Continuous particulate monitoring is becoming an issue for the electric utility industry as a result of several different sets of environmental monitoring and reporting rules. Title V permitting requirements, compliance assurance monitoring (CAM) rules, possible new source performance standards (NSPS) violations, and credible evidence laws are forcing power plant operators to look much more closely at the question of particulate emissions and control. The CAM rules in particular with the requirement that a source verify that it is operating in compliance with its Title V permit have spurred the reexamination of need to continuously monitor particulate. The option of relying on ESP or fabric filter operating parameters to verify compliance now seem much less likely or desirable for any plant. The option of relying on ESP or fabric filter operating parameters to verify compliance now seems almost impossible for those plants that change fuels or blend coals. The problem of verifying compliance with particulate emission standards has become even more difficult with the introduction of low NOX burners and other nitrogen oxide control strategies on an industry wide basis during the last several years. In the mid 1990's the installation of low NOX burners resulted in lower efficiencies and higher loss on ignition in many plants. Recently the reliance on SCR and NSCR technologies to meet new permit limits for nitrogen oxides produced unintended emissions of acid mists and other operational problems. Plants responded to these challenges by changing firing procedures, adjusting precipitator control cycles, and making the changes necessary to ensure the new pollution abatement equipment functioned properly. Every change affected particulate emissions and redefined the particulate removal equipment operating parameters. With these type of changes now the rule instead of the exception, it difficult to see how a strategy that relies on monitoring operating parameters instead of actual emission can be effective. It is increasing clear that direct measurement of particulate emissions may be the only option to guarantee compliance. With a requirement for continuous particulate monitoring likely in the not too distant future for a number of industrial groups including electric utilities, questions of how to accurately and economically monitor particulate will continue to be asked. Beta gauge particulate monitors offer many advantages in monitoring difficult sources. The technology is unaffected by the parameters which marginalize other particulate monitoring instruments that rely on optical or charged particle measuring techniques to record emissions. This paper provides a background on beta gauge technology and discusses the requirements for meeting EPA Performance Specification 11 for particulate monitors.
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