Direct PM2.

5 Emissions Data, Testing, and Monitoring Issues

Ron Myers
myers.ron@epa.gov

Measurement Policy Group SPPD, OAQPS

The Issues

Collecting data needed for effective inventories and SIP development Selecting and prescribing appropriate test methods Improving monitoring in rules Implementing a transition period

Components of Direct PM2.5

Filterable PM2.5

Solid or liquid material at stack temperature and higher (measured at ~250o to 320o F) Stable in atmosphere and collected on ambient sampler
Vapor or gas at stack temperature Condenses to liquid or solid at stack exit Stable in atmosphere and collected on ambient sampler

Condensable PM2.5

Reasons to Consider Condensable PM2.5 Emissions

Condensable fraction of direct PM2.5 can be significant

10 to 50 percent of PM2.5 emissions depending on control measures, temperature, other source-specific conditions

Combustion, metallurgical & wood product sources emit large quantities of vapors that condense to form PM2.5

Acids (e.g., sulfuric acid from coal combustion) Neutralized acids (e.g., [NH4]2[SO4], NH4Cl ) Organic materials (e.g., alkanes, PAHs, PCBs, PCDDs, acids) Metals (e.g., As, Se, Sb, Pb compounds)

A small fraction of point sources are responsible for the majority of condensable PM emissions

Inventories and PM2.5 Emissions

Filterable PM

Condensable PM

Historically only PM included in databases Some States include filterable PM10 or PM 2.5 Current knowledge is spotty Some SIP databases fail to include PMcond (even when required) When PMcond included - calculated from emissions factors (e.g., AP-42) that are often based on incorrect test methods Federal inventory includes some adjustments Underestimate some sources contributions, overestimate others

Inventories reflect database errors

Effect on SIP Regulations

Most current regulations do not address PMcond

Focus on filterable PM Force control technology towards filterable PM

Some regulations do include PMcond, but with incorrect test methods Final rule creates a transition period
Regulations addressing PMcond encouraged but not required Develop more precise and accurate PMcond emissions for inventories and rules

EPA Method 202

(Condensable PM Test Method)

Sample collected in cold water Organic PM extracted with solvent Water & solvent evaporated Residue weighed Procedures Preferred Optional

Impact

N2 purge Evaporation @ 80 F Neutralize quantitatively by titration

No purge Evaporation @ 250 F Over neutralize, measure sulfate, assume SO3

10-20X artifact Lose nitrates, chlorides Sulfate biased low, SO3 biased high

Test Method Selection is Important for Measuring PMcond

Variations of Method 202 commonly applied Method 202 can be (and often is) conducted incorrectly
Without N2 purge, dreaded artifacts can form (e.g., SO2 gets trapped in water, reacts with other stuff to form psuedo-PM) Artifacts can be > PMcond by orders of magnitude Amount of artifact is source-specific and testspecific variable and unpredictable

EPA Activities to Resolve PMcond Test Methods Issues

Recommending use of Method 202 with purge and use of condensable PM2.5 (see
http://www.epa.gov/ttn/emc/methods/method202.html)

Assessing improvements to Method 202 Apply technologies tested in Canada and US Reduce artifacts from ~10 mg to >2 mg

Revise M202 in Appendix M

More precise (no options) More accurate (reduce artifacts) Post on EPA/EMC web site in July 2007 Propose in 2007/2008 Promulgate 2008/2009

EPA PM2.5 Transition Period Activities

Recommending use of Method 201A (existing filterable PM10 test method) with supplemental hardware for filterable PM2.5 Revise Method 201A in Appendix M
Add filterable PM2.5 measurement Available now on EPA/EMC web site as CTM-040 Propose 2007/2008 Promulgate 2008/2009

Encourage stakeholder testing for Total PM2.5

Other EPA Transition Period Activities

Advance Dilution Sampling Method

Promote ASTM Standard development process Assess speciation capacity Improve consistency mobile source methods

Document benefits of improved monitoring Develop PM2.5 CEMS Develop guidance on understanding and applying data uncertainty

April 2008 SIP expectations

States are encouraged to evaluate and control sources of condensable PM2.5 that may be important in attainment strategies However, emissions limits (e.g., RACT, RACM) in 2008 are not required to include condensable PM2.5 If want credit for condensable PM2.5 reductions, must ensure those reductions with enforceable emission limits

Your Direct PM2.5 SIP Activities

By 2011 - transition period

Collect information on PM2.5 filterable and condensable Include PMcond at your option

In new rules with appropriate test methods As supplemental testing with filterable PM

Incremental cost $700

Populate emissions factors database

Use Electronic Reporting Tool to document emissions tests (http://www.epa.gov/ttn/chief/ert/ert_tool.html )

Your Direct PM2.5 SIP Activities

Post 2011
Use information obtained during transition period

Improve direct PM2.5 emissions inventory Revise control strategies

Revise or establish new PM2.5 limits

Not necessary to REVISIT old limits Must incorporate condensable PM in NEW limits
e.g. SIPs to make mid-course corrections SIPs for 2006 PM2.5 standards

Improve monitoring methods Improve management of short term emissions

Start up/shut down/malfunction Continuous performance assessment

Important Monitoring Elements

Indicator of performance

Emission measurements Operating parameters Work practice Raw material or fuel content Continuous emissions monitor High Sensitivity PM monitor Continuous opacity monitor Continuous parametric monitoring

Monitoring technique

Monitoring frequency Averaging time

Summary - Direct PM2.5 Emissions Issues

Both filterable and condensable PM2,5 are important components direct PM2.5 Databases must address both for all sources to ensure effective control program
Target significant sources Establish technologically correct regulations

Test methods and monitoring must correspond with emissions limitations

You get what you measure