4.2 Stack Gas 

Samples of stack gas were collected for determination of the following analytical 

parameters: 

• PM; 

• HC1/C12; 

• Metals; and 

• Dioxins/Furans. 

The stack gas concentration of the test parameters reported as the average of three test 

runs are used to document compliance. Stack gas concentration for a parameter may include 

analytical results for multiple components. For the determination of stack gas concentration 

measured in an individual sample, or run, for those sampling systems as applicable (other than 

SW-846 Method 0023A), the following convention is used to sum the results of multiple 

analyses: 

• In cases where all analytical results are hits (i.e., not "non-detects"), all analytical 

results will be summed. 

• In cases where all analytical results are "non-detects," all method detection limits will 

be summed, and the summed result reported as a maximum ("<"). 

• In cases where one or more analytical results are hits, and one or more analytical 

results are "non-detects," the hits and the "non-detects" will be summed and reported 

as a maximum ("<"). 

Example calculations of the HWC MACT emission hmits for PM, HCI/CI2, metals, 

dioxins/furans, and THC showing the calculations performed for a reported result are presented 

following the respective table. 

4.2.1 PM in Stack Gas 

Stack gas samples for determination of PM were collected according to EPA Method 5. 

These samples were analyzed gravimetrically for PM according to EPA Method 5, Two samples 

were recovered from each train for the determination of PM. They were as follows: 

• An acetone rinse of the probe and nozzle (PNR), and; 

• Filter (FILT). 

4-18 

VES017400 
The results for PM are presented in Table 4-14 for Unit 2, Table 4-15 for Unit 3, and 

Table 4-16 for Unit 4. The concentration of oxygen measured using CEMS and EPA Method 3A 

during the collection of the EPA Method 5 samples are shown in the tables, and the 

concentration of PM in the stack gas corrected to 7% O2 is shown. 

The analytical results for the determination of PM are included in Appendix G4. 

Table 4-14. Unit 2 - Results of PM in Stack Gas 

Date 

Time 

Run l 

10-8-13 

11:50-13:00 

Run 2 

10-9-13 

09:45-10:53 

Run 3 

10-10-13 

09:15-10:23 

Volume Collected (dscf) 40.815 42.356 41.278 

Oxygen Concentration (%) 11.56 11.23 11.48 

P M Found (mg) 

mm <0.5 <0.5 <0.5 

Probe and Nozzle Rinse 1.05 0.80 0.55 

Total <1,55 <1.3 <1.05 

Stack Gas Loading 

Particulate Matter (mg/dscf) <0.038 <0.031 <0.025 

Particulate Matter (mg/dscm) <1.3 <1.1 <0.90 

Particulate Matter (mg/dscm, corrected to 1% O J <2.0 <1.6 <1.3 

Particulate Matter (gr/dscf) <0.00059 <0.00047 <0.00039 

Particulate Matter (gr/dscf, corrected to 7% 02 ) 

<0.00087 <0.00068 <0.OO058 

Particulate Matter (gr/dscf, corrected to 7% 02 ) 

<0.00071 

4-19 

VES017401 
Particulate Matter HWC MACT Sample Calculation, gr/dscf @ 7% Oz 

Unit 2-Run 2 

PM Stack Concentration (mg/dscf) = 

PM Stack Concentration (mg/dscf) = 

Total IVIass Loading 

(mg) 

Sample Volume 

(dscf) 

<1.3 mg 

42.356 dscf 

= <0.031 

PM Stack Concentration (gr/dscf) 

PM Stack Concentration (gr/dscf) 

Stack 

Concentration X 

(mg/dscf) 

<0.031 mg/dscf X 

0.01543 mg 

1 grain 

0.01543 mg 

1 grain 

<0.00047 

PM Stack Concentration (gr/dscf @ 7% 02) 

PM Stack Concentration (gr/dscf @ 7% 02) 

Stack (21% -7%) 

Concentration X 

(gr/dscf) (21%-Meas.02) 

0.0006 gr/dscf X 

(21-7) 

(21-11.23) 

= 0.00068 

4-20 

VES017402 
Table 4-15. Unit 3 - Results of PM in Stack Gas 

Date 

Time 

Run l 

10-15-13 

13:16-14:25 

Run 2 

10-16-13 

11:15-12:25 

Run 3 1 

10-1713 

09:50-10:57 

Volume Collected (dscf) 41.229 42.461 41.921 

Oxygen Concentration (%) 12.87 13.38 11.74 1 

Particulate Matter Found (mg) | 

Filter 1.05 1.3 1.15 

Probe and Nozzle Rinse 1.95 1.7 2.5 

Total 3.00 3.00 3.65 

Stack Gas Loading - Front-Half Only 

Particulate Matter (mg/dscf) 0.0728 0.0707 0.0871 

Particulate Matter (mg/dscm) 2.57 2.50 3.07 

Particulate Matter (mg/dscm, corrected to 7% 02 ) 4.45 4.61 4.67 

Particulate Matter (gr/dscf) 0.00112 0.00109 0.00134 

Particulate Matter (gr/dscf, corrected to 7% 02 ) 

0.00194 0.00202 0.00204 

Particulate Matter (gr/dscf, corrected to 7% 02 ) 

0.00200 

4-21 

VES017403 
Table 4-16. Unit 4 - Results of PM in Stack Gas 

Date 

Time 

Run l 

10-23-13 

09:30-10:42 

Run 3 

10-25-13 

09:35-10:40 

Run 4 

10-25-13 

10:50-11:55 

Volume Collected (dscf) 38.181 39.691 36.759 

Oxygen Concentration (%) 12.22 12.48 12.11 

Particulate Matter Found (mg) 

Filter 1.95 0.5 <0,5 

Probe and Nozzle Rinse 2.2 2.35 2.4 

Front-Half Total 4.15 2.85 <2.9 

Stack Gas Loading - Front-Half Only 

Particulate Matter (mg/dscf) 0.109 0.0718 <0.079 

Particulate Matter (mg/dscm) 3.84 2.54 <2.8 

Particulate Matter (mg/dscm, corrected to 7% 02 ) 6.15 4.19 <4.4 

Particulate Matter (gr/dscf) 0.00168 0.00111 <0.0012 

Particulate Matter (gr/dscf, corrected to 1% 0 2 ) 

0.00269 0.00183 <0.0019 

Particulate Matter (gr/dscf, corrected to 1% 0 2 ) 

<0.0021 

4.2.2 HCI/CI? in Stack Gas 

Stack gas samples for determination of HC/CI2 were collected using a Modified Method 

26A. Samples were analyzed for the chloride ion using IC according to EPA Method 26A. Each 

train was recovered into multiple components for analysis as follows: 

• The first two impingers, which contained 0.1 N sulfuric acid (ACEDIMP); and 

• The fourth and fifth impingers, which contained 0.1N sodium hydroxide (ALKTMP). 

The results for HC1/C12 are presented in Table 4-17 for Unit 2, Table 4-18 for Unit 3, and 

Table 4-19 for Unit 4. The concentration of oxygen measured using CEMS and EPA Method 3A 

during the second half of the run is shown in the tables, and the concentration of HCI/CI2 

converted to chloride equivalents (CT) and corrected to 7% O2 is shown. 

The analytical results for the determination of HCI/CI2 are included in Appendix G4. 

4-22 

VES017404 
Table 4-17. Unit 2 - Results of HCI/CI2

 in Stack Gas 

Date 

Time 

Run l 

10-8-13 

15:40-16:40 

Run 3 

10-10-13 

12:30-13:30 

Run 5 

10-30-13 

12:45-13:45 

Volume Collected (dscf) 37.384 37.290 36.879 

Oxygen Concentration (%) 10.08 10.38 10.50 

Hydrogen Chloride 36,600 15,500 21,600 

Chlorine <160 <180 <180 

Concentration (mg/dscf) 

Hydrogen Chloride 0.979 0.416 0.586 

Chlorine <0.0043 <0.0048 <0.0049 

Concentration (chloride equivalents, ppmvd) 

Hydrogen Chloride 22.8 9.68 13.6 

Chlorine <0.10 <0.12 <0.12 

Total <23 <9.8 <14 

Concentration (chloride equivalents, ppmvd, corrected to 7% 02 ) 

Total <29 <13 <18 

Average <20 

4-23 

VES017405 
HCI/CI2

 HWC MACT Sample Calculation, ppmvd @ 7% 02 

Unit 2 - Run 2 

Sum of HCI Sample 

HCI Stack Concentration (mg/dscf) Fraction Values (ng) X 

HCI Stack Concentration (mg/dscf) 

HCI Stack Concentration 

(chloride equivalents ppmvd] 

HCI Stack Concentration 

(chloride equivalents ppmvd) 

Cl 2 Stack Concentration (mg/dscf) 

Cl 2 Stack Concentration (mg/dscf) 

CI2 Stack Concentration 

(chloride equivalents ppmvd) 

CI2 Stack Concentration 

(chloride equivalents ppmvd) 

Concentration (chloride equivalents 

ppmvd) 

Concentration (chloride equivalents 

ppmvd) 

Concentration (ppmvd @ 7% 02) 

Concentration (ppmvd @ 7% 02) 

Sample Volume (dscf) 

15,500 ug 

37.290 dscf 

Concentration (mg/dscf) 

28.317 L/cf 

24 L/g-mol 

Molecular Weight of HCI 

(g/g-mol) 

0.416 mg/dscf HCI 

28.317 L/cf 

24 L/g-mol 

36.5 g/g-mol 

Sum of Cl 2 Sample Fraction 

Values (ug) 

Sample Volume (dscf) 

<180 ug 

37.290 dscf 

Concentration (mg/dscf) 

28.317 L/cf 

24 L/g-mol 

[Molecular Weight of CI2 

(g/g-mol)] / 2 Chloride 

Equivalents 

. <0.0048 mg/dscf CI2 

28.317 L/cf 

24 L/g-mol 

35.5 g/g-mol 

HCI Stack Concentration 

(chloride equivalents 

ppmvd) 

9.68 ppmvd 

Concentration (chloride 

equivalents ppmvd) 

<9.80 ppmvd 

lmg 

10' ug 

lmg 

ltrug 

10° mg 

106 ppmvd 

l g 

lcFmg 

106 ppmvd 

10° ug 

l m g 

10'pg 

l g 

10° mg 

106 ppmvd 

l g 

10 mg 

10s ppmvd 

CI2 Stack 

Concentration 

(chloride 

equivalents 

ppmvd) 

<0.12 ppmvd 

(21% - 7%) 

(21% - Meas. 02) 

(21-7) 

(21-10.38) 

0.416 

= 9.68 

= <0.0048 

= <0.12 

<9.8 

= <13 

4-24 
Table 4-18. Unit 3 - Results of HCI/CI2

 in Stack Gas 

Date 

Time 

Run 2 

10-16-13 

14:00-15:00 

Run 3 

10-17-13 

12:30-13:33 

Run 4 

10-18-13 

09:35-10:35 

Volume Collected (dscf) 36.088 34.597 35.241 

Oxygen Concentration (%) 11.19 10.72 10.87 

Mass Found (ug) 

Hydrogen Chloride 4,740 4,720 1,810 

Chlorine <130 <120 <140 

Concentration (mg/dscf) 

Hydrogen Chloride 0.131 0.136 0.0514 

Chlorine <0.0036 <0.0035 <0.0040 

Concentration (chloride equivalents ppmvd) 

Hydrogen Chloride 3.06 3.18 1.20 

Chlorine <0.086 <0.083 <0.095 

Total <3.1 <3.3 <1.3 

Concentration (Chloride equivalents, ppmvd, corrected to 1% 02 ) 

Total <4.5 <4.4 <1.8 

Average <3.6 

Table 4-19. Unit 4 - Results of HCI/CI2 in Stack Gas 

Date 

Time 

Run l 

10/23/2013 

12:36-13:36 

Run 3 

10/24/2013 

12:35-13:35 

Run 4 

10/25/2013 

13:35-14:35 

Volume Collected (dscf) 39.935 39.264 37.034 

Oxygen Concentration (%) 12.27 12.37 12.00 

Mass Found (ug) 

Hydrogen Chloride 11,100 8,150 23,600 

Chlorine <130 <120 <140 

Concentration (mg/dscf) 

Hydrogen Chloride 0.278 0.208 0.637 

Chlorine <0.0033 <0.0031 <0.0038 

Concentration (chloride equivalents ppmvd) 

Hydrogen Chloride 6.47 4.84 14.8 

Chlorine <0.078 <0.073 <0.091 

Total <6.6 <4.9 . <15 

Concentration (Chloride equivalents, ppmvd, corrected to 7% O J 

Total <11 <8.0 <23 

Average <14 

4-25 

VES017407 
4.2.3 Metals in Stack Gas 

Metals were sampled in the stack gas using EPA Method 29. The samples were analyzed 

for the six (6) metals regulated by the HWC MACT. Five metals, arsenic, berylHum, cadmium, 

chromium, and lead) were analyzed using ICPES according to Method 6010B of SW-846. 

Mercury analysis was performed by cold vapor atomic absorption spectroscopy according to 

Method 7470A of SW-846. 

The Method 29 samphng trains were recovered to provide the following fractions: 

• Probe and nozzle rinse with 0.1 N nitric acid (PNR); 

• Filter (FELT); 

• Content and rinse of the acidified peroxide impingers with 0.1 N nitric acid (NPI); 

• Contents and rinse of the empty impinger with 0.1 N nitric acid (EER); 

• Contents and rinse of the acidified permanganate impingers with deionized water, 

0.1 N nitric acid, and permanganate solution (Perm); and; 

• Rinse' of the permanganate impingers with hydrochloric acid (HClRns). 

The analytical results for metals in the individual sample fractions are presented in Table 

4-20 for Unit 2, Table 4-22 for Unit 3, and Table 4-24 for Unit 4. The concentrations of the 

metals in the stack gas are presented in Table 4-21 for Unit 2, Table 4-23 for Unit 3, and Table 

4-25 for Unit 4. The concentration of oxygen measured using CEMS and EPA Method 3A 

during the second half of the test are shown in Tables 4-21,4-23, and 4-25, and the concentration 

of metals in the stack gas corrected to 7% O2 is shown. The concentrations of cadmium and lead 

are shown summed as SVM, and the concentrations of arsenic, beryllium, and chromium are 

shown summed as LVM . 

The analytical results for the determination of metals in the stack gas are included in 

Appendix G3. 

4-26 

VES017408 
Table 4-20. Unit 2 - Analytical Results of Metals in Stack Gas 

Run Analyte 

Nitric 

Acid PNR 

& Filter 

Nitric Acid & 

Hydrogen 

Peroxide 

Impingers 

Empty 

Impinger 

Rinse 

Potassium 

Permanganate 

Impinger 

HCI 

Rinse 

Total 

1 

Arsenic <0,37 <0.25 <0.25 <0.87 

1 

Beryllium <0.015 <0.015 <0.015 <0.045 

1 

Cadmium <0.021 <0.021 <0.021 <0.063 

1 

Chromium 3.3 0.78 0.33 4.41 

1 

Lead 1.3 0.35 <0.27 <1.9 

1 

Mercury <0.08 84.2 51.6 <31.136 1.1 <170 

3 

Arsenic <0.74 <0.25 <0.99 

3 

Beryllium <0.015 <0.015 <0.03 

3 

Cadmium <0.021 <0.021 <0.042 

3 

Chromium 2.5 0.55 3.05 

3 

Lead <1 0.27 <1.3 

3 

Mercury <0.08 182 0.57 0.5 17.2 <200 

5 

Arsenic 0.77 <0.25 <1 

5 

Beryllium 0.016 <0.015 <0.031 

5 

Cadmium <0.021 <0.021 <0.042 

5 

Chromium 2.3 0.81 3.11 

5 

Lead <1 0.66 <1.7 

5 

Mercury <0.08 142 <0.15 3.4 14.3 <160 

1

 The empty impinger was analyzed for As, Be, Cd, Cr, and Pb due to carry-over from the second nitric acid and 

hydrogen peroxide impinger. 

4-27 

VES017409 
Table 4-21. Unit 2 - Results of Metals in Stack Gas 

Run l Run 3 Run 5 

Date 10-8-13 10-10-13 10-30-13 

Time 15:40-18:43 12:30-15:10 12:45-15:32 Average 

Volume Collected (dscf) 84.952 78.951 79.607 

Average 

Oxygen Concentration (%) 10.08 10.38 10.50 

Average 

Mass Found (ng) 

Arsenic <0.87 <0.99 <1.0 

Beryllium <0.045 <0.030 <0.031 

Cadmium <0.063 <0.042 <0.042 

Chromium 4.41 3.05 3.11 

Lead <1.9 <1.3 <1.7 

Mercury <170 <200 <160 

Stack Gas Concentration (ug/dscf) 

Arsenic <0.010 <0.013 <0.013 <0.012 

Beryllium <0.00053 <0.00038 <0.00039 <0.00043 

Cadmium <0.00074 <0.00053 <0.00053 <0.00060 

Chromium 0.0519 0.0386 0.0391 0.0432 

Lead <0.023 <0.016 <0.021 <0.020 

Mercury <2.0 <2.5 <2.0 <2.2 

Stack Gas Concentration (ug/dscm) 

Arsenic <0.36 . <0.44 <0.45 <0.42 

Beryllium <0.019 <0.013 <0.014 <0.015 

Cadmium <0.026 <0.019 <0.019 <0.021 

Chromium 1.83 1.36 1.38 1.53 

Lead <0.80 <0.57 <0.74 <0.70 

Mercury <70 <90 <71 <77 

Stack Gas Concentration (ug/dscm, 7% O2) 

Arsenic <0.46 <0.59 <0.60 <0.55 

Beryllium <0.024 <0.018 <0.018 <0.020 

Cadmium <0.034 <0.025 <0.025 <0.028 

Chromium 2.35 1.80 1.84 2.00 

Lead <1.0 <0.75 <0.98 <0.92 

Mercury <90 <120 <95 <100 

S V M (Cd, Pb) <1.1 <0.78 <1.0 <0.95 

L V M (As, Be, Cr) <2.8 <2.4 <2.5 <2.6 

Mercury <90 <120 <95 <100 

4-28 

VES017410 
Table 4-22. Unit 3 - Analytical Results of Metals in Stack Gas 

Run Analyte 

Nitric 

Acid PNR 

& Filter 

Nitric Acid 

& Hydrogen 

Peroxide 

Impingers 

Empty 

Impinger 

Rinse 

Potassium 

Permanganate 

Impinger 

HCI 

Rinse 

Total 

2 

Arsenic <0.74 <0.25 <0.99 

2 

Beryllium <0.015 <0.015 <0.03 

2 

Cadmium <0.021 <0.021 <0.042 

2 

Chromium 10.6 0.56 11.2 

2 

Lead 28.6 <0.27 <29 

2 

Mercury <0.08 81 0.29 0.21 2.5 <84 

3 

Arsenic <0.74 <0.25 <0.99 

3 

Beryllium <0.015 <0.O15 <0.03 

3 

Cadmium <0.021 <0.021 <0.042 

3 

Chromium 11 0.79 11.8 

3 

Lead 19.4 <0.27 <20 

3 

Mercury <0.08 52.2 0.25 <0.048 2.6 <55 

4 

Arsenic <0.37 0.83 <1.2 

4 

Beryllium <0.015 <0.015 <0.03 

4 

Cadmium 0.91 <0.021 <0.93 

4 

Chromium 13.7 0.72 14.4 

4 

Lead 15.7 . 0.3 16 

4 

Mercury <0.08 54 0.18 0.16 12.8 <67 

4-29 

VES017411 
Table 4-23. Unit 3 - Results of Metals in Stack Gas 

Date 

Time 

Run 2 

10-16-13 

14:00-16:50 

Run 3 

10-17-13 

12:30-15:25 

Run 4 

10-18-13 

09:35-12:20 Average 

Volume Collected (dscf) 71.708 69.016 71.540 

Average 

Oxygen Concentration (%) 11.19 10.72 10.87 

Average 

Mass Found (ug) 

Arsenic <0.99 <0.99 <1.2 

Beryllium <0.030 <0.030 <0.030 

Cadmium <0.042 <0.042 <0.93 

Chromium 11.2 11,8 14.4 

Lead <29 <20 16.0 

Mercury <84 <55 <67 

Stack Gas Concentration (ug/dscf) 

Arsenic <0;014 <0.014 <0.017 <0.015 

Beryllium <0.00042 <0.00043 <0.00042 <0.00042 

Cadmium <0.00059 <0.00061 <0.013 <0.0047 

Chromium 0.156 0.171 0.202 0.176 

Lead <0.40 <0.29 0.224 <0.30 

Mercury <1.2 <0.80 <0.94 <0.97 

Stack Gas Concentration (ug/dscm) 

Arsenic <0.49 <0.51 <0.59 <0.53 

Beryllium <0.015 <0.015 <0.015 <0.015 

Cadmium <0.021 <0.021 <0.46 <0.17 

Chromium 5.50 6.03 7.12 6.22 

Lead <14 <10 7.90 <11 

Mercury <41 <28 <33 <34 

Stack Gas Concentration (ug/dscm, 7% 02 ) 

Arsenic <0.70 <0.69 <0.82 <0.74 

Beryllium <0.021 <0.021 <0.021 <0.021 

Cadmium <0.030 <0.029 <0.64 <0.23 

Chromium 7.87 8.23 9.87 8.66 

Lead <20 <14 10.9 <15 

Mercury <59 <39 <46 <48 

SVM(Cd,Pb) <20 <14 <12 <15 

L V M (As, Be, Cr) <8.6 <8.9 <11 <9.4 

Mercury <59 <39 <46 <48 

4-30 

VES017412 
Metals HWC MACT Sample Calculation, ug/dscm @ 7% 02 

Total Mass (ug) = Sum of Masses in Individual Sample Fractions 

(See Table 4-20) 

Unit 2 - Run 1, Arsenic 

Arsenic Mass (ug) 

Metals Stack Concentration [ug/dscf) 

Metals Stack Concentration (ug/dscf) = 

Sample Volume (dscf) 

<0.87 ng 

= <0.010 

84.952 dscf 

Metals Stack Concentration (pg/dscm) 

Arsenic Stack 

Concentration (pg/dscf) 

Metais Stack Concentration (ug/dscm) = <0.0l0 pg/dscf 

35.315 dscf 

1 dscm 

35.315 dscf 

1 dscm 

= <0.36 

Metals Stack Concentration (pg/dscm 

@7%02 ) 

Metals Stack Concentration (pg/dscm 

<§> 7% 02 ) 

Arsenic Stack 

Concentration (ug/dscm) 

<0.36 

(21% - 7%) 

(21% - Meas. 02 ) 

(21-7) 

(21-10.08) 

= <0.46 

4-31 

VES017413 
Table 4-24. Unit 4 - Analytical Results of Metals in Stack Gas 

Run Analyte 

Nitric 

Acid PNR 

& Filter 

Nitric Acid 

& Hydrogen 

Peroxide 

Impingers 

Empty 

Impinger 

Rinse 

Potassium 

Permanganate 

Impinger 

HCI 

Rinse 

Total 

1 

Arsenic 9.1 <0.25 <9.4 

1 

Beryllium <0.015 <0.015 <0.03 

1 

Cadmium 0.33 <0.021 <0.35 

1 

Chiomium 5.5 0.82 6.32 

1 

Lead 10.4 0.71 11.1 

1 

Mercury <0.08 9 <0.12 <0.048 0.22 <9.5 

2 

Arsenic 7.9 <0.25 <8.2 

2 

Beryllium <0.015 <0.015 <0.03 

2 

Cadmium 0.15 <0.021 <0.17 

2 

Chromium 4.2 0.66 4.86 

2 

Lead 5.4 0.42 5.82 

2 

Mercury <0.08 10.4 <0.12 <0.047 <0.082 <11 

3 

Arsenic 2.7 <0.25 <3 

3 

Beryllium <0.015 <0.015 <0.03 

3 

Cadmium 0.069 <0.021 <0.09 

3 

Chromium 6.9 0.62 7.52 

3 

Lead 14 0.44 14.4 

3 

Mercury <0.08 19.5 <0.12 <0.047 0.75 <20 

4-32 

VES017414 
Table 4-25. Unit 4 - Results of Metals in Stack Gas 

Date 

Time. 

Run 1 

10-23-13 

12:36-15:20 

Run 2 

10-24-13 

12:35-15:15 

Run 3 

10-25-13 

13:35-16:11 Average 

Volume Collected (dscf) 76.06S 76.498 76.846 

Average 

Oxygen Concentration (%) 12.27 12.37 12.00 

Average 

Mass Found (ug) 

Arsenic <9.4 <8.2 <3.0 

Beryllium <0.030 <0.O30 <0.030 

Cadmium <0.35 <0.17 <0.090 

Chromium 6.32 4.86 7.52 

Lead 11.1 5.82 14.4 

Mercury <9.5 <11 <20 

Stack Gas Concentration (ug/dscf) 

Arsenic <0.12 <0.11 <0.038 <0.089 

Beryllium <0.00039 <0.00039 <0.00039 <0.00039 

Cadmium <0.0046 <0.0022 <0.0012 <0.0027 

Chromium ,0.0831 0.0635 0.0979 0.0815 

Lead 0.146 0.0761 0.188 0.137 

Mercury • <0.12 <0.14 <0.27 <0.18 

Stack Gas Concentration (ng/dscm) 

Arsenic <4.3 <3.8 <1.4 <3.2 

Beryllium <0.014 <0.014 <0.014 <0.014 

Cadmium <0.16 <0.079 <0.041 <0.094 

Chromium 2.93 2.24 3.46 2.88 

Lead 5.16 2.69 6.64 4.83 

Mercury <4.4 <5.0 <9.4 <6.3 

Stack Gas Concentration (ug/dscm, 7% Oj) 

Arsenic <7.0 <6.1 <2.1 <5.1 

Beryllium <0.022 <0.023 <0.022 <0.022 

Cadmium <0.26 <0.13 <0.065 <0.15 

Chromium 4.73 3.66 5.40 4.59 

Lead 8.31 4.38 10.4 7.68 

Mercury <7.1 <8.1 <15 <10.0 

S V M (Cd, Pb) <8.6 <4.5 <10 <7.8 

L V M (As, Be, Cr) <12 <9.8 <7.5 <9.7 

Mercury <7.1 <8.1 <15 <10.0 

4-33 

VES017415 
4.2.4 Dioxins/Furans in Stack Gas 

Stack gas samples for determination of dioxins/furans were collected using SW-846 

Method 0023A and were analyzed using SW-846 Method 8290, a high resolution gas 

chromatography (HRGC) with high resolution mass spectroscopy (HRMS) analytical technique. 

The sampling train was recovered to provide the following fractions: 

• Combined probe and nozzle rinse with acetone, methylene chloride and toluene 

(PNR); 

• Filter (FILT); 

• Condenser rinse with acetone, methylene chloride, and toluene (CR); and 

• XAD sorbent (XAD). 

Components recovered from the train were combined as follows: 

• Combination of the filter and all the rinses between the nozzle and filter; and 

• Combination of the sorbent and all the rinses between the filter and sorbent. 

After sample cleanup and concentration procedures at the analytical laboratory, an aliquot 

of the front-half extracts (i.e., PNR and filter) is combined and analyzed using SW-846 Method 

8290 for dioxins/furans separate from the back-half components (i.e., condenser rinses, XAD 

sorbent). Dioxins/furans results are presented in Table 4-26 for Unit 2, Table 4-27 for Unit 3, and 

Table 4-28 for Unit 4. The concentration of oxygen measured using CEMS and EPA Method 3A 

during the second half of the run are shown in the tables, and the concentration of dioxins/furans 

corrected to 7% O2 is shown. 

The analytical results for the dioxins/furans analyses are included in Appendix G2. 

Results for dioxins/furans are converted to 2,3,7,8-tetrachlorodibenzo-dioxin toxicity equivalents 

(TEQ). Note that Section §1208(b)(l)(iii) of the HWC MACT states that non-detects (all results 

preceded by a "<") of dioxins/furans can be assumed to be at zero concentrations. Additionally, 

results followed by an "*" are denoted as Estimated Possible Maximum Concentrations, and are 

likewise not included in the calculation of total mass. 

4-34 

VES017416 
Table 4-26. Unit 2 - Results of Dioxins/Furans in Stack Gas 

Date 

Time 

Runl 

10-8-13 

15:40-18:55 

Run 3 

10-10-13 

12:30-15:40 

Run 5 

10-30-13 

12:45-16:02 

Volume Collected (dscf) 121.164 119.568 124.921 

Oxygen Concentration (%) 10.08 10.38 10.50 

Analyte Toxicity Equivalent Factor1 Mass Found (pg)* Analyte Toxicity Equivalent Factor1 

PNR/Filter XAD/Cond Sum PNK/FUter XAD/Cond Sum PNR/Filter XAD/Cond Sum 

2,3,7,8-TCDD 1 <2.93 <3.6 <6.5 <2.8 <3 <5.8 <4.6 <4.7 <9.3 

1,2,3,7,8-PcCDD 0.5 <1.4 7.2* <8.6 <1.6 6.9* <8.5 <2.1 23 * <25.1 

1,2,3,4,7,8-HxCDD 0.1 <1.2 7.3 <8.5 <1.2 5 <6.2 <1.7 20 <21.7 

1,2,3,6,7,8-HxCDD 0.1 <1.2 14 <15.2 <1.2 15 <16.2 <1.6 39 <40.6 

1,2,3,7,8,9-HxCDD 0.1 <1.2 12 <13.2 <1.2 17 <18.2 <1.7 48 <49.7 

1,2,3,4,6,7,8-HpCDD 0.01 3.3*" 82 85.3* 2.9 94 96.9 <2 250 <252 

OCDD 0.001 9.1 110 119.1 8.1 * 120 128.1 * 7.7 350 357.7 

2,3,7,8-TCDF 0.1 <1.7 9.5 <11.2 <2 9.3 <11.3 <3 49 <52 

1,2,3,7,8-PeCDF 0.05 <1.1 11* <I2.1 <1.1 12* <13.1 <2.1 72* <74.1 

2,3,4,7,8-PeCDF 0.5 <1.2 16 <17.2 <1.1 18 <19.1 <2.1 110* <112.1 

1,2,3,4,7,8-HxCDF 0.1 <0.69 41* <41.69 <0.82 46* <46.82 <1.1 190* <191.1 

1,2,3,6,7,8-HxCDF 0.1 <0.61 17* <17.61 <0.73 17* <17.73 <1 130* <131 

1,2,3,7,8,9-HxCDF 0.1 <0.75 2.9 <3.65 <0.89 2.1 <2.99 <1.2 12 <13.2 

2,3,4,6,7,8-HxCDF 0.1 <0.65 13* <13.65 <0.77 16* <16.77 <1.1 130 <131.1 

1,2,3,4,6,7,8-HpCDF 0.01 5* 79 84* 4 89 93 2.4* 780 782.4 * 

1,2,3,4,7,8,9-HpCDF 0.01 <1.7 10 <11.7 <1.8 12 <13.8 <1.7 110 <111.7 

OCDF 0.001 11* 110 121 * 11 98* 109* 9.7 630* 639.7 * 

Total Toxicity Equivalents 0.00910 14.5 14.5 0.0800 15.9 16.0 0.0174 41.6 41.6 

Concentration (ng TEO/dscf) 0.000120 0.000134 0.000333 

Concentration (ng TEQ/dscm) 0.00423 0.00472 0.0118 

Concentration (ng TEQ/dscm @ 1% 0,) 0.00543 0.00624 0.0157 

Average Concentration (ng TEQ/dscm ® 7% O J 0.00912 

1

 Toxic Equivalency Factor (TEF) as developed in: ^Interim Procedure for Estimating Risks Associated With Exposures to Mixtures of Chlorinated Diben2x>p-Dioxin and -Dibenzofurans (CDDs and 

CDFs) and 1989 Update", March 1989; Van den Berg, M., et al. ^Toxic Equivalency Factors (TEFs) for PCBs, PCDDs, PCDFs for Humans and "Wildlife" Environmental Health Perspectives, 

Volume 106, Number 12, December 1998., as directed by the Preamble to the HWC MACT. 

7

 Results followed by an are Estimated Maximum Possible Concentrations (EMPCs). 

In accordance with Section §1208(b)(l)(iii) of the HWC MACT, non-detects of dioxins/furans are assumed to be at 2;ero concentrations. 

In accordance with the USEPA Analytical Services Branch document National Functional Guidelines for Chlorinated Dibenzo-p-Dioxins and Chlorinated Dibenzofurans Data Review, EMPCs are 

not included in the calculation of TEFs. 

4-35 
Dioxins/Furans HWC MACT Sample Calculation 

ng TEQ/dscm @ 7% 02 (continued) 

Unit 2 - Run 1 

Sum of all TEQ 

Values (pg) " 9 

Stack Concentration (ng TEQ/dscf) = X 

Sample Volume .„ 3 

(dscf)

 1 0 P 9 

14.5pgTEQ 1 ng 

Stack Concentration (ng TEQ/dscf) = X , = 0.000120 

121.164 dscf Wpg 

Concentration 35.315 dscf 

Stack Concentration (ng TEQ/dscm) = X 

(ng TEQ/dscf) 1 dscm 

35.315 dscf 

Stack Concentration (ng TEQ/dscm) = 0.000120 X = 0.00423 

1 dscm 

Concentration f21%-7%) 

Stack Concentration (ng TEQ/dscm @ 7% 02 ) = X 

(ng TEQ/dscm) (21 % - Meas. 02 ) 

0.00423 

Stack Concentration (ng TEQ/dscm @ 7% 02 ) = X (21 - 7) = 0.00543 

(21-10.08) 

4-36 

VES017418 
Table 4-27. Unit 3 - Results of Dioxins/Furans in Stack Gas 

Date 

Time 

Run 2 

10-16-13 

14:00-17:20 

Run 3 

10-17-13 

12:30-15:55 

Run 4 

10-18-13 

09:35-12:50 

Volume Collected (dscf) 106303 102.724 102.624 

Oxygen Concentration (%) 11.19 10.72 10.87 

Analyte Toxicity Equivalent Factor1 Mass Found (pg)2 Analyte Toxicity Equivalent Factor1 

PNR/Filter XAD/Cond Sum PNR/Filter XAD/Cond Sum PNR/Filter XAD/Cond Sum 

2,3,7,8-TCDD 1 <0.14J 1.1 * <1.24 <0.7 3.8 * <4.5 <0.29 1.9* <2.19 

1,2,3,7,8-PeCDD 0.5 0.23 4.8* 5.03* 1.4* 12* 13.4* <0.15 5* <5.15 

1,2,3,4,7,8-HxCDD 0.1 <0.15 2.6 <2.75 <0.7 4.1 * <4.8 <0.42 3 <3.42 

1,2,3,6,7,8-HxCDD 0.1 0.22 ** 5.3 5.52* <0.67 11 * <11.67 <0.4 5.1 * <5.5 

1,2,3,7,8,9-HxCDD 0.1 0.41 * 5.6 6.01* 1.5* 12* 13.5* 1.4* 8.1 9.5* 

1,2,3,4,6,7,8-HpCDD 0.01 1.5* 29 30.5* 1.6* 57 58.6* 1.9 29 30.9 

OCDD 0.001 7.7* 37 44.7* 12 40 52 5.6* 28 33.6* 

2,3,7,8-TCDF 0.1 0.29 6.8* 7.09* <0.47 14 <14.47 <0.29 11 <11.29 

1,2,3,7,8-PeCDF 0.05 <0.11 9.1 * <9.21 <0.78 20* <20.78 <0.31 12* <12.31 

2,3,4,7,8-PeCDF 0.5 <o.u 19* <19.11 <0.78 36* <36.78 <0.31 27* <27.31 

1,2,3,4,7,8-HxCDF 0.1 0.48* 25* 25.48* 2.5* 61 * 63.5* 0.62* 26* 26.62* 

1,2,3,6,7,8-HxCDF 0.1 0.22* 11 * 11.22* <0.57 23* <23.57 0.29* 12* 12.29 * 

1,2,3,7,8,9-HxCDF 0.1 0.7 0.9* 1.6* 1.4* 2.4* 3.8* 0.56 * 1.2* 1.76* 

2,3,4,6,7,8-HxCDF 0.1 0.42* 11 * 11.42* 1.3* 21 * 22.3 * 0.55* 12* 12.55 * 

1,2,3,4,6,7,8-HpCDF 0.01 1.1 * 28 29.1 * <0.63 43 <43.63 0.78* 22 22.78 * 

1,2,3,4,7,8,9-HpCDF 0.01 0.48* 3.8* 4.28* 1.9* 5* 6.9* 0.66* 4.4 5.06* 

OCDF 0.001 3.8 8.5* 12.3* 5.8 9.7* 15.5* 4.7 5.7* 10.4* 

Total Toxicity Equivalents 0.218 1.96 2.17 . 0.0178 2.44 2.46 0.0237 2.79 2.82 

Concentration (ng TEQ/dscf) 0.0000205 0.0000239 0.0000274 

Concentration (ng TEQ/dscm) 0.000722 0.000845 0.000969 

Concentration (ng TEQ/dscm @ 7% 03 ) 0.00103 0.00115 0.00134 

Average Concentration (ng TEQ/dscm @ 7% O J 0.00118 

1

 Toxic Equivalency Factor (TEF) as developed in: "Interim Procedure for Estimating Risks Associated With Expasures to Mixtures of .Chlorinated Dibenzo-p-Dioxin and -Dibenzofurans (CDDs and 

CDFs) and 1989 Update", March 1989; Van den Berg, M , et al. "Toxic Equivalency Factors (TEFs) for PCBs, PCDDs, PCDFs for Humans and Wildlife" Environmental Health Perspectives, 

Volume 106, Number 12, December 1998., as directed by the Preamble to the HWC MACT. 

1

 Results followed by an "*" are Estimated Maximum Possible Concentrations (EMPCs). 

3

 In accordance with Section §1208(b)(l)(iii) of the HWC MACT, non-detects of dioxins/furans are assumed to be at zero concentrations. 

4

 In accordance with the USEPA Analytical Services Branch document National Functional Guidelines for Chlorinated Dibenzo-p-Dioxins and Chlorinated Dibenzofurans Data Review, EMPCs are 

not included in the calculation of TEFs. 

4-37 
Table 4-28. Unit 4 - Results of Dioxins/Furans in Stack Gas 

Date 

Time 

Runl 

10-23-13 

12:36-15:50 

Run 2 

10-24-13 

12:35-15:45 

Run 3 1 

10-25-13 

13:35-16:41 

Volume Collected (dscf) 110.791 112.803 115.284 

Oxygen Concentration (%) 12.27 12.37 12.00 1 

Analyte Toxicity Equivalent Factor1 Mass Found (pg)i | Analyte Toxicity Equivalent Factor1 

PNR/Filter XAD/Cond Sum PNR/Filter XAD/Cond Sum PNR/Filter XAD/Cond Sum 

2,3,7,8-TCDD 1 <4.9* 7* <11.9 <4.3' 9.5* <13.8 <2.5 8.2* <10.7 

1,2,3,7,8-PeCDD 0.5 <1.9 120* <121.9 <2.2 120* <122.2 2 120* 122* 

1,2,3,4,7,8-HxCDD 0.1 <2 230 <232 . 4.3 230 234.3 3.9* 230 233.9 * 

1,2,3,6,7,8-HxCDD 0.1 13 ** 990 1003* 9.4* 930 939.4 * 16 940 956 

1,2,3,7,8,9-HxCDD 0.1 10* 640 650* 12* 650 662* 12 630 642 

1,2,3,4,6,7,8-HpCDD 0.01 160 6100 6260 130 5500 5630 160 5900 6060 

OCDD 0.001 170 3600 3770 150 3500 3650 190 4100 4290 

2,3,7,8-TCDF 0.1 3.8 * 78 81.8* <2.9 70 <72.9 3.6* 70 73.6* 

1,2,3,7,8-PcCDF 0.05 <2 130* <132 <2.1 120* <122.1 <1.2 110* <111.2 

2,3,4,7,8-PeCDF 0.5 4.5* 550* 554.5 * <2.2 510* <512.2 4.7* 430* 434.7 * 

1,2,3,4,7,8-HxCDF 0.1 4.7* 570* 574.7 * 5 510* 515* 3.6* 260 263.6 * 

1,2,3,6,7,8-HxCDF 0.1 2.3* 310* 312.3 * 2.7* 290* 292.7 * 2.6* 300* 302.6 * 

' 1,2,3,7,8,9-HxCDF 0.1 <1.3 39 * <40.3 <1.4 38* <39.4 <0,82 43* <43.82 

2,3,4,6,7,8-HxCDF 0.1 7.9* 600* 607.9 * 6.9 510* 516.9 * 8.4* 560* 568.4 * 

1,2,3,4,6,7,8-HpCDF 0.01 15 760 775 10* 710 720* 17 720 737 

1,2,3,4,7,8,9-HpCDF 0.01 4.1 * 180 184.1 * 3.5* 160 163.5 * 5.9* 200 205.9 * 

OCDF 0.001 12* 140* 152* 10* 140 150* 11 * 160* 171 * 

Total Toxicity Equivalents 1.92 268 270 3.07 255 258 5.76 285 291 

Concentration (ng TEQ/dscf) 0.00243 0.00229 0.00252 

Concentration (ng TEQ/dscm) 0.0860 0.0809 0.0892 

Concentration (ng TEQ/dscm @ 7% O J 0.138 0.132 0.139 

Average Concentration (ng TEQ/dscm @ 7% 02 ) 0.137 

' Toxic Equivalency Factor (TEF) as developed in: "Interim Procedure for Estimating Risks Associated With Exposures to Mixtures of Chlorinated Dibenzo-p-Dioxin and -Dibenzofurans (CDDs and 

CDFs) and 1989 Update", March 1989; Van den Berg, M., et al. "Toxic Equivalency Factors (TEFs) for PCBs, PCDDs, PCDFs for Humans and Wildlife" Environmental Health Perspectives, 

Volume 106, Number 12, December 1998., as directed by the Preamble to the HWC MACT. 

2

 Results followed by an "*" are Estimated Maximum Possible Concentrations flEMPCs). 

3

 In accordance with Section §1208(b)(l)(iii) of the HWC MACT, non-detects of dioxins/furans are assumed to be at zero concentrations. 

* In accoidance with the USEPA Analytical Services Branch docnment National Functional Guidelines for Chlorinated Dibenzo-p-Dioxins and Chlorinated Dibenzofurans Data Review, EMPCs are 

not included in the calculation of TEFs. 

4-38 
4.2.5 THC in Stack Gas 

Total hydrocarbons (THC) were monitored in fhe stack gas using EPA Method 25A. 

THC was monitored throughout the second half of each run. Stack gas concentrations of THC 

are presented in Table 4-29 for Unit 2, Table 4-30 for Unit 3, and Table 4-31 for Unit 4. The 

concentration of oxygen measured using CEMS and EPA Method 3A during the second half of 

the run are shown in the tables, and the concentration of THC corrected to 7% O2 is shown. 

Table 4-29. Unit 2 - Results for THC in Stack Gas 

Date 

Time 

Run l 

10-8-13 

15:40-18:55 

Run 3 

10-10-13 

12:30 -15:40 

Run 5 

10-30-13 

12:45 -16:02 

T H C (ppmv, wet, as propane) 0.68 0.07 0.21 

Moisture (%) 44.7 45.3 42.9 

T H C (ppmv, dry, as propane) 1.2 0.13 0.37 

Oxygen Concentration (%) 10.08 10.38 10.50 

T H C (ppmv, dry, as propane, corrected to 7% 02 ) 1.6 0.18 0.49 

Average TH C (ppmv, dry, as propane, corrected to 7% 02 ) 0.75 

THC HWC MACT Sample Calculation 

ppmvd @ 7% O2 (continued) 

Unit 2 - Run 5 

1 

(l-(% Moisture/100%)) 

1 

= 0.37 

(1-(42.9%/100%)) 

(21% - 7%) 

(21% - Meas. 02) 

(21-7) 

= 0.49 

(21-10.50) 

THC Concentration 

THC Concentration (ppmvd) = X 

(ppmv) 

The Concentration (ppmvd) = 0.21 ppmv 

THC Concentration 

THC Concentration (ppmvd) = , „ X 

(ppmvd) 

THC Concentration (ppmvd) = 0.37 

4-39 
Table 4-30. Unit 3 - Results for THC in Stack Gas 

Run 2 Run 3 Run 4 

Date 10-16-13 10-17-13 10-18-13 

Time 14:00 -17:20 12:30 -15:55 09:35 -12:50 

T H C (ppmv, wet, as propane) 0.18 0.11 0.23 

Moisture (%) 42.9 44.4 43.7 

T H C (ppmv, dry, as propane) 0.31 0.19 0.41 

Oxygen Concentration (%) 11.19 10.72 10.87 

T H C (ppmv, dry, as propane, corrected to 7% 02 ) 0.44 0.26 0.57 

Average TH C (ppmv, dry, as propane, corrected to 7% 02 ) 0.43 

Table 4-31. Unit 4 - Results for THC in Stack Gas 

Run l Run 2 Run 3 

Date 10-23-13 10-24-13 10-25-13 

Time 12:36-15:50 12:35 -15:45 13:35 -16:41 

T H C (ppmv, wet, as propane) 0.19 0.23 0.33 

Moisture (%) 39.2 38.3 39.3 

T H C (ppmv, dry, as propane) 0.32 0.37 0.54 

Oxygen Concentration (%) 12.27 12.37 12.00 

T H C (ppmv, dry, as propane, corrected to 7% 0_) 0.51 0.60 0.85 

Average TH C (ppmv, dry, as propane, corrected to 7 % 02 ) 0.65 

4-40 

VES017422 
4.3 Chlorine, Ash, and Metals Feedrates 

This section presents calculated values using the analytical results presented previously, 

waste feedrates, and spiking feedrates. Feedrates are calculated for: 

• Total Chlorine/Chloride; 

• Ash; and 

• Metals. 

In those circumstances where a constituent is not detected in a waste feed (i.e., is not 

analyzed above the detection limit), the concentration of that parameter is treated as zero "0" in 

the calculation of the feedrate of that constituent that becomes an OPL for that parameter. 

4.3.1 Chlorine Feedrate 

Feedrate of total chlorine and chloride (i.e., chlorine) is an OPL for the emission 

standards for hydrogen chloride and chlorine gas (HCI/CI2) and for SVM and LVM . The feedrate 

of chlorine has been determined during both the HCI/CI2 and metals (i.e., SVM and LVM) stack 

sampling in the second part of each run. Table 4-32 presents the chlorine feedrates calculated 

during both the HCI/Q2 and metals stack sampling for Unit 2. Chlorine feedrates for Unit 3 are 

presented in Table 4-33, and chlorine feedrates for Unit 4 are presented in Table 4-34. 

For the calculation of the chlorine feedrate, the weight of the Containerized Solid Waste 

used to calculate the feedrates of chlorine was reduced by the weight of the box, and the spiking 

materials lead nitrate, hexachloroethane, and the solution of mercuric nitrate to determine the 

feedrate of Containerized Solid Waste that was analyzed for chlorine. 

4.3.2 Ash Feedrate 

Feedrate of ash is an OPL for the emission standard for particulate matter. The feedrate of 

ash has been determined during the particulate matter stack sampling in the first part of each run. 

Table 4-35 presents the ash feedrate calculated during stack sampling for particulate matter for 

Unit 2. Ash feedrates for Unit 3 are presented in Table 4-36, and ash feedrates for Unit 4 are 

presented in Table 4-37. 

4-41 

VES017423 
Table 4-32. Unit 2 - Chlorine Feedrate 

HCI/Cl, Stack Sampling Metals Stack Sampling 

Runl Run 3 RunS Runl Run 3 Run 5 

10-8-13 10-10-13 10-30-13 10-8-13 10-10-13 10-30-13 

15:40 -16:40 12:30-13:30 12:45 -13:45 15:40 -18:43 12:30 -15:10 12:45 -15:32 

Feedrate (lbs/hr) 1,422.1 1,500.9 1,451.9 1,474.6 1,513.3 1,396.5 

Low-Btu Liquid Waste Chlorine Concentration (mg/kg) 340 404 340 347 364 357 

Chlorine Feedrate (Ib/hr) 0.48 0.61 0.49 0.51 0.55 0.50 

Feedrate (lbs/hr) 1,370.8 1,098.7 1,200.0 1,289.1 1,098.9 1,164.6 

High-Bt High-Btu Liquid Waste Chlorine Concentration (mg/kg) 6,960 3,260 3,500 7,140 3,210 3,580 

Chlorine Feedrate (lb/hr) 9.54 3.58 4.20 9.20 3.53 4.17 

Feedrate (lbs/hr) 485.9 398.2 440.8 432.6 425.4 445.3 

Specialt Specialty Liquid Waste Chlorine Concentration (mg/kg) 105 130 106 159 124 92.4 

Chlorine Feedrate (Ib/hr) 0.05 0.05 0.05 0.07 0.05 • 0.04 

Feedrate (lbs/hr) 540.0 534.3. 535.7 • 547.0 536.1 542.4 

Containerized Solid Waste1 Chlorine Concentration (mg/kg) 184 345 346 167 499 396 

Chlorine Feedrate (lb/hr) 0.10 0.18 0.19 0.09 0.27 0.21 

Chlorine Spiking Chlorine Feedrate (lb/hr) 197.9 203.1 197.9 199.7 199.2 200.2 

Total Chlorine Feedrate (lb/hr) 208.0 207.5 202.8 209.6 203.6 205.1 

Average Chlorine Feedrate (lb/hr) 206.1 206.1 

The weight of the Containerized Solid Waste used to calculate the feedrates of chlorine and metals has been reduced by the weight of the box, and the spiking materials lead nitrate, 

hexachloroethane, and the solution of mercuric nitrate. 

4-42 
Table 4-33. Unit 3 - Chlorine Feedrate 

HC1/C12 Stack Samplmg Metals Stack Sampling 

Run 2 Run 3 Run 4 Run 2 Run 3 Run 4 

10-16-13 10-17-13 10-18-13 10-16-13 10-17-13 10-18-13 

14:00-15:00 12:30 -13:33 09:35 -10:35 14:00 -16:50 12:30 -15:25 09:35 -12:20 

I^)W-Btu Liquid Waste 

Feedrate (lbs/hr) 1,783.5 1,563.4 1,725.3 1,787.6 1,685.3 1,707.4 

I^)W-Bt I^)W-Btu Liquid Waste Chlorine Concentration (mg/kg) 563 409 , 388 419 429 408 

Chlorine Feedrate (lb/hr) 1.00 0.64 0.67 0.75 0.72 0.70 

High-Btu Liquid Waste 

Feedrate (lbs/hr) 977.2 1,151.9 1,163.5 1,043.9 1,166.5 1,197.7 

High-Bt High-Btu Liquid Waste Chlorine Concentration (mg/kg) 2,460 1,690 1,910 2,720 1,650 1,810 

Chlorine Feedrate (lb/hr) 2.40 1.95 2.22 2.84 1.92 2.17 

Specialty Liquid Waste 

Feedrate (lbs/hr) 177.5 407.7 248.8 202.9 350.0 244.8 

Specialt Specialty Liquid Waste Chlorine Concentration (mg/kg) 1,480 101 113 696 125 127 

Chlorine Feedrate (lb/hr) 0.26 0.04 0.03 0.14 0.04 0.03 

Containerized Solid Waste1 

Feedrate (lbs/hr) 550.6 539.6 516.5 541.9 536.5 523.9 

Containerized Solid Waste1 Containerized Solid Waste Chlorine Concentration (mg/kg) 482 115 382 195 271 255 1 

Chlorine Feedrate (Ib/hr) 0.27 0.06 0.20 0.11 0.15 0.13 

Chlorine Spiking Chlorine Feedrate (lb/hr) 203.1 203.3 197.9 200.3 201.7 200.7 

Total Chlorine Feedrate (lb/hr) 207.0 206.0 201.0 204.2 204.6 203.7 

Average Chlorine Feedrate (lb/hr) 204.7 204.2 

The weight of the Containerized Solid Waste used to calculate the feedrates of chlorine and metals has been reduced by the weight of the box, and the spiking materials lead nitrate, 

hexachloroethane, and the solution of mercuric nitrate. 

4-43 
Table 4-34. Unit 4 - Chlorine Feedrate 

HCI/C1? Stack Sampling Metals Stack Sampling 

Runl 

10-23-13 

12:36 -13:36 

Run 2 

10-24-13 

12:35-13:35 

Run 3 

10-25-13 

13:35 -14:35 

Runl 

10-23-13 

12:36 -15:20 

Run 2 

10-24-13 

12:35 -15:15 

Run 3 

10-25-13 

13:35 -16:11 

Low-Btu Liquid Waste to Kiln 

Feedrate (Ibs/hr) 1,943.7 ,_ 1,996.5 1,999.6 1,978.5 1,986.6 1,999.0 

Low-Btu Liquid Waste to Kiln Chlorine Concentration (rag/kg) 416 467 486 413. 393 532 

Chlorine Feedrate (lb/hr) 0.81 0.93 0.97 0.82 0.78 1.06 

High-Btu Liquid Waste to Kiln 

Feedrate (lbs/hr) 1,167.0 1,205.4 1,201.0 1,189.2 1,201.2 1,201.8 

High-Bt High-Btu Liquid Waste to Kiln Chlorine Concentration (mg/kg) 1,450 1,390 1,360 1,490 1,360 1,350 

Chlorine Feedrate (lb/hr) 1.69 1.68 1.63 1.77 1.63 1.62 

Liquid Waste to SCC 

Feedrate (lbs/hr) 1165.6 1203.1 1196.3 1186.2 1201.5 1196.2 

Liquid Waste to SCC Chlorine Concentration (mg/kg) 1,230 1,260 1,280 1,250 2,500 1,250 

Chlorine Feedrate (lb/hr) 1.43 1.52 1.53 1.48 3.00 1.50 

Containerized Solid Waste1 

Feedrate (lbs/hr) 515.3 51Z3 498.3 514.2 505.4 507.6 

Containerized Solid Waste1 Containerized Solid Waste Chlorine Concentration (mg/kg) 192 205 207 190 201 180 1 

Chlorine Feedrate (lb/hr) 0.10 0.11 0.10 0.10 0.10 0.09 

Bulk Solid Waste 

Feedrate (lbs/hr) 6,093.0 5,448.0 5,739.0 5,251.5 5,598.4 5,345.0 

Bulk Solid Waste Chlorine Concentration (mg/kg) 184 257 191 219 243 173 

Chlorine Feedrate (Ib/hr) 1.12 1.40 1.10 1.15 1.36 0.92 

Chlorine Spiking Chlorine Feedrate (Ib/hr) 197.9 197.9 197.9 200.0 197.2 200.3 

Total Chlorine Feedrate (lb/hr) 203.0 203.5 203.2 205.3 204.1 205.5 

Average Chlorine Feedrate (Ib/hr) 203.2 205.0 

' The weight of the Containerized Solid Waste used to calculate the feedrates of chlorine and metals has been reduced by the weight of the box, and the spiking materials lead nitrate, 

hexachloroethane, and the solution of mercuric nitrate 

4-44 
Table 4-35. Unit 2 - Ash Feedrate During the EPA Method 5 Stack Sampling for PM 

Run l 

10-8-13 

11:50 -13:00 

Run 2 

10-9-13 

09:45 -10:53 

Run 3 

10-10-13 

09:45 -10:53 

Low-Btu Liquid Waste 

Feedrate (lbs/hr) 1,277.2 1,353.3 1,288.3 

Low-Btu Liquid Waste 

Ash Concentration 

(mg/kg) 

Low-Btu Liquid Waste 3,140 2,960 3,250 

Ash Feedrate (lb/hr) 4.01 4.01 4.19 

High-Btu Liquid Waste 

Feedrate (lbs/hr) 1,000.2 997.7 998.5 

High-Btu Liquid Waste 

Ash Concentration 

(mg/kg) High-Btu Liquid Waste 1,350 1,010 1,180 

Ash Feedrate (lb/hr) 1.35 1.01 1.18 

Specialty Liquid Waste 

Feedrate (lbs/hr) 270.8 256.5 296.7 

Specialty Liquid Waste 

Ash Concentration 

(mg/kg) Specialty Liquid Waste 649 599 598 

Ash Feedrate (lb/hr) 0.18 0.15 0.18 

Containerized Sohd Waste 

Feedrate (lbs/hr) 734.9 738.4 746.0 

Containerized Sohd Waste 

Ash Concentration 

(mg/kg) Containerized Sohd Waste 675,000 688,000 655,000 

Ash Feedrate (lb/hr) 496.1 508.0 488.6 

Total Ash Feedrate (lb/hr) 501.6 513.2 494.2 

Average Ash Feedrate (lb/hr) 503.0 

4-45 

VES017427 
Table 4-36. Unit 3 - Ash Feedrate During the EPA Method 5 Stack Sampling for PM 

Run l 

10-15-13 

13:16 -14:25 

Run 2 

10-16-13 

11:15 -12:25 

Run 3 

10-17-13 

09:50 -10:57 

Low-Btu Liquid Waste 

Feedrate (lbs/hr) , 1,292.9 955.4 1,357.6 

Low-Btu Liquid Waste Ash Concentration (mg/kg) 3,090 4,070 3,650 

Ash Feedrate (lb/hr) 4.00 3.89 4.96 

High-Btu Liquid Waste 

Feedrate (lbs/hr) 847.9 818.2 875.3 

High-Bt High-Btu Liquid Waste Ash Concentration (mg/kg) 1,260 937 599 

Ash Feedrate (lb/hr) 1.07 0.77 0.52 

Specialty Liquid Waste 

Feedrate (lbs/hr) 307.9 269.1 457.4 

Specialt Specialty Liquid Waste Ash Concentration (mg/kg) 591 622 588 

Ash Feedrate (lb/hr) 0.18 0.17 0.27 

Containerized Solid Waste 

Feedrate (lbs/hr) 738.3 742.1 720.7 

Containerize Containerized Solid Waste Ash Concentration (mg/kg) 670,000 682,000 778,000 

Ash Feedrate (lb/hr) 494.7 506.1 560.7 

Total Ash Feedrate (lb/hr) 499.9 510.9 566.5 

Average Ash Feedrate (lb/hr) 525.8 

4-46 

VES017428 
Table 4-37. Unit 4 - Ash Feedrate During the EPA Method 5 Stack Sampling for PM 

Run l 

10-23-13 

09:30 -10:42 

Run 3 

10-25-13 

09:35 -10:40 

Run 4 

10-25-13 

10:50 -11:55 

Low-Btu Liquid Waste 

Feedrate (lbs/hr) 1,899.6 1,901.0 1,896.8 

Low-Btu Liquid Waste Ash Concentration (mg/kg) 2,790 3,320 3,250 

Ash Feedrate (lb/hr) 5.30 6.31 6.16 

High-Btu Liquid Waste 

Feedrate (lbs/hr) 1,101.4 1,098.1 1,108.9 

High-Bt High-Btu Liquid Waste Ash Concentration (mg/kg) 1,610 1,500 989 

Ash Feedrate (lb/hr) 1.77 1.65 1.10 

Liquid Waste to SCC 

Feedrate (lbs/hr) 1,095.6 1,100.7 1,102.8 

Liquid Waste to SCC Ash Concentration (mg/kg) 744 787 743 

Ash Feedrate (lb/hr) 0.82 0.87 0.82 

Containerized Solid Waste 

Feedrate (lbs/hr) 565.8 568.6 553.8 

Containerized Solid Waste Ash Concentration (mg/kg) Containerized Solid Waste 758,000 724,000 771,000 

Ash Feedrate (lb/hr) 428.9 411.7 427.0 

Bulk Solid Waste 

Feedrate (Ibs/hr) 6,286.7 6,408.0 5,992.6 

Bulk Solid Waste Ash Concentration (mg/kg) 695,000 689,000 710,000 

Ash Feedrate (lb/hr) 4,369.2 4,415.1 4,254.8 

Total Ash Feedrate (lb/hr) 4,806.0 4,835.6 4,689.9 

Average Ash Feedrate (lb/hr) 4,777.2 

4-47 

VES017429 
4.3.3 Metals Feedrates 

Feedrates ofthe metals regulated by the HWC MACT (As, Be, Cd, Cr, Pb, and Hg) are 

OPLs for the emission standards for SVM, LVM, and mercury. The feedrates of these six metals 

have been determined during the metals stack sampling in the second part of each run. The stack 

gas concentrations of all six of the HWC MACT metals are determined by EPA Method 29. 

Table 4-38 presents the feedrates of these metals calculated during stack sampling for metals for 

Unit 2. Metals feedrates for Unit 3 are presented in Table 4-40, and metals feedrates for Unit 4 

are presented in Table 4-42. 

The OPLs for metals feedrates are total LV M feedrate (i.e., total and pumpable) and 

pumpable LV M for the emission standard for LV M (i.e., arsenic, beryllium, and chromium); 

(Total) SVM feedrate (i.e., total and pumpable) for the emission standard for SVM (i.e., 

cadmium and lead); and (Total) mercury feedrate (i.e., total and pumpable) for the emission 

standard for mercury. Table 4-39 presents the feedrates of total LV M and pumpable LVM, total 

SVM, and mercury calculated during stack samphng for metals for Umt 2. Total LV M and 

pumpable LVM , total SVM, and mercury feedrates for Unit 3 are presented in Table 4-41, and 

total LV M and pumpable LVM, total SVM, and mercury feedrates for Unit 4 are presented in 

table 4-43. 

For the calculation of the metals feedrates, the weight of the containerized solid waste 

used to calculate the feedrates of metals was reduced by the weight of the box, and the spiking 

materials lead nitrate, hexachloroethane, and the solution of mercuric nitrate to determine the 

feedrate of containerized solid waste that was analyzed for the metals As, Be, Cd, Cr, Pb, and 

Hg. 

4-48 

VES017430 
Table 4-38. Unit 2 - Metals Feedrates 

Runl Run 3 Run 5 

10-8-13 10-10-13 10-30-13 

15:40-18:43 12:30-15:10 12:45 -15:32 

Feedrate (lbs/hr) 1,475 1,513 1,396 

Arsenic Cone (mg/kg) 2.7 3.2 2.1 

Beryllium Cone (mg/kg) <0.097 <0.096 <0.097 

Cadmium Cone (mg/kg) 7.2 9 7 

Chromium Cone (mg/kg) 0.8 0.88 0.74 

Low-Btu Liquid Waste 

Lead Cone (mg/kg) 1.1 1.7 1.1 

Low-Btu Liquid Waste Mercury Cone (mg/kg 0.021 0.042 0.052 Liquid Waste 

Arsenic Feedrate (lbs/hr) 0.00398 0.00484 0.00293 

Low-Btu Liquid Waste 

Beryllium Feedrate (lbs/hr) <0.00014 <0.00015 <0.00014 

Low-Btu Liquid Waste 

Cadmium Feedrate (lbs/hr) 0.0106 0.0136 0.00978 

Low-Btu Liquid Waste 

Chromium Feedrate (lbs/hr) 0.00118 0.00133 0.00103 

Low-Btu Liquid Waste 

Lead Feedrate (lbs/hr) 0.00162 0.00257 0.00154 

Low-Btu Liquid Waste 

Mercury Feedrate (lbs/hr) 0.0000310 0.0000636 0.0000726 

High-Btu Liquid Waste 

Feedrate (lbs/hr) 1,289 1,099 1,165 

High-Btu Liquid Waste 

Arsenic Cone (mg/kg) 8.3 2.8 <0.32 

High-Btu Liquid Waste 

Beryllium Cone (mg/kg) <0.096 <0.099 <0.096 

High-Btu Liquid Waste 

Cadmium Cone (mg/kg) <0.076 <0.078 <0.076 

High-Btu Liquid Waste 

Chromium Cone (mg/kg) 0.26 <0.22 <0.21 

High-Btu Liquid Waste 

Lead Cone (mg/kg) 1 0.67 6.7 

High-Bt High-Btu Liquid Waste Mercury Cone (mg/kg 0.026 0.021 0.096 Liquid Waste 

Arsenic Feedrate (lbs/hr) 0.0107 0.00308 <0.00037 

High-Btu Liquid Waste 

Beryllium Feedrate (lbs/hr) <0.00012 <0.00011 <0.00011 

High-Btu Liquid Waste 

Cadmium Feedrate (lbs/hr) <0.000098 <0.000086 <0.000089 

High-Btu Liquid Waste 

Chromium Feedrate (lbs/hr) 0.000335 <0.00024 <0.00024 

High-Btu Liquid Waste 

Lead Feedrate (lbs/hr) 0.00129 0.000736 0.00780 

High-Btu Liquid Waste 

Mercury Feedrate (lbs/hr) 0.0000335 0.0000231 0.000112 

Specialty Liquid Waste 

Feedrate (lbs/hr) 433 425 445 

Specialty Liquid Waste 

Arsenic Cone (mg/kg) <0.32 <0.3 <0.31 

Specialty Liquid Waste 

Beryllium Cone (mg/kg) <0.096 <0.092 <0.093 

Specialty Liquid Waste 

Cadmium Cone (mg/kg) <0.076 <0.073 <0.073 

Specialty Liquid Waste 

Chromium Cone (mg/kg) <0.21 <0.2 <0.2 

Specialty Liquid Waste 

Lead Cone (mg/kg) <0.27 <0.26 <0.26 

Specialt Specialty Liquid Waste Mercury Cone (mg/kg <0.009 <0.0086 <0.0099 

Arsenic Feedrate (lbs/hr) <0.00014 <0.00013 <0.000l4 

Specialty Liquid Waste 

Beryllium Feedrate (Ibs/hr) <0.000042 <0.000039 <0.000041 

Specialty Liquid Waste 

Cadmium Feedrate (lbs/hr) <0.000033 <0.000031 <0.000033 

Specialty Liquid Waste 

Chromium Feedrate (lbs/hr) <0.000091 <0.000085 <0.000089 

Specialty Liquid Waste 

Lead Feedrate (lbs/hr) <0.00012 <0.00011 <0.00012 

Specialty Liquid Waste 

Mercury Feedrate (lbs/hr) <0.0000039 <0.0000037 <0.0000044 

Containerized Solid Waste1 

Feedrate (lbs/hr) 547 536 542 

Containerized Solid Waste1 

Arsenic Cone (mg/kg) 8.8 7.5 8.8 

Containerized Solid Waste1 

Beryllium Cone (mg/kg) 0.48 0.61 0.73 

Containerized Solid Waste1 

Cadmium Cone (mg/kg) 0.082 <0.077 0.084 

Containerized Solid Waste1 

Chromium Cone (mg/kg) 12.8 19.3 16.7 

Containerized Solid Waste1 

Lead Cone (trig/kg) 11.6 11.7 13.5 

Containerized Solid Waste Containerized Solid Waste1 Mercury Cone (mg/kg 0.045 0.022 0.016 1 

Arsenic Feedrate (lbs/hr) 0.00481 0.00402 0.00477 

Containerized Solid Waste1 

Beryllium Feedrate (lbs/hr) 0.000263 0.000327 0.000396 

Containerized Solid Waste1 

Cadmium Feedrate (lbs/hr) 0.0000449 <0.000041 0.0000456 

Containerized Solid Waste1 

Chromium Feedrate (lbs/hr) 0.00700 0.0103 0.00906 

Containerized Solid Waste1 

Lead Feedrate (lbs/hr) 0.00635 0.00627 0.00732 

Containerized Solid Waste1 

Mercury Feedrate (lbs/hr) 0.0000246 0.0000118 0.00000868 

4-49 
Table 4-38. (continued) Unit 2 - Metals Feedrates 

Runl 

10-8-13 

15:40 -18:43 

Run 3 

10-10-13 

12:30 -15:10 

Run 5 

10-30-13 

12:45 -15:32 

Spiking 

Arsenic Feedrate (lbs/hr) 0 0 0 

Spiking 

Beryllium Feedrate (lbs/tir) 0 0 0 

Spiking 

Cadmium Feedrate (lbs/hr) 0 0 0 

Spiking Chromium Feedrate (lbs/hr) 45.8 47.3 45.8 Spiking 

Lead Feedrate (lbs/hr) 61.9 61.7 62.0 

Spiking 

Mercury Feedrate (lbs/hr) 0.00196 0.00196 0.00204 

Pumpable Feedrate2 

Arsenic Feedrate (lbs/hr) 0.0147 0.00792 0.00293 

Pumpable Feedrate2 

Beryllium Feedrate (lbs/hr) 0 0 0 

Pumpable Feedrate2 Cadmium Feedrate (lbs/hr) 0.0106 0.0136 0.00978 Pumpable Feedrate2 

Chromium Feedrate (lbs/hr) 45.8 47.3 45.9 Pumpable Feedrate2 

Lead Feedrate (lbs/hr) 0.00291 0.00331 0.00934 

Pumpable Feedrate2 

Mercuiy Feedrate (lbs/hr) 0.0000645 0.0000866 0.000184 

Total Feedrate2 

Arsenic Feedrate (lbs/hr) 0.0195 0.0119 0.00771 

Total Feedrate2 

Beryllium Feedrate (lbs/hr) 0.000263 0.000327 0.000396 

Total Feedrate2 Cadmium Feedrate (lbs/hr) 0.0107 0.0136 0.00982 Total Feedrate2 

Chromium Feedrate (lbs/hr) 45.8 47.3 45.9 Total Feedrate2 

Lead Feedrate (Ibs/hr) 61.9 61.7 62.0 

Total Feedrate2 

Mercury Feedrate (lbs/hr) 0.00205 0.00206 0.00224 

1

 The weight of the Containerized Solid Waste used to calculate die feedrates of chlorine and metals has been reduced by 

the weight ofthe box, and the spiking materials lead nitrate, hexachloroethane, and the solution of mercuric nitrate. 

2

 Non-detects treated as a zero "0". 

4-50 
Table 4-39. Unit 2 - HWC MACT Metals Feedrates 

Units 

Runl 

10-8-13 

13:40 -18:43 

Run 3 

10-10-13 

12:30 -15:10 

Run 5 

10-30-13 

12:45 -15:32 

Average 

Arsenic (Total) lb/hr 0.0195 0.0119 0.0077 0.0130 

Beryllium (Total) lb/hr 0.00026 0.00033 0.00040 0.00033 

Chromium (Total) lb/hr 45.8 47.3 45.9 46.3 

Total LV M (Arsenic, Beryllium, 

Chromium) lb/hr 45.9 47.3 45.9 46.3 

Arsenic (Pumpable) Ib/hr 0.0147 0.0079 0.0029 0.0085 

Beryllium (Pumpable) lb/hr 0.0000 0.0000 0.0000 0.0000 

Chromium (Pumpable) lb/hr 45.8 47.3 45.9 46.3 

Pumpable LV M (Arsenic, Beryllium, 

Chromium) lb/hr 45.9 47.3 45.9 46.3 

Cadmium Ib/hr 0.0107 0.0136 0.0098 0.0114 

Lead lb/h'r 61.9 61.7 62.0 61.9 

Total SVM (Cadmium, Lead) lb/hr 61.9 61.7 62.0 61.9 

Mercury lb/hr 0.00205 0.00206 0.00224 0.00212 

4-51 

VES017433 
Table 4-40. Unit 3 - Metals Feedrates 

Run 2 Run 3 Run 4 

10-16-13 10-17-13 10-18-13 

14:00 • 16:50 12:30 -15:25 09:35 -12:20 

Feedrate (lbs/hr) 1,788 ' 1,685 1,707 

Arsenic Cone (mg/kg) 4.8 3.2 3.3 

Beryllium Cone (mg/kg) <0.096 <0.097 <0.096 

Cadmium Cone (mg/kg) 15.2 9.4 11.3 

Chromium Cone (mg/kg) 1.3 0.87 0.97 

Lead Cone (mg/kg) 3.1 1.9 1.9 

Low-Btu Liquid Waste Mercury Cone (mg/kg 0.065 0.049 0.08 

Arsenic Feedrate (lbs/hr) 0.00858 0.00539 0.00563 

Beryllium Feedrate (lbs/hr) <0.00017 <0.00016 <0.00016 

Cadmium Feedrate (lbs/hr) 0.0272 0.0158 0.0193 

Chromium Feedrate (lbs/hr) 0.00232 0.00147 0.00166 

Lead Feedrate (lbs/hr) 0.00554 0.00320 0.00324 

Mercury Feedrate (lbs/hr) 0.000116 0.0000826 0.000137 

Feedrate (lbs/hr) 1,044 1,167 1,198 

Arsenic Cone (mg/kg) 12.4 1.7 2.4 

Beryllium Cone (mg/kg) <0.095 <0.1 <0.096 

Cadmium Cone (mg/kg) <0.075 <0.079 <0.076 

Chromium Cone (mg/kg) <021 <0.22 <0.21 

Lead Cone (mg/kg) 1.8 1 1.3 

High-Bt High-Btu Liquid Waste Mercury Cone (mg/kg 0.027 0.029 0.022 

Arsenic Feedrate (lbs/hr) 0.0129 0,00198 0.00287 

Beryllium Feedrate (lbs/hr) <0.000099 <0.00012 <0.00011 

Cadmium Feedrate (lbs/hr) <0.000078 <0.000092 <0.000091 

Chromium Feedrate (lbs/hr) <0.00022 <0.00026 <O.00O25 

Lead Feedrate (lbs/hr) 0.00188 0.00117 0.00156 

Mercury Feedrate (lbs/hr) 0.0000282 0.0000338 0.000O263 

Feedrate (lbs/hr) 203 350 245 

Arsenic Cone (mg/kg) <0.32 <0.32 <0.33 

Beryllium Cone (mg/kg) <0.098 <0.096 <0.099 

Cadmium Cone (mg/kg) <0.077 <0.076 <0.078 

Chromium Cone (mg/kg) <0.22 <0.21 <0.22 

Lead Cone (mg/kg) <0.27 <0.27 <0.28 

Specialt Specialty Liquid Waste Mercury Cone (mg/kg <0.0088 <0.0094 <0.0099 

Arsenic Feedrate (lbs/hr) <O.O00O65 <0.00011 <0.000081 

Beryllium Feedrate (lbs/hr) <0.000020 <0.000034 <0.000024 

Cadmium Feedrate (lbs/hr) <0.000016 <O.O00O27 <0.000019 

Chromium Feedrate (lbs/hr) <0.000045 <O.O00073 <0.000054 

Lead Feedrate (lbs/hr) <0.000055 <0.000094 <0.000069 

Mercury Feedrate (lbs/hr) <0.0000018 <0.0000033 <0.0000024 

Feedrate (lbs/hr) 542 537 524 

Arsenic Cone (mg/kg) 7.5 6.4 8.4 

Beryllium Cone (mg/kg) 0.58 0.55 0.79 

Cadmium Cone (mg/kg) <0.071 <0.076 <0.071 

Chromium Cone (mg/kg) 13.6 13.7 18.9 

Lead Cone (mg/kg) 11.1 10.7 14.1 

Containerized Solid Waste1 Mercury Cone (mg/kg 0.028 0.028 0.026 

Arsenic Feedrate (lbs/hr) 0.00406 0.00343 0.00440 

Beryllium Feedrate (lbs/hr) 0.000314 0.000295 0.000414 

Cadmium Feedrate (lbs/hr) <0.000038 <0.000041 <0.000037 

Chromium Feedrate (lbs/hr) 0.00737 0.00735 0.00990 

Lead Feedrate (lbs/hr) 0.00601 0.00574 0.007393 

Mercury Feedrate (lbs/hr) 0.0000152 0.0000150 0.0000136 

4-52 
Table 4-40. (continued) Unit 3 - Metals Feedrates 

Run 2 Ron 3 Run 4 

10-16-13 10-17-13 10-18-13 

14:00-16:50 12:30 -15:25 09:35 -12:20 

Spiking 

Arsenic Feedrate (lbs/hr) 0 0 0 

Spiking 

Beryllium Feedrate (lbs/hr) 0 0 0 

Spiking 

Cadmium Feedrate (lbs/hr) 0 0 0 Spiking Chromium Feedrate (lbs/hr) 46.3 46.1 45.7 

Spiking 

Lead Feedrate (lbs/hr) 62.1 62.5 62.2 

Spiking 

Mercury Feedrate {lbs/hr) 0.00204 0.00200 0.00209 

Pumpable Feedrate2 

Arsenic Feedrate (lbs/hr) 0.0215 0.00738 0.00851 

Pumpable Feedrate2 

Beryllium Feedrate (lbs/hr) 0 0 0 

Pumpable Feedrate2 Cadmium Feedrate (lbs/hr) 0.0272 0.0158 0.0193 Pumpable Feedrate2 

Chromium Feedrate (lbs/hr) 46.3 46.1 45.7 Pumpable Feedrate2 

Lead Feedrate (lbs/hr) 0.00742 0.00437 0.00480 

Pumpable Feedrate2 

Mercury Feedrate (lbs/hr) 0.000144 0.000116 0.000163 

Total Feedrate2 

Arsenic Feedrate (lbs/hr) 0.0256 0.0108 0.0129 

Total Feedrate2 

Beryllium Feedrate (lbs/hr) 0.000314 0.000295 0.000414 

Total Feedrate2 Cadmium Feedrate (lbs/hr) 0.0272 0.0158 0.0193 Total Feedrate2 

Chromium Feedrate (lbs/hr) 46.3 46.1 45.7 Total Feedrate2 

Lead Feedrate (lbs/hr) 62.1 62.5 62.2 

Mercury Feedrate (lbs/hr) 0.00220 0.00213 0.00226 

1

 The weight of fhe Containerized Solid Waste used to calculate the feedrates of chlorine and metals has been reduced by the 

weight of fhe box, and fhe spiking materials lead nitrate, hexachloroethane, and fhe solution of mercuric nitrate. 

2

 Non-detects treated as a zero "0". 

Table 4-41. Unit 3 - HWC MACT Metals Feedrates 

Units 

Run 2 

10-16-13 

14:00 -16:50 

Run 3 

10-17-13 

12:30 -15:25 

Run 4 

10-18-13 

09:35 -12:20 

Average 

Arsenic (Total) lb/hr 0.0256 0.0108 0.0129 0.0164 

Beryllium (Total) lb/hr 0.00031 0.00030 0.00041 0.00034 

Chromium (Total) lb/hr 46.3 46.1 45.7 46.0 

Total LV M (Arsenic, Beryllium, Chromium) lb/hr 46.3 46.1 45.8 46.1 

Arsenic (Pumpable) lb/hr 0.02152 0.00738 0.00851 0.01247 

Beryllium (Pumpable) lb/hr 0.00000 0.00000 0.00000 0.000000 

Chromium (Pumpable) lb/hr 46.3 46.1 45.7 46.0 

Pompable LV M (Arsenic, Beryllium, Chromium) lb/hr 46.3 46.1 45.7 46.0 

Cadmium lb/hr 0.02717 0.01584 0.01929 0.02077 

Lead lb/hr 62.1 62.5 62.2 62.3 

Total SVM (Cadmium, Lead) lb/hr 62.1 62.5 62.2 62.3 

Mercury lb/hr 0.00220 0.00213 0.00226 0.00220 

4-53 

VES017435 
Table 4-42. Unit 4 - Metals Feedrates 

Runl Run 2 Run 3 

10-23-13 10-24-13 10-25-13 

12:36 -15:20 12:35-15:15 13:35-16:11 

Feedrate (lbs/hr) 1,979 1,987 1,999 

Arsenic Cone (mg/kg) 5.5 4.9 2.9 

Beryllium Cone (mg/kg) <0.094 <0.098 <0.096 

Cadmium Cone (mg/kg) 13.6 12.1 9.4 

Chromium Cone (mg/kg) 1.3 1.2 0.84 

Lead Cone (mg/kg) 3.3 . 2.9 1.6 

Low-Btu Liquid Waste to Kiln Mercury Cone (mg/kg 0.11 0.14 0.11 

Arsenic Feedrate (lbs/hr) 0.0109 0.00973 0.00580 

Beryllium Feedrate (lbs/hr) <0.00019 •C0.00019 <0.O0019 

Cadmium Feedrate (lbs/hr) 0.0269 0.0240 0.0188 

Chromium Feedrate (lbs/hr) 0.00257 0.00238 0.00168 

Lead Feedrate (lbs/hr) 0.00653 0.00576 0.00320 

Mercury Feedrate (lbs/hr) 0.000218 0.000278 0.000220 

Feedrate (lbs/hr) 1,189 1,201 1,202 

Arsenic Cone (mg/kg) 1.4 0.37 <0.32 

Beryllium Cone (mg/kg) <0.099 <0.093 <0.097 

Cadmium Cone (mg/kg) 0.12 <0.073 <0.077 

Chromium Cone (mg/kg) 0.24 <0.2 <0.21 

Lead Cone (mg/kg) 1.1 . 0.4 <0.27 

High-Bt High-Btu Liquid Waste to Kiln Mercury Cone (mg/kg 0.048 0.021 0.018 

Arsenic Feedrate (lbs/hr) 0.00166 0.000444 <O.OO038 

Beryllium Feedrate (lbs/hr) <0.00012 <0.00011 <0.00012 

Cadmium Feedrate (lbs/hr) 0.000143 <O.O0O088 <0.000093 

Chromium Feedrate (lbs/hr) 0.000285 <0.00024 <0.00025 

Lead Feedrate (lbs/hr) 0.00131 0.000480 <0.00032 

Mercury Feedrate (lbs/hr) 0.0000571 0.0000252 0.0000216 

Feedrate (lbs/hr) 1,186 1,202 1,196 

Arsenic Cone (mg/kg) <0.3 <0.32 <0.31 

Beryllium Cone (mg/kg) <0.092 <0.098 <0.094 

Cadmium Cone (mg/kg) <0.073 <0.077 <0.074 

Chromium Cone (mg/kg) <0.2 <0.22 <0.21 

Lead Cone (mg/kg) 0.26 <0.27 <0.26 

Liquid Waste to SCC Mercury Cone (mg/kg 0.017 0.019 0.017 

Arsenic Feedrate (lbs/hr) <0.00036 <0.00038 <0.00037 

Beryllium Feedrate (lbs/hr) <0.00011 <0.00012 <0.00011 

Cadmium Feedrate (lbs/hr) <0.000087 <0.000093 <O.O0O089 

Chromium Feedrate (Ibs/hr) <0.00024 <0.00026 <0.00025 

Lead Feedrate (lbs/hr) 0.O00308 <0.00032 <0.00031 

Mercury Feedrate (lbs/hr) 0.0000202 0.0000228 0.0000203 

Feedrate (lbs/hr) 514 505 508 

Arsenic Cone (mg/kg) 2.4 2 2.1 

Beryllium Cone (mg/kg) 0.13 0.16 <0.1 

Cadmium Cone (mg/kg) 0.46 0.43 0.45 

Chromium Cone (mg/kg) 45.2 58.9 35.1 

Lead Cone (mg/kg) 35.9 212 25.4 

Containerized Solid Waste1 Mercury Cone (mg/kg 0.18 0.24 0.26 

Arsenic Feedrate (lbs/hr) 0.00123 0.00101 0.00107 

Beryllium Feedrate (lbs/hr) 0.0000668 0.0000809 <0.000051 

Cadmium Feedrate (lbs/hr) 0.000237 0.000217 0.000228 

Chromium Feedrate (lbs/hr) 0.0232 0.0298 0.0178 

Lead Feedrate (lbs/hr) 0.0185 O.107 0.0129 

Mercury Feedrate (lbs/hr) 0.0000926 0.000121 0.000132 

4-54 

VES017436 
Table 4-42. (continued) Unit 4 - Metals Feedrates 

Sunt 

10-23-13 

12:36 -15:20 

Run 2 

10-24-13 

12:35-15:15 

Run 3 

10-25-13 

13:35 -16:11 

Bulk Solid Waste 

Feedrate (lbs/hr) 5251 5598 5345 

Bulk Solid Waste 

Arsenic Cone (mg/kg) 2.2 3 2.2 

Bulk Solid Waste 

Beryllium Cone (mg/kg) 0.21 0.28 0.26 

Bulk Solid Waste 

Cadmium Cone (mg/kg) 0.28 0.37 0.3 

Bulk Solid Waste 

Chromium Cone (mg/kg) 35.6 37.9 29.8 

Bulk Solid Waste 

Lead Cone (mg/kg) 41 58.1 26.6 

Bulk Solid Waste Mercury Cone (mg/kg 0.082 0.12 0.077 

Arsenic Feedrate (lbs/hr) 0.0116 0.0168 0.0118 

Bulk Solid Waste 

Beryllium Feedrate (lbs/hr) 0.00110 0.00157 0.00139 

Bulk Solid Waste 

Cadmium Feedrate (lbs/hr) 0.00147 0.00207 0.00160 

Bulk Solid Waste 

Chromium Feedrate (lbs/hr) 0.187 0.212 0.159 

Bulk Solid Waste 

Lead Feedrate (lbs/hr) 0.215 0.325 0.142 

Bulk Solid Waste 

Mercury Feedrate (lbs/hr) 0.000431 0.000672 0.000412 

Spiking 

Arsenic Feedrate (lbs/hr) 0 0 0 

Spiking 

Beryllium Feedrate (lbs/hr) 0 0 0 

Spiking 

Cadmium Feedrate (lbs/hr) 0 0 0 

Spiking Chromium Feedrate (lbs/hr) 46.0 46.0 45.8 Spiking 

Lead Feedrate (lbs/hr) 62.0 61.1 62.0 

Spiking 

Mercury Feedrate (lbs/hr) 0.0393 0.0388 0.0394' 

Pumpable Feedrate2 

Arsenic Feedrate (lbs/hr) 0.0125 0.0102 0.00580 

Pumpable Feedrate2 

Beryllium Feedrate (lbs/hr) 0 0 0 

Pumpable Feedrate2 Cadmium Feedrate (lbs/hr) 0.0271 0.0240 0.0188 Pumpable Feedrate2 

Chromium Feedrate (lbs/hr) 46.0 46.0 45.8 Pumpable Feedrate2 

Lead Feedrate (lbs/hr) 0.00815 0.00624 0.00320 

Pumpable Feedrate2 

Mercury Feedrate (lbs/hr) 0.000295 0.000326 0.000262 

Total Feedrate2 

Arsenic Feedrate (Ibs/hr) 0.0253 0.0280 0.0186 

Total Feedrate2 

Beryllium Feedrate (lbs/hr) 0.00117 0.00165 0.00139 

Total Feedrate2 Cadmium Feedrate (lbs/hr) 0.0288 0.0263 0.0206 Total Feedrate2 

Chromium Feedrate (lbs/hr) 46.2 46.3 46.0 Total Feedrate2 

Lead Feedrate (lbs/hr) 62.2 61.5 62.2 

Total Feedrate2 

Mercury Feedrate (lbs/hr) 0.0402 0.0399 0.0402 

1

 The weight of the Containerized Solid Waste used to calculate the feedrates of chlorine and metals has been reduced by 

the weight of the box, and the spiking materials lead nitrate, hexachloroethane, and the solution of mercuric nitrate. 

2

 Non-detects treated as a zero "0". 

4-55 

VES017437 
Table 4-43. Unit 4 - HWC MACT Metals Feedrates 

1 Runl Run 3 Run 5 

Units 10-8-13 

15:40 -18:43 

10-10-13 

12:30 -15:10 

10-30-13 

12:45-15:32 

Average 

Arsenic (Total) Ib/hr 0.0253 0.0280 0.0186 0.024O 

Beryllium (Total) lb/hr 0.00117 0.00165 0.00139 0.0014O 

Chromium (Total) lb/hr 46.2 46.3 46.0 46.1 

Total LV M (Arsenic, Beryllium, Chromium) lb/hr 46.2 ' 46.3 46.0 46.2 

Arsenic (Pumpable) lb/hr 0.0125 0.0102 0.0058 0.0095 

Beryllium (Pumpable) lb/hr 0,00000 0.00000 0.00000 0.000000 

Chromium (Pumpable) lb/hr 46.0 46.0 45.8 45.9 

Pumpable LV M (Arsenic, Beryllium, Chromium) lb/hr 46.0 46.0 45.8 45.9 

Cadmium lb/hr 0.0288 0.0263 0.0206 0.0252 

Lead lb/hr 62.2 61.5 62.2 62.0 

Total SVM (Cadmium, Lead) lb/hr 62.2 61.6 62.2 62.0 

Mercury lb/hr 0.0402 0.0399 0.0402 0.0401 

4-56 

VES017438 
5.0 Quality Assurance/Quality Control 

As part of the comprehensive performance test, a project-specific quality 

assurance/quality control (QA/QC) effort was developed and implemented. This QA/QC effort 

was documented in the QAPjP, and was tailored to meet the specific needs of this test effort. 

The results of the QA/QC activities demonstrate that the quality of project 

measurement data is well documented and that the data are reliable, defensible, and 

meet project objectives. 

The primary objectives of the QA/QC effort were to control, assess, and document data 

quality. To accomplish these objectives, the QA/QC approach consisted of the following key 

elements: 

• Definition of quality assurance objectives that reflect the overall technical objectives 

of the measurement program; 

• Design of a sampling, analytical, QA/QC and data .analysis system to meet those 

objectives; 

• Evaluation of the performance of the measurement system; and 

• initiation of corrective action when measurement system performance does not meet 

the specifications 

The CPT of the incinerators at Veolia Sauget was conducted in accordance with the QA 

procedures described in the Quality Assurance Project Plan for the Comprehensive Performance 

Test ofthe Units 2 and 3 Fixed Hearth Incinerators and the Unit 4 Rotary Kiln Incinerator, 

September 25, 2013. These QA procedures include sampling and analytical procedures, along 

with specified calibration requirements, QC checks, data reduction and validation procedures, 

and sample tracking. A review of analytical results for QA/QC samples and assessment of 

overall data quality is presented in this section. Detailed QC information is presented in the 

appendices to this report. 

The sections below present discussions of the QA/QC activities associated with the 

overall quality ofthe data associated with the CPT, Although several minor issues are identified 

and discussed in the following sections, the overall conclusion of the QA/QC assessment is that 

the results of the testing are of high quality, and are appropriate for their intended use. 

A few minor issues were identified during the QA/QC assessment. These issues and their 

impact on data usability are discussed in greater detail in following sections. 

5-1 

VES017439 
5.1 Audit Samples 

Audit samples were acquired from a Sigma-Aldrich RTC for metals and hydrogen 

chloride. These samples were submitted to the analytical laboratory along with the samples 

collected during the CPT. These results are included on the laboratory reports generated by Test 

America. The evaluation of the results by Sigma Aldrich RTC is presented in Appendix G6. 

The results of the audit samples are summarized in Table 5-1. Laboratory analysis of each audit 

sample was rated as "Acceptable". 

Table 5-1. Results of Analysis of Audit Samples 

Result 

Assigned 

Value 

Evaluation 

Metals on Filter 

Arsenic (ng/filter) 20.31 21.0 Acceptable 

Beryllium (jig/filter) 12.16 11.3 Acceptable 

Cadmium (ng/filter) 11.72 11.2 Acceptable 

Chromium ((ig/filter) 17.67 16.1 Acceptable 

Lead dig/filter) 21.60 21.0 Acceptable 

Metals in Impinger Solution 

Arsenic (ug/ml) 0.1884 0.201 Acceptable 

Beryllium (ug/ml) 0.0576 0.0530 Acceptable 

Cadmium (ug/ml) 0.1053 0.105 Acceptable 

Chromium (ug/ml) 0.2017 0.202 Acceptable 

Lead (|Xg/ml) 0.2102 0.202 Acceptable 

Mercury (ng/ml) 13.9 15.0 Acceptable 

Hydrogen Chloride in Impinger Solution (mg/L) 30.4 27.6 Acceptable 

5.2 Analysis of Waste Feeds 

5.2.1 Analysis of Waste Feeds for Metals 

Samples of waste feed materials were analyzed for mercury using CVAA, according to 

SW-846 Method 7470A. These same samples were also analyzed for arsenic, beryllium, 

cadmium, chromium, and lead using ICPES, according to SW-846 Method 6010B. These 

samples were prepared for analysis using appropriate extraction or dilution techniques. Quality 

assurance and quality control activities associated with these analyses included: 

• Sample handhng and preservation; 

• Preparation and analysis of samples within specified holding times; 

• Preparation and analysis of laboratory blanks; 

5-2 

VES017440 
• Preparation and analysis of laboratory control samples; 

• Duplicate preparation and analysis of received samples; 

• Analysis of duplicate samples; and 

• Preparation and analysis of matrix spike (MS) and matrix spike duplicate (MSD) 

samples. 

Review of these QA/QC activities indicates that these data are supportable, and useable. 

See the detailed data quality assessment in Appendix H. The following issues were identified as 

part of this data quality assessment; 

• The QAPjP specifies the performance of matrix spike/matrix spike duplicates with 

75-125% recovery, 0-20% RPD for mercury and 70-130% recovery, 0-20% RPD for 

other metals. One hundred eighty-seven of 204 MS or MSD met the specifications for 

recovery. One hundred of 102 MS/MSD pairs met the specification for RPD. The 

following samples were outside the specification: 

— VS2-CS-11B-COMP2B: Arsenic recovery 67% in MS, arsenic RPD 23%, 

chromium recovery 149% and 172% in MS/MSD; 

— VS2-CS-15B-COMP2B: chromium recovery 150% in MSD; 

VS3-CS-12B-COMP 2B: chromium recovery 131 and 145% in MS/MSD; 

— VS4-BS-13B-COMP2B: chromium recovery 132 and 134% in MS/MSD, lead 

recovery 208% in MSD; 

— VS4^CS-13B-COMP2B: chromium recovery 164 and 186% in MS/MSD, lead 

recovery 406% in MS, lead RPD 49%, mercury recovery 61 and 45% in 

MS/MSD; and 

— VS4-LBW-12B-COMP2B: cadmium recovery 145% in MSD, mercury recovery 

71 and 66% in MS/MSD. 

Metals feedrates are developed as a sum of totals fed.to the system as LV M (arsenic, 

beryllium and chromium); SVM (cadmium and lead) and mercury. The MS/MSD 

outliers detailed above indicate increased uncertainty in the concentrations ofthe 

metals in those streams. The contribution of these streams to the total feedrates of 

LVM, SVM and mercury are negligible, and the increased uncertainty in these 

concentrations has no impact on the conclusions ofthe report. No data are qualified 

or invalidated based on MS/MSD results. 

5-3 

VES017441 
5.2.2 Analysis of Waste Feeds for Physical and Chemical Parameters 

Samples of liquid and solid waste feed materials were analyzed for ash content, total 

chlorine, density, gross calorific value, kinematic viscosity, and percent moisture, using the 

following methods: 

• Ash Content: ASTMD482; 

• Total Chlorine: KNOX WC-0016; 

• Density: ASTM D1963; 

• Gross Calorific Value: ASTM D240, ASTM D5865; 

• Kinematic Viscosity: ASTM D 445; and 

• Percent Moisture: Method 160.3, ASTM D017. 

Quahty assurance and quahty control activities associated with these analyses included: 

• Sample handling and preservation; 

• Preparation and analysis of samples within specified holding times; 

• Preparation and analysis of laboratory blanks; 

• Preparation and analysis of laboratory control samples; 

• Preparation and analysis of matrix spike and matrix spike duplicate samples; 

• Collection and analysis of duplicate samples; and 

• Preparation and analysis of selected samples in duplicate. 

Review of these QA/QC activities indicates that data are supportable, and usable for the purpose 

of demonstrating regulatory compliance. See the detailed data quality assessment in Appendix H. 

The following issues were identified during the course of the QA/QC assessment: 

• Selected samples were analyzed in duplicate. Ninety of 96 duplicate analyses met the 

QAPP specifications (see table below). The outliers are: 

- Ash in VS2-HBW-13B-COMP2B; results of 582 and 646 mg/kg; RPD of 10.4%; 

- Gross Calorific Value in VS2-LBW-15B-COMP2B; results of 178 and 152 

Btu/lb; RPD of 15.8%; 

- Chlorine in VS3-CS-11A-COMP 1; results of 253 and 325 mg/kg; RPD of 24.9%; 

- Chlorine in VS4-BS-11A-COMP1; results of 171 and 221 mg/kg; RPD of 25.5%; 

- Ash in VS4-HBW-12B-COMP2B-DUP; results of 943 and 1050 mg/kg; RPD of 

10.7%; and 

- Ash VS4-HBW-13A-COMP1; results of 1,500 and 928 mg/kg; RPD of 47.1%. 

The outliers for duplicate analysis have a negligible impact on the usability of the 

data. The chlorine carried in containerized solids and bulk solids is negligible (<1%) 

compared to the chlorine provided by the spiking material. The ash carried in highBtu waste is negligible (<] %) compared to the ash provided by the bulk or 

5-4 

VES017442 
containerized solids. The heat input results in low-Btu waste are near the detection 

limit. Increased uncertainty is expected close to the detection hmit. No data are 

qualified or invalidated based on the results of duplicate analysis. 

• No duplicate analysis was performed for moisture in solid waste streams. This 

duplicate analysis was specified in the QAPjP. This has no impact on the usability of 

the data. Moisture results are used only to characterize the waste feed materials, and 

are not used in any demonstration of compliance. No data are qualified or invalidated 

based on this omission. 

5.3 Stack Gas 

5.3.1 Isokinetic Sample Collection 

Isokinetic samplmg trains were used for the collection of samples for the determination 

of: 

• Particulate matter according to EPA Method 5; 

• Hydrogen chloride and chlorine according to Modified EPA Method 26A; 

• Metals according to EPA Method 29; and Polychlorinated dibenzodioxins and 

polychlorinated dibenzofurans according to SW<-846 Method 0023A. 

Quality assurance and quahty control activities associated with the collection of these samples 

included: 

• Collection of the specified volumes of stack gas over the specified duration; 

• Collection of stack gas within 90-110% of isokinetic; 

• Maintaining the probe, filter and (on applicable trains) heated transfer line at the 

specified temperatures; 

• Maintaining the impinger exit and (on applicable trains) the condenser exit at the 

specified temperature; 

• Performing sampling train leak checks before sample collection, at port changes, and 

after sample collection; 

• Performing pitot tube leak checks before and after sample collection; and 

• Recording all data on pre-printed data sheets. 

Review of these QA/QC activities indicates that sampling was performed according to the 

methods and the QAPjP. See the detailed data quality assessment in Appendix H, Sampling data 

sheets are presented in Appendix F. Calibration documentation for all field equipment is 

presented in Appendix I. No issues were identified as part of the data quahty assessment. 

5-5 

VES017443 
5.3.2 Analysis of Stack Gas Samples for Determination of PM 

Samples of stack gas for determination of particulate matter (PM) were collected in a 

sampling train meeting the requirements EPA Method 5. 

Quality assurance and quality control activities associated with this analysis included: 

• Sample handling and preservation; 

• Preparation and analysis of samples within specified holding times; 

• Preparation and analysis of laboratory blanks; 

• Collection and analysis of field blanks; 

• Repeatability of sequential weighings; and 

• Daily balance calibration. 

Review of these QA/QC activities indicates that these data are supportable, and useable. See the 

detailed data quality assessment in Appendix H. The following issue was identified during the 

QA/QC review: 

• The field blank probe and nozzle rinse had observable levels near the detection hmit. 

The levels of particulate material observed in the PNR samples were very low, and 

near the detection limit. Levels in the field samples were similar to these results, and 

may have a positive bias. As a positive bias is conservative relative to the estimation 

of emissions, no data are qualified or invalidated based on field blank results. 

5.3.3 Analysis of Stack Gas Samples for Determination of HCI/CI2 

Samples of stack gas for determination of hydrogen chloride and chlorine (HCI/CI2) were 

collected in a Modified EPA Method 26A sampling train. Samples recovered from this sampling 

train were analyzed for hydrogen cliloride and chlorine using ion chromatography, according to 

EPA Method 26A. 

Quality assurance and quality control activities associated with these analyses included: 

• Sample handling and preservation; 

• Preparation and analysis of samples within specified holding times; 

• Preparation and analysis of laboratory blanks; 

• Collection and analysis of field blanks; 

• Preparation and analysis of laboratory control samples; 

• Preparation and analysis of matrix spike and matrix spike duplicate samples; and 

• Preparation and analysis of all samples in duplicate. 

5-6 

VES017444 
Review of these QA/QC activities indicates that these data are supportable, and useable. See the 

detailed data quality assessment in Appendix H. The following issue was identified during the 

QA/QC review: 

• Hydrogen chloride was consistently detected in the field blank samples. The levels of 

hydrogen chloride observed (approximately 60 |Ag per sample) are well below the 

levels observed in the field samples (all greater than 1,800 ng per sample). These 

levels are negligible and have no impact on the data. No data are qualified or 

invalidated based on blank results. 

5.3.4 Analysis of Stack Gas Samples for Determination of Metals 

Samples for determination of metals in stack gas were collected according to EPA 

Method 29. The filters, impinger solutions and rinses were analyzed for mercury by CVAA 

according to SW-846 Method 7470A and for arsenic, beryllium, cadmium, chromium, and lead 

by ICPES, according to SW-846 Method 6010B. 

Quality assurance and quality control activities associated with these analyses included: 

• Sample handling and preservation; 

• Preparation and analysis of samples within specified.holding times; 

• Preparation and analysis of laboratory blanks; 

• Collection and analysis of field blanks; 

• Preparation and analysis of media check samples; 

• Preparation and analysis of laboratory control samples (LCS) and laboratory check 

sample duplicates (LCSD); 

• Preparation and analysis of matrix spike and matrix spike duplicate samples; and 

• Preparation and analysis of post digestion spike (PDS) and post digestion spike 

duplicate (PDSD) samples. 

Review of these QA/QC activities indicates that these data are supportable, and useable. See the 

detailed data quality assessment in Appendix H. The following issues were identified during the 

QA/QC review: 

• Arsenic was found above the detection limit in laboratory blank samples associated 

with analysis of PNR/filter samples. The blank results for arsenic in the laboratory 

blanks are near the detection hmit, and similar to or below the results for the field 

samples. This may indicate a slight positive bias in the field results. Samples were not 

corrected for field blank results. No results are invalidated or quahfied based on 

blank results. 

5-7 

VES017445 
• Cadmium and mercury were each found in one field blank sample. The single 

positive result for cadmium in one field blank is similar in magnitude to the field 

results. The single positive result for mercury in one field blank is near the detection 

limit, and well below many of the field results. These may indicate a slight positive 

bias in the field samples. Samples were not corrected for field blank results. No 

results are invalidated or quahfied based on blank results. 

• Chromium was consistently observed in field blanks and media check samples. The 

consistent observation of chromium in field blank and media check samples is at a 

lower level than the field samples. This may indicate a slight positive bias in the 

results for the field samples. Samples were not corrected for field blank results. No 

results are invalidated or qualified based on blank results. 

5.3.5 Analysis of Stack Gas Samples for Determination of Dioxins/Furans 

Samples for determination of the polychlorinated dibenzodioxins and dibenzofurans 

(dioxins/furans) were collected according to the methodology described in SW-846 

Method 0023A. The filters, sorbent traps, and rinses from these samples were prepared for 

analysis according to SW-846 Method 0023A, and the resulting extracts analyzed for 

dioxins/furans by high-resolution GCMS, according to SW-846 Method 8290. 

Quality assurance and quahty control activities associated with these analyses included: 

• Sample handhng and preservation; 

• Preparation and analysis of samples within specified holding times; 

• Preparation and analysis of laboratory blanks; 

• Collection and analysis of field blanks; 

• Preparation and analysis of media check samples; 

• Preparation and analysis of laboratory control samples and laboratory check sample 

duplicates; and 

• Addition of surrogate compounds to each sample. 

Review of these QA/QC activities indicates that these data are supportable, and useable. See the 

detailed data quality assessment in Appendix H. The following issue was identified during the 

QA/QC review of these data: 

• All target analytes except 2,3,7,8-TCDD were observed in a media check sample, 

laboratory blank or field blank. The levels observed in the blank samples are very 

low, typically near the detection limit. Typically these levels are below the levels 

observed in the field samples. This indicates a potential positive bias in the field 

samples, which is conservative relative to the determination of emission rate. No data 

are qualified or invalidated based on blank results. 

5-8 

VES017446 
i 

! 

5.3.6 Monitoring of Stack Gas for 02, C02 , and THC 

The stack gas was monitored for oxygen (02), carbon dioxide (CO2), and total 

hydrocarbons (THC) according to EPA Methods 3A and 25A, respectively. 

Quality assurance and quality control activities associated with continuous emission 

monitoring include: 

• Use of calibration gas standards of known and acceptable quality; 

• Use of calibration gas standards in the specified ranges, 

• Performance of system bias checks, 

• Performance of cahbration error tests; and 

• Performance of zero and span drift checks. 

Review of these QA/QC activities indicates that these data are supportable and usable. See the 

data quahty assessment in Appendix H Copies of certifications of calibration gas standards are 

presented in Appendix L Raw data for continuous emission monitors are presented in Appendix 

F. The following issue was identified during the QA/QC review of this data: 

• Seventy of 72 drift checks for total hydrocarbons met method specifications. The two 

outliers were both during Unit 2 Run IB. A drift of 8.0% was seen at 1800, and a drift 

of 8.3% was observed at 1909. In accordance with EPA Method 25A, the total 

hydrocarbon analyzer was immediately re-calibrated following each of the drift 

excursions. The data from the run was then recalculated using both cahbration curves 

and the higher (more conservative) result reported. As the average THC was well 

below the standard, and that the conservative recalculation approach specified in the 

method was implemented, any uncertainty in these data has no impact on the 

conclusion of the report and the demonstration of comphance. No data are flagged or 

invalidated based on the cahbration drift results. 

5.4 Process Data 

In accordance with the MACT requirements, all process instrumentation was cahbrated. 

A Continuous Monitoring System Performance Evaluation Test Plan (CMSPETP) was prepared 

and defines the calibration procedures and acceptance criteria. The testing specified in the 

CMSPETP was performed prior to the CPT. Data from the CMSPET is presented in Appendix 

D. 

5-9 

VES017447 
5.5 Spiking 

As detailed in Sections 1.3 and 2.3 and Appendix B, during the CPT, liquids and solids 

were spiked into the incinerator feed. QA/QC activities associated with the spiking included: 

• Use of spiking materials of known and acceptable quahty; 

• Collection of data on data sheets and appropriate data acquisition systems; 

• Cahbration of pumps; and 

• Documentation of preparation of spiking packets. 

Review of these QA/QC activities indicates that the spiking data are supportable and useable. 

5-10 

VES017448 
VES017449-017462.pdf 
Review of Monitoring Experience with the Xact® MultiMetal Continuous Emissions Monitor 

Paper # 29 

Presented at the 

33r d International Conference on Thermal Treatment Technologies & Hazardous Waste 

Combustors 

October 13-15,2014 

Baltimore, M D 

Krag Petterson 

Cooper Environmental Services, LLC , Beaverton, OR 

ABSTRACT 

The Xact 640 is a multi-metals Continuous Emissions Monitor (CEM) based on X-ray 

fluorescence and reactive filter tape technology. The Xact was ceitified as a compliance CE M as 

part of an alternative monitoring plan at a hazardous waste incinerator.1,2 As part ofthe 

certification process the Xact underwent a Method 3013 procedure to validate its accuracy and 

precision. This presentation will review the test results from this Method 301 vahdation as well 

as the results from subsequent annual relative accuracy testing during the six years it was used as 

a comphance instrument. In addition, the presentation will review the results from several other 

tests involving the Xact, including multi-metals testing on a coal fired source as well as mercury 

measurements on several coal fired power plants. Finally, the presentation will also outline 

testing that will occur during an upcoming demonstration project sponsored by the South Coast 

Air Quality Monitoring District on two secondary lead smelters. 

BACKGROUND 

Under the Clean Air Act amendments of 1990 the United States Environmental Protection 

Agency (US EPA) has the authority to regulate hazardous metal emissions from sources using a 

Maximum Achievable Control Technology (MACT) approach. Several source categories 

currently have regulated emission levels for metals including coal fired power plants,4 hazardous 

waste incinerators,5 medical waste incinerators6 and Portland cement plants.7 Often these 

sources are regulated using or at least allowing particulate matter (PM) as a surrogate for metals 

emissions (e.g. coal fired power plants, Portland cement plants). In other cases actual metal 

measurements of metal emissions are required but not on a continuous basis. In these cases 

perfomiance testing of control equipment may be performed periodically using Method 298 

1 

VES017449 
along with representative momtoring of the waste stream during normal operation (e.g. 

Hazardous Waste Incinerators). 

The US EPA has, however, indicated that it may, for certain sources, prefer to see continuous 

metals momtoring using a multi-metals CEMS. For example, in 1996 when the original 

hazardous waste incinerator MACT rule was proposed it contained an option to perform metals 

monitoring with a multi-metals CEMS, 9 however, the option was later withdrawn since no there 

were no commercially available multi-metals CEMS at the time. More recently, in 2013, the US 

EPA unsuccessfully attempted to require the use of a multi-metals CEMS as part of air permit for 

a specific hazardous waste incineration facihty. 1 0 EPA also requested comment on the use of 

lead (Pb) CEMS as part ofthe proposed secondary lead smelter MACT 1 1 and is likely to 

continue to explore the use of multi-metals CEMS on several sources regulated for metals 

including hazardous waste incinerators and medical waste incinerators as the MACT rules for 

these source categories come up for review. 

The Xact is a multi-metals continuous emissions monitor based on X-Ray Fluorescence (XRF) 

developed by Cooper Envhonmental Services, LLC (CES). The instrument operates by 

withdrawing a large sample of stack effluent from the source and transporting it to the 

instrument. A subsample of this main flow is then drawn through a reactive filter tape mounted 

on a reel-to-reel type tape drive. The filter tape captures both vapor phase and particulate phase 

metals. Following sampling, the deposit is automatically advanced into the analysis area where 

it is analyzed using XRF to determine the mass of each metal while the next sample is collected. 

The stack concentration (pg/dscm) is determined by dividing the XRF determined mass (pg) by 

the total sample flow through the tape (dscm). The Xact is able to measure concentrations of 

nearly all ofthe metals on the US EPA's hst of hazardous air pollutants mcluding antimony (Sb), 

arsenic (As), cadmium (Cd), chromium (Cr), cobalt (Co), lead (Pb), manganese (Mn), merciuy 

(Hg), nickel (Ni), and selenium (Se). 

EXPERIMENTAL 

The work described in this document spans several years and several different apphcations ofthe 

Xact to various sources including: 

1) Method 301 validation ofthe Xact CEMS 

2) Operation ofthe instrument for approximately six years on a gas fired hazardous waste 

incinerator 

3) Brief study evaluating the feasibihty of measuring metals with the Xact on a coal fired 

source 

4) Two studies evaluating the accuracy of mercury measurement with the Xact on coal fued 

power plants. 

With the exception of work done measuring mercury on coal fired power plants the accuracy of 

the Xact was evaluated using a dynamic spiking procedure in which the instrument was 

challenged with known concentrations ofthe elements of interest. These procedures utilize the 

Quantitative Aerosol Generator (QAG) which has itself under gone evaluation and Method 301 

testing.12 The QAG operates by nebulizing a solution containing a National Ihstirute of Standards 

2 

VES017450 
and Technology (NIST) traceable concentr ation of metals (Cs) at a measured rate (R) into a 

measured flow (F). The concentration of the resulting aerosol (Ca ) is given by equation 1. 

Ca = Equation 1. 

Tlie aerosol is spiked into a subsample of stack gas being drawn into the instrument. By spiking 

actual stack gas, the potential effect of different interfering components present in the stack 

effluent is evaluated. The QAG was utilized instead of Method 29 because of the precision and 

accuracy of Method 29 are around 15%1 3 "

1 5

 and are not sufficient to evaluate the precision and 

accuracy of the Xact. 

Method 301 Validation ofthe Xact 

The Method 301 validation of the Xact was performed on a gas fired hazardous waste incinerator 

at Eli Lilly's Tippecanoe Laboratories in West Lafayette, Indiana. The incinerator burned waste 

associated with Lilly's drug production and was equipped with bag house and a wet scrubber. 

During the test, QAG aerosol containing five regulated metals mcluding arsenic (As), cadmium 

(Cd), chromium (Cr), lead (Pb) and mercury (Hg) were spiked into a subsample of stack gas. 

Each metal was spiked at three different norninal concentration levels (20,40 and 110 pg/dscm). 

The Xact then sampled the spiked stack gas and the Xact reported results were evaluated for 

precision, accuracy and linearity. 

Operation ofthe Xact Over Several Years 

The Xact was certified as a comphance metals monitoring instrument at the Eli Lilly incinerator 

based in part on its Method 301 vahdation.2 The Xact then operated at that facihty for a period of 

approximately six years during which time it had to continuously meet several performance 

criteria. 161 7 Each required test is listed below along with a brief description and its required 

testing frequency is in parentheses. 

1) Upscale Calibration Drift Check (Daily) 

During the upscale calibration drift check the XRF portion of the Xact is challenged with 

solid sample containing several key metals measured by the instrument for comphance 

purposes. The standard consists of a rod with a bit of material at the end that is injected into 

the analysis area once per day. The concentration ofthis standard is detennined immediately 

following cahbration and then subsequent checks ofthe Xact verify the stability ofthe XRF 

system after that. The reported concentration for each of the metals on the daily calibration 

drift standard need to be within 15% of the reference concentration each day for the 

instrument to remain in comphance. 

2) Zero Drift Check (Daily) 

VES017451 
The zero drift check involved challenging the Xact's XRF analyzer with a blank section of 

tape once per day. The difference between the value ofthe zero standard and the CEMS 

reported concenhation must be less than 20% ofthe applicable emission limit. 

3) Flow Check (Daily) 

During the flow check, the reading from the Xact's sample flow meter is checked against a 

second quahty assurance (QA) flow meter. The difference between the sample flow meter 

and the QA flow meter needed to be less than 20% ofthe full scale value ofthe meter. 

4) XRF Audit (Quarterly) 

The XRF audit evaluates the accuracy of the XRF analyzer portion of the Xact. During the 

audit the XRF analyzer is challenged with a series of thin film standards. These standards 

are produced by vapor deposition onto a filter and are commercially available from 

Micromatter Co. 1 8 The standards are gravimetrically traceable to NIST standards and have 

been recommend for use by the US EPA in cahbrating XRF equipment used to measure 

ambient air filter samples.19 The difference between the reference concentration ofthe 

standard and the concentration reported by the Xact must be less than 10% ofthe reference 

concentration for the mstrument data to be used for comphance purposes. 

5) Flow Audit (Quarterly) 

The flow audit evaluates the accuracy ofthe Xact's flow system. The readings froni both the 

sample and dilution flow meters are compared to an independent NIST traceable reference 

flow meter. The error between the Xact flow meter and the reference flow meter need to be 

less than 10% of the reference flow, 

6) Relative Accuracy Test Audit (Annually) 

Finally, the Xact was challenged with a dynamically spiked a reference aerosol at three 

different concentration levels on at least an annual basis. The reference aerosol during each 

test was generated using the QAG and spiked into the Xact's sample flow system as near as 

possible to the probe tip. The Xact reported concentration was then plotted against the 

reference aerosol concentration and a linear least squares regression fit was performed on the 

data. The slope of this best fit line needed to be between 0.80 and 1.20, the conelation 

coefficient needed to be greater than 0.90 and intercept needed to be less than 20% ofthe 

emission limit for the instrument to pass its relative accuracy test. 

Evaluation of the Xact Multi-Metals CEMS on a Coal Fired Source 

As part of an EPA sponsored small business innovative research (SBIR) grant the accuracy of 

the Xact multi-metals CEMS was evaluated on a pilot scale coal fired source. Testing was 

performed at the US EPA's Multi Pollutant Control Research Facility (MPCRF) located in 

Research Triangle Paric, North Carolina. The MPCRF is able to fire pulverized coal, distillate 

oil, and or natural gas at 4 million Btu/hr. The facility is equipped with wet and dry flue gas 

cleaning systems and closely simulates full scale emissions sources. During the study with the 

Xact the facility burned bituminous coal and utilized an ESP and wet scrubber conhols. The 

VES017452 
Xact extracted a sample of effluent downstream of all controls. The extracted effluent was 

dynamically spiked with five different metals (As, Cd, Cr, Pb, Hg) at three different 

concenhation levels (27, 92 and 250 ng/dscm) using the QAG. The Xact reported concentration 

was plotted against the reference aerosol concentration and a linear least squares regression fit 

was perfomied. The accuracy ofthe Xact was evaluated on the basis of slope, conelation 

coefficient and intercept. 

Measurement of Mercury with the Xact on Coal Fired Power Plants 

This paper also summarizes the results of two distinct studies evaluating the accuracy ofthe 

Xact's mercury measurement on coal fired power plants. During both studies the accuracy of the 

Xact was determined by comparing it to Method 30B2 0, a sorbent trap approach to measuring 

mercury. The first study was performed on a 585 MW facihty, burning subbituminous coal and 

operating with ESP controls. The Xact was deployed at this facihty for three weeks and 

comparison testing took place on one of those days. 

The second study was performed at a 750MW source binning two separate blends of lignite and 

Powder River Basin (PRB) coal (60/40 and 80/20 blends of lignite/PRB). The facility was 

equipped with an ESP and wet scrubber, but all of the Xact sampling was done downstream of a 

single ESP module and upsheam ofthe wet scrubber, hi addition, the facility was testing two 

separate mercury control options - activated powdered carbon and EMO, a broniine based 

additive. Ehuing the course of the approximately two week test the Xact reported mercury 

concenhation was compared to Method 30B measured concentration at several times each day. 

RESULTS AND DISCUSSION 

Method 301 Validation Results 

During the Method 301 validation of the Xact the bias, precision and linearity of the Xact were 

detennined by comparing the Xact's reported concenhation with reference aerosol concentration 

oyer three different concentration levels (nominally 20,45 and 110 u.g/dscm) and a zero 

concentration. The bias was calculated for each element at each data point using Equation 2 

Bi = ' Q *c • 100 Equation 2 

where: 

B— The Xact's bias for the i * element relative to the QAG expressed as a percentage 

C/f= The concentration ofthe i * element as measured by the Xact 

cfAG= The concenhation ofthe r* element in the QAG aerosol 

The precision of the Xact was calculating by first determining the relative percent standard 

deviation as shown in equation 3. 

5 

VES017453 
Equation 3 

where: 

V/=the total variability ofthe 1t h element 

SDi= the standard deviation ofthe i01 element 

Ci = the average concentration of the 1th element 

Because there is random variability associated with both the QAG aerosol concentration as well 

the Xact measurement, the total variability (V?) is an indicator ofthe overall variabihty of both 

the QAG aerosol generation and the Xact measurement. The individual variabihty of just the 

Xact measured concenhation then is determined by dividing the total variabihty by the square 

root of 2 as shown in equation 4. 

Vt = ^ Equation 4 

where: 

I^i=the precision of the Xact measurement for the r* element 

l^'=the total precision of the r* element 

Table 1 summarizes the results for both the average bias and average precision for the Xact for 

each ofthe five tested elements over all three concentration levels. Ih general, there was less 

than 10% difference between the Xact reported concentrations and the known concentration of 

the reference aerosol. Only the bias for mercuiy was detennined to be statisticaUy significant and 

6% ofthe bias was later determined to be due to a cahbration error for mercuiy. The average 

variabihty of the Xact was also less than 2% for each element indicating that the Xact's 

measurements were extremely precise and consistent. 

TaMe 1. Xact Method 301 Results for Measurement Bias and Variabiliry 

Element N Average Bias (%) Average Variability 

(%) 

Cr 40 8.2 1.6 

As 40 4.9 1.7 

Hg 40 16 1.4 

Pb 40 7.9 1.5 

Cd 40 5.2 1.9 

Figure 1 shows the overall linear regression for all of the metals tested over all three 

concentration levels and a zero concentration. The slope ofthe linear regression fit was 0.95 

indicating exceUent agreement between the Xact measured concentration and the QAG reference 

aerosol. The intercept was slightly greater than 1 ug/dscm indicating very little background bias 

6 

VES017454 
and the conelation coefficient was gieater than 0.99 indicating very httle scatter in the data and 

good precision.12 

Figure 1. Xact Linearity During Method 301 Validation 

140 

QAG Reference Concentration (ug/dscm) 

Operation of the Xact Over Several Years 

Tlie Xact operated for several years at Eh Lilly's hazardous waste incinerator and during that 

time met all ofthe daily, quarterly and annual quality assurance requirements. Some sample 

upscale cahbration check results from March of2006 to March of 2007 are shown in Figure 2. 

During that entire 12 month period the Xact upscale drift exceeded its upscale cahbration drift 

criteria on only two occasions. Table 2 shows all the quarterly XRF and flow audit results for 

the entire compliance operation period from 2007 to 2010. During that four year span the Xact 

passed all of its quarterly audit requhements. Finally, table three shows the results from six 

separate relative accur acy test audits (RATA) over a span of five years. The Xact met the RATA 

criteria in all cases, however, in 2006 and 2008 a small correction factor needed to be apphed to 

the mstrument data for arsenic. 

Figure 2. Daily Upscale Results from March 2006 to March 2007 

7 

VES017455 
2500 

I 2000 

X3 

03 

| r 1500 

o 

£3 

~ 1000 

0) 

o 

c 

o 

O 

500 1 IkffS 

o 

Feb-06 

• Cd 

• Cr 

A Hg 

Pb 

May-06 Aug-06 Nov-06 

Date 

Mar-07 

VES017456 
Table 2. Quarterly Flow and XRF Audit Results from 2007 to 2010 

Audit 

Year 

Quarter Flow Error 

{%) 

Audit XRF Audit Error {%) 

Year 

Quarter Flow Error 

{%) Cr As Cd Hg Pb 

2007 1 3.04 1.46 2.18 2.84 1.75 2.34 

2 3.13 3.32 0.13 4.23 2.60 2.96 

2007 

3 0.68 -3.74 2.18 -4.13 2.36 2.76 

2007 

4 1.42 6.50 0.36 7.36 4.18 0.40 

2008 1 NA 0.22 .11 1.20 -0.99 0.87 

2 1.07 1.93 .66 1.82 2.16 2.34 

2008 

3 0.53 2.96 2.61 3.30 2.53 0.68 

2008 

4 1.37 1.77 0.72 1.48 0.56 1.06 

2009 1 2.10 0.60 2.94 1.52 3.45 0.46 

2 3.67 1.49 4.09 1.07 1.78 0.30 

2009 

3 0.84 2.00 5.43 2.78 0.72 0.22 

2009 

4 NA NA NA NA NA NA 

2010 1 NA 1.60 5.13 0.45 0.71 2.11 

2 NA 1.61 5.92 1.12 4.00 0.96 

2010 

3 1.68 -3.47 -0.92 -2.82 -2.42 -2.11 

2010 

4 NA 2.00 0.82 2.70 1.83 2.91 

Average 1.77 1.35 2.16 1.66 1.68 1.22 

NA - Data not available 

Table 3. Annual QAG RAT A Results 

Year Slope 

Cr As Cd Hg Pb Annual 

Average 

2006 0.83 0.90 0.85 0.82 0.85 0.85 

2006 

(Quarterly) 

0.91 0.77 0.95 0.92 0.93 0.89 

2007 0.84 0.82 0.88 0.84 0.81 0.84 

2008 0.96 0.71 0.98 0.99 0.97 0.92 

2009 0.96 0.99 0.99 1.10 1.00 1.01 

2010 0.97 1.06 1.11 1.02 1.04 1.04 

Average 

for Each 

Element 

0.91 0.87 0.96 0.95 0.93 0.93 

Results ofthe Evaluation ofthe Xact on a Coal Fired Source 

Table 4 shows the results ofthe evaluation ofthe Xact's accuracy on a coal fired source. During 

the study the Xact was chaUenged with three concentration levels using CES' quantitative 

aerosol generator. As with the Method 301 testing the Xact effluent was dynamically spiked to 

test for any potential interferences from the coal fired effluent. For each element, the Xact 

9 

VES017457 
reported concentrations were plotted against the known reference aerosol concentration and a 

least squares regression analysis was performed. In all cases, the Xact slope was between 1.00 

and 1.15 with correlation coefficients greater than 0.99. This indicated that there were no 

measurement matrix effects associated emissions from a coal fired source and that the Xact is 

able to accurately measure many of the key metals of interest on such a source.21 

Table 4. Results from Accuracy Testing on a Coal Fired Source 

Element N Slope Correlation 

Coefficient 

Cr 28 1.09 >0.99 

As 28 1.14 >0.99 

Cd 28 1.11 >0.99 

Hg 28 1.14 >0.99 

Pb 28 1.00 >0.99 

Mercury Measurement with the Xact on a Coal Fired Power Plant 

During testing on a 585 MW coal fired facility equipped with ESP controls the mercury 

concentration as reported by the Xact was compared against method 30B. The percent 

difference between the Xact and Method 30B was 3.53%.22 These results are shown graphically 

in Figure 3. 

Figure 3. Xact Comparison with Method 30B 

10 

9 

8 

c 

3 5 

4 

I 3 

XLX L 

• • 

• CES Xact 

• Method 30B 

5 6 7 8 9 10 11 12 13 

RATA Number 

10 

VES017458 
Additional compaiisons have been made between Method 30B and the Xact at another coal fired 

power plant. This 750 MW facility was biuiiing lignite-PRB coal blends and testing two 

different mercuiy conhol technologies (powder activated carbon and EMO). Over the entire 

two week period 21 comparisons were made between the Xact and Method 30B under a variety 

of stack effluent conditions. The average percent difference between the Xact and Method 30B 

was 6.0% demonshating the accuracy of the Xact's mercury measurements. The results are 

summarized in Table 5. 

Table 5. Xact Mercury Measurements With and Without Mercury Control 

Fuel 

Conditions 

Date Time Hg 

Controls 

Method 

30B 

(ug/dscm) 

Xact 

(pg/dscm) 

Percent 

Difference 

60% 10/3/12 11:45 Baseline 24.57 22.59 -8.1 

lignite 10/3/12 14:45 EMO 14.85 15.33 3.2 

40% PRB 10/3/12 16:45 EMO 16.30 15.83 -2.9 

10/5/12 12:15 EMO & 

PAC 

9.25 10.09 9.0 

10/5/12 16:45 EMO & 

PAC 

11.52 12.74 10.6 

10/5/12 17:45 EMO & 

PAC 

4.05 5.88 45.2 

10/6/12 10:45 Baseline 24.03 24.55 2.2 

10/6/12 13:45 EMO & 

PAC 

11.14 12.34 10.8 

10/6/12 15:45 EMO & 

PAC 

5.74 7.97 38.8 

10/6/12 18:45 EMO & 

PAC 

13.92 15.72 13.0 

80% 10/9/12 10:15 Baseline 28.14 25.07 -10.9 

Lignite 10/9/12 12:15 P AC 19.01 19.26 1.3 

20% PRB 10/9/12 16:15 PAC 7.00 7.34 4.9 

10/10/12 10:30 Baseline 23.19 23.98 3.4 

10/10/12 13:45 EMO 18.73 20.22 8.0 

10/10/12 16:45 EMO 20.10 22.10 10.0 

10/10/12 19:45 E MO 18.60 22.11 18.8 

10/10/12 9:00 Baseline 21.57 18.69 -13.4 

10/11/12 9:00 Baseline 24.00 23.53 -1.9 

10/11/12 10:45 EMO 20.52 18.90 -7.9 

10/11/12 11:30 EMO 21.38 19.55 -8.6 

Average Percent Difference Under Baseline Conditions -4.8 

Average Percent Difference with Hg Controls 7.6 

Overall Percent Difference 6.0 

11 

VES017459 
CONCLUSION 

The Xact has demonstrated metals measur ement accuracy on a variety of source types and with a 

variety of differeut conhols. These sources have included gas fired and coal fired sources with 

ESP and wet scmbbing conhols. In addition, the Xact demonshated accuracy measiuing 

mercmy with at least two differeut approaches to mercury conhol - powder activated carbon and 

EMO. In the future the accuracy and precision of the Xact will be tested on two secondary lead 

smelters in the Los Angeles Basin area. These tests will include both dynamic spiking tests with 

a reference aerosol as well as comparisons to stack metals measurement methods such as Method 

29. 

REFERENCES 

1. Eli Lilly and Co. (2005), Alternative Monitoring Petition for the Solid-Liquid Incinerator, 

Tippecanoe Laboratories, Lafayette, IN 47909 

2. Oldham, CB . Air Measurements and Quahty Group, Office of A h Planning and 

Standards, U.S. Envhonmental Protection Agency, Research Triangle Park, NC. Written 

commimication with Eli Lilly and Company: Lafayette, IN. 2006 

3. U . S. Envhonmental Protection Agency Method 301, Field Vahdation of Pollution 

Measurement Methods for Various Media, ha Code of Federal Regulations, 40 CFR Part 

56. U.S. Government Printing Office: Washington, DC, 2005 

4. "National Emissions Standards From Coal- Oil-fired Electric Steam Generating Units and 

Standards of Performance for Fossil-Fuel-Fired Electric Utility, mdustrial-CommercialInstitutional Steam Generating Units, Final Rule." Federal Register 77 (February 16, 

2012): 9403-9513. 

5. "National Emissions Standards for Hazardous A h Pollutants for Hazardous Waste 

Combustors (Phase I Final Replacement Standards and Phase II);" Final Rule. Federal 

Register 70, No. 196 (October 12,2005): 59402 -

59450) http://ww.epa. gov/fe^ 

Accessed July 24,2014. 

6. "Standards of Performance for New Stationary Sources and Ernissions Guidelines for 

Existing Sources: Hospital/Medical/Infections Waste Incinerators;" Final Rule. Federal 

Register 74, No. 192 (October 6,2009). ht1p://ww.^o.gov/f(favs/pkg/FR-2009-10-

06/pdf/E9-22928.pdf Accessed July 24, 2014. 

7. "National Emission Standards for Hazardous Ah- Pollutants from the Portland Cement 

Manufacturing Industry and Standards of Performance for Portland Cement Plants;" Final 

Rule. Federal Register 75, No. 174 (September 9,2010). 

htb://www.epa.gov/ttn/atw/pcen]/fr09sel0.pdf Accessed July 24,2014 

8. U.S. Envhonmental Protection Agency. Method 29, Determination of Metals Emissions 

from Stationary Sources, hi Code of Federal Regulations, 40 CFR 60; U.S. Government 

Printing Office: Washington, DC, 2005. 

12 

VES017460 
9. "Revised Standards for Hazardous Waste Combustors" Proposed Rule. Federal Register 

61, No. 77 (April 19, 1996). hdD://wvw.gpo.gov/fdsvs/pkg/FR-1996-04-19/pdf/96-

7872.pdf Accessed July 24.2014. 

10. U.S. Environmental Protection Agency, Region 5. Air Pollution Control Title V Permit to 

Operate. Peimit No. V-IL-1716300103-08-01. 

htto://www.regulations.gov/#!documentDetail;D=EPA-R05-OAR-2012-0649-0001 

Accessed July 24,2014. 

11. "National Emission Standards for Hazardous Air Pollutants: Secondary Lead Smelting" 

Proposed Rule. Federal Register 76, No. 97 (May 19, 

2011) http://ww.epa.gov/ttn/atw/lead2nd/frl9mvl l.pdf Accessed July 24.2014 

12. Yanca, C.A.; Barth, D.C; Petterson, K.A.; Nakanishi, M.P.; Cooper, J.A.; Johnsen, B.E.; 

Lambert, R.H.; Bivins, D.G.; J. Air and Waste Manage. Assoc. 2006,56,1733-1742. 

13. Rigo, H.G.; Chandler A.J.; J. Air and Waste Mange. Assoc. 1999,49, 399-411. 

14. American Society of Mechanical Engineers, Research Comniittee on Industrial and 

Municipal Waste. Reference Method Accuracy and Precision (ReMAP): Phase 1, 

Precision of Manual Stack Emission Measurements; Report No. CRTD-60; American 

Society of Mechanical Engineers International; Washington, DC, 2001. 

15. U.S. Envhonmental Protection Agency. Evaluation of Two Methods for the Measurement 

of Mercury Emissions in Exhaust Gases from a Mumcipal Waste Combustor; EPA 450/4-

92-013. U.S. Government Printing Office: Washington, DC, 1991 

16. U.S. Envhonmental Protection Agency. Other Test Method 16, Specifications for X-ray 

Fluorescence Based Multi-Metals CEMS at Stationary 

Sources. htm://www.epa.gov/ttri/emc/prelirn/otml6.pdf Accessed July 24.2014. 

17. U.S. Envhonmental Protection Agency. Other Test Method 20. Quahty Assurance 

Requhements for X-ray Fluorescence Based Multi-Metals CEMS at Stationary 

Sources, http://www.epa.gov/ttn/emc/preliiri/otm20.pdf Accessed July 24,2014. 

18. Micromatter Co. 4004 Westbrook Mall, Vancouver, B.C. V6T 2A3, Canada. 

19. U.S. Envhonmental Protection Agency. Compendium Method 10-3.3: Determination of 

Metals in Ambient Particulate Matter Using X-ray Fluorescence (XRF) Spectroscopy. In 

Compendium of Methods for the Determination of Inorganic Compounds in Ambient Air; 

EPA/625/R-96/010a. U.S. Government Printing Office: Washington, DC, 1999. 

20. U.S. Envhonmental Protection Agency. Method 30B. Determination of Total Vapor 

Phase Mercury Emissions From Coal-Fired Combustion Sources Using Carbon Sorbent 

Traps. In Code of Federal Regulations 40 CFR 60. U.S. Government Printing Office. 

Washington, DC, 

21. Cooper Environmental Services LLC. Feasibility of Monitoring Heavy Metal Emissions 

from a Coal Fired Hazardous Waste Incinerator Using a Multi-Metal Continuous 

13 

VES017461 
Emissions Monitor. EPA Contract JD EP-D-07-026. April 30,2007. 

22. The Avagadro Group LLC , Continuous X-Ray Fluorescence Mercury Emissions 

Monitor, Unofficial Relative Accuracy Test Audit, April 28t h 2009. 

KEYWORDS 

Multi-Metals CEMS, Hazardous Waste Incinerators, X-ray Fluorescence 
VES017463-017634.pdf 
United States Environmental Protection Agency 

Region 5 

Air & Radiation Division 

77 West Jackson Boulevard 

Chicago, Illinois 60604 

AIR POLLUTION CONTROL 

TITLE V PERMIT TO OPERATE 

Permit No.: V-IL-1716300103-2014-10 

Issue Date: DRAFT 

Effective Date; DRAFT 

Expiration Date: DRAFT 

In accordance with the provisions of Title V ofthe Clean Air Act and 40 C.F.R. Part 71, 

Veolia ES Technical Solutions, L.L.C. 

is authorized to operate ah emission units and to conduct other air pollutant emitting activities in 

accordance with the permit conditions listed in this permit. 

This source is authorized to operate in St. Clair County at the following address: 

7 Mobile Avenue, Sauget, Illinois 62201 

Terms and conditions not otherwise defined in this permit have the meaning assigned to them in 

40 C.F.R. Part 71 unless other regulations or statutes are referenced. All terms and conditions of 

the permit are enforceable by EPA and citizens under the Clean Air Act. 

Once effective, this permit supersedes any other permit issued to the source pursuant to Title V 

of the Clean Air Act and 40 C.F.R. Part 71. 

/s/ 10/10/14 

George Czerniak, Director Date 

Air and Radiation Division 

U.S. EPA - Region 5 

VES017463 
Veolia ES Technical Solutions, L.L.C. Page 2 of 172 

Permit No.: V-IL-1716300103-2014-10 

Issuance Date: DRAFT 

Expiration Date: DRAFT 

TABLE OF CONTENTS 

1.0. SOURCE IDENTIFICATION AND UNIT-SPECIFIC INFORMATION 8 

1.1. GENERAL SOURCE INFORMATION 8 

1.2. FACILITY DESCRIPTION 8 

1.3. EMISSION UNITS 8 

2.0. UNIT-SPECIFIC OPERATING REQUIREMENTS 11 

2.1. HAZARDOUS WASTE COMBUSTORS, UNITS 2, 3 AND 4 11 

(A) Emission Limitations and Standards 11 

(B) Nonapplicable Regulations 14 

(C) Work Practice and Operational Requirements 15 

(D) Monitoring and Testing 31 

(E) Recordkeeping and Reporting 73 

2.2. MATERIAL PROCESSING AREAS 90 

(A) Emission Limitations and Standards 90 

(B) Nonapplicable Regulations 91 

(C) Work Practice and Operational Requirements 92 

(D) Monitoring and Testing 94 

(E) Recordkeeping and Reporting 99 

2.3. DRUM CRUSHER 99 

(A) Emission Limitations and Standards 100 

(B) Nonapplicable Regulations 100 

(C) Work Practice and Operational Requirements 100 

(D) Monitonng and Testing 100 

(E) Recordkeeping and Reporting 101 

2.4. LIQUID WASTE STORAGE TANKS 102 

(A) Emission Limitations and Standards 102 

(B) Nonapplicable Regulations 104 

(C) Work Practice and Operational Requirements 105 

VES017464 
Veolia ES Technical Solutions, L.L.C. Page 3 of 172 

Permit No.: V-IL-1716300103-2014-10 

Issuance Date: DRAFT 

Expiration Date: DRAFT 

(D) Monitoring and Testing 105 

(E) Recordkeeping and Reporting 106 

2.5. BULK SOLID WASTE STORAGE FACILITY'...! 109 

(A) Emission Limitations and Standards 109 

(B) Nonapplicable Regulations 111 

(C) Work Practice and Operational Requirements 112 

(D) Monitoring and Testing 112 

(E) Recordkeeping and Reporting ; 114 

2.6. GASOLINE STORAGE TANK 117 

(A) Emission Limitations and Standards 117 

(B) Nonapplicable Regulations 118 

(C) Work Practice and Operational Requirements 118 

(D) Monitoring and Testing 119 

(E) Recordkeeping and Reporting 119 

2.7. BOILER , 120 

(A) Emission Limitations and Standards 120 

(B) Nonapplicable Regulations 121 

(C) Work Practice and Operational Requirements 122 

(D) Monitoring and Testing 123 

(E) Recordkeeping and Reporting 124 

2.8. EMERGENCY GENERATORS 126 

(A) Emission Limitations and Standards 126 

(B) Nonapplicable Regulations. 126 

(C) Work Practice and Operational Requirements 126 

(D) Monitoring and Testing 130 

(E) Recordkeeping and Reporting 130 

2.9. FUGITIVE EMISSIONS 133 

(A) Emission Limitations and Standards 133 

(B) Nonapplicable Regulations 134 

VES017465 
Veolia ES Technical Solutions, L.L.C. Page 4 of 172 

Permit No.: V-IL-1716300103-2014-10 

Issuance Date: DRAFT 

Expiration Date: DRAFT 

(C) Work Practice and Operational Requirements 134 

(D) Monitoring and Testing '. 143 

(E) Recordkeeping and Reporting.... 146 

2.10. INSIGNIFICANT EMISSION UNITS AND ACTIVITIES 148 

(A) List of Insignificant Emission Units and Activities 148 

(B) Applicable Requirements 149 

(C) Compliance with Applicable Requirements 149 

3.0. FACILITY-WIDE PERMIT REQUIREMENTS 150 

3.1. GENERAL PART 71 RECORDKEEPING 150 

(A) Required Records 150 

(B) Record Retention Schedule 150 

(C) Emissions Calculation Methodology 150 

3.2. GENERAL PART 71 REPORTING 151 

(A) Semi-annual Reports 151 

(B) Deviations • 152 

3.3. PERFORMANCE TESTING 153 

3.4. FACILITY-WIDE APPLICABLE REQUIREMENTS 154 

(A) Fugitive Particulate Matter Restrictions 154 

(B) Open Burning Prohibitions 154 

(C) Visible Emissions 154 

(D) Recycling and Emissions Reduction 154 

(E) Risk Management Plan (RMP) .• 155 

(F) Episode Action Plans 155 

(G) Annual Benzene Waste Quantity Determination 155 

(H) General Prohibition on Air Pollution 156 

(I) Facility-wide Testing 156 

(J) Facility-wide Recordkeeping 160 

VES017466 
Veolia ES Technical Solutions, L.L.C. Page 5 of 172 

Permit No.: V-IL-1716300103-2014-10 

Issuance Date: DRAFT 

Expiration Date: DRAFT 

4.0. GENERAL PART 71 REQUIREMENTS 163 

4.1. DEFINITIONS 163 

4.2. ANNUAL FEE PAYMENT 163 

4.3. COMPLIANCE STATEMENT 165 

4.4. COMPLIANCE CERTIFICATIONS 165 

4.5. SCHEDULE OF COMPLIANCE 166 

4.6. DUTY TO PROVIDE AND SUPPLEMENT INFORMATION 166 

4.7. ENFORCEABILITY 167 

4.8. SUBMISSIONS 167 

4.9. SEVERABILITY CLAUSE 167 

4.10. PERMIT ACTIONS 167 

4.11. ADMINISTRATIVE PERMIT AMENDMENTS 168 

4.12. MINOR PERMIT MODIFICATIONS 168 

4.13. SIGNIFICANT PERMIT MODIFICATIONS 168 

4.14. REOPENING FOR CAUSE 168 

4.15. PROPERTY RIGHTS 168 

4.16. INSPECTION AND ENTRY 168 

4.17. EMERGENCY PROVISIONS 169 

4.18. OFF PERMIT CHANGES 170 

4.19. PERMIT EXPIRATION AND RENEWAL 170 

4.20. OPERATIONAL FLEXIBILITY 171 

4.21. PERMIT SHIELD 171 

4.22. CREDIBLE EVIDENCE 172 

VES017467 
Veolia ES Technical Solutions, L.L.C. Page 6 of 172 

Permit No.: V-IL-1716300103-2014-10 

Issuance Date: DRAiFT 

ExpirationDate: DRAFT 

Abbreviations and Acronyms 

ASTM American Society for Testing and Materials 

C AA or Act Clean Air Act [42 U.S.C. § 7401 et seq.] 

C EM Continuous Emission Monitor 

CEMS Continuous Emissions Monitoring System 

C.F.R. Code of Federal Regulations 

CMS Continuous Monitoring System 

CO Carbon Monoxide 

C OM Continuous Opacity Monitor 

CPMS Continuous Parametric Monitoring System 

DOC Documentation of Compliance 

DRE Destruction and removal efficiency 

EPA United States Environmental Protection Agency 

ESV Emergency Safety Vent 

EU Emission Unit 

Facility Veolia ES Technical Solutions, L.L.C. 

gal gallon 

g grams 

gr/scf grains per standard cubic foot of exhaust gas 

HAP Hazardous Air Pollutant 

hr hour 

HWC hazardous waste combustor 

IAC Illinois Administrative Code 

IEPA Illinois Environmental Protection Agency 

kg kilogram 

kpa kilo pascals 

lb pound 

L V M Low Volatile Metals (Arsenic, Chromium and Beryllium) 

MACT Maximum Achievable Control Technology 

pg/dscm micrograms per dry standard cubic meter of exhaust gas 

Mg megagram 

MMBtu million British Thermal Units 

NESHAP National Emission Standards for Hazardous Air Pollutants 

ng TEQ/dscm nanograms toxicity equivalents per dry standard cubic meter of exhaust 

gas 

NOC Notification of Compliance 

NOx Nitrogen Oxides 

NSPS New Source Performance Standard 

NSR New Source Review 

Operator Veolia ES Technical Solutions, L.L.C. 

Permittee Veolia ES Technical Solutions, L.L.C. 

PM Particulate Matter 

PMio Particulate matter less than 10 microns in diameter 

ppm parts per million 

VES017468 
Veolia ES Technical Solutions, L.L.C. Page 7 of 172 

Permit No.: V-IL-1716300103-2014-10 

Issuance Date: DRAFT 

Expiration Date: DRAFT 

POHC principle organic hazardous constituent 

PSD Prevention of S ignificant Deterioration 

Psi Pounds per square inch 

SO2 Sulfur Dioxide 

SVM Semivolatile Metals (Lead and Cadmium) 

tpy tons per year 

VOC Volatile Organic Compounds 

VHAP Volatile Hazardous Air Pollutant 

VES017469 
Veolia ES Technical Solutions, L.L.C. Page 8 of 172 

Permit No.: V-IL-1716300103-2014-10 

Issuance Date: DRAFT 

Expiration Date: DRAFT 

1.0. SOURCE IDENTIFICATION AND UNIT-SPECIFIC 

INFORMATION 

1.1. GENERAL SOURCE INFORMATION 

Parent Company: 

Facility: 

County: 

SIC Code: 

AFS Plant Identification Number: 

Veolia ES Technical Solutions, L.L.C. 

700 E. Butterfield Road 

Lombard, Illinois 60148 

Veolia ES Technical Solutions, L.L.C. 

7 Mobile Avenue 

Sauget, Illinois 62201 . 

St. Clair 

4953 

1716300103 

1.2. FACILITY DESCRIPTION 

Veolia ES Technical Solutions, L.L.C. is a treatment, storage, and disposal facility, which 

accepts offsite waste for further disposal through incineration. Containers and bulk 

shipments of hazardous and solid wastes are received, analyzed, transferred to temporary 

storage facilities, processed, and incinerated in one of three combustion units. 

1.3. EMISSION UNITS 

The emissions units located at the facility at the time of permit issuance are: 

1 mission 

1 mt 

M.tnut.Htmt'i 

Ih'M'imtitin Moikl 

l>.iu. ni 

( iiiistriiilion 

Emission Control 

Equipment 

Hazardous 

Waste 

Combustors 

Incineration Unit #2 

(Incinerator) with a 

Maximum Heat 

Capacity of 

16 mmBtu/hr 

Trade Waste 

Incineration, TWI2000, Series 2 

October 1986 Joy-Niro Spray 

Dryer Absorber 

(SDA-2), Pulse Flo 

Fabric Filter (BH-2) 

VES017470 
Veolia ES Technical Solutions, L.L.C. Page 9 of 172 

Permit No.: V-IL-1716300103-2014-10 

Issuance Date- DRAFT 

ExpirationDate: DRAFT 

rniisMuii 

1 ml 

M.iiiiitacliiKi 

Description Modil 

l>.ik of 

Construction 

Emission Control 

Equipment 

Incineration Unit #3 

(Incinerator) with a 

Maximum Heat 

Capacity of 

16 mmBtu/hr 

Tiddc \\ jsto 

Incineration, TWI2000, Series 2 

No\ ember 1987 .li>\-Niu> Spray 

Dryer Absorber 

(SDA-3), Pulse Flo 

Fabric Filter (BH-3) 

Incineration Unit #4 

(Rotary Kiln) with a 

Maximum Heat 

Capacity of 

50 mmBtu/hr 

International Waste 

Energy, PY*ROX 

June 1988 Tempering 

Chamber, Activated 

Carbon Injection, 

Spray Dryer 

Absorber, Fabric 

Filter 

Material 

Processing 

Areas 

Waste Processing 

Units (Area 1 and 

Area 2) 

1988 

None 

Material 

Processing 

Areas Lab Pack Repack 

Unit 

1988 

None 

Drum 

Crusher 

Empty drums are 

crushed 

1984 None 

Storage 

Tanks for 

Liquid 

Wastes 

Tanks #2 (4,391 

gals), #4 (4,931 gals), 

#6 (7,200 gals), #8 

(5,820 gals), #10 

(12,869 gals), #20 

(12,869 gals), #30 

(12,869 gals), #40 

(12,869 gals), #50 

(12,869 gals), #60 

(12,869 gals), #300 

(19,850 gals), #302 

(30,000 gals), #304 

(30,000 gals), #306 

(30,000 gals), #308 

(30,000 gals), #310 

(30,000 gals), #312 

(10,000 gals) and 

#314(10,000 gals) 

Modern Welding April 2002 for 

#2 and #4; June 

2004 for #10 

and #20; March 

2009 for #30; 

1988 forthe 

others. 

Activated Carbon 

Absorption Systems 

on each storage tank 

vent. 

Storage 

Tanks for 

Liquid 

Wastes 

Storage tank for #2 

fuel oil: Tank #390 

(30,000 gals) 

Modern Welding 1988 None 

Bulk Solid 

Waste 

Temporary storage of 

bulk solid wastes in 

pits prior to being fed 

1988 Cyclone, Airtol 

Baghouse (BF BldgBH-1), Carbon 

VES017471 
Veolia ES Technical Solutions, L.L.C. Page 10 of 172 

Permit No.: V-IL-1716300103-2014-10 

Issuance Date: DRAFT 

ExpirationDate: DRAFT 

Emission 

I nil Desciipliuii 

M.lllllt.Klllll-l 

MoiKI 

Date of 

( misti lu-tion 

1 mission ( mitrol 

Equipment 

Storage 

Facility 

to Incineration Unit 

#4 

Adsorption Unit (BF 

Bldg-CA) 

Gasoline 

Storage Tank 

550 gallon tank, 

equipped with 

submerged loading 

pipe 

June 2012 None 

Boiler Natural Gas-Fired 

Boiler with a 

Maximum Heat 

Capacity of 

10.6 mmBtu/hr 

(Boiler #1) 

Cleaver Brooks, 

250 

November 1995 None 

Emergency 

Generators 

(2) 

Two #2 Fuel oil-fired 

Emergency 

Generators each with 

Maximum Heat 

Capacity of 

0.40 mmBtu/hr (<112 

kilowatts (kW)) 

1988 None 

Fugitive 

Emissions 

Pumps, Valves, 

Open-End Lines and 

Compressors 

N/A None 

VES017472 
Veolia ES Technical Solutions, L.L.C. Page 11 of 172 

Permit No.: V-IL-1716300103-2014-10 

Issuance Date: DRAFT 

ExpirationDate: DRAFT 

2.0. UNIT-SPECIFIC OPERATING REQUIREMENTS 

2.1. HAZARDOUS WASTE COMBUSTORS, UNITS 2,3 AND 4 

(A) Emission Limitations and Standards [40 C.F.R. § 71.6(a)(1)] 

The Permittee shall comply with the following requirements at each individual 

incinerator unless specified otherwise: 

1. Visible Emission Limitations. 

(a) The Permittee shall not cause or allow from any emission source the 

emission into the atmosphere of smoke or other particulate matter with an 

opacity greater than 30 percent, except as allowed by 35 IAC 212.123(b) 

and 212.124. [35 IAC 212.123(a)] 

(b) The Permittee shall not cause or allow from any process, including any 

material handling or storage activity, the emission of fugitive particulate 

matter that is visible by an observer looking generally overhead at a point 

beyond the property line of the source unless the wind speed is greater than 

40.2 kilometers per hour (25 miles per hour). [35 IAC 212.301 and 

212.314] 

2. Sulfur Dioxide Limitations. 

Total sulfur dioxide emissions from the facility shall not exceed 7.7 tons per year 

(tpy) from Unit 2, 7.7 tpy from Unit 3, and 50.76 tpy from Unit 4. [Construction 

Permits 87100024 and 88010001] 

3. Carbon Monoxide Limitations. 

(a) The Permittee shall not allow emissions of carbon monoxide in excess of 

100 parts per million (ppm) by volume, on an hourly rolling average 

(monitored continuously with a continuous emissions monitoring system), 

dry basis and corrected to 7. percent oxygen. The Permittee must also 

document that, during the destruction and removal efficiency test runs or 

their equivalent as provided by 40 C.F.R. § 63.1206(b)(7), hydrocarbons do 

not exceed 10 ppm by volume during those runs, on an hourly rolling 

average (monitored continuously with a continuous emissions monitoring 

system), dry basis, corrected to 7 percent oxygen, and reported as propane, 

[40 C.F.R. §63.1219(a)(5)] 

(b) The Permittee shall not allow emissions of carbon monoxide from any 

incinerator in excess of 500 ppm corrected to 50 percent excess air. [35 

IAC 216.141, Construction Permits 83120053, 87100024 and 88010001] 

VES017473 
Veolia ES Technical Solutions, L.L.C. Page 12 of 172 

Permit No.: V-IL-1716300103-2014-10 

Issuance Date: DRAFT 

ExpirationDate: DRAFT 

(c) The Permittee shall not allow emissions of carbon monoxide in excess of 

6.6 tpy from Unit 2, 6.6 tpy from Unit 3 and 13.86 tpy from Unit 4. 

[Construction Permits 87100024 and 88010001] 

4. Particulate Matter Limitations. 

(a) The Permittee shall not cause or allow the emission of particulate matter 

into the atmosphere from any incinerator burning more than 0.907 

megagram per hour (Mg/hr; 2,000 pounds per hour (lb/hr)) but less than 

27.2 Mg/hr (60,000 lb/hr) of refuse to exceed 183 milligrams per standard 

cubic meter (mg/scm; 0.08 grain per standard cubic foot (gr/scf)) of 

effluent gases corrected to 12 percent carbon dioxide. [35 IAC 212.181(b), 

Construction Permit 83120053] 

(b) The Permittee shall not allow emissions of particulate matter from the 

facility in excess of 0.013 gr/dscf, corrected to 7 percent oxygen. 

[40 C.F.R. §63.1219(a)(7)] 

(c) The Permittee shall not allow emissions of total suspended particulate 

matter from the facility in excess of 15.0 tpy from Unit 2, 15.0 tpy from 

Unit 3, and 16.92 tpy from Unit 4. [Construction Permits 87100024 and 

88010001] 

5. Volatile Organic Compounds Limitations. 

(a) The Permittee shall not cause or allow the discharge of more than 3.6 kg/hr 

(8 lbs/hr) of organic material into the atmosphere from any emission unit, 

except that, if no odor nuisance exists, this limitation shall apply only to 

photochemically reactive material. Alternatively, the Permittee may use a 

control device to reduce such emissions either to 10 ppm equivalent 

methane (molecular weight 16) or less, or to convert 85 percent of the 

hydrocarbons to carbon dioxide and water. [35 IAC 219.301, 219.302] 

(b) Organic material emissions from the facility shall not exceed 0.9 tpy from 

Unit 2, 0.9 tpy from Unit 3, and 3.1 tpy from Unit 4. [Construction Permits 

87100024 and 88010001] 

6. Nitrogen Oxide Limitations. 

Nitrogen oxide emissions from the facility shall not exceed 4.0 tpy from Unit 2, 

4.0 tpy from Unit 3, and 61.6 tpy from Unit 4. [Construction Permits 87100024 

and 88010001] 

7. Hazardous Air Pollutant Limitations. 

VES017474 
Veolia ES Technical Solutions, L.L.C. Page 13 of 172 

Permit No.: V-IL-1716300103-2014-10 

Issuance Date: DKA;PT 

ExpirationDate: DRAFT 

(a) The Permittee shall not allow emissions of dioxins and furans from the 

facility in excess of 0.20 nanograms toxicity equivalents per dry standard 

cubic meter (ng TEQ/dscm), corrected to 7 percent oxygen. [40 C.F.R. 

§ 63.1219(a)(1)] 

(b) The Permittee shall not allow emissions of mercury from the facility in 

excess of 130 micrograms per dry standard cubic meter (ug/dscm), 

corrected to 7 percent oxygen. [40 C.F.R. § 63.1219(a)(2)] 

(c) The Permittee shall not allow combined emissions of cadmium and lead 

from the facility in excess of 230 ug/dscm, corrected to 7 percent oxygen. 

[40 C.F.R. § 63.1219(a)(3)] 

(d) The Permittee shall not allow combined emissions of arsenic, beryllium, 

and chromium from the facility in excess of 92 ug/dscm, corrected to 

7 percent oxygen. [40 C.F.R. § 63.1219(a)(4)] 

(e) The Permittee shall design, install, operate, and maintain a treatment 

process that destroys benzene in the waste stream by incinerating the waste 

in a combustion unit that achieves a destruction efficiency of 99 percent or 

greater for benzene. [40 C.F.R. § 61.348(a)(l)(iii)] 

(f) All joints or seams between the pipe sections of any transfer system that 

consists of continuous hard-piping shall be permanently or semipermanently sealed (e.g., a welded joint between two sections of metal pipe 

or a bolted and gasketed flange). [40 C.F.R. § 63.689(c)(2)] 

8. Hydrogen Chloride Limitations. 

(a) The Permittee shall not allow combined emissions of hydrogen chloride 

and chlorine gas (total chlorine) from the facility in excess of 32 ppm by 

volume, expressed as a chloride (Cl -) equivalent, dry basis and corrected to 

7 percent oxygen. [40 C.F.R. § 63.1219(a)(6)] 

(b) The Permittee shall not allow hydrogen chloride emissions in excess of 4.0 

pounds per hour (lbs/hr) from either Unit 2 or Unit 3 or the control devices 

shall demonstrate a minimum hydrogen chloride removal efficiency of 99 

percent. [Construction Permits 83120053 and 87100024] 

9. Destruction and Removal Efficiency (DRE) Standard. 

(a) Units 2, 3 and 4 must each achieve a DRE of 99.99 percent for each 

principle organic hazardous constituent (POHC) specified under condition 

2.1(A)(9)(c)(ii), below. The Permittee shall calculate the DRE for each 

POHC using the following equation: 

VES017475 
Veolia ES Technical Solutions, L.L.C. Page 14 of 172 

Permit No.: V-IL-1716300103-2014-10 

Issuance Date: DRAFT 

Expiration Date: DRAFT 

DRE = [1-(WOUT/WIN)] X 100% 

Where: 

WIN = mass feedrate of one POHC in a waste feedstream; and 

WOUT

 = mass emission rate of the same POHC present in exhaust 

emissions prior to release to the atmosphere. 

The Permittee must perform intermediate calculations using at least three 

significant figures, but may round the resultant emission levels to two 

significant figures to document compliance. [40 C.F.R. § 63.1219(c)(1) 

and (d)] 

(b) For dioxin-listed hazardous wastes F020, F021, F022, F023, F026, or F027 

(see 40 C.F.R. § 261.31), Units 2, 3 and 4 must each achieve a DRE of 

99.9999 percent for each POHC specified under condition 2.1(A)(9)(c)(ii), 

below. The Permittee must demonstrate this DRE performance on POHCs 

that are more difficult to incinerate than tetra-, penta-, and 

hexachlorodibenzo-p-dioxins and dibenzofurans. The Permittee must use 

the equation in condition 2.1(A)(9)(a), above, to calculate DRE for each 

POHC. In addition, the Permittee must notify the Administrator of its 

intent to incinerate hazardous wastes F020, F021, F022, F023, F026, or 

F027. [40 C.F.R. § 63.1219(c)(2)] 

(c) Principal organic hazardous constituents [40 C.F.R. § 63.1219(c)(3)] 

(i) The Permittee must treat the POHCs in the waste feed that the 

Permittee specifies under condition 2.1(A)(9)(c)(ii), below, to the 

extent required by 40 C.F.R. § 63.1219(c)(1) and (c)(2). 

(ii) The Permittee must specify one or more POHCs that are 

representative of the most difficult to destroy organic compounds in 

the hazardous waste feedstream. The Permittee must base this 

specification on the degree of difficulty of incineration ofthe organic 

constituents in the waste and on their concentration or mass in the 

waste feed, considering the results of waste analyses or other data 

and information. 

(B) Nonapplicable Regulations [40 C.F.R. § 71.6(f)(1)] 

1. Units 2, 3 and 4 are not subject to 40 C.F.R. Part 64, Compliance Assurance 

Monitoring (CAM) for Major Stationary Sources, because: 

VES017476 
Veolia ES Technical Solutions, L.L.C. Page 15 of 172 

Permit No.: V-IL-1716300103-2014-10 

Issuance Date: DRAFT 

Expiration Date: DRAFT 

(a) The affected units are required to comply with a NESHAP proposed after 

November 15, 1990. Emission limitations or standards proposed by the 

Administrator after November 15, 1990 pursuant to section 111 or 112 of 

the Act are exempt from CAM. [40 C.F.R. § 64.2(b)(l)(i)] 

2. Units 2, 3 and 4 are not subject to 35 IAC Part 229 ofthe Illinois State 

Implementation Plan (SIP), "Hospital Medical Infectious Waste Incinerators," 

because the Permittee is prohibited from accepting or processing hospital 

medical infectious waste at the facility. [35 IAC 229.110] 

(C) Work Practice and Operational Requirements [40 C.F.R. § 71.6(a)(1)] 

1. The Permittee shall not burn hospital medical infectious waste, municipal waste, 

or waste that is subject to the Beryllium NESHAP. [42 U.S.C. § 7661c(a)] 

2. The Permittee must operate Units 2, 3 and 4 in compliance with the following 

operating parameter limits (OPLs). The Permittee must also comply with the 

OPLs contained in the Notification of Compliance (NOC) required pursuant to 

condition 2.1(E)(2), below. If any OPL contained in this condition 2.1(C)(2) 

differ from the corresponding OPL contained in the Permittee's most recent 

NOC, the Permittee may submit an application requesting a revision to the OPLs 

in this permit, pursuant to 40 C.F.R. § 71.7(e)(1). Nothing in this permit 

obligates the Administrator to approve an application to revise OPLs in this 

permit. 

0|ii'i.itiii!> I'sii.iHiflit 

OPI A\eraging 

0|ii'i.itiii!> I'sii.iHiflit 

I ml n 1 mi 3 Unit #4 Pci iod 

Minimum primary 

combustion chamber 

temperature (40 C.F.R. 

§ 63.1209(j)(l),(k)(2)) 

1,709 °F 1,709 °F 1,561 °F hourly rolling 

average 

Minimum secondary 

combustion chamber 

temperature (40 C.F.R. 

§ 63.1209(i)(l), (k)(2)) 

1,885 °F 1,850 °F 1,881 °F hourly rolling 

average 

Maximum flue gas 

flowrate or production 

rate (40 C.F.R. 

§ 63.12090(2)), (k)(3), 

(m)(2), (n)(5), (o)(2)) 

15,310 acf/min 15,310 acf/min 37,393 acf/min hourly rolling 

average 

Maximum hazardous 

waste pumpable 

feedrate rate for each 

3,107 lbs/hr 3,107 lbs/hr 3,312 lbs/hr for 

PCC and 1,203 

lbs/hr for SCC 

hourly rolling 

average 

VES017477 
Veolia ES Technical Solutions, L.L.C. Page 16 of 172 

Permit No.: V-IL-1716300103-2014-10 

Issuance Date: DRAFT 

ExpirationDate: DRAFT 

Operating Wramyer 

• . • 

.^Averaging Operating Wramyer 

l nil 12 I nil - 3 L i t 44 

combustion chamber 

(40 C.F.R. 

§ 63.1209(0(3), (k)(4)) 

Maximum hazardous 

waste total feedrate rate 

for each combustion 

chamber (40 C.F.R. 

§ 63.1209(0(3), (k)(4)) 

4,017 lbs/hr 4,017 lbs/hr 10,632 lbs/hr 

for PCC and 

1,203 lbs/hr for 

SCC 

hourly rolling 

average 

Operation of waste 

firing system for each 

location where waste is 

fed to the incinerator 

(40 C.F.R. 

§ 63.12090(4)) 

Minimum 

waste 

atomization 

pressure follow BTU 

waste - 15 psi 

Minimum 

waste 

atomization 

pressure for 

low BTU 

waste -15 psi 

Minimum 

waste 

atomization 

pressure for 

low BTU 

waste - 15 psi 

Instantaneous 

Maximum temperature 

of the gas at the inlet to 

a dry particulate matter 

control device (i.e., 

baghouse inlet) 

(40 C.F.R. 

§ 63.1209(k)(l)), 

(n)(D) 

420 °F 420 °F 399 °F hourly rolling 

average 

Minimum carbon 

injection rate 

(40 C.F.R. 

§ 63.1209(k)(6)(i)) 

N/A N/A 6.2 lbs/hr hourly rolling 

average 

Minimum carrier fluid 

(gas or liquid) flowrate 

or pressure drop for 

activated carbon 

injection system 

(40 C.F.R. 

§ 63.1209(k)(6)(ii)) 

N/A N/A 3.10 gal/lb Cl 2 hourly rolling 

average 

The brand (i.e., 

manufacturer) and type 

of carbon used during 

the comprehensive . 

performance test 

(40 C.F.R. 

§ 63.1209(k)(6)(iii)) 

N/A N/A NORIT 

Americas Inc. 

DARCO® 

FGL 

VES017478 
Veolia ES Technical Solutions, L.L.C. Page 17 of 172 

Permit No.: V-IL-1716300103-2014-10 

Issuance Date- DRAFT 

ExpirationDate: DRAFT 

Operating Pai .imttLi 

Averaging ' k 

Period ' \ Operating Pai .imttLi 

i nit -

-fi-'{.:

 B ' 

I-mt^V 

Averaging ' k 

Period ' \ 

Maximum total 

feedrate of mercury (40 

C F R 

§ 63.1209(l)(l)(i)) 

0.0021 lbs/hr 0.0021 lbs/hr 0.040 lbs/hr 12-hour 

rolling 

average 

Maximum ash feedrate 

(40 C.F.R. 

§ 63.1209(m)(3)) 

503 lbs/hr 503 lbs/hr 4,777 lbs/hr 12-hour 

rolling 

average 

Maximum total 

feedrate of semivolatile 

metals (40 C.F.R. 

§ 63.1209(n)(2)(ii)) 

62 lbs/hr 62 lbs/hr 62 lbs/hr 12-hour 

rolling 

average 

Maximum total 

feedrate of low volatile 

metals (40 C.F.R. 

§ 63.1209(n)(2)(ii)) 

46 lbs/hr 46 lbs/hr 46 lbs/hr 12-hour 

rolling 

average 

Feedrate limits for low 

volatile metals in 

pumpable feedstreams 

(40 C.F.R. 

§ 63.1209(n)(2)(vii)) 

46 lbs/hr 46 lbs/hr 46 lbs/hr 12-hour 

rolling 

average 

Feedrate of total 

chlorine and chloride in 

all feedstreams 

(40 C.F.R. 

§ 63.1209(n)(4), (o)(l)) 

204 lbs/hr 204 lbs/hr 203 lbs/hr 12-hour 

rolling 

average 

Minimum sorbent 

feedrate (40 C.F.R. 

§ 63.1209(o)(4)(i)) 

2.24 lb/lb Cl 2 2.24 lb/lb Cl 2 2.13 lb/lb Ch hourly rolling 

average 

Minimum carrier fluid 

flowrate or nozzle 

pressure drop for the 

spray dry adsorber 

(40 C.F.R. § 

63.1209(o)(4)(ii)) 

1.90 gal/lb Ch 1.90 gal/lb Ch 3.10 gal/lb Ch hourly rolling 

average 

The brand (z'.e., 

manufacturer) and type 

of sorbent used during 

the comprehensive 

performance test 

(40 C.F.R. § 63.1209 

(o)(4)(iii)(A)) 

Mississippi 

Lime 

Company 

Hydrated Lime 

Code MR200 

Mississippi 

Lime 

Company 

Hydrated Lime 

Code MR200 

Mississippi 

Lime 

Company 

Hydrated Lime 

CodeMR200 

VES017479 
Veolia ES Technical Solutions, L.L.C. Page 18 of 172 

Permit No.: V-IL-1716300103-2014-10 

Issuance Date. DRAFT 

ExpirationDate: DRAFT 

Operatiii!! Piir.imclci i^ilfeilliliJilw 

Period Operatiii!! Piir.imclci 

luff 2 Unit #3 1 ml -*4 Period 

Maximum combustion 

chamber pressure 

(40 C.F.R. § 

63.1209(p)) 

-0.01 inch H2O -0.01 inchFfcO -0.01 inchHbO 5 seconds for 

Units 2 and 3 

and 

instantaneous 

for Unit 4 

3. Compliance with standards. [40 C.F.R, § 63.1206(b)(1)] 

The emission standards and operating requirements derived from 40 C.F.R. 

Part 63, Subpart EEE, apply at all times except: 

(a) During periods of startup, shutdown, and malfunction; and 

(b) When hazardous waste is not in the combustion chamber (i.e., the 

hazardous waste feed to the combustor has been cut off for a period of time 

not less than the hazardous waste residence time) and the Pennittee has 

documented in the operating record compliance with all otherwiseapplicable requirements and standards promulgated under authority of 

sections 112 (e.g., 40 C.F.R. Part 63, Subparts LLL, DDDDD, and 

NNNNN) or 129 of the Clean Air Act in lieu of the emission standards 

under 40 C.F.R. §§ 63.1203, 63.1204, 63.1205, 63.1215, 63.1216, 63.1217, 

63.1218, 63.1219, 63.1220, and 63.1221; the monitoring and compliance 

standards of 40 C.F.R. §§ 63.1206 through 63.1209, except the modes of 

operation requirements of § 63.1209(q); and the notification, reporting, and 

recordkeeping requirements of §§ 63.1210 through 63.1212. 

4. Changes in design, operation, or maintenance. [40 C.F.R. § 63.1206(b)(5)] 

(a) If the Permittee plans to change (as defined in 40 C.F.R. 

§ 63.1206(b)(5) (iii)) the design, operation, or maintenance practices ofthe 

source in a manner that may adversely affect compliance with any emission 

standard that is not monitored with a CEMS, the Permittee must not burn 

hazardous waste for more than a total of 720 hours (renewable at the 

discretion of the Administrator) and only for the purposes of pretesting or 

comprehensive performance testing. Pretesting is defined at 40 C.F.R. 

§ 63.1207(h)(2)(i) and (ii). [40 C.F.R. § 63.1206(b)(5)(i)(C)(l)] 

(i) The Permittee may petition the Administrator to obtain written 

approval to burn hazardous waste in the interim prior to submitting a 

Notification of Compliance for purposes other than testing or 

pretesting. The Permittee must specify operating requirements, 

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including limits on operating parameters that the Permittee 

determines will ensure compliance with the emission standards of 

40 C.F.R. Part 63, Subpart EEE, based on available information. 

The Administrator will review, modify as necessary, and approve if 

warranted the interim operating requirements. [40 C.F.R. 

§ 63.1206(b)(5)(i)(C)(2)] 

(ii) Nothing in this permit exempts any changes made under this 

provision from any applicable requirements under Title I of the 

CAA. [40 C.F.R. § 71.6(a)(1)] 

(b) Notification. [40 C.F.R. § 63.1206(b)(5)] 

The Permittee must comply with the notification requirements of condition 

2.1(E)(9), below. 

5. General Operating Requirements. [40 C.F.R. § 63.1206(c)(1)] 

(a) The Permittee must operate under the operating requirements specified in 

the Documentation of Compliance (DOC) under 40 C.F.R. § 63.1211(c) or 

the NOC under 40 C.F.R. §§ 63.12070) and 63.1210(d), except: 

(i) During performance tests under approved test plans according to 40 

C.F.R. § 63.1207(e), (f), and (g); 

(ii) Under the provisions of condition 2.1(C)(3)(a) or (b), above; and 

(iii) As provided by condition 2.1(C)(2), above. 

(b) Documentation of Compliance. [40 C.F.R. § 63.1211(c)] 

The Permittee's operating record must include a DOC. The DOC must 

identify the applicable emission standards under 40 C.F.R. Part 63, Subpart 

EEE, and the limits on the operating parameters under 40 C.F.R. § 63.1209 

that will ensure compliance with those emission standards. 

(c) Failure to comply with the operating requirements is failure to ensure 

compliance with the emission standards of 40 C.F.R. Part 63, Subpart EEE. 

6. Startup, Shutdown, and Malfunction Plan. [40 C.F.R. §§ 63.6(e)(3), 

63.1206(c)(2)] 

(a) The Permittee is subject to the startup, shutdown, and malfunction plan 

requirements of 40 C.F.R. § 63.6(e)(3). [40 C.F.R. § 63.1206(c)(2)(i)] 

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(i) The Permittee must develop a written startup, shutdown, and 

malfunction plan that describes, in detail, procedures for operating 

and maintaining the source during periods of startup, shutdown, and 

malfunction; and a program of corrective action for malfunctioning 

process, air pollution control, and monitoring equipment used to 

comply with the relevant standard. The startup, shutdown, and 

malfunction plan does not need to address any scenario that would 

not cause the source to exceed an applicable emission limitation in 

the relevant standard. The purpose of the startup, shutdown, and 

malfunction plan is to: 

A. Ensure that, at all times, the Permittee operates and maintains 

each affected source, including associated air pollution control 

and monitoring equipment, in a manner which satisfies the 

general duty to minimize emissions established by 40 C.F.R. 

§ 63.6(e)(l)(i); 

B. Ensure that the Permittee is prepared to correct malfunctions as 

soon as practicable after their occurrence in order to minimize 

excess emissions of hazardous air pollutants; and 

C. Reduce the reporting burden associated with periods of startup, 

shutdown, and malfunction (including corrective action taken 

tp restore malfunctioning process and air pollution control 

equipment to its normal or usual manner of operation). 

[40 C.F.R. § 63.6(e)(3)(i)] 

(ii) The Permittee must maintain at the affected source a current startup, 

shutdown, and malfunction plan and must make the plan available 

upon request for inspection and copying by the Administrator. In 

addition, if the startup, shutdown, and malfunction plan is 

subsequently revised as provided in 40 C.F.R. § 63.6(e)(3)(viii), the 

Permittee must maintain at the affected source each previous (i.e., 

superseded) version of the startup, shutdown, and malfunction plan, 

and must make each previous version available for inspection and 

copying by the Administrator for a period of 5 years after revision of 

the plan. If at any time after adoption of a startup, shutdown, and 

malfunction plan an affected source ceases operation or is otherwise 

no longer subject to the provisions of this part, the Permittee must 

retain a copy of the most recent plan for 5 years from the date the 

source ceases operation or is no longer subject to 40 C.F.R. Part 63, 

and must make the plan available upon request for inspection and 

copying by the Administrator. Upon receipt of a written request 

from the Administrator that the Permittee submit a copy of any 

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startup, shutdown and malfunction plan (or portion thereof) which 

the Permittee maintains at the affected source or which is in the 

possession of the Permittee, the Permittee must promptly submit a 

copy ofthe requested plan (or a portion thereof).to the 

Administrator. The Permittee may elect to submit the required copy 

of any startup, shutdown, and malfunction plan to the Administrator 

in an electronic format. The Permittee may claim that any portion of 

such a startup, shutdown, and malfunction plan is confidential 

business information (CBI) entitled to protection from disclosure 

under section 114(c) ofthe Act or 40 C.F.R. § 2.301. If the 

Permittee makes a CBI claim, it must clearly designate in the 

submission the material which it claims as confidential. [40 C.F.R. 

§ 63.6(e)(3)(v)] 

(iii) To satisfy the requirements of 40 C.F.R. § 63.6 to develop a startup, 

shutdown, and malfunction plan, the Permittee may use the affected 

source's standard operating procedures (SOP) manual, an 

Occupational Safety and Health Administration (OSHA), or other 

plan, provided the alternative plans meet all the requirements of 40 

C.F.R. § 63.6 and the Permittee makes the alternative plans available 

for inspection when requested by the Administrator. [40 C.F.R. 

§ 63.6(e)(3)(vi)] 

(iv) The Permittee must revise the startup, shutdown and malfunction 

plan if required by the Administrator to do so based on the results of 

a determination made under 40 C.F.R. § 63.6(e)(l)(i), or if the 

Administrator finds that the plan: 

A. Does not address a startup, shutdown, or malfunction event that 

has occurred; 

B. Fails to provide for the operation of the source (including 

associated air pollution control and monitoring equipment) 

during a startup, shutdown, or malfunction event in a manner 

consistent with the general duty to minimize emissions 

established by 40 C.F.R. § 63.6(e)(l)(i); 

C. Does not provide adequate procedures for correcting 

malfunctioning process and/or air pollution control and 

monitoring equipment as quickly as practicable; or 

D. Includes an event that does not meet the definition of startup, 

shutdown, or malfunction listed in 40 C.F.R. § 63.2. 

[40 C.F.R. § 63.6(e)(3)(vii)] 

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(v) The Permittee may periodically revise the startup, shutdown, and 

malfunction plan for the affected source as necessary to satisfy the 

requirements of 40 C.F.R. Part 63 or to reflect changes in equipment 

or procedures at the affected source. The Permittee may make such 

revisions to the startup, shutdown, and malfunction plan without 

prior approval by the Administrator or the permitting authority. 

However, the Permittee must report each revision to the startup, 

shutdown, and malfunction plan in the semiannual report required by 

40 C.F.R. § 63.10(d)(5). If the startup, shutdown, and malfunction 

plan fails to address or inadequately addresses an event that meets 

the characteristics of a malfunction but was not included in the 

startup, shutdown, and malfunction plan at the time the Permittee 

developed the plan, the Permittee must revise the startup, shutdown, 

and malfunction plan within 45 days after the event to include 

detailed procedures for operating and maintaining the source during 

similar malfunction events, and a program of corrective action for 

similar malfunctions of process or air pollution control and 

monitoring equipment. In the event that the Permittee makes any 

revision to the startup, shutdown, and malfunction plan which alters 

the scope of the activities at the source which are deemed to be a 

startup, shutdown, or malfunction, or otherwise modifies the 

applicability of any emission limit, work practice requirement, or 

other requirement in a standard established under 40 C.F.R. Part 63, 

the revised plan shall not take effect until after the Permittee has 

provided a written notice describing the revision to the 

Administrator. [40 C.F.R. § 63.6(e)(3)(viii)] 

(vi) Any revisions made to the startup, shutdown, and malfunction plan 

in accordance with the procedures established by 40 C.F.R. Part 63 

shall not be deemed to constitute revisions to this permit, and the 

elements ofthe startup, shutdown, and malfunction plan shall not be 

considered an applicable requirement as defined in 40 C.F.R. §§ 70.2 

and 71.2. [40 C.F.R. § 63.6(e)(3)(ix)] 

(vii) The procedures specified in the startup, shutdown, and malfunction 

plan do not fall within the permit shield provided in condition 4.21 

ofthis permit. [40 C.F.R. § 63.6(e)(3)(ix)] 

(b) The Permittee is subject to the following provisions of 40 C.F.R. 

§ 63.1206(c)(2) and (3): 

(i) The Permittee must identify in the startup, shutdown, and 

malfunction plan a projected oxygen correction factor, based on 

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normal operations, to use during periods of startup and shutdown. 

[40 C.F.R. § 63.1206(c)(2)(iii)] 

(ii) The Permittee must record the startup, shutdown, and malfunction 

plan in the operating record. [40 C.F.R. § 63.1206(c)(2)(iv)] 

(iii) Operating under the startup, shutdown, and malfunction plan: 

[40 C.F.R. § 63.1206(c)(2)(v)(A)] 

A. Compliance with automatic waste feed cutoff (AWFCO) 

requirements during malfunctions: 

I. During malfunctions, the AWFCO requirements of 

condition 2.1(C)(7) ofthis permit continue to apply, 

except for condition 2.1 (C)(7)(e). If there is an 

exceedance of a 40 C.F.R. Part 63, Subpart EEE, 

emission standard monitored by a CEMS or COMS or 

operating limit specified under 40 C.F.R. § 63.1209, the 

automatic waste feed cutoff system must immediately 

and automatically cutoff the hazardous waste feed, 

except as provided by condition 2.1(C)(7)(f) of this 

permit. If the malfunction itself prevents immediate and 

automatic cutoff of the hazardous waste feed, the 

Permittee must cease feeding hazardous waste as quickly 

as possible. 

II. Although the automatic waste feed cutoff requirements 

continue to apply during a malfunction, an exceedance 

of an emission standard monitored by a CEMS or 

COMS or operating limit specified under 40 C.F.R. 

§ 63.1209 is not a violation of 40 C.F.R. Part 63, 

Subpart EEE, if the source continues to operate in 

accordance with 40 C.F.R. § 63.6(e)(1)]. [40 C.F.R. 

§ 63.1206(c)(2)(v)(A)(2)] 

III. Excessive number of exceedances during malfunctions. 

For each set of 10 exceedances of an emission standard 

or operating requirement while hazardous waste remains 

in the combustion chamber (i.e., when the hazardous 

waste residence time has not transpired since the 

hazardous waste feed was cutoff) during a 60-day block 

period, the Permittee must: 

(aa) Within 45 days ofthe 10th exceedance, complete 

an investigation ofthe cause of each exceedance 

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and evaluation of approaches to minimize the 

frequency, duration, and severity of each 

exceedance, and revise the startup, shutdown, and 

malfunction plan as warranted by the evaluation 

to minimize the frequency, duration, and severity 

of each exceedance; and 

(bb) Record the results of the investigation and 

evaluation in the operating record, and include a 

summary of the investigation and evaluation, and 

any changes to the startup, shutdown, and 

malfunction plan, in the excess emissions report 

required under condition 2.1(D) of this permit and 

40 C.F.R. § 63.10(e)(3). [40 C.F.R. 

§ 63.1206(c)(2)(v)(A)] 

B. Compliance with AWFCO requirements when burning 

hazardous waste during startup and shutdown: [40 C.F.R. 

§ 63.1206(c)(2)(v)(B)] 

I. If the Permittee feeds hazardous waste during startup or 

shutdown, the Permittee must include waste feed 

restrictions (e.g., type and quantity), and other 

appropriate operating conditions and limits in the 

startup, shutdown, and malfunction plan. [40 C.F.R. 

§ 63.1206(c)(2)(v)(B)(l)] 

II. The Permittee must interlock the operating limits 

established under condition 2.1 (C)(6)(iii)(B)(l), above, 

with the automatic waste feed cutoff system required 

under condition 2.1(C)(7), except for condition 

2.1(C)(7)(e). [40 C.F.R. § 63.1206(c)(2)(v)(B)(2)] 

III. When feeding hazardous waste during startup or 

shutdown, the automatic waste feed cutoff system must 

immediately and automatically cutoff the hazardous 

waste feed if the Permittee exceeds the operating limits 

established under condition 2.1(C)(6)(b)(iii)(B)(l) of 

this permit, except as provided by condition 2.1(C)(7). 

[40 C.F.R. § 63.1206(c)(2)(v)(B)(3)] 

IV. Although the automatic waste feed cutoff requirements 

of 40 C.F.R. § 63.1206 (c)(2)(v)(B)(4) apply during 

startup and shutdown, an exceedance of an emission 

standard or operating limit is not a violation of Subpart 

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EEE if the Permittee operates in accordance with 40 

C.F.R. § 63.6(e)(1). [40 C.F.R. 

§ 63.1206(c)(2)(v)(B)(4)] 

(c) The Permittee shall not cause or allow the continued operation of an 

emission source during malfunction or breakdown of the emission source 

or related air pollution control equipment if such operation would cause a 

violation of the standards or limitations set forth in the Illinois 

Administrative Code, Subchapter c: Emission Standards and Limitations 

for Stationary Sources. The Permittee shall not cause or allow violation of 

the standards or limitations set forth in Subchapter c: Emission Standards 

and Limitations for Stationary Sources during startup. [35 IAC 201.149] 

7. Automatic waste feed cutoff (AWFCO). [40 C.F.R. § 63.1206(c)(3)] 

(a) The Permittee must operate the hazardous waste combustor with a 

functioning AWFCO system that immediately and automatically cuts off 

the hazardous waste feed, except as provided by condition 2.1(C)(7)(f): 

(i) When any of the following are exceeded: Operating parameter limits 

specified under condition 2.1(C) ofthis permit and 40 C.F.R. 

§ 63.1209; an emission standard monitored by a CEMS; and the 

allowable combustion chamber pressure; 

(ii) When the span value of any CMS detector, except a CEMS, is met or 

exceeded; 

(iii) Upon malfunction of a CMS monitoring an operating parameter limit 

specified under condition 2.1(C) of this permit and 40 C.F.R. 

§ 63.1209 or an emission level; or 

(iv) When any component of the AWFCO system fails. [40 C.F.R. 

§ 63.1206(c)3)(i)] 

(b) Ducting of combustion gases. During an AWFCO, the Permittee must 

continue to duct combustion gasses to the air pollution control system 

while hazardous waste remains in the combustion chamber (i.e., if the 

hazardous waste residence time has not transpired since the hazardous 

waste feed cutoff system was activated). [40 C.F.R. § 63.1206(c)(3)(H)] 

(c) Restarting waste feed. The Permittee must continue to monitor during the 

cutoff the operating parameters for which limits are established under 

condition 2.1(C) of this permit and 40 C.F.R. § 63.1209 and the emissions 

required under that section to be monitored by a CEMS, and must not 

restart the hazardous waste feed until the operating parameters and 

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emission levels are within the specified limits. [40 C.F.R. 

§ 63.1206(c)(3)(iii)] 

(d) Failure ofthe AWFCO system. If the AWFCO system fails to 

automatically and immediately cut off the flow of hazardous waste upon 

exceedance of a parameter required to be interlocked with the AWFCO 

system under condition 2.1(C)(7)(a), the Permittee has failed to comply 

with the AWFCO requirements of condition 2.1(C)(7). If an equipment or 

other failure prevents immediate and automatic cutoff of the hazardous 

waste feed, however, the Permittee must cease feeding hazardous waste as 

quickly as possible. [40 C.F.R. § 63.1206(c)(3)(iv)] 

(e) Corrective measures. If, after any AWFCO, there is an exceedance of an 

emission standard or operating requirement, irrespective of whether the 

exceedance occurred while hazardous waste remained in the combustion 

chamber (i.e., whether the hazardous waste residence time has transpired 

since the hazardous waste feed cutoff system was activated), the Permittee 

must investigate the cause of the AWFCO, take appropriate corrective 

measures to minimize future AWFCOs, and record the findings and 

corrective measures in the operating record. [40 CF.R. § 63.1206(c)(3)(v)] 

(f) Ramping down waste feed. [40 C.F.R. § 63.1206(c)(3)(viii)] 

(i) The Permittee may ramp down the waste feedrate of pumpable 

hazardous waste over a period not to exceed 1 minute, except as 

provided by condition 2.1(C)(7)(f)(ii) ofthis permit, below. If the 

Permittee elects to ramp down the waste feed, the Permittee must 

document ramp down procedures in the operating and maintenance 

plan. The procedures must specify that the ramp down begins 

immediately upon initiation of AWFCO and the procedures must 

prescribe a bona fide ramping down. If an emission standard or 

operating limit is exceeded during the ramp down, the Permittee has 

failed to comply with the emission standards or operating 

requirements of 40 C.F.R. Part 63, Subpart EEE. 

(ii) If the AWFCO is triggered by an exceedance of any of the following 

operating limits, the Permittee may not ramp down the waste feed 

cutoff: minimum combustion chamber temperature, maximum 

hazardous waste feedrate, or any hazardous waste firing system 

operating limits that may be established for its combustor. 

(g) Compliance with the AWFCO requirements in 40 C.F.R. Part 63, Subpart 

EEE, will assume compliance with the requirements for a waste feed cutoff 

interlock system and sensors required by construction permits 87100024, 

88010001, and 83120053. [40 C.F.R. § 71.6(a)(3)(i)(A)] 

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8. Emergency safety vent (ESV) openings. [40 C.F.R. § 63.1206(c)(4)] 

(a) Failure to meet standards. If an ESV opens when hazardous waste remains 

in the combustion chamber (i.e., when the hazardous waste residence time 

has not expired) during an event other than a malfunction as defined in the 

startup, shutdown, and malfunction plan such that combustion gases are not 

treated as during the most recent comprehensive performance test (e.g., if 

the combustion gas by-passes any emission control device that was 

operating during the performance test), the Permittee must document in the 

operating record whether the source remained in compliance with the 

emission standards of 40 CF.R. Part 63, Subpart EEE, considering 

emissions during the ESV opening event. [40 CF.R. § 63.1206(c)(4)(i)] 

(b) ESV operatmg plan. [40 C.F.R. § 63.1206(c)(c)(4)(ii)] 

(i) The Permittee must develop an ESV operating plan, comply with the 

operating plan, and keep the plan in the operating record. 

(ii) The ESV operating plan must provide detailed procedures for rapidly 

stopping the waste feed, shutting down the combustor, and, if 

feasible, maintaining temperature and negative pressure in the 

combustion chamber during the hazardous waste residence time. 

The plan must include calculations, information and data 

documenting the effectiveness of the plan's procedures for ensuring 

that combustion chamber temperature and negative pressure are 

maintained as is reasonably feasible. 

(c) Corrective measures. After any ESV opening that results in a failure to 

meet the emission standards as defined in condition 2.1(C)(8)(a) of this 

permit, the Permittee must investigate the cause of the ESV opening, take 

appropriate corrective measures to minimize such future ESV openings, 

and record the findings and corrective measures in the operating record. 

[40 C.F.R. § 63.1206(c)(4)(iii)] 

9. Combustion system leaks. [40 C.F.R. § 63.1206(c)(5)] 

(a) The Permittee must control combustion system leaks of hazardous air 

pollutants by maintaining the maximum combustion zone pressure lower 

than ambient pressure using an instantaneous monitor; and [40 C.F.R. 

§ 63.1206(c)(5)(i)(B)] 

(b) The Permittee must specify in the performance test work plan and NOC 

the method that it will use to control combustion system leaks. Because 

the Permittee controls combustion system leaks by maintaining the 

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combustion zone pressure lower than ambient pressure using an 

instantaneous monitor, the Permittee must also specify in the performance 

test work plan and NOC the monitoring and recording frequency of the 

pressure monitor, and specify how the monitoring approach is integrated 

into the automatic waste feed cutoff system. [40 C.F.R. 

§ 63.1206(c)(5)(h)] 

10. Operator training and certification. [40 C.F.R. § 63.1206(c)(6)] 

(a) The Permittee must establish training programs for all categories of 

personnel whose activities may reasonably be expected to directly affect 

emissions of hazardous air pollutants from the source. Such persons 

include, but are not limited to, chief facility operators, control room 

operators, continuous monitoring system operators, persons that sample 

and analyze feedstreams, persons that manage and charge feedstreams to 

the combustor, persons that operate emission control devices, and ash and 

waste handlers. Each training program shall be of a technical level 

commensurate with the person's job duties specified in the training 

manual. Each commensurate training program shall require an 

examination to be administered by the instructor at the end of the training 

course. Passing of this test shall be deemed the "certification" for 

personnel, except that, for control room operators, the training and 

certification program shall be as specified in conditions 2.1(C)(10)(c) 

through (e) ofthis permit. [40 C.F.R. § 63.1206(c)(6)®] 

(b) The Permittee must ensure that the source is operated and maintained at all 

times by persons who are trained and certified to perform these and any 

other duties that may affect emissions of hazardous air pollutants. A 

certified control room operator must be on duty at the site at all times the 

source is in operation. [40 C.F.R. § 63.1206(c)(6)(ii)] 

(c) Hazardous waste incinerator control room operators must: [40 C.F.R. 

§ 63.1206(c)(6)(iii)] 

(i) Be trained and certified under a site-specific, source-developed and 

implemented program that meets the requirements of condition 

2.1(C)(10)(d), below; or 

(ii) Be trained under the requirements of, and certified under, one of the 

following American Society of Mechanical Engineers (ASME) 

standards: QHO-1-1994, QHO-la-1996, or QHO-1-2004 (Standard 

for the Qualification and Certification of Hazardous Waste 

Incinerator Operators). If the Permittee elects to use the ASME 

program: 

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A. Control room operators must, prior to the compliance date, 

achieve provisional certification, and must submit an 

application to ASME and be scheduled for the full certification 

exam. Within 1 year of the compliance date, control room 

operators must achieve full certification; 

B. New operators and operators of new sources must, before 

assuming their duties, achieve provisional certification, and 

must submit an application to ASME, and be scheduled for the 

full certification exam. Within 1 year of assuming their duties, 

these operators must achieve full certification; or 

(iii) Be trained and certified under a State program. 

(d) Site-specific, source developed and implemented training programs for 

control room operators must include the following elements: 

(i) Training on the following subjects: 

A. Environmental concerns, including types of emissions; 

B. Basic combustion principles, including products of 

combustion; 

C. Operation of the specific type of combustor used by the 

operator, including proper startup, waste firing, and shutdown 

procedures; 

D. Combustion controls and continuous monitoring systems; 

E. Operation of air pollution control equipment and factors 

affecting performance; 

F. Inspection and maintenance of the combustor, continuous 

monitoring systems, and air pollution control devices; 

G. Actions to correct malfunctions or conditions that may lead to 

malfunction; 

H. Residue characteristics and handling procedures; and 

I. Applicable federal, state, and local regulations, including 

Occupational Safety and Health Administration workplace 

standards; and , 

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(ii) An examination designed and administered by the instructor; and 

(iii) Written material covering the training course topics that may serve 

as reference material following completion of the course. 

[40 C.F.R. § 63.1206(c)(6)(v)] 

(e) To maintain control room operator qualification under a site-specific, 

source developed and implemented training program as provided by 

condition 2.1(C)(10)(d), above, control room operators must complete an 

annual review or refresher course covering, at a minimum, the following 

topics: 

(i) Update of regulations; 

(ii) Combustor operation, including startup and shutdown procedures, 

waste firing, and residue handling; 

(iii) Inspection and maintenance; 

(iv) Responses to malfunctions or conditions that may lead to 

malfunction; and 

(v) Operating problems encountered by the operator. 

[40 C.F.R. § 63.1206(c)(6)(vi)] 

(f) The Permittee must record the operator training and certification program 

in the operating record. [40 C.F.R. § 63.1206(c)(6)(vii)] 

11. Operation and maintenance plan. [40 C.F.R. § 63.1206(c)(7)] 

(a) The Permittee must prepare and at all times operate according to an 

operation and maintenance (O&M) plan that describes in detail procedures 

for operation, inspection, maintenance, and corrective measures for all 

components of the combustor, including associated pollution control 

equipment, that could affect emissions of regulated hazardous air 

pollutants. [40 C.F.R. § 63.1206(c)(7)(i)] 

(b) The plan must prescribe how the Permittee will operate and maintain the 

combustor in a manner consistent with good air pollution control practices 

for minimizing emissions at least to the levels achieved during the 

comprehensive performance test; [40 C.F.R. § 63.1206(c)(7)(ii)] 

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(c) This plan ensures compliance with the operation and maintenance 

requirements of 40 C.F.R. § 63.6(e) and minimizes emissions of 

pollutants, automatic waste feed cutoffs, and malfunctions. [40 C.F.R. 

§ 63.1206(c)(7)(iii)] 

(d) The Permittee must record the plan in the operating record. [40 C.F.R. 

§ 63.1206(c)(7)(iv)] 

(D) Monitoring and Testing [40 C.F.R. § 71.6(a)(3)(i)(A)] 

1. Continuous emissions monitoring systems (CEMS) and continuous opacity 

monitoring systems (COMS). [40 C.F.R. § 63.1209(a)]: 

(a) The Permittee must use either a carbon monoxide or hydrocarbon CEMS 

to demonstrate and monitor compliance with the carbon monoxide or 

hydrocarbon standard. The Permittee must also use an oxygen CEMS to 

continuously correct the carbon monoxide measurements to 7 percent 

oxygen. 

(b) After such time as the EPA promulgates all performance specifications 

and operational requirements applicable to PM CEMS, the Permittee must 

install, calibrate, maintain, and operate a P M CEMS to demonstrate and 

monitor compliance with the particulate matter standards under this 

permit. 

(c) Performance specifications. The Permittee must install, calibrate, 

maintain, and continuously operate all CEMS and COMS in compliance 

with the quality assurance procedures provided in the appendix to 40 

C.F.R. Part 63, Subpart EEE, and Performance Specifications 1 (opacity), 

4B (carbon monoxide and oxygen), and 8A (hydrocarbons) in Appendix B 

to 40 C.F.R. Part 60. 

(d) Carbon monoxide readings exceeding the span should be recorded in 

accordance with the following requirements of 40 C.F.R. § 63.1209(a)(3): 

(i) Except as provided by 40 C.F.R. § 63.1209(a)(3)(ii), if a carbon 

monoxide CEMS detects a response that results in a 1-minute 

average at or above the 3,000 ppmv span level required by 

Performance Specification 4B in Appendix B to 40 C.F.R. Part 60, 

the Permittee must record the 1-minute average as 10,000 ppmv. 

The Permittee must use the 1-minute 10,000 ppmv value for 

calculating the hourly rolling average carbon monoxide level. 

(ii) Carbon monoxide CEMS that use a span value of 10,000 ppmv when 

1-minute carbon monoxide levels are equal to or exceed 3,000 ppmv 

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are not subject to 40 C.F.R. § 63.1209(a)(3)(i). Carbon monoxide 

CEMS that use a span value of 10,000 are subject to the same CEMS 

performance and equipment specifications when operating in the 

range of 3,000 ppmv to 10,000 ppmv that are provided by 

Performance Specification 4B for other carbon monoxide CEMS, 

except: 

A. Calibration drift must be less than 300 ppmv; and 

B. Calibration error must be less than 500 ppmv. 

'(e) Hydrocarbon readings exceeding the span. 

(i) Except as provided by 40 C.F.R. § 63.1209(a)(4)(ii), if a 

hydrocarbon CEMS detects a response that results in a 1-minute 

average at or above the 100 ppmv span level required by 

Performance Specification 8A in Appendix B to 40 CF.R. Part 60, 

the Permittee must record the 1-minute average as 500 ppmv. The 

Permittee must use the 1-minute 500 ppmv value for calculating the 

hourly rolling average hydrocarbon level. 

(ii) Hydrocarbon CEMS that use a span value of 500 ppmv when 

1-minute hydrocarbon levels are equal to or exceed 100 ppmv are 

not subject to 40 C.F.R. § 63.1209(a)(4)(f). Hydrocarbon CEMS that 

use a span value of 500 ppmv are subject to the same CEMS 

performance and equipment specifications when operating in the 

range of 100 ppmv to 500 ppmv that are provided by Performance 

Specification 8A in Appendix B to 40 C.F.R. Part 60 for other 

hydrocarbon CEMS, except: 

A. The zero and high-level calibration gas must have a 

hydrocarbon level of between 0 and 100 ppmv, and between 

. 250 and 450 ppmv, respectively; 

B. The strip chart recorder, computer, or digital recorder must be 

capable of recording all readings within the CEM measurement 

range and must have a resolution of 2.5 ppmv; 

C. The CEMS calibration must not differ by more than ±15 ppmv 

after each 24-hour period of the seven day test at both zero and 

high levels; 

D. The calibration error must be no greater than 25 ppmv; and 

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E. The zero level, mid-level, and high level calibration gas used to 

determine calibration error must have a hydrocarbon level of 

0-200 ppmv, 150-200 ppmv, and 350-400 ppmv, respectively. 

(f) Petitions to use CEMS for other standards. The Permittee may petition 

EPA to use CEMS for compliance monitoring for particulate matter, 

mercury, semivolatile metals, low volatile metals, and hydrogen chloride 

and chlorine gas under 40 C.F.R. § 63.8(f), in lieu of compliance with the 

corresponding operating parameter limits. 

(g) Calculation of rolling averages. The Permittee shall calculate rolling 

averages in accordance with the following requirements of 40 CF.R. 

§ 63.1209(a)(6): 

(i) Calculation of rolling averages upon intermittent operations. The 

Permittee must ignore periods of time when 1-minute values are not 

available for calculating the hourly rolling average. When 1-minute 

values become available again, the first 1-minute value is added to 

the previous 5 9 values to calculate the hourly rolling average. 

[40 C.F.R. § 63.1209(a)(6)(h)] 

(ii) Calculation of rolling averages when the hazardous waste feed is cut 

off. [40 CF.R. § 63.1209(a)(6)(iii)] 

A. Except as provided by condition 2.l(D)(l)(g)(ii)(B), below, the 

Permittee must continue monitoring carbon monoxide when 

the hazardous waste feed is cut off if the source is operating. 

The Permittee must not resume feeding hazardous waste if the 

emission levels exceed the standard. 

B. The Permittee is not subject to the CEMS requirements of 

40 CF.R. Part 63, Subpart EEE, during periods of time the 

Permittee meets the requirements of 40 C.F.R. 

§ 63.1206(b)(l)(ii) (compliance with emissions standards for 

nonhazardous waste burning sources when the Permittee is not 

burning hazardous waste). 

(h) Operating parameter limits for hydrocarbons. If the Permittee elects to 

comply with the carbon monoxide and hydrocarbon emission standard by 

continuously monitoring carbon monoxide with a CEMS, the Permittee 

must demonstrate that hydrocarbon emissions during the comprehensive 

performance test do not exceed the hydrocarbon emissions standard. In 

addition, the limits the Permittee establishes on the DRE operating 

parameters required under 40 C.F.R. § 63.1209(j) also must ensure that the 

Permittee maintains compliance with the hydrocarbon emission standard. 

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Expiration Date: DRAFT 

If the Permittee does not conduct the hydrocarbon demonstration and DRE 

tests concurrently, the Permittee must establish separate operating 

parameter limits under 40 C.F.R. § 63.1209(j) based on each test, and the 

more restrictive ofthe operating parameter limits applies. 

(i) Multi-metals CEMS. [40 C.F.R. § 63.1209(g)(2); 42 U.S.C. § 7414(a)] 

The Permittee shall install, calibrate, maintain and operate an x-ray 

fluorescence multi-metals CEMS for use as a continuous parametric 

monitoring system (CPMS) on Units 2, 3 and 4 within 12 months (365 

days) after this permit becomes effective, unless the Administrator 

determines that a time extension is warranted based oh the Permittee's 

documentation in writing of factors beyond its control that prevent the 

Permittee from meeting the 12-month deadline. The Permittee must also 

install and operate an oxygen CEMS on each unit to continuously correct 

the multi-metals CEMS data to 7 percent oxygen. 

(i) Each multi-metals CEMS must meet the installation requirements in 

Other Test Method (OTM) 16, Performance Specification Y Y 

(Specifications and Test Procedures for X-ray Fluorescence Based 

Multi-Metals Continuous Emission Monitoring Systems at 

Stationary Sources) and the on-going quality control and quality 

assurance procedures set forth in OTM 20, Procedure Z (Quality 

Assurance Requirements for X-Ray-Fluorescence Based MultiMetals Continuous Emission Monitoring Systems at Stationary 

Sources) and subsequent revisions. 

(ii) At a minimum, each multi-metals CEMS shall measure and report 

the total concentrations (regardless of speciation) ofthe following 

metals in both their vapor and solid forms in the exhaust stream: 

arsenic, beryllium, cadmium, chromium, lead and mercury. If the 

Permittee installs a multi-metals CEMS that is incapable of 

measuring any ofthe specified metals, the Permittee must quantify 

that metal's emissions using that metal's feedrate as determined 

according to condition 2.1(D)(4)(d) for the most recent 12-hour 

period for which feedstream analysis data for that metal is available 

and the system removal efficiency and exhaust parameters used by 

the Permittee to estimate emissions of that metal for that 12-hour 

period. For this purpose, unless otherwise approved in writing by 

EPA, the Permittee shall base its calculations on the affected metal's 

feedrate as determined according to condition 2.1(D)(4)(d), system 

removal efficiency from the last comprehensive performance test 

required by conditions 2.1(D)(8) and (10), and continuous flow and 

temperature data as measured by CMS required under condition 

2.1(D)(2). 
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(iii) The parametric range for each metal or class of metals measured by 

the multi-metals CEMS is equal to the emission limit for that metal 

or class of metals specified in condition 2.1(A)(7) of this permit. 

(iv) For a period of no less than 12 consecutive months, the Permittee 

shall operate each multi-metals CEMS at all times except during 

periods of monitor downtime due to calibration, quality assurance 

checks or scheduled maintenance. Operation "at all times" is 

defined as the collection of at least one measurement for each 

successive 15-minute period. In order to calculate a valid one-hour 

block average, valid results must be available for at least three of the 

four 15-minute cycles in each hour. 

(v) During the period when each multi-metals CEMS is installed and 

operating, the Permittee shall calculate and record 1-hour rolling 

average emissions from the raw data obtained by each CEMS. The 

Permittee shall also calculate a 12-hour rolling average of data for 

each CEMS, calculated each hour as the average of data collected 

over the previous 12 operating hours. The Permittee shall maintain 

for five years all data used in all calculations. 

(vi) The Permittee shall report to EPA in accordance with condition 

2.1(D)(l)(i)(x) for every 12-hour averaging period during which the 

12-hour average emissions from any incinerator were higher than the 

limits in condition 2.1 (A)(7) whether or not the levels of metals in 

the feedstream complied with the OPLs in the permit. 

(vii) During periods when any multi-metals CEMS is malfunctioning, or 

during periods of monitor downtime due to calibration, quality 

assurance checks or scheduled maintenance, the Permittee shall use 

data from feedstream analysis, performance tests and/or other CMSs, 

as provided in this permit, to demonstrate compliance at the 

respective incinerator with the applicable emissions limits provided 

that the monitor downtime lasts at least three ofthe four 15-minute 

cycles in each hour needed to calculate a valid one-hour block 

average. 

(viii) During the period when any multi-metals CEMS is being operated, 

the Permittee must continue to operate other CMS required under 

condition 2.1(D)(2) for the respective incinerator, and must monitor 

feedrates for the incinerator using the procedures contained in the 

feedstream analysis plan required under condition 2.1(D)(4)(b), and 

the supplemental procedures contained in condition 2.1(D)(4)(d)(2). 

(ix) At the end of the 12-month period during which each multi-metals 

CEMS was continuously operated, the Permittee may petition the 

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Administrator, in accordance with 40 C.F.R. § 63.1209(a)(5), to 

continue to use any or all of the multi-metals CEMS for compliance 

monitoring for mercury, LV M and SVM under 40 CF.R. § 63.8(f) in 

lieu of compliance with the corresponding operating parameter limits 

for the respective incinerators. 

(x) Any one-hour block average CEMS reading above any parametric 

range, as defined in condition 2.1(D)(l)(i)(iii), is a deviation. 

(xi) If the data from any multi-metals CEMS show a deviation, as 

defined in condition 2.1 (D)( 1 )(i)(x), the Pennittee must analyze the 

feedstream analysis data for the waste burned at the time ofthe 

deviation and the combustion conditions that existed at the time of 

the deviation to determine why the deviation occurred. The 

Permittee will send to the Administrator within 30 days of the 

deviation all feedstream analysis data for the period ofthe deviation 

and its analysis ofthe cause of the deviation, actions taken to address 

the deviation, and the corresponding 12-hour average concentration 

of each affected metal or class of metals for the measurement period 

that includes the hour(s) for which a deviation occurred. 

(xii) From the time that a CEMS records a deviation, the Permittee must 

immediately take corrective action to reduce emissions of the 

affected metal(s) and record all corrective actions taken. Corrective 

actions may include, but are not limited to, stop feeding or reduce 

the feedrate of the batch of waste burned when the deviation 

occurred, or adjustment to combustion conditions. The Permittee 

must document all corrective actions in the report required by 

condition 2. l(D)(l)(i)(x). 

(xiii) If operation ofthe multi-metals CEMS during the 12-month period, 

in conjunction with feedstream analysis or other relevant data, 

reveals that any of the feedrate limits included in this permit must be 

made more stringent in order to assure compliance with the 

applicable emissions limits, EPA will reopen this permit, pursuant to 

40 C.F.R. § 71.7(f), to either revise the affected feedrate limits or 

require operation of the multi-metals CEMS for a longer period of 

time or permanently. 

(xiv) If operation of the multi-metals CEMS during the 12-month period, 

in conjunction with feedstream analysis or other relevant data, 

reveals that any ofthe feedrate limits included in this permit are 

more stringent than necessary to assure compliance with the 

applicable emissions limits, the Permittee may petition the 

Administrator to use the results of historical comprehensive 

performance tests, feedstream analysis, and CEMS data to establish 
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higher feedrate limits for the affected incinerators provided the 

CEMS data demonstrate that compliance would be assured at the 

higher feedrate limits regardless of the waste burned. Nothing in this 

permit or 40 C.F.R. Part 63, Subpart EEE, obligates the 

Administrator to approve a petition for revised feedrate limits. 

(xv) Notwithstanding the specific recordkeeping and reporting 

requirements contained in condition 2.1(E) ofthis permit, the 

Permittee shall, on a quarterly basis, submit to EPA a summary of 

emissions data recorded by each multi-metals CEMS and the 1-hour 

and 12-hour rolling average mercury, SVM and LV M feedrates 

recorded during the same period. The emissions data summary shall 

include: 

A. The 1-hour and 12-hour rolling average concentrations of 

mercury, LV M and SVM as recorded by the multi-metals 

CEMS, in the units of the applicable MACT standards 

(p.g/dscm, corrected to 7 percent oxygen); 

B. The 12-hour rolling average feedrates, as determined through 

the required feedstream analyses conducted during the same 

period; 

C. Sample calculations, equations or other data used by the 

Permittee to convert CEMS and feedrate data; 

D. The total duration in minutes of any excess emissions during 

the reporting period, the 1-hour and 12-hour rolling average 

concentrations recorded during each period of excess 

emissions, the total duration of excess emissions expressed as a 

percent ofthe total source operating time during that reporting 

period, and a breakdown of the total duration of excess 

emissions during the reporting period into those that are due to 

startup/shutdown, control equipment problems, process 

problems, other known causes, and other unknown causes; and 

E. All deviations that occurred during the reporting period and 

corrective actions taken. 

2. Other continuous monitoring systems (CMS). [40 C.F.R. § 63.1209(b)] 

(a) The Permittee must use CMS (e.g., thermocouples, pressure transducers, 

flow meters) to document compliance with the applicable operating 

parameter limits under 40 C.F.R. § 63.1209. 

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