### May 23,2008 Cheryl L. Newton, Acting Director Air and Radiation Division 

## W nited States Environmental Protection Agency Region 5 77 West Jackson Blvd. Chicago, lL 60604-3590 RE: Veolia ES Technical Solutions, L.L.C. Metals Performance Test Plans for Incinerators 2,3 and 4 Dear Ms. Newton, Pursuantto our agreement, attached is the Metals Performance Test Plan Prepared for the Fixed Hearth lncinerator Number 2 in Accordance with 40 CFR 

# 5 63 Subpart EEE, Metals Performance Test Plan Preparedfor the Fixed Hearth lncinerator Number 3 in Accordance with 40 CFR § 

### 63 Subpart EEE and Metals Performance Test Plan Preparedfor the Rotary Kiln lncinerator Number 4 in Accordance with 40 CFR § 

### 63 Subpart EEE. Electronic copies of these plans have been sent to Mr. Charles Hall of your Agency on May 22. Please call me at (61 8) 271-2804, ext. 101 if you have any questions. Sincerely,

~eneral Manager

#7 Mobile Avenue, Sauget, IL 62201 (618) 271 -2804 www.veoliaes.comP-. Prepared for: Veolia ES Technical Solutions 

### 7 Mobile Avenue Sauget, 

### IL62201



# Metals Performance Test Plan Prepared for the Rotary Kiln Incinerator Number 4 

# in Accordance with 40 

# CFR 

# 5 63 

# Subpart EEE

ENSR Corporation May 2008 Document No.: 10002-022Prepared for: Veolia ES Technical Solutions 7 Mobile Avenue Sauget, IL 62201



# Metals Performance Test Plan Prepared for the Rotary Kiln Incinerator Number 

# 4 in Accordance with 40 

# CFR 

# 5 63 

# Subpart EEE

Reviewed By Craig Doolittle

ENSR Corporation May 2008 Document No.: 10002-022Veolia ES Technical Solutions Unit 4 HWC MACT Performance Test Plan Revision: 0 Date: May 2008 Section: Table of Contents Page i of vi 

## Contents

1.0 Introduction 

## ................................................................................................................................................ I

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


### .1 Program Summary [40 CFR 

### § 63.1207(f) and 

### § 63.7(c)(2)(i)] 1 1.2 FacilityIUnit Identification

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

### I 1.2.1 General



### .................................................................................................................................. I 1.2.2 Facility ID, MailingAddress, and Primary Contacts I



### .............................................................................................................. 1.2.3 Incinerator Overview 1 1.3 Purpose and Objectivesof the Performance Test

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



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



### ............................................................................................ ...2
2.0 Engineering Description

# ........................................................................................................................... I 2.1 Process Overview



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

### I 2.2 Waste Feed Systems [40 CFR 

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


### ................................. 1 2.2.1 Unit 4 Liquid Waste Feed System and Blending Operations

...............................................1 2.3 Manufacturer. Make and Model of the Incinerator [40 CFR 

### § 63.1207(f)(l)(iii)(A)]

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

........................ 2 2.3.2 Secondary Combustion Chamber (SCC)



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

.............4 2.3.4 Hazardous Waste ResidenceTime [40 CFR §63.1207(f)(l)(ix)]



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



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



### .........................................................................................................4 2.4 Procedures for Rapidly Stopping Hazardous Waste Feed During Equipment Malfunction [40 CFR



### ...

............................................................................................................................. §63.1207(f)(l)(v111)] 5

....................................................... 2.5 Air Pollution Control Equipment [40 CFR §63.1207(f)(l)(iii)(G)] 5 2.5.1 Air Pollution Control Systems Descriptions

........................................................................ 5 2.6 Stack Emissions Monitoring [40 CFR §63.1207(f)(l)(iii)(H)]

............................................................. 8 2.6.1 CEM System Description

...................................................................................................... 8 2.7 Process Monitoring and Control



### ......................................................................................................... 9 2.8 Automatic Waste Feed Cut-off System [40 CFR §63.1207(f)(l)(iii)(F)]

............................................ 9 2.8.1 AWFCO System Testing

..................................................................................................... 10 2.9 Air Pollution Control Equipment Maintenance Practices [40 CFR §63.1207(f)(l)(iii)(G)] 10 2.9.1 Program Overview



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



### ................................................................................... 2.9.2 Test Program Preparation Activities 11

Q:\mw97\Projects\lOOO2022\Veolia PerformanceTest PlanU4 R3-052108.doc

### Veolia ES

### Technical Salutions Unit4 

### HWC IMACT PerformanceTest Plan Revision

. 0 

### Date: May 2008 

### Section: Table of 

### Contents Page ii of 

### vi

3.0 Incinerator Feed Stream Descriptions

## .................................................................................................... I



### ................................................................................................................................................ 3.1 General 1 3.2 High Volume Wastes

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

### 1

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

### 3.2.1 LiquidWastes 1



### ............................................................................................................................. 3.2.2 Bulk Solids 1



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



### .. 3.3 Aux~l~ary fuels

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

### 1
4.0 Performance Test Protocol

# ....................................................................................................................... I

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

### 4.1 General Description I



### ...................................................................................................................... 4.2 Performance Standards 1 4.3 Test Conditions [40 CFR 

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

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

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

### 4.4 Waste Feed Spiking 1

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

### 4.4.1 Inorganic Constituents 2 4.4.2 Spiking for the LVM Category



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

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

### 2 4.4.4 Spiking for Mercury

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

### .................................................................................2 4.5 Metals Extrapolation Method

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

## . ............................................................................... 3 4.6 Description. Preparation and Deliveryof Feeds for the PerformanceTest [40 CFR 

## 5 63.1207



### .............................................................................................. (f)(l)(vi) and (vii)]

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

### . 3 4.7 Conditioning Time Weeded to Reach Steady State [40 CFR § 

### 63.1207(f)(l)(xii)]

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

### 3 4.8 Anticipated Test Schedule

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

### ..... ... 

### ............................................................................ 3

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

### 4.9 Performance Test Reporting 4 5.0 Sampling and Analytical Program Quality AssurancelQualityControl 

## ............................................. I 

### 5.1 Title Page



### ............................................................................................................................................. 2 5.1.1 ProjectTitle

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

### 2

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

### 5.1.2 Expected Performance Test Date 2



### ................................................................................................................. 5.1

.

### 3 Project Approvals 2 5.2 Table of Contents

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

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

### 5.3 Project Description 3

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

### 5.4 Project Organization 3 5.4.1 QA Officer's Responsibilities

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

### 3 5.4.2 Laboratory Coordinator Responsibilities



### ............................................................................... 3 5.5 QAQC Program Objectives

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

### 4 5.5.1 Precision. Accuracy and Completeness

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

### 4

Q:\mw97\Projects\l0002022\Veol1a Performance Test Plan U4 R3-0521OB.docVeolia ES Technical Solutions Unit4 HWC MACT PerformanceTest Plan Revision: 0 Date: May 2008 Section: Table of Contents Page iii of vi

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



### . 4

.................................................................... 5.5.3 Method Detection Limit (MDL) Determinations 5 5.6 Sampling and Monitoring Procedures



### .............................................................................................. 5

..................................................................................................... 5.6.1 Field Program Description 5 5.6.2 Pre-sampling Activities



### ........................ . ............................................................................ 5



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



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

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

............ . 7 5.7 Sample Handling. Traceability and HoldingTimes

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

### .................................................... 8 5.8 Analytical Methods and Calibration Procedures



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

### ..................................................9



### .......................................................................................... 5.8.1 Analysis of Waste Feed Streams 9 5.8.2 Analysis of Stack Gas Samples



### ......................................................................................... 9

........................................................................................................................ 5.9 Internal QA Program I0



### .................................................................. 5.9.1 Data Collection and Sampling QC Procedures I0 5.9.2 Analytical QC Procedures for Samples to beAnalyzed in the Laboratory



### ........................ 11



### ........................................................................ 5.10 Data Reduction. Verification and Data Reporting 

### I I

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

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

............ .. 12

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



### ............................................................................................................ 5.10.4 Final Data Reporting 13 5.11 Routine Maintenance Procedures and Schedules

.......... . .......................................................... 13 5.1 1

.1 Field Sampling Equipment

................................................. ........................................... 14 5.11.2 Facility Equipment and Instrumentation



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

...................................................................................................... 5.12 QNQC Assessment Procedures 14 5.12.1 Accuracy

............................................................................................................................ 14

. . 5.1 2.2 Prec~s~on

............................................................................................................................ 15 5.12.3 Completeness


### ............................................................................................................. 15 5.13 ExternalQA Program



### ...................................................................................................................... 15 5.13.1 Performance Audits

.................................... .. ................................................................... 16



### .................................................................................................................. 5.13.2 Corrective Action 16 5.1 3.3 Quality Assurance Reportsto Management



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

Q:\mw97\Projects\l0002022\Veolia Performance Test Plan U4 R3-052108 docVeol~a ES Technical Solutions Un~t 4 HWC MACT Performance Test Plan Revision: 0 Date: May 2008 Section: Table of Contents Page iv of vi 

# List of 

# Appendices Appendix A Unit 4 Process Flow Diagram Appendix 

### B Field Data Sample Collection Forms Appendix C lsokinetic Sampling Train Setup and Recovery Schematics

Q:\mw97\Projects\l0002022\Veolia PerformanceTest Plan U4 R3-052108.docVeolia ES Technical Solutions Unit 4 HWC MACT Performance Test Plan Revision: 0 Date: May 2008 Section: Table of Contents Pagev of vi 

## List of Tables
Table 1-1 Summary of Applicable MACT EmissionStandards

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

### 3

.................................................................... Table 1-2 Cross Reference of PerformanceTest Requirements 4 Table 2-1 Veolia ES Technical Solutions 

### - Continuous Emissions Monitors

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

### 8 Table 2-2 Technical InformationSummary on Incinerator NO

. 

### 4



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

. 

### 4

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

### 13

................................................................................................... Table 3-1 Top Volume LiquidWaste Streams 2

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

........................................................................................... Table 3-3 Top Containerized Solid Waste Streams 3 Table 3-4 Summary of Major HAPSProcessed

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

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

.................................................................................... 4

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

### Table 3-6 Typical Properties for Natural Gas ~4

.......................................................... Table 4-1 IVlACT OPLs to be Established Duringthe PerformanceTest 5

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

### Table 4-2 Metals Evaluation Plan

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

### 6

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

### Table 4-3 Anticipated Metals PerformanceTest Schedule 

### 7 Table 5-1 General Sampling and Analytical Program Overview (Stack Exhaust)



### .......................................... 19 Table 5-2 

### QA Objectives for Field Measurements



### ........................................................................................... 20 Table 5-3 Overall Summary of PerformanceTest Stack Gas Sampling and Analysis Program


### .................... 21



### .................................................................................................................. Table 5-4 Traverse Point Locations 22 Table 5-5 Sample Preservation and Holding Time Requirements



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

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

### 23



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

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

### 24

Qlrnw97\Projects\l0002022\Veol1a PerformanceTest PlanU4 R3-052108.docVeolia ESTechnical Solutions Unit 4 HWC MACT Performance Test Plan Revision: 0 Date: May 2008 Section: Table of Contents Page vi of vi 

## List of 

## Figures Figure 5-1 Stack Sampling Locations

............................................................................................................... 25 Figure5-2 Example Sample Packing List

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

### 26

Q~\mw~7\Projects\l0002022\Veolia Performance Test Plan U4 R3-052108.docRevision: 0 Date: May 2008 Section: 1.0 Veolia ESTechnical Solutions Unit 4 HWC MACT Performance Test Plan Page I of 4



## I

.O 

## Introduction

I

.I Program Summary [40 CFR 

### § 63.1207(f) and 

### § 63.7(c)(2)(i)] This document is the Metals PerformanceTest Plan for the rotary kiln lncinerator Number4 operated by Veolia ES Technical Solutions (Veolia) at its Sauget, Illinois facility. Since the Veolia inc~nerator treats certain waste that are classifiedas hazardous under state andlor federal regulations, this unit is subjectto the requirements of the HWC MACT Rule. This Plan has been prepared in accordance with requirements initially promulgated in NESHAPS: Final Standards for Hazardous Waste Air Pollutantsfor Hazardous Waste Combustors, (generally referredto as the HazardousWaste Combustor [or "HWC"] MACT Rule). These regulations were initially published by US EPA on September30, 1999 in 40 CFR 

### § 63 Subpart EEE. However, these initial regulations were vacated basedon a DC Circuit Court ruling, were subsequently replaced by "Interim Standards" in Februaryof 2002 and then re-promulgated again in the Permanent Replacements Standards published in the Federal Register on October 12, 2005. This document addresses the requirementsto develop and submit a Performance Test Plan set forth in 40 CFR 

### § 63.1207. This PerformanceTest Plan is written to address all applicable Subpart EEE (and General Provisions) requirements incorporated into the regulations through promulgation of the Final Replacement Standards published in the Federal Reg~ster on October 12,2005. 

### I.2 FacilityIUnit Identification I I General As mentionedabove, this Performance Test Plan has been developedto evaluate the rotary kiln incinerator Number4 at the Veolia facility in Sauget, IL. This is a commercial hazardous waste incineration facility that treats liquid and soltd wastes that are classifiedas both hazardous and non-hazardous. 

### 1.2.2 Facility 

### ID, MailingAddress, and Primary Contacts The facility address is: The facility contact is: Veolia ESTechnical Solutions Mr. Dave Klarich 7 Mobile Avenue Phone: 361 -572-231 7 Sauget, IL 62201 Email: David.Klarich@veoliaes.com Facility ID#: 

### lLD098642424 

### 1.2.3 Incinerator Overview This incineratoris a rotary kiln incineration system with primary and secondary combustion chambersthat treats solid wastes as well as aqueous and organic liquids. The process is monitored and controlled by a distributed control system (DCS) capable of continuously monitoring the processto assure all operational parameters are within regulatory and permit limits while waste is being fed to the unit. In addition, this

Q \mw97\Projects\l0002022\Veolia Performance Test Plan U4 R3-052108.docVeolia ES Technical Solutions Un~t 4 HWC MACT PerformanceTest Plan Revision: 0 Date: May2008 Section: 1.0

Page 2 of 4
incinerator is equipped with a Continuous Emissions Monitoring System (CEMS) that continuously samples the exhaust gases for oxygen and carbon monoxide in the stack gas exhaust stream. 

### 1.3 

### Purpose and Objectives of the Performance Test 1.3.1 General The purpose of the performance test is to validate the performance level of the incineratoragainst the requirements in 40 CFR Part 63, Subpart EEE. To this end, the specific objectives of this performance test are to:

a Demonstratethat the metals emissions from the incinerator meet the HWC MACT emission limits while treating hazardous waste for the parameters being tested. Collect monitoring data in order to re-establish operating parameter limits (OPLs) or set new OPLs on key operating variables that will ensure that the incinerator operates within the HWC MACT emission limits while treating hazardous waste. Utilize an extrapolation procedure, as appropriate, to establish metalsfeed rate limits. The performance test will include feeding a variety of liquid and solid waste materials to the incinerator, sampling and analyzing the feed streams, monitoring certain process parameters and conducting emissions testing. The emissions standardsthat will be evaluated under the HWC MACT regulations are summarized in Table 1-1. 

### 1.4 Performance Test Plan Organization This test plan has been organized in a format typically used for compliance demonstration test programs. Table 1-2 is included so that the performance test requirements in the HWC MACT rule can be crossreferenced with the sections in this Plan. The remainderof the document has been organized as follows: Section 2.0 provides a general physical descriptionof the rotary kiln incineration system and associated unit operations (including the air pollution control system) as well as an overview of the automatic waste feed cutoff (AWFCO) system and maintenance procedures. Section 3.0 presents a brief discussion of the wastes to be treated in terms of physicaland chemical parameters which impact thermal oxidation and summarizes the hazardous air pollutants presently identified in the waste streams.

a Section

### 4.0 presents the Test Protocol including planned feed and test conditions, rationale for the test design, anticipated test schedule and final report format. Section 5.0 fully describes all sampling and analysis procedures and associated QNQC protocols following the latest EPA guidance. This section essentially serves as the Quality Assurance Project Plan (QAPP) for this project. The Appendices contain Process Flow Diagrams (AppendixA), examples of performance test field data sheets and test equipment calibration (Appendix B); and isokinetic sample train setup and recovery forms (Appendix C).

Q:\1nw97\Pr0je~t~\lO002022\Ve0lia Performance Test Plan U4 R3-05210B.docRevision: 0 Date: May 2008 Section: 1.0 Veolia ES Technical Solutions Unit4 HWC MACT Performance Test Plan Page 3 of 4
Table 

### 1-1 Summary ofApplicable MACT Emission Standards

Semivolatile Metals (SVM) (Cadmium and Lead) Emissions Parameter Mercury 5 230 ygldscm 

# 1 40 CFR § 63.1219(a)(3) 

# 11 Limit 1 130 ygldscm Citation 40 CFR § 63.1219(a)(2) 

# 1

Q:\mw97\Projects\l0002022\Veolia PerformanceTest Plan U4 R3-052108.doc LowVolatile Metals (LVM) (Arsenic, Beryllium and Chromium) Note: All emission concentrations are correctedto 7% oxygen. S 92 pgldscm 40 CFR § 63.1219(a)(4)Revision: 0 Date: May 2008 Section: 1.0 Veolia ESTechnical Solutions Unit 4 HWC MACT Performance Test Plan Page 4 of 4


### Table 1-2 

### Cross Referenceof Performance Test Requirements

Q:\rnw97\Projects\l0002022\VeoliaPerformance Test Plan U4 R3-052108.doc Section No. inthis Document 1.1 4.7 5.5 5.9 & 5.13 3.0

2.0 2.2 2.2 2.2 2.3 2.2.6 2.5.1 2.4.11

N/A 2.6 2.3.5 5.6 & 5.8 4.3, 4.4 & 4.5 2.3.6 2.2.7 4.4.2 3.0 4.6 N/A Topic Program Summary Test schedule Data Quality Objectives (DQOs) Internal and External Quality Assurance Plan Analysis of feedstreams (as fired) Heating value, ash content, semi-volatile metals, low volatile metals, mercury and total chlorine Viscosity Identification and quantificationof reasonably expected HAPS Detailed engineering description of combustor Manufacturer/make/modelof HWC Type of HWC Maximum design capacity Feed systems Locationof combustion zone temperature device Hazardous waste AWFCO system Design, operation and maintenanceof APC Justification of alternative gas flow rate measurement technique Design, operation and maintenance of stack gas mohitoringsystems Description of Waste handling and blending Operations Detailed test protocol including. Description of sampling, monitoring and analytical procedures Descriptionof Planned Feed and Operating conditions during the PerformanceTest Proceduresfor rapidly stopping hazardous waste feed and controlling emissions during malfunction Determination of hazardous waste residence time Metal feed rate limit extrapolation (if used) Documentation of expected levels of regulated constituents in other feed streams that are not analyzed Documentationof conditioning time needed to reach steady state priorto testing Alternative monitoring frequency for wet scrubbers (if used) Other information deemed necessary by the agency Regulatory Citation 40 CFR § 63.1207(f) and § 63.7(c)(2)(i) 40 CFR § 63.1207(f), (f)(l)(v) and § 63.7(~)(2)(i) 40 CFR 

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

### 5 63.1207(f) and § 63.7(c)(2)(i) 40 CFR § 63.1207(f)(l)(i) 40 CFR § 63.1207(f)(l)(i)(A) 40 CFR § 63.1207(f)(l)(i)(B) 40 CFR § 63.1207(f)(l)(ii)(A) & (B)

40 CFR § 63.1207(f)(l)(iii)(A) 40 CFR § 63.1207(f)(l)(iii)(B) 40 CFR § 63.1207(f)(l)(ii1)(C) 40 CFR § 63.1207(fj(l)(iii)(D) & (E) 40 CFR § 63.1207(f)(l)(xix) 40 CFR § 63.1207(f)(l)(iii)(F) 40 CFR § 63.1207(f)(l)(iii)(G) 40 CFR § 63.1207(f)(l)(xvii) 40 CFR § 63,1207(f)(l)(iii)(H) 40 CFR 

### 3 63.1207(f)(l)(ii)(C) 40 CFR § 63.1207(f)(l)(iv) 40 CFR 

### 5 63.1207(f)(l)(vi) & (vii) 40 CFR § 63.1207(f)(l)(viii) 40 CFR § 63.1207(f)(l)(ix) 40 CFR § 63.1207(f)(l)(x) 40 CFR § 63.1207(f)(l)(xi) 40 CFR § 63.1207(f)(l)(xii) 40 CFR § 63.1207(f)(l)(xxiii) 40 CFR § 63.1207(f)(l)(xxvii)Revision: 0 Date: May 2008 Section: 2.0 Veolia ES Technical Solutions Unit 4 HWC MACT Pelformance Test Plan Page 1 of 14 

## 2.0 

# Engineering Description

2.1 Process Overview Veolia operates

### 2 Fixed Hearth Dual Chambered Incinerators (Units

### 2 and 3) and one rotary kiln incinerator (Unit 4) at the Sauget, ILfacility. The two fixed hearth units are rated at 16 million Btulhr each. Incineration Unit No.3 is a mirror image of Unit No. 

### 2. Both of these units have their own waste handling systems as described in the sections that follow. The only difference being Unit No. 

### 2 is equipped with four (4) baghouse modules, while Unit IVo. 3 is equipped with three (3) baghouse modules. However, each incinerator is operated identically with only three baghouse modules in service during operation. Unit 4 is rated at 50 million Btulhr and is equipped with its own tank farm system, drum storage, bulk solids storage and feed systems. 

### 2.2 Waste Feed Systems [40 

### CFR 

# 5 63.1207(f)(I)(ii)(c) and (f)(l)(iii)(D)and 

### (E)] 2.2.1 Unit4 Liquid Waste Feed System and Blending Operations The Unit 4 Rotary Kiln can incinerate any of the waste that Veolia is authorized and permitted to receive. All physicalforms of wastes will be handled and fed by the system's waste feed devices. Liquids will be fed to either the k~ln or the Secondary Combustion Chamber (SCC). Bulk solid wastes will be fed to the kiln through either the ram feeder. Containerizedwastes will be fed to the kiln through the ram feeder or the auxiliary ram feeder. This unit can receiveany combination of wastes 

## -- liquid, semi-solid, or solid --with a heat value of up to 50 m~llion Btulhr. Unit

### 4 is supported by storage tanks located in Tank Farm #3. These tanks are used to store the liquid organic waste, aqueous wastes, and pumpable sludges to be fed to the system. UnlikeTank Farm#I, all of the tanks in Tank Farm#3 can be used as feed tanks to the incinerator. Several criteria are important in designing a blend from receivedwastes. These ~nclude compatibility, proper range of heatingvalue, and permit restrictions regarding elemental composition (based on emission limitations). Pumpsto transfer these wastes to the system are ~nstalled in the tank farm, The material is transferred through aboveground pipelines from the tank farm to the incinerator. Pipelines used to transfer liquid organic waste and aqueous waste are equipped with strainers. In compliance with the Benzene NESHAP, all tanks are vented to individual carbon adsorption canisters for removal of organics beforevapor is dischargedto the atmosphere. Each carbon adsorber canister is essentially equivalentto a 55 gallon container or greater, if necessary. All tanks are equipped with conservationvents, in addition to the carbon canister adsorber. All tanks are grounded, and flame arrestors are installed between the carbon adsorbers and the tanks.
2.2.1 .I Organicand Aqueous Liquid Waste Feeds The liquid waste injectors used in the combustion chambers are air-atomizing injectors. These are used for injection of pumpable sludges, aqueous wastes and organic liquid wastes to the kiln and for ivjection of organic liquid waste to the SCC. Dualfluid injection nozzles will be usedfor atomization of the waste. Each of the injectors is rated at 0-300 gph. The liquid waste feed nozzles are served by parallel redundant pumps and recirculation systems with back pressure control.

Q:\rnw97\Projects\l0002022\Veolia Performance Test Plan U4 R3-052108.docVeolia ES Technical Solutions Unit4 HWC IMACT Performance Test Plan Revision: 0 Date: May 2008 Section 2.0 Page2 of 14

2.2.1.2 Packaged and Bulk Solid Containers of wastes are sampled and analyzed after receipt in accordance with the facility's Waste Analysis Plan. These wastes can then be delivered directly to Unit 4 or repacked into small combustiblecontainers at the facility. Repackaged containers are delivered to, and staged, in the Container Storage Unit No. 6 adjacent to the Unit 4 incinerator. When scheduled for feeding to the system, the containers of waste are transferred by forklifts to the feed conveyors serving Unit 4. Bulk solids and non-pumpablewastes are delivered and discharged intowaste feed bins in the Bulk Solids Storage Building after being received, sampled,and analyzed. A clamshell operating from an overhead crane is used to transfer thesewastes from the bins to the feed hoppers discharging to the system's ram feeder. Theweigh hopper is equippedwith weigh cells so each charge of waste can be weighed before it is discharged into the ram feeder. Fugitiveemissions are controlled by a baghouse, cyclone, and carbon adsorption system connected to this system. The ram feeder is a 25-inch wide by 42 inch high (inside dimensions) rectangulartube operated by a hydraulically driven ram. The ram tube is equipped with a vertical, hydraulically operated charge door nearthe kiln end. This door is opened before the ram beginsadvancing to push a charge into the kiln. After the ram has fully retracted, a limit switch triggers the door to close so as to protect the ram feeder from the kiln's radiant heat. The ram is capable of operating from 0-30 cycles/hour. The top face of the ram feeder has a 2' x 2' opening which receiveswaste charges from the hopper. The ram 

## P" feeder isolation gate, the charge door, and the ram operate in sequence. At the beginning of a cycle, the ram is fully retracted. On a "start" commandfrom the operator or the programmable controller, the ram feeder isolation gate opens to receive a charge of waste from the hopper. The gate then closes, the charge door opens, and the ram begins its advance. Once the ram reaches its full extension, it begins to retract. When the ram isfully retracted,the charge door is closed and the cycle can be repeated. This system's sequenced operation combinedwith the negative pressure in the kiln prevent fugitive emissions from escaping the kiln ram feeder system. The ram feeder also receives containers of wastes delivered by an auxiliary feed system. The auxiliary feed conveyor is capableof handling charge weights of I to I00pounds. The system is capable of handling charge sizes up to 24 inches in diameter and 24 inches tall. The auxiliary feed conveyor is capable of making 60 charges an hour or one complete cycle every minute. 2.2.1.3 Specialty Liquid Feeds The Specialty Feed System associatedwith lncinerator No. 4 is a Direct Inject Liquid Feed System. 

### 2.3 Manufacturer, Make and Model of the lncinerator [40 CFR 

# 5 63.1207(f)(I)(iii)(A)] 2.3.1 Combustion Chamber and Burners [40 CFR §63.1207(f)(I)(~ii)(B) and (C) lncinerator No. 4 features a two-stagecombustion process. Ignitionof waste material takes place in the kiln, or primary combustion chamber (PCC). A secondary combustion chamber (SCC) serves as an "after-burner" for process gases and is also permitted to incinerate high Btu liquid waste. lgnition of the waste takes place at temperatures in excess of 1600degrees F. The secondary combustion chamber maintains a minimum temperature of approximately 1875 degrees F.,fibThe rotary kiln is fabricated of carbon steel. It has approximatedimensions of 8'8O.D. 

### X 35' long. It is supported on a one-degree slope by two steel tires or riding rings. Each riding ring rides on two pairs of steel
Q \rnw9~Pro~ects\lD002022\Veolia Performance Test Plan U4 R3-052108.docVeolia ESTechn~cal Solutions Unit4 HWC MACT PerformanceTest Plan Revision: 0 Date: May 2008 Section: 2.0 Page 3 of 14
trunnions and have an approximate outside diameter of 9 feet 5 inches. The thickness and face width of the trunnions are approximately 6 inches and 9 inches, respectively.Table 2-2 provides a summary of the incineratordesign specifications. The kiln is lined with approximately 7 % inches of dense abrasion-resistant high-alumina firebrick refractory. Wtth this refractory system, the kiln has an inside diameter of approximately 7 feet and a length of approximately35 feet, an integralcross-section area of approximately 38 square feet and an internal volume of approximately 1,346 cubic feet. All kiln feeds will enter through the upper kiln face plate which is located on the feed end of the kiln. The plate contains a primary burner, three liquid feed nozzles (for pumpablesludge, aqueous waste, and high Btu liquid waste), a ram feeder and a surge vent. The primary burner is equivalent to a North American 'Fuel Directed' burner of 25 MMBtuihr. and burns No. 2 fuel oil or natural gas. The burner system is suppliedwith approximately 4,000 admcombustion air at a static pressure of 20" water column (WC). The pilot for the primary burner will burn natural gas. The fuel system for the kiln (and secondary combustion chamber) is controlled by a Factory Mutual approved burner management system complete with interlocks and safety valves. 

### 2.3.2 Secondary Cornbustion Chamber (SCC) The SCC is a vertical, cylindrical chamber having approximate dimensions of 10'-6" O.D. x 71' high. It is fabricated of carbon steel and lined with an inner course (hot face) of approximately six inches of high alumina refractory and an outer course of approximatelytwo inches of insulating refractory. With this installed refractory, the SCC has an inside diameter of approximately nine feet. The effective length (gas retention length) of the chamber is approximately 48' 

### - 6". Consequently, the SCC has a cross-section area of 64 square feet and an effective volume of approximately 3,084 cubic feet. At maximum combustion gas flows, the combustion gas restdencetime is greater than two seconds. Combustion gases from the kiln enter the bottom of the SCC through a refractory-lined side duct and exit from the top of the SCC through a refractory-lined duct to the tempering chamber. The floor of the chamber is sloped to facilitate the removal of ash and solids through a slag tap. The SCC is equipped with one burner mounted on the sidewall of the chamber near the bottom. The burner is a Trane Thermal Model, or equivalent, with a design heat release of approximately30 million Btulhr. This burner is supplied with No. 2 fuel oil or natural gas and combustion air. As with the kiln burner, the SCC burner is supplied with atomizing air and is equipped with a burner managementsystem. This system controls the ignition and initiates an automatic shutoff when there is a loss of flame, combustion air supply, fuel pressure, atomizing air pressure, pilot burner or IDfan. The SCC burner is a high-intensity, vortex type unit with a spin vane assembly, located within the windbox to impart an intense rotary motion to the combustion air. This rotary motion and the burner design provide complete mixing of air and fuel, and recirculationof the gases within the combustion chamber promotes rapid combustion and high heat intensity.

Q \mw97\Prqects\l0002022\VeoliaPerformance Test Plan U4 R3-052108.docRevision: 0 Date: May 2008 Section: 2.0 Veolia ESTechn~cal Solutions Unit4 HWC MACT PerformanceTest Plan Page 4 of 14


### 2.3.3 Location of CombustionZone Temperature Device [40 CFR §63.1207(f)(l)(xix)] The pyrometer that monitors temperature in the rotary kiln is located top-center in the transition section between the rotary kiln and the SCC about two feet downstream from the exit of the kiln. The thermocouple that monitorstemperature in the SCC is located on the west side of the chamber near the SCC exit duct. 

### 2.3.4 Hazardous Waste Residence Time [40 CFR §63.1207(f)(l)(ix)] The hazardous waste gas residence time for the Unit 4 Rotary Kiln Incinerator is calculated as follows: Rotary Kiln Volume 

### - 1346 ft3 Secondary Combustion Chamber Volume 

### - 3084 ft3 Total Volume 

### -4430 ft3 Maximum Flue Gas Flowrate

### -43,000 acfm (717 ft3/sec) Total Combustion Zone Residence Time 

### = (4430ft3)/(717 ft3/sec)= 6.2 sec 

### 2.3.5 Combustion System Leak The kiln itself is equipped with a double seal system that is comprised of overlapping, adjustable, stainless steel sprlng plates on both the feed and discharge ends of the kiln. The sealing edges of each plate are fitted wlth 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 additionto the klln seal system, Unit 4 also utilizes an induced draft fan that maintains a vacuum of 

### - 0.5 to 

### - 1.0 incheswater column while waste IS beingfired into the system. 

### 2.3.6 Emergency Safety Vent Unit 4 is equipped with two emergencyvents, one located at the kiln inlet which acts as an emergency pressure relief, the second is locatedat the top of the SCC as a thermal relief vent. The emergencyvent at the kiln inlet would only be required for an occurrence that overwhelms the ability of the 

### IDfan to controlthe pressureof the kiln. The vent and chute opening is designed such that waste from the bulk solids chutewould not impede the escaping gas flow. A deflector separates the feed flow from the vent opening. The entrainment of solids through the surge vent is minimal. As an extra precaution, the exhaust opening of the vent is angled to provldea horizontal exit, thereby minimizing sol~ds entrainment into the air. The vent is kept closed by weighted louvers. These louvers will open only if the pressure in the kiln suddenly rises beyond the compensat~ng capac~ty of the 

### IDfan. A limit switch on the louvers

### will automatically shutoff all waste feeds to the kiln and SCC when the vent is opened. The Incinerator is also equipped with an emergency safety vent (ESV) located at the top of the secondary combustion chamber. This ESV is a refractory-lined emergency thermal relief vent (TRV) which is held in the closed position by a pneumatic cylinder. The control valve in the line supplying air to the cylinder and the cylinder vent valve which opens the TRV are located in the control room for each unit. Valve locks (with keys attached) are utilized to deter indiscriminate operation of these valves. Opening of the TRV allows hot combustion gas to vent from the combustion system during emergency shutdown events. The purpose of the TRV is to protect the downstream APCS from excessive temperature situations. A limit switch on the TRV shuts off all waste feeds to the system as it sensesthat the cap is opening.
Q.\rnw97\Pro]ects\I0002022\Veolia PerformanceTest Plan U4 R3-052108.docVeolia ESTechnical Solutions Unit4 HWC MACT PerformanceTest Plan Revision: 0 Date: May 2008 Section: 2.0 Page 5 of 14


### 2.4 Procedures for Rapidly Stopping Hazardous Waste Feed During Equipment Malfunction [40 CFR §63.1207(f)(l)(viii)] Equipment malfunctions are identified by the control system, observation of process control variables, or by regularfield inspections. In the event of a minor equipment malfunction (e.g.waste feed or scrubber leaks), the control room operator will be notified. The control room operator will then close the waste feed valves and disable the waste feed pumps. In the event of major equipment malfunction (e.g.fire), the emergency stop button located in the control room will be pushed. If this button is pushed all equipment will switch to its fail-safe position. 

### 2.5 Air Pollution Control Equipment [40 CFR §63.1207(f)(l)(iii)(G)] 2.5.1 

### Air Pollution Control Systems Descriptions The air pollution control system consists of a tempering chamber,two spray dryer absorbers, and fabric filter baghouse modules. The air pollution control system neutralizes acidic compounds and removes particulate from the exhaust gas. Two subsystems, the spray dryer absorber and the fabric fllter, carry out the chemical neutralizationand particulate removal functions, respectively. A third subsystem,the lime system, is usedto prepare and provide lime slurry to the spray dryer absorber for use in the chemical neutralization process. The induced drafl fan and stack provide the mechanical energy required to transportthe flue gas through the interconnecting ductwork,to its eventual discharge point to atmosphere. 2.5.1 .I Tempering Chamber The tempering chamber is a vertical, cylindrical unit designedto cool the combustion gases using a series of internaldual-fluid (water and air) spray nozzles. The combustion gases enter the top of the chamber, flow downward through the spray pattern and exit from the bottom of the chamber. The spray pattern is designed
, to eliminate direct contact of water with refractory, and the chamber is designedto maintain a dry bottom under all operating conditions. That is, the injection rate of spray water is controlledso that it is completely vaporized and carried out of the chamber in the combustion gases. The tempering chamber is approximately 49' high with 

### 11' I.D. and is fabricated of % inch nominal plate thickness carbon steel (ASTM A36) and lined with refractory. The spray nozzles and extensions are fabricated of 304 SS material. The tempering chamber is sized so that a combustion gas retention time of greater than one second will be maintainedat all gas flows. Because some molten particulate materials in the combustion gases are cooled in this process unitto below their fusion point, some solids are generated and collected in the chamber. Therefore, the chamber has a cone bottom and a slide gate to fac~litate the removal of solids. These solids are discharged onto a conveyor system, which transports them to a hopper. 2.5.1.2 Lime System The lime system prepares lime slurry for use in the chemical neutralization process in sufficient supply and concentration to maintain continuous flue gas treatment in the spray dryer absorber. The system has been designedfor batch mixingto provide this service. Hydrated lime is stored in a storage bin above the lime preparationarea. The storage bin is sizedto hold enough hydrated lime to maintain several days of system operation at the maximum combustion rate of the Q:\rnwS7\Projects\l0002022\Veol1a PerformanceTest Plan U4 R3-052108.docVeolia ESTechnical Solutions Unit 4 HWC MACT Performance Test Plan Revision: 0 Date: May 2008 Section: 2.0 Page 6 of 14
incinerator. Lime is discharged through the conical storage bin bottom. The flow of the material from the bin is aided by a v~brating "live bottom," or b~n activator. A variable speed screw feeder is used to meter the hydrated lime in the proportions required for batch mixing lime slurry The lime is mixed with water in a tank beneaththe lime storage bin. The screw feeder speed and the rate that water is addedto the lime slurry tank are variable so that the desired lime solids concentration can be achieved in the tank. The variable feed adjustments allow water and lime to be added to the lime slurry tank at a rate that will allow a batch mode of mixing. An agitator is provided in the slurry tank to mix the water and lime and to maintain the suspension of lime solids. The mixed lime slurry is pumped at a continuous rate of flow through a recirculation loopto the SDA nozzles. 2.5.1.3 Spray 

### Dry Absorber Unit4 is equipped with two Spray Dryer Absorbers (SDA) located immediately downstream of the Tempering Chamber. Each SDA unit is fabricated of 318 inch carbon steel. The function of the SDAs is to:

w Further cool the combustion gases from 600-800°F to 300-500°F,
w Neutralize and remove HCIand other acids from the combustion gases, Removea portion of the particulate (fly ash) from these gases. Slurry flow to each spray dryer absorber (SDA) is metered by a flow control valve to obtain the proper feed concentration to the spray dryer absorber. Manual adjustment to the flow is made as a function of the SDA outlet temperature and as a function of the output from a hydrochloric acid (HCI) analyzer in the gas duct downstream of the fabric filter. The combined units are sized to remove more than 820 Iblhr.of chlorine from the combustion gases. Each SDA is approximately 72' high by 10'7" in diameter. Each unit includes a head section, and a 60°conical hopper. Each SDA chamber has one access door inthe upper section. Each hopper has one access door, a flanged clean-out port, and a drain connection. The SDA head section consists of a flanged inlet connection and a hot gas inlet plenum. The dual-fluid atomizing nozzles include stainless steel housings and stellited inserts. The nozzles are assembledto permit field removal from the piping. The two lime slurry piping headers have automatic isolation valves. Combustion gases enter the top of each of these units, flow downward through a central duct and are dispersed symmetrically from this duct intothe absorber chamber at a velocity and direction that assures optimal contact with the cloud of atomized lime slurry droplets introduced intothe chamber by dual-fluid (lime slurry and air) nozzles. The gases then flow downward through each absorber chamber and exit through a bottom side duct. As the gases contact and pass through the cloud of atomized lime slurry, the water in the slurry evaporates, cooling the gases. Simultaneously, the lime in the slurry reacts with the hydrogen chloride inthe gases to produce calcium salts. Some of the resulting dry material,

### consisting of calcium salts, fly ash and excess lime, falls to the conical bottom of each unit. The dry material from each unit is dischargedto a conveyor systemwhich transports it to a dump trailer or equivalent type system. 2.5.1.4 Fabric Filter Gas exhausted from the spray dryer absorbers is distributed to two fabric fhter modules connected in parallel. Each module is divided into three compartments connected in parallel, which contain multiple fabric filter bags through which the combustion gases pass to remove particulates. Within each compartment, the gas is passed through Teflon-coated fiberglass cloth bags. The gas passes from the outside to the Inside of the filter

Q:\~~7\Pr0~e~tS\10002022\VeoIia PerformanceTest Plan U4 R3-052108.docRevision: 0 Date: May 2008 Section: 2.0 Veolia ES TechnicalSolutions Unit4 HWC MACT Performance Test Plan Page 7 of 14 bags. Particulate entrained in the gas stream is mechanically deposited on the outside of the filter bags as the gas passes through the cloth. Each compartment has a clean air plenum and housing section to contain approximately308 bags. Each bag is approximately

### 5" in diameter by 

### 5' long. The baghouses are fabricated from 3116" mild steel plate, of welded construction, gas tight and stiffened to withstand the maximum operating negative pressure. Each compartment has a tube sheet that supports the bags and provides for top baglcage removal. Access to the clean arr plenum is via a bolted access door. Each trailer mounted unit contains the compressed air headers, gas inlet and outlet manifolds, and the conveyor. The fabric filter cleaning mechanism utilizes jets of air to clean the filter bags. Periodically,the cleaning sequencew~ll be initiated. The sequence is started when the differential pressure across the filter reaches a predeterminedsetpoint of approximately 8.0" W.C. or when the operator initiates a cycle. The controller then sequences to each row of filter bags in each module, releasing a burst of air oppositeto the direction of gas flow. The quickly released burst of air dislodges dust cake on the exterior of each bag as it travels from the top to the bottom of the bags. Releasedfrom the bag, the dust cake falls by gravity into the hopper at the bottom of the module. From there it is discharged to a conveyor system which transports it to a dump trailer, or equivalent type system. Treated by the spray dryer absorbersand filtered by the fabric filters, the cleaned flue gas exits the fabric filter compartmentsto an outlet manifold for exhaust. 2.5.1.5 Carbon Injection The carbon injection systemw~ll air inject activated carbon intothe plenum immediately upstream of the baghouses and allow for a more efficient means of controlling DioxinlFuran and mercury emissions. This system will be controlled by an existing PLCwhich will control the input of activated carbon to the baghouse inlet plenum. 2 to 20 pounds per hour of powdered activated carbon will be air injected into this plenum and allow for direct contact with the stack gases exitingthe SDA's. The amount of carbon is dosed in a dust-free manner into a low pressure air stream via pneumatic eduction. The eductor uses a blower for the motive air. High and low air pressure switches ensure that the blower is operating correctly and that the carbon delivery system is clear from obstruction. The minimum high pressure setting is 4 psig and the maximum low pressure setting is 1 inch water column. The carbonlair stream will then travel through pipingto the injection nozzle into the ductwork. The carbon will contact the gas stream exiting the SDA's and allow for the adsorption of any dioxinlfurans and mercury that might be present in this stream. Adsorption will continue as the stack gases proceed through the baghouses. The clean stack gas will exit the final stack via the induced draft fan and the captured solids will be discharged from the baghouses via the screw conveying system into an enclosed dump trailer for disposal at a Subtitle C landfill. 2.5.1.6 induced Draft Fan and Stack The induced draft fan and stack are located downstream of the fabric filter. Combustion gases are drawn throughthe system by a 400 hp induced draft (ID) fan, rated at 53,000 acfm at 400' F saturated, and 25"water column pressure. The induced draft fan provides the mechanism for transporting the incinerator flue gas through the spray dryer absorber, fabric filter, and all interconnecting ducts. The ID fan includes an inlet volume control damper to be usedto control the velocity of the gas within the ducting and treatment devices. Treated gases are exhausted from the induced draft fan to the atmosphere through a 100-ft. high stack. The stack diameter for Unit 4 is 48 inches I.D. The stack is equipped with instrument sampling ports and a Q:\mw97\Projects\~OW2022\Veolia PerformanceTest Plan U4 R3-052108.docRevision: 0 Date: May 2008 Section: 2.0 Veolia ESTechnical Solutions Unit4 HWC MACT Performance Test Plan Page 8 of 14 sampling platformfor emissions testing. Figure5-1 providesdetails on the design and sample port locations and configurations for the stack. 

### 2.6 Stack Emissions Monitoring [40 

### CFR §63.1207(f)(I)(iii)(H)] The continuous emissions monitoring (CEM) system consists of sample probes, sample delivery and conditioning apparatus, and gas analyzers. Samples are extracted from the transition ducting located between the ID fan and the stack. A CEM performancetest and quality assurance program has been implemented in accordance with Performance Specifications for Continuous Emission Monitoring of Carbon Monoxide and Oxygen for Incinerators, Boilers and Industrial Furnaces Burning Hazardous Waste, as defined in 40 CFR 266,Appendix IX. Section 2.1. Responses from each CEMS will befed to the Control System (CS) where the CO hourly rolling average is calculated and interlockedto the waste feed cutoff valves as part of theAutomatic Waste Feed Cutoff System (AWFCO) discussed in Section 2.8, below. The following provides a brief description of the CEMS instruments includingthe operating range and measurement principal. 

### 2.6.1 

### CEM System Description The Continuous Emissions Monitoring Systems (CEMS) currently being utilized at Incinerator4 analyzesfor opacity, carbon monoxide, hydrogen chloride, total hydrocarbons and oxygen. These monitors, except opacity, are extractive devices mounted in the ductwork between the ID fan and the stack. The table below summarizesthe analyzer specifications. The opacity monitor continuously measures the stack gas opacity and reports the measurements to an indicator and a recorder. An opacity that exceeds a preset limit triggers an alarm and interlock. Carbon monoxide and hydrogen chloride are monitored with extractive non-disperse infraredanalyzers. Total hydrocarbon is monitored with an extractive flame ion detector analyzer. Oxygen is monitoredwith a zirconium oxide cell. Stack gas flow rate is continuously monitored using an anubar that sends a 4-20 mA signaltothe PLC which converts the signal to acfm. Table 

### 2-1 Veolia ES Technical Solutions -Continuous Emissions Monitors

Q:\mw97\Projects\l0002022\VeoliaPerformanceTest Plan U4 R3-052108.doc Parameter Oxygen 

# r
Carbon Monoxide Total hydrocarbons Hydrogenchloride Opacity Stack gas flow Current Mfg. COSA Echochem MC 3 Thermoelectron Echochem MC 3 Teledyne PSEIRosemount Range 0-25% 0-200 ppmv 0-3000 ppmv 0-100 ppmv 0-1000 ppmv 0-100% 0-55,000 acfm Principle Electrochemical Infrared FIDIlnfrared

lnfrared White light Pressure dropRevis~on: 0 Date: May 2008 Section: 2.0 Veolia ESTechnical Solutions Unit 4 HWC MACT PerformanceTest Plan Page 9 of 14


### 2.7 Process Monitoringand Control The facility is equipped with a state-of-the-art monitoring and control system, which facrlitates compliance with permit conditions, and otherwise, collects process control information, facilitates effic~ent operation and detects and prevents damage to the facility. The system consists of three major components' A human-machine interface (HIVII) system, Programmable logic controller's (PLC's),and A high speed ethernet cable connects all control system components The desired control functions are implemented through the HMI system. All digital control and emergency interlocks are accomplished by the PLC. The control system is capable of monitoringthe "operational envelope" of the incinerator and is capable of performing a number of activities including: Control room indication of processor sensors located within the incinerator system (such as pressure indicationof a field installed pressure transmitter); Process controller for single instrument loopsor an individual sub-system, such as a temperature control loop involving a sensor reading from one temperature transmitter affecting the function of one temperature control valve; and Alarm for an exceedance of a designated setpoint, such as a high pressure or low temperature. The process control computer will continuously control and monitorthe operation of the incinerator. When outof-range conditions exist, it will notify the operator of those conditions.The process control computer is programmed to shut-down equipment (i.e., bring the system into a safe mode) when designated parameters are exceeded, which is a protective mechanism against potential equipment damage, operation outside of permit limits, or conditions that might lead to a release to the environment. Continuous monitoringof the incineratorand scrubber system is an important aspect of the system design. A digital readout of all monitoring instrumentation is displayed on the main control screen. An audible and visual alarm alertsthe incinerator operatorto significant deviationsfrom normal operating conditions. This system allows an immediate response to adverse conditions by the operator. Automatic waste feed cut-off and incineration shutdown mechanisms are also interlocked with the monitoring system at or prior to reaching permit limit levels. Monitoring methods and calibration frequencies are listed in Table 

### 2-3. The Incinerator has an independent process control computer that interfacesto the Allen-Bradley programmable controllers. The process computer is capable of controlling the incinerator in case of a failure in a HMI server. This computer runs a RSVIEW HlVll control software that provides operator interface to all instrumentation and controls. 

### 2.8 Automatic Waste Feed Cut-off System [40 CFR 963.1207(f)(l)(iii)(F)] The incinerator has an Automatic Waste Feed Cut-Off (AWFCO) System that will shut waste feeds off in the event certain operating parameters deviate from allowable set points. The PLC continuously monitors operating parameters, making adjustments to the process as needed for proper control. Alarm logic is incorporated into the PLC system to automatically initiate an AWFCO. Table 2-3 summarizes the current

Q:\rnw97\Projects\l0002022\Veolia Performance Test Plan U4 R3-052108.docRevision: 0 Date: May 2008 Section: 2.0 Veolia ESTechnical Solutions Unit 4 HWC MACT PerformanceTest Plan Page 10 of 14
AWFCO set points. AWFCO limits have been established based on several factors that are summarized below. Reuulatorv/~ermit limits 

### -established to comply with existing permits. An example of this type of limit is the low temperature limit, below which waste cannot befed untilthe proper limit is re-established. In addition,the HWC MACT regulations requirethat the AWFCO system be interlocked with the span of each process instrument that is part of the Continuous Monitoring System (CMS). A listingof these CMS instruments and their interlocked span setpoints is maintainedas part of Veolia's Operating Record. Process safety limits -established to assure process equipment is protected and unsafe operating conditions do not occur. An example of this is inadequate excess air in the combustion chamber that can lead to fuel rich conditions. Utilitvor Power failure -established to facilitate a controlled shutdown of the process during loss of process air, steam, water or electricity. An example of this is the loss of instrument air that is necessaryfor certain types of process instruments to function properly. Wastes will not be reintroduced into the incinerators until proper operation of key instruments is re-established. In addition to the AWFCO system, operators can manually shutdown waste feeds or the entire process should this be needed. 

### 2.8.1 AWFCO System Testing Veolia tests the AWFCO systems bi-weekly. Instrument calibrationsare performed as indicated in 

### Table 2-3. In some cases this testing occurs more frequently depending on how often actual AWFCOs occur at the unit. Per the requiredfrequency, Incinerator personnel check the functionality ofAWFCO logic that is part of the incinerator's PLC system to make sure that should process conditions deviate from allowable limits, the computer logic will initiate waste feed shutdowns as required. This is accomplished by manually simulating process conditions that are outside allowable limits and observing and documenting when the control or block valve software logic on the waste feed line begins to initiate valve closure. Should actual AWFCOs occur during a given testing period, these are documented by operating personnelto satisfy regulatory requirements for system testing. Results of this testing are documented on a separate AWFCO Test~ng Log and maintained as part of the unit's Operating Record. 

### 2.9 

### Air Pollution Control Equipment Maintenance Practices [40 

### CFR 563.1207(f)(l)(iii)(G)] 2.9.1 Program Overview Once equipment is installed and operational, Veolia utilizes an extensive preventative maintenance (PM) program to keep equipment operational and prevent breakdowns and failures. Based upon the type of equipment and historical operations and maintenance experience, schedules for various inspection and PM activities are followed. This includes aspects such as documenting detailed maintenance histories on equipment, routlne inspection and lubrication programsfor high wear equipment and non-destructivetesting of piping and vessels uslngtechniques like ultrasoundto assess integrity. The frequency of these activities varies depending upon the equipment, PM activity and the incinerator's shutdown schedule. For example, frequent (i.e.,weekly) instrument and certain mechanical equipment checks are madefor critical process items. Lubrication, vibration analysis and other mechanical integrity checks are done at longer
Q:\mw97\Projects\l0002022\Veol1a PerformanceTest Plan U4 R3-052108.docVeolia ESTechnical Solutions Unit4 HWC MACT PerformanceTest Plan Revision: 0 Date May 2008 Section: 2.0 Page 11 of 14 frequencies like monthly or quarterly. And finally, such items as inspecting refractory brick for wear, are typically performed when the entire incinerator is shut down for maintenance. 

### 2.9.2 

### Test Program Preparation Activities Prior to testing, instrumentation associated with key parameters of the test will be checked, calibrated, or replaced, as appropriate, to ensure proper operation of the instrumentation during testing (i.e.,waste feed flowmeters and scales, CEM's, pressuretransmitters, thermocouples and pyrometers, stack flowmeters, etc.).

Q:hw97\Pro~ects\l0002022\Veoi1a Performance Test Plan U4 R3_05210B,docRevision: 0 Date: May 2008 Section: 2.0 Veolia ESTechn~cal Solutions Unit 4 HWC MACT PerformanceTest Plan Page 12 of 14
Table 

### 2-2 Technical InformationSummary on Incinerator No. 4 

# 11 TY pe 

# 1 Rotary Kiln 

# 11 -- Manufacturer

Model No.



# 11 External Diameter 

# I TradeWaste Incineration TWI-2000, Series 2
Dateof Manufacture Dimensions 

## 1 External Length 

# (1 Internal Diameter 

# I 7' 

# I 9' 

# 11 1989 

### 11 Primary Chamber 35'

Cross-sectional area Burners Manufacturer Size

Q.\mwSilProjects\l0002022\Veolia PerformanceTest Plan U4 R3-052108.doc Secondary Chamber 48'6"

Fuel Primer Mover 38 square feet Primary Chamber Burner North American 12.0 Million Btu/hr 64 square feet Secondary Chamber Burner Trane Thermal 30 Million Btuthr Natural Gas Natural Gas Induced Draft Fan 4,000 acfm @ 400°F saturated, 20 in. water columnVeolia ESTechnical Solutions Unit4 HWC MACT Performance Test Plan Revaion: 0 Date: May 2008 Section: 2.0 Page 13 of 14

-- - Table 2-3 Current AWFCO Parametersand Limits for Incinerator No. 4

Q~\mw97\Pro~ects\l0002022\Veolia PerformanceTest Plan U4 R3-052108.doc System Primary Combustion Chamber Temperature Device Pyrometer Units OF
Secondary Combustion Chamber Temperature Primary Combustion Chamber pressure Secondary Combustion Chamber pressure Spray Dryer Adsorber Inlet Temperature Spray DryerAdsorber Outlet Temperature Total PumpableWaste Feedrate Total Waste Feedrate
LVM Feedrate SVM Feedrate Mercury Feedrate Chlorine Feedrate Ash Feedrate Carbon Feedrate Chlorine Feed to Slurry Flow Ratio Combustion Gas Flow Rate Stack Gas Excess Oxygen OF
in,W.C.
in. W.C.

OF OF
Iblhr Iblhr Iblhr Iblhr Iblhr Iblhr Iblhr Iblhr Ratio acfm

% Type 

### K Thermocouple Pressure transmitter

Pressure transmitter

Type 

### K Thermocouple Type 

### K Thermocouple Mass flow meterlscales

Mass flow meterlscales

Mass flow meterlscales

Mass flow meterlscales

Mass flow meterlscales

Mass flow meterlscales

Mass flow meterlscales

Mass flow

meter Flow Meter

Anubar Zirconium Oxide fuel cell Cutoff Limits 51,240 (one-minute average) <I ,507 (HRA') 22,400 (instantaneous) 

# ---- Calibration Frequency

Annually
51,825 (one-minute average) <I,886 (HRA') 22,400 (instantaneous) 2 atmospheric (instantaneous)
2 atmospheric (instantaneous)


### r 1,200 (one minute average)

2 500 (one mlnute average) >435 (HRA) >4262 (HRA) >14,802 (HRA) >I20 (12 HRA)
>I17 (12 HRA)
>0.067 (12 HRA)
>274 (1 2 HRA)
>8777 (12 HRA) 

### >6 (HRA)

>44 4 2 43,900 (HRA) 5 3 (one minute average)



### - Annually
Quarterly Quarterly Annually Annually Annually Annually1 Quarterly Annually1 Quarterly Annually1 Quarterly Annually1 Quarterly Annually1 Quarterly Annually1 Quarterly Quarterly Annually Annually QuarterlyVeolia ES Technical Solutions Unit 4 HWC MACT Performance Test Plan Revision: 0 Date: May 2008 Section: 2.0 Page 14 of 14

Q:\mw97\Projects\lO002022\VeoliaPerformanceTest Plan U4 R3-052108.doc System Stack carbon monoxide Stack Hydrocarbon Stack gas opacity Stack hydrogen chloride L~quid feedrate

- Sludgefeedrate Drummedand Bulk Solids Feedrate Fabric filter pressure drop

HRA means "hourly rolling average" as calculated by averaging the previous60 one-minute average values. Device Infrared

FID White Light

Infrared Mass flow

meter Mass flow

meter Scale Delta 

### P transmitter Units PPmV
ppmv



### % PPmv Ib/hr Ib/hr Ib/hr 

### in.W.C. Cutoff Limits 2100 (HRA) 2500 (one minute average) 210 (one minute average) 210 (one minute average) 2100 (HRA) 2500 (one minute average) 2 1,700 21,100

2 15,000

5 

### 2 or 

### 2 10 (one minute average) Calibration Frequency Quarterly Quarterly Quarterly Quarterly Annually

- Annually Quarterly QuarterlyVeolia ES Technical Solutions Unit4 HWC MACT PerformanceTest Plan Revision: 0 Date: May 2008 Section: 3.0

Page 1 of 4 

## 3.0 

## Illcinerator Feed Stream Descriptions

3.1 

### General Veolia treats a broad range of wastes and thus the individual streams that may make up the incinerator overall feed at any given time can vary greatly, depending on generator production and shipping schedules. Priorto schedulingwastes for shipment to the facility, the waste streams are characterized by the generator and reviewed by Veolia staff. A Waste Profile Number uniquely identifies each different waste stream. This assuresthat only pre-approved wastes are handled at the facility and that all necessary regulatory, handling, safety and other important information is availableto Operations personnel. Organic Hazardous Air Pollutants (HAPs) measured or expected (based on process knowledge) to be present in a source waste at or above approximately 0.1 % by weight are listed in the tables in this Section. Organic HAPS not listed are, based on process knowledge, believed to be either completely absent or present in the waste at less than 0.1 % by weight. In addition to the information below that summarizes the top volume waste streams processed at Veolia, Table 3-1 providesa summary of the major HAPs processed at the facility. 

### 3.2 High Volume Wastes 3.2.1 Liquid Wastes Liquid wastes are received at the Sauget facility in tank trucks and drums and are e~ther direct fed through a dedicated line or are blended with other compatible waste streams into the tank farm. Table 3-1 providesa summary of the top volume liquid streams that have been processed in the last year. Liquid wastes can be processed in any one of the three incinerators. These streams can be organic, aqueous or a mixture. 

### 3.2.2 Bulk Solids Table 3-2 provides a summary of the top bulk solid streams handled at the Sauget facility. Bulk solids can includestreams like contaminated soils, wastewater sludges or manufacturing process solids. These wastes are received at the site primarily in 20 to 40 cubic yard roll-off containers or other similar bulk transport vehicles. 

### 3.2.3 ContainerizedWaste Table 3-3 provides a summary of the top containerized waste streams handled at Sauget. Containerized wastes are received in drums and smaller cartons, boxes or pails and can include materials such as laboratory waste, spent carbon, process residues. 

### 3.3 Auxiliary fuels Natural gas or 

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

Q:\mw97\Projects\l0002022\Veolia Performance Test Plan U4 R3-052108.docVeolia ESTechnical Solutions Unit 4 HWC MACT PerformanceTest Plan Revision: 0 Date: May 2008 Section: 3.0

Page 1of 4 

## 3.0 

## Incinerator Feed Stream Descriptions

3.1 General Veolia treats a broad range of wastes and thus the individual streams that may make up the incinerator overall feed at any given time can vary greatly, depending on generator production and shipping schedules. Priorto schedulingwastes for sh~pment o the fac~lity, the waste streams are characterrzed by the generator and reviewed by Veolia staff. A Waste Profile Number uniquely identifies each different waste stream. This assures that only pre-approved wastes are handledat the facility and that all necessary regulatory, handling, safety and other important information is availableto Operations personnel. Organic Hazardous Air Pollutants (HAPs) measuredor expected (based on process knowledge) to be present in a source waste at or above approximately 0.1 % by weight are listed in the tables in this Section. Organrc HAPS not listed are, based on process knowledge, believedto be either completely absent or present in the waste at less than 0.1 

### % by weight. In additionto the information below that summarizesthe top volume waste streams processed atVeolia, Table 3-1 provides a summary of the major HAPs processedat the 

### facility. 

### 3.2 

### High Volume Wastes 3.2.1 Liquid Wastes Liquid wastes are received at the Sauget facility in tank trucks and drums and are either direct fed through a dedicated line or are blended with other compatible waste streams into the tank farm. Table 3-1 provides a summary of thetop volume liquid streams that have been processed in the last year. Liquid wastes can be processed in any one of the three incinerators. These streams can be organic, aqueous or a mixture. 

### 3.2.2 

### Bulk Solids Table 3-2 providesa summary of the top bulk solid streams handled at the Sauget facility. Bulk solids can include streams like contaminated soils, wastewater sludges or manufacturing process solids. These wastes are receivedat the site primarily in 20 to 40 cubic yard roll-off containers or other similar bulk transport vehicles. 

### 3.2.3 Containerized Waste Table 3-3 providesa summary of the top containerized waste streams handled at Sauget. Containerized wastes are received in drums and smaller cartons, boxes or pails and can include materials such as laboratory waste, spent carbon, process residues. 

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

Q:hw9T\Projects\l0002022\VeoliaPerformance Test Plan U4 R3-052108.docRevision: 0 Date: May 2008 Section: 3.0 Veolia ESTechnical Solutions Unit 4 HWC MACT Performance Test Plan Page 2 of 4
Table 3-1 Top Volume Liquid Waste Streams

Table 3-2 Top Bulk Solid Waste Streams

Q:\mw97\Projects~10002022\Veolia PerformanceTest Plan U4 R3_052108.doc Profile 396871 346603 562221 330548 396775 351070 674065 350400 024042 360069 Waste Name DOG FOOD HYDROCARBON TANK BOTTOMS BULK SOLID WASTE BTU >5000 HYDROCARBON WASTE FROM PETROLE WASTEWATER TRASH BOXES-DRY CWD BULKED INCINERATION SOLID DRUMS & BULK CONTAINING GREASE SMALL PAINTCANS SURGE TANK CLEAN OUT PRIMARY SEPARATOR SLUDGE Annual Pounds Received 9,682,704 3,677,040 2,638,520 2,567,400 1,613,940 1,610,360 1,557,680 1,380,780 1,058,000 956,980Veolia ES Technical Solutions Unit 4 HWC MACT Performance Test Plan Revision: 0 Date: May 2008 Section: 3.0

Page 3 of 4
Table 3-3 Top Containerized Solid Waste Streams

Table 3-4 Summary of Major HAPS Processed

Q:\mw97\Projeds\l0002022\Veol1aPerformance Test Plan U4 R3-052108.doc Annual Pounds Received 1,635,929 1,439,51'3 1,026,877 858,467 855,396 771,078 648.240 646.796 579,685 567,961 548,425 547,098 Profile SOLO03 395485 CG6944 BB1445 LOP003 393399 393758 360169 346662 640004 PZLOP4 579751 Waste Name SOLIDS CHLORINE < 25% NON-HAZ PRODUCTION WASTE PPE PILOT PLANT SOLVENTS REP LAB PACK (DCN) LOOSE PACKS OF NON-REGULATED PHARMACEUTICALS (DEA) Q8-6061 SILOXANE DRLIMS M865 ROUNDS FLAMMABLE LAB WASTE PHARMACEUTICAL SAMPLES LOOSE PACKS OF NON-REG USED SHARPS WITH CONSUMER PRODUCTSRevision: 0 Date: May 2008 Section: 3.0 Veolia ES Technical Solutions Unit 4 HWC MACT Performance Test Plan Page 4 of 4
Table 3-5 Typical Properties for Supplemental Fuel Oil

Table 3-6 Typical Properties for Natural Gas Parameter Heat Value Ash Content Chloride Content Antimony Arsenic Barium Beryllium Cadmium

Q:\mw97\Prqects\10002022\Veolia Performance Test Plan U4 R3-0521OB.doc Parameter Chromium Lead Mercury Nickel Selenium Silver Thallium Units Btullb 

### %wt % wt PPm PPm PPm PPm PPm

Component Methane Ethane Propane lsobutane N-butane lsopentane N-pentane Hexanes Parameter Heat Content, gross, dry Heat Content, Units PPm PPm pPm 

### --- PPm PPm PPm PPm Value > 17,000 < 5.0 < 2.0 < 1.0 < 1.0 < 2.0 < 2.0 < 5.0 Value 2.0 < 20 IVIA < I0 < 0.1 < 0.1 < 0.05

Value 0019 0.005 0.703 0.824 0.014 0.023 0.0 0.004 Value 0.592
gross, sat. Units mole % mole % mole% mole % mole % mole 

### Oh mole 

### Oh mole %

ppp Units Btu/CF Btu/CF Component Heptanes Octanes Nitrogen Carbon D~oxide Helium Hydrogen Argon Oxygen Parameter Relative Density

PP 

# WObbe Index Value 94.428 3.081 0.582 0.087 0.129 0.040 0.032 0.029 Value 1040.5 1023.6 Units mole% mole % mole % mole % mole % mole % mole % mole % UnitsVeolia ES Technical Solutions Unit4 HWC MACT PerformanceTest Plan Revision: 0 Date: May 2008 Section: 4.0

Page 1of 7 

## 4.0 

## Performance Test Protocol
4.1 General Description This Performance Test Plan has been designed to demonstrate performance under a single test condition using a combination of actual and spiked feeds. This test condition will be designed to establish maximum metalsfeed rates while demonstrating conformance with applicable HWC MACT metals emissions standards. Duringthe performance test, Veolia will be seeking to establish new Operating Limits for Unit 4. Dueto this. Veolia will adjust the limits at which the AWFCO system activates except for carbon monoxide. At the end of each day of testing, current AWFCO limits will be reinstated back to currently established limits. 

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

### 4.3 Test Conditions [40 CFR

# 5 63,1207(f)(l)(vi) and (vii)] The test condition for this performance test is designed to demonstrate compliance with the applicable MACT metals emissions standards. Unit

### 4 will be operated at normal combustion zone temperatures during this condition with normal waste feed rates. The flue gas flow rate and chlorine feed ratewill be maximized. The baghouse inlet temperature will be maximized The proposed operating limits for the performance test are summarized in Table 4-1. 

### 4.4 Waste Feed Spiking In order to demonstrate the required performance criteriafor this program, it will be necessary to fortify (spike) the incinerator feeds with organic and inorganic constituents. The spiking levels and approach proposed for this performance test have been used successfully in the past for testing at not only Veolia but for testing at other hazardouswaste combustion facilities as well. Each spiked material will be preparedto a known specification and verified by a certificate of analysis. These materials will be prepared and fed in a manner that assures a very consistent feedrate. Feed rates of each spiked compound are chosen to bewell above expected levels in native wastes, generally 

### an order of magnitudeor more higher, so that the spiked constituent is the dominant feed and the native contribution is not significant. Spiking rates are also selected based on historical performanceto assure that emissions can be detected and actual results, versus non-detect results,are used in calculation removal efficiencies.

0:hw3AProjects\10002022\VeoliaPerformanceTest Plan U4 R3-052108.dacRevision: 0 Date: May 2008 Section: 4.0 Veolia ES Technical Solutions Un~t 4 HWC MACT PerformanceTest Plan Page 2 of 7


### 4.4.1 

### Inorganic Constituents Several metals will be spiked to the system to permit calculation of system removal efficiencies (SREs), which can then be used to determine appropriatefeed rate limits, as necessary. Regulated metals may be fed at some level in the native waste materials to be used during the test. However, these native concentrations may not be h~gh enough to achieve the desiredfeed rate limits to be set for the system. Therefore, Veolia plans to spike three surrogate metals at higher than normal rates to ensure that sufficient metals are fed to achieve measurable emissions in the stack emissions. Table 

### 4-2 provides an overall summary of information relevant to the metalstest~ng portion of the program. SRE data from previous test programs have been used in conjunction with present feed rate limits and present MACT emission limitsto specify target feed rates that will result in acceptable emission rates. This table is only used as a predictivetool, however, and final limits to be imposed will depend on the actual resultsof the pelformancetest. Two other points are worth noting with regardto Table 4-2: The spiked amount for a given metal will bethe difference between the desired feed rate limit and the native quantity expectedto fed during the test; and Surrogate metals will represent the whole group (in the case of LVM and SVM) and test results will be used to extrapolate up to the applicable MACT standard. The three metalsto be spiked are representativeof the three classes of metal volatility and therefore can be used to set limits for any metals not spiked. 

### 4.4.2 

### Spiking for the LVM Category The LVM Category for incinerators includes arsenic, beryllium and chromium. Veolia plans to spike chromium at 40-45 Iblhrto establish a SRE for all three test runs. The SRE demonstrated during the pelformance test for chromiumwill be used to establish a LVM feed rate limit. Chromium w~ll be spiked as chromic acid through a liquid feed ipjectorvia a pumping station that will monitor the feed rate. 

### N Waste chromic acid is treated at Veolia and thus, spiking chromic acid during the performance test is representativeof normal operations. 

### 4.4.3 

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

## leadwill be used to establish a SVM feed rate limit. Leadwill be spiked as lead nitrateand delivered in small, pre-measured plastic baggies at regular intervals along with other solid waste feeds during the performance test. Lead containing waste that are normally treated at Veolia are predominantlybulk or containerized solids and thus, this spiking approach during the pelformance test is representative of normal operations. 

### 4.4.4 

### Spiking for Mercury For mercury, the only high volatile metal, Veolia plans to spike this at approximately 0.01 

### -0.02 Iblhrand will follow a similar approach as noted above for the other MACT-regulatedmetals. Mercury will befed as a mercuric nitrate solution at regular intervals along with other solid feeds during the performance test. Mercury is predominantly present in solid feeds processedat Veolia and using a liquid solution for spiking will provide
Q \rnw97\Prqects\l0002022\Veolia Performance Test Plan U4 R3-052108.docRevision: 0 Date: May 2008 Section: 4.0 Veolia ESTechnical Solutions Unit 4 HWC MACT Performance Test Plan Page 3 of 7

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

### 4.5 Metals Extrapolation Method Veolia plans to extrapolateto higher feed rate limits than actually fed during the test using the performance test -established SREs. This is appropriate since it is generally agreed that SREs at higherfeed rates would be at least as good as those observed at the lower level. Any extrapolation performed will take into consideration the MACT standards to ensure full compliance. Based on previous discussions with EPA Region 5, the following approach will be used. The average SRE for the three runs would be calculated from the feed and emission rates for each run and an average SRE for the performancetest. A feed rate limit would then be calculated for each metal category by dividing 75% of the emission standard for that category by the SRE for the spiked compound representing that category. A similar approach would be followed for SVM (cadmium and lead) and for mercury. To further assure that this method is protective, Veolia proposes to limit the maximumfeedrate for any one categoryto 10 times the spiked feed rate during the performance test. The test program will establish 12-hourfeed rate limits for the MACT metals. Example calculations are show below: Maximum emission rate for extrapolation

= (emission standard (pg/m3@ 7% 

### 02) * 0.75 * QstacK (dscfm @ 7% 

### 02) " 0 0283 m3/ft3* 60 min/hr)l(453.6gllb * 

### lo6 ~glg) Maximum extrapolatedfeed rate



### = Maximum emission rate/ (1 

### -SRE from performance test) 

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

# 5 63.1207 (f)(l)(vi) and (vii)] To the extent possible (and with the exception of the spiked constituents noted above), only normal waste materials processed at the facility will be fed to the incinerator during the test program. Waste materials will be stockpiled to meet the objectives for the target performance test parameters. These wastes will be characterized in advance of the test and kept until needed. Allwaste materials will be deliveredto the facility in accordance with routine operation and currently permitted proceduresas described elsewhere in this document. 

### 4.7 Conditioning Time Needed to Reach Steady State [40 CFR 

# 5 63.1207(f)(I)(xii)] The incineratorwill be operated for 15 minutes at the desired feed rates and operating conditions before sampling begins for a given condition of the performance test. This will assure all operating parameters are stabilized at the desired settings to achieve steady state before sampling. 

### 4.8 

### Anticipated Test Schedule The performance test will be performed over a 4-day period using a three-person field crew accordingto the schedule shown in Table 4-3. For this performance test, it is anticipated that all runs will be approximately two hours in duration,as dictated by the sample run time required for metals measurements. The performance test program for this incineratoris planned to start on or after August 1, 2008.
Q:\1nw97\Projects\10002022\Veolia PerformanceTest Plan U4 R3-052108 docVeolia ESTechnical Solutions Unit4 HWC MACT Performance Test Plan Revision: 0 Date: May 2008 Section: 4.0

Page 4 of 7


### 4.9 Performance

### Test Reporting The final report will be preparedfor submittal no later than 

### 90 days from completion of the field test program. This document will provide a concise presentationof performance test results and will include all necessary supporting documentation. An example outline of the final performance test report is presented below: Section 

### 1.0 Certification 

### - Includes project title, statement of compliance and project approval signatures Section 2.0 Summary of Test Results-Summary of emission results compared to applicable standards; interim status operating limits; overview of process operating conditions; Section 3.0 Project Overview 

### - Facility and unit description; project background and scope; test requirements; test chronology and report organization Section 4.0 MACT Notification of Compliance 

### - Regulatory requirements; performance test results and compliance determination; area or major source determination: description of air pollution control system; and description of process monitoring systems Section 5.0 Process Operating Conditions

## - Overv~ew of test condit~ons and summary of facility process monitoring data Section 6.0 Sampling and Analytical Program Overview 

### -Summary of proposed plans and discussion of actual activities and any required deviations from plan Section 7.0 Test Results 

### - Detailed presentation of waste analysis and stack sampling results including tabulated presentationof all data Section 8.0 Quality Assurance 

### 1 Quality Control 

### - Detailed discussion of waste and stack sampling and analytical

### QAtQC procedures and results APPENDICES A 

### - Facility Process Monitoring Data 

### B 

### - Spiking Report 

### C 

## - Field Sampling Documentation D -Analytical Data Reports

Q:\mw97\Projects\l0002022\VeoIia PerformanceTest PlanU4 R3-052108.docVeolia ES Technical Solutions Unit 4 HWC MACT Performance Test Plan Revision: 0 Date: May2008 Section: 4.0

Page 5 of 7
Table 4-1 IVlACT OPLs to be Established Duringthe Performance Test

Q:\mw97\Projects\l0002022\VeoliaPerformance Test Plan U4 R3-052108.doc Process Parameter Maximum Flue Gas Flowrate Maximum Low Volatile Metals (LVM) Feed Rate Maximum Total Pumpable LVM Feed Rate Maximum Semi-volatile Metals (SVM) Feed Rate Carbon Feed Rate MaximumChlorineIChloride Feed Rate MaximumTotal Mercury Feed Rate Maximum Fabric F~lter Inlet Temperature Avg

## . Period



### I -hr 12-hr 12-hr 12-hr I-hr 12-hr 12-hr



### I -hr Units acfm Ib/hr Ib/hr Ib/hr Ib/hr Iblhr Iblhr.



### "F How Limit Established Average of maximum HRAs for each run Average of the average HRAsfor each run Average of the average HRAs for each run Average ofthe average HRAs for each run Average of the average HRAs for each run Average of the test run averages Average of the test run averages Average of the test run averages Expected Limit 40,000

## -45,000 400 

### -450 400 

### -450 600 

### - 650 6-7 250-350 0.1 

## - 0.2 400 

### - 440Veolia ES Technical Solutions Unit 4 HWC MACT Performance Test Plan Revision. 0 Date: May 2008 Section: 4.0

Page 6 of 7

Table 4-2 Metals Evaluation Plan

Assumptions: Qs = stack gas flow rate = 02= stack oxygen level = MACT Standards: SVM (Cd and Pb) = LVM (As, Be and Cr) = Mercury = 18,600 dscfm 12.0 % vol. Metal Mercury SVlM Chromium *

* Surrogate metals to be spiked during the 2008 Performance Test Expected Metal SRE (%) 85.00% 99 9999% 99 9999%

Q:\rnw97\Projects\l0002022\VeoliaPelformance Test Plan U4 R3-052108 doc Historical Desired Feed Range Feed Rate (Iblhr) Limit (Iblhr) 0 1 600 

### - 650 400 

### - 450 Expected Spiked Quantity (Iblhr) 0 02 60 

### - 75 40 

### - 45 Projected Emission Rate at the Desired

Feed Rate Limit (Iblhr) 0 002 0 001 0 0005 lJglm3@ 7% 02

33 14 5 10 0Revision: 0 Date: May 2008 Section: 4.0 Veolia ESTechnical Solutions Unit 4 HWC MACT Performance Test Plan Page 7 of 7
Table 4-3 Anticipated IVletals Performance Test Schedule General Overview of Planned Schedule

Example of Detailed Daily Schedule (Day 2 Above) 

# 1

Q:\mw97\Projects\l0002022\Veolia PerformanceTest Plan U4 R3-05210B.doc Activity Mobilization,site safety training and set-up Preliminary traverses, Conduct Run 1 and Run 

### 2 Conduct Run 3 Equipment removal and depart site



## 1 Schedule Day 1 Day 

### 2 Day 3 Day 4

Test Activity Incinerator lined out on trial burn wastes Begin metal spiking Initiateall stack sampling and waste sampling Approx. end time for sampling runs Recovery of sampling train Depart Site Time 07:OO 08:30 08:45 15:OO 15:OO 

### - 16:30 17:OO

### Veolia ESTechnical MACT Unit 4 HWC 

### PerfomanceTest Plan Rev~sion: 0 

### Date: May 

### 2008 Section: 5.0 Page 1

### of 26 

## 5.0 Sampling and Analytical Program Quality AssuranceIQuality Control

This sectlon presentsthe Quality Assurance and Quality Control goals, objectives, and proceduresfor the MACT Performance Test program.The quality assurancelquality control procedures and criteria for this program will comply with the requirements of this document and its updates. The analytical work conducted will incorporatethe QNQC requirements of the approved methods.This document has been prepared using available guidance provided in the following EPA documents: "EPA Requirementsfor Quality Assurance Project Plans", EPA QNR-5, November 1999. "Component2 

### - How to Review a Quality Assurance Project Plan (including Attachment A 

### - Generic Trial Burn QAPP", Hazardous Waste Combustion Unit Permitting Manual, U.S. EPA Region6, January 1998. "Handbook

## - QualityAssuranceIQuality Control (QNQC) Procedures for Hazardous Waste Incineration"(EPN62516-891023January 1990).



### P""i Quality Assurance Project Plan for Veolia ES Technical MACT Metals Performance Test on the Rotary Kiln IncinerationNumber 4 

### Facility ID Number: lLD098642424 

### Prepared for: Veolia ES Technical. 7 

### Mobile Avenue, Sauget, IL 62201 

### Prepared by: ENSR Corporation, Westford, MA 01886 

### Revision No.: 0 

### Date: May2008

Q:\mw97\Projects\l0002022\Veolia PerformanceTest Plan U4 R3-052108 docVeolia ES Technical IMACT Unit4 HWC Performance Test Plan Revision: 0 Date: May 2008 Section: 5.0 Page 2 of 26


### 5.1 

### Title Page 5.1.1 Project Title QualityAssurance Project Planfor Veolia ES Technical Solutions HWC MACT Metals Performance Test Plan for the Rotary Kiln Incineration System 

### 5.1.2 Expected PerformanceTest Date On or after August 

### 1,2008. 

### 5.1.3 Project Approvals

Veolia Project Manager

*"-- ENSR Project Manager

ENSR QA Officer

Maxxam Analytics Lab Services Coordinator Date

Date

Date

Date

Q:hw97\Projects\l0002022\Veolia PerformanceTest Plan U4R3-052108.docVeolia ES Technical MACT Unit 4 HWC Performance Test Plan Revision: 0 Date: May 2008 Section: 5.0 Page 3 of 26


### 5.2 Table of Contents A complete table of contents, including listings of tables and figures and acronyms is presentedat the beginning of this PerformanceTest Plan and includes all pertinent information applicable to this QAPP section. 

### 5.3 Project Description This project will consist of a comprehensive sampling and analysis program designed to demonstrate compliance with the HWC MACT rule requirements. Testing will be performed under one process operating condition, entailing triplicate sampling runs. Operating parameter limits (OPLs) associated with metals emissions testing will be re-established or modified based on the results of the program. The reader is referred to Sections 1.3, 1.4,2.5.3 and 4.0 for further details on program scope, test objectives and target parameters for emission measurements and process monitoring. The remainder of this section outlines the detailed measures that will be followed to ensure collectionof val~d data. A brief overview of the measurements to be made during the test program is provided in Table 5-1.

### A more detailed summary of the sampling and analytical program is provided later in Section 5.6. 

### 5.4 Project Organization The ENSR Project Manager, IMr. Jeffrey Gorman will be responsible for the overall direction of this program and will report to the Veolia Project Manager, Mr. David Klarich. Mr. Gormanwill be responsible for project 

### r""* design and implementation, communicating with the client, scheduling all activities, reviewing all project data and preparing all reports. Hewill be assisted in the oversight of Quality Assurance activities by the program Quality Assurance Officer (QAO) and each Analytical Laboratory Services Coordinator (LSC). Each contract laboratory will have one individual designated as the person responsible for project activities. 

### 5.4.1 

### QA Officer's Responsibilities IVlr. Craig Doolittle

### will serve as the project Quality Assurance Officer (QAO) and 

### will be responsible for review and approval of the Quality Assurance Project Plan presented in this section, as well as any subsequent revisions. Hewill monitor implementationof field and laboratory activities, scheduling performanceand/or system audits as warranted. The QAO will report to the Project Manageron any conditions noted which may adversely affect data quality. Mr. Doolittle will provide independent oversight for data verification and data quality assessment activities. He will preparea section for the Final Report summarizing QAlQC activities and provide an overall evaluation of data quality. 

### 5.4.2 

### Laboratory Coordinator Responsibilities Each analytical laboratory will designate a Laboratory Services Coordinator (LSC), who will be the principal point of contact for the ENSR Project Manager. The LSC will review QA requirements with all laboratory staff to ensurethat all required measures are taken to meet data quality objectives.They will monitor the shipment and receipt of samples, track analytical progress and review data as reported from the laboratories for completeness. Each LSC will be responsible for validation of all data generated by the laboratoryfor this programand 

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

Q:\mwS~Projects\l0002022\Veolia Performance Test PlanU4 R3-052108.docRevision: 0 Date: May 2008 Section: 5.0 Veolra ESTechnical MACT Unit4 HWC PerformanceTest Plan Page 4 of 26


### 5.5 QAIQC 

### Program Objectives 5.5.1 Precision, Accuracy and Completeness The collection of data to fully characterize the incinerator waste feed materials and stack gas emissions requires that sampling and analysis procedures be conducted with properly operated and calibrated equipment by trained personnel.QA objectives for measurements made in the field are summarized in 

### Table 5-2. QA objectives specific to each analytical methodology performed by the subcontractor laboratories are presented later in Section 5.9. The overall program has been designed with consideration of sampling parameters and analytical limits to ensure that the achieved MDLsfor emissionswill be more than adequate for regulatory limit decisions. Critical MDL determinations are addressed subsequently in Section 5.5.3. Precision IS defined as a measurementof mutual agreement among individual measurements made under prescribed similar conditions. Precision is expressed in terms of relative percent difference (RPD) between duplicate determinations and in terms of relative standard deviation (RSD) when 3 or more determinations are made. Overall precision for analysisof the waste feed streams will be assessed through the analysis of one set of duplicate samples for each designated parameter. Accuracy 1s the degree of agreement of a measurement with an accepted reference or true value. Analyt~cal accuracy will be measured through the recoveries of matrix spikes, analysis of standard reference materials or audit sample analys~s. Matrix spike samples for the waste feed will be prepared by spiking known amounts of target analytes into a portion of the sample Recoveries are monitored to assess laboratory and method accuracy. Laboratory control samples (LCS) will also be usedto distinguish between method performance and matrix effects on accuracy. LCS and MS spiking solutions will be independent from calibration standards. Completeness is a measure of the amount of valid data obtained compared to the amount that was expected under normal conditions The overall program objective is to obtain valid data for three (3) runs for each test condition. For all data considered critical to the investigation,a completeness objective of 100% has been established. As a result, critical priority data from each of three (3) runs should achieve the precision and accuracy goals established herein. This completeness criterion applies to all permit parameters in emissions samples as well as feedlprocess stream samples. Individual samples for which the critical data points do not achieve accuracy and/or precision data quality objectives may require reanalysis. Results for samples where matrix interferences preclude meeting objectives for the recoveries of surrogates or spikes will be evaluated for potential bias to calculated emission results. In summary, the completeness goals are stated at 

## loo%, since three valid runs are necessaryto assess operation at any one condition. 

### 5.5.2 Representativeness and Comparability It is recognizedthat the usefulness of the data is also contingent upon meeting the criteria for representativeness and comparability. Wherever possible, reference methods and standard sampling procedures will be used. The QA objective is that all measurementsbe representative of the matrix and operation being evaluated. The detailed requirements for sampling given in the various EPA Reference Methods will be followedto ensure representative sampling of flue gases. The sampling of incinerator feed streams priorto the performance test will provide representative samples of these matrices. The correspondingQA objective is that all data resulting from sampling and analysis be comparable with other representative measurements made by the performance test field team, on this or a similar process operating

,uJslr~slr under similar conditions. The use of published sampling and analytical methods and standard reporting units will aid in ensuring the comparabilityof the data.

Q:\rnw97\Projects\l0002022\Veol1a PerformanceTest Plan U4 R3-052108,docVeolia ESTechnical MACT Unit4 HWC Performance Test Plan Revision: 0 Date: May 2008 Section: 5.0 Page 5 of 26


### 5.5.3 Method Detection Limit (MDL) Determinations Method Detection Limits (MDLs)for the various analytes to be measured in this program will be determined following well-established laboratory procedures in accordancewith standard EPA protocols. These are described below for those parameters deemed most crucial to the program. 

### 5.5.3.1 Metals 

### - Methods 6020 and 7470A Reporting limits for all metals are determined based on the results of the latest NlDL studies performed for each metal. For this program,the MDL for non-detect values will be determined by low-level replicatespiking of aliquots of the trial burn samples submitted. The reporting limit for non-detectable metals is a chosen whole number above the MDL, usually in the range of 1.5-2timesthe MDL value. 

### 5.6 

### Sampling and Monitoring Procedures This section describes the proceduresthat will be followed during the field sampling program. Throughout the overall program, all sampling will be performed using sampling protocols described herein and approved by EPA. Regulatoryagency approval will be obtained for any deviations from or changesto the approved Performance Test Planwhich may be warranted priorto program implementation as a result of changes in personnel or facility circumstances. If situations occur during the demonstration testing which necessitate deviations from the plan, the agency will be notified and onsite approval requested. Any deviations from the specified protocolsw~ll be fully documented in the final Performance Test Report. 

### 5.6.1 Field Program Description A detailed description of the compliance strategy and test conditions was provided previously in Section 4.0. In general, however, the program is presently configured to collect samples during three runs for a single process operating condition. 

### Table 53provides a detailed listing of the sampling and analytical parameters and methods planned for this program. All samplingwill be conducted concurrently at the outlet stack location. 

### 5.6.2 Pre-sampling Activities Pre-sampling activities includeequipment calibration, sample media preparation, cleaning of sample train glassware, preparation of computer-generated sample labels, and other miscellaneous tasks. Each of these activities are described or referenced in the following subsections. Other pre-sampling activities includesuch details as team meetings, equipment packing and shipment, equipment setup, and finalization of all details leading up to the coordinated initiation of the sampling program. 

### 5.6.2.1 Equipment Calibration A most important aspect of pre-sampling preparations is the inspection and calibrationof all equipment plannedto be used for the field effort. Equ~pment is inspected for proper operation and durability priorto calibration. Calibration of equipment is conducted in accordance with the proceduresoutlined in the EPA document entitled "Quality Assurance Handbook for Air Pollution Measurement Systems; Volume IIIStationary Source Specific Methods" (EPA-60014-77-027b). Equipment calibration is performed in accordance with EPA guidelines andlor manufacturer's recommendations. Documentation of all calibration records will be kept in the project file during the field programand will be available for inspection by test observers. Examples i""% of field equipment used and typical calibration requirements follows:

Q\mw97\Projecrs\l0002022\Veolia Performance Test Plan U4 R3-052108.docVeolia ESTechnical MACT Unit 4 HWC Performance Test Plan Revision: 0 Date: May 2008 Section: 5.0 Page 6 of 26
Probe nozzles (QA Handbook Section 3.4.2, pg. 19) 

### - make three measurements of the nozzle ID (to the nearest 0.001 in.) using different diameters with a micrometer. Difference betweenthe high and low values should not exceed 0.004 in. Post-test check 

### - inspect for damage. Pitottubes (QA Handbook Section 3.1.2, pp. 1-1 3) 

## - measured for appropriate spacing and dimensionsor calibrate in a wind tunnel. Rejection criteria given on the calibration sheet. Post-test check 

### - inspect for damage. Thermocouples (QA Handbook Section 3.4.2, pp. 15-1 8) 

## - verify against a mercury-in-glass thermometer at two or more points including the anticipated measurement range. Acceptance limits

### - impinger+2"F; DGM ~54°F; stack &I .5 percent of stack temperature. 

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

### - pretest Yi 

### = Y

# + 0.02; post test Y 

### = A 0.05 Yi. Field barometer (QA Handbook Section 3.4.2, pp. 18-1 9) 

## - compare against a mercury-in-glass barometer or use Airport Station BP and correctfor elevation. Acceptance criteria

## - & 0.02 in. Hg; post-test check

## - same. 5.6.2.2 Glassware Preparation Sample train glassware and sample containers require specialized pre-cleaningto avoid contamination of the sample from the collection container or devices. Cleaninglstorage procedures for sample train glassware are ,-** summarized below. Note that all bottle caps are fitted with teflon liners which are cleaned in the same manner as the bottles themselves. Sample containers used for waste feed streams are purchased pre-cleaned and sealed to specified EPA protocols. EPA Method29 glassware and containers (metals) -wash with soap and water, rinse with hot tap water, rinse three times with reagent water. The glassware is next soaked in a 10% nitric acid solution for a minimum of 4-hours, rinsed three times with reagent water, rinsed a final time with acetone and air dried. All glassware openings where contamination can occur will be covered until the sampling train is assembled prior to sampling. 5.6.2.3 Sample Media Preparation All reagents will bechecked in accordance with ENSRs existing QC Program to minimize the probability of using contaminated solvents. This includes the use of the proper grade reagentslsolventsas specified in the test method, selection of reagents from the same lot and the collection and analysis of the appropriate blanks. Sampling media will be procured and prepared in accordance with the appropriate test methods as described below: Quartz filters used in the Method29 sampling train are purchased from Pallflex Products Co.who pre-screen filters for metals content. 5.6.2.4 Other Pre-Sampling Activities Sample team meetings will be heldto designate responsibilities to each team member. Assignments will be based on individual experienceand relative importance of the assigned task. Other pre-sampling activities in the office will include generation of sample checklists, printing of computer-generated sample labels, and proper packing of all equipment. Equipmentw~ll then betransported by freight ur truck to the sampling /- location.

Q:\rnw97\Projects\l0002022\Veolia Performance Test Plan U4 R3-05210B.docRevision: 0 Date: May 2008 Section: 5.0 Veolia ESTechnical MACT Unit4 HWC PerformanceTest Plan Page 7 of 26
Site setup is the final pre-samplingactivity. This task will involve moving the equipmentto the vicinity of the sample collection area. A separate office trailer or other suitable onsite facility will be used to serve as a sample train setup and recovery area and sample custody area. Normally, preliminary tests are conducted at the stack locationto verify the presence or absence of cyclonic flow conditions and to determine flue gas moisture, temperature and velocity. These measurements facilitate determination of nozzle size selection and sample train operation rates for the isokinetic sampling trains. 

### 5.6.3 Sampling Locations 5.6.3.1 Waste Feed Streams Waste feed materials will be sampled in accordance with the facility's feed stream analysis plan (FSAP) and RCRA Waste Analysis Plan (WAP). Waste feed sampling will occur upstream of any metal spiking location. Samples will be collected using methodologiesdescribed in the FSAP and WAP. 5.6.3.2 Stack Sampling Location Sample test ports in the circular48-inch inside diameter (ID) stack are located 65.5 feet (16.4 diameters) downstream of the induced-draftfan and 26feet (6.50 diameters) upstream of the stack exit to atmosphere. In accordancewith EPA Method 

### 1, a 12-point traverse will be performed during testing. One test port level will be usedto accommodate simultaneous testing of all emissions test parameters. Figure5-1 provides a schematic of the stack showing the locationof the sampling ports. Actual traverse point locations and upstream/downstreamdistances from flow disturbances are shown in Table 

### 54. 

### 5.6.4 Waste Feed Stream Sampling Procedures Each waste feed materialfed during the test will be sampled from taps in the feed lines or other appropriate locations, upstream of any metal spiking location. Dur~ng the testing each waste feed material will be sampled at the start of each run, at port change, and at the completionof each run. After testing is completed, the three samples thatwere collected will be composited and analyses will be performed on this composite sample.The feed streams will be characterized for ash, heat content, metals (arsenic, beryllium, chromium, cadmium, lead, and mercury) and total chlorine. Veolia w~ll be responsible for allwaste feed analyses. 

### 5.6.5 Stack Sampling Methodologies Gases discharged from the exhaust stack will be sampled by ElVSR for the following parameters: Flue gas velocity, flow rate, temperature, moisture content and fixed gas (02 and C02)composition; MACT Metals

### - arsenic, beryllium,cadmium, chromium, lead and mercury; The following sections provide summaries of the sampling methodologies to be followed. In addition, sample field data sheets to be used during the program are provided in Appendix B. Summaries of relevant informationpertaming to setup and recovery of the EPA Method29 sampling train are provided in Appendix C.

Q:\mw97\Projects\lO002022\Veolia PeriormanceTest Plan U4 R3-052108.docRevision: 0 Date: May 2008 Section: 5.0 Veolia ESTechnical MACT Unit4 HWC PerformanceTest Plan Page 8 of 26
5.6.5.1 Gas StreamVelocity, Moisture and Fixed Gases Gas stream flowrate, moisture and fixed gas concentration will be determined concurrent with the EPA Method 29 isokinetic sampling train. Gas stream velocity

### will be determined using a pitot tube and water manometer in accordance with EPA Method2. Gas stream temperature will also be determined at each of the Method 2 traverse points using a Type 

### "K thermocouple and pyrometer. Gas stream moisture will be will be determined as specified in EPA Method4 concurrent with the EPA Method 29 isokinetic sampling train. Inthis procedurethe impinger contents are measured or weighed before and after each test run and used in conjunction with the metered gas volume to determinethe gas stream moisture content. Fixed gases (02 and COz)for gas stream molecularweight determination and constituent oxygen correctionwill be determined in accordance with EPA Method 3 (Orsat procedure)during each test run. 5.6.5.2 Metals EPA Method29 will be utilized for the collection of MACT and other metals including: MACT LVM metals 

### -arsenic, berylliumand chromium; MACT SVlbl metals

## -cadmium and lead; and Mercury. Specific sampling details for the Method29 sampling train are as follows: Target sampling rate

### - 0.75 cfm Sample run time

## - 2-hr Number of sampling points per stack traverse

## - 6 Total number of sampling points 

### - 12 Number of field reagent blank sets collected

### - 1 5.6.5.3 Continuous Emission Monitoring ENSR will provide measurement of oxygen (02)and carbon dioxide (CO*) throughout all test run periods. These parameters will be measured using the procedures specified in 40 CFR 60, AppendixA, Method3 (Orsat analysis). Veolia will provide continuous emission monitoringfor carbon monoxide (CO) during all three test runs in accordance with the facility's Quality Assurance Planfor their CEMs. 

### 5.7 Sample Handling, Traceability and Holding Times Sample integritywill be maintained throughout all phases of the sampling and analysis program. Samples will be held within sight ofthe samplers or sample custodian,or will be kept in sealed or secured containersat all times. Sealed coolers and DOT sh~pping boxesw~ll be used to ship samples to the designated laboratory via Priority 

### 1overnight FedEx service. Preprinted sample identification labels are used by ENSRto ensure that all required information is fully f- documented. When sample batches are shippedto the specified laboratory, a sample packing list (see

Q:\mw9APro~ects\l0002022\Veolia Performance Test Plan U4 R3-052108.docRevision: 0 Date: May 2008 Section: 5.0 Veolia ES Technical MACT Unit 4 HWC Performance Test Plan Page 9 of 26 Figure

### 5-2) accompanies the shipment. This form is based on established laboratory format and will be used to document sample transfer in the field and from sampling personnelto the laboratory. The ENSR Field Team Leaderwill coordinate the packingand shipment of all samples. Worksheets specifically designed for this program will be generated priorto the field effort. These sheets will assist the Field Team Leader in assuring that all samples have been collected, accounted for and shipped under sample traceability documentation to the appropriate laboratory. Requirements pertainingto sample preservation and recommended holding times are noted in Table 

### 5-5. All materials such as field and laboratory notebooks and logbooks, field and laboratory data records, correspondence, reports, sampletags, traceability records and instrument printouts will be clearly labeled with the project number and become a permanent part of the project file. Project samples will be disposed of in an appropriate manner 60 days after acceptanceand approval of a final report. All project-relateddocumentation at both ENSR and the subcontractor laboratories will be kept on file for 2 years following submittalof the final report. 

### 5.8 

### Analytical Methods and Calibration Procedures This section delineates the analytical protocols that will be used to analyze samples duringthis performance test. Samples of waste feed materials and stack gas will be collected and analyzed for the parameters previously discussed usingthe appropriate laboratory protocols detailed in this section and as outlined previously in Table 

### 5-3. 5.8.1 Analysis of 

### Waste Feed Streams 5.8.1 

### .I Chemical and Physical Propertiesof Waste Feed Streams 

### Analyses to determinethe chemical and physical properties of the waste feed materials will be performed using appropriate ASTM or EPA SW-846 analytical methods as outlined in the Veolia FSAP and WAP. For any analytical results that are "non-detect",Veolia will utilize % 

### of the detection limit for that parameter in any calculation of feed rates. 

### 5.8.2 

### Analysis of 

### Stack Gas Samples 5.8.2.1 Metals in Stack Gas Samples Analysis 

# - Each sampling train will be prepared and analyzed in accordance with EPA Reference Method 29. From each sampling train, seven individualsamples are generated for analysis. The first two samples, labeled Fractions 1A and 1

### B consists of the digested samplefrom the front half of the train, consisting of the particulate filter and the front-half nitric acid probe rinse. Fraction 1A is for ICP analysisand Fraction 

### 1B is for mercury analysis. Fractions 2A and 2B consist of digestates from the moisture knock out and HN03/H202 impingers 1,2, and 3. Fraction 2A is for ICP analysis and Fraction 2B is for mercury analysis. Fractions 3A, 3B and 3C consist of the impinger contents and rinses from the empty and permanganateimpingers 4, 

### 5, and 6. These fractions will be analyzed for mercury. Analyses for metals other than mercury will be performed using Inductively Coupled Plasma Mass Spectroscopy (ICP-MS) as described in EPA Method6020 (SW-846, 3rd Edition). Mercury analysis will be performed using EPA Methods7470A or 7471A (SW-846, 3rd Edition). All quality control procedures, including the interferencecheck standard, will be followed as described in the respective method. Q:\mw97\Projects\l0002022\VeoliaPerformance Test Plan U4 R3-052108.docVeolia ESTechnical MACT Unit4 HWC PerformanceTest Plan Revision: 0 Date: May 2008 Section: 5.0 Page 10 of 26
Calibration 

### - Calibration of the ICAPwill be performed daily in accordance with the procedures described in Method 6020 and the manufacturer's instructions. The calibration is verified daily by analysis of an instrument check standard prepared from an EPA quality control concentrate or other independent standard. QAlQC requirements for the analysis of metals in stack gas samples are summarized in Table 5-6. 

### 5.9 Internal QA Program Quality control checks will be performed to ensure the collectionof representative samples and the generation of valid analytical resultsfor these samples. These checks will be performed by project participants throughout the program underthe direction of the Project Manager and the QA Officer. 

### 5.9.1 

### Data Collection and Sampling QC 

### Procedures QC checks for the process data collectionand sampling aspects of this programwill include, but not be limited to, the following: 1. Use of standardized data sheets, checklists and field notebooks to ensure completeness,traceability, and comparability of the process information and samples collected. 2. Field checking of standardized forms by the Field Team Leader and a second personto ensure accuracy and completeness. 

### 3. Strict adherence to the sample traceability procedures. 4. Submission of field biased blanks. 

### 5. Leak checks of sample trains beforeand after sample collection and during the test, when appropriate. 5.9.1.1 Sampling Equipment QC Checks and Frequency Calibration of the field sampling equipmentwill be performed priorto and at the conclusion of the field sampling effort. Copies of the calibration sheets will be availableonsite during the field sampling program for inspection,will be kept in the projectfile and 

### will be submitted in the final report. Calibrationsw~ll be performed as described in the EPA publication "QualityAssurance Handbookfor Air Pollution Measurement Systems, Volume Ill, Stationary Source Specific Methods;" Section 4.2 1 presents acceptance limits. Leak checks of the sample trains will be conducted in accordance with the protocol called out for each method. Leak checks will be conducted priorto and at the end of sample collectionand during the test run, when appropriate. 5.9.1.2 Sample Collection QC Checks Field-biased blanks of reagents and collection media (deionized water, filters, impinger solutions, etc.) will be placed in appropriately cleaned and sized sample containers in the field and handled in the same way as actual field samples, to provide a QC check on sample handling. For this program, sample'collectionQC checks and frequency for samples to be analyzed in the laboratory are listed below: One field reagent blank Method 29 sampling train Q:\rnMm7\Prqects\l0002022\Veolia Performance Test Plan U4 R3-0521 O8.docRevision: 0 Date: May 2008 Section: 5.0 Veolia ESTechnical MACT Unit 4 HWC Performance Test Plan Page 11 of 26


### 5.9.2 Analytical QC 

### Procedures for Samples to be Analyzed inthe Laboratory The Quality Control program for laboratory analysis makes use of a number of different types of QC samples to document the validity of the generated data. The following types of QC samples will be used during the program. 5.9.2.1 Quality ControlSamples and Blanks Method Blanks Method blanks contain all the reagents used in the preparation and analysis of samples and are processed through the entire analytical scheme to assess spurious contamination arising from reagents,glassware, and other materials used in the analysis. Calibration Check Sam~les One of the working calibration standards which is periodically used to check that the original calibration is stilt valid. Laboratow Control Samples (LCS) or Blank Spikes These samples are generated from spikes prepared independently from the calibration concentrates. The LCS are used to establish that an instrumentor procedure is in control. An LCS is normally carried through the entire sample preparation and analysis procedure also. Reagents used in the laboratory are normally of analytical reagent grade or higher purity; each lot of acid or solvent used is checked for acceptability priorto laboratory use. All reagents are labeled with the date received and date opened. The quality of the laboratory deionized water is routinely checked.All glassware used in the sampling and analysis procedures

### will be pre-cleaned accordingto the method requirements. Standard laboratory practices for laboratorycleanliness, personnel training and other general procedures are used. The resultsof these quality control procedures will be included in the final report. 

### 5.10 

### Data Reduction, Verification and Data Reporting Specific QC measures

### will be used to ensure the generationof reliabledata from sampling and analysis activities. Proper collection and organization of accurate information followed by clear and concise reportingof the data is a primary goal in all such projects. 

### 5.10.1 Field Data Reduction Appendix B of this PerformanceTest Plan presents the standardized forms that will be usedto record field samplingdata. The Field Team Leader and at least one other field crew member will review the data collected from each train in its entirety in the field. Errorsor discrepancies will be noted and dealt with accordingly. The Field Team Leader has the authority to institute correction actions in the field. The QA officer will also be notifiedfor resolution if the situation warrants. At a minimum, the QA officer is apprised of all deviations from standard protocol. Field data reduction (checking of valid isokinetic sampling rate and other sampling parameters) is done with a laptop computer using standardized Excel spreadsheets. Appendix C provides sample train setup and recovery schematics and a descriptionof solutions and reagents to be used in each isokinetictrain required for the overall program All sample recovery sheets will be checked for completeness.

Q:\mw97\Projects\lO00202~Veolia Performance Test Plan U4 R3-052108.docVeolia ES Technical MACT Unit4 HWC PerformanceTest Plan Revision: 0 Date: May 2008 Section: 5.0 Page 12 of 26


### 5.10.2 Laboratory Analysis Data Reduction Analytical resultswill be reduced to appropriate units by the laboratory using the equations given in the applicable analytical method. Unless otherwise specified, results from the analysis of waste feed and process samples for specific target constituents will be reported in units of mglkg or % 

### wt. Other parameters will be reported in standard units such as glcc, Btullb, etc. The laboratory typically reports results from the analysis of stack flue gas samples as total mass detected for the sample submitted. For those sample fractions where liquid impinger condensate is analyzed, the laboratorywill measure the total liquidvolume submitted and multiply by the measured concentrationsof target analytes in these samples. The laboratories will generally report data as follows. All metals except mercury 

### -total 

### pg of each metal in the combined front-half and back-half sample train fractions Mercury -total 

### pg in each sample train fraction Each LSC will be responsible for reviewing all results and calculations and verifying the completeness of the data set. The laboratory reports submitted by each laboratorywill include the following deliverables: Transmittal letter listing all samples and analyses and a case narrative identifying any difficulties associated with the analyses and any anomalousQAIQC results Copies of Chain of Custody Forms Sample Report forms with sample field and laboratory identifier, dates of sample preparation and analysis, analytical results and detection limits Method Blank results Matrix spike and matrix spike duplicate results (as applicable) Replicatesample analyses (as applicable) Laboratory Control Sample results 

### 5.1 0.3 Data Verification Data verification is the process of reviewing data and accepting, qualifying or rejecting it on the basis of method-specific criteria. The independent project QAO will use validation methods and criteria appropriate to the type of data and the purpose of the measurement. Records of all data will be maintained, even that judged to be an "outlying" or spuriousvalue. Field sampling data will be validated by the Field Team Leader based on a judgment of the representativeness of the sample, maintenanceand cleanlinessof sampling equipment and the adherence to an approved, written sample collection procedure. Analytical data will be validated by the subcontractor laboratory QC or supervisory personnel using criteria outlined in their laboratory-specific QA Plan andlor written SOPS. Results from field and laboratory method blanks, replicate samples and internal QC samples will be used to further validate analytical results. Analytical resultson field blanks and replicate field samples are valuable for validation of sample collection also. QC personnel will review all subcontractor laboratory raw analytical data to verify calculated results presented 

### P

Q:\mw97\Projects\l0002022\Veolia PerformanceTest Plan U4R3-052108.docRevis~on: O Date: May 2008 Section: 5.0 Veolia ESTechnical MACT Unit 4 HWC Performance Test Plan Page 13of 26 The following criteriawill be used to evaluate the field sampling data: Use of approved test procedures Proper operation of the process being tested Use of properly operating and calibrated equipment Leak checks conducted before and after tests Use of reagents that have conformedto QC specified criteria Use of 

### NBStraceable CEM calibration gases (as applicable) Proper chain-of-custody maintained All sample trains --check to ensure proper sample gas volume collected The criteria listed below will be usedto evaluate the analytical data: Use of approved analytical procedures Use of properly operating and calibrated instrumentation Precision and accuracy achieved should be comparableto that achieved in previous analytical programs and consistent with objectives stated in this document. 

### 5.10.4 

### Final Data Reporting Stack gas concentrations for each applicable parameter will be calculated from laboratory results and field sampling data. The total weight of the analyte detected will be divided by the volume of gas sampled to provide emission concentrations. For MACT compliance, all emission concentrations are further corrected to 

### 7% oxygen for comparison to the published standards. A complete Final Report outlining the goals, methods and results for the program will be prepared and any deviations from this test plan will be documented. The Final Report will include a section on evaluation and discussion of QAlQC results. Results will be compared to expected limits for accuracy, precision and/or completenessas targeted in this protocol. The final test report will also include the results of any internal audits conducted on the program as well as: All field data sheets showing sampling method, dates, run times, personnel, equipment; sample preservation, identificationand compositing records. Field equipment calibration data. Analytical lab reports and relevant supporting documentation. 

### 5.11 Routine Maintenance Procedures and Schedules This section provides pertinent information for field sampling equipment as well as a listing of all criticalfacility equipment necessary to maintain permitted operating conditions and to demonstrate continuing permit compliance. Information is provided for preventive maintenance and schedules and spare parts for key equipment and instrumentation.flQ:\rn~7~Projects\l0002022~Veolia Pefioformance Test Plan U4 R3-052108.docVeolia ES Technical IblACT Unit4 HWC PerFormanceTest Plan Revision: 0 Date: May 2008 Section: 5.0 Page 14 of 26


### 5.1 1.1 Field Sampling Equipment The field team follows an orderly program of positiveactions to prevent the failure of equipment or instruments during use. This preventive maintenance and careful calibration helps to ensure accurate measurements and minimalfield delays. All equipment that is scheduled for field use is calibrated as outlined previously in Section 5.6.2.1. Priorto each field usefor a specific project,the equipment is cleaned and checked to ensure it is in good working order. An adequate supply of spare parts and sample train glassware is brought to each site to minimize downtime and field sampling delays. Any equipment that does experience problems is appropriately tagged in the field to ensure that it is repaired upon returnto the office. 

### 5.11.2 Facility Equipment and Instrumentation As stated in SectionsV.a.F. and V.b.F. of Veolia's Part 

### B RCRA Permit, each incinerator system undergoes a "thorough visual inspection for leaks, spills, fugitive emissions, and sign of tampering at least daily and in accordance with the inspection schedulecontained inAppendix 6 of the approved permit application". Veolia utilizes these inspections and additional preventive maintenance activities as proactive measures for minimizing the potential for malfunctions. To facilitate proper maintenance,a cold shutdown will occur at least once per year for each incineratorsystem. Routine inspection and maintenance activities are scheduled, communicated, and recordedthrough the use of 

### i"" field checklists. Partsof the incineratorsystems that are subject to wear (e.g., bearings,O-rings, airloilfilters) are replaced based on the schedules indicated on these checklists. These field checklists will also be used to document repairs or replacements of incinerator components that may be revealed during inspections. Brief procedures/instructionsfor inspection and maintenance activities are provided on field checklists. Continuous monitoring system components are comprised of many instruments includingscales, flowmeters, thermocouples, pressure transmitters, differential pressure cells, bag leak detectors,and limit switches. All components critical for monitoring permitted parameters are audited either on a quarterly or annual basisto ensure proper operation. Daily callbration checks are performed on the Unit's CEM's. 

### 5.12 QAIQCAssessment Procedures The QA activities implemented in this programwill provide a basisfor assessing the accuracy and precision of the analytical measurements. Section 5.8 of this QAPP discusses the QA activity that will generate the accuracy and precisiondata for each sample type. A generalized form of the equations that will be usedto calculate accuracy, precision and completeness follows. 

### 5.1 2.1 Accuracy Percent accuracywill be determined using the following equation: % 

### Recovery = 

## (X x 100 

### T where: X = 

### experimentally determined concentrationof the spiked sample T = 

### true concentration of the spike S 

### = sample concentration beforespiking
Q:\rnw9AProjects\10002022\Veolia Performance Test Plan U4R3-052108 docVeolia ESTechnical MACT Unit4 HWC Performance Test Plan Revision: 0 Date: May2008 Section: 5.0 Page 15 of 26


### 5.12.2 Precision Precision (calculated as percent relative difference) will be determined using the following equation:

where: D, and D2

### = results of duplicate measurementsor standard deviation relative to the average value expressed as relative standard deviation: Relative standard deviation will be expressed as follows: Relative Standard Deviation (% RSD) 

### = x (x,

.... x J where:



### o 

### = standard deviation of the sample data n 

### = number of replicates 

### x(,~.,~,, = arithmetic mean of the sample data 

### 5.12.3 Completeness Data completeness is a measure of the extentto which the database resulting from a measurement effort fulfills objectives for the amount of data required. Forthis program, completeness will be defined as the percentage of valid data for the total valid tests. Completeness is assessed usingthe following equation:

where: D, 

### = number of samples for which valid results are reported D, 

### = number of valid samples that are collected and reach the laboratoryfor analysis The completeness objective will help to evaluate the accuracy and precision of the analytical measurements. 

### 5.13 External 

### QA Program The External Quality Assurance Program includes both performance and system audits as independent checks on the quality of data obtained from sampling, analysis, and data gathering activities. Every effort is madeto have the audit assess the measurement process in normal operation. Either type of audit may show the needfor corrective action.

Q:\rnw97\Projects\l0002022\Veolia Performance Test Plan U4 R3-05210B.docRevision: 0 Date: May 2008 Section: 5.0 Veolia ES Technical MACT Unit 4 HWC Performance Test Plan Page 16of 26


### 5.13.1 Performance Audits The sampling, analysis, and data handling segments of a projectare checked in performance audits. A different operatortanalystprepares and conducts these audit operat~ons to ensure the independence of the quantitative results. EPA Quality Control concentratesor other standards will be used to assess the analytical work. Results will be reviewed by the subcontractor laboratory and QC personnel. Any additional audit samples presented by the regulatory agencies will be analyzed along with program samples, by the appropriate lab and at the same time as all other samples. It will, however, be the responsibility of the regulatory agency to obtain these samples, and present them to the facility project manager in a form that is amenable and appropriate to the analytical methods being utilized. If the regulatory agency advisesfacility program manager that audit results fall outside of acceptable ranges, the analytical data will befurther reviewed for error in conjunction with the agency. If a simple, correctable error is found (e.g., an arithmetic error), correction will be made and results resubmitted. If no error is found, an investigation into other causes of the failure (e.g., lack of sample integrity) will be conducted and results evaluated in terms of the impact on sample data integrity. 

### 5.13.2 Corrective Action The acceptance limits for the sampling and analysesto be conducted in this program will bethose stated in the method or defined by the project manager. The corrective actions are likely to be immediate in nature and most often will be implemented by the analyst or Project Manager; the corrective action will usually involve recalculation, reanalysis,or repeating a sample run. Ongoing corrective action policy is described here. 5.13.2.1 

### Immediate CorrectiveAction Specific QC proceduresand checklists are designed to help analysts detect the need for corrective action. Often the person's experience will be more valuable in alertingthe operatorto suspicious data or malfunctioningequipment. If a corrective action can betaken at this point, as part of normal operating procedures, the collection of poor quality data can be avoided. Instrumentand equipment malfunctions are amenable to this type of action and QC procedures include troubleshooting guides and corrective action suggestions. The actions taken should be noted in field or laboratory notebooks but no other formal documentation is required, unless further corrective action is necessary. These on-the-spot corrective actions are an everyday part of the QA/QC system. Corrective action during the field sampling portion of a program is most often a result of equipment failure or an operator oversight and may require repeatinga run. When equipment is discoveredto be defective (i.e., pre- and post-sampling leak check) it is repaired or replaced and a correction factor is established as per the EPA method. If a correction factor is unacceptable the run is repeated. Operator oversight is best avoided by having field crew members audit each other's work before and after a test. Every effort is made by the field team leader to ensure that all QC procedures are followed. Economically, it is preferredto repeat a run during a particularfield trip rather than return at a later date. Corrective action for analytical work would include re-calibration of instruments, reanalysis of known QC samples and, if necessary, of actual field samples.

Q:\mwS7lProjects\l0002022\Veolia Performance Test Plan U4 R3-05210B.docVeolia ES Technical MACT Unit4 HWC Performance Test Plan Revision: 0 Date: May 2008 Section: 5.0 Page 17 of 26
Ifthe problem is not solved in this way, more formalized long-term corrective action may be necessary. 5.13.2.2 

### Long-Term CorrectiveAction The need for this action may be identified by standard QC procedures, control charts, performance or system audits. Any quality problem which cannot be solved by immediate corrective action falls into the long-term category. The condition is reportedto a person responsible for correcting it who is part of the closed-loop action and follow-up plan. The essential steps in the closed-loop corrective action system are: Identify and define the problem. Assign responsibility for investigating the problem. Investigate and determinethe cause of the problem. Determine a corrective action to eliminatethe problem. Assign and accept responsibility for implementing the corrective action. Establish effectiveness of the corrective action and implement it. Verify that the corrective action has eliminatedthe problem. Documentation of the problem is important to the system. A Corrective Action Request Form is filled out by the person finding the quality problem. This form identifies the problem, possible causes and the person responsible for action on the problem. The responsible person may be an analyst, field team leader, departmentQC coordinator or the QA Director. If no person is identified as responsiblefor action,the QA Director investigates the situation and determines who is responsible in each case. The Corrective Action Request Form includes a description of the corrective action planned and the date it was taken, and space for follow-up. The QA Director checksto be sure that initial action has been taken and appears effective and, at an appropr~ate later date, checks again to see if the problem has been fully solved. The QA Director receives a copy of all Corrective Action Forms and then enters them in the Corrective Action Log. This permanent record aids the QA Director in follow-up and makes any quality problems visible to management; the log may also prove valuable in listing a similar problem and its solution. 

### 5.13.3 

### Quality Assurance Reportsto Management 5.13.3.1 

### Internal Reports The Laboratory Services Coordinator will prepare a written report on QC activities associated with this project for the Quality Assurance Director. This report will detail the results of quality control procedures, problems encountered and any corrective action, which may have been required. All Corrective Action Forms are submittedto the QA Officer for initial approval of the corrective action planned and a copy is providedto the Program Manager. All system audit reports are providedto the Program Managerand the Quality Assurance Officer.

Q:\mw97\Projects\l0002022\VeoliaPerformance Test Plan U4 R3-052108.docRevision: 0 Date: May 2008 Section: 5.0 Veolia ES Technical IMACT Unit4 HWC PerformanceTest Plan Page 18 of 26
5.13.3.2 Reportsto Client The final report will include a section summarizing QNQC activities during the program. The Project Manager, Laboratory Services Coordinators and the QA Officerwill participate in preparingthis section. This section will provide summary QNQC results for method blanks and laboratory control spike recoveries. This section will evaluate overall data qual~ty in terms of accuracy, precision and completeness. Any discrepancies or difficulties noted in program work, protocol deviations or documentation gaps will be identified and discussed.

Q.\mw97\Projects\I 0002022\Veol1a Performance Test Plan U4 R3-052108.docRevision: 0 Date: May 2008 Section: 5.0 Veolia ES Techn~cal MACT Unit 4 HWC Performance Test Plan Page 19 of 26
Table 

### 5-1 General Sampling and Analytical Program Overview (Stack Exhaust)

Q:\mw9nPro~ects\10002022\Veolia Performance Test Plan U4 R3-052108.doc Parameter Flow, Fixed Gases and Moisture lblercury LVM Metals (As, Be and Cr) SVM Metals (Cd and Pb) MACT Emission Limits (a) NIA 130 pgldscm 92 pgldscm 230 pgldscm Sampling Method EPA Methods 2, 3 and 4 EPA Method 29 EPA Method 29 EPA Method 29 Analytical Method NIA EPA Method7471 CVAAS EPA Method6020 ICP-IVIS EPA Method 6020 ICP-MSVeolia ESTechnical MACT Unit 4 HWC Performance Test Plan Revision: 0 Date: May 2008 Section: 5.0 Page 20 of 26


### Table 5-2 

### GlA Objectivesfor 

### Field Measurements

Moisture (EPA Method4) Carbon Dioxide (EPA Method 3 

### - OrsatAnalysis) Oxygen (EPA Method 3 

## -OrsatAnalysis) 

### (a) Not determinable. (b) An accuracy of 

### k 0.2% would be expected if a certified gas audit is performed. Otherwise individual readings must bewithin 0.3 glg-mole of the mean value for three (replicate) readings. 

### (c)An accuracy of 20.8% i. 0.5% would be expected if an ambient air audit is performed.

Q:\mw97\Projects\l0002022\VeoliaPerformanceTest Plan U4 R3-052108.docVeolia ESTechnical MACT Unit4 HWC Performance Test Plan Revision: 0 Date: May 2008 Section: 5.0 Page21 of 26
Table 5-3 

### Overall Summary of Performance Test Stack Gas Sampling and Analysis Program

Sample Matrix and

Q:\mwS7\Pro~ects\l0002022\Veol1a Perfomlance Test Plan U4 R3-052108.docRevision: 0 Date: May 2008 Section: 5.0 Veolia ES Technical MACT Unit 4 HWC Performance Test Plan Page 22 of 26
Table 54 Traverse Point Locations STACK INSIDE DIAMETER: 48 inches SAMPLING LOCATIONS: 16.4 diameters downstream 6.50 diameters upstream MINIMUM NUMBER OF TRAVERSE POINTS 12 AS SPECIFIED BY EPA METHOD 

### 1: NUMBER OF TRAVERSE POINTS SAMPLED: 12

Percent of Stack Traverse Point Diameter Distance in Inches Number From Inside Wall From Inside Wall
1 95.6 45.9 2 85.4 41.0 3 70.4 33.8 4 29.6 14.2 5 14.6 7.0 6 4.4 2.1

Q:\rnw97\Projects\l0002022\Veolia Performance Test Plan U4 R3-052108 docRevision: 0 Date: May 2008 Section: 5.0 Veolia ESTechnical MACT Unit4 HWC PerformanceTest Plan Page 23 of 26
Table 5-5 Sample Preservationand HoldingTime Requirements Stack Gas Samples '"I

Q:~mw97\Projects\l0002022\Veolia Performance Test Plan U4 R3-052108 doc Parameter Metals (Method 29) (except Hg) Mercury (Method 29)

(a) Holdingtimes will be calculated from the day of sample collection. Matrix Aqueous Solid I Filter Aqueous SolidIFilter Preservation Cool, 4°C Cool, 4°C Cool, 4°C Cool, 4°C Holding Time 6 months 6 months 28 days 28 daysRevision: 0 Date: May 2008 Section: 5.0 Veolia ES Technical MACT Unit 4 HWC Performance Test Plan Page 24 of 26
Table 

### 5-6 QA Requirementsfor Metals in Stack Gas by ICAP or ICP-MS

Q:im~7\Projectsil0002022\VeoliaPerformance Test Plan U4R3-052108.doc Target Criteria Analysis of calibration check standard w~thin 10%of true value 90-110% Subject to interpretation 90% to 11 0% of true value 70% to 130% of reference value 70% to 130% recovery RPD < or = 35% Evaluated on case by case basis Quality Parameter Calibration

Accuracy 

### - ICV Accuracy 

### - filters Accuracy Precision Blanks

ICAP = InductivelyCoupled Argon Plasma ICP-MS= InductivelyCoupled Plasma

### - Mass Spectrometry ICV = Initial Calibration Verification RPD = Relative Percent Difference Method Determination Initial analysis of standards Continuing mid-range calibration standard Continuing calibration blank Analysis of calibration check standard Analysis of NlSTstandard reference filters or EPA audit filters, if provided Post-digestion spikes Post-digestion spikes Field Reagent Blanks and Method Blanks Frequency 

### ---- Daily At least once before and after sample analysis With continuing calibration standard After every initial callbration Once pertest Once pertest Once pertest One each pertestVeolia ESTechnical MACT Unit 4 HWC PerformanceTest Plan Revision: 0 Date: May 2008 Sect~on: 5.0 Page 25 of 26 

### Figure 5-1 

### Stack Sampling Locations

Q:\mw97\Projects\10002022\Veolia PerformanceTest Plan U4 R3-052108.docRevision: 0 Date: May 2008 Section: 5.0 Veolla ES Technical MACT Unit4 HWC Performance Test Plan Page 26 of 26 

### Figure 5-2 

### Example Sample Packing List



### i 

## EN% / AECOM 

### SAMPLE PACKING LIST Page of Sw Date : I~roiect Iocation: P.O. # 

# 11

ll~elin~uirhed by (Print) Date: l~eceived by (Print) Date: Analytical Laboratory: 

# 1

Q:\m~7\Projects\l0002022\Veolia Performance Test Plan U4 R3-0521 O8.doc Signature: Time: Relinquished by (Print) Date. Signature: Time: Signature: Time: Received by (Print) Date: Signature: Time: Received by: Date: Signature: Time:Revision: 0 Date: May 2008 Veolia ES Technical MACT Unit4 HWC Performance Test Plan Section: Appendices



## Appendix A Unit 4 

## Process Flow Diagram

Q:\mw97\Projects\lO002022\Veoiia Performance Test Plan U4 R3-052108.docVeolia ES Technical MACT Unit4 HWC Performance Test Plan Revision: 0 Date: May 2008 Section: Appendices



## Appendix B Field Data Sample Collection Forms

Q:hw97\Projects\l0002022\Veolia PerforrnanmTest Plan U4 R3-052108.doc

### ORSAT ANALYSIS (EPA METHOD 3)

Valid Leak Check : Liquid level must not fall
not change by more than

When less than 4%, difference between readings shall be 0.2% or less.

I I I I I I I I I 

### * Net O2 is actual O2 minus actual C02reading
Q\mw97\Projects\l0002022iAppend1x 0-all units\[OrsatAnalys~sForm.xls]A

### SAMPLE TRAIN MOISTURE RECOVERY DATA SHEET

# ENSR

# 1 WEClOM

9



## NOZZLE CALIBRATION FORM Client: Project #: 

### Date: Calibrated by:

Where: Dl,,,, = 

### Nozzle diameter measured on a different diameter to the nearest 0.001 

### in. Delta D 

### = Maximum difference between any two measurements, in. Tolerance 

### = 0.004 in. 

### D,,, 

### = Average of 

### D,,,,,Veolia ESTechnical MACT Unit 4 HWC Performance Test Plan Revision: 0 Date: May 2008 Section: Appendices



## Appendix C 

## lsokinetic Sampling Train Setup and Recovery Schematics

Q:\mw97\Projects\l0002022\VeoIia PerformanceTest Plan U4 R3-052108.doc

## SAMPLE TRAIN SETUP MULTIMETALS (as Per EPA Method 29 10060)

I st empty 

### * 2nd 

### -- 100 mL 5% HNO, 

### I 10% H202 3rd 

### -- 100 mL 5% HNO, 

### I 10% H202 4t

### h 

### -- emP~Y 5th 

### -- 100 mL 10% H2SO4 / 4% KMnO, 6th 

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

# -- (Exact Volumes Specified by Method)



### Dl Water 

### 8 N HCI 

### -- 25 mL (added to 200 mL water) Filter 

### -- One unused filter



### * optional

## - used for high moisture stacksNOZZLE 

# I PROBE 

# I

BrushlRinse 0.1 N HN03 (- 50 mL) 3X FILTER HOUSING

FH 

### - HN03 Container 3

Note I

### : Exactly 100 mL of 0.1 N HN03 used for rinsing nozzle, probe and FH filter housing. Note 

### 2: Nozzle, probe and FH filter housing are rinsed with water followed by acetone after the nitric acid rinse. The water and acetone are then discarded. Carefully remove filter from support with Tefloncoated tweezers and place in petri dish

Brush loose particulate onto petri dish 

# i

Seal petri dish with 

# I tape

Filter (1 Container 1



### METHOD 29 

### (METALS) RECOVERY SCHEMATIC 

## - FRONT HALF RECOVERY Page 

### I 

### of 2FILTER SUPPORTAND BACK HALF OF (Empty) (Optional)

with 0.1 N NitricAcid

into Container

Rinse Three Times with 0.1 N Nitric Acid 

# rl

Note: Exactly I00mL of 950 m~ 

### nitric acid is used to rinse all components up (Container 4) 

### through impingers 1-3. 2"' and 3rd (HN031H702) 

# 7 5Ih and fith (KMn04) (Silica Gel)

Measure Volume Measure Volume

into Container No. 4 Contents into 

# -7 I container 

# I

Rinse Three Times with 0.1 N Nitric Acid

250 mL 0.1 N HN03 (Container 5A) 

# I Empty the lmpinger 

## ( 

# 1 Nos. 5 and 6 Contents 

# I I into Container 

# I

Rinse Three Times with Permanganate Reagent, (1 00 

# 1 mLtotal) then with Water 

# 1 (100 niLtotal)

# LRemove Any Residue with 25 Solution (Container 58)

8 N HCI (Container 5C)


### METHOD 29 

### (METALS) RECOVERY SCHEMATIC 

## - BACK HALF RECOVERY Page 2 of 

### 2