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

Under current Hazardous Waste Combustor Maximum Achievable Control Technology rule, heavy metal emissions from the nations 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% or more. This error could be greatly reduced by measuring emissions continuously using a multi-metal continuous emission monitor (CEM). Cooper Environmental Services, LLLC (CES) has developed a multi-metal CEM, the Xact, which has recently been accepted by the U.S. 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 in this proposal seeks to 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, the SOx and NOx have higher moisture content, and operate at a higher temperature, thus representing a more challenging environment for Xact operations. Procedures used for feasibility demonstration will be similar to those used for the 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.