A UG 1 6 2013 

GWV!RONM£NTAL SERVICES 

(Fed-Ex'd) 

August 15, 2013 

Mr. David Ogulei 

US Environmental Protection Agency 

Region 5 

77 West Jackson Blvd 

Mail Code: AR-18J 

Chicago, IL 60604-3507 

Dear Mr. Ogulei, 

Enclosed are two copies of the Addendum to Application for Renewal of a Major Source 

Operating Permit for the Veolia ES Technical Solutions, L.L.C. Sauget, Illinois facility. 

The Addendum is comprised of the Veolia Title V permit renewal application submitted 

in April 2013 and all information referenced in the April 2013 submittal. Previously 

referenced material is included now in expanded form, as requested, to aid the review 

process. 

If you have any questions on this submittal or would like to meet and discuss this 

addendum, please call Dennis Warchol or Doug Harris at (618) 271-2804. 

Sincerely, 

Nancy L. Paddock 

Environmental Engineering Specialist 

Att. 

C: EPA File 

#7 Mobile Avenue, Sauget, IL 62201 

(618) 271-2804 

www.veoliaes.com 
:AUS I 6 

ADDENDUM TO APPLICATION FOR 

RENEWAL OF A MAJOR SOURCE 

OPERATING PERMIT 

Veolia ES Technical Solutions 

#7 Mobile Avenue 

Sauget, Illinois 62201 

AUGUST 2013 

l 
TABLE OF CONTENTS 

I. COMPLIANC E CERTIFICATION 1 

II. INTRODUCTION 2 

III. FACILITY DESCRIPTION 3 

A. Air Permit History 3 

B. Process Information 3 

1. Storage Units 4 

a. Tanks 4 

b. Containers 5 

2. Incineration Units 6 

a. Unit 2 and Unit 3 6 

b. Unit 4 7 

c. Air Pollution Control Devices - Unit 2 and Unit 3 9 

d. Air Pollution Control Devices - Unit 4 11 

3. Other Treatment Units 15 

a. Material Processing Areas 15 

b. Bulk Feed Building 15 

c. Glove Box Building 15 

d. Drum Crusher 16 

4. Ancillary Processes 16 

C. General Air Emission Information 16 

IV. REGULATOR Y APPLICABILITY AND PERMIT CONDITIONS 17 

A. Facility-wide Requirements 17 

1. Fugitive Particulate Matter [35 IAC 212.301] 17 

2. Open Burning Prohibitions [35 IAC 237.102] 17 

3. Organic Emissions from Pumps and Compressors [35 IAC 219.142] 17 

4. NESHAP from Off-site Waste and Recovery Operations: Equipment Leaks 

[40 CF R 63.691(b)(1); 40 CF R 61 Subpart V] 17 

5. Prevention of Significant Deterioration and Nonattainment New Source 

Review 17 

B. Incinerators: Unit 2, Unit 3, and Unit 4 Emission Standard Requirements 18 

1. Visible Emissions 18 

a. Visible Emissions Limitations [35 IAC 212.123(a)] 18 

b. Fugitive Particulate Matter [35 IAC 212.301 and 212.314] 18 

2. Sulfur Dioxide Emissions 19 

a. Sulfur Dioxide Annual Emission Limitation 19 

3. Carbon Monoxide Emissions 19 

a. NESHAP for Hazardous Waste Combustors [40 CF R 63.1219(a)(5)] 19 

b. Carbon Monoxide Limitations for Incinerators [35 IAC 216.141] 19 

c. Carbon Monoxide Annual Emission Limitation 19 

4. Particulate Matter Emissions 19 

a. Particulate Matter Limitations for Incinerators [35 IAC 212.181(b)] 19 

b. NESHAP for Hazardous Waste Combustors [40 CF R 63.1219(a)(7)] 20 
c. Particulate Matter Annual Emission Limitation 20 

5. Volatile Organic Material Emissions 20 

a. Use of Organic Material [35 IAC 219.301 and 219.302] 20 

b. Volatile Organic Material Annual Emission Limitation 20 

6. Nitrogen Oxide Emissions 20 

a. Nitrogen Oxide Annual Emission Limitation 20 

7. Hazardous Air Pollutant Emissions 20 

a. NESHAP for Hazardous Waste Combustors - Dioxin and Furan Emission 

Limitations [40 CF R 63.1219(a)(1)] 20 

b. NESHAP for Hazardous Waste Combustors - Mercury Emission 

Limitations [40 CF R 63.1219(a)(2)] 21 

c. NESHAP for Hazardous Waste Combustors - Semi-volatile Metal Emission 

Limitations [40 CF R 63.1219(a)(3)] 21 

d. NESHAP for Hazardous Waste Combustors - Low Volatile Metal Emission 

Limitations [40 CF R 63.1219(a)(4)] 21 

e. NESHAP for Benzene Waste Operations [40 CFR 61.348(a)(l)(iii)] 21 

f. NESHAP from Off-site Waste and Recovery Operations [40 CFR 

63.689(c)(2)] 21 

8. Hydrogen Chloride Emissions 21 

a. NESHAP for Hazardous Waste Combustors - Hydrogen Chloride Emission 

Limitations [40 CF R 63.1219(a)(6)] 21 

b. Hydrogen Chloride Emission Limitation 21 

9. Destruction and Removal Efficiency (DRE) Requirement 22 

a. NESHAP for Hazardous Waste Combustors - DRE Standard [40 CFR 

63.1219(c)(1)] 22 

b. NESHAP for Hazardous Waste Combustors - DR E Standard [40 CF R 

63.1219(c)(2)] 22 

c. NESHAP for Hazardous Waste Combustors - DR E Standard [40 CF R 

63.1219(c)(3)] 22 

C. Incinerators: Unit 2, Unit 3, and Unit 4 Work Practice and Operational 

Requirements 23 

1. Operating Parameter Limits 23 

a. NESHAP for Hazardous Waste Combustors [40 CF R 63.1206(a), (b) and 

63.1209)0) through (p)] 23 

b. NESHAP for Hazardous Waste Combustors [40 CF R 63.1206(c)(1) and 

63.1211(c)] 25 

c. NESHAP for Hazardous Waste Combustors [40 CF R 63.1206(c)(2) and 

63.6(e)(3)] 25 

d. NESHAP for Hazardous Waste Combustors [40 CF R 63.1206(c)(3) and 35 

IAC 201.149] 25 

e. NESHAP for Hazardous Waste Combustors [40 CF R 63.1206(c)(4)] 26 

f. NESHAP for Hazardous Waste Combustors [40 CF R 63.1206(c)(5)] 26 

g. NESHAP for Hazardous Waste Combustors [40 CF R 63.1206(c)(6)] 26 

h. NESHAP for Hazardous Waste Combustors [40 CF R 63.1206(c)(7) and 

63.6((e)] 27 

2. Work Practice Requirements 27 

ii 
D. Incinerators: Unit 2, Unit 3, and Unit 4 Monitoring Requirements 28 

1. Continuous emissions monitoring systems (CEMS) and continuous opacity 

monitoring systems (COMS) [40 CF R 63.1209(a)] 28 

a. NESHAP for Hazardous Waste Combustors [40 CF R 63.1209(a)(l)(i)] 28 

b. NESHAP for Hazardous Waste Combustors [40 CF R 63.1209(a)(l)(iii)] 28 

c. NESHAP for Hazardous Waste Combustors [40 CF R 63.1209(a)(2)] 28 

d. NESHAP for Hazardous Waste Combustors [40 CFR 63.1209(a)(5) and 

63.8(f)] 28 

e. NESHAP for Hazardous Waste Combustors [40 CF R 63.1209(a)(6)] 28 

2. Other continuous monitoring systems (CMS) [40 CF R 63.1209(b)] 29 

a. NESHAP for Hazardous Waste Combustors [40 CF R 63.1209(b)(1) and (2)] 29 

b. NESHAP for Hazardous Waste Combustors [40 CF R 63.1209(b)(3)] 29 

c. NESHAP for Hazardous Waste Combustors [40 CFR 63.1209(b)(4)] 29 

d. NESHAP for Hazardous Waste Combustors [40 CF R 63.1209(b)(5)] 29 

3. Bag leak detection systems (CMS) [40 CFR 63.1206(c)(8)] 29 

4. Feedstream Analysis [40 CF R 63.1209(c)] 30 

5. Performance Evaluations [40 CF R 63.1209(d), 63.8(d) and 63.8(e)] 30 

6. Conduct of Monitoring [40 CFR 63.1209(e) and 63.8(b)] 30 

7. Operation and Maintenance of Continuous Monitoring Systems [40 CFR 

63.1209(f) and 63.8(c)] 31 

8. Reduction of Monitoring Data [40 CFR 63.1209(h) and 63.8(g)] 31 

9. Operating Parameters for Multiple Standards [40 CF R 63.1209(i) through 

(P)] 31 

10. Operating Parameter Limit Averaging Periods [40 CF R 63.1209(r)] 31 

E. Incinerators: Unit 2, Unit 3, and Unit 4 Performance Testing Requirements 31 

1. Changes to the Source [40 CF R 63.1206(b)(5)(i)(B)] 31 

2. Compliance with C O and TH C Emission Standard [40 CF R 63.1206(b)(6)] 32 

3. Types of Performance Tests [40 CF R 63.1207(b)] 32 

4. Frequency of Performance Tests [40 CF R 63.1207(d)] 32 

5. Content of Performance Test Plans [40 CFR 63.1207(f)] 33 

a. NESHAP for Hazardous Waste Combustors [40 CF R 63.1207(f)(1)] 33 

b. NESHAP for Hazardous Waste Combustors [40 CF R 63.1207(f)(2)] 35 

6. Operating Conditions During Performance Tests [40 CF R 63.1207(g)] 36 

a. NESHAP for Hazardous Waste Combustors [40 CFR 63.1207(g)(a)] 36 

b. NESHAP for Hazardous Waste Combustors [40 CF R 63.1207(g)(b)] 37 

7. Operating Conditions During Subsequent Performance Tests [40 CF R 

63.1207(h)] 38 

8. Test Methods [40 CF R 63.1208] 38 

9. Failure of Performance Test [40 CF R 63.1207(1)] 38 

a. NESHAP for Hazardous Waste Combustors [40 CF R 63.1207(1)(1)] 38 

b. NESHAP for Hazardous Waste Combustors [40 CF R 63.1207(1)(2)] 39 

c. NESHAP for Hazardous Waste Combustors [40 CF R 63.1207(f)(2)] 39 

F. Incinerators: Unit 2, Unit 3, and Unit 4 Recordkeeping and Reporting 39 

1. Summary of Notification Requirements [40 CFR 63.1210(a)] 39 

2. Summary of Reporting Requirements [40 CF R 63.1211(a)] 42 

3. Summary of Recordkeeping Requirements [40 CFR 63.1211(b)] 42 

i ii 
G. Waste Processing Unit Requirements (MP-1, MP-2 and LPR) 43 

1. Visible Emissions Limitations [35 IAC 212.123] 43 

2. Use of Organic Material [35 IAC 219.301] 44 

3. NESHAP for Off-site Waste and Recovery Operations [40 CF R 63 Subpart 

DD] 44 

4. NESHAP for Containers [40 CF R 63.922] 44 

5. NESHAP for Containers [40 CF R 63.925 and 40 CFR 71.6(a)(3)(i)(A)] 45 

6. NESHAP for Containers [40 CFR 71.6(a)(3)] 45 

7. NESHAP for Benzene Waste Operations [40 CFR 61 Subpart FF] 45 

8. Emission Calculation Requirements [40 CF R 71.6(a)(3)(i)(B)] 45 

H. Liquid Waste Storage Tank Requirements 45 

1. Use of Organic Material [35 IAC 219.301] 46 

2. Organic Material Emission from Pumps and Compressors [35 IAC 219.142] 46 

3. Standards of Performance for Volatile Organic Liquid Storage Vessels 

(Including Petroleum Liquid Storage Vessels) for Which Construction, 

Reconstruction, or Modification Commenced After July 23, 1984 [40 CFR 60 

Subpart Kb] 46 

4. Storage Tanks [35 IAC 219.122 and 129] 46 

5. NESHAP for Benzene Waste Operations [40 CFR 61 Subpart FF] 46 

6. NESHAP for Off-site Waste and Recovery Operations [40 CF R 63 Subpart 

DD] 46 

7. Monitoring and Testing [40 CFR 71.6(a)(3)(i)(A) and (B)] 47 

8. Recordkeeping [40 CF R 71.6(a)(3)] 47 

9. Organic Material Emissions [CP #88030001, Condition 3] 47 

I. Bulk Solid Waste Storage Facility Requirements 47 

1. Particulate Emission from Process Units for Which Construction or 

Modification Commenced On or After April 14,1972 [35 IAC 212.321] 47 

2. Use of Organic Material [35 IAC 219.301] 48 

3. Visible Emissions Limitations [35 IAC 212.123] 48 

4. NESHAP for Benzene Waste Operations [40 CFR 61 Subpart FF] 48 

5. NESHAP for Off-site Waste and Recovery Operations [40 CF R 63 Subpart 

DD] 48 

6. Work Practice and Operational Requirements [40 CFR 71.6(a)(1)] 48 

7. Monitoring and Testing [40 CFR 71.6(a)(3)(i)(A) and (B)] 49 

8. Recordkeeping and Reporting [40 CFR 71.6(a)(3)] 49 

J. Drum Crusher Requirements 50 

1. Use of Organic Material [35 IAC 219.301] 50 

2. Particulate Matter Limitation [35 IAC 219.321] 50 

3. Visible Emissions Limitations [35 IAC 212.123] 50 

4. Monitoring and Testing [40 CFR 71.6(a)(3)(i)(A) and (B)] 50 

5. Recordkeeping and Reporting [40 CFR 71.6(a)(3)] 51 

K. Boiler Requirements 51 

1. Fuel Combustion Emission Sources (> 10 MMBtu/hr) [35 IAC 216.121] 51 

2. Standards of Performance for Small Industrial-Commercial-Institutional 

Steam Generating Units [40 CFR 60 Subpart Dc] 51 

3. Visible Emissions Limitations [35 IAC 212.123] 51 

iv 
4. Emission and Operational Limitations [CP# 95080025] 52 

5. Emission Limitations [40 CF R 63.52] 52 

6. NESHAP Major Sources: Industrial, Commercial and Institutional Boilers 

and Process Heaters [40 CF R 63 Subpart DDDDD] 52 

7. Monitoring and Testing [40 CF R 71.6(a)(3)(i)(A) and (B)] 52 

8. Recordkeeping and Reporting [40 CF R 71.6(a)(3)] 53 

L. Emergency Generator Requirements 53 

1. NESHAP for Stationary Reciprocating Internal Combustion Engines [40 

C F R 63 Subpart ZZZZ] 53 

2. Work Practice Standards [40 CF R 63.6602)] 54 

3. Recordkeeping and Reporting [40 CF R 63.6655] 55 

M . Gasoline Storage Tanks 55 

1. Storage of Gasoline [35 IAC 219.122] 55 

2. Gasoline Dispensing Operations [35 IAC 219.583] 55 

3. Recordkeeping and Reporting [40 CF R 71.6(a)(3)] 55 

V. AIR EMISSIONS INFORMATION 56 

A. Insignificant Air Emission Sources 56 

B. List of Air Emission Sources with Regulatory Requirements 57 

C. Emission Calculations 58 

1. Unit 2 Incineration 58 

2. Unit 3 Incineration 59 

3. Unit 4 Incineration 59 

4. Existing Boiler 60 

5. Lab Pack Repack Building (LPR) 61 

6. Material Processing Area 1 (MP-1) 61 

7. Material Processing Area 2 (MP-2) 62 

8. Bulk Solids Storage 62 

9. Drum Crusher 62 

10. Tanks 65 

VI. COMPLIANC E METHODS 66 

A. Continuous Emission Monitors 66( 

B. Process Parameter Monitoring 67 

C. Demonstration of Compliance with Applicable Requirements 68 

VII. RECORDKEEPING AND REPORTING 74 

A. Recordkeeping 74 

B. Reporting Requirements 78 

APPENDICES 

APPENDIX A FORMS 

APPENDIX B NON-APPLICABILE REGULATIONS 

APPENDIX C FIGURES 

APPENDIX D CEMS AND CMS QUALIT Y ASSURANCE PLANS 

APPENDIX E MOST RECEN T NOC 

APPENDIX F CONSTRUCTION PERMITS 

APPENDIX G STARTUP, SHUTDOWN, AND MALFUNCTION PLA N 

v 
APPENDIX H AUTOMATI C WASTE FEE D CUTOF F PLA N 

APPENDIX I ESV OPERATING PLA N 

APPENDIX J FEEDSTREA M ANALYSIS PLA N 

APPENDIX K TITLE V ITEMS TO BE REMOVE D 

v i 
TITLE V PERMIT APPLICATION FOR RENEWAL 

ADDENDUM TO RENEWAL APPLICATION 

I. COMPLIANCE CERTIFICATION 

In accordance with 40 CFR 71.5(c)(9), the following certification for this application 

document is provided. 

I certify under penalty of law that, based on information and belief formed after reasonable 

inquiry, the statements and information contained in this application are true, accurate, and 

complete. 

Authorized Signature: 

General Manager 

Responsible Official Title 

Donglas Harris % / / 

Typed or Printed Name of Signatory Date 

A compliance certification will be submitted annually to the appropriate agencies. In 

addition, a description of all monitoring, recordkeeping, and reporting requirements and the 

methods used to demonstrate compliance is included in subsequent sections of this 

document. The facility and all emission units are in compliance with the enhanced 

monitoring and compliance certification requirements of the Clean Air Act. 

1 
II. INTRODUCTION 

Veolia ES Technical Solutions, L.L.C . (Veolia) is submitting this addendum to the Title V 

permit renewal application, submitted to USEP A April 9, 2013, in accordance with the 

federal operating permits program in 40 CFR Part 71. The application and the addendum are 

for renewal of Veolia's Title V Permit to Operate No . V-IL-12716300103-08-01, which 

expires October 12, 2013. The permit is for the operation of Veolia's hazardous waste 

storage and treatment facility in Sauget, Illinois. USEP A Part 71 application forms are 

provided in Section I X of this document. The additional narrative that follows is also 

included to supplement the information on the forms and to present relevant information 

about the facility and its operations. 

2 
III. FACILITY DESCRIPTION 

Veolia ES Technical Solutions, L.L.C. (Veolia) operates a commercial hazardous waste 

facility in Sauget, Illinois. The facility receives a variety of liquid, solid, and gaseous waste 

for treatment in incineration systems. The facility includes waste receiving areas; waste 

staging and storage for small and large containers, drums, bulk solids, tank trucks, and 

cylinders; three incinerators and their associated equipment; a laboratory; and other site 

infrastructure and facilities necessary to support the operations. Figures l a - Id provide 

facility site layout information. (Figures are provided in Appendix C.) 

A. Air Permit History 

Veolia has received the construction permits from the Illinois Environmental Protection 

Agency (IEPA) listed below for the emission units at the Sauget facility. A previously 

permitted emission unit, incineration Unit 1, covered under permit #83080072 has been 

dismantled and removed from site. 

Unit 1 (removed from service) #83080072 

Shredder system #84060063 8/8/84 

Unit 2 & 3 Construction & 

Tank Farm #1 Permit #83120053 9/2/86 and revisions 

Pneumatic Conveyor #87110052 2/11/88 

Residue Feed System for Unit 1 #87120069 4/13/88 

Unit 3 Construction Permit #87100024 8/19/88 and revisions 

Unit 4 Construction Permit #88010001 8/3/88 and revisions 

Tank Farm #3 Permit #88030001 6/27/88 

Specialty Feeder for Unit 3 #93030107 6/7/93 

Cleaver Brooks Boiler 1 #95080025 

Activated Carbon Injection Unit 4 #00110030 

Copies of the construction permits for the active emission units are provided in Appendix F. 

B. Process Information 

Liquid wastes are received at the facility in tank trucks and drums. Gaseous (and some 

liquid) wastes arrive in various sized cylinders. Bulk solids are received at the site primarily 

in 20- to 40-yard roll-off containers or other similar bulk transport vehicles. Solid wastes are 

also received in containers such as drums, totes, and Gaylord boxes. Wastes are stored prior 

to incineration and either fed directly to an incinerator, repackaged into smaller charge 

containers for incineration, or sent off-site for treatment at other locations. 

Fixed-hearth incinerators Unit 2 and Unit 3 are designed to receive containerized wastes, 

aqueous liquid wastes, organic liquid wastes, specialty liquid wastes, and sludge wastes. The 

aqueous and organic liquid wastes are fed through air-atomizing nozzles. The specialty liquid 

feeds and direct-inject liquids are fed through the aqueous or organic liquid feed systems. Each 

incinerator can receive any combination of liquid, semi-solid, or solid wastes. Unit 2 can also 

3 
receive waste gases through separate feed nozzles. The rotary kiln incinerator Unit 4 can 

incinerate container, aqueous liquid, organic liquid, specialty liquid, and sludge wastes. Liquid 

wastes are fed into either the kiln or Secondary Combustion Chamber (SCC). Bulk solid wastes 

are fed into the kiln through either the ram feeder or the screw auger. Containerized wastes are 

fed into the kiln through the ram feeder or the auxiliary ram feeder. Unit 4 can also accept 

liquid wastes injected directly from the delivery vehicle. 

The incinerators produce ash, which enters the As h Handling System. As h from Units 2 and 

3 is staged in roll-off containers temporarily at the As h Storage Building. From here it is 

transported to the Bulk Feed Building. As h from Unit 4 is collected in roll-off containers and 

transported to Storage Building #7. Emissions of particulate matter are minimized through 

work practices such as wet handling, covering with a tarp, and handling inside enclosed 

structures. The sections below provide detailed information for the processing operations at 

the facility. 

1. Storage Units 

Upon arrival, wastes are sampled according to the facility's Waste Analysis Plan and 

Feed Stream Analysis Plan and analyzed at Veolia's on-site laboratory. Bulk liquid 

wastes may be transferred to Tank Farm #1 or Tank Farm #3 for bulk storage and 

blending or directly into Unit 2, 3, or 4 for incineration. Containerized liquid wastes 

(drums) may be transferred via drum pumps to Tank Farm #1 for bulk storage or directly 

into Unit 2 or 3 for incineration. 

a. Tanks 

Bulk liquids are stored at Tank Farm #1 and Tank Farm #3. Al l bulk liquid tanks are 

vertical, fixed-roof tanks equipped with carbon canisters for control of volatile 

organics. See Figures 2 and 3 for tank farm process flow diagrams. Figure 4 depicts 

a typical tank-to-carbon-canister flow diagram. (Figures are provided at the end of 

this section.) Tank Farm #1 includes ten bulk liquid waste tanks (2, 4, 6, 8, 10, 20, 

30, 40, 50, and 60) and supplies bulk liquid waste to Units 2 and 3. 

Tank Farm #3 includes eight bulk liquid waste tanks (300, 302, 304, 306, 308, 310, 

312, and 314) and supplies bulk liquid waste to Unit 4. Tank Farm #3 also includes a 

vertical, fixed-roof tank that stores No. 2 fuel oil (Tank 390). 

Other fuel tanks on site include a horizontal kerosene tank, two horizontal diesel fuel 

tanks, and a horizontal gasoline tank. These fuel tanks are used to supply fuel to onsite company vehicles and for fire suppression system pump. 

4 
Table 1. Waste Storage Tanks and Carbon Canisters 

Control -

Carbon 

Capacity Canister 

Location Number (gallons) Number 

Tank Farm #1 2 4,931 2 

Tank Farm #1 4 4,931 4 

Tank Farm #1 6 7,200 6 

Tank Farm #1 8 5,280 8 

Tank Farm #1 10 12,869 10 

Tank Farm #1 20 12,869 20 

Tank Farm #1 30 12,869 30 

Tank Farm #1 40 12,869 40 

Tank Farm #1 50 12,869 50 

Tank Farm #1 60 12,869 60 

Tank Farm #3 300 30,000 300 

Tank Farm #3 302 30,000 302 

Tank Farm #3 304 30,000 304 

Tank Farm #3 306 30,000 306 

Tank Farm #3 308 30,000 308 

Tank Farm #3 310 30,000 310 

Tank Farm #3 312 10,000 312 

Tank Farm #3 314 10,000 314 

Table 2. Other Storage Tanks 

Location Number 

Capacity 

(gallons) 

Material Stored 

Tank Farm #3 390 30,000 No. 2 Fuel Oil 

South of Parking Lot None 550 Kerosene 

South of Parking Lot None 550 No. 2 Fuel Oil 

South of Parking Lot None 550 Gasoline 

Fire Pump House None 550 No. 2 Fuel Oil 

b. Containers 

Solid wastes are also received in containers, including, but not limited to, drums, 

totes, cartons, boxes, or pails. Drums and other containers received on site, 

depending on compatibility, maybe stored in buildings 1A, IB, 1C, 2A, 2B, 2C, 3, 

3A, 3B, and 6. 

5 
2. Incineration Units 

Three separate incinerator systems consist of two fixed-hearth, dual-chambered units 

rated at 16 million Btu/hr each (Units 2 and 3). Units 2 and 3 are mirror images of each 

other. The only difference between the units is Unit 2 has four baghouse modules, while 

Unit 3 has three baghouse modules. The third incinerator (Unit 4) is a rotary kiln rated at 

50 million Btu/hr. Each unit includes its own feed, air pollution control, process 

instrumentation and controls, and continuous emission monitoring systems. 

a. Unit 2 and Unit 3 

Units 2 and 3 are fixed-hearth incinerators with a two-stage combustion process. See 

Figure 5 for the Units 2 and 3 process flow diagram. (Figures are at the end of this 

section.) Ignition of waste material takes place in the primary (lower) combustion 

chamber at temperatures in excess of 1,700 degrees F. A secondary (upper) 

combustion chamber serves as an "after-burner" for process gases. The secondary 

combustion chamber temperature is maintained at a minimum temperature of 1,800 

degrees F. Wastes are not injected into the secondary combustion chamber. The 

thermocouple that monitors temperature in the lower combustion chamber is located 

on top of the chamber approximately 5 feet from the transition. The thermocouple 

that monitors temperature in the upper combustion chamber is located on top of the 

chamber above the transition. 

Each incinerator has two burners. The burner in the lower chamber is a North 

American burner rated at 12 million Btu/hr. This burner only burns natural gas and is 

used to maintain minimum chamber temperatures. Liquid or gaseous (Unit 2 only) 

wastes are injected through separate feed nozzles. The burner in the upper chamber is 

a North American burner rated at 6 million Btu/hr used to supply additional heat to 

the chamber when necessary. This burner only burns natural gas. 

The primary and secondary chambers of Units 2 and 3 each have an external diameter 

of 9 feet and are 17.5 feet long. The interior walls of both chambers are lined with 

approximately 10 inches of brick refractory and insulating backing. The internal 

operating diameter is 7 feet 2 inches. The cross-sectional area of the chambers is 40.3 

square feet. Combustion air is controlled separately in the upper and lower chambers. 

See Table 3 for a summary of Units 2 and 3 design specifications. 

Table 3. Units 2 and 3 Design Specifications 

Model TWI-2000, Series 2 

Manufacturer Trade Waste Incineration 

Type Fixed Hearth, Dual Chamber 

Feed Solids, Organic Liquids, Aqueous Liquids, Sludges, 

Gases (Unit 2 only) 

Heat Release Rating 16 M [MBtu/hr 

Primary Chamber Secondary Chamber 

External Length 17.5 ft 17.5 ft 

6 
Table 3. Units 2 and 3 Design Specifications 

External Diameter 9 ft 9 ft 

Internal Diameter 7 ft 2 in 7 ft 2 in 

Cross-sectional Area 40.3 sq ft 40.3 sq ft 

Burner Manf. North American North American 

Burner Size 12 MMBtu/h r 6 MMBtu/hr 

Burner Fuel Natural Gas Natural Gas 

Liquid Waste Injectors 0-425 gph 

Prime Mover Induced draft fan, 15,000 acfm @ 400°F, 22 inches 

water column 

After ignition of waste material under controlled conditions in the lower chamber, 

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. 

After passing through the upper chamber, the hot gas stream travels through 28 feet 

of refractory-lined stack sections before reaching the start of the gas scrubbing 

system. The combined volume of the upper and lower chambers, the flue gas 

passage, and the hot crossover section is approximately 1,567 cubic feet. The total 

retention time of combustion gases within the system is approximately 5 seconds. 

The incinerator is rated at 16 million Btu/hr and has a design unit heat release of 

approximately 10,000 Btu per cubic foot. Maximum gas volume when firing a heat 

release of 16 million Btu/hr is 15,000 acfm at 400 degrees F. 

b. Unit 4 

Bulk solid wastes are fed into the Unit 4 incinerator through either the ram feeder or a 

screw auger. Containerized wastes are fed into the kiln through the ram feeder or the 

auxiliary ram feeder. Unit 4 is supported by storage/blend tanks located i n Tank 

Farm #3. Rates of wastes fed from the tank farm are controlled at the incinerator. 

The material is transferred through above-ground pipelines from the tank farm to the 

Unit 4 system. 

Unit 4 incinerator has a two-stage combustion process consisting of a kiln and 

Secondary Combustion Chamber (SCC). See Figure 6 for the Unit 4 process flow 

diagram. (Figures are at the end of this section.) Ignition of waste material takes 

place in the primary kiln at temperatures in excess of 1,500 degrees F. The SCC 

temperature is maintained above 1,880 degrees F. High Btu liquid wastes can be 

injected directly into the SCC. The pyrometer that monitors temperature in the rotary 

kiln is located top-center in the transition section between the rotary kiln and the 

SCC, approximately 2 feet downstream from the exit of the kiln. The thermocouple 

that monitors temperature in the SCC is located on the west side of the chamber near 

the SCC exit duct. 

7 
The rotary kiln is fabricated of carbon steel. It has approximate dimensions of 8 feet 

8 inches outside diameter by 35 feet long. It is supported on a one-degree slope by 

two steel tires or riding rings. Each riding ring rides on two pairs of steel trunnions 

and has an approximate outside diameter of 9 feet 5 inches. The thickness and face 

width of the trunnions are approximately 6 inches and 9 inches, respectively. The 

kiln is lined with approximately 7.5 inches of dense, abrasion-resistant, high-alumina 

firebrick refractory. With this refractory system, the kiln has an inside diameter of 

approximately 7 feet, a length of approximately 35 feet, an integral cross-section area 

of approximately 38 square feet, and an internal volume of approximately 1,346 cubic 

feet. 

A ll kil n feeds enter through the upper kiln face plate located on the feed end of the 

kiln. The plate contains a primary burner, three liquid feed nozzles (for direct 

injection of liquid waste, aqueous waste, and high Btu liquid waste), an air turbulence 

nozzle, a ram feeder, and a surge vent. 

The primary burner is equivalent to a North American 'Fuel Directed' burner of 25 

MMBtu/h r and burns natural gas. The burner system is supplied with approximately 

4,000 acfm combustion air at a static pressure of 20 inches water column. The pilot 

for the primary burner burns natural gas. The fuel system for the kiln and SCC is 

controlled by a Factory Mutual approved burner management system complete with 

interlocks and safety valves. 

The SCC is a vertical, cylindrical chamber having approximate dimensions of 10 feet 

6 inches outside diameter by 71 feet high. It is fabricated of carbon steel and lined 

with an inner course (hot face) of approximately 6 inches of high-alumina refractory 

and an outer course of approximately 2 inches of insulating refractory. With this 

installed refractory, the SCC has an inside diameter of approximately 9 feet. The 

effective length (gas retention length) of the chamber is approximately 48 feet 6 

inches. Consequently, the SCC has a cross-section area of 64 square feet and an 

effective volume of approximately 3,084 cubic feet. At maximum combustion gas 

flows, the combustion gas residence time is greater than 2 seconds. High Btu liquids 

can be fed directly into the SCC. 

Combustion gases from the kiln enter the bottom of the SCC through a refractorylined side duct and exit from the top of the SCC through a refractory-lined duct to the 

tempering chamber. The floor of the chamber is sloped to facilitate the removal of 

ash and solids through a slag tap. The SCC is equipped with one burner mounted on 

the sidewall of the chamber near the bottom. The burner is a Trane Thermal Model 

or equivalent, with a design heat release of approximately 30 million Btu/hr. This 

burner is supplied with natural gas and combustion air. As with the kiln burner, the 

S CC burner is supplied with atomizing air and is equipped with a burner management 

system. This system controls the ignition and initiates an automatic shutoff when 

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

pilot burner, or induced-draft fan. 

8 
The SCC burner is a high-intensity, vortex type unit with a spin vane assembly, 

located within the windbox to impart an intense rotary motion to the combustion air. 

This rotary motion and the burner design provide complete mixing of air and fuel, 

and recirculation of the gases within the combustion chamber promotes rapid 

combustion and high heat intensity. See Table 4 for a summary of Unit 4 design 

specifications. 

Table 4. Unit 4 Design Specifications 

Model PY*RO X 

Manufacturer International Waste Energy Systems 

Type Transportable Rotary Kil n 

Feed Solids, Organic Liquids, Aqueous Liquids, Sludges 

Heat Rating 50 MMBtu/h r 

Kil n Secondary Chamber 

External Length 35 ft 71 ft 

External Diameter 8 ft 10.5 ft 

Internal Diameter 7 ft 9 ft 

Burner Mfg . North American T-Thermal 

Burner Size 25 MMBtu/hr 25 MMBtu/h r 

Burner Fuel Natural Gas Natural Gas 

Liquid Waste 

Injectors 

0-750 gph 

Prime Mover Induced draft fan, 53,000 acfm 

c. Air Pollution Control Devices - Unit 2 and Unit 3 

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

baghouse. The air pollution control system neutralizes acidic compounds and 

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

and the fabric filter, carry out the chemical neutralization and particulate removal 

functions, respectively. A third subsystem, the lime system, is used to prepare and 

provide lime slurry to the spray dryer absorber for use in the chemical neutralization 

process. The induced draft fan and stack provide the mechanical energy required to 

transport the flue gas through the interconnecting ductwork to its eventual discharge 

point to atmosphere. 

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. 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 

9 
of the material from the bin is aided by a vibrating "live bottom" or bin activator. 

A variable speed rotary 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 rotary feeder speed and the rate that 

water is added to the lime slurry tank are variable so that the desired 20% 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. A n 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. 

Spray Dryer Absorber 

Slurry flow to the spray dryer absorber 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 (HC1) analyzer in the gas duct downstream of the fabric 

filter. The amount of slurry metered is proportional to the amount of HC1 

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. A feedback signal from the atomizer power transmitter 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 occur. The spray dryer absorber features a two-point product 

discharge. A portion of the dried spent chemicals and ash settle to the bottom of 

the chamber. This material is discharged at the base of the powder discharge 

cone. It then passes through a lump breaker that reduces large agglomerations of 

material to a manageable size. Finally, it is discharged through a rotary valve to 

the conveying system. The remainder of the spent chemicals is carried from the 

module entrained in the flue gas. 

Fabric Filter 

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

four fabric filter modules at Unit 2 and three fabric filter modules at Unit 3. 

Within each filter module, the gas is passed through Teflon-coated fiberglass 

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

Particulate, entrained in the gas stream, is mechanically deposited on the outside 

of the filter bags as the gas passes through the cloth. 

10 
The fabric filter cleaning mechanism utilizes jets of air to clean the filter bags. 

Periodically, the cleaning sequence will be initiated. The sequence is either 

started at the end of a timed cycle or when the differential pressure across the 

filter reaches a predetermined setpoint of approximately 7.0" w.c. The controller 

then sequences to each row o f 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 

bag. Released from the bag, the dust cake falls by gravity into the hopper at the 

bottom of the module. The dust cleaned from the filter bags is removed at the 

base of the hopper through a rotary valve for discharge to the conveying system. 

Treated by the spray dryer absorber and filtered by the fabric filter, the cleaned 

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

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 fan, 

rated at 15,000 acfm at 400 degres 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 velocity of the gas within the ducting and treatment devices is regulated by 

the damper associated with the fan. Treated gases are exhausted from the induced 

draft fan to the atmosphere through a 90-foot high stack. The stack diameter for 

Units 2 and 3 are both 39 inches inside diameter. Each stack is equipped with 

instrument sampling ports and a sampling platform for emissions testing. 

d. Air Pollution Control Devices - Unit 4 

a. Tempering Chamber 

The tempering chamber is a vertical, cylindrical unit designed to cool the 

combustion gases using a series of internal dual-fluid (water and air) spray 

nozzles. The combustion gases enter the top of the chamber, flow downward 

through the spray pattern and exit from the bottom of the chamber. The spray 

pattern is designed to eliminate direct contact of water with refractory, and the 

chamber is designed to maintain a dry bottom under all operating conditions. 

That is, the injection rate of spray water is controlled, so that it is completely 

vaporized and carried out of the chamber in the combustion gases. The tempering 

chamber is approximately 49 feet high with an 11-foot inside diameter, is 

fabricated of

 lA inch nominal plate thickness carbon steel (AST M A36), and is 

lined with refractory. The spray nozzles and extensions are fabricated of 304 SS 

material. 

The tempering chamber is sized so that a combustion gas retention time of greater 

than one second will be maintained at all gas flows. Because some molten 

11 
particulate materials in the combustion gases are cooled in this process unit to 

below their fusion point, some solids are generated and collected in the chamber. 

Therefore, the chamber has a cone bottom and double valves to facilitate the 

removal of solids. These solids are discharged onto a conveyor system that 

transports them to a hopper. 

Spray Dryer Absorber 

Unit 4 is equipped with two Spray Dryer Absorbers (SDA) located immediately 

downstream of the Tempering Chamber. Each SD A unit is fabricated of 3/8 inch 

carbon steel. The SDAs operate in parallel to: 

• Further cool the combustion gases from 600-800 degrees F to 300-500 

degrees F; 

• Neutralize and remove HC1 and other acids from the combustion gases; 

and, 

• Remove a portion of the particulate (flyash) from these gases. 

The combined units are sized to remove more than 820 lbs./hr. of chlorine from 

the combustion gases. Each SD A is approximately 72' high by 10'7" in diameter. 

Each unit includes a head section, and a 60° conical hopper. Each SD A chamber 

has one access door in the upper section. Each hopper has one access door, a 

flanged clean-out port, and a drain connection. The SD A head section consists of 

a flanged inlet connection and a hot gas inlet plenum. The dual-fluid atomizing 

nozzles include stainless steel housings and stellited inserts. The nozzles are 

assembled to permit field removal from the piping. The two lime slurry piping 

headers have automatic isolation valves. 

Combustion gases enter the top of each of these units, flow downward through a 

central duct, and are dispersed symmetrically from this duct into the absorber 

chamber at a velocity and direction that assures optimal contact with the cloud of 

atomized lime slurry droplets introduced into the chamber by dual-fluid (lime 

slurry and air) nozzles. The gases then flow downward through each absorber 

chamber and exit through a bottom side duct. As the gases contact and pass 

through the cloud of atomized lime slurry, the water in the slurry evaporates, 

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

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

consisting of calcium salts, flyash, and excess lime, falls to the conical bottom of 

each unit. The dry material from each unit is discharged to a conveyor system, 

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

Fabric Filter 

The fabric filter consists of two modules connected in parallel. Each module is 

divided into three compartments connected in parallel, which contain multiple 

fabric filter bags through which the combustion gases pass to remove particulates. 

12 
The modules provide an operating air-to-cloth ratio of approximately 4:1. The 

bags are periodically cleaned via a pulse air jet, which causes the particulate 

matter to fall to the bottom hoppers of each module. From there it is discharged 

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

system. 

Each fabric filter consists of a trailer-mounted unit subdivided into three 

compartments. Each compartment has a clean air plenum and housing section to 

contain approximately 308 bags. Each bag is approximately 5 inches in diameter 

by 5 feet long. The baghouses are fabricated from 3/16-inch 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 bolted 

access door. Each trailer-mounted unit contains the compressed air headers, gas 

inlet and outlet manifolds, and the conveyor. 

The fabric filter is equipped with a high-efficiency, pulse-jet cleaning system. 

The cleaning system uses low pressure, approximately 40-80 psig, and 

compressed dry air to dislodge the accumulated particulates from the bags. A 

solid state programmable controller accomplishes the control of the air flow. The 

filter units are designed to minimize filter bag wear by cleaning on demand, yet 

maintaining the desired pressure drop across the fabric filter. Alternately, at the 

option of the operator, the units can be cleaned on a timed cycle, in a manual 

mode or on the basis of high pressure drop. The pressure drop set point is 

adjustable, but normally is less than 8" w.c. The bags are designed for 25" w.c. 

vacuum, which is greater than the maximum negative pressure the induced draft 

fan can develop. The design allows the bags to be cleaned when the fabric filter 

is in operation. For a six-compartment unit, one-sixth of the total bags, or onethird of a module, can be isolated. The remaining five-sixths of the fabric filter 

capacity is more than adequate to accommodate the process requirements. The 

filter medium is a 22 oz/sq yd., woven fiberglass material, with an acid-resistant 

finish. Bags include snap rings for easy and dust-tight installation. The bags are 

held in place by bag cages constructed of galvanized steel wire. 

Carbon Injection and Lime Recirculation System 

The carbon injection system air-injects activated carbon into the plenum 

immediately upstream of the baghouses and allows for a more efficient means of 

controlling dioxin/furan and mercury emissions. To compliment this system and 

to incorporate waste minimization, the facility is permitted to pull a slip stream of 

the partially reacted lime from the exit of the baghouse solids discharge system 

and recirculate/recycle this back to the Spray Dryer Absorbers (SDAs) to further 

aid in HC1 removal and dioxin/furan removal. The carbon injection system is 

controlled by a PLC , which will control the input of activated carbon to the 

baghouse inlet plenum to allow from 2 to 20 pounds per hour of powdered 

13 
activated carbon to be air injected into this plenum and allow for direct contact 

with the stack gases exiting the SDAs. 

The amount of carbon is dosed in a dust-free manner into a low-pressure air 

stream via pneumatic eduction. The eductor uses a blower for the motive air. 

The carbon/air stream travels through piping to the injection nozzle into the 

ductwork. The carbon contacts the gas stream exiting the SDAs and allows for 

the adsorption of any dioxin/furans and mercury that might be present in this 

stream. Adsorption continues as the stack gases proceed through the baghouses. 

The clean stack gas exits the final stack via the induced draft fan, and the captured 

solids are discharged from the baghouses via the screw conveying system into an 

enclosed dump trailer for disposal at a Subtitle C landfill. 

In addition to this system, the facility is permitted for a lime recirculation system 

that directs a portion of the spent lime and carbon stream back into the SDAs. 

This recirculation system serves two purposes. The main objective is to further 

aid in the neutralization of HC1 and the adsorption of dioxin/furan and mercury in 

the SDAs. The second objective is to minimize the hazardous waste that will be 

generated requiring disposal at a Subtitle C landfill by recycling a portion of the 

partially reacted lime. 

The spent lime and carbon stream exiting the baghouses will contain up to 50% 

unreacted lime and a portion of unadsorbed activated carbon. A slip stream of 

this residual will be taken out of each baghouse system and directed back to each 

SDA . Since the SDAs and baghouses are in parallel, the North baghouse residual 

stream will be directed to the North SD A and the South baghouse residual stream 

will be directed to the South SDA. The residual will be blown into the SDAs via 

an injection nozzle that will be located approximately 20 feet down from the gas 

inlet duct of each vessel. This stream will add more neutralizing and adsorbing 

surface area and further aid in the removal efficiency of this vessel. The 

unreacted lime portion of this stream will aid in neutralization of HC1, and the 

increased surface area of the total residual stream will aid in the adsorption of any 

dioxin/furan compounds present in the off-gases. The basis is providing more 

surface area in the gas cleaning train to which the dioxin/furan compounds can 

adhere, thus reducing the stack emissions of these compounds. This closedlooped system will provide a constant cycle of adding and removing spent lime 

via the recirculation system, so, theoretically, the composition of the recirculation 

feed stock should remain fairly constant. 

Induced Draft Fan and Stack 

The induced draft fan draws combustion gases through the system and discharges 

them through the stack. It has a carbon steel centrifugal design sized to develop a 

pressure of approximately 25" wc at a maximum gas flow of approximately 

53,000 acfm at 400 degrees F. The induced draft fan was sized to maintain a 

14 
negative pressure of V%" w.c. i n the kiln and greater negative pressures throughout 

the remainder of the system, thereby, preventing fugitive emissions. 

The induced draft fan includes an inlet volume control damper to be used to 

control the pressure of the kiln. The stack diameter for Unit 4 is 48 inches inside 

diameter and is 100 feet high. Unit 4's stack is equipped with instrument 

sampling ports and a sampling platform for emissions testing. Figure 5-2 

provides details on the design and sample port locations and configurations for the 

stack. 

3. Other Treatment Units 

a. Material Processing Areas 

Material processing involves repackaging of containerized solid wastes into smaller, 

more manageable containers for incineration. Some solid wastes may be received 

containing free liquids that may be aqueous or organic. During material processing, 

free liquids are fixed with an inert absorbent to facilitate repackaging. Material 

processing occurs at MP-1 , MP-2 , and the Lab Pack Repack Facility i n Building 2B. 

See Figure 7 for the Material Processing flow diagram. (Figures are at the end of this 

section.) 

Table 5. Material Processing Areas 

Activity Location 

Material Processing 1 MP-1 

Material Processing 2 MP- 2 

Lab Pack Repack Building 2B 

These operations emit fugitive emissions in an enclosed building. Volatile organic 

material (VOM) is emitted to the atmosphere through building/area exhaust fans. 

b. Bulk Feed Building 

Bulk solid wastes are stored in four pits in the Bulk Feed Building. Solids stored in 

these pits are incinerated i n Unit 4. A carbon adsorption system controls volatile 

emissions. The building is equipped with a cyclone and two baghouses to control 

particulate emissions. Bulk solid wastes are moved from the pits to Unit 4 by a 

clamshell through an enclosed gallery. See Figure 8 for the Bulk Feed Building 

process flow diagram. (Figures are at the end of this section.) 

c. Glove Box Building 

Wastes may also be processed in the Glove Box Building, which is located near Unit 

3 and contains two separate glove box units. Materials received in drums, lab packs, 

cylinders, or small containers that are reactive or odiferous are opened in order to be 

repacked and re-closed inside one of the two glove boxes. Only one glove box is in 

15 
use at a time, depending on the size of the container to be processed. A flexible 

connection duct is connected to the glove box in operation. This duct vents all 

emissions from the material in the glove box directly to incinerator Unit 3. The draft 

of the system induced draft fan provides negative pressure of evacuation of the glove 

box in use. When handling open containers in the glove box, all equipment is used by 

the operator from outside the glove box by either automation or gloves attached to the 

glove box. 

d. Drum Crusher 

Drums received that are unsuitable for reuse are crushed at the Drum Crusher after 

being emptied. These empty drums may contain residual organic material. Crushed 

drums are transported off-site for disposal. Fugitive emissions of VO M are emitted to 

the atmosphere. See Figure 9 for the Drum Crusher process flow diagram. (Figures 

are at the end of this section.) 

4. Ancillary Processes 

There is one 10.6 MMBtu/hr natural gas boiler located north of Tank Farm #1. Another 

12.55 MMBtu/hr natural gas boiler is proposed. These boilers are used to generate heat 

and steam for on-site uses. See Figure 10 for the boiler process flow diagram. (Figures 

are at the end of this section.) There is also a portable 2.5 MMBtu/hr boiler and two 

emergency generators, each rated at less than 112 kW. There are no emission control 

devices associated with these units. 

C. General Air Emission Information 

Emission units at the Veolia Sauget facility emit CO, NOx , SOx, particulate matter, semivolatile metals, low-volatile metals, lead, HAPs, and VOM . Control devices and standard 

work practices are used to control emissions to the atmosphere. 

The Veoli a Sauget facility is located in a nonattainment area for the 8-hour ozone and PM2.5 

national ambient air quality standards. The facility is a major source of HAPs, emitting 

greater than 10 tons per year of HCl . The facility's potential to emit is less than 100 tons per 

year for VO M and NOx, and less than 250 tons per year for all other regulated pollutants. 

16 
REGULATORY APPLICABILITY AND PERMIT CONDITIONS 

A. Facility-wide Requirements and Permit Shield Request [40 CF R 71.6(f)] 

The following requirements apply to the plant operations as a whole or to certain categories 

of equipment throughout the plant. A listing of any non-applicable requirements and the 

reasons for the non-applicability are provided in Appendix B. Veolia requests a permit 

shield such that compliance with the conditions of the issued Part 71 permit shall be deemed 

in compliance with the applicable and non-applicable requirements contained in the Title V 

renewal application and addendum. 

1. Fugitive Particulate Matter [35 IAC 212.301] 

No person shall cause or allow the emission of fugitive particulate matter from any 

process, including any material handling or storage activity that is visible by an observer 

looking generally toward the zenith at a point beyond the property line of the source. 

2. Open Burning Prohibitions [35 IAC 237.102] 

No person shall cause or allow open burning, except as provided by permit received in 

accordance with Section 237.201 of the regulations. In addition, no person shall cause or 

allow the burning of any refuse in any chamber or apparatus, unless such chamber or 

apparatus is designed for the purpose of disposing of the class of refuse being burned. 

Landscape waste may be exempted under certain conditions listed in 35 IA C 237.120 (c). 

3. Organic Emissions from Pumps and Compressors [35 IAC 219.142] 

No person shall cause or allow the discharge of more than 32.8 ml (2 cu in) of volatile 

organic liquid (VOL) with vapor pressure of greater than 2.5 psia at 70 degrees F into the 

atmosphere from any pump or compressor in any 15 minute period at standard 

conditions. 

4. NESHAP from Off-site Waste and Recovery Operations: Equipment Leaks [40 

C F R 63.691(b)(1); 40 CF R 61 Subpart V] 

The facility shall comply with the leak detection and repair standards contained in 40 

C FR 61.242-1 through 40 CF R 61.242-11 for pumps, compressors, pressure relief 

devices, sampling connection systems, open-ended valves or lines, valves, connectors, 

surge control vessels, bottoms receivers, and control devices or systems. 

5. Prevention of Significant Deterioration and Nonattainment New Source Review 

The facility is located in St. Clair County, a marginal non-attainment area for the 8-hr 

ozone and the PM-2.5 national ambient air quality standards (NAAQS). The area is 

designated attainment or unclassifiable for all other regulated pollutants. The facility is a 

major source of hazardous air pollutants with potential emissions as follows: 

17 
POLLUTAN T P TE 

(tons/yr) 

P M 1 0 12.55 

so2 66.19 

N Ox 74.11 

V O M (OZONE) 15.63 

C O 30.85 

LEA D 0.0968 

P M 13.93 

HAPS 21.41 

ARSENI C <0.10 

BENZEN E <0.40 

BERYLLIU M <0.05 

LEA D <0.10 

MERCUR Y 0.055 

The current facility's PTE is a summation of the potential to emit of each emission unit. 

B. Incinerators: Unit 2, Unit 3, and Unit 4 Emission Standard Requirements 

The regulations applicable to the incinerators are listed below. A listing of any nonapplicable requirements and the reasons for the non-applicability are provided in Appendix 

B. 

1. Visible Emissions 

a. Visible Emissions Limitations [35 IAC 212.123(a)] 

The emission of smoke or other particulate matter, with an opacity greater than 30 

percent, into the atmosphere from any emission source shall not be caused or allowed, 

except as allowed by 35 IA C 212.123(b) and 212.124. 

b. Fugitive Particulate Matter [35 IAC 212.301 and 212.314] 

The facility shall not cause or allow the emission of fugitive particulate matter from 

any process, including any material handling or storage activity, that is visible by an 

observer looking generally overhead at a point beyond the property line of the source 

unless the wind speed is greater than 40.2 kilometers per hour (25 miles per hour.) 

except as described in 35 IA C 212.314. 

18 
2. Sulfur Dioxide Emissions 

a. Sulfur Dioxide Annual Emission Limitation 

Total sulfur dioxide emissions from the facility shall not exceed 7.7 tons per year for 

units 2 and 3 and 50.76 tons per year for Unit 4. [Construction permits #87100024 

and #88010001] 

3. Carbon Monoxide Emissions 

a. NESHAP for Hazardous Waste Combustors [40 CFR 63.1219(a)(5)] 

Emissions of carbon monoxide shall be less than or equal to 100 parts per million by 

volume, over an hourly rolling average (monitored continuously with a continuous 

emissions monitoring system), dry basis and corrected to 7% oxygen. If the facility 

elects to comply with this carbon monoxide standard rather than the hydrocarbon 

standard under paragraph (a)(5)(ii) of this section, it must also document that, during 

the destruction and removal efficiency (DRE) test runs or their equivalent as provided 

by 40 CFR 63.1206(b)(7), hydrocarbons do not exceed 10 parts per million by 

volume during those runs, over an hourly rolling average (monitored continuously 

with a continuous emissions monitoring system), dry basis, corrected to 7% oxygen, 

and reported as propane. 

b. Carbon Monoxide Limitations for Incinerators [35 IAC 216.141] 

Carbon monoxide emissions from each incinerator shall not exceed 500 parts per 

million (ppm) corrected to 50% excess air. [Construction permits #83120053, 

#87100024 and #88010001] 

c. Carbon Monoxide Annual Emission Limitation 

Total carbon monoxide emissions from the facility shall not exceed 6.6 tons per year 

for Units 2 and 3 and 13.86 tons per year for Unit 4. [Construction permits 

#87100024 and #88010001] 

4. Particulate Matter Emissions 

a. Particulate Matter Limitations for Incinerators [35 IAC 212.181(b)] 

The emission of particulate matter into the atmosphere from any incinerator burning 

more than 0.907 megagram per hour (Mg/hr; 2,000 pound per hour (lb/hr)) but less 

than 27.2 Mg/hr (60,000 lb/hr) of refuse shall be limited to 183 milligrams per 

standard cubic meter (mg/scm; 0.08 grain per standard cubic foot (gr/scf)) of effluent 

gases corrected to 12% carbon dioxide. [Construction permit #83120053] 

19 
b. NESHAP for Hazardous Waste Combustors [40 CF R 63.1219(a)(7)] 

Emissions of particulate matter from the facility shall be limited to 0.013 grain per 

standard cubic foot (gr/scf), corrected to 7% oxygen. 

c. Particulate Matter Annual Emission Limitation 

Total suspended particulate matter emissions from the facility shall not exceed 15.0 

tons per year for Units 2 and 3 and 16.92 tons per year for Unit 4. [Construction 

permits #87100024 and #88010001] 

5. Volatile Organic Material Emissions 

a. Use of Organic Material [35 IAC 219.301 and 219.302] 

The facility shall not cause or allow the discharge of more than 3.6 kg/hr (8 lbs/hr) of 

organic material into the atmosphere from any emission unit, except that, if no odor 

nuisance exists, this limitation shall apply only to photochemically reactive material. 

Alternatively, the facility may use a control device to reduce such emissions either to 

10 ppm equivalent methane (molecular weight 16) or less, or to convert 85% of the 

hydrocarbons to carbon dioxide and water. 

b. Volatile Organic Material Annual Emission Limitation 

Volatile organic material emissions from the facility shall not exceed 0.9 tons per 

year for Units 2 and 3 and 3.1 tons per year for Unit 4. [Construction permits 

#87100024 and #88010001] 

6. Nitrogen Oxide Emissions 

a. Nitrogen Oxide Annual Emission Limitation 

Total nitrogen oxide emissions from the facility shall not exceed 4.0 tons per year for 

Units 2 and 3 and 61.6 tons per year for Unit 4. [Construction permits #87100024 and 

#88010001] 

7. Hazardous Air Pollutant Emissions 

a. NESHAP for Hazardous Waste Combustors - Dioxin and Furan Emission 

Limitations [40 CF R 63.1219(a)(1)] 

The emission rate of dioxin and furans from the facility shall not exceed 0.20 ng 

TEQ/dscm, corrected to 7% oxygen. 

20 
b. NESHAP for Hazardous Waste Combustors - Mercury Emission Limitations 

[40 CF R 63.1219(a)(2)] 

The emission rate of mercury from the facility shall not exceed 130 ug/dscm, 

corrected to 7% oxygen. 

c. NESHAP for Hazardous Waste Combustors - Semi-volatile Metal Emission 

Limitations [40 CF R 63.1219(a)(3)] 

The emission rate of cadmium and lead from the facility shall not exceed 230 

Lig/dscm, combined emissions, corrected to 7% oxygen. 

d. NESHAP for Hazardous Waste Combustors - Low Volatile Metal Emission 

Limitations [40 CFR 63.1219(a)(4)] 

The emission rate of arsenic, beryllium, and chromium from the facility shall not 

exceed 92 jag/dscm, combined emissions, corrected to 7% oxygen. 

e. NESHAP for Benzene Waste Operations [40 CFR 61.348(a)(l)(iii)] 

The combustion units shall be designed, installed, operated, and maintained such that 

benzene in the waste stream is destroyed by incinerating the waste. The combustion 

units must achieve a destruction efficiency of 99% or greater for benzene. 

f. NESHAP from Off-site Waste and Recovery Operations [40 CF R 

63.689(c)(2)] 

A l l joints or seams between the pipe sections of any transfer system that consists of 

continuous hardpiping shall be permanently or semi-permanently sealed (e.g., a 

welded joint between two sections of metal pipe or a bolted and gasketed flange). 

8. Hydrogen Chloride Emissions 

a. NESHAP for Hazardous Waste Combustors - Hydrogen Chloride Emission 

Limitations [40 CF R 63.1219(a)(6)] 

The hydrogen chloride and chlorine gas (total chlorine) emissions from the facility 

shall not exceed 32 ppm by volume, combined emissions, expressed as a chloride 

(Cl~) equivalent, dry basis and corrected to 7% oxygen. 

b. Hydrogen Chloride Emission Limitation 

Hydrogen chloride emissions from incinerators 2 and 3 in excess of 4.0 pounds per 

hour or the control devices shall demonstrate a minimum HC l removal efficiency of 

99%. [Construction permits 83120053 and 87100024] 

21 
9. Destruction and Removal Efficiency (DRE) Requirement 

a. NESHAP for Hazardous Waste Combustors - DRE Standard [40 CF R 

63.1219(c)(1)] 

Each HW C unit must achieve a 99.99% DRE. Except as provided in paragraph (c)(2) 

of this section, you must achieve a DR E of 99.99%> for each principle organic 

hazardous constituent (POHC) designated under paragraph (c)(3) of 40 CFR 63.1219. 

The DR E for each POH C will be calculated using the following equation: 

D R E = [1 - (Wout / )] x 100% 

Where: 

W i n

 = mass feedrate of one POH C in a waste feedstream; and 

W0 ut

 = mass emission rate of the same POH C present in exhaust emissions prior 

to release to the atmosphere. 

The emission limits in this rule are presented with two significant figures. The 

intermediate calculations must be performed using at least three significant figures; 

however, the resultant emission levels may be rounded to two significant figures to 

document compliance. 

b. NESHAP for Hazardous Waste Combustors - DRE Standard [40 CF R 

63.1219(c)(2)] 

If the facility burns the dioxin-listed hazardous wastes F020, F021, F022, F023, F026, 

or F027 (see § 261.31 of this chapter), it must achieve a DR E of 99.9999% for each 

POH C that it designates under 40 CFR 63.1219(c)(3). The facility must demonstrate 

this DR E performance on POHCs that are more difficult to incinerate than tetra-, 

penta-, and hexachlorodibenzo- p -dioxins and dibenzofurans. The equation in 40 

C FR 63.1219(c)(1) must be used to calculate DR E for each POHC. In addition, the 

facility must notify the Administrator of its intent to incinerate hazardous wastes 

F020, F021, F022, F023, F026, or F027. 

c. NESHAP for Hazardous Waste Combustors - DRE Standard [40 CF R 

63.1219(c)(3)] 

• Each POH C in the waste feed that the facility specifies under section 

63.1219(c)(3)(h) must be treated to the extent required by sections 

63.1219(c)(1) and (c)(2). 

• One or more POHCs that are representative of the most difficult to destroy 

organic compounds in the facility's hazardous waste feedstream must be 

specified. This specification must be based on the degree of difficulty of 

incineration of the organic constituents in the hazardous waste and on their 

22 
concentration or mass in the hazardous waste feed, considering the results of 

hazardous waste analyses or other data and information. 

• 

C. Incinerators: Unit 2, Unit 3, and Unit 4 Work Practice and Operational 

Requirements 

1. Operating Parameter Limits 

a. NESHAP for Hazardous Waste Combustors[40 CF R 63.1206(a), (b) and 

63.1209)0) through (p)] 

Units 2, 3, and 4 must be operated in accordance with the operating parameter limits 

(OPLs) specified in the most recent Notification of Compliance (NOC). The 

operating parameters are listed below. A copy of the most recent NO C with the 

current limits is provided in Appendix E. 

Operating Parameters Regulatory Citation 

Emission 

Standard 

Minimum primary combustion 

chamber temperature 

63.1209G)(l),(k)(2) DRE, Dioxin/Furan 

Minimum secondary combustion 

chamber temperature 

63.1209(j)(l),(k)(2) DRE, Dioxin/Furan 

Maximum flue gas flowrate or 

production rate 

63.1209(j)(2)), (k)(3), (m)(2), (n)(5), (o)(2) DRE, Dioxin/Furan, 

P M , SVM , LVM , 

HCL/C12 

Maximum hazardous waste 

pumpable feedrate for each feed 

location 

(63.1209©(3), (k)(4)) DRE, Dioxin/Furan 

Maximum hazardous waste total 

feedrate for each feed location 

(63.1209(j)(3),(k)(4)) DRE, Dioxin/Furan 

Operation of waste firing system 

for each location where waste is 

fed to the incinerator 

(63.1209(j)(4) D RE 

Maximum temperature of the gas 

at the inlet to dry control device 

(63.1209(k)(l)),(n)(l)) Dioxin/Furan, SVM , 

L V M 

Minimum carbon injection rate (63.1209(k)(6)(i)) Dioxin/Furan, Mercury 

Minimum carrier fluid (gas or 

liquid) flowrate or pressure drop 

(63.1209(k)(6)(ii)) Dioxin/Furan, Mercury 

The brand (i.e., manufacturer) 

and type of carbon used during 

the comprehensive performance 

test 

(63.1209(k)(6)(iii)) Dioxin/Furan, Mercury 

Maximum total feedrate of 

mercury 

(63.1209(l)(l)(i)) Mercury 

Maximum ash feedrate (63.1209(m)(3)) P M 

Maximum total feedrate of 

semivolatile metals 

(63.1209(n)(2)(ii)) S V M 

Maximum total feedrate of low 

volatile metals 

(63.1209(n)(2)(ii)) L V M 

Feedrate limits for low volatile 

metals in pumpable feedstreams 

(63.1209(n)(2)(vii)) L V M 

23 
Operating Parameters Regulatory Citation 

Emission 

Standard 

Feedrate of total chlorine and 

chloride in all feedstreams 

(63.1209(n)(4),(o)(l)) SVM , LVM , HCL/C12 

Minimum sorbent feedrate (63.1209 (o)(4)(i)) HCL/C12 

Minimum carrier fluid flowrate 

or nozzle pressure drop for the 

spray dry adsorber 

(63.1209(o)(4)(ii)) HCL/Clj 

The brand (i.e., manufacturer) 

and type of sorbent used during 

the comprehensive performance 

test 

(63.1209(o)(4)(iii)(A)) HCL/C12 

Maximum combustion chamber 

pressure 

(63.1209(p) Combustion System 

Leaks 

The emission standards and operating requirements 40 CFR 63 Subpart EE E apply at 

all times except: 

• During periods of startup, shutdown, and malfunction; 

• When hazardous waste is not i n the combustion chamber (i.e., the hazardous 

waste feed to the combustor has been cut off for a period of time not less than 

the hazardous waste residence time) and the facility has documented in the 

operating record compliance with all otherwise applicable requirements and 

standards promulgated under authority of sections 112 (e.g., 40 CFR. part 63, 

subparts LLL , DDDDD , and NNNNN ) or 129 of the Clean Air Ac t in lieu of 

the emission standards under 40 CFR 63.1203, 63.1204, 63.1205, 63.1215, 

63.1216, 63.1217, 63.1218, 63.1219, 63.1220, and 63.1221; the monitoring 

and compliance standards of 40 CF R 63.1206 through 63.1209, except the 

modes of operation requirements of 40 CFR 63.1209(q); and the notification, 

reporting, and recordkeeping requirements of 40 CF R 63.1210 through 

63.1212; 

• During performance tests under approved test plans according to 40 

C FR 63.1207(e), (f), and (g); and 

• If plans to change (as defined in 40 CFR 63.1206(b)(5)(iii)) the design, 

operation, or maintenance practices of the units in a manner that may 

adversely affect compliance with any emission standard that is not monitored 

with a CEM S are developed, then hazardous waste must not be burned for 

more than a total of 720 hours (renewable at the discretion of the 

Administrator) and only for the purposes of pretesting or comprehensive 

performance testing. Pretesting is defined at 40 CF R 63.1207(h)(2)(i) and (ii). 

However, the facility may petition the Administrator to obtain written 

approval to burn hazardous waste in the interim prior to submitting a 

Notification of Compliance for purposes other than testing or pretesting. 

Operating requirements must be specified, including limits on operating 

parameters that have been determined to ensure compliance with the emission 

standards of this permit based on available information. The Administrator 

will review, modify as necessary, and approve i f warranted the interim 

24 
operating requirements. A notification must be submitted to the 

Administrator at least 60 days prior to any change described above. 

b. NESHAP for Hazardous Waste Combustors [40 CF R 63.1206(c)(1) and 

63.1211(c)] 

The facility operating record must include a Documentation of Compliance (DOC) 

that identifies the applicable emission standards under this subpart and the limits on 

the operating parameters under 40 CF R 63.1209 that will ensure compliance with 

those emission standards. The DO C must be updated with any changes to the OPLs 

or affected sources and becomes the compliance document until the NO C is 

submitted. Veolia will operate in accordance with the DO C and/or the most current 

NOC . (Appendix E.) 

c. NESHAP for Hazardous Waste Combustors [40 CF R 63.1206(c)(2) and 

63.6(e)(3)] 

• The facility must develop a written startup, shutdown, and malfunction plan 

(SSMP) that describes, in detail, procedures for operating and maintaining the 

source during periods of startup, shutdown, and malfunction; and a program 

of corrective action for malfunctioning process, air pollution control, and 

monitoring equipment used to comply with the relevant standards. The SSMP 

is provided in Appendix G of this document. 

• The facility must maintain a current SSMP and must make the plan available 

upon request for inspection and copying by the Administrator. In addition, i f 

the SSMP is subsequently revised as provided in 40 CF R 63.6(e)(3)(viii), the 

facility must maintain each previous (i.e., superseded) version of the SSMP, 

and must make each previous version available for inspection and copying for 

a period of 5 years after revision of the plan. If at any time after adoption of 

an SSMP an affected source ceases operation or is otherwise no longer subject 

to the provisions of this part, the facility must retain a copy of the most recent 

plan for 5 years. Al l retained plans must be available for inspection and 

copying upon request. 

• The contents of the SSMP must address the requirements in 40 CF R 

63.1206(c)(2) and 40 CFR 63.6(e)(3). 

• The SSMP and revisions must be submitted to the Administrator for review 

and approval. 

d. NESHAP for Hazardous Waste Combustors [40 CF R 63.1206(c)(3) and 35 

IAC 201.149] 

The facility must operate the hazardous waste combustors with a functioning 

automatic waste fuel cutoff (AWFCO) system that immediately and automatically 

cuts off the hazardous waste feed when: 

25 
• An y of the following are exceeded: Operating parameter limits specified under 40 

C F R 63.1209; an emission standard monitored by a CEMS; and the allowable 

combustion chamber pressure; 

• The span value of any CM S detector, except a CEMS, is met or exceeded; 

• Upon malfunction of a CM S monitoring an OP L specified under 40 CFR 63.1209 

or an emission level; or 

• An y component of the AWFC O system fails. 

The AWFC O system must address the requirements in 40 CFR 63.1206(c)(3) and 

construction permits #83120053, #87100024 and #88010001. 

The continued operation of an emission source during malfunction or breakdown of 

the emission source or related air pollution control equipment shall not be allowed i f 

such operation would cause a violation of the standards or limitations set forth in IL 

Title 35, Subchapter c: Emission Standards and Limitations for Stationary Sources. 

Violation of the standards or limitations set forth in IL Title 35, Subchapter c: 

Emission Standards and Limitations for Stationary Sources shall not be allowed 

during startup. The AWFC O plan is provided in Appendix H of this document. 

e. NESHAP for Hazardous Waste Combustors [40 CFR 63.1206(c)(4)] 

• The facility must develop and maintain an Emergency Safety Vent (ESV) 

operating plan, comply with the operating plan, and keep the plan in the operating 

record. 

• The ES V operating plan contents must address the requirements in 40 CFR 

63.1206(c)(4). 

The ES V operating plan is provided in Appendix I of this document. 

f. NESHAP for Hazardous Waste Combustors [40 CFR 63.1206(c)(5)] 

Combustion system leaks of hazardous air pollutants must be controlled by 

maintaining the maximum combustion zone pressure lower than ambient pressure 

using an instantaneous monitor. 

g. NESHAP for Hazardous Waste Combustors [40 CFR 63.1206(c)(6)] 

Training programs must be established for all categories of personnel whose activities 

may reasonably be expected to directly affect emissions of hazardous air pollutants 

from the source. Each training program shall be of a technical level commensurate 

with the person's job duties specified in the training manual. Each commensurate 

training program shall require an examination to be administered by the instructor at 

the end of the training course. Passing of this test shall be deemed the "certification" 

for personnel, except that, for control room operators, the training and certification 

program shall be as specified below. 

26 
A certified control room operator must be on duty at the site at all times the source is 

in operation. Hazardous waste incinerator control room operators must: 

• Be trained and certified under a site-specific, source-developed and implemented 

program that meets the requirements of section 2.1(C)(10)(d);or 

• Be trained under the requirements of, and certified under, one of the following 

American Society of Mechanical Engineers (ASME) standards:QHO-l-1994, 

QHO-la-1996, or QHO-1-2004 (Standard for the Qualification and Certification 

of Hazardous Waste Incinerator Operators). If the Permittee elects to use the 

ASM E program: 

(A) Control room operators must, prior to the compliance date, achieve 

provisional certification and must submit an application to ASM E and be 

scheduled for the full certification exam. Within 1 year of the compliance 

date, control room operators must achieve full certification. 

(B) New operators and operators of new sources must, before assuming their 

duties, achieve provisional certification, submit an application to ASME , and 

be scheduled for the full certification exam. Within 1 year of assuming their 

duties, these operators must achieve full certification; or. 

• Be trained and certified under a State program. 

• Site-specific, source-developed and implemented training programs for control 

room operators must include the elements described 40 CF R 63.1206(c)(6)(v) and 

(vi). 

• Documentation of the operator training and certification program will be 

maintained in the operating record of the facility. 

h. NESHAP for Hazardous Waste Combustors [40 CF R 63.1206(c)(7) and 

63.6((e)] 

The facility must prepare and at all times operate according to an operation and 

maintenance plan (O& M Plan) that describes in detail procedures for operation, 

inspection, maintenance, and corrective measures for all components of the 

combustor, including associated pollution control equipment, that could affect 

emissions of regulated hazardous air pollutants. 

The contents of the O& M Plan must address the requirements in 40 CFR 

63.1206(c)(7) and 40 CFR 63.6(e). The O& M Plan is maintained in the operating 

record onsite. 

2. Work Practice Requirements 

The facility shall not bum hospital medical infectious waste, municipal waste, or 

beryllium NESHA P containing waste. 

27 
D. Incinerators: Unit 2, Unit 3, and Unit 4 Monitoring Requirements 

1. Continuous Emissions Monitoring Systems (CEMS) and Continuous Opacity 

Monitoring Systems (COMS) [40 CFR 63.1209(a)] 

a. NESHAP for Hazardous Waste Combustors [40 CF R 63.1209(a)(l)(i)] 

The facility must use either a carbon monoxide or hydrocarbon CEM S to demonstrate 

and monitor compliance with the carbon monoxide or hydrocarbon standard. A n 

oxygen CEM S must be used to continuously correct the carbon monoxide to 7 % 

oxygen. If the facility elects to comply with the hydrocarbon and carbon monoxide 

emission standards with a C O CEMS, then the facility must demonstrate that 

hydrocarbon emissions do not exceed the hydrocarbon standard during DR E testing. 

b. NESHAP for Hazardous Waste Combustors [40 CFR 63.1209(a)(l)(iii)] 

After such time as EP A promulgates all performance specifications and operational 

requirements applicable to P M CEMS, the facility must install, calibrate, maintain, 

and operate a particulate matter CEM S to demonstrate and monitor compliance with 

the particulate matter standards under this permit. 

c. NESHAP for Hazardous Waste Combustors [40 CF R 63.1209(a)(2)] 

The facility must install, calibrate, maintain, and continuously operate the CEM S and 

COM S in compliance with the quality assurance procedures provided in the appendix 

to 40 C.F.R. part 63, Subpart EE E and Performance Specifications 1 (opacity), 4B 

(carbon monoxide and oxygen), 8A (hydrocarbons) in Appendix B to 40 C.F.R. Part 

60, and the requirements of 40 CFR 63.1209(3) and (4). 

d. NESHAP for Hazardous Waste Combustors [40 CF R 63.1209(a)(5) and 

63.8(f)] 

The facility may petition EP A to use CEM S for compliance monitoring for particulate 

matter, mercury, semivolatile metals, low volatile metals, and hydrogen chloride and 

chlorine gas under 40 C.F.R. § 63.8(f), in lieu of compliance with the corresponding 

OPLs. 

e. NESHAP for Hazardous Waste Combustors [40 CF R 63.1209(a)(6)] 

Calculation of rolling averages for CEM S and COM S should be performed in 

accordance with the requirements of 40 CFR 63.1209(a)(6). 

28 
2. Other Continuous Monitoring Systems (CMS) [40 CF R 63.1209(b)] 

a. NESHAP for Hazardous Waste Combustors [40 CF R 63.1209(b)(1) and (2)] 

The facility must use CM S to document compliance with the applicable operating 

parameter limits for DRE , dioxin/furan, mercury, particulate matter, semivolatile 

metals, and low volatile metals. Except as specified in paragraphs 40 CFR 

63.1209(b)(2)(i) and (ii) of this section, the facility must install and operate CM S 

other than CEM S in conformance with 40 CF R 63.8(c)(3) that requires the facility, at 

a minimum, to comply with the manufacturer's written specifications or 

recommendations for installation, operation, and calibration of the system: 

• The calibration of thermocouples must be verified at a frequency and in a manner 

consistent with manufacturer specifications, but no less frequent than once per 

year. The facility must operate and maintain optical pyrometers in accordance 

with manufacturer specifications unless otherwise approved by the Administrator. 

The facility must calibrate optical pyrometers in accordance with the frequency 

and procedures recommended by the manufacturer, but no less frequent than once 

per year, unless otherwise approved by the Administrator. 

• If the facility operates a carbon injection system, the accuracy of the weight 

measurement device must be ±1 % of the weight being measured. The calibration 

of the device must be verified at least once each calendar quarter at a frequency of 

approximately 120 days. 

b. NESHAP for Hazardous Waste Combustors [40 CF R 63.1209(b)(3)] 

C M S must sample the regulated parameter without interruption, and evaluate the 

detector response at least once each 15 seconds, and compute and record the average 

values at least every 60 seconds. 

c. NESHAP for Hazardous Waste Combustors [40 CF R 63.1209(b)(4)] 

The span of the non-CEMS CM S detector must not be exceeded. The facility must 

interlock the span limits into the AWFC O system required by § 63.1206(c)(3). 

d. NESHAP for Hazardous Waste Combustors [40 CF R 63.1209(b)(5)] 

Calculation of rolling averages for CM S should be performed in accordance with the 

requirements of 40 CFR 63.1209(b)(5). 

3. Bag Leak Detection Systems (CMS) [40 CF R 63.1206(c)(8)] 

Veolia's incinerators are equipped with a baghouse; therefore, the facility must 

continuously operate either a bag leak detection system or a particulate matter detection 

system. The systems must meet the specifications listed in 40 CFR 63.1206(i) - (iv). 

29 
4. Feedstream Analysis [40 CFR 63.1209(c)] 

A n analysis of each feedstream to the incinerators must be obtained prior to feeding the 

material to document compliance with the feedrate limits contained in the most recent 

NOC . 

• The facility must develop and implement a feedstream analysis plan (FAP), the 

contents of which address the requirements in 40 CFR 63.1209(c)(2). 

• The FA P must be submitted to the agency for review and approval upon request 

in accordance with 40 CFR 63.1209(c)(3). The FA P is provided in Appendix J of 

this document. 

• To comply with the applicable feedrate limits of this section, the facility must 

monitor and record feedrates as provided in 40 CFR 63.1209(c)(4): 

(1) Determine and record the value of the parameter for each feedstream by 

sampling and analysis or other method; 

(2) Determine and record the mass or volume flowrate of each feedstream by 

a CMS. If the facility determines flowrate of a feedstream by volume, the 

facility must determine and record the density of the feedstream by sampling 

and analysis (unless the facility reports the constituent concentration in units 

of weight per unit volume (e.g., mg/1)); and 

(3) Calculate and record the mass feedrate of the parameter per unit time. 

In accordance with 40 CFR 63.1209(c)(5), the facility is not required to monitor 

the levels of metals or chlorine in the following feedstreams to document 

compliance with the feedrate limits under this section provided that the facility 

documents in the comprehensive performance test plan the expected levels of the 

constituent in the feedstream and account for those assumed feedrate levels in 

documenting compliance with feedrate limits: natural gas, process air, and 

feedstreams from vapor recovery systems. 

5. Performance Evaluations [40 CFR 63.1209(d), 63.8(d) and 63.8(e)] 

The facility is required to conduct performance evaluations of components of the CM S 

under the frequency and procedures (for example, submittal of performance evaluation 

test plan for review and approval) applicable to performance tests as provided by 40 CF R 

63.1207. In addition, the quality assurance procedures for CEM S prescribed in the 

appendix to 40 CF R 63 Subpart EE E is applicable. 

6. Conduct of Monitoring [40 CFR 63.1209(e) and 63.8(b)] 

Monitoring must be performed in accordance with 40 CFR 63.8(b). 

30 
7. Operation and Maintenance of Continuous Monitoring Systems [40 CF R 

63.1209(f) and 63.8(c)] 

The provisions of 40 CF R 63.8(c) apply except: 

• The requirements of 40 CF R 63.1211(c), that requires CMSs to be installed, 

calibrated, and operational on the compliance date, shall be complied with instead of 

section 63.8(c)(3); and 

• The performance specifications for carbon monoxide, hydrocarbon, and oxygen 

CEMSs in subpart B, part 60 of this chapter that requires detectors to measure the 

sample concentration at least once every 15 seconds for calculating an average 

emission rate once every 60 seconds shall be complied with instead of 40 CF R 

63.8(c)(4)(h). 

8. Reduction of Monitoring Data [40 CF R 63.1209(h) and 63.8(g)] 

Reduction of monitoring data must be performed i n accordance with 40 CF R 63.8(b). 

9. Operating Parameters for Multiple Standards [40 CF R 63.1209(f) through (p)] 

The facility must establish limits on the operating parameters identified in 40 CF R 

63.1209(j) through (p) based on comprehensive performance testing to ensure it 

maintains compliance with the emission standards of this subpart. For several 

parameters, the facility must establish a limit for the parameter to ensure compliance with 

more than one emission standard. If the performance tests for such standards are not 

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

independent performance tests applies. A list of the OPLs required is provided in section 

C. 1 .a of this document. 

10. Operating Parameter Limit Averaging Periods [40 CFR 63.1209(r)] 

The averaging periods specified for operating parameters are not-to-exceed averaging 

periods. The facility may elect to use shorter averaging periods. For example, the 

facility may elect to use a 1-hour rolling average rather than the 12-hour rolling average 

specified for mercury. 

E. Incinerators: Unit 2, Unit 3, and Unit 4 Performance Testing Requirements 

1. Changes to the Source [40 CFR 63.1206(b)(5)(i)(B)] 

If changes occur (as defined in 40 CFR 63.1206(b)(5)(iii)) to the design, operation, or 

maintenance practices of the source in a manner that may adversely affect compliance 

with any emission standard that is not monitored with a CEMS, a comprehensive 

performance test must be conducted under the requirements of 40 CFR 63.1207(f)(1) and 

(g)(1) to document compliance with the affected emission standard(s) and to confirm 

31 
existing or establish new OPLs as required under 40 CF R 63.1209, and submit a new 

Notification of Compliance. 

2. Compliance with CO and TH C Emission Standard [40 CFR 63.1206(b)(6)] 

This paragraph applies to sources that elect to comply with the carbon monoxide and 

hydrocarbon emissions standards of subpart EE E by documenting continuous compliance 

with the carbon monoxide standard using a continuous emissions monitoring system and 

documenting compliance with the hydrocarbon standard during the DR E performance 

test or its equivalent. 

(a) If, during the acceptable DR E test, the Permittee did not obtain hydrocarbon 

emissions data sufficient to document compliance with the hydrocarbon standard, the 

facility must either: 

• Perform, as part of the performance test, an "equivalent DR E test" to document 

compliance with the hydrocarbon standard. A n equivalent DR E test is comprised of a 

minimum of three runs, each with a minimum duration of 1 hour during which the 

Permittee operates the combustor as close as reasonably possible to the OPLs that the 

Permittee established based on the initial DR E test. The Permittee must use the 

highest hourly rolling average hydrocarbon emission level achieved during the 

equivalent DR E test to document compliance with the hydrocarbon standard; or 

• Perform a DR E test as part of the performance test. 

3. Types of Performance Tests [40 CFR 63.1207(b)] 

• The facility is required to conduct comprehensive performance tests to 

demonstrate compliance with the emission standards provided by this subpart, 

establish limits for the operating parameters provided by 40 CF R 63.1209, and 

demonstrate compliance with the performance specifications for continuous 

monitoring systems. 

• The facility must conduct confirmatory performance tests to demonstrate 

compliance with the dioxin/furan emission standard when the source operates 

under normal operating conditions and to conduct a performance evaluation of 

continuous monitoring systems required for compliance assurance with the 

dioxin/furan emission standard under 40 CF R 63.1209(k). 

• 

4. Frequency of Performance Tests [40 CF R 63.1207(d)] 

The facility must conduct testing periodically as prescribed in 40 CF R 63.1207(d)(1) 

through (d)(3). 

• A comprehensive performance test must be conducted no later than 61 months 

after the beginning of the previous comprehensive performance test used to show 

compliance with 40 CFR 63 Subpart EE E requirements. 

32 
• A confirmatory test must be conducted no later than 31 months after the 

beginning of the previous comprehensive performance test used to show 

compliance with 40 CFR 63 Subpart EE E requirements. 

The deadline for commencing confirmatory and comprehensive performance testing is 

based on the date of commencement of the previous comprehensive performance test. 

5. Content of Performance Test Plans [40 CF R 63.1207(f)] 

a. NESHAP for Hazardous Waste Combustors [40 CFR 63.1207(f)(1)] 

Comprehensive performance test plans must meet the requirements of 40 

C FR 63.7(c)(2)(i)-(iii) and (v). In addition, comprehensive performance test plans 

must include the following information: 

• A n analysis of each feedstream, including hazardous waste, other fuels, and 

industrial furnace feedstocks, as fired, that includes: heating value, levels of ash 

(for hazardous waste incinerators only), levels of semivolatile metals, low volatile 

metals, mercury, and total chlorine (organic and inorganic); and viscosity or 

description of the physical form of the feedstream. 

• For organic hazardous air pollutants established by 42 U.S.C. 7412(b)(1), 

excluding caprolactam (CAS number 105602) as provided by § 63.60: an 

identification of such organic hazardous air pollutants that are present in each 

hazardous waste feedstream except as provided by paragraph 40 CFR 

63.1207(f)(l)(ii)(D) of this section, an approximate quantification of such 

identified organic hazardous air pollutants in the hazardous waste feedstreams, 

within the precision produced by analytical procedures of § 63.1208(b)(8), and a 

description of blending procedures, if applicable, prior to firing the hazardous 

waste feedstream, including a detailed analysis of the materials prior to blending, 

and blending ratios. A hazardous waste feedstream analysis for organic 

hazardous air pollutants may approved on a case-by-case basis in lieu of the 

analysis required under paragraph 40 CF R 63.1207(f)(l)(ii)(A) if the reduced 

analysis is sufficient to ensure that the POHCs used to demonstrate compliance 

with the applicable DR E standards of this subpart continue to be representative of 

the most difficult to destroy organic compounds in the facility's hazardous waste 

feedstreams. 

• A detailed engineering description of the hazardous waste combustor, including: 

manufacturer's name and model number of the hazardous waste combustor; type 

of hazardous waste combustor; maximum design capacity in appropriate units; 

description of the feed system for each feedstream; capacity of each feed system; 

description of automatic hazardous waste feed cutoff system(s); description of the 

design, operation, and maintenance practices for any air pollution control system; 

and description of the design, operation, and maintenance practices of any stack 

gas monitoring and pollution control monitoring systems. 

• A detailed description of sampling and monitoring procedures, including 

sampling and monitoring locations in the system, the equipment to be used, 

33 
sampling and monitoring frequency, and planned analytical procedures for sample 

analysis. 

A detailed test schedule for each hazardous waste for which the performance test 

is planned, including date(s), duration, quantity of hazardous waste to be burned, 

and other relevant factors. 

A detailed test protocol, including, for each hazardous waste identified, the ranges 

of hazardous waste feedrate for each feed system, and, as appropriate, the 

feedrates of other fuels and feedstocks, and any other relevant parameters that 

may affect the ability of the hazardous waste combustor to meet the emission 

standards. 

A description of, and planned operating conditions for, any emission control 

equipment that will be used. 

Procedures for rapidly stopping the hazardous waste feed and controlling 

emissions in the event of an equipment malfunction. 

A determination of the hazardous waste residence time as required by 40 CF R 

63.1206(b)(ll). 

If the facility is requesting to extrapolate metal feedrate limits from 

comprehensive performance test levels under 40 CFR 63.1209(l)(l)(v) or 

63.1209(n)(2)(vii): a description of the extrapolation methodology and rationale 

for how the approach ensures compliance with the emission standards, 

documentation of the historical range of normal (i.e., other than during 

compliance testing) metals feedrates for each feedstream, and documentation that 

the level of spiking recommended during the performance test will mask sampling 

and analysis imprecision and inaccuracy to the extent that the extrapolated 

feedrate limits adequately assure compliance with the emission standards. 

If the facility does not continuously monitor regulated constituents in natural gas, 

process air feedstreams, and feedstreams from vapor recovery systems under 40 

C FR 63.1209(c)(5), it must include documentation of the expected levels of 

regulated constituents in those feedstreams. 

Documentation justifying the duration of system conditioning required to ensure 

the combustor has achieved steady-state operations under performance test 

operating conditions, as provided by paragraph (g)(l)(iii) of this section. 

For cement kilns with in-line raw mills, i f the facility elects to use the emissions 

averaging provision of this subpart, it must notify the Administrator of its intent in 

the initial (and subsequent) comprehensive performance test plan, and provide the 

information required by the emission averaging provision. 

For preheater or preheater/precalciner cement kilns with dual stacks, if the facility 

elects to use the emissions averaging provision of this subpart, it must notify the 

Administrator of its intent in the initial (and subsequent) comprehensive 

performance test plan, and provide the information required by the emission 

averaging provision. 

If the facility requests to use Method 23 for dioxin/furan, it must provide the 

information required under 40 CFR 63.1208(b)(l)(i)(B). 

If the facility is not required to conduct performance testing to document 

compliance with the mercury, semivolatile metals, low volatile metals, or 

hydrogen chloride/chlorine gas emission standards 40 CFR 63.1207(m), it must 

34 
include with the comprehensive performance test plan documentation of 

compliance with the provisions of that section. 

• If the facility proposes to use a surrogate for measuring or monitoring gas 

flowrate, it must document in the comprehensive performance test plan that the 

surrogate adequately correlates with gas flowrate, as required by 40 CF R 

63.1207(m)(7), and 40 CFR 63.1209(j)(2), (k)(3), (m)(2)(i), (n)(5)(i), and 

(o)(2)(i). 

• A n application must be submitted to request alternative monitoring under 40 CF R 

63.1209(g)(1) not later than with the comprehensive performance test plan, as 

required by 40 CF R 63.1209(g)(l)(iii)(A). 

• The temperature location measurement must be documented in the comprehensive 

performance test plan, as required by 40 CF R 63.1209(j)(l)(i) and 

63.1209(k)(2)(i). 

• For the activated carbon injection system, the facility must document in the 

comprehensive performance test plan: the manufacturer specifications for 

minimum carrier fluid flowrate or pressure drop, as required by 40 CF R 

63.1209(k)(6)(ii); and key parameters that affect carbon adsorption, and the 

operating limits the facility establishes for those parameters based on the carbon 

used during the performance test, if it elects not to specify and use the brand and 

type of carbon used during the comprehensive performance test, as required by 40 

C FR 63.1209(k)(6)(iii). 

• For a dry scrubber used to control hydrogen chloride and chlorine gas, the facility 

must document in the comprehensive performance test plan key parameters that 

affect adsorption, and the limits it establishes for those parameters based on the 

sorbent used during the performance test, i f the facility elects not to specify and 

use the brand and type of sorbent used during the comprehensive performance 

test, as required by 40 CFR 63.1209(o)(4)(iii)(A). 

• For purposes of calculating semivolatile metal, low volatile metal, mercury, and 

total chlorine (organic and inorganic), and ash feedrate limits, a description of 

how the facility will handle performance test feedstream analytical results that 

determines these constituents are not present at detectable levels. 

• Such other information as the Administrator reasonably finds necessary to 

determine whether to approve the performance test plan. 

b. NESHAP for Hazardous Waste Combustors [40 CF R 63.1207(f)(2)] 

Confirmatory performance test plans must meet the requirements of 40 

C F R 63.7(c)(2)(i)-(iii) and (v). In addition, confirmatory performance test plans must 

include the following information: 

• A description of the normal hydrocarbon or carbon monoxide operating levels, as 

specified in paragraph (g)(2)(i) of this section, and an explanation of how these 

normal levels were determined. 

• A description of the normal applicable operating parameter levels, as specified in 

paragraph (g)(2)(ii) of this section, and an explanation of how these normal levels 

were determined. 

35 
• A description of the normal chlorine operating levels, as specified in paragraph 

(g)(2)(iii) of this section, and an explanation of how these normal levels were 

determined. 

• For a carbon injection system or a carbon bed, a description of the normal 

cleaning cycle of the particulate matter control device, as specified in 40 CFR 

63.1207(g)(2)(iv), and an explanation of how these normal levels were 

determined. 

• A detailed description of sampling and monitoring procedures including sampling 

and monitoring locations in the system, the equipment to be used, sampling and 

monitoring frequency, and planned analytical procedures for sample analysis. 

• A detailed test schedule for each hazardous waste for which the performance test 

is planned, including date(s), duration, quantity of hazardous waste to be burned, 

and other relevant factors. 

• A detailed test protocol, including, for each hazardous waste identified, the ranges 

o f hazardous waste feedrate for each feed system, and, as appropriate, the 

feedrates of other fuels and feedstocks, and any other relevant parameters that 

may affect the ability of the hazardous waste combustor to meet the dioxin/furan 

emission standard. 

• A description of, and planned operating conditions for, any emission control 

equipment that will be used. 

• Procedures for rapidly stopping the hazardous waste feed and controlling 

emissions in the event of an equipment malfunction. 

• Such other information as the Administrator reasonably finds necessary to 

determine whether to approve the confirmatory test plan. 

6. Operating Conditions During Performance Tests [40 CF R 63.1207(g)] 

The provisions of 40 CFR 63.7(e) applies. Performance testing must be conducted under 

operating conditions representative of the extreme range of normal conditions which is 

consistent with 40 CFR 63.7(e)(1). 

a. NESHAP for Hazardous Waste Combustors [40 CF R 63.1207(g)(a)] 

For the following parameters, the combustor must be operated during the 

comprehensive performance test under normal conditions (or conditions that will 

result in higher than normal emissions): 

• Chlorine feedrate. The facility must feed normal (or higher) levels of chlorine 

during the dioxin/furan performance test; 

• Ash feedrate. For hazardous waste incinerators, the facility must conduct the 

following tests when feeding normal (or higher) levels of ash: the semivolatile 

metal and low volatile metal performance tests, and the dioxin/furan and mercury 

performance tests if activated carbon injection or a carbon bed is used; and 

• Cleaning cycle of the particulate matter control device. The facility must conduct 

the following tests when the particulate matter control device undergoes its 

normal (or more frequent) cleaning cycle: the particulate matter, semivolatile 

36 
metal, and low volatile metal performance tests; and the dioxin/furan and mercury 

performance tests if activated carbon injection or a carbon bed is used. 

Given that the facility must establish limits for the applicable operating parameters 

specified in 40 CFR 63.1209 based on operations during the comprehensive 

performance test, the facility may conduct testing under two or more operating modes 

to provide operating flexibility. 

Prior to obtaining performance test data, the facility must operate under performance 

test conditions until it reaches steady-state operations with respect to emissions of 

pollutants it must measure during the performance test and operating parameters 

under 40 CFR 63.1209 for which it must establish limits. During system 

conditioning, the facility must ensure that each operating parameter for which it 

must establish a limit is held at the level planned for the performance test. The 

facility must include documentation in the performance test plan justifying the 

duration of system conditioning. 

b. NESHAP for Hazardous Waste Combustors [40 CF R 63.1207(g)(b)] 

For the following parameters, the confirmatory performance testing for dioxin/furan 

must be conducted under normal operating conditions: 

• Carbon monoxide (or hydrocarbon) CEM S emissions levels must be within the 

range of the average value to the maximum value allowed, except as provided by 

paragraph (g)(2)(v) of this section. The average value is defined as the sum of the 

hourly rolling average values recorded (each minute) over the previous 12 

months, divided by the number of rolling averages recorded during that time. The 

average value must not include calibration data, startup data, shutdown data, 

malfunction data, and data obtained when not burning hazardous waste. 

• Each operating limit (specified in 40 CFR 63.1209) established to maintain 

compliance with the dioxin/furan emission standard must be held within the range 

of the average value over the previous 12 months and the maximum or minimum, 

as appropriate, that is allowed, except as provided by 40 CFR 63.1207(g)(2)(v). 

The average value is defined as the sum of the rolling average values recorded 

over the previous 12 months, divided by the number of rolling averages recorded 

during that time. The average value must not include calibration data, startup 

data, shutdown data, malfunction data, and data obtained when not burning 

hazardous waste. 

• Chlorine must be fed at normal feedrates or greater. 

• For a carbon injection system or carbon bed, normal cleaning cycle of the 

particulate matter control device. 

• The Administrator may approve an alternative range to that required by 

paragraphs 40 CFR 63.1207(g)(2)(i) and (ii) if the facility documents in the 

confirmatory performance test plan that it may be problematic to maintain the 

required range during the test. In addition, when making the finding of 

compliance, the Administrator may consider test conditions outside of the range 

37 
specified in the test plan based on a finding that the facility could not reasonably 

maintain the range specified in the test plan and considering factors including 

whether the time duration and level of the parameter when operations were out of 

the specified range were such that operations during the confirmatory test are 

determined to be reasonably representative of normal operations. In addition, the 

Administrator will consider the proximity of the emission test results to the 

standard. 

7. Operating Conditions During Subsequent Performance Tests [40 CF R 

63.1207(h)] 

Current operating parameter limits established under 40 CFR 63.1209 are waived during 

subsequent comprehensive performance testing. Current operating parameter limits are 

also waived during pretesting prior to comprehensive performance testing for an 

aggregate time not to exceed 720 hours of operation (renewable at the discretion of the 

Administrator) under an approved test plan or if the source records the results of the 

pretesting. 

8. Test Methods [40 CFR 63.1208] 

Test methods as described in 40 CF R 63.1208 must be used to determine compliance 

with the applicable emission standards. 

9. Failure of Performance Test [40 CF R 63.1207(1)] 

a. NESHAP for Hazardous Waste Combustors [40 CF R 63.1207(f)(1)] 

The provisions of this paragraph do not apply to the initial comprehensive 

performance test if the facility conducts the test prior to its compliance date. 

• If it is determined (based on CE M recordings, results of analyses of stack 

samples, or results of CM S performance evaluations) that the facility has 

exceeded any emission standard during a comprehensive performance test for a 

mode of operation, hazardous waste burning must cease immediately under that 

mode of operation. This determination must be made within 90 days following 

completion of the performance test. 

• If the facility has failed to demonstrate compliance with the emission standards 

for any mode of operation, prior to submitting a revised Notification of 

Compliance, it may burn hazardous waste only for the purpose of pretesting or 

comprehensive performance testing under revised operating conditions, and only 

for a maximum of 720 hours (renewable at the discretion of the Administrator), 

except as provided by 40 CF R 63.1207(1)(3). 

• The facility must conduct a comprehensive performance test under revised 

operating conditions following the requirements for performance testing of this 

section. 

38 
• The facility must submit to the Administrator a Notification of Compliance 

subsequent to the new comprehensive performance test. 

b. NESHAP for Hazardous Waste Combustors [40 CF R 63.1207(f)(2)] 

• If it is determined (based on CE M recordings, results of analyses of stack 

samples, or results of CM S performance evaluations) that the facility has failed 

the dioxin/furan emission standard during a confirmatory performance test, it 

must cease burning hazardous waste immediately. This determination must be 

made within 90 days following completion of the performance test. 

• To burn hazardous waste in the future, the facility must submit to the 

Administrator for review and approval a test plan to conduct a comprehensive 

performance test to identify revised limits on the applicable dioxin/furan 

operating parameters specified in 40 CF R 63.1209(k). 

• To burn hazardous waste in the future, the facility must submit to the 

Administrator a Notification of Compliance with the dioxin/furan emission 

standard. The facility must include in the Notification of Compliance the revised 

limits on the applicable dioxin/furan operating parameters specified in 40 CFR 

63.1209(k);and 

• Until the Notification of Compliance is submitted, the facility must not burn 

hazardous waste except for purposes of pretesting or confirmatory performance 

testing, and for a maximum of 720 hours (renewable at the discretion of the 

Administrator), except as provided by 40 CFR 63.1207(1)(3) of this section. 

c. NESHAP for Hazardous Waste Combustors [40 CF R 63.1207(f)(3)] 

The facility may petition the Administrator to obtain written approval to burn 

hazardous waste in the interim prior to submitting a Notification of Compliance for 

purposes other than testing or pretesting. The facility must specify operating 

requirements; including limits on operating parameters that are determined to ensure 

compliance with the emission standards of this subpart based on available 

information including data from the failed performance test. The Administrator will 

review, modify as necessary, and approve if warranted the interim operating 

requirements. A n approval of interim operating requirements will include a schedule 

for submitting a Notification of Compliance. 

F. Incinerators: Unit 2, Unit 3, and Unit 4 Recordkeeping and Reporting 

1. Summary of Notification Requirements [40 CF R 63.1210(a)] 

The following notification requirements as outlined in 40 CF R 63.1210 are applicable: 

Reference Notification 

63.9(b) Initial notifications that the facility is subject to Subpart EEE of this 

Part. 

39 
Reference Notification 

63.9(d) Notification that the facility is subject to special compliance 

requirements. 

63.9© Notification and documentation of any change in information already 

provided under § 63.9. 

63.1206(b)(5)(i) Notification of changes in design, operation, or maintenance. 

63.1206(c)(8)(iv) Notification of excessive bag leak detection system exceedances. 

63.1206(c)(9)(v) Notification of excessive particulate matter detection system 

exceedances. 

63.1207(e), 63.9(e) 63.9(g)(1) and (3) Notification of performance test and continuous monitoring system 

evaluation, including the performance test plan and CMS performance 

evaluation plan. 1 

63.1210(b) Notification of intent to comply. 

63.1210(d), 63.1207(j), 63.1207(k), 

63.1207(1), 63.9(h), 63.10(d)(2), 

63.10(e)(2) 

Notification of compliance, including results of performance tests and 

continuous monitoring system performance evaluations. 

The facility must submit the following notifications to the Administrator if it requests or 

elects to comply with alternative requirements: 

Reference Notification, Request, Petition, or Application 

63.9(i) The facility may request an adjustment to time periods or postmark deadlines for submittal 

and review of required information. 

63.10(e)(3)(ii) The facility may request to reduce the frequency of excess emissions and CMS 

performance reports. 

63.10(f) The facility may request to waive recordkeeping or reporting requirements. 

63.1204(d)(2)(iii), 

63.1220(d)(2)(iii) 

Notification that the facility elects to comply with the emission averaging requirements for 

cement kilns with in-line raw mills. 

63.1204(e)(2)(iii), 

63.1220(e)(2)(iii) 

Notification that the facility elects to comply with the emission averaging requirements for 

preheater or preheater/precalciner kilns with dual stacks. 

63.1206(b)(4), 63.1213, 

63.6(i), 63.9(c) 

The facility may request an extension of the compliance date for up to one year. 

63.1206(b)(5)(i)(C) The facility may request to burn hazardous waste for more than 720 hours and for purposes 

other than testing or pretesting after making a change in the design or operation that could 

affect compliance with emission standards and prior to submitting a revised Notification of 

Compliance. 

63.1206(b)(8)(iii)(B) If the facility elects to conduct particulate matter CEMS correlation testing and wishes to 

have federal particulate matter and opacity standards and associated operating limits 

waived during the testing, it must notify the Administrator by submitting the correlation 

test plan for review and approval. 

63.1206(b)(8)(v) The facility may request approval to have the particulate matter and opacity standards and 

associated operating limits and conditions waived for more than 96 hours for a correlation 

test. 

40 
Reference Notification, Request, Petition, or Application 

63.1206(b)(9) Owners and operators of lightweight aggregate kilns may request approval of alternative 

emission standards for mercury, semivolatile metal, low volatile metal, and hydrogen 

chloride/chlorine gas under certain conditions. 

63.1206(b)(10) Owners and operators of cement kilns may request approval of alternative emission 

standards for mercury, semivolatile metal, low volatile metal, and hydrogen 

chloride/chlorine gas under certain conditions. 

63.1206(b)(14) Owners and operators of incinerators may elect to comply with an alternative to the 

particulate matter standard. 

63.1206(b)(15) Owners and operators of cement and lightweight aggregate kilns may request to comply 

with the alternative to the interim standards for mercury. 

63.1206(c)(2)(ii)(C) The facility may request to make changes to the startup, shutdown, and malfunction plan. 

63.1206(c)(5)(i)(C) The facility may request an alternative means of control to provide control of combustion 

system leaks. 

63.1206(c)(5)(i)(D) The facility may request other techniques to prevent fugitive emissions without use of 

instantaneous pressure limits. 

63.1207(c)(2) The facility may request to base initial compliance on data in lieu of a comprehensive 

performance test. 

63.1207(d)(3) The facility may request more than 60 days to complete a performance test if additional 

time is needed for reasons beyond its control. 

63.1207(e)(3), 63.7(h) The facility may request a time extension if the Administrator fails to approve or deny its 

test plan. 

63.1207(h)(2) You may request to waive current operating parameter limits during pretesting for more 

than 720 hours. 

63.1207(f)(l)(ii)(D) The facility may request a reduced hazardous waste feedstream analysis for organic 

hazardous air pollutants if the reduced analysis continues to be representative of organic 

hazardous air pollutants in its hazardous waste feedstreams. 

63.1207(g)(2)(v) The facility may request to operate under a wider operating range for a parameter during 

confirmatory performance testing. 

63.1207© The facility may request up to a one-year time extension for conducting a performance 

test (other than the initial comprehensive performance test) to consolidate testing with 

other state or federally-required testing. 

63.1207©(4) The facility may request more than 90 days to submit a Notification of Compliance after 

completing a performance test if additional time is needed for reasons beyond itscontrol. 

63.1207(1)(3) After failure of a performance test, the facility may request to burn hazardous waste for 

more than 720 hours and for purposes other than testing or pretesting. 

63.1209(a)(5), 63.8(0 The facility may request: (1) Approval of alternative monitoring methods for compliance 

with standards that are monitored with a CEMS; and (2) approval to use a CEMS in lieu of 

operating parameter limits. 

63.1209(g)(1) The facility may request approval of: (1) Alternatives to operating parameter monitoring 

requirements, except for standards that it must monitor with a continuous emission 

monitoring system (CEMS) and except for requests to use a CEMS in lieu of operating 

parameter limits; or (2) a waiver of an operating parameter limit. 

41 
Reference Notification, Request, Petition, or Application 

63.1209(1X1) The facility may request to extrapolate mercury feedrate limits. 

63.1209(n)(2) The facility may request to extrapolate semivolatile and low volatile metal feedrate limits. 

63.1211(d) The facility may request to use data compression techniques to record data on a less 

frequent basis than required by § 63.1209. 

2. Summary of Reporting Requirements [40 CFR 63.1211(a)] 

The following reports must be submitted in accordance with 40 CF R 63.1211: 

Reference Report 

63.10(d)(4) Compliance progress reports, if required as a condition of an extension of the compliance date 

granted under § 63.6(i). 

63.10(d)(5)® Periodic startup, shutdown, and malfunction reports. 

63.10(d)(5)(a) Immediate startup, shutdown, and malfunction reports. 

63.10(e)(3) Excessive emissions and continuous monitoring system performance report and summary 

report. 

63.1206(c)(2)(ii)(B) Startup, shutdown, and malfunction plan. 

63.1206(c)(3)(vi) Excessive exceedances reports. 

63.1206(c)(4)(iv) Emergency safety vent opening reports. 

63.1206(c)(3)(vi) AWFCO excessive exceedance reports. 

63.1206(c)(8)(iv) BLDS excessive exceedance reports. 

63.1206(c)(4) ESV opening that results in failure to meet emission standards. 

3. Summary of Recordkeeping Requirements [40 CF R 63.1211(b)] 

The following records must be retained in the operating record: 

Reference Document, Data, or Information 

63.1200, 63.10(b) and (c) General. Information required to document and maintain compliance with the 

regulations of Subpart EEE, including data recorded by continuous monitoring 

systems (CMS), and copies of all notifications, reports, plans, and other documents 

submitted to the Administrator. 

63.1206(b)(l)(ii) If the facility elects to comply with all applicable requirements and standards 

promulgated under authority of the Clean Air Act, including Sections 112 and 129, 

in lieu of the requirements of Subpart EEE when not burning hazardous waste, it 

must document in the operating record that it is in compliance with those 

requirements. 

63.1206(b)(5)(h) Documentation that a change will not adversely affect compliance with the emission 

standards or operating requirements. 

63.1206(b)(ll) Calculation of hazardous waste residence time. 

63.1206(c)(2) Startup, shutdown, and malfunction plan. 

42 
Reference Document, Data, or Information 

63.1206(c)(2)(v)(A) Documentation of the facility's investigation and evaluation of excessive 

exceedances during malfunctions. 

63.1206(c)(3)(v) Corrective measures for any automatic waste feed cutoff that results in an 

exceedance of an emission standard or operating parameter limit. 

63.1206(c)(3)(vii) Documentation and results of the automatic waste feed cutoff operability testing. 

63.1206(c)(4)(ii) Emergency safety vent operating plan. 

63.1206(c)(4)(iii) Corrective measures for any emergency safety vent opening. 

63.1206(c)(5)(ii) Method used for control of combustion system leaks. 

63.1206(c)(6) Operator training and certification program. 

63.1206(c)(7)(i)(D) Operation and maintenance plan. 

63.1209(c)(2) Feedstream analysis plan. 

63.1209(k)(6)(iii), 

63.1209(k)(7)(ii), 

63.1209(k)(9)(ii), 

63.1209(o)(4)(iii) 

Documentation that a substitute activated carbon, dioxin/furan formation reaction 

inhibitor, or dry scrubber sorbent will provide the same level of control as the 

original material. 

63.1209(q) Documentation of changes in modes of operation. 

63.1211(c) Documentation of compliance. 

The permittee shall maintain all records for five calendar years and make them available 

at all times for inspection by EPA , IEPA, local agencies or their duly authorized 

representatives in accordance with 40 CFR 71.6(a)(3)(i)(B). 

G. Waste Processing Unit Requirements (MP-1, MP-2 and LPR) 

Material processing involves the repackaging of solid waste material from larger containers 

such as drums and totes to smaller "charge" containers/boxes for subsequent incineration. 

Aqueous or organic free liquids may also be present. A n inert absorbent is used to fix the 

free liquids to facilitate repackaging. Volatile organic materials may be emitted during 

material processing in MP-1 and MP-2 . The regulations applicable to the emission units are 

listed below. A listing of any non-applicable requirements and the reasons for the nonapplicability are provided in Appendix B. 

1. Visible Emissions Limitations [35 IAC 212.123] 

Visible emissions from either MP-1 or MP- 2 shall not exceed 30% opacity, except that, 

for any 8-one minute period in any one hour, the opacity may be greater than 30% but 

less than 60%>, provided that the opacity greater than 60% occurs at one emission unit 

limited to 3 times within a 24-hour period. 

43 
2. Use of Organic Material [35 IAC 219.301] 

Emission of organic material from these emission units shall not exceed 8 lb/hr. If no 

odor nuisance exists, the limitation shall apply only to photochemically reactive material. 

3. NESHAP for Off-Site Waste and Recovery Operations [40 CFR 63 Subpart DD] 

Veolia is a waste management operation that receives off-site material and is regulated as 

a hazardous waste treatment, storage, and disposal facility (TSDF). The National 

Emission Standards for Hazardous Ai r Pollutants from Off-Site Waste and Recovery 

Operations are applicable to the MP-1 and MP- 2 operations at the facility. As required in 

40 CFR 63.683(b)(1)(f) and 63.688(a), Veolia controls air emissions from the containers 

processed in these waste management units by following the standards for Container 

Level 1 controls specified in 40 CFR 63.922 for Containers. 

4. NESHAP for Containers [40 CF R 63.922] 

A container using Container Level 1 controls is one of the following: 

a. A container that meets the applicable U.S. Department of Transportation (DOT) 

regulations on packaging hazardous materials for transportation as specified in 40 

C FR 63.922(f). 

b. A container equipped with a cover and closure devices that form a continuous 

barrier over the container openings such that when the cover and closure devices 

are secured in the closed position there are no visible holes, gaps, or other open 

spaces into the interior of the container. The cover may be a separate cover 

installed on the container (e.g., a lid on a drum, a suitably secured tarp on a rolloff box) or may be an integral part of the container structural design (e.g., a bulk 

cargo container equipped with a screw-type cap). 

c. A n open-top container in which an organic vapor-suppressing barrier is placed on 

or over the regulated material in the container such that no regulated material is 

exposed to the atmosphere. One example of such a barrier is application of 

suitable organic vapor suppressing foam. 

d. A container used to meet the requirements of either paragraph 40 CFR 

63.922(b)(2) or (b)(3) shall be equipped with covers and closure devices, as 

applicable to the container, that are composed of suitable materials to minimize 

exposure of the regulated material to the atmosphere and to maintain the 

equipment integrity for as long as it is in service. Factors to be considered when 

selecting the materials for and designing the cover and closure devices shall 

include: organic vapor permeability; the effects of contact with the material or its 

vapor managed in the container; the effects of outdoor exposure to wind, 

moisture, and sunlight; and the operating practices used for container on which 

the cover is installed. Whenever a regulated material is in a container using 

Container Level 1 controls, the owner or operator shall install all covers and 

closure devices for the container, and secure and maintain each closure device in 

the closed position except as described in 40 CF R 63.922(d)(1) through (d)(5). 

44 
The owner or operator shall inspect containers using Container Level 1 controls in 

accordance with the procedures specified in 40 CFR 63.926(a). 

5. NESHAP for Containers [40 CFR 63.925 and 40 CFR 71.6(a)(3)(i)(A)] 

To determine that there are no detectable organic emissions for the purpose of complying 

with 40 CFR 63 Subpart PP, the facility shall conduct a test annually in accordance with 

the procedures specified in Method 21 of 40 CFR. Part 60, Appendix A and 40 CFR 

63.925. Each potential leak interface (i.e., a location where organic vapor leakage could 

occur) on the cover and associated closure devices shall be checked annually. The test 

shall be performed when a material having a total organic concentration representative of 

the range of concentrations for the materials expected to be managed in the units is in the 

containers. 

6. NESHAP for Containers [40 CF R 71.6(a)(3)] 

• The facility shall promptly notify the permitting authority of deviations of the 

affected waste processing units with the permit requirements, pursuant to 40 CFR 

71.6(a)(3)(iii)(B). Reports shall describe the probable cause of such deviations, and 

any corrective actions or preventive measures taken. 

• The facility shall maintain the records of each visual inspection, visible emission 

observation, findings of any investigation required, and results of any Method 9 

observation conducted. 

• The records shall include the date, time, type of investigation conducted, and type of 

corrective actions as applicable. 

7. NESHAP for Benzene Waste Operations [40 CF R 61 Subpart FF] 

Veoli a operates a hazardous waste TSD facility that manages benzene-containing 

hazardous waste as regulated by this subpart. Containers of benzene-containing waste 

are processed in MP-1 and MP- 2 following standard work practices that address the 

provisions of 40 CFR 61.345. 

8. Emission Calculation Requirements [40 CF R 71.6(a)(3)(i)(B)] 

VOM/HA P emissions from units MP1 , MP2 , and the labpack shall be calculated based 

on the most recent version of the TANK S program. 

H. Liquid Waste Storage Tank Requirements 

Bulk liquid wastes are stored in Tank Farm #1 and Tank Farm #3. Al l tanks are vertical, 

fixed-roof tanks. Tank Farm #1 supplies liquid waste to Unit 2 and Unit 3 incinerators. 

Tank Farm #3 supplies liquid waste to Unit 4 incinerator. The regulations applicable to the 

emission units are listed below. A listing of any non-applicable requirements and the reasons 

for the non-applicability are provided in Appendix B. 

45 
1. Use of Organic Material [35 IAC 219.301] 

Emission of organic material from these emission units shall not exceed 8 lb/hr. If no 

odor nuisance exists, the limitation shall apply only to photochemically reactive material. 

2. Organic Material Emission from Pumps and Compressors [35 IAC 219.142] 

No person shall cause or allow the discharge of more than 32.8 ml (2 cu in) of VO L with 

vapor pressure of 17.24 kPa (2.5 psia) or greater at 294.3°K (70°F) into the atmosphere 

from any pump or compressor in any 15-minute period at standard conditions. 

3. Standards of Performance for Volatile Organic Liquid Storage Vessels 

(including petroleum liquid storage vessels) for which Construction, 

Reconstruction, or Modification Commenced After July 23,1984 [40 CF R 60 

Subpart Kb] 

The facility shall equip the applicable tank with a control method as listed in 40 CF R 

60.112b. The requirements of this regulation apply to Organic Liquid Storage Tanks 

#300, #302, #304, #306, #308, and #310, all of which have capacity greater than 75 cubic 

meters (19,813 gallons). Documentation and records as described in 40 CF R 60.115b(c) 

shall be retained on site. 

4. Storage Tanks [35 IAC 219.122 and 129] 

Each affected liquid waste storage tank is subject to 35 IA C 219.129(f) and 35 IA C 

219.122(b). 

• The Permittee shall maintain readily accessible records of the dimension and 

analysis of the capacity of each affected liquid waste storage tank. 

• Each affected liquid waste storage tank should be equipped with a permanent 

submerged loading pipe. 

5. NESHAP for Benzene Waste Operations [40 CFR 61 Subpart FF] 

Veolia operates a hazardous waste TSD facility that manages benzene-containing 

hazardous waste as regulated by this subpart. Tanks containing benzene waste must be 

designed and operated as described in 40 CF R 61.343 and 61.349. Documentation and 

records as described in 40 CF R 61.356 shall be retained on site. 

6. NESHAP for Off-Site Waste and Recovery Operations [40 CF R 63 Subpart DD] 

Veolia is a waste management operation that receives off-site material and is regulated as 

a hazardous waste TSD facility. The National Emission Standards for Hazardous Air 

Pollutants from Off-Site Waste and Recovery Operations is applicable to the liquid waste 

storage tanks when only non-benzene waste is stored. The provisions of 40 CF R 

63.683(b)(2)(i) exempts the tanks from the control requirements of Subpart D D if such 

46 
units are subject to another subpart of 40 CFR Part 63 or part 61 and the HA P emissions 

are controlled. The tanks are subject to 40 CF R 61 Subpart FF for benzene-containing 

waste. 

7. Monitoring and Testing [40 CFR 71.6(a)(3)(i)(A) and (B)] 

The facility shall comply with the monitoring requirements established in 40 CFR 

61.354(d), the inspection requirements in 40 CF R 61.349(f)-(g), and the testing 

requirements of 40 CF R 61.349(c) and 61.355(h). 

If a breakthrough does not occur within 365 days of operation on a high Btu tank, the 

permittee must replace the carbon. If a breakthrough does not occur within 3 years of 

operation on a low Btu tank, the carbon must be replaced. 

The presence and condition of the submerged loading pipes from the top will be observed 

and documented during the quarterly inspections; with a physical inspection every five 

years. 

8. Recordkeeping [40 CF R 71.6(a)(3)] 

The following records must be maintained on site: 

• Total organic liquid wastes processed in gallons per month and gallons per year; 

• Average VOM/HA P content of received wastes, (percent by weight) 

• Average vapor pressure of received liquid wastes; 

• Records of the size (capacity) of the affected liquid wastes storage tanks; and 

• Records of all inspections performed. 

9. Organic Material Emissions [CP #88030001, Condition 3] 

Emissions of organic material from Tank Farm #3 shall not exceed 2.5 tons/year. 

I. Bulk Solid Waste Storage Facility Requirements 

Bulk solid waste is stored in four pits in the Bulk Feed Building. A clamshell moves solid 

wastes from the Bulk Feed Building to the Unit 4 incinerator. The building is equipped with 

a cyclone, a baghouse, and a carbon adsorption system. The regulations applicable to the 

emission unit are listed below. A listing of any non-applicable requirements and the reasons 

for the non-applicability are provided in Appendix B. 

1. Particulate Emission from Process Units for which Construction or Modification 

Commenced on or After April 14,1972 [35 IAC 212.321] 

The facility shall cause or allow the emission of particulate matter into the atmosphere in 

any one hour period from any new process emission unit which, either alone or in 

combination with the emission of particulate matter from all other similar process 

47 
emission units for which construction or modification commenced on or after April 14, 

1972, at a source or premises, exceeds the allowable emission rates specified in 

subsection 35 IA C 212.321(c). 

2. Use of Organic Material [35 IAC 219.301] 

Emission of organic material from this emission unit shall not exceed 8 lb/hr except as 

allowed by 35 IA C 219.302(b). If no odor nuisance exists, the limitation shall apply only 

to photochemically reactive material. 

3. Visible Emissions Limitations [35 IAC 212.123] 

Visible emissions from the unit shall not exceed 30% opacity, except that, for any eight 

one-minute periods in any one hour, the opacity may be greater than 30% but less than 

60%), provided that the opacity greater than 60% occurs at one emission unit limited to 3 

times within a 24-hour period. 

4. NESHAP for Benzene Waste Operations [40 CF R 61 Subpart FF] 

Veolia operates a hazardous waste TS D facility that manages benzene-containing 

hazardous waste as regulated by this subpart. This emission unit is defined as a tank 

within an enclosure. Units containing benzene waste must be designed and operated as 

described in 40 CF R 61.343 and 61.349. 

The bulk solid waste storage facility must be designed and operated in accordance with 

the criteria for a permanent total enclosure as specified in "Procedure T-Criteria for and 

Verification of a permanent or Temporary Total Enclosure" in 40 CF R 52.741, Appendix 

B. A n average facial velocity of at least 200 ft/minute flowing into the enclosure at all 

natural draft openings must be maintained. Annual verification testing must be 

performed in accordance with 40 CFR 61.343(e). 

5. NESHAP for Off-Site Waste and Recovery Operations [40 CF R 63 Subpart DD] 

Veolia is a waste management operation that receives off-site material and is 

regulated as a hazardous waste TSD facility. The National Emission Standards for 

Hazardous Air Pollutants from Off-Site Waste and Recovery Operations is applicable 

to the bulk solid waste storage facility. The provisions of 40 CF R 63.683(b)(2)(i) 

exempts the tanks from the control requirements of Subpart D D i f such units are 

subject to another subpart of 40 CFR Part 63 or part 61 and the HA P emissions are 

controlled. The unit is subject to 40 CFR 61 Subpart FF. 

6. Work Practice and Operational Requirements [40 CF R 71.6(a)(1)] 

• Except during times when bulk solid wastes are unloaded into the pits, all doors of the 

building shall be closed and all operations shall be enclosed inside the building. 

48 
• The enclosed building where bulk solid waste is accumulated shall be operated under 

permanent negative pressure. 

7. Monitoring and Testing [40 CFR 71.6(a)(3)(i)(A) and (B)] 

The facility shall comply with the monitoring procedures in 40 CF R 61.354(c), the 

inspection requirements in 40 CFR 349, and the testing requirements of 40 CFR 61.349 

and 61.355(h). 

A visual survey the Bulk Feed Building shall be performed each day for the presence of 

visible emissions or fugitive emissions of particulate matter. If visible emissions or 

fugitive emissions of particulate matter are observed the following procedures shall be 

followed: 

• Immediately, upon conclusion of the visual observation, investigate the source and 

reason for the presence of visible emissions or fugitive emissions; and 

• As soon as practicable, take appropriate corrective action. 

If the corrective actions undertaken do not eliminate the visible or fugitive emissions, a 

Method 9 test shall be conducted within 24 hours of the initial survey. If any of the 

visible emissions observations indicate visible emissions greater than 20% opacity, the 

Permittee shall conduct daily visible emissions observations, for thirty minutes, of the 

emission point in question until two consecutive daily observations indicate visible 

emissions of 20% opacity or less. If the Method 9 visible emissions observation, or if 

two consecutive daily observations, indicate visible emissions of 20% opacity or less, the 

Permittee shall conduct weekly visible emissions observations of the emission point for 

three additional weeks. 

8. Recordkeeping and Reporting [40 CFR 71.6(a)(3)] 

Records as described in 40 CF R 61.356(f) - (j) and (n) shall be maintained on site. 

In addition, the following records will be maintained on site: 

• Amount of accepted solid wastes, in tons per month and tons per year. 

• A log of maintenance and repair of air pollution control devices with the dates of 

service/repair made, and inspection conducted. 

• Records of the pressure being maintained inside the building. 

• Monthly and annual VOM/HA P emissions. Details of each visual survey or visible 

emissions observation, including date, time, observer and results for each emission 

unit and any other pollutant emitting activity. 

• Date, time, and type of any investigation conducted. 

• Findings of the investigation, including the reasons for the presence of visible 

emissions or fugitive emissions of particulate matter. 

• Date, time, and type of corrective actions taken. 

49 
• Results of any Method 9 visible emissions observations conducted on the source of 

visible or fugitive emissions. 

J . Drum Crusher Requirements 

Drums that are unsuitable for reuse are crushed by this emission unit. The regulations 

applicable to the emission unit are listed below. A listing of any non-applicable requirements 

and the reasons for the non-applicability are provided in Appendix B. 

1. Use of Organic Material [35 IAC 219.301] 

Emission of organic material from this emission unit shall not exceed 8 lb/hr. If no odor 

nuisance exists, the limitation shall apply only to photochemically reactive material. 

2. Particulate Matter Limitation [35 IAC 219.321] 

The emission of particulate matter into the atmosphere in any one-hour period from any 

new process emission unit, either alone or in combination with the emission of particulate 

matter from all other similar process emission units for which construction or 

modification commenced on or after April 14, 1972 at a source or premises, shall not 

exceed the allowable emission rates specified in subsection (c) of 35 IA C 212.321. 

3. Visible Emissions Limitations [35 IAC 212.123] 

Emission of smoke or other particulate matter shall not exceed an opacity greater than 

30%t, into the atmosphere from any emission source, except as allowed by 35 IA C 

212.123(b) and 212.124. 

4. Monitoring and Testing [40 CF R 71.6(a)(3)(i)(A) and (B)] 

A visual survey of the drum crusher shall be performed each day for the presence of 

visible emissions or fugitive emissions of particulate matter. If the observations 

conducted identify any visible emissions or fugitive emissions of particulate matter, the 

facility shall: 

• Immediately, upon conclusion of the visual observation, investigate the source 

and reason for the presence of visible emissions or fugitive emissions; and 

• As soon as practicable, take appropriate corrective action. 

If the corrective actions undertaken do not eliminate the visible or fugitive emissions, the 

facility shall, within 24 hours of the initial survey, conduct a test using EP A Reference 

Method 9 (see 40 CFR part 60, appendix A). If any of the visible emissions observations 

indicate visible emissions greater than 20% opacity, a Method 9 visible emissions 

observation shall be conducted of the emission point in question for thirty minutes each 

day, until two consecutive daily observations indicate visible emissions of 20%> opacity 

or less. If the Method 9 visible emissions observation or i f two consecutive daily 

50 
observations indicate visible emissions of 20% opacity or less, the facility shall conduct 

weekly visible emissions observations of the emission point for three additional weeks. 

5. Recordkeeping and Reporting [40 CF R 71.6(a)(3)] 

• Records of the total number of drums crushed (drums/hour and drums/year) for the 

drum crusher shall be maintained pursuant to 40 C.F.R. § 71.6(a)(i)(3)(B). 

• The facility shall calculate and keep records of VO M emissions from the drum 

crusher based on the emission factor equal to 0.0221 lb VOM/ 1 drum crushed. This 

emission factor is based on a characterization of the drum residue as containing the 

most prevalent organics at the concentrations present in the waste received during 

2007 - 2011. The maximum drum crushing rate is 40 drums per hour. 

• Records of the fugitive emissions shall be maintained including: details of each 

visual survey or visible emissions observation, including date, time, name of observer 

and results for each emission unit and any other pollutant emitting activity and date, 

time and type of any investigation conducted. 

K. Boiler Requirements 

One 10.46 million Btu per hour natural gas-fired boiler is located on-site. The existing boiler 

supplies heat and steam to the facility. The regulations applicable to the existing emission 

unit are listed below. A listing of any non-applicable requirements and the reasons for the 

non-applicability are provided in Appendix B. 

1. Fuel Combustion Emission Sources (> 10 MMBtu/hr) [35 IAC 216.121] 

Carbon monoxide emissions from this emission unit shall not exceed 200 ppm corrected 

to 50% excess air. 

2. Standards of Performance for Small Industrial-Commercial-Institutional Steam 

Generating Units [40 CFR 60 Subpart Dc] 

The facility shall record and maintain records of the amount of fuel combusted during 

each day. The owner or operator of an affected facility that only burns very low sulfur 

fuel oil or other liquid or gaseous fuels with potential sulfur dioxide emissions rate of 140 

ng/J (0.32 lb/MMBtu) heat input or less shall record and maintain records o f the fuels 

combusted during each calendar month. 

3. Visible Emissions Limitations [35 IAC 212.123] 

Emission of smoke or other particulate matter shall not exceed an opacity greater than 

30%o, into the atmosphere from any emission source, except as allowed by 35 IA C 

212.123(b) and 212.124. 

51 
4. Emission and Operational Limitations [CP# 95080025] 

Emissions and operation of this boiler shall not exceed the following limits: 

Operating Hours = 8,760 

N O x 1.46 lb/hr, 6.41 ton/yr 

C02. 1 lb/hr, 9.2 ton/yr 

Fuel = Natural Gas only at maximum of 7.6 mmscf/month and 91.1 mmscf/year. 

These limits are based upon the maximum firing rate for the boiler, and standard 

emission factors/ 

5. Emission Limitations [40 CFR 63.52] 

Emissions of C O from the boiler shall not exceed 100 ppm by volume on a dry basis 

corrected to 3%t oxygen. 

6. NESHAP Major Sources: Industrial, Commercial And Institutional Boilers and 

Process Heaters [40 CFR 63 Subpart DDDDD] 

Boiler #1 must meet the work practice standards listed below. 

• Performance of an annual tune-up addressing all regulated emissions. The tune-up 

shall include the following as described in 40 CFR 63.7540(10): 

1. Inspection of the burner, the flame pattern, and the air-to-fuel ratio controls 

for operation in accordance with manufacturer's specifications and 

performance of adjustments as necessary. 

2. Optimization of total C O emissions in coordination with NO x limitations. 

3. Measurement of C O concentrations and oxygen concentration in the boiler 

exhaust. 

4. Production of a written report documenting C O concentrations, corrective 

actions, and the amount of fuel combusted during the year. 

• Performance of a one-time energy assessment by a qualified energy assessor. 

• Submission of a Notification of Compliance Status within 60 days of the initial tuneup. The applicable information listed in 40 CFR 63.7545(e)(1) through (8) must be 

provided in the Notification of Compliance Status. 

• Submission of an Annual Compliance Report as described in 40 CFR 63.7550 by 

January 31s t of each year. 

7. Monitoring and Testing [40 CF R 71.6(a)(3)(i)(A) and (B)] 

• A n annual Method 9 test to ensure compliance with the opacity limit shall be 

performed. 

• A n annual tune-up in accordance with 40 CF R 63.7540 shall be performed. 

52 
8. Recordkeeping and Reporting [40 CFR 71.6(a)(3) and 40 CFR 63.7550(b) and 

40 CF R 63.7555] 

The following records must be maintained on site: 

• Monthly records of natural gas usage. 

• Annual records of natural gas usage (million square cubic feet per year. 

• Records of the results of the annual tune-up. 

• Documentation of the one-time energy assessment. 

A n annual compliance report must be submitted which contains: 

• Company and facility name and address. 

• Process unit information. 

• Statement by a responsible official with that official's name, title, and signature, 

certifying the truth, accuracy, and completeness of the content of the report. 

• Date of report and beginning and ending dates of the reporting period. 

• The total fuel use by the boiler, for each calendar month within the annual reporting 

period, including. 

• Date of the most recent tune-up and burner inspection. 

• The date and duration of the boiler startup, shutdown, and/or malfunction events 

during the reporting period. 

L . Emergency Generator Requirements 

Two emergency generators are located at the facility. They are stationary reciprocating 

internal combustion engines (RICE) with a site rating of less than 500 brake H P used only for 

emergency purposes that operate at a major source of HA P emissions. 

1. NESHAP for Stationary Reciprocating Internal Combustion Engines [40 CFR 

63 Subpart ZZZZ] 

The emergency RICE must comply with the requirements of 40 CFR 63.6640(f) in order 

to be considered emergency stationary RICE. These requirements are listed below. 

• For owners and operators of emergency engines, any operation other than emergency 

operation, maintenance, and testing, and operation in nonemergency situations for 50 

hours per year, as permitted in this section, is prohibited. 

• There is no time limit on the use of emergency stationary RICE in emergency 

situations. 

• The emergency stationary RICE may be operated for the purpose of maintenance 

checks and readiness testing, provided that the tests are recommended by federal, 

state, or local government; the manufacturer; the vendor; or the insurance company 

associated with the engine. Maintenance checks and readiness testing of such units is 

limited to 100 hours per year. The owner or operator may petition the Administrator 

for approval of additional hours to be used for maintenance checks and readiness 

53 
testing, but a petition is not required if the owner or operator maintains records 

indicating that federal, state, or local standards require maintenance and testing of 

emergency RICE beyond 100 hours per year. 

• The emergency stationary RICE may be operated up to 50 hours per year in nonemergency situations, but those 50 hours are counted toward the 100 hours per year 

provided for maintenance and testing. The 50 hours per year for non-emergency 

situations cannot be used for peak shaving or to generate income for a facility to 

supply power to an electric grid or otherwise supply power as part of a financial 

arrangement with another entity; except that owners and operators may operate the 

emergency engine for a maximum of 15 hours per year as part of a demand response 

program if the regional transmission organization or equivalent balancing authority 

and transmission operator has determined there are emergency conditions that could 

lead to a potential electrical blackout, such as unusually low frequency, equipment 

overload, capacity or energy deficiency, or unacceptable voltage level. The engine 

may not be operated for more than 30 minutes prior to the time when the emergency 

condition is expected to occur, and the engine operation must be terminated 

immediately after the facility is notified that the emergency condition is no longer 

imminent. The 15 hours per year of demand response operation are counted as part of 

the 50 hours of operation per year provided for nonemergency situations. The supply 

of emergency power to another entity or entities pursuant to financial arrangement is 

not limited by this paragraph (f)(4), as long as the power provided by the financial 

arrangement is limited to emergency power. 

2. Work Practice Standards [40 CFR 63.6602)] 

Each emergency RICE must comply with the following requirements. 

During normal operations: 

• Change oil and filter every 500 hours of operation or annually, whichever comes first; 

• Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first; 

• Inspect all hoses and belts every 500 hours of operation or annually, whichever comes 

first, and replace as necessary. 

• During startup, minimize the engine's time spent at idle and minimize the engine's 

startup time at startup to a period needed for appropriate and safe loading of the 

engine, not to exceed 30 minutes, after which time the non-startup emission 

limitations apply. 

Operate and maintain the stationary RICE and after-treatment control device (if any) 

according to the manufacturer's emission-related written instructions or develop and 

follow the facility's own maintenance plan, which must provide, to the extent practicable, 

for the maintenance and operation of the engine in a manner consistent with good air 

pollution control practice for minimizing emissions. 

Install a non-resettable hour meter i f one is not already installed. 

54 
3. Recordkeeping and Reporting [40 CF R 63.6655] 

Maintain the following records: 

• Description of each malfunction of operation/monitoring equipment; 

• Description of all maintenance performed; 

• Description of actions taken during malfunction to minimize emissions; 

• Description of corrective actions; 

• List of maintenance conducted to demonstrate that RICE was operated and 

maintained in accordance with the maintenance plan/manufacturer's 

recommendations; 

• The hours of operation as monitored by the non-resettable hour meter; and 

• Description of purpose of operation hours spent. 

Sources must report any failure to perform the work practices on the required schedule. 

M . Gasoline Storage Tanks 

1. Storage of Gasoline [35 IAC 219.122] 

The loading of any organic material in any stationary tank having a storage capacity of 

greater than 946 liters (250 gallons) shall not be allowed, unless such tank is equipped 

with a permanent submerged loading pipe or an equivalent device approved by the 

Agency according to the provisions of 35 IA C 201, and further processed consistent with 

35 IA C 219.108, or unless such tank is a pressure tank as described in 35 IAC 219,121 (a) 

or it fitted with a recovery system as described in 35 IA C 219.121(b)(2). 

2. Gasoline Dispensing Operations [35 IAC 219.583] 

The transfer of gasoline from any delivery vessel into the stationary storage tank at a 

gasoline dispensing operations shall not be allowed unless the tank is equipped with a 

submerged loading pipe. 

3. Recordkeeping and Reporting [40 CF R 71.6(a)(3)] 

Records retained for the storage tank include design information on the capacity of the 

tank and documents that confirm the presence of a permanent submerged loading pipe. 

In addition, an inspection, maintenance, and repair log or other records for the storage 

tank shall be maintained that, at a minimum, includes information related to any repair or 

replacement of the submerged loading pipe. 

55 
AIR EMISSIONS INFORMATION 

A. Insignificant Air Emission Sources 

This section identifies and describes the insignificant activities at the Veolia facility. The 

table below contains a list of the insignificant activities and the regulatory reference that 

exempts them from permitting requirements. 

Insignificant Emission Units 

Insignificant Emission Units Regulatory Citation 

2.5 mmBtu/hr Tioga portable boiler 35 IA C 270 Section 201.210(a)(4) 

Horizontal 550-gallon tank (Kerosene) 35 IA C 270 Section 201.210(a)(ll) 

Horizontal 550-gallon tank (No. 2 fuel oil) 35 IA C 270 Section 201.210(a)(ll) 

Horizontal 550-gallon tank (Gasoline) 35 IA C 270 Section 201.210(a)(ll) 

Horizontal 550-gallon tank (No. 2 fuel oil) 35 IA C 270 Section 201.210(a)(l 1) 

A s h Handling See Below Explanation 

Handling of spent dry scrubber solids (DSS) See Below Explanation 

Lime unloading (silo) and proportioning See Below Explanation 

Gasoline storage and dispensing See Below Explanation 

Use of absorbent (fugitive particulate 

generation) See Below Explanation 

General Vehicle maintenance and servicing, 

assumed to include diesel fuel handling 35 IA C 270 Section 201.210(b)(4) 

Laboratory (chemical and physical analysis) 35 IA C 270 Section 201.210(b)(l 1) 

Piping and storage system for natural gas 35 IA C 270 Section 201.210(b)(15) 

Non-halogenated cold cleaning degreasers 35 IA C 270 Section 201.210(b)(19) 

Internal combustion engines of motor vehicles 

(primarily forklifts) 35 IA C 270 Section 201.210(b)(24) 

Storage and handling of closed drums 35 IA C 270 Section 201.210(b)(26) 

The ash handling, handling of spent dry scrubber solids (DSS), lime unloading (silo) and 

proportioning, gasoline storage and dispensing, and use of absorbent (fugitive particulate 

generation) do not emit more than 1.0 lb/hr of any regulated air pollutant not listed as 

hazardous pursuant to Section 112(b) of the CA A in the absence of air pollution control 

equipment. They do not emit more than 0.1 lb/hr of any regulated air pollutant that is listed 

as hazardous pursuant to Section 112(b) of the CA A in the absence of air pollution control 

equipment; and none are process units. 

56 
B. List of Air Emission Sources with Regulatory Requirements 

Unit Name Unit Description 

Incineration Unit 2 

Fixed Hearth Incineration Unit used in the destruction of 

hazardous waste 

Incineration Unit 3 

Fixed Hearth Incineration Unit used in the destruction of 

hazardous waste 

Incineration Unit 4 

Rotary Kil n Incinerator (Transportable) used in the 

destruction of hazardous waste 

Material Processing Area 1 

Material processing/repackaging, repackaging of 

containerized solid waste 

Material Processing Area 2 

Material processing/repackaging, repackaging of 

containerized solid waste 

Lab Pack Repack 

Material processing/repackaging, repackaging of Lab 

Packs 

Drum Crusher Drums are crushed 

Bulk Feed Building 

Temporary storage of bulk solid wastes before being feed 

to Unit 4 

Boiler 1 Steam Boiler used for steam generation at plant 

Tank #2 4,931-gallon tank used for the storage of liquid waste 

Tank #4 4,931-gallon tank used for the storage of liquid waste 

Tank #6 7,200-gallon tank used for the storage of liquid waste 

Tank #8 5,820-gallon tank used for the storage of liquid waste 

Tank #10 12,869-gallon tank used for the storage o f liquid waste 

Tank #20 12,869-gallon tank used for the storage of liquid waste 

Tank #30 12,869-gallon tank used for the storage o f liquid waste 

Tank #40 12,869-gallon tank used for the storage of liquid waste 

Tank #50 12,869-gallon tank used for the storage o f liquid waste 

Tank #60 12,869-gallon tank used for the storage of liquid waste 

Tank #300 19,850-gallon tank used for the storage of liquid waste 

Tank #302 30,000-gallon tank used for the storage of liquid waste 

Tank #304 30,000-gallon tank used for the storage of liquid waste 

Tank #306 30,000-gallon tank used for the storage of liquid waste 

Tank #308 30,000-gallon tank used for the storage of liquid waste 

Tank #310 30,000-gallon tank used for the storage of liquid waste 

Tank #312 10,000-gallon tank used for the storage of liquid waste 

Tank #314 10,000-gallon tank used for the storage of liquid waste 

Tank #390 30,000-gallon tank used for storage of No. 2 Diesel Fuel 

57 
C. Emission Calculations 

The following are the emission calculations for all the significant sources at the plant. 

1. Unit 2 Incineration 

The actual emissions and potential emissions for Unit 2 are presented in the following 

table. The basis for each of the emission rates is provided also. The potential to emit 

(PTE) was calculated using emission testing infonnation, permit limits, and emission 

limitations in regulatory standards and 8,760 hours of operation. 

Unit 2 Emissions Summary 

Pollutant 

Actual 

Emission 

Rate 

(lbs/hr) 

Basis of Actual 

Emission Rate 

PTE 

(Lbs/hr) 

PTE 

(tons/yr) PTE Basis 

P M 0.0640 12/2009 CPT 0.5775 2.53 Based on HWCMACT 

Limit, 0.013 gr/dscf 

P M 1 0 0.0640 Same as P M 0.5775 2.53 Based on HWCMACT 

Limit, 0.013 gr/dscf 

P M 2. 5 0.0640 Same as P M 0.5775 2.53 Based on HWCMACT 

Limit, 0.013 gr/dscf 

HC1/C12 0.5612 12/2009 CPT 0.9117 3.99 Based on HWCMACT 

Limit, 32 ppmv 

N O x 2.51 2007 stack test Not available 4.0 Construction permit 

#88010001 

CO 0.045 CEMS 2.31 6.6 

Based on HWCMACT 

Limit, 100 ppmv 

Construction permit 

#87100024 

V O M 0.43 Max Feed & 

D RE 8.0 0.9 

Construction permit 

#87100024 

so2 4.00 0.1% Total 

Feed Not available 7.7 Construction permit 

#87100024 

Hg 0.0008 8/2008 CPT 0.0026 0.0114 Based on HWCMACT 

Limit, 130ug/m3 

As 0.00002 9/2008 CPT 0.0018 0.0081 Based on HWCMACT 

Limit, 92 ug/m3 

Be 0.0000017 9/2008 CPT 0.0018 0.0081 Based on HWCMACT 

Limit, 92 ug/m3 

Cd 0.000022 9/2008 CPT 0.0046 0.0202 Based on HWCMACT 

Limit, 230 ug/m3 

Cr 0.000069 9/2008 CPT 0.0018 0.0081 Based on HWCMACT 

Limit, 92 ug/m3 

Sb 0.00000342 6/2002 stack 

test 

0.00000342 0.000015 6/2002 stack test 

Pb 0.00028 9/2008 CPT 0.0046 0.0202 Based on HWCMACT 

Limit, 230 ug/m3 

N i 0.00000446 6/2002 stack 

test 

0.00000446 0.000020 6/2002 stack test 

Se 0.00000854 6/2002 stack 

test 

0.00000854 0.000037 6/2002 stack test 

Dioxin/Furan 

ng TEQ 7% 0 2 

0.00178 6/2012 Conf. 

Test 

4.38 x 10"9 1.92 x 10-8 Based on HWCMACT 

Limit, 0.20 ng/dscm TEQ 

58 
2. Unit 3 Incineration 

The actual emissions and potential emissions for Unit 3 are presented i n the following 

table. The basis for each of the emission rates is provided also. The PTE was calculated 

using emission testing information, permit limits, and emission limitations in regulatory 

standards and 8,760 hours of operation. 

Unit 3 Emissions Summary 

Pollutant 

Actual 

Emission 

Rate 

(lbs/hr) 

Basis of Actual 

Emission Rate 

PTE 

(Lbs/hr) 

PTE 

(tons/yr) PTE Basis 

P M 0.0708 12/2009 CPT 0.5775 2.53 Based on HWCMACT Limit, 

0.013 gr/dscf 

P M 1 0 0.0708 Same as P M 0.5775 2. 53 Based on HWCMACT Limit, 

0.013 gr/dscf 

P M 2. 5 0.0708 Same as P M 0.5775 2.53 Based on HWCMACT Limit, 

0.013 gr/dscf 

HC1/C12 

0.3989 12/2009 CPT 0.9340 4.09 Based on HWCMACT Limit, 

32 ppmv 

N O x 2.51 2007 stack test Not available 4.0 Construction permit 

#88010001 

CO 0.0250 CEMS 2.31 6.6 

Based on HWCMACT Limit, 

100 ppmv 

Construction permit #87100024 

V O M 0.43 Max Feed & DRE 8.0 0.9 

Construction permit 

#87100024 

so2 

4.00 0.1% Total Feed Not available 7.7 Construction permit #87100024 

Hg 0.0008 8/2008 CPT 0.0026 0.0114 Based on HWCMACT Limit, 

130 ug/m3 

As 0.00002 9/2008 CPT 0.0018 0.0081 Based on HWCMACT Limit, 

92 ug/m3 

Be 0.0000019 9/2008 CPT 0.0018 0.0081 Based on HWCMACT Limit, 

92 ug/m3 

Cd 0.0000054 9/2008 CPT 0.0046 0.0202 Based on HWCMACT Limit, 

230 ug/m3 

Cr 0.000278 9/2008 CPT 0.0018 0.0081 Based on HWCMACT Limit, 

92 ug/m3 

Sb 0.00000342 6/2002 stack test 0.00000342 0.000015 6/2002 stack test 

Pb 0.000824 9/2008 CPT 0.0046 0.0202 Based on HWCMACT Limit, 

230 ug/m3 

N i 0.00000446 6/2002 stack test 0.00000446 0.000020 6/2002 stack test 

Se 0.00000854 6/2002 stack test 0.00000854 0.000037 6/2002 stack test 

Dioxin/Furan 

ng TEQ 7% 02 0.00068 6/2012 Conf. Test 4.56 x 10"9 2.00 x 10"8 Based on HWCMACT Limit, 

0.20 ng/dscm TEQ 

3. Unit 4 Incineration 

The actual emissions and potential emissions for Unit 4 are presented i n the following 

table. The basis for each of the emission rates is provided also. The potential to emit 

(PTE) was calculated using emission testing information, permit limits, and emission 

limitations in regulatory standards and 8,760 hours of operation. 

59 
Unit 4 Emissions Summary 

Pollutant 

Actual 

Emission 

Rate 

(lbs/hr) 

Basis of Actual 

Emission Rate 

PTE 

(Lbs/hr) 

PTE 

(tons/yr) PTE Basis 

P M 0.4416 12/2009 CPT 1.63 7.15 Based on HWCMACT Limit, 

0.013 gr/dscf 

P M 1 0 0.4416 Same as P M 1.63 7.15 Based on HWCMACT Limit, 

0.013 gr/dscf 

P M 2. 5 0.4416 Same as P M 1.63 7.15 Based on HWCMACT Limit, 

0.013 gr/dscf 

HC1/C12 2.34 12/2009 CPT 2.64 11.57 Based on HWCMACT Limit, 32 

ppmv 

NOx 9.14 2007 stack test 

Not 

available 

61.6 Construction permit 

#88010001 

CO 0.115 CEMS 6.52 13.86 

Based on HWCMACT Limit, 100 

ppmv 

Construction permit #88010001 

V O M 1.48 Max Feed & 

D RE 8.0 3.1 Construction permit 

#88010001 

so2 3.69 0.1% Total 

Feed 

Not 

available 

50.76 Construction permit #88010001 

Hg 0.0012 8/2008 CPT 0.0073 0.0319 Based on HWCMACT Limit, 130 

ug/m3 

As 0.00026 9/2008 CPT 0.0052 0.0226 Based on HWCMACT Limit, 92 

ug/m3 

Be 0.0000051 9/2008 CPT 0.0052 0.0226 Based on HWCMACT Limit, 92 

ug/m3 

Cd 0.0000287 9/2008 CPT 0.0129 0.0564 Based on HWCMACT Limit, 230 

ug/m3 

Cr 0.000135 9/2008 CPT 0.0052 0.0226 Based on HWCMACT Limit, 92 

ug/m3 

Sb 0.0000111 2/2002 stack 

test 

0.0000111 0.0000486 6/2002 stack test 

Pb 0.00109 9/2008 CPT 0.0129 0.0564 Based on HWCMACT Limit, 230 

ug/m3 

N i 0.0000110 2/2002 stack 

test 

0.0000110 0.0000482 6/2002 stack test 

Se 0.0000277 2/2002 stack 

test 

0.0000277 0.000121 6/2002 stack test 

Dioxin/Furan 

ng TEQ 7% 02 0.195 6/2012 Conf. 

Test 

1.38 x 10"8 6.05 x 10"8 Based on HWCMACT Limit, 0.20 

ng/dscm TEQ 

4. Existing Boiler 

A l l boiler emission factors are taken from the AP-42 - Section 1.4 Natural Gas 

Combustion. Actual emissions are based on natural gas burned in 2012. PT E is based on 

maximum hourly heat input into the boiler and 8,760 hours per year of operation. The 

table below contains all emission factors and emission rates. 

60 
Existing Boiler Emissions Summary 

Maximum Hourly Heat Input: 10.6 MMBtu/hr (90.15 mmscf/hr) 

Actual Natural Gas Usage 2012: 86.83 mmscf/yr 

Emission Actual 

Factor Emissions P TE P TE 

Pollutant (lb/mmscf) (tons/yr) (lb/hr) (tons/yr) 

C O 84 3.65 0.864 3.79 

V O M 5.5 0.239 0.057 0.248 

N O x 100 4.34 1.03 4.51 

P M 2. 5 7.6 0.330 0.078 0.343 

P M 1 0 7.6 0.330 0.078 0.343 

P M 7.6 0.330 0.078 0.343 

s o 2 0.6 0.026 0.006 0.027 

N H 3 3.2 0.139 0.033 0.144 

5. Lab Pack Repack Building (LPR) 

The LP R building emission factor is based on exposure monitoring data collected in the 

area during normal operations. This emission factor is multiplied by the hours of 

operation in 2012 to give an estimate of the actual emission rate and multiplied by 8,760 

hours per year of operation to give the potential to emit. 

V O M Actual Emission = 0.3321 (lbs/hr) x 6440 (hrs) / 2000 = 1.07 tons/year 

V O M PT E = 0.3321 (lbs/hr) x 8760 (hrs) / 2000 = 1.45 tons/year 

Benzene Actual Emission = 0.0552 (lbs/hr) x 6440 (hrs) / 2000 = 0.1777 tons/year 

Benzene PT E = 0.0552 (lbs/hr) x 8760 (hrs) / 2000 = 0.2418 tons/year 

6. Material Processing Area 1 (MP-1) 

The MP-1 building emission factor is based on exposure monitoring data collected in the 

operations area during normal operations. This emission factor is multiplied by the hours 

of operation in 2012 to give an estimate of the actual emission rate and multiplied by 

8,760 hours per year of operation to give the PTE. 

V O M Actual Emission = 0.0545 (lbs/hr) x 7310 (hrs) / 2000 = 0.1992 tons/year 

V O M PT E = 0.0545 (lbs/hr) x 8760 (hrs) / 2000 = 0.2387 tons/year 

Benzene Actual Emission = 0.0113 (lbs/hr) x 7310 (hrs) / 2000 = 0.0413 tons/year 

Benzene PT E = 0.0113 (lbs/hr) x 8760 (hrs) / 2000 = 0.0495 tons/year 

61 
7. Material Processing Area 2 (MP-2) 

The MP- 2 building emission factor is based on exposure monitoring data collected in the 

operations area during normal operations. This emission factor is multiplied by the hours 

of operation in 2012 to give an estimate of the actual emission rate and multiplied by 

8,760 hours per year of operation to give the PTE. 

V O M Actual Emission = 0.0545 (lbs/hr) x 5230 (hrs) / 2000 = 0.1425 tons/year 

V O M PTE = 0.0545 (lbs/hr) x 8760 (hrs) / 2000 = 0.2387 tons/year 

Benzene Actual Emission = 0.0113 (lbs/hr) x 5230 (hrs) / 2000 = 0.0295 tons/year 

Benzene PTE = 0.0113 (lbs/hr) x 8760 (hrs) / 2000 = 0.0495 tons/year 

8. Bulk Solids Storage 

The bulk solids storage building emission factor is based on monitoring data collected in 

the storage and handling area. This emission factor is multiplied by the hours of 

operation in 2012 to give an estimate of the actual emission rate and multiplied by 8,760 

hours per year of operation to give the PTE. 

V O M Actual Emission = 0.5836 (lbs/hr) x 8760 (hrs) / 2000 = 2.56 tons/year 

V O M PTE = 0.5836 (lbs/hr) x 8760 (hrs) / 2000 = 2.56 tons/year 

Benzene Actual Emission = 0.0043 (lbs/hr) x 8760 (hrs) / 2000 = 0.0188 tons/year 

Benzene PT E = 0.0043 (lbs/hr) x 8760 (hrs) / 2000 = 0.0188 tons/year 

9. Drum Crusher 

Actual Emissions 

Emissions - Volatile Organic Material (VOM) 

Basis: 

Veolia has collected data for the five years since the permit was issued including: 

the number of containers crushed, the type of volatile constituents likely to be in 

container residue, and the amount of these volatile constituents processed on an 

annual basis. A new VO M emission factor was calculated utilizing this data from 

actual operations. The container residue was characterized as containing the top 

organics at their overall concentrations in the waste received in 2007 - 2011. The 

remainder of the waste was represented as water and inert solids. This approach 

yielded a VO M emission factor of 0.0221 pounds VO M per drum crushed. With 

a maximum crushing rate of 40 drums per hour, the PTE for the drum crusher was 

62 
calculated to be 0.8833 pounds VO M per hour and 3.87 tons VO M per year. The 

detailed calculations are provided below. 

Drums crushed per year = 350,400 (40 drums /hour, 8,760 hours/year 

V O M Emission Factor Calculation for Drum Crusher 

Emission Factor = Summation of Pounds VO M from Column I below 

= 0.0221 pounds per drum 

Maximum rate of crushing = 40 drums per hour 

Maximum VO M emission rate = 0.0221 x 40 = 0.8833 pounds VO M per hour 

Maximum annual VO M rate = 0.8833 x 179/2,000 = 0.0790 tons VO M per 

year 

63 
Vessel Contents Analysis Vessel volume (ft3) = 7.3524 R = 998.9 (mmHg)(ft3)/(lbmole)(K) 

Assumptions: 

1. Each container contents is uniformly representative of the overall waste mixture received at the plant. 

2. The overall waste mixture at the plant is characterized by the top organic constituents in waste received for 2007 - 2011. 

A B C D E F G H I J 

VOC 

MW 

(lb/lbmole) 

Weight 

(lbs) lbmoles Xi Psati Pi 

Vapor 

(lbmoles) 

Vapor 

(lbs) Comments 

acetonitrile 41.05 3,361,228 81,881 0.0100 86.37 0.86 0.00002 0.00087 

acrylonitrile 53.1 804,316 15,147 0.0018 105.83 0.20 4.83E-06 0.00026 

atrazine 215.68 356,148 1,651 0.0002 0.00 0.00 1.44E-15 3.10E-13 

cyanide compounds 27.03 138,879 5,138 0.0006 1.00 0.00 1.55E-08 4.19E-07 

ethylbenzene 106.17 633,274 5,965 0.0007 9.51 0.01 1.71E-07 0.00002 

hydrazine 32.05 180,238 5,624 0.0007 10.00 0.01 1.69E-07 0.00001 

methanol 32.04 6,070,501 189,466 0.0231 126.94 2.93 0.00007 0.00232 

methyl isobutyl 

ketone 100.16 3,042,483 30,376 0.0037 19.28 0.07 1.77E-06 0.00018 

methyl tert-butyl 

ether 88.15 405,413 4,599 0.0006 273.71 0.15 3.79E-06 0.00033 

n-butyl alcohol 74.12 1,503,986 20,291 0.0025 6.16 0.02 3.77E-07 0.00003 

n-hexane 86.18 747,614 8,675 0.0011 151.54 0.16 3.96E-06 0.00034 

nitrate compounds 84.99 181,239 2,132 0.0003 0.00 0.00 0.00E+00 0.00E+00 None in vapor 

pthalic anhydride 148.1 154,635 1,044 0.0001 0.00 0.00 0.00E+00 0.00E+00 None in vapor 

pyridine 79.1 169,554 2,144 0.0003 45.09 0.01 2.91E-07 0.00002 

styrene 104.15 1,915,487 18,392 0.0022 6.18 0.01 3.43E-07 0.00004 

toluene 92.13 8,657,468 93,970 0.0115 28.44 0.33 0.00001 0.00074 

triethylamine 101.2 850,752 8,407 0.0010 67.78 0.07 1.72E-06 0.00017 

xylene 106.17 2,328,688 21,934 0.0027 8.30 0.02 5.49E-07 0.00006 

as ethanol 46.07 93,612,150 2,031,955 0.2479 59.16 14.67 0.00036 0.01669 

Avg volatility for 

smaller amounts 

V O M in waste 

as water 18.02 93,612,150 5,194,903 0.6339 23.69 15.01 0.00037 0.00668 

solids (as lead) 207.2 93,612,150 451,796 0.0551 None in vapor 

64 
Potential-To-Emit (PTE) 

Emissions - Volatile Organic Material (VOM) 

V O M Emission Factor Calculation for Drum Crusher 

Emission Factor = Summation of Pounds VO M from Column I 

= 0.0221 pounds per drum 

Maximum rate of crushing = 40 drums per hour 

Maximum VO M emission rate = 0.0221 x 40 = 0.8833 pounds VO M per hour 

Maximum annual VO M rate = 0.8833 x 8,760/2,000 = 3.87 tons VO M per year 

P TE VO M emissions from drum crushing operations = 3.87 ton VOM/y r 

10. Tanks 

A l l the tanks emit both VO M and benzene. The actual VO M emissions are those reported in 

the Annual Air Emissions Report for 2012. The VO M and benzene PTEs were calculated from 

the emission factor detennined using 2012 emission rates and throughputs. The emission factor 

was then multiplied times the maximum hourly throughput to yield the potential VO M 

emissions in pounds per hour; and then converted to tons per year using 8,760 hours per year. 

Tank Emissions Summary 

Tank 

Number 

Pollutant 

Actual 

Emissions 

2012 

(lb/yr) 

2012 

Throughput 

(103 gals/yr) 

Emission 

Factor 

(lbs/103 

gals) 

P TE 

(Lb/hr) 

P TE 

(Ton/yr) 

Tank #2 

V O M 1.58 

602 

0.0026 0.0052 0.0230 

Tank #2 

Benzene 0.0015 

602 

2.49E-06 4.98E-06 2.18E-05 

Tank #4 

V O M 1.73 

602 

0.0029 0.0057 0.0252 

Tank #4 

Benzene 0.017 

602 

2.82E-05 5.65E-05 2.47E-04 

Tank #6 

V O M 2.76 

3061 

0.0009 0.0018 0.0079 

Tank #6 

Benzene 0.0027 

3061 

8.82E-07 1.76E-06 7.73E-06 

Tank #8 

V O M 2.81 

2461 

0.0011 0.0023 0.0100 

Tank #8 

Benzene 0.0027 

2461 

1.10E-06 2.19E-06 9.61E-06 

Tank #10 

V O M 10.68 

500 

0.0214 0.0427 0.1871 

Tank #10 

Benzene 0.0104 

500 

2.08E-05 4.16E-05 1.82E-04 

Tank #20 

V O M 1.12 

310 

0.0036 0.0072 0.0316 

Tank #20 

Benzene 0.0011 

310 

3.55E-06 7.10E-06 3.11E-05 

Tank #30 

V O M 2.33 

79 

0.0295 0.0590 0.2584 

Tank #30 

Benzene 0.0023 

79 

2.91E-05 5.82E-05 2.55E-04 

65 
Tank Emissions Summary 

Tank 

Number 

Pollutant 

Actual 

Emissions 

2012 

(lb/yr) 

2012 

Throughput 

(103 gals/yr) 

Emission 

Factor 

(lbs/103 

gals) 

P TE 

(Lb/hr) 

P TE 

(Ton/yr) 

Tank #40 

V O M 2.42 

657 

0.0037 0.0074 0.0323 Tank #40 

Benzene 0.0023 

657 

3.50E-06 7.00E-06 3.07E-05 

Tank #50 

V O M 0.7650 

764 

0.0010 0.0020 0.0088 

Tank #50 

Benzene 0.0007 

764 

9.46E-07 1.83E-06 8.03E-06 

Tank #60 

V O M 5.55 

950 

0.0058 0.0117 0.0512 

Tank #60 

Benzene 0.0054 

950 

5.68E-06 1.14E-05 4.98E-05 

Tank #300 

V O M 1.90 

580 

0.0033 0.0066 0.0287 

Tank #300 

Benzene 0.0018 

580 

3.10E-06 6.21E-06 2.71E-05 

Tank #302 

V O M 11.74 

543 

0.0216 0.0432 0.1894 

Tank #302 

Benzene 0.0114 

543 

2.10E-05 4.20E-05 1.84E-04 

Tank #304 

V O M 2.81 

434 

0.0065 0.0130 0.0567 

Tank #304 

Benzene 0.0027 

434 

6.22E-06 1.24E-05 5.45E-05 

Tank #306 

V O M 5.28 

466 

0.0113 0.0227 0.0993 

Tank #306 

Benzene 0.0051 

466 

1.09E-05 2.19E-05 9.59E-05 

Tank #308 

V O M 8.99 

355 

0.0253 0.0506 0.2218 

Tank #308 

Benzene 0.0087 

355 

2.45E-05 4.90E-05 2.15E-04 

Tank #310 

V O M 8.27 

282 

0.0293 0.0587 0.2569 

Tank #310 

Benzene 0.0080 

282 

2.84E-05 5.67E-05 2.48E-04 

Tank #312 

V O M 7.71 

192 

0.0402 0.0803 0.3517 

Tank #312 

Benzene 0.0075 

192 

3.91E-05 7.81E-05 3.42E-04 

Tank #314 

V O M 4.64 

192 

0.0242 0.0483 0.2117 

Tank #314 

Benzene 0.0045 

192 

2.34E-05 4.69E-05 2.05E-04 

COMPLIANCE METHODS 

A. Continuous Emission Monitors 

The continuous emissions monitoring (CEM) system consists of sample probes, sample delivery 

and conditioning apparatus, and gas analyzers. Each incinerator is equipped with a CEMS, which 

consists of the following major components: 

• Heated stack sample probe 

• Heated traced umbilical 

• Heated sample pump 

• EcoChem MC 3 multicomponent infrared (IR) gas analyzer 

• Zirconium oxide-based oxygen analyzer 

• System controller and data acquisition system 

Samples are extracted from the stack at Units 2 and 3 and the transition ducting located between 

the scrubber and stack at Unit 4. The Continuous Emission Monitoring System Quality Assurance 

66 
Plan contains detailed information about the operation and maintenance of the CE M systems at the 

facility. A copy of the most current plan is provided in Appendix D. Responses from each CEM S 

are fed to the Control System (CS). The system controller controls the sampling system 

temperatures, purge/blowback, calibration checks, data handling, messaging, and alarms. The 

CEM S controller is integrated with the incinerator data acquisition system, automatic waste feed 

cutoff (AWFCO ) system and the main control system. 

B. Process Parameter Monitoring 

Veolia monitors a number of process parameters for the purpose of demonstrating on-going 

compliance with regulatory requirements and permit conditions. Continuous monitoring devices 

equipped with data logging allow Veolia to calculate, record, and view values for process 

parameters that are regulated. Operation, maintenance, and data handling procedures are described 

in the Continuous Monitoring System Quality Control Program. A copy of the most recent 

program is provided i n Appendix D. Descriptions of the parameters monitored and the 

instrumentation used is provided below. 

1. Mass/Feedrate Monitors 

Liquid waste feedrates from tanks are measured by coriolis mass flowmeters. Direct inject 

liquid feedrates from the tanker truck are calculated using the continuously monitored weight 

of the tanker. Al l solid waste charges are weighed using a scale/load cell prior to being fed to 

the incinerator. These measurements are used to calculate pumpable waste, total waste, and 

constituent feedrates. 

For Unit 4, the output of a calibrated feeder is utilized to calculate the feedrate of powdered 

activated carbon, which is injected into the plenum upstream of the baghouses. 

2. Pressure/Differential Pressure Monitors 

Primary combustion chamber pressure is measured by diaphragm-actuated pressure 

transmitters. The position of the damper immediately upstream of the induced-draft fan is 

varied to control stack gas flowrate and to maintain kiln combustion chamber negative pressure 

(draft). The primary combustion chamber pressure is interlocked with waste feeds. 

For Units 2 and 3, pressure drop in the cylinder gas feedstream is measured and converted to a 

feedrate. The feedrate is used to calculate this feedstream's contribution to the chlorine, lowvolatile metals, and semi-volatile metals feedrates to the incinerator. 

For Unit 4, pressure switches are utilized to ensure that the carbon feeder discharge pressure 

and the carbon injection air blower discharge pressure are within the design limits. 

The pressure drop across a pitot tube in the stack is continuously monitored and used to 

calculate the stack gas flowrate. 

67 
3. Temperature Monitors 

For Units 2 and 3, redundant thermocouples are used to measure the temperature in both 

combustion chambers. A thermocouple is also located at the exit to the SD A and is the primary 

element for the SD A exit temperature control loop. 

Unit 4 is equipped with redundant pyrometers in the primary chamber and redundant 

thermocouples in the secondary chamber. Each SD A outlet is equipped with redundant 

thermocouples used for temperature control and monitoring of the baghouse inlet temperature. 

4. Emergency Safety Vent Position Monitors 

The position of the emergency safety vent is indicated as open or closed by a position 

transmitter. No waste or fuel can be fed if the emergency safety vent position is "open." The 

Emergency Safety Vent Plan provides details on the emergency safety vent systems. 

5. Bag Leak Detection System 

A triboelectric sensor is located downstream of the induced draft fan that monitors the relative 

particulate matter loading of the combustion gas exiting the baghouses. Alarms and interlocks 

based on this relative measurement are indications of a potential bag leak or failure. 

Procedures for setup and adjustments to the bag leak detection system are not covered by this 

quality control program. The Operation and Maintenance Plan provides details on the bag leak 

detection system. 

C. Demonstration of Compliance with Applicable Requirements 

The methods for demonstrating compliance with the applicable requirements identified i n Section 

IV of this application are described in the following table. 

68 
EMISSION 

UNIT ID(S) 

APPLICATION 

REFERENCE 

FOR 

APPLICABLE 

REQUIRMENT CITATION COMPLIANCE METHOD 

Hazardous Waste Combustors: Emission Standard Requirements 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.B.l.a 35 IAC 212.123(a) Monitoring/Recordkeeping - Continuous opacity monitors and recording devices. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.B.l.b 35 IAC 212.301 Work Practices - Standard operations at the facility are designed to avoid the 

generation of fugitive particulate emissions. Surfaces are paved and kept free of 

material that could generate particulate. Material handling operations are enclosed 

processes designed to minimize particulate emissions to the atmosphere. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.B.2.a Construction Permits 

#87100024 and #88010001 

Recordkeeping - Emissions are calculated on an annual basis using test results, 

monitoring data, engineering calculations and standard emission factors. Records 

of these calculations are maintained onsite. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.B.3.a 40 CFR 63.1219(a)(5) Monitoring/Recordkeeping - Continuous emission monitor and recording device. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.B.3.b Construction Permits 

#83120053,#87100024 and 

#88010001 

Monitoring/Recordkeeping - Continuous emission monitor and recording device. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.B.3.C Construction Permits 

#87100024 and #88010001 

Recordkeeping - Emissions are calculated on an annual basis using test results, 

monitoring data, engineering calculations and standard emission factors. Records 

of these calculations are maintained onsite. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.B.4.a 35 IAC 212.181(b) Testing/Monitoring/Recordkeeping - Compliance with NESHAP for Hazardous 

Waste Combustors as referenced in Section B.4.b below. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.B.4.b 40 CFR 63.1219(a)(7) Testing/Monitoring/Recordkeeping - CPT to establish OPLs as provided in most 

recent NOC (Appendix E). 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.B.4.C Construction Permits 

#87100024 and #88010001 

Recordkeeping - Emissions are calculated on an annual basis using test results, 

monitoring data, engineering calculations and standard emission factors. Records 

of these calculations are maintained onsite. 

ncinerators: 

Jnit2, Unit 3, 

Unit 4 

Section rV.B.5.a 35 IAC 219.301 and 219.302 Testing/Monitoring/Recordkeeping - Compliance with NESHAP for Hazardous 

Waste Combustors DRE requirement of at least 99.99% destruction provides for 

compliance with this requirement. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section FV.B.5.b Construction Permits 

#87100024 and #88010001 

Recordkeeping - Emissions are calculated on an annual basis using test results, 

monitoring data, engineering calculations and standard emission factors. Records 

of these calculations are maintained onsite. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.B.6.a Construction Permits 

#87100024 and #88010001 

Recordkeeping - Emissions are calculated on an annual basis using test results, 

monitoring data, engineering calculations and standard emission factors. Records 

of these calculations are maintained onsite. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.B.7.a 40 CFR 63.1219(a)(1) Testing/Monitoring/Recordkeeping - CPT to establish OPLs as provided in most 

recent NOC (Appendix E). 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.BJ.b 40 CFR 63.1219(a)(2) Testing/Monitoring/Recordkeeping - CPT to establish OPLs as provided in most 

recent NOC (Appendix E). 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.B.7.C 40 CFR 63.1219(a)(3) Testing/Monitoring/Recordkeeping - CPT to establish OPLs as provided in most 

recent NOC (Appendix E). 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.B.7.d 40 CFR 63.1219(a)(4) Testing/Monitoring/Recordkeeping - CPT to establish OPLs as provided in most 

recent NOC (Appendix E). 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.B.7.e 40 CFR61.348(a)(l)(iii) Testing/Monitoring/Recordkeeping - Compliance with NESHAP for Hazardous 

Waste Combustors DRE requirement of at least 99.99% destruction provides for 

compliance with this requirement. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.B.7.f 40 CFR 63.689(c)(2) The design of all transfer systems subject to this rule calls for welded joints for 

continuous hardpiping. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.B.8.a 40 CFR 63.1219(a)(6) Testing/Monitoring/Recordkeeping - CPT to establish OPLs as provided in most 

recent NOC (Appendix E). 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.B.8.b Construction Permits 

#83120053 and #87100024 

Testing/Monitoring/Recordkeeping - Compliance with NESHAP for Hazardous 

Waste Combustors HCl emissions limitations provides for compliance with this 

requirement. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.B.9.a 40 CFR 63.1219(c)(1) Testing/Monitoring/Recordkeeping - CPT to establish OPLs as provided in most 

recent NOC (Appendix E). 

69 
EMISSION 

UNIT ID(S) 

APPLICATION 

REFERENCE 

FOR 

APPLICABLE 

REQUIRMENT CITATION COMPLIANCE METHOD 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.B.9.b 40 CFR 63.1219(c)(2) Recordkeeping - The facility does not accept dioxin-listed hazardous waste in their 

waste streams for combustion. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.B.9.C 40 CFR 63.1219(c)(3) Testing/Monitoring/Recordkeeping - CPT to establish OPLs as provided in most 

recent NOC (Appendix E). 

Hazardous Waste Combustors: Work Practice and Operational Requirements 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.C.l.a 40 CFR63.1206(a)&(b), 

63.1209G) through (p) 

Testing/Monitoring/Recordkeeping - CPT to establish OPLs as provided in most 

recent NOC (Appendix E). NOC submittal to agency. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section rV.C.l.b 40 CFR 63.1206(c)(1), 

63.1211(c) 

Recordkeeping - a Documentation of Compliance (DOC) has been developed and 

is maintained in the facihty operating record. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.C.l.c 40 CFR 63.1206(c)(2), 

63.6(e)(3) 

SSMP developed, implemented and maintained in accordance with 40 CFR 63.6 

and 63.1206(c)(2). 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.C.l.d 40 CFR 63.1206(c)(3) 35 IAC 

201.149 

AWFCO system in operation for all three incinerators. Hazardous waste feed is 

shutoff according to procedures specified in the faculty's Automatic Waste Feed 

Cutoff Plan. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.C.l.e 40 CFR 63.1206(c)(4) ESV operating plan developed, implemented and is maintained in the operating 

record of the facility. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.C.l.f 40 CFR 63.1206(c)(5) Testing/Monitoring/Recordkeeping - CPT to establish OPLs as provided in most 

recent NOC (Appendix E). 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section rV.C.l.g 40 CFR 63.1206(c)(6) Training Program and Operator Certification Program developed, implemented 

and is maintained. Records of training and operator certification retained on site. 

Incinerators: 

T

Jnit2,Unit3, 

Jnit4 

Section PV.C.l.h 40 CFR 63.1206(c)(7), 63.6(e) An Operation and Maintenance Plan has been developed, implemented and 

maintained in the operating records on site. 

Hazardous Waste Combustors: Monitoring and Testing Requirements 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.D. 1.a 40CFR63.1209(a)(l)(i) Continuous CO monitor and data acquisition system (DAS). THC testing during 

CPT. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.D.l.b 40CFR63.1209(a)(l)(iii) Will install and operate continuous PM CEMS when required. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.D.l.c 40 CFR 63.1209(a)(2), (a)(3) 

and (a)(4) 

CEMS and COMs installed, calibrated, maintained and continuously operated in 

accordance with the performance specifications in this rule. CEMS & COMS 

QA/QC Plan developed, implemented and maintained to reflect these 

requirements. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.D.l.d 40 CFR 63.1209(a)(5), 63.8(f) Not applicable. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.D.l.e 40 CFR 63.1209(a)(6) Rolling averages from CEMS, COMS data are calculated by the DAS in 

accordance with this requirement. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.D.2.a 40 CFR 63.1209(b)(1), (b)(2) CMS installed, calibrated, maintained and continuously operated as described in 

most recent NOC (Appendix E). CMS QA/QC Plan developed, implemented and 

maintained to reflect these requirements. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.D.2.b 40 CFR 63.1209(b)(3) CMS installed, calibrated, maintained and continuously operated as described in 

most recent NOC (Appendix E). CMS QA/QC Plan developed, implemented and 

maintained to reflect these requirements. 

incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.D.2.C 40 CFR 63.1209(b)(4) CMS installed, calibrated, maintained and continuously operated as described in 

most recent NOC (Appendix E). CMS QA/QC Plan developed, implemented and 

maintained to reflect these requirements. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.D.2.d 40 CFR 63.1209(b)(5) Rolling averages from CMS data are calculated by the DAS in accordance with 

this requirement. 

Incinerators: 

Unit 2, Unit 3, 

Jnit 4 

Section IV.D.3 40 CFR 63.1206(c)(8) BLDS installed, maintained and continuously operated. CMS QA/QC Plan 

developed, implemented and maintained to reflect these requirements. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.D.4 40 CFR 63.1209(c) FAP developed, implemented and maintained to reflect these requirements. 

70 
EMISSION 

UNIT ID(S) 

APPLICATION 

REFERENCE 

FOR 

APPLICABLE 

REQUIRMENT CITATION COMPLIANCE METHOD 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.D.5 40 CFR 63.1209(d), 63.8(d), 

6..8(e) 

CMS installed, calibrated, maintained and continuously operated as described in 

most recent NOC (Appendix E). CMS QA/QC Plan developed, implemented and 

maintained to reflect these requirements. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.D.6 40 CFR 63.1209(e), 63.8(b) CMS installed, calibrated, maintained and continuously operated as described in 

most recent NOC (Appendix E). CMS QA/QC Plan developed, implemented and 

maintained to reflect these requirements. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.D.7 40 CFR63.1209(f), 63.8(c) CMS installed, calibrated, maintained and continuously operated as described in 

most recent NOC (Appendix E). CMS QA/QC Plan developed, implemented and 

maintained to reflect these requirements. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section rV.D.8 40 CFR 63.1209(h), 63.8(g) CMS installed, calibrated, maintained and continuously operated as described in 

most recent NOC (Appendix E). CMS QA/QC Plan developed, implemented and 

maintained to reflect these requirements. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.D.9 40 CFR 63.1209(i), 63.8(b) Testing/Monitoring/Recordkeeping - CPT to establish OPLs as provided in most 

recent NOC (Appendix E). NOC submittal to agency. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.D.10 40 CFR63.1209(r) Testing/Monitoring/Recordkeeping - CPT to establish OPLs as provided in most 

recent NOC (Appendix E). NOC submittal to agency. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.E.l 40CFR63.1206(b)(5)(i)(B) Changes to a source are evaluated during planning. A new CPT will be performed 

and NOC submitted if indicated. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.E.2 40 CFR 63.1206(b)(6) Testing/Monitoring/Recordkeeping - CPT to establish OPLs as provided in most 

recent NOC (Appendix E). 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.E.3 40 CFR 63.1207(b) Testing - CPT to establish OPLs as provided in most recent NOC (Appendix E). 

Confkmatory testing conducted for dioxin/furan standard as provided in most 

recent NOC. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section PV.E.4 40 CFR 63.1207(d) Testing - CPT to establish OPLs as provided in most recent NOC (Appendix E). 

Confirmatory testing conducted for dioxin/furan standard as provided in most 

recent NOC. 

ncinerators: 

Jnit2, Unit 3, 

Unit 4 

Section rV.E.5.a 40 CFR 63.1207(f)(1), 

63.7(c)(2) 

CPT plans submitted for approval prior to test with contents as described in 

regulations. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.E.5.b 40 CFR 63.1207(f)(2), 

63.7(c)(2) 

Confirmatory test plans submitted for approval prior to test with contents as 

described in regulations. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.E.6.a 40 CFR 63.1207(g)(a), 63.7(e) Testing - CPT to establish OPLs as provided in most recent NOC (Appendix E). 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section rV.E.6.b 40 CFR63.1207(g)(b), 63.7(e) Corifirmatory testing conducted for dioxin/furan standard as provided in most 

recent NOC. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.E.7 40 CFR 63.1207(h) Performance test plans submitted for approval prior to test. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.E.8 40 CFR 63.1208 Performance test plans submitted for approval prior to test using prescribed test 

methods. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.E.9.a 40 CFR 63.1207(1)(1) Procedures will be followed for hazardous waste burning if failure to demonstrate 

compliance occurs. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.E.9.b 40 CFR 63.1207(1)(2) Procedures will be followed for hazardous waste burning if failure to demonstrate 

compliance occurs. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.E.9.C 40 CFR 63.1207(1)(2) Procedures will be followed for hazardous waste burning if failure to demonstrate 

compliance occurs. 

Hazardous Waste Combustors: Recordkeeping and Reporting Requirements 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section rV.F.l 40 CFR 63.1210(a) Notifications will be submitted as required. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.F.2 40 CFR 63.1211(a) Reports will be prepared and submitted as required. 

Incinerators: 

Unit 2, Unit 3, 

Unit 4 

Section IV.F.3 40 CFR 63.1211(b) Records required by the regulations, by the plans utilized at the facility and by 

standard operating procedures will be retained on site for at least five years. 

71 
EMISSION 

UNIT ID(S) 

APPLICATION 

REFERENCE 

FOR 

APPLICABLE 

REQUIRMENT CITATION COMPLIANCE METHOD 

Waste Procesing Units: Requirements 

Waste Processing: 

MP-1, MP-2, LPR 

Section rV.G.l 35 IAC 212.123(a) Monitoring/Recordkeeping - Routine visible emissions observations. 

Waste Processing: 

MP-1, MP-2, LPR 

Section IV.G.2 35 IAC 219.301 Recordkeeping - VOM emission rate calculations. 

Waste Processing: 

MP-1, MP-2, LPR 

Section IV.G.3 40 CFR63.683(b)(l)(i), 

63.688(a) 

Veolia controls air emissions from containers in accordance with Container Level 

1 requirements. 

Waste Processing: 

MP-1, MP-2, LPR 

Section IV.G.4 40 CFR 63.922 Veolia controls air emissions from containers in accordance with Container Level 

1 requirements and facility SOPs. 

Waste Processing: 

MP-1, MP-2, LPR 

Section IV.G.5 40 CFR 63.925, 

71.6(a)(3)(i)(A) 

Veolia controls air emissions from containers in accordance with Container Level 

1 requirements and facility SOPs. 

Waste Processing: 

MP-1, MP-2, LPR 

Section rV.G.6 40 CFR 71.6(a)(3) Veolia controls air emissions from containers in accordance with Container Level 

1 requirements and facility SOPs. 

Waste Processing: 

MP-1, MP-2, LPR 

Section IV.G.7 40 CFR 61 Subpart FF Standard work practices as reflected in SOPs are followed for containers of 

benzene-containing waste. 

Waste Processing: 

MP-1, MP-2, LPR 

Section IV.G.8 40 CFR71.6(a)(3)(i)(B) VOM/HAP emission calculations performed and recorded using TANKS program. 

Liquid Waste Storage Tanks: Requirements 

Liquid Waste 

Storage Tanks 

Section rV.H.l 35 IAC 219.301 Recordkeeping - VOM emission rate calculations. 

Liquid Waste 

Storage Tanks 

Section TV.H.2 36 IAC 219.142 LDAR program including inspections, monitoring and corrective actions has been 

implemented. 

Liquid Waste 

Storage Tanks 

Section IV.H.3 40 CFR 60.112b Closed vent system and control device installed and operated for Tanks 300, 302, 

304,306, 308 and 310. 

Liquid Waste 

Storage Tanks 

Section IV.H.4 40 CFR63.115b(c),35 IAC 

219.122 and 219.129 

Each tank is equipped with permanent submerged loading pipe and records are 

retained as to the design of the tank. 

liquid Waste 

Storage Tanks 

Section IV.H.5 40 CFR 61 Subpart FF Standard work practices as reflected in SOPs are followed for tanks. 

Liquid Waste 

Storage Tanks 

Section IV.H.6 40 CFR 63 Subpart DD Standard work practices as reflected in SOPs are followed for tanks and equipment 

leaks. 

Liquid Waste 

Storage Tanks 

Section IV.H.7 40 CFR71.6(a)(3)(i)(A)and 

(B) 

Testing/monitoring/inspection of carbon adsorption system will be conducted. 

Liquid Waste 

Storage Tanks 

Section IV. H. 8 41 CFR 71.6(a)(3) Records will be retained on site for at least five years. 

Liquid Waste 

Storage Tanks 

Section IV.H.9 Construction Permit 88030001 VOM emission calculations performed and recorded. 

Bulk Solid Waste Storage Facility: Requirements 

Bulk Feed 

Building 

Section rV.I.l 35 IAC 212.321 PM emission calculations performed and recorded . 

Bulk Feed 

Building 

Section IV.I.2 35 IAC 219.301 Recordkeeping - VOM emission rate calculations. 

Bulk Feed 

Building 

Section IV.I.3 35 IAC 212.123(a) Monitoring/Recordkeeping - Routine visible emissions observations. 

Bulk Feed 

Building 

Section IV. 1.4 40 CFR 61 Subpart FF Standard work practices as reflected in SOPs are followed for tanks. 

Monitoring/testing to verify operation as a Totally Enclosed Unit. Closed-vent 

system and control device installed and maintained. 

Bulk Feed 

Building 

Section LV.I.5 40 CFR 63 Subpart DD Standard work practices as reflected in SOPs are followed for tanks and equipment 

leaks. 

Bulk Feed 

Building 

Section IV.I.6 40 CFR 71.6(a)(1) SOPs for enclosed operation, negative pressure. 

Bulk Feed 

Building 

Section LV.I.7 40 CFR71.6(a)(3)(i)(A)and 

(B) 

Testing/monitoring/inspection of carbon adsorption system will be conducted. 

Routine visible emissions observations are performed and documented. 

Bulk Feed 

Building 

Section IV.I.8 40 CFR 71.6(a)(3) Records will be retained on site for at least five years. 

Drum Crusher: Requirements 

Drum Crusher Section IV.J.l 35 IAC 219.301 Recordkeeping - VOM emission rate calculations. 

Drum Crusher Section IV.J.2 35 IAC 212.321 PM emission calculations performed and recorded. 

Drum Crusher Section IV.J.3 35 IAC 212.123(a) Monitoring/Recordkeeping - Routine visible emissions observations. 

72 
EMISSION 

UNIT ID(S) 

APPLICATION 

REFERENCE 

FOR 

APPLICABLE 

REQUIRMENT CITATION COMPLIANCE METHOD 

Drum Crusher SectionIV.J.4 40CFR71.6(a)(3)(i)(A)and 

(B) 

Routine visible emissions observations are performed and documented. 

Drum Crusher SectionIV.J.5 40 CFR 71.6(a)(3) Records will be retained on site for at least five years. 

Boiler: Requirements 

Boiler Section FV.K.l 35 IAC 216.121 Monitoring with CO CEMS and recordkeeping. 

Boiler Section rV.K.2 40 CFR Subpart Dc Recordkeeping of fuel combusted. 

Boiler Section IV.K.3 35 IAC 212.123(a) Monitoring/Recordkeeping - Routine visible emissions observations. 

Boiler Section IV.K.4 Construction permit 95080025 NOx, CO emission rate calculations for annual operating hours. 

Boiler Section TV.K.5 40 CFR 63.52 Monitoring with CO CEMS and recordkeeping. 

Boiler Section IV.K.6 40 CFR 63 Subpart DDDDD Work practices for annual tune-up, one-time energy assessment, submission of 

NOC and annual compliance report. 

Boiler Section IV.K.7 40 CFR71.6(a)(3)(i)(A)and 

(B) 

Annual visible emissions tests are performed and documented. 

Boiler Section TV.K.8 40 CFR 71.6(a)(3) Records will be retained on site for at least five years. A semiannual compliance 

report will be submitted. 

Emergency Generators: Requirements 

Emergency 

Generators 

Section IV.L.l 40 CFR 63 Subpart ZZZZ Record of the hours of operation will be retained. 

Emergency 

Generators 

Section IV.L.2 40 CFR 63.6602 Work practice procedures for maintenance, inspection and idle operation will be 

followed. 

Emergency 

Generators 

Section IV.L.3 40 CFR 71.6(a)(3) Records will be retained on site for at least five years. A semiannual compliance 

report will be submitted. 

Gasoline Storage Tank: Requirements 

Gasoline Tank Section IV.M.l 35 IAC 219.122 The tank is equipped with a submerged loading pipe. 

Gasoline Tank Section TV.M.2 35 IAC 219.583 The tank is equipped with a submerged loading pipe. 

jasoline Tank Section TV.M.3 40 CFR 71.6(a)(3) Records will be retained on site for at least five years. 

73 
VII. RECORDKEEPING AND REPORTING 

Veolia monitors and records multiple operating parameters that are part of the operating 

record. The Continuous Emissions Monitoring System (CEMS) being utilized at incinerator 

Units 2, 3, and 4 includes measurement of the combustion gas oxygen, carbon monoxide, 

hydrocarbon, and hydrogen chloride concentrations; opacity; and gas velocity. The table 

below summarizes the analyzer specifications. If performance or stack tests are required to 

be conducted in the future, Veolia will record and report testing results as described in the 

appropriate test plan. Prior to any testing activities, 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. Records of such activities will be 

retained. 

Recorded Operating Parameters for Incinerators 

Parameter Current Manufacturer Range Principle 

Oxygen COSA 0-25% Electrochemical 

Carbon 

Monoxide 

Ecochem MC3 0-200 ppmv 

0-3000 ppmv 

Infrared 

Total 

hydrocarbons 

TheimoElectro (Unit 2) 

Compur FID (Unit 3 & 4) 0-100 ppmv FID/Infrared 

Hydrogen 

chloride 

Ecochem MC3 0-1000 ppmv Infrared 

Opacity Teledyne 0-100% White light 

Stack Flow PSE 0-20,000 acfm (Unit 2 & 3) 

0-55,000 acfm (Unit 4) Pressure drop 

A. Recordkeeping 

Veolia records information as required by the Hazardous Waste Combustor MAC T standard, 

40 CFR 63. Unit 2, 3, 4, Material Processing Areas 1 and 2, Bulk Feed Building, Lab Pack 

Repack Area, and all tanks used for the storage of liquid waste are subject to requirements of 

40 CF R 61 Subpart FF (Benzene NESHAP). In addition to the general recordkeeping 

requirements summarized in the following tables, these units comply with all applicable 

recordkeeping requirements as required by 40 CF R 61 Subpart FF. 

74 
Recorded Operating Parameters 

63.1200, 63.10(b) and (c) 

General. Information required to document and maintain compliance 

with the regulations of subpart EEE, including data recorded by 

continuous monitoring systems (CMS), and copies of all 

notifications, reports, plans, and other documents submitted to the 

Administrator. 

63.1206(b)(5)(ii) Documentation that a change will not adversely affect compliance 

with the emission standards or operating requirements. 

63.1206(b)(ll) Calculation of hazardous waste residence time. 

63.1206(c)(2) Startup, shutdown, and malfunction plan. 

63.1206(c)(2)(v)(A) Documentation of your investigation and evaluation of excessive 

exceedances during malfunctions. 

63.1206(c)(3)(v) 

Corrective measures for any automatic waste feed cutoff that results 

in an exceedance of an emission standard or operating parameter 

limit. 

63.1206(c)(3)(vii) Documentation and results of the automatic waste feed cutoff 

operability testing. 

63.1206(c)(4)(ii) Emergency safety vent operating plan. 

63.1206(c)(4)(iii) Corrective measures for any emergency safety vent opening. 

63.1206(c)(5)(ii) Method used for control of combustion system leaks. 

63.1206(c)(6) Operator training and certification program. 

63.1209(c)(2) Feedstream analysis plan. 

63.1209(q) Documentation of changes in modes of operation. 

63.1211(c) Documentation of compliance. 

The following operating parameters for Units 2, 3, and 4 are automatically recorded every 15 

seconds into the computer system. 

Recorded Operating Parameters Units 2 and 3 

Data Recorded Related to Operating Parameter 

Primary Combustion Chamber Temperature 

Primary Combustion Chamber 

Temperature 

Secondary Combustion Chamber Temperature 

Secondary Combustion Chamber 

Temperature 

Stack 02 Corrected C E M 

Stack CO Corrected C E M 

Stack Opacity C E M 

Stack Flow Stack Flow Rate 

Spay Dryer Adsorber Outlet Temp Baghouse Inlet Temperature 

Pumpable Hazardous Waste Feed Pumpable / Total Waste Feed Rate 

Solid Hazardous Waste Feed Pumpable / Total Waste Feed Rate 

Hazardous Waste Chlorine Content Chlorine Feed Rate 

Hazardous Waste Arsenic, Beryllium and 

Chromium Content Low Volatile Metals Feed Rate 

75 
Recorded Operating Parameters Units 2 and 3 

Hazardous Waste Cadmium and Lead Content Semi Volatile Metals Feed Rate 

Hazardous Waste Mercury Content Mercury Feed Rate 

Ash Content of Hazardous Waste Ash Feed Rate 

Recorded Operating Parameters Unit 4 

Data Recorded Related to Operating Parameter 

Primary Combustion Chamber Temperature 

Primary Combustion Chamber 

Temperature 

Secondary Combustion Chamber Temperature 

Secondary Combustion Chamber 

Temperature 

Stack 0 2 Corrected C E M 

Stack CO Corrected C E M 

Stack Opacity C E M 

Stack Flow Stack Flow Rate 

Spray Dryer Absorber Outlet Temperature Baghouse Inlet Temperature 

Pumpable Hazardous Waste Feed Pumpable / Total Waste Feed Rate 

Solid Hazardous Waste Feed Pumpable / Total Waste Feed Rate 

Hazardous Waste Chlorine Content Chlorine Feed Rate 

Hazardous Waste Arsenic, Beryllium and 

Chromium Content 

Low Volatile Metals Feed Rate 

Hazardous Waste Cadmium and Lead 

Content 

Semi Volatile Metals Feed Rate 

Hazardous Waste Mercury Content Mercury Feed Rate 

Ash Content of Hazardous Waste Ash Feed Rate 

Carbon Injection Flow Carbon Injection Feed Rate 

Additional Recordkeeping 

Recorded Parameter Method Frequency 

Units 2,3 and 4 

Various - See tables above Computer System / CE M Every 15 Seconds 

Inspection As Required by 40 CFR 61 Subpart FF Quarterly 

Inspection Certification Quarterly 

Spray Dryer Absorber (SDA) for Unit 2, SDA for Unit 3 and SDA for Unit 4 

Chlorine Feed Programmable Logic Controller Per Charge 

Outlet Temperature Thermocouple Continuous 

Inlet Temperature Thermocouple Continuous 

H Cl Extractive NDIR Continuous 

Lime Flow Magnetic Continuous 

Baghouse for Unit 2, Baghouse for Unit 3 and Baghouse for Unit 4 

Stack Gas Flow Annubar Flowmeter Continuous 

Pressure Drop Delta P Transmitter Continuous 

Opacity White Light Monitor Continuous 

76 
Additional Recordkeeping 

Material Processing Area 1 and Material Processing Area 2 

Throughput Operations Log Daily 

Lab Pack Repack 

Throughput Operations Log Daily 

Drum Crusher 

Throughput Waste Tracking Continuous 

Bulk Feed Building 

Work Practices / 

Operations 

Visual Inspection and Inspection Log Daily 

System Condition Visual Inspection Quarterly 

Inspection As Required by 40 CFR 61 Subpart FF Quarterly 

Inspection Certification Quarterly 

Carbon Adsorption System for Bulk Feed Building 

Exhaust VO M EPA Method 21 per 40 CFR 61 Subpart 

FF Daily 

System Condition 

Inspection 

Visual Inspection per 40 CFR 61 

Subpart FF Quarterly 

Inspection Certification Quarterly 

Boiler 1 

Amount and Type of Fuel 

Used Natural Gas Meter Monthly 

Startup, Shutdown 

Malfunction time and 

duration 

Operating record Per Occurrence 

Tune-up Records Maintenance records and Report Annual 

Energy Assessment Report Once 

Tank 2, 4, 6, 8,10, 20, 30,40, 50, 60 

Throughput Waste Tracking Continuous 

Carbon Canister 2, 4, 6, 8,10, 20,30, 40, 50, 60 

Exhaust VO M E PA Method 21 20% design carbon 

replacement interval 

Condition of Closed Vent 

System 

Visual Inspection Quarterly 

Inspection As Required by 40 CFR 61 Subpart FF Quarterly 

Inspection Certification Quarterly 

Tank 300,302,304,306, 308, 310, 312, 314 

Throughput Waste Tracking Continuous 

Condition of Closed Vent 

System 

Visual Inspection Quarterly 

Carbon Canister 300, 302,304, 306,308,310, 312,314 

Exhaust VO M E PA Method 21 20% design carbon 

replacement interval 

Condition of Closed Vent 

System 

Visual Inspection Quarterly 

77 
Additional Recordkeeping 

Inspection As Required by 40 CFR 61 Subpart FF Quarterly 

Inspection Certification Quarterly 

Tank 390 

Throughput Supplier invoices Purchase frequency 

Emergency Generators 

Hours of operation and 

description of use 

Non-resettable hour meter Per Occurrence 

Startup, Shutdown 

Malfunction time and 

duration 

Operating record and maintenance 

records 

Per Occurrence 

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

operational and prevent breakdowns and failures. 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, P M activity, and the incinerator's shutdown schedule. 

B. Reporting Requirements 

Veolia reports information as required by the Hazardous Waste Combustor MAC T standard, 

40 CF R 63. Unit 2, 3, 4, Material Processing Area 1 and 2, Bulk Feed Building, Lab Pack 

Repack Area and all tanks that are used for the storage of liquid waste are also subject to 

requirements of 40 CFR 61 Subpart FF (Benzene NESHAP). In addition to the general 

reporting requirements summarized in the following tables, these units comply with all 

applicable reporting requirements as required by 40 CF R 61 Subpart FF. 

General Reporting Requirements 

Reference Report 

63.10(d)(4) Compliance progress reports, if required as a condition of an 

extension of the compliance date granted under Sec. 63.6(i). 

63.10(d)(5)(i) Periodic startup, shutdown, and malfunction reports. 

63.10(d)(5)(h) Immediate startup, shutdown, and malfunction reports. 

63.10(e)(3) Excessive emissions and continuous monitoring system 

performance report and summary report. 

63.1206(c)(2)(ii)(B) Startup, shutdown, and malfunction plan. 

63.1206(c)(3)(vi) Excessive exceedances reports. 

63.1206(c)(4)(iv) Emergency safety vent opening reports. 

Reporting Requirements 

Reporting Requirement Report Title Frequency 

Unit 2, Unit 3 and Unit 4 

Emission Inventory Annual Emissions Report Annual 

Visual Inspections and 

Monitoring 

Quarterly inspection certification as 

Required by 40 CFR 61 Subpart FF Quarterly 

78 
Reporting Requirements 

Inspection as required by 

40 CFR 61.357 Annual Inspection Summary Annual 

Lab Pack Repack 

Emission Inventory Annual Emissions Report Annual 

Drum Crusher 

Emissions Inventory Annual Emissions Report Annual 

Material Processing Area 1 and Material Processing Area 2 

Emission Inventory Annual Emissions Report Annual 

Bulk Feed Building 

Inspections as required by 

40 CFR 61.357 Annual Inspection Summary Annual 

Emissions Inventory Annual Emissions Report Annual 

Visual Inspections and 

Monitoring 

Quarterly inspection certification as 

Required by 40 CFR 61 Subpart FF Quarterly 

Carbon Adsorption System for Bulk Feed Building 

Inspections as required by 

40 CFR 61.357 Annual Inspection Summary Annual 

Visual Inspections and 

Monitoring 

Quarterly inspection certification as 

Required by 40 CFR 61 Subpart FF Quarterly 

Boiler 1 and Proposed Boiler 2 

Emission Inventory Annual Emissions Report Annual 

Compliance Report Annual Compliance Report Annual 

Tank 2,4, 6, 8,10, 20,30, 40, 50, 60 

Emission Inventory Annual Emissions Report Annual 

Inspections as required by 

40 CFR 61.357 Annual Inspection Summary Annual 

Visual Inspections and 

Monitoring 

Quarterly inspection certification as 

Required by 40 CFR 61 Subpart FF Quarterly 

Carbon Canister 2, 4, 6, 8,10, 20,30, 40, 50, 60 

Inspections as required by 

40 CFR 61.357 Annual Inspection Summary Annual 

Visual Inspections and 

Monitoring 

Quarterly inspection certification as 

Required by 40 CFR 61 Subpart FF Quarterly 

Tank 300,302,304,306, 308, 310,312,314 

Emission Inventory Annual Emissions Report Annual 

Inspections as required by 

40 CFR 61.357 Annual Inspection Summary Annual 

Visual Inspections and 

Monitoring 

Quarterly inspection certification as 

Required by 40 CFR 61 Subpart FF Quarterly 

Carbon Canister 300,302, 304, 306,308,310, 312,314 

Inspections as required by 

40 CFR 61.357 Annual Inspection Summary Annual 

Visual Inspections and 

Monitoring 

Quarterly inspection certification as 

Required by 40 CFR 61 Subpart FF Quarterly 

Tank 390 

Emissions Inventory Annual Emissions Report Annual 

79 
Veolia reports to the IEPA each occurrence of an AWFC O due to the combustion zone 

pressure being greater than allowable setpoints when evidence of visible emissions during the 

AWFC O exists. In addition, any failure to perform the work practice standards for the 

emergency generators will be reported. 

80