On February 2 - 3, 1999, the Center for Waste Reduction Technologies (CWRT) and the Electric Power Research Institute (EPRI) sponsored a workshop designed to address the regulatory and technological developments of particulate matter (PM) continuous emission monitoring systems (CEMS). The Workshop, held in Durham, North Carolina, was attended by over eighty people representing individual chemical, pulp and paper, pharmaceutical, and utility companies; PM CEMS vendor companies, consulting and engineering firms; as well as the U.S. Environmental Protection Agency (EPA) and state agencies. Workshop topics included:
Ralph Roberson, President of RMB Consulting & Research, Inc. (RMB), presented two papers during the Workshop. The first presentation addressed the electric utility industrys perspective of PM CEMS. During the second presentation, Mr. Roberson discussed the results of a recent PM CEMS demonstration project which was conducted on a coal-fired boiler. The demonstration project, developed and managed by RMB, was conducted for EPRI as a tailored collaboration (TC) project. The final report for this project is being prepared.
Because commercially available PM CEMS measure secondary properties of particulate matter as opposed to directly measuring mass emissions, a correlation (or "site-specific calibration") to mass emissions must be developed using PM reference method testing. There are two key aspects for developing a sound correlation or calibration. First, it is imperative to obtain emissions data for the complete process operating range, from zero emissions to "worst-case scenarios" resulting from process upsets, pollution control failures, and/or varying fuel feedrates. Secondly, it is equally important to ensure that the reference method data collected are accurate and representative.
Nevertheless, given the band of uncertainty surrounding these correlations/calibrations, one key issue discussed was how these monitors will be used for determining compliance with emission limits. Another major concern was the treatment of emission limit exceedances that may occur during the development of the instrument calibration correlation. Within the regulatory community, opinions on the treatment of these data differ between those drafting this regulation and those in enforcement. This matter is further complicated by the Credible Evidence Rule and the power granted to individual citizens in Section 304 of the Clean Air Act to file suit against companies for violating the Act. Muddy waters, indeed!
RMB intends to closely monitor both the regulatory and technological developments associated with PM CEMS. Periodic updates will be posted to our website. The Workshop proceedings will also be posted when they become available to RMB.
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