IMPLEMENTING MERCURY CEMS IN DOE MIXED WASTE TREATMENT SYSTEMS

This paper examines the current state of the art of mercury continuous emission monitors (CEMs), and their usability for monitoring effluent from mixed waste treatment systems. EPA’s Office of Solid Waste (OSW) is not mandating mercury CEMs in the draft Maximum Achievable Control Technology (MACT) Rule for hazardous waste incinerators. However, voluntary use of mercury CEMs can be negotiated on a site-by-site basis to reduce up-front waste feed characterization, compliance testing, and operational costs. It is important to evaluate the usability of mercury CEMs for two reasons. First, mercury is a ubiquitous pollutant for DOE, and has unique ramifications in treatment systems. Second, recent DOE/EPA field test results may have unfairly branded mercury CEMs as unworkable for hazardous waste applications. In this paper we compare 17 different mercury (and multi-metal) CEMs both under development and commercially available. We base these comparisons on results from field tests, direct discussions with vendors, and literature. We also discuss performance requirements (e.g. calibration and detection limits) in the EPA/OSW draft MACT rule, compared to requirements in German TUV regulations. This paper also includes a discussion on some practicalities and terminology regarding speciating mercury CEMs. With no regulatory-based market for mercury CEMs, implementation will depend on clear, achievable performance specifications and validation tests. Individual permit writers can work with a facility to make site-specific decisions how to use mercury CEMs where practical. Draft EPA performance specifications, PS12, will undoubtedly play a role in site-by-site implementation. EPA and DOE can also work together to define and conduct more realistic validation tests