Abstract
Perceived needs to identify easily measured surrogates for products of incomplete combustion (PICs) from hazardous wastes incinerators have spawned a spirited scientific debate. Can any simple surrogates be correlated with PICs? What surrogates can be measured and at what levels? How should surrogates be normalized, averaged, and reported? Carbon monoxide (CO) and total hydrocarbons (THC) are two possible candidates. Interim guidelines of 100 ppm for CO and 20 ppm for THC have been suggested by the U.S. EPA for use by permit writers. Formal proposal, public comment, and promulgation as regulatory standards are being considered. Although CO, and possibly THC, have some utility as parameters of operation, both have recognized limitations as parameters of performance. There are also shortcomings in their measurement, normalization and statistical averaging. Correlations of CO or THC with PICs, or with each other, are not quantitative. Continuous emission monitoring (CEM) is difficult. Interpretation of results is equivocal. Alternatives to technology-forcing “guidelines” are needed. Flexible control strategies, further development of CEM monitoring technology, valid statistical analysis of emissions, and consideration of composite parameters are encouraged.
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