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CONTINUOUS EMISSION MONITORING
CONTINUOUS EMISSION MONITORING

Third Edition

JAMES A. JAHNKE, PH.D.

This third edition first published 2022
© 2022 John Wiley & Sons, Inc.

Edition History
John Wiley & Sons, Inc., 2e (Continuous Emission Monitoring, 2000)
Van Nostrand Reinhold/co Wiley, 1e (Continuous Emission Monitoring: Theory and Practice, 1993)

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Library of Congress Cataloging-­in-­Publication Data

Names: Jahnke, J. A. (James A.), author.

Title: Continuous emission monitoring / James A. Jahnke.
Description: Third edition. | Hoboken, NJ : Wiley, 2022. | Includes
bibliographical references and index.
Identifiers: LCCN 2021050361 (print) | LCCN 2021050362 (ebook) | ISBN
9781119433989 (cloth) | ISBN 9781119433996 (adobe pdf) | ISBN
9781119434023 (epub)
Subjects: LCSH: Continuous emission monitoring.
Classification: LCC TD890 .J34 2022 (print) | LCC TD890 (ebook) | DDC
628.5/30287–dc23/eng/20211115
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Cover Image: © Cover illustration art by John M. Havel

Set in 10/12pt Times by Straive, Pondicherry, India

10 9 8 7 6 5 4 3 2 1
To Gloria
CONTENTS

PREFACE ix

1 INTRODUCTION TO CEM SYSTEMS 1

2 CEM REGULATIONS 11

3 EXTRACTIVE SYSTEM DESIGN 41

4 INTRODUCTION TO THE ANALYTICAL METHODS 75

5 EXTRACTIVE SYSTEM ANALYZERS 91

6 IN-­SITU GAS MONITORING SYSTEMS 137

7 FLOW RATE MONITORS 163

8 OPACITY MONITORS 187

9 CONTINUOUS PARTICULATE MONITORING 217

10 CEM SYSTEM CONTROL, DATA ACQUISITION, AND REPORTING 253

11 CERTIFYING CEM SYSTEMS 277

12 MONITORING FOR MERCURY 311

13 MONITORING HAZARDOUS AIR POLLUTANTS 345

14 GREENHOUSE GAS MONITORING 375

vii
viii CONTENTS

15 QUALITY ASSURANCE PROGRAMS FOR CEM SYSTEMS 395

APPENDIX A UNITS OF THE STANDARD AND F FACTORS 437

APPENDIX B CONVERSION FACTORS AND USEFUL INFORMATION 447

INDEX 449
PREFACE
This third edition to Continuous Emission Monitoring
comes 20 years after the second edition was published.
Over that period, more sources in more industries have
been required to monitor a wider range of pollutants at
ever-­decreasing emission levels. To meet the challenges of
more stringent regulatory programs, both monitoring
technology and the management systems necessary to
maintain them have developed to the point where accu-
rate and precise emissions data can be obtained at the
lowest ranges specified by regulatory agencies. The evolu-
tion of monitoring regulation and the technology neces-
sary to support it are based on programs initiated in the
1970s and 1980s. These programs were described in the
first and second editions of Continuous Emission
Monitoring, which have provided a foundation for those
newly entering or those needing to gain perspective of the
field. This third edition extends that foundation to later
programs implemented in the 1990s and 2000s. In the
1990s, continuous emission monitoring (CEM) systems
were applied to support the determination of emission
“allowances,” in the U.S. acid rain cap and trade program.
Later, in the 2000s, regulatory programs for NOx emis-
sions, mercury, volatile and “air toxics,” semi-­ volatile
organic and inorganic compounds were instituted, leading
to significant challenges for the monitoring community.
This book focuses on continuous emission monitoring
requirements promulgated in the United States, although
monitoring rules developed in Canada and the European
Union are addressed where appropriate.
Continuous emission monitoring involves the sum of
activities associated with determining and reporting
­pollutant emissions from stationary sources. Coal-­and
oil-­fired power plants, municipal and hazardous waste
incinerators, petroleum refineries, cement plants, Kraft
pulp mills, and, now, many chemical process industries
are required to monitor emissions on a continuous basis.
The emissions data obtained provide a continuous record
that can be used by environmental control agencies to
support a variety of regulatory programs. First used to
monitor the operation of air pollution control equip-
ment, regulatory applications have extended in the
United States to use CEM systems for determining the
compliance of stationary sources with their emission lim-
itations. For CEM data to be credible, one cannot rely
only on instrumentation. The implementation of a plant-­
level quality assurance program, based on routine qual-
ity control procedures, has been found essential for data
credibility. As a result, CEM quality assurance and qual-
ity control have become integral to CEM regulation.
One of the purposes of this book is to provide an
understanding of both the regulatory and technical issues
that must be considered when making decisions about
CEM systems. As regulatory applications are extended,
CEM system data are being used increasingly for process
control and optimization. Although the use of CEM sys-
tems for determining compliance with pollutant emis-
sion limits has been the driving force for their installation,
the benefits of knowing what and how much of some-
thing is being emitted are becoming more widely recog-
nized. Here, the adage that “if you can measure it, you
can control it” has led to the acceptance of CEM systems
by managers who understand that CEM systems can be
used for more than just meeting environmental regula-
tions – that a knowledge of emission rates can also be
used to optimize plant operations.
The earlier editions of this book have continued to
serve as a resource for training programs, the develop-
ment of quality assurance plans, and the drafting of techni-
cal specifications for monitoring system purchases. It is a
characteristic of U.S. environmental programs, that once
written, regulations do not go away. In some cases they
may be revised, but in others, they remain static.
ix
x PREFACE
Continuous emission monitoring requirements have
accordingly remained relatively unchanged over the past
four decades. U.S. CEM requirements have remained basi-
cally the same since their inception in the 1970s, seeing
only their greatest alteration with the allowance trading
programs implemented in the 1990s. In terms of technol-
ogy, extractive sampling methods, in situ monitoring, the
principles of light absorption and light scattering, and
other analytical methods applied in the monitoring instru-
mentation are fundamental; providing the basis for under-
standing the operation of instruments that typically
remain installed from 15 to 30 years. However, much has
been learned over the past 20 years and an update of the
second edition is needed to provide a current perspective
of the field. In particular, the U.S. Environmental
Protection Agency institutes new rules and requirements
as required by the periodic amendment of the Clean Air
Act. These new rules are added to extend control over a
wider range of industries for a wider range of pollutants.
This edition of Continuous Emission Monitoring addresses
these rules and the technology applied to meet them.
This book examines the interplay of technology and
regulation as it affects the design, application, and certi-
fication of CEM systems. It describes new techniques
employed in emissions monitoring, adds new knowledge
gained on existing methods, but excludes instrumenta-
tion that is no longer available commercially. Chapters
on the measurement of air toxics, mercury, and green-
house gases have been added. The chapter on air toxics
discusses monitoring instrumentation and methods used
to measure hazardous air pollutants regulated under 40
CFR 63, the so-­called MACT (Maximum Achievable
Control Technology) program. Monitoring for mercury is
also required under this rule; however, due to the com-
plexity of both the monitoring technology, calibration
methods, and certification requirements, a separate chap-
ter is devoted to this topic. A chapter on greenhouse gas
monitoring has also been added. Monitoring greenhouse
gases is relatively straightforward; however, data quality
is paramount in this area of measurement. The role of
CEM systems in greenhouse gas reporting is discussed in
relation to the use of mass balance, emission factors, and
other estimates to provide perspectives in reporting and
certifying greenhouse gas information.
Due to the expanded use of CEM systems in regulatory
programs both in the United States, Canada, Europe, and
Asia, it is important for data comparability between nations
that both the monitoring technology and regulatory stand-
ards used for system specification be technically sound.
Additional emphasis is given to international approaches to
continuous monitoring, particularly approval methods for
the “automatic monitoring systems” (AMS) of the
European Union (EU). Differences between the U.S. and
European methods are discussed with regard to data equiv-
alence and the implications for international agreements.
CEM technology can be considered to be mature for
the continuous measurement of gases such as SO2, NO,
CO, O2, and CO2, in addition to the measurement of
­ articulate matter, mercury, and flue gas volumetric flow.
p
By mature, it is meant that sufficient knowledge has been
attained over the past 50 years of CEM development so
that when properly designed, operated, and maintained,
these CEM systems can be used to measure emissions
to within acceptable levels of precision and accuracy.
Advances in the application of digital electronics have
greatly improved monitoring instruments, as well as con-
tinuing the trend to smaller, more cost-­effective, and less
maintenance intensive instruments. But CEM systems do
remain application dependent. An instrument manufac-
turer’s new analyzer or a CEM systems integrator’s inno-
vative design must still be evaluated with respect to
plant-­ specific requirements as well as the ever more
demanding regulatory requirements. In terms of present
realities, the first law of CEM systems that “there is no best
type of system” may be rephrased more positively. The best
system is one that (i) works in the plant application, (ii) can
be purchased and operated at “reasonable cost,” and
(iii) requires relatively low maintenance. It is, however, not
always easy to obtain that one best system when con-
fronted with marketing claims, conflicting performance
histories, cost limitations, and installation deadlines.
This third edition is written in the same spirit as the first
and second, presenting the principles by which CEM sys-
tem technical and regulatory developments can be under-
stood. This book is designed to be comprehensive in scope,
to meet the needs of both the plant environmental engi-
neer applying CEM systems and control agency personnel
incorporating CEM systems in regulatory programs.
Although the chemical or physical basis of analyzer
operation is given, the theoretical and technical details
necessary for designing monitoring instrumentation and
systems is beyond the scope of this book. Ample refer-
ences are incorporated after each chapter should the
reader wish to further pursue specific topics. This edition
of Continuous Emission Monitoring, as the first and sec-
ond editions, seeks to introduce the reader to this
dynamic field and to point the way to the knowledge of
today’s CEM systems necessary to address the chal-
lenges of today’s regulatory environment.
The author would like to thank the graphic artists who
have contributed to the evolution of the figure illustra-
tions presented in this book. These artists include
Katherine Lindsay and Betsy Huber who initiated many
of the original CEM system dimensional drawings,
Sherry Stafford who prepared the graphics for the first
edition, and John Havel who developed the new graphics
for both the second edition and this third edition. The
author is indebted to the instrument manufacturers and
CEM system integrators who graciously furnished
­diagrams and technical information of their instruments
and systems. Thanks are also expressed to Kata Kollath
for assistance in editing, and the colleagues who offered
suggestions for the development of this edition and
pointed out errors in the second edition.
James A. Jahnke, PhD
CHAPTER 1
INTRODUCTION TO CEM SYSTEMS
In the early 1970s, a better way was needed to monitor
stack emissions than by manual stack tests. In general,
manual methods are conducted by inserting a probe into
a stack, extracting a sample, and analyzing the sample in
a laboratory, which is a time-­consuming process. Manual
source tests also require a degree of preparation, and the
coordination and prior scheduling of a test may result in
source operations being highly tuned before such testing
takes place. Manual test results, therefore, may not nec-
essarily be representative of day-­ to-­
day emissions.
Clearly, for monitoring plant emissions and the perfor-
mance of pollution control equipment on a more realistic
basis, alternative measurement techniques are needed.
A BRIEF HISTORY
Attempts were made in the 1960s to use ambient air ana-
lyzers and process industry analyzers to measure source
emissions. Ambient air analyzers were not successful at
that time due to the instability of dilution systems.
However, process analyzers did prove to be useful, par-
ticularly those that employed ultraviolet and infrared pho-
tometric techniques. Then, in the late 1960s and early
1970s, successful developments emerged in instrumenta-
tion in Germany and the United States. Ambient analyz-
ers were redesigned to measure gases at higher
concentration levels, and the so-­called “in-­situ” analyzers
were developed, which can measure gases in the stack
without sample extraction. These methods, in addition to
new German optical systems for opacity monitors and the
development of luminescence measurement t­ echniques in
Continuous Emission Monitoring, Third Edition. James A. Jahnke.
© 2022 John Wiley & Sons, Inc. Published 2022 by John Wiley & Sons, Inc.
the United States, provided a technological base from
which continuous emission monitoring (CEM) regula-
tions could be established.
Continuous emission monitoring requirements in the
United States were first promulgated in 1971. However,
the CEM industry did not begin to develop until after 6
October 1975 when the U.S. Environmental Protection
Agency (U.S. EPA) established performance specifica-
tions for CEM systems and required their installation in
a limited number of sources. Since then, CEM systems
have been applied to a wider range of sources, and over
50 years of experience has led to the evolution of analyz-
ers and monitoring systems with ever-­improving perfor-
mance The technology is considered mature, having a
solid foundation in reliable instrumentation, procedures,
and standards that can assure the quality of source emis-
sion data at specified limits of accuracy and precision.
The earliest focus of CEM technology was on the
­analyzer – the instrument that measures. However, it was
soon found that the process of transporting the gas to the
analyzer was a source of many problems. Such problems
were addressed in a number of ways by CEM “systems”
integrators. Those who understood the effects of corro-
sive stack gases on materials and the effects of pressure
and temperature on gas transport were the first to design
and successfully market systems that worked under
severe sampling conditions.
The difficulties associated with extractive systems led
to the idea of measuring the flue gases as they exist in the
stack or duct, without conditioning. This idea was realized
in the development of “in-­ situ” analyzers, second-­
generation source monitoring systems especially designed
1
2 INTRODUCTION TO CEM SYSTEMS
to avoid problems inherent in extracting gases. In-­situ sys-
tems have been designed to measure gas concentrations,
flue gas opacity, flue gas flow, and particulate matter con-
centrations. Many present-­day CEM systems are a combi-
nation of extractive and in-­situ systems (Figure 1‑1).
Third-­generation systems emerged with the promulga-
tion of the Clean Air Act Amendments of 1990 and the
implementation of the acid rain allowance trading pro-
gram. Requirements to report emissions in tons per year
led to the demand for systems that could measure pollut-
ant mass rate. As a result of this program, flow monitors
and dilution-­extractive systems were added to the inven-
tory of monitoring methods. It was in the acid rain pro-
gram that CEM systems found their maturity. To assure
the success of plant monitoring programs, both equipment
and personnel resources were made available by corpo-
rate management. And here, it was found that for the suc-
cess of monitoring programs, trained and experienced
personnel can be equally important as the equipment.
A fourth wave of continuous emission monitoring
applications came after 2000 with the delayed and piece-
meal regulatory development of rules for hazardous air
pollutants. The program to control hazardous air pollut-
ant emissions was promulgated in the 1990 Clean Air Act
Amendments along with the acid rain program; however,
due to the enormity of the task of regulating 187 hazard-
ous air pollutants from 174 source categories, the pro-
gram was slow to start. It wasn’t until after 2000 that
Gas
sampling
probe
Flow
monitor
Figure 1-1 A continuous emission monitoring (CEM) system.
continuous monitoring requirements for air toxics began
to come into effect, but the need to develop new and
more sophisticated monitoring systems for measuring
particulate matter, mercury, and hydrochloric acid was
apparent before that time. A new generation of monitor-
ing systems was developed, measuring a wider range of
compounds and materials, at ever lower concentrations,
by incorporating advanced measurement and miniaturi-
zation techniques developed in response to national mil-
itary and security concerns.
The business of continuous emission monitoring is
largely dependent upon environmental regulations and
is almost cyclical with the ebb and flow of environmental
rule-­making. As new regulatory programs are developed,
it is found necessary that a means be provided to keep
track of progress or lack of progress. When emission lim-
its are mandated, enforcement programs require a meas-
ure of whether emission limits are met or not. Intermittent
manual stack testing is clearly not adequate for this pur-
pose, and it has been demonstrated that continuous
emission monitoring systems can provide data of suffi-
cient precision and accuracy to support enforcement
programs and allowance trading programs. With emis-
sion limits becoming ever more stringent and the proper
operation of pollution control equipment ever more
critical, continuous emission monitoring systems have
evolved where they can today, meet the most demanding
applications.
Opacity
monitor
Flow control
panel Data acquisition
system
Gas
cylinders
Pump
Analyzers
Chiller

TYPES OF MONITORING SYSTEMS
A CEM system is actually composed of several subsys-
tems: the sampling interface, the gas analyzer(s), and the
data acquisition/controller system. The sampling interface
is a subsystem that either transports or separates the flue
gas from the analyzer. CEM systems are characterized in
terms of the design of this interface. In extractive systems,
the interface consists of a system that extracts and condi-
tions the gas before entering the analyzer. In in-­situ sys-
tems, the interface is simpler, composed of flanges
designed to align or support the monitor and blower sys-
tems used to minimize interference from particulate mat-
ter. The data acquisition/controller subsystem is integral
to the proper operation of the total system. The control
system controls automatic functions of the system, such as
calibration, probe purging, and alarming. The data acquisi-
tion system receives the analyzer data, converts it into
appropriate units, records it, and provides reports for both
internal and external use. Today, CEM data acquisition
systems are frequently networked to engineering, corpo-
rate, and even agency offices, where the data are used for
a variety of operational and management purposes.
Both extractive and in-­situ systems operate in the
source environment and must operate continually under
changing stack and ambient conditions. Although this is
not necessarily a problem for properly designed and
maintained systems, alternative approaches have been
sought. One of these approaches, remote sensing, has
been applied with limited success, but has not been used
widely. Another alternative, the correlation of stack
emissions to process parameter data, has led to comput-
erized “predictive emission monitoring systems” or
PEMS. These systems have been employed successfully
in a number of applications and have considerable poten-
tial if used in tandem with extractive or in-­situ ­monitoring
Types of continuous monitoring methods
Extractive
Source level Dilution Path
Dry In-stack
Wet Out-of-stack
Close-
coupled
Figure 1-2
TYPES OF MONITORING SYSTEMS 3
hardware. The monitoring methods discussed earlier are
classified in Figure 1-­
2 and discussed further in the
­following sections.
Extractive Systems
Extractive gas monitoring systems were the first to be
developed for source measurements. In these systems,
gas is extracted from a duct or stack and transported to
analyzers to measure the pollutant concentrations. Many
of the early extractive systems first diluted the gas using
rotameters, and then applied ambient air analyzers for
measurements. However, frequent problems occurred in
maintaining stable dilution ratios, so analyzers were
­subsequently developed to directly measure the flue gas
at source-­ level concentrations in the range of 100–
1000 ppm or higher. These source-­ level extractive
­systems were quite successful and received their widest
application in the 1970s and early 1980s.
Many of the problems associated with the earlier dilu-
tion systems have since been eliminated by new tech-
niques developed in the 1980s. The advent of the “dilution
probe” made dilution systems viable for source measure-
ments. Dilution systems are now relatively easy to con-
struct and exhibit good performance. They are
particularly useful for monitoring water-­soluble gases
and provide a platform for the application of a new gen-
eration of analyzers that are able to measure part per
billion concentration levels.
In order for an instrument to measure gas concentra-
tions, the gas sample must be free of particulate matter.
Often, water vapor is removed and the sample is cooled
to instrument temperature. This requires the use of
valves, pumps, chillers, sample tubing, and other compo-
nents necessary for gas transport and conditioning. “Hot-­
wet” systems, which measure hot gases without water
In-situ Parameter Remote
sensing
Point Emissions Predictive
surrogate
Single-pass Theory-based
Double-pass Statistical
Types of monitoring systems.
4 INTRODUCTION TO CEM SYSTEMS
removal, operate continuously at elevated temperatures,
eliminating the need for water removal systems.
Extractive systems use an umbilical line to transport the
flue gas sample from the stack or duct to an analyzer
cabinet or temperature-­controlled shelter. This line is
heated in source-­level systems where the conditioning
system is located in the shelter.
Dilution-­ extractive systems became popular in the
1990s for determining pollutant mass emission rates at
U.S. coal-­fired power plants subject to acid rain cap-­and-­
trade regulations. Dilution-­ extractive CEM systems
measure on a wet basis, an advantage when required to
report emissions in units of tons/year or kg/hr. Dilution-­
extractive systems are available where the sample dilu-
tion takes place in a specially designed in-­stack probe or,
alternatively, in a probe box outside of the stack, where a
variety of dilution techniques are available. In either
case, when the flue gas sample is diluted at the stack, a
heated umbilical line is not always needed to transport
the diluted sample to a CEM shelter.
Close-­coupled systems are extractive systems where
the sample conditioning and analysis are conducted
directly on the stack. In these systems, the analyzer is
connected directly to the sample probe. These systems
avoid sample losses for “sticky” or reactive gases due to
gas transport and also reduce system costs by not requir-
ing an umbilical line.
In-­Situ Systems
In-­situ systems consist primarily of an analyzer that
employs some type of sensor to measure the gas directly
in the stack, or projects light through the stack to make
measurements. The opacity monitor and flow monitor
illustrated in Figure 1‑1 are typical examples of in-­situ
analyzers. There are two classifications of in-­situ analyz-
ers: point and path. Point analyzers consist of an electro-­
optical or electroanalytical sensor mounted on the end
of a probe that is inserted into the stack. The point in-­
stack measurement is usually made by a sensor over a
distance of only a few centimeters. Path analyzers, on the
other hand, measure along a path across the width of the
duct or diameter of the stack. In these “cross-­stack” gas
analyzers, light is transmitted through the gas, and the
interaction of the light with the flue gas is used to obtain
a quantitative value of the pollutant concentrations. In
single-­pass instruments, light is transmitted from a unit
on one side of the stack to a detector on the other side,
making only one pass through the stack. In a double-­pass
system, light is reflected from a mirror on the opposite
side, doubles back on itself, and is detected back at the
“transceiver.”
In-­situ analyzers are used to measure the concentra-
tions of pollutant and combustion gases and particulate
matter, flue gas opacity, and flue gas velocity (flow). Both
point and path techniques are used to monitor gas and
particulate concentrations. Opacity monitors (transmis-
someters) are path monitors and can be either single-­
pass or double-­pass systems, measuring the transmittance
of visible light through the stack. Flow monitors are
designed in either point or path configurations, depend-
ing upon the analytical technique.
Using wavelength-­tunable lasers, in-­situ gas monitor-
ing systems are experiencing renewed popularity, par-
ticularly for the measurement of reactive gases such as
HCl and NH3. More attention is being paid to verifying
system calibration using NIST traceable calibration
gases, an important issue in the United States. In-­situ
point monitors using laser-­ light scattering techniques
have become popular for monitoring flue gas particulate
matter concentrations. Light-­ scattering particle sizing
techniques are developing, but this technology has lagged
behind in source monitoring applications for many years.
Remote Sensors
Remote sensing systems have no interface between the
stack gases and the sensing instrument, other than the
ambient atmosphere. They thus avoid problems associ-
ated with a stack or duct interface. These systems can
detect emission concentrations merely by projecting
light up to the stack (active systems) or by sensing the
light radiating from the “hot” molecules emitted from
the stack (passive systems). However, due to an inherent
problem in defining the length of the measurement path
in the plume, the accuracy of gas concentration data is
poorer than that obtained by the extractive or in-­situ
techniques. This problem is also an issue in making flue
gas measurements using laser systems mounted on
unmanned aerial vehicles (drones), a developing source
monitoring technology.
The U.S. EPA has developed Method 9A for monitor-
ing stack exit opacity, using a laser light detection and
ranging technique (LIDAR). The method is particularly
useful at night or under atmospheric conditions that are
not favorable to a visible emissions observer (VEO) per-
forming EPA test method 9. In a related development, a
digital camera technique for measuring plume opacity
has been standardized by ASTM in ASTM standard
D7520-­16. Although not a continuous method, data using
this method are being accepted by regulatory agencies
for visible emissions compliance determinations.
Test methods and certification procedures have not
been standardized for remote sensing systems used to
monitor gaseous emissions. Since the regulatory
a­pplicability of remote pollutant gas measurements to
stationary sources has not yet been established, these sys-
tems for source emissions monitoring are not extensively
applied in commercial applications. They have, however,
seen wider application in “fence-­ line” m
­onitoring,

­ articularly at petroleum refineries and chemical plants.
p noncompliance with permit conditions. Control equip-
Attempts are frequently made to correlate emissions data
with long-­ path remote sensing data obtained along a
plant perimeter. Such correlations typically devolve into
research studies and have met with limited success as a
regulatory tool.
Unmanned aerial vehicles (UAVs) (drones) offer sig-
nificant potential in source monitoring applications
(Villa et al. 2016). UAV systems can obtain grab sample
for laboratory analysis, or, as part of an active remote sys-
tem, incorporate a stationary mirror to reflect light pro-
jected from a ground-­based analyzer. Using lasers, two
drones standing-­off from a stack exit can make cross-­
stack gas measurements. Four drones could measure on
two diameters. UAV platforms can carry simple minia-
ture sensors, readily available from hand-­held monitors,
to measure flue gases in real time using a stand-­off probe
or by flying through the stack. For compliance measure-
ments, a probe can be inserted from the UAV “down” the
stack, as it hovers at a fixed position next to the stack.
The availability, at present, of miniature and micro ana-
lyzers provides many options for analysis using UAV
platforms. Flares and smaller process stacks with limited
access or without sampling platforms are seen as poten-
tial applications for this technology.
Performance specification and certification proce-
dures have not been developed for remote sensing sys-
tems or UAVs; however, this technology is relatively new.
Calibration procedures and precision and accuracy issues
relative to in-­stack measurements must first be standard-
ized for UAV data to be credible. Standards developed
by independent standards bodies such as ASTM or ISO
may provide a basis for future agency requirements.
Because the regulatory applicability of remote and UAV
pollutant gas measurements to stationary sources has
not yet been established, they will not be discussed fur-
ther, but do bear watching in the technical literature.
Parameter Monitoring Systems
Alternative approaches to emissions monitoring have
been developed that do not require the use of analytical
instrumentation, but rely instead on inputs from process
sensors, such as thermocouples, pressure transducers,
and fuel flow meters. Data from these sensors can be
used in a variety of ways in environmental regulatory
programs. The parameter information can be either used
directly as a surrogate to substitute for concentration-­
based emissions data or it can be incorporated into a
model to predict emissions.
U.S. regulatory programs have long used parameter
data such as pressure drop or temperature to monitor the
performance of emission control equipment. The param-
eter data has been used either as a regulatory trigger to
initiate enforcement action directly or as an indicator of
TYPES OF MONITORING SYSTEMS 5
ment and unit operational parameters can also be used
directly in continuous parameter monitoring systems
(CPMS) as part of a continuous monitoring system
(CMS). This regulatory approach does not require the
use of continuous emission monitoring systems although
a CEM system can be a part of a CMS. The U.S. air toxics
standards make extensive use of this method.
A more recent approach has been used to develop
emission models based on process parameter data.
Models are developed by first correlating parameter
data to emissions data. An initial study is performed by
varying and monitoring process and control equipment
parameters while monitoring flue gas emissions using
reference methods or CEM systems. One can then cor-
relate the data using engineering calculations, least
squares methods, or neural net techniques to develop a
model that “predicts” emissions from parameter data.
Such predictive emission monitoring systems (PEMS)
employ from 3 to 20 input parameters and have been
applied to a variety of sources. They are most successful
on sources with minimal variation in fuels and operating
conditions.
Analytical Techniques Used in CEM System
Instrumentation
The analytical techniques used in extractive and in-­situ
CEM systems encompass a wide range of chemical and
physical methods. These vary from chemical methods
using simple electrochemical cells to advanced electro-­
optical techniques such as wavelength modulation and
Fourier-­transform infrared spectroscopy. Table 1‑1 sum-
marizes the analytical techniques that are used in cur-
rently marketed CEM systems for gases. Table 1‑2 gives a
summary of analytical techniques used in continuous
emission monitoring systems for particulate matter (PM
CEMS).
Techniques used for laboratory analysis, as well as
techniques applied specifically for emissions monitoring,
have been incorporated into commercially marketed sys-
tems. New analyzers have been developed using estab-
lished electro-­optical methods, but are beginning to
incorporate new light sources and detectors, such as tun-
able diode lasers, quantum cascade lasers, and diode
arrays and new techniques such as cavity ringdown spec-
troscopy. The incorporation of microprocessors into
today’s analyzers has added useful features such as data
storage, troubleshooting diagnostics, and external
communication.
To lower the cost of CEM systems, CEM system manu-
facturers are employing multi-­gas techniques to avoid sub-
system duplication that occurs when using single-­ gas
dedicated analyzers. One approach is to use multi-­ gas
methods such as dispersive, FTIR, or photoacoustic
6 INTRODUCTION TO CEM SYSTEMS

TABLE 1-­1 Analytical Techniques Used in Continuous Emission Monitoring Systems for Gases and Volumetric Flow/Velocity
Gases Flow/Velocity
Extractive In-­situ In-­situ
Absorption spectroscopy: Path: Path:
Differential absorption Differential absorption – IR/UV Acoustic velocimetry
Photoacoustic Second-­derivative spectroscopy Time-­of-­flight
Gas filter correlation Wavelength modulation
Fourier transform IR Gas filter correlation
Luminescence methods: Point: Point:
Fluorescence (SO2) Differential absorption – IR/UV Differential pressure
Chemiluminescence (NOx) Gas filter correlation Thermal sensing
Electroanalytical methods:
Polarography
Potentiometry
Calorimetry
Electrocatalysis (O2)
Paramagnetism (O2)
Methods for HAPS:
Differential absorption
Gas chromatography
Mass spectrometry
Fourier-­transform IR
Ion-­mobility spectrometry
Atomic emission (Metals)
Atomic absorption (Metals)
Atomic fluorescence (Metals)

TABLE 1-­2 Analytical Techniques Used in Particulate Matter Continuous Emission Monitoring Systems (PM CEMS)
Extractive In-­Situ
Point Point: Path
Beta radiation attenuation Light scattering Transmissometry
Light scattering Contact charge transfer Light scattering
Electrodynamic induction

s­ pectrometry. Another approach is to incorporate discrete,
multiple, and interchangeable sensors into a single chassis.
Succeeding chapters present details of both extractive
and in-­situ systems – their advantages, disadvantages,
and limits of application. The sampling interface is of
particular importance in extractive system design and is
treated separately in Chapter 3. Extractive system ana-
lyzers are discussed in Chapter 5. For in-­ situ system
design, the analyzer type is most important. In-­situ moni-
tors for measuring gases are discussed in Chapter 6 and
monitors designed for measuring flue gas flow, opacity
and particulate matter in Chapters 7–9.
Mercury monitoring, a field in itself, has advanced sig-
nificantly, within 15 years of research and development.
This topic is treated separately in Chapter 12, to outline
how a new generation of mercury monitoring systems
has evolved to enable continuous monitoring of station-
ary source mercury emissions down to less than 1 μg/m3.
Monitoring for hazardous air pollutants (HAPs) has
developed along with increased concerns over their toxic
effects. Monitoring requirements for these materials,
implemented incrementally over the past 20 years, are
discussed in Chapter 13.
Data Acquisition and Handling Systems
CEM system analyzers do not stand alone, but are part
of a larger system as seen in Figure 1‑1. The assembly of

analyzers is coordinated and controlled to provide emis-
sions data that are subsequently recorded and reported.
These roles were all originally considered part of the
data acquisition and handling system (DAHS or DAS).
Today, control functions are commonly separated from
the DAHS by using data loggers, programmable logic
controllers (PLCs), or separate microprocessor systems.
This simplifies the CEM system by providing more flex-
ibility for both system control and data acquisition and
reporting.
Hardware used in CEM recording and reporting sys-
tems has evolved from the now archaic strip chart record-
ers to computer systems integrated into the plant
distributive control system and the plant local area net-
work, corporate wide area network, or intranet. In spe-
cial cases, remote terminal units are used to provide
emissions data to environmental control agencies either
continuously on a real-­time basis or on demand.
CEM software has evolved significantly, principally
due to the demands of the U.S. EPA Acid Rain Program.
Requirements to report all emissions data plus plant
operational data, on a quarterly basis, have led to sophis-
ticated multitasking programs, having the capability of
editing and back-­ filling data according to prescribed
algorithms. Today’s programs offer flexibility to both
CEM system operators and environmental engineers in
evaluating data quality and in preparing internal and
external reports.
Programming tends to be customized to meet the
demand of each plant installation with flexible and user-­
configurable programs, making this task somewhat eas-
ier. The integration of CEM system data into plant
distributive control systems and information networks
has become a larger task. This requires considerable
coordination between plant information technology per-
sonnel, plant engineers, the CEM system integrator, and
the data acquisition system provider. This is often the
most difficult job associated with the installation of a
new CEM system.
THE ROLE OF QUALITY ASSURANCE
In the 1970s, industry frequently presented quite valid
arguments that the performance of continuous monitor-
ing systems was questionable. Two basic principles of
CEM technology were soon learned:
1. There is no one “best” type of system for all
applications.
2. A CEM system must be maintained if it is to
operate.
During this period, aggressive CEM system vendors
frequently sold their systems to anyone who could be
convinced to buy their product. This resulted in
APPLICATION 7
­ isapplications of both in-­situ and extractive systems.
m
The resulting poor performance led to unfortunate per-
ceptions about the reliability of the technology and
bankruptcy and absorption of several companies. This is
a process that continues still today. From this experience,
formal procedures for specifying and evaluating CEM
systems have been developed and should be used by
companies planning major CEM system purchases.
Errors in application have not been the only reason
for poor CEM system performance. It is often assumed
that after a CEM system is installed, it can generate data
as routinely as a thermocouple or pressure gauge. It must
be realized that routine maintenance programs are nec-
essary for the continuing operation of extractive system
plumbing and electro-­ optical systems. Although this
necessity is now well understood, awareness of this need
did not develop in the United States until the early 1980s.
A CEM specialty conference of the Air Pollution Control
Association held in Denver in 1981 pointed out the need
for established and effective CEM system quality assur-
ance (QA) programs. By the time of a subsequent con-
ference held in Baltimore in 1985, the U.S. Environmental
Protection Agency proposed CEM system quality assur-
ance requirements and many companies were reporting
the success of their own QA programs in improving
CEM system performance. In 1989, the U.S. EPA prom-
ulgated quality assurance procedures for CEM systems
used for compliance determinations, specifying require-
ments for calibration and periodic audits. With this les-
son learned, when new performance specifications are
promulgated, quality assurance procedures specific to
the pollutant are published concurrently. This can be
seen in the almost concurrent publication of Appendix F
quality assurance procedures for particulate monitoring
systems, mercury monitoring systems, and hydrochloric
acid monitoring systems with the publication of their
respective performance specifications in Appendix B of
Part 60.
Like an automobile, where the oil must be changed
and the tires rotated, a CEM system requires routine
checks and replacements. QA programs incorporating
daily and weekly checks, periodic audits, and preventive
maintenance procedures have been found to be the key
to continuing CEM system operation. Systems with
such programs today show better than 98% data
availability.
APPLICATION
CEM systems were originally required by regulatory
agencies in the United States for monitoring the effective-
ness of air pollution control equipment in removing pol-
lutants from flue gases. As indicators of control equipment
performance, the data could be used to track plant perfor-
mance and target sources that were not meeting their
8 INTRODUCTION TO CEM SYSTEMS
emission limitations. Manual source tests would then be
conducted on targeted sources to determine if, indeed,
they were failing to be in compliance with emission
limitations.
However, the extension of CEM data to direct
enforcement applications has grown in both federal and
state programs. By stating specifically in a rule or permit
that a CEM system provides enforceable data that deter-
mines if an emission limit is being met or exceeded, the
earlier link to control equipment performance is not as
important. In addition, the promulgation of the “credible
evidence” rule now allows the use of CEM system data in
litigation.
CEM systems also provide the basis for the U.S. EPA
acid rain control program mandated in the 1990 Clean
Air Act Amendments. Here, CEM systems determine
the “allowances,” the number of tons per year of SO2
emissions that are traded between the electrical utilities.
This successful regulatory program has led to significant
SO2 reductions in the United States within two years of
its implementation. The over 2000 utility CEM systems
installed to track allowances have contributed much to
this success, providing an accurate database necessary to
instill confidence in the trading market.
Another trading program is found in the Cross-­State
Air Pollution Rule, where NOx emissions are traded
between electrical utilities and other sources in the
northeastern states. These regulatory programs as well as
economic forces led to an 89% decrease in SO2 emis-
sions and an 82% decrease in NOx emissions from 1995
to 2017.
Although emission monitoring systems have been
applied principally to satisfy such regulatory require-
ments, CEM system data can also be used proactively
by plant and corporate management by providing a
base of information on compliance status or for consid-
eration in legal issues. As a result of both agency envi-
ronmental programs and proactive source monitoring,
the CEM database provides assurance to the public
that emissions are being monitored to address environ-
mental concerns.
However, the essential purpose of CEM systems
should not be forgotten when providing for the timely
submission of emissions reports. That purpose is to use
CEM system data to control plant operations to meet
emissions limitations (Figure 1‑3). The continuous record
of emissions data enables plant operators and engineers
to optimize plant performance and control equipment
operation. On a continuous basis, emissions can then be
maintained within regulated limits. In some cases, oper-
ating costs can be reduced and data can be gathered for
plant design and maintenance information. In sum, the
focus should not be on the quarterly emissions report,
but rather, on how to use the data to improve operational
efficiencies to minimize emissions.
Plant
emissions Continuous
emissions data
Plant
operations
control Emissions
reporting
Figure 1-3 Industry uses of CEM system data.
SUMMARY
The technology of continuous emissions monitoring has
not been static. The use of CEM systems for allowance
trading programs and emissions enforcement programs,
the demands for increased system availability, and
advances in data handling and reporting have led to
more sophisticated systems with better reliability. CEM
systems have advanced considerably over 50 years of
development, with improved sampling techniques, ana-
lyzers, and data processing systems being integrated into
today’s systems to meet the challenges posed by new
requirements. Also, by implementing CEM system qual-
ity assurance programs and by properly managing the
monitoring programs, high system availability can be
achieved. This high availability is a necessity today, where
inaccurate data or missing data can incur both regulatory
and economic penalties.
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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 indus-
tries, 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 measur-
ing 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 regu-
lations. 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 moni-
toring 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.
Continuous Emission Monitoring, Third Edition. James A. Jahnke.
© 2022 John Wiley & Sons, Inc. Published 2022 by John Wiley & Sons, Inc.
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 includ-
ing these elements.
Continuous monitoring requirements were first promul-
gated for fossil-­fuel-­fired steam generators in the United
States in December 1971. In 1974, Germany passed the
Federal Immission Control Act, which incorporated contin-
uous monitoring requirements. Also, in 1974, pollutant emis-
sion 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 specifica-
tion 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, affect-
ing 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 speci-
fications, 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
11
12 CEM REGULATIONS

CEM technology requirements are discussed later in this chapter. Details

of performance specification, performance specification
test procedures, and quality assurance programs are dis-
cussed in the dedicated chapters that follow.

Implementing Quality IMPLEMENTING RULES IN THE UNITED STATES

rules Certification assurance
Figure 2-1 CEM program elements.
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.
Implementing rules address the source categories and
types of units required to monitor emissions, whereas
performance specifications provide design, installation,
and certification criteria. Quality assurance (QA)
requirements specify procedures necessary for obtaining
accurate data on a continuing basis. These elements sup-
port a CEM program, and a failure in definition of any
one element can lead to an ineffective or failed regula-
tory program. Each of these elements incorporates a
number of integral parts, which are illustrated in
Figure 2‑2.
The regulatory development of implementing rules,
performance specifications, and quality assurance
Implementing rules specify the type of source affected
by the rule and may further specify types of process
units required to monitor emissions. For example, a
Kraft pulp mill recovery furnace may be required to
monitor opacity and total reduced sulfur (TRS), or a
petroleum refinery sulfur recovery unit may be required
to monitor SO2 and H2S emissions through an imple-
menting rule.
The rule should also specify why monitoring is
required – its purpose. This may not always be stated or
may be ill-­defined, particularly in permits. However, dis-
tinctions are important in the case of litigation. Purposes
for which CEM systems are typically installed are as
follows:
Control equipment operation and maintenance
monitoring
Compliance monitoring
Emissions accounting
Public perception monitoring
The first U.S. Federal CEM implementing rules
required the installation of CEM systems to monitor the
performance of emissions control equipment. Since CEM
systems provide a continuous record that shows if a source
is either below or above its emissions limits (emissions

Elements of a CEM rule

Implementing Performance Quality assurance

rules specifications requirements

Affected Installation QA manual

source/units requirements
Quality control
Purpose Design procedures
specifications
Source-specific QA audit
requirements Test procedures
procedures
System

Performance

Figure 2-2 Elements of a CEM rule.


standards), it was soon noted that the data could also be
used for enforcement purposes. Implementing rules fol-
lowed that required the installation of CEM systems to be
used directly for enforcement. Another purpose for the
installation of CEM systems is to provide the data neces-
sary to support emissions accounting programs, such as
the EPA acid rain program. Pollutant and flow monitoring
data are used in these programs to calculate emissions in
units of tons per year. A regulatory instrument called an
“allowance” is equivalent to a right to emit one ton per
year of a given pollutant and a source must have in its
possession, the number of allowances equal its mass emis-
sions expressed in tons/year. Here, CEM systems are the
measurement tool used to track allowances.
Public perception monitoring (or more euphemisti-
cally, “good neighbor” monitoring) refers to more strin-
gent monitoring requirements established for sources
such as municipal and hazardous waste combustors. In
this case, extensive monitoring requirements are speci-
fied, coupled with plant operational interlock criteria
where waste feed is shut off if emission limits should be
exceeded. The continual oversight given by this instru-
mentation is intended to provide assurances to the public
that environmental concerns associated with these types
of sources are being addressed.
In addition to addressing source categories, opera-
tional units, and monitoring purposes, implementing
rules also specify source specific monitoring details,
such as instrument span requirements, data conversion
equations, averaging periods, quality assurance, and
reporting requirements. These details are important for
using the data, but are often overlooked, particularly in
state permits. Although there is a greater awareness of
the need to specify such requirements in the implement-
ing rules, when they are not incorporated, the rule may
be too ambiguous to fulfill its regulatory intent. The
variety of implementing rules that require the installa-
tion of CEM systems are examined further in the fol-
lowing sections.
U.S. Federal Implementing Rules
U.S. federal stationary source emissions standards and
monitoring requirements are drafted by offices of the
Environmental Protection Agency. The most important
of these is the Office of Air Quality Planning and
Standards (OAQPS), which developed the first CEM
implementing rules and performance specifications in
the early 1970s (U.S. EPA 1975). Other EPA offices have
instituted CEM programs based on the original OAQPS
regulations, modifying them for their own regulatory
applications. Figure 2‑3 summarizes CEM regulatory
programs that have been instituted.
In the United States, rules are first developed by the
respective office and proposed in the Federal Register
(FR), a document published on each government busi-
IMPLEMENTING RULES IN THE UNITED STATES 13
ness day that includes regulatory proposals, promulga-
tions, notices, and discussions concerning the rulemaking.
After public hearings, comment, and revision, the regula-
tions and requirements are promulgated and adopted
into the U.S. Code of Federal Regulations (CFR). The
CFR is a multivolume compendium of U.S. regulations
for federal government agencies, which is revised annu-
ally to incorporate any new rules or changes in existing
rules. It is the principle reference for environmental reg-
ulation in the United States.
Code of Federal Regulation citations are given in the
format: (Title) CFR (Part). For example, 40 CFR 60
refers to the part of the code where the New Source
Performance Standards (NSPS) are found. Performance
specification test procedures for CEM systems are found
in 40 CFR 60 Appendix B (U.S. EPA 2020c). Federal
Register citations are given in the format: (Volume No.)
FR (Page No.) (Date). As another example, the final per-
formance specification test procedures 1–4 were pub-
lished in the Federal Register in 1975 at 40 FR 46240 10/
6/75. CFR publications can be found on http://www.ecfr.
gov. Federal Register publications can be found on http://
www.govinfo.gov/app/collection/fr. Federal Register
publications can be useful by providing a background
behind decisions that went into a final rule. Preambles to
final rules include EPA’s responses to comments submit-
ted on the proposed rule on which the final rule is based.
Most of the rules do not stand alone and refer to other
rules, test methods, monitoring specifications, and quality
assurance requirements in other subparts and/or appen-
dices of the Code of Federal Regulations.
Once promulgated, implementing rules may be
amended or superseded by subsequent rules. This can
create some confusion, particularly when rules overlap,
as has been the case with the acid rain rules of 40 CFR 75
and the New Source Performance Standards of 40 CFR
60. Because the source-­specific standards are written at
different times by different people, the formats, termi-
nology, and specifications are sometimes inconsistent
between the different standards. Although there are
periodic attempts to harmonize the rules, inconsistencies
often remain.
New Source Performance Standards, 40 CFR 60 U.S.
EPA regulations concerning stationary sources are found
under Title 40 Subchapter C of the Code. Newly con-
structed sources are required to meet New Source
Performance Standards (NSPS), which are given in Part 60
of Title 40 (expressed as 40 CFR 60). Each source cate-
gory, such as the electric utilities, municipal incinerators, or
cement plants, is assigned a Subpart letter (Subpart Da,
Eb, and F, respectively) by which it is referred to in the
CFR (U.S. EPA 2020a).
The rules prepared by this office affect newly con-
structed sources. A “new source” is defined as one
14 CEM REGULATIONS

Rulemaking requiring
CEM systems

State
Federal agency programs

New source Minimum emission Cross state

Acid rain
performance monitoring air pollution rule
trading program
standards (NSPS) requirements CSAPR

40 CFR 60 40 CFR 75 40 CFR 51 App. P 40 CFR 96

Permit programs
National emissions Air toxics
standards for • Prevention of significant deterioration
MACT
hazardous air (PSD) 40 CFR 52
pollutants (NESHAPS) standards
• Compliance assurance monitoring
(CAM) (CEM Option) 40 CFR 64
40 CFR 61 40 CFR 63 • Other

State rulemaking and initiatives

Incineration standards Mandatory Examples:
hazardous waste greenhouse gas • RGGI/WSI (NE states carbon
reporting rule trading, CA carbon trading)
40 CFR 266 • RECLAIM (CA)
40 CFR 98 • PA requirements
Sewage sludge
• NH3 monitoring (NJ, VA, RI)
40 CFR 503? • HCI monitoring (CT, PA)

Discretionary programs

• Variances
• Orders
• Agreements

Figure 2-3 U.S. Rulemaking requiring CEM systems.

c­ onstructed after the date the rules are first proposed in
the Federal Register. An “existing source” is a source
constructed before that date. Rules for existing sources
are given by the individual states, usually in facility oper-
ating permits, with federal guidance and approval. The
Part 60 Subparts address primarily new sources, but also
include subparts that provide guidance to the states to
develop rules for existing sources. When meeting the
federal guidance requirements, the rules for specific
source categories can be incorporated into the State
Implementation Plan (SIP) (U.S. EPA 2020b). Source
categories required to install CEM systems under NSPS
are given in Table 2‑1.
Table 2‑1 shows the depth of CEM applications in
U.S. industry and power production, but it should also
be viewed as a guide to the Part 60 Subparts. The table
gives applicability dates that distinguish “existing”
sources from “new” and modified or reconstructed
sources. The table lists those source categories required
to monitor the concentration of gaseous pollutants, flue
gas opacity, and/or particulate matter (PM). The table
also lists the types of operational units on which a CEM
system is to be installed. For example, Subpart BB for
Kraft pulp mills may require monitoring on a number of
devices, such as the recovery furnace, lime kiln, and
digester contained within the plant. Sources such as the
electric utilities or municipal waste combustors may
have multiple boilers or combustors, all of which may
require monitoring.
Note that most of the “effective dates” are old, and
one might consider that “new” sources first affected by
this program are now “old.” When Part 60 source
requirements prove to be inadequate, new subparts are
added to address newer “new” sources. This is the case
TABLE 2-­1 Summary of New Source Performance Standards (NSPS) 40 CFR 60 CEM Requirements for Sources with Effective Dates 1971–1990
CFR Monitoring
Source Category Part 60 Subpart Affected Units Effective Datea,b CEM Requirementsc Reference
Hospital/Medical/Infectious Waste Ce Combustor 6/20/96 CO 60.37e
Incinerators SIP Guidelines 3/16/98b
(HMIWI)
Fossil-­fuel-­fired steam generators D Boilers > 73 MW 8/17/71a,b SO2, NOx, CO 60.45
O2 or CO2
Opacity
(PM CEMS option)
Electric utility steam-­generating Da Boilers > 73 MW 9/18/78a,b SO2, NOx, CO 60.49Da
unitsd O2 or CO2
2/28/05a,b Opacity
(IGCC) PM CEMS (Options for
PMCPMS, Bag Leak Detector)
Industrial-­commercial-­ institutional Db Boilers >29 MW 6/19/84a,b SO2, NOx, CO 60.46b
steam-­generating units < 73 MW O2 or CO2 60.47b
Opacity 60.48b
(PM CEMS Option)
Small industrial-­commercial-­ Dc Boilers > 2.9 MW 6/9/89a SO2 60.46c
institutional steam-­generating units <29 MW Opacity 60.47c
Municipal waste combustors Ea Combustor 12/20/89 Opacity 69.56a
SO2, NOx,
CO
Municipal waste combustors Eb Combustor 9/20/94 Opacity 60.58b
6/19/96b SO2, NOx,
CO
(Options for PM HCl, Hg, D/F)
Portland cement plants F Kiln and clinker cooler 8/17/71 Opacity 60.63
HNO3 plants G Process equipment 8/17/71 NOx 60.73
HNO3 plants Ga Process equipment 10/14/11b NOx 60.73a
H2SO4 plants H Process equipment 8/17/71 SO2 60.84
O2, CO2
Petroleum refineries J Catalytic cracker 6/11/73 Opacity, SO2, O2, CO 60.105
SO2 or H2S
Fuel gas combustor TRS or SO2
Claus recovery plants O2

(Continued)
TABLE 2-­1 (Continued)
CFR Monitoring
Source Category Part 60 Subpart Affected Units Effective Datea,b CEM Requirementsc Reference

Petroleum refineries Ja Fluid Catalytic 5/14/07 PM, Opacity 60.106a

Cracking Units BLD
CO, CO2, O2
SO2, NOx
Sulfur Recovery Units SO2, TRS, H2S 60.106b
Fuel Gas Combustion O2
Process Heaters SO2 or H2S 60.107a
O2
NOx,O2
Primary copper smelters P Roaster/Smelter 10/16/74 SO2 60.165
Cu convertor
Dryer Opacity
Primary zinc smelters Q Sintering machine 10/16/74 Opacity 60.175
SO2
Primary lead R Blast/Reverberatory 10/16/74 Opacity 60.185
smelters furnaces
Sintering machine Opacity SO2
Ferroalloy production facilities Z Submerged electric arc 10/21/74 Opacity 60.264
furnaces
Steel plants AA Electric arc furnaces Constructed between Opacity 60.273
10/21/74 and 8/17/83
Steel plants AAa Electric arc furnaces 8/7/83 Opacity 60.273a
Kraft pulp mills BB Recovery furnace 9/24/76 Opacity, TRSe 60.284
Lime kiln
Digester
Brown stock washer
Evaporator:
oxidation and
stripper system
Glass manufacturing plants CC Glass melting furnace 6/15/79 Opacity 60.293
Stationary gas turbines GG 10 MBtu Constructed between Option: 60.334
10/3/77 to 7/8/04 NOx, O2/CO2
Lime manufacturing HH Rotary lime kiln 5/3/77 Opacity, or 60.343
facilities scrubber Δp & supply P
Phosphate rock NN Dryer and calciner 9/21/79 Opacity 60.403
plants grinder Opacity
Tire manufacturing industry BBB 1/20/83 VOCd 60.544
Polymer industry DDD Carbon adsorbers Constructed between VOCd 60.563
9/30/87 – 11/10/89
Flexible vinyl and urethane coating FFF Solvent recovery 1/18/83 VOCd 60.584
and printing controls
Exhaust hoods
Synthetic Organic Chemical III Air oxidation process 10/21/83 VOCd 69.615
Manufacturing Industry (SOCMI) controls 60.613
Absorbers, condensers,
carbon adsorbers
Onshore natural gas processing LLL Sweetening units Constructed between TRS, SO2 Velocity 60.646
1/20/84 and 8/23/11
SOCMI NNN Distillation operations 12/30/83 VOCd 60.663
Nonmetallic mineral processing OOO Baghouses 4/22/08 Particulate 60.674
plants Matter
Petroleum refinery wastewater QQQ Carbon adsorbers 5/4/87 VOC 60.694
systems 60.695
SOCMI reactor processes RRR Absorbers 6/29/90 VOCd 60.703
Condensers
Adsorbers
Magnetic tape coating SSS Carbon adsorbers 1/22/86 VOCd 60.714

Mineral industries UUU Calciners and dryers 4/23/86 Opacity 60.734

Polymeric coating VVV Carbon adsorbers 4/30/87 VOCd 60.774
a
NSPS applies if construction commenced after this date.
b
NSPS applies if modification or reconstruction commenced after this date.
c
CEM requirements are as applicable when meeting the conditions of the subpart.
d
Rule applies if constructed before this date.
e
Organic monitoring device based on IP, photoionization, or thermal conductivity.
Source: Data from U.S. EPA (2020b).
18 CEM REGULATIONS
for Subparts D and Da for electric utilities, Subparts
Ea and Eb for municipal waste combustors, and
Subparts J and Ja for petroleum refineries. The newer
rules become more proscriptive and often require the
installation of CEM systems not required in earlier
subparts. Both new and existing stationary sources can
be further regulated through programs such as the acid
rain program of 40 CFR 75 and the air toxics program
of 40 CFR 63, in addition to state permit requirements.
Each of these programs can impose additional moni-
toring requirements.
Not listed in the table are operational units or smaller
sources that instead of installing CEM systems may
alternatively be required to monitor process parameters
such as pressure drops, temperatures, or fuel flow rates.
Regulatory relief is applied to smaller sources where it
can be a burden to purchase, operate, and maintain a
CEM system. Here, the less stringent parameter moni-
toring requirements for low-­emitting sources may not be
especially significant when considering their relatively
smaller contribution to the atmospheric pollution
burden.
The subparts tend to be complex. Accordingly, they
should be referred to for detailed information concern-
ing units of the emissions standards, monitoring require-
ments, reporting requirements, and exceptions.
General Provisions for the NSPS Subparts General
provisions pertinent to CEM systems required for
sources regulated under the NSPS subparts are present
in four sections of Part 60 of the Code. These sections are
as follows:
§60.7 Notification and Recordkeeping
§60.8 Performance Tests
§60.11 Compliance with Standards and Maintenance
Requirements
§60.13 Monitoring Requirements
Each of these sections gives important requirements
regarding the opacity and gas monitoring systems man-
dated for source categories addressed by the subparts.
These should be read in tandem with the subparts. For
example, §60.7 gives requirements for Part 60 sources
with installed CEM systems to submit excess emission
reports and describes the information that is to be
included in the report. In §60.8, requirements are given
for conducting performance tests to determine whether
the facility is within its compliance limits. Here, the
performance tests conducted are those reference test
methods of 40 CFR 60 Appendix A specified for the
source category (e.g. acid plant, electric utility) (U.S.
EPA 2020c).
Section 60.11 incorporates a requirement that has
been central to U.S. EPA stationary source regulatory
policy. This requirement [§60.11(d)] states:
At all times, including periods of startup, shutdown, and
malfunction, owners and operators shall, to the extent prac-
ticable, maintain and operate any affected facility including
associated air pollution control equipment in a manner con-
sistent with good air pollution control practice for minimiz-
ing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will
be based on information available to the Administrator
which may include but is not limited to, monitoring results,
opacity observations, review of operating and maintenance
procedures, and inspection of the source.
This policy, formulated in the early 1970s, is reprised
in the compliance assurance monitoring and credible
evidence rules that resulted from congressional concerns
addressed in the 1990 Clean Air Act Amendments (which
is discussed below).
Section 60.13 incorporates important requirements
for Part 60 CEM systems. This section is sometimes for-
gotten after a CEM program has been implemented, but
nevertheless, contains essential program requirements.
Among these requirements are given as follows:
• Performance Specification Tests. Part 60 installed
systems must show that they meet performance
specifications of 40 CFR 60 Appendix B (U.S.
EPA 2020d) by conducting a performance specifi-
cation test (Note: “performance specification tests”
are used to certify CEM systems and are not the
same as the “performance tests” of §60.8 conducted
to determine source compliance with emission
limits).
• Quality Assurance Requirements. In the absence of
other quality assurance requirements, as a mini-
mum; the system must conduct a zero and span drift
check once every 24 hours, zero and span adjust-
ments must be made if the drift exceeds twice the
value of the drift performance specification of
Appendix B, and the zero and span check proce-
dures must be written.
• Representativeness. All CEM systems are to be
installed such that measurements representative of
actual emissions are obtained.
• Alternative Performance Test Requirements. An
alternative to conducting reference method tests
for determining relative accuracy may be requested
if the pollutant emissions are less than 50% of the
emissions limit (60.13(j)(1)). When applicable, this
allows conducting a cylinder gas test (audit) (CGA)
instead of a relative accuracy test audit (RATA).
NESHAP, 40 CFR 61 The National Emission Standards
for Hazardous Air Pollutants (NESHAP), formerly
­legislated under Section 112 of the Clean Air Act, require
continuous monitoring for a limited number of sources

covered under Part 61 of Title 40. As in Part 60, general
monitoring instructions regarding notification, record-
keeping, etc. are given in the “general provisions” prior to
the source requirements. Few pollutants were regulated
under the NESHAP program due to uncertainties associ-
ated with risk assessments and scheduling mandates
(Mohin 1992). Source categories affected by this subpart
and monitoring requirements are discussed further in
Chapter 13 on monitoring hazardous air pollutants.
The Air Toxics Program, 40 CFR 63 Title III of the 1990
Clean Air Amendments replaced the previous NESHAP
program. Title III identified 189 hazardous air pollutants
(HAPs) (later reduced to 187), to be regulated for sources
emitting more than 10 tons/year of any one listed pollut-
ant or 25 tons/year of a combination of listed pollutants.
EPA has promulgated emission limits and engineering
standards for the principal sources emitting HAPS (or “air
toxics”). The sources must apply “maximum achievable
control technology,” where MACT technology is the best
control achieved in practice by 12% of the best controlled
similar sources. However, MACT encourages process
changes or other pollution prevention activities rather
than the application of control equipment.
The air toxics, or “MACT standards,” also incorporate
monitoring requirements to determine, on a continuous
basis, whether emission limits are being met. Most MACT
standards require parameter monitoring, in other words a
“continuous parameter monitoring system (CPMS)” that
is described in a “monitoring plan,” rather than the instal-
lation of CEM systems. However, where control devices
are used that can be effectively monitored, such as carbon
adsorbers and incinerators, CEM systems are either
required or suggested as an alternative to parameter mon-
itoring. The Part 63 Subparts give the emissions standards
and monitoring requirements for HAPs emitted from
174 listed industries. Rather than requiring the monitoring
of specific pollutants from the list of 187 HAPs, the use of
surrogate analyzers is often allowed (such as a particulate
monitor to monitor metal emissions or a total hydrocar-
bon monitor rather than a speciating instrument). Sources
required to monitor HAPs and methods used to measure
them are discussed further in Chapter 13.
Compliance Assurance Monitoring (CAM) 40 CFR
64 The compliance assurance monitoring program
(CAM) was initiated from a congressional requirement
included in the 1990 Clean Air Act Amendments (§702
(b) of the amendments). This amendment to Section 114
of the Clean Air Act states:
The Administrator shall in the case of any person which is
the owner or operator of a major stationary source, and
may in the case of any other person, require enhanced
monitoring and submission of compliance certifications.
IMPLEMENTING RULES IN THE UNITED STATES 19
Compliance certifications shall include (A) identification
of the applicable requirement that is the basis of the certi-
fication, (B) the method used for determining the compli-
ance status of the source, (C) the compliance status of the
source, (D) whether compliance is continuous or intermit-
tent, (E) other such facts as the administrator may require.
The amendment addressed the concern of Congress
that the compliance status of most emission sources was
determined only periodically by conducting manual
stack tests. It was viewed that since source operations
may be highly tuned during such testing, operations may
not necessarily be representative of day-­to-­day perfor-
mance. Congress gave EPA the task to devise a strategy
that can assure Congress (and the public) that emissions
standards and limitations are being met continually, not
just intermittently.
The Compliance Assurance Monitoring (CAM) rule
was developed as a response to the requirement that
essentially places the burden back upon the source. The
CAM rule applies to sources required to obtain a Part 70
or 71 air permit and having emission units with active con-
trol devices, whose potential pre-­control device emissions
are at or above the emission thresholds that define a
“major” source (such as 100 tons per year). Affected
sources are to develop a “CAM Plan” that will provide
assurance to the agency that they are meeting their emis-
sions limitations (Neulicht et al. 1996). The CAM plan
provides for the recording of work practice procedures,
equipment monitoring, and inspection procedures related
to pollution control compliance. CEM systems that meas-
ure pollutant emissions directly or by parameter monitor-
ing techniques that provide indirect determinations may
also be used. A guidance document on how to write a plan
has been prepared by the U.S. EPA (OAQPS 1998).
Methods incorporated into the plan are to specify
indicator ranges, within which the emission source is
assumed to be in compliance. The range may be simply a
range of pollutant concentration, or a range of pressure
drops, temperatures, voltage settings, fuel flow, gas flows,
and so on. Exceeding the range then triggers a require-
ment for initiating corrective action.
The CAM program emphasizes the use of plant sen-
sors and parameter monitoring techniques to avoid the
installation of CEM systems. This was due to public com-
ment on an earlier “enhanced monitoring” rule intended
to meet the requirements of §702 (b) of the 1990 CAA
amendments. This earlier rule, viewed as a “CEM rule,”
was withdrawn, due in part to outcry over assumed CEM
system costs. However, the costs associated with develop-
ing CAM plans, modifying plans when plant operations
change, and reporting parameter data may ultimately be
comparable to the cost of CEM systems and process
monitors. If a CEM system is already installed for compli-
ance monitoring through a permit, NSPS, or other
requirement, additional monitoring is not required.
20 CEM REGULATIONS
Acid Rain Program (40 CFR 75) The EPA acid rain
program was the most significant program for CEM sys-
tem implementation and development since the promul-
gation of the NSPS requirements in the 1970s. The program
was responsible for the installation of over 2000 CEM sys-
tems in the electrical utilities in a relatively short period of
three years. As a result of the program, dilution extractive
systems were popularized in the United States, flow moni-
tors were applied widely, and CEM system data acquisi-
tion systems improved markedly. Also, CEM systems
achieved respectability. Being necessary to support the
structure of the acid rain program, CEM system operation
and performance came under supervision by engineers
who report to upper management levels.
The acid rain program was established through Title IV
of the 1990 Clean Air Act and is codified in Parts 72-­75 of
Title 40 of the Code of Federal Regulations (U.S.
EPA 2020f). Parts 72–74 deal with the programmatic issues
of allowance trading, whereas Part 75 addresses the con-
tinuous emission monitoring requirements that support
the program. The acid rain program is a “trading program”
where the trading commodity is the “allowance.” An
allowance is a trading permit, corresponding to the right
to emit one ton of pollutant such as SO2, NOx, or CO2 in
any year. In the program, an affected facility must be in
possession of the exact number of allowances correspond-
ing to its annual emission of SO2 in tons per year. If a coal-­
fired power plant emits 30 000 tons per year of SO2, it
must have 30 000 allowances. If it has only 20 000 allow-
ances, it must either reduce emissions by 10 000 tons dur-
ing the year or it must purchase allowances to make up the
difference. Allowances may be purchased, sold, banked,
auctioned, or otherwise treated as negotiable securities.
The acid rain program differed from previous federal
programs by applying to both existing and new electrical
Plant A Plant B
Tons
100
50
Reduction 50 Tons Reduction 70 Tons
20 Allowances Traded
Figure 2-4 Trading allowances.
utilities greater than 25 MW capacity. In a trading pro-
gram, a set number of allowances are initially issued to
facilities affected by the program. To reduce emissions by
50%, only one-­half of the allowances necessary to cover
annual emissions were provided by EPA. From SO2
emissions level of 17.5 million tons annual emissions, in
1980 for the electric utilities, only 8.9 million allowances
were distributed. When fully implemented by 2010, SO2
emissions were expected to be approximately halved.
In contrast to “command and control” programs where
certain control equipment or operating conditions are
mandated, in trading programs a facility can choose how
to comply with the rule. For example, a facility could add
an SO2 scrubber to reduce emissions; it could shut down
intermittently; it could burn lower sulfur fuels, switch fuels,
or buy allowances at auction, or could buy allowances
from a company that had “overcontrolled” its emissions
and had allowances to sell. This is illustrated in the exam-
ple of Figure 2‑4. In the example, each plant emits 100 tons
per year, but each plant is allocated only 50 allowances. To
meet their allowance requirements, the plants adopt dif-
ferent strategies. Plant A decides to burn low-­sulfur coal
and succeeds in reducing its emissions to 50 tons per year
to meet the 50 allowances it was allocated. Plant B decides
to install a wet scrubbing system and reduces its annual
emissions by 70 tons down to 30 tons. It has overcontrolled
its emissions, but now has 20 allowances available to sell.
Plant C is an older plant and finds it too expensive to
reduce its emissions by 50%. It decides to reduce them by
only 30% down to 70 tons per year. To meet its allowance
obligation at the end of the year, it then buys the 20 allow-
ances available from Plant B.
The advantages of a trading program are that a source
has choices instead of mandates and can change control
strategies without notifying the agency. A trading program
Total
Plant C emissions
Initial
300 Tons
After reductions
150 Tons
Reduction 30 Tons

also changes the character of environmental management
from spending money for compliance to possibly profiting
by controlling its emissions more than it is required.
Additionally, the similarity of an “allowance” to a “secu-
rity” is understandable to corporate management and
helps management to participate in a game with which it
may be more familiar. Here, a strategy’s success or failure
can be measured; and that measurement is made by CEM
systems.
Trading allowances requires a high degree of confidence
in the negotiable instrument, the allowance. To calculate
SO2 mass emission rates, the flue gas volumetric flow rate
must also be known. This is shown in Equation 2‑1.
pmrs cs Qs (2-­1)
where
pmrs = pollutant mass rate (kilograms per hour, tons
per year)
cs = pollutant concentration (milligrams per cubic
meter, pounds per cubic foot)
Qs = volumetric flow rate (cubic meters per hour,
cubic feet per hour)
s = subscript denoting “stack”
For coal-­fired plants, flow monitors are specified for
monitoring the flue gas volumetric flow. For gas-­and oil-­
fired plants, the fuel flow in conjunction with an O2 or
CO2 “diluent” monitor can be used instead, to calculate
the flue (stack) gas volumetric flow (see Appendix A).
Under the acid rain program, NOx emissions were not
traded, but instead regulated under lb/mmBtu emission
limits. Emissions are calculated using F-­factor methods,
where the emissions in lb/mmBtu are determined from
Equation 2‑2:
100
E cs Fc (2-­2)
%CO2
where
E = emissions in units of lb/mmBtu (or ng/J)
cs = NOx concentration
Fc = carbon dioxide F factor
Here, a NOx monitor and diluent monitor measuring
either CO2 or O2 are necessary to perform the calcula-
tion. F factors can be found in Table A‑2.
Since CEM systems are used to determine mass emis-
sion rates and, therefore, available allowances, it is essen-
tial that the CEM systems installed for this purpose meet
high levels of accuracy and precision. Consequently, EPA
established a new set of rules and performance specifica-
tions for CEM systems in 40 CFR 75, increasing the strin-
gency of monitoring requirements from those originally
promulgated in the New Source Performance Standards
of 40 CFR 60 (U.S. EPA 2020g). As a result, CEM ­systems
IMPLEMENTING RULES IN THE UNITED STATES 21
essentially became the “gold standard” by which the pro-
gram operated. Because of the importance of the pro-
gram and its potential costs, utility managers purchased
new CEM systems, assigned engineers to oversee the
monitoring programs, and provided financial and staff
resources for their operation and maintenance. This led
to a new generation of CEM systems and a new genera-
tion of CEM professionals. Close cooperation between
utility professionals, regulators from the EPA Clean Air
Markets Division (CAMD), and CEM system vendors
contributed greatly to the overall success of the program
(Schakenbach and Forte 2006).
Because of the more stringent monitoring require-
ments and incentives, Part 75 CEM systems typically
achieve relative accuracies of <5%, in contrast to the min-
imum specification of <20% in Part 60 and <10% in Part
75 (Mangus 1997). Some utility managers initially
installed redundant systems, concerned that CEM system
downtime would incur allowance penalties. However, by
instituting effective quality assurance programs and
maintenance practices, availabilities of >98% became
typical, negating the need for redundant systems, which
were mostly removed and kept as spares. The key to these
successes was in management providing the support and
resources necessary to assure that the CEM data would
be sufficiently accurate to back the allowance trades,
where financial considerations could be substantial.
Allowance prices were relatively stable for about 10
years, hovering from approximately $150 to $200 per
allowance from 1994 to 2004. Due to changes in regula-
tory policies (beginning with the Clean Air Interstate
Rule and ending with the Cross-­State Air Pollution Rule),
the closure of older coal-­fired facilities, and the increased
usage of natural gas (which contains little sulfur), the mar-
ket has essentially crashed, where SO2 allowances are
readily available and are priced today at less than $1.
However, the acid rain program led to a decrease in SO2
emissions in the power sector from 15.7 million tons per
year in 1990 to below 1 million tons in 2019 (Figure 2‑5).
The acid rain program succeeded in meeting and
exceeding its original program objectives sooner than
mandated. However, factors other than trading also
contributed to the program’s success (Schmalensee and
Stavins 2013, 2015). The availability of low-­sulfur coal
from Montana and Wyoming, the means to transport
coal across the West and Midwest, and emergence of
natural gas as an alternative fuel to coal led to SO2
reductions that were not originally anticipated.
Regardless of how the reductions were achieved, the
constant factor in the program was highly accurate, reli-
able emissions data provided by the installed CEM sys-
tems. Accurate CEM data allowed the utilities to “keep
score” with confidence, to weigh their operational and
control options to cost-­effectively meet their regulatory
obligations (Schreifels and Napolitano 2014).
The acid rain program serves as a template for other
cap-­and-­trade programs, which is well documented by
22 CEM REGULATIONS

18

Sulphur dioxide emissions (short tons)

16

14

12

10

1990 1995 2000 2005 2010 2015 2020

Year

Figure 2-5 U.S. utility sector SO2 emission reductions 1990–2019.

Schakenbach and Forte (2006). As viewed by Market (RECLAIM) in California (discontinued),

Schakenbach et al., it is necessary that the monitoring and the Houston-­Galveston HROVC (Highly Reactive
and reporting procedures of the program be supported Organic Compound) cap-­ and-­trade program. In
by effective quality control and quality assurance Canada, the province of Ontario has instituted a trad-
requirements. These requirements were at the time ing program for SO2 and NOx (Government of
unique for a CEM regulatory program, incorporating Ontario 2020b).
elements such as the following: Trading programs have also been established for the
control of greenhouse gases. In the United States, the
1. An implemented/effective CEM QA/QC plan Western Climate Initiative (WCI) in California (with
2. Incentives for good performance Quebec as a partner) and the Regional Greenhouse Gas
3. Penalties for poor performance Initiative (RGGI) in the northeastern states. A U.S.
Federal greenhouse gas trading program had been con-
4. Standardized electronic reporting formats and
sidered at one time, but no longer appears likely due to
procedures
political polarization regarding climate change issues.
5. Electronic audits and data quality checking
software
6. Targeted and random field performance and sys- Mandatory Greenhouse Gas Reporting Program (40
tem audits CFR 98) Forty-­two source categories, ranging from sta-
7. Flexibility for special circumstances and technical tionary fuel combustion sources to electronics manufac-
issues turing, emitting more than 25 000 metric tons of CO2e per
8. Vigorous enforcement year are required as per 40 CFR 98 to report greenhouse
gas emissions. Monitoring methods are specified in each
These elements are further detailed in the Part 75 of the 42 subparts; however, sources subject to Part
Subpart A – General Provisions (U.S. EPA 2020f). The 75 where CO2 monitors are already installed must use
Part 75 CEM requirements, for installation and certifica- CEM system data for reporting. Hazardous waste incin-
tion, are found in Part 75 Appendix A (U.S. EPA 2020g), erators with installed CO2 monitors must similarly report
and quality assurance and quality control requirements emissions using CEM system data. However, for most
are given in Appendix B (U.S. EPA 2020h). Other docu- source categories, the reporting rule does not require the
ments such as EPA’s Plain English Guide to the Part 75 installation of continuous emission monitors, but allows
Rule (U.S. EPA 2009), the Part 75 Emission Monitoring the use of production data and emission factors instead.
Technical Q and A document (U.S. EPA 2013), and the Subpart C of Part 98 applies to stationary sources that
Part 75 CEMS Field Audit Manual (U.S. EPA 2003) are combust fossil fuels. Here, a tier approach is taken, where
helpful in clarifying details of the Part 75 requirements. each successive tier requires more measurements and
The success of the acid rain program encouraged the application of fewer emission factors, with the
other cap-­and-­trade programs such as the EPA NOx assumption that the higher the number of the tier, the
Budget Program, the Regional Clean Air Incentives higher the accuracy of the reported data. As an example

of the use of emission factors, in Tiers 1 and 2, CO2
emissions are calculated from the following equation:
CO2 1 x 10 3 Fuel x HHVd x EF (2-­3)
where
CO2 = annual CO2 mass emissions (metric tons) for a
particular type of fuel
Fuel = quantity of fuel combusted during the year
(tons, scf, gal)
HHVd = default (Tier 1) or measured (Tier 2) high
heating value of fuel (mmBtu per quantity of fuel)
EF = fuel-­specific default CO2 emission factor (kg
CO2/mmBtu)
Tier 3 applies to sources larger than 250 mmBtu that
have not been required to install a CEM system. In this
tier, sources are required to monitor fuel use and the car-
bon content of the fuel instead of the fuel’s high heating
value. CEM systems are used for Tier 4 reporting, where
annual emissions are calculated as a pollutant mass rate
times operating time. Methane and nitrous oxide emis-
sions are reported using default emission factors for CH4
and N2O in Equation 2‑3. The CH4 and N2O calculate
emissions data are combined with the CO2 data to report
greenhouse gas emissions as CO2e, carbon dioxide
equivalents.
Greenhouse gas issues and reporting procedures are
discussed in greater detail in Chapter 14.
Office of Solid Waste CEM Requirements (40 CFR
266) Through the authority of the Resource
Conservation and Recovery Act (RCRA), the EPA
Office of Solid Waste requires CEM systems to be
installed for incinerators designed to burn hazardous
waste and for boilers and industrial furnaces (“BIF”
sources) that burn hazardous wastes as supplemental
fuel under 40 CFR 266 (U.S. EPA 2020i). This program
under RCRA is delegated for management by the states.
For hazardous waste incinerators, initial trial burns of
hazardous pollutants are used to set operating criteria
for the facilities. In many permits, the CEM system is
tied into the operating system, where feed is cut off if
CO or THC levels exceed the established trigger levels,
or if the O2 concentration decreases below the estab-
lished limits. This is done, in part, to address the public’s
concern regarding emissions from such facilities.
BIF continuous emission monitoring requirements
are found for CO in 40 CFR 266 §266.104(b)(2) and
hydrocarbons (HC) in [§266.104(c)((3)]. In the BIF rules,
performance specification for CO analyzers are given in
Part 266 Appendix IX §2.1 and for hydrocarbon analyzers
in §2.2. The performance specifications for CO are
IMPLEMENTING RULES IN THE UNITED STATES 23
similar to those given in 40 CFR 60 Appendix B
Performance Specification 4a. A relative accuracy test is
not required for Part 266 hydrocarbon analyzers.
Quality assurance requirements for Part 266 CO and
HC monitoring systems are found in Appendix IX of
Part 266, where daily calibration checks, daily system
audits, quarterly calibration error (linearity) tests, and an
annual performance specification tests are required.
Conducting an annual performance specification test for
the CO monitoring system implies that a seven-­day cali-
bration drift test, in addition to a response time test and
a RATA, would be required, in contrast to Part 60
Appendix F where only an annual RATA is required
(U.S. EPA 2020e).
Monitoring requirements have also been promulgated
for hazardous waste combustors under the MACT stand-
ards of 50 CFR 63 Subpart EEE. Section 63.1209(a) (ii)
requires that either a CO or hydrocarbon analyzer be
installed, along with an oxygen monitor, to report emis-
sions corrected to 7% O2. Cement kilns burning hazard-
ous waste are also required to install a continuous opacity
monitoring system (COMS).
Sewage Sludge Incineration (40 CFR 503) EPA reg-
ulations concerning sludge management programs are
found under Title 40 Subchapter O – Sewage Sludge and
Part 501: State Sludge Management Program Regulations.
Regulatory authority is given under the Clean Water Act,
which requires that states must develop sludge manage-
ment programs. Part 501 specifies the requirements that
a State program must meet for it to be approved by EPA.
Sewage sludge can be disposed of in a solid waste land-
fill, applied to the land, or incinerated. For landfill or
land applications, limits for metal concentrations, load-
ing levels, and pathogen density are specified.
Monitoring requirements for incineration of sewage
sludge are given in Subpart E of 40 CFR 503 – Standards
for the Use or Disposal of Sewage Sludge If the sludge is
incinerated, the concern shifts from releases to the soil
and groundwater to the efficiency of combustion and
releases to the air. Total hydrocarbons are required to be
monitored as specified in §503.45(a)(1) of the Code. In
addition, the carbon monoxide concentration must be
monitored as an indicator of combustion efficiency,
where a limit of 100 ppm corrected to 7% O2 and zero
percent moisture is specified. Total hydrocarbon concen-
tration is similarly limited to 100 ppm corrected to 7%
O2 and zero percent moisture. Accordingly, an oxygen
concentration monitor and an instrument used to deter-
mine the moisture content must also be installed to mon-
itor the stack exit gas continuously along with the THC
and CO analyzers. No other requirements are given for
the monitoring system and analyzers, other than that a
calibration and maintenance logbook shall be retained
[40 CFR 503.47(n)]. Design and operational requirements
24 CEM REGULATIONS

are specified for the total hydrocarbon analyzer, where it
must use a flame ionization detector (FID), be calibrated
with propane, and have a heated sampling line main-
tained at a temperature of 150 °C.
New sewage sludge incinerators are also regulated
under New Source Performance Standard Subpart O if
the incinerator was constructed after 11 June 1973. The
regulation requires the installation of an oxygen analyzer
only. Here, the instrument specifications require a ±5%
relative accuracy as certified by the manufacturer and a
calibration every 24 hours according to manufacturer
procedures. No reference is made to the Part 60 Appendix
B or Appendix F CEM requirements, which are more
complete.
have less stringent programs, accept EPA NSPS delega-
tion for regulating new sources and have adopted mini-
mum requirements for existing sources. Different types
of programs delegated or otherwise employed by the
states, where CEM system installations may be required,
are listed in Table 2‑2.
By applying established regulatory procedures, CEM
systems can also be required to be installed on other
source categories or used directly for compliance. The
development of such regulations typically proceeds
through public hearings, combined with many approval
processes. Under these procedures, it can often take sev-
eral years before a regulation is issued.

State Implementation Plan Requirements (40 CFR 5l)

State Programs and Federal Programs
Administered by the States
State environmental control agencies are tasked with
federal requirements to meet ambient air standards for
SO2, NOx, ozone, and particulate matter as PM2.5. The
states receive federal funding for this purpose and insti-
tute programs to monitor ambient air concentrations of
these ambient pollutants. Ambient air monitoring shel-
ters housing analyzers that use many of the same analyti-
cal techniques as CEM systems are located across the
country, providing a continuous assessment of ambient
air quality.
A number of regulatory mechanisms can be used by
the states to require the installation of CEM systems as
a tool in meeting their goals. Because of the differences
in state agency regulatory policies and work-­force capa-
bilities and limitations, CEM programs vary greatly
between the states. Several states have very stringent
programs, based on CEM compliance monitoring for
enforcement and public assurances. Other states, which
Each state is required by the U.S. Clean Air Act to have
a State Implementation Plan, or SIP, that will lead to the
improvement and maintenance of the air quality such
that all areas of the state will meet national ambient air
quality standards. Federal requirements for SIPs are
given in 40 CFR 51 – Requirements for Preparation,
Adoption, and Submittal of Implementation Plans and 40
CFR 52 – Approval and Promulgation of Implementation
Plans (U.S. EPA 2020b).
Part 51 Appendix P – Minimum Requirements for
Existing Sources. In Appendix P of Part 51, the U.S. EPA
established minimum CEM requirements for existing
sources (U.S. EPA 2020a). The rules, published in the
1970s, required state CEM requirements to be written by
1976 for only four source categories: fossil-­ fuel-­
fired
steam generators, sulfuric acid plants, nitric acid plants,
and petroleum refineries. Even so, these particular mini-
mum requirements only applied to larger sources and
allowed many exemptions, such as not requiring SO2
monitoring unless SO2 control systems are installed. The

TABLE 2-­2 State CEM Program Options

Federal Programs Delegated to States
Compliance
SIP Permit NSPS SIP Assurance Waste Trading Discretionary
Rulemaking Programs Delegation Rulemaking Monitoring Incineration Programs Programs
Part 62
Part 51 Parts existing Court
Part 52 70 & 71 Part 60 sources Part 64 Part 266/503 Actions
Utilities Major NSPS categories Hazardous Major Hazardous CSAPR Variances
Pet. Ref. sources (Table 2‑1) waste sources waste WCI (CA) orders
HNO3 incinerators/ incinerators/ RGGI (NE agreements
H2SO4 sewage sludge sewage sludge States)
incineration incineration HRVOC
PSD (TX)
NSR
 IMPLEMENTING RULES IN THE UNITED STATES 25

“existing sources” referenced in Part 51 were those built the source must monitor mass emissions in tons per year
before 1971, many of which are no longer operating by of any pollutant designated under the New Source
having become subject to reclassification as a “new Review program for at least five years.
source” after modification, or are otherwise subject to
acid rain, air toxics, and other rules written after promul-
gation of the 1990 Clean Air Act Amendments. Once in 40 CFR Part 62 – Federal Requirements for
the Code of Federal regulations, rules, test methods, and Existing Units Not Covered by a State Plan
procedures tend not to go away. They layer upon them-
Part 62 gives requirements for existing sources that are
selves; so, when reading them, attention must be paid to
not regulated by a state or tribal plan. The Subparts of
applicability and other conditions of the requirements.
Part 62 give Federal plans that can be delegated to the
Part 52 – Approval and Promulgation of implementa-
states for implementation by existing stationary sources.
tion Plans Part 52.21 – Prevention of Significant
The applicable plan must be included in the Title V
Deterioration (PSD) For any source or a major modifica-
Permit for the affected source. Part 62 addresses a variety
tion to an existing source, located in an attainment area,
of incineration facilities listed in Table 2‑3. For a number
where ambient air standards are met, a PSD permit must
of the sources, options are offered for using CEM sys-
be granted. Once an area is in attainment, it is possible
tems instead of periodic performance testing.
that the construction of a new source or modification of
an existing source could lead to “significant” emissions
that bring the area into nonattainment. To avoid this pos-
40 CFR Part 70 – Title V Operating Permits
sibility a permit must be obtained by the source prior to
the construction or modification. It must be shown Congress established the Title V Operating Permit
whether a significant increase of emissions will occur, Program under the 1990 Clean Air Act Amendments.
through a technical analysis and an air quality modeling, Under the program, major sources are required to obtain
as specified in Part 52.21. One of the requirements of operating permits, operate in compliance with the per-
Part 52.21 is that the after construction or modification, mit, and certify annually that they are in compliance with

TABLE 2-­3 Summary of 40 CFR 62 Monitoring Requirements for Existing Units Not Covered by an Approved and Effective
State or Tribal Plan
Part 62 Effective CFR Monitoring
Source Category Subpart Affected Units Datea,b CEM Requirements Reference
Large municipal waste FFF > 250 tpd Constructed Opacity 62.14105
combustion units before 9/20/94 As per 62.14109
40 CFR 60.8b 60.58b
Subpart Eb
Hospital/Medical/ HHH Large Constructed Options for 62.14452
Infectious Waste Medium before 12/1/08 SO2, NOx, CO, HCl, O2, D/F,
Incinerator Small PM CEMS, Bag leak
(HMIWI) Small Rural detector
Commercial and III Combustion Constructed Bag leak detector if FF 62.14690
Industrial solid Units before 11/30/99
waste Incinerators
(CISWI)
Small municipal waste JJJ >35 tpd < 250 tpd Constructed Opacity 62.15170
combustion units before 8/30/99 SO2, CO 62.15175
4/6/10a NOx (Class 1)b
O2 or CO2
Sewage sludge LLL Combustion units Constructed Bag leak detector if FF 62.15960
incineration units before 10/04/10 Options for 62.15980
SO2, NOx, CO, HCl, O2 or 62.16015
CO2, D/F
a
Modification began before this date
b
Units > 250 tpd capacity
26 CEM REGULATIONS
the permit requirements. Most permits are issued by
state and local agencies following the requirements of
40 CFR Part 70. Federal permits can be issued following
40 CFR Part 71.
States issue operating permits for both existing and
new stationary sources.
An operating permit may include conditions that
require the installation of CEM systems. States may pre-
pare rules for existing sources that are more stringent
than those promulgated by the federal agency
(Kerstetter 1985). As a result, the stringency of state
CEM rules may extend beyond those established for
similar sources regulated under NSPS. Monitoring of
gases such as HCl or volatile organic compounds may be
required, or process cutoffs for excess emissions or real-­
time telemetry may be required in the permit. Sources
often agree to very stringent CEM requirements to expe-
dite approval of the operating permit.
Federal Programs Delegated to the States Most
states have received delegation by the U.S. EPA to regu-
late the emission sources affected by the following fed-
eral rules:
• Part 60 New Source Performance Standards
• Part 64 Compliance Assurance Monitoring.
• Parts 266 and 503 Hazardous and Municipal Waste
Incineration
In implementing these programs, states have developed
regulations to assure that affected sources have installed
required CEM systems, to see that they are properly certi-
fied, and to receive and process excess emission reports
and compliance data as required by the applicable rule.
Part 96 Cross-­State Air Pollution Rule (CSAPR) The
Cross-­State Air Pollution Rule, of 40 CFR 96, evolved
from the Clean Air Interstate Rule (CAIR) and the NOx
Budget Program (NBP). After the promulgation of Part
75 and the implementation of the acid rain program, sig-
nificant progress was made in reducing SO2 and NOx
emissions. However, even with 50% reductions in SO2
and NOx emissions, critical load was not being reached.
“Critical load” is the level of emissions below which
harmful effects to the environment do not occur. Studies
indicated that reductions on the order of 75% on top of
the previous 50% reductions would be necessary for SO2
and NOx to meet ambient air standards for ozone and
particulate matter, as well as reaching critical load
requirements for acid rain. In the East, it was felt that
part of the problem was due to the interstate transport of
pollutants from the western to eastern parts of the
United States. Thus, began the saga of rulemaking that
extended from the NOx Budget Trading Program, to the
Clean air Interstate Rule, and to the Cross-­State Air
Pollution Rule, which is in effect today.
The NOx Budget Program (NBP) To reduce the regional
transport of ozone in the Northeastern United States, the
U.S. EPA instituted a NOx control program, known as the
NOx Budget Program, which was operated by the 20 east-
ern states plus Washington DC. The trading program
began in 2003 and was discontinued in 2008. In the pro-
gram, NOx emissions were capped for affected sources
and NOx allowances were traded between sources under
the program rules during the summer ozone season. The
NOx Budget Program differed from the acid rain program
in that it was administered by the states under State
Implementation Plans, whereas the acid rain program is
administered directly by the Federal EPA. In addition to
the electric utilities, sources such as cement plants, petro-
leum refineries, and pulp and paper mills also participated
in the program. The U.S. EPA provided guidance through
the requirement of 40 CFR 96 to achieve consistency
between the state programs (U.S. EPA 1998).
As in the acid rain program, an essential program
component was the determination of the yearly NOx
mass emissions. CEM systems incorporating NOx moni-
tors, flow monitors, diluent gas monitors, and a DAHS
provided the basis for these determinations. Because
CEM systems for SO2 and NOx had already been
installed on fossil-­fuel electric generating units and other
sources in the Part 60 and Part 75 programs, the primary
impact on their monitoring requirements was in modify-
ing CEM system software to accommodate the NOx
Budget reporting requirements. NOx Budget CEM sys-
tem certification and performance requirements refer-
enced those of Part 75.
The Clean Air Interstate Rule (CAIR) The NOx Budget
Program was replaced by the Clean Air Interstate Rule
in 2009 although the rule had been issued originally in
2005. The rule extended the NBP affecting 27 states plus
Washington DC. CAIR included three interstate cap-­
and-­trade programs: (i) the CAIR SO2 trading program,
(ii) the CAIR NOx annual trading program, and (iii) the
CAIR NOx ozone season trading program. About 70%
of the CAIR NOx ozone season units used CEM systems
to measure NOx emissions (U.S. EPA 2010, 2014b).
Lower-­cost monitoring alternatives were used for low-­
emitting and infrequently operating gas and oil units.
After a training year in 2008, the CAIR NOx ozone
season and NOx annual programs began in 2009 and the
CAIR SO2 program in 2010. This was after several court
challenges that resulted in CAIR being vacated by the
D.C. Court of Appeals in 2008, but remanded back to
EPA until new rules could be developed to replace the
program. CAIR was eventually replaced by the Cross-­
State Air Pollution Rule (CSAPR), which was proposed
in 2011, but was not implemented until 2015.

The Cross-­ State Air Pollution Rule (CSAPR) The
Cross-­State Air Pollution Rule was proposed in 2011 as a
replacement for CAIR, but was in turn vacated by the
D.C. Circuit Court of Appeals in 2012 after judicial
review. The U.S. Supreme Court reversed the decision of
the Court of Appeals in April of 2014 and the stay was
lifted in October 2014. Phase I of CSPAR began on
1 January 2015, but an update to the rule (the CSAPR
Update) was finalized in September 2016.
CSAPR differs from CAIR in its level of stringency
and trading restrictions. In CSPAR, allowance allocations
are reduced from those in CAIR, and interstate trading is
restricted. Despite the legal issues and shifting bases of
the NOx control programs, using cap-­and-­trade policies
as a tool, they have been successful in decreasing NOx
emissions below the original target levels (Shouse 2018).
Ultimately, this history is not important to the CEM
engineer, particularly since CEM requirements, based
on Part 75, were not affected by the judicial issues. In
the end, with the addition of control equipment and the
increasing availability of natural gas over the decade,
the electric utilities were able to meet NOx emission
limitations.
Other Cap-­and-­Trade Programs A number of other
cap-­and-­
trade programs have been initiated by the
states. In California, the 1994 Regional Clean Air
Incentives Program (RECLAIM) was one of the first
programs to be implemented by a state (Lents and
Leyden 1996). It established emission reduction targets
for SO2 and NOx, along with detailed protocols similar
to those of Part 75. RECLAIM was discontinued in
2018; however, California currently participates in a
Western Climate Initiative (WCI) CO2 trading pro-
gram. The northeastern U.S. states participate in the
Regional Green House Gas Initiative (RGGI) CO2
trading program.
A local trading program is active in the Houston-­
Galveston area, where the numerous petroleum refin-
eries and chemical companies have made it difficult to
meet ambient air standard for ozone. Here, the “Highly
Reactive Volatile Organic Carbon (HRVOC)” cap-­
and-­trade program requires the continuous monitor-
ing of speciated volatile organic compounds, precursors
to ozone formation. Flares, process vents, cooling
towers, and fugitive emissions are affected by the
­ to meet the purposes of the implementing rule.
program.
Discretionary Programs Actions such as issuing per-
mits give an agency a great deal of flexibility for achiev-
ing its goals. The ability of an agency to incorporate
continuous monitoring requirements as part of these
actions is within the agency’s “discretionary authority.”
Discretionary programs include:
PERFORMANCE SPECIFICATIONS 27
Variances. Under special circumstances, a temporary
authorization, called a variance, may allow a source to
discharge pollutants in excess of the standard that would
normally apply. A variance is generally issued for a spe-
cific time period, requiring that the source correct the
problem and meet the standard by the end of the period.
Special monitoring requirements are often included in
the provisions of such variances.
Orders. Orders to comply with state agency require-
ments can be issued to a source under the enforcement
authority given in Section 113 of the Clean Air Act.
There are several types of orders: administrative orders,
delayed compliance orders, and court orders. These
orders differ with respect to the type of legal authority it
takes to issue them.
Agreements. Agreements are often a result of bargaining
between an agency and a source. Again, the purpose of
any agreement is for the source to come into compliance
with applicable regulations. As with orders, there are sev-
eral types of agreements, each differing with respect to
the level of authority or legal action exercised. Consent
decrees, stipulation agreements, and court settlements
are found in this group.
The use of discretionary authority allows fairness to
be applied in regulatory programs. For example, a
source may be able to gain time to install new control
equipment by agreeing to the installation of a compli-
ance CEM system. However, state discretionary
authority can also result in arbitrary regulation since it
does not have the extensive public oversight that rule-
making does.
PERFORMANCE SPECIFICATIONS
To this point, we have discussed implementing rules for
CEM systems, rulemaking requiring the installation of a
CEM system on a source category or a specific unit of a
source. The implementing rule, however, is not complete
unless it refers to some procedure that can be used to
verify that the installed CEM system can provide data at
a specified level of accuracy and precision. The level of
accuracy can vary with the rule, depending upon the pol-
lutant and the purpose of the rule. However, some verifi-
cation procedure must be established so that the installed
system can be shown to provide emissions data suitable
In the United States, the verification or certification
procedures established for CEM systems are given in
standards called “performance specifications.” The per-
formance specifications include requirements for the
installation, design, performance, and testing of CEM
systems. The installation criteria are regulatory guide-
lines for identifying measurement locations where repre-
sentative measurements can be expected. Design
specifications require that the instruments must be
28 CEM REGULATIONS
designed in a certain manner. These are important and
specified in detail for opacity monitors, but are minimal
for gas monitors.
The specifications for the performance of the moni-
toring systems are the most important part of these
standards (except for opacity monitors, where the design
specifications predominate). Specifications are given for
drift, relative accuracy, and, in some cases, linearity.
Basically, the design of a gas monitoring system is not
relevant to the specifications. It does not matter whether
the system is extractive or in-­situ or if the method of
measurement is electro-­ optical or electrochemical. It
does matter, however, how the system performs. The
proof of a system is in its performance as installed. The
performance specification test procedures are applied to
demonstrate that the installed CEM system meets “per-
formance specifications.” If a CEM system meets these
specifications, it is considered capable of providing qual-
ity data for the purpose of the implementing rule.
Sixteen sets of performance specification have been
established for pollutant and diluent gas flow and par-
ticulate monitoring systems for sources subject to the
New Source Performance Standards. Sources are
required to meet these specifications after an applicable
monitoring system has been installed or when otherwise
called out by a rule. The NSPS specifications are found in
Appendix B of 40 CFR 60. Other specifications are given
for other implementing rules, and the states may write
their own performance specifications (e.g. Pennsylvania
and California). The Code of Federal Regulations cita-
tions where performance specifications for other imple-
menting rules can be found are given in Table 2‑4.
As noted, EPA does not approve specific brands of
instrumentation or specific analytical methods (in the
case of gas monitoring) for source monitoring systems.
This is in contrast to the policy of approving specific
instrument models for continuous ambient air analysis.
The procedure of meeting performance specifications
provides latitude in continuous monitoring system design
TABLE 2-­4 Performance Specifications for U.S. EPA
Implementing Rules
Citation for Implementing
Originating Rule Performance
EPA Office Program Specifications
OAQPS NSPS 40 CFR 60 Appendix B
OAQPS Air toxics 40 CFR 63.8 monitoring
requirements
OAR-­ARD Acid rain 40 CFR 75 Appendix A
OSW Boilers and 40 CFR 266 Appendix IX
industrial
furnaces
OWM Sewage sludge 40 CFR 503 Subpart E
incinerators
and application by allowing sources to handle individual
monitoring problems. Since stack conditions vary from
plant to plant, a CEM system found to work well at one
plant may not work at another. Vibration, heat, or other
conditions may necessitate a careful analysis of available
monitors and systems before one can be chosen for the
job. The performance specifications define the proce-
dures to be used for checking the installed instrument’s
performance. It is the installed instrument system, oper-
ating on the stack, that is approved, not the model.
U.S. CEM system certification procedures differ
from those instituted in the European Union, where
CEM system analyzers must undergo “type” testing,
both in the laboratory and field, to show that they meet
the design and performance specifications of the EU
standard EN 15267. However, it has been found that a
CEM system accredited under EN 15267 does not nec-
essarily guarantee that it will pass a U.S. Performance
Specification Test after installation.
QUALITY ASSURANCE REQUIREMENTS
The earliest applications of CEM systems in the 1970s
were often met with frustration. Systems were installed
and certified, but over a period of time began to fail.
Either inconsistent data or no data would be generated.
Often, the monitoring systems behaved so poorly that
the data would not be accepted by control room opera-
tors. The problem was not so much in the instrumenta-
tion itself, but in misconceptions in how the systems
operated. CEM systems were viewed as just another
plant sensor, such as a thermocouple or pressure
gauge – once installed, it would be expected to function
for an extended period of time; failure could be cor-
rected by a simple replacement. CEM systems, how-
ever, are more complicated than sensors. If not serviced
periodically, serious corrosion and plugging problems
can result, which can lead to a breakdown of the system.
Failures cannot always be corrected through simple
replacement, but instead may require expensive repairs
and recertification.
The realization came quickly that in order to continue
operating, a CEM system must be maintained continu-
ally (Jahnke 1986). Periodic inspections, a preventive
maintenance program, and performance assessment pro-
cedures are all necessary for a CEM system to provide
quality data on a continuing basis. These are the elements
of a quality assurance program.
A quality assurance (QA) program requirement
should be either part of an implementing rule or referred
to in an appendix, as are the performance specifications
in the NSPS requirements. QA requirements should
include the preparation of a QA manual that describes
the quality assurance and quality control procedures that
will lead to optimum data quality for the CEM

installation. Quality control procedures should detail the
calibration methods, preventive maintenance activities,
data back-­up procedures, and so on. Periodic audits such
as systems audits and performance audits mandated by
the regulatory agency should be part of the plan.
Performance audits that use independent audit materials
(e.g. calibration gases) or independent test instruments
are recommended for providing quantitative assess-
ments of data quality. Systems audits conducted by either
internal or external auditors provide an assessment of
whether the QA program has been implemented and is
operating effectively.
Part 60 Quality Assurance Procedures
Quality assurance programs were not required for CEM
systems in the implementing rules promulgated by EPA
in the 1970s and early 1980s. After the initial certification
was achieved by passing the performance specification
tests, no further testing was required, unless requested by
the agency for special circumstances. It was not until the
1980s that EPA proposed minimum quality assurance
procedures for SO2, NOx, and diluent monitoring sys-
tems in Appendix F to 40 CFR 60 (U.S. EPA 2020e). This
rule was promulgated in 1987 and is today known as
Procedure 1 of Appendix F. Other procedures were
added to Appendix F as continuous monitoring require-
ments extended to the measurement of other pollutants,
such as mercury and hydrochloric acid. However, quality
assurance procedures for opacity monitors were not pub-
lished until 2014 (U.S. EPA 2014a) although opacity moni-
tors have been required at certain facilities since 1973.
Other U.S. QA Procedures
QA requirements for acid rain Part 75 CEM systems
were promulgated along with the implementing rule and
are found in 40 CFR 75 Appendix B (U.S. EPA 2020h).
The requirements include procedures for SO2 and NOx
monitoring systems, O2 and CO2 diluent monitors, and
flow monitors. The flow monitoring procedures are espe-
cially important because none are given in Part 60
Appendix F. It is obvious from Equation 2‑1 that the flow
measurement is as equally important in pollutant mass
emission rate determinations as is the gas measurement.
The flow monitoring performance audit procedures such
as the “flow-­to-­load ratio test” and semiannual/annual
relative accuracy test audits are valuable, if not necessary
for assuring accurate flow measurements.
The acid rain program, NSPS, and air toxics monitor-
ing programs all include requirements for writing a
plant-­specific CEM QA plan and periodic performance
testing. Although Appendix F applies only to those NSPS
sources that use CEM systems for compliance, many
states have viewed CEM quality assurance as integral to
INTERNATIONAL RULES 29
their own programs and have patterned QA require-
ments after those of Appendix F. Even if not required to
implement a QA program, a source should develop a
QA plan if it wishes its CEM data to be legally
defensible.
The Role of Calibration Gases
U.S. CEM programs have been written so that gaseous
pollutant emission data are traceable to National
Institute of Standards and Technology (NIST) stand-
ard reference materials (SRMs). Certified calibration
gases, traceability back to SRMs, are used for this pur-
pose when conducting the required quarterly cylinder
gas audit of Part 60 Appendix F – Procedure 1 and the
Part 75 daily calibration verifications and quarterly lin-
earity tests. The traceability protocols are found in the
document: EPA Traceability Protocol for Assay and
Certification of Gaseous Calibration Standards (U.S.
EPA 2012).
In addition to the traceability protocol, the Clean Air
Markets Division instituted the Protocol Gas Verification
Program (PGVP) designed to ensure the accuracy of
protocol calibration gases – a program that has done
much to ensure the quality of CEM data [see 40 CFR
75.21(g)(6) and (7)]. To sell gases as “protocol” gases, gas
suppliers must adhere to traceability protocol proce-
dures and participate in the PGVP program. In the pro-
gram, protocol gases are purchased by users, who instead
of using them, send the gases to NIST for analysis against
NIST standard reference materials. The results of the
analyses are made publicly available, which provides an
incentive for gas vendors to perform well on the blind
audits. Failure to perform well can result in a loss of both
credibility and customers in this competitive and lucra-
tive business.
INTERNATIONAL RULES
Internationally, as in the United States, the implement-
ing rules first require the installation of a CEM system,
and then procedures for installation and certification are
provided either in an appendix to the implementing rule
or are given in a separate set of specifications. Either U.S.
CEM Performance Specification Test procedures or the
EU accreditation and calibration procedures are com-
monly adopted for CEM system certification by other
countries.
Canada
In Canada, the Federal Government provides national
guidelines, through Environment Canada, that are to
be implemented by the provinces. For example, in
30 CEM REGULATIONS
May of 1993, National Power Generation Emissions
guidelines for New Stationary Sources (N 305) were
published to address acid rain control requirements
agreed upon in the U.S.– Canada Clean Air Accords.
Mercury monitoring requirements are given in the doc-
ument Canada-­wide Standards for Mercury Emissions
(CCME 2006, 2007).
Implementing rules are published separately by the
provinces. For example, in Ontario, monitoring require-
ments for cement plants and smelters are found in
Ontario Rule 194/05 (Government of Ontario 2020a).
Monitoring requirements for electrical generation are
found in Ontario Rule 347/01 (Government of
Ontario 2020b).
In Alberta, CEM implementing rules are given in facil-
ity “approvals.” Approaches to emission monitoring
requirements in other Canadian provinces have been
summarized in a report submitted to the Canadian Council
of Ministers by Marbek Consultants (Marbek 2009).
CEM system installation, certification, and quality
assurance criteria are found in the Environment Canada
document EPS/1/PG7 – Protocols and Performance
Specifications for Continuous Monitoring of Gaseous
Emissions from Thermal Power Generation (ENVC 2005),
which is either adopted or modified by the provincial
environmental ministries. In Alberta, a “CEMS Code,”
based on EPS 1/PG/7, was developed to address petro-
leum industry and other sources (AEP 1998). The
Alberta CEMS Code has also been adopted in Australia
(WADER 2016).
Europe
In Europe, directives for installation of CEM systems are
issued by the European Parliament and the Council. For
example, the Industrial Emissions Directive (EU 2010)
requires the Member States of the European Union to
develop implementing rules for automated monitoring
systems (AMS). CEM certification requirements were
standardized by the European Committee for
Standardization , i.e., (Comité Europeén de Normalisation
[CEN]) in standards EN 15627 and 14181.
Asia
Both China and India are active in requiring the instal-
lation of CEM systems in major stationary sources. In
China, an air pollution emissions standard for power
plants, requiring the installation of CEM systems, was
issued in 1997 (Qingfeng and Yuhong 1997; Sloss 1997).
In 2007, China’s Ministry of Environmental Protection
issued further requirements for all state-­controlled pol-
luting facilities to install CEM systems by the end of
2008 (Zhang and Schreifels 2011). Certification
procedures in China have followed those of U.S. Part 60
and 75, and over 10 000 systems have been reported as
being installed (Zhu et al. 2010). The emissions data
from these systems have been compared to satellite
data (Karplus et al. 2018), a novel method of assessing
data quality.
In 2014, the Central Pollution Control Board of India
mandated 17 industrial sectors to install CEM systems
(CPCB 2018a). This has created a large market in India
for both particulate and gas monitoring systems.
Certification procedures and data credibility issues are
being resolved in this nascent program. Compliance
reporting protocols for online continuous emission and
effluent monitoring systems (OCEMS) were issued in
2018, which will require the submittal of CEM system
design and installation details and real-­ time data
(CPCB 2018b).
Latin America*
CEM systems in Latin America are typically required to
be installed through national emission control programs
(Montoya 2020, Morrell 2020).
Mexico Stationary source emissions in Mexico are
regulated by the Secretaria del Medio Ambiente y
Recursos Naturales (SEMARNAT – Secretariat of the
Environment and Natural Resources). CEM systems
were required in 1995 for glass manufacturing plants for
monitoring NOx, CO, and O2. CEM systems for moni-
toring NOx and O2 were required for large thermoelec-
tric plants in 1995, and SO2 and opacity monitors were
required in a 2011 revision of the standard. In 2002,
CEM systems for CO and O2 were required for waste
incineration plants. In cement plants, if 15–30% of the
fuels combusted are nonconventional fuels, continuous
monitoring is required for CO, HCl, NOx, SO2, THC,
and O2 (CMIC 2020).
It is only required to validate CEM systems in the
incineration and thermoelectric plant regulations, where
the U.S. performance specifications of 40 CFR 60
Appendix B are referenced.
Chile In Chile, the Ministry of the Environment
requires the installation of CEM systems at pulp mills,
incinerators, thermoelectric power plants, and copper
smelters. Lime kiln and recovery TRS emissions from
pulp mills have been required to be monitored continu-
ously since 1999 (MMA 1999). Thermoelectric power
plants were regulated in 2011, where continuous moni-
toring systems for SO2, NOx, and particulate matter are
required (MMA 2011). Requirements to monitor SO2
* The assistance of L. Montoya and S. Morrell in the writing of
this section are greatly appreciated.

from smelter acid plants were established in 2013
(MMA 2013a). Monitoring requirements 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), comple-
mented 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 cer-
tification 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
INTERNATIONAL RULES 31
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 valida-
tion 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 monitor-
ing PM, SO2, NOx, CO, HCl, HF, and THC were estab-
lished in 2008 for various industrial sectors, including
waste incineration plants, cement kilns that burn hazard-
ous wastes (Ministerio del Ambiente Minambiente 2008).
No protocol for CEM system validation or quality assur-
ance has been published to support the monitoring
requirements.
Ecuador
A regulation was implemented in 2019 for the installa-
tion of CEM systems in cement plants and thermoelec-
tric plants for monitoring PM, SO2, and NOx (Ministerio
del Ambiente y Agua 2015). No protocol for CEM sys-
tem 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 assur-
ance criteria are either left ambiguous or are to be devel-
oped 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 imple-
mented quality assurance procedures. Failure to incorpo-
rate 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
32 CEM REGULATIONS
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 eas-
ily 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 main-
taining and improving air quality. Properly used, CEM
data can expand an agency’s enforcement capabilities.
The CEM database can assist in negotiating the instal-
lation 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 regu-
lated 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 continu-
ous compliance determination method means:
a method specified by an applicable standard or an appli-
cable 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 corre-
lated 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 appli-
cation 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
test (reference) methods such as those given in 40 CFR
60 Appendix A. Since a CEM system is not an EPA refer-
ence method, it has been argued that CEM system data
cannot be used in enforcement cases. Also, early experi-
ence with CEM systems was somewhat less than satisfac-
tory, and the lack of QA programs often made the CEM
data less defensible in court. The conservative approach
was to rely ultimately on the reference methods for
enforcement issues.
The use of CEM system data for enforcement has
grown as confidence has increased in the quality of the
data. Specifying in a permit that a CEM system is the
compliance method also helps to eliminate any ambigu-
ity regarding compliance determinations. The EPA pro-
grams developed in response to the volume of data
available have matured from the use of CEM systems
from compliance indicating systems to compliance moni-
toring systems.
Compliance assurance monitoring (CAM) programs,
the credible evidence rule, and periodic monitoring
requirements for State Title V CAAA permits are also
relevant to predictive and parameter monitoring meth-
ods, and fill in the monitoring gaps where CEM systems
are not explicitly required (although CEM systems may
still be used in such circumstances). As a result, EPA has
put in place a regulatory framework that can be used to
determine if a source is meeting its emission limits and
standards at all times, as is required by the Clean Air Act
of 1990.
Compliance Indicating Systems – Using CEM
Systems for Reporting Excess Emissions
Federal CEM requirements were originally developed in
1975 to provide a means for sources and agencies to
check the operation and performance of NSPS-­mandated
control equipment such as bag houses and wet scrubbers.
The intention was that the source could use the emis-
sions data to track the control system performance, and
that reports would be submitted quarterly to the agency.
These reports, called excess emission reports (EERs),
were to include data on the exceedances of emissions
standards.
In 1975, new fossil-­ fuel-­
fired steam generators
(FFFSGs), petroleum refineries, nitric acid plants, and

sulfuric acid plants were the first source categories in the
United States required to report such data on a quarterly
basis. The excess emission reports can be used for the
following:
1. To indicate if the source is using good operating
and maintenance practices on its process and its
control equipment to minimize emissions
2. To provide the agency with data on upset condi-
tions or trend data indicating degradation of con-
trol equipment performance
3. To provide the agency with a continuous record of
the source’s ability to comply with standards
4. To provide a screening tool in inspection targeting
programs
5. To provide the agency with sufficient data to issue
a Notice of Violation (NOV) if the source is not
complying with regulations or standards
Under U.S. regulations when CEM data are used for
excess emissions reporting, the data usually have not
been used alone as legally enforceable determinants of
emission exceedances. Instead, the data have been
used to show that a problem exists and, based upon the
severity of the problem, the agency takes further
action, which might include conducting reference
method tests for determining compliance with emis-
sions standards. The reference method test data would
then determine if the source was complying with its
emissions standards.
Using EER data to show that a system is not meeting
emissions standards and then requiring an EPA compli-
ance test to initiate legal action is cumbersome to some.
The advantage, however, is that this method offers the
agency significant negotiating power and provides flexi-
bility in the enforcement program. The problem is that
evaluating excess emission reports and following up with
inspections and compliance tests can require more time
and resources than an agency may have available.
Until 1997, many states adopted the position that
excess emission report (EER) data would not be used to
refer cases to the Department of Justice or to issue an
order of noncompliance, unless other regulatory man-
dates specify the CEM system as the compliance method
(as a compliance indicating systems). Actually, this posi-
tion has not precluded the use of EER data in enforce-
ment cases. Because an agency may review all available
information when evaluating the compliance status of a
source, the CEM data can constitute part of the record of
an enforcement proceeding. Section 113 of the Clean Air
Act states:
“Whenever, on the basis of any information available
to him, the Administrator finds that any person is in vio-
lation of any standard of performance. . .he may bring a
civil action in accordance with subsection 113(a).”
ENFORCEMENT POLICIES AND CEM SYSTEMS 33
EPA can use EER data alone, as a basis for issuing a
“finding of violation” (FOV) or a “notice of violation”
(NOV) (U.S. EPA – OAQPS, 1984, Reich). If the source
does not come into compliance after an FOV or NOV is
issued, EPA must acquire compliance test (Reference
Method) data before it can initiate litigation or issue a
Notice of Noncompliance (NON). However, NOVs have
been issued using CEM data on the basis of the Clean
Air Act Section 113(a) to effectively enforce source com-
pliance (McCoy 1985, 1990).
For agency personnel, a handbook providing proce-
dures for reviewing excess emission reports is available
(Quarles and Peeler 1986). A more recent review guide-
line, developed by the Commonwealth of Virginia
Department of Air Quality (VADEQ), extends review
procedures to predictive emission monitoring systems
(PEMS) and continuous parametric monitoring systems
(CPMS) as well as CEM systems (VADEQ 2018).
Enforcement Levels
The advantage of the “Excess Emission” (EER) approach
for source enforcement is that it allows an agency discre-
tion in its enforcement program. Based upon past source
performance, agency resources, and so on, an agency may
choose to follow up on or not to follow up on reported
instances of excess emissions. A phone call may suffice to
clarify a problem, an FOV or NOV may be issued, or,
further, a site inspection or source test may become
necessary.
An agency may take action on several levels after a
review of an excess emission report. Depending on the
agency policy, this determination may be either formal-
ized or may be flexible. The approach illustrated in
Table 2‑5 is typical although the action levels based on
magnitude and periods of excess emissions or length of
monitor downtime may vary.
Depending on the stringency of the program, the
action levels may vary. For example, percentages for
acceptable out-­ of-­
compliance periods could be <1%
(more stringent) or <3% (less stringent) instead of <2%
as given in Table 2-5. Acceptable monitor downtime (in
the absence of a percent availability requirement in the
facility permit) might be specified in an agency policy as
<1% (more stringent) or <3% (less stringent).
Level 1
On the first level, the agency evaluates the facility’s quar-
terly EERs, by checking the following items:
• Submittal timeliness and completeness
• Reports of periods and magnitudes of excess emissions
• Nature and cause of each period of excess emissions
34 CEM REGULATIONS

TABLE 2-­5 Example Target Criteria and Agency Follow-­up Action Levels Based Upon a Review of the Excess Emission
Report
Suggested
Agency% of Time % of Monitor Out Downtime
Compliance Response of Compliance Follow-­up Action
Acceptable <2.0% <2.0% If both cases exist, acknowledge receipt of EER
Request for corrective >2.0% and <5.0% >2.0% and If either or both cases exist, then send a letter requesting
action < 5.0% corrective action within 30 days
Warning letter >5.0% and <10.0% >5.0% and If either or both cases exist, then warn by letter of
< 10.0% unacceptable condition, request explanations of
condition, and request corrective action plan to prevent
condition from reoccurring
Notice of violation >168 hrs >10% If either or both cases exist, then issue NOV and require
performance (compliance) test for monitored pollutant,
monitor certification (PS) tests and request corrective
action plan to prevent condition from reoccurring

• Periods during which the continuous monitoring Level 4

system was inoperative
• Records of calibration checks, adjustments,
and maintenance performed on the monitoring
system
Problem areas in source operation and/or control
equipment operation should present themselves on thor-
ough evaluation of these items. When the documentation
is unclear or incomplete, the facility should be contacted
for clarification of the problem areas, perhaps avoiding
more extensive agency action.
Level 2
On the second level, for more frequent exceedances or
greater CEM system downtime, a request may be issued
for corrective action to be taken within 30 days.
Level 3
If the EER reports are repeatedly late, indicate opera-
tional problems at the plant, or if emission levels are sub-
stantial, a warning letter requesting that the issues be
resolved within 30–90 days may be issued. Alternatively,
these deficiencies could be used to trigger an inspection
by the agency that may include both an examination of
the emission control system operation and the emission
monitoring program. The inspection could take the form
of a systems audit, not requiring the use of test equip-
ment or gases.
Based on the findings and observations of the on-­site
inspection, it may be necessary to conduct limited testing
on the CEM system to check that it is operating properly.
Performance audit procedures may be conducted, where
the CEM system is challenged with certified audit gases
and/or filters to check data validity.
This level of activity determines the source performance with
respect to the compliance test methods. If the tests show that
the source is not in compliance with emissions limits, the test
data can be used to support further legal action.
The following potential violations (among others)
may be indicated from an excess emission report, sup-
plementary information accompanying the report, or
information requested upon the review (VADEQ 2018;
U.S. EPA 2014c):
• Exceeding the emission limit
• Failure to meet emission control percentage reduc-
tion requirement
• Failure to meet monitoring availability specifica-
tion (as applicable in rule or permit)
• Control equipment operation and maintenance
deficiencies
• Failure to conduct required, periodic CEM perfor-
mance evaluations (RATAs, CGAs, Linearity Tests)
• Failure to write or implement a CEM system QA/QC
Plan
• Failure to follow permit recordkeeping and report-
ing requirements
Compliance Monitoring Systems – Using CEM
Systems for Direct Compliance
The use of CEM systems has evolved in other ways for
enforcement purposes. The continuous record can be
used directly to establish whether the source is in viola-
tion of the standard if a compliance CEM system is
legally mandated. The CEM system becomes a “compli-
ance monitoring” system, in contrast to a “compliance
indicating” system. In this instance, CEM systems can
Another random document with
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while in that city. They found, that, during their absence, the mother-
in-law of Simon had been taken ill, and was then suffering under the
heat of a violent fever. Jesus at once, with a word, pronounced her
cure, and immediately the fever left her so perfectly healed, that she
arose from her sick bed, and proceeded to welcome their return, by
her grateful efforts to make their home comfortable to them, after
their tiresome pilgrimage.

“Immediately the fever left her.”――Matthew viii. 15: Mark i. 31: Luke iv. 39. It may seem
quite idle to conjecture the specific character of this fever; but it seems to me a very
justifiable guess, that it was a true intermittent, or fever and ague, arising from the marsh
influences, which must have been very strong in such a place as Capernaum,――situated
as it was, on the low margin of a large fresh water lake, and with all the morbific agencies of
such an unhealthy site, increased by the heat of that climate. The immediate termination of
the fever, under these circumstances, was an abundant evidence of the divine power of
Christ’s word, over the evil agencies, which mar the health and happiness of mankind.

During some time after this, Peter does not seem to have left his
home for any long period at once, until Christ’s long journeys to
Judea and Jerusalem, but no doubt accompanied Jesus on all his
excursions through Galilee, besides the first, of which the history has
been here given. It would be hard, and exceedingly unsatisfactory,
however, to attempt to draw out from the short, scattered incidents
which fill the interesting records of the gospels, any very distinct,
detailed narrative of these various journeys. The chronology and
order of most of these events, is still left much in the dark, and most
of the pains taken to bring out the truth to the light, have only raised
the greater dust to blind the eyes of the eager investigator. To
pretend to roll all these clouds away at once, and open to common
eyes a clear view of facts, which have so long confused the minds of
some of the wisest and best of almost every Christian age, and too
often, alas! in turn, been confused by them,――such an effort,
however well meant, could only win for its author the contempt of the
learned, and the perplexed dissatisfaction of common readers. But
one very simple, and comparatively easy task, is plainly before the
writer, and to that he willingly devotes himself for the present. This
task is, that of separating and disposing, in what may seem their
natural order, with suitable illustration and explanation, those few
facts contained in the gospels, relating distinctly to this apostle.
These facts, accordingly, here follow.

his first mission.

The next affair in which Peter is mentioned, by either evangelist, is

the final enrolling of the twelve peculiar disciples, to whom Jesus
gave the name of apostles. In their proper place have already been
mentioned, both the meaning of this title and the rank of Peter on the
list; and it need here only be remarked, that Peter went forth with the
rest, on this their first and experimental mission. All the first three
gospels contain this account; but Matthew enters most fully into the
charge of Jesus, in giving them their first commission. In his tenth
chapter, this charge is given with such particularity, that a mere
reference of the reader to that place will be sufficient, without any
need of explanation here. After these minute directions for their
behavior, they departed, as Mark and Luke record, and went through
the towns, preaching the gospel, that men should repent. And they
cast out many devils, and anointed with oil many that were sick, and
healed them. How far their journey extended, cannot be positively
determined, but there is no probability that they went beyond the
limits of Galilee. Divided as they were into couples, and each pair
taking a different route, a large space must have been gone over in
this mission, however brief the time can be supposed to have been.
As to the exact time occupied, we are, indeed, as uncertain as in
respect to the distance to which they traveled; but from the few
incidents placed by Mark and Luke between their departure and
return, it could hardly have been more than a few weeks, probably
only a few days. The only affair mentioned by either evangelist,
between their departure and return, is, the notice taken by Herod of
the actions of Jesus, to whom his attention was drawn by his
resemblance to John the Baptist. They then say, that the apostles,
when they were returned, gathered themselves together to Jesus,
and told him all things,――both what they had done and what they
had taught. As this report was received by Jesus, without any
comment that is recorded, it is fair to conclude, that their manner of
preaching, and the success of their labors, had been such as to
deserve his approbation. In this mission, there is nothing particularly
commemorated with respect to Peter’s conduct; but no doubt the
same fiery zeal which distinguished him afterwards, on so many
occasions, made him foremost in this his earliest apostolic labor. His
rank, as chief apostle, too, probably gave him some prominent part
in the mission, and his field of operations must have been more
important and extensive than that of the inferior apostles, and his
success proportionably greater.

It is deserving of notice, that on this first mission, Jesus seems to have arranged the
twelve in pairs, in which order he probably sent them forth, as he certainly did the seventy
disciples, described in Luke x. 1. The object of this arrangement, was no doubt to secure
them that mutual support which was so desirable for men, so unaccustomed to the high
duties on which they were now dispatched.

Their destination, also, deserves attention. The direction of Jesus was, that they should
avoid the way of the heathen, and the cities of the Samaritans, who were but little better,
and should go to the lost sheep of the house of Israel. This expression was quoted,
probably, from those numerous passages in the prophets, where this term is applied to the
Israelites, as in Jeremiah l. 6, Isaiah liii. 6, Ezekiel xxxiv. 6, &c., and was used with peculiar
force, in reference to the condition of those to whom Jesus sent his apostles. It seems to
me, as if he, by this peculiar term, meant to limit them to the provinces of Galilee, where the
state and character of the Jews was such as eminently to justify this melancholy appellative.
The particulars of their condition will be elsewhere shown. They were expressly bounded on
one side, from passing into the heathen territory, and on the other from entering the cities of
the Samaritans, who dwelt between Galilee and Judea proper, so that a literal obedience of
these instructions, would have confined them entirely to Galilee, their native land. Macknight
also takes this view. The reasons of this limitation, are abundant and obvious. The
peculiarly abandoned moral condition of that outcast section of Palestine,――the perfect
familiarity which the apostles must have felt with the people of their own region, whose
peculiarities of language and habits they themselves shared so perfectly as to be unfitted
for a successful outset among the Jews of the south, without more experience out of
Galilee,――the shortness of the time, which seems to have been taken up in this
mission,――the circumstance that Jesus sent them to proclaim that “the kingdom of heaven
was at hand,” that is, that the Messiah was approaching, which he did in order to arouse the
attention of the people to himself, when he should go to them, (compare Luke x. 1,) thus
making them his forerunners; and the fact, that the places to which he actually did go with
them, on their return, were all in Galilee, (Matthew xi., xix. 1, Mark vi. 7, x. 1, Luke ix. 1‒51,)
all serve to show that this first mission of the apostles, was limited entirely to the Jewish
population of Galilee. His promise to them also in Matthew x. 2, 3, “you shall not finish the
cities of Israel, before the son of man come,” seems to me to mean simply, that there would
be no occasion for them to extend their labors to the Gentile cities of Galilee, or to the
Samaritans; because, before they could finish their specially allotted field of survey, he
himself would be ready to follow them, and confirm their labors. This was mentioned to
them in connection with the prediction of persecutions which they would meet, as an
encouragement. For various other explanations of this last passage, see Poole’s Synopsis,
Rosenmueller, Wetstein, Macknight, Le Sainte Bible avec notes, &c. in loc. But Kuinoel,
who quotes on his side Beza, Bolten, and others, supports the view, which an unassisted
consideration induced me to suggest.

“Anointed with oil.” Mark vi. 13. The same expression occurs in James v. 14, and needs
explanation from its connection with a peculiar rite of the Romish church,――extreme
unction, from which it differs, however, inasmuch as it was always a hopeful operation,
intended to aid the patient, and secure his recovery, while the Romish ceremony is always
performed in case of complete despair of life, only with a view to prepare the patient, by this
mummery, for certain death. The operation mentioned as so successfully performed by the
apostles, for the cure of diseases, was undoubtedly a simple remedial process, previously
in long-established use among the Hebrews, as clearly appears by the numerous
authorities quoted by Lightfoot, Wetstein, and Paulus, from Rabbinical Greek and Arabic
sources; yet Beza and others, quoted in Poole’s Synopsis, as well as Rosenmueller,
suggest some symbolical force in the ceremony, for which see those works in loc. See also
Kuinoel, and Bloomfield who gives numerous references. See also Marlorat’s Bibliotheca
expositionum, Stackhouse’s History of the Bible, Whitby, &c.

the scenes on the lake.

After receiving the report of his apostles’ labors, Jesus said to

them, “Come ye yourselves apart into a retired place, and rest
awhile:” for there were many coming and going, and they had no
leisure so much as to eat. And he took them and went privately by
ship aside, into a lonely place, near the city called Bethsaida. And
the people saw him departing, and many knew him, and went on foot
to the place, out of all the country, and outwent them, and came
together to him as soon as he reached there. And he received them,
and spoke unto them of the kingdom of God, and healed them that
had need of healing. It was on this occasion that he performed the
miracle of feeding the multitude with five loaves and two fishes. So
great was the impression made on their minds by this extraordinary
act of benevolence and power, that he thought it best, in order to
avoid the hindrance of his great task, by any popular commotion in
his favor, to go away in such a manner as to be effectually beyond
their reach for the time.――With this view he constrained his
disciples to get into the ship, and go before him to the other side of
the lake, opposite to Bethsaida, where they then were; while he sent
away the people. After sending the multitude away, he went up into a
mountain, apart, to pray. And after night fall, the vessel was in the
midst of the sea, and he alone on the land. Thence he saw them
toiling with rowing, (for the wind was contrary to them, and the ship
tossed in the waves:) and about three or four o’clock in the morning,
he comes to them, walking on the sea, and appeared as if about to
pass unconcernedly by them. But when they saw him walking upon
the sea. they supposed it to have been a spirit, and they all cried out,
“It is a spirit;” for they all saw him, and were alarmed; and
immediately he spoke to them, and said “Be comforted; it is I; be not
afraid.” And Peter, foremost in zeal on this occasion, as at almost all
times, said to him, “Lord, if it be thou, bid me come to thee upon the
water.” And he said, “Come.” And when Peter had come down out of
the vessel, he walked on the water, to go to Jesus. But when he saw
the wind boisterous, he was afraid; and beginning to sink, he cried,
“Lord, save me.” And immediately Jesus stretched forth his hand,
and caught him; and said to him, “O thou of little faith! wherefore
didst thou doubt?” And when they were come into the ship, the wind
ceased; and they were sore amazed in themselves beyond measure,
and wondered. And all they that were in the vessel came and
worshiped him, saying, “Of a truth, thou art the Son of God.” This
amazement and reverence was certainly very tardily acknowledged
by them, after all the wonders they had seen wrought by him; but
they considered not the miracle of the loaves, the most recent of all,
which happened but a few hours before. For this thoughtlessness, in
a matter so striking and weighty, Jesus himself afterwards rebuked
them, referring both to this miracle of feeding the five thousand, and
to a subsequent similar one. However, the various great actions of a
similar character, thus repeated before them, seem at last to have
had a proper effect, since, on an occasion not long after, they boldly
and clearly made their profession of faith in Jesus, as the Christ.

“A lonely place.”――The word desert, which is the adjective given in this passage, in the
common English version, (Matthew xiv. 13, 15, Mark vi. 31, 32, 35, Luke ix. 10, 12,) does
not convey to the reader, the true idea of the character of the place. The Greek word Ερημος
(eremos) does not in the passages just quoted, mean “desert,” in our modern sense of that
English word, which always conveys the idea of “desolation,” “wildness” and “barrenness,”
as well as “solitude.” But the Greek word by no means implied these darker characteristics.
The primary, uniform idea of the word is, “lonely,” “solitary,” and so little does it imply
“barrenness,” that it is applied to lands, rich, fertile and pleasant, a connection, of course,
perfectly inconsistent with our ideas of a desert place. Schleusner gives the idea very fairly
under Ερημια, (eremia,) a derivative of this word. “Notat locum aliquem vel tractum terrae,
non tam incultum et horridum, quam minus habitabilem,――solitudinem,――locum vacuum
quidem ab hominibus, pascuis tamen et agris abundantem, et arboribus obsitum.” “It means
a place or tract of land, not so much uncultivated and wild, as it does one thinly
inhabited,――a solitude, a place empty of men indeed, yet rich in pastures and fields, and
planted with trees.” But after giving this very clear and satisfactory account of the derivative,
he immediately after gives to the primitive itself, the primary meaning “desertus, desolatus,
vastus, devastatus,” and refers to passages where the word is applied to ruined cities; but in
every one of those passages, the true idea is that above given as the meaning, “stripped of
inhabitants,” and not “desolated” or “laid waste.” Hedericus gives this as the first meaning,
“desertus, solus, solitarius, inhabitatus.” Schneider also fully expresses it, in German, by
“einsam,” (lonely, solitary,) in which he is followed by Passow, his improver, and by
Donnegan, his English translator. Jones and Pickering, also give it thus. Bretschneider and
Wahl, in their New Testament Lexicons, have given a just and proper classification of the
meanings. The word “desert” came into our English translation, by the minute verbal
adherence of the translators to the Vulgate or Latin version, where the word is expressed by
“desertum” probably enough because desertus, in Latin, does not mean desert in English,
nor any thing like it, but simply “lonely,” “uninhabited;”――in short, it has the force of the
English participle, “deserted,” and not of the adjective “desert,” which has probably acquired
its modern meaning, and lost its old one, since our common translation was made; thus
making one instance, among ten thousand others, of the imperfection of this ancient
translation, which was, at best, but a servile English rendering of the Vulgate. Campbell, in
his four gospels, has repeated this passage, without correcting the error, though Hammond,
long before, in his just and beautiful paraphrase, (on Matthew xiv. 13,) had corrected it by
the expression, “a place not inhabited.” Charles Thomson, in his version, has overlooked
the error in Matthew xiv. 13, 15, but has corrected it in Mark vi. 31, &c., and in Luke ix. 10;
expressing it by “solitary.” The remark of the apostles to Jesus, “This place is lonely,” does
not require the idea of a barren or wild place; it was enough that it was far from any village,
and had not inhabitants enough to furnish food for five thousand men; as in 2 Corinthians xi.
26, it is used in opposition to “city,” in the sense of “the country.”

his declaration of christ’s divinity.

Journeying on northward, Jesus came into the neighborhood of

♦Caesarea Philippi, and while he was there in some solitary place,
praying alone with his select disciples, at the conclusion of his
prayer, he asked them, “Who do men say that I, the son of man,
am?” And they answered him, “Some say that thou art John the
Baptist:” Herod, in particular, we know, had this notion; “some, that
thou art Elijah, and others that thou art Jeremiah, or one of the
prophets, that is risen again.” So peculiar was his doctrine, and so
far removed was he, both in impressive eloquence and in original
views, from the degeneracy and servility of that age, that the
universal sentiment was, that one of the bold, pure “spirits of the
fervent days of old,” had come back to call Judah from foreign
servitude, to the long remembered glories of the reigns of David and
Solomon. But his chosen ones, who had by repeated instruction, as
well as long acquaintance, better learned their Master, though still far
from appreciating his true character and designs, had yet a higher
and juster idea of him, than the unenlightened multitudes who had
been amazed by his deeds. To draw from them the distinct
acknowledgment of their belief in him, Jesus at last plainly asked his
disciples, “But who do ye say that I am?” Simon Peter, in his usual
character as spokesman, replied for the whole band, “Thou art the
Christ, the Son of the living God.” Jesus, recognizing in this prompt
answer, the fiery and devoted spirit that would follow the great work
of redemption through life, and at last to death, replied to the zealous
speaker in terms of marked and exalted honor, prophesying at the
same time the high part which he would act in spreading and
strengthening the kingdom of his Master: “Blessed art thou, Simon,
son of Jonah, for flesh and blood have not revealed this unto thee,
but my Father who is in heaven. And I say also unto thee, that thou
art a rock, and on this rock I will build my church, and the gates of
hell shall not prevail against it. And I will give thee the keys of the
kingdom of heaven: and whatsoever thou shalt bind on earth shall be
bound in heaven: and whatsoever thou shalt loose on earth, shall be
loosed in heaven.” In such high terms was the chief apostle
distinguished, and thus did his Master peculiarly commission him
above the rest, for the high office, to which all the energies of his
remaining life were to be devoted.

♦ “Cesarea” replaced with “Caesarea”

Who do men say that I am.――The common English translation, here makes a gross
grammatical blunder, putting the relative in the objective case,――“Whom do men say,” &c.
(Matthew xvi. 13‒15.) It is evident that on inverting the order, putting the relative last instead
of first, it will be in the nominative,――“Men say that I am who?” making, in short, a
nominative after the verb, though it here comes before it by the inversion which the relative
requires. Here again the blunder may be traced to a heedless copying of the Vulgate. In
Latin, as in Greek, the relative is given in the accusative, and very properly, because it is
followed by the infinitive. “Quem dicunt homines esse Filium hominis?” which literally is,
“Whom do men say the son of man to be?”――a very correct form of expression; but the
blunder of our translators was, in preserving the accusative, while they changed the verb,
from the infinitive to the finite form; for “whom” cannot be governed by “say.” Hammond has
passed over the blunder; but Campbell, Thomson, and Webster, have corrected it.

Son of Man.――This expression has acquired a peculiarly exalted sense in our minds,
in consequence of its repeated application to Jesus Christ, and its limitation to him, in the
New Testament. But in those days it had no meaning by which it could be considered
expressive of any peculiar characteristic of the Savior, being a mere general emphatic
expression for the common word “man,” used in solemn address or poetical expressions.
Both in the Old and New Testament it is many times applied to men in general, and to
particular individuals, in such a way as to show that it was only an elegant periphrasis for
the common term, without implying any peculiar importance in the person thus designated,
or referring to any peculiar circumstance as justifying this appellative in that case. Any
concordance will show how commonly the word occurred in this connection. The diligent
Butterworth enumerates eighty-nine times in which this word is applied to Ezekiel, in whose
book of prophecy it occurs oftener than in any other book in the Bible. It is also applied to
Daniel, in the address of the angel to him, as to Ezekiel; and in consideration of the vastly
more frequent occurrence of the expression in the writers after the captivity, and its
exclusive use by them as a formula of solemn address, it has been commonly considered
as having been brought into this usage among the Hebrews, from the dialects of Chaldea
and Syria, where it was much more common. In Syriac, more particularly, the simple
expression, “man,” is entirely banished from use by this solemn periphrasis, (bar-
nosh,) “son of man,” which every where takes the place of the original direct form. It should
be noticed also, that in every place in the Old Testament where this expression (“son of
man”) occurs, before Ezekiel, the former part of the sentence invariably contains the direct
form of expression, (“man,”) and this periphrasis is given in the latter part of every such
sentence, for the sake of a poetical repetition of the same idea in a slightly different form.
Take, for instance, Psalm viii. 4, “What is man, that thou art mindful of him? or the son of
man, that thou visitest him?” And exactly so in every other passage anterior to Ezekiel, as
Numbers xxiii. 19, Job xxv. 16, xxxv. 8, Isaiah li. 12, lvi. 2, and several other passages, to
which any good concordance will direct the reader.

The New Testament writers too, apply this expression in other ways than as a name of
Jesus Christ. It is given as a mere periphrasis, entirely synonymous with “man,” in a general
or abstract sense, without reference to any particular individual, in Mark iii. 28, (compare
Matthew xii. 13, where the simple expression “men” is given,) Hebrews ii. 6, (a mere
translation of Psalm viii. 4,) Ephesians iii. 5, Revelation i. 13, xiv. 14. In the peculiar
emphatic limitation to which this note refers, it is applied by Jesus Christ to himself about
eighty times in the gospels, but is never used by any other person in the New Testament, as
a name of the Savior, except by Stephen, in Acts, vii. 56. It never occurs in this sense in the
apostolic epistles. (Bretschneider.) For this use of the word, I should not think it necessary
to seek any mystical or important reason, as so many have done, nor can I see that in its
application to Jesus, it has any very direct reference to the circumstance of his having,
though divine, put on a human nature, but simply a nobly modest and strikingly emphatic
form of expression used by him, in speaking of his own exalted character and mighty plans,
and partly to avoid the too frequent repetition of the personal pronoun. It is at once evident
that this indirect form, in the third person, is both more dignified and modest in solemn
address, than the use of the first person singular of the pronoun. Exactly similar to this are
many forms of circumlocution with which we are familiar. The presiding officer of any great
deliberative assembly, for instance, in announcing his own decision on points of order, by a
similar periphrasis, says “The chair decides,” &c. In fashionable forms of intercourse, such
instances are still more frequent. In many books, where the writer has occasion to speak of
himself, he speaks in the third person, “the author,” &c.; as in an instance close at hand, in
this book it will be noticed, that where it is necessary for me to allude to myself in the text of
the work, which, of course, is more elevated in its tone than the notes, I speak, according to
standard forms of scriptorial propriety, in the third person, as “the author,” &c.; while here, in
these small discussions, which break in on the more dignified narrative, I find it at once
more convenient and proper, to use the more familiar and simple forms of ♦expression.

♦ “expresssion” replaced with “expression”

This periphrasis (“son of”) is not peculiar to oriental languages, as every Greek scholar
knows, who is familiar with Homer’s common expression υιες Αχαιων, (uies Akhaion,) “sons
of Grecians,” instead of “Grecians” simply, which by a striking coincidence, occurs in Joel
xiii. 6, in the same sense. Other instances might be needlessly ♦multiplied.

♦ “multipled” replaced with “multiplied”

Thou art a Rock, &c.――This is the just translation of Peter’s name, and the force of the
declaration is best understood by this rendering. As it stands in the original, it is “Thou art
Πετρος, (Petros, ‘a rock,’) and on this Πετρα (Petra, ‘a rock’) I will build my church,”――a
play on the words so palpable, that great injustice is done to its force by a common tame,
unexplained translation. The variation of the words in the Greek, from the masculine to the
feminine termination, makes no difference in the expression. In the Greek Testament, the
feminine πετρα (petra) is the only form of the word used as the common noun for “rock,” but
the masculine πετρος (petros) is used in the most finished classic writers of the ancient
Greek, of the Ionic, Doric and Attic, as Homer, Herodotus, Pindar, Xenophon, and, in the
later order of writers, Diodorus Siculus.

H. Stephens gives the masculine form as the primitive, but Schneider derives it from the
feminine.

After this distinct profession of faith in him, by his disciples,

through Peter, Jesus particularly and solemnly charged them all, that
they should not, then, assert their belief to others, lest they should
thereby be drawn into useless and unfortunate contests about their
Master, with those who entertained a very different opinion of him.
For Jesus knew that his disciples, shackled and possessed as they
were with their fantasies about the earthly reign of a Messiah, were
not, as yet, sufficiently prepared to preach this doctrine: and wisely
foresaw that the mass of the Jewish people would either put no faith
at all in such an announcement, or that the ill disposed and
ambitious would abuse it, to the purposes of effecting a political
revolution, by raising a rebellion against the Roman rulers of
Palestine, and oversetting foreign power. He had, it is true, already
sent forth his twelve apostles, to preach the coming of the kingdom,
(Matthew x. 7,) but that was only to the effect that the time of the
Messiah’s reign was nigh,――that the lives and hearts of all must be
changed,――all which the apostles might well preach, without
pretending to announce who the Messiah was.

his ambitious hopes and their humiliation.

This avowal of Peter’s belief that Jesus was the Messiah, to which
the other apostles gave their assent, silent or loud, was so clear and
hearty, that Jesus plainly perceived their persuasion of his divine
authority to be so strong, that they might now bear a decisive and
open explanation of those things which he had hitherto rather darkly
and dimly hinted at, respecting his own death. He also at this time,
brought out the full truth the more clearly as to the miseries which
hung over him, and his expected death, with the view the more
effectually to overthrow those false notions which they had
preconceived of earthly happiness and triumph, to be expected in
the Messiah’s kingdom; and with the view, also, of preparing them
for the events which must shortly happen; lest, after they saw him
nailed to the cross, they should all at once lose their high hopes, and
utterly give him up. He knew too, that he had such influence with his
disciples, that if their minds were shocked, and their faith in him
shaken, at first, by such a painful disclosure, he could soon bring
them back to a proper confidence in him. Accordingly, from this time,
he began distinctly to set forth to them, how he must go to
Jerusalem, and suffer many things from the elders, and chief priests,
and scribes, and be killed, and be raised again the third day. There is
much room for reasonable doubt, as to the manner in which those
who heard this declaration of Christ, understood it at the time. As to
the former part of it, namely, that he would be ill-treated by the great
men of the Jewish nation, both by those ruling in the civil and
religious government, it was too plain for any one to put any but the
right meaning upon it. But the promise that he should, after this
horrible fate, rise again from the dead on the third day, did not, as it
is evident, by any means convey to them the meaning which all who
read it now, are able to find in it. Nothing can be more plain to a
careful reader of the gospels, than that his disciples and friends had
not the slightest expectation that he would ever appear to them after
his cruel death; and the mingled horror and dread with which the first
news of that event was received by them, shows them to have been
utterly unprepared for it. It required repeated positive demonstration,
on his part, to assure them that he was truly alive among them, in his
own form and character. The question then is――what meaning had
they all along given to the numerous declarations uttered by him to
them, apparently foretelling this, in the distinct terms, of which the
above passage is a specimen? Had they understood it as we do,
and yet so absolutely disbelieved it, that they put no faith in the event
itself, when it had so palpably occurred? And had they, for months
and years, followed over Palestine, through labors, and troubles, and
dangers, a man, who, as they supposed, was boldly endeavoring to
saddle their credulity with a burden too monstrous for even them to
bear? They must, from the nature of their connection with him, have
put the most unlimited confidence in him, and could not thus
devotedly have given themselves up to a man whom they believed
or suspected to be constantly uttering to them a falsehood so
extravagant and improbable. They must, then, have put some
meaning on it, different from that which our clearer light enables us
to see in it; and that meaning, no doubt, they honestly and firmly
believed, until the progress of events showed them the power of the
prophecy in its wonderful and literal fulfilment. They may have
misunderstood it in his life time, in this way: the universal character
of the language of the children of Shem, seems to be a remarkable
proneness to figurative expressions, and the more abstract the ideas
which the speaker wishes to convey, the more strikingly material are
the figures he uses, and the more poetical the language in which he
conveys them. Teachers of morals and religion, most especially,
have, among those nations of the east, been always distinguished
for their highly figurative expressions, and none abound more richly
in them than the writers of the Old and New Testament. So peculiarly
effective, for his great purposes, did Jesus Christ, in particular, find
this variety of eloquence, that it is distinctly said of him, that he
seldom or never spoke to the people without a parable, which he
was often obliged to expound more in detail, to his chosen followers,
when apart with them. This style of esoteric and exoteric instruction,
had early taught his disciples to look into his most ordinary
expressions for a hidden meaning; and what can be more likely than
that often, when left to their own conjectures, they, for a time, at
least, overleaped the simple literal truth, into a fog of figurative
interpretations, as too many of their very modern successors have
often done, to their own and others’ misfortune. We certainly know
that, in regard to those very expressions about raising the dead,
there was a very earnest inquiry among the three chief apostles,
some time after, as will be mentioned in place, showing that it never
seemed possible to them that their Lord, mighty as he had showed
himself, could ever mean to say to them, that, when his bitter foes
had crowned his life of toil and cares with a bloody and cruel exit,
he――even He, could dare to promise them, that he would break
through that iron seal, which, when once set upon the energies of
man, neither goodness, nor valor, nor knowledge, nor love, had ever
loosened, but which, since the first dead yielded his breath, not the
mightiest prophet, nor the most inspired, could ever break through
for himself. The figure of death and resurrection, has often been
made a striking image of many moral changes;――of some one of
which, the hearers of Jesus probably first interpreted it. In connection
with what he had previously said, nothing could seem more natural
to them, than that he, by this peculiarly strong metaphor, wished to
remind them that, even after his death, by the envious and cruel
hands of Jewish magistrates, over but a few days, his name, the
ever fresh influence of his bright and holy example――the undying
powers of his breathing and burning words, should still live with
them, and with them triumph after the momentary struggles of the
enemies of the truth.

The manner, also, in which Simon Peter received this

communication, shows that he could not have anticipated so glorious
and dazzling a result of such horrible evils: for, however literally he
may have taken the prophecy of Christ’s cruel death, he used all his
powers to dissuade his adored master from exposing himself to a
fate so dark and dreadful,――so sadly destructive of all the new-
born hopes of his chosen followers, and from which the conclusion of
the prophecy seemed to offer no clear or certain mode of escape.
Never before, had Jesus spoken in such plain and decided terms,
about the prospect of his own terrible death. Peter, whose heart had
just been lifted up to the skies with joy and hope, in the prospect of
the glorious triumphs to be achieved by his Lord through his means,
and whose thoughts were even then dwelling on the honors, the
power, the fame, which were to accrue to him for his share in the
splendid work,――was shocked beyond measure, at the strange and
seemingly contradictory view of the results, now taken by his great
leader. With the confident familiarity to which their mutual love and
intimacy entitled him, in some measure, he laid his hand
expostulatingly upon him, and drew him partly aside, to urge him
privately to forget thoughts of despondency, so unworthy of the great
enterprise of Israel’s restoration, to which they had all so manfully
pledged themselves as his supporters. We may presume, that he, in
a tone of encouragement, endeavored to show him how impossible it
would be for the dignitaries of Jerusalem to withstand the tide of
popularity which had already set so strongly in favor of Jesus; that so
far from looking upon himself as in danger of a death so infamous,
from the Sanhedrim, he might, at the head of the hosts of his
zealous Galileans, march as a conqueror to Jerusalem, and thence
give laws from the throne of his father David, to all the wide
territories of that far-ruling king. Such dreams of earthly glory
seemed to have filled the soul of Peter at that time; and we cannot
wonder, then, that every ambitious feeling within him recoiled at the
gloomy announcement, that the idol of his hopes was to end his
days of unrequited toil, by a death so infamous as that of the cross.
“Be it far from thee, Lord,” “God forbid,” “Do not say so,” “Do not thus
damp our courage and high hopes,” “This must not happen to
thee.”――Jesus, on hearing these words of ill-timed rebuke, which
showed how miserably his chief follower had been infatuated and
misled, by his foolish and carnal ambition, turned away indignantly
from the low and degraded motives, by which Peter sought to bend
him from his holy purposes. Not looking upon him, but upon the
other disciples, who had kept their feelings of regret and
disappointment to themselves, he, in the most energetic terms,
expressed his abhorrence of such notions, by his language to the
speaker. “Get thee behind me, Satan; thou art a scandal to me; for
thou savorest not the things which be of God, but the things which
be of men. In these fervent aspirations after eminence, I recognize
none of the pure devotion to the good of man, which is the sure test
of the love of God; but the selfish desire for transient, paltry
distinction, which characterizes the vulgar ambition of common men,
enduring no toil or pain, but in the hope of a more than equal earthly
reward speedily accruing.” After this stern reply, which must have
strongly impressed them all with the nature of the mistake of which
they had been guilty, he addressed them still further, in continuation
of the same design, of correcting their false notion of the earthly
advantages to be expected by his companions in toil. He
immediately gave them a most untempting picture of the character
and conduct of him, who could be accepted as a fit fellow-worker
with Jesus. “If any one wishes to come after me, let him deny
himself, and let him take up his cross, (as if we should say, let him
come with his halter around his neck, and with the gibbet on his
shoulder,) and follow me. For whosoever shall save his life for my
sake, shall lose it; and whosoever will lose his life for my sake, shall
find it. For what is a man profited, if he shall gain the whole world,
and lose his own soul? For the Son of Man shall come in the glory of
his Father, with his angels; and then, he shall reward every man
according to his works.” “I solemnly tell you, there are some standing
here who shall not taste of death, till they see the Son of Man
coming in his kingdom.”――“In vain would you, in pursuit of your idle
dreams of earthly glory, yield up all the powers of your soul, and
spend your life for an object so worthless. After all, what is there in
all the world, if you should have the whole at your disposal――what,
for the momentary enjoyment of which, you can calmly pay down
your soul as the price? Seek not, then, for rewards so unworthy of
the energies which I have recognized in you, and have devoted to far
nobler purposes. Higher honors will crown your toils and sufferings,
in my service;――nobler prizes are seen near, with the eye of faith.
Speedily will the frail monuments of this world’s wonders crumble,
and the memory of its greatnesses pass away; but over the ruins of
kingdoms, the coming of the Man to whom you have joined
yourselves is sure, and in that triumphant advent, you shall find the
imperishable requital of your faithful and zealous works. And of the
nature and aspect of the glories which I now so dimly shadow in
words, some of those who now hear me shall soon be the living
witnesses, as of a foretaste of rewards, whose full enjoyment can be
yours, only after the weariness and misery of this poor life are all
passed. Years of toil, dangers, pain, and sorrow,――lives passed in
contempt and disgrace,――deaths of ignominy, of unpitied anguish,
and lingering torture, must be your passage to the joys of which I
speak; while the earthly honors which you now covet, shall for ages
continue to be the prize of the base, the cruel, and the foolish, from
whom you vainly hope to snatch them.”

the transfiguration.

The mysterious promise thus made by Jesus, of a new and

peculiar exhibition of himself, to some of his chosen ones, he soon
sought an occasion of executing. About six or eight days after this
remarkable conversation, he took Peter, and the two sons of
Zebedee, James and John, and went with them up into a high
mountain, apart by themselves. As to the name and place of this
mountain, a matter of some interest certainly, there have been two
opinions among those who have attempted to illustrate the
topography of the gospels. The phrase, “a high mountain,” has
instantly brought to the thoughts of most learned readers, Mount
Tabor, famous for several great events in Bible history, which they
have instantly adopted, without considering the place in which the
previous account had left Jesus, which was Caesarea Philippi;
hereafter described as in the farthest northern part of Galilee. Now,
Mount Tabor, however desirable in other particulars, as the scene of
a great event in the life of Jesus, was full seventy miles south of the
place where Jesus had the conversation with his disciples, which led
to the remarkable display which followed a few days after, on the
mountain. It is true, that the intervening period of a week, was
sufficient to enable him to travel this distance with ease; but the
difficulty is, to assign some possible necessity or occasion for such a
journey. Certainly, he needed not to have gone thus far to find a
mountain, for Caesarea Philippi itself stands by the base of Paneas,
which is a part of the great Syrian range of Antilibanus. This great
mountain, or mountain chain, rises directly behind the city, and parts
of it are so high above the peak of Tabor, or any other mountain in
Palestine, as to be covered with snow, even in that warm country.
The original readers of the gospel story, were dwellers in Palestine,
and must have been, for the most part, well acquainted with the
character of the places which were the scenes of the incidents, and
could hardly have been ignorant of the fact, that this splendid city, so
famous as the monument of royal vanity and munificence, was near
the northern end of Palestine, and of course, must have been known
even by those who had never seen it, nor heard it particularly
described, to be very near the great Syrian mountains; so near too,
as to be very high elevated above the cities of the southern country,
since not far from the city gushed out the most distant sources of the
rapid Jordan. But another difficulty, in respect to this journey of
seventy miles to Tabor, is, that while the gospels give no account of
it, it is even contradicted by Mark’s statement, that after departing
from the mountain, he passed through Galilee, and came to
Capernaum, which is between Tabor and Caesarea Philippi, twenty
or thirty miles from the former, and forty or fifty from the latter. Now,
that Jesus Christ spared no exertion of body or mind, in “going about
doing good,” no one can doubt; but that he would spend the strength
devoted to useful purposes, in traveling from one end of Galilee to
the other, for no greater good than to ascend a particular mountain,
and then to travel thirty miles back on the same route, is a most
unnecessary tax upon our faith. But here, close to Caesarea Philippi,
was the mighty range of Antilibanus, known in Hebrew poetry by the
name of Hermon in this part; and He, whose presence made all
places holy, could not have chosen, among all the mountains of
Palestine, one which nature had better fitted to impress the beholder
who stood on the summit, with ideas of the vast and sublime.
Modern travelers assure us that, from the peaks behind the city, the
view of the lower mountains to the south,――of the plain through
which the young Jordan flows, soon spreading out into the broad
sheet of lake Houle, (Samachonitis lacus,) and of the country, almost
to lake Tiberias, is most magnificent. The precise peak which was
the scene of the event here related, it is impossible to conjecture. It
may have been any one of three which are prominent: either the
castle hill, or, farther off and much higher, Mount Bostra, once the
site of a city, or farther still, and highest of all, Merura Jubba, which is
but a few hours walk from the city. The general impression of the
vulgar, however, and of those who take the traditions of the vulgar
and the ignorant, without examination, has been, that Tabor was the
scene of the event, so that, at this day, it is known among the stupid
Christians of Palestine, by the name of the Mount of the
Transfiguration. So idly are these foolish local traditions received,
that this falsehood, so palpable on inspection, has been quietly
handed down from traveler to traveler, ever since the crusades,
when hundreds of these and similar localities, were hunted up so
hastily, and by persons so ill-qualified for the search, that more
modern investigators may be pardoned for treating with so little
consideration the voice of such antiquity, when it is found opposed to
a rational and consistent understanding of the gospel story. When
the question was first asked, “Where is the mount of the
transfiguration?” there were enough persons interested to reply,
“Mount Tabor.” No reason was probably asked for the decision, and
none was given; but as the scene was acted on a high mountain in
Galilee, and as Tabor answered perfectly to this very simple
description, and was moreover interesting on many other accounts,
both historical and natural, it was adopted for the transfiguration
without any discussion whatever, among those on the spot. Still, to
learned and diligent readers of the gospels, the ♦inconsistencies of
such a belief have been so obvious, that many great theologians
have decided, for the reasons here given, that the transfiguration
must have taken place on some part of Mount Paneas, as it was
called by the Greeks and Romans, known among the Jews,
however, from the earliest times, by the far older name of Mount
Hermon. On the determination of this point, more words have been
expended than some may deem the matter to deserve; but among
the various objects of the modern historian of Bible times, none is
more important or interesting, ♠than that of settling the often disputed
topography of the sacred narrative; and as the ground here taken
differs so widely from the almost universally received opinion, the
minute reasons were loudly called for, in justification of the author’s
boldness. The ancient blunders here detected, and shown to be
based only upon a guess, is a very fair specimen of the way in
which, in the moral as in the natural sciences, “they all copy from
one another,” without taking pains to look into the truth of small
matters. And it seems to show, moreover, how, when men of patient
and zealous accuracy, have taken the greatest pains to expose and
correct so causeless an error, common readers and writers too, will
carelessly and lazily slip back into the old blunder, thus making the
counsels of the learned of no effect, and loving darkness rather than
light, error rather than exactness, because they are too shiftless to
find a good reason for what is laid down before them as truth. But so
it is. It is, and always has been, and always will be, so much easier
for men to swallow whole, or reject whole, the propositions made to
them, that the vast majority had much rather believe on other
people’s testimony, than go through the harassing and tiresome task,
of looking up the proofs for themselves. In this very instance, this
important topographical blunder was fully exposed and corrected a
century and a half ago, by Lightfoot, the greatest Hebrew scholar
that ever lived; and we see how much wiser the world is for his
pains.

♦ “inconsistences” replaced with “inconsistencies”

♠ duplicate word “than” removed

Caesarea Philippi.――This city stood where all the common maps place it, in the
farthest northern part of Palestine, just at the foot of the mountains, and near the fountain
head of the Jordan. The name by which it is called in the gospels, is another instance, like
Julias Bethsaida, of a compliment paid by the servile kings, of the divisions of Palestine, to
their imperial masters, who had given, and who at any time could take away, crown and
kingdom from them. The most ancient name by which this place is known to have been
mentioned in the Hebrew scriptures, is Lasha, in Genesis x. 19, afterwards variously
modified into Leshem, (Joshua xix. 47,) and Laish, (Judges xviii. 7: xiv. 29,) a name
somewhat like the former in sound, though totally different in meaning, (‫ לשם‬leshem, “a
precious stone,” and ‫ ליש‬laish, “a lion,”) undoubtedly all three being from the same root, but
variously modified in the changing pronunciations of different ages and tribes. In the earliest
passage, (Genesis x. 19,) it is clearly described as on the farthest northern limit of the land
of Canaan, and afterwards, being conquered long after most of the cities of that region, by
the tribe of Dan, and receiving the name of this tribe, as an addition to its former one, it
became proverbially known under the name of Dan, as the farthest northern point of the
land of Israel, as Beersheba was the southern one. It did not, however, lose its early
Canaanitish name till long after, for, in Isaiah x. 30, it is spoken of under the name of Laish,
as the most distant part of Israel, to which the cry of the distressed could reach. It is also
mentioned under its later name of Dan, in Genesis xiv. 14, and Deuteronomy xxxiv. 1, where
it is given by the writer, or some copyist, in anticipation of the subsequent account of its
acquiring this name after the conquest. Josephus also mentions it, under this name, in
Antiquities book i. chapter 10, and book viii. chapter 8, section 4, in both which places he
speaks of it as standing at one of the sources of the Jordan, from which circumstance, no
doubt, the latter part of the river’s name is derived. After the overthrow of the Israelitish
power in that region, it fell into the hands of new possessors, and under the Greeks and
Romans, went by the name of Panias, (Josephus and Ptolemy,) or Paneas, (Josephus and
Pliny,) which name, according to Ptolemy, it had under the Phoenicians. This name,
supposed to have been taken from the Phoenician name of the mountain near, Josephus
gives to it, in all the later periods of his history, until he speaks of the occasion on which it
received a new change of name.

Its commanding and remarkable position, on the extremity of Palestine, made it a

frontier post of some importance; and it was therefore a desirable addition to the dominions
of Herod the Great, who received it from his royal patron, Augustus Caesar, along with its
adjacent region between Galilee and Trachonitis, after the death of Zenodorus, its former
possessor. (Josephus Antiquities book xv. chapter 10, section 3.) Herod the Great, out of
gratitude for this princely addition to his dominions, at a time when attempts were made to
deprive him of his imperial master’s favor, raised near this city, a noble monument to
Augustus. (Josephus as above quoted.) “He built a monument to him, of white marble, in
the land of Zenodorus, near Panium. There is a beautiful cave in the mountain, and beneath
it there is a chasm in the earth, rugged, and of immense depth, full of still water, and over it
hangs a vast mountain; and under the cave rise the springs of the Jordan. This place,
already very famous, he adorned with the temple which he consecrated to Caesar.” A lofty
temple of white marble, on such a high spot, contrasted with the dark rocks of the mountain
and cave around, must have been a splendid object in the distance, and a place of frequent
resort.

This city, along with the adjacent provinces, after the death of the first Herod, was given
to his son Philip, made tetrarch of Iturea and Trachonitis. This prince, out of gratitude to the
royal donor, at the same time when he rebuilt and repaired Bethsaida, as already
mentioned, “also embellished Paneas, at the fountains of the Jordan, and gave it the name
of Caesarea.” (Josephus Antiquities book xviii. chapter 2, section 1, also Jewish War, book
ii. chapter 9, section 1,) and to distinguish it from other Caesareas, hereafter to be
mentioned, it was called from the name of its royal builder, Caesarea Philippi, that is, “the
Caesarea of Philip.” By this name it was most commonly known in the time of Christ; but it
did not answer the end of perpetuating the name of its builder and his patron, for it shortly
afterwards recovered its former name, Paneas, which, probably, never went wholly out of
use. As late as the time of Pliny, (about A. D. 70,) Paneas was a part of the name of
Caesarea. Fons Paneas, qui cognomen dedit Caesareae, “the fountain Paneas, which gave
to Caesarea a surname.” (Pliny Natural History book v. chapter 15,) which shows, that at
that time, the name Paneas was one, by which even foreign geographers recognized this
city, in spite of the imperial dignity of its new title. Eusebius, (about A. D. 315,) speaks of
“Caesarea Philippi, which the Phoenicians call Paneas, at the foot of mount Panium.”
(Φιλιππου Καισαρεια ἡν Πανεαδα Θοινικες προσαγορευσι, &c. Church History book vii. chapter
17.) Jerome, (about A. D. 392,) never mentions the name Caesarea Philippi, as belonging
to this city, except in commenting on Matthew xvi. 13, where he finds it necessary to explain
this name, as an antiquated term, then out of use. Caesaream Philippi, quae nunc dicitur
Paneas, “Caesarea Philippi, which is now called Paneas;” and in all the other places where
he has occasion to mention the place, he gives it only the name of Paneas. Thus, in
commenting on Amos viii. 14, he says, “Dan, on the boundary of the Jewish territory, where
now is Paneas.” And on Jeremiah iv. 15,――“The tribe Dan, near mount Lebanon, and the
city which is now called Paneas,” &c.――See also commentary on Daniel xiii. 16.

After the death of Philip, this city, along with the rest of his dominions, was presented by
Cains Caligula to Agrippa, who added still farther to the improvements made by Philip, more
particularly ornamenting the Panium, or famous source of the Jordan, near the city, as
Josephus testifies. (Jewish War, book iii. chapter 9, section 7.) “The natural beauty of the
Panium, moreover, was still more highly adorned (προσεξησκηται) with royal magnificence,
being embellished by the wealth of Agrippa.” This king also attempted to perpetuate the
name of one of his imperial patrons, in connection with the city, calling it Neronias, in honor
of one who is well enough known without this aid. (Josephus Antiquities book xx. chapter 8,
section 3.) The perfectly transient character of this idle appellation, is abundantly shown
from the preceding copious quotations.

The city, now called Banias, (not Belinas, as Wahl erroneously says,) has been visited
and examined in modern times by several travelers, of whom, none has described it more
minutely than Burckhardt. His account of the mountains around the city, so finely illustrates
my description of the scene of the transfiguration, that I extract largely from it here. In order
to appreciate the description fully, it must be understood that Heish is now the general
Arabic name for the mountain chain, which was by ancient authors variously called
Lebanon, Libanus, Anti-Libanus, Hermon, and Panium; for all these names have been given
to the mountain-range, on whose slope Caesarea Philippi, or Paneas, stood.

“The district of Banias is classic ground; it is the ancient Caesarea Philippi; the lake
Houle, is the Lacus Samachonitis. Immediately after my arrival, I took a man of the village to
shew me the way to the ruined castle of Banias, which bears East by South from it. It stands
on the top of a mountain, which forms part of the mountain of Heish, at an hour and a
quarter from Banias; it is now in complete ruins, but was once a very strong fortress. Its
whole circumference is twenty-five minutes. It is surrounded by a wall ten feet thick, flanked
with numerous round towers, built with equal blocks of stone, each about two feet square.
The keep, or citadel, seems to have been on the highest summit, on the eastern side,
where the walls are stronger than on the lower, or western side. The view from thence over
the Houle and a part of its lake, the Djebel Safad, and the barren Heish, is magnificent. On