Direct PMDirect PM2.52.5 Emissions Data, Emissions Data,

Testing, and Testing, and Monitoring IssuesMonitoring Issues

Ron MyersRon Myersmyers.ron@epa.govmyers.ron@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