United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park, NC 27711
EPA-454/R-00-039
September 2000
Air
CURRENT KNOWLEDGE OF PARTICULATE
EPA MATTER (PM) CONTINUOUS EMISSION
MONITORING
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Current Knowledge of Particulate Matter (PM)
Continuous Emission Monitoring
FINAL REPORT
For U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Emission, Monitoring and Analysis Division
Emission Measurement Center
Research Triangle Park, North Carolina 27711
Attn: Mr. Dan Bivins
EPA Contract No. 68-W6-0048
Work Assignment No. 3-07 and 4-03
MRI Project Nos. 104702-1-007-07-15
104703-1-003-07
September 8, 2000
U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th Floor
Chicago, IL 60604-3590
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PREFACE
This document was prepared by Midwest Research Institute (MRI) for the U. S.
Environmental Protection Agency (EPA) under Contract No. 68-W6-0048, Work
Assignments 3-07 and 4-03. Mr. Dan Bivins was the EPA Work Assignment Manager (WAM).
This document summarizes the EPA's current knowledge of paniculate matter continuous
emission monitoring. The document consists of one volume with 98 pages and one appendix.
MIDWEST RESEARCH INSTITUTE
L/
0
Craig Clapsaddle
Task Leader
Andrew Trenholm
Work Assignment Leader
Approved:
Joe Palausk^^
Program Manager
September 8, 2000
in
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TABLE OF CONTENTS
PREFACE iii
EXECUTIVE SUMMARY ix
1.0 INTRODUCTION 1-1
2.0 HISTORICAL PERSPECTIVE OF CONTINUOUS PM MONITORING 2-1
2.1 OVERVIEW OF REGULATORY USE 2-1
2.2 PAST STUDIES 2-2
2.3 CURRENT EUROPEAN EXPERIENCE 2-8
3.0 ANALYTICAL PRINCIPLES 3-1
3.1 LIGHT SCATTERING 3-1
3.2 BETA ATTENUATION 3-2
3.3 PROBE ELECTRIFICATION (TRIBOELECTRIC EFFECT) 3-3
3.4 LIGHT EXTINCTION (TRANSMISSOMETER) 3-3
3.5 OPTICAL SCINTILLATION 3-5
4.0 SUMMARY OF KNOWN PM CEMS 4-1
4.1 DURAG F904K BETA ATTENUATION 4-2
4.2 ENVIRONMENT S.A. 5M BETA ATTENUATION 4-3
4.3 MECHANICAL SYSTEMS INC. BETAGUARD PM BETA
ATTENUATION 4-4
4.4 SIGRIST KTNR AND CTNR EXTRACTIVE LIGHT SCATTER 4-5
4.5 DURAG DR-300-40 IN-SITU LIGHT SCATTER 4-6
4.6 ENVIRONMENTAL SYSTEMS CORPORATION P5 IN-SITU
LIGHT SCATTER 4-6
4.7 SICK INC. RM210 IN-SITU LIGHT SCATTER 4-7
4.8 SICK INC. FW 100 IN-SITU AND FWE 200 EXTRACTIVE LIGHT
SCATTER 4-8
4.9 GRIMM TECHNOLOGIES 6300 IN-SITU LIGHT SCATTER 4-8
4.10 MONITOR LABS 300L IN-SITU LIGHT SCATTER 4-9
4.11 BHA GROUP CPM 5000 SCINTILLATION 4-9
4.12 PCME SCINTILLA SC600 SCINTILLATION 4-10
4.13 INSITEC TESS IN-SITU OR EXTRACTIVE LASER LIGHT
EXTINCTION-SCATTER 4-11
4.14 PCME DUST ALERT 90 ELECTROSTATIC INDUCTION 4-11
4.15 AUBURN INTERNATIONAL TRIBOGUARD m OR n IN-SITU
TRIBOELECTRIC 4-12
4.16 CODEL STAKGARD TRIBOELECTRIC DUST MONITOR 4-12
4.17 OPACITYATRANSMISSOMETERS 4-13
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TABLE OF CONTENTS (CONTINUED)
5.0 SUMMARY OF PM CEMS DEMONSTRATION FIELD STUDIES 5-1
5.1 TUV CERTIFICATION TESTING OF PM CEMS 5-1
5.1.1 Sigrist CTNR 5-1
5.1.2 Durag F-904 5-2
5.1.3 Durag DR-300-40 5-3
5.2 EPA/OSW FIELD DEMONSTRATION - HAZARDOUS WASTE
INCINERATORS 5-4
5.2.1 Mixed Solid and Liquid Hazardous Waste Incinerator 5-4
5.2.2 Hazardous Waste Burning Cement Kiln 5-5
5.2.3 DuPont Hazardous Waste Incinerator 5-6
5.3 ELECTRIC POWER RESEARCH INSTITUTE - COAL-FIRED BOILER
WITH ESP 5-8
5.4 ELI LILLY - HAZARDOUS WASTE INCINERATOR 5-10
5.4.1 Phase One 5-11
5.4.2 Phase Two 5-11
5.5 EPA/OAQPS FIELD DEMONSTRATION - COAL-FIRED BOILER
WITH BAGHOUSE 5-13
6.0 FUTURE FIELD DEMONSTRATIONS 6-1
6.1 TEST PLAN GUIDELINES 6-1
6.2 MONITOR SELECTION GUIDELINES 6-2
6.3 TEST PLAN APPROVAL AND DATA ANALYSIS 6-3
7.0 PM CEMS IMPLEMENTATION 7-1
7.1 SOURCE APPLICABILITY 7-1
7.2 PM CEMS SELECTION 7-2
7.3 SITE-SPECIFIC CORRELATION TEST 7-4
7.4 UNDERSTANDING THE MEANING OF THE CORRELATION 7-7
7.5 QUALITY ASSURANCE/QUALITY CONTROL 7-8
7.6 PS-11 ISSUES TO BE ADDRESSED CASE BY CASE 7-11
8.0 SUMMARY OF PS-11 AND PROCEDURE 2 8-1
8.1 PS-11 8'1
8.2 PROCEDURE 2 8-3
9.0 PM CEMS COST 9'1
10.0 REFERENCES 1(M
APPENDIX A. BREAKDOWN OF PM CEMS COSTS A-l
VI
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TABLE OF CONTENTS (CONTINUED)
'Jage
LIST OF TABLES
TABLE 2-1. NSPS REQUIRING COMS 2-1
TABLE 2-2. PM MONITOR EVALUATION RESULTS AT A SECONDARY LEAD
SMELTER 2-6
TABLE 2-3. GERMAN SUITABILITY TEST SPECIFICATIONS FOR APPROVAL 2-9
TABLE 2-4. MCERTS PM CEM EVALUATION CHARACTERISTICS 2-13
TABLE 4-1. COMPARISON OF OPACITY MONITORS AS PM CEMSs 4-14
TABLE 5-1. PM CONCENTRATIONS FOR THE THREE WEEKS OF THE EPRI
PM CEMS TEST 5-9
TABLE 5-2. PM CEMSs CORRELATION STATISTICS FOR THE EPRI
PM CEMS TEST 5-10
TABLE 5-3. PM CEMSs CORRELATION STATISTICS FOR THE LILLY
PHASE TWO PM CEMSs TEST 5-13
TABLE 5-4. PM CONCENTRATIONS FOR THE EPA/OAQPS PM CEMS TEST 5-15
TABLE 5-5. PM CEMSs CORRELATION STATISTICS FOR THE OAQPS
PM CEMSs FIELD EVALUATION 5-16
TABLE 9-1. IN-SITU (LIGHT SCATTERING) PM CEMS COSTS 9-1
TABLE 9-2. EXTRACTIVE (BETA GAUGE) PM CEMS COSTS 9-1
vn
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EXECUTIVE SUMMARY
Continuous monitoring of particulate matter (PM) concentrations in smoke stacks started
during the 1960s in Germany and became a German Federal requirement in the mid 1970s. In
the United States, PM concentrations were correlated to opacity monitor readings during the
1970s. Then, in the mid 1970s, the EPA dictated the use of transmissometers for continuous
monitoring of the opacity of emissions from sources. Opacity is used as a surrogate for PM
emissions and provides qualitative information on the operation and maintenance of particulate
control equipment. Continuous particulate mass monitoring was proposed as an EPA regulatory
requirement on April 19, 1996, as part of the proposed Hazardous Waste Combustion MACT
standard (61 FR 17358). The EPA also proposed performance specification (PS)-l 1,
Specifications and Test Procedures for Particulate Matter Continuous Emission Monitoring
Systems in Stationary Sources, to evaluate the acceptability of a PM continuous emission
monitoring system (CEMS). The Portland Cement Manufacturing MACT Final Rule
(64 FR 31898, June 14, 1999) in section 63.1250(k) makes mandatory the use of PM CEMSs
although not until the EPA has finalized PS-11.
Five analytical principles (light scattering, beta attenuation, probe electrification, light
extinction, and optical scintillation) used in instruments to measure PM concentrations are
described in this document. The following monitors are described in detail and are commercially
available from manufacturers as "off-the-shelf PM continuous emission monitors:
Durag F904K Beta Attenuation
Environment S.A. 5M Beta Attenuation
Mechanical Systems Inc. BetaGuard PM Beta Attenuation
Sigrist KTNR and CTNR Extractive Light Scatter
Durag DR-300-40 In-situ Light Scatter
Environmental Systems Corporation P5 In-situ Light Scatter
Sick Inc. RM210 In-situ Light Scatter
Sick Inc. FW 100 and FWE 200 Light Scatter
Grimm Technologies Inc. Model 6300 In-situ Light Scatter
Monitor Labs Model 300L In-situ Light Scatter
BHA Group CPM 5000 Scintillation
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PCME Scintilla SC600 Scintillation
Insitec TESS In-situ or Extractive Laser Light Extinction-Scatter
PCME DustAlert 90 Electrostatic Induction
Auburn International Triboguard ffl or n In-situ Triboelectric
Codel StakGard Triboelectric Dust Monitor
Several opacity monitors are included for completeness.
PS-11 is used for evaluating the acceptability of an installed PM CEMS. This
performance specification requires site-specific correlation of the PM CEMS response against
manual gravimetric EPA Methods. PS-11 outlines the procedures and acceptance criteria for
installation and operation of instrumentation and for calculations and reporting of data generated
during a PM CEMS correlation. PS-11 is unique, relative to the performance specifications for
other CEMS, because it is based on a technique of correlating a PM CEMS's response to
emissions determined by the manual PM method. In conjunction with PS-11, Procedure 2,
which was also proposed in 1996 with PS-11, stipulates the quality assurance (QA) and quality
control (QC) measures that must be applied to a PM CEMS.
In Germany to meet regulatory monitoring requirements for a particular industry type, a
specific model PM CEMS must pass a suitability test and be approved by the German Federal
Environmental Agency before it can be installed and used as a PM CEMS. The suitability test
consists of both a laboratory evaluation and a field evaluation. The United Kingdom has a
similar approval mechanism for a PM CEMS.
The EPA and industry have done the following recent field evaluations of PM CEMS:
EPA/Office of Solid Waste (OSW) - 3 PM CEMSs at a mixed solid and liquid hazardous
waste incinerator located in Bridgeport, New Jersey during March 1995.
EPA/OSW - 2 PM CEMSs at a hazardous waste cement kiln located in Fredonia, Kansas
during May through July 1995.
EPA/OSW - 5 PM CEMSs at the DuPont Experimental Station's hazardous waste
incinerator located in Wilmington, Delaware during September 1996 through May 1997.
Electric Power Research Institute - 4 PM CEMSs at Georgia Power Company's Plant
Yates coal-fired boiler located in Newnan, Georgia during June through September 1998.
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Eli Lilly, the Chemical Manufacturers Association, and the Coalition for Responsible
Waste Incineration - 2 PM CEMSs at a liquid hazardous waste incinerator at the Eli Lilly
Clinton Lab in Clinton, Indiana during February through June 1998 and November
through December 1998.
EPA/OAQPS - 3 PM CEMSs at a coal-fired boiler located in Battleboro, North Carolina
during June 1999 through February 2000.
Results of the EPA and industry field evaluations are described in this document.
XI
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1.0 INTRODUCTION
This report provides detailed information on the current knowledge of PM CEMSs. This
information was gained from literature reviews; attendance at many meetings and conferences
where the use of PM CEMSs was discussed; shared knowledge between the EPA, industry, and
consultants experienced with PM CEMSs in both the United States and Europe; discussions with
PM CEMS vendors; and personal experiences from performing a field demonstration of PM
CEMSs. The report will be maintained as a "living document" with periodic updates as needed.
The report is primarily written to provide information useful to State permitting
authorities and EPA Regional personnel. However, the information contained herein will be
useful to all persons involved with a PM CEMS program. It includes (1) technical information
on the monitors and their principal of operation, (2) their use history, (3) a summary of recent
PM CEMS field demonstrations, (4) recommendations for future field demonstrations,
(5) recommendations on how to implement a PM CEMS program, (6) a summary of the
performance specification for PM CEMSs, and (7) cost information.
A draft of this report was sent to 14 individuals with different view points and knowledge
in the field of continuous PM monitoring. The EPA received comments from nine reviewers,
and their comments were incorporated into this final report.
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2.0 HISTORICAL PERSPECTIVE OF CONTINUOUS PM MONITORING
2.1 OVERVIEW OF REGULATORY USE
Continuous monitoring of PM concentrations in smoke stacks started during the 1960s in
Germany. In the United States during the 1970s, PM concentrations were correlated to opacity
monitor readings, but the EPA dictated the use of transmissometers to continuously monitor the
opacity of emissions from sources. For the EPA's emission monitoring regulations and State
Implementation Plans (SIP), opacity is used as a surrogate for PM emissions and provides
qualitative information on the operation and maintenance of paniculate control equipment. The
EPA's New Source Performance Standards (NSPS) require continuous monitoring of opacity of
emissions from the 11 source categories presented in Table 2-1.
TABLE 2-1. NSPS REQUIRING COMS
Source category
Electric Power Plants
Portland Cement Plants (Kiln and Clinker cooler)
Petroleum Refineries (FCCU)
Primary Copper Smelters (Dryer)
Primary Zinc Smelters (Sintering machine)
Primary Lead Smelters (Blast furnace, Dross
reverberatory furnace, and Sintering machine)
Ferroalloy Production (Control device)
Electric Arc Furnace in steel mills (Control device)
Kraft Pulp Mills (Recovery furnace)
Lime Kilns (Rotary lime kiln)
Phosphate Rock Plants (Dryer, Calciner, Grinder)
40 CFR Part 60
D, Da, Db,
Subpart
DC
F
J
P
Q
R
Z
AA
BB
HH
NN
In Germany, the first laws to require continuous monitoring of PM emissions came on
December 29, 1959 in the German Federal Law for Citizens (Act to Amend the Industrial
Code..., 1959). Then in 1964, a more concrete requirement for continuous PM monitoring that
included many types of industrial plants was amended in the Technical Instruction for Air
Pollution Control (TA Luft, 1964). Plants with emissions exceeding 55 pounds per hour were
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required to continuously monitor PM concentration in mg/acm "as soon as a suitable instrument
becomes available." The requirements in TA Luft of 1964 initiated field studies of continuous
PM emission monitoring instrumentation. Several field-based research projects were completed
by the German federal government in the years following the German Federal Law of
Environmental Protection (BlmSchG, March 15, 1974). These field studies were completed to
correct deficiencies found in the measurement technology and formed the basis for the German's
instrument approval process (see Section 2.3). Additional legislative rules detailed the
monitoring requirements for power plants (13th BlmSchV, 1983) and waste incinerators
(17th BlmSchV, 1990) (Breton, 1989, Martin, 1994, Jockel, 1998, and Jockel, 1999).
In the United States in 1975, the EPA promulgated Performance Specification - 1 (PS-1),
Specifications and Test Procedures for Opacity Continuous Emission Monitoring Systems in
Stationary Sources, to govern the design, performance, and installation of COMS (40 FR 64250,
October 6, 1975). In 1983, the EPA amended PS-1 (48 FR 13322, March 30, 1983), and in 2000,
the EPA amended PS-1 again by incorporating ASTM D6216-98 design and monitor
manufacturer performance specifications (65 FR 48914, August 10, 2000).
Continuous paniculate mass monitoring was proposed as an EPA regulatory requirement
April 19, 1996, as part of the proposed Hazardous Waste Combustion MACT emission standard
(61 FR 17358). As part of the Hazardous Waste Combustion MACT, the EPA proposed PS-11,
Specifications and Test Procedures for Paniculate Matter Continuous Emission Monitoring
Systems in Stationary Sources, to evaluate the acceptability of a PM CEMS. The Portland
Cement Manufacturing MACT Final Rule in section 63.1250(k) (64 FR 31898, June 14, 1999)
makes mandatory the use of PM CEMSs although not until the EPA has finalized PS-11.
2.2 PAST STUDIES
During the 1970s, the EPA sponsored several studies to examine the applicability of
transmissometers to sources and the potential to correlate opacity to PM mass concentrations.
Some of those studies are summarized below. Into the 1980s, philosophies changed within the
EPA, and continuous PM monitoring was not a priority. Work on the PM CEMS in this country
stopped until new initiatives started in the mid 1990s.
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In a 1974 publication from the EPA's National Environmental Research Center, Conner
(1974) showed that smoke's opacity is related to (1) the size of the particles and (2) the light
wavelength used by a transmissometer. Particles much smaller than the light wavelength
(particle diameter < 0.05 urn in white light) contribute little to the opacity (extinction coefficient
< 0.01). For particles much larger than the light wavelength (particle diameter > 2 urn in white
light), the opacity is not a function of the light wavelength, and the mean extinction coefficient is
about 2. For particles about the same size as the light wavelength (0.05 < d < 2 um in white
light), opacity has a strong dependence on the particle diameter, that is, the extinction coefficient
increases from 0.01 to as high as 3 or 4 as the particle diameter increases from 0.05 um to 2 um.
Also, Conner detailed the effect of a transmissometer's light wavelength on the opacity of fine
particles (Conner et al., 1967). Opacity determined from a blue light source has a positive bias
(e.g., in a white plume, an opacity of 25 percent, as determined by white light, is seen as about
40 percent by blue light), and opacity determined from a red light source has a negative bias (e.g.,
in a white plume, an opacity of 25 percent, as determined by white light, is seen as about
18 percent by red light). Opacity determined from an infrared light source has a strong negative
bias (e.g., in a white plume, an opacity of 25 percent, as determined by white light, is seen as
about 5 percent by infrared light). A black plume demonstrates the same biases but to a lesser
degree.
As of 1974, the EPA had not resolved a transmissometer's ability to monitor PM mass
concentrations from sources. Some investigators reported good empirical correlations between
mass concentration and light transmittance while others indicated that the effect of particle
characteristics on the correlation was too strong for a meaningful correlation. At that time, the
researchers clearly understood that for a useful correlation to exist between opacity and PM mass
concentration, the particle characteristics (size, shape, and composition) needed to be sufficiently
consistent and to remain consistent over time (Conner, 1974). Conner (1974) showed mass
concentration versus opacity for a kraft pulp mill recovery furnace, a cement plant kiln, and a
coal-fired boiler. The concentration versus opacity graphs showed that a strong linear
relationship existed between mass concentration and opacity at those three sources. Conner
noted that paniculate emission control devices would likely control the paniculate characteristics
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that most affect the opacity to mass concentration correlation sufficiently enough that a
transmissometer could be used as a mass monitor.
In a 1975 journal article, John Nader, Chief of the Stationary Source Measurements
Research Section of the EPA's National Environmental Research Center, published a summary
of the current technologies for continuously monitoring PM emissions. In his paper, he
discussed electromagnetic techniques, beta attenuation techniques, optical techniques (both light
attenuation and light scatter), and electrical techniques. At the time his paper was published,
most of the instruments were prototypes. Nader concluded that a performance specification for
particulate mass concentration monitors would be developed in the near future.
In a 1979 publication from the EPA's Environmental Sciences Research Lab, Conner,
Knapp, and Nader (1979) presented, in addition to other things, the existence of a functional
relationship between in-stack transmissometer-measured opacity and mass concentration of PM
emissions. This examination was done at Portland cement plants and oil-fired power plants.
Their paper contained the following equation that demonstrates that the opacity-mass
concentration relationship depends on the chemical and physical characteristics of the particles,
as well as the pathlength of the opacity measurement:
where:
O = opacity
A = attenuation per unit path length per unit mass concentration
C = mass concentration
H. = pathlength of opacity measurement
Tests to correlate opacity and mass concentration were done at three cement plants; two
used the wet-process rotary kiln with PM emissions controlled with ESPs and one used the dry-
process rotary kiln with a baghouse for PM emissions control (Conner, Knapp, and Nader, 1979).
Opacity measurements were made with either a Lear Siegler RM4 or RM41P. Mass
concentrations were determined by EPA Reference Method 5. The results of their study indicate
that the light attenuation coefficient of PM emissions at cement plants is linearly related to the
PM mass concentration for both wet and dry processes. However, for the correlation done at
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actual stack conditions, the slopes of the curves (attenuation coefficient/mass concentration) were
distinctly different for the wet process (1.55±0.02 m"'/g/m3) and the dry process
(0.92±0.08 m'Vg/m3). Note, the correlation for the process controlled by the baghouse was
developed from only three data points within a narrow opacity range of about 6 percent to
8 percent. This suggests caution when interpreting these results.
Other tests to correlate opacity and mass concentrations were done at three oil-fired
power plants (Conner, Knapp, and Nader, 1979). The boilers had no PM emission control
equipment installed. Two plants combusted low-sulfur oil, and the boilers were fired at excess
oxygen levels between 1.5 percent and 3.0 percent. The third plant combusted high-sulfur oil,
and the boiler excess oxygen was at 0.2 percent. Opacity measurements were made with a Lear
Siegler RM41P. Mass concentrations were determined by EPA Method 5. The data from the
two similar plants were combined, and a light attenuation coefficient per mass concentration ratio
(at actual stack conditions) of 0.43 m'Vg/m3 was calculated. This relationship was calculated
over an opacity range from about 2.5 percent to 6.7 percent and forced through the origin. The
data for the high-sulfur, oil-fired boiler produced a light attenuation coefficient per mass
concentration ratio (at actual stack conditions) of 0.20 nv'/g/m3. This relationship was calculated
from data collected during two sampling efforts 6 months apart covering an opacity range from
about 6 percent to 11 percent. This relationship was also forced through the origin. The authors
stated their reason for the difference in the correlations as follows: the low excess oxygen
combustion produced a greater portion of particles (unburned carbon) in the large size fraction
(mean diameter of about 3 um compared to less than 0.3 um) and therefore, as expected,
produced lower opacity readings.
In a 1980 article, Uthe published the results of an evaluation of a relatively inexpensive
infrared transmissometer used as a PM mass concentration monitor. Uthe's results showed that
the extinction-to-mass concentration for a given aerosol type is dependent on particle size within
the visible light spectrum but nearly independent of particle size at the infrared wavelength. Uthe
tested his IR transmissometer in an aerosol chamber with three distinct particle size ranges:
0-2.5 um, 2.5-5 um, and 5-1Q um. His particles were composed of fly ash, iron oxide, and silica.
For fly ash particles in the size range of 0-10 um, the ER extinction to mass concentration ratio
varied by a factor of 1.6 while the variability for visible light was a factor of 4.4. For silica
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particles, the IR extinction to mass concentration ratio was nearly constant while the variability
for visible light was about a factor of 3. Personal communication with Uthe revealed that the IR
transmissometer was never evaluated on a real emission source.
During a 1-year period in 1976-1977, a group of researchers from the Industrial Research
Institute, University of Windsor (Gnyp et al., 1978), conducted a field evaluation of five different
PM monitors. The test was done at a secondary lead smelter. The stack exhaust consisted of
paniculate from uncontrolled lead alloying kettles and a reverberatory furnace controlled with a
fabric filter. Thirty-two PM test runs were conducted over a 9-month period from June 4, 1976
to March 7, 1977. Twelve tests accounted for the reverberatory furnace mode of operation (i.e.,
controlled emissions). The remaining 20 tests were conducted while refining processes were in
progress (i.e., uncontrolled emissions). The arithmetic mean particle diameter of the baghouse
emissions was 0.43 urn with a standard deviation of 0.13 urn. The arithmetic mean particle
diameter of the emissions from the lead kettles was 18.9 urn with a range from 0.05 um to 150
um. The particulate consisted primarily of lead, tin, and zinc. The results of the PM monitor
evaluation are summarized in Table 2-2.
TABLE 2-2. PM MONITOR EVALUATION RESULTS
AT A SECONDARY LEAD SMELTER
PM monitor
LearSieglerRM41
transmissometer
Contraves Goertz with
RAC transmissometer
Environmental Systems
Corporation PILLS V light
scatter monitor
Results
Impossible to correlate all 32 tests to one curve
Three distinct linear correlations were evident
Most reliable of all monitors tested
Not applicable for sources where process variations cause changes
PM size, color, or refractive indices
in
Impossible to correlate all 32 tests to one curve, basically the same
results as the RM41
Not capable of detecting large particles greater than 25 um in diameter
Correlation was relatively independent of changes in particle size,
and refractive index
color,
More useful than the best transmissometers
Some of the variability in the data was attributed to changes in
absorptive components of refractive indices
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TABLE 2-2. (CONTINUED)
PM monitor
IKOR 2710 charge transfer
Research Appliance Co.
(RAC) beta gauge monitor
Results
Limited sensitivity to particles smaller than 1 jam diameter; particles
must contact sensor
At the stack conditions, only particles larger than 4 um in diameter
made contact with the sensor surface
Orienting the sensing element with its axis perpendicular to the flow did
not improve the contact of small particles
Expected a single correlation curve, but instrument was more sensitive
to smaller particles less than 1 urn in diameter
Substantial amounts of PM were recovered from the sampling system at
the end of the test program
Experienced many operational breakdowns, only functioned for 1 3 test
runs
The developmental testing of PM CEMSs in Germany started during the 1960s when the
TUV-Rheinland (the German "technical inspection agency," a not-for-profit organization similar
to Underwriters Laboratories in the United States) first investigated continuous PM monitors
(Draft Technical Support Document, 1996). The early tests involved transmissometers. Initially,
eight devices were evaluated, but all failed to perform to the satisfaction of TUV. After
improvements were made, TUV Rheinland certified two transmissometers in 1968 (Peeler et al.,
1995). The first certification of a PM CEMS (a transmissometer) was issued in 1974 and
prompted the German Federal Law of Immission Protection to require continuous monitoring of
PM emissions at power plants. A further reduction in particulate emissions was required with
the passage of the First Regulation of General Administration Procedures to the Federal Law of
Immission Protection on February 27, 1986. This latter act spurred the use of more sensitive
monitors to measure PM emissions from well-controlled waste incinerators.
As previously noted, during the early period of continuous PM monitoring in Germany,
transmissometers were used to measure extinction (b = 2.303 * log(l/T) / PL) and were
correlated to PM concentration. A key advantage of using extinction rather than opacity is that
extinction relates linearly to particulate matter. Extinction also results in an output that is more
sensitive to increases in PM concentration at low levels. The transmissometers were typically
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operated at two measuring ranges, 0-9 percent or 0-33 percent opacity. For a 1-meter pathlength,
a transmissometer's minimum quantifiable PM concentration is about 30 mg/acm (Peeler et al.,
1995). From 1968 through 1985, approximately 1,000 to 2,000 transmissometers, measuring
extinction, were installed on all types of sources in Germany measuring PM emission limits in
the range of 30 mg/m3 to 150 mg/m3. Furthermore, approximately 5,000 transmissometers,
measuring opacity, were installed for monitoring control equipment performance. Then, as PM
concentrations decreased to levels too low to be accurately measured with transmissometers, use
of the light scattering type PM CEMS came into favor. Light scatter monitors are 100 to 1,000
times more sensitive than transmissometers. A light scattering monitor's output is directly
proportional to PM concentration, and thus inversely proportional to a transmissometer output
(i.e., it cannot be used as a substitute for an opacity monitor). Since 1986, light scatter monitors
represent about 80 percent of new PM monitors installed in Germany (Peeler et al., 1995).
During the 1990s, many existing transmissometers were replaced with light scattering type PM
CEMS as facilities updated their pollution control equipment to come into compliance with more
stringent regulations. The suitability testing for transmissometers is governed by VDI Guideline
2066, Part 4. The suitability testing of light scattering type PM CEMSs is governed by VDI
Guideline 2066, Part 6.
2.3 CURRENT EUROPEAN EXPERIENCE
In Germany, a specific model PM CEMS must pass a suitability test and be approved by
the Federal Environmental Agency before it can be installed and used as a PM CEMS to meet
regulatory monitoring requirements. The suitability test follows guidelines in a Standard Practice
regarding the monitoring of emissions (Standard Practice, 1990, revised June 8, 1998). The
source-specific acceptance of a suitability test is based on a hierarchy of difficulty in passing the
test; incinerators are most difficult, followed by coal, oil, and gas-fired plants. Thus, if a monitor
passes suitability for an incinerator, the monitor is also approved for all the less difficult sources.
However, sources such as cement kilns and metal recovery furnaces are separate and require their
own suitability test (Draft Technical Support Document, 1996). The specifications that a PM
monitor must meet to gain approval are presented in Table 2-3. The suitability test consists of
both a laboratory evaluation and a field evaluation. In most cases, the suitability test is done by
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the TUV branch in Rheinland; however, TUV is not the only organization that can do the
suitability test.
TABLE 2-3. GERMAN SUITABILITY TEST SPECIFICATIONS FOR APPROVAL
Test
Normative conditions
Endurance test
Analytical function
Protection from changing
settings (Security)
Zero and reference point
position
Full scale readout range
Measured value output
Status signals
Availability
Maintenance interval
Reproducibility - for all PM
CEMS since 1998
Complete system
Specification"
Suitability testing must be done according to guidelines in VDI
2449 part 1 dated February 1995.
Conduct an endurance test for at least 3 months. If possible,
conduct the test at a single test site for a continuous period.
In suitability testing, the relationship between the instrument
reading and mass concentration from a reference measuring method
must be determined by regression analysis. Each instrument must
be supplied with a characteristic curve plotted by the manufacturer.
The instrument and control units must be secured against
unauthorized or inadvertent change during operation.
The zero point should be 10 percent to 20 percent of full scale on
the instrument display and recording device. The reference point
should be 70 percent to 90 percent of full scale.
The readout range should equal:
2.5 to 3 times the applicable emission limit for a coal-fired
furnace
1.5 times the applicable emission limit for a waste incinerator
The instrument must have two readout channels.
The instrument must have status signals for
1 . Operation
2. Service
3. Malfunction
The instrument must achieve 90 percent data availability during
continuous operation and 95 percent availability during the
evaluation test.
The instrument's maintenance period must be at least 8 days (i.e.,
no operator intervention for at least 8 day intervals). Maintenance
period is determined during the field evaluation.
RD > 50 for a measuring range > 20 mg/m3
RD > 30 for a measuring range < 20 mg/m3
The suitability test covers the entire CEMS.
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TABLE 2-3. (CONTINUED)
Test
Specification3
Normal operating conditions
Evaluate the instrument under the following conditions over the
manufacturer's recommended range for each:
1. Supply voltage variation
2. RH in ambient air
3. Liquid water in the air
4. Vibration and shock
Automatic readjustment
For instruments with self-testing of proper operation and automatic
readjustment, test these features in the evaluation test. If an
adjustment range of ±6 percent of span is exceeded during
autoconnection, an alarm must be given.
Ambient temperature range
For instruments installed unprotected from ambient conditions, the
instrument must operate over the range of
-20°C to 50°C. For temperature-controlled installations, the
instrument must operate over the range of 5°C to 40°C.
Test instrument in a climate chamber.
Effect of sample gas flow
For instruments using a bypass for sampling, the effect of changes
in sample gas flow rate on the measured signal must not exceed
±1 percent of span. Neither the total volumetric flow sampled
during the operating cycle nor the dilution air volumetric flow may
deviate from the expected value by more than ±8 percent.
Multicomponent instrument
Each component must fulfill the requirements, even when all
measuring channels are operating simultaneously.
Drift between servicing
intervals
The zero point must not drift more than
±2 percent of full scale for range > 20 mg/m3
±3 percent of full scale for range < 20 mg/m3
The reference point must not drift more than
±2 percent of the reference value for range >: 20 mg/m3
±3 percent of the reference value for range < 20 mg/m3
Linearity
The difference between the actual value and the reference value
must not exceed ±2 percent of full scale (for a 5 point check).
Contamination check
If the measurement principle depends on optical methods, the
instrument must check for optical surface contamination during
operation. Use clean purge air to keep optical surfaces clean.
Outward migration of
measurement beam
If the measurement principle is based on optical methods, any
impairment due to outward migration of the measurement beam
must be stated and must not exceed 2 percent of full scale in an
angular range of ±0.3 °.
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TABLE 2-3. (CONTINUED)
Test
Automatic correction of zero
and reference points
Exhaust gas volume
Dead time, setting time (similar
to cycle time)
Specification51
The instrument must automatically initiate and record the zero
reference points at regular intervals. For instruments with
automatic zero point correction, the correction amount must be
recorded as a measure of contamination.
and
For extractive instruments, the sample volume must be within
±5 percent of the set point.
Measure the dead time to include: response time, analysis time, and
reporting time.
Specifications derived from TUV Suitability Test Reports for the Sigrist CTNR, Verewa F-904, and Durag D-R
300-40.
After a PM CEMS is installed, its output is correlated to manual gravimetric particulate
data. The stability of the correlation is checked by conducting additional manual gravimetric
tests at 3- to 5-year intervals, depending on the source type. A linearity check of the instrument's
response is also done annually (Peeler et al., 1995). The TUV has guidelines for establishing
correlation curves. Most of the manual particulate emissions measurements are done by an
isokinetic, in-stack filter test method (similar to Method 17 - VDI2066, Part 7); however, in-
stack sampling is limited to stacks with no entrained water droplets. The following guidelines
are used for a correlation test in Germany (personal communication with Dr. Wolfgang Jockel,
TUV, Rheinland):
The test program consists of 12 to 20 test runs.
A few paired train test runs are completed to demonstrate an ability to maintain precision.
If the testing team has experience at a source, they do not do any test runs with paired
trains.
Test runs are short, no longer than 30 minutes (this is so that any variability in PM
concentrations is noticeable and not averaged out by a long test run).
If the facility cannot achieve any variability in PM concentration, the correlation test
program is stopped after 6 test runs. Typically, waste combustion facilities have
extensive air pollution control systems (e.g., a water spray drier for cooling, a fabric filter,
an acid gas (HC1) scrubber, a lime scrubber SO2 control, a dual catalyst SCR and dioxin
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oxidizer, and an activated charcoal "police" filter), and the paniculate emissions cannot
be artificially adjusted to obtain a range of PM concentrations.
In cases with emissions that are very low relative to the limit, the guidelines allow
extrapolation of the correlation; however, data measured beyond the correlation range trigger
only additional testing, not noncompliance. For a correlation data set with only a cluster of data
points very much below the emission limit, the emission limit becomes related to the mA signal
of the PM CEMS. For example, if a PM CEMS output during the testing ranged from 4 mA to
4.5 mA, no 30-minute average may exceed 4.5 mA during plant operations. If an average
exceeds 4.5 mA, a new correlation test that includes values above 4.5 mA would have to be
done. For a limited correlation data set with little variability in PM concentration, the German
guidelines require the use of a hypothetical zero point (i.e., 4 mA = 0 mg/m3) in the correlation
data set for an in-situ light scatter type PM CEMS using little or no purge air and for an
extractive type PM CEMS (i.e., either beta gauge or light scatter).
The German approach to using a PM CEMS is to build the statistical uncertainty of the
PM CEMS measurement (due to the factors of particle composition and size distribution) into the
emission limit value. The correlation relation is not required to achieve a specific statistical
accuracy (e.g., a confidence interval < 10 percent at the emission limit value) to be approved.
This approach is illustrated in the following example. A municipal waste combustion facility has
a base PM emission limit (EL) of 30 mg/dscm. Assume a specific source's PM CEMS
correlation has a confidence interval (CI) at the emission limit of 4 mg/dscm (13 percent) and a
tolerance interval (TI) at the emission limit of 11 mg/dscm (37 percent). Then, that specific
source would have the following PM limitations (from personal communication with Dr.
Wolfgang Jockel, TUV, Rheinland):
No 30-minute average may exceed: 2*EL + TI = 60 + 11 = 71 mg/dscm.
97 percent of the annual 30-minute averages may not exceed: 1.2(EL + CI) = 36 + 5 =
41 mg/dscm.
No daily average may exceed: EL + CI = 30 + 4 = 34 mg/dscm.
Even with the uncertainty in the PM CEMS measurement, the correlation relationship can still be
used as a basis for compliance. Traditionally, the EPA regulations have taken this uncertainty
into account when a CEMS-based standard is adopted.
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In addition to the suitability testing specifications that exist in Germany, the International
Standards Organization (ISO) has developed standards for PM CEMSs. The ISO committee
TC146/SC1/WG1 finalized ISO 10155 "Stationary Source Emissions - Automated Monitoring of
Mass Concentrations of Particles - Performance Characteristics, Test Methods, and
Specifications" on April 1, 1995. ISO 10155 specifies conditions and criteria for the automated
monitoring of PM mass concentrations in stationary sources. The specifications are general and
not limited to a specific measurement principle or system. The Central European Normalization
(CEN) Committee TC264/WG5 has developed requirements applicable to continuous PM
monitoring. CEN adopted ISO 10155 for hazardous waste incinerators.
The Environment Agency (EA) in the United Kingdom (UK) has established a
monitoring certification scheme (MCERTS) for all CEMSs, including PM CEMSs. The
MCERTS program is similar to the program used in Germany and began on April 22, 1998. The
performance standards have been specified for the following sources:
Large combustion plants
Municipal and hazardous waste combustors
Solvent-using processes
The instrument performance standards are based on relevant sections of several ISO and
CEN standards. These standards are published as EA standards under the MCERTS program.
Instrument testing is done in two parts; laboratory tests and a 3-month field evaluation. The
standards cover the performance characteristics presented in Table 2-4.
TABLE 2-4. MCERTS PM CEM EVALUATION CHARACTERISTICS
Laboratory test
Use a wind tunnel test with well characterized
and reproducible particle-size distribution with
mass concentration variable from 0 to 500 mg/m3
at a gas flow velocity of 1 .5 to 50 ft/s
Response time
Calibration to PM generated in wind tunnel
Linearity of PM CEM response to changes in PM
concentration at 5 levels
Field evaluation
Accuracy - as calibrated according to ISO
10155
Reproducibility from two identical PM CEMS
Zero and upscale drift during the field test
- average of daily drifts over a month
period
Data availability
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TABLE 2-4. (CONTINUED)
Laboratory test
Cross-sensitivity to gases, velocity changes at a
fixed PM concentration, and particle size changes
Establishment of a lower detection limit
Repeatability of the PM CEM's output to a
continuous PM concentration in tunnel
Change in zero value to variations in
Ambient humidity
Ambient temperature
Vibration
Mechanical shock
Magnetic field
Aging
Field evaluation
Maintenance interval - time over which the zero
and upscale drifts remain within specification
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3.0 ANALYTICAL PRINCIPLES
Five analytical principles used in instruments to measure PM concentrations are described
below. These principles are light scattering, beta attenuation, probe electrification, light
extinction, and optical scintillation.
3.1 LIGHT SCATTERING
Light is both absorbed and scattered by particles in the path of the light. Scattering is due
to reflection and refraction of the light by the particle. The amount of light scattered is based on
the concentration of particles and the properties of the particles in the light's path (e.g., the size,
shape, and color of the particles). If the wavelength of the incident light is much larger than the
radius of the particle, a type of scattering called "Rayleigh" scattering occurs. Rayleigh
scattering causes the blue color of the sky because visible sunlight is scattered by very small
particles and gases in the upper atmosphere. If the wavelength of the incident light is about the
same size as the radius of the particle, a type of scattering called "Mie" scattering will occur.
Mie scattering causes the haze seen on a hot summer day and the reduction of visibility by car
headlights in a fog.
A light scatter type instrument measures the amount of light scattered in a particular
direction (i.e., forward, side, or backward) and outputs a signal proportional to the amount of
scattering material (e.g., particulate matter) in the sample stream. The PM concentration is
derived by correlating the output of the instrument to manual gravimetric measurements. In a
scatter light instrument, a collimated beam of visible or near infrared (IR) light is emitted into a
gas stream. The light is scattered by particles in the light path (i.e., Mie scattering), and the
receiving optics focus an area of that light onto a detector that generates a current proportional to
the intensity of light it receives. The angle of the source to the receiving optics and the
characteristics of the optics determine the volume of space from which the scattered light is
measured.
Some components included in these instruments to minimize the effect of interference
and degradation of the light source are: (1) the use of a pulsed light and (2) parallel measurement
of the light source intensity. The use of the pulsed light source limits the possibility that light
from some other source (e.g., ambient light) will be measured, because the instrument only
measures the reflected light while the instrument light source is on. The parallel measurement of
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the light source intensity accounts for degradation of the light source because a reference of the
source intensity is measured along with each scattered light measurement.
3.2 BETA ATTENUATION
When beta rays pass through a material, they can be absorbed, reflected or pass directly
through. The attenuation of intensity in beta rays is proportional to the amount of material
present. The attenuation through most materials is relatively consistent and is based on the
electron density of the material (calculated by dividing the atomic number by the atomic mass).
The attenuation for most materials is about 0.5, except for hydrogen and heavy metals. Beta
attenuation has been used in production lines as a quality control check of product thickness for
more than 40 years. For example, in the production of cellophane plastic wrap, a beta gauge is
used to ensure that the thickness of the cellophane remains within specification.
The principle behind beta attenuation paniculate sampling instruments (beta gauge) is
that energy is absorbed from beta particles as they pass through PM collected on a filter media.
Beta gauge instruments have been designed to take advantage of this scientific principle to
monitor/measure PM concentrations. The attenuation due to only the PM is measurable if a
baseline beta count through just the filter can be established prior to sampling. The difference
between the baseline beta count and the beta count after sampling is directly proportional to the
mass of PM in the sample.
The two main components of a beta attenuation measuring system are the beta source and
the detector. The beta source must be selected so that: it has an energy level high enough for the
beta particles to pass through the collection media (i.e., the filter tape) and the paniculate, it has
enough source material so that a high count rate is present, it is stable over long periods of time,
and it does not present a danger to the health of personnel that come into contact with the
instrument. The source of choice has been Carbon-14 because: it has a safe yet high enough
energy level, it has a half-life of 5,568 years, and it is relatively abundant. Many different types
of detectors can quantify beta particle counts, but the ones most widely used are the Geiger
Mueller counter or a photodiode detector.
The beta gauge works by measuring beta counts before and after collecting PM on a filter
media. The instrument will measure a clean area of the filter media for a fixed period to
determine the baseline (e.g., 2 minutes), then it will advance that area of the filter to a sampling
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apparatus for another set period of time (e.g., 8 to 9 minutes), and finally return that area of the
filter to the detector for the same period used to establish the baseline reading. The difference in
the beta count can be directly correlated to paniculate mass through calibration of the instrument
using a filter media containing a known mass of a particulate-like material.
The beta gauge instrument is designed to provide a mass concentration. The instrument
measures the volume of gas extracted from the stack/duct for each sample interval and calculates
mass concentration in the specified units (e.g., mg/dscm).
3.3 PROBE ELECTRIFICATION (TRTBOELECTRIC EFFECT)
Probe electrification takes advantage of the fact that all particles have a charge.
Electrostatic charges from the friction of particles contacting a probe will electrify the probe (i.e.,
a small current is produced in the probe). This is called triboelectricity. Another applicable
mechanism is based on a small current being induced in the probe when charged particles pass
near a probe.
A triboelectric paniculate monitoring device measures the direct current (DC) produced
by the charge transfer when particles strike the probe. The DC is measured by an electrically
isolated sensor probe that is connected to amplification electronics. Multiple particle strikes
create a small flow of current through the instrument; current is proportional to the momentum
(mass times velocity squared) of the particles. Amplification electronics convert the current to an
instrument output signal. Monitors that rely on inducing a current in the probe, rather than
particle contact with the probe, work similarly except an alternating current (AC) is measured.
Because the signal produced by these monitors may be affected by several factors, the
instrument output must be correlated to manual gravimetric measurements. Some of the primary
factors that may affect the relationship between particle mas and the monitored signal are particle
velocity for triboelectric devices, particle characteristics (e.g., composition and size), and particle
charge. Probe electrification does not work well in wet gas streams with water droplets or when
the particles are subject to a varying electrical charge. The AC component of the induced current
is being used to minimize the effect of velocity on the measurement.
3.4 LIGHT EXTINCTION (TRANSMISSOMETER)
Light extinction is a common method in use today; the instruments that incorporate this
technology are referred to as transmissometers or opacity monitors. These instruments measure
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the loss of light intensity across a participate laden gas stream as a function of Beers-Lambert's
Law. The intensity of the light at the detector, I, is compared with the reference light intensity, I0,
to give the transmittance, T = I/I0. Transmittance can be converted to opacity, Op = 1-T, or
optical density, D = log(l/T). The loss of light intensity can be correlated to particulate mass
concentration measured by manual gravimetric sampling. In general, the measurement
sensitivity of transmissometers is not fine enough to detect small changes in PM concentration.
For example, in a 2 meter diameter stack (4 m path length) the smallest emission standard that
should be measured with a transmissometer is 15 mg/m3 (personal communication with
Dr. Wolfgang Jockel, TUV Rheinland, email dated March 20, 2000).
The basic operational principle of these instruments is that a collimated beam of visible
light is directed through a gas stream toward receiving optics. The receiving optics measure the
decrease in light intensity, and the instrument electronics convert the signal to an instrument
output. An instrument incorporating the components described in the previous sentences would
be considered a single pass system. For better resolution and higher accuracy, a dual-pass
transmissometer and a modulating light source are used. The dual-pass transmissometer (with a
reflector mirror on the opposite side of the stack from the light source) allows all of the
instrument electronics to be incorporated into one unit. A high frequency modulation of the light
source limits the possibility of interference because the instrument only reads the loss of light
while the light source is on. When an LED light source is used, electronic modulation of the
light (instead of chopping) is possible. Incorporating the light source and detector into one
instrument also allows direct measurement of the loss of light by comparison of the source
intensity and the loss of light at the same time. This helps prevent inaccurate readings due to the
degradation of the light source intensity (a common problem in basic transmissometers).
-A transmissometer used as a PM CEMS should use a red or near infrared light source,
and not the white light source used on traditional opacity monitors (see Section 2.2, the
discussion of Uthe's work, for an explanation). Some manufacturers have started using a green
LED to monitor both opacity and PM concentration simultaneously. Furthermore, the opacity
monitor's correlation to PM concentration as measured by the Reference Method should be done
versus opacity or optical density.
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3.5 OPTICAL SCINTILLATION
Optical scintillation, like light extinction, utilizes a light source and a remote receiver that
measures the amount of received light. The difference is that the scintillation monitor uses a
wide beam of light, no focusing lenses, and the receiver measures the modulation of the light
frequency due to the movement of particles through the light beam and not the extinction of light.
The principles at work here are that the particles in a gas stream will momentarily
interrupt the light beam and cause a variation in the amplitude of the light received (scintillation).
The greater the particle concentration in the gas stream the greater the variation in the amplitude
of the light signal received. The scintillation monitor must be calibrated to manual gravimentic
measurements at the specific source on which it is installed.
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4.0 SUMMARY OF KNOWN PM CEMS
Based on the analytical measurement principles presented in Section 3.0, instrument
manufacturers have developed monitors to continuously measure PM concentrations in source
emissions. Most of these monitors measure a property of the paniculate matter in the stack (e.g.,
scatter of light, transfer of charge, or modulation of transmitted light) and the concentration is
then inferred based on a correlation to manual gravimetric samples. In contrast, the beta
attenuation monitors produce results on a concentration basis from the mass of paniculate matter
collected on a filter divided by the volume of gas sampled through the filter.
This section presents a summary of most of the monitors that are commercially available
from manufacturers as "off-the-shelf PM CEMS, as listed below. Mention of specific
manufacturers equipment is not an endorsement of the product by the EPA. These descriptions
are solely for informational purposes.
4.1 Durag F904K Beta Attenuation
4.2 Environment S.A. 5M Beta Attenuation
4.3 Mechanical Systems Inc BetaGuard PM Beta Attenuation
4.4 Sigrist KTNR and CTNR Extractive Light Scatter
4.5 Durag DR-300-40 In-situ Light Scatter
4.6 Environmental Systems Corporation P5 In-situ Light Scatter
4.7 Sick Inc. RM210 In-situ Light Scatter
4.8 Sick Inc. FW 100 and FWE 200 Light Scatter
4.9 Grimm Technologies 6300 In-situ Light Scatter
4.10 Monitor Labs 300L In-situ Light Scatter
4.11 BHA Group CPM 5000 Scintillation
4.12 PCME Scintilla SC600 Scintillation
4.13 Insitec TESS In-situ or Extractive Laser Light Extinction-Scatter
4.14 PCME Dust Alert 90 Electrostatic Induction
4.15 Auburn International Triboguard HI or n In-situ Triboelectric
4.16 Codel StakGard Triboelectric Dust Monitor
4.17 Opacity/Transmissometers
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Many of these PM CEMSs have been in use for 10 or more years while others are
relatively new. Source specific applicability of each of these PM CEMSs is presented in
Section 7.0, PM CEMS Implementation.
4.1 DURAG F904K BETA ATTENUATION
The F904K extracts a sample from the stack, transports the sample to the instrument
through a heated line, and deposits PM on a filter tape during user-selected sampling periods
(e.g., 4 to 8 minutes). Before and after each sampling period, the filter tape is moved between a
carbon 14 beta particle source and Geiger-Mueller detector. The amount (in units of mg) of PM
on the filter is determined by the reduction in transmission of beta particles between the readings
for the dirty tape and the clean tape. This instrument measures the sample gas volume on a dry
basis, and therefore outputs PM concentration in units of mg/dscm. The F904K samples
isokinetically at normal stack gas velocity, but isokinetic sampling is not actively maintained
(i.e., when the stack gas velocity decreases, the F904K's sampling rate remains constant creating
a superisokinetic sampling condition and a low bias to the measured PM concentration). To
minimize particulate loss in the sampling system, the F904K introduces dilution air after the
sampling nozzle and samples at a high rate of about 3,000 liters per hour (~ 1.75 cfm); however,
this sampling rate can be modified as needed for site-specific conditions. The measuring range is
determined by the length of the sampling period, but the instrument can only accommodate up to
6 mg to 8 mg of particulate deposited on the filter tape during each sampling period. If too much
particulate is collected during a sampling interval, a high vacuum is created, and the sampling is
curtailed. This instrument does automatic zero and upscale drift checks to meet daily QC check
requirements.
The distance between the probe and instrument is recommended to be less than 20 feet.
The footprint of the F904K is approximately 30 inches by 48 inches with clearance needed in
front and behind the case to open the doors. The instrument weighs about 400 pounds. A single,
6-inch port is needed for the probe installation into the stack. This instrument also requires a
supply of high-pressure air and 230V of electrical power.
The F904 version was approved by the German TUV in 1990 for all sources. The F904
version was evaluated by the EPA/OSW at the long-term field test at the DuPont Experimental
Field Station liquid waste incinerator and by Eli Lilly (only during phase II) at a liquid waste
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incinerator. The F904K was evaluated by the EPA/OAQPS at a coal-fired boiler and by the
Department of Energy at the radionuclide incinerator at Oak Ridge National Lab. The instrument
is relatively insensitive to changes in the PM composition and PM properties and is not affected
by the presence of condensed water droplets in the gas stream. Although the instrument output is
in units of mg/dscm, a correlation to manual gravimetric data is recommended to account for any
particulate stratification at the sampling point.
4.2 ENVIRONMENT S.A. 5M BETA ATTENUATION
The Beta 5M extracts a sample from the stack through a heated probe and deposits PM on
a filter tape during user defined sampling periods (e.g., 4 to 8 minutes). The instrument mounts
onto the end of the probe and thus does not have a sampling line. At the end of each sampling
period, the filter tape is moved between a carbon 14 beta particle source and a detector. The
amount (in units of mg) of PM on the filter is determined by the decrease in beta particles
passing through the dirty tape as compared to the clean tape. This instrument measures the
sampled volume on a wet basis, and therefore, outputs PM concentration in units of mg/acm.
Since the sampled volume is measured on a wet basis, the instrument is susceptible to clogging
in the volume measurement lines when used in high-stack-gas-moisture environments. The Beta
5M maintains isokinetic sampling with real-time AP and temperature measurements. Before the
analysis is done at the end of each sampling period, the probe nozzle is closed, opened, and
closed again creating a vacuum to re-entrain any PM deposited in the probe. The measuring
range is determined by the length of the sampling period, but the instrument does have a lower
detection limit. Currently, this instrument does not do automatic zero and upscale drift checks,
but the manufacturer is reportedly developing this capability.
The footprint of the Beta 5M is a box attached to the probe with dimensions of
approximately 15 inches by 30 inches by 30 inches that hangs from a support frame attached to
the stack. The instrument weighs about 180 pounds. A single, 6-inch port is needed for the
probe installation into the stack. This instrument also requires a supply of high-pressure air and
either 115V or 230V of electrical power.
The Beta 5M was evaluated by the EPA/OSW at the long-term field test at the DuPont
Experimental Field Station liquid waste incinerator, by Eli Lilly at a liquid waste incinerator, and
by the Department of Energy at the radionuclide incinerator at Oak Ridge National Lab. The
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instrument is relatively insensitive to changes in the PM composition and properties and is not
affected by the presence of condensed water droplets in the gas stream, except for the potential of
clogging the sample volume lines. Although the instrument output is in units of mg/acm, a
correlation to manual gravimetric data is recommended to account for any particulate
stratification at the sampling point.
4.3 MECHANICAL SYSTEMS INC. BETAGUARD PM BETA ATTENUATION
The BetaGuard PM extracts a sample from the stack, transports the sample to the
instrument through a heated line, and deposits PM on a filter tape during user-selected sampling
periods (e.g., 4 to 8 minutes). Before and after each sampling period, the filter tape is moved
between a carbon 14 beta particle source and Geiger-Mueller detector. This instrument uses a
dual beta source-detector arrangement to minimize lost sample time (i.e., sampling is occurring
on a second "spot" while a measurement is being made on the first "spot"). The amount (in units
of mg) of PM on the filter is determined by the reduction in transmission of beta particles
between the readings for the dirty tape and the clean tape. This instrument measures the sample
gas volume on both a wet and dry basis, and therefore outputs PM concentration in a variety of
units. The BetaGuard PM actively samples isokinetically by receiving a stack gas flow rate
signal from a flow monitor. Isokinetic sampling is maintained by holding the total sample flow
rate constant and then varying the amount of dilution air that is added to the sample gas. The
measuring range is determined by the length of the sampling period and the selected nozzle size.
The instrument can measure in a range from 1 to 500 mg/dscm. If too much particulate is
collected during a sampling interval, a high vacuum is created, but, instead of aborting the
sampling cycle, the amount of PM is measured and a new sampling cycle is started. This
instrument does automatic zero and upscale drift checks to meet daily QC check requirements.
Additionally, this instrument automatically does daily sample flow rate checks.
The distance between the probe and instrument is recommended to be less than 50 feet.
The footprint of the BetaGuard PM is approximately 12 inches by 30 inches with clearance
needed in front of the case to open the door. The instrument weighs about 350 pounds. A single,
6-inch port is needed for the probe installation in most stacks. This instrument also requires a
supply of high-pressure air and 120V of electrical power.
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The BetaGuard PM has undergone field trials done by the vendor and is being evaluated
in a second Electric Power Research Institute (EPRI) field evaluation at a coal-fired boiler. The
instrument is relatively insensitive to changes in the PM composition and PM properties and is
not affected by the presence of condensed water droplets in the gas stream. Although the
instrument vendor asserts that a site specific correlation to manual gravimetric data is not needed
for a representative sample location, the EPA requires a PS-11 correlation test to account for any
paniculate stratification at the sampling point.
4.4 SIGRIST KTNR AND CTNR EXTRACTIVE LIGHT SCATTER
The KTNR and CTNR (newer version) are both PM CEMSs that use the principle of
forward light scattering at 15° in the visible to near infrared light spectrum. The measuring
ranges are from 0 to 0.1 mg/dscm up to 0 to 1000 mg/dscm. These instruments extract a heated
slipstream (1 mVmin) from a single point in the stack and pass a small portion (35 1pm) through a
photometer. The extracted gas is then returned to the stack. The extraction sample rate is over-
isokinetic at normal stack gas flow rate. The vendor notes that over-isokinetic sampling
significantly reduces the error caused by velocity fluctuations and is an alternative to continuous
monitoring of the stack gas velocity and adjustment of the sampling rate. The KTNR and CTNR
do not perform automatic zero and upscale drift checks, but manual drift checks can be done on
the CTNR.
The minimum space requirement for this instrument is a height of 8.5 feet, width of
5 feet, and a depth of 3.5 feet. For outdoor installations, a shelter must be provided. Two 4-inch
ports are needed for the extraction and return probes. The electrical power requirement is
3-phase 400V and 230V. A transformer is offered to facilities that do not have the required
power.
Both instruments were approved by the German TUV for all source categories. The
KTNR was evaluated by the EPA/OSW at the long-term field test at the DuPont Experimental
Field Station liquid waste incinerator, and the CTNR was evaluated by Eli Lilly at a liquid waste
incinerator and by the Department of Energy at the radionuclide incinerator at Oak Ridge
National Lab. The instrument response can be correlated in mg/acm by comparison to manual
gravimetric data. This instrument is sensitive to changes in particle characteristics (e.g., size,
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shape, and color), but because it heats the extracted sample gas to vaporize condensed water, it is
not affected by the presence of condensed water droplets in the gas stream.
4.5 DURAG DR-300-40 IN-SITU LIGHT SCATTER
The DR-300-40 PM CEMS uses the principle of side light scattering at 120° in the
visible light spectrum. This instrument's measuring ranges are from 0 to 1 mg/m3 up to 0 to
100 mg/m3, depending on the size of the aperture installed. It is therefore recommended for
measurements of low PM concentrations. The "sampled volume" (i.e., the volume of stack gas
where the scatter of light due to particles is detected) is located in an area 3 to 11 inches
(centered at 6 inches) from the instrument's face. The DR-300-40 does automatic zero and
upscale drift checks to meet daily QC check requirements.
The footprint of the DR-300-40 is a protective covering box attached to the stack with
dimensions of approximately 36 inches high by 24 inches wide by 30 inches deep. A separate
purge air blower and filter are needed near the instrument. The instrument weighs about
60 pounds, and the protective covering weighs about 15 pounds. A single, 5-inch by 12-inch port
with a supplied mating flange is needed for installation of this instrument onto the stack. If this
instrument is installed in a stack or duct less than 5 feet in diameter, an anti-reflective device
(light trap) should be installed in the opposite wall in line with the incident light. The electrical
power requirement is 110V.
This instrument was approved by the German TUV in 1992 for all source categories. It
was evaluated by the EPA/OSW at the long-term field test at the DuPont Experimental Field
Station liquid waste incinerator and by the EPA/OAQPS at a coal-fired boiler. The instrument
response can be correlated in mg/acm by comparison to manual gravimetric data. This
instrument is sensitive to changes in particle characteristics (e.g., size, shape, and color) and
presence of condensed water droplets in the gas stream.
4.6 ENVIRONMENTAL SYSTEMS CORPORATION P5 IN-SITU LIGHT SCATTER
The P5 uses the principle of backward light scattering at 175° in the near infrared light
spectrum. This instrument's measuring range is 0.5 mg/acm up to 20,000 mg/acm. The
measuring volume is located 4.75 inches from the physical end of the probe that contains both
the transmitting and receiving optics. The P5 does automatic zero and upscale drift checks to
meet daily QC check requirements.
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The footprint of the P5 is a box attached to the port flange with dimensions of
approximately 18 inches high by 12 inches wide by 36 inches deep. Also, additional clearance
beyond the physical depth is needed for the drive rod (the same length as the probe). With a
3-foot probe, the instrument weighs about 160 pounds. A single, 4-inch port with flange is
needed for installation of this instrument onto the stack. If the opposite wall of the stack is less
than 48 inches away from the end of the probe, an anti-reflective device (light trap) should be
installed in the opposite wall. The electrical power requirement is 110V.
This instrument was approved by the Korean Ministry of the Environment (non-technical
evaluation) for use as a source PM monitor. This instrument was evaluated by the EPA/OSW at
the long-term field test at the DuPont Experimental Field Station liquid waste incinerator and by
the EPA/OAQPS at a coal-fired boiler. It is also part of a second EPRI field evaluation at a coal-
fired boiler. The prototype to this instrument was evaluated at a secondary lead smelter by the
University of Windsor in 1976-1977. The instrument response can be correlated in mg/acm by
comparison to manual gravimetric data. Since this instrument measures in the near infrared, it is
less sensitive to changes in particle size, and it has a roughly constant response to particles in the
0.1 to 10 urn range. The P5 will measure condensed water droplets in the gas stream as
paniculate.
4.7 SICK INC. RM210 IN-SITU LIGHT SCATTER
The RM210 uses the principle of side light scattering at 90° in the visible light spectrum.
This instrument is ideally suited for measuring extremely low PM concentrations in the range of
0.0001 mg/acm up to 200 mg/acm. This instrument is available in the following three versions
depending on the needed penetration of the sampled volume:
Version 1, the sampled volume is 0.5 to 7 inches from the instrument's face,
Version 2, the sampled volume is 6.7 to 27.5 inches from the instrument's face, and
Version 3, the sampled volume is 13.4 to 63.8 inches from the instrument's face.
The RM210 does automatic zero and upscale drift checks using light attenuators. This
instrument is essentially the same size and shape as the Durag DR-300-40.
This instrument was approved by the German TUV for all source categories, and it was
evaluated by the EPA/OSW at an early, short-term field test. The instrument response can be
correlated in mg/acm by comparison to manual gravimetric data. This instrument is sensitive to
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changes in particle characteristics (e.g., size, shape, and color) and the presence of condensed
water droplets in the gas stream.
4.8 SICK INC. FW 100 IN-SITU AND FWE 200 EXTRACTIVE LIGHT SCATTER
The Sick FW 100 and FWE 200 are new, state-of-the-art PM CEMS that use the principle
of forward light scattering at 15° using a red laser light source. The FW 100 measures
particulate concentrations in-situ with a 31.5-inch probe. The FWE 200 extracts stack gas using
an eductor at over-isokinetic conditions, heats the sample gas in a thermal cyclone, then guides
the sample gas to the measurement cell where the PM concentration is measured with the
FW 100 probe. The sample gas is then deposited back into the stack. These instruments have
two measuring ranges: 0 to 5 mg/acm and 0 to 200 mg/acm with a resolution of 0.1 mg/acm.
The footprint for the FWE 200 is two boxes (a measurement and control cell and a blower
unit) with dimensions of approximately 33 inches high by 30 inches wide by 16 inches deep and
22 inches high by 22 inches wide by 11 inches deep. For outdoor installations, a cover is needed
for the blower unit. The measurement and control cell weighs about 150 pounds and the blower
weighs about 30 pounds. One 4-inch port is needed for the probe. The electrical power
requirement is 115 or 230V.
The FWE 200 is being evaluated by TUV for type certification. The instrument response
can be correlated in mg/acm by comparison to manual gravimetric data. This instrument is
sensitive to changes in particle characteristics (e.g., size, shape, and color), but because it heats
the extracted sample gas to vaporize condensed water, it is not affected by the presence of
condensed water droplets in the gas stream.
4.9 GRIMM TECHNOLOGIES 6300 IN-SITU LIGHT SCATTER
The Model 6300 uses the principle of backward light scattering in the red light spectrum
(660 nrn). An electronically modulated laser-diode is the light source. Since this instrument uses
a laser-light, a light trap must be installed on the opposite side of the stack to prevent
backscattering from reflection of the light on the opposite wall. This instrument's measuring
range is 0 to 1 mg/dscm up to 0 to 10,000 mg/dscm. The instrument contains both the
transmitting and receiving optics within a single box. The Model 6300 does not do automatic
zero and upscale drift checks to meet daily QC check requirements, these must be done
manually.
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The footprint of the Model 6300 is a box with dimensions of approximately 8 inches by
6 inches by 10 inches attached to a 3-inch port flange. The instrument assembly weighs about
30 pounds. The electrical power requirement is 110V.
This instrument was tested and approved by the German TUV at a waste incineration
source in accordance with the 17th BImSchV in the 0 to 20 mg/dscm measuring range. The
instrument response must be correlated by comparison to manual gravimetric data. The
manufacturer asserts that water droplets are widely ignored by the instrument, due to the
specially selected laser wavelength.
4.10 MONITOR LABS 300LIN-SITU LIGHT SCATTER
The 300L uses the principle of backward light scattering in the red light spectrum. An
electronic modulated laser emitting diode provides the light source. The laser light is directed
into the stack at a slight angle, so that, for stacks larger than about 6 feet, a light trap is not
needed. This instrument's measuring range is 0 to 20 mg/acm up to 20,000 mg/acm. Manual
zero and upscale drift checks can be done to meet daily QC check requirements.
The footprint of the 300L is a single optical head assembly attached to a special port
flange (provided by the vendor) with dimensions of approximately 15 inches long by 8 inches
high by 36 inches wide and weighing about 34 pounds. A single, 3.5 to 6-inch port with the
special flange is needed for installation of this instrument onto the stack. A purge air system
(about 17 inches wide by 8 inches deep by 37 inches high and weighing about 71 pounds) is
needed to keep the optical surface clean. The electrical power requirement is 120V.
The instrument response must be correlated in mg/acm by comparison to manual
gravimetric data. The 300L will measure condensed water droplets in the gas stream as
paniculate.
4.11 BHA GROUP CPM 5000 SCINTILLATION
The CPM 5000 uses the principle of scintillation or modulation in the intensity of the
transmitted light beam. The receiver senses the light signal modulation and converts it to PM
concentration (i.e., signal modulation is proportional to PM concentration). The transmitter and
receiver are located on opposite sides of the duct; therefore, this instrument measures across
stack PM concentration. As the PM concentration increases, the amplitude of the signal
modulation increases, and the instrument response can be correlated in mg/acm by comparison to
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manual gravimetric data. Because the CPM 5000 measures signal variations resulting from
moving particles rather than from a diminished intensity of the incident light beam, the
instrument is relatively unaffected by paniculate accumulation on the optics windows, optical
misalignment, or aging of the transmitter and receiver. The CPM 5000 has zero and upscale drift
check capabilities for daily QC checks.
The footprint of the CPM 5000 is a box containing the microprocessor controls with
dimensions of approximately 24 inches square and 6 inches deep. The transmitting and receiving
optical heads are small and are attached to 2.5-inch port flanges on opposite sides of the stack.
The microprocessor control box weighs about 30 pounds and the optical heads each weigh about
3 pounds. Two 2.5-inch ports are needed for installation of this instrument onto the stack. The
electrical power requirement is 110V.
This instrument was tested as part of the short-term field test done by EPRI at a coal-fired
boiler, and it is also being evaluated in a second EPRI field test. The CPM 5000 was approved
by the German TUV to meet the requirements for accuracy and repeatability for power plant
applications. The CPM 5000 will measure condensed water droplets in the gas stream as
paniculate.
4.12 PCME SCINTILLA SC600 SCINTILLATION
The Scintilla SC600 uses optical scintillation technology coupled with advanced design
techniques to monitor PM concentration. The SC600 can measure PM concentration as low as
2.5 mg/acm per meter of path length. The scintillation technology and advanced techniques
reduce zero and upscale drift. The instrument uses modulated light to eliminate effects of stray
or ambient light. The transmitter and receiver are located on opposite sides of the duct;
therefore, this instrument also measures across-stack PM concentration. The instrument response
increases with PM concentration and can be correlated in mg/acm by comparison to manual
gravimetric data. The SC600 has zero and upscale drift check capabilities for daily QC checks.
The footprint of the SC600 is a small control module with dimensions of approximately
10 inches wide by 7 inches high by 4 inches deep. The transmitting and receiving optical heads
are small and are attached to 2-inch port flanges on opposite sides of the stack. The control
module weighs about 8 pounds and the optical heads each weigh about 12 pounds. Two 2-inch
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ports are needed for installation of this instrument onto the stack. The electrical power
requirement is 110V.
This instrument was tested as part of the short-term field test done by the EPRI at a coal-
fired boiler, and it is also part of a second EPRI field evaluation at another coal-fired boiler. The
SC600 has MCERTS approval meeting the accuracy and repeatability requirements for power
plant applications. The SC600 will measure condensed water droplets in the gas stream as
particulate.
4.13 INSITEC TESS IN-SITU OR EXTRACTIVE LASER LIGHT EXTINCTION-SCATTER
The Insitec TESS provides real-time PM concentration data for particles ranging in size
from 0 to 20 microns. The TESS can measure PM concentrations in-situ with an up to
8-foot-long probe or in a sample extracted from the stack. The in-situ TESS has been evaluated
in both laboratory and field studies by the Department of Energy (DOE), Southern Research
Institute, and the EPA (Giel et al., 1995). The in-situ TESS is capable of measuring PM
concentration as low as 1.3 mg/acm. A prototype of the extractive TESS was demonstrated in a
short-term field test done by EPRI at a coal-fired boiler. The manufacturer indicates the
instrument is insensitive to particle variations (particle size distribution) and to process changes
(particle composition).
4.14 PCME DUSTALERT 90 ELECTROSTATIC INDUCTION
The DustAlert 90 uses a patented electrostatic induction measurement principle; where
particles in the gas stream interact with a probe inserted in the duct and induce charge movement
in the probe. The AC current generated by charge induction in the probe can be directly related
to the PM concentration. This instrument filters out the DC current generated by the
particulate/probe interaction. The manufacturer asserts that the DustAlert 90 can measure PM
concentration as low as 0.02 mg/acm. Unlike triboelectric technology, the particles do not need
to collide with the probe to be detected. The instrument's output can be correlated to mg/acm
from manual gravimetric data. However, it is more often used to display and record in a relative
"Emission Factor" scale, which indicates emissions as a multiple of "reference" emissions (i.e.,
as a baghouse bag leak detection device). The DustAlert 90's correlation to PM concentration is
affected by changes in particle size distribution, particle type, and particle charge, thus
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eliminating applications on wet exhaust gas stacks and sources controlled by electrostatic
precipitators.
The footprint of the DustAlert 90 is a small module with dimensions of approximately
10 inches wide by 7 inches high by 4 inches deep. The module extends about 6.5 inches back
from the port. A 7/8-inch diameter sensor probe extends into the stack and is attached by a
1.5-inch NPT port. The electrical power requirement is 110V.
This instrument has been type certified by the Environment Agency under the MCERTS
program in the United Kingdom. Also, TUV notes that this instrument should only be used in
constant velocity and constant gas composition environments; however, the velocity restriction
does not apply to the DustAlert 60 model.
4.15 AUBURN INTERNATIONAL TRIBOGUARD m OR HIN-SITU TRffiOELECTRIC
The Triboguard n and HI use proven triboelectric technology, invented nearly 25 years
ago. These instruments are low maintenance and can detect baseline PM concentrations as low
as 0.005 mg/acm (as established by the manufacturer). The Triboguard instruments are primarily
used for baghouse broken bag detection (Fabric Filter Bag Leak Detection Guidance, 1997).
Since triboelectric type instruments are sensitive to changes in stack gas velocity, particle size,
and particle characteristics (e.g., charge and composition), the Triboguard instruments are not
commercially marketed as potential PM CEMS; however, they are used in some applications in
the United Kingdom. This instrument is roughly the same size as the DustAlert 90.
4.16 CODEL STAKGARD TRIBOELECTRIC DUST MONITOR
The StakGard uses triboelectric technology (i.e., the AC current generated by particles
flowing around the probe) to detect PM concentration. The AC current generated by charge
induction in the probe can be directly related to the PM concentration. This instrument filters out
the DC current generated by the particulate/probe interaction. The manufacturer asserts that the
StakGard can measure PM concentration as low as 0.1 mg/acm. The instrument's output can be
correlated to mg/acm from manual gravimetric data; however, it is more often used as a baghouse
bag leak detection device. The StakGard's correlation to PM concentration is affected by
changes in particle size distribution, particle type, and particle charge; however, Codel has
designed a metal mesh housing around the probe to reduce the effect of particle charge after an
ESP. This instrument has been type certified by the Environment Agency under the MCERTS
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program in the United Kingdom. This instrument is also roughly the same size as the
DustAlert 90.
4.17 OPACITY/TRANSMISSOMETERS
For completeness, and because some opacity monitors have been type certified as
paniculate CEMSs, opacity monitors have been included in this section on known PM CEMSs.
Although each opacity monitor is not presented separately as the other PM CEMS presentations
above, Table 4-1 includes a comparison on many opacity monitors that could be applicable as a
PM CEMS in specific applications.
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TABLE 4-1. COMPARISON OF OPACITY MONITORS AS PM CEMSs
Dual Pass
Light Source
Electrical/
Mechanical
Modulation
PM
Measurement
Concentration
Footprint
Land
Combustion
4500 mkll
Yes
LED - Green
Electrical
3kHz
As low as
1 .5 mg/acm
(1 urn dust)
30" long x
18" wide x
24" high
including purge
system and
shutters
Durag
DR-280
Yes
Tungstun Lamp
- White
Mechanical
1.2kHz
From 0-0.1 to
0-1.6 extinction
Transceiver
7" wide x
9" high x
22" deep
Retroreflector
7"x9"x 13"
Durag
DR-290
Yes
Wide Band
Diode-White
Electrical
2kHz
1 mg/acm
resolution for
1 jam dust and
10-foot path
length
Transceiver
7" wide x
13" high x
16" deep
Retroreflector
7" x 10" x
11"
KVB-Enertec
MIP
No
Helium-Neon
Laser - Green
Electrical
Transmitter
12" wide x
18" high x
6" deep
Receiver 5" x
5" x 8"
without
purge system
Monitor Labs -
USI
560 LightHawk
Yes
LED - Green
Electrical
2.4k Hz
For 1 urn dust
and 20-foot
path length -
single-digit
mg/acm
22" long x
20" wide x
33" high
including purge
system and
weather cover
Rosemount
OPM 2000R
Yes
Frosted,
incandescent
lamp - White
Liquid crystal
windows
(electrical)
From 0 to 3
extinction
34" long x
13" wide x
29" high
including purge
system
Sick
OMD41
Yes
LED - Yellow
Electrical
From 0-0. 1 to
0-2 extinction;
PM
concentration
as low as
1.2 mg/acm
Transceiver
15"x8"x
11"
Reflector 1 1 " x
8"x 11"
without
purge system
and
protective
cover
Phoenix
Instruments
OP AC 20/20
Yes
LED - Green
Electrical
2.5k Hz
From 0-0. 1 to
0-2 extinction
Both sides
22" wide x
30" high
Transceiver
27" long
Retroreflector
18" long
Includes
weather cover
and air purge
system with
shutters
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TABLE 4-1. (CONTINUED)
Weight
Electrical
Power
Requirement
Type Approval
Land
Combustion
4500 mkll
60 Ib per side
110V
German TUV -
1997
Durag
DR-280
Transceiver
35 Ib
Retroreflector
13 Ib
Purge air
blowers 65 Ib
each
115V
220 V for
blowers
German TUV -
1978
Durag
DR-290
Transceiver
22 Ib
Retroflector
15 Ib
Purge air with
weather hood
65 Ib each side
90-264 V
48-62 Hz
German TUV -
2000 expected
KVB-Enertec
MIP
110V
HOVfor
blowers
Monitor Labs -
USI
560 LightHawk
Transceiver
27 Ib
Retroreflector
71b
Purge air
blower 22 Ib
Weather cover
and mounting
plate 43 Ib
115V
220 V for
blowers
Rosemount
OPM 2000R
Transceiver
80 Ib
Retroreflector
40 Ib
11 0-240 V
Sick
OMD41
Transceiver
27 Ib
Retroreflector
18 Ib
90. ..267V
120V/3or
230 V/3 for
purge air
system
German TUV -
1995
Phoenix
Instruments
OPAC 20/20
Transceiver
26 Ib
Retroreflector
91b
Weather
enclosure and
air purge
system
1251b/side
115V or 220V
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5.0 SUMMARY OF PM CEMS DEMONSTRATION FIELD STUDIES
Many field studies demonstrating the performance of PM CEMSs have been conducted.
TUV conducted most of the early evaluations and type certifications of PM CEMSs. Later, as
the EPA considered their use, the EPA performed several field evaluations of PM CEMSs. Also,
at least two industry groups have done field evaluations of PM CEMSs. This section presents a
summary of those field studies.
5.1 TUV CERTIFICATION TESTING OF PM CEMS
In Germany, all CEMSs, including PM CEMSs, are type certified and approved for use at
a particular industry type. A PM CEMS cannot be used on a source in Germany unless it has
been certified. TUV is the principle agency that conducts CEMS certifications in Germany.
5.1.1 Sigrist CTNR
The Sigrist CTNR, a light scattering type PM CEMS, was evaluated by TUV Rheinland
in the laboratory and in the field (Report on the Suitability Testing ... CTNR, 1997). The
laboratory test checked the following using two identical instruments:
All instrument functions,
Instrument characteristics (linearity and common response),
Stability of the zero and reference filter values,
Effect of variations in supply line voltage,
Effect of relative humidity, rain, vibrations, and operating position, and
Proper operation of the self-monitoring feature.
The field test was done using the same two instruments from the laboratory test at a
refuse incinerator from April 16, 1997 to June 4, 1997 and at a coal-fired furnace from June 12,
1997 to August 12, 1997. The field test evaluated the following:
Dead time and setting time,
Detection limit,
Correlation capability,
Reproducibility,
Stability of instrument characteristics,
Maintenance interval,
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Data availability, and
Functional test and correlation.
The results of TUV's evaluation of the Sigrist CTNR PM CEMS indicate that it met all of
the applicable requirements with the exception that it does not have the capability of doing
automatic zero and upscale calibration checks. However, TUV recommended the CTNR for
monitoring PM emissions from incinerators and power plants, noting the reservation about the
lack of an automatic calibration feature.
5.1.2 Durag F-904
The Durag F-904, a beta gauge type PM CEMS, was evaluated by TUV Rheinland in the
laboratory and in the field (Performance Testing of the F-904 Beta Gauge). The laboratory test
checked the following:
Effect of variations in supply line voltage, and
Effect of changes in ambient temperature on (1) the zero and span signals, (2) the total
volumetric flow sampled during the measuring cycle, and (3) the dilution air volume.
The field test was done on two identical instruments at a municipal waste combustor from
July 31, 1989 to December 31, 1989. The instruments were installed downstream of an ESP and
wet scrubber and operated in the following stack gas conditions:
Stack diameter 78.7 inches
Average stack gas velocity 45.9 feet per second
Dew point of stack gas 149°F
Stack gas temperature 154.4°F
PM concentration < 10 mg/acm
The TUV report notes that the F-904 was tested under recognizably difficult operating
conditions. The field test evaluated the following monitor features:
Correlation capability,
Reproducibility,
Maintenance interval, and
Data availability.
The results of TUV's evaluation of the Durag F-904 PM CEMS indicate that it met all of
the applicable requirements with the exception of the sample volume audit. On two of 13 tests,
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the sample volume deviated from the expected volume by more than the allowable 8 percent.
However, this test was done at a dilution ratio of 4 to 1, and TUV determined that the monitor
could fully meet the sample volume accuracy requirement at a dilution ratio of 2 to 1.
5.1.3 Durag DR-300-40
The Durag DR-300-40, a light scatter type PM CEMS, was evaluated by TUV Rheinland
in the laboratory and in the field (Report on the Performance Testing of the D-R 300-40 Dust
Concentration Monitor, 1992). The laboratory test checked the following:
Calibration capability in a test duct, where the effect of changes in paniculate size was
evaluated,
Effect of variations in supply line voltage,
Effect of changes in ambient temperature,
Testing of the dirty window correction,
Linearity check, and
Effect of ambient light.
The field test was done on two identical instruments at a secondary lead smelter kiln from
February 27, 1992 to June 3, 1992. The instruments were installed downstream of a baghouse
and operated in the following stack gas conditions:
Stack diameter 41 inches
Stack gas velocity 30 to 59 feet per second
Dew point of stack gas 50 to 122 °F
Stack gas temperature 140 to 230°F
The field test evaluated the following monitor features:
Correlation capability and effect of process changes on the correlation stability,
. Reproducibility,
Maintenance interval,
Data availability, and
Necessity of a light trap.
The results of TUV s evaluation of the Durag DR-300-40 PM CEMS indicate that it met
all of the applicable requirements with the following notes:
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For installations on thick or double-walled stacks, the scattering volume must be within
the flowing stack gas.
Since the scattering volume is only 3 to 11 inches from the instrument face, for
installations on stacks greater than 6.5 feet in diameter, the monitor must be shown to
provide a representative sample.
A light trap may be omitted if the interference from reflected light is demonstrated to be
less than 2 percent of the measuring range.
5.2 EPA/OSW FIELD DEMONSTRATION - HAZARDOUS WASTE INCINERATORS
The OSW wanted to propose PM CEMSs as part of their Hazardous Waste Combustion
MACT rule. Before proposing PM CEMSs, OSW did two preliminary field studies and a
comprehensive field evaluation.
5.2.1 Mixed Solid and Liquid Hazardous Waste Incinerator
The first preliminary test examined three PM CEMSs at a mixed solid and liquid
hazardous waste incinerator located in Bridgeport, New Jersey. The three PM CEMSs were
chosen to represent three different measurement techniques: light scattering, time-dependent
optical attenuation, and beta attenuation. The CEMSs were installed downstream of a pilot scale
wet electrostatic precipitator (ESP). The focus of this test was to determine the PM GEMS's
viability at a wet ESP installation.
The test was conducted in three phases during March of 1995. First, the PM CEMSs
were calibrated according to ISO 10155 using EPA Method 5. Three paired Method 5 tests were
done at each of three operating conditions designed to produce different PM loadings. The PM
concentrations ranged from a low of about 1 mg/m3 to a high of about 30 mg/m3. Second, the
CEMSs were operated for 2 weeks. Finally, another set of Method 5 tests were done to check the
stability of the original calibration. The final Method 5 testing consisted of four paired test runs
at only two operating conditions. PM concentrations were less than 1 mg/m3 during all four test
runs (i.e., the change in operating conditions did not change the PM concentration).
The PM CEMSs evaluated were the following:
Sick Inc. RM200,
BHA Group CPM1000, and
Environment S.A. Beta M5.
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The Sick RM200 and BHA CPM1000 were operating for the initial Method 5 tests,
during the 2-week experimental period, and the final Method 5 tests. The Beta M5 was not
operating during the initial Method 5 tests but operated during the experimental period and final
Method 5 tests.
The OSW reported the following conclusions from this brief test:
The calibration data did not meet ISO 10155 requirements for (1) three or more different
PM concentration levels and (2) nine or more data points.
With proper care, an optical device used in conjunction with a heated bypass can be
calibrated in a wet exhaust stream.
For a low-temperature, saturated stack gas stream, extracting and drying a slipstream is
more appropriate than attempting to make in-situ optical measurements. The CPM1000
responded to liquid droplets in the exhaust stream.
Not enough data were obtained to properly evaluate the performance of the Beta M5.
The PM CEMSs responded to changes in PM concentration levels.
More information on this test can be found in the document entitled "Draft Technical
Support Document for HWC MACT Standards, Volume IV: Compliance with the Proposed
MACT Standards," February 1996, Pages 4-2 to 4-9.
5.2.2 Hazardous Waste Burning Cement Kiln
The OSW chose a hazardous waste cement kiln in Fredonia, Kansas for another
evaluation of PM CEMSs and a test of the initial draft PM CEMS performance specification
(PS-11) criteria. The facility manufactures cement from raw materials in a two-phase wet
process kiln. Particulate emissions are controlled with an ESP. The PM CEMSs selected
included two light-scattering monitors: the ESC PSA and the Sick RM200. The tests involved
triplicate testing at three different ESP power settings ranging from 55 to 140 KW; each
Method 5 test run had paired trains. Initial Method 5 correlation tests were done in May and
June 1995. A final test was done in July 1995 and served as a simulated response correlation
audit (RCA). The test contractor had extreme difficulty obtaining consistent results between the
paired Method 5 trains. A concerted effort was made to achieve an appropriate test matrix and
distribution over three PM levels for each calibration test. During each test period, data from one
of the Method 5 trains was disregarded as suspect.
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The OSW reported the following conclusions from this brief test:
The correlation is highly sensitive to errors that can occur in making the manual method
measurements.
The ESC PSA correlation test produced encouraging but inadequate results in terms of
meeting the draft PS-11 criteria. Also, the PSA's RCA test results did not meet the
performance criteria.
The Sick RM200 experienced some operational problems attributed to the heated, purge-
air system. The instrument was removed during the initial correlation test program.
When the instrument was reinstalled, the response continued to deteriorate.
More information on these tests can be found in the document entitled "DRAFT
Particulate Matter CEMS Demonstration, Volume I: DuPont, Inc. Experimental Station On-site
Incinerator," Wilmington, DE, December 1997, Pages 2-42 to 2-44.
5.2.3 DuPont Hazardous Waste Incinerator
The preliminary tests presented above encouraged OSW to conduct a long term (6 months
to 9 months) demonstration to determine what PM CEMS performance could be achieved at a
reasonable worst-case source. Because the work would be used to support a proposed
requirement that a PM CEMS be used on a hazardous waste combustion device, OSW chose the
DuPont Experimental Station's hazardous waste incinerator for this demonstration. Among such
sources, a source like DuPont's would cause the particulate matter in the stack to be more
variable, thus causing a more variable response from the PM CEMS than at other sources under
consideration (e.g., cement kilns and light-weight aggregate kilns). The EPA also obtained
information to characterize PM CEMS installation needs, data availability, maintenance and
personnel requirements, and costs. One particularly important piece of information learned from
this test was that the PM CEMS can be sensitive to emissions variability on a real-time basis.
Neither periodic short-term manual testing nor operational parametric monitoring would provide
an adequate picture of this variability for standard setting purposes. Only PM CEMS data
collected over a relatively long period of time would provide data sufficient for the statistical
analyses necessary for establishing achievable continuous compliance emissions limits.
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In addition to the importance of long term data gathering in setting standards, the EPA
also learned from this test the importance of precise manual particulate matter measurements.
The variability associated with manual method imprecision can mask the true performance of the
PM CEMS. In response to this issue and to improve sample recovery and analysis time, the
EPA chose to redesign the Method 5 equipment when used at low particulate concentration
sources. These changes became EPA's Method 5i. To evaluate method precision, the EPA used
dual Method 5i trains (two Method 5i trains conducted simultaneously from different ports) and
established acceptable paired train precision criteria.
The EPA also learned much about PM CEMS performance characteristics. This
information included the need to address the performance characteristics of different
technologies, the need to use data flags as indicators of potential problems, the importance of
instrument set-up and a "debugging period." This knowledge led to changes in the draft
performance specification criteria and associated QA/'QC requirements.
The DuPont tests extended over a 9-month period, from September 1996 to May 1997.
Tests conducted from September to November, 1996 were an extension of the learning
experience started in the EPA's preliminary test program. Data collected from September to
November 1996 were not considered in the final analysis of results. Forty-four Method 5i paired
train tests were conducted from December 1996 through May 1997. The EPA conducted the
initial correlation testing in 1-week periods each month from December 1996 through
March 1997. A second correlation was done in April 1997. Finally, the 9-month demonstration
program ended with a RCA in May 1997.
In summary, these tests led the EPA to believe that PM CEMS are a viable accurate
measure of real-time particulate matter emissions. The EPA believes the approach to correlating
emissions to gravimetric manual methods can result in an adequate correlation. The EPA also
believes that data availability, maintenance and personnel, and overall costs associated with
particulate matter CEMSs are representative of other CEMSs, such as SO2 analyzers for utility
boilers. However, site decisions, such as the technology employed for a given application, the
QA/QC capabilities of the CEMS, and the accuracy of the manual method data collected, can
affect the viability of a given PM CEMS at a particular source. More information on the DuPont
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tests can be found in the Paniculate Matter CEMS Demonstration final report at the EPA Office
of Solid Waste's Web site: http://www.epa.gov/epaoswer/hazwaste/combust/CEMS.
5.3 ELECTRIC POWER RESEARCH INSTITUTE - COAL-FIRED BOILER WITH ESP
Another field test program was sponsored by EPRI and conducted at Georgia Power
Company's Plant Yates. Yates Unit 7 uses a conventional Combustion Engineering tangentially
fired boiler with a rated generating capacity of 360 MWe. The unit burns eastern bituminous
coal and is equipped with low NOX burners and separate overfire air. The particulate emission
limit for Unit 7 is 0.24 Ib/mmBtu, and particulate emissions are controlled by an ESP. This
program was designed to provide data for use in a rigorous evaluation of both ESP performance
models and PM CEMS.
The following five devices were tested:
BHA CPM 5000,
PCME SC600,
Insitec extractive TESS,
Spectrum Systems (via Sabata), and
Lear Seigler RM41 opacity monitor.
Of the four instruments classified as a PM CEMS, only the BHA CPM 5000 and PCME SC600
were commercially available at the time of the EPRI test, and only the BHA CPM 5000 had been
used on other field evaluations. The PCME SC600 has since received MCERTS approval. The
Insitec extractive TESS and Spectrum System devices were prototypes.
The test plan was to evaluate three different ESP power conditions, which would result in
three different particulate mass emission levels, during three separate weeks of testing, for a total
of nine independent test conditions. Testing was done in June and September 1998. During each
week, 15 paired Method 17 test runs were conducted. The first 2 weeks of testing were
performed during consecutive weeks and the third week of testing was approximately 3 months
later. The fundamental premise of this field evaluation was to use the initial week of testing to
develop correlation equations for the PM CEMSs. The second week of testing, conducted
immediately following the initial week, provided information regarding the short-term accuracy
and stability of the PM CEMSs. The third week of testing, conducted approximately 3 months
following the initial 2 weeks, provided information regarding the long-term accuracy and
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stability of the correlations. Unfortunately, during the 3-month period between the week 2 and
week 3 tests, the four PM CEMSs were not properly maintained.
PM concentrations were varied by (1) deenergizing ESP fields (i.e., simulating the
complete loss of ESP sections, the most common failure mode of an ESP) and (2) turning down
power on all ESP sections in increments (i.e., simulating problems attributable to high-resistivity
ash or close clearance). PM concentrations during the 3 weeks of testing are presented in
Table 5-1.
TABLE 5-1. PM CONCENTRATIONS FOR THE THREE WEEKS OF
THE EPRI PM CEMS TEST
PM concentrations
Low
Mid
High
Week 1
~ 0.002 lb/106 Btu,
1.8 mg/m3 and
3 percent opacity
-0.06 lb/106 Btu,
49.5 mg/m3 and
15 percent opacity
- 0.23 lb/106 Btu,
174 mg/m3 and
25 percent opacity
Week 2
-0.0 12 lb/106 Btu,
9.1 mg/m3 and
7 percent opacity
- 0.057 lb/106 Btu,
42.3 mg/m3 and
5 percent opacity
-0.121 lb/106 Btu,
87.5 mg/m3 and
6 percent opacity
Week 3
- 0.019 lb/106 Btu,
15.3 mg/m3 and
10 percent opacity
-0.121 lb/106 Btu,
94.5 mg/m3 and
5 percent opacity
-0.149 lb/106 Btu,
119 mg/m3 and
6 percent opacity
The high-PM-concentration condition during week 1 produced a significant number of "chunky"
carbon particles; therefore, this condition was not repeated in the other test periods.
The conclusions from this EPRI study were the following (Roberson et al., 1999):
The paired Method 17 sampling trains showed very good measurement precision and a
tolerance interval of 12 mg/m3 at an emission limit value of 75 mg/m3 (-0.10 Ib/mmBtu).
The BHA CPM 5000, PCME SC600, and prototype Insitec extractive TESS passed the
draft PS-11 correlation criteria. The prototype Spectrum and opacity monitor had
confidence intervals and tolerance intervals well outside the draft PS-11 requirements.
The PM CEMSs correlation statistics from the week 1 test are presented in Table 5-2.
The week 3 tests that were used for the RCA, showed that none of the three PM CEMS
that passed the initial correlation met the RCA criteria.
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The ESP inlet particle size distribution ranged from 21.5 to 24.4 microns for the first two
weeks of testing and was 30.9 during the third week. EPRI believes the skewed particle
size distribution and geometric standard deviation is due to either the retrofit of low-NOx
burners in a short furnace or the wearing of the coal pulverizes.
TABLE 5-2. PM CEMSs CORRELATION STATISTICS FOR
THE EPRI PM CEMS TEST
Instrument
BHA CPM 5000
PCME SC600
Insitec extractive
TESS
Spectrum Systems
(via Sabata)
LearSeiglerRM41
opacity monitor
Correlation Coefficient
0.986
0.984
0.991
0.939
0.937
Confidence Interval
6.7%
6.9%
9.4%
21.1 %
13.6 %
Tolerance Interval
18.2 %
19.2 %
19.2 %
45.5 %
41.1%
More detailed information on the EPRI test at Plant Yates can be found in a paper written
for the EPRI CEM Users Group Meeting at the following RMB Consulting Web site:
http://www.rmb-consulting.com/cinnati/rlrpaper.htm
5.4 ELI LILLY - HAZARDOUS WASTE INCINERATOR
Eli Lilly and Company (Eli Lilly), the Chemical Manufacturers Association (CMA), and
the Coalition for Responsible Waste Incineration (CRWI) jointly sponsored a two-phase test
program of PM CEMSs. The summary presented below was taken from a draft report provided
by Eli Lilly. This test was done at a liquid hazardous waste incinerator at the Eli Lilly Clinton
Lab in Clinton, Indiana. The instruments assessed in this study were an Environment S.A. (ESA)
Model Beta 5M and a Sigrist Photometer AG (Sigrist) Model KTNRM/SIGAR4000.
Phase one of the program demonstrated that the instruments, as initially configured,
would not meet the requirements of draft PS-11. During the same period as Phase One, Eli Lilly
purchased and installed two Sigrist monitors at a facility in Ireland. Eli Lilly contracted TUV
Rheinland to calibrate the instruments which led to new knowledge on the calibration of PM
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CEM instruments. Eli Lilly conducted Phase Two testing using knowledge gained from the
Phase One testing, the DuPont testing, and the TUV Rheinland calibration in Ireland.
5.4.1 Phase One
Phase One of the Eli Lilly evaluation was designed to duplicate the testing conducted at
the DuPont Hazardous Waste Incinerator, but on a source that was saturated with water vapor.
The evaluation was conducted over a 5-month period from February to June 1998. During this
period, a total of 74 paired Reference Method 5i (M5i) sample runs were completed at varying
particulate levels from 17 to 45 mg/dscm at 7 percent O2. Of the 74 test runs, 70 test runs
produced acceptable paired M5i results.
The Reference Method data was compared to the output of the two instruments and the
requirements of draft PS-11 with the following conclusions:
None of the data sets met the draft PS-11 criteria for correlation coefficient but most
passed the CI and TI criteria.
The Sigrist had a significantly higher correlation coefficient than the ESA monitor did.
The "best fit" correlation relation for the ESA was polynomial, versus little difference
between the linear and polynomial correlations relations for the Sigrist.
Use of the polynomial correlation relation for the ESA would significantly limit the range
of the instrument.
Evaluation of quarterly sets of the Sigrist data showed different slopes and correlation
coefficients.
The data availability of the instruments was 78 percent for the ESA and 96 percent for the
Sigrist. The ESA instrument, as designed and operated, had trouble dealing with the high
moisture level. Finally, both instrument's measuring range was set too wide for the range of PM
concentrations.
In general, Lilly believes that the Phase One test was a learning experience, and the Phase
One results should not be used to judge the performance of these PM CEMSs.
5.4.2 Phase Two
Phase Two of the Eli Lilly program was designed using lessons learned from previous
testing. Phase Two incorporated new instrument operating procedures as well as design changes
to the ESA instrument. Eli Lilly noted the following changes were included:
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The Sigrist instrument was limited to operate on a single range that spanned the known
particulate concentration (i.e., multi-ranging capability was eliminated because of non-
linearity between ranges).
The ESA instrument had some design changes incorporated to make it operate better at
the high moisture levels.
The sample period for the ESA instrument was changed from 6 to 15 minutes, changing
the sample collection time from 2.5 to 8.5 minutes.
During Phase Two (November to December 1998), 40 sets of paired train data were
collected using M5i with particulate concentrations ranging from 1 to 64 mg/dscm at 7 percent
O2. Of the 39 paired test runs (after one run, train 2 failed its leak check), four failed the
precision criteria. The paired train bias comparison had a correlation coefficient of 0.99 and a
slope of 0.97, indicating no bias.
The Method 5i test data was compared to the output of the two instruments and the
requirements of draft PS-11 with the following conclusions:
Both instruments met the draft PS-11 correlation criteria. The correlation statistics are
presented in Table 5-3.
Successful correlation required operating the incinerator at abnormal conditions to obtain
the needed range of PM concentration (i.e., the waste feed was stopped and only natural
gas was combusted to produce the low PM concentrations).
During the Phase Two test, the incinerator was operated in excess of the proposed PM
standard for a hazardous waste combustor.
Successful correlation required a substantial site-specific operational learning process
with the instruments (i.e., supporting the need for the shakedown period and correlation
test planning period in PS-11, see Sections 7.3 and 8.3 of this report).
Evaluation of the data collected shows that the best correlation relationship of the Sigrist
monitor was logarithmic with a correlation coefficient of 0.97. The ESA monitor was found to
have a linear relationship with a correlation coefficient of 0.99.
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TABLE 5-3. PM CEMSs CORRELATION STATISTICS FOR
THE LILLY PHASE TWO PM CEMSs TEST
Instrument
ESA BetaSM
Sigrist KTNR
Correlation coefficient
0.99
0.97
Confidence interval
2.6%
6.7%
Tolerance interval
9.1 %
24.3 %
Although both instruments met the correlation criteria, Eli Lilly had concerns because the
Sigrist was at the maximum tolerance level, 25 percent, of draft PS-11. Also, the ESA did not
track with the Sigrist 12.3 percent of the time. The trend analysis was based on an analysis of the
data using mA output of the monitor and the regression equation calculated using the data from
this test. During the periods in which the two instruments did not trend together, data from the
ESA were higher than the Sigrist. The difference was assumed to be in the ESA data because in
several instances the ESA had a sample volume error, but this error was not recorded.
The data availability of the instruments for Phase Two were 98.1 percent for the Sigrist
and 85.8 percent for the ESA. The data for the periods that the ESA did not trend with the Sigrist
were treated as an instrument malfunction for the ESA.
5.5 EPA/OAQPS FIELD DEMONSTRATION - COAL-FIRED BOILER WITH BAGHOUSE
The EPA's Office of Air Quality Planning and Standards (OAQPS) may require the use
of PM CEMSs in future standards. Also, States may require them for State Implementation Plan
(SIP) monitoring and Economic Incentive Program (EIP) monitoring. Additionally, industry
sources may use PM CEMSs for Title V monitoring. The EPA, therefore, desired additional
evaluations of PM CEMS technology on a long-term continuous basis. Also, the EPA wanted
additional data to support revisions to draft PS-11 and Procedure 2. The EPA initiated a
demonstration program to setup and operate PM CEMSs over an extended time to gather data for
assessing their performance against draft PS-11 and Procedure 2. The EPA chose a coal-fired
power plant that used a baghouse for paniculate control for the test site.
The test site was Cogentrix of Rocky Mount Inc., located in Battleboro, North Carolina.
This facility is an electric utility plant consisting of four identical boilers powering two electric
generating units. Each generating unit is rated at approximately 55-60 MWe for a total plant
electrical capacity of 115 MWe. Each of the generating units is powered by a pair of
Combustion Engineering stoker-grate power boilers. Each of the four boilers fires bituminous
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coal and is rated for 375 mmBtu/hr heat input and steam output of 250,000 Ib/hr. Each is
equipped with a Joy Technologies, Inc. dry type SO2 absorber (lime slurry scrubber) and a Joy
Technologies pulse-jet fabric filter (baghouse) for particulate control. The particulate emission
limit for each boiler is 0.02 Ib/mmBtu.
The following three commercially available PM CEMSs (two light scattering types and
one beta gauge type) were included in the demonstration:
ESC P5B,
DURAG DR-300-40, and
DURAG F904K.
The demonstration project proceeded as follows:
The PM CEMSs were installed in early June 1999.
A shakedown period lasted from June 12 through June 30, 1999.
A 7-day drift test was done on each PM CEMS, an ACA was done on the two light scatter
type PM CEMSs, and a sample volume audit (SVA) was done on the beta gauge type PM
CEMS.
A correlation test planning period consisting of nine preliminary Method 17 runs, which
were used for assessing the range of emissions (i.e., how to obtain three levels of PM
concentration) and setting the measurement range on the PM CEMS, was carried out over
the period of July 9-14, 1999.
The initial correlation test consisting of 15 paired Method 17 runs was carried out during
the period of July 15-19, 1999.
An RCA and ACA/SVA were done in late August 1999, about 1 month after the initial
correlation test.
A second RCA and ACA/SVA were done in November 1999 to evaluate discrepancies
between the initial correlation and the first RCA.
A final ACA/SVA was done on February 7, 2000 with project completion on
February 16, 2000.
The duration of the demonstration project was approximately 8 months, with continuous
operation of the PM CEMSs and emissions data collection over the 6-month period following the
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initial correlation test. All PM CEMSs were maintained in proper operating order during the
demonstration with daily zero and upscale drift evaluations.
PM concentrations were varied by adjusting a multi-position butterfly valve to bypass PM
from the inlet duct (dirty side) to the outlet duct (clean side) of the baghouse. The PM
concentrations during the initial correlation test and the RCAs are presented in Table 5-4.
TABLE 5-4. PM CONCENTRATIONS FOR THE EPA/OAQPS PM GEMS TEST3
PM concentrations
Low
Mid
High
Initial correlation
~ 4.5 mg/dscm and 3.7
percent opacity
~ 16.4 mg/dscm and
4.1 percent opacity
~ 24.4 mg/dscm and
4.7 percent opacity
First RCA
~ 3.6 mg/dscm and
5.1 percent opacity
-18.6 mg/dscm and
4.7 percent opacity
~ 38.6 mg/dscm and
5.5 percent opacity
Second RCA
No tests done at low
PM cone.
~ 22.5 mg/dscm and
9.3 percent opacity
~ 38.2 mg/dscm and
9.6 percent opacity
"Opacity readings were taken in the stack which discharges emissions from both boilers 2A and 2B.
Conclusions from this EPA/OAQPS demonstration were the following (Evaluation of
Particulate Matter Continuous Emission Monitoring Systems, 2000):
The 37 paired Method 17 sampling trains during the initial correlation and the first RCA
showed very good measurement precision with an RSD of no greater than 4.3 percent.
The bias between Trains A and B was only 2 percent for the initial correlation test and
2.3 percent for the first RCA. Except for one test run to demonstrate precision, paired
trains were not used during the second RCA.
Three levels of PM concentrations could be obtained for a baghouse controlled unit by
using a baghouse bypass system that simulated a typical baghouse failure. When using a
paniculate bypass system to increase the PM concentration, the point where the dirty gas
mixes with the clean gas must be well upstream of the manual reference method and the
PM CEMS measurement locations to avoid possible stratification of the PM.
All three PM CEMSs passed the draft PS-11 initial correlation criteria at an emission
limit of 17 mg/acm (used for the light scattering instruments) or 25.5 mg/dscm (used for
the beta gauge instrument) using a linear regression relation. The correlation statistics are
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presented in Table 5-5. Note, the DR-300-40 had a confidence interval of 10.4 percent
compared to a criteria limit of 10 percent.
All three PM CEMSs passed the initial QC checks for the 7-day drift, ACA, and SVA.
All three PM CEMSs failed to meet the RCA criteria after 1 month of operation. Based
on results from the second RCA, a likely cause in the discrepance between the initial
correlation data and the first RCA data was a shift in the PM stratification at the PM
CEMS measurement location (which did not meet PS-11 siting criteria).
Correlations generated using the combined initial correlation data and the RCA data
failed to meet the draft PS-11 criteria, and the correlations generated using only the RCA
data were just outside the draft PS-11 criteria bounds. During the second RCA, data
collected during 5 of the 6 test runs done at full boiler operating load fell within the
tolerance interval of the first RCA correlations.
At reduced and variable boiler load conditions, the three PM CEMSs did not respond to
the higher PM concentrations as expected.
The two light scatter type PM CEMSs met the ACA criteria after 1 month, 4 months, and
6 months of operation.
The beta gauge PM CEMS met the SVA criteria after 1 month, 4 months, and 6 months
of operation.
Assuming that plant personnel could have responded to the observed maintenance issues
in a reasonable time, the light scatter PM CEMSs achieved 99 percent data availability
and the beta gauge PM CEMS achieved over 96 percent data availability.
TABLE 5-5. PM CEMSs CORRELATION STATISTICS FOR
THE OAQPS PM CEMSs FIELD EVALUATION
Instrument
ESC P5B
DURAG DR-300-40
DURAG F904K
Correlation coefficient
0.964
0.955
0.988
Confidence interval
9.20 %
10.4 %
5.37 %
Tolerance interval
17.9 %
20.2 %
10.7 %
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6.0 FUTURE FIELD DEMONSTRATIONS
The EPA anticipates that additional field demonstrations of PM CEMSs will be done by
both the EPA and industry. To facilitate a successful field demonstration, this section presents
some guidelines that should be considered.
6.1 TEST PLAN GUIDELINES
A field demonstration or evaluation of PM CEMSs should be done in accordance witn a
written test plan. In general, a written test plan should follow the outline provided in the
Emission Measurement Center's 1991 Guidebook: "Preparation and Review of Site Specific Test
Plans." The site specific test plan (SSTP) should contain the following information:
1. Introduction
Summarize the test program and what criteria will be used to evaluate the PM
CEMS(s)
Show a test program organization
2. Source Description
Describe the process that is generating PM emissions
Describe the control equipment
3. Test Program
Describe the test objectives (e.g., demonstrate that a PM CEMS provides reliable and
accurate data for this source over an extended period, evaluate maintenance
requirements, determine if a PM CEMS satisfies PS-11 and Procedure 2 criteria)
Show the test matrix, including personnel responsibilities (e.g., site modifications,
shakedown and planning periods, initial correlation test period, Procedure 2 audits,
instrument maintenance)
Describe how the source and control equipment will be operated and how PM
concentrations at different levels will be obtained
4. Sampling Locations
Include a diagram or photograph of the Reference Method sampling location
Include a diagram or photograph of the PM CEMS measurement location,
5. Sampling and Analytical Procedures
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Describe the PM CEMS(s), including what instrument data will be logged (e.g., daily
calibration drift, operational flags, data averaging periods)
Describe the Reference Method used, including dual/paired train arrangement, and
how on-site results will be obtained (as applicable)
Present what process operating data will be collected to evaluate operation of the
source and control equipment
6. QA/QC Activities
Present QC procedures that will be applied to the Reference Method sampling
Present QC procedures that will be applied to the PM CEMS (e.g., daily calibration
drift checks, ACA, SVA) and who will do them
Describe how the PM CEMS(s) measurement range will be properly set
Conduct an independent check of the regression analysis
7. Safety Issues
6.2 MONITOR SELECTION GUIDELINES
When selecting a PM CEMS for a field demonstration project, the following should be
considered:
What technology is to be demonstrated?
Is that technology known to be affected by site specific conditions (see Section 8.2)? If
no, then the technology can be considered; if yes, then only consider the technology if
precautions are taken to offset the effect.
Considering the measurement location, can the potential PM CEMS be installed (i.e.,
consider platform size and location versus the size of the instrument, stack/duct diameter,
weight limitations, installation efforts, exposure effects, the need for a light trap, etc.)?
Select a PM CEMS that is commercially available. If a prototype PM CEMS is to be
evaluated, a second PM CEMS that uses the same technology and has been proven should
also be used.
Only use a PM CEMS that does zero and upscale drift checks and one that has
operational fault indicators.
Ensure the vendor can provide adequate support and assistance.
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6.3 TEST PLAN APPROVAL AND DATA ANALYSIS
The final test plan should be completed at least 45 days before the initial correlation
testing is planned. For a field demonstration sponsored by the EPA, the industry group affected
should be given the opportunity to review the test plan. The industry group can provide
comments to the EPA. The industry group will also be invited to witness the initial correlation
testing and any other part of the program they desire. For a field demonstration sponsored b} an
industry, the industry should submit the final test plan to the EPA and State agency for review at
least 45 days before the initial correlation testing. In reciprocation, the EPA and the State agency
should be invited to witness the initial correlation testing and any other part of the program they
desire.
Results of the field demonstration should be shared between the industry group and the
EPA. The industry group and the EPA are encouraged to separately analyze the data. Finally, a
consensus should be reached regarding the conclusions of the demonstration.
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7.0 PM CEMS IMPLEMENTATION
Once PS-11 is finalized and published in the Federal Register, the EPA, State regulatory
agencies, and industry will be tasked with implementing PM CEMS programs. This section
provides guidance on the following topics: source applicability, how to select the appropriate PM
CEMS, how to conduct the initial correlation, what does the correlation mean and how accurate
are the data generated by the PM CEMS, what QA/QC measures to apply to PM CEMS, and
finally, issues to be addressed case by case.
7.1 SOURCE APPLICABILITY
PM CEMSs have three main applications: (1) process monitoring, (2) compliance
assurance, and (3) compliance monitoring. As a process monitor, a PM CEMS can be used to
improve process performance by providing an indication that a setpoint has changed and an
adjustment is needed or to improve air pollution control device performance by indicating when
maintenance is needed. As a compliance assurance monitor, a PM CEMS can be used as an
indicator for reasonable assurance that an emission limit is not exceeded. A small amount of
testing would be needed to establish the not-to-exceed level, but a full correlation test can be
avoided. As a compliance monitor, the PM CEMS would provide a continuous record of actual
PM concentration. To be used as a compliance monitor, a full correlation test is needed.
Specific source applications of the PM CEMS in each of these areas are presented below.
The ESC P5B light scatter PM CEMS has been used as an ESP performance monitor at
many large electric utility plants in the U.S. (personal communication with Robert Nuspliger,
ESC). Furthermore, a PM CEMS has been used to monitor for product losses through an exhaust
stack during process changes (e.g., in the exhaust duct of a potato chip manufacturing process to
monitor for oil losses during process changes).
In Canada, many PM CEMSs are in use at pulp and paper mills with some being used as
environmental compliance assurance monitors in lieu of more frequent Reference Method testing
for compliance. In the United Kingdom, PM CEMSs are used at municipal waste combustors,
power plants, and cement kilns in a compliance assurance manner (personal site visits at two
facilities and personal communication with the U.K. Environment Agency, September 1999).
Also, in Korea, PM CEMSs are used in a compliance assurance manner.
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PM CEMS have been applied in Germany to industrial furnaces (i.e., coal- and oil-fired
units larger than 50 MW and gas-fired units greater than 100 MW) following the requirements of
the 13th BlmSchV and to waste incinerators following the requirements of the 17th BlmSchV. In
Denmark, PM CEMSs are used at coal-fired power plants. In the United States, PM CEMSs
have been installed and evaluated on liquid hazardous waste burning sources, cement kilns,
copper smelters, a glass furnace, and oil- and coal-fired boilers.
When a PM CEMS is used for compliance monitoring, the PM emission limit that is used
as a compliance set point should be based on PM CEMS data collected from many representative
sources over an extended period (e.g., at least 6 months). The accuracy limitations of a PM
CEMS must also be considered when setting an emission limit. For example, in Germany the
PM CEMS's confidence interval (e.g., 4 mg/dscm) is added to the baseline PM emission
standard (e.g., 30 mg/dscm) to determine the facility's daily emission limit (e.g., 34 mg/dscm).
Also, the averaging period and whether the average is a block or rolling average are critical
choices to be made. These choices will have an effect on sources ability to remain in compliance
(Joklik, 1999). Furthermore, the definition of paniculate itself can be problematic at some
sources, especially when comparing in-situ PM CEMS measurements to extractive Reference
Method measurements (i.e., because of condensible paniculate).
7.2 PM CEMS SELECTION
Since a PM CEMS determines PM concentration by measuring secondary properties of
the paniculate, selecting the appropriate PM CEMS technology for the source is a critical first
step. Site-specific conditions must be considered (see Section 6.2 of this report). Also, different
types of PM CEMSs can report different PM concentrations for the same sample stream just
because of the concentration units (i.e., mg/dscm versus mg/acm) used in the correlation test.
Some of the factors that affect PM concentration measurements made by the PM CEMSs
presented in Section 4 of this report are offered below (Joklik, 1999) along with some practical
suggestions.
Opacity and light scattering monitors have responses that are functions of the particulate's
index of refraction and size distribution. However, in addition to being more sensitive
than opacity monitors, light scatter monitors also provide more degrees of design
freedom. Parameters such as light wavelength, scattering angle, and solid angle of
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detection affect the response of the instrument, which makes it possible to minimize the
influence of index of refraction and size distribution over certain specified size ranges.
However, since optical techniques effectively measure particle volume, using them to
infer PM concentrations introduces an additional dependence on particle density. Since
these instruments respond to liquid droplets in the sample gas stream, in-situ devices of
this type are inappropriate for saturated or nearly saturated exhaust streams. Extractive
devices of this type that heat the sample gas may be used on saturated or nearly saturated
exhaust streams. Additionally, using these types of instruments on sample gas streams
that are likely to have varying particle size distributions is less desirable, unless
precautions are taken to avoid the effects of changing particle sizes (e.g., multiple
correlation curves). These instruments are most appropriate for sources controlled by
fabric filters (i.e., baghouse) or multi-stage air pollution control systems in which the
particle size distribution at the outlet of the device does not vary much.
Beta gauge monitors have a weak dependence on particle composition. This effect arises
because of the composition dependence of the electron mass-attenuation coefficient (the
atomic number versus atomic mass ratio). The main issues associated with the use of a
beta gauge PM CEMS are practical ones: maintaining isokinetic sampling may be
necessary and sample loss may occur in the probe. The importance of these issues will be
site dependent. Since beta gauge type instruments are much less sensitive to changes in
particle size than optical based instruments, these instruments are more appropriate for
sample gas streams that are likely to have varying particle size distributions (e.g.,
following an ESP or sources that use many different fuels). Also, since beta gauge type
instruments extract and heat the sample gas, these instruments are appropriate for sample
gas streams that are saturated or nearly saturated. If a beta gauge instrument is used at a
source that varies its exhaust gas stream velocity a great deal (e.g., load following electric
power plant), the instrument must have the capability to adjust its sampling rate to
maintain isokinetic sampling.
The response of probe electrification devices is a function of resistivity of the particles,
which depends on particle composition and humidity. The response is also affected by
flow velocity, particle size, and particle charge. Also, since a physical probe is inserted
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into the sample gas stream, effects due to erosion and deposition must be considered. A
PM CEMS of this type should only be used in exhaust streams that do not have varying
particle sizes, do not have varying velocity, do not have saturated or near saturated
conditions, and do not have varying particle charge (e.g., cement kiln controlled by a
fabric filter). Probe electrification devices based on the AC portion of the current are not
as sensitive to gas velocity changes as DC measuring devices.
The PM CEMS measurement location is critical, especially if the PM concentration will
be artificially increased for purposes of developing the correlation relation. The point
where high-PM-concentration gas is mixed with low-PM-concentration gas must be well
upstream of both the PM CEMS and the manual Reference Method measurement
location. This is to ensure the paniculate is evenly distributed and well mixed across the
stack area at the measurement location. Also, devices that can introduce dilution air or
otherwise disturb the air flow pattern must be well upstream of the PM CEMS
measurement location.
7.3 SITE-SPECIFIC CORRELATION TEST
Since a PM CEMS measures secondary properties of particulate (with the possible
exception of the beta gauge type monitors) and outputs a signal that is proportional to the PM
concentration, a PM CEMS must be correlated to the site specific conditions at the measurement
location. Also, a site-specific correlation will account for any PM stratification that may exist at
the PM CEMS measurement location. The procedure for carrying out a correlation test is
described in PS-11. Some specific issues related to the correlation test are presented in this
section. A correlation test consists of the following steps:
1. Install an appropriate PM CEMS at a representative location and start it according to
the manufacturer's instructions.
2. Operate the PM CEMS and record the output for a Shakedown Period and then a
Correlation Test Planning Period (up to a 6-month period may be needed). Establish a proper
measurement range at the end of the Correlation Test Planning Period. The Shakedown Period
and Correlation Test Planning Period must not extend beyond the date when the PM CEMS must
be used to report emissions.
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3. Carefully, conduct 15 paired train Reference Method tests for paniculate while
simultaneously collecting PM CEMS output values over the range of PM CEMS responses
recorded during the Correlation Test Planning Period. Higher PM CEMS responses may be
tested to increase the effective range of the correlation equation by perturbing the air pollution
control system or other means.
4. Evaluate the Reference Method data for precision and bias, and calculate the
statistically appropriate correlation equation (linear or polynomial) from the valid, concurrent PM
CEMS responses and Reference Method PM concentrations.
5. For the selected correlation equation, compare the statistical parameters to the PS-11
criteria.
The main issues to resolve during the Shakedown Period and Correlation Test Planning
Period are the following:
Plant people must learn how to properly operate the PM CEMS.
The process should operate over its full operating envelope, especially in the areas that
are suspected to affect PM composition and concentration (e.g., all expected waste feeds,
all fuels, start-up and shutdown, sootblowing).
The proper measuring range or sensitivity level must be set such that normal operations
are approximately 6 to 10 mA output but that concentrations at and just above the
emission limit do not exceed the upper measurement point (i.e., 20 mA). Also, the
measuring range must never be exceeded for a 15-minute average period. Completing
this task will likely require some Reference Method testing before the initial correlation
test.
The operating conditions that produce low and high PM concentrations must be
documented so that those conditions can be reproduced for the correlation test. If
changes in operation cannot produce a range of PM concentrations, some technique of
perturbing or bypassing the pollution control system can be used.
During the initial correlation test, the most critical task is to carefully and properly
perform the manual Reference Method tests and laboratory analysis. This task is critical because
the accuracy of the PM CEMS correlation can be no better than the accuracy of the Reference
Method measurements. The sole reason for requiring dual sampling trains is to help ensure the
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accuracy of the Reference Method values by checking that the precision between the paired
Reference Method results is sufficiently high and that the bias between the two sampling systems
is sufficiently low. Although having a high level of precision between paired numbers does not
guarantee that either number is accurate, the chance that the number is accurate is greater than
with a single value. Another important point is to coordinate starting and stopping of the test
runs with the sampling interval of the PM CEMS. This point is most important for a batch type,
extractive PM CEMS (i.e., a beta gauge). Also, if port changes during the Reference Method
tests take a long time (e.g., 5 minutes or more), the PM CEMS data during port changes can be
discarded from the PM CEMS's average output.
Since the paired Reference Method results must be evaluated for their precision before
the run can be considered valid, getting PM concentration results in the field is highly
recommended. This requires sample recovery and laboratory analysis in the field. Furthermore,
checking the progress of the test program by plotting the Reference Method values against the
PM CEMS's output during the correlation test is highly recommended.
Another requirement for a valid correlation test per draft PS-11 is to collect PM
concentrations over the full range of PM CEMS responses recorded during the Correlation Test
Planning Period. At most sources, some effort (e.g., operational changes or adjustments to the
pollution control system) will be needed to obtain the full range of PM concentration levels.
Testing at PM concentrations above the emission limit is not required. Some examples of how a
source might obtain lower and higher PM concentrations are the following:
For low PM concentrations:
Burn only natural gas
Stop product feed
Shut off process and only run the fans
Use filtered sample air
For high PM concentrations:
Change fuels combusted
Change product or waste feed
Perturb or bypass the pollution control system to simulate normal, unpreventable
upsets
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The EPA is aware that some sources will not be able to create a wide range of PM
concentration levels for the correlation test. Therefore, draft PS-11 allows a source to perform
the correlation test over the range of PM concentrations normally experienced. The PM CEMS
is then limited to how far its response can be used for reporting PM emissions (i.e., 125 percent
of the highest PM CEMS response during the correlation test) before additional data must be
collected to extend the correlation. For example, if the PM CEMS responses ranged from
4.5 mA to 5 mA during the correlation testing, the corresponding correlation equation from this
data could be used up to a PM CEMS response of 6.25 mA. When three hourly averages exceed
6.25 mA, additional test data at PM CEMS responses around 6.25 mA would have to be added to
the correlation data. This approach is particularly appealing when the limited range of PM
concentrations is much lower than the standard. This approach is used in Germany.
7.4 UNDERSTANDING THE MEANING OF THE CORRELATION
After a successful correlation test and development of the correlation relation equation,
one must understand the meaning and appropriate use of the regression equation (Joklik, 1999).
The estimated regression equation that correlates the manual gravimetric PM concentration
measurements (e.g., mg/dscm) and PM CEMS measurements (e.g., mA) has associated with it a
degree of uncertainty expressed by two hyperbolae around the fitted line of the regression
equation (i.e., the mean of the estimated PM concentration values.) The first is a confidence
interval, defined in PS-11 as a 95 percent confidence level. The second is a tolerance interval,
defined in PS-11 as a 95 percent tolerance interval that contains at least 75 percent of the entire
population of PM concentration values. In other words, a tolerance interval will bracket at least a
certain proportion (e.g., 75 percent) of the population with a specified degree of confidence (e.g.,
95 percent). The width of the band determined by these bounds is narrowest at the point defined
by the mean of PM CEMS measurements and mean of PM concentration measurements. The
farther one moves away from the mean, the wider the bounds become. Thus, extrapolating the
estimated regression line and its confidence and/or tolerance bounds will necessarily result in
decreased precision in PM concentration measurements estimates. Therefore, the EPA's policy
decision to limit the amount of extrapolation of a regression equation developed from data over a
narrow range of PM CEMS responses to 125 percent of the largest PM CEMS response is
supported by the statistical meaning of the correlation.
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For a given PM concentration (i.e., mg/acm), several different PM CEMS responses (i.e.,
mA signal) can occur within the bounds of the tolerance interval (following along a horizontal
line from the upper tolerance interval to the lower tolerance interval, this is based on inverse
regression). Conversely, for a given PM CEMS output, several different PM concentrations can
occur (following along a vertical line from the lower tolerance interval to the upper tolerance
interval). Thus, the uncertainty in the PM concentration reported by a PM CEMS's correlation
relation equation that meets PS-11 acceptance criteria is limited to ± 25 percent of the emission
limit value.
7.5 QUALITY ASSURANCE/QUALITY CONTROL
Quality assurance (QA) has two functions in the PM CEMS program:
1. Assessment of the continued quality of the PM CEMS's data, and
2. Maintaining data quality by implementing quality control (QC) policies and corrective
action.
When the assessment function indicates a reduction in data quality, the QC procedures
must be revised until the PM CEMS produces data of acceptable quality. The specific QA/QC
activities found in Procedure 2 for a PM CEMS program are the following:
Quality check of Reference Method data,
Daily zero and upscale drift checks,
Daily sample volume check (where applicable),
Relative response audit (RRA),
Response correlation audit (RCA),
Absolute correlation audit (ACA), and
Sample volume audit (SVA), where applicable.
As noted earlier, collecting quality manual Reference Method data is key to a successful
PM CEMS program. The quality of the Reference Method data applies to the initial correlation
test described earlier and to the RCA test. The quality of the Reference Method data is first
evaluated by the population relative standard deviation (RSD) between the paired Reference
Method data points from each individual test run. The RSD must meet the following criteria:
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IF
the average PM concentration > 10 mg/dscm
THEN
RSD < 10 percent
the average PM concentration < 1 mg/dscm
RSD < 25 percent
the average PM concentration is between 1 and
10 mg/dscm
RSD < the percentage determined from the
following equation:
-(15/9)* mg/dscm+ 26.667
(i.e., the linear interpolation between
25 percent at 1 mg/dscm and 10 percent at
10 mg/dscm)
If the pair of Reference Method PM concentration values meets the RSD criteria, the data are
deemed acceptable. At the conclusion of the test program (either initial correlation or RCA), all
valid pairs are evaluated for systematic bias. The bias is evaluated by calculating the linear
regression of all valid pairs (Train B versus Train A), and comparing the slope from the linear
regression to the range of 0.93 to 1.07. If the slope is between 0.93 and 1.07, the bias is
acceptable, and the averages of each paired train are used in the initial correlation relation or
RCA.
On a daily basis, the PM CEMS is subjected to zero and upscale drift checks. This
routine check is done to assess system electronics and optics, light and radiation sources and
detectors, electric or electro-mechanical systems, and general stability of the system calibration.
Basically, the zero and upscale drift check is a daily health check of the instrument (i.e., is it still
responding to a reference value today as it did yesterday and the day before that, etc?). In
general, the instrument must be adjusted when the daily drift exceeds 4 percent, but it may be
adjusted at lower drift values. The instrument is considered out-of-control (i.e., the data are not
valid for compliance determination) when either the zero or upscale drift exceeds 4 percent for 5
consecutive days or exceeds 8 percent on any one day.
For extractive type PM CEMS that measures the sample volume and uses the measured
sample volume as part of calculating the output value, a check of the sample volume measuring
equipment must be done on a daily basis. This sample volume check is done at the normal
sampling rate of the PM CEMS. The PM CEMS sample volume measurement must be adjusted
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whenever the daily sample volume check exceeds 10 percent. The instrument is considered out-
of-control (i.e., the data are not valid for compliance determination) when the sample volume
check exceeds 10 percent for 5 consecutive days or exceeds 20 percent on any one day.
At least once each calendar quarter (but no closer than 2 months), the PM CEMS must
have an ACA and a SVA (as applicable) done. The ACA applies to all types of PM CEMSs, and
the SVA applies to extractive type PM CEMSs that use the measured sample volume to calculate
PM concentration. An ACA and a SVA are higher level performance checks than the daily
checks. The ACA is designed to evaluate the performance of the PM CEMS across its full
measuring range by checking the instrument's response at three audit points. If any of the ACA
audit points have an error in excess of ± 10 percent of the audit value, the instrument must be
repaired and a new audit done to confirm the proper operation of the instrument. The PM CEMS
manufacturer should provide the source with materials for the audit. A SVA is done by
measuring the instrument's sample volume with a calibrated device (e.g., dry gas meter) and
comparing the audit value to the volume reported by the instrument. If the SVA shows an error
in excess of ± 5 percent of the audit value, the instrument must be repaired and a new SVA done
to confirm the proper operation of the instrument. Procedure 2 provides the method for
performing the SVA.
At the frequency specified in the regulation that requires the PM CEMS, at least 12 paired
manual Reference Method tests for the RCA must be conducted following the same procedures
described for the initial correlation test. Each paired train result must meet the same RSD criteria
as for the initial correlation. The RCA must include PM concentrations within the range
obtained during the initial correlation test. For the RCA, at least 9 of the 12 sets of PM
CEMS/Reference Method measurements must fall within the initial correlation's tolerance
interval bounds. If the PM CEMS fails to meet this RCA criteria, the PM CEMS is out-of-
control, and the following two actions must be taken:
1. Combine the RCA data with the initial correlation data and perform the regression
analysis in PS-11 to develop a new correlation relationship. If this new correlation meets the
PS-11 criteria, the new correlation must be used, or
2. Do the PS-11 regression analysis on the new RCA data. If this new correlation
relation meets PS-11 criteria, it must be used.
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Once every four calendar quarters, a RRA must be conducted. The RRA consists of
collecting three simultaneous Reference Method PM concentration measurements and PM
CEMS measurements at the as-found source operating conditions and PM concentration. Paired
trains for the Reference Method sampling are not required but are recommended to avoid failing
the test due to imprecise and inaccurate Reference Method results. For the RRA, at least 2 out of
the 3 test runs must fall within the tolerance interval to ensure the PM CEMS correlation is s .ill
applicable and accurate. EPA believes the RRA is a cost effective means to ensure that the PM
CEMS correlation remains applicable without the need to complete a costly RCA on an annual
basis. If the PM CEMS fails to meet this RRA criteria, the PM CEMS is out-of-control, and a
full RCA must be completed.
7.6 PS-11 ISSUES TO BE ADDRESSED CASE BY CASE
As discussed previously, the EPA produced a draft performance specification (PS-11) to
govern the installation and calibration of a PM CEMS. The EPA has been revising PS-11 based
on the results of its and industry's field evaluations of PM CEMSs and comments received to the
proposed PS-11. Many issues have been resolved, but several issues need to be resolved on a
case by case basis. The PS-11 case by case issues are the following:
1. How to vary the source's PM emission concentrations during the correlation test.
How to simulate a normal, unpreventable, expected failure of the APCD?
If adjusting the APCD changes the characteristics of the PM in the stack, some types
of PM CEMSs will not be applicable.
What effect does fuel changes have on the PM concentration?
Can sootblowing be used to increase the PM concentration?
Can and should the product feed be stopped to get near zero emissions?
Is testing during start-up and shut-down viable?
Can clean sample gas be used for a zero point?
Is the zero point hypothesis (i.e., 0 mg/m3 = 4mA) valid? The zero point hypothesis is
used by the German agency, and the tests done by Eli Lilly while only combusting
natural gas support the zero point hypothesis concept.
2. Can and should multiple correlations be used in some instances when clearly the PM
characteristics change?
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3. For sources having condensible materials in the exhaust stream, the PM CEMS must be
able to measure PM at the Reference Method filter temperature. If condensible PM is
included in the total paniculate, in-situ PM CEMS (e.g., light scattering, probe
electrification, light extinction, and optical scintillation) may not be applicable.
In addition to PS-11, the EPA also produced QA and QC measures designed to ensure
that the ongoing PM data collected by the PM CEMS is valid. These QA/QC measures are found
in Procedure 2. The following QA/QC and data handling issues must be specified in the
applicable regulation:
1. What is the appropriate frequency for confirming the correlation (e.g., annually, every
18 months, every 5 years)? In Germany, many correlations are not checked for 5 years.
The EPA added a 3-run Reference Method check of the correlation equation, called a
relative response audit, to be done annually.
2. What is continuous data (e.g., are four 15-minute block averages needed for an hourly
average), and how does continuous apply to batch type monitors (i.e., beta attenuation)?
If a batch type PM CEMS samples stack gas for 9 minutes out of each 15-minute period,
is this CEMS collecting continuous data?
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8.0 SUMMARY OF PS-11 AND PROCEDURE 2
The initial proposed versions of PS-11 and Procedure 2 were published in the Draft
Technical Support Document for HWC MACT Standards, Volume IV: Compliance with the
Proposed MACT Standards dated February 1996. Public comment was received, and additional
revisions were made. PS-11 and Procedure 2 were published again in December 1997.
Additional comments were received, and EPA has continued to learn about the capabilities and
performance of PM CEMS. The following sections present EPA's latest approach to PS-11 and
Procedure 2. EPA intends to publish a supplemental proposal for PS-11 and Procedure 2 by the
end of 2000.
8.1 PS-11
PS-11 is used for evaluating the acceptability of a PM CEMS at the time of or soon after
installation, and whenever specified in the source's applicable regulation. This performance
specification requires site-specific correlation of the PM CEMS response against manual
gravimetric Reference Method measurements (including those made using EPA Reference
Methods 5 or 17). PS-11 outlines the procedures and acceptance criteria for installation,
operation, calculations, and reporting of data generated during a PM CEMS correlation. PS-11 is
unique, relative to the performance specifications for other CEMS because it is based on a
technique of correlating PM CEMS response to emissions determined by the Reference Method.
This differs from a CEMS measuring gaseous pollutants which has available calibration gases of
known concentration.
As presented in Section 4 "Summary of Known PM CEMS," several different types of
PM CEMSs, which use different operating principles, are available. The selection of an
appropriate PM CEMS is dependent on site-specific configurations, flue gas conditions, and PM
characteristics (see Section 7 "PM CEMS Implementation" for source applicability). After an
appropriate PM CEMS is selected, it must be installed at an accessible location downstream of
all pollution control equipment. The PM CEMS concentration measurements must be performed
from a location considered most representative or from one that can provide data that can be
corrected to be representative of the total PM emissions as determined by the manual Reference
Method. The site-specific correlation developed during the Performance Specification testing
must relate specific PM CEMS responses to integrated paniculate loadings.
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After completing the initial field installation, the PM CEMS is operated for a Shakedown
Period. The objective of the Shakedown Period is for the facility operators to become familiar
with the PM CEMS and its routine operation for providing reliable data. The Shakedown Period
continues until the instrument technicians are comfortable with the operating characteristics of
the PM CEMS and that the PM CEMS is operating within the manufacturer's specifications.
After completing the Shakedown Period, the PM CEMS is operated for a Correlation Test
Planning Period. The objective of this period is to identify the full range of operating conditions
and PM emissions to be used in the PM CEMS correlation test. During the Correlation Test
Planning Period the process and air pollution control equipment are operated in their normal set
of operating conditions, except when attempts are purposely made to produce higher emissions.
The Correlation Test Planning Period continues until the source owner is satisfied that the
complete range of PM emissions have occurred. During the Correlation Test Planning Period,
the operators must establish whether the monitor is operating in a suitable range(s) relative to the
source's emission profile. The objective here is to assure that the monitor's measurement range
is broad enough to measure peak emissions yet sensitive enough to address low-emission
conditions. Ideally the monitor should be reading near mid-scale during normal conditions but
never reading off-scale during peak emissions.
The performance of the PM CEMS is judged from the results of two tests: (1) 7-day drift
test and (2) initial correlation test. The 7-day drift test is to validate the internal performance of
the PM CEMS relative to its own zero and upscale drift checks for seven consecutive days. The
purpose of the 7-day drift measurement is to verify that the PM CEMS response is the same as
that established during the development of the initial correlation and to determine whether the
PM CEMS is in control during day-to-day operation. The initial correlation test is done to
develop the relationship between the PM CEMS responses and the manual Reference Method
results over a range of PM concentrations. Collection of Reference Method PM data using
paired trains is required. Each set of paired train results must achieve a specific level of
precision to be used in the correlation data set.
For the correlation relation tests, a minimum of 15 valid runs must be conducted, each
consisting of simultaneous PM CEMS and Reference Method measurements sets and covering
the full range of PM concentrations identified during the Correlation Test Planning Period. The
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Reference Method measurements consist of paired trains operated simultaneously. For
acceptable Reference Method measurements, the paired trains must meet precision and bias
criteria. Ideally, the manual Reference Method data would be distributed over the complete
operating range experienced by the facility, with at least 20 percent of the minimum 15 measured
data points in each of the following three levels:
Level 1: From zero PM concentration to 50 percent of the maximum PM concentration.
Level 2: 25 to 75 percent of the maximum PM concentration.
Level 3: 50 to 100 percent of the maximum PM concentration.
Although the above levels overlap, individual run data may only be applied in one level.
Lower and higher than normal PM concentrations may be intentionally created by operating the
facility outside of its normal operation, but, at a minimum, the correlation data must include the
range of PM CEMS responses observed during the Correlation Test Planning Period. The
correlation relation can only be extrapolated to 125 percent of the highest PM CEMS reading
observed during the correlation test. If the PM CEMS records readings higher than 125 percent
of the highest PM CEMS reading observed during the correlation test for three consecutive
hours, three additional Reference Method test runs must be made at the higher PM CEMS
response. The correlation relation must be revised within 30 days of the occurrence.
Developing a PM CEMS correlation will affect plant operations for about a week while
the correlation tests are being performed. PS-11 does not require the source to emit PM that
exceeds the PM emission limit during the correlation test.
From the complete set of correlation data, the correlation coefficient, confidence interval,
and tolerance interval are calculated for a polynomial and a linear regression. A test to determine
if the polynomial regression offers a statistically significant improvement to the preferred linear
regression is done. The correlation coefficient, confidence interval, and tolerance interval for the
selected regression must meet the performance criteria in PS-11.
8.2 PROCEDURE 2
40 CFR Part 60, Appendix F, Procedure 2 describes the procedures used to evaluate the
effectiveness of QA and QC procedures and the quality of the data produced by any PM CEMS
that is used for compliance monitoring. The QA/QC practices of Procedure 2 consist of
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daily drift and sample volume checks
quarterly audit of the PM GEMS's accuracy in response to reference standards
quarterly audit of the measured sample volume
longer-term assessment of the stability and applicability of the initial correlation relation.
Also included in Procedure 2 are assessments of the accuracy and precision of the
Reference Method data used in the correlation relation assessment.
Procedure 2 requires a written QA Plan that includes complete detailed QA/QC
procedures. If the PM CEMS fails to meet the acceptable criteria for any Procedure 2 audit, the
PM CEMS is called out-of-control. When the PM CEMS is out-of-control for two consecutive
periods, procedures in the QA Plan must be enhanced to prevent a repeat of the out-of-control
condition.
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9.0 PM CEMS COST
The data on Tables 9-1 and 9-2 are based on actual expenditures experienced by the EPA
in field studies, information gained from interviews with users, and the expected costs of
appropriate QA/QC requirements in the draft performance specifications and associated
procedures. The tables point out that costs can vary widely, mainly according to the frequency of
the RCA. Since the costs in Tables 8 and 9 were developed, the EPA has received new
information about PM CEMS costs. The EPA believes the First Costs may be a little low
because of the potential need for more Reference Method particulate testing than originally
anticipated. Additional test runs may be needed during the Correlation Test Planning Period in
order to assess the proper measurement range for the PM CEMS.
TABLE 9-1. IN-SITU (LIGHT SCATTERING) PM CEMS COSTS3
Task
Total First Costs (Equipment, installation, initial
testing, correlation)
Total Annual Costs - RCA done every year
RCA done every 1 8 months
RCA done every 3 years
Total cost $
102,600-132,600
51,800-82,800
40,700-71,700
29,600 - 60,600
TABLE 9-2. EXTRACTIVE (BETA GAUGE) PM CEMS COSTS"
Task
Total First Costs (Equipment, installation, initial
testing, correlation)
Total Annual Costs - RCA done every year
RCA done every 18 months
RCA done every 3 years
Total cost $
140,000-170,000
58,200 - 88,800
47,100-77,700
36,000 - 66,600
1 Assumptions for these tables are given in Appendix A
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10.0 REFERENCES
1. Act to Amend the Industrial Code and Expand the Civil Code, Federal Law Gazette
(BGB1), Part I, No. 54, December 1959
2. Breton, H., Overview of German Emission Monitoring Regulations, in Proceedings,
Continuous Emission Monitoring: Present and Future Applications, AWMA International
Specialty Conference - Chicago, pp. 44-54, 1989.
3. Conner, W.D. and Hodkins, J.R., Optical Properties and Visual Effects of Smoke-Stack
Plumes, U.S. Public Health Service Publication No. 999-AP-30, NTIS Publication
Number PB 174-705, Springfield, VA, 1967.
4. Conner, W. D., Measurement of Opacity and Mass Concentration of Paniculate
Emissions by Transmissometry, EPA 650/2-74-128.
5. Conner, W.D., Knapp, K.T., and Nader, J.S., Applicability of Transmissometers to
Opacity Measurement of Emissions - Oil-fired Power Plants and Portland Cement
Plants, EPA 600/2-79-188.
6. Draft Technical Support Document for HWC MACT Standards, Vol. IV: Compliance
with the Proposed MACT Standards, U. S. EPA Office of Solid Waste and Emergency
Response, February 1996.
7. Evaluation of Particulate Matter Continuous Emission Monitoring Systems, U. S. EPA
Office of Air Quality Planning and Standards, EPA-454/R-00-040, 2000.
8. Fabric Filter Bag Leak Detection Guidance, U. S. EPA Office of Air Quality Planning
and Standards, EPA-454/R-98-015, 1997.
9. Farthing, W.E. and Williamson, A.D., Characterizations of Continuous Particulate
Monitoring Approaches for Stationary Sources, in Continuous Compliance Monitoring
Under the Clean Air Act Amendments, AWMA, Pittsburgh, PA, pp. 194-207, 1995.
10. Federal Minister for the Environment, Nature Conservation, and Nuclear Safety, Air
Pollution Control Manual of Continuous Emission Monitoring, Regulations and
Procedures for Emission Measurements, 2nd Revised Edition, Federal Republic of
Germany, 1992.
11. Giel, T.V., Douglas, J.R., Benin, M.P., and Holve, D.J., Measurement of Particle Volume
Concentrations with a New CEMfor Particulate Emissions, in Proceedings of the 88th
Annual Air & Waste Management Association Conference, 95-MP17.03, A&WMA,
Pittsburgh, 1995.
10-1
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12. Gnyp, A.W., Price, S.J.W., St. Pierre, C.C., and Smith, D.S., Long Term Field Evaluation
of Continuous Paniculate Monitors, in Proceedings: Advances in Particulate Sampling
and Measurement (Ashville, NC, May 1978), EPA-600/79-065, pp. 122-168, 1979.
13. International Standards Organization (ISO), Automated Monitoring of Mass
Concentration of Particles in Stationary Source Emissions: Performance Characteristics,
Test Procedures, and Specifications, ISO 10155, 1995.
14. Jockel, W., Monitoring Dusty Emissions - Measurement Technology in Transition,
Modified version of a lecture presented at Durag and Hegwein Group in Hamburg,
Germany, November 17, 1998 (English Translation).
15. Jockel, W., Continuous PM Monitoring, in EntsorgungsPraxis 9, pp. 36-40, 1999.
16. Joklik, R., Issues Related to Implementation, in Proceedings: Particulate Continuous
Emission Monitoring Workshop, Center for Waste Reduction Technologies, ISBN
#0-8169-0802-8,1999.
17. Martin, P., Continuous Emission Monitoring; Particulate Measurement in Flue Gases,
Congress on Continuous Emission Monitoring for Process Control and Regulatory
Compliance, London, Ontario, Canada, May 1994.
18. Nader, J.S., Current Technology for Continuous Monitoring of Particulate Emissions,
J. Air Poll. Control Assoc. Vol. 25, No. 8, pp. 814-821, 1975.
19. Peeler, J.W., Jahnke, J.A., and Wisker, S.M., Continuous Particulate Monitoring in
Germany and Europe Using Optical Techniques, in Continuous Compliance Monitoring
Under the Clean Air Act Amendments, A&WMA, Pittsburgh, pp. 208-220, 1995.
20. Peeler, J.W. and Jahnke, J.A., Handbook: Continuous Emission Monitoring Systems for
Non-criteria Pollutants, EPA 625/R-97/001, April 1997.
21. Performance Testing of the F-904 Beta Gauge Particulate Monitor Manufactured by
Verewa, TUV Report: 3.5.2/209/88 - 338529 (Translated to English).
22. Report on the Performance Testing of the D-R 300-40 Dust Concentration Monitor, TUV
Report: 936/801004, Cologne, Germany, 1992 (Translated to English).
23. Report on the Suitability Testing of the Dust Emission Measuring Instrument CTNR of
the Company Sigrist-Photometer AG, TUV Report: 936/806015, Cologne, Germany,
1997 (Translated to English).
24. Roberson, Ralph L., Mitchell, G.C., and Dene, C.E., Evaluation of Continuous
Particulate Matter (PM) Monitors for Coal-Fired Utility Boilers with Electrostatic
10-2
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Precipitators, in Proceedings of the May 1999 CEM Users Group Meeting, Electric
Power Research Institute, Palo Alto, CA., 1999.
25. Sem, Gilmore J. et al., State of the Art: 1971 Instrumentation for Measurement of
Paniculate Emissions From Combustion Sources, Volume II: Paniculate Mass-Detail
Report, APTD-0734, U. S. EPA, Research Triangle Park, 1971.
26. Standard Practice in the Federal Republic (of Germany) Regarding the Monitoring of
Emissions: Guidelines on the Suitability Testing, Installation, Calibration and
Maintenance of Instruments for the Continuous Measurement of Emissions, RdSchr. of
the BMU of 3/1/90, GMBI, 1990.
27. (TA Luft) Technical Instructions for Clean Air Maintenance, General Implementation
Rules for Installations Subject to Official Approval Pursuant to § 16 of the Industrial
Code, Joint Publication of the Federal Ministries (GMBI), No. 15, p. 433, September 8,
1964.
28. Uthe, E.E., Evaluation of an Infrared Transmissometer for Monitoring Paniculate Mass
Concentrations of Emissions from Stationary Sources, J. Air Poll. Control Assoc.
Vol. 30, pp. 382-386, 1980.
29. VDI 2066, Part 4: Measurement of Paniculate Matter in Flowing Gases; Determination
of Dust Load by Continuous Measurement of Optical Transmission, Verein Deutscher
Ingenieure, Dusseldorf, Germany, 1989.
30. VDI 2066, Part 6: Measurement of Paniculate Matter in Flowing Gases; Determination
of Dust Load by Continuous Measurement of Scattered Light with the Photometer KTN,
Verein Deutscher Ingenieure, Dusseldorf, Germany, 1989.
10-3
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APPENDIX A
BREAKDOWN OF PM CEMS COSTS
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LIGHT SCATTERING PM CEMS COSTS
Task
Planning
Select Equipment
Provide Support Facilities
Purchase CEMS
Install & Check CEMS
Performance Spec. Tests
Prepare QA Plan
Total First Costs
Operation & Maintenance
Annual RATA (O2 monitor)
PM Monitor RCA
Quarterly ACA
Record Keeping
Annual Review & Update
Capital Recovery
Total Annual Costs
If RCA done every 18 months
If RCA done every 3 years
Total Cost $
3,500
10,300
1,000-8,100
36,000-47,100
9,900
25,000 - 36,800
16,900
102,600 - 132,600
12,900
0 - 5,800
15,000-26,300
1,000-7,000
7,500
1,000-4,400
14,364-18,880
51,800 - 82,800
40,700 - 71,700
29,600 60,600
A-3
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BETA GAUGE PM CEMS COSTS
Task
Planning
Select Equipment
Provide Support Facilities
Purchase CEMS
Install & Check CEMS
Performance Spec. Tests
Prepare QA Plan
Total First Costs
Operation & Maintenance
Annual RATA (O2 monitor)
PM Monitor RCA
Quarterly ACA
Record Keeping
Annual Review & Update
Capital Recovery
Total Annual Costs
If RCA done every 18 months
If RCA done every 3 years
Total Cost $
3,500
10,300
1,000-8,100
71,000-82,100
12,300
25,000 - 36,800
16,900
140,000 - 170,000
13,700
0 - 5,800
15,000 - 26,000
1,000-7,000
7,500
1,000-4,600
20,000 - 24,200
58,200 - 88,800
47,100 - 77,700
36,000 - 66,600
A-4
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TECHNICAL REPORT DATA
(Please read Instructions on reverse before completing)
1 REPORT NO 2
EPA--454/R-00-039
4 TITLE AND SUBTITLE
CURRENT KNOWLEDGE OF PARTICULATE
CONTINUOUS EMISSION MONITORING
7. AUTHOR(S)
Dan Bivins - Emission Monitoring and Analysis
(PM)
Division
9 PERFORMING ORGANIZATION NAME AND ADDRESS
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Research Triangle Park, NC 27711
12 SPONSORING AGENCY NAME AND ADDRESS
Director
Office of Air Quality Planning and Standards
Office of Air and Radiation
U.S. Environmental Protection Agency
Research Triangle Park, NC 2771 1
3. RECIPIENT'S ACCESSION NO.
5 REPORT DATE September 2000
6 PERFORMING ORGANIZATION CODE
8 PERFORMING ORGANIZATION REPORT NO
10. PROGRAM ELEMENT NO
11 CONTRACT/GRANT NO.
68-W6-0048
13. TYPE OF REPORT AND PERIOD COVERED
14 SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES
16 ABSTRACT
This report provides detailed information on the current knowledge of PM CEMS. This information was gained from literature
reviews; attendance at many meetings and conferences where the use of PM CEMS was discussed; shared knowledge between the
EPA, industry, and consultants experienced with PM CEMS in both the United States and Europe; discussions with PM CEMS
vendors; and personal experiences from performing a field demonstration of PM CPMS. The report will be maintained as a
"living document" with periodic updates as needed.
17 KEY WORDS AND DOCUMENT ANALYSIS
a DESCRIPTORS
Paniculate Matter Continuous Emission Monitoring Systems
PM CPMS
Method 17
PS- 11
Procedure 2
Beta gauge
light scattering
tnboelectric
optical
opacity
18 DISTRIBUTION STATEMENT
Release Unlimited
b IDENTIFIERS/OPEN ENDED TERMS
Air Pollution control
19 SECURITY CLASS (Report)
Unclassified
20 SECURITY CLASS (Page)
Unclassified
c COATI Field/Group
21 NO. OF PAGES
100
22 PRICE
EPA Form 2220-1 (Rev. 4-77)
PREVIOUS EDITION IS OBSOLETE
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