Statement ofBasis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia FS Technical Solutions, L.L.C, Sauget, Illinois 

Date Issued: October 10, 2014 Page 59 of 79 

C The CPT demonstrates compliance only for the particular 

combination of wastes incinerated and combustion conditions 

at the time of the test. 

Even though Veolia's October 2013 comprehensive performance tests 

demonstrated compliance with the HWC MACT emissions limits at each of the 

three incinerators, the tests cannot guarantee that Veolia will be in compliance 

with the emissions limits under different combustion conditions or when burning 

a different mix of wastes. As discussed above, there are a variety of possible 

reasons that the test results for Units 2 and 3 differed despite the similarity of the 

two units. For similar reasons, any of the three units may be out of compliance 

when different mixes of waste are incinerated or when combustion conditions 

differ from that achieved during the October 2013 tests. The temporary use of 

multi-metals CEMS will allow Veolia to ascertain under what conditions it 

remains in compliance. Further, the use ofthe CEMS will allow Veolia to vary 

its feedstream or incinerator parameters if it discovers that it is violating 

emissions limits while burning different combinations of waste under varying 

conditions. 

5.3.4. Availability of Multi-Metals CEMS 

Multi-metals CEMS are commercially available and have been demonstrated to 

be reliable for measuring metal emissions from a commercial hazardous waste 

combustor. In addition, EPA has monitored side-by-side evaluations of multimetals CEMS with EPA Method 29 of Appendix A-8 to 40 C.F.R. Part 60 at 

industrial waste incinerators and found good correlation between the two 

methods. 75 Fed. Reg. 31962 (June 4, 2010). Moreover, though not specifically 

required, EPA considers multi-metals CEMS as an accepted option for metals 

emission compliance in the recently promulgated mercury and air toxics (MATS) 

rule. 77 Fed. Reg. 9303 (February 16, 2012). 

EPA recently evaluated at several facilities a commercial version of a multimetals CEMS (the XactTM multi-metals CEMS), which is capable of measuring 

up to 20 or more HAP metals in real time. The XactTM multi-metals CEMS was 

developed and is being marketed by Cooper Environmental Services, LLC (10180 

SW Nimbus Avenue, Suite J6, Portland, Portland, Oregon 97223).51 The system 

uses reel-to-reel filter tape sampling technology followed by X-ray fluorescence 

(XRF) analysis of metals in the deposit. The process begins when an isokinetic 

sub-sample of stack gas is taken from the stilling chamber and drawn through a 

chemically-reactive filter tape. Vapor phase metals, including mercury, are 

deposited on the reactive filter tape along with the particulate matter. The 

Prior to March 2013, the XactTM was being marketed by Pall Corporation (25 Harbor Park Drive, Port 

Washington, New York 11050); however, Cooper Environmental Services now holds the exclusive manufacturing 

and marketing rights for the XactTM. 

VES017300 
Statemenl ofBasis for DRAFT Title V Pennit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C, Sauget, Illinois 

Date Issued: October 10, 2014 Page 60 of 79 

resulting deposit is then automatically advanced and analyzed by XRF for 

selected metals while the next sample is being collected. The XRF sample 

analysis technique does not destroy the sample, which allows for possible sample 

archiving and re-analysis at a later time. 5 2 '

5 3

 The XactTM multi-metals CEMS 

can measure up to 20 or more metals simultaneously including arsenic, cadmium, 

chromium, mercury, and lead.54 The system reports analytical results every 15 

minutes in the units of the MACT standards (pg/dscm).55 

Cooper Environmental Services has also developed and received EPA approval 

for a Quantitative Aerosol Generator (QAG), which generates a reference aerosol 

for calibrating the multi-metals CEMS and for performing relative accuracy test 

audits (RATAs) of the multi-metals CEMS. 5 6 Yanca et al. evaluated both the 

XactTM and the QAG using a modified EPA Method 301 at a hazardous waste 

combustor by comparing measured and reference aerosol concentrations. The 

authors found that both the XactTM and the QAG met the Method 301 validation 

criteria with precisions and accuracies on the order of 5 percent over a wide range 

of concentrations.57 

In 2006, Eli Lilly and Company received approval from EPA to use a multimetals CEMS as an alternative to operating parameter monitoring at the Eli Lilly 

Tippecanoe Laboratories manufacturing facility near Lafayette, Indiana. Eli Lilly 

successfully installed and certified the XactTM multi-metals CEMS, and operated 

it for at least six years, on a 50 mmBtu/hr rotary kiln hazardous (solid and liquid) 

waste incinerator at its facility from 2005 until 20IO.58 Eli Lilly used the XactTM 

s

 Hay, K.J. , Johnsen, B.E. , and Cooper, J.A. (2005). X-Ra y Fluorescence-Based Multi-jMetal Continuous Emission 

Monitor: Development. Final Report ERDC/CER L TR-05-3, January 2005. Available at: 

http://www.dtic.mil/dtic/tr/fulltext7u2/a430237.pdf (accessed October 16, 2012). 

5 3

 Yanca, C.A. , Barth, D.C , Petterson, K.A. , Nakanishi, M.P. , Cooper, J.A., Johnsen, B.E. , Lambert, R.H. , and 

Bivins, B.G . (2006). Validation of Three New Methods for Determination of Metal Emissions Using a Modified 

Environmental Protection Agency Method 301. Journal of the Air & Waste Management Association, 56: 1733-

1742. 

5 4

 Lambert, R. and Foster, M . (2011). El i Lilly's Experience Using a Multi-Metals Continuous Emission Monitoring 

System. Available at: http://events.awma.org/it3201 l/presentations/SESSION%2014/14-

3%20Lillv's%20Experience%20with%20Using%20the%20Xact%20Multi-Metals%20Monitoring%20Svstem.pdf 

(accessed October 17, 2012) 

5 5

 Cooper Environmental Services reports that the XactTM multi-metals CEM S can be used at waste incinerators 

(hazardous, sewage, municipal, medical, industrial), cement kilns, lime kilns, foundries, coal-fired power plants, 

industrial furnaces and boilers, primary and secondary metal smelters, etc. The unit has been tested at hazardous 

waste incinerators, coal-fired boilers, wet and dry stacks and 50 ppm acid gases. See 

iittp:.//cooperenvironmental.com/wp-cuntent/uploads/2010/ll/20IO-Xact-640-l:'resentation-at-the-AWMASvmposium-on-Air-Oualitv-Measurement-Methods-and-Technology.pdf (Slide 37). In one test case at a coal-fired 

power plant, the XactTM was installed and operating within 2 days. 

S f ' http://cooperenvironmental.com/wp-content/uploads/2010/01/QAG-820-Data-Sheet.pdf 

1 7

 Yanca et al. (2006). 

i R

 Eli Lilly's stack gases at the Tippecanoe facility averaged approximately 8 percent moisture content and 140 "F 

ivhile the multi-metals CEM S was being operated. However, Cooper Environmental Services has assured EP A that 

trial tests on its CEM S demonstrate that the unit can operate reliably at moisture contents above 40 percent. 

VES017301 
Statemenl ofBasis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Pennittee: Veolia ES Technical Solutions, L.L.C, Sauget, Illinois 

Date Issued: October 10, 2014 Page 61 of 79 

multi-metals CEMS in conjunction with a PM and HCI CEMS. 5 9- Evonik 

Degussa Corporation purchased the Tippecanoe facility in 2010 and continued to 

operate the PM, HCI and, for a brief period, the multi-metals CEMS for 

monitoring compliance with Ihe HWC MACT. 6 1 

Cooper Environmental Services has also recently signed agreements with the 

South Coast Air Quality Management District (SCAQMD) and a Texas company 

to supply two multi-metals CEMS units.62 The SCAQMD will operate one 

multi-metals CEMS at a secondary lead smelter in southern California for a 

period of at least 10 months beginning in December 2014. According to Cooper, 

the Texas company expects to begin operating the CEMS at its facility in Nigeria 

in mid-summer 2014. 

Several additional multi-metals CEMS are under development, including several 

efforts focused on laser-based atomic emission spectroscopy (AES), microwave 

AES and spark-based AES. 5 3 However, EPA is not aware that any of these other 

technologies are cunently commercially available. 

5.3.5. Performance Specifications for the Multi-Metals CEMS 

Although performance specifications for multi-metals CEMS have not yet been 

subjected to a formal rulemaking process, EPA has published specifications and 

quality assurance procedures for the multi-metals CEMS in its website as OTM 

16 (Specifications and Test Procedures for X-ray Fluorescence Based MultiMetals Continuous Emission Monitoring Systems at Stationary Sources) and 

OTM 20 (Quality Assurance Requirements for X-Ray-Fluorescence Based MultiMetals Continuous Emission Monitoring Systems at Stationary Sources).64

 As 

5 9

 Lambert, R. and Foster, M . (2011). As part of El i Lily's experience with the multi-metals CEMS , Eli Lill y in 

conjunction with EP A prepared a number of technical documents that are now posted on the OAQP S methods web 

site as Other Test Methods. See http://www.epa.eov/ttn/emc/prelim.html 

s o

 The U.S. Army has also successfully installed and evaluated a multi-metals CEM S on one of its hazardous waste 

incinerators. Hay et al. (2005). EP A also understands that the U.S. Department of Defense has purchased three 

XactTM units for use at army munitions incinerators. Finally, multi-metals CEM S are an accepted option for metals 

emission compliance in the utility mercury and air toxics (MATS ) mle that was recently promulgated by EPA . See 

40 C.F.R. § 63.1O010(j). 

1

 EPA's Emissions Measurement Center (EMC), located within the Offic e of Air Quality Planning and Standards 

(OAQPS), has also recently evaluated the use of the multi-metals CEM S technology for ambient fenceline multimetals monitoring for compliance determinations, ambient health exposure studies, and for locating and evaluating 

unknown sources of metals emissions. In 2010-2011, EM C deployed the Xact I M 625 fenceline multi-metals 

monitor at two sites in Ohio in coordination with EP A Region 5, EP A Office o f Research and Development (ORD) 

and Ohio EPA . The Xact 1 M 625 reports hourly ambient air metals concentrations in near real-time, which allows fo r 

faster data acquisition and decision making over conventional filter-based monitoring methods. EPA's Ohio studies 

show excellent comparability between the XactTM 625 and conventional, filter-based, metals monitoring methods. 

'' 2 Phone conversations between EP A and John Cooper and Krag Petterson, Cooper Environmental Services, dated 

March 24 and 26, 2014, respectively. 

French, N.B. , and Priebe, S.J. (1999) 

M

 See http://www.epa.tiov/ttn/emc/prelim/otml 6.pdf and http://www.epa.eov/ltn/emc/prelim/otm20.pdf. 

VES017302 
Statement ofBasis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C, Sauget, Illinois 

Date Issued: October 10, 2014 Page 62 of 79 

EPA's historical practice indicates, OTM specifications and procedures can be 

used for compliance purposes with the approval of the permitting authority. As 

the permitting authority for this permitting action, EPA believes that the 

specifications and procedures published as OTM 16 and 20 are appropriate for the 

multi-metals CEMS. In addition, these specifications and procedures were 

reviewed and approved by EPA under 40 C.F.R. § 63.7(f) as part of the Eli Lilly 

Alternative Monitoring Petition (AMP) approval process. 

EPA guidance allows EPA to impose continuous monitoring requirements under 

Title V without a promulgated performance specification, provided that we 

include appropriate Q A and QC procedures within the pennit. See, for example, 

Dianne J. McNally, Air Toxics Coordinator, EPA Region III to Tamera 

Thompson, Virginia Department of Environmental Quality, May 30, 2001 

(McNally Memo) (the permitting authority is required to incorporate into the Title 

V permit acceptable perfonnance specifications for the continuous monitoring 

system used to comply with the Pulp and Paper MACT standard, and may rely on 

draft performance specifications to develop such performance specifications).65 

5.3.6. Measurement of Beryllium Emissions 

EPA recognizes that the only cwrently available multi-metals CEMS that would 

meet EPA's requirements is incapable of measuring beryllium 

emissions. Because of this, EPA has proposed a methodology in the draft permit 

for quantifying emissions of metals for which the multi-metals CEMS is 

incapable of directing measuring. See Condition 2.1(D)(l)(i)(ii). The proposed 

methodology would require that beryllium emissions be quantified using the 

results of feedstream analysis and the system removal efficiency and exhaust 

parameters used by Veolia to estimate emissions during the 12-hour period used 

to calculate the 12-hour average rolling average. 

The proposed methodology for measuring beryllium emissions is appropriate 

since the proposed temporary multi-metals CEMS is not intended to replace the 

feedstream analysis provisions. As already discussed, the purpose of the multimetals CEMS is to enable EPA to establish a conelation between the feedrates 

(and feedrate OPLs) and the emissions; therefore, Veolia will continue to analyze 

its feedstreams while the multi-metals CEMS is installed and operated. After the 

12-month period over which the multi-metals CEMS will be operated (unless that 

period is extended by EPA), Veolia has the option to petition EPA to permanently 

operate the multi-metals CEMS in lieu of feedstream analysis. Should Veolia 

choose that option, EPA and Veolia would determine at that time the best 

methodology for quantifying beryllium emissions without concunent feedstream 

analysis. Until such time, we believe that it is appropriate to require Veolia to 

Available at www.regulations.gov: document ID. EPA-R05-OAR-2012-0649-0100. 

VES017303 
Statement ofBasis for DRAFT Title V Pennit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C, Sauget, Illinois 

Date Issued: October 10, 2014 Page 63 of 79 

calculate beryllium emissions from the beryllium feedstream analysis results and 

using acceptable conversion factors. We expect that Veolia would use the system 

removal efficiency from the last CPT or other EPA-approved Method 29 tests in 

the calculations. Also, because Veolia is required to install and operate 

continuous monitoring systems (CMSs) for purposes of demonstrating 

compliance with the maximum temperature and flowrate OPLs, we expect that 

Veolia will have continuous flow and temperature data that it can use in the 

calculations. 

5.4. Other Supplemental Monitoring Provisions Included in the Permit 

5.4.1. Emissions Calculation Methodology [Condition 3.1(C)] 

Veolia's Title V permit establishes periodic monitoring in a number of conditions 

as summarized below. In general, the periodic monitoring requirements include, 

as appropriate, regular or periodic performance testing, recordkeeping and work 

practice provisions. In situations where continuous emissions monitoring, 

performance testing or use of specific emissions estimation software, is not 

required, EPA expects Veolia to rely on emission factors to calculate emissions. 

Whether or not the permit specifics the emission factors to be used, Veolia is 

required to document the emission factors it uses, including a demonstration of 

their appropriateness to the specific emission units from which emissions are 

being calculated. 

In all situations, EPA expects Veolia to follow the following hierarchy when 

selecting the appropriate methodology for calculating emissions: 

1. Continuous Emissions Monitoring CEM data from the stationary source; 

2. Performance test data from the stationary source; 

3. Manufacturer's emissions performance guarantee; 

4. CEM data from a similar stationary source or sources; 

5. Performance test data from a similar stationary source or sources; 

6. Industry-derived emission factors; 

7. Emission factors published by EPA in the latest version of AP-42; 6 6 

8. Engineering judgment. 

See, generally, Introduction to AP-42, Volume I, Fifth Edition - January 1995 

(AP-42 Introduction) at 2-5 and Figure 1. Veolia should document in its records 

that it followed this hierarchy. Note that Veolia's choice of emission calculation 

methodology based on the above hierarchy does not preclude any person, such as 

EPA, the public, or other regulatory agencies, from using other credible evidence 

htlp://www.epa,gov/ttn/chiei7ap42 

VES017304 
Statement of Basis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C, Sauget, Illinois 

Date Issued: October 10, 2014 Page 64 of 79 

to establish compliance or noncompliance with applicable requirements as 

provided by the Act. See 42 U.S.C. § 7413 and 62 Fed. Reg. 8314 (February 24, 

1997). 

Under the above hierarchy, Veolia should treat AP-42 emission factors (if 

available) as the last resort before using engineering judgment to estimate 

emissions. In situations where representative source-specific data cannot be 

obtained, EPA believes that emissions information from equipment vendors, 

particularly emission performance guarantees or actual test data from similar 

equipment, is a better source of information for calculating emissions than an AP42 emission factor. AP-42 Introduction at 3. If AP-42 emission factors must be 

used, A-rated AP-42 emission factors should be considered before the lower rated 

emission factors. While it may not be necessary in some situations to review 

each individual data source that EPA relied upon in developing the AP-42 

emission factors, such review may be appropriate in cases where EPA has 

reported significant source-to-source variability in the measured emission 

rates. Because AP-42 emission factors represent an average of emissions from 

different sources, it is possible that some of the sources evaluated by EPA in 

developing the AP-42 emission factors being considered have significantly 

different emissions characteristics than Veolia. Therefore, it is crucial that 

Veolia's records include a clear justification of the appropriateness of the selected 

AP-42 emission factor for the specific emission unit being evaluated/'7 

5.4.2. Testing Requirements for NOx, VO M and SO2 Emissions from the 

Incineration Units 

Condition 2.1(A)(6) limits NOx emissions from Units 2, 3 and 4 to 4.0 tpy, 4.0 

tpy and 61.6 tpy, respectively. Condition 2.1(A)(2) limits SO2 emissions from 

Units 2, 3 and 4 to 7.7 tpy, 7.7 tpy and 50.76 tpy, respectively. Condition 

2.1(A)(5)(b) limits VOM emissions from Units 2, 3 and 4 to 0.9 tpy, 0.9 tpy and 

3.1 tpy, respectively. These limits are from Construction Permits 87100024 and 

88010001. In addition, Conditions 2.1(A)(1) and 2.1(A)(5)(a) contain emissions 

limitations for visible emissions (opacity) and VOM from any emission unit, 

respectively. These limits arc from the Illinois SIP. 

Although EPA acknowledges that compliance with the HWC MACT 

requirements assures that NOx, SO2 and VOM emissions will generally be 

" As EP A has previously stated: "Before simply applying AP-4 2 emission factors to predict emissions from new or 

proposed sources, or to make other source-specific emission assessments, the user should review the latest literature 

and technology to be aware of circumstances that might cause such sources to exhibit emission characteristics 

different from those of other, typical existing sources. Care should be taken to assure lhat the subject source type and 

design, controls, and raw material input are those o f the source(s) analyzed to produce the emission factor. This fact 

should be considered, as well as the age of the information and the user's knowledge of technology advances." AP -

42 Introduction at 4. 

VES017305 
Statement ofBasis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C, Sauget, Illinois 

Date Issued: October 10, 2014 Page 65 of 79 

minimized from the incineration units, EPA believes it is necessary to periodically 

document the actual emissions of these pollutants so as to document compliance 

with the numerical emission limits for these pollutants. Therefore, EPA has 

proposed additional emissions testing requirements for NOx, SOa, opacity and 

V OM emissions in Condition 2.1(D)(7)(b) of the draft permit. These 

requirements state that during the confirmatory performance tests required by 

Conditions 2.1(D)(8) and (10), Veolia shall also measure emissions of NOx, SO2, 

visible emissions (opacity) and VOM to document compliance with the NOx, 

SO2, visible emissions and VOM limitations, respectively. EPA has included the 

appropriate test methods in Conditions 2.1 (D)( 14)(i) through (1). 

Confinnatory performance tests are conducted approximately once every five 

years on each incinerator to demonstrate compliance with the dioxin/furan 

emission standards, and to evaluate the perfonnance of continuous monitoring 

systems for dioxin/furans. Because the NOx, SO2, opacity and VOM emissions 

testing would be conducted along with the dioxin/furan tests required by the 

HWC MACT, Veolia can demonstrate compliance with the NOx, SO2, opacity 

and VOM emissions limits while it bums the same type of waste, and under the 

same operating conditions, as used to demonstrate compliance with the 

dioxin/furan emission standards. 

5.4.3. Visible Emissions Observations for Material Processing Areas (Conditions 

2.2(D)(4) and 2.2(E)(2)! 

Condition 2.2(A)(4) of the permit limits emissions of "smoke or other particulate 

matter" from any emission unit to no greater than 30% opacity. To demonstrate 

compliance with this requirement, Condition 2.2(D)(4) requires Veolia to visually 

survey units MP1, MP2 and the Lab Pack Repack area each day for the presence 

of visible emissions or fugitive emissions. If emissions are observed, the permit 

requires appropriate conective action. If the conective action does not eliminate 

the visible emissions, then Veolia is required to conduct opacity observations 

using EPA Method 9. If any ofthe visible emissions observations indicate visible 

emissions greater than 20 percent opacity, Veolia must conduct daily visible 

emissions observations, for 30 minutes, of the emission point in question until 2 

consecutive daily observations indicate visible emissions of 20 percent opacity or 

less. If the Method 9 visible emissions observations, or if 2 consecutive daily 

observations, indicate visible emissions of 20 percent opacity or less, the 

Permittee shall conduct weekly visible emissions observations of the emission 

point for 3 additional weeks. Condition 2.2(E)(2) requires Veolia to keep records 

associated with the visual surveys and Method 9 observations. 

It is very unlikely that the repackaging of materials will cause opacity greater than 

30% because the wastes that are being repackaged are in enclosed containers. 

The process typically involves opening the containers briefly while the waste is 

VES017306 
Statement ofBasis for DRAFT Title V Pennit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions. L.L.C, Sauget, Illinois 

Date Issued: October 10, 2014 Page 66 of 79 

repackaged, and takes place in an enclosure that minimizes the impact from wind. 

EPA believes this staged approach to assessing compliance with the opacity limit 

is appropriate, given the infrequency of visible emissions in the materials 

processing area. 

5.4.4. Calculation of VO M Emissions from Material Processing Areas 

[Condition 2.2(E)(3)] 

Condition 2.2(A)(3) provides that no person shall cause or allow the discharge of 

more than 3.6 kg/hr (8 lb/hr) of organic material into the atmosphere from any 

emission unit. To demonstrate compliance with this requirement, Condition 

2.2(E)(3) of the 2008 permit required Veolia to calculate VOM/HAP emissions 

from units MP-1, MP-2 and the Lab Pack Repack using the most recent version of 

the TANKS program.68 EPA had believed that the majority of the waste 

processing occuning in the waste processing areas took place within the drums 

and canisters and therefore, using TANKS to determine the VOC and HAP 

emissions based on the size of the containers and the liquid content would yield 

the most reliable information. However, according to Veolia/' 9 containers that are 

received and stored in MP-1, MP-2 and the Lab Pack Repack are closed with a lid 

or cover which allows no volatile compounds to escape. Once the containers are 

received into the MP-1, MP-2 and the Lab Pack Repack buildings, they are held 

there until the waste is transfened for processing either within the building or 

directly to the incinerator feeds. Containers are only opened to sample and 

process the contents. The processing consists of placing the waste from a 

container either into open troughs through which the waste moves through sizing 

activities and is repacked into feed containers; or directly into feed 

containers. The waste in the trough is open to the atmosphere of the building. As 

such constituents in the waste volatilize into the building atmosphere and are 

emitted through the building exhaust. 

In recognition of the nature of the waste processing operations performed in the 

material processing areas, EPA is proposing in the renewal permit to require 

Veolia to calculate VOM and HAP emissions from units MP-1, MP-2 and the Lab 

Pack Repack using the Emission Inventory Improvement Program's70 surface 

evaporation model for calculating emissions from surface evaporation of VOM 

from open or partially covered mixing tanks during coating mixing operations, 

Methods for Estimating Air Emissions from Paint, Ink, and Other Coating 

Manufacturing Facilities, Volume II: Chapter 8 (February 2005) at 8.4-22 

m

 TANK S is a computer software program that estimates VO C and HA P emissions from fixed- and floating-roof 

storage tanks. It is based on the emission estimation procedures from Chapter 7 of AP-42. 

1,9 See email from Kathy Strubberg to David Ogulei dated April 3, 2014. 

, n

 The Emission Inventory Improvement Program was a joint effort by the State and Territorial Air Pollution 

I'rograni Administrators/Association of Local Air Pollution Control Officials (STAPPA/ALAPCO ) and EPA . 

VES017307 
Slatement ofBasis for DRAFT Title V Pemiit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C, Sauget, Illinois 

Date Issued: October 10, 2014 Page 67 of 79 

(Equation 8.4-22).71 The surface evaporation model estimates the amount of 

constituents volatized based on the volatility of the different waste constituents 

and the air flow across the exposed surface of the waste and it is more appropriate 

than TANKS for calculating emissions from emission units that behave like 

spills.72 Thus, although EPA generally considers the TANKS program to be 

reliable for estimating VO M emissions from enclosed storage tanks, the surface 

evaporation model is more conservative than TANKS for estimating emissions 

from Veolia's waste processing areas. 

EPA is proposing to continue to require that Veolia use TANKS or the equations 

and algorithms specified in Chapter 7 of AP-42 for estimating any VOCs emitted 

from any enclosed storage tanks located in MP-1, MP-2 and the Lab Pack 

Repack. 

5.4.5. Visible Emissions Observations for the Drum Crusher [Conditions 2.3(D) 

and 2.3(E)(3)] 

Condition 2.3(A)(3) limits emissions of "smoke or other particulate matter" from 

any emission unit to no greater than 30% opacity. To demonstrate compliance 

with this requirement, Condition 2.3(D) requires Veolia to visually survey the 

drum crusher each day for the presence of visible emissions or fugitive emissions. 

If emissions are observed, the permit requires appropriate corrective action. If the 

corrective action does not eliminate the visible emissions, then Veolia is required 

to conduct opacity observations using EPA Method 9. If any of the visible 

emissions observations indicate visible emissions greater than 20 percent opacity, 

Veolia must conduct daily visible emissions observations, for 30 minutes, of the 

emission point in question until 2 consecutive daily observations indicate visible 

emissions of 20 percent opacity or less. If the Method 9 visible emissions 

observations, or if 2 consecutive daily observations, indicate visible emissions of 

20 percent opacity or less, the Permittee shall conduct weekly visible emissions 

observations of the emission point for 3 additional weeks. Condition 2.3(E)(3) 

requires Veolia to keep records associated with the visual surveys and Method 9 

observations. 

It is very unlikely that crushing drums will cause opacity greater than 30% 

because the drums are empty and would not generate enough dust particles to 

violate the opacity standard when the drums are crushed. EPA believes this 

staged approach to assessing compliance with the opacity limit is appropriate, 

given the unlikelihood of visible emissions from the drum crusher. 

7 1

 http://www.epa.gov/ttri/chief/eiip/techreport/volume02/ii08 feb2005.pdf. 

7 2

 Moreover, EP A has recently determined that the TANK S model is not reliably fiinctional on computers using 

certain operating systems such as Windows Vista or Windows 7. 

VES017308 
Statement ofBasis for DRAFT Title V Pennit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C, Sauget, Illinois 

Date Issued: October 10, 2014 Page 68 of 79 

5.4.6. Calculation of VOM Emissions from the Drum Crusher [Conditions 

2.3(E)(1) and (2)[ 

Condition 2.3(E)(2) requires Veolia to calculate VOM emissions from the drum 

crusher using an emissions factor of 0.0221 pounds VO M per drum crushed. This 

V OM emission factor is based on an analysis of actual throughput data collected 

by Veolia since the initial Title V 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. The VOM emission factor of 0.0221 pounds VO M per drum crushed 

assumes that the drum residue contains the most prevalent organics at the 

concentrations present in the waste received during 2007- 2011.73 

To enable calculation of hourly and annual emissions, Veolia must maintain 

records of the total number of drums crushed (drums/hour and drums/year) for the 

drum crusher. EPA believes this is a reasonable procedure for estimating actual 

V OM emissions from the drum crusher. As provided by Condition 4.22 of the 

pennit, any person may also use other credible evidence to establish compliance 

or noncompliance with applicable requirements. 

5.4.7. Periodic Replacement of Carbon in the Carbon Adsorption System 

[Condition 2.4(D)(4)] 

To ensure the integrity of the carbon adsorption bed, Condition 2.4(D)(4) of the 

permit requires Veolia to replace the carbon bed within 365 days of operation for 

a high BTU tank and 3 years of operation for a low BTU tank. This provision 

supplements Condition 2.4(D)(3) which requires Veolia to replace the existing 

carbon with fresh carbon immediately when carbon breakthrough is indicated. 

5.4.8. Inspection Requirements for the Submerged Loading Pipes [Condition 

2.4(D)(6)1 

This provision requires Veolia to inspect the presence and condition of the 

submerged loading pipes from the top during the quarterly inspections and lo 

conduct a physical inspection of the submerged loading pipes every 5 years. EPA 

believes this provision is necessary to assure compliance with Condition 

2.4(A)(5) which requires that each affected liquid waste storage tank be equipped 

with a permanent submerged loading pipe. 

7 3

 The original permit required Veolia to calculate VO M emissions from the drum crusher using an emission factor 

of 0.0914 lb VO M per drum crushed. That emission factor was calculated based on the assumption that only 

methanol residue is in the containers to be crushed and that methanol is the only VO M released as the containers are 

crushed. This was a rather conservative assumption because methanol has a higher vapor pressure than most o f the 

volatiles found in the container residues. Veolia requested that EP A update the VO M emission factor as discussed 

here. 

VES017309 
Stalement ofBasis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C, Sauget, Illinois 

Date Issued: October 10, 2014 Page 69 of 79 

5.4.9. Visible Emissions Observations for the Bulk Feed Building [Condition 

2.5(D)(3) and 2.5(E)(3)] 

Condition 2.5(A)(4) limits emissions of "smoke or other particulate matter" from 

any emission unit to no greater than 30% opacity. To demonstrate compliance 

with this requirement, Condition 2.5(D)(3) requires Veolia to visually survey the 

bulk feed building each day for the presence of visible emissions or fugitive 

emissions. If emissions are observed, the permit requires appropriate corrective 

action. If the corrective action does not eliminate the visible emissions, then 

Veolia is required to conduct opacity observations using EPA Method 9. If any of 

the visible emissions observations indicate visible emissions greater than 20 

percent opacity, Veolia must conduct daily visible emissions observations, for 30 

minutes, of the emission point in question until 2 consecutive daily observations 

indicate visible emissions of 20 percent opacity or less. If the Method 9 visible 

emissions observations, or if 2 consecutive daily observations, indicate visible 

emissions of 20 percent opacity or less, Veolia is required to conduct weekly 

visible emissions observations ofthe emission point for 3 additional weeks. 

Condition 2.5(E)(3) requires Veolia to keep records associated with the visual 

surveys and Method 9 observations. 

It is unlikely that operations in the bulk feed building will cause opacity greater 

than 30% since it is totally enclosed. EPA believes this staged approach to 

assessing compliance with the opacity limit is appropriate, given the unlikelihood 

of visible emissions from the bulk feed building. 

5.4.10. Requirements that Ensure Total Enclosure for the Bulk Feed Building 

[Condition 2.5(D)(6)] 

Conditions 2.5(A)(1)(b) and 2.5(D)(4) contain requirements to ensure that the 

bulk feed building is totally enclosed. For the purpose of assuring compliance 

with these requirements, Condition 2.5(D)(6) requires Veolia to maintain an 

average facial velocity of at least 200 ft/min flowing into the bulk feed building's 

enclosure at all natural draft openings in the building. Veolia must annually 

demonstrate the facial velocity according to Procedure T - Criteria for and 

Verification of a Permanent or Temporary Total Enclosure, 40 C.F.R. § 52.741, 

Appendix B. EPA believes this periodic monitoring requirement, in conjunction 

with the requirements of Condition 2.5(D)(4), assures that Veolia is maintaining a 

total enclosure of the building. 

VES017310 
Statement of Basis for DRAFT Tille V Pennit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C, Sauget, Illinois 

Date Issued: October 10, 2014 Page 70 of 79 

5.4.11. Supplemental Recordkeeping Requirements for the Bulk Feed Building 

[Condition 2.5(E)(2)] 

To help verify compliance with the applicable requirements, EPA is requiring 

Veolia to maintain records according to Condition 2.5(E)(2). These records 

would provide information on VOM/HAP emissions, amount of wastes 

processed, maintenance and repair activity and level of pressure maintained inside 

ofthe building. EPA is proposing to require that Veolia calculate VOM/HAP 

emissions from waste processing operations located at the bulk solid waste 

storage facility (bulk feed building) using the Emission Inventory Improvement 

Program's surface evaporation model. See discussion in Section 5.4.4, above. In 

addition, Veolia will use the most recent version of the TANKS program or the 

equations and algorithms specified in Chapter 7 of AP-42 to calculate 

VOM/HAPs emitted from any enclosed storage tanks located in the bulk feed 

building. 

5.4.12. Monitoring and Recordkeeping Requirements for the Gasoline Storage Tank 

[Conditions 2.6(D) and (E)] 

Conditions 2.6(A)(1) and (2) prohibit Veolia from causing or allowing the transfer 

of gasoline from any delivery vessel into any stationary storage tank unless the 

tank is equipped with a submerged loading pipe. EPA believes it is necessary for 

Veolia to maintain records that document the presence of a permanent submerged 

loading pipe. Also, to ensure that the submerged loading pipe and the storage 

tank are designed and operated so as to limit VOM/IIAP emissions during the 

transfer of gasoline, EPA believes it is appropriate to require Veolia to maintain 

records of inspections, maintenance and repair for the storage tank and submerged 

loading pipe. Condition 2.6(E) requires such recordkeeping. 

The draft permit also includes the requirements of 35 IAC 219.585, Gasoline 

Volatility Standards for the Metro East Area, in Conditions 2.6(A)(3) 

through (5).74 To monitor compliance with these requirements, EPA is proposing 

to include periodic monitoring provisions in Conditions 2.6(D)(1) through (5). In 

particular, Condition 2.6(D)(1) of the draft permit requires Veolia to demonstrate 

compliance with the 7.2 pounds per square inch Reid vapor pressure limit in 

Condition 2.6(A)(4) by annually sampling and analyzing for Reid vapor pressure 

M

 Effective January 28, 2013, the Illinois Pollution Control Board repealed the requirements of 35 IAC 219.585 

from state rules. IEPA has submitted to EP A a request to revise its SIP to remove the repealed provisions; however, 

E P A has not yet acted on that request. EP A is proposing to retain the repealed provisions in Veolia"s permit until 

such a time that those provisions are removed from the Illinois SIP. If prior to issuing the final permit, EP A grants 

IEPA's request to remove the repealed provisions from its SIP, EP A will remove the repealed provisions from this 

pemiit when it issues the final permit. EP A will follow the appropriate permit reopening/revision procedures in 

40 C.F.R. § 71.7 if EP A grants IEPA's request to remove the repealed provisions from its SIP after the final permit 

is issued. 

VES017311 
Statement of Basis lor DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C, Sauget, Illinois 

Date Issued: October 10, 2014 Page 71 of 79 

the gasoline in the affected tank. Pursuant to Condition 2.6(E)(4), Veolia must 

maintain records of all sampling and analyses it conducts. In addition, Veolia 

must maintain for three years records of, among other things, the Reid vapor 

pressure of each shipment of gasoline loaded into the gasoline storage tank 

pursuant to Condition 2.6(E)(5). Because Veolia is required to record the Reid 

vapor pressure of each shipment of gasoline loaded into the gasoline storage tank, 

EPA believes that the additional annual sampling and testing requirements for 

Reid vapor pressure are sufficient to assure compliance with the vapor pressure 

limit. 

5.4.13. Compliance with the Opacity and Other Numerical Limits for the Boiler 

[Conditions 2.7(C)(2), 2.7(D)(1), 2.7(D)(2)(e)] 

Conditions 2.7(A)(1) through (3) contain numerical limits for the boiler, including 

SIP limits in Conditions 2.7(A)(1) and (3) and construction permit limits in 

Condition 2.7(A)(2). Because emissions from a boiler are directly related to the 

amount and type of fuel burned in the boiler, the permit also includes limits on 

natural gas consumption (see Condition 2.7(C)(2)) along with requirements to 

track and report natural gas usage (see Condition 2.7(E)). To demonstrate 

compliance with these numerical limits, the Permittee must comply with a number 

of work practice and operational requirements as well as performance testing 

requirements for NOx, CO and opacity. 

Condition 2.7(D)(1) requires Veolia to demonstrate compliance with the opacity 

limit by conducting annual opacity observations using EPA Method 9. In 

addition, Condition 2.7(C)(1) provides that natural gas will be the only fuel fired 

in the boiler, and Veolia must conduct annual tune-ups pursuant to Condition 

2.7(D)(2). Because natural gas-fired boilers generally emit very low levels of 

particulate matter, it is unlikely that visible emissions from the boiler would ever 

exceed 30% opacity. Therefore, an annual opacity observation using EPA 

Method 9 is sufficient to demonstrate compliance with the 30% opacity limit for 

this unit. 

Pursuant to Condition 2.7(D)(2)(e), Veolia must measure the concentrations of 

both CO and NOx in the effluent stream each time it conducts the annual tune-ups 

required by the permit. These measurements may be taken using portable CO and 

NOx analyzers. Because CO and NOx typically have an inverse relationship in 

boilers (i.e., CO is typically highest when NOx is lowest), EPA believes that 

measurement of both CO and NOx during the tune-ups will help assure 

continuous compliance with the CO and NOx emission limits. In addition, Veolia 

is required, pursuant to Condition 2.7(D)(4), to conduct performance tests for CO 

and NOx from the affected boiler at a frequency of no less than once every 5 

years to demonstrate compliance with the CO and NOx emission limits in 

Condition 2.7(A)(2). EPA believes this frequency of testing is adequate given 

VES017312 
Statement ofBasis for DRAFT Title V Pennit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C, Sauget, Illinois 

Date Issued: October 10, 2014 Page 72 of 79 

that previous testing conducted on the affected boiler over the past four years has 

produced CO concentrations that are significantly lower than the applicable CO 

limits.75 All CO and NOx measurements would be recorded and reported to EPA 

according to Conditions 2.7(E)(1)(c), 2.7(E)(1)(d) and 2.7(E)(2). 

5.4.14. Periodic Monitoring Requirements for Insignificant Emission Units 

ICondition 2.10(C)] 

Conditions 2.10(B)(1) through (3) contain requirements that apply to insignificant 

emission units and activities, including numerical emission limits contained in the 

Illinois SIP for process emission units (Condition 2.10(B)(1)) and organic 

material emission units (Condition 2.10(B)(2)). Pursuant to 40 C.F.R. § 71.6, the 

permit must include monitoring requirements sufficient to assure compliance with 

these requirements. 

Because the insignificant emission units specifically identified in the permit are 

expected to have very low emissions compared to the applicable emission limits, 

EPA believes the appropriate means of monitoring compliance for these units is 

through recordkeeping requirements. Specifically, EPA is requiring that Veolia 

maintain a record of its emissions calculations, throughput, inspection, 

maintenance and repair log, and other information necessary to demonstrate 

compliance with the applicable requirements and classification of the units as 

insignificant emissions units. Veolia must submit that record to EPA according to 

the general recordkeeping and reporting schedule in the permit. 

5.5. Streamlining 

Pursuant to 40 C.F.R. § 71.6(a)(3)(i)(A), if two or more monitoring or testing 

requirements apply to the same pollutant from the same emission unit, EPA may allow a 

permittee to comply with a streamlined set of monitoring or testing provisions, provided 

that the specified monitoring or testing is adequate to assure compliance at least to the 

same extent as the monitoring or testing applicable requirements that are not included in 

the pennit as the result ofthe streamlining. EPA is proposing to streamline requirements 

in Condition 2.1(C)(7)(g) pertaining to requirements for a waste feed cutoff interlock 

system and sensors as contained in construction pennits 83120053, 87100024 and 

88010001 and the HWC MACT. 

7 5

 Test data provided by Veolia indicate that average C O concentrations in the boiler exhaust were less than 0.5 part 

per million (ppm), corrected to 3% oxygen, in measurements conducted on June 25, 2009 (0.06 ppm), June 17, 2010 

(<0.01 ppm), June 9, 2011 (<0.01 ppm) and June 8, 2012 (0.13 ppm). See Veoli a Permit Application (April 8, 2013) 

at 9-10. 

VES017313 
Statement ofBasis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C, Sauget, Illinois 

Date Issued: October 10, 2014 Page 73 of 79 

The waste cutoff interlock syslem required by construction permits 83120053, 87100024 

and 88010001 must be constructed and operated so as to prevent introduction of waste 

into the incineration unit when any ofthe following events have occurred: 

(a) Primary chamber temperature below 1600 °F; 

(b) Secondary chamber temperature below 1800 °F; 

(c) Primary or secondary chamber above atmospheric pressure; 

(d) Spray dryer adsorber inlet greater than 2200 °F; 

(e) Spray dryer adsorber outlet greater than 400 °F or below 370 °F; 

(f) Low liquid level in lime slurry head tank; 

(g) Low makeup water pressure into slurry heat tank; 

(h) Baghouse tube sheet pressure drop greater than 10 inches water column (w.c); 

(i) Combustion stack gas flow less than 5,000 actual cubic feet per minute (acfm) 

or greater than 15,000 acfm; 

(j) Oxygen concentration less than 6% by volume; 

(k) Carbon monoxide concentration greater than 500 ppm; 

(1) Carbon monoxide concentration greater than 50 ppm for 3 minutes; 

(m) Total hydrocarbon concentration greater than 100 ppm corrected to 1% oxygen; 

(n) HCI concentration greater than 100 ppm for 1 hour; 

(o) Opacity greater than 10%; 

(p) Primary fuel pressure below 30 psig; 

(q) Combustion air pressure below 10 inches w.c; 

(r) Primary burner failure; 

(s) Secondary burner failure; 

(t) Emergency stack open; and 

(u) OPLs as established based upon evaluation of actual operation and measured 

emissions during a trial burn. 

See Construction Permit 87100024 (Unit 3), Condition 4, and Construction Permit 

88010001 (Unit 4), Condition 4. 7 6 

Conversely, the HWC MACT requires each subject facility to have in place a functioning 

system that immediately and automatically cuts off the hazardous waste feed under 

certain conditions, also known as the Automatic Waste Feed Cut-Off (AWFCO) system. 

See 40 C.F.R. § 63.1206(c)(3). This system is triggered: 

7 6

 Available at www.regulations.gov: Docket ID. EPA-R05-OAR-2014-0280. Construction Permit 83120053 (Units 

2 and 3) includes additional trigger events such as induced draft fan failure, quench water flow below 100 gallons 

per minute (gpm), Venturi scrubber water below 37 gpm, pressure drop across Venturi scrubber less than 21 inches 

w.c , scrubber pH less than 6, flue gas temperature entering the scrubber greater than 180 °F, and loss o f slurry flow 

to spray dryer adsorber. See Condition 5 of Construction Permit 83120053. EP A is not proposing to streamline 

these trigger events. 

VES017314 
Stalement ofBasis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Pennittee: Veolia ES Technical Solutions, L.L.C, Sauget, Illinois 

Date Issued: October 10, 2014 Page 74 of 79 

(a) when any ofthe following are exceeded: OPLs specified under 40 C.F.R. 

§ 63.1209; an emission standard monitored by a CEMS; and the allowable 

combustion chamber pressure; 

(b) when the span value of any CMS detector, except a CEMS, is met or exceeded; 

(c) upon malfunction of a CMS monitoring an OPL specified under 40 C.F.R. 

§ 63.1209 or an emission level; or 

(d) when any component of the AWFCO fails. 

The construction permits and the HWC MACT contain different criteria for when the 

feed should be cut off, making it difficult to compare each individual criteria for 

triggering the waste feed cutoff interlock system with the criteria for triggering the 

AWFCO system. Although the criteria are different, the two applicable requirements are 

clearly monitoring the incineration units' operation as a means to determine when the 

units may be out of compliance. Because the AWFCO system required by the HWC 

MACT can be configured to incorporate all of the triggering events identified in the 

construction permits, EPA believes that compliance with the AWFCO requirements of 

40 C.F.R. Part 63, Subpart EEE, will assure compliance with the list of required monitors 

in construction permits 83120053, 87100024 and 88010001. 

VES017315 
Statement ofBasis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C, Sauget, Illinois 

Date Issued: October 10, 2014 Page 75 of 79 

6.0. ENVIRONMENTAL JUSTICE CONSIDERATIONS 

In 2011, EPA published Plan EJ 2014, EPA's roadmap for integrating EJ into its programs, 

policies and activities. Plan EJ 2014 has three objectives: 1) Protect health and the environment 

in overburdened communities; 2) Empower communities to take action to improve their health 

and environment; and 3) Establish partnerships with local, state, tribal, and federal governments 

and organizations to achieve healthy and sustainable communities.77 One focus area of Plan EJ 

2014 is "Considering Environmental Justice in Permitting."78 EPA's goal is to enable 

overburdened communities to have full and meaningful access to the permitting process and to 

develop permits that address EJ issues to the greatest extent practicable under existing 

environmental laws. Overburdened communities are communities that potentially experience 

disproportionate environmental harms and risk as a result of cumulative impacts or greater 

vulnerability to environmental hazards.79 

Veolia is located in East St. Louis, an area with overburdened communities, and the source is of 

significant public interest. Approximately two-thirds of all persons living within three miles of 

Veolia (64 percent) are minorities, and one-third (33 percent) live below the federal poverty 

level.80 Table 11 compares the race distribution in the vicinity of Veolia to the state and national 

distributions. Figure 5 shows the breakdown of household income within three miles of Veolia, 

based on 2000 U.S. census data. As shown in Figure 5, below, about one-half of all households 

within three miles of Veolia have annual household income of $25,000 or less. 

Table 11. Race Distribution Within 3 Miles of Veolia. 

Race 

Percent of total 

population within 3 miles 

Illinois U.S. 

White 36% 71.5% 72.4% 

African-American 59% 14.5% 12.6% 

Asian/ Pacific Islander 2% 4.6% 5.0% 

American Indian 0% 0.3% 0.9% 

Other race 0% 6.7% 6.2% 

Multiracial 3% 2.3% 2.9% 

*Statistics represent residential population, by 2000 Census Block Group, from EJView: 

http://epamapl4.epa.gov/ejmap/enlrv.html 

11 See Plan EJ 2014: Considering Environmental Justice in Permitting - Implementation Plan. Available at: 

http://www.epa.gov/compliance/ei/resources/policv/plan-ej-2014/plan-ei-permitting-2011 -09.pdf. See also "EP A 

Activities To Promote Environmental Justice in the Pennit Application Process," Notice of Availability of 

Proposed Regional Actions to Promote Public Participation in the Permitting Process and Draft Best Practices for 

Permit Applicants Seeking EPA-Issued Permits; Request for Comments, 77 Fed. Reg. 38052. 

, s

 Id. 

1 9

 77 Fed. Reg. 38052. 

s o

 U.S. Census 2000 and 2010 data, by Block Group. Available through EPA's EJView: 

http://epamapl4.epa.KOv/ei map/en try, html 

VES017316 
Statement ofBasis for DRAFT Title V Pemiit No. V-IL-1716300103-2014-10 

Pennittee: Veolia ES Technical Solutions, L.L.C, Sauget, Illinois 

Dale Issued: October 10, 2014 Page 76 of 79 

11% 

29% 

Les s than $15,000 

B$15,000 - $25,000 

$25,000 - $50,COO 

$50,000 - $75,000 

Greate r than $75,000 

Figure 5. Income of households within 3 miles of Veolia. 

(Source: U.S. Census 2000 data, by Block Group) 

Figure 6. Percentage of population surrounding Veolia living below the federal poverty 

level. (Source: U.S. Census 2000 data, by Block Group) 

VES017317 
Statement ofBasis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C, Sauget, Illinois 

Date Issued: October 10, 2014 Page 77 of 79 

A significant portion of the population living directly north of Veolia in East Saint Louis, and 

across the river to the west ofthe facility in portions of Saint Louis is living below the federal 

poverty level. See Figure 6 (marker shows the location ofthe facility). Compared to the national 

average of 12.4% of individuals living below the poverty level, it is clear that the block groups 

near Veolia have a much higher percentage of individuals living below the federal poverty level 

than the national average.81 

The Title V program itself does not grant EPA the authority to create new limits or other 

requirements based on these concerns. As previously discussed, the Title V permitting program 

codified under 40 C.F.R. Part 71 provides EPA with the authority to incorporate into permits "all 

operational requirements and limitations that assure compliance with all applicable 

requirements" and monitoring "sufficient to yield reliable data from the relevant time period that 

are representative of the source's compliance with the permit" that will assure compliance with 

all requirements ofthe Act. Through this proposed permit renewal action, EPA is incorporating 

monitoring requirements necessary to assure compliance with all applicable requirements. 

EPA believes that compliance with the HWC MACT requirements will help protect the air 

quality around Veolia, which will benefit the entire community. To ensure compliance with the 

feedrate limits in the permit, EPA has included in the Title V permit additional and specific 

monitoring requirements for heavy metals (mercury, arsenic, beryllium, cadmium, chromium and 

lead). The proposed monitoring requirements are based on site-specific conditions at the Veolia 

facility and will help protect human health and the environment from the consequences of 

emissions of mercury and other metals by providing further assurance that Veolia will not exceed 

its permitted limits. See sections 5.2 and 5.3 for a discussion of the additional monitoring 

requirements included in the permit. 

EPA defines EJ as providing fair treatment and meaningful participation in environmental 

decision making. We believe that the process we are following with this Title V permitting 

action provides opportunity for meaningful participation in environmental decision making. 

Specifically, EPA has fulfilled and exceeded CA A public notice requirements for Title V 

permitting by holding a 45-day public comment period and a public hearing for the draft permit. 

The specific public participation opportunities for this permitting action are described in a fact 

sheet that accompanies this draft permit {see Docket ID. EPA-R05-OAR-2014-0280). We 

believe that more transparency and dialogue can lead to better permit outcomes for the 

community as well as permit applicants. 

U.S. Census 2000 data. Available through: http://factfinder2.census.gov/faces/nav/isfypaees/index.xhtml 

VES017318 
Statement ofBasis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Permittee: Veolia ES Technical Solutions, L.L.C, Sauget, Illinois 

Date Issued: October 10,2014 Page 78 of 79 

7.0. MAJOR CHANGES FROM THE 2008 PERMIT 

7.1. Revision of OPLs and Addition of Monitoring Requirements for Metals 

and Other Pollutants 

As previously discussed, today's permit includes multi-metals CEMS requirements and 

supplemental feedstream analysis procedures for mercury, LV M and SVM. The permit 

also includes new OPLs required by the HWC MACT based on performance tests 

conducted by Veolia in October 2013. Please see detailed discussions in sections 4.2.3, 

4.2.4, 5.2 and 5.3 of this Statement ofBasis. 

EPA has also proposed in Condition 2.1(D)(7)(b) emissions testing requirements for 

NOx, SO2, opacity and VO M emissions from each incineration unit. The new 

requirements state that during the comprehensive performance tests required by 

Conditions 2.1(D)(8) and (10), Veolia shall also measure emissions of NOx, S02, opacity 

and VO M to document compliance with the NOx, SO2, visible emissions and VO M 

limitations, respectively. EPA has included the appropriate test methods in Conditions 

(2.1)(D)(14((i) through (1). See section 5.4.2 for a more detailed discussion. 

7.2. Removal of Case-By-Case MACT Determination for the Boiler 

On September 13,2004, under the authority of Section 112(d) ofthe Act, 42 U.S.C. 

§ 7412(d), EPA promulgated national emission standards for HAPs for new and existing 

industrial/commerciayinstitutional boilers and process heaters, 40 C.F.R. Part 63, Subpart 

DDDDD (the Boiler MACT). On June 19,2007, the United States Court of Appeals for 

the District of Columbia Circuit vacated and remanded those standards. See Natural 

Resources Defense Council v. EPA, 489 F.3d 1250 (D.C. Cir. 2007). Veolia was subject 

to the Boiler MACT prior to its vacatur by the D.C. Circuit. As a consequence of the 

Boiler MACT's vacatur, pursuant to Section 112(j) ofthe Act, EPA was required to 

include in the 2008 Title V permit for Veolia limitations on HAP emissions that EPA 

determined, on a case-by-case basis, to be equivalent to the limitations that would apply 

to the affected boiler if an emission standard had been promulgated in a timely manner 

under Section 112(d) ofthe Act. Thus, in the 2008 permit, EPA established pursuant to 

Section 112(j) of the Act, a carbon monoxide emission standard (as a surrogate for 

organic HAP) for Veolia's natural gas-fired boiler of 100 parts per million by volume on 

a dry basis corrected to 3 percent oxygen. See Condition 2.7(A)(1) ofthe 2008 permit.82 

After EPA issued the 2008 permit, on March 21,2011, EPA promulgated new national 

emission standards for HAPs for new and existing industrial/commercial/institutional 

a

 Docket ID: EPA-R05-OAR-2008-0235 

VES017319 
Statement ofBasis for DRAFT Title V Permit No. V-IL-1716300103-2014-10 

Pennittee: Veolia ES Technical Solutions, L.L.C, Sauget, Illinois 

Date Issued: October 10, 2014 Page 79 of 79 

boilers and process heaters, 40 C.F.R. Part 63, Subpart DDDDD. Veolia's boiler is 

subject to those standards and EPA has proposed to incorporate each applicable provision 

from 40 C.F.R. Part 63, Subpart DDDDD, into the Title V permit. See Conditions 2.7(C) 

through (E). Pursuant to 42 U.S.C. § 7412(j)(6), if the Administrator promulgates an 

emission standard that is applicable to the major source prior to the date on which a 

permit application is approved, the emission limitation in the permit shall reflect the 

promulgated standard rather than the case-by-case MACT emission limitation. 

Because the Administrator has promulgated a standard that applies to Veolia's boiler 

under Section 112(d) of the Act, EPA is proposing to remove from the permit the caseby-case MACT determination that it made in the 2008 permit and to incorporate into the 

permit the applicable provisions from 40 CF.R. Part 63, Subpart DDDDD. 

7.3. Incorporation of Applicable Requirements for the Emergency 

Generators 

Veolia's two diesel fuel-fired emergency generators, each with a site rating of less than 

112 kW, are subject to the NESHAP for Stationary Reciprocating Internal Combustion 

Engines (RICE), 40 C.F.R. Part 63, Subpart ZZZZ. See 40 C.F.R. § 63.6585. This 

federal rule establishes national emission limitations and operating limitations for HAP 

emitted from stationary RICE located at major and area sources of HAP emissions. 73 

Fed. Reg. 3603 (January 18,2008). For emergency generators of the size owned and 

operated by Veolia, 40 C.F.R. Part 63, Subpart ZZZZ, includes work practice and 

operational requirements that will minimize HAP emissions from the generators while 

they are being operated. 

Consistent with the CAA's mandate to include all applicable requirements in the permit, 

EPA has incorporated all ofthe applicable provisions of 40 C.F.R. Part 63, Subpart 

ZZZZ, into Veolia's renewal permit. 

VES017320 
VES017321-017448.pdf 
©vgou a 

eNVIRONMGNTAL SERVICES 

January 28, 2014 

Via FedEx 

Attn: Compliance Tracker, AE-17J 

Air Enforcement and Compliance Assurance Branch 

United States Environmental Protection Agency 

Region 5 

77 W. Jackson Blvd., AE-17J 

Chicago, IL 60604 

RE: Veolia ES Technical Solutions, L.L.C. 

163121AAP 

40 CFR Part 63 - Subpart EEE 

National Emission Standards for Hazardous Air Pollutants from 

Hazardous Waste Combustors 

Comprehensive Performance Test Reports and Notification of 

Compliance (NOC) 

Compliance Tracker, 

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

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

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

NOC documents compliance with the emission standards and continuous 

monitoring system requirements, and identifying operating parameters 

defined in 40 CFR 63.1209 and 63.1219. Veolia is now complying with all 

operating requirements specified in this NOC. The Performance Test 

Reports detail compliance with these standards. 

I certify under penalty of law that this document and all attachments were 

prepared under my direction or supervision in accordance with a system 

designed to assure that qualified personnel properly gather and evaluate 

the information submitted. Based on my inquiry of the person or persons 

who manage the system, or those persons directly responsible for 

gathering the information, the information submitted, is to the best of my 

Wt Mobile Avenue, Sauget, IL 62ZD1 

(€18)271-2804 

www.veoliaes.com 
Qveou A 

ENVIRONMENTAL SERVICES 

Compliance Tracker 

January 28, 2014 

Page 2 

knowledge and belief, true, accurate, and complete. I am aware that there 

are significant penalties for submitting false information, including the 

possibility of fine and imprisonment for knowing violations. 

Upon review of this submittal, should the Agency have a need for additional 

information or questions, please contact Dennis Warchol at (618) 271-2804 

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

e-mail at doug.harris(5)veolia.com. 

Sincerely, 

Veolia ES Technical Solutions, L.L.C. 

Doug Harris 

General Manager 

Att. 

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

USEPA File 

#7 Mobile Avenue, Sauget, IL 62201 

(618) 271-2804 

www.veoliaes.com 

VES017322 
URS 

!ffl| 

40 CFR §63 Subpart EEE 

Comprehensive Performance Test Repor' 

Fixed Hearth Incinerator - Unit 2 

Fixed Hearth Incinerator - Unit 3 

Rotary Kiln Incinerator - Unit 4 

Veolia ES Technical Solutions, L.L.C. 

7 Mobile Avenue 

Sauget, IL 62201 

Prepared by: 

URS Corporation 

9400 Amberglen Blvd. 

Austin, TX 78729 

January 28,2014 

URS Corporation 

9400 Amberglen Boulevard 

Austin, TX 78729 

P.O. Box 201088 

Austin, TX 78720-1088 

Tel: 512.4 54.4797 

Fax: 512.454.8807 

www.urscorp.com 

for 

Prepared for: 

VES017323 
Table of Contents 

Page 

1.0 Introduction • 1-1 

1.1 Incinerator Overview 1-2 

1.2 Test Objectives - 1-3 

1.3 Test Protocol Summary 1-4 

1.4 CPT Schedule < 1-9 

1.5 Summary of Results 1-10 

1.6 Report Organization 1-10 

2.0 Process Operations..... 2-1 

2.1 Process Overview 2-1 

2.2 Process Operating Data and Waste Feedrates 2-6 

2.2.1 Unit 2 2-6 

2.2.2 Unit 3 2-6 

2.2.3 Unit 4... 2-7 

2.3 Spiking of Metals and Chlorine .2-7 

3.0 Sampling, Analysis, and Monitoring Procedures 3-1 

3.1 Samphng Locations and Procedures 3-1 

3.1.1 Liquids Sampling Procedures 3-1 

3.1.2 Solids Sampling Procedures 3-6 

3.1.3 Stack Gas Samphng Procedures 3-6 

3.1.3.1 Sample Port Locations 3-10 

3.1.3.2 EPA Methods 2 and 4 (Flowrate and Moisture) .3-10 

3.1.3.3 EPA Method 5 (PM) 3-10 

3.1.3.4 Modified EPA Method 26A (HC1/C12) • 3-11 

3.L3.5 EPAMethod29 (Metals) 3-11 

3.1.3.6 SW-846 Method 0023A (Dioxins/Furans) 3-12 

3.1.3.7 Continuous Emissions Monitoring (THC, C02, CO and 02 ) 3-13 

3.2 Analysis Procedures : 3-13 

3.2.1 Composition and Physical Parameters Analysis .....3-14 

3.2.2 Metals Analysis 3-14 

3.2.3 PM Analysis -.3-14 

3.2.4 HCVC12 Analysis 3-14 

3.2.5 Dioxins/Furans Analysis 3-15 

3.3 Process Monitoring Procedures 3-15 

iii 

VES017324 
Table of Contents (continued) 

Page 

4.0 Results 4-1 

4.1 Waste Feedstreams 4-1 

4.2 Stack Gas 4-18 

4.2.1 PM in Stack Gas 4-18 ' 

4.2.2 HC1/C12 in Stack Gas 4-22 

4.2.3 Metals in Stack Gas 4-26 

4.2.4 Dioxins/Furans in Stack Gas 4-34 

4.2.5 THC in Stack Gas 4-39 

4.3 Chlorine, Ash, and Metals Feedrates 4-41 

4.3.1 Chlorine Feedrates 4-41 

4.3.2 Ash Feedrates 4-41 

4.3.3 Metals Feedrates 4-48 

5.0 Quality Assurance/Quality Control 5-1 

5.1 Audit Samples • 5-2 

5.2 Analysis of Waste Feeds 5-2 

5.2.1 Analysis of Waste Feeds for Metals 5-2 

5.2.2 Analysis of Waste Feeds for Physical and Chemical Parameters 5-4 

5.3 Stack Gas 5-5 

5.3.1 Isokinetic Sample Collection 5-5 

5.3.2 Analysis of Stack Gas Samples for Detenmnation of PM ..5-6 

5.3.3 Analysis of Stack Gas Samples for Determination of HC1/C1S 5-6 

5.3.4 Analysis of Stack Gas Samples for Determination of Metals 5-7 

5.3.5 Analysis of Stack Gas Samples for Determination of Dioxins/Furans 5-8 

5.3.6 Monitoring of Stack Gas for 02 ) C02, and THC 5-9 

5.4 Process Data 5-9 

5.5 Spiking 5-10 

iv 

VES017325 
List of Appendices 

APPENDIX A - CEMS RATA Reports 

APPENDIX B-Spiking Report 

APPENDIX C-Process Operating Data 

APPENDIX D - CMS Performance Evaluation Test Report 

APPENDTX E-Chains-of-Custody/Field Logbook 

APPENDIX F - Sampling Documentation 

APPENDIX G - Analytical Data Reports 

APPENDIX G l - Laboratory Reports - Analysis of Liquid and Solid Waste Feed 

Samples for Metals, Total Chlorine, Ash, and Physical 

Parameters 

APPENDIX G2- Laboratory Reports - Analysis of Stack Samples for 

Dioxins/Furans 

APPENDIX G3 - Laboratory Reports - Analysis of Stack Samples for Metals 

APPENDIX G4 - Laboratory Reports - Analysis of Stack Samples for Particulate 

Matter, Hydrogen Chloride, and Chlorine 

APPENDED G5 - Laboratory Reports - Analysis of Spike Materials 

APPENDIX G6 - Audit Report 

APPENDIX H - Data Quahty Assessments 

APPENDIX I - Samphng Equipment/mstrumentation Calibration Documentation 

v 

VES017326 
List of Tables 

Page 

1-1 Applicable HWC MACT Emission Standards 1-3 

1-2 Data Used To Establish OPLs 1-8 

1-3 Unit 2 Comphance Summary , 1-11 

1-4 Unit 3 Compliance Summary 1-12 

1- 5 Umt 4 Compliance Summary 1-13 

2- 1 Unit 2 - Summary of Process Data and Feedrates During the EPA Method 5 Stack 

Sampling for PM 2-8 

2-2 Unit2-Srunmary of Process Data and Feedrates During the Modified EPA 

Method 26A Stack Sampling for HC1/C12 2-9 

2-3 Unit 2 - Summary of Process Data and Feedrates During the EPA Method 29 Stack 

Sampling for Metals 2-10 

2-4 Unit 2 - Summary of Process Data and Feedrates During the SW-846 MethodOO 23 A 

Stack Sampling for Dioxins/Furans 2-11 

2-5 Unit 3 - Summary of Process Data and Feedrates During the EPA Method 5 Stack 

Sampling for PM. 2-12 

2-6 Unit 3 - Summary of Process Data and Feedrates During the Modified EPA 

Method 26A Stack Sampling for HC1/C12 2-13 

2-7 Unit 3 - Summary of Process Data and Feedrates During the EPA Method 29 Stack 

Sampling for Metals 2-14 

2-8 Unit 3 - Summary of Process Data and Feedrates During the SW-846 Method 0023A 

Stack Sampling for Dioxins/Furans 2-15 

2-9 Unit 4 - Summary of Process Data and Feedrates During the EPA Method 5 Stack 

Sampling for PM 2-16 

2-10 Unit 4 - Summary of Process Data and Feedrates During the Modified EPA 

Method 26A Stack Samphng for HC1/C12 2-17 

2-11 Unit 4 - Summary of Process Data and Feedrates During the EPA Method 29 Stack 

Sampling for Metals 2-18 

2-12 Unit 4 - Summary of Process Data and Feedrates During the SW-846 Method 0023A 

Stack Sampling for Dioxins/Furans 2-19 

2-13 Unit 2 - Chlorine Spiking Rates During the HC1/HC12 Stack Sampling 2-20 

2-14 Unit 3 - Chlorine Spiking Rates During the HC1/HC12 Stack Samphng 2-20 

2-15 Unit 4 - Chlorine Spiking Rates During the HC1/HC12 Stack Sampling 2-20 

2-16 Unit 2 - Spiking Rates During the Metals Stack Sampling 2-21 

2-17 Unit 3 - Spiking Rates During the Metals Stack Sampling 2-21 

2-18 Unit 4 - Spiking Rates During the Metals Stack Sampling 2-21 

vi 

VES017327 
List of Tables (continued) 

Page 

2-19 Unit 2 - Analytical Results for the Chromium Spiking Solution 2-22 

2-20 Unit 2 - Analytical Results for the Mercury Spiking Solution ...2-22 

2-21 Unit 3 - Analytical Results for the Chromium Spiking Solution 2-23 

2-22 Unit 3 - Analytical Results for the Mercury Spiking Solution 2-23 

2-23 Unit 4 - Analytical Results for the Chromium Spiking Solution 2-24 

2- 24 Unit 4 - Analytical Results for the Mercury Spiking Solution : 2-24 

3- 1 Measurement Frequency 3-3 

3-2 Sampling Methods 3-4 

3-3 Unit 2 - Summary of Isokinetic Sampling 3-7 

3-4 Unit 3 - Summary of Isokinetic Sampling 3-8 

3-5 Unit 4 - Summary of Isokinetic Sampling 3-9 

3- 6 Summary of Analytical Methods 3-13 

4- 1 Unit 2 - Analytical Results for Chlorine, Ash, Metals, and Physical Parameters 

in the Low-Btu Liquid Waste Feed 4-5 

4-2 Unit 2 - Analytical Results for Chlorine, Ash, Metals, and Physical Parameters 

in the High-Btu Liquid Waste Feed 4-6 

4-3 Unit 2 - Analytical Results for Chlorine, Ash, Metals and Physical Parameters 

in the Specialty Liquid Waste Feed 4-7 

4-4 Unit 2 - Analytical Results for Chlorine, Ash, Metals and Physical Parameters 

in the Containerized Solids Waste Feed... 4-8 

4-5 Unit 3 - Analytical Results for Chlorine, Ash, Metals, and Physical Parameters 

in the Low-Btu Liquid Waste Feed 4-9 

4-6 Unit 3 - Analytical Results for Chlorine, Ash, Metals, and Physical Parameters 

in the High-Btu Liquid Waste Feed 4-10 

4-7 Unit 3 - Analytical Results for Chlorine, Ash, Metals and Physical Parameters 

in the Specialty Liquid Waste Feed 4-11 

4-8 Unit 3 - Analytical Results for Chlorine, Ash, Metals and Physical Parameters 

in the Containerized Solids Waste Feed 4-12 

vii 
List of Tables (continued) 

Page 

4-9 Unit 4 - Analytical Results for Chlorine, Ash, Metals, and Physical Parameters 

in the Low-Btu Liquid Waste Feed to the Kiln 4-13 

4-10 Unit 4 - Analytical Results for Chlorine, Ash, Metals, and Physical Parameters 

in the High-Btu Liquid Waste Feed to the Kiln .4-14 

4-11 Unit 4-Analytical Results for Chlorine, Ash, Metals and Physical Parameters 

in the Liquid Waste Feed to the SCC , 4-15 

4-12 Unit 4 - Analytical Results for Chlorine, Ash, Metals and Physical Parameters 

in the Containerized Solids Waste Feed 4-16 

4-13 Unit 4 - Analytical Results for Chlorine, Ash, Metals and Physical Parameters 

in the Bulk Solids Waste Feed 4-17 

4-14 Unit 2 - Results of PM in Stack Gas 4-19 

4-15 Unit 3 - Results of PM in Stack Gas 4-21 

4-16 Unit 4 - Results of PM in Stack Gas.. 4-22 

4-17 Unit2-Results of HCl/Cl 2 in StackGas 4-23 

4-18 Unit 3 - Results of HCyCl 2 in Stack Gas 4-25 

4-19 Unit 4 - Results of HCyCl 2 in Stack Gas 4-25 

4-20 Unit 2 - Analytical Results of Metals in Stack Gas 4-27 

4-21 Unit 2 - Results of Metals in Stack Gas 4-28 

4-22 Unit 3 - Analytical Results of Metals in Stack Gas 4-29 

4-23 Unit 3 - Results of Metals in Stack Gas 4-30 

4-24 Unit 4 - Analytical Results of Metals in Stack Gas 4-32 

4-25 Unit 4 - Results of Metals in Stack Gas 4-33 

4-26 Unit 2 - Results of Dioxins/Furans in Stack Gas 4-35 

4-27 Unit 3 - Results of Dioxins/Furans in Stack Gas 4-37 

4-28 Unit 4 - Results of Dioxins/Furans in Stack Gas 4-38 

4-29 Unit 2 - Results of THC in Stack Gas 4-39 

4-30 Unit 3 - Results of TCH in Stack Gas 4-40 

4-31 Unit 4 - Results of THC in Stack Gas 4-40 

4-32 Unit 2-Chlorine Feedrate 3-42 

4-33 Unit 3 - Chlorine Feedrate 3-43 

4-34 Unit 4-Chlorine Feedrate 3-44 

viii 

VES017329 
List of Tables (continued) 

Page 

4-35 Unit 2 - Ash Feedrate During the EPA Method 5 Stack Sampling for PM 4-45 

4-36 Unit 3 - Ash Feedrate During the EPA Method 5 Stack Samphng for PM 4-46 

4-37 Unit 4 - Ash Feedrate During the EPA Method 5 Stack Sampling for PM 4-47 

4-38 Unit 2 - Metals Feedrate 4-49 

4-39 Unit 2 - HWC MACT Metals Feedrate 4-51 

4-40 Unit 3 - Metals Feedrate 4-52 

4-41 Unit 3 - HWC MACT. Metals Feedrate 4-53 

4-42 Unit 4 - Metals Feedrate 4-54 

4- 43 Unit 4 - HWC MACT Metals Feedrate .-. 4-56 

5- 1 Results of Analysis of Audit Samples 5-2 

List of Figures 

Page 

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

2-2 Unit 3 Process Flow Diagram 2-4 

2-3 Unit 4 Process Flow Diagram 2-5 

ix 

VES017330 
1.0 Introduction 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Region 5.The HWC MACT, at 40 CFR § 63!l207(d), states "The date of commencement ofthe 

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

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

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

commencing subsequent confirmatory and comprehensive performance testing is based on the 

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

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

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

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

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

all three units and a Quahty Assurance Project Plan (QAPjP) for the subsequent CPT oh 

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

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

Region 5. 

EPA Region 5 considers that testing of the three incinerators comprises the CPT for 

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

facility on September 4, 2013 with the performance of the RATA of the CO and O2 continuous 

monitoring systems (CEMS) of Unit 4. The RATA of the CO and 0 2 CEMS of Unit 3 was 

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

performed on September 6,2013. Testing for the applicable parameters of the HWC MACT 

including dioxins/furans, total hydrocarbons (THC), carbon monoxide (CO), particulate matter 

1-1 
(PM), hydrogen chloride/chlorine gas (HCl/Ch), mercury, SVM, and LV M was completed on 

October 30, 2012. In accordance with 40 CFR §63.1207(j)(l)(i) and §63.1207(j)(3), the 

Notification of Comphance (NOC) and CPT Report are being filed within 90 days of completion 

of the CPT. 

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

demonstrated only one time, and Veoha Sauget demonstrated DRE during RCRA Trial Bums of 

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

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

hazardous waste at a location in the combustion system other than the normal flame zone" 

(§63.1207(c)(2)(iv)). Veolia did not re-demonstrate DRE in the subsequent CPT. DRE, and the 

associated OPLs, were demonstrated during the January 1993, November 1996, and December 

1995 RCRA Trial Burns, respectively for Units 2, 3, and 4, and operations of the incinerators 

have not significantly changed since that test. 

This test (i.e., the subsequent CPT) demonstrated applicable emission standards and 

estabhshed OPLs as required by the HWC MACT for dioxins/furans, THC, CO, PM, 

HCI/CI2, mercury, SVM, and LVM . The results of this are used to revise the NOC for the 

three incinerators. 

1.1 Incinerator Overview 

Units 2 and 3 are identical fixed hearth incineration systems with primary and secondary 

combustion chambers that treat sohd wastes as well as aqueous and organic liquids. The 

processes are monitored and controlled by individual distributed control systems (DCS) capable 

of continuously monitoring the processes to assure all operational parameters are within 

regulatory and permit hmits while waste is being fed to the unit. In addition, Units 2 and 3 are 

equipped with a Continuous Emissions Monitoring System (CEMS) that continuously samples 

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

Unit 4 is a rotary kiln incineration system with primary and secondary combustion 

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

monitored and controlled by a DCS capable of continuously monitoring the process to assure all 

operational parameters are within regulatory and permit limits while waste is being fed to the 

unit. In addition, this incinerator is equipped with a CEMS that continuously samples the 

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

1-2 

VES017332 
1.2 Test Objectives 

This subsequent CPT for the Final Replacement Standards of the HWC MACT was 

designed and conducted to demonstrate comphance with the standards and associated OPLs of 

the HWC MACT for existing incinerators at §63.1219. The CPT: 

• Demonstrated that the incinerators meet the applicable HWC MACT emission 

limits while treating hazardous waste; and 

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

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

while treating hazardous waste. 

The test program included feeding hquid and sohd waste materials to the 

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

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

sampling of waste streams and spiking materials. Apphcable emissions standards under the 

HWC MACT regulations demonstrated during the CPT are summarized in Table 1-1. 

Table 1-1. Applicable HWC MACT Emission Standards 

Emissions Parameter Limit Citation 

Dioxins/Furans (TEQ basis) 

< 0.20 ng/dscm - Units 2 & 3 

< 0.40 ng/dscm - Unit 4 

40CFR63.1219(a)(l)(i)(A) 

40CFR63.1219(a)(l)(i)(B) 

Mercury < 130 ug/dscm 40 CFR § 63.1219(a)(2) 

Semivolatile Metals (SVM) (Cadmium and 

Lead) < 230 ug/dscm 40 CFR § 63.1219(a)(3) 

Low Volatile Metals (LVM) (Arsenic, 

Beryllium and Chromium) < 92 ug/dscm 40 CFR § 63.1219(a)(4) 

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

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

Hydrogen Chloride & Chlorine (HC1/C12) < 32 ppmv dry, as Cl" 40 CFR § 63.1219(a)(6) 

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

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

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

1-3 

VES017333 
The objectives for the subsequent CPT for the Final Replacement Standards of the HWC 

MACT for each of the three incinerators were to: 

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

following limits, corrected to 7% 02: 

— Carbon Monoxide: 100 ppmv, dry; 

— Total Hydrocarbons: 10 ppmv, dry; 

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

Unit4; 

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

— Mercury: 130 p,g/dscm; 

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

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

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

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

previous RCRA trial bums. 

• Estabhsh limits for operating parameters. 

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

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

Emissions Monitoring Systems (CEMS. 

1.3 Test Protocol Summary 

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

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

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

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

Tn the first part of the test for each incinerator, Veoha demonstrated compliance with the 

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

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

MACT for the particulate matter standard. Comphance with the standard for carbon monoxide 

•was also demonstrated during this portion of the test. 

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

developed OPLs, with the HCl/Cl 2, dioxins/furans, THC, CO, LVM, SVM, and mercury 

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

hazardous waste feedrate, maximum pumpable hazardous waste feedrate, rninimum primary 

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

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

1-4 

VES017334 
combustion gas flowrate, and maximum inlet temperature to the baghouse. Ash was fed to the 

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

standard for carbon monoxide was also, demonstrated during this test 

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

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

HCl/Cb, metals, and dioxins/furans stack testing. Composite hquid waste feed samples 

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

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

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

beryllium, chromium, cadmium, lead, and mercury). All of the composite sohd waste feed 

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

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

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

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

chromium, cadmium, lead, and mercury). 

The incinerators were operated for 30 minutes at the desired feedrates and operating 

conditions before samphng began for a given condition of the testing to assure all operating 

parameters were stabilized at the desired settings to achieve steady state. Spiking with chromium, 

lead, mercury, and chlorine was initiated at least 30 minutes before beginning samphng in the 

second part of each test run for HCI/CI2, metals, and dioxiris/furans to assure that feedrates of 

spiking materials had stabilized before samphng began. Spiking of the waste feed with 

clrromium, lead, mercury, and chlorine continued through the completion of the stack samphng 

for dioxins/furans, the last sampling to be completed. 

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

incinerators during, and throughout, the second part of each test run. The LV M category for 

incinerators includes arsenic, beryllium and chromium. Chromium was spiked as a solution of 

chromic acid into the PCC of the respective incinerators. The SVM category for incinerators 

includes cadmium and lead. Lead was spiked as sohd lead nitrate fed to the incinerators in premeasured plastic baggies at regular intervals with the containerized solid waste. Mercury is the 

only high volatility metal of the HWC MACT. Mercury was spiked as a mercuric nitrate solution, 

and was fed in vials fed to the incinerator at regular intervals with the containerized solid waste. The 

concentration of the solution of mercuric nitrate was different (higher) for Unit 4 than for Units 2 

and 3. One vial containing 10 mLs of the mercuric nitrate solution was fed per charge of the 

containerized sohd waste to Units 2 and 3, and one vial containing 20 mLs were fed with each 

charge of the containerized sohd wastes to Unit 4. 

40 CFR §63.1207(g)(1)(A) requires feeding normal (or higher) levels of chlorine during the 

test for dioxins/furans. Chlorine was spiked the second part of the test and throughout the 

dioxins/furans testing to provide a consistent feedrate of chlorine throughout the dioxins/furans 

1-5 

VES017335 
sampling. The average feedrate of chlorine for Unit 2 from December 2012 through May 2013 was 

35 lb/hr; the average feedrate of chlorine for Unit 3 from December 2012 through May 2013 was 

31 lb/hr; and the average feedrate of chlorine for Unit 4 from December 2012 through May 2013 

was 82 lb/hr. The spiking rate of chlorine was about 200 lbs/hr for all three incinerators. 

Pursuant to 40 CFR §63.1209(m)(3), Veoha is establishing a maximum ash feedrate during 

the CPT for each of the three incinerators, developed in association with the samphng of the stack 

gas for particulate matter. The desired ash feedrate was achieved as the ash fed to the incinerator 

with the wastes, primarily sohd wastes. The requirement in 40 CFR §63.1207 (g) (1)(B) for feeding 

normal (or higher) levels of ash during the SVM and LV M performance tests was achieved by the 

feeding of solid wastes. The average solids feedrate of ash in the first part ofthe test was 503.0 

lbs/hr for Unit 2,525.8 lbs/hr for Unit 3, and 4,777.2 lbs/hr for Unit 4. The feeding of solid 

wastes continued throughout the second part of the test at rates similar to those in the first part of 

the test. The average feedrate of ash for Unit 2 from December 2012 through May 2013 was 102 

lb/hr; the average feedrate of ash for Unit 3 from December 2012 through May 2013 was 109 lb/hr; 

and the average feedrate of ash for Unit 4 from December 2012 through May 2013 was 949 lb/hr. 

40 CFR 63.1207(g)(l)(i)(C) requires that tests for PM, SVM, LVM, mercury, and 

<Uoxms/furans include a normal cleaning cycle of the P M control device. For each of the three 

units, the baghouse is the unit of the air pollution control train that is designed and operated to 

control particulate matter. Testing in all three runs for PM, SVM, LVM, mercury, and 

dioxins/furans was performed including a cleaning cycle of the fabric filter (i.e., baghouse). 

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

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

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

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

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

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

were demonstrated during the RCRA trial burns, and operations of the incinerators have not 

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

DRE for Unit 2 are: 

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

• Maximum Total Waste Feedrate 4,017 lb/hr; 

• Minimum Stack Gas Flowrate 15,605 acfm; 

• Minimum Temperature in the Primary Combustion Chamber 1,658°F; and 

• Minimum Temperature in the Secondary Combustion Chamber 1,848°F. 

1-6 

VES017336 
The operating limits associated with the standard for DRE for Unit 3 are: 

• Maximum Total Pumpable Waste Feedrate 4,045 lb/hr; 

• Maximum Total Waste Feedrate 5,098 lb/hr; 

• Mnimum Stack Gas Flowrate 16,061 acfm; 

• Minimum Temperature in the Primary Combustion Chamber l,627°F;and 

• Mimmum Temperature in the Secondary Combustion Chamber 1,845°F. 

The operating hmits associated with the standard for DRE for Unit 4 are: 

Maximum Total Pumpable Waste Feedrate to the Kiln 

Maximum Total Pumpable Waste Feedrate to the SCC 

Maximum Total Waste Feedrate to the Kiln 

Maximum Total Waste Feedrate to the SCC 

Minimum Stack Gas Flowrate 

3,312 lb/hr; 

1,788 lb/hr; 

18,667 lb/hr; 

1,788 lb/hr; 

44,900 acfm; 

• Mmimum Temperature in the Primary Combustion Chamber l,415°F;and 

• Minimum Temperature in the S econdary Combustion Chamber 1,798°F. 

The OPLs associated with each of the apphcable emission standards (i.e., PM, HCI/CI2 

gas, metals, and dioxins/furans) were developed using process data taken during the collection 

of the applicable samphng train (i.e., EPA Method 5 for particulate matter, Modified EPA 

Method 26A for HC1/C12, EPA Method 29 for metals, and SW-846 Method 0023A for 

dioxins/furans). Operating parameter data were used as shown in Table 1-2 to develop HWC 

MACT OPLs. 

THC is typically monitored in CPTs during the measurement of DRE. The OPLs for 

THC (Le., minimum combustion chamber temperature in the primary combustion chamber, 

minimum combustion chamber temperature in the secondary combustion chamber, maximum 

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

feedrate) are the same as the OPLs for DRE and dioxins/furans. Even though DRE was not 

demonstrated, THC was measured during the second part of each test run of the CPT for each 

unit. 

1-7 

VES017337 
Table 1-2. Data Used to Establish OPLs 

Demonstrated OPLs 

Emission 

Standard 

OPLs Developed 

During the CPT 

Demonstrated OPLs 

Emission 

Standard 

Unit 2 Unit 3 Unit 4 

Maximum Pumpable Waste Feedrate 

DRE 1993 1996 1995 

Maximum Pumpable Waste Feedrate THC V Maximum Pumpable Waste Feedrate • 

Dioxins/Furans V • 

Maximum Total Waste Feedrate 

DRE 1993 1996 1995 

Maximum Total Waste Feedrat Feedrate THC • • 

Dioxins/Furans • • 

Maximum Stack Gas Flowrate 

SVM • • 

Maximum Stack Gas Flowrate 

L VM • • 

Maximum Stack Gas Flowrate 

PM • • 

Maximum Stack Gas Flowrat Flowrate HC1/C12 • • • 

DRE 1993 1996 1995 

Maximum Stack Gas Flowrate 

THC • • 

Maximum Stack Gas Flowrate 

Dioxins/Furans • 

Minimum Combustion Chamber Temperature in the PCC 

DRE 1993 1996 1995 

Minimum Combustio Combustion Chamber Temperatur Temperature in the PCC THC • • • 

Dioxins/Furans • V V 

Minimum Combustion Chamber Temperature in the SCC 

DRE 1993 1996 1995 

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

Dioxms/Furans • • 

Maximum Total Feedrate of LVM (As, Be, Cr) L VM 

Maximum Pumpable Feedrate of LVM (As, Be, Cr) L VM • • • 

Maximum Feedrate of SVM (Pb, Cd) SVM S 

Maximum Feedrate of Mercury (Hg) Hg s • • 

Maximum Feedrate of Ash PM s • 

Maximum Feedrate of Total Chlorine/Cbloride 

HC1/C12 • / 

Maximum Feedrate of Total Chlorine/Cbloride L VM • • Feedrate of Total Chlorine/Cbloride 

SVM • • • / 

Maximum Baghouse Inlet Temperature 

THC • 

Maximum Baghouse Inlet Temperature 

Dioxins/Furans • • Maximum Baghouse Inlet Temperature 

L VM 

Maximum Baghouse Inlet Temperature 

SVM • • 

Minimum Carbon Feedrate 

Dioxins/Furans NA NA • Minimum Carbon Feedrate 

Hg NA NA • 

Minimum Sorbent Feedrate HC1/C12 • • • 

Minimum Carrier Fluid Flowrate HC1/C12 

/ • 

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

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

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

1-8 

VES017338 
1.4 CPT Schedule 

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

performance of RATAs. The RATA of the CO and 0 2 continuous monitorhig systems (CEMS) 

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

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

performed on September 6, 2013. 

The CPT with testing for dioxins/furans, THC, CO, PM, HCI/C12 gas, mercury, SVM, 

and LV M was conducted in October 2013. The CPT testing for each of the three incinerators was 

observed by staff from the Illinois Environmental Protection Agency (IEPA). Due to the federal 

government shutdown in the earher stages of October 2013, staff from EPA Region 5 observed 

the CPT testing only of Unit 4, the last unit tested. 

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

successfully completed on this day. Run 2 was performed on October 9, 2013. The first part of 

Run 2 was successfully completed. During the second part of Run 2, the THC monitor failed and 

drifted well beyond the emission limit of the HWC MACT for THC. It was recognized that the 

THC monitor used to demonstrate comphance with the HWC MACT had malfunctioned because 

Veoha monitors stack gases for THC, and the concentration of THC monitored by Veolia had 

not increased. The second part of Run 2 was stopped for this reason. The THC monitor was 

replaced and Run 3 was performed on October 10, 2013. With the successful completion of Run 

3, three runs for PM had been successfully completed. The third run of the second part of the test 

of Unit 2 (i.e., Run 4) was performed on October 11, 2013. At the completion of Run 4, the leakcheck of the pitot tubes of the dioxins/furans sampling train did not meet the full requirements of 

the apphcable EPA test method (i.e., EPA Method 2) although it was considered that the leakcheck of the pitot tabes was acceptable. Because it was felt that the results of the dioxins/furans 

sampling train were acceptable, this run of the CPT of Unit 2 was not re-done. Personnel from 

EPA Region 5 declared that the dioxins/furans sampling train was unacceptable when on-site the 

week of October 21, 2013. Another run of the second part of the test, for HC1/C12, metals, and 

dioxins/furans, (i.e., Run 5) was performed on October 30, 2013. 

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

1, for PM, was successfully completed on this day. However, the isokinetic sampling rate 

of the dioxins/furans sampling train did not meet method acceptance criteria, and the 

second part of this run, for HC1/C12, metals, and dioxins/furans, had to be repeated as Run 

4. Run 2 was'performed on October 16,2013, and Run 3 was performed on October 17, 

2013. The third successful run of the second part of the test of Unit 3 (i.e., Run 4) was 

performed on October 18, 2013. 

1-9 

VES017339 
The subsequent CPT of Unit 4 was begun October 23, 2013 with the successful 

completion of Run 1. Run 2 was performed on October 24, 2013. The glass nozzle of the P M 

sampling train was chipped with the withdrawal of the samphng probe from the stack at the 

completion of the run. Although the samphng train met all acceptance criteria, including the final 

leak-check, the second run for PM was repeated. Run 3 was performed on October 25, 2013. The 

third (accepted) run for PM (i.e., Run 4) was performed at the conclusion of Run 3 for PM. 

Incinerator operating conditions required for the PM testing were maintained through both of 

these test runs. 

1.5 Summary of Results 

Veolia successfully demonstrated compliance with all of the apphcable regulatory 

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

test condition of each unit. Table 1-3 summarizes the results of the emissions testing of Unit 2. 

Table 1-4 summarizes the results of the emissions testing of Unit 3, and Table 1-5 summarizes 

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

runs for each parameter of interest. The term "test condition" refers to the sum of all the testing 

activities designed to demonstrate the operation of the waste incinerator under particular 

operating parameters (e.g., development of operating parameter limits) under the HWC MACT. 

The term "test run" refers to the replicate testing periods. A complete definition ofthe test 

protocol and methodology is defined in the CPT Plan and QAPjP. 

1.6 Report Organization 

The remainder of this report presents the following sections: 

Process Operations; 

Sampling, Analysis, and Monitoring Procedures; 

Results; and 

Quality Assurance/Quality Control. 

The appendices provide raw data, including chain-of-custody forms, samphng data sheets 

and logs, laboratory reports, process data, CMS PET sheets, spiking reports, and samphng 

equipment calibration forms. 

• Section 2.0-

• Section 3.0 -

• Section 4.0 -

• Section 5.0 -

1-10 

VES017340 
Table 1-3. Unit 2 Compliance Summary 

Unit 2 

Parameter HWC MACT Limit Runl 

10-8-13 

Run 2 

10-9-13 

Run 3 

10-10-13 

RunS 

10-30-13 

Average 

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

HC1/C12 - Modified EPA Method 26A 32 ppmv dry, as Cl", corrected to 1% 02 <29 <13 <18 <20 

Metals - EPA Method 29 

LVM 92 u,g/dscm corrected to 7% Oj <2.8 . <2.4 <2.5 <2.6 

SVM 230 ug/dscm corrected to 7% 0 2 <U <0.78 <1.0 <0.95 

Mercury 130 ng/dscm corrected to 7% 02 <90 <120 <95 <100 

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

Total Hydrocarbons (THC) - EPA Method 25A 10 ppmv, dry corrected to 7% 02 1.6 0.18 0.49 0.75 

Carbon Monoxide (CO)1 100 ppmv, dry corrected to 7% 02 0.00 0.00 0.15 0.05 

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

1-11 

VES017341 
Table 1-4. Unit 3 Compliance Summary 

Parameter HWC MACT Lirnit 

Unit 3 

Parameter HWC MACT Lirnit Runl 

10-15-13 

Run 2 

10-16-13 

Run 3 

10-17-13 

Run 4 

10-18-13 

Average 

Particulate Matter - EPA Method 5 0.013 gr/dscf corrected to 7% 0 2 0.00194 0.00202 0.00204 0.0020O 

HCI/CI2 - Modified EPA Method 26A 32 ppmv dry, as Cl", corrected to 7% Ch <4.5 <4.4 <1.8 <3.6 

Metals - EPA Method 29 

L VM 

SVM 

Mercury 

92 (ig/dscm corrected to 7% 02 

230 ng/dscm corrected to 7% 02 

130 ug/dscm corrected to 7% 0 2 

<8.6 

<20 

<59 

<8.9 

<14 

<39 

<11 

<12 

<46 

<9.4 

<15 

<48 

Dioxins/Furans - SW-846 Method 0023A 0.20 ng/dscm corrected to 7% 0 2 0.00103 0.00115 0.00134 0.00U8 

Total Hydrocarbons (THC) - EPA Method 25A 10 ppmv, dry corrected to 7% 02 0.44 0.26 0.57 0.43 

Carbon Monoxide (CO)1 100 ppmv, dry corrected to 7% 02 0.00 0.00 0.00 0.00 

1

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

1-12 

VES017342 
Table 1-5. Unit 4 Compliance Summary 

Unit 4 

Parameter HWC MACT Limit Runl 

10-23-13 

Run 2 

10-24-13 

Run 3 

10-25-13 

Run 4 

10-25-13 

Average 

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

HCl/Cla - Modified EPA Method 26A 32 ppmv dry, as Cl", corrected to 7% 02 <11 <8.0 <23 <14 

Metals - EPA Method 29 

L VM 92 ug/dscm corrected to 7% 02 <12 <9.8 <7.5 <9.7 

SVM 230 ug/dscm corrected to 7% Oz <8.6 <4.5 <10 <7.8 

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

Dioxins/Furans - SW-846 Melhod 0023A 0.40 ng/dscm corrected to 7% 02 0.138 0.132 0.139 0.137 

Total Hydrocarbons (THC) - EPA Method 25A 10 ppmv, dry corrected to 1% 02 0.51 0.60 0.85 0.65 

Carbon Monoxide (CO)1 100 ppmv, dry corrected to 1% 02 0.07 0.06 0.08 0.07 

1

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

1-13 

VES017343 
2.0 Process Operations 

This section presents brief descriptions of the three incinerators at Veolia's facihty in 

Sauget, IL, and process and feedrate results from the CPTs ofthe three incinerators. 

2.1 Process Overview 

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

rotary Min incinerator (Unit 4) at the Sauget, IL facility. The two fixed hearth units are rated at 16 

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

handling systems. 

Units 2 and 3 feature a two-stage combustion process. Ignition of waste material takes 

place in the primary (lower) combustion chamber (PCC). A secondary (upper) combustion 

chamber (SCC) serves as an "afterburner" for process gases. Liquid wastes, organic and aqueous, 

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

liquids, low-Btu hquids and specialty feed liquids. Sohds, usually packaged in plastic or fiberboard 

containers, are introduced into the incinerator through a PLC controlled airlock-ram system located 

at the lower front of the PCC. 

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

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

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

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

An induced draft fan and stack provide the mechanical energy required to transport the flue gas 

through the interconnecting ductwork, to its eventual discharge point to atmosphere. The only 

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

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

identically with only three baghouse modules in service during operation. 

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

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

Figure 2-2. 

2-1 

VES017344 
Unit 4 is rated at 50 million Btu/hr and is equipped with its own tank farm system, drum 

storage, bulk sohds storage and feed systems. Unit 4 includes a rotary kiln as the PCC, and a SCC. 

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

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

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

are used for injection of pumpable sludges, aqueous wastes and organic hquid wastes to the kiln 

and for injection of organic hquid waste to the SCC. 

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

absorbers, and fabric filter baghouse modules with carbon injection. The air pollution control 

system neutralizes acidic compounds and removes particulate from the exhaust gas. Two 

subsystems, the spray dryer absorber and the fabric filter, carry out the chemical neutralization and 

particulate removal functions, respectively. An induced draft fan and stack provide the mechanical 

energy required to transport the flue gas through the interconnecting ductwork, to its eventual 

discharge point to atmosphere. 

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

A process flow diagram for Unit 4 is presented in Figure 2-3. 

2-2 

VES017345 
Figure 2-1. Unit 2 Process Flow Diagram 

TANK FARM, 

PIRECT INJECT. 

HIGH 

BTU. 

UOUIDS 

SOLIDSI I. I 1 I 

i I T I I 

ITTT T 

COMBUSTION 

AIR 

8LOWR 

TANK FARM , LOW 

8TU . 

DIRECT INJECT , .LIQUIDS 

LIQUID--CONTAINERS, 

GAS CYIINOM , 

SPECIALTY 

FEEDER. 

\ PRIMARY V 

1/

 W / 

.LT.Fif Ff, V ' 

-SKOHOMff 

m 

INCINERATOR 

LOWER 

CHAMBER 

EMH«SO(« 

STACK 

INCINERATOR 

UPPER 

CHAMBER 

WASH , 

DUMRSTER 

U ME 

PREPARATION 

SYSTEM: 

SPRAY 

P RY 

ABSORBER 

MAIN STACK -

STAQt CAS 

MtAMK S -

BAGHOUSE 1,0. FAN 

DRY SCRUBBER ORY SCRUBBER 

SOUDS (. OSS ) SQUOSi ( OSS ) 

EMO DUMP END DUMP 

-FUELS/UOJIO WASTE FCjDW 

1~ -COMBUSTION AlS-pmrf 

» STACK CAS ROW 

ccooco- ASH FLOW 

lOOOO*.: SPUD WASTE aow 

; v \ V > UME SLURRY FLPW 
Figure 2-2. Unit 3 Process Flow Diagram 

TANK FARM 

DIRECT INJECT. 

I I ' I I I 

I I Ml . 

TTH t 

COMBUSTION 

AIR 

BUMER 

,UfflOTO£ 

m 

TANK FARM ¥ W W 

BTU 

DIRECT INJECT UOUJDS 

ffrrr r 

J.T. T T T T 

'SECOWMRY 

INCINERATOR 

LOVER 

CHAMBER 

I 

EWEStEKcr 

STA& 

|»UBTOIi8iWiSI 

XT ASH 

DUMPSTER 

SPECIALTY'FKOER 

FUME HOOD 

EMISSION CONTROL 

SYSTEM 

PRIMARY 

FUEL > 

.UM E 

PREPARATION 

SYSTEM 

1 

T 

INCINERATOR 

UPPER 

CHAMBER 

INCINERATOR 

UPPER 

CHAMBER 

~1 

MAIM STACK -

iwat CAS 

ANALT!£SS» 

:SPRAY 

DRY 

ABSORBER 

BAGHOUSE 1.0. FAN 

ORY SCRUBBER I 

S0U0 5 ( OSS } 

END DUMP 

DRY SCRUB8ER 

SOUOS ( OSS j 

END. DUMP 

GLOVE BOX 

EMISSION CONTROU 

SYSTEM 

FUELS/UQUID WASTE .ROW 

: »_ COMBUSTION AIR ROW 

»- STACK CAS FLOW 

tnccoo- ASH aow 

X3O0C*- SOUO WASTE FLOW 

\\\ » UME SLURRY FLOW 

2-4 

VES017347 
Figure 2-3. Unit 4 Process Flow Diagram 

TANK FARh U 

DIRECT INJECT 

tooooooH 

TANK FARM „ tow 

B T U 

DIRECT INJECT , UOUIOS 

SJRSE 

iWNT 

KILN 

\ PRIMARY V 

/ FUEL / 

D R Y SCRUBBE R 

[SOLIDS { DS S ) 

E ND DUMP 

WESBENCY 

STACK 

SECONDARY 

COMBUSTION 

CHAMBER 

ASH 

ROLL-OFF 

BMBUSTlOM 

AIR 

BIONERS 

TEMPERING 

CHAMBER 

SPRA Y 

D RY 

ABSORBE R 

LIME 

PREPARATION 

SYSTEM 

SPRA Y 

O RY 

ABSORBE R 

m AS H DRY AS H 

DUMPSTER DUMPSTER IDRY SCRUBBE R 

jsOUDS ( DSS ) 

E N D DUM P 

ORY SCRUBBE R 

ISOUDS ( DSS ) 

BHD OUMP 8 

BAGHOUSE 

. MAIN STACK -

CARBON 

INJECTION 

SYSTEM 

BAGHOUSE 

ORY SCRUBBER 1 

|S0L!DS ( OSS ) 

END DUMP 

XDQOOV 

FUELSAIOUID WASTE FLOW 

COMBUSTION AIR FLOW 

STACK -GAS FLOW 

ASH FLOW 

SOUD- WASTE FLOW 

LIM? SLURRY FLOW 

2-5 

VES017348 
2.2 Process Operating Data and Waste Feedrates 

Process parameters that were monitored and recorded during the test by Veolia, and 

feedrates that result from the combination of waste feedrates with the respective waste feed 

analyses, are presented in this section. Process data recorded by Veolia every 15 seconds are used to 

create one-minute averages (OMAs). The DCS calculates hourly rolling averages (HRAs) for 

applicable parameters using the OMA from the first minute and the OMAs from previous 59 

minutes of data. The raw data from Veoha's DCS are provided in Appendix C. 

2.2.1 Unit 2 

Process data and waste and parameter feedrates have been determined and are presented for 

the time periods over the collection of the stack gas samphng trains for particulate matter (EPA 

Method 5), HC1/C12 (Modified EPA Method 26A), metals (EPA Method 29), and dioxins/furans 

(SW-846 Method 0023A) and THC (EPA Method 25A). 

Table 2-1 presents process data summaries and waste feedrates during the particulate matter 

(PM) stack gas samphng of the first part of each test run for Unit 2. 

Table 2-2 presents process data summaries and waste feedrates during the HC1/C12 stack gas 

sampling of the second part of each test run for Unit 2. 

Table 2-3 presents process data summaries and waste feedrates during the metals stack gas 

sampling of the second part of each test run for Unit 2. 

Table 2-4 presents process data summaries and waste feedrates during the dioxins/furans 

and THC stack gas sampling and monitoring of the second part of each test run for Unit 2. 

2.2.2 Unit 3 

Table 2-5 presents process data summaries and waste feedrates during the PM stack gas 

samphng of the first part of each test run for Unit 3. 

Table 2-6 presents process data summaries and waste feedrates during the HCI/CI2 stack gas 

sampling of the second part of each test run for Unit 3. 

Table 2-7 presents process data summaries and waste feedrates during the metals stack gas 

sampling of the second part of each test run for Unit 3. 

Table 2-8 presents process data summaries and waste feedrates during the dioxins/furans 

and THC stack gas sampling and monitoring of the second part of each test run for Unit 3. 

2-6 

VES017349 
2.2.3 Unit 4 

Table 2-9 presents process data summaries and waste feedrates during the PM stack gas 

sampling of the first part of each test run for Unit 4. 

Table 2-10 presents process data summaries and waste feedrates during the HCI/CI2 stack 

gas sampling of the second part of each test run for Unit 4. 

Table 2-11 presents process data surnmaries and waste feedrates during the metals stack gas 

sampling of the second part of each test run for Unit 4. 

Table 2-12 presents process data summaries and waste feedrates during the dioxins/furans 

and THC stack gas sampling and monitoring of the second part of each test run for Unit 4. 

2.3 Spiking of Metals and Chlorine 

During the test of each incinerator, the metals chromium, lead, and mercury were spiked into 

the incinerator. The spiking was performed by Veoha. Details concerning the spiking of metals and 

chlorine are presented in Appendix B. 

The spiking rates of chlorine during the HQVCI2 stack samphng of the second part of each 

mn are presented in Table 2-13 for Unit 2, Table 2-14 for Unit 3, and 2-15 for Unit 4. 

The spiking rates of chromium, lead, mercury, and chlorine during the metals stack 

samphng of the second part of each run are presented in Table 2-16 for Unit 2, Table 2-17 for Unit 

3, and 2-18 for Unit 4. 

The spiking solutions of chromium (chromic acid) and mercury (mercuric nitrate) were 

sampled at the beginning, at port change, and at the end of the EPA Method 29 stack sampling for 

metals of each run, and each of these samples were analyzed for chromium or mercury, 

respectively. The analytical results for chromic acid and mercuric nitrate solutions are presented in 

Tables 2-19 and 2-20 for Unit 2, Tables 2-21 and 2-22 for Unit 3, and Tables 2-23 and 2-24 for Unit 

4. 

2-7 

VES017350 
Table 2-1. Unit 2 - Summary of Process Data1

 and Feedrates During 

the EPA Method 5 Stack Sampling for PM 

Operating Parameter Units Basis 

Run 1 

10-8-13 

11:50-13:00 

Run 2 

10-9-13 

09:45-10:53 

Run 3 

10-10-13 

09:15 -10:23 

Average 

Operating Parameter Units Basis 

Max Avg Min Max Avg Mill Max Avg Min Max Avg Min 

Stack Gas Flowrate ACFM HRA 15,015 14,955 14,876 15,529 15,430 15,324 15,690 15,374 15,240 15,412 15,253 15,147 

Low-Btu Liquid Waste Feedrate lb/hr OMA 1,947.7 1,277.2. 899.3 1,948.6 1,353.3 749.5 2850.8 1288.3 299.8 2,249.0 1,306.3 649.5 

High-Btu Liquid Waste Feedrate lb/hr OMA 1,009.9 1,000.2 982.6 1,142.2 997.7 792.3 1008.4 998.5 985.5 1,053.5 998.8 920.1 

Specialty Liquid Waste Feedrate lb/hr OMA 351.7 270.8 190.5 424.9 256.5 131.9 468.9 296.7 161.2 415.1 274.6 161.2 

Containerized Solids Waste Feedrate lb/hr OMA 734.9 738.4 746.0 739.8 

Ash Feedrate lb/hr OMA 501.6 513.2 494.2 . 503.0 

PCC Temperature °F OMA 1,735 1,708 1,640 1,733 1,691 1,650 1,759 1,698 1,638 1,742 1,699 1,643 

SCC Temperature °F OMA 1,894 1,880 1,867 1,893 1,880 1,869 1,900 1,882 1,870 1,896 1,881 1,869 

CO, Corrected to 7% O2 ppmvd OMA 0.00 0.00 0,00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

Baghouse Inlet Temperature2 °F OMA 440 420 396 444 420 400 438 421 393 441 420 396 

1

 Process data are the averages for the duration of the emissions sampling run for particulate matter in stack. 

2

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

Note: Values in bold used to develop OPL. 

2-8 
Table 2-2. Unit 2 - Summary of Process Data1

 and Feedrates During 

the Modified EPA Method 26A Stack Sampling for HCI/Cl2 

Operating Parameter Units Basis 

Run 1 

10-8-13 

15:40-16:40 

Run 3 

10-10-13 

12:30-13:30 

Run 5 

10-30-13 

12:45-13:45 

Average 

Operating Parameter Units Basis 

Max Avg Min Max Avg Min Max Avg Min Max Avg Min 

Stack Gas Flowrate actin HRA 15,410 15,278 15,142 15,854 15,652 15,310 15,407 15,225 15,038 15,557 15,385 15,163 

Low-Btu Liquid Waste Feedrate Ib/hr OMA, . 2,546.4 1,422.1 299.8 2,246.8 1,500.9 899.6 2,321.8 1,451,9 374.9 2371.6 1458.3 524.8 

High-Btu Liquid Waste Feedrate Ib/hr OMA 1.424.2 1,370.8 1,191.0 1,129.5 1.098.7 1,051.6 1.226.6 1.200.0 1,163.7 1260.1 1223.1 1135.5 

Specialty Liquid Waste Feedrate lb/hr OMA 586.1 485.9 410.3 527.5 398.2 307.7 615.4 440.8 263.7 576.3 441.6 327.2 

Containerized Solids Waste Feedrate2 lb/hr 884.8. 902.0 880.4 889.0 

Total Chlorine Feedrate lb/hr 208.0 207.5 202.8 206.1 

Sorbent Feedrate lb/lb Clj HRA 2.32 2.18 2.21 . 2.24 

Carrier Fluid Flowrate gal/lb Cl 2 HRA 1.93 1.85 1.92 1.90 

PCC Temperature °F OMA 1,772 1,707 1,648 1,813 1,721 1,631. 1,753 1,703 1,608 1,779 1,710 1,629 

SCC Temperature °F OMA 1,958 1,891 1,866 1,910 1,878 1,865 1,897 1,882 1,872 1,922 1,884 1,868 

CO, Corrected to 7% 02 ppmvd OMA 0.00 0,00 0.00 0.00 0.00 0.00 0.66 0.08 0.00 0.22 0.03 0.00 

Baghouse Inlet Temperature3 °F OMA 447 421 392 439 418 399 439 419 394 441 420 395 

1

 Process data are the averages for the duration of the emissions sampling mn for HC1/CU in stack. 

2

 Containerized Waste Feedrate includes the spikes of hexachloroethane, lead nitrate, and mercuric nitrate solution. 

3

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

Note: Values in bold used to develop OPL. 

2-9 

VES017352 
Table 2-3. Unit 2 - Summary of Process Data1

 and Feedrates During the EPA Method 29 Stack Sampling for Metais 

Operating Parameter Units Basis 

Runl 

10-8-13 

15:40-18:43 

Run 3 

10-10-13 

12:30-15:10 

RunS 

10-30-13 

12:45-15:32 

Average 

Operating Parameter Units Basis 

Max Avg Min Max Avg Min Max Avg Min Max Avg Min 

Stack Gas Flowrate acfm HRA 15,602 15,375 14,946 15,854 15.487 15,126 15,636 15,438 15,038 15,697 15,433 15,037 

Low-Btu Liquid Waste Feedrate lb/hr OMA 2,546.4 1,474.6 299.8 2,246.8 1,513.3 899.6 2,547.3 1,396.5 0.9 2,446.8 1,461.5 400.1 

High-Btu Liquid Waste Feedrate lb/hr OMA 1,424.2 1,289.1 1,191.0 1,129.5 1,098.9 1,051.6 1,226.6 1,164.6 973.4 1,260.1 1,184.2 1,072.0 

Specially Liquid Waste Feedrate lb/hr OMA 615.4 432.6 0.0 586.1 425.4 307.7 , 732.6 445.3 234.4 644.7 434.4 180.7 

Containerized Solids Waste Feedrate2 lb/hr 895.0 883.1 891.2 889.8 

SVM Feedrate lb/hr 61.9 61.7 62.0 61.9 

LVM Feedrate - Total Ib/hr 45.8 47.3 45.9 46.3 

LVM Feedrate - Pumpable lb/hr 45.9 47.3 45.9 46.3 

Mercury Feedrate lb/hr 0.00205 0.00206 0.00224 0.00212 

Total Chlorine Feedrate lb/hr 209.6 203.6 205.1 206.1 

Baghouse Inlet Temperature3 °F OMA 447 420 392 439 419 399 439 419 394 441 420 395 

PCC Temperature °F OMA 1,772 1,701 1,622 1,821 1.708 1,607 1,798 . 1,705 1,608 1,797 1,705 1,612 

SCC Temperature T OMA 1,958 1,875 1,714 1,962 1,886 1,865 1,897 1,882 1,857 1,939 1,881 1,812 

CO, Corrected to 1% 02 ppmvd OMA 0.00 0.00 0.00 0.00 0.00 0.00 1.25 0.13 0.00 0.42 0.04 0.00 

1

 Process data are the averages for the duration of the emissions sampling run for Metals in stack. 

2

 Containerized Waste Feedrate includes the spikes of hexachloroethane, lead nitrate, and mercuric nitrate solution. 

3

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

Note: Values in bold used to develop OPL. 

2-10 
Table 2-4. Unit 2 - Summary of Process Data1

 and Feedrates During 

the SW-846 Method 0023A Stack Sampling for Dioxins/Furans 

Operating Parameter Units Basis 

Runl 

10-8-13 

15:40-18:55 

Run 3 

10-10-13 

12:30-15:40 

Run 5 

October 30,2013 

12:45-16:02 

Average Operating Parameter Units Basis 

Max Avg Min Max Avg Min Max Avg Min Max Avg Min 

Stack Gas Flowrate ACFM HRA 15,602 15,345 14.862 15.854 15,462 15,126 15,636 15,416 15,038 15,697 15,408 15,009 

Low-Btu Liquid Waste Feedrate lb/hr OMA 2546.4 1470.7 299.8 2,246.8 1,510.2 899.6 2547 1383 1 2,446.8 1,454.7 400.1 

High-Btu Liquid Waste Feedrate lb/hr OMA 1424.2 1286.7 1191.0 1,129.5 1,099.2 1,051.6 1227 1140 973 1,260.1 1,175.2 1,072.0 

Specialty Liquid Waste Feedrate lb/hr OMA 615.4 429.8 0.0 586.1 425.5 307.7 733 445 234 644.7 433.6 180.7 

Containerized Solids Waste Feedrate2 lb/hr 897.9 867.4 874.1 879.8 

Total Waste Feedrate3 lb/hr HRA 4,473.4 4,317.4 4,060.4 4,369.4 4,110.4 2,944.5 4,446.7 4,119.3 3,707.4 4,429.8 4,182.4 3,570.8 

Total Pumpable Waste Feedrate3 lb/hr HRA 3,564.8 3,429.5 3,241.7 3,469.0 3,276.5 2,507.5 3,519.5 3,267.4 2,930.6 3,517.8 3,324.5 2,893.3 

PCC Temperature °F OMA 1,772 1,701 1,622 1,821 . 1,707 1,594 1,798 1,701 1,608 1,797 1,703 1,608 

SCC Temperature °F OMA 1,958 1,875 1,714 1,962 1,884 1,865 1,899 1,883 1,857 1,940 1,881 1,812 

Baghouse Inlet Temperature'' °F OMA 447 420 392 439 419 399 439 419 394 441 420 395 

CO, Corrected to 7% O2 ppmvd OMA 0.00 0.00 0.00 0.00 0.00 0.00 1.62 0.15 0.00 0.54 0.05 0.00 

1

 Process data are the averages for the duration of the emissions sampling run for Dioxins/Furans in stack. 

2

 Containerized Waste Feedrate includes the spikes of hexachloroethane, lead nitrate, and mercuric nitrate solution. 

3

 Total Waste Feedrate and Total Pumpable Waste Feedrate, maximum, average, and minimum, includes the average chromic acid solution feedrate. 

4

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

Note: Values in bold used to develop OPL. 

2-1 1 
Table 2-5. Unit 3 - Summary of Process Data1

 and Feedrates During 

the EPA Method 5 Stack Sampling for PM 

Operating Parameter Units Basis 

Runl 

10-15-13 

13:16-14:25 

Run 2 

10-16-13 

11:15-12:25 

Run 3 

10-17-13 

09:50-10:57 

Average 

Operating Parameter Units Basis 

Max Avg Min Max Avg Min Max Avg Min Max Avg Min 

Stack Gas Flowrate ACFM HRA 15,245 15,167 15,149 15,407 15,279 15.173 15,278 15,064 14,901 15,310 15,170 15,074 

Low-Btu Liquid Waste Feedrate Ib/hr OMA 1,636.3 1,292.9 890,5 1,635.2 955.4 ' 368.1 2,007.3 1,357.6 3675 1,759.6 1,202.0 542.2 

High-Btu Liquid Waste Feedrate lb/hr OMA 861.1 847.9 833.4 887.5 818.2 742.2 933.0 8753 810.1 893.8 847.1 795.2 

Specialty liquid Waste Feedrate lb/hr OMA 395.6 307.9 131.9 381.0 269.1 190.5 791.2 457.4 263.7 522.6 344.8 195.4 

Containerized Solids Waste Feedrate lb/hr OMA 738.3 742.1 720.7 733.7 

Ash Feedrate lb/hr OMA 499.9 510.9 566.5 525.8 

PCC Temperature "F OMA 1,766 1,707 1,650 1,726 1,704 1,684 1,742 1,704 1,614 1,744 1,705 1,649 

SCC Temperature °F OMA 1,899 1,890 1,883 1,895 1,885 1,878 1,902 1,885 1,863 1,899 1,887 1,875 

CO, Corrected to 7% 02 ppmvd OMA 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

Baghouse Inlet Temperature2 °F OMA 431 420 407 431 421 401 434 420 402 432 420 403 

' Process data are the averages for the duration of the emissions sampling run for particulate matter in stack. 

2

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

Note; Values in hold used to develop OPL 

2-1 2 

VES017355 
Table 2-6. Unit 3 - Summary of Process Data1

 and Feedrates During 

the Modified EPA Method 26A Stack Sampling for HCI/CI2 

Operating Parameter Units Basis 

Run 2 

10-16-13 

14:00-15:00 

Run 3 

10-17-13 

12:30-13:33 

Run 4 

10-18-13 

09:35-10:35 

Average 

Operating Parameter Units Basis 

Max Avg Min Max Avg Min Max Avg Min Max Avg Min 

Stack Gas Flowrate acfm HRA 15,517 15,395 15,088 15,360 15,204 14,840 15,228 15,193 15,116 15,378 15,264 15,015 

Low-Btu Liquid Waste Feedrate Ib/hr OMA 2,530.5 1,783.5 442.9 2,008.4 1,563.4 0.0 2,231.4 1,725.3 1,261.8 2,256.8 1,690.7 568.2 

High-Btu Liquid Waste Feedrate lb/hr OMA 1,053.0 977.2 926.8 1,212.3 1,151.9 1,039.1 1,263.1 1,163.5 1,003.3 1,176.1 1,097.6 989.7 

Specialty Liquid Waste Feedrate lb/hr OMA 380.9 177.5 87.9 556.8 407.7 322.3 410.3 248.8 146.5 449.3 •278.0 185.6 

Containerized Solids Waste Feedrate2 lb/hr 904.4 893.8 861.3 886.5 

Total Chlorine Feedrate lb/hr 207.0 206.0 201.0 204.7 

Sorbent Feedrate lb/lb CU HRA 2.13 1.99 2.13 2.09 

Carrier Fluid Flowrate gal/lb Cl 2 HRA 1.86 1.78 1.88 1.84 

PCC Temperature °F OMA 1,746 1,709 1,675 1,770 1,715 1,691 1,743 1,719 1,694 1,753 1,714 1,686 

SCC Temperature °F OMA 1,909 1,887 1,867 1,931 1,884 1,842 1,923 1,881 1,864 1,921 1,884 1,858 

CO, Corrected to 7% 02 ppmvd OMA 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

Baghouse Inlet Temperature3 "F OMA 430 . 420 395 433 420 380 429 415 385 431 418 386 

1

 Process data are tiie averages for the duration of the emissions sampling run for HO/G2 in stack. 

2

 Containerized Waste Feedrate includes the spikes of hexachloroethane, lead nitrate, and mercuric nitrate solution. 

3

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

Note: Values in bold used to develop OPL. 

2-13 
Table 2-7. Unit 3 - Summary of Process Data1

 and Feedrates During the EPA Method 29 Stack Sampling for Metals 

Operating Parameter Units Basis 

Run 2 

10-16-13 

14:00-16:50 

Run 3 

10-17-13 

12:30-15:25 

Run 4 

10-18-13 

09:35 -12:20 

Average Operating Parameter Units Basis 

Max Avg Mm Max Avg Min Max Avg Min Max Avg Min 

Stack Gas Flowrate acfm HRA 15,547 15,274 15,088 15.429 15,230 14,840 15,277 15,133 14,983 15,417 15,212 14,970 

Low-Btu Liquid Waste Feedrate lb/hr OMA 2,531.2 1,787.6 442.9 2,157.8 1,685.3 0.0 2,231.4 1,707.4 1,261.8 2,306.8 1,726.8 568.2 

High-Btu Liquid Waste Feedrate lb/hi OMA 1,114.5 1,043.9 926.8 1,212.3 1,166.5 1,039.1 1,263.1 1,197.7 1,001.3 1,196.6 1,136.0 989.1 

Specialty Liquid Waste Feedrate lb/hr OMA 410.3 202.9 0.0 556.8 350.0 0.0 410.3 244.8 146.5 459.1 265.9 48.8 

Containerized Solids Waste Feedrate2 lb/hr 890.9 888.0 873.6 884.2 

SVM Feedrate ib/hr 62.1 62.5 62.2 62.3 

LVM Feedrate - Total lb/hr 46.3 46.1 45.7 46.1 

LVM Feedrate - Pumpable lb/hr 46.3 46.1 45.7 46.0 

Mercury Feedrate Ib/hr 0.00221 0.00214 0.00227 0.00221 

Total Chlorine Feedrate lb/hr 204.2 204.6 203.7 204.2 

Baghouse Inlet Temperature3 °F OMA 430 419 395 433 420 380 436 421 385 433 420 386 

PCC Temperature °F OMA 1,752 1,710 1,675 1,770 1,707 1,657 1,743 1,708 1,610 1,755 1,708 1,647 

SCC Temperature °F OMA 1,909 1,885 1,867 1,931 1,885 1,842 1,923 1,886 1,864 1,921 1,885 1,858 

CO, Corrected to 7% 02 ppmvd OMA 0.00 O.OO 0.00 0.00 0.00 0.00 0.00 0.00 o.oo 0.00 0.00 0.00 

1

 Process data arc the averages for tie duration of the emissions sampling run for Metals in stack. 

2

 Containerized Waste Feedrate includes the spikes of hexachloroethane, lead nitrate, and mercuric nitrate solution. 

3

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

Note: Values in bold used to develop OPL. 

2-14 
Table 2-8. Unit 3 - Summary of Process Data1

 and Feedrates During 

the SW-846 Method 0023A Stack Sampling for Dioxins/Furans 

Operating Parameter Units Basis 

Run 2 

10-161-13 

14:00 -17:20 . 

Run 3 

10-17-13 

12:30 -15:55 

Run 4 

10-18-13 

09:35 -12:50 

Average Operating Parameter Units Basis 

Max Avg Min Max Avg Min Max Avg Min Max Avg Min 

Stack Gas Flowrate ACFM HRA 15,547 15,248 15,088 15,429 15,219 14,840 15,277 15,125 14,983 15,417 15,197 14,970 

Low-Btu Liquid Waste Feedrate lb/hr OMA 2,531.2 1,806.5 442.9 2,157.8 1,688.0 0.0 2,231.4 1,718.8 1,261.8 2,306.8 1,737.7 568.2 

High-Btu Liquid Waste Feedrate lb/hr OMA 1,114.5 1,052.3 926.8 1.212.3 1,167.4 1,039.1 1,263.1 1,188.4 805.7 1,196.6 1,136.0 923.9 

Specialty Liquid Waste Feedrate lb/hr OMA 410.3 199.6 0.0 556.8 340.4 0.0 410.3 246.2 146.5 459,1 262.1 48.8 

Containerized Solids Waste Feedrate2 lb/hr 887.2 870.5 872.5 876.7 

Total Waste Feedrate3 lb/hr HRA 4,288.0 4,057.1 2,491.4 4,503.5 4,250.4 2,904.3 4,437.3 4,233.2 3,734.8 4,409.6 4,180.2 3,043.5 

Total Pumpable Waste Feedrate3 lb/hr HRA 3,412.8 3,209.1 2,055.4 3,613.3 3,410.5 2,467.1 3,556.0 3,393.0 3,238.5 3,527.4 3,337.5 2,587.0 

PCC Temperature °F OMA 1,752 1,709 1,675 1,770 1,707 1,657 1,757 1,712 1,610 1,760 1,709 1,647 

SCC Temperature °F OMA 1,909 1.885 1,867 1,931 1,885 1,842 1,923 1,884 1.864 1,921 1,885 1,858 

Baghouse Inlet Temperature' °F OMA. 430 419 395 433 421 380 436 420 385 433 420 386 

CO, Corrected to 7% 02 ppmvd OMA 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

1

 Process data are the averages for the duration of the emissions sampling tun for Dioxins/Furans in stack. 

2

 Containerized Waste Feedrate includes the spikes of hexacbloroetliane, lead nitrate, and mercuric nitrate solution. 

3

 Total Waste Feedrate and Total Pumpable Waste Feedrate, maximum, average, and minimum, mcludes the average chromic acid solution feedrate. 

4

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

Note: Values in bold used to develop OPL 

2-15 

VES017358 
Table 2-9. Unit 4 - Summary of Process Data1

 and Feedrates During 

the EPA Method 5 Stack Sampling for PM 

Operating Parameter Units Basis 

Runl 

10-23-13 

09:30-10:42 

Run 3 

10-25-13 

09:35 -10:40 

Run 4 

10-25-13 

10:50-11:55 

Average Operating Parameter Units Basis 

Max Avg Min Max Avg Min Max Avg Min Max Avg Min 

Stack Gas Flowrate ACFM HRA 37,755 37,632 37,333 37,997 37,824 37,479 37,647 36,949 36,518 37,800 37,468 37,110 

Low-Btu Liquid Waste to Kiln Feedrate lb/hr OMA 2,080.6 1,899.6 1,646.9 2,180.2 1,901.0 1,730.0 1,957.9 1,896.8 1,807.7 2,072.9 1,899.2 1,728.2 

High-Btu Liquid Waste to Kiln Feedrate lb/hr OMA 1,124.8 1,101.4 1,081.3 1,403.2 1,098.1 1,010.0 1,200.5 1,108.9 996.8 1,242.8 1,102.8 1,029.4 

Liquid Waste to SCC Feedrate lb/hr OMA 1,185.5 1,095.6 1,003.0 1,158.5 1,100.7 1,026.9 1,153.8 1,102.8 1,068.8 1,166.0 1,099.7 1,032.9 

Containerized Solids Waste Feedrate lb/hr OMA 565.8 568.6 553.8 562.8 

Bulk Solids Waste Feedrate lb/hr OMA 6,286.7 6,408.0 5,992.6 6,229.1 

Ash Feedrate lb/hr OMA 4,806.0 4,835.6 4,689.9 4,777.2 

PCC Temperature °F OMA 1,631 1,591 1,537 1,623 1,574 1,503 1,601 1,559 1,508 1,618 1,575 1,516 

SCC Temperature "F OMA 1,909 1,885 1,866 1,905 1,886 1,863 1,896 1,882 1,870 1,903 1,884 1,866 

CO, Corrected to 7% 02 ppmvd OMA 0.33 0.14 0.00 0.26 0.09 O.OO 0.21 0.08 0.00 0.27 0.10 0.00 

Baghouse Inlet Temperature2 °F OMA 402 398 392 403 397 391 407 . 401 396 404 399 393 

Carbon Injection Rate lb/hr OMA 6.7 6.2 5.9 6.7 6.2 5.9 7.0 6.2 5.7 6.8 6.2 5.8 

1

 Process data are the averages for the duration of the emissions sampling run for particulate matter in stack. 

2

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

Note: Values in bold used to develop OPL 

2-16 
Table 2-10. Unit 4 - Summary of Process Data1

 and Feedrates During 

the Modified EPA Method 26A Stack Sampling for HCI/CI-. 

Operating Parameter Units Basis 

Run 1 

10-23-13 

12:36-13:36 

Run 2 

10-24-13 

12:35-13:35 

Run 3 

10-25-13 

13:35-14:35 

Average Operating Parameter Units Basis 

Max Avg Min Max Avg Min Max Avg Min Max Avg Min 

Stack Gas Flowrate acfm HRA 38,042 37,935 37,857 37,265 37,170 37,063 36,872 36,754 36,572 37,393 37,286 37,164 

Low-Btu Liquid Waste to Kiln Feedrate lb/hr OMA 2,105.9 1,943.7 0.0 2,057.1 1,996.5 1,863.0 2,068.1 1,999.6 1,942.1 2,077.0 1,980.0 1,268.4 

High-Btu Liquid Waste to Kiln Feedrate lb/hr OMA 1,224.9 1,167.0 0.0 1.230.8 1,205.4 1.172.2 1,294.3 1.201.0 1.094.0 1.250.0 1.191.2 755.4 

Liquid Waste to SCC Feedrate lb/hr OMA 1,261.5 1,165.6 0.0 1,240.6 1,203.1 1,126.5 1,238.0 1,196.3 1,171.4 1,246.7 1,188.3 766.0 

Containerized Solids Waste Feedrate1 lb/hr 860.0 857.0 843.0 853.3 

Bulk Solids Waste Feedrate Ib/hr 6,093.0 5,448.0 5739.0 5,760.0 

Total Chlorine Feedrate lb/hr 203.0 203.5 203.2 203.2 

Sorbent Feedrate 

Lb/lb 

Ck HRA Z23 2.07 2.07 2.13 

Carrier Fluid Flowrate 

Gal/lb 

Cl 2 

HRA 3.16 3.07 3.07 3.10 

PCC Temperature °F OMA 1,635 1,589 1,493 1,623 1,569 1,507 1,567 1,513 1,460 1,609 1,557 1,487 

SCC Temperature °F OMA 1,909 1,883 1,801 1,901 1,880 1,838 1,905 1,878 1,847 1,905 1,880 1,828 

CO, Corrected to 7% 02 ppmvd OMA 0.23 0.08 0.00 0.21 0,06 0.00 0.27 0.09 0.00 0.24 0.08 0.00 

Baghouse inlet Temperature"' °F OMA 409 398 383 403 399 393 406 400 392 406 399 389 

Carbon Injection Rate lb/hr OMA 6.7 6.0 0.0 6.5 6.2 6.1 6.7 6.2 6.0 6.6 6.1 4.0 

1

 Process data are the averages for the duration of the emissions sampling run for HCl/Cli in stack, 

2

 Containerized Waste Feedrate includes the spikes of hexachloroethane, lead nitrate, and mercuric nitrate solution. 

3

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

Note: Values in bold used to develop OPL. 

2-17 
Table 2-11. Unit 4 - Summary of Process Data1

 and Feedrates During the EPA Method 29 Stack Sampling for Metals 

Operating Parameter Units Basis 

Runl 

10-23-13 

12:36-15:20 

Sun 2 

10-24-13 

12:35-15:15 

Run 3 

10-25-13 

13:35 -16:11 

Average Operating Parameter Units Basis 

Max Avg Mm Max Avg Min Max Avg Min Max Avg Min 

Stack Gas Flowrate acfm HRA 38,042 37,659 37,010 37,267 37,087 36,864 38,297 37,199 36,572 37,869 37,315 36,815 

Low-Btu Liquid Waste to Kim Feedrate lb/hr OMA 2,105.9 1,978.5 0.0 2,113.9 1,986.6 1,711.7 2,072.2 1,999.0 1,939.2 2,097.3 1,988.0 1,217.0 

High-Btu Liquid Waste to Kiln Feedrate lb/hr OMA 1,232.7 1,189.2 0.0 1,239.1 1,201.2 1,159.0 1,340.2 1,201.8 1,094.0 1,270.7 1,197.4 751.0 

Liquid Waste to SCC Feedrate lb/hr OMA 1,261.5 1,186.2 0.0 1,240.6 1,201.5 1,077.4 1,238.0 1,196.2 1,167.1 1,246.7 1,194.6 748.1 

Containerized Solids Waste Feedrate2 lb/hi 862.7 849.0 856.5 856.1 

Bulk Solids Waste Feedrate Ib/hr 5,251.5 5,598.4 5345.0 5,398.3 

SVM Feedrate lb/hr 62.2 61.6 62.2 62.0 

LVM Feedrate-Total lb/hr 46.2 46.3 46.0 46.2 • 

LVM Feedrate - Pumpable lb/hr • 46.0 46.0 45.8 45.9 

Mercury Feedrate lb/hr 0.0402 0.0400 0.0403 0.0402 

Total Chlorine Feedrate lb/hr 205.3 204.1 205.5 205.0 

Baghouse Inlet Temperature3 °F OMA 409 399 383 409 399 390 410 399 388 410 399 387 

Carbon Injection Rate lb/hr OMA 6.7 6.1 0.0 6.7 6.2 5.9 6.9 6.2 5.9 6.8 6.2 3.9 

PCC Temperature °F OMA 1,666 1,582 1,493 1,623 1,571 1,507 1,602 1,525 1,460 1,631 1,559 1,487 

SCC Temperature °F OMA 1,928 1,885 1,801 1,901 1,879 1,838 1,912 1,879 1,831 1,914 1,881 1,823 

CO, Corrected to 1% 02 ppmvd OMA 0.23 0.08 0.00 0.21 0.06 0.00 0.27 0.08 0.00 0.24 0.07 0.00 

1

 Process data are the averages for the duration of the emissions sampling run for metals in stack. 

1

 Containerized Waste Feedrate includes the spikes of hexachloroethane, lead nitrate, and mercuric nitrate solution. 

3

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

Note: Values in bold used to develop OPL. 

2-18 
Table 2-12. Unit 4 - Summary of Process Data1

 and Feedrates During 

the SW-846 Method 0023A Stack Sampling for Dioxins/Furans 

Operating Parameter Units Basis 

Runl 

10-23-13 

12:36-15:50 

Run 2 

10-24-13 

12:35-15:45 

Run 3 

10-25-13 

13:35 -16:41 

Average Operating Parameter Units Basis 

Max Avg Min Max Avg Min Max Avg Min Max Avg Min 

Stack Gas Flowrate ACFM HRA 38,042 37,547 36,881 37,267 37,028 36,454 38.297 37,325 36,572 37,869 37,300 36,635 

Low-Btu Liquid Waste to Kiln Feedrate lb/hr OMA 2,105.9 1,982.8 0.0 2,113.9 1,950.9 1,711.7 2,072.2 1,998.3 1,939.2 2,097.3 1,977.4 1,217.0 

High-Btu Liquid Waste to Kiln Feedrate lb/hr OMA . 1,232.7 1,190.9 0.0 1,239.1 1,201.0 1,159.0 1,340.2 1,200.9 1,094.0 1,270.7 1,197.6 751.0 

Liquid Waste to SCC Feedrate lb/hr OMA 1,261,5 1,187.5 0.0 1,240.6 1,201.3 1,077.4 1,238.0 1,196.9 1,167.1 1,246.7 • 1,195.2 748.1 

Containerized Solids Waste Feedrate2 lb/hr 862.6 • 841.6 854.2 852.8 

Bulk Solids Waste Feedrate lb/hr 5,322.4 5,090.8 5,284.2 5,232.5 

Total Waste Feedrate to PCC3 lb/hr HRA 10,621.4 9,551.1 7,192.1 10,662.8 9,512.7 7,097.6 10,610.4 9,407.6 6,913.6 10,631.5 9,490.5 7,067.8 

Total Pumpable Waste Feedrate to PCC' lb/hr HRA 3,466.7 3,418,2 3,095.1 3,465.0 3,430.7 3,151.6 3,473.2 3,447.0 3,129.6 3,468.3 3,432.0 3,125.4 

Total Waste Feedrate to SCC (Pumpable) lb/hr HRA 1,201.9 1,184.2 1,078.0 1,207.0 1,197.8 1,082.2 1,199.5 1,192.4 1,077.6 1,202.8 1,191.5 1,079.3 

PCC Temperature °F OMA 1,666 1,580 1,493 1,626 1,575 1,507 1,602 1,527 1,460 1,632 1,561 1,487 

SCC Temperature op OMA 1,928 1,885 1,801 1,910 1,881 1,838 1,912 1,879 1,831 1,917 1,881 1,823 

Baghouse Inlet Temperature" °F OMA 410 400 383 409 399 390 413 399 388 411 399 387 

Carbon Injection Rate lb/hr OMA 6.8 6.2 0.0 7.1 6.2 5.9 6.9 6.2 5.9 6.9 6.2 3.9 

CO, Corrected to 7% 02 • ppmvd OMA 0.23 0.07 0.00 0.21 0.06 0.00 0.27 0.08 0.00 0.24 0.07 0.00 

' Process data are the averages for the duration of the emissions sampling run for Dioxins/Furans in stack. 

1

 Containerized Waste Feedrate mcludes the spikes of hexachloroethane, lead nitrate, and mercuric nitrate solution. 

3

 Total Waste Feedrate to PCC and Total Pumpable Waste Feedrate to PCC, maximum, average, and mmimum, iuclude the average chromic acid solution feedrate. 

4

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

Note: Values in bold used to develop OPL. 

2-19 

VES017362 
Table 2-13. Unit 2 - Chlorine Spiking Rates During the HCI/Cl2

 Stack Sampling 

Spiking 

Constituent 

Spiking Rate (lbs/hr) | 

Spiking 

Constituent Target 

Run l 

10-8-13 

15:40 -16:40 

Run 3 

10-10-13 

12:30-13:30 

Run 5 ' 1 

10-30-13 

12:45-13:45 | 

Chlorine 200-250 197.9 203.1 197.9 | 

Table 2-14. Unit 3 - Chlorine Spiking Rates During the HCl/CI2 Stack Sampling 

Spiking 

Constituent 

Spiking Rate (lbs/hr) 

Spiking 

Constituent Target 

Run 2 

10-16-13 

14:00 -15:00 

Run 3 

10-17-13 

12:30 -13:33 

Run 4 

10-18-13 

09:35 -10:35 

Chlorine 200-250 203.1 203.3 197.9 

Table 2-15. Unit 4 - Chlorine Spiking Rates During the HCI/CI2 Stack Sampling . 

Spiking 

Constituent 

Spiking Rate (lbs/hr) 

Spiking 

Constituent Target 

Run 1 

10-23-13 

12:36 -13:36 

Run 2 

10-24-13 

12:35 -13:35 

Run 3 

10-25-13 

13:35 -14:35 

Chlorine 200-250 197.9 197.9 197.9 

2-20 

VES017363 
Table 2-16. Unit 2 - Spiking Rates During the Metals Stack Sampling 

Spiking 

Constituent 

Spiking Rate (lbs/hr) 

Spiking 

Constituent Target 

Run l 

10-8-13 

15:40 -18:43 

Run 3 

10-10-13 

12:30 -15:10 

Run 5 

10-30-13 

12:45 -15:32 

Chromium 40-45 45.8 47.3 45.8 

Lead 60-65 61.9 61.7 62.0 

Mercury 0.001 - 0.003 0.00196 0.00196 0.00204 

Chlorine 200 - 250 199.7 199.2 200.2 

Table 2-17. Unit 3 - Spiking Rates During the Metals Stack Sampling 

I 

Spiking 

Constituent 

I Spiking Rate (lbs/hr) 

Spiking 

Constituent Target 

Run 2 

10-16-13 

14:00 -16:50 

Run 3 

10-17-13 

12:30 -15:25 

Run 4 

10-18-13 

09:35 -12:20 

Chromium 40-45 46.3 46.1 45.7 

I Lead 60-65 62.1 62.5 62.2 

Mercury 0.001 - 0.003 0.00204 0.00200 0.00209 

Chlorine 200-250 200.3 201.7 200.7 

Table 2-18. Unit 4 - Spiking Rates During the Metals Stack Sampling 

Spiking 

Constituent 

Spiking Rate (lbs/hr) 

Spiking 

Constituent Target 

Run l 

10-23-13 

12:36 -15:20 

Run 2 

10-24-13 

12:35 -15:15 

Run 3 

10-25-13 

13:35 -16:11 

Chromium 40-45 46.0 46.0 45.8 

Lead 60-65 62.0 61.1 62.0 

Mercury 0.02-0.06 0.0393 0.0388 0.0394 

Chlorine 200 - 250 200.0 197.2 200.3 

2-21 

VES017364 
Table 2-19. Unit 2 - Analytical Results for tbe Chromium Spiking Solution 

Run l Run 3 Run 5 

Chromium 

C OA 

Concentration 

Analytical 

Result 

C O A 

Concentration 

Analytical 

Result 

C OA 

Concentration 

Analytical 

Result 

(mg/kg) (mg/kg) (mg/kg) 

Beginning of Method 29 Sample 178,000 178,000 174,000 

Middle of Method 29 Sample 178,881 172,000 178,871 174,000 178,881 173,000 

End of Method 29 Sample 169,000 178,000 170,000 

Table 2-20. Unit 2 - Analytical Results for the Mercury Spiking Solution 

Run l Run 3 Run 5 

Mercury 

Calculated 

Concentration 

Analytical 

Result 

Calculated 

Concentration 

Analytical 

Result 

Calculated 

Concentration 

Analytical 

Result 

(pg/ml) (mg/kg) (Ug/ml) (mg/kg) (Mg/ml) (mg/kg) 

Beginning of Method 29 Sample 1,960 2,370 2,210 

Middle of Method 29 Sample 2,323 2,050 2,323 2,150 2,323 2,120 

End of Method 29 Sample 2,390 1,950 2,250 

2-22 

VES017365 
Table 2-21. Unit 3 - Analytical Results for the Chromium Spiking Solution 

Run 2 Run 3 Run 4 

Chromium 

C OA 

Concentration 

Analytical 

Result 

C OA 

Concentration 

Analytical 

Result 

C OA 

Concentration 

Analytical 

Result 

(mg/kg) (mg/kg) (mg/kg) 

Beginning of Method 29 Sample 176,000 176,000 176,000 

Middle of Method 29 Sample 179,137 173,000 179,137 1.79,000 179,137 172,000 

End of Method 29 Sample 177,000 174,000 173,000 

Table 2-22. Unit 3 - Analytical Results for the Mercury Spiking Solution 

Run 2 Run 3 Run 4 

Mercury 

Calculated 

Concentration 

Analytical 

Result 

Calculated 

Concentration 

Analytical 

Result 

Calculated 

Concentration 

Analytical 

Result 

(Ug/ml) (mg/kg) (ug/ml) (mg/kg) (ug/ml) (mg/kg) 

Beginning of Method 29 Sample 2,420 2,460 2,480 

Middle of Method 29 Sample 2,323 2,380 2,323 2,390 2,323 2,500 

End of Method 29 Sample 2,380 2,480 2,480 

2-23 
Table 2-23. Unit 4 - Analytical Results for the Chromium Spiking Solution 

Run l Run 2 Run 3 

Chromium 

C O A 

Concentration 

Analytical 

Result 

C O A 

Concentration 

Analytical 

Result 

C OA 

Concentration 

Analytical 

Result 

(mg/kg) (mg/kg) (mg/kg) 

Beginning of Method 29 Sample 171,000 173,000 169,000 

Middle of Method 29 Sample 179,137 175,000 179,137 172,000 179,009 172,000 

End of Method 29 Sample 169,000 174,000 176,000 

Table 2-24. Unit 4 - Analytical Results for the Mercury Spiking Solution 

Run l Run 2 Run3 

Mercury 

Calculated 

Concentration 

Analytical 

Result 

Calculated 

Concentration 

Analytical 

Result 

Calculated 

Concentration 

Analytical 

Result 

(Mg/mi) (mg/kg) (Ug/ml) (mg/kg) (ug/ml) (mg/kg) 

Beginning of Method 29 Sample 21,300 19,700 22,000 

Middle of Method 29 Sample 23,228 18,700 23,228 19,900 23,228 21,300 

End of Method 29 Sample 19,300 21,000 21,400 

2-24 
3.0 Sampling, Analysis, and Monitoring Procedures 

The subsequent CPT was performed at one test condition on each of the three incinerators 

to demonstrate system performance and to establish appropriate operating parameter limits 

(OPLs) for all of the applicable standards of the HWC MACT. The CPT included three replicate 

sampling runs on each incinerator at the one test condition. Table 3-1 summarizes the parameters 

that were measured during the test of each of the three incinerators and the frequency of 

measurement. The CPT was conducted in accordance with the comprehensive performance test 

plans for Units 2, 3, and 4 (i.e. the CPT Plan) and Quality Assurance Project Plan (QAPjP) dated 

September 25,2013 that were approved by EPA Region 5. 

3.1 Sampling Locations and Procedures 

Samples were collected of solid, liquid, and gas streams during the CPT. Table 3-2 

summarizes the sampling methods for each stream and the parameters that were determined. 

Refer to the QAPjP for more detailed descriptions of the methods and the quality control 

activities for each method. Section 5.0 presents a discussion of the QA/QC activities performed 

for the CPT. 

3.1.1 Liquids Sampling Procedures 

Samples of the liquid waste feeds were collected every 15 minutes during each of the 

three runs of the CPT for each of the three incinerators beginning at the start of stack 

sampling through completion of stack sampling for both the first and second parts of the CPT. 

Individual samples (i.e., sub-samples) were collected every 15 minutes throughout the test, 

and composited for analysis. 

Samples of the liquid waste feeds were collected at 15-minute intervals during the 

collection of the Method 5 sampling train of the first part of each run of the test, and during 

the collection of the Modified Method 26A, Method 29, and Method 0023A sampling trains 

of the second part of each run of the test. Composite samples were prepared of the samples 

collected during each of the Method 5, Modified Method 26A, Method 29, and Method 

0023A sampling times. All of the composite liquid waste feed samples from the first part and 

the second part of the CPT were analyzed for ash, total chlorine, heat content, moisture, density, 

and viscosity. The composite liquid waste feed samples collected during the Method 29 stack 

sampling were also analyzed for metals (arsenic, beryllium, chromium, cadmium, lead, and 

mercury). 

3-1 

VES017368 
In addition to the collection of sub-samples every 15 minutes of the liquid wastes, 

individual samples were collected and archived for further analysis, if required. 

Samples of the chromium and mercury spiking solutions were collected in each run of 

the second part of the test of each incinerator. At the beginning, middle (at port change), and 

end of the Method 29 sampling of the second part of the test, samples of the chromium and 

mercury spiking solutions were collected. The individual samples of the chromium and 

mercury spiking solutions collected during each Method 29 sampling run of the test of each 

incinerator were analyzed for chromium or mercury, respectively. A fourth sample of tlie 

chromium and mercury spiking solutions was collected at the completion of the Method 

0023A sampling train. This fourth sample was archived (i.e., not analyzed). 

Liquid waste samples were collected upstream of any metal spiking location. Split 

samples of the composite liquid waste feed and tlie chromium and mercury spiking solutions from 

one run were taken by the Illinois EPA and/or U.S. EPA Region 5. 

3-2 

VES017369 
Table 3-1. Measurement Frequency 

Sample Frequency for 

Stream/Parameters 

the Subsequent CPT 

First Part Second Part 

Liquid Waste Feed 

Ash 3 3 

Chlorine •3 3 

Moisture 3 3 

Heating Value 3 3 

Viscosity, Density 3 3 

Metals 3' 

Solid Waste Feed-Containerized and Bulk (Unit 4) 

Ash - 3 3 

Chlorine 3 3 

Moisture 3 3 

Heating Value 3 3 

Metals 3' 

Spiking Materials2 

Mercury Spiking Solution 3 

Lead Solid Spiking Material 3 

Chromium Spiking Solution 3 

Chlorine Solid Spiking Material (if spiked) 3 

Stack Gas 

Metals . 3

1 

Particulate Matter 3 

HC1/C12 3 

Dioxins/Furans 3 

co2, o2 Continuous Continuous3 

Total Hydrocarbons Continuous3 

Moisture Concurrent with Concurrent with 

isokinetic sampling isokinetic sampling 

• co,o 2

4 Continuous Continuous 

1

 Analysis is for As, Be, Cd, Cr, Pb, and Hg . 

2

 Each collected sample of the mercury and chromium spiking solutions were analyzed for the target spiking 

metal. Samples of the lead and chlorine spiking materials were archived. 

3

 Allowing for hourly calibration of the THC monitor. 

4

 Plant monitors. 

3-3 

VES017370 
Table 3-2. Sampling Methods 

Stream Sampling Method Sampling Frequency 

Compositing 

Approach 

Analytical 

Parameters 

Liquid Waste Feed 

Units 2 and 3 

Low-Btu 

High-Btu 

Liquid 

(Specialty) 

Waste 

Unit 4 

Low-Btu to 

Kiln 

High-Btu to 

Kiln 

Liquid Waste 

to SCC 

Tap 

(Method S004) 

First part ofthe test 

condition - Every 15 

Minutes During 

Method 5 sampling 

Second part of the test 

condition - Every 15 

Minutes During 

Modified Method 

26A, Method 29, and 

Method 0023A 

-sampling 

Subsamples from 

each test period 

composited 

Ash 

Chlorine 

Moisture 

Heating Value 

Density 

Viscosity 

Metals1 

Sohd Waste Feed 

Units 2 and 3 

Containerized 

Unit 4 

Containerized 

- Bulk 

Grab or Scoop 

(Method S007) - Solids 

First part of the test 

condition - Every 15 

Minutes During 

Method 5 sampling 

Second part of the test 

condition - Every 15 

Minutes During 

Modified Method 

26A, Method 29, and 

Method 0023A 

sampling 

Subsamples from 

each test period 

composited 

Ash 

Chlorine 

Moisture 

Heating Value 

Metals1 

Chromium Spiking 

Solution 

Tap 

(Method S004) 

Second part of the test 

condition - Beginning, 

middle, and end of 

Method 29 sampling 

End of Method 0023A 

sampling 

Subsamples 

collected during 

Method 29 sampling 

analyzed 

Subsample collected 

at end of Method 

0023A sampling 

archived 

Chromium 

Mercury Spiking 

Solution 

Grab 

Second part of the test 

condition - Beginning, 

middle, and end of 

Method 29 sampling 

End of Method 0023A 

sampling 

Subsamples 

collected during 

Method 29 sampling 

analyzed 

Subsample collected 

at end of Method 

0023A sampling 

archived 

Mercury 

3-4 

VES017371 
Table 3-2. (continued) Sampling Methods 

Stream Sampling Method Sampling Frequency 

Compositing 

Approach 

Analytical 

Parameters 

Lead and Chlorine 

Spiking Materials 

Grab 

Second part of the test 

condition - Beginning, 

middle, and end of 

Method 29 sampling 

End of Method 0023A 

sampling 

None-Archive Archive 

EPA Method 2 

Concurrent with 

isokinetic sampling for 

EPA Methods 5, 29, 

and SW-846 Method 

0023A 

NR Flowrate 

EPA Method 3A 

Concurrent with 

isokinetic sampling -

First and Second Parts 

ofthe Test 

NR 02

, C02 

EPA Method 4 

Concurrent with 

isokinetic.sampling -

First and Second Parts 

of the Test 

NR Moisture 

Stack Gas 

EPA Method 5 1+ hour collected 

isokineticany - First 

Part of the Test 

NR PM 

Stack Gas 

Modified EPA Method 26A 

1+ hour collected 

isokinetically at single 

point - Second Part of 

the Test 

NR HC1/C12 

EPA Method 29 

2+ hour collected 

isokinetically - Second 

Part of the Test 

NR Metals

 1 

SW-846 Method 0023A 

3+hour collected 

isokinetically - Second 

Part of the Test 

NR Dioxins/Furans 

EPA Method 25A 

Concurrent with 

isokinetic sampling -

Second Part of the 

Test 

NR THC 

Plant CEMS Continuous NR CO,0 2 

1

 Analysis for As, Be, Cd, Cr, Pb, and Hg only in samples from the second part of the test condition collected during Method 

29 stack sampling. 

NR = Not Required 

3-5 

VES017372 
3.1.2 Solids Sampling Procedures 

Samples of the containerized solid waste feed fed to Units 2,3, and 4, and the bulk 

solids fed to Unit 4, were collected every 15 minutes during the collection of the Method 5 

samphng train of the first part of each run of the test, and during the collection of the 

Modified Method 26A, Method 29, and Method 0023A sampling trains of the second part of 

each run of the test. Composite samples were prepared of the samples collected during each 

of the Method 5, Modified Method 26A, Method 29, and Method 0023A sampling times. All 

of the composite solid waste feed samples from the first part and the second part of the CPT 

were analyzed for ash, total chlorine, heat content, and moisture. The composite solid waste feed 

samples collected during the Method 29 stack sampling were also analyzed for metals (arsenic, 

beryllium, chromium, cadmium, lead, and mercury). 

In addition to the collection of sub-samples every 15 minutes of the solid wastes, 

individual samples were collected and archived for further analysis, if required. 

Spikes of solid lead and chlorine were added to the containerized solid waste in the test of 

each incinerator. Samples of the lead (as lead nitrate) and the chlorine (as hexachloroethane) were 

collected during the Method 29 stack sampling in the second part of the test. Three grab samples of 

the chlorine and lead spiking materials were collected at the begimiing, middle (at port change), 

and end of the Method 29 samphng of the second part of the test. A fourth sample of the lead and 

chlorine spiking materials was collected at the completion of the Method 0023A sampling train in 

the second part of the test. All samples of the lead and chlorine spiking materials were archived 

(i.e., not analyzed). Samples of the composite solid waste feeds and the chlorine and lead spiking 

solutions from one run were taken by the Illinois EPA and/or U.S. EPA Region 5. 

3.1.3 Stack Gas Sampling Procedures 

Stack gas emissions were sampled for determination of the parameters indicated in 

Tables 5-1 and 5-2. The stack samples collected using isokinetic sampling methods were 

particulate matter by EPA Method 5, HCI and Cl 2 using a Modified Method 26A, metals by EPA 

Method 29, and dioxins/furans by SW-846 Method 0023A. Table 3-3, Table 3-4, and Table 3-5 

present summaries of the sampling data for the isokinetic sampling trains for the CPT testing of 

Unit 2, Unit 3, and Unit 4, respectively. 

3-6 

VES017373 
Table 3-3. Unit 2 - Summary of Isokinetic Sampling 

Run Analytical Parameter Date Time 

Average 

Stack 

Temperature 

CF) 

Velocity 

(ft/sec) 

Flue Gas 

Moisture 

(%) (vol %) 

co2 

(vol %) 

Avg 

Flowrate 

(acfm) 

Avg 

Flowrate 

(dscfm) 

Volume 

at Meter 

(dscf) 

Isokinetic 

Sampling 

Rate 

(%) 

1 

PM 

10-8-13 

11:50-13:00 390 30.50 41.2 11.56 6.35 14,796 5,395 40.815 97.9 

1 

HC1/C12 

10-8-13 

15:40-16:40 391 29.97 45.1 10.08 7.95 14,537 4,942 37.384 103.5 

1 

Metals 

10-8-13 

15:40-18:43 389 • 31.41 45.5 10.08 7.95 15,235 5,156 84.952 107.1 

1 

Dioxins/Furans 

10-8-13 

15:40-18:55 387 30.05 44.7 10.08 7.95 14,578 5,017 121.164 104.6 

2 PM 10-9-13 09:45-10:53 390 31.07 41.6 11.23 6.56 15,070 5,451 42.356 100.5 

3 

PM 

10-10-13 

09:15-10:23 391 30.42 42.0 11.48 6.28 14,753 5,287 41.278 101.0 

3 

HCUC12 

10-10-13 

12:30-13:30 396 31.95 45.9 10.38 7.50 15,498 5,150 37.290 99.0 

3 

Metals 

10-10-13 

12:30-15:10 393 31.36 45.8 10.38 7.50 15,212 5,081 78.951 101.0 

3 

Dioxins/Furans 

10-10-13 

12:30-15:40 396 32.05 45.3 10.38 7.50 15,544 5,225 119.568 99.1 

5 

HC1/C12 

10-30-13 

12:45-13:45 392 31.21 43.8 10.50 7.25 15,138 5,225 36.879 96.1 

5 Metals 10-30-13 12:45-15:32 386 31.06 43.8 10.50 7.25 15,064 5,236 79.607 97.9 

Dioxins/Furans 

10-30-13 

12:45-16:02 389 33.10 42.9 10.50 7.25 16,056 5,650 124.921 95.3 

3-7 

VES017374 
Table 3-4. Unit 3 - Summary of Isokinetic Sampling 

Run Analytical Parameter Date Time 

Average 

Stack 

Temperature 

(°F) 

Velocity 

(ft/sec) 

Flue Gas 

Moisture 

(%) 

o2 

(vol %) 

co2 

(vol %) 

Avg 

Flowrate 

(acfhi) 

Avg 

Flowrate 

(dscfm) 

Volume 

at Meter 

(dscf) 

Isokinetic 

Sampling 

Rate 

(%) 

1 PM 10-15-13 13:16-14:25 365 29.94 38.3 12.87 5.31 14,523 5,675 41.229 98.9 

2 

PM 

10-16-13 

11:15-12:25 366 30.75 36.2 13.38 4.96 14,916 6,034 42.461 96.2 

2 

HCI/C12 

10-16-13 

14:00-15:00 368 30.98 41.6 11.19 6.88 15,028 5,542 36.088 101.6 

2 

Metals 

10-16-13 

14:00-16:50 367 30.68 43.5 11.19 6.88 14,882 5,319 71.708 103.6 

2 

Dioxins/Furans 

10-16-13 

14:00-17:20 367 30.92 42.9 11.19 6.88 14,996 5,420 106.303 102.5 

3 

PM 

10-17-13 

09:50-10:57 368 30.66 41.0 11.74 6.02 14,870 5,549 41.921 103.3 

3 

HC1/C12 

10-17-13 

12:30-13:33 366 30.35 43.2 10.72 7.36 14,721 5,293 34.597 101.9 

3 

Metals 

10-17-13 

12:30-15:25 367 30.22 44.5 10.72 7.36 14,658 5,150 69.016 102.9 

3 

Dioxins/Furans 

10-17-13 

12:30-15:55 367 30.72 44.4 10.72 7.36 14,901 5,248 102.724 102.3 

4 

HC1/C12 

10-18-13 

09:35-10:35 368 32.06 43.4 10.87 7.26 15,549 5,579 35.241 98.5 

4 Metals 10-18-13 09:35-12:20 368 31.52 44.1 10.87 7.26 15,292 5,414 71.540 101.5 

Dioxins/Furans 

10-18-13 

09:35-12:50 368 30.59 43.7 10.87 7.26 14,839 5,290 102.624 101.4 

3-8 
Table 3-5. Unit 4 - Summary of Isokinetic Sampling 

Run Analytical Parameter Date Time 

Average 

Stack 

Temperature 

CF) 

Velocity 

(ft/sec) 

Flue Gas 

Moisture 

(%) 

o2 

(vol %) 

co2 

(vol'%) 

Avg 

Flowrate 

(acfm) 

Avg 

Flowrate 

(dscfm) 

Volume 

at Meter 

(dscf) 

Isokinetic 

Sampling 

Rate 

(%) 

1 

PM 

10-23-13 

09:30-10:42 374 57.55 39.4 12.22 5.59 43,275 16,483 38.181 97.9 

1 

HC1/C12 

10-23-13 

12:36-13:36 377 60.30 39.6 12.27 5.86 45,345 17,157 39.935 99.1 

1 

Metals 

10-23-13 

12:36-15:20 371 57.26 39.7 12.27 5.86 43,061 16,382 76.068 100.1 

1 

Dioxins/Furans 

10-23-13 

12:36-15:50 370 55.12 39.2 12.27 5.86 41,455 15,919 110.791 100.7 

2 

HC1/C12 

10-24-13 

12:35-13:35 377 57.91 38.6 12.37 5.74 43,550 16,824 39.264 99.3 

2 Metals 10-24-13 12:35-15:15 370 57.72 38.6 12.37 5.74 43,410 16,917 76.498 97.5 

Dioxins/Furans 

10-24-13 

12:35-15:45 370 55.32 38.3 12.37 5.74 41,598 16,284 112.803 100.3 

3 

PM 

10-25-13 

09:35-10:40 372 57.35 38.7 12.48 5.45 43,126 16,847 39.691 100.3 

3 

HC1/C12 

10-25-13 

13:35-14:35 378 54.66 39.3 12.00 5.96 41,102 15,796 37.034 99.8 

3 

Metals 

10-25-13 

13:35-16:11 373 57.94 39.8 12.00 5.96 43,575 16,723 76.846 99.1 

3 

Dioxins/Furans 

10-25-13 

13:35-16:41 374 56.95 39.3 12.00 5.96 42,829 16,550 115.284 100.8 

4 PM 10-25-13 10:50-11:55 374 54.52 39.5 12.11 5.71 40,998 15,768 36.759 100.5 

3-9 

VES017376 
3.1.3.1 Sample Port Location 

The Unit 2 and Unit 3 stacks are 90-feet high and have an inside diameter of 39 inches. 

There are two sets of two orthogonal ports located at two shghtly different levels. Only the upper 

set of orthogonal ports are suitable for, and were used for, isokinetic sampling. An additional 

port located about four feet below the upper orthogonal ports, and about 45° between the 

orthogonal ports, was used for the Modified Method 26A sampling for HCI/CI2. The number of 

sampling points for the isokinetic sampling by Method 5, Method 29, and Method 0023A was 

determined in accordance with EPA Method 1. 

The Unit 4 stack is lOO-feet high and has an inside diameter of 48 inches. There are four 

orthogonal ports located at one level. An additional port located about four feet below the upper 

orthogonal ports, and about 45° between the orthogonal ports, was used for the Modified Method 

26A sampling for HCl/Cla. The number of sampling points for the isokinetic samphng by 

Method 5, Method 29, and Method 0023A was determined in accordance with EPA Method 1. 

3.1.3.2 EPA Methods 2 and 4 (Flowrate and Moisture) 

Concurrent with the performance of the isokinetic sampling trains, measurements were 

made to determine gas velocity by 40 CFR Part 60, Appendix A, Method 2, and moisture by 

Method 4. The absence of cyclonic flow was determined by performing a cyclonic flow check, 

prescribed in EPA Method 2, prior to the CPT testing of each incinerator. 

3.1.3.3 EPA Method 5 (PM) 

Samples for the determination of particulate matter (PM) in stack emissions were 

collected in the first part of the tests of each incinerator using EPA Method 5. This sample train 

consisted of the following components: 

• Glass (quartz) nozzle; 

• Heated, glass (quartz)-hned probe; 

• Heated filter with a Teflon filter support; 

• Optional empty knockout impinger; 

• Modified Greenburg-Srnith impinger containing 100 mL of DI water; 

• Greenburg-Srnith impinger containing 100 mL of DI water; 

• Empty Modified Greenburg-Srnith impinger; and 

• Modified Greenburg-Srnith impinger containing silica gel. 

The procedures specified in EPA Method 5 protocol were used to determine particulate matter. 

These procedures require the isokinetic extraction of particulate matter on a filter maintained at a 

controlled temperature between 223°F and 273°F. The particulate mass includes the mass 

3-10 

VES017377 
determined gravimetrically in the probe and nozzle rinse (PNR) with acetone, after evaporation 

and desiccation, and filter after desiccation. 

3.1.3.4 Modified EPA Method 26A (HCI/Cb) 

During the second part of the test of each incinerator, samples for the determination of 

HCI/CI2 in stack emissions were collected using a modification of EPA Method 26A proposed 

and approved by EPA Region 5. This sample train consisted of the following components: 

• Glass (quartz) nozzle; 

• Heated, glass (quartz)-lined probe; 

. • Heated Teflon mat filter with a Teflon® filter support; 

• Teflon® transfer line; 

• Optional empty knockout impinger; 

• Greenburg-Smith impinger containing 100 mL of 0.1 N H2SO4; 

• Greenburg-Srnith impinger containing 100 mL of 0.1 N H2SO4; 

• Modified Greenburg-Smith impinger containing 100 mL of 0.1 N NaOH; 

• Modified Greenburg-Smith impinger containing 100 mL of 0.1N NaOH; and 

• Modified Greenburg-Smith impinger containing silica gel. 

The procedures specified in EPA Method 5, as referenced in EPA Method 26A, were used for 

the isokinetic collection of the sample except that the sample was collected at a single point 

located at the center of the stack. A Teflon® union was used to connect the glass or quartz nozzle 

to the glass or quartz probe liner, and the filter and probe were kept at a temperature between 

248°F and 273T. A Teflon®-backed filter was used, as specified in EPA Method 26A. 

3.1.3.5 EPA Method 29 (Metals) 

Samples of the stack gas emissions were collected for the detennination of metals during 

the second part of the test of each incinerator, The stack gas samples were collected 

isokinetically for the HWG MACT metals As, Be, Cd, Cr, Pb, and Hg using Method 29 from 40 

CFR Part 60, Appendix A. 

This method is basically an EPA Method 5 sampling train with some very specific 

modifications: 

• Glass nozzle; 

• Heated, glass-lined probe; 

• Heated filter; 

3-11 

VES017378 
• Teflon transfer line; 

• Empty modified Greenburg-Smith impinger; 

• Modified Greenburg-Smith impinger containing 100 mL of 5% HN03 and 10% 

H2 0 2; 

• Greenburg-Smith impinger containing 100 mL of 5% HN0 3 and 10% H2 02; 

• Empty modified Greenburg-Smith impinger; 

• Modified Greenburg-Smith impinger containing 100 mL of 4% KMn04 and 10% 

H2S04; 

• Modified Greenburg-Smith impinger containing 100 mL of 4% KMn04 and 10% 

H2S04;and 

• Modified Greenburg-Smith, impinger containing silica gel. 

A Teflon® transfer line was used between the filter and the first impinger. This is done to address 

space limitations on the stack, to allow for ease in probe moving, and to minimize potential 

hazards moving the very large and heavy impinger box. 

Following samphng, the probe and nozzle of the sampling train were recovered using a 

brush containing no metal using 0.1 normal nitric acid. 

3.1.3.6 SW-846 Method 0023A (Dioxins/Furans) 

Stack gas emissions were sampled isokinetically for dioxins/furans in the second part of 

the test of each incinerator using SW-846 Method 0023A. 

The sampling train consists of the following components: 

• Glass nozzle; 

• Heated, glass-lined probe; 

• Heated filter; 

• Heated Teflon® transfer line; 

• Sorbent module; 

• Knock-out impinger; 

• Greenburg-Smith impinger containing 100 mL water; 

• Modified Greenburg-Smith impinger containing 100 mL water; and 

• Modified Greenburg-Smith impinger containing silica gel. 

From the heated filter, sample gas was passed through a heated Teflon® transfer line before 

entering the sorbent module. The sorbent module consisted of a water-cooled condenser and a 

3-12 

VES017379 
resin trap containing XAD-2 resin. The condenser is used to ensure that the gas entering the 

resin trap is below 68°F. 

i 

Isotopically-labeled dioxins/furans were spiked onto the XAD-2 resin both before field 

sampling (surrogate standards) and into appropriate places in the preparation prior to analysis 

after returning from the field. 

3.1.3.7 Continuous Emissions Monitoring (THC, C02 , CO and 02) 

CEMs were used to monitor the concentrations of total hydrocarbons (THC), carbon 

dioxide (CO2), carbon monoxide (CO), and oxygen (O2) in the stack gas. 

CO, corrected to 7% 0 2 is reported for the stack gases from permanent installation CEMS 

on each of the three incinerators. The concentrations of THC, CO2, and O2 in the stack gas were 

determined using EPA Methods 25A and 3A, respectively. CO2 and 0 2 were monitored using 

Method 3 A to detennine the stack gas composition (i.e., molecular weight) used to determine the 

flowrate of tlie stack gas, and to correct the stack sampling results to 7% oxygen. Both of these 

methods utilize continuous monitors. 

3.2 Analysis Procedures 

Samples collected during the CPT were analyzed for the parameters specified in 

Table 3-6. All analyses were performed by Test America Laboratories in Knoxville, TN. 

Analytical results for the waste feed samples are reported on an as-received or wet weight basis. 

Samples of the waste feed were not dried prior to analysis. 

Table 3-6. Summary of Analytical Methods 

Parameter Stream Analytical Method 

Moisture Stack Gas E PA Method 4 

Metals 

Waste Feeds, Spiking 

Solutions, Stack Gas 

ICPBS - SW-846 Method 6010B 

CVAAS - Hg, SW-846 Method 7470A 

or7471A 

PM Stack Gas Gravimetric - EPA Method 5 

HCl/Cl 2 Stack Gas IC - EPA Method 26A 

Dioxins/Furans Stack Gas HRGC/MS - SW-846 Method 8290A 

Composition/Physical Parameters Waste Feeds E PA and/or ASTM Standard Methods 

3-13 

VES017380 
3.2.1 Composition and Physical Parameters Analysis 

Samples of the waste feeds will be collected for determination of a number of chemical 

and physical parameters. Samples of the waste feeds were analyzed for the following parameters, 

hy the referenced standard methods: 

• Ash-ASTM Method ASTM D-482; 

• Total Chlorine-SW-846 Methods 5050 and 9056A; 

• Moisture - ASTM Method E-203 or D-4017(Karl-Fischer titration) for hquid waste, 

and ASTM Method D-5142 or D-160.3 (loss on drying) for solid waste; 

• Calorific Value - ASTM Method D-5865 or D-240; 

• Density-ASTM Method D-1475; and 

• Viscosity-ASTM Method D-445. 

3.2.2 Metals Analysis 

Waste feed samples were analyzed for metals using a trace level inductively coupled 

argon plasma emission spectroscopy (ICPES) and atomic absorption spectroscopy. Samples were 

prepared for analysis using SW-846 Method 3050B. The metals analyzed by ICPES (SW-846 

Method 6010B) are arsenic (As), beryllium (Be), cadmium (Cd), chromium (Cr), and lead (Pb). 

Mercury (Hg) was analyzed using Method 7471A of SW-846. Spiking solutions of chromium 

and mercury were analyzed for chromium and mercury, respectively. 

The Method 29 sampling train used to collect samples of the stack gas for metals was 

analyzed using ICPES according to SW-846 Method 6010B for arsenic (As), beryllium (Be), 

cadmium (Cd), chromium (Cr), and lead (Pb), and mercury was analyzed using Method 7470A 

of SW-846. 

3.2.3 PM Analysis 

The PM concentration of the stack gas was determined following 40 CFR 60, Appendix 

A, Method 5 protocols. The wash from the nozzle, probe liner, and glassware prior to the filter 

Q?NR) of the sampling train was evaporated, and the mass determined on an analytical balance. 

The filter recovered from the sampling train was desiccated, and weighed to determine the mass 

of particulate on the fdter. The combined mass from the filter and the evaporated wash are used 

with the total volume of gas sampled to determine the particulate loading. 

3.2.4 HCI/CIa Analysis 

The sulfuric acid and sodium hydroxide impinger catches and rinses from the Modified 

Method 26A samphng trains were analyzed for chloride ion concentrations using the analytical 

3-14 

VES017381 
approach specified in Method 26A. The Modified Method 26A sampling train was recovered to 

provide a rinse of the transfer line and contents and rinses of the acidic impingers (and knockout 

impinger) for determination of hydrogen chloride; and the contents and rinses of the alkaline 

impingers for determination of chlorine. Both were analyzed for chloride by ion chromatography 

(IC) for determination of chloride. The chloride found in the acid impingers (and rinses) is 

reported as HCI, and the chloride determined in the alkaline impingers (and rinses) is reported as 

CI2. Sodium thiosulfate was added to the collected alkaline impinger samples in the analytical 

laboratory before analysis. 

3.2.5 Dioxins/Furans Analysis 

Samples of the stack gas were collected using SW-846 Method 0023A, and were 

analyzed for dioxins/furans using SW-846 Method 8290A, high resolution gas chromatography 

(HRGC) with high resolution mass spectroscopy (HRMS) analytical technique. The analytical 

protocol includes quantitation of all dibenzodioxins and dibenzofurans including four or more 

chlorine atoms. The method provides congener class definition for each of the five congener 

groups (tetra-, penta-, hexa-, hepta-, and octa-). In addition, each individual isomer containing 

the 2,3,7,8-substitution pattern was individually quantified, 

Dioxins/furans concentrations are reported for: 

• Combination of the filter and all the rinses between the nozzle and filter; and 

• Combination of the sorbent and all the rinses between the filter and sorbent. 

3.3 Process Monitoring Procedures 

The incinerator systems are monitored to ensure operation is in accordance with the 

permitted conditions. During the performance test, the automatic waste feed cutoff systems were 

operational; however, AWFCO hinits in the current NOC were adjusted or disabled during the 

performance testing periods to allow target operations to be achieved. The CPT Plan prescribed a 

Continuous Monitoring System Performance Evaluation Test for each of the three incinerators. 

The Continuous Monitoring System Performance Evaluation Test Reports (CMSPETR) for the 

three incinerators are included as Appendix D. The raw process monitoring data from the CPT 

testing of each of the three incinerators are presented in Appendix C. 

3-15 

VES017382 
4.0 Results 

This section presents the results of the comprehensive performance test of Veoha's 

incinerators at Sauget. The analytical results for the waste feed streams and stack gas are 

presented in Sections 4.1 and 4.2. The collection of samples and the methods used for sampling 

and analysis are specified in the CPT Plan and QAPjP. 

Note that values presented in these tables (and throughout the report) are rounded to 

display an appropriate level of significance. All calculations are done with unrounded values, 

and therefore, it may not be possible to reproduce a calculated value exactly from the data shown 

in a table. It may be necessary to go to earlier tables, or the raw data in the appendices, to 

reproduce a calculated value exactly. 

4.1 Waste Feedstreams 

Four waste streams were sampled and analyzed in both the first part and the second part 

of each run of the CPT tests of Units 2 and 3, three liquid waste streams and one solid waste 

stream. All are fed to the primary combustion chamber (PCC). The streams sampled and 

analyzed are: 

• Low-Btu Liquid Waste; 

• High Btu Liquid Waste; 

• Liquid (Specialty) Waste; and 

• Containerized Solid Waste. 

Five waste streams were sampled and analyzed in both the first part and the second part 

of each run of the CPT test of Unit 4, three hquid waste streams and two solid waste streams . 

including two liquid wastes and two sohd wastes that were fed to the kiln (i.e., the primary 

combustion chamber - PCC), and one liquid waste that was fed to the secondary combustion 

chamber (SCC). The streams sampled and analyzed are: 

• Low-Btu Liquid Waste to Kiln; 

• High Btu Liquid Waste to Kiln; 

• Containerized Solid Waste; 

• Bulk Sohd Waste; and 

• Liquid Waste to the SCC. 

Composite samples were prepared of the samples collected during each of the Method 5 

sampling time in the first part of each test, and the Modified Method 26A, Method 29, and 

4-1 

VES017383 
Method 0023A samphng times of the second part of each test. All of the composite liquid 

waste feed samples from fhe first part and the second part of the CPT tests were analyzed for 

ash, total chlorine, heat content, moisture, density, and viscosity. All of the composite solid 

waste feed samples from the first part and the second part of the CPT tests were analyzed for 

ash, total chlorine, heat content, and moisture. The composite hquid and solid waste feed 

samples collected during the Method 29 stack samphng were also analyzed for metals (arsenic, 

beryllium, chromium, cadmium, lead, and mercury). 

Each sample was given a unique log number that identifies the project and unit, run 

number, and an identification code based upon the sample type and fraction. An example of the 

log number format follows: 

Proj-XY-ABC 

Where: 

Proj is a project specific identification; 

X Y represent the condition and run number; and 

A BC is an alphanumeric sequence describing the particular sample. 

Here is a description of the sample codes used for the waste samples in the CPT. 

VS2 (Veoha Sauget and unit number 2, 3, or 4) - Stream Code - Test 

Condition/Run Number/Part A or B - Sample Description 

Stream Codes: 

LWF = Liquid Waste Feed (to SCC Unit 4) 

HBW = High-Btu Liquid Waste (to Kiln Unit 4) 

LBW = Low-Btu Liquid Waste (to Kiln Unit 4) 

CS = Containerized Sohds (sohds material sampled from the box containers) 

BS Bulk Solids (Unit 4 only) 

CL = Chlorine Spiking Material (samples of the chlorine spiking material 

from the box containers) 

PB Lead Spiking Material (samples of the lead salts contained in the box 

containers) 

HG = Mercury Spiking Material (samples of the vials containing the mercury 

spiking solution in the box containers) 

CR = Chromium Spiking Solution 

4-2 

VES017384 
Test Condition/Run Number/Part A or B: 

Test Condition is "1" for all samples and all runs. 

Run Numbers typically are 1,2,& 3, however additional runs performed to replace 

aborted and/or repeated runs continue in sequence, 4, 5, etc. 

Part A refers to the test segment associated with the PM emissions testing (i.e., 

the first part of the test). 

Part B refers to the test segment associated with the HCI/CI2, Metals, and 

Dioxins/Furans emissions testing (i.e., the second part of the test). 

Sample Description: 

Waste and spiking material samples included individual grab samples for 

archiving, and composite samples specific to each emissions test period. 

These are labeled as follows: 

Individual grab samples are labeled with the suffix as: 

-Grab 1, -Grab 2, -Grab 3, etc. in sequential order. 

Composite samples were collected during each emissions samphng period and are 

represented by the following ID suffix: 

COMP1 = Composite sample collected during the PM emissions test 

period 

COMP2A = Composite sample collected during the HCI/CI2 emissions 

test period 

COMP2B = Composite sample collected during the Metals emissions 

test period 

COMP2C = Composite sample collected during the dioxins/furans 

emissions test period 

Note that there should not be any COMP2A, B, or C samples labeled with a " -

xxA-" run number, nor should there be any COMP1 samples with a "-xxB-" run 

number. 

Examples: 

VS2-HBW-15B-Grab 4 is the 4t h grab sample of High-Btu liquid waste collected 

for archive during Run 5-Part B on Unit 2. 

VS3-LWF-12A-COMP1 is the composite sample of the hquid waste feed 

collected for analysis during PM emissions Run 2 test period (Part A) on Unit 

3. 

Table 4-1 presents the analytical results for chlorine, ash, metals, heat content, moisture, 

density, and viscosity in the Low-Btu Liquid Waste fed to Unit 2. 

Table 4-2 presents fhe analytical results for chlorine, ash, metals, heat content, moisture, 

density, and viscosity in the High-Btu Liquid Waste fed to Unit 2. 

4-3 

VES017385 
Table 4-3 presents the analytical results for chlorine, ash, rnetals, heat content, moisture, 

density, and viscosity in the Specialty Liquid Waste fed to Unit 2. 

Table 4-4 presents the analytical results for chlorine, ash, metals, heat content, and 

moisture in the Containerized Sohd Waste fed to Unit 2. 

Table 4-5 presents the analytical results for chlorine, ash, metals, heat content, moisture, 

density, and viscosity in the Low-Btu Liquid Waste fed to Unit 3. 

Table 4-6 presents the analytical results for chlorine, ash, metals, heat content, moisture, 

density, and viscosity in the High-Btu Liquid Waste fed to Unit 3. 

Table 4-7 presents the analytical results for chlorine, ash, metals, heat content, moisture, 

density, and viscosity in the Specialty Liquid Waste fed to Unit 3. 

Table 4-8 presents the analytical results for chlorine, ash, metals, heat content, and 

moisture in the Containerized Solid Waste fed to Unit 3. 

Table 4-9 presents the analytical results for chlorine, ash, metals, heat content, moisture, 

density, and viscosity in the Low-Btu Liquid Waste fed to the kiln (PCC) of Unit 4. 

Table 4-10 presents the analytical results for chlorine, ash, metals, heat content, moisture, 

density, and viscosity in the High-Btu Liquid Waste fed to the kiln (PCC) of Unit 4. 

Table 4-11 presents the analytical results for chlorine, ash, metals, heat content, moisture, 

density, and viscosity in the Liquid Waste fed to the SCC of Unit 4. 

Table 4-12 presents the analytical results for chlorine, ash, metals, heat content, and 

moisture in the Containerized Sohd Waste fed to Unit 4. 

Table 4-13 presents the analytical results for chlorine, ash, metals, heat content, and 

moisture in the Bulk Solid Waste fed to Unit 4. 

The detailed analytical reports are presented in Appendix Gl. 

4-4 

VES017386 
Table 4-1. Unit 2 - Analytical Results for Chlorine, Ash, Metals, and Physical Parameters in the Low-Btu Liquid Waste Feed 

Analytical Parameter Units 

Runl Run 2 Run 3 Run 5 

Analytical Parameter Units 1 

PM 

2A 

HC1/C12 

2B 

Metals 

2C 

Dioxins/ 

Furans 

1 

PM 

1 

PM 

2A 

HC1/C12 

2B 

Metals 

- 2C 

Dioxins/ 

Furans 

2A 

HCI/CI 2 

2B 

Metals 

2C 

Dioxins/ 

Furans 

Chlorine mg/kg 345 340 347 363 346 374 404 364 393 340 357 372 

Ash mg/kg 3,140 2,940 2,970 2,990 2,960 3,250 3,860 3,180 3,130 3,130 3,100 2,940 

Arsenic mg/kg NA NA 2.7 NA NA NA NA 3.2 NA NA 2.1 NA 

Beryllium mg/kg NA NA <0.097 NA NA NA NA <0.096 NA NA <0.097 NA 

Cadmium mg/kg NA NA 7.2 NA NA NA NA 9.0 NA NA 7.0 NA 

Chromium mg/kg NA NA 0.8 NA NA NA NA 0.88 NA NA 0.74 NA 

Lead mg/kg NA NA 1.1 NA NA NA NA 1.7 NA NA 1.1 NA 

Mercury mg/kg NA NA 0.021 NA NA NA NA 0.042 NA NA 0.052 NA 

Percent Water % 98.1 98.0 98.2 98.3 97.9 98.4 97.5 96.6 98.2 99.9 99.0 99.2 

Heating Value Btu/lb <130 <130 <130 <130 <130 <130 <130 <130 <130 <130 178 <130 

Density g/m3 1.000 1.000 1.000 1.000 0.999 1.000 0.999 1.000 1.000 0.999 1.000 1.000 

Viscosity cSt 0.934 0.939 0.930 0.934 0.930 0.930 0.932 0.932 0.933 0.928 0.929 0.927 

4-5 

VES017387 
table 4-2. Unit 2 - Analytical Results for Chlorine, Ash, Metals, and Physical Parameters in the High-Btu Liquid Waste Feed 

Analytical Parameter Units 

Runl Run 2 Run 3 Run 5 

Analytical Parameter Units 1 

PM 

2A 

HC1/C12 

2B 

Metals 

2C 

Dioxins/ 

Furans 

1 

PM 

1 

PM 

2A 

HCI/C12 

2B 

Metals 

2C 

Dioxins/ 

Furans 

2A 

HC1/C12 

2B 

Metals 

2C 

Dioxins/ 

Furans 

Chlorine mg/kg 7,070 6,960 7,140 7,240 7,180 3,780 3,260 3,210 3,330 3,500 3,580 3,450. 

Ash mg/kg 1,350 1,030 1,100 1,040 1,010 1,180 557 582 551 2,080 1,210 1,350 

Arsenic mg/kg NA NA 8.3 NA NA NA NA 2.8 NA NA <0.32 NA 

Beryllium mg/kg NA NA <0.096 NA NA NA NA <0.099 NA NA <0.096 NA 

Cadmium mg/kg NA NA <0.076 NA NA NA NA <0.078 NA NA <0.076 NA 

Chromium mg/kg NA NA 0.26 NA NA NA NA <0.22 NA NA <0.21 NA 

Lead mg/kg NA NA 1,0 NA NA NA NA 0.67 NA NA 6.7 NA 

Mercury mg/kg NA NA 0.026 NA NA NA NA 0.021 NA NA 0.096 NA 

Percent Water % 22.1 21.9 22.1 21.9 21.8 20.6 20.0 20.2 20.3 27.6 28.1 27.8 

Heating Value Btu/lb 9,090 9,000 9,040 9,050 9,040 9,120 9,160 9,130 9,150 8,630 8,630 8,660 

Density g/m3 O.880 0.879 0.880 0.878 0.879 0.875 0.868 0.869 0.869 0.883 0.883 0.883 

Viscosity cSt 1.31 1.30 1.29 1.29 1.28 1.19 1.18 1.18 1.17 1.60 1.62 1.60 
Table 4-3. Unit 2 - Analytical Results for Chlorine, Ash, Metals, and Physical Parameters in the Specialty Liquid Waste Feed 

Analytical Parameter Units 

Runl Run 2 Run 3 Run 5 

Analytical Parameter Units 1 

PM 

2A 

HCI/C12 

2B 

Metals 

2C 

Dioxins/ 

Furans 

1 

PM 

1 

PM 

2A 

HCyci 2 

2B 

Metals 

2C 

Dioxins/ 

Furans 

2A 

HC1/C12 

2B 

Metals 

2C 

Dioxins/ 

Furans 

Chlorine mg/kg 91.8 105 159 156 140 111 130 124 130 106 92.4 108 

Ash mg/kg 649 600 575 1,010 599 598 657 592 579 904 832 832 

Arsenic mg/kg NA NA <0.32 NA NA NA NA <0.3 NA NA <0.31 NA 

Beryllium mg/kg NA NA <0.096 NA NA NA NA . <0.092 NA NA <0.093 NA 

Cadmium mg/kg NA NA <0.076 NA NA NA NA <0.073 NA NA <0.073 NA 

Chromium mg/kg NA NA <0.21 NA NA NA NA <0.2 NA. NA <0.2 NA 

Lead mg/kg NA NA <0.27 NA NA NA NA <0.26 NA NA <0.26 NA 

Mercury mg/kg NA NA <0.009 NA NA NA NA <0.0086 NA NA <0.0099 NA 

Percent Water % 98.1 98.2 98.2 99.0 98.8 98.4 98.5 98.7 98.3 101.0 101.0 100.0 

Heating Value Btu/lb <130 <130 <130 <130 <130 <130 <130 <130 <130 <130 <130 <130 

Density g/m3 0.998 0.998 0.999 1.000 0.997 0.998 0.997 0.997 0.997 0.997 0.998 0.998 

Viscosity cSt 0.897 0.894 0.894 0.896 0.897 0.900 0.895 0.897 0.897 0.906 0.907 0.91 

4-7 

VES017389 
Table 4-4. Unit 2 - Analytical Results for Chlorine, Ash, Metals, and 

Physical Parameters in the Containerized Solids Waste Feed 

Analytical Parameter Units 

Runl Run 2 Run 3 Run 5 

Analytical Parameter Units 1 

PM 

2A 

HC1/C12 

2B 

Metals 

2C 

Dioxins/ 

Furans 

1 

PM 

1 

PM 

2A 

HC1/C12 

2B 

Metals 

2C 

Dioxins/ 

Furans 

2A 

HC!/Cl 2 

2B 

Metals 

2C 

Dioxins/ 

Furans 

Chlorine mg/kg 288 184 167 237 284 433 345 499 267 346 396 351 

Ash mg/kg 675,000 785,000 708,000 676,000 688,000 655,000 657,000 634,000 637,000 732,000 688,000 703,000 

Arsenic mg/kg NA NA 8.8 NA NA NA NA 7.5 NA NA 8.8 NA 

Beryllium mg/kg • NA NA 0.48 NA NA NA NA 0.61 NA NA 0.73 NA 

Cadmium mg/kg NA NA 0.082 NA NA NA NA <0.077 NA NA 0.084 NA 

Chromium mg/kg NA NA 12.8 NA NA NA NA 19.3 NA NA 16.7 NA 

Lead mg/kg NA NA 11.6 NA NA NA NA 11.7 NA NA 13.5 NA 

Mercury mg/kg NA NA 0.045 NA NA NA NA 0.022 NA NA 0.016 NA 

Percent Water % 20.2 23.4 21.7 24.5 26.2 24.9 25.2 25.1 25.1 22.6 25.4 20.8 

Heating Value Btu/lb <130 <130 <130 <130 <130 <130 <130 <130 <130 <130 <130 <130 

Density g/m3 NA NA NA NA NA NA NA NA NA NA NA NA 

Viscosity cSt NA NA NA NA NA NA NA NA NA NA NA NA 

4-8 

VES017390 
Table 4-5. Unit 3 - Analytical Results for Chlorine, Ash, IMetals, and Physical Parameters in the Low-Btu Liquid Waste Feed 

Analytical Parameter Units 

Runl Run 2 Run 3 Run 4 

Analytical Parameter Units 1 

PM 

1 

PM 

2A 

HC1/C12 

2B 

Metals 

2C 

Dioxins/ 

Furans 

1 

PM 

2A 

HC1/C12 

2B 

Metals 

2C 

Dioxins/ 

Furans 

2A 

HC1/CI2 

2B 

Metals 

2C 

Dioxins/ 

Furans 

Chlorine mg/kg 409 440 563 419 408 427 409 429 400 388 408 424 

Ash mg/kg 3,090 4,070 4,860 3,700 3,280 3,650 3,200 3,200 3,000 2,940 3,460 3,100 

Arsenic mg/kg NA NA NA 4.8 NA NA NA 3.2 NA NA 3.3 NA 

Beryllium mg/kg NA NA NA <0.096 NA NA NA <0.097 NA NA <0.096 NA 

Cadmium mg/kg NA NA NA 15.2 NA NA - NA 9.4 NA NA 11.3 NA 

Chromium mg/kg NA NA NA 1.3 NA NA NA 0.87 NA NA 0.97 NA 

Lead mg/kg NA NA NA . 3.1 NA NA NA 1.9 NA NA 1-9 NA 

Mercury mg/kg NA NA NA 0.065 NA NA NA 0.049 NA NA 0.08 NA 

Percent Water % 101.0 99.8 99.3 99.8 100.0 98.2 99.3 100.0 99.2 99.7 99.5 99.9 

Heating Value Btu/lb <130 173 361 256 158 462 209 181 213 154 <130 132 

Density g/m3 1.000 1.000 1.000 1.000 0.999 1.000 1.000 1.000 1.000 1.000 1.010 1.000 

Viscosity cSt 0.932 0.931 0.933 0.932 0.935 0.935 0.940 0.933 0.937 0.935 0.932 0.934 

4-9 

VES017391 
Table 4-6. Unit 3 - Analytical Results for Chlorine, Ash, Metals, and Physical Parameters In the High-Btu Liquid Waste Feed 

Analytical Parameter Units 

Runl Run2 Run 3 Rim 4 

Analytical Parameter Units 1 

PM 

1 

PM 

2A 

HC1/C12 

2B 

Metals 

2C 

Dioxins/ 

Furans 

1 

PM 

2A 

HC1/C12 

2B 

Metals 

2C 

Dioxins/ 

Furans 

2A 

HC1/C12 

2B 

Metals 

2C 

Dioxins/ 

Furans 

Chlorine mg/kg 3,450 2,410 2,460 2,720 2,430 1,730 1,690 1,650 1,620 1,910 1,810 1,830 

Ash mg/kg 1,260 937 1,100 1,160 730 599 478 586 648 734 693 730 

Arsenic mg/kg NA NA NA 12.4 NA NA NA 1.7 NA "NA 2.4 NA 

Beryllium mg/kg NA NA NA <0.095 NA NA NA <0.1 NA NA <0.096 NA 

Cadmium mg/kg NA NA NA <0.075 NA NA NA <0.079 NA NA <0.076 NA 

Chromium mg/kg NA NA NA . <0.21 NA NA NA <0.22 NA NA <0.21 NA 

Lead mg/kg NA NA NA 1.8 NA NA NA 1.0 NA NA 1.3 NA 

Mercury mg/kg NA NA NA 0.027 NA NA NA 0.029 NA NA 0.022 NA 

Percent Water % 24.0 23.9 23.9 24.1 24.0 23.3 23.0 23.0 23.1 25.2 25.2 25.4 

Heating Value Btu/lb 8,680 8,820 8,700 8,700 8,800 8,840 8,870 8,790 8,860 8,550 8,620 8,560 

Density g/m3 0.879 0.878 0.877 0.877 0.878 0.874 0.874 0.873 0.874 0.879 0.879 0.880 

Viscosity cSt 1.33 1.30 130 1.31 1.30 1.28 1.26 1.27 1.26 1.35 1.35 1.36 

4-10 
Table 4-7. Unit 3 - Analytical Results for Chlorine, Ash, Metals, and Physical Parameters in the Specialty Liquid Waste Feed 

Analytical Parameter Units 

Run 1 Run 2 Run 3 Run 4 

Analytical Parameter Units 1 

PM 

1 

PM 

2A 

HC1/C12 

2B 

Metals 

2C 

Dioxins/ 

Furans 

1 

PM 

2A 

HCI/C12 

2B 

Metals 

2C 

Dioxins/ 

Furans 

2A 

HC1/C12 

2B 

Metals 

2C 

Dioxins/ 

Furans 

Chlorine mg/kg 188 174 1,480 696 587 111 101 125 112 113 127 92 

Ash mg/kg 591 622 917 713 733 588 520 520 521 648 620 606 

Arsenic mg/kg NA NA NA <0.32 NA NA NA <0.32 NA NA <0.33 NA 

Beryllium mg/kg NA NA NA <0.098 NA NA NA <0.096 NA NA <0.099 NA 

Cadmium mg/kg NA NA NA <0.077 NA NA NA <0.076 NA NA <0.078 NA 

Chromium mg/kg NA NA NA <0.22 NA NA NA <0.21 NA NA <0.22 NA 

Lead mg/kg NA NA NA <0.27 NA NA NA <0.27 NA NA <0.28 NA 

Mercury mg/kg NA NA NA <0.0088 NA NA NA <0.0094 NA NA <0.0099 NA 

Percent Water % 98.4 97.7 97.3 98.7 95.8 97.9 97.2 98.4 96.2 97.1 99.2 97.1 

Heating Value Btu/lb <130 <130 <130 • <130 <130 <130 <130 <130 <130 <130 <130 <130 

Density g/m3 0.998 1.000 1.000 0.999 1.000 0.999 0.997 0.997 0.998 1.000 1.000 1.000 

Viscosity cSt 0.901 0.904 0.898 0.903 0.897 0.897 0.899 0.901 0.899 0.898 0.898 0.897 

4-11 
Table 4-8. Unit 3 - Analytical Results for Total Chlorine, Ash, Metals, and 

Physical Parameters in the Containerized Solids Waste Feed 

Analytical 

Parameter 

Units 

Runl Run 2 Run 3 Run 4 

Analytical 

Parameter 

Units 1 

PM 

1 

PM 

2A 

HCVCfc 

2B . 

Metals 

2C 

Dioxins/ 

Furans 

1 

PM 

2A 

HCI/C12 

2B 

Metals 

2C 

Dioxins/ 

Furans 

2A 

HCI/CIj 

2B 

Metals 

2C 

Dioxins/ 

Furans 

Chlorine mg/kg 253 229 482 195 129 347 115 271 204 382 255 297 

Ash mg/kg 670,000 682,000 663,000 775,000 737,000 778,000 655,000 715,000 682,000 721,000 686,000 698,000 

Arsenic mg/kg NA NA NA 7.5 NA NA NA 6.4 NA NA 8.4 NA 

Beryllium mg/kg NA NA NA 0.58 NA NA NA 0.55 NA NA 0.79 NA 

Cadmium mg/kg NA NA NA <0.071 NA NA NA <0.076 . NA NA <0.071 NA 

Chromium mg/kg NA NA NA 13.6. NA NA NA 13.7 NA NA 18.9 NA 

Lead mg/kg NA NA NA 11.1 NA NA NA 10.7 NA NA 14.1 NA 

Mercury mg/kg NA NA NA 0.028 NA NA NA 0.028 NA NA 0.026 NA 

Percent 

Water 

% 18.2 15.8 22.5 27.4 22.0 28.7 20.8 25.0 19.0 27.5 24.8 22.6 

Heating 

Value 

Btu/lb <130 <130 <130 <130 <130 <130 <130 <130 <130 <130 <130 <130 

Density g/m3 NA NA NA NA NA NA NA NA NA NA NA NA 

Viscosity cSt NA NA NA NA NA NA NA NA NA NA NA NA 

4-12 

VES017394 
Table 4-9. Unit 4 - Analytical Results for Chlorine, Ash, Metals, and 

Physical Parameters in the Low-Btu Liquid Waste Feed to the Kiln 

Analytical Parameter Units 

Runl Run 2 Run 3 Run 4 

Analytical Parameter Units 1 

PM 

2A 

HC1/CI2 

2B 

Metals 

2C 

Dioxins/ 

Furans 

2A 

HC]/Ci 2 

2B 

Metals 

2C 

Dioxins/ 

Furans 

1 

PM 

2A 

HC1/C12 

2B 

Metals 

2C 

Dioxins/ 

Furans 

1 

PM 

Chlorine mg/kg 472 416 413 449 467 393 422 537 486 532 439 530 

Ash mg/kg 2,790 2,910 3,100 2,570 3,060 3,260 2,940 3,320 3,220 2,630 3,260 3,250 

Arsenic mg/kg NA NA 5.5. NA NA 4.9 NA NA NA 2.9 NA NA 

Beryllium mg/kg NA NA <0.094 NA NA <0.098 NA NA NA <0.096 NA NA 

Cadmium mg/kg NA NA 13.6 NA NA 12.1 NA NA NA 9.4 NA NA 

Chromium mg/kg NA NA 1.3 NA NA 1.2 NA NA NA 0.84 NA NA 

Lead mg/kg NA NA 3.3 NA NA 2.9 NA NA NA 1.6 NA NA 

Mercury mg/kg NA NA 0.11 NA NA 0.14 NA NA NA 0.11 NA NA 

Percent Water % 98.8 97.3 97.7 97.0 96.5 95.8 97.3 97.1 98.1 98.6 96.9 98.8 

Heating Value Btu/lb <130 <130 <130 <130 <130 157 166 <130 197 <130 283 402 

Density g/m3 0.999 1.000 1.000 0.999 0.999 1.000 1.000 1.000 1.000 0.999 . 1.000 0.999 

Viscosity cSt 0.934 0.939 0.929 0.933 0.928 0.933 0.929 0.932 0.930 0.932 0.932 0.932 

4-13 
Table 4-10. Unit 4 - Analytical Results for Chlorine, Ash, Metals, and 

Physical Parameters in the High-Btu Liquid Waste Feed to the Kiln 

Analytical Parameter Units 

Runl Run 2 Run 3 Run 4 

Analytical Parameter Units 1 

PM 

2A 

HC1/C12 

2B 

Metals 

2C 

Dioxins/ 

Furans 

2A 

HCl/Clj 

2B 

Metals 

2C 

Dioxins/ 

Furans 

1 

PM 

2A 

ncvch 

2B 

Metals 

2C 

Dioxins/ 

Furans 

1 

PM 

Chlorine mg/kg 1,470 1,450 1,490 1,420 1,390 1,360 1,360 1,350 1,360 1,350 1,350 1,330 

Ash mg/kg 1,610 2,350 2.110 1,820 898 1,010 1,020 1,500 973 931 1,020 989 

Arsenic mg/kg NA NA 1.4 NA NA 0.37 NA NA NA <0.32 NA NA 

Beryllium mg/kg NA NA <0.099 NA NA <0.093 NA NA NA <0.097 NA NA 

Cadmium mg/kg NA NA 0.12 NA NA <0.073 NA NA NA <0.077 NA NA 

Chromium mg/kg NA NA 0.24 NA NA <0.2 NA NA NA <0.21 NA NA 

Lead mg/kg NA NA 1-1 NA NA 0.4 NA NA NA <0.27 NA NA 

Mercury mg/kg NA NA 0.048 NA NA 0.021 NA NA NA 0.018 NA NA 

Percent Water % 24.0 24.3 24.0 23.8 25.0 24.9 24.5 25.2 24.8 25.1 24.7 24.8 

Heating Value Btu/lb 8,740 8,700 8,690 8,750 8,780 8,760 8,730 8,760 8,790 8,750 8,780 8,810 

Density g/m3 0.876 0.877 0.876 0.877 0.877 0.877 0.877 0.877 0.877 0.878 0.877 0.877 

Viscosity cSt 1.29 1.28 1.28 1.29 1.37 1.37. 1.37 1.38 1.36 1.37 1.36 1.36 

4-14 
Table 4-11. Unit 4 - Analytical Results for Chlorine, Ash, Metals, and 

Physical Parameters in the Liquid Waste Feed to the SCC 

Analytical Parameter Units 

Runl Run 2 Run 3 Run 4 

Analytical Parameter Units I 

PM 

2A 

HCl/Clj 

2B 

Metals 

2C 

Dioxins/ 

Furans 

2A 

HC1/C12 

2B 

Metals 

2C 

Dioxins/ 

Furans 

1 

PM 

2A 

HC1/C12 

2B 

Metals 

2C 

Dioxins/ 

Furans 

1 

PM 

Chlorine mg/kg 1,250 1,230 1,250 1,210 1,260 2,500 1,240 1,270 1,280 1,250 1,280 1,320 

Ash mg/kg 744 511 485 . 478 694 673 672 787 651 604 591 743 

Arsenic mg/kg NA NA <0.3 NA NA <0.32 NA NA NA <0.31 NA NA 

Beryllium mg/kg NA NA <0.092 NA NA <0.098 NA NA NA <0.094 NA • NA 

Cadmium mg/kg NA NA <0.073 NA NA <0.077 NA NA NA <0.074 NA NA 

Chromium mg/kg NA NA <0.2 NA NA <0.22 NA NA NA <0.21 NA NA 

Lead mg/kg NA NA 0.26 NA NA <0.27 NA NA NA <0.26 NA NA 

Mercury mg/kg NA NA 0.017 NA NA 0.019 NA NA NA 0.017 NA NA 

Percent Water % 27.0 26.5 26.5 26.2 26.9 26.7 27.0 26.8 26.6 25.6 26.6 26.9 

Heating Value Btu/lb 8,830 8,810 8,790 8,810 8,760 8,800 8,760 8,780 8,860 8,860 8,870 8,830 

Density gW 0.879 0.878 0.878 0.878 0.879 0.878 0.877 0.879 0.877 0.878 0.878 0.878 

Viscosity cSt 1.54 1.52 1.52 1.52 1.53 1.52 1.52 1.52j 1.52 1.52 1.51 1.52 

4-15 
Table 4-12. Unit 4 - Analytical Results for Chlorine, Ash, Metals, and 

Physical Parameters in the Containerized Solids Waste Feed 

Analytical Parameter Units 

Runl Run 2 Run 3 Run 4 

Analytical Parameter Units 1 

PM 

2A 

HCI/C12 

2B 

Metals 

2C 

Dioxins/ 

Furans 

2A 

HC1/CI2 

2B 

Metals 

2C 

Dioxins/ 

Furans 

1 

PM 

2A 

HCI/C12 

2B 

Metals 

2C 

Dioxins/ 

Furans 

1 

PM 

Chlorine mg/kg 176 192 190 167 205 201 257 227 207 180 271 244 

Ash mg/kg 758,000 828,000 739,000 728,000 728,000 731,000 745,000 724,000 749,000 730,000 719,000 771,000 

Arsenic mg/kg NA NA 2.4 NA NA 2.0 NA NA NA 2.1 NA NA 

Beryllium mg/kg NA NA 0.13 NA NA 0.16 NA NA - NA <0.1 NA NA 

Cadmium mg/kg NA NA 0.46 NA NA 0.43 NA NA NA 0.45 NA NA 

Chromium mg/kg NA NA 45.2 NA NA 58.9 NA NA NA 35.1 NA NA 

Lead mg/kg NA NA 35.9 NA . NA 212 NA NA NA 25.4 NA NA 

Mercury mg/kg NA NA 0.18 NA • NA 0.24 NA NA NA 0.26 NA NA 

Percent Water % . 7.64 8.10 6.75 9.10 7.93 8.29 7.82 9.88 8.11 7.94 9.31 6.31 

Heating Value Btu/lb <130 <130 <130 <130 <130 <130 <130 <130 <130 <130 <130 <130 

Density g/m3 NA NA NA NA NA NA NA NA NA NA NA NA 

Viscosity cSt NA NA NA NA . NA NA NA NA NA NA NA NA 

4-16 
Table 4-13. Unit 4 - Analytical Results for Chlorine, Ash, Metals, and Physical Parameters in the Bulk Solids Waste Feed 

Analytical Parameter Units 

Runl Run 2 Run 3 Run 4 

Analytical Parameter Units 1 

PM 

2A 

HCI/C12 

2B 

Metals 

2C 

Dioxins/ 

Furans 

2A 

HC1/C12 

2B 

Metals 

2C 

Dioxins/ 

Furans 

1 

PM 

2A 

HCl/Clj 

2B 

Metals 

2C 

Dioxins/ 

Furans 

1 

PM 

Chlorine mg/kg 171 184 219 265 257 243 236 193 191 173 182 164 

Ash mg/kg 695,000 646,000 715,000 784,000 770,000 720,000 674,000 689,000 729,000 737,000 695,000 710,000 

Arsenic mg/kg NA NA 2.2 NA NA 3.0 NA NA NA 2.2 NA NA 

Beryllium mg/kg NA NA 0.21 NA NA 0.28 NA NA NA 0.26 NA NA 

Cadmium mg/kg NA NA 0.28 ' NA NA 0.37 NA NA NA 0.30 NA NA 

Chromium mg/kg NA NA 35.6 NA NA 37.9 NA NA NA 29.8 NA NA 

Lead mg/kg NA NA 41.0 NA NA 58.1 NA NA NA 26.6 NA NA 

Mercury mg/kg NA NA 0.082 NA NA 0.12 NA NA NA 0.077 NA NA 

Percent Water .• % 14.2 18.8 10.3 11.6 16.6 19.2 19.9 13.3 19.3 17.3 15.6 24.7 

Heating Value Btu/lb <130 <130 <130 <130 <130 <130 <130 <130 <130 <130 <130 <130 

Density g/m3 NA NA NA NA NA NA NA NA NA NA NA NA 

Viscosity cSt NA NA NA NA NA NA NA NA NA NA NA NA 

4-17