oEPA 

United States 

Environmental Protection 

Agency 

Public hearing scheduled 

EPA will hold a public hearing from 

3 to 7 p.m., at 

SlU-EdwardsviUe 

East St. Louis Higher Education 

Campus 

Distance Learning Lab, Room 2083 

BuildingS 

601 James R. Thompson Blvd 

If you need special accommodations 

to attend the hearing, contact 

Andrea Morgan at 

morgan.andrea@epa.gov 

by _ ____ _, 

How to comment 

You will have an opportunity to 

make oral comments at the public 

hearing. You may also send EPA 

written comments on Veolia's 

pe.nnit renewal from __ to 

-- There are several ways to 

comment (see Page 4 for details). 

For more information 

You may review the draft penni! 

and a document called a "Statement 

of Basis," which details reasons for 

the permit changes. Visit one of 

these libraries: 

Cent.ralLlbrary, 1301 Olive St, 

St. Louis. 

East St. Louis Library, 5300 State 

St., East St. l ouis. 

Cahokia Public Library, 140 

Cahokia Park Drive, East StLouis. 

Facility tours available 

Veolia is offering tours of its Sauget 

facility. To arraoge a tour, contact 

Doug Harris, 618-271-2804. 

Air Permit Renewal Planned 

for Hazardous Waste Incinerator 

Veoli.a ES Technical Solutions Air Permit 

Sauget, Illinois 2014 

The U.S. Enviroomeotal Protectioo Ageocy plans to reoew a Clean Air Act 

Title V operating permit for Veolia ES Technical Solutions LLC. The pennit 

is for a facility at 7 Mobile Ave. that stores and burns hazardous waste. EPA 

is accepting public commeots oo the reoewaJ (see box, left). 

In addition to emissions limits, work practice requirements, and monitoring 

aod recordkeeping requirements found in Veolia's current penmt, the 

renewed permit would incorporate some changes, including: 

• Limits on how much arseoio, lead, mercury and other metals Veolia 

can put into its incinerators- called the "feedrate limits" or "OPLs" 

- based on results ofVeolia's perfonnance tests in October 2013. 

• Enhanced waste aoalysis procedures to eosure compliance with the 

metal feedrate limits. 

• Temporary (12montbs) installation and operatjoo of a special 

emissions monitoring system on each incinerator to ensure the 

feedrate limits are adequate to assure compliance with applicable 

emissions limits. 

• New requirements for emergency generators. 

Veolia will continue operating under il~ current permit uotil EPA either 

renews tbe permit or denies the company's application. 

Background 

The Cleao Air Act requires an operating permit- koown as a Title V pennit 

-for facilities that emit large amounts of air pollution. This permit details the 

amount of pollutioo the facility can emit aod what it must do to control the 

pollution. A Title V permit is valid for five years and may be reoewed in 

five .. year incrementS. 

EPA issued Veolia's initial permit Sept. 12,2008. In Jaouary 2013, EPA 

began a process to revise tl>e 2008 permit, but later chose to simply 

incorporate the proposed changes into Veolia's permit renewal. 

Pollutants affected by the permit 

Veolia 's Sauget facility emits a ,'3Jiety of pollutants rej.,'tolated by EPA, 

includiog: 

• Carbon moooxide. 

• Nitrogen oxides. 

• Sulfur dioxide. 

• Fine particles, known as particulate matter. 

• Volatile organic compounds. 

• Mercury. 

• Semi-volatile metals such as cadmium and lead. 

• Low-volatile metals such as arsenic .. beryllium and chromium. 

• Dioxins and furaos. 

• Hydrogen chloride. 

VES009336 
..... ..,.,.. 

I I t II 

I ;.,- l!'ll 

Vi~ ""' 00 lltrla Sl~ 

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---- <o>IIII.I$MN HA ruw - IIQ( R.Ofr 

~ Ul!l'l. · > PIIMI,j! ~ lQJII W>.$1l' AOfl 

M\ I ~ UW: $U!MY n.otl 

Tllis diagram showtl.hc Unit1 combustion proet!Ss. 11tecombustlon pr()(X!.Sses ofUnlu J un-d 4 tlrc slfghtl}' d(QCrcnt, but follow similar 

principles. 

Burning hazardous waste 

Hazardous waste - which is toxic, flannnable or 

corrosive and can react with other materials- can be 

produced by businesses or manufacturing operations. 

Burning hazardous waste, usually in specially designed 

incinerators, boilers and industrial furnaces, is one way 

to safely manage it. 

Burning reduces waste volume by converting solids and 

liquids to ash while destroying toxic organic 

compounds. Disposing of the ash in a landfill is safer 

and more efficient than disposal of untreated ha.zardous 

waste. The ash from hazardous waste combustion mu>1 

be tested. If it is still hazardous, it must be treated 

before it is disposed of in a landfill. However, the 

incineration of waste can result in emissions of 

hazardous air pollutants into the air. 

Veolia bas three hazardous waste combustors: #2, #3, 

and #4 (#1 was closed in 1992). Veolia receives 

hazardous waste in gas, liquid and solid forms. 

Veolia may store liquid waste in a tank farm prior to 

burning it Gases occasionally escape from the tanks, 

and carbon adsorption units are attached to each tank to 

help control these emissions. 

Veolia stores bulk solid wastes in a building prior to 

combustion. The structure is maintained at negative 

pressure so emissions don't escape. Before tbe waste is 

2 

bumed it is packaged into more manageable containers 

and any liquids are absorbed. 

Veolia bums gaseous wastes in Combustor #2 only. 

Each combustor has a primary and secondary 

combustion chamber that includes natural gas-fired 

auxiliary burners used during startup, shutdown, and 

malfunctions, and for additional beat input. The 

combustors are also connected to spray dryer absorbers 

and a baghouse, which help control air pollution. 

Combustor #4 also has a tempering chamber and 

activated carbon injection to further help control air 

pollution. Veolia is required to monitor continually tor 

carbon monoxide and hydrogen chloride emissions. 

The combustors are augmented by a lime handling 

system and an ash handling system. The lime handling 

system feeds lime to the spray dry absorber, as lime is 

an important material in Ibis air pollution control 

technology. The ash handling system ensures tltat ash 

produced during the combustion process is collected 

and properly disposed of. 

Changes to the permit 

A Title V penuit is an enforceable compilation of aU 

operating temtS, condit on.~ and limitations that apply to 

an emission source. It is meant to improve compliance 

by making clear the Clean Air Act requirements with 

VES009337 
which the facility must comply. The permitting 

authority ensures requirements that apply to the facility 

are included aod that there is enougb monitoring and 

recordkeeping required to verify that the source is in 

compliance with permit requirements. EPA, the Title V 

permitting authority for the Sauget facility, is proposing 

to make changes to and renew Veolia's existing penni!. 

Proposed changes to Veolia's monitoring requirements 

will verify the facility is complying with the feedrate 

limits and that tbe limits will assure compliance with 

the Clean Air Act (see "Monitoring, ''below). 

EPA also removed some requirements that no longer 

apply. For example, an emission limit previously 

included in the permit to meet federal standards for the 

boiler is oo longer applicable because BP A has 

promulgated new federal standards that apply to the 

boiler. EPA is therefore replacing that emissions limit 

with the new federal standards for boilers. 

Setting the limits 

Veolia's pennit includes emission limits established by 

the following regulations or pennits: 

• National Emission Standards for Hazardous Air 

Pollutants, or NESHAPs, which are standards 

promulgated under Section 112 of the Clean Air 

Act and promulgated under40 C.P.R. Parts 61 and 

63. Veolia is subject to the NESHAP for hazardous 

waste combuston;, 40 C.F.R. Part 63, SuhP'•n EEE. 

• New Source Perfonnance Standards, which are 

emission standards promulgated under the authority 

of Section Ill of the Clean Air Act and 

promulgated under 40 C.F.R. Part 60. 

• The Illinois State Implementation Plan, state 

regulations found at Title 35 of the Illinois 

Administrative Cnde, which are approved and 

made federally enforceable by EPA and codified at 

40 C.F.R. § 52.720. 

• Construction and operating permits issued by the 

Illinois BP A. 

Most requirements in the current pennit will not change 

in the renewal. However, EPA is adding feedrate limits 

for certain heavy metals and updating other operating 

parameter limits as required by federal regulations for 

hazardous waste combustors. These limits were 

established using the results of Veolia's October 2013 

comprehensive performance tests, and Veolia already is 

required to comply with the limits under the NESHAP 

for hazardous waste combustors, the "HWC MACT." 

Monitoring 

In the proposed revisions to the Title V permit, EPA is 

augmenting Veolia's fe<-dstream analysis procedures to 

ensure compliance with the metal feedrate limits. The 

3 

proposed enhanced waste analysis procedures would 

require Veolia to: 

• Sample and analyze each feedstream accepted for 

incineration unless specitically exempted. 

• Sample and analyze all batched, treated, blended, 

mixed or otherwise altered waste for mercury and 

other metals in its final fonn as feed for incineration 

prior to incineration, or perform a mass balance 

calculation to determine concentrations in the final 

hatched, treated, blended, mixed or otherwise altered 

waste. 

• Not batch, treat, blend, mix or otherwise alter 

feedstreams which are exempt from sampling unless 

Veolia samples and analyzes the otherwise exempt 

feed stream. 

• Document the concentration of mercury, L VM and 

SVM in any fuel other than natural gas, including 

used oil, diesel and alternative fuels fed into the 

incinerators by either obtaining analytical results 

from each fuel supplier or conducting representative 

sampling of each fuel supply and analyzing such 

samples using appropriate quality assurance/quality 

control procedures and test methods. Veolia would 

follow this procedure at least once per year for each 

fuel supply. 

• Document concentrations that fall below the 

detection limit in non-exempt feedstreams as equal 

to the detection limit. 

• Maintain records of all required feedstrearn analyses 

for five years. 

EPA also proposes requiring Veolia to tenaporarily 

install and operate a continuous emissions monitoring 

system, or CEMS, on each of its three combustion units. 

Veolia will operate the CEMSs as parametric monitoring 

systems to assess whether the operating parameter limits 

for specific metals are adequate to ensure compliance 

with federal rules. As parametric monitoring systems, 

the CBMSs will verify the adequacy of the leedrate 

limits. The systems will test the air emitted during 

incineration to determine the amount of mercury, semivolatile metals, low-volatile metals and other metals 

emitted, and report results approximately once every 15 

minutes. The test results will help Veolia and EPA 

ensure the feedrate limits are adequate to ensure that the 

facility can comply with the HWC MACT emissions 

limits for n1ercury, semi-volatile metals and low-volatile 

metals when complying with its metals feedrate limits. 

EPA will require Veolia to operate the CEMSs on a 

temporary basis until EPA has enough infonnation to 

determine if the proposed feedrate limits are adequate to 

ensure Veolia complies with the Clean Air Act. 

Once EPA has collected sufficient information, EPA 

will no longer require Veolia to use multi-metal CEMSs. 

VES009338 
' 

' 

Public comments encouraged 

The public comment period expires on"'<"'D'"' A-;;T'"E>"". All wrinen comments must be pos!lllarked or emailed no later 

than . EPA will consider all comments before making a tina! decision on tl1e permit renewal. If you 

submit a wrinen collliDent, include your name and address and all reasonable references, factual grounds and 

supporting material. Be sure to note whether you would like to receive notification ofEPA's final decision and its 

responses to comments. 

There are several ways to submit written comments: 

By visiting www.regulations.gov- put Docket ID No. EPA-ROS-OAR-2014-0280 intbe sea reb box. 

By mail to: 

George Czerniak 

U.S. EPA Region 5 (A-18J) 

77 W. JacksonBivd. 

Chicago, 1L 60604 

Public hearing details 

By email to: 

.John Mooney 

mooney.john@epa.gov 

At the public hearing you may submit a written statement or make an oral statement. There will be a 

signup sheet at the entrauce for those who wish to present oral testimony. Presentations will be given on a firstcome-first-served basis. A rourt reporter will record all oral statements. 

Each spea ker will be limited to five to I 0 minutes depending on the number of presenters. The EPA representative 

may ask clarifying questions during the oral presentations bur will not respond to the comments at that time. 

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VES009339 
VES009340 .pdf 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

RESEARCH TRIANGLE PARK, NC 2ntt 

Beth Brock 

Team Leader 

Eli Lilly and Company 

Tippecanoe Laboratories 

1650 Lilly Road 

Lafayette, IN 47909 

Dear Ms. Brock: 

JAN 2 7 1.1106 

E 

F 

tJUG 

OFFICE OF 

AlA QUAI:.ITY PlANNING ...., STANC>AAOS 

I am writing in response to your request for alternative monitoring described in detail in 

your Alternative Monitoring Petition (AMP) dated December 2, 2005, which requests 

alternatives to monitoring for Eli Lilly and Company's (Lilly) rotary kiln, solid-liquid 

incineration system, also known as the T-149 incinerator, that burns hazardous and nonhazardous waste. The T-149 incinerator is subject to the National Emission Standards for 

Hazardous Ai.r Pollutants from Hazardous Waste Combustors (HWC MACT) rule under 40 CFR 

63, Subpart EEE and the General Provisions under 40 CFR 63, Subpart A. The T-149 

incinerator is located at the Lilly Tippecanoe Laboratories in Lafayette, Indiana. 

The HWC MACT rule requires that Lilly monitor certain operating parameters 

continuously, but not the actual pollutants [metals, particulate matter (PM), and hydrogen 

chloride and chlorine (HCVCJ,)]. However, Section 63.1209(a)(5) of the HWC MACT allows 

facilities to petition the Administrator under Section 63.8(f) oftbe General Provisions to use 

continuous emissions monitoring systems (CEMS) for compliance monitoring of pa.rticulate 

matter, mercury, semi-volatile metals, low volatile metals, and hydrochloric acid/chlorine gas 

emissions in lieu of complying with corresponding operating parameter limits. In addition, 

Section 63.1209(g) of the HWC MACT allows facilities to submit an application to the 

Administrator to request approval of alternative monitoring requirements to demonstrate 

compliance with operating parameter Limits monitored by parametric instruments. 

You are proposing to install and operate CEMS for metals, PM, and HClto directly 

demonstrate continuous compliance with the semi-volatile metals, low-volatile metals, mercury, 

particulate matter, and HCI/CI2 emission limits as an alternative to monitoring operating 

parameter limits that are shown in the attached table. As required by the HWC !v!ACT, you are 

also proposing to install and operate CO and ~ CEMS to demonstrate compliance with the CO 

emission limit, corrected to 7 percent oxygen. 

ln....,.IM:Iteu(URL) • "'-' Jwww- QOV 

R~eMd/R..:yctabllt •Prlm.IIW.tl V~ Oil Bawd Inks M AecyoledPtl* (Mir6num 2.5% Pos1COI\SurMr) 

VES009340 
2 

Pursuant to Section 60.8(1) of the General Provisions of 40 CFR 63 and 40 CFR 

63.1209(a)(5) of the HWC MACT, the U.S. Environmental Protection Agency hereby approves 

your request for the alternative monitoring approach, associated QA/QC procedures, and the 

backup monitoring conditions as described in detail in your December 2, 2005 AMP and its 

associated appendices. The approved alternative monitoring modes and averaging periods are 

summarized in the enclosed table. This approval is only applicable to the Lilly facility cited 

above. · 

If you have further questions on this matter, please contact Dan Bivins at (919) 541-5244. 

Enclosure 

Sincerely, 

(1.,,;-t~~-~ 

ConniesueB. Oldham, Ph.D., Group Leader 

Air Measurements & Quality Group 

cc: Steve Friend, Indiana Department of Environmental Management 

Brent Marable, Region 5 

Sarah Marshall. Region 5 

Beth Valenziano, Region 5 

Ethan Chatfield, Region 5 

Pamela Blakley, Region 5 

Sam Portanova, Region 5 

Bob Holloway, EPA, OSW 

Tom Driscoll, EPA, OAQPS 

Barrett Parker, EPA, OAQPS 

Peter Tsirigotis, EPA, OAQPS 

VES009341 
TABLE 1. ROTARY KILN INCINERATOR EXPECTED HWC MACT OPERATING AND EMISSION LIMITS 

: : . .: )·s: ' .;/ . 

JI0W 

l:STNBLISHED ~ .... . M~~ LIMIT 

owe MA CT L I MIT AND . 1'lMI: MONITORED IN 

MtASlJRED Mmll: PAJMMETRIC 

MODE 

!Wns1'SE1 .UNIT 

63, ~~~·~ 1205 G)) . Houtl)' toft~~ ••• ... Nuiii'IJIII~dllrilef~ Bi , .. . · N9 NO 

Mt;li!NIIII 11..-.., tow tale M ~-• U..120t{6_(2) Hr:u!ty ....... ... ... ' 

~or....-blll~$3..12090) l!ltli'nlm 

-*N~ ..... ~ *"rdlnQ~ .... ... 

~m:li'IOII~tlrislionra 63..12-0i(., HWCtMCl HO\If\v fOfltV ... >a ... 

• wiTJIWiST.£ FEED 

~ms.okS-sat fMd e3.1209 Ul l'tol.lt; f\1lt'lg~fiGO ... YES 

MillliiNiftiOIII)'kii(!IIM*.Y~Md U9tfl F. 

{." 

..... VES •_.,.,·<""_?, '· 

~lftfOfltyNin~'A'Mtt,_,_43..120tO) , .. YES 

• . . 

~soc~ ~o¥Nit rMd rm 83,1:zoi Q) ... "'*'-"Oft....,...._."' tblirltllai~ l:toullydfiQ~ YES ""' ,.,'""""soc~~r•AI~t63 20e(f) A'**OidN~ HOully 1011110 a''*8Qt .... YES '*"QtiCU'~ 

iMTil . ' 

PMIICUIN El'liWofl Liri $4'1ourl'(illl'l~·~ 

fl'omlfodl. hcuJ ......... ves NO 

VES009342 
owe MACT LIMIT 

l.la't.!IWIII'IICIIICS eordt!!l Oft'lt ~~ ta\101)11 

SO'Ubbct 

wa~trv<sCMS 

tatlk WiiU'I'It 

orfriri~A~m~ 

(If lew! 

,.,. afld fi'* ~ 

~"¥¥'d IOfN tlllo {Uillor triNrutfi....,Md 

!MIIiln.lm tuf ~ fb,ot ~'"" ..... HVOr~Sol1e. tciVM!tf 

~$c:rllc:l~~rnM'IUquiCI100M Raa:o(VG)Ct 

ltlllnimum IIQu\4 & .,...SmM! M OM ll(lorf ralet 

~~mw.n.vnUQufd toO..Rato(iJG)Ot .:inltl\lfi'IIIQo.id6f!Uiflll!ll._gM!bttt81tf 

HOW 

EST.MJLISHED 

AND 

MEASURED 

" ,:, , 

c(--~NI\ 

· 

AVERAGING 

TIME '

, 

1 ........ 

2 

NO 

LIMIT 

1\fONJTORED 

INCEMS 

MODE 

NO 

YES 

NO 

NO 

NO 

NO 

U:IIIIT 

MONITORED IN 

PARAMETRIC 

MODE 

~ 

..01-..d .. NWnfliq 

Pcl~~~tnf~Cl~J*$1 

under ~)CIIMlo.C W.Cl 

ViS 

NO 

YES 

VES009343 
- $'A ~Qle 

~= :n.nu.:.~ ,.. NO 

niaiotl~ I_: 

~ ~ 

........ __ 

VIS "" 11'08\tllocl "'* ~ 

~f*r Of"'*CCll'' I~ 12 . .fli)Ut ~ ...... ... ..... ~ 

~'" r.,.; ~ ol $\IN ~--~ .... ,..--.... .,.-~ ~ 

12-no.r ro1ir1t f;lltf'l9t NO .,. 

·: ·.· . 

1>- ·-.- " 

H we MA CT LIMIT t~Mi LIMIT iiril MONrOOUD IN ME.( StiltED _-: :-, P~RIC 

~ teedt* d l \'1.1 ~e and tolat fee6!olet ~oth'-1¥"1MQU -o-riN~ 

-· •a.-.~ • .,.. HO vu 

~~total cftlorl,.. .-I cHoridef«d '*' ~t:itle 'eotN\ 

- 1;:.tlour~ _... NO Yl$ 

MjtlimJm l)fen~~~e Olol) wou IN Hljcrl) -Sc:riel ~ o\Wn:l)ldh:tMII\IIl Hourlylli,......,.. NO ~'«< ~$1RG'op 

-.:· . . ·· NO .... Mnl!w.mtlQI.Iid e..s~toChe · . "" ..... 

waw 

Nalolii\A$01ICitQOnstr'IICifN~~ 

~eMS orm-.....n~catt'IIM.,~ ~d!M . ..a'Nn NO -... - ~t;~nt\O"...,.. ....-

- Ul'lil.w 

---t2IBJ;)ciKWCMA.CT 

-- ~ .3 .. ,_: 

~SCUCJl tonltfll Of ... lt)'t\'Oo.Sonlcs SCJ-'\Ibbel' ..... ,. ~of-I'A-tt&ttun 

~"'jf CMI.\or,.......,.~ta14and.,_ tr*im.ICJ\I!Mt NO VU.WaCMS \;Ink WlltlmtOtll'wt!l 

-- liMi 

COndiiNtr~lrini!Ntlt QIJidlloO.~Io{VG)'O" A~dl'leldtf\.1" Hol.wty~~ ... NO '" m1n1-11q~ & ma~flue gg.~ tow1'1611i 

-- H)~u -.rubber m\Wum LIQIIId to GIP IW.Io (\.JG} or 

IIWVn\lm~ & ~ M91itlowtat.f ~dt\tt.sli'UI'I 

- Hol.ilrW rdlltiO....,.., NO YU 

• This limit is also an ildicator of compliance with the SVM, L VM, PM, and HCVCI2 emission limits. NA = 

Not Applicable CMS = Continuous Mon"oring System 

3 

VES009344 
VES009345. pdf 
ALTERNATIVE MONITORING PETITION FOR THE 

SOLID-LIQUID INCINERATOR 

Ell Lilly and Company 

Tippecanoe Laboratories 

1650 Ully Road 

Lafayette, IN 47909 

October 2005 

Revision: 7.0 

VES009345 
Ell Lilly and Company 

Lafayette, Indiana 

TABLE OF CONTENTS 

Alternative Monitoring Petitio n 

1.0 INTRODUCTION ................................................................................................................... 1 

2.0 ENGINEERING DESCRIPTION ............................................................................................ 3 

2.1 KEY COMPONENTS ...................................................................................................... 3 

2.2 SYSTEM OVERVIEW ..................................................................................................... 4 

3.0 CANDIDATES FOR ALTERNATIVE MONITORING UNDER §63.8(1) ................................. 6 

3.1 PARTICULATE MATTER CEMS .................................................................................... 7 

3.1.1 Indicator of Performance ................................................................................. 7 

3.1.2 Measurement Technique ................................................................................. 7 

3.1.2.1 Operating Principles ...................................................................•..... 7 

3.1.2.2 Installation Location ...................................................................•..... 9 

3.1.2.3 Installation .......................................•................................................ 9 

3.1.2.4 Instrument Span ............................................................................... 9 

3.1.2.5 System Start Up (Initial Operation) .................................................. 9 

3.1.2.6 PM CEMS Calibration Correlation Test (PM CEMS 

Certification) ................................................................................... 12 

3.1.2.7 Routine Operation of the PM CEM$ .............................................. 16 

3.1.2.8 Component Replacement. ............................................................. 19 

3.1.2.9 Out of Control ................................................................................. 19 

3.1.3 Use of the PM CEMS for Compliance with the HWC MACT PM 

Standard ........................................................................................................ 20 

3.1.4 Monitoring Frequency and Averaging Time .................................................. 20 

3.1.5 Rolling Block Average Calculations during Routine Checks and 

System Audits ................................................................................................ 21 

3.1.6 Backup to tha Particulate Matter CEMS ........................................................ 22 

3.1.7 Deviations from Performance Specifocation 11 ............................................. 23 

32 MULTI-METALS CEMS ................................................................................................ 25 

3.2.1 Indicator of Performance ............................................................................... 25 

3.2.2 Measurement Technlque ............................................................................... 26 

3.22.1 Operating Principles ....................................................................... 26 

3.22.2 Installation Location ....................................................................... 29 

3.2.2.3 Installation ...................................................................................... 29 

3.2.2.4 Instrument Span ............................................................................. 29 

3.2.2.5 System Start-up (Initial Operation) ................................................ 29 

3.2.2.6 System Start-up (Field Installation) ................................................ 30 

3.2.2.7 Performance Specification Test. .................................................... 31 

3.2.2.8 Routine Operation of the Multi-Metals CEMS ................................ 34 

3.2.2.9 Component Replacement .............................................................. 37 

Rev. 7.0 

VES009346 
Ell Lilly and Company 

Lafayette, Indiana Alternative Monitoring Petition 

3.2.2.10 Out of ControL ............................................................................... 37 

3.2.3 Use of the XACT Multi Metals CEMS to Demonstrate Compliance 

with the HWC MACT Metals Standards ........................................................ 37 

3.2.4 Monitoring Frequency and Averaging Time .................................................. 37 

3.2.5 Block Average calculations during Multi-Metals GEMS Dally Checks 

and Ongoing Quality Assurance Checks ....................................................... 39 

3.2.6 Multi-Metals CEMS Backup ........................................................................... 39 

3.3 HYDROGEN CHLORIDE (HCI) CEMS ......................................................................... 40 

3.3.1 Indicator of Perlormance ............................................................................... 40 

3.3.2 Measurement Technlque ............................................................................... 41 

3.3.2.1 Operating Principles ....................................................................... 41 

3.3.2.2 Installation Location ....................................................................... 43 

3.3.2.3 Installation ...................................................................................... 43 

3.3.2.4 Instrument Span ............................................................................. 43 

3.3.2.5 System Start-tJp (Initial Operation) ................................................ 43 

3.3.2.6 System Start-tJp (Field Installation) ................................................ 44 

3.3.2.7 Performance Specification Test ..................................................... 44 

3.3.2.8 Routine Operation of HCI CEMS ................................................... 47 

3.3.2.9 Out 01Control ................................................................................ 49 

3.3.3 Use of HCI CEMS for Demonstrating Continuous Compliance with 

the HCIIC12 HWC MACT Emission Standard ................................................. 49 

3.3.4 Monitoring Frequency and Averaging Time .................................................. 50 

3.3.4.1 Rolling Average Calculations during HCI CEMS Daily 

Calibration and Ongoing Quality Assurance Audits ....................... 51 

3.3.4.2 Rolling Average Calculations during System Autopurge ............... 51 

3.3.4.3 PM and HWC MACT Metals Rolling Average Calcutat.ions 

during Ecochem CEMS Daily Calibration and Ongoing 

Quality Assurance Audits ............................................................... 52 

3.3.5 Backup to the HCI GEMS .............................................................................. 52 

3.4 JUSTIFICATION FOR REQUEST FOR ALTERNATNE MONITORING 

METHOD ....................................................................................................................... 53 

4.0 ALTERNATIVE MONITORING CANDIDATES UNDER 63.1209(g) ................................... 54 

4.1 STACK GAS FLOWMETER DAILY CHECK AND AUTOPURGE ................................ 54 

4.2 COMBUSTION GAS FLOW RATE OPERATING PARAMETER LIMIT ....................... 54 

4.3 CALCULATION OF ROLLING AVERAGES WHEN ALL ONE-MINUTE 

AVERAGE VALUES ARE NOT AVAILABLE ................................................................ 55 

5.0 ALTERNATIVE MONITORING PETITION APPROVAL ..................................................... 56 

6.0 RELEVANT REFERENCES ................................................................................................ 57 

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Lafayette, Indiana 

FIGURES 

Figure 1. Block Flow Diagram of Solld-Uquid Incinerator 

Figure 2. Sigrist Particulate Matter CEMS 

Figure 3. T149 CEMS Data ExChange 

Figure 4. Multi-Metals CEMS (XACT) 

Figure 5. Ecochem CEMS (HCI) 

Figure 6. Ecochem Dynamic Spiking Overview 

TABLES 

Altematlve Monitoring PetiUon 

Table 1. Rotary Kiln Incinerator HWC MACT Operating and Emission Limits 

APPENDICIES 

Appendix A: EPA Draft Guidance Document for PM CEMS 

Appendix B: XACT Multi-Metals CEMS Guidance Documents, Perlormance Specifications, and Quality 

Assurance Documents 

Appendix C: HCI CEMS Performance Specification, HCL CEMS Quality Assurance Documents 

Appendix D: Ctted Performance Specifications and Oualtty Assurance Procedures 

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Eli Lilly and Company 

Lafayette, Indiana 

1.0 INTRODUCTION 

Alternative MonHorlng Petition 

Eli Lilly and Company (Lilly) operates a rotary kiln incineration system located at the Lilly Tippecanoe 

Laboratories in Lafayette. Indiana. The rotary kiln is referred to as the solid-liquid incinerator. The solid· 

liquid incinerator is used to bum hazardous and non-hazardous sol.id wastes and hazardous liquid 

wastes. The solid-liquid incinerator is subject to requirements of the hazardous waste combustor 

maximum achievable control technology (HWC MACT) rule under 40 CFR 63 Subpart EEE and the 

General Provisions under 40 CFR 63 Subpart A. 

The HWC MACT places considerable emphasis on continuous monitoring for demonstrating compliance 

with applicable emission standards and operating parameter limits. As such, facilities are required to 

Install continuous emission monitoring systems (GEMS) that continuously monltor and record emission 

data and continuous parametric monitoring systems (CPMS) that continuously monitor and record 

operating data. Section 63.1209(a)(5) of the HWC MACT allows facilities to petition the Administrator 

under Section 63.8(1) of the General Provisions to use GEMS for compliance monitoring for particulate 

matter, mercury, semivolatile metals. low volatile metals. and hydrochloric acid/chlorine gas in lieu of 

complying with corresponding operating parameters. Section 63.8(1) of the General Provisions allows 

facilities to request approval of an alternative monitoring petition to use attemative GEMS to demonstrate 

compliance with the applicable MACT requirements. In addition, Section 1209(g) of the HWC MACT 

allows facilities to submit an application to the Administrator to request approval of alternative monitoring 

requirements to document compliance with operating limits monitored by parametric instruments. 

As required by the HWC MACT, Lilly will Install and operate a CO and 0 2 CEMS to demonstrate 

compliance with the CO emission limit. corrected to 7% oxygen. Lilly is also proposing to install and 

operate GEMS for multi-metals, particulate matter, and HCI to demonstrate anainment with the semivolatile metals. low-volatile metals, mercury, particulate matter, and HCI/Ciz emission mils. Pursuant to 

Section 63.1209(a)(5) of the HWC MACT, Lilly will not be required to use CPMSs to continuously monitor 

operating parameters identified in Section 1209 of the HWC MACT when CEMS are used to demonstrate 

compliance with the metals, particulate matter, and HCVC12 HWC MACT emission standards. However, 

when the CEMS are not in use, Lilly will operate CPMSs to monitor and demonstrate compliance with the 

corresponding operating parameter limits (OPLs) to avoid shutting down hazardous waste feed to the 

sOlids-liquids incinerator. Table 1 provides a summary of which HWC MACT standards will apply while 

operating the alternative CEMS (CEMS mode). and which operating parameter limits win apply when a 

CEMS are not in use (parametric mode). 

Rev. 7.0 

VES009349 
Eli Lilly and Company 

Lafayette, Indiana Alternative Monitoring Petition 

Ully submitted an earlier version of this Alternative Monitoring Petition to EPA in conjunction with the 

Comprehensive Performance Test Plan in September 2003 to address alternative requests under Section 

40 CFR 63.8(1) Use of an alternative monitoring method and 40 CFR 63.1209(g) Alternative monitoring 

requirements other than continuous emissions monitoring systems (CEMS). EPA responded to the 

majority of the parametric monitoring requests under 40 CFR 63.1 209(g) in a letter dated February 27, 

2004 which was signed by George T. Czerniak, Chief of the Air Enforcement and Compliance Assurance 

Branch, EPA Region 5. Therefore, those Section 1209(g) parametric monitoring requesls formerly in 

Section 4.0 of this document addressed by EPA's February 27, 2004 letter have been removed from this 

revision of the Alternative Monitoring Petition. 

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2.0 ENGINEERING DESCRIPTION 

The key components of the solid-liquid incinerator are described below. The Comprehensive 

Performance Test (CPT) Plan for the solid-liquid incinerator provides a more detailed engineering 

description of the Incinerator. 

2.1 KEY COMPONENTS 

The foUowing are the key components of the solid-liquid incinerator: 

Waste Feed SVstem The waste feed system Is designed to feed solid and liquid wastes to the rotary 

kiln, and liquid wastes to the secoodary combustion chamber (SCC). 

Rotary Kiln - The rotary ki.ln is a refractory-lined cylinder that rotates while incinerating solid and liquid 

wastes. 

Wet Ash Handljno Svstem- Hot, dry ash from the rotary kiln is cooled and has moisture added in the wet 

ash handling system. 

Yertjcal Up-Flow sec - The combustion gases from the rotary kiln enter the sec whiCh is designed to 

complete the combustion of the gases from the kiln, and to bum primary liquid (high BTU content) end 

secondary Liquid (low BTU content) wastes. 

NO. Abatement Svstem - The hot combustion gases enter the selective non-catalytic reduction (SNCR) 

system which uses urea Injection to reduce NO, emissions. The NO, Abatement System does not meet 

the regulatory definition of a low or a high-~mergy wet scrubber and the operation of the NO, abatement 

system Is not regulated by the HWC MACT regulations. 

Oueneh - The combustion gases from the NO, abatement system enter the quench where the 

combustion gases are cooed to their adiabatic saturation temperature. The quench is not designed nor 

intended to be an air pollution control device. The quench does not meet the regulatory definition of a low 

or a high energy wei scrubber and the operation of the quench Is not regulated by the HWC MACT 

regulations. 

Condenser/Absorber - The combustion gases from the quench enter the coodenser/absorber where the 

gases are cooled to below their adiabatic saturation temperature. The condenser/absorber provides 

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additional conditioning of the combustion gases exiting the quench. The condenser/absorber is 

considered a low energy wet scrubber according to the HWC MACT regulations 

Hydro§onic"' Scrubber - The combustion gases from the condenser/absorber enter the Hydro-Sonic 

scrubber where particulate and metals are removed from the combustion gas stream. Removal of acid 

gases is also provided. Steam injection can be used to enhance the particulate removal. The HydroSonic scrubber Is considered a high energy wet scrubber according to the HWC MACT regulations 

A block flow diagram ol the sotid iquld Incineration system is provided in Figure 1. 

2.2 SYSTEM OVERVIEW 

The incineration system is designed to combust solid as well as primary and secondary liquid wastes. 

Solid wastes are fed through the solid waste feed system on the rotary kiln. Liquid wastes can be fed to 

both the rotary kiln and sec. The combustion gas from the treatment of the wastes is treated in a wet air 

pollution control (APC) system consisting of a NO, abatement system, a full quench, condenser/absorber, 

Hydro..Sonic scrubber, and stack. An induced draft fan is the combustion gas prime mover. 

The function of the quench is to adiabatically cool the combustion gas via saturating water sprays. The 

quench consists of a vertical. cylindrical, brick·llned chamber. Fresh and recirculating water is sprayed 

through quench nozzles to adiabatically saturate and cool the inlet combustion gas. 

Saturated combustion gas from the quench enters the lower portion ol the condenser/absort>er. 

Combustion gas flows up through the packed section. Recirculated water is introduced to the top of the 

packed section and flows countercurrent to the combustion gas flow for additional combustion gas cooling 

and conditioning. 

Combustion gas from the condenser/absorber flows to the Hydro-Sonic scrubber. The Hydro-Sonic 

scrubber removes fine particulate maHer by inertial impaction. Particulate removal efficiency is a function 

of the pressure differential aaoss the Hydro-Sonic scrubber. The differential pressure is dependent on 

the flow of combustion gases and water through the Hydro..Sonic scrubber. The combustion gas flow 

changes with changes in the Incinerator condiUons. The water flow to the Hydro-Sonics scrubber Is a 

combination of recirculated water and makeup water. Steam injection can be used to enhance the 

particulate removal of the Hydro-Sonlcs scrubber. 

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An induced draft (10) fan draws the combustion gas through the combustion chamber and APC system 

and discharges the gases through an FRP (or equivalent) stack conslructed with sampling ports and 

platfO<ms. 

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Eli Lilly and Company 

Lafayette, Indiana Alternative Monitoring Petition 

3.0 CANDIDATES FOR ALTERNATIVE MONITORING UNDER §63.8(f) 

Lilly intends to Install and operate a particulate matter GEMS, a multi-metal~ GEMS, and an HGI GEMS to 

demoostrate comp ian~ with the particulate matter, metals, and HGI/G12 HWG MAGT emissioo 

standards. As previously stated, Section 1209(a)(5) of the HWG MAGT allows Lilly to petition the 

Administrator under Section 63.8(f) of the General Provisions to use GEMS for compl an~ moottoring for 

particulate matter, mercury, sernivolatile metals, low volatile metals, and hydrochloric acid/chorine gas In 

lieu of complying with the correspondlng HWG MAGT operating parameter limits. As required in Sectioo 

63.8(f), this application must contain a description of the proposed alternative monitoring system and 

address the four elements contained In the definition of monttonng In Section 63.2 of the General 

Provisions. Those four elements are as follows: 

1) lndlcator(s) of Performance: The parameter or parameters you measure or observe for 

demonstrating proper operation of the pollution control measures or compliance with the 

applicable emissions limttation or standard. Indicators of performance may Include direct or 

predicted emissions measurements and may be expressed as a single maximum or minimum 

value; 

2) Measurement T echnlques: The means by which you gather and record information of or about 

the indicators of performan~. The components of the measurement technique include the 

detector type, location and Installation specifications, Inspection procedures, and quality 

assurance and quality control measures; 

3) Monkoring Frequency: The number of times you obtain and record monttoring data over a 

specified time interval. Examples of monitoring frequencies include at least four points equally 

sp~ for each hour for GEMS; and 

4) Averaging Time: The period over which you average and use data to verify proper operation of 

the pollution control approach or compliance with the emlssioos limitation or standard. 

Pursuant to Section 63.8(f)(4)(ii), the application must also contain a performance evaluation test plan 

(PETP) if requested. The detailed Information contained in this petition meets the requirements of 40 

GFR 63.8(e)(3)(i) which speCifies the information that must be contained in a GMS PETP. Therefore, the 

PETP requirements for the particulate matter GEMS. the multi-metal GEMS, and the HGI GEMS are met 

through submission of the detailed alternative monitoring petition. 

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Lafayette, Indiana Alternative Monitoring Petition 

In addition, Seclion 3.4 of this alternative monitO<ing petition includes infonnation justifying the request for 

an alternative monitoring method, such as the technical or economic unfeasibility, or the impracticality, of 

the affected source using the required method. This meets the requirements of Section 63.8(1)( 4 )(li). 

3.1 PARTICULATE MATTER CEMS 

3.1.1 Indicator of Performance 

The particulate maHer CEMS is designed to continuously monitor the stack gas particulate matter 

concentration. Compliance with the particulate HWC MACT emission standard is demonstrated when the 

particulate matter measured stack concentration is less than or equal to the applicable standard. 

Currently, Lilly must comply with the interim PM standard of 34 mg/dscm, corrected to 7 percent oxygen, 

specified under Section 63.1203(b) of the HWC MACT. Lilly will comply with the HWC MACT flnal PM 

standard specified in Section 63.1219(a) no later than the date required by Section 1206(a)(1)(ii) of the 

HWC MACT Final Replacement Standards. The averaging time for both the interim and final PM 

standard is a 6-!1our roiling average, updated every hour. 

3.1.2 Measurement Technique 

3.1.2.1 Operating Principles 

The total particulate mass continuous emission monitoring system Is a Sigrist Dust Emission Measuring 

System CTNR (or equivalent), manu1actured by Sigrist Process-Photometer, AG. The Sigrist system is 

intended to measure particle mass concentration from the Incinerator stack. It will withdraw a 

representative sample of the exhaust from the stack and transport it, via the Sigrist ring pipe, for 

measurement by the photometer. The sample transport system maintains sample stream temperature at 

approximately 160 •c (320 Of). A portion of the sample stream is separated (reducing orifice) and 

measured by the photometer. then merged back Into the main sample stream for transport back into the 

incinerator stack. A data acquisition system collects particle measurement data from the photometer 

through the Sigrist Controller. Figures 2 and 3 Illustrate the major components of the Sigrist GEMS, which 

include: 

1. Sample Extraction System 

2. Photometer 

3. System Controller 

4. Data Acquisition System (DAS) and HiStorian 

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Eli Lilly and Company 

Lafayette, Indiana 

3.1.2.1.1 Sample Extraction System 

Allemative Monitoring Petition 

The Sigrist sample system consists of a sample p.-obe and ring pipe. The sample probe size was 

selected by the manufacturer to provide an inlet gas velocily that Is app.-oxlmately 1.0 - 1.5 times greater 

than the normal stack gas velocity when sampling at the preset (design) rate of approximately 1 acmlmin. 

This super-lsokinetlc operating condition Is used to minimize particulate measurement error that can be 

significant at sub-isokinetic conditions. The super-isokinetic condition is an alternative to continuous 

monitoring of the stack gas velocity and adjustment of the sampling rate in order to maintain isol<inetic 

conditions. 

Stack gases are transferred through a ring pipe where the gas is conditioned by heating to approximately 

160 •c (320 °F) to vaporize any water and acid droplels that may be present In the gas stream. A 

slipstream of the sample gas Is extracted for ·continuous• analysis by the photometer. which is also 

heated to 1so•c and kept at a consistent pressure. Aller analysis, the slip stream gas passes through a 

flow measurement venturi and returns to the bypass sample gas stream, which is forwarded by the 

blower, to the sample return probe in the stack. 

3.1.2.1.2 Photometric Analysis 

The PM analysis is performed by the photometer which measures the attenuation in forward light caused 

by the PM present In the sample gas. The photometer measures forward light scattered at 15° from an 

incandescent bulb emitting over the range of 360 to 2800 nanometers. Dual beam compensation is used 

in which the light path Is split and the Intensity of the reference path Is adjusted by an attenuator to equal 

the intensity of the measurement path. The sample and reference scattered light are combined ahead of 

a photocell, which generates a photoelectric signal that is proportional to the concentration of PM In the 

sample stream. The instrument response time is app.-oximately 5 seconds. The photoelectric signal is 

amplified to 4 to 20 milliampere (rnA) and output to the data acquisition system (OAS) on one of four 

available channels according to the increasing levels of intensity associated with increasing PM 

concentration. An automatic switching device operates relays to block a signal being sent from the other 

three channels. The system can also operate in a single oc locked range. The nominal PM 

concentrations associated with the four measurement levels are ~5. 0-1, ~.2, and ~.05 PLA based on 

a polystyrene latex aerosol (PLA) used in factory calibration of the monitor. The monitor's output signal, 

however, is always a single current value In the 4 -20 mA range. 

3.1.2.1.3 System Controller 

The SIGAR 4000 controller, or equivalent, is the connecting link between the photometer, the sample 

transport system, and the OAS. It communicates with the photometer, and processes and displays the 

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partlde mass reading signal. The SIGAR controller operates the sample transport system valves. 

heaters, blowers, and temperature sensors. The controller outputs critical system Information indudlng 

the real·time mass reading, sample transport system temperatures. and controller parameters. It stores 

all the threshold parameters for the Sigrist photometer. It provides relay contact Input and outputs to 

signal photometer and sample transport system status. It provides the user interface for photometer and 

controller parameter setup and pre891'Vation. 

3.1.2.1.4 Data Acquisition System and Historian 

The Sigrist micro controller provides system operation, status, instrument output, and range identifiCation 

to a computerized DAS. The DAS performs all data calculations for compliance. All data, system 

operation, status. and quality assurance data are stored in a historian. 

3.1.2.2 Installation Location 

The Sigrist PM CEMS will be located at a point In the stack that allows a representative sample to be 

extracted for subsequent analysis. This location will be at least two duct diameters from the top of the 

stack, and at least two duct diameters downstream from the last point of interference. The final PM 

CEMS location l be determined during the correlation test. 

3.1 .2.3 Installation 

The PM CEMS will be installed per manufacturer's recommendations. The CEMS will be installed in a 

location such that the correlation between the PM CEMS response and emissions determined by a 

reference method will meet the perfOITTlance spedfications stated in this document. Once the system is 

installed, it will be commissioned for use. This exercise will verify the system Is Installed properly per the 

manufacturer's spedfiCStion. 

3.1.2.4 Instrument Span 

The operating range of the PM CEMS will be established during the CEMS initial startup and correlation 

test plan period. Lilly will verify that the operating range (zero to span) will encompass the response of 

the PM CEMS for all expected waste streams. 

3.1.2.5 System Start Up (Initial Operation) 

The Sigrist will be started and allowed to run using ambient air in the sample line. A valve, located at the 

probe, allows Lilly to start the system with ambient air as opposed to ftue gas. The system will run on 

ambient air for approximately four weeks. During this time, Lilly will check the operation of the system 

and correct any issues that arise. 

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Lafayette, Indiana Alternative Monitoring Petition 

After this approximate four-week period, Lilly will sample the ftue gas under different feed conditions 

(surrogate material, liquid waste, solid waste, natural gas, fuel oU). Ulty will sample flue gas for 

approximately 4-8 weeks. The objective is to correct any issues that arise, and begin to compare the type 

of waste burned to the output of the Sigrist. Unearity checks will begin during this phase of the PM CEMS 

operation. 

The linearity check Is a procedure which checks the Instrument drift at five levelS. h an instrument 

response range of 4 to 20 milliamps, lhe linearity test checks the instrument drift at approximately 4, 5, 8, 

12 .. and 16 milliamps. The percent drift will be calculated as: 

where: 

Percent Drift= !Ra .. cs - RR£,. I "'00 

Span 

Percent Drift = Amount of drift (%) 

Rw.s = The measured PM CEMS response (rnA) 

R.... =The PM reference standard value (rnA) 

Span =Span of the instrument (20 rnA) 

3.1.2.5.1 Preliminary Correlation Test Plan Period 

The intent of the preliminary COITelation test plan period (PCTPP) during the PM CEMS startup is to: (1) 

understand the affect of specific materials (surrogate material and/or haZardous waste) on the response 

of the Sigrist PM CEMS (2) establish a preliminary correlation to predict particulate mass in terms of 

mg/scm, based on the output of the PM CEMS. It is expected that the PCTPP wiD take up to 16 weeks. 

Acliv~ies during the PCTPP will follow guidance in 4() CFR 6() Appendix B, Performance Specification 11 

(PS1 1 ). The following activ'itles will be conducted during the PCTPP: 

Seyen-pay Prift: Prior to beginning the PCTPP, the PM CEMS will have passed a seven-day drift test. 

For seven consecutive days, the linearity check will be completed. The percent drift at five levels vAll be 

recorded. Each value must be within 5% of the reference value. 

Reference Method: During the PCTPP, Ully will use Method 5 or Method 5l as the reference method. 

Lilly will use dual trains (perpendicular trains) for the reference method (RM) sampling. The targets are 

SO-minute runs. Shorter or longer runs may be necessary. For example, for high particulate loading, the 

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Lafayette, Indiana AHernatlve Monitoring Petition 

test runs may only be 45 minutes due to excessive pressure drop across the filter, and for very low 

particulate loading, test runs may be 120 minutes. The averaging time for each run will be documented. 

Ully will treat each sample train result In the data set as an Individual data point 

Data range: During the PCTPP. Lilly wijl collect at least 15 valid data sets consisting of simultaneous PM 

CEMS and dual RM measurements. More may be collected so that certain test results may be rejected. 

Lilly will auempt to collect data in three ranges [(Low) from zero to 50% of maximum measured PM 

concentration; (Mid) 25 - 75% of the maximum measured PM concentration; and (high) 50 to 100% of 

the maximum measured PM concentration]. The goal is to have at least 20% of the total data in each of 

the three ranges. A data set can only be used for one range. Lilly will use zero point data for the low 

values if a response at the low level cannot be achieved. 

Reference Method oa!a: Dumg the PCTPP, Lilly will evaluate the precision of the two sample trains by 

determining the relatille standard deviation (RSD) for each paired data set and comparing It to the 

recommended maximum RSD. The RSD will be calculated for each test run using the following equation: 

where: 

RSD = relatille standard deviation (%) 

Ca =concentration measured using Train A, units of concentration 

Cb =concentration measured using Train B, same units as Ca. 

Pursuant to Section Z.1.4 of EPA's Draft Guidance Document on PM CEMS, the recommended maximum 

RSD will be determined as follows: 

• For average PM concentrations that are at least 10 mg/dscrn (or at least 10 mg/acrn), 

the recommended maximum RSD is 10% 

• For average PM concentrations that are less than or equal to 1.0 mg/dscrn (or less 

than or equal to 1.0 mg/acrn), the recommended maximum RSD is 25%; and 

• For average PM concentrations between 1.0 and 10 mgldscrn (or between 1.0 and 

10 mg/acm), the recommended maximum RSD is determined using the following 

equation: 

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Eli Lilly and Company 

Lafayette, Indiana 

where: 

Altemative Monitoring Petition 

RSD,. = (26.67 - 1.67C.,.) 

RSD, = recommended maximum RSD for average PM concentration between 1.0 

and 10 mgldscm, (%). 

c.,. = average PM concentration for the Trains A and B, units of concentration 

EPA's draft guidance document on PM CEMS is provided in Appendix A. 

If the RSD analysis shows that the data for all test runs are within the recommended maximum RSD, no 

further assessment of data preclslon wltl be performed. If the RSD shows one or more ouUiers, Ully will 

use the standardized residual method. Under the standardized residual method, Lilly will plot data that 

compares Train 1 sampling results to Train 2 sampling results. The linear relationship must have a slope 

falling between 0.93 and 1.07. Data sets will be removed until the reference method data meets this 

criterion. 

Preliminary Correlation Deyelooment: Valid reference method data (Train 1 and Train 2 as individual 

points) will be plotted against the Sigrist output (mA or PLA) averaged over the sample period. The 

average Sigrist output will be on the X-axls and RM result, in mglscm (to represent the condijions in 

sample train standardized to standard temperature and pressure) on the Y-axls. Using the equations In 

PS11, Ully wltl calculate up to five correlations (1) linear (2) polynomial (3) logarithmic (4) exponential (5) 

power correlation models. Each attempted correlation will have the correlation coefficient, tolerance 

Interval, and confidence Interval calculated as described in PS11. Lilly will compare the correlation 

coefficient, confidence interval, and tolerance interval to the limits in PS 11. A successful preliminary 

correlation will be obtained, that uses real·tlme GEMS values to predict PM concentrations in mglscm, if 

all statistical checks in PS11 are met. 

During the correlation development, drill from the linearity checks will be recorded daily. If the drill, for 

any of the values, exceeds 6%, the PM CEMS will be adjusted and a new drill test performed. 

3.1.2.6 PM CEMS Calibration Correlation Tes1 (PM CEMS Certification) 

The objective of the calibration correlation test period (CCTP) Is to collect data, while buming hazardous 

waste, to establish a correlation which will predict tolal particulate mass emissions, in mg/scm, based 

upon the output of the Sigrist PM GEMS. PS 11 will be used as guidance to establish a valid cal.ibration 

correlation. 

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The following activijies will be conducted during the CCTP: 

Alternative Monitoring Petition 

Seyen day Drift: Prior to beginning the CCTP. the PM CEMS will have passed a seven day drift lest 

pursuant to Section 8.5(3) of PS 11. For seven coosecullve days, the linearity check will be completed. 

The percent drift at five levels will be recored. Each value must be within 5% of the reference value. 

Absolute Correlation Audit The absolute correlation audit (ACA) evaluates the PM CEMS response to a 

series of reference standards covering a full measurement range of the instrument To conduct this audij 

the PM CEMS will be challenged three times at each of the five audit points. lilly will follow Section 

10.3(2) of 40 CFR 60 Appendix F Procedure 2 (Procedure 2) as guidance for conducting the ACA. The 

average response will be used to calculate the accuracy at each audit point The ACA wiU be calculated 

using the equation In Procedure 2 listed below. The error cannot exceed 10% of the audit value, or 7.5% 

of the applicable standard; whichever is greater. 

l

R - R I ACA Accuracy = CB.IfS REF *I 00 

R,EF 

where: 

ACA Accuracy = The ACA accuracy at each audit point, (%) 

Rcer.ts =the measured PM CEMS response to the reference standard (rnA) 

R..eF =the PM reference standard value (rnA) 

Stra!jfjcation Test: Lilly will test for PM stratification by following the same general steps specified for 

gaseous pollutants, and following the guidance specified In Section V.5 of EPA's Draft Guidance 

Document on PM CEMS. To determine whether effluent stratification exists, a dual probe system will be 

uSed to determine the average effluent concentration while measurements at each traverse point are 

being made. One probe, located at the stack centroid, will be used as a stationary reference point to 

Indicate change in the effluent coocentration over lime. The second probe will be used for sampling at the 

traverse points specifoed in Method 1 (40 CFR part 60 appendix A). The monitoring system samples 

slmullaneously at the reference and traverse points throughout the testing period for approximately fifteen 

minutes at each point A minimum of 12 sampling points will be used, with 6 sampling points along each 

of the two traverses. Lilly will use Method 5 as the sampling method and sample at least 15 minutes at 

each sampling point. 

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The PM concentrations at each traverse point are then compared to the average of the PM 

concentrations for all sampling points to determine the percent stratification using the following equation: 

S =IC - C 1*100"1< i Q•"' 0 

where: 

S = percent stratification 

C; = PM concentration at sampling point 

C..., = average PM concentration for all sampling points. 

If the percent stratification is less than or equal to 10 percent for any traverse point, the duct is not 

considered stratified at that location. 

Reterence Me!!Jod: Lilly will use Method 5 or Method Si as the reference method. Lilly will use dual trains 

(perpendicular trains) tor the reference method (RM) sampling. The targets are 60-mlnute runs. Shorter 

or longer runs may be necessary. For example, for high particulate loading, the test runs may only be 45 

minutes due to excessive pressure drop across the filter, and for very low particulate loading, test runs 

may be 120 minutes. The averaging time for each run will be well documented. Lilly will adhere to P$11 

and treat each sample train result in the data set as an individual data point 

Data range: Lilly will adhere to PS11 for the data collection. This requires at least 15 valid data sets 

consisting of simultaneous PM GEMS and dual RM measurements. More may be collected so that 

certain test resulls may be rejected as long as at least 15 valid data sets are used to determine the 

correlation. All data will be reported. 

Lilly will attempt to collect data in three ranges [(Low) from zero to 50% of max PM concentration; (Mid) 

25- 75% of the max PM concentration; and (high) 50 to 100% of the max PM concentration]. The goal 

is to heve at least 20% of the total data in each of the three ranges. A data set can only be used for one 

range. Lilly will use zero point data for the low values if a response at the low level cannot be achieved. 

While collecting total particulate mass data during the CCTP, the Intention is to collect total particulate 

data that is close to, but not signlfocantty greater than the total particulate mass emission standard. 

However, because the purpose of CCTP Is to develop an acceptable correlation that can verify 

compliance at the emission standard, ~ is impossible to ensure that the total particulate mass emission 

standard will not be exceeded during some of the test runs. Accordingly, emissions standards from parts 

60, 61, 63, 264, 265, and 266 of Title 40 of the Code of Federal Regulations do not apply while 

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conducting a correlation testing program. Any permit or other emissions or operating parameter limits or 

cood~ions. including any im~atioos on work place practices, that are applicable to ensure compliance 

whh the emissions standards of parts 60, 61, 63, 264, 265, and 266 of Title 40 of the Code of Federal 

Regulations also do not apply while conducting a correlation testing program. 

Reference Method Data: Ully will evaluate the precision of the two sample trains by determining the 

relative standard deviation (RSD) for eacfh paired data set and comparing it to the recommended 

maximum RSD. Ully will follow the guidance provided in Section Z.1 .4 of EPA's Draft Guidance Document 

on PM GEMS. The RSD will be calculated for eacfh test run using the following equation: 

where: 

"c c >I RSD too t~-' ' - • 

(C, +c.> 

RSD : relative standard deviation (%) 

Ga = concentration measured using Train A. units of concentration 

Gb = concentration measured using Train B. same units as Ga 

Pursuant to Section 2.1.4 of EPA's Draft Guidance Document on PM GEMS, the recommended maxlmum 

RSD will be determined as follows: 

• For average PM concentrations that are at least 10 mgldscm (or at least 10 mglacm). 

the recommended maximum RSD is 100/o 

• For average PM concentrations that are less than or equal to 1.0 mgldscm (or tess 

than or equal to 1.0 mglacm), the recommended maximum RSD is 25%; and 

• For average PM concentrations between 1.0 and 10 mgldscm (or between 1.0 and 

10 mglacm), the recommended maxlmum RSD Is determined using lhe following 

equation: 

RSD, = (26.67 - 1.67Cm.) 

where: 

RSD, = recommended maximum RSD for average PM concentration between 1.0 

and 10 mgldscm, (%). 

C,.,. = average PM concentration for the Trains A and B, units of concentration 

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If the RSD analysis shows that the data for all test runs are within the recommended maximum RSD, no 

further assessment of data precision will be performed. If the RSD shows one or more outliers. Lilly will 

use the standardized residual method. Under the standardized residual method, Lilly will plot data that 

compares Train 1 sampling results to Train 2 sampling resuHs. The linear relationship must have a slope 

falling between 0.93 and 1.07. Data sets will be removed until the reference method data meets this 

criterion. All data will be saved and submitted. Regardless of which method is used, any potential outliers 

will be investigated to determine possible causes for the lack of precision. 

Cotrelation Development Valid reference method data (Train 1 and Train 2 as Individual points) will be 

plotted against the Sigrist output (rnA or PLA) averaged over the sample period. The average Sigrist 

output will be on the X-axls and RM result, In mg/scm (to represent the conditions In sample train 

standardized to standard temperature and pressure) on theY-axis. Using the equations in PSI t, Lilly will 

calculate up to fiVe correlations (1) linear (2) polynomial (3) logarithmic (4) exponential (5) power 

correlation models. Each attempted correlation will have the correlation coefficient, tolerance interval, 

and confidence interval calculated as described in PS11. Lilly will compare the correlation coefficient 

confidence interval, and tolerance interval to the limits in PS 11. A successful correlation will be 

established that uses reaHime CEMS values to predict particulate concentration In mg/scm If all statistical 

checks In PS 11 are met. If the PM CEMS does not pass the statistical limits for any of the five 

correlations. Lilly, with appropriate agency review, may develop an atternalive correlation by providing an 

explanallon of how compliance demonstration would be assured. 

The correlation established during the CCTP for the PM CEMS will supersede any previous correlations. 

whleh may have been established. 

During the CCTP. drift from the linearity checks will be recorded daily. If the drift, for any of the values. 

exceeds 8% once, the PM CEMS will be adjusted and a new drift test performed. 

3.1.2.7 Routine Operation of the PM CEMS 

3.1.2.7.1 On-Going Quality Assurance 

This section describes the on-going quality assurance that will be performed on the PM CEMS to ensure 

lhat it continues to operate correcUy and produces valid data. These quality assurance activities will 

occor only when the PM CEMS is operational. Lilly will follow Procedure 2 and EPA's Draft Guidance 

Document on PM CEMS located in Appendix A of this document when performing on-going quality 

assurance on the PM CEMS. 

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3.1.2.7.2 Routine System Checks 

Alternative Monitoring Petition 

Daily checks of the PM CEMS will be done according the recommended checklist provided by Sigrist, as 

modified by Lilly. Data status Hags wm be used to troubleShoot any problems that arise in the PM CEMS 

system. This meets the Intent of the daily system checks in PS11. 

3.1.2.7.3 Weekly Linearity Drift Checks 

Lilly will perform a linearity check once per week. This will be performed manually according to the 

procedure outlined in the Sigrist operational manual. 

The percent drift is calculated as: 

l

R - R I % Drift = CWS REF *J OO 

Span 

where: 

% Drift = Drift of the CEMS (%) 

RcEhos = the measured PM CEMS response (rnA) 

RREF =the PM reference standard value (rnA) 

Span =Span of the instrument (20 rnA) 

Five values between 0·20 mA will be checked. The actual value{s) will be adjusted when the drift 

exceeds 5% for any of the five values. (Refer to Section 3.1.2.9 for out of control definition). 

The Sigrist will be off-line for up to one hour during the linearity check. All calibration data collected along 

w~h the drift percentage will be recorded. During this time, the 6-hour rolling blOCk average ~J be frozen. 

3.1.2.7.4 System Audits 

3.1.2.7 .4.1 Quarterly Absolute Correlation Audit (ACA) 

The absolute correlation audit (ACA) evaluates the PM CEMS response to a series of reference 

standards covering a full measurement range of the Instrument. To conduct this audit, Lilly will perform 

the linearity drift check. The PM CEMS will be challenged three times at each of the five audit points. The 

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average response will be used to calculate the accuracy at each audit poinl The ACA will be calculated 

using the Equa~on 2·1 in Procedure 2 as follows: 

IR . -R I ACA Accuracy = C<Ms RtF *I 00 

R,u 

where: 

ACA Accuracy= Accuracy of the GEMS(%) 

Rce ... s =the measured PM GEMS response (rnA) 

R..EF =the PM reference standard value (rnA) 

The error cannot exceed 10% of the d~ value, or 7.5% of the applicable standard; whichever is greater. 

The ACA wiR be performed each quarter. 

3.1 .. 2.7.4.2 Quarterly Relative Response Audit (RRA) 

The relative response aud~ (RRA) is a brief series of tests conducted between annual full response 

correlation audits (RCA) to assure the continued validity of the PM GEMS correlation. The RRA will be 

pelforrned by collecting, at current source conditions. three reference method samples and PM GEMS 

measurements at the as-found source operating conditions. The data points will be plotted on the current 

calibration correlation function. To meet the RRA performance criteria. the three points must be less than 

or equal to the highest GEMS values used for the calibration curve and two or the threa sets of PM GEMS 

and RM measurements must fall within a specified area on the graph of the calibration correlation 

function. The specified area is two lines parallel with the correlation regression curve, offset at a distance 

of t 25% of the numerical emission limit value from the correlation regression curve. 

If the PM GEMS does not meet the RRA criteria, Ully will take the necessary corrective action to eliminate 

the problem and rapeat the test. If the RRA criteria cannot be achieved. Ully will perform an RCA. 

3.1.2.7.4.3 Annual Response COI"AAIalion Audit (RCA) 

Lilly will perform a response correlation audit (RCA) annually. The quarterly RRA will not be performed in 

the same quarter that the annual RCA is preformed. The response correlation audit (RCA) is a series of 

tests conducted to assure the continued valid~ of the PM CEMS correlation. Lilly will conduct the RCA 

as prescribed in PS 11 and Procedure 2. Uliy will collect a minimum of 12 data points attempting to 

disperse the points through low, mid. and high ranges on the calibration correlation function. The points 

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will be plolled oo the current calibration correlation function. To meet the RCA criteria, 75% of the points 

must fall within a specified area on the correlation regression curve. The specified area is two lines 

parallel with the calibration correlation function. offsat at a distance of :t 25% of the numerical emission 

limit value from the correlation regression curve. 

As defined in Secllon 10.6 of Procedure 2. H Lilly does not meet the performance criteria. then the two 

data sets (current correlation and the current RCA) will be combined and the correlation statistics in PS 11 

applied. If a correlation from the combined data sets passes the statistical ti miL~. this correlalloo becomes 

the new correlation curve. If the statistical limits are not met with the combined data, Lilly will use only the 

RCA data and run the PS11 statistics. If the statistical limits are met, this Is the new correlation curve. If 

the statistical limits are not met for the RCA data, the correlation test will be redone with a minimum of 15 

data points, applying the statistics in PS11. If the new data do not meet the statistical criteria for any of 

the five PS11 equalloos. and assuming no definable problems exist with the PM CEMS, lilly, with 

appropriate agency review, may develop an alternative correlation by providing an explanation of how 

compliance demonstration would be assured. 

While collecting total particulate mass data during the RCA, the intention is to collect total particulate data 

that is close to, but not significantly greeter then the total particulate mass emission standard. However, 

because the purpose of RCA is to verify that the correlation is suitable for complying with the emission 

standard, It Is Impossible to ensure that the total particulate mass emission standard will not be exceeded 

during some of the test runs. Accordingly, emissions standards from parts 60, 61, 63, 264, 265, and 266 

of Trtle 40 of the Code of Federal Regulations do not apply while conducting a correlalloo testing 

program. Any permit or other emissions or operating parameter limits or conditions, including any 

limitations on work place practices, that are applicable to ensure compliance with the emissions 

standards of parts 60, 61, 63, 264, 265, and 266 of Title 40 of the Code of Federal Regulations also do 

not apply while conducting a correlation testing program. 

3.1.2.8 Component Replacement 

During normal operation of the PM GEMS, specific components will need to be replaced. The PM CEMS 

standard operating procedures will address the criteria to be met upon replacement of Significant 

components. 

3.1.2.9 Out of Control 

Lilly will adjust the PM CEMS when the drift is equal to or greater than 5%. lilly will consider the PM 

CEMS out of control if drift, for any of the fove values, exceeds 8%. In addition, the GEMS will be deemed 

out of control if the PM CEMS fails to meet the RCA criteria, RRA criteria, or ACA criteria. 

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The oot of control period will begin immediately after the last test run or check ol an unsuccessful RCA, 

RRA. ACA or linearity drift check. The oot of control period ends immediately after the last test run or 

check of the subsequent successful audij or drift check, when the metals GEMS Is used as a back-up, or 

when the incinerator enters parametric mode. When the incinerator is operating in parametric mode, the 

PM GEMS will not be deemed out of control. 

3.1.3 Use of the PM CEMS for Compliance with the HWC MACT PM Standard 

Lilly may begin using the PM CEMS to demonstrate continuoos compliance with the HWC MACT PM 

emission standard only after the following is achieved: 

• A successful PM CEMS calibration Correlation Test as specified in Section 3.1.2.6 following 

EPA's approval of this Alternative Monitoring Petition. 

• A modification to the Title V permit is approved that incorporates the requirements of the 

approved Attemalive Monitoring Petition. 

Following completion of the above, on-going quality assurance will be performed on the PM CEMS as 

specified In Section 3.1.2.7 of this document. 

3.1.4 Monitoring Frequenc y and Averaging Time 

The PM CEMS will provide a six-hoor rolling block average in mg/dscm corrected to 7% oxygen. The sixhoor block average was selected as representative of the time period to collect three manual particulate 

measurement samples. One-minute values wm be used to develop 15-minute average values, which will 

be used to develop one-hour block average values and six-hour rolling block average values. 

Using the equation from the calibration correlation, the PM CEMS output values will be converted to 

mg/scm each minute. The Ecochem GEMS will send the DAS one-minute average oxygen and moisture 

values to use to correct the PM CEMS values to mg/dscm at 7% oxygen. 

The particulate stack concentration will be corrected to 7% oxygen by the following equation: 

where: 

PM"'" = PM concentration corrected to 7% oxygen (mg/dscm) 

PM"""'"= PM stack gas concentration (mg/dscm) 

0, = Oxygen stack gas percent (vol %dry) 

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The 15-minute data Is lhe average of the one-minute data within that block of time. Only one valid oneminute value is required to achieve a valid 15-minute average value. 

The hourly block average wiH be calculated from lhe four 15 minute averaged values during the hour as 

shown In the foftowlng equallon: 

HBA = .1:]__ 

4 

where: 

HBA = Hourly block average value (mg/dscm corrected to 7% 0 2) 

Gl =a fifteen minute observatioo from the GEMS analyzer (mg/dscm corrected to 7% 0 2.) 

In the event that four valid 15-minute averaged values are nol available to calculate an hOurly block 

average (i.e. the GEMS produced problematic data), valid resuHs must be available for at least three 15-

minute cycles of operation to calculate a one-hour block average. 

The six-hOur rolling average will be calculated based on the average of the six most recent hourly block 

averages as shown in the following equation: 

where: 

• I HBA 

SHRA = i =J 

6 

SHRA =Six hour rolling average value (mg/dscm corrected to 7% 0.) 

HBA = Hourly block average value (mgldscm corrected to 7% 0.) 

The six-hour rolling block average will be updated every hour when a new, vafid, hourly block average is 

calculated. 

3.1.5 Rolling Block Average Calculations during Routine Checks and Sys tem Audits 

Lilly will put the PM CEMS in a non-measure mode once per week for up to one hour in order to perform 

the weekly linearity checks while buming hazardous waste. During this time, block average calculations 

will be frozen. Rolling block hour average calculations will resume once the linearity check is successfully 

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Lafayette, Indiana Alternative Monitoring Petition 

perfonned. The six-hour rolling block average calculations will resume by adding the lirst valid hour block 

average after the linearity check to the previous five hour block average values. 

The rolling average calculations will also ba frozen during the quarterly absolute correlation audits. Block 

hour average calculations will resume once the audit Is complete. The ACA auditing may take more than 

one hour to complete. 

The PM CEMS OAS uses the oxygen concentration and moisture content from the Ecochem CEMS to 

correct the one minute average mg/scm concentrations of PM to 7% oxygen. dry basis. Once per day, 

the Ecochem will be in calibration mode for up to one hour. During this time the PM block average will 

also ba frozen. Incinerator operations will attempt to maintain stable operating parameters during times 

of calibration. 

3.1.6 Backup to the Particulate Matter CEMS 

In the event the PM CEMS is not operating. Lilly will have the option to use the multi-metals CEMS as a 

backup to the PM CEMS under the following conditions: 

1. Results obtained from parallel operation of the IWo CEMS will ba used to develop a technical 

justification of how lhe metals CEMS provides reasonable assurance of compliance w~h the PM 

emission standard. 

2. When the PM CEMS Is not operating and the mu t~metals CEMS begins use as a backup, Lilly 

will use Its best efforts to avoid introducing new waste streams (i.e. those that have not been 

historically burned while the IWo CEMS were In parallel operation) from the six "in-feed' 

conveyors to the final 'merge" conveyor that leads to the kiln feed chute. 

In order to allow CEMS mode to establish waste streams that are not "new" during its Initial 

implementation period, the above restrictions on use of the mult~ta s CEMS serving as a backup for 

the PM CEMS will apply only after a sufficient time period has elapsed (not to exceed 6 months from the 

first CEMS mode operation) for Lilly to gain experience while processing a variety of existing solid waste 

streams. Finally, Lilly wil attempt to maintain nominally stable or historically lower feed rates of waste 

while the backup is being used, and will limit the use of the ul ~metals CEMS as a back up for the PM 

CEMS to 14 consecutive days per episode. 

Lilly will use Its best efforts to minimize the time that the multi-metals CEMS acts as a backup to the PM 

CEMS. To facil ~te its efforts, Lilly will keep spare parts In stock and will maintain a service relationship 

with the PM CEMS manufacturer, or other qualified consultants, to minimize downtime. If both the PM 

CEMS and tha multi-metals CEMS are not in use, Lilly will monitor operating parameter limits defined In 

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Lafayette, Indiana Alternative Monitoring Petition 

Section 1209 of the HWC MACT (i.e. parametric operation). Details of the specific operating lim~s are 

provided In the Notification of Compliance (NOC). 

Lilly will incorporate delays when transitioning from the CEMS mode of operation to the parametric mode 

of operation. Specifically, once the primary PM CEMS and the backup uR~meta s CEMS are 

unavailable, the oontrol system will automatically sw~ch to the parametric mode of operation. Rolling 

averages, related to the Air Pollution Control System (APCS). will not start until the system has been 

under the parametric mode of operation for 10 minutes. This 1 O·minute time period will allow Lilly time to 

make any adjustments to the APCS to bring the system to w~in the respective operating parameter 

limits. In addition, up to four hours will be allowed before re-starting conslituent feed rate rolling average 

operating parameter im~ in order to clear the solid feed conveyor system. (Note that, in a similar 

fashion to the "backup" scenario described above, Ully will use Its best efforts to avoid introducing "new' 

waste streams from the six "in-feed" conveyors to the final ·merge' conveyor that leads to the kiln feed 

chute during this four hour period. However, during Initial CEMS mode operation periods there will be 

practical limitations to this criterion because few waste streams will have been burned.) Feed rates will 

be maintained nominally stable or historically lower than when operating in CEMS mode. If the CEMS 

mode of operation is stat not avaiable after four hours. the transition to parametric mode will be 

completed and only waste with known compos~ion will be processed in the incinerator so that consmuent 

feed rate operating parameter limits can be computed. 

3.1.7 Deviations from Performance Specification 11 

• The Sigrist PM CEMS samples superisokinetic and may not continuously meat the requirement 

of plus or minus 10% isokinetic. The Sigrist system is designed to sample superisokinetic. This 

is normally about 1.2 to 1.5 times isokinetic. Because of the Sigrist design, Lilly cannot be sure 

that the system will always be within ±10% of lsoklnetics. Lilly will adhere to PS11 and provide 

data indicating that isokinetic sampling is not necessary. This data will consist of particulate size 

distribution data showing the PM is predominately small partides; thus acting as a gas. The 

particulate size distribution data will be collected during the Comprehensive Performance Test. 

• The calibration correlation function will plot Sigrist values (mA or PLA} on the X-axis and the 

referanc6 method average In units of mglscm on the Y-axls. PS 11 Indicates that the reference 

method values for PM should be in the same units as the CEMS (the Sigrist units are mgfSigrist 

m3). Based upon the experience with the Sigrist at Lilly (PM CEMS demonstrations 1 and 2), 

Lilly saw no affect upon the correlation by correcting the Method 5 units to units of the Sigrist 

The operating pressure Inside the photometer is not well defined, making correction to this 

pressure an unknown. Based upon experience, Lilly will standardize the RM data to mg/scm 

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(68•F and 29.92 inclles). This is also consistent with the way lilly's Kinsale, Ireland facility has 

established valid correlations to the two Sigrist units operated at that facility. 

• Ully will use up to 20% of the correlation data (low range only) for zero points if low PM data 

cannot be produced. It is important to provide PM emission data for the correlatiOn that is 

spread across the desired range of measurement Often, data at the low end of the range is 

difficult to obtain. Given this lac~ using zero points for the low data may be required. 

• Lilly will conduct a seven-day drift prior to the calibration correlation. This will be the linearity 

check procedure described In the Sigrist operation manual (cllecks 5 values between 0-20 rnA), 

which is a manual exercise eacll day for seven days. The criteria will default to the allowable 

drift recommended by Sigrist of 5% as opposed to 2% of the span indicated in PS 11. Use of the 

Sigrist for compliance to a PM standard is new In the US. In our experience, the criteria 

specified above are sufficient to understand the drift of the unit and is acceptable based on our 

PM CEMS demonstrations. Sigrist (the CEMS manufacturer) supports using the above criteria. 

• P$11 stipulates immediate compliance with QAIQC requirements (Procedure 2) upon 

successfully completing the correlation test outlined in P$11. Lilly will comply with Proposed 

Procedure 2 after final correlation and statistics have been established and the Sigrist PM 

CEMS is deemed ready for use as a compliance tool. Until then, Lilly will use another means 

(surrogate operating parameters or the multi-metals CEMS) to assure compliance with the PM 

standard if waste is being burned In the solld4iquld Incinerator. 

• Appendix F, Procedure 2 does not discuss time to calibrate for the Sigrist. Lilly will put the 

Sigrist in a non-measure mode once per week for up to one hour while continuing to bum 

hazardous waste in order to periorrn the calibration cllecks. 

• Unearity drift will be checked once per week, not once per day. lilly will lot low PS 11 on 

adjusting the zero or upscale value when the drift, per the Procedure 2 equation, is greater than 

5%. Sigrist recommends checking the zero and or upscale drift not more than once per week. 

Since the photometer compensates for electronic drift during each sample, checking the zero 

and upscale drift dai y is of no value. NOTE: The weekly calibration drift check will check five 

values within the 0 - 100% range of the PM CEMS. This exceeds the zero and upscale drift 

range requirements. 

• P$11 deems the CEMS out of control if the daily, zero or upscale drift exceeds 4% for five 

consecutive days, or 8% once. Ully will adhere to the 8% requirement as described In section 

3.1.2.9. 

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• While pefforming the quarterly ACA the PM CE.MS may be off-line for greater than one hour per 

day. The time ofl lne will not require use of either the multi-metals CEMS or surrogate 

parameters to demonstrate compliance with the HWC MACT. The quarterly audits will not 

require the use of parametric mo(!e. 

3.2 MULn-METALS CEMS 

3.2.1 Indicator of Perlonnance 

Lilly has voluntarily chosen to use a multi-metals CEMS to (!emonstrate continuous compliance with the 

HWC MACT metals emission limits. Using a CEMS to monitor stack gas concentrations of metals is a 

relatively new application and as such, the HWC MACT does not require facilities to Install and operate a 

multi-metals CEMS for HWC MACT compliance purposes. 

The multi-metals CEMS is designed to continuously monitor the stack gas concentration of mercury, 

arsenic, chromium, cadmium, and lead to (!emonstrate compliance with the HWC MACT metals emission 

limits. Compliance with HWC MACT metals emission standards will be demonstrated when the 

measured stack metals concentrations are less than or equal to the applicable standards. Currently, Lilly 

must comply with the HWC MACT interim standards under 40 CFR 63.1203(b). Compliance with the 

interim HWC MACT mercury standard will be demonstrated when the measured slack concentrations of 

mercury is less than or equal to 45 ug/dscm corrected to 7% oxygen over a 12-hour rolling averaging 

period, updated hourly. Compliance with the low volaHie metals HWC MACT lnlerlm emission standard 

will be demonstrated when the measured stack concentrations of arsenic and chromium and defauH 

levels of beryllium (see section 3.2.2.1) are less than or equal to 97 ug/dscm combined, corrected to 7% 

oxygen over a 12-hour rolling averaging period, updated hourly. Compliance with the semi-volatile metals 

interim HWC MACT emission standard will be demonstrated when the measured stack concentrations of 

lead and cadmium are less than or equal to 120 ug/dscm combined, corrected to 7% oxygen over a 12· 

hour rolling averaging period, updated houl1y. 

Lilly will comply with the HWC MACT final replacement metals emission standards specifl8d in Section 

63.1219(a) no later than the date required by Section 1206(a)(1)(11) of the HWC MACT Final Replacement 

Standards. 

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3.2.2 Measurement Technique 

3.2.2.1 Operating Principles 

Alternative Monitoring Petition 

The multi-metals CEMS is an X-ray based continuous emission monitor (XACT) manufaclured by Cooper 

Environmental Services LLC (or equivalent). The XACT extracts a representative stack gas sample and 

concentrates the particulate and gas phase metals on a chemica8y-reactive filter. The concentratiOns of 

metals in the filter depos~s are measured with an energy-dispersive X-ray fluorescence (XRF) analyzer. 

Figures 3 and 4 sChematically illustrate the major components of the XACT, which include: 

1. A sample extraction system 

2. A sample collection module 

3. A metals analysis module 

4. A flow control module 

5. A system control module 

6. A PC interface 

7. A Data Acquisition System and Historian 

The XACT is designed to measure the concentration of up to 20 elements. including antimony (Sb). 

arsenic (As). barium (Ba). cadmium (Cd), chromium (Cr). cobalt (Co), lead (Pb), manganese (Mn). 

mercury (Hg). nicKel (NI), selenium (Se) silver (Ag). and thallium (TI). 

Because the XACT is incapable of measuring beryllium (Be), Lilly has developed a default value for 

beryllium emissions. Fortunately. beryllium Is a scarce element that is not used in Lilly pharmaceutical 

manufacturing processes. Lilly has examined all ~ manufacturing processes and associated process 

construction materials (e.g. alloy sleets) and found no Indication that beryllium should be present. 

Therefore, Lilly believes that a conservatively calculated default value for beryllium is technically 

defensible. 

Trace levels of beryllium are possible in raw materials and ground water. Lilly has sampled its liquid 

waste and found only sporadic "hits" of beryllium at levels close to the detection limits. Lilly has also done 

some limited sampling of plant trash. some of which might be processed in the so id~ qu d incinerator, 

and some low-levels of beryllium were reported. For the purposes of calculating a conservative default 

emission concentration, Lilly has assumed that all liquid and solid wastes fed to the solid-liquid incinerator 

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contain Be at ttle maximum levels detected: 1.0 ppm in the solid waste and 0.01ppm In the liquid wastes. 

The defaun emission concentration was then calculated using the maximum waste feed rates from the 

CPT plan, and an LVM system removal efficiency (SRE) of 98% (which Is a factor of two less than the 

design SRE of 99% and a factor of 20 less than the SRE of 99.9% obtained during the CPT of another 

Lilly incinerator with a virtually identical scrubber system). The resulting value was just over 1 ug/dscm. 

To be more conservative, Lilly has chosen 2 ug/dscm as a defauH value. Therefore, a value of 2 ug/dscm 

wil be added to the measured LVM emission before comparison to the emission standard limit. If the 

CPT data or any other evidence Indicates the default value Is not appropriate, it wnt be adjusted 

accordingly. 

Copies of the XACT Multi-Metals CEMS Guidance Documents, Perlormance Specifications, and Quality 

Assurance Documents are provided in Appendix e. 

3.2.2.1.1 Sample Extraction System 

The extraction system for the XACT is Identical to the extraction system used by the Sigrist PM CEMS. 

The sample system consists of a sample probe and ring pipe. The sample probe size was selected by 

the manufacturer to provide an Inlet gas velocity that is app.-oximately 1.0 to 1.5 times greater than the 

normal stack gas velocity when sampling at the preset (design) rate of approximately 1 acm/min. This 

super-isoklnetic operating condition is used to minimize particulate measurement error that can be 

significant at sub-isokinetic conditions. The supe ~sok netic condition is an alternative to continuous 

monitoring of the stack gas velocity and adjustment of the sampling rate In order to maintain isokinetic 

cond~ ons. 

Stack gases are withdrawn through a fixed sample probe, transferred through a ring pipe where the gas is 

condtlloned by heating to approximately 160 •c (320 °F) to vaporize any water and acid droplets that may 

be present in the gas stream. A slipstream of the sample gas Is extracted lsokinetically from the main ring 

pipe flow Into a large diameter smling chamber and through the flow control module. 

3.2.2.1.2 Sample Collection Module 

About one liter per minute (lpm) of the stack gas is isokinetically drawn from the stilling chamber through 

a sampling tube, mixed with a reducing agent, and filtered through a filter tape for analysis. After 

sampling for approximately 15 minutes, the deposit spot is advanced about two inches where the metals 

concen ra~ons per sample deposit are measured by XRF while the next sample is being collected. 

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3.2.2.1.3 Metals Analysis Module 

AHematlve Monitoring Pelition 

The metals analysis module of the XACT consists of an energy dispersive multi-element XRF analyzer. 

This muki-element sensor consists of an X-ray tube and a lithium-drifted silicon energy dispersive X-ray 

detector, or equiValent. The energy of the characteristic X-rays provid&s the qualitative information to 

identify the elements present in the sample while the Intensity of each analyte line (X-ray) provides the 

quantitative Information to determine the mass of each element present in the depos~. The mass or each 

metal per sample deposit spot is reported to the data acquisition system for subsequent stack gas 

concentration calculations. 

3.2.2.1.4 Flow Control Module 

The filtered gas from the sample module is drawn through the gas conditioning component or the flow 

control module. These components remove moisture and corrosive gaS&s from the stack gas allowing for 

volume measurements in dry standard cubic meters (dscm). The gas Is then drawn through a two-way 

solenoid valve, pressure transducer, and mass flow controller. Typically, the flow travels direcUy to a 

manual leak check valve and vacuum pump but a ftow QA loop is available for cross-checking flows 

against a second mass flow meter. After flowing through the vacuum pump, the sample gas is returned 

to the stack. 

3.2.2.1.5 System Control Module 

The system control module consists of programmable logic control devices, firmware, power supplies, 

relays, fuses, etc. to control the temperatures, flows and mechanical aspects or the system. The status of 

these components Is monitored by software and firmware associated with the PC module. 

3.2.2.1.6 PC Interface Module 

The PC module contains the overall system control, XRF analysis. and calculation software. This 

software monitors the system operating parameters and presents a variety or status and flags when a 

component Is operating outside or defined control ranges. It also performs quantitative XRF metals 

concentration calculations and combines the metals concentrations per sample deposit with the volume 

sampled per sample deposit data to calculate dry stack gas concentrations in micrograms per dscrn. 

3.2.2.1.7 Data Acquisition System and Historian 

Metals concentrations, In micrograms per dscm, data status, quality assurance data .. status flags, and 

system operational status/alarms are passed to a data aoquisition system (DAS). The DAS perfonns the 

data calculations for compliance. All data are saved in a historian. 

28 Rev. 7.0 

VES009376 
Eli Lilly and Company 

Lafayette, Indiana 

3.2.2.2 Installation Location 

Alternative Monitoring Petition 

The XACT sample interface inlet will be Installed at an accessible location downstream of the air pollution 

control equipment where the metals concentration of tihe XACT -extracted sample of stack aerosol will be 

representative or the metals concentration (ug/m3) in the effluent emitted from the stack. Specifically, the 

monitor location will be at least 

• 2 equivalent duct diameters downstream from the nearest control device, point of 

pollution generation or other point at which a change In the pollutant concentration or 

emlssion rate may occur. 

2 equivalent duct diameters upstream from the effluent exhaust. 

The equivalent duct diameter is calculated as per 40 CFR Part 60, Appendix A Method 1, Section 2.1. 

A representative sample of stack gas will be drawn from the stack at an approximate rate of one cubic 

meter per minute, immediately heated to a temperature above the dew point lor most acids, and 

maintained at that temperature during transport through heat-traced and insulated stainless steel tubing 

to an Instrument shed housing the GEMS and other monrtoring instruments. 

3.2.2.3 Installation 

The XACT GEMS wilt be installed per manufacturer's reccmmendations. Once the system is installed, it 

will be commissioned for use. This exercise wil verify tihe system Is Installed property per tihe 

manufacturer's specifiCation. 

3.2.2.4 Instrument Span 

The operating range of the XACT GEMS will be established during the GEMS certification period. Ully will 

vemy that the operating range (zero to span) will encompass the response of the XACT GEMS for all 

expected waste streams. The HWC MACT emission limits. for the three metal classes. will fall within this 

measurement range. 

3.2.2.5 System Start ... p (Initial Operation) 

The initial start-up of the XACT GEMS will be at Cooper Environmental Services. The XACT GEMS will 

be operated, sampling room air, to shakedown the system. Once the system is operating w~hout errors, 

the XACT GEMS will undergo a Factory Acceptance Test to verify that tihe system meets or exceeds the 

functional criteria. 

29 Rev. 7.0 

VES009377 
Eli Wily and Company 

Lafayette, Indiana 

3.2.2.5.1 Factory Acceptance Test 

Alternative Monitoring Petition 

The Factory Acceptance Test will be executed at Cooper Environmental Services. The objective of this 

testing is to ensure the XACT GEMS meets or exceeds the functional operating criteria. Results of the 

Factory Acceptance Test will be doCumented and include the following major components: 

1. Manual Check List 

2. National institute of Standards and TeChnology (NIST) Traceable Thin Film Calibrallon 

3. XRF Energy Alignment Check 

4. Stability Check 

5. Blank Bias Check (zero drift check) 

6. XRF Instrument Drift Check (upscale drill check) 

7. Flow Rate Drill Check 

8. MACT Metal Linearity Check 

9. MACT Metal Relative Accuracy Check 

3.2.2.6 System Start-up (Field installation) 

Once the XACT GEMS is installed, the system will undergo an Installation qualification (IQ) to ensure the 

system is installed to manufacturer's recommendations and that the system meets all safety 

requirements. Following successful IQ, the system will operate, sampling ambient air, for several weeks. 

Once the XACT GEMS has operated for several weeks without significant issues, Lilly will (1) Calibrate 

(or check calibration) the XRF (2) Begin routine daily QNQC (3) Begin daily system Check for appropriate 

operation. The XACT GEMS will operate contlnuoosty in this mode (at least four weeks) prior to the 

performance specification test. 

3.2.2.6.1 NIST Traceable Thin Film Calibration 

During the inftial start-up of the XACT CEMS, the XRF will be calibrated using NIST traceable thin film 

standards. This calibration will establish calibration factors for eaCh of the metals to be analyzed. The 

calibration factors are used to provide ug/spot quantitation for eaCh metal analyzed. After the XACT 

CEMS Is installed at Lilly, the caUbratlon factors wiD be Checked by using thin film standards for up to five 

30 Rev. 7.0 

VES009378 
Eli Ully and Company 

Lafayette, Indiana Alternative Monitoring Petition 

different metals (at least one metal for eacll of the three metals classes). The XACT CEMS XRF will be 

re-calibrated n the relative percent difference is greater than 10% by using the following equation: 

I

R - R I CA Accuracy = cws REF "tOO 

RR£F 

where: 

CA = X-ray fluorescence calibration accuracy 

Rca.os = the value of the standard reported by the CEMS 

~ = the known value of the standard 

3.2.2.6.2 Routine Dally Quality Assurance and Quality Control 

The XACT CEMS conducts automatic precision cllecks with every sample run as well as daily upscale 

and blank measurements (zero and upscale drift checks). These checks ensure that the XRF data Is 

precise; minimal blank bias is occurring, and signlfocant instrument drift has not taken place. SpecifiCally, 

the XACT CEMS will automatically (1) clleck energy alignment (2) check XRF stability (3) check zero drift 

(4) clleck upscale drift (5) check sample flow drift. 

3.2.2.6.3 Daily System Check 

Operations will manually perfonn a daily clleck of the XACT CEMS. The daily clleck will be documented. 

3.2.2.7 Perfonnance Specification Test 

Once the XACT CEMS installation and inibal field operation have been achieved, a validation of the 

XACT CEMS will be performed with hazardous waste. Data collected during these tests will provide an 

initial validation of the XACT CEMS. This validation will allow the use of the XACT CEMS to demonstrate 

continuous compliance with the HWC MACT metals emission limits. 

The perfonnance specification test will be performed to determine the accuracy, bias, precision, stability, 

and cycle time of the XACT CEMS. The following checks will be perfonned as part of the perfonnance 

specification test 

Cycle Time: The XACT CEMS will adhere to Performance Specification YY (Specifications and Test 

Procedures for X-ray Fluorescence Based Multi-Metals Continuous Emission Monitoring Systems at 

Stationary Sources prepared by Cooper Environmental Services. LLC). Perfonnance Specification YY is 

31 Rev. 7.0 

VES009379 
Ell Lilly and Company 

Lafayette, Indiana Alternative Monitoring Petition 

provided in Appendix B. Pursuant to Section 1 .2. 1 of Performance Specification YY, the CEMS must 

have a cycle time that is less than one-third the period of the appficable standard. For this application, 

the cyde time will not exceed fifteen minutes. 

Stratification Test: The stratification test, described in section 3.1.2.6, for PM CEMS, will be applied to 

meet this requirement for the XACT CEMS. 

X-ray Fluorescence Calibration Check: The XACT CEMS will adhere to Performance Specification YY 

when conducting the X-ray Fluorescence Calibration Check. Using NIST traceable standards, the XACTXRF is challenged three times for each metal measured. The error is calculated according to the following 

equation: 

I

R - R I CA = CF.M.< RF.F "'00 

RREF 

where: 

CA = X-ray fluorescence calibration accuracy 

RcEMs =the value of the standard reported by the CEMS (ug) 

R,.., = the known value of the standa1d (ug) 

The average error of the three measurements for each metal must be less than 10% of the calibration 

standard's value for each metaL 

Stability: The 7-Day Calibration Drift Test: The XACT CEMS will adhere to Performance Specification YY 

when conducting the 7-day Calibration Drift Test. The stability test will be performed prior to the accuracy 

testing. The CEMS must meet the following specifications for each of the seven consecutive days, 

without any adjustments or calibrations made to the CEMS: 

• zero drift S20% (of the emission limit value) determined by the following equation: 

ZDi 

where: 

ZDi = the zero drift of the r• element(%) 

32 Rev. 7.0 

VE$009380 
Ell Lilly and Company 

Lafayette, Indiana Alternative Monitoring Petition 

Riao1.os = the measured CEMS response to the zero standard for the i

1

" element 

Rio£, = the reference value of the r• element on the zero standard 

Cl = the emission Omit of the 1

1

" element. 

Lilly will consider the emission limit of the Individual metalS (CI) to be equal to the HWC MACT limit for the 

metal class. For example, the emission limit for lead wm be considered to be 120 ug/dscm for the 

purposes of determining zero drift for the XACT. 

• upscale drift: S15% (of the reference value) detennined by the following equation: 

l o; - Ri I UDi _I'~CCMs R£F *100 

RinEP 

where: 

UDi =the upscale drift of the i"' element(%) 

Ria;, ... = the measured CEMS response to the upscale standard for the i"' 

element. 

Rl..,. = the reference value of the 1

1

" element on the upscale standard 

• volume of flow drift: s 20% (of instrument span) detennined by the following 

equation: 

where: 

IV -VI VD - CE.VSI< M • I 00 

FS 

VO = Volume drift (%) 

VcEJJt;tt = Sample gas volume or flow measured by the CEMS volume check 

measurement device. 

Vm =Sample gas volume or flow reported by the multi-metals CEMS 

FS = Full scale value of the CEMS volume or flow measurement 

33 Rev. 7.0 

VES009381 
Ell U lly and Company 

Lafayette, Indiana Alternative Monitoring Petition 

CEMS Accuracy: The XACT CEMS will adhere to Performance SpecifiC8tion YY when determining the 

CEMS accuracy. The aocuracy of the XACT CEMS Is determined using one of the following four opllons 

and performance cr~eria : 

• Option A:. Linearity test of the enUre CEMS 

- slope: 0.85· 1.15 

- r;, 0.90 

- intercept < 20% of emission limit for each metal 

• Option B: Linearity test of the XRF and sampling modules separately from the 

sample interface. This option will also lndude a Transport Effldency Test 

- slope: 0.85·1.15 

- r:< 0.90 

- intercept < 20% of emisslon limit for each metal 

- Percent transport :<90% or S11 0% 

• Option C: Relative bias ofthe entire CEMS 

- Relative % Bias s 15% for each metal 

% RSD s 10% for each metal 

- r;, 0.90 for the metal used to demonstrate the 3-fold change 

• Option D: Relative bias of tihe XRF and sampling modules separately from the 

sample interface. This option will also indude a Transport Etrociency Test. 

- Relative % Bias s 15% for each metal 

- % RSD s 10% for each metal 

- r ;, 0.90 for the metal used to demonstrate the 3-fold change 

- Percenttransport <:90% or S110% 

3.2.2.8 Routine Operation of the Multi-Metals CEMS 

The quality assurance requirements will adhere to Procedure Z: Quality Assurance Requirements for X· 

ray FluoresceriC8 Based Multi-Metals Continuous Emission Monitoring Systems at StatiOnary Sources 

prepared by Cooper Environmental Services, LLC. Procedure Z is located in Appendix B. 

34 Rev. 7.0 

VES009382 
Eli Lilly and Company 

Lafayette, Indiana Alternative Monitoring Petition 

3.2.2.8.1 Daily Quality Assurance Checks 

Each day, operations will manually perform a daily check of lhe XACT CEMS. Resulls will be 

documented. The XACT CEMS conducts at.rtomatic precision checks with every sample run as well as 

daily upscale and blank measurements (zero drift, upscale drift, and volume (flow) checks). These checks 

ensure that the XRF data Is precise; minlma.l blank bias Is occurring, and significant instrument drift has 

not taken place. Specifically, the XACT CEMS will automatically (1) check energy alignment (2) check 

XRF stability (3) roeck zero drift {4) check upscale drift (5) check sample ftow drift. For earo dally check, 

the percent drift cannot exceed: 

• zero drift 20% in terms of the emission limit 

• upscale drift: 15% in terms of the baseline value for each metal 

• volume ftow: 20% in terms of instrument span 

3.2.2.8.2 Quarterly Audit 

3.2.2.8.2.1 First Quarterly Audit after Performance Specification Test 

The first quarterly audit after the performance specification test will consist of the CEMS accuracy test 

described in Section 3.2.2.7. 

XRF calibration factors wiD also be checked by performing an X-ray Fluorescence Calibration d~. For 

ead1 element measured, the percent difference must not exceed 10%. Each quarter, a sample volume 

(flow) audit will be performed. The average of three volumes, taken at different measurement cycles, 

must not exceed 10% of the reference value. The entire XACT CEMS and transport system will be 

examined for problems, suro as particulate build up. Appropriate preventative maintenance will be 

performed on the CEMS. 

3.2.2.8.2.2 Subsequent Quarterly Audits 

Each quarter the XRF calibration factors will be checked by performing an X-ray Auorescence Calibration 

Aud~. For earo element measured, the percent difference must not exceed 10%. Each quarter. a 

sample volume (flow) aud~ will be performed. The average of three volumes, taken at different 

measurement cycles, must not exceed 10% of the reference value. 

The entire XACT CEMS and transport system will be examined for problems, such as particulate build up. 

Appropriate preventative maintenance will be performed on the CEMS. 

35 Rev. 7.0 

VES009383 
Ell Ully and Company 

Lafayette, Indiana 

3.2.2.8.3 Annual Audit 

Alternative Monitoring Petition 

Annually, in addition to the quarterly checks, the XACT CEMS will be checked for accuracy (Performance 

Specification YY). The accuracy will be determined using one of the four options and respective 

performance criteria: 

• Option A: Linearity test of the entire CEMS 

slope: 0.85-1.15 

~ 0.90 

intercept < 20% of emission limit for each metal 

• Option B: Linearity test of the XRF and sampling modules separately from the 

sample interface. This option will also include a Transport Efficiency Test 

slope: 0.85-1.15 

~ 0.90 

intercept < 20% of emission limit for each metal 

Percent transpor1 «90% or s 110% 

• Option C: Relative bias of the entire CEMS 

Relative% Bias s 15% for each metal 

% RSO s 10% for each metal 

r ~ 0.90 for the metal used to demonstrate the 3-fold change 

• Option 0 : Relative bias of the XRF and sampling modules separately from the 

sample interface. This option will also include a Transpor1 Efficiency Tesl 

Relative % Bias s 15% for each metal 

% RSD s 10% for each metal 

r <: 0.90 for the metal used to demonstrate the 3-fold change 

Percent transport 90% or s 110% 

36 Rev. 7.0 

VES009384 
Ell Lilly and Company 

Lafayette, Indiana 

3.2.2.9 Component Replacement 

Alternative Monitoring Petition 

During normal operation of the XAGT GEMS, specific components will need to be replaced. The XAGT 

GEMS standard operating procedures will address the criteria to be met upon replacement of significant 

components. 

3.2.2.10 Out of Control 

The out of control period will begin immediately after the last test run or check of an unsuccessful zero 

drift, upscale drift. sample flow drift, or unsuccessful accuracy audit. The out of control period ends 

Immediately after the last test run or check of the subsequent successful audij or drift check, when the 

PM GEMS is used as a back-up or when the incinerator enters parametric mode. When the Incinerator is 

operating In parametric mode, the XAGT GEMS will not be deemed out of control. 

3.2.3 Use of the XACT Multi Metals CEMS to Demonstrate Compliance with the HWC MACT 

Metals Standards 

Lilly may begin using the XAGT GEMS to demonstrate continuous compliance with the HWC MACT 

metals emission standards only after the following Is achieved: 

• A successful Performance Specification Test Is performed following EPA's approval of this 

Alternative Monitoring Pet~ion . 

• A modification to the TrUe V permit is approved that Incorporates the requirements of the 

approved Alternative Monitoring Petition. 

Following completion of the above, on-going quality assurance will be performed on the XAGT GEMS as 

speclfoed In Section 3.2.2.8 of this document. 

3.2.4 Monitoring Frequency and Averaging Time 

The multl-illetals GEMS wiD monitor and record concentration values (f'Qidscm) of mercury, tow volatile 

metals (arsenic and chromium; a default value will be incorporated for beryllium), and semlvolatite metals 

(lead and cadmium) at least once every 15 minutes. 

37 Rev. 7.0 

VES009385 
Eli Lilly and Company 

Lafayette, Indiana Alternative Monitoring Petition 

The metals conce!'ltrations will be CO<Tected to 7% oxygen by the following equation: 

where: 

M - \1 • 21 - 7 (V)I'f' -~ UIIW'J• 21- 0, 

M""'= Mercury, semivolatile metals, or low volatile metals concentration corrected to 7% oxygen 

(~g/ scm) 

M,..,,., Mercury, semivolatile metals, or low volatile metals stack gas concentration g/dscm) 

0,= Oxygen stack gas percent (vol % dry) 

An hourly block average will be calculated from the four 15 minute measurements during the hour as 

shown in the following equation: 

' L Ci 

HBA = ; • I 

4 

where: 

HBA = Hourly block average value (ug/dscm) 

Cl = a fifteen minute observation from the CEMS analyzer (ug/dscm) 

The established beryllium defauH value will be added to the fifteen-minute chromium and arsenic CEMS 

observations to calculate the L VM how1y block average. 

Valid results must be available for at least three of the 15-minute cycles of operation to calculate a onehour block average. 

Twelve-hour rolling averages will be calculated based on the average of the twelve most recent hou~y 

block averages as shown in the following equation: 

12 L HBA 

THRA = 

I • I 

12 

Where: 

THRA = Twelve hour rolling average value (ugldscm) 

HBA = Hourly block average value (ug/dscm) 

38 Rev. 7.0 

VES009386 
Eli Lilly and Company 

Lafayette, Indiana AHematlve Monitoring Petition 

The ~velve-hour rolling average will be updated every hour when a new hOurly block average is 

calculated. 

3.2.5 Block Average Calculations during Multi-Metals CEMS Daily Checks and Ongoing Quality 

Assurance Check s 

The XACT CEMS wil.l be off line up to one hour each day to perform the daily quality assurance checks. 

Block average calculations will be frozen during the dally upscale and zero checks. Lilly will continue to 

burn hazardous waste during the daily quality assurance checks. Block average calculations will resume 

once the checks are performed. The twelve-hour rolling block average calculations will resume by adding 

the first valid hour block average after the drift check to the previous 11-hour block average values. 

In addition, bled< average calculations will be frozen during the quarterly and annual audits. Rolling block 

average calculations will resume once these quality assurance checks are completed. 

3.2.6 Multi-Metals CEMS Backup 

In the event the multi-melals CEMS is not operating, Lilly will have the option to use the PM CEMS as a 

backup to the multi-metals CEMS under the following conditions: 

1. Results oblained from parallel operation of the two CEMS t be used to develop a technical 

justification of how the PM CEMS provides reasonable assurance of compliance with the HWC 

MACT metals emission standard. 

2. When the multi-metals CEMS is not operating and the PM CEMS begins use as a backup, Lilly 

will use its best efforts to avoid introducing new waste streams (i.e. those that have not been 

historically burned while the ~ CEMS were in parallel operation) from the six "in-feed" 

conveyors to the final "merge" conveyor that leads to the kiln feed chute. 

In order to allow CEMS mode to establish waste streams that are not "new" during its initial 

implementation period, the above restrictions on use of the PM CEMS serving as a backup lor the multimetals CEMS will apply only after a sufficient time period has elapsed (not to exceed 6 months from the 

first CEMS mode operation) for Lilly to gain experience while processing a variety of existing solid waste 

streams. Finally, Lilly will altempl to maintain nominally stable or historically lower feed rates of waste 

while the backup is being used, and will limit the use of the PM CEMS as a back up for the multi-melals 

CEMS to 14 consecutive days per episode. 

Lilly will use Its best efforts to minimize the time that the PM CEMS acts as a backup to the XACT CEMS. 

To facilitate its efforts, Lilly will keep spare parts in stock and will mainlain a service relationship w~h the 

XACT CEMS manufacturer, or other qualified consultants. If both the PM CEMS and the multi-metals 

39 Rev. 7.0 

VES009387 
Ell Lilly and Company 

Lafayette, Indiana AHernatlve Monitoring Petition 

CEMS are not in use, LiHy will monitor operating parameter limits defined in Secllon 1209 of the HWC 

MACT (I.e. parametric operatiOn). Details of the specific operating limits are provided in the Notification of 

Compliance (NOC). 

Lilly wnt Incorporate delays when transltloning from the CEMS mode of operation to the parametric mode 

of operatiOn. Speciftcally, once the primary multi-metals CEMS and the backup PM CEMS are 

unavailable, the control system will automatically switch to the parametric mode of operatiOn. Rolling 

averages, related to the Air Pollution Control System (APCS), will not start unm the system has been 

under the parametric mode of operation for 10 minutes. This 10-minute time period will allow Lilly lime to 

make any adjustments to the APCS to bring the system to within the respective operating parameter 

limits. In addition, up to four hours will be allowed before re-starting constituent feed rate rojllng average 

operating parameter limits in order to clear the solid feed conveyor system. (Note that, in a similar 

fashion to the "backup" scenario described above, Lilly will use its best efforts to avoid introducing "new" 

waste streams from the sbc "in-feed" conveyors to the final "merge" conveyor that leads to the ki ln feed 

chute during this four hour period. However, during initial CEMS mode operation periods there will be 

practical limitatiOns to this criterion because few waste streams will have been bumed.) Feed rates will 

be maintained nominally stable or historically lower than when operating In CEMS mode. If the CEMS 

mode of operation is stm not avaaable after four hours, the transition to parametric mode will be 

completed and only waste with known composition will be processed in the incinerator so that consmuent 

feed rate operating parameter limits can be computed. 

3.3 HYDROGEN CHLORIDE (HCI) CEMS 

3.3.1 Indicator of Performance 

The HCI CEMS Is designed to continuously monitor the stack gas HCI concentration. Compliance with the 

HCVC12 HWC MACT emissiOn standard will be demonstrated when the measured stack concentration of 

HCI combined with the defautt chlorine concentration is less than or equal to the applicable standard. 

Currently. Lilly must comply with the HCIICI, HWC MACT interim standard of 21 ppmvd. corrected to 7 

percent oxygen, specified under Section 63.1203(b) of the HWC MACT. Lilly will comply with the HWC 

MACT final HCVC12 standard specified in SectiOn 63.1219(a) no later than the date required by Section 

1206(a)(1)(11) of the HWC MACT final replacement standards. The averaging time is over a 12-hour 

period, updated every minute. 

40 Rev. 7.0 

VES009388 
Eli Lilly and Company 

Lafayette, Indiana 

3.3.2 Measurement Technique 

3.3.2.1 Operating Principles 

Alternative Monitoring Petition 

The HCI GEMS Is an Ecochem Multi-Component Infrared Analyzer (MC3), or equivalent. manufactured by 

Ecochem Analytics. The MC3 monrtors the stack gas sample for HCI concentrations. The MC3 also 

measures stack gas concentrations of carbon monoxide (CO), oxygen (~). carbon dioxide (C02). suffur 

dioxide (S02) and nitrogen oxides (NO,). In addrtion, the MC3 measures the moisture content of the 

stack gas. Figures 3 and 5 schematically Illustrate the major components of the MC3, which ind ude: 

1. Sample Extraction System 

2. Pressure Regulation Module 

3. Ecochem Multi-Component Infrared Analyzer 

4. System Controller 

5. Data Acquisition System and Historian 

3.3.2.1.1 Sample Extraction System 

The sample extraction system consists of two elements; a sample probe and a heated umbilical line. 

The heated sample probe is M&C Products Sample Drift Probe. or equivalent, manufactur>1d by M&C 

Products. To provide accurate measurement of HCI, the sample extraction system, sample line and 

probe, provides a hot. wet sample to the MC3; eliminating the scrubbing of water-soluble compounds 

such as HCI and S02• The M&C Products Sample Drift Probe provides the capability of sampling a water 

saturated gas stream, reducing the affect of water droplets at the sample point (first step in eliminating the 

water soluble aerosol). Operation of the sample probe (temperature. sample, purge, calibration modes) is 

controlled by a Programmable Logic Controller (PLC); located In the MC3 sample cabinet. 

The sample umbilical line has the function of (1) providing calibration gas to the probe for daily zero and 

upscale span checks (2) providing calibration gas to the probe for linearity audits (3) providing a hot, wet 

sample to the MC3 analyzer. The sample umbilical is designed to operate at temperatures of 

approximately 180 •c; which is Imperative for hot, wet sampling of HCI, moisture, and S02• 

41 Rev. 7.0 

VES009389 
Eli Lilly and Company 

Lafayette, Indiana 

3.3.2.1.2 Pressure Regulation Module 

Alternative Monitoring Petition 

The pressure regulation module is designed to remove both free particulates and water-soluble aerosols 

from the gas stream prior to analysis by the MC3 analyzers. The system also provides a sample gas to 

the MC3 at a constant pressure. Control of thls system resides With the PLC In the MC3 cabinet. 

The pressure regulation module is designed to maintain a temperature of at least 180 Celsius. minimizing 

scrubbing of HCI, moisture, and S02 • 

3.3.2.1.3 Ecocllem Mufti-Component Infrared Analyzer 

The sample extraction system delivers a hot, wet sample to the Ecochem Multi-Component infrared 

Analyzer. The MC3 quantitates stack gas concentrations of CO, 0 2, C02, S02• NO,, H,O and HCI. HCI 

analysis occurs by using single beam dual wavelength nondispersive infrared spectroscopy. The HCI gas 

absorbs infrared radiation at a specific wavelength, which depends on its molecular structure. The 

degree of absorption is proportional to the concentration of the target gas. Final values are reported by 

the PLC In ppmv, dry units. 

Because the HCIICI, HWC MACT emission limit is based on combined stack emissions of hydrogen 

chloride and chlorine gas and the MC3 only measures hydrogen chloride, Ully has developed a 

conservative default value for the chlorine concentration. Fortunately the amount of chlorine present in 

stack gas from incinerators similar to the solid-liquid incinerator is typically very low, particularly if they 

burn aqueous wastes and have wei air pollution control systems. Lilly has tasted its incinerator in 

Mayaguez, Puerto Rico that is equipped with the same air pollution control system and bums similar 

liquid wastes as the solid·liquid lnclneratOI'. The resulls showed chlorine levelS much less than 1 ppm 

(NOTE: During this testing, the bromine/chlorine and sulfur/chlorine waste composition ratios were below 

levels that EPA believes could result In a negative measurement bias.) To be conservative, Lilly will use 

1 ppm as the default value for chiOI'ine. Therefore. a value of 1 ppm will be added to the measured value 

of HCI before comparison to the HWC MACT emission standard. If the CPT data or any other evidence 

indicates the default value is not appropriate, it will be adjusted accordingly. 

3.3.2.1.4 System Controller 

A PLC provides control of the MC3, sample probe, pressure regulation module. and the sample interface. 

The PLC provides one minute averaged data, and validity status. for each analyte measured as well as 

flow. The calibration and linearity procedures are also controlled by the PLC. All data, and status flags. 

are sent to a data acquisition system tor data formatting and compliance determination. 

42 Rev. 7.0 

VES009390 
Eli Lilly and Company 

Lafayette, Indiana 

3.3.2.1 .5 Data Acquisition System and Historian 

Alternative Monitoring Petition 

HCi concentrations in part per n~llion corrected for moisture. data status. qualily assurance data, status 

nags, and system operational status/alarms are passed to a data acqu s~ion system (OAS) via modbus 

communication from the MC3 PLC. The OAS performs the data calculations for compliance. All data, 

both system status and HCI concentrations, are saved In an historian. 

3.3.2.2 Installation Locatlon 

The HCI CEMS extracts fts sample from the Rue gas stream In the stack. Section 3.1.1 of Performance 

Specification 2 provides guidance regarding appropriate monitor location. This measurement location is 

a !least: 

• 2 equivalent duct diameters downstream from the nearest control device. point of 

pollution generation or other point at which a change In the pollutant concentration or 

emission rate may occur. 

• 0.5 equivalent duct diameters upstream from the effluent exhaust. 

3.3.2.3 Installation 

The MC3 system will be Installed per manufacturer's recommendations. Once the system Is installed, it 

will be commissioned for use. This exercise will verify the system is installed properly per the 

manufacturer's spedfocation. 

3.3.2.4 Instrument Span 

The span for the HCI CEMS Is 100 ppmv. An Instrument span which covers the expected peak levels will 

help to ensure that the 12-hour rolling average value correctly accounts for the short periods of mora 

concentrated ss ons. Addftionalfy. 100 ppmv HCI caflbration gas is an HCI blending concentration 

much preferred by vendors. Due to the high reactivity of HCI, it is difficuH to ensure the continuing 

accuracy of the calibration gas at lower concentrations. 

3.3.2.5 System Start-up (Initial Operation) 

3.3.2.5.1 Factory Acceplance Test 

The Factory Acceptance Test will be executed at Ecochem Analytlcs. The objective of this testing is to 

ensure the Ecochem CEMS meets or exceeds the functional operating criteria. Results of the Factory 

Acceptance Test will be documented and include the following major components: 

1. Sample Extraction System 

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2. Pressure Regulation Module 

3. System Configuration 

4. Ecochem Multi-Component Infrared Analyzer 

5. Sys1em Controller 

3.3.2.6 System Start-up (Field Installation) 

Alternative Monitoring Petition 

Once the Ecochem CEMS is Installed, the system will undergo an installation qualification (IQ) to ensure 

the system is installed per the manufacturer recommendations. Following successful IQ of the MC3, the 

system will operate sampling ambient air for several weeks. During this time, MC3 operational issues will 

be addressed. Once the MC3 system has operated for several weeks without significant issues, dally QA 

procedures will begin (zero and upscale drift checks, alarm monitoring, and completion ol a daily system 

check sheet). The MC3 system wiD operate in this mode until the incinerator is ready to treat waste. 

3.3.2.7 Performance Specltlcation Test 

The certification of the Ecochem CEMS for HCI will follow the HCI CEMS Performance Specification 

(a«ached as appendix C). Specifically, the following will be either tested 01 documented: 1) data recorder 

scale, 2) daily calibration drift, 3) Installation and measurement location, 4) calibration drift test, 5) 

calibration error test, 6) system response time, 7) stratification test, and, 8) accuracy determination. Upon 

successful completion/verification of the above tests. the Ecochem CEMS can be used to show 

continuous compliance the HWC MACT HCI/CI; emission standard. Each test is described below: 

3.3.2..7.1 Data Recorder Scale 

The range of the data recorder and the measurement range of the HCI CEMS will be documented. The 

daily zero and upscale calibration checks will fall within this range. The HCI CEMS will have a 

measurement range of 0·1 00 ppm HCI. 

3.3.2.7 .2 Daily Calibration Drift 

The zero and upscale drift will be checked once daily. Zero gas (0 ppm HCI) will be used for the zero, 

and approximately 50 -100 ppmv HCI for the upscale. The calibration drift limH will be 5% of the 

instrument span, 01 ± 5 ppmv. Zero and high-level calibration drifts shall be adjusted, at a minimum, 

whenever the 24-hour zero drift exceeds the limits of the calibration drift specification of :tS ppmv. The 

amount of excess zero and hlgh·levet drift measured at the 24-hour interval checks will be recorded. 

3.3.2. 7.3 Installation and Measurement Location 

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The HCI CEMS extracts rts sample from the Due gas stream In the stack. Section 8.12 of Perfoonance 

Speclflcation 2 prOIIides guidance regarding appropriate monHor location. This measurement location is 

at least 

• 2 equivalent duct diameters downstream from the nearest control device. point of 

pollution generation or other point at which a change in the pollutant concentration or 

emission rate may occur. 

• 0.5 equivalent duct diameters upstream from the effluent exhaust. 

3.3.2.7.4 Seven Day Calibration Drift Test 

The procedure oullined in the HCI CEMS Performance Specification (attached as appendix C) will be 

used for this specification. The specification proposed for the calibration drift is 5 ppmv, which Is 5% of 

the instrument span. This is consistent with the expected drift for HCI monitoring using Fourier Transform 

Infrared Spectroscopy (FTlR) found In Performance Specification 15 (PS15), Section 10.1. Ills also 

consistent wllh Lilly's experience with a similar monHoring system in Ireland, and with others' experience 

in the U.S. The higher calibration drift for HCI monitoring as compared to that for NO, or SO. mo ~ori g 

appears to be a result of the reactivHy of HCI. The chemical's high reactivHy causes rt to "stick' to the 

calibration cylinder walls, and to be extracted unevenly from the cylinder during the calibration process. 

Thus, It is the calibration gas itself that is causing variance in the calibration drift results, as well as 

whatever drift the analyzer experiences. It is also worth noting that some other performance 

speclfocations, such asPS 4 (for CO) do allow a calibration drift of up to 5% of span. 

3.3.2.7.5 Calibration Error Tes1 

The Calibration Error test will follow the procedures In the HCI CEMS Perfoonance Specificatloo 

(adaehed as appendix C). The Ecochem CEMS will be challenged three non-consecutive times wrth 

zero, mid-level, and high-level certified gases. The cylinder gases will not be EPA Protocol 1 gases. The 

calibration gases wiH be injected into the sample system as close to the sampling probe outlet as practical 

and will pass through all CEMS components used during normal monitoring. The difference between the 

instrument response and the reference value (certified gas) will be calculated after each injection and the 

resulting three differences will be averaged to determine the CE at eaCh measurement point. The 

calibration error for each of the three levels ,v;n not exceed 5% of span. 

3.3.2.7.6 System Response Time 

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Using the Response Time Test procedure in the HCI GEMS Performance Specification (attached as 

appendix C), Li ly will determine a mean upscale and mean downscale system response time for the 

Ecochem (based upon CO). The slower of the upscale and downscale mean response times will be 

considered the system response time. The system response time will meet the requirements specified in 

performance specification (i.e. 2 minutes). 

3.3.2.7.7 Interference Response Determination 

The affect of other analytes upon the measurement of HCI wil be documented (Ecochem calibration 

table). 

3.3.2.7.8 Stratification Test 

The stratification of the gas stream will be determined using guidance in the HCI GEMS Performance 

Specification (attached as appendix C). Due to the low concentration of HCI expected in the gas stream. 

stratification will be documented in terms of velocity. A minimum of 12 sampling points will be used, with 

6 sampling points along each of the two traverses. 

The value at each traverse point is then compared to the average value for all sampling points to 

determine the percent stratification using the foRowing equation: 

S =JC - C J*IOO% i O•Vc 

where: 

S c percent stratification 

C, = velocity at sampling point I 

~ = average velocity at all sampling points. 

If the percent stratification is less than or equal to 10 percent for any traverse point, the duct Is not 

considered stratified at that location 

3.3.2.7.9 Accuracy Determination 

The accuracy of the HCI GEMS will be determined by performing either a Relative Accuracy 

determination, or by dynamic spiking. 

3.3.2.7.9.1 Relative Accuracy Determination 

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The proce<~ure outlined In the HCI CEMS Perlonnance Specification (atlached as appendix C) will be 

used as a guide for this specification. The RA of the CEMS must not be greater than 20% of the mean 

value of the reference method (RM) test data, or not greater than 10% in terms of the emlssioo standard 

(ppmv, dry), or have an absolute difference of less than 5 ppmv between the mean reference value and 

the mean CEMS value. 

3.3.2.7.9.2 Dynamic Spiking 

Dynamically spiking may be used in lieu of a Relative Accuracy Test as a means to document the 

accuracy, precision, and bias of the HCI CEMS. 

The dynamic spiking will follow the HCI Performance Specification (attached in Appendix C). Linear 

regression Is used to establish the accuracy, precision, and btas of the HCI CEMS. The criteria for the 

HCI dynamic spiking is (1) The correlation coefficient, r, must be greater than or equal to 0.90 (2) The 

stope must be 1.0, +/- 0.15 (3) The Intercept must be equal to or tess than 15% of the instrument span. 

See Figure 6 for the Ecochem dynamic spiking overview. 

3.3.2.8 Routine Operation of HCI CEMS 

Ongoing qua6ty assurance will fOIIoYI the CMS operation and maintenance requirements in 40 CFR 

63.8(c) and the quality control program requirements under 40 CFR 63.8(d). In addition, Lilly will perform 

daily calibration drift tests. quarterly calibration error audits (absolute calibration audit), and annual 

accuracy test audits as part of OlliJOing quality assurance. 

3.3.2.8.1 Daily Calibration Drift 

The zero and upscale drift will be checked once daily. Zero gas (0 ppm HCI) will be used for the zero, 

and approximately 50 -100 pprnv HCI for the upscale. The calibration drift lima will be 5% of the 

instrument span, or :t: 5 ppmv. Zero and high-level calibration drifts shall be adjusted, at a minimum, 

whenever the 24-hour zero drift exceeds the limits of the calibration drift specification of :t:S ppmv. The 

amount of excess zero and high-level drift measured at the 24-hour interval checks will be recorded. 

The HCI CEMS will be deemed out of control when either the zero or upscale drift exceeds 2x the 

performance specification. See Section 3.3.2.9. 

3.3.2.8.2 Quarterly Absolute Calibration Audit (Calibration Error Test) 

The Calibration Error test will follow the procedures in the HCI CEMS Performance Specification 

(attached as appendi~ C). The Eoochem CEMS will be challenged three non-consecutive times with 

zero, mid-level, and high-level certified gases. The cylinder gases will be certified gases (EPA Protocol 1 

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gases are not available for HCI). The catibration gases will be injected into the sample system as close to 

the sampling probe outlet as practical and will pass through all CEMS components used during normal 

monnoring. The difference between the instrument response and the reference value (certified gas) will 

be calculated after each injection and the resulting three differences will be averaged to determine the CE 

at each measurement point. The cafibration error for each of the three levels will not exceed 5% of span. 

An absolute calibration audit will be performed quarterly, except during the quarter the annual accuracy is 

performed. 

3.3.2.8.3 Annual Accuracy Test Aud it 

The accuracy of the HCI CEMS will be determined by performing enher a Relative Accuracy 

determination, or by dynamic Spiking. The location of the sample probe will be verified. 

3.3.2.8.3.1 Seven Day Drift Test 

Prior to the start of the accuracy test (either the Relative Accuracy Determination or Dynamic Sp;king) you 

must perform a calibration drift test for a period of at least seven daY$. The seven-day calibration drift test 

must be conducted When the faCility is under normal operations. During the calibration drift test period you 

must determine the magnitude of the zero calibration drift and the upscale calibration drift at least once 

each day. During the stability tests no adjustments or catibrations may be made to the CEMS. If periodic 

automatic or manual adjustments are made to the CEMS zero and calibration settings, conduct the CD 

test immediately before these adjustments, or conduct it in such a way that the CD can be determined. 

The zero and upscale drift each must be less than 5% of the Instrument span each day for seven 

consecutive daY$. 

3.3.2.8.3.2 Relative Accuracy Determination 

The procedure outlined in the HCI CEMS Performance Specification (attached as appendix C) will be 

used as a guide for this specification. The RA of the CEMS must not be greater than 20% of the mean 

value of the reference method (RM) test data, or not greater than 10% in terms of the emission standard 

(ppmv, dry), or have an absolute difference of less than 5 ppmv between the mean reference value and 

the mean CEMS value. 

3.3.2.8.3.3 Dynamic Spiking 

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Dynamically spiking may be used in lieu of a Relative Accuracy Test as a means to document the 

accuracy, precision, and bias of the HGI GEMS. 

The dynamic spiking will follow the HGI CEMS Performance Specification (attached in Appendix C). 

Linear regression is used to estabtish the accuracy, precision, and bias of the HGI GEMS. The criteria for 

tha HGI dynamic spiking are: (1) The oorrelation coefficient (r) must be greater than or equal to 0.90, (2) 

Tha slope must be 1.0, +/- 0.15, (3) Tha Intercept must be equal to or less than 15% of the Instrument 

span. See Rgure 6 for the Ecochem dynamic spiking oveiView. 

3.3.2.9 Out Of Control 

Out of control determinations will follow 40 CFR 63.8(c)(7). SpecifiCally, tha HGI CEMS will be considered 

out of control if the zero (low·level) or high level calibration drift exoeeds two times the applicable 

callbration drift specification (i.e. the calibration drift is greater than ± 10 pprnv.) In addition, the HCI 

GEMS will also be considered out of control if the GEMS fails the accuracy test ~ or absolute 

calibration audit 

When the HCI CEMS is out of control, Lilly will take the necessary corrective action and shall repeat all 

necessary tests which indicate that the system is out of control. Lmy will take oorrective action and 

conduct retesting until the performance requirements are below the applicable limits. The beginning of 

the out of control period is the hour Lilly conducts a perfonnance check that indicates an exceedance of 

tha performance requirements. Tha end of tha out of control period will be the hour following the 

completion of corrective action and successful demonstration that the system is within the allowable 

lim~. When the incinerator is operating in parametric mode, the HCI GEMS will not be deemed out of 

control. 

3.3.3 Use of HCI CEMS for Demonstrating Continuous Compliance with the HCIICI2 HWC MACT 

Emission Standard 

Lilly may begin using the Ecocham CEMS to demonstrate continuous compliance w~ the HWC MAGT 

HCIIC~ emission standard only after tha following is achieved: 

• A successful Performance Specification Test is performed following EPA's approval of this 

Alternative Monitoring Petition. 

• A modification to the TIUe v permit Is approved which establishes monitoring requirements based 

on the results of the approved AMP. 

Following completion of tha above, on-going quality assurance wHI be performed on the Ecochem CEMS 

as specified in Section 3.3.2.8 of this document. 

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3.3.4 Monitoring Frequency and Averaging Time 

The Ecochem CEMS will monitor and record an HCI concentration at least once every 15 seconds. A 

one minute average will be calculated from the four 15 second measurements during the minute as 

shown In the following equation: 

OMA = 4 + Cl 2 

where: 

OMA = HCII Cl2 one-minute average value (ppmvd) 

Ci = HCI fifteen second observation from the CEMS analyzer (ppmvd) 

Cl2 = Chlorine gas default value (1 ppmvd), 

The twelve hour rolling average will be calculated based on the average of the 720 most recent valid oneminute averages as shown in the following equation: 

Where: 

,,. 

L OMA 

THRA I • 

720 

THRA = Twelve hour rolling average value {ppmvd) 

OMA = One minute average value (ppmvd) 

The twelve hour roiling average will be updated every minute when a new one minute average is 

ca.lculated. 

The HCI/C12 stad< concenllation will be corrected to 7% oxygen by the following equation: 

21- 7 

HCI,.,, = HCI,"""". *--- 21 - 0 2 

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where: 

HCI"" = HCVCI, concentration, expressed as HCI corrected to 7% oxygen (ppmvd) 

HCI..., .. , = HCI/CI1 stack gas concentration. expressed as HCI (ppmvd) 

0 2 = Oxygen stack gas percent (vol % dry) 

3.3.4.1 Rolling Average Cal<:ulations during HCI CEMS Daily Calibration and Ongoing Quality 

Assurance Audits 

The Ecochem CEMS wiU be off-line for up to an hour, daily, to perform the daily quality assurance. 

Hazardous waste will continue to be burned while performing the zero and upscale drift checks for the 

Ecochem CEMS (CO, 0 2, HCI). This is in lieu of the 20 minutes per day provided for in the appendix to 

subpart EEE of part 63 (section 6.2 of the appendix). 

Rolling average calculations will be frozen while Ully performs the daily span drift check and zero drift 

check while continuing to bum hazardous waste, unless a redundant HCI measurement system is 

available. The rolling average calculations will be frozen for a period not to exceed one hour whlle 

burning hazardous waste for the daily calibration test. This hour includes the time needed to calibrate the 

Ecochem system for ail measured parameters (HCI, CO, 0 2, SO, and NO,). RoPing average calculations 

wlil resume once the span drift check and zero drift check have been performed. The twelve-hour rolling 

average calculations will resume by adding the first valid one-minute average after the drift check to the 

previous 719 one minute average values. 

In addition. rolling average calculations will also be frozen while the quartetly absolute calibration audn Is 

conducted. Rolling average cal<:ulalions will resume once the tests have been completed. The one-hour 

rolling average cal<:ulations will resume by adding the first valid one-minute average to the previous 59 

one minute average values. The twelve-hour rolling average calculations will resume by adding the first 

valid one-minute average to the previous 719 one minute average values. 

3.3.4.2 Rolling Average Calculations during System Autopurge 

The Ecochem CEMS may be purged automatically once per day while hazardous waste is being burned. 

Purging involves directing compressed air through the probe into the stack for a shot! period of lime to 

prevent buildup of solids in the probe. The purge period will last approximately 5 minutes. Purging the 

stack probe Is necessary for preventive maintenance reasons and is recommended by the CEMS 

manufacturer due to the types of wastes burned in the solid liquid incineration system. 

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