APPENDI X D 

CEM S AN D CM S QUALIT Y ASSURANC E PLAN S 
CONTINUOUS EMISSIONS MONITORING SYSTEM 

QUALITY ASSURANCE PLAN 

Prepared for: 

Veolia ES Technical Solutions, LLC 

Sauget, Illinois 

Prepared by: 

Franklin Engineering Group, Inc. 

Franklin, Tennessee 

October 2008 
TABL E O F CONTENT S 

1.0 INTRODUCTIO N AN D BACKGROUN D 1 

1.1 DESCRIPTION OF CEM S 1 

1.2 OVERVIEW OF REGULATORY REQUIREMENTS 2 

2.0 CEM S CALIBRATION S AN D PERFORMANC E 5 

2.1 DAILY DRIFT CHECKS 5 

2.2 CALIBRATION 8 

2.3 ABSOLUTE CALIBRATION AUDIT 10 

2.4 INTERFERENCE RESPONSE TEST 10 

2.5 RELATIVE ACCURAC Y TEST AUDIT 11 

3.0 CEM S MAINTENANC E 14 

3.1 DAILY SYSTEM AUDIT 14 

3.2 SPARE PARTS INVENTORY 14 

3.3 CALIBRATION GA S SUPPLY AND CERTIFICATION 15 

3.4 CORRECTIVE ACTION FOR MALFUNCTIONING CEM S 17 

4.0. INTEGRATIO N O F TH E CEM S WIT H TH E AWFC O SYSTE M 18 

4.1 EMISSION STANDARDS 18 

4.2 DRIFT LIMITS 18 

5.0. RECORDKEEPIN G AN D QUALIT Y ASSURANC E REVIEW S 19 

6.0 OPERATO R TRAININ G AN D CERTIFICATIO N 21 

i 
INDE X O F TABLE S 

TABL E 1 -1 REGULATORY REQUIREMENTS FOR THE CEM S Q C PROGRAM AND THE 

CEM S QAPLA N 3 

TABL E 2-1 OVERVIEW OF CEM S PERFORMANCE REQUIREMENTS 6 

TABL E 3 -1 SUMMARY OF CONCENTRATION REQUIREMENTS FOR CALIBRATION GASES 16 

LIS T O F APPENDICE S 

APPENDIX A CEM S DAT A SHEET S AN D CHECKLIST S 

ii 
1.0 INTRODUCTION 

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

incinerators (Units 2 and 3) and a transportable rotary kiln incinerator (Unit 4) at its 

facility located in Sauget, Illinois. These incinerators are subject to the National 

Emissions Standards for Hazardous Air Pollutants (NESHAP) for Hazardous Waste 

Combustors (HWCs), Part 63, Subpart EEE (§§63.1200 to 63.1221). The NESHAP for 

HWCs specifies emissions standards which reflect emissions performance of maximum 

achievable control technologies (MACT), and is commonly referred to as the HWC 

MACT. 

For each incinerator, Veolia utilizes a continuous emissions monitoring system (CEMS) 

for demonstrating on-going compliance with the carbon monoxide (CO) emission 

standard. These CEMS are subject to the requirements of the Appendix to 40 CFR Part 

63, Subpart EEE—Quality Assurance Procedures for Continuous Emissions Monitors 

Used for Hazardous Waste Combustors. This plan has been developed per the CEMS 

quality assurance (QA)/quality control (QC) requirements. Implementation of this plan 

will ensure that the CEMS generates, collects, and reports valid data that is precise, 

accurate, complete, and of a quality that meets the requirement of the HWC MACT 

Standard and the applicable performance specification. 

1.1 Description of CEMS 

Each incinerator is equipped with an EcoChem Analytics MC3 CEMS, which consists of 

the following major components: 

• Heated stack sample probe 

• Heated traced umbilical 

• Heated sample pump 

• EcoChem MC3 multicomponent infrared (IR) gas analyzer 

• Zirconium oxide-based oxygen analyzer 

• System controller and data acquisition system 

Hot, wet stack gas is drawn through the heated stack sample probe and heat traced 

umbilical using a heated sample pump. The sampling location is downstream of the 

induced draft (ID) fan. The umbilical supplies instrument air to the filter probe to allow 

for automated periodic blowback. It also supplies calibration gases through the sampling 

system. The stack gas sample is maintained at approximately 185°C through the 

1 
sampling equipment and analyzer sample cell to prevent the removal of pollutants from 

the sample through contact with condensed moisture. 

The sample cell consists of multiple mirrors that were adjusted and aligned at the factory 

to set the path length appropriate for the specific application. The MC3 multicomponent 

IR photometer uses a Gas Filter Correlation analytical technique to continuously monitor 

the stack gas concentrations of HCl and CO. The Single Beam Dual Wavelength 

analytical technique is used to continuously monitor stack gas water vapor (H2O) 

concentrations. 

A technical description and specification for the CEMS is presented in Section 2.0 of the 

MC3 Operations Guide, Section 2.1.1 documents the lowest range for each component 

and an accuracy of ±2% of full-scale value. The lower threshold is 1% of the lowest 

range. These technical specifications document that the CEMS is capable of meeting the 

requirements of the Appendix to Part 63, Subpart EEE and Performance Specification 4B 

of 40 CFR Part 60, Appendix B. 

The system controller controls the sampling system temperatures, purge/blowback, 

calibration checks, data handling, messaging, and alarms. The CEMS controller is 

integrated with the incinerator data acquisition system, automatic waste feed cutoff 

(AWFCO) system, and the main control system. 

A l l three incinerators are equipped with COSA model ZFN-11YA1-2Z1 O2 analyzers. 

These analyzers are zirconium oxide cells and are located downstream of the ID fan. 

1.2 Overview of Regulatory Requirements 

Cross-references and summaries of the applicable regulatory requirements are presented 

in Table 1-1. This table indicates the sections, tables, and figures of this document that 

address each particular requirement. 

2 
Table 1-1 

Regulatory Requirements for the CEMS QC Program and the CEMS QA Plan 

Regulatory Reference: 

Appendix to 

Subpart EEE of Part 63 

Description 

CEMS QA Plan 

Section 

Section 3.1.a.l Checks for component failures, leaks, and other 

abnormal conditions 

3.0 

3.1 

Section 3.1.a.2 Calibration of CEMS 2.2 

Section 3.1.a.3 Calibration Drift determination and adjustment 

of CEMS 

2.1,2.2 

Appendix A 

Section 3.1.a.4 Integration of CEMS with the AWFCO system 4.0 

Section 3.1.a.5 Preventive Maintenance of CEMS (including 

spare parts inventory) 

3.0 

Appendix A 

Section 3.1.a.6 Data recording, calculations, and reporting 

4.1 

5.0 

Section 3.1.a.7 Checks of record keeping 5.0 

Section 3. La. 8 Accuracy audit procedures, including sampling 

and analysis methods 

2.3,2.5 

Appendix A 

Section 3.1.a.9 Program of corrective action for malfunctioning 

CEMS 3.4 

Section 3.1.a. 10 Operator training and certification 6.0 

Section 3.1.b Reporting of excessive inaccuracies 5.0 

Section 3.2.1 QA responsibilities 5.0 

Section 3.2.2 

Schedules for: 

(1) daily checks 

(2) periodic audits 

(3) preventive maintenance 

(1) 3.0,3.1 

(2) 2.0, Table 2-1 

(3) 3.0 

Section 3.2.3 Check lists and data sheets Appendix A 

Section 3.2.4 Preventive maintenance procedures 3.0 

3 
Table 1-1 (Continued) 

Regulatory Requirements for the CEMS QC Program and the CEMS QA Plan 

Regulatory Reference: 

Appendix to 

Subpart EEE of Part 63 

Description 

CEMS QA 

Plan Section 

Section 3.2.5 Description of the media, format, and location 

of all records and reports 

5.0 

Section 3.2.6 

Provisions for review of the CEMS data; 

revisions or updates of the QA plan based on 

review 

5.0 

Section 4.1 

Check, record, quantify: 

(1) Zero Drift 

(2) Calibration Drift 

2.1 

Section 4.2 

Recording Requirements for: 

(1) Zero Drift 

(2) Calibration Drift 

2.1 

Appendix A 

Section 4.3 Daily System Audit 3.1 

Section 4.4 Data recording and reporting 5.0 

Section 5.1 Relative Accuracy Test Audit (RATA) 2.5 

Section 5.2 Absolute Calibration Audit (ACA) 2.3 

Section 5.3 Interference Response Test (IRT) 2.4 

Section 5.4 Excessive audit inaccuracies 

Table 2-1 

2.3 

2.5 

4 
2.0 CEMS CALIBRATIONS AND PERFORMANCE 

The CEMS must be operated, calibrated, and maintained to ensure conformance with the 

Appendix to Part 63, Subpart EEE and the EPA Performance Specification 4B (PS 4B). 

Calibration drift checks and performance demonstrations are performed periodically on 

the CEMS based on the following schedule: 

• Daily calibration checks for determination of Calibration Drift (CD) and Zero 

Drift (ZD). 

• Quarterly Absolute Calibration Audit (ACA) for determining calibration error 

(CE) for 02, CO, and HCl. 

• Annual Relative Accuracy Test Audit (RATA) for determining the CEMS relative 

accuracy (RA) for CO emissions. 

The procedures, QC criteria, corrective actions, and recordkeeping associated with these 

drift checks and audits are described in this section. A summary of the QC criteria and 

corrective actions is presented in Table 2-1. Blank data sheets are provided in Appendix 

A. 

2.1 Daily Drift Checks 

Daily drift checks are automatically initiated by the CEMS controller. During the 

automated calibration sequence, calibration gases are injected from pressurized cylinders 

through the sampling system. The sequence starts with the IR analyzer zero gas that is 

free of any of the constituents analyzed by the IR analyzer. This zero gas may also serve 

as the span gas for the integrated O2 analyzer. The zero gas flows through the system 

with enough time allowed for the analyzer to fully respond to the gas. Then the analyzer 

response to the zero gas is recorded for one minute and averaged. The next calibration 

gas in the calibration sequence is the first IR analyzer span gas. This span gas is a 

calibration standard that has one or more constituent concentrations at the analyzer span 

value (this gas may also be used as the zero gas for the O2 analyzer). The first span gas 

flows through the system to allow the analyzer enough time to fully respond to the gas. 

Then the analyzer response to the first span gas is recorded for one minute and averaged. 

This is then repeated for the second span gas and then possibly a third span gas 

depending upon the composition of the span gases. The total duration of this calibration 

sequence has been designed to not exceed the 20 minute maximum allowable CEMS 

downtime while burning hazardous waste. 

5 
Table 2-1 

Overview of CEMS Performance Requirements 

Analyzer Parameter 

(Span Value) QC Parameter 

Minimum 

Frequency 

QC Limit Corrective Action 

H2 0 

(60%) ZD Daily ±2% of span Zero Adjustment 

0 2 

(25%) 

ZD and CD Daily ±0.5% 0 2 Zero/Span Adjustment 

0 2 

(25%) 

CD Daily ±1.0% 0 2 Shut off waste, service/calibrate, conduct A C A 

0 2 

(25%) 

Cumulative Span 

Adjustment 

Per 

Adjustment 0 ±1.5% 0 2 Shut off waste, service/calibrate, conduct AC A 

2 

(25%) 

CE Quarterly

 1 0.5% 0 2 

Shut off waste, service/calibrate, conduct 

RAT A 

0 2 

(25%) 

R A Annually 1.0% 0 2 Shut off waste, service/calibrate, repeat RAT A 

CO 

(200 ppm) 

ZD and CD Daily ±3%o of span Zero/Span Adjustment 

CO 

(200 ppm) 

CD Daily 

±5% of span 

for 6 out of 7 day 

Shut off waste, service/calibrate, conduct AC A 

CO 

(200 ppm) 

CD Daily ±6% of span Shut off waste, service/calibrate, conduct AC A 

CO 

(200 ppm) 

Cumulative Span 

Adjustment 

Per 

Adjustment 

±9% of span Shut off waste, service/calibrate, conduct AC A 

CO 

(200 ppm) 

CE Quarterly

 1 5% 

Shut off waste, service/calibrate, conduct 

RAT A 

CO 

(200 ppm) 

R A 2 Annually 

5 ppmdv @ 7%> O2 

(See Section 2.5) 

Shut off waste, service/calibrate, conduct 

RAT A 

The ACAs for determining the O2 and CO CE are conducted quarterly, except in a quarter when a RAT A is conducted instead. 

The R A accuracy for CO is based on the units of the CO emission standard (ppmdv @ 7% O2). CO data collected from the 

analyzer during the RAT A will include low and or high range values per the normal operating requirements. 

6 
Table 2-1 (continued) 

Overview of CEMS Performance Requirements 

Analyzer Parameter 

(Span Value) QC Parameter 

Minimum 

Frequency 

QC Limit Corrective Action 

CO 

(3000 ppm) 

ZD and CD Daily ± 3% of span Zero/Span Adjustment 

CO 

(3000 ppm) 

CD Daily 

±5% of span 

for 6 out of 7 day 

Shut off waste, service/calibrate, conduct AC A 

CO 

(3000 ppm) CD Daily ±6% of span Shut off waste, service/calibrate, conduct AC A CO (3000 ppm) 

Cumulative Span 

Adjustment 

Per 

Adjustment 

±9% of span Shut off waste, service/calibrate, conduct AC A 

CO 

(3000 ppm) 

CE Quarterly3 5% Shut off waste, service/calibrate, conduct RAT A 

HCl 

(1000 ppm) 

ZD and CD Daily ± 3% of span Zero/Span Adjustment 

HCl 

(1000 ppm) 

CD Daily 

±5% of span 

for 6 out of 7 day 

Shut off waste, service/calibrate, conduct AC A 

HCl 

(1000 ppm) CD Daily ±6% of span Shut off waste, service/calibrate, conduct AC A HCl (1000 ppm) 

Cumulative Span 

Adjustment 

Per 

Adjustment 

±9% of span Shut off waste, service/calibrate, conduct AC A 

HCl 

(1000 ppm) 

CE Quarterly4 5% Shut off waste, service/calibrate, conduct AC A 

The ACAs for determining the O2 and CO CE are conducted quarterly, except in a quarter when a RAT A is conducted instead. 

A RAT A for HCl may be performed annually in lieu of performing an AC A in that quarter. 

7 
The drift for each stack gas constituent is determined as the difference between the 

known constituent concentration in the calibration gas and the analyzer reading. ZD is 

the drift determined using zero gas. CD is the drift determined using span gases. ZD and 

CD are determined daily for 0 2, CO, and HCl. ZD for H 2 0 is also determined daily. 

The ZD and CD are recorded by the CEMS datalogger as a percent of full-scale deviation 

(Dev%). Given that the "span value" is equal to the "full-scale" value, Dev% is 

calculated as follows: 

Dev% = \Drift %\ 

^ ,, „, reference concetration - analyzer responce , 

Drift % = — - • 100 

span value 

For CO and 0 2, if Dev% for CD exceeds the limits specified in the applicable 

Performance Specifications in 40 CFR Part 60, Appendix B, the analyzer must be 

calibrated. If the Dev% for CD is greater than the preset tolerance (Tol%) the instrument 

technician will notify the incinerator operator and waste feeds will be shut off until 

corrective measures have been taken. The CD tolerances for both 0 2 and CO have been 

set at the two times the performance specification limits. A calibration failure alarm 

indicates that the analyzer is out-of-control and must be serviced and recalibrated. An 

A C A must be conducted to document that the analyzer is within the performance 

specifications prior to resuming hazardous waste burning. 

For CO, if the Dev% for CD is greater than 5% for 6 out of 7 days, then the analyzer is 

out-of-control and must be serviced and recalibrated. An AC A must be conducted to 

document that the analyzer is within the performance specifications prior to resuming 

hazardous waste burning. 

Similar requirements for drift limits apply to HCl, except that no performance 

specifications have been promulgated for CEMS monitoring these parameters. In lieu of 

limits specified by an EPA Performance Specification, Veolia has developed selfimposed performance specification limits for HCl. These limits are specified in Table 2-

1. 

2.2 Calibration 

Calibration of the analyzer will be conducted periodically to ensure that the results of 

drift checks, ACAs, or RATAs meet the applicable performance specifications. 

8 
Calibration for each IR channel (H2 0, CO, and HCl) may be performed daily during the 

automated calibration sequence used to determine calibration drift. For each calibration 

gas used during the automated sequence, the automatic calibration will reset the analyzer 

response to correspond with the known reference concentrations. Any automated 

calibration adjustment will be made immediately after the analyzer response to the 

calibration gas is recorded electronically. The drift determined immediately prior to a 

calibration adjustment is equal to the magnitude of the adjustment. The oxygen analyzer 

uses a two-point calibration curve. The first calibration point resets the measured 

concentration of air to 20.94%. The second calibration point resets the measured 

concentration of a low concentration calibration gas to its known concentration. This 

calibration is performed manually. To document the calibration adjustment, the actual 

measurement at each calibration point prior to adjustment will be recorded. 

Following service to the MC3 analyzer that could affect its calibration, each IR channel, 

and the 0 2 analyzer will be calibrated. The CEMS Drift and Calibration Data Sheet in 

the Appendix to this document will be used to track the cumulative span adjustments 

(i.e., change in the calibration factor). Section 5.5 of the MC3 CEMS Operations Guide 

and Section 4.4 of the MC3 CEMS System Guide should be referred to as needed for 

additional detail regarding calibration of the CEMS. 

If the cumulative calibration adjustment for CD is three times the performance 

specification limits at any time, hazardous waste burning will be cutoff. The analyzer 

will be serviced, recalibrated, and an AC A will document that hazardous waste burning 

can recommence. A calibration factor that has been verified through an AC A will 

become the new reference point for assessing the cumulative adjustments made to correct 

for calibration drift. 

The incinerator can remain on hazardous waste during CEMS drift checks, calibrations, 

purges, and corrective actions for CEMS failures provided that the CEMS downtime does 

not exceed 20 minutes. During these times, the instantaneous values used to determine 

one-minute averages of dry, oxygen corrected concentrations of CO are discarded. This 

allowance is provided by Section 6.2 and 6.5.1 of the Appendix to Subpart EEE. The 

applicable regulatory requirements do not limit the frequency that this allowance can be 

utilized. Typically, this allowance will only be utilized once per day for the daily drift 

checks. Since the oxygen analyzer cannot be calibrated during the automatic calibration 

of the IR channels, calibration of the oxygen analyzer will require additional downtime. 

9 
If a there is a CEMS failure, the incinerator may remain on hazardous waste provided that 

the CEMS can be restored within 20 minutes. 

Following downtime, the CEMS must be within the performance specifications described 

in this document. Otherwise, hazardous waste burning will cease until the appropriate 

corrective measures can be taken. To ensure that the hourly rolling average (HRA) for 

CO is representative of current operating conditions, CEMS data validity must be at least 

75% (i.e., 60 valid one minute averages per 80 minutes of normal operations). 

2.3 Absolute Calibration Audit 

A n AC A is conducted quarterly for 02, CO (high and low range), and HCl. For O2 and 

CO, an AC A is not conducted in the quarter that the required annual RAT A is performed. 

The AC A is conducted according to the calibration error (CE) test procedure described in 

the Performance Specifications 4B. During the ACA , the analyzer is challenged over 

each range with EPA Protocol 1 cylinder gases. The EPA Protocol 1 cylinder gases are 

NIST traceable calibration standards. For a given parameter, the analyzer response is 

recorded at three measurement points. This is then repeated twice to give three sets of 

data. The CE at each measurement point is determined as follows: 

CE = 

d 

FS 

•100% 

where d is the mean difference between the CEMS response and the known reference 

concentration and FS is the span value. 

For CO and HCl, the CE determined at each measurement point cannot exceed 5%. For 

02, CE cannot exceed 2%. If an AC A fails to pass the QC criterion (i.e., the audit 

indicates excessive inaccuracy), then hazardous waste burning cannot resume until 

corrective measures have been taken and a RAT A demonstrates that the CEMS is 

operating within the performance specifications. 

2.4 Interference Response Test 

The MC3 analyzer corrects for interferences using additive and multiplicative 

interference tables. These tables were generated per the manufacturer's procedure at the 

initial setup of the CEMS system. An Interference Response Test (IRT) is listed in the 

Appendix to Subpart EEE, however, the Performance Specification 4B does not include 

requirements or acceptance criteria for an interference response test. Veolia will perform 

10 
Interference Response Tests at such time as US EPA specifies the test procedures and 

acceptable criteria for an Interference Response Test. 

2.5 Relative Accuracy Test Audit 

The Relative Accuracy Test Audit (RATA) is required annually for 0 2 and CO CEMS. 

The Relative Accuracy (RA) test procedures required by Section 7.2 of PS 4B references 

incorrect sections of PS 3 (for 02 ) and PS 4A (for CO). The applicable sections of the 

performance specifications are: 

• RAT A procedures: Sections 8.4.3 through 8.4.5 of PS 2. 

• 0 2 reference methods: Section 8.2 of PS 3 

• CO reference methods: Section 8.2 of PS 4A. 

• 0 2 RA calculations: Section 12.0 of PS 3 

• CO RA calculations: Section 12.0 of PS 2 

• 0 2 R A criterion: Section 13.2 of PS 3 

• CO R A criteria: Section 13.2 of PS 4A 

A brief summary of the applicable reference methods are provided below: 

US EPA Method 3/3A (Stack Gas Composition and Molecular Weight) 

The sampling and analytical procedures outlined in this method will be used to determine 

the 0 2 composition of the stack gas during the RATA. Using this method, a gas sample 

is extracted from the stack at a constant rate for determination of O2, C0 2 and molecular 

weight. The integrated gasbag collection option will be employed. The gasbags will be 

analyzed using an Orsat analyzer. As an alternative, the Method 3A (instrumental 

analyzer) method may be used for analysis of the sample. 

US EPA Method 4 (Stack Gas Moisture Content) 

If necessary, the sampling and analytical procedures outlined in this method will be used 

to determine the moisture content of the stack gas during the RATA. Using this method, 

a gas sample is extracted from the stack. The gas passes through a series of impingers 

that contain reagents. The impingers are connected in series and are contained in an ice 

bath in order to assure condensation of the moisture in the gas stream. Any moisture that 

is not condensed in the impingers is captured in the silica gel, ensuring that all moisture 

can be weighed and entered into moisture calculations. 

US EPA Method 10 (Carbon Monoxide CEMS) 

11 
A continuous emissions monitor will be used to continuously sample exhaust gas for 

carbon monoxide analysis as described in EPA Method 10. Using this method, a 

continuous gas sample is extracted from the exhaust gas, and is analyzed for carbon 

monoxide (CO) using a Luft-type Non-Dispersive Infrared Analyzer (NDIR), or another 

equivalent analyzer. This sampling and analysis will occur continuously throughout the 

duration of each run of the RATA. 

During a test run of the RATA, US EPA reference methods are utilized to obtain stack 

gas data. These data are used to calculate the stack gas dry 0 2 concentration and the 

stack gas CO concentration corrected to seven percent oxygen in units of parts per 

million, dry volume (i.e., in the units of the emission standard, 100 ppmdv CO @ 7% 

O2). The average stack gas O2 (%, dry) and CO (ppmdv, @ 7% O2) concentrations—as 

calculated from the installed CEMS over the duration of the run—are compared to the 

value obtained using the reference methods. The RAT A consists of a minimum of 9 test 

runs. If more test runs are conducted, at least 9 data sets will be used to determine RA, 

and no more than three sets of data will be rejected. The O2 and CO RA calculations and 

acceptance criteria are presented below. 

RA. 

oxygen 

^00 = 

<1.0%O2,dry 

+ \CC\ 

RM 

• 100% < 10%...for RM > 50 ppmdv @ 7% 02 

d + \CC\<5ppmdv @ 7% 02

...for RM < 50ppmdv @ 7% 02 

where, 

d = -•YJ{RMi-CEMSi) 

n j 

n = number of test runs 

RMj = the concentration determined by the reference method for the i t h test run 

CEMSj = the concentration determined by the CEMS for the i t h test run 

CC = the 2.5 percent error confidence coefficient (see Section 12.4 of PS 2) 

If a RAT A fails to pass the QC criterion (i.e., the audit indicates excessive inaccuracy), 

then hazardous waste burning cannot resume until corrective measures have been taken 

and a RAT A demonstrates that the CEMS is operating within the performance 

12 
specifications. If CO emission levels are significantly low, it may be difficult to produce 

meaningful results using the R A test procedure. Under these circumstances, Veolia will 

request approval to utilize the Alternative R A Procedure prescribed by Section 7.3 of PS 

4B. 

13 
3.0 CEMS MAINTENANCE 

Veolia has developed a preventative maintenance program for the CEMS. This program 

includes frequent inspections of the CEMS in order to identify potential component 

failures, leaks, and data quality issues. The CEMS preventative maintenance program 

also includes scheduled replacement of critical components and maintenance of spare 

parts inventory. Al l scheduled and unscheduled maintenance of the CEMS will be 

documented in a CEMS logbook maintained for each incinerator. Section 8.0 of the MC3 

CEMS Operations Guide provides details for daily, weekly, monthly, quarterly, and 

annual inspection and maintenance activities. Procedures and recordkeeping for the 

specific inspection and maintenance activities are described below. 

3.1 Daily System Audit 

The Daily System Audit includes: 

• Review of the daily drift check data 

• Inspection of the recording system 

• Check for controller alarms and error/warning messages 

• Check expected calibration values 

• Check of current data status 

• Check of calibration gas cylinder pressures 

• Check calibration gas pressure regulator settings 

• Inspection of the instrument air pressure 

• Inspection of the stack gas sampling system 

The Daily System Audit Checklist will be used to document the findings from the daily 

system audit. A CEMS Drift and Calibration Data Sheet will be completed during the 

daily system audit in order to track and evaluate drift and adjustments made to the 

CEMS. 

3.2 Spare Parts Inventory 

CEMS spare parts are maintained in sufficient quantities on-site to perform routine 

maintenance activities. It is anticipated that these spare parts and typical maintenance 

supplies will be adequate to service the CEMS. Some services and replacement of 

components must be performed by an EcoChem Analytics Service Engineer to avoid 

violation of the system certification. 

14 
The following consumable parts have been targeted for periodic inspection and 

replacement for maintaining the CEMS: 

• Air conditioner filters for CEMS shelter 

• Instrument air coalescing filters 

• Sample pump Teflon diaphragm 

• Sample pump Teflon flapper valve 

• Sample probe internal filter 

• Sample probe gaskets 

• Probe-tip filter 

The following spare parts are not part of routine maintenance and would be replace by an 

EcoChem Service Engineer: 

• Cell front cover gasket 

• Cell inlet filter 

• Cell windows with o-ring gaskets 

• Cell mirrors 

The CEMS Calibration Gas and Spare Parts Log is provided in Appendix A and will be 

used as needed to keep track of inventory. 

3.3 Calibration Gas Supply and Certification 

A summary of the calibration gases needed to perform the daily drift checks, calibrations, 

and ACAs is presented in Table 3-1. The number of gas cylinders maintained on-site 

depends on the specific mixture of gases in each cylinder and the lead time required for 

placing orders. An inventory of calibration gases will be conducted in conjunction with 

the spare parts inventory to ensure that the appropriate gases are available for use. 

Certification from the supplier of calibration gas quality will be kept with the most recent 

spare parts inventory documentation. 

Each calibration sequence depletes approximately 40 psi, and a cylinder with less than 

150 psi should be replaced. The daily system audit includes inspection of the calibration 

gas cylinder pressures and will be used track usage and to predict when to reorder. 

15 
Table 3-1 

Summary of Concentration Requirements for Calibration Gases 

Constituent QC 

Parameter 

Concentration 

Requirement 

Accuracy 

H 2 0 ZD 0% per gas supplier 

o2 

ZD 0% per gas supplier o2 

CD 25% per gas supplier 

o2 

A C A 0-2% E PA Protocol 1/NIST Traceable 

o2 

A C A 8-10% E PA Protocol 1/NIST Traceable 

o2 

A C A 14-16% E PA Protocol 1/NIST Traceable 

CO (low range) ZD 0 ppm per gas supplier CO (low range) 

CD 200 ppm per gas supplier 

CO (low range) 

A C A 0-40 ppm E PA Protocol 1/NIST Traceable 

CO (low range) 

A C A 60-80 ppm E PA Protocol 1/NIST Traceable 

CO (low range) 

A C A 140-160 ppm E PA Protocol 1/NIST Traceable 

CO (high range) ZD 0 ppm per gas supplier CO (high range) 

CD 3000 ppm per gas supplier 

CO (high range) 

A C A 0-600 ppm E PA Protocol 1/NIST Traceable 

CO (high range) 

A C A 900-1200 ppm E PA Protocol 1/NIST Traceable 

CO (high range) 

A C A 2100-2400 ppm E PA Protocol 1/NIST Traceable 

H Cl ZD 0 ppm per gas supplier l 

CD 1000 ppm per gas supplier 

H Cl 

A C A 0-200 ppm E PA Protocol 1/NIST Traceable 

H Cl 

A C A 300-400 ppm E PA Protocol 1/NIST Traceable 

H Cl 

A C A 700-800 ppm E PA Protocol 1/NIST Traceable 

16 
3.4 Corrective Action for Malfunctioning CEMS 

It is Veolia's policy to minimize the occurrence of malfunctions by taking a proactive 

approach to facility maintenance. Proactive measures include the preventive 

maintenance described in this section, and the calibration and performance testing 

described in Section 2.0. Frequent inspections and availability of spare parts allow for 

the timely completion of as needed service to the CEMS prior to a major malfunction. 

Operating and maintaining the incinerator during a malfunction will be conformance with 

the Startup, Shutdown, and Malfunction Plan (SSMP). Attachment 4 to the SSMP is the 

Program of Corrective Action for Malfunctions. Section 9.2 of the Program of 

Corrective Action for Malfunctions addresses corrective actions for malfunctioning 

CEMS. Section 9.0 through 9.2 of the MC3 CEMS Operations Guide may be referred to 

as needed for troubleshooting and corrective maintenance of the CEMS. 

17 
4.0. INTEGRATION OF THE CEMS WITH THE AWFCO SYSTEM 

The CEMS is integrated with the automatic waste feed cutoff (AWFCO) system to assure 

on-going compliance with CO emission standards. The AWFCO system is designed to 

immediately and automatically shut of all waste to the incinerator in the event of an 

exceedance of an emission or operating limit. The CEMS is integrated with AWFCO 

system through interlocks. These interlocks are conditions which trigger a relay causing 

the AWFCO system to activate. This section describes the AWFCO interlocks associated 

with the CEMS. 

4.1 Emission Standards 

The CEMS raw data for Oz (% vol), H 2 0 (% vol), and CO (ppmv) consists of 

instantaneous values which have not been smoothed or averaged, evaluated once every 

15 seconds. These values are used to calculate CO emissions in the units of emission 

standards. Calculations equivalent to the following procedures are performed to compare 

the stack gas emissions to the CO emission standard. 

First 15-second data in the units of the emission standards are calculated: 

( \ 

CO@7% O2,ppmdv = 

CO, ppmv 

IOO%-(H2O,%) 

14% 

21%- o7

,% 

100%-{H2O,%) 

The calculated 15-second data are then used to calculate one-minute averages (OMAs). 

The current minute OM A is averaged with the previous 59 OMAs to generate an hourly 

rolling average (HRA). Al l rounding is avoided for the numbers used to calculate HRAs. 

The HRA of CO emissions are rounded to two significant figures. 

If the HR A CO emission concentration exceeds the CO emission standard of 100 ppmdv 

@ 7% 0 2, an AWFCO will occur. 

4.2 Drift Limits 

As described in Section 2.1, waste feeds will be manually shut off in case a drift limit is 

exceeded. For CO and 0 2, drift limits are equal to 2 times the performance 

specifications. Comparable drift limits have been established for excessive H 2 0 drift. 

18 
5.0. RECORDKEEPING AND QUALITY ASSURANCE REVIEWS 

Documentation generated from CEMS QA/QC procedures and monitoring will be kept 

on-site for a period of five years. The data and documentation that is generated and 

reviewed is kept in various locations at the Veolia facility. Table 6-1 below lists the 

storage location and format of this documentation. 

Maintenance and Instrument Technicians have the primary responsibility for creating and 

organizing CEMS data sheets, daily system audit checklists, maintenance logbook, and 

spare part inventory records. The Environmental Engineer/Specialist or designee will 

check these records quarterly to verify completion and organization. This review will 

also consider the following requirements: 

1. Whenever excessive audit inaccuracies occur for two consecutive quarters, the 

current written procedures will be revised or the CEMS modified or replaced to 

correct the deficiency causing the excessive inaccuracies. Previous versions of 

written procedures will be kept on record and made available for inspection. 

2. If the ZD and/or CD exceed(s) two times the limits in the Performance 

Specifications, or if the cumulative adjustment to the ZD and/or CD exceed(s) 

three times the limits in the Performance Specifications, the CEMS is considered 

"out-of-control" (as defined in 40 CFR 63.8(c)(7)), and the event will be reported 

in the facility's semi-annual "Excess Emissions and CMS Performance Report". 

Further detail on this report can be found in the facility CMS Quality Assurance 

Program. 

On an annual basis the Environmental Engineer/Specialist or designee will review all 

CEMS data generated for the previous 12 months and prepare a brief internal 

report/memo summarizing findings. Based on this review, the Environmental 

Engineer/Specialist or designee will solicit recommendations for revisions to the CEMS 

Quality Assurance Plan. The CEMS Quality Assurance Plan will be revised as needed to 

maintain QA/QC of the CEMS. Al l versions of this plan for the last five years remain in 

the operating record. 

19 
Table 5-1 CEMS Records and Reports 

Record/Report Storage Location Media/Format1 

CEMS QA Plan 

- Current Version 

- Previous Version 

Incinerator Manager's Office 

Operating Records Archives 

HD and/or P 

RD 

CEMS Readings and HRA 

- Previous year through year to date 

- Remaining archives 

Data Historian 

Operating Records Archives 

HD and/or RD 

RD 

Drift and Calibration Data: 

- Previous year through year to date 

- Remaining archives 

Operating Records Archives P and/or RD 

Absolute Calibration Audit 

- Previous year though year to date 

- Remaining archives 

Operating Record Archives P and/or RD 

Relative Accuracy Test Audit 

- Previous year through year to date 

- Remaining archives 

Operating Record Archives P and/or RD 

Daily System Audit 

- Previous year through year to date 

- Remaining archives 

Operating Record Archives P and/or RD 

Preventive Maintenance Logbook 

- Previous year through year to date 

- Remaining archives 

Operating Records Archives P and/or RD 

Spare Parts Inventory 

- Previous year through year to date 

- Remaining archives 

Operating Records Archives P and/or RD 

Annual Review of CEMS Data Operating Records Archives 

P and/or HD 

and/or RD 

1

 Media Format: 

HD - Computer or network hard drive 

RD - Removable drive (floppy, CD, backup tape) 

P - Paper documentation 

20 
6.0 OPERATOR TRAINING AND CERTIFICATION 

Training is provided to Veolia employees on the basis of their job title. Individuals 

specifically involved in the operation of the incinerator and associated CEMS are the 

Instrument Technicians, Incinerator Operators, and Environmental Engineer/Specialist. 

The Veolia operator training and certification program meets the requirements outlined in 

40 CFR 63.1206(c)(6). Documentation of employee training and certification is kept 

with the Training Director, and is available for review upon request. 

21 
APPENDIX A 

CEMS DATA SHEETS AND CHECKLISTS 

NOTE: THE FOLLOWING SHEETS ARE FOR EXAMPL E PURPOSES ONLY. 

VEOLIA MA Y UTILIZE EQUIVALENT DOCUMENTATION FOR AN Y OF THE 

SHEETS INCLUDED. 
CEMS DRIFT AND CALIBRATION DATA SHEET 

Parameter 

(Span Value) 

Date & Time 

Concentration 

Drift % Adjustment % 

Cumulative 

Adjustment % 

Parameter 

(Span Value) 

Date & Time 

Reference Analyzer 

Drift % Adjustment % 

Cumulative 

Adjustment % 

HzO (60 %) 

Zero 

Oz (25%) 

Zero 

Calibration 

CO (200 ppm) 

Zero 

Calibration 

CO (3000 ppm) 

Zero 

Calibration 

HCl (1000 ppm) 

Zero 

Calibration 

Drift % =

 RfifeW0C * - AmlyZer

. 100% 

Span Value (Name & Title) 

Adjustment % = Drift % (if zero/span was reset during drift check) 

Cumulative Adjustment % = (Previous Cumulative Adjustment %) + (Current Adjustment %) 

(Signature) 
ABSOLUTE CALIBRATION AUDIT (ACA) 

DATA SHEET 

Parameter 

• o2 

EH CO-low range 

f~l CO-high range 

• HCl 

NIST Traceable Calibration Standards 

Parameter 

• o2 

EH CO-low range 

f~l CO-high range 

• HCl 

Gas Concentration 

Parameter 

• o2 

EH CO-low range 

f~l CO-high range 

• HCl 

Low (Zero) ± 

Parameter 

• o2 

EH CO-low range 

f~l CO-high range 

• HCl 

M id ± 

Parameter 

• o2 

EH CO-low range 

f~l CO-high range 

• HCl High ± 

RUN 

NUMBER 

RUN Concentration Difference 

NUMBER Reference Analyzer Low Mid High 

1 - Low — — 

2-Mi d ~ 

3 - High — -

4-Low — — 

5-Mi d ~ — 

6 - High ~ ~ 

7-Low — — 

8-Mi d — — 

9 - High — 

MEAN DIFFERENCE = 

CALIBRATION ERROR = 

MEAN DIFFERENCE = 

CALIBRATION ERROR = % % % 

Calibration Error = ^ e a n Difference * ^QQ 

Span Value 

(Name) (Title) 

(Signature) (Date) 
RELATIVE ACCURACY TEST AUDIT RATA 

DATA SHEET 

Reference Method CEMS Difference Reference Method CEMS Difference 

Run H2 0, % 

(if applicable) 

02, % wet 

(if applicable) 

02, % dry 02

, % dry 02

, % dry 

CO ppmv 

(if applicable) 

CO ppmdv 

CO ppmdv 

@ 7% 0 2 

CO ppmdv 

@ 7% 0 2 

CO ppmdv 

@ 7% 0 2 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

0 2RA Mean Difference 

Standard Deviation 

Confidence Coefficient 

CORA 

(Name) (Title) 

(Signature) (Date) 
CEMS DAILY SYSTEM AUDIT 

Initials 

Verify that the most recent drift checks and calibration adjustments are within limits. 

Complete Drift and Calibration Data Sheet. 

Corrective Actions: 

Verify proper operation of CEMS data recording and printing 

Corrective Actions: 

Check for controller alarms and error/warning messages 

Corrective Actions: 

Check expected calibration values 

Corrective Actions: 

Check current emissions data status 

Corrective Actions: 

Verify calibration gas cylinder pressures (>150 psi) 

Corrective Actions: 

Verify pressure regulator settings (approximately 25-35 psi) 

Corrective Actions: 

Verify proper instrument air pressure to CEMS umbilical 

Corrective Actions: 

Perform visual inspection of the stack gas sampling system 

Corrective Actions: 

(Name) 

(Signature) 

(Title) 

(Date) 
CEM S CALIBRATIO N GA S AN D SPAR E PART S LO G 

CALIBRATION GASES: 

(Attach all certification forms) 

Zero gas: 

Span gas 1 

Span gas 2 

Span gas 3 

A C A Gases: 

cylinders 

cylinders 

cylinders 

cylinders 

Composition: 

Composition: 

Composition: 

Composition: 

PARTS: 

Air conditioner filters for CEMS shelter 

Instrument air coalescing filters 

Sample pump Teflon diaphragm 

Sample pump Teflon flapper valve 

Sample probe internal filter 

Sample probe gaskets 

Probe-tip filter 

Cell front cover gasket 

Cell inlet filter 

Cell windows with o-ring gaskets_ 

Cell mirrors 

Tubing 

Fittings _____ 

Solenoid Values 

Thermocouples 

Electronic parts 

Other spare parts 

Inventory taken by: Date: 

CONTINUOUS MONITORING SYSTEM 

QUALITY CONTROL PROGRAM 

Prepared for: 

Veolia ES Technical Solutions, LLC 

Sauget, Illinois 

Prepared by: 

Franklin Engineering Group, Inc. 

Franklin, Tennessee 

October 2008 
TABLE OF CONTENTS 

1.0 INTRODUCTION AND BACKGROUND 1 

1.1 SUMMARY OF FACILITY INFORMATION 4 

1.1.1 Fixed Hearth Incinerators 4 

1.1.2 Rotary Kiln Incinerator 5 

1.2 CM S INSTRUMENTATION 6 

2.0 CMS CALIBRATION AND PREVENTIVE MAINTENANCE 13 

2.1 CM S CALIBRATION 13 

2.1.1 Initial CMS Calibration 13 

2.1.2 Subsequent CMS Calibration 13 

2.1.3 CEMS Calibration Audits and Calibration 14 

2.2 CM S CALIBRATION AUDITS 14 

2.3 PREVENTIVE MAINTENANCE 19 

3.0 CMS RECORDKEEPING AND REPORTING 20 

3.1 RECORDKEEPING 20 

3.2 REPORTING 21 

4.0 CMS CORRECTIVE ACTIONS 24 

ii 
INDEX OF TABLES 

TABL E 1-1 REGULATORY CHECKLIST FOR THE CM S Q A PROGRAM 2 

TABL E 1 -2 CM S INSTRUMENT SPECIFICATIONS 7 

TABL E 2-1 CM S CALIBRATION AUDIT REQUIREMENTS 15 

TABL E 3 -1 REPORTING REQUIREMENTS 23 

iii 
1.0 INTRODUCTION AND BACKGROUND 

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

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

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

Hazardous Air Pollutants (NESHAP) for Hazardous Waste Combustors (HWC), Part 63, 

Subpart EEE (§ 63.1200 to § 63.1221). The NESHAP specifies emissions standards 

which reflect emissions performance of Maximum Achievable Control Technologies 

(MACT), and is commonly referred to as the HWC MACT. 

Hazardous waste combustors are required [per § 63.8(d)(2)] to establish and implement a 

Continuous Monitoring System (CMS) Quality Control (QC) Program. The purpose of 

the QC Program is to outline procedures used to verify that the CMS are properly 

installed, calibrated, and collecting accurate data on an ongoing basis. The CMS 

performance evaluation test plan was submitted as part of the Comprehensive 

Performance Test Plan. 

The QC Program demonstrates Veolia's compliance with the requirements set forth in 

§ 63.8(d)(2), as well as the additional quality assurance (QA) requirements. The QC 

Program is required to contain descriptions of initial and subsequent CMS calibration, 

calibration drift, preventive maintenance, data recording, calculations and reporting; and 

a corrective action plan for malfunctioning CMS. Table 1-1 presents the regulatory 

references related to the QC program, followed by the section of this plan that addresses each 

specific requirement. Some references are made to other HWC MACT required facility 

operating plans. 

This QC Program is intended to fulfill the requirements of § 63.8(d)(2), and includes 

information related to the procedures for each of the following operations: 

• Initial and subsequent calibration of the CMS 

• Detenriination and adjustment of the calibration drift of the CMS 

• Preventive maintenance of the CMS, including spare parts inventory 

• Data recording, calculations, and reporting 

• Program of corrective action for malfunctioning CMS. 

1 
Table 1-1 

Regulatory Checklist for the CMS QA Program 

Regulatory 

Citation 

Description Plan Section 

§ 63.8(c)(l)(i) Operation and maintenance of each CMS 

Section 1.2, 2.3 

O & M Plan 

CEMS Plan 

§ 63.8(c)(l)(iii) Startup, shutdown, and malfunction plan for CMS SSMP Plan 

§ 63.8(c)(3) Verification of operational status CMS PET Plan 

§ 63.8(c)(7)(ii) 

Out-of-control CMS data will not be used in averages 

and calculations. 

Section 4.0 

§ 63.8(c)(7)(h) Corrective actions for an out-of-control CMS 

Section 4.0 and 

SSMP Plan 

§ 63.8(c)(8) Out-of-control CMS information to be submitted Section 4.0 

§ 63.8(d)(2) Develop and implement QC portion of CMS QA 

program 

Section 1.0 

§ 63.8(d)(2) QA program includes the development and submittal of 

the performance evaluation test plan 

Section 2.1.1 

§ 63.8(d)(2)(f) Develop written procedures for initial and subsequent 

calibrations 

Sections 2.1.1, 

2.1.2 

§ 63.8(d)(2)(h) Develop written procedures for determination and 

adjustment of calibration drifts 

Section 2.2 

§ 63.8(d)(2)(iii) 

Develop written procedures for preventive maintenance 

and spare parts inventory 

Section 2.3 

§ 63.8(d)(2)(iv) Data recording, calculations, and reporting Sections 3.1, 3.2 

§ 63.8(d)(2)(vi) Corrective actions for malfunctioning CMS Section 4.0 

§ 63.8(e)(3) Performance evaluation of CMS CMS PET Plan 

§ 63.8(g) Reduction of monitoring data Section 3.2 

§ 63.10(b)(1) Maintaining files Section 3.1 

§63.10(b)(2)(ix) Maintain records of measurements from performance 

evaluations 

Section 3.1 

§ 63.10(b)(2)(vi) 

Maintain records of each period during which a CMS is 

malfunctioning, or inoperative and out of control 

Section 4.0 and 

SSMP Plan 

§63.10(b)(2)(vii) 

Maintain records of measurements to demonstrate 

compliance 

Section 3.1 

§ 63.10(b)(2)(viii) 

Maintain records of results of CMS performance 

evaluations and opacity and visible emission 

observations 

Section 3.1 

§63.10(b)(2)(x) Maintain records of CMS calibration checks Section 2.1.2 

2 
Table 1-1 (continued) 

Regulatory Checklist for the CMS QA Program 

Regulatory 

Citation 

Description Plan Section 

§63.10(b)(2)(xi) 

Maintain records of all adjustments and maintenance 

performed on the CMS Section 3.1 

§ 63.10(c)(1) 

Recordkeeping requirements for CMS measurements 

(including unavoidable breakdowns and out-of-control 

situations) 

Section 3.1 

§63.10(c)(13) Maintain records of total process operating time during 

the reporting period Section 3.1 

§63.10(c)(14) Develop and implement CMS QA program procedures Section 1.0 

§ 63.10(c)(5) Maintain records of date and time for CMS § 63.10(c)(5) Section 3.1 inoperability (except for zero and high-level checks) 

Section 3.1 

§ 63.10(c)(6) Maintain records of date and time for CMS out-ofcontrol periods 

Section 3.1 

Maintain records of identification of each time period 

§ 63.10(c)(8) of exceedances - does not include periods of Startup, 

Shutdown, Malfunction (SSM) 

Section 3.1 

§63.10(e)(3)(i) Submittal of semiannual excess emissions and CMS §63.10(e)(3)(i) Section 3.1 performance report 

Section 3.1 

§63.10(e)(3)(v) 

Content and submittal data of excess emissions and 

CMS performance report 

Section 3.2 

§63.10(e)(3)(vi) 

Content of summary report required by (e)(3)(vii) and 

(e)(3)(viii) to this section 

Section 3.2 

§63.10(e)(3)(vii) Condition for submitting only the summary report Section 3.2 

§63.10(e)(3)(viii) 

Condition for submitting both the summary report and 

excess emissions and CMS performance report 

Section 3.2 

§ 63.1209(b)(2)(i) Calibration of thermocouples and pyrometers Section 2.1 

§ 63.1209(b)(3) 

Frequency of CMS sampling, evaluation, computing, 

and recording of regulated parameter 

Section 3.1 

§ 63.1209(b)(5) Calculation of rolling averages Section 3.1 

§ 63.1209(f)(1) 

§ 63.1211(c) requires that CMS are installed, 

calibrated, and operational by the compliance date 

CMS PET Plan 

Notes: 

PET Performance Evaluation Test 

SSMP Startup, Shutdown, Malfunction Plan 

SDP Standard Division Practices 

3 
The data collected from CMS instrumentation is used to demonstrate the unit's 

compliance with the performance requirements promulgated in the Interim HWC 

Maximum Achievable Control Technology (MACT) standard. The QA Program outlines 

procedures used to verify that the CMS are properly calibrated and collecting accurate 

data on an ongoing basis. 

Due to the similarity of the three CMS systems (one for each incinerator system), general 

references to a CMS system or incinerator system in this document will imply all three 

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

clearly identified. 

This document is organized as follows: 

Section 1.0 Introduction and Background 

Section 2.0 CMS Calibration and Preventive Maintenance 

Section 3.0 CMS Recordkeeping and Reporting 

Section 4.0 CMS Corrective Actions 

This plan also assimilates information and procedures found in other documents. As 

required by § 63.6(e)(3)(vi), other documents containing procedures or information 

referred to in this plan will be made available for inspection when requested by the 

Administrator. 

The remainder of this section provides an overview of the incineration system followed 

by a discussion on the CMS instrumentation. Section 2.0 discusses CMS initial and 

continuing calibration and preventive maintenance requirements. Section 3.0 addresses 

requirements related to facility documentation and reporting. Section 4.0 defines and 

discusses nonstandard operations of the CMS and applicable corrective actions. 

1.1 Summary of Facility Information 

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

incinerator are presented in this section. 

1.1.1 Fixed Hearth Incinerators 

Each of the fixed hearth incinerators includes the following components: 

• Feed equipment 

4 
• Primary and secondary combustion chambers 

• Lime injection system 

• Spray dryer absorber (SDA) 

• Fabric filter baghouse 

• Solids and ash removal systems 

• Induced draft (ID) fan and stack 

• Instrumentation, controls, and data acquisition systems 

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

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

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

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

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

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

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

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

combustion chamber. Combustion chamber temperatures are maintained using natural 

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

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

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

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

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

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

Hot, wet gas is extracted downstream of the baghouse through a continuous emissions 

monitoring system. This system features a multi-component infrared gas analyzer that 

detects hydrogen chloride, carbon monoxide, and water vapor concentrations. An 

integrated zirconium oxide-based analyzer detects oxygen concentrations. 

1.1.2 Rotary Kiln Incinerator 

The rotary kiln incinerator includes the following components: 

• Waste feed system 

• Primary and secondary combustion chambers 

• Tempering chamber 

• Lime injection system 

• Spray dryer absorber 

5 
• Carbon injection system 

• Fabric filter baghouse 

• Solids and ash removal systems 

• ID fan and stack 

• Instrumentation, controls, and data acquisition systems 

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

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

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

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

atomized liquid injectors. Combustion chamber temperatures are maintained using 

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

Combustion gas exits the secondary combustion chamber and enters the tempering 

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

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

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

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

the combustion gas immediately downstream of the convergence of combustion gases 

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

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

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

the main stack. 

Hot, wet gas is extracted downstream of the ID fan through a continuous emissions 

monitoring system. This system features a multi-component infrared gas analyzer that 

detects hydrogen chloride, carbon monoxide, and water vapor concentrations. An 

integrated zirconium oxide-based analyzer detects oxygen concentrations. 

1.2 CMS Instrumentation 

This section describes the CMS instruments used monitor regulated process parameters 

for demonstrating on-going compliance with the Interim HWC MACT emission 

standards. A summary of specifications for CMS instrumentation is provided in Table 

1-2. 

The Interim HWC MACT standard requires all CMS's be installed in locations that 

provide representative measurements of emissions or process parameters. All CMS 

6 
Table 1-2 

CMS Instrument Specifications 

Application Instrument Tag Number Manufacturer Model Operating Range Location 

Unit No. 2 

High BTU Liquid Feedrate Mass Flowmeter FT-215 Micro Motion D 40S-SS 0-3,600 lb/hr Feed Line 

High BTU Liquid Direct Injection 

Feedrate 

Scale WT-215DI Weigh-Tronix WI-.130 0-60,000 lb Feed Line 

Low BTU Liquid Feedrate Mass Flowmeter FT-216 Micro Motion D 40S-SS 0-3,600 lb/hr Feed Line 

Low BTU Liquid Direct Injection 

Feedrate 

Scale WT-215DI Weigh-Tronix WI-.130 0-60,000 lb Feed Line 

Specialty Feed Weight Weigh Scale WT-204 Toledo 8140 EXP 0-4,000 lb # 204 Specialty 

Feeder 

Drummed Solids Feed Weight Weigh Scale WT-210 Toledo A140 0-400 lb Solid Charge 

Conveyor 

Cylinder Gas Feedrate dP Cell FT-217 Yokogawa YA11F 0-10 in. w.c. 

(0-60 lb/min) 

Cylinder Gas 

Feed System 

PCC Temperature 

TypeK 

Thermocouple 

TT-200A/B Modicon B883-200 0-2500 °F Primary 

Chamber 

SCC Temperature 

TypeK 

Thermocouple 

TT-219A/B Modicon B883-200 0-2500 °F Secondary 

Chamber 

PCC Pressure 

Pressure 

Transmitter 

PT-200 Rosemont 1151DP -7.5 to 2.5 in. w.c. 

Primary 

Chamber 

ESV Position Position Switch ZS-224 Square-D 9007 CG2B2 open/close 

Emergency 

Stack 

Baghouse Inlet Temperature 

Type K 

Thermocouple 

TT-270 Modicon 833-200 0-2500 °F SDA Outlet 

Combustion Gas Flow Rate dPCell FT-283 Rosemount 1151DR 0-20,000 acfm Stack 

Stack Gas Oxygen Concentration 

Zirconium Oxide 

Analyzer 

AT-289 COSA ZFN-11YA1-2Z1 0-25% CEMS 

Building 

Stack Gas Carbon Monoxide 

Concentration Multicomponent 

Infrared 

Photometer 

AT-288E EcoChem MC3 

0-200 / 0-3000 ppmv 

CEMS 

Building Stack Hydrogen Chloride 

Concentration 

Multicomponent 

Infrared 

Photometer 

AT-288E EcoChem MC3 

0-1000 ppmv 

CEMS 

Building 

Stack Gas Moisture Concentration 

Multicomponent 

Infrared 

Photometer 

AT-288E EcoChem MC3 

0-60% 

CEMS 

Building 

Lime Slurry Flow Rate Mag. Flowmeter FT-288 Fischer & Porter 10D1475 0-10 GPM SDA Penthouse 

Lime Slurry Density 

Density 

Transducer 

AT-968 Solartron Mobrey 7846 0-100 Lb/Ft3 SDA Penthouse 

7 
Table 1-2 (continued) 

CMS Instrument Specifications 

Application Instrument Tag Number Manufacturer Model Operating Range Location 

Unit No. 3 

High BTU Liquid Feedrate Mass Flowmeter FT-315 Micro Motion DS-040 0-3,600 lb/hr Feed Line 

High BTU Liquid Direct Injection 

Feedrate 

Scale WT-315DI Weigh-Tronix WI-130 0-60,000 lb Feed Line 

Low BTU Liquid Feedrate Mass Flowmeter FT-316 Micro Motion DS-040 0-3,600 lb/hr Feed Line 

Low BTU Liquid Direct Injection 

Feedrate 

Scale WT-315DI Weigh-Tronix WI-130 0-60,000 lb Feed Line 

Specialty Feed Weight Weigh Scale WT-304 Toledo AI40EXP 0-2,000 lb #304 Hooded 

Feeder 

Drummed Solids Feed Weight Weigh Scale WT-310 Toledo A140 0-400 lb Solid Charge 

Conveyor 

PCC Temperature 

Type K 

Thermocouple 

TT-300A/B Modicon 883-200 0-2500 °F Primary 

Chamber 

SCC Temperature 

TypeK 

Thermocouple 

TT-319A/B Modicon 883-200 0-2500 °F Secondary 

Chamber 

PCC Pressure 

Pressure 

Transmitter 

PT-300 Rosemount 1151 dP -7.5 to 2.5 in. w.c. Feed Line 

TRV Position Position Switch ZS-324 Square-D 9007 CG2B2 open/close 

Emergency 

Stack 

Baghouse Inlet Temperature 

TypeK 

Thermocouple 

TT-370 Modicon 833-200 0-2500 °F SDA Outlet 

Combustion Gas Flow Rate dPCell FT-383 Rosemount 1151 DR 0-20,000 acfm Stack 

Stack Gas Oxygen Concentration 

Zirconium Oxide 

Analyzer 

AT-389 COSA ZFN-11YA1-2Z1 0-25% CEMS 

Building 

Stack Gas Carbon Monoxide 

Concentration Multicomponent 

Infrared 

Photometer 

AT-388E EcoChem MC3 

0-200 / 0-3000 

ppmv 

CEMS 

Building Stack Hydrogen Chloride 

Concentration 

Multicomponent 

Infrared 

Photometer 

AT-388E EcoChem MC3 

0-1000 ppmv 

CEMS 

Building 

Stack Gas Moisture Concentration 

Multicomponent 

Infrared 

Photometer 

AT-388E EcoChem MC3 

0-60% 

CEMS 

Building 

Lime Slurry Flow Rate Mag. Flowmeter FT-388 Fischer & Porter 10D1475 0-10 GPM SDA Penthouse 

Lime Slurry Density 

Density 

Transducer 

AT-969 Solartron Mobrey 7846 0 - 100 Lb/Ft3 SDA Penthouse 

8 
Table 1 (continued) 

CMS Instrument Specifications 

Application Instrument Tag Number Manufacturer Model Operating Range Location 

Unit No. 4 

Waste Feedrate to X-10 Nozzle Mass Flowmeter FT-129 Micro Motion DS100S 128 0-7,000 lb/hr Feed Line 

Waste Feedrate to X- l 1 Nozzle Mass Flowmeter FT-138 Micro Motion D100S-HY 0-6,000 lb/hr Feed Line 

Waste Feedrate to X-l2 Nozzle Mass Flowmeter FT-145 Micro Motion DL100S-SS 0-8,000 lb/hr Feed Line 

Waste Feedrate to X-22 Nozzle Mass Flowmeter FT-212 Micro Motion D1D00S-SS 0-7,000 lb/hr Feed Line 

Clam Shell Feed Weight 

(shredded solids) Load Cell WT-001 Toledo 8140 0-2,000 lb Ram Feed 

Hopper 

Drum Conveyor Solids Weight Load Cell WT-014A Toledo 8140 0-1,000 lb Drum 

Conveyor 

Auxiliary Conveyor Solids 

Weight Load Cell WT-14B Toledo 8140 0-200 lb Auxiliary 

Conveyor 

PCC Temperature Pyrometer TT-305A/B Ircon 

Modline4 44-99-F1-0-1 0-3,000 °F Kiln Outlet 

SCC Temperature 

TypeR 

Thermocouple 

TT-317A/B Chessel 3510 0-3,000 °F SCC Outlet 

PCC Pressure 

Pressure 

Transmitter 

PT-300 Rosemount 1151DR2F -9.0 to 1.0 in. w.c. Kiln Hood 

Surge Vent Position Position Switch ZSC-026 Square-D 9007 CG2B2 open/close Kiln Face 

TRV Position Position Switch ZSC-316 Square-D 9007 CG2B2 open/close 

Emergency 

Stack 

Carbon Feedrate Feeder C-17 K-Tron K2T35 0-100 Carbon Inject. 

System 

Carbon Injection Carrier Gas 

Supply Pressure 

Pressure Switch PSL-438A Dwyer 3330 Trip Points: 

± 5 in. w.c. 

Carbon 

Injection Line 

Carbon Feeder Discharge Pressure Pressure Switch PSH-438B Dwyer 3215 

Trip Points: 

< 3 psig 

> 13 psig 

Carbon 

Injection Line 

9 
Table 1 (continued) 

CMS Instrument Specifications 

Application Instrument Tag Number Manufacturer Model Operating Range Location 

Unit No. 4 (continued) 

SDA X-l8 Outlet Temperature 

(Baghouse Inlet Temperature) 

TypeK 

Thermocouple 

TT-417A/B Modicon B883-200 0-2,500 °F SDA X- l 8 

Outlet 

SDA X-l9 Outlet Temperature 

(Baghouse Inlet Temperature) 

TypeK 

Thermocouple 

TT-418A/B Modicon B883-200 0-2,500 °F SDA X-l9 

Outlet 

Combustion Gas Flowrate Pitot Tube/dP Cell FT-559A/B Automation Service 1151DRF2283 0-55,000 acfm Stack 

Stack Gas Oxygen Concentration 

Zirconium Oxide 

Analyzer 

AT-560A/B COSA ZFN-11YA1-2Z1 0-20% CEMS 

Building 

Stack Gas Carbon Monoxide 

Concentration 

Multicomponent 

Infrared 

Photometer 

AT-556E EcoChem MC3 

0-200 / 0-3000 ppmv 

CEMS 

Building 

Stack Hydrogen Chloride 

Concentration 

Multicomponent 

Infrared 

Photometer 

AT-556E EcoChem MC3 0-1000 ppmv 

CEMS 

Building 

Stack Gas Moisture Concentration 

Multicomponent 

Infrared 

Photometer 

AT-556E EcoChem MC3 

0-60% 

CEMS 

Building 

Lime Slurry Flow Rate Mag. Flowmeter FT-615 Fischer & Porter 10D1475 0-80 GPM SDA Nozzles 

Lime Slurry Density 

Density 

Transducer 

DIT-609 Solartron Mobrey 7846 0 - 100 Lb/Ft3 Lime Silo 

10 
operating parameter measurement devices at the Veolia facility are installed in compliance with 

this requirement. A description of the types of CMS instrumentation follows: 

Mass/Feedrate Monitors: Liquid waste feedrates from tanks are measured by coriolis mass 

flowmeters. Direct inject liquid feedrates from tanker truck are calculated using the continuously 

monitored weight of the tanker. Al l solid waste charges are weighed using a scale/load cell prior 

to being feed to the incinerator. These measurements are used to calculate pumpable waste, total 

waste, and constituent feedrates. 

For Unit 4, the output of a calibrated feeder is utilized to calculate the feedrate of powdered 

activated carbon, which is injected into the plenum upstream of the baghouses. 

Pressure/Differential Pressure Monitors: Primary combustion chamber pressure is measured 

by diaphragm actuated pressure transmitters. The position of the damper immediately upstream 

of the ID fan is varied to control stack gas flowrate and to maintain kiln combustion chamber 

negative pressure (draft). The primary combustion chamber pressure is interlocked with waste 

feeds. 

For Unit 2, pressure drop in the cylinder gas feedstream is measured and converted to a feedrate. 

The feedrate is used to calculate this feedstream's contribution to the chlorine, low volatile 

metals, and semivolatile metals feedrates to the incinerator. 

For Unit 4, pressure switches are utilized to ensure that the carbon feeder discharge pressure, and 

the carbon injection air blower discharge pressure are within the design limits. 

The pressure drop across a pitot tube in the stack is continuously monitored and used to calculate 

the stack gas flowrate. 

Temperature Monitors: For Units 2 and 3, redundant thermocouples are used to measure the 

temperature in both combustion chambers. A thermocouple is also located at the exit to the SDA 

and is the primary element for the SDA exit temperature control loop. 

Unit 4 is equipped with redundant pyrometers in the primary chamber and redundant 

thermocouples in the secondary chamber. Each SDA outlet is equipped with redundant 

thermocouples used for temperature control and monitoring of the baghouse inlet temperature. 

11 
Emergency Safety Vent Position Monitors: The position of the emergency safety vent (ESV) 

is indicated as open or closed by a position transmitter. No waste or fuel can be fed if the ESV 

position is "open". The Emergency Safety Vent (ESV) Plan provides details on the ESV 

systems. 

Bag Leak Detection System: A triboelectric sensor is located downstream of the ID fan and 

monitors the relative particulate matter loading of the combustion gas exiting the baghouses. 

Alarms and interlocks based on this relative measurement are indications of a potential bag leak 

or failure. Procedures for setup and adjustments to the bag leak detection system are not covered 

by this QC program. The Operation and Maintenance Plan provides details on the bag leak 

detection system. 

Continuous Emissions Monitoring System: The CEMS continuously samples and analyzes 

stack gas for the concentrations of carbon monoxide (CO), Hydrogen Chloride (HCl), and 

moisture using a multicomponent infrared photometer. The oxygen concentration is analyzed 

simultaneously using a zirconium oxide analyzer. These data are used to calculate the stack gas 

CO concentration on a dry basis, corrected to 7% 02. The CEMS QA Plan provides additional 

details on the CEMS. 

12 
2.0 CMS CALIBRATION AND PREVENTIVE MAINTENANCE 

This section discusses the calibration and preventive maintenance requirements to meet the 

requirements of § 63.8(d). 

2.1 CMS Calibration 

To ensure ongoing compliance with the Interim HWC MACT standard, it is essential that the 

data collected from the CMS be measured and recorded in an accurate manner. Initial 

calibrations, subsequent calibration, and CEMS calibrations are described in this section. 

2.1.1 Initial CMS Calibration 

As part of Veolia's Quality Control Program, the CMS instruments were initially calibrated prior 

to the Interim HWC MACT compliance date. Calibration prior to the compliance date is 

required so that all collected data are reliable and accurate. Al l initial calibration data are part of 

the operating record. Initial calibrations of new/replacement instruments will be performed per 

the manufacture's written procedures. In lieu of an initial calibration for new/replacement 

instruments or instrument components, the facility may use a manufacturer's certification. 

2.1.2 Subsequent CMS Calibration 

Subsequent calibrations on CMS instrumentation will be performed as needed and in accordance 

with the manufacture's written procedures. Calibrations will be performed as corrective 

measures for high calibration drift. Calibrations may be required when restoring CMS 

instruments after maintenance or repairs. Al l calibration adjustments will be documented by 

records of the calibration drift determined before and after the instrument was serviced. 

Some instruments such as differential pressure cells must be removed from service and bench 

calibrated. To minimize downtime these instruments may be replaced with a calibrated spare. 

The Unit 4 primary combustion chamber pyrometers will be replaced at least annually with a 

factory calibrated pyrometer. Electronic checks and replacements of thermocouples will be 

performed per the facility's Thermocouple Calibration, Operation, and Replacement Procedure. 

A calibration record form is available for each CMS instrument and will be used to document 

calibration audits, calibrations, and replacements. The most recently completed calibration 

record documents that the instrument in service meets the quality control criteria set forth by this 

program. These calibration records contain "calibration notes" which provide the instrument 

technician with procedures specific to a given instrument. The calibration record forms for CMS 

instruments are incorporated in this QC Program by reference. 

13 
2.1.3 CEMS Calibration Audits and Calibration 

CEMS QA/QC procedures are provided by the Continuous Emission Monitoring System Quality 

Assurance Plan. These procedures are maintained at the facility and describe the requirements 

for CEMS drift checks, audits, calibrations, preventive maintenance, and recordkeeping. 

2.2 CMS Calibration Audits 

C MS calibration audits are performed to determine the calibration drift (CD) of CMS 

instruments. Calibration Drift (CD) is the bias between the CMS instrument reading and a 

calibration reference. Table 2-1 presents the requirements for CMS calibration audits. Each 

C MS instrument will be subjected a calibration audit at the frequency indicated in Table 2-1. 

The calibration audit will be performed at the low-level (zero) and high-level checks indicated. 

The calibration check will confirm that all process variable indications (e.g., local reading, 

control room display) at the high-level value agree with the calibration reference within Vi of the 

required tolerance. Calibration adjustments/corrective actions must be taken if this calibration 

drift is greater than Vi of the required tolerance. If the calibration drift exceeds the required 

tolerance, the instrument is considered out-of-control. Section 4.0 describes the corrective 

actions for out-of-control, inoperative, and malfunctioning CMS. 

If the accuracy of a CMS instrument is in question, the CD is determined and documented prior 

to performing maintenance, repairs, or adjustments. The troubleshooting/calibrations of CMS 

instruments will be performed in a manner consistent with the manufacturer's written procedures 

and recommendations. The CD determined after calibrations/corrective actions have been taken 

will document the effects of the adjustments and demonstrate that the instrument is performing 

properly. 

Calibration records will document CD, which is an indicator of the stability of the CMS 

calibration over time. The amount of drift and stability is dependant on the type of instrument 

and the calibration frequency. Veolia may increase or decrease the frequency of particular 

calibration audits to the extent warranted by an assessment of an instrument's stability. Veolia 

will maintain regularly scheduled calibration audit intervals for each CMS instrument. 

Calibrations will be performed to prevent excessive CD and to maintain the validity of the data 

collected from the monitoring system. 

14 
T V .2-1 

CMS Calibration Audit Requirements 

Application Instrument Tag Number 

Frequency of 

Calibration Audit 

Low Level Check 

Point 

High Level Check 

Point Tolerance 

Unit No. 2 

High BTU Liquid Feedrate Mass Flowmeter FT-215 Annually 0-5 lb/min 15-25 lb/min 10% 

High BTU Liquid Direct Injection 

Feedrate 

Scale WT-215DI Quarterly 01b 25,000 lb 10% 

Low BTU Liquid Feedrate Mass Flowmeter FT-216 Annually 0-5 lb/min 15-25 lb/min 10% 

Low BTU Liquid Direct Injection 

Feedrate 

Scale WT-215DI Quarterly 01b 25,000 lb 10% 

Specialty Feed Weight Weigh Scale WT-204 Quarterly 01b -500 lb 10% 

Drummed Solids Feed Weight Weigh Scale WT-210 Quarterly 01b -50 lb 10% 

Cylinder Gas Feedrate dP Cell FT-217 Annually 0 in. w.c. 10 in. w.c. 10% 

Primary Combustion Chamber 

Temperature 

TypeK 

Thermocouple 

TT-200A/B Refer to the Thermocouple Calibration, Operation, and Replacement Procedure 

Secondary Combustion Chamber 

Temperature 

TypeK 

Thermocouple 

TT-219A/B Refer to the Thermocouple Calibration, Operation, and Replacement Procedure 

Primary Combustion Chamber 

Pressure 

Pressure 

Transmitter 

PT-200 Quarterly -7.5 to -6.5 1.5 to 2.5 in w.c. 10% 

ESV Position Position Switch ZS-224 Annually AWFCO interlock energized when open Pass 

Baghouse Inlet Temperature 

Type K 

Thermocouple 

TT-270 See Calibration Record Form 

Combustion Gas Flow Rate dP Cell FT-283 Annually 0-0.05 in. w.c. 0.45-0.50 in. w.c. 10% 

Lime Slurry Flow Rate Mag. Flowmeter FT-288 Annually 0 gpm 1-10 gpm 10% 

Lime Slurry Density 

Density 

Transducer 

AT-968 Replace, as required, with factory serviced transducer 

Stack Gas Oxygen Concentration 

Zirconium Oxide 

Analyzer 

AT-289 Per CEMS QAPlan 

Stack Gas Carbon Monoxide 

Concentration Multicomponent 

Infrared 

Photometer 

Stack Hydrogen Chloride AT-288E Per CEMS QAPlan 

Concentration 

Multicomponent 

Infrared 

Photometer 

AT-288E Per CEMS QAPlan 

Stack Gas Moisture Concentration 

Multicomponent 

Infrared 

Photometer 

AT-288E Per CEMS QAPlan 

15 
Table 2-1 (continued) 

CMS Calibration Audit Requirements 

Application Instrument Tag Number 

Frequency of 

Calibration Audit 

Low Level Check 

Point 

High Level Check 

Point Tolerance 

Unit No. 3 

High BTU Liquid Feedrate Mass Flowmeter FT-315 Annually 0-5 lb/min 15-25 lb/min 10% 

High BTU Liquid Direct Injection 

Feedrate 

Scale WT-315DI Annually 01b 25,000 lb 10% 

Low BTU Liquid Feedrate Mass Flowmeter FT-316 Annually 0-5 lb/hr 15-25 lb/min 10% 

Low BTU Liquid Direct Injection 

Feedrate 

Scale WT-315DI Annually 01b 25,000 lb 10% 

Specialty Feed Weight Weigh Scale WT-304 Quarterly 01b -200 lb 10% 

Drummed Solids Feed Weight Weigh Scale WT-310 Quarterly 01b -50 lb 10% 

Primary Combustion Chamber 

Temperature 

TypeK 

Thermocouple 

TT-300A/B Refer to the Thermocouple Calibration, Operation, and Replacement Procedure 

Secondary Combustion Chamber 

Temperature 

TypeK 

Thermocouple 

TT-319A/B Refer to the Thermocouple Calibration, Operation, and Replacement Procedure 

Primary Combustion Chamber 

Pressure 

Pressure 

Transmitter 

PT-300 Quarterly -7.5 to -6.5 1.5 to 2.5 in w.c. 10% 

ESV Position Position Switch ZS-324 Annually AWFCO interlock energized when open Pass 

Baghouse Inlet Temperature 

Type K 

Thermocouple 

TT-370 Refer to the Thermocouple Calibration, Operation, and Replacement Procedure 

Combustion Gas Flow Rate dP Cell FT-383 Annually 0-0.05 in. w.c. 0.45-0.50 in. w.c. 10% 

Lime Slurry Flow Rate Mag. Flowmeter FT-388 Annually 0 gpm 1-10 gpm 10% 

Lime Slurry Density 

Density 

Transducer 

AT-969 Replace, as required, with factory serviced transducer 

Stack Gas Oxygen Concentration 

Zirconium Oxide 

Analyzer 

AT-389 Per CEMS QAPlan 

Stack Gas Carbon Monoxide 

Concentration Multicomponent 

Infrared 

Photometer 

Stack Hydrogen Chloride AT-388E Per CEMS QA Plan 

Concentration 

Multicomponent 

Infrared 

Photometer 

AT-388E Per CEMS QA Plan 

Stack Gas Moisture Concentration 

Multicomponent 

Infrared 

Photometer 

AT-388E Per CEMS QA Plan 

16 
Table 2-_ continued) 

CMS Calibration Audit Requirements 

Application Instrument Tag Number 

Frequency of Drift 

Check/Accuracy 

Audit 

Low Level Check 

Point 

High Level Check 

Point Tolerance 

Unit No. 4 

Waste Feedrate to X-l0 Nozzle Mass Flowmeter FT-129 Annually 0-5 lb/min 15-25 lb/min 10% 

Waste Feedrate to X- l 1 Nozzle Mass Flowmeter FT-138 Annually 01b 21,000 lb 10% 

Waste Feedrate to X-l2 Nozzle Mass Flowmeter FT-145 Annually 0-5 lb/min 15-25 lb/min 10% 

Waste Feedrate to X-22 Nozzle Mass Flowmeter FT-212 Annually 01b 21,000 lb 10% 

Clam Shell Feed Weight 

(shredded solids) Load Cell WT-001 Quarterly 01b -200 lb 10% 

Drum Conveyor Solids Weight Load Cell WT-014A Quarterly 01b -100 lb 10% 

Auxiliary Conveyor Solids 

Weight Load Cell WT-14B Quarterly 01b -50 lb 10% 

Primary Combustion Chamber 

Temperature 

Pyrometer TT-305A/B Replace at least annually with factory calibrated Pyrometer 

Secondary Combustion Chamber 

Temperature 

Type R 

Thermocouple 

TT-317A/B Refer to the Thermocouple Calibration, Operation, and Replacement Procedure 

Primary Combustion Chamber 

Pressure 

Pressure 

Transmitter 

PT-300 Quarterly -9.0 to -8.0 in. w.c. 0 to 1.0 in. w.c. 10% 

Surge Vent Position Position Switch ZS-026 Annually AWFCO interlock energized when open Pass 

ESV Position Position Switch ZS-324 Annually AWFCO interlock energized when open Pass 

Carbon Feedrate Feeder WT-438 Quarterly 0 lb/min 6-30 lb/min 10% 

Carbon Injection Carrier Gas Low 

Pressure 

Pressure Switch PSL-438A Annually Energize Switch Pass 

Carbon Injection Carrier Gas 

High Pressure 

Pressure Switch PSH-438B Annually Energize Switch Pass 

17 
Table 2-1 (continued) 

CMS Calibration Audit Requirements 

Application Instrument Tag Number 

Frequency of Drift 

Check/Accuracy 

Audit 

Low Level Check 

Point 

High Level Check 

Point Tolerance 

Unit No. 4 (continued) 

SDA X- l 8 Outlet Temperature 

(Baghouse Inlet Temperature) 

TypeK 

Thermocouple 

TT-417A/B Refer to the Thermocouple Calibration, Operation, and Replacement Procedure 

SDA X-l9 Outlet Temperature 

(Baghouse Inlet Temperature) 

TypeK 

Thermocouple 

TT-418A/B Refer to the Thermocouple Calibration, Operation, and Replacement Procedure 

Combustion Gas Flowrate Pitot Tube/dP Cell FT-559A/B Annually 0 in. w.c. 1.74 in w.c. 10% 

Lime Slurry Flow Rate Mag. Flowmeter FT-615 Annually 0 gpm 1-10 gpm 10% 

Lime Slurry Density Density Transducer DIT-609 Replace, as required, with factory serviced transducer 

Stack Gas Oxygen 

Concentration 

Zirconium Oxide 

Analyzer 

AT-560A/B Per CEMS QA Plan 

Stack Gas Carbon Monoxide 

Concentration 

Multicomponent 

Infrared Photometer 

AT-556E Per CEMS QAPlan 

Stack Hydrogen Chloride 

Concentration 

Multicomponent 

Infrared Photometer 

AT-556E Per CEMS QAPlan 

Stack Gas Moisture 

Concentration 

Multicomponent 

Infrared Photometer 

AT-556E Per CEMS QAPlan 

18 
2.3 Preventive Maintenance 

Veolia takes daily proactive measures to assure that potential problems with the CMS are quickly 

identified and avoided, if possible. Daily maintenance checks include: 

• Verification that process variables are reasonable 

• Comparison of readings from redundant instruments 

• Cleaning and visual check of monitoring equipment 

• Communication between operators and instrument technicians 

These checks are documented on a daily logsheet for each incinerator. The preventive 

maintenance on the CMS also includes the calibration audits previously described. Al l necessary 

parts for routine repairs of the affected CMS equipment are made readily available onsite. A 

spare parts inventory for each component of the CMS is included in the records maintained by 

the Maintenance Department. Additional details regarding preventive maintenance applicable to 

the CMS are provided in the facility's Operation and Maintenance Plan and the CEMS QA Plan. 

19 
3.0 CMS RECORDKEEPING AND REPORTING 

This section discusses recordkeeping and reporting requirements for CMS 

instrumentation as specified by § 63.1211. 

3.1 Recordkeeping 

Veolia will follow the recordkeeping requirements as specified in § 63.10(b), including 

the semiannual excess emissions and CMS performance report. Veolia will maintain 

these records of CMS data for a minimum of 5 years following the date of each 

occurrence, measurement, maintenance, corrective action, report, or record. At a 

minimum, the most recent 2 years of data will be retained onsite. Below is a brief 

summary of these requirements. 

Veolia will maintain records on the following: 

• The occurrence and duration of each startup, shutdown, or malfunction of 

operation. 

• The occurrence and duration of each malfunction of the air pollution control 

and monitoring equipment. Maintenance performed on the air pollution 

control and monitoring equipment 

• Actions taken during periods of startup, shutdown, and malfunction (including 

corrective actions to restore the process or air pollution control system to 

normal operation) when such actions are different the procedures outlined in 

the SSMP 

• Al l information necessary to demonstrate conformance with the SSMP 

• Each period in which a CMS is malfunctioning or inoperative (including outof-control periods) 

• Al l required measurements needed to demonstrate compliance with a relevant 

standard. 

• Al l results of performance tests, CMS performance evaluations, and opacity 

and visible emission observations 

• Al l CMS calibration checks 

• Al l adjustments and maintenance performed on CMS 

• Al l required CMS measurements (including data recorded during unavoidable 

CMS breakdowns and out-of-control periods) 

• The date and time identifying each period during which the CMS was 

inoperative except for zero (low level) and high level checks 

20 
• The date and time identifying each period during which the CMS was out-ofcontrol as defined by § 63.8(c)(7) 

• The specific identification (date and time of commencement and completion) 

of each period of excess emissions and parameter monitoring exceedances, as 

defined in the relevant standard, that occurs during periods other than startup, 

shutdowns, and malfunctions. 

• The nature and cause of any malfunction 

• The corrective action taken or preventive measures adopted 

• The nature of the repairs or adjustments to the CMS that was inoperative or 

out-of-control 

• The total process operating time during the reporting period 

• Al l procedures that are part of quality control program developed and 

implemented for CMS under § 63.8(d). 

A l l CMS instrumentation will be operated on a continuous basis. The detector response 

will be evaluated at least every 15 seconds, and these values will be used to calculate 

regulated parameters. For parameters interlocked with the AWFCO system on an hourly 

rolling average basis, raw data will be averaged and recorded at least once per minute. 

One minute averages will be used to calculate the hourly rolling averages. The pumpable 

waste, total waste, and constituent feedrate operating parameter limits are bases on rolling 

totals in lieu of rolling averages. 

An integral part of the CMS is the data acquisition and data historian systems, which 

records all operating data generated by the CMS instruments. The data historian and 

associated archive files are part of the operating record. CMS instrument calibrations, 

maintenance activities, and corrective actions are recorded and kept in the operating 

record. Al l data collected during CMS PETs are recorded and kept in the operating 

record. 

3.2 Reporting 

Veolia will follow the reporting requirements as specified in § 63.10. In addition, Veolia 

will develop and include in the operating record a Documentation of Compliance (DOC) 

per § 63.1211(c). The DOC must include a signed and dated certification that the CEMS 

and CMS are installed, calibrated, and continuously operating in compliance with the 

requirements of Subpart EEE. 

21 
Raw data from the CMS will be collected, reduced as described in § 63.8(g), and 

included in the CMS PET report. This data will be analyzed to determine compliance 

with the HWC MACT and the results will be submitted as part of the notification of 

compliance required by § 63.1207(j). 

The content and deadline requirements for the excess emissions and monitoring system 

performance reports are specified in § 63.10(e)(3)(v). The requirements for the summary 

report are given in § 63.10(e)(3)(vi). 

As noted in § 63.10(e)(3)(vii), Veolia is required to only submit the summary report if the 

total duration of excess emissions or process or control system parameter exceedances for 

the reporting period is less than one percent of the total operating time for the reporting 

period, and CMS downtime for the reporting period is less than five percent of the total 

operating time for the reporting period. Conversely, additional reporting is required by § 

63.10(e)(3)(viii) if the total duration of exceedances, or the total CMS downtime during 

the reporting period, is greater than the allowable percentage of the reporting period. 

Table 3-1 provides a list of Veolia's reporting requirements. 

22 
Table 3-1 Reporting Requirements 

Regulatory 

Citation 

Description Frequency 

§ 63.1211(c) Record Documentation of Compliance in the operating 

record Once 

§ 63.10(d)(2) Before Title V permit has been issued, owner operator 

must submit results of performance test. 

By the 60th day 

following every 

performance test 

§ 63.10(d)(2) After Title V permit has been issued, owner operator 

must submit results of required performance tests. 

By the 60th day 

following required 

performance test 

§ 63.10(d)(4) Progress reports 

As specified in written 

extension of 

compliance 

§ 63.10(d)(5)(i) Periodic startup, shutdown, and malfunction reports 

(during reporting period) 

Submitted 

simultaneous with 

excess emission report 

§63.10(d)(5)(ii) 

Startup, shutdown, and malfunction reports when 

actions are taken that are inconsistent with SSMP. 

2 working days from 

commencement of 

action, followed with a 

letter explaining extent 

within 7 working days. 

§ 63.10(e)(3)(i) Submittal of semiannual excess emissions and CMS 

performance report 

Semiannually - by the 

30th day following the 

end of each calendar 

half performance test 

23 
4.0 CMS CORRECTIVE ACTIONS 

If a CMS is found to be out-of-control, inoperative, or malfunctioning; corrective actions 

must be taken to return the CMS to normal operation. Definitions used in determining 

the type of corrective action required are given below. 

Out-of-control: A CMS is out-of-control if: 

• The zero (low level), mid-level, or high-level calibration drift exceeds two 

times the applicable CD specification in the applicable performance 

specification or procedure; or 

• The CMS fails a performance test audit, relative accuracy audit, relative 

accuracy test audit, or linearity test audit. 

The only applicable performance specification to the CMS is Performance Specification 

(PS) 4B of 40 CFR Part 63, Appendix B. PS 4B applies to the 0 2 and CO CEMS. The 

requirements of PS 4B and additional requirements Veolia imposes on the CEMS are 

detailed in the CEMS QA Plan. In the absence of promulgated performance specification 

applicable to non-CEMS CMS instruments, Veolia has self-imposed a high-level CD 

specification, as described in Section 2.0. 

When a CMS is out-of-control, Veolia will take the necessary corrective action and shall 

repeat all necessary tests which indicate that the system is out-of-control. Corrective 

actions and retesting will continue until the CMS is returned to normal operation. The 

beginning of the out-of-control period is the hour that the calibration drift indicates that 

the CMS has exceeded its performance specifications. The end of the out-of-control 

period is the hour following the completion of corrective action and successful 

demonstration that the CMS is within its allowable limits. During the period the CMS is 

out-of-control, recorded data shall not be used in data averages and calculations, or to 

meet any data availability requirement established under this part. 

Veolia will submit all information concerning out-of-control periods, including start and 

end dates and hours, and descriptions of corrective actions taken, in the excess emissions 

and continuous monitoring system performance report required by § 63.10(e)(3). 

Malfunction: For use in this plan, malfunction is defined as any sudden, infrequent, and 

not reasonably preventable failure of air pollution control or monitoring equipment. 

24 
Malfunction also includes the failure of a process or any process equipment to operate in 

a normal or usual manner. Failures that are caused in part by poor maintenance or 

careless operation are not malfunctions. 

The Program of Corrective Actions for Malfunctions is Attachment 4 of the SSMP Plan. 

This program addresses how the incinerator will be operated and maintained during 

malfunctions. In this program, potential malfunctions are listed for each portion of the 

incinerator system. The malfunctions are events that are recognized by the operator, or 

indicated by an alarm, and threaten to cause an exceedance. In the response to the 

malfunction and/or alarms, the operator will apply discretion and attempt to maintain the 

incinerator system within regulatory limits. In the program of corrective actions, 

potential causes of each malfunction are listed. The operator will utilize process 

knowledge, job experience, and, if needed, assistance from other personnel to identify the 

cause of the malfunction. For each potential cause, actions to correct the failure are 

listed. The corrective actions prescribed may require the collaboration of multidisciplined personnel who are qualified to return the incinerator system to proper working 

conditions (i.e., maintenance personnel, instrument technicians, engineering) 

25