Feature Report
THE MATURATION OF A TECHNOLOGY:
Predictive
Emissions
Monitoring
To be successful,innovative environmental technology and regulations
must evolve together. This technology’s success is based on
its effectiveness and its cost advantages
Paul S. Reinermann, III, Pavilion Technologies, Inc.
A
ir pollution is monitored by
many different regulatory
programs, some of which
require that emissions be
measured continuously. This
task is often accomplished
by directly measuring air pollutants
with continuous emissions monitor-
ing systems (CEMS). In recent years,
innovative technology has enabled a
new approach that predicts emissions
from process variables. Industry wel-
comes predictive emission monitoring
systems (PEMS) because they reduce
emissions-monitoring costs. Regula-
tory agencies are accepting these new
systems, as proof of their accuracy and
reliability is demonstrated.
The onset of PEMS was in 1992,
when a chemical engineer used neural-
networks (Figure 1), a pattern-learn-
ing technology, to accurately predict
nitrogen oxides (NOx) emissions from
a natural-gas-fired boiler. This model
worked like no other first-principles
model or regression model previously
built — it was accurate over the entire
operating range of the boiler, whereas
the other models were accurate only
in specific operations. Within a year,
the neural-network-based NOx model
evolved into the first PEMS that was ap-
proved by the U.S. Environmental Pro-
tection Agency (EPA) as an alternative
to direct CEMS measurements. This
first PEMS was proven to be as ac-
50 CHEMICAL ENGINEERING WWW.CHE.COM JULY 2006
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to predict emissions from process-sensor-input data
curate as the hardware-based CEMS
over the entire range of operation, and
to cost 50% less.
Since then, 250 PEMS have been in-
stalled worldwide. The effectiveness of
PEMS has been proven in many types
of process units, combustion configu-
rations and fuel types (see box, p. 51).
PEMS AND REGULATIONS
PEMS can only predict certain pollut-
ants. The most prevalent pollutants
predicted are nitrogen oxides, followed
by carbon monoxide (CO). Regulations
generally require that emissions be
normalized to a common oxygen (O2)
or carbon dioxide (CO2) basis. For ex-
ample, measurements of NOx in parts-
per-million (ppm) may be normalized
to percentage of O2. By far, the usage
of O2 is more customary than CO2.
Pollutants such as sulfur dioxide
(SO2) or specific organic compounds are
related to the sulfur content in fuels or
the level of the organics in a material.
The prediction of these pollutants is
done by mass-balance calculations and
is not considered by regulatory author-
ities to be part of a PEMS.
Regulations
PEMS are more compatible with some
regulatory programs than with others.
Practical PEMS requirements have
been established for emission units
that are subject to EPA’s 40 CFR Part
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FIGURE 1. Neural
networks learn patterns
60 (New Source Performance Stan-
dards), whereas more cumbersome
and less favorable PEMS require-
ments have been established for emis-
sion units that are subject to 40 CFR
Part 75 (Acid Rain Program — Utility
Boilers and Turbines). The main dif-
ference between these two regulations
lies in the initial certification require-
ments — a one- to three-day test under
Part 60 and a 30-day test under Part
75. Note that the quality and the ac-
curacy of the PEMS are not enhanced
because of the increased certification-
test duration.
Most state agencies and non-U.S.
agencies have adopted the Part 60
PEMS requirements published by
EPA in January 1996. The Part 75
PEMS requirements were viewed as
impractical by the Texas Environ-
mental Quality Council. Hundreds of
PEMS have been established under
Part 60 PEMS requirements whereas
less than ten PEMS have been estab-
lished under Part 75. The main reason
for the difference is that PEMS under
Part 60 cost significantly less than
under Part 75, primarily due to the
cost of certifying the PEMS.
Regulatory acceptance
In the U.S., in order for the EPA to
accept PEMS, the agency required as-
surance of the quality and reliability
of PEMS’ outputs over a long term.
 TABLE 1. GENERAL INFORMATION
NEEDED FOR PEMS FEASIBILITY
EVALUATION
������������������ Contact In- Operations
����������� formation Environmental
Information technology (IT)
Type of Boiler
Emission Turbine
Unit Process heater
Combination
Other
��������������
Burners Number of burners
Air register and other burner
controls
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������������ �������� Types and Natural gas
��������� Ratios of No. 2 fuel oil
Fuels Refinery or process gas
FIGURE 2. Execution of the DOE creates the dataset that is needed for Coal
building the PEMS emissions and sensor-validation system models Wood waste
Process Fuel flow
Sensors Fuel quality
PROVEN PEMS APPLICATIONS Available Air flow
Process Units: Turbines with duct burners, other turbines, engines, boilers, Temperatures
olefin furnaces, crude oil heaters, styrene superheaters, methanol reformers System In- DCS and data historian
Configurations: Single burner, multiple burners, low NOx and dry, low tegration
NOx burners, flue gas recirculation (FGR), steam injection Pollutants NOx, O2, CO, CO2, SO2, Particu-
and Regu- lates
Fuels: Natural gas, No. 2 fuel oil, other fuel oils, refinery gas, hydrogen-rich
lations US EPA 40 CFR Part 60 or Part 75
fuels, varying but measured gaseous-fuel quality, waste wood EU NEN-14181
Permit Requirements

Initially, the EPA used the CEMS
quality-assurance requirements as a
template. For the most part, however,
fitting PEMS into CEMS require-
ments is like putting a square peg into
a round hole. As a better fit, two key
PEMS technologies were created:
1) A realtime sensor validation system
that evaluates all sensors which input
into the PEMS (this is discussed in
more detail later)
2) The daily electronic data assess-
ment tests of the PEMS, where a
known set of values is put into the sys-
tem to verify the PEMS accuracy
PEMS PROJECT EXECUTION
The decision to use a PEMS is based
on two factors: technical feasibility
and cost effectiveness. The technical
viability of a PEMS for a particular
application should be assessed be-
fore economics are even considered.
Once the technical aspects have been
confirmed, regulatory issues must be
evaluated. In some states, EPA re-
gions, and regions of the world, PEMS
have not been introduced. And despite
their technical soundness, PEMS have
not been accepted in some locations.
Experienced PEMS vendors will be
able to guide you in achieving techni-
cal sense and regulatory acceptance.
Step 1. Analyzing viability
To check technical feasibility, the emis-
sion source (also called the emission
unit in EPA terms) must be evaluated.
A general checklist of information that
makes up such an evaluation is given
in Table 1.
Contact information. Operations
personnel know the emission unit,
the burners, the fuels, and the avail-
able sensors. They do not necessarily
understand the nuances of the envi-
ronmental regulations nor the system
integration issues, so contacts who are
experienced in both environmental
and information technology (IT) are
also necessary. For these key people,
their names, phone numbers and
email addresses should be obtained
and made readily available.
Details on the emission unit. In-
formation about the emission unit,
including the number and type of
burners, fuel types and ratios, and
available process sensors is needed
and can usually be obtained from
the operations group. The simplicity
or complexity of the emission unit is
a function of the number of different
configurations of burners and fuels.
The simpler the emission unit, the less
time is needed to gather data to build,
validate and certify the PEMS. For ex-
ample, a natural-gas-fired boiler with
a single burner requires three days for
data gathering, one day for validation
and one day for certification. If the
same boiler instead fires both natural
CHEMICAL ENGINEERING WWW.CHE.COM JULY 2006
gas and oil, either alone or in combina-
tion (effectively three fuel types that
produce different level of pollutants),
then nine days are required for data
gathering, two for validation and two
for certification. Also, the time that is
needed to build the model doubles.
Another critical step is ensure that
needed process sensors are available.
In general, most classical instrumen-
tation packages for boilers, turbines,
and process heaters contain sufficient
sensors to support the PEMS. For
process or refinery gases, fuel quality
monitors need to be present because
fluctuations in fuel quality affect pol-
lutant levels. The presence of the nec-
essary process-sensor data in the dis-
tributed control system (DCS) or data
historian also needs to be confirmed.
System integration. The PEMS soft-
ware must be able to access the pro-
cess-sensor data from either the DCS
or data historian. For optimum per-
formance, design your system to read
process sensor data from the DCS and
have the PEMS write values back to
the DCS, using information that the
PEMS obtained from the DCS by the
data historian. This design takes ad-
vantage of the store-and-forward ca-
pability of most DCSs and provides a
backup of PEMS data in case of DCS/
data-historian communication down-
time. Regulatory agencies expect con-
tinuous monitoring systems to have
51

Feature Report
data availability for 95% of the oper-
ating time. Proper system integration
eliminates most known PEMS down-
time.
Remote access to the PEMS for
periodic or requested evaluation is
a must to reduce response time and
the overall cost of PEMS ownership.
The most effective link is by Virtual
Private Network (VPN). System secu-
rity comes into play when considering
remote access. The views and proce-
dures on remote access vary by com-
pany and change with time as person-
nel, products and perceptions change.
The location of the PEMS server, with
reference to the firewall, can make a
difference in allowing remote access. If
located outside the firewall, generally
remote access can be granted, while if
located inside the firewall, remote ac-
cess may not be possible.
Step 2. Experimental design
According to six-sigma methodology, a
design of experiments (DOE; Figure 2)
is a structured, organized method for
determining the relationship between
factors (X) affecting a process and the
outputs of that process (Y). In the case
of PEMS, the DOE is key to creating a
dataset that reflects the relationships
between process operating conditions
(X) and pollutants being emitted (Y).
The overall accuracy and robustness
of the PEMS is predicated on the ex-
ecution of the DOE.
Pushing the operating window.
A properly designed DOE will push
the operating window of the emission
unit. The design needs to be created
by an expert PEMS engineer and re-
viewed by operations for process con-
formity and safety. While an emission
unit may be capable of a wide operat-
ing range in many instances, the ac-
tual operating range is constrained in
practice. For example, a boiler may be
able to operate in the range of 25 to
100% of rated capacity, but in reality
only operates between 75 to 100%.
Ensuring good data quality. Prior
to conducting the DOE, all process sen-
sors should be in good working order.
Calibration of the process instruments
is desirable but not necessary. Repeat-
ability of the process instruments is
more important than the accuracy of
the process sensors.
52 CHEMICAL ENGINEERING WWW.CHE.COM JULY 2006
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FIGURE 3. This preliminary evaluation FIGURE 4. Another step in evaluating
of a PEMS shows a good r-correlation a PEMS is to check if the predictions are
within ± 7.5% of actual values
At this stage of the
project, accuracy of the �����
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emissions data is more ��������������������
important than that of ��������������
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the process sensors. For ���������������
instance, a good and ad- ����������������
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equate sampling location ���������������������
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on the stack is necessary
to obtain representative
samples that are not com- ����
promised by possible pol-
lution stratification in the
stack. Adherence to EPA ����
reference test methods ����
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for gathering the emis-
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sions data ensures good
emissions-data quality. In
practice, utilizing dual (re- FIGURE 5. This neural-network PEMS has learned
dundant) EPA reference the correct gains without the use of additional soft-
ware functions
test methods guarantees
highly accurate emissions
data and helps avoid having to repeat through the experimental design. If
portions of the DOE if one reference any planned experiments are missed,
test method fails. they will need to be made up, which
will increase costs. The PEMS engi-
Step 3. Executing the DOE neer or operations superintendent
The coordination of the DOE with should work with each operating shift
plant operations is key to minimizing to explain the DOE and the ramifica-
any economic impact that could arise tions of not following it.
from varied operations of the emission Emissions data sources. When
unit. For example, when executing the replacing a hardware CEMS with
DOE to create a PEMS on a boiler, if a PEMS, a reliable source of data
the facility has more than one steam is needed. If the CEMS data are of
source, then the other steam source questionable quality, it is advised to
should be allowed to “swing” to en- not use them. If CEMS data are to be
sure that enough steam is provided to used, ensure that the CEMS has been
the facility and no fuel is wasted. At shown to meet accuracy requirements
a petroleum refinery, the effect of the of within 7.5% relative accuracy im-
crude oil slates and the ability to han- mediately before the DOE. It is rec-
dle downstream disturbances of the ommended that consideration also be
products from the crude heater need given to having the EPA reference test
to be considered. method operational during the DOE,
Waiting for the right window of op- in order to supplement and confirm
portunity to execute the DOE is para- the CEMS data.
mount to containing costs. Execution In practice, most PEMS are created
of the DOE is a 24-hour-per-day exer- for emission units that do not have
cise. All operating shifts need to be in CEMS installed. In such cases, firms
tune with moving the emission unit specializing in stack testing using in-
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�������������������� tween combined process parameters and emissions
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operations with suffi-
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cient accuracy.
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Periodic DOE re- pollutant and to add sensors until the
view. After the first accuracy becomes sufficient.
day of experiments, Evaluating offline accuracy. An
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����� the PEMS engineer offline evaluation of the PEMS is per-
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should evaluate ex- formed throughout the PEMS model-
� � ��� ecution of the DOE. building exercise. Two criteria for ac-
The engineer should curacy are used: 1) an r-correlation
access and combine analysis of the PEMS predictions to
FIGURE 6. For a complex system, software functions the process data and the reference-test-method; and 2) the
can force the neural network to learn the observed gains. sensor data to ensure overall accuracy of the PEMS predic-
In this case, the top graph shows incorrect learning that is
corrected on the bottom that the DOE is being tions in comparison to the findings of
followed, that process the actual reference-test-method.
strumental EPA reference test meth- data and emissions data are being col- The r-correlation coefficient is a
ods must be hired. As mentioned lected properly, and that the emission number that is a measure of the
earlier, dual instrumental EPA-refer- unit is behaving as expected. strength and direction of the correla-
ence-test methods should be utilized In some cases, adjustments to the tion between two variables, which in
to guarantee accurate pollutant data. DOE will be made. For example, if a this case is between the results from
The stack-testing firm needs to en- certain change in operation had no the PEMS and the EPA reference test
sure that the emission analyzers are effect on emissions, then it does not method. The closer r is to 1, the stron-
kept in a climate-controlled environ- need to be repeated later, and time ger and more positive the relation-
ment and are properly calibrated. and money can be saved. In most ship. The r-correlation coefficient for a
Warm-up of the analyzers and stabil- cases, however, the DOE proceeds as PEMS must be higher than 0.8.
ity of the testing-trailer environment scheduled with daily evaluation of its The r-correlation analysis does,
are needed. While the equipment can execution and performance. however, have some statistical limi-
be installed and producing numbers tations. For one thing, the dataset
within one hour, approximately four to Step 4. Building the model is invalid for r-correlation analysis if
eight hours are necessary to achieve Engineers with expertise in this area auto-correlation is present, or if the
stable, repeatable and accurate read- should be employed to build PEMS signal-to-noise ratio of the data from
ings. At a minimum, initial three-point models. The selection of the right the reference test method is too high.
calibrations and twice daily calibra- input sensors for the PEMS is criti- Also, there is a special limitation if the
tions should be performed. cal. Originally, neural-network PEMS emissions data do not change signifi-
Process data source. The facility’s were built following the “kitchen soup” cantly while a key input parameter
data historian is the source for process approach — all available process sen- (generally fuel flow) is varied: in this
data. Data historians can be set up to sors were initially used and then pro- situation, there is simply not enough
compress the data or ignore the data cess sensors were eliminated until a movement for the r-correlation test to
if sensor readings do not vary signifi- good mix of sensors and PEMS accu- have a meaningful result. When this
cantly. These features must be turned racy was achieved. This worked well, lack of change occurs, agencies will
off during the DOE because otherwise, but resulted in PEMS that used ten waive the r-correlation test require-
the process data will not reflect actual or more process sensors. The current ment. Figure 3 depicts a good r-corre-
CHEMICAL ENGINEERING WWW.CHE.COM JULY 2006 53
 Feature Report
lation for PEMS predictions to refer-
ence-test-method results.
The second check is designed to en-
sure that the accuracy of the PEMS
emission model, as required by regula-
tions, will be achieved. The actual test
reference margin of ±7.5% is plotted in
comparison to the actual PEMS pre-
dictions. The predictions should fall
within this range for at least 90% of all
data points to ensure that the PEMS
will meet the relative-accuracy require-
ments of 10% of the emission standard
or 20% of the actual emission value.
Figure 4 depicts a comparison between
the actual test reference margin of
±7.5% to the actual PEMS predictions.
Good predictions versus good mod-
els. While good predictions are impor-
tant, of greater importance are good
models that combine accuracy with
model behavior. A model’s behavior
is judged by evaluating the combined
effect of individual sensor gains with
process-sensor interactions on emis-
sion predictions. If the emissions
model reflects the gains correctly, then
the emissions model will be robust
and effective when in operation over
the long term.
During the development of PEMS
emission- and sensor-validation mod-
els, the engineer must determine if
the neural network has learned the
correct gains. If the neural network
has not, then the engineer can use one
or more modeling techniques and soft-
ware functions to influence the learn-
ing of the neural network.
Figure 5 illustrates the gains for a
NOx-emissions model on a natural-
gas-fired turbine with steam injection.
This neural-network PEMS learned
the correct gains without the use of
other software functions.
Figure 6 shows wrong neural-net-
work learning (top) as compared to
correct neural-network learning (bot-
tom) for NOx-emissions models that
were built from the dataset for a coal-
fired boiler. While the output data for
both NOx emissions models were sat-
isfactory, the neural-network model
on the bottom graph reflects the gains
observed and will give performance
superior to that of the model on the
top, both initially and long term. For
a complex system, such as this coal-
fired boiler, software functions are
54 CHEMICAL ENGINEERING WWW.CHE.COM JULY 2006
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necessary to force the neural network
to learn the observed gains.
Another evaluation of model behav-
ior is to ascertain the relationship be-
tween combined process sensors and
emissions, especially two key process
sensors. This can be done with a three-
dimensional (3-D) plot as shown in Fig-
ure 7. This graph represents the effects
of fuel flow and steam-injection rate
upon NOx emissions from a turbine.
As expected, the highest fuel flow com-
bined with the lowest steam-injection
rate results in the highest NOx emis-
sions. Alternately, the lowest fuel flow-
rate combined with the highest steam-
injection rate results in the lowest NOx
emission rate.
Step 5. Sensor validation
The dataset used to create the emis-
sions model is also used to create
models of each sensor as a function of
the other process sensors. These sen-
sor models are combined with other
software to form the sensor validation
system of the PEMS.
When developing the sensor mod-
els, the redundancies of instrumen-
tation and the relationships between
certain sensors should be considered.
More process sensors are used by the
sensor-validation system than by the
emissions model because redundant
information, which is required for the
emissions model, is not necessary for
the system. All sensor inputs into the
PEMS are evaluated by the sensor-
validation system, not just the sensors
used in the emissions model.
Combustion units monitor several
temperature zones or points. For a
boiler, the firebox, economizer inlet,
economizer outlet and stack tempera-
tures are usually monitored. These
temperatures are closely correlated.
FIGURE 8. An installed
PEMS generally resides on
a server and communicates
directly with the DCS and/
or data historian
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If the firebox temperature is used in
the emissions model, then one or more
of the other temperatures are used by
the sensor-validation model for the
firebox temperature. The validation
model for the firebox-temperature
sensor will also include other process
sensors, such as fuel flow, as deter-
mined by the engineer.
To develop appropriate sensor-vali-
dation models, the engineer utilizes
the model-building and model-analy-
sis techniques, as well as software
functions that were used to develop
the emissions model. While the devel-
opment of the emissions model can be
rather straightforward, the develop-
ment of the sensor-validation models
can be complicated because the rela-
tionships may not be well-understood.
Once sensor validation is modeled,
the engineer needs to determine the
sensitivity or tolerance of the differ-
ences between the predicted sensor
output and the observed sensor out-
put that will label a value as suspect
and therefore not useable in the emis-
sions model. The tolerances are read-
ily selected by an experienced PEMS
engineer. In some cases, such as in re-
sponse to similar and numerous false-
sensor validation-system alarms, the
tolerances are adjusted after installa-
tion of the PEMS.
When a sensor’s input to the emis-
sions model is suspect, then the sen-
sor-validation system will generate
a reconciled value for the emissions
model. For example, if a boiler is firing
fuel at rated capacity and the process
O2 value is 21%, then the process O2
meter is either in calibration or read-
ing ambient air. When this occurs, the
sensor-validation system will provide
a reconciled sensor value to be used in
the model.
 GENERAL REGULATORY ��������������� �������������� ���������������
REQUIREMENTS FOR PEMS ��������� ���������� ����������
�������� �������������
Submit PEMS Plan Ongoing PEMS ����������
�������
• Technical feasibility Quality Assurance ����

• Operating range of PEMS Requirements ������� ��������

��������
• Annual �������
Initial PEMS Certification comparison test
Requirements • Quarterly or �������
• Comparison test against more frequent �������
reference-test methods PEMS electronic
- EPA methods 3A, data assessment �������
7E, and 10 • Minute-by-minute �
- Test at three operating operation of � � � � � � � � � �� ��
conditions sensor-validation �����
• Sensor-validation system
system evaluation FIGURE 9. PEMS make good economic sense in comparison
to CEMS. Here total cost of ownership (TCO) is compared

The ability of the sensor-validation
system to reconcile sensor values and
maintain good PEMS accuracy must
be evaluated. The EPA expects the fol-
lowing offline evaluation:
1. Determine the overall accuracy of
the PEMS for the dataset that was
used to create the PEMS. Express
this in terms of relative accuracy as
defined in 40 CFR Part 60, Appendix
B, Performance Specification 2
2. Artificially fail the most important
sensor used to predict emissions.
This can be done by analysis of
the relationship between process
sensors and emissions. Using the
reconciled values generated by the
sensor-validation system, assess the
effect on the accuracy of the PEMS
over the entire dataset. If relative
accuracy is less than 10%, then one
failed sensor can be tolerated
3. Retain the first artificially failed
sensor. Artificially fail the next most
important sensor and evaluate the
effect on the relative accuracy of the
PEMS. If relative accuracy is less
than 10%, then two failed sensors
can be tolerated
4. Repeat this procedure for the next
most important sensor until relative
accuracy is greater than 10%
Step 6. PEMS integration
Once the sensor-validation system
and emissions model are created, the
PEMS online software can be inte-
grated with the DCS and data his-
torian. At this point, the electronic-
data-assessment test is set up. This
test works by passing known sensor
inputs through the PEMS, gener-
ating outputs and then comparing
these outputs to the known outputs.
The electronic-data-assessment test
ensures that the PEMS models have
not been corrupted or replaced.
By this time, the PEMS personal
computer (PC) has been installed, and
communications with the DCS and/or
data historian has been tested by the
plant’s IT department and the soft-
ware vendor’s system-integration spe-
cialist. Once the output tags from the
PEMS have been created in the DCS
and/or data historian, then the PEMS
can be installed and placed online
(Figure 8).
Step 7. Certification and
documentation
Once the PEMS is online, the stack-
testing firm is brought back to vali-
date the PEMS and then certify the
PEMS as required by the EPA or other
applicable regulatory agency. A report
of the certification test results is sub-
mitted to the authorities and a PEMS
site guide is issued to assist in the un-
derstanding of the PEMS.
Requirements for PEMS have been
established worldwide (see box). While
the format of the documents, the length
and breadth of the certification tests
and the timing of the submittals and
tests vary, regulatory agencies have
the same, basic expectations of PEMS
performance and documentation.
THE FUTURE OF PEMS
PEMS are getting better over time
and continue to out perform regula-
tory requirements. The EPA recently
evaluated initial and long-term PEMS
performance by analyzing relative-ac-
curacy-test audit results. The PEMS
passed all audits and the relative
accuracy of the PEMS improved sig-
nificantly from the initial certification
tests to the ongoing certification tests.
In comparison to the requirement of
less than 20% relative accuracy, the
initial relative accuracy for over 130–
NOx PEMS was 6.4%, and the ongo-
ing relative accuracy was 3.2% — an
improvement of 50%. The main reason
for the improvement was the ability
to tune the models by augmenting the
original dataset with new data.
PEMS continue to make good eco-
nomic sense in comparison to CEMS.
Actual costs for NOx PEMS were com-
pared to CEMS for a natural-gas-fired
boiler in the EPA’s “CEMS Cost Model,
Version 3.” The total cost of ownership
(TCO) is shown to be substantially
less for the PEMS than for the CEMS
(see Figure 9).
The neural-network based idea of
the chemical engineer in 1992 was the
birth of a technology now recognized
around the world. The relatively rapid
acceptance of PEMS can be attributed
to cost advantages found by industry
and the accuracy that satisfies regula-
tors. Both are impressed by the reli-
ability that these systems can offer. ■
Edited by Dorothy Lozowski
Author
Paul Reinermann is director
of environmental and regula-
tory affairs at Pavilion Tech-
nologies, Inc. (10415 Morado
Circle, Austin, Texas 78759;
Phone 512-438-1575; Email
preinermann@pavtech.com).
At Pavilion, he assists in the
sales, marketing, business de-
velopment and project execu-
tion associated with Pavilion’s
environmental product suite,
consisting of Pavilion’s PEMS and Real-time En-
vironmental Management application. He holds
a B.S. deegree in chemical engineering from the
University of Cincinnati (1982) and has worked
exclusively in the field of air emissions testing,
monitoring, compliance and enforcement since
graduation. Paul has been with Pavilion for over
11 years. Prior to Pavilion, he worked as an en-
vironmental consultant performing air emissions
studies, as EPA’s Chief of the Air Compliance
Monitoring Section enforcing air-pollution-control
permits and rules, and as an environmental spe-
cialist for an owner of independent power plants,
overseeing a myriad of permitting and compliance
activities.

CHEMICAL ENGINEERING WWW.CHE.COM JULY 2006 55