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condensables of pm emissions epa
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Direct PMDirect PM2.52.5 Emissions Data, Emissions Data,
Testing, and Testing, and Monitoring IssuesMonitoring Issues
Ron MyersRon [email protected]@epa.gov
Measurement Policy GroupMeasurement Policy GroupSPPD, OAQPSSPPD, OAQPS
The IssuesThe Issues
Collecting data needed for effective Collecting data needed for effective inventories and SIP developmentinventories and SIP development
Selecting and prescribing Selecting and prescribing appropriate test methodsappropriate test methods
Improving monitoring in rulesImproving monitoring in rules Implementing a transition periodImplementing a transition period
Components of Direct PMComponents of Direct PM2.52.5
Filterable PMFilterable PM2.52.5
Solid or liquid material at stack temperature Solid or liquid material at stack temperature and higher (measured at ~250and higher (measured at ~250oo to 320 to 320oo F) F)
Stable in atmosphere and collected on ambient Stable in atmosphere and collected on ambient samplersampler
Condensable PMCondensable PM2.52.5
Vapor or gas at stack temperatureVapor or gas at stack temperature Condenses to liquid or solid at stack exitCondenses to liquid or solid at stack exit Stable in atmosphere and collected on ambient Stable in atmosphere and collected on ambient
samplersampler
Reasons to Consider Reasons to Consider CondensableCondensable
PMPM2.52.5 Emissions Emissions Condensable fraction of direct PMCondensable fraction of direct PM2.52.5 can be significant can be significant
10 to 50 percent of PM10 to 50 percent of PM2.52.5 emissions depending on control emissions depending on control measures, temperature, other source-specific conditionsmeasures, temperature, other source-specific conditions
Combustion, metallurgical & wood product sources Combustion, metallurgical & wood product sources emit large quantities of vapors that condense to form emit large quantities of vapors that condense to form PMPM2.52.5 Acids (e.g., sulfuric acid from coal combustion)Acids (e.g., sulfuric acid from coal combustion) Neutralized acids (e.g., [NHNeutralized acids (e.g., [NH44]]22[SO[SO44], NH], NH44Cl )Cl ) Organic materials (e.g., alkanes, PAHs, PCBs, PCDDs, acids)Organic materials (e.g., alkanes, PAHs, PCBs, PCDDs, acids) Metals (e.g., As, Se, Sb, Pb compounds)Metals (e.g., As, Se, Sb, Pb compounds)
A small fraction of point sources are responsible for A small fraction of point sources are responsible for the majority of condensable PM emissionsthe majority of condensable PM emissions
Inventories and PMInventories and PM2.52.5 EmissionsEmissions
Filterable PMFilterable PM Historically only PM included in databasesHistorically only PM included in databases Some States include filterable PMSome States include filterable PM1010 or PM or PM 2.5 2.5
Condensable PMCondensable PM Current knowledge is spotty Current knowledge is spotty Some SIP databases fail to include PMSome SIP databases fail to include PMcond cond
(even when required)(even when required) When PMWhen PMcondcond included - calculated from included - calculated from
emissions factors (e.g., AP-42) that are often emissions factors (e.g., AP-42) that are often based on incorrect test methodsbased on incorrect test methods
Inventories reflect database errorsInventories reflect database errors Federal inventory includes some adjustmentsFederal inventory includes some adjustments Underestimate some sources’ contributions, Underestimate some sources’ contributions,
overestimate othersoverestimate others
Effect on SIP RegulationsEffect on SIP Regulations Most current regulations do not address Most current regulations do not address
PMPMcondcond
Focus on filterable PMFocus on filterable PM Force control technology towards filterable PMForce control technology towards filterable PM
Some regulations do include PMSome regulations do include PMcondcond, but , but with incorrect test methodswith incorrect test methods
Final rule creates a transition periodFinal rule creates a transition period Regulations addressing PMRegulations addressing PMcondcond encouraged but encouraged but
not requirednot required Develop more precise and accurate PMDevelop more precise and accurate PMcondcond
emissions for inventories and rulesemissions for inventories and rules
EPA Method 202(Condensable PM Test Method)(Condensable PM Test Method)
PreferredPreferred NN22 purge purge Evaporation Evaporation
@ 80 F@ 80 F Neutralize Neutralize
quantitativequantitatively by ly by titrationtitration
OptionalOptional No purgeNo purge Evaporation @ Evaporation @
250 F250 F Over Over
neutralize, neutralize, measure measure sulfate, assume sulfate, assume SOSO33
ImpactImpact 10-20X 10-20X
artifactartifact Lose nitrates, Lose nitrates,
chlorideschlorides Sulfate biased Sulfate biased
low, SOlow, SO33 biased highbiased high
Sample collected in cold waterSample collected in cold water Organic PM extracted with solventOrganic PM extracted with solvent Water & solvent evaporatedWater & solvent evaporated Residue weighedResidue weighed ProceduresProcedures
Test Method Selection is Test Method Selection is Important for Measuring Important for Measuring
PMPMcondcond Variations of Method 202 commonly appliedVariations of Method 202 commonly applied Method 202 can be (and often is) conducted Method 202 can be (and often is) conducted
incorrectlyincorrectly Without NWithout N22 purge, dreaded artifacts can form purge, dreaded artifacts can form
(e.g., SO(e.g., SO22 gets trapped in water, reacts with gets trapped in water, reacts with other stuff to form psuedo-PM)other stuff to form psuedo-PM)
Artifacts can be > PMArtifacts can be > PMcondcond by orders of magnitude by orders of magnitude Amount of artifact is source-specific and test-Amount of artifact is source-specific and test-
specific – variable and unpredictablespecific – variable and unpredictable
EPA Activities to Resolve EPA Activities to Resolve PMPMcondcond Test Methods Test Methods
IssuesIssues Recommending use of Method 202 Recommending use of Method 202 with with purgepurge and use of condensable PM and use of condensable PM2.52.5 (see (see http://www.epa.gov/ttn/emc/methods/method202.html)http://www.epa.gov/ttn/emc/methods/method202.html)
Assessing “improvements” to Method 202Assessing “improvements” to Method 202 Apply technologies tested in Canada and USApply technologies tested in Canada and US Reduce artifacts from ~10 mg to >2 mgReduce artifacts from ~10 mg to >2 mg
Revise M202 in Appendix MRevise M202 in Appendix M More precise (no options)More precise (no options) More accurate (reduce artifacts)More accurate (reduce artifacts) Post on EPA/EMC web site in July 2007Post on EPA/EMC web site in July 2007 Propose in 2007/2008Propose in 2007/2008 Promulgate 2008/2009Promulgate 2008/2009
EPA PMEPA PM2.52.5 Transition Period Transition Period ActivitiesActivities
Recommending use of Method 201A Recommending use of Method 201A (existing filterable PM(existing filterable PM1010 test method) with test method) with supplemental hardware for filterable PMsupplemental hardware for filterable PM2.52.5
Revise Method 201A in Appendix MRevise Method 201A in Appendix M Add filterable PMAdd filterable PM2.52.5 measurement measurement Available now on EPA/EMC web site as CTM-040Available now on EPA/EMC web site as CTM-040 Propose 2007/2008Propose 2007/2008 Promulgate 2008/2009Promulgate 2008/2009
Encourage stakeholder testing for Total Encourage stakeholder testing for Total PMPM2.52.5
Other EPA Transition Period Other EPA Transition Period ActivitiesActivities
Advance Dilution Sampling MethodAdvance Dilution Sampling Method Promote ASTM Standard development processPromote ASTM Standard development process Assess speciation capacityAssess speciation capacity Improve consistency mobile source methodsImprove consistency mobile source methods
Document benefits of improved Document benefits of improved monitoringmonitoring
Develop PMDevelop PM2.52.5 CEMS CEMS Develop guidance on understanding Develop guidance on understanding
and applying data uncertaintyand applying data uncertainty
April 2008 SIP expectations States are encouraged to evaluate and States are encouraged to evaluate and
control sources of condensable PMcontrol sources of condensable PM2.52.5 that that may be important in attainment may be important in attainment strategiesstrategies
However, emissions limits (e.g., RACT, However, emissions limits (e.g., RACT, RACM) in 2008 are not required to RACM) in 2008 are not required to include condensable PMinclude condensable PM2.52.5
If want credit for condensable PMIf want credit for condensable PM2.52.5 reductions, must ensure those reductions reductions, must ensure those reductions with enforceable emission limitswith enforceable emission limits
Your Direct PMYour Direct PM2.52.5 SIP SIP ActivitiesActivities
By 2011 - transition periodBy 2011 - transition period Collect information on PMCollect information on PM2.52.5 filterable filterable
and condensableand condensable Include PMInclude PMcondcond at your option at your option
In new rules with appropriate test methodsIn new rules with appropriate test methods As supplemental testing with filterable PMAs supplemental testing with filterable PM
Incremental cost ≈$700Incremental cost ≈$700
Populate emissions factors databasePopulate emissions factors database Use Electronic Reporting Tool to document Use Electronic Reporting Tool to document
emissions tests emissions tests (http://(http://www.epa.gov/ttn/chief/ert/ert_tool.htmlwww.epa.gov/ttn/chief/ert/ert_tool.html ) )
Your Direct PMYour Direct PM2.52.5 SIP SIP ActivitiesActivities
Post 2011Post 2011 Use information obtained during transition Use information obtained during transition
periodperiod Improve direct PMImprove direct PM2.52.5 emissions inventory emissions inventory Revise control strategiesRevise control strategies
Revise or establish new PMRevise or establish new PM2.52.5 limits limits Not necessary to REVISIT old limitsNot necessary to REVISIT old limits Must incorporate condensable PM in Must incorporate condensable PM in NEWNEW limits limits
e.g. SIPs to make mid-course correctionse.g. SIPs to make mid-course corrections SIPs for 2006 PMSIPs for 2006 PM2.52.5 standards standards
Improve monitoring methodsImprove monitoring methods Improve management of short term emissionsImprove management of short term emissions
Start up/shut down/malfunctionStart up/shut down/malfunction Continuous performance assessmentContinuous performance assessment
Important Monitoring Important Monitoring ElementsElements
Indicator of performanceIndicator of performance Emission measurementsEmission measurements Operating parametersOperating parameters Work practiceWork practice Raw material or fuel contentRaw material or fuel content
Monitoring technique Continuous emissions monitorContinuous emissions monitor High Sensitivity PM monitorHigh Sensitivity PM monitor Continuous opacity monitorContinuous opacity monitor Continuous parametric monitoringContinuous parametric monitoring
Monitoring frequency Averaging time
Summary - Direct PMSummary - Direct PM2.52.5 Emissions IssuesEmissions Issues
Both filterable and condensable PMBoth filterable and condensable PM2,52,5 are important components direct PMare important components direct PM2.52.5
Databases must address both for all Databases must address both for all sources to ensure effective control sources to ensure effective control programprogram Target significant sourcesTarget significant sources Establish technologically correct regulationsEstablish technologically correct regulations
Test methods and monitoring must Test methods and monitoring must correspond with emissions limitationscorrespond with emissions limitations You get what you measure You get what you measure