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TTP#:
OR0-1-MW31
Project Overview
This task will support the performance evaluation of long-term
Continuous Emissions Monitors (CEMs) for Mercury (Hg) at the Toxic
Substances Control Act Incinerator (TSCAI). In order for Hg CEMs
to be considered for regulatory compliance assurance, acceptable
performance must first be demonstrated. Previous Hg CEM testing in
conjunction with a proposal on the Environmental Protection Agency (EPA)
Maximum Achievable Control Technology (MACT) standards for hazardous
waste combustors at a commercial cement kiln in 1996-97 was not
successful. The emission characteristics of the kiln, specifically the
combination of high particulate matter, moisture, and acid gases, were
believed to have contributed to the failure of the tested CEMs. Further
testing of a commercial Hg CEM at the TSCAI in 1998 was evaluated
according to the proposed EPA Performance Specification 12 (PS12). The
CEM exhibited potential at the mixed waste incinerator to meet proposed
requirements under liquid feed conditions for Hg concentrations in the
range of proposed MACT standards. However, under conditions of
incinerating liquids and solids simultaneously, reliable CEM performance
was NOT demonstrated under the facility's operating conditions and
configuration. The data supported the feasibility of Hg CEM at hazardous
waste incinerators, however, pointed to additional testing required to
satisfy PS12, CEM modifications to handle transient emissions from
treating heterogeneous waste streams, further development of calibration
standards and methods to meet EPA MACT mercury emission limits, and
agreement on site-specific response factors.
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