APPENDIX H 

AUTOMATIC WASTE FEED CUTOFF PLAN 
AUTOMATIC WASTE FEED CUTOFF PLAN 

Prepared for: 

Veolia ES Technical Solutions, LLC 

Sauget, Illinois 

Prepared by: 

Franklin Engineering Group, Inc. 

Franklin, Tennessee 

October 2008 
TABLE OF CONTENTS 

1.0 INTRODUCTION AND BACKGROUND 1 

1.1 SUMMAR Y OF FACILITY INFORMATION 1 

1.1.1 Fixed Hearth Incinerators / 

1.1.2 Rotary Kiln Incinerator 2 

1.2 DESCRIPTION OF THE AWFC O SYSTE M 5 

2.0 AWFCO OPERABILITY TEST PROCEDURES 11 

3.0 RESPONCE TO AN AWFCO EVENT 12 

3.1 REPORTING REQUIREMENTS 13 

4.0 MANUAL WASTE FEED CUT-OFF PROCEDURES 14 

ii 
LIST OF TABLES 

TABL E 1 -1 REGULATOR Y REQUIREMENTS FOR A N AWFC O PLA N AN D 

CORRESPONDING SECTION THAT ADDRESSES THE REQUIREMENT 4 

TABL E 1 -2 AUTOMATIC WAST E FEED CUTOFF INTERLOCKS 6 

iii 
1.0 INTRODUCTION AND BACKGROUND 

Veolia ES Technical Solutions, LL C (Veolia) owns and operates two fixed hearth 

incinerators (Units 2 and 3) and a rotary kiln incinerator (Unit 4) at its facility located in 

Sauget, Illinois. These incinerators are subject to the National Emissions Standards for 

Hazardous Air Pollutants (NESHAP) for Hazardous Waste Combustors (HWCs), Part 63, 

Subpart EEE (§§63.1200 to 63.1221). The NESHAP for HWCs specifies emissions 

standards which reflect emissions performance of maximum achievable control 

technologies (MACT), and is commonly referred to as the HWC MACT. 

Hazardous Waste Combustors are required to have a functioning system that immediately 

and automatically cuts off the hazardous waste feed under certain conditions. The 

Automatic Waste Feed Cut-Off (AWFCO) System must follow the requirements 

described in 40 CFR 63.1206(c)(3). This Automatic Waste Feed Cut-Off Plan 

demonstrates Veolia's compliance with these requirements. 

This plan includes infonnation about AWFCO systems, procedures for responding to an 

AWFCO event, and procedures for testing the operability of the AWFCO systems. Table 

1-1 presents the regulatory references related to AWFCO Plans and the section of this plan 

that addresses each specific requirement. 

Due to the similarity of the three AWFCO systems (one for each incinerator system), 

general references to an AWFCO system or incinerator system in this document will 

imply all three systems. Information that is only applicable to one or two of the three 

systems will be clearly identified. 

1.1 Summary of Facility Information 

Brief summaries which describe the fixed hearth incinerators and the rotary kiln 

incinerator are presented in this section. 

1.1.1 Fixed Hearth Incinerators 

Each of the fixed hearth incinerators includes the following components: 

• Feed equipment 

• Primary and secondary combustion chambers 

• Lime injection system 

• Spray dryer absorber (SDA) 

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• Fabric filter baghouse 

• Solids and ash removal systems 

• Induced draft (ID) fan and stack 

• Instrumentation, controls, and data acquisition systems 

Various solid and liquid wastes and gaseous feedstreams are thermally treated in the 

fixed hearth incinerators. Solid waste is fed to the primary (lower) combustion chamber 

via a feed conveyor system and pneumatic ram. Liquid waste from tanks and tanker 

trucks are fed to the primary combustion chamber through two atomized liquid injectors. 

Liquid waste from containers are fed to the primary combustion chamber through a 

specialty feed injector. A gaseous feedstream is fed to the Unit 2 primary combustion 

chamber directly from gas cylinders. Off gases from a hooded feed emission control 

system and from a waste handling glove box are fed directly to the Unit 3 secondary 

combustion chamber. Combustion chamber temperatures are maintained using natural 

gas fired to a dedicated burner in both the primary and secondary chambers. 

Combustion gas exits the secondary combustion chamber and enters the SDA, which 

provides acid gas removal and cooling of the combustion gas. Combustion gas exits the 

SDA and is distributed to the fabric filter baghouses, which provide particulate matter 

removal. The induced draft fan, located downstream of the baghouses, moves the 

combustion gas through the system and exhausts the gas through the main stack. 

Hot, wet gas is extracted downstream of the baghouse through a continuous emissions 

monitoring system. This system features a multi-component infrared gas analyzer that 

detects hydrogen chloride, carbon monoxide, and water vapor concentrations. An 

integrated zirconium oxide-based analyzer detects oxygen concentrations. 

1.1.2 Rotary Kiln Incinerator 

The rotary kiln incinerator includes the following components: 

• Waste feed system 

• Primary and secondary combustion chambers 

• Tempering chamber 

• Lime injection system 

• Spray dryer absorber 

• Carbon injection system 

• Fabric filter baghouse 

2 
Solids and ash removal systems 

ID fan and stack 

Instrumentation, controls, and data acquisition systems 

Various solid and liquid wastes are thermally treated in the rotary kiln incinerator. Solid 

wastes are fed to a ram feeder via a clamshell, a drum feed conveyor, and an auxiliary 

feed conveyor. A hydraulic ram pushes the solid waste into the kiln. Liquid waste from 

tanks and tanker trucks is fed to the primary and secondary combustion chambers through 

atomized liquid injectors. Combustion chamber temperatures are maintained using 

natural gas fired to a dedicated burner in both the primary and secondary chambers. 

Combustion gas exits the secondary combustion chamber and enters the tempering 

chamber, which provides cooling of the combustion gases. The combustion gas exits the 

tempering chamber and is distributed between two identical SDAs, which provide acid 

gas removal and additional gas cooling. A carbon injection system is utilized for 

controlling dioxin/furan and mercury emissions. The activated carbon is air injected into 

the combustion gas immediately downstream of the convergence of combustion gases 

from the SDAs. From the SDAs, combustion gas is distributed to fabric filter baghouses, 

which provide particulate matter removal. The ID fan, located downstream of the 

baghouses, moves the combustion gas through the system and exhausts the gas through 

the main stack. 

Hot, wet gas is extracted downstream of the ID fan through a continuous emissions 

monitoring system. This system features a multi-component infrared gas analyzer that 

detects hydrogen chloride, carbon monoxide, and water vapor concentrations. An 

integrated zirconium oxide-based analyzer detects oxygen concentrations. 

3 
Table 1-1 

Regulatory Requirements for AWFCO Plan and 

Corresponding Section that Addresses the Requirement 

Regulatory Citation Description Plan Section 

§ 63.1206(c)(3)(i) Facility must have a functioning AWFCO system Section 1.0 

§ 63.1206(c)(3)(i)(A) 

System must cut off waste when any of the 

following are exceeded: 

(1) Operating Parameter Limit 

(2) Emission standard monitored by CEMS 

(3) Allowable Combustion Chamber Pressure 

(1) Section 1.2 

(2) Section 1.2 

(3) Section 1.2 

§ 63.1206(c)(3)(i)(B) 

System must cut off waste when span value of any 

CMS detector is met or exceeded 

Section 1.2 

§ 63.1206(c)(3)(i)(C) 

System must cut off waste upon malfunction of a 

CMS monitoring an OPL or emission level 

Section 1.2 

§ 63.1206(c)(3)(i)(D) 

Waste cut-off must occur when any component of 

the AWFCO system fails 

Section 1.2 

§ 63.1206(c)(3)(ii) Ducting of combustion gases Section 3.0 

§ 63.1206(c)(3)(iii) Restarting waste feed Section 3.0 

§ 63.1206(c)(3)(iv) Failure of AWFCO system Section 4.0 

§ 63.1206(c)(3)(v) Corrective measures Section 3.0 

§ 63.1206(c)(3)(vi) 

Reporting exceedance of emission standard or 

operating requirement 

Section 3.1 

§ 63.1206(c)(3)(vii) AWFCO system testing Section 2.0 

§ 63.1206(c)(3)(viii) Ramping down waste feed N A 

§ 63.1209(b)(4) 

Interlock span of non-CEMS CMS into the AWFCO 

system 

Section 1.2 

4 
1.2 Description of the AWFCO System 

The AWFCO system includes all hardware and software (i.e., control logic) necessary to 

immediately and automatically cutoff waste feeds to the incinerator in the event that an 

AWFCO interlock is triggered. Table 1-2 lists the parameter and setpoint for each 

required AWFCO interlock. In addition to the interlocks specified in Tables 1-2, the 

following conditions are interlocked with each AWFCO system: 

• The span value of each CMS instrument (except for a CEMS instrument) 

• CMS Malfunction 

• AWFCO System Malfunction 

AWFCO interlocks ensure that the pneumatically actuated waste feed block valves 

cannot open or remain open unless all regulated operating parameters and conditions are 

within limits. Additionally, the waste feed block valves will fail in the closed position if 

there is a loss of electrical power or instrument air supply. The parameters interlocked 

with the AWFCO system are described below in further detail. 

• Maximum Pumpable Hazardous Waste Feedrate - Each pumpable hazardous 

waste feed line to the incinerator is equipped with a mass flowmeter. The 

pumpable hazardous waste feedrate is continuously calculated as the sum of the 

individual flowrates. If the hourly rolling total (HRT) pumpable hazardous waste 

feedrate meets or exceeds its limit, an AWFCO interlock is triggered. 

• Maximum Total Hazardous Waste Feedrate - For Units 2 and 3, solid waste is 

fed to the primary combustion chamber via a feed conveyor and pneumatic ram. 

A scale in the feed conveyor monitors the weight of each charge of solid waste. 

For Unit 4, solid wastes are fed to a ram feeder via a clamshell, a drum feed 

conveyor, and an auxiliary feed conveyor. The clamshell empties into a hopper 

equipped with a load cell that monitors each charge weight. The solid feed 

conveyors are equipped with weigh scales. For each incinerator, the time between 

charges is used to convert these charge weights to a solid waste feedrate. The 

solid waste feedrate is summed with the pumpable hazardous waste feedrate to 

calculate the total hazardous waste feedrate. If the HRT of the total hazardous 

waste feedrate meets or exceeds its limit, an AWFCO interlock is triggered. 

5 
Table 1-2 

Aui tomatic Waste Feed Cutoff Interlocks 

Operating Parameter Averaging Period Units 

AWFCO Interlock Setpoint 

Operating Parameter Averaging Period Units 

Unit 2/3 Unit 4 

Maximum Pumpable Waste Feedrate HRT lb/hr 3,107 PCC-3256/SCC-1006 

Maximum Total Waste Feed Rate HRT lb/hr 4,017 PCC-13,796/SCC-1006 

Maximum Ash Feed Rate 12-HRT lb/hr 673 8,777 

Maximum Chlorine/Chloride Feedrate 12-HRT lb/hr 218 252 

Maximum Mercury Feedrate Limit 12-HRT lb/hr 0.0047 0.031 

Maximum Semi Volatile Metals Feedrate 12-HRT lb/hr 63 65 

Maximum Total Low Volatile Metals Feedrate 12-HRT lb/hr 46 55 

Maximum Pumpable Low Volatile Metals Feedrate 12-HRT lb/hr 47 47 

Maximum Primary Combustion Chamber Pressure Instantaneous in. w.c. > 0.0 for 5 seconds > 0.0 for 5 seconds 

Minimum Primary Combustion Chamber Temperature HRA °F 1,734 1,507 

Minimum Secondary Combustion Chamber Temperature HRA °F 1,849 1,886 

Emergency Safety Vent Position Instantaneous - TRV Open 

Surge Vent Open 

TRV Open 

Maximum Baghouse Inlet Temperature HRA op 420 434 

Maximum Bag Leak Detector Output 10 seconds % of scale > 30 % for 6 minutes > 15% for 12 minutes 

Minimum Carbon Feedrate HRA lb/hr - 6.2 

Minimum Carbon Feeder Exit Pressure Instantaneous psig - 4 

Maximum Carbon Carrier Gas Supply Pressure Instantaneous in. w.c. - 1 

Maximum Stack Gas Flow Rate HRA acfm 15,147 38,086 

Stack Gas Carbon Monoxide Concentration HRA ppmdv @ 7% 0 2 100 100 

Minimum Sorbent Feed Rate HRA Lb/lb C12 1.76 1.01 

Minimum Carrier Fluid Flow Rate HRA Gal/lb C12 1.70 1.61 

Notes: HRA = Hourly Rolling Average 

HRT = Hourly Rolling Total 

12-HRT = 12-Hour Rolling Total 

TRV = Thermal Relief Vent 

6 
Maximum Ash Feedrate - The ash concentration of each waste feed is 

determined in accordance with the Feedstream Analysis Plan. The CMS uses the 

waste ash concentration and the continuously monitored waste feedrate to 

calculate the ash feedrate of each waste stream. If the 12-hour rolling total (12-

HRT) of the combined ash feedrate meets or exceeds its limit, an AWFCO 

interlock is triggered. 

Maximum Chlorine/Chloride Feedrate - The chlorine/chloride concentration of 

each waste feed is determined in accordance with the Feedstream Analysis Plan. 

The CMS uses the chlorine/chloride concentration and the continuously 

monitored waste feedrate to calculate the chlorine/chloride feedrate of each waste 

stream. If the 12-HRT of the combined chlorine/chloride feedrate meets or 

exceeds its limit, an AWFCO interlock is triggered. 

Maximum Mercury Feedrate - The concentration of mercury in each waste feed 

is determined in accordance with the Feedstream Analysis Plan. The CMS uses 

the mercury concentration and the continuously monitored waste feedrate to 

calculate the mercury of each waste stream. If the 12-HRT of the combined LV M 

feedrate meets or exceeds its limit, an AWFCO interlock is triggered. 

Maximum SVM Feedrate - The concentrations of cadmium and lead in each 

waste feed is determined in accordance with the Feedstream Analysis Plan. The 

semivolatile metals (SVM) concentration in each waste stream is the sum of these 

metal concentrations. The CMS uses the SV M concentration and the 

continuously monitored waste feedrate to calculate the SV M feedrate of each 

waste stream. If the 12-HRT of the combined SV M feedrate meets or exceeds its 

limit, an AWFCO interlock is triggered. 

Maximum Total LV M Feedrate - The concentrations of arsenic, beryllium, and 

chromium in each waste feed is determined in accordance with the Feedstream 

Analysis Plan. The low volatile metals (LVM) concentration in each waste 

stream is the sum of these metal concentrations. The CMS uses the LV M 

concentration and the continuously monitored waste feedrate to calculate the 

L V M feedrate of each waste stream. If the 12-HRT of the combined LV M 

feedrate meets or exceeds its limit, an AWFCO interlock is triggered. 

7 
Maximum Pumpable LV M Feedrate - The LV M feedrate from pumpable 

waste feedstreams are summed to obtain the combined pumpable LV M feedrate. 

If the 12-HRT pumpable LV M feedrate meets or exceeds its limit, an AWFCO 

interlock is triggered. 

Maximum Primary Combustion Chamber Pressure - The primary chambers 

for Units 2 and 3 are totally sealed. Both the feed and discharge ends of the kiln 

(Unit 4) are equipped with an air pressurized double seal system that is comprised 

of steel spring plates with self-lubricating seal shoes. Fugitive emissions are 

prevented by these measures and the negative primary combustion chamber 

pressure maintained by the ID fan. An AWFCO interlock will be triggered if the 

primary combustion chamber pressure meets or exceeds the maximum limit (0.0 

in. w.c. gauge) for greater than five seconds. Continuous video surveillance of 

the combustion chamber exterior is utilized to determine if an AWFCO caused by 

high primary combustion chamber pressure corresponds with fugitive emissions. 

There must be visual evidence of fugitive emissions from the primary combustion 

chamber for a positive pressure event to be considered an exceedance. 

Minimum Primary Combustion Chamber Temperature - The temperature of 

combustion gas inside the primary chamber is monitored by redundant 

thermocouples. If the hourly rolling average (HRA) primary combustion chamber 

temperature meets or exceeds its limit, an AWFCO interlock is triggered. 

Minimum Secondary Combustion Chamber Temperature - The temperature 

of combustion gas inside the secondary chamber is monitored by redundant 

thermocouples. If the HRA secondary combustion chamber temperature meets or 

exceeds its limit, an AWFCO interlock is triggered. 

Emergency Safety Vent Position - Each incinerator's secondary combustion 

chamber is equipped with an emergency stack and emergency safety vent (ESV), 

which is also referred to as the thermal relief vent (TRV). The TRV allows hot 

combustion gas to vent from the combustion system during certain scenarios to 

protect the downstream APCS from excessive temperature situations. Unit 4 is 

also equipped with a second ESV located at the kiln face. This ESV is referred to 

as the surge vent and provides emergency pressure relief of the kiln. To minimize 

excessive emissions during an ESV opening, the output from the ESV position 

8 
transmitter is interlocked with the AWFCO system. If the ESV position is 

detected as open, an AWFCO interlock is triggered. 

• Maximum Baghouse Inlet Temperature - For Units 2 and 3, the baghouse inlet 

temperature (i.e., spray dryer absorber exit gas temperature) is continuously 

monitored by a thermocouple. Unit 4 is equipped with redundant thermocouples 

at the exit of each SDA. If the HRA baghouse inlet temperature meets or exceeds 

its limit, an AWFCO interlock will occur. 

• Maximum Bag Leak Detector Output - A triboelectric sensor is located in the 

duct downstream of the I D fan and continuously monitors the relative particulate 

matter loading of the gas. An AWFCO interlock will be triggered if the bag leak 

detector output remains at or above it high-high setpoint for the duration of the 

alarm delay time. 

• Minimum Carbon Feedrate - Powdered activated carbon is air injected into the 

plenum immediately upstream of the Unit 4 baghouses. A calibrated feeder is 

used to continuously monitor the addition rate of carbon to the carbon-air stream. 

If the HR A carbon feedrate meets or exceeds its limit, an AWFCO interlock is 

triggered. 

• Carbon Injection System Operating Pressures - The Unit 4 carbon injection 

system is equipped with a high level pressure switch located between the carbon 

feeder and the eductor. A low level pressure switch is located downstream of the 

blower that supplies air as the carbon carrier fluid. Both pressure switches have 

two setpoints, which define the permissible operating range at each location. 

These setpoints are interlocked with AWFCO system. 

• Maximum Stack Gas Flowrate - The pressure drop across a pitot tube located in 

the exhaust stack is utilized to continuously monitor the stack gas flowrate. If the 

H RA stack gas flowrate meets or exceeds it limit, an AWFCO interlock is 

triggered. 

• Maximum Stack Gas Carbon Monoxide Concentration - The CEMS 

continuously samples and analyzes stack gas for the concentrations of carbon 

monoxide (CO), and moisture using a multicomponent infrared photometer. The 

oxygen concentration of the sampled gas is analyzed simultaneously using a 

9 
zirconium oxide analyzer. A back-up zirconium oxide O2 analyzer also monitors 

stack gas O2 concentration. These data are used to calculated the stack gas CO 

concentration on a dry basis, corrected to 7% O2. If the CO concentration meets 

or exceeds the HWC MACT emission standard for CO (100 ppm dry volume, 

corrected to 7% oxygen), an AWFCO interlock is triggered. 

10 
2.0 AWFCO OPERABILITY TEST PROCEDURES 

The AWFCO interlocks are tested bi-weekly, as weekly testing would unduly interfere 

with operations, cause excessive downtime, and substantially increase operating costs. 

Testing of the AWFCO system is a time-consuming and manpower intensive process. 

The current testing program has been in place under the RCRA permit for a number of 

years and has proven to be adequate in detecting problems. 

AWFCO system operability testing is conducted by manually simulating input of process 

conditions to the programmable logic controller (PLC). The simulated input for each 

OPL will be set outside of limits to trigger the AWFCO interlock and associated alarms. 

The point at which the simulated input activates the control logic for the closure of the 

waste feed block valves will be observed and documented. Waste feed valves will not 

actually close during AWFCO testing. In addition to this AWFCO system control logic 

testing, the functionality of the waste feed block valves are confirmed during startups, 

shutdowns, actual AWFCO conditions, and when transitioning to and from warm standby mode 

Tests of the AWFCO system interlocks and associated alarms are documented an a 

AWFCO Testing Log and are maintained separately as part of the unit's operating record. 

11 
3.0 RESPONCE TO AN AWFCO EVENT 

While an AWFCO event will trigger an alarm, and automatically (and immediately) 

cutoff waste feed to the incinerator, the other portions of the incinerator system will 

remain operational and functioning (the APCS, CEMS, etc). Combustion chamber 

temperatures will be maintained on natural gas fired to the main burners, if possible. 

An AWFCO event is initiated in the following manner: 

1) An alarm is activated at a level below the permit limit in the case of a 

maximum limit or above the permit limit in the case of a minimum operating 

condition. This alarm indicates that the system is approaching a regulatory set 

point. The alarm also indicates a potential malfunction. 

2) At this point, the operator reviews the situation and takes action to correct the 

situation, up to and including a manual shutdown of the affected system. 

These corrective actions will be consistent with the Startup, Shutdown, and 

Malfunction Plan (SSMP). 

3) If the corrective actions taken are not effective, and the operating parameter 

reaches its permit limit or a permit preemptive set point, an AWFCO is 

initiated. An AWFCO Log form will be used to document the event. 

If an AWFCO event corresponds with an exceedance while hazardous waste remains in 

the combustion chamber, it must be determined if the event meets the regulatory 

definition of a malfunction. If such an event is a malfunction, a malfunction 

recordkeeping form will be used. Regardless of whether the hazardous waste residence 

time has transpired, if there is an exceedance that corresponds with an AWFCO event the 

following actions will be taken: 

• Investigate the cause of the AWFCO; 

• Take appropriate corrective measures to minimize future AWFCOs; 

and 

• Record the findings and corrective measures in the operating record. 

After an AWFCO has occurred, all operating parameters must be within limits prior to 

restarting hazardous waste feeds. 

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3.1 Reporting Requirements 

For each set of ten1 exceedances of an emission standard or operating parameter limit, 

and each exceedance occurs while hazardous waste remains in the combustion chamber, 

a written report will be submitted by Veolia to the Illinois Environmental Protection 

Agency (IEPA). The written report will be submitted within five calendar days of the 

tenth1 exceedance and will document the exceedances and results of the investigation and 

corrective measures taken. 

1

 Exceedances occurring during malfunction are not included in this tally. The Startup, Shutdown, and 

Malfunction Plan summarizes the reporting requirements associated with exceedances occurring during 

malfunctions. 

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4.0 MANUAL WASTE FEED CUT-OFF PROCEDURES 

If an AWFCO interlock fails to cutoff the feed of hazardous waste to the incinerator, the 

operator will manually cutoff all waste feeds to the incinerator in a quick and safe 

manner. This response is consistent with the procedure prescribed by the SSMP and will 

be documented on a malfunction recordkeeping form. The Program of Corrective 

Actions for Malfunctions, Attachment 4 to the SSMP, will be followed for the restoring 

the AWFCO system. 

14