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166 

VES017201 
VES017202-017202.pdf 
5-62 PARTICL E DYNAMIC S 

Equivalent standard 

Tyler screen' rnesh 

Theoretical screen mesh n opmootiNjejio> r10 100 1000 

Particle diameter, microns 

10,000 

Fio. 3-74. Terminal velocities of Bpherioat particles of different 

densities settling in. air and water at 70°F.. under tbe action of 

gmvity. (from Lappleet .oj.,. op. eiU, p. 292.) 

becomes high, the particles will be close enough to exert 

a mutual retarding effect onthe settling. This condition 

ia often referred to as "hindered" Bettllag. The effect 

ia not significant at volumetrio concentrations below 

Oil per cent. Fo r the effect at hiidicr concentrations, see 

Lapple el al. (op. oil, p. 289) and Brown et at. (op. cfti, 

pp. 78-79). 

When; the diameter of the particle becomes appreciable 

with respect to the; diameter of tne container in which it 

is settling, the container walls will exert an additional 

retarding effect known as the wall effect. This car :* 

allowed for in the case of rigid particles by'multipljriii; 

the terminal velocity as computed from Stokes's law "r? 

the factor %, as given in Table 5-26. 

Table i-26. Wall Correction Pactoir for Bigid 

Particles in Stokes's-law Region 

K *„ 

0.0 1.000 0.5 0.170 

0.1 o.ro 0.6 0.0945 

0.2 0.5% 0.7 0.0468 

0.3 0.422 o.e 0.0205 

0.4 0.279 

(8 .= particle' diameter divided by vessel dianietw, (From Hsbernaa us 

SBjre.fiBiJ W, Taifa.Madtl Bonn Report U4J, 1958): 

For the turbulent regime (Newtotf's-law reglei 

Munroe [ZVan«. Ant. bid. Mining Met: Bngrt., 17. 

637-659 (1888-1889)1 developed the correction facta: 

Sb' by which the computed terminal velocity may ":•» 

multiplied: 

V = 1 - 61-

1

 (6-215 

where (8 •= particle diameter divided by vessel diameie 

Stokes's law is subject to a lower limit in the case it 

rigid particles settling in a gas. When the particle sa! 

approaches the mean free path of the fluid molecule*, 

the settling velocity will he greater than that co—-

puied from Stokes's law. The correction known •» 

the Stokes-Cunningham correction is less tksx 

1 per cent for particles larger than 16 microns settiiie 

in air. Particles smaller than this are also, subject «t 

Brownian motion because of impact of the fluid moticulee. For particles finer than 0.1 micron, this randco. 

motion is far greater in magnitude than any directac 

particle motion due to gravitational settling. For additional information on the magnitude of these two effetrra. 

see Lapple ec al. (op. cit., pp. 285-286) and Zenz ar : 

Othmer (op. cit., Chap. 6). 

Por the case of bubbles i n liquids, a wall effect « C 

be encountered for bubble diameters larger than 1/100 st 

the vessel diameter. Information on this effect, is &f*a. 

by Hafmathy (loc. cit.) and Uno and Kintrier [Am. InA. 

Chem. Bngre. J., 2, 420 (1966)].' 

Por the case of liquid drops In liquids, informatics, 

on the wall effect is given by H&rmathy (loo. cit.) abs 

Strom and Kintner [Am. Inet. Chem. 'Bngrt. J., 4, 15* 

(1958)!. 

Particle Trajectories. In the treatment up to ti i 

point, only one-dimensional steady-state motion hashe s 

considered, vertically up or down, tinder ihe action a. 

gravity. Equations have been developed by Lapple and 

Shepherd [Ind. Enj. Chem., 32, 605-617 (1940)] for calculating the position-time histories for particles undergoing one-dimensional accelerated motion and twodimensional motion. 

In the Stokes's law region, the motion in a given direction is shown to be independent of motion in a directioi 

perpendicular to the .first, and the resulting trajectory 

i? fhat of one motion superimposed upon the pthtr. 

For other than the laminar regime, the motion of s 

particle in any direction will be influenced by velocitr 

components in other directions. Por example, the verdeal terminal velocity of & particle will be lower the higher 

the horizontal Telocity component. See also Brows 

et cl-., op. at., pp. 79-83; DallaVallo, "Micromeritios.' 

2d ed., pp. 24-29, Pitman, New York. 1948; Zena and 

Othmer, op. cit., pp. 216-220. 
VES017203-017221.pdf 
£-$ba ' POWDER l£$L TECHNOLOGY 

ELSEVIER Powder Technology 119(2001) 134-152 — 

www.e1sevier.com/locale / powtcc 

Mixing and dispersion of particle ropes in lean phase 

pneumatic conveying 

Harun Bilirgen, Edward K. Levy * 

Energy Research Center, Lehigh University, 117 ATLSSDrive, Bethlehem, PA 18015, USA 

Received 21 August 2000; received in revised form 4 November 2000 

Abstract 

The objective of this study was to investigate mixing mechanisms in lean phase pneumatic conveying, with the emphasis on 

techniques for dispersing the severe particle stratification caused by flow through a 90° elbow. This type of stratification is referred to as a 

particle rope. The paper describes a combined numerical and experimental study of the rope dispersion characteristics of various mixing 

devices lhat were installed immediately downstream of the elbow. The laboratory experiments were conducted in a 0.154 m I.D. vertical 

lest section. Local particle velocities and concentrations were measured using a reflective type fiber optic probe. The numerical 

simulations were carried out using the CFX-4.2 code developed by AE A Technology. 

The effect of secondary velocities on rope dispersion was investigated by using a flow straightener installed after the elbow. The 

results show that the rope dispersion rate in both the axial and radial directions was significantly reduced in the absence of secondary 

velocities. 

The types of flow mixers investigated included nozzles, air jet injection, and swirl vanes. Although all mixing techniques were able to 

disperse the particle rope within nine pipe diameters from the bend exit plane, nozzles with beta ratios of 0.5 and 0.67 and air jet injection 

from the inner wall caused the most rapid rope dispersion. However, the nozzles cause excessive pressure drop and the air jet injection 

technique increases the flow rate of conveying fluid carried by the pipe. ©200 1 Elsevier Science B.V. All rights reserved. 

Keywords: Mixing; Dispersion; Particle ropes; Lean phase pneumatic conveying 

1. Introduction 

Pipe bends are a common feature of most pneumatic 

conveying systems and are well known to create flow 

problems, even in single phase flows. The situation is 

further complicated with the presence o f a solid phase, 

such as occurs in pneumatic conveying. A s the air-particle 

mixture approaches the pipe bend, a double vortex flow 

structure occurs in the fluid phase and a significant phase 

separation in the particulate phase is experienced within 

the bend geometry due to centrifugal forces. Upon exiting 

from the bend, the particles flow together in a narrow 

localized stream (see Fig . 1) and the velocity of the 

particles in the suspension is reduced to almost one half of 

' Corresponding author. Tel.: +1-610-758-4090; fax: + 1-610-758-

5959. 

E-mail address: eklO@lchigh.edu (E.K.. Levy). 

the mean gas velocity. This phenomenon is referred to as 

"roping". Once formed, this flow stratification pattern can 

persist over a region extending up to 25 pipe diameters 

downstream of the elbow. It eventually breaks down due to 

flow turbulence and to the secondary flow induced by the 

elbow. 

The objective of the present study was to identify ways 

to quickly dissipate a rope-like structure and achieve a 

homogeneous distribution o f the two phase mixture over 

the pipe cross-section within short distances from the bend 

exit. Since naturally occurring mechanisms such as flow 

turbulence and secondary flow patterns with a plain elbow 

are not sufficient to achieve this, the use of mechanical 

mixing devices is necessary for promoting rapid mixing of 

the flow. A detailed investigation, including laboratory 

experiments and numerical simulations, was carried out to 

understand the rope mixing processes with different types 

of devices. 

The present study focuses on dilute phase pneumatic 

conveying. The air-to-solids mass loading ratios were typi0032-5910/01/$ - see front matter ©200 1 Elsevier Science B.V. All rights reserved. 

Pll: S0032-59 1 0(00)0041 3-7 

VES017203 
II. Rilirgen. E.K. Levy / Powder Technology 119 (2001) 134-152 135 

U 

Flow 

Flow 

Fig. 1. Particle roping. 

cally ia the range of 1-3 and the average air velocity was 

between 15 and 30 m/s. 

2. Experimental apparatus 

Table 1 

Particle size distribution of conveyed material (coal) 

Diameter (u.m) Weight (%) 

> 125 0.05 

106-125 0.27 

90-106 1.73 

75-90 15.46 

63-75 14.54 

45-63 22.50 

<45 45.44 

the inlet air stream at (6) via a screw feeder. The flow 

mixing mechanisms were positioned immediately after the 

elbow (7). Instrument ports allow measurements of particle 

flow patterns in the vertical test section downstream o f the 

pipe bend. A t the end of the upper horizontal pipe, the 

particles are separated from the air using a cyclone separator (3), and any remaining fine particles are removed in the 

fabric filter (4). 

The experiments were performed with coal particles 

with a mean diameter of 59 p.m and a density o f 1680 

kg/m 3. The particle size distribution is given in Table 1. 

Loca l particle concentration and velocity measurements 

were performed using a reflective type fiber optic probe 

that was traversed over the cross-section of the pipe to 

obtain detailed profiles. Infonnation about the probe is 

given by Refs. [1,2], 

Fig . 2 shows the experimental test facility used for this 

study. Air is supplied by compressors that provide a 

maximum air velocity of 30 m/ s in the 0.154 m I.D. test 

section. Particles stored in hopper (1) are discharged into 

3. Numerical technique 

The numerical predictions described in this paper were 

perfomied using the Lagrangian approach provided by the 

i j j Feodei end liofiuc 

(?) Hotory Ahoc k 

(Sj Cyc;r:r:(> 

• -' f i 

"ii ' 

' JIU 

/

 J H 

v

 .in?'** -

L-.. 6 o j 

jxj \: 

I t 

Fig. 2. Experimental test facility. 

VES017204 
II. Ililirgcn. E.K. Levy / Powder Teclmology 119 (2001) 134-152 

Fig. 3. Measured inlet particle concentration distribution one diameter upstream of the elbow ( A/F= 3.0; Rc/D = 1.5; U0 = 30 m/s and A/F = 3.0). 

CFX-4. 2 software package developed by AE A technology 

[3], The numerical calculations for the gas phase were 

perfomied by solving a set o f time averaged Navier-Stokes 

equations together with the well-known k-e turbulence 

model of Launder and Spalding [4]. The particles are 

introduced at a finite number o f starting locations. In every 

given time step, their positions and velocities are calculated according to the forces acting on the particle and 

using ISewton's second law. The equation of motion for a 

particle can be written as 

1

 dt 

(1) 

where F T is the total force and includes the drag force 

(Fpj), gravitational force (F G ) , and the added mass force 

(F A ). 

Fj = F^F a + F„ (2 ) 

The major component o f the force is the drag force 

exerted on the particle by the gas phase. This has the fon n 

Fd = ^tt6 2

P C d \ V r \ V r (3) 

Fig. 4. Secondary flow pattern at the exit of an elbow. 

where the drag coefficient CD is based on the motion of a 

single particle and is given by 

24 

C D = —(1+0.1 5 Jte? 

Rep = 

(4) 

(5) 

2 D 

_ L 

x / D 

FLDW 

Fig. 5. Flow straightener geometry. 

VES017205 
/ / . Bilirgen, U.K. Levy / Powder Teclmology: 119 (2001) 134-152 1.17 

The gravitational force is given by 

1 

and the added mass force (virtual force) is given by 

12 ' dl 

(6) 

The gas phase velocity in the momentum equations is 

taken to be the mean velocity plus a contribution due to 

the turbulence, which is assumed to be made up of a 

collection o f randomly directed eddies. The interactions 

between these eddies and the particles arc taken into 

account by a stochastic procedure, referred to as the eddy 

life time concept. Particle interactions with the wall are 

computed using a coefficient of restitution coefficient equal 

to 0.9. 

3.1. Boundary conditions 

At the inlet to the horizontal section (downstream o f (6) 

in Fig . 2), a full y developed turbulent velocity profile was 

specified for the air, 

1/7 

( « ) 

At the exit o f the vertical test section, the total mass 

flow rate of gas out of the flow domain was set equal to 

that specified at the inlet. Since this exit boundary condi-

—•— Flow Straightener 

—e— Plain Elbow 

L/D=3.0 

E 

CL 

O 

c 

8 

c 

o 

O 

<u 

•a 

'€ 

ca 

a. 

12 

9 

6 

3 

0 

bee 

Uo=30 m/s 

A7F=3.0 

R/D=1.5 

12 

L/D=5.0 

9 > 

6 

A 

3 

Q 

12 

L/D=7.0 

9 -

6 

3 

$ 

0 

_j i 

L/D=9.0 

in 

E 

is 

o 

o 

<u 

> 

(B 

CO 

CL 

40 

30 

20 

10 

0 

40 

30 

20 

10 

0 

—•— Flow Straightener 

— «— Plain Elbow 

UD=3.0 

Uo=30 m/s 

A/F=3.0 

R/D=1.5 

40 

30 

20 

10 h 

0 

40 

30 

20 

10 

0 

L/D=5.0 

L/D=7.0 

L/D=9.0 

0.0 0.2 0.4 0.6 0.8 1. 0.0 0.2 0.4 0.6 0.8 1.0 

x/D x/D 

Fig. 6. Comparison of particle concentration profiles for A/F— 3.0 (plain elbow, Rc/D = 1.5 and flow straightener). 

VES017206 
II. Bilirgen, EX. Levy / Powder Teclmology 119(2001) 134-152 

lion was specified downstream far from the elbow, a full y 

developed flow was assumed at this location; and the axial 

gradients of all transported variables were set to zero. 

No-slip boundary conditions at the wall and the wall 

function concept were used for the near wall regions of the 

gas How, eliminating the necessity of extremely fine grids 

in these regions. 

Measurements showed that the particle distribution in 

the horizontal section upstream o f the elbow was not 

completely uniform. Therefore, the particle locations, velocities and mass fluxes measured in the horizontal section 

one diameter upstream of the elbow were used in the 

numerical calculations as inlet conditions for particles, as 

shown in Fig. 3. 

A total of 5000 computational particles was tracked 

throughout the flow domain. Each computational particle 

carried the same flow rate and was assumed to be spherical, The particle diameters were stochastically sampled 

using a Rossin Rammler distribution function (Eq. (9)) and 

particle size distribution information obtained from the 

sieve analysis given in Table 1. 

Plain Elbow 

Flow Straightener 

Prob(Diameter > d) = exp (9) 

The quantity d m is the mean particle diameter and n is 

the spread of the data from the mean, calculated as 59 p,m 

and 2.64, respectively. 

Details of the numerical method and solution algorithm 

are described in Ref. [5]. 

4. Rope dispersion mechanisms 

Secondary motions in pipe bends arise due to the 

response o f a viscous element to an imbalance between the 

centripetal acceleration and the cross-stream pressure gradient induced by lateral curvature o f the main flow. A s a 

0.25 r 

0.20 j 

0.15 • 

0.10 

0.05 

0.00

 ; 

Plain Elbow 

Flow Straightener 

Uo=30 m/s 

A/F=3.0 

R/D=1,5 

0 2 4 6 8 10 

Axial Distance From Bend Exit, IVD 

Fig. 7. Normalized maximum transverse velocity as a function of axial 

distance (U0 / U). 

0.15 ; Uo=30 m/s 

A/F=3.0 

R/D=1.5 

0.05 

0 2 4 6 8 10 

Axial Distance From Bend Exit, L/D 

Fig. 8. Turbulent intensity of (he air as a function of axial distance 

(li/l/t/,). 

result, the axial velocity profile is distorted and the point at 

which the velocity has its peak is shifted towards the outer 

wall. A n accentuated double vortex flow structure occurs 

in the fluid phase (Fig. 4) and a significant phase separation in the particulate phase is experienced within the bend 

geometry due to the density differences and to the centrifugal forces. Upon exiting from the bend, the particles flow 

together in a nan'ow localized stream, which is referred to 

as a particle rope. The dispersion of a particle rope is 

achieved mainly by flow turbulence and the accentuated 

double vortex flow structure created by the elbow. 

Recently, Yilma z [1] studied both the rope formation 

process and the individual effects of secondary flows and 

flow turbulence on rope dispersion downstream of a plain 

elbow using the CFX-Flow3 D software. The numerical 

simulation results showed that the secondary velocities 

transported the particles from within the rope to the particle-free regions whil e the flow turbulence was responsible 

for localized mixin g in the region immediately adjacent to 

the rope. 

In the present study, the effect o f secondary velocities 

on the rope dispersion characteristics was studied experimentally, l n order to eliminate the secondary velocities, a 

flow straightener was placed at the beginning of the vertical section following the elbow. The flow straightener had 

eight peripheral and three radial elements in a 0.308-m-long 

(two pipe diameters) pipe section. The location and the 

geometry of the flow straightener are shown in Fig . 5. 

Fig, 6 shows the radial variations ofth e particle concentration and velocity distributions downstream of the flow 

straightener for A/F—iSS and (70 = 30 m/s. Th e rope 

structure stayed attached to the outer pipe wall at all 

elevations, resulting in the largest particle concentrations at 

the wall. In the vicinity of the outer pipe wall, the acceleration of the particles within the particle rope was significantly reduced, probably due to particle-particle and particle-wal l interactions. Moreover, the particles within the 

rope occupied a small portion o f the pipe cross-section 

even at higher elevations (L/D = 9.0), indicating that the 

VES017207 
/ / . Bilirgen, E.K. Levy/ Powder Teclmology 119(2001) 134-152 

particle transport in the radial direction of the pipe crosssection was negligible in the absence of secondary velocities, 

In order to compare the dispersion characteristics between the cases with and without the flow straightener, 

liber optic measurements were performed for both cases 

for the same flow conditions {R„/D = 1.5, U0 = 30 m/s, 

A/F = 3.0). The measured particle concentrations and velocities are compared at 3.0, 5.0, 7.0 and 9.0 pipe diameters from the pipe bend exit plane in Fig, 6. As can be 

seen, the rope dispersion characteristics for each flow 

configuration occurred differently. The most prominent 

difference between the two cases is that the peak particle 

concentrations with the flow straightener are larger than 

139 

those without the flow straightener (plain elbow) at all 

elevations. In addition, the rope remained attached to the 

outer wall in the vertical pipe downstream of the How 

straightener, while it moved towards the midsection o f the 

pipe for the case without a flow straightener. This suggests 

that the secondary flows not only cany the particles around 

the pipe circumference but also move the rope structure 

away from the outer wall. 

There are also some differences in the particle axial 

velocitj' profiles for these two cases. The particle velocity 

profiles downstream of the bend without a flow straightener (plain elbow) resembled the letter "U" , with larger 

velocities at the edges o f the rope and smaller velocities at 

the center. On the other hand, the particle velocity changed 

L/D=0.0 

A/F=3.0 

L/D=1.0 

A/F=3.0 

L/D=3.0 

A/F=3.0 

L/D=5.0 

A/F=3.0 

L/D=7.0 

A/F=3.0 

L/D=9.0 

A/F=3.0 

x/D 

—Flow 

Fig. 9. Predicted particle concentration contours downstream ofthe flow straightener. 

VES017208 
UO / / . Bilirgen, E.K. Levy/ Powder Technology 119 (2001) 134-152 

almost linearly with the .v-axis for the case of a flow 

straightener, having the minimum values at the wall and 

the maximum values at the edge ofth e rope. 

Numerical simulations were performed for the cases of 

the plain elbow and the flow straightener. The primary 

objectives of the numerical simulations were to investigate 

the effects o f the flow straightener on both the rope 

structure and the flow field and to understand the mixing 

processes occurring in each flow configuration. 

The CF D simulations for the cases with and without the 

flow straightener showed that the gas phase secondaryvelocities after the flow straightener (2D from the elbow 

exit) were significantly reduced as shown in Fig. 7. On the 

other hand, the turbulence intensity in the gas phase was 

only slightly affected by the flow straightener (see Fig . 8). 

Fig . 9 shows the contour plots o f the predicted particle 

concentrations in the pipe cross-section at different axial 

distances away from the bend exit for the case with a flow 

straightener. It can be seen from these plots that the 

particles did not spread over the pipe cross-section, as they 

normally do without a flow straightener. However, a reduction in the predicted maximum particle concentration 

from 28.4 (at the exit o f the bend, L/D = 0.0) to 7.5 

kg/m 3 (at L/D = 9.0) indicated that localized particle 

mixing occurred inside the region adjacent to the outer 

wall. Localized particle mixin g is probably due to a combination of flow turbulence and particle-wall and particle -

particle interactions. 

The numerical results were validated by comparing the 

C F D results with the experimental data obtained wit h the 

fiber optic probe. Fig . 10 shows comparisons of predicted 

particle concentrations with the measured data at four 

different axial distances away from the bend exit for 

A/F =3. 0 and U0 = 30 m/ s for the case of the flow 

£ 

Q. 

o 

rf 

o 

12 

9 

6 

3 

0 

12 

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6 

3 

0 

12 

9 

6 

3 

0 

12 

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6 

3 

0 

—•• Predictions, CFX- 4 

° Data, Fiber Optic 

L/D=3.0 

Uo=30 m/s 

A/F=3.0 

R/D=3.0 

°\ 

o \ , 

L/D=5.0 

0 \ 

-o \ 

o \ 

L/D=7.0 

° o \ 

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L/D=9.0 

K \ 

0.0 0.2 0.4 0,6 O.l 

x/D 

CL 

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30 

20 

10 

0 

40 

30 

20 

10 

0 

Simulations, CFX- 4 

o Data, Fiber Optic 

L/D=3.0 

O, -" L/D=5.0 O, -" 

Uo=30 m/s 

- A/F=3.0 

R/D=3.0 

4 0 

30 

20 

10 

o 

o -

o . --

o 

3 3 ° 

L/D=9.0 

'.0 0.2 0.4 0.6 0.8 1.0 

x/D 

x/D 

HA//r/ v V 

—Flow 

Fig. 10. Comparisons of particle concentrations and velocities downstream of the flow straightener. 

VES017209 
II. Bilirgen, E.K. Levy / Powder Technology 119 (2001) 134-152 141 

conditioner. In general, the predicted results show good 

agreement with the experimental data, particularly at the 

elevations close to the elbow exit {L/D = 3.0 and 5.0). 

However, the numerical simulations were not able to predict the measured rapid dispersion rate in particle concentration further downstream of the elbow (L/D = 7.0 and 

9.0). These differences most likely occurred because the 

present model does not account for particle-particle and 

irregular particle-wall interactions. 

Comparisons of particle velocities at different axial 

distances from the bend exit show that the profiles of axial 

velocity were in good agreement with the numerical simulations (Fig . 10). However, the numerical calculations 

slightly overestimated the particle velocities at three diameters downstream of the bend, while the particle velocities 

were underestimated after seven diameters downstream of 

the elbow. In general, however, the predicted particle 

concentrations and velocities can be considered in very 

good agreement with the experimental data when the 

complexity of the flow is taken into consideration. 

5. Rope dispersion with mixing devices 

5.1. Nozzles 

t. I'v 

h $ / i 

I: t 

, Particle 

Concentration 

Profiles 

Mixing 

Layer 

jet Core 

Streamline 

Curvalure 

/'•-" 

Rope 

Flo w 

A - A Detail 

Flow 

Fig. 12. Skelch of the jel mixing mechanism downstream of a nozzle. 

The possibility of dispersing a particle rope i n a turbulent jet flo w formed by a convergent nozzle was investigated. Nozzles having a constant nozzle throat height to 

P

 D 

U d -I 

i— - D ^ 

Fig. 11. Nozzle geometry. 

diameter ratio (H/D ) of 0.8 and beta ratios of 0.5, 0.67 

and 0.83 were studied. The nozzle beta ratio (/3 ) is 

defined as the ratio of the nozzle bore diameter to the pipe 

diameter. The nozzle geometry and a schematic of the tesl 

section arc shown in Fig. 11. 

Previous jet studies showed that the basic physical 

mechanism responsible for particle dispersion in jet flows 

is the mixing layer, where the flow is dominated by a 

series of large-scale longitudinal vortices [6,7]. These longitudinal vortices result i n the presence o f streamline 

curvature downstream of the nozzle exit, which then moves 

some particles towards the pipe wall. The mixing layer and 

the region of streamline curvature are sketched in Fig . 12. 

Loca l particle concentrations and velocities were measured using the fiber optic probe at four axial distances 

from the bend exit plane (L/D = 3.0, 5.0, 7.0, and 9.0). 

These measurements were performed on the pipe symmetry axis by traversing the probe along the .v-axis (symmetry axis) from the outer wall to inner wall (from x/D = 0.0 

to x/D =1.0). 

The effect of nozzle f3 ratio and the air-to-solids loading ratios (A/F ) on rope dispersion were studied by 

comparing time-averaged particle concentration and velocity profiles downstream ofth e flow. Figs. 13 and 14 show 

the radial variations of the particle concentration and velocity profiles as functions of /3 at four different axial 

distances (L/D = 3.0, 5.0, 7.0 and 9.0), for a conveying 

velocity of 30 m/s, and fo r air-to-solids loading ratios of 

A/F =3.0 and 1.0. As can be seen from these figures, 

VES017210 
142 / / . Bilirgen, EX. levy/Powder Technology 119 (2001) 134-152 

10 

8 

6 

4 

2 

0 

P=0.5 

|i=0.67 

P=0.83 

X" 

Poo -

-

Flow 

f —» I 

fc«-cr:::it.:.S;:S:,, 

10 

8 

6 

4 

2 

0 

0.0 0.2 0.4 0.6 0,8 1.0 

x/D 

0.0 0.2 0.4 0.6 0.8 1.0 

x/D 

Fig. 13. Measured radial varialions of the particle concentration and velocity profiles as a function of nozzle beta ralio ( B) (Ua = 30 m/s; A/F = 3.0; 

L/D = 3.0, 5.0, 7.0 and 9.0). 

there are significant non-uniformities in measured particle 

concentrations and velocities, particularly at three diameters away from the bend exit. A t L/D = 3.0, the largest 

particle concentration (or strongest rope-like structure) was 

measured downstream of the /3 = 0.83 nozzle, while the 

(3 = 0.5 nozzle created the lowest peak particle concentration. The dispersion of the rope structure was almost 

complete five diameters downstream o f the bend exit fo r 

/J = 0.5 and 0.67. However, a non-uniform particle concentration and velocity distribution persisted until nine 

diameters downstream of the bend exit for the nozzle with 

/3 = 0.83. 

The CF D predictions of the particle concentration and 

velocity profiles downstream o f the nozzles with /3 = 0.5 

and 0.67 are compared with the measurements perfomied 

by the fiber optic probe in Figs. 15 and 16. A total o f 5000 

spherical particles was tracked through the flow domain. 

The effect of the flow turbulence on the particle behavior 

was modeled by a stochastic method proposed by Gosman 

and Ionnides [16]. However, the influence of the particles 

on fluid turbulence was not modeled. Whil e the interactions between particles and the wall were modeled using a 

coefficient of restitution, particle-particle interactions were 

ignored. 

VES017211 
/ / . Bilirgen, EX. levy / Powder Technology 119 (2001) 134-152 143 

25 

20 

15 

10 

5 

0 

°- 15=0.5 

" [3=0.67 

' (3=0.83 

1 ,- 1 % -e°»[r».Jf| 

Uo=30 m/s 

A/F=1.0 

R/D=1.5 

0.0 0.2 0.4 0.6 0.8 1.0 

x/D 

80 

60 

40 

20 

0 / 

/ 

UD=3.0 

Q. 

> 

O 

CD 

> 

o 

80 

60 

40 

20 

0 

80 

60 

40 

20 

0 

80 

60 

40 

20 

0 

L/D=5.0 

/ /"'-)-

L/D=7.0 

• •n o 

' o - .(. .<> o 

L/D=9.0 

0.0 0.2 0.4 0.6 0.8 1.0 

x/D 

Fig. 14. Measured radial varialions ol'lhe particle concentration and velocily as a function of nozzle beta ratio (13) (U0 — 30 m/s; A/F = 1.0; L/D = 3.0, 

5.0, 7.0 and 9.0). 

The magnitude of the peak particle concentration, observed in the center o f the pipe at L/D = 3.0, was underestimated by the CF D predictions for both nozzle beta 

ratios. On the other hand, the particle concentrations at the 

pipe wall were overestimated by the CF D predictions. 

However, the CF D predictions were able to qualitatively 

predict the presence of particle restratification in the vicinity of the wall. For j3 = 0.5 and 0.67, "U " shaped particle 

concentration profiles were observed after approximately 

five diameters downstream of the elbow. The local increase in tlie mean particle concentration adjacent to the 

wall was produced by longitudinal vortices (or streamline 

curvature) which carried the particles into the viscous 

sublayer where they became trapped [7], 

In order to facilitate a quantitative comparison between 

the cases, a mixing index (MI) was defined based on the 

VES017212 
144 II Bilirgen, EX. Levy / Powder Teclmology 119(2001) 134-152 

particle concentration profile along the pipe diameter at a 

given axial location. The mixing index (MI) was computed 

using: 

1V2 

M l = — 

1 

n - 1 E (cm(k)-cpy (10) 

where C p is the mean particle concentration in the pipe 

cross-section, Cm{k) is the local particle concentration 

measured at equally spaced radial locations in the x-direction, and n is the total number o f measurements along the 

pipe diameter. Eq . (10) gives the degree of variation in 

concentration as a standard deviation. The flow is assumed 

to be well mixed when M I tends to zero. The mixing 

perfonnance for each flow condition was estimated and 

compared by using the mixing index parameter. 

Fig . 17 shows M I for four combinations of U0 and 

solids loading with the f3 = 0.5 nozzle. The restratification 

phenomenon described in earlier paragraphs is particularly 

noticeable from these curves at larger values o f L/D with 

U0 — 15 m/s. Fig . 18 compares the values o f M I for the 

three nozzles, all with c/o = 30 m/ s and A/F =5.0. 

These results show there were large improvements in 

mixing as the nozzle (3 ratio was reduced from 0.83 to 0.5. 

5.2. Lateral jet injection 

The use of air jets to break up a particle rope and avoid 

saltation in long horizontal pipes was first suggested by 

Weintraub, in a discussion o f Patterson's paper [8]. However, no study has been reported since then to investigate 

the effect o f air jets on rope dispersion. In a study by 

Johnson and Means [9], air jets were used in an attempt to 

reduce erosion in bends. In the Johnson and Means' study, 

the erosion rate in a 90° elbow with an air injection was 

reduced by about 50% compared to that for a standard 90° 

elbow. 

In the present study, the use of air jets was investigated 

as a possible rope dispersion technique. A jet injector was 

designed to create an air jet in a plane perpendicular to the 

main flow stream as shown in Fig . 19. ln preliminary 

experiments, the effect of jet flow rate on the mixin g 

performance was studied by varying the injected flo w rate. 

These measurements were performed at seven pipe diameters away from the bend exit for three different jet flow 

rates (m,). These results show fairly well dispersed flow 

structures at the measurement location with an air injection 

rate of 5.4% o f the total flow rate in the pipe (see Fig . 20). 

VES017213 
II. Bilirgen, E.K. levy / Powder Teclmology 119 (2001) 134-152 145 

O 

| 4 

ra 

§ 2 

c 

o 

O 

CO 

co ,, 

0. 6 

L/D=5.0 

Data 

Predictions 

0 

-

Nozzle, [3=0.67 L/D=9.0 

Uo=30 m/s 

A/F=30 

R/D=1.5 

i i i 1 

0.0 0.2 0.4 0.6 0.8 1.0 

x/D 

0.0 0.2 0.4 0.6 0.8 1.0 

x/D 

Fig. 16. Comparisons of particle concentration and velocity distributions downstream of a nozzle with B = 0.67. 

In order to determine the best orientation for the jet tested. The mixing performance with each configuration 

injector, three different circumferential positions were then was first evaluated by visual inspection using a transparent 

Uo=30 m/s&A/F=3.0 

Uo=30m/s&A/F=1.0 

Uo=15 m/s & A/F=3.0 

Uo=15 m/s & A/F=1.0 

10 

Uo=30 m/s 

A/F=30 m/s 

R/D=1.5 

(1=0.5 

(i=0.67 

(3=0.83 

4 6 8 

Distance From the Bend Exit, L/D 

Fig. 17. Mixing indices for the p = 0.5 nozzle. 

10 

2 4 6 8 10 

Distance From the Bend Exit, L/D 

Fig. 18. Mixing indices for nozzles with 0 = 0.5, 0.67 and 0.83 (i7„ = 30 

m/s; A/F= 1.0; and Rc/D=l.S). 

VES017214 
f f . Bilirgen. E.K. Levy / Powder Teclmology 119 (2001) 134-152 

Jet al Oilier 

Wall 

, D 

7(7 ul Inner Wall 

.lei al Onier Wall 

Fk. 

Fig. 19. Plane jet injection system for inner and outer jets. 

test section, which was located between L/D = 2.0 and 

4.0. Detailed fiber optic measurements were then perfomied. According to the visual observations, the jet injector was able to destroy the rope better when it was located 

either at the inner wall (inner jet) or outer wall (outer jet) 

(see Fig. 19). The least effective rope dispersion was 

observed when the jet injector was located on a side wall. 

Detailed fiber optic measurements were performed for 

two jet configurations, inner jet and outer jet, for a constant normalized jet flow rate (m;) of 5.4% and for a 

conveying air velocity o f 30 m/s. In addition, the effect of 

air-to-solids loading ratio was investigated for each configuration. Since the flow was not symmetrical about the 

A'-axis, the fiber optic measurements were performed over 

the pipe cross-section by traversing the probe along the 

radius at eight circumferential locations, 45° apart from 

each other. In each case, the jet injector was located one 

diameter downstream o f the bend exit (L/D= 1.0) as 

shown in Fig. 19. 

2 

CD 

Q. 1 

o 

0.0 

Uo=30 m/s 

A/F=3.0 

L/D=7.0 

-- o -

mi=0.0 % 

<:' - mi=3.0 % 

- o- mi=4.2 % 

mi=5.4% 

0.2 0.4 0.6 0.8 1.0 

x/D 

E 4 

JSC 

c l 

O 2 

0 

A

 Uo=30 m/s mi=0.0 % 

/> « • A/F=1.0 - • mi=3.0 % 

13 ' 

/ 

X

 A L/D=7 0 <• mi=4.2 % 

<> 

&• \\ O mi=5.4 % 

n A \ \ 

-

G- —o— 

"Q. 

ts ..... 

' -o .. 

o 

--••8 

i J 

0.0 0.2 0.4 0.6 

x/D 

0.8 1.0 

40 

35 

30 

E 

c i 25 

> 

20 

15 

0.0 0.2 0.4 0.6 0.8 1.0 

x/D 

35 

.52 30 

E 

D. 

> 25 

20 

0.0 0.2 0.4 0.6 

x/D 

0.8 1.0 

Jet at Outer Wall 

i ... Rope \ j j Flow 

/ I! 

| >x/D 

Fig. 20. Effect of air injection rate for A/F - 1.0 and 3.0. 

VES017215 
/ / . Bilirgen. E.K. Levy / Powder Technology 119 (2001) 134-152 147 

5.2./. Plane jel front inner wall 

Fig. 21 illustrates the particle concentration contour 

plots for A/F =3.0 and 1.0. At three diameters away 

from the bend exit plane, the particle rope was positioned 

unsymnietrically, having moved towards a side wall. The 

asymmetrical particle concentration distribution at L/D = 

3.0 was probably caused by nonuniformities in the particle 

concentration distribution in the horizontal pipe upstream 

of the elbow. 

However, at five and seven diameters downstream of 

the bend exit, the particle concentrations, were fairly symmetrically distributed over the pipe cross-section. The 

majority of the particles were located in the central region 

with peak particle concentrations (C p ) ranging from 1.0 to 

2.0 (kg/m3). These C p values are significantly lowe r than 

those for the case o f the plam elbow (no flow mixin g 

device). 

5.2.2. Plane jet from outer wall 

The experiments were repeated for the case when the jet 

injector was positioned at the outer wall (referred to as 

outer jet). The particle concentration contour plots at difInner Je t 

A/F=3. 0 

Ft/D=1.5 

L/D=3. 0 

Inner Je t 

A/F=1.0 

R/D=1.5 

L/D=3.0 

hJiy ro 

0.1 

4.1, 

'•o 'tp 

o.:-

L/D=7. 0 

0 • 

t 0.4 

OS ! 

/ 5 

\ 

;-L 8 

0.4 / 

0.7 

\ 

Jet at Inner Wall 

l V j 

2 4 <, ' 

. 1-u / 

L/D=7. 0 

Rope 1 Air Jet 

Fig. 21. Measured particle concentration contours downstream ofthe inner jet injector for A/F ~ 3.0 and VQ — 30 m/s. 

VES017216 
us 11. liilirgci,. E.K. Levy / Powder Technology 119 (2001) 134-152 

fcrent axial distances arc shown in Fig. 22. The particle 

rope does not appear lo he affected by the air jet at three 

diameters away from the bend exit plane for either solids 

loading rate (A/ F — 3.0 and 1.0), however, the effect of 

the air jet is clearly seen at L/D = 5.0. At this location 

( L/D = 5.0 for A/F = 3.0 and 1.0), the rope was divided 

into several small topes, each of which had relatively low 

particle concentrations and was located at a side wall. 

Moreover, downstream of the mixing plane, the flow 

exhibited a rotational particle motion. Once again, this 

probably occurred because of the asymmetrical particle 

distribution in the horizontal inlet pipe. The rotational 

motion was more pronounced for low solids loading rate 

(A/F= 3.0). 

Quantitative comparisons between the inner and outer 

jets were made by using the mixing index (Fig. 23). These 

comparisons reveal that the inner jet established a more 

homogeneous flow distribution over the pipe cross-section. 

These results clearly show how the orientation of the jet 

injector is important to obtaining optimal mixing. 

5.3. Swirl vanes 

Swirling two-phase flows are encountered i n many 

engineering applications, including combustion systems 

and cyclone separators. Extensive research efforts have 

been expended i n understanding and characterizing the 

effects of swirling flows [10-13]. 

The degree o f swirl usually is characterized by a swirl 

number S, which is a nondimensional number representing 

the axial flux o f angular momentum divided by the product 

o f the pipe radius and axial momentum flux. The swirl 

number is defined as follows, 

r uur

2

dr 

R(Rv

2

rdr 

(11) 

where u and u are tangential and axial velocities, respectively, and R is the pipe radius. 

Outer Jet 

A/F=3.0 

Uo=30 m/s 

0.1 

L7D=3.0 

Outer Jet 

A/F=1.0 

Uo=30 m/s 

L/D=3.0 

0.6 

L/D=5.0 

•-1 9 

L/D=5.0 

0.2 

0.5 

0.7 

0.7 

L/D=7.0 

0.3 

Jet at Outer Wall \ 1 . * ~ 

L/D=7.0 

Air Jet /.- . Rope \ | j Flow 

--<;. i@ ) | — 

Fig. 22. Measured particle concentration contours downstream of the outer jet injector for A/F = 1.0 and 3.0 and (70 = 30 m/s. 

VES017217 
/ / . Bilirgen, E.K. Levy/Powder Teclmology 119 (2001) 134-152 \49 

Inner Jet 

Outer Jet 

3 4 5 6 7 

Axia l Distanc e Fro m Ben d Exit, L/D 

2.0 

g 1.5 

"D 

1.0 

0.5 

••o - Inner Jet 

- • — Outer Jet 

A/F=1.0 

Uo=30 rn/s 

rrij=6 % 

R/D=1.5 

3 4 5 6 7 

Axia l Distanc e Fro m Ben d Exit, L/D 

Fig. 23. Comparison of mixing indices between inner jet and outer jet for A/F = 3.0 and 1.0. 

Recently, swirling flow has been applied to pneumatic 

conveying systems to reduce pressure drop, pipe blockage, 

pipe wear, and particle deposition [14]. 

In the present study, the swirling flow was used to 

disperse the particle rope created by the elbow. The calculation of tlie swirl number (S) was based on the swirl vane 

angle, <j>, as suggested by Lille y [10]. 

2 

S=-tanc/> (12) 

For vane angles of 15, 30 and 60, for example, approximate swirl numbers are 0.2, 0.4 and 1.2, respectively, Here 

100% efficiency is assumed for the swirl vanes. 

Fig . 24 shows a sketch of the experimental test section, 

where a counter-clockwise rotation was generated at the 

exit o f the elbow, between L/D = 0,0 and 2.0, using 

vaned swirlers. Two different designs for generating 

swirling motion were used. In the first design, eight swirl 

vanes were installed inside the test section, providing a 

swirl number {S) of 0.13. In the second design, a swirl 

number (5) of 0.26 was achieved with four swirl vanes 

placed inside the test section. Therefore, the results show 

the combined effects of both the swirl number and the 

number of swirl vanes on the rope dispersion characteristics. 

The fiber optic probe measurements of particle concentration were performed over the pipe cross-section at three 

different axial locations for A/F*= 3.0 and U0 = 30 m/s. 

Fig. 25 illustrates the particle concenfration and velocity 

contours for S = 0.13 and 0.26. It can be seen from Fig. 25 

that for the S — 0.13 case, the rope created by the elbow 

was split into several rope-like structures by the swirl 

vanes and each individual flow structure spiraled around 

the pipe circumference. These smaller rope structures had 

relatively small particle concentrations compared to the 

original rope (here, the term "original rope" refers to the 

rope exiting the 90° elbow). Although the original rope 

was destroyed by the swirl vanes, the rotational motion of 

each smaller particle rope persisted further downstream. 

Mor e importantly, the peak particle concentration o f each 

rotating particle structure remained relatively unchanged as 

the flow moved downstream. In fact, a slight increase in 

the peak particle concentration was observed after three 

pipe diameters from the bend exit. A s mentioned by Hira i 

and Takagi [15], owing to the body force field resulting 

from tlie swirling motion, a counter effect of the swirling 

motion was observed further downstream of the flow , and 

the particle mixin g was retarded. 

D—1 

Fig. 24. Experimental test section and swirl vanes. 

VES017218 
150 / / . Bilirgen, F..K. Levy/Powder Technology 119 (2001) 134-152 

Swirl Vane s -1 

A/F=3.0 

S=0.13 

Swirl Vane s - 2 

A/F=3.0 

S=0.26 ____ _ L/D=3.0 

R/D=1.5 o.<b ~-- x 

/CP> " o \ 

/ * ' . ' \ 

, o °- 4 ; a 

L/D=7.0 

Fig. 25. Particle velocity and concentration contours for S = 0.13 ( A/F - 3.0, U0 = 30 m/s and /?,./£> = 1.5). 

The mixin g index values for both swirl numbers are 

compared in Fig . 26. A s can be seen from this figure, the 

values of the mixin g indices slightly increased further 

downstream of the swirl vanes, indicating a strengthening 

of the smaller rope structures. 

2.5 ;--

I 2.0 I 

x~ ; 

QJ 

C 1.5 ; 

ro 

1 1.0; 

0.5 i 

S =0.13 A/F=3.0 

Uo=30 m/s 

R/D=1.5 

3 4 5 6 7 8 

Axial Distance From Bend Exit, L/D 

Fig. 26. Mixing index values as a function of axial distance. 

6. Summary and conclusions 

Rope dispersion characteristics in the absence o f secondary flows were investigated in the first part o f this 

study. It was observed that the rope dispersion rate was 

significantly reduced when the double vortex structure 

formed by the elbow was eliminated with a flow straightener installed immediately after the elbow. Furthermore, 

no significant particle dispersion in the radial direction 

towards the inner wall was observed in ihe absence o f the 

flow straightener. These findings confirm the importance 

of secondary velocities in transporting the particles from 

within the rope to the particle-free regions. 

VES017219 
I f . Bilirgen. E.K. l.cuy/ Powder Technology 119 (2001) 114-152 151 

In Ihe second part of the study, the rope dispersion 

characteristics of several types of mixing devices were 

studied. These included convergent nozzles, air jet injection, and .swirl vanes. 

The liber optic measurements for the fi — 0.5 and 0.67 

nozzles showed that the local particle concentration at the 

pipe wall increased slightly after approximately three diameters downstream of the bend exit, caused by a partial 

restratification of the flow further downstream. Moreover, 

a strong dependency of rope dispersion on the conveying 

air velocity, air-to-solids loading ratios, and nozzle beta 

ratios was found, with more uniform particle distribution 

over the pipe cross-section occurring for higher conveying 

air velocities, lower solids loadings and smaller beta ratios. 

A l l mixing techniques, except the fi = 0.83 nozzle, 

were able to disperse the particle rope within nine pipe 

diameters from the bend exit plane. However, there are 

some disadvantages of these designs for practical applications. For instance, the nozzles with fi — 0.5 and 0.67 

cause excessive pressure drop. The pressure drop caused 

by the 0 = 0.83 nozzle was 9 kPa (36 in. H 2 0 ) for an 

average conveying air velocity of 30 m/ s and A/F = 3.0. 

The air jet injection technique requires additional fan 

power and also increases the total flow rate of conveying 

fluid carried by the pipe. With swirl vanes, an effect of 

swirling motion on particle mixing was observed further 

downstream of the flow. A s a consequence of the centrifugal forces, local particle concentration increased at the pipe 

wall, causing some particle restratification as the particles 

were transported downstream. 

The CF D predictions are in good agreement with the 

measurements performed with the fiber optic probe. De -

spite slight differences from the experimental data, the 

C F D predictions were able to predict the most important 

flow phenomena observed by the measurements. 

Nomenclature 

A 

A/F 

C D 

C

P 

c, 

D 

d 

d m 

e 

Fd 

FT 

L/D 

Pipe cross-section area (m2) 

Air-to-fue l mass flow rate ratio (-) 

Drag coefficient (-) 

Particle mass concentration (C p = p p (l — e)), 

(kg/m 3) 

k-e model constant 

Inside pipe diameter (m) 

Orific e or nozzle bore diameter (m) 

Particle diameter (u.m) 

Mean particle diameter (fxm) 

Coefficient o f restitution 

Drag force (N) 

Total force acting on a particle (N) 

Axia l dimensionless distance downstream of the 

elbow exit (m) 

Normalized injected jet flow rate 

Solids mass flow rate (kg/s) 

Radius of curvature of elbow (m) 

Re. 

S 

SI 

u 

k i 

Particle Reynolds number (Rep = p\U K \ d f / / j . ) 

Swirl number 

Stokes number (Sr = ppdfU0/\8u.DT) 

Loca l fluid velocity (m/s) 

Conveying air velocity (m/s) 

w' Fluctuating air velocities (m/s) 

T 

mis air velocity v « (m/s) 

Particle velocity (m / s) 

Relative particle velocity (with respect to air) 

p 

x/D 

x, y 

mis particle velocity (J'-'pH yi/' p j , (m/s) 

Dimensionless transverse distance from outer wall 

of elbow (m) 

Transverse distances in pipe cross-section (m) 

Greek letters 

Particle density (kg/m 3) 

Fluid viscosity (kg/ms) 

A i r density (kg/m 3) 

General Variable 

Ratio of orifice diameter to pipe diameter (/3 = 

d/D ) 

Turbulence dissipation rate (nr/s 3) and Voidage 

(e=l-V p / V T ) 

References 

[1] A. Yilmaz, Roping Phenomena in Lean Phase Pneumatic Conveying, Lehigh University, PhD Dissertation, 1997. 

[2] A. Yilmaz, EX . Levy, Particle Velocity and Concenfration Measurements in Lean Phase Pneumatic Conveying Using a Fiber Optic 

Probe, Proceedings of 1998 ASME Fluids Engineering Division 

Meeting, Fluid Measurement and Instrumentation Fortim, Paper No. 

FEDSM98-5282, Washington, DC, 1998-b. 

[3] CFX-4.2 User Manual. Computational Fluid Dynamics Services, 

AEA Technology, Harwell, England, 1997. 

[4] B.E. Launder, D.B. Spalding, The numerical compulation of turbulent flows, Comp. Meth. Appl. Mcch. Eng. 3 (1974) 269-289. 

[5] II. Bilirgen, Mixing and Dispersion of Particle Ropes in Lean Phase 

Pneumatic Conveying, Lehigh University, PhD Dissertation, 2000. 

[6] CT . Crowe, M . Sommerfeld, Y. Tsuji, Multiphase Flows with 

Droplets and Particles, CRC Press, 1998. 

[7] J.K. Eaton, J.R. Fessler, Preferential concentration of particles by 

turbulence, Int. J. Multiphase Flow 20 (1994) 169-209. 

[8] R.C. Patterson, Pulverized coal transport through pipes, J. Eng. 

Power (1959)43-54. 

[9] E.K. Johnson, K.H. Means, Erosion studies in pneumatic transport 

bends, Engineering Foundation Conference—Pneumaiic and Hydraulic Conveying Systems, April 21-25, 1996. 

[10] D.G. Lilley, Review: swirl flows in combustion, AIAA J. 15 (1977) 

1063-1078. 

[11] M. Sommerfeld, H.H. Qiu, Cliaraclerizalion of particle-laden, confined swirling flows by phase-doppler anemometry and numerical 

calculations, Int. J. Multiphase Flow 19 (19) (1993) 1093-1127. 

VES017220 
152 II. Bilirgen. E.K. Lety / Powder Technology 119 (2001) 134-152 

[12] II, Li, Y. Tomita, Experimental study of .swirling How pneumatic 

conveying system in a vertical pipeline. .1. Fluids Eng., Trans. 

ASME 120 (1) (IWS) 200 203. 

113] li. Li, Y. Tomita, Experimental study of swirling ilow pneumatic 

conveying system in a horizontal pipeline, J. Fluids Eng., Trans. 

ASME I IK (3) (19%) 526 -530. 

[14] II. Li, Y. Tomita, K. Funatsu, Research of swirling flow pneumatic 

conveying system in a horizontal pipeline, Trans. ASME 58 (1992) 

1599-1604. 

115] S, Hirai, T, Takagi, Parameters dominating swirl effects on turbulent 

transport derived from stress-scalar flux transport equation, Int. J. 

Heat Mass Transfer 38 (12) (1995) 2175-2182. 

[16] A. Gosman, E. Ionnides, Aspects of computer simulation of liquidfueled combustors, AIAA paper. No. 81-0323 (1981). 

VES017221 
VES017222-017230.pdf 
Open Journal of Fluid Dynamics, 2013, 3, 331-339 

Published Online December 21)13 (http://www.scirp.org/joumal/ojfd) 

liltn:/'dx.doi.org/]0.42.3(V()ifil.Z()l 3.34040 

4 » ; > Scientific 

Research 

Experimental and Numerical Study of Dilute Gas-Solid 

Flow inside a 90° Horizontal Square Pipe Bend 

Walid Aniss Aissa1'

2

, Tarek Abdel Malak Mekhail 1, Soubhi Al i Hassanein', Osama Hamdy3 

' Department of Mechanical Power, Faculty of Energy Engineering, Aswan University, Aswan, Egypt 

"Faculty of Engineering, King Abdulaziz University, Rabigh, K.SA 

'Upper Egypt Flour Mills Co., Sohag, Egypt 

Email: mina_tarek@hotmail.corn 

Received October 12, 2013; revised November 21, 2013; accepted November .30, 2013 

Copyright €5 2013 Walid Aniss Aissa el al. This is an open access article distributed under the Creative Commons Attribution License, which permits unrestricted use, distribution, and reproduction in any medium, provided the original work is properly cited. 

ABSTRACT 

A pneumatic test rig is built to test a curved 90* square bend in an open-circuit horizontal-lo-horizontal suction win d 

tunnel system. Sand particles are used to represent the solid phase with a wide range ofparticle diameters. Velocity profiles are constructed by measuring the gas velocity using a 3-hoIe probe. Flow patterns inside the bend duct are introduced using sparks caused by burning sticks of incense with the air flow inside the piping system for flow visualization 

purpose. Numerical calculations are performed by Lagrangian-partiele tracking model for predicting particle trajectories 

of dispersed phase, and standard k - e model for predicting the turbulent gas-solid flows in bends. Comparisons made between the theoretical results and experimental data for the velocity vectors and particle trajectories show good agreement. 

Keywords: 90" Bend; CFD ; Gas-Solid Flow; k - s Model 

1. Introduction 

The research, optimal design and malfunction diagnoses 

of pneumatic conveying systems require a fundamental 

understanding and detailed information of both the gas 

and particle phases. It is common for a conveying mill 

duct system to incorporate 90° bends for changing the 

direction o f the particulate flow within a limited space. 

Gas-solid flow inside 90" bends is complex and chaotic 

and perhaps for this reason is not completely understood. 

There are many of documented experimental and numerical studies relating to gas-particle two-phase flows 

in channels and ducts involving curved 90° bends. 

Sharma [1] developed a particle tracking direct numerical simulation code to carry out the large-scale turbulent flow and particle transport computations on serial 

and parallel computers. Fairweather and Yao [2] studied 

numerically three sizes (1, 50, and 100 pm) of particle 

dispersion in fully developed turbulent duct flows at 

three Reynolds numbers up to 250,000. Humphrey el al. 

[3] reported the first comprehensive air flow velocity 

measurements using LD A for a square sectioned curved 

90° elbow bend. 

Mekhail et al. [4] conducted CF D simulation of gassolid two-phase flow in a 90° bend, predicted the gas 

Open Access 

velocity vectors. They adopted a computational flui d 

dynamic code (CFX-TAS C flow) for the simulation of 

the flow field inside the piping and for the simulation of 

the particle trajectories. They conducted comparison between the results with those presented by Yang and Koran 

[5]. Particle trajectories inside 90° square bend were predicted using Lagrangian particle tracking model [6]. Also , 

the effect of presence of solid particles on the velocity 

field and the erosion pattern using Finnic's erosion mo -

del was studied. Mossad et al. [7] summarized the numerical and experimental investigations of turbulent air 

flows inside a right-angled sharp 90° elbow bend. They 

compared the CF D predictions of mean velocity profiles 

of the air flow inside the sharp 90° elbow bend against 

the experimental results obtained using Laser Doppler 

Anemometry (LDA). Njobuenwu et al. [8] studied turbulent gas-solid flows in square ducts with a 90° bend 

numerically using an Fulcrian-Lagrangian approach coupled under the assumption of one-way coupling using a 

stochastic approach based on a random Fourier scries 

method. 

Cheng and Wang [9] developed a model for the impaction efficiency of aerosol particles in 90° bends; based 

on an analytical laminar flow solution and gave the 

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VES017222 
W. A. AISSA ET AL. 

separation efficiency as a function ofthe Stokes number 

and curvature ratio. Crane and Evans [10] performed 

numerical calculations to predict the behavior of aerosol 

particles in laminar flow in 90° bends. Cheng and Wang 

11 1) re-examined the separation of particles in the bends. 

They concluded that in the laminar flow regime, the particle separation was mainly a function of Stokes number 

and flow Reynolds number (Re) for curvature ratio between 4 to 20. 

A numerical study was done by Keating and Nesic [12] 

to investigate the erosion-corrosion in a three-dimensional square-sectioned 180° U-bend using lagrangian 

tracking model for simulating the particle motion and 

three models for predicting the erosion rates, Finnic's 

model, Bergevin's model, and Nesic's model. 

Hence, it is needed to create a whole picture of the dilute phase gas-solid flow behavior and the characteristics 

in 90° duct bend. An understanding of the role of particle 

properties such as the size, and size distribution or erosion pattern will probably provide the ultimate solution 

to the problem. However, it is very difficult to quantify 

the properties such as particle size distribution, particle 

concentration and so meas urahle bulk properties associated with gas-particle interactions. 

The present paper documents an experimental and 

numerical study of dilute-gas solid flow in a horizontal 

90° bend with a uniform cross-section. Under the assumptions that the solids at dilute concentration have a 

negligible contribution to gas-phase turbulence, experimental measurements of gas and solids flow properties 

are performed separately. For the gas-phase, velocities 

are measured using a three-hole probe. For the dispersedphase, burning sticks of incense are utilized to provide 

visualization of solids motion and their distribution inside the duct. Numerical simulations are performed for 

the same flow condition. Validation of the model settings 

are achieved by repeating a published flow case. 

2. Test Rig Facility 

Figure 1 shows a schematic diagram of the test rig designed with the objective of handling the research activities of the main transport mode, i.e., dilute phase conveying. It mainly consists of an open supply hopper with 

slide gate valve, number of conveying pipes with a 

transparent 90° bend that form an open-circuit pneumatic 

conveying line. In addition, a cyclone separator involved 

with an air-lock valve is placed after the piping system in 

order to separate the solids from the flow at the exit of 

the line. At the end of the conveying line, a high pressure 

centrifugal fan provides the suitable pressure drop needed for the air flow. 

The test setup consists of three square sectioned pipeline ducts of the same cross-section area (0.15 m x 0.15 

Open Access 

Figure 1. Schematic diagram of the test rig. 1: Supply hopper; 2: Slide gate valve; 3: Upstream duct; 4: Duct joint; S: 

90° duct bend; 6: Downstream duct; 7: Cyclone separator; 8: 

Centrifugal fan. 

m) and each has a length of 1.5 m. The pipes are 

mounted horizontally in 90° angle and are connected by a 

90° bend. The bend is 3 mm in thickness and is made of 

Perspex. The bend and the two duct joints are perforated, 

as shown in Figure 2, vertically to the direction o f the 

stream to allow doing the required measurements. 

2.1. Gas Phase and Velocity Measurements 

The measurement of air velocity as well as static pressure 

is very important for the present study in order to know 

the flow pattern, the air velocity distribution at different 

sections and identify the zones of flow separation; if exits. 

For measuring purposes; a three-hole probe; Figure 3, is 

used for velocity measurements of the gas phase only. 

Velocity measurements are taken at the vertical plane 

of the 90° duct bend at various locations in the duct's 

streamwise direction. At each plane, with the aid o f a 

traversing mechanism, the vertical measurements are 

taken with an increment of 0.075 m in the upstream and 

downstream square pipes and of 0.05 m in the 90° square 

bend and the horizontal measurements are taken with an 

increment of 0.025 m in each pipe. At the bend section, 

velocity is measured at five locations from 0' to 90° at 

15" intervals as shown in Figure 4. 

2.2. Solid Phase and Flow Visualization 

The knowledge of mean velocity profile of gas flow is 

required to get an insight of the trajectories of the particles, which represent the solid phase flow within the gas 

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W. A. AISSA ET AL. 

Figure 2. Perforated 90° bend and the two duct joints. 

Figure 3. A photograph of the 3-hole probe. 

0.15 m x 0.15 m Crosssection (/) ^-0.15 m) Flow, Out 

Flow, In 

phase. This helps us to obtain an overall picture of the 

flow particles inside the bend, get a deeper understanding 

ofthe flow phenomena and determine the parameters that 

control and govern particle trajectories and impacts with 

the bend wall. Hence, the erosion could be analyzed. 

A s the bend is made of a transparent thermoplastic 

(Perspex), the flow pattern could be visible by introducing sparks caused by burning sticks of incense within the 

air flow inside the piping system. A digital camera (Sony 

DSC-W310 Cyber-shot 12.1 Mega pixels) is fixed i n a 

specific position to take photos of the flow process. Photos of the flow process are taken in a darkened room to 

make the sparks more visible and detectable. The sparks 

represent the particles (solid phase) flowing with the gas 

phase. 

3. Numerical Simulation 

With the increase of computer power and advancement 

of commercial modeling software, computational flui d 

dynamics (CFD) technique is gradually becoming an 

attractive tool to study turbulent gas-particle flow problems. CF D has the capacity of providing the "microscopic" or "local" information, for instance, the maximum and minimum gas and particle velocity, local particle concentration and individual particle trajectory [13]. 

Another feature of CF D approach is the graphical presentation of the flow geometry, velocity, pressure, erosion 

pattern and particle concentration fields. 

3.1. Gas Phase 

Using a commercial CF D software CFX-2.9.0, the governing equations, Equations (1) and (2), of mass and 

momentum of the gas phase are numerically solved to get 

the flow fields and velocity vectors ofthe gas phase; 

dp _ e 

d l +'dx , 

(p«, ) = o 

5

 l \ d I \ d P dT<< c 

dl 8.x. 

(1) 

(2) 

Figure 4. Bend geometry. 

In the above equations, », represents the velocities in 

the ^,-coordinatc directions, p is the static pressure, p is 

the density, r,. is the viscous stress tensor and the 5" terms 

are additional source terms. Assumptions made in formulating the tracking model are listed in [14]. 

The governing equations arc discietiscd using finile 

volume approach and the grid generator employs a multigrid linear solver to solve the dicretised equations using 

upwind difference. Recent, comparisons between CF D 

and the experiments have shown that the standard k- e 

model is capable of predicting accurately the important 

global performance indicators, such as the entrainment 

and pressure lift ratios, and that the main difference bcOpcn Access OJFD 

VES017224 
114 W. A . AISSA ET AL. 

tween turbulence models lies in their prediction of local 

flow structure; Fan cl al. [15]. The standard k -1: model is 

used lo predict the turbulence in the straight and bend 

ducts. The computational domain starts 2D upstream the 

bend entrance and extends 2D downstream the bend exit. 

Uniform velocity was imposed at the downstream duct 

inlet plane of the bend with wall boundary conditions 

imposed on the top and bottom and also along the sides 

of the 90' square duct. The solution procedure of finite-volume descretization scheme, is solved over one 

grid system that has a cross-sectional cell density o f (ID 

-45 , JD = 45, K D = 135) or 91125 cells shown in Figure 5. 

In the current study, air is used as the canier fluid and 

is flowing at a bulk velocity (Vh) of 9.6 m/s, the Reynolds 

number based on the bulk velocity, hydraulic diameter of 

the square cross-section and kinematic viscosity of air is 

(Re = 1.708 * 105) and the pressure at the outlet is 

101,325 Pa. 

Moreover a grid independent test is carried over using 

three grid system of (ID = 30, JD = 30, KD = 90) or 

81,000 cells and the second one with a a mesh size o f (ID 

» 30, JD - 30, KD = 90) or 273,375 cells and the third 

one is finer with a mesh size of (ID = 60, JD = 60, KD = 

180) or 648,000 cells. The fine and medium cases showed the same results. 

3.2. Solid Phase 

Tbe most widely applied method available to determine 

the behavior of the dispersed phase is to track several 

individual particles through the flow field. Each particle 

represents a sample of particles that follow an identical 

path. The behavior of the tracked particles is used to describe the average behavior of the dispersed phase. This 

Jk. .£&w - -

Figure 5. The computational grid. 

Open Access 

method is called separated flow analysis [16]. The separated flow analysis has been implemented as a Lagrangian tracking model to characterize the flow behavior of 

a dispersed phase and is optionally available in the 

CFX-TASCflo w software. 

The forces acting on the particle which affect the particle acceleration are due to the difference in velocity 

between the particle and fluid and due to the displacement ofthe fluid by the particle. The equation of motion 

for such a particle can be written as: 

m

p ^ -

 = F D + F

* + F

l «

+ F A+ F

.

 (3 ) 

where, mp is the particle mass, subscript p represents particle properties and the subscripts D, g, ps

, A and e respectively denote the force components arising from drag, 

gravity, flow pressure gradient, added mass effect and 

external forces such as electrical field. A detailed description o f mathematical models for the force components considered in Equation (3) is available in [16]. 

Sand particles are used here to represent the solid 

phase with solids loading ratio of 1.2. To detennine the 

percentage of different sizes contained within the sand, a 

particle size analysis (sieve analysis) is performed. Particle diameter is analyzed and it is found that there are 

seven groups of particle diameters, 63 u.m, 125 p.m, 200 

pm, 400 pm. 630 pm, 800 pm and 1250 pm. Figure 6 

shows an averaged particle size distribution (by volume) 

over the sand sample. The panicle size distribution versus cumulative volume percentage is also plotted in Figure 7, which indicates that the diameter of sand particles 

is approximately about 0.2 mm at 10%. and 1.2 m m at 

90% of the cumulative mass retained. 

4. Results and Discussion 

4.1. Gas Phase 

The duct has devided into 13 planes as shown in Figure 

8. Figures 9(a) & (b) and 10(a) & (b) show experimental 

30 -i 

20 -

15 -

10-

5 -

aiT, t-t - -r-l 

0.0 0.2 0.4 0.6 0.8 1.0 1.2 1.4 1.6 1.8 2.0 2.2 

Size (mm) 

Figure 6. Particle size distribution by volume percentage 

retained. 

O./Ff) 

VES017225 
W. A. AISSA ET AL. .3.35 

0.0 0.2 0.4 0.6 0.8 1.0 1.2 1.4 1.6 1.8 2.0 2.2 

Size (mm) 

Figure 7. Particle size distribution by cumulative volume 

percentage retained. 

Plane (1) 

Plane (4) 

Plane (13) 

Plane (5) plane <9) P'me(lO) 

Figure 8. Duct measured planes. 

1.20 

1.10 

1.00 

0.90 

0.80 

0.70 

- si 

•S2 

•S3 

•S4 

-S5 

1.20 

1.10 

1.00 

0.90 

0.80 

0.70 

-•—S4 

-*-S 5 

Figure 9. Mean streamwise gas velocity profiles in different planes, (a) Plane (1); (b) Plane (4); (c) Plane (5); (d) Plane (9); (e) 

Plane (10); (f) Plane (13). 

and numerical streamwise velocily profiles o f the gas 

phtase at the upstream duct. It may be remarked that the 

gas is quite evenly distributed which indicates that the 

flow is symmetric in the straight section and the gas velocity is increased slightly as the gas accelerates from 

inlet with Vm = 9.6 m/s till nearly 10 m/s at the end of the 

straight duct. The numerical simulation successfully predicted the acceleration of the gas phase near the inner 

wall. As the flow advances closer to the bend; Figure s 

9(c) & (d) and 10(c) & (d), it begins to experience the 

influence of the bend, which results in the mean velocity 

profiles becoming slightly skewed, with a small acceleration near the inner wall due to the favorable pressure 

gradients and a slight deceleration near the outer wall due 

to the adverse pressure gradients. As seen, the numerical 

simulation successfully predicted the acceleration of the 

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VES017226 
3)6 W. A. AISSA ET AL. 

1.40 

1.20 

1.00 

o.xo 

0.60 

0.40 

0.20 

0.00 1 m i 

0.0 0.2 0.4 0.6 0.8 1.0 

(a) 

0.0 0.2 0.6 0.8 

(c) 

1.40 

1.20 

1.00 

0.80-

0.60-

0.40-

0.20 

0.00 

f -•—S I 

—•—S3 

S4 

—»-S 5 

f -•—S I 

—•—S3 

S4 

—»-S 5 

\ 

-•—S I 

—•—S3 

S4 

—»-S 5 

-•—S I 

—•—S3 

S4 

—»-S 5 1 

-•—S I 

—•—S3 

S4 

—»-S 5 

0.0 0.2 0.4 0.6 0.8 

(c) 

1.40 

1.20 

I.OO 

O.80 

O.60 

0.40 

0.20 

O.OO 

—•— si 1 — — S2 

— — S4 

— — S5 

— — S2 

— — S4 

— — S5 

— — S2 

— — S4 

— — S5 

— — S2 

— — S4 

— — S5 

0.0 0.2 0.4 0.0 0.8 1.0 

(b) 

0.2 0.4 

(d) 

1.40 

1.20 

1.00 

0.80 

0.60 

0.40 

0.20 

0.00 

• ° 1 

_^S 3 

—_S 4 1 

1 

(0 

Figure 10. Predicted mean streamwise gas velocity profiles in different planes, (a) Plane (1); (b) Plane (4); (c) Plane (5); (d) 

Plane (9); (e) Plane (10); (f) Plane (13). 

gis phase near the inner wall. The presence of the favorable and unfavorable pressure gradients was caused by 

the balance of centrifugal force and radial pressure gradient in the bend. 

The effect of the bend on the flow continues downstream of the bend, Figures 9(e) & (f) and 10(e) & (t), 

with a reversal of the location of the peak velocity toward the outer wall, leading to a deceleration near the 

inner wall and an acceleration near the outer wall. This is 

because of the separation that has occurred in the inner 

section of the bend due to the adverse pressure gradient. 

A comparison between the experimental and numerical results of this study and the results obtained by Yang 

and Kuan [5] are done. Al l data are normalized by the 

bulk air velocity Vh = 9.6 m/s and plotted against a nondimensionalised wall distance; 

(4) 

such that r* = 0.0 at the inner wall and r* = 1.0 at the 

outer wall. Figure 11 shows the results at tbe middle 

plane section of the 90° bend duct (0 = 45°) and the results show that the behaviour of the present study is in 

good qualitative agreement with the observation of Yan g 

and Kuan [5]. 

Figure 11 shows a comparison between the numerical 

and experimental results in the current investigation and 

experimental results presented in [5] (Re = 1.708 

It may be remarked that there is a close agreement 

105). 

4.2. Flow Visualization 

As shown in Figure 12(a), it is obviously seen that the 

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VES017227 
W. A. AISSA ET AL. 337 

0.0 0.2 0.4 0.6 0.8 1.0 

Figure 11. Comparison between experimental, numerical 

present data and published experimental data of Yang and 

Kuan |5|, 0= 45", (Re = 1.708 * 10s). 

trajectories of sparks in the upstream duct bend are effectively linear. As the sparks are injected with the same 

initial velocity of the gas, their motion is strongly influenced by that of the gas, with their trajectories similar to 

those o f the gas flow streamlines, which means that the 

particle streamwise mean velocity profiles are closely 

similar to the gas streamwise mean velocity profiles and 

hence the flow is symmetric. 

Trajectories of the sparks through the bend section are 

presented in Figure 12(b). There are two types of trajectories, The first type is where the sparks tend to follow 

the flow and turning before reaching the outer wall. This 

type represents the particles with small diameters, since 

they possessed lower inertia and gained less momentum 

to overcome the drag of the fluid. The second type is 

where the sparks don't follow the flow and hit the outer 

wall of the bend. This type represents particles with large 

diameters. This can be explained as the motion o f the 

larger particles is dominated by their inertia and hence 

they deviate considerably from the gas streamlines within 

the curved duct. 

Figure 12(c) shows the sparks trajectories in the 

downstream duct bend. Sparks that represent the large 

particles are subsequently continue to encounter other 

walls after rebounding from the outer surface ofthe bend. 

The high probability of large particles impacting on the 

walls o f the bend is clearly of concern in terms o f the 

wall erosion and pitting effects that occur as a consequence. As the flow travels through the bend it loses its 

momentum near the inner wall, while gaining momentum 

near the outer wall. 

This behavior is attiibuted to the flow separation at the 

inner wall, which arises as a result of the adverse pressure gradient found typically in curved bends. At the exit 

of the downstream duct bend section, the flow starts to 

recover from flow separation as the flow starts to re-establish the characteristics of the straight duct flow until it 

reaches to the fully recovered flow characteristics and is 

almost assumed to be a fully developed turbulent channel 

flow. 

Open Access 

1 

/I 

/ 

/ 

(c) 

Figure 12. Visualization of flow pattern in the 90° bend section, (a) Upstream duct; (b) 90° Bend section; (c) Downstream duct. 

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VES017228 
W. A. AISSA ET AL. 

4,3. Solid Phase Simulation 

Lagrangian particle tracking with one-way coupling is 

applied to evaluate particle dynamics within the straight 

and elhow ducts because solid motion has negligible influence on the carrier fluid flow. Based on the separated 

flow analysis results, a total of 20,000 particle tracks arc 

calculated for the given particle size distribution and solids loading ratio of 1.2 is used. The total CP U time taken 

for the solution is (2:40:17) (h:min:scc). The results are 

presented in Figure 13. 

In general, the results obtained numerically using CF X 

show good qualitative agreement with the visualization 

figures in Section 4.2. These figures show the trajectories 

of the particles tracked in a wide range of particle diameters; ranging from 63 pm to 1250 pm, resulting from 

particle size distribution. 

The results show that the particle concentration increases near the outer wall and decreases near the inner 

wall with the increase of particle diameter; Dp. In an attempt to raise the presence of fine particles in the numerical calculation and hence improve the resolution of 

the predicted particle tracks in the inner wall region, 

100,000 particles have been tracked but this did not result in any noticeable improvement. 

5. Conclusion 

Measurements arc done at different locations using a 3-

hole probe to obtain the mean gas flow velocities inside 

(c) (d) 

Figure 13. Predicted particle trajectories of different particle diameters, (a) Dp = 63 pm; (b) Dp = 200 pm; (c) D„ = 630 

pm; (a) Dp = 630 pm. 

Open Access 

straight and bend sections. Mean streamwise velocity 

profiles of gas phase are plotted and they show good 

agreement with the results published in the literature. 

The flow patterns are visualized by introducing sparks 

caused by burning sticks of incense with the air flo w 

inside the duct system. The results show that particles 

with small diameters tend to follow the flow due to low 

inertia and less momentum gained to overcome the drag 

of the gas, but with the increase in the particles diameter 

the particles tend to go in straight lines dominated by 

their inertia. This is a significant parameter that affects 

the erosion pattern. 

Experimental data are used to evaluate CF D simulation results. The mean streamwise gas velocities are predicted and the results arc in good qualitative agreement 

with the experimental data. The particle trajectories are 

tracked by applying Lagrangian-partiele tracking model 

and the results are in good quantitative agreement with 

the flow visualization results. It is noted that increasing 

the number of tracked particles does not result in improvement in the prediction of particle tracks in the inner 

wall region especially for fine particles. 

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TECHNICAL PAPER ISSN 1047-3289 ]. Air & Waste Manage. Assoc. 56:1733-1742 

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Validation of Three New Methods for Determination of Metal 

Emissions Using a Modified Environmental Protection Agency 

Method 301 

Catherine A . Yanca, Douglas C. Barth, Krag A. Petterson, Michael P. Nakanishi, and 

John A. Cooper 

Cooper Environmental Services, LLC, Portland, OR 

Bruce E. Johnsen 

SAIF Co., Portland, OR 

Richard H. Lambert 

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Daniel G . Bivins 

U.S. Environmental Protection Agency, Research Triangle Park, NC 

ABSTRACT 

Three new methods applicable to the determination of 

hazardous metal concentrations in stationary source 

emissions were developed and evaluated for use In U.S. 

Environmental Protection Agency (EPA) compliance 

applications. Two of the three independent methods, a 

continuous emissions monitor-based method (Xact) 

and an X-ray-based filter method (XFM), are used to 

measure metal emissions. The third method involves a 

quantitative aerosol generator (QAG), which produces a 

reference aerosol used to evaluate the measurement 

methods. A modification of EPA Method 301 was used 

to validate the three methods for As, Cd, Cr, Pb, and Hg, 

representing three hazardous waste combustor Maximum Achievable Control Technology (MACT) metal 

categories (low volatile, semivolatile, and volatile). The 

modified procedure tested the methods using more 

stringent criteria than EPA Method 301; these criteria 

included accuracy, precision, and linearity. The aerosol 

generation method was evaluated in the laboratory by 

Volume 56 December 2006 

comparing actual with theoretical aerosol concentrations. The measurement methods were evaluated at a 

hazardous waste combustor (HWC) by comparing measured with reference aerosol concentrations. The QAG , 

Xact, and XF M met the modified Method 301 validation criteria. All three of the methods demonstrated 

precisions and accuracies on the order of 5%. In addition, correlation coefficients for each method were on 

the order of 0.99, confirming the methods' linear response and high precision over a wide range of concentrations. The measurement methods should be applicable to emissions from a wide range of sources, and the 

reference aerosol generator should be applicable to additional analytes. EPA recently approved an alternative 

monitoring petition for an HWC at Eli Lilly's Tippecanoe site in Lafayette, IN, in which the Xact is used for 

demonstrating compliance with the HWC MACT metal 

emissions (low volatile, semivolatile, and volatile). The 

QAG reference aerosol generator was approved as a 

method for providing a quantitative reference aerosol, 

which is required for certification and continuing quality assurance of the Xact. 

INTRODUCTION 

Air toxic metals have been associated with a wide range 

of environmental and human health effects, including 

respiratory disorders, pulmonary disorders, and cancer. 1 2

 EPA regulates the emissions of toxic metals from 

stationary sources under the National Emission Standards for Hazardous Air Pollutants (NESHAP) or Maximum Achievable Control Technology rule. 3

 Currently, 

emissions are estimated based on control efficiencies 

established during performance tests and estimated 

feed rates during normal operations. When actual emissions are measured, EPA Reference Method 29 (Method 

29) is used. 4 However, Method 29 is based on 30-yr-old 

Journal ot the Air & Waste Management Association 1733 

IMPLICATIONS 

The two measurement methods for determining metal 

emissions validated in this study (the Xact and the XFM) 

Include significant improvements in measurement technology. With these two new methods, plant operators can 

make more precise, accurate, and frequent measurements, 

leading to a better understanding of emissions. With the 

new reference aerosol generator validated in this study (the 

QAG), development and evaluation of new measurement 

methods are now more practical. The measurement methods are applicable to a wide range of elements and may be 

applicable to other sources. The aerosol generator may be 

applicable to both organic and inorganic analytes. 

VES017232 
Yanca et al. 

impinger technology with accuracies and precisions on 

the order of 1S%. 5-

7

 The method also involves hazardous chemicals, and it requires long turnaround times. It 

is clear that there are opportunities for improvement in 

the current monitoring technology. 

There have been attempts over the past decade to 

improve metals measurement technology by developing multimetal continuous emissions monitoring systems (CEMS). 8

-

1 0

 None of the proposed technologies 

have been approved for compliance demonstration 

other than those discussed in this paper. The new technology presented here includes three new methods applicable to the determination of hazardous metal concentrations in emissions: a multimetal CEMS-based 

method (Xact), a sampling and analysis measurement 

method (X-ray-based filter method [XFM]), and a National Institute for Standards and Technology (NIST)-

traceable reference aerosol generating method (QAG). 

The methods and the instruments used to perform the 

methods were developed to provide more precise, accurate, and frequent measurement capabilities than are 

offered by Method 29. The Xact method uses a CEMS 

based on X-ray fluorescence (XRF) analysis of aerosol 

deposits (particulate and vapor phase) on reactive filter 

tape. 1 1-

1 2

 XFM is comparable to Method 29 but uses 

reactive filters (solid sorbants) 1 1 '

1 2

 instead of impingers 

to trap both particulate and vapor phase metals, followed by nondestructive XRF analysis ofthe filters. The 

quantitative aerosol generator (QAG) is based on nebulization of a metal-containing solution and produces a 

reference aerosol that can be used to validate measurement methods, such as the Xact and XFM. 

To evaluate the performance of the new methods, a 

test plan1 3 based on the requirements of EPA Method 

3011 4 was developed. Method 301 is a defined procedure 

for validating new pollutant measurement methods that 

could potentially be used to demonstrate compliance 

with permits or other EPA applications. A more stringent 

modification of this procedure was used to validate the 

three methods based on accuracy, precision, and linearity 

criteria. This paper presents: (1) an overview of the three 

methods, (2) the procedure used for validating these 

methods, and (3) the results of the validation tests. Details 

about these instruments and methods, performance specifications, and standard operating procedures are presented elsewhere.15

-

20 

EXPERIMENTAL WORK 

Quantitative Reference Aerosol Generation 

The method for generating a quantitative reference 

aerosol involves the operation of the QAG instrument. 152 1

 Using the QAG, an aerosol of analyte solution droplets is created using a nebulizer. 2 1

-

2 2

 The droplets are then passed into a settling chamber where the 

large droplets are removed and liquid and vapor phases 

are equilibrated. Droplets <30 u.m in diameter are allowed to pass into a drying chamber where they are 

dried before being emitted. The aerosol exiting the drying chamber consists of the transport gas, water and 

metal vapor, and dried salt particles. The aerosol emission concentration (Ca ) is calculated from the analyte 

1734 Journal of the Air & Waste Management Association 

concentration in the nebulized solution (Cs), the solution emission rate (i?m) corrected for vapor loss (Rv), 

and the total volume of nebulizing, drying, and dilution gas used to create the aerosol (FJ. 

C a = y(R„ - R,) (1) 

Quantitation of the emitted aerosol is made possible by: 

(1) using a large reservoir of NIST-traceable analyte solution to minimize the impact of evaporation on solution 

concentration, (2) continuously measuring the solution 

emission rate (i?m) with a NIST-traceable balance, (3) precise control of nebulizer conditions, and (4) stable control 

of the maximum droplet size introduced into the generator's drying chamber such that only aerosols with high 

transport efficiencies are generated. The reference aerosol 

produced by the QA G is process NIST traceable and can be 

used in addition to its other applications to challenge and 

evaluate the accuracy, precision, and linearity of the measurement methods. It is applicable to both metal and 

nonmetal species. 

Metal Concentration Measurement 

Xact. The Xact method of metals measurement uses a 

CEMS, called the Xact CEMS, that collects and analyzes 

a sample of emissions using filter-based technology and 

nondestructive XRF. 1 5-

2 3

 During sample collection, the 

Xact CEMS directs a continuous flow of stack gas 

through a stilling chamber where its velocity is reduced 

(i.e., stilled). A continuous subsample is taken from the 

stilling chamber and drawn through chemically-reactive filter tape, which traps both particulate and vaporphase metals. 1 1

-

1 2 '2 3

 The volume of the sample flow is 

measured, and the filter tape deposits are advanced to a 

position where they are analyzed for metal mass using 

XRF analytical procedures similar to those listed in 

EPA's Compendium Method IO-3.3. 2 4 The Xact CEMS 

then divides the XRF-determined mass per sample by 

the volume per sample and simultaneously reports concentrations for s20 analyte metals every 15 min. During analysis of the current sample, the next sample is 

automatically collected. In the Xact CEMS, sampling 

and analysis is performed continuously in the same 

instrument except for the time required to advance the 

tape (~3 sec) and the time required for automated 

quality assurance checks (~ 1 hr, once per day). Detection limits for the Xact CEMS are listed in Table 1 and 

range from 0,1 n-g/dry standard cubic meter (dscm) to 

~6 |xg/dscm with 15-min sampling times. These limits 

can be lowered significantly by varying sampling and 

analysis conditions. Both the XFM and Xact methods 

are generally applicable to elements with atomic numbers ranging from 13 (Al) to 92 (U). 

XFM. Like the Xact, the XFM uses filter-based technology 

to collect a representative sample of emissions followed 

by nondestructive XRF analysis of the sample. 1 5 '

2 3

 For 

sample collection, the XFM sampling train connects to a 

stilling chamber, such as the one used for the Xact CEMS. 

A representative sample of stack gas is continuously directed into the stilling chamber (at —30-100 L/min), and 

Volume 56 December 2006 

VES017233 
Yanca et al. 

Table 1. Xact and XFM detection limits. 

Xact' XFM* 

Element ((ug/dscm) (iig/dscm) 

Cr 0.3 0.08 

As 0.1 0.08 

Cd 2.4 0.8 

Hg 0.3 0.14 

Pb 0.6 0.12 

Mn 0.2 0.08 

Co 0.3 0.08 

Ni 0.3 0.06 

Se 0.1 0.08 

Ag 4.2 0.6 

Sb 6.2 1.6 

Cu 0.5 0.08 

Fe 0.9 0.12 

Zn 0.2 0.06 

Br 0.4 0.2 

Sr 0.3 0.18 

Tl 0.3 0.14 

Lab Air or 

Stack Gas 

Notes: "95% Confidence, interference free, 15-min sample.

 b95% confidence, 

interference free, 30-min sample. 

the XFM pulls a subsample of ~1 L/min into its samphng 

train. The subsample is diluted and cooled before being 

drawn through a stacked filter cassette containing a polytetrafluoroethylene filter followed by a chemically reactive filter.11'

12

-

23 Particulate-phase metals are trapped on 

the nonreactive polytetrafluoroethylene filter, whereas 

vapor-phase metals, including Hg, are collected on the 

chemically reactive filter or solid sorbent. After sample 

collection, the filter cassettes are removed from the sampling train, and the resulting filter deposits are analyzed 

for metal mass using nondestructive XRF procedures similar to those listed in EPA's Compendium Method IO3.3. 2 4The filters do not require handling during any part 

of the XFM procedure, and they can be readily shipped to 

a laboratory for analysis or analyzed in the field. The 

emissions concentration is calculated by dividing the 

XRF-determined metal mass by the volume of emissions 

that pissed through the filters. Typical sample times are 

30 min, and analysis turnaround times can be on the 

order of a few hours with a field-portable XRF analyzer. 

Detection limits typically range from 0.06 u.g/dscm to 1.6 

p.g/dscm with 30-min sample times (Table 1). Substantially lower detection limits can be attained by varying 

sampling and analysis conditions. 

Method Independence 

The QAG-generated aerosol concentration is independent 

of the aerosol concentrations measured by the Xact and 

XFM. Method independence is confirmed using NIST 

traceability and additional procedures. The concentration 

of the aerosol produced by the QAG is procedurally traceable to NIST through nebulized solution standards and 

Q AG operating parameters. The XFM- and Xact-measured 

concentrations are both analytically NIST traceable 

through thin film standards and NIST Standard Reference 

Materials 1832 and 1833. In addition to the independent 

Xact Stilling XFM 

Chamber Sample Train 

Quantitative 

Aerosol 

Generator 

(QAG) 

"I 

Exhaust 

Figure 1. Experimental arrangement for laboratory and field tests. 

NIST traceability of the generation and measurement 

methods, inductively coupled plasma (ICP) analysis conducted at an independent laboratory (Chester LabNet, 

Tigard, OR) confirmed the standard solution concentrations used in the QAG and the filter deposit measurements made by the XFM method. 

Validation Methodology 

The procedures used to validate the QAG, XFM, and Xact 

were based on EPA Method 301. This EPA method is 

required when new methods of measuring analytes are to 

be used on a source in lieu of the standard reference 

method. Method 301 establishes accuracy and precision 

capabilities of a new method by comparing its determined 

concentrations with those of an accepted reference 

method. The resulting bias between concentrations from 

the two methods is used as an indicator of accuracy. 

Simultaneous method measurements are used to determine precision. Following normal Method 301 procedures, the Xact and XFM measurement methods would be 

tested against Reference Method 29. However, the precision and accuracy of Method 29, which are on the order 

of 15%,5-

7

 were insufficient for verifying the precisions 

and accuracies believed to be attainable with the Xact and 

the XFM (i.e., potential precision <5% and accuracy 

<5%). The validation procedure presented in this section 

is a modified Method 301 in which Method 29 comparisons were replaced with QAG reference aerosol comparisons. 1 3

 This modified method was more stringent than 

Method 301, because it included more replicate runs, 

sequential measurements instead of simultaneous measurements, additional validation criteria (e.g., linearity), 

and independent NIST traceability of results. 

The first step in the modified Method 301 procedure 

required laboratory vahdation of the QAG emissions, and 

the second step was a field validation of the XFM and Xact 

measurements. The general experimental arrangement 

used for both laboratory and field tests is schematically 

illustrated in Figure 1. First, the QAG generated an aerosol, which was blended with laboratory air for laboratory 

tests and stack gas for field tests. The aerosol flow was then 

directed into the Xact CEMS stilling chamber 1517-

1 9

 from 

which the Xact CEMS and XFM simultaneously withdrew 

representative samples. After sampling, the XFM filters 

were removed and analyzed, whereas the Xact automatically reported metal concentrations every 15 min for the 

duration of the test. It should be noted that an Xact CEMS 

located at the Cooper Environmental Services facility was 

Volume 56 December 2006 Journal of the Air & Waste Management Association 1735 

VES017234 
Yanca et al. 

used in the laboratory tests, and an Xact CEMS located at 

Eli Lilly and Company's Tippecanoe facility in Lafayette, 

IN, was used in the field. 

runs had to be used to demonstrate acceptable values for 

accuracy, precision, and linearity.2 5 Accuracy, precision, 

and linearity criteria are defined and discussed below. 

QAG Laboratory Validation. The QAG was evaluated in a 

series of laboratory tests15 in which a QAG-generated 

aerosol was combined with ambient laboratory air and 

simultaneously sampled by the Xact CEMS and XFM sampling train. The theoretical QAG concentration calculated 

using eq 1 was then compared with the actual concentrations measured with the Xact and XFM to detennine the 

accuracy, precision, and linearity of the QAG method. All 

of the QAG-generated aerosols contained As, Cd, Cr, Pb, 

and Hg, representing the volatile, semivolatile, and lowvolatility metal categories as defined in the NESHAP HWC 

rule. 3 Tests were conducted at four concentration levels 

(high, mid, low, and blank) ranging from 0 to >130 

u,g/dscm. In these laboratory tests, the QAG aerosol concentrations were compared with results from a total of 22 

X FM and 135 Xact runs. Only Xact runs that corresponded with simultaneous XFM runs were used for accuracy and precision determinations. All of the runs for 

both methods were used in the linear regression analysis. 

The XFM sample time was 30 min per run and the Xact 

was IS min; concentrations from two Xact runs were 

averaged to represent a 30-min sample period for comparison with the XFM. All of the methods were performed 

according to specifications set forth by their test method 

and standard operating procedures. 1 5-

2 0 

Xact and XFM Field Validation. The Xact and the XFM 

were evaluated in a series of field tests conducted at a 

hazardous waste incinerator, where an Xact CEMS was in 

operation. 1 5 For each field test, the validated QAG was 

used to generate a reference aerosol of known concentration, which was spiked into the hazardous waste incinerator flue gas. This dynamically-spiked flue gas was transported to the Xact CEMS stilling chamber where it was 

simultaneously sampled by the Xact CEMS and XFM sampling train. Measured concentrations from each method 

were compared with the QAG-spiked stack gas concentration to determine the accuracy and precision of the Xact 

and XFM methods. All of the QAG-generated aerosols 

contained As, Cd, Cr, Pb, and Hg, and tests were conducted at four concentration levels (high, mid, low, and 

blank) ranging from 0 to >130 (xg/dscm. During these 

field tests, a total of 24 XFM and 192 Xact runs were 

compared with the QAG aerosol concentrations. Again, 

only conesponding Xact/XFM runs were used for accuracy and precision determinations, but all of the runs 

were used for linear regression analysis. During these 

tests, the background concentrations of the stack gas were 

negligible relative to the spiked stack gas concentrations. 

All of the methods were performed according to specifications set forth by their test method and standard operating procedures. 1 5

-

2 0 

Validation Criteria 

Criteria for method validation were based on Method 301 

bias and precision requirements and were either equal to 

those listed in Method 301 or were more stringent. A 

general criterion for all of the validation tests was that >9 

Accuracy. Accuracy for the ith element (A,) is defined as 

bias (B„ u-g/dscm) divided by the theoretical or reference 

concentration of the QAG generated aerosol (Cp A O, \ig/ 

dscm), expressed as a percent. 

14 

•A, = ^jjnr-100 (2) 

Bias is the difference between the mean measured aerosol 

concentration (Cj*1, ixg/dscm) and the theoretical or reference concentration (CP A G

, u.g/dscm). 

Bl = - CPAG 

(3) 

For the QAG, accuracy values s20% were defined as acceptable for validation. For the measurement methods, 

this same criterion was required for accuracy values determined at concentrations at or near the emission limit as 

required by Method 301. In addition to meeting the 

above accuracy criterion, the bias was required to be insignificant relative to the uncertainty in the bias. In this 

case, the uncertainty in the bias for the /th element (Uf) is 

the square root of the sum of the uncertainty in the QAG 

aerosol concentration (Up A G ) squared and the standard 

deviation of the mean of the measurement method 

concentration (SDMTM) squared, as shown in following 

equation: 

£/?= v'(t/PMi)

2

 + (SDM?)* (4) 

where the QAG propagated uncertainty was estimated to 

be —5% during the laboratory and field tests.15 Bias was 

considered significant at the 95% confidence level if B( > 

2Vf. If B, was found to be significant, a correction factor 

was required. The correction factor (CFt) is calculated by 

dividing the concentration of the QAG aerosol (CP A G ) by 

the concentration of the measurement method (CTM). 

CF. qQAG (5) 

Precision. Total precision for the ith element (Pf) is defined as percent relative standard deviation (PRSD,), or the 

standard deviation (SD() divided by the mean concentration (C,) of a given method determined from sequential 

measurements. 

P[ = -^-100 (6) 

Because there is random variability associated with both 

the QAG aerosol concentration, as well as the measured 

aerosol concentration, the total precision (Pf) is an indicator of the combined variability introduced by all 

1736 Journal of the Air & Waste Management Association Volume 56 December 2006 

VES017235 
Yanca et al. 

Table 2. OAG accuracy determined during laboratory tests. 

Measurement 

Method Element 

Low Concentration 

(-20 |j.g/dscm) 

MM Concentration 

(—65 (Jtg/dscm) 

High Concentration 

(-130 ug/dscm) Average All Runs 

Measurement 

Method Element N Accuracy A, % SD N Accuracy A, % SD N Accuracy A, % SD N Accuracy A, % SD 

Xact 

Cr 8 1.7 1.0 24 1.4 1.4 8 2.4 0.3 40 1.6 1,2 

As 8 1.9 1.7 24 4.1 1.7 8 4.9 1.0 40 3.8 1.9 

Hg 8 2.3 1.4 24 1.3 1.0 8 0.6 0.5 40 1.3 1.1 

Pb 8 2.9 2.1 24 1.5 0.8 8 1.6 1.1 40 1.8 1.2 

Cd 8 2.8 1.8 24 1.7 0.9 8 2.0 1.5 40 2.0 1,2 

XFM 

Cr 4 2.5 1.9 12 2.7 2.7 4 1.5 1.4 20 2.4 2.3 

As 4 2.5 1.2 12 3.0 3.0 4 2.6 1.5 20 2.8 2,4 

Hg 4 6.3 1.1 12 3.5 3.0 4 6.7 5.1 20 4.7 3,5 

Pb 4 2.2 2.2 12 2.3 2.6 4 2.3 1.5 20 2.3 2.2 

Cd 4 6.2 3.4 12 2.0 1.4 4 1.1 0.8 20 2.6 2.5 

Notes: SD = standard deviation. 

components of the generation-measurement system; that 

is, QAG and measurement method. For this series of tests, 

the magnitude of the QAG precision is considered to be 

the same as the measurement method. Therefore, the 

individual precision of the QAG or measurement method 

(PJ is defined as the combined, or total, precision (J?f) 

divided by the square root of 2. 

Pi = PRSD, = (7) 

A precision £10 % was required for the method to satisfy 

established validation requirements. 

Linearity. Evaluation of linearity was based on parameters 

derived from a linear least squares regression analysis of 

the theoretical or reference concentrations and the measured concentrations. Although slope and intercept of the 

regression line were considered, the key linearity criterion 

was the correlation coefficient (r). The QAG and both 

measurement methods must have a conelation coefficient (r) that is aO.85 for method validation. 

RESULTS AND DISCUSSION 

QAG Validation 

Accuracy. QAG accuracy results for each of the five metals 

tested are listed in Table 2. This table includes results from 

a comparison of theoretical QAG concentrations with 40 

Xact and 20 corresponding XFM measurements. Concentrations ranged from a low of -20 ug/dscm to a high of 

—130 u.g/dscm. The QAG demonstrated accuracies <7% 

for all of the elements at each concentration level, well 

below the 20% validation threshold. These results show 

that average QAG accuracy for all runs ranged from a low 

of 1.3% for Hg as measured with the Xact to a high of 

4.7% for Hg as measured with the XFM. The overall average accuracy including all five elements, all three concentration levels, and both methods is 2.5 ± 2.3%. None of 

the biases were determined to be significant. In addition, 

independent ICP analysis of a nebulized solution and 

Table 3. QAG precision determined during laboratory tests. 

Measurement 

Method Element 

Low Concentration 

(-20 ug/dscm) 

Mid Concentration 

(-65 ^g/dscm) 

High Concentration 

(-130 nrj/dscm) Average All Runs 

Measurement 

Method Element H Precision P, % N Precision P, % N Precision P, % n Precision P, % 

Xact 

Cr 8 1.7 24 1.1 8 1.7 40 1.0 

As 8 2.0 24 1.0 8 2.0 40 1.2 

Hg 8 2.0 24 0.7 8 2.0 40 1.1 

Pb 8 2.0 24 0.8 8 2.0 40 1.3 

Cd 8 2.5 24 1.5 8 2.5 40 1.7 

XFM 

Cr 4 1.3 12 2.3 4 1.3 20 1.5 

As 4 1.8 12 2.2 4 1.8 20 1.7 

Hg 4 0.8 12 2.8 4 0.8 20 2.4 

Pb 4 1.7 12 2.2 4 1.7 20 1,6 

Cd 4 2.3 12 1.9 4 2.3 20 1.7 

Volume 56 December 2006 Journal of the Air & Waste Management Association 1737 

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Yanca et al 

Table 4. QAG linearity determined during laboratory tests. 

Method 

Element n R Slope SD Intercept SD 

XFM 

Cr 22 0.999 1.02 0.005 -0.54 0.35 

As 22 0.999 1.05 0.005 -0.71 0.38 

Hg 22 0.999 0.99 0.004 -0.01 0.32 

Pb 22 0.999 1.02 0.007 -1.13 0.51 

Cd 22 0,999 0.98 0.008 0.72 0.56 

Xact 

Cr 135 0.999 1.01 0.004 -0.42 0.25 

As 135 0,999 0.98 0.004 0.31 0.26 

Hg 135 0,999 1.04 0.004 -0.67 0.25 

Pb 135 0.999 1.00 0.005 -0.41 0.30 

Cd 135 0.998 0.98 0.005 0.27 0.35 

Notes: SO = standard deviation, 

selected filter samples were supportive of the XFM measured concentrations. Clearly, these results demonstrate 

that the QAG is an accurate method for generating a 

reference aerosol containing metal concentrations in the 

range from 20 to 130 (jig/dscm. 

Precision. Precision for the QAG and the measurement 

methods tested in the field was determined from sequential measurements taken during a period of ~4 hr. The 

results from these tests are presented in Table 3. The QAG 

demonstrated precisions well below the 10% validation 

threshold; average precisions were better than 3% for all 

of the elements at each concentration level. The average 

Q AG precision for all of the runs ranged from a low of 1% 

for Cras measured with the Xact to a high of 2.4% for Hg 

as measured with XFM. Including all five of the elements, 

all three of the concentration levels, and both measurement methods, the average QAG precision was 2.2%. 

These results show that the QAG is a precise method for 

generating aerosols in the concentration range from 20 to 

130 u.g/dscm. 

Linearity. Linearity of the QAG was analyzed with linear 

least-squares regressions of the measured aerosol concentrations compared with the theoretical concentrations 

over all of the concentration levels. Correlation coefficients (r), slopes, and intercepts from these regressions are 

presented for each element in Table 4. The correlation 

coeffirients for all of the elements as determined with 

each measurement method were >0.99, well above the 

acceptability requirement of 0.85. Slopes ranged from a 

low of 0.98 to a high of 1.05, all within 5% of unity (i.e., 

1.00). Intercepts ranged from -0.01 to -1.13 and were all 

<1% of the concentration range. Plots of the regression 

analyses using all 5 of the metals combined are presented 

for the Xact in Figure 2 and for the XFM in Figure 3. The 

Q AG again demonstrated correlation coefficients of 0.99, 

and slopes were within 0.4% of 1.00. Intercepts were 

<0.3°/4 of the concentration range. A final regression analysis of all of the measured versus theoretical QAG data 

yielded a 0.998 correlation coefficient, a slope within 

0.2% of unity (0.998 ± 0.002), and an intercept <0.1% of 

140 

120 

100 

80 

60 

40 

20 

0 

y = 0.999X - 0.103 

r = 0.998 

n=675 

o Cr 

A As 

• Hg 

X Pb 

+ Cd 

20 40 60 80 100 120 

Theoretical Concentration (ug/dscm) 

140 

Figure 2. QAG linearity as determined by the Xact using all five 

elements. 

the concentration range (-0.04 ± 0.16). This strong linear relationship between the theoretical QAG aerosol concentrations and the independently measured concentrations demonstrates the ability of the QAG to produce 

aerosols quantitatively over a wide range of concentrations. 

Xact Method Validation 

Accuracy. The Xact met the 20% validation criterion for 

accuracies demonstrated at the high concentration level 

(Table 5). For the measurement methods, this level is 

expected to be most representative of concentrations near 

the emission limit as required by Method 301. For the 24 

high-concentration runs, the Xact accuracies ranged from 

1.8% for As to a high of 13% for Hg. The Xact average 

accuracies for all 40 runs ranged from a low of 4.9% for As 

to a high of 16% for Hg. The average Xact accuracy calculated using all five of the elements was 4.7 ± 4,3% for 

the high concentration and 8.3 ± 7.2% for all three of the 

concentration levels. 

Bias was insignificant for four of the five metals but 

was significant for Hg at all of the concentration levels. A 

post-test investigation of this bias revealed a 6% calibration error, although these runs were retained in the dataset without correction. Assuming correct calibration, the 

Hg accuracies would have been on the same order as the 

accuracies of the other four elements; for example, the Hg 

accuracy at the high concentration level would be ~7% (i.e., 

? 

140 -

u 

ID 

120 

TD 

I 100 

C 

••a 80 

c 

s 

c 

60 

o 

•o 40 

I 

20 

0 I 

y = 0.996x - 0.2S6 

r = 0.997 

n = 110 

20 40 60 80 100 120 

Theoretical Concentration (|ig/dscm) 

140 

Figure 3. QAG linearity as determined by the XFM using all five 

elements. 

1738 Journal of the Air & Waste Management Association Volume 56 December 2006 

VES017237 
Yanca et al. 

Table 5. Xact accuracy determined during field tests. 

Uw Concentration Mid Concentration High Concentration 

(-20 |ig/dscm) (-45 fig/dscm) (-110 |jig/dscm) Average All Runs 

Element N Accuracy A, % SD N Accuracy A, % SD N Accuracy A, % SD N Accuracy A, % SD 

Cr 8 7.4 2.9 8 20 1.6 24 4.5 1.7 40 8.2 6.5 

As 8 3.3 2.4 8 16 1.9 24 1.8 0.7 40 4.9 5.7 

Hg 8 14" 2.1 8 25a 1.7 24 13s 1.0 40 16" 5.2 

Pb 8 13 1.4 8 20 1.4 24 2.4 1.5 40 7.9 7.4 

Cd 8 3.6 2.6 8 16 1.7 24 2.1 0.8 40 5,2 5,7 

Notes: SD = standard deviation; "Bias was determined to be significant for this value. 

6% of the 13% accuracy can be attributed to the calibration 

error). This identified error can be readily corrected and 

future bias, thus, eliminated. As a result, a correction factor 

was not required. In addition to the calibration error, the 

average accuracies for both the Xact and XFM (discussed 

below) were somewhat impacted by biases in the middle 

concentration runs. These biases appear to be the result of 

an increased difficulty in maintaining proper QAG operating conditions in the field compared with the laboratory. 

The biases were not significant, and these runs were retained 

in the dataset. The results presented in Table 5 demonstrate 

a high accuracy for the Xact measurement method even 

with the Hg calibration error and midconcentration biases. 

Furthermore, these results suggest even better accuracies 

with correct Hg calibrations. 

Precision. The Xact demonstrated better than 4% for all of 

the concentration levels, well below the 10% validation 

threshold (Table 6). The average precision for all of the 

Xact runs ranged from a low of 1.4% for Hg to a high of 

1.9% for Cd. Over all five of the elements and all three of 

the concentration levels, the total average precision for 

the Xact was calculated as 1.6%. These results demonstrate the high precision of the Xact over a wide range of 

concentrations. 

Linearity. Xact linearity was evaluated with linear leastsquares regression analysis of the Xact-measured concentrations compared with the QAG-spiked stack gas reference concentrations over all of the concentration levels. 

Regression parameters for each element are presented in 

Table 7. Xact correlation coefficients for all of the elements were >0.99, easily surpassing the 0.85 requirement. Slopes for all of the metals ranged from 0.87 for Hg 

to a high of 1.02 for Pb. Intercepts ranged from -0.79 to 

-1.09, all <1% of the concentration range. A plotted 

regression analysis for all 5 of the metals combined (Figure 4) produced a correlation coefficient of 0.995, a slope 

within 5% of unity (0.952 ± 0.003), and an intercept <2% 

of the concentration range (-1.10 ± 0.18). The strong 

linear relationship between the Xact concentrations" and 

the reference concentrations confirms the Xact linear response and high precision over a wide range of concentrations and demonstrates its ability to accurately measure metals over this range. 

XFM Validation 

Accuracy. The XFM accuracy results for each element are 

presented in Table 8. At the high concentration level, the 

X FM accuracies ranged from 3.5% for Hg to 5.8% for Pb, 

all well below the 20% validation requirement. None of 

the biases were significant relative to their uncertainty. 

The average XFM accuracy for all of the runs ranged from 

a low of 6% for Cd and As to a high of 7.9% for Pb. 

Combining data from all five of the elements, the average 

X FM accuracy was calculated as 4.7 ± 3.1% for the high 

concentration level and 6.5 ± 4.5% for all three of the 

concentration levels. These results clearly demonstrate 

the high accuracy of the XFM measurement method. 

Precision. The XFM precisions (Table 9) all met the 10% 

validation criterion and were better than 7% at all of the 

concentration levels. The average XFM precision for all of 

Table 6. Xact precision determined during field tests. 

Low Concentration Mid Concentration High Concentration 

(-20 ug/dscm) (-45 (xg/dscm) -110 Htg/dscm) Average AK Runs 

Element N Precision P, % N Precision P, % N Precisian P, % N Precision P, % 

Cr 8 2.2 8 1.4. 24 1.3 40 1.6 

As 8 2,4 8 1.6 24 1.0 40 1.7 

Hg 8 1.7 8 1.6 24 0.83 40 1.4 

Pb 8 1.2 8 1.3 24 2.0 40 1.5 

Cd 8 3.4 8 1.4 24 0.83 40 1.9 

Volume 56 December 2006 Journal ot the Air & Waste Management Association 1739 

VES017238 
Yanca et al. 

Table 7. Xact linearity determined during field tests. Table 10. XFM linearity determined during field tests. 

Element N R Slope SO Intercept SO Element N R Slope SD Intercept SD 

Cr 192 0.997 0.951 0.00505 -1.08 0.297 Cr 24 0.997 1.04 0.0174 -1.61 1.39 

As 192 0.998 0.982 0.00487 -0.994 0.287 As 24 0.997 1.07 0.0180 -2.72 1.43 

Hg 192 0.998 0.869 0.00412 -0.788 0.243 Hg 24 0.996 1.04 0.0209 -1.80 1.67 

Pb 192 0.999 1.02 0.00387 -1.09 0.220 Pb 24 0.995 1.07 0.0221 -2.08 1.81 

Cd 192 0.997 0.970 0.00573 -0.802 0.337 Cd 24 0.997 1.05 0.0171 -1.61 1.36 

Notes: SD = standard deviation. Notes: SD = standard deviation. 

the runs ranged from a low of 1.8% for Cr and As and to 

a high of 3.7% for Pb. The total average XFM precision 

was calculated as 2.6% over all five of the elements and all 

three of the concentration levels. These results demonstrate that the XFM met this acceptance criterion and is 

precise over a wide range of concentiations. 

140 

120 

t 

u 

IO 

100 

80 

c 

o 

60 E 

t: >nce 

40 

O 

u 20 

X 

y = 0.952x-1.10 

r = 0.995 

n = 960 

0 Cr 

A As 

• Hg 

X Pb 

+ Cd 

20 40 60 80 100 

QAG Reference Concentration (pg/dscm) 

120 

Figur e 4 . Xact linearity using all five elements. 

Table 8. XFM accuracy determined during field tests. 

Linearity. The results of the XFM linearity evaluation are 

presented on Table 10. These parameters were determined 

with linear least-squares regression analysis of the XFMmeasured concentrations compared with the QAG-spiked 

stack gas concentrations over all of the concentration 

levels. XFM correlation coefficients for all elements were 

aO.99, well above the 0.8S acceptance value. Slopes for all 

of the metals ranged from 1.04 to 1.07, all within 7% of 

unity. Intercepts were all <3% of the linearity test concentration range and ranged from -1.61 to -2.72. A 

plotted regression analysis for all 5 of the metals combined is presented for the XFM in Figure 5. The combined 

metal regression yielded a correlation coefficient of 0.996, 

a slope within 5% of 1.00 (1.05 ± 0.01), and an intercept 

<2% of the full concentration range (-1.96 ± 0.6). The 

strong correlation of the XFM concentrations with the 

reference concentrations demonstrates the ability of the 

XFM to accurately measure a wide range of concentrations and confirms its precision over this range. 

Summary 

A summary of each method's performance in reference to 

the validation criteria is presented in Table 11. This table 

Low Concentration Mid Concentration High Concentration 

( -20 ug/dscm) (-45 fig/dscm) (-110 ug/dscm) Average All Runs 

Element N Accuracy A, % SD N Accuracy A, % SD H Accuracy A, % SD H Accuracy A, % SD 

Cr 4 6.0 3.4 4 12 1,3 12 4.0 2.4 20 6.0 3.9 

As 4 1.7 1.0 4 13 2.5 12 5.0 2.9 20 6.0 4.7 

Hg 4 5.5 3.4 4 15 3.8 12 3.5 3.4 20 6.1 5.5 

Pb 4 8.0 6.4 4 14 2.3 12 5.8 4.0 20 7.9 5.2 

Cd 4 6.7 2.0 4 9.0 2.5 12 5.1 2.5 20 6.2 2.8 

Notes: SD = standard deviation. 

Table 9. XFM precision determined during field tests. 

Low Concentration Mid Concentration High Concentration 

(-20 pg/dscm) (~ 45 ug/dscm) (-110 ug/dscm) Average All Runs 

Element N Precision P, % N Precision P, % H Precision P, '/< t • Precision P, % 

Cr 4 2.3 4 1.0 12 2.2 20 1.8 

As 4 1.5 4 2.0 12 1.9 20 1.8 

Hg 4 2.3 4 3.2 12 2.9 20 2.8 

Pb 4 6.5 4 1.9 12 2.7 20 3.7 

Cd 4 4.7 4 2.0 12 2.4 20 3.0 

1740 Journal of the Air & Waste Management Association Volume 56 December 2006 

VES017239 
Yanca et al. 

0 20 40 60 80 100 120 

QAG Reference Concentration (pg/dscm) 

Figure S. XFM linearity using all five elements. 

clearly shows that the three methods easily passed all of 

the required criteria for all five of the metals. 

CONCLUSIONS 

The three independent methods discussed in this paper 

met EPA Method 301 requirements for compliance applications and are precise, accurate, and linear tools applicable to the determination of hazardous metal concentrations in emissions. The QAG and the Xact technologies 

have currently been approved by EPA for compliance 

demonstration at a HWC. 2 6 In addition to the five elements measured with these tests, the methods are expected to be applicable to most hazardous elements in 

stack and fugitive emissions from stationary sources, as 

well as in the ambient environment. The QAG reference 

aerosol generator could, thus, be used as a generally applicable reference aerosol generator for research, method 

certification, and audits. The XFM measurement methods 

could be used for performance testing, initial certification, 

and continuing quality assurance audits of multimetal 

CEMS. Finally, the Xact could be used to demonstrate 

ongoing compliance through its use as a CEMS, and its 

technology could be extended to an instrumental analysis 

procedure with applications similar to the XFM. 

In addition to the results presented in this paper, all 

three methods have demonstrated high precisions and 

accuracies in other field and laboratory tests. 3 7-

3 0

 The 

measurement methods have also consistently demonTable 11. Summary of validation results. 

Parameters Criteria QAG Method XFM Method Xact Method 

No. of runs (n) s>9 20 12 24 

Accuracy(/) s20% <5% <6%a <7%a

'

b 

Precision (fl <10% <3% <4% <4% 

linearity (r) 20.85 0.99 0.99 0.99 

Notes: "Results from high concentration level; "Assuming correct calibration 

of Hg. 

strated frequent sampling times, rapid analysis turnaround times (15 min for the Xact and 2 hr for the XFM 

if a field-portable analyzer is used), and low detection 

limits. Analysis is nondestructive, and the methods can be 

independently audited with the QAG. In addition to metals, the QAG can potentially generate aerosols of both 

organic and inorganic analytes. 

REFERENCES 

1. Prieditis, H.; Adarason, l.Y. Comparative Pulmonary Toxicity of Various Soluble Metals Found in Urban Particulate Dust Exp. Lung. Res. 

2002, 28, 563-576. 

2. Monn, C ; Becker, S. Cytotoxicity and Induction of Proinflammatory 

Cytokines from Human Monocytes Exposed to Fine (PM2.5) and 

Coarse Particles (PM10-2.S) in Outdoor and Indoor Air; Toxicol. Appl. 

Pharmacol. 1999, 155, 245-252. 

3. U.S. Environmental Protection Agency, National Emissions Standards 

for Hazardous Air Pollutants for Source Categories. In Coife of Federal 

Regulations, 40 CFR 63; U.S. Government Printing Office: Washington, 

DC, 2005. 

4. U.S. Environmental Protection Agency. Method 29, Determination of 

Metals Emissions from Stationary Sources. In Code of Federal Regulations, 40 CFR 60; U.S. Government Printing Office: Washington, DC, 

2005. 

5. U.S. Environmental Protection Agency. Evaluation of Two Methods for 

the Measurement of Mercuiy Emissions in Exhaust Gases from a Mumcipal 

Waste Combustor; EPA 450/4-92-013. U.S. Government Printing Office: 

Washington, DC, 1991. 

6. Rigo, H.G.; Chandler A.J. Quantitation Limits for Reference Methods 

23, 26, and 29; /. Air & Waste Manage. Assoc. 1999, 49, 399-411. 

7. .American Society of Mechanical Engineers, Research Committee 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. 

8. Zhang, H.; Yueh, F.Y.; Singh, J.P. Evaluation of the Potential of LaserInduced Breakdown Spectroscopy for Detection of Trace Element in 

Liquid; /. Air & Waste Manage. Assoc. 20O2, 51, 681-687. 

9. Seltzer, M.D. Performance Testing of a Multimetals Continuous Emissions Monitor. /. Air & Waste Manage. Assoc. 2000, 50, 6. 

10. Sky +, Inc. 1997 Performance Testing of Multi-Metal Continuous Emissions Monitors; DOE/1D-10665. U.S. Department of Energy, Idaho Operations Office: Idaho Falls, ID, 1998. 

11. Cooper, J.A; Fry, S.C; Johnsen, B.E. Apparatus and Methods for Removing Mercury from Fluid Stream. U.S. Patent 6,770,250 B2, 2004. 

12. Cooper, J.A; Fry, S.C; Johnsen, B.E. Apparatus and Methods for Removing Mercury from Fluid Stream. U.S. Patent 6,872,370 B2, 2005. 

13. Draft Test Plan for Validating a Reference Procedure for Measuring tlie 

Concentration of Metals in Eli Lilly and Company's Hazardous Waste 

Incinerator Stack Gas; Cooper Environmental Services: Portland, OR, 

2004. 

14. U.S. Environmental Protection Agency. Method 301, Field Validation 

of Pollution Measurement Methods for Various Media. In Code of 

federal Regulations, 40 CFR 56; U.S. Government Printing Office: 

Washington, DC, 2005. 

15. Method 301 Evaluation of Three Methods for Multi-Metals Measurement 

and Validation; Cooper Environmental Services; Portland, OR, 2006. 

16. Barth, D.C; Yanca, C.A.; Petterson, K.A., Nakanishi, M.P.; Cooper, 

J.A.; Johnsen, BJ.; Lambert, R, H. Aerosol Sci. Tech., submitted for 

publication. 

17. Determination of Metal Concentration In CES'Xact CEMS Stilling Chamber 

Using the CES XFM; Cooper Environmental Services: Portland, OR, 

2006. 

18. Determination of Metal Concentrations from Stationary Sources Using the 

CES XFM; Cooper Environmental Services: Portland, OR, 2006. 

19. Specifications and Test Procedure for X-Ray Fluorescence Based MultiMetals Continuous Emissions Monitoring Systems at Stationary Sources; 

Cooper Environmental Services: Portland, OR, 2006. 

20. Qiiality Assurance Requirements for X-Ray Fluorescence Eased Multi-Metais 

Continuous Emissions Monitoring Systems at Stationary Sources; Cooper 

Environmental Services: Portland, OR, 2006. 

21. Cooper, J.A.; Barth, D.B.; Nakanishi, M.P.; Petterson, K.A.; Yanca, CA. 

A Quantitative, Traceable-to-NIST, Reference Aerosol Generator for 

Evaluating Aerosol Speciation Monitors and Measurement Methods. 

In Proceedings ofthe Air & Waste Management Association's Symposium 

on Air Quality Measurement Methods and Technology, Durham, NC, May 

9-11, 2006; A&WMA: Pittsburgh, PA, in press. 

22. May, K.R. The Collison Nebulizer. Description, Performance & Application. /. Aerosol. Sci. 1973, 4, 235-243. 

23. Cooper, J.A.; Barth, D.B.; Nakanishi, M.P.; Petterson, K.A.; Yanca, CA. 

New Filter-Based Methods for Precise, Accurate, and Timelier Measurement of Metal Emissions. In Proceedings ofthe Air & Waste Management 

Volume 56 December 2006 Journal of the Air & Waste Management Association 1741 

VES017240 
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Association's Symposium on Air Quality Measurement Methods and Txhnology; Durham, NC, May 9-11, 2006; A&WMA: Pittsburgh, I'A, in 

press. 

24. U.S. Environmental 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. 

25. Watson, J.G.; Lioy, P.J.; Mueller, P.K. The Measurement Process: Precision, Accuracy and Validity. In Air Sampling Instruments for Evaluation 

of Atmospheric Contaminants, 6th ed.; Lioy, PJ; Lioy, M.J.Y; Eds.; American Conference of Governmental Industrial Hygienists: Cincinnati, 

OH, 1983; pp 2-7. 

26. Oldham, C.B. Air Measurements and Quality Group, Office of Air 

Quality Planning and Standards, U.S. Environmental Protection 

Agency, Research Triangle Park, NC. Written communication with Eli 

Lilly and Company: Lafayette, IN. 2006. 

27. Hay, K.J.; Boddu, V.M.; Johnsen; B.E.; Cooper, J.A. X-Ray FluorescenceBased Multi-Metal Continuous Emission Monitor Technology Demonstration; ERDC/CERL-TR-OS-3; U.S. Army Corps of Engineers Engineer 

Research and Development Center: Champaign, IL, 2005. 

28. Installation and Use of an X-Ray Based Continuous Emissions Monitor for 

AED Treatability Study; Cooper Environmental Services: Portland, OR, 

2003. 

29. Re-design and Field Testing of an X-Ray Fluorescence Multi-Metals Monitor 

at the Iowa Army Ammunition Plant, Middleton, Iowa Coal Fired Boiler; 

Cooper Environmental Services: Portland, OR, 2005. 

30. Hay, K.J.; Johnsen, B.E.; Ginochio, P.R.; Cooper, J.A. Relative Accuracy 

Testing of an X-Ray Fluorescence-Based Mercury Monitor at CoalFired Boilers; /. Air & Waste Manage. Assoc. 2006, S6, 657-665. 

About the Authors 

Catherine Yanca, Douglas Barth, Krag Petterson, and Michael Nakanishi are environmental scientists at Cooper En -

vironmental Services, LLC. John Cooper is the president of 

Cooper Environmental Services, LLC. Bruce Johnsen is a 

claims adjuster at SAIF Co. Richard Lambert is an engineering consultant at the Engineering Tech Center, Eli Lilly 

and Co. Daniel Bivins is the work assignment manager for 

the Emission Measurement Center of the Office of Air Quality Planning and Standards, U.S. Environmental Protection 

Agency. Address correspondence to: John Cooper, Cooper 

Environmental Services, LLC, 10180 SW Nimbus Ave., Suite 

J6, Portland, OR 97223; phone: +1-503-624-5750; fax: +1-

503-624-2120; e-mail: jacooper@cooperenvironmental.com. 

1742 Journal of the Air & Waste Management Association Volume 66 December 2006 

VES017241 
VES017242-017320.pdf 
United States Environmental Protection Agency, Region 5 

Air & Radiation Division 

77 West Jackson Boulevard 

Chicago, Illinois 60604 

Statement of Basis 

for: 

DRAFT Air Pollution Control Title V Permit to Operate 

No. V-IL-1716300103-2014-10 

issued to: 

Veolia ES Technical Solutions, L.L.C. 

7 Mobile Avenue 

Sauget, Illinois 62201 

October 2014 
Statement of Basis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10,2014 Page 2 of 79 

SUMMARY 

Pursuant to Title V ofthe Clean Air Act (CAA or Act), as amended, 42 U.S.C. § 7401, et seq., 

and its implementing regulations at 40 C.F.R. Part 71, the U. S. Environmental Protection 

Agency is issuing for public comment a draft renewal operating permit (draft permit) for Veolia 

ES Technical Solutions, L.L.C. (Veolia), a hazardous waste storage and disposal facility located 

at 7 Mobile Avenue, Sauget, Illinois. This document sets forth the legal and factual bases for the 

draft permit conditions, including references to applicable provisions ofthe CAA and its 

implementing regulations. This document also describes the derivation of conditions as required 

by 40 C.F.R. § 71.11(b). 

The draft pennit (Permit No. V-IL-1716300103-2014-10) contains emissions limitations and 

standards to assure compliance with all CAA requirements that apply to the source, as well as 

other necessary terms and conditions. This proceeding is subject to the administrative 

requirements of 40 C.F.R. §71.11. The draft permit is subject to a minimum 30-day public 

comment period as required by 40 C.F.R. § 71.11(d). 

VES017243 
Statement of Basis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10,2014 Page 3 of 79 

TABL E OF CONTENTS 

SUMMARY 2 

1.0. GENERAL INFORMATION 6 

1.1. Introduction 6 

1.2. Applicant and Stationary Source Information 6 

1.3. General Facility Description 6 

1.4. Area Classification 7 

1.5. Basis for Title V Applicability 12 

1.6. Application Review History and Application Shield 12 

2.0. EMISSION UNITS AND EMISSIONS 15 

2.1. Emission Units and Process Information 15 

2.1.1. Process Description 16 

2.1.2. Incineration Units 17 

2.2. Insignificant Emission Units and Activities 19 

2.3. Emissions 22 

3.0. AIR PERMITTING AND ENFORCEMENT HISTORY 24 

3.1. Pennitting History 24 

3.1.1. Construction Permits 24 

3.1.2. Title V Permitting History 25 

3.2. Enforcement History and Permit Shield 27 

3.2.1. Allegations of Violation 27 

3.2.2. Permit Shield 28 

3.2.3. Compliance Schedule 29 

4.0. PERMIT TERMS AND CONDITIONS 30 

4.1. Overview of Permit Terms 30 

4.2. Applicable Requirements 31 

4.2.1. GHG Emissions 36 

4.2.2. Prevention of Significant Deterioration of Air Quality (PSD) 37 

VES017244 
Statement of Basis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 4 of 79 

4.2.3. OPLs Required by the HWC MACT 37 

4.2.4. Extrapolation of CPT Feedrates 39 

4.2.5. Feedrate OPLs Included in Veolia's Permit 40 

4.3. Non-applicable Requirements 42 

5.0. MONITORING REQUIREMENTS 46 

5.1. Statutory Requirements 46 

5.2. Feedstream Analysis Procedures for Mercury, LV M and SVM 46 

5.2.1. Overview of Requirements 46 

5.2.2. Deficiencies in Veolia's Current Feedstream Analysis Procedures 49 

5.3. Multi-Metals Continuous Monitoring Requirements 52 

5.3.1. Overview of Requirements 52 

5.3.2. Multi-Metals CEMS and Feedstream Analysis 56 

5.3.3. Deficiencies in Veolia's Current Emissions Monitoring Procedures 58 

5.3.4. Availability of Multi-Metals CEMS 59 

5.3.5. Performance Specifications for the Multi-Metals CEMS 61 

5.3.6. Measurement of Beryllium Emissions 62 

5.4. Other Supplemental Monitoring Provisions Included in the Permit 63 

5.4.1. Emissions Calculation Methodology 63 

5.4.2. Testing Requirements for NOx, VOM and SO2 Emissions from the Incineration 

Units 64 

5.4.3. Visible Emissions Observations for Material Processing Areas 65 

5.4.4. Calculation of VO M Emissions from Material Processing Areas 66 

5.4.5. Visible Emissions Observations for the Drum Crusher 67 

5.4.6. Calculation of VOM Emissions from the Drum Crusher 68 

5.4.7. Periodic Replacement of Carbon in the Carbon Adsorption System 68 

5.4.8. Inspection Requirements for the Submerged Loading Pipes 68 

5.4.9. Visible Emissions Observations for the Bulk Feed Building 69 

5.4.10. Requirements that Ensure Total Enclosure for the Bulk Feed Building 69 

5.4.11. Supplemental Recordkeeping Requirements for the Bulk Feed Building 70 

5.4.12. Monitoring and Recordkeeping Requirements for the Gasoline Storage Tank 70 

5.4.13. Compliance with the Opacity and Other Numerical Limits for the Boiler 71 

VES017245 
Statement of Basis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10,2014 Page 5 of 79 

5.4.14. Periodic Monitoring Requirements for Insignificant Emission Units 72 

5.5. Streamlining 72 

6.0. ENVIRONMENTAL JUSTICE CONSIDERATIONS 75 

7.0. MAJOR CHANGES FROM TH E 2008 PERMIT 78 

7.1. Revision of OPLs and Addition of Monitoring Requirements for Metals and Other 

Pollutants 78 

7.2. Removal of Case-By-Case MACT Determination for the Boiler 78 

7.3. Incorporation of Applicable Requirements for the Emergency Generators 79 

VES017246 
Statement of Basis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 6 of 79 

1.0. GENERAL INFORMATION 

1.1. Introduction 

The 1990 amendments to the CAA established a comprehensive air quality permit 

program under the authority of Title V ofthe Act. Title V requires certain facilities that 

emit large amounts of air pollution (also called major sources) to obtain an operating 

permit, also known as a Title V permit, after the source has begun to operate. This permit 

is an enforceable compilation of all enforceable terms, conditions and limitations that are 

applicable to the source and is designed to improve compliance by clarifying what 

facilities must do to control air pollution. EPA regulations implementing Title V are 

codified at 40 C.F.R. Part 71 for permits issued by EPA or its delegatees and at 40 C.F.R. 

Part 70 for permits issued by states and local agencies pursuant to approved programs. A 

Title V permit is valid for no more than five years and may be renewed in five year term 

increments. 

EPA is the CAA Title V permitting authority for Veolia's Sauget facility. EPA issued the 

initial Title V permit to Veolia on September 12,2008 pursuant to 40 CF.R. Part 71. As 

allowed by Title V, EPA is now proposing to renew the permit for a five year term. 

1.2. Applicant and Stationary Source Information 

Owner: Veolia ES Technical Solutions, L.L.C. 

Facility Name & Address: Veolia ES Technical Solutions 

7 Mobile Avenue 

Sauget, Illinois 62201 

SIC Code: 4953 

Responsible Official & Mailing 

Address: 

Doug Harris 

7 Mobile Avenue 

Sauget, Illinois 62201 

Telephone: (618)271-2804 

Facility Contact: Dennis Warchol, (618) 271-2804 

1.3. General Facility Description 

Veolia owns and operates a commercial hazardous waste incinerator in Sauget, St. Clair 

County, Illinois. Veolia's Sauget facility is a waste treatment, storage and disposal 

VES017247 
Statement of Basis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 7 of 79 

facility that accepts offsite waste for further disposal through incineration. The facility 

includes two fixed-hearth, dual chamber, multi-type feed incinerators (Incineration Units 

2 and 3), each rated at 16 million British thermal units per hour (mmBtu/hr), and one 

rotary kiln incinerator (Incineration Unit 4), rated at 50 mmBtu/hr. Incineration Units 2 

and 3 each use spray dry absorbers with lime slurry injection to control hydrogen chloride 

(HCI) emissions and baghouses for particulate matter (PM). Incineration Unit 4 uses a 

spray dry absorber for HCI control, an activated carbon injection system for mercury 

(Hg) control, and a baghouse for PM control. Containers and bulk shipments of 

hazardous and solid wastes are received, analyzed and transferred to temporary storage 

facilities, processed, and incinerated in one of three incineration units. Figures 1 through 

4 show the layout ofthe facility. 

1.4. Area Classification 

St. Clair County, Illinois, is designated as a moderate nonattainment area for the 8-hour 

ozone National Ambient Air Quality Standard (NAAQS). It is also designated as a 

nonattainment area for the 1997 annual NAAQS for particulate matter with aerodynamic 

diameter less than 2.5 micrometers (PM2.5).1 St. Clair County is classified as attainment 

or unclassifiable with respect to all other NAAQS. 

The area surrounding Veolia has a significant minority population (about 65 percent), and 

a substantial proportion of all persons living within three miles of Veolia (over 30 

percent) live below the federal poverty level. EPA considers the area surrounding Veolia 

as an area with environmental justice (EJ) concerns. See section 6.0 for a detailed 

discussion of the EJ considerations specific to this permit action. 

On May 23, 2011, EPA took final action determining that the Saint Louis PM2.5 nonattainment area in Illinois and 

Missouri has attained the 1997 annual PM2.5 NAAQS , based upon quality-assured, quality-controlled, and certified 

ambient air monitoring data for the 2007-2009 monitoring period. This final determination suspends the States' 

obligation to submit a number of plans for this area but is not equivalent to redesignating the area to attainment. 

The designation of the area will remain nonattainment for the 1997 annual PM2.5 NAAQS until such time as EPA 

determines that this area meets the Act requirements for redesignation to attainment. See 76 Fed. Reg. 29652. 

VES017248 
Statement of Basis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 8 of 79 

wuv^w 

Figure 1. Layout of Veolia's FacUity Showing Units 2 and 3. 

VES017249 
Statement of Basis for DRAFT Title VPermit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10,2014 Page 9 of 79 

(3m 

EDUIPUENT STORAGE 

STIF UU> 

Figure 2. Layout of Veolia's Facility Showing Drum Storage and Lab Pack Repack Areas. 

VES017250 
Statement of Basis for DRAFT Title V Pennit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 10 of 79 

tMA T SIE IOP 

warn r ~ jr 

SIT E UM > 

IHI W 

Figure 3. Layout of Veolia's Facility Showing Additional Storage and Staging Areas. 

VES017251 
Statement of Basis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 11 of 79 

Figure 4. Layout of Veolia's Facility Showing Incineration Unit 4 and Associated Emission Units. 
Statement of Basis for DRAFT Title V Pennit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 12 of 79 

1.5. Basis for Title V Applicability 

Veolia is subject to Title V permitting requirements because it is a major source of 

hazardous air pollutant (HAP) emissions and because it is subject to the requirements 

established under 40 C.F.R. Part 63, Subpart EEE, National Emission Standards for 

Hazardous Air Pollutants from Hazardous Waste Combustors (HWC MACT). 

1.6. Application Review History and Application Shield 

Pursuant to 40 C.F.R. § 71.5(a)(l)(iii), a timely renewal application is one that is 

submitted at least 6 months but not more than 18 months prior to expiration of a Title V 

permit. Since Veolia's existing Title V permit had an expiration of date of October 12, 

2013, Veolia was required to submit its renewal application no earlier than April 12, 2012 

and no later than April 12, 2013. As shown in Table 1, below, Veolia submitted its 

application on April 8, 2013; therefore, Veolia's renewal application is timely. 

Table 1. Application Review History. 

Relevant Date Activity 

April 8,2013 Veolia submits its Title V Permit renewal application. 

May 16, 2013 E PA notifies Veolia that its application is incomplete. 

July 17,2013 Veolia submits (by electronic mail) a preliminary response to 

EPA's May 16, 2013 Notification of Incompleteness. Veolia 

and EP A hold a conference call to discuss the Notification of 

Incompleteness. 

August 16, 2013 Veolia submits an addendum to its renewal application. 

September 11,2013 EPA notifies Veolia that its application is complete. 

November 20, 2013 Veolia submits additional information on its renewal 

application as requested by EPA on November 7, 2013. 

December 9,2013 Veolia submits additional information on its renewal 

application as requested by EP A on December 9, 2013. 

December 10,2013 Veolia submits additional information on its renewal 

application as requested by EPA on December 9, 2013. 

VES017253 
Statement of Basis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Pennittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 13 of 79 

Relevant Date Activity 

December 20, 2013 Veolia submits additional information on its renewal 

application as requested by EP A on December 19, 2013. 

January 14, 2014 Veolia submits additional information on its renewal 

application as requested by EP A on December 11, 2013. 

March 3, 2014 Veolia submits additional information on its renewal 

application. 

March 4, 2014 Veolia submits additional information on its renewal 

application as requested by EP A on March 4, 2014. 

March 10, 2014 Veolia submits additional information on its renewal 

application. 

March 27, 2014 EPA holds a conference call with interested parties to discuss 

public participation opportunities. 

March 31, 2014 Veolia submits additional information on its renewal 

application as requested by EPA on March 28, 2014. 

April 1, 2014 Veolia submits additional information on its renewal 

application. 

April 3, 2014 Veolia submits additional information on its renewal 

application as requested by EP A on April 1, 2014. 

October 10, 2014 EPA issues Veolia's draft renewal pennit for comment. 

E PA reviewed Veolia's April 8, 2013 Title V permit renewal application, as amended on 

August 16, 2013, for completeness pursuant to the criteria in 40 C.F.R. § 71.5(a)(2). 

E PA determined on September 11, 2013 that the information submitted by Veolia was 

administratively complete. As specified by 40 C.F.R. § 71.5(a)(2), the application 

completeness determination does not preclude EP A from requesting additional relevant 

information during the course of evaluating or taking final action on the application. In 

addition, 40 C.F.R. § 71.5(b) obligates Veolia to promptly file corrections to its 

application should Veolia find that it has omitted any relevant facts or has submitted 

inconect information in the application. 

Because EPA found that Veolia's permit application was timely and complete, Veolia is 

covered by an application shield, which allows Veolia to continue operating its facility 

VES017254 
Statement of Basis for DRAFT Title V Permit No. V4L-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 14 of 79 

even though EPA has not yet issued a renewal permit to Veolia. 40 C.F.R. §§ 71.5(a)(2) 

and 71.7(b). This application shield is in effect from the date of completeness until EP A 

has acted on Veolia's pending application, provided Veolia submits any requested 

information by EPA's specified deadlines. The permit application shield does not mean 

lhat EPA has already approved the requested permit, nor does it mean that EPA has 

detennined that Veolia has adequately addressed compliance concerns in its application. 

The permit application shield means only that Veolia may operate its facility until EP A 

has acted on the pending application. 

VES017255 
Statement of Basis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 15 of 79 

2.0. EMISSION UNITS AND EMISSIONS 

2.1. Emission Units and Process Information 

Table 2 shows a listing of all of Veolia's emission units that have applicable requirements 

in the pennit. 

Table 2. Listing of Veolia's Emission Units with Applicable Requirements in the Permit. 

Emission 

Unit Description 

Date of 

Construction 

Emission Control 

Equipment 

Hazardous Waste 

Combustors 

Incineration Unit #2, Model TWI2000, Series 2 October 1986 Joy-Niro Spray Dryer 

Absorber (SDA-2), Pulse 

Flo Fabric Filter (BH-2) 

Hazardous Waste 

Combustors 

Incineration Unit #3, Model TWI2000, Series 2 

November 

1987 

Joy-Niro Spray Dryer 

Absorber (SDA-3), Pulse 

Flo Fabric Filter (BH-3) 

Hazardous Waste 

Combustors 

Incineration Unit #4, Model 

PY*RO X 

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) 

April 2002 for 

#2 and #4; 

June 2004 for 

#10 and #20; 

March 2009 

for #30; 1988 

for the 

others.2 

Activated Carbon 

Absorption Systems for 

Storage Tank Vents. 

Storage Tank for 

#2 Fuel Oil 

Tank #390 (30,000 gals) 1988 None 

2

 Al l of the tanks were originally constructed in 1988. Construction dates later than 1988 were in-kind 

replacements. 

VES017256 
Statement of Basis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 16 of 79 

Emission 

Unit Description 

Date of 

Construction 

Emission Control 

Equipment 

Bulk Solid Waste 

Storage Facility 

Temporary storage of bulk solid 

wastes in pits prior to being fed to 

incineration unit #4 

1988 Cyclone, Airtol Baghouse 

(BF Bldg-BH-1), Carbon 

Adsorption Unit (BF BldgC A) 

Gasoline Storage 

Tank 

550-gallon design capacity, 

equipped with submerged loading 

pipe 

June 20123 None 

Boiler 10.6 mmBtu/hr natural gas-fired 

boiler (Boiler #1) 

November 

1995 

None 

Emergency 

Generators (2) 

Two #2 fuel oil-fired emergency 

generators (each <112 kilowatts 

(kW)) 

1988 None 

Fugitive 

Ernissions 

Pumps, Valves, Open-End Lines 

and Compressors 

N / A None 

2.1.1. Process Description 

Veolia receives a variety of wastes in containers (drums, roll offs, etc.) and in 

bulk form. These wastes come into the facility predominantly in the form of 

solids and liquids. Liquid wastes anive in tank trucks and drums. Gaseous (and 

some liquid) wastes anive in various sized cylinders. Bulk solids primarily arrive 

in 20- to 40-yard roll-off containers or other similar bulk transport vehicles. Solid 

wastes are also received in containers such as drums, totes, and Gaylord boxes. 

Once received, wastes are stored prior to incineration in various buildings on the 

property (including an explosives magazine), depending on the characteristics o f 

the material, and either fed directly to an incinerator, repackaged into smaller 

charge containers for incineration, or sent off-site for treatment at other locations. 

Drummed liquids may be transferred via drum pumps to Tank Farm #1 or Tank 

Farm #3. 

Tank Farm #1, which services Incineration Units 2 and 3, is made up of 10 

vertical fixed roof storage tanks. Tank Farm #3, which services Incineration Unit 

4, is made up of 8 vertical fixed roof storage tanks. These storage tanks release 

fugitive emissions during filling and emptying of the tanks, as well as when the 

tanks are empty. Emissions from these storage tanks are controlled by an 

individual carbon adsorption unit on each tank. 

' This was an in-kind replacement to the tank originally constructed in 1992. 

VES017257 
Statement of Basis for DRAFT Title V Pemiit No. V-1L-1716300103-2014-10 

Permittee: Veolia BS Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 17 of 79 

Bulk solid wastes are stored in four pits in the bulk feed building (bulk solid 

waste storage facility). The building is enclosed and equipped with a cyclone, 

baghouse, and carbon adsorption unit. Veolia's Title V permit requires Veolia to 

operate the enclosed building under permanent negative pressure. A clam shell 

moves bulk solids from the bulk feed building through an enclosed gallery to 

Combustion Unit 4. 

Material processing occurs at units MP-1 and MP-2, and the lab pack repack 

areas. Material processing involves the repackaging of drummed solids into more 

manageable containers for subsequent incineration. Some of these solids may 

have free liquids, which are fixed with an inert absorbent material before 

repackaging. Lab packs are opened and repackaged into acceptable containers for 

charging to the incineration units. 

The incineration units produce ash, which enters the Ash Handling System. Ash 

from Units 2 and 3 is temporarily staged in roll-off containers at the Ash Storage 

Building. From there it is transported to the bulk solid waste storage facility. As h 

from Unit 4 is collected in roll-off containers and transported to Storage Building 

#7. Emissions of P M are minimized through work practices such as wet handling, 

covering with a tarp, and handling inside enclosed structures. 

Veolia also operates a drum crusher, at which drums that are unsuitable for reuse 

are crushed. Some empty drums may contain residual waste when crushed. 

These emissions are not controlled. 

Fugitive emissions occur facility-wide. The most significant source of fugitive 

emissions is equipment leaks from pipelines and pumps that handle liquid organic 

waste. The evaporation of organics from spills, leaks, and drum sampling also 

contribute to facility-wide fugitive emissions. 

Finally, Veolia operates small combustion sources consisting of a natural gasfired boiler (10.6 mmBtu/hr natural gas boiler) used to generate heat and steam 

for on-site uses, two emergency generators (each rated at less than 112 kW) and a 

portable Tioga heater (rated at 2.5 mmBtu/hr). There are no emission control 

devices associated with these units. 

2.1.2. Incineration Units 

As shown in Table 2, above, Veolia has three incineration units: Units 2, 3, and 4. 

Incineration Unit 1 was decommissioned and closed in 1992. Incineration Units 2 

and 3 are custom fixed-hearth, dual-chamber units each rated at 16 mmBtu/hr. 4 

4

 Units 2 and 3 are similar in design and function. The key differences between these units are the slight differences 

in feed types and baghouse configurations. As shown in Table 1, Unit 2 also burns gases while Unit 3 does not. 

Also, Unit 2 has four baghouse modules while Unit 3 has three baghouse modules. 
Statement of Basis for DRAFT Title V Permit No. V-1L-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 18 of 79 

Incineration Unit 4 is a rotary kiln (transportable system converted to a stationary 

unit) rated at 50 mmBtu/hr. Each unit includes its own feed, air pollution control, 

process instrumentation and controls, and continuous emission monitoring 

systems. Each incineration unit has a primary combustion chamber (PCC) and a 

secondary combustion chamber (SCC). The PCCs and SCCs have natural gasfired auxiliary burners, which are used during startup, shutdown, malfunctions 

and additional heat input. Table 3 shows a summary of the key design 

specifications for each of the three incineration units. 

Table 3. Design Specifications for Veolia's Incineration Units. 

Design Paramete Parameter Specification 

Unit 2 Unit 3 Unit 4 

Incinerator Type Fixed Hearth, Dual 

(Primary and 

Secondary) Chamber 

Fixed Hearth, Dual 

(Primary and 

Secondary) 

Chamber 

Transportable Rotary 

Kiln (includes kiln and 

a secondary chamber) 

Model TW1-2000, Scries 2 TW1-2000, Series 2 PY*RO X 

Manufacturer Trade Waste 

Incineration 

Trade Waste 

Incineration 

International Waste 

Energy Systems 

Feed Type Solids, Organic 

Liquids, Aqueous 

Liquids, Sludges, 

Gases (Unit 2 only) 

Solids, Organic 

Liquids, Aqueous 

Liquids, Sludges 

Solids, Organic 

Liquids, Aqueous 

Liquids, Sludges 

Maximum Feed 

Rate For Each 

Combustion 

Chamber 

Limited by permit 

(see Table 9) 

Limited by permit 

(see Table 9) 

Limited by permit (see 

Table 9) 

Heat Release 

Rating 

16 mmBtu/hr 16 mmBtu/hr 50 mmBtu/hr 

Burner Fuel Type Natural Gas Natural Gas Natural Gas 

Emission Control 

Device 

Spray dryer absorber 

and fabric filter 

(baghouse) 

Spray dryer 

absorber and fabric 

filter (baghouse) 

Tempering chamber, 

spray dryer absorber, 

carbon injection and 

lime recirculation 

system, and fabric 

filter (baghouse) 

Units 2 and 3 are designed to receive and incinerate containerized wastes, 

aqueous, organic and specialty liquid wastes, and sludge wastes. The aqueous 

and organic liquid wastes are fed through air-atomizing nozzles. The specialty 

liquid feeds and direct-inject liquids are fed through the aqueous or organic liquid 

VES017259 
Statement of Basis For DRAFT Title V Pennit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Dale Issued: October 10, 2014 Page 19 of 79 

feed systems. Each unit can receive any combination of liquid, semi-solid, or 

solid wastes. Unit 2 can also receive waste gases through separate feed nozzles. 

Unit 4 can incinerate container, aqueous, organic and specialty liquid, and sludge 

wastes. Liquid wastes are fed into either the kiln or SCC. Bulk solid wastes are 

fed into the kiln through either the ram feeder or the screw auger. Containerized 

wastes are fed into the kiln through the ram feeder or the auxiliary ram feeder. 

Unit 4 can also accept liquid wastes injected directly from the delivery vehicle. 

The three incineration units are supported by lime handling systems and ash 

handling systems. The lime handling systems are made up of lime storage silos 

and slurry mix tanks. There is one system for Units 2 and 3 and one for Unit 4. 

The silos are controlled by bin vents. Ash handling consists of material collection 

from the combustion chambers, the spray dryer and baghouse. The combustion 

chamber ash is collected in roll-off boxes. Veolia tarps the roll-off boxes to 

minimize P M emissions. Veolia continuously monitors each incineration unit for 

carbon monoxide (CO) and hydrogen chloride/chlorine (HCI/Cb) emissions via a 

continuous emissions monitoring system. 

2.2. Insignificant Emission Units and Activities 

Table 4, below, provides a listing of emission units and activities located at Veolia that 

E PA has determined to be insignificant pursuant to 40 C.F.R. § 71.5(c)(l 1). Unless 

otherwise specified in the permit, the Permittee must comply with all applicable 

requirements including any air quality control requirements that apply to insignificant 

emission units and activities. Pursuant to 40 C.F.R. § 71.9(c)(5)(iii), emissions from 

insignificant emission units and activities that are not required to be listed or calculated in 

a permit application pursuant to 40 C.F.R. § 71.5(c)(l 1) are excluded from the 

calculation of fees under 40 C.F.R. § 71.9 (c)(1) through (4). 

Table 4. List of Insignificant Emission Units and Activities. 

Unit Description Basis for Classification as an Insignificant 

Emission Unit or Activity 

Regulatory Reference 

2.5 mmBtu/hr 

Tioga portable 

boiler 

Direct combustion unit designed and used for 

comfort heating purposes, as defined at 35 IAC 

201.210(a)(4). 

35 IAC 201.210(a)(4); 

40 C.F.R. § 

71.5(c)(ll)(i)(D) 

Horizontal 550-

gallon kerosene 

tank 

Storage tanks of virgin or rerefined distillate 

oil, hydrocarbon condensate from natural gas 

pipeline or storage systems, lubricating oil, or 

residual fuel oils. 

35 IAC 201.210(a)(ll) 

VES017260 
Statement of Basis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Pennittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 20 of 79 

Unit Description Basis for Classification as an Insignificant 

Emission Unit or Activity 

Regulatory Reference 

Two horizontal 

550-gallon No. 2 

fuel oil tanks 

Storage tanks of virgin or rerefined distillate 

oil, hydrocarbon condensate from natural gas 

pipeline or storage systems, lubricating oil, or 

residual fuel oils. 

35 IAC201.210(a)(ll) 

Ash handling • The emission unit does not emit more than 

1.0 lb/hr of any regulated air pollutant not 

listed as a HA P pursuant to Section 112(b) 

of the CA A in the absence of air pollution 

control equipment; 

• The emission unit does not emit more than 

0.1 lb/hr of any regulated air pollutant that 

is listed as a HA P pursuant to Section 

112(b) of the CA A in the absence of air 

pollution control equipment; and 

• The emission unit is not a process unit. 

35 IAC 201.211(a) 

Handling of spent 

dry scrubber solids 

• The emission unit does not emit more than 

1.0 lb/hr of any regulated air pollutant not 

listed as a HA P pursuant to Section 112(b) 

of the CA A in the absence of air pollution 

control equipment; 

• The emission unit does not emit more than 

0.1 lb/hr of any regulated air pollutant that 

is listed as a HA P pursuant to Section 

112(b) of the CA A in the absence of air 

pollution control equipment; and 

• The emission unit is not a process unit. 

35 IAC 201.211(a) 

Lime unloading 

(silo) and 

proportioning 

• The emission unit does not emit more than 

1.0 lb/hr of any regulated air pollutant not 

listed as a MAP pursuant to Section 112(b) 

of the CA A in the absence of air pollution 

control equipment; 

• The emission unit does not emit more than 

0.1 lb/hr of any regulated air pollutant that 

is listed as a HA P pursuant to Section 

112(b) of the CA A in the absence of air 

pollution control equipment; and 

35 IAC 201.211(a) 

VES017261 
Stalcmcnt of Basis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia FS Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 21 of 79 

Unit Description Basis for Classification as an Insignificant 

Emission Unit or Activity 

Regulatory Reference 

• The emission unit is not a process unit. 

Gasoline storage 

and dispensing 

• The emission unit does not emit more than 

1.0 lb/hr of any regulated air pollutant not 

listed as a HA P pursuant to Section 112(b) 

of the CA A in the absence of air pollution 

control equipment; 

• The emission unit does not emit more than 

0.1 lb/hr of any regulated air pollutant that 

is listed as a HA P pursuant to Section 

112(b) of the CA A in the absence of air 

pollution control equipment; and 

• The emission unit is not a process unit. 

35 IAC 201.211(a) 

Use of absorbent 

material (fugitive 

P M generation) 

• The emission unit does not emit more than 

1.0 lb/hr of any regulated air pollutant not 

listed as a HA P pursuant to Section 112(b) 

of the CA A in the absence of air pollution 

control equipment; 

• The emission unit does not emit more than 

0.1 lb/hr of any regulated air pollutant that 

is listed as a HA P pursuant to Section 

112(b) of the CA A in the absence of air 

pollution control equipment; and 

• The emission unit is not a process unit. 

35 IAC 201.211(a) 

General vehicle 

maintenance and 

servicing (assumed 

to include diesel 

fuel handling) 

General vehicle maintenance and servicing 

activities at the source, other than gasoline fuel 

handling, are insignificant pursuant to 35 IAC 

201.210(b)(4). 

35 IAC 201.210(b)(4) 

Laboratory 

(chemical and 

physical analysis) 

Bench scale laboratory equipment and 

laboratory equipment used exclusively for 

chemical and physical analysis, including 

associated laboratory fume hoods, vacuum 

producing devices and control devices installed 

primarily to address potential accidental 

releases, are insignificant pursuant to 35 IAC 

201.210(b)(ll). 

35 IAC201.210(b)(Il) 

VES017262 
Statement of Basis for DRAFT Tille V Pennit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 22 of 79 

Unit Description Basis for Classification as an Insignificant 

Emission Unit or Activity 

Regulatory Reference 

Piping and storage 

system for natural 

gas 

Piping and storage systems for natural gas, 

propane, and liquefied petroleum gas are 

insignificant pursuant to 35 IAC 

201.210(b)(15). 

35 IAC 201.210(b)(15) 

Non-halogenated 

cold cleaning 

degreasers 

Cold cleaning degreasers that are not in-line 

cleaning machines, where the vapor pressure 

of the solvents used never exceed 2 kPa (15 

mmHg or 0.3 psi) measured at 38 °C (100 °F) 

or 0.7 kPa (5 mmHg or 0.1 psi) at 20 °C (68 

°F) are insignificant pursuant to 35 IAC 

201.210(b)(19). 

35 IAC 201.210(b)(19) 

Internal combustion 

engines of motor 

vehicles (primarily 

forklifts) 

Internal combustion engines (including the fuel 

system) of motor vehicles, locomotives, 

aircraft, watercraft, lift trucks, and other 

vehicles powered by nonroad engines are 

insignificant pursuant to 35 IAC 

201.210(b)(24). 

35 IAC 201.210(b)(24) 

Storage and 

handling of closed 

drums 

Storage and handling of drums or other 

transportable containers where the containers 

are sealed during storage and handling is 

insignificant pursuant to 35 IAC 

201.210(b)(26). 

35 IAC 201.210(b)(26) 

2.3. Emissions 

Veolia emits a variety of pollutants including CO, nitrogen oxides (NOx), sulfur dioxide 

(SO2), PM, particulate matter with aerodynamic diameter less than 10 micrometers 

(PMio), PM2.5, semivolatile metals (SVM) (i.e., lead and cadmium), low-volatile metals 

(LVM ) (i.e., arsenic, beryllium and chromium), volatile organic compounds (VOC or 

VOM), greenhouse gases (GHGs) 5 and other HAPs. 

Veolia is a major source of HAPs with potential and actual emissions as shown in Table 

5, below. The source's actual and potential GH G emissions are provided for 

informational purposes. The facility's potential to emit (PTE) is less than major source 

thresholds for the other pollutants.6 

5

 GHG s refers to the aggregate group o f six greenhouse gases: carbon dioxide, nitrous oxide, methane, 

hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride. 40 C.F.R. § 71.2. 

* As it pertains to HA P emissions, "major source" means any stationary source or group of stationary sources 

located within a contiguous area and under common control that emits or has the potential to emit considering 

controls, in the aggregate, 10 tpy or more of any HA P or 25 tpy or more of any combination of HAPs. 40 C.F.R. 

§ 63.2. The major source threshold for regulated criteria pollutants in the Sauget area is 100 tpy. 40 C.F.R. § 71.2. 

VES017263 
Statement of Basis For DRAFT Title V Pennit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 23 of 79 

Table 5. Potential to Emit and Actual Emissions Reported by Veolia (Tons Per Year). 

Pollutant ! PTE 

Actual Emissions 

Pollutant ! PTE 

2012 2011 ! 2010 2009 2008 

P M 12.62 1.07 1.12 1.10 1.07 1.04 

PMio 12.62 1.07 1.12 1.10 1.07 1.04 

PM2.5 12.62 1.07 1.12 1.10 1.07 1.04 

S 0 2 66.25 0.53 0.49 0.49 0.52 0.50 

NOx 74.99 56.56 58.16 57.1 55.23 54.76 

V O M (VOC) 15.70 1.93 1.51 1.62 1.74 1.70 

CO 31.04 1.16 1.21 1.41 1.67 1.95 

GHGs (as carbon 

dioxide equivalents 

(C02 e))* 

147,053 112,378 

HAPs (Total) 21.41 

Arsenic (As) 0.0388 2.51 x 10"5 

Beryllium (Be) 0.0388 1.76 x 10"7 

Cadmium (Cd) 0.0968 3.11 x 10"5 

Chromium (Cr) 0.0388 5.46 x 10"5 

Dioxins and 

Furans 

9.97E-08 6.35 x IO"8 

Hydrogen 

Chloride (HCI) 

19.75 1.98 1.89 2.03 2.09 3.56 

Lead 0.0968 0.00018 

Mercury (Hg) 0.0342 0.0017 

G H G emissions were calculated using global warming potentials for CO2 , methane and nitrous 

oxide as published in 78 Fed. Reg. 71948 (November 29, 2013). 

This threshold applies to VO M and NOx because this area is designated as a "moderate" nonattainment area for the 

8-hour ozone, and its P M nonattainment designation is not classified as "serious." Although EP A is including GH G 

emissions here for informational purposes, it notes that after the June 23, 2014 U.S. Supreme Court decision in 

Utility Air Regulatory Group v. EPA (No. 12-1146) EP A may not treat GHG s as an air pollutant for purposes of 

determining whether a source is a major source required to obtain a Prevention o f Significant Deterioration (PSD) or 

Title V permit. The major source threshold is 250 tpy for all other regulated pollutants. 

VES017264 
Statement of Basis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10,2014 Page 24 of 79 

3.0. AIR PERMITTING AND ENFORCEMENT HISTORY 

3.1. Permitting History 

Veolia operates under a number of construction permits issued by the Illinois 

Environmental Protection Agency (IEPA). Veolia also operates under a CA A Title V 

permit No. V-IL-1716300103-08-01 that EPA issued on September 12, 2008 pursuant to 

40 C.F.R. Part 71, and that became effective on October 12, 2008. As discussed in more 

detail below, EPA took over as the CA A Title V permitting authority for Veolia's Sauget 

facility, as provided by 40 C.F.R. § 70.8, when IEPA did not timely issue a permit to 

address EPA's February 1, 2006 Order objecting to IEPA's proposed Title V permit for 

this facility. Although EPA is the CA A Title V permitting authority for Veolia's facility, 

IEPA retains the authority to issue construction permits for projects proposed by Veolia. 

3.1.1. Construction Permits 

Table 6 lists all of the construction permits issued by IEPA to Veolia. EPA has 

incorporated applicable requirements from all of Veolia's active construction 

permits into the Title V permit. 

Table 6. Summary of State Construction Permits Issued by IEPA to Veolia. 

Date Issued Permit # Project Description Permit Active? 

83080072 Construction of Unit 1. Unit 1 was 

decommissioned and removed from 

service in 1992. 

No 

8/8/1984 84060063 Shredder System No 

9/2/1986 83120053 Units 2 and 3 and Tank Farm #1 

Construction 

Yes 

2/11/1988 87110052 Pneumatic Conveyor No 

4/13/1988 87120069 Residue Feed System for Unit 1 No 

6/27/1988 88030101 Tank Farm #3 Construction Yes 

8/3/1988 88010001 Unit 4 Construction Yes 

8/19/1988 87100024 Unit 3 Construction Yes 

6/7/1993 93030107 Specialty Feeder for Unit 3 No 

11/7/1995 95080025 Cleaver Brooks Boiler #1 Yes 

2/6/2001 00110030 Activated Carbon Injection System 

and Baghouse Solids Recirculation 

System for Unit 4. 7 

Yes 

7

 Construction Permit #00110030 did not establish additional air quality control requirements beyond those already 

established by 40 C.F.R. Part 63, Subpart EEE . 

VES017265 
Statement of Basis for DRAFT Title V Pennit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 25 of 79 

3.1.2. Title V Permitting History 

A. Regulatory and Factual Background 

A l l major stationary sources of air pollution and certain other sources are required 

to apply for Title V operating permits that include emission limitations and other 

conditions necessary to assure compliance with applicable requirements ofthe 

Act, including the requirements of the applicable State Implementation Plan 

(SIP). See CA A sections 502(a) and 504(a), 42 U.S.C. §§ 7661a(a) and 7661c(a). 

On September 7, 1995, Veolia submitted to IEPA its first application for a Title V 

permit for Veolia's Sauget, Illinois facility. Following a public comment period 

that ended on November 6, 2003, IEPA provided a proposed permit to EPA for 

review. EPA did not object to the proposed permit within its statutory 45-day 

review period, which ended on December 21, 2003. On February 18, 2004, EP A 

received a petition submitted by the Siena Club and American Bottom 

Conservation (ABC) pursuant to Section 505(b)(2) ofthe CA A and 40 C.F.R. 

§ 70.8(d), requesting that EP A object to issuance of Veolia's Title V permit. On 

February 1, 2005, EPA issued an Order granting the petition in part and denying it 

in part. Pursuant to 40 C.F.R. § 70.8(c), EPA's action on the petition initiated a 

90-day period during which IEPA was required to issue a revised Title V permit 

that addressed the issues raised in the EPA Order. IEPA did not issue the permit 

within the 90-day period. The Siena Club and AB C filed a complaint with the 

U.S. District Court for the Northern District of Illinois, alleging that EPA failed to 

perform a nondiscretionary duty under CA A section 505(c), 42 U.S.C. 

§ 7661d(c), to issue by Ma y 2, 2006, a Title V operating permit for Veolia under 

40 C.F.R. Part 71. Sierra Club v. Johnson, Case No. 06-CV-4000 (N.D. 111.). 

On September 29, 2006, EP A announced its intent to issue or deny a federal 

Title V permit for Veolia. Subsequently, Veolia submitted a Title V permit 

application to EPA on Ma y 2, 2007. On June 4, 2008, EPA signed a settlement 

agreement with the plaintiffs requiring the Agency to take action on Veolia's 

application by September 12, 2008. 

B. The Initial Permit 

Following a public comment period that closed on July 18, 2008, EPA issued a 

final Title V permit to Veolia on September 12, 2008. 8 

Prior to issuing the 2008 permit, EP A reviewed historical metal feedrate data 

supplied by Veolia to support Veolia's proposed operating parameter limits 

(OPLs or feedrate limits) for HAPs required by the HW C MACT . EPA 

s

 The final permit and support documents are available at www.remilations.aov: Docket ID: EPA-R05-OAR-2008 -

0235. Also, see Document ID. EPA-HQ-OGC-2008-0310. 

VES017266 
Statement 0 r Basis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 26 of 79 

concluded that reliance on the OPLs submitted by Veolia would not assure 

Veolia's compliance with the applicable requirements in tlie HW C MACT. 9 

Specifically, EPA determined that the past data were not reliable for determining 

feedrate OPLs for mercury, SV M and LVM . On February 22, 2008, EP A issued a 

Request for Information under Section 114 of the Act, 42 U.S.C. § 7414, 

requiring Veolia to complete comprehensive performance tests (CPTs) on all of 

its three incineration units. The required testing was limited to mercury, SV M 

and LVM. 1 0 Veolia conducted the CPTs in August and September 2008. 

Since reliable test results for mercury, SV M and LV M were not available at the 

time that EPA made the initial permit available for public comment, EP A 

provided the opportunity forthe public to comment on the compliance schedule, 

Veolia's comprehensive performance test (CPT) plan, and the OPL calculation 

methodologies. In the September 12, 2008 final permit, EPA required Veolia to 

submit, by October 10, 2008, the results of its testing and a request for a 

significant modification to its Title V permit to incorporate OPLs. 

C. The 2013 Proposed Significant Modification/Reopening 

As required by the 2008 permit, on October 10, 2008, Veolia submitted to EPA 

the results of the August and September 2008 tests, and requested a significant 

modification to its Title V permit to incorporate OPLs for mercury, SV M and 

LVM , as specified in the compliance schedule in the 2008 Title V permit. EPA 

reviewed Veolia's application and submitted multiple requests for additional 

information from Veolia. In response to EPA's requests for information, Veolia 

amended its significant modification application multiple times, including 

application updates submitted to EPA on January 7, 2009," March 27, 2009,' 2 

March 2, 2010, 1 3 and March 12, 2012. 1 4 

On November 29, 2012, EP A notified Veolia that it intended to deny its 

significant modification application and to reopen the permit to add feedrate 

OPLs that EPA considered to be supported by the available CPT data. However, 

Veolia withdrew the significant modification application on December 13, 2012. 

'Se e Statement of Basis for Permit No. V-IL-1716300103-08-01 at 8, September 12, 2008 (citing Apri l 16, 2008 

memorandum from Charles Hall to the permit file, "Operating Parameter Limits for Veolia ES Technical Solutions, 

LLC , Sauget, IL."). Available at www.regulations.gov: Docket ID: EPA-R05-OAR-2008-0235. 

1 0

 Veolia explained that it could not meet the deadlines in the February 22, 2008 Request for Information because 

stack testing crews and materials were not available. Therefore, EP A extended the testing schedule and limited the 

testing to mercury, SV M and LVM . For all other required OPLs, EP A incorporated into the draft Title V permit 

parameters that EP A calculated based upon data submitted by Veolia. See Statement of Basis for Permit No. V-IL -

1716300103-08-01, September 12, 2008. 

11 See Document ID. EPA-R05-OAR-2012-0649-0007. 

12 See Document ID. EPA-R05-OAR-2012-0649-0104. 

" See Document ID. EPA-R05-OAR-2012-0649-0005 

See Document ID. EPA-R05-OAR-2012-0649-0069 

VES017267 
Statement of Basis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 27 of 79 

On January 8, 2013, EPA proposed to reopen Veolia's Title V Permit No. V-IL1716300103-08-01 for cause, pursuant to 40 C.F.R. § 71.7(f)(l)(iv), to 

incorporate OPLs and additional monitoring requirements into the permit. EPA's 

primary purpose for proposing to reopen the permit was to ensure that the permit 

complied with the CAA's mandate that the permit include "all operational 

requirements and limitations that assure compliance with all applicable 

requirements" and monitoring sufficient to assure compliance with the 

requirements of the Act. See 40 C.F.R. § 71.6(a) and (c). EPA's action was 

based on EPA's analysis o f the 2008 CPT data and recognition that, given the 

variability of Veolia's feedstream, minimal monitoring is not sufficient to assure 

compliance with the HW C MAC T emissions limits. 

E PA received a significant number of substantive written and oral comments 

during the public comment period for the reopening, which closed on 

April 1, 2013. Due to the complexity ofthe comments received, EPA did not 

finalize the proposed modifications prior to expiration of the 2008 permit. At the 

same time, Veolia informed EPA that it was planning to conduct another round o f 

CPTs in October 2013. Because of that fact and because Veolia's 2008 permit 

was due for renewal, EPA decided that, rather than finalizing the proposed 

reopening, it would be most effective to include the OPLs and additional 

monitoring requirements in the renewal permit that is the subject of this 

permitting action. Inclusion ofthe additional monitoring discussed below will 

satisfy the CA A mandate that the permit contain sufficient monitoring to assure 

compliance with all requirements of the Act. 

3.2. Enforcement History and Permit Shield 

3.2.1. Allegations of Violation 

On September 27, 2006, EP A issued a Finding of Violation and Notice of 

Violation (FOV/NOV) to Veolia notifying the company that EPA found it to be in 

violation of the Act and the following regulations: 40 C.F.R. Part 61, Subpart V , 

the National Emission Standard for Emission Leaks; 40 C.F.R. Part 63, Subpart 

D D, the National Emission Standard for Hazardous Air Pollutants from Off-Site 

Waste and Recovery Operations; and 40 C.F.R. Part 61, Subpart FF, the National 

Emission Standard for Benzene Waste Operations. 

Subsequent to the issuance of the FOV/NO V and based on further investigation, 

on June 12, 2008, EPA issued an FO V to Veolia alleging that Veolia was also in 

noncompliance with 40 C.F.R. Part 63, Subpart EEE, the HWC MACT , for 

failure to timely perform compliance testing as required by 40 C.F.R. 

§ 63.1207(c); failure to appropriately request the use of an extrapolation 

VES017268 
Statement or Basis lor DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Dale Issued: October 10, 2014 Page 28 of 79 

methodology as required by 40 C.F.R. § 63.1207(f)( 1 )(x); exceeding the 

applicable HWC MAC T mercury limit on Units 2, 3, and 4, as set forth in 

40C.F.R. § 63.1206(b)(1); and exceeding the HWC MAC T arsenic emission 

standard as set forth in 40 C.F.R. § 63.1203(a)(4). 

On August 24, 2012, after further investigation into Veolia's compliance with the 

H WC MACT , EPA issued another FO V to Veolia notifying Veolia that EPA 

found it to be in violation of Section 112 ofthe Act, 42 U.S.C. § 7412, and its 

implementing regulations for the HWC MACT , and Section 114 ofthe Act, 

42 U.S.C. § 7414. 1 5 

3.2.2. Permit Shield 

EPA's regulations at 40 C.F.R. Part 71 allow permitting authorities the discretion 

to include a provision in the permit stating that compliance with the conditions o f 

the permit shall be deemed compliance with any applicable requirements as of the 

date of permit issuance, provided that certain specific conditions set out in 

40 C.F.R. § 71.6(f) are met. This provision is commonly referred to as a "permit 

shield." See 40 C.F.R. § 71.6(1). EPA has determined that it is appropriate at this 

time to grant a permit shield for the requirements applicable to the Sauget facility 

as a result of applicability of the following regulations: 40 C.F.R. Part 61, Subpart 

V, the National Emission Standard for Emission Leaks; 40 C.F.R. Part 63, 

Subpart DD, the National Emission Standard for Hazardous Air Pollutants from 

Off-Site Waste and Recovery Operations; and 40 C.F.R. Part 61, Subpart FF, the 

National Emission Standard for Benzene Waste Operations. EPA has made this 

detennination because EPA is no longer pursuing the violations of these 

provisions alleged in the September 27, 2006 FOV/NOV . 

However, because the allegations in the June 12, 2008 and August 24, 2012 FOVs 

have not yet been resolved, and may result in incorporation into the permit of a 

compliance schedule, if necessary to bring this facility into compliance, EPA has 

determined that it is not appropriate at this time to grant a permit shield for the 

applicable requirements of the HWC MAC T standard, including those portions o f 

the general provisions of 40 C.F.R. Part 63 applicable to the source as a result of 

the applicability of 40 C.F.R. Part 63, Subpart EEE. EPA will reconsider whether 

a permit shield for these provisions is appropriate following resolution of the 

allegations in the FOVs. 

b

 On February 26, 2007, IEP A referred Veolia to the Illinois Attorney General for alleged violations of the Illinois 

Environmental Protection Act, Illinois Pollution Control Board Regulations, and the HW C MACT . On March 5, 

2010, after receiving additional information, IEP A referred to the Illinois Attorney General additional alleged 

violations ol'lhe Illinois Environmental Protection Act, Illinois Pollution Control Board Regulations, and the HW C 

MACT . 

VES017269 
Statement of Basis for DRAFT Title V Pennit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 29 of 79 

In addition, EPA notes that 40 C.F.R. § 71.6(f)(3) expressly provides that nothing 

in any Part 71 permit shall alter or affect the following: 

(i) The provisions of Section 303 of the Act (emergency orders), including the 

authority ofthe Administrator under that section; 

(ii) The liability of an owner or operator of a source for any violation of 

applicable requirements prior to or at the time of permit issuance; 

(iii) The applicable requirements of the acid rain program, consistent with 

Section 408(a) ofthe Act; or 

(iv) The ability of EPA to obtain information from a source pursuant to Section 

114 ofthe Act. 

EPA may reopen the permit to add or modify permit terms and conditions if EP A 

determines that additional measures are necessary to assure compliance. See 

Conditions 4.10 through 4.14 of the permit. 

3.2.3. Compliance Schedule 

E PA has determined that a compliance schedule is not required at this time to 

address the pending FOVs. An FO V is simply one early step in EPA's 

enforcement process. This step is commonly followed by additional investigation 

or discovery, information gathering, and an exchange of views, all of which occur 

in the context of an enforcement proceeding, and are important means of factfinding under our system of civil litigation. A n FOV is not a final agency action 

and is not subject to judicial review. No binding legal consequences flow from an 

FOV, and an FO V does not have the force or effect of law. See PacifiCorp v. 

Thomas, 883 F.2d 661 (9th Cir. 1988); Absetec Conslr. Servs. v. EPA, 849 F.2d 

765,768-69 (2nd Cir. 1988); Union Elec. Co. v. EPA, 593 F.2d 299, 304-06 (8th 

Cir. 1979); and West Penn Power Co. v. Train, 522 F.2d 302, 310-11 (3rd Cir. 

1975). See also, Sierra Club v. Johnson, 541 F.3d 1257, 1267 (1 l l h Cir. 2008); 

Sierra Club v. EPA, 557 F.3d 401, 406-409 (6l h Cir. 2009). However, EPA will 

reopen the pennit following resolution of EPA's allegations, if necessary, to 

incorporate a compliance schedule or any applicable requirements. 

VES017270 
Statement of Basis for DRAFT Title V Pennit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 30 of 79 

4.0. PERMIT TERMS AND CONDITIONS 

4.1. Overview of Permit Terms 

Title V permits generally do not impose new substantive air quality control requirements, 

referred to as "applicable requirements."16 See 57 Fed. Reg. 32250, 32251. A Title V 

permit must include all emissions limitations and standards, including those operational 

requirements and limitations that assure compliance with all applicable requirements at 

the time of permit issuance. 40 C.F.R § 71.6(a)(l). Additionally, the pennit must 

contain periodic monitoring that is sufficient to yield reliable data from the relevant time 

period that are representative ofthe source's compliance with the permit, and that is 

sufficient to assure compliance with the terms and conditions of the permit. 40 C.F.R. 

§ 71.6(a)(3)(B), (c)(1). 

One purpose of the Title V permit is to enable the source, states, EPA , and the public to 

better understand the requirements to which the source is subject, and whether the source 

is meeting those requirements. 57 Fed. Reg. 32251. Thus, the Title V permit is a vehicle 

for ensuring that air quality control requirements are appropriately applied to facility 

emission units and for assuring compliance with such requirements. The Title V permit 

is an enforceable compilation of enforceable terms, conditions and limitations. 

Veolia's permit includes enforceable terms and conditions from the following sources: 

• National Emission Standards for HAPs (NESHAPs) - Standards promulgated under 

the authority of Section 112 ofthe CA A and promulgated under 40 C.F.R. Parts 61 

and 63. The specific applicable subparts are listed in Table 7; 

• New Source Performance Standards (NSPS) - Standards promulgated under the 

authority of Section 111 of the CA A and promulgated under 40 C.F.R. Part 60. The 

specific applicable subparts are listed in Table 7; 

• The Illinois SIP - EPA-approved regulations codified in Title 35 ofthe Illinois 

Administrative Code (35 IAC) and 40 C.F.R. § 52.720; and 

• Constmction and operating permits issued by IEPA. 

1 6

 The term "applicable requirement" is defined in 40 C.F.R § 71.2. 
Statement of Basis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 31 of 79 

4.2. Applicable Requirements 

Table 7 provides a summary of the applicable requirements mcluded in Veolia's permit. 

Note that this summary is provided as an overview ofthe requirements that apply to 

Veolia's emission units and it does not include specifics on all ofthe applicable 

requirements nor does it include all of the monitoring, reporting and recordkeeping 

requirements to which Veolia is subject. The permit itself includes such information. 

Table 7. Summary of Applicable Requirements. 

Emission 

Unit 

Summary of 

Applicable 

Requirement and 

Permit Condition 

Regulatory 

Citation 

Summary of Monitoring, 

Reporting and 

Recordkeeping 

Requirements 

Incineration Units 

2, 3 and 4 

Visible emission 

limitations: maximum 

30 percent opacity and 

no visible emissions 

beyond the property 

boundary. [Condition 

2.1(A)(1)] 

35 IAC 212.123(a), 

212.301 and 212.314 

Continuous opacity 

monitors (COMs) and 

recording devices. Best 

management practices. 

Incineration Units 

2, 3 and 4 

SO2 emission limit: 

7.7 tpy for Units 2 and 

3; 50.76 tpy for Unit 4. 

[Condition 2.1(A)(2)1 

Construction Permits 

87100024 and 

88010001 

Calculate emissions from 

test results, monitoring data, 

engineering calculations and 

standard emission factors. 

Incineration Units 

2, 3 and 4 

CO emission 

limitations: 100 parts 

per million by volume 

(ppmv) corrected to 7 

percent oxygen; 500 

ppm corrected to 50 

percent excess air; 6.6 

tpy for Units 2 and 3; 

and 13.86 tpy for Unit 

4. [Condition 

2.1 (A)(3)] 

40 C.F.R. § 

63.1219(a)(5); 35 

I AC 216.141; 

Construction Permits 

83120053,87100024 

and 88010001. 

CO continuous emissions 

monitoring systems (CEMS) 

and recording devices. 

Incineration Units 

2, 3 and 4 

P M limits: 0.08 grain 

per standard cubic foot 

(gr/scf)) of effluent 

gases corrected to 12 

percent C0 2; 0.013 

gr/dscf, corrected to 

7 percent oxygen; 15.0 

35 IAC 212.181(b), 

Construction Permit 

83120053; 40 C.F.R. 

§ 63.1219(a)(7); 

Construction Permits 

87100024 and 

88010001 

Bag leak detection systems 

for baghouses. CPTs at the 

frequency required by the 

HWC MACT . Establish 

and comply with the 

applicable OPLs. 

VES017272 
Statement of Basis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia RS Technical Solutions, L.L.C , Sauget, Illinois 

Dale Issued: October 10, 2014 Page 32 of 79 

Emission 

Unit 

Summary of 

Applicable 

Requirement and 

Permit Condition 

Regulatory 

Citation 

Summary of Monitoring, 

Reporting and 

Recordkeeping 

Requirements 

tpy for Units 2 and 3 

and 16.92 tpy for 

Unit 4. [Condition 

2.1(A)(4)] 

Comply with the reporting 

and recordkeeping 

requirements of the HW C 

MACT . Calculate 

emissions from test results, 

monitoring data, 

engineering calculations and 

standard emission factors. 

V OC emission limits: 

8 lb/hr; 0.9 tpy for 

Units 2 and 3 and 3.1 

tpy for Unit 4. 

[Condition 2.1(A)(5)] 

35 IAC 219.301, 

219.302; 

Construction Permits 

87100024 and 

88010001 

Compliance with the HW C 

MACT's DRE standard o f 

99.99% destruction provides 

for compliance with these 

requirements. Calculate 

emissions from test results, 

monitoring data, 

engineering calculations and 

standard emission factors. 

NOx emission limits: 

4.0 tpy for Units 2 and 

3 and 61.6 tons per 

year for Unit 4. 

[Condition 2.1(A)(6)] 

Construction Permits 

87100024 and 

88010001 

Calculate emissions from 

test results, monitoring data, 

engineering calculations and 

standard emission factors. 

HAP emission limits 

(corrected to 7 percent 

oxygen): dioxins and 

furans: 0.20 ng 

TEQ/dscm; mercury: 

130 pg/dscm; 

cadmium and lead 

(combined): 230 

pg/dscm; arsenic, 

beryllium and 

chromium (combined) 

92 ug/dscm; HCI: 32 

ppmv, 4.0 lb/hr from 

Units 2 and 3 or a 

minimum HCI 

removal efficiency of 

99 percent. 

[Conditions 

40 C.F.R. 

§ 63.1219(a); 

Construction Permits 

83120053 and 

87100024 

CPTs at the frequency 

required by the HWC 

MACT . Establish and 

comply with applicable 

OPLs established in the 

permit through the use of 

continuous monitoring 

systems (CMSs), feedstream 

analysis as prescribed in a 

feedstream analysis plan 

and the permit, and 

operation of a multi-metals 

CEM S as a parametric 

monitor at each unit for at 

least one year. Comply with 

the reporting and 

recordkeeping requirements 

1 of the HW C MACT . 

VES017273 
Statement ol" Basis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia FS Technical Solutions, L.L.C , Sauget, Illinois 

DaleLssued: October 10, 2014 Page 33 of 79 

Emission 

Unit 

Summary of 

Applicable 

Requirement and 

Permit Condition 

Regulatory 

Citation 

Summary of Monitoring, 

Reporting and 

Recordkeeping 

Requirements 

2.1(A)(7)(a)-(d) and 

(A)(8)] 

Destruction and 

Removal Efficiency 

(DRE) standard. 

[Condition 2.1(A)(9)] 

40 C.F.R. §§ 

63.1219(c)(1) 

and 63.1219(d); 

40 C.F.R. 

§ 63.1219(c)(2); 40 

C.F.R. § 

63.1219(c)(3)] 

CPTs at the frequency 

required by the HW C 

MACT . Establish and 

comply with applicable 

OPLs. Comply with the 

reporting and recordkeeping 

requirements of the HWC 

MACT . 

Work practice, design 

and operating 

requirements. 

[Conditions 

2.1(A)(7)(e) and (0; 

2.1(C)] 

40 C.F.R. 

§§ 61.348(a)(l)(iii); 

63.689(c)(2); 

63.1209; 63.1206; 

63.6(e)(3) 

Establish and comply with 

applicable OPLs. Comply 

with the reporting and 

recordkeeping requirements 

ofthe HWC MACT . 

Material Processing 

Areas (MP-l,MP- 2 

and Lab Pack 

Repack Unit) 

NESHAPs for off-site 

waste and recovery 

operations and 

containers. 

[Conditions 2.2(A)(1) 

and (A)(2))] 

40 C.F.R. Part 63, 

Subparts D D and PP 

Comply with the work 

practice requirements of 40 

C.F.R. Part 63, Subparts D D 

and PP. Control air 

emissions from containers 

in accordance with 

Container Level 1 

requirements. 

Material Processing 

Areas (MP-l,MP- 2 

and Lab Pack 

Repack Unit) 

V O C limit: 8 lb/hr 

except as allowed for 

in 35 IAC 219.301. 

[Condition 2.2(A)(3)] 

35 IAC 219.301 Calculate VO C emissions 

based on the most recent 

version of the TANK S 

program. 

Visible emissions: 30 

percent limit except as 

allowed by 35 IAC 

212.123(b). 

[Condition 2.2(A)(4)] 

35 IAC 212.123 Daily visible emissions 

observations. 

Drum Crusher PM limits: Variable 

SIP limits for process 

emission units. 

[Condition 2.3(A)(1)] 

35 IAC 212.321(a) Calculate P M emissions 

from test results, monitoring 

data, engineering 

calculations and standard 

emission factors. 

VES017274 
Statement of Basis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10,2014 Page 34 of 79 

Emission 

Unit 

Summary of 

Applicable 

Requirement and 

Permit Condition 

Regulatory 

Citation 

Summary of Monitoring, 

Reporting and 

Recordkeeping 

Requirements 

VOC limit: 8 lb/hr 

except as allowed for 

in 35 IAC 219.301. 

[Condition 2.3(A)(2)] 

35 IAC 219.301 Calculate VO M emissions 

using an emission factor 

equal to 0.0221 lb VO M per 

drum crushed. 

Visible emissions: 30 

percent opacity limit 

except as allowed by 

35 IAC 212.123(b) 

and 212.124. 

[Condition 2.3(A)(3)] 

35 IAC 212.123(a) Daily visible emissions 

observations. 

Storage Tanks for 

Liquid Wastes 

(Tanks #2, #4, #6, 

#8, #10, #20, #30, 

#40, #50, #60, 

#300, #302, #304, 

#306, #308, #310, 

#312, #314), and 

No. 2 Fuel Oil 

(Tank #390) 

NESHAPs for benzene 

waste operations and 

off-site waste and 

recovery operations. 

[Conditions 2.4(A)(1) 

and (A)(2)] 

40 C.F.R. Part 61, 

Subpart FF; 40 

C.F.R. Part 63, 

Subpart DD 

Monitoring, recordkeeping 

and reporting requirements 

of 40 C.F.R. Part 61, 

Subpart FF and 40 C.F.R. 

Part 63, Subpart DD. 

Regular inspection of 

submerged loading pipes. 

Storage Tanks for 

Liquid Wastes 

(Tanks #2, #4, #6, 

#8, #10, #20, #30, 

#40, #50, #60, 

#300, #302, #304, 

#306, #308, #310, 

#312, #314), and 

No. 2 Fuel Oil 

(Tank #390) 

NSPS for Volatile 

Organic Liquid 

Storage Vessels. 

[Condition 2.4(A)(3)] 

40 C.F.R. Part 60, 

Subpart Kb 

Monitoring, recordkeeping 

and reporting requirements 

of 40 C.F.R. Part 60, 

Subpart Kb. 

Storage Tanks for 

Liquid Wastes 

(Tanks #2, #4, #6, 

#8, #10, #20, #30, 

#40, #50, #60, 

#300, #302, #304, 

#306, #308, #310, 

#312, #314), and 

No. 2 Fuel Oil 

(Tank #390) 

V OC emissions from 

Tank Farm #3 limited 

to 2.5 tpy. [Condition 

2.4(A)(3)] 

Construction Permit 

88030101 

Comply with the work 

practice and operating 

requirements of 40 C.F.R. 

Part 60, Subpart Kb, 35 IA C 

219.129(f) and 219.122(b). 

Bulk Solid Waste 

Storage Facility 

(Bulk Feed 

Building) 

NESHAPs for benzene 

waste operations and 

off-site waste and 

recovery operations. 

[Conditions 2.5(A)(1) 

and (A)(2)] 

40 C.F.R. Part 61, 

Subpart FF; 40 

C.F.R. Part 63, 

Subpart D D 

Monitoring, recordkeeping 

and reporting requirements 

of 40 C.F.R. Part 61, 

Subpart FF and 40 C.F.R. 

Part 63, Subpart DD. 

Bulk Solid Waste 

Storage Facility 

(Bulk Feed 

Building) 

PM limits: Variable 

SIP limits for process 

emission units. 

[Condition 2.5(A)(3)] 

35 IAC 212.321(a) Calculate P M emissions 

from test results, monitoring 

data, engineering 

calculations and standard 

emission factors. 

Bulk Solid Waste 

Storage Facility 

(Bulk Feed 

Building) 

Visible emissions: 30 

percent opacity limit 

except as allowed by 

35 IAC 212.123(a) Daily visible emissions 

observations. 

VES017275 
Stalement of Basis for DRAFT Title V Pennit No. V-IL-1716300103-2014-10 

Pennittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 35 of 79 

Emission 

Unit 

Summary of 

Applicable 

Requirement and 

Permit Condition 

Regulatory 

Citation 

Summary of Monitoring, 

Reporting and 

Recordkeeping 

Requirements 

35 IAC 212.123(b) 

and 212.124. 

[Condition 2.5(A)(4)] 

V OC limit: 8 lb/hr 

except as allowed for 

in 35 IAC 219.301. 

[Condition 2.5(A)(5)] 

35 IAC 219.301 Enclosed building during 

operations. Calculate VO C 

emissions from test results, 

monitoring data, 

engineering calculations and 

standard emission factors. 

Gasoline Storage 

Tank (564 gallon 

design capacity 

equipped with 

submerged loading 

pipe) 

Requirements of the 

Illinois SIP. 

[Conditions 2.6(A)(1) 

and (A)(2)] 

35 IAC 219.122(b) 

and 35 IAC 

219.583(a)(1). 

Recordkeeping of tank 

design information and 

gasoline throughput. 

Boiler #1 

CO emission limits: 

200 ppm, conected to 

50 percent excess air; 

2.1 lb/hr; 9.2 tpy. 

[Conditions 2.7(A)(1) 

and (A)(2)] 

35 IAC 216.121; 

Construction Permit 

95080025 

Performance tests for CO 

and NOx at a frequency o f 

no less than once every 5 

years. Comply with the 

work practice requirements 

of 40 C.F.R. Part 63, 

Subpart DDDDD, including 

conducting annual tune-ups. 

Use of natural gas only. 

Recordkeeping of fuel 

usage. 

Boiler #1 

NOx emission limits: 

1.46 lb/hr and 6.41 

tpy. [Condition 

2.7(A)(2)] 

Construction Permit 

95080025 

Performance tests for CO 

and NOx at a frequency o f 

no less than once every 5 

years. Measure NOx 

concentrations during 

annual tune-ups. Use of 

natural gas only. 

Recordkeeping of fuel 

usage. 

Boiler #1 

Visible emissions: 30 

percent opacity limit 

except as allowed by 

35 IAC 212.123(b) 

35 IAC 212.123(a) Annual Method 9 testing. 

VES017276 
Statement ofBasis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia FS Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 36 of 79 

Emission 

Unit 

Summary of 

Applicable 

Requirement and 

Permit Condition 

Regulatory 

Citation 

Summary of Monitoring, 

Reporting and 

Recordkeeping 

Requirements 

and 212.124. 

[Condition 2.7(A)(3)] 

NESHA P for 

Industrial, 

Commercial, and 

Institutional Boilers 

and Process Heaters. 

[Condition 2.7(A)(5)] 

40 C.F.R. Part 63, 

Subpart DDDD D 

Comply with the work 

practice requirements of 40 

C.F.R. Part 63, Subpart 

DDDDD , including 

conducting annual tune-ups. 

Emergency 

Generators (2) 

NESHA P for 

Stationary 

Reciprocating Internal 

Combustion Engines 

(RICE). [Condition 

2.8(A)] 

40 C.F.R. Part 63, 

Subpart ZZZZ 

Comply with the work 

practice requirements of 40 

C.F.R. Part 63, Subpart 

ZZZZ. 

Facility-wide 

Fugitive Emissions 

Requirements 

Requirements of 35 

IAC Part 219, Subpart 

C, and 40 C.F.R. Part 

61, Subparts J and V 

(equipment leaks). 

[Conditions 2.9(A)(1) 

and (A)(2)] 

40 C.F.R. Part 61, 

Subparts J and V , 

and 35 IAC Part 

219, Subpart C 

Comply with the work 

practice, leak detection and 

repair requirements of 35 

IAC Part 219, Subpart C, 

and 40 C.F.R. Part 61, 

Subparts J and V . 

Other General 

Facility-wide 

Requirements 

Permit conditions 2.10, 3.0 and 4.0 detail all applicable general 

requirements, including emissions control requirements that apply to 

insignificant emissions units and activities. Veolia must maintain records 

sufficient to demonstrate compliance with the applicable requirements. 

4.2.1. GHG Emissions 

Veolia is not cunently subject to any applicable requirements for emissions of 

GHGs. This is because there are no GH G air quality control requirements 

contained in the CAA , the Illinois SIP, constmction permits issued pursuant to the 

Illinois SIP, or operating permits that ctinently apply to this facility. While 

Veolia is subject to the Mandatory Reporting Rule for GH G emissions, 40 C.F.R. 

Part 98, that rule does not constitute an "applicable requirement," as defined at 

40 C.F.R § 71.2. See, e.g., 74 Fed. Reg. 56260, 56288 (October 30, 2009). The 

Permittee must continue to comply with the applicable provisions of the GH G 

Mandatory Reporting Rule. 

VES017277 
Statement of Basis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 37 of 79 

4.2.2. Prevention of Significant Deterioration of Air Quality (PSD) 

Congress developed the PSD program, set forth in Part C of the CA A (Sections 

160 through 169B), to prevent significant adverse environmental impacts on 

"attainment areas" from large industrial sources of air pollution. Attainment areas 

are regions of the United States where air quality meets standards established by 

EPA (also called National Ambient Air Quality Standards, or NAAQS). 

The PSD pennitting requirements of 40 C.F.R. § 52.21 apply to major stationary 

sources located in Illinois. This is because EP A has delegated to IEPA the 

responsibility for all PSD permitting in the state of Illinois with the exception of 

any sources in Indian Country. 1 7 A major stationary source under the PSD 

regulations is a stationary source that emits or has the potential to emit 100 tpy or 

more of a regulated new source review (NSR) pollutant as defined in 40 C.F.R. 

§ 52.21(b)(50), and the stationary source belongs to the list of source categories 

provided in 40 C.F.R. § 52.21 (b)( 1 )(i)(a). 40 C.F.R. § 52.21(b)(1). Additionally, 

any stationary source is considered a major source if it emits or has the potential 

to emit 250 tpy or more of a regulated NSR pollutant. Id. 

As of the date of EPA's proposal ofthis Title V renewal permit, there are no PSD 

permits issued by IEPA for construction projects undertaken by Veolia. Future 

construction projects at Veolia will continue to be reviewed for applicability of 

PSD permitting requirements. 

4.2.3. OPLs Required by the HWC MAC T 

To demonstrate compliance during periods between compliance tests, the HWC 

MAC T (40 C.F.R. Part 63, Subpart EEE) requires sources to establish and comply 

with OPLs that are representative of operating levels achieved during compliance 

testing required by the HW C MACT . 40 C.F.R. § 63.1207. Veolia must develop 

the OPLs contained in Table 8 for Units 2, 3 and 4. 

7

 Illinois currently does not have any federally-recognized Indian Country areas. 

VES017278 
Statement of Basis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 38 of 79 

Table 8. OPLs Required by the HWC MACT. 

OPL Reference 

Minimum primary combustion chamber 

temperature 

40 C.F.R. § 63.12090X1), (k)(2) 

Minimum secondary combustion chamber 

temperature 

40 C.F.R. § 63.1209(j)(l), (k)(2) 

Maximum flue gas flowrate or production rate 40 C.F.R. § 63.12090X2)), (k)(3), 

(m)(2), (n)(5), (o)(2) 

Maximum hazardous waste pumpable feedrate 

rate for each combustion chamber 

40 C.F.R. § 63.12090X3), (k)(4) 

Maximum hazardous waste total feedrate rate for 

each combustion chamber 

40 C.F.R. § 63.12090X3), (k)(4) 

Operation of waste firing system for each location 

where waste is fed to the incinerator 

40 C.F.R. § 63.12090X4) 

Maximum temperature of the gas at the inlet to a 

dry particulate matter control device 

40 C.F.R. § 63.1209(k)(l)), (n)(l) 

Minimum carbon injection rate (Unit 4 Only)* 40 C.F.R. § 63.1209(k)(6)(i) 

Minimum carrier fluid (gas or liquid) flowrate or 

pressure drop for activated carbon injection 

system (Unit 4 Only)* 

40 C.F.R. § 63.1209(k)(6)(ii) 

The brand (i.e., manufacturer) and type of carbon 

used during the comprehensive perfonnance test 

(Unit 4 Only)* 

40 C.F.R. § 63.1209(k)(6)(iii) 

Maximum total feedrate of mercury 40 C.F.R. § 63.1209(l)(l)(i) 

Maximum ash feedrate 40 C.F.R. § 63.1209(m)(3) 

Maximum total feedrate of semivolatile metals 40 C.F.R. § 63.1209(n)(2)(ii) 

Maximum total feedrate of low volatile metals 40 C.F.R. § 63.1209(n)(2)(ii) 

Feedrate limits for low volatile metals in 

pumpable feedstreams 

40 C.F.R. § 63.1209(n)(2)(vii) 

Feedrate of total chlorine and chloride in all 

feedstreams 

40 C.F.R. § 63.1209(n)(4), (o)(l) 

Minimum sorbent feedrate 40 C.F.R. § 63.1209(o)(4)(i) 

Minimum canier fluid flowrate or nozzle 

pressure drop for the spray dry adsorber 

40 C.F.R. § 63.1209(o)(4)(ii) 

The brand (i.e., manufacturer) and type of sorbent 

used during the comprehensive performance test 

40 C.F.R. § 63.1209(o)(4)(iii)(A) 

Maximum combustion chamber pressure 40 C.F.R. § 63.1209(p) 

*These OPLs only apply to combustion units that are equipped with an activated carbon 

injection system. Units 2 and 3 are not equipped with activated carbon injection systems. 

VES017279 
Statement of Basis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 39 of 79 

To ensure that these OPLs do not impede normal day-to-day operations, sources 

generally take measures to operate during compliance testing under conditions 

that would normally produce the highest emissions. For example, sources often 

feed ash, metals, and chlorine during compliance testing at substantially higher 

than normal levels (e.g., by spiking the feedstream) to maximize the feed 

concentration, and they often detune the air pollution control equipment to 

establish operating limits on the control equipment that provide operating 

flexibility. 1 8 Thus, the emission levels achieved during compliance tests are 

typically the highest emission levels a source emits under reasonably anticipatable 

circumstances.19 

By designing its CPT to generate emissions under worst case operating 

conditions, a source can establish OPLs that account for variability in operations 

(e.g., composition and feedrate of feedstreams, as well as variability of pollution 

control equipment efficiency) and that do not impede normal operations. Thus, 

the feedrate OPL would be based on waste levels fed during the CPT unless the 

regulatory authority approves a request for the source to extrapolate to a higher 

allowable feedrate (and emission rate) limit. 2 0 

4.2.4. Extrapolation of CPT Feedrates 

40 C.F.R. § 63.1209(l)(l)(v) and (n)(2)(vii) allows each facility to include as part 

ofthe CPT plan required under 40 C.F.R. §§ 63.7(b) and (c) and 63.1207(e) and 

(f) a request to use the mercury, SV M and LV M feedrates and associated 

emission rates during the CPT to extrapolate to higher allowable feedrate limits 

and emission rates, subject to a number of statutory and policy provisions. 2 1 

Extrapolation can be advantageous because it avoids much ofthe spiking that 

sources normally undertake during compliance testing and the associated costs, 

risks to operating and testing personnel, and environmental loading from 

emissions. 64 Fed. Reg. 52827, 52946-52947. Under an approved extrapolation 

approach, the facility would be required to feed metals at no less than normal 

rates to narrow the amount of extrapolation requested. Id. Further, EPA expects 

that some spiking would be desired to increase confidence in the measured 

performance test feedrate levels that will be used to project feedrate limits (i.e., 

the enors associated with sampling and analyzing heterogeneous feedstreams can 

be minimized by spiking known quantities). Id. EP A will generally disapprove 

any extrapolation approaches that request feedrate limits that are significantly 

higher than the historical range of feedrates. Id. Extrapolated feedrate limits 

1 8

 69 Fed. Reg. 21198, 21218 (April 20, 2004). 

1 9

 69 Fed. Reg. 21197, 21218, April 20, 2004, HW C MAC T Proposed Rule. See also 40 C.F.R. §§ 63.1206(b)(2), 

63.1207(f)(1) and (g)(1). 

2 0

 69 Fed. Reg. 21197, 21309-10, th. 202 & 204. 

21 See also 64 Fed. Reg. 52827, 52946-47 (September 30, 1999); 40 C.F.R. § 63.1209(l)(l)(v) and (n)(2)(vii). 

VES017280 
Statement of Basis for DRAF F Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 40 of 79 

should be limited to levels within the range ofthe highest historical feedrates for 

the source. Id. 

4.2.5. Feedrate OPLs Included in Veolia's Permit 

EPA has reviewed Veolia's CPT test report dated January 28, 2014 (the 2014 

CPT report)22 and Veolia's Notification of Compliance (NOC) dated January 28, 

2014 (the 2014 NOC) and determined that there is sufficient information to enable 

EPA to establish OPLs for mercury, SV M and LV M that satisfy the requirements 

ofthe Act and the HWC MACT . Specifically, EP A has determined that the OPLs 

shown in Table 9, below, are supported by the available CPT data. Therefore, 

consistent with 40 C.F.R § 71.6(a)(1), EP A is proposing to incorporated these 

OPLs into the permit. See Condition 2.1(C)(2). 

Table 9. Proposed Feedrate OPLs for Selected Parameters. 

Unit* Measured Parameter 

Average 

Feedrate 

During 

CPT Gb/hr) 

Proposed 

OPL 

0b/hr)» 

Measured Average 

Stack Concentration 

(fig/dscm @ 7% O2, 

except as noted)

 d 

MAC T Limit 

(Corrected to 7% 

O2) 

Mercury 0.00212 0.0021 100 130 pg/dscm 

L V M 46.3 46 2.6 92 ug/dscm 

L V M (Pumpable) 46.3 46 2.6 92 pg/dscm 

2 

S V M 61.9 62 0.95 230 pg/dscm 

2 

Total Chlorine 206.1 204 20 32 ppmv dry, as CL 

Ash 503.0 503 0.00071 gr/dscf (PM) 0.013 gr/dscf 

Total Waste 4,182.4 4,017

 b N / A N / A 

Total Pumpable Waste 3,324.5 3,107

 b N / A N / A 

Mercury 0.00221 0.0021 48 130 pg/dscm 

L V M 46.0 46 9.4 92 pg/dscm 

L V M (Pumpable) 46.0 46 9.4 92 pg/dscm 

3 

S V M 62.3 62 15 230 pg/dscm 

3 

Total Chlorine 204.2 204 3.6 32 ppmv dry, as CL 

Ash 525.8 503 0.00200 gr/dscf (PM) 0.013 gr/dscf 

Total Waste 4,180.2 4,017

 b N / A N / A 

Total Pumpable Waste 3,337.5 3,107

 b N / A N / A 

2 2

 The 2014 CPT report contains the results ofthe CP T performed in October 2013 and analysis ofthe data. 

VES017281 
Stalement of Basis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 41 of 79 

Unit# Measured Parameter 

Average 

Feedrate 

During 

CPT (lb/hr) 

Proposed 

OPL 

(lb/hr) a 

Measured Average 

Stack Concentration 

(ug/dscm @ 7% O2, 

except as noted)d 

MAC T Limit 

(Corrected to 7% 

O2) 

Mercury 0.0402 0.040 10 130 pg/dscm 

L V M 46.2 46 9.7 92 pg/dscm 

L V M (Pumpable) 45.9 46 9.7 92 pg/dscm 

S V M 62.0 62 7.8 230 pg/dscm 

Total Chlorine 203.2 203 14 32 ppmv dry, as CL 

4 Ash 4,777.2 4,777 0.0021 gr/dscf (PM) 0.013 gr/dscf 

Total Waste to PCC 9,490.5 10,632 N / A N / A 

Total Pumpable Waste 

to PCC 

3,432.0 3,312° N / A N / A 

Total Pumpable Waste 

to SCC 1,191.5 1,203 N / A N / A 

a. Hazardous waste feedrate OPLs are 1 -hour rolling averages; other OPLs are 12-hour 

rolling averages. Maximum hazardous waste feedrate is established as the average of the 

maximum hourly rolling averages for each run. 

b. 1993 Resource Conservation and Recovery Act (RCRA) Trial Burn value for Unit 2. 

c. 1995 RCR A Trial Bum value for Unit 4. 

d. Data taken from the 2014 CPT Report. For purposes ofthis table, measurements that 

were reported below the detection limit have been rounded up to the detection limit. 

Veolia did not include in the 2014 CPT report or application for renewal of its Title V permit 

a request to extrapolate mercury, SV M or LV M feedrates pursuant to 40 C.F.R. 

§ 63.1209(l)(l)(v) and (n)(2)(vii). Because Veolia did not request such extrapolation, we are 

proposing to incorporate as mercury, SV M and LV M feedrate OPLs the feedrates at which 

Veolia conducted its October 2013 testing, as documented in the 2014 NOC. 

To establish the mercury, LVM , SV M and chlorine feedrates reported in Table 9, Veolia 

spiked: 2 3 

• mercury (as a mercuric nitrate solution) during all three metal test runs of the CPT 

and used the mercury system removal efficiency (SRE) demonstrated during the 

CPT to establish the feedrate limits for total mercury; 

2 3

 Spiking during CPTs involves adding a known amount of a high purity compound into the feedstream for the 

purpose of establishing the maximum amount of that compound that can be fed to the incinerator without violating 

any applicable emission standards. The average CP T feedrates for mercury, SVM , LV M and chlorine reported in 

Table 9 represent the analysis results of feedstream samples collected at least 30 minutes after spiking with 

chromium, lead, mercury and chlorine had been initiated. 

VES017282 
Statement of Basis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Dale Issued: October 10, 2014 Page 42 of 79 

• chromium (as chromic acid) during all three metal test runs ofthe CPT and used the 

chromium SRE demonstrated during the CPT to establish the feedrate limits for total 

and pumpable LVM ; 

• lead (as lead nitrate) during all three metal test runs of the CPT and used the lead 

SRE demonstrated during the CPT to establish the feedrate limits for SVM ; and 

• chlorine (hexachloroethane) during all three metal test runs of the CPT and used the 

chlorine SRE demonstrated during the CPT to establish the feedrate limits for 

HCl/Cb. 

4.3. Non-applicable Requirements 

As previously discussed, EPA's regulations at 40 C.F.R. Part 71 allow permitting 

authorities the discretion to include a "permit shield" in the permit (i.e., a provision in the 

permit stating that compliance with the conditions of the permit shall be deemed 

compliance with any applicable requirements as of the date of permit issuance). See 

40 C.F.R. § 71.6(f). However, to extend the permit shield to conditions to which the 

source is not subject, the permitting authority must, in acting on the permit application, 

determine in writing that requirements specifically identified in the permit are not 

applicable to the source, and must include in the permit that determination or a concise 

summary thereof. See 40 C.F.R. § 71.6(f)(l)(ii). 

Table 10 provides a summary of requirements that EP A has determined do not apply to 

Veolia's emission units. The non-applicability determinations are found in conditions 

2.1(B), 2.2(B), 2.3(B), 2.4(B), 2.5(B), 2.6(B), 2.7(B), 2.8(B) and 2.9(B) ofthe proposed 

renewal permit. Each non-applicability determination is based on the particular rule's 

applicability criteria. 

Table 10. Summary of Non-applicable Requirements. 

Emission Unit The affected emission unit is not 

subjectto... 

Explanation and Regulatory 

Reference 

Incineration 

Units 2, 3 and 4 

40 C.F.R. Part 64, Compliance 

Assurance Monitoring for Major 

Stationary Sources (CAM). 

These units are required to comply 

with a MAC T standard proposed after 

November 15, 1990. Emissions units 

subject to MAC T standards proposed 

by the Administrator after November 

15, 1990 are exempt from CAM . [40 

C.F.R. § 64.2(b)(l)(iY| 

Incineration 

Units 2, 3 and 4 

35 IAC Part 229, Hospital Medical 

Infectious Waste Incinerators. 

Condition 2.1(C)(1) prohibits the 

Permittee from accepting or 

VES017283 
Slatement of Basis for DRAFT Title V Pemiit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 43 of 79 

Emission Unit The affected emission unit is not 

subject to... 

Explanation and Regulatory 

Reference 

processing hospital medical infectious 

waste at the facility. [35 IAC 

229.1101 

Waste 

Processing Areas 

(MP-1, MP-2 

and the Lab Pack 

Repack) 

40 C.F.R. Part 64, CAM . These units do not use an add-on 

control device to achieve compliance 

with an emission limitation or 

standard. [40 C.F.R. § 64.2(a)] 

Waste 

Processing Areas 

(MP-1, MP-2 

and the Lab Pack 

Repack) 

40 C.F.R. Part 61, Subpart BB. This source is not part of a benzene 

production facility. [40 C.F.R. 

§ 61.300] 

Waste 

Processing Areas 

(MP-1, MP-2) 

Conveyor 

Systems 

40 C.F.R. Part 63, Subpart DD. The conveyor systems associated with 

MP-1 and MP-2 are used in the 

conveyance of material using a 

container. [40 C.F.R. § 63.681] 

Drum Crusher 40 C.F.R. Part 64, CAM . The affected drum crusher does not 

use an add-on control device to 

achieve compliance with an emission 

limitation or standard. [40 C.F.R. 

§ 64.2(a)] 

Liquid Waste 

Storage Tanks 

35 IAC 219.120, 219.121 and 

219.123 

The affected liquid waste storage 

tanks are not subject to the control 

requirements of 35 IAC 219.120, 

219.121 and 219.123 because these 

storage tanks are less than 151m3 

(40,000 gallon) capacity. [35 IAC 

219.119,219.121,219.123(a)(2)] 

Liquid Waste 

Storage Tanks 

40 C.F.R. Part 64, CAM . • The affected liquid waste storage 

tanks are subject to a NESHA P 

proposed after November 15, 

1990. Emissions units subject to 

NESHAPs proposed by the 

Administrator after November 15, 

1990 are exempt from CAM . [40 

C.F.R. § 64.2(b)(l)(i)] 

• The potential pre-control device 

emissions are less than major 

source levels for any of the CA M 

pollutants. [40 C.F.R. 

§ 64.2(a)(3)] 

VES017284 
Statemenl of Basis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Dale Issued: October 10, 2014 Page 44 of 79 

Emission Unit The affected emission unit is not 

subjectto... 

Explanation and Regulatory 

Reference 

Bulk Solid 

Waste Storage 

Facility 

40 C.F.R. Part 64, CAM . The potential pre-control device 

emissions are less than major source 

levels for any of the CA M pollutants. 

[40 C.F.R. § 64.2] 

Gasoline Storage 

Tank 

35 IAC219.583(a)(2),(3),(4) The affected gasoline storage tank has 

a capacity of less than 575 gallons. 

[35 IAC 219.583(b)(3)] 

Gasoline Storage 

Tank 

40 C.F.R. Part 60, Subpart Kb The design capacity of the storage 

tank is less than 40 m3 (10,576 

gallons). [40 C.F.R. § 60.110b(a)] 

Gasoline Storage 

Tank 

35 IAC 219.121 The gasoline storage tank has a 

capacity of less than 40,000 gallons. 

[35 IAC 219.121] Gasoline Storage 

Tank 

35 IAC 219.120 The gasoline storage tank stores 

petroleum liquids. [35 IAC 

219.119(e)] 

Gasoline Storage 

Tank 

40 C.F.R. Part 64, CAM . The gasoline storage tank does not use 

an add-on control device to achieve 

compliance with an emission 

limitation or standard. [40 C.F.R. § 

64.2] 

Boiler #1 

35 IAC 217.121 The actual heat input of the affected 

boiler is less than 73.2 M W (250 

mmBtu/hr). [35 IAC 217.121] 

Boiler #1 

35 IAC 219.301 Boiler #1 is a fuel combustion 

emission unit and fuel combustion 

emission units are not subject to 35 

IAC 219.301. [35 IAC 219.303] 

Boiler #1 

35 IAC 214.122 Solid or liquid fuels are not burned in 

the affected boiler. [35 IAC 214.122] 

Boiler #1 

40 C.F.R. Part 63, Subpart JJJJJJ Boiler #1 is a gas-fired boiler as 

defmed at 40 C.F.R. § 63.11237. [40 

C.F.R. § 63.11195(e).] 

Boiler #1 

40 C.F.R. Part 60, Subpart Da Boiler #1 is not capable of combusting 

more than 73 M W (250 mmBtu/hr) 

heat input of fossil fuel (either alone 

or in combination with any other fuel). 

[40 C.F.R. § 60.40Da(a)(l)] 

Boiler #1 

40 C.F.R. Part 60, Subpart Db Boiler #1 has a heat input capacity 

from fuels combusted in the unit of 

less than 29 M W (100 mmBtu/hr). 

[40 C.F.R. § 60.40b(a)] 

VES017285 
Statemenl of Basis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 45 of 79 

Emission Unit The affected emission unit is not 

subjectto... 

Explanation and Regulatory 

Reference 

40 C.F.R. Part 64, CA M The affected boiler does not use an 

add-on control device to achieve 

compliance with an emission 

limitation or standard. [40 C.F.R. 

§ 64.2(a)] 

Emergency 

Generators 

40 C.F.R. Part 60, Subpart IIII Construction ofthe emergency 

generator engines did not commence, 

as defined at 40 C.F.R. § 60.4200(a), 

after July 11, 2005 and the engines 

have not been modified or 

reconstructed after July 11, 2005. [40 

C.F.R. § 60.4200] 

Emergency 

Generators 

40 C.F.R. Part 60, Subpart J.IJJ The emergency generator engines are 

not spark ignition engines as defined 

at 40 C.F.R. § 60.4248. [40 C.F.R. § 

60.4230] 

Emergency 

Generators 

40 C.F.R. Part 64, CAM . The affected emergency generators do 

not use an add-on control device to 

achieve compliance with an emission 

limitation or standard. [40 C.F.R. 

§ 64.2(a)] 

Fugitive 

Emissions from 

Equipment 

Leaks 

40 C.F.R. Part 60, Subparts VV , III, 

NNN , and RRR (NSPS for the 

Synthetic Organic Chemicals 

Manufacturing Industry) and 40 

C.F.R. Part 63, Subparts F, G , II, and 

I (NESHAP for the Synthetic Organic 

Chemicals Manufacturing Industry). 

The leaking equipment is not 

associated with the manufacture or 

production of the affected organic 

chemicals. [40 C.F.R. §§ 60.480; 

60.610; 60.660; 60.700; 63.100; 

63.110; 63.160] 

Fugitive 

Emissions from 

Equipment 

Leaks 40 C.F.R. Part 64, CAM . The affected leaking equipment does 

not use add-on control devices to 

achieve compliance with an emission 

limitation or standard. [40 C.F.R. 

§ 64.2(a)] 

VES017286 
Statement of Basis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 46 of 79 

5.0. MONITORING REQUIREMENTS 

5.1. Statutory Requirements 

Section 504(c) ofthe Act requires that all Title V permits contain, among other things, 

monitoring requirements to assure compliance with permit terms and conditions. 

42 U.S.C. § 7661c(c). EPA codified monitoring rules at 40 C.F.R. §§ 71.6(a)(3)(i)(A) 

and (B) and 71.6(c)(1) to carry out that directive. 

E PA must take the following three steps to satisfy the monitoring requirements in its 

regulations: 

• First, EPA must ensure that monitoring requirements contained in applicable 

requirements are properly incorporated into the Title V permit. 40 C.F.R. 

§71.6(a)(3)(i)(A). 

• Second, if the applicable requirement does not require periodic testing or 

instrumental or noninstrumental monitoring (which may consist of recordkeeping 

designed to serve as monitoring), EPA must add "periodic monitoring sufficient 

to yield reliable data from the relevant time period that are representative of the 

source's compliance with the permit." 40 C.F.R. § 71.6(a)(3)(i)(B). Such 

monitoring requirements, which may consist of recordkeeping provisions, shall 

assure use of terms, test methods, units, averaging periods, and other statistical 

conventions consistent with the applicable requirement. Id. 

• Third, if the applicable requirement contains some periodic monitoring, but that 

monitoring is not sufficient to assure compliance with permit terms and 

conditions, EPA must supplement monitoring to assure such compliance. 

40 C.F.R. § 71.6(c)(1). See Sierra Club v. EPA, 536 F.3d 673, 680-681 (D.C. Cir. 

2008) (the most reasonable reading of 40 C.F.R. § 70.6(c)(1) is that it ensures that 

"all Title V permits include monitoring 'sufficient to assure compliance with the 

terms and conditions of the permit.'"). See also In the Matter of CITGO Refining 

& Chemicals Co., Petition No. VI-2007-01 (Order on Petition) (May 28, 2009) at 

6-7. 

5.2. Feedstream Analysis Procedures for Mercury, LV M and SVM 

[Condition 2.1(D)(4)(d)(ii)] 

5.2.1. Overview of Requirements 

Under the HWC MACT , to demonstrate compliance with the emissions limits for 

mercury, LVM , SVM , P M and chlorine, Veolia must either comply with feedrate 

VES017287 
Statemenl of Basis for DRAFT Title V Pennit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page47of79 

limits established through comprehensive performance testing for those metals, 

ash and chlorine, or it may petition EP A to approve the installation and 

continuous operation of emission monitoring systems to directly measure and 

document compliance with PM , metals and chlorine emissions limits. Veolia has 

not petitioned EP A to install and operate a CEM S for PM , metals, or chlorine. 

Therefore, under the HWC MACT , Veolia must analyze each feedstream prior to 

feeding the material into any of its incinerators and document the amount of 

metals, ash and chlorine present in the feedstream. Veolia must follow 

procedures documented in a feedstream analysis plan (FAP). The FA P must be 

"sufficient to document compliance with the applicable feedrate limils." 

40 C.F.R. § 63.1209(c). 

E PA has reviewed Veolia's FAP, which is available as part of the permit record 

for this proposed permit renewal action, 2 4 and other monitoring requirements in 

the existing 2008 permit, and detennined that they are not sufficient to determine 

that waste streams comply with the feedrate limits or assure compliance with 

applicable emissions limits for metals. Although Veolia's FAP contains the 

minimum elements required by 40 C.F.R. § 63.1209(c)(2)(i) through (vi), forthe 

reasons outlined below, EP A has found that the existing FA P is not sufficient to 

ensure that the mercury, lead, arsenic, beryllium, cadmium and chromium 

concentrations in the waste streams are no greater than the concentrations stated 

in the waste profiles that Veolia has used to calculate metal feedrates. As 

discussed below, Veolia cunently depends on information in a corporate database 

for "similar" waste streams without real knowledge of what metals are in the 

wastes it incinerates. Further, the database frequently contains information that is 

inconsistent with data provided by waste generators. Therefore, the existing FA P 

cannot assure compliance with the metals feedrate limits. 

Additionally, because Veolia's FA P does not ensure that each feedstream is 

appropriately characterized, the cunent FA P does not assure compliance with the 

feedrate limits in the permit. 

For the reasons further discussed below, Veolia's current FAP is not sufficient to 

ensure that the mercury, SV M and LV M concentrations in the waste streams are 

no greater than the concentrations stated in the waste profiles that Veolia uses to 

calculate metal feedrates. Therefore, the FAP cannot assure compliance with the 

feedrate limits for mercury, SV M and LVM . Compliance with the feedrate limits 

is a fundamental step in assuring compliance with the HWC MAC T emissions 

limits. To address the deficiencies in Veolia's FAP described above, and to 

assure compliance with the feedrate limits, EP A has proposed minimum mercury, 

L V M and SV M analysis procedures in the permit. The proposed analysis 

procedures would require Veolia to: 

2 4

 Veolia's FA P and RCR A Waste Analysis Plan (WAP ) are available at 

http://ww\v. epa. (•ov/region5/air/veoliasauget/index, html. 

VES017288 
Statement of Basis for DRAFT Title V Pennit No. V-IL-1716300103-2014-10 

Permittee: Veolia F.S Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 48 of 79 

• sample and analyze each feedstream accepted for incineration unless that 

feedstream is specifically exempted by the permit; 2 5 

• sample and analyze all batched, treated, blended, mixed, or otherwise 

altered waste for mercury, LV M and SV M in its final form as feed for 

incineration prior to incineration; 2 6 

• not batch, treat, blend, mix, or otherwise alter feedstreams which are exempt 

from sampling unless Veolia samples and analyzes the otherwise exempt 

feedstream; 

• document the concentration of mercury, LV M and SV M in any fuel other 

than natural gas, including used oil, diesel, and alternative fuels fed into the 

incinerators by either (1) obtaining analytical results from each fuel supplier 

or (2) conducting representative sampling of each fuel supply and analyzing 

such samples using appropriate quality assurance/quality control procedures 

and test methods. Veolia would follow this procedure at least once per year 

for each fuel supply; 2 7 

• document concentrations that fall below the detection limit in non-exempt 

feedstreams as equal to the detection limit; 2 8 and 

• maintain records of all required feedstream analyses for a period of five 

calendar years. 

The above feedstream analysis provisions supplement any analysis procedures 

specified in Veolia's FA P for mercury, LV M and SVM , and supersede any less 

stringent provisions in the FAP . Incorporation of these requirements into the Title 

V permit would not eliminate Veolia's obligation to maintain an adequate FAP, 

consistent with 40 C.F.R. § 63.1209(c); rather, the permit would specify minimum 

feedstream analysis procedures to assure compliance with the proposed feedrate 

limits, and, through them, with applicable HWC MAC T emissions limits. 

Because Veolia would generally base metal feedrate calculations on actual 

feedstream analysis data and not on theoretical profile estimates, the above 

2 5

 The proposed permit lists exemptions in condition 2. l(D)(4)(d)(ii)(F). 

2 , 1

 In lieu of sampling and analysis, Veolia would be given the option to perform a mass balance calculation to 

determine concentrations in the final batched, treated, blended, mixed, or otherwise altered waste. The calculation 

must be based on all batched, treated, blended, mixed, or otherwise altered ingredients having been analyzed and the 

contribution of each ingredient determined as specified in the permit. 

2 7

 This provision refers to fuels that are burned in the incinerators along with hazardous waste. 

2 8

 For purposes of this provision, "detection limit" loosely refers to the proposed permit's "reporting limit" that 

would be calculated for each measurement using procedures contained in EPA's solid waste analysis methods 

manual, SW-846. 

VES017289 
Statement of Basis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia BS Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 49 of 79 

supplemental feedstream analysis provisions will increase our confidence in the 

feedrates reported by Veolia. These provisions also will ensure that Veolia does 

not report metal concentrations of zero in situations where actual metal 

concentrations in the feedstream are only slightly below the detection limit. 

5.2.2. Deficiencies in Veolia's Current Feedstream Analysis Procedures 

A. Veolia currently does not sample and analyze all feedstreams 

and thus might be underreporting metal concentrations in its 

feedstreams. 

Under Veolia's current feedstream analysis procedures, Veolia does not analyze 

all feedstreams and instead primarily relies on the generator for information 

regarding the composition of a feedstream. Prior to scheduling wastes for 

shipment to the facility, the generator characterizes the waste streams. Veolia 

staff review the generator information before accepting the waste for 

incineration. 2 9 Veolia maintains a "dynamic suspect list" of industries and 

process wastes that could contain mercury, cadmium, chromium, arsenic, lead, 

and beryllium which it, therefore, must analyze for metals before the waste stream 

can be approved for incineration. 3 0 However, if Veolia considers a waste stream 

submitted by a generator for approval to be "similar" to waste streams that it 

already has accepted for treatment at Veolia facilities, rather than sampling the 

waste, Veolia currently may use a standard profile designation to calculate the 

amount of metals in the waste. 3 1 The standard profile designation is based on a 

database developed using analytical data from wastes from similar industries or 

processes. Once waste is accepted for incineration, Veolia randomly samples and 

analyzes 10 percent of containers from each receipt number (profile) within a 

shipment for pH, radiation, flash point, polychlorinated biphenyls (PCBs) and 

apparent viscosity, pursuant to its waste analysis plan. 3 2 However, metals 

analysis may nor may not be conducted on these samples. As discussed below, 

there are numerous problems with Veolia's reliance on its analytical database in 

lieu of independently sampling and analyzing each feedstream. 

2 9

 Comprehensive Performance Test (CPT) Plan for Unit 2 (June 27, 2013) at 3-1. 

5 0

 NEIC Multimedia Compliance Investigation Observations Report, Veolia ES Technical Services, NEIC Project 

No. VP0972, August 2012 (NEIC Report) at 8-9. Available at: www.regulations.gov: document ID. EPA-R05 -

OAR-2012-0649-0035. NEIC conducted this investigation at the request of EP A Region 5. The goal of the 

investigation was to determine Veolia's compliance with CA A and RCR A waste analysis requirements. In general, 

Veolia does not analyze wastes that are exempted by the FA P from sampling and analysis. 

31 Id. Veolia utilizes standard profile designations, many of which are based on historical data obtained by the 

Veolia facility located in Port Arthur, Texas, for waste streams that have similar physical and chemical 

characteristics, that are generated by similar industries or processes, or that have the same EP A hazardous waste 

codes as similar process waste. Id. 

32 Id. at 10. 

VES017290 
Statement of Basis for DRAFT Title V Pennit No. V-IL-1716300103-2014-10 

Pennittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 50 of 79 

B. Veolia's feedstreams are highly variable and metal 

compositions can vary significantly within the feedstream (i.e., 

heterogeneous feedstreams) and among feedstreams (variable 

feedstreams). 

Veolia treats and disposes a variety of solid, liquid and gaseous wastes which 

typically arrive in drums, roll-off containers or other similar bulk transport 

vehicles, totes, Gaylord boxes, tank trucks and cylinders. 3 3 According to Veolia's 

website, in addition to other hazardous and non-hazardous waste, Veolia's Sauget 

facility accepts for incineration Drug Enforcement Administration controlled 

substances, drugs, goods with expired dates, seized goods, returned goods and lab 

chemicals. 3 4 Because Veolia's Sauget facility accepts and incinerates a broad 

range of wastes, Veolia has explained that "the individual streams that may make 

up the incinerator overall feed at any given time can vary greatly, depending on 

generator production and shipping schedules."35 

In its 2012 investigation, EPA's National Environmental Investigations Center 

(NEIC) found that some nominally similar waste streams generated by different 

generators had significantly different metal concentrations, yet, as described 

above, Veolia did not analyze these wastes when they arrived onsite. Instead, 

Veolia relied upon an "overly broad" characterization of the wastes and assigned 

a single metal concentration value for the individual wastes. In one instance, for 

example, Veolia has assigned two waste streams, both classified as "cyanide 

containing wastes" and identified by Veolia as "very similar," two very different 

cadmium concentrations: 6,470 mg/kg and 1 mg/kg, respectively. 3 6 NEIC 

suggested that, due to the potential variability in metal concentrations of some 

"very similar" wastes from different generators, Veolia should analyze waste 

streams generated by different generators each time they arrive on-site instead of 

relying on "overly broad profiles" to characterize these wastes.37 

Also, as noted in the NEIC report, "[s]amples of bulk liquids are not analyzed [by 

Veolia] for metals; instead, metals concentrations are calculated based on profile 

information stored in Veolia's waste tracking system (WTS). The WTS pulls 

information from the corporate tracking system, called the "I-Series".... Onsite 

analyses may be used to update the profile information in the WTS." 3 8 Because 

liquids stored in drums, tank trucks or other containers separate or settle and, thus, 

do not generally stay homogenous (i.e., well mixed) over an extended period of 

n

 Veolia's 8-16-13 application addendum at 3. 

5 4

 http://www.veoliaes.com/en/services/enterprise/waste/incineration.html (last accessed 3/14/14) 

! 5

 CP T Plan for Unit 2 (June 27, 2013) at 3-1. 

1 6

 NEIC Report at 23. 

"Id. 

! s

 NEIC Report (August 2012) at 6. The goal of the NEIC investigation was to determine Veolia's compliance with 

C A A and RCR A waste analysis requirements. Id. at 8. 

VES017291 
Slatement of Basis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 51 of 79 

time in storage, the metal concentrations in these drums can vary substantially 

within the drum, tank truck or container such that the stored metal concentration 

profile may no longer represent the actual metal concentrations in each portion o f 

the waste as fed to the incinerator. In addition, solids stored in containers may not 

stay well-mixed (i.e., homogeneous) during transport from the waste generator to 

the facility. Therefore, in order to better determine actual metal concentrations i n 

solid and liquid wastes as fed to the incinerator, it is critical that these wastes be 

analyzed after they are accepted for incineration at the facility. 

C. Veolia's current feedstream analysis and recordkeeping 

procedures could cause Veolia to significantly underreport 

concentrations of some metals in its feedstreams. 

NEIC's investigation revealed that Veolia may have significantly undeneported 

concentrations of chromium and cadmium in some feedstreams.39 In one 

example, Veolia reported a chromium value of 228 milligrams per kilogram 

(mg/kg) for a certain waste in its databases while a material safety data sheet for 

that waste listed a total chromium value of 30,000 to 60,000 mg/kg. 4 U Because 

Veolia generally uses infonnation contained in its databases to calculate metal 

feedrates rather than independently analyzing each feedstream before it is fed to 

the incinerator, Veolia may have used an inconect concentration to calculate 

chromium feedrates in this case. Therefore, in the examples observed by NEIC, 

Veolia's possible use of incorrect metal concentrations to calculate feedrates may 

have resulted in significant undeneporting of the actual metal feedrates.41 

Without the proposed monitoring procedures, there is no way to evaluate the 

accuracy of the metal concentrations used by Veolia. 

D. Analytical and data reporting errors may have resulted in 

inaccurate feedrate calculations for some metals. 

In its investigation, NEIC identified conflicting metals data between the profile 

package and the information entered in Veolia's databases.42 In one example, a 

profile reported a chromium concentration of 1.8 milligrams per liter (mg/L), yet 

"NEI C Report at 23. 

4 0

 Id. 

4 1

 Another example of this possibility is illustrated within the preparations leading up to the October 2013 

comprehensive performance test. Waste Profile #739592, BIL T PLATE S - a product containing kaolin clay was 

not identified by Veolia staff as "suspect" for mercury. As such, Veolia continued to receive several shipments and 

would likely have incinerated the material assuming a mercury concentration of zero had it not decided to reserve 

this material for the test burn. As it turns out, analysis of this wastestream during the test burn revealed that the 

actual mercury concentration in the wastestream was 0.19 ppm - not zero. Thus, the wastestream contained enough 

mercury to have supplied about 36% of the total mercury feedrate for Units 2 or 3 (based on the updated 

Notification of Compliance (NOC)), but Veolia would not have accounted for it in its wastestream analysis. 

4 2

 NEI C Report at 23. 

VES017292 
Statement of Basis tor DRAFT Title V Pemiit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 52 of 79 

Veolia used a value of 0 mg/L in its databases.43 In another example, a profile 

reported a total mercury concentration of 4140 mg/kg but Veolia used a value o f 

25 mg/kg in its databases for at least 5 years. 4 4 NEIC estimated that if a mercury 

concentration of 4140 mg/kg had been present in waste that was incinerated on 

August 28 and 29, 2011, Veolia would have exceeded the emissions and feedrate 

limits for mercury on those days. 4 5 Because ofthis type of problem with 

conflicting entries, without any clear indication of which concentration is correct, 

it is possible that Veolia used incorrect metals concentrations for feedrate 

calculations on August 28 and 29, 2011, and very likely that Veolia uses incorrect 

metals concentrations on a regular basis. 

Thus, in the proposed Title V renewal pennit, EPA requires Veolia to prepare and 

follow a FAP to demonstrate compliance with the metal feedrate limits, conduct 

periodic comprehensive performance tests as required by the HW C MACT , and 

comply with a number of additional monitoring, recordkeeping and reporting 

requirements. The additional feedstream analysis procedures, which are found in 

conditions 2.1(D)(l)(i) and 2.1(D)(4)(d)(ii), supplement any other mercury, LV M 

and SV M analysis procedures specified in Veolia's FAP and supersede any less 

stringent provisions in the FAP . As already stated above, incorporation of these 

requirements into the Title V permit does not eliminate Veolia's obligation to 

maintain an adequate FAP, consistent with 40 C.F.R. § 63.1209(c); rather, we are 

specifying minimum feedstream analysis procedures to assure compliance with 

the proposed feedstream limits, and, through them, compliance with the 

applicable HW C MAC T limits. 

We are also specifying that Veolia maintain records of its feedstream analyses and 

other data required to be kept by the permit for a period of five calendar years, 

and make them available at all times for inspection by EPA, Illinois EPA, local 

agencies, or their duly authorized representatives, pursuant to Condition 

2.1(E)(21) ofthe permit. 

5.3. Multi-Metals Continuous Monitoring Requirements [Condition 

2.1(D)(l)(i)] 

5.3.1. Overview of Requirements 

Veolia conducted comprehensive performance tests (CPTs) at each of the 

incinerators in October 2013. The results of those CPTs demonstrated, among 

other things, that the emissions from the three units were significantly different, 

« Id. 

»Id. 

1,3 Id. at 27. 

VES017293 
Statement ofBasis lor DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia BS Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 53 of 79 

despite the fact that Veolia had incinerated similar wastes during the tests. This 

illustrates that a simple linear calculation may not be appropriate for estimating 

metal slack concentrations from the emission units. As discussed at section 5.3.3, 

below, EPA has identified several possible reasons for the differing emissions at 

the three units. Further, EP A does not know with which metals chlorine or other 

anions preferentially react in the gas stream and which metal chlorides are more 

easily captured in Veolia's air pollution control equipment. 

The HWC MAC T at 40 C.F.R. § 63.1209(g)(2) provides the Administrator 

authority to limit additional or alternative operating parameters or require 

"alternative approaches to establish limits on operating parameters" that are 

necessary to document compliance with the HW C MAC T emissions standards. 

E PA interprets 40 C.F.R. § 63.1209(g)(2) as providing EPA with authority to 

require additional monitoring related to parametric monitoring. Additionally, 

section 114(a) of the Act, 42 U.S.C. § 7414(a), provides EPA with authority to 

require "enhanced monitoring" as necessary to carry out any provision ofthe Act. 

Section 114(a) of the Act states in relevant part: 

For the purpose ... (iii) [of] carrying out any provision of this chapter 

(except a provision of subchapter II of this chapter with respect to a 

manufacturer of new motor vehicles or new motor vehicle engines) ... (1) 

the Administrator may require any person who owns or operates any 

emission source, ... who the Administrator believes may have information 

necessary for the purposes set forth in this subsection, or who is subject to 

any requirement of this chapter (other than a manufacturer subject to the 

provisions of section 7525(c) or 7542 of this title with respect to a 

provision of subchapter II of this chapter) on a one-time, periodic or 

continuous basis to ... (C) install, use, and maintain such monitoring 

equipment, and use such audit procedures, or methods ... and (G) provide 

such other information as the Administrator may reasonably require.... 

The Administrator shall in the case of any person which is the owner or 

operator of a major stationary source.. .require enhanced monitoring and 

submission of compliance certifications. 

Therefore, 40 C.F.R. § 63.1209(g)(2) and 42 U.S.C. § 7414(a) provide the 

authority to require installation and temporary use of a multi-metals Continuous 

Parameter Monitoring System (CPMS) to assess whether the identified 

parameters and operating parameter levels are adequate to assure compliance with 

the emission limits set forth in the HWC MACT . Under these authorities, a 

CPMS using CEMS technology can be used to indicate performance and not 

necessarily as a direct measure of emissions. EP A has previously employed this 

approach in the context of the Portland Cement MAC T rulemaking in which EP A 

required affected sources to install P M CEM S but to operate each P M CEM S as a 

CPMS . See 78 Fed. Reg. 10019-10020. Therefore, throughout this document and 

VES017294 
Statement ofBasis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Pennittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 54 of 79 

Veolia's permit, EPA is using the term multi-metals CEM S to reflect the use of 

the CEM S as a CPMS. Section 504(a) of the Act requires that "Each permit 

issued under [Title V of the Act] shall include ... such other conditions as are 

necessary to assure compliance with the applicable requirements of this Act, 

including the requirements ofthe applicable implementation plan." Inclusion of 

requirements for use of the multi-metals CEMS as a CPMS under the authority o f 

40 C.F.R. § 63.1209(g)(2) and 42 U.S.C. § 7414(a) is consistent with this 

mandate. 

To verify that the feedrate limits and the feedstream analysis procedures proposed 

in this Title V permit renewal are sufficient to assure continuous compliance with 

the HWC MAC T emissions limits, EPA is proposing to require that Veolia install 

and operate a multi-metals CEM S at each incineration unit for a period of at least 

12 months. 4 6 Veolia will operate each multi-metals CEM S as a CPMS , using the 

metal concentrations measured by the multi-metals CEM S as a parametric 

indicator of compliance with the emissions standards and to verify the adequacy 

ofthe feedrate limits. Because multi-metals CEM S measurements have 

previously been demonstrated47 to have excellent conelation with measurements 

made using EP A Reference Method 29 of Appendix A to 40 C.F.R. Part 60, 

Determination of Metals Emissions from Stationary Sources, the EPA sees a 

distinct advantage in using this technology for establishing the conelation 

between metal emissions and metal feedrates. For purposes of Veolia's permit, 

the parametric range for the multi-metals CEM S would be equivalent to the HW C 

MAC T emissions standards. However, Veolia may choose to perform a sitespecific sidc-by-side evaluation of the multi-metals CEM S and EPA Reference 

Method 29 to establish an alternate parametric range that demonstrates 

compliance with the HW C MAC T standards, and it may propose to use that 

alternate parametric range to establish a correlation between the OPLs and the 

emission limits. Because the metal concentrations measured by the multi-metals 

CEM S are directly comparable to concentrations by Method 29, EPA does not 

believe that such a site-specific evaluation is necessary. 

During the period in which the multi-metals CEM S is operating, a correlation can 

be determined between the emissions concentration values reported by the multimetals CEM S and the feedrate concentrations reported through feedstream 

analysis. Veolia then will use the data from the multi-metals CEM S as an 

indicator of whether or not the feedrate limits are sufficiently stringent to assure 

* EP A is aware of one commercially available multi-metals CEM S - the Xact Multi-Metals CEM S manufactured 

and distributed by Cooper Environmental Services, LL C (10180 SW Nimbus Avenue, Suite J6, Portland, Portland, 

Oregon 97223). The Xact does not directly measure beryllium, which is one of the regulated metals. The proposed 

permit would require Veolia to estimate beryllium emissions from its feedrate as quantified according to the 

additional feedstream analysis procedures in the permit and the system removal efficiency and exhaust parameters 

used by Veolia to estimate emissions of that metal. 

47 See, for example, http://www.dtic.mil/cgi-bin/GetTRDoc7AD~ADA433778 for the results of one such evaluation. 

VES017295 
Statement ofBasis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Pennittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 55 of 79 

continuous compliance with the metals emissions limits in the HW C MAC T at 

each ofthe combustion units. 

During the 12-month period, Veolia will continue to monitor feedrates using the 

procedures in its FAP and the additional feedstream analysis procedures proposed 

in the Title V permit. In addition, during the 12-month period during which it 

operates the multi-metals CEMS , Veolia will be required to comply with the 

feedrate limits for mercury, LV M and SVM . 

If the data from the multi-metals CEM S show a deviation from the metals 

emissions limits, indicating that Veolia may not be in compliance with a HW C 

MAC T metals emissions limit, Veolia will analyze the feedstream analysis data 

for the waste burned at the time of the deviation and the combustion conditions 

that existed at the time of the deviation to determine why the deviation occurred. 

Veolia will send to EPA within 30 days of the deviation all feedstream analysis 

data for the period of the deviation, its analysis ofthe cause of the deviation, an 

explanation of all corrective actions taken, and the corresponding 12-hour average 

metal concentrations for the period that includes the hour ofthe deviation. 

At any time during or after the period in which Veolia operates the CEM S as a 

parametric monitor of the adequacy of the feedrate limits, Veolia may petition 

E PA to allow it to use the multi-metals CEM S as the primary means of 

demonstrating compliance with the HWC MAC T emissions limits, in lieu of 

complying with the feedrate limits. If Veolia does not petition to use the CEM S 

as the primary means of demonstrating compliance, Veolia may discontinue use 

ofthe CEM S once EPA has sufficient infonnation to verify the efficacy of the 

feedrate limits in assuring compliance with the HW C MAC T emissions limits. 

Under EPA's proposal, the multi-metals CEM S will provide evidence of 

deviations that may demonstrate that the feedrate limits in the Title V permit are 

not stringent enough to assure compliance with the HWC MAC T limits at all 

times. A deviation will not necessarily mean that Veolia has violated a HWC 

MAC T emissions limit, lf data collected through operation of the multi-metals 

CEM S at the time of any deviation, along with analysis of the waste burned and 

the combustion conditions that existed at the time ofthe deviation, reveal that any 

ofthe feedrate limits included in Veolia's permit must be more stringent to assure 

compliance with the applicable emissions limits, EP A will reopen the permit, 

pursuant to 40 C.F.R. § 71.7(f), to either revise the affected feedrate limits or 

require extended or permanent operation ofthe multi-metals CEMS . On the other 

hand, if operation of the multi-metals CEM S reveals that any of the feedrate limits 

included in the permit are more stringent than necessary to assure compliance 

with the applicable emissions limits, Veolia may petition EPA to use the results of 

historical performance tests, feedstream analysis, and CEM S data to establish 

higher feedrate limits for the affected incineration units, provided that Veolia 

VES017296 
Stalement ofBasis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 56 of 79 

demonstrates that compliance would be assured at the higher feedrate limits 

regardless of the waste burned. 

Because the multi-metals CEM S will provide continuous data, Veolia can identify 

deviations from the HWC MAC T emissions limits in near real time and make 

prompt adjustments to process parameters (temperature, oxygen, feed rate, etc.) to 

minimize emissions, as well as analyze the waste data and combustion conditions 

that existed at the time of the deviation. 

E PA believes that one year of data at each incinerator should be sufficient to 

ensure that deviations resulting from any variability in feedstream characteristics 

can adequately be captured. Additionally, Veolia may be able to develop a 

correlation between feedrates and deviations based on the CEM S data. The 

temporary use of the CEMS , in conjunction with the feedstream analysis plan and 

the supplements to the plan proposed in the permit to ensure compliance with the 

feedrate limits should, therefore, confirm that the metal feedrate limits established 

in the permit are adequate to assure compliance with the emissions limits for these 

metals. 

5.3.2. Multi-Metals CEMS and Feedstream Analysis 

Aside from the specific deficiencies discussed above, feedstream analysis 

generally poses several challenges including the uncertainty associated with 1) 

measurement of extremely low metal concentrations in the feedstream (i.e., 

concentrations at or near the detection limit of the measurement device); 2) 

heterogeneity ofthe hazardous waste, which may lead to a non-representative 

sample and hence an inaccurate estimate of the metal feed concentration; and 3) 

inability to demonstrate continuous compliance with MAC T limits since there is 

typically a considerable time lag time between sampling and analysis. 

The uncertainties caused by feedstream analysis can be largely resolved when a 

well-maintained and operated CEM S is used to identify deviations from emissions 

limitations that may result from inaccurate or insufficient feedstream analysis. 

First, unlike feedstream analysis, CEM S provide continuous or semi-continuous 

data. 4 8 This allows the facility to identify the waste being burned at the time a 

deviation occurs, enabling it to detennine the reason for the deviation. 

I x

 Depending on the sampling and analytical technique used by the CEMS , a brief time lag typically exists between 

measurements due to the amount of time needed to collect and analyze each sample and to conduct quality assurance 

checks. For example, Cooper Environmental Services, LLC , Portland, Oregon, has informed EP A that the XactTM 

multi-metals CEM S samples and analyzes simultaneously within the instrument except for the time required to 

advance the tape (about 20 seconds) and the time required for automated quality assurance checks. See XactTM 640 

Multi-Metal Continuous Emissions Monitoring System. Specification Data Sheet. Available at: 

http ://static.pall.com7pdfs/OEM-Media-Membrancs-and-Materials/PGXA CT640EN.pdf. 

VES017297 
Slatement ofBasis For DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Pennittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 57 of 79 

Second, because multi-metals CEM S continuously measure post-combustion 

stack emissions, they are able to capture all deviations that occur during 

combustion of heterogeneous feedstreams. Without a CEMS , many deviations 

resulting from combustion of such heterogeneous feedstreams would go 

undetected. A CEMS can alleviate this concern by giving the facilityinstantaneous data, thus enabling it to make changes that compensate for the 

increased metals in the feedstream before emissions become excessive. 4 9 Titus, 

the facility operator could rely on the instantaneous data to initiate various 

corrective actions before there is a compliance or safety problem. Instantaneous 

data typically gives a facility plenty of time to optimize performance before 

employee or public safety is threatened. 

Third, the use of CEM S has the potential to enable the facility to increase waste 

feedrates by demonstrating that the HWC MAC T limits may not be exceeded at 

higher feedrates. This could be attractive to a facility that wants flexibility in 

feedrates to account for expected or unplanned variability in waste profiles. 

In the context of this Title V permit, EPA is proposing the temporary use of the 

multi-metals CEMS to provide data that will allow verification that the OPLs in 

the permit will assure compliance with the emissions limits in the HWC MACT . 

Because the multi-metals CEM S provides real-time data, Veolia can use the data 

to evaluate whether it is necessary to make adjustments to process parameters 

(temperature, oxygen, feed rate, etc.) to minimize emissions. EPA is not 

proposing to replace the feedstream analysis provisions of the HWC MAC T as 

Veolia must continue to demonstrate compliance with the OPLs in the permit 

through feedstream analysis. 

As further discussed below, the record for EPA's proposed action on Veolia's 

Title V permit renewal application supports the conclusion that the monitoring 

already performed by Veolia does not provide sufficient data for EPA to 

determine that the metal feedrate OPLs proposed by Veolia are stringent enough 

to assure compliance with the HWC MAC T metals emissions limits regardless o f 

the mix of wastes being incinerated or the combustion conditions, given the 

heterogeneity of the waste that Veolia incinerates and EPA's observations on 

Veolia's operating practices. Multi-metals CEM S would provide the data that 

E PA needs to verify the stringency of the metal feedrate OPLs proposed by 

Veolia. 

4 9

 French, N.B. , and Priebe, S J. (1999). Implementing Mercury CEM S in DO E Mixe d Waste Treatment Systems. 

Presented at the WM'9 9 Conference, February 28 - March 4, 1999. Available at 

http://www.wmsym.org/archivcs/1999/32/32-6.pdf (accessed October 16, 2012). 

VES017298 
Statement ofBasis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C , Sauget, Illinois 

Date Issued: October 10, 2014 Page 58 of 79 

5.3.3. Deficiencies in Veolia's Current Emissions Monitoring Procedures 

A. Veolia's October 2013 comprehensive performance tests 

revealed that Veolia's three incineration units have 

significantly different emissions. 

In October 2013, Veolia conducted performance tests on each of its incinerators 

as required by the HWC MAC T regulations. The test results show that emissions 

of mercury were at least 50% higher from Incineration Unit 2 than from 

Incineration Unit 3, despite nearly identical mercury feedrates to Units 2 and 3, s o 

and despite the fact that Units 2 and 3 are nearly identical by design and type of 

emissions control equipment used. Emissions of other metals from Units 2, 3, and 

4 were also significantly different. See Table 9. Therefore, it is not possible to 

assume that emissions data from any one emissions unit are representative of 

emissions from any other unit. To verify actual emission rates from each unit and 

to assure that compliance with the feedrate limits, verified through feedstream 

analysis, is adequate to assure compliance with all applicable requirements, it is 

necessary to separately monitor emissions from each incineration unit. 

B. Veolia's October 2013 comprehensive performance tests on 

Units 2 and 3 demonstrated that the relationship between 

stack concentrations and metal feedrates may not be linear. 

As discussed above, the October 2013 test results showed that, despite nearly 

identical feedrates, emission unit design, and control equipment, stack 

concentrations of mercury and other metals were significantly different from Units 

2 and 3. This illustrates that a simple linear calculation may not be appropriate for 

estimating metal stack concentrations from the emission units. A number of 

factors might be responsible for the test results on Units 2 and 3, including: 

(a) possible interference by other chemical species present in the feedstreams; 

(b) feedstream sampling and analysis enors; 

(c) stack testing errors; 

(d) differences in the mix of wastes as fired; 

(e) differences in incinerator operating parameters (residence time, 

temperature, etc). 

Because of EPA's and Veolia's lack of knowledge about any of these or other 

relevant factors, the temporary use of multi-metals CEM S on each of the 

incinerators is necessary to determine whether compliance with the OPLs in the 

pennit will lead to compliance with the HWC MAC T emissions limits. 

See CPT Report (January 28, 2014) at 1-11 through 1-13. 

VES017299