Protocol Gas Verification Program (PGVP)

In a recent rulemaking posted in the Federal Register (FR), EPA has established a national Protocol Gas Verification Program (PGVP). Under this program, EPA, in cooperation with the National Institute of Standards and Technology (NIST), will conduct an annual blind audit of EPA Protocol gases that are used to calibrate continuous emission monitoring systems (CEMS) and the instruments used in EPA reference methods. The use of EPA Protocol gases in these applications helps to ensure the quality of the emissions data that the Agency uses to assess the effectiveness of its emissions reduction programs under the Clean Air Act. The PGVP has four main objectives: (1) to ensure that EPA Protocol gases meet the accuracy requirements of 40 CFR Part 75; (2) to assist calibration gas consumers in their purchasing decisions; (3) to provide an incentive for gas vendors that perform well in the audits to continue to use good practices; and (4) to encourage gas vendors that perform poorly in the audits to make improvements.

PGVP Training:

Lesson 1: Introduction to PGVP
Lesson 2: Explaination of PGVP Gas Type Codes
Lesson 3: Entering PGVP Settings in CeDAR
Lesson 4: Entering PGVP Linearity Information in CeDAR
Lesson 5: Entering PGVP Linearity Information in breez75x
Lesson 6: Entering Calibration Check PGVP Information in breez75x

Other Information:

Table of PGVP Gas Type Codes

ECMPS PGVP Rules and Regulations

Frequently Asked Questions:

Do I have to enter PGVP information for the entire quarter?

Since the PGVP went into effect on 9/26/11, you do not have to have PGVP information filled out for your daily calibrations prior to this date. However, if you have entered any of this information prior to 9/26/11 you will need to fill it out for the entire quarter. So, either report beginning 9/26/11 or for the entire quarter. For linearities, please fill out this information for any linearities this quarter even though it is not required until 9/26. There is an issue both with breez75X and the Client Tool and filling in this information on your linearities for this quarter is the easiest work around.


Can I enter the PGVP values via the maple/OIT panel or from the CEMS shelter?

At this point in time that is not possible. Since PLC’s and panels are unique to sites there is no easy way for us to update these without updating them individually. Also, if it is an older PLC, a change like this would require an upgrade in PLC since some PLC’s do not have the space or capability to handle alpha numeric fields.


Can I enter these values in the Real View?

If you have a Real View (which is the windows based version of the panel) we are working on the capability to enter these values through the Real View but that has not been completed yet.


Why isn’t there a place in breez75X to enter my zero gases?

Remember, zero calibrations gases and those that are Part 60 only do not fall under PGVP. There are place holders in the settings window in the Data Monitor and the Database Editor for you to track this information as we will be developing a gas bottle management utility in the future but those values do not get reported under PGVP. Also, since they don’t fall under PGVP, there are no gas type codes for these gases.


What about CGA’s?

Quarterly CGA’s also do not fall under PGVP as they are a Part 60 requirement (but Linearities do as they are Part 75 requirements). There are place holders in the CGA/Linearity window in the Database Editor for CGA’s in case you would like to track this information but you are not required to electronically report this information and there are no gas type codes for these gases.


Can I use the same cylinder for different units on my linearities?

Yes. Just put the same cylinder number in the appropriate place for each unit. You cannot use the same cylinder number for different types of gases.


What about gases that are recertified?

When you recertify a gas, you send it to the gas company for recertification. Once they recertify it, they send it back with a new expiration date. So, while the cylinder number is the same, the expiration date will be different.


Is NX (EPA Protocol gas bi-blend standard consisting of two certified components, NO and NO2, and a balance gas) the correct code for NOx for PGVP?

Only if the NO2 component is certified. Since NO2 is not very stable, it usually isn’t certified. In that case the code would be NO. Check your gas certification sheets or call your gas vendor to see if the NO2 component is certified.


What happens next year when the vendor ID’s change?

While the cylinder number and expiration date will remain the same, you will have to update the vendor ID with the new code.


In Breeze75x when I enter the PGV info the software is wanting an expiration date filled in for our O2 cylinders. The zero cylinder doesn’t have expiration date and our span gas is plant air, what should we use?

Again, the zero gases do not get reported under PGVP. If you use instrument air to calibrate your O2 span, the gas type code is “AIR” and the cylinder, expiration date, and vendor ID are left blank.


If I use instrument air to calibrate my O2 span and I accidentally click on the expiration date field in the CeDAR settings, the software makes me put in an expiration date. How do I fix this?

This is a known issue is CeDAR and will be fixed with a future release of the software. For now, you will need to go into breez75X and remove the expiration date making sure that you remove everything from this field (including the time stamp). Then call CiSCO to have the expiration date removed from the settings window so this expiration date does not get put on future calibrations.


What code do we use for NOx L span gas? Ours is a mix of CO and NOx?

If the NO2 component is not certified then the gas type code would be NC.


Even if we don’t report CO in the EDR do we use NC or do we use NX as though it isn’t blended with CO?

If this gas is used for Part 60 calibrations, no gas type code is required so leave this field blank.


Breez75X is not allowing me to save my Vendor ID’s for my linearities. What should I do?

This is a known issue in breez75X and will be fixed with the next release. For now, enter the vendor ID’s for linearities in the CeDAR Database Editor.


Do I have to enter the Vendor ID using a capital letter?

Yes, both CeDAR and breez75X will allow you to enter lower case letters for the Vendor ID. The logic is that at some point, the EPA may add Vendor ID’s with lower case letters. Breez75X will not convert the lower case letter to a capital letter when you create the EDR. The Client Tool will check Vendor ID’s in the EDR against the Vendor ID list so make sure you enter a capital letter if the letter is capitalized on the Vendor ID list.


Can you provide guidance on how a facility handles PGVP info if the facility has performed 40 CFR 75 calibrations or linearities using cylinder gases purchased prior to May 27, 2011?

For gases purchased before the PGVP requirement was in effect, that are still within their shelf life (i.e., have not expired) if those bottles are still in use after September 26, 2011, then report a Vender ID of "NONPGVP" as specified in the reporting instructions. No further PGVP information is required (i.e., leave all other PGVP fields blank).