QVGOLI A 

ENVIRONMENTAL SERVICES 

January 28, 2014 

Via FedEx hi JA N 3 0 2014 [ | 

. ' • r-.f-^.-.-,..' • • • 

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 

R E: Veolia ES Technical Solutions, L.L.C. 

163121AAP 

40 CF R Part 63 - Subpart EEE 

National Emission Standards for Hazardous Air Pollutants from 

Hazardous Waste Combustors 

Comprehensive Performance Test Reports and Notification of 

Compliance (NOC) 

Compliance Tracker, 

Pursuant to the requirements of 40 CFR 63.1200, subpart EEE, Veolia ES 

Technical Solutions, L.L.C, hereby submits the Performance Test Reports 

for Incinerators 2, 3 and 4 and the Notification of Compliance (NOC). The 

NOC documents compliance with the emission standards and continuous 

monitoring system requirements, and identifying operating parameters 

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. 

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 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 

#7 Mobile Avenue, Sauget, IL 62201 

(618)271-2804 

www.veoliaes.com 
QVGOLIA 

ENVIRONMENTAL SERVICES 

Compliance Tracker 

January 28, 2014 

Page 2 

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 dennis.warchol@veolia.com or me at (618) 271-2804 or via 

e-mail at doug.harris@veolia.com. 

Sincerely, 

Veolia ES Technical Solutions, L.L.C. 

Doug Harris 

General Manager 

Att. 

cc: Mr. George Czerniak, Director, Air and Radiation Division 

USEPA File 

#7 Mobile Avenue, Sauget, IL 62201 

(618) 271-2804 

www.veoliaes.com 
El¥I 

Notification of Compliance 1^1^11^^ 

with the ~ 

Final Replacement Standards 

of the 

National Emission Standards for Hazardous Air Pollutants for 

Hazardous Waste Combustors 

(40 CFR 63, Subpart EEE) 

Veolia ES Technical Solutions, L.L.C. 

Sauget, Illinois 

Veolia ES Technical Solutions, L.L.C. 

7 Mobile Avenue 

Sauget, Illinois 62201 

January 28, 2013 

URS Corporation 

9400 Ambergien Boulevard 

Austin. TX 78729 

P.O. Box 201088 

Austin, TX 78720-1088 

Tel: 512.454.4797 

Fax: 512.454.8807 

www.urscorp.com 
Table of Contents 

Page 

1.0 Certification Statement 1 

2.0 Introduction 2 

2.1 Test Objectives 2 

2.2 CPT Schedule 4 

3.0 Unit Description 5 

4.0 Results of the Comprehensive Performance Test 10 

4.1 Test Protocol Summary 11 

4.2 Summary of Results 14 

5.0 Operating Parameter Limits 18 

6.0 Bases for Establishment of OPLs 31 

ii 
List of Tables 

Page 

2-1 HWC MACT Standards 3 

4-1 Data Used to Establish OPLs 13 

4-2 Unit 2 Compliance Summary 15 

4-3 Unit 3 Compliance Summary 16 

4- 4 Unit 4 Compliance Summary 17 

5- 1 HWC MACT Operating Parameter Limits for the Final Replacement Standards 

for Units 2 and 3 19 

5-2 HWC MACT Operating Parameter Limits for the Final Replacement Standards 

for Unit 4 20 

5-3 Unit 2 Development HWC MAC T Operating Limits 21 

5-4 Unit 3 Development HWC MACT Operating Limits 24 

5-5 Unit 4 Development HWC MACT Operating Limits 27 

List of Figures 

Page 

3-1 Unit 2 Process Flow Diagram 7 

3-2 Unit 3 Process How Diagram 8 

3-3 Unit 4 Process Flow Diagram 9 

iii 
1.0 Certification Statement 

I certify under penalty of the 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 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. 

Signature: 

Doug Harris

 u 

General Manager 

Veolia ES Technical Solutions, L.L.C. 

Sauget, Illinois 

1 
2.0 Introduction 

Veolia ES Technical Solutions, L.L.C. (Veolia) operates three incinerators at its Sauget, 

Illinois facility. Two of the incinerators are fixed hearth units (Units 2 and 3), and the third 

incinerator is a rotary kiln unit (Unit 4). Al l of the incinerators treat certain wastes that are 

classified as hazardous under state and/or federal regulations, and are subject to the National 

Emission Standards for Hazardous Air Pollutants (NESHAPs) for Hazardous Waste 

Combustors (Title 40 of the Code of Federal Regulations, Part 63 [40 CFR Part 63], Subpart 

EEE), (i.e., the HWC MACT). 

A subsequent Comprehensive Performance Test (CPT) of the three incinerators at 

Veolia's Sauget facility was completed on October 30, 2013. The CPT demonstrated applicable 

emission standards and established OPLs as required by the HWC MACT for dioxins/furans, 

THC, CO, particulate matter (PM), hydrochloric acid and chlorine gas (HC1/C12), mercury, SVM, 

and LVM . Compliance with the DRE standard (99.99% DRE) is demonstrated using data from 

previous RCRA trial burns. The subsequent CPT began with the performance of RATAs of the 

CO and 0 2 continuous monitoring systems (CEMS). The RATA of the CO and 0 2 CEMS of 

Unit 4 was performed on September 4, 2013. The RATA of the CO and 0 2 CEMS of Unit 3 was 

performed on September 5, 2013, and the RAT A of the CO and 0 2 CEMS of Unit 2 was 

performed on September 6, 2013. The results of the CPT are presented in an accompanying 

report, Comprehensive Performance Test Report for Fixed Hearth - Unit 2 Fixed Hearth - Unit 

3 Rotary Kiln Incinerator - Unit 4 (CPT Report). In accordance with 40 CFR §63.1207(j)(l)(i) 

and §63.1207(j)(3), the Notification of Compliance (NOC) and CPT Report are being filed 

within 90 days of completion of the CPT. 

2.1 Test Objectives 

The subsequent CPT for the Final Replacement Standards of the HWC MACT for the 

three incinerators at Veolia Sauget was designed and conducted to demonstrate compliance with 

the standards and associated OPLs of the HWC MACT for existing incinerators at §63.1219. The 

CPT: 

• Demonstrated that the incinerators meet the applicable HWC MACT emission 

limits while treating hazardous waste; and 

• Re-established operating parameter limits (OPLs) on key operating variables that 

will ensure that the incinerator operates within the HWC MACT emission limits 

while treating hazardous waste. 

2 
The test program included feeding liquid and solid waste materials to the incinerators, 

sampling and analyzing the feedstreams, spiking waste feedstreams with metals and chlorine, 

monitoring certain process parameters, conducting emissions testing, and sampling of waste 

streams and spiking materials. Applicable emissions standards for the incinerators at Veoha Sauget 

under the HWC MACT regulations are summarized in Table 2-1. 

Table 2-1. HWC MACT Standards 

HAP or HAP Surrogate Final Replacement Standards 

Destruction and Removal Efficiency 99.99% 

Dioxins/Furans 

0.20 ng TEQ/dscm - Units 2 and 3 1 

0.40 ng TEQ/dscm - Unit 4 1 2 

Particulate Matter 0.013 gr/dscf, at 7% 0 2 

Mercury 130 (xg/dscm, at 7% O z 

S V M (Semivolatile metals, Cd, Pb) 230 [xg/dscm, at 7% 0 2 

L V M (Low volatility Metals, As, Be, Cr) 92 u,g/dscm, at 7% 0 2 

HC1/C12 32 ppmv, dry, at 7% 0 2

, as chloride equivalents. 

CO 100 ppmv, dry, at 7% 0 2 

Hydrocarbons 10 ppmv, dry, at 7% 0 2 

1

 Toxicity Equivalents - relating the relative concentrations and toxicity of the dioxin and furan congeners 

and isomers to the toxicity of 2,3,7,8 tetrachlorodibenzodioxin. 

2

 The initial particulate matter control device is a baghouse, and the OPL for the maximum inlet temperature 

to the baghouse of Unit 4 is 399°F (i.e., less than 400°F). During the CPT, the average of the test run 

averages (during the sampling for Dioxins/Furans) was 399°F. 

The objectives for the subsequent CPT for the Final Replacement Standards of the HWC 

MAC T for each of the three incinerators were to: 

• Demonstrate compliance with stack gas emissions less than or equal to the 

following limits, corrected to 7% O2: 

— Carbon Monoxide: 100 ppmv, dry; 

— Total Hydrocarbons: 10 ppmv, dry; 

— Dioxins/Furans: 0.20 ng TEQ/dscm for Units 2 and 3, and 0.40 ng TEQ/dscm for 

Unit 4; 

— Particulate Matter (PM): 0.013 grains/dscf; 

— Mercury: 130 |d,g/dscm; 

— Semivolatile Metals (SVM) (Cd and Pb combined): 230 |ig /dscm; 

— Low Volatility Metals (LVM) (As, Be and Cr combined): 92 \ig /dscm; and 

— Hydrogen Chloride/Chlorine (HCI/CI2): 32 ppmv as CT equivalent, dry. 

• Compliance with the DRE standard (99.99% DRE) is demonstrated using data from 

previous RCRA trial burns. 

3 
• Establish limits for operating parameters. 

• Conduct a Continuous Monitoring System (CMS) performance evaluation test. 

• Conduct a Relative Accuracy Test Audit (RATA) for the CO and O2 Continuous 

Emissions Monitoring Systems (CEMS. 

2.2 CPT Schedule 

The subsequent CPT of the three incinerators at the Sauget facility began with the 

performance of RAT As of the CO and O2 continuous monitoring systems (CEMS). The RAT A 

of the CO and 0 2 CEMS of Unit 4 was performed on September 4, 2013. The RAT A of the CO 

and 0 2 CEMS of Unit 3 was performed on September 5, 2013, and the RAT A of the CO and 0 2 

CEMS of Unit 2 was performed on September 6, 2013. 

The subsequent CPT of Unit 2 was begun October 8, 2013. Run 1 of the test was 

completed on this day. Run 2 was performed on October 9, 2013, but only results associated with 

the standard for particulate matter are reported (i.e., the first part of the run). The second run, 

identified as Run 3, was performed on October 10, 2013. The third run of the second part of the 

test, for HC1/C12, metals, and dioxins/furans, (i.e., Run 5) was performed on October 30, 2013. 

The subsequent CPT of Unit 3 was begun October 15, 2013. The first part of Run 

1, for PM , was completed on this day. Testing for HCI/CI2, metals, and dioxins/furans, 

had to be repeated. Run 2 was performed on October 16, 2013, and Run 3 was performed 

on October 17, 2013. The third successful run of the second part of the test of Unit 3 for 

HCI/CI2, metals, and dioxins/furans (i.e., Run 4) was performed on October 18, 2013. 

The subsequent CPT of Unit 4 was begun October 23, 2013 with the completion of Run 

1. Run 2 was performed on October 24, 2013. Results for HCI/CI2, metals, and dioxins/furans are 

reported for Run 2. P M results for Run 2 are not reported. Run 3 was performed on October 25, 

2013. The third (accepted) run for P M (i.e., Run 4) was performed at the conclusion of Run 3 for 

P M . 

4 
3.0 Unit Descriptions 

Veolia operates two 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. Unit 3 is a mirror image of Unit 2. Both of these units have their own waste 

handling systems. 

Units 2 and 3 feature 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 "afterburner" for process gases. Liquid wastes, organic and aqueous, 

and solid wastes are fed to the PCC. Air-atomizing injectors are used for injection of high-Btu 

liquids, low-Btu liquids and specialty feed liquids. 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 PCC. 

The air pollution control systems of Units 2 and 3 consist of a spray dryer absorber and 

fabric filter baghouse modules. The air pollution control system neutralizes acidic compounds and 

removes particulate matter from the exhaust gas. Two subsystems, the spray dryer absorber and the 

fabric filter, carry out the chemical neutralization and particulate removal functions, respectively. 

An 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. The only 

difference between Units 2 and 3 is that Unit 2 is equipped with four (4) baghouse modules, while 

Unit 3 is equipped with three (3) baghouse modules! However, each incinerator is operated 

identically with only three baghouse modules in service during operation. 

A complete description of Units 2 and 3 is provided in the CPT Plan. A process flow 

diagram for Unit 2 is presented in Figure 3-1, and a process flow diagram for Unit 3 is presented in 

Figure 3-2. 

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. Unit 4 includes a rotary kiln as the PCC, and a SCC. 

Liquids are fed to either the kiln PCC or the SCC. Bulk solid wastes are fed to the kiln through the 

ram feeder. Containerized wastes are fed to the kiln through the ram feeder or the auxiliary ram 

feeder. The Uquid waste injectors used in the combustion chambers are air-atomizing injectors, and 

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. 

5 
The air pollution control system consists of a tempering chamber, two spray dryer 

absorbers, and fabric filter baghouse modules with carbon injection. 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. An 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. 

A complete description of Unit 4 is provided in the Comprehensive Performance Test Plan. 

A process flow diagram for Unit 4 is presented in Figure 3-3. 

6 
Figure 3-1. Unit 2 Process Flow Diagram 

TANK FARM 

DIRECT INJECT 

Mil ! 

I I I I I 

,..T. TJ L T Y 

COMBUSTION 

AIR 

BLOWER 

tooooooH 

TANK FARM ^ LOW 

em 

DIRECT INJECT LOT S 

/ AI R 

Mrrrr -

T T• T T T 

-SECCWOAR Y 

A IR 

EMERGENC Y 

STAC K 

INCINERATOR 

L0V£R 

CHAMBER 

HOD/0 CONTAINER^ 

GAS CYLINDERS. 

SPECIALTY 

FEEDER 

INCINERATOR 

UPPER 

CHAMBER 

PRIMARY 

FUEL 

WET ASH 

DUMPSTER 

i i 

UME 

PREPARATION 

SYSTEM 

SPRAY 

DRY 

A8SORBER 

DRY SCRUBBER 

SOLIDS { DSS ) 

END DUMP 

MAIN STACKSTAC K OA S 

ANAlY2fl?S • 

BAGHOUSE I.D. FAN 

DRY SCRUBBER 

|S0LIDS ( OSS ) 

END DUMP 

cccax»~ 

>oooo*>-

FUELS/LIQUID WASTE FLOW 

COMBUSTION AIR FLOW 

STACK OAS FLOW 

ASH FLOW 

SOUP WASTE FLOW 

LIME SLURRY FLOW 

7 
Figure 3-2. Unit 3 Process Flow Diagram 

TAN K FARM . 

DIRECT INJEC T 

HIGH 

8TU 

LIQUIDS 

m i l 

i i i i i 

T T T f V 

SOLIDS 

COMBUSTION 

AIR 

SLOWE R 

fooooooH 

TANK. FARM 

OIRECT INJECT 

L OW 

B T U 

LIQUIDS 

-UHDEWIIK 

f m. 

••f frrr -

T. T, T T T T. 

-SECONDAR Y 

INCINERATOR 

LOWER 

CHAMBE R 

EMERGENC Y 

STAC K 

LIME 

PREPARATIO N 

SYSTE M 

INCINERATOR 

UPPE R 

CHAMBE R 

BURNE R 

W E T AS H 

DUMPSTE R 

/ 

SPRA Y 

O R Y 

ABSORBE R 

SPECIALTY FEEDER 

FUME HOOD 

EMISSION CONTROL 

SYSTEM 

PRIMAR Y 

FUE L 

O R Y SCRUBBE R 

SCUD S ( DS S ) 

E N D DUM P 

GLOV E BO X 

EMISSION CONTROL! 

SYSTE M 

JJMAIN STACK -

SIACK OAS 

ANALYSERS -

BAGHOUSE t.D. FAN 

DRY SCRU8BER 

SOLIDS ( OSS ) 

END DUMP 

axxro-

>OO0O*~ 

-\\\»-

FUELSAIQUID WASTE FLOW 

COMBUSTION AIR FLOW 

STACK GAS FLOW 

ASK FLOW 

SOLID WASTE FLOW 

UME SLURRY FLOW 

8 
Figure 3-3. Unit 4 Process Flow Diagram 

TANK FARM 

DIRECT INJECT 

HIGH 

BTU" 

LIQUIDS 

SOLIDS 

MAIN 

AUX. 

BULK. 

(ooocxx>i 

«• 

TANK FARM _ LOW 

BTU 

DIRECT INJECT „ LIQUIDS 

SURGE 

VENT 

KILN 

DRY" SCRUBBER 

S0LID5 ( DSS )| 

END DUMP 

EUER6ENCY 

STACK 

SECONDARY 

COMBUSTION 

CHAMBER 

TEMPERING 

CHAMBER 

ASH 

ROLL-OFF 

|BWER | 

;OMBUSTJOf| 

AIR 

BLOWERS 

SPRAY 

DRY 

ABSORBER 

I 

LIME 

PREPARATION 

SYSTEM 

^—— 

SPRAY 

DRY 

ABSORBER 

WET ASH DRY ASH 

OUMPSTfj? DU,V?STER DRY SCRUBBER 

SOLOS ( DSS ) 

END DUMP 

\ PRIMARY V 

/ FUEL f 

9 

DRY SCRUBBER 

[SOUDS ( DSS ) 

BHD DUMP 

BAGHOUSE 

CARBON 

INJECTION 

SYSTEM 

MAIN STACKSTAtK CAS 

DRY SCRUBBER 

SOLIDS :( DSS ) 

END DUMP 

_ v . Fuas/uQWD WASTE: FLOW 

—.—to . COMBUSTION AW ROW 

p~ STACK GAS ROW 

CXXCCO - ASH FLOW 

KJOOO* - SOUD WASTE FLOW 

.LIM E SLURRY FLOW 
4.0 Results of the Comprehensive Performance Test 

In August and September of 2008, Veolia conducted tests of Units 2, 3, and 4 required by 

the information collection requests from U.S. EPA Region 5 dated June 5, 2008 and September 

12, 2008. Those tests began on August 11, 2008 for Unit 2, August 5, 2008 for Unit 3, and 

August 21, 2008 for Unit 4 following test plans approved by U.S. EPA Region 5. Initial 

Comprehensive Performance Tests (CPTs) of Units 2, 3, and 4 commenced on December 8, 2009 

for Unit 2; on December 1, 2009 for Unit 3; and on December 16, 2009 for Unit 4, and were 

performed in accordance with Comprehensive Performance Test Plans approved by U.S. EPA 

Region 5. The HWC MACT, at 40 CFR § 63.1207(d), states "The date of commencement of the 

initial comprehensive performance test is the basis for establishing the deadline to commence the 

initial confirmatory performance test and the next comprehensive performance test. You may 

conduct performance testing at any time prior to the required date. The deadline for 

commencing subsequent confirmatory and comprehensive performance testing is based on the 

date of commencement of the previous comprehensive performance test." EPA Region 5 

considers that the start of the subsequent CPTs be based on the initiation of the metals tests 

performed in 2008, requiring that the subsequent CPT be started by September 5, 2013, and that 

a site-specific test plan be submitted before this date. Veolia originally submitted to EPA its 

notification of intent and site-specific test plans (i.e., comprehensive performance test plans) for 

all three units and a Quality Assurance Project Plan (QAPjP) for the subsequent CPT on 

September 5, 2012. Revisions to the CPT Plans and QAPjP were made based on negotiations with 

E PA Region 5. The CPT Plan and QAPjP dated September 25, 2013 were approved by EPA 

Region 5, and the subsequent CPT for Units 2, 3, and 4 was conducted in accordance with these 

plans. 

E PA Region 5 considers that testing of all three of the incinerators comprises the CPT for 

Veolia's facility in Sauget. Veolia Sauget started the CPT of the three incinerators at the Sauget 

facility on September 4, 2013 with the performance of the RAT A of the CO and 0 2 CEMS of 

Unit 4. Testing for the applicable parameters of the HWC MAC T including dioxins/furans, total 

hydrocarbons (THC), carbon monoxide (CO), particulate matter (PM), hydrogen 

chloride/chlorine gas (HCI/CI2), mercury, SVM, and LV M was completed on October 30, 2012. 

The HWC MACT, at §63.1207(d)(3), states that "you must complete the performance testing 

within 60 days after the date of commencement..." The subsequent CPT of the three 

incinerators at Veolia's Sauget facility began by the date required by EPA Region 5, and was 

completed within 60 days. 

10 
4.1 Test Protocol Summary 

A definition of the applicable emission limits and the resulting operating parameter limits 

(OPLs) are given in Section 4.0 of the CPT plans for each incinerator. The subsequent CPT of 

each of the incinerators included one test condition, and the test condition included one mode of 

operation. One set of OPLs was developed for each incinerator. 

In the first part of the test for each incinerator, Veolia demonstrated compliance with the 

particulate matter standard of the HWC MACT while the plant was operated to establish the 

maximum ash feedrate and maximum combustion gas flowrate OPLs as required by the HWC 

MAC T for the particulate matter standard. Compliance with the standard for carbon monoxide 

was also demonstrated during this portion of the test. 

In the second part of the test for each incinerator, Veolia demonstrated compliance, and 

developed OPLs, with the HC1/C12, dioxins/furans, THC, CO, LVM , SVM , and mercury 

standards of the HWC MACT while the plant was operated to establish maximum total 

hazardous waste feedrate, maximum pumpable hazardous waste feedrate, minimum primary 

combustion chamber (PCC) temperature, minimum secondary combustion chamber (SCC) 

temperature, maximum LVM , SVM , and Hg feedrates, maximum chlorine feedrate, maximum 

combustion gas flowrate, and maximum inlet temperature to the baghouse. Ash was fed to the 

incinerators at normal (or higher) levels during this portion of the test. Compliance with the 

standard for carbon monoxide was demonstrated during all testing. 

Samples of the wastes fed during the tests were sampled every 15 minutes and 

composited for analysis. Waste feed samples were collected in coordination with the PM, 

HCI/CI2, metals, and dioxins/furans stack testing. Composite liquid waste feed samples 

associated with each of the four sampling trains were analyzed for ash, total chlorine, heat content, 

moisture, density, and viscosity. The composite liquid waste feed samples collected during the 

Method 29 stack sampling from the second part of the test were also analyzed for metals (arsenic, 

beryllium, chromium, cadmium, lead, and mercury). Al l of the composite solid waste feed 

samples, containerized and bulk, from the first and second parts of the test were analyzed for total 

chlorine, ash, moisture, and heat content. The composite containerized waste feed samples for Units 

2, 3, and 4, and bulk solid waste feed samples from Unit 4, collected during the Method 29 stack 

sampling from the second part of the test were also analyzed for metals (arsenic, beryllium, 

chromium, cadmium, lead, and mercury). 

Chlorine and the metals lead, chromium and mercury were spiked into each of the three 

incinerators during, and throughout, the second part of each test run. 

Per 40 CFR §63.1206(b)(7)(i)(A) compliance with the DRE standard is required to be 

11 
demonstrated only one time and Veolia demonstrated DRE for each of the three incinerators in 

RCRA trial burns. The RCRA trial burn for Unit 2 was conducted in January 1993, and the 

RCRA trial burn for Unit 3 was conducted in November 1996. The RCRA trial burn for Unit 4 

was conducted in December 1995. Veolia did not re-demonstrate DRE in the subsequent CPT for 

the Final Replacement Standards of the HWC MACT because DRE, and the associated OPLs, 

were demonstrated during the RCRA trial burns, and operation of the incinerators has not 

significantly changed since those tests. The operating limits demonstrated with the standard for 

D RE in the RCR A Trial Burns of Units 2, 3, and 4 were considered in the development of OPLs 

for the incinerators. 

The OPLs associated with each of the applicable emission standards demonstrated 

during the subsequent CPT (i.e., PM, HCI/CI2 gas, metals, and dioxins/furans) were developed 

using process data taken during the collection of the applicable sampling train (i.e., EPA 

Method 5 for particulate matter, Modified EPA Method 26A for HC1/C12, EPA Method 29 for 

metals, and SW-846 Method 0023A for dioxins/furans). Operating parameter data were used as 

shown in Table 4-1 to develop HWC MACT OPLs. 

12 
Table 4-1. Data Used to Establish OPLs 

Demonstrated OPLs 

Emission 

Standard 

OPLs Developed During the 

CPT 

Demonstrated OPLs 

Emission 

Standard Unit 2 Unit 3 Unit 4 

Maximum Pumpable Waste Feedrate 

DRE 1993 1996 1995 

Maximum Pumpabl Pumpable Waste Feedrat Feedrate THC V 

Dioxins/Furans •/ • / 

Maximum Total Waste Feedrate 

DRE 1993 1996 1995 

Maximum Total Waste Feedrate THC Maximum •/ Total Waste Feedrate 

Dioxins/Furans •/ •/ VMaximum Stack Gas Flowrate 

SVM •/ 

Maximum Stack Gas Flowrate 

L V M •/ 

Maximum Stack Gas Flowrate 

PM • / •/ V 

Maximum Stack Gas Flowrate Hcyci Maximum 2 Stack Gas Flowrate 

DRE 1993 1996 1995 

Maximum Stack Gas Flowrate 

THC 

Maximum Stack Gas Flowrate 

Dioxins/Furans •/ •/ • 

Minimum Combustion Chamber Temperature in the PCC 

DRE 1993 1996 1995 

Minimum Combustion Chamber Temperature in the PCC THC Minimum •/ • / Combustion Chamber Temperature in the PCC 

Dioxins/Furans •/ S • / 

Minimum Combustion Chamber Temperature in the SCC 

DRE 1993 1996 1995 

Minimum Combustion Chamber Temperature in the SCC THC Minimum / Combustion Chamber Temperature in the SCC 

Dioxins/Furans • / V 

Maximum Total Feedrate of LV M (As, Be, Cr) L V M • / •/ 

Maximum Pumpable Feedrate of LV M (As, Be, Cr) L V M •/ 

Maximum Feedrate of SVM (Pb, Cd) SVM V V 

Maximum Feedrate of Mercury (Hg) Hg •/ 

Maximum Feedrate of Ash PM •/ • / 

Maximum Feedrate of Total Chlorine/Chloride 

HC1/C12 

s •/ 

Maximum Feedrate of Total Chlorine/Chloride L V M Maximum •/ Feedrate of Total Chlorine/Chloride 

SVM V 

Maximum Baghouse Inlet Temperature 

THC V • / 

Maximum Baghouse Inlet Temperature 

Dioxins/Furans •/ •/ 

Maximum Baghouse Inlet Temperature L V M V Maximum Baghouse Inlet Temperature 

SVM •/ •/ 

Minimum Carbon Feedrate 

Dioxins/Furans NA NA V 

Minimum Carbon Feedrate 

Hg NA NA </ 

Minimum Sorbent Feedrate HC1/C12 

•/ / •/ 

Minimum Carrier Fluid Flowrate HC1/C12 

• / •/ 

1993 - Operating data from the January 1993 RCRA Trial Burn for Unit 2. 

1996 - Operating data from the November 1996 RCRA Trial Burn for Unit 3. 

1995 - Operating data from the December 1995 RCRA Trial Burn for Unit 4. 

13 
4.2 Summary of Results 

Veolia successfully demonstrated compliance with all of the applicable regulatory 

requirements of the HWC MACT for Unit 2, Unit 3, and Unit 4 using the results from the single 

test condition of each unit. Table 4-2 summarizes the results of the emissions testing of Unit 2. 

Table 4-3 summarizes the results of the emissions testing of Unit 3, and Table 4-4 summarizes 

the results of the emissions testing of Unit 4. The test for each unit consisted of three reported 

runs for each parameter of interest. Al l reported results of the CPT are reported in the CPT 

Report. 

The term "test condition" refers to the sum of all the testing activities designed to 

demonstrate the operation of the waste incinerator under particular operating parameters (e.g., 

development of operating parameter limits) under the HWC MACT. The term "test run" refers to 

the replicate testing periods. A complete definition of the test protocol and methodology is 

defined in the CPT Plan and QAPjP. 

14 
Table 4-2. Unit 2 Compliance Summary 

Unit 2 

Parameter HWC MACT Limit Runl 

10-8-13 

Run 2 

10-9-13 

Run 3 

10-10-13 

Run 5 

10-30-13 

Average 

Particulate Matter - EPA Method 5 0.013 gr/dscf corrected to 7% 0 2 <0.00087 <0.00068 <0.00058 <0.00071 

HC1/C12 - Modified EPA Method 26A 32 ppmv dry, as CP, corrected to 7% 0 2 <29 <13 <18 <20 

Metals - EPA Method 29 

L V M 92 |xg/dscm corrected to 7% 0 2 <2.8 <2.4 <2.5 <2.6 

SVM 230 (xg/dscm corrected to 7% 0 2 <1.1 <0.78 <1.0 <0.95 

Mercury 130 (ig/dscm corrected to 7% 0 2 <90 <120 <95 <100 

Dioxins/Furans - SW-846 Method 0023A 0.20 ng/dscm corrected to 7% 0 2 0.00543 0.00624 0.0157 0.00912 

Total Hydrocarbons (THC)1 - EPA Method 25A 10 ppmv, dry corrected to 7% 0 2 1.6 0.18 0.49 0.75 

Carbon Monoxide (CO)1 100 ppmv, dry corrected to 7% 0 2 0.00 0.00 0.15 0.05 

THC and CO results collected during the stack sampling for dioxins/furans. 

15 
Table 4-3. Unit 3 Compliance Summary 

Unit 3 

Parameter HWC MACT Limit Runt 

10-15-13 

Run 2 

10-16-13 

Run 3 

10-17-13 

Run 4 

10-18-13 

Average 

Particulate Matter - EPA Method 5 0.013 gr/dscf corrected to 7% 0 2 0.00194 0.00202 0.00204 0.00200 

HC1/C12 - Modified EPA Method 26A 32 ppmv dry, as CP, corrected to 7% 0 2 <4.5 <4.4 <1.8 <3.6 

Metals - EPA Method 29 

L V M 92 ^ig/dscm corrected to 7% 0 2 <8.6 <8.9 <11 <9.4 

S VM 230 |xg/dscm corrected to 7% 0 2 <20 <14 <12 <15 

Mercury 130 u.g/dscm corrected to 7% 0 2 <59 <39 <46 <48 

Dioxins/Furans - SW-846 Method 0023A 0.20 ng/dscm corrected to 7% 0 2 0.00103 0.00115 0.00134 0.00118 

Total Hydrocarbons (THC)1 - EPA Method 25A 10 ppmv, dry corrected to 7% 0 2 0.44 0.26 0.57 0.43 

Carbon Monoxide (CO)1 100 ppmv, dry corrected to 7% 0 2 0.00 0.00 0.00 0.00 

1

 THC and CO results collected during the stack sampling for dioxins/furans. 

16 
Table 4-4. Unit 4 Compliance Summary 

Unit 4 

Parameter HWC MACT Limit Runt 

10-23-13 

Run 2 

10-24-13 

Run 3 

10-25-13 

Run 4 

10-25-13 

Average 

Particulate Matter - EPA Method 5 0.013 gr/dscf corrected to 7% 0 2 0.00269 0.00183 <0.0019 <0.0021 

HC1/C12 - Modified EPA Method 26A 32 ppmv dry, as CP, corrected to 7% 0 2 <11 <8.0 <23 <14 

Metals - EPA Method 29 

L V M 92 [xg/dscm corrected to 7% 0 2 <12 <9.8 <7.5 <9.7 

SVM 230 [xg/dscm corrected to 7% 0 2 <8.6 <4.5 <10 <7.8 

Mercury 130 ng/dscm corrected to 7% 0 2 <7.1 <8.1 <15 <10 

Dioxins/Furans - SW-846 Method 0023A 0.40 ng/dscm corrected to 7% Oz 0.138 0.132 0.139 0.137 

Total Hydrocarbons (THC)1 - EPA Method 25 A 10 ppmv, dry corrected to 7% 0 2 0.51 0.60 0.85 0.65 

Carbon Monoxide (CO)1 100 ppmv, dry corrected to 7% 0 2 0.07 0.06 0.08 0.07 

1

 THC and CO results collected during the stack sampling for dioxins/furans. 

17 
5.0 Operating Parameter Limits 

Table 5-1 and 5-2 present the operating parameter limits (OPLs) established for the three 

incinerators (i.e., Unit 2, Unit 3, and Unit 4) at the Veolia facility in Sauget, Illinois in 

compliance with the Final Replacement Standards of the HWC MACT. Unit 2 and Unit 3 are 

both Fixed Hearth Dual Chambered Incinerators. The two fixed hearth units are identical except 

that Unit 2 is equipped with four (4) baghouse modules, while Unit 3 is equipped with three (3) 

baghouse modules. However, each incinerator is operated identically with only three baghouse 

modules in service during operation. Unit 3 is a mirror image of Unit 2. Because Unit 2 and Unit 

3 are identical and are operated the same way, one set of OPLs for Unit 2 and Unit 3 are 

established for both units. The OPLs for Units 2 and 3 are established selecting the more 

conservative, or stringent, value developed for Unit 2 or Unit 3. Table 5-1 presents the OPLs 

established for Unit 2 and Unit 3. Table 5-2 presents the OPLs established for Unit 4. 

OPLs to comply with the Final Replacement Standards were developed based on data 

collected during the October 2013 CPT, and data for DRE from RCRA Trial Burns conducted 

in 1993 for Unit 2, 1996 for Unit 3, and 1995 for Unit 4. Also note that OPLs were developed, 

as appropriate, during the EPA Method 5 testing for PM, Modified EPA Method 26A for 

HC1/C12, EPA Method 29 for metals, and SW-846 Method 0023A for dioxins/furans of the 2013 

CPT for each of Unit 2, Unit, 3 and Unit 4. In those cases where an OPL is applicable to more 

than one standard, the OPL was established selecting the more, or most, stringent value (i.e., the 

lower, or lowest, value where the OPL is a maximum, and a higher, or highest, value where the 

OPL is a minimum) from these tests. Tables 5-1 and 5-2 present the source of the OPL. 

Tables 5-3 and 5-4 present the bases for development of the OPLs shown in Tables 5-1 

and 5-2. The data used to develop the OPLs are presented in Table 5-3 for Unit 2, Table 5-3 for 

Unit 3, and Table 5-4 for Unit 4 for each of the Final Replacement Standards of the HWC 

MACT. 

The CPT Plan, that included test plans for Unit 2, Unit 3, and Unit 4, presented an 

approach to extrapolate the feedrates of SVM , total and pumpable LVM , and mercury based on 

the SREs (System Removal Efficiencies) of lead, chromium, and mercury measured during the 

CPT. The OPLs for the feedrates of SVM , total and pumpable LVM , or mercury presented in 

this NOC do not include extrapolation of the feedrates of SVM , total and pumpable LVM , and 

mercury demonstrated, and measured, during the CPT. As presented in the CPT Plan, Veolia 

will have further discussions with EPA Region 5 before extrapolation is requested. Since 

extrapolation of metals feedrates is not being requested by this NOC, SREs for lead, chromium, 

and mercury are not in the CPT Report. 

18 
Table 5-1. HWC MACT Operating Parameter Limits for the 

Final Replacement Standards for Units 2 and 3 

Operating Parameter 

Permitting 

Units 

OPL Established 

From 

Operating Limit 

Maximum Feedrate of Total Mercury 12-HRA 2013 CPT 

Unit 2 Metals Test 

0.0021 lb/hr 

Maximum Total Feedrate of SVM (Pb, Cd) 12-HRA 2013 CPT 

Unit 2 Metals Test 

62 lb/hr 

Maximum Total Feedrate of LV M (As, Be, Cr) 12-HRA 2013 CPT 

Unit 3 Metals Test 

46 lb/hr 

Maximum Pumpable Feedrate of LVM (As, Be, Cr) 12-HRA 2013 CPT 

Unit 3 Metals Test 

46 lb/hr 

Maximum Feedrate of Total Chlorine/Chloride 12-HRA 2013 CPT 

Unit 3 Metals Test 

204 lb/hr 

Maximum Feedrate of Ash 12-HRA 2013 CPT 

Unit 2 PM Test 

503 lb/hr 

Minimum Combustion Chamber Temperature in the PCC HRA 

2013 CPT 

Unit 3 Dioxins/Furans 

Test 

1,709°F 

Minimum Combustion Chamber Temperature in the SCC HRA 

2013 CPT 

Unit 3 Dioxins/Furans 

Test 

1,885°F 

Maximum Flue Gas Flowrate HRA 2013 CPT 

Unit 3 PM Test 

15,310 acfm 

Maximum Total Hazardous Waste Feedrate HRA 1993 RCRA Trial Burn 

Unit 2 4,017 lb/hr 

Maximum Pumpable Hazardous Waste Feedrate HRA 1993 RCRA Trial Burn 

Unit 2 3,107 lb/hr 

Maximum Baghouse Inlet Temperature1 HRA 

2013 CPT 

Unit 2 and 3 

Dioxins/Furans and 

Metals Tests 

420°F 

Minimum Sorbent Feedrate HRA 2013 CPT 

Unit 2 HC1/C12 Test 

2.24 lb/lb C12 

Minimum Carrier Fluid Flowrate HRA 2013 CPT 

Unit 2 HC1/C12 Test 

1.90 gal/lb C12 

Emission Limit for Carbon Monoxide HRA 100 ppmv corrected 

to 7% Q2 

HRA - Hourly Rolling Average 

12-HRA - 12-Hour Rolling Average 

1

 Measured as the SDA (Spray Dryer/Absorber) Outlet Temperature. 

19 
Table 5-2. HWC MACT Operating Parameter Limits for the 

Final Replacement Standards for Unit 4 

Operating Parameter 

Permitting 

Units 

OPL Established 

From 

Operating Limit 

Maximum Feedrate of Total Mercury 12-HRA 2013 CPT 

Metals Test 

0.040 lb/hr 

Maximum Total Feedrate of SVM (Pb, Cd) 12-HRA 2013 CPT 

Metals Test 

621b/hr 

Maximum Total Feedrate of LV M (As, Be, Cr) 12-HRA 2013 CPT 

Metals Test 

46 lb/hr 

Maximum Pumpable Feedrate of LV M (As, Be, Cr) 12-HRA 2013 CPT 

Metals Test 

461b/hr 

Maximum Feedrate of Total Chlorine/Chloride 12-HRA 2013 CPT 

HC1/C12 Test 

203 lb/hr 

Maximum Feedrate of Ash 12-HRA 2013 CPT 

PM Test 4,777 lb/hr 

Minimum Combustion Chamber Temperature in the PCC HRA 2013 CPT 

Dioxins/Furans Test 

1,561°F 

Minimum Combustion Chamber Temperature in the SCC HRA 2013 CPT 

Dioxins/Furans Test 

1,881°F 

Maximum Flue Gas Flowrate HRA 2013 CPT 

HCl/Clz Test 

37,393 acfm 

Maximum Total Hazardous Waste Feedrate to the PCC HRA 2013 CPT 

Dioxins/Furans Test 

10,632 lb/hr 

Maximum Pumpable Hazardous Waste Feedrate to the PCC HRA 1995 RCRA Trial Burn 3,312 lb/hr 

Maximum Total (Pumpable) Hazardous Waste Feedrate to the SCC HRA 2013 CPT 

Dioxins/Furans Test 

1,203 lb/hr 

Maximum Baghouse Inlet Temperature1 HRA 

2013 CPT 

Dioxins/Furans and Metals 

Tests 

399°F 

Minimum Carbon Injection Feedrate HRA 

2013 CPT 

Dioxins/Furans and Metals 

Tests 

6.2 lb/hr 

Minimum Sorbent Feedrate HRA 2013 CPT 

HC1/C12 Test 

2.13 lb/lb C12 

Minimum Carrier Fluid Flowrate HRA 2013 CPT 

HC1/C12 Test 

3.10 gal/lb C12 

Emission Limit for Carbon Monoxide HRA 100 ppmv 

corrected to 7% 0 2 

HRA - Hourly Rolling Average 

12-HRA - 12-Hour Rolling Average 

1

 Measured as the SDA (Spray Dryer/Absorber) Outlet Temperature. 

20 
Table 5-3. Unit 2 Development of HWC MACT Operating Limits 

Operating Parameter 

Averaging 

Period Regulatory Basis 

HWC 

MACT 

Limit 

Measured Values 

Operating Parameter 

Averaging 

Period Regulatory Basis 

HWC 

MACT 

Limit 

1993 RCRA 

Trial Burn 

2013 CPT 

Destruction and Removal Efficiency 99.99% >99.99970% 1 

Minimum Combustion Chamber Temperature in 

the Primary Combustion Chamber 

HRA 

Average of the Test Run 

Averages 

[40 CFR 63 J209(i)(l)(ii)] 

1,658°F 

Minimum Combustion Chamber Temperature in 

the Secondary Combustion Chamber 

HRA 

Average of the Test Run 

Averages 

[40CFR63.1209G)(l)(ii)] 

1,848°F 

Maximum Flue Gas Flowrate HRA 

Average of the Test Run 

Maximum HRAs 

[40 CFR 63.1209(j)(2)(ii)] 

15,605 acfm 

Maximum Total Hazardous Waste Feedrate HRA 

Average of the Test Run 

Maximum HRAs 

[40CFR63.1209Cj)(3)(ii)] 

4,017 lb/hr 

Maximum Pumpable Hazardous Waste Feed HRA 

Average of the Test Run 

Maximum HRAs 

[40CFR63.1209(j)(3)(ii)] 

3,107 lb/hr 

Dioxins/Furans

 2 0.20 ng/dscm TEQs 

corrected to 7% 02 

0.00912 

Minimum Combustion Chamber Temperature in 

the Primary Combustion Chamber 

HRA 

Average of the Test Run 

Averages 

[40CFR63.1209(k)(2)(ii)] 

1,703°F 

Minimum Combustion Chamber Temperature in 

the Secondary Combustion Chamber 

HRA 

Average of the Test Run 

Averages 

[40 CFR63.1209(k)(2)(ii)] 

1,881°F 

Maximum Flue Gas Flowrate HRA 

Average of the Test Run 

Maximum HRAs 

[40CFR63.1209(k)(3)(i)] 

15,697 acfm 

Maximum Total Hazardous Waste Feedrate HRA 

Average of the Test Run 

Maximum HRAs 

[40CFR63.1209(k)(4)(ii)] 

4,430 lb/hr 

Maximum Pumpable Hazardous Waste Feed HRA 

Average of the Test Run 

Maximum HRAs 

[40 CFR 63.1209(k)(4)(ii)] 

3,518 lb/hr 

Maximum Baghouse Inlet Temperature3 HRA 

Average of the Test Run 

Maximum HRAs 

[40CFR63.1209(k)(l)(i)] 

420°F 

21 
Table 5-3. Unit 2 Development of HWC MACT Operating Limits (continued) 

Operating Parameter 

Averaging 

Period Regulatory Basis 

HWC 

MACT 

Limit 

Measured Values 

Operating Parameter 

Averaging 

Period Regulatory Basis 

HWC 

MACT 

Limit 

1993 RCRA 

Trial Burn 

2013 CPT 

Mercury

 2 130 ug/dscm 

corrected to 7% O 2 <100 

Maximum Feedrate of Total Mercury 12-HRA 

Average of the Test Run 

Averages 

[40 CFR 63.1209(0(1)] 

0.00212 lb/hr 

Particulate Matter

 2 0.013 grains/dscf 

corrected to 7% 02 

<0.00071 

Maximum Flue Gas Flowrate HRA 

Average of the Test Run 

Maximum HRAs 

[40 CFR 63.1209(m)(2)(i)] 

15,412 acfm 

Maximum Feedrate of Ash 12-HRA 

Average of the Test Run 

Averages 

[40CFR63.1209(m)(3)] 

503.0 lb/hr 

Semivolatile Metals - SVM (Pb, Cd)

 2 230 ug/dscm 

corrected to 7% 02 

<0.95 

Low Volatile Metals - LVM (As, Be, Cr) 2 92 ug/dscm 

corrected to 7% 02 

<2.6 

Maximum Total Feedrate of SVM (Pb, Cd) 12-HRA 

Average of the Test Run 

Averages 

[40 CFR 63.1209(n)(2)(i)(A)] 

61.9 lb/hr 

Maximum Total Feedrate of LV M 

(As, Be, Cr) 12-HRA 

Average of the Test Run 

Averages 

[40 CFR 63.1209(n)(2)(i)(B)] 

46.3 lb/hr 

Maximum Pumpable Feedrate of LV M 

(As, Be, Cr) 12-HRA 

Average of the Test Run 

Averages 

[40 CFR 63.1209(n)(2)(i)(C)] 

46.3 lb/hr 

Maximum Flue Gas Flowrate HRA 

Average of the Test Run 

Maximum HRAs 

[40CFR63.1209(n)(5)(i)] 

15,697 acfm 

Maximum Feedrate of Total Chlorine/Chloride 12-HRA 

Average of the Test Run 

Averages 

[40CFR63.1209(n)(4)] 

206.1 lb/hr 

Maximum Baghouse Inlet Temperature

 3 HRA 

Average of the Test Run 

Maximum HRAs 

[40CFR63.1209(n)(l)] 

420°F 

22 
Table 5-3. Unit 2 Development of HWC MACT Operating Limits (continued) 

Operating Parameter 

Averaging 

Period Regulatory Basis 

HWC 

MACT 

Limit 

Measured Values 

Operating Parameter 

Averaging 

Period Regulatory Basis 

HWC 

MACT 

Limit 

1993 RCRA 

Trial Burn 

2013 CPT 

Hydrochloric Acid and Chlorine Gas (HC1/C12)

 2 

32 ppmv combined as 

CI" equivalents, 

corrected to 7% 02 

<0.20 

Maximum Feedrate of Total Chlorine/Chloride 12-HRA 

Average of the Test Run 

Averages 

[40CFR63.1209(o)(l)] 

206.1 lb/hr 

Maximum Flue Gas Flow HRA 

Average of the Test Run 

Maximum HRAs 

[40CFR63.1209(o)(2)(i)] 

15,557 acfm 

Minimum Sorbent Feedrate HRA 

Average of the Test Run 

Averages 

[40CFR63.1209(o)(4)(i)] 

2.24 Lb/lb C12 

Minimum Carrier Fluid Flowrate HRA 

Average of the Test Run 

Averages 

[40CFR63.1209(o)(4)(ii)] 

1.90 Gal/lb C12 

Total Hydrocarbons (THC)

 4 10 ppmv corrected 

to 7% 02 

0.75 ppmv 

Carbon Monoxide (CO)

 4 100 ppmv corrected 

to 7% 02 

0.05 ppmv 

1

 Lowest value measured, for carbon tetrachloride and monochlorobenzene. All DREs determined to be >99.99%. DRE measured for the semivolatile 

POHC trichlorobenzene, and the volatile POHCs carbon tetrachloride and monochlorobenzene. Trichlorobenzene and monochlorobenzene are in 

Class 1 of the Thermal Stability Index; carbon tetrachloride is in Class 4. 

2

 Average value. 

3

 Measured as the SDA (Spray Dryer/Absorber) Outlet Temperature. 

4

 Average value second half of test. 

23 
Table 5-4. Unit 3 Development of HWC MACT Operating Limits 

Operating Parameter 

Averaging 

Period Regulatory Basis 

HWC 

MACT 

Limit 

Measured Values 

Operating Parameter 

Averaging 

Period Regulatory Basis 

HWC 

MACT 

Limit 

1996 RCRA 

Trial Burn 

2013 CPT 

Destruction and Removal Efficiency 99.99% >99.99983% 1 

Minimum Combustion Chamber Temperature 

in the Primary Combustion Chamber 

HRA 

Average of the Test Run 

Averages 

[40CFR63.1209())(l)(ii)] 

1,627°F 

Minimum Combustion Chamber Temperature 

in the Secondary Combustion Chamber 

HRA 

Average of the Test Run 

Averages 

[40CFR63.1209(i)(l)(ii)] 

1,845°F 

Maximum Flue Gas Flowrate HRA 

Average of the Test Run 

Maximum HRAs 

[40CFR63.1209(j)(2)(ii)] 

16,061 acfm 

Maximum Total Hazardous Waste Feedrate HRA 

Average of the Test Run 

Maximum HRAs 

[40 CFR 63T209(j)(3)(ii)] 

5,098 lb/hr 

Maximum Pumpable Hazardous Waste Feed HRA 

Average of the Test Run 

Maximum HRAs 

[40CFR63.1209(j)(3)(ii)] 

4,045 lb/hr 

Dioxins/Furans

 2 0.20 ng/dscm TEQs 

corrected to 7 % 02 

0.00118 

Minimum Combustion Chamber Temperature 

in the Primary Combustion Chamber 

HRA 

Average of the Test Run 

Averages 

[40CFR63.1209(k)(2)(ii)] 

1,709°F 

Minimum Combustion Chamber Temperature 

in the Secondary Combustion Chamber 

HRA 

Average of the Test Run 

Averages 

[40CFR63.1209(k)(2)(ii)] 

1,885°F 

Maximum Flue Gas Flowrate HRA 

Average of the Test Run 

Maximum HRAs 

[40CFR63.1209(k)(3)(i)] 

15,417 acfm 

Maximum Total Hazardous Waste Feedrate HRA 

Average of the Test Run 

Maximum HRAs 

[40 CFR 63.1209(k)(4)(ii)] 

4,410 Ib/hr 

Maximum Pumpable Hazardous Waste Feed HRA 

Average of the Test Run 

Maximum HRAs 

[40 CFR 63.1209(k)(4)(ii)] 

3,527 lb/hr 

Maximum Baghouse Inlet Temperature

 3 HRA 

Average of the Test Run 

Maximum HRAs 

[40CFR63.1209(k)(l)(i)] 

420°F 

24 
Table 5-4. Unit 3 Development of HWC MACT Operating Limits (continued) 

Operating Parameter 

Averaging 

Period Regulatory Basis 

HWC 

MACT 

Limit 

Measured Values 

Operating Parameter 

Averaging 

Period Regulatory Basis 

HWC 

MACT 

Limit 

1996 RCRA 

Trial Burn 

2013 CPT 

Mercury2 130 ug/dscm corrected 

to 7% 02 

<48 

Maximum Feedrate of Total Mercury 12-HRA 

Average of the Test Run 

Averages 

[40 CFR 63.12090X1)] 

0.00220 lb/hr 

Particulate Matter2 0.013 grains/dscf 

corrected to 7% 02 

0.00200 

Maximum Flue Gas Flowrate HRA 

Average of the Test Run 

Maximum HRAs 

[40CFR63.1209(m)(2)(i)] 

15,310 acfm 

Maximum Feedrate of Ash 12-HRA 

Average of the Test Run 

Averages 

[40 CFR 63.1209(m)(3)] 

525.8 lb/hr 

Semivolatile Metals - SVM (Pb, Cd)2 230 ug/dscm corrected 

to 7% 02 

<15 

Low Volatile Metals - LVM (As, Be, Cr)2 92 ug/dscm corrected 

to 7% 02 

<9.4 

Maximum Total Feedrate of SVM (Pb, Cd) 12-HRA 

Average of the Test Run 

Averages 

[40 CFR 63.1209(n)(2)(i)(A)] 

62.3 lb/hr 

Maximum Total Feedrate of LV M (As, Be, Cr) 12-HRA 

Average of the Test Run 

Averages 

[40 CFR 63.1209(n)(2)(i)(B)] 

46.1 lb/hr 

Maximum Pumpable Feedrate of LV M 

(As, Be, Cr) 12-HRA 

Average of the Test Run 

Averages 

[40 CFR 63.1209(n)(2)(i)(C)] 

46.0 lb/hr 

Maximum Hue Gas Flowrate HRA 

Average of the Test Run 

Maximum HRAs 

[40 CFR 63.1209(n)(5)(i)] 

15,417 acfm 

Maximum Feedrate of Total Chlorine/Chloride 12-HRA 

Average of the Test Run 

Averages 

[40CER63.1209(n)(4)] 

204.2 lb/hr 

Maximum Baghouse Inlet Temperature3 HRA 

Average of the Test Run 

Maximum HRAs 

[40CFR63.1209(n)(l)] 

420°F 

25 
Table 5-4. Unit 3 Development of HWC MACT Operating Limits (continued) 

Operating Parameter 

Averaging 

Period Regulatory Basis 

HWC 

MACT 

Limit 

Measured Values 

Operating Parameter 

Averaging 

Period Regulatory Basis 

HWC 

MACT 

Limit 

1996 RCRA 

Trial Burn 

2013 CPT 

Hydrochloric Acid and Chlorine Gas (HCI/C12)

2 

32 ppmv combined as CI" 

equivalents, corrected to 

7% 02 

<3.6 

Maximum Feedrate of Total Chlorine/Chloride 12-HRA 

Average of the Test Run 

Averages 

[40CFR63.1209(o)(l)] 

204.7 lb/hr 

Maximum Flue Gas Flow HRA 

Average of the Test Run 

Maximum HRAs 

[40CFR63.1209(o)(2)(i)] 

15,378 acfm 

Minimum Sorbent Feedrate HRA 

Average of the Test Run 

Averages 

[40CFR63.1209(o)(4)(i)] 

2.09 Lb/lb C12 

Minimum Carrier Fluid Flowrate HRA 

Average of the Test Run 

Averages 

[40CFR63.1209(o)(4)(ii)] 

1.84 Gal/lb C12 

Total Hydrocarbons (THC)3 10 ppmv corrected 

to 7% 02 

0.43 ppmv 

Carbon Monoxide (CO)3 100 ppmv corrected 

to 7% 02 

0.00 ppmv 

1

 Lowest value measured, for 1,2,3-trichlorobenzene. All DREs determined to be >99.99%. DRE measured for the semivolatile POHC 1,2,3-

trichlorobenzene, and the volatile POHCs carbon tetrachloride and tetrachloroethene. 1,2,3-Trichlorobenzene is not listed in the Thermal Stability 

Index, although 1,2,4 -trichlorobenzene and 1,3,5-trichlorobenzene are listed in Class 1. Tetrachloroethene is in Class 2 of the Thermal Stability 

Index; carbon tetrachloride is in Class 4. 

2

 Average value. 

3

 Measured as the SDA (Spray Dryer/Absorber) Outlet Temperature. 

4

 Average value second half of test. 

26 
Table 5-5. Unit 4 Development of HWC MACT Operating Limits 

Operating Parameter 

Averaging 

Period Regulatory Basis 

HWC 

MACT 

Limit 

Measured Values 

Operating Parameter 

Averaging 

Period Regulatory Basis 

HWC 

MACT 

Limit 

1995 RCRA 

Trial Burn 

2013 CPT 

Destruction and Removal Efficiency 99.99% >99.99981%' 

Minimum Combustion Chamber Temperature in the 

Primary Combustion Chamber 

HRA 

Average of the Test Run 

Averages 

[40 CFR 63.1209(j)(l)(ii)] 

1,415°F 

Mmimum Combustion Chamber Temperature in the 

Secondary Combustion Chamber 

HRA 

Average of the Test Run 

Averages 

[40 CFR 63.1209(j)(l)(ii)] 

1,798°F 

Maximum Flue Gas Flowrate HRA 

Average of the Test Run 

Maximum HRAs 

[40 CFR 63.1209(j)(2)(I)] 

44,900 acfm 

Maximum Total Hazardous Waste Feedrate to the 

Primary Combustion Chamber 

HRA 

Average of the Test Run 

Maximum HRAs 

[40CFR63.1209(j)(3)(ii)] 

18,667 lb/hr 

Maximum Pumpable Hazardous Waste Feedrate to 

the Primary Combustion Chamber 

HRA 

Average of the Test Run 

Maximum HRAs 

[40CFR63.1209(j)(3)(ii)] 

3,312 lb/hr 

Maximum Total (Pumpable) Hazardous Waste Feed 

to the Secondary Combustion Chamber 

HRA 

Average of the Test Run 

Maximum HRAs 

[40 CFR 63.12O90(3)(ii)] 

1,788 lb/hr 

27 
Table 5-5. Unit 4 Development of HWC MACT Operating Limits (continued) 

Operating Parameter 

Averaging 

Period Regulatory Basis 

HWC 

MACT 

Limit 

Measured Values 

Operating Parameter 

Averaging 

Period Regulatory Basis 

HWC 

MACT 

Limit 

1995 RCRA 

Trial Burn 

2013 CPT 

Dioxins/Furans2 0.40 ng/dscm TEQs 

corrected to 7% 02 

0.137 

Minimum Combustion Chamber Temperature in the 

Kiln 

HRA 

Average of the Test Run 

Averages 

[40 CFR 63.1209(k)(2)(ii)] 

1,561°F 

Minimum Combustion Chamber Temperature in the 

SCC HRA 

Average of the Test Run 

Averages 

[40 CFR 63.1209(k)(2)(ii)] 

1,881°F 

Maximum Flue Gas Flowrate HRA 

Average of the Test Run 

Maximum HRAs 

[40CFR63.1209(k)(3)(i)] 

37,869 acfm 

Maximum Total Hazardous Waste Feedrate to the 

Primary Combustion Chamber 

HRA 

Average of the Test Run 

Maximum HRAs 

[40CFR63.1209(k)(4)(ii)] 

10,632 lb/hr 

Maximum Pumpable Hazardous Waste Feedrate to 

the Primary Combustion Chamber 

HRA 

Average of the Test Run 

Maximum HRAs 

[40 CFR 63.1209(k)(4)(ii)] 

3,468 lb/hr 

Maximum Total (Pumpable) Hazardous Waste Feed 

to the Secondary Combustion Chamber 

HRA 

Average of the Test Run 

Maximum HRAs 

[40 CFR 63.1209(k)(4)(ii)] 

1,203 lb/hr 

Maximum Baghouse Inlet Temperature3 HRA 

Average of the Test Run 

Maximum HRAs 

[40CFR63.1209(k)(l)(i)] 

399°F 

Minimum Carbon Feedrate HRA 

Average of the Test Run 

Maximum HRAs 

[40 CFR 63.1209(k)(6)(i)] 

6.2 lb/hr 

Mercury2 130 ug/dscm corrected 

to 7% 02 

<10 

Maximum Feedrate of Total Mercury 12-HRA 

Average of the Test Run 

Averages 

[40 CFR 63.1209(1X1)] 

0.0401 lb/hr 

Minimum Carbon Feedrate HRA 

Average of the Test Run 

Maximum HRAs 

[40 CFR 63.1209(1)(3)] 

6.2 lb/hr 

28 
Table 5-5. Unit 4 Development of HWC MACT Operating Limits (continued) 

Operating Parameter 

Averaging 

Period Regulatory Basis 

HWC 

MACT 

Limit 

Measured Values 

Operating Parameter 

Averaging 

Period Regulatory Basis 

HWC 

MACT 

Limit 

1995 RCRA 

Trial Burn 

2013 CPT 

Particulate Matter2 0.013 grains/dscf 

corrected to 7% 02 

<0.0021 

Maximum Flue Gas Flowrate HRA 

Average of the Test Run 

Maximum HRAs 

[40CFR63.1209(m)(2)(i)] 

37,800 acfm 

Maximum Feedrate of Ash 12-HRA 

Average of the Test Run 

Averages 

[40CFR63.1209(m)(3)] 

4,777 lb/hr 

Semivolatile Metals - SVM (Pb, Cd)

 2 230 ug/dscm corrected 

to 7% 02 

<7.8 

Low Volatile Metals - LVM (As, Be, Cr)2 92 ug/dscm corrected 

to 7% 02 

<9.7 

Maximum Total Feedrate of SVM (Pb, Cd) 12-HRA 

Average of the Test Run 

Averages 

[40 CFR 

63.1209(n)(2)(i)(A)] 

62.0 lb/hr 

Maximum Total Feedrate of LV M 

(As, Be, Cr) 12-HRA 

Average of the Test Run 

Averages 

[40 CFR 

63.1209(n)(2)(i)(B)] 

46.2 lb/hr 

Maximum Pumpable Feedrate of LV M 

(As, Be, Cr) 12-HRA 

Average of the Test Run 

Averages 

[40 CFR 

63.1209(n)(2)(i)(C)] 

45.9 lb/hr 

Maximum Flue Gas Flowrate HRA 

Average of the Test Run 

Maximum HRAs 

[40 CFR 63.1209(n)(5)(i)] 

37,869 acfm 

Maximum Feedrate of Total Chlorine/Chloride 12-HRA 

Average of the Test Run 

Averages 

[40CFR63.1209(n)(4)] 

205.0 lb/hr 

Maximum Baghouse Inlet Temperature3 HRA 

Average of the Test Run 

Maximum HRAs 

[40CFR63.1209(n)(l)] 

399°F 

29 
Table 5-5. Unit 4 Development of HWC MACT Operating Limits (continued) 

Operating Parameter 

Averaging 

Period Regulatory Basis 

HWC 

MACT 

Limit 

Measured Values 

Operating Parameter 

Averaging 

Period Regulatory Basis 

HWC 

MACT 

Limit 

1995 RCRA 

Trial Burn 

2013 CPT 

Hydrochloric Acid and Chlorine Gas (HCI/C12)

2 

32 ppmv combined as CI" 

equivalents, corrected to 

7% 02 

<14 

Maximum Feedrate of Total Chlorine/Chloride 12-HRA 

Average of the Test Run 

Averages 

[40CFR63.1209(o)(l)] 

203.2 lb/hr 

Maximum Flue Gas Flow HRA 

Average of the Test Run 

Maximum HRAs 

[40CFR63.1209(o)(2)(i)] 

37,393 acfm 

Minimum Sorbent Feedrate HRA 

Average of the Test Run 

Averages 

[40CFR63.1209(o)(4)(i)] 

2.13 Lb/lb C12 

Minimum Carrier Fluid Flowrate HRA 

Average of the Test Run 

Averages 

[40 CFR 

63.1209(o)(4)(ii)] 

3.10 Gal/lb C12 

Total Hydrocarbons (THC)4 10 ppmv corrected 

to 7% 02 

0.65 ppmv 

Carbon Monoxide (CO)

 4 100 ppmv corrected 

to 7% 02 

0.07 ppmv 

1

 Lowest value measured, for hexachloroethane. Lowest DRE measured for monochlorobenzene was >99.99983%. All DREs determined to be >99.99%. 

DRE measured for the semivolatile POHCs naphthalene and hexachloroethane, and the volatile POHC monochlorobenzene. Naphthalene and 

monochlorobenzene are listed in Class 1 of the Thermal Stability Index. Hexachloroethane is listed in Class 5 of the Thermal Stability Index Index. 

2

 Average value. 

3

 Measured as the SDA (Spray Dryer/Absorber) Outlet Temperature. 

4

 Average value second half of test. 

30 
6.0 Bases for Establishment of OPLs 

The HWC MACT has standards for eight emission limits and for destruction and removal 

efficiency (DRE). In association with each of these standards, the HWC MACT requires that 

feedrate limits and/or operating parameter limits (OPLs) be established for the combustion 

systems and/or for air pollution control equipment. The operation of the unit within the feedrate 

limits and OPLs will ensure that the standards of the HWC MACT are being continuously 

achieved. Listed below are the HWC MACT limits and the feedrate and OPLs required for each 

standard. For each feedrate limit or OPL, an explanation is provided for the establishment of the 

feedrate limit or OPL. As stated in 40 CFR 63.12090), if an operating parameter is applicable to 

multiple standards then the most stringent limit applies. 

• DRE - 40 CFR 63.1209(j) 

Compliance with the standard for destruction and removal efficiency (DRE) was 

demonstrated using data from RCRA Trial Burns conducted in 1993 for Unit 2, 1996 

for Unit 3, and 1995 for Unit 4. Applicable feedrates and OPLs associated with this 

standard are established using data from these trial burns. 

Units 2 and 3 

Minimum Combustion Chamber Temperature in the PCC - 40 CFR 63.1209(j)(l) 

Minimum combustion chamber temperature in the PCC was developed during the 1993 RCR A 

Trial Burn for Unit 2, 1996 RCRA Trial Burn for Unit 3, the 2013 CPT for Unit 2, and the 2013 

CPT of Unit 3. The OPL for minimum combustion chamber temperature in the PCC was 

established from the most stringent value of these tests, during the dioxins/furans testing of the 

2013 CPT of Unit 3. 

Minimum Combustion Chamber Temperature in the SCC - 40 CFR 63.1209(j)(l) 

Minimum combustion chamber temperature in the SCC was developed during the 1993 RCR A 

Trial Burn for Unit 2, the 1996 RCR A Trial Burn for Unit 3, the 2013 CPT for Unit 2, and the 

2013 CPT of Unit 3. The OPL for minimum combustion chamber temperature in the SCC was 

established from the most stringent value of these tests, during the dioxins/furans testing of the 

2013 CPT of Unit 3. 

Maximum Flue Gas Flowrate or Production Rate - 40 CFR 63.1209(j)(2) 

Flue gas flowrate, as stack gas flowrate, is monitored continuously by an Annubar. 

The OPL for maximum flue gas flowrate in association with the standard for DRE was developed 

during the 1993 RCR A Trial Burn for Unit 2 and the 1996 RCR A Trial Burn for Unit 3. During 

the 2013 CPT for Units 2 and 3, the OPL for maximum flue gas flowrate was developed in 

association with the standards for PM , HC1/C12, SVM , LVM , Mercury, and Dioxins/Furans. The 

OPL for maximum flue gas flowrate was established from the most stringent value of these tests, 

during the P M testing of the 2013 CPT of Unit 3. 

Maximum Total Hazardous Waste Feedrate to the PCC - 40 CFR 63.1209(j)(3) 

Units 2 and 3 feed both pumpable and nonpumpable hazardous wastes to the PCC. The OPL for 

maximum total hazardous waste feedrate to the PCC is based on the combined measured 

nonpumpable and pumpable waste feedrates to the PCC during the 1993 RCR A Trial Burn for 

Unit 2, 1996 RCRA Trial Burn for Unit 3, the 2013 CPT for Unit 2, and the 2013 CPT of Unit 3. 

31 
The OPL for maximum hazardous waste feedrate to the PCC was established from the most 

stringent value of these tests, during the 1993 RCRA Trial Burn of Unit 2. 

Maximum Pumpable Hazardous Waste Feedrate to the PCC - 40 CFR 63.1209(j)(3) 

Units 2 and 3 feed both pumpable and nonpumpable hazardous wastes to the PCC. The OPL for 

maximum pumpable hazardous waste feedrate to the PCC is based on the pumpable waste feedrate 

to the PCC during the 1993 RCR A Trial Burn for Unit 2, 1996 RCR A Trial Burn for Unit 3, the 

2013 CPT for Unit 2, and the 2013 CPT of Unit 3. The OPL for maximum pumpable hazardous 

waste feedrate to the PCC was established from the most stringent value of these tests, during the 

1993 RCRA Trial Bum of Unit 2. 

Unit 4 

Minimum Combustion Chamber Temperature in the PCC (Kiln) - 40 CFR 63.1209(j)(l) 

Minimum combustion chamber temperature in the PCC was developed during the 1995 RCRA 

Trial Bum and the 2013 CPT of Unit 4. The OPL for minimum combustion chamber temperature 

in the PCC was established from the most stringent value of these tests, during the dioxins/furans 

testing of the 2013 CPT of Unit 4. 

Minimum Combustion Chamber Temperature in the SCC - 40 CFR 63.1209fj)(l) 

Minimum combustion chamber temperature in the SCC was developed during the 1995 RCR A 

Trial Bum and the 2013 CPT of Unit 4. The OPL for minimum combustion chamber temperature 

in the SCC was established from the most stringent value of these tests, during the dioxins/furans 

testing of the 2013 CPT of Unit 4. 

Maximum Flue Gas Flowrate or Production Rate - 40 CFR 63.1209(j)(2) 

Flue gas flowrate, as stack gas flowrate, is monitored continuously by an Annubar. 

The OPL for maximum flue gas flowrate in association with the standard for DRE was developed 

during the 1995 RCR A Trial Bum. During the 2013 CPT for Unit 4, the OPL for maximum flue 

gas flowrate was developed in association with the standards for PM , HC1/C12, SVM , LVM , 

Mercury, and Dioxins/Furans. The OPL for maximum flue gas flowrate was established from the 

most stringent value of these tests, during the HCl/CL testing of the 2013 CPT of Unit 4. 

Maximum Total Hazardous Waste Feedrate to the PCC (Kiln) - 40 CFR 63.1209(j)(3) 

Unit 4 feeds both pumpable and nonpumpable hazardous wastes to the PCC (Kiln). The OPL for 

maximum total hazardous waste feedrate to the PCC is based on the combined measured 

nonpumpable and pumpable waste feedrates to the PCC during the 1995 RCR A Trial Bum and the 

2013 CPT of Unit 4. The OPL for maximum total hazardous waste feedrate to the PCC was 

established during the dioxins/furans testing of the 2013 CPT of Unit 4. 

Maximum Pumpable Hazardous Waste Feedrate to the PCC (Kiln) - 40 CFR 63.1209(j)(3) 

Unit 4 feeds both pumpable and nonpumpable hazardous wastes to the PCC. The OPL for 

maximum pumpable hazardous waste feedrate to the PCC is based on the nonpumpable and 

pumpable waste feedrate to the PCC during the during the 1995 RCR A Trial Bum and the 2013 

CPT of Unit 4. The OPL for maximum pumpable hazardous waste feedrate to the PCC was 

established during the 1995 RCR A Trial Bum of Unit 4. 

Maximum Total (Pumpable) Hazardous Waste Feedrate to the SCC - 40 CFR 63.1209(j)(3) 

Unit 4 feeds pumpable hazardous wastes to the SCC. The OPL for maximum pumpable hazardous 

waste feedrate to the SCC is based on the pumpable waste feedrate to the SCC during the 1995 

RCRA Trial Bum and the 2013 CPT of Unit 4. The OPL for maximum pumpable hazardous waste 

feedrate to the SCC was established during the dioxins/furans testing of the 2013 CPT of Unit 4. 

32 
• Dioxins and Furans - 40 CFR 63.1209(k) 

Compliance with the standard for dioxins and furans was demonstrated during the 

2013 CPT. Applicable feedrates and OPLs associated with this standard are 

established from the 2013 CPT. 

Units 2 and 3 

Gas Temperature at the Inlet to a Dry Particulate Matter Control Device — 40 CFR 63.1209(k)(l) 

The dry particulate matter control devices on Units 2 and 3 are baghouses. The temperature to the 

inlet of the baghouse is measured as the SDA (Spray Dryer/Absorber) Outlet Temperature, and 

was developed during the 2013 CPT for Units 2 and 3 in association with the standards for 

Dioxins/Furans and Metals. The OPL for maximum baghouse inlet temperature was established 

during the dioxins/furans and metals testing of the 2013 CPT of Units 2 and 3. 

Minimum Combustion Chamber Temperature in the PCC - 40 CFR 63.1209(k)(2) 

Minimum combustion chamber temperature in the PCC was developed during the 2013 CPT for 

Unit 2 and the 2013 CPT of Unit 3 in association with the standard for Dioxins and Furans. The 

OPL for minimum combustion chamber temperature in the PCC was established from the most 

stringent value of these tests, during the dioxins/furans testing of the 2013 CPT of Unit 3. 

Minimum Combustion Chamber Temperature in the SCC - 40 CFR 63.1209(k)(2) 

Minimum combustion chamber temperature in the SCC was developed during the 2013 CPT for 

Unit 2 and the 2013 CPT of Unit 3 in association with the standard for Dioxins and Furans. The 

OPL for minimum combustion chamber temperature in the SCC was established from the most 

stringent value of these tests, during the dioxins/furans testing of the 2013 CPT of Unit 3. 

Maximum Flue Gas Flowrate or Production Rate - 40 CFR 63.1209(k)(3) 

Flue gas flowrate, as stack gas flowrate, is monitored continuously by an Annubar. 

The OPL for maximum flue gas flowrate in association with the standard for DRE was developed 

during the 1993 RCR A Trial Burn for Unit 2 and the 1996 RCR A Trial Burn for Unit 3. During 

the 2013 CPT for Units 2 and 3, the OPL for maximum flue gas flowrate was developed in 

association with the standards for PM , HC1/C12, SVM , LVM , Mercury, and Dioxins/Furans. The 

OPL for maximum flue gas flowrate was established from the most stringent value of these tests, 

during the P M testing of the 2013 CPT of Unit 3. 

Maximum Total Hazardous Waste Feedrate to the PCC - 40 CFR 63.1209(k)(4) 

Units 2 and 3 feed both pumpable and nonpumpable hazardous wastes to the PCC. The OPL for 

maximum total hazardous waste feedrate to the PCC is based on the combined measured 

nonpumpable and pumpable waste feedrates to the PCC during the 1993 RCR A Trial Burn for 

Unit 2,1996 RCRA Trial Burn for Unit 3, the 2013 CPT for Unit 2, and the 2013 CPT of Unit 3. 

The OPL for maximum hazardous waste feedrate to the PCC was developed in association with 

the standard for Dioxins and Furans during the 2013 CPT for Unit 2 and the 2013 CPT of Unit 3. 

The OPL for maximum hazardous waste feedrate to the PCC was established from the most 

stringent value of these tests, during the 1993 RCRA Trial Burn of Unit 2. 

Maximum Pumpable Hazardous Waste Feedrate to the PCC - 40 CFR 63.1209(k)(4) 

Units 2 and 3 feed both pumpable and nonpumpable hazardous wastes to the PCC. The OPL for 

maximum pumpable hazardous waste feedrate to the PCC is based on the pumpable waste feedrate 

to the PCC during the 1993 RCR A Trial Burn for Unit 2, 1996 RCR A Trial Burn for Unit 3, the 

2013 CPT for Unit 2, and the 2013 CPT of Unit 3. The OPL for maximum pumpable waste 

feedrate to the PCC was developed in association with the standard for Dioxins and Furans during 

the 2013 CPT for Unit 2 and the 2013 CPT of Unit 3. The OPL for maximum pumpable hazardous 

waste feedrate to the PCC was established from the most stringent value of these tests, during the 

1993 RCRA Trial Burn of Unit 2. 

33 
Particulate Matter Operating Limit - 40 CFR 63.1209(k)(5) 

Not applicable. This OPL is only applicable if the incinerator is equipped with an activated carbon 

injection system. Carbon is not injected into Units 2 and 3. 

Activated Carbon Injection Parameter Limits - 40 CFR 63.1209(k)(6) 

Not applicable. There is no carbon injection system on Units 2 and 3. 

Carbon Bed Parameter Limits - 40 CFR 63.1209(k)(7) 

Not applicable. There is not a carbon bed on the incinerators at Sauget. 

Catalytic Oxidizer Parameter Limits - 40 CFR 63.1209(k)(8) 

Not applicable. There is not a catalytic oxidizer on the incinerators at Sauget. 

Unit 4 

Gas Temperature at the Inlet to a Dry Particulate Matter Control Device - 40 CFR 63.1209(k)(l) 

The dry particulate matter control device on Unit 4 is a baghouse. The temperature to the inlet of 

the baghouse is measured as the SDA (Spray Dryer/Absorber) Outlet Temperature, and was 

developed during the 2013 CPT for Unit 4 in association with the standards for Dioxins/Furans 

and Metals. The OPL for maximum baghouse inlet temperature was established during the 

dioxins/furans and metals testing of the 2013 CPT of Unit 4. 

Minimum Combustion Chamber Temperature in the PCC (Kiln) - 40 CFR 63.1209(k)(2) 

Minimum combustion chamber temperature in the PCC - the kiln - was developed during the 

2013 CPT for Unit 4 in association with the standard for Dioxins and Furans, and in the 1995 

RCR A Trial Burn of Unit 4 for DRE. The OPL for minimum combustion chamber temperature in 

the PCC was established from the most stringent value of these tests, during the dioxins/furans 

testing of the 2013 CPT of Unit 4. 

Minimum Combustion Chamber Temperature in the SCC - 40 CFR 63.1209(k)(2) 

Minimum combustion chamber temperature in the SCC was developed during the 2013 CPT for 

Unit 4 in association with the standard for Dioxins and Furans, and in the 1995 RCRA Trial Burn 

of Unit 4 for DRE. The OPL for minimum combustion chamber temperature in the SCC was 

established from the most stringent value of these tests, during the dioxins/furans testing of the 

2013 CPT of Unit 4. 

Maximum Flue Gas Flowrate or Production Rate - 40 CFR 63.1209(k)(3) 

Flue gas flowrate, as stack gas flowrate, is monitored continuously by an Annubar. The OPL for 

maximum flue gas flowrate in association with the standard for DRE was developed during the 

1995 RCRA Trial Burn for Unit 4. During the 2013 CPT for Unit 4, the OPL for maximum flue 

gas flowrate was developed in association with the standards for PM , HC1/C12, SVM , LVM , 

Mercury, and Dioxins/Furans. The OPL for maximum flue gas flowrate was established from the 

most stringent value of these tests, during the HC1/C12 testing of the 2013 CPT of Unit 4. 

Maximum Total Hazardous Waste Feedrate to the PCC (Kiln) - 40 CFR 63.1209(k)(4) 

Unit 4 feeds both pumpable and nonpumpable hazardous wastes to the PCC. The OPL for 

maximum total hazardous waste feedrate to the PCC is based on the combined measured 

nonpumpable and pumpable waste feedrates to the PCC. The OPL for maximum hazardous waste 

feedrate to the PCC was developed in association with the standard for Dioxins and Furans during 

the 2013 CPT for Unit 4, and in the 1995 RCRA Trial Burn of Unit 4 for DRE. The OPL for 

maximum hazardous waste feedrate to the PCC was established from the most stringent value of 

these tests, during the dioxins/furans testing of the 2013 CPT of Unit 4. 

Maximum Pumpable Hazardous Waste Feedrate to the PCC (Kiln) - 40 CFR 63.1209(k)(4) 

Unit 4 feeds both pumpable and nonpumpable hazardous wastes to the PCC - the kiln. The OPL 

for maximum pumpable hazardous waste feedrate to the PCC is based on the pumpable waste 

34 
feedrate to the PCC during the 1995 RCRA Trial Burn for Unit 2 and the 2013 CPT for Unit 4. 

The OPL for maximum pumpable waste feedrate to the PCC was developed in association with 

the standard for Dioxins and Furans during the 2013 CPT for Unit 4 and the 1995 RCRA Trial 

Burn of Unit 4 for DRE. The OPL for maximum pumpable hazardous waste feedrate to the PCC 

was established from the most stringent value of these tests, during the 1995 RCR A Trial Burn of 

Unit 4. 

Maximum Total (Pumpable) Hazardous Waste Feedrate to the SCC - 40 CFR 63.1209(j)(3) 

Unit 4 feeds pumpable hazardous wastes to the SCC. The OPL for maximum pumpable hazardous 

waste feedrate to the SCC is based on the pumpable waste feedrate to the SCC during the 1995 

RCRA Trial Burn and the 2013 CPT of Unit 4. The OPL for maximum pumpable hazardous waste 

feedrate to the SCC was established during the dioxins/furans testing of the 2013 CPT of Unit 4. 

Particulate Matter Operating Limit - 40 CFR 63.1209(k)(5) 

The particulate matter control device on Unit 4 is a baghouse, and there are no OPLs for 

baghouses required by the HWC MACT . 

Activated Carbon Injection - 40 CFR 63.1209(k)(6) 

Carbon is injected into the baghouse on Unit 4. The minimum carbon feedrate was developed in 

association with the standard for Dioxins and Furans and the standard for Mercury during the 2013 

CPT for Unit 4. The OPL for minimum carbon feedrate was established during the dioxins/furans 

and metals testing of the 2013 CPT of Unit 4. 

Carbon Bed Parameter Limits - 40 CFR 63.1209(k)(7) 

Not applicable. There is not a carbon bed on the incinerators at Sauget. 

Catalytic Oxidizer Parameter Limits - 40 CFR 63.1209(k)(8) 

Not applicable. There is not a catalytic oxidizer on the incinerators at Sauget. 

• Total Hydrocarbons - 40 CFR 63.1209(a)(7) 

Compliance with the total hydrocarbons standard was demonstrated during the 2013 

CPT. Applicable feedrates and OPLs associated with this standard are the same as for 

D RE and dioxins/furans. 

• Mercury - 40 CFR 63.1209(1) 

Compliance with the standard for mercury was demonstrated during the 2013 CPT. 

Applicable feedrates and OPLs associated with this standard are established from the 

2013 CPT. 

Units 2 and 3 

Maximum Feedrate of Total Mercury - 40 CFR 63.1209(1)(1) 

The maximum feedrate of mercury was developed during the 2013 CPT of Units 2 and 3. The 

total feedrate of Mercury includes the spiking rates and the contribution of mercury with the 

waste streams - both pumpable and nonpumpable, and was established during the metals testing of 

the 2013 CPT of Unit 2. 

The feedrate for mercury has not been extrapolated. 

Wet Scrubber - 40 CFR 63.1209(1)(2) 

Not applicable. There is not a wet scrubber on the incinerators at Sauget. 

35 
Minimum Pressure Drop Across a High Energy Scrubber - 40 CFR 63.1209(1)(2) and 40 CFR 

63.1209(0)(3)(i) 

Not applicable. There is not a high energy scrubber on the incinerators at Sauget. 

Minimum Pressure Drop for Low Energy Scrubber - 40 CFR 63.1209(1)(2) and 40 CFR 

63.1209(o)(3)0i) 

Not applicable. There is not a low energy scrubber on the incinerators at Sauget. 

Minimum Liquid Feed Pressure for Low Energy Scrubber - 40 CFR 63.1209(1)(2) and 40 CFR 

63.1209(o)(3)(iii) 

Not applicable. There is not a high energy scrubber on the incinerators at Sauget. 

Minimum Liquid to Gas Ratio - 40 CFR 63.12090X2) and 40 CFR 63.1209(o)(3)(v) 

Not applicable. There is not a wet scrubber on the incinerators at Sauget. 

Activated Carbon Injection - 40 CFR 63.1209(1)(3) 

Not applicable. There is no carbon injection system on Units 2 and 3. 

Activated Carbon Bed - 40 CFR 63.12090X4) 

Not applicable. There is not a carbon bed on the incinerators at Sauget. 

Catalytic Oxidizer Parameter Limits - 40 CFR 63.1209(k)(8) 

Not applicable. There is not a catalytic oxidizer on the incinerators at Sauget. 

Unit 4 

Maximum Feedrate of Total Mercury - 40 CFR 63.12090X1) 

The maximum feedrate of mercury was developed during the 2013 CPT of Unit 4. The total 

feedrate of Mercury includes the spiking rates and the contribution of mercury with the waste 

streams - both pumpable and nonpumpable, and was established during the metals testing of the 

2013 CPT of Unit 4. 

The feedrate for mercury has not been extrapolated. 

Wet Scrubber - 40 CFR 63.1209(1X2) 

Not applicable. There is not a wet scrubber on the incinerators at Sauget. 

Minimum Pressure Drop Across a High Energy Scrubber - 40 CFR 63.12090X2) and 40 CFR 

63.1209(0)(3)(i) 

Not applicable. There is not a high energy scrubber on the incinerators at Sauget. 

Minimum Pressure Drop for Low Energy Scrubber - 40 CFR 63.1209(1)(2) and 40 CFR 

63.1209(o)(3)(ii) 

Not applicable. There is not a low energy scrubber on the incinerators at Sauget. 

Minimum Liquid Feed Pressure for Low Energy Scrubber - 40 CFR 63.12090X2) and 40 CFR 

63.1209(o)(3)(iii) 

Not applicable. There is not a low energy scrubber on the incinerators at Sauget. 

Minimum Liquid to Gas Ratio - 40 CFR 63.1209(1)(2) and 40 CFR 63.1209(o)(3)(v) 

Not applicable. There is not a wet scrubber on the incinerators at Sauget. 

Activated Carbon Injection - 40 CFR 63.1209(1)(3) 

Carbon is injected into the baghouse on Unit 4. The OPL for minimum carbon feedrate was 

developed in association with the standard for Dioxins and Furans and the standard for Mercury 

36 
during the 2013 CPT for Unit 4. The OPL for minimum carbon feedrate was established during 

the dioxins/furans and metals testing of the 2013 CPT of Unit 4. 

Activated Carbon Bed - 40 CFR 63.1209(1)(4) 

Not applicable. There is not a carbon bed on the incinerators at Sauget. 

Catalytic Oxidizer Parameter Limits - 40 CFR 63.1209(k)(8) 

Not applicable. There is not a catalytic oxidizer on the incinerators at Sauget. 

• Particulate Matter - 40 CFR 63.1209(m) 

Compliance with the standard for particulate matter was demonstrated during the 

2013 CPT. Applicable feedrates and OPLs associated with this standard are 

established from the 2013 CPT. 

Control Device Operating Parameter Limits - 40 CFR 63.1209(m)(l) 

The HWC MAC T prescribes OPLs for high energy scrubbers and wet scrubbers used to control 

particulate matter (and metals). There is no high energy scrubber or wet scrubbers on the 

incinerators at Sauget used for control of particulate matter. The control devices on the 

incinerators at Sauget that are designed and operated to control particulate matter (and metals) are 

baghouses, and the HWC MAC T has no OPLs for baghouses. 

Minimum Pressure Drop Across a High Energy Scrubber - 40 CFR 63.1209(m)(l)(i)(A) 

Not applicable. There are no high energy scrubbers on the incinerators at Sauget. 

Minimum Liquid to Gas Ratio or Minimum Scrubber Flowrate and Maximum Flue Gas 

Flowrate for a High Energy Scrubber - 40 CFR 63.1209(m)(l)(i)(C) 

Not applicable. There are no high energy scrubbers on the incinerators at Sauget. 

Minimum Blowdown Rate and Minimum Scrubber Tank Volume or Level- OR -

Maximum Conductivity of Scrubber Water-AO CFR 63.1209(m)(l)(B)(i) 

Not applicable. There are no wet scrubbers on the incinerators at Sauget. 

Minimum TankLevel-AQ CFR 63.1209(m)(l)(B)(ii) 

Not applicable. There are no wet scrubbers on the incinerators at Sauget 

Units 2 and 3 

Maximum Flue Gas Flowrate or Production Rate - 40 CFR 63.1209(m)(2) 

Flue gas flowrate, as stack gas flowrate, is monitored continuously by an Annubar. 

The OPL for maximum flue gas flowrate in association with the standard for DRE was developed 

during the 1993 RCR A Trial Burn for Unit 2 and the 1996 RCR A Trial Burn for Unit 3. During 

the 2013 CPT for Units 2 and 3, the OPL for maximum flue gas flowrate was developed in 

association with the standards for PM , HC1/C12, SVM , LVM , Mercury, and Dioxins/Furans. The 

OPL for maximum flue gas flowrate was established from the most stringent value of these tests, 

during the P M testing of the 2013 CPT of Unit 3. 

Maximum Ash Feedrate - 40 CFR 63.1209(m)(3) 

The maximum feedrate of ash was developed during the 2013 CPT of Units 2 and 3, and was 

established during the P M testing of the 2013 CPT of Unit 2. 

37 
Unit 4 

Maximum Flue Gas Flowrate or Production Rate - 40 CFR 63.1209(m)(2) 

Flue gas flowrate, as stack gas flowrate, is monitored continuously by an Annubar. 

The OPL for maximum flue gas flowrate in association with the standard for DRE was developed 

during the 1995 RCR A Trial Burn for Unit 4. During the 2013 CPT for Unit 4, the OPL for 

maximum flue gas flowrate was developed in association with the standards for PM , HC1/C12, 

SVM , LVM , Mercury, and Dioxins/Furans. The OPL for maximum flue gas flowrate was 

established from the most stringent value of these tests, during the HC1/C12 testing of the 2013 

CPT of Unit 4. 

Maximum Ash Feedrate - 40 CFR 63.1209(m)(3) 

The maximum feedrate of ash was developed during the 2013 CPT of Unit 4, and was established 

during the P M testing of the 2013 CPT of Unit 4. 

• Semivolatile Metals and Low Volatility Metals - 40 CRF 63.1209(n) 

Compliance with the standard for semivolatile metals (SVM) and low volatility 

metals (LVM) was demonstrated during the 2013 CPT. Applicable feedrates and 

OPLs associated with this standard are established from the 2013 CPT. 

Units 2 and 3 

Maximum Inlet Temperature to Dry Particulate Matter Air Pollution Control Device - 40 CFR 

63.1209(n)(l) 

The dry particulate matter control devices on Units 2 and 3 are baghouses. The temperature to the 

inlet of the baghouse is measured as the SDA (Spray Dryer/Absorber) Outlet Temperature, and 

was developed during the 2013 CPT for Units 2 and 3 in association with the standards for 

Dioxins/Furans and Metals. The OPL for maximum baghouse inlet temperature was established 

during the dioxins/furans and metals testing of the 2013 CPT of Units 2 and 3. 

Maximum Feedrate of Semivolatile and Low Volatile Metals - 40 CFR 63.1209(n)(2) 

The feedrates of the semivolatile metals (SVMs) lead (Pb) and cadmium (Cd), and the low 

volatility metals (LVMs) arsenic (As), beryllium (Be), and chromium (Cr) were demonstrated 

during the 2013 CPT of Units 2 and 3. The total feedrates of the SVMs and LVM s include the 

spiking rates and the contribution of these metals with the waste streams - both pumpable and 

nonpumpable. 

The OPL for maximum feedrate of Semivolatile Metals (SVM) was established during the metals 

testing of the 2013 CPT of Units 2 and 3. 

The OPL for maximum total feedrate of Low Volatility Metals (LVM) was established during the 

metals testing of the 2013 CPT of Units 2 and 3. 

The OPL for maximum feedrate of pumpable Low Volatility Metals (LVM) was established 

during the metals testing of the 2013 CPT of Units 2 and 3. 

Feedrates for SVM , total LVM , or pumpable LV M have not been extrapolated. 

38 
Control Device Operating Parameter Limits - 40 CFR 63.1209(n)(3) 

These OPLs are identical to the OPLs for the Particulate Matter standard. 40 CFR 63.1209(D)(3) 

references 40 CFR 63.1209(m)(l). The OPLs established for the SV M and LV M standards and the 

Particulate Matter standard are the same, and are established from results of the 2013 CPT. 

Minimum Pressure Drop Across a High Energy Scrubber 

Not applicable. There are no high energy scrubbers on the incinerators at Sauget. 

Minimum Liquid to Gas Ratio or Minimum Scrubber Flowrate and Maximum Flue Gas 

Flowrate for a High Energy Scrubber 

Not applicable. There are no high energy scrubbers on the incinerators at Sauget. 

Minimum Blowdown Rate and Minimum Scrubber Tank Volume or Level— OR -

Maximum Conductivity of Scrubber Water 

Not applicable. There are no wet scrubbers on the incinerators at Sauget. 

Minimum Tank Level - 40 CFR 63.1209(n)(3) and 40 CFR 63.1209(m)(l)(B)(ii) 

Not applicable. There are no wet scrubbers on the incinerators at Sauget. 

Maximum Total Chlorine and Chloride Feedrate - 40 CFR 63.1209(n)(4) 

The HWC MAC T prescribes the establishment of the feedrate of total chlorine and chloride in 

association with both the SV M and LV M and the HC1/C12 standards. The emission limits for 

SVM , LV M (i.e., metals),, and HC1/C12 were demonstrated in the 2013 CPT. The feedrate of total 

chlorine and chloride includes the spiking rate and the contribution of chlorine with the waste 

streams - both pumpable and nonpumpable. The OPL for the maximum feedrate of total chlorine 

and chloride was established from the most stringent value of these tests, during the metals testing 

of the 2013 CPT of Unit 3. 

Maximum Flue Gas Flowrate or Production Rate - 40 CFR 63.1209(n)(5) 

Flue gas flowrate, as stack gas flowrate, is monitored continuously by an Annubar. 

The OPL for maximum flue gas flowrate in association with the standard for DRE was developed 

during the 1993 RCRA Trial Burn for Unit 2 and the 1996 RCR A Trial Burn for Unit 3. During 

the 2013 CPT for Units 2 and 3, the OPL for maximum flue gas flowrate was developed in 

association with the standards for PM , HC1/C12, SVM , LVM , Mercury, and Dioxins/Furans. The 

OPL for maximum flue gas flowrate was established from the most stringent value of these tests, 

during the P M testing of the 2013 CPT of Unit 3. 

Unit 4 

Maximum Inlet Temperature to Dry Particulate Matter Air Pollution Control Device — 40 CFR 

63.1209(n)(l) 

The dry particulate matter control device on Unit 4 is a baghouse. The temperature to the inlet of 

the baghouse is measured as the SDA (Spray Dryer/Absorber) Outlet Temperature, and was 

developed during the 2013 CPT for Unit 4 in association with the standards for Dioxins/Furans 

and Metals. The OPL for maximum baghouse inlet temperature was established during the 

dioxins/furans and metals testing of the 2013 CPT of Unit 4. 

Maximum Feedrate of Semivolatile and Low Volatile Metals - 40 CFR 63.1209(n)(2) 

The feedrates of the semivolatile metals (SVMs) lead (Pb) and cadmium (Cd), and the low 

volatility metals (LVMs) arsenic (As), beryllium (Be), and chromium (Cr) were demonstrated 

during the 2013 CPT of Unit 4. The total feedrates of the SVMs and LVM s include the spiking 

rates and the contribution of these metals with the waste streams - both pumpable and 

nonpumpable. 

The OPL for maximum feedrate of Semivolatile Metals (SVM) was established during the metals 

testing of the 2013 CPT of Unit 4. 

39 
The OPL for maximum total feedrate of Low Volatility Metals (LVM) was established during the 

metals testing of the 2013 CPT of Unit 4. 

The OPL for maximum feedrate of pumpable Low Volatility Metals (LVM) was established 

during the metals testing of the 2013 CPT of Unit 4. 

Feedrates for SVM , total LVM , or pumpable LV M have not been extrapolated. 

Control Device Operating Parameter Limits - 40 CFR 63.1209(n)(3) 

These OPLs are identical to the OPLs for the Particulate Matter standard. 40 CFR 63.1209(n)(3) 

references 40 CFR 63.1209(m)(l). The OPLs established for the SV M and LV M standards and the 

Particulate Matter standard are the same, and are established from results of the 2011 CPT. 

Minimum Pressure Drop Across a High Energy Scrubber 

Not applicable. There are no high energy scrubbers on the incinerators at Sauget. 

Minimum Liquid to Gas Ratio or Minimum Scrubber Flowrate and Maximum Flue Gas 

Flowrate for a High Energy Scrubber 

Not applicable. There are no high energy scrubbers on the incinerators at Sauget. 

Minimum Blowdown Rate and Minimum Scrubber Tank Volume or Level- OR -

Maximum Conductivity of Scrubber Water 

Not applicable. There are no wet scrubbers on the incinerators at Sauget. 

Minimum Tank Level - 40 CFR 63.1209(n)(3) and 40 CFR 63.1209(m)(l)(B)(ii) 

Not applicable. There are no wet scrubbers on the incinerators at Sauget. 

Maximum Total Chlorine and Chloride Feedrate - 40 CFR 63.1209(n)(4) 

The HWC MAC T prescribes the establishment of the feedrate of total chlorine and chloride in 

association with both the SV M and LV M and the HC1/C12 standards. The emission limits for 

SVM , LV M (i.e., metals),, and HC1/C12 were demonstrated in the 2013 CPT. The feedrate of total 

chlorine and chloride includes the spiking rate and the contribution of chlorine with the waste 

streams - both pumpable and nonpumpable. The OPL for the maximum feedrate of total chlorine 

and chloride was established from the most stringent value of these tests, during the HC1/C12 

testing of the 2013 CPT of Unit 4. 

Maximum Flue Gas Flowrate or Production Rate - 40 CFR 63.1209(n)(5) 

Flue gas flowrate, as stack gas flowrate, is monitored continuously by an Annubar. 

The OPL for maximum flue gas flowrate in association with the standard for DRE was developed 

during the 1995 RCRA Trial Burn for Unit 4. During the 2013 CPT for Unit 4, the OPL for 

maximum flue gas flowrate was developed in association with the standards for PM, HC1/C12, 

SVM , LVM , Mercury, and Dioxins/Furans. The OPL for maximum flue gas flowrate was 

established from the most stringent value of these tests, during the HC1/C12 testing of the 2013 

CPT of Unit 4. 

• Hydrochloric Acid and Chlorine Gas - 40 CFR 63.1209(o) 

Compliance with the standard for hydrochloric acid and chlorine gas (HCI/CI2) was 

demonstrated during the 2013 CPT. Applicable feedrates and OPLs associated with 

this standard are established from the 2013 CPT. 

40 
Units 2 and 3 

Maximum Total Chlorine and Chloride Feedrate - 40 CFR 63.1209(o)(l) 

The HWC MACT prescribes the establishment of the feedrate of total chlorine and chloride in 

association with both the SV M and LV M and the HC1/C12 standards. The emission limits for 

SVM , LV M (i.e., metals),, and HC1/C12 were demonstrated in the 2013 CPT. The feedrate of total 

chlorine and chloride includes the spiking rate and the contribution of chlorine with the waste 

streams - both pumpable and nonpumpable. The OPL for the maximum feedrate of total chlorine 

and chloride was established from the most stringent value of these tests, during the metals testing 

of the 2013 CPT of Unit 3. 

Maximum Flue Gas Flowrate or Production Rate - 40 CFR 63.1209(o)(2) 

Flue gas flowrate, as stack gas flowrate, is monitored continuously by an Annubar. 

The OPL for maximum flue gas flowrate in association with the standard for DRE was developed 

during the 1993 RCR A Trial Burn for Unit 2 and the 1996 RCR A Trial Burn for Unit 3. During 

the 2013 CPT for Units 2 and 3, the OPL for maximum flue gas flowrate was developed in 

association with the standards for PM , HC1/C12, SVM , LVM , Mercury, and Dioxins/Furans. The 

OPL for maximum flue gas flowrate was established from the most stringent value of these tests, 

during the P M testing of the 2013 CPT of Unit 3. 

Dry Scrubber - 40 CFR 63.1209(o)(4) 

The control devices on the incinerators at Sauget that are designed and operated to control HC1 

and Cl 2 are Spray Dryer/Absorbers, considered as Dry Scrubbers. The HWC MACT prescribes the 

establishment of OPLs for dry scrubbers in association with the HC1/C12 standard. 

Minimum Sorbent Feedrate - 40 CFR 63.1209(o)(4)(i) 

The HWC MACT prescribes the establishment of an OPL for sorbent feedrate to a dry scrubber. 

The OPL for the minimum feedrate of sorbent to the Spray Dryer/Absorber (SDA) is measured as 

the feedrate of lime to the SDA, and was developed during the 2013 CPT for Units 2 and 3 in 

association with the standard for HC1/C12. The OPL for minimum sorbent feedrate to the SDA was 

established during the HC1/C12 testing of the 2013 CPT of Unit 2. 

Minimum Carrier Fluid Flowrate or Nozzle Pressure Drop - 40 CFR 63.1209(o)(4)(ii) 

The HWC MACT prescribes the establishment of an OPL for carrier fluid flowrate to a dry 

scrubber. The OPL for the minimum carrier fluid flowrate to the Spray Dryer/Absorber (SDA) 

was developed during the 2013 CPT for Units 2 and 3 in association with the standard for HC1/C12. 

The OPL for minimum sorbent feedrate to the SDA was established during the HC1/C12 testing of 

the 2013 CPT of Unit 2. 

Wet Scrubber - 40 CFR 63.1209(o)(3) 

The HWC MACT prescribes that operating parameter limits for wet scrubbers be established 

under the hydrochloric acid and chlorine gas standard found in 40 CFR 63.1206(o)(3). 

Not applicable. There is not a wet scrubber on the incinerators at Sauget. 

Minimum Pressure Drop Across a High Energy Scrubber - 40 CFR 63.1209(1)(2) and 40 CFR 

63.1209(0)(3)(i) 

Not applicable. There is not a high energy scrubber on the incinerators at Sauget. 

Minimum Liquid Feed Pressure for Low Energy Scrubber - 40 CFR 63.1209(1)(2) and 40 CFR 

63.1209(o)(3)(iii) 

Not applicable. There is not a low energy scrubber on the incinerators at Sauget. 

Minimum pH - 40 CFR 63.1209(o)(3)(iv) 

Not applicable. There is not a wet scrubber on the incinerators at Sauget. 

41 
Minimum Liquid to Gas Ratio - 40 CFR 63.1209(o)(3)(v) 

Not applicable. There is not a wet scrubber on the incinerators at Sauget. 

Unit 4 

Maximum Total Chlorine and Chloride Feedrate - 40 CFR 63.1209(o)(l) 

The HWC MACT prescribes the establishment of the feedrate of total chlorine and chloride in 

association with both the SV M and LV M and the HC1/C12 standards. The emission limits for 

SVM , LV M (i.e., metals),, and HC1/C12 were demonstrated in the 2013 CPT. The feedrate of total 

chlorine and chloride includes the spiking rate and the contribution of chlorine with the waste 

streams - both pumpable and nonpumpable. The OPL for the maximum feedrate of total chlorine 

and chloride was established from the most stringent value of these tests, during the HC1/C12 

testing of the 2013 CPT of Unit 4. 

Maximum Flue Gas Flowrate or Production Rate - 40 CFR 63.1209(o)(2) 

Flue gas flowrate, as stack gas flowrate, is monitored continuously by an Annubar. 

The OPL for maximum flue gas flowrate in association with the standard for DRE was developed 

during the 1995 RCRA Trial Burn for Unit 4. During the 2013 CPT for Unit 4, the OPL for 

maximum flue gas flowrate was developed in association with the standards for PM, HC1/C12, 

SVM , LVM , Mercury, and Dioxins/Furans. The OPL for maximum flue gas flowrate was 

established from the most stringent value of these tests, during the HC1/C12 testing of the 2013 

CPT of Unit 4. 

Dry Scrubber - 40 CFR 63.1209(o)(4) 

The control devices on the incinerators at Sauget that are designed and operated to control HC1 

and Cl 2 are Spray Dryer/Absorbers, considered as Dry Scrubbers. The HWC MACT prescribes the 

establishment of OPLs for dry scrubbers in association with the HC1/C12 standard. 

Minimum Sorbent Feedrate - 40 CFR 63.1209(o)(4)(i) 

The HWC MAC T prescribes the establishment of an OPL for sorbent feedrate to a dry scrubber. 

The OPL for the minimum feedrate of sorbent to the Spray Dryer/Absorber (SDA) is measured as 

the feedrate of lime to the SDA, and was developed during the 2013 CPT for Unit 4 in association 

with the standard for HC1/C12. The OPL for minimum sorbent feedrate to the SDA was established 

during the HC1/C12 testing of the 2013 CPT of Unit 4. 

Minimum Carrier Fluid Flowrate or Nozzle Pressure Drop - 40 CFR 63.1209(o)(4)(ii) 

The HWC MAC T prescribes the establishment of an OPL for carrier fluid flowrate to a dry 

scrubber. The OPL for the minimum carrier fluid flowrate to the Spray Dryer/Absorber (SDA) 

was developed during the 2013 CPT for Unit 4 in association with the standard for HC1/C12. The 

OPL for minimum sorbent feedrate to the SDA was established during the HC1/C12 testing of the 

2013 CPT of Unit 4. 

Wet Scrubber - 40 CFR 63.1209(o)(3) 

The HWC MAC T prescribes that operating parameter limits for wet scrubbers be established 

under the hydrochloric acid and chlorine gas standard found in 40 CFR 63.1206(o)(3). 

Not applicable. There is not a wet scrubber on the incinerators at Sauget. 

Minimum Pressure Drop Across a High Energy Scrubber - 40 CFR 63.1209(1)(2) and 40 CFR 

63.1209(0)(3)(i) 

Not applicable. There is not a high energy scrubber on the incinerators at Sauget. 

Minimum Liquid Feed Pressure for Low Energy Scrubber - 40 CFR 63.1209(1)(2) and 40 CFR 

63.1209(o)(3)(iii) 

Not applicable. There is not a low energy scrubber on the incinerators at Sauget. 

42 
Minimum pH - 40 CFR 63.1209(o)(3)(iv) 

Not applicable. There is not a wet scrubber on the incinerators at Sauget. 

Minimum Liquid to Gas Ratio - 40 CFR 63.1209(o)(3)(v) 

Not applicable. There is not a wet scrubber on the incinerators at Sauget. 

• Carbon Monoxide - 40 CFR 63.1203(a)(l)(i) 

Compliance with the standard for carbon monoxide was demonstrated at all times 

during the 2013 CPT. 

• Maximum Combustion Chamber Pressure - 40 CFR 63.1206(c)(5) and 40 CFR 

63.1209(p) 

Units 2 and 3 

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. 

Unit 4 

The kiln 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 of the 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. 

• Hazardous Waste Residence Time - 40 CFR 63.1206(b)(ll) 

Units 2 and 3 

The hazardous waste gas residence time for Unit 2 is calculated as follows using the OPL for the stack gas 

flowrate in the current NOC: 

• Primary Combustion Chamber Volume - 635 ft 3; 

• Secondary Combustion Chamber Volume - 635 ft 3; 

• Total Volume-1,270 ft 3; 

• Maximum Flue Gas Howrate - 15,147 acfm (252 frVsec); and 

• Total Combustion Zone Residence Time = (1,270 ft 3) / 252 ftVsec) = 5.0 sec. 

Since Unit 2 is a fixed hearth unit, residence time is based on the travel length of the ash ram that 

functions to clear the primary combustion chamber of solid waste residue. A travel length of 110 

inches for the ash ram has been established as the criteria for determining when solid waste is no 

longer in the combustion zone. In the case of an ash ram failure, an elapsed time of one hour has been 

established as the criteria for determining when solid waste is no longer in the combustion zone. 

43 
Unit 4 

The hazardous waste gas residence time for the Unit 4 Rotary Kiln Incinerator is calculated as follows: 

" Rotary Kiln Volume - 1,346 ft 3; 

• Secondary Combustion Chamber Volume - 3,084 ft 3; 

• Total Volume - 4,430 ft 3; 

• Maximum Flue Gas Flowrate - 37,432 acfm (624 ft3/sec); and 

• Total Combustion Zone Residence Time = (4,430 ft 3) / (624 ftVsec = 7.1 sec. 

Solids residence time in the Unit 4 kiln is dependent upon the kiln rotation rate, solids bed depth, and a 

number of other parameters set by design. The maximum solids hazardous waste residence time for the 

Unit 4 incinerator (i.e., in the rotary kiln) is 30 minutes based on calculations using an equation from 

Chemical Engineering Handbook, Perry's 5* Edition. 

Based on the equation: 

0 = [(O.19L)/(NDS)] 

Where: 

0 is the residence time in minutes, 

L is the kiln length in feet, 

N is the rotational speed in revolutions per minute, 

S is the kiln slope in feet per feet, and 

D is the internal diameter in feet. 

Inserting the known values for L (35), N (2), S (0.0174), and D (6.5) result in a solids residence time 

for the rotary kiln of 30 minutes. 

44