### May 23,2008 Cheryl L. Newton, Acting Director Air and Radiation Division United States Environmental Protection Agency Region 5 77West Jackson Blvd. Chicago, IL 60604-3590 RE: Veolia ES Technical Solutions, L.L.C. Metals Performance Test Plans for Incinerators 2,3 and 4 Dear Ms. Newton, Pursuant to our agreement, attached is the Metals Performance Test Plan Prepared for the Fixed Hearth lncinerator Number 2 in Accordance with 40 CFR 

### § 63 Subpart EEE, Metals Performance Test Plan Prepared for the Fixed Hearth lncinerator Number 3 in Accordance with 40 CFR 

# 5 63 Subpart EEE and Metals Performance Test Plan Preparedfor the Rotary Kiln lncinerator Number 4 in Accordance with 40 CFR 

### § 63 Subpart EEE. Electronic copies of these plans have been sent to Mr. Charles Hall of 7q 

### your Agency on May 22. Please call me at (618) 271-2804, ext. 101 if you have any questions. Sincerely,
Doug krris General Manager

#7 Mobile Avenue, Sauget, IL 62201 (618) 271-2804 www.veoliaes.comsspq Prepared for: Veolia ES Technical Solutions 7 Mobile Avenue Sauget, IL 62201



# Metals Performance Test Plan Prepared for the Fixed Hearth Incinerator Number 3 

# in Accordance with 

# 40 CFR 

# 5 63 Subpart 

# EEE

ENSR Corporation May 2008 Document No.: 10002-022Prepared for: Veolia ES Technical Solutions 7 Mobile Avenue Sauget, IL 62201



# Metals Performance Test Plan Prepared for the Fixed Hearth Incinerator Number 3 in Accordance with 

# 40 CFR 

# 5 63 Subpart EEE

Reviewed 

### By Craig Doolittle

ENSR Corporation May 2008 Document No.: 10002-022Veolia ES Technical Solutions MACT Performance Test Plan Revision
. 0 Date: May 2008 Section

. Table of Contents Page i of vi 

# Contents

1.0 Introduction

## ................................................................................................................................................ I 1


### .1 Program Summary 140 CFR § 63.1207(f) and § 63.7(c)(2)(i)]

........................................................... 1 1.2 FacilitylUnit Identification

.................................................................................................................... 

### I 1.2.1 General



### .................................................................................................................................. I



### ......................................................... 1.2.2 Facility ID, Mailing Address, and Primary Contacts 

### I 1.2.3 Incinerator Overview

.............................................................................................................. 1 1.3 Purpose and Objectives of the Performance Test

................................ 

### ........................................ 2 1.3.1 General



### .................................................................................................................................. 2 1.4 Performance Test Plan Organization

................................................................................................. 2 2.0 Engineering Description

# ........................................................................................................................... I

............................................................................................................................... 2.1 Process Overview 

### I



### ............................... 2.2 Waste Feed Systems [40 CFR § 63.1207(f)(l)(ii)(c) and (f)(l)(iii)(D) and (E)] 1 2.2.1 Unit 3 Liquid Waste Feed System and Blending Operations

............................................... 1 2.3 Manufacturer. Make and Model of the Incinerator 140 CFR !j 63.1207(f)(l)(iii)(A)]

.......................... 2 2.3.1 Combustion Chamber and Burners [40 CFR §63.1207(f)(l)(iii)(B) and (C)


### ........................2 2.3.2 Secondary Combustion Chamber



### ......................................................................................... 3 2.3.3 Location of Combustion Zone Temperature Device [40 CFR §63.1.207(f)(I)(xix)]

............. 3 2.3.4 Hazardous Waste ResidenceTime [40 CFR §63.1207(f)(l)(ix)]

......................................... 3 2.3.5 Combustion System Leak



### ............................... . ............................................................... 4 2.3.6 Emergency Safety Vent

.................. . 

### .................................................................................. 4 2.4 Proceduresfor Rapidly Stopping HazardousWaste Feed During Equipment Malfunction [40 CFR §63.1207(f)(l)(viii)]



### .............................................................................................................................. 4 2.5 Air Pollution Control Equipment [40 CFR §63.1207(f)(l)(iii)(G)]

....................................................... 4 2.5.1 Air Pollution Control Systems Descriptions

.......................................................................... 4 2.6 Stack Emissions Monitoring[40 CFR §63.1207(f)(l)(iii)(H)]

............................................................. 6 2.6.1 CEM System Description

.................................... ....

### .............................................................. 6



### ......................................................................................................... 2.7 Process Monitoring and Control 7 2.8 AutomaticWaste Feed Cut-off System [40 CFR §63.1207(f)(l)(iii)(F)]



### ............................................ 8

............................. ................................................................. 2.8.1 AWFCO System Testing


### .. 8

................. 2.9 Air Pollution Control Equipment Maintenance Practices [40 CFR §63.1207(f)(l)(iii)(G)] 9 2.9.1 Program Overview

................................................................................................................. 9

................................................ 2.9.2 Test Program Preparation Activities

................................ . 9 3.0 Incinerator Feed Stream Descriptions

# .................................................................................................... I
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3.1 General



### .................................. 

### . ........................................................................................................ 1 3.2 HighVolume Wastes

........................................................................................................................... I 3.2.1 Liquid Wastes

........................ . 

### ......................................................................................... 

### I 3.2.2 Bulk Solids



### ........................................................................................................................ I 3.2.3 Containerized Waste



### ............................................................................................................. I 3.2.4 Gaseous Wastes



### ...................................................................................................................

### I 3.3 Auxiliary Fuels



### ................................................................................................................................... 2
4.0 Performance Test Protocol

# ....................................................................................................................... I

........................................................................................................................... 4.1 General Description I 4.2 Performance Standards



### .................... 

### . ........................................................................................... 1 4.3 Test Conditions [40 CFR

## 5 63.1207(f)(l)(vi) and (vii)]

....................................................................... 1

............................................................................................................................ 4.4 Waste Feed Spiking 1 4.4.1 Inorganic Constituents

........................................................................................................... 2 4.4.2 Spiking for the LVM Category

.................... . .................................................................... 2 4.4.3 Spiking for the SVM Category

............................................................................................... 2 4.4.4 Spiking for Mercury

................ 

### . ......................................................................................... 2 4.5 Metals Extrapolation IMethod



### ........................................................................................................... 3 4.6 Description.Preparation and Delivery of Feeds for the Performance Test [40 CFR 

## 5 63.1207 (f)(l )(vi) and (vii)]



### ............................................................................................................................... 3 4.7 Conditioning Time Needed to Reach Steady State [40 CFR

## 5 63.1207(f)(l)(xii)]

............................ 3 4.8 Anticipated Test Schedule

.......................... . 

### ................................................................................... 3 4.9 Performance Test Reporting

............................................................................................................... 4 5.0 Sampling and Analytical Program Quality AssurancelQuality Control 

## ............................................. I 5.1 Title Page

........................................................................................................................................... 2 5.1.1 Project Title

........................ . 

### ............................................................................................. 2 5.1.2 Expected Performance Test Date



### ......................................................................................... 2 5.1.3 ProjectApprovals

.....................

## .. ...................................................................................... 2 5.2 Table of Contents

................................................................................................................................ 3

. .



### ........................................................................................ ............................. 5.3 Project Descrlpt~on

.. 3

............................................................................................................................ 5.4 Project Organization 3 5.4.1 QA Officer's Responsibilities

................................................................................................. 3 5.4.2 Laboratory Coordinator Responsibilities

............................................................................... 3 5.5 QAIQC Program Objectives



### ................................................................................................................ 4 5.5.1 Precision,Accuracy and Completeness

............................ 

### .. ............................................ 4 5.5.2 Representativeness and Comparability

.............................................................................. 4 5.5.3 Method Detection Limit (MDL) Determinations

................................................................. 5
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................................................................................................ 5.6 Sampling and Monitoring Procedures 5

..................................................................................................... 5.6.1 Field Program Description 5

................................................................................ 

### ................. 5.6.2 Pre-samplingActivities

... 5 5.6.3 Sampling Locations



### ............................................................................................................... 7 5.6.4 Waste Feed Stream Sampling Procedures



### ........................................................................ 7

.............................................................................. 5.6.5 Stack Sampling IVlethodologies

.... . 7



### ............................................................................ 5.7 Sample Handling. Traceability and HoldingTimes 8 5.8 Analytical Methods and Calibration Procedures



### ................................ . ........................................... 9

.......................................................................................... 5.8.1 Analysis of Waste Feed Streams 9

............................. 5.8.2 Analysis of Stack Gas Samples

. ..........................................................9

......................................................................................................................... 5.9 Internal QA Program I0

............................. 5.9.1 Data Collection and Sampling QC Procedures

.. .............................. I0

........................ 5.9.2 Analytical QC Procedures for Samples to beAnalyzed in the Laboratory 11 5.10 Data Reduction. Verification and Data Reporting



### ........................................................................ I

........................................................................................................... 5.10.1 Field Data Reduction 11



### ................................................................................. 5.10.2 Laboratory Analysis Data Reduction 12

................................................................................................................... 5.10.3 DataVerification 12

...................................................................................... 5.10.4 Final Data Reporting

............... 

## . 13 5.1 1 Routine Maintenance Procedures and Schedules

............ . ...... 

### . ............................................... 13



### .................................................................... 5.1 1

.1 Field Sampling Equipment

........................ 

## . 14

........................................................ 5.11.2 Facility Equipment and Instrumentation

................. . 14



### ..................................................................................................... 5.1 2 QAlQC Assessment Procedures 14

5.12.1 Accuracy

...........................

### ... 14



### ........................................................................................

........................................................................................ 5.1 2.2 Precision

.............................. 15

...................................................................................................................... 5.12.3 Completeness 15 5.1 3 ExternalQA Program



### ........................................................................................................................ 15



### ........................................................................................................... 5.1 3.1 Performance Audits 15



### .............................................. 

### ....................................................... 5.13.2 Corrective Action


### ..... 16

..................................................................... 5.13.3 Quality Assurance Reports to Management 17

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## List of Appe~idices Appendix A Unit 3 Process Flow Diagram Appendix 

### B Field Data Sample Collection Forms Appendix C lsokinetic Sampling Train Setup and Recovery Schematics

Q:\mw97\Projects\l0002022\Veol1a PerformanceTest Plan U3 R2-05210B.doc

### Veolia ES 

### Technical Solutions MACT PerformanceTest Plan Revision: 0 

### Date: May 2008 

### Section: Table of Contents Pagev of vi 

## List of 

## Tables
Table 1-1 Summary of Applicable MACT Emission Standards

......................................................................... 

### 3 Table 1-2 Cross Referenceof PerformanceTest Requirements

.................................................................... 

### 4 Table 2-1 Unit 3 Continuous Emission Monitors



### ................................................................................................7 

### Table 2-2 Technical Information Summary on Incinerator No


### . 3


### .....................................................................I0 Table 2-3 CurrentAWFCO Parameters and Limits for Incinerator No

. 

### 3

...................................... 

### 11 Table 3-1 Top Volume Liquid Waste Streams


### ................................................................................................... 3 Table 3-2 Top Bulk Solid Waste Streams


### ........................................................................................................... 3 Table 3-3 Top Containerized Solid Waste Streams

........................................................................................... 

### 4 Table 3-4 Summary of Major HAPSProcessed


### ............................................................................................... 4 Table 3-5 Typical Properties for Supplemental Fuel Oil

.................................................................................... 5 Table 3-6 Typical Properties for Natural Gas

............................... . 

### ................................................................. 5 Table 4-1 MACT OPLs to be Established During the PerformanceTest

.......................................................... 

### 5 Table 4-2 Metals Evaluation Plan

....................................................................................................................... 

### 6 Table 4-3 Anticipated PerformanceTest Schedule

........................................................................................... 7 

### Table 5-1 General Sampling and Analytical Program Overview (Stack Exhaust)



### ........................................ 18 Table 5-2 QA Objectives for Field Measurements



### ........................................................................................... 19 Table 5-3 Overall Summary of PerformanceTest Stack Gas Sampling and Analysis Program

.................... 

### 20 Table 5-4 Traverse Point Locations

................................................................................................................. 21 Table 5-5 Sample Preservation and Holding Time Requirements

.............................. 

### . ............................... 22 Table 5-6 QA Requirements for Metals in Stack Gas by ICAP or ICP-MS

................................................... 

### 23

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## List of Figures

..................................... ..................................................................... Figure 5-1 Stack Sampling Locations

. 24

....................................................................................................... Figure 5-2 Example Sample Packing List 25

Q:\mw97\Projects\l0002022\Veolia Performance Test Plan U3 R2-052108.docA"a Veolia ESTechnical Solutions MACT Performance Plan Revision: 0 Date: May 2008 Section: 1.0

Page 1 of 4 

## 1.0 

## Introduction

1.I Program Summary [40 CFR 

# 9 63.1207(f)and 

# 9 63.7(c)(2)(i)] This document is the Performance Test Plan for lncinerator No. 3 operated by Veolia ES Technical Solutions (Veolia) at its Sauget, Illinois facility. Since the Veolia incinerator treats certain waste that are classified as hazardous under state and/or federal regulations, this unit is subject to the requirementsof the HWC MACT Rule. This Plan has been prepared in accordance with requirements initially promulgated in NESHAPS: Final Standards for Hazardous Waste Air Pollutantsfor Hazardous Waste Combustors, (generally referredto as the Hazardous Waste Combustor [or "HWC"] MACT Rule). These regulations were initially published by US EPA on September 30, 1999 in 40 CFR § 63 Subpart EEE. However, these initial regulations were vacated based on a DC Circuit Court ruling, were subsequently replaced by "Interim Standards" in Februaryof 2002 and then re-promulgated again in the Permanent Replacements Standards published in the Federal Registeron October 12, 2005. This document addressesthe requirementsto develop and submit a Performance Test Plan set forth in 40 CFR § 63.1207. This PerformanceTest Plan is written to address all applicable Subpart EEE (and General Provisions) requirements incorporated into the regulations through promulgation of the Final Replacement Standards published in the Federal Registeron October 12, 2005. 

### 1.2 FacilitylUnit Identification I

.2.1 

### General As mentioned above, this PerformanceTest Plan has been developed to evaluate the incineratorat the Veolia facility in Sauget, IL. This is a commercial hazardous waste incineration facility that treats liquid, solid and gaseous wastes that are classifiedas both hazardous and non-hazardous. 

### 1.2.2 

### Facility ID, Mailing Address, and Primary Contacts The facility address is: The facility contact is: Veolia ES Technical Solutions Mr. Dave Klarich 7 MobileAvenue Phone: 361 -572-231 7 Sauget, IL 62201 Email: 

### David.Klarich@veolraes.com Fac~lity ID#: lLD098642424 

### 1.2.3 

### lncinerator Overview This Veolia incinerator is a fixed hearth incineration systemwlth primary and secondary combustion chambers that treats solid wastes as well as aqueous and organic liquids. The process is monitored and controlled by a distributed control system (DCS) capable of continuously monitoringthe process to assure all opetational parameters are within regulatory and permit limits while waste is being fed to the unit. In addition, this incinerator is equipped with a Continuous Emissions Monitoring System (CEMS) that continuously samples the exhaust gases for oxygen and carbon monoxide in the stack gas exhaust stream.
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Page 2 of 4


### 1.3 Purpose and Objectives of the Performance Test 1.3.1 

### General The purpose of the performance test is to validate the performance level of the incineratoragainst the requirements in 

### 40 CFR Part 63, Subpart 

### EEE. To this end, the specific objectives of this performance test are to: Demonstratethat the emissions from the incinerator meet the HWC MACT emission limits while treating hazardous waste for the parameters being tested. Collect monitoring data in order to re-establish operating parameter limits (OPLs)or set new OPLs on key operating variables that will ensure that the incinerator operates within the HWC MACT emission limits while treating hazardous waste. Utilize an extrapolation procedure, as appropriate,to establish metalsfeed rate limits. The test program will include feeding a variety of liquid and solid waste materialsto the incinerator, sampling and analyzing the feed streams, monitoring certain process parameters and conducting emissions testing. The emissions standards that will be evaluated under the HWC MACT regulations are summarized in Table 1-1. 

### 1.4 Performance Test Plan Organization This test plan has been organized in a format typically used for compliance demonstration test programs. Table 1-2 is includedso that the performance test requirements in the HWC MACT rule can be crossreferenced with the sections in this Plan. The remainderof the document has been organized as follows: Section 2.0 provides a general physical description of the fixed hearth incineration system and associated unit operations (includingthe air pollution control system) as well as an overview of the automatic waste feed cutoff (AWFCO) system and maintenance procedures. Section 3.0 presentsa brief discussion of the wastes to be treated in terms of physical and chemical parameters which impact thermal oxidation and summarizes the hazardous air pollutants presently identified in the waste streams. Section 4.0 presents the Test Protocol including planned feed and test conditions, rationale for the test design, anticipatedtest schedule and final report format. Section 5.0 fully describes all sampling and analysis procedures and associated QNQC protocols following the latest EPA guidance. This section essentially serves as the Quality Assurance Project Plan (QAPP) for this project. The Appendices contain Process Flow Diagrams (AppendixA), examples of performance test field data sheets and test equipment calibration (Appendix 

### B); and isokinetic sample train setup and recovery forms (Appendix C).

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Page 3 of 4


### Table 1-1 

### Summary of Applicable MACT EmissionStandards

Q\mw97\Pro~ects\l0002022\Veolia Performance Test Plan U3 R2-052108.doc Emissions Parameter Mercury Semivolatile Metals (SVM) (Cadmiumand Lead) Low Volatile Metals (LVM) (Arsenic, Beryllium and Chromium) Note: All emission concentrations are correctedto 7% oxygen. Limit 5 130 pgldscm 1230pgldscm

5 92 pg/dscm Citation 40 CFR 

## 5 63.121 9(a)(2) 40 CFR 

## 5 63.121 9(a)(3) 40 CFR 

## 5 63.1219(a)(4)Revision: 0 Date: May 2008 Section: 1.0 Veolia ESTechnical Solutions MACT Performance Plan Page 4 of 4
Table 

### 1-2 Cross Reference of Performance Test Requirements

Q:\mw97\Projects\l0002022\VeoliaPerformanceTestPlan U3 R2_052108doc Topic Program Summary Test schedule Data Quality Objectives (DQOs) Internal and External Quality Assurance Plan Analysis of feedstreams (as fired) Heating value, ash content, semi-volatile metals. low volatile metals, mercury and total chlorine Viscosity Identification and quantification of reasonably expected HAPS Detailed engineering description of combustor Manufacturerlmakelmodelof HWC Type of HWC Maximum design capacity Feed systems Locationof combustion zone temperature device Hazardous waste AWFCO system Design, operation and maintenance of APC Justificationof alternative gas flow rate measurement technique Design, operation and maintenance of stack gas monitoring systems Descriptionof Waste handling and blending Operations Detailed test protocol including: Description of sampling, monitoring and analytical procedures Descriptionof Planned Feed and Operating conditions during the PerformanceTest Procedures for rapidly stopping hazardous waste feed and controlling emissions during malfunction Determinationof hazardous waste residence time Metalfeed rate l~mit extrapolation (if used) Documentationof expected levels of regulated constituents in other feed streams that are not analyzed Documentationof conditioning time needed to reach steady state prior to testing Alternative monitoring frequency for wet scrubbers (if used) Other information deemed necessary by the agency Regulatory Citation 40 CFR § 63.1207(f) and 

### 5 63.7(c)(2)(i) 40 CFR 

### 5 63.1207(f), (f)(l)(v) and

### 3 63,7(c)(2)(i) 40 CFR § 63.1207(f) and § 63.7(c)(2)(i) 40 CFR § 63.1207(f) and !j63.7(c)(2j(i) 40 CFR § 63.1207(f)(l )(i) 40 CFR § 63.1207(f)(l)(i)(A) 40 CFR § 63.1207(f)(l)(i)(B) 40 CFR § 63.1207(f)(l)(ii)(A) & (B)
40 CFR § 63.1207(f)(l)(ii1)(A) 40 CFR § 63.1207(f)(l)(iii)(B) 40 CFR § 63.1207(f)(l)(iii)(C) 40 CFR § 63.1207(f)(l)(ii1)(D) & (E) 40 CFR § 63.1207(f)(l)(xix) 40 CFR § 63.1207(f)(l)(ii1)(F) 40 CFR § 63.1207(f)(I)(lii)(G) 40 CFR § 63.1207(f)(l)(xvii) 40 CFR 

### 3 63.1207(f)(I)(iii)(H) 40 CFR § 63.1207(f)(l)(ii)(C)
40 CFR 

### 5 63.1207(f)(l)(iv) 40 CFR 

### 5 63.1207(f)(l)(vi) & (vii) 40 CFR 

### 5 63.1207(f)(l)(viii) 40 CFR § 63.1207(f)(l)(ix) 40 CFR § 63.1207(f)(l)(x) 40 CFR 

### 5 63.1207(f)(I)(xi)
40 CFR 

### 5 63.1207(f)(l)(xii) 40 CFR 

### 5 63.1207(f)(l)(x~ii) 40 CFR 

### 5 63.1207(f)(l)(xxvii) Section No. inthis Document 1.1 4.7 5.5 5.9 & 5.13 3.0

2.0 22 2.2 2.2 2.3 2.2.6 2.5.1 2.4.1 1

NIA 2.6 2.3.5
5.6& 5.8 4.3, 4.4 & 4.5 2.3.6 2.2.7 4.4.2 3.0
4.6 N/Ap--. I Veolia ES Technical Solutions MACT Performance Test Plan Revision: 0 Date: May 2008 Section: 2.0 Page 1of 11 

## 2.0 Engineering Description

2.1 Process Overview Veolia operates2 Fixed Hearth Dual Chambered Incinerators (Units 2 and 3) and one rotary kiln incinerator (Unit 4) at the Sauget, ILfacility. The two fixed hearth units are rated at 16 million Btulhr each. Incineratton Unit No. 3 is a mirror image of Unit IVo. 2. Both of these units have their own waste handling systems as described in the sections that follow. The only difference being Unit No. 2 is equipped with four (4) baghouse modules, while Unit No. 3 is equipped with three 

### (3) baghouse modules. However, each incinerator is operated identically with only three baghouse modules in service during operation. 

### 2.2 Waste FeedSystems [40 CFR 

### § 63.1207(f)(I)(ii)(c) and (f)(l)(iii)(D) and 

### (E)] 2.2.1 

### Unit 3 

### LiquidWaste Feed System and Blending Operations The fixed hearth incinerator is designed to receive containers, aqueous liquid wastes, organic liquid wastes, specialty liquidfeeds and direct inject liquidsfed through the aqueous or organic liquid feed systems. These units can receive any combination of wastes 

### -- liquid, semi-solid or solid --with a heat value of up to 16 million Btuthr. Unit 3 is supported by storagetblendtanks located in Tank Farm #I. Rates of feed are controlled at each incinerator. Segregated liquid wastes are stored untll utllized in the waste blending facilities. At that t~me, liquids are deliveredto the blendingtanks where the daily liquidfeed to the incinerator is formulated, tested, and releasedto the lnclnerator. Blending of stored liquid wastes to achieve optimum heating value and viscosity for Incineration takes place in Tanks 2, 4, 6 

### & 8. SIXadditional tanks (1 0, 20, 30, 40, 50 

### & 60) are used to segregate differentwaste stream types for blending of liquid feed to the incinerator. Several criteria are important ~n designinga blend from 

### available wastes that have been segregated principally by physical and chemical properties These include compatibility, proper range of heating value, and permit restrictions regarding elemental composition (based on emission limitations). The material IS transferred through aboveground pipelines from the tank farm to the incinerator Pipelines usedto transfer liqu~d organic waste and aqueous waste are equipped with strainers In compliance with the Benzene NESHAP, all tanks are vented to individual carbon adsorption canisters for removalof organics before vapor is dischargedto the atmosphere. Each carbon adsorber canister is essentially equivalentto a 55 gallon container or greater, if necessary. All tanks are equipped with conservation vents, in additionto the carbon canister adsorber. All tanks are grounded, and flame arrestors are ~nstalled betweenthe carbon adsorbers and the tanks. 2.2.1.1 

### Organic and Aqueous Liquid Waste Feeds The liquid waste injectors used in the combustion chambers are air-atomizing injectors. These are used for injection of high Btu, low Btu liquids and specialty feed liquids. Dual fluid injection nozzles will be used for atomizationof the waste. Each of the injectors is rated at 0-300 gph. The liquid waste feed nozzles are served by parallel redundant pumps and recirculationsystems with back pressure control.

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2.2.1.2 Packaged and BulkSolid Containersof wastes are sampled and analyzed after receipt in accordance with the facility's Waste Analysis Plan. These wastes can then be delivered directly to Unit 3 or repacked into small combustible containers at the facility. Fiberboardor plastic containers (fully or partially full of waste), up to 40-gallon size, may be charged directly to the primary chamber. These will be received at the dock adjoining each fixed hearth incinerator, and charged to the incinerator within 24 hours or returned to permitted storage. Solids, usually packaged in plastic or fiberboard containers, are introduced into the incinerator through a PLC controlled airlock-ramsystem located at the lower front of the primary chamber of the incinerator. The airlock is composed of a refractory-lineddoor, a door into the airlock enclosure, and two pneumatic rams. The action of the feeder is as follows:

a With the incinerator door closed, the airlock door is opened.

a The first pneumatic ram (load ram) pushes weighed charges of waste into the airlock chamber.

a The airlock door is closed.

a A switch is activated either automaticallyor manually, which opens the door to the incinerator and actuates the ram (charge ram) that pushes the waste into the incinerator. The ram then retracts and the incinerator door closes. 

### r"" 2.2.1.3 Specialty Liquid Feeds and Gases Specialty Feed Systems associated with lncinerator No. 3 are as follows Hooded Specialty Container Feeder Glove Box Emission Control Systems Direct Inject Liquid Feed System 

### 2.3 Manufacturer, Make and IVlodel of the lncinerator [40 CFR 

# 5 63.1207(f)(l)(iii)(A)] 2.3.1 Combustion Chamber and Burners [40 CFR §63.1207(f)(l)(iii)(B)and (C) lncinerator IVo. 3 features a two-stage combustion process. Ignition of waste material takes place in the primary (lower) combustion chamber (PCC). A secondary (upper) combustion chamber (SCC) serves as an "after-burner"for process gases. lgnition of the waste takes place at temperatures in excess of 1700 degrees F. The secondary combustion chamber maintains a minimum temperature of approximately 1800 degrees 

### F. The fixed hearth incinerator is fabricated of carbon steel. The primary chamber has an external diameter of 9 feet and is 17.5 feet long. The interior walls of the chamber are lined with approximately 10 inches of brick refractory and insulation backing, making the internal operating diameter approximately 7'2". The crosssectional area of the chamber is thus 40.3 square feet. Table 2-2 provides a summary of the incinerator design specifications. Liquid and solid waste feeds enter the lower chamber on the front-face of the chamber. The primary burner 

### ic"". and the specialty feed injector are located near the front-face of the chamber and are mountedtangentially.

Q:\mw97\Projects\l0002022\VeoliaPerformanceTest Plan U3 R2-052108.docRevision: 0
P-. : I Date: May 2008 Section: 2.0 Veolia ESTechnical Solutions MACT Performance Test Plan Page 3 of 11 The primary burner is a North American burner rated at 12.0million Btulhr. and is used in the lower chamber to maintain permitted temperatures. It will burn only natural gas or No. 2 fuel oil. The burner system is supplied with combustion

### air at a static pressure of 30 water column (WC). The pilot for the primary burner will burn natural gas. The fuel systemfor the lower chamber (and secondary combustion chamber) is controlled by a Factory Mutual approved burner management system complete with interlocks and safety valves. 

### 2.3.2 Secondary Combustion Chamber The secondary combustion chamber (SCC) is a horizontal, cylindrical chamber that has an external diameter of 9 feet and is 17.5 feet long. The interior walls of the chamber are lined with approximately 10 inches of brick refractory and insulation backing, making the internal operating diameter approximately 7'2". The cross-sectional area of the chamber is thus 40.3 square feet. Following ignition of the waste material under controlled or starved-air conditions in the lower chamber, offgases travel through a refractory-lined flue gas passage into the upper chamber, which acts as an afterburner. Turbulence is achieved by the tangential introduction of air and additional fuel in the upper chamber. The SCC is equipped with one burner mounted tangentially on the side of the chamber. The burner is a North American burner rated at 6.0 million Btulhr and is fueled with natural gas or fuel oil. ./- As with the primary chamber burner, the SCC burner is supplied with atomizing air and is equipped with a burner managementsystem. This system controls the ignition and initiatesan automatic shutoff when there is a loss of flame, combustion air supply, fuel pressure, atomizing air pressure, or pilot burner. Leaving the upper chamber, the hot gas stream travels through 28 feet of refractory-linedstack sections before reaching the start of the gas scrubbing system. The combined volume of the upper and lower chambers, the flue gas passage and the hot crossover section is approximately 1,567cubic feet. The total retention time of combustion gases within the system is approximately 5 seconds. 

### 2.3.3 Locationof Combustion Zone Temperature Device [40 CFR $i63.1207(f)(l)(xix)] The thermocouplethat monitors temperature in the primary combustion chamber is locatedon top of the chamber about five feet from the transition. The thermocouple that monitors temperature inthe SCC is located on top of the chamber above the transition. 

### 2.3.4 Hazardous Waste Residence Time [40 CFR $i63.1207(f)(I)(ix)] The Hazardous waste gas residence time for the Fixed Hearth Incineratoris calculated as follows: Primary Combustion Chamber Volume 

## -635 ft3 Secondary Combustion Chamber Volume 

### -635 ft3 Total Volume 

### - 1270ft3 Maximum Flue Gas Flowrate 

### - 17,382 acfm (290 ft3/sec) Total Combustion Zone Residence Time = (1270ft3)/(290 ft3/sec)= 4.4 sec

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### 'I Section: 2.0 Veolia ES Technical Solutions MACT PerformanceTest Plan Page 4 

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### 2.3.5 Combustion System Leak Combustion system leaks are prevented through maintaininga totally sealed combustion chamber, coupled with the use of an induced draft fan that maintainsa vacuum of normally

## - 4 

### to 

### - 6 

### inchesof water column in both combustion chambers while wastes are beingfed to the unit. 

### 2.3.6 Emergency Safety Vent The incinerator is equippedwith an emergency safetyvent (ESV) located at the top of the secondary combustion chamber. This ESV is a refractory-lined emergency thermal relief vent (TRV) which is held in the closed position by a pneumatic cylinder. The control valve in the line supplying air to the cylinder and the cylinder vent valve which opens the TRV are located in the control room for each unit. Valve locks (with keys attached) are utilizedto deter indiscriminate operation of these valves. Opening of the TRV allows hot combustion gas to vent from the combustion system during emergency shutdown events The purposeof the TRV is to protect the downstream APCS from excessive temperature situations. A limit switch on the TRV shuts off all waste feeds to the system as it sensesthat the cap is opening. 

### 2.4 Proceduresfor Rapidly Stopping Hazardous Waste Feed During Equipment Malfunction [40 CFR §63.1207(f)(I)(viii)] Equipment malfunctions are identified by the control system, observationof process control variables, or by regular field inspections. Inthe event of minor equipment malfunctions (e.g. waste feed or scrubber leaks), the control room operator will be notified by radio. The control room operatorwill then disable the waste feed pumps and close the waste feed valves. In the event of major equipment malfunctions (e.g. fire), the emergency stop button located in the control room will be pushed. If this button is pushed, all equipment will switch to its fall-safe position. 

### 2.5 Air Pollution Control Equipment [40 CFR §63.1207(f)(I)(iii)(G)] 2.5.1 Air Pollution Control Systems Descriptions The air pollution control system consists of a spray dryer absorber and fabric filter baghouse. The air pollution control system neutralizes acidic compounds and removes particulate from the exhaust gas. Two subsystems, the spray dryer absorber and the fabricfilter, carry out the chemical neutralization and particulate removalfunctions, respectively. A third subsystem, the lime system, is used to prepare and provide lime slurry to the spray dryer absorberfor use in the chemical neutralization process. The induced draft fan and stack provide the mechanical energy requiredto transportthe flue gas through the interconnectingductwork, to its eventual discharge pointto atmosphere. 2.5.1 .I Lime System 

### The lime system prepares lime slurry for use in the chemical neutralization process in sufficient supply and concentration to maintain continuous flue gas treatment in the spray dryer absorber. The system has been designed for batch mixingto provide this service. /-

Q:\mw97\Pro~ects\l0002022\Veolia PerformanceTest Plan U3 R2-052108,docVeolia ES Technical Solutions MACT PerformanceTest Plan Revision: 0 Date: IWay2008 Section: 2.0 Page5 of 11 Hydrated lime is stored in a storage bin above the lime preparation area. The storage bin is sized to hold enough hydrated lime to maintain several days of system operation at the maximum combustion rate of the incinerator. Lime is discharged through the conical storage bin bottom. The flow of the material from the bin is aided by a vibrating "live bottom," or bin activator. A variable speed screw feeder is used to meterthe hydrated lime in the proportions required for batch mixing lime slurry. The lime is mixed with water in a tank beneaththe lime storage bin The screw feeder speed and the rate that water is added to the lime slurry tank are variable so that the desired lime solids concentrat~on can be achieved in the tank. The variable feed adjustments allow water and limeto be added to the lime slurry tank at a rate that will allow a batch mode of mixing. An agitator is provided in the slurry tank to mix the water and lime and to maintain the suspension of lime solids. The mixed lime slurry is pumped at a continuous rate of flow through a 

### recirculation loop to the atomizer. 2.5.1.2 Spray 

### Dry Absorber Unit 

### 3 is equipped with a Spray Dryer Absorber (SDA) located immediately downstream of the secondary combustion chamber. The SDA unit is fabricated of 318 inch carbon steel. The function of the SDA is to: Further cool the combustion gases from 1600-2000oFto 300-500oF, Neutralize and remove HCI and other acids from the combustion gases, Remove a portion of the particulate (fly ash) from these gases. Slurry flow to the spray dryer absorber (SDA) is metered by a flow control valve to obtain the proper feed concentrationto the spray dryer absorber atomizer. Automatic (or manual) adjustment to the flow is made as a function of the output from a hydrochloric acid (HCI) analyzer in the gas duct downstream of the fabric filter. The amount of slurry metered is proportional to the amount of HCI monitored. The slurry passes through a stationary swirl-type liquid distributor into the atomizer wheel where induced centrifugal force from the rapidly spinning wheel dischargesthe slurry through the wheel nozzles at high velocity. The design of the atomizer wheel, its rate of spin, and the discharge velocity of the slurry, create a cloud of finely divided droplets around the periphery of the atomizer wheel. A feedback signal from the atomizer power transmitter provides verification that water flow to the atomizer increases or decreases in proportion to the spray dryer absorber outlet temperature. Flue gas enters from the bottom of the spray dryer absorber through a vertical, centrally located disperser. The disperser directsthe flue gas through the zone f~lled by the atomized slurry cloud where the flue gas and slurry mix and most of the absorption occurs. The gases then flow downward through the absorber chamber and exit through a bottom side duct. As the gases contact and pass through the cloud of atomized lime slurry, thewater in the slurry evaporates, cooling the gases. Simultaneously, the lime in the slurry reacts with the hydrogen chloride in the gases to produce calcium salts. Some of the resulting dry material, consisting of calcium salts, fly ash and excess lime, falls to the conical bottom of the unit. The dry material from each unit is discharged to a conveyor system which transports it to a dump trailer or equivalent type system. 2.5.1.3 Fabric Filter Gas exhaustedfrom the spray dryer absorber is distributed by manifold ducts to three fabric fllter modules. Within each filter module,the gas is passed through Teflon-coated fiberglass cloth bags. The gas passes from

,.,#- the outside to the inside of the filter bags. Particulate, entrained in the gas stream, is mechanically deposited on the outside of the filter bags as the gas passes throughthe cloth.

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Each module has a clean air plenum and housing section to contain approximately 96 bags. Each bag is approximately 6" in diameter by 20' long. The baghouses are fabricated from 3/16" mild steel plate, of welded construction,gas tight and stiffened to withstand the maximum operating negative pressure. Each compartment has a tube sheet that supports the bags and provides for top baglcage removal. Access to the clean air plenum is via a side access door in the clean air plenum. The fabric filter cleaning mechanism utilizesjets of air to clean the filter bags. Periodically,the cleaning sequence will be initiated. The sequence is either started at the end of a timed cycle, or when the differential pressure across the filter reaches a predeterminedsetpoint of approximately 7.0" w.c., or when the operator initiates a cycle. The controller then sequences to each row offilter bags in each module, releasing a burst of air opposite to the direction of gas flow. The quickly released burst of air dislodges dust cake on the exterior of each bagas it travels from the top to the bottom of the bags. Released from the bag, the dust cake falls by gravity into the hopper at the bottom of the module. From there it is dischargedto a conveyor system which transports it to a dump trader, or equivalent type system Treated by the spray dryer absorber and filtered by the fabric filter, the cleaned flue gas exits the Fabric filter modules to an outlet manifold for exhaust. 

### 2.5.1.4 Induced Draft Fan and Stack The induced draft fan and stack are located downstream of the fabric filter. Combustion gases are drawn through the system by a 75 hp induced draft (ID) fan, rated at 15,000 acfm at 400' F saturated, and 22" water column pressure. The induced draft fan providesthe mechanism for transporting the incinerator flue gas through the spray dryer absorber, Fabricfilter, and all interconnecting ducts. The ID fan includes an inlet volume control damper to be used to control the velocity of the gas within the ducting and treatment dev~ces. Treated gasses exhausted from the induced draft fan to the atmosphere through a 904. high stack. The stack diameter is 39 inches I.D. The stack is equipped with instrument sampling ports and a sampling platform for emissionstesting. Figure 5-1 provides details on the des~gn and sample port locations and configurations. 

### 2.6 Stack 

### Emissions Monitoring [40 CFR 

### §63.1207(f)(I)(iii)(H)] The continuous emissions monitoring (CEM) system consists of sample probes, sample delivery and conditioning apparatus,and gas analyzers. Samples are extracted from the transition ducting located between the scrubber and stack. A CEM performance test and quality assurance program has been implemented in accordancewith 

### Performance Specifications for Continuous Emission Monitoring of Carbon Monoxide and Oxygen for Incinerators, Boilers and Industrial Furnaces Burning HazardousWaste, as defined in 40 CFR 266, Appendix IX, Section 2.1. Responses from each CEMS will be fed to the Control System (CS) where the CO hourly rolling average is calculatedand interlockedto the waste feed cutoff valves as part of the Automatic Waste Feed Cutoff System (AWFCO) discussed in Section 2.8, below. The following provides a brief descriptionof the CEMS instruments including the operating range and measurement principal. 

### 2.6.1 CEM System Description The Continuous Emissions Monitoring Systems (CEMS) currently being utilized at Incinerator 3 analyzes for opacity, carbon monoxide, hydrogen chloride, total hydrocarbonsand oxygen. These monitors, except f- opacity, are extractive devices mounted in sampling ports on the stack. The table below summarizes the analyzer specifications.

Q imw97iProjects\l0002022\VeoliaPerformanceTest Plan U3 R2-052108.docRevision: 0 ,#-. Date: May 2008 Section: 2.0 Veolia ES Techn~cal Solut~ons MACT Performance Test Plan Page 7 of 11 The opacity monitor continuously measures the stack gas opacity and reportsthe measurementsto an indicator and a recorder. An opacity that exceeds a preset limit triggers an alarm and interlock. Carbon monoxideand hydrogen chloride are monitored with extractive non-disperse infrared analyzers. Total hydrocarbon is monitored with an extractive flame ion detector analyzer. Oxygen is monitored with a zirconium oxide cell, Stack gas flow rate is continuously monitored using an anubar that sends a 4-20 mA signal to the PLC which converts the signalto acfm. Table 

### 2-1 Unit 

### 3 Continuous Emission Monitors



### 2.7 Process Monitoringand Control The facility is equippedwith a state-of-the-art monitoring and control system, which facilitates compliance with permit conditions,and otherwise, collects process control information, facilitates efficient operation and detects and prevents damage to thefacility. The system consists of three major components,

a A human-machine interface (HMI) system,
a Programmable logic controller's (PLC's), and Parameter Ox~gen Carbon Monoxide Total hydrocarbons Hydrogen chloride Opacity Stack gas flow

2.7.1 .I A highspeed ethernet cable connects all control system components Range 0-25% 0-200 ppmv 0-3000 ppmv 0-100 ppmv 0-1,000 ppmv 0-1 00% 0-20,000 acfm Current Mfg. COSA Ecochem MC3 Thermoelectron Ecochem MC3 Teledyne PSEIRosemount

The desired control functions are implemented through the HMI system. All digital control and emergency interlocks are accomplished by the PLC. Principle Electrochemical lnfrared FIDIlnfrared

lnfrared White light Pressure drop

The control system is capable of monitoring the "operational envelope" of the incinerator and is capable of performing a number of activities including:

a Control room indicationof processor sensors located within the incinerator system (such as pressure indicationof a field installed pressuretransmitter); Process controller for single instrument loops or an indiv~dual sub-system, such as a pressure control loop involving a sensor reading from one pressure transmitter affectingthe function of one pressure control valve; and
a Alarm for an exceedance of a designated setpoint, such as a high pressure or low temperature.

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The process control computer will continuously control and monitorthe operation of the incinerator. When out-of-range conditions exist, itwill notifythe operator of those conditions. The process control computer is programmedto shut-down equipment (i.e., bring the system into a safe mode) when designated parameters are exceeded,which is a protective mechanism against potential equipment damage, operation outside of permit limits, or conditions that might leadto a releaseto the environment. Continuous monitoring of the incineratorand scrubber system is an important aspect of the system design. A digital readout of all monitoring instrumentationis displayed on the main control screen. An audible and visual alarm alertsthe incinerator operatorto significant deviations from normal operating conditions. This system allows an immediate responseto adverse conditions by the operator. Automatic waste feed cut-off and incineration shutdown mechanismsare also interlocked with the monitoring system at or prior to reaching permit limit levels. Monitoring methods and calibration frequencies are listed in Table 2-3. The Incineratorhas an independent process control computer that interfacesto the Quantum Progammable controllers The process computer is capable of controlling the incinerator in case of a failure in a computer. This computer runs a RSVIEW HMI control software that provides operator interfaceto all instrumentation and controls. 

### 2.8 Automatic Waste Feed Cut-off System [40 CFR 563.1207(f)(l)(iii)(F)] The incinerator has an Automatic Waste Feed Cut-Off (AWFCO) System that will shut waste feeds off in the event certain operating parameters deviate from allowable set points. The PLC continuously monitors operating parameters, making adjustmentsto the process as needed for proper control. Alarm logic is incorporated into the PLC system to automatically initiate an AWFCO. Table 2-3 summarizesthe current AWFCO set points. AWFCO limits have been established based on several factors that are summarized below. RegulatotyI~ermit limits 

### - established to complywith existing permits. An example of this type of limit is the low temperature limit, belowwhich waste can not befed untilthe proper limit is re-established. In addition,the HWC MACT regulations require that the AWFCO system be interlocked with the span of each process instrument that is part of the Continuous Monitoring System (CMS). A listing of these CMS instrumentsand their interlocked span setpoints is maintained as part of Veolia's Operating Record. Process safetv limits

### - establishedto assure process equipment is protected and unsafe operating conditions do not occur. An example of this is inadequate excess air inthe combustion chamber that can lead to fuel rich conditions. Utilitvor Power failure 

### - established to facilitate a controlled shutdown of the process during loss of process air, steam, water or electricity. An example of this is the loss of instrumentair that is necessary for certain types process instrumentsto function properly. Wastes will not be re-introduced into the incinerators untll proper operation of key instruments is re-established. In additionto the AWFCO system, operators can manually shutdown waste feeds or the entire process should this be needed. 

### 2.8.1 AWFCO 

### System Testing Veolia tests the AWFCO systems bi-weekly. Instrument calibrationsare performed as indicated in Table 2-3. In some cases this testing occurs more frequently depending on how often actualAWFCOs occur at the unit. Per the required frequency, incinerator personnel check the functionality of AWFCO logic that is part of the Q:~w97\Pmjects\l0002022\Veolia Performance Test Plan U3 R2-052108.docVeolia ES Technical Solutions MACT PerformanceTest Plan Revision: 0 Date. May 2008 Section: 2.0 Page 9 of 11 incinerator's PLC system to make sure that should process conditions deviate from allowable limits, the computer logic will initiate waste feed shutdowns as required. This is accomplished by manually simulating process conditions that are outside allowable l~mits and observing and documenting when the control or block valve software logic on the waste feed line beginsto initiate valve closure. Should actualAWFCOs occur during a given testing period, these are documented by operating personnel to satisfy regulatory requirements for system testing. Results of this testing are documented on a separate AWFCO Testing Log and maintained as part of the unit's Operating Record. 

### 2.9 Air Pollution Control Equipment Maintenance Practices [40 

### CFR §63.1207(f)(i)(iii)(G)] 2.9.1 Program Overview Once equipment is installed and operational, Veolia utilizes an extensive preventative maintenance (PM) programto keep equipment operational and prevent breakdowns and failures. Based upon the type of equipment and historical operations and maintenance experience, schedules for various inspection and PM activities are followed. This includes aspects such as documenting detailed maintenance histories on equipment, routine inspection and lubrication programsfor high wear equipment and non-destructive testing of piping and vessels using techniques like ultrasoundto assess integrity. The frequency of these activities varies depending uponthe equipment, PM activity and the incinerator's shutdown schedule For example, frequent (i.e., weekly) instrument and certain mechanical equipment checks are made for critical process items. Lubrication, vibration analysis and other mechanical integrity checks are done at longer frequencies like monthly or quarterly. And finally, such items as inspecting refractory brick for wear, are typically performed when the entire incinerator is shut down for maintenance. 

### 2.9.2 Test Program Preparation Activities Prior to testing, instrumentation associated with key parametersof the test will be checked, calibrated,or replaced, as appropriate,to ensure proper operation of the instrumentation during testing (i.e.,waste feed flowmeters and scales, CEM's, pressure transmitters, thermocouples, stack flowmeters, etc.).

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### Table 2-2 

### Technical Information Summary on Incinerator No. 3

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Table 2-3 CurrentAWFCO Parameters

### and Limits for Incinerator No. 3

/"""L

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## 3.0 Incinerator Feed Stream Descriptions

3.1 General Veolia treats a broad range of wastes and thus the individual streams that may make up the incinerator overall feed at any given time can vary greatly, depending on generator productionand shipping schedules. Priorto scheduling wastes for shipment to the facility,thewaste streams are characterized by the generator and ' reviewed by Veolia staff. A Waste Profile Number uniquely identifies each different waste stream. This assures that only pre-approved wastes are handled at the facility and that all necessary regulatory, handling, safety and other important information is availableto Operations personnel. Organic Hazardous Air Pollutants (HAPs) measured or expected (based on process knowledge)to be present in a source waste at or above approximately 0.1 % by weight are listed in the tables in this Section. Organic HAPS not listed are, based on process knowledge, believed to be either completely absent or present in the waste at less than 0.1 % by weight. In addition to the information below that summarizesthe top volume waste streams processed at Veolia. Table 3-1 providesa summary of the major HAPs processedat the facility. 

### 3.2 High Volume Wastes 3.2.1 Liquid Wastes Liquid wastes are received at the Sauget facility in tank trucks and drums and are either direct fed through a dedicated line or are blended with other compatible waste streams intothe tank farm. Table 3-1 provides a summary of the top volume liquid streams that have been processed in the last year. Liquid wastes can be processed in any one of the three incinerators. These streams can be organic, aqueous or a mixture. 

### 3.2.2 Bulk Solids Table 3-2 providesa summary of the top bulk solid streams handledat the Sauget facility. Bulk solids can include streams like contaminatedsoils, wastewater sludges or manufacturing process solids. These wastes are receivedat the site primarily in 20 to 40 cubic yard roll-off containers or other similar bulk transport vehicles. 

### 3.2.3 Containerized Waste Table 3-3 providesa summary of the top containerized waste streams handled at Sauget. Containerized wastes are received in drums and smaller cartons, boxes or pails and can include materials such as laboratory waste, spent carbon, process residues. 

### 3.2.4 Gaseous Wastes Small volumes of compressed gases are processed in Unit2 however these are minimal in comparisonto the other waste types that are treated.

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Page2 of 5 

## 3.3 Auxiliary Fuels Natural gas or #2 fuel oil can be used as auxiliary fuels to start-up and obtain desiredtemperatures in the incinerators. At this time, all incinerators use natural gas as their primaryfossil fuel. Typical composition of both fuels is provided in Tables 3-5 and 3-6.

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Page 3 of 5
Table 3-1 Top Volume Liquid Waste Streams

Table 

### 3-2 Top Bulk Solid Waste Streams

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Page4 of 5
Table 3-3 Top Containerized Solid Waste Streams

Table 3-4 Summary of Major HAPS Processed

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- - - Table 3-5 Typical Properties for Supplemental Fuel Oil

Table 3-6 Typical Properties for NaturalGas Parameter Units Value Parameter Heat Value Btullb 

### > 17,000 Chromium Ash Content Chloride Content

Q:\mw97\Projects\10002022\Veolia Performance TestPlan U3 R2-052108.doc Antimony Arsenic Barium Beryllium Cadmium PPm PPm PPm PPm PPm < 1.0 < 1.0 < 2.0 < 2.0 < 5.0 I Nlckel Selenium Silver Thallium PPm PPm PPm 

# --- PPm < 10 < 0.1 c 0.1 < 0.05Veolia ES Technical Solut~ons MACT PerformanceTest Plan Revision: 0 Date: May 2008 Section: 4.0

Page 1of 7 

## 4.0 

## Performance Test Protocol
4.1 General Description This performancetest has been designed to demonstrate performance under a single test condition using a combination of actual and spiked feeds. This test condition will be designed to establish overall maximum waste, chlorine and metals feed rates while demonstrating conformancewith all applicable HWC MACT emissions standards. During the testing, Veolia will be seeking to establish new Operating Limits for Unit 3. Due to this, Veolia will adjust the limits at which the AWFCO system activates except for carbon monoxide. At the end of each day of testing, current AWFCO limits will be reinstated back to currently established limits. 

### 4.2 Performance Standards The performancetest for the Veolia incinerator has been designed to demonstrate compliance with current performance standards of the Hazardous Waste MACT rule asfollows:

w Conformance with the mercury emission limit of 130 pgldscm corrected to 7% oxygen;
w Conformancewith the semivolatile metal (cadmium and lead) emission limit of 230 pgldscm corrected to 7%oxygen; and Conformancewith the volatile metal (arsenic, beryllium and chromium) emission limit of 92 pgldscm correctedto 7% oxygen. 

### 4.3 Test Conditions [40 

### CFR 

# 5 63.1207(f)(l)(vi) and (vii)] The test condition for this performance test isdesigned to demonstrate compliance with the applicable MACT metals emissions standards. Unit 

### 3 will be operated at normal combustion zone temperatures during this condition with normal waste feed rates. The flue gas flow rate and chlorine feed rate will be maximized. The baghouse inlet temperature will be maximized. The proposed operating limitsfor the performance test are summarized in Table 4-1. 

### 4.4 Waste Feed Spiking In order to demonstrate the required performance criteriafor this program, it will be necessary to fortify (spike) the incinerator feeds with organic and inorganic constituents. The spiking levels and approach proposedfor this performancetest have been used successfully in the past for testing at not only Veolia but for testing at other hazardous waste combustion facilities as well. Each spiked material will be prepared to a known specification and verified by a certificate of analysis. These materials will be prepared and fed in a manner that assures a very consistent feedrate. Feed rates of each spiked compound are chosen to bewell above expected levels in native wastes, generally an order of magnitudeor more higher, so that the spiked constituent is the dominant feed and the native contribution is not significant. Spiking rates are also selected based on historical performance to assure that emissions can be F- detected and actual results, versus non-detect results, are used in calculation removal efficiencies.

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### 4.4.1 Inorganic Constituents Several metalsw~ll be spiked to the system to permit calculation of system removal efficiencies (SREs),which can then be used to determine appropriatefeed rate limits, as necessary. Regulatedmetals may be fed at some level in the native waste materialsto be used duringthe test. However, these native concentrations may not be high enough to achieve the desired feed rate limits to be set for the system. Therefore, Veolia plans to spike three surrogate metals at higherthan normal rates to ensure that sufficient metals are fed to achieve measurable emissions in the stack emissions. 

### Table 

### 4-2 provides an overall summary of informationrelevant to the metals testing portion of the program. SRE data from previous test programs have been used in conjunctionwith present feed rate limits and present MACT emission limitsto specify target feed ratesthat will result in acceptable emission rates. This table is only used as a predictive tool, however, and final limitsto be imposed will depend on the actual results of the performancetest. Two other points are worth noting with regard to Table 4-2: The spiked amount for a given metal will bethe difference between the desired feed rate limit and the nativequantity expected to fed during the test; and Surrogate metalswill represent the whole group (in the case of LVM and SVM) and test resultswill be usedto extrapolate up to the applicable MACT standard. The three metalsto be spiked are representative of the three classes of metalvolatility and therefore can be rc- usedto set limits for any metals not spiked. 

### 4.4.2 Spiking for the 

### LVM Category The LVM Category for incinerators includesarsenic, beryllium and chromium. Veolia plans to spike chromium at 40-45 Iblhrto establish a SRE for all three test runs. The SRE demonstrated during the performancetest for chromium will be usedto establish a LVM feed rate limit. Chromium will be spiked as chromic acid through a liquid feed injectorvia a pumping station that will monitor the feed rate. Waste chromic acid is treated at Veolia and thus, spiking chromic acid during the performance test is representative of normaloperations. 

### 4.4.3 Spiking for the SVM Category The SVM category for incinerators includes cadmium and lead. Veolia plans to spike lead at 60-65 Iblhrduring the performancetest to establish a SRE for all three runs. The SRE demonstratedduring the performancetest for will be used to establish a SVM feed rate limit. Leadwill be spiked as lead nitrateand delivered in small, pre-measured plastic baggies at regular intervals along with other solid waste feeds during the performance test. Lead containing waste that are normally treated at Veolia are predominantly bulk or containerized solids and thus, this spiking approachduring the performance test is representative of normal operations. 

### 4.4.4 Spiking for Mercury For mercury, the only high volatile metal,Veolia plans to spike this at approximately 0.001 

### - 0.002 Iblhr and P""- will follow a similar approach as noted above for the other MACT-regulated metals. Mercury will be fed as a mercuric nitrate solutionat regular intervals along with other solidfeeds during the performancetest. Mercury is predominantly present in solidfeeds processed at Veolia and uslng a liquid solutionfor spiking will provide Q:\mw97Wrojects\l00D2022\VeoiiaPerformance Test Plan U3 R2-052108.docVeolia ES Technical Solutions MACT Performance Test Plan Revision: 0 Date: May 2008 Section: 4.0

Page 3 of 7 an easily volatilized form fed along with other solid feeds in a manner that is representativeof normal operations. 

### 4.5 Metals Extrapolation Method Veolia plans to extrapolateto higher feed rate limits than actually fed during the test using the performance test-establishedSREs. This is appropriate since it is generally agreed that SREs at higher feed rates would be at least as good as those observed at the lower level. Any extrapolation performed will take into consideration the IMACTstandards to ensure full compliance. Based on previous discussions with EPA Region 

### 5, the following approach will be used. The average SRE for the three runs would be calculated from the feed and emission rates for each run and an average SRE for the performance test. A feed rate limit would then be calculated for each metal category by dividing 75% of the emission standard for that category by the SRE for the spiked compound representing that category. A similar approach would be followed for SVM (cadmiumand lead) and for mercury. To further assure that this method is protective, Veolia proposes to limit the maximumfeedrate for any one categoryto 10 times the spiked feed rate during the testing. The test program will establish 12-hour feed rate limits for the MACT metals. Example calculations are show below. Maximum emission rate for extrapolation f-', = (emission standard (pglm3 @ 7% 02) * 0.75 * Qstack (dscfm @ 7% 02) * 0.0283 m3/ft3* 60 minlhr)l(4536 gllb * 10' yglg) Maximum extrapolated feed rate

= Maximum emission rate/(I

### - SRE from performancetest) 

### 4.6 Description, Preparation and Delivery of Feeds for the Performance Test [40 CFR 

# 5 63.1207 (f)(l)(vi) and (vii)] To the extent possible (and with the exception of the spiked constituents noted above), only normal waste materials processed at the facility w~ll befed to the incinerator during the test program. Waste materials will be stockpiled to meetthe objectivesfor the target test parameters. These wastes will be characterized in advance of the test and kept until needed. All waste materials will be delivered to the facility in accordance with routine operation and currently permitted procedures as described elsewhere in this document. 

### 4.7 Conditioning Time Needed to Reach Steady State [40 CFR § 

### 63.1207(f)(l)(xii)] The incinerator will be operated for 15 minutes at the desired feed rates and operating conditions before sampling begins for a given condition of the performance test. This will assure all operating parameters are stabilized at the desired settingsto achieve steady state before sampling. 

### 4.8 Anticipated Test Schedule The performance test will be performed over a 4-day period using a three-person field crew according to the schedule shown in Table 4-3. For this test program, it is anticipated that all runswiH beapproximately two /- hours in duration, as dictated by the sample run time requiredfor metals measurements. The test program for this incineratoris plannedto start on or after August I, 2008.

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Page4 of 7


### 4.9 Performance Test Reporting The final reportwill be prepared for submittal no laterthan 

### 90 days from completion of the field test program. This document will provide a concise presentation of performancetest resultsand will include all necessary supporting documentation. An example outline of the final Performance Test report is presented below: Section 1.0 Certification 

### - Includes project title, statement of complianceand project approval signatures Section 2.0 Summary 

### of Test Results -Summary of emission results compared to applicable standards; interim status operating limits; overview of process operating conditions; Section 3.0 Project Overview 

## - Facility and unit description; project background and scope;test requirements; test chronology and report organization Section 4.0 MACT Notification ofCompliance 

### - Regulatory requirements; performance test results and compliance determination; area or major source determination; description of air pollution control system; and descriptionof process monitoring systems Section 

### 5.0 Process Operating Conditions 

## - Overviewof test conditions and summary of facility process monitoring data
P Section 6.0 Sampling and Analytical Program Overview 

## - Summary of proposed plans and discussion of actual activities and any required deviationsfrom plan Section 7.0 Test Results 

### - Detailed presentation of waste analysis and stack sampling results including tabulated presentationof all data Section 8.0 Quality Assurance 

### I Quality Control 

## - Detailed discussion of waste and stack samplingand analytical 

### QAlQC procedures and results APPENDICES A 

## - Facility Process Monitoring Data 

### B 

### - Spiking Report C

## - Field Sampling Documentation D -Analytical Data Reports

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Page 5 of 7
Table 4-1 MACT OPLs to be Established During the PerformanceTest

Q:\mw97\Projects\l0002022\Veolia PerformanceTest Plan U3 R2-052108.doc Process Parameter Units Period Established Maximum Flue Gas Flowrate acfm I-hr Average of maximum 14,500

### - 17,000 HRAs for each run Maximum LowVolatile Metals Iblhr 12-hr Average of the (LVM) Feed Rate average HRAsfor each run MaximumTotal Pumpable Iblhr 12-hr Average of the LVM Feed Rate average HRAsfor Max~mum Semi-volatile Metals (SVM) Feed Rate Maximum Total Mercury Feed Rate Maximum ChlorineIChloride Feed Rate Max~mum Fabric Filter Inlet Temperature Iblhr
Iblhr. Iblhr

OF 12-hr
12-hr 12-hr 

### I -hr each run Average of the average HRAsfor each run Average of the test run averages Average. of the test run averages Average of the test run averages 600 

## -650
0.01 

### - 0.02 200 

## -250 390 

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Page 6 of 7
Table 4-2 Metals Evaluation Plan

Feed Range Feed Rate 

# I spiked Expected

Historical Desired
Mercury 0.002 110 

# ~ 156 0.002

- LVM 206 400 

### -450 40 

### - 45 99.9999% 0 0005 32 

# 1 Expected

Assumptions: Qs = stack gas flow rate = 02 = stack oxygen level = MACT Standards: SVM (Cd and Pb) = LVM (As. Be and Cr) = Mercury = Projected Emission Rate at the Desired

Feed Rate Limit

5,838 dscfm 12.0 % vol.

* Surrogate metals to be spiked during the Performance Test

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Table 4-3 Anticipated Performance Test Schedule General Overview of Planned Schedule

Activity 

# SI I Mobilization,site safety training and set-up 

# I Day 

# I, I Preliminary traverses, Conduct Run 

### 1 and Run 2

Example of Detailed Daily Schedule (Day 2 Above) 

# 1 Conduct Run 3

Equipment removal and depart site 

### --


# ( Incinerator lined out on trial burn wastes 

# I 07:OO 

# 11 Day 3 

## 11

Q:hw97Projects\l0002022\Veolia PerformanceTest Plan U3 R2-052108.doc - - -



# ' Begin metal spiking

Initiateall stack sampling and waste sampling Approx. end time for sampling runs Recovery of samplingtrain Depart Site - -1 08:30 08:45 15:OO 15:OO

## - 16:30 17:OOVeolia ES Technical Solutions MACT Performance Test Plan Revision: 0 Date: May 2008 Section: 5.0 Page 1 of 25 

## 5.0 Sampling and Analytical Program Quality AssuranceIQuality Control

This section presentsthe Quality Assurance and Quality Control goals, objectives, and procedures for the MACT PerformanceTest program.The quality assurancelquality control procedures and criteria for this programwill comply with the requirements of this document and its updates. The analytical work conducted will incorporate the QAIQC requirementsof the approved methods. This document has been prepared using available guidance provided in the following EPA documents: "EPA Requirements for Quality Assurance Project Plans", EPA QNR-5, November 1999. "Component2 

### - How to Reviewa Quality Assurance Project Plan (including Attachment A 

### - Generic Trial Burn QAPP", Hazardous Waste Combustion Unit Permitting Manual, U.S. EPA Region 6, January 1998.

a "Handbook

### - QualityAssuranceIQuality Control (QAIQC) Procedures for Hazardous Waste Incineration"(EPN62516-891023January 1990).
Quality Assurance Project Planfor Veolia ES Technical Solutions MACT Metals PerformanceTest on the Fixed Health Incineration System Facility ID Numbers: lLD098642424 Prepared for: Veolia ES Technical Solutions, 7 Mobile Avenue, Sauget, IL 62201 Prepared by: ENSR Corporation, Westford, MA 01886 Revision No.: 0 Date: May 2008

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### 5.1 Title Page 5.1 .I Project Title Quality Assurance Project Plan for Veolia ESTechnical Solutions HWC MACT Metals Performance Test Plan for the Unit 

### 3 Fixed Hearth Incinerator. 

### 5.1.2 Expected Performance Test Date On or after August 1.2008. 

### 5.1.3 ProjectApprovals

Veolia Project Manager

,."d. ENSR Project Manager

ENSR QA Officer

Maxxam Analytics Lab Services Coordinator Date

Date

Date

Date

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### 5.2 Table of Contents A complete table of contents, including listings of tables and figures and acronyms is presentedat the beginning of this PerformanceTest Plan and includes all pertinent information applicable to this QAPP section. 

### 5.3 Project Description This project will consist of a comprehensive sampling and analysis program designed to demonstrate compliance with the HWC MACT rule requirements. Testing will be performed under one process operating condition, entailirlgtriplicate sampling runs. Operating parameter limits (OPLs) associated with metals emissions testing will be re-established or modified based on the results of the program. The reader is referred to Sections 1.3, 1.4, 2.5.3 and 4.0 for further details on program scope, test objectives and target parameters for emission measurements and process monitoring. The remainder of this section outlines the detailed measures that will be followed to ensure collection of valid data. A brief overview of the measurements to be made during the test program is provided in Table 

### 5-1. A more detailed summary of the sampling and analytical program is provided later in Section 5.6. 

### 5.4 

### Project Organization The ENSR Project Manager, Mr. Jeffrey Gorman will be responsible for the overall directionof this program and w~ll reportto the Veolia Project Manager, Mr. David Klarich. Mr. Gorman will be responsible for project design and implementation, communicating with the client, scheduling all activities, reviewing all project data and preparing all reports. Hewill be assisted in the oversight of Quality Assurance activities by the program QualityAssurance Officer (QAO) and each Analytical Laboratory Services Coordinator (LSC). Each contract laboratorywill have one individual designated as the person responsible for project activities. 

### 5.4.1 QA Officer's Responsibilities Mr. Craig Doolittle will serve as the project Quality Assurance Officer (QAO) and will be responsible for review and approval of the Quality Assurance Project Plan presented inthis section, as well as any subsequent revisions. Hewill monitor implementationof field and laboratory activities, scheduling performanceand/or system audits as warranted. The QAO will report to the Project Manager on any conditions noted which may adversely affect data quality. Mr. Doolittle will provide independent oversight for data verification and data quality assessment activities. He will prepare a sectionfor the Final Report summarizing QAIQC activities and provide an overall evaluation of data quality. 

### 5.4.2 Laboratory Coordinator Responsibilities Each analytical laboratory will designate a Laboratory Services Coordinator (LSC), who will be the principal point of contact for the ElVSR Project Manager. The LSC will review QA requirements with all laboratory staff to ensure that all required measures are taken to meet data quality objectives.They will monitor the shipment and receipt of samples, track analytical progress and review data as reported from the laboratories for completeness. Each LSC will be responsible for validation of all data generated by the laboratory for this programand will provide all necessary documentationfor inclusion in the final report.

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### 5.5 QAlQC Program 

### Objectives 5.5.1 Precision, Accuracy and Completeness The collection of data to fully characterize the incinerator waste feed materials and stack gas emissions requires that sampling and analysis procedures be conductedwith properly operated and calibrated equipment by trained personnel.QA objectivesfor measurements made in the field are summarized in 

### Table 5-2. QA objectives specific to each analytical methodology performed by the subcontractor laboratories are presented later in Section 

### 5.9. The overall program has been designedwith consideration of sampling parameters and analytical limitsto ensure that the achieved MDLsfor emissionswill be more than adequatefor regulatory limit decisions. Critical MDL determinationsare addressed subsequently in Section 5 5.3. Precision is defined as a measurementof mutual agreement among individual measurements made under prescribed similar conditions. Precision is expressed in terms of relative percent difference (RPD) between duplicate determinations and in terms of relative standard deviation (RSD) when 3 or more determinations are made. Overall precision for analysisof the waste feed streamswill be assessed through the analysis of one set of duplicate samplesfor each designated parameter. Accuracy is the degreeof agreement of a measurementwith an accepted reference or true value. Analytical accuracy will be measured through the recoveries of matrix spikes, analysis of standard reference materials or audit sample analysis. Matrix spike samples for the waste feed will be prepared by spiking known amounts of target analytes into a portion of the sample recoveries are monitored to assess laboratory and method accuracy. Laboratory control samples (LCS) will also be usedto distinguish between method performance and matrix effects on accuracy. LCS and MS spiking solutionswill be independent from calibration standards. Completeness is a measure of the amount of valid data obtained compared to the amount that was expected under normal conditions. The overall program objective isto obtain valid data for three (3) runs for each test condition. For all data considered criticalto the investigation,a completeness objective of 100% has been established. As a result, critical priority data from each of three (3) runs should achieve the precision and accuracy goals established herein. This completeness criterion appliesto all permit parameters in emissions samples as well as feedlprocess stream samples. Individual samples for which the critical data points do not achieve accuracy andlor precision data quality objectives may require reanalysis. Results for samples where matrix interferences preclude meeting objectives for the recoveries of spikes will be evaluated for potential bias to calculated emission results. In summary, the completeness goals are stated at loo%,since three valid runs are necessary to assess operation at any one condition. 

### 5.5.2 Representativeness and Comparability It is recognized that the usefulnessof the data is also contingent upon meeting the criteria for representativeness and comparability. Wherever possible, reference methods and standard sampling procedures will be used. The 

### QA objective is that all measurements be representativeof the matrix and operation being evaluated. The detailed requirements for sampling given in the various EPA Reference Methodswill befollowed to ensure representative sampling of flue gases Sampling of incineratorfeed streams prior to the performance test will provide representative samples of these matrices. The corresponding QA objective is that all data resulting from sampling and analysis be comparablewith other representative measurements made by the performancetest field team, on this or a similar process operating under similar conditions. The use of published sampling and analytical methods and standard reporting units will aid in ensuring the comparab~lity of the data.

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### 5.5.3 Method Detection Limit (MDL) Determinations Method Detection Limits (MDLs)for the various analytes to be measured in this programwill be determined following well-established laboratory procedures in accordancewith standard EPA protocols. These are described belowfor those parameters deemed most crucial to the program. 5.5.3.1 Metals

# - Methods 

### 6020 and 

### 7470A Reporting limits for all metals are determined based on the results of the latest MDL studies performed for each metal. Forthis program,the MDL for non-detect values will be determined by low-level replicate spiking of aliquots of the samples submitted. The reporting limit for non-detectable metals is a chosen whole number above the MDL, usually in the range of 1.5-2 times the MDL value. 

### 5.6 Sampling and Monitoring Procedures This section describes the procedures that will be followed during the field sampling program. Throughout the overall program, all sampling will be performed using sampling protocols described herein and approved by EPA. Regulatory agency approval will be obtained for any deviations from or changes to the approved Performance Test Plan which may be warranted priorto program implementation as a result of changes in personnel or facility circumstances. If situations occur during the demonstration testingwhich necessitate deviations from the plan, the agency will be notified and onsite approval requested. Any deviations from the specified protocolswill be fully documented in the final Performance Test Report. 

### 5.6.1 Field Program Description A detailed description of the compliance strategy and test conditions was provided previously in Section 4.0. In general, however,the program is presently configured to collect samples during three runs for a single process operating condition. Table 5-3 prov~des a detalled listing of the sampling and analytical parameters and methods planned for this program. All sampling will be conducted concurrently at the outlet stack location. 

### 5.6.2 Pre-sampling Activities Pre-samplingactivities includeequipment calibration, sample media preparation, cleaning of sampletrain glassware, preparation of computer-generated sample labels, and other miscellaneous tasks. Each of these activities are described or referenced inthe following subsections. Other pre-samplingactivities includesuch details as team meetings, equipment packing and shipment, equipment setup, and finalization of all details leading up to the coordinated initiation of the sampling program. 5.6.2.1 Equipment Calibration A most important aspect of pre-sampling preparations isthe inspection and calibration of all equipment plannedto be used for the field effort. Equipment is inspected for proper operation and durability priorto calibration. Calibration of equipment is conducted in accordance with the proceduresoutlined in the EPA document entitled "QualityAssurance Handbook for Air Pollution Measurement Systems; Volume IIIStationary Source Specific Methods" (EPA-60014-77-027b). Equipment calibration is performed in accordance with EPA guidelines andlor manufacturer'srecommendations. Documentation of all calibration recordswill be kept In the project file during the field program and w~ll be available for inspection by test observers. Examples of field equipment used and typical calibration requirementsfollows:

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Probe nozzles (QA Handbook Section 3.4.2, pg. 19)

## - make three measurements of the nozzle ID (to the nearest 0.001 in.) using different diameters with a micrometer. Differencebetween the high and lowvalues should not exceed 0.004 in. Post-test check 

## - inspect for damage. Pitottubes (QA Handbook Section 3.1.2, pp. 1-13) 

### - measured for appropriatespacing and dimensions or calibrate in a wind tunnel. Rejection criteria given on the calibration sheet. Post-test check

## - inspect for damage. Thermocouples (QA Handbook Section 3.4.2, pp. 15-18) 

## - verify against a mercury-in-glass thermometer at two or more points includingthe anticipated measurement range. Acceptance limits

## - impinger +2"F; DGM k5.4"F; stack 

### *I .5 percent of stack temperature. Dry gas meters (QA Handbook Section 3.4.2, pp. 1-12) 

### - calibrate against a wet test meter. Acceptance criteria

### - pretest Yi 

### =Y 

# * 0.02; post test Y 

### =

# + 0.05 Yi. Field barometer (QA Handbook Section 3.4.2, pp. 18-19)

### - compare against a mercury-in-glass barometer or useAirport Station BP and correct for elevation. Acceptance criteria 

### - 

# * 0.02 in. Hg; post-test check 

### - same. 5.6.2.2 Glassware Preparation Sampletrain glassware and sample containers require specialized pre-cleaning to avoid contamination of the sample from the collectioncontainer or devices. Cleaninglstorageproceduresfor sampletrain glasswareare ,A- summarized below. Note that all bottle caps are fitted with teflon liners which are cleaned in the same manner as the bottles themselves. Sample containers used for waste feed streams are purchased pre-cleaned and sealedto specified EPA protocols. EPA Method 29 glassware and containers (metals) -wash with soap and water, rinse with hot tap water, rinsethree times with reagent water. The glassware is next soaked in a 10% nitric acid solution for a minimum of 4-hours, rinsed three timeswith reagent water, rinsed a final time with acetone and air dried. All glassware openingswhere contaminationcan occur will be covered until the sampling train is assembled prior to sampling. 5.6.2.3 Sample Media Preparation All reagents will be checked in accordance with ENSR's existing QC Programto minimize the probability of using contaminated solvents. This includes the use of the proper grade reagentslsolventsas specified in the test method, selection of reagents from the same lot and the collection and analysis of the appropriate blanks. Sampling mediawill be procured and prepared in accordance with the appropriate test methods as described below: Quartzfilters used in the Method 29 sampling train are purchased from Pallflex Products Co. who pre-screenfilters for metals content. 5.6.2.4 Other PreSampling Activities Sampleteam meetings will be held to designate responsibilitiesto eachteam member Assignments will be based on individual experienceand relative importance of the assignedtask. Other pre-sampling activities in the office will include generatton of samplechecklists, printing of computer-generated sample labels, and ,*- proper packing of all equipment. Equipmentwill then betransported by freight or truck to the sampling location.

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Site setup is the final pre-sampling activity. This task will involve movingthe equipment to the vicinity of the sample collection area. A separate office tra~ler or other suitable onsitefacility will be usedto serve as a sample train setup and recovery area and sample custody area. Normally, preliminary tests are conducted at the stack locationto verify the presence or absence of cyclonic flow conditions and to determine flue gas moisture, temperature and velocity. These measurements facilitate determination of nozzle size selection and sample train operation rates for the isokinetic sampling trains. 

### 5.6.3 Sampling Locations 5.6.3.1 Waste Feed Streams Waste feed materials will be sampled in accordance with the facility's feed stream analysis plan (FSAP) and RCRA Waste Analysis Plan (WAP). Waste feed sampling will occur upstream of any metal spiking location. Samples will be collected using methodologies described inthe FSAP and WAP. 

### 5.6.3.2 Stack Sampling Location Sample test ports in the circular 39-inch ~nside diameter (ID) stack are located 32 feet (9.85 diameters) downstream of the induced-draftfan and 49 feet (15.1 diameters) upstream of the stack exit to atmosphere. In accordancewith EPA Method 1, a 12-point traverse will be performed during testing. One test port level will be used to accommodate simultaneoustesting of all emissions test parameters. 

### Figure 5-1 providesa schematic of the stack showingthe location of the sampling ports. Actual traverse point locations and upstream/downstreamdistancesfrom flow disturbances are shown in 

### Table 54. 5.6.4 Waste Feed Stream Sampling Procedures Each waste feed material fed during the test will be sampled from taps in the feed lines or other appropriate locations, upstream of any metal spiking location. Duringthe testing each waste feed material will be sampled at the start of each run, at port change, and at the completion of each run. After testing is completed, the three samples that were collected will be composited and analyses will be performed on this composite sample. The feed streams will be characterized for ash, heat content, metals (arsenic, beryllium, chromium, cadmium, lead, and mercury) and total chlorine. Veolia will be responsible for all waste feed analyses. 

### 5.6.5 Stack Sampling Methodologies Gases discharged from the exhaust stack will be sampled by ENSR for the following parameters: Flue gas velocity, flow rate, temperature, moisture content and fixed gas (0, and C02) composition; MACT Metals 

### -arsenic, beryllium, cadmium, chromium, lead and mercury; The following sections provide summaries of the sampling methodologiesto be followed. In addition, sample field data sheets to be used during the program are provided in 

### Appendix B. Summaries of relevant information pertaining to setup and recoveryof the EPA Method29 sampling train are provided in 

### Appendix C.

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5.6.5.1 Gas Stream Velocity, Moisture and Fixed Gases Gas streamflowrate, moisture and fixed gas concentration will be determined concurrent with the EPA Method 29 isokinetic sampling train. Gas stream velocity will be determined using a pitot tube and water manometer in accordance with EPA Method 2. Gas stream temperature will also be determined at each of the Method2 traverse points using a Type 

### "K" thermocouple and pyrometer. Gas stream moisturewill be will be determined as specified in EPA Method 4 concurrent with the EPA Method 29 isokinetic sampling train. In this procedure the impinger contents are measured or weighed before and after each test run and used in conjunction with the metered gas volume to determine the gas stream moisture content. Fixed gases (02and C02)for gas stream molecular weight determination and constituent oxygen correction will be determined in accordance with EPA Method 3 (Orsat procedure) during each test run. 5.6.5.2 Metals EPA Method29 will be utilized for the collection of MACT and other metals including: MACT LVM metals -arsenic, beryllium and chromium; MACT SVM metals 

### - cadmium and lead: and Mercury. Specific sampling details for the Method 29 sampling train are as follows: Target sampling rate 

### - 0.75 cfm Sample run time 

## - 2-hr Number of sampling points per stack traverse

## - 6 Total number of sampling points

## - 12 Number of field reagent blank sets collected

## - 1 5.6.5.3 Continuous Emission Monitoring ENSR will provide measurement of oxygen (02)and carbon dioxide (COz)throughout all test run periods. These parameters will be measured using the procedures specified in 40 CFR 60, Appendix A, Method 3 (Orsat analysis). Veolia will provide continuous emission monitoring for carbon monoxide (CO) during all three test runs in accordance with the facility's Quality Assurance Planfor their CEMs. 

### 5.7 Sample Handling, Traceability 

### and HoldingTimes Sample integrity will be maintained throughout all phases of the sampling and analysis program. Samples will be held within sight of the samplers or sample custodian, or will be kept in sealed or secured containersat all times. Sealed coolers and DOT shipping boxes will be used to ship samples to the designated laboratory via Priority 1 overnight FedEx service.

<A-* Preprinted sample identification labels are used by ENSRto ensure that all required information is fully documented. When sample batches are shippedto the specified laboratory,a sample packing list (see

Q:\mw97Wrojects\l0002022\Veolia PerformanceTest Plan U3 R2-052108.docRevision: 0 Date: May2008 Section: 5.0 Veolia ESTechnical Solutions IMACT Performance Test Plan Page 9 of 25 Figure 5-2) accompanies the shipment. This form is based on established laboratory format and will be used to document sample transfer in the field and from sampling personnelto the laboratory. The ENSR F~eld Team Leader will coordinate the packing and sh~pment of all samples. Worksheets specifically designed for this program will be generated priorto the field effort. These sheets will assist the FieldTeam Leader in assuring that all samples have been collected, accounted for and shipped under sample traceability documentation to the appropriate laboratory. Requirements pertaining to sample preservation and recommended holdingtimes are noted in Table 5-5. All materials such as field and laboratory notebooks and logbooks,freld and laboratory data records, correspondence, reports, sample tags, traceability records and instrument pr~ntouts will be clearly labeled with the project number and become a permanent part of the project file. Project samples will be disposed of in an appropriate manner 60 days after acceptanceand approval of a final report. All project-related documentation at both ENSR and the subcontractor laboratories will be kept on file for 2 years following submittal of the final report. 

### 5.8 Analytical Methods and Calibration Procedures This section delineates the analytical protocols that will be used to analyze samples duringthis performance test. Samples of waste feed materials and stack gas will be collected and analyzedfor the parameters previously discussed usingthe appropriate laboratory protocols detailed inthis section and as outlined previously in Table 5-3. 

### 5.8.1 Analysis of Waste Feed Streams 5.8.1 

### .I Chemical and Physical Properties ofWaste Feed Streams Analyses to determine the chemical and physical properties of the waste feed materials will be performed using appropriateASTM or EPA SW-846 analytical methods as outlined in the Veolia FSAP and WAP. For any analytical results that are "non-detect", Veolia will utilize%ofthe detection limitfor that parameter in any calculation of feed rates. 

### 5.8.2 Analysis of Stack Gas Samples 5.8.2.1 Metals in Stack Gas Samples Analysis

# - Each sampling train will be prepared and analyzed in accordance with EPA Reference Method29. From each sampl~ng train, seven individualsamples are generatedfor analysis. The first two samples, labeled Fractions 1A and 

### 'I B consists of the digested sample from the front half of the train, consisting of the particulate filter and the front-half nitric acid probe rinse. Fraction 1A is for ICP analysis and Fraction 

### 1 B is for mercury analysis. Fractions 2A and 2B consist of digestates from the moisture knock out and HN03/H202 impingers 1,2, and 3. Fraction 2A is for ICP analysis and Fraction2B is for mercury analysis. Fractions3A, 3B and 3C consist of the impinger contents and rinsesfrom the empty and permanganate impingers4, 5, and 6. These fractions will be analyzedfor mercury. Analyses for metals other than mercury will be performed using Inductively Coupled Plasma Mass Spectroscopy (ICP-MS) as described in EPA Method6020 (SW-846, 3rd Edition). Mercury analysiswill be performed using EPA Methods7470A or 7471A (SW-846, 3rd Edition). All quality control procedures, including the interference check standard, will befollowed as described in the respective method. Q:\mw97\Projects\l0002022\Veolia Performance Test Plan U3 P.2-052108.docRevision: 0 Date: May 2008 Section: 5.0 Veolia ESTechnical Solutions MACT Performance Test Plan Page 10of 25
Calibration-Calibration of the ICAPwill be performeddaily in accordance with the procedures described in Method

### 6020 and the manufacturer's instructions. The calibration is verified daily by analysis of an instrument check standard prepared from an EPA quality control concentrate or other independent standard. QAIQC requirementsfor the analysis of metals in stack gas samples are summarized in Table 5-6. 

### 5.9 Internal QA Program Quality control checks will be performedto ensurethe collection of representative samples and the generation of valid analytical results for these samples. These checks will be performed by project participants throughout the program underthe direction of the Project Manager and the QA Officer. 

### 5.9.1 

### Data Collection and Sampling QC 

### Procedures QC checksfor the process data collection and sampling aspects of this program will include, but not be limited to, the following: 1. Use of standardizeddata sheets, checklists and field notebooks to ensure completeness, traceability, and comparability of the process information and samples collected. 2. Field checking of standardized forms by the Field Team Leader and a second personto ensure accuracy and completeness. 

### 3. Strict adherence to the sample traceability procedures. 4. Submissionof field biased blanks. 

### 5. Leak checks of sample trains before and after sample collection and during the test, when appropriate. 5.9.1.1 Sampling Equipment QC Checks and Frequency Calibration of the field sampling equipment will be performed prior to and at the conclusion of the field sampling effort. Copies of the calibration sheets will be available onsite during the field sampling program for inspection, will be kept in the project file and w~ll be submitted in the final report. Calibrations will be performed as described in the EPA publication "Quality Assurance Handbook for Air Pollution Measurement Systems, Volume Ill, Stationary Source Specific Methods;" Section 4.2.1 presents acceptance limits. Leak checks of the sample trains will be conducted in accordance with the protocol called out for each method. Leak checks will be conducted priorto and at the end of sample collection and during the test run,when appropriate. 5.9.1.2 Sample Collection QC Checks Field-biased blanks of reagents and collection media (deionized water, filters, impinger solutions, etc.) will be placed in appropriately cleaned and sized sample containers in the field and handled in the same way as actual field samples,to provide a QC check on sample handling. For this program, sample collection QC checks and frequency for samplesto be analyzed in the laboratory are listed below: ,+6-, One field reagent blank Method 29 sampling train.

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### 5.9.2 Analytical QC 

### Procedures for Samples to be Analyzed in the Laboratory The Quality Control program for laboratory analysis makes use of a number of different types of QC samples to document the validity of the generated data. The following types of QC samples will be used during the program. 

### 5.9.2.1 

### Quality Control Samples and Blanks Method Blanks Method blanks contain all the reagents used in the preparationand analysis of samples and are processed through the entire analytical scheme to assess spurious contamination arising from reagents, glassware, and other materials used in the analysis. Calibration Check Samples One of the working calibration standards which is periodically used to check that the original calibration is still valid. Laboratorv Control Samples (LCS) or Blank Spikes These samples are generatedfrom spikes prepared independently from the calibration concentrates. The LCS are used to establish that an instrument or procedure is in control. An LCS is normally carried through 

### ,e the entire sample preparation and analysis procedure also. Reagents used in the laboratory are normally of analytical reagent grade or higher purity; each lot of acid or solvent used is checkedfor acceptability prior to laboratory use. All reagents are labeled with the date received and date opened. The quality of the laboratory deionized water is routinely checked.All glassware used in the sampling and analysis procedures will be pre-cleaned according to the method requirements. Standard laboratory practices for laboratory cleanliness, personnel training and other general procedures are used. The results of these quality control procedures will be included in the final report. 

### 5.10 

### Data Reduction, Verification and Data Reporting Specific QC measureswill be used to ensure the generation of reliable data from sampling and analysis activities. Proper collection and organization of accurate information followed by clear and concise reporting of the data is a primary goal in all such projects. 

### 5.10.1 Field Data Reduction Appendix 

### B of this PerformanceTest Plan presents the standardized forms that will be used to recordfield sampling data. The Field Team Leader and at least one other field crewmember will review the data collected from each train in its entirety in the field. Errors or discrepancies will be noted and dealt with accordingly. The Field Team Leader has the authorrtyto institute correction actions in the field. The QA officer will also be notified for resolution if the situationwarrants. At a minimum, the QA officer is appr~sed of all deviationsfrom standard protocol. Field data reduction (checking of valid isokinet~c sampling rate and other sampling parameters) is done with a laptop computer using standardrzed Excel spreadsheets. 

### Appendix C provides sample train setup and recovery schematics and a description of solutrons and reagents to be used in each isokinetic train required for the overall program. All sample recovery sheets will bechecked for completeness. 

# ,+-.

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### 5.10.2 Laboratory Analysis Data Reduction Analytical results will be reduced to appropriate units by the laboratory using the equations given in the applicable analytical method. Unless otherwise specified, results from the analysis of waste feed and process samplesfor specific target constituents will be reported in units of mg/kg or % 

### wt. Other parameters

### will be reported in standard units such as 

### glee, Btullb, etc. The laboratory typically reports results from the analysis of stack flue gas samples as total mass detectedfor the sample submitted. For those sample fractions where liquid impinger condensate is analyzed,the laboratory will measurethe total liquid volume submitted and multiply by the measured concentrations of target analytes in these samples. The laboratories

### will generally report data as follows: All metals except mercury 

### -total ~g of each metal in the combined front-half and back-half sample train fractions Mercury-total yg in each sample train fraction Each LSCwill be responsible for reviewing all results and calculations and verifyingthe completeness of the data set. The laboratory reports submitted by each laboratory will include the following deliverables: Transmittal letter listing all samples and analyses and a case narrative identifying any difficulties associated with the analyses and any anomalous QNQC results Copies of Chain of Custody Forms Sample Report forms with sample field and laboratory identifier, dates of sample preparation and analysis, analytical results and detection limits Method Blank results Matrix spike and matrix spike duplicate results (as applicable) Replicate sample analyses (as applicable) Laboratory Control Sample results 

### 5.1 0.3 Data Verification Data verification is the processof reviewing data and accepting, qualifying or rejecting it on the basis of method-specific criteria. The independent project QAO will use validation methods and criteria appropriate to the type of data and the purpose of the measurement. Records of all data will be maintained, even that judged to be an "outlying"or spurious value. Field sampling datawill bevalidated by the Field Team Leader based on a judgment of the representativeness of the sample, maintenance and cleanliness of sampling equipment and the adherence to an approved, written sample collection procedure. Analytical data will be validated by the subcontractor laboratory QC or supervisory personnel using criteria outlined intheir laboratory-specificQA Plan and/orwritten SOPS. Results from field and laboratory method blanks, replicate samples and internal QC samples will be used to further validate analytical results. Analytical results on field blanks and replicate field samples are valuable for validation of sample collection also. QC personnel will review all subcontractor laboratory raw analytical data to verify calculated results presented. 

### ,--

Q:\mw97\Projects\10002022\Veolia PerformanceTest Plan U3 R2-052108,docRevision: 0 Date: May 2008 Section: 5.0 Veol~a ESTechnical Solutions MACT Performance Test Plan Page 13 of 25 The following criteria will be used to evaluate the field sampling data: Use of approved test procedures Proper operation of the process being tested Use of properly operating and calibrated equipment Leak checks conducted before and after tests Use of reagents that have conformedto QC specified criteria Use of NBStraceable CEM calibration gases (as applicable) Proper chain-of-custody maintained All sample trains --check to ensure proper sample gas volume collected The criteria listed below will be used to evaluate the analytical data: Use of approved analytical procedures Use of properly operating and calibrated instrumentation Precision and accuracy achieved should be comparable to that achieved in previous analytical programs and consistent with objectives stated in this document. 

### 5.10.4 

### Final Data Reporting Stack gas concentrations for each applicable parameter will be calculated from laboratory results and field sampling data. The total weight of the analyte detected w~ll be divided by the volume of gas sampled to provide emission concentrations. For MACT compliance, all emission concentrations are further corrected to 7% oxygen for comparison to the published standards. A complete Final Report outlining the goals, methods and results for the program will be prepared and any deviations from this test plan will be documented. The Final Report will include a section on evaluation and discussion of QAlQC results. Results will be comparedto expected limits for accuracy, precision and/or completeness as targeted in this protocol. The final test report will also include the results of any internal audits conducted on the program as well as: All field data sheets showing sampling method, dates, run times, personnel, equipment; sample preservation, identification and compositing records. Field equipment calibration data. Analytical lab reports and relevant supporting documentation. 

### 5.11 Routine Maintenance Procedures and Schedules This section provides pertinent information for field sampling equipment as well as a listing of all critical facility equipment necessaryto maintain permitted operating conditions and to demonstrate continuing permit compliance. Information is provided for preventive maintenance and schedules and spare parts for key equipment and instrumentation.

Q~\mw97\Projects\l0002022\Veolia Performance Test PlanU3 RZ-052108.docVeolia ES Technical Solutions MACT Performance Test Plan Revision: 0 Date May 2008 Section: 5.0 Page 14of 25


### 5.11.I Field Sampling Equipment The field team follows an orderly program of positive actions to prevent the failure of equipment or instruments during use. This preventive maintenance and careful calibration helps to ensure accurate measurements and minimal field delays. All equipment that is scheduled for field use is calibrated as outlined previously in Section 

### 5 6.2.1. Prior to each field use for a specific project, the equipment is cleaned and checked to ensure it is in good working order. An adequate supply of spare parts and sample train glassware is brought to each site to minimize downtime and field sampling delays. Any equipment that does experience problems is appropriately tagged in the field to ensure that it is repaired upon return to the office. 

### 5.11.2 Facility Equipment and Instrumentation As stated in Sections V.a.F. and V.b.F. of Veolia's Part 

### B RCRA Permit, each incinerator system undergoesa "thorough visual inspectionfor leaks, spills, fugitive emissions, and sign of tampering at least daily and in accordance with the inspection schedule contained in Appendix 

### 6 of the approved permit application". Veolia utilizes these inspections and additional preventive maintenance activities as proactive measures for minimizing the potentialfor malfunctions. To facilitate proper maintenance,a cold shutdownw~ll occur at least once per year for each incinerator system. Routine inspectionand maintenance activities are scheduled, communicated, and recorded throughthe use of field checklists. Parts of the incinerator systems that are subject to wear (e.g., bearings, O-rings, airtoil filters) are replaced based on the schedules indicated on these checklists. These field checklists will also be used to document repairs or replacements of incinerator components that may be revealed during inspections. Brief procedures/instructions for inspection and maintenance activities are provided on fietd checklists. Continuous monitoring system components are comprised of many instruments including scales, flowmeters, thermocouples, pressure transmitters, differential pressure cells, bag leak detectors, and limit switches. All components critical for monitoring permitted parameters are audited either on a quarterly or annual basisto ensure proper operation. Daily calibration checks are performed on the Unit's CEM's. 

### 5.12 QAIQC 

### Assessment Procedures The 

### QA activities implemented in this program will providea basis for assessing the accuracy and precision of the analytical measurements. Section 

### 5.8 of this QAPP discusses the 

### QA activity that will generate the accuracy and precision data for each sample type. A generalizedform of the equations that will be used to calculate accuracy, precisionand completeness follows. 

### 5.1 2.1 Accuracy Percent accuracy will be determined usingthe following equation:
% Recovery = 

### cx-S)xl~~ 

### T where: X 

### = experimentally determined concentrationof the spiked sample 

### T = true concentration of the spike S = sample concentration before spiking Q:~mw97\Projects\lO002022\Veolia PerformanceTest Plan U3 R2-052108,docVeolia ES Technical Solutions MACT Performance Test Plan Revision: 0 Date: May 2008 Section: 5.0 Page 15of 25


### 5.12.2 Precision Precision (calculatedas percent relative difference) will be determined using the following equation:

where: Dl and D2

### = results of duplicate measurements or standard deviation relativeto the average value expressedas relative standard deviation: Relative standard deviationwill be expressed as follows: Relative Standard Deviation (% RSD) 

### = 0 i"- 5, 

# I
Irn x (x,. 

# x,)I where:
o (,-, 

### = standard deviation of the sample data n = number of replicates x~~~.,,,~ 

### = arithmetic mean of the sample data 

### 5.12.3 Completeness Data completeness is a measure of the extent to which the database resulting from a measurement effort fulfills objectives for the amount of data required. Forthis program, completeness will be defined as the percentageof valid data for the total valid tests. Completeness is assessed usingthe following equation:

where: 

### D, = number of samples for which valid results are reported D, = number of valid samples that are collected and reach the laboratoryfor analysis The completeness objective will help to evaluatethe accuracy and precisionof the analytical measurements. 

### 5.13 External 

### QA Program The External Quality Assurance Program includes both performance and system audits as independent checks on the quality of data obtained from sampling, analysis, and data gathering activities. Every effort is made to have the audit assess the measurement process in normal operation. Either type of audit may show the need for corrective action. 

### 5.13.1 PerformanceAudits The sampling, analysis, and data handlingsegments of a project are checked in performance audits. A different operatorlanalyst prepares and conductsthese audit operationsto ensure the independenceof the quantitative results.
Q \mw9~Projects\lW02022\Veol1a Performance Test Plan U3 R2-052108.docRevision: 0 Date: May 2008 Section: 5.0 Veolia ES Technical Solutions MACT Performance Test Plan Page 16 of 25 EPA Quality Control concentrates or other standards will be used to assessthe analyticalwork. Results will be reviewed by the subcontractor laboratory and QC personnel. Any additional audit samples presented by the regulatory agencies will be analyzed along with program samples, by the appropriate lab and at the same time as all other samples. It will, however, bethe responsibilityof the regulatory agency to obtain these samples, and present them to the fac~lity project manager in a form that is amenable and appropriate to the analytical methods being utilized. If the regulatory agency advises facility program manager that audit results fall outside of acceptable ranges, the analytical data will be further reviewedfor error in conjunction with the agency. If a simple, correctable error is found (e.g., an arithmetic error), correction will be made and results resubmitted. If no error is found, an investigation into other causes of the failure (e.g., lack of sample integrity) will be conducted and results evaluated in terms of the impact on sample data integrity. 

### 5.13.2 Corrective Action The acceptance limits for the sampling and analyses to be conducted in this program will be those stated in the method or defined by the project manager. The corrective actions are likely to be immediate in nature and most often will be implemented by the analyst or Project Manager;the corrective action w~ll usually involve recalculation, reanalysis, or repeatinga sample run. Ongoing corrective action policy is described here. 5.13.2.1 Immediate Corrective Action Specific QC proceduresand checklists are designed to help analysts detect the need for corrective action. Often the person's experience will be more valuable in alertingthe operatorto suspicious data or malfunctioningequipment. If a corrective action can betaken at this point, as part of normal operating procedures, the collection of poor quality data can be avoided. Instrument and equipment malfunctions are amenableto this type of action and QC procedures include troubleshooting guides and corrective action suggestions. The actions taken should be noted in f~eld or laboratory notebooks but no other formal documentation is required, unless further corrective action is necessary. These on-the-spot corrective actions are an everyday part of the QAJQC system. Corrective action during the field sampling portion of a program is most often a result of equipment failure or an operator oversight and may require repeating a run. When equipment is discovered to be defective (i.e., pre- and post-sampling leak check) it is repaired or replaced and a correction factor is established as per the EPA method. If a correction factor is unacceptablethe run is repeated. Operator oversight is best avoided by having field crew members audit each other'swork before and after a test. Every effort is made by the field team leaderto ensure that all QC procedures are followed. Economically, it is preferredto repeat a run during a particular field trip rather than return at a later date. Corrective action for analytical work would include re-calibrationof instruments, reanalysisof known QC samples and, if necessary, of actual field samples. If the problem is not soived in this way, more formalized long-term corrective action may be necessary. 5.13.2.2 Long-Term CorrectiveAction The need for this action may be identified by standard QC procedures, control charts, performance or system audits. Any quality problem which cannot be solved by immediate corrective action falls into the long-term Q~\mw97\Pr0je~t~\10002022\Ve0lia PerformanceTest PlanU3 R2-052108.docRevision: 0 Date: May 2008 Section: 5.0 Veolia ES Technical Solutions MACT Performance Test Plan Page 17 of 25 category. The condition is reportedto a person responsible for correcting itwho is part of the closed-loop action and follow-up plan. The essential steps in the closed-loop corrective action system are: Identify and define the problem. Assign responsibility for investigating the problem. Investigate and determine the cause of the problem. Determine a corrective action to eliminatethe problem. Assign and accept responsibility for implementingthe corrective action. Establish effectiveness of the corrective action and implement it Verify that the corrective action has eliminated the problem. Documentation of the problem is importantto the system. A Corrective Action Request Form is fllled out by the person finding the quality problem. This form identifies the problem, possible causes and the person responsible for action on the problem. The responsible person may be an analyst. field team leader, departmentQC coordinator or the QA Director. If no person is identified as responsible for action,the QA Director investigates the situation and determines who is responsible in each case. The Corrective Action Request Foml includes a description of the corrective action planned and the date itwas taken, and space for follow-up. The QA Director checks to be sure that initial action has been taken and appears effective and, at an appropriate later date, checks again to see if the problem has been fully solved. The 

### QA Director receives a copy of all Corrective Action Forms and then enters them in the Corrective Action Log. This permanent record aids the QA Director in follow-up and makes any quality problems visible to management;the log may also prove valuable in listing a similar problem and its solution. 

### 5.13.3 

### Quality Assurance Reports to Management 5.13.3.1 Internal Reports The Laboratory Services

### Coordinator will prepare a written report on QC activities associatedwith this project for the Quality Assurance Director. This report will detailthe results of quality control procedures, problems encountered and any corrective action, which may have been required. All Corrective Action Forms are submittedto the QA Officer for initial approval of the corrective action planned and a copy is providedto the Program Manager. All system audit reports are providedto the Program Manager and the Quality Assurance Officer. 5.13.3.2 Reportsto Client The final report will include a section summarizing QNQC activities during the program. The Project Manager, Laboratory Services Coordinators and the QA Officerwill participate in preparing this section. This section wilt provide summary QNQC results for method blanks, and laboratory control spike recoveries. This section will evaluate overall data quality in terms of accuracy, precisionand completeness. Any discrepancies or difficulties noted in program work, protocol deviationsor documentation gaps will be identified and discussed.

Q'\rnw97\Pro~ects\l0002022\Veol1a PerformanceTest Plan U3 R2-05210B.docVeolia ESTechnical Solutions MACT Performance Test Plan Revision: 0 Date: May 2008 Section: 5.0 Page 18of 25


### Table 5-1 

### General Sampling andAnalytical Program Overview (Stack Exhaust)

Q'\mw97\Projects\l0002022\Veolia PerformanceTest Plan U3 R2-052108.doc 

### Analytical Method NIA EPA Method 7471 CVAAS EPA Method 6020 ICP-MS EPA Method 6020 ICP-MS MACT Emission Parameter Limits (a) Sampling Method Flow, Fixed Gases and EPA Methods2, 3 

### Moisture and 4 Mercury LVRll Metals (As, Be and Cr) SVM Metals (Cd and Pb) 130 pgldscm 92 pgldscm 230 pgldscm EPA Method 29 EPA Method 29 EPA Method 29Revision: 0 Date: May 2008 Section: 5.0 Veolia ES Technical Solutions MACT Performance Test Plan Page 19 of 25
Table 5-2 QA Objectivesfor Field Measurements

Q:\mwS'nProjects\I0002022\Veolia Perfomlance Test Plan U3 R2-052108.doc Field Measurement Moisture (EPA Method4) Carbon Dioxide (EPA Method

### 3 

## -Orsat Analysis) Oxygen (EPA Method 

### 3 

### - Orsat Analysis) (a) Not determinable. (b)An accuracy of i0.2% would be expected if a certified gas audit is performed. Otherwise individual readings must be within 0 

### 3 glg-mole of the mean value for three (replicate) readings. (c)An accuracy of 20.8% i0.5% would be expected if an ambient air audit is performed. Accuracy (a) (b) (c) Precision 

# +20%



### NIA NIA Completeness 100% 100% 100%Veolia ES Technical Solutions MACT Performance Test Plan Revision: 0 Date: May 2008 Section: 5.0 Page 20 of 25
Table 

### 53 Overall Summary of Performance Test Stack Gas Sampling and Analysis Program

Q:\mwS~Projects\l0002022\Veolia Performance Test Plan U3 R2-052108.doc Sample Matr~x and Sarnpl~ng Method EPA M 29 EPA M 3 Fac~l~ty CEM (a) MAX = Maxxam Analytical. Burllngton,Ontarlo Veolla = Veolla ES Techn~cal Solut~ons (b) Target metals Include arsenlc, beryllium,cadmlum, chrom~um, lead and mercury Total Samples Analyzed Analytical Parameters

Metals (b) O2and COz O2and CO Total Runs

3 3 3 Analytrcal

Method EPA M 601OB16020/7000 EPA M 3 (Orsat) Facil~ty CEM QA Plan Lab QC

1 0 0 Lab (a) MAX ENSR Veolia F~eld Blanks 1 0 0 Total 5 3 3 Audit

0 0 0Revision 0 Date- May 2008 Section: 5.0 Veol~a ES Technical Solutions IVACT Performance Test Plan Page 21 of 25
Table 

### 54Traverse Point Locations STACK INSIDE DIAMETER: 39 inches SAMPLING LOCATIONS: 9.85 diameters downstream 15.1 diameters upstream MINIMUM NUMBER OF TRAVERSE POINTS 12 AS SPECIFIED BY EPA METHOD 1: IVUlVlBER OF TRAVERSE POINTS SAMPLED: 12
Percent of Stack Traverse Point Diameter Distance in Inches Number From Inside Wall From Inside Wall
1 95.6 37.3 2 85.4 33.3 3 70.4 27.5 29.6 11.5 14.6 5.7 4.4 1.7

Q?mw97\Projects\lO002022\Veolia PerformanceTest Plan U3 R2-052108.docRevision: 0 Date: May 2008 Sectjon: 5.0 Veolia ES Technical Solutions MACT PerformanceTest Plan Page 22 of 25


### Table 5-5 Sample Preservation and Holding Time Requirements 

### Stack Gas Samples 'a'

Q:\mwS~Projects\l0002022\Veolia PerformanceTest Plan U3 R2_052108.doc 

### Parameter Metals (Method29) (except Hg) 

### Mercury (Method 29)

(a) Holding times will be calculated from the day of sample collection. Matrix Aqueous Solid 

### I Filter Aqueous SolidIFilter Preservation Cool, 4°C Cool, 4°C Cool,4°C Cool, 4°C Holding Time 6 months 6 months 28 days 28 daysVeolia ESTechnical Solutions MACT Performance Test Plan Revision: 0 Date: May 2008 Section: 5.0 Page 23 of 25
Table 5-6 

### QA Requirements for Metals in Stack Gas by ICAPor ICP-MS

Q:\mw97\Pro~ects\l0002022\Veolia PerformanceTest Plan U3R2-052108 doc Quality Parameter Calibration

Accuracy - ICV Accuracy - filters Accuracy Precision Blanks
RPD = Relative Percent Difference ICAP = Inductively Coupled Argon Plasma ICP-MS= Inductively Coupled Plasma - Mass Spectrometry ICV = Initial Calibration Verification Method Determination Initial analysis of standards Continuing mid-range calibration standard Continuing calibration blank Analysis of calibrationcheck standard Analysis of NlSTstandard reference filters or EPA audit filters, if provided Post-digestion spikes Post-digestion spikes Freld Reagent Blanks and Method Blanks Frequency Daily At least once before and after sample analysis With continuing calibration standard After every initial calibration Once pertest Once pertest Once per test One each per test Target Criteria Analysis of calibration check standard within 10% of true value 90-110% Subject to interpretation 90%to 11 0% of true value 70% to 130% of reference value 70%to 130% recovery RPD < or = 35% Evaluatedon case by case basisVeolia ES Technical Solutions MACT Performance Test Plan Revision: 0 Date: May 2008 Section: 5.0 Page 24 of 25 

### Figure5-1 

### Stack Sampling Locations

Q:\rnw9AProjects\l0002022\Veolia PerformanceTest Plan U3 R2-052108.docRevision: 0 Date: May 2008 Section: 5.0 Veolia ES Technical Solutions MACT Performance Test Plan Page 25 of 25 Figure 5-2 Example Sample Packing List



### SAMPLE PACKING LIST 

# 11 Proiect Site: Date : !Proiect Iomon: 

# 11

Q:\mw97\Projects\l0002022\Veolia Performance Test Plan U3 R2-052108.doc Relinquished by (Print) Date: Stgnature: Time: Relinquished by (Print) Date: Signature: Time: Received by (Print) Date. Signature. Time: Received by (Print) Date: Signature: Time: Analytical Laboratory:

Received by. Date: Signature: Time:Veolia ES Techn~cal Solutions MACT PerformanceTest Plan Revision: 0 Date: May 2008 Section: Appendices



## Appendix A 

## Unit 3 Process Flow Diagram

Q:\mw97\Projects\l0002022\VeoliaPerformanceTest Plan U3 P.2-052108 docSPECIALTY FEEDER EMISSION CONTROL EMISSION CONTRO PRIMARY SYSTEM

FUEL 

# - FUELSflQUlD WASTE FLOW 

### - --c COMBUSTION AIR FLOW STACK GAS FLOW CCCCCC, ASH FLOW rOOOOc SOUD WASTE FLOW +A++ UME SLURRY FLOW VEOLIA ENVIRONMENTALSERVICES TRADE WASTE INClPERATlONRevision: 0 Date: May 2008 Veolia 

### ES Technical Solutions MACT Performance Test Plan Section: Appendices



## Appendix B 

## Field Data Sample Collection Forms

Q:\rnwSAProjects\l0002022\Veolia Performance Test Plan U3 R2-052108.doc.. 

### - -- 'OM ~OX 1awd wa!wao3 WI!~

### ORSAT ANALYSIS (EPA METHOD 3)

Valid Leak Check : Liquid level must not fall not change by more than

When less than 4%, difference between readings shall be 

### 0.2% or less.



### * Net 0, is actual 0, minus actual C02reading.

Q \mw97\Pro]ecrs\lDDD2022\Append1x 6-all ~inirs\[OrsatAnalyslsForm xls]A

### SAMPLE TRAIN MOISTLIRE RECOVERY DATA SHEET

# ENSR

# 1 AECUM

NOZZLE CALIBRATION FORM Client: Project #: 

### Date: Calibrated by:

Where: Dl ,,3 = 

### Nozzle diameter measured on a different diameter to the nearest 0.001 

### in. Delta D 

### = Maximum difference between any two measurements, in. Tolerance 

### = 0.004 

### in. D,,, 

### = Average of D, ,Veolta ES Technical Solutions MACT Performance Test Plan Revision: 0 Date: May 2008 Section: Appendices



## Appendix C 

## lsokinetic Sampling Train Setup and Recovery Schematics

Q'\rnwS~Projects\l0002022\Veol1a Performance Test Plan U3 R2-052108.doc

## SAMPLE TRAIN SETUP MULTIMETALS (as 

## Per 

## EPA Method 29 

## / 0060)

I st empty * 2nd 

## -- 100 mL 5% HNO, / 10% H202 3rd 

### -- 100 mL 5% HNO, / 10% H202 4th 

### -- empty 5th 

### -- 100 mL 10% H2S04 14% KMnO, 6th 

### -- 100 mL 10% H2S04 14% KMnO, 7th Silica Gel


### FIELD BLANKS 

## -- (Exact Volumes Specified by Method)

Dl Water 

### 8 N HCI
Filter 

### -- 25mL (added to 200 mL water)



### -- One unused filter

* optional 

### - used for high moisturestacksNOZZLE 

# 1 PROBE 

# I FILTER HOUSING

BrushIRinse 0.1 N HN03 1- 25 mLj 3X 

# 1

FH - HN03 Container 3

Note I:Exactly 100 

### mL of 0.1N HN03 used for rinsing nozzle, probe and FH filter housing. from support with Tefloncoated tweezers and place in petri dish

Seal petri dish with



# 7

Filter Container 1 Note 

### 2: Nozzle, probe and FH filter housing are rinsed with water followed by acetone after the nitric acid rinse. The water and acetone arethen discarded.



### METHOD 29 

### (METALS) RECOVERY SCHEMATIC 

# - FRONT HALF RECOVERY Page 1 of 2FILTER SUPPORT AND BACK HALF OF

with 0.1 N Nitric Acid



### Note: Exactly 100 mL of nitric acid is used to rinse all components up through impingers 1-3. (Empty) (Optional)

I Measure Volume

Empty the Contents into Container

Rinse Three Times with 0.1 N Nitric Acid

(Container 4) 4th(Empty) 5thand 6th(KMn04) (Silica Gel) 

# u

Measure Volume Measure Volume

Empty the Contents into Container

# lRinse Three Times Empty the lmpinger No. 4 Contents into Container

Rlnsewlth 100 mL 0.1 N HN03

250 mL 0.1 N HN03 (Container 5A) 

# I Empty the lmpinger 

# I Nos. 5 and 6 Contents into Container

Rinse Three T~mes with Permanganate Reagent, (100

mL total) then with Water (100 mL total)

500 mL KMn04 (Container 5B) Residue with 25 mL 8N HCI

Solution

250 mL 8 N HCI (Container 5C) 

### METHOD 29 (METALS) RECOVERY SCHEMATIC

# - BACK HALF RECOVERY 

### Page 2 

### of 2