Particulate Matter Continuous Emission Monitors - Do they Really Work?, 2003 Environmental Conference Proceedings

Particulate matter (PM) mass monitors are commercially available for use as a PM continuous emission monitor system (CEMS). The instrument vendors continue to improve the monitor design and operation. The United States Environmental Protection Agency (EPA) continues to refine the performance criteria for a PM CEMS. Many PM CEMS studies have been conducted by EPA, trade associations, and individual companies to evaluate the feasibility of installing and operating a PM CEMS as a compliance monitor, a compliance indicator, and a process monitor. These studies have identified numerous issues associated with the use of PM CEMS technology for compliance monitoring. Although technical issues are unresolved and the EPA performance criteria has not been finalized, EPA continues to gain further knowledge and experience with PM CEMS for compliance monitoring. In one case, an electric utility installed a PM CEMS on a coal-fired boiler to meet the requirements of a consent decree, but has not successfully completed a performance demonstration using the EPA criteria in Performance Specification-11 (PS-11) and Procedure 2, as proposed in December 2001. A final version of PS-11 and Procedure 2 is expected in 2003. Although this will not directly affect the pulp and paper industry, this action indicates that PM CEMS technology has advanced to the point of potentially meeting EPA performance criteria. For Title V sources with units subject to Compliance Assurance Monitoring (CAM) Plan requirements, a PM CEMS may be an “indicator” of PM emissions in cases where other monitoring methods are not acceptable. A “one-of-a-kind” pulp manufacturing facility plans to install a PM CEMS as “surrogate” for PM emissions in their proposed CAM Plan for Title V permit renewal. This paper presents a history of the development of PM CEMS, a summary of PM mass measurement technology, a summary of US PM mass monitor studies, a report on the recent progress of the PM CEMS installations, and a discussion of applicability of PM CEMS in the pulp and paper industry.