Comprehensive Performance Test Plan

for

Fixed Hearth Unit 2

in Accordance with

40 CFR §63 Subpart EEE

Prepared for:

Veolia ES Technical Solutions, L.L.C.

7 Mobile Avenue

Sauget, IL 62201

Prepared by:

URS Corporation

9400 Amberglen Blvd.

Austin, TX 78729

June 27, 2013September 5, 2012
ii

Table of Contents

Page

1.0 Introduction........................................................................................................................1-1

1.1 Program Summary ..................................................................................................1-1

1.2 Facility/Unit Identification......................................................................................1-2

1.2.1 General........................................................................................................1-2

1.2.2 Facility ID, Mailing Address, and Primary Contacts ................................1-2

1.2.3 Incinerator Overview..................................................................................1-3

1.3 Test Objectives........................................................................................................1-3

1.3.1 General........................................................................................................1-3

1.3.2 Test Protocol Summary ..............................................................................

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

2.0 Engineering Description ...................................................................................................2-1

2.1 Process Overview....................................................................................................2-1

2.2 Waste Feed Systems................................................................................................2-1

2.2.1 Unit 2 Liquid Waste Feed System and Blending Operations....................2-1

2.2.1.1 Organic and Aqueous Liquid Waste Feeds ..................................2-3

2.2.1.2 Packaged Solids.............................................................................2-3

2.2.1.3 Specialty Liquid Feeds and Gases ................................................2-4

2.3 Manufacturer, Make and Model of the Incinerator................................................2-4

2.3.1 Combustion Chamber and Burners............................................................2-4

2.3.2 Secondary Combustion Chamber...............................................................2-5

2.3.3 Location of Combustion Zone Temperature Device .................................2-6

2.3.4 Hazardous Waste Residence Time.............................................................2-6

2.3.5 Combustion System Leak...........................................................................2-6

2.3.6 Emergency Safety Vent..............................................................................

2.4 Procedures for Rapidly Stopping Hazardous Waste Feed and Controlling Emissions 

During EquipmentMalfunction...............................................................................

2.5 Air Pollution Control Equipment............................................................................

2.5.1 Air Pollution Control System Descriptions ...............................................

2.5.1.1 Lime System..................................................................................

2.5.1.2 Spray Dry Absorber.......................................................................

2.5.1.3 Fabric Filter....................................................................................

2.5.1.4 Induced Draft Fan and Stack.........................................................

2.6 Stack Emissions Monitoring...................................................................................

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

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

2.8 Automatic Waste Feed Cut-off System..................................................................

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

2.9 Air Pollution Control Equipment Maintenance Practices......................................

2.9.1 Program Overview......................................................................................

2.9.2 Test Program Preparation Activities..........................................................
iii

Table of Contents (continued)

Page

3.0 Incinerator Feed Stream Descriptions............................................................................3-1

3.1 General.....................................................................................................................3-1

3.2 High Volume Wastes..............................................................................................3-2

3.2.1 Liquid Wastes.............................................................................................3-2

3.2.2 Bulk Solids..................................................................................................3-2

3.2.3 Containerized Waste...................................................................................3-2

3.2.4 Gaseous Wastes..........................................................................................3-2

3.3 Auxiliary Fuels........................................................................................................3-2

4.0 Performance Test Protocol...............................................................................................4-1

4.1 General Description.................................................................................................4-1

4.2 Performance Standards ...........................................................................................4-1

4.3 Test Conditions........................................................................................................4-2

4.3.1 Maximum Feedrate of Ash and Chlorine, Minimum Sorbent and Carrier 

Fluid Flowrates to the SDATest Condition 1 – Maximum Feedrate of

Metals and Chlorine....................................................................................

4.3.2 Maximum Feedrate of Metals and Chlorine, Maximum Waste Feedrates,

Minimum Temperatures in the PCC and SCCTest Condition 2 – Maximum 

Feedrate of Ash and Chlorine.....................................................................

4.3.3 Test Condition 3 – Maximum Feedrates and Minimum Combustion

 Temperature ................................................................................................

4.4 Establishing Operating Parameter Limits...............................................................

4.5 Waste Feed Spiking.................................................................................................

4.5.1 Inorganic Constituents................................................................................

4.5.2 Spiking for the LVM Category.....................................................................

4.5.3 Spiking for the SVM Category.....................................................................

4.5.4 Spiking for Mercury......................................................................................

4.5.5 Spiking for Chlorine Loading.......................................................................

4.5.6 Spiking for Ash Loading...............................................................................

4.6 Metals Extrapolation Method .................................................................................

4.7 Description, Preparation, and Delivery of Feeds for the CPT...............................

4.8 Testing During Cleaning Cycles.............................................................................

4.9 Conditioning Time Needed to Reach Steady State ................................................

4.10 AWFCO System during the CPT ...........................................................................

4.11 Anticipated Test Schedule ......................................................................................

4.12 Reporting .................................................................................................................

5.0 Sampling, Analysis, and Monitoring Procedures..........................................................5-1

5.1 Sampling Locations and Procedures.......................................................................5-1

5.1.1 Liquids Sampling Procedures.....................................................................5-1

5.1.2 Solids Sampling Procedures.......................................................................
iv

Table of Contents (continued)

Page

5.1.3 Stack Gas Sampling Procedures...................................................................

5.1.3.1 Sample Port Location ..........................................................................

5.1.3.2 EPA Methods 2 and 4 (Flowrate and Moisture).................................

5.1.3.3 EPA Method 29 (Metals).....................................................................

5.1.3.4 EPA Method 5 (PM) / APA Method 26A (HCl/Cl2)..........................

5.1.3.5 SW-846 Method 0023A (Dioxins/Furans)..........................................

5.1.3.6 Continuous Emissions Monitoring (THC, CO2, CO, O2)...................

5.2 Analysis Procedures................................................................................................

5.2.1 Composition and Physical Parameters Analysis........................................

5.2.2 Metals Analysis...........................................................................................

5.2.3 Particulate Matter Analysis ........................................................................

5.2.4 HC/Cl2 Analysis..........................................................................................

5.2.5 Dioxins/Furans Analysis ............................................................................

5.3 Process Monitoring Procedures..............................................................................

5.4 Quality Assurance/Quality Procedures...................................................................

5.4.1 Sampling QA/QC........................................................................................

5.4.2 Procedures for Analytical Quality Control ................................................

APPENDIX A Continuous Monitoring System Performance Evaluation Test Plan
v

List of Tables

Page

1-1 Applicable HWC MACT Emission Standards...................................................................1-4

1-2 Data Used To Establish OPLs.............................................................................................1-8

1-3 Cross References of Performance Test Requirements .......................................................

2-1 Technical Information Summary on Unit 2........................................................................2-5

2-2 Unit 2 Continuous Emission Monitors................................................................................

2-3 Current HWC MACT AWFCO Parameters and Limits for Unit 2 ...................................

3-1 Summary of Major HAPs Processed ..................................................................................3-1

3-2 Top Volume Liquid Waste Streams....................................................................................3-3

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

3-4 Top Containerized Solid Waste Streams ............................................................................3-4

3-5 Typical Properties for Natural Gas......................................................................................3-4

4-1 Target Feedrates and Operating Conditions .......................................................................

4-2 HWC MACT OPLs to be Established During the Metals Demonstration Test ................

4-3 Emission Standards versus Operating Parameters..............................................................

4-4 Metals Evaluation Plan........................................................................................................

4-5 Daily Schedule for the Subsequent CPT of Unit 2.............................................................

5-1 Measurement Frequency .....................................................................................................

5-2 Sampling Methods...............................................................................................................

5-3 Summary of Analytical Methods ........................................................................................

5-4 Summary of Matrix Specific QC Sample Requirements ...................................................

Figure List

Page

2-1 Unit 2 Process Flow Diagram .............................................................................................2-2

2-2 Hydrated Lime Specifications.............................................................................................
1-1

1.0 Introduction

1.1 Program Summary [40 CFR § 63.1207(f) and § 63.7(c)(2)(i)]

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

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

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

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

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

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

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

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

by the information collection requests from USEPA Region 5 dated June 5, 2008 and 

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

Unit 3, and August 21, 2008 for Unit 4. The test plans for these tests were approved by 

USEPA Region 5. The tests were designed to demonstrate compliance with the applicable 

emission standards of the HWC MACT for metals codified at 40 CFR § 63.1219(a)(2), 40 CFR

§ 63.1219(a)(3), and 40 CFR § 63.1219(a)(4) for mercury, cadmium and lead (i.e., Semivolatile 

Metals – SVM), and arsenic, beryllium, and chromium (i.e., Low Volatility Metals - LVM). 

The tests also established Operating Parameter Limits (OPLs) for mercury, and SVM and LVM 

codified at 40 CFR § 63.1209(l) and 40 CFR § 63.1209(n), respectively. 

The initial Comprehensive performance tests of Units 2, 3, and 4 commenced on December 8, 

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

Comprehensive Performance Tests were performed in accordance with Comprehensive 

Performance Test Plans approved by USEPA Region 5 on November 25, 2009. The HWC 

MACT, at 40 CFR § 63.1207(d), states “The date of commencement of the initial comprehensive 

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

performance test and the next comprehensive performance test. You may conduct performance 

testing at any time prior to the required date. The deadline for commencing subsequent 

confirmatory and comprehensive performance testing is based on the date of commencement of 

the previous comprehensive performance test.” Veolia Sauget understands that EPA Region 5’s 

position regarding commencement of the subsequent CPTs is based on the initiation of the metals 

tests performed in 2008, stating in a letter dated August 3, 2012 ―Veolia must submit to EPA a 

notification of intent to conduct a CPT and a site-specific test plan for the CPT at least one year 

before the performance test. 40 CFR § 63.1207(e)(1)(i)...by September 5, 2012‖. Veolia is 

submitting to EPA its notification of intent and site-specific test plan for the subsequent CPT by 

this date.
1-2

This document is a Comprehensive Performance Test Plan for Unit 2 for the subsequent 

comprehensive performance test (CPT) and provides notification that Veolia Sauget intends to 

start the CPTs of the three incinerators at the Sauget facility by September 5, 2013. All of the 

applicable parameters of the HWC MACT including dioxins/furans, total hydrocarbons (THC), 

carbon monoxide (CO), particulate matter (PM), hydrogen chloride/chlorine gas (HCl/Cl2), 

mercury, SVM, and LVM will be determined during the CPT. 

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

demonstrated only one time, and Veolia Sauget demonstrated DRE during RCRA Trial Burns of 

Units 2, 3, and 4 performed in January 1993, November 1996, and December 1995, respectively. 

The HWC MACT requires that DRE only be demonstrated one time as long as ―you do not feed 

hazardous waste at a location in the combustion system other than the normal flame zone‖ (§ 

63.1207(c)(2)(iv)). Veolia will not re-demonstrate DRE for Unit 2 in the subsequent CPT. DRE, 

and the associated OPLs, were demonstrated during the 1993 trial burn, and operations of the 

incinerator have not significantly changed since that test. 

This test (i.e., the subsequent CPT) is designed to demonstrate applicable emission 

standards and establish OPLs as required by the HWC MACT for dioxins/furans, total 

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

chloride/chlorine gas (HCl/Cl2), mercury, SVM, and LVM. The results of this test will be 

used to revise the current NOC.

1.2 Facility/Unit Identification

1.2.1 General

This CPT Plan is designed to demonstrate applicable emission standards and establish 

OPLs as required by the HWC MACT for dioxins/furans, total hydrocarbons (THC), carbon 

monoxide (CO), particulate matter (PM), hydrogen chloride/chlorine gas (HCl/Cl2), mercury, 

SVM, and LVM. This is a commercial hazardous waste incineration facility that treats liquid

and solid wastes that are classified as both hazardous and non-hazardous.

1.2.2 Facility ID, Mailing Address, and Primary Contacts

The facility address is: The facility contact is:

Veolia ES Technical Solutions Mr. Dave Klarich

7 Mobile Avenue Phone: 618-271-2804

Sauget, IL 62201 Email: David.Klarich@veoliaes.com

Facility ID#: ILD098642424
1-3

1.2.3 Incinerator Overview

Unit 2 is a fixed hearth incineration system with primary and secondary combustion

chambers that treats solid wastes as well as aqueous and organic liquids. The process is

monitored and controlled by a distributed control system (DCS) capable of continuously

monitoring the process to assure all operational parameters are within regulatory and permit

limits while waste is being fed to the unit. In addition, this incinerator is equipped with a

Continuous Emissions Monitoring System (CEMS) that continuously samples the exhaust gases

for carbon monoxide and oxygen in the stack gas exhaust stream.

1.3 Test Objectives

1.3.1 General

This document presents Veolia’s plan for the subsequent CPT for the Final Replacement 

Standards of the HWC MACT and is designed to demonstrate compliance with the standards and 

associated OPLs of the HWC MACT for existing incinerators at §63.1219. The CPT is designed

to:

Demonstrate that the incinerator meets the applicable HWC MACT emission 

limits while treating hazardous waste; and

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

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

while treating hazardous waste.

The test program will include feeding a variety of liquid and solid waste materials to

the incinerator, sampling and analyzing the feedstreams, spiking waste feedstreams with 

metals and chlorine, monitoring certain process parameters, and conducting emissions

testing. The emissions standards that will be demonstrated under the HWC MACT

regulations are summarized in Table 1-1.
1-4

Table 1-1. Applicable HWC MACT Emission Standards

Emissions Parameter Limit Citation

Dioxins/Furans (TEQ basis) ≤ 0.20 ng/dscm 40 CFR 63.1219(a)(1)(i)(A)

Mercury ≤ 130 g/dscm 40 CFR § 63.1219(a)(2)

Semivolatile Metals (SVM) (Cadmium and 

Lead) ≤ 230 g/dscm 40 CFR § 63.1219(a)(3) 

Low Volatile Metals (LVM) (Arsenic, 

Beryllium and Chromium) ≤ 92 g/dscm 40 CFR § 63.1219(a)(4) 

Carbon Monoxide (CO) ≤ 100 ppmv, dry 40 CFR § 63.1219(a)(5)(i)

Total Hydrocarbons (THC) ≤ 10 ppmv, dry 40 CFR § 63.1219(a)(5)(ii)

Hydrogen Chloride & Chlorine (HCl/Cl2) ≤ 32 ppmv dry, as Cl40 CFR § 63.1219(a)(6)

Particulate Matter (PM) ≤ 0.013 gr/dscf 40 CFR § 63.1219(a)(7)

Destruction and Removal Efficiency (DRE) ≥ 99.99 % 40 CFR § 63.1219(c)(1)

Note: All emission concentrations are corrected to 7% oxygen.

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

MACT are:

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

following limits, corrected to 7% O2:

— Carbon Monoxide: 100 ppmv, dry;

— Total Hydrocarbons: 10 ppmv, dry;

— Dioxins/Furans: 0.20 ng TEQ/dscm; 

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

— Mercury: 130 g/dscm;

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

— Low Volatility metals (LVM) (As, Be and Cr combined): 92 g /dscm; and

— Hydrogen Chloride/Chlorine (HCl/Cl2): 32 ppmv as Clequivalent, dry.

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

previous RCRA Trial Burn.

Establish limits for operating parameters. 

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

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

Emissions Monitoring Systems (CEMS) if a RATA of the CO and O2 CEMS does not 

occur within 60 days of the CPT.
1-5

1.3.2 Test Protocol Summary

A brief description of the subsequent CPT is provided below, and a definition of the 

applicable emission limits and the resulting operating parameter limits (OPLs) are given in 

Section 4.0. The test condition of the subsequent CPT of Unit 2 will include one mode of 

operation, and one set of OPLs will be developed.

In the first part of the test, Veolia will demonstrate compliance with the particulate matter

and HCl/Cl2 standards of the HWC MACT while the plant is operating to establish the maximum 

ash feedrate, maximum chlorine feedrate, maximum combustion gas flowrate, and other 

applicable OPLs as required by the HWC MACT for the particulate matter and HCl/Cl2

standards. Compliance with the standard for carbon monoxide will also be demonstrated during 

this test. 

In the second part of the test, Veolia will demonstrate compliance, and develop OPLs,

with the dioxins/furans, THC, CO, LVM, SVM, and mercury, SVM, and LVM standards of the 

HWC MACT while the plant is operating to establish maximum total hazardous waste feedrate, 

maximum pumpable hazardous waste feedrate, minimum primary combustion chamber (PCC) 

temperature, minimum secondary combustion chamber (SCC) temperature, maximum LVM, 

SVM, and Hgmetals feedrates, maximum chlorine feedrate, maximum combustion gas flowrate,

and maximum inlet temperature to the baghouse and other OPLs as required by the HWC MACT

for the mercury, SVM, and LVM standards. Ash will be fed to the incinerator at normal (or 

higher) levels during this test. Compliance with the standard for carbon monoxide will also be 

demonstrated during this test. 

Veolia will demonstrate compliance with the particulate matter and HCl/Cl2 standards of 

the HWC MACT while the plant is operating to establish the maximum ash feedrate, maximum 

chlorine feedrate, maximum combustion gas flowrate, and other OPLs as required by the HWC 

MACT for the particulate matter and HCl/Cl2 standards. Compliance with the standard for 

carbon monoxide will also be demonstrated during this test . 

Veolia will demonstrate compliance with the dioxins/furans, total hydrocarbons, and 

carbon monoxide standards of the HWC MACT while the plant is operating to establish the 

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

chamber (SCC) temperature, maximum total hazardous waste feedrate, maximum pumpable 

hazardous waste feedrate, maximum combustion gas flowrate, and other OPLs as required by the 

HWC MACT for the dioxins/furans, total hydrocarbons, and carbon monoxide standards. 

Chlorine will be fed to the incinerator at normal (or higher) levels during this test.

Per 40 CFR §63.1206(b)(7)(i)(A) compliance with the DRE standard is required to be 
1-6

demonstrated only one time and Veolia demonstrated DRE for Unit 2 in a January 1993 RCRA 

trial burn. Veolia will not re-demonstrate DRE for Unit 2 in the subsequent CPT for the Final 

Replacement Standards of the HWC MACT. DRE, and the associated OPLs, were demonstrated 

during the 1993 trial burn, and operations of the incinerator have not significantly changed since 

that test. The resulting OPLs associated with the standard for DRE, from the NOC, are:

Maximum Total Pumpable Waste Feedrate 3,107 lb/hr;

Maximum Total Waste Feedrate 4,017 lb/hr;

Minimum Stack Gas Flowrate 15,605 acfm;

Minimum Temperature in the Primary Combustion Chamber 1,658oF; and

Minimum Temperature in the Secondary Combustion Chamber 1,848oF.

Per 40 CFR §63.1209(i), when an operating parameter applicable to multiple standards is

demonstrated in performance tests not performed simultaneously, the most stringent limit 

applies. The OPLs required for DRE and for dioxins/furans are the same. The OPLs for 

maximum pumpable hazardous waste feedrate, maximum total hazardous waste feedrate, 

minimum temperature in the PCC, minimum temperature in the SCC, and maximum stack gas 

flowrate will be the more stringent demonstrated in the 1993 trial burn and the subsequent CPT. 

The OPL for maximum stack gas flowrate will be the most stringent demonstrated in the 1993 

trial burn and the first and second portions of the subsequent CPT.

THC is typically demonstrated in conjunction with DRE. The OPLs for THC (i.e., 

minimum combustion chamber temperature in the primary combustion chamber, minimum 

combustion chamber temperature in the secondary combustion chamber, maximum flue gas 

flowrate, maximum pumpable hazardous waste feedrate, and maximum total waste feedrate) are 

the same as the OPLs for DRE (that the same for dioxins/furans). Even though DRE will not be 

demonstrated, THC will be demonstrated during the subsequent CPT of Unit 2 during the 

dioxins/furans portion of the CPT.

The CPT will be performed to demonstrate compliance and establish OPLs for targeted 

standards, recognizing that per 40 CFR §63.1209(h)(1), ―if the performance tests...are not 

performed simultaneously, the most stringent limit for a parameter derived from independent 

performance tests applies‖. Operating conditions during the subsequent CPT represent the 

―extreme range of normal‖ conditions which will allow for establishment of HWC MACT OPLs 

that provide adequate operational flexibility. The operating parameter data will be used as shown 

in Table 1-2 to develop HWC MACT OPLs. Wastes utilized during the CPT will be typical of 

the wastes normally treated in Unit 2. The constituent spiking approaches are presented in 

Section 4.5. Upon completion of the subsequent CPT, a Notification of Compliance (NOC) will 

be prepared, and the OPLs of this NOC will replace those in the current NOC.
1-7

Table 1-2. Data Used to Establish OPLs

Demonstrated OPLs Emission Parameters to be Demonstrated 

During the CPT

Maximum Pumpable Waste Feedrate

DRE 1993

THC 

Dioxins/Furans 

Maximum Total Waste Feedrate

DRE 1993

THC 

Dioxins/Furans 

Maximum Stack Gas Flowrate

SVM 

LVM 

PM 

HCl/Cl2 

DRE 1993

THC 

Dioxins/Furans 

Minimum Combustion Chamber Temperature 

in the PCCRotary Kiln

DRE 1993

THC 

Dioxins/Furans 

Minimum Combustion Chamber Temperature 

in the SCC

DRE 1993

THC 

Dioxins/Furans 

Maximum Total Feedrate of LVM (As, Be, 

Cr) LVM 

Maximum Pumpable Feedrate of LVM (As, 

Be, Cr) LVM 

Maximum Feedrate of SVM (Pb, Cd) SVM 

Maximum Feedrate of Mercury (Hg) Hg 

Maximum Feedrate of Ash PM 

Maximum Feedrate of Total 

Chlorine/Chloride

HCl/Cl2 

LVM 

SVM 

Maximum Baghouse Inlet Temperature

THC 

Dioxins/Furans 

LVM 

SVM 

Minimum Sorbent Feedrate HCl/Cl2 

Minimum Carrier Fluid Flowrate HCl/Cl2 

1993 – Data in lieu from the January 1993 RCRA Trial Burn
1-8

1.4 Performance Test Plan Organization

This test plan has been organized in a format typically used for compliance

demonstration test programs. Table 1-3 is included so that the requirements in the HWC

MACT rule can be cross-referenced with the sections in this plan. The remainder of the

document has been organized as follows:

Section 2.0 provides a general physical description of the fixed hearth incineration

system and associated unit operations (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 physical and chemical parameters of 

the waste streams treated in the incinerator that impact thermal oxidation and 

summarizes the hazardous air pollutants presently identified in the waste streams.

Section 4.0 presents the Test Protocol including planned feed and operating

conditions, rationale for the test design, anticipated test schedule, and final report 

format.

Section 5.0 presents the sampling and analysis that will be performed during the test,

and provides an overview of the QA/QC protocols that will be followed. A Quality 

Assurance Project Plan (QAPjP) has been prepared for the tests of Units 2, 3, and 4, 

and fully describes all sampling and analysis procedures and associated QA/QC

protocols. The QAPjP is provided as a separate document.

Appendix A contains the Continuous Monitoring System Performance Evaluation 

Test Plan (CMS PETP) to be performed in conjunction with the CPT of Unit 2. 
1-9

Table 1-3. Cross Reference of Performance Test Requirements

Topic Regulatory Citation Section in this 

Document

Program Summary 40 CFR § 63.1207(f) and § 63.7(c)(2)(i) 1.1

Test Schedule 40 CFR § 63.1207(f), (f)(1)(v) and §

63.7(c)(2)(i)

4.11

Data Quality Objectives (DQOs) 40 CFR § 63.1207(f) and § 63.7(c)(2)(i) QAPjP – 3.0

Internal and External Quality Assurance Plan 40 CFR § 63.1207(f) and § 63.7(c)(2)(i) QAPjP – 9.0 & 

12.0

Analysis of Feedstreams (as fired)

Heating value, ash content, semi-volatile metals, low volatile metals,

mercury and total chlorine 

Viscosity

Identification and quantification of reasonably expected HAPs

40 CFR § 63.1207(f)(1)(i)

40 CFR § 63.1207(f)(1)(i)(A)

40 CFR § 63.1207(f)(1)(i)(B)

40 CFR § 63.1207(f)(1)(ii)(A) & (B)

3.0

Detailed Engineering Description of Combustor

Manufacturer/make/model of HWC

Type of HWC

Maximum design capacity

Feed systems

Location of combustion zone temperature device

Hazardous waste AWFCO system

Design, operation and maintenance of APC 

Justification of alternative gas flowrate measurement technique

Design, operation and maintenance of stack gas monitoring systems

40 CFR § 63.1207(f)(1)(iii)(A)

40 CFR § 63.1207(f)(1)(iii)(B)

40 CFR § 63.1207(f)(1)(iii)(C)

40 CFR § 63.1207(f)(1)(iii)(D) & (E)

40 CFR § 63.1207(f)(1)(xix)

40 CFR § 63.1207(f)(1)(iii)(F)

40 CFR § 63.1207(f)(1)(iii)(G)

40 CFR § 63.1207(f)(1)(xvii)

40 CFR § 63.1207(f)(1)(iii)(H)

2.0

2.3

2.3

2.3

2.2

2.3.3

2.8

2.5

N/A

2.6

Description of Waste Handling and Blending

Operations

40 CFR § 63.1207(f)(1)(ii)(C) 2.2.1

Detailed Test Protocol Including:

Description of sampling, monitoring and analytical procedures

Description of Planned Feed and Operating conditions during the

Performance Test

40 CFR § 63.1207(f)(1)(iv)

40 CFR § 63.1207(f)(1)(vi) & (vii)

5.0

4.0

Procedures for Rapidly Stopping Hazardous Waste Feed and Controlling

Emissions during Malfunction

40 CFR § 63.1207(f)(1)(viii) 2.3.6

Determination of Hazardous Waste Residence Time 40 CFR § 63.1207(f)(1)(ix) 2.3.4

Metal Feedrate Limit Extrapolation (if used) 40 CFR § 63.1207(f)(1)(x) 4.6

CMS and CEMS performance evaluation plans 40 CFR § 63.8(e)(4) and 1207(b)(1) Appendix A

Documentation of Expected Levels of Regulated Constituents in Other

Feedstreams that are not Analyzed

40 CFR § 63.1207(f)(1)(xi) 3.0

Documentation of Testing during Cleaning Cycle 40 CFR § 63.1207(g)(1)(i)(C) 4.8

Documentation of Conditioning Time Needed to Reach Steady State Prior

to Testing

40 CFR § 63.1207(f)(1)(xii) 4.9

Alternative Monitoring Frequency for Wet Scrubbers (if used) 40 CFR § 63.1207(f)(1)(xxiii) N/A

Other Information Deemed Necessary by the Agency 40 CFR § 63.1207(f)(1)(xxvii) ---
2-1

2.0 Engineering Description

2.1 Process Overview

Veolia operates two Fixed Hearth Dual Chambered Incinerators (Units 2 and 3) and one

rotary kiln incinerator (Unit 4) at the Sauget, IL facility. The two fixed hearth units are rated at

16 million Btu/hr each. Unit 3 is a mirror image of Unit 2. Both of these units have their own

waste handling systems as described in the following sections. The only difference being Unit 2

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

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

in service during operation.

A process flow diagram for Unit 2 is presented in Figure 2-1.

2.2 Waste Feed Systems [40 CFR § 63.1207(f)(1)(ii)(c) and (f)(1)(iii)(D) and (E)]

2.2.1 Unit 2 Liquid Waste Feed System and Blending Operations

The fixed hearth incinerators are designed to receive containers, aqueous liquid wastes,

organic liquid wastes, specialty liquid feeds, gases and direct inject liquids fed through the

aqueous or organic liquid feed systems. These units can receive any combination of wastes –

liquid, semi-solid, solid or gases – with a heat value of up to 16 million Btu/hr.

Unit 2 is supported by storage/blend tanks located in Tank Farm #1. Rates of feed are

controlled at each incinerator. Segregated liquid wastes are stored until utilized in the waste

blending facilities. At that time, liquids are delivered to the blending tanks where the daily

liquid feed to the incinerator is formulated, tested, and released to the incinerator. Blending of

stored liquid wastes to achieve optimum heating value and viscosity for incineration takes

place in Tanks 2, 4, 6 and 8. Six additional tanks (10, 20, 30, 40, 50 and 60) are used to

segregate different waste stream types for blending of liquid feed to the incinerator. Several

criteria are important in designing a blend from available wastes that have been segregated

principally by physical and chemical properties. These include compatibility, proper range of

heating value, and permit restrictions regarding elemental composition (based on emission

limitations). The material is transferred through aboveground pipelines from the tank farm to

the incinerator. Pipelines used to transfer liquid organic waste and aqueous waste are

equipped with strainers.
2-2

Figure 2-1. Unit 2 Process Flow Diagram
2-3

In compliance with the benzene NESHAP, all tanks are vented to individual carbon

adsorption canisters for removal of organics before vapor is discharged to the atmosphere. 

Each carbon adsorber canister is essentially equivalent to a 55 gallon container or greater, if

necessary. All tanks are equipped with conservation vents, in addition to the carbon canister

adsorber. All tanks are grounded, and flame arrestors are installed between the carbon

adsorbers and the tanks.

2.2.1.1 Organic and Aqueous Liquid Waste Feeds

The liquid waste injectors used in the combustion chambers are air-atomizing

injectors. These are used for injection of high Btu liquids, low Btu liquids and specialty feed

liquids. Dual fluid injection nozzles are used for atomization of the waste. Each of the

injectors is rated at 0-300 gph. The liquid waste feed nozzles are served by parallel redundant

pumps and recirculation systems with back pressure control.

2.2.1.2 Packaged Solids

Containers of wastes are sampled and analyzed after receipt in accordance with the

facility’s HWC MACT Feed Stream Analysis Plan and RCRA Waste Analysis Plan. These

wastes can then be delivered directly to Unit 2 or repacked into small combustible containers at 

the facility. Fiberboard or plastic containers (fully or partially full of waste), up to 40-gallon

size, may be charged directly to the primary chamber. These will be received at the dock

adjoining each fixed hearth incinerator, and charged to the incinerator within 24 hours or

returned to permitted storage.

Solids, usually packaged in plastic or fiberboard containers, are introduced into the

incinerator through a PLC controlled airlock-ram system located at the lower front of the

primary chamber of the incinerator. The airlock is composed of a refractory-lined door, a door

into the airlock enclosure, and two pneumatic rams. The action of the feeder is as follows:

With the incinerator door closed, the airlock door is opened;

The first pneumatic ram (load ram) pushes weighed charges of waste into the airlock 

chamber;

The airlock door is closed; and

A switch is activated either automatically or manually, which opens the door to the 

incinerator and actuates the ram (charge ram) that pushes the waste into the 

incinerator, and the ram then retracts and the incinerator door closes.
2-4

2.2.1.3 Specialty Liquid Feeds and Gases

Specialty feed systems associated with Unit 2 are:

Specialty feeder;

Compressed gas cylinder feed system; and

Direct inject liquid feed system.

2.3 Manufacturer, Make and Model of the Incinerator

[40 CFR § 63.1207(f)(1)(iii)(A)]

2.3.1 Combustion Chamber and Burners [40 CFR §63.1207(f)(1)(iii)(B) and (C)

Unit 2 features a two-stage combustion process. Ignition of waste material takes place

in the primary (lower) combustion chamber (PCC). The current OPL for the minimum 

temperature in the primary combustion chamber is 1,686 oF. A secondary (upper) combustion

chamber (SCC) serves as an ―afterburner‖ for process gases. Ignition of the waste takes place

at temperatures in excess of 1,700 °F. The current OPL for the minimum temperature in the 

secondary combustion chamber is 1,877 oF.

The fixed hearth incinerator is fabricated of carbon steel. The primary chamber has an

external diameter of 9 feet and is 17.5 feet long. The interior walls of the chamber are lined

with approximately 10 inches of brick refractory and insulation backing, making the internal

operating diameter approximately 7’2‖. The cross- sectional area of the chamber is thus 40.3

square feet. Table 2-1 provides a summary of the incinerator design specifications.

Liquid and solid waste feeds enter the lower chamber on the front-face of the

chamber. The primary burner and the specialty feed injector are located near the front-face of

the chamber and are mounted tangentially.

The primary burner is a North American burner rated at 12.0 million Btu/hr. and is

used in the lower chamber to maintain permitted temperatures. It will burn only natural gas or

No. 2 fuel oil. The burner system is supplied with combustion air at a static pressure of 30‖ 

water column (WC). The pilot for the primary burner will burn natural gas.

The fuel system for the lower chamber (and secondary combustion chamber) is

controlled by a Factory Mutual approved burner management system complete with interlocks

and safety valves.
2-5

Table 2-1. Technical Information Summary for Unit 2

Manufacturer Trade Waste

Mode Incineration l No. TWI-2000,

Series 2

Type Fixed Hearth, Dual Chamber

Date of Manufacture 1987

Dimensions Primary Chamber Secondary Chamber

External Length 17.5’ 17.5’

External Diameter 9’ 9’

Internal Diameter 7’2‖ 7’2‖

Cross-sectional area 40.3 square feet 40.3 square feet

Burners Primary Chamber Burner Secondary Chamber Burner

Manufacturer North American North American

Size 12.0 Million Btu/hr 6.0 Million Btu/hr

Fuel Natural Gas Natural Gas

Prime Mover

Induced Draft Fan 15,000 acfm @ 400

o

F saturated, 22 in. water column

2.3.2 Secondary Combustion Chamber

The secondary combustion chamber (SCC) is a horizontal, cylindrical chamber that has an

external diameter of 9 feet and is 17.5 feet long. The interior walls of the chamber are lined with

approximately 10 inches of brick refractory and insulation backing, making the internal operating

diameter approximately 7’2‖. The cross- sectional area of the chamber is thus 40.3 square feet.

Following ignition of the waste material under controlled or starved-air conditions in the

lower chamber, off- gases travel through a refractory-lined flue gas passage into the upper

chamber, which acts as an afterburner. Turbulence is achieved by the tangential introduction of

air and additional fuel in the upper chamber.

The SCC is equipped with one burner mounted tangentially on the side of the chamber.

The burner is a North American burner rated at 6.0 million Btu/hr and is fueled with natural gas or

fuel oil.

As with the primary chamber burner, the SCC burner is supplied with atomizing air and

is equipped with a burner management system. This system controls the ignition and initiates an

automatic shutoff when there is a loss of flame, combustion air supply, fuel pressure, atomizing

air pressure, or pilot burner.
2-6

Leaving the upper chamber, the hot gas stream travels through 28 feet of refractory-lined

stack sections before reaching the start of the gas scrubbing system. The combined volume of the

upper and lower chambers, the flue gas passage and the hot crossover section is approximately

1,567 cubic feet. The total retention time of combustion gases within the system is

approximately five seconds.

2.3.3 Location of Combustion Zone Temperature Device

[40 CFR § 63.1207(f)(1)(xix)]

The thermocouple that monitors temperature in the primary combustion chamber is

located on top of the chamber about 5 feet from the transition. The thermocouple that monitors

temperature in the SCC is located on top of the chamber above the transition.

2.3.4 Hazardous Waste Residence Time [40 CFR § 63.1207(f)(1)(ix)]

The hazardous waste gas residence time for Unit 2 is calculated as follows using the OPL 

for the stack gas flowrate in the current NOC:

Primary Combustion Chamber Volume – 635 ft3;

Secondary Combustion Chamber Volume – 635 ft3;

Total Volume – 1,270 ft3;

Maximum Flue Gas Flow Rate – 15,147 acfm (252 ft3/sec); and

Total Combustion Zone Residence Time = (1,270 ft3) / 252 ft3/sec) = 5.0 sec.

Since Unit 2 is a fixed hearth unit, residence time is based on the travel length of the ash 

ram that functions to clear the primary combustion chamber of solid waste residue. A travel 

length of 110 inches for the ash ram has been established as the criteria for determining when 

solid waste is no longer in the combustion zone. In the case of an ash ram failure, an elapsed 

time of one hour has been established as the criteria for determining when solid waste is no 

longer in the combustion zone. 

Since Unit 2 is a fixed hearth unit, residence time is based on the elapsed time since the 

last solids charge was put into the combustion zone or based on the travel length of the ash ram 

that functions to clear the primary combustion chamber of solid waste residue. An elapsed time 

of one hour or a travel length of 110 inches for the ash ram have been established as the criteria 

for determining when solid waste is no longer in the combustion zone.

2.3.5 Combustion System Leak

Combustion system leaks are prevented through maintaining a totally sealed

combustion chamber, coupled with the use of an induced draft fan that maintains a vacuum of

normally -4 to -6 inches of water column in both combustion chambers while wastes are
2-7

being fed to the unit.

2.3.6 Emergency Safety Vent

The incinerator is equipped with an emergency safety vent (ESV) located at the top of

the secondary combustion chamber. This ESV is a refractory-lined emergency thermal relief

vent (TRV) which is held in the closed position by a pneumatic cylinder. The control valve in

the line supplying air to the cylinder and the cylinder vent valve which opens the TRV are

located in the control room for each unit. Valve locks (with keys attached) are utilized to deter

indiscriminate operation of these valves. Opening of the TRV allows hot combustion gas to

vent from the combustion system during emergency shutdown events. The purpose 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 senses that the cap is opening.

2.4 Procedures for Rapidly Stopping Hazardous Waste Feed and Controlling 

Emissions During Equipment Malfunction [40 CFR §63.1207(f)(1)(viii)]

Equipment malfunctions are identified by the control system, observation of process

control variables, or by regular field inspections.

In the event of minor equipment malfunctions (e.g. waste feed or scrubber leaks), the

control room operator will be notified. The control room operator will then close the waste

feed valves and disable the waste feed pumps.

In the event of major equipment malfunctions (e.g. fire), the emergency stop button

located in the control room will be pushed. If this button is pushed, all equipment will switch to

its fail-safe position.

The extent to which emissions can be controlled in an equipment malfunction is 

dependent upon the type of malfunction that occurs. Waste feeds are stopped in equipment 

malfunctions, and depending on the nature of the malfunction, the air pollution control system 

remains in operation. Emissions are controlled during malfunctions by stopping all waste 

feeds (may occur manually or automatically), maintaining combustion zone and scrubber 

system temperatures within OPLs, keeping the ESV in a closed state, and maintaining 

negative pressure in the combustion zones.

2.5 Air Pollution Control Equipment [40 CFR §63.1207(f)(1)(iii)(G)]

2.5.1 Air Pollution Control Systems Descriptions

The air pollution control system consists of a spray dryer absorber and fabric filter

baghouse modules. The air pollution control system neutralizes acidic compounds and removes
2-8

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

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

third subsystem, the lime system, is used to prepare and provide lime slurry to the spray dryer

absorber for use in the chemical neutralization process. The induced draft fan and stack provide

the mechanical energy required to transport the flue gas through the interconnecting ductwork, to

its eventual discharge point to atmosphere.

2.5.1.1 Lime System

The lime system prepares lime slurry for use in the chemical neutralization process in

sufficient supply and concentration to maintain continuous flue gas treatment in the spray 

dryer absorber. The system has been designed for batch mixing to provide this service.

Veolia utilizes hydrated lime as its neutralizing agent in the air pollution control systems.

The key neutralization parameter of the hydrated lime is the ―CaO Equivalent‖. Figure 2-2 is 

the specification sheet for the hydrated lime that Veolia uses. Veolia has used this specific 

product for over 20 years and plans to continue with its use. Although, if Veolia does change

suppliers or type of lime in the future, it would have a ―CaO Equivalent‖ specification equal 

to or greater than the 72.6% shown on Figure 2-2.
2-9

Figure 2-2. Hydrated Lime Specifications

Hydrated lime is stored in a storage bin above the lime preparation area. The storage bin

is sized to hold enough hydrated lime to maintain several days of system operation at the

maximum combustion rate of the incinerator. Lime is discharged through the conical storage bin

bottom. The flow of the material from the bin is aided by a vibrating ―live bottom,‖ or bin

activator. A variable speed screw feeder is used to meter the hydrated lime in the proportions

required for batch mixing lime slurry. The lime is mixed with water in a tank beneath the lime

storage bin. The screw feeder speed and the rate that water is added to the lime slurry tank are

variable so that the desired lime solids concentration can be achieved in the tank. The variable

feed adjustments allow water and lime to be added to the lime slurry tank at a rate that will allow

a batch mode of mixing. An agitator is provided in the slurry tank to mix the water and lime and

to maintain the suspension of lime solids. The mixed lime slurry is pumped at a continuous rate

of flow through a recirculation loop to the atomizer at a rate of up to 10 gpm.
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2.5.1.2 Spray Dry Absorber

Unit 2 is equipped with a Spray Dryer Absorber (SDA) located immediately

downstream of the secondary combustion chamber. The SDA unit is fabricated of 3/8 inch

carbon steel. The function of the SDA is to:

Further cool the combustion gases from 1,600 – 2,000 °F to 300 – 500 °F;

Neutralize and remove HCl and other acids from the combustion gases; and

Remove a portion of the particulate matter (fly ash) from these gases.

Slurry flow to the spray dryer absorber (SDA) is metered by a flow control valve to obtain

the proper feed concentration to the spray dryer absorber atomizer. Automatic (or manual)

adjustment to the flow is made as a function of the output from a hydrochloric acid (HCl) analyzer

in the gas duct downstream of the fabric filter. The amount of slurry metered is proportional to the

amount of HCl monitored.

The slurry passes through a stationary swirl-type liquid distributor into the atomizer wheel

where induced centrifugal force from the rapidly spinning wheel discharges the slurry through the

wheel nozzles at high velocity. The design of the atomizer wheel, its rate of spin, and the discharge

velocity of the slurry, create a cloud of finely divided droplets around the periphery of the atomizer

wheel. Cooling water is also passed through the atomizer to provide additional gas cooling to the

system. The water flow is not metered, but is controlled by a feedback signal from the atomizer

power transmitter. This provides verification that water flow to the atomizer increases or decreases

in proportion to the spray dryer absorber outlet temperature.

Flue gas enters from the bottom of the spray dryer absorber through a vertical, centrally

located disperser. The disperser directs the flue gas through the zone filled by the atomized

slurry cloud where the flue gas and slurry mix and most of the absorption occurred. The gases

then flow downward through the absorber chamber and exit through a bottom side duct. As the

gases contact and pass through the cloud of atomized lime slurry, the water in the slurry

evaporates, cooling the gases. Simultaneously, the lime in the slurry reacts with the hydrogen

chloride in the gases to produce calcium salts. Some of the resulting dry material, consisting of 

calcium salts, fly ash and excess lime, falls to the conical bottom of the unit. The dry material

from each unit is discharged to a conveyor system which transports it to a dump trailer or

equivalent type system.

2.5.1.3 Fabric Filter

Gas exhausted from the spray dryer absorber is distributed by manifold ducts to four

fabric filter modules. The unit is operated with only three modules on-line with the fourth

module off-line in a standby mode. Within each filter module, the gas is passed through Teflon-
2-11

coated fiberglass cloth bags. The gas passes from the outside to the inside of the filter bags. 

Particulate matter entrained in the gas stream is mechanically deposited on the outside of the

filter bags as the gas passes through the cloth.

Each module has a clean air plenum and housing section to contain approximately 96

bags. Each bag is approximately 6‖ in diameter by 20’ long. The baghouses are fabricated from

3/16‖ mild steel plate, of welded construction, gas tight and stiffened to withstand the maximum

operating negative pressure. Each compartment has a tube sheet that supports the bags and

provides for top bag/cage removal. Access to the clean air plenum is via a side access door in

the clean air plenum.

The fabric filter cleaning mechanism utilizes jets of air to clean the filter bags.

Periodically, the cleaning sequence will be initiated. The sequence is started at the end of a

4-hour timed cycle, when the differential pressure across the filter reaches a predetermined

setpoint of approximately 7.0‖ w.c., or when the operator initiates a cycle. The controller then

sequences to each row of filter bags in each module, releasing a burst of air opposite to the

direction of gas flow. The quickly released burst of air dislodges dust cake on the exterior of 

each bag as it travels from the top to the bottom of the bags. Released from the bag, the dust cake

falls by gravity into the hopper at the bottom of the module. From there it is discharged to a

conveyor system which transports it to a dump trailer, or equivalent type system.

Treated by the spray dryer absorber and filtered by the fabric filters, the cleaned flue

gas exits the fabric filter modules to an outlet manifold for exhaust.

2.5.1.4 Induced Draft Fan and Stack

The induced draft fan and stack are located downstream of the fabric filter. Combustion

gases are drawn through the system by a 75 hp induced draft (ID) fan, rated at 15,000 acfm at

400

o

F saturated, and 22‖ water column pressure. The induced draft fan provides the mechanism for

transporting the incinerator flue gas through the spray dryer absorber, fabric filter, and all

interconnecting ducts. The ID fan includes an inlet volume control damper to be used to control the

velocity of the gas within the ducting and treatment devices.

Treated gases are exhausted from the induced draft fan to the atmosphere through a 90-ft.

high stack. The stack diameter for Unit 2 is 39 inches I.D. The stack is equipped with instrument

sampling ports and a sampling platform for emissions testing. Figure 5-1 in the QAPjP provides

details on the design and sample port locations and configurations for the stack.

2.6 Stack Emissions Monitoring [40 CFR §63.1207(f)(1)(iii)(H)]

The continuous emissions monitoring (CEM) system consists of sample probes,
2-12

sample delivery and conditioning apparatus, and gas analyzers. Samples are extracted from

the sampling ports on the stack. A CEM performance test and quality assurance program has

been implemented in accordance with the Appendix to Subpart EEE of Part 63—Quality

Assurance Procedures for Continuous Emissions Monitors Used for Hazardous Waste

Combustors.

Responses from each CEMS are fed to the Control System (CS) where the CO hourly

rolling average is calculated and interlocked to the waste feed cutoff valves as part of the

Automatic Waste Feed Cutoff System (AWFCO) discussed in Section 2.8, below. The

following provides a brief description of the CEMS instruments including the operating range

and measurement principal.

2.6.1 CEM System Description

The Continuous Emissions Monitoring Systems (CEMS) on Unit 2 analyzes for opacity,

carbon monoxide, hydrogen chloride, total hydrocarbons, and oxygen. These monitors, except 

opacity, are extractive devices mounted in sampling ports on the stack. Table 2-2 below

summarizes the analyzer specifications.

Table 2-2. Unit 2 Continuous Emission Monitors1

Parameter Current Mfg. Range Principle

Oxygen COSA 0-25% Electrochemical

Carbon Monoxide Ecochem MC3

0-200 ppmv

0-3000 ppmv

Infrared

Total Hydrocarbons Thermoelectron 0-100 ppmv FID

Hydrogen Chloride Ecochem MC3 0-1,000 ppmv Infrared

Opacity Teledyne 0-100% White light

Stack Gas Flow PSE/Rosemount 0-20,000 acfm Pressure drop

1 Only the carbon monoxide, oxygen, and stack gas flow rate are parameters, and monitors, regulated 

and required by the HWC MACT. The other CEMS are required by the RCRA permit for the facility. 

The opacity monitor continuously measures the stack gas opacity and reports the

measurements to an indicator and a recorder. An opacity that exceeds a preset limit

triggers an alarm and interlock.

Carbon monoxide and hydrogen chloride are monitored with extractive non-disperse

infrared analyzers. Total hydrocarbons is monitored with an extractive flame ionization detector

analyzer. Oxygen is monitored with a zirconium oxide cell.

Stack gas flowrate is continuously monitored as actual cubic feet per minute (acfm) 
2-13

using an AnnubarTM.

Only the carbon monoxide, oxygen, and stack gas flowrate are parameters, and 

monitors, regulated and required by the HWC MACT. The other CEMS are required by the 

RCRA permit for the facility. The carbon monoxide and oxygen CEMS have been certified 

according to the requirements of 40 CFR Part 60, Appendix B, Performance Specification 4B. 

A Relative Accuracy Test Audit (RATA) of the CO and O2 CEMS is conducted annually. In 

addition, a RATA of the CO and O2 CEMS will be conducted within 60 days of the 

Comprehensive Performance Test to coincide with the performance test as required by Section 

5 of the Appendix to Subpart EEE of Part 63.

2.7 Process Monitoring and Control

The facility is equipped with a state-of-the-art monitoring and control system, which

facilitates compliance with permit conditions, and otherwise, collects process control

information, facilitates efficient operation and detects and prevents damage to the facility. 

The system consists of three major components:

A human-machine interface (HMI) system;

Programmable logic controller’s (PLCs); and

A high speed Ethernet cable connects all control system components.

The desired control functions are implemented through the HMI system. All digital control and

emergency interlocks are accomplished by the PLC.

The control system is capable of monitoring the ―operational envelope‖ of the

incinerator and is capable of performing a number of activities including:

Control room indication of processor sensors located within the incinerator system 

(such as pressure indication of the field installed pressure transmitter);

Process controller for single instrument loops or an individual sub-system, such as a 

temperature control loop involving a sensor reading from one temperature transmitter 

affecting the function of one temperature control valve; and

Alarm for an exceedance of a designated setpoint, such as a high pressure or low 

temperature.

The process control computer will continuously control and monitor the operation of the
2-14

incinerator. When out-of-range conditions exist, it will notify the operator of those conditions. The

process control computer is programmed to shut-down equipment (i.e., bring the system into a safe

mode) when designated parameters are exceeded, which is a protective mechanism against

potential equipment damage, operation outside of permit limits, or conditions that might lead to a

release to the environment.

Continuous monitoring of the incinerator and scrubber system is an important aspect of

the system design. A digital readout of all monitoring instrumentation is displayed on the main

control screen. An audible and visual alarm alerts the incinerator operator to significant

deviations from normal operating conditions. This system allows an immediate response to

adverse conditions by the operator. Automatic waste feed cut-off and incineration shutdown

mechanisms are also interlocked with the monitoring system at or prior to reaching permit limit

levels. Monitoring methods and calibration frequencies required by the HWC MACT are listed

in Table 2-3.

The incinerator has an independent process control computer that interfaces to the

Quantum programmable controllers. The process computer is capable of controlling the

incinerator in case of a failure in a HMI server. This computer runs a RSVIEW HMI control

software that provides operator interface to all instrumentation and controls.
2-15

Table 2-3. Current HWC MACT AWFCO Parameters and Limits for Unit 2

System Device Units CurrentLimits in NOC

Total Pumpable Waste Feedrate1 Mass Flow Meters/Scales lb/hr ≤ 3,107 (HRA2

)

Total Waste Feedrate1 Mass Flow Meters/Scales lb/hr ≤ 4,017 (HRA)

High BTU Liquid Feedrate Mass Flow Meter lb/hr

Low BTU Liquid Feedrate Mass Flow Meter lb/hr

Direct Inject Feedrate Vehicle Scale lb/hr

Specialty Feedrate Floor Scale lb/hr

Container Feedrate Floor Scale lb/hr

Total LVM Feedrate

1 Mass Flow Meters/Scales lb/hr ≤ 47 (12-HRA3

)

Pumpable LVM Feedrate

1 Mass Flow Meter/Scales lb/hr ≤ 46 (12-HRA)

SVM Feedrate

1 Mass Flow Meters/Scales lb/hr ≤ 63 (12-HRA)

Mercury Feedrate

1 Mass Flow Meters/Scales lb/hr ≤ 0.0019 (12-HRA)

Chlorine Feedrate

1 Mass Flow Meters/Scales lb/hr ≤ 218 (12-HRA)

Ash Feedrate1 Mass Flow Meters/Scales lb/hr ≤ 617 (12-HRA)

Primary Combustion

Chamber Temperature

Type K Thermocouple °F ≥ 1,686 (HRA)

Secondary Combustion

Chamber Temperature

Type K Thermocouple °F ≥ 1,877 (HRA)

Primary Combustion Chamber Pressure Pressure Transmitter in. w.c. ≤ -0.1 (5 second delay)

Secondary Combustion Chamber Pressure Pressure Transmitter in. w.c. ≤ -0.1 (5 second delay)

Sorbent Feedrate Flow Meter lb/lb Cl2 ≥ 1.57 (HRA)

Carrier Fluid Flowrate Flow Meter gal/lb Cl2 ≥ 1.46 (HRA)

Baghouse Inlet Temperature (i.e., Spray Dryer

Adsorber Outlet Temperature) Type K Thermocouple °F ≤ 420

Stack Gas Flowrate Pitot Tube acfm ≤ 15,147

Stack Carbon Monoxide Corrected to 7% 

Oxygen

Infrared ppmv

≤ 100 (HRA)

1 Feedrate is tabulated within the DAS using measured individual stream feedrates. Total pumpable hazardous 

waste and total hazardous waste feedrates are summations of the applicable individual waste feedrates. Total 

LVM, pumpable LVM, SVM, mercury, chlorine, and ash feedrates are calculated based on the stream 

feedrates and analytical results of the applicable waste streams.

2 HRA – Hourly Rolling Average

3 12-HRA – 12-Hour Rolling Average

The incinerator has an independent process control computer that interfaces to the

2.8 Automatic Waste Feed Cut-off System [40 CFR §63.1207(f)(1)(iii)(F)]

The incinerator has an Automatic Waste Feed Cut-Off (AWFCO) System that will

shut waste feeds off in the event certain operating parameters deviate from allowable set

points. The PLC continuously monitors operating parameters, making adjustments to the

process as needed for proper control. Alarm logic is incorporated into the PLC system to

automatically initiate an AWFCO. Table 2-3 summarizes the current HWC MACT AWFCO

set points. AWFCO limits have been established based on several factors that are summarized 

below:
2-16

Regulatory Limits – Established to comply with current limits in the NOC. An example

of this type of limit is the low temperature limit, below which waste cannot be fed until

the proper limit is established.

In addition, the HWC MACT regulations require that the AWFCO system be

interlocked with the span of each process instrument that is part of the Continuous

Monitoring System (CMS). A listing of these CMS instruments and their interlocked

span setpoints is maintained as part of Veolia’s Operating Record.

Process Safety Limits – Established to assure process equipment is protected and unsafe

operating conditions do not occur. An example of this is inadequate excess air in the 

combustion chamber that can lead to fuel rich conditions. 

Utility or Power Failure – Established to facilitate a controlled shutdown of the process

during loss of process air, steam, water or electricity. An example of this is the loss of 

instrument air that is necessary for certain types of process instruments to function 

properly. Wastes will not be re-introduced into the incinerator 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

§63.1206(c)(3)(vii) provides for AWFCO operability testing to be performed less 

frequently than weekly, but at a minimum, the testing must be performed monthly. Veolia tests

the AWFCO systems bi-weekly, as weekly testing would unduly restrict and upsetinterfere with

operations. Waste feeds are ceased when AWFCO operability testing is performed and 

restarted upon completion of the testing. Bby ceasing and restarting waste feeds, potentially

increaseding emissions, such as elevated CO concentrations in the stack gas, can occur due to 

the unsteady state of the operation during these periods. Besides incurring excessive downtime,

during these testing periods, increased burning additional costs are experienced due to much 

higher natural gas consumption during this idling period to maintain the hourly average 

combustion zone temperatures. By performing the AWFCO testing on a bi-weekly basis, 

decreased emissions can be achieved and a reduction in fossil fuel usage realized. during the

downtime, and increasing operating costs. 

The current testing program has been in place under the RCRA permit for over 20 years

and has proven to be adequate in detecting problems. This rationale is included in the facility’s

AWFCO Plan. In some cases this testing occurs more frequently depending on how often actual

AWFCOs occur at the unit. When these AWFCOs occur, verification of the system operability 

is confirmed by the actuation of closed limited switches on the waste feed shutoff valves. Per

the required frequency, incinerator personnel check the functionality of AWFCO logic that is
2-17

part of the incinerator’s PLC system to make sure that should process conditions deviate from

allowable limits, the computer logic will initiate waste feed shutdowns as required.

This is accomplished by manually simulating process conditions that are outside

allowable limits and observing and documenting when the control or block valve software logic

on the waste feed line begins to initiate valve closure. Should actual AWFCOs occur during a

given testing period, these are documented by operating personnel to satisfy regulatory

requirements for system testing. Results of this testing are documented on a separate AWFCO

Testing Log and maintained as part of the unit’s Operating Record.

2.9 Air Pollution Control Equipment Maintenance Practices

[40 CFR §63.1207(f)(1)(iii)(G)]

2.9.1 Program Overview

Veolia utilizes an extensive preventative maintenance (PM) program to keep equipment

operational and prevent breakdowns and failures. Based upon the type of equipment and

historical operations and maintenance experience, schedules for various inspection and PM 

activities are followed. This includes aspects such as documenting detailed maintenance

histories on equipment, routine inspection and lubrication programs for high wear equipment

and non-destructive testing of piping and vessels using techniques like ultrasound to assess

integrity. The frequency of these activities varies depending upon the equipment, PM activity

and the incinerator’s shutdown schedule.

For example, frequent (i.e., weekly) instrument and certain mechanical equipment

checks are made for critical process items. Lubrication, vibration analysis and other mechanical

integrity checks are done at longer frequencies like monthly or quarterly. 

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

In accordance with the Continuous Monitoring System Performance Evaluation Test 

Plan (CMS PETP) in Appendix A, 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 flow meters and

scales, CEMs, pressure transmitters, thermocouples, stack flow meters, etc.).

Feedrates are tabulated within the DAS using measured individual stream 

feedrates. Total pumpable hazardous waste and total hazardous waste feed rates are 

summations of the applicable individual waste feedrates. Total LVM, pumpable LVM, 

SVM, mercury, chlorine, and ash feedrates are calculated based on the stream feedrates 

and analytical results of the applicable waste streams.
3-1

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. Prior to scheduling wastes 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 assures that only pre-approved

wastes are handled at the facility and that all necessary regulatory, handling, safety and other

important information are available to Operations personnel. Organic Hazardous Air Pollutants 

(HAPs) measured or expected (based on process knowledge) to be present in a source waste at

or above approximately 0.1 % by weight are listed in the tables in this section. Organic HAPS

not listed are, based on process knowledge, believed to be either completely absent or present in

the waste at less than 0.1 % by weight.

In addition to the information below that summarizes the top volume waste streams

processed at Veolia, Table 3-1 provides a summary of the major HAPs processed at the facility.

Veolia will provide EPA with waste profiles and chemical compositions of the anticipated 

wastes to be burned during the CPTs about one month prior to testing. Note that waste 

streams may be added or removed from this packet by test time. The test report will include

the waste profiles fed during the testing with the analytical results for the samples obtained

during tests for heating value, ash, SVM, LVM, mercury, and total chlorine.

Table 3-1. Summary of Major HAPs Processed

HAP CAS Number Annual Pounds Received

Toluene 108-88-3 1,413,638

Styrene 100-42-5 816,986

Methanol 67-56-1 779,318

Acetonitrile 75-05-8 766,568

o-Xylene 95-47-6 506,286

Ethylbenzene 100-41-4 438,753

Atrazine 1912-24-9 356,148

Methyl Isobutyl Ketone 108-10-1 347,681

Triethylamine 121-44-8 212,270

Pyridine 110-86-1 115,835
3-2

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 3-2 provides a 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 3-3 provides a summary of the top bulk solid streams handled at the Sauget

facility in the last year. Bulk solids can include streams 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 Containerized Waste

Table 3-4 provides a summary of the top containerized waste streams handled at Sauget

in the last year. Containerized wastes are received in drums and smaller cartons, boxes or pails

and can include materials such as laboratory waste, spent carbon, process residues.

3.2.4 Gaseous Wastes

Small volumes of compressed gases are processed in Unit 2 however these are minimal

in comparison to the other waste types that are treated.

3.3 Auxiliary Fuels

Natural gas is used as auxiliary fuel 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 the natural gas is provided in Table 3-5.
3-3

Table 3-2. Top Volume Liquid Waste Streams

Profile Waste Name Annual Pounds Received

397628 DE175 - IPA Wash & Filtrate Wash 4,649,673

388522 Mother Liquor Residue 2,246,160

076148 Formulation Aqueous With or Without Sevin 2,096,319

388955 1.51B Waste Organics/MKH Sencor FOE/GAU 1,723,519

388521 Upper Phase (May have cyanide) 1,530,146

697847 1.5B3/B4 Aqueous Waste (Sencor/FOE) 1,405,346

351071 Bulked Liquid for Incin (CWDTWILIQ) 1,345,870

131663 MDU-SIB Recycle Oil 1,299,755

857617 Amine and Water Mixture 1,216,946

097250 Tank Rinsate Aqueous Non-Haz 915,950

Table 3-3. Top Bulk Solid Waste Streams

Profile Waste Name Annual Pounds Received

156453 Unused Medication 151,439

393836 Hazardous Contaminated Soil 80,768

410031 Bulked Liq for Incin (CWDTWILIQ) 43,099

175684 Soil Contaminated with Xylene 38,318

251059 Metal Equipment for Cleanout 29,322

360856 Sludge -AG Chemical Hazardous 24,740

208526 Bromoxynil Octanoate; Atrazine 19,992

272684 Exchanger Pad Debris 13,328

076872 Demilitarized BDU-PPE 13,328

197763 Serfene 121 Solids 12,495
3-4

Table 3-4. Top Containerized Solid Waste Streams

Profile Waste Name Annual Pounds Received

SOL003 Solid Neutral BTU > 5000, Halogen <25% 1,285,211

LOP001 Flammable Loose Pack 821,421

597419 Toxic Solids 724,418

076154 Lab Waste (COM) 679,895

BB1445 PLC-Direct Charge 658,253

LOP003 Non Reg Material - Loose Pack 534,886

387332 Residues (Plastic Bags PPEET) 479,225

502988 Centrum Vitamin Tablet Production Waste 372,184

534022 Centrum Multi-Vitamin 357,357

LIQ003 Liquid BTU 5000-10000 Halogen, 10% 346,820

Table 3-5. Typical Properties for Natural Gas

Component Units Value Component Units Value

Methane mole % 94.428 Heptanes mole % 0.019

Ethane mole % 3.081 Octanes mole % 0.005

Propane mole % 0.582 Nitrogen mole % 0.703

Isobutane mole % 0.087 Carbon Dioxide mole % 0.824

N-butane mole % 0.129 Helium mole % 0.014

Isopentane mole % 0.040 Hydrogen mole % 0.023

N-pentane mole % 0.032 Argon mole % 0.0

Hexanes mole % 0.029 Oxygen mole % 0.004

Parameter Units Value Parameter Units Value

Heat Content, gross, dry Btu/CF 1040.5 Relative Density - 0.592

Heat Content, gross, sat. Btu/CF 1023.6 Wobbe Index - 1330
4-1

4.0 Performance Test Protocol

4.1 General Description

This CPT Plan has been designed to demonstrate compliance with all of the applicable 

standards of the HWC MACT and to establish OPLs while demonstrating compliance with

applicable, and targeted, HWC MACT emissions standards.

During the testing, Veolia will be seeking to establish new Operating Parameter Limits

(OPLs) for Unit 2. Due to 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

This test plan for Unit 2 at Sauget has been designed to demonstrate compliance with the

performance standards of the HWC MACT for all of the applicable emission standards including:

Carbon Monoxide: 100 ppmv, dry, corrected to 7% O2;

Total Hydrocarbons: 10 ppmv, dry, corrected to 7% O2;

Dioxins/Furans: 0.20 ng TEQ/dscm, corrected to 7% O2; 

Particulate Matter (PM): 0.013 grains/dscf, corrected to 7% O2;

Mercury: 130 g/dscm, corrected to 7% O2;

Semivolatile Metals (SVM) (Cd and Pb combined): 230 g /dscm, corrected to 7% 

O2;

Low Volatility Metals (LVM) (As, Be and Cr combined): 92 g /dscm, corrected to 

7% O2; and

Hydrogen Chloride/Chlorine (HCl/Cl2): 32 ppmv as Clequivalent, dry, corrected to 

7% O2.

A performance evaluation test of the Continuous Monitoring System (CMS) will be performed in 

association with the CPT (see Appendix A). A Relative Accuracy Test Audit (RATA) for the CO 

and O2 Continuous Emissions Monitoring Systems (CEMS) will be performed to coincide with 

the CPT (i.e., within 60 days of the CPT).
4-2

4.3 Test Conditions [40 CFR § 63.1207(f)(1)(vi) and (vii)]

TheAll testing is designed to demonstrate compliance with targeted HWC MACT

emissions standards while establishing OPLs required in association with the targeted standard, 

or standards. There will be one test condition, and one set of OPLs will be established. In the 

first part of the test, compliance will be demonstrated with the emission standards for PM and 

HCl/Cl2, and the OPLs required in association with these emission standards will be 

developed. In the second part of the test, compliance will be demonstrated with the emission 

standards for dioxins and furans, LVM, SVM, mercury, and THC, and the OPLs required in 

association with these emission standards will be developed. There will be three test runs 

performed at the one test condition. Section 4.11 and Table 4-5 present an anticipated daily 

schedule for the conduct of the subsequent CPT.

4.3.1 Maximum Feedrate of Metals and Chlorine

This test is designed to demonstrate compliance with the emission limits and to 

establish OPLs for the Final Replacement Standards of the HWC MACT for LVM, SVM, and 

mercury.

Unit 2 will be operated at normal combustion zone temperatures during this condition

with normal waste feedrates. The flue gas flowrate and chlorine feedrate will be maximized. The 

baghouse inlet temperature will be maximized. The target feedrates and operating conditions for

this test of the CPT are summarized in Table 4-1 and the proposed operating limits are

summarized in Table 4-2. The feedrate of ash will be at normal (or higher) levels. Table 4-1

presents the waste feeds and spiked feed materials that are planned to be fed during the testing

along with anticipated feed rates for each. In the event that selected waste feed materials contain

an appreciable quantity of chlorine, LVM, SVM, or mercury, the metals or chlorine spiking rates

may be adjusted to achieve the overall desired feed rate.

4.3.12 Maximum Feedrate of Ash and Chlorine, Minimum Sorbent and Carrier Fluid 

Flowrates to the SDA

This part of the CPTtest is designed to demonstrate compliance with the emission limits 

and to establish OPLs for the Final Replacement Standards of the HWC MACT for PM and 

HCl/Cl2.

Unit 2 will be operated at normal combustion zone temperatures with normal waste feed

rates. The flue gas flowrate and the chlorine and ash feedrates will be maximized. The target

waste and component feedrates and operating conditions for this portion this test of the CPT are 

summarized in Table 4-1 and the proposed operating limits are summarized in Table 4-2. Target 

operating conditions for this portion of the test are:
4-3

Maximum Feedrate of Ash

Maximum Feedrate of Chlorine

Maximum Stack Gas Flowrate

Minimum Sorbent Flowrate to the SDA

Minimum Carrier Fluid Flowrate to the SDA

Table 4-1 presents the waste feeds and spiked feed materials that are planned to be fed

during the testing along with anticipated feedrates for each. In the event that selected waste feed

materials contain an appreciable quantity of ash and chlorine, the ash or chlorine spiking rates

may be adjusted to achieve the overall desired feedrate.

Sampling for this portion of the test include:

Stack – PM

Stack – HCl/Cl2

Stack – CO, O2

Chlorine Spiking Material

Waste Feeds – Ash, Chlorine, Moisture, Heating Value, and Density and 

Viscosity (Liquids)

The OPLs associated with the emission standards for PM and HCl/Cl2 will be 

developed from this portion of the test using process data collected during the collection of the 

Method 5/26A sampling train.

4.3.2 Maximum Feedrate of Metals and Chlorine, Maximum Waste Feedrates, 

Minimum Temperatures in the PCC and SCC

This part of the test is designed to demonstrate compliance with the emission limits and 

to establish OPLs for the Final Replacement Standards of the HWC MACT for LVM, SVM, 

mercury, dioxins and furans, and THC.

Unit 2 will be operated at maximum hazardous waste feedrates and minimum combustion

zone temperatures. The feedrates of SVM, LVM, and Hg will be maximized, and the flue gas

flowrate and chlorine feedrate will be maximized. The baghouse inlet temperature will be

maximized. The feedrate of ash will be at normal (or higher) levels. The target feedrates and 

operating conditions for this portion of the CPT are summarized in Table 4-1 and the proposed

operating limits are summarized in Table 4-2. Target operating conditions for this portion of the 

test are:

Maximum Pumpable Hazardous Waste Feedrate
4-4

Maximum Total Hazardous Waste Feedrate

Minimum PCC Temperature

Minimum SCC Temperature

Maximum Stack Gas Flowrate

Maximum Feedrate of Pumpable LVM

Maximum Feedrate of Total LVM

Maximum Feedrate of SVM

Maximum Feedrate of Mercury

Maximum Feedrate of Chlorine

Maximum Baghouse Inlet Temperature

Table 4-1 presents the waste feeds and spiked feed materials that are planned to be fed

during the testing along with anticipated feed rates for each. In the event that selected waste feed

materials contain an appreciable quantity of chlorine, LVM, SVM, or mercury, the metals or

chlorine spiking rates may be adjusted to achieve the overall desired feed rate.

Sampling for this portion of the test include:

Stack – Dioxins/Furans

Stack – LVM, SVM, and Hg

Stack – CO, O2

Stack - THC

Cr, Pb, Hg, and Chlorine Spiking Materials

Waste Feeds – Metals (LVM – As, Be, Cr; SVM – Pb, Cd; Hg), Ash, Chlorine, 

Moisture, Heating Value, and Density and Viscosity (Liquids)

Operation of Unit 2 will remain consistent throughout the collection of the Method 29 

and Method 0023A sampling trains. The OPLs associated with the emission standards for 

LVM, SVM, Hg, dioxins/furans, and THC will be developed using process data gathered

during the collection of the Method 29 and Method 0023A sampling trains. The second part of 

the test is expected to be completed with the completion of sampling of the Method 0023A

sampling train. The Method 0023A sampling train is the longer running sampling train, and 

should be the last one completed.
4-5

Table 4-1. Target Feedrates and Operating Conditions

Parameter Units Current OPL

in NOC

Expected Feedrate or 

Operating Condition 

to be Demonstrated 

During the CPT

Pumpable Waste Feed lb/hr ≤ 3,107 3,150 - 4,000

Solids Waste Feed lb/hr 600 – 1,100

Total Waste Feed lb/hr ≤ 4,017 3,750 – 5,000

Stack Gas Flowrate Acfm ≤ 15,147 14,500 – 17,000

Temperature in the Primary Combustion Chamber oF ≥ 1,686 1,650 – 1,750

Temperature in the Secondary Combustion Chamber oF ≥ 1,877 1,800 – 1,900

Lead Spike1lb/hr 60 - 65

SemiVolatile Metals Feedrate lb/hr ≤ 63 60 -65

Chromium Spike1lb/hr 40 - 45

Pumpable Low Volatility Metals Feedrate lb/hr ≤ 46 40 - 45

Total Low Volatility Metals Feedrate lb/hr ≤ 47 40 - 45

Mercury Spike1lb/hr 0.001 – 0.003

Mercury Feedrate lb/hr ≤ 0.0019 0.001 – 0.003

Chlorine Spike1lb/hr 200 - 250

Chlorine Feedrate lb/hr ≤ 218 200 - 250

Ash Feedrate lb/hr ≤ 617 500 - 700

Fabric Filter Inlet Temperature oF ≤ 420 390 - 425

Sorbent Feedrate lb/lb Cl2 ≥ 1.57 1.25 – 2.0

Carrier Fluid Flowrate gal/lb Cl2 ≥ 1.46 1.4 – 2.0

1 Rates may be modified based on concentrations in the native waste fed during the CPT.
4-6

Table 4-2. HWC MACT OPLS to be Established During the Comprehensive Performance Test

Process Parameter Units Averaging 

Period

How Limit

Established

Expecte

d

Limit

Maximum Pumpable Waste Feed 1lb/hr 1-hr Average of maximum

HRAs for each run

3,150 – 4,000

Maximum Total Waste Feed 1lb/hr 1-hr Average of maximum

HRAs for each run

3,750 – 5,000

Maximum Flue Gas Flowrate 1 Acfm 1-hr Average of maximum

HRAs for each run

14,500 – 17,000

Minimum Temperature in the Primary Combustion Chamber 1 oF 1-hr Average of the test run

averages

1,650 – 1,750

Minimum Temperature in the Secondary Combustion Chamber 1 oF 1-hr Average of the test run

averages

1,800 – 1,900

Maximum Total Low Volatility Metals (LVM) Feedrate lb/hr 12-hr Average of the average

HRAs for each run

40 – 45

Maximum Pumpable LVM Feedrate lb/hr 12-hr Average of the average

HRAs for each run

40 – 45

Maximum Semivolatile Metals (SVM) Feedrate lb/hr 12-hr Average of the average

HRAs for each run

60 – 65

Maximum Total Mercury Feedrate lb/hr 12-hr Average of the test run

averages

0.001 – 0.003

Maximum Chlorine/Chloride Feedrate 2lb/hr 12-hr Average of the test run

averages

200 – 250

Maximum Ash Feedrate lb/hr 12-hr Average of the average 

HRAs for each run 500 - 700

Maximum Fabric Filter Inlet Temperature oF 1-hr Average of the test run

averages

390 – 425

Minimum Sorbent Feedrate lb/lb Cl2 1-hr Average of the test run

averages

1.25 – 2.0

Minimum Carrier Fluid Flowrate gal/lb Cl2 1-hr Average of the test run

averages

1.4 – 2.0

1

Per 40 CFR 63.1209(i), the most stringent limit derived from independent performance tests (i.e., Data in lieu from the January 1993 RCRA Trial Burn and the 

subsequent CPT applies.

2

Per 40 CFR 63.1209(i), the most stringent limit derived from independent performance tests (i.e., the two portions of the subsequent CPT) applies.
4-7

4.3.3 Maximum Waste Feedrates and Minimum Combustion Temperatures

This test is designed to demonstrate compliance with the emission limits and to 

establish OPLs for the Final Replacement Standards of the HWC MACT for dioxins/furans 

and THC.

Unit 2 will be operated at minimum combustion chamber temperature in the primary 

combustion chamber, minimum combustion chamber temperature in the secondary combustion 

chamber, maximum flue gas flowrate, maximum pumpable hazardous waste feedrate, and 

maximum total waste feedrate. The target feed rates and operating conditions for this test of the 

CPT are summarized in Table 4-1 and the proposed operating limits are summarized in Table 4-

2. The feedrate of chlorine will be at normal (or higher) levels. Table 4-1 presents the waste feeds

that are planned to be fed during the testing along with anticipated feedrates for each. No spiking 

of waste streams is planned for the dioxins/furans tests.

4.4 Establishing Operating Parameter Limits

An objective of the subsequent CPT for the Final Replacement Standards is to establish 

limits for a number of operating parameters while simultaneously demonstrating compliance 

with the performance standards and emission limits of the HWC MACT. Operating parameter 

limits established as required by the HWC MACT from the results of the CPT will limit 

emissions of the regulated parameters, and will ensure compliance with these standards during 

future operations. Table 4-3 identifies each emission standard and the operating parameter to be 

monitored to ensure future compliance. The HWC MACT requires operating parameters be 

established. The operating limit is set as the average of the three runs during the applicable 

portion of the CPT and the, 1993 RCRA Trial Burn, as appropriate per manufacturer 

specification, or by rule.
4-8

Table 4-3. Emission Standards versus Operating Parameters

Operating Parameter

Carbon Monoxide Stack CO CEMS concentration

Dioxins/Furans

PCC temperature

SCC temperature

Flue gas flowrate

Total waste feedrate

Pumpable waste feedrate

Baghouse Inlet Temperature

DRE

PCC temperature

SCC temperature

Flue gas flowrate

Total waste feedrate

Pumpable waste feedrate

Total Hydrocarbons (THC)

PCC temperature

SCC temperature

Flue gas flowrate

Total waste feedrate

Pumpable waste feedrate

Mercury Mercury feedrate

Particulate Matter Flue gas flowrate

Ash feedrate

Semivolatile Metals

Low Volatility Metals

Flue gas flowrate

SVM feedrate

LVM feedrate (total and pumpable)

Total chlorine and chloride feedrate

Baghouse Inlet Temperature

HCl/Cl2

Flue gas flowrate

Total chlorine and chloride feedrate

Sorbent feedrate

Carrier Fluid Flowrate

The following operating conditions will be established for the HWC MACT:

Limits on the Combustion Units

The carbon monoxide (CO) concentration is established by rule. The HRA limit is 100 

ppmv, dry basis, corrected to 7% oxygen, and will be demonstrated during all testing performed. 

The total hydrocarbon (THC) concentration is established by rule. The limit for THC 

of 10 ppmv, dry basis, corrected to 7% oxygen will be demonstrated during the dioxins/furans 

portion of the CPT.
4-9

Minimum combustion chamber temperatures in the primary combustion chamber 

(PCC) and in the secondary combustion chamber (SCC) will be established during the CPT. The 

hourly rolling average (HRA) limits are the average of the test run averages from the 

dioxins/furans tests or the limits set during the 1993 RCRA Trial Burn, whichever is more 

stringent since DRE is being demonstrated using test results from the 1993 trial burn.

Fugitive emissions are controlled by maintaining a negative pressure on the combustion 

system and by maintaining totally sealed combustion chambers. The pressure of both the PCC 

and SCC are monitored.

The maximum flue gas flowrate, measured as the stack gas flowrate, will be established 

during the CPT. Flue gas flowrate is an OPL required by standards to be demonstrated during all 

testing performed. The HRA limit is the average of the maximum hourly rolling averages for 

each run, and will be established from data from all tests conducted during the CPT or based on 

the 1993 RCRA Trial Burn, whichever is most stringent since DRE is being demonstrated using 

test results from the 1993 trial burn.

Limits on the Feedstreams

The maximum total hazardous waste feedrate to the incinerator (both the PCC and 

SCC) will be established during the dioxins/furans portion of the CPT. The HRA limit is the 

average of the maximum hourly rolling averages for each run or the limit set during the 1993 

RCRA Trial Burn, whichever is more stringent since DRE is being demonstrated using test 

results from the 1993 trial burn.

The maximum pumpable hazardous waste feedrate will be established during the 

dioxins/furans portion of the CPT. The HRA limit is the average of the maximum hourly rolling 

averages for each run during or the limit set during the 1993 RCRA Trial Burn, whichever is 

more stringent since DRE is being demonstrated using test results from the 1993 trial burn.

The maximum feedrate of mercury will be established during the metals portion of the 

CPT. The 12-hour rolling average limit is the average of the test run averages. The limit 

demonstrated during the CPT can be extended by extrapolating the measured total feedrate of 

mercury and the measured emission concentration of mercury up to 75% of the HWC MACT 

standard of 130 g/dscm or three times the spiked feedrate during the testing.

The maximum feedrate of semivolatile metals (SVM) (Pb and Cd combined) will be 

established during the metals portion of the CPT. The 12-hour rolling average limit is the 

average of the test run averages with the demonstration of maximum feedrate of SVM along with 

demonstration of higher maximum flue gas flue rate and other associated operating parameter 
4-10

limits. Feedrates for SVM and LVM will be established concurrently. The feedrate of total 

chlorine/chloride will be maximized as SVM and LVM are demonstrated. A feedrate of total 

chlorine/chloride will be developed in conjunction with the feedrates of SVM and LVM as an 

OPL for SVM. The feedrate limit for SVM can be extended by extrapolating the measured total 

feedrate of SVM and the measured emission concentration of SVM up to 75% of the HWC 

MACT standard of 230 g/dscm or 3 times the spiked feed rate during the testing.

The maximum feedrate of low volatility metals (LVM) (As, Be, and Cr combined) will 

be established during the metals portion of the CPT. Feedrate limits will be established for 

feedrate of LVM in all feedstreams (i.e., total in nonpumpable and pumpable streams) and for 

feedrate in all pumpable feedstreams. The 12-hour rolling average limits are the averages of the 

test run averages with the demonstration of maximum feedrate of LVM along with 

demonstration of higher maximum flue gas flow rate and other associated operating parameter 

limits. Feedrates for SVM and LVM will be established concurrently. The feedrate of total 

chlorine/chloride will be maximized as SVM and LVM are demonstrated. A feedrate of total 

chlorine/chloride will be developed in conjunction with the feedrates of SVM and LVM as an 

OPL for LVM. The feedrate limit for LVM can be extended by extrapolating measured total 

feedrate of LVM and the measured emission concentration of LVM up to 75% of the HWC 

MACT standard of 92 g/dscm or 3 times the spiked feed rate during the testing.

A maximum feedrate of total chlorine and chloride is established during the CPT in 

association with the establishment of feedrate limits for SVM and LVM, and with demonstration 

of the emission limit for HCl/Cl2. The 12-hour rolling average limit is the average of the test run 

averages during the metals portion or the HCl/Cl2 portion of the CPT, whichever is more 

stringent. 

A maximum feedrate of ash is established during the PM portion of the CPT with 

demonstration of the emission limit for PM. The 12-hour rolling average limit is the average of 

the test run averages during the PM portion of the CPT.

Limits on the Spray Dryer Absorber and Baghouse

The HWC MACT requires that operating parameter limits be established in association 

with standards for identified parameters. The air pollution control system of Unit 2 includes a 

spray dryer absorber and baghouse. The spray dryer absorber is designed and operated for 

control of acid gases. The regulated constituents of the HWC MACT for the spray dryer 

absorbers are HCl/Cl2. The baghouse is designed and operated for control of entrained solids. 

The regulated constituents of the HWC MACT for the baghouse are PM, SVM, LVM, and 

dioxins/furans. Operating parameter limits will be established for components of the air pollution 

control system in association with the regulated parameters. 
4-11

A maximum inlet temperature to dry particulate matter control device (i.e., the 

baghouse) is required in association with the standards for SVM and LVM, and dioxins/furans, 

and will be established during the CPT in association with the establishment of feedrate limits 

for SVM and LVM, and with demonstration of the emission limit for dioxins/furans. The HRA

limit is the average of the test run averages during the SVM and LVM portion or the 

dioxins/furans portion of the CPT, whichever is more stringent. 

The minimum sorbent feedrate to the absorbers is required in association with the 

standard for HCl/Cl2, and will be established during the HCl/Cl2 portion of the CPT. The HRA 

limit is the average of the test run averages. 

The minimum carrier fluid flowrate to the absorbers is required in association with the 

standard for HCl/Cl2, and will be established during the HCl/Cl2 portion of the CPT. The HRA 

limit is the average of the test run averages. 

4.5 Waste Feed Spiking

In order to demonstrate the required performance criteria for this program, it will be

necessary to spike the incinerator feeds with select organic and inorganic constituents. The spiking

levels and approach proposed for the CPT have been used successfully in the past for testing at not

only Veolia, but for testing at other hazardous waste combustion facilities as well.

Each spiked material will be prepared to a known specification and confirmedverified by a

certificate of analysis. These materials will be prepared and fed in a manner that assures a very

consistent feedrate. Feedrates of each spiked compound are to be well above expected levels in

native wastes such that the spiked constituent is expected to be the dominant feed of the selected 

parameter. Waste feeds will be sampled during the test and analyzed. The amounts of the selected 

parameters in the waste streams will contribute to the OPL for the waste feed rate of that constituent.

Spiking rates are also selected based on historical performance to assure that emissions can be 

detected and actual results, versus non-detect results, are used in the calculation of system removal

efficiencies (SREs).

A Standard Operating Procedure (SOP) for the preparation of the spiking materials by 

Veolia is included in the QAPjP.

4.5.1 Inorganic Constituents

Several metals will be spiked to the system to establish OPLs for the select constituents and 

calculate SREs. 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 high enough to achieve the

desired feed rate limits to be set for the system. Therefore, during the metals portion of the CPT,
4-12

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 4-4 provides an overall summary of information relevant to the metals emissions 

testing. This table shows that at conservative method detection limits for the stack sampling 

method that will be used to measure metals in the stack gas (i.e., EPA Method 29) and the spiking 

rates of these metals, a SRE can be calculated greater than SRE measured in previous test programs

of Unit 2. These calculations show that the metals spiking rates will result in measurable

concentrations in the stack gas and emission rates. This table is only used as a predictive tool, and

OPLs will be developed using actual results of the CPT. Two other points are worth noting with

regard to Table 4-4:

The spiked amount for a given metal will be the difference between the desired feed 

rate limit and the native quantity expected to be fed during the test; and

Surrogate metals will represent the whole group (in the case of LVM and SVM) and 

test results for the spiked of these two metals categories will be used to extrapolate to 

the OPL for the metal feed rate.

The three metals to be spiked are representative of the three classes of metal volatility of the HWC 

MACT, and therefore can be used to set limits for the HWC MACT metals not spiked.

4.5.2 Spiking for the LVM Category

The LVM category for incinerators includes arsenic, beryllium and chromium. Veolia plans

to spike chromium at 40 - 45 lb/hr during all three metals test runs. The SRE demonstrated during

the CPT for chromium will be used to establish the feedrate limits for total and pumpable LVM, 

using extrapolation (see Section 4.6).

Chromium will be spiked as chromic acid (unless another compound of chromium is used, 

based on availability, and approved by USEPA Region 5) through a liquid feed injector via a

pumping station that will monitor the feedrate. Waste chromic acid is treated at Veolia and thus,

spiking chromic acid during the CPT is representative of normal operations.

4.5.3 Spiking for the SVM Category

The SVM category for incinerators includes cadmium and lead. Veolia plans to spike lead

at 60 - 65 lb/hr during the CPT to establish a SRE for all three metals test runs. The SRE

demonstrated during the CPT for lead will be used to establish a SVM feed rate limit, using 

extrapolation (see Section 4.6).

Lead will be spiked as lead nitrate (unless another compound of lead is used, based on 
4-13

availability, and approved by USEPA Region 5) and fed to the incinerator in small, pre-measured

plastic baggies at regular intervals along with other solid waste feeds during the performance test.

Lead containing wastes that are normally treated at Veolia are predominantly bulk or containerized

solids and thus, this spiking approach during the CPT is representative of normal operations.

Table 4-4. Metals Evaluation Plan

Lead Chromium Mercury

Detection Limit (μg)

0.45

(0.2+0.25)1

0.50

(0.25+0.25)1

1.79

(0.14+0.87+0.085+0.47+0.22)2

Sample Volume Collected (dscf) 45 45 45

Stack Detection Limit (μg/m3) 0.35 0.39 1.40

Stack Flowrate (acfm / dscfm at 12% O2) 15,147 / 5,733 15,147 / 5,733 15,147 / 5,733

Emission Rate at Detection Limit (lb/hr) 7.6 x 10-68.5 x 10-63.0 x 10-5

Target Spiking Rate (lb/hr) 60 – 65 40 - 45 0.001 – 0.003

SRE at Detection Limit (%) 399.999238 99.999151 99.996952

Historical SRE (%) 499.999519 99.999808 55.77

Stack Gas Concentration at Expected SRE 

and Mid-Range of Target Spiking Rate (μg/m3

at 7% O2)

21 5.8 63

1 Detection Limit in Probe and Nozzle Rinse + Acidic Peroxide Impingers of EPA Method 29.

2 Detection Limit in Probe and Nozzle Rinse + Acidic Peroxide Impingers + Empty Impinger + 

Acidic Permanganate Impinger + HCl Rinse of EPA Method 29.

3 Based on the low end target spiking rate.

4 This SRE is an average of the results from the August/September 2008 test programs.

4.5.4 Spiking for Mercury

Mercury is the only high volatility metal of the HWC MACT. Veolia plans to spike

mercury at approximately 0.001 – 0.003 lb/hr during all three metals test runs. The SRE

demonstrated during the CPT for mercury will be used to establish a mercury feedrate limit, using 

extrapolation (see Section 4.6).

Mercury will be fed as a mercuric nitrate solution (unless another compound of mercury 

is used, based on availability, and approved by USEPA Region 5) contained in vials fed with solids 

to the incinerator, and will be fed placing a vial in solids fed to the incinerator at regular intervals

during the performance test. Mercury is predominantly present in solid feeds processed at Veolia
4-14

and using a liquid solution for spiking will provide an easily volatilized form fed along with

other solid feeds in a manner that is representative of normal operations.

4.5.5 Spiking for Chlorine Loading

Pursuant to 40 CFR §63.1209(n)(4) and 40 CFR §63.1209(o)(1), Veolia will be

establishing a maximum total chlorine and chloride feedrate during the CPT. The maximum 

chlorine feedrate is an OPL to be established in association with the HWC MACT standards for 

LVM and SVM, and HCl/Cl2. In addition to the chlorine being fed to the incinerator from the

native wastes, chlorine feed to the incinerator will be supplemented during the HCl/Cl2 portion and 

the SVM and LVM portion of the CPT by the spiking of hexachloroethane (unless another 

chlorinated compound is used, based on availability, and approved by USEPA Region 5). The

hexachloroethane will be delivered in small, pre-measured plastic baggies at regular intervals along

with other solid waste feeds during the performance test. The spiking will be adjusted based on the

total chlorine/chloride content of the native wastes.

Veolia believes that the native wastes will contain sufficient chlorine content to comply

with the requirement in 40 CFR §63.1207(g)(1)(A) for feeding normal (or higher) levels of

chlorine during the test for dioxins/furans. If the native wastes that are going to be fed during the

testing do not contain a sufficient chlorine content to achieve the targeted feedrate, Veolia may

need to spike chlorine during the dioxins/furans tests. The average feedrate of chlorine from 

December January 2012 through May 2013June 2012 was 3534 lb/hr.

4.5.6 Spiking for Ash Loading

Pursuant to 40 CFR §63.1209(m)(3), Veolia will be establishing a maximum ash feedrate

during the CPT. The maximum ash feedrate is an OPL to be established in association with the 

HWC MACT standard for PM. In addition to the ash being fed to the incinerator from the native

wastes, the ash feedrate to the incinerator may be supplemented during the PM portion of the CPT

if the ash content of the wastes do not contain a sufficient ash content to meet the targeted 

feedrate.

Veolia believes that the native wastes will contain sufficient ash content to comply with

the requirement in 40 CFR §63.1207 (g) (1)(B) for feeding normal (or higher) levels of ash

during the SVM and LVM performance tests. If the native wastes that are going to be fed during

the testing do not contain a sufficient ash content to meet this requirement, Veolia may need to

spike a high ash material into the solids feeds. The average feedrate of ash from 

DecemberJanuary 2012 through May 2013June 2012 was 102123 lb/hr.

4.6 Metals Extrapolation Method

As stated previously in this section, chromium (LVM), lead (SVM), and mercury will be
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spiked into the waste feeds to achieve the desired feedrates of each metals category. Veolia plans to

extrapolate to higher feedrate limits than actually fed during the test using the SREs determined 

during the test. This is appropriate since it is generally agreed that SREs at higher feedrates would

be at least as good as those observed at the lower level. Any extrapolation performed will take into

consideration the HWC MACT standards to ensure full compliance. 

The average feedrates of mercury, LVM, and SVM to Unit 2 from JuneJanuary 2012 

through May 2013June 2012 were:

Mercury LVM SVM

(lbs/hr) (lbs/hr) (lbs/hr)

Unit 2 0.00023 0.20 0.61

The maximum feedrates of mercury, LVM, and SVM to Unit 2 from mid-February to mid-June

2013 were:

Mercury LVM SVM

(lbs/hr) (lbs/hr) (lbs/hr)

Unit 2 0.0013 4.3 24.6

Based on previous discussions with EPA Region 5, the following approach will be used. 

The average SRE for the spiked compound for the three runs will be calculated from the feed and

emission rates for each run. A feedrate limit will then be calculated for each metal category by 

dividing the maximum emission rate determined using 75% of the emission standard for that

category by 1 minus the SRE (as a percentage) for the spiked compound representing that category. 

A similar approach will be followed for LVM (total and pumpable), SVM (cadmium and lead), and

mercury. To further assure that this method is protective, Veolia proposes to limit the maximum

feedrate for any one category to 3 times the spiked feedrate during the testing. The OPLs for 

feedrates of the metals will be established as 12-HRAs. Example calculations are shown below.

Maximum Emission Rate for Extrapolation (lb/hr)

= (emission standard (μg/m

3 @ 7% O2

) * 0.75 * Qstack (dscfm @ 7% O2) *

0.0283 m

3

/ft3* 60 min/hr) / (453.6 g/lb * 10

6

μg/g)

Where

Emission standard (μg/m

3 @ 7% O2

) = Applicable HWC MACT emission standard;

0.75 = 75% of the applicable HWC MACT emission 

standard;
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Qstack (dscfm @ 7% O2) = Average stack gas flowrate using the stack gas 

flowrate from each run normalized to 7% 

oxygen using the measured oxygen 

concentration from that run;

0.0283 m

3

/ft3= Conversion from cubic feet to cubic meters;

60 min/hr = Conversion from minutes to hours; and

453.6 g/lb * 10

6

μg/g = Conversion from micrograms to pounds.

Extrapolated Feedrate (lb/hr)

= Maximum Emission Rate / (1 – (SRE/100))

During the comprehensive performance testing, Veolia will spike metals at feedrates that 

are at the extreme range of normal. Veolia will feed metals at or above Veolia’s defined NOC 

rates which are well above the average feed over the last five years. These demonstrated 

feedrates will be incorporated in the subsequent NOC. Veolia will discuss with the Agency any 

further requirements that may be necessary, such as varied carbon feed rates during mercury and 

dioxins/furans testing, before extrapolation is requested. Any additional information or testing 

requirements for extrapolation purposes will be done outside of the CPT to not only satisfy the 

Agency, but also to avoid conflicts between HWC MACT testing requirements and extrapolation 

requirements.

4.7 Description, Preparation and Delivery of Feeds for the CPT

[40 CFR § 63.1207 (f)(1)(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 test parameters.

These wastes will be characterized in advance of the test and kept until needed. All waste materials

will be delivered to the facility in accordance with routine operation and currently permitted

procedures as described elsewhere in this document.

4.8 Testing During Cleaning Cycles

40 CFR 63.1207(g)(1)(i)(C) requires that tests for PM, SVM, LVM, mercury, and 

dioxins/furans include a normal cleaning cycle of the PM control device. The baghouse is the 

unit of the air pollution control train that is designed and operated to control particulate matter. 

Testing for PM, SVM, LVM, mercury, and dioxins/furans will be performed during a cleaning 

cycle of the fabric filter (i.e., baghouse). Testing in all three runs of all tests conducted will 

include a cleaning cycle of the baghouse.
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As discussed in Section 2.5.1 of this plan, jets of air are used to clean the filter bags of the 

baghouse. Periodically, the cleaning sequence is initiated, either at the end of a 4-hour timed cycle,

when the differential pressure across the filter reaches a predetermined setpoint of approximately

7.0‖ w.c., or when the operator initiates a cycle. Veolia will ensure that the baghouse undergoes a 

cleaning cycle during each run of the CPT.

4.9 Conditioning Time Needed to Reach Steady State

[40 CFR § 63.1207(f)(1)(xii)]

Since there are no recirculating scrubber flows (the lime slurry to the spray dryer is oncethrough), the conditioning time prior to sampling for the Veolia units is governed primarily by the

gas residence time from the feed point to the sampling locations. This residence time is

approximately 5 seconds (see Section 2.3.4). 

The incinerator will be operated for 15 minutes at the desired feedrates and operating conditions

before sampling begins for a given condition of the testing. This will assure all operating

parameters are stabilized at the desired settings to achieve steady state before sampling. 

The conditioning time needed to achieve steady state operation of Unit 2 is 30 minutes. 

Before sampling begins for a test run of the CPT, or a portion of the CPT, the incinerator will be

operated for 30 minutes at the desired feedrates and operating conditions, and spiking of waste 

feeds will be performed for 30 minutes. This will assure all operating parameters are stabilized at

the desired settings to achieve steady state, and that the feedrates of spiking materials have 

stabilized, before sampling begins.

4.10 AWFCO System during the CPT

The CPT will be conducted at operating conditions at the extreme range of normal. A 

primary objective of the test is to establish limits for operating parameters that ensure compliance 

with the emission standards during subsequent operations. The HWC MACT, at 40 CFR 

63.1207(h)(1) and (2), waives the OPLs during subsequent performance testing and pretesting 

under an approved test plan. 
4-18

One of the objectives of the subsequent CPT is to establish certain HWC MACT limits at

or near the limits in the current NOC. To accomplish operation near current OPLs, Veolia will 

disable the OPLs in the current NOC during the subsequent CPT. 

Veolia currently does not envision pre-testing of Unit 2 prior to the CPT. If pre-testing is 

deemed to be necessary prior to the CPT, Veolia will request a and for the 720-hour shakedown

period (i.e., pretesting) in which OPLs would be disengaged. Veolia will notify EPA Region 5 if 

pretesting is to be conducted.

4.11 Anticipated Test Schedule

The subsequent CPT of Unit 2 will be performed at one test condition (i.e., one mode of 

operation), and one set of OPLs will be developed. There are two portions to the test condition. 

In the first part of the test, Veolia will demonstrate compliance with the particulate matter and 

HCl/Cl2 standards of the HWC MACT while the plant is operating to establish the maximum ash 

feedrate, maximum chlorine feedrate, maximum combustion gas flowrate, and other applicable 

OPLs as required by the HWC MACT for the particulate matter and HCl/Cl2 standards. In the 

second part of the test, Veolia will demonstrate compliance, and develop OPLs, with the 

dioxins/furans, THC, CO, LVM, SVM, and mercury standards of the HWC MACT while the 

plant is operating to establish maximum total hazardous waste feedrate, maximum pumpable 

hazardous waste feedrate, minimum primary combustion chamber (PCC) temperature, minimum 

secondary combustion chamber (SCC) temperature, maximum LVM, SVM, and Hg feedrates, 

maximum chlorine feedrate, maximum combustion gas flowrate, and maximum inlet temperature 

to the baghouse.

 

Both parts of the test condition will include three test runs, or test periods. An individual 

run of the CPT will be performed over three successive days with the testing for the two portions of 

the single test condition performed back-to-back on each of the three days. For the first part of the 

test, target operating conditions (i.e., normal waste feedrates, maximum ash and chlorine feedrates,

maximum stack gas flowrate, and minimum sorbent and carrier fluid flowrates to the SDA) will be 

established and maintained, and chlorine will be spiked for 30 minutes prior to the start of testing. 

Once steady-state operations have been achieved, stack testing for PM and HCl/Cl2 will begin 

along with the sampling of waste feeds. The sampling time of a Method 5/26A run for PM and 

HCl/Cl2 will be one hour. It is anticipated that a Method 5/26A run for PM/HCl/Cl2 will require 

approximately one and one-half to two hours to complete. The amount of time needed to complete 

stack sampling for PM and HCl/Cl2 will determine the length of the first part of the test condition.

The collection of samples of the waste feeds, and the collection of the chlorine spiking material,

will be coordinated with the Method 5/26A stack sampling for PM and HCl/Cl2 (i.e., at the 

beginning, at port change, and at completion stack sampling).
4-19

Following completion of testing for the first part of the test, the operation of Unit 2 will be 

adjusted to the target operating conditions for the second portion of the test condition (i.e., maximum 

waste feedrates, minimum temperatures in the PCC and SCC, maximum chlorine feedrate, maximum 

stack gas flowrate, and normal or higher ash feedrate. Steady-state operation will be established 

and maintained, and Cr, Pb, Hg, and chlorine will be spiked for 30 minutes prior to the start of 

testing. Once steady-state operations have been achieved, stack testing for LVM, SVM, and Hg

and for dioxins and furans and THC will begin concurrently along with sampling of waste feeds. 

The sampling time of a Method 29 run for LVM, SVM, and Hg will be two hours. It is anticipated

that a Method 29 run for metals will require approximately two and one-half to three hours to 

complete. The sampling time of a Method 0023A run for dioxins and furans will be three hours, and 

the amount of time to complete a Method 0023A run for dioxins/furans is expected to be 

approximately three and one-half to four hours. The collection of samples of the waste feeds will 

be coordinated with the Method 0023A stack sampling for dioxins/furans (i.e., at the beginning, at 

port change, and at completion stack sampling). While spiking of Cr, Pb, Hg, and chlorine will 

continue throughout the second portion of the test, sampling of the spiking materials for Cr, Pb, 

Hg, and chlorine will be coordinated with the Method 29 stack sampling for LVM, SVM, and Hg

(i.e., at the beginning, at port change, and at completion stack sampling). The three individual 

samples of the liquid spiking solutions of Cr and Hg will be analyzed. The individual samples of 

the solid spiking materials for Pb and chlorine will be archived. A fourth set of samples of the Cr, 

Pb, Hg, and chlorine spiking solutions and materials will be collected at the completion of the 

Method 0023A sampling train for dioxins/furans. This fourth sample of the spiking solutions and 

materials will be archived.

Table 4-5 presents a schedule for the conduct of the subsequent CPT of Unit 2.
4-20

Table 4-5. Daily Schedule for the Subsequent CPT of Unit 2

Day Start Stop Activity

1 8:00 17:00 On-Site Mobilization

2

6:00 8:00 Unit Line Out – Run 1, First Part of the Test Condition

7:30 Begin Spiking of Chlorine

8:00 10:00

Run 1, First Part of the Test Condition

- Stack Testing for PM/HCl-Cl2

- Waste Feed Sampling (3 Samples)

 First Sample at Start of PM/HCl-Cl2 Sampling

 Second Sample at Port Change of PM/HCl-Cl2 Sampling Train

 Third Sample at Completion of PM/HCl-Cl2 Sampling

- Chlorine Spike Sampling

 Taken from the Solid Waste Feed Container Collected at the 

Beginning, Mid-Point, and Completion of PM/HCl-Cl2 Sampling Train

10:00 11:00 Unit Line Out, Second Part of the Test Condition

10:30 Begin Spiking of Chromium, Lead, Mercury, and Chlorine

11:00 14:00

Run 1, Second Part of the Test Condition

- Stack Testing for LVM, SVM, and Hg

- Waste Feed Sampling (3 Samples; Composited)

 First Sample at Start of Metals and Dioxins/Furans Sampling

 Second Sample at Port Change of Dioxins/Furans Sampling Train

 Third Sample at Completion of Dioxins/Furans Sampling

- Cr, Pb, Hg, Chlorine Spike Sampling (3 Samples Collected and Analyzed; 1 

Sample Archived

 First Sample at Start of Metals and Dioxins/Furans Sampling

 Second Sample at Port Change of Metals Sampling Train

 Third Sample at Completion of Metals Sampling

 Fourth Sample at Completion of Dioxins/Furans Sampling (Archived)

11:00 15:00

Run 1, Second Part of the Test Condition

- Stack Testing for Dioxins/Furans, THC

- Waste Feed Sampling (3 Samples; Composited)

 First Sample at Start of Metals and Dioxins/Furans Sampling

 Second Sample at Port Change of Dioxins/Furans Sampling Train

 Third Sample at Completion of Dioxins/Furans Sampling

- Cr, Pb, Hg, Chlorine Spike Sampling (3 Samples Collected and Analyzed; 1 

Sample Archived

 First Sample at Start of Metals and Dioxins/Furans Sampling

 Second Sample at Port Change of Metals Sampling Train

 Third Sample at Completion of Metals Sampling

 Fourth Sample at Completion of Dioxins/Furans Sampling (Archived)

15:00 17:00 Sample Recovery
4-21

Table 4-5. Daily Schedule for the Subsequent CPT of Unit 2 (continued)

3

6:00 8:00 Unit Line Out – Run 2, First Part of the Test Condition

7:30 Begin Spiking of Chlorine

8:00 10:00

Run 2, First Part of the Test Condition

- Stack Testing for PM/HCl-Cl2

- Waste Feed Sampling (3 Samples)

 First Sample at Start of PM/HCl-Cl2 Sampling

 Second Sample at Port Change of PM/HCl-Cl2 Sampling Train

 Third Sample at Completion of PM/HCl-Cl2 Sampling

- Chlorine Spike Sampling

 Taken from the Solid Waste Feed Container Collected at the 

Beginning, Mid-Point, and Completion of PM/HCl-Cl2 Sampling Train

10:00 11:00 Unit Line Out, Second Part of the Test Condition

10:30 Begin Spiking of Chromium, Lead, Mercury, and Chlorine

11:00 14:00

Run 2, Second Part of the Test Condition

- Stack Testing for LVM, SVM, and Hg

- Waste Feed Sampling (3 Samples; Composited)

 First Sample at Start of Metals and Dioxins/Furans Sampling

 Second Sample at Port Change of Dioxins/Furans Sampling Train

 Third Sample at Completion of Dioxins/Furans Sampling

- Cr, Pb, Hg and Chlorine Spike Sampling (3 Samples Collected and Analyzed; 

1 Sample Archived

 First Sample at Start of Metals and Dioxins/Furans Sampling

 Second Sample at Port Change of Metals Sampling Train

 Third Sample at Completion of Metals Sampling

 Fourth Sample at Completion of Dioxins/Furans Sampling (Archived)

11:00 15:00

Run 2, Second Part of the Test Condition

- Stack Testing for Dioxins/Furans, THC

- Waste Feed Sampling (3 Samples; Composited)

 First Sample at Start of Metals and Dioxins/Furans Sampling

 Second Sample at Port Change of Dioxins/Furans Sampling Train

 Third Sample at Completion of Dioxins/Furans Sampling

- Cr, Pb, Hg and Chlorine Spike Sampling (3 Samples Collected and Analyzed; 

1 Sample Archived

 First Sample at Start of Metals and Dioxins/Furans Sampling

 Second Sample at Port Change of Metals Sampling Train

 Third Sample at Completion of Metals Sampling

 Fourth Sample at Completion of Dioxins/Furans Sampling (Archived)

15:00 17:00 Sample Recovery
4-22

Table 4-5. Daily Schedule for the Subsequent CPT of Unit 2 (continued)

4

6:00 8:00 Unit Line Out – Run 3, First Part of the Test Condition

7:30 Begin Spiking of Chlorine

8:00 10:00

Run 3, First Part of the Test Condition

- Stack Testing for PM/HCl-Cl2

- Waste Feed Sampling (3 Samples)

 First Sample at Start of PM/HCl-Cl2 Sampling

 Second Sample at Port Change of PM/HCl-Cl2 Sampling Train

 Third Sample at Completion of PM/HCl-Cl2 Sampling

- Chlorine Spike Sampling

 Taken from the Solid Waste Feed Container Collected at the 

Beginning, Mid-Point, and Completion of PM/HCl-Cl2 Sampling Train

10:00 11:00 Unit Line Out, Second Part of the Test Condition

10:30 Begin Spiking of Chromium, Lead, Mercury, and Chlorine

11:00 14:00

Run 3, Second Part of the Test Condition

- Stack Testing for LVM, SVM, and Hg

- Waste Feed Sampling (3 Samples; Composited)

 First Sample at Start of Metals and Dioxins/Furans Sampling

 Second Sample at Port Change of Dioxins/Furans Sampling Train

 Third Sample at Completion of Dioxins/Furans Sampling

- Cr, Pb, Hg, Chlorine Spike Sampling (3 Samples Collected and Analyzed; 1 

Sample Archived

 First Sample at Start of Metals and Dioxins/Furans Sampling

 Second Sample at Port Change of Metals Sampling Train

 Third Sample at Completion of Metals Sampling

 Fourth Sample at Completion of Dioxins/Furans Sampling (Archived)

11:00 15:00

Run 3, Second Part of the Test Condition

- Stack Testing for Dioxins/Furans, THC

- Waste Feed Sampling (3 Samples; Composited)

 First Sample at Start of Metals and Dioxins/Furans Sampling

 Second Sample at Port Change of Dioxins/Furans Sampling Train

 Third Sample at Completion of Dioxins/Furans Sampling

- Cr, Pb, Hg, Chlorine Spike Sampling (3 Samples Collected and Analyzed; 1 

Sample Archived

 First Sample at Start of Metals and Dioxins/Furans Sampling

 Second Sample at Port Change of Metals Sampling Train

 Third Sample at Completion of Metals Sampling

 Fourth Sample at Completion of Dioxins/Furans Sampling (Archived)

15:00 17:00 Sample Recovery

5 8:00 17:00 Composite Waste Samples, Pack and Ship Samples, Demobilize, Contingency
4-23

It is anticipated that the Method 29 runs for metals will be approximately two and one-half 

to three hours in duration; that the Method 5/26A runs for PM/HCl/Cl2 will be approximately one 

and one-half to two hours in duration; and that the Method 0023A runs for dioxins/furans will be

approximately three and one-half to four hours in duration. These sampling trains will dictate the 

times required to complete the sampling for an individual run. 

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

the information collection requests from USEPA Region 5 dated June 5, 2008 and September 12, 

2008. These tests were designed to demonstrate compliance with the applicable emission 

standards of the HWC MACT for metals, and began on August 11, 2008 for Unit 2, August 5, 

2008 for Unit 3, and August 21, 2008 for Unit 4. The initial Comprehensive Performance Tests of 

Units 2, 3, and 4 commenced on December 8, 2009 for Unit 2; on December 1, 2009 for Unit 3; 

and on December 16, 2009 for Unit 4. The HWC MACT, at 40 CFR § 63.1207(d), states “The 

date of commencement of the initial comprehensive performance test is the basis for establishing 

the deadline to commence the initial confirmatory performance test and the next comprehensive 

performance test. You may conduct performance testing at any time prior to the required date. 

The deadline for commencing subsequent confirmatory and comprehensive performance testing 

is based on the date of commencement of the previous comprehensive performance test.” Veolia 

Sauget understands that EPA Region 5’s position regarding commencement of the subsequent 

CPTs is based on the initiation of the metals tests performed in 2008, stating in a letter dated 

August 3, 2012 ―Veolia must submit to EPA a notification of intent to conduct a CPT and a sitespecific test plan for the CPT at least one year before the performance test. 40 CFR §

63.1207(e)(1)(i)...by September 5, 2012‖. Veolia is submitteding to EPA its notification of intent 

and site-specific test plan for the subsequent CPT on September 5, 2012.by this date.

4.12 Reporting

A Notification of Compliance (NOC) and test report of the subsequent CPT of Unit 2 will be

prepared as separate documents and submitted to EPA Region 5 and Illinois EPA no later than 90

days from completion of the field test program. The test report will provide a complete, concise

presentation of the test results and will include all necessary supporting documentation.

An example outline of the NOC is presented below:

Section 1.0, Certification Statement – Statement of compliance as required by 40 CFR 63.1210(d).

Section 2.0, Introduction – Summary of test program.

Section 3.0, Unit Description – Brief unit description.

Section 4.0, Results of Comprehensive Performance Test – Summary of the results of the 

Comprehensive Performance Test.

Section 5.0, Operating Parameter Limits – Listing of the OPLs established from the 
4-24

Comprehensive Performance Test, and the data, and regulatory requirements, used to establish the 

OPLs.

Section 6.0, Bases for Establishment of OPLs – Summary of the regulatory requirements of the 

HWC MACT, and Veolia’s approach to address those requirements.

An example outline of the test report is presented below:

Section 1.0, Executive Summary – Summary of the test objectives and results.

Section 2.0, Process Operations – Brief description of the unit, and the process operating data from 

the test.

Section 3.0, Sampling and Analytical Procedures

Section 4.0, Results – The results of the test.

Section 5.0, Calculated Values – Values calculated using the results, operating data, and spiking 

rates.

Section 6.0, Quality Assurance / Quality Control – Detailed discussion of sampling and

analytical QA/QC procedures and results.

APPENDIX A – CEMS RATA Report

APPENDIX B – Spiking Report

APPENDIX C – Process Operating Data

APPENDIX D – CMS Performance Evaluation Test Report

APPENDIX E – Field Logbook

APPENDIX F – Sampling Documentation

APPENDIX G – Analytical Data Reports

APPENDIX H – Data Quality Assessments

APPENDIX I – Sampling Equipment/Instrumentation Calibration Documentation
5-1

5.0 Sampling, Analysis, and Monitoring Procedures

The subsequent CPT of Unit 2 will be performed at oneinclude multiple test conditions to 

demonstrate system performance and to establish appropriate operating parameter limits (OPLs) 

for all of the applicable standards of the HWC MACT. Sections 4.3.1, 4.3.2, and 4.3.3 present 

the tests at which the incinerator will be tested. The CPT will include three replicate sampling 

runs at the one test conditioneach of the set of multiple conditions. Table 5-1 summarizes the 

parameters that will be measured during the test and the frequency of measurement. URS will 

perform all on site sampling activities during the CPT.

5.1 Sampling Locations and Procedures

Samples will be collected of solid, liquid, and gas streams during the CPT. This section 

describes the sampling methods that will be employed. Table 5-2 summarizes the sampling 

methods for each stream and the parameters that will be determined. Because most of the 

proposed methods are standard reference methods, only brief, summary type descriptions are 

presented. More detailed descriptions are presented in the indicated reference documents and in 

the Quality Assurance Project Plan (QAPjP) for the test.

5.1.1 Liquids Sampling Procedures

Samples of the liquid waste feed and chromium spiking solution will be collected in 

amber glass bottles with Teflon cap liners. The mercury solution samples will remain in the 

vials in which the mercuric nitrate solution was fed to the incinerator. Pre-cleaned bottles 

will be purchased and used to collect the samples. The liquid waste feed samples will be

characterized for ash, total chlorine, heat content, metals (arsenic, beryllium, chromium,

cadmium, lead, and mercury), total chlorine, and moisture, density, and viscosity, in the first 

part of the test, as appropriate. and ash, total chlorine, heat content, moisture, density, viscosity, 

and metals (arsenic, beryllium, chromium, cadmium, lead, and mercury) in the second part of 

the test. URS will be collecting the spike and waste samples. 

Three samples of the liquid waste feed, and the chromium and mercury spiking 

solutions will be collected in each run. At the beginning, middle (at port change), and end of

the Method 5/26A sampling train of the first part of the test, approximately 1-liter samples of 

the liquid waste feed stream will be collected. At the beginning, middle (at port change), and 

end of the Method 0023A sampling train of the second part of the test, approximately 1-liter 

samples of the liquid waste feed stream will be collected. The 1-liter sub-samples will be 

collected at each designated sampling time, and the collected material (i.e., sub-sample) will 

be transferred into a larger container, producing a composite sample of the liquid waste feed. 

The composite liquid waste feed samples from the first part and the second part of the CPT 

will be analyzed. 
5-2

Samples of the chromium and mercury spiking solutions will be collected in each run of 

the second part of the test. At the beginning, middle (at port change), and end of the Method 

29 sampling of the second part of the test, approximately 125-mL samples of the chromium 

spiking solution will be collected. At the same frequency, samples of the mercury spiking 

solution will be collected from randomly selected waste feed containers. The individual 

samples of the chromium and mercury spiking solutions collected during each run of the test 

will be analyzed for chromium or mercury, respectively.archived. A fourth sample of the 

chromium and mercury spiking solutions will be collected at the completion of the Method 

0023A sampling train. This fourth sample will be archived.

Liquid waste samples will be collected upstream of any metal spiking location using the 

tap sampling procedure specified in U.S. EPA Method S004, ―Sampling and Analysis Methods 

for Hazardous Waste Combustion.‖ The sample tap will be flushed each time by allowing the 

sample to flow briefly before the sample is collected. This will ensure that any stagnant 

accumulation of solids, or other contaminants that may be present in the tap, does not affect the 

sample integrity or its representation of the stream being sampled.

Adequate amounts of the samples of the liquid waste feed and the chromium and mercury 

spiking solutions will be collected such that duplicate samples can be made available to EPA 

Region 5.

At the beginning, middle (at port change), and end of each test period, approximately 

1-liter samples of each liquid stream will be collected. The individual samples will be 

composited on site to provide one sample per test run. 

Samples of the chromium spiking solution will be collected at the beginning and end of 

each sampling run.
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Table 5-1. Measurement Frequency

Stream/Parameters

Sample Frequency for 

the Subsequent CPTEach Test Condition

First Part Second Part

Liquid Waste Feeds

Ash

Chlorine

Moisture

Heating Value

, Viscosity, Density

Metals

3

3

3

3

3

3

1

3

3

3

3

3

3

1

Solid Waste Feed - Containerized

Ash

Chlorine

Moisture

Heating Value

Metals

3

3

3

3

3

3

3

3

3

1

Spiking Materials2

Mercury Spiking Solution

Lead Solid Spiking Material

Chromium Spiking Solution

Chlorine Solid Spiking Material (if spiked)

3

3

3

3

3

3

3

3

Stack Gas

Metals

Particulate Matter

HCl/Cl2

Dioxins/Furans

CO2, O2

Total Hydrocarbons

Moisture

CO, O2 

43

3

1

3

3

3

Continuous3

Continuous3

Concurrent with 

isokinetic sampling

Continuous

3

1

3

Continuous2

Continuous2

Concurrent with 

isokinetic sampling

Continuous

1 Analysis is for As, Be, Cd, Cr, Pb, and Hg.

2 Samples will be archived.

32 Allowing for hourly calibration of the THC monitor.

43 Plant monitors.
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Table 5-2. Sampling Methods

Stream Sampling Method Sampling 

Frequency

Compositing 

Approach

Analytical 

Parameters

Liquid Waste 

Feeds

Grab or Scoop

(Method S007) – Solids

Tap

(Method S004) – Liquids

First part of the test 

condition -

Beginning, middle,

and end of Method 

5/26A samplingeach 

test period

Second part of the 

test condition -

Beginning, middle,

and end of Method 

0023A sampling

Composite all 

subsamples from

each test period

Ash

Chlorine

Moisture

Heating Value

Density

Viscosity

Metals1

Solid Waste Feed Grab or Scoop

(Method S007) – Solids

First part of the test 

condition -

Beginning, middle,

and end of Method 

5/26A sampling

Second part of the 

test condition -

Beginning, middle,

and end of Method 

0023A sampling

Composite all 

subsamples from 

each test period

Ash

Chlorine

Moisture

Heating Value

Metals1

Chromium 

Spiking Solution

Tap

(Method S004)

Beginning and end 

of each test period

Second part of the 

test condition -

Beginning, middle, 

and end of Method 

29 sampling

End of Method 

0023A sampling

Analyze all 

subsamples 

collected during 

Method 29 

sampling

Archive 

subsample 

collected at end of 

Method 0023A 

sampling

None - Archive

ChromiumArch

ive

Mercury Spiking 

Solution Grab

Collect one packet 

from the storage 

area each run

Second part of the 

test condition -

Beginning, middle, 

and end of Method 

29 sampling

End of Method 

0023A sampling

Analyze all 

subsamples 

collected during 

Method 29 

sampling

Archive 

subsample

collected at end of 

Method 0023A 

sampling

None - Archive

MercuryArchiv

e
5-5

Lead and 

Chlorine Spiking 

Materials

Grab

Collect one packet 

from the storage 

area each run

Second part of the 

test condition -

Beginning, middle, 

and end of Method 

29 sampling

End of Method 

0023A sampling

None - Archive Archive

Stack Gas

EPA Method 2 Concurrent with 

isokinetic sampling NR Flow Rate

EPA Method 3A

Concurrent with 

isokinetic sampling NR O2, CO2

EPA Method 4 Concurrent with 

isokinetic sampling NR Moisture

EPA Method 5

EPA Method 26A

1+ hour collected 

isokinetically NR PMHCl/Cl2

EPA Method 29 2+ hour collected 

isokinetically NR Metals 1

EPA Method 5

EPA Method 26A

1+ hour collected 

isokinetically NR PMHCl/Cl2

SW-846 Method 0023A 3+ hour collected 

isokinetically NR Dioxins/Furans

Plant CEMS Continuous NR CO, O2

1 Analysis is for As, Be, Cd, Cr, Pb, and Hg only in samples from the second part of the test condition.

NR = Not Required

5.1.2 Solids Sampling Procedures

For the containerized solid waste feedstreams, a grab sample from a randomly selected

container being fed to the incinerator will be collected using a pre-cleaned scoop. at the start of

each run, at port change, and at the completion of each run. Each of t The three sub-samples from 

the first part of the test will be composited so that the result is a single composite sample for the first 

part of the test.per run, and a Likewise, three sub-samples from the second part of the test will be

composited to produce a composite sample for the second part of the test. Three solid waste 

samples taken during both parts of the testing will be representative of the waste since the solid 

waste being fed during each run will be consistent, from a single profile. Analyses will be

performed on theis composite samples. The solid waste feed samples will be characterized for total 

chlorine, ash, moisture, and heat content in the samples from the first part of the test, and for total 

chlorine, ash, moisture, heat content, and metals (arsenic, beryllium, chromium, cadmium, lead, and

mercury) from the second part of the test and total chlorine. URS will be collecting the spike and 

waste samples.
5-6

The three samples of the solid waste feed will be collected at the beginning, middle (at 

port change), and end of the Method 5/26A sampling of the first part of the test. The three 

samples of the solid waste feed from the second part of the test will be collected at the 

beginning, middle (at port change), and end of the collection of the Method 0023A sampling 

train. 

Samples of the chlorine spiking material will be collected in each run of the first part of 

the test, and samples of the lead and chlorine spiking materials will be collected in each run of 

the second part of the test. Three grab samples of the chlorine spiking material will be 

collected at the beginning, middle (at port change), and end of the Method 5/26A sampling of 

the first part of the test. At the beginning, middle (at port change), and end of the Method 29 

sampling of the second part of the test, grab samples of the lead and chlorine spiking 

materials will be collected. A fourth sample of the lead and chlorine spiking materials will be 

collected at the completion of the Method 0023A sampling train. All samples of the lead and 

chlorine spiking materials will be archived.

Adequate amounts of the samples of the solid waste feed and the lead and chlorine 

spiking materials will be collected such that duplicate samples can be made available to EPA 

Region 5.

Samples of the chromium (i.e., chromic acid), lead (i.e., lead nitrate), mercury (i.e., solution 

of mercuric nitrate), and chlorine (i.e., hexachloroethane) spiking materials will be collected during 

each run and archived.

5.1.3 Stack Gas Sampling Procedures

The stack gas emissions will be collected for determination of the parameters indicated in 

Tables 5-1 and 5-2. The methods that will be employed are described below. 

5.1.3.1 Sample Port Location 

The stack is 90-feet high and has an inside diameter of 39 inches. There are two sets of 

two orthogonal ports located at two slightly different levels. The number of sampling points will 

be determined in accordance with EPA Method 1, and is discussed further in the QAPjP.

5.1.3.2 EPA Methods 2 and 4 (Flowrate and Moisture)

Concurrent with the performance of the isokinetic sampling train, measurements will be 

made to determine gas velocity by 40 CFR Part 60, Appendix A, Method 2, and moisture by 

Method 4.

5.1.3.3 EPA Method 29 (Metals)
5-7

Samples of the stack gas emissions will be collected isokinetically for the HWC MACT 

metals As, Be, Cd, Cr, Pb, and Hg using Method 29 from 40 CFR Part 60, Appendix A.

This method is basically an EPA Method 5 sampling train with some very specific 

modifications:

The nozzle and probe liner will be glass or quartz. All connections will be glass or 

Teflon;

The filter will be quartz or glass fiber, with a fritted glass or Teflon support;

The first impinger will be empty (optional);

The second and third impingers will contain a nitric acid/hydrogen peroxide solution;

The fourth impinger will be empty;

The fifth and sixth impingers will contain acidic potassium permanganate; and

Modified Greenburg-Smith impinger containing silica gel. 

Following sampling, the probe and nozzle of the sampling train will be recovered using a 

brush containing no metal. The probe and nozzle will be rinsed with 0.1 normal nitric acid. 

Sampling will involve collecting samples isokinetically across both diagonals of the 

stack. The sampling rate for each train will be between 0.5 and 0.75 dry standard cubic feet per 

minute. A minimum of 45 dry standard cubic feet will be collected over a minimum sampling 

time of 120 minutes.

5.1.3.4 EPA Method 5 (PM) / EPA Method 26A (HCl/Cl2)

Samples for the determination of HCl, Cl2, and particulate matter (PM) in stack emissions 

will be collected using a single sampling train meeting the requirements of both EPA Method 

26A and Method 5. This sample train consists of the following components: 

Glass (quartz) nozzle;

Heated, glass (quartz)-lined probe;

Heated Teflon mat filter with a Teflon filter support;

Optional empty knockout impinger;

Greenburg-Smith impinger containing 100 mL of 0.1 N H2SO4;

Greenburg-Smith impinger containing 100 mL of 0.1 N H2SO4;

Modified Greenburg-Smith impinger containing 100 mL of 0.1 N NaOH;

Modified Greenburg-Smith impinger containing 100 mL of 0.1 N NaOH; and

Modified Greenburg-Smith impinger containing silica gel. 
5-8

The procedures specified in EPA Method 5 and TCEQ protocol will be used to determine 

particulate matter. These procedures require the isokinetic extraction of particulate matter on a 

filter maintained at a controlled temperature. In accordance with EPA Method 26A, the 

temperature of the filter will be maintained between 248°F and 273°F. A Teflon union will be 

used to connect the quartz nozzle to the quartz probe liner. The particulate mass, which includes 

all material that condenses at or above the filtration temperature, is determined gravimetrically, 

after desiccation. 

Sampling will involve collecting samples isokinetically across both diagonals of the 

stack. The sampling rate for each train will be between 0.5 and 0.75 dry standard cubic feet per 

minute. A minimum of 30 dry standard cubic feet will be collected over a minimum sampling 

time of 60 minutes.

Chloride analysis will be performed on the impinger contents using ion chromatography 

according to Method 26A.

5.1.3.5 SW-846 Method 0023A (Dioxins/Furans)

Stack gas emissions samples will be collected for dioxins/furans using SW-846 Method 

0023A. The sampling train consists of a heated probe, heated filter, sorbent module, and 

pumping and metering unit. A gooseneck nozzle of proper size to allow isokinetic sample 

collection is attached to the probe. S-type pitot differential pressure is monitored to determine the 

isokinetic sampling rate. 

From the heated filter, sample gas enters the sorbent module. The sorbent module 

consists of a water-cooled condenser followed by the XAD-2 resin trap. After the resin trap is a 

dry modified Greenburg-Smith impinger that collects the aqueous condensate. The stem of this 

impinger is short to reduce carryover of collected aqueous condensate. Following the condensate 

trap are two impingers containing 100 mL of DI water to collect any mist carryover from the 

condensate trap and a final impinger containing a desiccant to dry the sample gas before 

metering. A pump and dry gas meter are used to control and monitor the sample gas flowrate.

Sampling of the stack gases will be conducted in accordance with published protocol. 

This will involve collecting samples isokinetically across both diagonals of the stack. The 

sampling rate for each train will be between 0.5 and 0.75 dry standard cubic feet per minute 

(dscfm). A minimum of 2.5 dry standard cubic meters (88.3 dry standard cubic feet) will be collected over a minimum sampling time of 3 hours.

5.1.3.6 Continuous Emissions Monitoring (THC, CO2, CO and O2)
5-9

CEMs will be used to monitor the concentrations of THC (total hydrocarbons), CO2, CO, 

and O2 in the stack gas.

CO and O2 results will be reported for the stack gases from permanent installation CEMS 

of the incinerator facility. THC, CO2, and O2 continuous monitors will be provided by the test 

contractor conducting the test. 

The concentrations of total hydrocarbons (THC), carbon dioxide (CO2), and oxygen (O2) 

in the stack gas will be determined by the test contractor conducting the test using EPA Methods 

25A and 3A, respectively. CO2 and O2 will be monitored using Method 3A to determine the 

stack gas composition (i.e., molecular weight) to determine the flowrate of the stack gas. Both of 

these methods utilize continuous monitors. 

5.2 Analysis Procedures

Samples collected during the Comprehensive Performance Test will be analyzed for the 

parameters specified in Table 5-3. This section describes the analytical methods that will be 

employed. Since most of the proposed methods are standard reference methods, only brief 

summary type descriptions are presented. More detailed descriptions can be found in the 

indicated reference documents and in the QAPjP. All analyses will be performed by Test 

America Laboratories in Knoxville, TN. Analytical results for the waste feed samples will be 

reported on an as-received or wet weight basis. Samples of the waste feed will not be dried prior 

to analysis.

Table 5-3. Summary of Analytical Methods

Parameter Stream Analytical Method

O2, CO2 Stack Gas EPA Method 3A

Moisture Stack Gas EPA Method 4

Metals Waste Feeds, Stack Gas

ICPES - SW-846 Method 6010B 

CVAAS - Hg, SW-846 Method 

7470A or 7471A

Particulate Matter Stack Gas Gravimetric - EPA Method 5

HCl/Cl2 Stack Gas IC - EPA Method 26A

Dioxins/Furans Stack Gas HRGC/MS – SW-846 Method 8290

Composition/Physical Parameters Waste Feeds EPA and/or ASTM Standard 

Methods

5.2.1 Composition and Physical Parameters Analysis

Samples of the waste feeds will be collected for determination of a number of chemical 
5-10

and physical parameters, including:

Ash;

Total chlorine;

Moisture;

Heating value;

Density; and

Viscosity. 

These analyses will be performed using appropriate EPA and/or ASTM standard 

methods.

5.2.2 Metals Analysis

Waste feed samples will be analyzed for metals using a trace level inductively coupled 

argon plasma emission spectroscopy (ICPES) and atomic absorption spectroscopy. Samples will 

be prepared for analysis using SW-846 Method 3050B. The metals to be analyzed by ICPES 

(SW-846 Method 6010B) are arsenic (As), beryllium (Be), cadmium (Cd), chromium (Cr), and 

lead (Pb). Mercury (Hg) will be analyzed using Method 7471A of SW-846. 

The Method 29 sampling train will be used to collect samples of the stack gas for metals. 

The samples will be analyzed using ICPES according to SW-846 Method 6010B, and mercury 

will be analyzed using Method 7470A of SW-846. The metals to be analyzed by ICPES are As, 

Be, Cd, Cr, and Pb. 

5.2.3 Particulate Matter Analysis

The particulate matter concentration of the stack gas will be determined following 40 

CFR 60, Appendix A, Method 5 protocols. The wash from the nozzle, probe liner, and glassware 

prior to the filter on the sampling train will be evaporated, and the mass determined on an 

analytical balance. The filter will be removed from the sampling train, desiccated, and weighed 

to determine the mass of particulate on the filter. The combined mass from the filter and the 

evaporated wash are then related to the total volume of gas sampled to determine the particulate 

loading. 

5.2.4 HCl and Cl2 Analysis 

The sulfuric acid and sodium hydroxide impinger catches from the Method 5/26A 

sampling train will be analyzed for chloride ion concentrations. Chloride analysis will be 

performed using EPA Method 26A, an IC technique.

5.2.5 Dioxins/Furans Analysis

Samples of the stack gas collected using SW-846 Method 0023A will be analyzed for 
5-11

dioxins/furans using SW-846 Method 8290, high resolution gas chromatography (HRGC) with 

high resolution mass spectroscopy (HRMS) analytical technique. The analytical protocol 

includes quantitation of all dibenzodioxins and dibenzofurans including four or more chlorine 

atoms. The method provides congener class definition for each of the five congener groups 

(tetra-, penta-, hexa-, hepta-, and octa-). In addition, each individual isomer containing the 

2,3,7,8-substitution pattern will be individually quantified.

5.3 Process Monitoring Procedures

The incinerator system is monitored to ensure that it is operating in accordance with the 

permitted conditions. During the performance test, the automatic waste feed cutoff system will be 

operational; however, AWFCO limits in the current NOC will be adjusted or disabled during the 

performance testing period, and during a 720-hour shakedown period prior to the test, if pretesting is conducted. Veolia will notify EPA Region 5 if pretesting is to be conducted.

5.4 Quality Assurance/Quality Control Procedures

An effective QA/QC strategy is essential to ensure the usefulness and reliability of data 

collected in any source testing effort. This QA/QC program is documented in a project-specific 

QAPjP. The QAPjP details QA/QC activities for the Comprehensive Performance Test, as well 

as specifications for sampling and analysis activities, objectives, and procedures. The QAPjP 

conforms to the requirements detailed in Guidance for Quality Assurance Project Plans (QA/G5). ―Preparation Aid for HWERL’s Category II Quality Assurance Project Plans,‖ U.S. EPA, 

June 1987 (PA QAPjP-0007-GFS). 

The primary objective of the QA/QC effort will be to provide the mechanism whereby 

the quality of the measurement data is known and documented and is subject to ongoing 

evaluation throughout the course of the project. To achieve this objective, the QA/QC program 

must serve two distinct, interrelated functions. One function will be that of providing a QC 

database which, together with performance audit results, can be used to assess measurement data 

quality in terms of precision and accuracy. Inherent and implied in this assessment function is a 

second, parallel function of controlling data quality within prescribed limits of acceptability.

The QAPjP delineates specific sampling and analytical procedures, calibration 

requirements, internal QC checks, data reduction and validation procedures, and sample custody 

requirements for each sampling/analytical activity. It also addresses general QA/QC 

considerations such as:

Data recording;

Documentation procedures;

Project organization and responsibilities;
5-12

Preventative maintenance operations;

Reporting requirements; and

Corrective action mechanisms. 

In addition to these general considerations, the QAPjP specifies schedules for 

performance and the duration of sampling (especially for stack gas samples) to provide adequate 

method detection limits to demonstrate compliance with the metals emission standards. The 

QAPjP also devotes considerable attention to the internal QC checks that will be used to ensure 

that the measurement data meet data quality requirements. These QC checks include procedures 

such as:

Daily calibration of analytical instruments;

Calibration of sampling equipment and apparatus; and

Analytical checks using QC standards to assess bias and precision. 

The following sections present a brief overview of the QA/QC activities that are an 

integral part of the stack test program. Table 5-4 lists specific QA/QC activities that will be 

performed. 
5-13

Table 5-4. Summary of Sampling and Analytical QC Requirements1

Field

Blank2

Trip

Blank3

BreakThrough

Duplicate 

Sample or 

Analysis4,5

MS/

MSD6

LCS/LCSD

Surrogate

Spike

Particulate Matter

 Stack Gas 1 1

HCl/Cl2

 Stack Gas 1 1 All 1 1

Dioxins/Furans

 Stack Gas 1 1 1 All

Metals

 Stack Gas 1 1 1 1

 Waste Feeds 1 1 1

Composition

 Waste Feeds 1 1

7

1 Table indicates number of QC samples planned for the Comprehensive Performance Test, unless otherwise 

indicated. 

2 Field blanks for gas samples are recovered from assembled trains that have been leak checked but through 

which no gas sample has passed. 

3 Trip blanks consist of applicable filters, sorbents, and solutions. These will be analyzed only if necessary based 

on field blank analysis results. 

4 Field duplicates will be collected as duplicate sets of subsamples used to prepare the composite sample.

5

Field duplicate will be collected of the liquid waste only in the CPT of each unit.

6 Matrix spiked samples will be spiked prior to sample preparation (digestion/extraction), except for metals train 

samples, which will be spiked following digestion.

7 MS/MSD for chlorine only.

5.4.1 Sampling QA/QC

The QAPjP prescribes QC procedures to be implemented during all sampling activities 

and specifies guidelines for:

Equipment calibration;

Sampling protocol; and

Sample handling techniques. 

The checkout and calibration of sampling equipment is an important function in 
5-14

maintaining data quality. Referenced calibration procedures are prescribed, and the results will 

be properly documented and retained. Calibrations will be performed prior to field deployment.

Sampling techniques to be used during the Comprehensive Performance Test will be EPA

references. Sample collection will be done in accordance with the methods prescribed in the 

QAPjP. The QA procedure checks will include the use of standard data forms and source 

sampling data sheet checklists. Other checks will include performance of the following:

Visual inspections of sampling systems;

System leak checks before and after sampling;

Heating system checks;

Impinger ice checks;

Isokinetic sampling rate checks; and

Daily data review and calculation checks. 

After the samples have been properly obtained in the field, their subsequent handling 

during transfer to the analytical laboratories becomes an important factor in the successful 

performance of a stack test program. All collected samples will be labeled with adequate 

descriptions of the samples to prevent confusion among multiple samples. Samples will be 

inventoried against logbook records before shipment. All sample container closures will be taped 

to ensure against sample leakage during shipment. The frequency of performance of specific 

activities for this stack testing is presented in Table 5-4.
5-15

Table 5-4. Summary of Matrix Specific QC Sample Requirements1

Field 

Blank2

Trip

Blank3

Duplicate Sample 

or Analysis4

MS/

MSD5 LCS/LCSD SurrogateSpike

Metals

 Stack Gas 1 1 1 1

 Wastes 1 1 1

Particulate Matter

 Stack Gas 1 1

HCl/Cl2

 Stack Gas 1 1 All 1 1

Dioxins/Furans

 Stack Gas 1 1 All

Composition

 Wastes 1 1

6

1 Table indicates number of QC samples planned for the Comprehensive Performance Test, unless otherwise

indicated. 

2 Field blanks for gas samples are recovered from assembled trains that have been leak checked but through 

which no gas sample has passed. 

3 Trip blanks consist of applicable filters, sorbents, and solutions. These will be analyzed only if necessary based 

on field blank analysis results. 

4 Field duplicates of waste feeds will be collected as duplicate sets for subsamples for compositing.

5 Matrix spiked samples will be spiked prior to sample preparation (digestion/extraction), except for metals train 

samples, which will be spiked following digestion.

6 MS/MSD for chlorine only.

5.4.2 Procedures for Analytical Quality Control

A regime of analytical QA/QC is specified in the QAPjP. The procedures will use various 

checks to determine the validity of analyses. These include:

Calibration standards;

Certified standards;

In-lab standards;

Blanks;

Spikes; and

Replicates. 

QA begins with the sample log and continues through the reporting of data. The unique 

identifying number assigned in the field and recorded in the sample log facilitates tracking and 
5-16

identification and prevents mix-ups during the analysis process. Chain-of-custody reports will be 

used to monitor samples through analytical laboratories.

Chemical characterization of emission and process samples will be performed using 

standard wet-chemistry, IC, ICPES, AAS, and GC/MS techniques. The accuracy and precision of 

analyses will be documented through the QA/QC programs specified in the QAPjP. Accuracy 

will be evaluated by analyzing standards and blank and spiked samples. Precision data will be 

reported for matrix spike duplicates, analytical duplicate samples, and surrogate spikes. 
Appendix A

Continuous Monitoring System

Performance Evaluation Test Plan