APPENDIX J 

FEEDSTREAM ANALYSIS PLAN 
FEEDSTREAM ANALYSIS PLAN 

Veolia ES Technical Services, LLC 

Sauget, Illinois 

October 2008 
Feedstream Analysis Plan - October 2008 

TABLE OF CONTENTS 

1.0 INTRODUCTION 

2.0 FEEDSTREAM PARAMETERS 

2.1 Chlorine 

2.2 Metals 

2.3 Ash 

3.0 ANALYTICAL RATIONALE 

3.1 Analysis Performed by Veolia 

3.2 Analysis Performed by Others 

3.3 Manufacturer Data or Other Published Information 

4.0 APPLICATION OF ANALYSIS FOR FEEDRATE COMPLIANCE 

4.1 Process Planning for Feedstreams 

4.2 Process Control for Feedstreams 

4.3 Documentation and Recordkeeping for Process Planning and 

Control 

5.0 SAMPLING AND ANALYTICAL METHODS 

5.1 S ampling Methodologies 

5.2 Documentation and Recordkeeping Associated with Sampling 

5.3 Analytical Methodologies 

5.4 Documentation and Recordkeepmg Associated with Sample 

Analysis 

6.0 FREQUENCY OF ANALYSIS 

7.0 COMPLIANCE WITH FEED RATES 

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Feedstream Analysis Plan - October 2008 

1.0 INTRODUCTION 

Pursuant to the regulatory requirements found in 40 CFR 63.1206 (c) of the HWC MACT 

Standard, Veolia ES Technical Solutions, LLC (Veolia) has developed a Feedstream 

Analysis Plan (FAP). Its purpose is to provide a system whereby Veolia can sample, 

analyze, and control the incineration of feedstreams that may contain constituents 

requiting feedrate limits as specified in the HWC MACT Standard. The FAP also 

addresses how these activities will be recorded in the facility's operating record. 

This FAP is organized such that each of the subsequent sections specifically addresses 

the six paragraphs under 40 CFR 63.1206 (c) (2) and three paragraphs under 40 CFR 

63.1206 (c) (4) in the order in which they are presented in the HWC MACT Standard. In 

many instances, this FAP will reference the facility's Waste Analysis Plan (WAP). The 

WAP is an integral part of the RCRA Part B Permit, the Permit Application, and any 

subsequent revisions or addenda to the Part B Permit or Permit Application. 

As required by sections 63.6 (e)(v) and 63.6 (e)(vi) of the HWC MACT Standard, the 

FAP and other documents containing procedures or information referred to in the FAP 

will be made available for inspection when requested by the Administrator. The FAP, 

correspondence with the Administrator concerning the FAP, and any subsequent 

additions or modifications to the FAP will be kept in the facility's Operating Record. If 

Veolia is required to submit copies of the FAP or portions of it (or related documents), 

<j^fiderrtM-busiiie^-in^ ~ 

designated. 

2.0 FEEDSTREAM PARAMETERS 

There are three feedstream constituents that are specified in the HWC MACT Standard 

for emission and/or feedrate limitations and that maybe present in any given feedstream. 

These three are: 

1) Chlorine 

2) Metals (Mercury, Lead, Cadmium, Chromium, Beryllium, and Arsenic) 

3) Ash 

These three constituents will serve as the feedstream parameters of concern in the FAP as 

required by 40 CFR 63.1206 (c) (2) (I) of the HWC MACT Standard. Feedstream data 

applicable to each of these parameters will be obtained for all feedstreams in order to 

control the incineration of them and remain within the feedrate limits set for them. 

2.1 Chlorine 

Feedstream data will provide a weight-based percentage of chlorine for each waste feed 

to the incinerators. These results can be used to both estimate targeted feed rate values 

and control actual feed rates during incineration. 

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Feedstream Analysis Plan - October 2008 

2.2 Metals 

Feedstream data will provide a parts-per-million concentration for each of the listed 

metals in each of the waste feeds to the incinerators. For analytical results that show less 

than detection limit concentrations, V* the detection limit value will be used for 

incinerator feed computations. These results can be used to both estimate targeted feed 

rate values and control actual feed rates during incineration. 

2.3 Ash 

Feedstream data will provide a weight-based percentage of ash for each of the waste 

feeds to the incinerators. These results can be used to both estimate targeted feed rate 

values and control actual feed rates during incineration. 

3.0 ANALYTICAL RATIONALE 

In 40 CFR 63.1206 (c) (2) (ii) of the HWC MACT Standard, a facility is required to 

identify how it will obtain the necessary analysis to comply with these regulations. There 

are three sources of analytical information that Veolia can use in evaluating the 

feedstream parameters as described in Section 2.0 of the FAP. They are: 

1) Analysis performed by Veolia - - - - - - - — - -

2) Analysis performed by others 

3) Manufacturer data or other published information 

These sources are also referenced in the facility's WAP and the ways in which they can 

be applied to feedstreams are extensively addressed. Many of the analytical procedures 

performed as described in the FAP are also required as part of the waste acceptance and 

management process at Veolia. The information derived from these procedures can then 

be used in complying with tlie feedstream limitations for the parameters identified in the 

FAP. 

The three analytical sources can be applied to generator wastes received at the Veolia 

facility, including those that undergo subsequent blending prior to incineration, and also 

to wastes that are generated at the facility. 

3.1 Analysis Performed by Veolia 

The predominate means applicable to this source of analytical information is the 

methodology described in Section 5.0 of the FAP. Specific analytical methods performed 

in the facility's laboratory are applied to applicable feedstreams to produce values for the 

required parameters. 

Typically, the feedstream is a waste profile from a generator that has been accepted 

according to the facility's WAP guidelines. This waste will have had analytical work 

performed on a sample for an initial acceptance decision and supplemental analysis as 

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Feedstream Analysis Plan - October 2008 1 

l : i 

i • 

required for subsequent shipments of the waste. This analytical work will include | 

information on the parameters identified in the FAP and can be used to control the | 

incineration of the feedstreams. j 

In other instances, the feedstreams are wastes blended together at the facility (e.g., bulk ! 

liquids and bulk solids) or wastes generated by the facility (e.g., laboratory wastes, 

incinerator ash). Feedstreams that are the result of blending or other on-site processing ! 

steps prior to incineration can have parameters determined from the same analytical 

methods described in the previous paragraph or by statistically arriving at an average ' 

value based on a body of previously analyzed samples. Wastes generated by the facility 

will have parameters determined from an average value based on a body of previously 

analyzed samples. 

For many feedstreams, the best source of information for the parameters identified in the j 

FAP will be obtained using the technical expertise of Veolia personnel. Examples of ; 

these types of feedstreams are labpacks, controlled substances and empty containers. The 

facility's WAP lists some of these reference sources in Appendix WAP-F. j 

3.2 Analysis Performed by Others 

In situations where Veolia cannot perform the necessary analysis due to the nature of the j' 

feedstream (e.g., gases, some reactive materials) or when previous outside analysis of j 

feedstreams that meets the standards of this FAP is available, Veolia will accept the ~"" T 

analysis of others in determining parameter values. This analytical information will be ; 

evaluated and used to control the incineration of feedstreams in the same manner as j 

analytical information produced at the facility. 

3.3 Manufacturer Data or Other Published Information 

Many feedstreams have pre-existing information applicable to them that can be used to 

determine the values of the parameters as identified in the FAP. This can take the form of 

manufacturer specifications and data, Material Safety Data Sheets, reference sources or 

other published information. The facility's WAP lists some of these reference sources in 

Appendix WAP-F. Examples of these types of feedstreams include commercial products, 

pharmaceuticals, chemical reagents, and gas cylinders. This information will be evaluated 

and used to control the incineration of these feedstreams in the same manner as analytical 

mformation produced at the facility, j 

4.0 APPLICATION OF ANALYSIS FOR FEEDRATE COMPLIANCE 

Feedstream data will be used to maintain compliance for the feedrate limitations to the I 

incinerators. This analysis will be completed prior to the feeding of any material to the I 

incinerators. The documentation of these feedrate compliance methods is required by 40 ! 

CFR 63.1206 (c) (2) (iii) of the HWC MACT Standard and outlined in this section of the \ 

FAP. j 

i 

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Feedstream Analysis Plan - October 2008 

Analytical results can be used to both estimate targeted feed rate values and control actual 

feed rates during incineration. Analysis from laboratory testing at the facility, analytical 

results from others, published mformation, and technical evaluations by Veolia personnel 

can all be used in complying with feedrate limitations for the parameters identified in the 

FAP. In addition, these analytical information sources can be used for wastes from 

generators, wastes blended at the facility, and wastes generated at the facility. 

4.1 Process Planning for Feedstreams 

When evaluating analytical results and any additional mformation applicable to a 

potential feedstream, a decision must be made whether parameters for that feedstream are 

acceptable for feeding to the incinerators or if some level of feed preparation is 

necessary. This step in the feedstream evaluation process is called process planning. It is 

applied to blending wastes, processing wastes into combustible charges, and determining 

if wastes can be fed directly to the incinerators as initially received at the facility. This 

planning is performed based on information from analytical results, incinerator 

performance capabilities, process operation history, and the technical expertise of the 

process planning personnel involved. 

4.2 Process Control for Feedstreams 

In order to ensure that feedrate limits for the parameters in the FAP are not exceeded 

-^uring^eratimt^fthe^tie^ 

incinerator process. These systems continuously track the feedstream parameters as they 

are introduced into the incinerators and make the necessary feed adjustments or cut-offs 

for compliance. Section 7.0 of the FAP addresses these systems and the rationale behind 

their operation in greater detail. 

4.3 Documentation and Recordkeeping for Process Planning and Control 

Documentation of process planning and control is demonstrated by the extensive body of 

information collected in the facility's data management system, and, if needed, 

distributed in hard copy form to appropriate personnel. This includes laboratory analysis 

used for feed preparation, bulk waste storage data, processing directions, and related 

mformation. Actual incinerator operations data is recorded in printed surnmaries, 

recorded onto digital data storage systems, and is also selectively available on-line. This 

information will be retained in the operating record for the life of the facility. 

5.0 SAMPLING AND ANALYTICAL METHODS 

The requirements in 40 CFR 63.1206 (c) (2) (iv) and (v) of the HWC MACT Standard 

state that a facility must identify the sampling and test methods used for analyzing the 

feedstreams. The sampling methodology and much of the analytical methodology that is 

described in Sections 2,0 and 3.0 of the facility's Waste Analysis Plan is applicable to the 

FAP. Additional sampling and testing information is included in the following paragraphs 

of this section. 

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Feedstream Analysis Plan - October 2008 

5.1 Sampling Methodologies 

Sampling is performed at the Veolia facility to identify waste shipments and also by the 

generator at their location when making an initial determination on the acceptability of 

the waste at Veolia. In some instances, an actual sample will not be required because 

technical personnel at Veolia will have determined that sufficient documentation already 

exists that identifies information regarding the parameters described in Section 2.0 of the 

FAP (see also Section 4.0, Paragraph 4.1.12 (2) of the WAP). In order to obtain a 

representative sample of the waste, specific sampling procedures that are dependent on 

both the nature of the waste sampled and the type of processes in which the waste will be 

stored or transferred must be performed. Section 2.0 of the facility's WAP and pertinent 

appendices in the WAP list these procedures and the ASTM method number (or other 

EPA approved method) on which they are based. This section in the WAP also addresses 

the sampling equipment used, the types of intended containment or processes that can 

impact the sampling, and guidelines on how to ensure that a valid and representative 

sample is obtained. 

5.2 Documentation and Recordkeeping Associated with Sampling 

A l l samples taken at the facility or sent to the facility for analysis are assigned a unique 

sample identification number. These identification numbers are recorded in a chain-ofcustody log and used for tracking the sample through the facility's data collection system. 

Each sample also has a label affixed to it identifying its contents, the date the sample was 

taken, and the person who took the sample. 

5.3 Analytical Methodologies 

CHLORINE 

The analytical procedures and EPA approved methods related to determining the amount 

of chlorine in a feedstream are found in Appendix WAP-A to the facility's WAP. 

METALS 

Feedstreams that require analysis for the metals specified in the HWC MACT Standard 

will either contain these metals in a non-water-soluble form or a water-soluble form. 

Samples of feedstreams in a non-water-soluble form will require additional preparation 

steps prior to analysis. The analytical procedures and EPA approved methods related to 

determining the amount of listed metals in a feedstream are listed below. 

Digestion Procedure forNon-Water-Soluble Samples 

Method 3051A - Microwave Assisted Acid Digestion of Sediments, Sludges, Soils, and 

Oils 
Feedstream Analysis Plan - October 2008 

Procedure for Determining Concentration of Mercury in Sample 

Method 7473 - Mercury in Solids and Solutions by Thermal Decomposition, 

Amalgamation, and Atomic Absorption Spectrophotometry 

Procedure for Determining Concentration of Arsenic, Beryllium. Cadmium. Chromium 

and Lead in Sample 

Method 601OC - Inductively Coupled Plasma-Atomic Emission Spectrometry 

A SH 

The analytical procedures and EPA approved methods related to determining the amount 

of ash in a feedstream are found in Appendix WAP-A to the facility's WAP. 

5.4 Documentation and Recordkeeping Associated with Sample Analysis 

Documentation of analytical work is accomplished by recording it in laboratory 

logbooks, entering it into the facility's data management system, and, if needed, 

distributed in hard copy form to appropriate personnel. Al l technical files for waste 

profiles will also include initial laboratory analysis and any applicable subsequent 

analysis. This information will be retained in the operating record for the life of the 

facility." ' * " 

6.0 FREQUENCY OF ANALYSIS 

In 40 CFR 63.1206 (c) (2) (vi) of the HWC MACT Standard, a facility is required to 

identify the frequency with which an initial analysis is repeated or reviewed to ensure that 

it is current. This FAP will require that the analytical information for the feedstreams be 

re-evaluated on a frequency consistent with that described for all wastes as described in 

Section 4.1.3 of the facility's WAP. The three events that may trigger a need to update or 

evaluate the analysis of a given feedstream are: 

1) Generator notifies Veolia that a feedstream has changed 

2) Subsequent analysis for a feedstream used by Veolia is inconsistent with the original 

analysis 

3) Five years have passed since the last assessment of the feedstream 

hi order for a feedstream to be considered acceptable again for incineration after one of 

these events has occurred, the evaluation process as described in this FAP must be 

completed. 

7.0 COMPLIANCE WITH FEED RATES 

Veolia employs process control systems for the incinerators that monitor, adjust and 

record feedstreams and the key parameters identified in the FAP that are associated with 

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Feedstream Analysis Plan - October 2008 

them. These systems meet the requirements of 40 CFR 63.1206 (c) (4), paragraphs (i), (ii) 

and (iii). The systems and the rationale that supports these systems are described in the 

following paragraph. 

7.1 Feed Rate Compliance Systems and Methodology 

After the metals and ash concentrations for feedstreams are determined, they will be 

entered into the facility's data management systems. These feedstreams are identified in 

the system under a site tracking number, bulk pit number, or tank number. Once this 

information is in the waste tracking system, the incinerator control systems are able to 

import and store the data for use as the waste streams are processed at the incinerators. 

A l l waste introduced into the incinerators has an associated site identification designation 

(receiver number, etc.) so it can be referenced to the appropriate data from the waste 

tracking system. As weights are recorded at 15 second intervals for each specific waste 

stream entering the incinerator, computations are being performed to calculate the 

quantities of metals (as low volatile metals, semi volatile metals, and mercury) and ash 

that are being incinerated. These quantities are displayed, totalized, and recorded in a 

manner that will show compliance with the established operating parameter limits for the 

metals categories and ash. One hour and 12 hour rolling totals are displayed for the 

incinerator operators for monitoring of these feeds. 

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