
and the PID sensor is also checked for functionality using an isobutylene gas cylinder in a
procedure called the bump test (BT). After a minimum of 30 minutes of operation of the
SPod(s)/BS system, the field personnel will conduct the BT on each SPod Node. During the
time it takes to perform the BT, the other sensors should be recording nominal data. After the
completion of the BT, the field person will confirm operation by visually examining the recorded
data (4.6.3.7.4)

Description of PID Bump Test: Under normal operation, the SPod PID produces an uncalibrated
measure (indicator) of time-resolved plume concentrations. As described in Section 4.3, the
baseline levels of the SPod PID can change by large amounts due to analytical interferences
(sensor drift, air shed changes) that are convolved with the signal from near-field emissions
plumes (target detection parameter). The near-field emission plumes have a different temporal
character than the analytical interferences allowing mathematical decoupling of the signals
(Section 4.7). The known baseline variability of the SPod, coupled with the PTD's varying
(unknown) response to different compounds present in emission plume make calibration not

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feasible in the current SPod version. The aim of the SPod PID BT is to present a short duration
concentration spike to the PID that simulates an emission plume it would encounter in the
ambient environment. Because the PID baseline is a function of ambient conditions (particularly
RH), the PID BT is designed to not alter the operational conditions of the PID (such as by
bathing in dry gas from a calibration cylinder).

4.6.3.7.1: Setup 58L bottle of 0.5-2 ppm isobutylene with regulator with a CGA C-10 (or CGA
590) fitting. Slip flexible tubing over the barbed fitting on the top of the regulator and connect to
~5' tubing with Swagelok fitting. The final setup should appear as in Figure 12.

Note: If using a larger cylinder, a rotameter must be in line to regulate flow to 0.5 1pm. The
CGA C-10 is an on-demand regulator set at 0.5 Ipm.

^ .25" Teflon Tubing
¦ ^ Pit) Sensor Cap

,25" Urnon

,25" toot
Tie Wraps

Hook

00 » vt two minutes. (5) Repeat the procedure to produce data point 2, (6) Repeat the
procedure to produce data point 3. Move to next SPod and repeat procedure 4.6.3.7.3. The BT
should be performed in triplicate (three times for each SPod). This step can be completed with
one person if time intervals are written down ahead of time and followed accordingly.

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4.6.3.7.4: Complete SPod installation operation tests: (1) Turn off SPod by unplugging the
power cable. (2) Remove the SD card from each SPod and insert it into a card reader and copy
the data file(s) onto the hard drive. (3) Replace each SPod SD card, double check card
installation (Section 4.6.2) and repower SPods. (4) Investigate data files to ensure data was
being recorded by all sensors and that it is reasonable (e.g. check wind direction by comparing
the value to other co-deployed units and to known values [nearby airport, onsite observed] to
ensure values are reasonable). The sensor reasonableness check is passed if all values and cross-
comparisons that are available to the installation team indicate that the SPod systems are
operatizing nominally. (5) Verify that the PID BT was registered on each unit and record the
time for signal appearance and approximate response level over baseline as recorded by the SPod
[called "PID level (cts)" ] in the appropriate sections on the data form (Section 7). The BT PID
Level is determined by estimating the baseline level (in cts) just prior to the application of the
BT concentration spike and subtracting this value from the observed highest estimated value
during the BT concentration spike. This determined value is recorded as ''PID Level (cts)" in the
setup form. Repeat for the two other BT spikes. The BT test is passed if PID levels are above
consistent at a value grater then the baseline for all three tests and the baseline signal is
approximately the same before and after the application of each BT. This provides the primary
time offset check for the SPod node in comparison to cell phone time. (6) investigate BS data file
(if present) and perform similar checks and record times of BT. This provides a primary time
offset check for the BS in comparison to cell phone time and confirms the identity of the SPod
node in the BS data feed. Perform remote communications test with the BS by attempting
communication from an independent computer (not on the local network). The communication
test is passed if stable remote communication is demonstrated. Record all values or pass/fail
assessments on the data form (Section 7). If any values fail, consult work assignment lead for
corrective action. If using a BS all BT data can be monitored live on the BS screen.

• Complete data fields (11) through (18) under SPod Field
Deployment Form in Section 7

4.6.3.7.5: Deploy can trigger system (if applicable). All can system must pass a lab leak check
and properly documented with the " Lab Can Trigger System Leak Check" Form. Follow the
procedures established on this form. This ensures that the can system has been checked before
field deployment. Once an installed SPod network is fully operational, mount SPod can trigger
system directly below SPod. This can be done using pipe clamps applicable to the size of the
pipe the SPod is mounted to (3/4"). See Figure 13 below:

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Figure 13: SPod-Evacuated Canister system

1.4 L Silonite® coated stainless steel canisters will be prepared in accordance to the procedures
described in MOP 3070: Canister Field Grab Sampling using 1.4 L canisters. The current can
trigger system employs one evacuated canister per SPod. The can system must pass an initial in-
field leak check. This can be done by installing a 1.4 L cannister and initializing the pressure
~30inlig. Then immediately take the can off and wait for 30 seconds. If the pressure in the
system does not change with the can uninstalled, then it can be assumed there is no leak.

To operate the can trigger system, the grey three prong male connector will plug directly into the
female receptor on the bottom of the SPod. The can's negative pressure must be noted before
and after operation to verify proper operation. In order to pass the can must have a negative
pressure remaining upon retrieval to be considered a usable sample. To control the sampling
system, the user must access the SPod menu via Tera Term or other HyperTerminal. This can be
done using a Xbee receiver compatible with the SPod (Or serial cord) setting to the associated
serial port, and using the baud rate of 57600. Table 2 below shows the standard values set for the
trigger system. When using a BS the VET v2.2 can also control the SPod and provide the
commands through its interface under "SPOD Settings" as shown in Figure 14. Through this
interface the user can also align the internal SPod time to the BS time.

17

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Note: The letter "a" will be used to denote the SPod node. This letter will vary by SPod.

Table 2: Can operation

Command

Function

Description

a??

Open SPod Menu

When this is executed the
SPod menu will appear.

aS35

Sample Time

When this is executed the can
system will be set to pull a
sample for 35 seconds when
actuated.

aDl

Arm Can

When this is executed the can

will be armed. Noting will
happen unless this value is set
to one. Disarm using aDO

aA10

Averaging Time

When this is executed the
SPod internal rolling average
period will be set to 10
seconds

aOl

Manual Trigger

When this is executed the can
system will be manually
triggered.

aC4000

Trigger Level

When this is executed the
trigger level will be set to 4000
counts.

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Can Trigger Level

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During normal operation the system is triggered when the rolling average is greater than the set
trigger value. Once the system is triggered the canister is disarmed until it is manually armed
again by the user. The same is true for the manual trigger.

Note: The trigger algorithm is in constant development to ensure the best results.

4.6.3.8: Complete the installation process by performing a final site and installation safety
inspection and cleaning up tools and materials. Take digital photographs of all the setup
configurations from various vantage points and store for future reference(Section 7).

• Complete data fields (19) and (20) under SPod Field Deployment
Form in Section 7

4.6.3.9: Occasionally, an SPod component may fail and require replacement. If there is a
component failure, the SPod can be field repaired if the part is "field swappable". For example,
if a new PJD, micro-processor or xbee receiver were to fail, trained field personnel may make the
swap. The SPod data will not be considered valid until a proper pre-deployment bump test has
been performed as per the project QAPP(this test can be performed at remote location). A field
deployment sheet will need to be completed to start the official data collection.

4.7 Calculations

This Section describes SPod data along with the calculations and procedures that are performed
to convert raw SPod data into plume detects. This Section also describes the data inspection
procedures and calculations that identify physical and analytical method interferences and
establish data acceptance criteria. Additional information on the Sensors that are used in the
SPod is contained in "Draft Design Package for U.S. EPA Beta Version SPod Fenceline Sensor",
version January 2018.2

4.7.1: SPod data are recorded in the format presented in Table 3. The example below is for a
single SPod that is fitted with a 3D Sonic anemometer. If a 2D sonic is used, the Sonic. W
column is not present in the data file. If multiple SPods nodes are part of the same network and a
BS is used to record data from the units, a unique letter (a, b, c...) precedes each data field [e.g.
a.PID (cts), a.Temp (degC), etc.]. For subsequent SPod units, the data field is repeated with a
different preceding letter [e.g. b.PID (cts), b.Temp (degC), etc.]. The preceding letter is linked to
the unique SPod S/N in the data form of Section 7. For a BS recorded system, each SPod node
data line is acquired sequentially and there is a slight delay time associated with this acquisition
so the data acquisition rate will slow to approximately 0.5 Hz for three units. Data are still
recorded on the SD cards on each unit at 1 Hz. The time stamp for a BS controlled system is the
computer time and may have some offset from individual SPod times due to SPod Arduino
computer drift (initial offset established in 4.6.3.7.4).

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Table 3: SPod data format

TimeStamp i PID (counts) iTemp(oC) iHum(%) i Press (hPa) i SUMMA_0 () i SUMMAA () i SUMMAJM () i Sample Time (sec) i Rolling Avglnt (sec)

4/5/190:00

2627 0

0

0



0

0 0



35

10

4/5/190:00

2630 0

0

0



0

0 0



35

10

4/5/190:00

2655 0

0

0



0

0 0



35

10

4/5/190:00

2696 0

0

0



0

0 0



35

10

4/5/190:00

2696 0

0

0



0

0 0



35

10

4/5/190:00

2651 0

0

0



0

0 0



35

10

4/5/190:00

2651 0

0

0



0

0 0



35

10

4/5/190:00

2685 0

0

0



0

0 0



35

10

4/5/190:00

2632 0

0

0



0

0 Q



35

10

4/5/190:00

2686 0

0

0



0

0 0



35

10

4/5/190:00

2666 0

0

0



0

0 0



35

10

4/5/190:00

2637 0

0

0



0

0 0



35

10

4/5/190:00

2675 0

0

0



0

0 0



35

10

4/5/190:00

2626 0

0

0



0

0 0



35

10

'ID Avg (counts) i Can Trig level (counts) 1 Sonlc.U () 1 Sonic.V () i

1 SonlcW()

ISonlc.So5() 1 Sonic.Temp (oC) 1 Sonlc.hex code () 1

i Sonlc.ErrorCode () 1 Sonic. Vol (V)

0

0

1.48 -ill



0.79

343.94

20.39

42

0

1L4

0

0

0.76 -2-11



0,39

343.96

20.43

45

0

11.4

0

a

0.52 -2.02



0.26

343.96

70.43 4F



0

11.4

0

0

0.64 -2.24



0.3

343.94

20.41

49

0

1X4

0

0

0.72 -2.35



0,39

343.92

20.37

40

0

11.4

0

0

0-82 -2.06



0.69

343.9

20.35 4A



0

11.4

0

0

0.43 -1.94



0.66

343.9

20.33

46

0

11.4

0

0

0.51 -2.14



0.56

343.88

20.29 4F



0

11.4

0

0

0.16 -1.54



0.12

343.9

20.35 4F



0

11.4

0

0

0.07 -1.81



0.08

343.88

20.29

48

0

11.4

0

0

-0.22 -1.67



-0.03

343.84

20.24 4D



0

11.4

0

0

0.13 -1.62



0.15

343.76

20.11

46

0

11.4

0

0

0.12 -1.53



0.31

343.78

20.14

48

0

11-4

0

0

0.37 -1.55



0.03

343.8

20.18

43

0

11.4

•	Timestamp: date and time of acquired data line in mm/dd/yy hr:min:sec

•	PID (counts): instantaneous signal level of PID sensor in counts, range from 0 to
32,000

•	Temp (oC): uncalibrated temperature sensor output in degrees C

•	Hum (%): Relative humidity percent

•	Press (hpa): Atmospheric pressure in hpar

•	SUMMA O (): Indicates at which data points the Sumrna can was open.

•	SUMMA_A(): Shows if the cannister is armed. Armed: I, unarmed :0.

•	SUMMA_N(): Shows if system has a new can. new:l, old:0. System can only be
armed if a new can is installed.

•	Sample Time (sec): If triggered, length of time the can will pull a sample.

•	Rolling Avg Int (sec): Interval at which the can trigger logic is averaging data.

•	PID Avg (counts): When can is armed, represents the rolling average over the
interval set.

•	Can Trig Level (counts): When the PID Avg exceeds this value the can will
trigger.

•	Sonic.U (): U-axis (horizontal component 1) wind speed in meters per second
from the sonic anemometer

•	Sonic.V (): V-axis (horizontal component 2) wind speed in meters per second
from the sonic anemometer

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•	Sonic. W (): W-axis (vertical component) wind speed in meters per second from
the sonic anemometer

•	Sonic.SoS 0: Speed of sound as determined by the sonic anemometer

•	Sonic.Temp (oC.): Temperature of air in degrees C as determined by the sonic
anemometer

•	Sonic.Hex.Code: Result of checksum in the sonic output string, expressed as a
two-digit hexadecimal value

•	Sonic.Error Code (0/other): If the sonic anemometer detects an operational error,
value becomes non zero

•	Sonic.Vol (V): The supply voltage the sonic anemometer is receiving, a surrogate
for SPod power

4.7.2: General description of prototype SPod data analysis. The current version of the SPod is
intended to be a low cost, easy to deploy system that can detect emission plumes in fenceline
applications. Several data analysis approaches can be applied to single node and multinode
fenceline sensor data to investigate aspects of source emissions, such as proximity, constancy,
triangulation (location determination), and source strength. This MOP does not describe these
types of data analysis. This MOP describes the basic data analysis approaches and screening
procedures that support data quality assessment and QA functions. This MOP focuses on
analysis of P1D data quality since this is the most challenging aspect of current prototype P1D
design and use. As discussed previously, the current version of the SPod does not condition the
inlet air but does heat the PID sensor. As such, physical and analytical method interferences can
present significant issues with the current system and special procedures must be used to ensure
data quality and filter-out unacceptable data (referred to as "QC screens" or "QC checks" in this
document). These procedures are described in subsequent sections. The following steps are
used for current prototype SPod data analysis:

•	SPod data visual inspection and thresholding to protect against "off scale"
conditions (Section 4.7.3)

•	SPod data visual inspection to investigate rapid RII swings (Section 4.7.4)

•	SPod data visual inspection to identify anomalous data drop-out conditions
(Section 4.7.5)

•	Use of baseline removal algorithms to separate plume events from background
changes and sensor drift (Section 4.7.6)

•	Use of concentration wind rose plots to understand source direction (Section
4.7.7)

•	Use of dual SPod deployments to correlate emission events. (Section 4.7.8)

SPod raw data are processed using a custom software program written in "R" [See Section 8],
1'he code reads in the SPod data and produces first level summary allowing visual inspection QA
procedures to be performed to screen-out unacceptable data. The program then applies baseline
removal on acceptable data followed by wind comparisons. Optionally, this program will also
generate a daily summary sheet described below. The code is contained in an EPA share drive
and can be obtained by contacting Eben Thoma.

The first step in analysis of SPod data is to create a daily summary sheet(data record) for each
day of operation that plots the raw SPod PID concentration counts (cts) throughout the day

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(Figure 14). This is accompanied with filling out items (1) - (7) in the SPod Data Analysis form
(Section 7). Hard copies of these records should be kept in a binder to allow each day of
operation to be easily investigated. Optionally, an electronically generated summary sheet can
be created in the place of the hand-written copy and stored on a share drive (figure xx). The
electronic version provides the same written information, raw graphs, polar plots and other
useful calculations. In the example of Figure 14, one can see some slower baseline variation and
one period of "spikes" near 20:00 that will require further investigation. In this example, two
independent P1D systems are co-deployed (here called units A104 and BI06).

2500

_ 2000

|

ID

I

1 1500

DO

«7>

*
cd

9 1000

500

Time (hr:min)

Figure 15: Example of a daily SPod PID raw data record

As discussed in subsequent sections, visual inspection of the daily data graph can provide critical
information on the operational state of the PID. For the example of Figure 15, these tests are
"passed" so provided here is an example of additional data analysis steps that include removal of
the slowing varying baseline (analytical interferences) using a spline fit procedure, allowing the
potential plume detects to be more easily observed [Figure 16(a)]. Figure 16(b) show a zoomed
in view of the primary plume detects around time 20:00 showing simultaneous detection on two
independent SPod units. Further analysis would bring in wind direction and other data.

Site: PI	(a\

Spods. A104, B106	V '

owe; 01/27/2017

• kuMi -jhm4h'i Ah <1,1.1		I

Time (hr:mln)

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Figure 16: (a) Data from Figure 15 after baseline removal, (b) zoomed in view of primary detects
After production of each daily data graph:

• Complete data fields (1) through (10) under SPod Date Analysis
Review Form in Section 7

4.7.3: SPod data visual inspection and data calculations are used to protect against "off scale
high" and "off scale low" conditions. Under certain conditions, (like a heavy dew) the current
SPod PID sensor can become contaminated with water causing the system to become non-
operational (off scale high or low) for a period of time until it dries out. Note that this physical
interference may be related to but is separate from the RH swing effects discussed subsequently.
The off scale high or low condition may also be caused by other factors such as sensor
malfunction or power loss. The off scale high condition is easy to visually detect and an R
function "screenOffScale" has been written to remove data that have a five-minute average
signal concentration greater than 31,000 cts. The off scale low condition can also be visually
detected and the "screenOffScale" R function removes values where the five-minute average
signal concentration less than ~250 cts

4.7.4 SPod data visual inspection to investigate rapid RH swings. The PID sensor responds to
relative humidity and when it changes rapidly, producing an analytical interference that can be
mistaken for a plume signal. As can been seen in Figure 17, the sharp increase in relative
humidity Around 16:00 causes a spike in the PID sensor that should be removed prior to further
analysis. An R function "screenRH" has been written to identify and remove these time periods,
but visual inspection should be conducted as well.

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Figure 17: (a) PID reading show large spike on three SPod
nodes coincident with (b) large R! I swing.

4.7.5 Perform SPod data visual inspection to identify anomalous data drop-out conditions. In
some cases, the SPod PID may exhibit sharp drops in signal (For example, Unit D in Figure 18 ).
This effect can be caused by the SPod running near the power threshold for operation (for
solar/battery systems) or by other sensor malfunctions. These time periods should be screened
out before further analysis. The screening can be performed using the R function "screenDrops"
but should be accompanied by visual inspection.

3000-

Q

2000-

1000-

0

	unite

— Unit D
	Un#E

Figure 18: Example of data drop-out on Unit D.

4.7.6 Use baseline removal algorithms to separate plume events from background changes and
sensor drift:Data that passes the above criteria should be further processed, by removing baseline
drift using quantile regression with trend filtering. This can be accomplished using the R
function "getBaseline". In Figure 19 on the left, the black trace represents raw PiD counts from
3 SPods (top to bottom). In the case the bottom two SPods are exhibiting off-scale low
conditions. The red trace represents data that has passed the QC screens. The figure on the right
shows the sensor values after drift removal. Note that these values are still likely below plume
detection threshold (Section 4.8).

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1 B

i- - r	r —i ~i

1-j	

'	1	1	1	 ¦ 1 1

0*03 ®£C 1*00 1920 0300

/\

r ¦ i i v

I: Jll

' i r ii i

0*00 09.03 1*00 1903 0303



-Jlj il

0*03	©00	1*03	1903	CO 03

0*03	900	1*00	1903	0000

Figure 19: Example data QC check (right) with red trace indicating data that passed the check
with baseline removal (left)

• Complete data field table in (11) under SPod Date Analysis Review
Form in Section 7

4.7.9 Further processing of data for those time periods recorded in step (11) of SPod Data
Analysis Review Form that are viable (pass above data QC screens/checks) as required by the
specific project. If plume detects are observed in initial data process, perform additional analysis
such as direct comparison of co-deployed SPods units and use of concentration wind rose plots
to understand source direction. After the drift has been removed, polar plots can be used to
investigate relation between the PID signal and wind conditions (Figure 20). These diagnostics
are meaningful when significant emissions plumes are isolated, so this represents advanced data
processing and is not described in this MOP.

•

•

I

-



.9

r



y





Figure 20: Example of a concentration wind rose plot for a strong emissions plume detection

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4.8 Quality Assurance/Quality Control

This Section summarizes the basic quality assurance and quality control procedures used for
SPod installation and operation (Table 4). Note that final data acceptance criteria will be project
specific and discussed in the QAPP and reporting.

Table 4. Summary of basic QA/QC procedures for prototype SPod set up and use

Condition

Accepting
Criteria

Method procedure /
corrective action

Frequency

SPod pre-
deployment
test

SPod must prove
normal operation
over the span of a
minimum of 36
hours.

At least three SPod bump test

(one worksheet) must be
completed on the test range (or
other site), and all sensor data
checked for reasonability before
deployment

Once before
deployment

Verify proper
SPod and BS
set up

Completion of
SPod Field
Deployment Form
(I)-(20)

Execute MOP 3010 Section 4.6

/ if during installation test
specific sensors are found to be
non-operational, consult with
field lead on corrective actions

Once at installation

Periodic

SPod
operations
check

Completion of
SPod Field
Deployment Form
item (18)

Execute MOP 3010 Section
4.6.3.7 / if during specific
sensors are found to be non-
operational, consult with field
lead on corrective actions

Once per month of
deployment (or by
frequency specified in
the QAPP) and at
decommission of
deployment

Daily Data
Screen

Completion of
SPod Data Review
form (1)-(11)

Execute MOP 3010 Section 4.6
/ no corrective action is
required

Once for each day of
data acquired

Wind
Measurement
Check

Reasonableness
compared to
independent
values

Perform reasonableness check
by comparing acquired data
other collocated data source / if
found problematic, exclude
data. Typically, 5-minute
average wind direction and sped
should agree within +/- 20% for
collocated units at the same
elevation.

Once per week
recommended

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Condition

Accepting
Criteria

Method procedure /
corrective action

Frequency

P1D Check (if
possible)

Reasonableness
compared to
independent
values

Perform reasonableness check
by comparing time periods with
elevated PID data (confirmed
plumes) with collocated other
data source (e.g. on site GC).
Typically, fast on-set plume
events register by a field GC
that exceed 50 ppbv (for P1D-
measured compounds) should
be observed by the SPod.

100% as available

Heater Check

Reasonableness
compared to
resistance of
heater being used.

Perform reasonableness check
by using an ohm meter to check
resistance across the heater to
ensure values are similar to the
resistance measured during
system assembly (+/- 20%)

Once at installation

Lab Can
Trigger
Check

System must pass
a 2 min leak check
and 24 hour leak

check before
being taken to the
field.

The method is described on the
worksheet in section 7.

Once before
deployment

Field Can
Trigger
Check

System must pass
leak check oGO
sec. System must
trigger by
command.

Perform leak check in the field
by putting on a canister to make
system pressure ~30 inhg and
taking off immediately. The
pressure in the system should
not change over the course of

30sec. Then send manual
trigger to verify operation of
system.

Once at deployment

5 REFERENCES

'Draft Design Package for U.S. EPA Beta Version SPod Fenceline Sensor, version January 2018,
contained as Appendix C2 of this QAPP

2E. D. Thoma, H. L. Brantley, K. D. Oliver, D. A. Whitaker, S. Mukerjee, B. Mitchell, B. Squier,
T. Wu, E. Escobar, T. A. Cousett, C. A. Gross-Davis, H. Schmidt, D. Sosna, H. Weiss. J. South
Philadelphia passive sampler and sensor study. J. Air Waste Manage. Assoc. (2016), Vol. No.
10, 959-970; doi:org/10.1080/10962247.2016.1184724.

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3R Core Team R: A Language and Environment for Statistical Computing; R Foundation for
Statistical Computing: Vienna, Austria, 2013.

6 MOP History

This MOP was based on previous SPod procedures. Biannual reviews and any revisions should
be documented in the table below.

Revision

#

Description

Prepared/Revised By:

Effective Date

0

First issuance

J. Cansler (JTI), H.
Brantley, and E. Thoma
(EPA)

05/11/2017

1

Revised version including
canister trigger and PID heater
with updates several sections

J. Cansler (JTI), P.
Deshmukh (JTI) and E.
Thoma (EPA)

03/12/2018

2

Updated procedures, software,
data handling.

J.Cansler (JTI)

08/01/2019

3

Minor Edits/ Revisions/Review

P,Deshmukh (JTI)

08/05/2019

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7 Deployment and Analysis Forms

SPod Pre-Deployment Form

Procedure Step 4.6.1	Date:	

(1)	SPod S/N(s):

(2)	SPod(s) Location:

(3)	Gas concentration and flow rate:

(4)	Set SPod time sync to cell time: (Y/N)

(5)	SPod anemometer pointed North check: (Y/N)

(6)	True or Magnetic North: (T/M)

(7)	Site notes:



SPod __
Bump Test 1

SPod	

Bump Test 2

SPod	

Bump Test 3

SPod	

Bump Test 4*

Cell Time









PID Level (cts)









~PID Baseline
Level (cts)









~PTD Spike (cts)









Temp. Pass (Y,N)









Press. Pass (Y,N)









RH Pass (Y,N)









Sonic Pass (Y,N)











SPod	

Bump Test 1

SPod_
Bump Test 2

SPod	

Bump Test 3

SPod_
Bump Test 4*

Cell Time









~PID Baseline
Level (cts)









~PID Spike (cts)









PID Pass (Y,N)









Temp. Pass (Y,N)









Press. Pass (Y,N)









RH Pass (Y,N)









Sonic Pass (Y,N)









~Bump lest 4 optional

(8) Certify SPods for the field: (Y/N)

Signature of tester:	

End.

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SPod Field Deployment Form

Procedure Step 4.6.1

(1)	Site name:

(2)	Deployment date:

(3)	Field personnel:

(4)	SPod S/N(s):

(5)	Base station S/N (if used):

(6)	GPS coordinates of SPod(s):

(7)	Set SPod time sync to cell time: (Y/N)

(8)	Perform pre-install site safety check:	( Y , N)

(9)	Site notes:

Procedure Step 4.6.2

(10)	Preform SD install check:	( Y , N)

Procedure Step 4.6.3

(11)	SPod anemometer pointed North check: ( Y , N )

(12)	Magnetic North or true North?

(13)	SPod level check: ( Y , N)

(14)	SPod to tripod tightness check: ( Y , N)

(15)	SPod solar panel pointed South check: ( Y , N, NA)

(16)	SPod powered on light check: ( Y , N )

(17)	SPod BS operation check: ( Y , N )

(18) SPod operation test:



SPod_
Bump Test 1

SPod	

Bump Test 2

SPod	

Bump Test 3

SPod	

Bump Test 4*

Cell Time









PID Level (cts)









~P1D Baseline
Level (cts)









-PID Spike (cts)









Temp. Pass (Y,N)









Press. Pass (Y.N)









RH Pass (Y,N)









Sonic Pass (Y,N)









Can Sys Pass

Y - N - NA







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SPod	

Bump Test 1

SPod	

Bump Test 2

SPod	

Bump Test 3

SPod	

Bump Test 4*

Cell Time









PID Level (cts)









~P1D Baseline
Level (cts)









-PID Spike (cts)









Temp. Pass (Y,N)









Press. Pass (Y,N)









RT T Pass (Y,N)









Sonic Pass (Y,N)









Can Sys Pass | Y - N - NA







~Bump test 4 optional

Add tables for additional SPods if required.

Procedure Step 4.6.4

(19) Perform final site and installation safety check (Y,N)

End

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SPod Data Analysis Review Form

Procedure Step 4.7

(1)	Site name:

(2)	Date data were acquired:

(3)	Date data were processed

(4)	Analysis personnel:

(5)	SPod(s) S/N:

(6)	Base Station S/N (if used):

(7)	Daily raw data file name:

(8)	Daily raw data graph file name:

(9)	Daily processed file name(s):

(10)	Daily processed data graph(s) file name(s):

(11)	Perform data visual inspection, thresholding, and basic processing (4.7.3 - 4.7.6).

Mote hours (hrs) in the day (0.00 hrs -24:00 hrs) were conditions exist.



SPod 1

SPod 2

SPod 3

SPod not operational
hrs.







PID off-scale hrs.
(4.7.3)







RH swing events
(4.7.4)







Data drop events
(4.7.5)







Successful Baseline
removal hrs. (4.7.6)







Potential plume
detects







(12) If potential plume detects exist, perform additional data analysis to confirm plume
detects

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UX&& 10	SPod Da-* A'afySi ftov** -wnr

SPod Data Analysis Review Form

Procedure Step 4.7

(1)	Site name, number and coordinates.:?1 ra Arrrs Train ng Carter 1 .39,231533 -85.731553

(2)	Date data acquired: 2019-3-'-26

(3)	Date data Proce**ed:20'9-07-30

(4)	SPod Modes: i. c

(5)	Base station sIn: VL104

(6)	Raw data file name: S01_201bScroonud_timoSeJtes.csv. 2C1&-0/-26basolrc_rQn-oved.csv.
2019.Q7-26tjaselioa_flt.CBV

(10} Perform data visual inspections, thresholding, and basic procesing (4.7.3 ¦4.7.6).

Summary Table (5min)

S pod .Summary

SPodl

SPod2

Oetocss

7M.00

I29jO0

P«/C*-13 Opt-f;; iiur.j

99,a i

99.91

PWWt PffCtOn

9.0«

1-49

PtJ Coiffc:l«d Vtea*i i.No Detect}

16.25

10.98

Dotad Pw iurf V'l.tri

r.q.nfl

21.97

SI)-No Ur.ec t

«.07

249

Can Trigyr-

0,00

9.00

SPod Raw Signal Daily Graph

S_Q1 Louisville
201 &-07-26

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f.nicraiy
Detects

26
20-
15
10-

SPcd A-alv« s	fonr

MOP #3010
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i

20

Pit) corrected with Threshholfl

f.lft

A!2S12:0IX	jL126 1fc:M

timeCut

Devic ©Number

Ji.JU*iliUL



•4m.

uU*Jl

•uJuJu

Polar Plots (5min)

34

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SPad Or* A-aly^s- ^v> -ortr

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3

2.5 ,
2

15Wj

- -A

to

k .



1

5

ft

SO

70
60
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40

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-20

f><1 mean

pn_S"i.'i,/.'PTngT3Tv5''i,Tn"cri-'»SP"rt_V'FTi'p'5«vn5sS£>orl_flnalysis*5-tr_l .Y_20t®M»^3,»ienl

End.

Printed copies of this document are uncontrolled. All users are responsible for confirming version
status against the electronic version in the document control system.


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MOP #3010
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Page 36 of 31

Lab Can Trigger System Leak Check

procedure:

Part A - Place an evacuated sumnna canmster on ttie system by connecting to the quick connect. The
pressure should be between 25-30 inHg. Let this set for 2 minutes. There should be zero pressure drop

for this to pass.

Part B - Place the same evacuated summa carmister on the system by connecting to the quick connect.
The pressure should be between 25-30 inHg. Let this set for 24 hours. There should be <1 inHg pressure
drop for this to pass.

test:

A:

Date

Time

System ID

Starting Pressure

End Time

Pass^Y/N)













B:

Date

Time

System ID

Starting Pressure









Date

Time

Ending Pressure

Pass(Y/N)









Signature of tester

End.

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Printed copies of this document are uncontrolled. All users are responsible for confirming version
status against the electronic version in the document control system.


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\#CriTVAgencv	Page 84 of 138

MOP #3010
Revision 2.0
08/05/2019
Page 37 of 31

8 Data Analysis Code

All codes and programs currently being used can be obtained by contacting Eben Thoma at
Thoma.Eben@EPA.gov.

Printed copies of this document are uncontrolled. All users are responsible for confirming version
status against the electronic version in the document control system.


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Appendix C: Remote Data Retrieval Procedure

1.0 Data Retrieval

1.1 Sensit SPod Data Retrieval

1.1.1	Connect the field laptop computer the internet and open a browser window. Log onto the Sensit
SPod cloud data storage by accessing the following web address:

http://18.222.146.48/SPOD/epa/data/raw/SPOD/10Q3/. The username is "epatestuser" and contact
ERG Task Manager for the password.

1.1.2	Click on the day of the data file that needs to be downloaded. While on the screen with the data,
click on the "File" header and choose the "Save as..." option.

1.1.3	Save the data file as a .txt file format in the prescribed folder that is set up just for the Sensit SPod
data.

1.1.4	Continue this process for all data files needing to be downloaded.

1.1.5	Log off of the website by closing the browser window.

1.1.6	Open one of the recently downloaded .txt data files with Microsoft Excel. Choose the option for
"Delimited" and click the "Next >" button. Select the "Tab", "Comma", and "Space" Delimiters
and click the "Finish" button.

1.1.7	Save the data by clicking the "File" header and choosing the "Save as..." option. Make sure Excel
is saving the file in the same folder as the original .txt file and as the same name of the original
file. Just to the left of the "Save" button select the option to save the file as an Excel workbook
(*.xlsx) file from the pull-down menu. Then click the "Save" button.

1.1.8	Repeat this process for all other downloaded Sensit SPod data.

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1.1.9

Inspect the converted data files to ensure data was being recorded by all sensors, that there are no
missing data or data gaps, and that it is reasonable (e.g. check wind direction by comparing the
value to other co-deployed units or to known values [nearby airport, onsite observation]).


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Appendix D: Certificates of Analysis

GASC6

GASCO AFFILIATES, LLC.

320 Scarlet Blvd.

Oldsmar, FL 34677
(800) 910-0051
fax: (866) 755-8920
www.gascogas.com

CERTIFICATE OF ANALYSIS

Date: March 8( 2019	Customer: Grainger

Order Number: 4625257641

Lot Number: DBJ-248-0.5-1	Use Before: 03/08/2023

Component	Specification l+l-10%)	Analytical Result (+1- 2%)

Isobutylene	0.5 PPM	0.45 PPM

Air	Balance	Balance

Cylinder Size: 3.6 Cu. Ft.	Valve: 5/8" -18UNF

Contents: 103 Liter	Pressure: 1000 psig

The calibration gas prepared by Gasco is considered a certified standard. It is prepared by gravimetric, or partial pressure
techniques. The calibration standard provided is certified against Gasco's G M I.S. (Gas Manufacturer's Intermediate
Standard) which is either prepared by weights traceable to the National Institute of Standards and Technology (NIST) or
by using NIST Standard Reference Materials where available.

Analyst:


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ISO 9001:2008

Linde SPECTRA Environmental Gases, 80 Industrial Drive, Alpha, NJ 08865

THE LinDE GROUP

If	

c^irtUc

e.-IIPPED TO:

Eastern Research Group
601 Keystone Park Dr Ste 700
Morrisville, NC 27560-0348

PAGE: 1 of 1

CERTIFICATE OF ANALYSIS

Sales#:
Production#:
Certification Date:
P.O.# :

Blend Type:
Material#:
Traceability:
Expiration Date:
Do NOT use under:

117071196

1481899

Feb-20-2019

P066562

CERTIFIED

24100940

NIST by weight

Feb-20-2020

150 psig

Cylinder Size: 185 (3.2" X 9.4")
Cylinder# : AB-111640
Cylinder Pressure: 1700 psig

Cylinder Valve: CGA 180/Aluminum
Cylinder Volume: 0 8 Liter
Cylinder Material: Aluminum
Gas Volume: 98 Liters
Blend Tolerance: 10% Relative
Analytical Accuracy: 5% Relative

COMPONENT

CAS
NUMBER

REQUESTED CERTIFIED
CONC CONC

Chloroprene

126-99-8

0.50 ppm 0.50 ppm

Nitrogen

7727-37-9

Balance

Balance

ANALYST:



c^-\^

DATE:

Feb-20-2019

Lou Lorenzetti

Linde Gas North America LLC	(908) 329-9700 Main (908) 329-9740 Fax

www Lirdeus.com


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Appendix E: Sensit SPOD Sensor Operational Manual

SENSIT SPOD Sensor Operation Manual and
Configuration Guide

Version 1.0, August 12, 2019

For Questions Contact: jmelby@gasleaksensors.com

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SPOD Sensor Overview

General

Overview

Parameter

Weight

Base unit: 6.75 lbs



Dimensions

Fully assembled with anemometer and antenna
• DxWxH (6" x 8" x 16")



Mounting

Attached mounting flanges



Voltage Requirements

18V - 24V DC Charging (wired adapter or solar panel)



Current Requirements

2A max current draw when charging



Operating Runtime

3-5 days battery backup 1



Operating Temp

-10°C to 50°C2



Data Outputs

•	Digital wired output (3.3V TTL - USB)

•	Wireless (4G loT Cellular Included)2

•	Optional analytics on server4

•	SD card data backup 5





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Notes:

1.	Battery backup time depends on run mode and frequency of transmission.

2.	Limited by lithium ion charging temperature. Lower temperature operation
will require external or internal heating to maintain sufficient battery
temperature for charge acceptance. Contact the manufacturer for more
information.

3.	Requires SIM card and suitable data plan on AT&T or T-mobile. Verizon
service is pending

4.	Cloud based analytics can be developed with additional contract

5.	When removing SD card to obtain data, it is recommended to power off the
sensor box prior to reinserting the SD card to avoid possible errors. If the
system stops responding or any SD errors are observed after inserting an
SD card, power down the sensor and turn back on.


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Sensors

Overview Parameter

Default PID Detection Range 10 ppb - 2 ppm1
Default PID Lamp Energy
Target PID Accuracy
Response Time
Expected Lamp Life

Notes:

1.	VOC range reference to isobutylene. Additional PID sensors available with
identical form factors if higher concentrations are necessary.

2.	Additional PID sensors available with identical form factors if different lamp
energies are required.

3.	Factory calibration conducted with lppm isobutylene and ultra zero air

4.	PID Sensors are sensitive to high amounts of humidity and may rail at the
upper output if humidity is excessive. The SPOD contains an internal sensor
heater to minimize humidity interference.

5.	If the unit has been off for an extended period of time, it could take several
minutes to an hour for the PID readings to drop to normal operating
conditions depending on storage conditions. This stabilization may
temporarily interfere with VOC detection.

6.	Exposure to very high levels of VOCs may saturate the detector for several
minutes to an hour

10.6 eV2

+/- 20 ppb min or 10%3'4
5-10 seconds5,6
1 year+

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Cellular Specifications

Overview Parameter

Network Technology

4G/2G1

Carrier

AT&T and T-mobile2

Transport Layer

TCP

Internet Layer

IP

Application Layer

HTTP and MQTT

Data Transfer Method

HTTP POST or MQTT Topics

HTTP Content Type

application/x-www-form-urlencoded

HTTP Body Field Identifiers

&ID, &MODULE, &STAT, &DATA

MQTT Content Type

JSON

MQTT Tags

"deviceld", "time", "iodb"

Post Location

Adjustable in Menu

APN

Adjustable in Menu

TLS/SSL

HTTPS and MQTTS with server
authentication3

Notes:

1.	4G CAT Ml and NB-loT

2.	Modem is pending Verizon certification

3.	Client authentication possible with additional development.


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Sensor Exterior Features (Front Exterior)

Cellular Antenna —*¦

Power/USB Port
PID Assembly

Anemometer

Power Switch

Auxiliary Port


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Sensor Interior Features (Front Interior)


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Sensor Interior LED Indication

Cellular Status: Red LED if failure, Green LED if successful

Charging Status: Green LED if Charging

Calibration Mode: Solid/Flashing Blue LED in Calibration

Sensor Status: Red LED if initialization failure (PID or Weather Station)
SD Card Status: Red LED if failure, Green LED if successful

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Quick Start Deployment Guide (USB Cable & Computer)

It is recommended to use a computer and the supplied USB cable when setting up
the sensor unit to verify the operation of the sensors, system output, and cellular
data connectivity (if applicable). If no cable and computer are available, please
see the next page.

Unpack the sensor unit and check for any physical damage or obstructions at the
sensor openings. Open enclosure cover and check for any loose or damaged
components. Make sure all wires are securely fastened as shown in the internal
sensor view on page 7.

1)	Hook up USB cable sensor and initialize terminal connection. Power on unit
and verify that the SD card was detected and initialized.

2)	Verify the sensor outputs are reasonable or trending toward reasonable
values keeping in mind the stabilization time for sensors that have been
powered off or exposed to high VOC concentrations. Additionally, it may
take up to 30 seconds for the ultrasonic anemometer to report valid
environmental data. For information on USB headings and field
identification, please see page 10.

3)	When installing orient the weather sensor such that it is pointing North.
Failure to do this will result in arbitrary wind direction. The North direction
is indicated with a notch on the ultrasonic anemometer base. See page 11
for anemometer instructions. Never rotate the anemometer from the top
or severe damage will occur.

4)	After verifying functionality remove the USB cable. If planning to run in
USB mode, install a power adapter or a solar panel for long term
deployment applications. Otherwise, power cycle the SPOD, then install a
power adapter or a solar panel for long term deployment applications.

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Quick Start Deployment Guide (No Computer)

Unpack the sensor unit and check for any physical damage or obstructions at the
sensor openings. Open enclosure cover and check for any loose or damaged
components. Make sure all wires are securely fastened as shown in the internal
sensor view on page 7 and refer to the LEDs indicated on page 8.

1)	Power on unit. The illuminated switch should turn on. If the switch does
not illuminate, inspect all wiring connections and charge battery.

2)	Verify that the SD card was detected and initialized with the SD status LEDs

3)	Verify the absence of sensor errors with sensor status LED.

4)	If HTTP or MQTT protocol is selected verify successful initialization after
startup with Cellular status. If PERIODIC protocol is used wait for required
amount of time before cellular post.

5)	If power is hooked up, wait for 1 minute after power up to verify the
charging status LED is illuminated. Please note that if the battery is
completely full the charging status LED will not illuminate.

6)	When installing orient the weather sensor such that it is pointing North.
Failure to do this will result in arbitrary wind direction. The North direction
is indicated with a notch on the ultrasonic anemometer base. See page 11
for anemometer instructions. Never rotate the anemometer from the top
or severe damage will occur.

7)	After initialization is complete the illuminated switch will flash once per
second to indicate normal operation

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USB Output Headings and Description

USB Heading Description	Units/Format

DATE

Local Date and Time

MM/DD/YY HH:MM:SS (24H)

PID1

Field 1, Sensor 1 VOC

PPB



Field 2, Sensor 1 Raw

mV

PID21

Field 1, Sensor 2 VOC

PPB



Field 2, Sensor 2 Raw

mV

T

Temperature

°C

RH

Relative Humidity

%

P

Pressure

mBar

WS

Wind Speed

mph

WD

Wind Direction

Degrees

TC

Field 1, Sensor 1 Temp

Arb Units



Field 2, Heater 1 Output

Arb Units



Field 3, Sensor 2 Temp1

Arb Units



Field 4, Heater 2 Output1

Arb Units

BATT

Battery Voltage

Volt

CHRG

Charging Current

mA

RUN

Operating Current

mA

TRIG

Field 1, Trigger Flag

0 or 1 if threshold exceeded



Field 2, Trigger Counter

Adjustable



Field 3, Sample Flag

0 or 1 if sample acquired

LAT2

GPS Latitude

Degrees

LON2

GPS Longitude

Degrees

Notes:

1.	The control circuit board is designed to support a second sensor.
Additional parameters will show up in the output if a dual sensor unit is
configured by the factory.

2.	GPS is not enabled on all units. Please contact Sensit to enable GPS.

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Ultrasonic Anemometer Mounting Instructions
Installing (Figure 3)

CAUTION: The reflector plate and the waterproof film found in the wind channel of
the Weatherstation Instrument are essential to its operation. Be careful not to
scratch the plate, puncture the film, or damage (hem in any way.

CAUTION: The Weatherstation Instrument must be installed upright and vertical,
/>or tilted to one side. It must be level and plumb. IF the Weatherstation Instrument
is tilted from the horizontal plane, it may introduce errors in Uie compass and wind
readings.

CAUTION: To accurately measure the wind direction and heading, the alignment
notch on the Weatherstation Instrument must be pointed correctly.

•	Moving vehicle/boat—The alignment notch must point forward and be
parallel to Ihe centerline of the vehicle/boat.

•	Stationary surface—It is recommended that the alignment notch point toward
true north.

CAUTION: Tighten or align the WeatherStalion Instrument by grasping the tower
housing below the reflector plate. Hand tighten onty.

•	Do not rotate the cap. Turning it may sever internal connections and void the
warranty.

•	110WXS, 150WXRS, 150WXS—Do not grasp the solar-radiation shield. The
louvers may break.

CAUTION: If you use a thread lock, use Teflon pipe-lhread tape. Do riot use a
liquid thread lock as if may weaken the plastic, causing it to swell and crack.

side view	bottom view

humidity sensor -

— cap

healer

waterproof film

wind channel

(wtare a* trairels
through Ihe unit)

reflector plate

(healcdl

lower housing

alignment.
notch

Figure 3. Weatherstation Instrument with heater (t20/220WXH shown)

Cqay*gtn C 2006 ¦ 3018 Ar
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Tripod Setup and Installation (Optional)

1)	Remove protective rubber feet if installing outdoors

2)	Install pole on tripod. Pole mounting attachment may differ from image
below.

3)	Set leg height of tripod and spread legs with a minimum of 30° from
perpendicular

4)	For added stability in high wind or long-term deployments place sandbags
against all legs

Catch tab with
bag to hold down

t

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5)	Use the shorter %" long screw to attach pole mount to back of SPOD

6)	Use the longer 1V" long screw + nut to tighten on pole

7)	Tighten sufficiently to prevent rotation

8)	Place SPOD as far up as possible on pole to avoid blocking anemometer

Note: The images below are used for reference. SPOD appearance will differ
from image below.

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Solar Panel Setup and Installation (Optional)

1)	Lift up on side with 2 knobs to unfold panel

2)	Fold down angular supports on both sides and remove 2 knobs on bottom

3) Reattach knobs vertical angular supports on both sides (flat washer, lock
washer, wing nut)

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4)	Place solar panel on ground and fasten to ground or add ballast if possible
(recommended to avoid wind damage and theft)

5)	Avoid shadowing on panel as much as possible as this will drastically reduce
panel output power and efficiency

6)	Route cable to SPOD unit

7)	Plug cable into SPOD "Power/USB" connection

8)	Power on SPOD unit

Note: Alternative solar mounts and solar panel extension cables can be purchased
from Sensit. Please contact Sensitfor more information if your application
requires an alternative solar mounting setup.

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USB Communication & Configuration Mode (Sensor)

The SPOD units allow for the reconfiguration of several parameters pertaining to
the operation of system. Adjustment of these parameters is only accessible for a
short period of time after powering on the sensor (~10s). These parameters are
stored in non-volatile memory and are retained during subsequent power cycling.
Documentation of these parameters is listed below.

Required Components:	

-	SPOD Unit

-	USB data cable

-	Computer with a serial port terminal software program (e.g. CoolTerm)

Sensor Quickstart Instructions	

1) Connect the USB cable to the SPOD and computer and establish the
communication link in the terminal software.

2) Turn on power switch and observe initialization process. After initializing the
microcontroller and printing SPOD information, the system will system will
prompt the user to:

"Enter Configuration Mode? (YES)"

3) Configuration mode allows access to configuration settings and system
settings. To enter configuration mode type Yes at the prompt and hit enter.
The menus are all text-based and easy to follow. The following list contains all
the adjustable within the menu:

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Menu Item

Description

Location

CELLULAR
DEFAULT
DISPLAY

OFFSET
POWER
SAMPLE

GPS
HEAT

TIME
EXIT

System Default Settings
Prints Current Settings

Power Settings
Trigger Sample Settings
Time Settings
Exit Menu

Sensor Heater Settings
Sensor Offset Setting

Common settings

GPS Settings

Root Menu
Root Menu
Root Menu
Root Menu
Root Menu
Root Menu
Root Menu
Root Menu
Root Menu
Root Menu

Detailed Root Menu Information

Cellular: Contains all settings associated with the cellular modem. This is
required for communication with any online servers.

Default: Resets all options to the factory default. Not recommended without
consulting Sensit.

Display: Displays all current settings in the terminal window. An example print
out is shown below. Please not that system settings may differ from device to
device depending on the application.

System DATE,08/09/19 11:57:06

Sensor ID: SPOD00100

Battery Voltage: 13.74

Power Source: AC Power

Output Mode: Streaming

Communication Mode: Cellular

Network Selection: Automatic

Cellular Protocol: MQTT v3.1.1 with TLS

Publish Topic: "devices/SPODOOlOO/messages/events/"

Subscribe Topic:

Output Data Rate: 10

Cellular Output Ratio: 120

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Server Address: sensit-test-hub.azure-devices.net
Access Point Name: zipitwireiess.com.attz
GPS Mode: Interval
Sensor Heater: Enabled
Temp Set: 15

Dew Point Control: Disabled
Humidity Threshold: 80
Temp Set: 15

PID1 Offset Value (ppb): 0.00
Sample Trigger Value (ppb): 500
Trigger Average Time (sec): 10
Sample Collection Time (sec): 30

GPS: "ENABLE" or "DISABLE" the GPS. Depending on the cellular data protocol
and output mode, the user may be presented with additional options. If cellular
output is disabled or if PERIODIC protocol is selected the GPS mode will default to
SINGLE (see below). If cellular output is enabled and MQTT or HTTP protocol are
enabled the user can select between the following GPS settings:

"CONSTANT": GPS is always on and fixing position (Highest power draw)
"INTERVAL": GPS turns on at and interval determined by "RATIO"x"ODR"
"SINGLE": GPS turns on at power up and remains off until system is reset

HEAT: Adjust "CONSTANT" or "HUMID" heat settings. The "CONSTANT" setting
means that the sensor heater is on at all times if enabled. The "HUMID" setting
means that the sensor heater is on only if humidity exceeds a predefined
threshold. If either option is enabled the user will be prompted to adjust the
heater setpoints and for the "HUMID" option the user will be prompted to adjust
the humidity set point. Both options could be enabled simultaneously to produce
different heater setpoints depending on the humidity level. "CONSTANT" heat is
enabled by default at 15°C above ambient.

OFFSET: Adjust the baseline of the PID sensor up or down by a constant value.

OUTPUT: This menu contains settings that modify the output characteristics of
the sensor.

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POWER: Select "SOLAR" and "AC" power. If "SOLAR" is selected the unit will try
to charge the batteries whenever power is present. If "AC" is selected the system
will maintain the battery voltage in the middle of its range to extend battery life.
It is very important that "SOLAR" is selected for remote power application.

SAMPLE: Control the behavior of the auxiliary port. The port is configured to
supply power to a valve to trigger sample collection if the PPB reading exceeds a
predefined threshold for a predefined amount of time.

TIME: Set the system date and time. If cellular mode is enabled this will happen
automatically when the device connects. Note that the initial data may have the
wrong date and time until the clock adjusts.

EXIT: Leave the root menu and starts system operation
Detailed Cellular Menu Information

Menu Item	Description	Location

APN

Carrier APN Setting

Cellular Menu

CREDENTIALS

MQTT Username and Password

Cellular Menu

HOST

Server Location Address

Cellular Menu

NETWORK

Cellular Network Configuration

Cellular Menu

PROTOCOL

Data Transfer Protocol

Cellular Menu

RATIO

Number of Samples to Buffer

Cellular Menu

SIGNAL

Apply settings and check signal

Cellular Menu

TLS

Activate TLS, Load Server Cert

Cellular Menu

TOPICS

MQTT Topics

Cellular Menu

EXIT

Exit Cellular Menu

Cellular Menu

APN: Set the required APN for data access on the installed sim card. Please note
that the APN text entry might be case sensitive

CREDENTIALS: Set the require USERNAME and PASSWORD require for MQTT
data access.

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HOST: Set the server address to send the data to. The target server must be
configured to accept the data.

NETWORK: Define network behavior of the cellular module. AUTO mode is
enabled by default and under most circumstances will work well. If required it is
possible to force the modem to only look for "CAT Ml", "NB loT", or "2G" service
instead of scanning for all network options. It is required to run "SIGNAL" option
after adjusting network settings. Contact Sensit for more information.

PROTOCOL: Set the cellular data communication protocol to the following
options:

"HTTP": Transfers data using HTTP Post protocol constantly at interval

determined by the output data rate (ODR)

"MQTT": Transfers data using MQTT publish constantly at interval determined

by the output data rate (ODR)

"PERIODIC": Buffers data according to the "RATIO" setting at the output data
rate. After the required number of samples has been collected the
modem will turn on, post all data, and then turn off. The interval of
cellular cycles is determined by "ODR" x "RATIO"

RATIO: Set the number of required samples between cellular cycles for the
"PERIODIC" cellular protocol. This value also influences GPS signal acquisition
interval for certain modes. See information of GPS for more info.

SIGNAL: Acquire cellular signal strength and network registration status. This
option also programs the modem with any changes to the NETWORK mode. After
10-15 seconds the serial terminal should display "CSQ: X,Y CREG Status: Z". A
description of X,Y, and Z follow below.

X: (0-31,99) defines the signal strength
Y: (0-7, 99) defines the data error rate
Z: (0-5) defines the network registration status

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X Value

rlBm

Meaning

0

<-113

Absolutely no Signal

1

-111

Very Weak Signal

2-10

-109 to-93

Weak Signal

10-20

-81 to-73

Moderate Signal

21-30

-71 to -53

Strong Signal

31

>-51

Very Strong Signal

99

?

Unknown/Not Detected

Y Value

Meaning



0-3

Reliable Data Link

4-5

Occasional Dropped Posts

6-7

Unreliable Data Link

99

Unknown/Not Detected

Z Value

Meaning



0

Not registered, Not Searching

1

Registered Successfully

2

Not registered, Searching

3

Registration Denied

4

Unknown Status



5

Registered Successfully, Roaming





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TLS: Enable or disable TLS encryption for HTTPS or MQTTS. For TLS
authentication the user must load a root certificate file for the server on the
microSD card. The certificate file must be named "CACERT.CER". If TLS is enabled
the terminal should display:

TLS Eanbled...Waiting to Load Cert
Deleting Old Files
Loading New Cert From SD
Cert File Found
+QFUPL: 1311,3f41

OK

Please note that the values after "+Q.FUPL" are different for different certificate
files. The first number is the number of bytes and the second number is a
checksum. The same cert file should always generate the same number of bytes
and checksum. If errors are observed verify that the certificate file is loaded on
the microSD card and properly named.

TOPICS: Set the publish and subscribe topic used for MQTT cellular protocol.

EXIT: Leave the cellular configuration menu and enter the root menu

Detailed Output Menu Information

Menu Item 		Description	Location

MODE

Output Mode Settings

Output Menu

ODR

Data Rate Setting

Output Menu

POLL

Output When Polled (any char)

Output Menu

STREAM

Output Continuously

Output Menu

EXIT

Exit Output Menu

Output Menu

MODE: Sets the communication mode of the SPOD. The following options are
possible:

"Cellular": Sends data with cellular modem at ODR and USB/Power port at 1Hz
"USB": Sends data with USB/Power Port at 1Hz

"XBEE": Sends data with XBEE (optional) at ODR and USB/Power port at 1Hz

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ODR: Sets the output data rate of the cellular modem or XBEE wireless device.
The USB port will always show data output at 1Hz

POLL: Disable streaming over USB/Port and XBEE. SPOD will return data when
receiving any character from control device.

STREAM: Continuous USB and XBEE data output at 1Hz.

EXIT: Leave the output configuration menu and enter the root menu

Detailed Sample Menu Information

Menu Item	Description		Location

SAMPLETEST

Test Sample Trigger

Sample

Menu

SAMPLETIME

Sample Acquisition Time

Sample

Menu

TRIGGERTIME

Time Above Trigger Threshold

Sample

Menu

TRIGGERVAL

Trigger Threshold Value (ppb)

Sample

Menu

EXIT

Exit Sample Menu

Sample

Menu

SAMPLETEST: Manually toggles the sample collection device for testing the setup

SAMPLETIME: Sets the duration of the sample grab. Adjustable between 1-3600
seconds

STREAM: Continuous USB and XBEE data output at 1Hz.

EXIT: Leave the sample configuration menu and enter the root menu.

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Sensor Maintenance and Calibration

Periodic Maintenance: The SPOD is a low maintenance device and is designed to
operate remotely with no user intervention. Occasional inspections for damage
and cleanliness are recommended to maintain optimum performance.

Sensor Calibration; Depending on application requirements and environmental
conditions, periodic calibrations may be required to maintain target accuracy.
Contact Sensit for ordering calibration gases, calibration hardware, and
calibration instructions.

Sensor Replacement: The PID sensor assembly is designed to be field
replaceable. Sensit recommends factory service when replacing the sensor to
ensure overall sensor performance. Contact Sensit for more information.

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Hardware and Software Installation Guide

1)	Download drivers for FTDI Serial Adapter and install drivers
http://www.ftdichip.com/Drivers/VCP.htm

2)	Open serial terminal program of your choice. CoolTerm is recommended and
instructions for using CoolTerm are found below. CoolTerm is available for
Windows, Mac, and Linux. CoolTerm can be downloaded for free from here:

http://freeware.the-meiers.org/

1)	Extract 'Software_CoolTerm' to the directory of your choosing. To avoid
certain permissions issues do not extract into "Program Files". It is
recommended to extract to the desktop if possible.

2)	Open the 'CoolTerm' application. You may receive an error indicating that
no serial ports are found depending on what is hooked up to the computer.
Click okay to continue.

CoolTerm

Version L4.6 (Build 322)

Copyright © 2007 - 2018 Roger Meier.



Jk

No Serial Ports found.

Your system currently does not have any serial ports. Unless at least one
serial port is added to the system, this application will not be usable.

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3) Click 'Options' as shown below

a. 'Serial Port' options should open by default. If not, select Serial Port
options from the list of available options as shown below. All default
options should be correct but please verify. Click on 'Port' dropdown
list and make note of any available ports. Plug in the USB cable and
wait for hardware installation to finish. Click "Re-Scan Serial Ports".
The newly added port is the USB cable. Select this port.

4? CoolTerm O

File Edit Connection View Window Help
New Open Save

uri

(9

Connec

COM34 / 9600 8-N-l
Disconnected

Connection Options (CoolTerm_0)

Serial Port Options

Serial Port

Terminal
Receive
Transmit
Miscellaneous

COM34

9600

Port
Baudrate:

Data Bits:	|8

Parity:	[none

Stop Bits:	fl

Flow Control:	O CTS

~	dtr

~	XON

Initial Line States when Port opens:
$ DTR On ( DTR Off
(§> RTS On O RTS Off

~

Re-Scan Serial Ports

Cancel

-OK	)

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b. Select 'Terminal' options from list of available options and select
'Line Mode' as shown below. Line mode adds a text entry bar at the
bottom of the screen that is useful for sending commands to the
connectedsensor.

n^n:

(9



U I



HEX

!©

New Open Save Connect conm t

Clear Data Options

View Hex j Help





it Connection Options (CoolTerm.O)

No Serial Port
Disconnected

Serial Port

Terminal

Receive

Transmit

Miscellaneous

Terminal Options
Terminal Mode:

Raw Mode
• iLine l\

Enter Key Emulation: ® CR+lf
OCR
0LF

Handle Bell Character
ETJ Local Echo

Replace TAB key with spaces
No. of spaces:	4

ASCII View Options

L/j Convert Non-printable Characters

E Handle Backspace Character

Cancel 1 I OK I

F

R

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c. Select 'Receive' options from list of available options and check
"Ignore Receive Signal Errors". Selecting this option reduces the
possibility of the serial connection closing upon a received serial
error such as connecting or disconnecting the cable or power cycling
the unit.

New Open Save ! Connect

* J! 0 ®

Clear Data Option*. View Ho Help

4 Connection Options (CooJTermJ))

COM25/
Disconnected

Serial Port

Terminal

Receive

Transmit
Miscellaneous

Receive Options

Loop back receded data
\ J Ignore receive signal errors

Receive Buffer Sue

10000

Capture Text Options
Captui* format:	RmOlU

Add hmestampi to received data
J i Wait for termination string
Termination String (Hex):

Type Absolute Date and Time

00 OA

Capture Local Echo

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4) To avoid having to configure the terminal every time you open it, you have
2 options to save the configuration as shown in Figure 4.

a.	Click "Save As" and save the connection settings as a file that you can
share or store on the computer

b.	Click "Save As Default" to change these settings to the default
settings when starting the program. If you are running off the CD this
option will give you an error as there is no default file.

fcdit Connection View Window Help

m

|| ~ N**

Open...
0 Clcwt Window

& Sjvt-.
0 Save As...

S*v« Ai Oefauft

Preftftnces.

Lut

& CooITerm.O

Ctrt*N
Ori-O
CtrKW

cm»s

Ctfl*&hi(l«S
Oil* Alt *S

\ %

HFX

©

Clear D«t« Options View Ho Hdp

: ,T< • cosr^nl h«r«. Xen&itute by pressing tf.'TLR.

COM25 / 4800f'N>l
Disconnected

V TX \J RT> u DTR U 0C0
O RX (j CTS DSR O W

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5) Coolterm can be configured to record all data received over serial. This will
be useful for evaluation purposes.

a.	To start a capture go to 'Connection' dropdown menu -> Capture to
Textfile -> Start or hit Ctrl-R (S£-R). Enter a file name and click save.

b.	To stop the capture navigate back to the menu entry and click stop or
hit Ctrl-Shift-R (36-Shift-R)

df CoorTefm_0

Connection] View Window Help

roi rsw^

~

\J' Connect

Options...

Reset Port
Send Break
Rush Serial Port
~ Send String...

Send Textfile...
Capture to Textfile

~

Ctrl+K
Ctrl+1

Ctri+B
Ctrl+F
Ctrl+T

Ctrl+Shift+T

ata | Options

H

©

l|
>

Help

•

Start-

Ctri-f-R



Pause

Ctrl* Alt*-R



Stop

Ctrl* Shift* R

No Serial Ports found
Disconnected

O TX
Q RX

O RTS (J DTR Q DCD

O as O dsr o ra

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Warranty

Your SENSIT SPOD is warranted to be free from defects in materials and workmanship for a period of one year after purchase.
If within the warranty period the instrument should become inoperative from such defects the instrument will be repaired
or replaced at our option. This warranty covers normal use and does not cover damage which occurs in shipment or failure
which results from alteration, tampering, accident misuse, abuse, neglect or improper maintenance. Proof of purchase
may be required before warranty is rendered. Units out of warranty will be repaired for a service charge. Internal repair or
maintenance must be performed by a Sensit Technologies authorized technician. Violation will void the warranty. Units must
be returned postpaid, insured and to the attention of the service department for warranty or repair.

This warranty gives you specific legal rights and you may have other rights which vary from state to state.

Sensit Technologies
851 Transport Drive
Valparaiso, Indiana
46383
USA

Tel: 219/465-2700
Fax: 219/465-2701

Email: info@gasleaksensors.com
Web: www.gasleaksensors.com

MADE IN THE USA

WI1M GLOBALLY SOURCEO COMPONENi!

SENSIT SPOD Sensor Operation Manual and Configuration Guide

Revision 8-12-2019


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Appendix F: Copy of ERG's current National Environmental Laboratory
Certification for EPA Method TO-15 analysis.

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Texas Commission on
Environmental Quality

NELAP - Recognized Laboratory Fields of Accreditation

pRECo

Eastern Research Group, Inc.

Certificate:
Expiration Date:
Issue Date:

T104704426-19-10
6/30/2020
7/1/2019

601 Keystone Park Drive, Suite 700
Morrisville, NC 27560-6363

These fields of accreditation supercede all previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.

Matrix: Air & Emissions
Method EPATO-15

Analyte

AB Analyte ID

Method ID

1,1,1-Trichloroethane

FL 5160

10248803

1,1,2,2-Tetrachloroethane

FL 5110

10248803

1,1,2-T richloroethane

FL 5165

10248803

1,1-Dichloroethane

FL 4630

10248803

1,1 -Dichloroethylene

FL 4640

10248803

1,2,4-T richlorobenzene

FL 5155

10248803

1,2-Dichlorobenzene

FL 4610

10248803

1,2-Dichloroethane (Ethylene dichloride)

FL 4635

10248803

1,3-Dichlorobenzene

FL 4615

10248803

1,4-Dichlorobenzene

FL 4620

10248803

Acetonitrile

FL 4320

10248803

Acryionitrile

FL 4340

10248803

Benzene

FL 4375

10248803

Carbon tetrachloride

FL 4455

10248803

Chlorobenzene

FL 4475

10248803

Chloroethane (Ethyl chloride)

FL 4485

10248803

Chloroform

FL 4505

10248803

Chloroprene (2-Chloro-1,3-butadiene)

FL 4525

10248803

cis-1,2-Dichloroethylene

FL 4645

10248803

cis-1,3-Dichloropropene

FL 4680

10248803

Ethylbenzene

FL 4765

10248803

Methyl bromide (Bromomethane)

FL 4950

10248803

Methyl chloride (Chloromethane)

FL 4960

10248803

Methyl isobutyl ketone (Hexone) (MIBK)

FL 4985

10248803

Methyl methacrylate

FL 4990

10248803

Methyl tert-butyl ether (MTBE)

FL 5000

10248803

Methylene chloride (Dichloromethane)

FL 4975

10248803

Styrene

FL 5100

10248803

Page 1 of 2


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Texas Commission on
Environmental Quality

NELAP - Recognized Laboratory Fields of Accreditation

Eastern Research Group, Inc.

Certificate:
Expiration Date:
Issue Date:

w *

Hp

T104704426-19-10
6/30/2020
7/1/2019

601 Keystone Park Drive, Suite 700
Morrisville, NC 27560-6363

These fields of accreditation supercede all previous fields. The Texas Commission on Environmental Quality urges customers to
verify the laboratory's current accreditation status for particular methods and analyses.

Matrix: Air & Emissions

Toluene

FL

5140

10248803

trans-1,3-Dichloropropylene

FL

4685

10248803

Trichloroethene (Trichloroethylene)

FL

5170

10248803

Vinyl chloride

FL

5235

10248803

Xylene (total)

FL

5260

10248803

Page 2 of 2


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Jon Niermann, Chairman
Emily Lindley, Commissioner
Toby Baker, Executive Director

Texas Commission on Environmental Quality

Protecting Texas by Reducing and Preventing Pollution

June 20, 2019
mai DCMD 0D57 faODS TSS2 75

Ms. Donna Tedder
Eastern Research Group, Inc.

601 Keystone Park Drive, Suite 700
Morrisville, NC 27560-6363

Subject: Accreditation renewal

Ms. Tedder:

I am writing to congratulate you and the staff of Eastern Research Group, Inc. Based on
your application and primary NELAP accreditation from the state of Florida, pursuant
to authorization from the Executive Director of the Texas Commission on
Environmental Quality, the Program Manager of the Quality Assurance Section has
renewed your laboratory's secondary NELAP accreditation.

I am enclosing the new accreditation certificate and fields of accreditation listing.
Please review the enclosures for accuracy and completeness. Your laboratory's
accreditation is valid until the expiration date on the certificate and scope, contingent
on continued compliance with the requirements of the state of Texas as well as those
of your primary accreditation body.

Please contact me by electronic-mail at frank.iamison@tcea.texas.gov or telephone at
(512) 239-3754 if I can provide any additional information or assistance.

Data and Records Specialist
Enclosures

P.O. Box 13087 • Austin, Texas 78711-3087 • 512-239-1000 • tceq.tcxas.gov

How is our customer service? tceq.texas.gov/customersurvey

primed on recycled paper


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Appendix G: Sampling Plan.

Denka Performance Elastomer Facility SPod Monitoring Sampling Plan

Eastern Research Group

Project Information

Project Name:

SPod Monitoring at the Denka Performance Elastomer Facility

Location:

LaPlace, Louisiana

Project Number:



Project Leader:

Dan Hoyt, EPA OECA

Preparation Date:

January 31, 2020



Project Implementation

Sampling:

Scott Sholar (ERG), David Bordelon (Weston Solutions)

Analysis:

SPod monitoring and VOCs by EPA Compendium Method TO-15

Introduction/Background

This sampling plan outlines the field work and monitoring requirements necessary to support
an EPA Headquarters and EPA Region 6 monitoring of the Denka Performance Elastomer
facility in LaPlace, Louisiana. This sampling plan is included as Appendix G of the QAPP for
SPod Monitoring at the Denka Performance Elastomer Facility in LaPlace, Louisiana.

Denka Performance Elastomer LLC ("Denka") owns and operates a neoprene manufacturing
facility (the only neoprene production facility in the U.S.) at the Pontchartrain Works Site in
Laplace, Louisiana (the "Facility"). Denka acquired the Facility from E.I. du Pont de Nemours
and Company (DuPont) on November 1, 2015. On December 17, 2015, EPA released the results
of the 2011 National Air Toxics Assessment (NATA). These results indicated the highest
modeled cancer risks in the country were associated with an area in St. John the Baptist Parish,
Louisiana, attributable to chloroprene (a likely human carcinogen) emissions from Denka's
Facility. EPA Region 6 began monitoring the air at six locations in the surrounding community
in May 2016 (see Figure 1-1), conducted a Clean Air Act (CAA) inspection of the Facility in
June 2016, and subsequently referred CAA violations to the Department of Justice (DOJ) for
civil enforcement.

Pursuant to a January 2017 Louisiana Department of Environmental Quality (LDEQ)
Administrative Order on Consent ("State AOC"), Denka installed a Regenerative Thermal

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Oxidizer (RTO) and other controls, designed to achieve an 85% reduction in Denka-reported
chloroprene emissions. While the RTO's operation has decreased ambient concentrations of
chloroprene in the community, ongoing monitoring results, presented in Table 2-3, indicate that
ambient chloroprene concentrations remain higher than 0.2 microgram per cubic meter (|ig/m3),
the inhalation exposure concentration associated with an estimated 100-in-l million lifetime
cancer risk (based on the current inhalation unit risk value from EPA's Integrated Risk
Information System). A 100-in-l million lifetime cancer risk is generally described as the upper
limit of acceptability for purposes of risk-based decisions at EPA.

Project/Task Description

Work for this project will be accomplished in phases. Information gathered from each phase
will inform the next phase. This sampling plan was written for SPod Monitoring to detect SIS
emissions in conjunction with canister sampling to measure SIS emissions surrounding the
Denka Facility. The first phase will be the field demonstration using Sensit Technologies'

SPod systems for continuous monitoring and collecting canister samples. Once the monitoring
systems are operating, the data obtained from the SPod monitoring will be used in conjunction
with data obtained from SPod triggered canister sampling to identify potential emissions.

Proximity to source from sampling locations for SIS detection will be evaluated throughout
monitoring. If it is determined that certain sampling locations are not suitable, alternative
sampling locations may be identified.

The effectiveness of an SPod-type sensor to detect SIS emissions is impacted by the proximity
of potential emission sources. In this project, the SPod sensors will be deployed at a variety of
distances around the Denka Facility, at the locations of the ambient air sampling sites. In
order to employ the SPod systems, a field demonstration is essential to verify the effectiveness
of the sensors at the identified locations.

The project involves installation of six Sensit SPods. These units are equipped with
photoionization detectors (PID) and with event-triggered evacuated canister systems. The
SPods will be installed at the current community sampling sites surrounding the Facility, with
the intent to detect elevated concentrations of total VOCs in the air, which may include
chloroprene. The SPod PIDs are capable of detecting VOCs with ionization energies of 10.6
eV or below. The SPods will not be used in potentially flammable areas. Following the pre-
deployment QA testing, field testing near the Denka plant will include two phases:

The Initial phase consists of six SPods deployed separately at the six current community
sampling sites surrounding the Facility for approximately two months. The data gathered in
this phase will be processed and used to assess the sampling equipment performance and

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develop a trigger concentration for canister samples and averaging period for that
concentration. A seventh SPod may be added as a collocate at one of the sites.

The Sampling phase consists of six SPods deployed separately at the six current community
sampling sites surrounding the Facility for at least four months. The purpose of this phase is to
collect data and determine if SIS can be measured. During this phase, the plan is to collect
continuous SPod data and collect event triggered 24-hour canister samples at the previously
determined trigger concentration for at least four months. The determined trigger
concentration is subject to change as more data becomes available. The entire project will be
evaluated at four months to determine if it should continue for a longer duration and how
much more sample collection time will be required. A seventh SPod may be added as a
collocate at one of the sites.

In addition to the commencement of this monitoring project, EPA will seek additional

detailed operational and maintenance information from Denka to assist assessment.

Data Quality Criteria/Data Review/Assessment

Overall measurement quality objectives (MQOs) for this project can be defined in terms of the
following data quality indicators:

Precision - a measure of mutual agreement between individual measurements
performed according to identical protocols and procedures. This is the random component of
error.

Accuracy - in terms of bias is the systematic or persistent distortion of a measurement
process that causes error in one direction. Bias is determined by estimating the positive and
negative deviation from the true value as a percentage of the true value.

Detectability - the determination of the low range critical value of a characteristic that a
method-specific procedure can reliably discern.

Completeness - a measure of the amount of valid data obtained from a measurement
system compared to the amount that was expected to be obtained under correct, normal
conditions.

Comparability - a measure of the level of confidence with which one data set can be
compared to another.

Due to some known limitations in the SPod sensor's capability/environmental factors, the
SPod is not expected to provide 100% data completeness; 70% is the anticipated completeness


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target. There is a potential for project MQOs to change based on data collected in the Initial
Phase.

Sampling and Measurements Design/Methods

Six SPods will be deployed at the six community sites surrounding the Facility to collect
continuous SPod data. Weston Solutions field personnel will visit each site, initially once every
six days. During the site visits the sampling equipment will be checked.

A seventh Sensit SPod will be a spare that could be used as a replacement, should any SPod
needed replacement. Any changes made to SPod set-up must be recorded on a SPod Field
Deployment Form from MOP 3010. A copy of all forms completed on-site must be sent to the
ERG Task Manager. The procedures for the SPod preparation, initial evaluation, deployment,
and use are described in MOP 3010. The Field Deployment Form is located in Section 7 of MOP
3010.

In the Initial phase sampling, six SPods will be deployed at all of the six current community
sampling sites. The field contractor will visit each monitoring location site every six days
initially for a potential of up to four triggered canister samples per site every six days. The data
collected in the initial phase will allow potential plume measurements to be compared between
the SPods and compared with associated triggered canister samples. A seventh SPod unit will be
a spare that can be used to replace one of the SPods, if one should need to be taken out of service.

During the two-month Initial phase, the triggered 24-hour canister samples will be analyzed as
follows:

•	For the first two weeks, the list of target compounds will increase from chloroprene-
only to fifty-nine VOCs by EPA Method TO-15. Table 3-1 displays the full list of
compounds and ERG's current MDLs.

•	Thereafter,

o when an SPod detects a plume (i.e. a predetermined concentration level
has been exceeded), the automatically triggered canister sample will be
	analyzed for chloroprene-only. Other key VOCs may be analyzed for on

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a case-by-case basis, if it is determined by the Project Lead to aid with
detection of SIS.

o when no plume is detected by the SPods, no canister sample will be
analyzed.

During the Initial phase, the following will be accomplished:

•	Determine a trigger concentration at each monitoring location site and averaging
period for the concentration,

•	Assess the sampling equipment performance for determining chloroprene plumes,

•	Update SPod data processing/analysis method, if needed, to aid characterization.
Current data analysis method is in MOP 3010 (software upgrades may have to be
implemented based on data analysis before Sampling phase).

•	Demonstrate the automated canister sampling trigger and remote trigger adjustment
capabilities are functioning correctly. As such, the initial canister sampling trigger
level will be based on initial monitoring PID monitoring data, at a level a canister
sample would be expected to be triggered during the first week of deployment. Each
trigger level will be adjusted higher, after at least one canister sample has been
collected at each monitoring location. Trigger levels will be assessed throughout the
project, including during the initial phase.

For the Sampling phase, the SPods will continued to be deployed at the six current community
sampling sites (see Figure 3-1 for overhead photograph of community sampling locations) to
collect continuous data for at least four months. The basic purpose of the Sampling phase is to
collect continuous SPod data, to collect event triggered canister samples, and to determine if SIS
can be detected.

Sampling/Handling Custody

ERG and Weston will use the sampling/handling custody procedures described in the Denka
Elastomer SPod Monitoring QAPP.


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Analytical Methods

ERG will also use EPA Compendium Method TO-15 to analyze the canister samples for
VOCs, more specifically chloroprene.

Quality Control Procedures

ERG and Weston will follow quality control procedures applicable to this monitoring program
as discussed in the Denka Elastomer SPod Monitoring QAPP.

Instrument Maintenance/Calibration

The GC/MS instruments are calibrated with National Institute of Standards and Technology
(NIST)-traceable TO-15 standards minimally every 3 months and use internal standards to
monitor instrument performance. The TO-15 calibration gas stock cylinders are recertified
annually by the vendor. The initial calibration is verified daily with a second source continuing
calibration standard.

For the SPods, calibration will be performed by Sensit Technologies. The calibrations will be
assessed by ERG and Weston via a series of "bump" tests conducted prior to, during, and after
monitoring in LaPlace, LA. "Bump" tests conducted during monitoring will be on a monthly
basis unless otherwise directed by EPA's OECA Project Leader.

Safety Procedures

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The safety hazards which may be encountered and the personnel protection requirements for
field activities are described in the Site Health and Safety Plan of the Denka Elastomer SPod
Monitoring QAPP. EPA, ERG and Weston will follow the safety procedures which are
documented in the ERG Health and Safety Program and applicable provisions of the EPA

Safety, Health, and Environmental Management Guidelines (1997 edition), the
NIOSH OSHA USCG EPA Occupational Safety and Health Guidance Manual for Hazardous
Waste Site Activities (1985 edition) and theEPA Standard Operating Safety Guides (1992
edition)..

Prepared

by:

Work Assignment Manager:v

Date: 03/06/2020

Reviewed

by:

Program Manager: ^3/uuais

Date: 03/06/2020

Approved

by:

EPA Team Leader: DdH tfotft

Date: 03/06/2020

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Appendix H: Health and Safety Plan.

SITE HEALTH AND SAFETY PLAN
****** General Information

1.

Project Title:

SPod Monitoring at the
Denka Performance
Elastomer Facility

Project Number



2.

Location

LaPlace, Louisiana



3.

Description of Field Activities:

Monitor Fugitive Emissions with Continuous Monitor



4.

Date of Field Activities:

February 2020 through August 2020

5.

EPA Personnel

Dan Hoyt



Project Lead



ERG Personnel

Scott Sholar



Task Manager / Team
Leader



Weston Solutions
Personnel

David Bordelon



Task Manager / Team
Leader

6.

All monitoring personnel must have undergone health and safety training.

Emergency Information for LaPlace. LA

7.

Ambulance:

Shepard Ambulance

Phone:

911/Not Listed

8.

Hospital:

Ochsner Medical Complex -
River Parishes
1900 West Airline Highway,
LaPlace, LA 70068

(Emergency
Room)

Phone:

(985) 652-7000

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9.

Emergency Route:

See attached directions





10.

Fire Department:

LaPlace Volunteer Fire Department
803 Walnut St,

LaPlace, LA 70068

Phone:

911

(985)652- 1777

11.

Police:

Garvville-Reserve Police Department

1801 W Airline Hwy
LaPlace, LA 70068

Phone:

911

(985)536-2112

12.

Poison Control Center:

Poison Control Center

Phone:

1-800-222-1222

13.

Site Emergency Notification/Evacuation Method

Route identified by facility personnel

Hazard Evaluation

14.

Check all known or potential hazards:



Radiation

X

Toxics



Fire/Explosion





Corrosives



O2 Deficient



Noise



Biological





Dusts

X

Heat/Cold Stress









NOTE: DISCUSS HAZARDS AND PRECAUTIONS IN DETAIL IN WORK PLAN BELOW.

15.

Specify unusual working conditions/limitations (excavations, confined spaces, lagoons, elevated
surface, weather, darkness, etc.) *:

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Heat Stress

Heat stress is expected to be a hazard during this inspection trip. Monitoring team personnel will wear cotton clothing
under coveralls or Tyvek® as required, will drink plenty of fluids, and will monitor each other for heat stress and the
team leader will be responsible for ensuring that proper treatment is administered in case a team member develops
any of the following heat stress-related disorders. The levels of heat stress and associated symptoms are:

Heat rash which may result from continuous exposure to heat or humid air. Signs and symptoms include:

Itching skin/skin eruptions
Reduced sweating

Treatment: Keen skin clean and drv. Reduce heat c\ do sure.

Heat cramps which are caused by heavy sweating and inadequate electrolyte replacement. Many times, cramps may
not occur until after work or until the worker is sleeping. Signs and symptoms include:

—	Muscle spasms

—	Pain in the hands, feet, and abdomen

Treatment: Gentlv stretch and massaee muscles and rcolacc fluids. Rest in a cool shaded area.

Heat exhaustion which occurs from increased stress on various body organs including inadequate blood circulation
due to cardiovascular insufficiency or dehydration. Signs and symptoms include:



—	Pale, cool, moist, clammy skin

—	Heavy sweating

—	Headache and dizziness

—	Nausea

—	Fainting or fatigue

—	Elevated pulse rate (above 150)

Treatment: Rcolacc fluids: Dour cool water over face. neck, hands, arms, and less. Place worker in cool air and seek
medical care.

Heat stroke is the most serious form of heat stress. Temperature regulation fails and the body temperature rises to
critical levels. Immediate action must be taken to cool the body before serious injury and death occur. Competent
medical help must be obtained. Signs and symptoms are:

—	Red, hot, usually dry skin body core temperature 108°F (oral)

—	Lack of or reduced perspiration

—	Nausea

—	Headache, dizziness, and confusion

—	Strong, rapid pulse

—	Coma


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Treatment: Remove worker to cool area, saturate clothes with cold water, wrao worker in wet cold sheets (if
possible), monitor ABC (airway, breathing, circulation), treat for shock, and call emergency services for basic life
support (BLS) or advanced life support (ALS).

Falling Hazards

Falls are expected to be a hazard during this inspection trip. Monitoring personnel may be monitoring from the top of
tanks as tall as 20 feet high. ERG will use the attached stairways and catwalks for getting to the top of the tanks.

Electrical.

Prior to installing equipment in the field, field staff will verify that all electrical equipment and cords are in good
working condition. Field personnel will be instructed to immediately report to their team leaders any signs of
malfunctioning electrical equipment.

Animals, Poisonous Insects, and Poisonous Plants.

Field personnel should be alert for and stay clear of wild and unsupervised animals, poisonous insects, and poisonous
plants (e.g., poison ivy, poison sumac). Particularly, team member should also be aware of poisonous spiders (e.g.,
black widow).

Be aware of your surroundings, do not just blindly wander in the monitoring locations. Observation is critical to
avoidance. Learn to check around with a sweeping glance for anything that seems out of place. Your subconscious
may notice a camouflaged animal.

Snakes and other animals have many sensing devices to warn them of your presence. Make plenty of noise and
movements while entering the monitoring area to announce your presence.

Treatment: If a field staff is bitten bv a snake, rodent, or snider, thev should be taken to a medical facility
immediately for treatment. Give the medical staff as much detailed information about the animal as possible.

Describe the size, shape, and color of the animal.

* Attach specific hazard management plans, if applicable.

16.

Potential Hazards: Identified through process knowledge and review the company corporate
website.


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Routes/







Chemical/

TLV/ IDLH/

Conditions of





Odor/Visual

Physical Hazard

OSHA PEL

Exposure

Acute Symptoms

Odor Level

Description

chloroprene

OSHA TLV-

Rapidly

The substance is severely

Odorless

Odorless/Clear



TWA: lppm

absorbed by

irritating to the eyes. The



Colorless liquid



IDLH: 300 ppm

skin.

substance is irritating to







OSHA PEL: 8-hr

Can be

the skin and respiratory







Time-Weighted

inhaled as a

tract. Exposure at high







Avg: 25 ppm (90

vapor

levels could cause lung







mg/cu m)



oedema. The substance







NIOSH REL: 15



may cause effects on







Min Ceiling



several organs. This may







Value: 1 ppm (3.6



result in impaired







mg/cu m)



functions. Exposure
above the OEL could
cause death.





Work Plan

17.

The following table summarizes planned tasks, anticipated hazards, and control measures which
will be taken, including levels of protection:

Task

Hazards

Level of Protection
(A, B, C, D) and Control Measures

Setup and operate remote
monitors for VOC detection

Slip trips falls, heat related
injuries, flora/fauna related
injuries

Long-sleeved clothing and close toed shoes will be worn when
performing onsite activities.

Specific Personal Protective Equipment (PPE):

Type of Protection

Hazard

Use of PPE

Foot Protection

Feet

Onsite personnel will wear closed toed shoes at all times while
performing field work activities.

Safe Work Practices -

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Task

Hazards

Safe Work Practices

18.

Site Control/Security Measures:

Weston Solutions will visit the sites weekly and inspect
them for any disturbance. All sites are on property owned
by residents or other entities. Security will fall under
landowner's responsibility. No other site security control
measures are planned at this time but will be considered if
necessary.

19.

Decontamination Procedures (personnel hygiene, contaminated clothing, equipment, instruments,
etc.):



Good personal hvsiene will be practiced.

20.

Disposal Procedures (contaminated equipment, supplies, decontamination solutions, etc.)



NA

********************************************************************************



Approvals

This site HASP has been reviewed and constitutes the minimum anticipated safety requirements for
personnel engaged in field activities at this project site. However, the Team Leader has the authority to
change these requirements, based upon the conditions present at the site.

Approved bv:

21.

EPA Project Leader: Date:

03/05/2020

22.

ERG Team Leader: Date:

03/05/2020

23.

Weston Solutions Team Leader: Date:
t>MAd 03-05-2020




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Emergency Route to Ochsner Medical Complex from the Denka Facility in LaPlace, LA:

BELLE POINT

f

icpaiaiuiy

Q Tractor Supply Co



Wlnn-Ouie Q % Walmart Supercenter

% O	' r.nrretfl < >

| \ DuPont 9
5th Word Q	_

Elementary School * DuPont Ponchartrain Site y
Denka Performance
Elastomer

BRS Seafood Q « » s

Q Dupont Plant

n Barge ft

©

Go gle




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