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Improved O 3 Scrubbers for Network Photometer Upgrades Ozone Transport Commission OTC Annual Meeting June 4, 2015 Princeton, NJ Will Ollison 1220 L Street, NW Washington, DC 20005 - 4070 www.api.org 1 Recent Developments in Ozone


  1. Improved O 3 Scrubbers for Network Photometer Upgrades Ozone Transport Commission OTC Annual Meeting June 4, 2015 Princeton, NJ Will Ollison 1220 L Street, NW • Washington, DC 20005 - 4070 • www.api.org 1

  2. Recent Developments in Ozone Photometer Scrubbers • Current network O 3 photometers are subject to positive interference bias (Hg, H 2 O, Aryl VOCs) raising O 3 design values Spicer et al. JAWMA 60: 1353 – 1364 (2010); Johnson et al. JAWMA 64: 360-71 (2014). • Nitric oxide-gas phase titration (NO-GPT) or heated graphite O 3 scrubbers improve both photometer accuracy (See Tech Note #40 - http://www.twobtech.com/products.htm ) and O 3 NAAQS attainment Ollison et al. JAWMA 63: 855 – 863 (2013). • FEM NO-GPT photometer or NO-chemiluminescence monitor swaps with existing FEM photometers would resolve such biases promptly. 79 FR 34734-5 (6/18/14); 76 FR 62402-3 (10/7/11) . 1220 L Street, NW • Washington, DC 20005 - 4070 • www.api.org 2

  3. EPA Proposes No O 3 Monitor Upgrades in Revised NAAQS • “Commercial availability of conventional UV-absorption O 3 analyzers is excellent…However , the technique is susceptible to potential measurement interference from mercury, some volatile aromatic hydrocarbons, water, and other compounds that sometimes occur in ambient air (Spicer et al ., 2010)… Although the interferences are substantially reduced by the use of scrubbers, the potential for interferences prevents the technique from consideration as an FRM .” • “ There will be no requirement for states to switch to NO-CL analyzers; therefore, UV absorption FEM analyzers can still be used for routine O 3 monitoring .” 79 FR 35367 (12/17/2014). 1220 L Street, NW • Washington, DC 20005 - 4070 • www.api.org 3

  4. Feasible Scrubber Upgrades to Existing Network Photometers • NO-GPT O 3 scrubbers presently remain commercially available for low-cost network photometer upgrades http://www.twobtech.com/model_GPT.htm. • NO-GPT upgraded photometer accuracy may be further improved by equally diluting both sample & reference streams with N 2 O, which is used as the photolyzed source of NO in the scrubbed reference stream. • Graphite scrubbers may also be commercially available this year, providing lower-cost but slightly less improved photometer upgrades. J.W. Birks, et al., Heated Graphite Scrubbers to Reduce Interferences in Ozone Monitors , U.S. Provisional Patent Application, 28 July 2014. 1220 L Street, NW • Washington, DC 20005 - 4070 • www.api.org 4

  5. 4-Fold Graphite Scrubber Cut in O 3 bias (ppb) vs. p-Xylene (ppb) 100 80 60 40 20 0 -20 0 200 400 600 800 1000 1200 1400 1600 2B Hopcalite Thermo Teledyne-API Graphite (100⁰C) Linear (2B Hopcalite) Linear (Thermo) Linear (Teledyne-API) Linear (Graphite (100⁰C)) J.W. Birks et al. Heated Graphite Scrubbers to Reduce Interferences in Ozone Monitors , Private Communication, 2015 1220 L Street, NW • Washington, DC 20005 - 4070 • www.api.org 5

  6. 4-Fold Graphite Scrubber Cut in O 3 bias (ppb) vs. Phenol (ppb) 200 180 160 140 120 100 80 60 40 20 0 -20 0 200 400 600 800 1000 1200 2B Hopcalite Thermo Teledyne-API Graphite (100⁰C) Linear (2B Hopcalite) Linear (Thermo) Linear (Teledyne-API) Linear (Graphite (100⁰C)) J.W. Birks et al. Heated Graphite Scrubbers to Reduce Interferences in Ozone Monitors , Private Communication, 2015 1220 L Street, NW • Washington, DC 20005 - 4070 • www.api.org 6

  7. 40 CFR Part 58, Appendix C Modification Applications • Low-cost scrubber upgrades need EPA approved 40 CFR Part 58 Appendix C modification applications from state, local, or tribal (SLT) agencies or associations (NESCAUM, MARAMA). • EPA approved vendor instrument applications apply to all monitoring sites/regions. SLT or association applications apply only to specific areas and EPA may require justified acceptable performance tests by O 3 level, season, and area. • EPA may also require added interference testing depending on the technical and geographical scope of the requested modifications. • Uncooperative vendors may choose to withhold warranty repair and vendor upgrade coverage of modified units. 1220 L Street, NW • Washington, DC 20005 - 4070 • www.api.org 7

  8. Recommendations • 40 CFR Part 58, Appendix C provides an O 3 monitor modification process for certifying FEM photometer O 3 scrubber upgrades; SLT agencies should ask EPA to facilitate such relatively low-cost photometer upgrades. • SLTs or associations (e.g., NESCAUM, MARAMA) should conduct the comparison testing needed to develop upgraded network photometer scrubber modification applications. • EPA should favorably review such applications and support cost-effective scrubber modifications to improve the accuracy of existing network O 3 photometers and to enhance O 3 NAAQS compliance. 1220 L Street, NW • Washington, DC 20005 - 4070 • www.api.org 8

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