VES 001918.pdf 
VEOLIA ES TECHNICAL SOLUTIONS, L.L.C. RESPONSES TO THE UNITED STATES 

ENVIRONMENTAL PROTECTION AGENCY'S REQUEST TO PROVIDE 

INFORMATION PURSUANT TO THE CLEAN AIR ACT DATED JANUARY 29, 2009 

Exhibits A - B 
A 

V E S 00191S 
ONYX ENVIRONMENTAL SERVICES 

SAUGET, IL 

DOCUMENT OF COMPLIANCE 

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR 

POLLUTANTS FROM HAZARDOUS WASTE COMBUSTORS 

40 CFR PART 63, SUBPART EEE 

JUNE 30, 2004 
ONXX 

ONYX ENVIRONMENTAL SERVICES 

SAUGET, IL 

DOCUMENT OF COMPLIANCE 

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR 

POLLUTANTS FROM HAZARDOUS WASTE COMBUSTORS 

40 CFR PART 63, SUBPART EEE 

JUNE 30, 2004 

Onyx Environmental Services certifies that: 

(i) Required CEMs and CMS are installed, calibrated, and 

continuous operating in compliance with the 

requirements of this subpart; and 

(ii) Based on an engineering evaluation prepared under 

my direction or supervision in accordance with a 

system designed to ensure that qualified personnel 

properly gathered and evaluated the information and 

supporting documentation, and considering at a 

minimum the design, operation, and maintenance 

characteristics of the combustor and emission 

control equipment, the types, quantities, and 

characteristic of feedstreams, and available 

emissions data: 

' (A) Onyx Environmental Services is in compliance 

with the emission standards of this subpart; and 

(B) The limits on the operating parameters under 

63.1209 ensure compliance with the emission 

standards of this subpart. 

General Manager 

Onyx Environmental Services, L.L.C. 

#7 Mobile Avenue, Sauget IL 62201 

Tel: 618 271 2804 • Fax: 618 271 2128 

Environment 

V E S 001921 
DOCUMENT OF COMPLIANCE 

TABLE OF CONTENT 

Applicable Emission Standards Section 1 

And Operating Parameters 

Start-up, Shutdown and Section 2 

Malfunction Plan 

Operating and Maintenance Plan 

CMS Plan 

ESV Plan 

AWFCO Plan 

Feed Stream Analysis Plan 

CEMs Plan (QA/QC Plan) 

Relative Accuracy Test Audit Section 3 

For CEMs 

Specification Sheets for Hydrated Lime Section 4 

Specification Sheets for Carbon 

Residence Time Calculations 

Operator Certification Training Section 5 
HWC MACT Emission Standards 

Parameter 

Dioxin/Furan (D/F) 

Mercury (Hg) * 

Semivolatile Metals (SVM) 

Cadmium, Lead * 

Low Volatile Metals (LVM) 

Arsenic, Beryllium, Chromium * 

Carbon Monoxide (CO) 

Mydrogen Chloride/Chlorine 

tHCl/C12) 

Particulate 

Units Standard 

ng/dscm TEQ 0.20 

ug/dscm 

ug/dscm 

ug/dscm 

ppmv 

ppmv 

mg/dscm 

130 

240 

97 

100 

77 

34 

Method of Compliance 

Operating Parameter 

Limits 

Operating Parameter 

Limits 

Operating Parameter 

Limits 

Operating Parameter 

Limits 

Continuous Emissions 

Monitor 

Continuous Emissions 

Monitor 

Operating Parameter 

Limits 

* Based on incinerator performance testing results for emissions of the three metals classifications, feed 

limitations for Hg, SVM, and LV M have been linearly extrapolated to a level equivalent to eighty percent of 

the respective emission standard. 

V ES 
UNITS 2/3 OPERATING PARAMETERS 

Operating Parameter Units Limits Data in Lieu Test 

Performance 

Standards 

Maximum Total Pumpable TLb/ia 3123 

Waste (Hourly Rolling Total) 

Maximum Total Hazardous Lb/hr 4301 

Waste (Hourly Rolling Total) 

Maximum Stack Gas Flow Acfm 15,534 

Rate (Hourly Rolling Average) 

Minimum Primary Combustion DegF 1712 

Chamber Temperature (Hourly 

Rolling Average) 

Mmimum Secondary Combustion Deg F 1845 

Chamber Temperature (Hourly 

jolling Average) 

Maximum Baghouse Met Deg F 420 

Temperature (Hourly Rolling 

Average) 

Maximum Low Volatile Metals Lb/hr 1264 

Feedrate (12 Hour Rolling Total) 

Maximum Semi Volatile Mends Lb/hr 3477 

Feedrate (.12 Hour Rolling Total) 

-Maximum Mercury Feed rate Lb/hr 0.0073 

(12 Hour Rolling Total) ' 

Maximum Chlorine Feed rate Lb/hr . " 237 

(12 Hour Rolling Total) 

Maximum Ash Feed Rate (12 Lb/hr . 673 

Hour Rollmg Total) 

May, 2004 

May, 2004 

Sept., 2003 

May, 2004 

Test Report 

from 1/21/97 

May, 2004 '. 

Sept., 2003 

Sept., 2003 

May, 2004 . 

Test Report 

•from 1/21/97 

Test Report 

from 1/21/97 

DRE, D/F 

DRE, D/F 

DRE, D/F, 

Part., SVM, 

L V M 

DRE, D/-F 

DRE, D/F 

D/Fj SVM, 

L V M 

L V M 

S V M 

Hg 

SVM, LV M 

Part. 

V ES 
UNIT 4 OPERATING PARAMETERS 

Operating Parameter Units Limits Data in Lieu Test 

Performance 

Standards 

Maximum Total Pumpable Lb/hr 4262 

Waste (Hourly Rolling Total) 

Maximum Total Hazardous Lb/hr 14,802 

Waste (Hourly Rolling Total) 

Maximum Stack Gas Flow Acfm 43,900 

Rate (Hourly Rolling Average) 

Minimum Primary Combustion Deg F 1507 

Chamber Temperature (Hourly 

Rolling Average) 

Minimum Secondary Combustion DegF 1886 

hamber Temperature (Hourly 

tolling Average) 

Maximum Baghouse Inlet Deg F 435 

Temperature (Hourly Rolling 

Average) 

Maximum Low Volatile Metals Lb/hr 120 

Feedrate (12 Hour Rolling Total) 

Maximum Semi Volatile Metals Lb/hr 117 

Feedrate (12 Hour Rolling Total) 

Maximum Mercury Feed rate Lb/hr 0.067 

(12 Hour Rolling Total) 

Maximum Chlorine Feed rate Lb/hr 274 

(12 Hour Rolling Total) 

Maximum Ash Feed Rate (12 Lb/hr 8777 

Hour Rolling Total) 

^^o n Injection Feedrate Lb/hr 6 

iourly Rolling Average) 

Sept., 2003 

Cond. 1 

Sept., 2003 

Cond. 1 

Sept., 2003 

Cond. 1 

Sept., 2003 

Cond. 1 

Sept., 2003 

Cond. 1 

Sept., 2003 

Cond. 1 

Sept., 2003 

Cond. 1 

Sept., 2003 

Cond. 1 

May, 2004 

Sept., 2003 

Cond. 1 

Test Report 

from 2/22/96 

May, 2004 

DRE, D/F 

DRE, D/F 

DRE, D/F, 

Part., SVM, 

L V M 

DRE. D/F 

DRE , D/F 

D/F, SVM, 

L V M 

L V M 

S VM 

Hg 

SVM, LV M 

Part. 

D/F, Hg 
Compliance with the Hydrogen Chloride and Chlorine 

Gas Standard in $63.1209 (o) (4) 

The HWC MACT Rule emission limit for HC1/C12 is 77 ppm. Veolia 

demonstrated compliance with this emission limit on Units 2, 3, and 4. HCI/CI2 

emissions during these tests were well below the 77 ppm Umit. Actual emissions 

during these tests were less than 22 ppm for all three incinerators. Utilizing data 

from these tests, operating parameters have been developed that provide a point of 

compliance with §63.1209 (o) (4). 

Below is a summary of the relative test data from these tests. 

Unit .23 4 

Test Date Jan. 1993 Nov. 1996 Dec. 1995 

Average Lime Slurry Flow 6.5 gpm 6.6 gpm 16.8 gpm 

Average Chlorine Feed 218 lb/hr 233 lb/hr 746 lb/hr 

Ratio of Average Chlorine Feed 33.5 35.3 44.4 

to Average Lime Slurry Flow 

Minimum sorbent and carrier fluid flow is established based on the ratio ofthe 

average chlorine feed to the average lime slurry flow for the tests conducted. The 

maximum ratio at which an incinerator can operate in compliance and in 

accordance with the test performance is 33.5,35.3 and 44.4, respectively for Units 

2, 3, and 4. This method utilized the test data to establish a minimum slurry flow 

rate based on chlorine feed rate. This ratio is calculated in the control systems of 

each unit on a real-time basis using the ratio of hourly rolling total chlorine feed 

divided by the hourly rolling average lime slurry flow. Operating parameter 

limits (OPL's) are set at the maximum ratio values stated above at all three unite; 
STARTUP, SHUTDOWN AND MALFUNCTION PLAN 

Prepared for: 

Onyx Environmental Services, Inc. 

Sauget, Illinois 

Prepared by: 

Franklin Engineering Group, Inc. 

Franklin, Tennessee 

June 2004 
TABL E O F CONTENT S 

1.0 INTRODUCTIO N . ~ 1 

1 -1 REGULATORY REQUIREMENTS 2 

l .2 RECORDKEEPING AND REPORTING PROCEDURES 2 

1.2.1 Records 4 

1.2.2 Reports = i 

2.0 ENGINEERIN G DESCRIPTIO N 6 

3.0 STARTU P AN D SHUTDOW N PROCEDURE S 1 3 

3.1 STARTUP ; 13 

3.2 NORMAL SHUTDOWN ; 15 

4.0 MALFUNCTION S - — —1 6 

4.1 MEASURES to MINIMIZE THE FREQUENCY OF MALFUNCTIONS .-. 16 

4.2 MEASURES TO MINIMIZE THE SEVERITY OF MALFUNCTIONS .....18 

4.3 CORRECTIVE MEASURES 19 

i 

V ES 00192f 
LIS T O F TABLE S 

TABLE 1 -1 OVERVIEW OF REGULATIONS REGARDING STARTUP, SHUTDOWN AND 

MALFUNCTION .- . 3 

TABL E 4-1 SUMMARY OF POTENTIAL MALFUNCTIONS AND CAUSES : 17 

TABLE 4-2 REDUNDANT EQUIPMENT AN D SYSTEMS FOR MINIMIZING THE FREQUENCY 

OR SEVERITY OF MALFUNCTIONS 2 0 

LIS T O F FIGURE S 

FIGURE 2-1 FIXED HEARTH INCINERATOR, UNIT2 , BLOCKFLO W DIAGRA M 7 

FIGURE 2-2 FIXED HEARTH INCINERATOR, UNIT 3, BLOCKFLO W DIAGRA M ; 8 

FIGURE 2-3 ROTARY KIL N INCINERATOR, UNIT 4, BLOCKFLO W DIAGRA M 11 

LIS T O F ATTACHMENT S 

ATTACHMENT 1 STARTUP RECORDKEEPING FORM 

ATTACHMENT 2 SHUTDOWN RECORDKEEPING FORM 

ATTACHMENTS MALFUNCTION RECORDKEEPING FORM 

ATTACHMENT 4 PROGRAM O F CORRECTIVE ACTIONS FOR MALFUNCTIONS 

ii 
1.0 INTRODUCTION 

Onyx Environmental Services, Inc. (Onyx) owns and operates two fixed hearth incinerators 

(Units 2 and 3) and a rotary kiln incinerator (Unit 4) at its facility located in Sauget, Illinois. The 

incinerators are subject to the National Ernissions Standards for Hazardous Air Pollutants 

(NESHAP) for Hazardous Waste Combustors (HWC), codified as 40 CFR, Part 63, Subpart EEE 

(§ 63.1200 to § 63.1213). The NESHAP specifies emissions standards which reflect emissions 

performance of Maximum Achievable Control Technologies (MACT), and is commonly referred 

to as the HWC MACT. 

The HWC MACT Standard defines the control of emissions during normal, day-to-day 

operations. In order to address the control of emissions during transient periods, the 

development of a Startup, Shutdown, and Malfunction Plan (SSMP) is required Startup, 

shutdown, and malfunction (SSM) are defmed in 

• Startup - the setting in operation of ah affected source or portion of an affected source for 

any purpose 

• Shutdown - the cessation of operation of an affected source or portion of an affected 

source for any purpose 

• Malfunction - any sudden, infrequent, and not reasonably preventable failure of air 

pollution control and monitoring equipment, process equipment, or a process to operate 

in a normal or usual manner which causes, or has the potential to cause, the emission 

limitations in an applicable standard to be exceeded. Failures that are caused in part by 

poor mamtenance or careless operation are not malfunctions 

During these transient periods of operations, a source must conform with its SSMP. Therefore, 

during periods of startup, shutdown, and malfunctions the operating and mamtaming of the 

incinerator will be consistent with the procedures and corrective actions that are prescribed in 

this plan. This will ensure that emissions are minimized, to the extent practical. 

The purpose of this startup, shutdown, and malfunction plan is to: 

• Prescribe procedures for operating the incinerator systems during periods of startup, 

shutdown, and malfunction that are consistent with safety and good air pollution control 

practices 

• Describe measures for the prevention and minimization of excess emissions during 

periods of startup, shutdown, and malfunction 

• Reduce the reporting burden associated with periods of startup, shutdown, and 

malfunction 

• Satisfy the requirements of § 63.1206(c) and § 63.6(e)(3), as shown in Table 1-1 

1 
Due to the similarity of the three incinerator systems, general references to an incinerator in this 

document wil imply all three incinerator systems. Irrformation that is only applicable to one or 

two of the three units will be clearly identified either parenthetically or delineated by the section 

heading. 

As required by §§ 63.6(e)(v) and 6"3.6(e)(vi), this plan and other documents containing 

procedures or information referred to in this plan will be made available for inspection when 

requested by the Adininistrator. If Onyx is requhed to submit copies of this plan or portions of 

this plan (or related documents) confidential business information entitled to protection from 

disclosure will be clearly designated. 

The remainder of this section provides an overview of regulatory requhements and a program for 

compliance with the recordkeeping and reporting requirements. Section 2.0 references an 

engineering description of the incinerator, air pollution control system, and continuous 

monitoring system. Section 3.0 addresses the startup and shutdown of the incinerator system. 

Section 4.0 addresses potential malfunctions of the incinerator system. 

1.1 Regulatory Requirements 

One of the objectives for this document is to estabhsh a program that will ensure comphance 

with relevant sections of the Interim MACT Standards. Table 1-1 includes the regulatory 

reqmrements and the location of each requirement addressed herein. 

1.2 Recordkeeping and Reporting Procedures 

This section addresses the recordkeeping and reporting requhements related to periods of SSM. 

The startup, shutdown, and malfunction reports discussed in this plan ensure that Onyx is 

satisfying the general duty to mmimize emissions and document that actions taken during those 

periods are consistent with this plan. These reports and records provide the necessary 

documentation to shield transient events from the HWC MACT emission standards imposed on 

steady-state operations. 

As long as actions taken during a transient event sufficiently maintain the incinerator system 

within limits, there is no justification in distmguishing that event from steady-state operations. 

For example, problems may arise that meet the definition of a malfunction yet do not impact the 

ability to maintain the incinerator system within limits. In these cases, mamtaimng the 

incinerator system within hmits substantiates that the actions taken sufficiently met the 

objectives of this SSMP and minimized emissions to a greater degree than required by 

regulations. 
Table 1-1 

Overview of Regulations Regarding Startup, Shutdown and Malfunction 

Regulatory Citation Description 

SSMP 

Section 

S 63.6(e)(3)(i) Purpose ofthe SSMP 1.0 

§ 63.6(e)(3Xi) • Procedures for operating and maintaining the source during startup 3.1, Table 3-1 

§ 63.6(e)(3)(i) Procedures for operating and maintaining the source during 

shutdown 

3.2, Table 3-1 

§63.6(e)(3)(i) 

Procedures for operating and maintaining the source during 

malfunction 

Attachment 4 

§ 63.6(e)(3)(i) A program of corrective action for malfunctioning process Attachment 4 

§ 63.6(e)(3)(ii) During SSM, operate and maintain source in accordance with SSMP 1.0 

§ 63.6(e)(3)(iii) Records and reports when actions conform with SSMP 1.2.1 

§63.6(e)(3)(iv) Records and reports when actions do not conform with SSMP and 

result in an exceedance 

1.2.2 

§63.6(e)(3)(v) Availability of current and superseded SSMPs ' 1.2 

§ 63.6(e)(3)(vi) Use and availability of other plans 1.0 

§ 63.6(e)(3Xviii) Revisions to .the SSMP 1.2.2 

§ 63.10(b)(1) Maintaining files 1.2 

§ 63.10(b)(2)(i) Record occurrence and duration of each startup and shutdown 1.2.1 

§63.10(b)(2)(ii) Record occurrence and duration of each malfimction 1.2.1 

§ 63.10(b)(2)(iv) Records of actions inconsistent with SSMP. 1-2.1 

§ 63.10(b)(2)(v) •Records demonstrating conformance with SSMP 1.2.1 

§63.10(b)(2)(vi) Record periods of malfunctioning CMS 1.2.1 

§ 63.10(d)(5)(i) Periodic startup, shutdown, and malfunction reports 1.2.2 

§ 63.10(d)(5)(ii) Immediate startup, shutdown, and malfunction reports 1.2.2 

§ 63.1206(c)(2)(ii)(A) Description of potential causes of malfunctions 

Table 4-1, 

Attachment 4 

§ 63.1206(c)(2)(xi)(A) Actions to minimize the frequency and severity of malfunctions 

4.1,4.2 

Table 4-2 

Attachment 4 

§ 63.1206(c)(2)(ii)(C) Changes to the plan 1.2.2 

§ 63.1206(c)(2)(iii) Projected oxygen correction factor to use during startup and 

shutdown 

3.0 

§ 63.1206(cX2)(iv) Record plan in the operating record 1.2 

§ 63.1206(c)(2)(v)(A)(l) AWFCO requirements during malfunctions 3.0 

§ 63.1206(c)(2)(v)(A)(3)(i) Investigation and evaluation of excessive exceedances during 

malfunctions .. . 

1.2.2 

§63.1206(c)(2)(v)(AX3X0 

Revisions to SSMP due to excessive exceedances during 

malfunctions 

1.2.2 

§63.1206(c)(2)(v)(A)(3)(ii) Record results from investigation and evaluation of excessive 

exceedances 

1.2.2 

§ 63.12006(c)(2)(v)A(3Xii) 

Additions to excess emissions report [§ 63.l0(eX3)] due to 

excessive exceedances during malfunctions 

1.2.2 

§63.1206(c)(2)(v)(BXD Waste feed restrictions and other OPLs during startup and shutdown 3.0 

§ 63.1206(c)(2)(v)(BX2) Interlock OPLs of (c)(2)(vXB)(l) with AWFCO system 3.0 

§63.1206(c)(2)(v)(BX3) AWFCO due to exceedance of startup/shutdown OPL 3.0 

3 

V E S 001932 
Accordingly, the recordkeeping and reporting requirements presented in this section are 

only applicable to periods of SSM in which there is a reasonable expectation that an OPL 

or emission standard can not be met. This includes all startups from cold conditions, all 

shutdowns to cold conditions, and malfunctions that result in an exceedance of an 

operating limit or emission standard. Malfunctions that prevent the ability to document 

on-going compliance are also subject to recordkeeping and reporting requhements. 

This plan, all revisions to this plan, and all records and reports described in this section 

will be retained in the operating record for at least five years. 

1.2.1 Records 

SSM records will include the following: 

• Date and time of each SSM 

• The duration of each SSM 

• Documentation to demonstrate that actions taken during periods of SSM are 

consistent with this SSMP 

• Description of any actions taken during periods of SSM that are not consistent 

with procedures in this SSMP 

• Results of investigations and evaluations of excessive exceedances occurring 

during malfunctions 

Attachments 1, 2, and 3 are blank recordkeeping forms for startups, shutdowns, and 

malfunctions, respectively. The infonnation recorded on these forms will be utilized to 

document conformance with the SSMP and to comply with the reporting requirements. 

The startup, shutdown, and nialfunction reporting requirements are described in the next 

section. 

1.2.2 Reports 

Revisions to this SSMP may be made without prior agency approval to reflect changes in 

equipment and procedures and to meet the regulatory requirements. Any such revisions 

made during a semiannual reporting period will be submitted with the periodic SSM 

report. Revisions to this plan—which alter the scope of activities during a startup, 

shutdown, or malfunction—will not take effect until a written notice, describing the 

revisions, is submitted to the penmtting authority. Changes made to this plan that may 

significantly increase emissions are subject to approval by the Administrator. A written 

request for approval of the changes and the revised SSMP will be submitted to the 
Administrator within 5 days after making such a change to this plan. Should an SSM 

event occur that is not addressed' or inadequately addressed in this SSMP, Onyx will 

make the appropriate revisions to this plan within 45 days after the event 

An investigation and evaluation will be performed on each set of 10 exceedances of a 

specific emission standard or a specific operating parameter limit that occur during 

malfunctions within a 60 day period. Within 45 days of the 10th exceedance, the 

investigation will determine plausible causes for each excessive exceedance. The 

evaluation will conclude how to minimize the frequency, duration, and severity of each 

excessive exceedance. The excessive emissions report required under § 63.10(e)(3) will 

include a summary of each investigation and evaluation requhed during the semiannual 

reporting period. In addition, the excessive emissions report will include any changes to 

this plan that may result from required investigations and evaluations of excessive 

exceedances occurring during malfunctions. 

Periodic SSM reports will be submitted to the Administrator semiannually, if a startup, 

shutdown, or malfunction occurred during that semiannual reporting period. This report 

will take the form of a letter to the Adniinistrator and include the following information: 

• A statement that actions taken during all periods of startup, shutdown, or 

malfunction were consistent with the procedures given in this SSMP 

• The number, duration, and a brief description of each malfunction 

• The name, title, and signature of the owner/operator (or other responsible official) 

certifying the accuracy of the report 

An immediate SSM report will be submitted if an action performed during a period of 

SSM is not consistent with this plan; and an OPL or emission standard is exceeded. 

Within two working days after such an action, the Administrator will be advised via 

telephone or fax. Within. 7 working days after such an action, a letter to the 

Administrator will be delivered or postmarked. The letter will explain the event, reasons 

for not following this plan, and descriptions ofthe excess emissions and/or operating 

parameter monitoring exceedances believed to have occurred. The letter will also include 

the name, title, and signature of the owner/operator (or other responsible official) 

certifying the accuracy of the report. 

5 

V E S 001934 
2.0 ENGINEERING DESCRIPTION 

Brief descriptions of the fixed hearth incinerators and the rotary kiln incinerator are 

presented in this section. A detailed engineering description of the Unit 2 and 3 

incinerators is provided by Technical Description—Fixed Hearth, Incinerators Units 

NOS. 2 & 3. A detailed engineering description of the Unit 4 incinerators is provided by 

Technical Description, Transportable Rotary Kiln Incinerator Unit No. 4. Drawing 

numbers PFD-2000, PFD-3000, PFD-4000 are the process flow diagrams for these 

incinerators. These documents and drawings are incorporated here by reference. 

2.1 Fixed Hearth Incinerators 

Each of the fixed hearth incinerators includes the following components: 

• Feed equipment 

• Primary and secondary combustion chambers 

• Lime injection system 

• Spray dryer absorber (SDA) 

• Fabric filter baghouse . 

• Solids and ash removal systems 

• Induced draft (ID) fan and stack 

• Instrumentation, controls, and data acquisition systems 

Figure 2-1 presents a block flow diagram of the Unit 2 incinerator system. The block 

flow diagram for Unit 3 is presented in Figure 2-2. 

A variety of solid, liquid, and gaseous wastes are thermally treated in the fixed hearth 

incinerators. Sohd waste is fed to the primary (lower) combustion chamber via a feed 

conveyor system and pneumatic ram. Liquid waste from tanks and tanker trucks are fed 

to the primary combustion chamber through two atomized liquid injectors. 

Both Units 2 and 3 are equipped with a specialty waste feed systems. The Unit 2 primary 

waste from liquid containers and gas cylinders are fed to the Unit 2 primary combustion 

chamber through a specialty feed port. Waste from hquid containers is fed from a 

hooded feed system to the Unit 3 primary combustion chamber through a specialty feed 

injector. Off gases from the hooded feed emission control system are fed dhectly to 
TAN K FARM ^ 

DIRECT INJECT. 

IIII I 

I I I I I 

COMBUSTION 

M R 

BLOW S 

TAN K FAR M R L OW 

B T U 

DIRECT INJECT T UOAIISS 

\ f m 

UOU O CONTAINERS ^ 

GASCYLMER S 

SPECIALTY • 

•FEEDE R 

\ PRIMARY V 

INCINERATOR 

UPPE R 

CHAMBE R 

WET AS H . 

DUMPSTE R 

U M E 

PREPARATION 

SYSTE M 

SPRA Y 

O R Y 

ABSORBE R 

STUKS K 

BAGHOUS E 1.0. FAN 

D RY SCRUBBE R D R Y SCRUBBE R 

SOUD S ( DS S ) SOUD S ( DSS ) 

E N D DUM P E N D DUM P 

FUELSAiOUO WASTE FLOW 

» - COMBUSTKJN AIR now 

» STACK OAS FLOW 

ASH FLOW 

IOOOO»> SOUO WASTE FLOW 

' >- LIME 3UHMT FLOW 

Figure 2-1 Fixed Hearth Incinerator, Unit 2, Block Flow Diagram 

< 

m 

w 

o 

o 

CO 

CO 
I I I I I 

IIII I 

TTTT T 

COMBUSTION 

Alii 

• BLOWER 

TANK FARM ( LOW 

BTU 

DIREC Liang s T INJECT , 

LOW 

BTU 

Liang s 

LOW 

BTU 

Liang s 

K I T /

SEC 

INCINERATOR 

LOWER 

CHAMBER 

SPECIALTY FEEDE R 

FUME HOOD 

EMISSION CONTROL 

SYSTEM 

\ PWMAR F \ _ 

INCINERATOR 

UPPER 

CHAMBER 

I f f 

w r ASH 

OUMPSTER 

UME 

PREPARATION 

SYSTEM 

SPRAY 

DRY 

ABSORBER 

IDRY SCRUBBER 

SOUDS ( DSS ji 

END DUMP I 

BAGHOUSE 1.0. FAN 

DRY SCRUBBER 

SOUDS ( DSS )l 

E N 0 DUMP 

GLOVE BOX 

EMISSION CONTROL) 

SYSTEM 

FUELS/UOUHJ WASrE FLOW 

— —-F - COMBUSTION AIR FLOW 

» STACK OAS FLOW 

aXCCO - ASM FLOW 

,0000» > SOUO WASTE no w 

UME SLURRY FLOW 

Figure 2-2 Fixed Hearth Incinerator, Unit 3, Block Flow Diagram 

< 

m 

co 

o 

o 

CO 

CO 
the Unit 3 secondary combustion chamber. Off gases from a waste handling glove box 

are also fed directly to the Unit 3 secondary combustion chamber. 

The primary combustion chamber main burner and the secondary combustion chamber 

main burner are used to maintain temperatures on natural gas. Combustion gases exit the 

primary combustion chamber and enter into the secondary combustion chamber, which 

serves as an afterburner. Combustion gases exit the secondary combustion chamber and 

enter the SDA. The secondary combustion chamber is equipped with an emergency 

stack. 

Lime slurry and water are fed to the SDA atomizer. The atomizer has a rapidly spiiming 

wheel that atomizes the lime slurry and water into a cloud of fine droplets. Combustion 

gases are directed upward through a disperser in the SDA and into the cloud of fine 

droplet created by the atomizer. This provides acid gas removal and cooling of the 

combustion gas. Dried spent chemicals and ash settle to the bottom of the SDA and are 

discharged to the ash removal system. 

Combustion gas exits the SDA and is distributed to the fabric filter modules. Unit 2 has 

four fabric filter modules and Unit 3 has three fabric filter modules. Combustion gas 

passes through Teflon-coated fiberglass cloth bags. Particles in the combustion gases are 

deposited on the outside of each bag in the filter module. During the bag cleaning cycle, 

a burst of ah in the dhection opposite to the gas flow dislodges particulate matter from 

the bag. 

The induced draft fan is located downstream of the fabric filter baghouse. The induced 

draft fan moves the combustion gas through the system and exhausts the gas through the 

main stack. 

Hot, wet gas is extracted downstream ofthe baghouse through a continuous emissions 

momtoring system. This system features a multi-component infrared gas analyzer that 

detects hydrogen chloride, carbon monoxide, and water vapor concentrations. An 

integrated zhconium oxide-based analyzer detects oxygeii concentrations. 

2.2 Rotary Kiln Incinerator 

The rotary kiln incinerator includes the following components: 

• Waste feed system 
• Primary and secondary combustion chambers 

• Tempering chamber 

• Lime injection system 

• Spray dryer absorber 

• Carbon injection system 

• Fabric filter baghouse 

• Solids and ash removal systems 

• Induced draft (ID) fan and stack 

• Mstrumentation, controls, and data acquisition systems 

Figure 2-3 presents a block flow diagram ofthe Unit 4 incinerator system. 

A variety of solid and liquid wastes are thermally treated in the rotary kiln incinerator. 

Solid wastes are fed to a ram feeder via a clamshell, a drum feed conveyor and an 

auxiliary feed conveyor. A hydraulic ram pushes the sohd waste into the kiln. Liquid 

waste from tanks and tanker trucks is fed to the primary and secondary combustion. 

chambers through atomized liquid injectors. 

The primary combustion chamber main burner and the secondary combustion chamber 

main burner are used to maintain temperatures pn natural gas. Combustion gases exit the 

primary combustion chamber and enter into the secondary combustion chamber, which 

serves as an afterburner. A surge vent is located at the front ofthe kiln and the secondary 

combustion chamber is equipped with a thermal relief vent. 

Combustion gases exit the secondary combustion chamber and enter the tempering 

chamber. Process water is fed to tempering chamber through ah atomized spray nozzles. 

Combustion gas is cooled as it passes through the spray of water. The water is 

completely vaporized, cooling the combustion gas. The combustion gas exits the 

tempering chamber and is distributed between two identical SDAs. 

Lime slurry is fed to each SDA through ah atomized spray nozzles. Combustion gases 

are directed downward through a duct in the SDA and then dispersed symmetrically into 

the cloud of atomized lime. This provides acid gas removal and cooling of the 

combustion gas. Dried spent chemicals and ash settle to the bottom of the SDA and are 

discharged to the ash removal system. 

10 
TANK FARM^ 

DIRECT INJECT, 

SOUOS 

MAIN ' 

AUX. 

BULK 

TANK FARM > LOW 

BTU ' 

DIRECT INJECT f LIQUIDS 

\ PRIMARY \ _ 

Figure 2-3 Rotary Kiln Incinerator, Unit 4, Block Flow Diagram 

< 

rn 

co 

o 

o 

11 

CD 

O Rr SCRUBBER 

[SOUDS ( DSS )| 

END DUMP a 

CARBON 

INJECTION 

SYSTEM 

ORr SCRUBBER 

[SCUDS { OSS )j 

END DUM P 

FUELS/LIQUID WASTE FLOW 

COMBUSTION A R FLOW 

STACK CAS FLOW 

AIH no w 

rOOOO* " SOUD WASTE FLOW 

UMC SLUflRY FLOW 
A carbon injection system is utilized for controlling dioxin/furan and mercury emissions. 

The activated carbon is air injected into the combustion gas immediately downstream of 

the convergence of combustion gases from the SDAs. 

Combustion gases exit the SDAs and are distributed to two fabric filter modules. Each 

module has three compartments, in parallel contenting multiple fabric bags. Combustion 

gas passes through the fabric bags. Particles in the combustion gases are deposited on the 

outside of each bag. During the bag cleaning cycle, a burst of air in me dhection 

opposite to the gas flow dislodges particulate matter from the bag. 

The induced draft fan is located downstream ofthe fabric filter baghouse. The induced 

draft fan moves the combustion gas through the system and exhausts the gas through the 

main stack. 

Hot, wet gas is extracted downstream of the ID fan through a continuous emissions 

monitoring system. This system features a multi-component irifrared gas analyzer that 

detects hydrogen chloride, carbon monoxide, and water vapor concentrations. An 

integrated zirconium oxide-based analyzer detects oxygen concentrations. 

12 
3.0 STARTUP AND SHUTDOWN PROCEDURES 

The purpose of this section is to prescribe procedures for the startup and shutdown ofthe 

incinerator system. This section also clarifies which actions are within the scope of the 

regulatory definition of startup and shutdown. 

To satisfy the requhements of § 63.1206(c)(2)(v)(B), waste feed restriction and operating, 

limits have been imposed to startups and shutdowns. During a startup, the feeding of 

hazardous waste to the incinerator will not be initiated until all operating parameters are 

within limits: Hazardous waste will not be fed during a shutdown event 

Consistent with the requirements of §' 63.1206(c)(2)(iii), Onyx will utilize an oxygen 

correction factor of 2 (i.e., 14% O2) during periods of startup and shutdown. This will 

eliminate wide variations in corrected CO concentration that can occur during stotup and 

shutdown due to changes in the oxygen concentration. The oxygen correction factor of 2 

is based on the highest oxygen correction factor observed during normal operations ofthe 

incinerators. This "default" oxygen correction factor can only be utilized when the waste 

residence time in the primary combustion chamber has expired. 

Onyx has developed standard division practices (SDPs) for the operation of each 

incinerator system and ancillary equipment and systems. The SDPs containing startup 

and shutdown procedures for the incinerators are: 

• SDP 2201 Startup, Operation, and Shutdown of No. 2/3 Incinerators 

• SDP 2417 Startup, Operation, and Shutdown of No. 4 Incinerator 

3.1 Startup 

A ll startups are preceded by a shutdown in which the primary combustion chamber was 

allowed to cool. Depending on the purpose of the preceding shutdown, portions ofthe ah 

pollution control system may be in service upon commencing a startup. This will be 

reflected on the startup record (see Attachments 1). During a startup, waste will not be 

introduced until all operating parameters are within limits. A startup event is concluded 

once waste is introduced and all operating parameters are within limits. 

Onyx's startup procedures are representative of safety and good ah pollution control 

practices. The procedures are designed to minimize the potential for excess emissions by 

ensuring that all equipment is fully operational (within permit limits) prior to the 

introduction of hazardous waste to the system. Adherence to these startup procedures 

13 
will employ the knowledge aad skills demonstrated through the implementation of the 

Operator Training and Certification Program. 

14 
3.2 Normal Shutdown 

A ll shutdowns will allow the primary combustion chamber to cool. Prior to every 

shutdown, the incinerator will be burning auxiliary fuel only and the hazardous waste 

residence time will have transpired. A shutdown will be initiated with the shutoff of 

auxiliary fuel to the incinerator. Portions ofthe ah pollution control system may remain 

in operating mode at the conclusion of a shutdown through the subsequent startup. 

Onyx's shutdown procedures are representative of safety and good ah pollution control 

practice. The procedures are designed to minimize the potential for excess emissions by 

ensuring that the hazardous waste residence time has transphed prior to the shutdown of 

the incinerator system. Adherence to these shutdown procedures will employ the 

knowledge and skills demonstrated through the implementation of the Operator Training 

and Certification Program. Procedures for emergency shutdown are described in the next 

section regarding malfunctions. 

15 
4.0 MALFUNCTIONS 

The purpose of this section ofthe Startup, Shutdown and Malfunction Plan is to: 

• Define potential malfunctions and their causes 

• • Describe measures to ndriimize the frequency and severity of malfunctions. 

• Prescribe procedures for operating and maintaining the incinerator during 

malfunctions 

• Prescribe actions to correct the cause of a malfunction 

A summary of potential malfunctions and theh causes is given in Table 4-1. This list of 

potential malfunctions is arranged according to unit operations. The occurrence of any 

event hsted in Table 4-1 should be responded to as a malfunction and a malfunction 

recordkeeping form, included as Attachment 3, should be initiated. During the response 

to these events, it will be detenriined if the event meets the regulatory definition of a 

malfunction. 

4.1 Measures to Minimize the Frequency of Malfunctions 

The following measures contribute to prevent malrunctions: 

• Incinerator system design consistent with safety and good engmeering practices 

• Hazards and operability studies of the incinerators 

• Appropriate frequency of preventative mamtenance and inspection 

• Good operating practices 

• Well trained and qualified personnel 

Onyx's performance history, this document, and the following regulatory documents 

serve as evidence of Onyx's proactive measures to rninLimize the frequency of 

malrunctions. . 

• Operation and Maintenance Plan 

• Operating Training and Certification Program 

• Continuous Emissions Monitoring System Quality Assurance Plan (CEMS QA 

Plan) 

• Continuous Monitoring System Quality Control Plan (CMS QC Plan) 

• Automatic Waste Feed Cutoff System Operability Test Procedures 

16 
Table 4-1 Summary of Potential Malfunctions and Causes 

Potential Malfunctions for Units 2,3, and 4 Potential Causes for a 

Malfunction 

GENERAL 

- Loss of Electrical Power Supply 

- Loss of Instrument/Plant Air Supply. 

- Loss of Plant Nitrogen Supply 

- Loss of City Water Supply 

- Loss of Process Water Pressure/Flow (Unit 4) 

- Malfunction of Safety Interlock or Automatic Waste Feed ' 

Cutofflnterlock 

PRIMARY COMBUSTION CHAMBER 

- Loss of Natural Gas Pressure/Flow to PCC Main Burner 

- Loss of Combustion Air Pressure/Flow to PCC 

- PCC Main Burner Pilot Failure 

- Loss of Waste Flow to PCC Injector 

- Loss of Waste Feedrate Control to PCC Injector 

- Loss of Atomization Air Pressure to a POC Injector 

- Loss of PCC Draft Control (Unit 4) 

- Loss of PCC Temperature Control 

- Flame Failure 

- Kiln Rotation Malfunction (Unit 4) 

- Bulk/Charge Feed Door- Malfunction 

- Physical/Mechanical Internal Equipment Failure 

- PCC Seal Visual Emissions Monitoring and Recording System 

SECONDARY COMBUSTION CHAMBER 

- Loss of Natural Gas Pressure/Flow to SCC Main Burner 

- Loss of Combustion Air Pressure/Flow to SCC 

- SCC Main Burner Ignition Failure 

- Loss of Waste Flow to SCC Injector 

- Loss of Waste Feedrate Control to SCC Injector 

- Loss of Atomization Air Pressure to a SCC Injector 

- Loss of SCC Temperature Control 

- Flame Failure 

- Emergency Safety Vent Opening 

- Physical/Mechanical Internal Equipment Failure 

- Low Water Level in Slag Collection System (Unit 4) 

TEMPERING CHAMBER (UNIT 4) 

- Loss of Tempering Chamber Exit Gas Temperature Control 

- Loss of Atomization Air Pressure to Nozzle 

LIME SLURRY SYSTEM . 

- Loss of Lime Feed to Lime Slurry Feed Tank 

- Malfunction in Lime Slurry Concentration 

UNITS 2 AND 3 SPRAY DRYER ABSORBER (SDA) 

- Loss of Lime Slurry Flow to SDA 

-. Loss of Lime Slurry Flow Control 

- Loss of City Water Flow to SDA 

- Loss of Cooling Air Flow to Atomizer 

- Loss of SDA Exit Gas Temperature Control 

- Atomizer Failure 

UNITS 4 SPRAY DRYER ABSORBER (SDA) 

- Loss of Lime Slurry Flow to SDA 

- Loss of Lime Slurry Flow Control/Exit Gas Temperature 

Control 

- Loss of Atomization Air Pressure to SDA Nozzle 

CARBON INJECTION SYSTEM (UNIT 4) 

- Loss of Carrier Gas Pressure 

- Loss/Restriction of Activated Carbon Flow 

- Loss of Plant Air Pressure/Flo w to Carbon Bulk Sack 

BAGHOUSE & INDUCED DRAFT (ID) FAN 

- . Torn/Leaking Bag 

- Bag Blinding/High-High Pressure Drop 

- Loss of Stack Gas Flowrate Control (Unit 2 and 3) 

- Baghouse Isolation Damper Malfunction (Unit 4) 

- TD Fan Failure 

CONTROL SYSTEM/CONTINUOUS MONITORING 

SYSTEM 

- Control System/Continuous Monitoring System Malfunction 

- Continuous Emissions Monitoring System Malfunction 

Mechanical/electrical 

failure of rotating 

equipment. 

Plugging/physical failure of 

lines/nozzles 

Physical/electrical failure 

of instrumentation 

Mechanical/electrical 

failure of actuated 

valves/dampers 

Physical/electrical failure 

of control system 

Mechanical/electrical 

failure of utility supplies 

Electrical/actuation failure 

of safety interlocks 

Physical/mechanical . 

internal equipment failure 

17 
Despite these efforts, equipment failures and other operating anomalies can occur. 

Within the scope of regulatory requirements, the operating record will contain the 

appropriate documentation to establish that poor maintenance or careless operations are 

not contributing factors to the cause of a malfunction. 

4.2 Measures to Minimize the Severity of Malfunctions 

The following measures contribute to mimmize me severity of malto 

• Alarms and interlocks 

• AWFCO testing 

• Failure positions for critical equipment 

• Well trained and qualified personnel 

• Design of the incinerator system 

Typically, an event that meets the definition of a malfunction will trigger an alarm. An 

alarm informs the operator of the situation and may provide an opportunity to avoid an 

exceedance. If conditions become unsafe or exceed operating hmits, interlocks are in 

place for an automated response that is specific to the triggering condition. Refer to 

Onyx's Documentation of Compliance or Notification of Compliance, whichever is 

currently applicable, for details on AWFCO conditions. Additional details on alarms and 

interlocks are mamtained on piping and iristrumentation diagrams (P&IDs) 

The most critical key to nrinimizing the severity of malfunctions is the functionality of 

AWFCO interlocks. Accordingly, Onyx performs testing of the AWFCO system, as 

described in fhe AWFCO Plan. This testing confirms a state of readiness to respond to a 

malfunction in a manner that will mimmize the release of hazardous air pollutants. 

Through training and job experience, the operator will have the process knowledge that 

qualifies him to use discretion in responding to malfunctions. Due to the unusual and 

dynamic conditions that are present during a malfunction, operator discretion is essential 

to minimizing the severity of malfunctions. An operator can evaluate process conditions 

and alarms and choose the best response to avoid an exceedance, if possible. If the 

nxalfunction adversely affects the functionality of alarms, interlocks, or fail safe positions, 

the operator must recognize the situation and respond appropriately. In the event that the 

malfunction affects the ability to automatically cutoff waste, the operator will manually 

cutoff waste feeds as quickly as possible. 

18 
The design of the each incinerator system also ensures that the severity of malrunctions 

will be minimized.. This includes alarms and interlocks, the fail safe position of actuated 

valves, and redundant instrumentation and process equipment. Also, the design of each 

incinerator's instrumentation and contrpl systems provides the operator convenient access 

to process variable indication, mcluding position indication of selected actuated valves. 

This is essential to providing the operator the information required to best evaluate 

system conditions and responses. Table 4-2 hsts potential malfunctions and associated 

redundant equipment and systems that are available to prevent these malfunctions or tp 

minimize the potential for a significant release of hazardous ah pollutants. 

4.3 Corrective Measures 

The Program of Corrective Actions for Malfunctions is Attachment 4 of this document. 

This program addresses how the incinerator will be operated and maintained during 

malfunctions. In this program, potential malfunctions are hsted for each portion of the 

incinerator system. The malfunctions are events that will be recognized by the operator, 

or indicated by an alarm, and threaten to cause an exceedance. In the response to the 

malfunction and/or alarms, the operator will apply discretion and attempt to maintain the 

incinerator system wifliin regulatory limits. In the program of corrective actions, 

potential causes of each malfunction are listed; The operator will utilize process 

knowledge, job experience, and, if needed, assistance from other personnel to identify the 

cause of the malfunction. For each potential cause, actions to correct the failure are 

listed. The corrective actions prescribed may require the collaboration of multidisciplined personnel who are quahfied to return the incinerator system to proper working 

conditions (i.e., maintenance personnel, control system technicians, engineering). 

19 
Table 4-2 

Redundant Equipment and Systems for 

Minimizing the Frequency or Severity of Malfunctions 

Redundant Equipment/Systems Potential Malfunctions Prevented/Minimized 

Emergency generator (Unit 4) Loss of Electrical Power Supply 

Universal Power Supply (UPS) system powers 

computers, monitors, and control systems 

Loss of Electrical Power Supply 

Two compressors are on hot standby (Unit 4) 

Three air compressors nmning.and one compressor 

on hot standby (Unit 2 and 3). 

Loss of Instrument/Plant Air Supply 

Dual Process Water Pumps Loss of Process Water Pressure/Flow 

Dedicated PCC combustion air fan (Unit 4) Loss of Combustion Air Pressure/Flow to PCC 

Dedicated SCC combustion air fan (Unit 4) 

Spare SCC combustion air fan (Unit 4) Loss of Combustion Air Pressure/Flow to SCC 

Multiple Tempering Chamber Nozzles 

Loss of Tempering Chamber Exit Gas Temperature 

Control 

Loss of Atomization Air Pressure to Nozzle 

Dual Slurry Feed Pumps (Unit 4) 

Shared Back-up Pump (Unit 2 and 3) Loss of Slurry Feed to SDA 

Off-line Spare Lime Slurry Atomizer (Unit 2 & 3) Atomizer Failure 

Dual SDAs (Unit 4) 

Loss .of Lime Slurry Flow to SDA 

Loss of Lime Slurry Flow Control/Exit Gas 

Temperature Control 

Loss of Atomization Air Pressure to SDA Nozzle 

Off-line Spare Baghouse Module (Unit 2) Torn/Leaking Bag 

Two baghouse modules with three compartments 

each. 5 compartments provide sufficient particulate 

removal so that one ofthe 6 compartments can be 

isolated as a spare. (Unit 4) 

TorrVLeaking Bag 

20 
ATTACHMENT 1 

STARTUP RECORDKEEPING FORM 
ONYX ENVIRONMENTAL SERVICES, INC. 

INCINERATOR STARTUP RECORD 

(Page 1 of 3) 

Tins reportpertains to a startup of Unit 2/3/ 4 (circle one). 

The startup event occurred on: __. -

(Month/Day/Year, Hours : Minutes) 

The total duration of this startup event was: 

(Hours: Minutes) 

Attached to this form is a checklist that summarizes the approved startup procedures referenced in Onyx's 

Startup, Shutdown, and Malfunction Plan (SSMP). The operational steps that have been checked document that 

the detailed startup procedures were followed. 

Were all actions associated with this startup event in conformance with the SSMP? Yes / No (circle.one). If 

no, describe the inconsistent actions below. 

WeretiereanyexceeclmcesofanoperaJiigpararneter .hmt? Yes / No (circle one). If yes, please list/describe. 

If any actions were not consistent with the SSMP and an operating parameter limit was exceeded, an immediate 

SSM report is required. 

Notes/Recommendations: 

The following signature certifies the accuracy of this record: 

(Name) [ ~ ' (Title) 

(Signature) (Date) 
ONYX ENVIRONMENTAL SERVICES, INC. 

INCINERATOR STARTUP RECORD 

(Page 2 of 3) 

Unit 2 and 3 Incinerator Startup Checklist Initials 

Verify that pre-startup has been completed 

Check thermal relief vent (TRV) 

Start combustion air fan 

Start PCC main burner and temperature ramp-up 

Start SCC main burner and temperature ramp-up 

Check stack gas flow and SDA temperatures control settings 

Start ID fan. Monitor SDA temperature while ramping up stack gas flowrate 

Close TRV 

Start lime slurry 

Establish all operating parameters within limits 

Operator's Notes: 

• •• ' -

Note: Certain air pollution control and ancillary equipment may be operational prior to startup 

(Signature of Shift Leader or Designee) (Date) 
ONYX ENVIRONMENTAL SERVICES, INC. 

INCINERATOR STARTUP RECORD 

(Page 3 of3) 

Unit 4 Incinerator Startup Checklist Initials 

Verify that pre-startup has been completed 

Check thermal relief vent (TRV) 

Start ID fan and set kiln draft (start of purge cycle) 

Start SCC combustion air fan 

Start the kiln combustion air fan (purge cycle complete) 

Start SCC main burner and temperature ramp-up . . 

Start PCC main burner and temperature ramp-up 

Start kiln rotation before. 500. °F 

Start the kiln seal air 

Start the SCC conveyor 

Set up the tempering chamber for operation 

Set up lime slurry injection system 

Set up the SDAs for operation 

Set up the ash collection system 

Set up the baghouses for operation 

Slowly ramp-up the tempering chamber exit temperature 

Continue PCC and SCC ternperature ramp-up 

Set up the air cannon 

Start the kiln seal conveyor 

Establish all operating parameters within limits 

Operator's Notes: 

Note: Certain air pollution control and ancillary equipment may be operational prior to startup. 

(Signature of Shift Leader or Designee) (Date) 
ATTACHMENT 2 

SHUTDOWN RECORDKEEPING FORM 
ONYX ENVIRONMENTAL SERVICES, INC. 

INCINERATOR SHUTDOWN RECORD 

(Page 1 of 3) 

This report pertams to a sbuMown of Unit 2 7 3 / 4 (circle one). 

The shutdown event that occurred on: 

(Month/Day/Year, Hours : Minutes) 

The total duration of this shutdown event was: 

(Hours: Minutes) 

Attached to this form is a checklist that summarizes the approved shutdown procedures referenced in the Onyx 

Startup, Shutdown, and Malfunction Plan (SSMP). The operational steps that have been checked , document that 

the detailed shutdown procedures were followed. 

Were all actions associated with this shutdown event in conformance with the SSMP? Yes / No (circle one). If 

no, describe the inconsistent actions below. 

Were there any exceedances of an operating parameter limit? Yes / No (circle one). If yes, please list/describe. 

If any actions were not consistent with the SSMP and an operating parameter limit was exceeded,' an immediate 

' SSM report is required. 

Notes/Recommendations: 

The following signature certifies the accuracy of this record: 

(Name) (Title) 

(Signature) (Date) 

V E S 001955 
ONYX ENVIRONMENTAL SERVICES, INC. 

INCINERATOR SHUTDOWN RECORD 

(Page 2 of3) 

Unit 2 and 3 Incinerator Shutdown Checklist Initials 

Verify that the hazardous waste residence time has transpired 

Monitor CEMS output to verify stable conditions 

Open the stack cap 

Stop the ID fan 

Shut off water and lime slurry flow to the atomizer 

Remove atomizer and position lid 

Operator's Notes: 

Note: Certain air pollution control and ancillary equipment may remain operational throughout 

shutdown. Once the hazardous waste residence time has transpired, operator's discretion can be 

applied. 

(Signature of Shift Leader or Designee) (Date) 
ONYX ENVIRONMENTAL SERVICES, INC. 

INCINERATOR SHUTDOWN RECORD 

(Page 3 of 3) 

Unit 4 Incinerator Shutdown Checklist Initials 

Verify that the hazardous waste residence time has transpired 

Vent the air cannons 

Shut off the kiln burner and SCG burner 

Shut off the kiln and SCC combustion air fans 

Reduce the tempering chamber outlet temperature to 500 °F 

Shutdown SDA (at appropriate temperatures) 

Shutdown tempering chamber (at appropriate temperatures) 

After PCC and SCC reach the. appropriate temperature, shut off the ID fan 

Operator's Notes: 

Note: Certain air pollution control and ancillary equipment may remain operational throughout 

shutdown. Once the hazardous waste residence time has transpired, operator's discretion can be 

applied. 

(Signature of Shift Leader or Designee) (Date) 
ATTACHMENT 3 

MALFUNCTION RECORDKEEPING FORM 

V E S 001958 
ONYX ENVIRONMENTAL SERVICES, INC. 

MALFUNCTION RECORD 

(Page 1 of 1) 

Tms report pertains to a malfunction of Unit 2/3/4 . (circle one). 

The malfunction event that occurred on: -

(Month/Day/Year, Hours: Minutes) 

The total duration of this malfunction event was: 

(Hours: Minutes) 

The Onyx Program of Corrective Actions for Malfunctions must be adhered to for the operating and mamtaining 

of the incinerator system and for correcting the cause of tlie malfunction Describe the malfunction, the 

automated and/or operator response, the potential cause of the malfunction, and the corrective actions taken: 

Were all actions associated with this malfunction event in conformance with the SSMP? Yes / No (circle one). 

If no, initiate an immediate startup, shutdown, and malfunction report 

List/describe the exceedances that occurred (or believed to have occurred) due to this malfunction: 

Notes/Recommendations: 

The following signature certifies the accuracy, of this record: 

(Name) (Title) 

(Signature) (Date) 
ATTACHMENT 4 

PROGRAM OF CORRECTIVE 

ACTIONS FOR MALFUNCTIONS 
PROGRAM OF CORRECTIVE 

ACTIONS FOR MALFUNCTIONS 

TABLE OF CONTENTS 

1.0 GENERAL 

1.1 Operating and Maintaining the System durmg Malfunctions 

1.2 Loss of Electrical Power Supply 

1.3 Loss of Instrument/Plant Air Supply 

1.4 Loss of Plant Nitrogen Supply 

1.5 Loss of City Water Supply 

1.6 Loss of Process Water Pressure/Flow (Unit 4) 

1.7 Malfunction of Safety Interlock or Automatic Waste Feed Cutoff Interlock 

2.0 PRIMARY COMBUSTION CHAMBER 

2.1 Loss of Natural Gas Pressure/Flow to PCC Main Burner 

2.2 Loss of Combustion Air Pressure/Flow to PCC 

2.3 PCC Main Burner Pilot Failure 

2.4 Loss of Waste Flow to PCC Injector 

2.5 Loss of Waste Feedrate Control to PCC Injector 

2.6 Loss of Atomization Air Pressure to a PCC Injector 

2.7 Loss ofPCC Draft Controi (Unit 4) 

2.8 Loss of PCC Temperature Control 

2.9 Flame Failure 

2.10 Kim Rotation Malfunction (Unit 4) 

2.11 Bulk/Charge Feed Door Malfunction 

2.12 Physical/Mechanical Internal Equipment Failure 

2.13 PCC Seal Visual Emissions Monitoring and Recording System 

3.0 SECONDARY COMBUSTION CHAMBER 

3.1 Loss of Natural Gas Pressure/Flow to SCC Main Burner 

3.2 Loss of Combustion Air Pressure/Flow to SCC 

3.3 SCC Mam Burner Ignition Failure 

3.4 Loss of Waste Flow to SCC Injector (Unit 4) 

3.5 Loss ofWaste Feedrate Control to SCC Injector (Unit 4) 

3.6 Loss of Atomization Air Pressure to a SCC Injector 

3.7 Loss of SCC Temperature Control 

3.8 Flame Failure 

3.9 Physical/Mechanical Internal Equipment Failure 

3.10 Low Water Level in Slag Collection System (Unit 4) 

3.11 Emergency Safety Vent Opening 

4.0 TEMPERING CHAMBER (UNIT 4) 

4.1 Loss of Tempering Chamber Exit Gas Temperature Control 

4.2 Loss of Atomization Air Pressure to Nozzle 

5.0 LIME SLURRY SYSTEM 

5.1. Loss of Lime Feed to Lime Slurry Feed Tank 

5.2. Malfunction in Lime Slurry Concentration 

6.0 UNITS 2 AND 3 SPRAY DRYER ABSORBER (SDA) 

6.1. Loss of Lime Slurry Flow to SDA 

6.2. Loss of Lime Slurry Flow Control 

6.3. Loss of City Water Flow to SDA (Unit 2 and 3) 

6.4. Loss of Cooling Air Flow to Atomizer 

V E S 001 
6.5. Loss of SDA Exit Gas Temperature Control 

. 6.6. Atomizer Failure 

7.0 UNIT 4 SPRAY DRYER ABSORBER (SDA) 

7.1. Loss of Lime Slurry Flow to SDA 

7.2. Loss of Lime Slurry Flow Control/Exit Gas Temperature Control 

7.3. Loss of Atomization Air Pressure to SDA Nozzle 

8.0 CARBON INJECTION SYSTEM (UNIT 4) 

8.1. Loss of Carrier Gas Pressure 

8.2. Loss/Restriction of Activated Carbon Flow 

8.3. Loss of Plant Air Pressure/Flow to Carbon Bulk Sack 

9.0 BAGHOUSE & INDUCED DRAFT (ID) FAN 

9.1. Tom/Leaking Bag . 

9.2. Bag Blmding/High-High Pressure Drop 

9.3. Loss of Stack Gas Flowrate Control (Unit 2 and 3) 

9.4. Baghouse Isolation Damper Malfunction (Unit 4) 

9.5. ID Fan Failure 

10.0 CONTROL SYSTEM/CONTINUOUS MONITORING SYSTEM 

10.1. Control System/Continuous Monitoring System Malfunction 

10.2. Continuous Emissions Monitoring System Malfunction 

V E S 00196 
ONY X ENVIRONMENTAL SERVICES, INC. 

PROGRAM OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

GENERAL 

1.1. Operating and Maintaining the System during Malfunctions 

1.1.1. Due to the sudden, infrequent, and unusual conditions associated 

with malfunctions, continually evaluate the situation. Using 

discretion, respond in a manner consistent with safety and good ah 

pollution control practices. 

1.1.2. Take fhe following actions to minimize fhe release of hazardous ah 

pollutants 

1.1.2.1. Cutoff all waste feeds and/or confirm that the automatic 

waste feed cutoff system functioned properly. 

1.1.2.2. Maintain operating parameters withinlimits, if possible. 

1.1.2.3. If apphcable, follow the procedures provided by the 

Emergency Safety Vent Plan. 

1.1.3. Keep supervisor and/or maintenance supervisor informed, as 

appropriate. 

1.1.4. Identify the malfunction and potential cause. 

1.1.5. Implement corrective actions involving the troubleshooting of 

failures and the servicing and/or replacing of components, as 

needed. Refer to manufacture's troubleshooting and service 

recommendations, as needed. 

1.1.6. Record the appropriate information using a malfunction record 

form. 

1.2. Loss of Electrical Power Supply 

1.2.1. Verify proper failure position of actuated valves. 

1.2.2. Identify link in power supply path that is not operational. 

1.2.3. Take the necessary" actions to restore the supply of electrical 

power.-

1.3. Loss of Instrument/Plant Air Supply 

1.3.1. Verify proper failure position of actuated valves. 

. 1.3.2. Ih case of plugging/physical failure of line or line components: 

1.3.2.1. Identify the location/cause of the restriction of 

instrument ah flow. 

1.3.2.2. . Clear line plugging and/or service/replace faulty line 

components, as needed. 

Page 1 of26 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRAM OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

; 1.3.3. In case of mechanical/electrical failure of actuated valve: 

1.3.3.1. Identify cause of actuation failure. 

1.3.3.2. Service/replace electrical and/or pneumatic 

components, as needed. 

1.3.3.3. Service/replace actuator and/or valve components, as 

needed. 

1.3.4. In case of mechanical/electrical failure at air supply source: 

1.3.4.1. Identify the cause ofthe failure. 

1.3.4.2. Take the necessary actions to restore the supply of 

instrument/plant air. 

1.4. Loss of Plant Nitrogen Supply 

1.4.1. In case of plugging/physical failure of line or line components: 

1.4.1.1. Identify the location/cause of the restriction of nitrogen 

flow. 

1.4.1.2. Clear line plugging and/or service/replace faulty line 

components, as needed. 

1.4.2. In case of mechanical/electrical failure of actuated valve: 

1.4.2.1. Identify cause of actuation failure. 

1.4.2.2. Service/replace electrical and/or pneumatic 

components, as needed. 

1.4.2.3. Service/replace actuator and/or valve components, as 

needed. 

1.4.3. In case of mechanical/electrical failure at nitrogen supply source: 

1.4.3.1. Identify tlie cause of the failure. 

1.4.3.2. Take the necessary actions to restore fhe supply of 

nitrogen. 

1.5. Loss of City Water Supply' 

1.5.1. In case of plugging/physical failure of line or line components: 

1.5.1.1. Identify the location of plugging or line failure. 

1.5.1.2. Clear line plugging and/or service/replace, faulty line 

components, as needed. 

1.5.2. In case of mechanical/electrical failure of actuated valve: 

1.5.2.1. Identify cause of actuation failure. 

. 1.5.2.2. Service/replace electrical and/or pneumatic 

components, as needed. 

Page 2 of 26 

V E S 001964 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRAM OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

1.5.2.3. Service/replace actuator and/or valve components, as 

needed. 

1.5.3. In case of mechanical/electrical failure at city water supply source: 

1.5.3.1. Identify the cause of the failure. 

1.5.3.2. Take the necessary actions to restore the supply of city 

water. 

1.6. Loss of Process Water Pressure/Flow (Unit 4) 

1.6.1. For loss of city water supply to process water tank, see 1.5. 

1.6.2. In case of mechanical/electrical failure of process water pump: 

1.6.2.1. Diagnose pump/drive failure. 

1.6.2.2. Service/replace the pump/drive, as needed. 

1.6.2.3. Restore electrical power supply to the pump. 

1.6.3. In case of plugging/physical failure of line or line components: 

1.6.3.1. Identify the location of plugging or line failure. 

1.6.3.2. Clear line plugging and/or service/replace faulty line 

components, as needed. 

1.6.4. Incase of mechanical/electricalfailure of actuated valve: 

1.6.4.1. Identify cause of actuation failure. 

1.6.4.2. Service/replace electrical and/or pneumatic 

components, as needed. 

1.6.4.3. Service/replace actuator and/or valve components, as 

needed. 

1.6.5. In case of physical/electrical failure of control system component: 

1.6.5.1. Identify faulty control system component 

1.6.5.2. Service/replace control system components, as needed. 

1.7. Malfunction of Safety Interlock or Automatic Waste Feed Cutoff 

Interlock 

1.7.1. If safety interlock or AWFCO interlock was erroneously triggered, 

proceed with corrective actions. 

1.7.2. If safety or AWFCO condition exists but automated response 

failed, cutoff waste feed as quickly as possible, then proceed with 

corrective actions. 

1.7.3. In case of physical/electrical failure of instrumentation: 

1.7.3.1. Identify faulty instrumentation component. 

1.7.3.2. Service/replace faulty instrumentation components, as 

needed. 

Page 3 of 26 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRAM OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

1.7.4. In case of mecharucal/electrical failure of actuated valve/damper: 

1.7.4.1. Identify cause of actuation failure. 

1.7.4.2. Service/replace electrical and/or pneumatic 

components, as needed. 

1.7.4.3. Service/replace actuator and/or valve components, as 

needed. 

1.7.5. In case of physical/electrical failure of control system component: 

1.7.5.1. Identify faulty control system component 

1.7.5.2. Service/replace control system components, as needed. 

Page 4 of 26 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRAM OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

2.0 PRIMARY COMBUSTION CHAMBER 

2.1. Loss of Natural Gas Pressure/Flow to PCC Main Burner 

2.1.3. In case of physical/electrical failure of control system component: 

2.1.3.1. Identify faulty control system component. 

2.1.3.2. Service/replace control system components, as needed. 

2.1.4. In case of mechanical/electrical failure at natural gas supply 

source: 

2.1.4.1. Identify the cause of the failure. 

2.1.4.2. Take the necessary actions to restore the supply of 

natural gas. 

2.2. Loss of Combustion Air Pressure/Flow to PCC 

2.2.1. In case of mechamcal/electrical failure of combustion air-blower. 

2.2.1.1. Diagnose blower/drive failure. 

2.2.1.2. Service/replace the blower/drive, as needed. 

2:2.1.3. Restore electrical power supply to the blower. 

2.2.2. In case of physical failure of combustion air duct: 

2.2.2.1. Identify fhe location of duct failure. 

2.2.2.2. Service/replace faulty duct, as needed. 

2.2.3. In case of mechanical/electrical failure of actuated valve: 

2.2.3.1. Identify cause of actuation failure. 

2.2.3.2. Service/replace electrical and/or pneumatic 

2.1.2. 

2.1.1. In case of plugging/physical failure of line or line component: 

2.1.1.1. Identify the location of plugging or line failure. 

2.1.1.2. Clear line plugging and/or service/replace faulty line 

components, as needed. 

In case of mechanical/electrical failure of actuated valve: 

2.1.2.1. Identify cause of actuation failure. 

2.1.2.2. Service/replace electrical and/or pneumatic 

components, as needed. 

2.1.2.3. Service/replace actuator and/or valve components, as 

needed. 

2.2.3.3. 

components, as needed. 

Service/replace actuator and/or valve components, as 

needed. 

Page 5 of 26 

V E S 001967 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRAM OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

2.2.4. In case of physical/electrical failure of control system component: 

2.2.4.1. Identify faulty control system component. 

2.2.4.2. Service/replace control system components, as needed." 

2.3. PCC Main Burner Pilot Failure 

2.3.1. For loss pf natural gas pressure/flow, see 2.1. 

2.3.2. For loss of combustion air pressure/flow, see 2.2. 

2.3.3. In case of physical/electrical failure of igniter: 

2.3.3.1. Identify cause of igniter failure. 

2.3.3.2. Service/replace igniter and/or associated components, 

as needed. 

2.3.4. In case of physical/electrical failure of control system component: 

2.3.4.1. Identify faulty control system component 

2.3.4.2. Service/replace control system components, as needed. 

2.4. Loss of Waste Flow to PCC Injector 

2.4.1. In case of mechanical/electrical failure of waste feed pump: 

2.4.1.1. Diagnose pump/drive failure. 

2.4.1.2. Service/replace the pump/drive, as needed. 

2.4.1.3. Restore electrical power supply to the pump. 

2.4.2. In case of low nitrogen pressure, see 1.4. 

2.4.3. In case of plugging/physical failure of line or line component: 

2.4.3.1. Identify the location of plugging or line failure. 

2.4.3.2. Clear line plugging and/or service/replace faulty line 

components, as needed. . 

2.4.3.3. Restore/confirm functional heat tracing, if apphcable. 

2A4. In case of mechanical/electrical failure of actuated valve: 

2.4.4.1. Identify cause of actuatioh failure. 

2.4.4.2. Service/replace electrical and/or pneumatic 

components, as needed. 

2.4.4.3. Service/replace actuator and/or valve components, as 

needed. 

2.4.5. In case of physical/electrical failure of conhol system component: 

2.4.5.1. Identify faulty control system component. 

2.4.5.2. Service/replace control system components, as needed. 

2.5. Loss pf Waste Feedrate Control to PCC Injector 

2.5.1. In case of loss of waste pressure/flow to PCC injector, see 2.4. 

Page 6 of 26 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRAM OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

2.5.2. In case of physical/electrical failure of flow transmitter: 

Service/replace flow tr^smitter and/or associated msmrmentation, 

as needed. 

2.5.3. In case of actuated valve failure: 

2.5.3.1. Identify cause of actuation failure. 

2.5.3.2. Service/replace electrical and/or pneumatic 

components, as needed. 

2.5.3.3. Service/replace actuator and/or valve components, as 

needed. 

2.5.4. In case of physical/electrical failure of control system component: 

2.5.4.1. Identify faulty control system component. 

2.5.4.2. Service/replace control system.components, as needed. 

2.6. Loss of Atomization Air Pressure to a PCC Injector 

2.6.1. For a total loss of plant/instrument air supply, see 1.3. 

2.6^2. In case of plugging/physical failure of line or line component: 

2.6.2.1. Identify the location of plugging or line failure. 

2.6.2.2. Clear line plugging and/or service/replace faulty line 

components, as needed. 

2.6.3. In case of mechanical/physical failure of pressure control valve: 

Service/replace pressure control valve, as needed. 

2.7. Loss of PCC Draft Control (Unit 4) 

2.7.1. In case of ID fan failure, see 9.5 

2.7.2. In case of physical/electrical failure of kiln pressure transmitter: 

Service/replace pressure transmitter and/or associated 

instrumentation, as needed. 

2.7.3. In case of actuated damper failure: 

2.7.3.1. Identify cause of actuation failure. 

2.7.3.2. Service/replace electrical and/or pneumatic 

components, as needed. 

2.7.3.3. Service/replace actuator and/or damper components, as 

needed. 

2.7.4. In case of physical/electrical failure of control system component: 

2.7.4.1. Identify faulty control system component 

2.7.4.2. Service/replace control system components, as needed. 

Page 7 of 26 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRAM OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

2.8. Loss of PCC Temperature Control 

2.8.1. In case of loss of natural gas pressure/flow to main burner, see 2.1. 

2.8.2. In case of loss of waste pressure/flow to PCC injector, see 2.4. 

2.8.3. In case of physical/electrical failureof temperature element: 

2.8.3.1. Service/replace faulty temperature element and/or 

associated mstrumentation, as needed. 

2.8.4. In case of pbysical/electrical failure of control system component: 

2.8.4.1. Identify faulty control system component. 

2.8.4.2. Service/replace control system components, as needed. 

2.9. Flame Failure 

2.9.1. In case of physical/electrical failure of flame detector: 

2.9.1.1. Identify faulty flame detector component. 

2.9.1.2. Service/replace flame detector components, as needed. 

2.9.2. In case of physical/electrical failure of control system component: 

2.9.2.1. Identify faulty control system component. 

2.9.2.2. Service/replace control system components, as needed. 

2.10. Kiln Rotation Malfunction (Unit 4) 

2.10.1. In case of mechanical/electrical kiln drive system: 

2.10.1.1. Diagnose drive failure. 

2.10.1.2. Service/replace the drive, as needed. 

2.10.1.3. Restore electrical power supply to motor. 

2.10.2. In case of physical/electrical failure of kiln rotational speed 

transmitter: Service/replace transmitter and/or associated 

mstrumentation, as needed. 

2.10.3. In case of physical/electrical failure of control system component: 

2.10.3.1. Identify faulty control system component 

2.10.3.2. Service/replace control system components, as needed. 

2.11. Bulk/Charge Feed Door Malfunction 

2.11.1. In case of mechanical/electrical failure of actuated door: 

2.11.1.1. Identify cause of actuation failure. 

2.11.1.2. Service/replace electrical, hydraulic, and/or pneumatic 

components, as needed. 

2.11.1.3. Service/replace actuator and/or valve components, as 

needed. 

2.11.2. In case of physical/electrical failure of control system componentPage 8 of 26 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRAM OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

2.11.2.1. Identify faulty control system component. 

2.11.2.2. Service/replace control.system components, as needed. 

2.12. Physical/Mechanical Internal Equipment Failure 

2.12.1. In case of refractory failure, rep air/replace refractory . 

2.12.2. In case of ash collection failure 

2.12.2.1. Diagnose ash collection system failure 

2.12.2.2. Service/replace ash collection system components, as 

needed. 

2.13. PCC Seal Visual Emissions Monitoring and Recording System 

2.13.1. In case of physical/electrical failure of camera, service/replace 

camera. 

2.13.2. In case of physical/electrical failure of monitor, service/replace 

monitor. 

2.13.3. In case of physical/electrical failure of recording system, 

service/replace recording system. 

Page 9 of 26 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRAM OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

SECONDARY COMBUSTION CHAMBER 

3.1. Loss of Natural Gas Pressure/Flow to SCC Main Burner 

3.1.1. In case of plugging/physical failure of line or line component: 

3.1.1.1. Identify the location of plugging or line failure; 

3.1.1.2. Clear line plugging arxL/pr service/replace faulty line 

components, as needed. 

3.1.2. In case of mechanical/electrical failure of actuated valve: 

. 3.1.2.1. Identify cause of actuatbn failure. 

3.1.2.2. Service/replace electaical and/pr pneumatic 

components, as needed. 

3.1.2.3. Service/replace actuator and/or valve components, as 

needed. 

3.1.3. In case of physical/electrical failure of control system component: 

3.1.3.1. Identify faulty control system component. 

3.1.3.2. Service/replace control system components, as needed. 

3.1.4. In case of mechanical/electrical failure.at natural gas supply 

source: 

3.1.4.1. Identify the cause of the rfailure. 

3.1.4.2. Take the necessary actions to restore the supply of 

natural gas. 

3.2. Loss of Combustion Air Pressure/Flow to SCC 

3.2.1. In case of mechanical/electrical failure of combustion air blower 

3.2.1.1. Diagnose blower/drive Mure. 

3.2.1.2. Service/replace the bibvrer/drive, as needed. 

3.2.1.3. Restore electrical power supply toithe blower. 

3.2.2. In case of physical failure combustion ah duct: 

3.2.2.1. Identify the location of duct failure. 

3.2.2.2. Service/replace faulty dart, as needed. 

3.2.3. In case of mechanical/electrical failure of actuated valve: 

3.2.3.1. Identify cause of actuation failure. 

3.2.3.2. Service/replace electrical and/or pneumatic 

components, as needed. 

3.2.3.3. Service/replace actuator and/or valve components, as 

needed. 

Page 10 of 26 
ONY X ENVIRONMENTAL SERVICES, INC. 

PROGRAM OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

3.2.4. Incase of physical/electrical failure of control system component: 

3.2.4.1. Identify faulty control system component. 

3.2.4.2. Service/replace control system components, as needed. 

3.3. SCC Main Burner Ignition Failure 

3.3.1. For loss of natural gas pressure/flow, see 3.1. 

3.3.2. For loss of combustion air pressure/flow, see 3.2. 

3.3.3. In case of pbysical/electrical failure of igniter: 

3.3.3.1. Identify cause of igniter failure. 

3.3.3.2. Service/replace igniter and/or associated components, 

as needed. 

3.3.4. In case of physical/electrical failure of control system component: 

3.3.4.1. Identify faulty control system component. 

3.3.4.2. Service/replace control system components, as needed. 

3.4. Loss of Waste Flow to SCC Injector (Unit 4) 

3.4.1. In case of mechanical/electrical failure of waste feed pump: 

3.4.1.1. Diagnose pump/drive failure. 

3.4.1.2. Service/replace tbe pump/drive, as needed. 

3.4.1.3. Restore electrical power supply to the pump. 

3.4.2. In case.of low nitrogen pressure, see 1.4. 

3.4.3. In case of plugging/physical failure of line or line component: 

3.4.3.1. ' Identify me location of plugging or line failure. 

3.4.3.2. Clear line plugging and/or service/replace faulty line 

components, as needed. 

3.4.3.3. Restore/confirm functional heat tracing, if applicable. 

3 .4.4. In case of mechanical/electrical failure of actuated valve: 

3.4.4.1. Identify cause of actuation failure. 

3.4.4.2. Service/replace electrical and/or pneumatic 

components, as needed. 

3.4.4.3. Service/replace actuator and/or valve components, as 

needed. 

3.4.5. In case of physical/electrical failure of control system component: 

3.4.5.1. Identify faulty control system component 

3.4.5.2. Service/replace control system components, as needed. 

3.5. Loss of Waste Feedrate Control to SCC Injector (Unit 4) 

3.5.1. In case of loss of waste pressure/flow to SCC injector, see 3.4. 

Page 11 of 26 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRA M OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

3.5.2. In case of physical/electrical failure of flow transmitter: 

Service/replace flow transmitter and/or associated instrumentation, 

as needed. 

3.5.3. In case of actuated valve failure: 

3.5.3.1. Identify cause of actuation failure. 

3.5.3.2. Service/replace electrical and/or pneumatic 

components, as needed. 

3.5.3.3. Service/replace actuator and/or valve components, as 

needed. 

3.5.4. In case of physical/electrical failure of control system component: 

3.5.4.1. Identify faulty control system component. 

3.5.4.2. Service/replace control system components, as needed. 

3;6. Loss of Atomization Air Pressure to a SCC Injector 

3.6.1. For atotal loss of plant/instrument air supply, see 1.3. 

3.6.2. In case of plugging/physical failure of line or line component: 

3.6.2.1. Identifythe location of plugging or line failure. 

3.6.2.2. Clear line plugging and/or service/replace faulty line 

components, as needed. 

3.6.3. In case of mechanical/physical failure of pressure control valve: 

Service/replace pressure control valve, as needed. 

3.7. Loss of SCC Temperature Control 

3.7.1. In case of loss of natural gas pressure/flow to main burner, see 3.1. 

3.7.2. Incase of loss of waste pressure/flow to SCC injector, see 3.4. 

3.7.3. In case of physical/electrical failure of temperature element: 

3.7.3.1. Service/replace faulty temperature element and/or 

associated instrumentation, as needed. 

3.7.4. In case of physical/electrical failure of control system component: 

3.7.4.1. Identify faulty control system component. 

3.7.4.2. Service/replace control system components, as needed. 

3.8. Flame Failure 

3.8.1. In case of physical/electrical failure of flame detector: 

3.8.1.1. Identify faulty flame detector component 

3.8.1.2; Service/replace flame detector components, as needed. 

3.8.2. In case of physical/electrical failure of control system component: 

3.8.2.1. Identify faulty control system componentPage 12 of 26 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRA M OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

3.8.2.2. Service/replace control system components, as needed. 

Physical/Mechanical Internal Equipment Failure 

3.9.1. In case of refractory failure, repair/replace refractory. 

Low Water Level in Slag CoUection System (Unit 4) 

3.10.1. For a loss of process water pressure/flow, see 1.6. 

3.10.2. In case of physical/mechanical failure of level controller: 

Service/replace faulty level controller and/or associated 

components, as needed. . 

3.10.3. In case of physical/mechanical failure of actuated valve: 

3.10.3.1. Identify cause of actuation failure. 

3.10.3.2. Service/replace pneumatic components, as needed. 

3.10.3.3. Service/replace actuator and/or valye components, as 

needed, 

3.11. Emergency Safety Vent Opening 

3.11.1. Respond to an emergency safety vent opening in a manner 

consistent with the Emergency Safety Vent Plan. 

3.11.2. In case of mechanical failure of the actuator: 

3.11.2.1. Identify cause of actuation failure. 

3.11.2.2. Service/replace emergency safety vent components, as 

needed. 

3.9. 

3.10. 

Page 13 of 26 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRA M OF CORRECTIVE ACTIONS FO R MALFUNCTIONS 

TEMPERING CHAMBER (UNIT 4) 

4.1. Loss of Tempering Chamber Exit Gas Temperature Control 

4.1.1. For a loss ofprocess water pressure/flow, see 1.6. 

4.1.2. In case pf physical/electrical failure of flow transmitter: 

Service/replace flow transmitter and/or associated mstrumentation, 

as needed. 

4.1.3. In case of actuated valve failure: 

4.1.3.1. Identify cause of actuation failure. 

4.1.3.2. Service/replace electrical and/or pneumatic 

components, as needed. 

4.1.3.3. Service/replace actuator and/or valve components, as 

needed. 

4.1.4. In case of physical/electrical failure of control system component: 

4.1.4.1. Identify faulty control system component. 

4.1.4.2. Service/replace control system components, as needed. 

4.1.5. In case of nozzle failure, service/replace nozzle, as needed. 

4.2. Loss of Atomization Air Pressure to Nozzle 

4.2.1. For a total loss of plant/mstnnnent air supply, see 1.3. 

4.2.2. In case of plugging/physical failure of line or line component:. 

4.2.2.1. Identify the location of plugging or line failure. 

4.2.2.2. Clear line plugging and/or service/replace faulty line 

components, as needed. 

Page 14 of 26 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRAM OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

LIME SLURRY SYSTEM 

5.1. Loss of Lime Feed to Lime Slurry Feed Tank 

5.1.1. In case of mechanical/electrical failure of iime slurry screw feeder: 

5.1.1.1. Diagnose feeder/drive failure. 

5.1.1.2. Service/replace th.e feeder/drive, as needed. 

5.1.1.3. Restore electrical power supply to the lime slurry screw 

feeder. 

5.1.2. In case of mechanical/electrical failure of lime bin 

activator/vibrator: 

5.1.2-1. Diagnose lime bin activator/vibrator failure. 

5.1.2.2. Service/replace the lime bin activator/vibrator, as 

needed. 

5.1.2.3. Restore electrical power supply to me lime slurry screw 

feeder. 

5.1.3. In case of plugging/physical failure pf line or line component: 

5.1.3.1. Identify the location of plugging or line failure. 

5.1.3.2. Clear line plugging and/or service/replace faulty line 

components, as needed. 

5.1.4. In case of physical/electrical failure of lime feed controls: 

Service/replace faulty mstrumentation and/or control system 

components, as needed. 

5.2. Malfunction in Lime Slurry Concentration 

5.2.1. In case of loss of lime feed to lime slurry feed tank, see 5.1 

5.2.2. In case of loss of water flow to lime slurry feed tank, see 1.5 

5.2.3. hi case of mechanical/electrical failure of lime slurry agitator: 

5.2.3.1. Diagnose agitator/drive failure. 

5.2.3.2. Service/replace the agitator/drive, as needed. 

5.2.3.3. Restore electrical power supply to the lime slurry 

agitator. 

5.2.4. In case of physical/electrical failure of mstrumentation: 

Service/replace faulty instrumentation, as needed. 

5.2.5. In case of physical/electrical failure of control system component: 

5.2.5.1. Identify faulty control system component. 

5.2.5.2. Service/replace control system components, as needed. 

Page 15 of 26 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRAM OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

UNITS 2 AND 3 SPRAY DRYER ABSORBER (SDA) 

6.1. Loss of Lime Slurry Flow to SDA 

6.1.1. In case of mechamcal/electrical failure of lime slurry feed pump: 

6.1.1.1. Diagnose pump/drive failure. 

6.1.1.2. Service/replace the pump/drive, as needed. 

6.1.1.3. Restore electrical power supply to the pump. 

6.1.2. In case of plugging/physical failure of line or line component:. 

6.1.2.1. Identify the location of plugging or line failure. 

6.1.2.2. Clear line plugging and/or service/replace faulty line 

components, as needed. 

6.1.2.3. Restore/confirm functional heat tracing, if applicable. ' 

6.1.3. In case of mechanical/electrical failure of actuated valve: 

6.1.3.1. Identify cause of actuation failure. 

6.1.3.2. Service/replace electrical and/or pneumatic 

components, as needed. 

6.1.3.3. Service/replace actuator and/or valve components, as 

needed. 

6.1.4. In case of physical/electrical failure of control system component: 

6.1.4.1. Identify faulty control system component. 

6.1.4.2. Service/replace control system components, as needed. 

6.2. Loss of Lime Slurry Flow Control 

6.2.1. In case of loss of slurry flow to SDA, see 6.1. 

6.2.2. In case of physical/electrical failure of flow transmitter 

Service/replace flow.trarisrmtter and/or associated instrumentation, 

as needed. 

6.2.3. ba case of actuated valve failure: 

6.2.3.1. Identify cause of actuation failure. 

6.2.3.2. Service/replace electrical and/or pneumatic 

components, as needed. 

6.2.3.3. Service/replace actuator and/or valve components, as 

. needed. 

6.2.4. In case of physical/electrical failure of control system component: 

6.2.4.1. Identify faulty conhol system component 

6.2.4.2. Service/replace control system components, as needed. 

Page 16 of 26 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRAM OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

6.3. Loss of City Water Flow to SDA (Unit 2 and 3) 

6.3.1. In case of total loss of city water supply, see 1.5. 

6.3.2. In case of plugging/physical failure of line or line component: 

6.3.2.1. Identify the location of plugging or line failure. 

6.3.2.2. Clear line plugging and/or service/replace faulty line 

components, as needed. 

6.3.3. mease of mechanical/electrical failure of actuated valve: 

6.3.3.1. Identify cause of actuation failure. 

6.3.3.2. Service/replace electrical and/or pneumatic 

components, as needed. 

6.3.3.3. Service/replace actuator and/or valve components, as 

needed. 

6.4. Loss of Cooling Air Flow to Atomizer 

6.4.1. In case of mecharhcal/electrical failure of atomizer cooling air 

blower 

6.4.1.1. Diagnose blower/drive failure. 

6.4.1.2. Service/replace the blower/drive, as needed. 

6.4.1.3. Restore electrical power supply to the blower. 

6.4.2. In case of physical failure of atomizer cooling ah duct: 

6.4.2.1. Identify the location of duct failure. 

6.4.2.2. Service/replace faulty duct, as needed. 

6.4.3. In case of physical/electrical failure of control system component: 

6.4.3.1. Identify faulty control system component 

6.4.3.2. Service/replace control system components, as needed 

6.5. Loss of SDA Exit Gas Temperature Control 

6.5.1. In case of loss of city water flow to SDA, see 6.3. 

6.5.2. In case of physical/electrical failure of temperature transmitter: 

Service/replace temperature fransmitter and/or associated 

instrumentation, as needed. 

. 6.5.3. In case of actuated valve failure: 

6.5.3.1. Identify cause of actuation failure. 

6.5.3.2. Service/replace electrical and/or pneumatic 

components, as needed. 

6.5.3.3. Service/replace actuator and/or valve components, as 

needed. 

6.5.4. In case of physical/electrical failure of control system component: 

Page 17 of 26 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRAM OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

6.5.4.1. Identify faulty control system component. 

6.5.4.2. Service/replace control system components, as needed. 

6.6. Atomizer Failure 

6.6.1. mease of low atomizer lubrication oil flow; 

6.6.1.1. Diagnose the failure in the lubrication system 

6.6.1.2. Service/replace components ofthe lubrication system, 

as needed. 

6.6.2. In case of mechanical/electrical failure of atomizer: 

6.6.2.1. Diagnose atomizer/drive failure. 

6.6.2.2. Service/replace the atomizer/drive, as needed. 

6.6.2.3. Restore electrical power supply to me atomizer. 

6.6.2.4. components, as needed. 

Page 18 of 26 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRAM OF CORRECTIVE ACTIONS FO R MALFUNCTIONS 

7.0 UNIT 4 SPRAY DRYER ABSORBER (SDA) 

7.1. Loss of Lime Slurry Flow to SDA 

7.1.1. In case of mechanical/electrical failure of lime slurry feed pump: 

7.1.1.1. Diagnose pump/drive failure. 

7.1.1.2. Service/replace the pump/drive, as needed. 

7.1.1.3. Restore electrical power supply to the pump. 

7.1.2. In case of plugging/physical failure of line or line component: 

7.1.2.1. Identify the location of plugging or line failure. 

7.1.2.2. Clear line plugging and/or service/replace faulty line 

components, as needed. 

7.1.2.3. Restore/corifirm functional heat tracing, if applicable. 

7.1.3. In case of mechanical/electrical failure of actuated valve: 

7.1.3.1. Identify cause of actuation failure. 

7.1.3.2. Service/replace electrical and/or pneumatic 

components, as needed. 

7.1.3.3. Service/replace actuator and/or valve components, as 

needed. 

7.1.4. In case of physical/electrical failure of control system component: 

7.1.4.1. Identify faulty control system component. 

7.1.4.2. Service/replace control system components, as needed. 

7.2. Loss of Lime Slurry Flow Control/Exit Gas Temperature Control 

7.2.1. In case of loss of slurry flow to SDA, see 7.1. 

7.2.2. In: case of physical/electrical failure of flow transmitter: 

Service/replace flow transmitter and/or associated instrumentation, 

as needed. 

7.2.3. In case of actuated valve failure: 

7.2.3.1. Identify cause of actuation failure. 

7.2.3.2. Service/replace electrical and/or pneumatic 

components, as needed. 

7.2.3.3. Service/replace actuator and/or valve components, as 

needed. 

7.2.4. In case of physical/electrical failure of control system component: 

7.2.4.1. Identify faulty control system component. 

7.2.4.2. Service/replace control system components, as needed. 

Page 19 of 26 

V E S 001981 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRA M OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

7.3. Loss of Atomization Air Pressure to SDA Nozzle 

7.3.1. For a total loss of plant/instrument air supply, see 1.3. 

7.3.2. In case of plugging/physical failure of line or line component: 

7.3.2.1. Identify the location of plugging or line failure. 

7.3.2.2. Clear line plugging and/or service/replace faulty line 

components, as needed. 

Page 20 of 26 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRAM OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

CARBON INJECTION SYSTEM (UNIT 4) 

8.1. Loss of Carrier Gas Pressure 

8.1.1. In case of mechanicaiyelectrical failure of carbon injection air 

blower: 

8.1.1.1. Diagnose blower/drive failure. 

8.1.1.2. Service/replace the blower/drive, as needed. 

8.1.1.3. Restore electrical power supply to the blower. 

8.1.2. In case of physical failure air duct: 

8.1.2.1. Identify the location of duct failure. 

8.1.2.2. Service/replace faulty duct, as needed. 

8.1.3. In case of physical/electrical failure of control system component: 

8.1.3.1. Identify faulty control system component 

8.1.3.2. Service/replace control system components, as heeded. 

8.2. Loss/Restriction of Activated Carbon Flow 

8.2.1. In case of loss of plant air to carbon bulk sack, see 8.3 

8.2.2. In case of mechanical/electrical failure of carbon feeder: 

8.2.2.1. Diagnose feeder/drive failure. 

8.2.2.2. Service/replace the feeder/drive, as needed. 

8.2.2.3. Restore electrical power supply to the carbon feeder. 

8.2.3. In case of plugging/physical failure of line or line component: 

8.2.3.1. Identify the location of plugging or line failure. 

8.2.3.2. Clear line plugging and/or service/replace faulty line 

components, as needed. 

8.2.3.3. Restore/c»nfirm functional heat tracing, if applicable. 

8.3. Loss of Plant Air Pressure/Flow to Carbon Bulk Sack 

8.3.1. For a total loss of plant/instrument ah supply, see 1.3. 

8.3.2. In case of plugging/physical failure of line or line component: 

8.3.2.1. Identify the location of plugging or line failure. 

8.3.2.2. Clear line plugging and/or service/replace faulty line 

components, as needed. 

8.3.3. In case of mechanical/electrical failure of actuated valve: 

8.3.3.1. Identify cause of actuation failure. 

8.3.3.2. Service/replace electrical and/or pneumatic 

components, as needed. 

Page 21 of 26 
ONY X ENVIRONMENTAL SERVICES, INC. 

PROGRAM OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

8.3.3.3. Service/replace actuator and/or valve components, as 

needed. 

8.3.4. In case of physical/electrical failure of control system component: 

8.3.4.1. Identify faulty control system component. 

8.3.4.2. Service/replace control system components, as needed. 

Page 22 of 26 

V E S 001984 
ONY X ENVIRONMENTAL SERVICES, INC. 

PROGRAM OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

BAGHOUSE & INDUCED DRAFT (ID) FA N 

9.1. Torn/Leaking Bag 

9.1.1. In case of a baghouse leak detection alarm, follow the relevant 

corrective measures prescribed in the Operation and Maintenance 

Plan. 

9.1.2. In case of a baghouse leak detection system failure: 

9.1.2.1. Service/replace tom/leaking bag(s), as needed. 

9.1.2.2. Diagnose fhe failure of the baghouse detection system. 

9.L2.3. Service/replace baghouse leak detection system, as 

needed. 

9.2. Bag Blinding/High-High Pressure Drop 

9.2.1. In case of low baghouse inlet gas temperature: 

9.2.1.1. Follow fhe appropriate corrective actions prescribed by 

paragraph 6.5 (Unit 2 and 3) 

9.2.1.2. Follow the appropriate corrective actions prescribed by 

paragraph 7.2 (Unit 4) 

9.2.1.3. Perform baghouse inspection. 

9.2.1.4. Service/replace bag(s), as needed. 

93. Loss of Stack Gas Flowrate Control (Unit 2 and 3) 

9.3.1. In case of ID fan failure, see 9.5 

9.3.2. In case of physical/electrical failure of flow transmitter: 

Service/replace flow transmitter and/or associated instrumentation, 

as needed. 

9.3.3. In case of actuated damper failure: 

9.3.3.1. Identify cause of actuation failure. 

9.3.3.2. Service/replace electrical and/or pneumatic 

components, as needed. 

9.3.3.3. Service/replace actuator and/or damper components, as 

needed. 

9.3.4. In case of physical/electrical failure of control system component: 

9.3.4.1. Identify faulty control system component. 

9.3.4.2. Service/replace control system components, as needed. 

9.4. Baghouse Isolation Damper Malfunction (Unit 4) 

9.4.1. In case of actuated damper failure: 

Page 23 of 26 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRAM OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

9.4.1.1. Identify cause of actuation failure. 

9.4.1.2. Service/replace electrical and/or pneumatic 

components, as needed. 

9.4.1.3. Service/replace actuator and/or damper components, as 

needed. 

9.4.2. In case of physical/electrical failure of control system component: 

9.4.2.1. Identify faulty control system component. 

9.4.2.2. Service/replace control system components, as needed. 

9.5. ID Fan Failure 

9.5.1. In case of mechanical/electrical failure of ID fan: 

9.5.1.1. Diagnose fan/drive failure. 

9.5.1.2. Service/replace the fan/drive, as needed. 

9.5.1.3. Restore electrical power supply to fhe ID fan. 

Page 24 of 26 

V E S 001986 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRAM OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

10.0 CONTROL SYSTEM/CONTINUOUS MONITORING SYSTEM 

10.1. Control System/Continuous Monitoring System Malfunction 

10.1.1. As needed, refer fo the CMS QA/QC Plan for guidance and to 

ensure that proper calibrations are performed. 

10.1.2. In case of physical/electrical failure of mstrumentation: 

10.1.2.1. Identify faulty instrumentation component. 

10.1.2.2. Service/replace faulty instrumentation components, as 

needed. 

10.1.3. In case of physical/electrical failure of control system component: 

10.1.3.1. Identify faulty control system component. 

10.1.3.2. Service/replace control system components, as needed. 

10.1.4. In case of physical/electrical failure of data acquisition/availabihty: 

10.1.4.1. Identify faulty data system components. 

10.1.4.2. Service/replace data system components, as needed. 

10.2. Continuous Emissions Momtoring System Malfunction 

10.2.1. As needed, refer to the. CEMS QA/QC Plan for guidance and tp 

ensure that proper calibrations are performed and that the 

appropriate perfonnance specifications are met. 

10.2.2. In case of physical/electrical failure umbilical beat tracing: 

. 10.2.2.1. Diagnose failure of heat tracing. 

10.2.2.2. Replace/restore heat traced sample umbihcal. 

10:2.3. In case of mechanical/electrical failure of heated vacuum pump; 

10.2.3.1. Diagnose pump/drive failure. 

10.2.3.2. Service/replace the pump/drive, as needed. 

10.2.3.3. Replace/restore pump head heat source. 

10.2.3.4. Restore electrical power supply to heated vacuum 

pump. 

10.2.4. In case of plugging/physical failure of sample probe/umbilical: 

10.2.4.1. Identify the location pf failure. 

10.2.4.2. Clear plugging and/or service/replace faulty 

components, as needed. 

10.2.5. In case of mechanical/electrical failure of actuated valve: 

10.2.5.1. Identify cause of actuation failure. 

Page 25 of 26 

V E S 001987 
ONY X ENVIRONMENTAL SERVICES, INC. 

PROGRAM OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

10.2.5.2. Service/replace electrical and/or pneumatic 

components, as needed. 

10.2.5.3. Service/replace actuator and/or valve components, as 

needed. 

10.2.6. In case of mechanical/electrical failure of analyzer: 

10.2.6.1. Refer to manufacturer's service manual for guidance on 

troubleshooting and servicing analyzer. 

10.2.6.2. Service/replace analyzer, as needed. 

10.2.7. In case of mechanical/electrical failure of associated 

instrumentation: 

10.2.7.1. Identify faulty instrumentation component. 

10.2.7.2. Service/replace faulty instrumentation components, as 

needed. 

10.2.8. In case of physical/electrical failure of control system component: 

10.2.8.1. Identify faulty control system component. 

10.2.8.2. Service/replace control system components, as needed. 

Page 26 of 26 
STARTUP, SHUTDOWN AND MALFUNCTION PLAN 

Prepared for: 

Onyx Environmental Services, Inc. 

Sauget, Elinois 

Prepared by: 

Franklin Engineering Group, Inc. 

Franklin, Tennessee 

July 2005 
TABL E O F CONTENT S 

1.0 INTRODUCTIO N 1 

1. l REGULATORY REQUIREMENTS - 2 

1.2 RECORDKEEPING AN D REPORTING PROCEDURES 2 

1.2.1 Records •. - 4 

1.2.2 Reports . 4 

2.0 ENGINEERIN G DESCRIPTIO N , 6 

3,0 STARTU P AN D SHUTDOW N PROCEDURES . .1 3 

3.1 STARTUP , •• 13 

3.2 NORMA L SHXTTOOWN ~ 15 

4.0 MALFUNCTIONS........ . » 1 6 

4.1 MEASURES TO MINIMIZE THE FREQUENCY OF MALFUNCTIONS 16 

4.2 MEASURES TO MINIMIZE THE SEVERITY OF MALFUNCTIONS 18 

4.3 CORRECTIVE MEASURES 19 

i 

V E S 001 
LIS T O F T ABLE S 

TABLE 1 -1 OVERVIEW OF REGULATIONS REGARDING STARTUP, SHUTDOWN AND 

MALFUNCTION 3 

TABLE 4-1 SUMMARY OF POTENTIAL MALFUNCTIONS AN D CAUSES 17 

TABLE 4-2 REDUNDANT EQUIPMENT AN D SYSTEMS FOR MINIMIZING THE FREQUENCY 

OR SEVERITY OF MALFUNCTIONS 2 0 

LIS T O F FIGURE S 

FIGURE 2-1 FIXED HEARTH INCINERATOR, UNIT 2, BLOCKFLO W DIAGRAM 7 

FIGURE 2-2 FIXED HEARTH INCINERATOR, UNIT 3, BLOC K FLOW DIAGRAM 8 

FIGURE 2-3 ROTARY KIL N INCINERATOR, UNIT 4, BLOC K FLOW DIAGRAM 11 

LIS T O F ATTACHMENT S 

STARTUP RECORDKEEPING FORM 

SHUTDOWN RECORDKEEPING FORM 

MALFUNCTION RECORDKEEPING FORM 

PROGRAM O F CORRECTIVE ACTIONS FOR MALFUNCTIONS 

ATTACHMENT 1 

ATTACHMENT 2 

ATTACHMENTS 

ATTACHMENT 4 

ii 
1.0 INTRODUCTION 

Onyx Environmental Services, Inc. (Onyx) owns and operates two fixed hearth, incinerators 

(Units 2 and 3) and a rotary kiln incinerator (Unit 4) at its facihty located in Sauget, Illinois. The 

incinerators are subject to the National Ernissions Standards for Hazardous Air Pollutants 

(NESHAP) for Hazardous Waste Combustors (HWC), codified as 40 CFR, Part 63, Subpart EEE 

(§ 63.1200 to § 63.1213). The NESHAP specifies emissions standards which reflect emissions 

performance of Maximum Achievable Control Technologies (MACT), and is commonly referred 

to as the HWC MACT. 

The HWC MACT Standard defines fhe control of emissions during normal, day-to-day 

operations. In order to address the control of emissions during transient periods, the 

development of a Startup, Shutdown, and Malfunction Plan (SSMP) is required. Startup, 

shutdown, and malfunction (SSM) are defined in § 63.2 as follows: 

• ' Startup — the setting in operation of an affected source or portion of an affected source for 

any purpose 

• Shutdown - the cessation of operation of an affected source or portion of an affected 

source for any purpose 

• Malfunction — any sudden, irifrequent, and not reasonably preventable failure of ah 

pollution control and momtoring equipment, process equipment, or a process to operate 

in a normal or usual manner which causes, or has the potential to cause, the emission 

limitations in an apphcable standard to be exceeded. Failures that are caused in part by 

poor maintenance or careless operation are not malfunctions 

During these transient periods of operations, a source must conform with its SSMP. Therefore, 

during periods of startup, shutdown, and malfunctions the operating and mamtairiing of the 

incinerator will be consistent with the procedures and corrective actions that are prescribed in 

this plan. This will ensure that emissions are minimized, to the extent practical. 

The purpose of this startup, shutdown, and malfunction plan is to: 

• Prescribe procedures for operating the incinerator systems during periods of startup, 

shutdown, and malfunction that are consistent with safety and good ah pollution control 

practices 

• .Describe measures for the prevention and minimization of excess ernissions during 

periods of startup, shutdown, and malfunction 

• Reduce the reporting burden associated with periods of startup, shutdown, and 

malfunction 

• Satisfy the requirements of § 63.1206(c) and $ 63.6(e)(3), as shown in Table 1-1 

1 
Due to the similarity of the three incinerator systems, general references to an incinerator in this 

document will imply all three incinerator systems. Information that is only apphcable-to one or 

two of the three units will be clearly identified either parenthetically or delineated by the section 

heading. 

As requhed by §§ 63.6(e)(v) and 63.6(e)(vi), this plan and other documents contahiing 

procedures or information referred to in this plan will be made available for mspection when 

requested by the Administrator. If Onyx is required to submit copies of this plan or portions of 

this plan (or related documents) confidential business information entitled to protection from 

disclosure will be clearly designated. 

The remainder of this section provides an overview of regulatory requhements and a program for 

compliance with the recordkeeping and reporting requhements. Section 2.0 references an 

engmeering description of the incinerator, ah pollution control system, and continuous 

momtoring system. Section 3.0 addresses the startup and shutdown of the incinerator system. 

Section 4.0 addresses potential malfunctions ofthe incinerator system. 

1.1 Regulatory Requhements 

One of the objectives for this document is to estabhsh a program that will ensure compliance . 

with relevant sections of the Interim MACT Standards. Table 1-1 includes the regulatory 

requirements and the location of each requirement addressed herein. 

. .1.2 Recordkeeping and Reporting Procedures 

This section addresses the recordkeeping and reporting requhements related to periods of SSM. 

The startup, shutdown, and malfunction reports discussed in this plan ensure that Onyx is 

satisfying the general duty to minimize emissions and document that actions taken during those 

periods are consistent with this plan. These reports and records provide the necessary 

documentation to shield transient events from the HWC MACT emission standards imposed on 

steady-state operations.. 

As long as actions taken during a transient event sufficiently maintain the incinerator system 

within limits, there is no justification in distinguishing that event from steady-state operations. 

For example, problems may arise that meet the definition of a malfunction yet do not impact the 

.ability to maintain the incinerator system within limits. In these cases, maintaining the 

incinerator system within limits substantiates that the actions taken sufficiently met the 

objectives of this SSMP and minimized emissions to a greater degree than requhed by 

regulations. 
Table 1-1 

Overview of Regulations Regarding Startup, Shutdown and Malfunction 

Regulatory Citation Description 

SSMP 

Section 

§ 63.6(e)(3)(i) Purpose ofthe SSMP 1.0 

§ 63.6(e)(3)(i> Procedures for operating arwi. maintaining the source during startup 3.1, Table 3-1 

§ 63.6(e)(3)(i) 

Procedures for operating and mamtaining the source during 

shutdown 

3.2, Table 3-1 

§ 63.6(e)(3)(i) 

Procedures for operating and maintaining the source during 

malfunction 

Attachment 4 

•§63.6(e)(3Xi) A program of corrective action for iriaUimctioningjirocess Attachment 4 

§ 63.6(e)(3Xii) During SSM, operate and maintain source in accordance with SSMP 1.0 

§ 63.6(e)(3)(iii) Records and reports when actions conform with SSMP 1.2.1 

§63.6(eX3Xiv) 

Records and reports when actions do not conform with SSMP and 

result in an exceedance 

1.2.2 

§63.6(eX3Xv) Availability of current and superseded SSMPs 1.2 

§63.6( e )(3)(vi) Use and availability of other plans 1.0 

§63.6(eX3XviH) Revisions to the SSMP 1.2.2 

§ 63.10(b)(1) Mamtaining files 1.2 

§ 63.10(b)(2)(i> Record occurrence and duration of each startup and shutdown 1.2.1 

§ 63:i0(b)(2)(ii) . Record occurrence and duration of each malfunction 1.2.1 

§63.10(b)(2)(iv) Records of actions inconsistent with SSMP 1.2.1 

§ 63.10fb)(2)(v) Records demonstrating conformance with SSMP 1.2.1 

§ 63.10(bX2)(vi) , Record periods' of maJbfmtctioning CMS 1.2.1 

§63.10(d)(5)(i) Periodic startup, shutdown, and malfunction reports 1.2.2 

§63.10(d)(5Xii) Immediate startup, shutdown, and malfunction reports 1.2.2 

§ 63.l206(c)(2)(ii)(A) Description of potential causes of malfunctions 

Table 4-1, 

Attachments 

§.63.1206(c)(2Xii)(A) Actions to minimize the frequency and severity of malfunctions 

4.1,4.2 

Table 4-2 

Attachment 4 

§ 63:i206(c)(2Xii)(C) Changes to the plan 1.2.2 

§ 63.1206(c)(2)(iii) 

Projected oxygen.correction factor to use during startup and 

shutdown . 

3.0 

§ 63.1206(cX2)(iv) Record plan in the operating record 1.2 

§63.1206(c)(2)(v)(A)(l) AWFCO requirements during malfunctions 3.0 

§ 63.1206(c)(2)(v)(A)(3)(i) . 

Investigation and evaluation of excessive exceedances during 

malfunctions 

1.2.2 

§63.1206(c)(2)(vXA)(3Xi) 

Revisions to SSMP due to excessive exceedances during 

malfunctions 

1.2.2 

§ 63.1206(c)(2)(v)(A)(3Xii) 

Record results from investigation and evaluation of excessive 

exceedances 

1.2.2 

§ 63,12006(c)(2)(v)A(3Xii) 

Additions to excess emissions report [§ 63.10(e)(3)] due to 

excessive exceedances during malfunctions 

1.2.2 

§ 63.l206(c)(2)(v)(B)(l) Waste feed restrictions and other OPLs during startup and shutdown 3.0 

§63.1206(c)(2)(v)(BX2) Interlock OPLs of (c)(2)(v)(B)(l) with AWFCO system 3.0 

§ 63.1206(c)(2)(v)(B)(3) AWFCO due to exceedance of startup/shutdown OPL 3.0 
Accordingly, the recordkeeping and reporting requirements presented in this section are 

only applicable to periods of SSM in which there is a reasonable expectation that an OPL 

or emission standard can not be met. This includes all startups, all shutdowns, and all 

malfunctions that result in an exceedance of an operating limit or emission standard. 

Malfunctions that prevent the ability to document on-going comphance are also subject to 

recordkeeping and reporting requirements. 

This plan, all revisions to this plan, and all records and reports described in this section 

will be retained in the operating record for at least five years. 

1.2.1 Records 

SSM records will include the following: 

• Date and time of each SSM 

• The duration of each SSM 

• Documentation to demonstrate that actions taken during periods of SSM are 

consistent with this SSMP 

• . Description of any actions taken during periods of SSM that are not consistent 

with procedures in this SSMP 

• Results of investigations and evaluations of excessive exceedances occurring 

during malfunctions 

Attachments 1, 2, and 3 are blank recordkeeping forms for startups, shutdowns, and 

malrunctions, respectively. The information recorded on these forms will be. utilized to 

document conformance with the SSMP and to comply with the reporting requhements. 

The startup, shutdown, and malfunction reporting requhements are described in the next 

section. 

1.2.2 Reports 

Revisions to this SSMP may be made without prior agency approval to reflect changes in 

equipment and procedures and to meet the regulatory requhements. Any such revisions 

made during a semiannual reporting period will be submitted with the periodic SSM 

report. Revisions to this plan—which alter the scope of activities during a startup, 

shutdown, or malfonction—will not take effect until a written notice, describing the 

revisions^ is submitted to the permitting authority. Changes made to this plan that may 

significantly increase emissions are subject to approval by the Administrator. A written 

request for approval of the changes and the revised SSMP will be submitted to the 

4 

V E S 001995 
Administrator within 5 days after making such a change to this plan. Should an SSM 

event occur that is not. addressed or inadequately addressed in this SSMP, Onyx will 

make the appropriate revisions to this plan within 45 days after the event. 

An investigation and evaluation will be performed on each set of 10 exceedances of a 

specific emission standard of a specific operating parameter limit that occur during 

malfunctions within a 60 day period. Within 45 days of the 10th exceedance, tbe 

investigation will determine plausible causes for each excessive exceedance. The 

evaluation will conclude how to minimize fhe frequency, duration, and severity of each 

excessive exceedance. The excessive emissions report required under § 63.10(e)(3) will 

include a summary of each investigation and evaluation requhed during the semiannual 

reporting period. In addition, the excessive emissions report will mclude any changes to 

this plan that may result from required investigations and evaluations of excessive 

exceedances occurring during malfunctions. 

Periodic SSM. reports will be submitted to the Administrator semiannually, if a startup, 

shutdown, or malfunction occurred during that semiannual reporting period. This report 

will take the form of a letter to. the Administrator and mclude the following infonnation: 

• A statement that actions taken during all periods of startup, shutdown, or 

malfunction were consistent with the procedures given in this SSMP 

• The number, duration, and a brief description of each malfunction 

• The name, title, arid signature ofthe owner/operator (or other responsible official) 

certifying the accuracy of the report 

An immediate SSM report will be submitted if an action performed during a period of 

SSM is not consistent with this plan; and an OPL or emission standard is exceeded. 

Within two working days after such an action, the Administrator will be advised via 

telephone or fax. Within 7 working days after such an action, a letter to the 

Administrator will be delivered or postmarked. The letter will explain the event, reasons 

for not following this plan, and descriptions of the excess emissions and/or operating 

parameter monitoring exceedances believed to have occurred. The letter will also include 

the name, title, and signature of the owner/operator (or other responsible official) 

certifying the accuracy of the report. 
2.0 ENGINEERING DESCRIPTION 

Brief descriptions of the fixed hearth, incinerators and the rotary kiln incinerator are 

presented in this section. A detailed engineering description of the Unit 2 and 3 

incinerators is provided by Technical Description—Fixed Hearth, Incinerators Units 

NOS. 2 &3. A detailed engmeering description ofthe Unit 4 incinerators is provided by 

Technical Description, Transportable Rotary Kiln Incinerator Unit No. 4. Drawing 

numbers PFD-2000, PFD-3000, PFD-4000 are the process flow diagrams for these 

incinerators. These documents and drawings are incorporated here by reference. 

2.1 Fixed Hearth Incinerators 

Each of the fixed hearth incinerators includes the following components: 

• Feed equipment 

• Primary and secondary combustion chambers 

• Lime injection system 

• Spray dryer absorber (SDA) 

• Fabric filter baghouse 

• Solids, and ash removal systems 

• Induced draft (TD) fan and stack 

• mstrumentation, controls, and data.acquisition systems 

Figure 2-1 presents a block flow diagram of the Unit 2 incinerator system.- The block 

flow diagram for Unit 3 is presented in Figure 2-2. 

A variety of sohd, liquid, and gaseous wastes are thermally treated in the fixed hearth 

incinerators. Solid waste is fed to the primary (lower) combustion chamber via a feed 

conveyor system and pneumatic ram. Liquid waste from tanks and tanker trucks are fed 

to the primary combustion chamber through two atomized liquid injectors. 

Both Units 2 and 3 are equipped with a specialty waste feed systems. The Unit 2 primary 

waste from liquid containers and gas cylinders are fed to the Unit 2 primary combustion 

chamber through a specialty feed port. Waste from liquid containers is fed from a 

hooded feed system to fhe Unit 3 primary combustion chamber through a specialty feed 

injector. Off gases from the hooded, feed emission control system aire fed dhectly. to 

6 

V E S 001997 
HIGH 

81U 

U (MOS 

SOUOS 

(III I 

I I I I I 

T T T t T 

COMBUSTON 

AIR 

ROWER 

T" 

M NK FARM ( LOW • 

BTU 

DIRECT INJECT , LIQUIDS 

££££ 

INCINERATOR 

LOWER 

CHAMBER 

LIQUID CONTAINERS, 

SPECIALTY 

FEEOER 

\ PRIMARY V 

/-SE C 

UME 

PREPARATION 

SYSTEM 

SPRAY 

ORY 

ABSORBER' 

WET ASH 

DUMPSTER 

0ACHOUSE 

ORY SCRUBBER DRY SCRUBBER 

SOLIDS ( DSS j SOLIDS ( DSS ) 

END DUMP END DUMP 

FUELS/LIQUID WASTC FLOW 

f C0H8U51WN *K FLOW 

.. i » SJACK CAS FLOW 

OOOOOO* ASH FLOW 

lOOOO* - SOUO WASTC FLOW 

UME SLURRY FLOW 

Figure 2-1 Fixed Hearth Incinerator, Unit 2, Block Flow Diagram 

< 

m • 

OO 7 

o 

o 

C D 

C D 

no 
TANK FARM 

DIRECT INJECT. 

IIII I 

.Mil l 

• TTTT.T . 

COMBUSTION 

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TANK FARM , LOW 

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££££" 

INCINERATOR 

LOWER 

CHAMBER 

SPECIALTY FEEDER 

FUME HOOD 

EMISSION CONTROL 

SYSTEM 

\ rrawRY V 

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l / 3 

INCINERATOR 

UPPER 

CHAMBER 

WET ASH 

DUMPStER 

U ME 

PREPARATION 

SYSTEM 

SPRAY 

ORY 

ABSORBER 

ORY SCRUBBER 

SOUDS ( DSS ) 

END DUMP ' 

MAIN STACK • 

DRY SCRUBBER, 

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END DUMP 

CLOVE BOX 

EMISSION CONTROL] 

SYSTEM 

FUELS/UOUIO WASTE FLOW 

COHBUSTIOM AW. FLOW 

' i > STACK OAS FLOW 

000000 * ASH FLOW 

KX>0O» - SOUO WASTE FLOW 

UME SLURRY FLOW ' 

Figure 2-2 Fixed Hearth Incinerator, Unit 3, Block Flow Diagram 

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the Unit 3 secondary combustion chamber. Off gases from a waste handling glove box 

are also fed directly to the Unit 3 secondary combustion chamber. 

The primary combustion chamber main burner and the secondary combustion chamber 

main burner are used to maintain temperatures on natural gas. Combustion gases exit the 

primary combustion chamber and enter into the secondary combustion chamber, which 

serves as an afterburner. Combustion gases exit the secondary combustion chamber and 

enter the SDA. The secondary combustion chamber is equipped with an emergency 

stack. 

Lime slurry and water are fed to the SDA atomizer. The atomizer has a rapidly spimung 

wheel that atomizes the lime slurry and water into a cloud of fine droplets. Combustion 

gases are directed upward through a disperser in the SDA and into the cloud of fine 

droplet created by the atomizer. This provides acid gas' removal and coohng of the 

combustion gas. Dried spent chemicals and ash settle to the bottom ofthe SDA and are 

discharged to the ash removal system. 

Combustion gas exits the SDA and is distributed to the fabric filter modules. Unit 2 has 

four fabric filter modules and Unit 3 has three fabric' filter modules. Combustion gas 

passes through Teflon-coated fiberglass cloth bags. Particles in the combustion gases are 

deposited on the outside of each bag in the filter module... During the bag cleaning cycle, 

a burst of air in the direction opposite to the gas flow dislodges particulate matter from 

the bag. 

The induced draft fan is located downstream of fhe fabric filter baghouse. The induced 

draft fan moves the combustion gas through the system and exhausts the gas through the 

main stack. ' 

Hot, wet gas is extracted downstream of the baghouse through a continuous emissions 

momtoring system. This system features a multi-component infrared gas analyzer that 

detects hydrogen chloride, carbon monoxide, and water vapor concentrations. An 

integrated zirconium oxide-based analyzer detects oxygen concentrations. 

2.2 Rotary Kiln Incinerator 

The rotary kiln incinerator includes the following components: 

• Waste feed system 
• Primary and secondary combustion chambers 

• Tempering chamber 

• Lime injection system 

• Spray dryer absorber 

• Carbon injection system 

• Fabric filter baghouse 

• Solids and ash removal systems 

• Induced draft (ID) fan and stack 

• mstrumentation, controls, and data acquisition systems 

Figure 2-3 presents a block flow diagram of the Unit 4 incinerator system. 

A variety of sohd and liquid wastes are thermally treated in fhe rotary kiha incinerator. 

Solid wastes are fed to a ram feeder via a clamshell, a <hum feed conveyor and an 

auxiUary feed conveyor. A hydraulic ram pushes the sohd waste into the kiln. Liquid 

waste from tanks and tanker trucks is fed to the primary and secondary combustion 

chambers through atomized liquid injectors. 

The primary combustion chamber main burner and the secondary combustion chamber 

main burner are used to maintain temperatures on natural gas. Combustion gases exit the 

primary combustion chamber and enter into the secondary combustion chamber, which 

serves as ah afterburner. A surge vent is located at the front ofthe kiln and the secondary 

combustion chamber is equipped with a thermal relief vent. 

Combustion gases exit the secondary combustion chamber and enter the tempering 

chamber. Process water is fed to tempering chamber through ah atomized spray nozzles. 

Combustion gas is copied as it passes through the spray of water. The water is 

completely vaporized, cooling the combustion gas. The combustion gas exits the 

tempering chamber and is distributed between two identical SDAs. 

Lime slurry is fed to each SDA through ah atomized spray nozzles. Combustion gases 

are directed downward through a duct in the SDA and then dispersed symmetrically into 

the cloud of atomized lime. This provides acid gas removal and cooling of the. 

combustion gas. Dried spent chemicals and ash settle to the bottom ofthe SDA and are 

discharged to the ash removal system. 

10 
V ES 002005 
A carbon injection system is utilized for controlling dioxin/fiiran and mercury emissions. 

The activated carbon is ah injected into the combustion gas immediately downstream of 

the convergence of combustion gases from fhe SDAs. 

Combustion gases exit the SDAs and are distributed to two fabric filter modules. Each 

module has three compartments in parallel containing, multiple fabric bags, Combustion 

gas passes through the fabric bags. Particles in the combustion gases are deposited on the 

outside of each bag. During the bag cleaning cycle,, a burst of ah in the dhection 

opposite to fhe gas flow dislodges particulate matter from the bag. 

The induced draft fan is located downstream ofthe fabric filter baghouse. The induced 

draft fan moves the combustion gas through the system and exhausts the gas through the 

main stack. . 

Hot, wet gas is extracted downstream of the ID fan through a continuous emissions 

monitoring system. This system features a multi-component infrared gas analyzer that 

detects hydrogen chloride, carbon monoxide, and water vapor concentrations. An 

integrated zirconium oxide-based analyzer detects oxygen concentrations. 

12 
3.0 STARTUP AND SHUTDOWN PROCEDURES 

The purpose of this section is to prescribe procedures for the startup and shutdown ofthe 

incinerator system. This section also clarifies which actions are within the scope of the 

regulatory definition of startup and shutdown. 

To satisfy the requhements of § 63.1206(c)(2)(v)(B), waste feed restriction and operating 

limits have been imposed to startups and shutdowns. During a startup, the feeding of 

hazardous waste to the incinerator will not be initiated until all operating parameters are 

within limits. Hazardous waste will not be fed during a shutdown event. 

Consistent with the requirements of § 63.1206(c)(2)(iii), Onyx will utilize an oxygen 

correction factor of 1.6 (i.e., 12.3% O2) during periods of startup and shutdown. This 

will eliminate wide variations in corrected CO concentration that can occur during startup 

and shutdown due to changes in the oxygen concentration^ The oxygen correction factor 

of 1.6 is based on the average oxygen correction factor observed during normal 

operations of the incinerators. This "default" oxygen correction factor can only be 

utiUzed when the waste residence time in the primary combustion chamber has expired 

and when the incinerator is in startup or shutdown. 

Onyx has developed standard division practices (SDPs) for the operation; of each 

incinerator system and ancillary equipment and systems. The SDPs contoiriing startup 

and shutdown procedures for the incinerators are: 

• SDP 2201 Startup, Operation, and Shutdown of No. 2/B Incinerators 

• SDP 2417 Startup, Operation, and Shutdown of No. 4 Incinerator 

3.1 Startup 

A ll startups are preceded by a shutdown. Depending on the purpose of the preceding 

shutdown, portions of the ah pollution control system may be in service upon 

commencing a startup. This will be reflected on the startup record (see Attachments 1). 

During a startup, waste will not be introduced until all operating parameters are within 

hmits. A startup event is concluded once waste is introduced and all operating 

parameters are within limits. 

Onyx's startup procedures are representative, of safety and good ah pollution control 

practices. The procedures are designed to mimrnize the potential for excess ernissions by 

ensuring that all equipment is fully operational (within permit limits) prior to the 

13 
introduction of hazardous waste to the system. Adherence to these startup procedures 

will employ "the knowledge and skills demonstrated through the implementation of the 

Operator Training and Certification Program. 
3.2 Normal Shutdown 

Some shutdowns will allow the primary combustion chamber to cool. Prior to these 

shutdowns, the incinerator will be burning auxiliary fuel only and the hazardous waste 

residence time will have transpired: A shutdown will be initiated with the shutoff of 

auxiliary fuel to the incinerator or by shutoff of me ID fan. Other shutdowns will be 

. initiated with the cessation of all waste feeds by the operator to stabilize system operating 

parameters. Portions or all of the ah pollution control system may remain in operating 

mode at the conclusion of a shutdown through the subsequent startup. 

Onyx's shutdown procedures are representative of safety and good ah pollution control 

practice. The procedures are designed tb mimmize the potential for excess ernissions by 

ensuring that all waste feeds are off arid/or the hazardous waste residence time has 

transpired prior to the shutdown of the incinerator system. Adherence to these shutdown 

procedures will employ the knowledge and skills demonstrated through the 

implementation of the Operator Training and Certification Program. Procedures for 

emergency shutdown are described in the next section regarding malfunctions. 

15 
4.0 MALFUNCTIONS 

The purpose of this section ofthe Startup, Shutdown and Malfunction Plan is to: 

• Define potential malfunctions and their causes 

• Describe measures to minimize me frequency and severity 

• Prescribe procedures for operating and maintaining the incinerator during 

malrunctions 

• Prescribe actions to correct the cause of a malfunction 

A summary of potential malfunctions and their causes is given in Table 4-1. This hst of 

potential malfunctions is arranged according to unit operations. The occurrence of any 

event hsted in Table 4-1 should be responded to as a malfunction and a malfunction 

recordkeeping form, included as Attachment 3-, should be initiated. During the response 

to these events, it will be determined if the event meets the regulatory definition of a 

malfunction. 

4.1 Measures to Minimize tbe Frequency of Malfunctions 

The following measures contribute to prevent malfunctions: 

• Incinerator system design consistent with safety and good engineering practices 

• Hazards and operability studies of the incinerators 

• Appropriate frequency of preventative maintenance and inspection 

• Good operating practices 

• Well trained and qualified personnel • 

Onyx's performance history, this document, and the foUowing regulatory documents 

serve as. evidence of Onyx's proactive measures to minimize the frequency of 

malfunctions. 

• Operation and Maintenance Plan 

• Operating Training and Certification Program 

• Continuous Emissions Monitoring System Quality Assurance Plan (CEMS QA 

Plan) . 

• Continuous Monitoring System Quality Control Plan (CM S Q C Plan) 

• Automatic Waste Feed Cutoff System Operability Test Procedures 

16 
Table 4-1 Summary of Potential Malfunctions and Causes 

Potential Malfunctions for Units 2,3, and 4. 

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GENERAL 

- Loss of Electrical Power Supply 

- Loss oflnstrument/Plant Air Supply 

- Loss of Plant Nitrogen Supply 

- Loss of City Water Supply 

- Loss of Process Water Pressure/Flow (Unit 4) 

- Malfunction of Safety Interlock or Automatic Waste Feed 

Cutoff Interlock 

- Excessive Air In-leakage in Air Pollution Control System 

PRIMARY COMBUSTION CHAMBER 

- Loss of Natural Gas Pressure/Flow to PCC Main Burner 

- Loss of Combustion Air Pressure/Flow to PCC 

- PCC Main Burner Pilot Failure 

- Loss of Waste Flow to PCC Injector 

- Loss of Waste Feedrate Control to PCC Injector ' 

- Loss of Atomization Air Pressure to a PCC Injector 

- Loss of PCC Draft Control (Unit 4) 

- Loss of PCC Temperature Control 

- Flame Failure 

- Kiln Rotation Malfunction (Unit 4) 

- Bulk/Charge Feed Door Malfunction 

- Physical/Mechanical Internal Equipment Failure 

- PCC Seal Visual Emissions Monitoring and Recording System 

- Rapid Steam Generation from Ash Collection System Water 

SECONDARY COMBUSTION CHAMBER 

- Loss of Natural Gas Pressure/Flow to SCC Main Burner 

-' Loss of Combustion Air Pressure/Flow to SCC 

- SCC Main Burner Ignition Failure 

- Loss of Waste Flow to SCC Injector 

- Loss of Waste Feedrate Control to SCC Injector 

- Loss of Atomization Air Pressure 'to a SCC Injector 

- Loss of SCC Temperature Control 

- Flame Failure . . 

- Emergency Safety Vent Opening 

- Physical/Mechanical Internal Equipment Failure 

- Low Water Level in Slag Collection System (Unit 4) 

- Rapid Steam Generation from Ash Collection System Water 

TEMPERING CHAMBER (UNIT 4) 

- Loss of Tempering Chamber Exit Gas Temperature Control 

- Loss of Atomization Air Pressure to Nozzle 

LIME SLURRY SYSTEM 

- Loss of Lime Feed to Lime Slurry Feed Tank 

- Malfunction in Lime Slurry Concentration 

UNITS 2 AND 3 SPRAY DRYER ABSORBER (SDA) 

- Loss of Lime Slurry Flow to SDA 

- Loss of Liirjfi Slurry Flow Control , 

- Loss of City Water Flow to SDA 

- Loss of Cooling Air Flow to Atomizer 

- Loss of SDA Exit Gas Temperature Control 

- Atomizer Failure 

UNITS 4 SPRAY DRYER ABSORBER (SDA) 

- Loss of Lime Slurry Flow to SDA 

- Loss of Lime Slurry Flow Control/Exit Gas Temperature 

Control 

- Loss of Atomization Air Pressure to SDA Nozzle 

CARBON INJECTION SYSTEM (UNIT 4) 

- Loss of Carrier Gas Pressure 

- Loss/Restriction of Activated Carbon Flow 

- Loss of Plant Air Pressure/Flow to Carbon Bulk Sack 

BAGHOUSE & INDUCED DRAFT (DD) FAN 

- Tom/Leaking Bag 

- Bag Blmding/High-High Pressure Drop 

- Loss of Stack.Gas Flowrate Control (Unit 2 and 3) 

- Baghouse Isolation Damper Malfunction (Unit 4) 

- ID Fan Failure .' . . . 

CONTROL SYSTEM/CONTINUOUS MONITORING 

SYSTEM 

•-. Control System/Continuous Monitoring System Malfunction 

- ' Continuous Emissions Monitoring System Malfunction 

.17 

Potential Causes for a 

Malfunction 

Mechanical/electrical 

failure of rotating 

equipment. 

Plugging/physical failure of | 

lines/nozzles 

Physical/electrical failure 

of mstrumentation 

MechanicaVelectrical 

failure of actuated 

valves/dampers 

Physical/electrical failure 

of control system 

Mechanical/electrical 

failure of utility supplies 

Electrical/actuation failure 

of safety interlocks 

Physical/mechanical 

internal equipment failure 
Despite these efforts, equipment failures and other operating anomalies can occur. 

Within fhe scope of regulatory requirements, the operating record mil contain the 

appropriate documentation to establish that poor maintenance or careless operations are 

not contributing factors to the cause of a malfunction. 

4.2 Measures to Minimize the Severity of Malfunctions 

The following measures contribute to mirihnize the severity of malfunctions: 

• Alarms and interlocks 

• AWFCO testing 

• Failure positions for critical equipment 

• Well trained and quahfied personnel 

• Design of me incinerator system 

Typically, an event that meets the definition of a malfunction will trigger an alarm. An 

alarm informs the operator of the situation and may provide an opportunity to avoid an 

exceedance. If conditions become unsafe or exceed operating limits, interlocks are in 

place for an automated response that is specific to the triggering condition. Refer to 

Onyx's Documentation of Compliance OT Notification pf Compliance, whichever is 

currently apphcable, for details on AWFCO conditions. Additional details on alarms and 

interlocks are maintained on piping and instrumentation diagrams (P&EDs) 

The most critical key to mininiizing the severity of malfunctions is the fimctionality of 

AWFCO interlocks. Accordingly, Onyx performs testing of the AWFCO system, as 

described in the AWFCO Plan. This testing confirms a state of readiness to respond to a 

malfunction in a manner that will minimize the release of hazardous air pollutants. 

Through training and job experience, the operator will have the process knowledge that 

qualifies him to use discretion in responding to malfunctions. Due to the unusual and 

dynamic conditions that are present during a'malfunction, operator discretion is essential 

to minimizing the severity of malfunctions." An operator can evaluate process conditions 

and. alarms and choose the best response to avoid an exceedance, if possible.; If the 

malfunction adversely affects the functionahty of alarms, interlocks, or fail safe positions, 

the operator must recognize the situation and respond appropriately. In the event that the 

malfunction affects the ability to automatically cutoff waste, the operator will manually 

cutoff waste feeds as quickly as possible. 

18 
The design of the each incinerator system also ensures that the severity of malfunctions 

will be minimized. This includes alarms and interlocks, the fail safe position of actuated 

valves, and redundant instrumentation and process equipment. Also, the design of each 

incinerator's instrumentation and control systems provides the operator convenient access 

to process variable indication, including position indication of selected actuated valves. 

This is essential to providing the operator the hiformation required to best evaluate 

system conditions and responses. Table 4-2 lists potential malfunctions and associated 

redundant equipment and systems that are available to prevent these malfunctions or to 

minimize the potential for a significant release of hazardous air pollutants. 

4.3 Corrective Measures 

The.Program of Corrective Actions for Malfunctions is Attachment 4 of this document 

This program addresses how .the incinerator will be operated and maintained during 

malfunctions. In this program, potential malfunctions are listed for each portion of fhe 

incinerator system. The malfunctions are events that will be recognized by the operator, 

or indicated by an alarm, and threaten to cause an exceedance. In fhe response to the 

malfunction and/or alarms, the operator will apply discretion and attempt to maintain the 

incinerator system within regulatory limits. In the program of corrective actions, 

potential causes of each malfunction are listed. The operator will utilize process 

knowledge, job experience, and, if needed, assistance from other personnel to identify the 

cause of the malfunction. For each potential cause, actions to correct the failure are 

hsted. The corrective actions prescribed may require the collaboration of multidisciplined personnel who are qualified to return the incinerator system to proper working 

conditions (i.e., maintenance personnel, control system technicians, engmeering). 

19 

V E S 002010 
Table 4-2 

Redundant Equipment and Systems for 

Minimizing the Frequency or Severity of Malfunctions 

Redundant Equipment/Systems Potential Malfunctions Prevented/Minimized 

Emergency generator (Unit 4) Loss of Electrical Power Supply 

Universal Power Supply (UPS) system powers 

computers, monitors, and control systems 

Loss of Electrical Power Supply 

Two compressors are on hot standby (Unit 4) 

Three ah compressors running and one compressor 

on hot standby (Unit 2 and 3). 

Loss of mstrument/Plant A h Supply 

Dual Process Water Pumps Loss of Process Water Pressure/Flow 

Dedicated PCC combustion ah fan (Unit 4) Loss of Combustion A h Pressure/Flow to PCC 

Dedicated SCC combustion air fan (Unit 4) 

Spare SCC combustion air fan (Unit 4) Loss of Combustion A h Pressure/Flow to SCC 

Multiple Tempering Chamber Nozzles 

Loss of Tempering Chamber Exit Gas Temperature 

Control 

Loss of Atomization Air Pressure to Nozzle 

Dual Slurry Feed Pumps (Unit 4) 

• Shared Back-up Pump (Unit 2 and 3) Loss of Slurry Feed to SDA 

Off-line Spare Lime Slurry Atomizer (Unit 2 & 3) Atomizer Failure 

-DualSDAs(Unit4) 

Loss of Lime Slurry Flow fo SDA 

Loss of Lime Slurry Flow Control/Exit Gas 

Temperature Control 

Loss of Atomization A h Pressure to SDA Nozzle 

Off-line Spare Baghouse Module (Unit 2) TorriVLealdhg Bag 

Two baghouse modules with three compartments 

each. 5 compartments provide sufficient particulate 

removal so that one of the 6 compartments can be 

isolated as a spare. (Unit 4) 

Tom/Leaking Bag 

20 

V ES 002011 
ATTACHMENT 1 

STARTUP RECORDKEEPING FORM 

V E S 002012 
ONYX ENVIRONMENTAL SERVICES, INC. 

INCINERATOR STARTUP RECORD 

(Page 1 of 3) 

This report pertains to a startup of Unit 2/3/4 . (circle one). 

Startup event initiated on: . 

(Month/Day/Year, Hours: Minutes) 

Startup event concluded on: 

(Month/Day/Year, Hours: Minutes) 

The total duration of this startup event was: 

(Hours: Minutes) 

Attached to this form is a checklist that summarizes the approved startup procedures referenced in Onyx's 

Startup, Shutdown, and Malfunction Plan (SSMP). The operational steps that have been checked document that 

the detailed startup procedures were followed. 

Were all actions associated with this startup event in conformance with the SSMP? Yes / No (circle one). If 

no, describe the inconsistent actions below. 

Were there any exceedances of an operating parameter lirnit? Yes / No (circle one). If yes, please list/describe. 

If any actions were not consistent with the SSMP and an operating parameter lirnit was exceeded, an immediate 

SSM report is required. 

Notes/Recommendations: 

The following signature certifies the accuracy of this record: 

(Name) (Tide) 

(Signature) (Date) 

V E S 002013 
ONYX ENVIRONMENTAL SERVICES, INC. 

INCINERATOR STARTUP RECORD 

(Page 2 of 3) 

Unit 2 and 3 Incinerator Startup Checklist Initials 

Verify that pre-startup has been completed 

Check thermal relief vent (TRV) 

Start combustiori air fan -

Start PCC main burner and temperature ramp-up 

Start SCC main burner and temperature ramp-up 

Check stack gas flow and SDA temperatures control settings 

Start D) fan; Monitor SDA temperature while ramping up stack gas flowrate 

Close TRV 

Start lime slurry 

Establish all operating parameters within limits 

Operator's Notes: 

Note: . Certain air pollution control and ancillary equipment may be operational prior to startup 

(Signature of Shift Leader or Designee) (Date) 

V E S 002014 
ONYX ENVIRONMENT A L SERVICES, INC. 

INCINERATOR STARTUP RECORD 

(Page 3 of 3) 

Unit 4 Incinerator Startup Checklist Initials 

Verify that pre-startup has been completed 

Check thermal relief vent (TRV) 

Start FD fan and set kiln draft'(start of purge cycle) 

Start SCC combustion air fan 

. Start the kiln combustion air fan (purge cycle complete) 

Start SCC main burner and temperature ramp-up 

Start PCC main burner and temperature ramp-up 

Start kiln rotation before 500 °F 

Start me kiln seal air 

Start the SCC conveyor 

Set up the tempering chamber for operation 

Set up lime slurry injection system 

Set up the SDAs for operation 

Set up the ash collection system 

Set up the baghouses for operation 

Slowly ramp-up the tempering chamber exit temperature 

> Continue PCC and SCC temperature ramp-up, 

Set up the air cannon 

Start the kiln seal conveyor 

Establish all operating parameters within limits 

Operator's Notes: 

Note: Certain air pollution control and ancillary equipment may be operational prior to startup. 

(Signature of Shift Leader or Designee) (Date) 
ATTACHMENT 2 

SHUTDOWN RECORDKEEPING FORM 

j 

V E S 002016 
ONYX ENVIRONMENTAL SERVICES, INC. 

INCINERATOR SHUTDOWN RECORD 

(Page 1 of 3) 

This report pertains to a shutdown of Unit 2/3/ 4 (circle one). 

Shutdown event initiated on: 

(Montb/Day/Year, Hours: Minutes) 

Shutdown event concluded on: 

(Month/Day/Year, Hours: Minutes) 

The total duration of this shutdown event was: 

(Hours: Minutes) 

Attached to this form is' a checklist that summarizes the approved shutdown procedures referenced in the Onyx 

Startup, Shutdown, and Malfunction Plan (SSMP). The operational steps that have been checked document that 

the detailed shutdown procedures were followed. 

Were all actions associated with this shutdpwn event in conformance with the SSMP? Yes / No (circle one). If 

no, describe the inconsistent actions below. 

Were there any exceedances of an operating parameter limit? Yes / No (circle one). If yes,, please list/describe. 

If any actions were' not consistent with the SSMP and an operating parameter limit was exceeded, an immediate 

SSM report is required. 

Notes/Recommendations: 

The foUowing signature certifies the accuracy pf this record: 

(Name) (Title) 

(Signature) (Date) 

V E S 002017 
ONYX ENVIRONMENTAJL SERVICES, INC. 

INCINERATOR SHUTDOWN RECORD 

(Page 2 of 3) 

Unit 2 and 3 Incinerator Shutdown Checklist Initials 

Verify that all waste feeds are off and/or that the hazardous waste residence 

time has transpired 

Monitor CEMS outout to verify stable conditions 

Open the stack cap 

Stop the ID fan 

. Shut off water and lime slurry flow to the atomizer 

' Remove atomizer and position lid 

Operator's Notes: 

Note: All or certain air pollution control and ancillary equipment may remain operational throughout 

shutdown. Once the hazardous waste residence time has transpired, operator's discretion can be 

applied. 

(Signature of Shift Leader or Designee) (Date) 
ONY X ENVIRONMENTAL SERVICES, INC. 

INCINERATOR SHUTDOWN RECORD 

(Page 3 of 3) 

Unit 4 Incinerator Shutdown Checklist Initials 

Verify that all waste feeds are off and/or mat the hazardous waste 

residence time has transpired 

• Vent the air cannons 

Shut off the kiln burner and SCC burner 

Shut off fhe kiln and SCC combustion air fans 

Reduce the tempering chamber outlet temperature to 500 °F 

Shutdown SDA (at appropriate temperatures) 

Shutdown tempering chamber (at appropriate temperatures) 

After PCC and SCC reach the appropriate temperature, shut off the ID fan 

Operator's Notes: 

Note: All or certain air pollution control and ancillary equipment may remain operational throughout 

shutdown. • Once fhe liazardous waste residence time has transpired, operator's discretion cart be 

applied. 

(Signature of Shift Leader or Designee) (Date) 
ATTACHMENT 3 

MALFUNCTION RECORDKEEPING FORM 
ONYX ENVIRONMENTAL SERVICES, INC. 

MALFUNCTION RECORD 

(Page 1 of 1) 

Trus report pertams to a malfunction of Unit 2/3/ 4 (circle one). 

The malfunction event occurred on: (Monlh/Day/Year, Hours: Minutes) . 

The malfunction event concluded on: 

(Month/Day/Year, Hours: Minutes) 

The total duration of this malfunction event was: 

(Hours: Minutes) 

The Onyx Program of Corrective Actions for Malfunctions must be adhered to for the operating and mamtaining 

of the incinerator system and for correcting the cause of the malfunction. Describe the malfunction, the 

automated and/or operator response, the potential cause ofthe malfunction, and the corrective actions taken: 

Waste Feeds off Time — 

Incinerator "Clear of Waste" Time -

Were all actions associated with this malfunction event in conformance with the SSMP? Yes / No (circle.one). 

If no, initiate an irnmediate startup, shutdown, and malfunction report 

List/describe the exceedances that occurred (or believed to have occurred) due to mis malfunction: 

Notes/Recommendations: 

' The following signature certifies the accuracy of this record: 

(Name)

 : (Title) 

(Signature) (Date) 
ATTACHMENT 4 

PROGRAM OF CORRECTIVE 

ACTIONS FOR MALFUNCTIONS 
PROGRAM OF CORRECTIVE 

ACTIONS FOR MALFUNCTIONS 

TABLE OF CONTENTS 

1.0 . GENERAL .. 

1.1 Operating and Maintaining the System during Malfunctions 

1.2 Loss of Electrical Power Suriply 

1.3 Loss of Instrument/Plant Air Supply 

1.4 Loss of Plant Nitrogen Supply 

1.5 Loss of City Water Supply 

1.6 Loss of Process Water Pressure/Flow (Unit 4) 

1.7 Malfunction of Safety Interlock or Automatic Waste Feed Cutoff Interlock 

1.8 Excessive Air In-leakage in Air Pollution Control System 

2.0 PRIMARY COMBUSTION CHAMBER 

2.1 Loss of Natural Gas Pressure/Flow to PCC Main Burner 

2.2 Loss of Combustion Air Pressure/Flow to PCC 

2.3 PCC Main Burner Pilot Failure 

2.4 Loss of Waste Flow to PCC Injector 

2.5 Loss of Waste Feedrate Control to PCC Injector. 

2.6 Loss of Atomization Air Pressure to a PCC Injector 

2.7 Loss of PCC Draft Control (Unit 4) 

2.8 Loss of PCC Temperature Control 

2.9 Flame Failure 

2.10 Kim Rotation Malfunction (Unit 4) 

2.11 Bulk/Charge Feed Door Malfunction 

2.12 Physical/Mechanical Internal Equipment Failure 

2.13 PCC Seal Visual Emissions Monitoring and Recording System 

2.14 Rapid Steam Generation from Ash Collection System Water 

3.0 SECONDARY COMBUSTION CHAMBER 

3.1 Loss of Natural Gas Pressure/Flow to SCC Main Burner 

'3.2 Loss of Combustion Air Pressure/Flow to SCC 

3.3 SCC Main Burner Ignition Failure 

3.4 Loss of Waste Flow to SCC Injector (Unit 4) 

3.5 Loss of Waste Feedrate Control to SCC Injector (Unit 4) 

3.6 Loss of Atomization Air Pressure to a SCC Injector 

3.7 Loss of SCC Temperature Control 

3.8 Flame Failure 

3.9 Physical/Mechanical Internal Equipment Failure 

3.10 Low Water Level in Slag Collection System (Unit 4) 

3.11 Emergency Safety Vent Opening 

3.12 Rapid Steam Generation from Ash Collection System Water 

4.0 TEMPERING CHAMBER (UNIT 4) 

4.1 Loss of Tempering Chamber Exit Gas Temperature Control 

4.2 Loss of Atomization Air Pressure to Nozzle 

5.0 . LIME SLURRY SYSTEM 

5.1. Loss of Lime Feed to Lime Slurry Feed Tank 

5.2. Malfunction in Lime Slurry Concentration 

6.0- UNITS 2 AND 3 SPRAY DRYER ABSORBER.(SDA) 

6.1. Loss of Lime Slurry Flow to SDA 

V E S 002023 
6.2. Loss of Lime Slurry Flow Control 

6.3. Loss of City Water Flow to SDA (Unit 2 and 3) 

6.4. Loss of Cooling Air Flow to Atomizer 

6.5. Loss of SDA Exit Gas Temperature Control 

6.6. Atomizer Failure 

7.0 UNIT 4 SPRAY DRYER ABSORBER (SDA) 

7.1. Loss of Lime Slurry Flow to SDA 

7.2. Loss of Lime Slurry Flow Control/Exit Gas Temperature Control 

7.3. Loss of Atomization Air Pressure to SDA Nozzle 

8.0 CARBON INJECTION SYSTEM (UNIT 4) 

8.1. Loss of Carrier Gas Pressure 

8.2. Loss/Restriction of-Activated Carbon Flow 

8.3.. Loss of Plant Air Pressure/Flow to Carbon Bulk Sack 

9.0 BAGHOUSE & INDUCED DRAFT (ID) FAN 

9.1. Torn/Leaking Bag 

9.2. Bag Blinding/High-Higb. Pressure Drop 

9.3. Loss of Stack Gas Flowrate Control (Unit 2 and 3) 

9.4. Baghouse Isolation Damper Malfunction (Unit 4) 

9.5. ID Fan Failure 

10.0 CONTROL SYSTEM/CONTINUOUS MONITORING SYSTEM 

10.1. Control SystenyCtontinuous Monitoring System Malfunction 

10.2. Continuous Emissions Monitoring System Malfunction 

V E S 002024 
ONY X ENVIRONMENTAL SERVICES, INC. 

PROGRA M OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

GENERAL 

1.1. Operating and Maintaining the System during Malfunctions 

1.1.1. Due to the sudden, infrequent, and unusual conditions associated 

with malfunctions, continually evaluate the situation; Using 

discretion, respond in a manner consistent with safety and good air 

pollution control practices. 

1.1.2. Take the following actions to minimize the release of hazardous air 

pollutants 

1.1.2.1. Cutoff all waste feeds and/or confirm that the automatic 

waste feed cutoff system functioned properly. 

1.1.2.2. Maintain operating parameters within limits, if possible. 

1.1.2.3. If applicable, follow the procedures provided by the 

Emergency Safety Vent Plan. 

1.1.3. Keep supervisor and/or maintenance supervisor informed, as 

appropriate. 

1.1.4. Identify the malfunction and potential cause. 

1.1.5. Implement corrective actions involving the troubleshooting of 

failures and the servicing and/or replacing of components, as 

needed. Refer to manufacture's troubleshooting and service 

recommendations, as needed. 

1.1.6. Record the appropriate information using a malfunction record 

form. 

1.2. Loss of Electrical Power Supply 

1.2.1. Verify proper failure position of actuated valves. 

1.2.2. Identify link in power supply path that is not operational. 

1.2.3. Take the necessary actions to restore the supply of electrical 

power. 

1.3. Loss of Instrument/Plant Air Supply 

1.3.1. Verify proper failure position pf actuated valves. 

1.3.2. In case of plugging/physical failure of line or line components: 

1.3.2.1. Identify the location/cause of the restriction of 

instrument ah flow. 

1.3.2.2. Clear line plugging and/or service/replace faulty line 

components, as needed. 

Page 1 of26 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRA M OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

1.3.3. In case of mechanical/electrical failure of actuated valve: 

1.3.3.1. Identify cause of actuation failure. 

1.3.3.2. Service/replace electrical and/or pneumatic 

components, as needed. 

1.3.3.3. Service/replace actuator and/or valve components, as . 

needed. 

1.3.4. In case of mechanical/electrical failure at air supply source: 

1.3.4.1. Identify the cause of the failure. 

1.3.4.2. Take the necessary actions to restore the supply of 

instrument/plant air. 

1.4. Loss of Plant Nitrogen Supply 

1.4.1. In case of plugging/physical failure of line or line components: 

1.4.1.1. Identify the location/cause of the restriction of nitrogen 

flow. 

1.4.1.2. Clear line plugging and/or service/replace faulty line 

components, as needed. 

1.4.2. In case of mechamcaVelectrical failure of actuated valve: 

1.4.2.1. Identify cause of actuation failure. 

1.4.2.2. Service/replace electrical and/or pneumatic 

components', as needed. 

1.4.2.3. Service/replace actuator and/or valve components, as 

needed. 

1.4.3. In case of mechanical/electrical failure at nitrogen supply source: 

1.4.3.1: Identify the cause of the failure. 

1.4.3.2. Take the necessary actions to restore the supply of 

nitrogen. 

1.5. Loss of City Water Supply 

1.5.1. In case of plugging/physical failure of line or line components: 

1.5.1.1. Identify the location of plugging or line failure. 

1.5.1.2. Clear line plugging and/or service/replace faulty line 

components, as needed. 

1.5.2. In case of mechanical/electrical failure of actuated valve: 

1.5.2.1. Identify cause of actuation failure. 

1.5.2.2. . Service/replace electrical and/or pneumatic 

components, as needed. 

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ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRAM OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

1.5.2.3. Service/replace actuator and/or valve components, as 

needed. 

1.5.3. In case of mechanical/electrical failure at city water supply source: 

1.5.3.1. Identify the cause ofthe failure. 

1.5.3.2. Take the necessary actions to restore the supply of city 

water. 

1.6. Loss of Process Water Pressure/Flow (Unit 4) 

1.6.1. For loss ofcity water supply to process water tank, see 1.5. 

1.6.2. In case of mechanical/electrical failure of process water pump: 

1.6.2.1. Diagnose pump/drive failure. 

1.6.2.2. Service/replace the pump/drive, as needed. 

1.6.2.3. Restore electrical power supply to fhe pump. 

1.6.3. In case of plugging/physical failure of line or line components: 

1.6.3.1. Identify the location of plugging or line failure. 

1.6.3.2. Clear line plugging and/or service/replace faulty line 

components, as needed. 

1.6.4. In case of mechanical/electrical failure of actuated valve: 

1.6.4.1. Identify cause of actuation failure. 

1.6.4.2. Service/replace electrical and/or pneumatic 

components, as needed. 

1.6.4.3. Service/replace actuator and/or valve components, as 

needed. 

1.6.5. In case of physical/electrical failure of control system component: 

1.6.5.1. Identify faulty control system component. 

1.6.5.2. Service/replace control system components, as needed. 

1.7. Malfunction of Safety Interlock or Automatic Waste Feed Cutoff 

Interlock 

1.7.1. If safety interlock or AWFCO interlock was erroneously triggered, 

proceed with corrective actions. 

1.7.2. If safety or AWFCO condition exists but automated response 

failed, cutoff waste feed as quickly as possible, then proceed with 

corrective actions. 

1.7.3. In case of physical/electrical failure of instrumentation: 

1.7.3.1. Identify faulty instrumentation component. 

1.7.3.2. Service/replace faulty instrumentation components, as 

needed. 

Page 3 of 26 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRAM OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

1.7.4. In case of mechanical/electrical failure of actuated valve/damper: 

1.7.4.1. Identify cause of actuation failure. 

1.7.4.2. Service/replace electrical and/or pneumatic 

components, as needed. 

1.7.4.3. Service/replace actuator and/or valve components, as 

needed. 

1.7.5. In case of physical/electrical failure of control system component: 

1.7.5.1. Identify faulty control system component 

1.7.5.2 Service/replace control system components, as needed. 

1.8. Excessive Air In-leakage in Air Pollution Control System 

1.8.1 In case of holes due to corrosion: 

1.8.1.1. Identify location of hole. 

1.8.1.2. Repair system as.needed. 

1.8.2 In case of open ports, manways, access ports, etc. 

1.8.2.1. Identify location of open port, manway, etc. 

1.8.2.2. Replace cover on open port, manway, etc. 

Page 4 of 26 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRAM OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

PRIMARY COMBUSTION CHAMBER 

2.1. Loss of Natural Gas Pressure/Flow to PCC Main Burner 

2.1.1. In case of plugging/physical failure of line or line component: 

2.1.1.1. Identify the location of plugging or line failure. 

2.1.1.2. Clear line plugging and/or service/replace faulty line 

components, as needed. 

2.1.2. In case of mechamcal/electrical failure of actuated valve: 

2.1.2.1. Identify cause of actuation failure. 

2.1.2.2. Service/replace electrical and/or pneumatic 

components, as needed. 

2.1.2.3. Service/replace actuator and/or valve components, as 

needed. 

2.1.3. In case of physical/electrical failure of control system component: 

2.1.3. L Identify faulty control system component 

2.1.3.2. Service/replace control system components, as needed. 

2.1.4. In case of mechahical/electrical failure at natural gas supply 

source: 

2.1.4.1. " Identify the cause of the failure. 

2.1.4.2. Take the necessary actions to restore the supply of 

natural gas. 

2.2. Loss of Combustion Air Pressure/Flow to PCC 

2.2.1. In case of mechanical/electrical failure of combustion air blower: 

2.2.1.1. Diagnose blower/drive failure. 

2.2.1.2. Service/replace the blower/drive, as needed. 

2.2.1.3. Restore electrical power supply to the blower. 

2.2.2. In case of physical failure of combustion ah duct: 

2.2.2.1. Identify the location of duct failure. 

2.2.2.2. Service/replace faulty duct, as needed. 

2.2.3. In case of mechanical/electrical failure of actuated valve: 

2.2.3.1. ' Identify cause of actuation failure. 

:

 2.2.3.2. Service/replace electrical and/or pneumatic 

components,, as needed. . 

2.2.3.3. Service/replace actuator and/or valve components, as 

needed. 

Page 5 of 26 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRAM OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

2.2.4. In case of physical/electrical failure of control system component: 

2.2.4.1. Identify faulty control system component. 

2.2.4.2. Service/replace control system components, as needed. 

2.3. PCC Main Burner Pilot Failure 

2.3.1. For loss of natural gas pressure/flow, see 2.1. 

2.3.2. For loss of combustion air pressure/flow, see 2.2. 

2.3.3. In case of physical/electrical failure of igniter: 

2.3.3.1. Identify cause of igniter failure. 

2.3.3.2. Service/replace igniter and/or associated components, 

as needed. 

2.3.4. In case of physical/electrical failure of control system component: 

2.3.4.1. Identify faulty control systerh component. 

2.3.4.2. Service/replace control system components, as needed. 

2.4. Loss of Waste Flow to PCC Injector 

2.4; 1. In case of mechanical/electrical failure of waste feed pump: 

2.4.1.1. Diagnose pump/drive failure. 

2.4.1.2. Service/replace the pump/drive, as needed. 

2.4.1.3. Restore electrical power supply to the pump. 

2.4.2. In case of low nitrogen pressure, see 1.4. 

2.4.3. In case of plugging/physical failure of line or line component: 

2.4.3.1. Identify the location of plugging or line failure. 

2.4.3.2. Clear line plugging and/or service/replace faulty line 

components, as needed. 

2.4.3.3. Restoreyconfirm functional heat tracing, if applicable. 

2.4.4. In case of mechanical/electrical failure of actuated valve: 

2:4.4,1. Identify cause of actuation failure. 

2.4.4.2. Service/replace electrical and/or pneumatic 

components, as needed. 

2.4.4.3. Service/replace actuator and/or valve components, as 

needed. 

2.4.5. In case of physical/electrical failure of control system component: 

2.4.5.1. Identify faulty control system component. 

2.4.5.2. Service/replace control system components, as needed. 

2.5. Loss of Waste Feedrate Control to PCC Injector 

2.5.1. Incase of lossiof waste pressure/flow to PCC injector, see 2.4. 

Page 6 of 26 
ONY X ENVIRONMENTAL SERVICES, INC. 

PROGRAM OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

2.5.2. In case of physical/electrical failure of flow transmitter: 

Service/replace flow transmitter and/or associated mstrumentation, 

as needed. 

2.5.3. In case of actuated valve failure: 

2.5.3.1. Identify cause of actuation failure. 

2.5.3.2. Service/replace electrical and/or pneumatic 

components, as needed. 

2.5.3.3. Service/replace actuator and/or valve components, as 

needed. 

2.5.4. In case of physical/electrical failure of control system component: 

2.5.4.1. Identify faulty control system component. 

2.5.4.2. Service/replace control system components, as needed. 

2.6. Loss of Atomization Air Pressure to a PCC Injector 

2.6.1. For a total loss of plant/instrument air supply, see 1.3 . 

2.6.2. In case of plugging/physical failure of line or line component: 

2.6.2.1. Identify the location of plugging or line failure. 

2.6.2.2. Clear line, plugging and/or service/replace faulty line 

components, as needed. 

2.6.3. In case of mechanical/physical failure of pressure control valve: 

Service/replace pressure control valve, as needed. 

2.7. Loss of PCC Draft Control (Unit 4) 

2.7.1. Incase of ID fan failure, see 9.5 

2.7.2. In case of physical/electrical failure of kiln pressure transmitter: 

Service/replace pressure transmitter and/or associated 

mstrumentation, as needed. 

2.7.3. mease of actuated damper failure: 

2.7.3.1. Identify cause of actuation failure. 

2.7.3.2. Service/replace electrical and/or pneumatic 

components, as needed. 

2.7.3.3. Service/replace actuator and/or damper coinponents, as 

needed. 

2.7.4. In case of physical/electrical failure of control system component: 

2.7.4.1. Identify faulty control system component. 

2.7.4.2. Service/replace control system components, as needed. 

Page 7 of 26 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRA M OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

2.8. Loss of PCC Temperature Control 

2.8.1. In case of loss of natural gas pressure/flow to main burner, see 2.1. 

2.8.2. In case of loss of waste pressure/flow to PCC injector, see 2.4. 

2.8.3. In case of physical/electrical failure of temperature element: 

2.8.3.1. Service/replace faulty temperature element and/or 

associated instrumentation, as needed. 

2.8.4. In case of physical/electrical failure of control system component: 

2.8.4.1. Identify faulty control system component. 

2.8.4.2. Service/replace control system components, as needed, 

2.9. Flame Failure 

2.9.1. In case of physical/electrical failure of flame detector: 

2.9.1.1. Identify faulty flame detector component. 

2.9.1.2. Service/replace flame detector components, as needed. 

2.9.2. In case of physical/electrical failure of control system component: 

2.9.2.1. Identify faulty control system component. 

2.9.2.2. Service/replace control system components, as needed. 

2.10. Kiln Rotation Malfunction (Unit 4) 

2 A 0.1. In case of mechanical/electrical kiln drive system: 

2.10.1.1. Diagnose drive failure. 

2.10.1.2. Service/replace the drive, as needed. 

2.10.1.3. Restore electrical power supply to motor. 

2.10.2. In case of physical/electrical failure of kiln rotational speed 

transmitter: Service/replace transmitter and/or associated 

instrumentation, as needed. 

2.10.3. In case of physical/electrical failure of control system component: 

2.10.3.1. Identify faulty control system component. 

2.10.3.2. Service/replace control system components, as needed. 

2.11. Bulk/Charge Feed Door Malfunction 

2.11.1. In case of mechanical/electrical failure of actuated door: 

2.11.1.1. Identify cause of actuation failure. 

2.11.1.2. Service/replace electrical, hydraulic, and/or pneumatic 

components, as needed. 

2.11.13. Service/replace actuator and/or valve components, as 

needed. 

2.11.2. In case of physical/electrical failure of control system component: 

Page 8 of26 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRA M OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

2.11.2.1. Identify faulty control system component. 

2.11.2.2. Service/replace control system components, as needed. 

2.12. Physical/Mechanical Internal Equipment Failure 

2.12.1. In case of refractory failure, repair/replace refractory 

2.12.2. In case of ash collection failure 

2.12.2.1. Diagnose ash collection system failure 

2.12.2.2. Service/replace ash collection system components, as 

needed. 

2il3. PCC Seal Visual Emissions Monitoring and Recording System 

2.13.1. In case of physical/electrical failure of camera, service/replace 

camera. 

2.13.2. In case of physical/electrical failure of monitor, service/replace 

monitor. 

2.13.3. In case of physical/electrical failure of recording system, 

service/replace recording system. 

2.14. Rapid Steam Generation from Ash Collection System Water 

2.14.1. In case of refractory failure, repair/replace refractory. 

2.14.2. In case of uncontrolled movement/dropping of residue into ash 

collection system water, inspect system to identify/remove other 

suspect material. 

Page 9 of 26 
ONY X ENVIRONMENTAL SERVICES, INC. 

PROGRA M OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

SECONDARY COMBUSTION CHAMBER 

3.1. Loss of Natural Gas Pressure/Flow to SCC Main Burner 

3.1.1. In case of plugging/physical failure of line or line component: 

3.1.1.1. Identify the location of plugging or line faiiure. 

3.1.1.2. Clear line plugging and/or service/replace faulty line 

components, as needed. 

3.1.2. In case of mechanical/electrical failure of actuated valve: 

3.1.2.1. Identify cause of actuation failure. 

3.1.2.2. Service/replace electrical and/or pneumatic 

components, as needed. 

3.1.2.3. Service/replace actuator and/or valve components, as 

needed. 

3.1.3. In case of physical/electrical failure of control system component: 

.3.1.3.1. Identify faulty control system component. 

3.1.3.2. Service/replace control system components, as needed. 

3.1.4. In . case of mechanical/electrical failure at natural gas supply 

source: 

3.1.4.1. Identify the cause of the failure. 

3.1.4.2. Take the necessary actions to restore the supply of 

natural gas. 

3.2. Loss of Combustion Air Pressure/Flow to SCC 

3.2.1. In case of mechanical/electrical failure of combustion ah blower. 

3.2.1.1. Diagnose blower/drive failure. 

3.2.1.2. Service/replace the blower/drive, as needed. 

3.2.1.3. Restore electrical power supply to the blower. 

3.2.2. In case of physical failure combustion ah duct: 

3.2.2.1. Identify the location of duct failure. 

3.2.2.2. Service/replace faulty duct, as needed. 

3.2.3. In case of mechanical/electrical failure of actuated valve: 

3.2.3.1. Identify cause of actuation failure. 

3.2.3.2. Service/replace electrical and/or pneumatic 

components, as needed. 

3.2.3.3. Service/replace actuator and/or valve components, as 

needed. 

Page 10 of 26 
ONY X EFTvTRONMENTAL SERVICES, INC. 

PROGRAM OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

3.2.4. In case of physical/electrical failure of control system component: 

3.2.4.1. Identify faulty control system component. 

3.2.4.2. Service/replace control system components, as needed. 

3.3. SCC Main Burner Ignition Failure 

3.3.1. For loss of natural gas pressure/flow, see 3.1. 

3.3.2. For loss of combustion air pressure/flow, see 3.2. 

3.3.3. In case of physical/electrical failure of igniter: 

3.3.3.1. Identify cause of igniter failure. 

3.3.3.2. Service/replace igniter and/or associated components, 

as needed. 

3.3.4. In case of physical/electrical failure of control system component: 

3.3.4.1. Identify faulty control system component. 

3.3.4.2. Service/replace control system components, as needed. 

3.4. Loss of Waste Flow to SCC Injector (Unit 4) 

3.4.1. In case of mechanical/electrical failure of waste feed pump: 

3.4.1-1. Diagnose pump/drive failure. 

3.4.1.2. Service/replace tbe pump/drive, as needed. 

3.4.1.3. Restore electrical power supply to me pump. 

3.4.2. In case of low nitrogen pressure, see 1.4. 

3.4.3. In case of plugging/physical failure of line or fine component: 

3.4.3.1. Identify tbe location of plugging or line failure. 

3.4.3.2. Clear line plugging and/or service/replace faulty line 

components, as needed. 

3.4.3.3. Restore/confirm functional heat tracing, if applicable. 

3.4.4. In case of mechanical/electrical failure of actuated valve: 

3.4.4.1. Identify cause of actuation failure. 

3.4.4.2. Service/replace electrical and/or pneumatic 

components, as needed. 

3.4.4.3. Service/replace actuator.and/or valve components, as 

needed. 

3.4.5. In case of physical/electrical failure of control system component: 

3.4.5.1. Identify faulty control system component. 

3.4.5.2. Service/replace control system components, as needed. 

3.5. Loss of Waste Feedrate Control to SCC Injector (Unit 4) 

3.5.1. In case of loss of waste pressure/flow to SCC injector, see 3.4. 

Page 11 of 26 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRAM OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

3.5.2. In case of physical/electrical failure of flow transmitter: 

Service/replace flow transmitter and/or associated instrumentation, 

as needed. 

3.5.3. In case of actuated valve failure: 

3.5,3.1. Identify cause of actuation failure. 

3.5:3.2. Service/replace electrical and/or pneumatic 

components, as needed. 

3.5.3.3. Service/replace actuator and/or valve components, as 

needed. 

3.5.4. . In case of physical/electrical failure of control system component: 

3.5.4.1. Identify faulty control system component. 

3.5.4.2. Service/replace control system components, as needed. 

3.6. Loss of Atomization Air Pressure to a SCC Injector 

3.6.1. For a total loss of plant/instrument air supply, see 1.3. 

3.6.2. In case of plugging/physical failure of line or line component: 

3.6.2.1. Identify me location of plugging or line failure. 

3.6.2.2. Clear line plugging and/or service/replace faulty line 

components, as needed. 

3.6.3. In case of mechanical/physical failure of pressure control valve: 

Service/replace pressure control valve, as needed. 

3.7. Loss of SCC Temperature Control 

3.7.1. m ease of loss of natural gas pressure/flow to main burner, see 3 .1. 

3.7.2. In case of loss of waste pressure/flow to SCC inj ector, see 3.4. 

3.7.3. In case of physical/electrical failure of temperature element: 

3.7.3.1. Service/replace faulty temperature element and/or 

associated instrumentation, as needed.. 

3.7.4. In case of physical/electrical failure of control system component: 

3.7.4.1. Identify faulty control system component. 

3.7.4.2. Service/replace control system components, as needed. 

3.8. Flame Failure 

3.8.1. In case of physical/electrical failure of flame detector: 

3.8.1.1. Identify faulty flame detector component 

3.8.1.2. Service/replace flame detector components, as needed. 

3.8.2. In case of physical/electrical failure of control system component: 

3.8.2.1. Identify faulty control system component. 

Page 12 of 26 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRAM OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

3.8.2.2. Service/replace control system components, as needed. 

3.9. Physical/Mechanical Internal Equipment Failure 

3.9.1. In case of refractory failure, repair/replace refractory. 

3.10. Low Water Level in Slag Collection System (Unit 4) 

3.10.1. For a loss of process water pressure/flow, see 1.6. 

3.10.2. In case of physical/mechanical failure of level controller: 

Service/replace faulty level controller and/or associated 

components, as needed. 

3.10.3. In case of physical/mechanical failure of actuated valve: 

3.10.3.1. Identify cause of actuation failure. 

3.10.3.2. Service/replace pneumatic components, as needed. 

3.10.3.3. Service/replace actuator and/or valve components, as 

needed. 

3.11. Emergency Safety Vent Opening 

3.11.1. Respond to an emergency safety vent opening in a manner 

consistent with the Emergency Safety Vent Plan. 

3.11.2. In case of mechanical failure of the actuator: 

3.11.2.1. Identify cause of actuation failure. 

3.11.2.2. Service/replace emergency safety vent components, as 

needed. 

3.12. Rapid Steam Generation from Ash Collection System Water 

2.14.1. In case of refractory failure, repair/replace refractory. 

2.14.2. In case of uncontrolled movement/dropping of residue into ash 

collection system water, inspect system to identify/remove other 

suspect material. 

Page 13 of 26 

V E S 002037 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRA M OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

TEMPERING CHAMBER (UNIT 4) 

4.1. Loss of Tempering Chamber Exit Gas Temperature Control 

4.1.1. For a loss of process water pressure/flow, see 1.6. 

4.1.2. In case • of physical/electrical failure of flow transmitter: 

Service/replace flow transmitter and/or associated instrumentation, 

as needed. 

4.1.3. In case of actuated valve failure: 

4.1.3.1. Identify cause of actuation failure. 

4.1.3.2. Service/replace electrical and/or pneumatic 

components, as needed. 

4.1.3.3. Service/replace actuator and/or valve components, as 

needed. 

4.1.4. In case of physical/electrical failure of control system component: 

4.1.4.1. Identify faulty control system component. 

4.1.4.2. Service/replace control system components, as needed. 

4.1.5. In case of nozzle failure, service/replace nozzle, as needed. 

4.2. Loss of Atomization Air Pressure to Nozzle 

4.2.1. For atotal loss of plant/instrument air supply, see 1.3. 

4.2.2. In case of plugging/physical failure of line or line component: 

.4.2.2.1: Identify the location of plugging or line failure. 

4.2.2.2. Clear line plugging and/or service/replace faulty line 

components, as needed. 

Page 14 of 26 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRA M OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

LIM E SLURRY SYSTEM 

5.1. Loss of Lime Feed to Lime Slurry Feed Tank 

5.1.1. In case of mechanical/electrical failure of lime slurry screw feeder: 

5.1.1.1. Diagnose feeder/drive failure. 

5.1.1.2. Service/replace the feeder/drive, as needed. 

5.1.1.3. Restore electrical power supply to me lime slurry sere 

feeder. 

5.1.2. In case of mechanical/electrical failure of lime bin 

activator/vibrator: 

5.1.2.1. Diagnose lime bin activator/vibrator failure. 

5.1.2.2. Service/replace the lime bin activator/vibrator, as 

needed. 

5.1.2.3. Restore electrical power supply to the lime slurry screw 

feeder. 

5.1.3. In case of plugging/physical failure of line or line component: 

5.1.3.1. Identify the location of plugging or line failure. 

5.1.3.2. Clear line plugging and/or service/replace faulty line 

components, as needed. 

5.1.4. In case of physical/electrical failure of lime feed controls: 

Service/replace faulty mstrumentation and/or control, system 

components, as needed. . 

5.2. Malfunction in Lime Slurry Concentration 

.5.2.1. In case oflossoflime feed to time slurry feed tank, see 5.1 

5.2.2. In case of loss of water flow to lime slurry feed tank, see 1.5 

5.2.3. In case of mechanical/electrical failure of lime slurry agitator: 

5.2.3.1. Diagnose agitator/drive failure. 

5.2.3.2. Service/replace the agitator/drive, as needed. 

5.2.3.3. Restore electrical power supply to the lime slurry 

agitator. 

5.2.4. In case of physical/electrical failure of instrumentation: 

Service/replace faulty instrumentation, as needed. 

5.2.5. In case of physical/electrical failure of control system component: 

5.2.5.1. Identify faulty control system component. 

5.2.5.2. Service/replace control system components, as needed. 

Page 15 of 26 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRA M OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

6.0 UNITS 2 AND 3 SPRAY DRYER ABSORBER (SDA) 

6.1. Loss of Lime Slurry Flow to SDA 

6.1.1. In case of mechanical/electrical failure of lime slurry feed pump: 

6.1.1.1. Diagnose pump/drive failure. 

6.1.1.2. Service/replace the pump/drive, as needed. 

6.1.1.3. Restore electrical power supply to the pump. 

6.1.2. In case of plugging/physical failure of line or line component: 

6.1.2.1. Identify the location of plugging or line failure: 

6.L2.2. Clear line plugging and/or service/replace faulty line 

components, as needed. 

6.1.2.3. Restore/confirm functional heat tracing, if applicable. 

6.1.3 . In case of mechanical/electrical failure of actuated valve: 

6.1.3.1. Identify cause of actuation failure. 

6.1.3.2. Service/replace electrical and/or pneumatic 

components, as needed. 

6.1.3.3. Service/replace actuator and/or valve components, as 

needed. ' 

6.1.4. In case of physical/electrical failure of control system component: 

6.1.4.1. Identify faulty control system component 

6.1.4.2. Service/replace control system components, as needed. 

6.2. Loss of Lime Slurry Flow Control 

6.2.1. In case of loss of slurry flow to SDA, see 6,1. 

6.2.2. In case of physical/electrical failure of flow transmitter: 

Service/replace flow transmitter and/pr associated instrumentation, 

as needed. 

6.2.3. In case of actuated valve failure: 

6.2.3.1. Identify cause of actuation failure. 

6.2.3.2. Service/replace electrical and/or pneumatic 

components, as needed. 

6.2.3.3. Service/replace actuator and/or valve components, as 

needed. 

6.2.4. In case of physical/electrical failure of control system component: 

6.2.4.1. Identify faulty control system component. 

6.2.4.2. Service/replace control system components; as needed. 

Page 16 of 26 

V E S 002040 
ONY X ENVIRONMENTAL SERVICES, INC. 

PROGRAM OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

6.3. Loss of City Water Flow to SDA (Unit 2 and 3) 

6.3.1. In case of total Loss of city water supply, see 1.5. 

6.3.2. In case of plugging/physical failure of line or line component: 

6.3.2.1. Identify me location of plugging or line failure. 

6.3.2.2. Clear line plugging and/or service/replace faulty line 

components, as needed. 

6.3.3. In case of mechanical/electrical failure of actuated valve: 

6.3.3.1. Identify cause of actuation failure. 

6.3.3.2. Service/replace electrical and/or pneumatic 

components, as needed. 

6.3.3.3. Service/replace actuator and/or valve components, as 

needed. 

6.4. Loss of Cooling Air Flow to Atomizer 

6.4.1. In case" of mechanical/electrical failure of atomizer cooling air 

blower: 

6.4.1.1. Diagnose blower/drive failure. 

6.4.1.2. Service/replace the blower/drive, as needed. 

6.4.1.3. Restore electrical power supply to the blower. 

6.4.2. In case of physical failure of atomizer cooling air duct: 

6.4.2.1. Identify ttie location of duct failure. 

6.4.2.2. Service/replace faulty duct, as needed. 

6.4.3. Incase of physical/electrical failure of control system component: 

6.4.3.1. Identify faulty control system component. 

6.4.3.2. Service/replace control system components, as needed. 

6.5. Loss of SDA Exit Gas Temperature Control 

6.5.1. In case of loss of city water flow to SDA, see 6.3. 

6.5.2. In case of physical/electrical failure of temperature transmitter: 

Service/replace temperature transmitter and/or associated 

instrumentation, as needed. 

6.5.3. In case of actuated valve failure: 

6.5 .3.1. Identify cause of actuation failure. 

6.5.3.2. Service/replace electrical and/or pneumatic 

components, as needed. 

6.5.3.3. Service/replace actuator and/or valve components, as 

needed. 

6.5.4. In case of physical/electrical failure of control system component: 

Page 17 of 26 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRA M OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

6.5.4.1. Identify faulty control system component. 

6.5.4.2. Service/replace control system components, as needed. 

6.6. Atomizer Failure 

6.6.1. In case of low atomizer lubrication oil flow: 

6.6.1.1. Diagnose the failure in the lubrication system 

6.6.1.2. Service/replace components of the lubrication system, 

as needed. 

6.6.2. In case of mechanical/electrical failure of atomizer: 

6.6.2.1. Diagnose atomizer/drive failure. 

6.6.2.2. Service/replace the atomizer/drive, as needed. 

6.6:2.3. Restore electrical power supply to the atomizer. 

6.6.2.4. components, as needed. 

Page 18 of 26 
ONY X ENVIRONMENTAL SERVICES, INC. 

PROGRA M OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

UNIT 4 SPRAY DRYER ABSORBER (SDA) 

7.1. Loss of Lime Slurry Flow to SDA 

7.1.1. In case of mechamcaVelectrical failure of lime slurry feed pump: 

7.1.1.1. Diagnose pump/drive failure. 

7.1.1.2. Service/replace the pump/drive, as needed. 

7.1.1.3. Restore electrical power supply to the pump. 

7.1.2. In case of plugging/physical failure of line or line component: 

7.1.2.1. Identify the location of plugging or line failure. 

7.1.2.2. Clear line plugging and/or service/replace faulty line 

components, as needed. 

7.1.2.3. Restore/confirm functional heat tracing, if applicable. 

7.1.3. In case of mechanical/electrical failure of actuated valve: 

7.1.3.1. Identify cause of actuation failure. 

7.1.3.2. Service/replace electrical and/or pneumatic 

components, as needed. 

7.1.3.3. Service/replace actuator and/or valve components, as 

needed. 

7.1.4. In case of physical/electrical failure of control system component:. 

7.1.4.1. Identify faulty control system component 

7.1.4.2. Service/replace control system components, as needed. 

7.2. Loss of Lime Slurry Flow Control/Exit Gas Temperature Control 

7.2.1. In case of loss of slurry flow to SDA, see 7.1. 

7.2.2. In case of physical/electrical failure of flow transmitter: 

Service/replace flow transmitter and/or associated instrumentation, 

as needed. 

7.2.3. In case of actuated valve failure: 

7.2.3.1. Identify cause of actuation failure. 

7.2.3.2. Service/replace electrical and/or pneumatic 

components, as needed. 

7.2.3.3. Service/replace actuator and/or valve components, as 

needed. 

7.2.4. In case of physical/electrical failure of control system component: 

7.2.4.1. Identify faulty control system component. 

7.2.4.2. Service/replace control system components, as needed. 

Page 19 of 26 
ONY X ENVIRONMENT A X SERVICES, INC. 

PROGRAM OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

7.3. Loss of Atomization Air Pressure to SDA Nozzle 

7.3.1. For a total loss of plant/instalment air supply, see 1.3. 

7.3.2. In case of plugging/physical failure of line or line component: 

7.3.2.1. Identify the location of plugging or line failure. 

7.3.2.2. Clear line plugging and/or service/replace faulty line 

components, as needed. 

Page 20 of 26 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRAM OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

S.O CARBON INJECTION SYSTEM (UNIT 4) 

8.1. Loss of Carrier Gas Pressure 

8.1.1. In case of mechanical/electrical failure of carbon injection air 

blower: 

8.1.1.1. Diagnose blower/drive failure. 

8.1.1.2. Service/replace the blower/drive, as needed. 

8.1.1.3. Restore electrical power supply to the blower. 

8.1.2. In case of physical failure air duct: 

8.1.2.1. Identify the location of duct failure. 

8.1.2.2. Service/replace faulty duct, as needed. 

8.1.3. In case of physicaVelectrical failure of control system component: 

8.1.3.1. Identify faulty control system component. 

8.1.3.2. Service/replace control system components, as needed. 

8.2. Loss/Restriction of Activated Carbon Flow 

8.2.1. In case of loss of plant air to carbon bulk sack, see 8.3 

8.2.2. In case of mechanical/electrical failure of carbon feeder: 

8.2.2.1. Diagnose feeder/drive failure. 

8.2.2.2. Service/replace the feeder/drive, as needed. 

8.2.2.3. Restore electrical power supply to the carbpn feeder. 

8.2.3. In case of plugging/physical failure of line or line component: 

8.2.3.1. Identify the location of plugging or line failure. 

8.2.3.2. Clear line plugging and/or service/replace faulty line 

components, as needed. 

8.2.3.3. Restore/confirm functional heat tracing, if applicable. 

8.3. Loss of Plant Air Pressure/Flow to Carbon Bulk Sack 

8.3.1. For a total loss of plant/instrument air supply, see 13. 

8.3.2. In case of plugging/physical failure of line or line component: 

8.3.2.1. Identify the location of plugging or line failure. 

83.2.2. Clear line plugging and/or service/replace faulty line 

components, as needed. 

83.3. In case of mechanical/electrical failure of actuated valve: 

8.3.3.1. Identify cause of actuation failure. 

8.3.3.2. Service/replace electrical and/or pneumatic 

components, as needed. 

Page 21 of 26 

V E S 002045 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRAM OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

8.3.3.3. Service/replace actuator and/or valve components, as 

needed. 

8.3.4. In case of physical/electrical failure of control system component: 

8.3.4.1. Identify faulty control system component. 

8.3.4.2. Service/replace control system components, as needed. 

Page 22 of 26 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRA M OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

BAGHOUSE & INDUCED DRAFT (TD) FA N 

9.1. Torn/Leaking Bag 

9.1.1. In case of a baghouse leak detection alarm, follow the relevant 

corrective measures prescribed in the Operation and Maintenance 

Plan. 

9.1.2. In case of a baghouse leak detection system failure: 

9.1.2.1. Service/replace torn/leaking bag(s), as needed: 

9.1.2.2. Diagnose the failure of the baghouse detection system. 

9.1.2.3. Service/replace baghouse leak detection system, as 

needed. 

9.2. Bag Bunding/High-High Pressure Drop 

9.2.1. In case of'low baghouse inlet gas temperature: 

9:2.1.1.- Follow the appropriate corrective actions prescribed by 

paragraph 6.5 (Unit 2 and 3) 

9.2.1.2. Follow the appropriate corrective actions prescribed by 

paragraph 7.2 (Unit 4) 

9.2.1.3. Perform baghouse inspection. 

9.2.1.4. Service/replace bag(s), as needed. 

93. Loss of Stack Gas Flowrate Control (Unit 2 and 3) 

9.3.1. In case of ED fan failure, see 9.5 

9.3.2. In ease of physical/electrical failure of flow transmitter: 

Service/replace flow transmitter and/or associated mstrumentation, 

as needed. 

9.3.3. In case of actuated damper failure: 

9.3.3.1. Identify cause of actuation failure. 

9.3.3.2.. Service/replace electrical and/or pneumatic 

components, as needed. 

9.3.3.3. Service/replace actuator and/or damper components, as 

needed. 

9.3.4. In case of physical/electrical failure of control system component: 

9.3.4.1. Identify faulty control system component. 

9.3.4.2. Service/replace control system components, as needed. 

9.4. Baghouse Isolation Damper Malfunction (Unit 4) 

9.4.1. In case of actuated damper failure: 

Page 23 of 26 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRAM OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

9.4.1.3, 

9.4.1.1 

9.4.1.2. 

Identify cause of actuation failure. 

Service/replace electrical and/or pneumatic 

components, as needed. 

Service/replace actuator and/or damper components, as 

needed. 

9.4.2. In case of physical/electrical failure of control system component: 

9.4.2.1. Identify faulty control system component. 

9.4.2.2. Service/replace control system components, as needed. 

9.5. ID Fan Failure 

9.5.1. In case of mechanical/electrical failure of ED fan: 

9.5.1.1. Diagnose fan/drive failure. 

9.5.1.2. Service/replace the fan/drive, as needed. 

9.5.1.3. Restore electrical power supply to the ED fan. 

Page 24 of 26 
ONY X ENVIRONMENTAL SERVICES, INC. 

PROGRA M OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

10.0 CONTROL SYSTEM/CONTINUOUS MONITORING SYSTEM 

10.1. Control System/Continuous Monitoring System Malfunction 

10.1.1. As needed, refer to the CMS QA/QC Plan for guidance and to 

ensure that proper cahbrations are performed. 

10.1.2. In case of physical/electrical failure of instrumentation: 

10.1.2.1. Identify faulty instrumentation component. 

10.1.2.2. Service/replace faulty mstrumentation components, as 

needed. 

10.1.3. In case of physical/electrical failure of control system component: 

10.1.3.1.. Identify faulty control system component 

10.1.3.2. Service/replace control system components, as needed. 

10.1.4. In case of physical/electrical failure of data acquisition/availabihty: 

10.1.4.1. Identify faulty data system components. 

10.1.4.2. Service/replace data system components, as needed. 

10.2. Continuous Emissions Monitoring System Malfunction 

10.2.1. As needed, refer to the CEMS QA/QC Plan for guidance and to 

) ensure that proper calibrations are performed and that the 

appropriate performance specifications are met. 

10.2.2. hi case of physical/electrical failure umbilical heat tracing: 

10-.2.2.1. Diagnose failure of heat tracing. 

10.2.2.2. Replace/restore heat traced sample umbilical. 

10.2.3. In case of mechanical/electrical failure of heated vacuum pump: 

10.2.3.1. Diagnose pump/drive failure. 

10.2.3.2. Service/replace the pump/drive, as needed. 

10.2.3.3. Replace/restore pump head heat source. 

10.2.3.4. Restore electrical power supply to heated vacuum 

pump. 

10.2.4. In case of plugging/physical failure of sample probe/umbilical: 

10.2.4.1. Identify the location of failure. 

10.2.4.2, Clear plugging and/or service/replace faulty 

components, as needed. 

10.2.5. In. case of mechanical/electrical failure of actuated valve: 

10.2.5.1. Identify cause of actuation failure. 

Page 25 of 26 

V E S 002049 
ONYX ENVIRONMENTAL SERVICES, INC. 

PROGRAM OF CORRECTIVE ACTIONS FOR MALFUNCTIONS 

10.2.5.2. Service/replace electrical and/or pneumatic 

components, as needed. 

10.2.5.3. Service/replace actuator and/or valve components, as 

needed. 

10.2.6. In case of mechamcaVelectrical failure of analyzer: 

10.2.6.1. Refer to manufacturer's service manual for guidance on 

troubleshooting and servicing analyzer. 

10.2.6.2. Service/replace analyzer, as needed. 

10.2.7. In case of mechanical/electrical failure of associated 

instrumentation: 

10.2.7.1. Identify faulty instrumentation component. 

10.2.7.2. Service/replace faulty instrumentation components, as 

needed. 

10.2.8. In case of physical/electrical failure of control system component 

10.2.8.1. Identify faulty control system component 

10.2.8.2. Service/replace control system components, as needed. 

Page 26 of 26 
OPERATION AND MAINTENANCE PLAN 

Prepared for: 

Onyx Environmental Services, Inc. 

Sauget, Illinois 

Prepared by: 

Franklin Engmeering Group, Inc. 

Franklin, Tennessee 

June 2004 
TABL E O F CONTENT S 

1.0 INTRODUCTION . . 1 

1. l REGULATORY REQUIREMENTS 2. 

1.2 RECORDKEEPING 2 

2.0 NORMA L OPERATION S O F TH E INCINERATORS... . 2 

3.0 BA G LEA K DETECTIO N SYSTE M ,. . 5 

3.1 CORRECTIVE MEASURES FOR BA G LEA K DETECTION ALARM S 7 

4.0 INSPECTIO N AN D MAINTENANC E 9 

5.0 ALTERNATIV E MOD E O F OPERATIO N .. 12 

5.1 WAR M STAND-BY MOD E OF OPERATION 12 

5.2 APPLICABLE REQUIREMENTS 13 

V E S 002052 
LIS T O F TABLE S 

TABLE 1-1 OPERATION AN D MAINTENANCE PLA N REGULATORY CHECKLIST 1 

TABLE 2-1 LIST OF STANDARD DIVISIONAL PRACTICES 3 

TABLE 3-1 BAGHOUSE LEA K DETECTION SYSTEM SPECIFICATIONS 6 

TABLE 4-1 INSPECTION AN D MAINTENANCE TO PREVENT MALFUNCTIONS 10 

ii 

V E S 002053 
1.0 INTRODUCTION 

Onyx Environmental Services, Inc. (Onyx) owns and operates three hazardous waste 

incinerators at its facility located in Sauget, Illinois. The incinerators are subject to the 

National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Hazardous 

Waste Combustors (HWC), codified as 40 CFR, Part 63, Subpart EEE (§ 63.1200 to § 

63.1213). The NESHAP for HWC specifies emissions standards which reflect emissions 

performance of Maximum Achievable Control Technologies (MACT), and is commonly 

referred to as the HWC MACT. 

The mterim HWC MACT Standard requires that Onyx operate and maintain the 

incinerators in a manner consistent with safety and good air pollution control practices 

for minimizing emissions based on parameter limits achieved during the comprehensive 

performance test. To meet this objective, Onyx has developed this operation and 

maintenance (O&M) plan. Onyx will utilize this O&M plan for periods of normal 

operation of the incinerators. During periods of startup, shutdown, and malfunction, 

Onyx will utilize the Startup, Shutdown, and Malfunction Plan (SSMP). During periods 

of startup, shutdown, and malfunction, conformance with the SSMP satisfies the duty to 

nnnimize emissions. Both the O&M plan and SSMP are maintained at the facihty. 

The purpose of this O&M plan is to: 

• Describe procedures for operating the incinerator during normal operations. 

• Describe procedures for inspection and maintenance of tbe incinerator. 

• Describe procedures for corrective measures. 

• Estabhsh guidelines designed to ensure that emissions of pollutants, automatic 

waste feed cutoffs (AWFCOs), and malfunctions are minimized. 

• Satisfy the requirements of § 63.1206(c)(7) and § 63.6(e), as shown in Table 1-1 

of this plan. 

Due to the similarity ofthe three incinerator systems, general references to an incinerator 

in this document will imply all three incinerator systems. Information that is only 

apphcable to one or two ofthe three units will be clearly identified. 

1 
1.1 Regulatory Requirements 

One of the objectives for this document is to establish a program that will ensure 

compliance with relevant sections of the Interim HWC MACT standard. Table 1-1 

provides the regulatory requhements and location within this document where each 

requirement is addressed. This table is included to facilitate fhe expeditious assessment 

of this plan's coverage of the relevant regulatory requirements. 

1.2 Recordkeeping 

Onyx will maintain files to comply with the recordkeeping requirements of the Interim 

MACT Standards. These requhements are summarized in 40 CFR 63.1211(b). The files 

relevant to this plan that are maintained in the operating record include: 

• This O&M Plan; 

• Records of all requhed preventive and necessary maintenance performed on the 

air pollution control and monitoring equipment; and 

• Records of all adjustments and maintenance performed on the continuous 

monitoring system (CMS). 

2 

V E S 002055 
Table 1-1 

Operation and Maintenance Plan Regulatory Checklist 

Regulatory Citation Description 

Location 

Addressed 

63.6(e)(l)(i) 

Implement safety and good air pollution control 

practices for mimmizing emissions 

1.0,2.0 

63.6(e)(l)(ii) 

Comply with SSMP and minimize emissions during 

SSM 

1.0 

63.6(e)(l)(iii) 

O &M requirements established pursuant to section 

112 ofthe CAA 

2.0 

63.6(e)(3) Startup, shutdown, and malfunction plan 1.0, SSMP1 

63.10(b)(1) Mamtahung files 1.2 

63.10(b)(2)(iii) 

Records of all requhed maintenance of APC and 

monitoring equipment 

1.2 

63.10(b)(2)(xi) 

Records of all adjustments and maintenance performed 

on CMS 

1.2 

63.1206(c)(7)(i)(A) Prepare and operate under O&M plan 1.0 

63.1206(c)(7)(i)(A) 

Procedures for operating combustion system 

components that could affect emissions 

2.0 

Table 2-1 

63.1206(c)(7)(i)(A) 

Procedures for inspecting combustion system 

components that could affect emissions 

4.0 

63.1206(c)(7)(i)(A) 

Procedures for maintenance combustion system 

components that could affect emissions 

4.0 

63.1206(c)(7)(i)(A) 

Corrective measures for combustion system 

components that could affect emissions 

2.0,3.1, 

SSMP1 

63.1206(c)(7)(i)(B) 

Good air pollution control practices for minimizing 

emissions 

1.0, 2.0 

63.1206(c)(7)(i)(C) 

O &M plan ensures comphance with O&M 

requhements of 63.6(e) 

1.0 

63.1206(c)(7)(i)(C) O&M plan minimizes emissions of pollutants 1.0, 2.0 

63.1206(c)(7)(i)(C) O &M plan minimizes AWFCOs 1.0,2.0 

63.1206(c)(7)(i)(C) O &M plan minimizes malfunctions 

1.0, 4.0 

Table 4-1 

63.1206(c)(7)(i)(D) O&M plan is recorded in operating record 1.2 

1

 The Startup, Shutdown, and Malfunction Plan (SSMP) is a stand-alone document, incorporated by reference. 

V E S 002056 
Table 1-1 (confirmed) 

Operation and Maintenance Plan Regulatory Checklist 

Regulatory Citation Description 

Location 

Addressed 

63.1206(c)(7)(h) 

If system equipped with a baghouse, bag leak 

detection system requhed 

3.0 

63.1206(c)(7)(ii)(A)(l) 

Detect and record PM emissions at adequate 

sensitivity 

3.0 

63.1206(c)(7)(ii)(A)(2) Output relative particulate matter loadings 3.0 

63.1206(c)(7)(ii)(A)(3) Audible alarm if loading detected over limit 3.0 

63.1206(c)(7)(ii)(A)(4) 

Comply with US EPA guidance or manufacturer's 

information for installation and operation 

3.0 

63.1206(c)(7)(ii)(A)(5) 

Initial adjustments of the system: baseline, averaging 

period, alarm set point and delay time 

3.0 

63.1206(c)(7)(ii)(A)(6) O &M plan specifies allowable adjustments 3.0,3.1 

63.1206(c)(7)(ii)(A)(6) Limits to sensitivity adjustments 3.0 

63.1206(c)(7)(ii)(A)(7) Installation location requhements 3.0 

63.1206(c)(7)(ii)(B) 

Procedures for responding to bag leak detection 

system alarm 

3.1 

63.1206(c)(7)(ii)(B)(l) 

Initiation of procedures to determine alarm within 30 

minutes 

3.1 

63.1206(c)(7)(ii)(B)(2) 

• 

Necessary corrective measure(s) to alleviate cause of 

alarm 

3.1 

1 
2.0 NORMAL OPERATIONS OFTH E INCINERATORS 

Table 2-1 presents a list of titles for Onyx's Standard Divisional Practices (SDPs). These 

SPDs provide procedures for operating the incinerator in a manner consistent with safety 

and good air pollution control practices. Utilizing these SDPs, process knowledge, and 

discretion, operators will maintain the incinerator operating parameters within 

permissible limits, if possible. Operating the incinerator in this manner will minimize the 

occurrence of AWFCOs and mhhmize the emissions of hazardous air pollutants. 

A ll applicable operating requirements for tbe incinerator, including operating parameter 

limits (OPLs), are specified in Onyx's Documentation of Compliance (DOC) or 

Notification of Compliance, whichever is currently applicable. Normal operations ofthe 

incinerator will be in compliance' with these requirements. . 

Onyx has developed Piping and Lnstrumentation Diagrams (P&IDs), Process Flow 

Diagram (PFDs), and technical descriptions for each incinerator. These resources in 

conjunction with MS PowerPoint® presentations are integral parts of operating training. 

With this framing, operators gain the understanding of alarms, interlocks, as well as the 

automated responses associated with each interlock. Knowledge of alarms and interlocks 

and access to process variable indication, prepares the operator to perform the appropriate 

corrective measures snoutd conditions deviate from normal operations. The corrective 

measures taken will be the operator's efforts to ensure safety and to maintain operating 

parameters within limits, if possible. If deviations from normal operations are caused by 

a malfunction, corrective measures will be consistent with the SSMP and the Program of 

Corrective Actions for Malfunctions, Attachment 4.0 of Onyx's SSMP. 
Table 2-1 

List of Standard Divisional Practices 

SDP NUMBER TITLE 

1011 TWI Remedial Action Work Order Program 

2200 Specialty Feeder Operation for No. 2/3 Incinerators 

2201 Startup, Operation and Shutdown of No. 2/3 Incinerators 

2202 Operation of Compressed Gas Cylinder Feeding System 

2203 Operation of Solids Feed Conveyor Systems for No. IA Incinerators 

2204 Ash Conveyor Operation for No. 2/3 Incinerators 

2205 Operation of Liquid Feed Injectors for No. 2/3 Incinerators 

2206 No. 2/3 Incinerators Legs Cleanout 

2207 No. 2 Incinerator Upper Chamber Feed System 

2208 No. 2/3 Incmerators Shutdown Permits, Tagouts and Lockouts 

2209 Operation of Baghouse Filters for No. 2/3 Incinerators. 

2210 Operation of Compressed Air System for No. 2/3 Incinerators 

2211 Lime Slurry System Operation for No. 2 and 3 Inciner ators 

2212 Spray Dryer Absorber Operation for No. 2/3 Incinerators 

2213 Operation of Dry Scrubber Solids Conveyor Systems for No. 2/3 Incinerators 

2214 Flushing the Lime Slurry System for No. 2/3 Incinerators 

2215 Operation of Oxygen Gas Cylinder Processing System 

2217 Operation of Specialty Feeder Fume Hood System for No. 3 Incinerator 
Table 2-1 (continued) 

List of Standard Divisional Practices 

SDP NUMBER 

. . _. 

TITLE 

2219 Lime Storage loading 

2221 24-Hour Staging of Burnable Containers on No. 2/3 Incinerators Dock 

2222 Ash Management for No. 2/3 Incinerators 

2224 No. 2/3 Incinerators Direct Inject System 

2401 No. 4 Incinerator Shutdown Permits, Tagouts and Lockouts 

2402 Main Feed Conveyor System Operation for No. 4 Incinerator 

2403 Clamshell Feed System Operation 

2404 Tempering Chamber Operation 

2405 Flushing the Lime Slurry System for No. 4 Incinerator 

2406 Operation of Liquid Feed Injectors for No. 4 Incinerator 

2407 Cleaning the Process Water System for No. 4 Incinerator 

2408 Operation of Carbon Injection System for No. 4 Incinerator 

2416 Lime Slurry System Operation for No. 4 Incinerator 

2417 Startup, Operation and Shutdown of No. 4 Incinerator 

2418 Spray Dryer Absorber Operation for No. 4 Incinerator 

2419 Operation of Direct Inject System for No. 4 Incinerator 

2421 Air Cannon Operation for No. 4 Incinerator 

2422 Auxiliary Feed Conveyor System Operation for No. 4 Incinerator 
3.0 BA G LEA K DETECTION SYSTEM 

Onyx utilizes a triboelectric bag leak detector to comply with the bag leak detection 

requirements of63.1206(c). The installation and on-going operation ofthe leak detection 

system is consistent with the US EPA Fabric Filter Bag Leak Detection Guidance (EPA454/R-98-015). The bag leak detection system monitors the relative particulate matter 

loading of the gas in the duct downstream of the induced draft fan. The bag leak 

detection system has been certified from manufacturer that the system is capable of 

detecting and recording particulate emissions at concentrations of 1.0 milligram per 

actual cubic meter. 

The sensitivity of the bag leak detector is set by selecting the relative output range. A 

response time (i.e., averaging period) is utilized to smooth fluctuations in the triboelectic 

signal. The bag leak detection system utilizes two alarm set points (high and high-high), 

which are set as a percentage of the full scale reading. The alarm set points are based on 

a multiple of the baseline reading considering cleaning cycle peaks, if apparent. The 

high-high alarm is interlocked with the AWFCO system. The delay times for the alarms 

are based on the normal bag cleaning pulse cycles. Tbe bag leak detection system 

settings are presented in Table 3-1. 

Following initial adjustments (including adjustments, made during a 30-day trial period) 

to the bag leak detection system, there will be no adjustments to the sensitivity (range), 

averaging period, alarm set point, or alarm delay time except for the adjustments made 

consistent with recommendations in Section 5.3 of the US EPA Fabric Filter Bag Leak 

Detection Guidance (EPA-454/R-98-015). Periodic adjustments to the bag leak detection 

system may be warranted to pievent/mirumize the occurrence of false alarms. If over a 

365 day period, the sensitivity is increased by more than 100 percent or decreased by 

more than 50 percent, a complete baghouse inspection and necessary repairs will be 

performed to assure good operating condition. 
Table 3-1 

Baghouse Leak Detection System Specifications 

Parameter Unit 2 Unit 3 Unit 4 

Range 0-1,000 0-1,000 0-1,000 

Averaging Period 10 seconds 10 seconds 10 seconds 

High Alarm 20% 20% 10% 

High Alarm Delay Time 3 minutes 3 minutes 6 minutes 

ffigh-High Alarm (AWFCO) 30% 30% 15% 

High-High Alarm Delay Time 6 niinutes 6 minutes 12 minutes 

6 

V E S 002062 
3.1 Corrective Measures for Bag Leak Detection Alarms 

Onyx has implemented the necessary proactive measures to prevent/mhhmize the 

occurrence of bag leak detection alarms. These proactive measures include inspections 

and preventive maintenance of the baghouse and the bag leak detection system. 

Additionally, the installation and operation of the bag leak detection system is consistent 

with EPA guidance. Despite these efforts, a false bag leak detection alarm or a bag 

leak/failure may occur and are considered potential malfunctions. Accordingly, this 

section is a component of the SSMP and is referenced by paragraph 9.1.1 of the Program 

of Correction Actions for Malfunctions, Attachment 4.0 of Onyx's SSMP. 

The purpose of this section is to prescribe the procedures for responding to bag leak 

detection alarms. The procedures specified in this section will be initiated within 30 

minutes of the time the alarm first sounds. The time and cause of each alarm will be 

recorded on a malfunction recordkeeping form. A blank malfunction recordkeeping form 

is Attachment 3.0 of Onyx's SSMP. 

3.1.1 In case of an alarm for high relative particulate matter loading: 

3.1.1.1 Review process data for variations in pressure drop across the 

baghouse, the baghouse cleaning cycle, baghouse inlet 

temperature, or gas flowrate that corresponds with the 

occurrence of the bag leak detection alarms. If review of this 

process data or other factors (e.g., high humidity, 

reconditioning) indicates a high probability that the excessive 

triboelecrric signal is a false indication of a bag leak/failure, 

then record findings and proceed with normal operations 

3.1.1.2 If relative particulate matter loading remains above the high 

alarm set point, take actions to reduce the relative particulate 

matter loading (e.g., controlled shutdown of high ash waste 

feeds). 

3.1.1.3 If after 30 minutes of the occurrence of the high alarm, the 

relative particulate matter loading remains above the high alarm 

set point, follow the corrective measures of 3.1.2. . 

3.1.2 In case of reoccurring false bag leak detection alarms: 

3.1.2.1 Clean the bag leak detection system probe, and/or adjust the 

sensitivity (range), averaging period, alarm set points, and/or 

alarm delay time, as needed. 
3.1.2.2 If corrective measures of 3.1.2.1 were previously unsuccessful, 

follow corrective measures of 3.1.3. 

3.1.3 In case of an alarm for high-high relative particulate matter loading: 

3.1.3.1 Initiate a controlled shutdown of waste feeds. 

3.1.3.2 Inspect baghouse for leaks, torn or broken filter elements, or 

other internal equipment failures; and repair as needed. 

3.1.3.3 Following inspection/repair of baghouse, clean the bag leak 

detection system probe, and/or adjust the sensitivity (range), 

averaging period, alarm set points, and/or alarm delay time, as 

needed. 

As stated in the US EPA Fabric Filter Bag Leak Detection Guidance (EPA-454/R-98-

015), "...conditioning the [bag leak detection] system to the process envhonment is 

critical to reliable and repeatable operation." Therefore, allowance for reconditioning the 

system to the process environment should be made after cleaning the probe or after 

making adjustments to the system. 
4.0 INSPECTION AND MAINTENANCE 

As stated ia Sections V.a.F. and V.b.F. of Onyx's Part B RCRA Permit, each incinerator 

system undergoes a "thorough visual inspection for leaks, spills, fugitive emissions, and 

sign of tampering at least daily and in accordance with the inspection schedule, contained 

in Appendix 6 of the approved permit application". Onyx utilizes these inspections and 

additional preventive maintenance activities as proactive measures for mimmizing the 

potential for malfunctions. To facilitate proper maintenance, a cold shutdown will occur 

at least once per year for each incinerator system. Table 4-1 presents a general summary 

ofthe inspection and maintenance activities that are performed to prevent malfunctions. 

Routine inspection and maintenance activities are scheduled, communicated, and 

recorded through the use of field checklists. Parts of the incinerator systems that are 

subject to wear (e.g., bearings, O-rings, air/oil filters) are replaced based on the schedules 

indicated on these checklists. These field checklists will also be used to document repairs 

or replacements of incinerator components that may be revealed during inspections. If 

as-needed repairs cannot be performed immediately (within 24-hours), SDP 1011—TWI 

Remedial Action Work Order Program—ensures that these non-routine maintenance 

activities are given the appropriate priority and are tracked through completion. Brief 

procedures/instructions for inspection and maintenance activities are provided on field 

checklists. Addition details and procedures for inspection and maintenance activities are 

communicated through the following: 

• SDPs for specific process maintenance procedures (see Table 2-1); 

• Inspection and maintenance procedures from equipment manufacturers; 

• Training activities for maintenance personnel; and 

• Shutdown and maintenance meetings. 

Selected inspection and maintenance activities may be performed by qualified contractors 

or associates affiliated with an equipment manufacturer/vendor. Onyx will include 

documentation of these activities in the operating record. 

Inspection and maintenance requirements are also addressed in other plans requhed by 

the Interim HWC MACT Standard. Inspection and testing of the AWFCO system are 

described in the Automatic Waste Feed Cutoff Plan. Inspection, calibration, and 

preventive maintenance for the continuous emissions monitoring system (CEMS) are 

discussed the Continuous Emissions Monitoring System Quality Assurance Plan. 

Discussion on calibration and maintenance for the continuous monitoring system (CMS) 

is presented in the Continuous Monitoring System Quality Assurance Program. 
Table 4-1 

Inspection and Maintenance to Prevent Malfunctions 

Potential Cause for 

Malfunction 

Inspections Maintenance 

MechamcaVelectrical 

failure of rotating 

equipment. 

• Daily inspections for leaks, 

corrosion, and vibration 

• Instrumentation and alarms for 

current, lubrication, and/or 

vibration on selected rotating 

equipment 

• Cleaning 

• Tightening fasteners and 

supports 

• Lubrication 

• Alignment 

• Scheduled replacement of 

critical parts 

• As needed 

repairs/replacements 

Plugging/Mecbariical 

failure of 

lines/nozzles 

• Daily inspection for leaks, and 

corrosion 

• Internal equipment inspections 

during shutdowns 

• Cleaning 

• Tightening supports 

• As needed 

repafrs/replacements 

Mechanical/electrical 

failure of 

mstrumentation 

• Process variable indication 

• Comparison between 

redundant instruments 

• Calibration checks 

• Scheduled replacement of 

instruments 

• As needed 

repairs/replacements 

Mechanical/electrical 

failure of actuated 

valves/dampers 

• Daily inspection for leaks, and 

corrosion 

• Visual inspection of instrument 

air and electrical connections 

• Confirmation of fail-safe 

positions during shutdowns 

• Confirmation of functionality 

through process variable 

control/indication 

• AWFCO Testing 

• Cleaning 

• Lubrication 

• As needed 

repairs/replacements 

10 

V E S 002066 
Table 4-1 (continued) 

Inspection and Maintenance to Prevent Malfunctions 

Potential Cause for 

Malfunction 

Inspections Maintenance 

Physical/electrical 

failure of control 

system 

• Process variable 

control/indication 

• Visual inspection of 

connections 

• AWFCO Testing 

• Cleaning 

• As needed 

repairs/replacements 

Mecbanical/electrical 

failure of utility 

supphes 

• Inspections ofthe utility 

supply source 

• As needed 

repairs/replacements 

Electrical/actuation 

failure of safety 

interlocks 

• Corifnmatipn of valve fail-safe 

positions during shutdowns 

• Verification of alarms and 

interlocks during AWFCO 

Testing 

• As needed 

repairs/replacements 

Physical/mechanical 

internal equipment 

failure 

• Daily exterior inspections for 

leaks, corrosion, and vibration 

• Interior inspections during 

shutdowns 

• Internal cleaning 

• Tightening fasteners and 

supports 

• As needed 

repairs/replacements 

11 
5.0 ALTERNATIVE MODE OF OPERATION 

Onyx routinely performs certain inspection and maintenance activities that cannot take 

place while operating the incinerator under the requhements of normal operation and 

must be performed more frequently than cold shutdowns. These activities are typically 

identified during the proactive inspections (see Table 4-1) or when noticeable changes in 

normal operating parameters are identified. These inspection and mamtenance activities 

cannot take place while operating the incinerator under the requhements of normal 

operations; however, a cold shutdown is not requhed to complete these activities. . For 

this reason, Onyx has defined an alternative mode of operation during which these 

activities can be performed. This mode of operation is referred to as the "warm stand-by 

mode". 

The warm stand-by mode of operation is being implemented per the requhements in § 

63.1206(b)(1)(h). This mode of operation will only be implemented when hazardous 

waste is not in the combustion chamber (i.e., the hazardous waste residence time has 

transpired). The remainder of the section describes the warm stand-by mode and the 

applicable requhements for this alternative mode of operation. 

5.1 Warm Stand-by Mode of Operation 

The warm stand-by mode of operation is utilized to perform inspections and maintenance 

activities that do not warrant a complete cold shutdown. During this mode of operation 

the combustion chamber temperatures are maintained utilizing natural gas. This is 

deshable from a long term operating standpoint to mimmize extreme temperature cycles 

for the refractory which can lead to excessive wear and premature failure. Further, this 

provides for shorter duration maintenance periods and a quicker return to normal 

operation (i.e., since the combustion chambers are not cooled to ambient conditions, then 

the "normal" operating temperatures can be attained in a shorter duration). 

Operation in the warm stand-by mode can only begin when hazardous waste is not in the 

combustion chamber (i.e., the hazardous waste residence time has transpired). Only 

natural gas will be fed to the main burners to maintain stand-by temperatures of the 

combustion unit. Onyx will document in the operating record all times that the unit is in 

warm stand-by maintenance operating mode as well as descriptions of any inspection and 

maintenance activities performed during the warm stand-by mode. 

12 
During the warm stand-by mode of operation all combustion gases are ducted through tbe 

ah pollution control system (APCS). The APCS, continuous momtoring systems (CMS), 

and continuous emission monitoring systems (CEMS) are operated per normal operating 

procedures, unless temporarily out-of-service for inspection and maintenance activities. 

The automatic waste feed cutoff (AWFCO) system is not operational since there is no 

hazardous waste feed to the unit 

Per § 63.1209(q)(2)(iii), Onyx will utilize a seamless transition between operating in 

warm stand-by mode and normal operations. This allows for calculating rolling averages 

using data from the previous operating mode. Prior to fransitioning to normal operating 

mode, Onyx will ensure that vahd data is available for calculating rolling averages and 

that all parameters are within limits. Normal operations will resume with the initiation of 

hazardous waste to the incinerator. 

5.2 Apphcable Requirements 

When operating in the warm stand-by mode the following Interim HWC MACT 

standards do not apply: 

• Emission standards in § 63.1203 

• Monitoring and compliance standards of §§ 63.1206"through 63.1209, except the 

modes of operation requhements in § 63.1209(q) 

• Notification, reporting, and recordkeeping requhements of §§ 63.1210 through 

63.1212 

Per the requirement of 63.1206(b)(ii), this section supplies documentation in the 

operating record that Onyx is complying with all "otherwise applicable requhements" 

during warm stand-by mode of operation. Requhements constitute "otherwise applicable 

requirements" to the extent that they do'not arise from Subpart EEE and they are 

otherwise apphcable to any of fhe emission units when it is operating during warm standby mode. Incinerator Unit 2, Unit 3, or Unit 4, when operated under warm stand-by 

mode, is not subject to any "otherwise apphcable requirements". 

13 
CONTINUOUS MONITORING SYSTEM 

QUALITY CONTROL PROGRAM 

Prepared for: 

Onyx Environmental Services, Inc. 

Sauget, Illinois 

Prepared by: 

Franklin Engineering Group, Inc. 

Franklin, Tennessee 

June 2004 
TABL E O F CONTENT S 

1.0 INTRODUCTIO N AN D BACKGROUN D 1 

1.1 SUMMARY OF FACILITY INFORMATION 4 

1.1.1 Fixed Hearth Incinerators 4 

1.1.2 Rotary Kiln Incinerator. — - ......5 

1.2 CM S INSTRUMENTATION ,„..„• 6 

2.0 CM S CALIBRATIO N AN D PREVENTIV E MAINTENANC E 13 

2.1 CM S CALIBRATION • —1 3 

2.1.1 Initial CMS Calibration : .....13 

2.1.2 Subsequent CMS Calibration 13 

2.1.3 CEMS Calibration Audits and Calibration ....14 

2.2 CM S CALIBRATION AUDITS • -14 

2.3 PREVENTIVE MAINTENANCE : - 19 

3.0 CM S RECORDKEEPIN G AN D REPORTIN G .... 20 

3.1 RECORDKEEPING

 2 0 

3.2 REPORTING '• 2 1 

4.0 CM S CORRECTIV E ACTION S 2 4 

ii 

V E S 002071 
INDE X O F TABLE S 

TABLE 1 - l REGULATORY CHECKLIST FOR THE CM S Q A PROGRAM 

TABLE 1-2 CM S INSTRUMENT SPECIFICATIONS „.., .... 

TABLE 2-1 CM S CALIBRATION AUDIT REQUIREMENTS .". 

TABLE 3-1 REPORTING REQUIREMENTS : 

iii 
1.0 INTRODUCTION AND BACKGROUND 

Onyx Environmental Services, Inc. (Onyx) owns and operates two fixed hearth 

incinerators (Units 2 and 3) and a rotary kiln incinerator (Unit 4) at its facility located in 

Sauget, Illinois. The incinerators are subject to the National Emissions Standards for 

Hazardous A h Pollutants (NESHAP) for Hazardous Waste Combustors (HWC), codified 

as 40 CFR, Part 63, Subpart EEE (§ 63.1200 to § 63.1213). .. The NESHAP specifies 

emissions standards which reflect emissions performance of Maximum Achievable 

Control Technologies (MACT), and is commonly referred to as the HWC MACT. 

Hazardous waste combustors are requhed (per § 63.8(d)(2)] to establish and implement a 

Continuous Monitoring System (CMS) Quahty Control (QC) Program. The purpose of 

the QC Program is to outline procedures used to verify that the CMS are properly 

installed, calibrated, and collecting accurate data on an ongoing basis. The CMS 

performance evaluation test plan was submitted as part of the Comprehensive 

Performance. Test Plan. 

The QC Program demonstrates Onyx's comphance with the requhements set forth in 

§ 63.8(d)(2), as well as the additional quality assurance (QA) requirements. The QC 

Program is required to contain descriptions of initial and subsequent CMS cahbration, 

calibration drift, preventive maintenance, data recording, calculations and reporting; and 

a corrective action plan for malfunctioning CMS. Table 1-1 presents the regulatory 

references related to the QC program, followed by fhe section of this plan that addresses each 

specific requirement. Some references are made to other HWC MACT requhed facihty 

operating plans. 

This QC Program is intended to fulfill the requhements of § 63.8(d)(2), and includes 

information related to the procedures for each of the following operations: 

• Initial and subsequent cahbration of the CMS 

• Determination and adjustment of the cahbration drift ofthe CMS 

• Preventive maintenance ofthe CMS, including spare parts inventory 

• Data recording, calculations, and reporting 

• Program of corrective action for malfimctioning CMS. 

1 
Table 1-1 

Regulatory Checklist for the CMS QA Program 

Regulatory 

Citation 

Description Plan Section 

§ 63.8(c)(l)(i) Operation and maintenance of each CMS 

Section 1.2,2.3 

O&M Plan 

CEMS Plan 

§63.8(c)(l)(iii) Startup, shutdown, and malfunction plan for CMS SSMPPlan 

§ 63.8(c)(3) Verification of operational status CMS PET Plan 

§63.8(c)(7)(ii) 

Out-of-control CMS data will not be used in averages 

and calculations. 

Section 4.0 

§ 63.8(c)(7)(h) Corrective actions for an out-of-control CMS 

Section 4.0 and 

SSMPPlan 

§ 63.8(c)(8) Out-of-control CMS information to be submitted Section 4.0 

§ 63.8(d)(2) Develop and implement QC portion of CMS QA 

program 

Section 1.0 

§ 63.8(d)(2) QA program includes .the development and submittal of 

me performance evaluation test plan 

Section 2.1,1 

§63.S(d)(2)(i) Develop written procedures for initial and subsequent 

calibrations 

Sections 2.1.1, 

2.1.2 

§63.8(d)(2)(ii) Develop written procedures for determination and 

adjustment of calibration drifts 

Section 2.2 

§ 63.8(d)(2)(iii) Develop written procedures for preventive maintenance 

and spare parts inventory 

Section 2.3 

§ 63.8(d)(2)(iv) Data recording, calculations, and reporting Sections 3.1,3.2 

• 

§ 63.8(d)(2)(vi) Corrective actions for malfunctioning CMS Section 4.0 

§ 63.8(e)(3) Performance evaluation of CMS CMS PET Plan 

§ 63.8(g) Reduction of monitoring data Section 3.2 

§ 63.10(b)(1) Mamtehiing files . ' Section 3.1 

§ 63.10(b)(2)(ix) Maintain records of measurements from performance 

evaluations 

Section 3.1 

§ 63.10(b)(2)(vi) 

Maintain records of each period during which a CMS is 

malfunctioning, or inoperative and out of control 

Section 4.0 and 

SSMP Plan 

§ 63.10(b)(2)(vii) Maintain records of measurements to demonstrate 

compliance 

Section 3.1 

§ 63.10(b)(2)(viii) 

Maintain records of results of CMS performance 

evaluations and opacity and visible emission 

observations 

Section 3.1 

§63.10(b)(2)(x) Maintain records of CMS calibration checks Section 2.1.2 

2 

V E S 002074 
Table 1-1 (continued) 

Regulatory Checklist for the CMS QA Program 

Regulatory 

Citation 

Description Plan Section 

§63.10(b)(2)(xi) Maintain records of all adjustments and maintenance 

perfbrmed on the CMS Section 3.1 

§63.10(c)(1) 

Recordkeeping requhements for CMS measurements 

(including unavoidable breakdowns and out-of-control 

situations) 

Section 3.1 

§63.10(c)(13) Maintain records of total process operating time during 

the reporting period Section 3.1. 

§63.10(c)(14) Develop and hnplement CMS QA program procedures Section 1.0 

§63.10(c)(5) Maintain records of date and time for CMS 

inoperabihty (except for zero and high-level checks) Section 3.1 

§ 63.10(c)(6) Maintain records of date and time for CMS out-ofcontrol periods 

Section 3.1 . 

§ 63.10(c)(8) 

Maintain records of identification of each time period 

of exceedances - does not include periods of Startup, 

Shutdown, Malfunction (SSM) 

Section 3.1 

§63.10(e)(3)(i) Submittal of semiannual excess emissions and CMS 

performance report Section 3:1 j 

§63:10(e)(3)(v) 

Content and submittal data of excess emissions and 

CMS performance report 

Section 3.2 

• § 63.10(e)(3)(vi) 

Content of summary report required by (e)(3)(vii) and 

(e)(3)(viii) to this section 

Section 3.2 

§ 63.10(e)(3)(vii) Condition for submitting only the summary report . Section 3.2 

§ 63.10(e)(3)(viii) 

Condition for submitting both the summary report and 

excess emissions and CMS performance report 

Section 3.2 

§ 63.1209(b)(2)(i) Calibration of thermocouples and pyrometers Section 2.1 

§ 63.1209(b)(3) 

Frequency of CMS samphng; evaluation, computing, 

and recording of regulated parameter 

Section 3.1 

§ 63.1209(b)(5) Calculation of rolling averages Section 3.1 

§ 63.1209(f)(1) 

§ 63 .121 l(c) requhes that CMS are installed, 

calibrated, and operational by the compliance date 

CMS PET Plan 

Notes: 

PET Performance Evaluation Test 

SSMP Startup, Shutdown, Malfunction Plan 

SDP Standard Division Practices 
The data collected from CMS mstrumentation is used to demonstrate the unit's 

compliance with the performance requirements promulgated in the mterim .HWC 

Maximum Achievable Control Technology (MACT) standard. The QA Program outlines 

procedures used to verify that tbe CMS are properly cahbrated and collecting accurate 

data on an ongoing basis. 

Due to the similarity of the three CMS systems (one for each incinerator system), general 

references to a CMS system or incinerator system in this document will imply all three 

systems. Information that is only apphcable to one or two of the three systems will be 

clearly identified. 

This document is organized as follows: . 

SectionT.O Introduction and Background 

Section 2.0 CMS Calibration and Preventive Maintenance . 

Section 3.0 CMS Recordkeeping and Reporting 

Section 4.0 CMS Corrective Actions 

This plan also assimilates information and procedures found in other documents. As 

required by § 63.6(e)(3)(vi), other documents containing procedures or information 

referred to in this plan will be made available for inspection when requested by the 

Administrator. 

The remainder of this section provides an overview of the incineration system followed 

by a discussion on the CMS mstrumentation. Section 2.0 discusses CMS initial and 

continuing cahbration and preventive maintenance requhements. Section 3.0 addresses 

requirements related to facility documentation and reporting. Section 4.0 defines and 

discusses nonstandard operations ofthe CMS and applicable corrective actions. 

1.1 Summary of Facility Information 

Brief summaries which describe the fixed hearth incinerators and the rotary kiln 

incinerator are presented in this section. 

1.1.1 Fixed Hearth Incinerators 

Each of the fixed hearth incmerators includes the following components: 

• Feed equipment 
• Primary and secondary combustion chambers 

. • Lime injection system 

• Spray dryer absorber (SDA) 

• Fabric filter baghouse 

• Solids and ash removal systems 

• Induced draft (ED) fan and stack 

• Instrumentation, controls, and data acquisition systems 

Various solid and liquid wastes and gaseous feedstreams are thermally treated in tbe. 

fixed hearth incinerators. Sohd waste is fed to the primary (lower) combustion chamber 

via a feed conveyor system and pneumatic ram. Liquid waste from tanks and tanker 

trucks are fed to the primary combustion chamber through two atomized hquid injectors. 

Liquid waste from containers are fed to the primary combustion chamber through a 

specialty feed injector. A gaseous feedstream is fed to the Unit 2 primary combustion 

chamber dhectly from gas cylinders. Off gases from a hooded feed emission control 

system and from a waste handling glove box are fed dhectly to the Unit 3 secondary 

combustion chamber. Combustion chamber temperatures are maintained using natural 

gas fired to a dedicated burner in both the primary and secondary chambers. 

Combustion gas exits the secondary combustion chamber and enters the SDA, which 

provides acid gas removal and cooling ofthe combustion gas. Combustion gas exits the 

SDA and is distributed to the fabric filter baghouses, which provide particulate matter 

removal. The induced draft fan, located downstream of the baghouses, moves the 

combustion gas through the system and exhausts the gas through the main stack. 

Hot, wet gas is extracted downstream of the baghouse through a continuous emissions 

monitoring system. This system features a multi-component infrared gas analyzer that 

detects hydrogen chloride, carbon monoxide, and water vapor concentrations. An 

integrated zirconium oxide-based analyzer detects oxygen concentrations. 

1.1.2 Rotary Kiln Incinerator 

The rotary kiln incinerator includes the following components: 

• Waste feed system 

• Primary and secondary combustion chambers 

• Tempering chamber 

• Lime injection system 

• Spray dryer absorber 
• Carbon injection system . 

• Fabric filter baghouse 

• Solids and ash removal systems 

• ID fan and stack ' 

• mstrumentation, controls^ and data acquisition systems 

Various solid and liquid wastes are thermally treated in the rotary kiln incinerator. Sohd 

wastes are fed tp a ram feeder via a clamshell, a drum feed conveyor, and an auxiliary 

feed conveyor. A hydraulic ram pushes the sohd waste into the kiln. Liquid waste from 

tanks and tanker trucks is fed to the primary and secondary combustion chambers through 

atomized liquid injectors. Combustion chamber temperatures are maintained using 

natural gas fired to a dedicated burner in both the primary and secondary chambers. 

Combustion gas exits the secondary combustion chamber and enters the tempering 

chamber, which provides cooling of the combustion gases. The combustion gas exits the 

tempering chamber and is distributed between two identical SDAs, which provide acid 

gas removal and additional gas coohng, A carbon injection system is utilized for 

controlling droxin/furan and mercury emissions. The activated carbon is air injected into 

the combustion gas immediately downstream of-the convergence of combustion gases 

from the SDAs. From the SDAs, combustion gas is distributed to fabric filter baghouses, 

which provide particulate matter removal. The ID fan, located downstream of the. 

baghouses, moves the combustion gas through the system and exhausts the gas through 

the main stack. 

Hot, wet gas is extracted downstream of Ihe ID fan through a continuous emissions 

monitoring system. This system features a multi-component infrared gas analyzer that 

detects hydrogen chloride, carbon monoxide, and water vapor concentiations. A n 

integrated zhconium oxide-based analyzer detects oxygen concentrations. 

1.2 CMS Instrumentation 

This section describes the CMS instruments used monitor regulated process parameters 

for demonstrating on-going compliance with the Interim HWC MACT emission 

standards. A summary of specifications for CMS instrumentation is provided in Table 

1-2. 

The Interim HWC MACT standard requires all CMS's be installed in locations that 

provide representative measurements of emissions or process parameters. All CMS 
Table 1-2 

CMS Instrument Specifications 

Application Instrument Tag Number Manufacturer Model Operating Range Location 

Unit No. 2 

| High BTU Liquid Feedrate Mass Flo wmeter FT-215 Micro Motion D 40S-SS 0-3,600 lb/hr Feed Line 

High BTU Liquid Direct Injection 

Feedrate 

Scale WT-215DI Weigh-Tronix WI-.130 0-60,000 lb Feed Line 

| Low BTU Liquid Feedrate Mass Flowmeter FT-216 Micro Motion D 40S-SS 0-3,600 lb/hr Feed Line 

1 

Low BTU Liquid Direct Injection • 

Feedrate 

Scale WT-215DI Weigh-Tronix WI-.130 0-60,000 lb Feed Line 

Specialty Feed Weight Weigh Scale WT-204 Toledo 8140 EXP 0-4,000 lb # 204 Specialty 

Feeder 

Drummed and Bulk Solids Feed 

Weight Weigh Scale WT-210 Toledo A140 0-400 Ib Solid Charge Conveyor 

Cylinder Gas Feedrate dPCell FT-217 Yokogawa YA11F • • 

0-10 in. w.c. 

(0-60 lb/min) 

Cylinder Gas 

Feed System 

PCC Temperature 

TypeK 

Thermocouple 

TT-200A/B Modicon B883-2O0 0-2500 °F Primary 

Chamber 

SCC Temperature . 

TypeK 

Thermocouple 

TT-219A/B Modicon B883-200 . 0-2500 °F Secondary 

Chamber 

PCC Pressure 

Pressure 

Transmitter 

• PT-200 Rosemont 1151DP . : -7.5 to 2.5 in. w.c. 

Primary 

Chamber 

ESV Position Position Switch , ZS-224 Square-D 9007 CG2B2 open/close 

Emergency 

Stack 

Baghouse Inlet Temperature 

TypeK 

Thermocouple 

TT-270 Modicon 833-200 0-2500 °F SDA Outlet 

Combustion Gas Flow Rate dPCell FT-283 Rosemount 1151DR 0-20,00.0 acfm. Stack 

Stack Gas Oxygen, Concentration 

Zif ranhirn Oxide 

Analyzer 

AT-289 COS A ZFN-11YA1-2Z1 0-25% . 

CEMS 

Building 

Stack Gas Carbon Monoxide 

Concentration 

Multicomponent 

Infrared. 

Photometer with 

Integrated 

Zirconium Oxide 

Oxygen Analyzer 

AT-288E EcoChem MC3 

0-200 / 0-3000 ppmv 

CEMS 

Building 

Stack Hydrogen Chloride 

Concentration 

Multicomponent 

Infrared. 

Photometer with 

Integrated 

Zirconium Oxide 

Oxygen Analyzer 

AT-288E EcoChem MC3 0-1000 ppmv 

CEMS 

Building 

Stack Gas Moisture Concentration 

Multicomponent 

Infrared. 

Photometer with 

Integrated 

Zirconium Oxide 

Oxygen Analyzer 

AT-288E EcoChem MC3 

' 0-60% 

CEMS 

Building 

Stack Gas Oxygen Concentration 

Multicomponent 

Infrared. 

Photometer with 

Integrated 

Zirconium Oxide 

Oxygen Analyzer 

AT-288E EcoChem MC3 

0-25% 

CEMS 

Building 
Table l-2(continued) 

CMS Instrument Specifications 

| Application Instrument Tag Number Manufacturer Model Operating Range Location 

| Unit No. 3 

High BTU Liquid Feedrate Mass Flowmeter FT-315 Micro Motion DS-040 0-3,600 lb/hr Feed Line 

High BTU Liquid Direct Injection 

Feedrate 

Scale WT-315 DI Weigh-Tronix WI-130 0-60,000 lb Feed Line 

Low BTU Liquid Feedrate Mass Flowmeter FT-316 Micro Motion . DS-040 0-3,600 lb/hr Feed Line 

Low BTU Liquid Direct Injection 

Feedrate 

Scale WT-315DI Weigh-Tronix WI-130 0-60,000 lb Feed Line 

Specialty Feed Weight Weigh Scale WT-304 Toledo AI40 EXP 0-2,000 lb #304 Hooded 

Feeder 

Drummed and Bulk Solids Feed 

Weight Weigh Scale WT-310 Toledo A140 0-400 lb Solid Charge 

Conveyor 

PCC Temperature 

TypeK 

Thermocouple 

TT-300A/B Modicon 883-200 0-2500 °F. 

Primary 

Chamber 

SCC Temperature 

TypeK 

Thermocouple 

TT-319A/B Modicon 883-200 0-2500 °F Secondary 

Chamber 

PCC Pressure 

Pressure 

Transmitter 

PT-300 Rosemount 1151 dP -7.5 to 2.5. in. w.c. Feed Line 

TRV Position Position Switch ZS-324 Square-D 9007 CG2B2 open/close 

Emergency 

Stack 

Baghouse Inlet Temperature 

TypeK 

Thermocouple 

TT-370 Modicon 833-200 0-2500

 P F SDA Outlet 

Combustion Gas Flow Rate dP Cell FT-383 Rosemount 1151 PR 0-20,000 acfm! • Stack 

Stack Gas Oxygen Concentration 

Zirconium Oxide 

Analyzer 

AT-389 COSA ZFN-11YA1-2Z1 0-25% CEMS 

Building 

Stack Gas Carbon Monoxide 

Concentration 

Multicomponent 

Infrared 

Photometer with 

Integrated 

Zirconium Oxide 

Oxygen Analyzer 

AT-388E EcoChem MC3 

0-200/0-3000 

ppmv 

"CEMS 

Building 

Stack Hydrogen.Chloride 

Concentration 

Multicomponent 

Infrared 

Photometer with 

Integrated 

Zirconium Oxide 

Oxygen Analyzer 

AT-388E EcoChem MC3 0-1000 ppmv 

"CEMS 

Building 

Stack Gas Moisture Concentration 

Multicomponent 

Infrared 

Photometer with 

Integrated 

Zirconium Oxide 

Oxygen Analyzer 

AT-388E EcoChem MC3 

0-60% 

"CEMS 

Building 

Stack Gas Oxygen Concentration 

Multicomponent 

Infrared 

Photometer with 

Integrated 

Zirconium Oxide 

Oxygen Analyzer 

AT-388E EcoChem MC3 

0-25%. 

"CEMS 

Building 

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Table 1 (continued) 

CMS Instrument Specifications 

Application Instrument Tag Number Manufacturer Model Operating Range Location 

Unit No. 4 

Waste Feedrate to X-10 Nozzle Mass Flowmeter FT-129 Micro Motion DS100S 128 0-7,000 Ib/hr Feed Line 

Waste Feedrate to X-l 1 Nozzle Mass Flowmeter FT-138 Micro Motion D100S-HY 0-6,000 lb/hr Feed Line 

Waste Feedrate to X-12 Nozzle Mass Flowmeter FT-145 Micro Motion DL100S-SS 0-8,000 lb/hr Feed Line 

Waste Feedrate to X-22 Nozzle Mass Flowmeter FT-212 Micro Motion , D1D00S-SS 0-7,000 lb/hr Feed Line 

Clam Shell Feed Weight 

(shredded solids) Load Cell WT-001 Toledo 8140 0-2,000 lb Ram Feed Hopper 

Drum Conveyor Solids Weight Load Cell WT-014A . Toledo 8140 0-1,000 lb ' Drum 

Conveyor 

Auxiliary Conveyor Solids 

Weight Load Cell WT-14B Toledo 8140 0-200 lb Auxiliary Conveyor 

PCC Temperature Pyrometer TT-305A/B Ircon 

Modline4 44-99-F1-0-1-

0-3,000 °F Kiln Outlet 

SCC Temperature 

TypeR 

Thermocouple 

TT-317A/B . Chessel 3510 0-3,000 °F SCC Outlet 

PCC Pressure 

Pressure 

Transmitter 

PT-300 Rosemount 1151DR2F -9.0 to 1.0 in. w.c Kiln Hood 

Surge Vent Position Position Switch ZSC-026 Square-D . 9007CG2B2 open/close Kiln Face 

TRV Position Position Switch ZSC-316 Square-D 9007CG2B2 open/close 

Emergency 

Stack 

Carbon Feedrate Feeder C-17 K-Tron K2T35 0-100 Carbon Inject. 

System 

Carbon Injection Carrier Gas 

Supply Pressure 

Pressure Switch PSL-438A Dwyer 3330 Trip Points: 

± 5 in. w;c. 

Carbon 

Injection Line 

Cavbon Feeder Discharge Pressure Pressure Switch PSH-438B Dwyer 3215 . 

Trip Points: 

< 3 psig 

> 13 psig 

Carbon 

Injection Line 
Table 1 (continued) 

CMS Instrument Specifications 

1 

Application 

Instrument Tag Number Manufacturer Model Operating Range Location 

Unit No. 4 (continued) 

SDA X-18 Outlet Temperature 

(Baghouse Inlet Temperature) 

TypeK 

Thermocouple 

TT-417A/B Modicon B883-200 0-2,500 °F SDA X-18 

Outlet 

1 SDA X-19 Outlet Temperature 

(Baghouse Inlet Temperature) 

TypeK 

Thermocouple 

TT-418A/B Modicon B883-200 0-2,500 °F SDA X-19 

. Outlet 

Combustion Gas Flowrate Pitot Tube/dP Cell FT-559A/B . Automation Service 115IDRF2283 0-55,000 acfm Stack 

Stack Gas Oxygen Concentration 

Zirconium Oxide 

Analyzer 

AT-560A/B COSA ZFN-11YA1-2Z1 0-20% CEMS . 

Building 

Stack Gas Carbon Monoxide 

Concentration 

Multicomponent 

Infrared 

Photometer with 

Integrated 

Zirconium Oxide 

Oxygen Analyzer 

AT-556E EcoChem MC3 

0-200/. 0-3000 ppmv 

CEMS 

Building 

Stack Hydrogen Chloride 

Concentration 

Multicomponent 

Infrared 

Photometer with 

Integrated 

Zirconium Oxide 

Oxygen Analyzer 

AT-556E EcoChem MC3 

0-1000 ppmv. 

CEMS 

Building 

Stack Gas Moisture Concentration 

Multicomponent 

Infrared 

Photometer with 

Integrated 

Zirconium Oxide 

Oxygen Analyzer 

AT-556E EcoChem MC3 

0-60% 

CEMS 

Building 

Stack Gas Oxygen Concentration 

Multicomponent 

Infrared 

Photometer with 

Integrated 

Zirconium Oxide 

Oxygen Analyzer 

AT-556E EcoChem MC3 

0-25% 

CEMS 

Building 

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10 
operating parameter measurement devices at the Onyx facility are installed in comphance with 

this requirement. A description ofthe types of CMS instrumentation follows: 

Mass/Feedrate Monitors: Liquid waste feedrates from tanks are measured by coriolis mass 

flowmeters. Direct inject liquid feedrates from tanker truck are calculated using the continuously 

monitored weight ofthe tanker. All sohd waste charges are weighed using a scale/load ceu prior 

to being feed to the incinerator. These measurements are used to calculate pumpable waste, total 

waste, and constituent feedrates. 

For Unit 4, the output of a calibrated feeder is utilized to calculate the feedrate of powdered 

activated carbon, which is injected into the plenum upstream ofthe baghouses. 

Pressure/Differential Pressure Monitors: Primary combustion chamber pressure is measured 

by diaphragm actuated pressure transmitters. The position ofthe damper immediately upstream 

of the ID fan is varied fo control stack gas flowrate and to maintain kiln combustion chamber 

negative pressure (draft). The primary combustion chamber pressure is interlocked with waste 

feeds. 

For Unit 2, pressure drop in the cylinder gas feedstream is measured and converted to a feedrate. 

The feedrate is used to calculate this feedstream's contribution to the chlorine, low volatile 

metals, and semivolatile metals feedrates to the incinerator. 

For Unit 4, pressure switches are utilized to ensure that the carbon feeder discbarge pressure, and 

the carbon injection air blower discharge pressure are within the design limits. 

The pressure drop across a pitot tube in the stack is continuously monitored and used to calculate 

the stack gas flowrate. 

Temperature Monitors: For Units 2 and 3, redundant thermocouples are used to measure the 

temperature in both combustion chambers. A thermocouple is also located at the exit to the SDA 

and is the primary element for the SDA exit temperature control loop. 

Unit 4 is equipped with redundant pyrometers in the primary chamber and redundant 

thermocouples in the secondary chamber. Each SDA outlet is equipped with redundant 

thermocouples used for temperature control and monitoring of the baghouse inlet temperature. 

11 
Emergency Safety Vent Position Monitors: The position ofthe emergency safety vent (ESV) 

is indicated as open or closed by a position transmitter: No waste or fuel can be fed if the ESV 

position is "open". The Emergency Safety Vent (ESV) Plan provides details on the ESV 

systems. 

Bag Leak Detection System: • A triboelecrric sensor is located downstream of the ID fan and 

monitors the relative particulate matter loading of the combustion gas exiting the baghouses. 

Alamos and interlocks based on this relative measurement are indications of a potential bag leak 

or failure. Procedures for setup and adjustments to the bag leak detection system are not covered 

by this QC program. The Operation and Mamtenance Plan provides details on the bag leak 

detection system. 

Continuous Emissions Monitoring System: The CEMS continuously samples and analyzes 

stack gas for the concentrations of carbon monoxide (CO), Hydrogen Chloride (HCI), and 

moisture using a multicomponent infrared photometer. The oxygen concentration ofthe sampled 

gas is analyzed simultaneously using an integrated zhconium oxide analyzer. A back-up 

zhcomum oxide O2 analyzer also monitors stack gas O2 concentration. These data are used to 

calculate the stack gas CO and HCI concentrations on a dry basis, corrected to 7% O2. The 

CEMS QA Plan provides additional details on the CEMS. . 

12 
2.0 CMS CALIBRATION AND PREVENTIVE MAINTENANCE 

This section discusses the cahbration and preventive maintenance requhements to meet the 

requirements of § 63.8(d). . 

2.1 CMS Calibration 

To ensure ongoing compliance with the mterim HWC MACT standard, it is essential that the 

data collected from the CMS be measured and recorded in an accurate manner. Initial 

calibrations, subsequent cahbration, and CEMS cahbrations are described in this section. 

2.1.1 Initial CMS-Calibration 

As part of Onyx's Quality Control Program, the CMS instruments were initially calibrated prior 

to the Interim HWC MACT comphance date. Cahbration prior to the compliance date is 

required so that all collected data are reliable and accurate. All initial cahbration data are part of 

the operating record. Initial calibrations of new/replacement instruments, will be performed per 

the manufacture's written procedures. In lieu of an initial calibration for new/replacement 

instruments or instrument components, the facility may use a manufacturer's certification. 

2.1.2 Subsequent CMS Calibration 

Subsequent calibrations on CMS instrumentation will be performed as needed and in accordance 

with the manufacture's written procedures. Cahbrations will be performed as corrective 

measures for high cahbration drift. Calibrations may be required when restoring CMS 

instruments after maintenance or repairs. All cahbration adjustments will be documented by 

records ofthe calibration drift deterrriined before and after tbe instrument was serviced. 

Some instruments such as differential pressure cells must be removed from service and bench 

calibrated. To minimize downtime these instruments may be replaced with a calibrated spare. 

The Unit 4 primary combustion chamber pyrometers will be replaced at least armually with a 

factory cahbrated pyrometer. Electronic checks and replacements of thermocouples will be 

performed per the facility's Thermocouple Calibration, Operation, and Replacement Procedure. 

A calibration record form is available for each CMS instrument and will be used to document 

calibration audits, cahbrations, and replacements. The most recently completed cahbration 

record documents that the instrument in service meets the quality control criteria set forth by this 

program. These calibration records contain "calibration notes" which provide the instrument 

technician with procedures specific to a given mstrument. The calibration record forms for CMS 

instruments are incorporated in this QC Program by reference. 

13 
2.13 CEMS Calibration Audits and Calibration 

CEMS QA/QC procedures are provided by the Continuous Emission Monitoring System Quality 

Assurance Plan. These procedures are maintained at the facihty and describe the requirements 

for CEMS drift checks, audits, cahbrations, preventive maintenance, and recordkeeping. 

2.2 CMS Calibration Audits 

CMS cahbration audits are performed to detennine the cahbration drift (CD) of CMS 

instruments. Calibration Drift (CD) is the bias between the CMS instounent reading and a 

cahbration reference. Table 2-1 presents the requhements for CMS calibration audits. Each 

CMS mstrument will be subjected a cahbration audit at the frequency indicated in Table 2-1. 

The calibration audit will be performed at the low-level (zero) and high-level checks indicated. 

The calibration check will confirm that all process variable indications (e.g., local reading, 

control room display) at the high-level value agree with the calibration reference within ofthe 

required tolerance. Calibration adjustments/corrective actions must be taken if this calibration 

• drift is greater than Vi of the requhed tolerance. If the calibration drift exceeds the requhed 

tolerance, the instrument is considered out-of-'control. Section 4.0 describes the corrective 

actions for out-of-control, inoperative, and malfunctioning CMS. 

If the accuracy of a CMS instrument is in question, the CD is determined and documented prior 

to performing maintenance, repairs, or adjustments. The troubleshooting/cahbrations of CMS 

instruments will be performed in a manner consistent with the manufacturer's written procedures 

and recornmendations. The CD determined after calibrations/corrective actions have been taken 

will document the effects ofthe adjustments and demonstrate that the mstrument is performing 

properly. 

Calibration records will document CD, which is an indicator of the stability of the CMS 

cahbration over time. The amount of drift and stability is dependant on the type of instrument 

and the cahbration frequency. Onyx may increase or decrease the frequency of particular 

calibration audits to the extent warranted by an assessment of an instrument's stability. Onyx 

will maintain regularly scheduled calibration audit intervals for each CMS instrument. 

Calibrations will be performed to prevent excessive CD and to maintain the validity of the data 

collected from, the monitoring system. 

14 
Table 2-1 

CMS Calibration Audit Requirements 

1 

Application 

Instrument Tag Number 

Frequency of 

Calibration Audit 

Low Level Check 

Point 

High Level Check 

Point Tolerance 

Unit No. 2 

High BTU Liquid Feedrate Mass Flowmeter FT-215 Annually 0-5 lb/min 15-25 lb/min 10% 

High BTU Liquid Direct Injection 

Feedrate 

Scale WT-215DI Quarterly 01b 25,0001b . 10% 

Low BTU Liquid Feedrate Mass Flowmeter FT-216 Annually 0-5 lb/min 15-25 lb/min 1.0% 

Low BTU Liquid Direct Injection 

Feedrate 

Scale WT-215DI Quarterly 01b 25,000 Ib 10% 

| Specialty Feed Weight . Weigh Scale WT-204 Quarterly . 01b -500 lb 10% 

Drummed and Bulk Solids Feed 

j Weight 

Weigh Scale WT-210 Quarterly 01b -50 lb. 10% 

J Cylinder Gas Feedrate dPCell FT-217 Annually 0 in. w.c. 10 in. w.c. 10% 

Primary Combustion Chamber 

Temperature 

Type'K • 

Thermocouple 

TT-200A/B Refer to the Thermocouple Calibration, Operation, and Replacement Procedure 

Secondary Combustion Chamber 

Temperature 

TypeK 

Thermocouple 

TT-219A/B Refer to the Thermocouple Calibration, Operation, and Replacement Procedure 

Primary Combustion Chamber 

Pressure 

Pressure 

Transmitter 

PT-200 Quarterly -7.5 to -6.5 1.5 to 2.5 in w.c. 10% 

ESV Position Position Switch ZS-224 Annually AWFCO interlock energized when open Pass 

Baghouse Inlet Temperature. 

TypeK 

Thermocouple 

TT-270 See Calibration Record Form 

Combustion Gas Flow Rate dPCell FT-283 Annually 0-0.05 in. w.c. 0.45-0.50 in. w.c. 

Stack Gas Oxygen Concentration 

Zirconium Oxide 

Analyzer 

AT-289 • Per CEMS QA Plan \ 

Stack Gas Carbon Monoxide 

Concentration 

Multicomponent 

Infrared 

Photometer with 

Integrated 

Zirconium Oxide 

Oxygen Analyzer 

. AT-288E Per CEMS QA Plan 

Stack Hydrogen Chloride 

Concentration 

Multicomponent 

Infrared 

Photometer with 

Integrated 

Zirconium Oxide 

Oxygen Analyzer 

. AT-288E Per CEMS QA Plan 

Stack Gas Moisture Concentration 

Multicomponent 

Infrared 

Photometer with 

Integrated 

Zirconium Oxide 

Oxygen Analyzer 

. AT-288E Per CEMS QA Plan 

Stack Gas Oxygen Concentration 

Multicomponent 

Infrared 

Photometer with 

Integrated 

Zirconium Oxide 

Oxygen Analyzer 

. AT-288E Per CEMS QA Plan 

15 
Table 2-1 (continued) 

CMS Calibration Audit Requirements 

Application Instrument Tag Number 

Frequency of 

Calibration Audit 

Low Level Check 

Point 

High Level Check 

Point Tolerance 1 

UnitNo.3 

| High BTU Liquid Feedrate Mass Flowmeter FT-315 Annually 0-5 lb/min 15-25 lb/min 10% 

1 High BTU Liquid Direct Injection 

Feedrate 

Scale WT-315DI Annually 01b 25,000 lb 10% 

| Low BTU Liquid Feedrate Mass Flowmeter FT-316 Annually • 0-5 lb/hr 15-25 lb/min 10% 

1 Low BTU Liquid Direct Injection 

Feedrate 

Scale WT-315DI Annually 01b 25,0001b 10% 

Specialty Feed Weight Weigh Scale WT-304 Quarterly 01b -200 lb 10% 

Drummed and Bulk Solids Feed 

Weight Weigh Scale WT-310 Quarterly 01b -50 lb 10% 

Prunary Combustion Chamber 

Temperature 

TypeK 

Thermocouple 

TT-300A/B Refer to the Thermocouple Calibration, Operation, and Replacement Procedure 

Secondary Combustion Chamber 

Temperature 

TypeK 

Thermocouple 

TT-319A/B Refer to the Thermocouple Calibration, Operation, and Replacement Procedure 

Primary Combustion Chamber 

Pressure 

Pressure 

Transmitter 

PT-300 Quarterly -7.5 to -6.5 1.5 to 2.5 in w.c. 10% 

ESV Position Position Switch . ZS-324 Annually AWFCO interlock energized when open Pass 

Baghouse Inlet Temperature 

TypeK 

Thermocouple 

TT-370 Refer to the Thermocouple Calibration, Operation, and Replacement Procedure 

Combustion Gas Flow Rate dP Cell FT-383 Annually 0-0.05 in. w.c. 0.45-0.50 in. w.c. 10% 

Stack Gas Oxygen Concentration 

Zirconium Oxide 

Analyzer 

AT-389 Per CEMS QA Plan 

Stack Gas Carbon Monoxide 

Concentration 

Multicomponent 

Infrared 

Photometer with 

Integrated 

Zirconium Oxide 

Oxygen Analyzer 

AT-388E. Per CEMS QA Plan 

Stack Hydrogen Chloride 

Concentration 

Multicomponent 

Infrared 

Photometer with 

Integrated 

Zirconium Oxide 

Oxygen Analyzer 

AT-388E. Per CEMS QA Plan 

Stack Gas Moisture Concentration 

Multicomponent 

Infrared 

Photometer with 

Integrated 

Zirconium Oxide 

Oxygen Analyzer 

AT-388E. Per CEMS QA Plan 

Stack Gas Oxygen Concentration 

Multicomponent 

Infrared 

Photometer with 

Integrated 

Zirconium Oxide 

Oxygen Analyzer 

AT-388E. Per CEMS QA Plan 

16 
Table 2-1 (continued) 

CMS Calibration Audit Requirements 

J Application Instrument Tag Number 

Frequency of Drift 

Check/Accuracy 

Audit 

Low Level Check 

Point 

High Level Check 

Point 

Tolerance 

Unit No. 4 

Waste Feedrate to X-10 Nozzle Mass Flowmeter FT-129 Annually 0-5 lb/min 15-25 lb/min 10% 

Waste Feedrate to X-l 1 Nozzle Mass Flowmeter FT-138 Annually 01b 21,000 lb 10% 

Waste Feedrate to X'12 Nozzle Mass Flowmeter FT-145 Annually 0-5 lb/min 15-25 lb/min 10% 

Waste Feedrate to X-22 Nozzle Mass Flowmeter FT-212 Annually 01b 21,0001b 10% 

Clam Shell Feed Weight 

(shredded solids) 

Load Cell WT-001 Quarterly 01b - -200 lb 10% 

| Drum Conveyor Solids Weight Load Cell WT-014A Quarterly. 01b • ~ 100 lb 10% 

Auxiliary Conveyor Solids 

1 Weight 

Load Cell WT-14B Quarterly .. 0 lb -50 lb 10% 

Primary Combustion Chamber 

Temperature 

Pyrometer TT-305A/B Replace at least annually with factory calibrated Pyrometer 

Secondary Combustion Chamber 

Temperature 

Type R 

Thermocouple 

TT-317A/B Refer to the Thermocouple' Calibration, Operation, and Replacement Procedure 

Primary Combustion Chamber 

Pressure 

Pressure 

Transmitter 

PT-300 Quarterly -9.0 to -8.0 in. w.c. 0 to 1.0 in., w.c. 10% 

Surge Vent Position Position Switch ZS-026 Annually AWFCO interlock energized when open . Pass 

ESV Position Position Switch ZS-324 Annually AWFCO interlock energized when open Pass 

Carbon Feedrate Feeder WT-438 Quarterly 0 lb/min 6-30 lb/min , 10% 

J Carbon Injection'Carrier Gas Low 

Pressure 

Pressure Switch PSL-438A Annually Energize Switch Pass 

Carb6n Injection Carrier Gas 

High Pressure 

Pressure Switch PSH-438B Annually Energize Switch Pass 

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17 
Table 2-1 (continued) 

CMS Calibration Audit Requirements 

Application Instrument Tag Number 

Frequency of Drift 

Check/Accuracy 

Audit 

Low Level Check 

Point 

High Level Check 

Point 

Tolerance 

Unit No.'4 (continued) 

SDA X-18 Outlet Temperature 

(Baghouse Inlet Temperature) 

TypeK 

Thermocouple 

TT-417A/B Refer to the Thermocouple Calibration, Operation, and Replacement Procedure 

SDA X-19 Outlet Temperature 

(Baghouse Inlet Temperature) 

TypeK 

Thermocouple 

TT-418A/B Refer to the Thermocouple Calibration, Operation, and Replacement Procedure 

Combustion Gas Flowrate Pitot Tube/dP Cell FT-559A/B Annually 0 in. w.c. 1.74 in w.c. 10% 

Stack Gas Oxygen 

Concentration 

Zirconium Oxide 

Analyzer 

AT-560A/B Per CEMS QA Plan 

Stack Gas Carbon Monoxide 

Concentration 

Stack Hydrogen Chloride 

Concentration 

Stack Gas Moisture 

Concentration 

Stack Gas Oxygen 

Concentration 

Multicomponent 

InfraredlPhotometer 

with Integrated 

Znconium Oxide 

Oxygen Analyzer 

AT-556E Per CEMS QA Plan 
2.3 Preventive Maintenance 

Onyx takes daily proactive measures to assure that potential problems with the CMS are quickly 

identified and avoided, if possible. Daily maintenance checks mclude: 

• Verification that process variables are reasonable 

• Comparison of readings from redundant instruments 

• Cleaning and visual check of monitoring equipment 

• Communication between operators and instrument technicians 

These checks are documented on a daily logsheet for each incinerator." The preventive 

maintenance on the CMS also includes the cahbration audits previously described. All necessary 

parts for routine repairs of the affected CMS equipment are made readily available onsite. A 

spare parts inventory for each component of the CMS is included in the records maintained by 

the Maintenance Department. Additional details regarding preventive maintenance applicable to 

the CMS are provided in the facility's Operation and Maintenance Plan and the CEMS QA Plan. 

19 

V E S 002091 
3.0 CMS RECORDKEEPING AND REPORTING 

This section discusses recordkeeping and reporting requirements for CMS 

instrumentation as specified by .§ 63.1211. 

3.1 Recordkeeping 

Onyx will follow the recordkeeping requirements as specified in § 63.10(b),. including the 

semiannual excess emissions and CMS performance report Onyx will maintain these 

records of CMS data for a mmimum of 5 years following tbe date of each occurrence, 

measurement, maintenance, corrective action, report, or record. At a minimum, the most 

recent 2. years of data will be retained onsite. Below is a brief summary of these 

requirements. 

Onyx will maintain records on the following: 

• The. occurrence and duration of each startup, shutdown, or malfunction of 

operation. 

• The occurrence and duration of each malfunction of the ah pollution control 

and monitoring equipment. Maintenance performed on the air pollution 

control and monitoring equipment 

• Actions taken during periods of startup, shutdown, and malfunction (including 

corrective actions to restore the process or ah pollution control system to 

normal operation) when such actions are different the procedures outlined in 

the SSMP 

• All infonnation necessary to demonstrate conformance with the SSMP 

• Each period in which a CMS is malfunctioning or inoperative (including outof-control periods) 

• All requhed measurements needed to demonstrate compliance with a relevant 

standard. 

• All results of performance tests, CMS performance evaluations, and opacity 

and visible emission observations 

• All CMS cahbration checks 

• All adjustments and maintenance performed on CMS 

• All required CMS measurements (including data recorded during unavoidable 

CMS breakdowns and out-of-control periods) . 

• The date and time identifying each period during which the CMS was 

inoperative except for zero (low level) and high level checks 

20 
• The date and time identifying each period during which the CMS was out-ofcontrol as defined by § 63.8(c)(7) 

• The specific identification (date and time of commencement and completion) 

of each period of excess emissions and parameter monitoring exceedances, as 

defined in the relevant standard, that occurs during periods other than startup, 

shutdowns, and malfunctions. 

• Tbe nature and cause of any malfunction 

• The corrective action taken or preventive measures adopted 

• The nature of the repairs pr adjustments to fhe CMS that was inoperative or 

out-of-control 

• The total process operating time during the reporting period 

• All procedures that are part of quahty control program developed and 

implemented for CMS under § 63.8(d). 

A l l CMS mstrumentation will be operated on a continuous basis. The detector response 

will be evaluated at least every 15 seconds, and these values will be used to calculate 

regulated parameters. For parameters interlocked with the AWFCO system on an hourly 

rolling average basis, raw data will be averaged and recorded at least once per minute. 

One minute averages will be used to calculate the hourly rolling averages. The pumpable 

waste, total waste, and constituent feedrate operating parameter limits are bases on rollmg 

totals in lieu of rollmg averages. 

An integral part of the CMS is the data acquisition and data historian systems, which 

records all operating data generated by the CMS instruments. The data historian and 

associated archive files are part of the operating record. CMS instrument calibrations, 

maintenance activities, and corrective actions are recorded and kept in the operating 

record. All data collected during CMS PETs are recorded and kept in the operating 

record. . 

3.2 Reporting 

Onyx will follow the reporting requhements as specified in § 63.10. In addition, Onyx 

will develop and include in the operating record a Documentation of Compliance (DOC) 

per § 63.1211(c). The DOC must include a signed and dated certification that the CEMS 

and CMS are installed, calibrated, and continuously operating in comphance with the 

requirements of Subpart EEE. 

21 
Raw data from the CMS will be collected, reduced as described in. § 63.8(g), and 

included in the CMS PET report. This data will be analyzed to determine compliance. 

with the HWC MACT and fhe results will be submitted as part of the notification of 

compliance requhed by § 63.1207(j). 

The content and deadline requirements for the excess emissions and monitoring system 

performance reports are specified in § 63.10(e)(3)(v). The requhements for the summary 

report are given in § 63.10(e)(3)(yi). 

As noted in § 63.10(e)(3)(vii), Onyx is required to only submit the summary report if the 

total duration of excess emissions or process or control system parameter exceedances for 

the reporting period is less than one percent of the total operating time for the reporting 

period, and CMS downtime for the.reporting, period is less than five percent of the total 

operating time for the reporting period. Conversely, additional reporting is requhed by § 

63.10(e)(3)(viii) if the total duration of exceedances, or the total CMS downtime during 

the reporting period, is greater than the allowable percentage of the reporting period. 

Table 3-1. provides a list of Onyx's reporting requirements. 

22 
Table 3-1 Reporting Requirements 

Regulatory 

Citation 

Description Frequency 

§ 63.1211(c) Record Documentation of Compliance in the operating 

record Once 

§ 63.10(d)(2) Before Title V permit has been issued, owner operator 

must submit results of performance test. 

By the 60th day 

following every 

performance test 

§ 63.10(d)(2) After Title V permit has been issued, owner operator 

must submit results of requhed performance tests. 

By the 60th day 

following requhed 

performance test 

§ 63.1.0(d)(4) Progress reports 

As specified in written 

extension of 

compliance 

§ 63.10(d)(5)(i) Periodic startup, shutdown, and malfunction reports 

(during reporting period) 

Submitted 

simultaneous with 

excess emission report 

§ 63.10(d)(5)(ii) Startup, shutdown, and malfunction reports when 

actions are taken that are inconsistent with SSMP. 

2 working days from • 

commencement of 

action, followed with a 

letter explaining extent 

within 7 working days. 

§ 63.10(e)(3)(i) Submittal of semiannual excess emissions and CMS 

performance report 

Semiannually - by the 

30th day following the 

end of each calendar 

half perfomiance test 

23 

V E S 002095 
4.0 CM S CORRECTIV E ACTION S 

If a CMS is found to be out-of-control, inoperative, or malfunctioning; corrective actions 

must be taken to return the CMS to normal operation. Definitions used in determining 

the type of corrective action required are given below. 

Out-of-control: A CMS is out-of-control if: 

• The zero (low level), mid-level, or high-level calibration drift exceeds two 

times the applicable CD specification in the applicable performance 

specification or procedure; or . 

• The CMS fails a performance test audit, relative accuracy audit, relative 

accuracy test audit, or hhearity test audit. 

The only applicable performance specification to the CMS is Performance Specification 

(PS) 4B of 40 CFR Part 63, Appendix B. PS 4B applies'to fhe 0 2 and CO CEMS. The 

requhements of PS 4B and additional requhements Onyx imposes on the CEMS are 

detailed in the CEMS QA Plan. In the absence of promulgated performance specification 

applicable to non-CEMS CMS instruments, Onyx has self-imposed a high-level CD 

specification, as described in Section 2.0. 

When a CMS is out-of-control, Onyx will take the necessary corrective action and shall 

repeat all necessary tests which indicate that the system is out-of-control. Corrective 

actions and retesting will continue until the CMS is returned to normal operation. The 

-beginning of the out-of-control period is the hour that the cahbration drift indicates that 

the CMS has exceeded its perfonnance specifications. The end of the out-of-control 

period is the hour following the completion of corrective action and successful 

demonstration that the CMS is within its allowable hmits. During the period the CMS is 

out-of-control, recorded data shall not be used in data averages and calculations, or to 

. meet any data availabihty requirement established under this part. 

Onyx will submit all infonnation concerning out-of-control periods, including start and 

end dates and hours, and descriptions of corrective actions taken, in the excess emissions 

and continuous monitoring system performance report required by § 63.10(e)(3). 

Malfunction: For use in this plan, malfunction is defined as any sudden, infrequent, and 

not reasonably preventable failure of air pollution control or monitoring equipment. 

24 
Malfunction also includes the failure of a process or any process equipment to operate in 

a normal or usual manner. Failures that are caused in part by poor maintenance or 

careless operation are not malfunctions. 

The Program of Corrective Actions for Malfunctions is Attachment 4 of the SSMP Plan. 

This program addresses how the incinerator will be operated and maintained during 

malfunctions. In this program, potential malfunctions are hsted. for each portion of the 

incinerator system. The malfunctions are events that are recognized by the operator, or 

indicated by an alarm, and threaten to cause an exceedance. In the response to the 

malfunction and/or alarms, the operator will apply discretion and attempt to maintain the 

incinerator system within regulatory , limits. In the program of corrective actions, 

potential causes of each malfunction are hsted. The operator will utilize process 

knowledge, job experience, and> if needed, assistance from other personnel to identify the 

cause of the malfunction. For each potential cause, actions to correct the failure are 

hsted. The corrective actions prescribed may requhe the collaboration of multidisciplined personnel who are quahfied to retum the incinerator system to proper working 

conditions (i.e., maintenance personnel, instrument technicians, engineering). 

25