Air Emissions Testing | Delta Energy Park | Mostardi Platt
Mostardi Platt
Sample Technical RATA Audit

Air Emissions
Testing

Regulatory validation and Relative Accuracy Test Audit for the Continuous Emissions Monitoring Systems (CEMS) serving Unit EUCTGHRSG2.

I. Detailed Methodology & Compliance Framework

The test program adhered strictly to 40 CFR Part 60 and Part 75, ensuring federal-grade data integrity during normal load operations at Delta Energy Park.
Oxygen (O2) via Method 3A: Validated via a paramagnetic analyzer. This technology leverages Oxygen's unique attraction to magnetic fields to provide precise, real-time concentration measurements.
Nitrogen Oxides (NOx) via Method 7E: Measured using chemiluminescent detection. This process quantifies the light intensity produced by the chemical reaction between Nitric Oxide and Ozone, which is directly proportional to NOx concentration.
Carbon Monoxide (CO) via Method 10: Assessed via a gas filter correlation infrared analyzer, identifying the specific infrared energy absorption patterns unique to CO molecules.
Pre-audit procedures included full system bias checks using NIST-traceable protocol gases to verify that the entire Continuous Emissions Monitoring Systems sampling chain was operating within allowable drift tolerances.
Perspective | Gaya's Note

Think of the Detailed Methodology as a high-stakes truth-test for industrial sensors. Every large energy plant has built-in monitors (Continuous Emissions Monitoring Systems) that constantly report how much pollution they are releasing—essentially an on-board computer for the smokestack.

To ensure these systems remain accurate, the law requires an independent third party to deploy laboratory-grade equipment. We compare the plant's permanent readings against our independent gold standard measurements. It is the industrial equivalent of verifying a speedometer's accuracy using a calibrated radar gun.

II. Audit Results Matrix

Constituent Regulatory Threshold Audit Performance
Nitrogen Oxides (NOx) ±0.015 lb/mmBtu 0.001 lb/mmBtu
Carbon Monoxide (CO) ±5.0 ppmvd @ 15% O2 0.29 ppmvd
Oxygen (O2) 1.0% O2 Diff or 10.0% RA 1.21% RA

III. Raw Data Verification

Captured: May 31, 2023 | 09:15 EST
Test RunRef MethodCEMS DataDelta
Sequence 011.9831.9800.003
Sequence 021.9791.982-0.003
Sequence 031.9851.9840.001

Asset Profile

Owner LBWL
Location Delta Energy Park, MI
Unit EUCTGHRSG2

Technical Glossary

EPA Method 7E / 10

Standardized regulatory procedures for instrumental analysis of NOx and CO concentrations.

Paramagnetic Analysis

A physical method for Oxygen detection that relies on the paramagnetic properties of the O2 molecule.

NIST Protocol

Ensures that testing gases are calibrated against primary standards from the National Bureau of Standards (now NIST).

Audited By
Mostardi Platt
AETB Certified Laboratory
Gaya Capital

Legal Notice: This document is a summary of third-party audit project M231206C. While efforts are made to ensure accuracy, Gaya Capital does not guarantee the completeness of technical data provided by external agencies. This briefing is for internal assessment purposes and does not constitute environmental consulting or investment advice.

© 2026 Gaya Capital.