Stability of HWC Emissions Over Time

摘要

This paper addresses the issue of whether Hazardous Waste Incinerator emissions change significantly over time when no significant equipment modifications occur. Hazardous Waste Combustor (HWC) Maximum Achievable Control Technology (MACT) regulations require a comprehensive performance test (CPT) every 5 years and a confirmatory performance test every 2 1/2 years to confirm that performance levels have not deteriorated. HWC MACT CPTs were conducted in 2001-2002 and again in 2008 under similar operating conditions at a multiple hearth sludge incinerator that burns wastewater treatment sludge at Kodak's industrial complex in Rochester, NY. This paper compares emissions test results from these two compliance tests and concludes that there were no significant changes in emission levels during the 6 1/2 years between tests. These results bring into question the need for a complete CPT for all HWCs every 5 years.