1. NYS Department of Environmental Conservation Through The Probe (TTP) NYSDEC Plan for Auditing For NPAP NESCAUM MAC Meeting Troy, New Hampshire April 24 – 25, 2007

3. TTP rack Photo Shows: - line conditioner, - cooling fans (2 more in back) rotometer on right is for TTP Ozone analyzer sample line connection, - API 700E calibrator, - pull out shelf, and - API 701H zero air supply

4. Presentation line Pulling the ½” Teflon tubing through the polyolefin tubing. Heat shrinking the polyolefin tubing.

5. Initial checkout of TTP system A complete set of analyzers (SO2, CO, Ozone, & NOx) was set-up to thoroughly test system before the EPA evaluation.

6. Certification in QA Lab Front of TTP rack, with the required ozone analyzer on top Back of TP rack showing the presentation line connections

7. Certification in QA Lab The multi gas certifications were conducted using the QA Labs glass manifold.

8. Van Modifications before modifications after modifications

9. Van Modifications before modifications after modifications

10. Vehicle Equipment Full sine wave 1500 watt invertor Exhaust line, power bar, 8’ folding ramp, gas cylinder mounts

11. EPA Lab in Edison, NJ NYSDEC -TTP rack evaluation

12. SITE AUDITS:

13. NYS Department of Environmental Conservation Loaded Van Fully loaded Van - presentation line - TTP rack - plywood panels to roll rack over grass - digital recorder - travel case with supplies - multi gas cylinder (SO2, CO, NO in Nitrogen)

14. Manifold connections: EPA staff have been The DEC presentation line using a siliconized plug is connected to the manifold that is a friction fit and the by an endcap modified with a presentation line is held screw type fitting that uses a place with bungee cords viton o-ring seal. Bungee cords used for strain relief.are also used for strain relief.

15. Niagara Falls CAM

16. NYS Department of Environmental Conservation Buffalo Primary

17. NYS Department of Environmental Conservation Tonawanda

18. NYS Department of Environmental Conservation Dunkirk

19. NYS Department of Environmental Conservation PROBLEMS NOTED AT SITES There have been several findings that could lead to the reduction in significant problems during future audits. - dirty manifold- dirty sample lines - dirty connectors- dirty particulate - leaky joints filter holders - difficult access

20. Dirty manifolds CO does not appear to be affected by an accumulation of dirt. SO2 is affected in that it takes significantly longer to come to equilibration. A dirty manifold seriously degrades Ozone response (anywhere from 4% to 6% loss), A dirty manifold lowers NO2 results (approx. 2% to 4%)

21. NYS Department of Environmental Conservation Manifold Have found that even with a clean manifold the joints collect enough dirt to affect the NO2 and Ozone responses. When manifolds are cleaned, attention needs to be given to the Teflon connection between the sections of glass manifold.

22. Leaky connections leaking joint (inside), it’s not easily seen, but there is a crack in the Teflon that caused a significant cycling in the analyzer response during an Ozone audit. Chart showing looping effect caused by the leak

23. Leaky connections When joints are misaligned, rain can enter the manifold – have seen water on top of the bug screen. - in the upper photo the rubber seal is being pinched causing a leak - in the lower photo the stainless steel shield is in place, which completes the seal.

24. NYS Department of Environmental Conservation Recommendations? Sample lines -Should be cleaned or replaced annually?

25. NYS Department of Environmental Conservation Recommendations? Particulate filters ‑ have found dirty particulate filter holders can retain enough contamination to have an effect on instrument responses with NOx and Ozone. Clean annually ?

26. Sunlight Effects Sunlight has not been a problem with SO2, Ozone, or CO TTP. Sunlight appears to convert NO gas in the presentation line to NO2, It is necessary to eliminate exposure of the audit gas to sunlight. - The presentation line must be covered: - EPA uses aluminum foil ‑ tears easily, needs to be replaced frequently - DEC is using polyolefin (heat shrink) tubing ‑ has been shown to work well both in lab and initial field audits It is also necessary to cover all exposed glass manifolds: - Have been using aluminum foil - are investigating other materials (mylar, woven plastic, corrugated dryer vent, etc.

27. Sunlight Effects

28. Hidden Requirements (TTP) Must write acceptable QAPP Must write acceptable SOP’s Annual certification of TTP equipment Annual certification of TTP operator It is also recommended that a TTP audit be repeated at a site within several days of an EPA TTP audit sometime during the year

29. EPA Results 2006 Parameter sites audited range of ave. %d’s SO2 6 -0.8% to + 1.9% CO 4 -2.4% to + 0.8% Ozone 10 -3.5% to + 5.5% NO 4 -2.6% to +7.2% NO2 4 -9.4% to +6.7% NOX 4 -2.6% to +8.3%

30. NYSDEC results 2007 Parameter sites audited range of ave. %d’s SO2 6 -1.6% to + 3.2% CO 3 -1.6% to – 0.3% Ozone 3 -0.7% to + 1.1% NO 1 -3.1% NO2 1 -2.7% NOX 1 -2.5%

31. NYS Department of Environmental Conservation Recommendations When siting or modifying existing sites, a gate directly in front of the door would be very beneficial – avoids having to lift the TTP rack in and out of shelter. Keep manifolds clean, TTP audits take longer than a back of the analyzer audit (3 - 4 hours vs. 1½ -2hours) – a dirty manifold can add significantly to the time it takes to conduct the audit.

32. Manifold Replace inverted cane type manifolds with a vertical inlet

33. Manifold The use of a lower volume blower will help keep the manifold cleaner Primary CAMS came equipped with a blower that draws between 45 and 65 CFM, with a residence time of approx. 2 to 3 seconds.

34. NYS Department of Environmental Conservation Thank you, Any Questions ???