VEOLI A 

€ N VS RON M E NTAL SERViCES 

TECHNICAL SQIUTIONS 

NORTH AMERICA 

October 10, 2008 

Via FedEx 

Attn: Compliance Tracker, AE-17J 

Air Enforcement and Compliance Assurance Branch 

United States Environmental Protection Agency 

Region 5 

77 W. Jackson Blvd., AE-17J 

Chicago, IL 60604 

RE: Veolia ES Technical Solutions, LLC . 

163121 AAP 

40 CFR Part 63 - Subpart EEE 

National Emission Standards for Hazardous Air Pollutants from Hazardous 

Waste Combustors 

Notification of Compliance (NOC) 

Compliance Tracker, 

Pursuant to Appendix B, Items 9,11 and 12 of the Request to Provide 

Information Pursuant to the Clean Air Act from USEPA, Region 5, dated 

February 22, 2008, revised June 5, 2008 and revised on September 16, 2008, 

Veolia ES technical Solutions, LLC , hereby submits the Notification of 

Compliance (NOC), the Performance Test Reports for Incinerators 2, 3 and 4 

and the Significant Modification to the Part 71 Permit. The NOC documents 

compliance with the emission standards and continuous monitoring system 

requirements, and identifying operating parameter limits for mercury, SVM and 

LVM defined in 40 CFR 63-1209 and 63.1219. Veolia is now complying with all 

operating requirements specified in this NOC. The Performance Test Reports 

detail compliance with these standards and the Significant Modification request 

that the revised OPL's be incorporated into Veolia's Part 71 permit. 

I certify under penalty of law that this document and all attachments were 

prepared under my direction or supervision in accordance with a system 

designed to assure that qualified personnel properly gather and evaluate the 

Veolia ES Technical Solutions, LL.C. #7 Mobile Ave, Sauget, IL 62201 tel: 618 2712804 - fax: 618 2712128 

VES 000743 
information submitted. Based on my inquiry of the person or persons who 

manage the system, or those persons directly responsible for gathering the 

information, the information submitted, is to the best of my knowledge and belief, 

true, accurate, and complete. I am aware that there are significant penalties for 

submitting false information, including the possibility of fine and imprisonment for 

knowing violations. 

Upon review of this submittal, should the Agency have a need for additional 

information or questions, please contact Dennis Warchol at (618) 271-2804 or via 

e-mail at dwarchol@onvxes.com or myself at (618) 271 -2804 or via e-mail at 

dharris @ onvxes.com.. 

Sincerely, 

VeoUavES Technical Solutions, L.L.C. 

Doug Harris 

General Manager 

Att. 

cc: Genevieve Damico, USEPA (Significant Modification Only) 

USEPA File 

VES 000744 
Veolia ES technical Solutions, LLC -

Significant Modification to Part 71 Permit 

title V Permit #: V-IL-1716300103-08-01 

Pursuant to 40 CFR 71.7(e)(3), Veolia ES technical Solutibhs, LL.C. is 

submitting a significant modification to our Part 71 Permit number V-IL1716300103-08-01, The following pages detail the requested modifications, 

supporting information and justification for the modifjcation. the requested 

modifications are as followed: 

• Section 1 (B) Dates of Construction for Incinerators 2, 3 and 4 

• Section 2.1 (C)(2) Operating Parameter Limits for Units 2, 3 and 4 

• Section 2.2 Material Processing, Handling of Level 2 Containers 

• Section 2.4 Storage Tanks, Monitoring and Testing for tanks Maintained 

at Atmospheric 

• 550 Gasoline Storage, Insignificant Activity 

• Drum Sampling, Insignificant Activity 

VES 000745 
Section 1 (B) Source Emission Points 

Veolia request that the dates of construction for Incinerators 2, 3 and 4 be 

modified as followed: 

Incinerator 

#2 ' 

#3 

#4 

These revised dates are taken directly from the construction permits 

issued by IEPA (construction permits attached). 

Date of Construction 

9/1986 (correct in permit) 

8/1988 (permit states 9/1986) 

8/1988 (permit states .6/1988) 
f A 

Illinois Envirprimenial ProteGticitt Agency » tlb'rj' ^^it f Road, SpirSiigReld, IL 62706 

217/782*2113 

GdHSTRUetlOW PERMIT 

fPSite Waste. IneiMrition ' 

Attentions James t, (sary 

7 Mobile Avenue 

Illinois 62201-10^9 

? 

jftpgTi cant - s D eg?} gnati on;; 

$mfaW'\'m W1-2UM0 fodrteytffiofrs 

pater mptrnMP iiii ' 

W^^^TWI Avenue, Sauget 

I..D, ..Ng.? 163121AAP 

Received: June 9:^ 1 

Permit is hereby granted to the above-designated Permittee to CONSTRUCT 

emission soufce(s) and/or air pollution control equipment consisting of two 

TWI-&G0Q Series 2 Hazardous Waste Incinerators one with a Joy Spray Dry 

Adsorber and fabric fitter* and the. second unit with a Venturi Scrubber, 

Cyclonic Water Gas Separator, Induced Draft Fan, and Exhaust Expansion Tank as. 

described in the above-referehced application. This Permit i s subject to 

standard conditions attached hereto and the following special conditions}; 

1, The incinerator when constructed shall include a Waste Feed Interlock 

System to insure that waste is not fed to the incinerator unless all 

critical operating parameters are with acceptable limits. As part of this 

system stack monitors shall be installed on each incinerator for Oxygen, 

Carbon Monoxide, and Hydrocarbons. For the incinerator with the SDA the 

following two additional emission monitor's are required: Broken Bag 

Detector and hydrogen chloride tnbnitor. 

2, Particulate matter emissions from the incinerator shall not exceed 0.08 

grains per dry standard cubic foot of gas discharged to the atmosphere, 

pursuant to 35 111, Adm, Code 121.181(b). 

3, Carbon monoxide; wtsslpns from the i nether a tor shal 1 not exceed 500 parts 

per mil 1 ion, corrected to SQ percent .excess ai ry pursuant to 35 111. Adm. 

Code 216.141, ' • • 

4, Hydrogen chloride emissions from incinerators 2 and 3 shall not eXCe/e'd 4 

lbs/hr or the control devices shall demonstrate a minimum HGL Removal 

efficiency of 99%. 

DECEIVED SEP 

VES 000747 
Pa g e t 

i s The; r!# i-R,!?llfrai0,r.| shall fee, §o;fjs*ru,ef£d aB4lfte-T§t^4jsf'$| a; waste cutoff 

^ ini;gr1'OG)< syjs'fera vshieh wf]3 prevent intro^UGfeTOn i f ISffe fcffe the 

1lfe?afl^te vihsR any the l^tl^ M events haye peourr.e<k 

J J . ft!?: Mtam . 

IK WM^iXttg al r p'res&ure- below Iff pSi§. 

:©v Inqiner:,a^or chamber pressure 2" W:..G.,. above aMosphoric for were titan 

0 seconds^ 

d, Emergency .stick opens . 

e\ Fail are to sustain operating parameters specif ieti in special 

•f, burner failure in the |?rimary or secondary civamher> 

g. When prima if" Camber- temperature f al Is below 1 S^Q^F or secondary 

ehamber exceeds. 2£?S°F. 

•h, GarbOn monoxide eoheeft^ration exceeds 500 ppm or exceed 50 ppm for 

more Ifen, three mi nutes; 

For The Incinerator tyft|i A Vepluri S^rubfeer 

f. Quench wjtte^ Mm 100 gpm. 

| , Venturi scrubber Water below 3.7 gpin, pressure drop across Venturi 

scrubber Ijess than 21" w.e..,. Scrubber pH less than .6 and flue gas 

temperature entering the scrubber greater than iSO^p; 

For The, Iniclirteratoi- gi th A Spray; ifepf Adsorber 

k.. Loss of slurry flow to SDA. 

1. ,High hydrogen chlori de .concentration in the stack;, 

ft. High opacity as iridicated by the broken bag detector, 

ii. Ifigt inlet tem|.erat«re %};. the fabric filler. 

6. The incinerators and assc-clated air pollution control equipment shall be 

constructed such that the values of the parameters being menitored are 

displayed for operating personnel. 

7. Operation of the incinerator utilizing auxiliary fuel will be limited as 

to composition and iocineratpr operating conditions which will meet all 

applicable regulations. Such a request should be incorporated in the 

trial burn plan. 

VES 000748 
flt,Kft^Wcftj*iB^. I?rate*ctio;ii Agency - Churchill Road, Springfield it, 6270S 

L r J 

I, Trade Waste incineration shalT subtntt as-buiTt plans and specifications to 

- the Agency as part Of their operating permit application. 

ffs. Prior to operation the new units, 2 and 3, shall be tested pursuant to an 

Ag«npy approved trial burn plan. Trade Waste Incineratfon shall submit a 

detailed trial burn plan for Agency approval prior to startup. The trial 

burh pi ah shall provide for demonstration of the incinerators' destruction 

and removal efficiency, and particulate matter, carbon Monoxide, organic 

materials and hydrogen chloride emissions throughout the range of waste 

characteristics and incinerator operating parameters for'which an " 

Operating permit will be sought. Such trial burn plan should also 

indicate period of operation ot incinerators during shajcedawn and 

testing. Standard condition 9 'which allows 30 days for shakedown and 

testing, is hereby superceded by this condition. 

An operating permit will only -be issued for these incinerators after a 

trial burn has demonstrated compliance with al l applicable regulations. 

Based upon trial burn operation and waste material burned, the operating 

permit may limit the incinerator operating parameters and the composition 

of the incinerator's waste feed, 

TJQV As part of the trial burn plan,, Trade Waste Incineration shall propose 

procedures fpr maintaining operating records. Such procedures shall 

include appropriate notification to the Agency and action to be taken by; 

operating personnel in the event of equipment malfunction or breakdown. 

II, Emissions of particulate matter (TSP), sulfur oxides (S02), nitrogen 

oxides fNQX), organic material (OM) and carbon monoxide (CQ) shall not 

exceed the amounts specified in the Table below. 

Emission 

Source: 

Annual EjmissTons {Tons/fear) 

W> Ul Mox oj eg 

E^Stthg Ineifierator 

Hew In^the^ators 

Storage Operations 

30.0, 

7.7 

15.4 

4.0 

8.D 

6j,.i 

1.8 

6.9 

13-.2 

These limits are based on the potential emissions of the incinerators and 

storage as indicated in the permit application. 

Bharat Mathur, P.E. 

Manager, Permit Section 

bivision of Air Pollution Control 

BM;JOC:jnrni/1857F/25-27 

cc; Region 1 

VES 000749 
Illinois Ewvimnmietl^l Pfbfcection Agency 

i. / WSf^SS^M PERMIT 

T#,ade Vfeste i;fte%e^tJw#- IS Division 0 t 

mmicM Waste l^Hase|in$. 

ifcttW i James u :la ^ 

f Mobile Avenue 

Sittget, Illinois: 6820TvW 

Applicatabn ffHJOom :l,D, No;g tSIWAAP 

J6tfl;iiPiWr S; Dgs^gnatioh: iNSp. a pate Received Hay 24, \$m 

W$M£V£ TWI 20QQ .|efies, 2* ;fffcinera*pr 

QaM 'issued; August TSS iftSS; 

X&mtfms i Mobile' ftyeotte-, Sallget, 111 inois 

Permi-t is hereby granted to the afeoje-Msiffftatea Perraftt.ee tb C0NSTM6J 

attached hereto and the fpliQ^R.g Special cpnditiorits?5: 

1* Particulate matter grtti^MoiiS for the; incjhefatOr shal 1 not, exceed Q-M 

gftint per dry standotrl cubic foot of the gas discharged tb the 

atmosphere, pursuant to 35 111 . Adm. Code 121..i8llbJ.' 

•2, Carbon monoxide emissions from the incinerator shall not exceed .BOO. parts 

pe r mi l l i on MrirmmA W Sfl pr©ent excess air , p&rs^^'Ibio/S 1 11,: Adm, 

Cede 216,141 

A,, The incinerator shall | i equipped vifth sensors to monitor tlie: following 

parameters: 

%v Upper anfl lower combustion chamber exit gas fMptSa^ra* 

b. Upper and lower combustion chamber pressure. 

Spray dryer adsorber inlet temperature. 

d. Spray dryer adsorber outlet temperature. 

e. Lime slurry head tank liquid level. 

f. Water pressure to slurry head tank makeup. 

g. Baghouse tube sheet pressure drop, 

h. Combustion stack gas flow rate, 

i„ Stack gas oxygen concentration. 

RECEIVED AII0 2 3 il l 

VES 000750 
i S£a#ft p § total b;0r&mmw 6W«w M 

W&M; gas Hit, eoii®l^:onj i -

Stack- gat® opaci ty. 

Liquid: anW&r s1uTd||e waste flo» ffiSe into tnje ?a#ifte^a|©;r* 

*"l;l i WSste cti^geiU ' • 

iif fuel preS;s.Ht;e> 

iStfdn. a^r p;re$su're:. 

Pl^toai^y 'Jlawfr $ Ntot flame,. 

Siae#niary epfiei^ & Pttofs, flames,* 

£$e/pge^y st&ek 1 atch * 

I, 

n\ 

a. 

PS~ 

4. The incinerator shall .be ^stfh M 4P4 e.onst^ucl-eid: to ape^te, with an 

•awloijalSfig waste: feed fiutpff th^eyim^jk: systefi' whiefi will prevent the 

introdHCtibn -df 'Wisjb into' the incinerator when opeij'atihg outside: the 

permfttea raflge of parameters, 

a. Startap range of parameters are established bused upon design 

specific-ations and performance tests conducted on Incinerator Umt 2 

and can be changed after successful stack test demonstration on Unit 

3. 

(1> primary chamber MoM 1600PF, 

111 p^ndary c.haiw>ef below l:0pQd,F. 

|tl Pf ftsat*^ or seMnaaW Chamfer ab.qrtfe aMospheric: pressure, 

(it Sb.ray dryer adsorber inlet greater t&an BfoOPF.' 

(51 Spray dryer adsorber outlet greater than 40d°F or below 

' 370PFV " 

(6} Low liquid level in lime slurry head tank, 

(7) Low;, makepp water pressure into slurry: heat tank. 

W) fiaghbuse |uSe sheet pressure drop greater than 10 i riches water 

column, 

(9) Combustion stack gas flow less than 5,000 acfm or greater than 

15,000 acfm. 

(10) Oxygen concentration less than. 6% by volume. 

(11) Carbon monoxide concentration greater than 500 ppm. 

(12) CarJjon monoxide concentration greater than 50 ppm for 3 minutes. 

(13) Total hydrocarbon concentration greater than 100 ppm corrected 

to 7% oxygen* 

(14) HCI concentration greater than 100 ppm for 1 hour. 

(15) Opacity greater than 10%, 

(16) Primary fuel pressure below 30 psig. 

(17) Combustion air pressure below 10 inches - M-X. 

(18) Primary burner failure. 

(19) Secondary burner failure. 

(20) Emergency stack open. 

VES 000751 
Page 3' 

is,.. o>Bi,aM.^ jmstititespn «fll ?&> ss^itsiiaf. IW £ ftp* s^5se^ai «*s 

ietual «5&N$t9ff- in& fflSBSRa*. SB^^BCK ifflrtil trial birtW. ' 

5v The ttefmrsm? ©tf-stsSie^ilBll ;air |QjI«tfon iej«rt#e3 t|tt%seaj| jft&if. 

,te G0ns#ac%dl s«en that the viTHes. of tjte |f^'ffi|ig^.^i$|rigt 

aMW'&r figfftlJp* 4f• ^^rtiiTO^ IsfSlt^ ^ jfijps^. for sptf^ft l 

||ri'OTMf li t -^f lli i M vfsuli al.§riis 

6. The Pgj$ttt£& shall submit as MH I plans, of the InGlneratOT and af r 

p^flutftoii •G^jftrol equipifieht as part of the operating permft appl f cation;, 

l:i The: permittee shal J not initiate the start-up. of the iheineratb'? without 

wWtteft app^tyiti fP H Me Affeflcf. This special' eonliiMon; sHpk^f&s 

standard gawiilfefi 6{b}, 

§. stack eiflfsloii tests shall Si eonjueted m this Unit 3 ^^m^atM 

esiiiji isiv eiraissipi rsies.- Std ggmpliawcfi Wi th the applicable g$g^k1$fct&. 

The: required stack tests' arf 1ft M conducted by an iftdependf g^'tss^elv 

•a* Emission tests are required for the foHiwihg loTfuja&Sif 

earlon; RbfldXide. 

C5) Principal organic: hazardous components:. 

a* The Permittee shall submit a stack test plan at; least 68 days i n 

advance for Agency approval. The plan shal1 contain detailed plans, 

and procedures. 

Written notice of the scheduled dates for compliance stack testing 

shall be given at least 30 days in advance to the Agency. Final 

notice shall be given verbally not less than 7 days- before emission 

testing begins. The required notice shall be given tp the following* 

Illinois Environmental Protection Agency 

Attn: Permit Section Manager 

Division of Air Pollution Control 

P.O.. Box 19276 

Springfield, Illinois 62794-9276 

217/782-2113 

Illinois E'nviro.nmentai Protection Agency 

Attn: Source Emission Test Specialist 

Division of Air Pollution Control 

The Intercontinental Center 

1701 First Avenue 

Maywood, Illinois 60153 

V ES 000752 
& f¥iW!m g$$r$H& Permittee sftal;1

! sitett ?l§|r«B!pi^c» arid . 

BiWitortrig gpsftflMMMtltt* p^olal : ##r the; il|afjs-a# Keford feeepifig 

and repot* foBnals' Used to shot tifflpi^i^v tlie l «tatif| s of |fi.e. 

opBrs^njf •piWffleas^ .t^pCt^l H I s gpn|^e|t f:ft spe^iaTlS^flllW t 

|fr% eoJiftMctton perntft sftall be :#ti$ntf feted to: tile Agency fpr approval. 

•m, Tht i|j^i^^^^M--' :@HS4'-^als Ittggfitp equipment sfiaTJ pi^vMe f§r 

storage of \QQ% of the incinerator parameters an4 stack monitored 

results: in: -£ Olm^uier pBaJiabll fd'Mat, Sopies shall be madei 

!a^aijafeii^ to thf .Agency; in; a: stfi tabfe computer readable format, 

b» Tie data Togging equijpmeht shal l also provide for recording waste:* 

analysis piagefe* for al burned v&ste 

e

;

. The :4fta l<Sg|iiig equipment snWH provide fel l time; acpiss to the 

ineineHater operating parameters through a teTecomrtunfeatioh computer 

p*t , *" 

The proposal shall §efe^r|:h„ite hardware and sof tv/are spectfi Rations 

for the; ihfbrftiatiop system along With available options in report 

formats' arid data exchartige modi a> 

e. The permittee Shall install a computer linkup system with IEPA 

Springfield, I£PA CollinsviUe and some location with public access. 

Such a system and location will require Agency approval. 

. Prior to startup, the Permittee shall submit details of an operator 

training program for Agency approval. " 

. Prior to startup, the Permittee shall submit for Agency approval, 

specifications for on-site security including video cameras, monitoring 

cabinet locks and seals and details of security fencing,. 

. Emissions of particulate matter (TSP)., sulfur oxides (SO^), nitrogen 

oxides (NOy), organic material (OM), and carbon monoxide (CO) shall not 

exceed the, amounts speciffed in the Table below. 

Illinois mffl8mm$fil PPitectfo'n 

JjfyiSfoii of Air i^Htftlon Gbfltrot jleiiWii. Office? 

Eriri ssion Source TSP 

AnnUai Emissions (Tons/Year) 

SQ2 NOx OM C CO 

Incinerator Unit 1 

Incinerator Unit 2 

Incinerator Unit 3 

incinerator Unit 4* 

Waste Storage 

15.0 7.7 4.0 

15.0 7.7 4.0 

15.0 7.7 4.0 

16.92 50.76 61.6 

0.9 

0.9 

0.9 

3.1 

6.6 

6,6 

6.6 

13.68 

VES 000753 
Illinois Bn\ycqi«mgnt!il PfoteetioTi 2;20Q Gh'^rCttiU Road, Spring?fel,a. Ji, 6&7.Q6 

*These 1 ifirits ari established based 0:0 72$? hears ef operates Bfer year 

and averts aitsffbft. rates; 'given tff the a^«%tii$ B> These: 1 pf e Will be; 

revi'sStt site* the s%#; |isl remi ts -aire, ^e^M&A 

please note that the start-up arid trial burn plan m subtriitted with the 

applliEiatiQ'h i& ^n%^ss^^%m Plan del^iotetgs tffll be tdehtlfied at ft 

filViffbn o f Air .Pottatlofi COntrol 

ce> Region 3 

VES 000754 
Wm$tCiUM^%$Xj PROTECTION A&ENGY 

j July 1,1985 

fjisifliptt of Afr ^IJtt^on GatiWl 

S|>i?iii|fi#d, BM&eiB 62706 

ft regional offitie ijf ttte j^Mft 

Operations Soetiph. Tji:e regional 

dfficeBaM:%ejfcarg&s sfteBfdiwiiiJij^ 

are tihawft <jijt $|£p.. Hfoe "attilEieBBeB 

^dfeleplip^e liMipbere of I6e f-egionfil 

"S.eg| aire iks Follows: 

lUinoiB EPA 

1701S, let Ayeniie 

•541i> Naftli University 

£iajria, Illiuois 61614 

691-2200 

Illinois El? A 

2a&|3Msiil Street 

^Qp|#8*ilig, IllinoiK 62234 

'345-Q700 

VES 000755 
illinois Environ mental Protect ion A$mcy < 22ftf) ChsfcWH Ro.a4. Springfield, iL 62706 

CONSTRUGTleN PEgf«T 

Trade Waste Incineration 

It fif^lsojn, W #amtSa1 Waste Manag^erii 

Attn :? tames L. Gary 

7 Mo bi l ft y e n ue 

^auge^ illinois: 

6®R1ffMa>* 88010001 

Mai ifa»^|1^.djia>^ga| il^Jtl $4 

•Subfect; Tra:rrsng.r^tb:le Rotary Kiln Incifierafcor 

flater issued,; August 1988 

Location* /"Mobile Avenue, SSttps, IL 

I A . te> t 163121 

M&mMarch 2% 1988 

jerwii notary i« in incinerator Unit #4: equipped #|jh, a dry scrubber and. 

a b:a#0.U.S:es as described in. the abovsrfrefer#:nc-ed application. In is Permit is 

snbpet to standard conditions attached .fe^i f and the following s-peeial 

COhditiionis): 

|% Particulate matter ^missions frolfl the iirclne rater shall not e>?csed ti,£8 

grains pjfir dry standard ciibie foot of; tft«s i p discharged to %hie 

aisnosphere, pursuant to ss in. Adm., Mete I2l.:18?(b). 

<L Carbon liionoxide emissions fPom the fnei iterate* shal 1 not exceed 500 parts 

per million corrected to 50 percent exfeess air., pursuant to M III* Adm. 

(lode 2.16,141,

 ; 

% The.incinerator shal 1 be equipped with sensors to continuously monitor the 

\ . foltoWi hg parameters; 

a*. |pf). and seeeodary combustion ehambier exit gas temperature,. 

' ;jf. lllffl. and sMIttSdftff' combustion oham|f,<E|r pressure; 

0. Spray dryer adsorber inlet teiiipera.ijjtire, 

1. Spray dryer adsorbef bullet teroper&tu^e* 

, f ime slurry fei3 tank liquid level low,. 

Water pressure to slurry feed tank makeup. 

Baghouse tube sfieet pressure drop. 

Combustion stack gas flow rate:. 

Stack gas oxygen concentration. 

Stack gas carbon monoxide concentration:. 

Stack gas total hydrocarbon concentration. 

Stack gas HCL concentration., 

i fri."-. -tack gas infrared absorption. 

| n... i qui ci and/or sludge waste flow rate into the incinerator. 

I lid waste charged. 

VES 000756 
ibis; EttyirQtimehtai Protection Agency ' 2®6 ChurcM'U ftoad, Spfingfteid, IL 62:706 

§) 

£o#us$:feo tit* pr^ssarf.. 

MsEinWI^ S.wT«i&m* Pilots flame, 

'Eiifeplfey stael. latch* 

The: ifiGiheraitor shall le: .-tije&f|pw& aa^, •g#ns«,raete«l to operate wjfch an 

.aylomyilf ^ E S * 6 feei i»lslf ifil^lock sj^Seni Wht# wil] prevent Me. 

piratflel rangs et parameters, 

a. Startup range of parameters are establ-fehed based upon design 

specifications and perfo^aiice tesNsS" esridueted oh rncinepaior 

and can is- changed after-" siucfe^ful Stack test, demonstratipn on 

tlnit 'i. 

b. 

chamber below 160 0 F> 

Secondary chamber' below; 

Ki lp, ^^eiggtii^ry abiave atmospheric pressure* 

f o r below 

(12) 

(13) 

IB) 

Baghduise ttfbe sf!ig$ pi^SS^ s tlrOp |t»^ W than 1Q inches water 

eoiumru. 

Owgm coH^eflt;p¥tib.rt te M tha*i 6% by Volume, 

Garlori monoxide elhfeMI;faftTork greater tftan: jiplCarbon monoxide concentration: greater thaft 50 ppifl' for 3 minutes. 

Total hydrocarbon concentration greater thati 1DQ ppm corrected 

to 7% ef^gen one hour running; average, 

lie! concentration gteater tiVari 1Q0 ppm for 1 hour rurini ng 

average, 

0pSCii*y; greMer thaft Wik 

PritfiaJry; fiieT pressure M s ftQ: ps3g. 

Combustion air pressure below 10 inches W.C, 

kiln fotmner failure. 

SeeMlary burner failure. 

Emergency stack open; 

Combustion stack gas flow parameters will be establifheiji, at a 

lafer 'stage,' 

Operating parameters shall be established based upon evaluation of 

actual operation and measured emissions during a trial burn. 

5. The incinerator and associated air poll ution control equipment shall be 

constructed such that the values of the parameters monitored and/or 

indicator of acceptable status are displayed for operating personnel with 

audible and visual alarms. 

VES 000757 
\ Illinois Enyiro^itteintal PrOteclibti Agenfiy ' 220tf ChureMH Road, Spriffgrteldi th 62^6 

6. The Permittee shall submit as: built plans f or tlje; feg|i^fe p ,pd ai:r 

•pji'lulfin: -g^ffi ! equipment as: part of the operatf ti| fWffiit ip| l ie&itdh, 

I* Tte HmiMee sftall hot inltiale ifj$j start-tip pf file' inelne^tbr wjibjtui 

m^ttim !s^^MWM ffsm •%<? Agens^.. Ihis" socia l cohdilibl supersedes 

standard condition 6|pj.v 

8, Stack gnfisitei. MIS ' shaft be: Conducted on tliis i«ci»6pato> to establ ish 

emission/ fpgs and c&fpliBftee with "the appl l4#Xe rejulatidns. The 

required stack tests1 are to fefej'Qo^dM^lejl.^ an independent tester*, 

a, Emission tests, are: required: for the fotllOiitfg polluisnM?' 

| l) Particulate, matter. 

(3) ^itr^geh oxides. 

(4) ,0arbb:ri moliOfife;.! 

(51 .Desijr^to.11 ajf' §riije1|$t fr^iftifc Mazardous components, 

.. b; Ttie Permittee steal! submit a startup plan Shoe trial buW plans and 

pj*0jrfl!t^ Suen I. WW burn ||ift shjMi rSfuire the Agency* s 

approval 30' days pripr to any st&ft-uo; afid testing, 

c. Writteri notice:, of li e s:dh;e4ulfed dates for cpmpliance stack testing. 

jsi'oti 

iowinp 

Illinois Environmental Protection Agency 

Attn:: Permit Section Manage1*

1 

llfvfsipM %fMf- PMfution Control 

Springfield, IL 62794-9276 

217/782-2113 

Illinois Environmental Protesjfefiaf: j&JBffl^f 

Attn: Source Emission Test Specialist 

Division of Air Pollution Control 

Intercontinental Center 

1701 First Avenue 

MaywDQd, IL 60153 

312/345-9780 

Illinois Environmental Protection Agency 

Division of Air Pollution Control-Regional Office 

2Q09 Mail Street 

Collinsville, IL 62234 

618/345-0700 

VES 000758 
i S - Illinois fes&ofi^eflllet ffroi^#m AgeHcf - g^W^BSJ SMwni, fL«| ; 

t, Mol * to SSftftHfr*. the Permittee: ShftYl tgtaait Ih^lplW W Wtf 

Ittittopittg speofffeafiiaisf ^ p^pss^l w She: ae«&fte o# rectoM 'HMrfei 

fftf repot* i|^a#s u^esl ^Q: eMpTiMe'e; with the o f 

#^%t|n§ pis^mifefi r^st^l' M te'jflejgf^&»a IW special eojilfiga: ^ of 

4g^- : &gi^ ^ fee submitted to |fie fenjy fpr WpWlv -

' a, 'The 'imwmm^rm ahf fata; Togging equipment shall proMi§*f6¥ 

st^rafe M' W($$-of $he i^fegj?aii ^ parameters gsi.^iaieWnii^e i 

MsuTts/ TO a «iiupju|^r r-ell^Ws fswat- espies; shall DB wi t 

availalTe tp- ^fe*lp W tff a tuitablje computer re;a#bl,e; format,. 

• bw; Tne: tfata lofgifig; esufprnent iftaii alsp previiie for- reeotdihg waste 

•srialfsts paMWe^ei? fer i§ burned -vitaste/ streamsk 

c... The #at& logging epip^ ^ p Wid e ^eal time access kg ihe 

inefperailor BBfK^ng: p^ame}ters; through -a. te^eeom|?upieitiQn eomptifer 

dj;. The proposal shall set forth the hardware and software specifications 

for the information, system along with available options in report 

formats and data exchange media. 

% The permittee shall install a computer linkup system with IEPA 

Springfield, IEPA Collinsville and some location y/ith public access. 

Such a system and location will require Agency approval. 

iibv Prior to startup, the Permittee shall submit details of an operator 

training program for Agency approval. 

11. Prior to startup, the Permittee shall submit for Agency approval, 

specifications for qa-sita security including video cameras, monitoring 

cabinet locks and seals and details of security fencing. 

12. Emissions of particulate matter (TSP), sulfur oxides (SOg), nitrogen 

oxides {MO^), organic material, (df4), and carbon monoxide {CO) shall not 

exceed the amounts specified in the Table below. 

Emission $pM# W:ssi&ns tfWs/Year): 

Source , %W iM IjQx, OW ..Cj) 

Ilicihferatpr Unit 4 11.92 5:0.76 6J ^ 3.1 1$M' 

These limits are. establ ished based on 72;p5 hours of operation per, year and 

average emission rates given in. the: application. These limits will lev 

revised after the stack test results are reviewed. 

13.. Prior to startup, the: permittee shall provide detai 1 s of the Quality 

Assurance/Quaii ty Control programs for the monitoring systems specified in 

Special Condition 3 above for Agency approval. 

V E S 000759 
Illinois Environmental PBOte^ion Age^ y ' ^PIMttlsiM. $p*t#eldj It. 

Page 5 

t**tat- torn fiiM 

uition Control 

sos. Segfpji I 

VES 000760 
mm mM0}mmm 

SH#WiR3@^fr:4pas^dJis are iapplicafcle unless a^j^rseded^'^^gi GOH^IIB»M. 

year 

2.. 3Ph£ c£nS!br«#^ 

fc% Illinois Ewfeonrnental-B^^ aSopfed'Tjy the Illinois feirtlutibn Control W<$gx$h 

§'.-. iiierB.«faalI|jfi;HO #wli3e(|fflS i®mi|ig:4$pj$^ r#$Lies.t fsl^^liei^a, 

ale'rig; syitfc .jalkliB -iifia: ^cM^tti^s, *S ^ r^juirfe* JiMlfee:.#(^ a^lt^ a ' W & an!4 k :|jj^lera^Ml 

Tfce j&pfiiiftee shall allow any; fuly authorized agent nf fee i%e ncy upon, tkts presentation nf credential^ a*--

-reaBgxjalfe. iifces s 

'whefce ;any;a'efe|iy ia. to pf qondu^ept pufcsiSHift' |^k |i&r^il;, 

b„ tp Jiaye acc§S*S |o„^Mo<iicApy^^a;i^'|^ss3g''r^#teeAfa ^ kept under the terms and condi tibna of this permit, 

ci to;iiiBpeGt,ini6ludiag during any tours af* i$gBra&3a.^ Operated u&der, fnigip^j^iJti 

g«en'%tfij!ffi^t*a^/ftftB' e^aipinent required tfrhe: ^Mk, W^GM^mA 'MlW^^M^Mi^^^Ms-: Mis 

d tp obtain and temolre samples of any discharge or emissions of pollutants, and 

e, -to enter atid utilize anypkotographic, recording, testing; monitoring ot otter egnitmiejifc ffcr the ^purpose of 

preserving, testing, motatoraig, ot recording any activity, discharge, or emission authorized by this permit 

•5. Ife: isgu^cg of this perftiit; 

a. shall not he considered' as in any maimer affecting the ti'tfe of the premises upon Winch the pefrnitted 

facilities are to be located, 

Us. doeB'riot release tne permittee from airy liability for damage: to per'soii dr property caused by or resultmg from 

the construction, maintenance, or operation of the proposed facilities, 

• c, does not release the permittee from compliance with other applicable statutes and regulations of the United 

States, of the State of Illinois, or with applicable local laws,'orctin&nfces and regulatione, 

d, doies not take, into consideration or attest to, thg structural stability of any units or p$r£s Qf the project, and. 

APQ^tS^tllv:, I13/U.S1 09Q-O0S 

VES 000761 
Etesian of^Afc' 

"ins Sfictftrai IBjs- "' ' 

VES 000762 
m "srtj/siBHsna 

mffl f mM&Rtm AMD fWPS i paiif? 

tmde Ipiiil ittMfieMtioti; 

& of ChepiesJ SfesM 

f

;

loMTs Avernje; 

SM&aetefes TanK; Farm MdMber % 

mm 'mums ;auiie s&t is p 

iteafieft: 1 fflabife ASeinue;,, It 

Permit is hereby granted to the above-desjgnated Remittee to CONSTRUCT and ' 

OPERATE emission $ouree(s) «thd/or air pollution control equipment'consisting 

of ten 12*000 gal. and sixteen 30^000 gaT. waste blending and storage" tanks 

with carbon adsorption and ^sjsociateti truck and rai l car unloading stations 

with va^or balance as- described In the above-refereflted application. This 

Permit is' subject to standard conditions attached hereto and the follnynng 

special condition (s\): 

U 0pei"#i,o;n; of the emis&lan s^reels i tnclMed. I'll. Wis. pgfTfilt shall not 

tseftn ucnfSl al l s^^fajagd aif j?6;Ttoti;£>h control equipWeht has been 

^nstWt.ed: and i;s y$^$:$%$Mi 

f« Wlthth $0 dafs: fpom the* !'gsi#j|e. <o;f tftfg pMtt i 4 carbon. §$sf$§^ 

breakthrough monitoring program sftall be submitted for Agency approval. 

%eraj%n M tM s tank farm; s%afj;l not begin until M^^m^,a^m&i 

I,s Emissions; of $^anic materia:! sJraCl not exceed 2,5 tpnt^ear, t## l;fni£ 

l i :&asej| ah fh^ria^lojj prjsvlfed fh the flp^fea1fro;ni 

Terry t^K; Sweitzej^PvIE, 

f%jia|#,. Permit Section 

Division of Air Pollution Control 

TAS:JD£:amm5/49a9H/S.i 

cc: Region 3 

RECEIVES m Z $ fl88 

VES 000763 
yjie ffinoMfittg-coiiiilbi^jB ire. ^ 

3(fifi^ fi$li: gatis of Seauaae^j u^pg f ij$j^$q% ^rflg^amof conetruslipp or 4^fopjpa:ent o» this j^^t e 

-^pg WMm sat ^ec^bajiSli W Wj&fa^&iM hwete « |a|:fE#ep| jig- iM ^meg-m&m n^j^t^MM' 

0%. P8e-|iBSB0lJstee; ^gi'. sssjftp-' ftgc^eQjy- njdSna^i* agltt-i f £ ife iipm torn f «e|etft|tfei «*f SHU^0M%- «*• 

a. tp)fcnter; l^e pef^tt^e's peojjef ty wlierc ac.tuftl o^ppientt'al effi^^ hoisd sourses are located or 

j$rgCe ajiy activilysis fo he eftftdugjed fthratiant o tlus 'peradtj 

\ B. to have access to and to copy £ny'recqrd's required to be j^pt ujade* the.terniB and conditions b|; thi's permit, 

c. to i^pf^fs j^fl^ftg-^^ug •aiay;&^fi'^lMffot' equipment eona&uete:! pr ppgi-aied i|n.der this peraait, 

sUcK^ to he fcepf), used,.opetatedi c|ijipfr'a:ted aiid maintained Un#r 'tliife 

mmk "' '~ « - •• • 

a. , to; obtain and retnove gsiiiipfes of airy d.wcharge or ejp|s§jipn6vpf plUtttanls, and 

0>: to enter and utilize any photographic, recording, testing, monitoring or other equipment for the purpose of 

preseryiftg, testing, monitoring-, or recording sSiy activity, discharge or emisBtGn authorized by this permit. 

Mk< "$he issuance of this penult: 

.a, shall not be considered as iii any manner Sf%dUng the title of the premises upon Which the permitted 

facilities are to be located, 

b. does'not release the permittee From any liability for damage to person orproperty caused hy or resulting from 

the construction, maintenance, or operation of the proposed facilities, 

. e> does not release the permittee from.cotnpliatiije With other applicable statutes and regulations of the United 

I Stateav of the State of Hlinojs, or with appucfibie local laws, ordinances arid regulatlolfts, 

di does nOt take into consideration or attest tp the structural stability of arty units or parts of th* project, arid 

Af>G <B6 tR=v. 10/851 G9&005 

VES 000764 
The Illinois (fll|kq& Ife^sgjl' iSfiatfttejev -SSteffest l&i-tjk, Seetiba WIU" iSW* th© 

BiLviconxoiei^I ^l^^nj^^ ^ S&t£g^^"feiEgtt^ ^ffiip^ioafi^a^S: #M^S iCiasu.es. 

conaiifona ate applteable iinlesa si|#ggB|ifeft. by special permit; cendjtion®. 

% ,|^jLg§^,J ^ *?8l?

3

4. M§/$iiS>& teei upoti, $ie..feTfliroatioa s)ib^^a bjr t%e-' fe'Eitfi|f^r$S' the jpr-ntffc 

dteg--iBl#^nS,gjtg% false: ^a|gj&§$j,ji of ;ttisp«ssen&*!pii .lid, *h/e.: £gpllea#0!i Shalt he gtopuadfir 

St.. a.. •pleiJ|^^1^fe:

,

4^||^^&#, stttorfSg};.aljf^&llf : j^odafioaiion, 'aB;. defllieS in. 36111. Adin.: @ode. 

•M||£$a|L3i^ fp'r^ievMpp;o|tfe ^ji$j|ag£iw^^ 

tt^piJitoItrQr. revisieti 'of

 ;

|i^Meifcinfoget^l^)1 ltiiB^ed. for-isucl inp;di5c|Liiipri. 

'b;-: ^bla germiiv aaljc ^If^S'eaTtiagion aetl.tJC6J|, ifd •control ed^uigiiRelit S?hlle phyEically pr^sM^ at.the indic&iegl 

nd|^illiSMadiii|f the expjr#ipn d£.te specified On the p'ecjiiit4. Th<| prjnitfeee shall AIIQW aay\duly auihoripd ageSt of the Agency^ uppli the presentiatioh ot. credeHiMsf

 alt 

fcgjgiiiable; times: '• . 

a. to fen|iefc fhe::.|«stiBitfcee's property, tyhere actual or potential effluent, emission, pr noise sources'toeifpgatSd or; 

vftere:;fii^a:ctiyity is to he conducted pursuant ,(a this permit, 

h. ,t^'|iftyp aeces8 & :an.d.|b. gdp^-.aTiy, woof p*s rgqiiii-gd tp be kept i^d^r':tb$ tlrjna:an ; d «Ojiffiia£8 of this permit 

•••Ci ito inBpee^ this permit,. 

;g;q^iprnJi.iiii and any-equipffiejtt:£^ cfiibr^ted a,nd mainia%e,lj.^fe,|his. 

perihit, , 

d; td, obtain and rejtnove samples of any disc)ia$ge~ or emission Of poilu;ta;nts, and 

e,. to enter and utilizij any photographic, recordings testing; moriitpring or. other equipment for the purpose of 

presetViflgi testing, monitoring or recording any activity, discharge or emission authorized by this permit. 

ii. The! issuance of this permit: 

% shall not be considered as in any manner affecting thfe titte of- the premises upon which the permitted 

facilities ^Lre located, 

b. does net release thepermittee from any liability fprdamage to person or property caused by or resulting from 

tlie construction, maintenance, or operation of the .Facilities, 

V E S 000765 
%> i^mkW^msm 

M ...... :2&. COUHTTJ 'JQ»* B> 

,mmWM SPSS! 

'IS* THE flH A m$ fti$$&M M P S )« rails; 

BECgEijSp 

PERSEfHiKGE BV WtCH: 

CREflip; ol DECREASED: 

ED; «?. Q *io * 

Q; VES P N O :

 li, 

P m • 

. .. 

',, :l.;'V?CT,T^i^r--^-CT»-r;,'iT P.rfs: ' • «o i: 

Sao!.. 

Wm::m R£GS,v CHWTfif 2, fi t ISK^ -AS' ABof-tEB. AP49L T?fe$<ge'Sj^'flt 

"NT. "Oft SIGHATDRf jUST; BE THAT OP IHf, Pf«50M AUfTHORIZEO TO tDiJERTE: A!i IMf K 

AUTfioRli'ED. SIGNATURE . . . ... 

A COPY Of THIS FORM Hl)ST EE SUBHITTED FOR EACH fiERfflt' APPLtCAflOi LISTED ABOVE. 

THIS OOCUMENT IS HOT A PERMIT APPLICATIOfi AND IS SOLELY FOR; STATISTICAL KHp: Sf%i4AjIQ.H.AL. PURPOSES. 

IF THE WfiOtTldS CONTAINED, IN A LISTED. PEflJIT APPLICATION IS HO LOSGER CORRECT,. HATfRIAL CORRECTING THE , SRPLVGAf ttN: SHOULD If SENT TO THE PERMIT SECTION OF TfiE DWlSJOlj 6p AI« PQLLUTjqN CONTROL. If THE CORRFf'TrnM IS DUE TO A rtgOtrfCATION (IKCRCASE IN EMISSIONS), jofc NEW FTOTPHWT -ru-V" coHSfRUOTOtr fttfct* tn&- «•«"• 

VES 000766 
V E S 000767 
Section 2.1 (C)(2) Modification of operating parameters limits (OPL's) Table. 

; Pursuant to the Request to Provide information Pursuant to the Clean Air Act 

dated June 5, 2608 and subsequently revised on September 12,2008, attached 

is a revised Oper ^ Parameters Limits (OPL's) table that reflect the mercury, 

S V M and LVM QfVs defined in 46 CF R 63.1209. 

The OPU s were modifie on the results orthe performance testing that 

r ^re'^i(if^ve6^t^ USEPA, Region 5 on August 8,2008 and conducted in 

August and September, 2008. These test plan results have been submitted as 

part of the Flequest frorii USEPA described above. 

Veolia has extrapolated metal feedrate limits for mercury, SVM and LVM. These 

feedrates were e ^ using the protocol provided by USEPA (attached) 

and included in the Performance Test Plan. The calculation sheets are included 

with this request, However,; based on the extremely high System Removal 

Efficiencies (SRE's) achieved during this testing, Veolia has lowered the 

extrapolated metal feedrates for SV M and LVM at Unit/4 to account for historical 

; M Veoha has also 

lowered the extrapolated metal feedrates for SVM and LVM at Unit 2 to match 

those values at Unit 3 and again taking into account historical metal feedrate 

dataas defined in 46 CFR 1209 (n)(2)(ii)(B)(2). Attached data sheets detail the 

extrapolated OPL's compared to the requested OPL's. 

In order for extrapolation to be utilized, Veolia conducted these performance test 

using metal feedrates as defined in 40 CF R 1207 (f)(1)(x)(B), that were greater 

than "the historical range of normal metals feedrates" fed to the units over the 

last year. Included is a table that defines average feedrates for metals over the 

past year compared to the actual rates that were spiked and fed to the 

inciherators during the performance test. As is detailed, the metals fed to the 

incinerators during the performance test were significantly higher than the 

historical range of normal metal feeds over that year and in some cases were 

higher than the 12 maximum values. 

As stated above, Veolia's extrapolated metal feedrates defined in the attached 

table used the extrapolated method defined in the Performance Test Plan as 

required by 40 CF R 1207 (f)(1 )(x) (A) and given to Veolia by USEPA Region 5 as 

an approved method but also took into account historical metal feedrates for 

each unit in setting these extrapolated values as required by the 40 CFR 1209 

(n)(2)(ii)(B)(2). Veolia is requesting approval of these extrapolated feedrates not 

only because it followed the requirements of the Regulations but it has been the 

Agency's practice of permitting extrapolation with other Region 5 incinerators. 

Veolia request that extrapolation be approved based on the merits of the 

methodology utilized, the metal federates at which the performance tests were 

V ES 000768 

\Ve61ia.' Environmental Services Page: 13 o f 176 -

. Permit-No/': ;'V:-IL-17163001p3-08-01 

.21 .'/.permittee, must'operate" Units 2, 3, and 4 under these 

'•'-. .../ operating.parameters limit s (OPL's) to' demonstrate.. 

^;'..:"«:^p^pliauveei; with'-.-Subpart; EEE. - - - • 

.Operating Parameters . ' .' • Onit #2 . Unit #3• Onit #4 • • AWFCO • • 

Minimum primary cOnibuStion'-

-• chamber; temperature. -

V6Vl ^ ••/' 

1,712'F l t 734°F ' "•'. 

Liy.712 . " 

l r,50Q°F . 

1, 507 /•:':. . 

Minimum 

hourly 

rollin g 

average 

.Minimum' secondary .;• '•:_" .• ..: 

'p6mbii.s'tion'"clii^be'r'. •: '' ; • ;' 

temperature ...' ' .,-

'• (63 . i209 (j),'{£); (ki (2) )':•:-..' •.. . 

l:, 8 48° ? 

li?:845' . 

1,850-°F, 

L ,845 .. 1,886 

Minimum 

hourly 

rollin g 

average 

Maximum flue .gas- flowrate''..' 

or production :.rafce'- ••' '•:- -

:;(63/l'2b5'(j)'f25')';-'':.(fc.) (.3),

 :' 

(m) (2) V . (ri) (6) , lp).m) -. ..' . 

10> 3GO.acf/ 

min 

15,147 "-. 

'1-3 > il l acf/., 

min 

15,147 . 

.43,-400 ' 

acf/min. 

38,08 6 .'''.-. 

hourly 

rollin g 

averages 

Maximum-hazardous Waste 

pumblable feedrate rate for 

.each/ 'combustion chamber'.. 

<63.1209 (j) (3) , . (k)(4)) / 

3,003 '. " 

lbs/hr 

3,123 

4ylG0-

lbs/hr ' . ' 

3,123 

W*3,256 

lbs/hr for 

•PCC and 

irW-1,006 

lbs/hr for 

scchourly 

-rolling 

averages 

:

 Maximum , hazardous '.waste .'-•;' 

total-' feedrate; -rat0..'.for-' 

.eaen .'combqs.tioh . chamber .' .,' •, 

•;/6i;:;i'2:p9/(j) (?Vr/Ykr/<4f). '•./. /' 

4,140 , . . 

lbs/hr 

4 ,301 

5-, .34 4- .. 

lbs/hr • 

4,30.1 . •:. 

17,-907, ^ 7 Q , 

..ibs/hr mt 

E.CC- and' ". 

p*f*f. 1,006 

•lbs/hr. for. . 

.SCC '. '• 

hourly 

rolling 

.average 

basis 

Operation of ':wa$.te/.firing 

'system- for each : location 

'.where waste' is fed-to' the'' 

•incinerator' (6.3; 1209 ( j ) (4) ) : 

Minimum 

waste . 

atomization 

pressure 

for low BTO 

was te - 15 

psi 

Minimum' . 

wasteatomization •• 

pressure 

for-low BTU 

waste - 15 

psi 

Minimum• 

waste . 

atom'izatioh ' 

pressure 

for'low BTU 

waste - IS 

psi ." 

Instantan 

' eous 

Maximum temperature of the 

gas., at the inlet. 

.(63;u:09.(k>tij.)v:'lny:(l)) ,.: 

.420° F 420°F 

434 

hourly 

rolling 

average 

Minimum carbon' injection ';.-' 

' .idtji.' (63 . 1209 (k).:(6r(i))' . , 

N/A N/A • -6-'lbs/hr . 

.6.2 

hourly 

rollin g 

average 

Minimum .'carrier., flui d (gas 

or liquid).'flowrate or /*.'/ •' 

pressure .drop . •' - ' 

(63.5209 (k) (6) (.ii ! ).,'.. ,•/'.- ': 

N/A . N/A , ' ' .miniitiuiA ; 

' high •-• 

pressure'; 

• 4 psig 

Maximum low 

pressure: ' 

1 inch H20 

hourly 

rolling 

average 

The brand (i:e., 

manufacturer) and type of 

carbon used during the 

comprehensive performance' 

test ,(63 . 1209 (k) (6) (iii) ) 

N/A N/A NORIT 

Americas 

Inc. 

DARCO® FGL 

Total feedrate of mercury | 0.0174 0.0174 0. 257 12-hour 

V ES 000770 
'.'Veblia Environmental Service s . • Page: 14 of 176 

VWrmi t ^o/:.-V7 IL-1716300i03-08-01 

"Operating'' Parameters , Onit #2 • Unit #3 Onit #4 AWFCO 

(G3.1209;:(l) (1) (i)> . . •; rolling 

average 

Maximum.-'ash- federate • 

"(6l'^1269'jiiv)'{3iV : • . •-./. 

• 673 ;'./ 

9.13.4 

lbs/hr, g 7 3 . 

7,CSO 

lbs/hr 

8,777 

12-hour • 

rolling 

average ' 

•TQta;li-'fe.e_sira'te";'of '-,.'. ' 

seM.^yi'a'tiie;Ve.tai.s 

^^:^Ql(nf';t2T:ii 1 > •.; v.;-'.; -/. 

V 45'9.' \ -4S9-.. . 500 

12-hp.ur 

rollin g 

average' 

limits 

Total, .feedrate-.q.f' low • . 

•.yoiatile-'me'tals - : '. • "• 

120.9 (n'V (2.) (ii) ) .• . .. 

399 ' - - 399 500 . 

12-hour • 

rolling 

average 

limits ; 

' .'Feedrate-limits!-.for low ••' 

•.volatile" jrietais" i n pumpable 

feedstreams '-'.- •': •"• 

.(e3-.iZ09-'('nr-(2) (vii) ) 

368 368 ' -427 • 

12^-hour 

rollin g 

average' 

limits 

Feedra-te-xif tota l chlorine 

• •'and;chlqr'ide .in' al l •' 

•'feWstream's'' <63.i209.(n) (4) > 

;•'(ai:(i).)':. /-.,: •'//. -.• 

- &5*~. lbs/hx . 

. .22.9. ';. 

lbs/hr • 

... . 229 

-e^H- lbs/hr 

252 • 

12-hpur 

rollin g 

average. 

* Minimum, sorbent'.' feedrate 

; .t63'.'li09.;Co)'<4)''(i) ) .. . 

1.76 lb/l b 

- • rr-? '- 1.76 lb/l b 

'

:

 C-l°' r' 

1.01 lb/l b 

• Minimum"- carrier , flui d • 

; .f ipy'ratel or .hd.zz.le/ pressure.. 

v 'drop ;;fiir tYis-'-Spray-- dry 

-. ''adsotbcf;'"^6.3. i'209 . . . 

•• %(o)'(4'j:(-ii)r:J- ; • 

1.70 Gal/ 1 

-: : ci-2 '. • 

>' 1.70 Gal / 

l b C12 

1.61 -Gal / 

l b C12 

"TEe'.'brand:•-.(, i;'e.'>. 

manufacturer")''and type o f ' 

.'- - sdrben't' used.'/during the-

.- cpmpjteh'ensiye/ performance 

"' .'test (63 .12.09 

: '(o)'(4) '(iii i ! (AV) 

Mississippi 

Lime 

Company 

Hydrated ' 

Lime Code 

MR2O0 

Mississippi• 

Lime' 

Company 

Hydrated 

Lime Code 

MR200 

Mississippi 

Lime 

Company. 

Hydrated 

L ime Code 

MR200 

Maximum combustion chamber 

•pressure-'' (63'. 1209 (p) ) 

-0.01 inchH20 -0.01 inch 

H20 

-0.01 inch 

H20 

5 seconds 

for unit's 

2' and 3 

and 

iostantan 

eous Cor 

unit 4 

.3'.' - ..'.:C'0'rttpli.'a'nce . vith standards: 140/'C. F:.R."••§.'63 .120"6.('b] (.1] j 

/.',K/v' .'T.K'4: emission standards and .operating requirements set 

; .-:. '.'....-.--.fo rtii derived' f rom-.Subpar t EEE apply -at al l times 

-'/ ;;- .' -' except;:- ' ' .'• • 

(a) During periods of startup, shutdown, and 

malfunction; and 

(b) When hazardous waste i s not in the combustion 

chamber (i.e. , the hazardous waste feed to the 

combustor has been cut of f for a period of time not 

V E S 000771 
USEPA Approved Extrapolation Method;-

Total Total 

'• -, • LVMEmis. SVMEmis. Hg Emis. 

Stackflow Oxygen LVM Feed . Rate (ER) SVM Feed : Rate(ER) Hg Feed Rate(ER) 

Test Data Run (dscfm) (%dry) (Ib/hr) (Ib/hr) (Ib/hr) (IbJhr) < (Ib/hr) (Ib/hr) 

Unit 2 (8/08) 1 5496 11.72 0:0052 • 0:000791 

2 5572 . . ii:54 0.0044 0.000822 

3 5357 . 11.3 0.0046 0.000799 

Unit 2 (9/08) 1 4698 11.21 47 ; 0.000125 62 0.000398 , 

2 5099 10.91 47 0.0000438 64 . 0.000144 

3 5248 . 11.35 47. 0.000101 63 0.000364 

Unit 3 (8/08) \ 5665, 11.99 51 . 0.000388 •• 65 0.000799 0.0045 0.000748 

2 .5719, . 10.96 51, ... 0.000308 66 0.00103 0.0056 0.000938 

3 5890 11.98 52-. .0.00022 65 0.000655 • 0.0051 0:000818 

Unit 4 (8/08) 1 17280 12.27 55 0.000214 65 0.0009 0:O306.. : 0.00153 .. 

2 17255 12.13 55 0.000425 65 0.0013 0.0304 0.000996 

3 17189 11.63 55 0.000586 66 0.00116 0.0306 . 0.00108 

V ES 000772 
USEPA Approved Extrapolation Method 

[1] [2] [3] 14] Proposed Proposed 

Unit 2 (LVM) Removal Max. ER at 75% LVM Feedrate Extrapolation Extrapolation 

Em. Std.: 92 ug/dscm Efficiency (RE) Stackflow of Standard OPL Limit (Total) Limit (Pump.) 

(9/08) (%) (dscfm.7%02) (Ib/hr) (Ib/hr) (Ib/hr) (lb/hr) 

1 99.99973 6718 0.001734 652 

2 99.99991 7075 0.001826 1959 

3 99.99979 7614 0.001965 914 

Avg 99.99981 7136 0.001841 1175 399 368 

[1] 12] [3] [4] Proposed 

Unit 2 (SVM) Removal Max. ER at 75% SVM Feedrate Extrapolation 

Em. Std.: 230 ug/dscm Efficiency (RE) Stackflow of Standard OPL Limit 

(9/08) (%) (dscfm, 7%02) (Ib/hr) (lb/hr) (lb/hr) 

1 99.99936 6718 0.004334 675 

2 99.99978 7075 0.004564 2029 

3 99.99942 7614 0.004912 850 

Avg 99.99952 7136 0.004604 1185 459 

[1] [2] [3] [4] Proposed 

Unit2(Hg) Removal Max. ER at 75% Hg Feedrate Extrapolation 

Em. Std.: 130 ug/dscm Efficiency (RE) Stackflow of Standard OPL Limit 

(8/08) (%) (dscfm.7%02) (Ib/hr) (Ib/hr) (Ib/hr) 

1 84.79 8291 0.003024 0.0199 

2 81.32 8246 0.003007 0.0161 

3 82.63 7732 0.002819 0.0162 

Avg 82.91 8090 0.002950 0.0174 

I 

0.017 

Extrapolated metals feedrates calculated using USEPA approved method. 
USEPA Approved Extrapolation Method 

[1] [2] PI [4] Proposed Proposed 

Unit 3 (LVM) Removal Max. ER at 75% LVM Feedrate Extrapolation Extrapolation 

Em. Std.: 92 ug/dscm Efficiency (RE) Stackflow of Standard OPL Limit Limit (Pump.) 

(%) (dscfm,7%02) (Ib/hr) (Ib/hr) (Ib/hr) (Ib/hr) 

1 99.99924 8802 0.002272 299 

2 99.99940 7975 0.002058 341 

3 99.99958 9142 0.002359 558 

Avg 99.99940 8640 0.002230 399 399 368 

[1] [2] PI [4] Proposed 

Unit 3 (SVM) Removal Max. ERat75% SVM Feedrate Extrapolation 

Em. Std.: 230 ug/dscm Efficiency (RE) Stackflow of Standard OPL Limit 

(%) (dscfm,7%02) (Ib/hr) (Ib/hr) (Ib/hr) 

1 99.99877 8802 0.005679 462 

2 99.99844 7975 0.005145 330 

3 99.99899 9142 0.005898 585 

Avg 99.99873 8640 0.005574 459 459 

IU [2] [3] [4] Proposed 

Unit3(Hg) Removal Max. ER at 75% Hg Feedrate Extrapolation 

Em. Std.: 130 ug/dscm Efficiency (RE) Stackflow of Standard OPL Limit 

(%) (dscfm,7%02) (Ib/hr) (Ib/hr) (Ib/hr) 

1 83.38 8802 0.003210 0.0193 

2 83.25 7975 0.002908 0.0174 

3 83.96 9142 0.003334 0.0208 

Avg 83.53 8640 0.003151 0.0192 0.017 

I 

Extrapolated metals feedrates calculated using USEPA approved method. 
USEPA Approved Extrapolation Method 

[1] [2] [3] [4] Proposed Proposed 

Unit 4 (LVM) Removal Max. ERat75% LVM Feedrate Extrapolation Extrapolation 

Em. Std.: 92 ug/dscm Efficiency (RE) Stackflow of Standard OPL Limit Limit (Pump.) 

(%) (dscfm,7%02) (Ib/hr) (Ib/hr) (Ib/hr) (Ib/hr) 

1 99.99961 27711 0.007151 1838 

2 99.99923 27234 0.007028 910 

3 99.99893 25683 0.006628 622 

Avg 99.99926 26876 0.006936 1123 500 427 

[1] [2] [3] [4] Proposed 

Unit 4 (SVM) Removal Max. ER at 75% SVM Feedrate Extrapolation 

Em. Std.: 230 ug/dscm Efficiency (RE) Stackflow of Standard OPL Limit 

(%) (dscfm.7%02) (Ib/hr) (Ib/hr) (Ib/hr) 

1 99.99862 27711 0.017878 1291 

2 99.99800 27234 0.017571 879 

3 99.99824 25683 0.016570 943 

Avg 99.99829 26876 0.017340 1038 500 

[1] [2] [3] [4] Proposed 

Unit4(Hg) Removal Max. ER at 75% Hg Feedrate Extrapolation 

Em. Std.: 130 ug/dscm Efficiency (RE) Stackflow of Standard OPL Limit 

(%) (dscfm,7%02) (Ib/hr) (Ib/hr) (Ib/hr) 

1 95.00 27711 0.010105 0.202 

2 96.72 27234 0.009931 0.303 

3 96.47 25683 0.009365 0.265 

Avg 96.06 26876 0.009801 0.257 0.257 

I 

Extrapolated metals feedrates calculated using USEPA approved method. 
1 Year Metals Data ' . ••• " -"' Iv-. • 

• | • 

_. /I.."--'.- . 

06/01.07 thru 05/31/08 .06/01/07 thru 05/31(08 • -- . .. -. . 06/01/07 thru 05/31/08 

.., ' •• 

LVM Unit 2 Unit 3 Unit* ., SVM Unit 2 ..'. unit 3 Unlt4.; Hg v::. Unit 2 Unit 3 Unit 4 

(lbs/hr) (lbs/hr) . (lbs/hr): (lbs/hr) : (lbs/hr) (lbs/hr) (lbs/hr) (lbs/hr) . (lbs/hr) : 

'... . - ••• '' 

12 Hr Max Value 77.74 .38.88 77.29 12 Hr Max Value '.90.73 -.81.59 '. -58.3B 12 Hr Max Value , . '. ;0.005396 0.00416 0.05373 

'. \ e '. . .' 12 Hr Avg Value •1.88 ":',."" 1.18 .3.03 12 Hr Avg Value .

i:

 1.75 .' ; .1.98 .. 3.81 12 Hr Avg Value - 0.0002972 .0.0002433 .0.007232 

..''.•••,•'• 

Std Dev . 6.00 3.69 6.5S Std Dev . 5.71 6.80 . 6.09 StdDev 0.0007109 0.0005683 0.008943 

Avg+ 1 StdDev 7.88 '4.87 8.58 Avg + IStdDev . ' ", . 7.46 8.78 9.90 Avg +1 StdDev 0.001008 0.000812 0.016175 

Avg + 2StdDev '13.88 ' 8.56 '14.13 Avg + 2 StdDev ' : 13.17 15.58 15.99 Avg+ 2 StdDev 0.001719 0.0013799 0.025118 

2008 Test Feed Rates 47 '61 55 200B Test Feed Rates ' 63 65 -. -65 2008 Test Feed Rates 0.0047 0.0051 0.031 

V ES 000776 
Utilization of Method 23 for Dioxin/Furan Emissions 

The HWC MACT standard at 40 CFR §63.l208(b)(l)(i)(A) specifies the use of EPA SW-846 

Method 0023A to determine compliance with the emission standard for dioxins arid furans. 

Alternatively, the standard provides in 40 CFR §63.1208(b)(i)(i)(B) that Method 23 (40 CFR, 

Part 60, Appendix A) can be used, after approval by the Administrator, Lubrizol requests 

approval to use Method 23 to detennine compliance with the emission standard for dioxins and. 

furans when it conducts the WHRI CPT. Further explanation and justification for this alternative 

monitoring request is found in Section 6.1. 

3.3 Mercury Feedrate Limit Determination 

Lubrizol requested a waiver from conducting the performance test to document compliance with 

the mercury emission Standard per 40 CFR-63.1207(m) and 63.7(h). This request was included 

in the 2002 CPT Plan and approved by US EPA on August 29, 2003. Lubrizol will utilize the 

maximum theoretical emission, concentration (MTEC) approach to document on-going 

compliance with the mercury emission standard per 40 CFR 63.1207(m)(4)... This approach is 

based on all the mercury fed to the combustor being emitted through the stack. (i.e., do not take 

any credit for mercury removal in the ARCS). The mercury concentration: in all feedstreams will 

be determined per the feedstream analysis plan (FAP) required by 40 CFR 63.1209(c); The 

mercury feedrate of each feedstream will be determined per the discussion in Section 3.1, Based 

on historical analytical and waste feedrate data, the maximum mercury feedrate limit will be 

0.0014 lb/hr. This OPL will be monitored on a I2-HRA basis and will be interlocked to the 

AWFCO system. Per 40 CFR 63.l207(m)(5) the full detection limit will be assumed for 

feedstreams where mercury is not detected. 

In addition, a minimum flue gas flow rate (acfm) OPL has been determined. Based on flue gas 

parameters collected in conjunction with the 2003 CPT, the mercury emission limit of 13.0 

ug/dscm at 7 percent oxygen and the maximum mercury feedrate of 0.0014 Ib/hr; the minimum 

flue gas flow rate of 7738 acfm was calculated. The flue gas flow rate is continuously monitored 

and the minimum OPL will be interlocked to the AWFCO system. The minimum flue gas flow 

rate OPL will- be monitored on a 12-HRA basis. These two OPLs in conjunction assure 

compliance with the mercury emission limit per 40 CFR 63.1207(m)(4). 

3.4 Metals Feedrate Extrapolation Procedures 

In order to establish an approach for controlling metal hazardous air pollutants, US EPA grouped 

the metals in categories by their relative volatility. The categories include low volatility metals 

(LVM), semi-volatile metals (SVM) and volatile metals. The LVM category includes arsenic, 

18 

V E S 000777 
beryllium, and chromium. The SVM category consists of cadmium and lead. Mercury is the 

only volatile metal regulated by the MACT standard. 

For the purpose of the CPT, one metal from each ofthe LVM and SVM categories will be spiked 

to fhe incinerator. The mercury feedrate limit is established and monitored based on the 

maximum theoretical emission concentration, as discussed in Section 3.3. 

The. emission limits for the LVM and SVM categories for existing incinerators are: 

• LVM (total of As, Be, and Cr) 92 ug/dscm, corrected to 7% 02 

• SVM (totalof Cd and Pb) 230 ug/dscm, corrected to 7% 02 

Lubrizol intends to spike metals during the CPT to assure that metal feedrates demonstrated 

during the CPT will allow for adequate flexibility based on historical metal feedrate data. 

However, due to variations in waste feedstreams, analytical uncertainties, and other factors, 

Lubrizol will continue to utilize fhe metals feedrate extrapolation procedure per 40 CFR 

63.1209(n)(2)(ii) based on the prior approval of this technique by US EPA Region 5. 

The Technical Implementation Document (TID) for US EPA's Boiler and Industrial Fumace (BIF) 

Regulations (US EPA, OSWER, EPA530-R-92-Q11, PB92-154 947, March 1992) provides a 

detailed discussion of the theoretical rationale. for upward extrapolation of allowable metals 

feedrates based on the relationship of metals feedrates and emissions rates demonstrated during 

testing of a unit. The relationship of metals feedrates and resulting emission rates is complex and 

dependent on a number of factors including operating conditions, the air pollution control system, 

and the metal feedrate itself. 

This guidance has proposed that three zones of relationship between feedrate and emission rate 

exist. These zones are: I) vaporization, which characterizes conditions below saturation of the 

metal in the combustion gas, 2) entrainment, which describes the conditions during which metals 

are primarily entrained on the ash particles in the system, and 3) complex, which includes the 

effects from both solid and liquid feed streams beyond the point at which metals concentrations ih 

the liquid stream alone are in excess of the gas saturation point The gu idance proposes that within 

each of these zones, the relationship of feedrate and emission rate is linear. Therefore, 

extrapolation of metals feedrates within a zone is performed simply, by assuming a linear 

relationship. Additionally, contributions of metals from solid and liquid streams are additive. 

19 

VES 000778 
Lubrizol utilized the removal efficiency (RE) demonstrated during the 2002 CPT for LVM and 

SVM and 75% ofthe HWC MACT emission standard for the respective metal categories to 

determine .the permitted LVM and SVM feedrate. The steps for utilizing extrapolation to 

calculate the LVM and SVM feedrate limits are detailed below. 

1. Detennine the demonstrated LVM and SVM RE based on data demonstrated during the 

CPT-

(LVM feedrate, lb/hr - LVM emission rate (ER), lb/hr) x 100 

LrVM RJb, /o-— • • — —: ^ 

LVM feedrate lb/hr 

cir* n,c o, ( S Y M feedrate, lb/hr- SVM emission rate (ER), lb/hr) x 100 

S VM feedrate, Ib/hr 

f -. . . . 

2. Utilize the flue gas flowrate measured by the stack test crew (in dscfrn) and correct to 7% 

oxygen using the following calculation: 

dscfm (measured) * (14 - (21 - dry %Oi)) = dscfm, 7%02 

3. Calculate the maximum mass emission rate (ER) of LVM and SVM at 75 percent ofthe 

HWC MACT emission standard based oh the gas flowrate demonstrated during the CPT: 

Max LVM ER, lb/hr = 69 jig/dscm, 7% 02 * dscfm,. 7% 02 * 0.0283 dscm/dscf 

* 60 min/hr * 1 lb/453.6g * 1 g/106 fxg 

Max. SVMER; lb/hr = 173 /Jg/dscm, 7% 02 * dscfm, 7% 02 * 0.0283 dscm/dscf 

* 60 min/hr * 1 lb/453.6 g * 1 g/106 

4. Calculate the permitted LVM "and SVM feedrate OPL based oh the mass emission rates 

determined in. step 3 and the LVM and SVM RE's demonstrated during the CPT. 

r TM? A ** nor iu,u Ma x LV M ER-

lb/h r 

LVM feedrate OPL, Ib/hr = 

SVM feedrate OPL, lb/hr = 

((100-LVMRE,%) -100) 

Max SVMER, lb/hr 

((100-SVM RE, %) -100) 

20 
The LVM calculation applies to pumpable LVM and total LVM, based on the respective 

feedrates of pumpable and total LVM demonstrated during, the CPT. The US EPA approved this 

extrapolation procedure for the LVM and SVM feedrate OPL in a letter dated August 29,2003. 

3.5 Waiver of Monitoring m Certain Feedstreams 

Lubrizol does not intend to perform feedstream monitoring for natural gas and process air during 

the up-coming CPT, as requested in the 2002 CPT plan and approved by US EPA Region 5. 

This section summarizes the justification of the initial waiver request 

in 40 CFR 63.1207(f)(l)(xi) . and 63.1209(c)(5) the HWC MACT Standard requires 

documentation of the expected levels of the regulated constituents in natural gas, process air and 

feeastfeams from vapor recovery systems: The WHRI utilizes fuel oil as the auxiliary fuel 

Natural gas is only utilized during start-up as a pilot (see Section 4.8). Therefore, the natural gas 

discussion_ is not applicable. The regulated constituents in fuel oil are determined per the 

Feedstream Analysis Plan and the feedrate Is continuously monitored. The contribution of this 

feedstream is included in calculation of the total regulated constituent feedrate to the WHRI by 

the PLC. 

There are no feedstreams from vapor recovery systems associated with fhe WHRI. The 

combustion air (process air) for the unit is drawn from ambient air near the unit. Since the 

WHRI system is operated , at less than ambient pressure, the fugitive emissions of regulated 

constituents from the unit will be negligible. Additionally, fugitive emissions from other 

processing equipment (tanks, pumps, etc.) are controlled per RCRA Subpart BB. Therefore, the 

feedrate of regulated constituents in the process air introduced to the WHRI system will be 

considered negligible as compared to the regulated constituents contained in the waste and fuel 

feedstreams. 

3.6 Operation of Waste Firing System 

In 40 CFR 63.1209(j)(4) the HWC MACT Standard requires that an operator must specify 

operating parameters and limits to ensure that good operation of each hazardous Waste firing 

system is maintained to ensure compliance with the DRE standards. The required OPLs per 40 

CFR63.l209(j)(l)-(3)are: 

« Minimum combustion chamber temperatures 

• Maximum flue gas flowrate 

• Maximum waste feedrate 

21 
Section 2.2 Material Processing Areas 

Add provisions for the handling of Level 2 containers in these areas. 

Veolia manages containers in the Material Processing Areas that/exceed 

the container size limits for Level 1 controls. The processing of Level 2 

containers at Veolia is identical to that of Level 1 containers: Waste 

treatment is not performed in the Material Processing areas. Level 2 

containers are controlled according to the requirements at 40 GFR Part 

63, Subpart PP "National Emission Standards for Containers;" as 

appropriate for Level 2 containers. Method 21 monitoring of Level 2 

containers is performed as required to demonstrate no detectable 

emissions. 

Please add the Emissions Limitations and Standards at Section 2.2(A), 

Work Practice and Operational Requirements at Section 2.2(C), 

Monitoring and Testing Requirements at Section 2.2(D), and 

Recordkeeping and Reporting requirements at Section 2.2(E.) as 

appropriate for management of Level 2 containers in these Material 

Processing Areas. 
Section 2.4 Storage Tanks 

Modify Monitoring and Testing section to reflect only those requirements 

- applicable to tanks, which are not maintained at less than atmospheric 

pressure. 

- None of Veolia's waste storage tanks are maintained below atmbspheric 

pressure. Title V Permit Section 2.4(D)(1) contains an appropriate 

requirement for annual testing of the tank cover and all openings pursuant 

to Benzene Waste Operations NESHAP 40 CFR 61.343(a)(1.) Following 

the appropriate requirement is an requirement derived from 40 CFR 

61.343(a)(1 )(C)(3), which reflects requirements for tanks maintained 

below atmospheric pressure. The last sentence of 2.4(D)(1) simply needs 

. to be deleted. 
Section 2.9 Insignificant Activities 

Drum Sampling 

Veolia proposes that emissions from drum sampling activities be treated 

as insignificant consistent with 40 CFR 71.5(c)(11) and 35 IAC 201.210. 

This activity does not emit more than 2 tons / year of regulated air . 

pollutants^ excluding HAP, nor does it emit any HAP in excess of 1000 lb 

per year. Likewise, it does not emit more than 1.0 lb / hour of any 

regulated pollutant excluding HAP, nor does it emit more than 0.1 lb / hour 

of any HAP in the absence of air pollution control equipment. 

The following text is copied from the Title V Permit Application (Pages 37 

^ 39) discussion on the drum crushing operation: 

According to previous TRI reports submitted by the facility, the 

major regulated constituents processed by the facility that Could 

emit VOM are toluene, methanol, xylene and methyl ethyl ketone. 

Methanol has a much higher vapor pressure than the other listed 

materials. For a very conservative estimate of VOM emissions 

from drum crushing activities, it was assumed that methanol 

residue was the VOM contain in, and released from the crushed 

drums. It was also assumed that then entire volume of the drum 

was filled with methanol vapor 

Drums crushed per year = 17,000 

Vapor pressure of methanol at 20°C = 97.48 mmHg = 1.88 psi 

Molecular weight of methanol = 32.04 Ib/lb-mole 

Atmospheric pressdre = 14.7 psi 

Density of air at 20°C = 0.0748 lb/ft3 

Molecular weight of air = 28,97 Ib/ib-rhoie 

Dimensions of a 55-galion drum = 24 inch diameter x 33 inch high = 

2 ft diameter x 2.75 ft high 

Volume of a 55-gallon drum = fl * (radius)2 * height 

= 3.14*(1) 2*2.75 = 8.635ft 3 
Raoult's Law: pA = xA*P where pA = partial pressure of 

methanol in air 

xA = mole fraction of methanol in 

air 

P = pressure 

1.88 psi = xA*14.7psi 

xA = 0.128 = mole fraction of methanol in air 

lb. of air in drum = 8.635 ft3 * 0.0748 lb/ft3 = 0.646 lb air 

moles of air = 0.646 lb air / 28.97 Ib/lb-mol air = 0.0223 Ib-mol air 

mole fraction of methanol * Ib-mol air - moles of methanol 

0.128 * 0.0223 Ib-mol air = 0.00285 Ib-mol methanol 

0.00285 Ib-mol methanol * 32.04 Ib/lb-mole methanol = 0.0914 lb 

methanol in drum 

This provides the basis for discussion on drum sampling emissions; 

0.0914 fb methanol vapor is contained in an empty 55 gallon drum. 

If an empty drum is filled with 0.0914 lb methanol vapors, a conservative 

estimate would be that 5% of a drum filled with waste would be filled with 

vapor. If the entire vaporous content of the drum were evacuated during 

the short sampling time, 0.00457 lb of methanol vapor would be emitted. 

Note that this is a conservative figure as many drums of nori-haz and nonregulated wastes are sampled which would not contain VOM, Many 

drums sampled are less than 55 gallons in size. Approximately half of the 

drums received contain solids, which emit little or rio vapors. 

If 0.00457 lb of methanol is emitted with every drum sampled, assume that 

half of that is attributed to HAP material; 0.002285 ib HAP per drum. 

Veolia currently samples approximately 30 drums per hour, roughly 3 

hours per day, 6 days per week; 936 hours / year. 

30 drums / hour * 0.00457 Ib methanol / drum = 0.1371 Ib VO M / 

hour 

0.1371 Ib VOM / hour * 936 hours / year = 128 Ib VOM / year 

30 drums / hour * 0.002285 Ib HAP / drum = 0.0686 Ib HAP / hour 

V E S 000784 
0.0686 Ib HAP / hour * 936 hours / year = 64 lb HAP / year 

The time spent sampling is directly related to the number of samples; this 

is to say that when the work load is increased, the hours spent sampling 

increases'accordingly. The number of drums sampled per hourwill not 

fluctuate; on the average, dramatically. Even if Veolia saw a 43% 

increase in the sampling rate (43 drums / hour) we would still be below the 

limits required to be an insignificant activity. 

43 drums / hour * 0.00457 Ib methanol / drum = 0.197 Ib VOM / 

hour 

0.197 Ib VO M / hour * 936 hours / year = 184 lb VOM / year 

43 drums / hour * 0.002285 Ib HAP / drum = 0.0982 ib HAP / hour 

0.0982 Ib HAP / hour * 936 hours / year = 92 Ib HAP / year 

40 GF R 71.5(c)(11) limits insignificant activities to 2 TPY regulated air 

pollutant. Even if sampling the unlikely 43 drums/hour, there are not 

enough hours in a year for Veolia to exceed the emission limits given at 40 

GFR71.5(c)(11). 

4000 lb VOM / year * 1 hr / 0.197 Ib VOM = 20,305 hours / year 

1000 lb HAP / year * 1 hr / 0.0982 Ib HAP = 10,183 hours / year 

Maximum hours / year: 8,736 

V ES 000785 
Section 2.6 Gasoline Storage Tank 

550 gallon Gasoline Storage Tank 

Veolia proposes that emissions from the 550 gallon gasoline storage tank 

be treated as insignificant consistent with 40 CF R 71.5(c)(11) and 35 IAC • 

201.210. This tank does not emit more than 2 tons / year of regulated air 

"pollutants, excluding HAP, nor does it emit any HAP in excess of 1000 lb 

per year. Likewise, it does not emit more than 1.0 Ib / hour of any 

regulated pollutant excluding HAP, nor does it emit more than 0.1 Ib / hour 

of any HAP in the absence of air pollution control equipment. 

Veolia operates one 550 gallon gasoline storage tank. Historical records 

indicate that this tank has never had an annual throughput that 

exceeded 6,000 gallons; four of the past 5 years have shown annual 

throughputs of less than 5,000 gallons. Each year, emissions from this 

tank are calculated using the TANKS software available at the USEPA 

website. The version most recently used was TANKS 4.0.9d. The 

maximum annual gasoline, emissions calculated by TANKS for this specific 

tank over the past 5 years is 81 lb. This includes both working and 

breathing losses. 

In order tb approach the 2 TPY regulated air pollutant'limit, Veoiia would 

need to handle 4 million gallons of gasoline in this tank according tp 

TANKS calculations. At this throughput, 3,740 Ib (1.87 T) of gasoline 

emissions would be released annually, 

fhe constituents of gasoline vary significantly, but resources agree that 

toluene is the HAP that will be found at the highest concentration in 

gasoline. The most conservative estimates indicate that toluene will be 

present In gasoline at concentrations of less than 25%. Again, using the 

annual throughput of 4 million gallons, if one quarter of the total gasoline 

emissions are attributed to toluene, this would result in emissions of 935 Ib 

toluene annually, which does not exceed the 1,000 Ib HAP limit. 

With respect tb the 1.0 lb / hour Hmit on any non-HAP pollutant, assume 

that Veolia unexplainably triples the use of gasoline on-site and annual 

throughputs become 18,000 gallons. This would result in annual gasoline 

emissions of 147 lb according to TANKS. If the entire year's emissions 

were to occur in a single week(168 hours), this would still not exceed the 

1.0 Ib / hour limit. 

V E S 000786 
Regarding the: 0.1 Ib/hr HAP limit, once again, use the exaggerated 

18,000 gallon throughput example with toluene concentration being 25% 

of the total gasoline emissions. Toluene emissions would be 37 Ib for the 

year. If the emissions were to occur in two weeks (336 hours) the 

emissions would barely exceed 0.1 lb Toluene per hour. 

These extremely exaggerated scenarios should illustrate the fact that it is 

impossible for Veolia to approach any of the limits of an insignificant 

source. Consideration of the small tank size and minimal ACTUAL 

throughputs of this tank should clearly qualify it as an insignificant source. 
Unit #2 Revised 

Run#1 

Date: 09/08/08 

Test Time: 14:36 to 16:46 

Run Length (minutes) - 130 

PPM PPM PPM PPM PPM 

Waste Type Btu/lb %CWorine %Ash Lead Cadmium Arsenic Beryllium Chromium 

PCC High Btu 5260 1,3 1.63 0.58 0.1 160 0.00025 1500 

PCC Low Btu 2850 0.002 0.66 0.03 0.003 0.06 0.00025 0,006 

(Chromium Spike) 0 0 26.6 0 0 0 0 177000 

PCC Sp Fdr 800 0.01 12.5 0.005 0.001 0.01 0.00025 0.33 

Containerized Solids 180 0.08 63.4 313.92 196.2 92.21 0.25 1177.2 

(Lead Spike) 0 0 63.9 621000 0 | 0 0 0 

(Chlorine Spike) 25 89.8 0.5 0 0 0 0 0 

... . 

Totals 

. L i 

Chromic Acid : Start Wgt End Wgt Total Wgt Average 

(Batch CH08H00216) Lb . Lb Lb Lb/Hr 

1124.8 568 556.8 257 

Solids: Number of Total Charges Average Pb Spike CI2 Spike Waste 

Charges Weight Per Hour Lb/Hr Lb/Hr Lb/Hr [ Lb/Hr 

83 1773 38.3| 818 100 245 474 

2.6 Ib/chg 6.4 Ib/chg 

62.1% Pb 89.8% CI2 
Unit #2 Revised : 

Run #1 

Date: 09/08/08 

Test Time: 14:36 to 16:46 

Run Length (minutes) — 130 

Average Thermal Chlorine Ash i Lead Cadmium Arsenic Beryllium Chromium 

Feedrate Loading Loading Loading Loading Loading Loading Loading Loading 

Waste Type (Ib/hr) (MMBtu/hr) (Ib/hr) (Ib/hr) (Ib/hr) (Ib/hr) (Ib/hr) (lb/hr) (Ib/hr) 

PCC High Btu 549 2.89 7.1 8.9 0.00 0.000 0.088 0.000 0,82 

PCC Low Btu 1018 2.90 0.0 6.7 0.00 0.000 0.000 0.000 0.00 

(Chromium Spike) 257 0.00 0.0 68.4 0.00 0.000 0.000 0.000 45,49 

PCC Sp Fdr 244 0.20 0.0 30.5 0.00 0.000 0.000 0.000 0.00 

Containerized Solids 474 0.09 0.4 300.2 0.15 > 0.093 0.044 0.000 0.56 

(Lead Spike) 100 0.00 0.0 63.6 61.85 0.000 0.000 0.000 0.00 

(Chlorine Spike) 245 0.01 220.2 1.2 0.00 0:000 0.000 0.000 0.00 

! 

Totals 2886 6.1 228 480| 62.0 0.09 0.13 0.00 46.9 
Unit #2 Revised I 

Run #2 • I i 

Date: 09/09/08 l 

Test Time: 12:20 to 14:30 

Run Length (minutes) - 130 

PPM PPM PPM PPM PPM 

Waste Type Btu/lb %Chlorine %Ash Lead Cadmium Arsenic Beryllium Chromium 

7 

PCC High Btu I 4930 1.5 1.67 0.72 0.11 160 0.00025 1400 

PCC Low Btu 1760 0.002 0.03 0.03 0.004 0.04 0.00025 0.0025 

(Chromium Spike) 0 0 26.6 0 0 0 0 177000 

PCC Sp Fdr 770 0.019 9.34 0.005 0.001 0.03 0.00025 0.12 

Containerized Solids 320 0.16 60.8 234.96 156.64 88.11 0.25 949.63 

(Lead Spike) 0 0 63.9 621000 0 0 0 0 

(Chlorine Spike) 25 89.8 0.5 0 0 0 0 0 

1 1 

Totals 

Chromic Acid: Start Wgt End Wgt Total Wgt! Average 

(Batch CH08H00216) Lb Lb Lb Lb/Hr 

1076.6 522.9 553.7 256 

Solids: Number of j Total Charges Average Pb Spike CI2 Spike Waste 

Charges ] Weight Per Hour Lb/Hr Lb/Hr Lb/Hr Lb/Hr 

85 2015 39.2 930 1021 251 577 

i ' 

2.6 Ib/chg 6.4 Ib/chg 

62,1% Pb 89-.8%CI2 
Unit #2 Revised 

Run #2 

Date: 09/09/08 

Test Time: 12:20 to 14:30 

Run Length (minutes) - 130 

Average Thermal Chlorine Ash Lead Cadmium Arsenic Beryllium Chromium 

Feedrate Loading Loading Loading Loading Loading Loading Loading Loading 

Waste Type (Ib/hr) (MMBtu/hr) (lb/hr) (Ib/hr) (Ib/hr) (Ib/hr) (Ib/hr) (Ib/hr) (Ib/hr) 

PCC High Btu • 549 2.71 8.2 9.2 0.00 0.000 0.088 0,000 0.77 

PCC Low Btu 1103 1.94 0;0 0.3 0.00 0.000 0.000 0.000 0.00 

(Chromium Spike) 256 0.00 0.0 68.0 . 0.00 0.000 0.000 • 0.000 45.23 

PCC Sp Fdr 244 0.19 0.0 22.8 0,00 0.000 0.000 0.000 0.00 

Containerized Solids 577 0.18 0.9! 350.8 0.14 0.090 0.051 0.000 0.55 

(Lead Spike) 102 0.00 O.Of 65.2 63.34 0.000 0.000 0.000 0.00 

(Chlorine Spike) 251 0.01 225.5 1.3 0.00 0.000 0.000 0.000 0.00 

Totals 3082 5.0 235 517 63.5 0.09 0.14| 0.00 46.5 
Unit #2 Revised 

Run #3 

Date: 09/10/08 

Test Time: 09:44 to 11:53 

Run Length (minutes) — 129 

PPM PPM PPM PPM PPM 

Waste Type Btu/lb %Chlorine %Ash Lead Cadmium Arsenic Beryllium Chromium 

PCC High Btu 4780 1.6 1.01 2.1 0.16 240 0.00025 630 

PCC Low Btu 1480 0.0025 0.01 0.03 0.005 0.04 0.00025 0.0025 

(Chromium Spike) 0 0 26.6 0 0 0 0 177000 

PCC Sp Fdr 240 0.01 6.41 0.005 0.002 0.005 0.00025 0.37 

Containerized Solids 250 0.1 ' 61.5 234.24 165.92 87.84 0.25 976 

(Lead Spike) 0 0 63.9 621000 0 0 0 0 

(Chlorine Spike) 25 89.8 0.5 0 0 0 0 0 

Totals 

Chromic Acid : Start Wgt End Wgt Total Wgt Average 

(Batch CH08H00216) Lb Lb Lb Lb/Hr 

1027.2 465.6 561.6 261 

i 

Solids: Number of ' Total Charges Average Pb Spike CI2 Spike Waste 

Charges Weight Per Hour Lb/Hr Lb/Hr Lb/Hr Lb/Hr 

84 2071 39.1 963 102 250 612 

2.6 Ib/chg 6.4 Ib/chg 

62.1% Pb 89.8% CI2 
Unit #2 Revised I 

Run #3 i 

Date: 09/10/08 

Test Time: 09:44 to 11:53 

Run Length (minutes) - 129 

Average Thermal Chlorine Ash Lead Cadmium Arsenic Beryllium Chromium 

Feedrate Loading Loading Loading Loading Loading Loading Loading Loading 

Waste Ty pe (Ib/hr) (MMBtu/hr) (Ib/hr) (Ib/hr) (Ib/hr) (Ib/hr) (Ib/hr) (Ib/hr) (Ib/hr) 

PCC High Btu 549 2.62 8.8 5.5 0.00 0.000 0.132 0.000 0.35 

PCC Low Btu 1055 1.56 0.0 0.1 0.00 0.000 0.000 0.000 0.00 

(Chromium Spike) I 261 0.00 0.0 69.5 0.00 0.000 0.000 0.000 46.23 

i 

PCC Sp Fdr 234 0.06 0.0 15.0 0.00 0.000 0.000 0.000 0.00 

Containerized Solids 612 0.15 0.6 376.2 0.14 0.101 0.054 0.000 0.60 

(Lead Spike) 102 0.00 0.0 64,9 63.08 0.000 0.000 0.000 0.00 

(Chlorine Spike) 250 0.01 224,5 1.3 0.00 0.000 0.000 0.000 0.00 

Totals 3062 4.4 234 532 63.2 0.10 0.19 0,00 47.2 
Unit #2 Revised 

Run#1 

Date: 08/11/08 

Test Time: 14:40 to 16:50 j 

Run Length (minutes) — 130 / 

PPM PPM PPM PPM PPM PPM 

Waste Type Btu/lb |%Chlorine %Ash Mercury Lead Cadmium Arsenic Beryllium Chromium 

PCC High Btu 1310 3.4 6.83 0.018 1.4 0.1 12 0.015 5.1 

PCC Low Btu 150 0.51 0.11 0.0068 0.05 0.04 0.5 0.0025 0.39 

(Chromium Spike) 0 0 26.6 0 0 .0 0 0 181800 

PCCSp Fdr 350 0.037 4 0.141 0.05 0.01 0.05 0.0025 0.025 

Containerized Solids 1840 0.2 6.03 5.281 947.8 812.4 17.6 0.25 5348.3 

(Lead Spike) 0 0 63.9 0 621000 0 0 0 0 

(Chlorine Spike) 25 89.8 0.5 0 0 0 0 0 0 

(Mercury Spike) 0 0 0 987 0 0 0 0 0 

Totals 

Chromic Acid : Start Wgt End Wgt Total Wgt Average 

(Batch CH08E00643) Lb Lb Lb Lb/Hr 

1225.6 676 549.6 254 

Solids: Number of Total Charges Average Pb Spike Hg Spike CI2 Spike Waste 

Charges Weight Per Hour Lb/Hr Lb/Hr Lb/Hr Lb/Hr Lb/Hr 

86 1823 39.7 841 103 1,23 230 507 

2.6 Ib/chg 0.031 Ib/chg 5.8 Ib/chg I 

62.1% Pb | 987 ppm Hg 89.8% CI2 j 
Unit #2 Revised | I 

Run #1 I I 

Date: 08/11/08 

Test Time: 14:40 to 16:50 

Run Length (minutes) - 130 

Average Thermal Chlorine Ash Mercury Lead Cadmium Arsenic Beryllium Chromium 

Feedrate Loading Loading Loading Loading Loading Loading Loading Loading Loading 

Waste Type (Ib/hr) (MMBtu/hr) (Ib/hr) (Ib/hr) (Ib/hr) (Ib/hr) (Ib/hr) (Ib/hr) (Ib/hr) (Ib/hr) 

PCC High Btu 500 0.66 17.0 34.2 0.00001 0.00 0.000 I 0.006 0.000 0.00 

PCC Low Btu 1087 0.16 5.5 1.2 0.00001 0.00 0.000 0.001 0.000 0.00 

(Chromium Spike) 254 0.00 0.0 67.5 0.00000 0.00 0.000 0.000 0.000 46.12 

PCC Sp Fdr 225 0.08 0.1 9.0 0.00003 0.00 0.000 0.000 0.000 0.00 

Containerized Solids 507 0.93 1.0 30.6 0.00268 0.48 0.412 0.009 0.000 2.71 

(Lead Spike) 103 0.00 0.0 65.9 0.00000 64.09 0.000 0.000 0,000 0.00 

(Chlorine Spike) 230 0.01 206.7 1.2 0,00000 0,00 0,000 0.000 0.000 0.00 

(Mercury Spike) 1.23 0.00 0.0 0.0 0.00121 0.00 0.000 0.000 0.000 0.00 

Totals 2907 1.8 230 209 0.0039 64.6 0.41 0.021 0.00 48.8 
Unit #2 Revised 

Run #2 

Date: 08/12/08 

Test Time: 11:05 to 13:16 

Run Length (minutes) — 131 

•i PPM PPM PPM PPM PPM PPM 

Waste Type Btu/lb %Chlorine %Ash Mercury Lead Cadmium Arsenic Beryllium Chromium 

PCC High Btu 2890 3.4 7 0.0425 1.3 0.1 11 0.015 4.7 

PCC Low Btu 25 0.5 0.03 0.0016 0.05 . 0.0.1 0.2 0.0025 0.12 

(Chromium Spike) 0 0 26.6 0 0 0 0 0 181800 

PCC Sp Fdr 840 0.005 8.48 0.006 0.05 0.01 0.05 0.0025 0.22 

Containerized Solids 1690 0.33 6.01 4.871 960.4 754.6 9.604 0.25 5350.8 

(Lead Spike) 0 0 63.9 0 621000 0 0 0 0 

(Chlorine Spike) 25 89.8 0.5 0 0 0 0 0 0 

(Mercury Spike) 0 0 0 667 0 0 0 0 , 0 

Totals 

Chromic Acid : Start Wgt End Wgt Total Wgt Average 

(Batch CH08E00643) Lb Lb Lb Lb/Hr 

812.9 252.8 560.1 257 

Solids: Number of Total Charges Average Pb Spike Hg Spike CI2 Spike Waste 

Charges Weight Per Hour Lb/Hr Lb/Hr Lb/Hr Lb/Hr Lb/Hr 

86 1806 39.4 827 102 1.22 228 495 

2.6 Ib/chg 0.031 Ib/chg 5.8 Ib/chg 

62.1% Pb 667 ppm Hg 89.8% CI2 
Unit #2 Revised 

Run #2 

Date: 08/12/08 

Test Time: 11:05 to 13:16 

Run Length (minutes) - 131 

Average Thermal Chlorine Ash Mercury Lead Cadmium Arsenic Beryllium Chromium 

Feedrate Loading Loading Loading Loading Loading Loading Loading Loading Loading 

Waste Type (Ib/hr) (MMBtu/hr) (Ib/hr) (Ib/hr) (Ib/hr) (Ib/hr) (Ib/hr) (Ib/hr) (Ib/hr) (Ib/hr) 

PCC High Btu 499 1.44 17.0 34.9 0.00002 0.00 0.000 0.005 0.000 0.00 

PCC Low Btu 1010 0.03 5.1 0.3 0.00000 0.00 0.000 0.000 0.000 0,00 

(Chromium Spike) 257 0.00 0.0 68.2 0.00000 0.00 0.000 0.000 0.000 46.64 

PCC Sp Fdr 212 0.18 0.0 18.0 0.00000 0.00 ' 0.000 0.000 0.000 0.00 

Containerized Solids 495 0.84 1.6 29.8 0.00241 0.48 0.374 0.005 0.000 2.65 

(Lead Spike) 102 0.00 0.0 65.4 0.00000 63.60 0.000 0.000 0,000 0.00 

(Chlorine Spike) 228 0.01 205.2 1.1 0.00000 0.00 0.000 0.000 0.000 0.00 

(Mercury Spike) 1.22 0.00 0.0 0.0 0.00081 0.00 0.000 0.000 0.000 0.00 

i 

Totals 2805 2.5 229| 218 0.0033 64.1 0.37 0.01] 0.00| 49.3 

VES 000797 
Unit #2 Revised ! 

Run #3 i . ... 

Date: 08/13/08 

Test Time: 10:39 to 12:47 I 

Run Length (minutes) — 128 

PPM PPM PPM PPM PPM PPM 

Waste Type Btu/lb %Chlorine %Ash Mercury Lead Cadmium Arsenic Beryllium Chromium 

PCC High Btu 1640 3.2 6.54 0.04 1.1 0.1 17 0.015 4.1 

PCC Low Btu 2000 0.46 0.09 0.0015 0.1 0.02 0.2 0.005 0.05 

(Chromium Spike) 0 0 26.6 0 0| 0 0 0 . 181800 

PCC Sp Fdr 25 0.005 9.05 0.0092 0.05 0.01 0.05 0.0025 0.18 

Containerized Solids 1480 0.17 6.62 4.86 840 720 9 0.25 5160 

(Lead Spike) 0 0 63.9 0 621000 0 0 0 0 

(Chlorine Spike) 25 89.8 .0.5 0 0 0 0 0 0 

(Mercury Spike) 0 0 0 548 0 0 0 0 0 

Totals 

Chromic Acid: Start Wgt End Wgt Total Wgt Average 

(Batch CH08E00643) Lb Lb Lb Lb/Hr 

725.4 188.2 537.2 252 

I 

Solids: Number of Total Charges Average Pb Spike Hg Spike CI2 Spike Waste 

Charges Weight Per Hour Lb/Hr Lb/Hr Lb/Hr Lb/Hr Lb/Hr 

82 1734 38.4 813 100 1.19 223 489 

2.6 Ib/chg 0.031 Ib/chg 5.8 Ib/chg 

62.1% Pb 548 ppm Hg 89.8% CI2 
Unit #2 Revised 

Run #3 

Date: 08/13/08 f 

Test Time: 10:39 to 12:47 

Run Length (minutes) - 128 

Average Thermal Chlorine Ash Mercury Lead Cadmium Arsenic Beryllium Chromium 

Feedrate Loading Loading Loading Loading Loading Loading Loading Loading Loading 

Waste Type (Ib/hr) (MMBtu/hr) (Ib/hr) (Ib/hr) (Ib/hr) (lb/hr) (Ib/hr) (Ib/hr) (Ib/hr) (Ib/hr) 

PCC High Btu 500 0.82 16.0 32.7 0.00002 0.00 0.000 0.009 0.000 0.00 

PCC Low Btu 1033 2.07 4.8 • 0.9 0.00000 0.00 0.000 0.000 0.000 0.00 

(Chromium Spike) 252 0.00 0.0 67.0 0.00000 0.00 0.000 0.000 0.000 45.78 

PCC Sp Fdr 208 0.01 0.0 18.8 0.00000 0.00 0.000 0.000 0.000 0.00 

Containerized Solids 489 0.72 0.8 32.4 0.00238 0.41 0.352 0.004 0:000 .2.52 

(Lead Spike) 100 0.00 0.0 63.9 0.00000 62.06 0.000 0.000 0.000 0.00 

(Chlorine Spike) 223 0.01 200.2 1.1 0.00000 0.00 0.000 0.000 0.000 0.00 

(Mercury Spike) 1.19 0.00 0.0 0.0 0.00065 0.00 0.000 0.000 0.000 0.00 

I 

Totals 2806 3.6 222 217 0.0031 62.5 0.35 0.011 0.00 48.3 

V E S 000799 
Unit 2 Operating Parameter [Revised] 

Limits Set During August and 

September, 2008 Testing 

August, 2008 — Run 1 Run 2 Run 3 Average — 

Mercury Feed (Lb/hr) 0.0039 0.0033 0.0031 0.0034 

(Ave. of test run ave.'s) 

September, 2008 Run 1 Run 2 Run 3 Average 

Baghouse Inlet Temp. (Deg F) 419 420 420 420 

(Ave. of test run ave.'s) 

Stackflow (ACFM) 15196 15120 15124 15147 

(Ave. of max. HRA's of each test run) 

Pumpable LVM Feed (Lb/hr) 46 46 47 46 

(Ave. of test run ave.'s) 

Total LVM Feed (Lb/hr) 47 47 47 47 

(Ave. of test run ave.'s) 

SVM Feed (Lb/hr) 62 64 63 63 

(Ave. of test run ave.'s) 

Chlorine Feed (Lb/hr) 228 235 234 232 

(Ave. of test run ave.'s) 

V E S 000800 
Recalculated Metal Concentrations in Solid Wastes 

2008 Metals Emission Testing ff.A 

i .. 

Unit 2 

Reported Metals Concentration of Solid Waste Feeds 

Date Run* Arsenic Beryllium Chromium Lead Cadmium Mercury Moisture Solid 

(ppm) (ppm) (ppm) (ppm) (Ppm) (ppm) (%) (%) 

8/11/2008 1 26 0.25 7900 1400 1200 7.8 32.3 67.7 

8/12/2008 2 14 0.25 7800 1400 1100 7.1 31.4 68.6 

8/13/2008 3 15 ' 0.25 8600 1400 1200 8.1 40 60 

As Received Metals Concentration of Solid Waste Feeds 

Date Run# Arsenic Beryllium Chromium Lead Cadmium Mercury 

(ppm) (ppm) (PPm) (ppm) (PPm) (ppm) 

8/11/2008 1 17.602 0.25 

0.25 

0.25 

5348,3 947.8 812.4 5.2806 1/2 detection limit 

8/12/2008 2 9.604 

0.25 

0.25 

0.25 

5350.8 960.4 754.6 4.8706 

8/13/2008 3 9 

0.25 

0.25 

0.25 5160 840 720 4.B6 

. . . 

Reported Metals Concentration of Solid Waste Feeds 

Date Run# Arsenic Beryllium Chromium Lead Cadmium Mercury Moisture Solid 

(ppm) (ppm) (ppm) (ppm) (ppm) (ppm) (%) (%) 

9/8/2008 1 94 0.25 1200 320 200 NA 1.9 98.1 

9/9/2008 2 90 0.25 970 240 160 NA 2.1 97.9 

9/10/2008 3 90 0.25 1000 240 170 NA 2.4 97.6 

_ 

As Received Metals Concentration of Solid Waste Feeds 

Date Run# Arsenic Beryllium Chromium Lead Cadmium Mercury 

(ppm) (ppm) (ppm) (ppm) (ppm) (ppm) 

9/8/2008 1 92.214 0.25 1177.2 313.92 | 196.2 NA 1/2 detection limit 

9/9/2008 2 88.11 0.25 949.63 234.96 156.64 NA I 

9/10/2008 3 87.84 0.25 976 234.24 165.92 NA I 

V E S 000801 
Notification of Compliance (NOC) Report 

Veolia ES Technical Solutions, L.L.C. hereby submits the Notification of 

Compliance (NOC) Report in compliance with 

40 CFR 63.1210(b) and 40 CFR 63.1207Q) 

Applicable Rule: 40 CFR Part 63.1200, Subpart EEE — National Emission Standards for 

Hazardous Air Pollutants for Hazardous Waste Combustors. This NOC 

is being made in accordance with §63.9(h). 

SECTION I 

GENERAL INFORMATION 

A. If you have been issued a Title V permit, do not complete this form. Submit your NOC in 

accordance with your Title V permit. [§63.9(h)(3)] 

B. If you have not been issued a Title V permit, complete the remaining portions of this section 

and also complete Sections ll-IX. [§63.9(h)(2)(i)] 

C. Print or type the following information for each, facility for which you are making notification of 

compliance status: 

Operating Permit Number (OPTIONAL) Facility I.D. Number (OPTIONAL) 

V-IL-1716300103-08-01 ILD098642424 

Responsible Official's Name/Title 

Douq Harris 

Street Address 

#7 Mobile Ave. 

City State ZIP Code 

Sauget 62201-1069 

Facility Name (if different from Responsible Official's Name) 

VeoliaJES Technical Solutions, L.L.C. 

Facility Street Address (If different than Responsible Official's Street Address) 

Facility Local Contact Name Title • \ Phone (OPTIONAL) 

Doug Harris General Manager 618-271-2804 

City State ZlPCode . 

Sauget IL * 62201-1069 

D..: Indicate the relevant standard or other requirement that is the basis for this notification and 

the source's compliance date: (§63.9(b)(2)(iii)) 

Basis for this notification (relevant standard or other requirement) Compliance Date (mm/dd/yy) 

40 CFR 63.1200 0B& June 30, 2004 

1 
SECTION II 

CERTIFICATION (Note: you may edit the text in this section as deemed appropriate) 

Based upon information and belief formed after a reasonable inquiry, I, as a responsible official of 

the above-mentioned facility, certify the information contained in this report is accurate and true to 

the best of my knowledge. The above-mentioned facility has complied with the relevant standard 

or arid other applicable requirements referenced in the relevant standard. [§63.9(h)(2)(i)(G)] 

Name of Responsible Official (Print or Type) Title Date (mm/dd/yy) 

Doug Harris General Manager 10/10/2008 

Signature ot Responsibl ponstble Official l , ^_ 

SECTION III 

Describe the methods you used to determine compliance. [§63.9(h)(2)(i)(A)] 

RCRA Trial Burn Data from EPA approved testing as required bythe RCRA Part B permit and testing 

conducted prior to the compliance date using all approved EPA methods was used to demonstrate 

compliance with all applicable emission standards defined in 40 CFR 63 1203. In addition, Performance 

Testing approved by USEPA, Regioq 5 on August 8, 2008 and conducted in August and September of 2008 

See the attached Operating Parameters Tables and HWC MACT Emission Standards fable for Units 2/3 and 

Unit 4, that define the operating parameters established dutmg testing that ensures compliance with the 

performance standards : . 

SECTION IV 

Describe the results of any performance tests, opacity dr visible emission observations, 

continuous monitoring system (CMS) performance evaluations, and/or other monitoring 

procedures or methods that were conducted. r§63.9(h)(2)(i)(B)] 

See attached test results that were tiled to develop fhe/limits defined in the Operating Parameter Tables 

referenced in Sectibn Jll of this report These results also include monitoring methods and procedures Also 

attached are the Facility's Continuous Emissions Monitoring System Quality Assurance Plan and Continuous 

Monitoring System Quality Gontrdl Program , , . 

SECTION V 

Describe tfie methods you will use to determine continuous compliance, including a description of 

monitoring and reporting requirements and test methods. [§63.9(h)(2)(i)(C)j 

Continuous compliance is based on the operating parameter limits established from compliance testing, 

tiefined in the attached Operating Parameters Table referenced in Section 111 of this report. These 

incinerator operating parameters^aremonitored continuously to verify compliance by a process 

monitoring and control system The details of these systems are defined in detail in Section 2 0, 

Incinerator Process description referenced m Section VIII of this report and attached 

2 

VES 000803 
SECTION VI 

Describe the type and quantity of hazardous air pollutants (HAP) emitted by the source (or 

surrogate pollutants if specified in the relevant standard), reported in units and averaging times 

and in accordance with the test methods specified in the relevant standard. [§63.9(h)(2)(i)(D)] 

See attached test results f rbm'c^ that was conducted to demonstrate compliance with 

the HAP's arid otfrer pollutants defined in; Subpart EEE. ;.„.^ : 

SECTION VII 

If the relevant standard applies tp both major and area sources, present an analysis 

demonstrating whether the affected source is a major source (using the emissions data 

generated fpr this notification. [§63.9(h)(2)(i)(E)] 

This facility is1 a major source due to its applicability to the NESHAP regulations, specifically Subpart EEE 

and Subpart .DD. Regardless of the. facility's emission concentrations, this facility is a major source by 

definition. 

SECTION VIII 

Describe the air pollution control equipment (or method) for each emission point, including each 

control device (or method) for each hazardous air pollutant and the control efficiency (percent) for 

each contrpl device (or method), [§63.9(h)(2)(i)(F)J 

See attached Section 2 0, Incinerator Process Description from 2D08 Performance Test Plans for 

Incinerators 2, 3 and 4 that describes the air pollution control equipment for each emission point Also, 

see attached the compliance testing data defined m Section IV of this report that details the control 

efficiency for each control device , . .. 

SECTION IX 

A. Did you submit an application for construction or reconstruction under §63.5(d) that contained 

preliminary or estimated data? £§63.9(h)(5)] 

•Yes L. . /Not" . , . Not applicable I . (did not submit an application for construction or 

reconstruction). 

B. :"if ybu answered yes, provide actual emission data or other corrected information below. 

END OF FORM. A Responsible Official must sign this form - See Section II. 
HWC MACT Emission Standards 

Parameter Units 

Dioxin/Furan (D/F) ng/dscm TEQ 

Mercury (Hg) * ug/dscm 

Semivolatile Metals (SVM) ug/dscm 

Cadmium, Lead * 

Low Volatile Metals (LVM) ug/dscm 

Arsenic, Beryllium, Chromium * 

Carbon Monoxide (CO) ppmv 

Hydrogen CMoride/CMorme ppmv 

(HC1/C12) 

-i.-articulate mg/dscm 

Standard Method of Compliance 

0.20 Operating Parameter 

Limits 

130 Operating Parameter 

Limits 

240 Operating Parameter 

Limits 

97 Operating Parameter 

Limits 

100 Continuous Emissions 

Monitor 

77 Operating Parameter 

Limits 

34 Operating Parameter 

Limits 
UNITS 2/3 OPERATING PARAMETERS 

Operating Parameter Units Limits Test Date 

Performance 

Standards 

Maximum Total Pumpable Lb/hr 3123 

Waste (Hourly Rolling Total) 

Maximum Total Hazardous Lb/hr 4301 

Waste (Hourly Rolling Total) 

Maximum Stack Gas Flow Acfm 15,147 

Rate (Hourly Rolling Average) 

Mmimum Primary Combustion Deg F 1712 

Chamber Temperature (Hourly 

Rolling Average) 

Minimum,Secondary Combustion DegF 1845 

Chamber Temperature (Hourly 

Rolling Average) 

Maximum Baghouse Inlet Deg F 420 

Temperature (Hourly Rolling 

..Average) 

•-Miax. Pump. Low Volatile Metals Lb/hr 46 

Feedrate (12 Hour Rolling Total) 

Max. Total Low Volatile Metals Lb/hr 47 

Feedrate (12 Hour Rollmg Total) 

Maximum Semi Volatile Metals Lb/hr 63 

Feedrate (12 Hour Rolling Total) 

Maximum Mercury Feedrate Lb/hr 0.0047 

(12 Hour RollingTotal) 

Maximum Chlorine Feedrate Lb/hr 229 

(12 Hour Rolling Total) V 

Maximum Ash Feedrate (12 Lb/hr 673 

Hour Rolling Total) 

Minimum Sorbent Feedrate Lb/lb Cl? 1.76 

(Hourly Rollmg Average) 

Minimum Carrier Fluid Flowrate Gal/lb Cl 2 1.70 

(Hourly Rolling Average) 

May, 2004 

May, 2004 

Sept., 2008 

May, 2004 

Nov., 1996 

Aug., 2008 

Sept., 2008 

Sept.; 2008 

Sept., 2008 

Aug., 2008 

Aug., 2008 

Nov., 1996 

Nov., 1996 

Nov;, 1996 

DRE, D/F 

DRE, D/F 

DRE, D/F, 

Part., SVM, 

LVM 

DRE, D/F 

DRE, D/F 

D/F, SVM, 

LVM 

LVM 

LVM 

SVM 

Hg 

SVM, LVM 

HCI/C12 

Part. 

HC1/C12 

HC1/C12 

VES 000806 
UNIT 4 OPERATING PARAMETERS 

Operating Parameter Units Limits Test Date 

Performance 

Standards 

Maximum Total Pumpable Lb/br 

Waste (Hourly Rolling Total) 

Maximum Total Hazardous Lb/hr 

Waste (Hourly Rolling Total) 

Maximum Stack Gas Flow Acfm 

Rate (Hourly Rolling Average) 

Minimum Primary Combustion Deg F 

Chamber Temperature (Hourly 

Rolling Average) 

Minimum Secondary Combustion Deg F 

Chamber Temperature (Hourly 

Rolling Average) 

Maximum Baghouse Inlet Deg F 

Temperature (Hourly Rolling 

erage) 

"Max. Pump. Low Volatile Metals Lb/hr 

Feedrate (12 Hour Rolling Total) 

Max, Total Low Volatile Metals Lb/hr 

Feedrate (12 Hour Rolling Total) 

Maximum Semi Volatile Metals Lb/hr 

Feedrate (12 Hour Rolling Total) 

Maximum Mercury Feed rate Lb/hr 

(12 Hour Rolling Total) 

Maximum Chlorine Feed rate Lb/hr 

(12 Hour Rolling Total) 

Maximum Ash Feed Rate (12 Lb/hr 

Hour Rolling Total) 

Carbon Ejection Feedrate Lb/hr 

(Hourly Rolling Average) 

PCC - 3256 

SCC -1006 

PCC -13,796 

SCC -1006 

38,086 

1507 

1886 

434 

47 

55 

65 

0.031 

252 

8777 

6:2 

Sept, 2003 

Cond. 1 

Sept., 2003 

Cond. 1 

Aug., 2008 

Sept., 2003 

Cond. 1 

Sept., 2003 

Cond. 1 

Aug., 2008 

Aug., 2008 

Aug., 2008 

Aug., 2008 

Aug., 2008 

Aug., 2008 

Dec, 1995 

Aug, 2008 

DRE, D/F 

DRE, D/F 

DRE, D/F, 

Part, SVM, 

LVM 

DRE, D/F 

DRE, D/F 

D/F, SVM, 

LVM 

LVM 

LVM 

SVM 

Hg 

SVM, LVM, 

HC1/C12 

Part. 

D/F, Hg 

Minimum Sorbent Feedrate 

(Hourly Rolling Average) 

Minimum Carrier pljiid Flowrate 

(Hourly Rolling Average) 

Lb/lb Cl2 

Gal/lb Cl2 

1.01 

1.61 

Dec, 1995 

Dec, 1995 

HC1/C12 

HC1/C12 
UNIT 2 

EMISSION RESULTS 

c 

( 

V E S 000808 
Table 3-3 RM 29 Sampling Parameters and Emission Results - Week of August 11, 

ENSR 

2008 

Run No. I 1 _ 2 ) 3 

Date j r It-AmSS ' t2-Aug-03 f t3-Ai/g-08 

Start Time "Units f 14:40 

r

 16:50 "' 

'11.05 

^'13T16 

f 10.39 

Stop Time 

f 14:40 

r

 16:50 "' 

'11.05 

^'13T16 "ri? :

4 7 AVGS 

Sampling Parameters — 

Barometric Pressure in. Hg r

 29^ 60 29.55 f 29.50 29.61 

Volume Metered def f 83'650 " 86.044 " ' 85 611 '81J996 

Sample Volume dscf \ 76 /50 80 233 ]' 78.036 78.340 

....... Moisturel 

02 at Stack 

% y/\T 

% dry T 11 72 

' 40.1"" 

7

 11.54 

"."I III!!..' 

J 11.30 11.52 

Avg. Stack Temp. .369 f 370 r

 358 365 

Stack Flowrate dscfm I 5,495 5,572 T" 5,357 5,475 

Isokinetics % ? 93 "96 i 97 95 

Mercun'(Ha) — 

pg. 

ug/m3 

83.5" \ 89.4 "T_"87.9'Z 87.0 

Stack Cone @ 7% 07 

pg. 

ug/m3 f 58.0 58.2 "]' 57.4 ' 67.9 

Stack Emission Rate Vlb/lir ' 

g/sec 

; y.9TFr 04 ^ 

i'a.96E-05 

8.22E 04 

104E-04 

7.99I.-04 

; 1 01E-04 

' 8.04E-04 

"VotL-04 

Total Chromium (Cr) H LVM ; 

Quantity Collected jjg„_„. | 78.75 75.66 XLZIJIX " 75.85 

Stack Cone. @ 7% 02 ug/m3 1 54.66 [ 49.28 47*76 " 50.57 

Stack Emission Rate Ib/hr 7.46E-04 'o.95h.04 j 6.64E-04 '7.02E-O4 

j g/sec 1 9.40E-05 i 8.76E-05 ! 8.37E-05 '>784E-u5 

Cadmium (Cd) — SVM \ 

Quantity Collected j 1.9 9 2.06 .'." X jJi . 

'r'~i-?l'. 

! Stack Cone. @7%0 2 

• Stack Emission Rate 

ug/m3 

' Jr5hr ' 

j 1.38 

':1.88E-05 

1.34 

1.89f;-05 

T ^'21 

r

'L68L-65 ' 

1.31 

r

"l .82E:05 ~ 

T l g/sec ;2.37E06 2.38E 06 " " "1 2;i?F:-06 

iLead (PM- SVM 

r

fQuantiry Collected 356 08 £9 " j 3?9.5 ' 369 2 '369.5 ' r

 356 08 

IStackConc. @7%Os ug/m3 ! 228.7 240.5 :

 241.3 " 236.8 

Stack Emission Rate Ib/hr 3.12E-03 j 3.3GE 03 r

3.29E-03 

r

"• T ' " " ' " ' AML-QA 

i 

g/sec 04 ''L23K-04' 

r

3.29E-03 

r

 AML-QA 

Arsenic (As)— 

Quantity Collected m. 10.08 

Stack Cone. @ 7% 02 pg/m3 11.80 6.57 f 3/0 

r

" 7.36 

Stack Emission Rate lb/hr 1.61E-04 i 9.26E-05 ' 1.02E-04 

g/sec 2.03E-05 1.17E-05 16~49E-u6 r

'f.28E-d5 

Beryllium (Be) — 

Quantity Collected jjg... 0.20 0.20 j 0.20 XPJILX Stack Cone. @ 7% 0? 

Stack Emission Rate 

pg/rrr 

Jb/hr 

g/sec 

j 0.14 

: i.89i:;-«i 

:

2 39E-07 

0.13 

1.84H-06 

2 .32fc;-07 ' 

1 0.13 

j 1.82E-06 

'2 29E-07'" 

0.13 

r

i85E-06 

' 2.33F-07 

LVM! Total.= ug/m3 j i 58.0 I 51.S 53.8 

SVM Totaf = pg/rrf j 230.1 : 2418 242.5 238.1 

C:\DOCUME-1\Marich.TVViU.OCALS--1\Temp\notesD30550 3-4 October 200B 

Weolia Report Unit 2 final-doc 

VES 000809 
ENSR 

Table 3-4 Summary of HWC MACT Metals - August 11,2008 

Low Volatile Metals Emissions -ug/m3@7% 0 2 

Metals Run 1 Run 2 Run 3 Average 

As 11.60 6.57 3.70 

Be 0.14 . 0.13 0.13 

Cr 54.7 49.3 47.8 

Total LVM 66.6 56.0 51.6 58.1 

LVM Regulatory Standard = 97 ug/m3 

Semi-Volatile Metal Emissions • VQlm* @ 7% 0 2 

Metals Rim 1 Run 2 Run 3 1 Average 

Pb 229 240 241 

Cd 1.38 1.34 1.21 

Total SVM 230 242 242 238 

SVM Regulatory Standard = 240 ug/m3 

I Mercury Emissions -|jgfm3(g> 7% 0 2 

Run 1 Run 2 Run 3 Average 

58.0 58.2 57.4 57.9 

Mercury Regulatory Standard = 130 ug/m3 

C:\DOCUME-1\Warich.TWI\LOCALS-1\Temp\natesD30550 

Weolia Report Unit 2 final.doc 

3-5 October 2008 

VES 000810 
ENSR 

Table 3-5 RM 29 Sampling Parameters and Emission Results - Week of September 8, 2008 

Run No. 

Date 

Start Time 

Slop^Time 

Units 

1 

r

08-Sep-08 

r

 14:36 

r

 16:46 

2 

r

09-Sep-08 

r

 12:20 

r

 14:30 

3 

r

10-Sep-08 

r

 09:44 

r

 11:53 AVGS 

Sampling Parameters — 

Barometric Pressure 

Volume Metered 

Sample Volume 

Moisture 

02 at Stack 

Avg. Stack Temp. 

Stack Flowrate 

Isokinetics 

in. Hg 

def 

dscf 

% v/v 

% dry 

T 

dscfm 

% 

r

 29.60 

r

 77.382 

75.296 

41.4 

r

 11.21 

r

 385 

4,698 

107 

r

 29.75 

r

 79.269 

78.407 

41.2 

r

 10.91 

" 381 

5,099 

103 

r

 29.72 

r

 78.905 

78.654 

41.3 

r

 11.35 

r

 384 

5248 

100 

' 29.71 

" 77.059 

• 77.452 

41.5 

7

 11.16 

' 383 

5,015 

104 

Total Cliromiumt'Cr) -

Quantity Collected 

Stack Cone. @ 7% 02 

Stack Emission Rate 

LVM 

pg 

ug/m3 

Ib/hr 

g/sec 

12.16 

8.16 

1 .OOE-04 

1.26E-05 

2.79 

1.74 

2.40E-05 

3.02E-06 

9.18 

5.98 

8.10E-05 

1.02E-05 

' 8.04 

5.29 

r

6.85E-05 

' 8.63E-06 

Cadmium (Cd) — 

Quantity Collected 

Stack Cone. @ 7% 02 

Stack Emission Rate 

SVM 

ug 

ug/m3 

Ib/hr 

g/sec 

2.73 

1.83 

2.25E-05 

2.83E-06 

2.74 

1.71 

2.35E-05 

2.96E-06 

2.20 

. 1.43 

1.94E-05 

2.44E-06 

" 2.55 

1.66 

'2.18E-D5 

r

2.75E-06 

LeadfPVtQuantity Collected 

Stack Cone. @ 7% 0 2 

Stack Emission Rate 

SVM 

M9 

ug/m3 

Ib/hr 

g/sec 

45.E 

30.6 

3.76E-04 

4.74E-05 

13.9 

8.7 

1.20E-04 

1.51 E-05 

39.0 

25.4 

3.45E-04 

4.34E-05 

' 32.84 

21.6 

r

2.80E-04 

" 3.53E-05 

Arsenic (As) -

Quantity Collected 

Stack Cone. @ 7% 02 

Stack Emission Rate 

MS 

ug/m3 

Ib/hr 

g/sec 

2.80 

1.88 

2.31 E-05 

2.91 E-06 . 

2.10 

1.31 

1.81 E-05 

2.28E-06 

2.10 

1.37 

1.85E-05 

2.34E-06 

" 2.33 

7

 1.52 

"1.99E-G5 

"2.51 E-06 

Beryllium (Be) — 

Quantity Collected 

Stack Cone. @7% 02 

Stack Emission Rate 

MS 

ug/ma 

Ib/hr 

g/sec 

0.20 

0.13 

1.65E-06 

2.08E-07 

0.20 

0.12 

1.72E-06 

2.17E-07 

0.20 

0.13 

1.77E-06 

2.22E-07 

7

 0.20 

0.13 

'1.71 E-06 

'2.16E-07 

LVM Total = ug/m3 10.2 3.2 7.5 6.9 

SVM Total = pg/m3 32.4 10.4 26.9 23.2 

C:\DOCUME-1\l<larich.TWI\LOCALS-1\Temp\notesD30550 3-6 October2008 

Weolia Report Unit 2 final.doc 

VES 000811 
ENSR 

Table 3-6 Summary of HWC MACT Metals - September 8,2008 

Low Volatile Metals Emissions •|ig/m3@ 7% 0 2 

Metals Rim 1 Run 2 Run 3 Average 

As . 1.88 1.31 1.37 

Be 0.13 0.12 0.13 

Cr 8.2 1.7 6.0 

Total LVM 10.2 3.2 7.5 6.9 

LVM Regulatory Standard = 92 ug/m3 

Semi-Volatile Metal Emissions -ugfm3@7% Q2 

Metals Run 1 Run 2 Run 3 Average 

Pb 30.6 8.7 25.4 

Cd 1.83 1.71 1.43 

Total SVM 32.4 10.4 26.9 23.2 

SVM Regulatory Standard = 230 ug/m3 

C:\DOCUME~1\klarich.TWI\L0CALS~1\Temp\notesO30550 

Weolia Report Unit 2 final-doc 

3-7 October 2008 

VES 000812 
UNIT 3 

EMISSION RESULTS 
ENSR 

Table 3-1 RM 29 Sampling Parameters and Emission Results 

Run No. 

Date 

Start Time 

Stop Time 

Units 

1 

05-Aufl-08 

" 12:56 

r

 15:19 

2 

06-Aug-08 

" 12:32 

r

 14:41 

3 

07-Aug-08 

r

 12:45 

" 15:04 AVGS 

Sampling Parameters — 

Barometric Pressure 

Volume Metered 

Sample Volume 

Moisture 

Oz at Stack 

Avg. Stack Temp. 

Stack Flowrate 

Isokinetics 

in. Hg 

def 

dscf 

% v/v 

% dry 

°F 

dscfm 

% 

r

 29.23 

r

 88.539 

78.488 

42.3 

11.99 

" 372 

5,665 

92 

T

 29.65 

" 87.452 

84.258 

43.6 

10.96 

r

 377 

5,719 

98 

' 29.65 

" 85.943 

83.932 

40.6 

11.98 

r

 374 

5,890 

95 

' 29.51 

' 87.311 

82.226 

42.2 

11.64 

' 374 

5,758 

95 

Mercurv (He) — 

Quantify Collected 

Stack Cone. @ 7% 02 

Stack Emission Rate 

pg 

pg/m3 

Ib/hr 

g/sec 

78.5 

54.9 

7.49E-04 

9.44E-05 

105 

61.1 

9.39E-04 

1.18E-04 

88.2 

57.6 

8.19E-04 

1.03E-04 

' 90.4 

57.9 

' 8.36E-04 

' 1.05E-04 

Total Chromium (Cr1) -

Quantity Collected 

Stack Cone. @ 7% 02 

Stack Emission Rate 

LVM 

P9 

pg/m3 

Ib/hr 

g/sec 

37.50 

26.22 

3.58E-04 

4.51 E-05 

30.49 

17.81 

2.74E-04 

3.45E-05 

21.76 

14.21 

2.02E-04 

2.55E-05 

' 29.92 

19.41 

' 2.78E-04 

" 3.50E-05 

Cadmium (Cd) — 

Quantity Collected 

Stack Cone. @ 7% 02 

Stack Emission Rate 

SVM 

pg 

pg/m3 

Ib/hr 

g/sec 

0.24 

0.17 

2.27E-06 

2.86E-07 

0.90 

0.53 

8.08E-06 

1.02E-06 

0.63 

0.41 

5.85E-06 

7.37E-07 

0.59 

0.37 

' 5.40E-06 

* 6.80E-07 

LeadflPb)--

Quantity Collected 

Stack Cone. @ 7% 02 

Stack Emission Rate 

SVM 

pg 

pg/m3 

Ib/hr 

g/sec 

83.5 

58.4 

7.97E-04 

J.OOE-04 

114 

66.6 

1.02E-03 

1.29E-04 

70.1 

45.8 

6.50E-04 

8.19E-05 

' 89.18 

56.9 

" 8.24E-04 

r

 1 04E-O4 

Arsenic (As) — 

Quantity Collected 

- Stack Cone. @ 7% O2 

Stack Emission Rate 

pg 

pg/m3 

Ib/hr 

g/sec 

3.15 

2.20 

3.01 E-05 

3.79E-06 

3.75 

2.19 

3.37E-05 

4.24E-06 

1.94 

1.27 

1.80E-05 

2.27E-06 

' 2.95 

1.89 

"2.73E-05 

" 3.43E-06 

Beryllium (Be) — 

Quantity Collected 

Stack Cone. @ 7% 02 

Stack Emission Rate 

M9 

pg/m3 

Ib/hr 

g/sec 

0.20 

0.14 

1.91E-06 

2.41.E-07 

0.20 

0.12 

1.80E-06 

2.26E-07 

0.20 

0.13 

1.86E-08 

2.34E-07 

" 0.20 

0.13 

'1.85E-08 

" 2.34E-07 

LVM Total = pg/m3 28.6 20.1 15.6 21.4 

SVM Total = pg/m3 58.6 67.1 46.2 57.3 

C:\DOCUME-1\klarlch.TWHLOCALS-1\Temp\notesD30S50 3-2 Ortober2008 

Weolia Report U nit 3 draft-doc 

VES 000814 
ENSR 

Table 3-2 Summary of HWC MACT Metals 

Low Volatile Metals Emissions -ug/m3<§> 7% 02 

Metals Run 1 Run 2 Run 3 Average 

As 2.20 2.19 1:27 

Be 0.14 0.12 0.13 

Cr 26.2 17.8 14.2 

Total LVM 28.6 20.1 15.6 21.4 

LVM Regulatory Standard = 92 pg/m3 

Semi-Volatile Metal Emissions - ug/m3

 @ 7% 02 

Metals Run 1 Run 2 Run 3 Average 

Pb 58.4 66.6 45,8 

Cd 0.17 0.53 0.41 

Total SVM 58.6 67.1 46.2 57.3 

SVM Regulatory Standard = 230 pg/m3 

iVlercury Emissions -pg/m3 @ 7% 02 

Run 1 Run 2 Run 3 Average 

54.9 61.1 57.6 57.9 

Mercury Regulatory Standard = 130 pg/m3 

C:\DOCUME-1\klarich.TWHLOCALS-1\Temp\notesD30550 

Weolia Report Unit 3 drstt.ioc 

3-3 October 2008 

VES 000815 
UNIT 4 

EMISSION RESULTS 
ENSR 

Table 3-2 RM 29 Sampling Parameters and Emission Rates 

Run No. 

Date 

Start Time 

Stop Time 

Units 

1 

r

21-Aug-08 

r

 13:25 

r

 -15:37 

2 

r

22-Aug-08 

r

 10:50 

r

 13:01 

3 

r

23-Aug-08 

r

 08:55 

" 10:59 AVGS 

Sampling Parameters — 

Barometric Pressure 

Volume Metered 

Sample Volume 

Moisture 

0 2 at Stack 

Avg. Stack Temp. 

Stack Flowrate 

Isokinetics 

in. Hg 

def 

dscf 

% v/v 

% dry 

°F 

dscfm 

% 

r

 29.54 

r

 90.938 

89.023 

39.0 

" 12.27 

r

 390 

17,280 

101 

r

 29.69 

" 89.784 

88.433 

39.5. 

T

 12.13 

r

 388 

17,255 

100 

r

 29.64 

" 91.420 

89.264 

40.3 

r

 11.63 

r

 394 

17,189 

102 

' 29.62 

" 90.714 

88.907 

39.6 

12.01 

' 391 

17,241 

101 

Mercury (~H%) -

Quantity Collected 

Stack Cone. @ 7% 0 2 

Stack Emission Rate 

pg 

pg/m3 

Ib/hr 

g/sec 

59.6 

37.9 

1.53E-03 

1.93E-04 

38.7 

24.4 

9.99E-04 

1.26E-04 

42.3 

25.0 

1.08E-03 

1.36E-04 

' 46.9 

29.1 

r

1.20E-03 

" 1.51 E-04 

Total Chromium (Cr) ~ 

Quantity Collected 

Stack Cone. @ 7% 0 2 

Stack Emission Rate 

LVM 

pg 

pg/ma 

Ib/hr 

g/sec 

3.12 

1.98 

8.01 E-05 

1.01 E-05 

6.2B 

3.96 

1.62E-04 

2.04E-05 

6.40 

3.78 

1.63E-04 

2.05E-05 

" 5.27 

3.24 

'1.35E-04 

r

 1.70E-05 

Cadmium fCd) — 

Quantity Collected 

Stack Cone. @ 7% 02 

Stack Emission Rate 

SVM 

pg 

pg/m3 

Ib/hr 

g/sec 

0.80 

0.51 

2.05E-05 

2.58E-06 

1.27 

0.80 

3.27E-05 

4.12E-06 

1.29 

0.76 

3.29E-05 

4.14E-06 

r

 1.12 

0.69 

r

2.87E-05 

k

 3.61 E-06 

LeadrPhVQuantity Collected 

Stack Cone. @ 7%. 02 

Stack Emission Rate 

SVM 

pg 

pg/m3 

Ib/hr 

g/sec 

34.3 

21.8 

8.81 E-04 

1.11E-04 

49.1 

30.9 

1.27E-03 

1.60E-04 

44.5 

26.3 

1.13E-Q3 

U3E-04 

r

 42.63 

* 26.4 

"1.09E-03 

r

 1.38E-04 

Arsenic (As) — 

Quantity Collected 

Stack Cone. @ 7% 0 2 

Stack Emission Rate 

pg 

pg/m3 

Ib/hr 

g/sec 

4.82 

3.07 

1.24E-04 

1.56E-05 

9.82 

6.19 

2.53E-04 

3.19E-05 

16.22 

9.59 

4.13E-04 

5.21 E-05 

' 10.29 

6.28 

r

2.63E-04 

' 3.32E-05 

Beryllium (Bet -

Quantity Collected 

Stack Cone. @ 7% 02 

Stack Emission Rate 

pg 

pg/m3 

Ib/hr 

g/sec 

0.20 

0.13 

5.13E-0B 

B.47E-07 

0.20 

0.13 

5.16E-06 

6.50E-07 

0.20 

0.12 

5.09E-06 

6.42E-07 

' 0.20 

0.12 

'5.13E-06 

' 6.46E-07 

LVM Total = 5.2 10.3 13.5 g.e 

SVM Total = pg/m3 22.3 31.7 27.1 27.0 

CADOCUME-1\klarich.TWI\LOCALS-1\Temp\noIesD30550 3-3 October 2008 

\-7902083.doc 

VES 000817 
ENSR 

Table 3-3 Summary of HWC MACT Metals 

Low Volatile Metals Emissions -ugfm3<§ 7% Q 2 

Metals Run 1 Run 2 Run 3 Average 

As 3.07 6.19 9.59 

Be 0.13 0.13 0.12 

Cr 2.0 4.0 3.8 

Total LVM 5.2 10.3 13.5 9.6 

LVM Regulatory Standard = 92 pg/m3 

Semi-Volatile Metal Emissions -|jg/m 3 @ 7 % O z 

Metals Run 1 Run 2 Run 3 Average 

Pb 21.8 30.9 26.3 

Cd 0.51 0.80 0.76 

Total SVM 22.3 31.7 27.1 27.0 

SVM Regulatory Standard = 230 pg/m3 

Mercury Emissions -jjg/m3 % 7% 0 2 

Run 1 Rim 2 Run 3 Average 

r m m m 37.9 24.4 25.0 29.1 

Mercury Regulatory Standard = 130 pg/m3 

C:\DOCUME-1\klarich.TWI\LOCALS~1\Temp\notesD30550 

V-T902083.doc 

3-4 October 2008 

VES 000818 
SYSTEM REMOVAL EFFICIENCY (SRE) 

FOR 

UNITS 2, 3 AND 4 
2008 Metals Testing Removal Efficiencies, 

Unit 2 (LVM) Removal Unit 3 (LVM) Removal Unit 4 (LVM) Removal 

Em. Std.: 92 ug/dscm Run Efficiency (RE)j Em. Std.: 92 ug/dscm Run Efficiency (RE) Em. Std.: 92 ug/dscm Run Efficiency (RE) 

(9/08) (%) (%) (%) 

1 99.99973 1 99.99924 1 99.99961 

2 99.99991 2 99.99940 2 99:99923 

3 .99.99979. 3 99.99958 3 99.99893 

Avg 99.99981 Avg . 99.99940 Avg 99.99926 

Unit 2 (SVM) Removal Unit 3 (SVM) Removal Unit 4 (SVM) Removal 

Em. Std.: 230 ug/dscm Run Efficiency (RE) Em. Std.: 230 ug/dscm Run Efficiency (RE) Em. Std.: 230 ug/dscm- Run Efficiency (RE) 

(9/08) (%) (%) (%) 

1 99.99936 1 99.99877 1 99.99862 . 

2 99.99978 2 99.99844 2 99.99800 

3 99.99942 3 99.99899 3 99.99824 

Avg 99.99952 Avg^ 99.99873 Avg 99.99829 

Unit2(Hg) Removal Unlt3(Hg) Removal Unit4(Hg) Removal 

Em. Std.: 130 ug/dscm Run Efficiency (RE) Em. Std.: 130 ug/dscm Run Efficiency (RE) Em. Std.: 130 ug/dscm. Run Efficiency (RE) 

(8/08) (%) (%) (%) 

1 84.79 1 83.38 1 95.00 

2 81.32 2 83.25 2 96.72 

3 82.63 3 83.96 3 96.47 

Avg 82.91 Avg 83.53 Avg 96.06 
Revision: 1 

Date: July 2008 

Section: 2.0 

Veolia ES Technical Solutions Unit 2 HWC MACT Performance Test Plan Page 1 of 12 

2.0 Engineering Description 

2.1 Process Overview 

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

(Unit 4) at the Sauget, IL facility. The two fixed hearth units are rated at 16 million Btu/hr 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 § 63.1207(f)(1)(ii)(c) and (f)(1)(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 million Btu/hr. 

Unit 2 is supported by storage/blend tanks located in Tank Farm #1. Rates of feed are controlled at each 

incinerator. Segregated liquid wastes are stored until utilized 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 limitations). The material is transferred through 

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

and aqueous waste are equipped with strainers. 

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

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

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

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

are installed between the carbon adsorbers and the tanks. 

2.2.1.1 Organic and Aqueous Liquid Waste Feeds 

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

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

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

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

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2.2.1.2 Packaged and Bulk Solid 

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

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

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

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

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

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

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

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

of the feeder is as follows: 

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

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

• The airlock door is closed. 

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

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

the incinerator door closes. 

2.2.1.3 Specialty Liquid Feeds and Gases 

Specialty Feed Systems associated with Incinerator 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 § 63.1207(f)(1)(iii)(A)] 

2.3.1 Combustion Chamber and Burners [40 CFR §63.1207(f)(1 )(iii)(B) and (C) 

Incinerator 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 ofthe waste takes place at temperatures in excess of 1700 

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

degrees F. 

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

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

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

design specifications. 

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

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

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

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

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

burn natural gas. 

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

approved burner management system complete with interlocks and safety valves. 

2.3.2 Secondary Combustion Chamber 

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

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

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

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

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

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

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

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

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

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

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

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

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

combustion gases within the system is approximately 5 seconds. 

2.3.3 Location of Combustion Zone Temperature Device [40 CFR § 63.1207(f)(1)(xix)] 

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

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 § 63.1207(f)(1)(ix)] 

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

• Primary Combustion Chamber Volume - 635 ft3 

• Secondary Combustion Chamber Volume - 635 ft3 

• Total Volume-1270ff.3 

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

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

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2.3.5 Combustion System Leak 

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

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

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

2.3.6 Emergency Safety Vent 

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

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

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

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

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

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

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

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

2.4 Procedures for Rapidly Stopping Hazardous Waste Feed During Equipment 

Malfunction [40 CFR §63.1207(f)(1)(viii)] 

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

regular field inspections. 

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

will be notified. The control room operator will then close the waste feed valves and disable the waste feed 

pumps. 

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

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

2.5 Air Pollution Control Equipment [40 CFR §63.1207(f)(1)(iii)(G)] 

2.5.1 Air Pollution Control Systems Descriptions 

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

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

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

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

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

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

eventual discharge point to atmosphere. 

2.5.1.1 Lime System 

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

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

designed for batch mixing to provide this service. Veolia utilizes hydrated lime as its neutralizing agent inf 

the air pollution control systems. The key neutralization parameter of the hydrated lime is the "CaO 

Equivalent". Figure 4-1 is the specification sheet for the hydrated lime that Veolia uses. Veolia has used 

this specific product for over 20 years and plans to continue with its use. Although, if Veolia does change 

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suppliers or type of lime in the future, it would have a "CaO Equivalent" specification equal to or greater than 

the 72.6% shown on Figure 4-1. 

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 ofthe 

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

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

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

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

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

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

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

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

atomizer at a rate of up to 10 gpm. 

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 3/8 inch carbon steel. The function of the SDA is to: 

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

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

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

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

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

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

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

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

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

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

cloud of finely divided droplets around the periphery of the atomizer wheel. Cooling water is also passed 

through the atomizer to provide additional gas cooling to the system. The water flow is not metered, but is 

controlled by a feedback signal from the atomizer power transmitter. This provides verification that water flow 

to the atomizer increases or decreases in proportion to the spray dryer absorber outlet temperature. 

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

The disperser directs the flue gas through the zone filled 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 ofthe resulting dry material, consisting of 

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

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

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2.5.1.3 Fabric Filter 

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

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

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

to the inside ofthe 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. 

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

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

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

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

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

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

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

pressure across the filter reaches a predetermined setpoint of approximately 7.0" w.c, or when the operator 

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

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

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

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

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

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

modules to an outlet manifold for exhaust. 

2.5.1.4 Induced Draft Fan and Stack 

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

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

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

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

volume control damper to be used to control the velocity ofthe 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)(1)(iiij(H)] 

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

conditioning apparatus, arid 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 the 

Appendix to Subpart EEE of Part 63—Quality Assurance Procedures for Continuous Emissions 

Monitors Used for Hazardous Waste Combustors. 

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

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

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

instruments including the operating range and measurement principal. 

2.6.1 CEM System Description 

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

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

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 

Parameter Current Mfg. Range Principle ] 

Oxygen COSA 0-25% Electrochemical 

Carbon Monoxide Ecochem MC3 0-200 ppmv 

0-3000 ppmv 

Infrared 

I Total hydrocarbons Thermoelectron 0-100 ppmv FID/lnfrared 

| Hydrogen chloride Ecochem MC3 0-1,000 ppmv Infrared 

Opacity Teledyne 0-100% White light 

Stack gas flow PSE/Rosemount 0-20,000 acfm Pressure drop | 

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: 

• 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. 

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

performing a number of activities including: 

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

indication of a field installed pressure transmitter); 

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

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

temperature control valve; and 

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

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

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

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

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

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

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

alarm alerts the incinerator operator to significant deviations from normal operating conditions. This system 

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

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

permit limit levels. Monitoring methods and calibration frequencies are listed in Table 2-3. 

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

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

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

controls. 

2.8 Automatic Waste Feed Cut-off System [40 CFR §63.1207(f)(1)(iii)(F)] 

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

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

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

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

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

below. 

• Regulatory/permit limits - established to comply with existing permits. An example of this type of limit 

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

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

of each process instrument that is part ofthe 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 safety limits - established to assure process equipment is protected and unsafe operating 

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

can lead to fuel rich conditions. 

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

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

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

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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 

Veolia tests the AWFCO systems bi-weekly, as weekly testing would unduly interfere with operations by 

ceasing and restarting waste feeds, potentially increasing emissions, incurring excessive downtime, burning 

additional natural gas during the downtime, and increasing operating costs. Testing ofthe AWFCO system is 

a time-consuming and manpower intensive process. The current testing program has been in place under the 

RCRA permit for over 20 years and has proven to be adequate in detecting problems. This rationale is 

included in the facility's AWFCO Plan. 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 ofthe incinerator's PLC system to make sure that should process 

conditions deviate from allowable limits, the computer logic will initiate waste feed shutdowns as required. 

This is accomplished by manually simulating process conditions that are outside allowable limits and observing 

and documenting when the control or block valve software logic on the waste feed line begins to initiate valve 

closure. Should actual AWFCOs occur during a given testing period, these are documented by operating 

personnel to satisfy regulatory requirements for system testing. Results of this testing are documented on a 

separate AWFCO Testing Log and maintained as part of the unit's Operating Record. 

2.9 Air Pollution Control Equipment Maintenance Practices [40 CFR 

§63.1207(f)(1)(iii)(G)] 

2.9.1 Program Overview 

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

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

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

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

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

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

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

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

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

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

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

2.9.2 Test Program Preparation Activities 

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

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

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

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

Manufacturer Trade Waste Incineration 

Model No. TWI-2000, Series 2 

Type Fixed Hearth, Dual Chamber 

Date of Manufacture 1987 

Dimensions Primary. Chamber Secondary Chamber 

External Length 17.5' 17.5' 

External Diameter 9' 9' 

Internal Diameter 7'2" 7'2" 

Cross-sectional area 40.3 square feet 40.3 square feet 

Burners Primary Chamber Burner Secondary Chamber Burner 

Manufacturer North American North American 

Size 12.0 Million Btu/hr 6.0 Million Btu/hr 

Fuel Natural Gas Natural Gas 

Primer Mover Induced Draft Fan 15,000 acfm @ 400°F saturated, 22 in. water column 

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

1 System Device Units Cutoff Limits 

Calibration j 

Frequency | 

J Total Pumpable Waste Feed 

frar.e 

Mass Flowmeters/Scales Lb/hr > 3,123 (HRA) Annually 

Total Waste Feedrate Mass Flowmeters/Scales Lb/hr >4,301 Annually/quarterly 

High BTU Liquid feedrate Mass flow meter lb/hr > 2,012 Annually 

Low BTU Liquid feedrate Mass flow meter Ib/hr > 1,993 Annually 

Specialty feeder Scale Ib/hr 5 724 Quarterly 

Total LVM Feedrate Mass Flowmeters/Scales Ib/hr > 1,264 (12 HRA) Annually/quarterly 

Pumpable LVM Feedrate Mass flow meter/Scales Ib/hr > 1,264 (12 HRA) Annually/quarterly 

SVM Feedrate Mass Flowmeters/Scales Ib/hr >3,477(12HRA) Annually/quarterly 

Mercury Feedrate Mass Flowmeters/Scales Ib/hr > 0.0073 (12HRA) Annually/quarterly 

Chlorine Feedrate Mass Flowmeters/Scales Ib/hr >237 (12 HRA) Annually/quarterly 

Ash Feedrate Mass Flowmeters/Scales Ib/hr > 673 (12 HRA) Annually/quarterly 

Primary Combustion 

Chamber Temperature 

Type K Thermocouple °F <1,590 (one-minute average) 

<1,712 (HRA1) 

>2,400 (instantaneous) 

Annually 

• Secondary Combustion 

Chamber Temperature 

Type K Thermocouple °F £1,794 (one-minute average) 

<1,845 (HRA1) 

>2,400 (instantaneous) 

Annually 

Primary Combustion 

Chamber pressure 

Pressure transmitter in. w.c. >-0.1 (5 second delay) Quarterly 

Secondary Combustion 

Chamber pressure 

Pressure transmitter in. w.c. 5 -0.1 (5 second delay) Quarterly 

Chlorine Feed to Slurry Flow 

Ratio 

Flowmeter ratio > 33.5 Annually 

[Spray Dryer Adsorber Outlet 

I Temperature 

Type K Thermocouple °F >500 (one minute average) 

>420 (HRA) 

Annually 

Combustion Gas Flow Rate Pitot Tube acfm £17,198 

>15,534 (HRA) 

Annually 

Stack Gas Excess Oxygen Zirconium Oxide fuel cell % < 3 (one-minute avg.) Quarterly 

Stack carbon monoxide Infrared ppmv >100 (HRA) 

2500 (one minute average) 

Quarterly 

Stack Hydrocarbon FID ppmv >10 (one minute average) Quarterly 

Stack gas opacity White Light % £10 (one minute average) Quarterly 

Stack hydrogen chloride2 Infrared ppmv >100 (HRA) 

2500 (one minute average) 

Quarterly 

Fabric filter pressure drop Delta P transmitter in. w.c. £ 2 or > 10 (1 min. average) Quarterly 

1

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

I

 z This is a RCRA permit limit only. 

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Figure 2-1 Hydrated Lime Specifications 

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2.0 Engineering Description 

2.1 Process Overview 

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

(Unit 4) at the Sauget, IL facility. The two fixed hearth units are rated at 16 million Btu/hr 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 § 63.1207(f)(1)(ii)(c) and (f)(1)(iii)(D) and (E)] 

2.2.1 Unit 3 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 and direct inject liquids fed through the aqueous or organic liquid feed systems. These 

units can receive any combination of wastes - liquid, semi-solid or solid - with a heat value of up to 16 million 

Btu/hr. 

Unit 3 is supported by storage/blend tanks located in Tank Farm #1. Rates of feed are controlled at each 

incinerator. Segregated liquid wastes are stored until utilized 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 limitations). The material is transferred through 

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

and aqueous waste are equipped with strainers. 

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

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

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

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

are installed between the carbon adsorbers and the tanks. 

2.2.1.1 Organic and Aqueous Liquid Waste Feeds 

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

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

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

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

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2.2.1.2 Packaged and Bulk Solid 

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

Plan. These wastes can then be delivered directly to Unit 3 Or repacked into small combustible containers at 

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

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

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

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

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

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

of the feeder is as follows: 

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

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

• The airlock door is closed. 

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

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

the incinerator door closes. 

2.2.1.3 Specialty Liquid Feeds and Gases 

Specialty Feed Systems associated with Incinerator No. 3 are as follows 

• Hooded Specialty Container Feeder 

• Glove Box Emission Control Systems 

• Direct Inject Liquid Feed System 

2.3 Manufacturer, Make and Model of the Incinerator [40 CFR § 63.1207(f)(1)(iii)(A)] 

2.3.1 Combustion Chamber and Burners [40 CFR §63.1207(f)(1)(iii)(B) and (C) 

Incinerator No. 3 features a two-stage combustion process. Ignition of waste material takes place in the 

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

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

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

degrees F. 

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

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

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

design specifications. 

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

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

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

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

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

burn natural gas. 

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

approved burner management system complete with interlocks and safety valves. 

2.3.2 Secondary Combustion Chamber 

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

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

inches of brick refractory and insulation backing, making the internal operating diameter approximately 

7'2". The cross-sectional area of the chamber is thus 40.3 square feet. 

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

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

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

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

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

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

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

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

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

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

combustion gases within the system is approximately 5 seconds. 

2.3.3 Location of Combustion Zone Temperature Device [40 CFR §63.1207(f)(1)(xix)] 

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

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

on top ofthe chamber above the transition. 

2.3.4 Hazardous Waste Residence Time [40 CFR §63.1207(f){1 )(ix)] 

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

• Primary Combustion Chamber Volume - 635 fr.3 

• Secondary Combustion Chamber Volume - 635 ft3 

. Total Volume-1270113 

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

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

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2.3.5 Combustion System Leak 

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

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

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

2.3.6 Emergency Safety Vent 

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

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

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

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

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

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

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

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

2.4 Procedures for Rapidly Stopping Hazardous Waste Feed During Equipment 

Malfunction 140 CFR §63.1207(f)(1)(viii)] 

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

regular field inspections. 

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

will be notified by radio. The control room operator will then disable the waste feed pumps and close the waste 

feed valves. 

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

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

2.5 Air Pollution Control Equipment [40 CFR §63.1207(f)(1)(iii)(G)] 

2.5.1 Air Pollution Control Systems Descriptions 

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

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

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

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

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

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

eventual discharge point to atmosphere. 

2.5.1.1 Lime System 

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

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

designed for batch mixing to provide this service. Veolia utilizes hydrated lime as its neutralizing agent inf the 

air pollution control systems. The key neutralization parameter of the hydrated lime is the "CaO Equivalent/'. 

Figure 4-1 is the specification sheet for the hydrated lime that Veolia uses. Veolia has used this specific 

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product for over 20 years and plans to continue with its use. Although, if Veolia does change suppliers or type 

of lime in the future, it would have a "CaO Equivalenf specification equal to or greater than the 72.6% shown 

on Figure 4-1. 

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

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

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

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

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

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

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

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

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

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

atomizer at a rate of up to 10 gpm. 

2.5.1.2 Spray Dry Absorber 

Unit 3 is equipped with a Spray Dryer Absorber (SDA) located immediately downstream ofthe secondary 

combustion chamber. The SDA unit is fabricated of 3/8 inch carbon steel. The function ofthe SDA is to: 

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

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

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

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

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

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

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

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

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

velocity. The design ofthe 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. Cooling water is also passed 

through the atomizer to provide additional gas cooling to the system. The water flow is not metered, but is 

controlled by a feedback signal from the atomizer power transmitter. This provides verification that water flow 

to the atomizer increases or decreases in proportion to the spray dryer absorber outlet temperature. 

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

The disperser directs the flue gas through the zone filled 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 

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

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

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2.5.1.3 Fabric Filter 

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

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

the outside to the inside ofthe filter bags. Particulate, entrained in the gas stream, is mechanically deposited 

on the outside ofthe filter bags as the gas passes through the cloth. 

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

approximately 8" in diameter by 20' long. The baghouses are fabricated from 3/16" mild steel plate, of welded 

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

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

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

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

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

pressure across the filter reaches a predetermined setpoint of approximately 7.0" w.c, or when the operator 

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

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

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

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

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

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

modules to an outlet manifold for exhaust. 

2.5.1.4 Induced Draft Fan and Stack 

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

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

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

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

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

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

stack diameter 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. 

2.6 Stack Emissions Monitoring [40 CFR §63.1207(f)(1)(iii)(H)] 

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

conditioning apparatus, and gas analyzers. Samples are extracted from the transition ducting located between 

the scrubber and stack. A CEM perfprmance test and quality assurance program has been implemented in 

accordance with the Appendix to Subpart EEE of Part 63—Quality Assurance Procedures for 

Continuous Emissions Monitors Used for Hazardous Waste Combustors. 

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

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

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

instruments including the operating range and measurement principal. 

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2.6.1 CEM System Description 

The Continuous Emissions Monitoring Systems (CEMS) currently being utilized at Incinerator 3 analyzes for 

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

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 3 Continuous Emission Monitors 

\ " = 

Parameter Current Mfg. Range Principle J 

Oxygen COSA 0-25% Electrochemical j 

Carbon Monoxide Ecochem MC3 0-200 ppmv 

0-3000 ppmv 

Infrared j 

Total hydrocarbons Thermoelectron 0-100 ppmv FID/Infrared j 

Hydrogen chloride Ecochem MC3 0-1,000 ppmv Infrared j 

Opacity Teledyne 0-100% White light 

I Stack gas flow PSE/Rosemount 0-20,000 acfm Pressure drop J 

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: 

• A human-machine interface (HMI) system, 

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

2-7.1.1 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. 

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

performing a number of activities including: 

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

indication of a field installed pressure transmitter); 

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

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

control valve; and 

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

The process control computer will continuously control and monitor the operation of the incinerator. When 

out-of-range conditions exist, it will notify the operator of those conditions. The process control computer is 

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

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

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

Continuous monitoring ofthe incinerator and scrubber system is an important aspect ofthe 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. This system 

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

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

permit limit levels. Monitoring methods and calibration frequencies are listed in Table 2-3. 

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

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

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

controls. 

2.8 Automatic Waste Feed Cut-off System [40 CFR §63.1207(f)(1)(iii)(F)] 

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

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

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

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

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

below. 

• Reoulatorv/permit limits - established to comply with existing permits. An example of this type of limit 

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

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

of each process instrument that is part ofthe 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 safety limits - established to assure process equipment is protected and unsafe operating 

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

can lead to fuel rich conditions. 

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

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

necessary for certain types process instruments to function properly. Wastes will not be re-introduced 

into the incinerators until proper operation of key instruments is re-established. 

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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 

Veolia tests the AWFCO systems bi-weekly, as weekly testing would unduly interfere with operations by 

ceasing and restarting waste feeds, potentially increasing emissions, incurring excessive downtime, burning 

additional natural gas during the downtime, and increasing operating costs. Testing ofthe AWFCO system is 

a time-consuming and manpower intensive process. The current testing program has been in place under the 

RCRA permit for over 20 years and has proven to be adequate in detecting problems. This rationale is 

included in the facility's AWFCO Plan. 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 incinerator's PLC system to make sure that should process 

conditions deviate from allowable limits, the computer logic will initiate waste feed shutdowns as required. 

This is accomplished by manually simulating process conditions that are outside allowable limits and observing 

and documenting when the control or block valve software logic on the waste feed line begins to initiate valve 

closure. Should actual AWFCOs occur during a given testing period, these are documented by operating 

personnel to satisfy regulatory requirements for system testing. Results of this testing are documented on a 

separate AWFCO Testing Log and maintained as part ofthe unit's Operating Record. 

2.9 Air Pollution Control Equipment Maintenance Practices [40 CFR 

§63.1207(f)(1)(iii)(G)] 

2.9.1 Program Overview 

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

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

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

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

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

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

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

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

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

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

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

2.9.2 Test Program Preparation Activities 

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

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

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

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Table 2-2 Technical Information Summary on Incinerator No. 3 

Manufacturer Trade Waste Incineration 

Model No. TWI-2000, Series 2 

Type Fixed Hearth, Dual Chamber 

Date of Manufacture 1988 

Dimensions Primary Chamber Secondary Chamber 

External Length 17.5' 17.5' 

External Diameter 9' 9' 

Internal Diameter 7'2" 7'2" 

Cross-sectional area 40.3 square feet 40.3 square feet 

Burners Primary Chamber Burner Secondary Chamber Burner 

Manufacturer North American North American 

Size 12.0 Million Btu/hr 6.0 Million Btu/hr 

Fuel Natural Gas Natural Gas 

Primer Mover Induced Draft Fan 15,000 acfm @ 400°F saturated, 22 in. water column 

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

] System Device Units Cutoff Limits 

Calibration 

Frequency 

Total Pumpable Waste 

Feed rate 

Mass Flowmeters/Scales Lb/hr >3,123 (HRA) Annually 

{Total Waste Feedrate Mass Flowmeters/Scales Lb/hr >4,301 Annually/quarterly i 

[High BTU Liquid feedrate Mass flow meter lb/hr >2,012 Annually 

[Low BTU Liquid feedrate Mass flow meter Ib/hr > 1,993 Annually 

Specialty feeder Scale Ib/hr £724 Quarterly 

Total LVM Feedrate Mass Flowmeters/Scales •Ib/hr > 1,264 (12 HRA) Annually/quarterly 

Pumpable LVM Feedrate Mass Flowmeters/Scales Ib/hr > 1,264 (12 HRA) Annually/quarterly 

JSVM Feedrate Mass Flowmeters/Scales Ib/hr >3,477 (12 HRA) Annually/quarterly 

JMercury Feedrate Mass Flowmeters/Scales Ib/hr > 0.0073 (12HRA) Annually/quarterly j 

Chlorine Feedrate Mass Flowmeters/Scales Ib/hr >237 (12 HRA) Annually/quarterly 

Ash Feedrate Mass Flowmeters/Scales Ib/hr >673 (12 HRA) Annually/quarterly 

Primary Combustion 

Chamber Temperature 

Type K Thermocouple °F <1,590 (one-minute average) 

<1,712 (HRA1) 

>2,400 (instantaneous) 

Annually 

Secondary Combustion 

Chamber Temperature 

Type K Thermocouple °F 51,794 (one-minute average) 

<1,845 (HRA1) 

>2,400 (instantaneous) 

Annually 

Primary Combustion 

Chamber pressure 

Pressure transmitter in. w.c. >-0.1 (5 second delay) Quarterly 

Secondary Combustion 

Chamber pressure 

Pressure transmitter in. w.c. £ -0.1 (5 second delay) Quarterly 

Chlorine Feed to Slurry 

Flow Ratio 

Flowmeter ratio >33.5 Annually 

Spray Dryer Adsorber 

[Outlet Temperature 

Type K Thermocouple °F 2500 (one minute average) 

>420 (HRA) 

Annually I 

Combustion Gas Flow 

[Rate 

PitotTube acfm >17,198 

>15,534 (HRA) 

Annually 

Stack Gas Excess Oxygen Zirconium Oxide fuel cell % < 3 (one-minute avg.) Quarterly j 

Stack carbon monoxide Infrared ppmv >100 (HRA) 

>500 (one minute average) 

Quarterly j 

Stack Hydrocarbon FID ppmv >10 (one minute average) Quarterly 

Stack gas opacity White Light % s10 (one minute average) Quarterly 

Stack hydrogen chloride2 Infrared ppmv >100 (HRA) 

>500 (one minute average) 

Quarterly 

Fabric filter pressure drop Delta P transmitter in. w.c. < 2 or > 10 (1 min. average) Quarterly 

1

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

2

 This is a RCRA permit limit only. J 

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Figure 2-1 Hydrated Lime Specifications 

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saRsrssipi^i ROTAR Y PI^AV T 

ccd* KRS'OQ 

' Usets AfrlVi atad w.at<er roeiaieiilB Codex £j-tsvi..r..l.c:*0.<;sn.-

C2tie;r-10.a1. Analysis 

C a t'OH>2 . . SCO * 9T,2 » 

CaO Htaijlvax«ct ....... . .72.a <.c 73.© 

CuO TotaJ • . . . 73,6 74.3 

cacoa ........... . o. as to 

CaSO 4 . . . . . . , .. . ." O.OS. t-n O.IO 

3 T?<fUlv«X<;!lt; . . . . ' O.OX 2 v o o . 

3J.O_ O.S S Ira O.O S . 

w

2 

AX^O 3 ; - 0.3 0 

F&2°3 O.C7 b o O,3.0 

M««? - . - O, <0 n> O .55 

P^O s . .. . fc . O.OOS LO 0 , O I S 

ila O . . . . ^ O.Ooi S t:o 0 .003 S 

MlPUi i 3H 5 tiejs.fi 9Z. O 

Dojt^ l tjf — iTOUnci3 js^as- It. 3 - ZtO C o 3 2 

<.D&p&n.£i.iigf upo n degre e « f 

c jr-5>ft c t i Ot; > 

c 

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2.0 Engineering Description 

2.1 Process Overview 

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

(Unit 4) at the Sauget, IL facility. The two fixed hearth units are rated at 16 million Btu/hr 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. Unit 4 is rated at 50 million 

Btu/hr and is equipped with its own tank farm system, drum storage, bulk solids storage and feed systems. 

2.2 Waste Feed Systems [40 CFR § 63.1207(f)(1)(ii)(c) and (f)(1)(iii)(D) and (E)] 

2.2.1 Unit 4 Liquid Waste Feed System and Blending Operations 

The Unit 4 Rotary Kiln can incinerate any of the waste that Veolia is authorized and permitted to receive. All 

physical forms of wastes will be handled and fed by the system's waste feed devices. Liquids will be fed to 

either the kiln or the Secondary Combustion Chamber (SCC). Bulk solid wastes will be fed to the kiln through 

either the ram feeder. Containerized wastes will be fed to the kiln through the ram feeder or the auxiliary ram 

feeder. This unit can receive any combination of wastes - liquid, semi-solid, or solid - with a heat value of up 

to 50 million Btu/hr. 

Unit 4 is supported by storage tanks located in Tank Farm #3. These tanks are used to store the liquid organic 

waste, aqueous wastes, and pumpable sludges to be fed to the system. Unlike Tank Farm #1, all of the tanks 

in Tank Farm #3 can be used as feed tanks to the incinerator. Several criteria are important in designing a 

blend from received wastes. These include compatibility, proper range of heating value, and permit 

restrictions regarding elemental composition (based on emission limitations). Pumps to transfer these wastes 

to the system are installed in the tank farm. The material is transferred through aboveground pipelines from 

the tank farm to the incinerator. Pipelines used to transfer liquid organic waste and aqueous waste are 

equipped with strainers. 

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

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

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

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

are installed between the carbon adsorbers and the tanks. 

2.2.1.1 Organic and Aqueous Liquid Waste Feeds 

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

injection of pumpable sludges, aqueous wastes and organic liquid wastes to the kiln and for injection of 

organic liquid waste to the SCC. Dual fluid injection nozzles will be used for atomization of the waste. Each of 

the injectors is rated at 0-300 gph. The liquid waste feed nozzles are served by parallel redundant pumps and 

recirculation systems with back pressure control. 

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2.2.1.2 Packaged and Bulk Solid 

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

Plan. These wastes can then be delivered directly to Unit 4 or repacked into small combustible containers at 

the facility. Repackaged containers are delivered to, and staged, in the Container Storage Unit No. 6 adjacent 

to the Unit 4 incinerator. When scheduled for feeding to the system, the containers of waste are transferred by 

forklifts to the feed conveyors serving Unit 4. 

Bulk solids and non-pumpable wastes are delivered and discharged into waste feed bins in the Bulk Solids 

Storage Building after being received, sampled, and analyzed. A clamshell operating from an overhead crane 

is used to transfer these wastes from the bins to the feed hoppers discharging to the system's ram feeder. 

The weigh hopper is equipped with weigh cells so each charge of waste can be weighed before it is 

discharged into the ram feeder. Fugitive emissions are controlled by a baghouse, cyclone, and carbon 

adsorption system connected to this system. 

The ram feeder is a 25-inch wide by 42 inch high (inside dimensions) rectangular tube operated by a 

hydraulically driven ram. The ram tube is equipped with a vertical, hydraulically operated charge door near the 

kiln end. This door is opened before the ram begins advancing to push a charge into the kiln. After the ram 

has fully retracted, a limit switch triggers the door to close so as to protect the ram feeder from the kiln's 

radiant heat. The ram is capable of operating from 0-30 cycles/hour. 

The top face of the ram feeder has a 2' x 2' opening which receives waste charges from the hopper. The ram 

feeder isolation gate, the charge door, and the ram operate in sequence. At the beginning of a cycle, the ram 

is fully retracted. On a "start" command from the operator or the programmable controller, the ram feeder 

isolation gate opens to receive a charge of waste from the hopper. The gate then closes, the charge door 

opens, and the ram begins its advance. Once the ram reaches its full extension, it begins to retract. When the 

ram is fully retracted, the charge door is closed and the cycle can be repeated. This system's sequenced 

operation combined with the negative pressure in the kiln prevent fugitive emissions from escaping the kiln 

ram feeder system. 

The ram feeder also receives containers of wastes delivered by an auxiliary feed system. The auxiliary feed 

conveyor is capable of handling charge weights of 1 to 100 pounds. The system is capable of handling charge 

sizes up to 24 inches in diameter and 24 inches tall. The auxiliary feed conveyor is capable of making 60 

charges an hour or one complete cycle every minute. 

2.2.1.3 Specialty Liquid Feeds 

The Specialty Feed System associated with Incinerator No. 4 is a Direct Inject Liquid Feed System. 

2.3 Manufacturer, Make and Model ofthe Incinerator [40 CFR § 63.1207(f)(1)(iii)(A)] 

2.3.1 Combustion Chamber and Burners [40 CFR §63.1207(f)(1)(iii)(B) and (C) 

Incinerator No. 4 features a two-stage combustion process. Ignition of waste material takes place in the kiln, 

or primary combustion chamber (PCC). A secondary combustion chamber (SCC) serves as an "after-burner" 

for process gases and is also permitted to incinerate high Btu liquid waste. Ignition of the waste takes place at 

temperatures in excess of 1600 degrees F. The secondary combustion chamber maintains a minimum 

temperature of approximately 1875 degrees F. 

The rotary kiln is fabricated of carbon steel. It has approximate dimensions of 8'8" O.D. X 35' long. It is 

supported on a one-degree slope by two steel tires or riding rings. Each riding ring rides on two pairs of steel 

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trunnions and have an approximate outside diameter of 9 feet 5 inches. The thickness and face width ofthe 

trunnions are approximately 6 inches and 9 inches, respectively. Table 2-2 provides a summary ofthe 

incinerator design specifications. 

The kiln is lined with approximately 7 Vz inches of dense abrasion-resistant high-alumina firebrick refractory. 

With this refractory system, the kiln has an inside diameter of approximately 7 feet and a length of 

approximately 35 feet, an integral cross-section area of approximately 38 square feet and an internal volume 

of approximately 1,346 cubic feet. 

All kiln feeds will enter through the upper kiln face plate which is located on the feed end of the kiln. The plate 

contains a primary burner, three liquid feed nozzles (for pumpable sludge, aqueous waste, and high Btu liquid 

waste), a ram feeder and a surge vent. 

The primary burner is equivalent to a North American 'Fuel Directed' burner of 25 MMBtu/hr. and burns No. 2 

fuel oil or natural gas. The burner system is supplied with approximately 4,000 acfm combustion air at a static 

pressure of 20" water column (WC). The pilot for the primary burner will bum natural gas. 

The fuel system for the kiln (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 (SCC) 

The SCC is a vertical, cylindrical chamber having approximate dimensions of 10'-6" O.D. x 71' high. It is 

fabricated of carbon steel and lined with an inner course (hot face) of approximately six inches of high alumina 

refractory and an outer course of approximately two inches of insulating refractory. With this installed 

refractory, the SCC has an inside diameter of approximately nine feet. The effective length (gas retention 

length) ofthe chamber is approximately 48' - 6". Consequently, the SCC has a cross-section area of 64 

square feet and an effective volume of approximately 3,084 cubic feet. At maximum combustion gas flows, 

the combustion gas residence time is greater than two seconds. 

Combustion gases from the kiln enter the bottom of the SCC through a refractory-lined side duct and exit from 

the top of the SCC through a refractory-lined duct to the tempering chamber. The floor of the chamber is 

sloped to facilitate the removal of ash and solids through a slag tap. 

The SCC is equipped with one burner mounted on the sidewall of the chamber near the bottom. The burner is 

a Trane Thermal Model, or equivalent, with a design heat release of approximately 30 million Btu/hr. This 

burner is supplied with No. 2 fuel oil or natural gas and combustion air. 

As with the kiln 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, pilot burner or ID fan. 

The SCC burner is a high-intensity, vortex type unit with a spin vane assembly, located within the windbox to 

impart an intense rotary motion to the combustion air. This rotary motion and the burner design provide 

complete mixing of air and fuel, and recirculation ofthe gases within the combustion chamber promotes rapid 

combustion and high heat intensity. 

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2.3.3 Location of Combustion Zone Temperature Device [40 CFR §63.1207(f)(1)(xix)] 

The pyrometer that monitors temperature in the rotary kiln is located top-center in the transition section 

between the rotary kiln and the SCC about two feet downstream from the exit of the kiln. The thermocouple 

that monitors temperature in the SCC is located on the west side ofthe chamber near the SCC exit duct. 

2.3.4 Hazardous Waste Residence Time [40 CFR §63.1207(f)(1 ){ix)] 

The hazardous waste gas residence time for the Unit 4 Rotary Kiln Incinerator is calculated as follows: 

• Rotary Kiln Volume -1346 ft3 

• Secondary Combustion Chamber Volume - 3084 ft3 

• Total Volume - 4430 ft3 

• Maximum Flue Gas Flowrate - 43,000 acfm (717 ft3/sec) 

• Total Combustion Zone Residence Time = (4430 ft3)/(717 ff/sec) = 6.2 sec 

2.3.5 Combustion System Leak 

The kiln itself is equipped with a double seal system that is comprised of overlapping, adjustable, stainless 

steel spring plates on both the feed and discharge ends of the kiln. The sealing edges of each plate are fitted 

with a sintered-metal wear shoe similar to a brake shoe with the inner seal resting on the kiln shell. The 

powdered metal formulation for the seal shoes include graphite granules, which make the shoes selflubricating. The void between the seals and the outer shell ofthe kiln is pressurized to further prevent fugitive 

emissions. In addition to the kiln seal system, Unit 4 also utilizes an induced draft fan that maintains a vacuum 

of- 0.5 to -1.0 inches water column while waste is being fired into the system. 

2.3.6 Emergency Safety Vent 

Unit 4 is equipped with two emergency vents, one located at the kiln inlet which acts as an emergency 

pressure relief, the second is located at the top ofthe SCC as a thermal relief vent. 

The emergency vent at the kiln inlet would only be required for an occurrence that overwhelms the ability of 

the ID fan to control the pressure of the kiln. The vent and chute opening is designed such that waste from the 

bulk solids chute would not impede the escaping gas flow. A deflector separates the feed flow from the vent 

opening. The entrainment of solids through the surge vent is minimal. As an extra precaution, the exhaust 

opening ofthe vent is angled to provide a horizontal exit, thereby minimizing solids entrainment into the air. 

The vent is kept closed by weighted louvers. These louvers will open only if the pressure in the kiln suddenly 

rises beyond the compensating capacity of the ID fan. A limit switch on the louvers will automatically shutoff all 

waste feeds to the kiln and SCC when the vent is opened. 

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

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

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

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

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

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

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

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

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2.4 Procedures for Rapidly Stopping Hazardous Waste Feed During Equipment 

Malfunction [40 CFR §63.1207(f)(1)(viii)] 

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

regular field inspections. 

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

will be notified. The control room operator will then close the waste feed valves and disable the waste feed 

pumps. 

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

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

2.5 Air Pollution Control Equipment [40 CFR §63.1207(f)(1)(ili)(G)] 

2.5.1 Air Pollution Control Systems Descriptions 

The air pollution control system consists of a tempering chamber, two spray dryer absorbers, and fabric filter 

baghouse modules. The air pollution control system neutralizes acidic compounds and removes particulate 

from the exhaust gas. Two subsystems, the spray dryer absorber and the fabric filter, carry out the chemical 

neutralization and particulate removal functions, respectively. A third subsystem, the lime system, is used to 

prepare and provide lime slurry to the spray dryer absorber for use in the chemical neutralization process. The 

induced draft fan and stack provide the mechanical energy required to transport the flue gas through the 

interconnecting ductwork, to its eventual discharge point to atmosphere. 

2.5.1.1 Tempering Chamber 

The tempering chamber is a vertical, cylindrical unit designed to cool the combustion gases using a series of 

internal dual-fluid (water and air) spray nozzles. The combustion gases enter the top ofthe chamber, flow 

downward through the spray pattern and exit from the bottom ofthe chamber. The spray pattern is designed 

to eliminate direct contact of water with refractory, and the chamber is designed to maintain a dry bottom under 

all operating conditions. That is, the injection rate of spray water is controlled so that it is completely vaporized 

and earned out of the chamber in the combustion gases. The tempering chamber is approximately 49' high 

with 11' I.D. and is fabricated of % inch nominal plate thickness carbon steel (ASTM A36) and lined with 

refractory. The spray nozzles and extensions are fabricated of 304 SS material. 

The tempering chamber is sized so that a combustion gas retention time of greater than one second will be 

maintained at all gas flows. Because some molten particulate materials in the combustion gases are cooled in 

this process unit to below their fusion point, some solids are generated and collected in the chamber. 

Therefore, the chamber has a cone bottom and a .slide gate to facilitate the removal of solids. These solids are 

discharged onto a conveyor system, which transports them to a hopper. 

2.5.1.2 Lime System 

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

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

designed for batch mixing to provide this service. Veolia utilizes hydrated lime as its neutralizing agent inf the 

air pollution control systems. The key neutralization parameter ofthe hydrated lime is the "CaO Equivalent'. 

Figure 4-1 is the specification sheet for the hydrated lime that Veolia uses. Veolia has used this specific 

product for over 20 years and plans to continue with its use! Although, if Veolia does change suppliers or type 

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of lime in the future, it would have a "CaO Equivalent" specification equal to or greater than the 72.6% shown 

on Figure 4-1. 

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

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

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

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

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

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

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

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

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

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

SDA nozzles at a rate of up to 10 gpm to each nozzle. 

2.5.1.3 Spray Dry Absorber 

Unit 4 is equipped with two Spray Dryer Absorbers (SDA) located immediately downstream of the Tempering 

Chamber. Each SDA unit is fabricated of 3/8 inch carbon steel. The function of the SDAs is to: 

• Further cool the combustion gases from 600-800°F to 300-500°F, 

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

concentration to the spray dryer absorber. Manual adjustment to the flow is made as a function of the SDA 

outlet temperature and as a function of the output from a hydrochloric acid (HCI) analyzer in the gas duct 

downstream of the fabric filter. Since the Tempering Chamber accomplishes initial cooling of the gases, no 

additional water is used in the SDAs for gas temperature control. 

The combined units are sized to remove more than 820 Ib/hr. of chlorine from the combustion gases. Each 

SDA is approximately 72' high by 107" in diameter. Each unit includes a head section, and a 60° conical 

hopper. Each SDA chamber has one access door in the upper section. Each hopper has one access door, a 

flanged clean-out port, and a drain connection. The SDA head section consists of a flanged inlet connection 

and a hot gas inlet plenum. The dual-fluid atomizing nozzles include stainless steel housings and stellited 

inserts. The nozzles are assembled to permit field removal from the piping. The two lime slurry piping 

headers have automatic isolation valves. 

Combustion gases enter the top of each of these units, flow downward through a central duct and are 

dispersed symmetrically from'this duct into the absorber chamber at a velocity and direction that assures 

optimal contact with the cloud of atomized lime slurry droplets introduced into the chamber by dual-fluid (lime 

slurry and air) nozzles. The gases then flow downward through each 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 each unit. The dry material from each unit is discharged to a 

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

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2.5.1.4 Fabric Filter 

Gas exhausted from the spray dryer absorbers is distributed to two fabric filter modules connected in parallel. 

Each module is divided into three compartments connected in parallel, which contain multiple fabric filter bags 

through which the combustion gases pass to remove particulates. Within each compartment, the gas is 

passed through Teflon-coated fiberglass cloth bags. The gas passes from the outside to the inside ofthe filter 

bags. Particulate entrained in the gas stream is mechanically deposited on the outside ofthe filter bags as the 

gas passes through the cloth. 

Each compartment has a clean air plenum and housing section to contain approximately 308 bags. Each bag 

is approximately 5" in diameter by 5' long. The baghouses are fabricated from 3/16" mild steel plate, of welded 

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

compartment has a tube sheet that supports the bags and provides fortop bag/cage removal. Access to the 

clean air plenum is via a bolted access door. Each trailer mounted unit contains the compressed air headers, 

gas inlet and outlet manifolds, and the conveyor. 

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

sequence will be initiated. The sequence is started when the differential pressure across the filter reaches a 

predetermined setpoint of approximately 8.0" w.c. or when the operator initiates a cycle. The controller then 

sequences to each row of filter bags in each module, releasing a burst of air opposite to the direction of gas 

flow. The quickly released burst of air dislodges dust cake on the exterior of each bag as it travels from the top 

to the bottom ofthe bags. Released from the bag, the dust cake falls by gravity into the hopper at the bottom 

of the module. From there it is discharged to a conveyor system which transports it to a dump trailer, or 

equivalent type system. 

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

compartments to an outlet manifold for exhaust. 

2.5.1.5 Carbon Injection 

The carbon injection system will air inject activated carbon into the plenum immediately upstream of the 

baghouses and allow for a more efficient means of controlling Dioxin/Furan and mercury emissions. This 

system will be controlled by an existing PLC which will control the input of activated carbon to the baghouse 

inlet plenum. 2 to 20 pounds per hour of powdered activated carbon will be air injected into this plenum and 

allow for direct contact with the stack gases exiting the SDA's. 

The amount of carbon is dosed in a dust-free manner into a low pressure air stream via pneumatic eduction. 

The eductor uses a blower for the motive air. High and low air pressure switches ensure that the blower is 

operating correctly and that the carbon delivery system is clear from obstruction. The minimum high pressure 

setting is 4 psig and the maximum low pressure setting is 1 inch water column. The carbon/air stream will then 

travel through piping to the injection nozzle into the ductwork. The carbon will contact the gas stream exiting 

the SDA's and allow.for the adsorption of any dioxin/furans and mercury that might be present in this stream. 

Adsorption will continue as the stack gases proceed through the baghouses. The clean stack gas will exit the 

final stack via the induced draft fan and the captured solids will be discharged from the baghouses via the 

screw conveying system into an enclosed dump trailer for disposal at a Subtitle C. landfill. 

2.5.1.6 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 400 hp induced draft (ID) fan, rated' at 53,000 acfm at 400° F saturated, and 25" water 

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

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

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

Treated gases are exhausted from the induced draft fan to the atmosphere through a 100-ft. high stack. The 

stack diameter for Unit 4 is 48 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)(1)(iii)(H)] 

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

conditioning apparatus, and gas analyzers. Samples are extracted from the transition ducting located between 

the ID fan and the stack. A CEM performance test and quality assurance program has been implemented in 

accordance with the Appendix to Subpart EEE of Part 63—-Quality Assurance Procedures for 

Continuous Emissions Monitors Used for Hazardous Waste Combustors. 

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

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

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

instruments including the operating range and measurement principal. 

2.6.1 CEM System Description 

The Continuous Emissions Monitoring Systems (CEMS) currently being utilized at Incinerator 4 analyzes for 

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

opacity, are extractive devices mounted in the ductwork between the ID fan and 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 Veolia ES Technical Solutions - Continuous Emissions Monitors 

Parameter Current Mfg. Range Principle 

Oxygen COSA 0-25% Electrochemical 

Carbon Monoxide Echochem MC 3 0-200 ppmv 

0-3000 ppmv 

Infrared 

Total hydrocarbons Thermoelectron 0-100 ppmv FID/lnfrared 

Hydrogen chloride Echochem MC 3 0-1000 ppmv Infrared 

Opacity Teledyne 0-100% White light 

Stack gas flow PSE/Rosemount 0-55,000 acfm Pressure drop 

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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: 

• 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. 

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

performing a number of activities including: 

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

indication of a field installed pressure transmitter); 

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

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

temperature control valve; and 

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

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

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

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

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

Continuous monitoring ofthe incinerator and scrubber system is an important aspect ofthe 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. This system 

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

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

permit limit levels. Monitoring methods and calibration frequencies are listed in Table 2-3. 

The Incinerator has an independent process control computer that interfaces to the Allen-Bradley 

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 §63.1207(f)(1 )(iii)(F)] 

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

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

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

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

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

below. 

• Regulatory/permit limits - established to comply with existing permits. An example of this type of limit 

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

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

of each process instrument that is part ofthe 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 safety limits - established to assure, process equipment is protected and unsafe operating 

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

can lead to fuel rich conditions. 

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

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

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

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

this be needed. 

2.8.1 AWFCO System Testing 

Veolia tests the AWFCO systems bi-weekly, as weekly testing would unduly interfere with operations by 

ceasing and restarting waste feeds, potentially increasing emissions, incurring excessive downtime, burning 

additional natural gas during the downtime, and increasing operating costs. Testing ofthe AWFCO system is 

a time-consuming and manpower intensive process. The current testing program has been in place under the 

RCRA permit for over 20 years and has proven to be adequate in detecting problems. This rationale is 

included in the facility's AWFCO Plan. 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 incinerator's PLC system to make sure that should process 

conditions deviate from allowable limits, the computer logic will initiate waste feed shutdowns as required. 

This is accomplished by manually simulating process conditions that are outside allowable limits and observing 

and documenting when the control or block valve software logic on the waste feed line begins to initiate valve 

closure. Should actual AWFCOs occur during a given testing period, these are documented by operating 

personnel to satisfy regulatory requirements for system testing. Results of this testing are documented on a 

separate AWFCO Testing Log and maintained as part of the unit's Operating Record. 

2.9 Air Pollution Control Equipment Maintenance Practices [40 CFR 

§63.1207(f)(1){iii)(G)] 

2.9.1 Program Overview 

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

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

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

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

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

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

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

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

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

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

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

2.9.2 Test Program Preparation Activities 

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

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

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

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Veolia ES Technical Solutions Unit 4 HWC MACT Performance Test Plan Page 12 of 15 

Table 2-2 Technical Information Summary on Incinerator No. 4 

Manufacturer Trade Waste Incineration 

Model No. TWI-2000, Series 2 

Type Rotary Kiln 

Date of Manufacture 1989 

Dimensions Primary Chamber Secondary Chamber 

External Length 35' 48'6" 

External Diameter 8'8" 10'6" 

Internal Diameter T 9' 

Cross-sectional area 38 square feet 64 square feet 

Burners Primary Chamber Burner Secondary Chamber Burner 

Manufacturer North American Trane Thermal 

Size 12.0 Million Btu/hr 30 Million Btu/hr 

Fuel Natural Gas Natural Gas 

Primer Mover Induced Draft Fan 4,000 acfm @ 400DF saturated, 20 in. water column 

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Veolia ES Technical Solutions Unit 4 HWC MACT Performance Test Plan Page 13 of 15 

Table 2-3 Current AWFCO Parameters and Limits for Incinerator No. 4 

i System Device Units Cutoff Limits 

Calibration 

Frequency 

Primary Combustion Chamber Temperature Pyrometer °F 

<1,240 (one-minute average) 

<1,507 (HRA1) 

£2,400 (instantaneous) 

Annually 

Secondary Combustion Chamber 

Temperature 

Type K Thermocouple °F 

£1,825 (one-minute average) 

<1,886 (HRA1) 

£2,400 (instantaneous) 

Annually ' 

Primary Combustion Chamber pressure Pressure transmitter in. w.c. £ atmospheric (instantaneous) Quarterly j 

[Secondary Combustion Chamber pressure Pressure transmitter in. w.c. > atmospheric (instantaneous) Quarterly | 

[Spray Dryer Adsorber Inlet Temperature Type K Thermocouple °F > 1,200 (one minute average) Annually | 

Spray Dryer Adsorber Outlet Temperature Type K Thermocouple °F 

£ 500 (one minute average) 

>435 (HRA) 

Annually 

Total Pumpable Waste Feedrate Mass flow meter/scales lb/hr >4262 (HRA) Annually 

Total Waste Feedrate Mass flow meter/scales Ib/hr >14,802 (HRA) Annually/ 

Quarterly 

|LVM Feedrate Mass flow meter/scales Ib/hr >120 (12 HRA) Annually/ 

Quarterly 

SVM Feedrate Mass flow meter/scales Ib/hr >117(12HRA) Annually/ 

Quarterly | 

Mercury Feedrate Mass flow meter/scales Ib/hr >0.067(12HRA) Annually/ 

Quarterly | 

Chlorine Feedrate Mass flow meter/scales ib/hr >274(12HRA) Annually/ 

Quarterly j 

Ash Feedrate Mass flow meter/scales lb/hr >B,777(12HRA) Annually/ 

Quarterly j 

Carbon Feedrate Mass flow meter Ib/hr >6 (HRA) Quarterly j 

Carbon Injection System Maximum Low 

Pressure 

Pressure Switch in. w.c. >1 Quarterly 

Carbon Injection System Minimum High 

Pressure 

Pressure Switch psig <4 Quarterly 

Chlorine Feed to Slurry Flow Ratio Flow Meter Ratio >44.4 Annually J 

Combustion Gas Flow Rate Anubar acfm £43,900 (HRA) Annually 

Stack Gas Excess Oxygen Zirconium Oxide fuel cell % £ 3 (one minute average) Quarterly 

Stack carbon monoxide Infrared ppmv 

£100 (HRA) 

£500 (one minute average) Quarterly 

Stack Hydrocarbon FID ppmv £10 (one minute average) Quarterly j 

Stack gas opacity White Light % £10 (one minute average) Quarterly I 

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Veolia ES Technical Solutions Unit 4 HWC MACT Performance Test Plan Page 14 of 15 

j System Device Units Cutoff Limits 

Calibration 

Frequency 

Stack hydrogen chloride2 Infrared ppmv 

>100 (HRA) 

>500 (one minute average) Quarterly 

Liquid feedrate Mass flow meter lb/hr > 1,700 Annually 

Sludge feedrate Mass flowmeter Ib/hr > 1,100 Annually 

Drummed and Bulk Solids Feedrate Scale Ib/hr > 15,000 Quarterly | 

Fabric filter pressure drop Delta P transmitter in. w.c. <2 or> 10 (one minute average) Quarterly 

1

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

2

 This is a RCRA permit limit only. 

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Veolia ES Technical Solutions Unit 4 HWC MACT Performance Test Plan Page 15 of 15 

Figure 2-1 Hydrated Lime Specifications 

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32 

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VES 000859 
CONTINUOUS MONITORING SYSTEM 

QUALITY CONTROL PROGRAM 

Prepared for: 

Veolia ES Technical Solutions, LLC 

Sauget, Illinois 

Prepared by: 

Franklin Engineering Group, Inc. 

Franklin, Tennessee 

October 2008 
TABLE OF CONTENTS 

1.0 INTRODUCTION AND BACKGROUND 1 

1.1 SUMMARY OF FACILITY INFORMATION 4 

1.1.1 Fixed Hearth Incinerators 4 

1.1.2 Rotary Kiln Incinerator. 5 

1.2 CM S INSTRUMENTATION 6 

2.0 CMS CALIBRATION AND PREVENTIVE MAINTENANCE 13 

2.1 CM S CALIBRATION , 13 

2.1.1 Initial CMS Calibration 13 

2.1.2 Subsequent CMS Calibration. 13 

2.1.3 CEMS Calibration Audits and Calibration ,14 

2.2 CM S CALIBRATION AUDITS 14 

2.3 PREVENTIVE MAINTENANCE 19 

3.0 CMS RECORDKEEPING AND REPORTING 20 

3.1 RECORDKEEPING 20 

3.2 REPORTING - 21 

4.0 CMS CORRECTIVE ACTIONS 24 

(. 

VES 000861 
INDEX OF TABLES 

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

TABLE 1 -2 CM S INSTRUMENT SPECIFICATIONS 7 

TABLE 2-1 CM S CALIBRATION AUDIT REQUIREMENTS 15 

TABLE 3-1 REPORTING REQUIREMENTS 23 

iii 

VES 000862 
1.0 INTRODUCTION AND BACKGROUND 

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

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

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

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

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

which reflect emissions performance of Maximum Achievable Control Technologies 

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

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

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

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

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

performance evaluation test plan was submitted as part of the Comprehensive 

Performance Test Plan. 

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

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

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

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

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

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

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

operating plans. 

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

information related to the procedures for each ofthe following operations: 

• Initial and subsequent calibration of the CMS 

• Determination and adjustment of the calibration drift ofthe CMS 

• Preventive maintenance ofthe CMS, including spare parts inventory 

• Data recording, calculations, and reporting 

• Program of corrective action for malfunctioning CMS. 

1 
Table 1-1 

Regulatory Checklist for the CMS QA Program 

Regulatory 

Citation 

Description Plan Section 

§ 63.8(c)(1)® Operation and maintenance of each CMS 

Section 1.2,2.3 

O&M Plan 

CEMS Plan 

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

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

§ 63.8(c)(7)(ii) 

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

and calculations. 

Section 4.0 

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

Section 4.0 and 

SSMP Plan 

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

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

program 

Section 1.0 

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

the performance evaluation test plan 

Section 2.1.1 

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

calibrations 

Sections 2.1.1, 

2.1.2 

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

adjustment of calibration drifts 

Section 2.2 

§ 63.8(d)(2)(iii) Develop written procedures for preventive maintenance 

and spare parts inventory 

Section 2.3 

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

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

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

§ 63.8(g) Reduction of monitoring data Section 3.2 

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

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

evaluations 

Section 3.1 

§ 63.10(b)(2)(vi) 

Maintain records of each period during which a CMS is 

malflmctioning, or inoperative and out of control 

Section 4.0 and 

SSMP Plan 

§ 63.10(b)(2)(vii) Maintain records of measurements to demonstrate 

compliance 

Section 3.1 

§ 63.10(b)(2)(viii) 

Maintain records of results of CMS performance 

evaluations and opacity and visible emission 

observations 

Section 3.1 

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

2 

VES 000864 
Table 1-1 (continued) 

Regulatory Checklist for the CMS QA Program 

Regulatory 

Citation 

Description Plan Section 

§ 63.10(b)(2)(xi) Maintain records of all adjustments and maintenance 

performed on the CMS Section 3.1 

§ 63.10(c)(1) 

Recordkeeping requirements for CMS measurements 

(including unavoidable breakdowns and out-of-control 

situations) 

Section 3.1 

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

the reporting period Section 3.1 

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

§ 63.10(c)(5) Maintain records of date and time for CMS 

inoperability (except for zero and high-level checks) Section 3.1 

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

Section 3.1 

§ 63.10(c)(8) 

Maintain records of identification of each time period 

of exceedances - does not include periods of Startup, 

Shutdown, Malfunction (SSM) 

Section 3.1 

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

performance report Section 3.1 

§ 63.10(e)(3)(v) 

Content and submittal data of excess emissions and 

CMS performance report 

Section 3.2 

§63.10(e)(3)(vi) 

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

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

Section 3.2 

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

§63.10(e)(3)(viii) 

Condition for submitting both the summary report and 

excess emissions and CMS performance report 

Section 3.2 

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

§ 63.1209(b)(3) 

Frequency of CMS sampling, evaluation, computing, 

and recording of regulated parameter 

Section 3.1 

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

§ 63.1209(f)(1) 

§ 63.1211(c) requires that CMS are installed, 

calibrated, and operational by the compliance date 

CMS PET Plan | 

Notes: 

PET Perfonnance Evaluation Test 

SSMP Startup, Shutdown, Malfunction Plan 

SDP Standard Division Practices 

VES 000865 
The data collected from CMS mstrumentation is used to demonstrate the unit's 

comphance with the perfonnance requirements promulgated in the Interim HWC 

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

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

data on an ongoing basis. 

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

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

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

clearly identified. 

This document is organized as follows: 

Section 1.0 Introduction and Background 

Section 2.0 CMS Calibration and Preventive Maintenance 

Section 3.0 CMS Recordkeeping and Reporting 

Section 4.0 CMS Corrective Actions 

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

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

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

Administrator. 

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

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

continuing calibration and preventive maintenance requirements. Section 3.0 addresses 

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

discusses nonstandard operations of the CMS and apphcable corrective actions. 

1.1 Summary of Facility Information 

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

incinerator are presented in this section. 

1.1.1 Fixed Hearth Incinerators 

Each ofthe fixed hearth incinerators includes the following components: 

• Feed equipment 

A 

VES 000866 
• Primary and secondary combustion chambers 

• Lime injection system 

• Spray dryer absorber (SDA) 

• Fabric filter baghouse 

• Solids and ash removal systems 

• Induced draft (ID) fan and stack 

• Instrumentation, controls, and data acquisition systems 

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

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

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

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

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

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

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

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

combustion chamber. Combustion chamber temperatures are maintained using natural 

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

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

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

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

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

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

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

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

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

integrated zirconium oxide-based analyzer detects oxygen concentrations. 

1.1.2 Rotary Kiln Incinerator 

The rotary Mln.incinerator includes the following components: 

• Waste feed system 

• Primary and secondary combustion chambers 

• Tempering chamber 

• Lime injection system 

• Spray dryer absorber 
• Carbon injection system 

• Fabric filter baghouse 

• Solids and ash removal systems 

• ID fan and stack 

• Instrumentation, controls, and data acquisition systems 

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

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

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

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

atomized liquid injectors. Combustion chamber temperatures are maintained using 

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

Combustion gas exits the secondary combustion chamber and enters the tempering 

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

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

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

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

the combustion gas immediately downstream of the convergence of combustion gases 

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

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

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

the main stack. 

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

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

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

integrated zirconium oxide-based analyzer detects oxygen concentrations. 

1.2 CMS Instrumentation 

This section describes the CMS mstruments used monitor regulated process parameters 

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

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

1-2. 

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

provide representative measurements of emissions or process parameters. All CMS 

6 

VES 000868 
Table 1-2 

CMS Instrument Specifications 

Application Instrument Tag Number Manufacturer Model Operating Range Location 

Unit No. 2 

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

High BTU Liquid Direct Injection 

Feedrate 

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

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

Low BTU Liquid Direct Injection 

Feedrate 

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

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

Feeder 

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

Conveyor 

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

(0-60 lb/min) 

Cylinder Gas 

Feed System 

PCC Temperature 

TypeK 

Thermocouple 

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

Chamber 

SCC Temperature 

TypeK 

Thermocouple 

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

Chamber 

PCC Pressure 

Pressure 

Transmitter 

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

Primary 

Chamber 

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

Emergency 

Stack 

Baghouse Met Temperature 

TypeK 

Thermocouple 

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

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

Stack Gas Oxygen Concentration 

Zirconium Oxide 

Analyzer 

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

Building 

Stack Gas Carbon Monoxide 

Concentration Multicomponent 

Infrared 

Photometer 

0-200 / 0-3000 ppmv 

CEMS 

Stack Building Hydrogen Chloride 

Concentration 

Multicomponent 

Infrared 

Photometer 

AT-288E EcoChem MC3 0-1000 ppmv 

CEMS 

Building 

Stack Gas Moisture Concentration 0-60% 

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

Lime Slurry Density 

Density 

Transducer 

AT-968 Solartron Mobrey 7846 0-100 Lb/Ft3 SDA Penthouse 
Table l-2(continued) 

CMS Instrument Specifications 

Application Instrument Tag Number Manufacturer Model Operating Range Location 

Unit No. 3 

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

High BTU Liquid Direct Injection 

Feedrate 

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

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

Low BTU Liquid Direct Injection 

Feedrate 

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

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

Feeder 

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

Conveyor 

PCC Temperature 

TypeK 

Thermocouple 

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

Chamber 

SCC Temperature 

TypeK 

Thermocouple 

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

Chamber 

PCC Pressure 

Pressure 

Transmitter 

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

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

Emergency 

Stack 

Baghouse Inlet Temperature 

TypeK 

Thermocouple 

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

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

Stack Gas Oxygen Concentration 

Znconium Oxide 

Analyzer 

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

Building 

Stack Gas Carbon Monoxide 

Concentration Multicomponent 

0-200/0-3000 

ppmv 

CEMS 

Building Stack Hydrogen Chloride 

Concentration 

Infrared 

Photometer 

AT-388E EcoChem MC3 

0-1000 ppmv 

CEMS 

Building 

Stack Gas Moisture Concentration 0-60% 

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

Lime Slurry Density 

Density 

Transducer 

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

8 

VES 000870 
Table ! (continued) 

CMS Instrument Specifications 

Application Instrument Tag Number Manufacturer Model Operating Range Location 

Unit No. 4 

Waste Feedrate to X-10 Nozzle Mass Flowmeter FT-129 Micro Motion DS10.0S 128 0-7,000 lb/hr Feed Line 

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

Waste Feedrate to X-12 Nozzle Mass Flowmeter FT-145 Micro Motion DL100S-SS 0-8,000 Ib/hr Feed Line 

Waste Feedrate to X-22 Nozzle Mass Flowmeter FT-212 Micro Motion D1D0OS-SS 0-7,000 lb/hr Feed Line 

Clam Shell Feed Weight 

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

Hopper 

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

Conveyor 

Auxiliary Conveyor Solids 

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

Conveyor 

PCC Temperature Pyrometer TT-305A/B Ircon 

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

SCC Temperature 

TypeR 

Thermocouple 

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

PCC Pressure 

Pressure 

Transmitter 

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

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

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

Emergency 

Stack 

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

System 

Carbon Injection Carrier Gas 

Supply Pressure 

Pressure Switch PSL-438A Dwyer 3330 Trip Points: 

± 5 jn. w.c. 

Carbon 

Injection Line 

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

Trip Points: 

< 3 psig 

> 13 psig 

Carbon 

Injection Line 

VES 000871 
Table 1 (continued) 

CMS Instrument Specifications 

Application Instrument Tag Number Manufacturer Model Operating Range Location 

Unit No. 4 (continued) 

SDA X-18 Outlet Temperature 

(Baghouse Inlet Temperature) 

TypeK 

Thermocouple 

TT-417A/B Modicon B883-200 0-2,500 °F SDA X-18 

Outlet 

SDA X-19 Outlet Temperature 

(Baghouse Inlet Temperature) 

TypeK 

Thermocouple 

TT-418A/B Modicon B883-200 0-2,500 °F SDA X-19 

Outlet 

Combustion Gas Flowrate PitotTube/dPCell FT-559A/B Automation Service 1151DRF2283 0-55,000 acfm Stack 

Stack Gas Oxygen Concentration 

Zirconium Oxide 

Analyzer 

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

Building 

Stack Gas Carbon Monoxide 

Concentration 

Multicomponent 

Infrared 

Photometer 

AT-556E EcoChem MC3 

0-200 / 0-3000 ppmv 

CEMS 

Building 

Stack Hydrogen Chloride 

Concentration 

Multicomponent 

Infrared 

Photometer 

AT-556E EcoChem MC3 0-1000 ppmv 

CEMS 

Building 

Stack Gas Moisture Concentration 

Multicomponent 

Infrared 

Photometer 

AT-556E EcoChem MC3 

0-60% 

CEMS 

Building 

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

Lime Slurry Density 

Density 

Transducer 

DLT-609 SolartronMobrey 7846 0 -100 Lb/Ft3 Lime Silo 

10 

VES 000872 
operating parameter measurement devices at the Veolia facility are installed in compliance with 

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

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

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

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

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

waste, and constituent feedrates. 

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

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

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

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

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

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

feeds. 

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

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

metals, and semivolatile metals feedrates to the incinerator. 

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

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

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

the stack gas flowrate. 

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

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

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

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

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

thermocouples used for temperature control and monitoring ofthe baghouse inlet temperature. 

11 

VES 000873 
Emergency Safety Vent Position Monitors: The position ofthe emergency safety vent (ESV) 

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

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

systems. 

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

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

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

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

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

detection system. 

Continuous Emissions Monitoring System: The CEMS continuously samples and analyzes 

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

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

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

CO concentration on a dry basis, corrected to 7% O2. The CEMS QA Plan provides additional 

details on the CEMS. 

12 

VES 000874 
2.0 CMS CALIBRATION AND PREVENTIVE MAINTENANCE 

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

requirements of § 63.8(d). 

2.1 CMS Calibration 

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

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

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

2.1.1 Initial CMS Calibration 

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

to the Interim HWC MACT comphance date. Cahbration prior to the compliance date is 

required so that all collected data are reliable and accurate. All initial cahbration data are part of 

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

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

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

2.1.2 Subsequent CMS Calibration 

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

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

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

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

records ofthe cahbration drift determined before and after the instrument was serviced. 

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

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

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

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

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

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

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

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

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

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

instruments are incorporated in this QC Program by reference. 

13 

VES 000875 
2.1.3 CEMS Calibration Audits and Calibration 

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

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

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

2.2 CMS Calibration Audits 

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

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

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

CMS instrument will be subjected a cahbration audit at the frequency indicated in Table 2-1. 

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

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

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

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

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

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

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

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

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

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

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

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

properly. 

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

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

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

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

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

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

collected from the monitoring system. 

14 

VES 000876 
CMS Calibration Audit Requirements 

Application Instrument Tag Number 

Frequency of 

Calibration Audit 

Low Level Check 

Point 

High Level Check 

Point Tolerance 

Unit No. 2 

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

High BTU Liquid Direct Injection 

Feedrate 

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

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

Low BTU Liquid Direct Injection 

Feedrate 

Scale WT-215DI Quarterly 01b 25,0001b 10% 

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

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

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

Primary Combustion Chamber 

Temperature 

TypeK 

Thermocouple 

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

Secondary Combustion Chamber 

Temperature 

TypeK 

Thermocouple 

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

Primary Combustion Chamber 

Pressure 

Pressure 

Transmitter 

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

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

Baghouse Inlet Temperature 

TypeK 

Thermocouple 

TT-270 See Calibration Record Form 

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

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

Lime Slurry Density 

Density 

Transducer 

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

Stack Gas Oxygen Concentration 

Zirconium Oxide 

Analyzer 

AT-289 Per CEMS QA Plan 

Stack Gas Carbon Monoxide 

Concentration 

Stack Hydrogen Chloride 

Concentration 

Stack Gas Moisture Concentration 

Multicomponent 

Infrared 

Photometer 

AT-288E Per CEMS QA Plan 

15 

VES 000877 
Table 2-\ ,ontinued) 

CMS Cabbration Audit Requirements 

Application Instrument Tag Number 

Frequency of 

Calibration Audit 

Low Level Check 

Point 

High Level Check 

Point Tolerance 

Unit No. 3 

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

High BTU Liquid Direct Injection 

Feedrate 

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

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

Low BTU Liquid Direct Injection 

Feedrate 

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

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

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

Primary Combustion Chamber 

Temperature 

TypeK 

Thermocouple 

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

Secondary Combustion Chamber 

Temperature 

TypeK 

Thermocouple 

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

Primary Combustion Chamber 

Pressure 

Pressure 

Transmitter 

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

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

Baghouse Inlet Temperature 

TypeK 

Thermocouple 

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

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

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

Lime Slurry Density 

Density 

Transducer 

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

Stack Gas Oxygen Concentration 

Zirconium Oxide 

Analyzer 

AT-389 Per CEMS QA Plan 

Stack Gas Carbon Monoxide 

Concentration Multicomponent 

Infrared 

Photometer 

Stack Hydrogen Chloride AT-388E Per CEMS QA Plan 

Concentration 

Multicomponent 

Infrared 

Photometer 

AT-388E Per CEMS QA Plan 

Stack Gas Moisture Concentration 

Multicomponent 

Infrared 

Photometer 

AT-388E Per CEMS QA Plan 

16 | 

VES 000878 
Table 2' bntinued) 

CMS Calibration Audit Requirements 

Application Instrument Tag Number 

Frequency of Drift 

Check/Accuracy 

Audit 

Low Level Check 

Point 

High Level Check 

Point Tolerance 

Unit No. 4 

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

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

Waste Feedrate to X-12 Nozzle Mass Flowmeter FT-145 Annually 0-5 lb/min 15-25 lb/min 10% 

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

Clam Shell Feed Weight 

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

Drum Conveyor Solids Weight Load Cell WT-014A Quarterly oib -1001b 10% 

Auxiliary Conveyor Solids 

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

Primary Combustion Chamber 

Temperature 

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

Secondary Combustion Chamber 

Temperature 

TypeR 

Thermocouple 

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

Primary Combustion Chamber 

Pressure 

Pressure 

Transmitter 

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

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

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

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

1 Carbon Injection Carrier Gas Low 

I Pressure 

Pressure Switch PSL-438A Annually Energize Switch Pass 

1 Carbon Injection Carrier Gas 

1 High Pressure 

Pressure Switch PSH-438B Annually Energize Switch Pass 

17 

VES 000879 
Table 2-. ,antinued) 

CMS Calibration Audit Requirements 

Application Instrument Tag Number 

Frequency of Drift 

Check/Accuracy 

Audit 

Low Level Check 

Point 

High Level Check 

Point Tolerance 

Unit No. 4 (continued) 

SDA X-18 Outlet Temperature 

(Baghouse Inlet Temperature) 

TypeK 

Thermocouple 

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

SDA X-19 Outlet Temperature 

(Baghouse Inlet Temperature) 

TypeK 

Thermocouple 

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

Combustion Gas Flowrate PitotTube/dPCell FT-559A/B Annually 0 in. w.c. 1.74 in w.c. 10% 

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

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

Stack Gas Oxygen 

Concentration 

Zirconium Oxide 

Analyzer 

AT-560A/B Per CEMS QA Plan 

Stack Gas Carbon Monoxide 

Concentration 

Multicomponeht 

Infrared Photometer 

AT-556E Per CEMS QA Plan Stack Hydrogen Chloride 

Concentration 

Multicomponeht 

Infrared Photometer 

AT-556E Per CEMS QA Plan 

Stack Gas Moisture 

Concentration 

Multicomponeht 

Infrared Photometer 

AT-556E Per CEMS QA Plan 

18 

VES 000880 
2.3 Preventive Maintenance 

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

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

• Verification that process variables are reasonable 

• Comparison of readings from redundant instruments • 

• Cleaning and visual check of monitoring equipment 

• Communication between operators and instrument technicians 

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

maintenance on the CMS also includes the cahbration audits previously described. All necessary 

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

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

the Maintenance Department. Additional details regarding preventive maintenance applicable to 

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

19 
3.0 CMS RECORDKEEPING AND REPORTING 

This section discusses recordkeeping and reporting requirements for CMS 

instrumentation as specified by § 63.1211. 

3.1 Recordkeeping 

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

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

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

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

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

summary of these requirements. 

Veolia will maintain records on the following: 

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

operation. 

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

and monitoring equipment. Maintenance performed on the air pollution 

control and monitoring equipment 

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

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

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

the SSMP 

• All information necessary to demonstrate conformance with the SSMP 

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

• All required measurements needed to demonstrate compliance with a relevant 

standard. 

• All results of performance tests, CMS performance evaluations, and opacity 

and visible emission observations 

• All CMS calibration checks 

• All adjustments and maintenance performed on CMS 

• All required CMS measurements (including data recorded during unavoidable 

CMS breakdowns and out-of-control periods) 

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

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

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

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

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

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

shutdowns, and malfunctions. 

• The nature and cause of any malfunction 

• The corrective action taken or preventive measures adopted 

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

out-of-control 

• The total process operating time during the reporting period 

• All procedures that are part of quality control program developed and 

implemented for CMS under § 63.8(d). 

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

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

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

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

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

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

totals in lieu of rolling averages. 

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

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

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

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

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

record. 

3.2 Reporting 

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

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

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

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

requirements of Subpart EEE. 

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

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

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

compliance required by § 63.1207(j). 

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

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

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

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

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

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

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

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

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

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

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

22 
Table 3-1 Reporting Requirements 

Regulatory 

Citation 

Description Frequency 

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

record Once 

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

must submit results of performance test. 

By the 60th day 

following every 

performance test 

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

must submit results of required performance tests. 

By the 60th day 

following required 

performance test 

§ 63.10(d)(4) Progress reports 

As specified in written 

extension of 

compliance 

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

(during reporting period) 

Submitted 

simultaneous with 

excess emission report 

§ 63.10(d)(5)(ii) Startup, shutdown, and malfunction reports when 

actions are taken that are inconsistent with SSMP. 

2 working days from 

commencement of 

action, followed with a 

letter explaining extent 

within 7 working days. 

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

perfonnance report 

Semiannually - by the 

30th day following the 

end of each calendar 

half performance test | 

23 

VES 000885 
4.0 CMS CORRECTIVE ACTIONS 

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

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

the type of corrective action required are given below. 

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

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

times the applicable CD specification in the apphcable performance 

specification or procedure; or 

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

accuracy test audit, or linearity test audit. 

The only applicable performance specification to the CMS is Performance Specification 

(PS) 4B of 40 CFR Part 63, Appendix B. PS 4B applies to the 02 and CO CEMS. The 

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

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

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

specification, as described in Section 2.0. 

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

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

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

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

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

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

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

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

meet any data availability requirement established under this part. 

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

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

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

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

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

24 

VES 000886 
Malfunction also includes the failure of a process or any process equipment to operate in 

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

careless operation are not malfunctions. 

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

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

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

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

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

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

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

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

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

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

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

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

25 
CONTINUOUS EMISSIONS MONITORING SYSTEM 

QUALITY ASSURANCE PLAN 

Prepared for: 

Veolia ES Technical Solutions, LLC 

Sauget, Illinois 

Prepared by: 

Franklin Engineering Group, Inc. 

Franklin, Tennessee 

October 2008 
TABL E O F CONTENT S 

1.0 INTRODUCTIO N AN D BACKGROUN D 1 

1.1 DESCRIPTION OF CEM S 1 

1.2 OVERVIEW OF REGULATORY REQUIREMENTS 2 

2.0 CEM S CALIBRATION S AN D PERFORMANC E 5 

2.1 DAILY DRIFT CHECKS 5 

2.2 CALIBRATION 8 

2.3 ABSOLUTE CALIBRATION AUDIT 10 

2.4 INTERFERENCE RESPONSE TEST 10 

2.5 RELATIVE ACCURACY TEST AUDIT 11 

3.0 CEM S MAINTENANC E 14 

3.1 DAILY SYSTEM AUDIT 14 

3.2 SPARE PARTS INVENTORY 14 

3.3 CALIBRATION GAS SUPPLY AND CERTIFICATION 15 

3.4 CORRECTIVE ACTION FOR MALFUNCTIONING CEM S 17 

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

4.1 EMISSION STANDARDS 18 

4.2 DRIFT LIMITS 18 

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

6.0 OPERATO R TRAININ G AN D CERTIFICATIO N 21 

VES 000889 
INDEX OF TABLES 

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

CEM S Q A PLAN 3 

TABLE 2-1 OVERVIEW OF CEM S PERFORMANCE REQUIREMENTS 6 

TABLE 3-1 SUMMARY OF CONCENTRATION REQUIREMENTS FOR CALIBRATION GASES 16 

LIST OF APPENDICES 

APPENDIX A CEM S DAT A SHEETS AN D CHECKLIST S 

ii 

VES 000890 
1.0 INTRODUCTION 

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

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

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

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

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

HWCs specifies emissions standards which reflect emissions performance of maximum 

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

MACT. 

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

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

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

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

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

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

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

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

Standard and the apphcable performance specification. 

1.1 Description of CEMS 

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

the following major components: 

• Heated stack sample probe 

• Heated traced umbilical 

• Heated sample pump 

• EcoChem MC3 multicomponent infrared (FR) gas analyzer 

• Zirconium oxide-based oxygen analyzer 

• System controller and data acquisition system 

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

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

induced draft (K>) fan. The umbihcal supphes mstrument air to the filter probe to allow 

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

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

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

the sample through contact with condensed moisture. 

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

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

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

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

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

concentrations. 

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

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

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

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

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

of 40 CFR Part 60, Appendix B. 

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

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

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

(AWFCO) system, and the main control system. 

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

These analyzers are zirconium oxide cells and are located downstream ofthe LD fan. 

1.2 Overview of Regulatory Requirements 

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

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

address each particular requirement. 

2 

VES 000892 
c 

Table 1-1 

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

Regulatory Reference: 

Appendix to 

Subpart EE E of Part 63 

Description 

CEMS QA Plan 

Section 

Section 3.1.a.1 Checks for component failures, leaks, and other 

abnormal conditions 

3.0 

3.1 

Section 3.1.a.2 Calibration of CEMS 2.2 

Section 3.1.a.3 Cahbration Drift determination and adjustment 

of CEMS 

2.1,2.2 

Appendix A 

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

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

spare parts inventory) 

3.0 

Appendix A 

Section 3. l.a.6 Data recording, calculations, and reporting 

4.1 

5.0 

Section 3.1. a. 7 Checks of record keeping 5.0 

Section 3.1.a.8 Accuracy audit procedures, including sampling 

and analysis methods 

2.3,2.5 

Appendix A 

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

CEMS 3.4 

Section 3.1.a.l0 Operator training and certification 6.0 

Section 3.1.b Reporting of excessive inaccuracies 5.0 

Section 3.2.1 QA responsibilities 5.0 

Section 3.2.2 

Schedules for: 

(1) daily checks 

(2) periodic audits 

(3) preventive maintenance 

(1) 3.0,3.1 

(2) 2.0, Table 2-1 

(3) 3.0 

Section 3.2.3 Check hsts and data sheets Appendix A 

Section 3.2.4 

„—, _ _=_=, 

Preventive maintenance procedures 3.0 

( 

VES 000893 
( 

V 

Table 1-1 (Continued) 

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

Regulatory Reference: 

Appendix to 

Subpart EE E of Part 63 

Description 

CEMS QA 

Plan Section 

Section 3.2.5 Description of the media, format, and location 

of all records and reports 

5.0 

Section 3.2.6 

Provisions for review of the CEMS data; 

revisions or updates of the QA plan based on 

review 

5.0 

Section 4.1 

Check, record, quantify: 

(1) Zero Drift 

(2) Cahbration Drift 

2.1 

Section 4.2 

Recording Requirements for: 

(1) Zero Drift 

(2) Cahbration Drift 

2.1 

Appendix A 

Section 4.3 Daily System Audit 3.1 

Section 4.4 Data recording and reporting 5.0 

Section 5.1 Relative Accuracy Test Audit (RATA) 2.5 

Section 5.2 Absolute Calibration Audit (ACA) 2.3 

Section 5.3 Interference Response Test (IRT) 2.4 

Section 5.4 Excessive audit inaccuracies 

Table 2-1 

2.3 

2.5 

( 

VES 000894 
2.0 CEMS CALIBRATIONS AND PERFORMANCE 

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

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

Cahbration drift checks and performance demonstrations are performed periodically on 

the CEMS based on the following schedule: 

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

Drift (ZD). 

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

(CE)for02, CO, and HCI. 

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

accuracy (RA) for CO emissions. 

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

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

corrective actions is presented in Table 2-1. Blank data sheets are provided in Appendix 

A. 

2.1 Daily Drift Checks 

Daily drift checks are automatically initiated by the CEMS controller. During the 

automated calibration sequence, calibration gases are injected from pressurized cylinders 

through the sampling system. The sequence starts with the LR analyzer zero gas that is 

free of any of the constituents analyzed by the IR analyzer. This zero gas may also serve 

as the span gas for the integrated O2 analyzer. The zero gas flows through fhe system 

with enough time allowed for the analyzer to fully respond to the gas. Then the analyzer 

response to the zero gas is recorded for one minute and averaged. The next cahbration 

gas in the cahbration sequence is the first IR analyzer span gas. This span gas is a 

cahbration standard that has one or more constituent concentrations at the analyzer span 

value (this gas may also be used as the zero gas for the O2 analyzer). The first span gas 

flows through the system to allow the analyzer enough time to fully respond to the gas. 

Then the analyzer response to the first span gas is recorded for one minute and averaged. 

This is then repeated for fhe second span gas and then possibly a third span gas 

depending upon the composition of the span gases. The total duration of this cahbration 

sequence has been designed to not exceed the 20 minute maximum allowable CEMS 

downtime while burning hazardous waste. 

VES 000895 
/—* \ 

Table 2-1 

Overview of CEMS Performance Requirements 

Analyzer Parameter 

(Span Value) QC Parameter 

Minimum 

Frequency 

QC Limit Corrective Action 

H2 0 

(60%) ZD Daily ±2% of span Zero Adjustment 

o 2 

(25%) 

ZD and CD Daily ±0.5% 02 Zero/Span Adjustment 

o 2 

(25%) 

CD Daily ±1.0%O2 Shut off waste, service/calibrate, conduct ACA 

o 2 

(25%) 

Cumulative Span 

Adjustment 

Per 

Adjustment 

o 2 ±1.5% 02 Shut off waste, service/calibrate, conduct ACA 

(25%) 

CE Quarterly1 0.5% 02 

Shut off waste, service/calibrate, conduct 

RATA 

o 2 

(25%) 

RA Annually 1.0% 02 Shut off waste, service/calibrate, repeat RATA 

CO 

(200 ppm) 

ZD and CD Daily ±3% of span Zero/Span Adjustment 

CO 

(200 ppm) 

CD Daily 

±5% of span 

for 6 out of 7 day 

Shut off waste, service/calibrate, conduct ACA 

CO 

(200 ppm) 

CD Daily ±6% of span Shut off waste, service/calibrate, conduct ACA 

CO 

(200 ppm) 

Cumulative Span 

Adjustment 

Per 

Adjustment ±9% of span Shut off waste, service/calibrate, conduct ACA 

CO 

(200 ppm) 

CE Quarterly1 5% Shut off waste, service/calibrate, conduct 

RATA 

CO 

(200 ppm) 

RA

 2 Annually 

5 ppmdv @ 7% 02 

(See Section 2.5) 

Shut off waste, service/calibrate, conduct 

RATA 

The ACAs for determining the 02 and CO CE are conducted quarterly, except in a quarter when a RATA is conducted instead. 

The RA accuracy for CO is based on the units of the CO emission standard (ppmdv @ 7% 02). CO data collected from the 

analyzer during the RATA will include low and or high range values per the normal operating requirements. 

6 

VES 000896 
Table 2-1 (continued) 

Overview of CEMS Performance Requirements 

Analyzer Parameter 

(Span Value) QC Parameter 

Minimum 

Frequency 

QC Limit Corrective Action 

CO 

(3000 ppm) 

ZD and CD Daily ±3% of span Zero/Span Adjustment 

CO 

(3000 ppm) 

CD Daily 

±5% of span 

for 6 out of 7 day 

Shut off waste, service/calibrate, conduct ACA 

CO 

(3000 ppm) CD Daily ±6% of span Shut off waste, service/calibrate, conduct ACA 

CO 

(3000 ppm) 

Cumulative Span 

Adjustment 

Per 

Adjustment ±9% of span Shut off waste, service/calibrate, conduct ACA 

CO 

(3000 ppm) 

CE Quarterly3 5% Shut off waste, service/calibrate, conduct RATA 

HCI 

(1000 ppm) 

ZD and CD Daily ±3% of span Zero/Span Adjustment 

HCI 

(1000 ppm) 

CD Daily 

±5% of span 

for 6 out of 7 day 

Shut off waste, service/calibrate, conduct ACA 

HCI 

(1000 ppm) CD Daily ±6% of span Shut off waste, service/calibrate, conduct ACA HCI (1000 ppm) 

Cumulative Span 

Adjustment 

Per 

Adjustment ±9% of span Shut off waste, service/calibrate, conduct ACA 

HCI 

(1000 ppm) 

CE Quarterly4 5% Shut off waste, service/calibrate, conduct ACA 

The ACAs for determining the 02 and CO CE are conducted quarterly, except in a quarter when a RATA is conducted instead. 

A RATA for HCI may be performed annually in lieu of perforrning an ACA in that quarter. 

7 

VES 000897 
The drift for each stack gas constituent is determined as the difference between the 

known constituent concentration in the calibration gas and the analyzer reading. ZD is 

the drift determined using zero gas. CD is the drift determined using span gases. ZD and 

CD are determined daily for O2, CO, and HCI. ZD for H2O is also determined daily. 

The ZD and CD are recorded by the CEMS datalogger as a percent of full-scale deviation 

(Dev%). Given that the "span value" is equal to the "full-scale" value, Dev% is 

calculated as follows: 

Dev%=-\Drift%\ 

n

 reference concetration - analyzer responce ,„„ 

Drift% = ^L — — — - --100 

span value 

For CO and 02, if Dev% for CD exceeds the limits specified in the apphcable 

Performance Specifications in 40 CFR Part 60, Appendix B, the analyzer must be 

cahbrated. If the Dev% for CD is greater than the preset tolerance (Tol%) the instrument 

technician will notify the incinerator operator and waste feeds will be shut off until 

corrective measures have been taken. The CD tolerances for both O2 and CO have been 

set at the two times the performance specification hmits. A calibration failure alarm 

indicates that the analyzer is out-of-control and must be serviced and recalibrated. An 

ACA must be conducted to document that the analyzer is within the performance 

specifications prior to resuming hazardous waste burning. 

For CO, if the Dev% for CD is greater than 5% for 6 out of 7 days, then the analyzer is 

out-of-control and must be serviced and recalibrated. An ACA must be conducted to 

document that the analyzer is within the performance specifications prior to resuming 

hazardous waste burning. 

Similar requirements for drift limits apply to HCI, except that no performance 

specifications have been promulgated for CEMS monitoring these parameters. In heu of 

limits specified by an EPA Performance Specification, Veolia has developed selfimposed performance specification hmits for HCI. These hmits are specified in Table 2-

1. 

2.2 Calibration 

Cahbration of the analyzer will be conducted periodically to ensure that the results of 

drift checks, ACAs, or RATAs meet the applicable performance specifications. 

8 

VES 000898 
Calibration for each IR channel (H2O, CO, and HCI) may be performed daily during the 

automated cahbration sequence used to determine cahbration drift. For each calibration 

gas used during the automated sequence, the automatic calibration will reset the analyzer 

response to correspond with the known reference concentrations. Any automated 

calibration adjustment will be made immediately after the analyzer response to the 

calibration gas is recorded electronically. The drift determined immediately prior to a 

calibration adjustment is equal to the magnitude of the adjustment. The oxygen analyzer 

uses a two-point calibration curve. The first calibration point resets the measured 

concentration of air to 20.94%. The second calibration point resets the measured 

concentration of a low concentration calibration gas to its known concentration. This 

cahbration is performed manually. To document fhe cahbration adjustment, the actual 

measurement at each cahbration point prior to adjustment will be recorded. 

Following service to the MC3 analyzer that could affect its calibration, each ER. channel, 

and the 02 analyzer will be calibrated. The CEMS Drift and Cahbration Data Sheet in 

the Appendix to this document will be used to track the cumulative span adjustments 

(i.e., change in the calibration factor). Section 5.5 ofthe MC3 CEMS Operations Guide 

and Section 4.4 of the MC3 CEMS System Guide should be referred to as needed for 

additional detail regarding cahbration of the CEMS. 

If the cumulative calibration adjustment for CD is three times the performance 

specification limits at any time, hazardous waste burning will be cutoff. The analyzer 

will be serviced, recalibrated, and an ACA will document that hazardous waste burning 

can recommence. A calibration factor that has been verified through an ACA will 

become the new reference point for assessing the cumulative adjustments made to correct 

for cahbration drift. 

The incinerator can remain on hazardous waste during CEMS drift checks, calibrations, 

purges, and corrective actions for CEMS failures provided that the CEMS downtime does 

not exceed 20 minutes. During these times, the instantaneous values used to determine 

one-minute averages of dry, oxygen corrected concentrations of CO are discarded. This 

allowance is provided by Section 6.2 and 6.5.1 of the Appendix to Subpart EEE. The 

applicable regulatory requirements do not limit the frequency that this allowance can be 

utilized. Typically, this allowance will only be utilized once per day for the daily drift 

checks. Since the oxygen analyzer cannot be calibrated during the automatic cahbration 

of the IR channels, calibration of the oxygen analyzer will require additional downtime. 
If a there is a CEMS failure, the incinerator may remain on hazardous waste provided that 

the CEMS can be restored within 20 minutes. 

Following downtime, the CEMS must be within the performance specifications described 

in this document. Otherwise, hazardous waste burning will cease until the appropriate 

corrective measures can be taken. To ensure that the hourly rolling average (HRA) for 

CO is representative of current operating conditions, CEMS data vahdity must be at least 

75% (i.e., 60 valid one minute averages per 80 minutes of normal operations). 

2.3 Absolute Calibration Audit 

An ACA is conducted quarterly for O2, CO (high and low range), and HCI. For O2 and 

CO, an ACA is not conducted in the quarter that the required annual RATA is performed. 

The ACA is conducted according to the cahbration error (CE) test procedure described in 

the Performance Specifications 4B. During fhe ACA, the analyzer is challenged over 

each range with EPA Protocol 1 cylinder gases. The EPA Protocol 1 cylinder gases are 

NIST traceable cahbration standards. For a given parameter, the analyzer response is 

recorded at three measurement points. This is then repeated twice to give three sets of 

data. The CE at each measurement point is determined as follows: 

CE=~-100% 

FS 

where d is the mean difference between the CEMS response and the known reference 

concentration and FS is the span value. 

For CO and HCI, the CE determined at each measurement point cannot exceed 5%. For 

O2, CE cannot exceed 2%. If an ACA fails to pass the QC criterion (i.e., the audit 

indicates excessive inaccuracy), then hazardous waste burning cannot resume until 

corrective measures have been taken and a RATA demonstrates that the CEMS is 

operating within the performance specifications. 

2.4 Interference Response Test 

The MC3 analyzer corrects for interferences using additive and multiphcative 

interference tables. These tables were generated per the manufacturer's procedure at the 

initial setup of the CEMS system. An Interference Response Test (IRT) is listed in the 

Appendix to Subpart EEE, however, the Performance Specification 4B does not include 

requirements or acceptance criteria for an interference response test. Veolia will perform 

10 

VES 000900 
Interference Response Tests at such time as US EPA specifies the test procedures and 

acceptable criteria for an Interference Response Test. 

2.5 Relative Accuracy Test Audit 

The Relative Accuracy Test Audit (RATA) is required annually for 02 and CO CEMS.. 

The Relative Accuracy (RA) test procedures required by Section 7.2 of PS 4B references 

incorrect sections of PS 3 (for 02) and PS 4A (for CO). The apphcable sections of the 

performance specifications are: 

• RATA procedures: Sections 8.4.3 through 8.4.5 of PS 2. 

• 02 reference methods: Section 8.2 of PS 3 

• CO reference methods: Section 8.2 of PS 4A. 

• 02 RA calculations: Section 12.0 of PS 3 

• CORA calculations: Section 12.0 of PS 2 

• 02 RA criterion: Section 13.2 of PS 3 

• CO RA criteria: Section 13.2 of PS 4A 

A brief summary of the applicable reference methods are provided below. 

US EPA Method 3/3A (Stack Gas Composition and Molecular Weight) 

The sampling and analytical procedures outlined in this method will be used to determine 

the 02 composition of the stack gas during the RATA. Using this method, a gas sample 

is extracted from the stack at a constant rate for determination of 02, C02 and molecular 

weight. The integrated gasbag collection option will be employed. The gasbags will be 

analyzed using an Orsat analyzer. As an alternative, the Method 3A (instrumental 

analyzer) method maybe used for analysis of the sample. 

US EPA Method 4 (Stack Gas Moisture Content) 

If necessary, the sampling and analytical procedures outlined in this method will be used 

to determine the moisture content of the stack gas during the RATA. Using this method, 

a gas sample is extracted from the stack. The gas passes through a series of impingers 

that contain reagents. The impingers are connected in series and are contained in an ice 

bath in order to assure condensation of the moisture in the gas stream. Any moisture that 

is not condensed in the impingers is captured in the silica gel, ensuring that all moisture 

can be weighed and entered into moisture calculations. 

US EPA Method 10 f Carbon Monoxide CEMS) 

11 
A continuous emissions monitor will be used to continuously sample exhaust gas for 

carbon monoxide analysis as described in EPA Method 10. Using this method, a 

continuous gas sample is extracted from the exhaust gas, and is analyzed for carbon 

monoxide (CO) using a Luft-type Non-Dispersive mfrared Analyzer (NDTR), or another 

equivalent analyzer. This sampling and analysis will occur continuously throughout the 

duration of each run ofthe RATA. 

During a test run of the RATA, US EPA reference methods are utilized to obtain stack 

gas data. These data are used to calculate the stack gas dry O2 concentration and the 

stack gas CO concentration corrected to seven percent oxygen in units of parts per 

million, dry volume (i.e., in the units ofthe emission standard, 100 ppmdv CO @ 7% 

O2). The average stack gas 02 (%, dry) and CO (ppmdv, @ 7% 02 ) concentrations—as 

calculated from the installed CEMS over the duration of the run—are compared to the 

value obtained using the reference methods. The RATA consists of a minimum of 9 test 

runs. If more test runs are conducted, at least 9 data sets will be used to detennine RA, 

and no more than three sets of data will be rejected. The O2 and CO RA calculations and 

acceptance criteria are presented below. 

RA, 

co 

d + CC 

RM 

•100% < 10% ...for RM > 50ppmdv @ 7% 02 

\d\ + |CC| < 5ppmdv@7% 02...for RM < 50ppmdv@7% 02 

where, 

d = — - V (RM. - CEMS,) 

n = number of test runs 

RMi = the concentration determined by the reference method for the i t h test run 

CEMSi = the concentration determined by the CEMS for the 1th test run 

CC = the 2.5 percent error confidence coefficient (see Section 12.4 of PS 2) 

If a RATA fails to pass the QC criterion (i.e., the audit indicates excessive inaccuracy), 

then hazardous waste burning cannot resume until corrective measures have been taken 

and a RATA demonstrates that the CEMS is operating within the performance 

12 

VES 000902 
specifications. If CO emission levels are significantly low, it may be difficult to produce 

meaningful results using the RA test procedure. Under these circumstances, Veolia will 

request approval to utilize the Alternative RA Procedure prescribed by Section 7.3 of PS 

4B. . 

13 

VES 000903 
3.0 CEMS MAINTENANCE 

Veolia has developed a preventative maintenance program for the CEMS. This program 

includes frequent inspections of the CEMS in order to identify potential component 

failures, leaks, and data quality issues. The CEMS preventative maintenance program 

also includes scheduled replacement of critical components and maintenance of spare 

parts inventory. All scheduled and unscheduled maintenance of the CEMS will be 

documented in a CEMS logbook maintained for each incinerator. Section 8.0 ofthe MC3 

CEMS Operations Guide provides details for daily, weekly, monthly, quarterly, and 

annual inspection and maintenance activities. Procedures and recordkeeping for the 

specific inspection and maintenance activities are described below. 

3.1 Daily System Audit 

The Daily System Audit includes: 

• Review of the daily drift check data 

• Inspection ofthe recording system 

• Check for controller alarms and error/warning messages 

• Check expected calibration values 

• Check of current data status 

• Check of calibration gas cylinder pressures 

• Check calibration gas pressure regulator settings 

• Inspection of the instrument air pressure 

• Inspection of the stack gas sampling system 

The Daily System Audit Checklist will be used to document the tradings from the daily 

system audit. A CEMS Drift and Cahbration Data Sheet will be completed during the 

daily system audit in order to track and evaluate drift and adjustments made to the 

CEMS. 

3.2 Spare Parts Inventory 

CEMS spare parts are maintained in sufficient quantities on-site to perform routine 

maintenance activities. It is anticipated that these spare parts and typical maintenance 

supplies will be adequate to service the CEMS. Some services and replacement of 

components must be performed by an EcoChem Analytics Service Engineer to avoid 

violation ofthe system certification. 

14 

VES 000904 
The following consumable parts have been targeted for periodic inspection and 

replacement for maintaining the CEMS: 

• Air conditioner filters for CEMS shelter 

• mstrument air coalescing filters 

• Sample pump Teflon diaphragm 

• Sample pump Teflon flapper valve 

• Sample probe internal filter 

• Sample probe gaskets 

• Probe-tip filter 

The following spare parts are not part of routine maintenance and would be replace by an 

EcoChem Service Engineer: 

• Cell front cover gasket 

• Cell inlet filter 

• Cell windows with o-ring gaskets 

• Cell mirrors 

The CEMS Calibration Gas and Spare Parts Log is provided in Appendix A and will be 

used as needed to keep track of inventory. 

3.3 Calibration Gas Supply and Certification 

A summary of the cahbration gases needed to perform the daily drift checks, calibrations, 

and ACAs is presented in Table 3-1. The number of gas cylinders maintained on-site 

depends on the specific mixture of gases in each cylinder and the lead time required for 

placing orders. An inventory of cahbration gases will be conducted in conjunction with 

the spare parts inventory to ensure that the appropriate gases are available for use. 

Certification from the supplier of cahbration gas quality will be kept with the most recent 

spare parts inventory documentation. 

Each calibration sequence depletes approximately 40 psi, and a cylinder with less than 

150 psi should be replaced; The daily system audit includes inspection of the calibration 

gas cylinder pressures and will be used track usage and to predict when to reorder. 

15 

VES 000905 
Table 3-1 

Summary of Concentration Requirements for Calibration Gases 

Constituent 

QC 

Parameter 

Concentration 

Requirement 

Accuracy 

H2 0 ZD 0% per gas supplier 

o2 

ZD 0% per gas supplier o2 

CD 25% per gas supplier 

o2 

ACA 0-2% EPA Protocol 1/NIST Traceable 

o2 

ACA 8-10% EPA Protocol 1/NIST Traceable 

o2 

ACA 14-16% EPA Protocol 1/NIST Traceable 

CO (low range) ZD Oppm per gas supplier (low range) 

CD 200 ppm per gas supplier 

CO (low range) 

ACA 0-40 ppm EPA Protocol 1/NIST Traceable 

CO (low range) 

ACA 60-80 ppm EPA Protocol 1/NIST Traceable 

CO (low range) 

ACA 140-160 ppm EPA Protocol 1/NIST Traceable 

CO (high range) ZD Oppm per gas supplier (high range) 

CD 3000 ppm per gas supplier 

CO (high range) 

ACA 0-600 ppm EPA Protocol 1/NIST Traceable 

CO (high range) 

ACA 900-1200 ppm EPA Protocol 1/NIST Traceable 

CO (high range) 

ACA 2100-2400 ppm EPA Protocol 1/NIST Traceable 

HCI ZD Oppm per gas supplier I 

CD 1000 ppm per gas supplier 

HCI 

ACA 0-200 ppm EPA Protocol 1/NIST Traceable 

HCI 

ACA 300-400 ppm EPA Protocol 1/NIST Traceable 

HCI 

ACA 700-800 ppm EPA Protocol 1/NIST Traceable | 

16 

VES 000906 
3.4 Corrective Action for Malfunctioning CEMS 

It is Veolia's policy to minimize the occurrence of malfunctions by taking a proactive 

approach to facihty maintenance. Proactive measures include the preventive 

maintenance described in this section, and the calibration and performance testing 

described in Section 2.0. Frequent inspections and availabihty of spare parts allow for 

the timely completion of as needed service to the CEMS prior to a major malfunction. 

Operating and maintaining the incinerator during a malfunction will be conformance with 

the Startup, Shutdown, and Malfunction Plan (SSMP). Attachment 4 to the SSMP is the 

Program of Corrective Action for Malfunctions. Section 9.2 of the Program of 

Corrective Action for Malfunctions addresses corrective actions for malfunctioning 

CEMS. Section 9.0 through 9.2 ofthe MC3 CEMS Operations Guide maybe referred to 

as needed for troubleshooting and corrective maintenance of the CEMS. 

17 
4.0. INTEGRATION OF TH E CEMS WITH THE AWFCO SYSTEM 

The CEMS is integrated with the automatic waste feed cutoff (AWFCO) system to assure 

on-going comphance with CO emission standards. The AWFCO system is designed to 

immediately and automatically shut of all waste to the incinerator in the event of an 

exceedance of an emission or operating limit. The CEMS is integrated with AWFCO 

system through interlocks. These interlocks are conditions which trigger a relay causing 

the AWFCO system to activate. This section describes the AWFCO interlocks associated 

with the CEMS. 

4.1 Emission Standards 

The CEMS raw data for 02 (% vol), H2 0 (% vol), and CO (ppmv) consists of 

instantaneous values which have not been smoothed or averaged, evaluated once every 

15 seconds. These values are used to calculate CO emissions in the units of emission 

standards. Calculations equivalent to the following procedures are performed to compare 

the stack gas emissions to the CO emission standard. 

First 15-second data in the units of the emission standards are calculated: 

f \ 

CO@7%02,ppmdv •• 

CO, ppmv 

WO%-(H2O,%) 

14% 

21%-

o2,% 

100%-(H2O,%) 

The calculated 15-second data are then used to calculate one-minute averages (OMAs). 

The current minute OMA is averaged with the previous 59 OMAs to generate an hourly 

rolling average (HRA). All rounding is avoided for the numbers used to calculate HRAs. 

The HRA of CO emissions are rounded to two significant figures. 

If the HRA CO emission concentration exceeds the CO emission standard of 100 ppmdv 

@ 7% 02, an AWFCO will occur. 

4.2 Drift Limits 

As described in Section 2.1, waste feeds will be manually shut off in case a drift limit is 

exceeded. For CO and 02, drift limits are equal to 2 times the performance 

specifications. Comparable drift limits have been estabhshed for excessive H2 0 drift. 

18 
5.0. RECORDKEEPING AND QUALITY ASSURANCE REVIEWS 

Documentation generated from CEMS QA/QC procedures and monitoring will be kept 

on-site for a period of five years. The data and documentation that is generated and 

reviewed is kept in various locations at the Veolia facility. Table 6-1 below lists the 

storage location and format of this documentation. 

Maintenance and Instrument Technicians have the primary responsibihty for creating and 

organizing CEMS data sheets, daily system audit checklists, maintenance logbook, and 

spare part inventory records. The Environmental Engineer/Specialist or designee will 

check these records quarterly to verify completion and organization. This review will 

also consider the following requirements: 

1. Whenever excessive audit inaccuracies occur for two consecutive quarters, the 

current written procedures will be revised or the CEMS modified or replaced to 

correct the deficiency causing the excessive inaccuracies. Previous versions of 

written procedures will be kept on record and made available for inspection. 

2. If the ZD and/or CD exceed(s) two times the limits in the Performance 

Specifications, or if the cumulative adjustment to the ZD and/or CD exceed(s) 

three times the limits in the Performance Specifications, the CEMS is considered 

"out-of-control" (as defined in 40 CFR 63.8(c)(7)), and the event will be reported 

in the facility's semi-annual "Excess Emissions and CMS Performance Report". 

Further detail on this report can be found in the facility CMS Quahty Assurance 

Program. 

On an annual basis the Environmental Engineer/Specialist or designee will review all 

CEMS data generated for the previous 12 months and prepare a brief internal 

report/memo summarizing findings. Based on this review, the Environmental 

Engineer/Specialist or designee will solicit recommendations for revisions to the CEMS 

Quahty Assurance Plan. The CEMS Quahty Assurance Plan will be revised as needed to 

maintain QA/QC of the CEMS. All versions of this plan for the last five years remain in 

the operating record. 

19 
Table 5-1 CEMS Records and Reports 

Record/Report Storage Location Media/Format1 

CEMS QA Plan 

- Current Version 

- Previous Version 

Incinerator Manager's Office 

Operating Records Archives 

HD and/or P 

RD 

CEMS Readings and HRA 

- Previous year through year to date 

- Remaining archives 

Data Historian 

Operating Records Archives 

HD and/or RD 

RD 

Drift and Calibration Data: 

- Previous year through year to date 

- Remaining archives 

Operating Records Archives P and/or RD 

Absolute Cahbration Audit 

- Previous year though year to date 

- Remaining archives 

Operating Record Archives P and/or RD 

Relative Accuracy Test Audit 

- Previous year through year to date 

- Remaining archives 

Operating Record Archives P and/or RD 

Daily System Audit 

- Previous year through year to date 

- Remaining archives 

Operating Record Archives P and/or RD 

Preventive Maintenance Logbook 

- Previous year through year to date 

- Remaining archives 

Operating Records Archives P and/or RD 

Spare Parts Inventory 

- Previous year through year to date 

- Remaining archives 

Operating Records Archives P and/or RD 

Annual Review of CEMS Data Operating Records Archives 

P and/or HD 

and/or RD 

1

 Media Format: 

HD - Computer or network hard drive 

RD - Removable drive (floppy, CD, backup tape) 

P - Paper documentation 

20 

VES 000910 
6.0 OPERATOR TRAINING AND CERTIFICATION 

Training is provided to Veolia employees on the basis of their job title. Individuals 

specifically involved in the operation of the incinerator and associated CEMS are the 

Instrument Technicians, Incinerator Operators, and Environmental Engineer/Specialist. 

The Veolia operator training and certification program meets the requirements outlined in 

40 CFR 63.1206(c)(6). Documentation of employee training and certification is kept 

with the Training Director, and is available for review upon request. 

21 

VES 000911 
APPENDIX A 

CEM S DAT A SHEETS AND CHECKLISTS 

NOTE: THE FOLLOWING SHEETS ARE FOR EXAMPLE PURPOSES ONLY. 

VEOLIA MAY UTILIZE EQUIVALENT DOCUMENTATION FOR ANY OF THE 

SHEETS INCLUDED. 
CEMS DRIFT AND CALIBRATION DAT A SHEET 

Parameter 

(Span Value) 

Date & Time 

Concentration 

Drift % Adjustment % 

Cumulative 

Adjustment % 

Parameter 

(Span Value) 

Date & Time 

Reference Analyzer 

Drift % Adjustment % 

Cumulative 

Adjustment % 

HzO (60 %) 

Zero 

Oj (25%) 

Zero 

Calibration 

CO (200 ppm) 

Zero 

Calibration 

CO (3000 ppm) 

Zero 

Calibration 

HCI (1000 ppm) 

Zero 

Calibration 

Drift%^ Ref6renCe-

AnalyZer .100 % 

Span Value ( Nam e & Title ) 

Adjustment % = Drift % (if zero/span was reset during drift check) 

Cumulative Adjustment % = (Previous Cumulative Adjustment %) + (Current Adjustment %) ~ (Signature) 
ABSOLUTE CALIBRATION AUDIT (ACA) 

DATA SHEET 

Parameter 

• o 2 

Q CO-Iow range 

CD CO-high range 

• HCI 

NIST Traceable Calibration Standards 

Parameter 

• o 2 

Q CO-Iow range 

CD CO-high range 

• HCI 

Gas Concentration 

Parameter 

• o 2 

Q CO-Iow range 

CD CO-high range 

• HCI 

Low (Zero) ± 

Parameter 

• o 2 

Q CO-Iow range 

CD CO-high range 

• HCI 

Mid ± 

Parameter 

• o 2 

Q CO-Iow range 

CD CO-high range 

• HCI 

High ± 

RUN 

NUMBER 

RUN Concentration Difference 

NUMBER Reference Analyzer Low Mid High 

1 - Low 

2 -Mi d -

3 -High - ~ 

4 -Low — -

5 -Mi d -- -

6-High - -

7 -Low - -

8 -Mi d ~ 

__ 

9 -High -

MEA N DIFFERENCE = 

CALIBRATION ERROR = 

MEA N DIFFERENCE = 

CALIBRATION ERROR = % % % 

_ r , ,. _ Mean Difference 

Cahbration Error = * 100 

Span Value 

(Name) (Title) 

(Signature) (Date) 

VES 000914 
RELATIVE ACCURAC Y TEST AUDIT RAT A 

DATASHEE T 

Reference Method CEMS Difference Reference Method CEMS Difference 

Run H20, % 

(if applicable) 

02, % wet 

(if applicable) 

02 ; % dry 02 s % dry 02

, % diy 

CO ppmv 

(if applicable) 

CO ppmdv 

CO ppmdv 

@7%02 

CO ppmdv 

@7%02 

CO ppmdv 

@ 7% 02 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

0 2 R A | Mean Difference 

Standard Deviation 

I Confidence Coefficient 

CORA 

(Name) (Title) 

(Signature) (Date) 
CEMS DAILY SYSTEM AUDIT 

Initials 

Verify that the most recent drift checks and calibration adjustments are within limits. 

Complete Drift and Calibration Data Sheet. 

Corrective Actions: 

Verify proper operation of CEMS data recording and printing 

Corrective Actions: 

Check for controller alarms and error/warning messages 

Corrective Actions: 

Check expected calibration values 

Corrective Actions: 

Check current emissions data status 

Corrective Actions: 

Verify calibration gas cylinder pressures (>150 psi) 

Corrective Actions: 

Verify pressure regulator settings (approximately 25-35 psi) 

Corrective Actions: 

Verify proper instrument air pressure to CEMS umbilical 

Corrective Actions: 

Perform visual inspection of the stack gas sampling system 

Corrective Actions: 

(Name) (Title) . 

(Signature) (Date) 

VES 000916 
CEM S CALIBRATIO N GA S AN D SPAR E PART S LO G 

CALIBRATION GASES: 

(Attach all certification forms) 

Zero gas: 

Span gas 1: 

Span gas 2: 

Span gas 3: 

ACA Gases: 

cylinders 

cylinders 

cylinders 

cylinders 

Composition: 

Composition: 

Composition: 

Composition: 

PARTS: 

Air conditioner filters for CEMS shelter 

Instrument air coalescing filters 

Sample pump Teflon diaphragm 

Sample pump Teflon flapper valve 

Sample probe internal filter ____ _ 

Sample probe gaskets 

Probe-tip filter 

Cell front cover gasket 

Cell inlet filter 

Cell windows with o-ring gaskets 

Cell mirrors 

Tubing 

Fittings 

Solenoid Values 

Thermocouples 

Electronic parts 

Other spare parts 

Inventory taken by: __ Date: 

VES 000917