### 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 inAccordance 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 (618) 271-2804, 

## ext. 101 if you have any questions. Sincerely,
Doug Harris General Manager

#7 MobileAvenue, Sauget, IL 62201 (61 8) 271 -2804 www.veoliaes.comPrepared 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.: 10002-022Prepared 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.: 10002-022Veolia 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 

### ................................................................................................................................................l



### ........................................................... 1

.1 Program Summary [40 CFR 

## 3 63.1207(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 Purposeand Objectivesof the Performance Test ..2

............................................................................................ 1.3.1 General



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

### . 2



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

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

## . 2 2.0 Engineering Description 

### ...........................................................................................................................l 2.1 Process Overview

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

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

### 1 2.2 Waste Feed Systems [40 CFR 

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

### (E)]

................................. 1 2.2.1 Unit 2 LiquidWaste Feed System and BlendingOperations

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



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

### . ........................4 2.5 Air Pollution Control Equipment [40 CFR 563.1207(f)(l )(iii)(G)]



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



### ....................................................................... 4 2.6 Stack Emissions Monitoring [40 CFR 563.1207(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.......................................................................................................................l



### ........................................................................................................................... 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 Spikingfor the LVM Category 2

............................................................................................ 4.4.3 Spikingfor the SVM Category 2



### ......................................................................................... ................. 4.4.4 Spiking for Mercury

.. 2

........................................................................................................... Metals Extrapolation Method 3 Description. Preparation and Deliveryof 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 63.1207(f)(l)(xii)] 3 Anticipated Test Schedule

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

............................................................................................................. PerformanceTest 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 PerformanceTest 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

Q?m~Wrojects\l0002022\Veol1a Pefiormance Test Plan UZ R2_052108.docRevision
. 0 Date: May 2008 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 Representativenessand 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 Samplesto beAnalyzed in the Laboratory

........................ 11 5.10 Data Reduction. Verification and Data Reporting

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



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



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

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

## .. 12



### ................................................................................................................... 5.10.3 Data Verification 12



### ............................................................................................................ 5.10.4 Final Data Reporting 13

........................................................................... 5.11 Routine Maintenance Procedures and Schedules 13 5.11

.1 Field Sampling Equipment



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



### .............................................................................. 14

..................................................................................................... 5.12 QAIQC Assessment Procedures 14

.............................................................................................................................. 5.12.1 Accuracy 14

. .


### ............................................................................................................................ 5.1 2.2 Prec~s~on 15 5.12.3 Completeness



### ...................................................................................................................... I5 5.13 External QA Program

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

............................................................................................................. 5.13.1 PetformanceAudits 16



### .................................................................................................................. 5.13.2 Corrective Action 16 5.1 3.3 Quality Assurance Reports to Management



### ....................................................................... 17

Q:hwS~Projects\l0002022\VeoliaPerformanceTest Plan U2 R2-052108.docVeolia ES Technical Solutions MACT Performance Test Plan Revision: 

### 0 Date: May 2008 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

Q:\mw97\Projects\l0002022\VeoliaPerformanceTest Plan U2 R2-052108 docVeolia ES Technical Solutions MACT Performance Test Plan Revision: 0 Date: May 2008 Section: Table of Contents Pagev of vi 

## List 

## of Tables

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

.............................. Table 1-2 Cross Reference of PerformanceTest Requirements

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

................................................................................................ 7 Table 2-2 Technical InformationSummary on Incinerator No

. 2



### ................................................................ I0

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

. 2

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

### .. 1 Table 3-1 Top Volume LiquidWaste Streams

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

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



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



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



### .................................................................................... 5 Table 3-6 Typical Propertiesfor 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

Q:\mw97lProjects\l0002022\Veolia Performance Test Plan U2 R2-052108.docRev~slon: 0 Date: May 2008 Section: Table of Contents 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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## I

.O 

# Introduction
1.I Program Summary [40 CFR 

# 5 63.1207(f) and 

# 5 63.7(c)(Z)(i)] This document is the PerformanceTest 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 requirementsof the HWC MACT Rule. This Plan has been prepared in accordance with requirements initially promulgated in 

### NESHAPS: Final Standards for Hazardous Waste Air Pollutantsfor Hazardous Waste Combustors, (generally referredto as the Hazardous Waste Combustor [or 'HWC"] MACT Rule). These regulationswere initially published by US EPA on September 30, 1999 in 40 CFR

## 3 63 Subpart EEE. However,these initial regulationswere 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 Registeron October 12,2005. This document addressesthe requirements to develop and submit a PerformanceTest 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 promulgationof 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 developedto evaluatethe 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 hazardousand non-hazardous. 

### 1.2.2 Facility ID, Mailing Address, and Primary Contacts The facility address is: The facility contact is: Veolia ES Technical Solutions Mr. Dave Klarich 7 MobileAvenue Phone: 361-572-2317 Sauget, IL 62201 Email: 

### David.Klarich@veoliaes.com Facility ID#: lLD098642424 

### 1.2.3 Incinerator Overview ThisVeolia 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 monitoringthe process to assure all operational parametersarewithin regulatory and permit limits while waste is being fed to the unit. In addition, this incinerator is equipped with a Continuous Emissions Monitoring System (CEMS) that continuously samples the exhaust gases for oxygen and carbon monoxide in the stack gas exhaust stream.

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Page 2 of 4


### 1.3 Purpose and Objectives of the Performance Test 1.3.1 General The purpose of this test program is to validatethe 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: Demonstratethat the metals emissions from the incinerator meet the HWC MACT emission limits while treating hazardouswaste 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 hazardouswaste. Utilize an extrapolation procedure, as appropriate, to establish metals feed rate limits. The test programwill include feeding a variety of liquid and solid waste materialsto the incinerator, sampling and analyzingthe 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 PerformanceTest 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 remainderof the document has been organized as follows: Section 

### 2.0 provides a general physical description of the fixed hearth incineration system and associated unit operations (includingthe air pollution control system) as well as an overview of the automaticwaste 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 plannedfeed and test conditions, rationalefor 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 (AppendixA), examples of performance test field data sheets and test equipment calibration (Appendix 

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

Q:\rnw97\Projects\l0002022\Veol1a Performance Test Plan U2 R2-052108.docRevision: 0 Date: May 2008 Section: 1.0 Veolia ES Technical Solutions MACT PerformanceTest Plan Page 4 of 4


### Table 1-2 

### Cross Referenceof PerformanceTest Requirements

Q~\mw97\Projects~l0002022\Veolia PerformanceTest Plan U2 R2-052108.doc Section No. inthis 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 ExternalQuality Assurance Plan Analysis of feedstreams (as fired) Heating value, ash content, semi-volatile metals, lowvolatile metals, mercury and total chlorine Viscosity Identificationand quantification of reasonably expected HAPS Detailed engineeringdescription of combustor Manufacturer/makelmodel of HWC Type of HWC Maximum design capacity Feed systems Location of combustion zone temperature device Hazardouswaste AWFCO system Design, operation and maintenanceof APC Justificationof alternative gas flow rate measurement technique Design, operation and maintenance of stack gas monitoring systems Descriptionof Waste handlingand blending Operations Detailed test protocol including: Descriptionof sampling, monitoring and analytical procedures Descriptionof 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 residencetime Metal feed rate limitextrapolation (if used) Documentation of expected levels of regulated constituents in other feed streams that are not analyzed Documentation of conditioning time neededto reach steady state prior to testing Alternat~ve monitoring frequency for wet scrubbers (if used) Other information deemed necessaryby 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 § 63.1207(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: May2008 Section: 2.0 Veolia ES Technical Solutions MACT Performance Test Plan Page1of12 

## 2.0 

## Engineering Description
2.1 Process Overview Veolia operates2 Fixed Hearth Dual Chambered Incinerators (Units2 and 3) and one rotary kiln incinerator (Unit 4) at the Sauget, ILfacility. The two fixed hearth units are rated at 16 million Btulhr each. 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. Unit2 is supported by storagelblendtanks 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 removalof organics before vapor is dischargedto the atmosphere. Each carbon adsorber canister is essentially equivalentto a 55 gallon container or greater, if necessary. All tanks are equipped with conservation vents, in addition to the carbon canister adsorber. All tanks are grounded, and flame arrestors are installed betweenthe carbon adsorbers and the tanks. 

### 2.2.1.1 Organic and Aqueous Liquid Waste Feeds The liquid waste injectors used in the combustion chambers are air-atomizing injectors. 'These are used for ipjectionof 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 liqurdwaste feed nozzlesare served by parallel redundant pumps and recirculation systems with back pressure control.

Q \rnw97\Projects\l0002022\Veolia PerformanceTest Plan U2 R2-052108.docVeolia ES Technical Solutions MACT PerformanceTest Plan Revision: 0 Date: May 2008 Section: 2.0 Page 2 of 12

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. Fiberboardor plastic containers (fully or partially full of waste), up to 40-gallon size, may be charged directly to the primary chamber. These will be received at the dock adjoining each fixed hearth incinerator, and charged to the incineratorwlthin 24 hours or returnedto permitted storage. Solids, usually packaged in plastic or fiberboard containers, are introduced into the incinerator through a PLC controlled airlock-ramsystem locatedat the lower front of the primary chamber of the incinerator. The airlock is composed of a refractory-lineddoor, a door into the airlock enclosure, and two pneumatic rams. The action of the feeder is as 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 automaticallyor manually,which opens the door to the incinerator and actuates the ram (charge ram) that pushes the waste into the incinerator. The ram then retracts and the incinerator door closes.
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 17.5feet long. The interiorwalls 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.

Q:\mw97\Projects\l0002022\Veolia PerformanceTest PlanU2 R2-052108.docVeolia ESTechnical Solutions IVlACT Performance Test Plan Revision: 0 Date: May2008 Section: 2.0 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 systemfor the lower chamber (and secondary combustion chamber) is controlled by a Factory Mutual approved burner management system complete with interlocks and safety valves. 

### 2.3.2 Secondary Combustion Chamber The secondary combustion chamber (SCC) is a horizontal, cylindrical chamber that has an external diameter of 9 feet and is 17.5 feet long. The interior walls of the chamber are linedwith approximately 10 inches of brick refractory and insulation backing, making the internal operatingdiameter 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 travelthrough 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 equippedwith one burner mounted tangentially on the side of the chamber. The burner is a North American burner rated at 6.0 million Btu/hrand 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. Leavingthe upper chamber, the hot gas stream travels through28 feet of refractory-linedstack sections before reachingthe start of the gas scrubbing system. The combined volume of the upper and lower chambers, the flue gas passage and the hot crossover section is approximately 1,567cubic feet. The total retention time of combustion gases within the system is approximately 5 seconds. 

### 2.3.3 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 locatedon 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 63.1207(f)(l)(ix)] The Hazardous waste gas residencetime for the Fixed Hearth Incinerator is calculated as follows: Primary Combustion ChamberVolume 

### - 635 ft3 Secondary Combustion ChamberVolume 

### -635 ft3 Total Volume 

### - 1270 173 Maximum Flue Gas Flowrate

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

### = 4.4 sec

Q:\mw97\Projects\l0002022\Veol1a Performance Test Plan U2 R2~052108.docVeolia 

### ES Technical Solutions MACT Performance Test Plan Revis~on:0 Date: May 2008 Section: 2.0 Page 4 of 12


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

### - 4 to 

### - 6 inches of water column in both combustion chamberswhile wastes are beingfed to the unit. 

### 2.3.6 Emergency Safety Vent The incinerator is equipped with an emergency safety vent (ESV) locatedat the top of the secondary combustion chamber. This ESV is a refractory-lined emergency thermal reliefvent (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 cylindervent valve which opens the TRV are located in the control room for each unit. Valve locks (w~th keys attached) are utilizedto deter indiscriminate operation of these valves. Opening of the TRV allows hot combustion gas to vent from the combustion system during emergency shutdown events. The purpose of the TRV isto protect the downstream

### APCS from excessive temperature situations. A limit switch on the TRV shuts off all waste feedsto the system as it senses that the cap is opening. 

### 2.4 Procedures for Rapidly Stopping Hazardous Waste Feed During Equipment Malfunction [40 CFR 563.1207(f)(l)(viii)] Equipment malfunctions are identified by the control system, observation of process control variables, or by regularfield inspections. Inthe 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 PollutionControl 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 particulatefrom the exhaust gas. Two subsystems, the spray dryer absorber and the fabricfilter, carry out the chemical neutralization and parttculate removalfunctions, 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 requiredtotransportthe 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 concentrationto maintain continuous flue gas treatment in the spray dryer absorber. The system has been designed for batch mixingto providethis service.

Q:\mw9AProjects\l0002022\Veolia PerformanceTestPlan U2 R2-05210B.docRevision: 0 Date: May 2008 Section: 2.0 Veolia ESTechnical Solutions IMACT PerformanceTest Plan Page 5 of 12 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 requiredfor 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 tothe 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 1600-2000oFto 300-500oF, Neutralize and remove HCI and other acids from the combustion gases, Remove a portion of the particulate (fly ash) from these gases. Slurry flow to the spray dryer absorber (SDA) is metered by a flow control valve to obtain the proper feed concentrationto the spray dryer absorber atomizer. Automatic (or manual) adjustmentto 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 proportionalto 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 verificationthat water flow to the atomizer increases or decreases in proportionto 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 dischargedto a conveyor system which transports it to a dump trailer or equivalent type system. 2.5.1.3 Fabric Filter Gas exhaustedfrom the spray dryer absorber is distributed by manifold ducts to 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 approximately6" in diameter by 20' long. The baghousesare fabricated from 3/16" mild steel plate, of welded construction,gas tight and stiffenedto 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 inthe clean air plenum. The fabric filter cleaning mechanism utilizesjets of air to clean the filter bags. Periodically, the cleaning sequence will be initiated. The sequence is started at the end of a 4 hour timed cycle, when the differential pressure across the filter reaches a predeterminedsetpoint of approximately 7 0" w.c., or when the operator initiatesa cycle. The controller then sequences to each row of f~lter bags in each module, releasinga 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 intothe hopper at the bottom of the module. From there it is dischargedto 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 modulesto 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 IDfan includes an inlet volume control damper to be usedto 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 Oxygenfor Incinerators, Boilers and Industrial Furnaces Burning Hazardous Waste, as defined in 40 CFR 266, Appendix IX, Section 2.1. Responses from each CEMSwill be fed to the Control System (CS) where the CO hourly rolling average is calculated and interlockedto the waste feed cutoff valves as part of the Automatic Waste Feed Cutoff System (AWFCO) discussed in Section 2.8, below. The following provides a brief 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 Incinerator2 analyzes for opacity, carbon monoxide, hydrogen chloride, total hydrocarbons and oxygen. These monitors, except

Q:\mw97\Projecls\l0002022\Veolia PerformanceTest Plan U2 R2-052108.docVeolia ES Technical Solutions MACT PerformanceTest Plan Revision: 0 Date: May 2008 Sect~on: 2.0 Page 7 of 12 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 0-100% 0-20,000 acfm

Control room indicationof 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 involvinga 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.
Q~\mw97\Pro]ects\l0002022\Veolia PerformanceTest Plan U2 R2-052108.docRevision: 0 Date: May 2008 Section: 2.0 Veolia ESTechnical Solutions MACT PerformanceTest Plan Page 8 of 12 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 programmedto shut-down equipment (i.e., bring the system into a safe mode) when designated parameters are exceeded, which is a protective mechanism against potential equipment damage, operation outside of permit limits, or conditionsthat might lead to a release to the environment. Continuous monitoringof the incinerator and scrubber system is an importantaspect 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 responseto adverse conditions by the operator. Automatic waste feed cut-off and incineration shutdown mechanisms are also interlocked with the monitoring system at or priorto reaching permit l~mit levels. Monitoring methods and calibration frequencies are listed in Table 2-3. The Incineratorhas 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 563.1207(f)(l)(iii)(F)] The incinerator has an Automatic Waste Feed Cut-Off (AWFCO) System that will shut waste feeds off in the event certain operating parameters deviate from allowable set points. The PLC continuously monitors operating parameters, making adjustmentsto the process as needed for proper control. Alarm logic is incorporated intothe PLC systemto automatically initiatean AWFCO. Table 2-3 summarizesthe 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 instrumentthat 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 leadto fuel rich conditions. Utilitv or Power failure 

### -establishedto facilitate a controlled shutdown of the process during loss of processair, 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 calibrationsare 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 Q.\mwS~Projects\lO002022\VeoliaPelformanceTest Plan U2 R2-052108.docVeolia ES Technical Solutions MACT Performance Test Plan Revision: 0 Date. May 2008 Section: 2.0 Page 9 of 12
incinerator's PLC systemto 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 actualAWFCOs occur during a given testing period, these are documented by operating personnelto satisfy regulatory requirements for system testing. Results of this testing are documentedon 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 963.1207(f)(l)(iii)(G)] 2.9.1 Program Overview Once equipment is installedand operational, Veolia utilizesan 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 highwear 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 associatedwith 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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### 2,O Veol~a ES Technical Solutions MACT Performance Test Plan Page 10 of 12
Table 2-2 Technical InformationSummary on Incinerator No. 2

Q:\rn~7\Projects\l0002022\Veolia Performance Test Plan U2 R2-05210B.doc Manufacturer

Model No.

TY pe Date of Manufacture Dimensions External Length External Diameter Internal Diameter Cross-sectional area Burners Manufacturer Size Fuel Primer Mover TradeWaste Incineration JWI-2000, Series 2 Fixed Hearth, Dual Chamber 1987 Primary Chamber 17.5'



### 9' 7'2" 40.3 square feet Primary Chamber Burner NorthAmerican 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 columnRevision: 0 Date: May 2008 Section: 2.0 Veolia ESTechnical Solutions MACT Performance Test Plan Page 1 1 of 12
Table 

### 2-3 CurrentAWFCO Parameters and Limitsfor Incinerator No. 

### 2

Q~hw97\Pro]ects\10002022\Veol1a Performance Test Plan U2 R2-052108.doc 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 (12HRA)

> 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 average) >420 (HRA)

pp 217,198 Units Lblhr System Total PumpableWaste 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 Liquidfeedrate Low BTU Liquidfeedrate 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)Veolia ES Technical Solutions MACT PerformanceTest Plan Revision: 0 Date: May 2008 Section: 2.0 Page 12 of 12



### Device Units Cutoff Limits System

- 1 HRA means "hourly rolling average" as calculated by averagingthe previous 60 one-minute average values. Stack hydrogen chloride 

## I Fabric filter pressure drop

Q:\mw97\Projects\l0002022\Veol1a Performance Test Plan U2 R2-052108.doc Infrared

Delta Ptransmitter PPmv

in.w.c. 2.100 (HRA) 2500 (one minute average) 

### s 2 or 2. 10 (1 min. average) Quarterly
QuarterlyRevision: 0 Date: May 2008 Section: 3.0 Veolia ES Technical Solutions MACT Performance Test Plan Page 1of 5 

## 3.0 

## Incinerator Feed Stream Descriptions
3.1 General Veolia treats a broad rangeof 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. Priorto scheduling wastes for shipmentto 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 handledat 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 processedat the facility. 

### 3.2 

### Highvolume 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 streamsthat have been processed in the lastyear. 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 includestreams like contaminated soils, wastewater sludges or manufacturing process solids. These wastes are receivedat the site primarily in 20 to 40 cubic yard roll-off containers or other similar bulk transport vehicles. 

### 3.2.3 Containerized Waste Table 3-3 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 GaseousWastes Small volumes of compressed gases are processed in Unit 2 however these are minimal in comparisonto the other waste types that are treated.

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Page 2 of 5


### 3.3 Auxiliary fuels Natural gas or 

### #2 fuel oil can be used as auxiliary fuels to start-up and obtain desiredtemperatures in the incinerators. At this time, all incinerators use natural gas as their primary fossil fuel. Typical composition of bothfuels is provided in Tables 3-5 and 3-6.

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### Table 3-1 

### Top Volume LiquidWaste 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 410013 296227 351 071 BF0568

Q:\rnW7\Projects\lOOO2022\Veolia Performance Test Plan U2 R2-052108.doc 

### Waste Name REFLUXWATER 1.51

### B WASTE ORGANICSIMKH DE175-IPA WASH 

### & FILTRATE WASH SEWllCARBAZlDE PROCESS WASTE BULK MIXEDWASTE LlQLllDS PVA PRODUCTIOIV DP202 

### RllVSE WATERIAG CHEMICAL BULKED LIQUID HIGH BTU >3000 

### BULK LIQUIDS LOW BTU <3000



### Profile 396871 346603 562221 330548 396775 351070 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 INClhlERATlONSOLID 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 1,058,000 956,980Veolia ES Technical Solutions MACT Performance Test Plan Revision 0 Date: May 2008 Section: 3.0

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

Table 3-4 Summary of Major HAPS Processed

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Page5 of 5
Table 3-5 Typical Propertiesfor Supplemental FuelOil

Table 3-6 Typical Propertiesfor Natural Gas

Q:\mw97\Pro~ects\l0002022\Veol1a Performance Test Plan U2 R2-052108,doc 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 HeatValue 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 

### < 0.05Veolia ES Technical Solutions MACT Performance Test Plan Revision: 0 Date: May 2008 Section: 4.0 Page 1 of 7 

## 4.0 Performance Test Protocol
4.1 

### General Description This PerformanceTest Plan has been designed to demonstrate performance under a single test condition using a combination of actual and spikedfeeds. This test condition will be designedto establish maximum metals feed rates while demonstrating conformance with applicable HWC MACT metals emissions standards. Duringthe testing, Veolia will be seeking to establish new Operating Limitsfor Unit 2. Due to this, Veolia will adjust the limitsat which the AWFCO system activates except for carbon monoxide. At the end of each day of testing, current AWFCO limits will be reinstated backto currently established limits. 

### 4.2 

### Performance Standards The test plan for the Veolia incinerator has been designedto demonstrate compliance with current performance standards of the Hazardous Waste MACT rule as follows: Conformance with the mercury emission limit of 130 ygldscm correctedto 7% oxygen; Conformance with the semivolatile metal (cadmium and lead) emission limit of 230 ygldscm corrected to 7% oxygen; and Conformancewith the volatile metal (arsenic, beryllium and chromium) emission limit of 92 ygldscm correctedto 7% oxygen. 

### 4.3 

### Test Conditions [40 

### CFR 

# 5 63.1207(f)(I)(vi) 

### and (vii)] The test condition for this performancetest 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 limitsfor the performancetest 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 incineratorfeeds with organic and inorganic constituents. The spiking levels and approach proposedfor this performance test have been used successfully in the past for testing at not only Veolia but for testing at other hazardouswaste combustion facilities as well. Each spiked material will be preparedto a known specification and verified by a certificate of analysis. These materialswill 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 performanceto assure that emissions can be detected and actual results,versus non-detect results,are used in calculation removal efficiencies.

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### 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 usedto determine appropriate feed rate limits, as necessary. Regulated metals may be fed at some level in the nativewaste materials to be used during the test. However, these native concentrationsmay 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 metalsat higher than normal rates to ensure that suffic~ent metals are fed to achieve measurable emissions in the stack emissions. 

### Table 4-2 providesan overallsummary 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 ratesthat will result in acceptableemission rates. This table is only used as a predictivetool, however, and final limits to be imposed will depend on the actual results of the performance test. Two other points are worth noting with regardto Table 4-2: The spiked amount for a given metal will be the difference between the desired feed rate limit and the native quantity expectedto 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 metalsto be spiked are representative of the three classes of metalvolatility and therefore can be usedto set limits for any metals not spiked. 

### 4.4.2 

### Spiking for the LVM Category The LVM Category for incineratorsincludes arsenic, beryllium and chromium. Veolia plans to spike chromium at 40-45 Iblhrto establish a SRE for all three test runs. The SRE demonstrated during the performance test for chromium will be used to establish a LVM feed rate limit. Chromiumwill be spiked as chromic acid through a liquid feed injectorvia a pumping station that will monitor the feed rate. Waste chromic acid is treated at Veolia and thus, spiking chromic acid duringthe performance test is representativeof normal operations. 

### 4.4.3 

### Spiking for the SVM Category The SVM category for incinerators includes cadmium and lead. Veolia plansto spike lead at 60-65 Iblhrduring the performance test to establish a SRE for all three runs. The SRE demonstrated during the performancetest for 

## leadwill 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 performancetest. Lead containing waste that are normally treated at Veolia are predominantly bulk or containerizedsolids and thus, this spiking approach during the performancetest 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 nitratesolution at regular intervals along with other solid feeds during the performancetest. Mercury is predominantly present in solid feeds processed at Veolia and usinga liquid solution for spiking will provide Q:\mw97\Projects\10002022\Veol1a Performance Test Plan U2 R2-052108.docVeolia ES Technical Solutions MACT Performance Test Plan Revision: 0 Date' May 2008 Section: 4.0

Page 3 of 7

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

### 4.5 Metals Extrapolation Method Veolia plansto extrapolate to h~gher feed rate limits than actually fed during thetest 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 standardsto ensure full compliance. Based on previous discussionsw~th EPA Region 5,the following approach will be used The average SRE for the three runs would becalculated from the feed and emiss~on rates for each run and an average SRE for the performancetest. 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 befollowed for SVM (cadmium and lead) and for mercury. To further assure that this method is protective, Veolia proposesto limitthe maximumfeedrate for any one category to 10 times the spiked feed rate duringthe testing. The test program will establish 12-hour feed rate limits for the MACT metals. Example calculationsare 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 processedat the facility will befed to the incineratorduring the test program. Waste materials will be stockpiledto meet the objectivesfor the target test parameters. These wastes will be characterized in advance of the test and kept until needed. All waste materials

### will be deliveredto the facility in accordance with routine operation and currently permitted procedures as described elsewhere in this document. 

### 4.7 Conditioning Time Neededto 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 thetesting. This w~ll assure all operating parameters are stabilized at the desired settingsto achieve steady state before sampling. 

### 4.8 Anticipated Test Schedule The performance test will be performed over a Cday period using a three-person field crew accordingto the schedule shown in 

### Table 4-3. For this test program, it is anticipated that all runs will beapproximatelytwo 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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Page 4 of 7


### 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 presentationof 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 comparedto 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 presentationof waste analysis and stack sampling results including tabulated presentationof all data 

### Section 8.0 

### Quality Assurance IQuality 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

Q:\mw97\Projects\lOO02022\Veoi1a Performance Test Plan U2 R2-052108.doc 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 MaximumTotal Mercury Feed Rate MaximumChlorineIChloride 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 HRAsfor each run Average of the average HRAsfor each run Average of the average HRAsfor each run Average of the test run averages Average of the test run averages Average of the test run averages Expected Limit 14,500

### - 17,000 400 

### -450
400 

### -450
600 

### -650
0.01

## - 0.02 200 

### -250 390

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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

Q\mw37\Pro~ects~l0002022\Veol1a PerformanceTest Plan U2 R2-05210B.doc Historical Desired Feed Range Feed Rate (Iblhr) 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 32Veolia ES Technical Solutions MACT Performance Test Plan Revision: 0 Date: May 2008 Section: 4,O Page 7of 7

- 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 Run2 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 Assuranceand Quality Control goals, objectives, and procedures for the MACT performance test program. The quality assurance/qualitycontrol proceduresand criteria for this programwill comply with the requirements of this document and its updates. The analytical work conducted will incorporatethe WQCrequirements of the approved methods. This document has been prepared using available guidance provided in the following EPA documents: "EPA Requirementsfor Quality Assurance Project Plans", EPA QNR-5, November 1999. "Component 2 

### - How to Reviewa QualityAssurance Project Plan (including AttachmentA 

### - 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 HazardousWaste Incineration" (EPN62516-891023 January 1990).
Quality Assurance Project Planfor Veolia's MACT Metals PerformanceTest for the Unit2 

### Incinerator Facility ID Number: lLD098642424 Prepared for: Veolia ES Technical Solutions, LLC, 

### 7 Mob~le Avenue, Sauget, IL62201 Prepared by: ENSR Corporation, Westford, MA 01886 Revision No.: 0 Date: May 2008

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### 5.1 

### Title Page 5.1.I ProjectTitle Quality Assurance Project Planfor Veolia ES Technical Solutions HWC MACT Metals Performance Test Plan for the Unit 2 Fixed Hearth Incinerator. 

### 5.1.2 Expected PerformanceTest Date On or af&er August 1,2008. 

### 5.1.3 Project Approvals

Veolia Project Manager

ElVSR Project Iblanqger

ENSR QA Officer

MaxxamAnalytics Lab Services Coordinator Date

Date

Date

Date

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### 5.2 Table of Contents A complete table of contents, including listings of tables and figures and acronyms is presentedat the beginning of this 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-establishedor 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 measuresthat will be followedto ensure collection of valid data. A brief overview of the measurementsto 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 Hewill 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. Hewill monitor implementation of field and laboratory activities, scheduling performanceand/or system audits as warranted. The QAO will report to the Project Manager on any conditions noted which may adversely affect data quality. Mr. Doolittle will provide independent oversight for data verification and data quality assessment activities. He will preparea 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 laboratorystaff to ensure that all required measures are taken to meet data quality objectives. They will monitorthe shipment and receipt of samples, track analytical progress and review data as reported from the laboratories for completeness. Each LSC will be responsible for validation of all data generated by the laboratory for this programand will provide all necessary documentationfor inclusion in the final report.

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### 5.5 QAIQC 

### Program 

### Objectives 5.5.1 Precision, Accuracy and Completeness The collectionof 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 limitsto ensurethat 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 measurementof mutual agreement among individual measurements made under prescribed similar conditions. Precision is expressed interms 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 truevalue. Analytical accuracy will be measured through the recoveriesof 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 monitoredto 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 solutionswill be independentfrom calibration standards. Completeness is a measureof 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. Resultsfor samples where matrix interferences preclude meeting objectives for the recoveriesof surrogates or spikeswill be evaluated for potential bias to calculated emission results. Insummary, the completeness goals are stated at 100%,since three valid runs are necessaryto assess operation at any one condition. 

### 5.5.2 Representativeness and Comparability It is recognized that the usefulnessof the data is also contingent upon meetingthe criteria for representativeness and comparability. Wherever possible, reference methods and standard sampling procedures will be used. The QA objective is that all measurements be representativeof the matrix and operation being evaluated. The detailed requirements for sampling given in the various EPA Reference Methodswill be followed to ensure representative sampling of flue gases. The sampling of incinerator feed streams priorto the performance test will provide representative samples of these matrices. The correspondingQA objective is that all data resultingfrom 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 comparabilityof the data.

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### 5.5.3 Method Detection Limit (MDL) Determinations Method Detection Limits (MDLs)for the various analytesto be measured in this program will be determined followingwell-establ~shed laboratory procedures in accordance with standard EPA protocols. These are described below for those parameters deemed most crucialto 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-detectvalues 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 proceduresthat will befollowed during the field sampling program. Throughout the overall program, all samplingw~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 priorto 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 protocolsw~ll befully documented in the final PerformanceTest 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 

### providesa detailed listing of the sampling and analytical parameters and methods planned for this program. All samplingwill 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, preparationof 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 importantaspect 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. Rejectioncriteria 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)

## - calibrateagainst 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 barometeror 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 collectioncontainer or devices. Cleaninglstorageprocedures for sample train glassware are summarized below. Notethat 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 purchasedpre-cleaned and sealed to specified EPA protocols. EPA Method 29 glassware and containers (metals)-wash with soap and water, rinsewith hot tap water, rinsethree times with reagent water. The glassware is next soaked in a 10% nitric acid solution for a minimum of 4-hours, rinsedthree 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 priorto sampling. 5.6.2.3 Sample Media Preparation All reagentswill be checked 

### in accordance with ENSR's existing QC Programto minimize the probability of using contaminated solvents. This includes the use of the proper grade reagentslsolventsas specified in the test method,selection of reagents from the same lot and the collectionand analysis of the appropriate blanks. Sampling mediawill be procuredand 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-screenfilters for metals content. 5.6.2.4 Other Pre-Sampling Activities Sample team meetingswill be held to designate responsibilities to each team member. Assignments will be based on individualexperience and relative importance of the assigned task. Other pre-sampling activities in the office will include generation of sample checklists, printingof computer-generated sample labels, and P"" proper packing of all equipment. Equipment will then betransported 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 movingthe equipment to the vicinity of the sample collectionarea. A separate officetrailer or other suitableonsite facility will be used to serve as a sample train setup and recovery area and sample custody area. Normally, preliminarytests are conducted at the stack locationto verify the presence or absence of cyclonic flow conditions and to determine flue gas moisture,temperatureand velocity. These measurements facilitate determination of nozzle size selectionand sample train operation rates for the isokineticsampling trains. 

### 5.6.3 Sampling Locations 5.6.3.1 Waste Feed Streams Waste feed materialswill be sampled in accordance with the facility's feed stream analysis plan (FSAP) and RCRA Waste Analysis Plan (WAP). Wastefeed sampling will occur upstream of any metal spiking location. Sampleswill 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-pointtraverse 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/downstreamdistances 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 materialwill besampled 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 analyseswill 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 providesummaries of the sampling methodologiesto be followed. In addition, sample field data sheets to be used during the program are provided in Appendix B. Summaries of relevant information pertainingto 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 streamflowrate, moisture and fixed gas concentration will be determined concurrent with the EPA Method 29 isokinetic sampling train. Gas stream velocity will be determined using a pitottube and water manometer in accordance with EPA Method2. 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 bewill be determined as specified in EPA Method 

### 4 concurrent with the EPA Method29 isokinetic sampling train. Inthis procedure the impinger contents are measuredor weighed before and after each test run and used in conjunction with the metered gas volume to determinethe 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 measurementof 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 samplesto the designated laboratoryvia Priority 1overnight FedEx service. Preprinted sample identification labels are used by ENSRto ensure that all required information is fully documented. When sample batches are shipped to the specified laboratory,a sample packing list (see

Q~\mw97\Projects\l0002022\Veolia Performance Test Plan U2 R2-052108.docVeolia ES Technical Solutions MACT Performance Test Plan Revision: 0 Date: May 2008 Section: 5.0 Page 9 of 26 Figure 5-2) accompaniesthe shipment. This form is based on established laboratory format and will be used to document sample transfer in the field and from sampling personnelto the laboratory. The ENSR FieldTeam Leaderwill coordinate the packing and shipment of all samples. Worksheets specifically designed for this program will be generated priorto the field effort These sheets will assist the FieldTeam Leader in assuring that all samples have been collected, accounted for and shipped under sample traceability documentationto 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 protocolsthat will be usedto 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 ofWaste Feed Streams Analyses to determine the chemical and physical properties of the waste feed materialswill be performed using appropriate ASTM or EPA SW-846 analytical methods as outlined in the Veolia FSAP and WAP. For any analytical resultsthat 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 inStack Gas Samples Analysis 

## - Each sampling train will be prepared and analyzed in accordance with EPA Reference Method 29. From each sampling train, seven individualsamples 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, consistingof 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. Fractions2A and 2B consist of digestates from the moisture knock out and 

### HN03/H202 impingers 1, 2, and 3. Fraction2A 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 mercurywill 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 interferencecheck standard, will befollowed as described inthe respective method. Q:\mw97\Pro~ects\lO002022\Veolia Performance Test Plan U2 R2-052108.docVeolia ES Technical Solutions MACT Performance Test Plan Revision: 0 Date: May2008 Section: 5.0 Page 10 of 26


### Calibration

### - Calibrationof the ICAP

### will be performeddally 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 performedto ensure the collection of representative samples and the generation of valid analytical results for these samples. These checkswilt 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 notebooksto 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 EquipmentQC Checks and Frequency Calibration of the field sampling equipmentwill 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 MeasurementSystems, Volume Ill, Stationary Source Specific Methods;" Section4.2.1 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 beconducted 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 samplesto beanalyzed in the laboratoryare listed below: One field reagent blank Method29 samplingtrain. Q:\mw97\Projects\lOM32022\Veolia PerformanceTest Plan U2 R2-052108.doc

### Veolia ES 

### Technical Solutions MACT Performance Test Plan Revision: 0 Date: May2008 Section: 5.0 Page 11

### of 26


### 5.9.2 Analytical QC Procedures for Samples to be Analyzed inthe 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.LaboratorvControlSamples (LCS) or Blank Spikes These samples are generated from spikes prepared independently from the calibration concentrates. The LCS are usedto 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 priorto laboratory use. All reagents are labeled with the date receivedand 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 accordingto the method requirements. Standard laboratory practicesfor laboratory cleanliness, personnel training and other general procedures are used. The results of these quality control procedures will be included in the final report. 

### 5.10 

### Data Reduction, Verification and Data Reporting Specific QC 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 PerformanceTest 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 FieldTeam 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 reagentsto 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 measurethe total liquid volume submitted and multiply by the measured concentrations of target analytes in these samples. The laboratories

### will generally report data as follows: All metals except mercury -total 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 verifyingthe completeness of the data set. The laboratory reports submitted by each laboratory will includethe 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 bean "outlying" or spurious value. Field sampling data will bevalidated by the Field Team Leader based on a judgment of the representativeness of the sample, maintenance and cleanliness of sampling equipment and the adherence to an approved, written sample collection procedure. Analytical data will be validated by the subcontractor laboratory QC or supervisory personnel using criteria outlined 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.

Q:\rnw97\Pro~ectsil0002022\Veolla PefiorrnanceTest Plan U2 R2-052108.doc

### Veolia ESTechnical Solutions MACT PerformanceTest Plan Revision: 0 

### Date: May 2008 

### Section: 5.0 

### Page 13 of 26


### 'The following criteriawill be used to evaluate the field sampling data: Use of approved test procedures Proper operation of the process being tested Use of properly operating and calibrated equipment Leak checks conducted before and after tests Use of reagents that have conformedto QC specified criteria Use of 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 comparableto that achieved in previous analytical programs and consistent with objectives stated in this document. 

### 5.10.4 

### Final Data Reporting Stack gas concentrationsfor 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 comparisonto the published standards. A complete Final Report outlining the goals, methods and results for the programwill be prepared and any deviations from this test plan will be documented. The Final Report will include a section on evaluationand discussionof QAIQC results. Results will be comparedto expected limits for accuracy, precisionand/or completeness as targeted in this protocol. The final test report will also includethe resultsof any internal audits conducted on the program as well as: All field data sheets showing sampling method, dates, run times, personnel, equipment; sample preservation, identificationand 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 necessaryto maintain permitted operating conditions and to demonstrate continuing permit compliance. Information is provided for preventive maintenance and schedules and spare parts for key equipment and instrumentation.

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### 5.11.I Field Sampling Equipment The field team follows an orderly program of positive actions to prevent the failure of equipment or instruments during use. 'This preventive maintenance and careful calibration helps to ensure accurate measurementsand minimal field delays. All equipment that is scheduledfor 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 broughtto each site to minimize downtime and field sampling delays. Any equipment that does experience problems is appropriately tagged in the field to ensure that it is repaired upon return to the office. 

### 5.11.2 Facility Equipmentand Instrumentation As stated in SectionsV.a.F. and V.b.F. of Veolia's Part B RCRA Permit, each ~ncinerator system undergoes a "thorough visual inspectionfor leaks, spills, fugitive emissions, and sign of tampering at least daily and in accordance with the inspection schedule contained inAppendix 6 of the approved permit application". Veolia utilizes these inspections and additional preventive maintenance activities as proactive measuresfor minimizing the potential for malfunctions. To facilitate proper maintenance,a cold shutdown will occur at least once per year for each incinerator system. Routine inspectionand 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 programwill provide a basis for assessing the accuracy and precisionof the analytical measurements. Section 

### 5.8 of this QAPP discussesthe QA activity that will generatethe accuracy and precision data for each sample type. A generalized form of the equations that will be usedto calculate accuracy, precision and completeness follows. 

### 5.12.1 Accuracy Percent accuracy will be determined usingthe 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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### 5.12.2 

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

where: Dl and D2

### = results of duplicate measurementsor standard deviation relativeto the average value expressed as relative standard deviation: Relative standard deviationwill 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 measurementeffort fulfills objectives for the amount of data required. For this program, completeness will be defined as the percentageof valid data for the total valid tests. Completeness is assessed usingthe follow~ng equation:

where: Dr= number of samplesfor which valid results are reported Dc= number of valid samples that are collected and reachthe laboratoryfor 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 performanceand system audits as independent checks on the quality of data obtained from sampling, analysis, and data gathering activities. Every effort is made to havethe 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 operationsto ensure the independenceof the quantitative results. EPA Quality Control concentrates or other standards will be used to assess the analytical work. Resultswill be reviewed bythe 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. Itwill, 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 appropriateto the analytical methods being utilized. Ifthe 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 inthis program will bethose 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 CorrectiveAction 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 betaken 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 discoveredto be defective (i.e., pre- and post-sampling leak check) it is repaired or replaced and a correction factor is establishedas perthe EPA method. If a correction factor is unacceptablethe 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 leaderto 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 analyticalwork would include re-calibrationof instruments, reanalysis of known QC samples and, if necessary, of actual field samples.

Q:\mw97Projects\l0002022~Veol1a PerformanceTest Plan U2 R2-05210B.docVeolia ES Technical Solutions MACT PerformanceTest Plan Revision: 0 Date: May 2008 Section: 5.0 Page 17 of 26 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 importantto 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 identifiedas 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 beenfully 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 QualityAssurance Reportsto Management 5.13.3.1 Internal Reports The Laboratory Services Coordinator will prepare a written report on QC activities associated with this project for the Quality Assurance Director. This reportwill detail the results of quality control procedures, problems encountered and any corrective action, which may have been required. All CorrectiveAction 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 Coordinatorsand 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 deviationsor documentation gaps will be identified and discussed

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Table 

### 5-1 General Sampling and Analytical ProgramOverview (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

Q:\mw3T\Projects\70002022\VeoIia Performance Test Plan U2R2P52708.doc 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-MSVeolia ES Technical Solutions MACT Performance Test Plan Revision: 0 Date: May 2008 Section: 5.0 Page 20 of 26
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 Method3 

## - Orsat Analysis) (a) Not determinable. (b)An accuracy oft0.2% 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

Q~\mw9~Pro~ects\10002022\Veolia Performance Test Plan U2 R2-052108.doc Sample Matrix and Sampling Method EPA M 29 EPA M 3 Facili ty CEM (a) MAX = MaxxamAnalytical, 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 601OB/6020/7000 EPA M 3 (Orsat) FacilityCEM QA Plan Analytical Parameters

Metals (b)
02 and COa O2and 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 3Revision: 0 Date: May 2008 Section: 5.0 Veolia ES Technical Solutions MACT Performance Test Plan Page 22 of 26
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 Preservationand 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 PerformanceTest 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 monthsVeolia ESTechnical 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 PerFormanceTest 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= InductivelyCoupled Plasma- Mass Spectrometry ICV = InitialCalibration 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 90-110% Subject to interpretation 90% to 11 0% oftrue value 70% to 130% of reference value 70% to 130% recovery RPD < or = 35% Evaluated on case by case basisRevision, 0 Date: May 2008 Section: 5.0 Veolia ESTechnical Solutions MACT Performance Test Plan Page 25 of 26 Figure 

### 5-1 Stack Sampling Locations

Q'\mw97Wrojects\l0002022\Veolia PerformanceTest Plan U2 R2-052108.docRevision: O Date: May 2008 Section: 5.0 Veolia ESTechnicalSolutions MACT PelformanceTest Plan Page 26 of 26 Figure 5-2 Example Sample Packing 

### List



### SAMPLE PACKING LIST

Field -ts. (1) PIPS
I/Relinquishedby (Pr~nt) Date 

# I~eceived by (Print) Date: Analytical Laboratory: Signature: Time: Signature: Time: Relrnquished by (Print) Date: Receivedby (Print) Date: Receivedby: Date Time: I~i~nature: Time: Signature: 

# I Time:

Q:\mw9~Projects\l0002022\VeoliaPerformanceTest PlanU2 R2-052108.docRevision: 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 PerformanceTest Plan U2 R2-052108.doc

# 7PRIMARY 

# ) 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

VEOLlA ENVIRONMENTALSERVICES TRADEWASTE INCINERATION



### BLOCK FLOW DIAGRAMVeolia ESTechnical 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 PeliormanceTest 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 

### O2minus actual C02reading.
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\VeoliaPefforrnanceTest 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 4th 

### -- empty 5th 

### -- 100 mL 10% H2S04 I 4% KMnO, 6th 

## -- 100 mL 10% H2S04 14% KMn0, 7th Silica Gel
FIELD BLANKS

# -- (Exact Volumes Specified by Method)

10% H2SO4I 4% KMnO, 

### -- l00mL 

### Dl Water 

### -- 100 mL 8 N HCI 

## -- 25 mL (addedto 200 mL water) Filter 

### -- One unused filter

* optional 

### - used for high moisture stacks

# ENSR

# 1AECOM

FILTER HOUSING

BrushlRinse 0.1 

### N HN03 l- 25 mL13X 

# 1

250 mLAmber 

# 6

FH

### - HN03 Container 3

Note 1

### : Exactly I00mL of 0.1N 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 2FILTER 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. 5thand 6ih (KMn04)

Measure Volume



# 7

Empty the lmpinger No. 4 Contents into Container

250 mL 0.1 N HN03 (Container 5A)



# 1 (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 mLtotal)

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

8 N HCI (Container 5C)