Evaluation of the PID Analyzers Model 102 PhotoionizerTM Detector for Measuring Hydrocarbon Concentrations

Final Report

PID Analyzers, LLC

PREPARED FOR

October 10, 2004

KWA

1125 Valley Ridge Drive, Grain Valley, MO 64029, USA Voice (816) 443-2494, Fax (816) 443-2495 E-mail info@kwaleak.com, Web http://www.kwaleak.com

Ken Wilcox Associates, Inc.

Evaluation of the PID Analyzers Model 102 PhotoionizerTM Detector for Measuring Hydrocarbon Concentrations

Final Report

25 Walpole Park South Drive Walpole, MA 02081

PID Analyzers, LLC

PREPARED FOR

October 10, 2004

Preface This report describes the testing that was conducted on the PID Analyzers Photoionization Analyzers. The forms contained in this report are based on data collected using the EPA protocol "Standard Test Procedures for Evaluating Leak Detection Methods: Vapor Phase Out-of-Tank Product Detectors", EPA/530/UST90/008, March, 1990. This evaluation meets the requirements of the U.S. Environmental Protection Agency for Nonvolumetric Tank Tightness Methods for Annual Tightness Testing on underground storage tanks. The testing was conducted by Jack Driscoll at the PID Analyzers facility under the observation of Ken Wilcox. The full evaluation report and certification forms are contained in Volume 1. The data sheets for the actual testing are contained in Volume 2. Technical questions regarding this evaluation should be directed to Jack Driscoll at 508 660-5001 KEN WILCOX ASSOCIATES, INC.

H. Kendall Wilcox, Ph.D. President October 10, 2004

ii

Table of Contents
Section Preface 1.0 Introduction 2.0 3.0 4.0 5.0 Description of the PID Analyzers Model 102 Analyzer Overview of the EPA Evaluation Procedures Description of the Test Facilities Test Results and Discussion Page No Ii 1 2 3 5 6 9

6.0 Conclusions Attachment A. EPA Certification and Description Forms Attachment B. Test Data Attachment C. Addendum for Model 101 Attachment D. Previous Evaluation Listing

iii

PID PhotoionizerTM Analyzers 1.0 Introduction The Environmental Protection Agency's (EPA's) regulations for underground storage tanks require owners and operators to check for leaks on a routine basis using one of a number of detection methods (40CFR Part 280, Subpart D). To ensure the effectiveness of these methods, the Environmental Protection Agency has set performance requirements for all leak detection equipment that is used to comply with the regulations. The USEPA has developed two similar protocols for testing vapor-phase hydrocarbon analyzers.12 These two methods differ only in the types of hydrocarbons used to conduct the evaluation. These are discussed in more detail in Section 3. For this evaluation, both sets of hydrocarbons were used to evaluate the performance of the PID Analyzers equipment. To assist users of these test methods and equipment, the EPA has developed requirements for evaluating the performance of external monitoring systems. The photoionization analyzers were developed by PID Analyzers (PID) for the measurement of hydrocarbons in monitoring wells or other locations where hydrocarbon vapors might be present. These system was evaluated using procedures described in the EPA protocol "Standard Test Procedures for Evaluating Leak Detection Methods: Vapor Phase Out-of-Tank Product Detectors", EPA/530/UST-90/008, March, 1990 and a modified version developed to include actual fuels rather than a series of specific chemicals. This evaluation presents the results of the tests that were conducted on several analyzers developed by PID. Analyzers included in the evaluation were: Model 102 – Full evaluation using parts of both procedures Model 101 – Diesel fuel and Jet A only Model DL 101 – Diesel fuel and Jet A only The Model 102 is the newest unit and the 101 is the oldest. The EPA Results forms have been provided in Attachment A and the data in Attachment B. The previous evaluation and listing form for the Model 101 is provided in Attachment C and an addendum for the Model 101 using diesel fuel, Jet A and Aviation gasoline is provided in Attachment D.

1

"Standard Test Procedures for Evaluating Leak Detection Methods: Vapor Phase Outof-Tank Product Detectors", EPA/530/UST-90/008, March, 1990.
2

“Development of Procedures to Assess the Performance of External Leak Detection Services, Vapor-phase ASTM-Formatted Methods” June 6, 1990. Page 1

PID PhotoionizerTM Analyzers 2.0 Description of the PID Analyzers Model 102 PhotoionizerTM

The Model 102 Photoionizer is a portable photoionization detector that is sensitive to many hydrocarbons found in motor fuels. These systems are self-contained and consist of a sample pump, sample pump, photoionization lamp, electronic signal processing, and display. The Model 101 has an analog meter while the Model 102 and DL 101 are equipped with a digital display. All models have provisions for zero and span settings, and range selection. The normal range of concentrations range from 0.1 ppm to 3,000 ppm with extended capability of the 102 to 30,000 ppm. Previous evaluations were conducted using the Model 101 and DL-101. The results of this evaluation are summarized in the NWGLDE list of methods that have been reviewed. The testing was conducted by Carnegie Mellon Research Institute dated 11/28/01. This evaluation followed the protocol cited in reference 2.

Page 2

PID PhotoionizerTM Analyzers 3.0 Overview of the EPA Evaluation Procedures

Three types of tests are conducted as a part of the evaluation. These are briefly summarized in Table 1 for both protocols. Table 1. Vapor Phase Test Protocol Summary3 Standard Test Method March 1990 Vapor Phase Test June 1990 Vapor Phase Test (Radian Corporation, EPA Contract No. 68-033909)

X0001 – Accuracy and Response Time Five tests at each concentration

50, 250, 500, @ 1,000 ppm Benzene 2-methylbutane

50, 500, @ 1,000 ppm Unleaded Gasoline JP-4 Jet Fuel Synthetic Gasoline

X0003 – Specificity At least on test for each product at 500

500 ppm Benzene n-Butane n-Hexane Iso-butane 2-methylpentane* 3-methylpentane Toluene

500 ppm Unleaded Gasoline JP-4 Jet Fuel* Synthetic Gasoline* n-Hexane Xylene Toluene

X0006 – Lower Detection Limit Test for the smallest concentration that the detector will respond six times out of six tests. * Not used in this evaluation.

Range; 1.25 – 1,000 ppm Benzene 2-methylbutane

Range 10 – 1,000 ppm Unleaded Gasoline JP-4 Jet Fuel* Synthetic Gasoline*

“Understanding EPA Standard and Equivalent Test Procedures for Liquid Phase and Vapor Phase Out of Tank Product Detectors” Marc Portnoff, July 28, 1992

3

Page 3

PID PhotoionizerTM Analyzers The testing conducted for this evaluation used all of the chemicals included in the March 1990 document except for 2-methylpentane, which was not available at the time of the test. The behavior of 2-methylpentane would be expected to be very similar to that for 3-methylpentane. Additional compounds of interest similar to those described in the June 1990 document were also included in the evaluation. These included Xylene, unleaded gasoline, #2 Diesel fuel, Jet A and aviation gasoline. All of the motor fuels were obtained directly from local commercial sources.

Page 4

PID PhotoionizerTM Analyzers 4.0 Description of the Test Apparatus

The evaluation was conducted at the PID Analyzers facility in Walpole, MA. The test apparatus was constructed by personnel at PID Analyzers as shown schematically in Figure 1.

2.0 L Syringe

Pump PID Analyzer

Bypass Flowmeter

Figure 1. Test Apparatus The test gasses were prepared by injecting the requisite amount of each chemical into a large 2.0 L syringe that was graduated in 20 ml increments. Zero air was then added to make the final volume 2.0 liters to obtain the initial concentration of gas. The volume of liquid needed to bring the initial gas concentration to 1000 ppm was calculated based on the liquid molecular weight and density. To dilute the gas to lower concentrations, the volume of gas in the syringe volume was reduced by pushing in the plunger and again adding zero air to return to the full 2L volume. For example, to produce a concentration of 500 ppm, the cylinder volume containing 1000 ppm vapor was reduced to 1000 ml and then again filled with zero air to obtain the desired 500 ppm.

Page 5

PID PhotoionizerTM Analyzers

5.0

Test Results and Discussion

The official results of the testing are provided in Attachment A of this report using the EPA forms found in the protocol "Standard Test Procedures for Evaluating Leak Detection Methods: Vapor Phase Out-of-Tank Product Detectors", EPA/530/UST90/008, March, 1990. Each subsection of the protocol is discussed below. 5.1 X0001 Accuracy and Response Time These tests were conducted to determine the accuracy of the sensor and the time required to reach 95% of the full response time and the time required to drop to 5% of the range after the vapor concentration is reduced to zero ppm. The accuracy of the measurement is determined by the response factor for each chemical species in the vapor mixture. The primary calibration was conducted using benzene, which was set to provide a response factor of 100%. Chemical species providing less response will have a correspondingly lower response factor. A summary of the results of the accuracy and response times is shown in Table 2 for the Model 102. Five measurements were made for each chemical at each concentration. The average and standard deviation are summarized. The raw test data is contained in Appendix B. Table 2. Summary of Test Results for Accuracy for Model 102
Detector Name Detector Type Test Gas Benzene PID Analyzers Model 102 X Quantitative Concentration (ppmv) 50 250 500 1000 50 250 500 1000 50 500 1000 50 250 500 50 100 500 50 100 500 Observed (ppmv) 46.8 243.8 569 1125.2 5.4 23.3 41.7 78.2 34.9 228 423 18.1 22.4 35.6 18 24.6 43.4 23.3 53.2 80.6 Qualitative Accuracy Precision (%) (%) 98.7 98.5 114.3 112.8 15.9 10.4 8.9 8.1 74 92 85 41.3 10 7.6 41.1 27.2 9.2 51.7 55.8 16.6 2.79 1.65 3.00 3.27 4.09 4.02 3.75 3.75 1.08 2.02 4.87 9.24 7.47 12.3 4.64 2.23 18.7 7.81 3.62 2.57 Bias (%) -6.4 -2.5 13.8 12.5 -89.3 -90.7 -91.7 -92.2 -31.2 -8.88 -15.32 -63.8 -91 -93 -64 -90 -91 -53.5 -78.7 -83.9 Detection Fall Time Time (sec) (sec) 17 14 14 11 9 11 11 12 <120 <120 <120 <120 <120 <120 28 36 50 <120 <120 <120 18 29 31 38 6 9 10 11 <120 <120 <120 <120 <120 <120 40 90 118 <120 <120 <120

2-Methylbutane

Unleaded Gasoline

Jet A

Diesel Fuel

Aviation Fuel

Page 6

PID PhotoionizerTM Analyzers 5.2 X0003 Specificity Specificity defines the response of the analyzer to different chemical species in the vapor form. To conduct these tests, the analyzer is exposed to multiple compounds all at a concentration of 500 ppmv. The results of this testing are summarized in Table 3. Table 3. Summary of Specificity Results for the Model 102 Instrument Reading (ppmv) 500 1.3 37.3 22.8 Not available 58.2 54.8 423.4 43.4 80.6 35.6 11.64 10.96 84.68 8.68 16.12 7.12

Concentration Chemical Benzene n-Butane n-Hexane Iso Butane 2-Methyl Pentane 3-Methyl Pentane Toluene Gasoline Diesel Fuel Aviation Fuel Jet A (ppmv) 500 500 500 500 500 500 500 500 500 500 500

Specificity (%) 100 0.26 7.46 4.56

5.3 X0006 Lower Limit of Detection This test method covers determination of lower detection limits for selected vapor-phase petroleum hydrocarbon leak detectors. A total of 12 tests were conducted using Benzene vapor and 2-Methylbutane. Six tests were conducted at a concentration that could be detected using the analyzer. A second set of six tests was conducted at the lowest concentration specified by the equipment manufacturer. While the analyzer might have been capable of detecting lower concentrations of hydrocarbon, the reported LDL for the Model 102 is well below the concentrations expected to be present at a leaking petroleum tank.

Page 7

PID PhotoionizerTM Analyzers The statistical calculations for the lowest set of six measurements were used to calculate the Lower Detection Limit (LDL) form Benzene and 2-Methyl Butane as specified in the protocol. The results are shown in Table 4. Table 4. Summary of Lower Detection Limit for Selected Vapors for the Model 102 Instrument Concentration Reading Chemical (ppmv) (ppmv)

Benzene

Stdev Critical Level Absolute Bias Critical Level Lower Detection Limit 2-Methyl Butane 3 3 3 3 3 3 Stdev (ppmv) Average Observed Value (ppmv) Absolute Bias (ppmv) Critical Level (ppmv) Lower Detection Limit (ppmv)

1 1 1 1 1 1

1.3 1.4 1.4 1.5 1.8 1.8 0.2 1.5 0.5 0.4 2.1 2.1 0.8 0.8 0.8 0.9 1.0 0.5 1.1 1.9 3.8 5.8

Because there was no LDL data for Diesel fuel, Aviation fuel and Jet A the LDL was estimated by graphing the accuracy data, extrapolating the results to zero ppmv and correcting for what appeared to be background concentrations in the dilution syringe. The resolution of the analyzer was assumed to be 1 ppmv and the calculated results based on the standard deviation for the 50 ppmv samples. The results are summarized in Table 5 for these less volatile materials. Table 5. Estimated Lower Detection Limit for Less Volatile Fuels Compound Diesel Fuel Aviation Fuel Stdev (ppmv) 0.8 1.8 Absolute Bias (ppmv) 17.9 8.5 Lower Detection Limit (ppmv) 24 22 Jet A 1.7 24.3 37 Page 8

PID PhotoionizerTM Analyzers 6.0 Conclusions

The following conclusions are based on the testing described in this report. 1. The equipment described in this report was tested according to the USEPA protocol for Out-of-Tank vapor monitoring. 2. The analyzers responded to all of thevarious hydrocarbon species that were used for the evaluation. 3. The response factors vary widely for different types of chemical compounds. The largest responses seem to be to aromatic compounds. 4. This evaluation does not describe how to use the analyzer for leak detection purposes. It is limited to analyzer characteristics only. 5. It may be difficult to distinguish releases of low volatility materials such as are found in diesel fuel when other more volatile compounds such as those found in gasoline are present. 6. Specific methods for sampling and data interpretation must be provided by the user. An alarm threshold must be set based on fuel type and site conditions.

Page 8

Attachment A

Vapor-Phase Out-of-Tank Product Detectors

Results of U.S. EPA Standard Evaluation

Vapor-Phase Out-of-Tank Product Detectors
This form documents the performance of the vapor-phase product detector described below. The evaluation was conducted by the equipment manufacturer or a consultant to the manufacturer according to the U.S. EPA’s “Standard Test Procedure for Evaluating Leak Detection Methods: Vapor-Phase Out-of-Tank Product Detectors.” Tank owners using this leak detection system should keep this form on file to prove compliance with the federal regulations. Tank owners should check with state and local agencies to verify that this form satisfies their requirements.
Method Description Name _PhotoionizerTM Analyzer Version__ Model 102 and 101 Vendor___PID Analyzers, Inc.______________________________________________

Results of U.S. EPA Standard Evaluation

_25 Walpole Park South Drive
(street address) (state (city )

___Walpole

MA

)

(zip

02091

)

(pho

800

ne)

724-5600

Detector output type: _X__ Quantitative ___ Qualitative Detector operating principle: ___ Metal Oxide Semiconductor ___ Adsistor ___ Detector Tube ___ Catalytic Gas Sensor ___ Combustible Gas Detector _X__ Photoionization Detector ___ Product-Permeable Detector ___ IR Detector ___ Other__________________________ Detector sampling frequency: _X__ Intermittent ___ Continuous

Evaluation Results
The detector described above was tested for its ability to detect known concentrations of test gas. The following parameters were determined: Accuracy – How closely test gas concentration, as measured by the detector, agrees with the actual gas concentration. Bias – Whether the method consistently over-estimates or under-estimates gas concentration. Not applicable to qualitative detectors. Precision – Agreement between multiple measurements of the same gas concentration. Not applicable to qualitative detectors. Detection Time – Amount of time the detector must be exposed to test gas before it responds. Fall Time – Amount of time that passes before the detector returns to its baseline reading after test gas is removed. Lower Detection Limit – The smallest gas concentration that the detector can reliably detect. Specificity – Indicates the ability of the detector to detect several different test gases.

Vapor-Phase Product Detector___PID Analyzers Version____Model 102 Evaluation Results (continued) >Compiled Test Results (for test conducted with 1000 ppm of test gas)

Accuracy and LDL Tests for Model 102 Test
Bias* (%) Precision* (%) Detection Time (hh:mm:ss) Fall Time (hh:mm:ss) Lower Detection Limit (ppm)

Benzene
__112.8__ __12.5___ __3.27___ __ 11 ___ 38 ___2.1 _ _

2-Methylbutane UL
_____8.1___ __ _ ___ -92.2____ __ _____3.75 ______ _____ 12__ _____ _____ 11_____ _ _____5.8______ _

Gasoline
85 -15.3 4.87 <120 <120

Accuracy (%)

Diesel Fuel
Accuracy (%) Bias* (%) Precision* (%) Detection Time (hh:mm:ss) Fall Time (hh:mm:ss) Lower Detection Limit (ppm) ___ 41.4______ ___ ___-64______ ___4.64_____ ___ ___28______ ___40______ ____24_____ ____

Jet-A
41.3___ ___-63.8___ 9.24__ _ ___<120___ ___<120___ 37____

Aviation Gas
16.6 -83.9 2.57 <120 <120 22

*Not applicable to qualitative detectors.

>Specificity Results (%) for Model 102
Benzene n-Butane n-Hexane Iso butane 2-Methylpentane 3-Methylpentane Toluene Unleaded Gasoline #2 Diesel Fuel Aviation Gas Jet A 84.7 8.68 16.1 7.12 ______ ______ ______ ______ 100______ __ 0.26_______ __ 7.46______ __ 4.56________ ___Not Available____ 11.6 ______11.0________

Accuracy and LDL Tests for Model 101 Diesel Fuel
Accuracy (%) Bias* (%) Precision* (%) Detection Time (hh:mm:ss) Fall Time (hh:mm:ss) Lower Detection Limit (ppm) ___ 41.4______ ___ ___-64______ ___4.64_____ ___ ___28______ ___40______ ____24_____ ____

Jet-A
41.3___ ___-63.8___ 9.24__ _ ___<120___ ___<120___ 37____

Aviation Gas
16.6 -83.9 2.57 <120 <120 22

> Safety disclaimer: This test procedure only addresses the issue of the method’s ability to detect leaks. It does not test the equipment for safety hazards.
Certification of Results

I certify that the vapor-phase product detector was operated according to the vendor’s instructions and that the evaluation was performed according to the standard EPA test procedure for vapor-phase out-of-tank product detectors except as noted on any attached sheets. I also certify that the results presented above are those obtained during the evaluation.
___H. Kendall Wilcox________________ (printed name) (organizatio __Ken Wilcox Associates, Inc.______ n performing evaluation)

(signature)

(city,

___

__Grain Valley, MO 64029________ state, zip) __(816) 443-2494________________ number)

__October 10, 2004 _________________ (date) (phone

Appendix B. Raw Test Data for PID Analyzers

LDL Data for Model 102
Concentration (ppmv) 10 10 10 10 10 10 1 1 1 1 1 1 100 100 100 100 100 100 10 10 10 10 10 10 3 3 3 3 3 3 Instrument Reading (ppmv) 12.4 10.5 10.5 11.2 11.9 12.9 1.3 1.4 1.4 1.5 1.8 1.8 22.3 21.7 21.4 20.9 21.2 20.9 2.9 2.7 2.7 2.9 2.9 2.9 0.8 0.8 0.8 0.8 0.9 1

Chemical Benzene

2-Methyl Butane

Model 102 Accuracy and Response Times Benzene Concentration (ppmv) Instrument Reading 50 45 48 48 47 46 46.8 1.3 250 239 248 248 242 242 243.8 4.0 500 541 571 585 580 568 569.0 17.1 1000 1060 1139 1150 1141 1136 1125.2 36.8

Mean Stdev 2-methyl butane Concentration (ppmv) Instrument Reading

50 5.3 5.5 5.5 5 5.5 5.4 0.2

250 22.7 24 23.7 22 24.2 23.3 0.9

500 40.8 42.4 42 39.7 43.8 41.7 1.6

1000 76.5 80.2 80.7 73.8 79.6 78.2 2.9

Mean Stdev Aviation Fuel Concentration (ppmv) Instrument Reading

50 20.5 22.6 23.5 25 24.7 23.3 1.8

100 56 53 54 52 51 53.2 1.9

500 82 83 81 79 78 80.6 2.1

Mean Stdev

Diesel Fuel #2 Concentration (ppmv) Instrument Reading

50 18 19.2 17.3 17.1 18.2 18.0 0.8

100 24 25 25 25 24 24.6 0.5

500 54.5 49 41 36.1 36.3 43.4 8.1

Mean Stdev Gasoline Concentration (ppmv) Instrument Reading

50 34.9 34.6 34.5 34.1 34 34.4 0.4

500 235 229 227 225 223 227.8 4.6

1000 458 426 416 409 408 423.4 20.6

Mean Stdev Jet A Concentration (ppmv) Instrument Reading

50 16 18 19.5 17 20 18.1 1.7

250 22 25 23 21 21 22.4 1.7

500 43 36 33 34 32 35.6 4.4

Mean Stdev

Data for Model 101 Aviation Fuel Concentration (ppmv) Instrument Reading 50 20.5 22.6 23.5 25 24.7 23.3 1.8 100 56 53 54 52 51 53.2 1.9 500 82 83 81 79 78 80.6 2.1

Mean Stdev Aviation Fuel Concentration (ppmv) Instrument Reading

50 20.5 22.6 23.5 25 24.7 23.3 1.8

100 56 53 54 52 51 53.2 1.9

500 82 83 81 79 78 80.6 2.1

Mean Stdev Aviation Fuel Concentration (ppmv) Instrument Reading

50 20.5 22.6 23.5 25 24.7 23.3 1.8

100 56 53 54 52 51 53.2 1.9

500 82 83 81 79 78 80.6 2.1

Mean Stdev

Attachment C Previous Evaluation and Listing for Model 101

Issue Date: January 11, 2001

HNU Systems, Inc.
PI-101 with 11.7 EV Probe #101397, HW-101 with 11.7 EV Probe #170214, ISPI-101 with 10.2 EV Probe #111100, DL-101 with 10.2 EV Probe #167085 VAPOR-PHASE OUT-OF-TANK PRODUCT DETECTOR

Detector: Output type: Sampling frequency: Operating principle: Test Results: unleaded gasoline PI-101 Accuracy* (%) - average reading Detection time* (sec) Fall time* (sec) Lower detection limit (ppm) HW-101 Accuracy* (%) - average reading Detection time* (sec) Fall time* (sec) Lower detection limit (ppm) ISPI-101 Accuracy* (%) - average reading Detection time* (sec) Fall time* (sec) Lower detection limit (ppm) DL-101 Accuracy* (%) Detection time* (sec) Fall time* (min:sec) Lower detection limit (ppm) 29.1 (730 ppm) 31 52 14.2 12.6 (888 ppm) 20 49 31.8 63.6 (360 ppm) 20 40 2.3 63.3 45 01:03 11.0 synthetic gasoline 12.3 (884 ppm) 21 14 11.7 8.5 (1076 ppm) 25 10 21.1 59.1 (415 ppm) 21 10 5.8 56.2 22 00:14 5.8 JP-4 jet fuel 29.6 (737 ppm) 26 49 29.7 5.7 (953 ppm) 24 49 26.8 70.8 (300 ppm) 35 37 5.1 59.5 51 01:01 5.0 quantitative intermittent photoionization detector

*For tests conducted with 1000 ppm of test gas Specificity Results (in addition to above): Activated: n-hexane, toluene, xylene(s)

HNU Systems, Inc.

Evaluator: Carnegie Mellon Research Institute

160 Charlemont St. Newton, MA 02461-1992 Tel: (617) 964-6690

Tel: (412) 268-3495 Dates of Evaluation: 02/5/92, 02/5/92, 03/5/92, 11/28/91

Attachment D Addendum for Model 101 Using Diesel Fuel, Jet A and Aviation Gasoline

Model 101 Diesel Fuel #2 Concentration (ppmv) Instrument Reading 50 20.4 20.1 19.5 21.0 20.3 20.3 0.5 45.7 2.67 -59.48 250 30.5 29.5 28.9 29.5 29.5 29.6 0.6 32.2 1.95 -88.168 500 47.2 46.2 47.1 46.5 46.7 46.7 0.4 9.9 0.89 -90.652

Mean Stdev Accuracy (%) Precision (%) Bias (%)

Diesel Fuel #2 (correced for background) Concentration (ppmv) 50 250 Instrument Reading 4 3.7 3.1 4.6 3.9 3.9 0.5 12.9 14.02 -92.28 14.1 13.1 12.5 13.1 13.1 13.2 0.6 15.8 4.37 -94.728

500 30.8 29.8 30.7 30.1 30.3 30.3 0.4 6.6 1.37 -93.932

Mean Stdev Accuracy (%) Precision (%) Bias (%) Jet A Concentration (ppmv) Instrument Reading

50 16 18 19.5 17 20 18.1 1.7 41.3 9.24 -63.8

250 22 25 23 21 21 22.4 1.7 25.0 7.47 -91.04

500 43 36 33 34 32 35.6 4.4 7.6 12.34 -92.88

Mean Stdev Accuracy (%) Precision (%) Bias (%)

``` Jet A (corrected for background) Concentration (ppmv) 50 Instrument Reading 1.2 3.2 4.7 2.2 5.2 3.3 1.7 11.7 50.71 -93.4 10

250 7.2 10.2 8.2 6.2 6.2 7.6 1.7 10.2 22.02 -96.96 14.8

500 28.2 21.2 18.2 19.2 17.2 20.8 4.4 4.7 21.12 -95.84

Mean Accuracy (%) Precision (%) Bias (%) Background

Aviation Gasoline Concentration (ppmv) Instrument Reading

50 25.1 24.9 22 22.3 21.1 23.1 1.8 51.3 7.84 -53.84

250 47.9 49.2 47.1 46.2 42 46.5 2.7 49.1 5.89 -81.408

500 69.7 72.1 72.8 71.2 69.3 71.0 1.5 14.7 2.12 -85.796

Mean Stdev Accuracy (%) Precision (%) Bias (%)

Aviation Gasoline (corrected for background) Concentration (ppmv) 50 250 Instrument Reading 8.7 8.5 5.6 5.9 4.7 6.7 1.8 18.5 27.08 -86.64 ? 31.5 32.8 30.7 29.8 25.6 30.1 2.7 32.7 9.10 -87.968 16.4

500 53.3 55.7 56.4 54.8 52.9 54.6 1.5 11.4 2.76 -89.076

Mean Stdev Accuracy (%) Precision (%) Bias (%) Background

Summary of Accuracy Data for Model 101
Detector Name Detector Type Test Gas Diesel Fuel PID Analyzers Model 101 X Quantitative Qualitative Concentration Observed Accuracy Precision (ppmv) (ppmv) (%) (%) 50 100 500 50 250 500 50 100 500 3.9 13.2 30.3 3.3 7.6 20.8 6.7 30.1 53.3 12.9 15.8 6.6 11.7 10.2 4.7 18.5 32.7 11.4 14.02 4.37 1.37 50.7 22.0 21.1 27.1 9.1 2.8 Bias (%) -92.3 -94.7 -93.9 -93.4 -97.0 -95.8 -86.6 -88.0 -89.1 Detection Fall Time Time (sec) (sec) 28 36 50 <120 <120 <120 <120 <120 <120 40 90 118 <120 <120 <120 <120 <120 <120

Jet A

Aviation Fuel

Vapor-Phase Out-of-Tank Product Detectors
This form documents the performance of the vapor-phase product detector described below. The evaluation was conducted by the equipment manufacturer or a consultant to the manufacturer according to the U.S. EPA’s “Standard Test Procedure for Evaluating Leak Detection Methods: Vapor-Phase Out-of-Tank Product Detectors.” Tank owners using this leak detection system should keep this form on file to prove compliance with the federal regulations. Tank owners should check with state and local agencies to verify that this form satisfies their requirements.
Method Description Name _PhotoionizerTM Analyzer Version__ Model 102 for Diesel, Jet A and Aviation Gasoline Vendor___PID Analyzers, Inc.______________________________________________

Results of U.S. EPA Standard Evaluation

_25 Walpole Park South Drive
(street address) (state (city )

___Walpole

MA

)

(zip

02091

)

(pho

800

ne)

724-5600

Detector output type: _X__ Quantitative ___ Qualitative Detector operating principle: ___ Metal Oxide Semiconductor ___ Adsistor ___ Detector Tube ___ Catalytic Gas Sensor ___ Combustible Gas Detector _X__ Photoionization Detector ___ Product-Permeable Detector ___ IR Detector ___ Other__________________________ Detector sampling frequency: _X__ Intermittent ___ Continuous

Evaluation Results
The detector described above was tested for its ability to detect known concentrations of test gas. The following parameters were determined: Accuracy – How closely test gas concentration, as measured by the detector, agrees with the actual gas concentration. Bias – Whether the method consistently over-estimates or under-estimates gas concentration. Not applicable to qualitative detectors. Precision – Agreement between multiple measurements of the same gas concentration. Not applicable to qualitative detectors. Detection Time – Amount of time the detector must be exposed to test gas before it responds. Fall Time – Amount of time that passes before the detector returns to its baseline reading after test gas is removed. Lower Detection Limit – The smallest gas concentration that the detector can reliably detect. Specificity – Indicates the ability of the detector to detect several different test gases.

Vapor-Phase Product Detector___PID Analyzers Version____Model 101 Evaluation Results (continued) >Compiled Test Results (for test conducted with 500 ppm of test gas)

Accuracy and LDL Tests Test
Accuracy (%) Bias* (%) Precision* (%) Detection Time (seconds) Fall Time (hh:mm:ss) Lower Detection Limit (ppm) ___

Diesel Fuel
6.6 ______ ___ ___-93.9_____ ___1.37_____ ___ ___50______ __ 118______ ____20____ ____

Jet-A
4.7 ___ ___-95.8___ 21.1__ _ ___<120___ ___<120___ 34____

Aviation Gas
11.4 -89.1 2.8 <120 <120 38

*Not applicable to qualitative detectors.

>Specificity Results (%)
#2 Diesel Fuel Aviation Gas Jet A

> Safety disclaimer: This test procedure only addresses the issue of the method’s ability to detect leaks. It does not test the equipment for safety hazards.
Certification of Results

I certify that the vapor-phase product detector was operated according to the vendor’s instructions and that the evaluation was performed according to the standard EPA test procedure for vapor-phase out-of-tank product detectors except as noted on any attached sheets. I also certify that the results presented above are those obtained during the evaluation.
___H. Kendall Wilcox________________ (printed name) (organizatio __Ken Wilcox Associates, Inc.______ n performing evaluation)

(signature)

(city,

___

__Grain Valley, MO 64029________ state, zip) __(816) 443-2494________________ number)

__October 10, 2004 _________________ (date) (phone