Should the Xact~® Multi-metal Continuous Emissions Monitoring System (CEMS) and Related Technologies Be Used For Compliance Monitoring?

摘要

The Environmental Protection Agency (EPA) has recently endorsed the installation of the Xact~® multi-metals continuous emissions monitoring system (CEMS) equipment. The purported objective of this endorsement is to continuously evaluate compliance with Maximum Achievable Control Technology (MACT) emission standards and the adequacy of current operating practices in ensuring compliance. The Xact~® multi-metals continuous monitors have also been proposed as ambient air monitors along perimeter locations to collect data related to source emissions. This paper evaluates the completeness of the data and suitability of using the Xact~® technology for compliance monitoring applications. Additionally, this paper examines the apparent technical and regulatory deficiencies incurred during the Xact~® methodology validation. Issues related to the quantitative transfer of representative particulate samples are presented as a major obstacle for operation of monitors used to report compliance. These issues and the impacts these issues have on incineration or thermal treatment facilities financially and operationally will be discussed. Finally, this paper evaluates Xact~® performance issues and questions the readiness and appropriateness of the Xact~® multi-metals, and other continuous monitors that are dependent on representative particulate transport for their accuracy, for compliance applications.