APPENDIX I 

ESV OPERATING PLAN 
EMERGENCY SAFETY VENT PLAN 

Prepared for: 

Veolia ES Technical Solutions, LLC 

Sauget, Illinois 

Prepared by: 

Franklin Engineering Group, Inc. 

Franklin, Tennessee 

October 2008 
TABLE OF CONTENTS 

1.0 INTRODUCTION AND BACKGROUND 1 

1.1 SUMMAR Y OF FACILITY INFORMATION 1 

1.1.1 Fixed Hearth Incinerators 1 

1.1.2 Rotary Kiln Incinerator 3 

1.2 DESCRIPTION OF THE ES V SYSTEM 4 

2.0 ESV SYSTEM INVESTIGATION, DOCUMENTATION AND 

REPORTING 7 

2.1 ES V INVESTIGATION 7 

2.2 DOCUMENTATION OF ES V OPENING 7 

2.3 REPORTING OF ES V OPENINGS 8 

3.0 PROCEDURES DURING AN ESV 9 

3.1 STOPPING WAST E FEED AN D SHUTTING DOW N THE COMBUSTOR 9 

3.2 MAINTAINING COMBUSTION CHAMBER TEMPERATURE 9 

3.3 MAINTAINING NEGATIVE COMBUSTION CHAMBE R PRESSURE 9 

3.4 SHUTTING DOW N THE COMBUSTOR 9 

3.5 DOCUMENTATION OF COMBUSTION CHAMBE R PRESSURE AN D 

TEMPERATURE MAINTENANCE 10 

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LIST OF TABLES 

TABL E 1 -1 REGULATOR Y REQUIREMENTS FOR A N EMERGENC Y SAFETY VEN T 

OPERATING PLA N AN D CORRESPONDING SECTION THAT ADDRESSES THE 

REQUIREMENT 2 

TABL E 1 -2 THERMA L RELIEF VEN T OPENINGS 5 

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1.0 INTRODUCTION AND BACKGROUND 

Veolia ES Technical Solutions, LLC (Veolia) owns and operates two fixed hearth 

incinerators (Units 2 and 3) and a rotary kiln incinerator (Unit 4) at its facility located in 

Sauget, Illinois. These incinerators are subject to the National Emissions Standards for 

Hazardous Air Pollutants (NESHAP) for Hazardous Waste Combustors (HWCs), Code 

of Federal Regulations (CFR), Part 63, Subpart EEE (§§ 63.1200 to 63.1221). The 

NESHAP for HWCs specifies emissions standards which reflect emissions performance 

of maximum achievable control technologies (MACT), and is commonly referred to as 

the HWC MACT. 

Hazardous Waste Combustors are required to have an Emergency Safety Vent Plan and 

to keep the plan in the operating record. The Emergency Safety Vent Plan must follow 

the requirements described in § 63.1206(c)(4). This Emergency Safety Vent Plan 

demonstrates Veolia's compliance with these requirements. This plan includes 

information about the facility as it relates to the Emergency Safety Vent (ESV) systems, 

and procedures that will be followed during an ESV event. Table 1-1 presents the 

regulatory references related to the required ESV program and the section of this plan that 

addresses each specific requirement. 

Due to the general applicability of the ESV requirement and the similarity of the 

incinerator systems, general references to an ESV or incinerator system in this document 

will imply all three systems. Information that is only applicable to one or two of the three 

systems will be clearly identified. 

1.1 Summary of Facility Information 

Brief summaries which describe the fixed hearth incinerators and the rotary kiln 

incinerator are presented in this section. 

1.1.1 Fixed Hearth Incinerators 

Each of the fixed hearth incinerators includes the following components: 

• Feed equipment 

• Primary and secondary combustion chambers 

• Lime injection system 

• Spray dryer absorber (SDA) 

• Fabric filter baghouse 

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Table 1-1 

Regulatory Requirements for Emergency Safety Vent Operating Plan 

and Corresponding Section that Addresses the Requirement 

Regulatory 

Citation 

Description Plan Section 

63.1206(c)(4)(i) 

Documentation in operating record of an ESV 

opening while hazardous waste remains in the 

combustion chamber: 

(1) Record if ESV by-passed APCS 

(2) Determine if operation remained in 

compliance considering the emissions during 

the ESV 

Section 2.2 

63.1206(c)(4)(ii)(B) 

Information documenting effectiveness of plan's 

procedures to maintain combustion chamber 

temperature and pressure, as is reasonably feasible 

Section 3.5 

63.1206(c)(4)(ii)(B) Detailed procedures for rapidly stopping waste feed Section 3.1 

63.1206(c)(4)(ii)(B) 

Detailed procedures for shutting down the 

combustor 

Section 3.4 

63.1206(c)(4)(ii)(B) 

Detailed procedures for maintaining temperature in 

combustion chamber 

Section 3.2 

63.1206(c)(4)(ii)(B) 

Detailed procedures for maintaining negative 

pressure in the combustion chamber 

Section 3.3 

63.1206(c)(4)(iii) Investigation of ESV openings Section 2.1 

63.1206(c)(4)(iii) Recording of ESV openings Section 2.2 

63.1206(c)(4)(iv) Reporting of ESV openings Section 2.3 

2 
• Solids and ash removal systems 

• Induced draft (ID) fan and stack 

• Instrumentation, controls, and data acquisition systems 

Various solid and liquid wastes and gaseous feedstreams are thermally treated in the 

fixed hearth incinerators. Solid waste is fed to the primary (lower) combustion chamber 

via a feed conveyor system and pneumatic ram. Liquid waste from tanks and tanker 

trucks are fed to the primary combustion chamber through two atomized liquid injectors. 

Liquid waste from containers are fed to the primary combustion chamber through a 

specialty feed injector. A gaseous feedstream is fed to the Unit 2 primary combustion 

chamber directly from gas cylinders. Off gases from a hooded feed emission control 

system and from a waste handling glove box are fed directly to the Unit 3 secondary 

combustion chamber. Combustion chamber temperatures are maintained using natural 

gas fired to a dedicated burner in both the primary and secondary chambers. 

Combustion gas exits the secondary combustion chamber and enters the SDA, which 

provides acid gas removal and cooling of the combustion gas. Combustion gas exits the 

SDA and is distributed to the fabric filter baghouses, which provide particulate matter 

removal. The induced draft fan, located downstream of the baghouses, moves the 

combustion gas through the system and exhausts the gas through the main stack. 

1.1.2 Rotary Kiln Incinerator 

The rotary kiln incinerator includes the following components: 

• Waste feed system 

• Primary and secondary combustion chambers 

• Tempering chamber 

• Lime injection system 

• Spray dryer absorber 

• Carbon injection system 

• Fabric filter baghouse 

• Solids and ash removal systems 

• ID fan and stack 

• Instrumentation, controls, and data acquisition systems 

Various solid and liquid wastes are thermally treated in the rotary kiln incinerator. Solid 

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

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feed conveyor. A hydraulic ram pushes the solid waste into the kiln. Liquid waste from 

tanks and tanker trucks is fed to the primary and secondary combustion chambers through 

atomized liquid injectors. Combustion chamber temperatures are maintained using 

natural gas fired to a dedicated burner in both the primary and secondary chambers. 

Combustion gas exits the secondary combustion chamber and enters the tempering 

chamber, which provides cooling of the combustion gases. The combustion gas exits the 

tempering chamber and is distributed between two identical SDAs, which provide acid 

gas removal and additional gas cooling. A carbon injection system is utilized for 

controlling dioxin/furan and mercury emissions. The activated carbon is air injected into 

the combustion gas immediately downstream of the convergence of combustion gases 

from the SDAs. From the SDAs, combustion gas is distributed to fabric filter baghouses, 

which provide particulate matter removal. The ID fan, located downstream of the 

baghouses, moves the combustion gas through the system and exhausts the gas through 

the main stack. 

1.2 Description of the ESV System 

Each incinerator is equipped with an emergency safety vent (ESV) located at the top of 

the secondary combustion chamber. This ESV is a refractory-lined emergency thermal 

relief vent (TRV) which is held in the closed position by a pneumatic cylinder. The 

control valve in the line supplying air to the cylinder and the cylinder vent valve which 

opens the TRV are located in the control room for each unit. Valve locks (with keys 

attached) are utilized to deter indiscriminate operation of these valves. Opening of the 

T RV allows hot combustion gas to vent from the combustion system during emergency 

shutdown events. The purpose of the TRV is to protect the downstream APCS from 

excessive temperature situations. 

Conditions which may warrant a TRV opening are summarized in Table 2-1. Typically, 

alarms and/or interlocks will be triggered prior to these conditions being present. Alarms 

provide the operator the opportunity to take measures in attempt to restore proper 

operating conditions. Otherwise, a controlled cutoff of the waste feeds, an AWFCO, or 

an emergency shutdown may occur prior to opening the TRV. If hazardous waste is 

being fed at the time the TRV is opened, the TRV position transmitter will detect the 

T RV opening and trigger an AWFCO. 

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Table 1-2 

Thermal Relief Vent Openings 

Parameter Condition

 1 

Electrical Supply- Loss of Power 

Air Supply 

Loss of Air Pressure 

(TRV will fail open) 

ID Fan Failure/Malfunction 

SDA Exit Gas Temperature > 500 °F 

Emergency Shutdown Operator's Discretion 

The operator is permitted to open the TRV if these conditions are present. 

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Unit 4 is equipped with, a second ESV located at the kiln face. This ESV is referred to as 

the surge vent and is kept closed by a weighted louver. The surge vent will only open if 

there is a pressure excursion in the kiln sufficient enough to overcome the weighted 

louver. A deflector separates the escaping combustion gas from the feed, and the surge 

vent angles to a horizontal opening. This design minimizes the entrainment of solid 

through the surge vent. 

An ESV opening may correspond with a malfunction event. Information regarding 

operation of the incinerator and the associated control equipment during times of start-up, 

shutdown and malfunction is provided in the facility Start-up, Shutdown, Malfunction 

Plan (SSMP). 

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2.0 ESV SYSTEM INVESTIGATION, DOCUMENTATION AND 

REPORTING 

2.1 ESV Investigation 

If an ESV opens for any reason during normal operations, the operator is instructed to: 

1) Verify that all waste feeds to the incinerator are cutoff, 

2) If possible, operate the ID fan, and 

3) If possible, maintain normal combustion chamber temperatures on natural gas. 

If hazardous waste is in the combustion chamber during a ESV opening, the incinerator 

supervisor should be notified as soon as possible. The incinerator supervisor will 

coordinate with technical staff to determine potential causes for the event and to estimate 

excessive emissions. 

2.2 Documentation of ESV Opening 

Each instance in which the emergency vent opens will be recorded in the facility 

operating record. This record will, at a minimum, include the date, time, and the 

operating mode at the time of the ESV opening. This data is automatically documented 

in the operating record by the CMS. 

If the 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 by the facility SSMP), Veolia personnel will document that an 

E SV event occurred, determine if the facility remained in compliance with facility 

emission standards, and record the findings of that determination in the facility operating 

record. Since the ESV is located upstream from the facility air pollution control devices 

(APCD), it is understood that combustion gas by-passes these emission control devices 

during an ESV event. This by-pass will be documented in the facility operating record. 

If an ESV opening is attributed to a malfunction and occurs when hazardous waste 

remains in the combustion chamber, a malfunction recordkeeping form will be completed 

to document the event. 

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2.3 Reporting of ESV Openings 

If an ESV opening results in a failure to meet the emission standards for the facility, 

Veolia will submit a written report within five days of the ESV event to Illinois 

Environmental Protection Agency (IEPA), documenting the results of the investigation 

and corrective measures taken. In most cases when an ESV event occurs, it is 

instantaneous. Therefore, it is practical to assume that diminimus emissions occur during 

these instantaneous events. 

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3.0 PROCEDURES DURING AN ESV 

In the event of an ESV opening that occurs while burning waste, it is important that waste 

feed is stopped rapidly, and that combustion chamber temperature and negative pressure 

are maintained to the extent practical. Following the expiration of the hazardous waste 

retention time, shutting down the combustor (allowing key components to cool) is 

equally important. These items are addressed below. 

3.1 Stopping Waste Feed and Shutting Down the Combustor 

An ESV opening is likely to be preceded by a AWFCO or safety interlock that causes a 

waste feed cutoff prior to the ESV opening. The ESV position is also interlocked with 

the AWFCO system. These redundant measures ensure that waste feeds will be stopped 

during an ESV opening. If the AWFCO system fails to cutoff wastes to the incinerator, 

the waste will be manually cutoff in a quick and safe manner. Waste burning cannot 

resume until the ESV is closed, corrective actions taken, permission is granted from the 

incinerator supervisor, and all parameters are within limits. 

3.2 Maintaining Combustion Chamber Temperature 

Combustion chamber temperatures are maintained using natural gas fired a dedicated 

burner in both the primary and secondary combustion chambers. If possible, the burning 

of natural gas will be used to maintain adequate combustion chamber temperatures for 

the combustion of waste remaining in the incinerator. 

3.3 Maintaining Negative Combustion Chamber Pressure 

If possible, the ID fan will be operated during an TRV opening to minimize the quantity 

of combustion gas that by-pass the air pollution control equipment. Operation of the ID 

fan during an ESV opening will maintain negative combustion pressure to the full extent 

that is reasonably feasible. It is likely that the opening of the TRV will cause the system 

to lose negative pressure (i.e. the ID fan cannot induce a strong draft). For surge vent 

opening, the positive pressure excursion will be temporary, and the ID fan (if operable) 

will be used to restore negative pressure in the primary chamber, as quickly as possible. 

3.4 Shutting Down the Combustor 

An event which causes an ESV opening may require a cold shut down of the combustor 

in order to perform corrective actions. After sufficient effort is taken to minimize 

emissions by maintaining the temperature and pressure, the incinerator supervisor will 

decide if a shut down is warranted. If the ESV opening corresponds with a malfunction 

9 
event then the corrective measures taken will be consistent with the procedures 

prescribed by the SSMP. 

3.5 Documentation of Combustion Chamber Pressure and Temperature 

Maintenance 

§ 63.1206(c)(4)(ii)(B) requires that the facility demonstrate that the procedures of this 

plan are adequate to maintain combustion chamber pressure and temperature while 

hazardous waste remains in the incinerator, if feasible. The occurrence of an emergency 

safety vent opening at the Veolia facility is possible only in a select set of circumstances, 

which are described in Section 1.2 of this plan. If natural gas cannot be burned, it is not 

feasible to maintain the combustion chamber temperature during an ESV event. 

Likewise, it is likely that the opening of the TRV will result in the loss of negative 

pressure. The duration of a surge vent opening will typically be brief and only 

momentarily prevent maintaining the combustion chamber pressure. The procedures 

presented in this plan will be followed to minimize the effects of such occurrences. 

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