Feasibility of Monitoring Heavy Metal Emissions from a Coal-Fired Thermal Hazardous Waste Incinerator using a Multi-Metal Continuous Emissions Monitor

Under the current Hazardous Waste Combustor Maximum Achievable Control Technology rule, heavy metal emissions from the nation’s thermal hazardous waste combustion facilities are estimated using control efficiencies determined during performance testing and estimated metal feed rates during normal operation. The error in estimates of metal emissions from this approach can be on the order of 100 percent or more. This error could be greatly reduced by measuring emissions continuously using a multi-metal continuous emission monitor (CEM). Cooper Environmental Services, LLC has developed a multi-metal CEM, the Xact, which recently has been accepted by the U.S. Environmental Protection Agency (EPA) for compliance purposes on a gas-fired thermal hazardous waste incinerator. The stack effluent from this facility, however, does not represent a particularly “challenging” environment. The particulate matter (PM) levels, the moisture content, and the SOx and NOx levels are all low relative to other types of facilities. The research described for this project will demonstrate the feasibility of using the Xact on a coal-fired thermal hazardous waste incinerator. The proposed EPA coal-fired test facility would have higher levels of PM, SOx, and NOx; have higher moisture content; and operate at a higher temperature, thus representing a more challenging environment for Xact operation. Procedures used for feasibility demonstration will be similar to those used for EPA Method 301 validation of the Xact on the gas-fired incinerator. These procedures will test the Xact for accuracy and for the linearity of its response to a dynamically spiked metal concentration. If successful, this feasibility study could pave the way for the Xact to be used on coal-fired thermal hazardous waste sources, as well as other coal-fired sources with regulated metal emissions, including municipal waste incinerators, coal-fired power plants, and industrial furnaces and boilers.