May 23,2008 

Cheryl L. Newton, Acting Director 

Air and Radiation Division 

United States Environmental Protection Agency 

Region 5 

77 West Jackson Blvd. 

Chicago, IL 60604-3590 

RE: Veolia ES Technical Solutions, L.L.C. 

Metals Performance Test Plans for Incinerators 2,3 and 4 

Dear Ms. Newton, 

Pursuant to our agreement, attached is the Metals Performance Test Plan Prepared for 

the Fixed Hearth lncinerator Number 2 in Accordance with 40 CFR § 63 S~lbpart EEE, 

Metals Performance Test Plan Prepared for the Fixed Hearth lncinerator Number 3 in 

Accordance with 40 CFR § 63 Subpart EEE and Metals Perforniance Test Plan 

Prepared for the Rotary Kiln lncinerator Number 4 in Accordance with 40 CFR § 63 

Subpart EEE. Electronic copies of these plans have been sent to Mr. Charles Hall of 

your Agency on May 22. 

Please call me at (61 8) 271-2804, ext. 101 if you have any questions. 

Sincerely, 

Doug Harris 

General Manager 

#7 Mobile Avenue, Sauget, IL 62201 

(61 8) 271 -2804 

www.veoliaes.com 
Prepared for: 

Veolia ES Technical Solutions 

7 Mobile Avenue 

Sauget, IL 62201 

Metals Performance Test Plan Prepared 

for the Fixed Hearth Incinerator 

Number 2 in Accordance with 

40 CFR 5 63 Subpart EEE 

ElVSR Corporation 

May 2008 

Document No.: 10002-022 
Prepared for: 

Veolia ES Technical Solutions 

7 Mobile Avenue 

Sauget, IL 62201 

Metals Performance Test Plan Prepared 

for the Fixed Hearth Incinerator 

Number 2 in Accordance with 

40 CFR 5 63 Subpart EEE 

Reviewed By Craig Doolittle 

ENSR Corporation 

May 2008 

Document No.: 10002-022 
Veolia ES Technical Solutions MACT Performance Test Plan 

Revis~on: 0 

Date: May 2008 

Section: Table of Contents 

Page i of vi 

Contents 

1.0 Introduction ..........................................................................

1 . 1 Program Summary [40 CFR 3 63.1 207(f) and 5 63.7(c)(2)(i)] ........................................................... 1 

1 . 2 FacilityIUnit Identification .................................................................................................................... 1 

1.2.1 General ...................................................

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

1.2.3 Incinerator Overview ............ ............................................................................................ I 

1.3 Purpose and Objectives of the Performance Test ......................................................................... ..2 

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

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

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

2.1 Process Overview ............................ .. .......................................................................................... 1 

2.2 Waste Feed Systems [40 CFR § 63.1 207(f)(l)(ii)(c) and (f)(l )(iii)(D) and (E)] ................................. 1 

2.2.1 Unit 2 Liquid Waste Feed System and Blending Operations ............................................... 1 

2.3 Manufacturer. Make and Model of the Incinerator [40 CFR § 63.1207(f)(l)(iii)(A)] .......................... 2 

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

2.3.2 Secondary Combustion Chamber ......................................................................................... 3 

2.3.3 Location of Combustion Zone Temperature Device [40 CFR § 63.1207(f)(l)(xix)] ............ 3 

2.3.4 Hazardous Waste Residence Time [40 CFR 3 63.1207(f)(l)(ix)] ........................................ 3 

2.3.5 Combustion System Leak ............................. .. ............................................................... 4 

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

2.4 Procedures for Rapidly Stopping Hazardous Waste Feed During Equipment Malfunction 

[40 CFR §63.1207(f)(l)(viii)] .................................................................................... ........................ 4 

2.5 Air Pollution Control Equipment [40 CFR 563.1 207(f)(l )(iii)(G)] ....................................................... 4 

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

2.6 Stack Emissions Monitoring [40 CFR 563.1 207(f)(I)(iii)(H)] ................................................... .. ..... 6 

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

2.7 Process Monitoring and Control ................................. .................................................................... 7 

2.8 Automatic Waste Feed Cut-off System [40 CFR §63.1207(f)(l)(iii)(F)] ............................................ 8 

2.8.1 AWFCO System Testing ....................................................................................................... 8 

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

2.9.1 Program Overview ................................................................................................................. 9 

2.9.2 Test Program Preparation Activities ......................... ...................................................... 9 

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3.0 Incinerator Feed Stream Descriptions .................................................................................................... I

3.1 General .............................................................................................................................. ................. 1 

3.2 High volume wastes ............................................................................................................................ 1 

3.2.1 Liquid wastes ......................................................................................................................... 1 

3.2.2 Bulk solids .............................................................................................................................. 1 

3.2.3 Containerized Waste ............................................................................................................. 1 

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

3.3 Auxiliary fuels ................................................................................................................................... 2 

4.0 Performance Test Protocol ..............................................................

4.1 General Description ........................................................................................................................... I 

Performance Standards .................................................................................................................... 1 

Test Conditions [40 CFR 3 63.1207(fj(l)(vi) and (vii)] ....................................................................... 1

Waste Feed Spiking 

4.4.1 Inorganic Constituents ........................................................................................................... 2 

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

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

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

Metals Extrapolation Method ........................................................................................................... 3 

Description. Preparation and Delivery of Feeds for the Performance Test .. > [40 CFR § 63.1 207 (fj(1 )(vi) and (vrr)] ................................................. .......................................... 3 

Conditioning Time Needed to Reach Steady State [40 CFR 3 63.1 207(f)(l)(xii)] ............................ 3 

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

Performance Test Reporting ............................................................................................................. 4 

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

5.1 Title Page ........................................................................................................................................... 2 

5.1 . 1 Project Title ............................................................................................................................ 2 

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

5.1.3 Project Approvals ................................................................................................................. 2 

5.2 Table of Contents .......................... .. ................................................................................................. 3 

5.3 Project Description ............................................................................................................................ 3 

5.4 Project Organization ............................................................................................................................ 3 

5.4.1 QA Officer's Responsibilities ................................................................................................. 3 

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

5.5 QAJQC Program Objectives ................................................................................................................ 4 

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Section Table of Contents 

Veolia ES Technical Solutions MACT Pelforrnance Test Plan Page iii of vi 

5.5.1 Precision. Accuracy and Completeness ................................. .......................................... 4 

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

5.5.3 Method Detection Limit (MDL) Determinations .................................................................... 5 

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

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

5.6.2 Pre-Sampling Activities ........................................................................................................ 5 

5.6.3 Sampling Locations ............................................................................................................... 7 

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

5.6.5 Stack Sampling Methodologies ........................................................................................... 7 

5.7 Sample Handling. Traceability and Holding Times ........................... ............................................. 8 

5.8 Analytical Methods and Calibration Procedures .................... ...................................................... 9 

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

5.8.2 Analysis of Stack Gas Samples .......................................................................................... 9 

5.9 Internal QA Program ......................................................................................................................... 70 

5.9.1 Data Collection and Sampling QC Procedures ....................... ..................................... I0 

5.9.2 Analytical QC Procedures for Samples to be Analyzed in the Laboratory ........................ 11 

5.1 0 Data Reduction. Verification and Data Reporting ......................................................................... 1 

5.1 0.1 Field Data Reduction ........................................................................................................... 11 

5.1 0.2 Laboratory Analysis Data Reduction .................... .. ....................................................... 12 

5.1 0.3 Data Verification ................................................................................................................... 12 

5.1 0.4 Final Data Reporting ............................................................................................................ 13 

5.1 1 Routine Maintenance Procedures and Schedules ........................................................................... 13 

5.1 1 . 1 Field Sampling Equipment .................................................................................................. 14 

5.1 1.2 Facility Equipment and Instrumentation .............................................................................. 14 

5.1 2 QAIQC Assessment Procedures ..................................................................................................... 14 

5.12.1 Accuracy .............................................................................................................................. 14 . . 5.1 2.2 Prec~s~on ............................................................................................................................ 15 

5.1 2.3 Completeness ...................................................................................................................... I5 

5.1 3 External QA Program ......................... ........................................................................................... 15 

5.1 3.1 Petformance Audits ............................................................................................................. 16 

5.1 3.2 Corrective Action .................................................................................................................. 16 

5.1 3.3 Quality Assurance Reports to Management ....................................................................... 17 

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Section: Table of Contents 

Page iv of vi 

List of Appendices 

Appendix A Unit 2 Process Flow Diagram 

Appendix I3 Field Data Sample Collection Forms 

Appendix C lsokinetic Sampling Train Setup and Recovery Schematics 

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Section: Table of Contents 

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List of Tables 

Table 1-1 Summary of Applicable MACT Emission Standards ......................................................................... 3 

Table 1-2 Cross Reference of Performance Test Requirements ................................ .... .............................. 4 

Table 2-1 Unit 2 Continuous Emission Monitors ................................................................................................ 7 

Table 2-2 Technical Information Summary on Incinerator No . 2 ................................................................ I0 

Table 2-3 Current AWFCO Parameters and Limits for Incinerator No . 2 ....................... .. ......................... 1 

Table 3-1 Top Volume Liquid Waste Streams .............................................................................................. 3 

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

Table 3-3 Top Containerized Solid Waste Streams ........................................................................................... 4 

Table 3-4 Summary of Major HAPS Processed ............................................................................................... 4 

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

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

Table 4-1 MACT OPLs to be Established During the Performance Test .......................................................... 5 

Table 4-2 Metals Evaluation Plan ....................................................................................................................... 6 

Table 4-3 Anticipated Performance Test Schedule ................................ ................................................... ..7 

Table 5-1 General Sampling and Analytical Program Overview (Stack Exhaust) .......................................... 19 

Table 5-2 QA Objectives for Field Measurements ....................................................................................... 20 

Table 5-3 Overall Summary of Performance Test Stack Gas Sampling and Analysis Program .................... 21 

Table 5-4 Traverse Point Locations .................................................................................................................. 22 

Table 5-5 Sample Preservation and Holding Time Requirements ................................ .............................. 23 

Table 5-6 QA Requirements for Metals in Stack Gas by ICAP or ICP-MS ................................................... 24 

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Veolia ES Technical Solutions MACT Performance Test Plan Page vi of vi 

List of Figures 

Figure 5-1 Stack Sampling Locations ............................................................................ ............................. 25 

Figure 5-2 Example Sample Packing List ......................................................................................................... 26 

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Section: 1.0 

Veolia ES Technical Solutions MACT Performance Test Plan Page 1 of 4 

I .O Introduction 

1 .I Program Summary [40 CFR 5 63.1207(f) and 5 63.7(c)(Z)(i)] 

This document is the Performance Test Plan for Incinerator No. 2 operated by Veolia ES Technical Solutions 

(Veolia) at its Sauget, Illinois facility. Since the Veolia incinerator treats certain waste that are classified as 

hazardous under state and/or federal regulations, this unit is subject to the requirements of the HWC MACT 

Rule. 

This Plan has been prepared in accordance with requirements initially promulgated in NESHAPS: Final 

Standards for Hazardous Waste Air Pollutants for Hazardous Waste Combustors, (generally referred to 

as the Hazardous Waste Combustor [or 'HWC"] MACT Rule). These regulations were initially published by 

US EPA on September 30, 1999 in 40 CFR 3 63 Subpart EEE. However, these initial regulations were 

vacated based on a DC Circuit Court ruling, were subsequently replaced by "Interim Standards" in February of 

2002 and then re-promulgated again in the Permanent Replacements Standards published in the Federal 

Register on October 12, 2005. 

This document addresses the requirements to develop and submit a Performance Test Plan set forth in 40 

CFR § 63.1207 and 3 63.7. This test plan is written to address all applicable Subpart EEE (and General 

Provisions) requirements incorporated into the regulations through promulgation of the Final Replacement 

Standards published in the Federal Register on October 12, 2005. 

1.2 FacilityIUnit Identification 

1.2.1 General 

As mentioned above, this Performance Test Plan has been developed to evaluate the incinerator at the Veolia 

facility in Sauget, IL. This is a commercial hazardous waste incineration facility that treats liquid and solid 

wastes that are classified as both hazardous and non-hazardous. 

1.2.2 Facility ID, Mailing Address, and Primary Contacts 

The facility address is: The facility contact is: 

Veolia ES Technical Solutions Mr. Dave Klarich 

7 Mobile Avenue Phone: 361 -572-2317 

Sauget, IL 62201 Email: David.Klarich@veoliaes.com 

Facility ID#: lLD098642424 

1.2.3 Incinerator Overview 

This Veolia incinerator is a fixed hearth incineration system with primary and secondary combustion chambers 

that treats solid wastes as well as aqueous and organic liquids. The process is monitored and controlled by a 

distributed control system (DCS) capable of continuously monitoring the process to assure all operational 

parameters are within regulatory and permit limits while waste is being fed to the unit. In addition, this 

incinerator is equipped with a Continuous Emissions Monitoring System (CEMS) that continuously samples 

the exhaust gases for oxygen and carbon monoxide in the stack gas exhaust stream. 

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Section: 1.0 

Page 2 of 4 

1.3 Purpose and Objectives of the Performance Test 

1.3.1 General 

The purpose of this test program is to validate the performance level of the incinerator against the 

requirements in 40 CFR Part 63, Subpart EEE. To this end, the specific objectives of this performance test are 

to: 

Demonstrate that the metals emissions from the incinerator meet the HWC MACT emission limits 

while treating hazardous waste for the parameters being tested. 

Collect monitoring data in order to re-establish operating parameter limits (OPLs) or set new OPLs on 

key operating variables that will ensure that the incinerator operates within the HWC MACT emission 

limits while treating hazardous waste. 

Utilize an extrapolation procedure, as appropriate, to establish metals feed rate limits. 

The test program will include feeding a variety of liquid and solid waste materials to the incinerator, sampling 

and analyzing the feed streams, monitoring certain process parameters and conducting emissions testing. 

The emissions standards that will be evaluated under the HWC MACT regulations are summarized in 

Table 1-11, 

1.4 Performance Test Plan Organization 

This test plan has been organized in a format typically used for compliance demonstration test programs. 

Table 1-2 is included so that the requirements in the HWC MACT rule can be cross-referenced with the 

sections in this Plan. The remainder of the document has been organized as follows: 

Section 2.0 provides a general physical description of the fixed hearth incineration system and 

associated unit operations (including the air pollution control system) as well as an overview of the 

automatic waste feed cutoff (AWFCO) system and maintenance procedures. 

Section 3.0 presents a brief discussion of the wastes to be treated in terms of physical and chemical 

parameters which impact thermal oxidation and summarizes the hazardous air pollutants presently 

identified in the waste streams. 

Section 4.0 presents the Test Protocol including planned feed and test conditions, rationale for the 

test design, anticipated test schedule and final report format. 

Section 5.0 fully describes all sampling and analysis procedures and associated QNQC protocols 

following the latest EPA guidance. This section essentially serves as the Quality Assurance Project 

Plan (QAPP) for this project. 

The Appendices contain Process Flow Diagrams (Appendix A), examples of performance test field data 

sheets and test equipment calibration (Appendix B); and isokinetic sample train setup and recovery forms 

(Appendix C). 

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Veolia ES Technical Solutions MACT Performance Test Plan Page 4 of 4 

Table 1-2 Cross Reference of Performance Test Requirements 

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Section No. 

in this 

Document 

1.1 

4.7 

5.5 

5.9 & 5.13 

3.0 

2.0 

2.2 

2.2 

2.2 

2.3 

2.2.6 

2.5.1 

2.4.11 

N/A 

2.6 

2.3.5 

5.6 & 5.8 

4.3, 4.4 & 4.5 

2.3.6 

2.2.7 

4.4.2 

3.0 

4.6 

NIA 

Topic 

Program Summary 

Test schedule 

Data Quality Objectives (DQOs) 

Internal and External Quality Assurance Plan 

Analysis of feedstreams (as fired) 

Heating value, ash content, semi-volatile metals, 

low volatile metals, mercury and total chlorine 

Viscosity 

Identification and quantification of reasonably 

expected HAPS 

Detailed engineering description of combustor 

Manufacturer/makelmodel of HWC 

Type of HWC 

Maximum design capacity 

Feed systems 

Location of combustion zone temperature 

device 

Hazardous waste AWFCO system 

Design, operation and maintenance of APC 

Justification of alternative gas flow rate 

measurement technique 

Design, operation and maintenance of stack gas 

monitoring systems 

Description of Waste handling and blending 

Operations 

Detailed test protocol including: 

Description of sampling, monitoring and 

analytical procedures 

Description of Planned Feed and Operating 

conditions during the Performance Test 

Procedures for rapidly stopping hazardous waste 

feed and controlling emissions during malfunction 

Determination of hazardous waste residence time 

Metal feed rate limit extrapolation (if used) 

Documentation of expected levels of regulated 

constituents in other feed streams that are not 

analyzed 

Documentation of conditioning time needed to reach 

steady state prior to testing 

Alternat~ve monitoring frequency for wet scrubbers (if 

used) 

Other information deemed necessary by the agency 

Regulatory Citation 

40 CFR !j 63.1207(f) and § 63.7(c)(2)(i) 

40 CFR 3 63.1207(f), (f)(l)(v) and § 63.7(c)(2)(i) 

40 CFR § 63.1207(f) and 5 63.7(c)(2)(i) 

40 CFR § 63.1207(f) and 3 63.7(c)(2)(i) 

40 CFR § 63.1207(f)(l)(i) 

40 CFR § 63.1207(f)(l)(i)(A) 

40 CFR § 63.1207(f)(l)(i)(B) 

40 CFR § 63.1207(f)(l)lii)(A) & (B) 

40 CFR § 63.1207(f)(l)(iii)(A) 

40 CFR § 63.1207(f)(l)(iii)(B) 

40 CFR § 63.1 207(f)(l)(lii)(C) 

40 CFR § 63.1207(f)(l)(iii)(D) & (E) 

40 CFR § 63.1207(f)(l)(xix) 

40 CFR § 63.1207(f)(l)(iii)(F) 

40 CFR 5 63.1207(f)(l)(iii)(G) 

40 CFR 5 63.1207(f)(l)(xvii) 

40 CFR § 63.1207(f)(l)(iii)(H) 

40 CFR § 63.1207(f)(l)(ii)(C) 

40 CFR § 63.1207(f)(l)(iv) 

40 CFR § 63.1207(f)(l)(vi) & (vii) 

40 CFR § 63.1207(f)(l)(viii) 

40 CFR 5 63.1207(f)(l)(ix) 

40 CFR § 63.1207(f)(l)(x) 

40 CFR § 63.1 207(f)(l)(xi) 

40 CFR Fj 63.1207(f)(l)(xii) 

40 CFR § 63.1207(f)(l)(xxiii) 

40 CFR § 63.1207(f)(l)(xxvii) 
Rev~sion: 0 

Date: May 2008 

Section: 2.0 

Veolia ES Technical Solutions MACT Performance Test Plan Page1 of12 

2.0 Engineering Description 

2.1 Process Overview 

Veolia operates 2 Fixed Hearth Dual Chambered Incinerators (Units 2 and 3) and one rotary kiln incinerator 

(Unit 4) at the Sauget, IL facility. The two fixed hearth units are rated at 16 million Btulhr each. Incineration 

Unit No. 3 is a mirror image of Unit No. 2. Both of these units have their own waste handling systems as 

described in the sections that follow. The only difference being Unit No. 2 is equipped with four (4) baghouse 

modules, while Unit No. 3 is equipped with three (3) baghouse modules. However, each incinerator is 

operated identically with only three baghouse modules in service during operation. 

2.2 Waste Feed Systems [40 CFR § 63.1 207(f)(l)(ii)(c) and (f)(l )(iii)(D) and (E)] 

2.2.1 Unit 2 Liquid Waste Feed System and Blending Operations 

The fixed hearth incinerator is designed to receive containers, aqueous liquid wastes, organic liquid wastes, 

specialty liquid feeds, gases and direct inject liquids fed through the aqueous or organic liquid feed systems. 

These units can receive any combination of wastes -- liquid, semi-solid, solid or gases --with a heat value of 

up to 16 m~llion Btulhr. 

Unit 2 is supported by storagelblend tanks located in Tank Farm #I. Rates of feed are controlled at each 

incinerator. Segregated liquid wastes are stored unt~l utllized in the waste blending facilities. At that time, 

liquids are delivered to the blending tanks where the daily liquid feed to the incinerator is formulated, tested, 

and released to the incinerator. Blending of stored liquid wastes to achieve optimum heating value and 

viscosity for incineration takes place in Tanks 2, 4, 6 & 8. Six additional tanks (10, 20, 30, 40, 50 & 60) are 

used to segregate different waste stream types for blending of liquid feed to the incinerator. Several criteria 

are important in designing a blend from available wastes that have been segregated principally by physical 

and chemical properties. These include compatibility, proper range of heating value, and permit restrictions 

regarding elemental composition (based on emission lim~tations). The material is transferred through 

aboveground pipelines from the tank farm to the incinerator. Pipelines used to transfer liquid organic waste 

and aqueous waste are equipped with strainers. 

In compliance with the Benzene NESHAP, all tanks are vented to individual carbon adsorption canisters for 

removal of organics before vapor is discharged to the atmosphere. Each carbon adsorber canister is 

essentially equivalent to a 55 gallon container or greater, if necessary. All tanks are equipped with 

conservation vents, in addition to the carbon canister adsorber. All tanks are grounded, and flame arrestors 

are installed between the carbon adsorbers and the tanks. 

2.2.1.1 Organic and Aqueous Liquid Waste Feeds 

The liquid waste injectors used in the combustion chambers are air-atomizing injectors. 'These are used for 

ipjection of high Btu, low Btu liquids and specialty feed liquids. Dual fluid injection nozzles will be used for 

atomization of the waste. Each of the injectors is rated at 0-300 gph. The liqurd waste feed nozzles are 

served by parallel redundant pumps and recirculation systems with back pressure control. 

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2.2.1.2 Packaged and Bulk Solid 

Containers of wastes are sampled and analyzed after receipt in accordance with the facility's Waste Analysis 

Plan. These wastes can then be delivered directly to Unit 2 or repacked into small combustible containers at 

the facility. Fiberboard or plastic containers (fully or partially full of waste), up to 40-gallon size, may be 

charged directly to the primary chamber. These will be received at the dock adjoining each fixed hearth 

incinerator, and charged to the incinerator wlthin 24 hours or returned to permitted storage. 

Solids, usually packaged in plastic or fiberboard containers, are introduced into the incinerator through a PLC 

controlled airlock-ram system located at the lower front of the primary chamber of the incinerator. The airlock 

is composed of a refractory-lined door, a door into the airlock enclosure, and two pneumatic rams. The action 

of the feeder is as foliows: 

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

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

The airlock door is closed. 

A switch is activated either automatically or manually, which opens the door to the incinerator and 

actuates the ram (charge ram) that pushes the waste into the incinerator. The ram then retracts and 

the incinerator door closes. 

2.2.1.3 Specialty Liquid Feeds and Gases 

Specialty Feed Systems associated with lncinerator No. 2 are as follows 

Specialty Feeder 

Compressed Gas Cylinder Feed System 

Direct Inject Liquid Feed System 

2.3 Manufacturer, Make and Model of the Incinerator [40 CFR 5 63.1207(f)(l)(iii)(A)] 

2.3.1 Combustion Chamber and Burners [40 CFR 963.1207(f)(l)(iii)(B) and (C) 

lnclnerator No. 2 features a two-stage combustion process. Ignition of waste material takes place in the 

primary (lower) combustion chamber (PCC). A secondary (upper) combustion chamber (SCC) serves as an 

"after-burner" for process gases. Ignition of the waste takes place at temperatures in excess of 1700 

degrees F. The secondary combustion chamber maintains a minimum temperature of approximately 1800 

degrees F. 

The fixed hearth incinerator is fabricated of carbon steel. The primary chamber has an external diameter of 9 

feet and is 17.5 feet long. The interior walls of the chamber are lined with approximately 10 inches of brick 

refractory and insulation backing, making the internal operating diameter approximately 7'2". The crosssectional area of the chamber is thus 40.3 square feet. Table 2-2 provides a summary of the incinerator 

design specifications. 

Liquid and solid waste feeds enter the lower chamber on the front-face of the chamber. The primary burner 

and the specialty feed injector are located near the front-face of the chamber and are mounted tangentially. 

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Page 3 of 12 

The primary burner is a North American burner rated at 12.0 million Btulhr. and is used in the lower chamber 

to maintain permitted temperatures. It w~ll burn only natural gas or No. 2 fuel oil. The burner system is 

supplied with combustion air at a static pressure of 30 water column (WC). The pilot for the primary burner will 

burn natural gas. 

The fuel system for the lower chamber (and secondary combustion chamber) is controlled by a Factory Mutual 

approved burner management system complete with interlocks and safety valves. 

2.3.2 Secondary Combustion Chamber 

The secondary combustion chamber (SCC) is a horizontal, cylindrical chamber that has an external diameter 

of 9 feet and is 17.5 feet long. The interior walls of the chamber are lined with approximately 10 inches of brick 

refractory and insulation backing, making the internal operating diameter approximately 7'2". The crosssectional area of the chamber is thus 40.3 square feet. 

Following ignition of the waste material under controlled or starved-air conditions in the lower chamber, offgases travel through a refractory-lined flue gas passage into the upper chamber, which acts as an afterburner. 

Turbulence is achieved by the tangential introduction of air and additional fuel in the upper chamber. 

The SCC is equipped with one burner mounted tangentially on the side of the chamber. The burner is a North 

American burner rated at 6.0 million Btu/hr and is fueled with natural gas or fuel 011. 

As with the primary chamber burner, the SCC burner is supplied with atomizing air and is equipped with a 

burner management system. This system controls the ignition and initiates an automatic shutoff when there is 

a loss of flame, combustion air supply, fuel pressure, atomizing air pressure, or pilot burner. 

Leaving the upper chamber, the hot gas stream travels through 28 feet of refractory-lined stack sections before 

reaching the start of the gas scrubbing system. The combined volume of the upper and lower chambers, the 

flue gas passage and the hot crossover section is approximately 1,567 cubic feet. The total retention time of 

combustion gases within the system is approximately 5 seconds. 

2.3.3 Location of Combustion Zone Temperature Device [40 CFR 5 63.1207(f)(l)(xix)] 

The thermocouple that monitors temperature in the primary combustion chamber is located on top of the 

chamber about five feet from the transition. The thermocouple that monitors temperature in the SCC is located 

on top of the chamber above the transition. 

2.3.4 Hazardous Waste Residence Time [40 CFR 5 63.1 207(f)(l)(ix)] 

The Hazardous waste gas residence time for the Fixed Hearth Incinerator is calculated as follows: 

Primary Combustion Chamber Volume - 635 ft3 

Secondary Combustion Chamber Volume - 635 ft3 

Total Volume - 1270 173 

Maximum Flue Gas Flowrate - 17,382 acfm (290 ft3/sec) 

Total Combustion Zone Residence Time = (1270 ft3)/(290 ft3/sec) = 4.4 sec 

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2.3.5 Combustion System Leak 

Combustion system leaks are prevented through maintaining a totally sealed combustion chamber, coupled 

with the use of an induced draft fan that maintains a vacuum of normally - 4 to - 6 inches of water column in 

both combustion chambers while wastes are being fed to the unit. 

2.3.6 Emergency Safety Vent 

The incinerator is equipped with an emergency safety vent (ESV) located at the top of the secondary 

combustion chamber. This ESV is a refractory-lined emergency thermal relief vent (TRV) which is held in the 

closed position by a pneumatic cylinder. The control valve in the line supplying air to the cylinder and the 

cylinder vent valve which opens the TRV are located in the control room for each unit. Valve locks (w~th keys 

attached) are utilized to deter indiscriminate operation of these valves. Opening of the TRV allows hot 

combustion gas to vent from the combustion system during emergency shutdown events. The purpose of the 

TRV is to protect the downstream APCS from excessive temperature situations. A limit switch on the TRV 

shuts off all waste feeds to the system as it senses that the cap is opening. 

2.4 Procedures for Rapidly Stopping Hazardous Waste Feed During Equipment 

Malfunction [40 CFR 563.1 207(f)(l)(viii)] 

Equipment malfunctions are identified by the control system, observation of process control variables, or by 

regular field inspections. 

In the event of minor equipment malfunctions (e.g. waste feed or scrubber leaks), the control room operator 

will be not~fied. The control room operator will then close the waste feed valves and disable the waste feed 

pumps. 

In the event of major equipment malfunctions (e.g. fire), the emergency stop button located in the control room 

will be pushed. If this button is pushed, all equipment will switch to its fail-safe position. 

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

2.5.1 Air Pollution Control Systems Descriptions 

The air pollution control system consists of a spray dryer absorber and fabric filter baghouse modules. The air 

pollution control system neutralizes acidic compounds and removes particulate from the exhaust gas. Two 

subsystems, the spray dryer absorber and the fabric filter, carry out the chemical neutralization and parttculate 

removal functions, respectively. A third subsystem, the lime system, is used to prepare and provide lime slurry 

to the spray dryer absorber for use in the chemical neutralization process. The induced draft fan and stack 

provide the mechanical energy required to transport the flue gas through the interconnecting ductwork, to its 

eventual discharge point to atmosphere. 

2.5.1 .I Lime System 

The lime system prepares lime slurry for use in the chemical neutralization process in sufficient supply and 

concentration to maintain continuous flue gas treatment in the spray dryer absorber. The system has been 

designed for batch mixing to provide this service. 

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Hydrated lime is stored in a storage bin above the lime preparation area. The storage bin is sized to hold 

enough hydrated lime to maintain several days of system operation at the maximum combustion rate of the 

incinerator. Lime is discharged through the conical storage bin bottom. The flow of the material from the bin is 

aided by a vibrating "live bottom," or bin activator. A variable speed screw feeder is used to meter the 

hydrated lime in the proportions required for batch mixing lime slurry. The lime is mixed with water in a tank 

beneath the lime storage bin. The screw feeder speed and the rate that water is added to the lime slurry tank 

are variable so that the desired lime solids concentration can be achieved in the tank. The variable feed 

adjustments allow water and lime to be added to the lime slurry tank at a rate that will allow a batch mode of 

mixing. An agitator is provided in the slurry tank to mix the water and lime and to maintain the suspension of 

l~me solids. The mixed lime slurry is pumped at a continuous rate of flow through a recirculation loop to the 

atomizer. 

2.5.1.2 Spray Dry Absorber 

Unit 2 is equipped with a Spray Dryer Absorber (SDA) located immediately downstream of the secondary 

combustion chamber. The SDA unit is fabricated of 318 inch carbon steel. The function of the SDA is to: 

Further cool the combustion gases from 1600-2000oF to 300-500oF, 

Neutralize and remove HCI and other acids from the combustion gases, 

Remove a portion of the particulate (fly ash) from these gases. 

Slurry flow to the spray dryer absorber (SDA) is metered by a flow control valve to obtain the proper feed 

concentration to the spray dryer absorber atomizer. Automatic (or manual) adjustment to the flow is made as 

a function of the output from a hydrochloric acid (HCI) analyzer in the gas duct downstream of the fabric filter. 

The amount of slurry metered is proportional to the amount of HCI monitored. 

The slurry passes through a stationary swirl-type liquid distributor into the atomizer wheel where induced 

centrifugal force from the rapidly spinning wheel discharges the slurry through the wheel nozzles at high 

velocity. The design of the atomizer wheel, its rate of spin, and the discharge velocity of the slurry, create a 

cloud of finely divided droplets around the periphery of the atomizer wheel. A feedback signal from the 

atomizer power transmitter provides verification that water flow to the atomizer increases or decreases in 

proportion to the spray dryer absorber outlet temperature. 

Flue gas enters from the bottom of the spray dryer absorber through a vertical, centrally located disperser. 

The disperser directs the flue gas through the zone fled by the atomized slurry cloud where the flue gas and 

slurry mix and most of the absorption occurs. The gases then flow downward through the absorber chamber 

and exit through a bottom side duct. As the gases contact and pass through the cloud of atomized lime slurry, 

the water in the slurry evaporates, cooling the gases Simultaneously, the lime In the slurry reacts with the 

hydrogen chloride in the gases to produce calcium salts. Some of the resulting dry material, consisting of 

calcium salts, fly ash and excess lime, falls to the conical bottom of the unit. The dry material from each unit is 

discharged to a conveyor system which transports it to a dump trailer or equivalent type system. 

2.5.1.3 Fabric Filter 

Gas exhausted from the spray dryer absorber is distributed by manifold ducts to four fabric filter modules. The 

unit is operated with only three modules on-line with the fourth module off-line in a standby mode. Within each 

filter module, the gas is passed through Teflon-coated fiberglass cloth bags. The gas passes from the outside 

to the inside of the filter bags. Particulate entrained in the gas stream is mechanically deposited on the outside 

of the filter bags as the gas passes through the cloth. 

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Each module has a clean air plenum and housing section to contain approximately 96 bags. Each bag is 

approximately 6" in diameter by 20' long. The baghouses are fabricated from 3/16" mild steel plate, of welded 

construction, gas tight and stiffened to withstand the maximum operating negative pressure. Each 

compartment has a tube sheet that supports the bags and provides for top baglcage removal. Access to the 

clean air plenum is via a side access door in the clean air plenum. 

The fabric filter cleaning mechanism utilizes jets of air to clean the filter bags. Periodically, the cleaning 

sequence will be initiated. The sequence is started at the end of a 4 hour timed cycle, when the differential 

pressure across the filter reaches a predetermined setpoint of approximately 7 0" w.c., or when the operator 

initiates a cycle. The controller then sequences to each row of f~lter bags in each module, releasing a burst of 

air opposite to the direction of gas flow. The quickly released burst of air dislodges dust cake on the exterior of 

each bag as it travels from the top to the bottom of the bags. Released from the bag, the dust cake falls by 

gravity into the hopper at the bottom of the module. From there it is discharged to a conveyor system which 

transports it to a dump trailer, or equivalent type system. 

Treated by the spray dryer absorber and filtered by the fabric filters, the cleaned flue gas exits the fabric filter 

modules to an outlet manifold for exhaust. 

2.5.1.4 Induced Draft Fan and Stack 

The induced draft fan and stack are located downstream of the fabric filter. Combustion gases are drawn 

through the system by a 75 hp induced draft (ID) fan, rated at 15,000 acfm at 400' F saturated, and 22 water 

column pressure. The induced draft fan provides the mechanism for transporting the incinerator flue gas 

through the spray dryer absorber, fabric filter, and all interconnecting ducts. The ID fan includes an inlet 

volume control damper to be used to control the velocity of the gas within the ducting and treatment devices. 

Treated gases are exhausted from the induced draft fan to the atmosphere through a 90-ft. high stack. The 

stack diameter for Unit 2 is 39 inches I.D. The stack is equipped with instrument sampling ports and a 

sampling platform for emissions testing. Figure 5-1 provides details on the design and sample port locations 

and configurations for the stack. 

2.6 Stack Emissions Monitoring [40 CFR §63.1207(f)(I)(iii)(H)] 

The continuous emissions monitoring (CEM) system consists of sample probes, sample delivery and 

condition~ng apparatus, and gas analyzers. Samples are extracted from the sampling ports on the stack. A 

CEM performance test and quality assurance program has been implemented in accordance with 

Performance Specifications for Continuous Emission Monitoring of Carbon Monoxide and Oxygen for 

Incinerators, Boilers and Industrial Furnaces Burning Hazardous Waste, as defined in 40 CFR 266, 

Appendix IX, Section 2.1. 

Responses from each CEMS will be fed to the Control System (CS) where the CO hourly rolling average is 

calculated and interlocked to the waste feed cutoff valves as part of the Automatic Waste Feed Cutoff System 

(AWFCO) discussed in Section 2.8, below. The following provides a brief description of the CEMS 

instruments including the operating range and measurement principal. 

2.6.1 CEM System Description 

The Continuous Emissions Monitoring Systems (CEMS) currently being utilized at Incinerator 2 analyzes for 

opacity, carbon monoxide, hydrogen chloride, total hydrocarbons and oxygen. These monitors, except 

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opacity, are extractive devices mounted in sampling ports on the stack. The table below summarizes the 

analyzer specifications. 

The opacity monitor continuously measures the stack gas opacity and reports the measurements to an 

indicator and a recorder. An opacity that exceeds a preset limit triggers an alarm and interlock. 

Carbon monoxide and hydrogen chloride are monitored with extractive non-disperse infrared analyzers. Total 

hydrocarbon is monitored with an extractive flame ion detector analyzer. Oxygen is monitored with a 

zirconium oxide cell. 

Stack gas flow rate is continuously monitored using an anubar that sends a 4-20 mA signal to the PLC which 

converts the signal to acfm. 

Table 2-1 Unit 2 Continuous Emission Monitors 

2.7 Process Monitoring and Control 

The facility is equipped with a state-of-the-art monitoring and control system, which facilitates compliance with 

permit conditions, and otherwise, collects process control information, facilitates efficient operation and detects 

and prevents damage to the facility. The system consists of three major components: 

Principle 

Electrochemical 

Infrared 

FIDIlnfrared 

Infrared 

White light 

Pressure drop 

Parameter 

Oxygen 

Carbon Monoxide 

Total hydrocarbons 

Hydrogen chloride 

Opacity 

Stack gas flow 

A human-machine interface (HMI) system, 

Programmable logic controller's (PLC's), and 

A high speed ethernet cable connects all control system components 

The desired control functions are implemented through the HMI system. All digital control and emergency 

interlocks are accomplished by the PLC. 

Current Mfg. 

COSA 

Ecochem MC3 

Thermoelectron 

Ecochem MC3 

Teledyne 

PSEIRosemount 

The control system is capable of monitoring the "operational envelope" of the incinerator and is capable of 

performing a number of activities including: 

Range 

0-25% 

0-200 ppmv 

0-3000 ppmv 

0-1 00 ppmv 

0-1,000 ppmv 

0-1 00% 

0-20,000 acfm 

Control room indication of processor sensors located within the incinerator system (such as pressure 

indication of a field installed pressure transmitter); 

Process controller for single instrument loops or an individual sub-system, such as a temperature 

control loop involving a sensor reading from one temperature transmitter affecting the function of one 

temperature control valve; and 

Alarm for an exceedance of a designated setpoint, such as a high pressure or low temperature. 

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The process control computer will continuously control and monitor the operation of the incinerator. When outof-range conditions exist, it will notify the operator of those conditions. The process control computer is 

programmed to shut-down equipment (i.e., bring the system into a safe mode) when designated parameters 

are exceeded, which is a protective mechanism against potential equipment damage, operation outside of 

permit limits, or conditions that might lead to a release to the environment. 

Continuous monitoring of the incinerator and scrubber system is an important aspect of the system design. A 

digital readout of all monitoring instrumentation is displayed on the main control screen. An audible and visual 

alarm alerts the incinerator operator to significant deviations from normal operating conditions Th~s system 

allows an immediate response to adverse conditions by the operator. Automatic waste feed cut-off and 

incineration shutdown mechanisms are also interlocked with the monitoring system at or prior to reaching 

permit l~mit levels. Monitoring methods and calibration frequencies are listed in Table 2-3. 

The Incinerator has an independent process control computer that interfaces to the Quantum programmable 

controllers. The process computer is capable of controlling the incinerator in case of a failure in a HMI server. 

'This computer runs a RSVIEW HMI control software that provides operator interface to all instrumentation and 

controls. 

2.8 Automatic Waste Feed Cut-off System [40 CFR 563.1 207(f)(l)(iii)(F)] 

The incinerator has an Automatic Waste Feed Cut-Off (AWFCO) System that will shut waste feeds off in the 

event certain operating parameters deviate from allowable set points. The PLC continuously monitors 

operating parameters, making adjustments to the process as needed for proper control. Alarm logic is 

incorporated into the PLC system to automatically initiate an AWFCO. Table 2-3 summarizes the current 

AWFCO set points. AWFCO limits have been established based on several factors that are summarized 

below. 

Reaulatowl~ermit limits -established to comply with existing permits. An example of this type of limit 

is the low temperature limit, below which waste cannot be fed until the proper limit is re-established. 

In addition, the HWC MACT regulations require that the AWFCO system be interlocked with the span 

of each process instrument that is part of the Continuous Monitoring System (CMS). A listing of these 

CMS instruments and their interlocked span setpoints is maintained as part of Veolia's Operating 

Record. 

Process safetv limits -established to assure process equipment is protected and unsafe operating 

conditions do not occur. An example of this is inadequate excess air in the combustion chamber that 

can lead to fuel rich conditions. 

Utilitv or Power failure - established to facilitate a controlled shutdown of the process during loss of 

process air, steam, water or electricity. An example of this is the loss of instrument air that is 

necessary for certain types of process instruments to function properly. Wastes will not be reintroduced into the incinerators until proper operation of key instruments is re-established. 

In addition to the AWFCO system, operators can manually shutdown waste feeds or the entire process should 

this be needed. 

2.8.1 AWFCO System Testing 

,c- Veolia tests the AWFCO systems bi-weekly. Instrument calibrations are performed as indicated in Table 2-3 

In some cases this testing occurs more frequently depending on how often actual AWFCOs occur at the unit. 

Per the required frequency, incinerator personnel check the functionality of AWFCO logic that is part of the 

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incinerator's PLC system to make sure that should process conditions deviate from allowable limits, the 

computer logic will initiate waste feed shutdowns as required. This is accomplished by manually simulating 

process conditions that are outside allowable limits and observing and documenting when the control or block 

valve software logic on the waste feed line begins to initiate valve closure. Should actual AWFCOs occur 

during a given testing period, these are documented by operating personnel to satisfy regulatory requirements 

for system testing. Results of this testing are documented on a separate AWFCO Testing Log and maintained 

as part of the unit's Operating Record. 

2.9 Air Pollution Control Equipment Maintenance Practices [40 CFR 

963.1 207(f)(l)(iii)(G)] 

2.9.1 Program Overview 

Once equipment is installed and operational, Veolia utilizes an extensive preventative maintenance (PM) 

program to keep equipment operational and prevent breakdowns and failures. Based upon the type of 

equipment and historical operations and maintenance experience, schedules for various inspection and PM 

activities are followed. This includes aspects such as documenting detailed maintenance histories on 

equipment, routine inspection and lubrication programs for high wear equipment and non-destructive testing of 

piping and vessels using techniques like ultrasound to assess integrity. The frequency of these activities 

varies depending upon the equipment, PM activity and the incinerator's shutdown schedule. 

For example, frequent (i.e., weekly) instrument and certain mechanical equipment checks are made for critical 

process items. Lubrication, vibration analysis and other mechanical integrity checks are done at longer 

frequencies like monthly or quarterly. And finally, such items as inspecting refractory brick for wear, are 

typically performed when the entire incinerator is shut down for maintenance. 

2.9.2 Test Program Preparation Activities 

Prior to testing, instrumentation associated with key parameters of the test will be checked, calibrated, or 

replaced, as appropriate, to ensure proper operation of the instrumentation during testing (i.e., waste feed 

flowmeters and scales, CEM's, pressure transmitters, thermocouples, stack flowmeters, etc.). 

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

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Manufacturer 

Model No. 

TY pe 

Date of Manufacture 

Dimensions 

External Length 

External Diameter 

Internal Diameter 

Cross-sectional area 

Burners 

Manufacturer 

Size 

Fuel 

Primer Mover 

Trade Waste Incineration 

JWI-2000, Series 2 

Fixed Hearth, Dual Chamber 

1987 

Primary Chamber 

17.5' 

9' 

7'2" 

40.3 square feet 

Primary Chamber Burner 

North American 

12.0 Million Btulhr 

Natural Gas 

Secondary Chamber 

17.5' 

9' 

7'2" 

40.3 square feet 

Secondary Chamber Burner 

North American 

6.0 Million Btulhr 

Natural Gas 

Induced Draft Fan 15,000 acfm @ 400°F saturated, 22 in. water column 
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Table 2-3 Current AWFCO Parameters and Limits for Incinerator No. 2 

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Calibration 

Frequency 

Annually 

Annuallylquarterly 

Annually 

Annually 

Quarterly 

Annually/quarterly 

Annually/quarterly 

Annually/quarterly 

Annually/quarterly 

Annuallylquarterly 

Annually/quarterly 

Annually 

Annually 

Quarterly 

Quarterly 

Annually 

Annually 

Annually 

Quarterly 

Quarterly 

Quarterly 

Quarterly 

Cutoff Limits 

> 3,123 (HRA) 

24,301 

2 2,012 

2 1 ,993 

r 724 

2 1.264 (1 2 HRA) 

> 1,264 (1 2 HRA) 

23,477 (1 2 HRA) 

> 0.0073 (1 2HRA) 

> 237 (12 HRA) 

> 673 (12 HRA) 

11,590 (one-minute 

average) 

<I ,712 (HRA') 

22,400 (~nstantaneous) 

51,794 (one-minute 

average) 

<I ,845 (HRA') 

22,400 (instantaneous) 

r -0 1 (5 second delay) 

r -0.1 (5 second delay) 

> 33.5 

2500 (one m~nute 

pp 

average) >420 (HRA) 

217,198 

Units 

Lblhr 

System 

Total Pumpable Waste 

Feed rate 

Device 

Mass Flowmeters/Scales 

Rate 

Stack Gas Excess 

Oxygen 

Stack carbon monox~de 

Stack Hydrocarbon 

Stack gas opacity 

Total Waste Feedrate 

High BTU Liquid feedrate 

Low BTU Liquid feedrate 

Specialty feeder 

Total LVM Feedrate 

Pumpable LVM Feedrate 

SVM Feedrate 

Mercury Feedrate 

Chlorine Feedrate 

Ash Feedrate 

Primary Combustron 

Chamber Temperature 

Secondary Combustion 

Chamber Temperature 

Primary Combustion 

Chamber pressure 

Secondary Combustion 

Chamber pressure 

Chlorine Feed to Slurry 

Flow Ratio 

Spray Dryer Adsorber 

Outlet Temperature 

Combustion Gas Flow 

Zirconium Ox~de fuel cell 

Infrared 

FID 

White L~ght 

Mass Flowmeters/Scales 

Mass flow meter 

Mass flow meter 

Scale 

Mass Flowmeters/Scales 

Mass flow meter/Scales 

Mass Flowmeters/Scales 

Mass Flowmeters/Scales 

Mass Flowmeters/Scales 

Mass Flowmeters/Scales 

Type K Thermocouple 

Type K Thermocouple 

Pressure transmitter 

Pressure transmitter 

Flowmeter 

Type K Thermocouple 

Prtot Tube 

Lb/hr 

Ib/hr 

lblhr 

Ib/hr 

Ib/hr 

Ib/hr 

Ib/hr 

Ib/hr 

Ib/hr 

Ibhr 

" F 

" F 

in. W.C. 

in W.C. 

ratio 

" F 

acfm 

% 

PPmv 

PPmv 

% 

>15,534 (HRA) 

< 3 (one-minute avg.) 

2100 (HRA) 

2500 (one minute 

average) 

210 (one m~nute average) 

210 (one minute average) 
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System Device Units Cutoff Limits 

- 

1 HRA means "hourly rolling average" as calculated by averaging the previous 60 one-minute average values. 

Stack hydrogen chloride 

I 

Fabric filter pressure drop 

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Infrared 

Delta P transmitter 

PPmv 

in. w.c. 

2.100 (HRA) 

2500 (one minute 

average) 

s 2 or 2. 10 (1 min. 

average) 

Quarterly 

Quarterly 
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3.0 Incinerator Feed Stream Descriptions 

3.1 General 

Veolia treats a broad range of wastes and thus the individual streams that may make up the incinerator overall 

feed at any given time can vary greatly, depending on generator production and shipping schedules. Prior to 

scheduling wastes for shipment to the facility, the waste streams are characterized by the generator and 

reviewed by Veolia staff. A Waste Profile Number uniquely identifies each different waste stream. This 

assures that only pre-approved wastes are handled at the facility and that all necessary regulatory, handling, 

safety and other important information is available to Operations personnel. Organic Hazardous Air Pollutants 

(HAPs) measured or expected (based on process knowledge) to be present in a source waste at or above 

approximately 0.1 % by weight are listed in the tables in this Section. Organic HAPS not listed are, based on 

process knowledge, believed to be either completely absent or present in the waste at less than 0.1 % by 

weight. 

In addition to the information below that summarizes the top volume waste streams processed at Veolia, 

Table 3-1 provides a summary of the major HAPs processed at the facility. 

3.2 High volume wastes 

3.2.1 Liquid wastes 

Liquid wastes are received at the Sauget facility in tank trucks and drums and are either direct fed through a 

dedicated line or are blended with other compatible waste streams into the tank farm. Table 3-1 provides a 

summary of the top volume liquid streams that have been processed in the last year. Liquid wastes can be 

processed in any one of the three incinerators. These streams can be organic, aqueous or a mixture. 

3.2.2 Bulk solids 

Table 3-2 provides a summary of the top bulk solid streams handled at the Sauget facility. Bulk solids can 

include streams like contaminated soils, wastewater sludges or manufacturing process solids. These wastes 

are received at the site primarily in 20 to 40 cubic yard roll-off containers or other similar bulk transport 

vehicles. 

3.2.3 Containerized Waste 

Table 3-3 provides a summary of the top containerized waste streams handled at Sauget. Containerized 

wastes are received in drums and smaller cartons, boxes or pails and can include materials such as laboratory 

waste, spent carbon, process residues. 

3.2.4 Gaseous Wastes 

Small volumes of compressed gases are processed in Unit 2 however these are minimal in comparison to the 

other waste types that are treated. 

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3.3 Auxiliary fuels 

Natural gas or #2 fuel oil can be used as auxiliary fuels to start-up and obtain desired temperatures in the 

incinerators. At this time, all incinerators use natural gas as their primary fossil fuel. Typical composition of 

both fuels is provided in Tables 3-5 and 3-6. 

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Table 3-1 Top Volume Liquid Waste Streams 

Table 3-2 Top Bulk Solid Waste Streams 

Annual Pounds 

Received 

3,222,363 

2,897,025 

2,192,832 

1,594,454 

1,453,766 

1,273,063 

949,035 

815,882 

797,682 

753.595 

Profile 

823328 

388955 

397628 

346631 

388852 

393651 

41 001 3 

296227 

351 071 

BF0568 

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Waste Name 

REFLUX WATER 

1.51 B WASTE ORGANICSIMKH 

DE175-IPA WASH & FILTRATE WASH 

SEWllCARBAZlDE PROCESS WASTE 

BULK MIXED WASTE LlQLllDS 

PVA PRODUCTIOIV 

DP202 

RllVSE WATERIAG CHEMICAL 

BULKED LIQUID HIGH BTU >3000 

BULK LIQUIDS LOW BTU <3000 

Profile 

396871 

346603 

562221 

330548 

396775 

351 070 

674065 

350400 

024042 

360069 

Waste Name 

DOG FOOD 

HYDROCARBON TANK BOTTOMS 

BULK SOLID WASTE BTU >5000 

HYDROCARBON WASTE FROM PETROLE 

WASTEWATER TRASH BOXES-DRY 

CWD BULKED INClhlERATlON SOLID 

DRUMS & BULK CONTAllVlNG GREASE - -- - --- 

SMALL PAINT CANS 

SURGE TANK CLEAN OUT 

PRIMARY SEPARATOR SLUDGE 

Annual Pounds 

Received 

9,682,704 

3,677,040 

2,638,520 

2,567,400 

1,613,940 

1,610,360 

1,557,680 

1,380,780 

1,058,000 

956,980 
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Table 3-3 Top Containerized Solid Waste Streams 

Table 3-4 Summary of Major HAPS Processed 

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Table 3-5 Typical Properties for Supplemental Fuel Oil 

Table 3-6 Typical Properties for Natural Gas 

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Value 

> 17,000 

< 5.0 

< 2 0 

<I0 

< 1.0 

< 2.0 

< 2.0 

< 5.0 

Parameter 

Chromium 

Lead 

Mercury 

Nickel 

Selenium 

Silver 

Thallium 

Parameter 

Heat Value 

Ash Content 

Chlorrde Content 

Antimony 

Arsenic 

Barium 

Beryllium 

Cadmium 

Units 

Btullb 

%wt 

%wt 

PPm 

PPm 

PPm 

PPm 

PPm 

Units 

PPm 

PPm 

PPm 

PPm 

PPm 

PPm 

PPm 

Value 

2.0 

< 20 

NIA 

< 10 

< 0.1 

< 0.1 

< 0.05 
Veolia ES Technical Solutions MACT Performance Test Plan 

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Section: 4.0 

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4.0 Performance Test Protocol 

4.1 General Description 

This Performance Test Plan has been designed to demonstrate performance under a single test condition 

using a combination of actual and spiked feeds. This test condition will be designed to establish maximum 

metals feed rates while demonstrating conformance with applicable HWC MACT metals emissions standards. 

During the testing, Veolia will be seeking to establish new Operating Limits for Unit 2. Due to this, Veolia will 

adjust the limits at which the AWFCO system activates except for carbon monoxide. At the end of each day of 

testing, current AWFCO limits will be reinstated back to currently established limits. 

4.2 Performance Standards 

The test plan for the Veolia incinerator has been designed to demonstrate compliance with current 

performance standards of the Hazardous Waste MACT rule as follows: 

Conformance with the mercury emission limit of 130 ygldscm corrected to 7% oxygen; 

Conformance with the semivolatile metal (cadmium and lead) emission limit of 230 ygldscm corrected 

to 7% oxygen; and 

Conformance with the volatile metal (arsenic, beryllium and chromium) emission limit of 92 ygldscm 

corrected to 7% oxygen. 

4.3 Test Conditions [40 CFR 5 63.1207(f)(I)(vi) and (vii)] 

The test condition for this performance test is designed to demonstrate compliance with the applicable MACT 

metals emissions standards. Unit 2 will be operated at normal combustion zone temperatures during this 

condition with normal waste feed rates. The flue gas flow rate and chlorine feed rate will be maximized. The 

baghouse ~nlet temperature will be maximized. The proposed operating limits for the performance test are 

summarized in Table 4-1. 

4.4 Waste Feed Spiking 

In order to demonstrate the required performance criteria for this program, it will be necessary to fortify (spike) 

the incinerator feeds with organic and inorganic constituents. The spiking levels and approach proposed for 

this performance test have been used successfully in the past for testing at not only Veolia but for testing at 

other hazardous waste combustion facilities as well. 

Each spiked material will be prepared to a known specification and verified by a certificate of analysis. These 

materials will be prepared and fed in a manner that assures a very consistent feedrate. Feed rates of each 

spiked compound are chosen to be well above expected levels in native wastes, generally an order of 

magnitude or more higher, so that the spiked constituent is the dominant feed and the native contribution is not 

significant. Sp~king rates are also selected based on historical performance to assure that emissions can be 

detected and actual results, versus non-detect results, are used in calculation removal efficiencies. 

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Veolia ES Technical Solutions MACT Performance Test Plan Page 2 of 7 

4.4.1 Inorganic Constituents 

Several metals will be spiked to the system to permit calculation of system removal efficiencies (SREs), which 

can then be used to determine appropriate feed rate limits, as necessary. Regulated metals may be fed at 

some level in the native waste materials to be used during the test. However, these native concentrations may 

not be high enough to achieve the desired feed rate limits to be set for the system. Therefore, Veolia plans to 

sp~ke three surrogate metals at higher than normal rates to ensure that suffic~ent metals are fed to achieve 

measurable emissions in the stack emissions. 

Table 4-2 provides an overall summary of information relevant to the metals testing portion of the program. 

SRE data from previous test programs have been used in conjunction with present feed rate limits and present 

MACT emission limits to specify target feed rates that will result in acceptable emission rates. This table is 

only used as a predictive tool, however, and final limits to be imposed will depend on the actual results of the 

performance test. Two other points are worth noting with regard to Table 4-2: 

The spiked amount for a given metal will be the difference between the desired feed rate limit and the 

native quantity expected to fed during the test; and 

Surrogate metals will represent the whole group (in the case of LVM and SVM) and test results will be 

used to extrapolate up to the applicable MACT standard. 

The three metals to be spiked are representative of the three classes of metal volatility and therefore can be 

used to set limits for any metals not spiked. 

4.4.2 Spiking for the LVM Category 

The LVM Category for incinerators includes arsenic, beryllium and chromium. Veolia plans to spike chromium 

at 40-45 Iblhr to establish a SRE for all three test runs. The SRE demonstrated during the performance test 

for chromium will be used to establish a LVM feed rate limit. 

Chromium will be spiked as chromic acid through a liquid feed injector via a pumping station that will monitor 

the feed rate. Waste chromic acid is treated at Veolia and thus, spiking chromic acid during the performance 

test is representative of normal operations. 

4.4.3 Spiking for the SVM Category 

The SVM category for incinerators includes cadmium and lead. Veolia plans to spike lead at 60-65 Iblhr during 

the performance test to establish a SRE for all three runs. The SRE demonstrated during the performance test 

for lead will be used to establish a SVM feed rate limit. 

Lead will be spiked as lead nitrate and delivered in small, pre-measured plastic baggies at regular intervals 

along with other solid waste feeds during the performance test. Lead containing waste that are normally 

treated at Veolia are predominantly bulk or containerized solids and thus, this spiking approach during the 

performance test is representative of normal operations. 

4.4.4 Spiking for Mercury 

For mercury, the only high volatile metal, Veolia plans to spike this at approximately 0.001 - 0.002 Iblhr and 

will follow a sim~lar approach as noted above for the other MACT-regulated metals. Mercury will be fed as a 

mercuric nitrate solution at regular intervals along with other solid feeds during the performance test. Mercury 

is predominantly present in solid feeds processed at Veolia and using a liquid solution for spiking will provide 

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an easily volatilized form fed along with other solid feeds in a manner that is representative of normal 

operations. 

4.5 Metals Extrapolation Method 

Veolia plans to extrapolate to h~gher feed rate limits than actually fed during the test using the performance 

test-established SREs. This is appropriate since it is generally agreed that SREs at higher feed rates would be 

at least as good as those observed at the lower level. Any extrapolation performed will take into consideration 

the MACT standards to ensure full compliance. Based on previous discussions w~th EPA Region 5, the 

following approach will be used 

The average SRE for the three runs would be calculated from the feed and emiss~on rates for each run and an 

average SRE for the performance test. A feed rate limit would then be calculated for each metal category by 

dividing 75% of the emission standard for that category by the SRE for the spiked compound representing that 

category. A similar approach would be followed for SVM (cadmium and lead) and for mercury. To further 

assure that this method is protective, Veolia proposes to limit the maximum feedrate for any one category to 

10 times the spiked feed rate during the testing. The test program will establish 12-hour feed rate limits for the 

MACT metals. Example calculations are show below: 

Maximum emission rate for extrapolation 

= (emission standard (Cig/m3 @ 7% 02) * 0.75 * Qstaa (dscfrn @ 7% 02) * 0.0283 m3/ft3 *60 min/hr)/(453.6 gllb * 1 0\g/g) 

Maximum extrapolated feed rate 

= Maximum emission rate / (1 - SRE from performance test) 

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

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

To the extent possible (and with the exception of the spiked constituents noted above), only normal waste 

materials processed at the facility will be fed to the incinerator during the test program. Waste materials will be 

stockpiled to meet the objectives for the target test parameters. These wastes will be characterized in 

advance of the test and kept until needed. All waste materials will be delivered to the facility in accordance 

with routine operation and currently permitted procedures as described elsewhere in this document. 

4.7 Conditioning Time Needed to Reach Steady State [40 CFR 5 63.1207(f)(l)(xii)] 

The incinerator will be operated for 15 minutes at the desired feed rates and operating conditions before 

sampling begins for a given condition of the testing. This w~ll assure all operating parameters are stabilized at 

the desired settings to achieve steady state before sampling. 

4.8 Anticipated Test Schedule 

The performance test will be performed over a Cday period using a three-person field crew according to the 

schedule shown in Table 4-3. For this test program, it is anticipated that all runs will be approximately two 

hours in duration, as dictated by the sample run time required for metals measurements. The test program for 

this incinerator is planned to start on or after August 1. 2008. 

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4.9 Performance Test Reporting 

The final report will be prepared for submittal no later than 90 days from completion of the field test program. 

This document will provide a concise presentation of performance test results and will include all necessary 

supporting documentation. An example outline of the final test report is presented below: 

Section 1.0 Certification - Includes project title, statement of compliance and project approval 

signatures 

Section 2.0 Summary of Test Results -Summary of emission results compared to applicable 

standards; interim status operating limits; overview of process operating conditions; 

Section 3.0 Project Overview - Facility and unit description; project background and scope; test 

requirements; test chronology and report organization 

Section 4.0 MACT Notification of Compliance - Regulatory requirements; performance test results and 

compliance determination; area or major source determination; description of air pollution control system; 

and description of process monitoring systems 

Section 5.0 Process Operating Conditions - Overview of test conditions and summary of facility 

process monitoring data 

Section 6.0 Sampling and Analytical Program Overview - Summary of proposed plans and 

discussion of actual activities and any required deviations from plan 

Section 7.0 Test Results - Detailed presentation of waste analysis and stack sampling results including 

tabulated presentation of all data 

Section 8.0 Quality Assurance I Quality Control - Detailed discussion of waste and stack sampling 

and analytical QAIQC procedures and results 

APPENDICES 

A - Facility Process Monitoring Data 

B - Spiking Report 

C - Field Sampling Documentation 

D -Analytical Data Reports 

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Table 4-1 MACT OPLs to be Established During the Performance Test 

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Process Parameter 

Maximum Flue Gas Flowrate 

Maximum Low Volatile Metals 

(LVM) Feed Rate 

Maximum Total Pumpable 

LVM Feed Rate 

Maximum Semi-volatile Metals 

(SVM) Feed Rate 

Maximum Total Mercury Feed 

Rate 

Maximum ChlorineIChloride 

Feed Rate 

Maximum Fabric F~lter Inlet 

Temperature 

Units 

acfm 

Iblhr 

Iblhr 

Iblhr 

Iblhr. 

Iblhr 

" F 

Avg . 

Period 

I -hr 

12-hr 

12-hr 

12-hr 

12-hr 

12-hr 

'I-hr 

How Limit 

Established 

Average of maximum 

HRAs for each run 

Average of the 

average HRAs for 

each run 

Average of the 

average HRAs for 

each run 

Average of the 

average HRAs for 

each run 

Average of the test 

run averages 

Average of the test 

run averages 

Average of the test 

run averages 

Expected 

Limit 

14,500 - 17,000 

400 - 450 

400 - 450 

600 - 650 

0.01 - 0.02 

200 - 250 

390 - 425 
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Table 4-2 Metals Evaluation Plan 

Assumptions: 

Qs = stack gas flow rate = 

O2 = stack oxygen level = 

MACT Standards: 

SVM (Cd and Pb) = 

LVM (As, Be and Cr) = 

Mercury = 

5,838 dscfm 

12.0 % vol. 

* Surrogate metals to be spiked during the performance test 

Expected 

Metal SRE 

(") 

85% 

99 9999% 

99 9999% 

Expected 

Spiked 

Quantity 

(I blhr) 

0 001 - 0 002 

60 - 65 

40 - 45 

Metal 

Mercury 

SVM 

LVM 

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Historical Desired 

Feed Range Feed Rate 

(I blh r) Limit (Iblhr) 

0 07 0 01 - 0 02 

156 600 - 650 

206 400 - 450 

Projected Emission 

Rate at the Desired 

Feed Rate Limit 

(Iblhr) 

0 002 

0 002 

0 0005 

IJglm3 @ 

7% 02 

110 

46 

32 
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- 

Table 4-3 Anticipated Performance Test Schedule 

General Overview of Planned Schedule 

- - -- 

Example of Detailed Daily Schedule (Day 2 Above) 

Activity 

Mobilization, site safety training and set-up 

Preliminary traverses, Conduct Run 1 and Run 2 

Conduct Run 3 

Equipment removal and depart site 

Incinerator lined out on trial burn wastes 

Begin metal spiking 

Initiate all stack sampling and waste sampling 

Approx. end time for sampling runs 

Recovery of sampling train 15:OO - 16:30 

Depart Site 

Schedule 

Day 1 

Day 2 

Day 3 

Day 4 

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5.0 Sampling and Analytical Program Quality Assurance/Quality 

Control 

This section presents the Quality Assurance and Quality Control goals, objectives, and procedures for the 

MACT performance test program. The quality assurance/quality control procedures and criteria for this 

program will comply with the requirements of this document and its updates. The analytical work conducted 

will incorporate the WQC requirements of the approved methods. This document has been prepared using 

available guidance provided in the following EPA documents: 

"EPA Requirements for Quality Assurance Project Plans", EPA QNR-5, November 1999. 

"Component 2 - How to Review a Quality Assurance Project Plan (including Attachment A - Generic 

Trial Burn QAPP", Hazardous Waste Combustion Unit Permitting Manual, U.S. EPA Region 6, 

January 1998. 

"Handbook - Quality Assurance/Quality Control (WQC) Procedures for Hazardous Waste 

Incineration" (EPN62516-891023 January 1990). 

Quality Assurance Project Plan for Veolia's MACT Metals Performance Test for the Unit 2 Incinerator 

Facility ID Number: l LD098642424 

Prepared for: Veolia ES Technical Solutions, LLC, 7 Mob~le Avenue, Sauget, IL 62201 

Prepared by: ENSR Corporation, Westford, MA 01886 

Revision No.: 0 

Date: May 2008 

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5.1 Title Page 

5.1 .I Project Title 

Quality Assurance Project Plan for Veolia ES Technical Solutions HWC MACT Metals Performance Test Plan 

for the Unit 2 Fixed Hearth Incinerator. 

5.1.2 Expected Performance Test Date 

On or af&er August 1,2008. 

5.1.3 Project Approvals 

Veolia Project Manager 

ElVSR Project Iblanqger 

ENSR QA Officer 

Maxxam Analytics Lab Services Coordinator 

Date 

Date 

Date 

Date 

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5.2 Table of Contents 

A complete table of contents, including listings of tables and figures and acronyms is presented at the 

beginning of this Performance Test Plan and includes all pertinent information applicable to this QAPP section. 

5.3 Project Description 

This project will consist of a comprehensive sampling and analysis program designed to demonstrate 

compliance with the HWC MACT rule requirements. Testing will be performed under one process operating 

condition, entailing triplicate sampling runs. Operating parameter limits (OPLs) associated with metals 

emissions testing will be re-established or modified based on the results of the program. The reader is 

referred to Sections 1.3, 1.4, 2.5.3 and 4.0 for further details on program scope, test objectives and target 

parameters for emission measurements and process monitoring. The remainder of this section outlines the 

detailed measures that will be followed to ensure collection of valid data. A brief overview of the 

measurements to be made during the test program is provided in Table 5-1. A more detailed summary of the 

sampling and analytical program is provided later in Section 5.6. 

5.4 Project Organization 

The ENSR Project Manager, Mr. Jeffrey Gorman will be responsible for the overall direction of this program 

and will report to the Veolia Project Manager, Mr. David Klarich. Mr. Gorman w~ll be responsible for project 

design and implementation, communicating with the client, scheduling all activities, reviewing all project data 

and preparing all reports He will be assisted in the oversight of Quality Assurance activities by the program 

Quality Assurance Officer (QAO) and each Analytical Laboratory Services Coordinator (LSC). Each contract 

laboratory will have one individual designated as the person responsible for project activities. 

5.4.1 QA Officer's Responsibilities 

Mr. Craig Doolittle will serve as the project Quality Assurance Officer (QAO) and will be responsible for review 

and approval of the Quality Assurance Project Plan presented in this section, as well as any subsequent 

revisions. He will monitor implementation of field and laboratory activities, scheduling performance and/or 

system audits as warranted. The QAO will report to the Project Manager on any conditions noted which may 

adversely affect data quality. 

Mr. Doolittle will provide independent oversight for data verification and data quality assessment activities. He 

will prepare a section for the Final Report summarizing QAJQC activities and provide an overall evaluation of 

data quality. 

5.4.2 Laboratory Coordinator Responsibilities 

Each analytical laboratory will designate a Laboratory Services Coordinator (LSC), who will be the principal 

point of contact for the ENSR Project Manager. The LSC will review QA requirements with all laboratory staff 

to ensure that all required measures are taken to meet data quality objectives. They will monitor the shipment 

and receipt of samples, track analytical progress and review data as reported from the laboratories for 

completeness. Each LSC will be responsible for validation of all data generated by the laboratory for this 

program and will provide all necessary documentation for inclusion in the final report. 

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5.5 QAIQC Program Objectives 

5.5.1 Precision, Accuracy and Completeness 

The collection of data to fully characterize the incinerator waste feed materials and stack gas emissions 

requires that sampling and analysis procedures be conducted with properly operated and calibrated equipment 

by trained personnel. QA objectives for measurements made in the field are summarized in Table 5-2. QA 

objectives specific to each analytical methodology performed by the subcontractor laboratories are presented 

later in Section 5.9. The overall program has been designed with consideration of sampling parameters and 

analytical limits to ensure that the achieved MDLs for emissions will be more than adequate for regulatory limit 

decisions. Critical MDL determinations are addressed subsequently in Section 5.5.3. 

Precision is defined as a measurement of mutual agreement among individual measurements made under 

prescribed similar conditions. Precision is expressed in terms of relative percent difference (RPD) between 

duplicate determinations and in terms of relative standard deviation (RSD) when 3 or more determinations are 

made. Overall precision for analysis of the waste feed streams will be assessed through the analysis of one 

set of duplicate samples for each designated parameter. 

Accuracy is the degree of agreement of a measurement with an accepted reference or true value. Analytical 

accuracy will be measured through the recoveries of matrix spikes, analysis of standard reference materials or 

audit sample analysis. Matrix spike samples for the waste feed will be prepared by spiking known amounts of 

target analytes into a portion of the sample recoveries are monitored to assess laboratory and method 

accuracy. Laboratory control samples (LCS) will also be used to distinguish between method performance 

and matrix effects on accuracy. LCS and MS spiking solutions will be independent from calibration standards. 

Completeness is a measure of the amount of valid data obtained compared to the amount that was expected 

under normal conditions. The overall program objective is to obtain valid data for three (3) runs for each test 

condition. For all data considered critical to the investigation, a completeness objective of 100% has been 

established. As a result, critical priority data from each of three (3) runs should achieve the precision and 

accuracy goals established herein. This completeness criterion applies to all permit parameters in emissions 

samples as well as feed/process stream samples. Individual samples for which the critical data points do not 

achieve accuracy and/or precision data quality objectives may require reanalysis. Results for samples where 

matrix interferences preclude meeting objectives for the recoveries of surrogates or spikes will be evaluated for 

potential bias to calculated emission results. In summary, the completeness goals are stated at 100%, since 

three valid runs are necessary to assess operation at any one condition. 

5.5.2 Representativeness and Comparability 

It is recognized that the usefulness of the data is also contingent upon meeting the criteria for 

representativeness and comparability. Wherever possible, reference methods and standard sampling 

procedures will be used. The QA objective is that all measurements be representative of the matrix and 

operation being evaluated. The detailed requirements for sampling given in the various EPA Reference 

Methods will be followed to ensure representative sampling of flue gases. The sampling of incinerator feed 

streams prior to the performance test will provide representative samples of these matrices. 

The corresponding QA objective is that all data resulting from sampling and analysis be comparable with other 

representative measurements made by the performance test field team, on this or a similar process operating 

under similar conditions. The use of published sampling and analytical methods and standard reporting units 

will aid in ensuring the comparability of the data. 

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5.5.3 Method Detection Limit (MDL) Determinations 

Method Detection Limits (MDLs) for the various analytes to be measured in this program will be determined 

following well-establ~shed laboratory procedures in accordance with standard EPA protocols. These are 

described below for those parameters deemed most crucial to the program. 

5.5.3.1 Metals - Methods 6020 and 7470A 

Reporting limits for all metals are determined based on the results of the latest MDL studies performed for 

each metal. For this program, the MDL for non-detect values will be determined by low-level replicate spiking 

of aliquots of the samples submitted. The reporting limit for non-detectable metals is a chosen whole number 

above the MDL, usually in the range of 1.5-2 times the MDL value. 

5.6 Sampling and Monitoring Procedures 

This section describes the procedures that will be followed during the field sampling program. Throughout the 

overall program, all sampling w~ll be performed using sampling protocols described herein and approved by 

EPA. Regulatory agency approval will be obtained for any deviations from or changes to the approved 

Performance Test Plan which may be warranted prior to program implementation as a result of changes in 

personnel or facility circumstances If situations occur during the demonstration testing which necessitate 

deviations from the plan, the agency will be notified and onsite approval requested. Any deviations from the 

specified protocols w~ll be fully documented in the final Performance Test Report. 

5.6.1 Field Program Description 

A detailed description of the compliance strategy and test conditions was provided previously in Section 4.0. 

In general, however, the program is presently configured to collect samples during three runs for a single 

process operating condition. Table 5-3 provides a detailed listing of the sampling and analytical parameters 

and methods planned for this program. All sampling will be conducted concurrently at the outlet stack location. 

5.6.2 Pre-Sampling Activities 

Pre-sampling activities include equipment calibration, sample media preparation, cleaning of sample train 

glassware, preparation of computer-generated sample labels, and other miscellaneous tasks. Each of these 

activities are described or referenced in the following subsections. Other pre-sampling activities include such 

details as team meetings, equipment packing and shipment, equipment setup, and finalization of all details 

leading up to the coordinated initiation of the sampling program. 

5.6.2.1 Equipment Calibration 

A most important aspect of pre-sampling preparations is the inspection and calibration of all equipment 

planned to be used for the field effort. Equipment is inspected for proper operation and durability prior to 

calibration. Calibration of equipment is conducted in accordance with the procedures outlined in the EPA 

document entitled "Quality Assurance Handbook for Air Pollution Measurement Systems; Volume IIIStationary Source Specific Methods" (EPA-60014-77-027b). Equipment calibration is performed in accordance 

with EPA guidelines and/or manufacturer's recommendations. Documentation of all calibration records will be 

kept in the project file during the field program and will be available for inspection by test observers. Examples 

of field equipment used and typical calibration requirements follows: 

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Probe nozzles (QA Handbook Section 3.4.2, pg. 19) - make three measurements of the nozzle ID (to 

the nearest 0,001 in.) using different diameters with a micrometer. Difference between the high and 

low values should not exceed 0.004 in. Post-test check - inspect for damage. 

Pitot tubes (QA Handbook Section 3.1.2, pp. 1-13) - measured for appropriate spacing and 

dimensions or calibrate in a wind tunnel. Rejection criteria given on the calibration sheet. Post-test 

check - inspect for damage. 

a Thermocouples (QA Handbook Section 3.4.2, pp. 15-18) - verify against a mercury-in-glass 

thermometer at two or more points including the anticipated measurement range. Acceptance limits - 

impinger k2"F; DGM +5.4"F; stack +I .5 percent of stack temperature. 

Dry gas meters (QA Handbook Section 3.4.2, pp. 1-12) - calibrate against a wet test meter 

Acceptance criteria - pretest Yi = Y & 0.02; post test Y = + 0.05 Yi. 

a Field barometer (QA Handbook Section 3.4.2, pp. 18-19) - compare against a mercury-in-glass 

barometer or use Airport Station BP and correct for elevation. Acceptance criteria - * 0.02 in. Hg; 

post-test check - same. 

5.6.2.2 Glassware Preparation 

Sample train glassware and sample containers require specialized pre-cleaning to avoid contamination of the 

sample from the collection container or devices. Cleaninglstorage procedures for sample train glassware are 

summarized below. Note that all bottle caps are fitted with teflon liners which are cleaned in the same manner 

as the bottles themselves. Sample containers used for waste feed streams are purchased pre-cleaned and 

sealed to specified EPA protocols. 

EPA Method 29 glassware and containers (metals) -wash with soap and water, rinse with hot tap 

water, rinse three times with reagent water. The glassware is next soaked in a 10% nitric acid solution 

for a minimum of 4-hours, rinsed three times with reagent water, rinsed a final time with acetone and 

air dried. All glassware openings where contamination can occur will be covered until the sampling 

train is assembled prior to sampling. 

5.6.2.3 Sample Media Preparation 

All reagents will be checked in accordance with ENSR's existing QC Program to minimize the probability of 

using contaminated solvents. This includes the use of the proper grade reagentslsolvents as specified in the 

test method, selection of reagents from the same lot and the collection and analysis of the appropriate blanks. 

Sampling media will be procured and prepared in accordance with the appropriate test methods as described 

below: 

Quartz filters used in the Method 29 sampling train are-purchased from Pallflex Products Co. who 

pre-screen filters for metals content. 

5.6.2.4 Other Pre-Sampling Activities 

Sample team meetings will be held to designate responsibilities to each team member. Assignments will be 

based on individual experience and relative importance of the assigned task. Other pre-sampling activities in 

the office will include generation of sample checklists, printing of computer-generated sample labels, and 

P"" proper packing of all equipment. Equipment will then be transported by fre~ght or truck to the sampling 

location. 

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Site setup is the final pre-sampling activity. This task will involve moving the equipment to the vicinity of the 

sample collection area. A separate office trailer or other suitable onsite facility will be used to serve as a 

sample train setup and recovery area and sample custody area. 

Normally, preliminary tests are conducted at the stack location to verify the presence or absence of cyclonic 

flow conditions and to determine flue gas moisture, temperature and velocity. These measurements facilitate 

determination of nozzle size selection and sample train operation rates for the isokinetic sampling trains. 

5.6.3 Sampling Locations 

5.6.3.1 Waste Feed Streams 

Waste feed materials will be sampled in accordance with the facility's feed stream analysis plan (FSAP) and 

RCRA Waste Analysis Plan (WAP). Waste feed sampling will occur upstream of any metal spiking location. 

Samples will be collected using methodologies described in the FSAP and WAP. 

5.6.3.2 Stack Sampling Location 

Sample test ports in the circular 39-inch inside diameter (ID) stack are located 32 feet (9.85 diameters) 

downstream of the induced-draft fan and 49 feet (15.1 diameters) upstream of the stack exit to atmosphere. In 

accordance with EPA Method 1, a 12-point traverse will be performed during testing. One test port level will 

be used to accommodate simultaneous testing of all emissions test parameters. Figure 5-1 provides a 

schematic of the stack showing the location of the sampling ports. Actual traverse point locations and 

upstream/downstream distances from flow disturbances are shown in Table 5-4. 

5.6.4 Waste Feed Stream Sampling Procedures 

Each waste feed material fed during the test will be sampled from taps in the feed lines or other appropriate 

locations, upstream of any metal spiking location. During the testing each waste feed material will be sampled 

at the start of each run, at port change, and at the completion of each run. After testing is completed, the three 

samples that were collected will be composited and analyses will be performed on this composite sample. The 

feed streams will be characterized for ash, heat content, metals (arsenic, beryllium, chromium, cadmium, lead, 

and mercury) and total chlorine. Veolia will be responsible for all waste feed analyses. 

5.6.5 Stack Sampling Methodologies 

Gases discharged from the exhaust stack will be sampled by ENSR for the following parameters: 

Flue gas velocity, flow rate, temperature, moisture content and fixed gas (02 and C02) composition; 

MACT Metals -arsenic, beryllium, cadmium, chromium, lead and mercury; 

The following sections provide summaries of the sampling methodologies to be followed. In addition, sample 

field data sheets to be used during the program are provided in Appendix B. Summaries of relevant 

information pertaining to setup and recovery of the EPA Method 29 sampling train are provided in 

Appendix C. 

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5.6.5.1 Gas Stream Velocity, Moisture and Fixed Gases 

Gas stream flowrate, moisture and fixed gas concentration will be determined concurrent with the EPA 

Method 29 isokinetic sampling train. Gas stream velocity will be determined using a pitot tube and water 

manometer in accordance with EPA Method 2. Gas stream temperature will also be determined at each of the 

Method 2 traverse points using a Type "K thermocouple and pyrometer. Gas stream moisture will be will be 

determined as specified in EPA Method 4 concurrent with the EPA Method 29 isokinetic sampling train. In this 

procedure the impinger contents are measured or weighed before and after each test run and used in 

conjunction with the metered gas volume to determine the gas stream moisture content. Fixed gases (02 and 

C02) for gas stream molecular weight determination and constituent oxygen correction will be determined in 

accordance with EPA Method 3 (Orsat procedure) during each test run. 

5.6.5.2 Metals 

EPA Method 29 will be utilized for the collection of MACT and other metals including: 

MACT LVM metals - arsenic, beryllium and chromium; 

MACT SVM metals -cadmium and lead; and 

Mercury. 

Specific sampling details for the Method 29 sampling train are as follows: 

Target sampling rate - 0.75 dm 

Sample run time - 2-hr 

Number of sampling points per stack traverse - 6 

Total number of sampling points - 12 

Number of field reagent blank sets collected - I 

5.6.5.3 Continuous Emission Monitoring 

EWSR will provide measurement of oxygen (02) and carbon dioxide (COz) throughout all test run periods. 

These parameters will be measured using the procedures specified in 40 CFR 60, Appendix A, Method 3 

(Orsat analysis). 

Veolia will provide continuous emission monitoring for carbon monoxide (CO) during all three test runs in 

accordance with the facility's Quality Assurance Plan for their CEMs. 

5.7 Sample Handling, Traceability and Holding Times 

Sample integrity will be maintained throughout all phases of the sampling and analysis program. Samples will 

be held within sight of the samplers or sample custodian, or will be kept in sealed or secured containers at all 

times. Sealed coolers and DOT shipping boxes will be used to ship samples to the designated laboratory via 

Priority 1 overnight FedEx service. 

Preprinted sample identification labels are used by ENSR to ensure that all required information is fully 

documented. When sample batches are shipped to the specified laboratory, a sample packing list (see 

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Figure 5-2) accompanies the shipment. This form is based on established laboratory format and will be used 

to document sample transfer in the field and from sampling personnel to the laboratory. 

The ENSR Field Team Leader will coordinate the packing and shipment of all samples. Worksheets 

specifically designed for this program will be generated prior to the field effort These sheets will assist the 

Field Team Leader in assuring that all samples have been collected, accounted for and shipped under sample 

traceability documentation to the appropriate laboratory. Requirements pertaining to sample preservation and 

recommended holding times are noted in Table 5-5. All materials such as f~eld and laboratory notebooks and 

logbooks, field and laboratory data records, correspondence, reports, sample tags, traceability records and 

instrument printouts will be clearly labeled with the project number and become a permanent part of the project 

file. Project samples will be disposed of in an appropriate manner 60 days after acceptance and approval of a 

final report. All project-related documentation at the subcontractor laboratory will be kept on flle for 2 years 

following submittal of the final report. 

5.8 Analytical Methods and Calibration Procedures 

This section delineates the analytical protocols that will be used to analyze samples during this performance 

test. Samples of waste feed materials and stack gas will be collected and analyzed for the parameters 

previously discussed using the appropriate laboratory protocols detailed in this section and as outlined 

previously in Table 5-3. 

5.8.1 Analysis of Waste Feed Streams 

5.8.1 .I Chemical and Physical Properties of Waste Feed Streams 

Analyses to determine the chemical and physical properties of the waste feed materials will be performed 

using appropriate ASTM or EPA SW-846 analytical methods as outlined in the Veolia FSAP and WAP. For 

any analytical results that are "non-detect", Veolia will utilize % of the detection limit for that parameter in any 

calculation of feed rates. 

5.8.2 Analysis of Stack Gas Samples 

5.8.2.1 Metals in Stack Gas Samples 

Analysis - Each sampling train will be prepared and analyzed in accordance with EPA Reference Method 29. 

From each sampling train, seven individual samples are generated for analysis. The first two samples, labeled 

Fractions 1A and 1 B consists of the digested sample from the front half of the train, consisting of the 

particulate filter and the front-half nitric acid probe rinse. Fraction 1A is for ICP analysis and Fraction 1 B is for 

mercury analysis. Fractions 2A and 2B consist of digestates from the moisture knock out and HN03/H202 

impingers 1, 2, and 3. Fraction 2A is for ICP analysis and Fraction 2B is for mercury analysis. Fractions 3A. 

3B and 3C consist of the impinger contents and rinses from the empty and permanganate impingers 4, 5, 

and 6. These fractions will be analyzed for mercury. 

Analyses for metals other than mercury will be performed using Inductively Coupled Plasma Mass 

Spectroscopy (ICP-MS) as described in EPA Method 6020 (SW-846.3rd Edition). Mercury analysis will be 

performed using EPA Methods 7470A or 7471A (SW-846,3rd Edition). 

All quality control procedures, including the interference check standard, will be followed as described in the 

respective method. 

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Calibration - Calibration of the ICAP will be performed dally in accordance with the procedures described in 

Method 6020 and the manufacturer's instructions. The calibration is verified daily by analysis of an instrument 

check standard prepared from an EPA quality control concentrate or other independent standard. 

QAIQC requirements for the analysis of metals in stack gas samples are summarized in Table 5-6. 

5.9 Internal QA Program 

Quality control checks will be performed to ensure the collection of representative samples and the generation 

of valid analytical results for these samples. These checks wilt be performed by project participants throughout 

the program under the direction of the Project Manager and the QA Officer. 

5.9.1 Data Collection and Sampling QC Procedures 

QC checks for the process data collection and sampling aspects of this program will include, but not be limited 

to, the following: 

1. Use of standardized data sheets, checklists and field notebooks to ensure completeness, traceability, and 

comparability of the process information and samples collected. 

2. Field checking of standardized forms by the Field Team Leader and a second person to ensure accuracy 

and completeness. 

3. Strict adherence to the sample traceability procedures. 

4. Submission of field biased blanks. 

5. Leak checks of sample trains before and after sample collection and during the test, when appropriate. 

5.9.1.1 Sampling Equipment QC Checks and Frequency 

Calibration of the field sampling equipment will be performed prior to and at the conclusion of the field 

sampling effort. Copies of the calibration sheets will be available onsite during the field sampling program for 

inspection, will be kept in the project file and will be submitted in the final report. Calibrations will be performed 

as described in the EPA publication "Quality Assurance Handbook for Air Pollution Measurement Systems, 

Volume Ill, Stationary Source Specific Methods;" Section 4.2.1 presents acceptance limits. 

Leak checks of the sample trains will be conducted in accordance with the protocol called out for each method. 

Leak checks will be conducted prior to and at the end of sample collection and during the test run, when 

appropriate. 

5.9.1.2 Sample Collection QC Checks 

Field-biased blanks of reagents and collection media (deionized water, filters, impinger solutions, etc.) will be 

placed in appropriately cleaned and sized sample containers in the field and handled in the same way as 

actual field samples, to provide a QC check on sample handling. 

For this program, sample collection QC checks and frequency for samples to be analyzed in the laboratory are 

listed below: 

One field reagent blank Method 29 sampling train. 

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5.9.2 Analytical QC Procedures for Samples to be Analyzed in the Laboratory 

The Quality Control program for laboratory analysis makes use of a number of different types of QC samples 

to document the validity of the generated data. The following types of QC samples will be used during the 

program. 

5.9.2.1 Quality Control Samples and Blanks 

Method Blanks 

Method blanks contain all the reagents used in the preparation and analysis of samples and are processed 

through the entire analytical scheme to assess spurious contamination arising from reagents, glassware, and 

other materials used in the analysis. 

Calibration Check Samples 

One of the working calibration standards which is periodically used to check that the original calibration is still 

valid. 

Laboratorv Control Samples (LCS) or Blank Spikes 

These samples are generated from spikes prepared independently from the calibration concentrates. The 

LCS are used to establish that an instrument or procedure is in control An LCS is normally carried through 

the entire sample preparation and analysis procedure also. 

Reagents used in the laboratory are normally of analytical reagent grade or higher purity; each lot of acid or 

solvent used is checked for acceptab~lity prior to laboratory use. All reagents are labeled with the date 

received and date opened. The quality of the laboratory deionized water is routinely checked. All glassware 

used in the sampling and analysis procedures will be pre-cleaned according to the method requirements. 

Standard laboratory practices for laboratory cleanliness, personnel training and other general procedures are 

used. The results of these quality control procedures will be included in the final report. 

5.1 0 Data Reduction, Verification and Data Reporting 

Specific QC measures will be used to ensure the generation of reliable data from sampling and analysis 

activities. Proper collection and organization of accurate information followed by clear and concise reporting of 

the data is a primary goal in all such projects. 

5.1 0.1 Field Data Reduction 

Appendix B of this Performance Test Plan presents the standardized forms that w~ll be used to record field 

sampling data. The Field Team Leader and at least one other field crewmember will review the data collected 

from each train in its entirety in the field. Errors or discrepancies will be noted and dealt with accordingly. The 

Field Team Leader has the authority to institute correction actions in the field. The QA officer will also be 

notified for resolution if the situation warrants. At a minimum, the QA officer is apprised of all deviations from 

standard protocol. Field data reduction (checking of valid isokinetic sampling rate and other sampling 

parameters) is done with a laptop computer using standardized Excel spreadsheets. Appendix C provides 

sample train setup and recovery schematics and a description of solutions and reagents to be used in each 

isokinetic train required for the overall program. All sample recovery sheets will be checked for completeness. 

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5.10.2 Laboratory Analysis Data Reduction 

Analytical results will be reduced to appropriate units by the laboratory using the equations given in the 

applicable analytical method. Unless otherwise specified, results from the analysis of waste feed and process 

samples for specific target constituents will be reported in units of mglkg or % wt. Other parameters will be 

reported In standard units such as glcc, Btullb, etc. 

The laboratory typically reports results from the analysis of stack flue gas samples as total mass detected for 

the sample submitted. For those sample fractions where liquid impinger condensate is analyzed, the 

laboratory will measure the total liquid volume submitted and multiply by the measured concentrations of target 

analytes in these samples. The laboratories will generally report data as follows: 

All metals except mercury -total pg of each metal in the combined front-half and back-half sample 

train fractions 

Mercury -total pg in each sample train fraction 

Each LSC will be responsible for reviewing all results and calculations and verifying the completeness of the 

data set. The laboratory reports submitted by each laboratory will include the following deliverables: 

Transmittal letter listing all samples and analyses and a case narrative identifying any difficulties 

associated with the analyses and any anomalous QAlQC results 

Copies of Chain of Custody Forms 

Sample Report forms with sample field and laboratory identifier, dates of sample preparation and 

analysis, analytical results and detection limits 

Method Blank results 

Matrix spike and matrix spike duplicate results (as applicable) 

Replicate sample analyses (as applicable) 

Laboratory Control Sample results 

5.1 0.3 Data Verification 

Data verification is the process of reviewing data and accepting, qualifying or rejecting it on the basis of 

method-specific criteria. The independent project QAO will use validation methods and criteria appropriate to 

the type of data and the purpose of the measurement Records of all data will be maintained, even that judged 

to be an "outlying" or spurious value. 

Field sampling data will be validated by the Field Team Leader based on a judgment of the representativeness 

of the sample, maintenance and cleanliness of sampling equipment and the adherence to an approved, written 

sample collection procedure. 

Analytical data will be validated by the subcontractor laboratory QC or supervisory personnel using criteria 

outlined in their laboratory-specific QA Plan andlor written SOPS. Results from field and laboratory method 

blanks, replicate samples and internal QC samples will be used to further validate analytical results. Analytical 

results on field blanks and replicate field samples are valuable for validation of sample collection also. QC 

personnel will review all subcontractor laboratory raw analytical data to verify calculated results presented. 

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'The following criteria will be used to evaluate the field sampling data: 

Use of approved test procedures 

Proper operation of the process being tested 

Use of properly operating and calibrated equipment 

Leak checks conducted before and after tests 

Use of reagents that have conformed to QC specified criteria 

Use of NBS traceable CEM calibration gases (as applicable) 

Proper chain-of-custody maintained 

All sample trains -check to ensure proper sample gas volume collected 

The criteria listed below will be used to evaluate the analytical data: 

Use of approved analytical procedures 

Use of properly operating and calibrated instrumentation 

Precision and accuracy achieved should be comparable to that achieved in previous analytical 

programs and consistent with objectives stated in this document. 

5.10.4 Final Data Reporting 

Stack gas concentrations for each applicable parameter will be calculated from laboratory results and field 

sampling data. The total weight of the analyte detected will be divided by the volume of gas sampled to 

provide emission concentrations. For MACT compliance, all emission concentrations are further corrected to 

7% oxygen for comparison to the published standards. 

A complete Final Report outlining the goals, methods and results for the program will be prepared and any 

deviations from this test plan will be documented. The Final Report will include a section on evaluation and 

discussion of QAIQC results. Results will be compared to expected limits for accuracy, precision and/or 

completeness as targeted in this protocol. The final test report will also include the results of any internal 

audits conducted on the program as well as: 

All field data sheets showing sampling method, dates, run times, personnel, equipment; sample 

preservation, identification and compositing records. 

r Field equipment calibration data. 

Analytical lab reports and relevant supporting documentation. 

5.1 I Routine Maintenance Procedures and Schedules 

This section provides pertinent information for field sampling equipment as well as a listing of all critical facility 

equipment necessary to maintain permitted operating conditions and to demonstrate continuing permit 

compliance. Information is provided for preventive maintenance and schedules and spare parts for key 

equipment and instrumentation. 

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5.1 1 .I Field Sampling Equipment 

The field team follows an orderly program of positive actions to prevent the failure of equipment or instruments 

during use. 'This preventive maintenance and careful calibration helps to ensure accurate measurements and 

minimal field delays. 

All equipment that is scheduled for field use is calibrated as outlined previously in Section 5.6.2.1. Prior to 

each field use for a specific project, the equipment is cleaned and checked to ensure it is in good working 

order. An adequate supply of spare parts and sample train glassware is brought to each site to minimize 

downtime and field sampling delays. Any equipment that does experience problems is appropriately tagged in 

the field to ensure that it is repaired upon return to the office. 

5.1 1.2 Facility Equipment and Instrumentation 

As stated in Sections V.a.F. and V.b.F. of Veolia's Part B RCRA Permit, each ~ncinerator system undergoes a 

"thorough visual inspection for leaks, spills, fugitive emissions, and sign of tampering at least daily and in 

accordance with the inspection schedule contained in Appendix 6 of the approved permit application". Veolia 

utilizes these inspections and additional preventive maintenance activities as proactive measures for 

minimizing the potential for malfunctions. To facilitate proper maintenance, a cold shutdown will occur at least 

once per year for each incinerator system. 

Routine inspection and maintenance activities are scheduled, communicated, and recorded through the use of 

field checklists. Parts of the incinerator systems that are subject to wear (e.g., bearings, O-rings, airloil filters) 

are replaced based on the schedules indicated on these checklists. These field checklists will also be used to 

document repairs or replacements of incinerator components that may be revealed during inspections. Brief 

procedureslinstruct~ons for inspection and maintenance activities are provided on field checklists. 

Continuous monitoring system components are comprised of many instruments including scales, flowmeters, 

thermocouples, pressure transmitters, differential pressure cells, bag leak detectors, and limit switches. All 

components critical for monitoring permitted parameters are audited either on a quarterly or annual basis to 

ensure proper operation. Daily calibration checks are performed on the Unit's CEM's. 

5.12 QAIQCAssessrnent Procedures 

The QA activities implemented in this program will provide a basis for assessing the accuracy and precision of 

the analytical measurements. Section 5.8 of this QAPP discusses the QA activity that will generate the 

accuracy and precision data for each sample type. A generalized form of the equations that will be used to 

calculate accuracy, precision and completeness follows. 

5.12.1 Accuracy 

Percent accuracy will be determined using the following equation: 

% Recovery = (X-S) xl00 

T 

where: 

X = experimentally determined concentration of the spiked sample 

T = true concentration of the spike 

S = sample concentration before spiking 

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5.1 2.2 Precision 

Precision (calculated as percent relative difference) will be determined using the following equation: 

where: 

Dl and D2 = results of duplicate measurements or standard deviation relative to the average value 

expressed as relative standard deviation: 

Relative standard deviation will be expressed as follows: 

Relative Standard Deviation (% RSD) = 

(X (XI .. x,,' 

where: 

o = standard deviation of the sample data 

n = number of replicates 

x~,~.,~~ = arithmetic mean of the sample data 

5.1 2.3 Completeness 

Data completeness is a measure of the extent to which the database resulting from a measurement effort 

fulfills objectives for the amount of data required. For this program, completeness will be defined as the 

percentage of valid data for the total valid tests. Completeness is assessed using the follow~ng equation: 

where: 

Dr = number of samples for which valid results are reported 

Dc = number of valid samples that are collected and reach the laboratory for analysis 

The completeness objective will help to evaluate the accuracy and precision of the analytical measurements. 

5.13 External QA Program 

The External Quality Assurance Program includes both performance and system audits as independent 

checks on the quality of data obtained from sampling, analysis, and data gathering activities. Every effort is 

made to have the audit assess the measurement process in normal operation. Either type of audit may show 

the need for corrective action. 

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5.13.1 Performance Audits 

The sampling, analysis, and data handling segments of a project are checked in performance audits. A 

different operatorlanalyst prepares and conducts these audit operations to ensure the independence of the 

quantitative results. 

EPA Quality Control concentrates or other standards will be used to assess the analytical work. Results will 

be reviewed by the subcontractor laboratory and QC personnel. Any additional audit samples presented by 

the regulatory agencies will be analyzed along with program samples, by the appropriate lab and at the same 

time as all other samples. It will, however, be the responsibility of the regulatory agency to obtain these 

samples, and present them to the fac~lity project manager in a form that is amenable and appropriate to the 

analytical methods being utilized. 

If the regulatory agency advises facility program manager that audit results fall outside of acceptable ranges, 

the analytical data will be further reviewed for error in conjunction with the agency. If a simple, correctable 

error is found (e.g., an arithmetic error), correction will be made and results resubmitted. If no error is found, 

an investigation into other causes of the failure (e.g., lack of sample integrity) will be conducted and results 

evaluated in terms of the impact on sample data integrity. 

5.1 3.2 Corrective Action 

The acceptance limits for the sampling and analyses to be conducted in this program will be those stated in 

the method or defined by the project manager. The corrective actions are likely to be immediate in nature and 

most often will be implemented by the analyst or Project Manager; the corrective action will usually involve 

recalculation, reanalysis, or repeating a sample run. Ongoing corrective action policy is described here. 

5.13.2.1 Immediate Corrective Action 

Specific QC procedures and checklists are designed to help analysts detect the need for corrective action. 

Often the person's experience will be more valuable in alerting the operator to suspicious data or 

malfunctioning equipment. 

If a corrective action can be taken at this point, as part of normal operat~ng procedures, the collection of poor 

quality data can be avoided. Instrument and equipment malfunctions are amenable to this type of action and 

QC procedures include troubleshooting guides and corrective action suggestions. The actions taken should 

be noted in field or laboratory notebooks but no other formal documentation is required, unless further 

corrective action is necessary. These on-the-spot corrective actions are an everyday part of the QAIQC 

system. 

Corrective action during the field sampling portion of a program is most often a result of equipment failure or 

an operator oversight and may require repeating a run When equipment is discovered to be defective (i.e., 

pre- and post-sampling leak check) it is repaired or replaced and a correction factor is established as per the 

EPA method. If a correction factor is unacceptable the run is repeated. Operator oversight is best avoided by 

having field crew members audit each other's work before and after a test. Every effort is made by the field 

team leader to ensure that all QC procedures are followed. Economically, it is preferred to repeat a run during 

a particular field trip rather than return at a later date. 

Corrective action for analytical work would include re-calibration of instruments, reanalysis of known QC 

samples and, if necessary, of actual field samples. 

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If the problem is not solved in this way, more formalized long-term corrective action may be necessary. 

5.1 3.2.2 Long-Term Corrective Action 

The need for this action may be identified by standard QC procedures, control charts, performance or system 

audits. Any quality problem which cannot be solved by immediate corrective action falls into the long-term 

category. The condition is reported to a person respons~ble for correcting it who is part of the closed-loop 

action and follow-up plan. 

The essential steps in the closed-loop corrective action system are: 

Identify and define the problem. 

Assign responsibility for investigating the problem. 

Investigate and determine the cause of the problem. 

Determine a corrective action to eliminate the problem. 

Assign and accept responsibility for implementing the corrective action. 

Establish effectiveness of the corrective action and implement it. 

Verify that the corrective action has eliminated the problem. 

Documentation of the problem is important to the system. A Corrective Action Request Form is filled out by 

the person finding the quality problem. This form identifies the problem, possible causes and the person 

responsible for action on the problem. The responsible person may be an analyst, field team leader, 

department QC coordinator or the QA Director. If no person is identified as responsible for action, the QA 

Director investigates the situation and determines who is responsible in each case. 

The Corrective Action Request Form includes a description of the corrective action planned and the date it was 

taken, and space for follow-up. The QA Director checks to be sure that initial action has been taken and 

appears effective and, at an appropriate later date, checks again to see if the problem has been fully solved. 

The QA Director receives a copy of all Corrective Action Forms and then enters them in the Corrective Action 

Log. This permanent record aids the QA Director in follow-up and makes any quality problems visible to 

management; the log may also prove valuable in listing a similar problem and its solution. 

5.13.3 Quality Assurance Reports to Management 

5.1 3.3.1 Internal Reports 

The Laboratory Services Coordinator will prepare a written report on QC activities associated with this project 

for the Quality Assurance Director. This report will detail the results of quality control procedures, problems 

encountered and any corrective action, which may have been required. 

All Corrective Action Forms are submitted to the QA Officer for initial approval of the corrective action planned 

and a copy is provided to the Program Manager. All system audit reports are provided to the Program 

Manager and the Quality Assurance Officer. 

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5.13.3.2 Reports to Client 

The final report will include a section summarizing QNQC activities during the program The Project Manager, 

Laboratory Services Coordinators and the QA Officer will participate in preparing this section. This section will 

provide summary QNQC results for method blanks, and laboratory control spike recoveries. This section will 

evaluate overall data quality in terms of accuracy, precision and completeness. Any discrepancies or 

difficulties noted in program work, protocol deviations or documentation gaps will be identified and discussed 

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

Parameter 

MACT Emission 1 ~imits(a) I Sampling Method I Analytical Method 

I - 

Flow, Fixed Gases and 

Moisture 

N/A EPA Methods 2, 3 

land 4 

N/A 

130 pg/dscm lEPA Method 29 

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EPA Method 7471 

CVAAS I 

LVM Metals 

(As, Be and Cr) 

SVM Metals 

(Cd and Pb) 

92 pg/dscm 

230 pgldscm 

EPA Method 29 

EPA Method 29 

EPA Method 6020 

ICP-MS 

EPA Method 6020 

ICP-MS 
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Table 5-2 QA Objectives for Field Measurements 

Field Measurement Accuracy Precision Completeness 

Moisture (EPA Method 4) 

Carbon Dioxide (EPA Method 3 - Orsat Analysis) 

Oxygen (EPA Method 3 - Orsat Analysis) 

(a) Not determinable. 

(b) An accuracy oft 0.2% would be expected if a certified gas audit is performed. Otherwise 

individual readings must be within 0.3 gig-mole of the mean value for three (replicate) readings. 

(c) An accuracy of 20.8% It 0.5% would be expected if an ambient air audit is performed. 

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Table 5-3 Overall Summary of Performance Test Stack Gas Sampling and Analysis Program 

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Sample Matrix and 

Sampling Method 

EPA M 29 

EPA M 3 

Facili ty CEM 

(a) MAX = Maxxam Analytical, Burlington, Ontarlo 

Veol~a = Veolia ES Techn~cal Solutions 

(b) Target metals ~nclude :anenlc, beryllium, cadm~um, chromium, lead and mercury 

Analytical 

--------- Method 

EPA M 601 OB/6020/7000 

EPA M 3 (Orsat) 

Facility CEM QA Plan 

Analytical 

Parameters 

Metals (b) 

02 and COa 

O2 and CO 

Lab 

(a) 

MAX 

ENSR 

Veolia 

Total Samples Analyzed 

Total 

Runs 

3 

3 

3 

Aud~t 

0 

0 

0 

F~eld 

Blanks 

1 

0 

0 

Lab 

QC 

1 

0 

0 

Total 

5 

3 

3 
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Table 5-4 Traverse Point Locations 

STACK INSIDE DIAMETER: 39 inches 

SAMPLING LOCATIONS: 9.85 diameters downstream 

15.1 diameters upstream 

MINIMUM NUMBER OF TRAVERSE POllVTS 12 

AS SPECIFIED BY EPA METHOD 1: 

NUMBER OF TRAVERSE POINTS SAMPLED: 12 

Percent of Stack 

Traverse Point Diameter Distance in Inches 

Number From Inside Wall From Inside Wall 

1 95.6 37.3 

2 85.4 33.3 

3 70.4 27.5 

4 29.6 11.5 

5 74.6 5.7 

6 4.4 1.7 

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Table 5-5 Sample Preservation and Holding Time Requirements 

Mercury (Method 29) Aqueous Cool, 4°C 28 days 

SolidtFilter Cool, 4°C 28 davs 

Stack Gas Samples 

0 \rnw97\Pro]ects\l0002022\Veolia Performance Test Plan U2 R2-052108.doc 

Parameter 

Metals (Method 29) 

(except Hg) 

Matrix 

Aqueous 

Solid / Filter 

Preservation 

Cool, 4°C 

Cool, 4°C 

Holding 

Time 

6 months 

6 months 
Veolia ES Technical Solutions MACT Performance Test Plan 

Revision: 0 

Date: May 2008 

Section: 5.0 

Page 24 of 26 

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

Q~\rnw97\Projects\l0002022\Veolia PerFormance Test Plan U2 R2-05210B.doc 

Quality 

Parameter 

Calibration 

Accuracy - ICV 

Accuracy - filters 

Accuracy 

Precision 

Blanks 

RPD = Relative Percent Difference 

ICAP = Inductively Coupled Argon Plasma 

ICP-MS = Inductively Coupled Plasma - Mass Spectrometry 

ICV = Initial Calibration Verification 

Frequency 

Daily 

At least once before and 

after sample analysis 

With continuing calibration 

standard 

After every init~al calibration 

Once per test 

Once per test 

Once per test 

One each per test 

Method Determination 

Initial analysis of standards 

Continuing mid-range calibration 

standard 

Continuing calibration blank 

Analysis of calibration check 

standard 

Analysis of NlST standard reference 

filters or EPA audit filters, if provided 

Post-digestion spikes 

Post-digestion spikes 

Field Reagent Blanks and Method 

Blanks 

Target Criteria 

Analysis of calibration check 

standard within 10% of true value 

90-1 10% 

Subject to interpretation 

90% to 11 0% of true value 

70% to 130% of reference value 

70% to 130% recovery 

RPD < or = 35% 

Evaluated on case by case basis 
Revision, 0 

Date: May 2008 

Section: 5.0 

Veolia ES Technical Solutions MACT Performance Test Plan Page 25 of 26 

Figure 5-1 Stack Sampling Locations 

Q'\mw97Wrojects\l0002022\Veolia Performance Test Plan U2 R2-052108.doc 
Revision: O 

Date: May 2008 

Section: 5.0 

Veolia ES Technical Solutions MACT Pelformance Test Plan Page 26 of 26 

Figure 5-2 Example Sample Packing List 

SAMPLE PACKING LIST 

Field -ts. 

(1) PIPS 

I/Relinquished by (Pr~nt) Date I ~eceived by (Print) Date: Analytical Laboratory: 

Signature: Time: Signature: Time: 

Relrnquished by (Print) Date: Received by (Print) Date: Received by: Date 

Time: I~i~nature: Time: Signature: I Time: 

Q:\mw9~Projects\l0002022\Veolia Performance Test Plan U2 R2-052108.doc 
Revision: 0 

Date. May 2008 

Veolia ES Technical Solutions MACT Performance Test Plan Section: Appendices 

Appendix A 

Unit 2 Process Flow Diagram 

Q:!mw9AProjects\l0002022\Veol1a Performance Test Plan U2 R2-052108.doc 
7 PRIMARY ) FUEL J 

MAIN STACKSTACK GAS 

ANALI~~RS 41- 

.-----F FuELS/L!QUIC WASTE FLOW 

--- - r- COMBUSTLON AIR FLOW 

STACK GAS FLOW 

AS3 FLOW 

~OOOW SOLID WASTE FLOW 

LIME SLURRY FLOW 

VEOLl A 

ENVIRONMENTAL SERVICES TRADE WASTE INCINERATION 

BLOCK FLOW DIAGRAM 
Veolia ES Technical Solutions MACT Performance Test Plan 

Revision: 0 

Date: May 2008 

Section: Appendices 

Appendix B 

Field Data Sarr~ple Collection Forms 

Q:\mw97~ro~ects\lO002022\Veol1a Peliormance Test Plan U2 R2-05210B.doc 

ORSAT ANALYSIS (EPA METHOD 3) 

Valid Leak Check : Liquid level must not fall 

not change by more than 

When less than 4%, difference between readings shall be 0.2% or less. 

* Net 0, is actual O2 minus actual C02 reading. 

Q:irnw97\Projects\10002022\A~pend1x B-all un1ts\[Orsat4nalysisForm.~ls]A 
SAMPLE TRAIN MOISTLIRE RECOVERY DATA SHEET 
ENSR I AECOM 

NOZZLE CALIBRATION FORM 

Client: Project #: 

Date: Calibrated by: 

Where: 

D1,2.3 = Nozzle diameter measured on a different diameter to the nearest 0.001 in. 

Delta D = Maximum difference between any two measurements, in. 

Tolerance = 0.004 in. 

D,,, = Average of Dl,,,, 
Veolia ES Technical Solutions MACT Performance Test Plan 

Revision: 0 

Date: May 2008 

Section: Appendices 

Appendix C 

lso kinetic Sampling Train Setup and Recovery Schematics 

Q:\mw9~Projects\l0002022\Veolia Pefforrnance Test Plan U2 R2-05210B.doc 
SAMPLE TRAIN SETUP 

MULTIMETALS 

(as Per EPA Method 29 / 0060) 

I st empty * 

2nd -- 100 mL 5% HNO, I 10% H,02 

3rd -- 100 mL 5% HNO, I 10% H202 

4t h -- empty 

5th -- 100 mL 10% H2S04 I 4% KMnO, 

6th -- 100 mL 10% H2S04 14% KMn0, 

7t h Silica Gel 

FIELD BLANKS -- (Exact Volumes Specified by Method) 

10% H2SO4 I 4% KMnO, -- l00mL 

Dl Water -- 100 mL 

8 N HCI -- 25 mL 

(added to 200 mL water) 

Filter -- One unused filter 

* optional - used for high moisture stacks 
ENSR 1 AECOM 

FILTER HOUSING 

BrushlRinse 

0.1 N HN03 1 l- 25 mL13X 

6 250 mL Amber 

FH - HN03 

Container 3 

Note 1 : Exactly I00 mL of 0.1 N HN03 used 

for rinsing nozzle, probe and FH filter 

housing. 

Note 2: Nozzle, probe and FH filter housing 

are rinsed with water followed by acetone 

after the nitric acid rinse. The water and 

acetone are then discarded. 

from support with Tefloncoated tweezers and place 

in petri dish 

petri dish 

Seal petri dish with 7 

Filter 

Container 1 

METHOD 29 (METALS) RECOVERY SCHEMATIC - FRONT HALF RECOVERY 

Page 1 of 2 
FILTER SUPPORT AND 

BACK HALF OF 

FILTER HOUSING 

Rinse Three Times 

with 0.1 N Nitric Acid 

2nd and 3rd 

(HN02) 

(Optional) 

Measure Volume Measure Volume 

into Container into Container 

Rinse Three Times Rinse Three Times 

Note: Exactly 100 mL of 950 mL 

nitric acid is used to rinse 

all components up (Container 4) 

through impingers 1-3. 

5th and 6ih (KMn04) 

7 Measure Volume 

Empty the lmpinger 

No. 4 Contents into 

Container 

250 mL 

0.1 N HN03 1 (Container 5A) 

(Silica Gel) 

Nos. 5 and 6 Contents 

METHOD 29 (METALS) RECOVERY SCHEMATIC - BACK HALF RECOVERY 

Page 2 of 2 

Rinse Three Times with 

Permanganate Reagent, (100 

mL total) then with Water 

(100 mL total) 

Residue with 25 

500 mL 

KMn04 

(Container 5B) 

mL 8N HCI 

Solution 

8 N HCI 

(Container 5C)