CHAPTER 2 CEM REGULATIONS

      Environmental control agencies have been the driving force for the installation of continuous emission monitoring systems. The emergence of CEM regulation in the 1970s brought a new perspective to emissions monitoring by requiring a wide range of sources to install systems and by requiring the installed systems to meet specified levels of performance. Although instrumentation had been applied in the 1960s to monitor product loss in the process industries, it was not until environmental control agencies began implementing pollutant monitoring rules that the CEM industry began to develop. This development began almost simultaneously in the United States and the Federal Republic of Germany (FRG). Monitoring requirements have since extended throughout the European Union (EU), to Canada, Latin America, the Middle East, and Asia.

      National environmental regulatory programs have been initiated to protect the health and welfare of their citizens. Ultimately, regulatory agencies establish limits for pollutant emissions from stationary, mobile, and area sources. This book addresses emissions from stationary sources, i.e., emissions from “smoke stacks.” By measuring the amount of pollutants emitted from stationary sources, assessments can be made as to their contribution to environmental problems. The data that they generate can also serve as a basis for future emission control regulations. Once in place, continuous emission monitoring systems provide a means of keeping score. Although measurements can be made manually and periodically as they were before the 1970s, continuous emission monitoring provides an ongoing record of how well emissions are being controlled and a means of determining at any time, the compliance status of an emissions source with its emission agency‐specified emission limits.

      To be used effectively in any environmental program, CEM data must be representative, accurate, precise, and credible. In this regard, calibration, performance testing, certification testing, and periodic auditing are essential in maintaining credibility. An environmental agency monitoring strategy cannot be successful without including these elements.

      Continuous monitoring requirements were first promulgated for fossil‐fuel‐fired steam generators in the United States in December 1971. In 1974, Germany passed the Federal Immission Control Act, which incorporated continuous monitoring requirements. Also, in 1974, pollutant emission limits and further monitoring requirements were published as “Technical Instructions on Air Quality Control” (TA‐Luft) in the Federal Republic of Germany. However, intensive monitor development did not begin until 1975 when the U.S. EPA published “performance specification procedures” for continuous emission monitors, and the German Federal Ministry of the Interior (BMI) published its corresponding “suitability testing guidelines.”

Since then, CEM regulations have expanded, affecting a wider range of sources and requiring a wider range of pollutants to be monitored. The basic CEM program elements established in the 1970s underlie most of the current regulations. The foundation of any regulatory continuous monitoring program incorporates three basic elements: (i) implementing rules, (ii) performance specifications, and (iii) quality assurance requirements. These three elements provide the necessary support for the application of CEM technology (Figure 2‐1).

When placed on uneven surfaces of a wide range of industrial applications, agency regulatory policies must be robust enough to enable CEM systems to produce accurate data. Continuing this analogy, when taking a photograph, a tripod serves to provide a stable base for a camera; the sharpness of the picture depends on the quality of the tripod as well as the quality of the camera. In the same sense, the quality of the data produced by a CEM system is dependent on both the system and the elements that support it.