Читать книгу Continuous Emission Monitoring - James A. Jahnke - Страница 34

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 established 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 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 calibration 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 standards 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 emissions corrected to 7% O₂. Cement kilns burning hazardous waste are also required to install a continuous opacity monitoring system (COMS).