1

Execution of Comprehensive Performance Test Using 

Particulate, HCl and Metals Continuous Emissions Monitoring 

Systems

Paper #26

Keith Beach1, P.E., Thomas G. Busmann2, P.E., Chris E. McBride2, P.E., Richard H Lambert3, 

and Krag Petterson4

1

Evonik Degussa Corporation, Tippecanoe Laboratories, 1650 Lilly Road, Lafayette, IN 47909 

USA

2

Focus Environmental Inc., 4700 Papermill Drive, Knoxville, TN 37909 USA

3

Eli Lilly and Company, Lilly Corporate Center, Indianapolis, IN 46285 USA

4Cooper Environmental LLC, 10180 SW Nimbus Ave. Suite J6, Portland, OR 97223 USA

ABSTRACT

Evonik Degussa Corporation, Tippecanoe Laboratories successfully demonstrated compliance 

with the HWC MACT Comprehensive Performance Test (CPT) requirements utilizing the 

continuous emission monitors for particulate matter (PM), hydrochloric acid (HCl), and metals 

as the compliance analyses for stack emissions. It is the authors’ belief that this is the first CPT 

conducted in the United States utilizing this approach.

This paper will briefly review the history of the CEMs development on the solid-liquid 

incinerator, provide an overview of the CPT plan and objectives, discuss the performance of the 

CEMs prior to and during the CPT, and present the performance test results. This performance 

test demonstration illustrates that the use of CEMs for performance test demonstration is an 

efficient, effective, and viable approach for compliance demonstration on hazardous waste 

incinerators.

INTRODUCTION

Evonik Degussa Corporation (Evonik) operates a Hazardous Waste Incinerator that burns solids 

and liquid organic and aqueous waste at their newly acquired facility, Tippecanoe Laboratories

(Tippe), in Lafayette, IN. The site was acquired by Evonik in 2010 from Eli Lilly and Company 

(Lilly) and has continued to manufacture pharmaceutical and animal health compounds for Lilly. 

Selected incinerator operating parameters limits and emissions limits are specified by the U. S. 

EPA Hazardous Waste Combustor Maximum Achievable Control Technology (HWC MACT)

rule in order to minimize emissions of Hazardous Air Pollutants (HAPs). Since the early 1990s 

when the MACT rules were initially being considered, EPA has often expressed a desire to use

Continuous Emissions Measurement Systems (CEMS) technology as a means to directly

demonstrate compliance by measuring emissions directly, rather than use operating parameters to 

infer compliance. Several years ago Tippe embarked on a program to evaluate and apply 

available CEMS technologies for particulate matter and hydrogen chloride, and to assist in 

developing a novel CEMS technology for metals.
2

Evonik successfully completed a Comprehensive Performance Test (CPT) in 2010 utilizing 

CEMs for HCl, particulate and the HWC/MACT metals in lieu of standard EPA test methods for

those pollutants. It is the authors’ belief that this is the first CPT conducted in the United States 

utilizing this approach.

HISTORY AND BACKGROUND

A previous Lilly affiliate facility in Ireland employed particulate matter (PM) CEMS and 

infrared multi-component CEMS under a different regulatory structure for a several years as 

indicators of compliance. EPA included the requirement for the application of PM CEMS to

hazardous waste incinerators in the proposed HWC MACT rule in 1996. Tippe, along with a

number of industry peers, demonstrated the limitations of these technologies on certain types of 

hazardous waste incineration systems. EPA subsequently deferred the requirement to implement 

PM CEMS under the HWC MACT. While demonstrating the viability of the PM CEMS, Tippe

joined forces with Cooper Environmental Services to develop practical application of X-ray

fluorescence as a multi-metals CEMS technology use on a solid-liquid waste incinerator.

Tippe has been involved with the testing, evaluation and development of CEMs beginning with 

installations on the liquids incinerators in the 1990s and subsequently on the solids and liquids 

incinerators in the early 2000s.

This development of the use of these CEMS technologies met a couple key Tippe concerns. 

First, using CEMS data for compliance reduced or eliminated the need for sampling and analysis 

of individual containers to develop waste characterization. This addressed the concerns Tippe 

had regarding the costs and potential exposure required by typical sampling and analytical 

programs. Due to the nature of high-potency pharmaceutical wastes, reducing or eliminating the 

typical sampling and analysis activities provided significant safety, operational, and economic 

benefits. 

Second, Tippe was also interested in the benefits from operational flexibility that could be 

realized by removing many of the prescribed HWC MACT operating parameters limits on the 

incinerator’s air pollution control system.

Tippe installed continuous monitoring of the combustion (stack) gas emissions on the solid and 

liquid waste incinerator designated T149 utilizing three CEMS:

 An EcoChem MC3 or equivalent for CO, O2, and HCl

 A Sigrist CTNR or equivalent for particulate emissions

 A Cooper Environmental Services XACT or equivalent for metals.

Since the required use of CEMs for parameters other than CO and O2 was removed from the 

HWC MACT requirements, the use of CEMs for PM, HCl and multi-metals required the 

submission and approval of an alternative monitoring petition. The requirements for petitioning 

the EPA for alternative monitoring for compliance is found in 40 CFR Part 63.8 (f), the General

Provisions of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for 

Source Categories. Paragraph (f)(4)(ii) states:

“The application must contain a description of the proposed alternative

monitoring system which addresses the four elements contained in the definition
3

of monitoring in §63.2 and a performance evaluation test plan, if required, as

specified in paragraph (e)(3) of this section. In addition, the application must

include information justifying the owner or operator's request for an alternative

monitoring method, such as the technical or economic infeasibility, or the

impracticality, of the affected source using the required method.”

Tippe initiated the process for the alternative monitoring petition (AMP) in early 2003. The 

AMP was approved by the EPA in January 2006. Implementation of the AMP then required a 

major modification to the facility’s Title V permit.

CPT OBJECTIVES

To demonstrate compliance with the HWC MACT performance standards and emission limits, 

Tippe proposed a single, low-temperature, combustion chamber test condition, treating solid and 

liquid wastes with enhanced ash, metals and chloride contents. This single test condition 

demonstrated the ability of the combustion system to comply with the applicable performance 

standards at the worst-case conditions of minimum combustion temperatures and maximum 

combustion air flow, and maximum waste, ash, and chloride feed rates. 

Since T149 has not been modified in a way which would affect its ability to meet the DRE 

standard since DRE testing was conducted in September 2005, Tippe did not conduct a DRE test 

during the testing described here. This is in accordance with the provisions of 40 CFR 

63.1206(b)(7)(i)(A), the HWC MACT Replacement Standard requires that compliance with the 

destruction and removal efficiency (DRE) standard must only be documented once, provided that 

the source is not modified after the DRE test in a way that could affect the ability of the source to 

achieve the DRE standard.

Under the provisions of the AMP approved in a letter dated January 27, 2006, the use of a 

particulate matter CEMS, a multi-metals CEMS, and an HCl CEMS to demonstrate compliance 

with the particulate matter, metals, and HCl/Cl2 HWC MACT emission standards was approved 

and Tippe used that provision to demonstrate compliance for this CPT test.

The performance standards established that are applicable for the T149 incinerator are 

summarized in Table 1.

Table 1. HWC MACT Replacement Rule Performance Standards

Performance

Standard

HWC MACT 40 CFR 63 Subpart EEE 

Replacement Standard-existing sources

Citation Standard

Organic DRE 40 CFR 63.1219(c)(1) 99.99%

CO Emissions 40 CFR 

63.1219(a)(5)(i)

100 ppmdv1

HC Emissions 40 CFR 

63.1219(a)(5)(i)

10 ppmdv1, as propane

Particulate Emissions 40 CFR 63.1219(a)(7) 0.013 gr/dscf1

HCl/Cl2 Emissions 40 CFR 63.1219(a)(6) 32 ppmdv HCl/Cl2 combined as Clequivalents1

Metals Emissions 40 CFR 63.1219(a)(3) Cd & Pb combined: 230 g/dscm1
4

Performance

Standard

HWC MACT 40 CFR 63 Subpart EEE 

Replacement Standard-existing sources

40 CFR 63.1219(a)(4) As, Be & Cr combined: 92 g/dscm1

40 CFR 63.1219(a)(2) Hg: 130 g/dscm1

Dioxin/furan 

emissions

40 CFR 

63.1219(a)(1)(ii)

0.40 g/dscm TEQ1

1. CORRECTED TO 7% OXYGEN.

CONTINUOUS MONITORING SYSTEMS PERFORMANCE 

EVALUATION TEST

As a part of the CPT, a performance evaluation of the CEMS was conducted in accordance with 

the CMS PET Plan. The evaluation showed that the Evonik’s CMS was operating in compliance 

with the HWC MACT requirements [40 CFR 63.1209(a)-(b)] as: 

The CEMS monitoring CO and O2 stack gas concentrations met the appropriate performance 

specifications promulgated by the EPA. 

The CEMS monitoring metals, HCl, and particulate met the appropriate performance 

specifications and requirements in the approved AMP using the annual auditing process.

Table 2. CEMS Audit Summary

Monitoring 

System Audit Description Audit Date Result

CO CEMS

Relative Accuracy Test Audit 

(RATA) 8/24/2010 Pass

CO CEMS Calibration Drift 8/18-24/2010 Pass

CO CEMS Calibration Error 8/24/2010 Pass

CO CEMS Response Time 8/24/2010 Pass

O2 CEMS

Relative Accuracy Test Audit 

(RATA) 8/24/2010 Pass

O2 CEMS Calibration Drift 8/18-24/2010 Pass

O2 CEMS Calibration Error 8/24/2010 Pass

O2 CEMS Response Time 8/24/2010 Pass

PM CEMS Response Correlation Audit (RCA) 8/11-12/2010

New 

Calibration 

Curve

PM CEMS Absolute Correlation Audit (ACA) 8/12/2010 Pass

HCL CEMS Accuracy (Dynamic Spiking) 8/24/2010 Pass

HCL CEMS Seven Day Drift 8/22/2010 Pass

Metals CEMS

Total System Flow (Sample 

Volume) 8/4/2010 Pass
5

Metals CEMS

X-Ray Fluorescence Calibration 

Audit 8/9/2010 Pass

Metals CEMS Accuracy (Dynamic Spiking) 8/5-6/2010 Pass

HCl CEMs Audit Methodology

The accuracy and precision of the HCl CEMS is determined by dynamically spiking a known 

concentration of HCl reference gas into the sample system and subsequently measuring the 

reference spike with the HCl CEMS.

Daily, prior to testing, the zero and upscale drift is checked and recorded. The HCl CEMS must 

pass the daily calibration requirements prior to any testing.

This testing was conducted as part of the CMS performance evaluation test.

Figure 1 provides an overview of the regression analysis for the HCl dynamic spiking indicating 

the resulting performance for the HCl CEMs.

Figure 1. Regression analysis of the HCl dynamic spiking accuracy

testing

Criteria Acceptance Limits Results

Pass/Fail 

(Bias)

Correlation Coefficient ( r ) > 0.90 1 Pass

Slope 0.85 - 1.15 1 Pass

Intercept 15 8.3 Pass

y = 0.9891x - 8.3018

R2 = 0.9991

0

10

20

30

40

50

60

70

80

90

100

0 20 40 60 80 100 120

2010 HCL CEMS Accuracy

Measured HCL ppm

Spiked HCL ppm

PM CEMs Audit Methodology

The objective of the annual relative calibration audit is to verify that the current calibration 

correlation is within statistical requirements for predicting total particulate mass based upon 

previous calibration to a particulate mass Reference Method (Method 5).

The RCA is performed by collecting a minimum of 12 valid (meets quality assurance 

requirements) particulate mass Reference Method samples (Method 5) over the expected 

operating range of the control device. The response of the PM CEMS is recorded during each 

Method 5 test and the data averaged to provide a PM CEMS response value (PLA) which 

correlates to a Method 5 data point (mg/scm).

Dual train Reference Method 5 sampling trains are used during the testing ensure the quality of 

the Reference Method particulate mass data.

Once all data is collected, both the Reference Method 5 and PM CEMS data are screened, 

according the Performance Specification 11 and Procedure 2 guidance, and only valid data is 

used for the calibration correlation check.
6

Using the current calibration correlation as the baseline, the Method 5 data is plotted against the 

respective PM CEMS averaged response. A minimum of 75% of the RCA data must fall within 

the current tolerance intervals of the existing calibration correlation.

If the new data does not meet this requirement, Performance Specification 11 provides guidance 

on how to establish a new or updated calibration correlation.

PM CEMS Operating Range

The operating range of the PM CEMS is 0 – 1 PLA. This range will be used for operation of the 

PM CEMS.

PM CEMS Daily Linearity Check 

Daily, prior to any RCA testing, the linearity of the Sigrist photometer is checked. The Sigrist 

must pass applicable quality assurance requirements, daily, and prior to the relative calibration 

audit testing.

Reference Method 5 Data Quality Assurance

Reference Method 5 data collected during the RCA is analyzed to ensure it meets applicable 

quality control requirements. This is completed by performing relative standard deviation for 

each Method 5 test pair (dual train) along with linear regression analysis. In addition, a 

standardized residual test along with a bias check of the data may be used to ensure the 

Reference Method paired data sets are statistically sound for use in the relative calibration audit 

test. Reference Method data which does not meet the quality assurance guidance may be 

discarded, as long as a minimum of 12 Reference Method data points remain. 
7

0

5

10

15

20

Method 5 (mg/scm)

0 0.1 0.2 0.3 0.4 0.5

Sigrist (PLA)

Linear Fit

Method 5 (mg/scm) = 1.2031621 + 35.764502*Sigrist (PLA)

RSquare

RSquare Adj

Root Mean Square Error

Mean of Response

Observations (or Sum Wgts)

0.976932

0.975779

0.958086

9.171818

22

Summary of Fit

Model

Error

C. Total

Source

1

20

21

DF

777.50316

18.35857

795.86173

Sum of

Squares

777.503

0.918

Mean Square

847.0193

F Ratio

<.0001*

Prob > F

Analysis of Variance

Intercept

Sigrist (PLA)

Term

1.2031621

35.764502

Estimate

0.341602

1.228869

Std Error

3.52

29.10

t Ratio

0.0021*

<.0001*

Prob>|t|

Parameter Estimates

Linear Fit

Bivariate Fit of Method 5 (mg/scm) By Sigrist (PLA) Year=2010

Figure 2. Calibration Correlation between the Sigrist PM CEMs and Method 5 train

Particulate Emission Range of Data during the Relative Calibration Audit

The range of the total particulate emissions during the RCA should represent expected 

particulate emission levels during normal operation of the incinerator. 

Per the T149 Alternative Monitoring Petition, Evonik will strive to provide a range of particulate 

emissions in which a minimum of 20% of the data falls into each of three ranges (1) 0-50% (2) 

25-75% (3) 50-100%, with 100% being the highest Sigrist output observed during the testing. In 

addition, the data set of particulate mass emissions should fall within the data range represented 

by the current calibration correlation. The total particulate emission data collected, based upon 

the mg/scm concentrations, fell within three distinct ranges
8

-5

0

5

10

15

20

25

30

35

Method 5 (mg/scm)

0 0.1 0.2 0.3 0.4 0.5

Sigrist (PLA)

Linear Fit Year=="2006"

Linear Fit Year=="2007"

Linear Fit Year=="2009"

Linear Fit Year=="2010"

Linear Fit Year=="Existing"

Linear Fit

Bivariate Fit of Method 5 (mg/scm) By Sigrist (PLA)

Figure 3. Performance Test Fit of Data for Sigrist PM CEMs

Xact Multi-Metal CEMs Audit Methodology

The annual audit requirements for the Xact multi-metal CEMS are to perform a sample volume 

audit, a thin film standard audit, and an accuracy test. The accuracy test, per the T149 

Alternative Monitoring Petition, is performed using dynamic spiking of lead, cadmium, arsenic, 

chromium, and mercury. Linear regression is used to assess the accuracy and precision of the 

Xact CEMS. The Xact CEMS met each of the audit requirements.

The accuracy and precision of the Xact CEMS is demonstrated by quantitatively spiking each of 

the regulated metals (arsenic, chromium, cadmium, lead, mercury) at a minimum of three levels. 

The metals are contained in a stock nitric acid solution and quantitatively spiked into the sample 

system, directly in back of the sample probe, using a quantitative aerosol generator. The 

concentration for each spiking trial is controlled by altering the mass loss rate of the aerosol 

generator and/or changing the concentration of the stock metals solution.

The range of metal concentrations tested encompasses the regulatory limits for each metal and 

are within the linear range of the Xact CEMS.
9

For each test level, a minimum of nine sample points are recorded. The output of the Xact multimetals CEMS, for each MACT metal, is plotted against the reference metal value from the 

dynamic spiking. Regression analysis is performed and the correlation coefficient, slope, and 

intercept, for each MACT metal recorded.

Plotted Linear Regression for Lead

y = 1.0387x + 2.2754

R

2

 = 0.9948

0.00

50.00

100.00

150.00

200.00

250.00

0.00 50.00 100.00 150.00 200.00

Reference Concentration (μg/dscm)

Xact C

oncentration

(μg/dscm)

Figure 4. Plot of Linear Regression for Lead from Xact CEMs

Plotted Linear Regression for Mercury

y = 1.0219x + 1.843

R

2

 = 0.9941

0

50

100

150

200

0 50 100 150 200

Reference Concentration (μg/dscm)

Xact Concentration

(μg/dscm)

Figure 5. Plot of Linear Regression for Mercury from Xact CEMs

Plotted Linear Regression for Arsenic

y = 1.0611x + 1.6166

R

2

 = 0.995

0

50

100

150

200

250

0 50 100 150 200

Reference Concentration (μg/dscm)

Xact Concentration

(μg/dscm)

Figure 6. Plot of Linear Regression for Arsenic from Xact CEMs
10

Plotted Linear Regression for Cadmium

y = 1.1066x + 2.9945

R

2

 = 0.9912

0

50

100

150

200

250

0.00 50.00 100.00 150.00 200.00

Reference Concentration (μg/dscm)

X

a

ct C

onc

entration

(μg/dsc

m)

Figure 7. Plot of Linear Regression for Cadmium from Xact CEMs

Plotted Linear Regression for Chromium

y = 0.9747x + 3.7603

R

2

 = 0.996

0

50

100

150

200

0.00 50.00 100.00 150.00 200.00

Reference Concentration (μg/dscm)

Xact C

oncentration

(μg/dscm)

Figure 8. Plot of Linear Regression for Chromium from Xact CEMs

COMPREHENSIVE PERFORMANCE TEST RESULTS

The T149 CPT was conducted September 28-29, 2010, utilizing the of a particulate matter 

CEMS, a multi-metals CEMS, and an HCl CEMS. 
11

Table 3. T149 HWC MACT Compliance Performance and Emissions Summary

HWC 

MACT T149 2010 CPT Results

Parameter Units Standard Run 1 Run 2 Run 3 Average

Stack gas particulate matter (Note 

a) gr/dscf 0.013 0.013 0.012 0.012 0.012

Stack gas HCl/Cl2 (Notes a, b) ppmv, dry 32 4.2 3.0 3.9 3.7

Stack gas LVM (Note a) μg/dscm 92 < 2.7 < 2.7 < 3.3 < 2.9

Stack gas SVM (Note a) μg/dscm 230 19 17 18 18

Stack gas mercury (Note a) μg/dscm 130 21 23 18 21

Notes:

(a) Corrected to 7% oxygen.

(b) HCl and Cl2 combined, expressed as HCl or Clequivalents.
12

Parameter Units Average

Stack Sampling Parameters

Stack gas flow rate dscfm 18,378 18,279 18,452 18,370

dscm/min 520.5 517.7 522.6 520.2

Stack gas oxygen content vol %, dry 9.0 9.0 9.4 9.1

Particulate Emissions by Sigrist CTNR CEMS

Particulate concentration gr/dscf 0.0127 0.0120 0.0125 0.0124

gr/dscf @ 7% O2 0.0129 0.0115 0.0116 0.0120

mg/dscm 29.1 27.4 28.5 28.3

mg/dscm @ 7% O2 29.5 26.4 26.6 27.5

Particulate emission rate lb/hr 2.00 1.88 1.97 1.95

g/s 0.252 0.237 0.248 0.246

Chloride Emissions by EcoChem MC3 CEMS

ppmv, dry 2.76 1.69 2.44 2.30

ppmv, dry @7% O2

4.23 2.98 3.93 3.71

lb/hr 0.284 0.173 0.252 0.236

g/s 0.0358 0.0217 0.0317 0.0297

lb/hr 0.276 0.168 0.245 0.230

g/s 0.0348 0.0211 0.0308 0.0289

Arsenic by Cooper Environmental Services XACT CEMS

Metal concentration ug/dscm 0.95 0.88 1.04 0.96

ug/dscm @ 7% O2 1.11 1.02 1.26 1.13

Metal emission rate lb/hr 6.5E-05 6.0E-05 7.2E-05 6.6E-05

g/s 8.2E-06 7.6E-06 9.1E-06 8.3E-06

Stack gas HCl concentration as HCl

or ClStack gas HCl emission rate as HCl

Stack gas HCl emission rate as Cl

-

Run 1 Run 2 Run 3

Table 4. T149 CPT Particulate, HCl, and Arsenic Emissions Summary
13

Parameter Units Average

Cadmium by Cooper Environmental Services XACT CEMS

Metal concentration ug/dscm 2.40 2.57 2.52 2.49

ug/dscm @ 7% O2

2.80 3.00 3.04 2.95

Metal emission rate lb/hr 1.7E-04 1.8E-04 1.7E-04 1.7E-04

g/s 2.1E-05 2.2E-05 2.2E-05 2.2E-05

Chromium by Cooper Environmental Services XACT CEMS

Metal concentration ug/dscm 1.26 1.36 1.63 1.42

ug/dscm @ 7% O2 1.48 1.59 1.97 1.68

Metal emission rate lb/hr 8.6E-05 9.3E-05 1.1E-04 9.7E-05

g/s 1.1E-05 1.2E-05 1.4E-05 1.2E-05

Lead by Cooper Environmental Services XACT CEMS

Metal concentration ug/dscm 13.82 12.23 12.77 12.94

ug/dscm @ 7% O2

16.10 14.33 15.45 15.29

Metal emission rate lb/hr 9.5E-04 8.4E-04 8.8E-04 8.9E-04

g/s 1.2E-04 1.1E-04 1.1E-04 1.1E-04

Mercury by Cooper Environmental Services XACT CEMS

Metal concentration ug/dscm 18.38 19.69 14.80 17.62

ug/dscm @ 7% O2 21.42 23.04 17.82 20.76

Metal emission rate lb/hr 1.3E-03 1.3E-03 1.0E-03 1.2E-03

g/s 1.6E-04 1.7E-04 1.3E-04 1.5E-04

Note: dscf = Dry standard cubic feet

 dscfm = Dry standard cubic feet per minute

Standard conditions are 68°F, 29.92 in. Hg (20°C, 760 mm Hg)

Run 1 Run 2 Run 3

Table 5. T149 CPT Cadmium, Chromium, Lead and Mercury Metals Emissions Summary
14

The following figures (Figures 9 -13) show the operating data from theT149 CEMs systems 

during the performance of the CPT.

20

30

40

Particulate mass 1-minute - P

M

mg/dscm (1-minute uncompressed)

28Sep2010 10:21:45 A

M

28Sep2010 11:13:45 A

M

28Sep2010 12:05:45 P

M

28Sep2010 12:57:45 P

M

29Sep2010 8:03:45 A

M

29Sep2010 8:55:45 A

M

29Sep2010 9:47:45 A

M

29Sep2010 10:39:45 A

M

29Sep2010 11:31:45 A

M

29Sep2010 2:16:45 P

M

29Sep2010 3:08:45 P

M

29Sep2010 4:00:45 P

M

29Sep2010 4:52:45 P

M

29Sep2010 6:05:45 P

M

Sigrist 1 min time

Levey Jennings of Particulate mass 1-minute - PM mg/dscm (1-minute uncompressed)

Figure 9. 
15

20

25

30

35

Particulate mass 15-minute block average

mg/dscm

@ 7% O2 (15-minute uncompressed)

1 2 3

09/28/2010 10:30 AM09/28/2010 11:30 AM09/28/2010 12:30 PM

09/28/2010 1:30 PM09/29/2010 8:45 AM09/29/2010 9:45 AM

09/29/2010 10:45 AM09/29/2010 11:45 AM

09/29/2010 2:30 PM09/29/2010 3:30 PM09/29/2010 4:30 PM09/29/2010 5:30 PM09/29/2010 6:30 PM

MACT Metals 15 Minute data sample end

date/time (triggered and uncompressed)

Individual Measurement of Particulate mass 15-minute block average mg/dscm @ 7% O2 (15-minute uncompressed)

Figure 10. 
16

-5

0

5

10

15

20

25

30

35

M

A

C

T

Metals - Hg ug/dscm

@ 7%

O2 (triggered and uncompressed)

1 2 3 3after

09/28/2010 11:45 A

M

09/29/2010 8:30 A

M

09/29/2010 11:00 A

M

09/29/2010 3:15 P

M

09/29/2010 5:45 P

M

MACT Metals 15 Minute data sample end

date/time (triggered and uncompressed)

Levey Jennings of MACT Metals - Hg ug/dscm @ 7% O2 (triggered and uncompressed)

Figure 11. 
17

-2

0

2

4

6

8

10

12

14

M

A

C

T

Metals - LV

M ug/dscm

@ 7%

O2 (triggered and uncompressed)

1 2 3 3after

09/28/2010 11:45 A

M

09/29/2010 8:30 A

M

09/29/2010 11:00 A

M

09/29/2010 3:15 P

M

09/29/2010 5:45 P

M

MACT Metals 15 Minute data sample end

date/time (triggered and uncompressed)

Levey Jennings of MACT Metals - LVM ug/dscm @ 7% O2 (triggered and uncompressed)

Figure 12. 
18

-40

-30

-20

-10

0

10

20

30

40

50

60

70

M

A

C

T

Metals - S

V

M ug/dscm

@ 7%

O2 (triggered and uncompressed)

1 2 3 3after

09/28/2010 11:45 A

M

09/29/2010 8:30 A

M

09/29/2010 11:00 A

M

09/29/2010 3:15 P

M

09/29/2010 5:45 P

M

MACT Metals 15 Minute data sample end

date/time (triggered and uncompressed)

Levey Jennings of MACT Metals - SVM ug/dscm @ 7% O2 (triggered and uncompressed)

Figure 13. 

Table 6. Metals SRE Comparison

Metal 2010 (CEMs) 2005 (Method 29)

Total LVM 99.998% 99.998%

Pumpable LVM 99.93% 99.85%

SVM 99.83% 99.74%

Hg 45.70% 17.6%
19

SUMMARY

Specific conclusions drawn from the 2010 CPT are as follows:

 PM emission standard was met. A maximum ash feed rate limit can be 

appropriately developed from the T149 CPT results.

 Metal emission standards were met for Hg, SVM, and LVM. Maximum metal 

feed rates can be reliably and appropriately determined using the T149 CPT 

results.

 Stack gas HCl/Cl2 emission standard was met. A maximum total chlorine feed 

rate limit can be appropriately established from the T149 CPT results.

Use of CEMs is a viable approach for CPT compliance demonstration.

For certain incineration facility, a number of benefits can be realized through use of CEMs for 

demonstration of compliance for emissions:

 Improved safety, improved operation efficiency, and economic advantages for waste 

characterization

 Operational flexibility for the incineration system

 Optimization of the establishment of operating parameter limits during the performance 

of the CPT.

ACKNOWLEDGEMENTS

REFERENCES

1. American Society for Testing and Materials, "Annual Book of ASTM Standards," latest annual 

edition.

2. Code of Federal Regulations, 40 CFR 264, 40 CFR 270, 40 CFR 63 Subpart EEE, and 40 CFR 

63 Subpart A.

3. USEPA, "New Source Performance Standards, Test Methods and Procedures,” Appendix A, 40 

CFR 60.

4. USEPA, "Test Methods for Evaluating Solid Wastes," Third Edition, 1986, and Updates.

5. T149 SOLID-LIQUID WASTE INCINERATOR, COMPREHENSIVE PERFORMANCE TEST 

PLAN, Evonik Degussa Corporation., Tippecanoe Laboratories, September 2009

6. CONTINUOUS MONITORING SYSTEMS PERFORMANCE EVALUATION TEST REPORT, , 

Evonik Degussa Corporation., Tippecanoe Laboratories, December, 2010

7. T149 SOLID-LIQUID WASTE INCINERATOR, COMPREHENSIVE PERFORMANCE TEST 

REPORT, Evonik Degussa Corporation., Tippecanoe Laboratories, December 2010
20

8. INTIAL PERFORMANCE TEST AND USE OF ALTERNATIVE MONITORING SYSTEMS FOR 

METALS, PM AND HCL FOR COMPLIANCE WITH THE HAZARDOUS WASTE COMBUSTOR 

MACT, Eli Lilly and Company, Richard H Lambert, Michael L Foster

KEY WORDS

1. Continuous Emission Monitoring Systems

2. Hazardous Waste Combustor MACT Emission Compliance

3. Incinerator Emission Monitoring

4. Multi-Metals Continuous Emission Monitoring

5. Total Particulate Continuous Emission Monitoring

6. Hydrogen Chloride Continuous Emission Monitoring

7. Comprehensive Performance Test