Continuous Emission Monitoring. James A. Jahnke
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for PM, SO2, and NOx emissions from incinerators were established in 2007 and 2013 (MMA 2013b)
Chile has applied a continuous monitoring protocol since 2011, which is based on U.S. Part 60 and Part 75 requirements and developed in collaboration with the U.S. EPA as part of the U.S.–Chile Environmental Cooperation Agreement (Chile 2003). Similar to the U.S. requirements, performance tests such as daily calibration verifications using certified gases, cylinder gas audits, and relative accuracy test audits are required for certification and after the systems are installed. This protocol was officially approved by the Superintendencia del Medio Ambiente (SMA) of the Government of Chile in 2019 (SMA 2019). For particulate matter monitoring systems, the correlation procedures of 40 CFR 60 Appendix B PS11 are followed. There are currently between 300 and 400 validated CEM systems in Chile (Montoya 2020).
Peru
In Peru, the Ministry of the Environment (Ministerio del Ambiente – MINAM) requires the installation of CEM systems for thermoelectric plants (MINAM 2014, 2020) and cement and lime manufacturing plants (MINAM 2016) for the measurement of particulate matter, SO2, and NOx concentrations. Although a standard for copper smelters has not been published, CEM systems are installed in these plants. CEM system requirements are expected to expand to other industrial sectors in the future (Montoya 2020).
A CEM protocol (Protocolo Nacional de Sistemas de Monitoreo Continuo de Emisiones CEMS), based on the U.S. Part 60/75 requirements and similar to the protocol of Chile, was approved in 2016 (MINAM 2016).
Brazil
In Brazil, the national regulatory body responsible for setting emission limits and monitoring requirements is Conselho Nacional do Meio Ambiente (CONAMA). National emission limits were established for stationary sources in Resolution 382 (CONAMA 2006), complemented by Resolution 386 (CONAMA 2011). According to Resolution 382, Article 5, monitoring is considered continuous when the pollution source is monitored at least 67% of the operational time during a one‐year period. A valid day emission rate must have monitoring data for at least 75% of the day’s operational time.
There are no national protocols for CEM system certification or quality assurance. These are set instead by state licensing agencies (see Annex 6 Resolution 386). Accordingly, CEM validation and quality assurance vary between the states. As examples, the federal states of São Pablo and Rio de Janeiro require CEM systems for waste incineration plants and for larger combustion sources. In the federal state of São Palo, where CEM system installations are the most prevalent. A validation standard based on on the European standard EN14181 has been applied. (Environmental‐Expert 2020). Companhia Ambiental do Estado de São Palo (CETSB) is the regulatory body for source emissions in Sao Paulo.
Argentina
In Argentina, thermoelectric plants have been required to monitor particulate matter, NOx, SO2, and O2 since 2001 (Argentina Ambiental 2001, 2002). A national CEM protocol, based on the U.S. EPA Part 60/75 requirements, was published in 2012 (ENRE 2012).
Colombia
Regulations requiring CEMS for monitoring PM, SO2, NOx, CO, HCl, HF, and THC were established in 2008 for various industrial sectors, including waste incineration plants, cement kilns that burn hazardous wastes (Ministerio del Ambiente Minambiente 2008). No protocol for CEM system validation or quality assurance has been published to support the monitoring requirements.
Ecuador
A regulation was implemented in 2019 for the installation of CEM systems in cement plants and thermoelectric plants for monitoring PM, SO2, and NOx (Ministerio del Ambiente y Agua 2015). No protocol for CEM system validation or quality assurance have been published to support the monitoring requirements.
Developing a National Continuous Emission Monitoring Program
One would expect that because it has been over fifty years since the proposal of CEM systems for monitoring industrial emissions in North America and Europe, the accumulated knowledge on monitoring systems could be readily adapted to developing CEM programs in other countries. Unfortunately, all too often, the implementing rules come first and the certification and quality assurance criteria are either left ambiguous or are to be developed later. Figure 2‐1 emphasizes in all clarity that if the benefits from CEM technology are to be realized, the technology must be supported by clear implementing rules, accreditation/certification standards, and implemented quality assurance procedures. Failure to incorporate any of these three elements can make installed systems eventually fail to work or produce corrupted data lacking credibility. However, even if the three elements are extant, the enforcement of the rules (the subject of the next section) has been found necessary if CEM data are to be credible.
The CEM rules, protocols, and guidance documents developed in the past 50 years by the United States, Canada, and Europe can be used as resources for those environmental control agencies setting up their own monitoring programs, Also, standards and specifications available from ASTM International, the International Standards Organization (ISO), and the European Union (EU) Committee for Standardization (CEN) can be easily referenced without having to repeat the lengthy standardization processes that led to their publication. A number of CEM guidance manuals on CEM systems and regulations are referenced in the bibliography of this chapter and are readily available on the Internet.
ENFORCEMENT POLICIES AND CEM SYSTEMS
The most obvious impact of continuous data is that more information is available to environmental control agencies. By obtaining such data (or summaries of data), fewer on‐site inspections and manual reference method tests may be necessary to enforce emissions standards. Different approaches can be taken by an agency in applying CEM data to meet its goals of maintaining and improving air quality. Properly used, CEM data can expand an agency's enforcement capabilities. The CEM database can assist in negotiating the installation of control equipment or requiring process modifications, or the data can provide the basis for a supply‐and‐demand market‐based approach for improving air quality.
One would expect the regulatory application of CEM system data to be straightforward. If a source has a regulated pollutant emission limit and a monitoring system is installed to monitor the pollutant emissions, then it should be possible to determine at any time whether the source is emitting either under or over that limit. A source is said to be out of compliance if it exceeds its regulated emissions limits. A source is in compliance with emission standards if the emissions are under those limits. CEM systems do this and, by definition, provide emissions data on a continuous basis.
However, the use of monitoring data by air pollution control agencies with regard to enforcement issues becomes somewhat complicated. Technically, a continuous compliance determination method means:
a method specified by an applicable standard or an applicable permit condition which: (1) is used to determine compliance with an emission limitation or standard on a continuous basis, consistent with the averaging period established for the emission limitation or standard; and (2) provides data either in units of the standard or correlated directly with the compliance limit. (U.S. EPA 1997b)
Averaging periods, units, and the degree of correlation with the compliance limit all become issues in the application of monitoring systems to enforcement programs. These issues are readily resolved with the application of CEM systems, but resolution becomes more difficult when predictive emission monitoring systems (PEMS), continuous parameter monitoring systems (CPMS), or other such correlation methods are used. Problems can also arise from other areas. Arguments have been made that emission limits were established based upon EPA