How the TSCA Incinerator is Used
How the TSCA Incinerator Works
Ensuring Safe Operation
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Emissions Monitoring
NESHAP Emission Sampling for Radionuclides
The Environmental Protection Agency (EPA) has established National Emission Standards for Hazardous Air Pollutants (NESHAP) which "provide an ample margin of safety" to protect the public health. NESHAP for radionuclide emissions from DOE facilities require that emissions of radionuclides, other than radon, "shall not exceed those amounts that would cause any member of the public to receive in any year an effective dose equivalent of 10 mrem/yr." The TSCA Incinerator is administratively controlled to contribute no more than 75 percent, or 7.5 mrem, of this regulatory limit. To determine compliance with this standard, EPA requires that radionuclide emissions be determined using EPA-approved sampling procedures, and effective dose equivalent values be calculated using EPA-approved computer models.
In the NESHAP sampling system, sample gas is withdrawn from the exhaust stack onto a heated filter to collect the particulate. A heated sample line then transfers the stack gas sample to the actual sampling train located in a building at ground level. After the sample gas enters the building, a condenser cools the gas, and the resulting condensate drains into a 30-gallon tank. The sample gas then passes through a series of impingers, which are used to collect gaseous radionuclides. Because of the high moisture content of the exhaust stream, the sample gas is subsequently passed through a series of drying tubes before entering the mass flow meter, vacuum pump, and dry gas meter. The sample gas is pulled through the system for a week, then the nozzle, probe, filter, filter holder, impingers, and drying tubes are replaced. The filter, impinger contents, and solution used to wash the nozzle and probe are submitted for analysis. The amount of water condensed is measured, and a representative sample of the condensate is also submitted for analysis.
A summary of the radionuclide emissions is provided in the Annual Site Environmental Report (ASER).
Visible Emissions Monitoring
The incinerator's operating permit states that "Visible emissions emitted from this source shall not exceed 2 percent opacity." Incinerator personnel are required to record certain information from a visible emission observation in the field documentation. To comply with the permit, qualified individuals who have successfully participated in Visible Emissions Training every six months read the stack plume quarterly during waste treatment operations.
Ambient Air Monitoring for Uranium and Semivolatiles
Safety is key to the operation of the incinerator, and it is operated in a manner to preclude the release of potentially hazardous materials to the atmosphere. However, if certain abnormal operating conditions arise, an opening of the thermal relief vent (TRV) to avoid overheating the air pollution control system equipment could occur. Even though a TRV event represents the "worst-case" possibility for releasing potentially hazardous materials to the atmosphere the off-site consequences would be minimal because of the very short duration and shutdown of the waste feed systems.
Two ambient air monitoring stations were designed, built, and positioned to show possible impact to the environment near populated areas around East Tennessee Technology Park should a TRV event occur.
The Ambient Air Monitoring Program monitors releases from the incinerator during an emergency upset. Data from this monitoring effort are used to model possible environmental and health effects due to uranium and semivolatile organics to the surrounding communities. The TSCA Incinerator Ambient Air Monitoring Program consists of two sampling stations for the detection of uranium and semivolatile organics. One monitoring station is located in the vicinity of the nearest resident to the incinerator, and the second is located on old Powerhouse Road, which represents emissions to the most affected resident. The collection of samples is activated remotely by a signal from a computer in the TSCA Incinerator Control Room. The samplers will activate when the TRV opens. Emissions data and calulated doses from the TRV events are included in the Annual Site Environmental Report (ASER).
Batch Metals Continuous Sampling System
A continuous sampling system for measuring metals emissions was installed and began trial operation in October 1998. The sampling system continuously extracts gas from the stack for a one-week period. The gas flows through a set of filters, which collect particle phase and gas phase metals. The filters are taken to a laboratory and analyzed for a suite of metals. The system resumed trial operation in 1999 and underwent a test to validate the performance of the system. Since then, it has been used to collect metal emissions data under routine operating conditions.
Particulate Matter Continuous Emission Monitor
A particulate matter (PM) CEMS was installed in 2005 for the purpose of demonstrating routine continuous monitoring of particulate matter emissions from the TSCA Incinerator. The device selected for deployment was the BetaGuard PM manufactured by Mechanical Systems, Inc. The BetaGuard PM is a beta gauge type monitor that measures the flue gas concentration of particulate matter in a batch-wise fashion. Flue gas is extracted from the stack and sampled onto a filter tape. The sample spot is interrogated before and after the sampling event using a beta source, and the mass of particulate matter collected on the filter tape is determined by difference. The volume of gas sampled is measured and used to calculate the PM concentration in the flue gas sample. The BetaGuard PM is designed to meet the performance specifications and quality assurance requirements promulgated by the EPA for PM CEMS.
Technology Demonstrations for Continuous Emission Monitoring
DOE has tested and evaluated new technologies for continuous stack monitoring of certain pollutants at the incinerator. The primary objective of this experimental monitoring is to eventually develop real-time stack emissions monitor(s) of these pollutants.
Recent advancements in sampling and analytical technology have allowed development of a suite of instrumentation that may provide more frequent measurements of pollutants in gas streams. Continuous emission monitoring (CEM) has gained wide recognition in recent years with development of continuous and semi-continuous CEM systems that can measure gaseous emissions from industrial sources in a near-real-time and real-time manner.
The incinerator staff has been closely following the advancement of monitoring technologies and has encouraged the use of the incinerator as a test site for demonstrating the field performance of these systems. Following are some of the CEM demonstrations that have been performed at the incinerator over the past few years:
- Fourier Transform Infrared Spectrometer - A FTIR spectrometer, developed by Argonne National Laboratory, was field tested at the incinerator three times from 1993 to 1995. FTIR technology has been demonstrated to excel at measuring volatile organic compounds, carbon monoxide, and hydrogen chloride.
- Direct Sampling Ion Trap Mass Spectrometer - This device was tested over a several-week period at the incinerator in 1994. The purpose of this test was to determine the feasibility of monitoring semivolatile compounds (PCBs, dioxins, and furans) in stack emissions with the ion trap mass spectrometer.
- SPICAP Multi-Metals Continuous Sampling System - Midwest Research Institute has developed an innovative method for continuously monitoring metal emissions, which is referred to as SPICAP. It consists of a wet collection device that collects pollutants from a gas stream. The pollutant-bearing liquid stream is directed into an inductively coupled plasma (ICP) analyzer, where the stream is analyzed for metals. Testing of the SPICAP sampling system was performed at the incinerator in 1996.
- Multi-Metals Monitoring System Evaluation - A field study to evaluate the deployment of three candidate monitoring techniques for measuring metal emissions was conducted in 1997. These systems were the TraceAIR inductively coupled plasma (ICP) based monitor manufactured by Thermo Jarrell Ash Corporation; a laser-induced breakdown spectroscopy (LIBS) based monitor developed by Sandia National Laboratories; and the Hazardous Element Sampling Train (HEST) developed by Cooper Environmental Services. The primary objectives of the tests were to assess the best available monitoring technology for measuring metal emissions, determine the deployment potential of the monitors tested, and propose recommendations for future testing, evaluation, and deployment. Results showed that neither the TraceAIR monitor nor the LIBS monitor provided reliable metal emission data. The HEST sampling train met the performance criteria for more than half of the test conditions. Therefore, the installation and long-term evaluation of a batch sampling system similar to the HEST system was recommended as an interim solution until multi-metals continuous emission monitoring systems can be shown to be more reliable.
- Total Mercury Continuous Emission Monitor - A total mercury CEMS manufactured by SICK, Inc. (formerly Perkin Elmer) and marketed by Aldora Technologies under the name MERCEM was tested in 1998 to determine the performance of a commercially available mercury emissions monitor under wet stack conditions.
Click here for an executive summary of the field evaluation.
- Particulate Matter CEMS Evaluation - A field study to evaluate the performance of three commercially available particulate matter (PM) continuous emission monitors (CEMs) was conducted over a 15-month period in 1999-2000.
Click here for an executive summary of the field test.
Mercury Continuous Emission Monitor Evaluation
In August-September 2002, six mercury CEMs were evaluated in a seven-week long field test at the TSCA Incinerator. The test was conducted for the purpose of evaluating mercury monitoring technologies for possible deployment at DOE facilities. This performance evaluation also served as part of the Phase 2 testing of mercury CEMs by the EPA Environmental Technology Verification (ETV) program. Mercury CEMs participating in the evaluation were the Envimetrics Argus-Hg 1000; Genesis Laboratory Systems, Inc. Quick Silver Sky Monitor; Nippon Instruments Corporation MS-1/DM-5 and DM-6/DM-6P; OPSIS AB Hg-200; and PS Analytical, LTD Sir Galahad II. An initial and final series of paired train Ontario Hydro (OH) reference method sampling runs were conducted to evaluate the performance of the CEMs while sampling and monitoring mercury emissions in the TSCA Incinerator flue gas. During the interim five-week period, the CEMs were operated and maintained by trained facility personnel. Mercury standard gases were used to challenge the CEMs for conducting calibration span checks, and the stability of the standards themselves was evaluated. The operation and maintenance requirements of the monitors were assessed, and issues associated with moving mercury CEMs out of the pilot-scale test arena and into an operating facility environment were identified. Click here (http://www.epa.gov/nrmrl/std/etv/vt-ams.html) and follow the link “Mercury emission monitors” to view ETV reports of the verified technologies.
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