EPA/600/A-92/277

       INNOVATIVE SENSING TECHNIQUES FOR MONITORING AND
      MEASURING SELECTED DIOXINS, FURANS, AND POLYCYCLIC
                AROMATIC HYDROCARBONS IN STACK GAS


                                Dr. Jeffrey A. Draves

                                 Radian Corporation
                                 P. O. Box 201088
                              Austin, Texas  78720-1088

                               Mr. Dave-Paul Dayton

                                 Radian Corporation
                                  P. O. Box 13000
                     Research Triangle Park, North Carolina 27709

                                Mr. Thomas J. Logan

                         U.S. Environmental Protection Agency
               Atmospheric Research and Exposure Assessment Laboratory
                     Methods Research and Development Division
                           Source Methods Research Branch
                     Research Triangle Park, North Carolina 27711
ABSTRACT

   The U.S. Environmental Protection Agency (EPA) has determined the need to develop in situ
continuous or semi-continuous emissions monitoring (CEM) techniques for assessing dioxin, furan,
and polycyclic  aromatic hydrocarbon (PAH) emissions from municipal  solid waste (MSW)
incinerators and other sources. These species have a potential public health risk because of their
low associated exposure limits.
   This paper  discusses 12 innovative optical sensing techniques, which were  evaluated for
application to continuous monitoring approaches. The ability of each of the techniques to function
as a CEM system is discussed.  Two techniques, that appear to have the most potential for
successful application, are Ultraviolet (UV) Direct Measurement and Fluorescence Measurement.
Vapor phase UV spectral data for selected dioxins, furans, and polycyclic aromatic hydrocarbons
are being generated to determine limits of detection and assess applicability of the techniques.

INTRODUCTION
   Dioxins and furans are formed as byproducts from combustion processes  and from certain
industrial chemical processes using chlorine (e.g., paper bleaching and pesticide production). The
toxicity of these compounds makes  them  a great human health concern.  Another class of
compounds, PAHs, is also associated  with  combustion processes.  A number of the  PAH
compounds are highly mutagenic and/or carcinogenic.  A potential emission source of dioxins,
furans,  and PAHs is MSW  incinerators.
   Current measurement  techniques for dioxins and furans involve collecting samples  using
U.S. EPA Method  23. Once collected, the dioxins and furans are identified and quantified using

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high resolution gas chromatography  (HRGC)  coupled with high resolution mass spectrometry
(HRMS). Approximately 2 months of processing time are required between Method 23 sample
collection and data reporting. Due to the acute and genetic toxicity of these compounds, the U.S.
EPA has determined that a continuous technique for monitoring dioxins, furans, and PAHs in stack
gas is needed1. Currently, there are  no technologies at a state of development to continuously
quantitate or monitor these compounds or other trace organic constituents of stack gas. Therefore,
a fundamental  research and development project  is being  conducted  to  address the need for
continuous monitoring of dioxins, furans, and PAHs.
   The U.S. EPA has specified that the monitoring technique should provide for the following:

   *      Vapor phase measurements (continuously or semi-continuously);

   •      Capability of achieving a detection limit of 100 nanogram/normal cubic meter (ng/Nm3)
          of total dioxin (the detection limits for the furans and PAHs were not specified);

   •      Particulate phase measurement (if feasible); and

   •      Speciated quantitation (if feasible).

Overview of the Research and Development Project
   The research and development project is being conducted in five separate steps. These steps
are as follows:

   »      Step I - Feasibility Study;

   •      Step II - Spectral Measurements;

   •      Step III - Instrument Design and Fabrication;

   •      Step IV - Pilot Scale Testing; and

   »      Step V - Full Scale Field Testing.

The primary objectives of Step I, the Feasibility Study, are:

   •     To conduct a technology investigation to identify and  evaluate applicable candidate
          measurement techniques; and

   •     To provide a plan for development of the technique(s), that would have the greatest
         potential for successful application as a CEM system.

   Step  II, Spectral Measurements,  is designed to obtain  measurements of the  vapor phase
absorption spectra and measurements of the fluorescent lifetimes and to determine the fluorescence
profiles of three of the 75 chlorinated dibenzodioxins, two of the 155 chlorinated dibenzofurans,
and one representative PAH species.  Candidate compounds are as follows:

   •     2,3,7,8-tetrachlorodibenzo-p-dioxin;

   *      1,2,3,7,8-pentachlorodibenzo-p-dioxin;

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   •      Octachlorodibenzo-p-dioxin;

   •      2,3,7,8-tetrachlorodibenzofuran;

   *      Octachlorodibenzofuran; and

   •      Benzo-a-pyrene.

   These six compounds present a representative cross-section of these classes of toxic species and
were chosen because of their level of toxicity and their likelihood of being emitted.  (Step II is in
progress.)
   Step in involves the actual design and fabrication of the monitoring instrumentation.
   Step IV involves testing the instrument produced in Step HI, at a small well-characterized
emissions source or simulated emissions source.
   Step V involves refining the instrument, based on information obtained during Step IV, and
then performing a field evaluation at a full scale operating emissions source.
   This paper specifically presents the results of Step I and the objectives of Step n of the research
and development  project.

Evaluating Optical Sensing Techniques
   The term optical sensing (OS), as used in this paper, refers to  the interaction of light with
matter (i.e.,  molecules, atoms or aerosols/paniculate) to  yield  qualitative and quantitative
information.  The  OS techniques are, for the  most part,  common laboratory spectroscopic
techniques that are applied to environmental monitoring. The advantages of OS techniques over
conventional analysis methods include real-time data analysis, structural specificity, and, in many
instances, in-situ monitoring capacity.

Requirements of Optical Sensing Techniques
   During the investigation, desired minimum performance criteria of OS systems were determined
to ensure both  accurate and rapid monitoring of dioxins, furans and PAHs. The categories "tor
which instrument  performance was evaluated are stated below:

   •     Frequency of Measurement.  This indicates whether the instrument is a continuous or
         semi-continuous monitor. The more frequently a measured value is obtained the higher
         the frequency of measurement. The evaluation is expressed in measurements per hour.

   •      Sensitivity.  This indicates whether the instrument can meet the desired 100 ng/Nm3
         detection limit and can distinguish between individual dioxin and furan isomers, and
         PAH compounds.  The  100 ng/Nm3 sensitivity level was specified by the U.S. EPA as
         the minimum sensitivity necessary for preliminary  technique consideration.  The  100
         ng/Nm3 is  based  on the measured emissions from MSWs  currently in operation..
         However, new regulations require that newly  constructed MSWs meet a 30 ng/Nm3
         emission level. While the techniques selected for further investigation will likely meet
         the 100 ng/Nm3 sensitivity level, their actual detection limits are uncertain because no
         vapor phase spectra of  the compounds of interest are currently  available.  Once  the
         measured spectra are obtained, a more accurate assessment of the minimum detectable
         limits will be made.

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   •      Constraints (Analytical and Physical).  This indicates the expected level of development
          required to achieve the capability of continuous monitoring. Analytical constraints refer
          to  the need to develop computer control software.   Physical constraints refer to
          development required to enable the technique to be used in a stack environment. The
          evaluation is expressed in person-years required to complete development.

   •      Paniculate Matter. This indicates whether the instrument can measure the compounds
          of interest on paniculate matter.

   •      Ease of Use.  This is an estimate  of the amount of training necessary to operate the
          instrument on a day-to-day basis. The evaluation is expressed in person-hours required
          to complete training.

   •      Maintenance. This is an estimate  of the amount of routine maintenance that may be
          required  by the instrument.    Maintenance includes down-loading of data,  optics
          alignment, diagnostic checks, etc. The evaluation is expressed in person-hours required
          to perform maintenance.

   •      In situ Monitoring.  This  indicates whether the instrument can measure the compounds
          of  interest in  the  stack, as  opposed  to  extracting samples from  the stack  for
          measurement.

   •      Cost.  This is an estimate of the expected associated cost of the instrument (based on
          a combination of the prototype and production  costs of the apparatus only).

Optical Sensing Techniques Considered  for Investigation
   Twelve OS techniques were considered for dioxin, furan, and PAH monitoring. The techniques
were selected for evaluation by reviewing available literature and through discussions with experts
in OS  applications.   The structural properties of the  compounds of interest were also used as
criteria for selection. The techniques are presented in Table I  and divided according to their
spectral region of operation.  Most of the OS systems considered operate using either UV or
infrared (IR) light. Two techniques, photoacoustic spectroscopy (PAS) and Multiphoton lonization
(MPI), are listed as  "consequence" techniques because the result of light  absorption is monitored,
instead of the increase or the decrease of the light intensity itself.
   Table II presents possible operating configurations  (e.g., extractive and/or in-situ) for eacrrof
the techniques presented in Table I. Figures 1 and 2 illustrate conceptual operating configurations
of OS systems in extractive and in-situ monitoring modes.  In either operating configuration, the
light beam is  multipassed to  extend the measured path length.

Techniques Considered for Further Investigation
     Each of  the techniques presented in Table I was evaluated in reference to the performance
criteria categories listed above. The results of this evaluation are given in Table III.
   The techniques were ranked for each category on a  scale of 0 to 10, with 10 indicating the best
result.  The scores from the individual categories were  then summed. The two techniques having
the highest summed  scores were selected for further consideration.  When summed, the highest
ranking techniques were  UV absorption and laser induced fluorescence  (LIF).  The operation
principles of each of these methods are described below.

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Ultraviolet Absorbance Spectroscopy
    The UV absorbanee spectroscopy is conventional absorption spectroscopy using an appropriate
broad-band excitation source, such as a Xenon arc lamp . The technique is well developed and
requires about 1 minute or less, depending on the signal-to-noise ratio  (S/N), to identity and
quantitate the concentration of a single species. It is also possible to use laser light sources (e.g.,
an excimer pumped dye laser).  The laser techniques are not, however, as well developed as the
broad-band technique. Typically, UV provides better sensitivity than IR because the UV band
strengths are  greater and  light  sources  are more intense.   However, not alt compounds are
observable in the UV region.  Further investigation will be necessary to evaluate possible dioxin or
ftiran detection in the UV or near visible region.
    The  literature review and  feasibility study yielded  no vapor phase UV  spectra  for the
compounds of interest.  However, liquid phase spectra2 and subsequent detection limits do exist
for several furan compounds.  Extrapolation of the liquid phase detection limits to the vapor phase
has been performed. The extrapolation is difficult for the following reasons:

    •     The type of solvent used can have a large effect on both the position of the absorbanee
         peak and its intensity.

    •     The solvent interacts with the dioxins, furans, and PAHs to hinder rotational motion,
         causing significant  changes in the width and intensity of the spectral features.

    •     The temperature difference between vapor and liquid phases can significantly increase
         the  population of higher rotational states, causing a decrease in peak intensity and a
         broadening of the spectral feature.  However, the lower frequency of collisions in the
         vapor phase will lead to longer lifetimes and narrower absorption features.  The overall
         result of these two  processes is difficult to predict a priori, but a factor of 10 increase
         in intensity is possible.

    Although not exact, these extrapolations indicate the order of magnitude of the detection limits
that can be expected in the vapor phase for the compounds of interest.
    As is shown in Table IV, the expected UV detection limits increase as the molecular weight of
the furan increases.  Over a 100-m path,  the detection limits  range  from 18.6 ng/Nm3 for
dibenzofuran to 2,353 ng/Nm3 for the heptachlorofurans.  The detection limit for the most toxic
isomer,  the tetraehlorodibenzofuran is 25.6 ng/Nm3. Considering the increase in spectral intensity
(about an order of magnitude in most cases) upon going from the liquid phase to the vapor phase,
detection limits of 1.86, 235.3, and 2.56 ng/Nm3 can be  expected  for these three furans.  These
detection limits, while only an order of magnitude estimate at best, are encouraging and fall within
the required detection limit of 100 ng/Nm3 for several of the furans.
   In the UV region of the spectrum, background interferences are minimal. While water vapor
and CO2 can significantly hamper IR detection limits, they have negligible effects in the UV region.
Other compounds present in the  stack gas may  interfere with UV detection.  Potential interfering
compounds include dioxins, furans, PAHs not  of interest, and  other compounds attached to the
surface  of the  paniculate matter. The lack of spectral information on dioxins, furans, and PAHs
makes exact identification of  interferants presently impossible.

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Fluorescence
   Fluorescence relies on  the excitation of the molecule of interest to  a known state by the
absorption of a photon from a light source (e.g., Xenon arc).  The photon is either emitted at the
same frequency (or more likely at  a lower frequency) and  monitored by a spectrometer. The
response times will generally be similar to those for the UV absorbance.  However, because
photoemissions can take on the order of seconds, it will be necessary to investigate the fluorescence
spectra and lifetimes.
   As with UV absorption, the sources are  capable of accommodating long path lengths, but the
fluorescence volume and, therefore,  the solid angle relative to the detector is important and must
be considered.  The amount of fluorescence is governed by Equations  1 and 2:

                            F = 2.3 « 1(0) * f(0) * g(?) « A (v)                  [Equation 1]

where:    1(0)   =    the incident light intensity
          f(0)   =    solid angle of irradiated volume falling on the detector
          g(i>)   =    the detector's response
          A(p)  =    the Beer's Law absorbance of the sample.

Replacing A with the components of Beer's Law gives the following:

                          F =  2.3 * 1(0) * f(0) « g(v) * a(»>) * c * 1               [Equation 2]

where:    a(i>)   =    the molecular absorbance strength
          1      =    is the path length
          c     =    concentrations

   No vapor phase fluorescence spectra of the compounds of interest were found during the
literature review.  However, liquid phase detection limits do  exist.  In this case, extrapolation of
the liquid  phase detection limits  to the vapor phase is difficult for the same reasons stated above
and for the following additional reasons:

   »      The limits of detection are not  solely dependent on the path length,  but  are also
          dependent upon the solid angle of the excitation volume that is  visible to the detector.

   •      Species  that can absorb the emitted photon by being located between the  emitting
          species and the detector may exist,

   «      The emission of light requires a finite amount of tune.  The species emitting the light
          are moving, both up the stack and out of the original excitation volume.  This motion
          may require the detector to be placed up the  stack from the source. Diffusion out of the
          excitation volume  will make  the detection limits higher as the excited  volume is
          increasing.

Expected fluorescence detection limits are presented in Table V.
   Trace components, such as the PAHs, the polychlorinated  biphenyls (PCBs), and other dioxins
and furans, may interfere with the fluorescence technique. The measurement of a single compound
will depend upon its fluorescence lifetime.

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    Laser Induced Fluorescence. The LIF technique is conceptually similar to the fluorescence
technique described above. The UF technique uses a carefully tuned laser to excite the molecule
of interest.  This careful tuning allows for very specific excitations and more specific compound
identifications.  As with the fluorescence technique above, the emitted photon can then be
monitored as a function of frequency with a spectrometer of appropriate resolution. This gives the
ability to both  selectively excite and selectively detect the compounds of interest.  The LIF
technique has been shown to be very sensitive for detecting  PAH compounds.
    The advantages of LIF over fluorescence are twofold. The first advantage is. that a laser light
source is much more specific in terms of which species are excited.  Consequently, the species will
be excited to a narrow band of states, making the emission spectra less complicated and easier to
interpret. The  second advantage is the increase in light intensity that  is obtained when using a
laser source. Because fluorescence is directly  related to the intensity of the  light source, lasers
offering greatly increased light intensity at the specific wavelength of interest will cause an increase
in the fluorescence.
    As with  the  fluorescence technique discussed above there  is no vapor  phase information
available concerning the compounds of interest. This lack of information makes identifying of the
appropriate  laser source difficult.   The frequency  of measurement will again depend  on the
fluorescence lifetime, but should be similar to UV absorption (on the order of 1 minute or less),
depending on the S/N ratio, per species.
    Actual vapor phase absorption spectra, emission spectra,  and emission lifetimes must be
obtained to  better characterize the ability of these techniques to measure  the  compounds of
interest.

Measurement of Vapor Phase Spectra
    One of the limiting factors in the feasibility study was the  absence of vapor phase spectral data
for the dioxin, furan, and PAH compounds. Lack of spectral information not only made identifying
the appropriate  OS techniques difficult, but  also affect the implementation of the  technique
because reference spectra  are generally needed to identify and quantify species.
    Vapor phase spectral data  are being obtained, in a temperature range typical of incinerator
stack emissions, for the six selected dioxins, furans, and PAHs presented above.
    The measurement  program consists of measuring the UV absorbance cross-sections for each
of the selected compounds.  The absorbance spectra will be used to identify  features  for use in
detection, as well as to pick the appropriate laser excitation  sources for LIF measurements. The
fluorescence wavelengths  and  cross-sections will then be identified.   Finally, the fluorescence
lifetime will  be measured for each  selected compound.

CONCLUSIONS
    The feasibility study yielded two techniques, UV absorption and OF, that have the potential
to be applied to real-time monitoring of dioxins, furans and PAHs,  The lack of vapor phase
spectral information precludes narrowing the  field  further.  Further information is needed to
definitively specify the most applicable technique.
   A  program designed to obtain  vapor phase spectral information for selected compounds of
interest is presently ongoing.  The spectral information that  is obtained will consist of measured
UV absorbance spectra, LIF spectra, and fluorescence lifetimes.

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REFERENCES
   1.     J.A.  Draves,  D-P.  Dayton, and  J.T. Bursey,  Innovative Sensing Techniques  for
         Monitoring and  Measuring  Selected Dioxins.  Furans.  and  Polycyclic  Aromatic
         Hydrocarbons in Stack Gas. Final Report.  DCN No. 91-275-065-10-09,  Radian
         Corporation, October 1991.

   2.     E.B.  Gonzalez,  R.A.  Baumann,  C. Gooijer,  N.H.  Velthorst,  and  R.W.  Frei,
         Chemosphere, 16 pp 1123-1135, (1987).

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               Table I.  Spectra! regions of the optical sensing techniques.
        Ultraviolet
        Infrared
     Consequence
UV Absorbance

Fluorescence

Laser Induced
Fluorescence (LIF)
ShpoPskii Spectroscopy
(SS)

Laser Induced Breakdown
Spectroscopy (LIBS)
Fourier Transform Infrared
   Spectroscopy (FTIR)

  Matrix Isolation/FITR
       (MI/FTIR)

  Gas Chromatography/
MI/FTIR (GC/MI/FTIR)

    Laser Absorbance
  Gas Filter Correlation
         (GFC)
    Photoacoustic
 Spectroscopy (PAS)

Multiphoton lonization
        (MPI)
                   Table II.  Extractive and non-extractive techniques.
Category
UV Techniques




IR Techniques



Consequence Techniques

Technique
UV Absorbance
Fluorescence
LIF
SS
LIBS
GC/MI/FTIR
MI/FTIR
FTIR
Laser Absorption
PAS
MPI
Extractive
X
X
X
X
X
X
X
X
X
X
X
In-situ
X
X
X

X


X
X

X

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                                                 Table III. Summary of techniques.
Technique
UV
Absorbance
Fluorescence

LIF

SS



LIBS

FTIR

MI/FTIR

GC/MI/FTIR


GFC

Laser
Absorbance
PAS

MPI

MS/MS

Frequency or
Measurements
[Number/Hour]
60

60

60

25







300

6


—

—

60

60

300

Sensitivity '
Within
specifications
Within
specifications
Within
specifications
Within
specifications


Out of
specification
Out of
specification
Possibly within
specification
Within
specification

Out of
specification
Out of
specification
Within
specification
No information

Within
specification
Analytical and Physical Partlculate
Constraint Matter
None No

Needs analysis software Yes

Will need stabilizers for Yes
optics; analysis software
Sampling and separation will No
need to be developed as will
solvent mixing system. Also
needs analysis software.




Needs development of a No
separation method
Needs development of No
software for control and
timing




Needs sample delivery Yes
system; computer software
Needs sample delivery No
system
Need downsizing and sample No
delivery system
Ease of Use
[Person-
Hour]
8

8

40

40







12

40






40

40

40

Maintenance
[Person-
Hour/Month]
2

2

5

10







10

10






15

10

12

In-
Situ
Yes

Yes

Yes

NcJ







No

No






No

No

No

Capital
Costs
(Thousands)
250

250

200

300







200

250






150

300

300

'Ability  to meet a 100 ng/Nm ' detection  limit and distinguish  among various  congeners.

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                         Table IV. Expected UV detection limits.
Path Length [M]:    0.0047
                                                      100
100
Species
DF
DF2
DF4
DF5
DF6
DF7
ng
0.008
0.038
0.11
0.11
0.44
1.01
tng/L]
400
1900
5500
5500
22000
50500
Dig/Mm3]
400
1900
5500
5500
22000
50500
[ng/Nm3]
18.64
88.54
256.3
256.3
1025.2
23533
[ppt]
02.7
09.1
20.5
18.4
66.8
140.5
DF = Dibenzofuran. Number after "DF indicates number of chlorines.
                      Table V.  Expected fluorescence detection limits.
Species
Dibenzofuran*
1,2,3,4
2,3,7,8
Dibenzodioxin
1,2,3,4
1,2,7,8
1,3,7,8
2,3,7,8
1,2,3,7,8
1,2,4,7,8
1,2,3,4,7,8
1,2,3,4,6,7,8
1,2,3,4,6,7,8,9
Wavelength
Excitation
285 246
292 252
307 257

230
230
232
235
232
232
230
232
232
[nm]
Emission
316 327
338 407
340

342 418
346
343
343
342 416
343
340 409
343 405
341
LOD
[ng/ml]
0.02
0.015
0.025

2
0.07
4
1.3
1.8
5.5
4.5
0.5
2.5
100 M
(ng/Nm3)
02
0.15
0.25

20
0.7
40
13
18
55
45
5
25
100 M
[PPt]
0.03
0.01
0.02

1.52
0.05
3.04
0.99
1.23
3.77
2.81
0.29
1.33
     The numbers in the column indicate the chlorinated positions.
                                                                                     11

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                                            Moisture
                                            Removal
   Heated
Paniculate Fitter
Data Aquls'rtion
                                                                                          Sample Stream
                                                                                              From
                                                                                            Incinerator
                                    Sample
          Figure 1.  Conceptual configuration of an optical sensing system in  an extractive mode.

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DISCLAIMER

   This paper has been reviewed in accordance with the U.S. Environmental Protection Agency's
peer and administrative review policies and approved for presentation and publication. Mention
of trade names or commercial products does not constitute endorsement or recommendation for
use.
                                                                                    14

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                                TECHNICAL REPORT DATA
 1. REPORT HO.

EPA/600/A-92/277
2.
 4. TITLE AND SUBTITLE
                                                           5.REPORT DATE
 Innovative  Sensing Techniques  for Monitoring and
 Measuring Selected Dioxins,  Furans,  and Polycyelic
 Aromatic Hydrocarbons in Stack Gas
                               6,PERFORMING ORGANIZATION CODE
 7. AUIHOR(S)

 Thomas J. Logan,  Dave-Paul Dayton,  Jeffrey A.  Braves
                               8,PERFORMING ORGANIZATION REPORT HO.
 9. PERFORMING ORGANIZATION NAME AND ADDRESS

 Radian Corp.,  P.O.  Box 201088,  Austin, TX 78720-
 1088; Radian Corp., P.O. Box  13000,  Research
 Triangle Park,  NC 27709
                                                           10.PROGRAM ELEMENT NO.
                               11. COKTRACT/GRANf NO.

                               68-D1-0010
 12. SPONSORING AGENCY NAME AND ADDRESS

 U.S. Environmental Protection Agency
 AREAL/MRBD/SMRB/PPIS (MD-77A)
 Research Triangle Park, NC  27711
                               13.TYPE OF REPORT AND PERIOD COVERED

                               Proceedings Paper
                               1*. SPOHSORIHG AGENCY CODE
 15. SUPPLEMENTARY BOIES
 16. ABSTRACT

 The U.S. Environmental Protection Agency (EPA)  has determined  the need to develop
 in-situ continuous or semi-continuous emissions monitoring  (CEM)  techniques for
 assessing dioxin,  furan, and  polycyclic aromatic hydrocarbon (PAH) emissions from
 municipal solid waste (MSW) incinerators and  other sources.  These species have  a
 potential public health risk  because of their low associated exposure limits.  This-
 paper discusses 12 innovative optical sensing techniques, which were evaluated for
 application  to  continuous monitoring approaches.  The ability  of  each of the
 techniques to function as a CEM system is discussed.  Two techniques that appear to
 have the most potential for successful application are Ultraviolet (UV) Direct
 Measurement  and Fluorescence  Measurement.  Vapor phase UV spectral data for
 selected dioxins,  furans, and polycyclic aromatic hydrocarbons are being generated ~
 to determine limits of detection and assess applicability of the  techniques.
 17.
                                 KEY WORDS AND DOCUMENT ANALYSIS
                   DESCRIPTORS
                                                b.IDENTIFIERS/ OPEN ENDED TERMS
                                               c.COSATI
 IS. DISTRIBUTION STATEMENT
                                                19, SECURITY CLASS (This Report)
                                               21.NO. OF PAGES

                                                    14
                                                20. SECURITY CLASS (This Page)
                                                                           22. PRICE

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