DSHW-2024-007865

TOOELE CHEMICAL AGENT DISPOSAL FACILITY
(rocDF)
HAND DELIVERED
DEC I 3 2010
UTAH DIVISION OF
SOLII}& HAZARDOUS WASTE
SURROGATE TRIAL BURN PLAN
FOR THE
AREA 10 LIQUID INCINERATOR
(Fulfilling Requirements of the RCM, Title V, and MACT Regulations)
Revision 1
December 2, 2010
ffi
EG&G Divi
REPLY TO
ATTENTION OF
DEPARTMENT OF THE ARMY
US ARMY CHEMICALS MATERIAL AGENCY
TOOELE CHEMICAL AGENT DISPOSAL FACILITY
11620 STARK ROAD
STOCKTON, UT 84071
DEC 1 B 2OIO
.IEHC $3ffffiIffi
rJTAhl []tvhsl0N 0r:
SOLID & hIAZARI}OU., WA$TE
J0 I0. 0 Vw[ [
Tooele Chemical Agent Disposal Facility PMO902-10
Mr. Scott Anderson
Director, Utah Department of Environmental Quality
Division of Solid and Hazardous Waste
P.O. Box 144880
195 North 1950 West
salt Lake city, utah 84114-4880
SUBJECT: Response to Division of Solid andHazardous Waste (DSHW) Comments
Concerning Tooele Chemical Agent Disposal Facility (TOCDF) Class 3 Permit Modification
Request Titled "Install and Operate Area 10 Liquid Incinerator", TOCDF-A10-03-1092 DSHW
Tracking Number: 2010.00067, EPA ID: UT5210090002
Dear Mr. Anderson:
Please find enclosed the response to comments received from DSHW boncerning Permit
Modification Request TOCDF-A10-03-1092, which is titled "Install and Operate Area l0 Liquid
Incinerator". Also enclosed is a compact disk containing electronic files of the affected TOCDF
Resource Conservation Recovery Act (RCRA) Permit change pages incorporating DSHW
comments, where applicable, revised ATLIC performance test plans, revised drawings, and
enclosures which provide supporting information. A hard copy of the files included on the
compact disk is also provided.
Note the following:
o The ATLIC exhaust stack Near Real Time 0r{RT) agent monitor Automatic Waste
Feed Cut-Off (AWFCO) limit is reviied from 0.5 and 0.4 Source Emission Limit
(SEL) for Agent GA and Lewisite, respectively to 0.2 SEL for each agent. The SEL
value for Lewisite remains at 0.03 miliigrams per cubic meter (0.03 mg/m3).
. The ATLIC Surrogate Trial Burn (STB) Plan is revised to include the spiking of
the Spent Decon Solutions (SDS) with an organic compound (monochlorobenzene),
and add the collection of exhaust gas samples for semi-volatile organic compounds.
o Module IV and Attachment 2 are revised to increase the agent concentration,limit
for SDS to be processed in the Secondary Combustion Chamber of the ATLIC from
20 and 200 parts per billion for agent GA and I.ewisite, respectively to 500 parts per
million (ppm) for each agent. The 500 ppm agent limit for spent decon feed to the
ATLIC Secondary Combustion Chamber is conservative and is proposed based on the
intended organic spiking rate to the Secondary Combustion Chamber (SCC) during
the ATLIC STB. TOCDF will spike monochlorobenzene to the ATLIC SCC during
Prinred "^ @
Recycred Paper
the STB at a rate that will result in a Spent Decon organic content of approximately
8,000 ppm (0.8 weight percent). The selected organic spike is more difficult to
incinerate than Agent GA or Lewisite.
o The SDS feed rate specified in the test plans is increased to account for the need
to spike the SDS with Phosphoric Acid to replicate during the STB the particulate
loading that will be experienced during the process of Agent GA.
o The ATLIC Agent Monitoring Plan is revised to use a Depot Area Air Monitoring
System as the confirmation method for Lewisite NRT monitor alarms rather than
second NRT monitor that is configured with a different analytical column.
.
. The ATLIC AWFCO system test frequency is revised from once every 30 days
and proposed to as once every 14 days when the ATLIC is feeding hazardous waste
for a period longer than 14 days. The basis for this proposal is provided in the
response to DSHW comment # 4.
o Module VI is revised to require TOCDF to conduct a Lewisite Mini-Burn which
will allow for the continued processing of Lewisite upon completion of the Lewisite
CPT. Data from this test will provide assurance that the ATLIC post-CPT Lewisite
processing complies with the TOCDF RCRA hazardous waste incinerator
performance standards
TOCDF intends to submit a revised Laboratory Quality Control Plan (LQCP) and revised
Laboratory Operating Procedures applicable to Agent GA and Lewisite analyses and rnonitoring
under separate cover. TOCDF is aware ofthe desire of the DSHW to include the revised LQCP
in the documents that will be evaluated during the second public comment period. A revised
LQCP is being prepared and will be submitted to the DSHW shortly after January 1,2011.
TOCDF respectfully requests a meeting to begin discussing any issues DSHW may have
with the enclosed comment responses on or before December 22,2010, so that we may begin to
work on those issues that appear to be the most conceming as soon as possible
The points of coniact in this matter are Ms. Sheila *. ,*." at [phone] or Mr. Trace
Salmon at [phone].
Sincerely,
Inc.
Thaddeus A. Ryba, Jr.
TOCDF Site Project Manager
*CERTIFICATION STATEMENT
Enclosure
. I CERTIFY UNDER PENALry OF LAW THAT THIS DOCUMENT AND ALL ATTACHMENTS WERE PREPARED UNDER MY DIRECTION OR SUPERVISION tN
ACCORDANCE wlTII A SYSTEM DESTGNED TO ASSURE THAT qUALIFIED PERSONNEL PROPERLY GAT}IER AND EVALUATE TI{E TNFORMATION SUBMITTED.
BASED ON TVfY INQUIRY OF THE PERSON OR PERSONS WHO MAI{AGE THE SYSTEM. OR THOSE PERSONS DIRECTLY NESPONSIBLE FOR CATHERING THE
INFORMATION, THE INFORMATION SUBMITTED lS. TO TltE BEST OF MY KNOWLEDGE AND BELTEF; TRUE, ACCURATE AND COMPLETE. I AM AWAR"E tHAT
THERE ARE SIGNIFICANT PENALTIES FON SUBMITTING FALSE INFORMATION, INCLT'DING THE POSSIBILITY OF FINE AND IMPRISONMENT FOR KNOWING
vloLATtoNs.
HAND DELIVERED
DEC f"3 2010
uTAH DlvlsloN-0t --
SOUO A HAZARDOUS WASTE
a0ru,Drll
TOOELE CHEMICAL AGENT DISPOSAL
FACILITY (TOCDF)
SURROGATE TRIAL BURI\ PLAN
FOR THE
AREA 10 LIQUID INCINERATOR
Revision I
December 212010
o
EXECUTIVE SUMMARY
The Tooele Chemical Agent Disposal Facility (TOCDF) was designed and built for the United
States (U.S.) Army to destroy the chemical munitions stockpile at the Deseret Chemical Depot
(DCD), located 20 miles south of Tooele, Utah. EG&G Defense Materials, Inc. (EG&G),
operates the TOCDF under contract to the Army through the Chemical Materials Agency. The
U.S. Envirorunental Protection Agency (EPA) identification number for the TOCDF is
UT5210090002. The facility operates under a Resource Conservation and Recovery Act
(RCRA) Part B permit, issued pursuant to the delegation of the State of Utah, Department of
Environmental Quality (DEQ), Division of Solid and Hazardous Waste (DSHW), under the Utah
Administrative Code, Section 315. In addition, the TOCDF also operates under a Title V air
permit administrated by the State of Utah DEQ, Division of Air Quality (DAQ). Under the
requirements of these permits, the incinerator system must demonstrate the ability to effectively
treat any hazardous wastes such that human health and the environment are protected.
This plan addresses the testing.to be conducted for the Area 10 Liquid Incinerator (ATLIC) as a
combined: 1) Surrogate Trial Burn (STB) to fulfill the trial burn requirements of the RCRA
permit for Agent GA and Lewisite processing; and}) Comprehensive Performance Test to fulfill
the air permit requirements of 40 CFR 63, Subpart EEE [i.e., Hazardous Waste Combustors
(HWC) Maximum Achievable Control Technology (MACT) regulations]. A surrogate mixture
containing chlorobenzene (MCB) and tetrachloroethene (TCE) will be used to establish the
Destruction and Removal Efficiency (DRE) for the ATLIC. The MCB is a Class 1 compound on
the EPA ranking system for difliculty of incineration. Therefore, any other Class 1 compound,
and any compound ranked less than a Class 1, may be processed subsequent to the STB. The
TCE is a Class 2 compound and their use is a conservative demonstration since Agent GA and
Lewisite are estimated to be Clasq 4 or 5 compounds. This test will also fulfiIIthe Title V air
permit condition to test the particulate matter (PM) and carbon monoxide (CO) emissions. Test
results will demonstrate compliance with the performance standards specified in the RCRA
Permit and the HWC Final Replacement standards for new sources that were published in the
Federal Register, October 12,2005 andfinalized in October 2008.
The ATLIC STB will be conducted at one set of operating conditions using a surrogate mixture
that will be spiked with arsenic, lead, and mercury, while being fed to the Primary Combustion
Chamber (PCC). The spent decontamination solution will be simulated by feeding MCB and
phosphoric acid to the Secondary Combustion Chambers (SCC). The STB wilt demonstrate
minimum temperatures in the PCC and SCC, while demonstrdting maximum feed rates and
maximum exhaust gas flow rates. The exhaust gas samples collected will be for oxygen, CO,
carbon dioxide, PM, hydrogen chloride, chlorine, metals, volatile organic compounds, semi-
volatile organic compounds, polychlorinated dibenzo-p-dioxins/polychlorinated dibenzofurans,
nitrogen oxides, and total hydrocarbons. The results of this STB will establish the DRE, chlorine
feed rate, metals feed rates for processing Agent GA, and total waste feed rate.
ATLIC STB Plan - Rev. I
Decemb er 2,2010
TOCDF ES.1
TABLE OF CONTENTS
LIST OF ACRONYMS AND ABBREVIATIONS.,....... .........,............... Vi
LIST OF UNITS AND MEASUREMENTS........... ............ ix
LIST OF CHEMICAL SYMBOLS AND FORMULAS ............. ,..............X
LIST OF IDENTIFICATION CODES FOR LIQUID INCINERATOR INSTRUMENTS MONITORING
REGULATED OPERATINGPARAMETERS............. ....,....,..,..,.......... Xi
1.1 ATLICSURROGATETRIALBURNPLANORGANIZATION........... ...............3
I.2 FACILITYINFORMATION........... ........3
I.3 WASTETREATMENTSYSTEMPROCESSANDFEEDDESCRIPTIONS................ ..,.,.,....,4
L3.I Waste Handling and Storage.. ......... 4
1.3.3 Pollution Abatement System......., .......................... 6
1.4 WASTESTOBETREATED............. ...........................6
1.4.1 l{orst Case Demonstration by the Sunogate Mixture ............... 6
1.5 SURROGATE TRIAL BURN O8JECTIVES................... ............... l0
I.6 SURROGATETRIALBURNAPPROACH ............... 11
1.7 PROPOSED SURROGATETRIALBURNPROGRAM .............,.. 11
1.8 SURROGATBTRIALBURNSAMPLINGANDANALYTICALPROTOCOLS........................................ 1I
1.10 ruSTIFICATrONFOREXEMPTION........... ........... 13
2.0 DETAILED ENGINEERING DESCRIPTION OF THE ATLIC .......................14
2.1 PRIMARY COMBUSTION CHAMBER............... ......................... 14
2.2 SECONDARYCOMBUSTIONCHAMBER. ............ 15
2.3 DESCRIPTIONOFTHEWASTEFEEDNOZZLESANDGASBURNERS... ...,.................... 16
2.4 DESCRIPTION OFTHEAUXILIARYFUEL SYSTEM.. ,.,.,.,.,.,.,,17
2.5 AGENTTCDRAINANDRINSESYSTEM..... ..,.,....17
2.5.1 Agent GA TC Drain and Rinse 5ystem.......... .......................... 18
2.5.2 Lewisite TC Drain and Rinse System .................. 19
2.5.3 Transparency TCs Decontamination 5ystem.......... .................. 20
2.6 DESCRIPTION OFTHEWASTEFEED SYSTEMS... ...............,... 20
2.7 HEATING, VENTILATION AND COOLING SYSTEM ,..,,.,,,...,.,21
2.8 DESCRIPTION OF THE AUTOMATIC WASTE FEED CUTOFF SYSTEM .........................22
ATLIC STB Plan - Rev. I
Decemb er 2,201 0
TOCDF
TABLE OF CONTENTS (continued)
2.9 EXHAUST GAS MONITORING EQUIPMENT .................. ..........26
2.9.1 Carbon Monoxide Monitors........... ,.................... 26
2.9.4 Agent Monitoring 5ystems..............,.. .................. 29
2.IO POLLUTIONABATEMENT SYSTEM..... ..............29
2.10.2 Packed Bed Scrubber System/Brine Chiller 9ystem............... ..................... 30
2.10.3 High-Energt Venturi Scrubber/Moisture 9eparator...,............ ..,................ 31
2.10.4 Exhaust Gas Electric Reheater....... ................... 31
2.10.5 Powdered Activated Carbon Injection System ....................... i2
2.10.7 Carbon Filter System 33
2.I1 CONSTRUCTIONMATERIALS.. ......33
2.12 LOCATION AND DESCRIPTION OF TEMPERATURE, PRESSURE, AND FLOW INDICATING AND
2.12.2 PCC Agent Feed Rate Control..... ..................... j7
2.12.3 PCC Pressure Contro1.,................ ..................... i7
2.12.4 PCC Exhaust Gas Temperature and Burner Controls ........... 37
2. 1 2.5 SCC Exhaust Gas Temperature and Burner Control ......... ......................... 38
2. 1 2.6 SCC Spent Decon l{aste Feed Control . .. .. ... .. .. ... . .. .. . . .... ... .. .. 38
2.12.8 Venturi Scrubber Water Flow ...... 38
2.12.12 Baghouse Pressure Drop......,...... .................... i9
2.12.13 CarbonFilterSystemDifferentialPressureControl......... ........................ j9
2.12.14 ATLIC Exhaust Gas Oxygen Concentration....,........... ........ 40
2.12.15 ATLIC Exhaust Gas Carbon Monoxide Concentration................... ..........40
2.12.16 ATLIC Exhaust Gas Flow Rate ............. .......... 40
2.12.17 Unintenuptable Power Supply 5ystem.......... .......................40
2.13 INCINERATIONSYSTEMSTARTUPPROCEDURES................ ...................40
2.13.1 Startup of the ATLIC Pollution Abatement 5ystem.......... ....... 41
2.1j.2 Startup of the PCC/5CC................ ....................41
2.13.3 Initiationof PrimaryllasteFeed............. .........42
2.13.4 Initiation of Spent Decon Feed..... ...........,......... 42
2.14 EMERGENCY/PLANNED SHUTDOWNS............ ...................... 43
ATLIC STB Plan - Rev. 1
Decemb er 2, 2010
TOCDF
TABLE OF CONTENTS (continued)
3.0 SAMPLING AllD ANALYSIS PROC8DUR8S................... ...........44
3.1 SAMPLTNG LOCATIONS.................. ....................... 45
3.2 SAMPLING METHODS..,................ .......................... 45
3.3 ANALYSES M8THODS................... ......................... 48
4.0 ATLIC SURROGATE TRIAL BIIRN SCHEDULE .......................49
5.0 ATLIC SURROGATE TRrAL BURN PROTOCOLS................... ......................50
5.1 WASTE CHARACTERIZATION ......... 50
5.1.1 Surrogate Mixture Feed............. ........................ 50
5.1.2 Spent Decontamination Solution llaste Feed..................j.... ....................... 52
5.2 PRINCIPAL ORGANIC HAZARDOUS CONSTITUENT SELECTION RATIONALE .,.....,. 52
5.3 TESTPROTOCOLAND OPERATING CONDITrONS................... .................. 53
5.3.1 Development of Worst-Case Criteria.................. .................... 53
5.3.2 ATLIC Surrogate Trial Burn Operating Conditions ............... 54
5.4 COMBUSTIONTEMPERATURERANGES .,..,.,,,.,.54
5.5 WASTE FEED RATES AND QUANTTTTES OF WASTES TO BE BURNED.......... ............... 55
5.6 EXHAUST GAS VELOCITY INDICATOR .............. 56
5.8 WASTEFEEDASHCONTENT ...........56
5.9 ORGANIC CHLORINE CONTENT OF THE WASTE FEED.................. .,,...,,.,. 57
5.10 METALSFEEDRATES........ ..............57
s.l1 PoLLUTTON CONTROL EQUTPMENT OPERATrONS......... ......................... s7
5.I2 SHUTDOWNPROCEDURES...... ..,.,,57
5.13 INCINERATORPERTORMANCE. ......................... 59
6.0 ATLIC STB SHAKEDOWN PROCEDURES........................... . 6l
6.1 STARTUPPROCEDURES.............. ......61
6.3 POST ATLIC SURROGATE TRIAL BURN OPERATION .,....,.,,. 62
6.4 TNCTNERATORPERFORMANCE.... ........................ 63
7.0 ATLIC SURROGATE TRIAL BURN SUBSTITUTE SUBMISSIONS........... .......................64
8.0 ATLIC SURROGATE TRIAL BURN RESULTS... ........................65
9.0 FINAL OPERATING PARAMETER LIMITS................... ............ 66
9.1 ESTABLISHING LTQUTD TNCTNERATOROPERATINGPARAMETERS ................... 66
9.2 CONTINUOUSLY MONITORED PARAMETERS............. ..,.,...,.67
9.3 OPERATINGRECORD PARAMETERS ............... ........................ 68
9.4 INDEPENDENT OPERATINGPARAMETERS................ ............ 68
ATLIC STB Plan - Rev. I
Decemb er 2,201 0
111
TOCDF
APPENDIX A.
APPENDIX B.
APPENDIX C.
APPENDIX D.
LIST OF APPENDICES
ATLIC STB QUALITY ASSURANCE PROJECT PLAN
ATLIC STB SHAKEDOWN PLAN
MASS AND ENERGY BALANCE FOR THE AREA 10 LIQUID
INCINERATOR SURROGATE TRIAL BURN AND EXHAUST GAS
RESIDENCE TIME CALCULATIONS
AUTOMATIC WASTE FEED CUTOFF TABLES AND OPERATING
CONDITION TARGET VALUE TABLES FOR THE AREA 10 LIQUID
INCINERATOR
ATLIC STB Plan - Rev. I
Decemb er 2, 2010
TOCDF 1V
1-1
L-2
2-l
2-2
3-1
5-1
5-2
5-3
t,.
LIST OF TABLES
Agent GA Characterization Summary.. .......8
Lewisite Characteization Summaxy............. .,...............9
ATLIC Construction Materials ..................34
Instruments Calibration Frequency................ ..............36
ATLIC Exhaust Gas Sampling Summary................ ......................46
Surrogate Mixture Composition and Calculated Feed Rates .........51
Waste Feed Requirements.... ......................55
Estimated Metals Feed Rates and Emission Rates ......58
ATLIC STB Plan - Rev. I
December 2,2010
TOCDF
LIST OF ACRONYMS AND ABBREVIATIONS
ACAMS Automatic Continuous Air Monitoring System
AHU Air Handling Unit
ASTM ASTM International
ATB Agent Trial Burn
ATLIC Area 10 Liquid lncinerator
AWFCO Automatic Waste Feed Cutoff
BMS Burner Management System
Brine Scrubber Liquor or Venturi Scrubber Liquor
CAL Chemical Assessment Laboratory
CEMS Continuous Emission Monitoring System
CFR Code of Federal Regulations
CMA Chemical Materials Agency
CON Control Room
CPT Comprehensive Performance Test
DAAMS Depot Area Air Monitoring System
DAQ Department of Environmental Quality (State of Utah), Division of Air
QualityDCD Deseret Chemical Depot
DEQ State of Utah, Department of Environmental QualityDFS Deactivation Furnace System
DI Deionized (as in deionized water)
DRE Destruction and Removal Efficiency
DSHW State of Utah Department of Environmental Quality, Division of Solid and
Hazardous Waste
EG&G Defense Materials, hc.
IJ.S. Environmental Protection Agency
Emergency Stop
Extreme Temperature Limit
Facility Control System
Flame Safety Shutdown System
Gas Chromatograph
Gas Chrom ato graph/Mass Spectrometer
Hazardous Air Pollutant
High Efficiency Particulate Air
Human Health Risk Assessment
HRGC/HRMS High Resolution Gas Chromatograph/High Resolution Mass Spectrometer
ATLIC STB Plan - Rev. I
Decemb er 2,201 0
EG&G
EPA
E-stop
ETL
FCS
FSSS
GC
GC/MS
HAP
HEPA
HHRA
viTOCDF
HVAC
HWC
HRA
IC
ICP/MS
ID
LIC
LOQ
MACT
MEB
MPF
NDIR
NOC
NRT
OPL
PAC
PAS
PCC
PICs
P&ID
PLC
PM
POHC
PST
QA
QAPP
QC
RCRA
SCC
SDS
SMVOC
SOP
Spent Decon
STB
SVOC
sw-846
TC
TE-LOP
LIST OF ACRONYMS AND ABBREVIATIONS (continued)
Heatitrg, Ventilation, and Cooling
Hazardous Waste Combustor
Hourly Rolling Average
Ion Chromatography
Inductively Coupled Plasma/Mass Spectrometry
Induced Draft
Liquid Incinerator
Limit of Quantitation
Maximum Achievable Control Technology
Mass and Energy Balances
Metal Parts Furnace
Non-Di sp ersive Infrared
Notifications of Compliance
Near Real Time
Operating Parameter Limits
Powdered Activated Carbon
Pollution Abatement System
Primary Combustion Chamber
Products of Incomplete Combustion
Piping and Instrument Diagram
Programmable Logic Controller
Particulate Matter
Principal Organtc Hazardous Constituent
Performance Specifi cation Test
Quality Assurance
Quality Assurance Proj ect Plan
Quality Control
Resource Conservation and Recovery Act
Secondary Combustion Chamber
Spent Decontamination System
Sampling Method for Volatile Organic Compounds
Standard Operating Procedure
Spent Decontamination S olution
Surro gate Trial Burn
S emi-Volatile Organic Compound
Test Methods for Evaluating Solid Waste, 3rd Edition including
Update IV, IISEPA, SW-8 46, February 2007 .
Ton Container
Tooele Laboratory Operating Procedure
ATLIC STB Plan - Rev. I
Decemb er 2,201 0
TOCDF vll
TEQ
THC
TOCDF
TOX
TSCA
TSDF
UPS
U.S.
VFD
VOC
WCL
XSD
LIST OF ACRONYMS AND ABBREVIATIONS (continued)
Toxic Equivalent Concentration
Total Hydrocarbons
Tooele Chemical Agent Disposal Facility
Toxic Area
Toxic Substances Control Act
Treatment Storage and Disposal Facility
Unintemrptible Power Supply
United States
Variable Frequency Drive
Volatile Organic Compound
Waste Control Limit
Halogen Specific Detector
vill ATLIC STB Plan - Rev. I
Decemb er 2,201 0
TOCDF
LIST OF UNITS AND MEASUREMENTS
acfm actual cubic feet per minute
Btu/hr British thermal units per hour
Btu/lb British thermal units per pound
cP centiPoise
cfm cubic feet per minuteoC degree centigradeoF degree Fahrenheit
dscf dry standard cubic foot
dscfm dry standard cubic feet per minute
dscm dry standard cubic meter
ft foot
ft3 cubic foot
g gram
g/sec grams per second
gal gallon
gpm gallons per minute
grldscf grains per dry standard cubic foot (1 atmosphere, 68 oF)
hp horsepower
inHg inches of mercury
inWC inches of water column
L liter
Llm liters per minute
lb/ft3 pornds per cubic foot
tlg microgram
m' cubic meter
mg milligram
mL milliliter
N Normal
ng nanogram
ppb parts per billion
ppm parts per million
ppmdv
lb/hr
parts per million on a dry volume basis
pounds per hour
psi pounds per square inch
pslg
scfm
AP
wt%
pounds per square inch gauge
standard cubic feet per minute
pitot velocity pressure
weight percent
1X ATLIC STB Plan - Rev. 1
Decemb er 2, 2010
TOCDF
LIST OF CHEMICAL SYMBOLS AND FORMULAS
Agent GA
A1
Ag
As
B
Ba
Be
Cd
Clz
COz
CO
Co
Cr
Cu
EDT
HNO:
Hg
HCl
HzOz
L
KMnO+
MCB
Mn
NaOH
HzSO+
Ni
NO*
Oz
P
Pb
PCE
PCDD
PCDF
Sb
Se
Sn
TCDD
TI
V
Zn
Ethyl N,N-dimethyl phosphoroamidocyanidate
aluminum
silver
arsenic
boron
barium
beryllium
cadmium
chlorine
carbon dioxide
carbon monoxide
cobalt
chromium
copper
ethanedithiol
nitric acid
mercury
hydrogen chloride
hydrogen Peroxide
Lewisite or (2-chlorovinyl) dichloro arsine
potas sium pennanganate
Chlorobenzene
manganese
sodium hydroxide
sulfuric acid
nickel
nitrogen oxides
oxygen
phosphorus
lead
perchloroethylene or tetrachloroethene
polychlorinated dib en zo -p - dioxin
p o lychlorinated dib enzo furans
antimony
selenium
tin
tetrachloro dib enzo -p - di oxin
thallium
vanadium
zlnc
ATLIC STB Plan - Rev. 1
December 2,2010
TOCDF
LIST OF IDENTIFICATION CODES FOR LIQUID INCINERATOR INSTRUMENTS
MONITORING REGULATED OPERATING PARAMETERS
815-TIC-8471 Primary Chamber Exhaust Gas Temperature, Hourly Rolling Average
807-FIT-8430 Primary Chamber Agent Feed Rate, Hourly Rolling Average
822-PI-8410 Agent Atomizing Air Pressure
815-TIT-8571 Secondary Chamber Exhaust Gas Temperature, Hourly Rolling Average
829-FIT-8521 Secondary Chamber SDS Feed Rate, Hourly Rolling Average
822-PI-8511 Spent Decon Atomizing Air Pressure
819-FIT-8924 Venturi Scrubber Liquor Feed, Hourly Rolling Average
819-FIT-8921 Scrubber Liquor Flow to Scrubber Tower #1, Hourly Rolling Average
819-FIT-8922 Scrubber Liquor Flow to Scrubber Tower #2, Hourly Rolling Average
819-FIT-8923 Scrubber Liquor Flow to Scrubber Tower #3, Hourly Rolling Average
819-PDI-8911 Scrubber #1 Pressure Drop, Hourly Rolling Average
819-PDI-8912 Scrubber #2 Pressure Drop, Hourly Rolling Average
819-PDI-8913 Scrubber #3 Pressure Drop, Hourly Rolling Average
819-PI-8982 Scrubber Liquor Pump Pressure
819-AIT-8983 Scrubber Liquor Density, 12-hr Rolling Average
819-AIT-8952 Scrubber Liquor pH, Hourly Rolling Average
819-PDI-8915 Venturi Exhaust Gas Pressure Drop, Hourly Rolling Average
819-PI-8956 Venturi Pump Pressure
819-TIT-8931 Baghouse Inlet Temperature, Hourly Rolling Average
819-PDIT-8936 BaghouseDifferentialPressure,HourlyRollingAverage
819-FIT-8940 Carbon Injection Air Flow, Hourly Rolling Average
819-FI-8933 Carbon Injection Feed Weight, Hourly Rolling Average
819-PDI-8941 18942 Carbon Filter Differential Pressure, Hourly Rolling Average
819-TI-8939 Carbon Filter Inlet Temperature, Hourly Rolling Average
819-FI-8932 Exhaust Gas Flow Rate, Hourly Rolling Average
819-TIT-8932 Exhaust Gas Temperature @ awnbar
819-PIT-8932 Exhaust Gas Pressure @ amrubar
819-AIT-8302 NB Blower Exhaust CO Concentration, Hourly Rolling Average
819-AAL-8301 A/B Blower Exhaust Gas Oz
819-AIT-8917 Venturi Sump pH, Hourly Rolling Average
819-AIT-8927 Venturi Sump Density, 12-hr Rolling Average
ATLIC STB Plan - Rev. I
Decemb er 2,2010
TOCDF x1
1.0 INTRODT]CTION
The Tooele Chemical Agent Disposal Facility (TOCDF) is ahazardous waste disposal facility
that was designed and built for the United States (U.S.) Army for the destruction of the chemical
agent munitions stockpile at the Deseret Chemical Depot (DCD), located 20 miles south of
Tooele, Utah. EG&G Defense Materials, Inc., (EG&G) operates the TOCDF under contract to
the Army through the Chemical Materials Agency (CMA). The TOCDF is designed to dispose
of chemical Agents GB, VX, and mustard (H-series), drained munitions, contaminated refuse,
bulk containers, liquid wastes, explosives, and propellant components. The planned eventual
closure of the DCD necessitates the destruction of the final remains of two additional agents,
Agent GA and the blister agent Lewisite, to complete the destruction of chemical agents in
storage at DCD. The destruction of these additional chemical agents has been contracted to
EG&G by the CMA, and the destruction activities will be conducted in DCD Area 10 in a newly-
constructed incinerator.
The U.S. Environmental Protection Agency (EPA) identification number for the TOCDF is
UT5210090002. The facility operates under a Resource Conservation and Recovery Act
(RCRA) Part B Permit, issued pursuant to the delegation of the State of Utah, Department of
Environmental Quality (DEQ), Division of Solid &Hazardous Waste (DSHW), under the Utah
Administrative Code, Section 3 15 (R315). The TOCDF also operates under a Title V air permit
administrated by the State of Utah, DEQ, Division of Air Quality (DAQ). These permits are
being modified to include processing Agent GA and Lewisite in the new incinerator. To fulfill
the requirements of these permits, a demonstration of the newly-installed Area 10 Liquid
Incinerator's (ATLIC) ability to effectively treat any hazardous waste such that human health
and the environment are protected will be conducted. This testing will meet the requirements of
a Comprehensive Performance Test (CPT) to meet the Title V and Hazardous Waste Combustors
(HWC) Maximum Achievable Control Technology (MACT) requirements. The EPA
promulgated Replacement HWC MACT Standards for HWCs on 12 October 2005, and they
were finalizedin October 2008.
This plan describes the fifth incinerator system that TOCDF operates to dispose of the chemical
agents stored at DCD. The five incinerators include the two liquid incinerators (LIC1 andLlC?),
the Metal Parts Furnace (MPF), the Deactivation Furnace System (DFS), and the new ATLIC.
Agent Trial Burns (ATBs) have been conducted in the other incinerator systems at the beginning
of each new campaign, and similar testing will be conducted in the ATLIC prior to processing
Agent GA and Lewisite. This plan describes how TOCDF intends to use surrogate chemicals to
demonstrate the combustion of hazardous chemicals in a combined Surrogate Trial Burn (STB)
and CPT in the ATLIC, which will be referred to as the ATLIC STB. (The follow-on ATLIC
Lewisite CPT will demonstrate the processing of increased concentrations of arsenic and
mercury present in the Lewisite and will be addressed in a separate plan.) This plan also serves
as the notification that TOCDF plans to conduct a CPT for the ATLIC. The feed rates, exhaust
ATLIC STB Plan - Rev. I
Decemb er 2, 2010
TOCDF
gas flow rates, flows and temperatures demonstrated during the ATLIC STB will be used to set
limits and operating parameters when the testing is completed.
The ATLIC will consist of a small-scale liquid incinerator, approximately one-third the size of
the existing TOCDF LICs. In order to remain compliant with all state and federal air rules and
regulations while processing these remaining agents, a Pollution Abatement System (PAS) with
enhanced capabilities from those of the existing PAS at TOCDF will be constructed to control air
emissions. The new PAS will havE additional capabilities for mercury and arsenic removal since
it is known that Lewisite TCs have a high amount of mercury and arsenic in the agents. Agent
GA monitoring on the AILIC and PAS will be with Automatic Continuous Air Monitoring
Systems (ACAMS) and Depot Area Air Monitoring Systems (DAAMS), while the Lewisite will
be monitored with MINICAMS and DAAMS. The incinerator will undergo performance testing
as required by the HWC MACT regulations to demonstrate compliance with the National
Emission Standards for Hazardous Air Pollutants as seen in Title 40, Code of Federal
Regulations, Part 63, Subpart EEE (40 CFR 63.1219) for new sources.
The ton containers (TCs) to be processed at the ATLIC include 4 TCs containing approximately
4,000 pounds (lb) of Agent GA (Ethyl N,N-dimethyl phosphoroamidocyanidate) and 10 TCs
containing approximately 26,000 lb of Lewisite [(2-chlorovinyl) dichloroarsine] that are
currently being stored at the DCD. In order to destroy these TCs without impacting the
completion schedule in regards to the Chemical Weapons Convention treaty, a new facility will
be constructed in Area 10 that will work in parallel with TOCDF. There are also ten TCs
(known as "transparency tons") that were found to be empty with low concentrations of Volatile
Organic Compounds (VOCs) in the headspaces. The transparency tons do not contain any
appreciable materials and the liquid levels were so low that samples could not be obtained.
This STB plan will describe how TOCDF will:
o Demonstrate with the use of surrogate chemicals that chemical agents can be destroyed in
accordance with the RCRA requirements outlined in 40 CFR 264.343 and the Utah
Administrative Code, R3 1 5-8-1 5
o Use sampling and analysis methods from Test Methods for Evaluating Solid Waste (SW-
846) (1), 40 CFR 60, Appendix A (2), and Tooele Laboratory Operating Procedures
(TE-LOPs) that have been approved by the DSHW Executive Secretary to measure that
the emissions from the ATLIC meet the required standards.
A separate Continuous Emissions Monitoring System (CEMS) performance evaluation is
conducted annually for the ATLIC CEMS as directed by Attachment 20 to the TOCDF Permit
(3). The ATLIC STB Plan was developed using the EPA guidance in the "Hazardous Waste
Combustion Unit Permitting Manual" (a). In addition, this plan is submitted as a RCRA Permit
modification for the treatment of Agent GA and Lewisite in the ATLIC. Regulatory reference
citations are given, as appropriate, throughout this STB plan.
ATLIC STB PIan - Rev. 1
Decemb er 2,201 0
TOCDF
1.1 ATLIC SURROGATE TRIAL BURN PLAN ORGANIZATION
This ptan is a stand-alone document to allow a separate review from that of the modifications to
the TOCDF Permits. The plan describes the operating conditions for the testing and the samples
to be collected as part of the ATLIC STB. The Quality Assurance Project Plan (QAPP)
(Appendix A) describes the sampling and analyses to be conducted. Appendix B contains the
ATLIC Shakedown Plan for the period prior to the ATLIC STB. The Mass and Energy Balances
(MEBs) are found in Appendix C. The Automatic Waste Feed Cutoffs (AWFCOs) are
summarized in separate tables for the ATLIC in Appendix D. A suflrmary of the Agent GA and
Lewisite characteization data are located in the Supporting Information to the Permit
Modification in Attachment 3 and Attachment 4 contains the referenced drawings for the
ATLIC.
This introduction provides an overview of the plan, including:
. Processdescriptions;
o Waste feed descriptions;
o STB objectives;
o STB approach;
. STB program;
o STB protocol; and
. Expected final permit conditions resulting from the STB.
1.2 FACILITY INFORMATION
The TOCDF is located in EPA Region 8. The TOCDF EPA Identification Number is
UT5210090002, which is also the DSHW permit number. The DCD Title V Operating Permit
Number is 4500071001.
The ATLIC STB points of contact are:
Thaddeus A. Ryba, Jr., TOCDF Site Project Manager
11620 Stark Road
Stockton, UT 84071
(43s) 833-7439
Mr. Gary McCloskey, Vice President and TOCDF General Manager
EG&G Defense Materials, Inc.
11600 Stark Road
Stockton, UT 84071
(43s) 882-s803
ATLIC STB Plan - Rev. 1
Decemb er 2, 2010
TOCDF
Mr. Larry Williams, ATLIC STB Test Director
EG&G Defense Materials, lnc.
11600 Stark Road
Stockton, UT 84071
(43s) 882-s803
1.3 WASTE TREATMENT SYSTEM PROCESS AND FEED DESCRIPTIONS
The ATLIC is located in DCD Area 10, and its operation is not affected by other operations
taking place at TOCDF during the STB. An overview of the facility is provided in the
Supporting Information to the Permit Modification in Attachment 4 the facility site plan,
Drawing TE-16-C-2. The ATLIC has a Primary Combustion Chamber (PCC) for agent
incineration followed by a Secondary Combustion Chamber (SCC). The SCC primarily
incinerates spent decontamination solution (spent decon), but also provides additional residence
time for PCC exhaust gases. Exhaust gases from the SCC are then routed to the PAS for
removal of air pollutants. Brief descriptions of the major discrete components follow, and a
detailed system description is provided in Section 2 of this plan.
1.3.1 Waste Handling and Storage
The demilitarizationprocess begins with the transport of the TCs from their storage site at DCD
Area 10 to the ATLIC for processing. Ton containers are moved from Area 10 storage igloos
and then placed in a glove box, The Agent GA drained from the TCs is pumped to the PCC
directly, while the Lewisite will be pumped to the Lewisite Agent Holding Tank (LCS-TANK-
8511) before being fed to the ATLIC. Any residual Agent GA in the TCs is destroyed by rinsing
with 18 % sodium hydroxide (NaOH). Lewisite remaining in the TCs is removed or destroyed
by the addition of two rinses with 3 molar (M) nitric acid. After treatment by the primary
decontamination chemical, the TCs are rinsed three times with water and a sample of the flnal
rinse is analyzed for agent. If the agent is below the Waste Control Limit (WCL), then the TC is
examined and sent to a Subtitle C Treatment Storage and Disposal Facility (TSDF). If the agent
is above the WCL, then the TC is retumed to storage for later decontamination treatment
followed by additional rinses. The rinse water is drained and sent to the Spent Decontamination
System (SDS) Holding Tank (SDS-TANK-8523).
During the demilitaizationprocess, the facility generates spent decon, which is collected by the
SDS and stored in SDS-TANK-8523 until processed in the SCC. Each tank is sampled after it
has been filled and analyzed for agent and the Human Health Risk Assessment (HHRA) metals.
If the agent concentration is less than 500 parts per million (ppm), the spent decon is pumped
through two spray nozzles into the SCC. If the agent concentration is less than the WCL, the
spent decon may be shipped offsite to a Subtitle C TSDF.
Acid gases and particulate matter (PM) generated during combustion
exhaust gases by the PAS. The scrubber liquor and venturi scrubber
are removed from the
liquor remove the acid
ATLIC STB Plan - Rev. 1
Decemb er 2,2010
TOCDF
gases and PM. The scrubber liquor removed from the PAS is stored in PAS Blowdown Storage
Tanks (PAS-TANK-8551, -8552, -8553) until it is shipped off-site for disposal.
1.3.2 Liquid Incinerator System
The,A.TLIC was custom designed and hence has no model designation. The ATLIC will be
comprised of a two chamber, refractory-lined furnace and associated subsystems. The ATLIC
will destroy the surrogate chemicals, Agent GA, Lewisite, and spent decon through high-
temperature incineration. The PCC was designed to treat the surrogate chemicals, Agent GA,
and Lewisite, while the SCC was designed to process spent decon.
The ATLIC will be controlled by the Facility Control System (FCS), which will be responsible
to safely and efficiently monitor and control the process systems, process support systems, and
control systems that are located within the ATLIC. The FCS will be composed of
microprocessor-based electronic controllers with the primary function of assisting operations
personnel in the safe startup, monitoring, control, data logging, alarming, and planned shutdown
of the facility. The FCS will consist of hardware including operator and engineer workstations,
and system software and development tools for system control, data collection, data storage,
report generation, and programming. Operation of the FCS will be conducted from a central
Control Center located near the ATLIC.
The PCC hot face will be lined with SR-90 alumina brick. The PCC temperature will be
maintained by a 3,000,000 British thermal units/hour (Btu/hr) natural gas fired burner allowing a
maximum feed rate of approximately 325 pounds per hour (lb/h) for Agent GA and
approximately 325Ib/hr Lewisite. A liquid waste nozzle will be mounted next to the burner and
angled towards the burner so that material fed through the waste nozzle mix with the hot burner
gases. The PCC temperature will be maintained above 2,500 oF for processing of all wastes.
The ATLIC will operate with a minimum 3-seconds overall system gas residence time through
the PCC and SCC (the exhaust duct leading to the PAS from the SCC is not included). There
will be two adjustable-speed induced draft (ID) fans in series associated with the ATLIC. The
ID fans, using negative pressure, will move the exhaust gases from the PCC directly into the
SCC, and on through the PAS for scrubbing and filtration. The exhaust gases will then exit the
PAS, enter the fans and exit the exhaust stack into the atmosphere.
The SCC hot face will be lined with Ruby SR Brick and the temperature will be maintained by a
1,000,000 Btu/hr natural gas fired burner. The gases entering the secondary chamber from the
primary chamber are cooled by injection of water or spent decon through two air-atomized
nozzles located next to the burner. Thenozzles will be capable of flows up to 2 gallons per
minute (gpm). The nominal flow rate throughthenozzles during normal operations will be
0.8 gpm. The SCC will be maintained above 1,800 oF for processing of all wastes.
An enclosure will be added to Igloo 1639 in Area 10 to house the new incinerator and associated
PAS. Utilities required by the ATLIC include fuel gas, electric power, plant air, process water,
ATLIC STB Plan - Rev. I
Decemb er 2, 2010
TOCDF
and instrument air. See Attachment 4 to the permit modification for a detailed drawing that
includes both chambers of the ATLIC and the PAS.
1.3.3 Pollution Abatement System
The PAS is designed to cool the exhaust gas exiting the SCC at approximately 2,000 oF to
approximately 70 oF at the exit of the condenser/absorber before it is heated to 180 oF before
going through the baghouse and carbon filter. The PAS will remove pollutants such as PM, acid
gases, and metals from the exhaust gas to below regulatory standards prior to being released to
the atmosphere. Additional filtration for mercury removal is also part of the PAS design. The
PAS will be in operation at all times that the ATLIC is operating, including startup and at idle
withno waste in the fumace.
The PAS equipment will consist of a quench tower, a series of packed bed scrubbers, a high-
energy venturi scrubber with a manually adjusted throat, a moisture separator, a Brine chiller, an
electric gas reheater, a powdered activated carbon (PAC) injection system, a baghouse, a sulfur-
impregnated carbon filter system, an induced draft fan, and an exhaust stack. A description of
each piece of equipment and its function in the PAS can be found in Section 2.10.
1.4 WASTES TO BE TREATED
The ATLIC will destroy the surrogate chemicals, Agent GA, Lewisite, and spent decon through
hightemperature incineration. The PCC is designed to treat the surrogate mixture, Agent GA,
and Lewisite, while the SCC is designed to process spent decon.
The State of Utah has defined chemical agents as acutely hazardous and identified them as P999
(i.e., chemical agent) waste along with any items contaminated by chemical agent. However, the
ATLIC will not produce or handle any liquids containing polychlorinated biphenyls (PCBs) that
would be regulated under the Toxic Substances Control Act (TSCA), or treat any waste materials
with dioxin waste codes (i.e. F020, F021,F022,F023,F026, or F027).
1.4.1 Worst Case Demonstration by the Surrogate Mixture
The ATLIC STB will demonstrate the worst case for organic compounds incineration by
establishing a Destruction and Removal Efficiency (DRE) for Class I compounds by the EPA
thermal stability ranking system guidance (5). The STB will use chlorobenzene in the surrogate
mixture feed material and chlorobenzene will be fed by itself to the SCC. Chlorobenzene was
chosen because it is a Class 1 compound in the EPA ranking system. The demonstration of a
DRE for a Class 1 compound allows other Class 1 compounds and any compounds ranked lower
to be incinerated without demonstrating a DRE for every compound; therefore, the
demonstration of a DRE for chlorobenzene establishes the worst case for both Agent GA and
Lewisite processing.
ATLIC STB Plan - Rev. I
Decemb er 2, 2010
TOCDF
Chlorobenzene and tetrachloroethene were selected as the Principal Organic Hazardous
Constituents (POHCs) for the ATLIC STB based on their thermal stability and high ranking in
the EPA thermal stability ranking system guidance (5). As a part of this test, a DRE will be
measured for the POHCs. The compounds in the surrogate mixture are classified as Hazardous
Air Pollutants (HAPs) by EPA. Agent GA and Lewisite will not have a DRE measured since
they are estimated to rank as a Class 4 or 5 compounds (5). The surrogate mixture will be fed to
the ATLIC during the shakedown period and the STB, and the details for the surrogate mixture
are discussed in Sections 5.1.1 and 5.3.1.
The ATLIC STB will also demonstrate a worst case for metals that will support the processing of
Agent GA. The worst case for metals ernissions for Lewisite will be established by the LCPT.
Metals will be spiked into the surrogate mixture in the feed line just before the waste feednozzle
to provide a test for metals emissions; The three classes of metals will be spiked dwing the STB:
volatile metals will be spiked with mercury, semi-volatile metals will be spiked by lead, and the
low volatile metals will be spiked with arsenic. The lead spiked for the STB will also
demonstrate the worst case for semi-volatile metals for the processing of Lewisite. A solution
containing arsenic, lead, and mercury will be pumped from their storage container into the
surrogate mixture in the waste feed line just before the waste feednozzle in the PCC. The metals
will be in a form that is miscible'in the organic compounds to allow the metals spike to be
carried into the PCC.
The ATLIC STB will also demonstrate the worst case for PM loading to the ATLIC PAS that
will support the processing of Agent GA. The worst case for PM loading for processing
Lewisite will be demonstrated by the LCPT. The spent decon used for the STB will be a diluted
phosphoric acid solution to demonstrate the removal of phosphorus and to increase the PM
loading to the system to simulate the ash loading to the PAS that will be encountered during the
processing of Agent GA. (See Section 5.8 for the discussion on ash loading.) Chlorobenzene
will also be spiked into the feed line to the SCC to demonstrate the processing of organic
compounds in the SCC as a part of the STB.
1.4.2 Normal Wastes Treated
The DREs established for the surrogates will allow the ATLIC to process Agent GA and
Lewisite wastes. Table 1-1 shows the composition of the four TCs with Agent GA as
determined by a study conducted in 2009 (6) with a copy supplied in Attachment 3 to the permit
modification. Chlorobenzene is listed in Table 1-1 as a constituent of the Agent GA wastes, but
it will be treated at a lower feed rate than demonstrated in the ATLIC STB. Table 1-2 shows the
composition of the Lewisite from the 2009 study (6). Both of these tables show that the DREs
for the surrogates are a conservative demonstration for the actual compounds treated by the
normal operations of the ATLIC.
ATLIC STB Plan - Rev. I
Decemb er 2, 2010
TOCDF
TABLE I-1. AGEI{T GA CHARACTERIZATION SUMIVIARY
**Fsi*ffiffi $iffi ..ilH
::lJrl
iai::
:ilii';
Ethyl N.N. -d i methylphosphoro-
amidocyanidate (GA) (Wt%)3 8.8 2I .t 26"6 19.8 '26.6
Triethy lphosphate (Area 9'o)1.0
Ethyl methyl N.N-
d imethy I pho sphoroam i d ate
(Area %)
2.0 8"0 7"0 5"7
Dimethyl dimethyl-
phosphoram idate (Area o/o)1.0 1.0
N,N -Dimethyl O.O'-diethyl
phosphoramidate (Area %)10 r0 '20 20 1s"0
bi s 0.J,N-d imethyl) O-ethy I
phosphorocliamidate (Area %)
0.5 6"0 8.0 9"0 5"9
Tetramethy I phosphorocyaniclic
diamide lAre a oA:)8"0 7"0 10.0 I 1.Cr 9,0
Chlorobenzene (Wt%)
Uniclentified TlCs lArea 0/o,)
T"t"l
4.09
I 7.8
8r.19
1 t"6
tr5
-71 "7
l 3.l
l:i"3
I00
I 0"'7
21"5
-r00
9" 8'7
l6"9tl
8S-t
hletals
A,rtt"r*U,' (r"g/kgi
Arsenic (mg/kg)
Bariurn (mg/k.-q)
Beryllium (rn,*eikg)
Boron (rng/kg)
Cadmium (rng/kg)
Ch**rr;* (*g/kg)
C"brlt (rg/kg)
:i4.9
0" 52w
r "06
-. o05
I09
< 0.05
'2 "13
.0.05
40":1
OJLl
29J
ute
0.05
1 t.2
0"05
2 "57
0.05
:10, i
ffi
.) i+
,19 "6
0-]9
-U. U)
l I3
0"05
L"25
CL 05
) l.*t
:lt 6
'jz.9
036
0"05
9s"6
0"0s
LN
0"0s
,1,- .-r). /
l{i:2Ji
:i6.3
0"6
0,1
107 "4
0"1
1"8
0.05
Copper (mg/k-q)'21.6 r 0"3 0.82 1 ,'7'2 E"6
Lead (m-eikg)r8.4 18"7 0"27 a "'7'7 9.5
Manganese (mg/kg)1"25 1"32 0.1 3 0"2 1 4"7
Mercury (mg/kg)4.1 4"49 10"4 1"8 r rl 'Jq ".L
Nickel (mg/ke)0.68 4.7 0.09 0.19 0"4
Selenium (mg/kg)< 0.05 0.05 0.07 0.09 0"1
Silver (rng/kg)< 0.05 0.05 0. 12 0.12 0.1
Thallium (mg/kg)< 0.05 0.05 0.05 0.0s 0.1
IiTin (melke) ___ l
304 |0.2s _ _l a.27
|
6.7 5
-
2.5
iVanadium (mg/kg) |9.5 8 1 1.5 13"9 11 I 1.5
Zinc(mg/ke) _ ___l 62.7 43.1 28.3 36"7 42.7
GAL Data Sum 2009.x1s
Agent GA Data Summary (2)
ATLIC STB Plan - Rev. I
Decernb er 2^ 201 0
TABLE I-2. LEWISITE, CHARACTE,RIZATIOI{ SUMMARY
:i.;::.i:it:ili.j:;*i1.i.i !t-,n:i':r:::ii.;i.;:r:,::j,:,'1..i::',,,:ii,.:
iii;jiiit;trifiiiiriti:*is'iiiiiii:, :'i :i:i' i
;i.i:iitri:t:l:i;:ii:i jiil\:,lt,iil.l li. iX'i*),i,j;iir :,;i:;i:;;; ;:
li:'i. ii 1.:ii; :::,:;.:;i; ',:J..i:ii jji;1.ii::l,,,;:;. ..t::i,:i;':'ri:;'......:..,,;..::-,.. .. - ._
-:.; 1..,',_,,.'.. .:,,_:,:.,,'_,,,,.,,
.: ::::.r:,:::-::i:.ri::j':'il:rr:r:::::.:. :i.lr:'...:-':.--::.'
Compounds (Area %)
(2-Chlorovinyl)
dichloroarsine
(Lewisite L 1)
7 6.9 2.1 80.4 7 4.3
bis (2-Chlorovinyl)
chloroarsine
(Lewisite LZ)
14.9 1.0 16.4 I 3.0
tr i s (2 - Chlorovinyl)arslne
(Lewisite L3)0.73 AM 0.99 ND
AsCh 1.3 0.34 r.9 NI)
Metals
Aluminum (mg/kg)34.3 4.25 44 29.8
Antimon,v (mg/kg)'!'tlJ1J 16.0 338 292
Arsenic (Wt%)32.1 1.1I 33.5 30.5
Baritrm (mg/kg)0.37 6 0"11 0.5e 0.16
Beryllium 1mg/k,_e)< 0.06 ND 0" 10 < 0.05
Boron (mg/kg)98. 1 11 0 113 788
CaCmium (mgikg;< 0"06 hID 0 10 <_0.05
Chromium (rnglk-q)1"34 0 ls 1.59 1 "17
Cobalt (mg/kg)< 0.05 NiD < 0.05 < 0.05
Copper (mg/ke)0.94 0" 8s 2.35 a.26
Lead (mgikg)0 "32 0.20 0.87 0.1 8
Manganese (rng/kg)0.18 0.07 0.3 s 0.1 1
Mercury (mg/kg)r92 136 s28 48.4
h{ickel (rngikg)a "22 0 "23 0.84 0.06
Selenium (mg/kg).- 0.68 2.04 6.36 0.05
Silver (mg/kg)0. 14 0.08 0.3 s 0.1
Thallium (mg/kg)< 0.05 NID < 0.05 < 0.05
Tin (mg/kg)<0"39 0.26 0.9s < 0.25
Vanadium (mg/kg)14.7 t.6 16.9 1 1.8
Zrnc (mg/kg)44.4 t3.2 72 3 0.8
ATLIC S'fB Plan - Rev. I
Decemb er 2.2010
C^ L nataSum 2oo9.xls
STB I-ewis Summary
Spent decon resulting from the treatment of Agent GA will be composed of a mixture of sodium
hydroxide, Agent GA hydrolysis products, and the water rinses from the TCs. It will be treated
in the SCC and will contain about 0.25 % organic compound concentrations. Spent decon will
have an agent concentration that is less than (<) 500 parts per million (ppm) before it can be
treated in the SCC. During the shakedown and STB, the spent decon will not be analyzed for
agent because no agent will have been introduced into the system until after the STB.
1.5 SURROGATE TRIAL BURN OBJECTIVES
The objectives for the ATLIC STB are to demonstrate:
A maximum surrogate mixture feed rate on an Hourly Rolling Average (HRA) basis,
while maintaining a DRE >99.9999 %o for the designated POHCs, chlorobenzene and
tetrachloroethene.
Control of carbon monoxide (CO) emissions to < 100 parts per million dry volume
(ppmdv), corrected to 7 percent oxygen (@7 % O2), on an HRA basis.
That PM emissions are < 0.0016 grains/dry standard cubic foot (grldscf) @ 7 % Oz
(MACT limit).
That the combined halogen emissions [hydrogen chloride (HCD and chlorine (Cl2) gas]
are < 2l ppm (MACT) expressed as HCI equivalents, dry basis @ 7 % Oz.
That the Polychlorinated Dibenzo-p-dioxin (PCDD) and Polychlorinated Dibenzofuran
(PCDF) emissions are < 0.20 nanograms/dscm (ng/dscm) 2,3,7,8-Tetrachlorodibenzo-p-
dioxin (TCDD) Toxic Equivalent Concentration (TEQ) @7 % C,2.
The mercury emissions are < 8.1 pgidscm @7 % 02 (MACT limit).
The semi-volatile metals emissions (lead and cadmium) are < 10 pgldscm @7 % 02
(MACT limiQ.
The low-volatility metals emissions (arsenic, beryllium, and chromium) are < 23 pg/dscm
@7 % 02 (MACT limit).
The emission rate of nitrogen oxides (NO.).
Limitations on waste feed characteristics and process operating conditions in order to
ensure compliance with performance standards and risk-based emission limits.
ATLIC STB Plan - Rev. I
Decemb er 2,2010
TOCDF 10
That the Total Hydrocarbon (THC) emissions are < 10 ppmdv @7 % Oz over an HRA
(monitored continuously with a CEMS), and reported as propane.
1.6 SURROGATE TRIAL BURN APPROACH
It is anticipated that chemical agents and spent decon may be processed simultaneously during
the Agent GA and Lewisite Campaign. Therefore, maximum waste feed rates for each stream
will be demonstrated simultaneously during the ATLIC STB. The incinerator operator will thus
have the flexibility to deal with combinations of both wastes while controlling the overall
combustion process within specific limits (including temperature, exhaust gas velocity, and
thermal duty). The operating parameter limits (OPL) will be set per 40 CFR 63.1209 with a
single mode of operation during the STB.
1.7 PROPOSED SURROGATE TRIAL BURN PROGRAM
The ATLIC is operated as a steady state incinerator. The ATLIC STB will be conducted at one
test condition established as a worst case condition by feeding the maximum surrogate mixture
feed rate with spiking metals into the PCC and chlorobenzene and phosphoric acid to the SCC.
As a part of this test, a surrogate mixture containing chlorobenzene and tetrachloroethene will be
fed to the PCC and chlorobenzene will be added to the SCC. A DRE measured to cover
processing HAPs in the ATLIC will include the chlorobenzene added in the PCC and also the
chlorobenzene added to the SCC. The ATLIC temperatures will be maintained within the limits
listed in Appendix D. The combustion airflows in the system vary ovff a small range, and
system pressures are maintained negative relative to the ATLIC furnace room. The metals will
be spiked into the surrogate mixture in the feed line to provide a "worst-case" test to support the
processing of Agent GA, thereby setting a fixed metals feed rate for Agent GA processing.
Spent decon fed to the SCC has the potential to contain HAPs by the EPA; therefore,
chlorobenzene will be fed to the SCC to demonstrate the destruction of HAPs in the SCC.
Operation of the PAS follows the furnace; hence, fluctuations in the PAS parameters will be
limited. The pH of the scrubber liquor and the venturi scrubber liquor will be controlled at a pH
> 7 to remove the acid gases from the exhaust gases, and scrubber liquor flows are controlled
principally to maintain PAS component liquid levels and temperatures.
1.8 SURROGATE TRIAL BURN SAMPLING AND ANALYTICAL PROTOCOLS
Detailed discussions of the sampling and analysis procedures are provided in the QAPP
(Appendix A). The structure of this STB is based on the previously-stated objectives in Section
1.4. The exhaust gas sampling and analytical methods to be used to quantify specific ATLIC
STB parameters are taken from SW-846 (1), 40 CFR 60, Appendix A (2), and TOCDF
Procedures. These methods are described below:
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11TOCDF
. The ATLIC CEMS will monitor for CO, Oz, and NO* on a continuous basis. The CO
concentration will be used to demonstrate control of Products of Incomplete Combustion
(PICs).
o EPA Methods I andZ (2) will determine traverse sampling locations and flow rates.
o EPA Method 3 (2) will determine the Oz and carbon dioxide (COz) concentrations using
an Orsat analyzer supplied by the sampling subcontractor.
o Each isokinetic sampling train will determine the moisture content of the exhaust gas.
o EPA Method 5126A(2) will determine the PM emissions and halogen (HCl, and Cl2 )
emissions.
o EPA Method 29 (2) will determine the HHRA metals emissions.
o SW-846, Method 0031 (1), will determine VOC emissions.
o SW-846, Method 0010 (1), will determine Semi-Volatile Organic Compounds (SVOC)
emissions
o SW-846, Method 0023A (1), will determine PCDD/PCDF emissions.
O . Method 25A(z)will determine the THC using a sampling subcontractor CEMS.
1.9 FINAL PERMIT LIMITS
The OPLs will be established following the guidance in 40 CFR 63.1209. Anticipated OPLs
resulting from this STB are summarized in Appendix D and will be established on the basis of
ATLIC STB results. The OPLs are established on the basis of regulatory guidance, process
design/safety considerations, or vendor recommendations. The OPLs will be continuously-
monitored process parameters, which will be tied to AWFCOs. Some operating parameters do
not require continuous monitoring and will not be interlocked with the AWFCO system;
however, detailed operating records will be maintained to demonstrate compliance with
permitted operating conditions. During the shakedown period, the AWFCO settings listed in
Appendix D will remain operational at the limits noted in Appendix D.
Some OPLs will be established independent of the STB results. For the most part, their
respective limits will be based on engineering considerations and good operating practices. For
safety and system performance purposes, the quench tower exit temperature and the differential
pressure between atomizinggas and waste feed will be monitored and recorded continuously,
and interlocked with the AWFCO system.
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1.10 JUSTIFICATION FOR EXEMPTION
The TOCDF is not seeking an exemption from any of the
because the regulatory requirements of 40 CFP.. 27 0. 19(a)
incinerator or trial burn requirements
do not apply to the ATLIC.
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TOCDF 13
2.0 DETAILED ENGINEERING DESCRIPTION OF THE ATLIC
This STB plan discusses the requirements of 40 CFR 270.19(b) to conduct a trial burn. This
section discusses the current engineering configuration of the ATLIC as required by 40 CFR
270.62(b)(2xii). The operating parameters will be established by the STB and included in the
final permits. Engineering changes that might be encountered during shakedown would
necessitate revisions to this STB plan; any such changes would be coordinated with the DAQ
and DSHW.
The ATLIC engineering drawings and specifications were prepared by EG&G. Selected Piping
and Instrument Diagrams (P&IDs) and equipment arrangements are provided in the
Supplemental lnformation for the Permit Modification, Attachment 4. DrawingsBG-22-F-8201,
Sheet 1, and EG-22-F-8202, Sheet I show a simplified process flow diagram (see Attachment 4).
2.1 PRIMARY COMBUSTION CHAMBER
The ATLIC is a controlled-air, direct-fired, liquid-injection incinerator with a PCC and a SCC.
The vessels are refractory-lined with the PCC designed to incinerate chemical agents drained
from bulk containers, and the SCC designed to process spent decon and ensure destruction of
agent. The ATLIC is designed so that the waste feed is pumped at a continuous, uniform rate to
the PCC. The waste feed is mixed with combustion air and is dispersed into the chamber with an
air-atomizingnozzle. Supplemental fuel (natural gas) is used for temperature control within the
PCC.
The PCC will be a horizontal, refractory-lined steel cylinder that is 12.5 feet (ft) in length and a
diameter of 3.5 ft. It will be refractory lined with a high-alumina corrosive-resistant SR90 brick.
One end of the chamber will be flanged and sealed with a flat steel plate, which can be removed
for refractory repair. A single burner assembly and waste feed injectionnozzle will be mounted
to the chamber end plate.
Combustion air will be introduced to the bumer assembly through a wind box, which will enter
into the primary chamber. As part of the burner assembly, a 3-million-Btu/hr natural gas fueled
burner will be used to ensure a stable flame pattern within the PCC and to control chamber
temperature, which is maintained betyeen 2,500 oF and 2,850 oF. Natural gas will be fed to the
PCC burner at rates between 49 and 150 lb/hr (see the Mass/Energy Balances in Appendix C).
Thermocouples at the exit of the PCC will measure the PCC exit gas temperature. The
temperatures will be transmitted to the Programmable Logic Controller (PLC) for temperature
control. The natural gas supplied to the PCC bumer assembly will be modulated to maintain the
PCC exit gas temperature at the setpoint.
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TOCDF L4
Surrogate compounds, Agent GA, or Lewisite will be supplied to the ATLIC PCC by a waste
feed injectionnozzle. Agent will be dispersed into the burner flame through the air-atomizing
feednozzle. Plant air is used to atomize the agent fed through the PCC liquid injection nozzles.
The waste feednozzle will be capable of processing neat agent. Processing rates for the furnace
will be established during the ATLIC STB.
The combined physical dimensions, gas flows, temperatures, and waste feed rates result in a
calculated residence time for the PCC of I.25 seconds (see calculations in Appendix C) and a
combined residence time for the PCC and SCC of 3.36 seconds. Due to the fact that Agent GA
contains chlorobenzene, which is difficult to incinerate, the increased residence time supplied by
the SCC is necessary to safely ensure the organic compounds are destroyed in the PCC and SCC.
This increase will help to oxidize the agent and improve the processing of chlorobenzene.
The furnace pressure will be maintained below the pressure in the ATLIC room, at a nominal
-3.0 to -7.0 inches water column (inWC). The furnace pressure will be varied by modulating the
speed of the two ID fans to maintain the pressure control setpoint. Pressure instruments measure
the furnace and room pressures and will be transmitted to a PLC pressure controller.
2.2 SECONDARY COMBUSTION CHAMBER
Exhaust gases from the PCC enter directly into the SCC. The SCC will be ahorizontal,
refractory-lined steel cylinder that is 12 ft in length and has a diameter of approximately 4 ft.
The refractory will be a corrosive-resistant Ruby Brick with Ruby bond mortar. A flanged inlet
in the side and toward one end of the chamber provides an inlet for the exhaust gasses from the
primary chamber. The ends of the chamber are flanged and sealed with flat steel plates. The end
plates are removable for refractory repair.
A single burner assembly and two liquid injection nozzles will be mounted to the SCC inlet end
plate. The two liquid injection nozzles utilize compressed air for atomization of either spent
decon or process water fed to the chamber. The burner assembly consists of a wind box, fuel gas
injector, and combustion zone. Combustion air is introduced to the burner assembly through the
wind box. A 1-million-Btu/hr natural gas fueled burner will be used to ensure a stable flame
pattern within the SCC and to control chamber temperature. Natural gas will be fed to the SCC
burner at rates between 16 and 50 lbihr (see the Mass/Energy Balances in Appendix C).
Thermocouples at the exit of the of the SCC measure the ATLIC exit gas temperature, and then
the temperature readings are transmitted to the PLC for temperature control. Either the fuel
supplied to the burner or the water/spent decon supplied to the liquid injection nozzles will be
modulated to maintain the SCC chamber exit gas temperature at the setpoint.
The SCC will operate at temperatures between 1,800 "F and2,200 oF. Either spent decon,
generated from facility maintenance activities and the rinsing and decontamination of TCs, or
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process water is introduced through two liquid atomizing nozzles (with nominal flow rates
during normal operations of 0.8 gpm) to lower temperature of the gas as it enters the SCC. The
spent dbcon or water evaporates and destroys any organic compounds present. Spent decon will
be supplied only if all process conditions are met, while process water will be used at all other
times. The process water flow rate is limited by the control code to a minimum of 2l5lblhr for
cooling of the liquid injection nozzles. Plant air is used to atomize the spent decon or water fed
to the SCC liquid injection nozzles.
The combined physical dimensions, gas flows, temperatures, and waste feed rates result in a
calculated residence time for the SCC of 2.11 seconds (see calculations in Appendix C) and a
combined residence time for the PCC and SCC of 3.36 seconds.
The furnace pressure is maintained below the pressure in the ATLIC room. The ATLIC pressure
is maintained at a nominal -3.0 to -7.0 inWC. The furnace pressure is varied by modulating the
speed of the ID fan to maintain the pressure control setpoint. Pressure instruments measure the
furnace and room pressures, and will be transmitted to a PLC pressure control.
2.3 DESCRIPTION OF THE WASTE FEED NOZZLES AND GAS BURNERS
A natural gas fueled burner is used to ensure a stable flame pattern within the PCC and to control
chamber temperature. The PCC temperature is maintained by a 3-million-Btu/tr natural gas
fired burner. An air-atomizing waste feednozzle is mounted next to the burner and angled
towards the bumer such that material fed through the waste nozzle mix with the hot burner gases.
The operating temperature of the PCC is maintained at a setpoint of approximately 2,500 oF.
The ATLIC combustion air blower provides combustion air through a supply duct to both the
PCC and SCC burner assemblies. The air flow volume will be measured to the PCC and SCC
burners by an orifice plate in the combustion air duct. A flow-control valve in the combustion
air supply duct to each furnace chamber burner maintains the desired flow to the bumers. The
combustion air flow will be set proportional to the fuel flow during fumace ramp-up and ramp-
down. During normal operations, the combustion air flow will be maintained at a constant rate
to provide excess air in both chambers for combustion during agent and waste processing to
ensure complete destruction of agent and organic compounds.
A natural gas fueled burner is used to ensure a stable temperature within the ATLIC SCC. The
SCC temperature is maintained by a 1-million-Btu/hr natural gas fired burner at a setpoint of
1,800 'F. Exhaust gases from the PCC enter directly into the ATLIC SCC. Spent decon or
water is introduced into the SCC through air-atomized nozzles located next to the burner to
lower the temperature of the gas as it enters the SCC. The nozzles are capable of flows lp to 2
gpm. The nominal flow rate through thenozzles during normal operations will be 0.8 gpm. The
spent decon/water evaporates, and any organic residue burns.
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TOCDF t6
2.4 DESCRIPTION OF THE AUXILIARY FUEL SYSTEM
Natural gas is fired to heat both the PCC and the SCC to the proper operating temperatures prior
to feeding the surrogate mixture or spent decon. It is supplied to the PCC through a line to the
burner system and supplements the injected chemicals to maintain the desired combustion
temperatures. Natural gas is supplied to the SCC through a line to the burner to provide
supplemental heating during periods of high spent decon feed rates to offset the cooling provided
by the spent decon. A pressure regulator reduces the fuel supply pressure to the burners. The
fuel flow rate will be measured by an orifice plate, and regulated by a flow control valve and
controller. Both burners are equipped with independent monitors, controls, interlocks, and fail
safe devices required by the National Fire Protection Association.
A flame safety shutdown system (FSSS) ensures safe operation of the burners. The FSSS is
located in the burner management system (BMS) panel and connects to the furnace controls
through a PLC. The BMS controls all fumace bumer operations through its connections to the
PLC.
2.5 AGENT TC DRAIN AND RINSE SYSTEM
Glove boxes have been used in the past to sample for types and amounts of agent in munitions.
The ATLIC TC drain and rinse system will consist of two separate glove boxes that will allow
the draining of Agent GA and Lewisite TCs of their liquid agent. There will also be the
capability to decontaminate the TCs by draining them and rinsing the drained TCs. At the
completion of the TC draining and rinsing operations, the glove boxes will be removed from the
ATLIC Processing Bay to make room for the TC cutting machine, which will cut the
decontaminated TCs to allow access to the valves and eductor tubes and to allow inspection prior
to shipment to a Subtitle C TSDF. Agent GA and Lewisite TCs will be processed through this
drain and rinse system individually depending on the current agent campaign.
The glove boxes are sealed environmental enclosures that prevent the escape of agent vapors to
the ambient air within the ATLIC Processing Bay. The pressure within the sealed glove box is
maintained negative relative to the ATLIC Processing Bay pressure by ducting that connects the
glove box to the ATLIC Heating, Ventilation, and Cooling (HVAC) system. The differential
pressures in the gloveboxes are monitored by PDIT-831 1 and PDIT-8319 which are recorded by
the control system. There are high and low pressure alarms associated with these monitors.
Both glove boxes will contain agent drain systems with a roller and drive assembly to assist
operators in getting the maximum amount of agent from the TCs. The valves within each glove
box can be arrayed to transfer the contents of each TC to the ATLIC PCC, the Lewisite Agent
Holding Tank, the SDS Holding Tank, or the Nitric Waste Collection tank. The valve located
outside each glove box can be arrayed to fill TCs, drained of their agent fill, with
decontamination solution or water. The outside valve can also add regulated air to enhance the
draining process by "air padding" the TC and/or clearing the TC eductor tubes. The agent-filled
ATLIC STB Plan - Rev. I
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TOCDF l7
TCs will be brought from storage in Area l0 to the processing area and placed on a transfer
table. The TCs will then be placed individually into glove boxes.
2.5.1 Agent GA TC Drain and Rinse System
The Agent GA will be drained and fed directly from the TC to the PCC. The Agent GA TCs are
processed by placing the TC into the glove box and rotating it so that the two fill and drain
valves are aligned vertically. A process air line is attached to the upper valve, and the drain line
is attached to the lower valve. The connections are made using specially-designed shutoff quick-
connect couplers, and the valves are then opened. The air added to the TC through the top valve
both prevents a vacuum from forming in the TC as the agent is removed, and provides additional
pressure to assist in agent draining. If plugged drain and fill valves are encountered, the same air
line can be used to unplug the valve(s). If the valve(s) cannot be unplugged using compressed
air, a drain lance can be inserted into the TC by removing one of the "blow-out" plugs that are
located on the opposite end of the TC from the drain and fill valves.
The Agent GA will be drained from the TC until less than 0.5 inch of agent remains in the TC,
which corresponds to about 7 lb of agent. Once emptied of its agent fiIl, the Agent GA TC is
filled with an 18 Yo NaOH solution. Approximately 110 gallons of 18 % NaOH will be added to
fill the TC more than half way. The TC is then rotated for a minimum of 60 minutes. The
rotation of the TC ensures that the solution contacts all the TCs' interior surfaces. The spent
decon solution is drained from the TC to the SDS Holding Tank. The TC then has
approximately 110 gallons of water added to filI the TC to more than half full and is rotated for a
minimum of 60 minutes to allow the rinse to contact the TC interior. This water rinse is
conducted atotal of three times with the rinse collected in the SDS Holding Tank.
A sample is collected from the final water rinse and analyzed for Agent GA concentration. If the
agent concentration is below the WCL, (20 ppb for Agent GA), then the TCs are stored until they
can be opened and examined for solids and transferred to an off-site Subtitle C TSDF. If the
Agent GA concentration is greater than the WCL but less than 1,000 ppm, the TCs are sent to
storage until the Lewisite agent has been processed and the TCs will be returned to the
gloveboxes and the NaOH and water rinses are continued until the Agent GA concentration is
less than the WCL. If the Agent GA concentration is greater than 1,000 ppm, the TC will be
rinsed with NaOH and water until the concentration is less than 1,000 ppm. The spent decon and
water generated from rinsing the Agent GA TCs are transferred to the SDS Holding Tank and
treated in the ATLIC SCC.
The cleaned Agent GA TCs will be stored until the gloveboxes can be removed and replaced
with the TC cutting device. This device will cut the TC open to allow access to the valves and
eductor tubes, which will be removed. Any solids remaining will be removed and the TCs will
be transferred to an off-site Subtitle C TSDF. The solids will be analyzed for Agent GA and
then handled as a hazardous waste and transferred to a Subtitle C TSDF.
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2.5.2 Lewisite TC Drain and Rinse System
Lewisite TCs are prepared for draining in a similar manner to the Agent GA TCs; the difference
is the agent drained is sent to the Lewisite Agent Holding Tank, and the solution used to
decontaminate the TC interior is a 3.0 mole/liter fmolar (M)] nitric acid solution.
The Lewisite is drained from the TCs and hansferred to the LCS-TANK-8Sl1, which is located
in the ATLIC Toxic Area (TOX). The contents of LCS-TANK-8511 are mixed and sampled
prior to being fed to the PCC. Once drained, the Lewisite TCs are filled with approximately 110
gallons of a 3 M nitric acid solution that will fill the TC more than half full and the TC is then
rotated for a minimum of 60 minutes. The resulting nitric acid rinse is transferred to LCS-
TANK-8516, also located in the TOX. A second nitric acid rinse is then performed using a new
110 gallons of 3 M nitric acid. The second rinse is transferred to LCS-TANK-8516. When the
tank is filled, it is mixed, sampled, and analyzed for Lewisite. If the Lewisite concentration is
greater than the WCL, 8 M nitric acid is added to the tank and the tank is mixed and resampled.
The tank contents are treated with nitric acid until the Lewisite concentration is below the WCL.
After the Lewisite concentration has been lowered to < WCL, the nitric acid solution is shipped
off-site to a deep well injection facility.
Once the nitric acid is drained from the TCs, the TCs are filled with approximately 110 gallons
of water and the TC is rotated for a minimum of 60 minutes, and then drained. This rinse is
conducted three times. A sample is collected from the final water rinse, which is analyzed for
Lewisite concentration. If the Lewisite concentration is less than the WCL of 200 ppb, then the
TCs are stored until they can be opened and examined for solids and transferred to an off-site
Subtitle C TSDF. If the Lewisite concentration is greater than the WCL but less than 1,000 ppm,
the TCs are sent to storage until the Lewisite agent has been processed and the TCs will be
returned to the gloveboxes and the nitric acid and water rinses are continued until the Lewisite
concentration in the last water rinse is less than the WCL. If the Lewisite concentration is
greater than 1,000 ppm, the TC will be rinsed with 3 M nitric acid and water until the water rinse
Lewisite concentration is less than 1,000 ppm. The water rinses are transferred to the SES-
TANK-8523 and treated in the SCC.
The Lewisite TCs will be rinsed with nitric acid and water until the third water rinse has a
Lewisite concentration that is < WCL. The cleaned Lewisite TCs will be stored until the
gloveboxes can be removed and replaced with the TC cutting device. This device will cut the
TC open to allow access to the valves and eductor tubes, which will be removed. Any solids
remaining will be removed and the TCs will be transferred to an off-site Subtitle C TSDF. The
solids will be analyzed for Lewisite and then handled as ahazardous waste and transferred to a
Subtitle C TSDF.
O
TOCDF ATLIC STB Plan - Rev. I
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T9
2.5.3 Transparency TCs Decontamination System
In a2009 study (6), the Transparency TCs were found to be empty, based on attempts to obtain
samples followed by taking boroscope pictures that verified the TCs were empty. The
Transparency TCs will be processed using one nitric acid rinse followed by three water rinses.
The Transparency TCs will be filled with approximately 110 gallons of 3 M nitric acid and
rotated for a minimum of 60 minutes. The acid will then be drained and transfened to LCS-
TANK-8516, where it is analyzed for Lewisite and treated with nitric acid if necessary to lower
the Lewisite concentration below the WCL. After the Lewisite concentration has been lowered
to < WCL, the nitric acid solution is shipped off-site to a deep well injection facility.
After the TCs are rinsed with nitric acid, they will then be filled with approximately 110 gallons
of water and rotated for a minimum of 60 minutes. The rinse will be drained to the SDS-TANK-
8523. This rinse process will be conducted a total of three times, and a sample will be collected
from the final water rinse which is analyzed for Lewisite concentration. If the Lewisite
concentration is less than the WCL, the TC is stored until it can be opened and examined for
solids before being shipped to an off-site Subtitle C TSDF. If the Lewisite concentration is
greater than the WCL, the nitric acid and water rinses are continued until the Lewisite
concentration in the last water rinse is < the WCL. The water rinses are transferred to the SDS-
TANK-8523 and treated in the SCC.
2.6 DESCRIPTION OF THE WASTE FEED SYSTEMS
Three types of waste materials are fed to the ATLIC: Agent GA or Lewisite are fed to the PCC,
and spent decon is fed to the SCC.
2.6.1 PCC Feed System
Pumps will be used to remove the surrogate mixture, Agent GA, or Lewisite from the TCs in the
gloveboxes. The feed pump is a positive displacement rotary gear pump with variable speed
controls. The pump is mounted to a single skid that can be started at any time by the operator.
In the case of the surrogate mixture and Agent GA, the pump will direct the material to the PCC,
while the Lewisite is sent to LCS-TANK-85l1. All waste feed pumps are located in the TOX.
Waste feed from the pumps will be routed through a series of control valves and instruments to
the waste injection nozzle on the PCC. The waste injection nozzle is purged with compressed air
and water following completion of waste feed. The compressed air and water for purge of the
waste feed nozzle is located on the control valve and instrument piping skid and are not
connected to any outside supply. The control valve and instrument piping skid is located in.the
ATLIC room.
ATLIC STB Plan - Rev. I
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TOCDF 20
Duplex basket strainers will be provided at the inlet of each set of feed pumps. The strainers will
remove any debris from the supply fluid that may cause damage to the supply pumps. A
differential pressure sensor monitored by the Control Center will indicate strainer plugging. The
duplex design of the strainers allows online switching from one basket to a clean one, making the
off-line basket available for cleaning or change-out without intemrption of processing. The
filters will be handled as directed by the WAP.
A control valve and instrumentation skid will be supplied for field installation between the
discharge of the waste feed pumps and the inlet of the waste feednozzle. All waste feed piping
with control valves and instrumentation required for safe operation of the system will be supplied
on the control valve and instrumentation skid. A self-contained supply of compressed air to
purge the waste feednozzle will be supplied on the control valve and instrumentation skid.
2.6.2 SCC Feed System
Spent decon will be pumped via the SDS feed pumps to the two SCC spent decon/water supply
nozzles. The SDS feed pump is a positive displacement rotary gear pump mounted to a single
skid and sized to supply the required flow of spent decon to the spent deconlwater supply
nozzles. The SDS feed pumps are located in the TOX. A control valve in the discharge line of
the pumps regulates discharge pressure by circulating excess spent decon back to the supply.
Duplex basket strainers will be provided at the inlet of the feed pump. The strainers will remove
any debris from the supply fluid that may cause damage to the supply pump. A differential
pressure sensor monitored by the Control Center will indicate plugging of the strainers. The
duplex design of the strainers allows online switching from one basket to a clean one, making the
off-line basket available for cleaning or change-out without interruption of processing. The
filters will be handled as directed by the WAP.
SDS feed piping with control valves and instrumentation required for safe operation of the
system will be pre-assembled (control valve and instrumentation skid) and supplied for field
installation between the discharge of the SDS feed pump and the inlet of the spent decon/water
injection nozzles. The pre-assembled control valve and instrumentation skid will have a supply
connection for process water. Process water will be supplied to the injection nozzles at all times
when the furnace is above 1,500 oF and spent decon is not being supplied.
2.7 HEATING, VENTILATION AND COOLING SYSTEM
The HVAC system has a vital role in the safe operation of the ATLIC. The purpose of the
HVAC system is to provide safe operating environments for personnel and equipment by
conditioning the air, capturing any volatilized agents and preventing their release by conveying
them to a filter system that will remove the agents from the air. The HVAC system will provide
two streams of conditioned air. One stream provides conditioned air to the igloo that houses the
glove box area, the two airlocks, and the TOX. The second stream provides conditioned air to
ATLIC STB Plan - Rev. 1
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2tTOCDF
o
the ATLIC room. The HVAC system is configured in a cascading fashion so that any captured
contamination flows from areas of less probability of contamination to areas of higher
probability of contamination. The two streams will utilize 100 % outside air with no circulation
air capability.
There will be two air handling units (AHUs) that will provide the air to the ATLIC room and
glove box area. The AHUs are both natural gas-fired and both rated at less than 5 million Btu/hr.
Because these sources are considered insignificant sources due to their size, they are not required
to be permitted individually [i.e. no Emission Point Numbers are associated with them].
From the glove boxes and the ATLIC room, the air will be routed from a common discharge duct
directly to the HVAC filter system. The filter system consists of three filter unitswith a
combined rating of 9,000 cfm. Two filters units will be online during normal operations, while
the third filter unit will be used as a spare. The air is drawn through the filters by an ID fan
downstream of the filters at the exhaust end of the filter assembly. Each filter unit will consist of
a particulate filter, a High Efficiency Particulate Air (HEPA) filter, three carbon adsorption
filters and a final HEPA filter. The exhaust air from the filters will be ducted to a 40-ft. filter
stack, which will discharge to the atmosphere. Agent monitoring is conducted on the HVAC
carbon filter exhaust stacks using ACAMS, and DAAMS for Agent GA; and MINICAMS@ and
DAAMS for Lewisite.
Each filter unit is equipped with differential pressure sensors to measure the pressure drop across
the filter banks. A change in the pressure differential between the inlet and outlet of a particulate
filter or HEPA filter bank is a good indicator of the condition of the filters, so the pressure
differential readings are monitored during operation of the filter unit to ensure that the banks are
not clogged and are functioning properly. Airflow through the filter system is controlled by
dampers within the ducts or by motor speed controllers on the filter fan motors.
An exhaust fan will be provided for each filtration unit and will be connected to a manifold
downstream of the filters. ln the event of loss of flow through an online filter, the back-up filter
unit will be started automatically, opening the inlet and discharge dampers simultaneously at the
start. When a filter change is required, the back-up filter will be brought online manually.
Instrumentation will be provided to monitor and control the airflow through the filter system.
Differential pressure or airflow gauges or alarms will be used to verify proper ventilation
conditions throughout the facility.
2.8 DESCRIPTION OF THE AUTOMATIC WASTE FEED CUTOFF SYSTEM
The primary function of the AWFCO system interlocks is to prevent feeding hazardous waste if
incineration conditions are outside the permit limits. The interlock system will automatically
stop the surrogate mixture and spent decon feed, and prevent restart until the incinerator is at
proper operating conditions and the interlock is manually reset. When an AWFCO is activated,
the process controller immediately increases natural gas feed to the PCC and switches from spent
ATLIC STB Plan - Rev. I
Decemb er 2, 2010
TOCDF 22
decon feed to process water in the SCC. This maintains PCC and SCC temperatures until all
wastes and waste residues exit the combustion chambers. Any residual agent in the ATLIC will
be completely combusted by the residual heat in the PCC and the SCC.
The AWFCO setpoints and the basis for their activation will be the same as required in the
established RCRA Permit and/or the HWC MACT Notifications of Compliance (NOC). Tables
specifying the process control instruments that will be interlocked with the AWFCO system and
their setpoints can be found in Appendix D. The DAQ and DSHW will be notified seven days in
advance of the first AWFCO test before the surrogate mixture is burned in the system. The
AWFCO system will be tested at a frequency specified in Attachment 6 to the RCRA Permit. A
discussion of the ATLIC AWFCO parameters follows.
PCC Exhaust Gas Temperature - The PCC gas temperature is monitored continuously at
the exit of the PCC by a thermocouple and temperature indicating transmitter 815-TIT-
8471. Surrogate and spent decon feeds are stopped if the exit gas temperature falls below
the low temperature setpoint on a HRA basis, or rises above the high temperature setpoint
on an instantaneous basis.
SCC Exhaust Gas Temperature - The temperature of the SCC exhaust gas is monitored
continuously in the crossover duct by a thermocouple and temperature indicating
transmitter 815-TIT-8571. This location is selected because the volume created by the
section of the crossover duct extending from the SCC is included in the overall
incinerator internal volume used to calculate residence time. Surrogate and spent decon
feeds are stopped if the exit gas temperature falls below the low temperature setpoint on a
HRA basis, or rises above the high temperature setpoint on an instantaneous basis.
Surrogate Feed Rate - The surrogate mixture is pumped from the storage TCs to the
PCC. The agent flow rate is continuously measured by a mass flow meter and flow
indicating transmitters that are in series, 807-FI-8430. The AWFCO setpoint used to stop
agent and spent decon feed is based on the HRA waste feed rate.
Spent Decon Feed Rate - Spent decon is pumped from an SDS-TANK-8523 to the SCC.
The spent decon flow rate to the SCC is measured continuously by a flow meter and flow
indicating transmitter 829-FIT-8521. The AWFCO setpoint used to stop spent decon and
agent feed is based on the HRA spent decon feed rate.
Agent Atomizing Air Pressure - A minimum air pressure is required to ensure complete
atomization of the agent as it enters the combustion chamber. The PCC atomizingair
pressure is measured continuouslyby 822-PSL-8410. Waste feeds to the ATLIC will be
stopped if the atomizingair pressure falls below the setpoint.
Spent Decon Atomizing Air Pressure - A minimum air pressure i." required to ensure
complete atomization of spent decon as it enters the SCC. This parameter is controlled
ATLIC STB Plan - Rev. I
December 2,2010
TOCDF 23
by use of pressure regulators and pressure switch 822-PSL-851 1. Agent and spent decon
feeds are stopped if the spent decon atomizing air pressure falls below the setpoint of the
pressure switch.
Water Flow to the Venturi Scrubber - The water flow to the venturi scrubber is
continuously monitored by flow sensor and flow indicating transmitter 819-FIT-8924.
Adequate water flow to the venturi scrubber is essential for proper scrubbing of the
exhaust gases. Waste feeds to the ATLIC are stopped if the measured value falls below
the setpoint on a HRA basis.
Venturi Scrubber Differential Pressure - The differential pressure across the venturi
scrubber is continuously monitored by pressure differential indicating transmitter
819-PDIT-8915. Waste feeds are stopped if the measured value falls below the setpoint
on an HRA basis.
Brine Flow Rate to Scrubber Towers - Brine is added to the top of the packed bed
scrubber by pumping fluid through distribution trays over the top of the pall rings. There
are three scrubber towers. The Brine flow rate to the packed bed scrubber sprays is
continuously monitored by flow sensor and flow indicating transmitter 819-FIT-8921
(Tower #1), 819-FIT-8922 (Tower #2),819-FlT-8923 (Tower #3). Waste feed is stopped
if the flow rate to the packed bed scrubber tower sprays falls below the setpoint on a
HRA basis.
Brine pH - The Brine pH is monitored continuously by pH probes and analyzer
indicating transmitters 819-AIT-8952A, B, and C to ensure the Brine remains under
control. One probe is active at a time and provides the input to the PLC. Waste feeds are
stopped if the measured value falls below the setpoint on a HRA basis.
Scrubber Tower Bed Differential Pressure - The pressure differential of the scrubber
towers are monitored continuously by 819-PDIT-8911 (Tower #1), 819-PDIT-8912
(Tower #2), and 819-PDIT-8913 (Tower #3). Waste feeds are stopped if the measured
value falls below the setpoint on an HRA basis.
Carbon Injection Feed - The feed rate of carbon to the baghouse will be monitored
continuously by 819-FIT-8933. Waste feeds are stopped if the measured value falls
below the setpoint on an HRA basis.
Baghouse Differential Pressure - The pressure differential across the baghouse is
monitored continuously by 819-PDIT-8936. Waste feeds are stopped if the measured
value falls below the setpoint on an HRA basis.
ATLIC STB Plan - Rev. 1
Decemb er 2,2010
TOCDF
Carbon Filter Differential Pressure - The pressure differential across the carbon filter is
monitored continuously by 819-PDIT-8941/8942. Waste feeds are stopped if the
measured value falls below the setpoint on an HRA basis.
Exhaust Gas Flow Rate - The exhaust gas flow is monitored continuously at the exit of
the PAS with an annubar flow meter and recorded by 819-FI-8932. Waste feeds are
stopped if the measured value falls below the setpoint on an HRA basis.
Blower Exhaust CO Concentration - The CO concentration is continuously measured at
the ID fan discharge by the CO CEMS and recorded by the FCS as 819-AIT-8302A18.
The CO AWFCO will stop waste feeds to the ATLIC if the HRA CO concentration
exceeds the permitted value corrected to 7 Yo 02, dry basis. The Oz correction factor will
be calculated using the following equation:
CO.: CO* x l4
(21 - Oz*)
the exhaust gas CO concentration corrected to 7 o/o Oz, dry basis
the measured exhaust gas CO concentration, dry basis
the measured exhaust gas Oz concentration, dry basis
where:
CO.
CO*
Oz^
Blower Exhaust Gas Oz Concentration - The Oz concentrations are monitored
continuously at the ID fan discharge by Oz CEMS recorded by the FCS as 819-AIT-8301.
If Oz concentrations fall below the minimum setpoint or rise above the maximum, waste
feeds to the ATLIC are stopped
ATLIC Stack Exhaust Gas Agent Concentration - Agent GA and Lewisite will not be
monitored during the STB and these AWFCOs will be activated after the STB is
completed. The agent concentrations in the exhaust gases at the stack are continuously
monitored. The operation of the ACAMS for Agent GA monitoring and the MINICAMS
in use during the LCPT will be controlled by Attachment22Ato the TOCDF RCRA
Permit (7). To monitor for Agent GA, would require three ACAMS (TEN 708 series)
with one in standby and the other two sequenced so one would be sampling while the
other is in the desorb and analysis mode. Lewisite will be monitored with three
MINICAMS (TEN 709 series) in a monitoring configuration similar to the Agent GA
ACAMS. Waste feed to the ATLIC is stopped if either of the online instruments
measures agent concentrations that exceed the setpoint.
The ATLIC control system is designed to minimize AWFCOs and ensure that the system is in
compliance. When an instrument fails, it usually will go out of range, which creates an alarm to
the process control system to alert the operator of the problem. The FCS monitors critical
functions and gives advanced warnings, using pre-alarms where possible, which indicates that an
alarm condition is developing. Advanced wamings give operators time to take corrective actions
before operations necessitate an AWFCO.
ATLIC STB Plan - Rev. I
December 2,Z0lA
TOCDF 25
The measurement devices that initiate AWFCOs are calibrated and maintained on a regular basis
as directed by TOCDF procedures. Most instruments are calibrated on a 180-day schedule. The
pH meters, 819-AIT-8952 (819-AIT-8917), are calibrated on a weekly basis. The CEMS are
checked on a daily basis and undergo an annual Performance Specification Test (PST).
2.9 EXHAUST GAS MONITORING EQUIPMENT
Exhaust gases from the ATLIC are monitored with CEMS on a continuous basis for CO, Oz, and
NO*. Agent monitoring systems located in the exhaust stack monitor for Agent GA or Lewisite,
but no agent monitoring will be part of the STB. For these parameters, the AWFCO will be
activated when the CEMS detect conditions beyond the setpoints. Outputs from these monitors
are sent to PLCs, which display the results in the Control Center, calculate rolling averages, and
archive the data for future reference.
A separate CEMS is used to monitor the exhaust gas concentrations of CO, Oz, and NO*. The
CEMS will meet all of the performance specifications detailed in 40 CFR 60, Appendix B,
"Performance Specifications" (8). Permanently installed CEMS probes will be located in the
ATLIC stack. The probes supply exhaust gas to the analyzers dedicated to monitoring the
ATLIC exhaust gas. The primary functions of the CEMS are to continuously measure, display,
and record the gas concentrations in the ATLIC stack. Output from the CEMS will activate
alarms and intemrpt waste feed when preset values are exceeded. The CEMS will remotely
display gas compositions and CEMS operational status. The ATLIC CEMS instrumentation is
located in a climate-controlled monitoring room, which is located next to the stack.'
The PLC stores data to provide remote data recording of CEMS operations at the Control Center.
All analog and digital input/output signals will be conditioned properly to reduce noise and
isolate signals from voltage transients. The control system displays and records the uncorrected
and rolling averages for the gas concentrations, which are updated at least every 15 seconds. The
PLC activates alarms and initiates an AWFCO when high CO or low 02 concentrations are
detected in the exhaust gas or when the control system experiences a loss of analyzer signal.
The exhaust gas sample enters the CEMS through a probe assembly located in the stack. The
sample is then drawn through a heated line to the sample conditioning system where it is
prepared for analysis in the analyzers.
2.9.1 Carbon Monoxide Monitors
Two CO analyzers will be used on the ATLIC and they are identified as 819-AIT-8302A/8.
They will be non-dispersive infrared (NDIR) analyzers as described in 40 CFR 60, Appendix A,
Method 10 (2). The analyzers are drift checked daily on two ranges according to the CEMS
Monitoring Plan, Attachment 20 (3) within the expected concentration ranges for the incinerator.
These drift checks include analyses of a zero gas and a span calibration gas. The CO monitor
O rocDF ATLIC STB Plan - Rev. I
Decemb er 2,2010
26
sends a reading to a PLC every 15 seconds. The readings are averaged over one minute by the
PLC. The PLC calculates an HRA from the one-minute averages. The averages are sent to the
FCS. The 40 CFR 60, Appendix B, Perfornance Specification 48 (8), is used to evaluate the
CO CEMS performance and determine if the CO CEMS meets the calibration drift requirements.
The CO CEMS initiates an AWFCO when the analyzer detects CO concentrations higher than
the setpoint. If the CO monitor fails, an AWFCO will be initiated.
The NDIR analyzers' specifications are:
Range: 0-200, 0-5000 ppm;
Accuracy: + 1 o/o of full scale;
Drift: ( 1 oh of full scale per week;
Reproducibility: 0.5 o/o of readirg; and
Response time: ( 60 seconds.
The CO CEMS is drift checked daily. Gases of 0 to 2Yo and 60 to 90 % of instrument span are
used to calibrate and drift check the CO analyzer. Calibration gases are injected into the
sampling system at the stack. Gases will be injected by opening the valve on each certified gas
standard cylinder to allow the reference gas to flow under pressure to the sample probe. The
reference gas is drawn through the sample transport, sample conditioning, and sample delivery
system and is analyzed in the same manner as an exhaust gas sample. Calibration results are
stored and printed through the FCS. The concentrations of the reference gases span the expected
concentrations of the exhaust gas. The span gas calibrations are considered a verification of the
quality of the CEMS data.
2.9.2 Oxygen Monitors
Two 02 analyzers will be used on the ATLIC and they are identified as 819-AIT-8301A/B.
They will be paramagnetic 02 analyzers. The analyzer is calibrated according to the CEMS
Monitoring Plan, Attachment 20 to the TOCDF RCRA Permit (3), using azero gas and span
calibration gases. The 40 CFR 60, Appendix B, Performance Specification 48 (8), is used to
evaluate the Oz CEMS.
The Oz analyzers' specifications are:
o
TOCDF
Range: 0-25 Volvmeo ;
Drift: Less than 0.5 oh ofspan;
ATLIC STB Plan - Rev. I
Decemb er 2,2010
27
Reproducibility: + 0.2% of measured value; and
Response time: ( 2 mtnutes.
The Oz CEMS are drift checked daily using a two-point method. Gases of 0 to 2 oh and 60 to
90 % of instrument span are used to drift check the Oz analyzers. Calibration gases a"re injected
into the sampling system at the exhaust stack. Gases will be injected by opening the valve on
each certified gas standard cylinder to allow the reference gas to flow under pressure to the
sample probe. The reference gas is drawn through the sample transport, sample conditioning,
and sample delivery system, and is analyzed in the same manner as an exhaust gas sample. Drift
check results are stored and printed through the FCS. The concentrations of the reference gases
span the expected exhaust gas concentrations. The span gas checks are considered a verification
of the quality of the CEMS data.
2.9.3 NO* Monitors
Two NO, analyzerswill be used on the ATLIC and they are identified as 819-AIT-8304A/B.
They will have a span of 0 to 1,000 ppmv. The analyzer is calibrated according to the CEMS
Monitoring Plan, Attachment 20 to the TOCDF RCRA Permit (3), using azero gas and span
calibration gases. The 40 CFR 60, Appendix B, Performance Specification 2 (8) is used to
evaluate these CEMS.
The NO* analyzers' specifications are:
o Range: 0 to 1,000 ppmv;
Accuracy: * 20 oh of Reference Material;
Drift: Less than 2.5 oh of span;
Reproducibility: + 0.2% of measured value; and
Response time: < 2 mrnutes.
The NO* CEMS are drift checked daily using a two-point method. Gases of 0 to 2 o/o and 60 to
90 % of instrument span are used to drift check the NO, analyzers. Calibration gases are injected
into the sampling system at the exhaust stack. Gases will be injected by opening the valve on
each certified gas standard cylinder to allow the reference gas to flow under pressure to the
sample probe. The reference gas is drawn through the sample transport, sample conditioning,
and sample delivery system, and is analyzed in the same manner as an exhaust gas sample. Drift
check results are stored and printed through the FCS. The concentrations of the reference gases
ATLIC STB Plan - Rev. I
Decemb er 2, 2010
TOCDF 28
o
span the expected exhaust gas concentrations.
of the quality of the CEMS data.
2.9.4 Agent Monitoring Systems
The span gas checks are considered a verification
The use of the ACAMS, DAAMS, and/or MINICAMS to monitor exhaust gas for the chemical
agents and the associated alarm setpoints will provide the ATLIC with the ability to demonstrate
a continuous near-real time monitoring for the agent being treated. Agent monitoring will not be
part of the shakedown and STB since the surrogate mixture will be used for this part of the
project. These monitoring systems will be placed in use when the system begins to handle agent
after the ATLIC STB.
The Agent GA and Lewisite monitors will be operated in accordance with Attachment 22Ato
the TOCDF Permit (7). Agent GA and Lewisite monitors will be equipped differently to provide
the most effective detection of the respective agent. Agent GA will be monitored using
ACAMS, a Near Real Time G\rRT) monitoring system, that provides a continuous record of
agent emissions. Agent GA will use DAAMS to confirm or deny the presence of agent. The
DAAMS is a time-integrated air sampler, also called a "composite air sampler."
The Lewisite monitoring methods utilize a deivatization step at the sample collection inlet
(distal end) to eliminate the problems associated with the instability of Lewisite during sampling
and analysis. Ethanedithiol (EDT) is added to the gas stream at the distil end of the sample
probe and allowed to react with Lewisite to form (2-chlorovinyl) arsonic acid which is volatile
and can be easily transported to the pre-concentration tube. The MINICAMS@ uses a gas
chromatograph (GC) with a halogen specific detector (XSOru; for the detection of Lewisite.
The Lewisite concentrations are confirmed using DAAMS tubes.
2.10 POLLUTION ABATEMENT SYSTEM
The PAS is designed to cool the exhaust gas exiting the ATLIC at approximately 2,000 oF to
approximately 185 oF at the Quench Tower exi! the gas is then cooled further by the packed bed
scrubbers. The PAS removes pollutants consisting of PM, acid gases, and metals from the
exhaust gas to below regulatory standards prior to being released to the atmosphere. Additional
filtration for mercury removal is also part of the PAS design. The PAS will be in operation at all
times that the LIC is operating, including startup and at idle with no waste in the furnace.
The PAS equipment consists of a quench tower, a packed bed scrubber, a Brine chiller, a high-
energy venturi scrubber, a moisture separator, an electric gas reheater, a PAC injection system, a
baghouse, a sulfur-impregnated carbon filter system, two induced draft fans in series, and an
exhaust stack. A description of each piece of equipment and their function in the PAS follows.
ATLIC STB Plan - Rev. 1
Decemb er 2,201 0
TOCDF
2.10.1 Quench Tower
The quench tower is a vertical cylindrical vessel containing two water spray nozzles and
equipped with a caustic wall wash system. The counter-flow quench tower is utilized to rapidly
cool the exhaust gases as they exit the SCC. The exhaust gases enter the quench tower and flow
down through the spray created by the upward-facing water spray nozzle. Evaporation of the
water cools the exhaust gas to approximately 185 oF, (i.e. saturation temperature). A process
water line supplies water to the quench spray nozzle. A flow control valve and flow controller
varies water flow to the quench nozzle to maintain quench outlet gas temperature to a setpoint of
approximately 185 oF. The quench walls are wetted for elimination of particulate buildup and
partial cooling of the vessel by addition of caustic around the top perimeter of the vessel.
Exhaust gas and excess liquid then exit the bottom of the quench tower, and the exhaust gas
flows to the inlet of the packed bed scrubber.
The quench tower has a second spray nozzlethat is connected to the emergency process water
supply system, which is activated if there is a loss of power. The emergency process water
supply system supplies water for cooling the exhaust gas entering the quench tower. If the
quench tower exhaust temperature ever reached 250 "F, a high-high temperature switch would
initiate a furnace shutdown in order to prevent downstream equipment damage due to high
temperatures.
2.10.2 Packed Bed Scrubber System/Brine Chiller System
Cooled and saturated exhaust gases exits the Quench Tower and enters the packed bed scrubber.
The packed bed scrubber system consists of three packed bed towers, an integral liquid sump, a
supply pump, a heat exchanger, and a scrubber liquor chiller system. The three packed towers
are vertical cylindrical vessels with a bed of packing and a scrubber liquor distribution system
that are connected in series so that the exhaust gas enters each vessel at the bottom and exits at
the top. The exhaust gas temperature is reduced through contact with the cooled liquid,
condensing moisture and absorbing acid gases. The packed towers utilize direct contact cooling
with the scrubber liquor to remove PM and acid gases. The scrubber liquor in the packed bed
scrubber train reacts with the acid gases present in the combustion exhaust gas stream. The pH is
controlled to > 7.0 using 18 Wt% NaOH solution. A baffle in the sump prevents the gas from
moving to other sections of the sump. The gas flows upward through the packed towers and is
brought in contact with the scrubber liquor. The packed towers provide a large surface area and
are structured to provide good contact between the exhaust gas and scrubber liquor. Acid gases
present react with the caustic in the scrubber liquor to form salts that dissolve in the scrubber
liquid. Other compounds that are water soluble are also removed from the exhaust gas. The
scrubber liquor exits the bottom of the packed towers and drains to the common sump.
Scrubber liquor is continuously drained from the common sump by the circulation pump. The
circulation pump moves scrubber liquor from the sump through an air-cooled liquid cooler and
chiller heat exchanger to the Brine injection nozzles located at the top of each packed tower. The
air-cooled exchanger is a packaged unit that cools the liquid by forcing ambient air over heat
ATLIC STB Plan - Rev. I
Decemb er 2,201 0
TOCDF 30
exchanger coils using a set of electrically-driven fans. The chiller heat exchanger is apackaged
unit that cools the liquid by circulating chilled liquid over heat exchanger coils. The coolers
operate continuously during operation of the LIC PAS. Cooling the scrubber liquor to the
packed bed vessels allows for removal of heat that is transferred to the liquid by contact with the
exhaust gas, thereby allowing for improved arsenic removal.
The pH in the sump is continuously monitored by three pH monitors and maintained within
normal operating values by the addition of 18 Yo NaOH solution. The pH meters send a signal to
the controller that varies caustic flow to the sump to maintain pH at the setpoint. To prevent the
uncontrolled addition of caustic to the scrubber sump if neither packed bed scrubber pump is
running, the caustic control valve is driven closed.
The liquid level within the scrubber sump is also continuously monitored and maintained within
normal operating levels. Depending on the level alarm, different controls will be initiated (i.e., a
furnace waste stop feed, a removal of scrubber liquid from the sump, or addition of water).
Process water is supplied to the scrubber liquor sump to make up for the water that is lost
through evaporation and blowdown. The blowdown will be taken off-site via tanker trucks.
Flow meters, flow controllers, and control valves maintain the scrubber liquor flow to the packed
towers at a constant rate. This rate is set by the operator to optimize the gas-to-liquid ratio for
better removal of the pollutants.
2.10,3 High-Energy Venturi Scrubber/Moisture Separator
The exhaust gas from the packed towers enters the venturi scrubber, where the scrubber uses a
high-energy design with a fixed throat to help accelerate the exhaust gas as it enters the throat of
the venturi. Water is atomized and injected into the accelerated exhaust gas through anozzle at
high pressure. The high-pressure atomization and extreme turbulence in the venturi throat
provides the conditions to remove small particulate at high efficiency rates. The exhaust gas
exits the venturi scrubber and enters the moisture separator.
The moisture separator is sized to slow the velocity of the gas, which allows the particulate-laden
fluid to separate from the gas stream and fall into the venturi sump. The exhaust gas flows
upward through a chevron-type entrainment separator located at the top of the separation
chamber to ensure against the loss of liquid droplets from the separator.
2.10.4 Exhaust Gas Electric Reheater
The combustion exhaust gas stream exits the venturi scrubber moisture separator saturated with
water vapor (100 % relative humidity) and enters the electric reheater where it is heated to a
temperature of at least 30 oF above the estimated dew point temperature of the exhaust gas
stream. The reheater consists of electric heating elements that extend into a section of the
exhaust duct between the exit moisture separator and the inlet of the baghouse. Thermocouples
in the exhaust duct downstream of the heating unit monitor the exhaust gas temperature and
ATLIC STB Plan - Rev. I
Decemb er 2,2010
31TOCDF
provide a signal to the heater control to maintain the outlet gas temperature at the setpoint. The
operating setpoint for the reheater temperature controller is set in the PLC by the operator. The
exhaust gas temperature is raised to ensure that the relative humidity of the exhaust gas is below
100 %. There is an alarm that will turn off and lock out the reheater while generating a stop
waste feed for the furnace if the exhaust gas temperature downstream of the reheater exceeds a
preset high temperature limit.
2.10.5 Powdered Activated Carbon Injection System
The exhaust gas continues to flow downstream of the reheater where it is injected with PAC
through anozzle for removal of mercury and trace organic compounds. The PAC injection
system consists of a storage unit, rotary feeders, a variable speed volumetric feeder, and a high
pressure transport blower/eductor. The feed system is located beneath the storage unit and is fed
into a feed hopper. A volumetric feeder, mounted on a weigh scale, meters the PAC to an
eductor while it is introduced into the transport air stream. The transport air is provided by a
high pressure transport blower.
The rate of PAC feed to the system is continuously calculated from the change in weight of the
feeder. The feed rate calculation is reset when a fill cycle of the feeder is initiated. The flow
sensor is located at the injection nozzle to verify that PAC is being fed to the system at all times.
2.10.6 PAS Baghouse
The PAC-injected exhaust gas flows directly into a baghouse comprised of a number of
vertically-mounted filter bags. The exhaust gas enters the baghouse and travels through the filter
bags, and exits from the baghouse. Particulate matter contained in the exhaust gas is removed as
it passes through the filters and remains on the outside of the filter bags. The filter bags are
cleaned sequentially with compressed air. The entire cleaning cycle is automatically initiated
based on the pressure differential or elapsed time. Particulate material dislodged from the filter
bags falls into a hopper below the bags. The baghouse hopper is sloped to a center discharge
equipped with a rotary airlock/feeder.
The PM is periodically removed from the baghouse hopper based on a signal from a level sensor
located in the hopper or a specified time interval. The baghouse discharge rotary airlock/feeder
starts from a control signal and runs for a specified period of time, discharging the collected PM
from the baghouse hopper. The PM discharged from the baghouse rotary feeder falls into a
containment bin that is periodically removed for landfill disposal according to permit
requirements. A flexible joint connects the baghouse discharge rotary feeder to the collection
bin for containment of the discharged particulate. The base of the baghouse is enclosed for
containment of any fugitive dust. The enclosure around the base of the baghouse is equipped
with accessible doors that allow the positioning of empty containment bins beneath the baghouse
discharge and removal of filled containment bins.
ATLIC STB Plan - Rev. 1
Decemb er 2,201 0
TOCDF 32
2.10.7 Carbon Filter System
The filtered combustion exhaust gas stream exits the baghouse and enters the carbon filter
system where trace organic vapors, PM, and mercury are removed from the exhaust gas. The
carbon system consists of two redundant filter beds where one bed is online during normal
operations and the second filter bed is used during emergency or maintenance operations. The
two filter units are six feet in diameter and are constructed from Type 316 stainless steel,
Each carbon filter bed consists of a pre-filter followed by a HEPA filter, an activated carbon bed
which is 12 inches thick,and a second HEPA filter. The differential pressure across the carbon
bed will be continuously monitored to detect filter plugging. The carbon is impregnated with
sulfur to remove mercury. The mercury removal efficiency of the carbon bed is approximately
99.99 %.
2.10.8 Induced Draft Fans
Two ID fans are associated with the PAS system and are sized to provide the motive force
required to move the exhaust gas stream through the complete PAS. The ID fans consist of two
single-stage fans in series with variable frequency drive (VFD) that modulates the speed of the
fan to control the speed and maintain furnace pressure at a slightly negative pressure. The ID
fans are provided with a variable-position damper located downstream of the fans. The fans
discharge to the exhaust stack. Agent GA and Lewisite will be monitored using ACAMS,
MINICAMS@ and DAAMS in the duct between the ID fans and the exhaust stack.
2.10.9 Exhaust Stack
The combustion exhaust gas stream exits the ID fan and enters the exhaust stack. The exhaust
stack is 40 feet in height and includes flanged ports installed 90" from each other around the
circumference of the exhaust stack for exhaust gas emission sampling and the CEMS equipment.
The exhaust gas emissions will be continuously monitored in the stack using a CEMS for the
presence of CO, Oz, and NOx.
2.11 CONSTRUCTION MATERIALS
The construction materials for the incinerator system components are listed in Table 2-1.
ATLIC STB Plan - Rev. I
Decemb er 2,2010
TOCDF 33
TABLE 2-I, ATLIC CONTRUCTION MATERIALS
2.12 LOCATION AND DESCRIPTION OF TEMPERATURE, PRESSURE, AND FLOW
INDICATING AND CONTROL DEVICES
This section provides a general description of the FCS, temperature, pressure, flow, and other
instrumentation necessary to ensure compliance with all permit conditions. A discussion of the
major controls of the ATLIC is also provided. The locations of the process control instruments
are shown on the drawings provided in Attachment 4 to the Permit Modification, which also
shows the instruments that are used to monitor plant operations and record data for the facility
operating record and the preparation of the STB report. A list of the alarm settings for key
process monitoring equipment is found in Appendix D.
ATLIC STB Plan - Rev. I
Decemb er 2,201 0
Primary Combustion Chamber SR90 Refractory-lined (aluminum silicate up to
52%; crystalline silica up to 52%) carbon steel
Combustion Air Blower Carbon steel
Secondary Combustion Chamber Ruby SR Refractory-lined (alumina up to 5 0oA,
amorphous silica up to 40%) carbon steel
Quench Tower [Jpper Section - AL6XN aluminum;
Lower Section - Type 3 l6 Stainless Steel
Packed Bed Scrubber Tower Type 316 Stainless Steel
Venturi Scrubber Type 316 Stainless Steel
Induced Draft Fan carbon steel housing
Packed Bed Scrubber Pump Type 316 Stainless Steel
Scrubber Blowdown Pump Type 316 Stainless Steel
Moisture Separator Type 316 Stainless Steel
Electric Re-Heater Type 316 Stainless Steel
Baghouse Type 316 Stainless Steel
Carbon Filter ljnit Type 316 Stainless Steel
Discharge Stack Fiberglass Reinforced Plastic
TOCDF 34
Control of equipment is provided through the FCS from the Control Center. All motors have a
Hand-Off-Auto or Local Off-Remote Hand Station and emergency stop (E-stop) pushbutton
located near the motor. Each hand station is connected to a motor controller that monitors motor
current, controls starting and stopping of the motor it is connected to, and relays all hand station
activity and motor status (including motor current) to the FCS. The ID fan has an E-stop as the
only local form of control and manual control is from the front panel of the VFD or through the
FCS.
The proper operation of this monitoring and control equipment is necessary to ensure consistent
compliance with all permit conditions and safe, efficient operation of the ATLIC. Although all
process monitoring instrumentation receives periodic maintenance, the equipment critical to
compliance with permit operating conditions receives additional attention. Key issues associated
with these instruments include:
Continuing and preventive maintenance;
Verification of instrument calibration; and
Verification of AWFCO integrity.
The preventive maintenance program is supported by information received from daily and
periodic inspections of the process equipment. Instrument calibration and preventive
maintenance are performed following the procedures and frequencies shown in Table 2-2. A
description of the most significant control loops follow.
2.12.L Facility Control System
The primary function of the FCS is to safely and efficiently monitor and control the process
systems, process support systems, and control systems that are located within the facility. The
FCS is composed of microprocessor-based electronic controllers with the primary function of
assisting operations personnel in the safe startup, monitoring; control, data logging, alarming,
and planned shutdown of the facility. Operation of the FCS will be conducted from the Control
Center located in proximity to the ATLIC.
The FCS is composed of manufacturer's standard hardware, systems software, and firmware that
will be configured to meet individual systems control requirements. The FCS system will
consist of hardware including operator and engineering workstations that provide data collection,
data storage, report generation, and programming capabilities. The FCS requires electric power
and an Unintemrptible Power Supply capable of sustaining the system should a substantial
primary power intemrption occur. A configurable, real-time and historical data collection
package will provide the functions of trending, logging, and reporting. The system will back up
historical data to removable media for long-term historical data storage. Data archiving will be
provided for all data types. There will be a primary and backup domain servers for the FCS
network in accordance with the specification(s) of the chosen equipment.
ATLIC STB Plan - Rev. I
Decemb er 2,2010
35TOCDF
TABLE 2-2. INSTRUMENT CALIBRATION FREQUENCY
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'ilg iii N.Uffi 6't: ... :,,, lll, :
iritr::::::::. . :.:::::l , ::,:::,: .:::::::.,:. ,,: ',,',,j.,'. : :::, ,,,,:,,,, ,.:::.:,, ,::::,
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1 8 15-FIT-8430 Agent Feed Rate 180
2 822-PSL-8410 Agent Atomizing Air Pressure 180
3 815-TIT-847 |Primary Chamber Temperafure 180
4 8 15-FIT-8521 Spent Decon Feed Rate 180
5 822-PSL-85 r l Spent Decon Atomizing Air Pressure 180
6 815-TIT-8571 Secondary Chamber Temperature 180
7 819-FrT-8932 Exhaust Gas Flow Rate 180
7a 819-Trr-8932 Exhaust Gas Temperature @ anrrubar 180
7b 819-PrT-8932 Exhaust Gas Pressure @ annubar 180
8 8 19-Pr-8982 Scrubber Delivery Pressure 180
9 819-FIT-8921 Brine Flow to Scrubber Tower #1 180
10 819-Frr-8922 Brine Flow to Scrubber Tower #2 180
11 819-FIT-8923 Brine Flow to Scrubber Tower #3 180
t2 819-PDIT-891 I Scrubb er #1 Pressure Drop 360
13 8 19-PDIT-8912 Scrubb er #2 Pressure Drop 360
t4 8 19-PDIT-8913 Scrubb er #3 Pressure Drop 360
15 819-FIT-8924 Brine to Venturi Scrubber Flow 180
t6 8 19-PDIT-891s Venturi Exhaust Gas Pressure Drop 360
t7 819-AIT-8952A
819-ArT-89s28
819-ArT-8952C
Scrubber Brine pH 7
18 819-Ar-8983 Brine Specific Gravity 180
r9 819-ArT-8917 A
819-AIT-89 T7B
8 19-ArT-89 t7 C
Venturi Sump pH 7
20 819-ArT-8927 Venturi Sump Specific Gravity 360
21 819-TrT-893 1 Baghouse Inlet Temperature 180
22 81g-PDIT-8936 Baghouse Pressure Drop 360
23 819-WI-8933 Carbon Injection Feed Weight 90
24 819-Frr-8934 Carbon Iniection Air Flow 180
25 81g-PDIT-894U
8942 Carbon Filter Pressure Drop 360
26 819-TrT-8939 Carbon Filter Inlet Temperature 180
27 819-Arr-83 02AlB Blower Exhaust CO Concentration Daily
28 8 19-AIT-8301A/B Blower Exhaust Gas Oz Low Daily
29a
2%
2%
30t
30b
30t
TEN 7O8AK
TEN 7O8BK
TEN 7O8CK
TEN 7O9AL
TEN 7O9BL
TEN 7O9CL
Stack Exhaust Agent GA
St..k E.hr*t Ag*t GA
S
St"*
Every 4 hr
Every 4 hr
Every 4 hr
Every 4 hr
Every 4 hr
Everv 4l'fi
ATLIC STB Plan - Rev. I
Decemb er 2,201 0
TOCDF 36
o The FCS has a centralized control console, including closed-circuit television monitors (for
observing operations at various locations), and locally mounted PLCs. Most processing and
sequencing operations are controlled automatically through the PLCs. Interlocks are provided to
prevent improper facility operation. These interlocks are monitored and continuous checking is
undertaken to determine any failure to complete a programmed step. The FCS logs abnormal
conditions, operator entries into the system, and starting and stopping of equipment with the time
of occurrence. The control system provides continuous automatic control of the incineration
process. In monitoring critical functions, the process control system gives advanced wamings
using pre-alarms where possible, indicating that an alarm condition is developing, which warns
operators in time to take corrective action.
The application software will control process functions, manipulate data, maintain configuration
control, do graphic displays, conduct alarm management, data logging, trending, report
generation, system diagnostics, and instrument maintenance management.
2.12.2 PCC Agent Feed Rate Control
The agent flow to the PCC feednozzle will be monitored constantly by means of mass flow
meter 807-FT-8430 on the agent feed lines. Their measurements are totaled by 807-FQI-8430
and the result compared to setpoint by 807-FIC 8430. The 807-FIC-8430 then drives a variable
speed motor for the agent pump 807-HX-8693 to the appropriate speed for the desired flow.
2.12.3 PCC Pressure Control
The differential pressure between the ATLIC furnace room and the PCC is monitored constantly
by means of pressure transmitter 815-PIT-8470 mounted near the top of the PCC. Pressure
controller 815-PIC-8470 sends a signal to 819-HS-8945 located on the motors of the ATLIC ID
fans. The 815-PIC-8470 then modulates the ID fan motors to maintain the PCC at least 0.5
inWC negative relative to the ATLIC furnace room. High-High PCC pressure switch 815-
PSHH-8470 actuates alarm switch 815-PAHH-8470. A continuous record of the PCC pressure is
maintained by the FCS through 815-PIC-8470.
2.12.4 PCC Exhaust Gas Temperature and Burner Controls
During normal operation, modulating the natural gas flow rate to the PCC burner provides
control of the PCC exhaust gas temperature. Temperature controller 815-TIC-8471controls the
PCC bumer gas rate by modulating control valve 818-FV-8443 to maintain PCC exhaust gas
temperature. The burner has a 10-to-1 tumdown ratio. A low-low PCC exhaust gas temperature
transmitter 815-TT-8471 actuates alarm 815-TALL-847I and an AWFCO if the PCC exhaust
temperature falls below the low temperature setpoint. High temperature is sensed by
815-TT-8471, andwill actuate an alarm and an AWFCO if the temperature rises above the high
temperature setpoint. A continuous record of the temperatures is maintained by the FCS.
37 ATLIC STB Plan - Rev. I
Decemb er 2,2010
TOCDF
2.12.5 SCC Exhaust Gas Temperature and Burner Control
The SCC temperature will be maintained by measuring the SCC exhaust gas temperature in the
duct exiting the SCC. The SCC exhaust gas temperature controller 815-TIC-8571 modulates the
process water valve and/or fuel gas valve depending on whether SDS or process water is being
used as a quenching medium in the SCC. Low-low temperature alarm 815-TALL-8571 and high
temperature alarm 815-TAH-8571 actuate alarms and AWFCOs if the SCC exhaust gas
temperature falls below the minimum temperature setpoint or rises above the maximum
temperature setpoint on an HRA basis.
Temperature control in the ATLIC SCC is accomplished in two ways. When not processing
spent decon, the chamber temperature is maintained by modulating the burner firing rate and the
amount of water cooling in the chamber. The burner firing rate is modulated down to the low-
fire limit, and the water spray is modulated open to quench the high-temperature exhaust gas
from the primary chamber. When the SCC is processing spent decon, the bumer firing rate is
modulated to maintain the temperature setpoint, and the spent decon feed rate is held constant.
2.12.6 SCC Spent Decon Waste Feed Control
The flow of spent decon to the SCC is monitored constantly by means of flow meter 829-FE-
8521 on the common spent decon/water spray line. After signal processing by 829-FIC-8521,
the spent decon feed rate is transmitted to the FCS to maintain a continuous record. Flow-
indicating controller 829-FIC-8521 also controls flow valve 829-FV-8521 to the SCC spray
nozzle. A high flow rate alarm 829-FAH-8521 will actuate an AWFCO if the feed rate exceeds
the setpoint on a HRA basis.
2.12.7 Quench Brine Flow
The Brine flow to the quench tower sprays is measnred by means of ma.gnetic flow mete.r
819-FE-8980. A flow controller valve varies water flow to the quench nozzle to maintain
quench outlet gas temperature at the setpoint.
2.12.8 Venturi Scrubber Water Flow
Water is sprayed radially and tangentially into the venturi scrubber. The water flow rate is
measured by the magnetic flow meter 819-FE-8924. Water flow data are provided to the FCS
for continuous process monitoring. Low-flow alarm 819-FAL-8924 acfiates an AWFCO if flow
falls below the setpoint on a HRA basis.
2.12.9 Brine pH
The Brine pH is monitored by means of three pH analyzers 819-AIT-8952A,89528, and8952C.
Indicating controller 819-AIC-8952 activates 819-HS-8907 to adjust the addition of caustic to
ATLIC STB Plan - Rev. 1
Decemb er 2, 2010
38TOCDF
maintain the desired pH and provides input to the FCS for continuous process monitoring. Low
pH alarm 819-PHL-8952 actuates an AWFCO if the pH falls below the setpoint on a HRA basis.
2.12.10 Venturi Scrubber Differential Pressure
Pressure indicator 819-PT-8915 measures the differential pressure across the venturi scrubber.
Indicating controller 819-PDI-8915 provides input to the FCS for process monitoring. The same
PDI provides high and low differential pressure alarms 819-PDAH-8915 and 819-PDAL-8915.
An AWFCO is initiated if the differential pressure falls below the setpoint on a HRA basis.
2.l2.ll Scrubber Tower Sump Level Control
The brine sump level is measured by level indicating transmitter 819-LIT-8951 . Indicating
controller 819-LIC-8951 provides input to the FCS for continuous level monitoring. The same
indicating controller provides high- and low-level alarms 819-LAH-8951 and 819-LAL-8951,
respectively. It also controls the level in the brine sump by opening solenoid valve
819-HV-8951 to adjust the quantity of process water added to the sump. If a low-low level is
detected, low-low level alarm 819-LALL-8951 will be activated. If a high-high level is detected,
alarm 819-LAHH-8951 will be activated. If either the low and low-low level alarms, or the high
and high-high level alarms are simultaneously activated, waste feed is stopped, and the PCC and
SCC bumers will automatically shutdown. Additionally, if 819-LAHH-8951 is activated, all
liquid inputs to the scrubber sump are isolated.
2.12.1,2 Baghouse Pressure Drop
Prior to entering the baghouse the exhaust stream is injected with carbon to remove Hg and trace
organic compounds. The exhaust gas enters the baghouse before the filter bags and travels
upward, passing through the filters and exits from the top of the baghouse. Differential pressure
indicating transmitter 819-PDIT-8936 senses the pressure drop, while providing continuous
pressure drop input to the FCS, and provides alarms when the pressure drop increases or
decreases to unacceptable values. An AWFCO is initiated if the differential pressure falls below
the setpoint on a HRA basis. The filter bags are cleaned sequentially with compressed air. The
entire cleaning cycle is automatically initiated based on pressure differential or elapsed time. To
control fugitive dust, the PM that dislodges from the filter bags falls into a slopped hopper below
the bags, which leads to a center disbharge to an enclosed containment bin.
2,12.13 Carbon Filter System Differential Pressure Control
The differential pressure across the carbon filter willbe continuously monitored using
819-PDT-8941 and 819-PDT-8942 to detect filter plugging. An AWFCO is initiated if the
differential pressure falls below the setpoint on a HRA basis.
ATLIC STB Plan - Rev. I
December 2,2010
TOCDF 39
2.12.14 ATLIC Exhaust Gas Oxygen Concentration
The ATLIC exhaust gas 02 concentrations are measured continuously by 02 analyzers
819-AIT-8301A/B. If the Oz concentration is below the preset low-low level setpoint, alarms
819-AAL-8301A/B are activated and a RCRA AWFCO is initiated. If the Oz concentrations axe
above the high-high level setpoint, alarms 819-AAH-8301A/B are activated and an AWFCO is
initiated.
2.12.15 ATLIC Exhaust Gas Carbon Monoxide Concentration
The ATLIC exhaust gas CO concentrations are measured continuously by CO analyzers
819-AIT-8302N8. These analyzers display results locally and provide continuous CO data to
PLCs. The PLCs calculate a one-minute average. The PLC also calculates a HRA corrected to
7 o/o Oz dry volume, which is compared to the emission standard of 100 ppmdv. If the CO
concentrations are above the limit, the alarms 819-AAH-8302N8 are activated and an AWFCO
is initiated. The averages are stored by the FCS.
2.12.16 ATLIC Exhaust Gas Flow Rate
Exhaust gas flow rates for the ATLIC are measured with annubar flow meter 819-FIT-8932. The
flow meter is installed in the exhaust duct located prior to the ID fan to measure the volumetric
flow rate. The annubar measures a differential pressure. The pressure difference is measured
and converted to a flow rate. The FCS records the value and generates an HRA. If the HRA
setpoint is exceeded, an AWFCO is initiated and audio and visual alarms are activated.
2.12.17 Uninterruptable Power Supply System
The Unintemrptible Power Supply (UPS) System, along with the generators, will provide back
up power and allow for automatic transfer to critical process equipment as well as health and life
safety systems (i.e. HVAC system). The generator backup distribution system will supply power
to the UPS system as well as essential power in the case of temporary loss of utility power.
2.13 INCINERATION SYSTEM STARTUP PROCEDURES
This section discusses the startup procedures as required by 40 CFR 270.62(b)(2)(vii). The
ATLIC is brought to full operating condition while firing natural gas before any hazardous
wastes are introduced into the PCC or SCC. Full operating condition means that combustion
temperatures are above the minimum for feeding waste, the ATLIC PAS is operational, the
ATLIC is under vacuum, and the unit is in compliance with all regulatory limits. The start-up
sequence is performed in reverse order of the direction that waste feed and combustion products
pass through the system; i.e., the PAS is started first, and the waste feed systems started last.
Before any of the ATLIC processing equipment can be started, all utilities and control systems
ATLIC STB Plan - Rev. I
Decemb er 2,201 0
TOCDF 40
must be operational. The typical time required for startup from a cold system is about 36 hours.
The DAQ and DSHW will be notified 7 days in advance of the AWFCO system test.
A summary of the ATLIC startup procedures is presented below.
2.13.1 Startup of the ATLIC Pollution Abatement System
The sequential steps for successful startup o(the ATLIC PAS are outlined below:
Perform the following steps, as applicable:
1. Check that the caustic valves are lined up to provide pH control.
2. Confirm that the scrubber tower sump levels are within acceptable limits.
3. Verify that the ACAMS or MINICAMS and DAAMS are on line.
4. Verify that agent concentration in the furnace room is less than the setpoint.
5. Verify that there are no fuel gas leaks in the LIC Room.
6. Start the Brine pump. Adjust flow rates, as necessary, and confirm the availability of the
spare pumps.
7. Start the venturi scrubber pump.
8. Start the exhaust blower.
2.13.2 Startup of the PCC/SCC
O
The sequential steps for successful startup of the SCC are outlined below:
1. Verify that all valve lineups have been completed.
2. Yerify that the secondary chamber spent decon/process water feed flow controller, secondary
chamber feed isolation valve, and secondary chamber atomizing air valve, are in their
correct positions per the furnace Standard Operating Procedure (SOP).
3. Start the combustion air blower.
4. lnitiate a fumace system purge
a. Primary and secondary combustion air valves go to high-fire position.
b. The system purge timer starts.
c. Primary and secondary combustion air valves go to low-fire position following
completion of purge.
5. The operator initiates the bumer light-off sequence.
NOTE: Both the primary and secondary burners will light at the same time. Both burners
will lock out and the system purge must be re-initiated if either burner fails to light. A
system purge is not required for a burner re-light if the primary chamber temperature is
above 11400 oF.
a. A11 fuel-gas valve and running interlocks are verified.
b. The primary and secondary burner igniters are energrzed.
ATLIC STB Plan - Rev. I
Decemb er 2,2010
4LTOCDF
c. The main gas control valves open.
d. The igniters are turned off ten seconds after the main gas control valves open.
e. The primary and secondary burner flame scanners sense flame presence and continue
to monitor the flame strength. The burners will be locked out if the flame strength
signal is not maintained and the primary chamber temperature is below 1400 "F.
f. The operator verifies primary and secondary burner light-off on the control screen from
the BMS.
6. lnitiate water flow to the secondary chamber when the temperature in the secondary chamber
exhaust duct reaches 1500"F.
2.13.3 Initiation of Primary Waste Feed
Waste feed to the primary chamber may be initiated by the operator if the furnace is at operating
temperature and all feed permissives have been met. The operator proceeds as follows to initiate
primary waste feed.
l. Verify that all waste feed permissives are met:
a. Primary chamber temperature is between 2,500 oF and 2,850 "F.
b. Secondary chamber temperature is between 1,800 "F and 2,200 "F.
c. TOX is normal.
d. ATLIC PAS is normal.
e. The primary waste holding tank is above low level.
f. Control system is operating within normal conditions.
g.No process alarms are active.
h. No stop feed conditions are active.
2. lnsert a setpoint into the primary combustion air flow controller for processing GA or
Lewisite. Verify that the combustion air flow increases to setpoint.
3. Allow primary chamber temperature to stabilize to the setpoint.
4. Set the primary waste feed flow rate for waste being processed (see section 1.2).
5. Open the primary waste holding tank discharge valve from the control screen.
6. Place feed mode in AUTO (primary waste feed pump starts).
7. lnitiate PRIMARY WASTE FEED from the control screen.
2.13.4 Initiation of Spent Decon Feed
Spent decon feed to the SCC may be initiated by the operator if the furnace is at operating
temperature and all feed permissives have been met. The operator initiates SDS feed by:
1. Verifing that all spent decon feed permissives are met:
a. Secondary chamber temperature is between 1,800 oF and 2,200 oF
.
b. ATLIC PAS is normal.
c. Open interlocks for SDS tank drain valve are satisfied.
ATLIC STB Plan - Rev. I
Decemb er 2, 201 0
TOCDF 42
d. Control system is operating within normal conditions.
e. There are no process alarms active.
f. No stop feed conditions are active.
2. Opening the SDS tank outlet valve.
3. Enabling the DECON FEED mode.
4. Placingthe DECON FEED mode to AUTO.
5. Verifing that the spent decon feed pump starts.
6. Verifing that the spent decon feed valve opens and the process water feed valve closes.
7. Setting the spent decon flow rate setpoint.
2.I4 F,MERGENCY/PLANNED SHUTDOWNS
The operator will be able to initiate an emergency shutdown of the ATLIC system by actuating
the E-stop button in the Control Center. The Control Center E-stop shuts down the PCC and
SCC burners, stops the combustion air blower, drives all valves to their safe position, stops
primary waste feed, and stops spent decon feed. The quench sprays and the ID fan will continue
operation.
There will also be an E-stop on the BMS panel in the case that an outside operator needs to
initiate an emergency shutdown. The BMS E-stop shuts down the PCC and SCC burners, stops
primary waste feed, stops SDS feed, and shuts down the fuel gas supply to the furnace.
In case of a planned shutdown, a Dowanol/air purge system will be used to clear all waste types
from the segment of the PCC waste feed piping and waste feednozzle. It is designed to protect
personnel in protective gear from exposure to waste feed materials when working on the feed
piping.
Water, followed by compressed air, will be introduced downstream of the last waste feed block
valve to flow through the feed piping to the primary waste feednozzle into the PCC. The system
will have a minimum capacity to purge three volumes of water and compressed air through the
feed piping andnozzle. The purge forces feed material remaining in the piping into the PCC
following a stop feed. The purge will be actuated prior to a planned furnace shutdown and while
the PCC is still at operating temperatures.
Plant air will be supplied to the waste feed line downstream of the second feed block valve. The
air purge will be used whenever primary waste feed is stopped. The flush will be independent of
the purge air line except for the common connection to the waste feed line.
43 ATLIC STB Plan - Rev. I
December 2,2010
TOCDF
3.0 SAMPLING AND ANALYSIS PROCEDURES
The sampling and analysis objectives for the ATLIC STB are to demonstrate:
Maximum hazardous waste feed rate while maintaining a DRE >99.9999 Yo for
chlorobenzene and tetrachloroethene.
Control of CO emissions by maintaining the CO concentration at < 100 ppm, @7 Yo 02,
on a HRA basis.
Control of PM emissions by showing that the concentration is < 0.0016 grldscf @7 o/o Oz
(MACT Limits).
That the metals emissions are in compliance with the MACT limits.
That the PCDD/PCDF emissions are < 0.20 ng2,3,7,8-TCDD TEQ/dscm @ 7 o/o Oz.
Control of NO, emissions on a HRA basis.
That the emissions of THC are < 10 ppmdv @7 % Oz on a HRA basis (monitored
continuously with a CEMS) and reported as propane.
That the halogen emissions (HCl and Cl2) are < 21 ppmdv @7 o/oC.2expressed as HCI
equivalents.
The VOCs emission rates.
The SVOCs emission rates.
The sampling and analysis procedures included in this section were selected to accomplish the
objectives discussed above. Detailed information on the sampling and analysis methods are
provided in the QAPP (Appendix A), and reference to the QAPP will be made to prevent
duplication of text. The rationale for the selection of the POHC is presented in Section 5.2. The
PCDDs/PCDFs data are being collected to demonstrate compliance with the MACT limits.
ATLIC STB Plan - Rev. 1
Decemb er 2, 2010
TOCDF 44
3.1 SAMPLING LOCATIONS
Samples collected for the ATLIC STB will be divided into exhaust gas samples, process sheam
samples, metal spiking samples, and surrogate mixture samples. The exhaust gas samples will
be collected after the ATLIC ID fan as detailed in Table 3-1. The parameters to be measured at
this location include CO, Oz, NO*, COz, THC, metals emissions, SVOCs, PCDDs/PCDFs, PM,
Clz, and HCl. The VOCs will be collected at a sampling port on the duct between the ID fan and
the exhaust stack. The exhaust gas sampling ports used for the sampling methods for the ATLIC
are shown in Drawing EG-22-D-8211inAttachment 4 to the Permit Modification.
The metals spiking solution will be sampled from a valve between the sample pump and the
mass flow meters used to measure the mass fed to the PCC. The surrogate mixture will be
sampled from a valve in the feed lines located between the glove boxes and the mass flow
meters.
The other process streams sampled as part of the ATLIC STB include phosphoric acid solution
and the scrubber liquor samples. A grab sample of phosphoric acid solution will be taken from a
valve on the holding container the acid will be fed from. The scrubber liquor and venturi
scrubber liquor samples will be taken via taps on the side of their PAS sumps.
3.2 SAMPLING METHODS
The samples for each run will be collected between the time the test starts and the time the test is
declared complete. The DAQ and DSHW representatives will be notified of times when process
samples will be collected,. when leak checks of sampling trains and pitot tubes will be conducted,
and when sample recovery begins.
Liquid process samples will be collected according to ASTM Method D3370 (9) bV attaching a
sample line to the tap and flushing the sample line. The resulting flush will be managed in
accordance with applicable EPA and DSHW regulations. According to this method, the sample
line is inserted into the sample container, and the tap is opened so that the sample fill time
exceeds one minute for VOCs. This sampling flow reduces the loss of VOCs from the sampling
container prior to closure of the container. The selected method ensures that the actual material
collected is representative of the stream. Separate sub-sample bottles are used for each sample.
Scrubber liquor samples will be collected during the final 60 minutes of each run.
Sample of the baghouse residue will be collected according to ASTM Method D5633 (10) from
the collection drum removed from the residue collection system after the run has ended. The
residue in the drum will have a representative sample collected and placed in separate sub-
sample bottles for each sample. One sample will be collected for each run with a field duplicate
sample collected during one run.
ATLIC STB Plan - Rev. I
Decemb er 2, 2010
TOCDF 45
. TABLE 3.1. ATLIC EXHAUST GAS SAMPLING SUMMARYU .:::
ATLIC STB Plan - Rev. I
Decemb er 2,201 0
Method 1 Traverse Points Each Port Report lnformation
Method2 Exhaust Gas Velocity Isokinetic Trains Report Information
Each Isokinetic
Train Exhaust Gas Moisture Isokinetic Trains Report Information
Method 0010 SVOCs
Environmental
Monitoring Ports in
ATLIC Exhaust Stack
Report Information
Metho d 00234 PCDDs and PCDFs
Environmental
Monitoring Ports in
ATLIC Exhaust Stack
Report Information
Method 003 1 VOCs
Sampling Port in the
Duct between the ID
fan and Exhaust Stack
Report lnformation
Metho d 51264'PM, HCl, and Clz
Environmental
Monitoring Porls in
ATLIC Exhaust Stack
Report Information
Metho d 29 HHRA Metals
Environmental
Monitoring Ports in
ATLIC Exhaust Stack
Report Information
CEMS C,2, CO, NO*
ATLIC Exhaust Duct
CEMS Port
AWFCOs & Report
Information
Orsat
Orsat analysis for
exhaust gas molecular
weight
Environmental
Monitoring Ports in
ATLIC Exhaust Stack
Report lnformation
TOCDF 46
Samples of the surrogate mixture will be collected from taps in the liquid delivery system. A
sampling tap will be placed in the line between the pump and the mass flow meter to allow
collection of a sample using ASTM Method D3370 (9). One sample will be collected at the
beginning of a run and another at the end of the run. Each sample will be analyzed separately.
The exhaust gas will be monitored as outlined in Table 3-1 using CEMS and selected EPA
methods sampling trains. Five EPA sampling trains will be used to collect the exhaust gas
samples: a Method 0031 sampling train will sample for VOCs, a Method 0010 sampling train
will sample for SVOCs, a Method 0023A sampling train will sample for PCDDs/PCDFs, a
Method 5126A sampling train will sample for PM and halogen emissions, and a Method29
sampling train will sample for metals. The four isokinetic sampling trains will all sample for 4
hours in the four sampling ports. Each train will spend 25 o/o of the time in each sampling port
and each train will change ports after sampling 60 minutes. (See Appendix A for more details.)
The ATLIC CEMS will collect data on the CO, 02, and NO* exhaust gas concentrations. (The
ATLIC CEMS are discussed in Section2.9.l through 2.9.3.) The Oz corrections will be made
with the ATLIC CEMS data. The THC concentrations will be monitored using a certified CEMS
supplied by the sampling subcontractor. Certification and calibration data for the sampling
subcontractor's CEMS will be available after the sampling subcontractor arrives onsite and set
up the instrumentation.
The exhaust gas molecular weight will be determined using 40 CFR 60, Appendix A, Method 3
using an Orsat system. The Method 3 samples will be collected using a sample line in one of the
sampling probes and fill an integrated bag over the sampling time.
The EPA methods for sampling the exhaust gas will be taken from SW-846 (1) and 40 CFR 60
(2). These methods are:
o A combination of Method 5 and Method 26A (2), which will collect samples for PM, Cl2,
and HCI emissions.
. Method 0031 (1), which will be used to collect VOC samples.
. Method 0010 (1), which will be used to collect SVOC samples.
e Method 0023A (1), which will be used to collect samples for PCDDs/ PCDFs.
o Method 29 sampling train (2), which will collect samples for metals emissions.
o The ATLIC CEMS (3) will sample for Oz, CO, and NO*.
. Method 3 (2), which will be used to determine the exhaust gas molecular weight using an
Orsat analysis by the sampling subcontractor.
ATLIC STB Plan - Rev. I
December 2,2010
TOCDF 47
o Method 25 (2), which will be used to determine the THC concentration using a CEMS
supplied by the sampling subcontractor.
3.3 ANALYSES METHODS
Summaries of these analysis methods are included in this section for completeness; detailed
descriptions of the analyses methods are located in the QAPP (Appendix A, Section 9).
The organic compormds in the surrogate mixture will be diluted in accordance with SW-846,
Method 3585, and analyzed using a gas chromatograph/mass spectrometer (GC/lvIS) as directed
by SW-846, Method 82608. Metals present in the metals spiking solution are analyzed by acid
digesting the sample by SW-846, Method 3051A, and then analyzingthe digested sample by
SW-846, Method 6020 andl470A. Appendix A lists the specific organic compounds and metals
tobe analyzed as well as the methods of analysis.
The process stream samples will be analyzed by the following methods:
o Method 82608 (1), which will be used to analyze samples for VOCs.
o Method 8270C (1), which will be used to analyze samples for SVOCs.
o Method 8290 (1), which will be used to determine PCDD/PCDF concentrations.
. Methods 6020 and7470A (1), which will determine metal concentrations.
Samples of the exhaust gas will be collected using five sampling trains and the TOCDF CEMS
and the sampling subcontractor CEMS. The collected samples will be analyzed using the
following methods:
o Method 5 (2) will be used to analyze PM.
o Method 9057 (1) will be used to measure halogen concentrations.
o Method 5041A (1) will be used to measure concentrations of VOCs.
o Method 8270C (1) will be used to measure concentrations of SVOCs.
o Method 0023N82g0 (1) will be used to determine concentrations of PCDDs/PCDFs.
. Methods 6020 and7470A (1) will be used to analyze metals emission samples.
ATLIC STB Plan - Rev. 1
Decemb er 2,2010
TOCDF 48
4.0 ATLIC SURROGATE TRIAL BURN SCHEDULE
The ATLIC STB is scheduled for the second quarter of 2011. The submittal of this plan will
serve as the official 60-day MACT notice required for CPT plans. The DAQ and DSHW will be
notified at least 30 days in advance of the actual STB date.
The STB will begin after TOCDF has: received approval of the ATLIC STB Plan; successfully
completed construction of the planU and successfully completed shakedown of the incinerator.
The ATLIC STB should span about 5 days: 1 day for setup, 3 days of testing, and I day for
cleanup. However, the ATLIC must achieve steady-state conditions by 2:00 p.m. on any test day
or the run will be cancelled for that day. The exhaust gas samples will be collected in four
isokinetic sampling trains and the Method 0031 sampling train. The isokinetic sampling trains
will sample for four hours, while the Method 0031 will collect four samples over the same time
period. The isokinetic samples will be collected in four sampling ports and each train will
sample for 60 minutes in each port.
The ATLIC STB will consist of one test condition with three replicate sampling runs. One run
per day is planned. Actual sampling time during each sampling run will last about 6 hours. The
ATLIC will be fed the surrogate solution at least 15 minutes before each sampling run to
establish steady operation at process test conditions. This, combined with the sampling trains
port changes, will cause total test time each day to be approximately 6 hours. Assuming minimal
intemrption of ATLIC operation during this STB, the incinerator is expected to operate for 6 or
more hours per day for 3 days.
ATLIC STB Plan - Rev. I
Decemb er 2,2010
TOCDF 49
5.0 ATLIC SURROGATE TRIAL BURN PROTOCOLS
The ATLIC STB will consist of three replicate runs performed at one set of operating conditions.
The surrogate mixture used for this STB will be spiked with metals to account for the maximum
metals concentrations in the Agent GA. The following subsections will discuss the waste to be
burned, the selection of the POHCs, the test operating conditions, waste feed rates, and total
waste to be processed.
5.1 WASTE CHARACTERIZATION
Two waste streams will be treated during the ATLIC STB: a surrogate niixture and a simulated
spent decon. The TOCDF does not produce or handle any liquids containing PCBs that would
be regulated under TSCA and does not treat any waste materials with dioxin waste codes (i.e.,
F020, F02 1, F022, F023, F026, or F027).
5.1.1 Surrogate Mixture Feed
The STB liquid waste stream fed to the PCC will be a mixture of chlorobenzene (POHC) and
tetrachloroethene (POHC) to establish a DRE for the POHCs. Chlorobenzene is present in the
Agent GA in storage, which makes it the candidate for the POHC. The surrogate mixture will be
prepared by the spiking contractor and will involve mixing chlorobenzene and tetrachloroethene.
The mixture will be shipped to the ATLIC where it will be pumped into TCs. The TC will be
mixed, and then the mixture will be pumped directly to the PCC to simulate the feeding of Agent
GA. Arsenic, lead, and mercury will be spiked into the waste feed line to account for the metals
in the Agent GA. Table 5-1 summarizes the composition of the surrogate mixture.
The surrogate mixture will establish a worst case for the establishment of a DRE for
chlorobenzene and tetrachloroethene. The DRE calculations will be based on the analyses of the
surrogate mixture processed during the ATLIC STB. The metals spiked into the PCC will
demonstrate the worst case for the processing of metals in the Agent GA, while the worst case of
metals feed for Lewisite will be demonstrated in the LCPT.
A sample of the surrogate mixture used during this STB will be collected during the first hour of
the run and during the last hour of each run. The samples will be analyzed for chlorobenzene
and tetrachloroethene, The metals spiking solution will be sampled at the same frequency as a
separate stream and analyzed for HHRA metals.
ATLIC STB Plan - Rev. I
December 2,2010
TOCDF 50
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5.1.2 Spent Decontamination Solution Waste Feed
The spent decon fed during the STB will be 4.5 lb/h of chlorobenzene and a solution of
phosphoric acid to match the phosphorus feed rate for the processing of Agent GA at half of
demonstrated surrogate mixture feed rate. The concentration of the phosphoric acid solution will
be developed using the following calculations. The STB surrogate mixture will be fed at a rate
of 325Ib/hr, so the Agent GA feed rate would be limited to 50 oh of that rate or 162.5lb|fu.
Assuming that the Agent GA feed is all ethyl N,N-dimethyl phosphoroamidocyanidate, which is
19.l Wt% phosphorus, that would give a phosphorus feed rate of 31 .0 lb/tr. Phosphoric acid is
3l.6Wt% phosphorus; therefore, the phosphoric acid feed rate would be98.2lblhr. The ATLIC
will require 450 lb of water per hour to provide cooling to the SCC; therefore, the 450 lb of water
plus the 98.2 lb of phosphoric acid would give a spent decon feed rate of 548.2|blhr of a 17.9 %
phosphoric acid in water solution. The final feed rate to the SCC will be 550 lbihr (rounded up)
of the 18 % phosphoric acid plus the 4.5 lb of chlorobenzene to represent an organic load to the
SCC of 0.81 Yo orgamcs for a total feed to the SCC of 554.5 lb/hr.
5.2 PRINCIPAL ORGANIC HAZARDOUS CONSTITUENT SELECTION RATIONALE
The liquid surrogate mixture consists of a collection of organic compounds selected to represent
the processing of chemical agents in the ATLIC. Chlorobenzene and tetrachloroethene were
selected as the POHCs for the ATLIC STB based on their thermal stability and high ranking in
the EPA thermal stability ranking system guidance (5). Chlorobenzene is representative of the
Agent GA because it is present in the waste stream (see Table 1-1). The RCRA regulations
require the demonstration of a DRE that is >99.99oA, but the DRE requirement for the ATLIC
STB will be> 99.9999 %. The DRE will be calculated by summing the chlorobenzene added to
the PCC and the SCC as the "waste in", while the waste out will be determined by the Method
0031 sample analyses. The chlorobenzene concentration will average about 49 oh (see Table 5-
1) and the tetrachloroethene will averag e 5l Yo. The metals spiked into the surrogate mixture
will represent ppm concentrations.
The feed to the SCC will be a dilute solution of phosphoric acid to act as a surogate for the
phosphorus in the Agent GA and as a PM loading to the PAS. Chlorobenzene will be added to
the phosphoric acid being fed to the SCC and the chlorobenzene added will be included as a
POHC in the determination of a DRE for the ATLIC. The feeding of chlorobenzene to the SCC
will be a surrogate for the feeding of 4.5 lb/hr of organic compounds to the SCC. The use of
chlorobenzene as the POHC covers the HAPs fed to the SCC, because chlorobenzene is a Class 1
compound in EPA's thermal stability ranking system (5). The EPA guidance allows a Class 1
compound to act as a surrogate for the other Class 1 compounds and the other compounds with a
lower thermal stability. The use of chlorobenzene as the surrogate allows processing of HAPs
with lower thermal stability such as carbon tetrachloride, chloroform, 1,2-dichloroethane, and the
other possible compounds that could be present in the spent decon.
ATLIC STB Plan - Rev. 1
Decemb er 2,201 0
TOCDF 52
5.3 TEST PROTOCOL AND OPERATING CONDITIONS
The ATLIC STB will be conducted to demonstrate compliance with permit conditions and
regulatory limits.
5.3.1 Development of Worst-Case Criteria
The ATLIC STB will demonstrate the worst case for organic compounds incineration by
establishing a DRE for Class 1 compounds by the EPA thermal stability ranking system guidance
(5). The ATLIC STB will be conducted at one operating condition, which will demonstrate the
minimum temperatures in the PCC and SCC. The STB will use chlorobenzene in the surrogate
mixture feed material and chlorobenzene will be fed by itself to the SCC. Chlorobenzene was
chosen because it is a Class 1 compound in the EPA ranking system. The demonstration of a
DRE for a Class 1 compound allows other Class 1 compounds and any compounds ranked lower
to be incinerated without demonstrating a DRE for every compound; therefore, the
demonstration of a DRE for chlorobenzene establishes the worst case for both Agent GA and
Lewisite processing.
Chlorobenzene and tetrachloroethene were selected as the POHCs for the ATLIC STB based on
their thermal stability and high ranking in the EPA thermal stability ranking system guidance (5).
As a part of this test, a DRE will be measured for the POHCs, which will be fed at 325lbl}u- to
the PCC and chlorobenzene will be fed at 4.5lblhr to the SCC. The compounds in the surrogate
mixture are classified as HAPs by EPA and Table 5-1 summarizes the composition of the
surrogate mixture. Agent GA and Lewisite will not have a DRE measured since they are
estimated to rank as a Class 4 or 5 compounds (5). The surrogate mixture will be fed to the
ATLIC during the shakedown period and the STB, and the details for the surrogate mixture are
discussed in Sections 5.1.1.
The ATLIC STB will also demonstrate a worst case for metals that will support the processing of
Agent GA. The worst case for metals emissions for Lewisite will be established by the LCPT.
Metals will be spiked into the surrogate mixture in the feed line just before the waste feed nozzle
to provide the worst case for metals emissions. A solution containing arsenic, lead, and mercury
will be pumped from their storage container into the surrogate mixture in the waste feed line just
before the waste feednozzle in the PCC to cover the highest anticipated metals concentrations in
the Agent GA. The metals will be in a form that is miscible in the organic compounds to allow
the metals spike to be carried into the PCC.
The ATLIC STB will also demonstrate the worst case for PM loading to the ATLIC PAS that
will support the processing of Agent GA. The worst case for PM loading for processing
Lewisite will be demonstrated by the LCPT. The simulated spent decon will be an 18 o/o
phosphoric acid solution fed at 550 lb/hr. Chlorobenzene will also be spiked into the feed line to
the SCC at 4.5 lbtfu to demonstrate the processing of organic compounds in the SCC as a part of
the STB. Therefore, the total feed to the SCC will be 554.5Lb/fu.
ATLIC STB Plan - Rev. 1
Decemb er 2,201 0
TOCDF 53
5.3.2 ATLIC Surrogate Trial Burn Operating Conditions
Tables in Appendix D shows the target Group A operating parameters for the STB conditions.
Samples collected will support the data needs required for the RCRA Permit, the Title V air
permit, and the HWC MACT emission limits. Final STB values for these parameters may
change slightly based on operational experience gained during the shakedown period.
The ATLIC STB will be performed under the following operating conditions:
Maximum surrogate feed rate to the PCC of 325 lb/hr.
Arsenic and lead spiked into the surrogate mixture fed to the PCC to correspond to a
concentration of about 100 mglkg, while mercury will be spiked to correspond to a
concentration of about 50 mglkg.
Maximum spent decon feed rate to the SCC of 554.5 lb/hr.
Minimum PCC temperatures in the range of 2,500 oF to 2,850 oF.
Minimum SCC temperatures in the range of 1,800 oF to 2,200 "F.
Residence time through the PCC, SCC, and duct work to the quench tower > 3 sec as
described in Sections 2.1 and2.2.
Oz concentration will be maintained above 3 o/o.
CO concentration will be below 100 ppm @7 % Oz.
Pressure drop across the venturi will be > 30 inWC.
Normal quench tower and venturi scrubber process water flows.
Minimum Brine pH.
5.4 COMBUSTION TEMPERATURE RANGES
The anticipated PCC temperatures for this STB will be between 2,500 oF and 2,850 oF. These
temperatures are from the AWFCO tables located in Appendix D. Experience with the LICs
indicates that the temperatures vary within this temperature range. The SCC temperature will be
between 1,800 oF and2,200 "F, which are the AWFCO limits from the tables located in
Appendix D. Minimum temperature limits will be established by the ATLIC STB and maximum
temperatures are set by the manufacturer's Extreme Temperature Limit (ETL).
ATLIC STB Plan - Rev. I
December 2,2010
TOCDF 54
5.5 WASTE FEED RATES AND QUANTITIES OF WASTES TO BE BURNED
The surrogate mixture feed rates for the ATLIC STB will be up to 325lb/hr, and the simulated
spent decon feed will be up to 554.5 lb/hr. The feed materials will be surrogate mixture and a
simulated spent decon made up of 550 lb/hr of 18 % phosphoric acid and 4.5 lb/hr of
chlorobenzene. This STB will require the surrogate mixture and spent decon to be fed to the
ATLIC for a minimum of 18 hours. The quantity of surrogate mixture burned during the STB
will be about 6,417lb based on a feed rate of 3251,blfu. The quantity of phosphoric acid solution
processed during the STB will be about 10,861.5 lb based on a feed rate of 550 lb/hr. The
quantity of chlorobenzerLe processed during the STB will be about 89.1 lb based on a feed rate of
4.5lblhr. Allowing a25 percent safety factor, the consumption of test feed materials is expected
to be about 8,000 pounds of surrogate mixture, 13,600 pounds of phosphoric acid solution, and
120 lb of chlorobenzene. The anticipated usage rates are summarized in Table 5-2. Metals feed
rates will be determined by analyses of the metals spiking mixture samples.
The ATLIC will reach equilibrium at test conditions with surrogate and spent decon
supplemented by natural gas about 15 minutes before the start of each sampling run. A surplus
of surrogate mixture and spent decon will be on hand in case operational problems require a
longer testing period. The feed materials remaining after the STB may be processed through the
ATLIC.
TABLE 5-2. WASTE, FE,E,D REQUIREME,NTS
ATLIC STB Plan - Rev. I
Decemb er 2,2010
Activity
Surrogate Mixture
Required
(tb)
Phosphoric Acid
Solution Required
(lb)
Chlorobenzene
Required
(lb)
Ramp-up,
20 mrn 108 183 1.5
Steady-State
Operations, 15 min 81 t37 .5 1.2
Exhaust Gas
Sampling, 6 hr 1,950 3,3 00 27
Total per
Performance Run 2,139 3,620.5 29.7
Total for Three
Performance Runs 6,417 10,861 .5 89.1
TOCDF 55
5.6 EXHAUST GAS VELOCITY INDICATOR
Exhaust gas flow rates for the ATLIC are measured with an annubar flow meter, installed in the
exhaust duct before the ID fan. The annubar is positioned in the center of the pipe to increase the
velocity of the exhaust flow, which creates a differential pressure. The pressure difference is
measured and converted to a scfm flow rate. The ATLIC control system records the value and
generates an HRA. If the HRA setpoint is exceeded, the PLC causes a stop feed and an alarm.
A maximum exhaust gas velocity will be established by the ATLIC STB.
5.7 AUXILIARY FUEL
Natural gas will be used as required to maintain temperatures in both the PCC and SCC. Natural
gas is also used as pilot burner fuel for both the PCC and the SCC. The average composition of
ihe natural gas from August 2OlO, showed that the Higher Heating Value averaged I,047 Bfiilft3,
and the methane concentration averaged94.1 %.
5.8 WASTE FEED ASH CONTENT
Ash particles exiting the SCC will be collected by the wet scrubbers, baghouse, carbon filter
beds, or measured in the ATLIC stack. Ash generated during the ATLIC STB will potentially
come from the metals spiked into the surrogate mixture and the simulated spent decon. Ash
generated by the combustion of Agent GA will come from the combustion of organophosphorus
compounds to produce phosphorus pentoxide (PzOs), which will be PM and will be removed by
the ATLIC PAS. Based on the metals spiking concentrations, the metals spiked into the
surrogate mixture will contribute less than 0.1 lb/hr to the estimated ash feed rate. Based on the
phosphorus content in Agent GA, it was calculated that a feed rate of 162.5 lblhr of Agent GA
would produce an ash load of 71.03 lb/hr. To match this ash load to the PAS, the phosphoric
acid solution processed in the SCC during the STB would need to have 31.0 lb/h phosphorus.
The spent decon fed during the STB will be 4.5 lblhr of chlorobenzene and a solution of
phosphoric acid to match the phosphorus feed rate for the processing of Agent GA at half of
demonstrated surrogate mixture feed rate. The STB surrogate mixture will be fed at arate of 325
lb/hr, so the Agent GA feed rate would be limited to 50 % of that rate or 162.5lblfu. Assuming
that the Agent GA feed is all ethyl N,N-dimethyl phosphoroamidocyanidate, which is 19.1 Wt%
phosphorus, that would give a phosphorus feed rate of 31.0 lb/hr. Phosphoric acid is 31.6 Wto/o
phosphorus; therefore, the phosphoric acid feed rate would be 98.2lblhr. The ATLIC will
require 450 lb of water per hour to provide cooling to the SCC; therefore, the 450 lb of water
plus the 98.2lb of phosphoric acid would give a spent decon feed rate of 548.2Iblhr of a 17 .9 %
phosphoric acid in water solution. The final feed rate to the SCC will be 550 lblhr (rounded up)
of the 18 % phosphoric acid plus the 4.5 lb of chlorobenzene to represent an organic load to the
SCC of 0.81 o/o orgarics for a total feed to the SCC of 554.5 lb/hr.
ATLIC STB Plan - Rev. I
Decemb er 2,201 0
TOCDF s6
5.9 ORGANIC CHLORINE CONTENT OF THE WASTE FEED
The surrogate compounds contain organic chlorine and the organic chlorine feed rates for the
ATLIC STB are summarized in Table 5-1. The chlorine feed rate for an average composition of
the surrogate mixture is 191.5 lb/hr, which is higher than the chlorine feed rate when feeding
Lewisite at325lblhr (153.7 lb/hr). Any chlorine measured in the ATLIC exhaust stack will
probably be attributed to the combustion of the organic chlorine present in the feed.
Concentrations of HCI and Cl2 in the ATLIC emissions will be sampled using Method 26A(2)
andanalyzed by Method9057 (1). Details are given in the QAPP (Appendix A).
5.10 METALS FEED RATES
The metals fed to the ATLIC will be from the arsenic, lead, and mercury added to the surrogate
mixture. The arsenic and lead will be fed at rates equivalent to concentrations of 100 ppm, and
mercury will be fed at a rate equivalent to a concentration of 50 ppm in the surrogate mixture.
Table 5-3 shows the estimated metals feed rates and the estimated metals emission rates
associated with the STB. Arsenic and mercury feed rates will be established for the Lewisite in a
separate LCPT using Lewisite agent as the source of arsenic and mercury. The arsenic, lead, and
mercury concentrations for the surrogate mixture were set to exceed the concentrations in the
Agent GA TCs. Metals emissions will be sampled using Method29 (2). The sampling and
analysis details for metals emissions are given in the QAPP (Appendix A).
s.11 POLLUTTON CONTROL EQUIPMENT OPERATTONS
Operation of the pollution control equipment is provided in this section as required by 40 CFR
270.62(b)(2)(vi). The anticipated operating conditions of the ATLIC PAS for the ATLIC STB
are the same as standard operating conditions and are summarized in Appendix D. Fluctuations
in PAS temperatures, flow rates, pressures, pH, and density will occur during this STB. These
normal variations will be reported in the final ATLIC STB Report. Standard operating
conditions for the pollution control equipment are described in Section 2.10.
5.12 SHUTDOWN PROCEDURES
The shutdown procedures to be observed during the ATLIC STB are discussed in this section as
required by 40 CFR 270.62(b)(2)(vii). The AWFCOs for Group A are continuously monitored
and interlocked. Group C parameters, which are also monitored and interlocked, will be in
operation during this STB. In addition, the system's operation will be monitored closely by the
operators. If the operation of the system should deviate significantly from the desired range of
operation or become unsafe, the operators will manually shut off waste feeds to the system. The
AWFCO system and parameters for shutting down the waste feeds are described in Section 2.8.
ATLIC STB Plan - Rev. I
Decemb er 2, 2010
TOCDF 57
TABLE 5.3. ESTIMATED METALS FEED RATES AND EMISSION RATES
Notes:
The MACT Lirnit for Semi-Volatile Metals is the summation of Pb + Cd : l0 pg/dscm.
The MACT Limit for Low Volatility Metals is the summation of As + Be + Cr :23 pgldscm.
o The MREs were taken from the LIC HD ATB Data.
o Th" MRE was taken from Pilot Plant testing.
TLIC STB Metals Feed Rate.xls ATLIC STB Plan - Rev. I
Decemb er 2,2010
Total Metal
Feed Rate
Agent Feed Rate: 325 lb/hr
Exhaust Gas Flow Rate | 934 dscfm
Exhaust Gas O2 Conc.: 8.8 %
Arsenic Conc.: 100 ppm 0.033 lb/hr
Lead Conc.: 100 ppm 0.033 lb/hr
Nlercurr Conc.:0.0163 lb/hr
EXHAUST GAS CONCENTRATIONS MACT
Conc.
@7%02
(pg/dscm)
Conc.
@7"/" Oz
LIC HD ATB
MRE,
o/ a/o
4.50E-0999.99989Arsenic u
99.9960 1.648-07
2.0sF-07
Semi-Volatile Metals
Low-Volatility Metals
B Metals Feed Emissions 58
Sampling will be stopped if an AWFCO is activated during the ATLIC STB. Should the
AWFCO condition persist for 2 hours, the run will be aborted. A run will also be aborted if
more than three AWFCOs occur during one traverse of the four-hour sampling trains. If the
DAQ and DSHW representatives approve continuing a run after either of the abort conditions is
reached, the approval will be documented and included in the deviations discussions in the final
report.
It may be necessary to shut down the ATLIC and PAS completely in the event of a major
equipment or system failure. A shutdown of this type will be performed in strict accordance
with the facility's standard operating procedures. Shutdown will be the reverse of the startup
process and are discussed in Section 2.14.
Subsystems will be shut down in the following order:
1. ATLIC PCC and SCC
2. PAS
3. lJtilities
Sampling will be stopped if a power failure occurs during a run. Waste feeds to the system will
be stopped, but other operating parameters will be maintained to minimize emissions.
Combustion air will continue to be supplied as the ID fan spins down.
5.13 INCINERATOR PERFORMANCE
Incinerator performance is discussed in this section as required by 40 CFR 270.62(a). The
TOCDF believes that the conditions specified in Section 5.3 for the STB will be adequate to
meet the performance standards of 40 CFR 264.343 while firing the surrogate mixture and spent
decon because:
TOCDF experience with both LICs buming Agents GB, VX, and mustard under similar
operating conditions shows that the expected DRE will exceed 99.9999 %.
TOCDF experience with the LICs burning mustard under similar operating conditions
suggests that the HCI and PM emissions will be less than the respective performance
standards.
The ranges of operating conditions planned for this STB are within the design envelope
of the ATLIC and PAS.
The ATLIC and PAS are tightly controlled by PLCs and AWFCO systems whenever
hazardous waste is being fed to the ATLIC.
ATLIC STB Plan - Rev. I
December 2,2010
TOCDF 59
One test condition will be used to establish the operating envelope for the ATLIC. The
ATLIC is operated as steady-state, base-loaded incinerator, and the test condition will
demonstrate the minimum temperatures and the ETL will set the upper temperature .
limits. Combustion air flow and velocity fluctuates as necessary to maintain the proper
negative pressure in the furnace. The fluctuations in metals and chlorine feed rates
should be minor.
ATLIC STB Plan - Rev. I
Decemb er 2, 2010
TOCDF 60
6.0 ATLIC STB SHAKEDOWN PROCEDURTS
Once the approval of this STB plan is received from the appropriate regulatory agencies,
shakedown will commence as described in Section 6.2. During the shakedown period, the entire
system will be thoroughly tested to verify that it performs in a safe, consistent, and predictable
manner when processing the surrogate mixture.
Shakedown testing will proceed in accordance with the ATLIC STB Shakedown Plan (see
Appendix B). This shakedown plan defines all activities, methodologies, shakedown criteria,
and compliance actions associated with the testing of the system. As stated in the shakedown
plan, operating conditions will be maintained within the envelope of anticipated final operating
limits (defined in Appendix D) throughout the shakedown period. These limits on operating
conditions are based on good engineering practice, over 13 years ofexperience processing
Agents GB, VX, and mustard in the TOCDF LICs. Operating limits will comply with the
requirements of 40 CFR 270.62(a)(1). Proposed operating conditions are preliminary, and final
values will be confirmed or modified as shakedown progresses.
Hazardous wastes will not be fed to the system at any time unless the conditions discussed above
are satisfied. The flow of hazardous waste to the incinerator will be stopped if operating
conditions deviate from the established limits. The AWFCO system, described in Section 2.8,
will be in operation at all times during the incineration of hazardous wastes, and the settings
during shakedown will be those specified in Appendix D. Individual AWFCOs for those
parameters that may cause total incinerator shutdown (such as auxiliary fuel, burners, or ID fan)
may be bypassed momentarily during routine calibrations. Those calibrations that require the
AWFCOs to be bypassed will not be conducted when waste is in the fumace.
6.1 STARTUP PROCEDURES
The startup periods for the ATLIC will be heated until operating conditions have been reached.
Temperatures will be held at operating conditions to verify that all systems are operating
correctly. During this period, operation of the PAS and CEMS will be verified, and the AWFCO
system will be tested to verify that all AWFCOs are operational. The systems will then be
declared ready for operation, and the shakedown period will begin. The DAQ and DSHW will
be notified of the AWFCO test 7 days in advance.
ATLIC STB Plan - Rev. I
December 2,2010
TOCDF 61
6.2 ATLIC SHAKEDOWN
O rhe objectives of the shakedown are to:
Demonstrate that the ATLIC can safely destroy the surrogate mixture at325lb/hr.
Familiarize the operators with the operation of the ATLIC.
Verify that all systems function properly.
Verify that the agent feed ramp-up rate is suitable for the surrogate mixture.
Verify that the spent decon feed ramp-up rate is suitable for phosphoric acid solutions.
Evaluate the ATLIC operating conditions required for permit compliance.
Evaluate the impact on the SCC of simultaneously processing the surrogate mixture and
phosphoric acid.
The TOCDF will provide the DAQ and DSHW with notice before introducing the surrogate
mixture into the system. The surrogate mixture will be introduced into the ATLIC in accordance
with 40 CFR 264.3aa(c)(1) to bring the unit to a point of operational readiness for the STB. This
phase may take four to six weeks and consist of up to 720 hours of surrogate processing. If
TOCDF determines that more time is necessary to ensure operational readiness before the STB,
an extension of up to 720 additional hours of operating time will be requested and must be
approved by the DSHW Executive Secretary.
The shakedown period will involve a series of tests as described in the shakedown plan (see
Appendix B). The TOCDF may request final modifications to the ATLIC STB Plan based on
data obtained during the shakedown period. If such changes are necessary, they will be
coordinated with the DAQ and the DSHW.
6.3 POST ATLIC SURROGATE TRIAL BURN OPERATION
The interim period between completion of the ATLIC STB and receipt of final approval from
DSHW for full operating authority could be several months. During this time, TOCDF intends
to continue operating the ATLIC on a full-time basis, under all federal requirements per 40 CFR
264,266, and270. The ATLIC will not be operated until the preliminary data have been
approved by DSHW, then the ATLIC operation will be restarted using Agent GA. The TOCDF
expects the ATLIC to operate during this period within the operating envelope defined and
demonstrated by the STB, with the exceptions of the waste feed rates. The waste feed rates to
the PCC shall be limited to 50 oh of the average rates demonstrated during the STB until the
ATLIC STB Plan - Rev. I
Decemb er 2,2010
TOCDF 62
Agent GA has been destroyed. The waste feed rates to the SCC will be limited to a total organic
compound feed rate of 50 % of the demonstrated chlorobenzene feed rate. The ash feed rate to
the PCC and SCC will be limited to the demonstrated ash feed rate. The metals feed rates to the
PCC and SCC will be limited to 50 Yo of the STB demonstrated metals feed rate until the Agent
GA and spent decon are destroyed. After the Agent GA has been destroyed, the ATLIC will
begin operation using Lewisite in preparation for the Lewisite CPT.
The inspection plan will be followed of the ATLIC for fugitive emissions, leaks, and associated
equipment spills and for signs of tampering, per 40 CFR 264.347(b). All appropriate operating
records will be maintained for documentation of operations.
The AWFCO system and associated alarms, as described in Section 2.8, will function any time
hazardous waste is in the combustion zone of the incinerator. The AWFCOs will be tested
according to the established schedule. Test methods for the AWFCOs will be demonstrated
before the STB shakedown begins.
6.4 INCINERATOR PERFORMANCE
The TOCDF believes that the conditions specified in Section 6.3 for the startup, shakedown,
STB, and post-STB operation will be adequate to meet the performance standards of 40 CFR
264.343 while processing the surrogate mixture, Agent GA, and spent decon because:
TOCDF experience with the LICs burning Agents GB, VX, mustard, and spent decon
under similar operating conditions shows that the expected DRE will exceed 99.9999 %.
Experience at the TOCDF with the LICs burning mustard and spent decon under similar
operating conditions suggests that the HCI and Clz emissions will be <21ppm, and the
PM emissions concentrations will be less than 0.0016 grldscf. These estimated emissions
are within the performance standards.
TOCDF experience with incineration of Agents GB, VX, and mustard spiked with metals
resulted in metals emissions that did not threaten to human health or the environment.
The range of operating conditions planned for the shakedown and post-STB periods are
within the design envelope of the ATLIC and PAS (refer to the Appendix C MEBs).
The ATLIC and PAS will be tightly controlled by the PLCs, and the AWFCO systems
will be operational at all times during the shakedown and post-STB periods when
hazardous materials are being fed to the ATLIC.
In addition, meeting the performance standards of 40 CFR 264.3 43 and 63.1219 ensures
protection of human health and the environment.
ATLIC STB Plan - Rev. I
December 2,2010
TOCDF 63
7.0 ATLIC SURROGATE TRIAL BURN SUBSTITUTE SUBMISSIONS
This section is not applicable since an STB will be conducted.
ATLIC STB Plan - Rev. I
December 2,2010
TOCDF 64
8.0 ATLIC SURROGATE TRIAL BURI{ RESULTS
The results of the ATLIC STB will be submitted to DAQ and DSHW in the report format used in
prior ATB reports. The operating data will be summarized; the VOCs emissions, SVOCs
emissions, PM emissions, PCDD/PCDF emissions, and metals emissions will be reported; and
the supporting laboratory data and data verification will be submitted.
The TOCDF will submit the ATLIC STB Report within 90 days after completion of the test.
The report will be certified in accordance with the requirements of 40 CFR 270.62OX7-9). It
should be noted that all data will be submitted for all analyses conducted, including the data from
any failed runs.
ATLIC STB Plan - Rev. 1
Decemb er 2, 2010
TOCDF 6s
9.0 FINAL OPERATTNG PARAMETER LIMITS
9.1 ESTABLISHING LIQUID INCINERATOR OPERATING PARAMETERS
The ATLIC STB demonstration of DRE, waste feed rates, spent decon feed rates, metal
emissions, PM emissions, and halogen emissions will be used to establish the permit limits for
the ATLIC. The successful completion of this STB will establish the operating permit at the
levels discussed in this section.
The destruction of organic compounds is a function of time, temperature, and turbulence. The
combustion temperatures and gas velocities in the system demonstrate operating conditions that
ensure the destruction of organic compounds. The waste feed rates demonstrated during this
STB will present the maximum challenge for the PM loading to the ATLIC PAS while
processing Agent GA. The maximum challenge for PM loading for processing Lewisite will be
demonstrated during a separate LCPT. The pH of the scrubber liquor in the PAS will control the
emission of acid gases present in the exhaust gas.
The anticipated final operating conditions resulting from the ATLIC STB are summarized in
Appendix D. These tables were prepared following the hierarchy of process-control-related
performance parameters, as established by EPA guidance (5). Each anticipated ATLIC final
operating limitation is listed by process parameter, target value during the STB, and anticipated
manner by which the limit will be established. The process parameters presented in Appendix D
are broken down as follows:
Those parameters that will be monitored continuously and will be connected to an
AWFCO system. When these parameters are exceeded, contaminated waste feed must be
discontinued immediately. These parameters will be established based on demonstrated
operating conditions during the STB.
Those parameters that will not be monitored continuously. Compliance with these
parameters will be based on operating records to ensure that routine operation is within
the operational limits established by the STB.
Those parameters that will be set independent of trial-bum-demonstrated parameters.
Instead, these limits will be based on EPA guidance, equipment manufacturer's design
and operating specifications, operational safety considerations, and good engineering
practices. These parameters include parameters monitored both continuously and
periodically. Depending upon the particular parameter, it may or may not be an AWFCO
parameter.
ATLIC STB Plan - Rev. I
December 2,2010
TOCDF 66
9.2 CONTINUOUSLY MONITORED PARAMETERS
Establishment of permit limits for these parameters is discussed in the following paragraphs:
Maximum Hazardous Waste Feed Rates - Maximum waste feed rates and spent decon
feed rates will be continuously monitored. The ATLIC STB will be performed as close
to the maximum waste and spent decon feed rates as possible. The final, approved permit
limit for each waste feed stream will be the demonstrated feed rates that achieve a
minimum DRE of 99 .9999 %.
Minimum PCC Temperature - Minimum PCC temperature will be related to meeting the
DRE. The minimum PCC temperature will be demonstrated during the ATLIC STB,
provided that a DRE of at least 99.9999 o/o is demonstrated.
Minimum SCC Temperature - Minimum SCC temperature will be related to DRE and
metals emissions. The minimum SCC temperature will be demonstrated by the ATLIC
STB, provided that a DRE of at least 99.9999 o/o is demonstrated.
Maximum Exhaust Gas Velocity - Exhaust gas velocity (measured before the ID fan with
an annubar flow meter) will be related to DRE and gas treatment. Gas velocity in the
ATLIC Duct is an indicator of exhaust gas residence time in the ATLIC. The final
approved operating conditions will be determined from the ATLIC STB results.
Minimum Flow to the Venturi Scrubber - Minimum water flow rate to the venturi
scrubber will be related to metals emissions and PM emissions. The final approved
permit limit for minimum water flow to the venturi scrubber will be based on the ATLIC
STB results, provided the STB demonstrates acceptable metals emissions and PM
concentrations < 0.0016 grldscf.
Minimum Venturi Scrubber Differential Pressure - The minimum differential pressure
across the venturi scrubber will be related to metals and PM emissions. The final
approved permit limit for minimum venturi scrubber differential pressure to the venturi
scrubber will be determined during the ATLIC STB provided acceptable metals and PM
emissions are demonstrated.
Minimum Scrubber Liquor pH - The minimum scrubber liquor pH'will be related to acid
gas emissions. The minimum scrubber liquor pH will be determined based on the ATLIC
STB results, provided adequate acid gas control is demonstrated.
Minimum Scrubber Liquor Flow Rate - The minimum scrubber liquor flow rate to the
packed bed scrubbers will be related to acid gas and PM emissions. The minimum clean
liquor flow rate will be determined based on the ATLIC STB results, provided control of
acid gases and PM emissions are demonstrated.
ATLIC STB Plan - Rev. I
Decemb er 2,2010
.a
TOCDF 67
9.3 OPERATING RECORD PARAMETERS
Establishment of these parameter limits based on the ATLIC STB is discussed below:
POHC DRE - A DRE of 99.9999 Yo or greater for chlorobenzene and tetrachloroethene
will be demonstrated by the STB. This DRE demonstration will allow TOCDF to
process the Agent GA and Lewisite contained in the TCs stored at DCD.
Maximum Metals Feed Limits - Metals feed limits will be set by the metals feed rates
demonstrated during the ATLIC STB for the processing of Agent GA. The metals feed
rates for Lewisite will be established during the Lewisite CPT. The TOCDF expects to
meet the permit limits while processing the surrogate mixture at325lblhr and spent
decon at 554.5lbllv.
Maximum PM Emissions - The PM emissions will be measured during the ATLIC STB.
The STB will be considered an acceptable PM test for Agent GA and spent decon,
because the surrogate spent decon will provide the ash loading to the PAS and provided
that the PM concentration is < 0.0016 grldscf corrected to 7 oh Oz.
Maximum Emissions of Chlorine and Hydrogen Chloride - The expected permit
condition for this parameter is 21 ppm, as required under the MACT limits.
Maximum PCDD/PCDF Emissions - The expected permit condition for these parameters
will be 0.2 ng/dscm of 2,3,7,8-TCDD TEQ corrected to 7 %o Oz.
9.4 INDEPENDENT OPERATING PARAMETERS
Establishment of these parameters are discussed in the following paragraphs:
CEMS Operation - CEMS operation will be a Group C parameter to comply with EPA
guidance that CEMS must be operational when the ATLIC is processirig wastes. A loss
of instrument signal from the CO monitor or Oz monitor will result in an AWFCO.
Maximum PCC Temperature - Maximum PCC temperature will be based on the
manufacturer's recommendations of an ETL.
Maximum SCC Temperature - Maximum SCC temperature will be based on the
manufacturer's recommendations of an ETL.
ATLIC STB Plan - Rev. I
Decemb er 2,201 0
TOCDF 68
Maximum Quench Tower Exhaust Gas Temperature - Quench tower exhaust gas
temperature will be based on the manufacturer's recommendations. The maximum
temperature limit proposed will be 250 "F to protect temperature-sensitive construction
materials in the remainder of the PAS. When the quench tower duct exit temperature
exceeds the maximum limit, all waste feeds are stopped.
Minimum Brine Pressure - The -iri*u* Brine pump pressure will be related to acid gas
and PM emissions. The final approved permit limit for minimum Brine pump pressure
will be 25 psig, provided the ATLIC STB demonstrates control of acid gases and PM
emissions.
Maximum CO Concentration at the Blower Exhaust - Maximum CO concentration at the
blower exhaust will be related to PIC control. The performance standard for CO is an
HRA of 100 ppmdv corrected to 7 Yo 02, provided the THC average concentration for the
STB is below 10 ppm and the POHC DRE are satisfactory. Waste feeds will not be
resumed until the HRA concentration falls below the 100-ppmdv corrected to 7 Yo Oz
HRA limit.
Minimum and Maximum Oxygen Concentration at the Blower Exhaust - Oxygen
concentration in the blower exhaust will be related to oxidative operating conditions to
treat the waste feeds. The oxygen levels in the combustion system will be controlled to a
concentration between 3 and 15 oh Oz at the lower exhaust. The final approved permit
limit for minimum and maximum oxygen at the stack will remain 3 oh and 15 o/o,
respectively, provided the POHC DRE are satisfactory.
Minimum Agent Feed Nozzle Pressure at High Feed Rate - Sound operating practice
dictates that the environment be protected against massive agent leaks. Were a major
leak to occur in agent feed piping, an AWFCO immediately stops all feed.
Minimum Agent Atomizing Air Pressure - The lower limit on air pressure to the agent
spray nozzle is 35 psig.
Minimum Spent Decon Atomizing Air Pressure - The lower limit on the air pressure to
the SCC spray nozzle is 35 psig.
ATLIC STB Plan - Rev. I
December 2,2010
TOCDF 69
1O.O REFERENCES
(1) Test Methods for Evaluating Solid Vl/aste, Physicat/Chemical Methods,3rd Edition,
including Update IV, USEPA, SW-846, February 2007.
(2) Title 40, Code of Federal Regulations, Part 60, Appendix A, "Test Methods."
(3) Attachment 20 to the TOCDF RCRA Permit, CEMS Monitoring Plan, EG&G Defense
Materials, Inc., CDRL-06.
(4) Hazardous Waste Combustion Unit Permitting Manual, Componenl l, "How to
Review A Trial Burn Plan," U.S. EPA Region 6, Center for Combustion Science and
Engineering, 1998.
(5) Guidance on Setting Permit Conditions and Reporting Trial Barn Results,EPN625l6-
891019, January 1989.
(6) Final Reportfor Ton Container Sample Analysis, T.A. Malloy, K. Whittington, B.
Fahey, B. Goodwin,Hazardous Materials Research Center, Battelle, Columbus, Ohio,
October 2,2009.
(7) Attachment22A to the TOCDF RCRA Permit, Agent Monitoring Plan, EG&G Defense
Materials, Inc., TOCDF CDRL 23.
(8) Title 40, Code of Federal Regulations, Part 60, Appendix B, "Performance
Specifications."
(9) ASTM D 3370,1995 (Reapproved 1999), "Standard Practices for Sampling Water from
Closed Conduits," ASTM International, West Conshohocken, Pennsylvania.
(10) ASTM D 5633 ,2004, (Reapproved 2008), "Standard Practices for Sampling with a
Scoop," ASTM International, West Conshohocken, Pennsylvania.
ATLIC STB Plan - Rev. 1
December 2,2010
TOCDF 70
rcrc
CD
F.
*
X
TOOELE CHEMICAL AGENT DISPOSAL
FACILITY (TOCDF)
SURROGATE TRTAL BURI{ PLAN
FORTHE
AREA 10 LIQUID INCINERATOR
APPENDIXA
QUALITY ASSURANCE, PROJE,CT PLAN
Revision I
December 21 2010
i
APPENDIXA
QUALITY ASSURANCE PROJECT PLAN
TOOELE CHEMICAL AGENT DISPOSAL FACILITY
Facility EPA ID Number:urs210090002
Prepared for: Tooele Chemical Agent Disposal Facility
11600 Stark Road
Tooele, UT 84074
Revision No.:
Date:December 2r 2010
IOCDF ATLIC STB
Section No.: I .0
Revision No.: I
Revision Date: Decemb er 2,2010
Page No.: I
1.0 TITLE PAGE
1.1 Project Title:
SURROGATE TRI,AL BURN FOR THE
AREA 10 LIQUID INCINERATOR
QUALITY ASSURANCE PROJECT PLAN
1.2 Expected Surrogate Trial Burn Date: July 2011
1.3 Project Approvals:
Thaddeus Ryba, CMA Project Manager Date
Gary McCloskey,
EG&G DMI General Manager
Craig M. Young, Ph.f).,
EG&G DMI, Project Specialist
Subcontractor, Quality Assurance Director
Date
Date
Date
TOCDF ATLIC STB
Section No.: 2.0
Revision No.: I
Revision Date: December 2,2010
Page No.: I
2.0 TABLE OF CONTENTS
1.0 TITLE PAGE ..........1-1
2.0 TABLE OF CONTENTS............... ............2-l
LIST OF ACRONYMNS AND ABBREVIATIONS.. ...,..2-6
LIST OFUNITS AND MEASUREMENTS........... ..........2-8
3.0 PROJECT DESCRIPTION .....3.1
4.0 PROJECT ORGANIZATION............... ....4-l
4.2 CONTRACTADMINISTRATIVEREPRESENTATIVE.............. .....................4-1
4.3 TOCDF LABORATORY MANAGER................ ......4-3
4.4 SUBCONTRACTORPROGRAMMANAGER. .......4-3
4.5 SAMPLTNG SUBCONTRACTOR QUALTTY ASSURANCE OFFICER..... ......4-3
4.6 SAMPLINGTEAM COORDINATOR............. ..,......4-4
4.7 SUBCONTRACTOR SAMPLING TEAM MEMBERS. ,..,..,.........4-4
4.8 SUBCONTRACT LABORATORrES............ ............4-5
s.0 QUALITY ASSURANCE AND QUALITY CONTROL OBJECTTVES ................."... s-l
5.I EVALUATIONOFPRECISION ..........5-2
5.2 EVALUATIONOFACCURACY .........5-2
5.3 EVALUATION OF COMPLETENESS.............. .......5-3
5.4 DETECTION AND REPORTING LIMITS........ .......5-4
5.5 REPRESENTATIVENESSAND COMPARABILITY ..................5-4
6.0 SAMPLING AND MONITORING PROCEDURES ......... .........6.1
6.I PRE-SAMPLINGACTIVITIES ...........6-1
6.1.2 Sampling Equipment Calibration.. ................... 6-1
6.1.4 Sample Media Preparation ..........6-2
6.1,5 Additional Pre-Sampling Activities ..................6-3
6,2 FIELD QUALITY CONTROLACTIVITIES.. ..........6-3
TOCDF ATLIC STB
Section No.: 2.0
Revision No.: 1
Revision Date: December 2,2010
Page No.: 2
TABLE OF .CONTENTS (continued)
6.3 EXHAUSTGASSAMPLING. ..............6-5
6.3.1 Methotl003l for Volatile Organic Compounds ....................6-7
6.i.2 Method I to Determine Duct Traverse Sampling Points .....6-8
6.3.3 Method 2 to Determine Exhaust Gas Velocity and Volumetric Flow Rate.... ................ 6-8
6,3.4 Exhaust Gas Moisture Content.... .....................6-8
6.3.5 Combined Method 5/26Afor Particulate Matter and Hahogens.................... .....,...........6-8
6.3.6 Method 0010 for Semi-Yolatile Organic Compounds.. ......... 6-9
6.3.7 Methotl 0023Afor PCDDs/PCDFs...... ...........6-10
6.3.8 Methotl29 for Metds .................6-10
6,i,9 Continuous Emissions Monitoring .................6-1 I
6.4.1 Process Stream Sampling Locations.......... ..... 6-12
6.4.2 Tap Sampling Method.............. .......................6-14
6.4.3 Residue Sampling Method................ ..............6-14
6.5 PROCESS MONITORING EQUIPMENT.................. .................6-15
6.6 POST-SAMPLINGACTIVITIES.... ...6-15
7.0 SAMPLE HANDLING, TRACEABILITY, AND HOLDING TIMES .......7-l
7.I SAMPLEPRESERVATIONANDHOLDINGTIMES............ ......7-I
7.2.3 Chain-of-Custody Forms .............7-3
7.3 SAMPLE TRANSPORT TO THE LA8ORATORY................ ......,7-4
8.0 SPECIFIC CALTBRATTON PROCEDURES AND FREQUENCY..............................8-1
8.1 PROCESS MONITORING EQUIPMENT CALrBRATrON........... .,..,...............8-1
8.2 EXHAUST GAS SAMPLTNG EQUIPMENT.................. ,......,.......8-1
8.3 CALIBRATION OF CONTINUOUS EMISSIONMONiTORING SYSTEMS .......................8-2
9.0 ANALYTICAL OBJECTIVES AND PROCEDURES .......... .....9-1
9.I ANALYSIS METHODS FORPROCESS STREAM SAMPLES ........................9-4
9.1.3 Metals Analyses Methods....... ......9-4
9.1.4 Organic Compound Analysis Methods............... ...................9-5
9.1.5 Saruogate Mixture Chsracterization Methods .,..................... 9-8
9.2 ANALYSIS METHODS FOR EXHAUST GAS SAMPLES .......... 9-8
9.2.1 Analysis of SMVOC Tubes........... .....................9-8
9.2.4 Analysis of Methotl 0010 Samples for SVOCs ....................9-1 I
9.2.2 Analysis of Method 0023A Samples for PCDDs/PCDFs ...... ...................9-15
9.2,3 Analysis of Metals Emissrans.......... ................9-17
9.2.4 Analysis of Halogen Emissions.... ...................9-17
9.2.5 Particulate Matter Analysis.......... ...................9-17
IOCDF ATLIC STB
Section No.: 2.0
Revision No.: I
Revision Date: Decemb er 2, 2010
Page No.: 3
TABLE OF CONTENTS (continued)
10.0 spEcrFrc LABORATORY QUALTTY CONTROL CHECKS ...............................10-1
IO.2 LABORATORY CONTROL SAMPLES... ........... 1O-I
10.3 DUPLICATEANALYSES .............. ...................... l0-1
10.4 MATRIXSPIKESAMPLES... ,,,,,,..,,10-2
10.5 SURROGATE SPIKES....... .............. 10-2
11.0 DATA REPORTING, DATA REVIEW, AND DATA RIDUCTION.......................11-1
11.1.1 Analytical Datu Packages ....... I l-1
11.1.2 Analytical Data Format......... ...,.....,.............. l1-2
11.1.3 ATLIC STB Report.. .............. 11-2
11.2.2 ldentiJication und Treutment of Outliers.... ....................... l1-5
11.3.1 Field Data Reduction .................. ................. I 1-6
11.3.2 Laboratory Analysis Data Reduction................... ............. l1-6
11.3.3 Blank Cotected Dqta...........,...... ................ 11-6
1I.4 EXHAUSTGASSAMPLETRAINTOTALCALCULATIONS........... ,........11-7
11.4.1 Calculation of Chlorobenzene Emissions and DRE ........ I 1-7
12.0 ROUTINE MAINTENANCE PROCEDURES AND SCHEDULES.........................12-I
13.0 ASSESSMENT PROCEDURES FOR ACCURACY, PRECISION, AND
COMPLETENESS.. .....13-1
14.0 AUDIT PROCEDURES, CORRECTIVE ACTION AND QA REPORTING......... 14-1
14.1 PERFORMANCEAUDITS ..............14-l
14.3 CORRECTIVEACTTON ..................14-2
IOCDF ATLIC STB
Section No.: 2.0
Revision No.: I
Revision Date: Decemb er 2, 2010
Page No.: 4
ANNEXA.
ANNEX B.
ANNEX C.
LIST OF ANNEXES
QA/QC OBJECTTVES FOR ANALYTICAL METHODS
EXAMPLE DATAFORMS
RESIJMES OF KEY INDTVIDUALS
TOCDF ATLIC STB
Section No.: 2.0
Revision No.: 1
Revision Date: December 2,2010
Page No.: 5
LIST OF TABLES
A-6.1 EXHAUST GAS SAMPLING SUMMARY....,.......... .............6-6
A-6-2 PROCESS SAMPLES TO BE COLLECTED............ ............6-13
A-7.T SAMPLE PRESERVATION AND HOLDING TIMES ............... ...,,...,....7-2
A-9-1 ANALYTICAL METHODS....... ,,........9-2
A-9-2 NUMBER OF SAMPLES ............... .....9-3
A-9-3 TOTAL VOC TARGET ANALYTE LIST FOR PROCESS SAMPLES....................9-6
A-9-4 TOTAL SVOC TARGET ANALYTE LIST FOR PROCESS SAMPLES .......,.....,..,.9-7
A-9-5 VOLATILE ORGANIC COMPOUND TARGET ANALYTE LIST FOR
METHOD 5041A .............9-10
A-9-6 SEMI-VOLATILE ORGANIC COMPOI.IND TARGET ANALYTE LIST ..........,.9-12
A-9-7 PCDD/PCDF TARGET ANALYTE LIST ........ ..9-16
A-9-8 METHOD 29 TARGET ANALYTE LIST ..........9-18
4-10.1 CALIBRATION PROCEDURES FOR ANALYTICAL METHODS .,... 1O-3
.A-11-1 CHLOROBENZENEEMISSIONSCALCULATIONDATA...... ...........11-7
LIST OF FIGURES
A-4-1 ATLrC STB ORGANZATTON CHART...................... ...........4-2
ACA
ASTM
ATB
ATLIC
AWFCO
CAL
CAR
CC
CCV
CEMS
CFR
CLP
COC
CPT
CVAAS
DAQ
DEQ
DCD
DFS
DI
DQO
DRE
DSHW
EG&G
EPA
ER
FCS
GC/MS
HHRA
HRGC/HRMS
HWC
IC
ICP/MS
ICV
TOCDF ATLIC STB
Section No.: 2.0
Revision No.: I
Revision Date: December 2,2010
Page No.: 6
LIST OF ACRONYMNS AND ABBREVIATIONS
Absolute Calibration Audit
ASTM International
Agent Trial Burn
Area 10 Liquid Incinerator
Automatic Waste Feed Cutoff
Chemical Assessment Laboratory
Contr act Admini strative Representative
Correlation Co effi cient
Continuing Calibration Verifi cation
Continuous Emission Monitoring System
Code of Federal Regulations
Contr act Laboratory Pro gram
Chain-of-Custody
Comprehensive P erforunance Test
Cold Vapor Atomic Absorption Spectroscopy
State of utah, Department of Environmental Quality, Division of
Air Quality
State of Utah, Department of Environmental Quality
Deseret Chemical Depot
Deactivation Furnace System
Deionrzed (as in deionized water)
Data Quality Objective
Destruction and Removal Efficiency
State of Utah, Department of Environmental Quality, Division of
Solid and Hazardous Waste
EG&G Defense Materials, Inc.
IJ.S. Environmental Protection Agency
Emission Rate
Facility Control System
Gas Chromatograph/Mass Spectrometer
Human Health Risk Assessment
High Resolution Gas Chrornatograph/High Resolution Mass
Spectrometer
Hazardous Waste Combustor
Ion Chromatograph
Inductively Coupled Plasma/Mass Spectrometer
Initial Calibration Verification
TOCDF ATLIC STB
Section No.: 2.0
Revision No.: I
Revision Date: December 2,2010
Page No.: 7
LIST OF ACRO|IYMS AND ABBREVIATIONS (continued)
LIC Liquid lncinerator
LCS Laboratory Control Sample
LOQ Limit of QuantitationMACT Maximum Achievable Conhol Technology
MDL Method Detection Limit
MPF Metal Parts Furnace
MS Matrix Spike
MSD Matrix Spike Duplicate
PCC Primary Combustion Chamber
PM Particulate Matter
POHC Principal Organic Hazardous Constituent
QA Quality Assurance
QAPP Quality Assurance Project Plan
QC Quality Control
%R Percent Recovery
RATA Relative Accuracy Test Audit
RCRA Resource Conservation and Recovery Act
RPD Relative Percent Difference
RRF Relative Response F-actor
RSD Relative Standard Deviation
SCC Secondary Combustion Chamber
SMVOC Sampling Method for Volatile Organic Compounds
SOP Standard Operating Procedure
Spent decon Spent Decontamination Solution
STB Surrogate Trial Burn
STC Sampling Team Coordinator
SVOC Semi-Volatile Organic Compounds
SW-846 Test Methods for Evaluating Solid Waste, 3rd Edition including
Update III, USEPA, SW-846, December 1996.
TEF Toxic Equivalency Factor
TE-LOP Tooele Laboratory Operating Procedure
TEQ Toxic Equivalent Concentration
THC Total Hydrocarbons
TIC Tentatively Identified Compound
TOCDF Tooele Chemical Agent Disposal Facility
VOA Volatile Organic Analysis
VOC Volatile Organic Compound
acfm
amu
cfm
OC
OF
dscf
dscfm
dscm
dsL
ft
ot)
g/sec
gal
gpm
grldscf
AH
inHg
inWC
kg
L
Llmrn
M
pg
3m
mg
mglL
mg/kg
min
mL
mLlmin
N
ng
ppb
ppm
ppmdv
lb/hr
psig
AP
wt%
Y.
TOCDF ATLIC STB
Section No.: 2.0
Revision Date: H:'##): io, I
Page No.: 8
LIST OF UNITS AND MEASUREMENTS
actual cubic feet per minute
atomic mass unit
cubic feet per minute
degree centigrade
degree Fahrenheit
dry standard cubic foot
dry standard cubic feet per minute
dry standard cubic meter
dry standard liter
foot
gram
grams per second
gallon
gallons per minute
grains per dry standard cubic foot (1 atmosphere, 68 "F)
ayerage pressure differential across orifice meter
inches of mercury
inches of water column
kilogram
liter
liters per minute
molar
microgram
cubic meter
milligram
milligrams per liter
milligrams per kilogram
minute
milliliter
milliliters per minute
Normal
nanogram
parts per billion
parts per million
parts per million on a dry volume basis
pounds per hour
pounds per square inch gauge
pitot velocity pressure
weight percent
dry gas meter calibration factor
Agent GA
A1
Ag
As
B
Ba
BFB
Be
Cd
Clz
Coz
CO
Co
Cr
Cu
DFTPP
HNO3
Hg
HCI
Hzoz
KMnOa
Mn
NaOH
NazSzOl
HzSO+
Ni
NO*
O2
Pb
PCDD
PCDF
Sb
Se
Sn
TCDD
TI
V
Zn
TOCDF ATLIC STB
Section No.: 2.0
Revision No.: I
Revision Date: December 2,2010
Page No.: 9
LIST OF'CHEMICAL SYMBOLS AI\D FORMULAS
Ethyl N,N-dimethyl phosphoroamidocyanidate
aluminum
silver
arsenic
boron
barium
4-bromofluorobenzene
beryllium
cadmium
chlorine
carbon dioxide
carbon monoxide
cobalt
chromium
copper
dec afl uo ro triphenylpho sphine
nitric acid
mercury
hydrogen chloride
hydrogen peroxide
p otas sium p ennanganate
manganese
sodium hydroxide
sodium thiosulfate
sulfuric acid
nickel
nitrogen oxides
oxygen
lead
p olychlorinated dib en zo -p - dioxin
p o lychlorinated dib en zofur an
antimony
selenium
tin
t etrachl oro d tb enzo -p - di o x in
thallium
vanadium
zinc
TOCDF ATLIC STB
Section No.: 3.0
Revision No.: 1
Revision Date: Decemb er 2,2010
Page No.: 1
3.0 PROJECT DESCRIPTION
The Tooele Chemical Agent Disposal Facility (TOCDF) was designed and built for the U.S.
Army as ahazardous waste incinerator facility to destroy the chemical munitions stockpile at the
Deseret Chemical Depot (DCD), which is 20 miles south of Tooele, Utah. The incinerator
system is designed to dispose of chemical agents (GB, VX, H-series mustard), drained munitions,
contaminated refuse, bulk containers, liquid wastes, explosives, and propellant components. As
the DCD is scheduled for closure, the destruction of the remaining nerve Agent GA and the
blister agent Lewisite is necessary to complete the destruction of all the chemical agents in
storage at DCD. The destruction of these additional chemical agents has been contracted to
EG&G Defense Materials, Inc. (EG&G), by the United States Army Chemical Materials Agency,
and these activities will be conducted in DCD Area 10 in a newly constructed facility.
The TOCDF operates under a Resource Conservation and Recovery Act (RCRA) permit issued
pursuant to delegation by the State of Utah, Department of Environmental Quality (DEQ),
Division of Solid andHazardous Waste (DSHW) under the Utah Administrative Code, Section
315. The TOCDF also operates under a Title V Permit from the State of Utah, DEQ, Division of
Air Quality (DAQ. Emissions from the TOCDF incinerators are regulated under the joint
authority of the Clean Air Act and RCRA. The TOCDF Environmental Protection Agency
(EPA) identification number is UT5210090002. Under the requirements of the TOCDF RCRA
Permit, the incinerator system must demonstrate an ability to effectively treat any hazardous
waste such that human health and the environment are protected, and the Maximum Achievable
Control Technology (MACT) rule has set the performance standards that incinerators must meet.
This plan describes the new Area 10 Liquid lncinerator (ATLIC), the fifth incinerator system that
TOCDF operates to dispose of the chemical agents stored at DCD. The TOCDF incinerator
systems include two Liquid lncinerators (LICl andLICZ), the Metal Parts Furnace (MPF), and
the Deactivation Furnace System (DFS). The systems are designed to meet theHazardous Waste
Combustor (HWC) MACT regulation performance requirements, which are found in Title 40 of
the Code of Federal Regulations, Part 63, Subpart EEE (40 CFR 63, EEE). Combined Agent
Trial Bums (ATBs) and Comprehensive Performance Tests (CPTs) have been conducted in the
other incinerator systems at the beginning of each new campaign, and similar testing will be
conducted in the ATLIC for processing Agent GA and Lewisite.
This plan describes how TOCDF intends to use surrogate chemicals to demonstrate the
combustion of hazardous chemicals in a combined Surrogate Trial Burn (STB) and CPT in the
ATLIC, which will be referred to as the ATLIC STB. (The ATLIC Lewisite CPT will
demonstrate the processing of increased concentrations of arsenic and mercury present in the
Lewisite and will be addressed in a separate plan.) This plan also serves as notification that
TOCDF plans to conduct a CPT for the ATLIC. The feed rates, flows and temperatures
demonstrated during the ATLIC STB will be used to set limits and operating parameters when
the testing is completed.
TOCDF ATLIC STB
Section No.: 3.0
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This Quality Assurance Project Plan (QAPP) describes the sampling and analytical activities that
will be performed by the sampling subcontractor and laboratory during the ATLIC STB. The
QAPP was developed using methods from SW-846 (l) and guidance from EPA Region 6 (2).
EG&G is responsible for operating TOCDF and conducting the ATBs. In addition, EG&G is the
principal data user and decision maker for the ATLIC STB, but will subcontract out the sampling
and analysis portions of this STB. This subcontracted support will include gas sampling
performance, spiking activities, samples transportation to the laboratory, sample analyses, the
Quality Assurance/Quality Control (QA/QC) associated with these tasks, and results reporting.
The subcontractor will provide in-process approvals with final acceptance and approval by
EG&G. EG&G will be responsible for the collection of certain fnonitoring information, the
collection and analysis of feed samples, the collection of system operating data, and preparation
of the final report.
The exhaust gas will be tested for the following analytes during the ATLIC STB:
. Oxygen (O2), carbon monoxide (CO), and carbon dioxide (COz);
. Particulate matter (PM);
O . Hydrogen chloride (HCl) and chlorine (Cl2), also referred to as the halogens;
. Nitrogen oxides (NOJ,
. Metals emissions;
. Volatile Organic Compounds (VOCs);
. Semi-Volatile Organic Compounds (SVOCs);
. Polychlorinated dibenzo-p-dioxins and polychlorinated dibenzofurans (PCDDs/PCDFs);
and
. Total Hydrocarbons (THCs).
The Principle Organic Hazardous Constituents (POHCs) will be chlorobenzene and
tetrachloroethene, which will be sampled as VOCs. The chlorobenzene data will be used to
verify that the ATLIC can demonstrate 99.9999 percent Destruction and RemovalBffrciency (Yo
DRE) or greater for chlorobenzene. The VOC analyses will be performed using SW-846,
Methods 5041N8260B (1), for all performance runs. The PCDDs/PCDFs will be sampled using
Method 0023A (l) and analyzedusing Method 8290 (1).
The exhaust gas will
(HHRA), which are:
boron (B), cadmium
mercury (Hg), nickel
zinc (Zn).
IOCDF ATLIC STB
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Page No.: 3
be analyzed for the elements used in the Human Health fusk Assessment
aluminum (Al), antimony (Sb), arsenic (As), barium (Ba), beryllium (Be),
(Cd), chromium (Cr), cobalt (Co), copper (Cu), lead (Pb), manganese (Mn),
(Ni), selenium (Se), silver (Ag), thallium (Tl), tin (Sn), vanadium (V), and
Samples of the surrogate mixture feed will be analyzed for chlorobenzene and tetrachloroethene.
The metals spiking solution will be aralyzed for the HHRA metals. Samples of the scrubber
liquor and venturi scrubber liquor will be analyzed for VOCs, SVOCs, PCDDs/?CDFs, and
HHRA metals. The process water sample will be analyzed for VOCs, SVOCs, and HHRA
metals.
The ATLIC STB Plan is designed to demonstrate the DRE that, under normal operating
conditions, will apply during the actual Agent GA and Lewisite destruction. Project scheduling
is found in the STB Plan and will be updated as necessary. Data Quality Objectives (DQOs) for
each method are found in Annex A to this QAPP. Individual project and quality records are
identified herein. Examples of the Calibration Data Sheets, Isokinetic Run Sheets, and Chain-of-
Custody (COC) Records are found in Annex B. Annex C contains resumes of the key
individuals for this project, and the DAQ and DSHW will be updated when any changes occur.
TOCDF ATLIC STB
Section No.: 4.0
Revision No.: I
Revision Date: Decemb er 2,201 0
Page No.: I
4.0 PROJECT ORGANIZATION
The ATLIC STB organizationis summarizedinFigure A-4-1. This organizationhas five groups
that work together for the successful completion of this STB. One group is the EG&G
organization, the second is the Battelle Chemical Assessment Laboratory (CAL), the third is the
sampling subcontractor, the fourth is the spiking contractor, and the fifth is the laboratory
subcontractors. This project management structure anticipates the direct, personal responsibility
for each task and provides the mechanism for review and corrective action. The direct
supervisory line of responsibility also provides for flexibility and timely action to correct
problems. The EG&G Contract Administrative Representative (CAR) will interface with the
subcontractor organizations. The EG&G Test Director has the overall responsibility for this
STB, and as such, is the point of contact between EG&G Operations and the STB organization.
Annex C contains copies of the resumes of the key individuals involved in the ATLIC STB. If
any subcontractors for the ATLIC STB change, resumes for the new subcontractor's key
individuals will be provided to DAQ and DSHW.
4.1 TEST DIRECTOR
The Test Director is an employee of EG&G and has the overall responsibility for the conduct of
the ATLIC STB. The Test Director coordinates the activities of EG&G, Monitoring personnel,
CAL personnel, and the sampling subcontractor. ln addition, the Test Director will coordinate
the information to be provided in the final ATLIC STB Report. The duties of the Test Director
include:
Ensuring that the feed is prepared for the STB.
Establishing the system operating parameters as described in the ATLIC STB plan.
Determining when Operations is ready to begin the performance run.
Notiffing the sampling subcontractor to begin sampling.
Determining whether the performance run is acceptable from an EG&G perspective.
4.2 CONTRACT ADMINISTRATIVE REPRESENTATIVE
The CAR and has the responsibility of oversight of the subcontractors to ensure that theyperform
as directed by the QAPP and their contract.
a
A
EG&G
Test
Director
TOCDF
QC
Inspectors
FIGURE A-4-I, ATLIC STB ORGANTZATION CHART
TOCDF ATLIC STB Plan
Section No.: 4.0
Revision No.: 1
Revision Date: December 2,2010
Page: 2
-lalataaa
Administrative Line
Communication Line
TOCDF
Laboratory
Manager
CAL
Analyses
Team
Subcontractor
QA Officer
Sampling
Subcontractor
Manager
Su bcontractor
Program
ManagerSubcontractor
Laboratories
Spiking
Subcontractor Sampling
Team
Coordinator
Data Analysis
& Report
Coordinator
Sampling Trai
Operators Document
Preparation
Recovery
Technicians
TLIC STB Project ORGN.xls
TOCDF ATLIC STB
Section No.: 4.0
Revision No.: I
Revision Date: December 2,2010
Page No.: 3
4.3 TOCDF LABORATORY MANAGER
The TOCDF Laboratory Manager is a Battelle employee who manages both the Monitoring
group and the CAL. The Monitoring group has the responsibility for agent monitoring and the
Continuous Emission Monitoring System (CEMS) Monitoring Team. ln addition, the CAL has
the responsibility for selected analyses and the Battelle QC Inspectors. The Laboratory Manager
is specifically responsible for:
. Tracking samples through the CAL.
. Archiving the analytical data generated by the CAL.
. Providing the QC performed in support of the analyses.
4.4 SUBCONTRACTOR PROGRAM MANAGER
The Subcontractor Program Manager is an employee of the subcontracted sampling firm. The
Subcontractor Program Manager is responsible for:
O . Committing the subcontractor resources to the project.
. Resolving problems if they occur.
. Ensuring that the subcontracting firm complies with the QAPP and the contract with
EG&G.
. Providing the detailed planning of the sample collection efforts in coordination with the
CAR.
4.5 SAMPLING SUBCONTRACTOR QUALITY ASSURANCE OFFICER
The Sampling Subcontractor QA Officer manages the QAiQC for the project. He reports to the
Sampling Subcontractor Management and is responsible for:
. Overseeing the overall QA/QC for the sampling subcontractor portion of the STB.
. Assisting in the development of the data evaluation report for the STB.
. Enforcing the protocols of the QAPP.
TOCDF ATLIC STB
Section No.: 4.0
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Observing all on-site activities to ensure that the QAPP is followed.
Coordinating with the Sampling Team Coordinator (STC) on observation of field sample
collecting.
4.6 SAMPLING TEAM COORDINATOR
The STC is a sampling subcontractor employee who is responsible for:
Managing on-site work by subcontractor employees.
Completing the data collection for lab analyses, gas samplingdata, emission calculations,
and results reporting.
Delivering samples to the laboratory.
Overseeing the required sampling.
Directly supervisirig the gas sampling teams, providing:
. Equipment;. Transportation;. Set up;. Calibration;. Sample train operations;. Pre- and post-test leak checks;. Isokinetic checks; and
' Gas sample recovery.
The CAR will be available to coordinate with the STC, including discussing changes in any
sampling or analytical procedures.
4.7 SUBCONTRACTOR SAMPLING TEAM MEMBERS
These team members are sampling contractor employees. Each team will include a team leader
and technician. The leader will be responsible for operation of the test equipment, QA/QC, and
record keeping for the assigned train. The team leader reports any irregularities to the STC, and
the STC will report any sampling problems to the EG&G CAR and the Subcontractor Program
Manager.
TOCDF ATLIC STB
Section No.: 4.0
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4.8 SUBCONTRACT LABORATORIES
The subcontracted laboratories will verify and document that the incoming field samples match
the COC and analysis request forms. They will be responsible for tracking the samples through
the laboratory and performing the appropriate tasks to meet the QC requirements outlined in the
QAPP. In addition, the laboratories will be responsible for archiving the laboratory data that they
generate.
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5.0 QUALITY ASSURANCE AND QUALITY CONTROL OBJECTIVES
The overall objective of the measurement data for the ATLIC STB is to demonstrate compliance
with the RCRA Permit, Title V Permit, and MACT emission limits while demonstrating at least
a99.9999 % DRE for chloroberrzerle. To assess the quality of the data, a series of DQOs have
been set for each method used for the analysis of samples collected during this STB. The DQOs,
summarized in Annex A, will be used to evaluate the data generated during the STB. The data
quality indicators produced to meet the DQOs will be evaluated against the data acceptance
criteria identified in Annex A. These criteria identiff the target precision and accuracy limits that
are used to assess the data quality. Annex A was developed using the criteria from the Region 6
guidance (2), EPA QA/G-5 (3), the QA/QC Handbook (4), and SW-846 (1).
The Sampling Subcontractor QA Officer will review the STB field data. A complete assessment
of the DQOs will be included in the STB report. The data quality will be discussed with regard
to the planned DQOs and the overall project objectives. Data that are outside the QC limits will
be evaluated relative to the overall project objectives to determine their impact on defining
system performance. A discussion of this evaluation will be included in the STB report. Several
procedures will be used for monitoring the precision and accuracy objectives of the analytical
program. These procedures include:
Sampling and analytical activities that will follow standard, referenced procedures
whenever possible.
Calibration standards, internal standards, laboratory control standards, and surrogate
compounds that will be high-purity, commercially-available materials.
Analytical instruments that will be calibrated per the reference method requirements prior
to sample analysis to demonstrate that accurate performance levels are being met.
Data precision and accuracy assessed by evaluating the results from the analysis of
internal standards, laboratory blanks, calibration check standards, reagent blanks, method
blanks, field and trip blanks, duplicate samples, and matrix or surrogate spiked samples.
Sections 6.0 and 10.0 describe the project-specific QC sample types that will be analyzed, and
list the sampling and analytical methods to which they will be applied. When analytical QC
procedures reveal that a measurement error has exceeded the DQOs, the source of the deviation
will be identified, and corrective action will be taken as described in Annex A. If data fall
outside the DQOs for precision and accuracy, even after corrective action has been taken, those
data points will be flagged and discussed specifically in the data validation report. Alternative
procedures (either sampling or analytical) will be considered and recommended to the CAR
when necessary. Any changes or additions will be submitted to the DAQ and DSHW for
approval as soon as the need is identified.
o
IOCDF ATLIC STB
Section No.: 5.0
Revision No.: I
Revision Date: Decemb er 2,2010
Page No.: 2
5.1 EVALUATION OF PRECISION
Estimates of precision are different for each method, and method-specific precision DQOs are
listed by method in Annex A. Estimates of variability levels for replicate measurements of the
same parameters are expressed in terms of Relative Percent Difference (RPD) for duplicate
samples and as Relative Standard Deviation (RSD) when three or more data points are being
compared. Section 13.1 discusses how the estimates of method precision will be calculated.
Some analyses require the evaluation of a larger data set, in which case, precision will be
reported as RSD. Examples of large data sets that will be used to evaluate precision include
surrogate spikes for VOC determinations. When the analytical results approach the detection
limit, precision often is affected adversely because of the enhanced uncertainty of determinations
at the lower end of the method applicability. For those determinations near the method detection
limit, the precision estimates that are outside the target DQOs will be flagged as estimated
measurements. ln cases where duplicates are performed, and one result is less than the Limit of
Quantitation (LOQ), the average will be calculated using the LOQ; the result reported will be
flagged to explain that the precision was not calculated. Precision data will be calculated and
presented in the data validation report.
Calculation of the precision for each analysis will be based on different criteria outlined in the
QA/QC Handbook (4) and the analytical methods. The.precision for the halogen samples will be
determined by the RPD calculated from the analysis of the Matrix Spikes and Matrix Spike
Duplicates (MS/MSD). The MS/MSD will be used because the field samples have a history of
very low concentrations. The precision of the Sampling Method for Volatile Organic Compound
(SMVOC) samples will be based on the RSD calculated from the Laboratory Control Sample
(LCS) analysis. The results of the analysis of spiked samples will be used because of the
historically-low concentrations of field samples. Precision for the metals emission samples will
be based on the RPD of the LCS and duplicate analyses of one emission sample. Precision data
for metals in the process samples will be based on MS/MSD and duplicate samples. The
estimate for precision for the CEMS data will be as required by the CEMS Monitoring Plan in
Attachment 20 to the TOCDF permit (5) for the ATLIC CEMS and 40 CFR 60, Appendix A,
methods for the sampling subcontractor CEMS.
5.2 EVALUATION OF ACCURACY
Accuracy will be expressed as a percent recovery (%R) for each method. The standard used to
measure the %R is method dependent (see tables in Annex A). Additional audit samples may be
submitted by DSHW and will act as an independent measure of accuracy. Analysis of an LCS
will be assessed as a measure of accuracy; matrix effects on accuracy will be assessed using
MS/MSD. A combination of LCS and MS/MSD analyses will be used to evaluate the accuracy
of most analysis methods. An evaluation of the accuracy of organic compound analyses that use
a gas chromatograph/mass spectrometer (GC/MS) will include the recovery of surrogate
'?:3lll:l:'ffi
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Page No.: 3
compounds spiked into each sample. Section 13.0 provides the accuracy calculations. Accuracy
data will be presented in the data validation report.
An assessment of accuracy on the SMVOC will include an evaluation of the analysis of the
Tenax@ traps and the Anasorb@-747 traps analyzed separately to determine possible compound
breakthrough to the Anasorb@-747 portion of the sampling hain. The analysis of an Anasorb@-
747 trap should indicate less than 30 percent of the compound concentration that is collected by
the front two Tenax@ traps. Breakthrough of the compound to the Anasorb@-747 above this
level may indicate a loss of the collection efficiency and result in a negative bias in the analytical
result. This criterion does not apply when less than 75 nanograms (ng) are detected on the
Anasorb@-747 fiibe.
Calculation of the accuracy for each analysis will be based on different criteria taken from the
QA/QC Handbook (a) and the analytical methods. Determinations of accuracy calculations will
be as follows:
For halogen samples, by the %R calculated from the analysis of the MSA{SD.
For SMVOC samples, based on the %R calculated from the analysis of the LCS.
For metals emission samples, based on the analysis of the LCS.
For PCDD/PCDF analyses, taken from the LCS data.
For the CEMS, as directed by Attachment20 (5). (The TOCDF CEMS are certified on
an annual basis. This certification involves the measurement of calibration drift, response
time, calibration error, and accuracy as measured against a known standard gas.)
5.3 EVALUATION OF COMPLETENESS
Data completeness represents the percentage of valid data collected from a measurement system
as compared to the total amount expected to be obtained under optimal or normal conditions.
The completeness DQO for the ATLIC STB will be to obtain representative results for all
analytical parameters while operating the unit at the desired test specifications for a total of three
test runs. The completeness DQO (100 percent completeness) will be met if valid test runs are
obtained. Samples resulting from runs that are judged to be invalid based on field indicators of
incinerator performance (or aborted runs) will not be submitted to the laboratory for analysis and
are not considered to be a part of the sample completeness objective. Sampling runs will be
repeated until three runs are successfully completed. The impact of any occrurence of sample
loss will be assessed against the objective of obtaining valid runs and will be discussed in the
ATLIC STB Report.o
TOCDF ATLIC STB
Section No.: 5.0
Revision No.: I
Revision Date: Decemb er 2,2010
Page No.: 4
5.4 DETECTION AND REPORTING LIMITS
The laboratories will prepare Method Detection Limit (MDL) and LOQs for parameters to be
analyzed for the STB using the laboratory's standard operating procedures and the analytical
methods referenced in this document. These limits will be compared to the actual analytical
results in the final report. Analyes not detected in the analyses will be reported as less than (<)
the LOQ. Analyes detected with a concentration between the MDL and the LOQ will be
qualified as an estimate and reported. The laboratory conducting the analysis will determine the
MDLs and LOQs. The LOQs for the STB parameters are included in Annex A.
5.5 REPRESENTATIYENESS AND COMPARABILITY
Representativeness is defined as "the degree to which data accurately and precisely represent a
characteristic of a population, parameter variations at a sampling point, process condition, or an
environmental condition." Comparability is defined as "expressing the confidence with which
one data set can be compared to another" as discussed in EPA QA/G-5 (3).
The usefulness of the data is contingent upon meeting the criteria for representativeness and
comparability. Wherever possible, reference methods and standard sampling procedures will be
used. The representativeness DQO is that all measurements be representative of the media and
operation being evaluated. The detailed requirements for each parameter given in their
respective methods will be followed to ensure representative sampling.
The comparability DQO is that all data resulting from sampling and analysis be comparable with
other representative measurements made by the sampling subcontractor or another organization
on this or similar processes operating under similar conditions. The use of published sampling
and analyical methods, and standard reporting units will aid in ensuring the comparability of the
data.
TOCDF ATLIC STB
TJliIl,Iil; ',?
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?
6.0 SAMPLING AND MONITORING PROCEDURES
The ATLIC must demonstrate an ability to effectively incinerate the surrogate mixture such that
human health and the environment are protected. The HWC MACT Limits establish the criteria
against which applications for permits must be measured. The ATLIC STB will demonstrate that
the operating parameters meet the required performance standards, and comply with the
regulations. The STB will be considered successful when identified analysis and DRE fall within
parameters stated in this QAPP.
This section describes the process and exhaust gas sampling procedures to be performed and the
equipment to be used during the ATLIC STB. The sample t1pes, sampling locations, and sample
collection procedures will also be discussed. The sampling subcontractor will utilize EPA-
approved sampling methods, if available, for the selected analyes. Any proposed modifications
to approved methods or procedures will be presented to the DAQ and DSHW for approval prior
to implementation and will be documented in the final report.
Standard sampling equipment that meets EPA guidance will be used to collect the exhaust gas
and process samples. An independent peer review is not included as part of this scope of work.
A final readiness review will be performed by the subcontractor to ensure that the subcontractor
has the appropriate manpower, equipment, and training in place before the start of this STB.
6.1 PRE-SAMPLING ACTIVITIES
Many pre-sampling activities need to be completed before sampling can begin. These tasks
include equipment calibration, glassware preparation, sample media preparation, team meetings,
equipment packing and shipment, equipment setup, and finalization of all the miscellaneous
details leading up to the coordinated initiation of the sampling program.
6.1.1 Calibration of Process Monitoring Equipment
Calibration of the process control instruments is required on a regular basis. The calibration
status of the ATLIC process control instruments at the time of the STB will be included in the
ATLIC STB Report. The calibration frequency for the process control instruments is
summarized in Table 2-2 of the ATLIC STB plan.
6.1.2 Sampling Equipment Calibration
Section 8.0 discusses the calibration procedures for the sampling equipment.
TOCDF ATLIC STB
Section No.: 6.0
Revision No.: I
Revision Date: Decemb er 2,201 0
Page No.: 2
6.1.3 Glassware Preparation
The only consumables used in the ATLIC STB sampling will be the sample bottles, and the
reagents used in the impingerg and for recovery of the samples. The sample containers will be
purchased pre-cleaned to meet EPA criteria for clean containers, per specific container tlpe and
purpose; a certificate will be provided with the containers to document compliance with these
specifications. Sample train glassware and sample containers require specialized cleaning to
avoid sample contamination from the collection containers or sampling equipment. Cleaning
procedures for the sample train glassware are summarized below:
. Method 5126A and Method 0010 glassware and containers: hot water rinse; hot, soapy
water wash; water rinse; deionized (DI) water rinse; acetone rinse; and air dry.
. Method 0023A glassware and containers: hot, soapy water wash; water rinse; DI water
rinse; 400 "C heating for two hours; methylene chloride rinse; toluene rinse; and rinse
with acetone and methylene chloride.
. Method 29 glassware and containers: hot water rinse; hot, soapy water wash; water rinse;
10 percent nitric acid soak; DI water rinse; acetone rinse; and air dry.
. Method 0031 glassware and containers: soap and water wash; DI water rinse; and oven
dry at 150 'C for two hours. (SMVOC tubes prepared by Method 0031.)
6.1.4 Sample Media Preparation
Reagents used in the laboratory are normally of analytical reagent grade, or higher, purity.
Reagents will be labeled with the date received and the date opened. Reagent purity will be
checked by collection of the appropriate blanks. All filters will be desiccated and properly tare-
weighed prior to use.
The SMVOC tubes will be supplied to the sampling subcontractor by the laboratory just prior to
the field effort. Sorbents used for Method 0031 sampling will be prepared using two different
methods. The Tenax@ tubes will be conditioned at 225 "C (t 10" C) with a > 100-ml/min flow
of ultra-high-purity helium or nitrogen. The Anasorb@-747 itbes will be conditioned at 300 oC
(t l0 "C) with a > 10O-ml/min flow of ultra-high-purity helium or nitrogen. Tubes will then be
placed into 25- by 150-mm, clean culture tubes while still hot. Each batch of SMVOC tubes will
be verified clean by a GC/MS analysis. A blank Tenax@ cartridge will be thermally desorbed
into the GC/MS. The Tenax@ will not be considered acceptable if more than 50 ng of any target
analytes are found. An Anasorb@-747 cartridge will be analyzedby GC/MS and evaluated using
the same criteria.
TOCDF ATLIC STB
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3
The XAD-2@ traps and filters will be supplied to the sampling subcontractor by the laboratory
just prior to the field effort. The XAD-2@ resin traps will be cleaned and conditioned as directed
in the methods. An analysis of each batch of XAD-2@ resin will be provided before use as a
QA/QC step. The resin used for the PCDD/PCDF sampling will be analyzed using a High
Resolution Gas Chromatograph/High Resolution Mass Spectrometer (HRGC/HRMS) to ensure
that the resin is contaminant free.
6.1.5 Additional Pre-Sampling Activities
Prior to mobilization of the field program, a sample team meeting will be held to designate
responsibilities to each team member for the ATLIC STB. Assignments will be made based on
individual experience and the relative importance of the assigned task. Site setup will be the
final pre-sampling activity. This task involves positioning the sampling equipment in the
sampling area. During setup, preliminary measurements will be taken to determine exhaust gas
moisture and flow rate. Preliminary exhaust gas moisture will be determined in accordance with
EPA Method,4 (6), and preliminary flow rate measurements will be conducted using Methods 1
and 2 (6). These data will be used to calculate the appropriatenozzle size and sample flow rate
to be used to accomplish isokinetic sampling.
o
6.2 FIELD QUALTTY CONTROL ACTTVTTTES
The QC checks for the process data collection and sampling aspects of this program will include,
but are not limited to:
. Using standardized forms and field notebooks to ensure completeness, traceability, and
comparability of the process information and samples collected.
. Field checking standardized forms to ensure accuracy and completeness.
. Strictly adhering to the sample traceability procedures (i.e., COC) outlined in Section 7.2.
. Submitting field-biased blanks,
. Leak checking sample trains before and during port change and after sample collection.
6.2.1 Reagent Blanks
Reagent blanks will be prepared by collecting reagents used in the sampling and recovery of the
exhaust gas samples. Reagent blanks are defined as samples of the reagent source water,
solvents, solutions, and other media used for sample collection. Reagent blank samples of
0.1 Normal (\) sulfuric acid (H2SO4), 0.1 N sodium hydroxide (NaOH), acetone probe rinse
TOCDF ATLIC STB
'-'il',lll)il; '?
Revision Date: DeciT;;rr?.3r,1
solvent, and the particulate filter will be collected for the Method 5l26Atrains. The following
reagent blank samples will be collected for the Method 29 train: 0.1 N nitric acid (HNOr) probe
rinse solution, particulate filter, 5 percent HNOI and 10 percent hydrogen peroxide (HzOz)
lmpinger solution, 4 percent potassium permanganate (KMnOo) *d 10 percent HzSOa, and 8 N
HC1.
Reagent blanks will be collected for the Method 0010 sampling train and the Method 00234
sampling train. The following reagent blanks will be collected for the Method 0010 trains:
methylene chloride solvent rinses, particulate filter, XAD@-2 resin, and DI impinger water.
The following reagent blanks will be collected for the Method 0023A trains: acetone, methylene
chloride, and toluene solvent rinses, particulate filter, and XAD@-2 resin. Each reagent blank
will be analyzed for the same analytical parameters as the actual ATLIC STB samples. The
results from the analyses of these blanks will be used to demonstrate that these solvents,
solutions, and filters are not potential sources of background contamination for sample collection
and recovery.
6.2.2 Field Blanks
Field blank samples will be collected during the ATLIC STB to provide a QC check on sample
handling. Field blanks contain all the reagents used during the sample collection process. The
field blank will be a sampling train assembled in the field, leak checked, let stand for the sample
time, and then recovered as other trains. Field blank samples will be placed in appropriately-
cleaned and sized sample containers in the field and handled in the same way as actual field
samples, and analyzed by the same methods as the field samples. The DAQ and DSHW will be
notified when the field blanks will be collected to allow them the opportunity to observe.
6.2.3 Trip Blanks
Trip blanks will be used to check for contamination resulting from the shipping and transport of
the samples to the laboratory. Trip blanks will consist of a set of clean, sealed SMVOC resin
tubes and a pair of Volatile Organic Analysis (VOA) vials filled with ASTM Type II DI water.
These tubes and vials are transported from the analytical laboratory to the field site and returned
to the laboratory for storage and analysis along with the field test samples. The trip blank data
will demonstrate that the samples are not exposed to fugitive contamination during storage and
transport. Trip blanks are analyzed for the same analytical parameters as the actual test samples,
and will demonstrate good quality of background if the compound concentrations detected are <
LOQ, as specified in the QA/QC Handbook (4).
6.2.4 Field Duplicates
Duplicate samples of the surrogate mixture, metals spiking solution, baghouse residue, scrubber
liquor, venturi scrubber liquor, and phosphoric acid solution will be collected during one
t performance run as a QC step.
TOCDF ATLIC STB
Section No.: 6.0
Revision No.: I
Revision Date: Decemb er 2,201 0
Page No.: 5
6.3 EXHAUST GAS SAMPLING
The exhaust gas sampling will take place in the ATLIC exhaust stack. Monitoring with the
ATLIC CEMS will be conducted by EG&G for CO, Oz, and NO*. The sampling subcontractor
will sample for PM, HCl, Cl2, metals, VOCs, SVOCs, and PCDDs/PCDFs. Monitoring for THC
will be done with CEMS operated by the sampling subcontractor. An exhaust gas molecular
weight will be determined using Method 3 and an Orsat analyzer.
Sampling will begin when the incinerator has reached steady-state operations on waste feed, and
a run will not be started after 2:00 p.m. The Test Director or a designated representative will
authorize the STC to begin sampling. Sampling will be stopped if the waste feed is stopped. To
restart sampling, the surrogate mixture feed will be burned for 15 minutes, and if operating
parameters are steady, sampling will be restarted.
Sampling train problems will be analyzed on-site by the STC and the Test Director. If it can be
shown that the samples collected are not significantly biased and the results are valid, the run will
continue. If the decision is made to abort a performance run, the entire set of samples collected
for that run will not be analyzed. If any corrective action is required during the field-sampling
portion of a program, these actions will be reported to the STC prior to the sampling crew
demobilizing from the field. If the STC determines that a run should be repeated, he makes the
determination at that point and communicates this requirement to the Test Director. These
problems and their resolution will be discussed with the DAQ and DSHW representatives.
Exhaust gas sampling procedures and frequencies to be used during this STB are summarizedin
Table ,4.-6-1. Sampling port locations for each train are shown in Drawing EG-22-D-8211in
Attachment 4 to the Permit Modification. Five sampling trains will be used in five different
ports in the stack and the exhaust gas samples will be collected over a four hour period. Other
parameters will be determined using CEMS as shown in Table 4-6-1. The isokinetic trains will
determine the gas flow rate and the moisture concentration. Leak checks of the sample trains
will be conducted in accordance with the protocol in each method prior to sampling, during port
change, and at the conclusion of sample collection. The DAQ and DSHW will have the option
of observing these leak checks. The five trains and constituents to be sampled are:
Metho d 5126A (6) for PM, HCl, and Clz)
Metho dzg (6) for HHRA metals;
Method 0010 (1) for SVOCs;
Method 0023A (1) for PCDDs/PCDFs; and
Method 003 1 (1) for VOCs.
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TOCDF ATLIC STB
Section No.: 6.0
Revision No.: 1
Revision Date: Decemb er 2,201 0
Page No.: 7
6.3.1 Method 0031 for Volatile Organic Compounds
The VOCs will be sampled using SW-846, Method 0031, "sampling Method for Volatile
Organic Compounds (SMVOC)" (l). The SMVOC draws exhaust gas through a series of three
sorbent traps. Four sets of traps will be collected per run. Sampled gas will be passed through
each set of traps for about 40 minutes. The sorbent traps will be conditioned as described in
Method 003 1 . The collection of the four sets of traps will result in 1 60 minutes of sampling,
which exceeds the 120 min the method specifies as a minimum.
The SMVOC probe removes exhaust gas from the duct at a probe temperature of 130 oC + 5 oC
(266 "F + 9 'F) during sampling. The exhaust gas passes through a condenser and two traps
containing about 1.6 grams of Tenax@ resin each. The exhaust gas then passes through a
knockout flask that collects condensed water. Following that, the gas passes through a second
condenser and through the third trap containing about 5 grams of Anasorb@-747. Each water-
cooled condenser is arranged so that condensate will drain vertically through the traps. The traps
are arrarLged in series, so the majority of the compounds will be trapped on the Tenax@ resin..
The Anasorb@-747 in the third trap will retain the gaseous compounds. New Teflon@ sample
transfer lines will be used for the ATLIC STB, and the sampling train will use greaseless fittings
and connectors. The exhaust gas will be sampled at approximately 0.5 Llmin (20 L/sample).
Analyses of the SMVOC tubes will follow SW-846, Method 50414 (1).
The condensate collected in the SMVOC flask will be transferred to a 28-mL or 40-mL VOA vial
with Teflon@-lined septa, The flask will be rinsed three times and the rinse transferred to the
VOA vial. The vial will then be filled to the top rvith organic-free water. The condensate will be
analyzed using Method 82608.
The laboratory performing the analyses will supply the SMVOC tubes. The tubes contain gas-
chromatography-quality Tenax@ and Anasorb@-747. These tubes will be used without further
cleanup. The tubes will meet the "blank" criteria and will be consistent with the requirements of
the method. The supplier will provide an analysis for each batch of SMVOC tubes used.
Extra sorbent tubes will be taken to the sampling site to serve as field blanks and trip blanks.
One pair of SMVOC tubes, designated as a field blank, will be removed from their containers,
attached to the sampling train, and leak checked. The field blank tubes will be recovered and
stored for transport in the same manner as the sample-exposed tubes. A field blank will be
collected for each run. One set of tubes will act as a trip blank and will not be opened at the site.
All of the blanks will be analyzed by the same method as the actual samples. The SMVOC tubes
will be stored at < 10 oC and away from other samples, both before and after sampling, to
minimize potential contamination.
TOCDF ATLIC STB
Section No.: 6.0
Revision No.: 1
Revision Date: Decemb er 2,2010
Page No.: 8
6.3.2 Method 1 to Determine Duct Traverse Sampling Points
The number and location of the exhaust gas sampling points will be determined according to the
procedures outlined in Method l, "sample and Velocity Traverses for Stationary Sources" (6).
The sampling locations and the number of sampling traverse points must meet the criteria
specified in EPA Method 1.
6.3.3 Method2 to Determine Exhaust Gas Velocity and Volumetric Flow Rate
The exhaust gas velocity and volumetric flow rate will be determined using Method 2,
"Determination of Stack Gas Velocity and Volumetric Flow (Type S Pitot tube)" (6). Velocity
measurements will be made using Tlpe S pitot tubes, which will be calibrated by conforming to
the geometric specifications outlined in Method 2 or in a wind tunnel against a standard pitot.
The differential pressures will be measured with fluid manometers, and the gas temperatures will
be measured with chromel-alumel thermocouples equipped with digital readouts.
6.3.4 Exhaust Gas Moisture Content
The exhaust gas moisture content will be determined in conjunction with each isokinetic
sampling train as directed in Method 5 (6). The impingers will be connected in series and will
contain reagents as described in the following sections. The impingers will be placed in an ice
bath to condense the moisture in the exhaust gas sample. Any moisture that is not condensed in
the impingers is captured in the silica gel. Moisture will be determined from impingers' weights.
6.3.5 Combined Method 5126A for Particulate Matter and Halogens
A combined train will be used to determine concentrations of PM, HCl, and Cl2. Sample
collection will be conducted as directed by Method 5 (6). A quartz-fiber or Teflon@ mat filter
will be used. The filter will be weighed before sampling and after desiccating as directed in
Method 5. Nozzles, probe liners, and filter holders will be rinsed thoroughly prior to testing.
Samples will be collected for a minimum of four hours.
The impinger configurations used in the train are:
Impinger 1: Condensate impinger containing 50 mL of 0.1 N H2SO4.
Impingers 2 and 3: Greenburg-Smith impingers containing 100 mL of 0.1 N HzSO+.
Impingers 4 and 5: Modified Greenburg-Smith impingers containing 100 mL of 0.1 N
NaOH.
Impinger 6: Modified Greenburg-Smith impinger containing silica gel.
TOCDF ATLIC STB
'f:iff"Iii:, '?
Revision Date: Decembet^*.1r,
3
The sample is withdrawn isokinetically from the exhaust gas, while the temperature of the
sample probe and the filter housing are maintained at248 "F (+ 25 "F). The sampling runs will
be performed within t l0% of isokinetic conditions. The probe rinse and the material collected
in the filter housing will be used to determine the PM emissions. Reagent blanks will be
analyzed. The field blank will be collected as directed by the method, and the recovered field
blank samples will be analyzed the same as the other trains. This method does not require the
sample fractions to be cooled.
An ion chromatograph (IC) will be used to analyze the impinger solutions. The HCI emissions
will be determined from the analysis of the HzSO+ impinger solutions, and the C12 emissions are
determined from the analysis of the NaOH impingers. Chlorine is absorbed by the basic solution
and disassociates to form sodium chloride and sodium hypochlorite (NaOCl). The sample
recovery of the NaOH impingers will include the addition of sodium thiosulfate (NazSzOr) to
reduce anyNaOCl to chloride ion. This will result in 2 moles of chloride ion for each mole of
Cl2 present in the exhaust gas sample.
6.3.6 Method 0010 for Semi-Volatile Organic Compounds
The SW-846, Method 0010 (1), will be used to collect a minimum sample volume of 120 dscf of
exhaust gas for SVOCs. The exhaust gas is extracted isokinetically from ports in the horizontal
duct through a glass nozzle and a borosilicate glass-lined probe. Sampling train connections will
be Teflon@ and glass. The PM is removed from the gas sample by a glass fiber filter housed in a
glass filter holder maintained at248 oF (+ 25 'F). The sample gas passes through a water-cooled
condenser and into the XAD@-2 sorbent trap that collects the SVOCs; the condenser and
XAD@-2 sorbent trap are arranged to allow the condensate to drain vertically through the trap.
The gas temperature at the entrance to the resin trap will be maintained below 68 'F. The chilled
impinger train removes water from the exhaust gas, and a dry gas meter then measures the
sample volume.
Mobile laboratory trailers will be used for sample train assembly and recovery. Recovery of the
Method 0010 samples and assembly of the sample trains will be conducted in an environment
that is free from uncontrolled dust. Containers used for the recovered samples will be labeled
during recovery procedures. After sample recovery, the sample fractions will be cooled at< 4 "C
until they are shipped. The sample fractions will be recorded on COC forms, packed in ice, and
shipped to the laboratory for analysis. The samples will be processed for analysis within the
holding-time requirements described in Section 7.0.
Blanks of each solvent lot used will be saved for potential analysis. A field blank will be
prepared and recovered as directed by the method. The field blank will be leak checked and then
allowed to sit for the sampling time of the train. The recovered samples will be shipped to the
laboratory and analyzed in the same manner as the other trains.
TOCDF ATLIC STB
Section No.: 6.0
Revision No.: I
Revision Date: December 2,2010
Page No.: 10
6.3.7 Method 0023A for PCDDs/PCDFS
Method 00234 (1) will be used to sample the exhaust gas for PCDDs/PCDFs during each
performance run. The Method 0023A sample train will collect exhaust gas for four hours. The
minimum sample volume collected will be 120 dry standard cubic feet (dscf). The exhaust gds is
extracted isokinetically through ports in the horizontal duct using a heated borosilicate glass-
lined probe. Sampling train connections are made with Teflon@ and glass. The PM is removed
by a glass fiber filter housed in a glass filter holder maintained at248 'F (+ 25 oF). For removal
of the organic compounds, the sample gas passes through a water-cooled condenser and XAD-
2@ sorbent trap, which are arranged in a manner that allows the condensate to drain vertically
through the XAD-2@ trap. The gas temperature at the entrance to the resin trap will be
maintained below 68 oF. A chilled impinger train is used to remove water from the exhaust gas,
and a dry gas meter will be used to measure the sample gas volume.
Recovery of the Method 0023A samples and assembly of the sample trains will be conducted in a
dust-controlled environment of mobile laboratories. The samples will be processed for analysis
within the holding time requirements described in Section 7.0. After sample collection, the
recovered sample fractions will be cooled at < 4 oC until they are shipped to the laboratory for
analysis. Samples received at the laboratory will be combined into two sample fractions for
analysis. One fraction will contain the probe rinse and the filter extract with surrogates added to
the filter. The second fraction will contain the XAD-2@ extract and the back half rinse with field
surrogates added to the XAD-2@ resin before sampling.
Blanks of each solvent lot used will be saved for potential analysis. A field blank will be
prepared and recovered as directed by the method. The field blank will be leak checked and then
allowed to sit for the sampling time of the train. The recovered samples will be shipped to the
laboratory and analyzed in the same manner as the recovered samples from the other trains.
6.3.8 Method29 for Metals
Metal emissions will be sampled using Method 29 (6). The setup, pretest preparations, and leak-
check procedures are the same as outlined in Method 5 (6). Nozzles, probe liners, and filter
holders will be rinsed thoroughly prior to testing. Samples will be collected for a minimum of
four hours.
Impinger configurations are:
. Impinger 1: Empty, modified Greenburg-Smith, to serve as a knockout.
. Impinger 2: Modified Greenburg-Smith containing 100 mL of 5 o/o HNO: and l0 %
HzOz.
. Impinger 3: Greenburg-Smith containing 100 mL of 5 YoHNO3/10 %oHzOz.
TOCDF ATLIC STB
Section No.: 6.0
Revision No.: I
Revision Date: December 2,2010
Page No.: l1
Impinger 4: Empty, modified Greenburg-Smith.
Impingers 5 and 6: Modified Greenburg-Smith containing 100 mL each of 4 % KMnO+
and 10 o/oHzSOa,.
. Impinger 7: Modified Greenburg-Smith containing silica gel.
The sample train will be recovered as directed by Method29 (6). The front half of the train is
rinsed with 0.1 N HNO3 including the probe nozzle, probe liner, and front half of the filter holder
into a tared sample bottle. When the rinse is complete, the bottle is capped and the weight of
rinse is recorded on the field sample recovery sheet. Then 100 mL of acid is placed in a second
wash bottle and used to rinse the back half of the filter housing, the transfer line, and the first
three impingers. These rinses are added to the impinger contents, the bottles capped, and the
weight of acid used in the rinse recorded on the field sample recovery sheet. The fourth impinger
will be recovered separately with a 0.1 N nitric acid rinse. Impingers 5 and 6 will be rinsed with
KMnO+ impinger solution, and DI water. These rinses will be combined with the collected
impinger catch from these two impingers, which are then rinsed with 8 N HCI; this rinse is kept
separate. Six sample fractions will be analyzed from the Method 29 train. The front-half
fraction consists of the acid digestion of the filter and the rinse of the probe, nozzle, and filter
holder front half. The back-half fraction consists of the contents of the first three impingers and
their rinses along with the rinse of the back half of the filter holder. These two fractions will be
analyzed for the HHRA metals. Impinger 4 and its rinse will be analyzed for mercury only.
lmpingers 5 and 6 and their rinses will be analyzed for mercury only, and the acid rinse of
impingers 5 and 6 will also be analyzed separately for mercury only as well. The sample
fractions are acid solutions, and the acid will preserve the samples. Method 29 (6) does not
require cooling the samples, so they will be shipped without cooling.
The reagent blanks will be prepared as directed by Method 29. The reagent blanks are analyzed
to determine if significant amounts of metals are added through the reagents. The reagent blank
will be used to make the corrections called for in Sections 12.6 and 12.7 of Method 29.
A field blank will be prepared with the same components as a regular train and recovered using
the same reagent amounts. The field blank willbe leak checked and then allowed to sit for the
sampling time. Recovered samples will be aralyzed using the same methods as field samples.
6.3.9 Continuous Emissions Monitoring
The ATLIC CEMS operated by EG&G will be used to monitor the CO, Oz, and NO*
concentrations. The operation, calibration procedures, and preventive maintenance procedures
for the CEMS are described in Attachment}} of the TOCDF RCRA Permit (5), which also
describes specific locations, sampling frequencies, and the speoific tlpes of instrumentation for
each monitoring station. Attachment2) of the TOCDF RCRA Permit (5) describes the
TOCDF ATLIC STB
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monitoring system that is used to provide continuous operational control of the ATLIC and to
meet the requirements listed in the RCRA Permit and Title V Permit. A Relative Accuracy Test
Audit (RATA) will be conducted prior to the STB ai directed by the HWC MACT regulations.
The CO, 02, and NO* CEMS data will be recorded continuously during each test. The sampling
ports for the monitors are located in the ATLIC stack. The CO concentration will be determined
using two monitors identified as 819-AIT-8302A/8. The Oz concentration will be determined
using two monitors identified as 819-AIT-8301A/B. The NO* concentration will be determined
using two monitors identified as 819-AIT-8304A/B. These monitors will be checked against
zero and span checks to veriff the CEMS data quality. If the zero and span checks indicate
unacceptable CEMS results for accuracy and precision, then the monitor will be recalibrated
according to the manufacturer's specifications. The Facility Control System (FCS) will record
the CEMS data, which will be used for Oz corrections.
Each year, the CEMS are certified by on-site testing and calibrations. Guidelines are delineated
in a quality control plan and laboratory operating procedure for each CEMS. In addition to the
annual certification, an Absolute Calibration Audit (ACA) will be conducted quarterly as
directed by the HWC MACT regulations. The QC plans, including bounds, calibration
frequency, and procedures, are discussed in Attachment}} of the TOCDF RCRA Permit (5).
The THC concentrations will also be monitored using CEMS operated by the sampling
subcontractor. The THC CEMS will be calibrated as directed in Methodzs (6). An exhaust gas
molecular weight will be calculated using Method 3 and an Orsat analyzer. The Method 3
sample will use a sample line from one of the isokinetic sample probes and an integrated sample
will be collected over each run.
6.4 PROCESS SAMPLING
Table A-6-2lists the process streams, analyses to be performed, sampling method, sampling
frequencies, and sample volumes. The process samples will be collected using ASTM
lnternational (ASTM) methods. Liquid samples will be collected from taps provided for sample
collection and residue samples will be taken using scoops. Field duplicates of the scrubber
liquor, baghouse residue, and surrogate mixture samples will be collected during one run.
6.4.1 Process Stream Sampling Locations
Process streams sampled as part of the ATLIC STB include the surrogate mixture feed, metals
spiking solution, phosphoric acid solution, process water, scrubber liquor, and venturi scrubber
liquor. Surrogate mixture samples will be collected from a valve in the feed lines. The
phosphoric acid solution in the SDS tank will be mixed before collection of the sample. A grab
sample of the phosphoric acid solution will be taken from the SDS tank during the run. If
additional phosphoric acid or other material is added to the SDS tank, then new samples will be
collected.
IOCDF ATLIC STB
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TABLF, A-6-2. PROCESS SAMPLES TO BE COLLECTED
l:. :.'.. . ... .'.:.'.. :'
Sampling
,N[ethro,d i
Vo:lume
Scrubber
Liquor *
PH, HHRA
Metals, VOCs,
SVOCs,
PCDDs/PCDFs,
Tup, ASTM
Method
D3370
One Sample
per Run
Three 40-mL VOA
vials, one 250-mL,
one 500-mL, and
two 1-L bottles
Venturi
Scrubber
Liquor *
pH, HHRA
Metals, VOCs,
SVOCs,
PCDDs/PCDFs,
Tup, ASTM
Method
D3370
One Sample
per Run
Three 40-mL VOA
vials, one 250-mL,
one 500-mL, and
two I -L bottles
Phosphoric
acid solution*
HHRA Metals,
VOCs, SVOCs,
PCDDs/PCDFs
Tup, ASTM
Method
D3370
One Sample
per Run
Three 40-mL VOA
vials, one 500-mL
and two 1-L bottles
Process
Water
TDS, HHRA
Metals, VOCs,
SVOCs,
PCDDs/PCDFs
Tup, ASTM
Method
D3370
One Sample
per STB
Three 40-mL VOA
vials, one 500-mL
and two 1-L bottles
Baghouse
Residue*
HHRA Metals,
VOCs, SVOCs,
PCDDs/PCDFs
Grab, ASTM
D5633
One Sample
per Run
Two VOA vials and
two 500-mL bottles
Metals
Spiking
Solution*
HHRA Metals
Tup, ASTM
Method
D3370
Two Samples
per Run
Two 250-mL
bottles
Surrogate
Mixfure*
HHRA Metals,
chlorobenzene,
and
tetrachloroethene
Tup, ASTM
Method
D3370
Two Samples
per Run
Two 250-mL
bottles
* One run will have a duplicate set of samples collected.
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The scrubber liquor samples will be taken via taps on the side of the sump. Samples of the
surrogate mixture will be collected from taps on the liquid delivery system at a location that will
prevent fluctuations in the delivery pressure or flow of the solution. The process water sample
will be taken from a tap on the water line.
6.4.2 Tap Sampling Method
Liquid process samples will be collected using the method described by the ASTM Method
D3370 (7). These samples will be collected by attaching a sample line to the tap and flushing the
sample line. The flush will be managed in accordance with applicable EPA and DSHW
regulations. Separate sub-sample bottles are used for each sample. To collect a liquid process
sample, the sample line is inserted into the sample container, and the tap is opened to allow the
sample bottles to be filled without splashing the sample. The VOA vials will be filled in a l-min
time to reduce the loss of VOCs from the sampling container. This method ensures that the
actual material collected is representative of the stream.
The surrogate mixture will be sampled each run during the first 30 minutes of the run and a
second collected during the final 60 minutes of the run. The metals spiking solution samples will
be collected at the same times. Scrubber liquor samples will be collected during the final 60
minutes of the run. The process water sample will be collected during one run.
6.4.3 Residue Sampling Method
After the run has been completed, the drum on the baghouse residue collection system will be
removed and a new drum placed on the collection system. A representative sample of the
residues will be removed from the drum with a laboratory scoop or sample thief using ASTM
Method 5633 (8) and placed in amber glass bottles with Teflon@-lined lids. The remaining
residue will be consolidated with other residues and properly managed.
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6.5 PROCESS MONITORTNG EQUIPMENT
Process electronic data output will be monitored carefully by incinerator operators to maintain
steady-state operating conditions during the ATLIC STB. Process monitoring equipment will be
inspected and calibrated periodically. EG&G will be responsible for collecting operations data,
the permit-required monitoring information, and system operating data in accordance with
Standard Operating Procedures (SOPs). The process data to be collected includes:
. Primary Combustion Chamber (PCC) exhaust gas temperature and PCC pressure;
. Secondary Combustion Chamber (SCC) exhaust gas temperature and SCC exhaust gas
delta pressure;
. Surrogate Mixture feed rate and phosphoric acid feed rate;
. Scrubber liquor pH;
. Quench exhaust gas temperature;
. Venturi delta pressure and venturi scrubber liquor flow;
. Scrubber liquor flow and pressure to the packed bed scrubbers; and
. CO concentration, 02 concentration, and NO* concentration.
6.6 POST-SAMPLING ACTIVITIES
Any wastes generated during sample collection will be handled in a safe manner. Liquid wastes
will be placed in appropriately-sized containers at a satellite collection point.
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7.0 SAMPLE HANDLING, TRACEABILITY, AND HOLDING TIMES
This section describes the sample preservation methods, holding times, field documentation and
shipping requirements. Process stream samples will be collected by the TOCDF Monitoring
personnel with the exception of the surrogate mixture samples and the metals spiking samples
which will be collected by the spiking subcontractor. Exhaust gas samples will be collected by
the sampling subcontractor.
7.1 SAMPLE PRESERVATION AND HOLDING TIMES
Requirements for preserving samples and holding times were taken from Table 3-1 in SW-846
(1) and the QC Handbook (4), and are shown in Table A-7-1. The sampling and packaging
technicians will preserve the samples as directed by Table A-7-1. Samples requiring cooling will
be maintained at < 4 "C until shipped in a cooler packed with ice, and sample temperatures will
be monitored upon receipt at the laboratory. The Method29 train samples will be in acid
solutions from the sample recovery, and additional acid will not be added for preservation.
Holding times will be monitored by keeping track of the time following sample collection.
Samples will be delivered or shipped to the laboratory as necessary to meet the holding times for
the sample analyses.
7.2 DOCUMENTATION
The following subsections present the requirements for labeling, maintaining the COC, and
handling environmental samples. Recording information necessary for reconstruction of the
sampling event will be discussed. Entries made on the following documents will use the error
correction protocol of drawing one line through the error, then initialing and dating the change.
Documentation will be made available to the DAQ and DSHW upon request.
7.2.1 Sample Labels
Sample labels are necessary to prevent misidentification of samples. Therefore, the samples
collected by the sampling subcontractor will be labeled following a designated code system
developed by the STC for this project. Samples will be sealed and the volume of the sample
marked. The data from each sample run will be recorded on a run sheet during each performance
run, and after each run, the data will be checked for completeness. The sampling subcontractor
will then complete the appropriate COC forms to be sent to the laboratory.
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TABLE A-7.1. SAMPLE PRESERVATION AND HOLDING TIMES
Process Streams (Resid ue)
Metals I p:H<z
I
| (Unpreserved)
|
6 months (28 days Hg)
I
28 days (14 days Hg)
I
VOCs Cool (< 4 "C)14 days
SVOCs Cool (< 4 'C)Extract 14 days, Analyze 45 days
PCDDs/PCDFs Cool (< 4 "C)Extract 30 days, Analyze 45 days
Exhaust Gas
Method 5 - PM None Required 28 days
Method26A-
Sulfuric Acid
Solutions
No Additional
Required 28 days
Method26A-
Sodium Hydroxide
Solutions
2mL of 0.5 M
NazSzO:28 days
Metho d 29 No Additional
Required 28 days
SMVOC Tubes and
Condensate Cool (< 4 "C)14 days
Method 0010 Cool (< 4 "C)Extract 14 days, Analyze 45 days
Method 0023A Cool (< 4 "C)Extract 30 days, Analyze 45 days
Gummed-paper labels or tags wiil be used to identify the samples. The labels will include at
least the following information:
A sample number, including a sample code that distinguishes field samples, duplicates,
or blanks where appropriate.
A signature or the initials of the sample collector.
The date and time of collection.
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. The incinerator designator and trial run number.
. The type of preservative used, or "None," as applicable.
Labels will be affixed to sample containers prior to, or at the time of, sampling. However, the
labels will be filled out at the time of sample collection.
7.2.2 Sample Seals
Sample seals are used to detect improper handling of samples from the time of sample collection
through the time of analysis. Items such as gummed paper seals and custody tape will be used
for this purpose. Signed and dated seals will be attached so that they must be broken to open
either the individual sample containers or shipping containers. Seals will be affixed to containers
before the samples leave the custody of the sampling personnel.
7 .2.3 Chain-of-Custody Forms
The purpose of COC procedures is to document the identity of the sample and its handling, from
collection through all transfers of custody. To establish the documentation necessary to trace
sample possession from the time of collection, a COC record must be filled out and accompany
every sample or group of individually identified samples
A designated field technician will take custody, sign the COC forms, and deliver the samples to
the laboratory. The field technician will sign the appropriate forms relinquishing custody, and
the laboratory representative will sign the form indicating that they have taken custody of the
samples. Examples of the sampling subcontractor's COC forms and other sampling
documentation can be found in Annex B.
When a sample arrives at the laboratory, an individual with the COC authority who is trained in
the laboratory sample receiving and control methods will take custody of the samples. The
sample coolers will be opened by the sample custodian or designee and logged into the master
sample log. A laboratory internal COC form will be completed, and the sample will be placed in
locked storage. Laboratory analysts will sign out samples prior to analysis. The sample
custodian will use a standard form to record the location of the sample and any transfers of the
sample to analytical personnel. The laboratory sample custodian will keep the form until the
project is complete. The forms will then be transferred to the Document Control Center with the
project file.
The COC for the sampling trains will be established when the sampling crew take possession of
the sample train components. Either the entire sampling crew handling the train or just one
person may be listed on the train COC. The person recording the data will sign the COC for the
sample when it reaches the sampling location. The person or persons transporting the sampling
train to the sample recovery laboratory will sign the COC. When the sample train reaches the
TOCDF ATLIC STB
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recovery laboratory, the laboratory chemist will check in the sample. Each person who has
custody of the samples fractions signs the COC when the fractions are all received. In addition,
the chemist will then begin a new COC when the fractions have been correctly recovered,
labeled, and sealed.
The COC for the process samples will be filled out at the end of each performance run. Before
that point, the samples will remain in the possession of the person collecting the samples. The
samples may be secured in a cooler with the COC taped to the cooler until the performance run is
completed. The samples will be secure because sample collection takes place in a high-security
area. Personnel in the area must have a security clearance or be escorted by a security-cleared
person before they are allowed within the double-fenced area. Only authorized personnel are
allowed into the areas where the samples are held until shipment to the laboratory.
Each person who has custody of the samples must sign the COC form, which must contain the
fo llowing information :
. The sample identification number;
. The date and time of sample collection;
. The signature or initials of the sample collector;
. The matrix type;
. The number of containers;
. The signatures of persons in the COC; and
. The date and time of each change in custody.
7.3 SAMPLE TRANSPORT TO THE LABORATORY
Samples will be packaged and shipped according to U.S. Department of Transportation and EPA
regulations, and delivered to the laboratory so that the requested analyses can be performed
within the specified allowable holding time. The samples will be accompanied by the COC
record and a sample analyses request form. The request form will list the variables to be
analyzed by the laboratory, and the total number and types of samples shipped for analysis.
Authorized laboratory personnel will acknowledge receipt of shipment by signing and dating the
COC form, and returning a copy to the Sampling Subcontractor QA Officer.
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8.0 SPECIFIC CALIBRATION PROCEDURES AND F'REQUENCY
This section contains information and details pertaining to the calibration of both the process
monitoring systems and the exhaust gas sampling equipment.
8.1 PROCESS MONITORING EQUIPMENT CALIBRATION
Process control inskuments are calibrated on a regular basis as directed in the Instrument
Calibration Plan (9). The calibration status of the ATLIC process control instruments at the time
of the ATLIC STB will be summarizedinthe final report. The calibrations will be conducted in
accordance with the manufacturer's instructions. The monitoring equipment calibrated will be
specified in the Appendix D tables IATLIC Automatic Waste Feed Cutoff (AWFCO) tables].
These instruments include:
The PCC temperature transmitters;
The SCC temperature transmitters;
The venturi differential pressure;
The scrubber liquor flow meter; and
The pH meters.
Most of these instruments are on a regular schedule of calibration of every 180 to 360 days. The
pH meters are on a weekly schedule for calibration. The monitoring equipment calibrated is
specified in the above mentioned tables in Appendix D.
8.2 EXHAUST GAS SAMPLING EQUIPMENT
The sampling subcontractor will calibrate the field sampling equipment before the ATLIC STB
and verify the calibration afterwards. When the STC personnel arrive on site, they will provide
copies of the calibration data to EG&G. The subcontractor will maintain an up-to-date list of
sampling equipment, including serial numbers and pertinent calibration data. Posttest
calibrations and equipment checks will be provided to EG&G before the subcontractor removes
the equipment from the site. Calibration procedures will follow guidelines provided by EPA
(10).
TOCDF ATLIC STB
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The calibrations and checks will be performed as directed below:
Probe Nozzles - Using a micrometer, measure the inside diameter of the nozzle to the
nearest 0.001 inch (0.025 mm). Make measurements at three separate places across the
diameter, and obtain the average of the measurements. The maximum difference should
not exceed 0.004 inch (0.1 mm). Inspect for damage after sampling.
Pitot Tubes - Measure for appropriate spacing and dimensions or calibrate in a wind
tunnel. The rejection criteria are provided on the calibration sheet. Inspect for damage
after sampling.
Thermocouples - Verify against a mercury-in-glass thermometer at three points; including
the anticipated measurement range. Acceptance limits are: impingers, + 2 'F; dry gas
meter, + 5.4 "F; and duct, * 1.5 percent of the duct temperature.
Dry Gas Meters - Calibrate in accordance with EPA Method 5 (6). Acceptance criteria:
pre-test Yc, + 5 percent of the calculated average Y.
Balance - Service and certify annually by the manufacturer. Prior to obtaining first
weights, confirm accuracy by placing a known S{ype weight on the balance. Balances
will be used for weighing the impingers and samples before sending them to the
laboratory.
8.3 CALIBRATION OF CONTINUOUS EMISSION MONITORING SYSTEMS
System checks will be performed on each of the CEMS analyzers(CO, Oz and NO*) on a daily
basis. Detailed information on the calibration of the CEMS is available in Attachment20 of the
TOCDF RCRA Permit (5). The CO CEMS are zero span checked daily as directed by
Attachment 20 (5). The Oz CEMS are zero span checked on a daily basis as directed by
Attachment 20 (5). The NO* CEMS are zero span checked daily as directed by Attachment20
(s).
The THC CEMS operated by the sampling subcontractor will be calibrated before the ATLIC
STB and checked on a daily basis. The calibration drift will be limited to less than 3 o/o of the
span and the calibration error will be limited to less than 5 oh of the value. The THC CEMS
response time will be less than or equal to 2.0 minutes.
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9.0 ANALYTICAL OBJECTIVES AND PROCEDURTS
This section describes the analytical procedures to be used to analyze the samples collected
during the ATLIC STB. The analyical methods to be used include GC/MS, HRGC/IIRMS, IC,
Inductively Coupled Plasma/IVlass Spectrometer (ICP/I\4S), and Cold Vapor Atomic Absorption
Spectroscopy (CVAAS). The QA procedures for this will follow the basic guidelines given in
the methods or the QA/QC Handbook (4). Should a failure in the analytical system occur, the
laboratory will notiff EG&G immediately. Any corrective actions will be as directed by Annex
A and EG&G. Table A-9-1 presents a summary of the analytical methods to be used.
The laboratories will prepare the sorbents (Tenax@, Anasorb@-747, and XAD-2@) for gas
sampling, prepare the QC samples, and analyze the samples. Laboratory QC samples will
include method blanks, blank spikes (as calibration checks and LCS), matrix spikes, and
replicates. These will be performed as required by the methods or at least one round of samples
per batch and one round every twenty samples. The field blank will be a sampling train
assembled in the field, leak checked, let stand for the sample time, and then recovered as other
trains. Table A-9-2lists the expected number of field samples, field blanks,.and trip blanks to be
analyzed.
Table A-9-2 assumes the following for:
. Method 0031 (SMVOC) samples - Four sets of three tubes collected for 40 minutes, for a
total of 160 minutes, plus a field blank set per run and a trip blank pair for each shipment
of samples. Analyses will be for VOCs.
. Method 0023A samples - One set of samples per run, plus one field blank per STB.
Analyses will be for PCDDs/PCDFs.
. Method 29 samples - One set of samples per run, plus one field blank per STB. Analyses
will be for the HHRA metals.
. Method 5126A samples - One set of samples per run, plus one field blank per STB.
Analyses will be for PM, HCl, and Cl2.
. Liquid Samples - The scrubber liquor samples will be collected during the final 60
minutes of the run. A phosphoric acid sample will be collected for each run. One
duplicate set of scrubber liquor will be collected during one run. The scrubber liquor
samples will be analyzed for total HHRA metals, VOCs, SVOCs, and PCDDs/PCDFs.
. Baghouse Residue Samples - The residue sample will be collected after the run.
TOCDF ATLIC STB
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TABLE A-9-1. ANALYTICAL ME,THODS
VOCs Tenax@, Anasorb@-7 47
SMVOC Condensate
Method 5041A Method 5041A182608
SVOCs XAD-2@/filter/
rinse/impinger contents Method 3542 Method 8270C
PCDDs/PCDFs XAD-2@/filter/rinse Method 0023A Method 0023 A18290
Particulate Matter
(PM)Filter/rinse Method 5 Method 5
HCI and C12 Impinger solutions Method 26A Method 9057
HHRA Metals Filter, rinse, impinger
solution Method 29 Methods 6020 and
7 470A
Chloroberuene and
Tetrachloroethene Surrogate mixture Method 3585 Method 82608
HHRA Metals Metals spiking solution and
phosphoric acid solution Method 30508 Method 602011470A
Phosphate Phosphoric acid solution Method 9056,4.Method 90564
TDS Process water Method 2540 (11)Method 2540 (11)
VOCs Baghouse residue Methods 5035A/5030B Method 82608
SVOCs Baghouse residue Method 3540C Method 8270C
VOCs Process water and
scrubber liquors Method 50308 Method 82608
SVOCs Process water and
scrubber liquors Method 3 5 10C Metho d 8210C
PCDDs/PCDFs Scrubber liquors and
baghouse residue Method 8290 Method 8290
HHRA Metals
Process water,
scrubber liquors, and
baghouse residue
Methods 3010A/3050B,
7 470A Methods 60201 7470A
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TABLE A-9-2. NUMBER OF SAMPLES*
: :,i
S:ampIe iATtil.c niela
Method 003 1 t2 0 3 3
Method 0010 3 0 1 0
Method 00234 3 0 I 0
Method 5126A 3 0 I 0
Method 29 3 0 1 0
Process Water I 0 0 0
Scrubber Liquor 3 I 0 0
Venturi Scrubber Liquor 3 I 0 0
Baghouse Residue 3 1 0 0
Phosphoric Acid Solution 3 1 0 0
Metals Spiking Solution 6 1 0 0
Surrogate Mixture 6 1 0 0
*Method blanks, blank spikes, matrix spikes, and replicates will be performed according to the methods.
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9.1 ANALYSIS METHODS FOR PROCESS STREAM SAMPLES
Process samples collected include surrogate mixture, metals spiking solution, process water,
scrubber liquor, venturi scrubber liquor, and phosphoric acid solution. The process streams will
be sampled each run except for the process water.
9.1.1 pH Analysis
The pH of scrubber liquor samples will be determined with a pH probe and pH meter using
Tooele Laboratory Operating Procedure 574 (TE-LOP-574). The pH probe and meter are
calibrated using certified standards; then the pH probe is rinsed, dried, and placed in the solution
tobe analyzed. The pH reading is recorded, and the probe is removed from the solution, rinsed
with distilled or DI water, and dried. The probe is then ready for the next measurement.
9.1.2 Total Dissolved Solids
The TDS will be measured on the process water sample using Method 2540 from Standard
Methods (11). A sample aliquot is filtered and the filtrate is then dried to a constant weight. The
dried weight is divided by the sample volume to determine the concentration.
9.1.3 Metals Analyses Methods
The process samples inorganic analyses are limited to the metals present in the samples.
Mercury will be analyzedby SW-846, Methods 7470A (1), which uses CVAAS. The remaining
HHRA metals are analyzed by ICP/IvIS. The methods are described below.
SW-846 Method 74704 (liquids) - Manual Cold-Vapor Atomic Absorption Technique.
A representative portion of the sample is digested with acids, potassium permanganate,
and potassium persulfate. Mercury ions are reduced to metallic mercury and stripped
from the aqueous solution with a gas stream. The mercury vapors are then directed into
the path of an atomic absorption spectrometer. Quantitation is achieved by comparison of
sample component responses to the responses of external standards.
SW-846 Method 6020 - ICP/MS. The metals concentrations in the process samples will
be determined by ICP/MS (the most recent version of the method). A representative
portion of the sample is digested with nitric acid and the sample digest is aspirated into
the nebulizer of the ICPA{S. The sample mist enters the plasma, the plasma converts the
sample to an atomic vapor, and the mass spectrometer separates the elements by mass.
The masses detected are used to quantitate the elements present by comparing sample
responses to the responses ofinternal standards.
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9.1.4 Organic Compound Analysis Methods
Scrubber liquor samples will be analyzed for VOCs (82608), SVOCs (8270C), and
PCDDs/PCDFs (8290) using the most recent versions of the methods. These methods are
described below, and their performance will be evaluated using the criteria listed in the QA/QC
tables found in Annex A.
SW-846 Method 82608 - Volatile Oreanic Compounds by GC/MS. A representative
portion of the liquid samples is introduced into a purge device using SW-846, Method
5030B (1). The liquid is purged with an inert gas, and the volatile compounds are
collected on a sorbent trap. The trap is then heated and backflushed to desorb the
compounds into the GCA4S. The sample is then analyzed for the Target Analyte List
shown in Table A-9-3 using SW-846, Method 8260B (1). Quantitation is achieved by
comparison of sample component responses to the responses of internal standards. The
20largest additional peaks, with an area at least 10 percent of the internal standards, will
be tentatively identified from each analyses conducted and will be classified as
Tentatively Identified Compounds (TICs).
SW-846 Method 8270C - Semi-Volatile Organic Compounds by GC/MS. Aqueous
samples have a representative aliquot of the sample extracted by SW-846, Method 3510B
(1), using methylene chloride and then concentrated to a known volume. Aliquots of the
extracts are analyzed by SW-846, Method 8270C (1), using GC/MS. Quantitation is
achieved by comparison of sample component responses to the responses of intemal
standards. Table A-9-4lists the target analyes for the total SVOC analyses. The 20
largest additional peaks, with an arcaat least 10 percent of the intemal standards, will be
tentatively identified from each analyses conducted and will be classified as TICs.
SW-846 Method 8290 - PCDDs/PCDFs bv HRGC/HRMS. A representative sample is
extracted with toluene; the extract is then concentrated to a known volume, and the
extract is subjected to a series of cleanup steps. The sample is evaporated to a small
volume and diluted to a known volume. An aliquot of the cleaned extract is then injected
into an HRGC/HRMS and the compounds quantitated against internal standards as
directed by SW-846, Method 8290.
TOCDF ATLIC STB Plan
Section No.: 9.0
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Revision Date: December 2,2010
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TABLE A.9.3. TOTAL VOC TARGET ANALYTE LIST FOR PROCESS SAMPLES
1,z-DichloropropaneAcetone
Benzene I ,3-Dichloropropane
Bromobenzene 2,z-Dichloropropane
Bromochloromethane 1 ,1 -Dichloropropene
Bromodichloromethane cis -1,3 -Dichloropropylene
Bromomethane tr ans - 1,3 -Dichloropropylene
2-Butanone 1,4-Dioxane
Carbon Disulfide Ethylbenzene
n-HexaneCarbon tetrachloride
Chlorobenzene 2-Hexanone
Iodomethanez-Chloro - 1, 3 -butadiene
Chlorodibromomethane Methylene chloride
Chloroethane Methyl isobutyl ketone
Chloroform n-Propylbenzene
Z-Chloroethyl vinyl ether Styrene
Chloromethane 7,1,1,2-T etrachloroethane
z-Chlorotoluene 7,l,2,2 -T etrachl oro ethane
4-Chlorotoluene Tetrachloroethylene
Cumene (i sopropylben zene)Toluene
1,z-Dibromoethane Tribromomethane (Bromoform)
1 , 1 , 1 -TrichloroethaneDibromomethane
tr ans -1,4 -Dichloro-2-butene 1,1,2-Trichloroethane
D i chl oro difl uoromethane Trichloroethylene
1 , 1 -Dichloroethane Tri chloro fl uoromethane
| ,2-Dichloroethane 1,2,3 - Tri chl oroprop ane
1 ,1-Dichloroethylene 1,I,Z-Trichloro - 1,Z,z-trifl uoro ethane
c i s - 1,Z-Dichloroethylene Vinyl chloride
tr ans -7,z-Di chloro ethylene Xylenes(o-, m-, p-)
G;H:,:]B rocDF Anarvte Listxrs
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TABLE A.9-4. TOTAL SVOC TARGET ANALYTE LIST
FOR PROCESS SAMPLES
1,4-Dinitrob enzeneAcenaphthylene
Acenaphthene 4,6-Dinitro-o-cresol
2,4-DinitrophenolAcetoohenone
2,4-Dinitrotoluene
Anthracene 2,6- Dinitrotoluene
Di-n-octyl phthalateBenz(a)anthracene
DiphenvlamlneBenzo(bXluoranthene
Benzo(k)fluoranthene Fluoranthene
Benzo(g,h,i)perylene Fluorene
Benzo(a)pyrene Hexachlorobenzene
Hexachlorobutadiene4-Bromophenyl phenyl ether
Butyl benzyl phthalate Hexachl oro cycl op entadi ene
p-Chloroaniline
Chlorobenzilate Indeno( 1,2,3-c,d) pyrene
NanhthaleneB i s (2 -Chl oro ethoxy)methane
B i s (2 - Chl oro ethyl) ether 2-Naphthylamine
2-NitroanilineB i s (2-Chloroisopropyl) ether
4 - Chl oro - 3 -methylpheno I 4-Nitroaniline
Nitrobenzene2-Chloronaphthalene
2-Chlorophenol 2-Nitrophenol
4-Nitroohenol
o-Cresol Pentachlorobenzene
m-Cresol Pentachloroethane
-Cresol P entachl oronitrobenzene
PentachlorophenolD i b e n z(a,h)anthr ac e n e
m-Dichlorobenzene Phenanthrene
o-Dichlorobenzene Phenol
Pyrenep-Dichlorobenzene
2,4-Dichlorophenol I ,2,4,5 -Tetrachloroben zerne
2,1-Dichlorophenol 2,3,4,6 -Tetrachloropheno I
Diethyl phthalate 1,2,4 -Tri chl orobe nzene
Z, -Dimethyl phenol 2,4,5 -Trichlorophenol
Dimethyl phthalate 2,4,6 -Trichl oropheno I
Di-n-butyl phthalate
ATLIC STB TOCDF Analyte List.xls
SVOC List
IOCDF ATLIC STB
Section No.: 9.0
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9.1.5 Surrogate Mixture Characterization Methods
Surrogate mixture samples collected are evaluated for chlorobenzene and tetrachloroethene. The
samples are prepared for chlorobenzene and tetrachloroethene analyses using SW-846, Method
3585. Sample aliquots are weighed and then diluted with n-hexadecane or other appropriate
solvent to a known volume. The diluted samples are analyzed by direct injection of an
appropriate aliquot into a GC/IUS setup for analyses in accordance with SW-846, Method 82608.
The compounds present are quantitated against internal standards.
9.2 ANALYSIS METHODS FOR EXHAUST GAS SAMPLES
9.2.1 Analysis of SMVOC Tubes
The samples collected from each SMVOC set will consist of two Tenax@ tubes and an
Anasorb@-747 tube. The two Tenax@ tubes will be desorbed as one sample, and each
Anasorb@.747 tube will be analyzed as a separate sample. The tubes will be analyzed for VOCs
by thermal desorption and subsequent analysis by GC/MS, using Method 504.1A (1). The
organic compounds in the sample will be thermally desorbed into water using a carrier gas. The
desorbed compounds will then be purged from the water and collected on an analytical trap
containing Tenax@ and other GC-column packing materials. The compounds will be desorbed
off the trap into the GC/MS.
Selected compounds are spiked into various parts of the Method 5041A analysis apparatus, and
spiking locations are specified by Method 0031 (1). For Method 5041A, the following
compounds are specified:
Application
Surrogates
Internal Standards
LCS
MS/MSD for
Condensate Samples
Compounds
Dibromofluoromethane,
Bromofluorobenzene,
1,2-Dichloroethane-d+, and Toluene-dg
Bromochloromethane, Chlorob enzene-
d5, and 1,4-Difluorobenzene
1, 1 -Dichloroetheno, B enzene,
Chlorobenzene, Tetrachloroethene
Toluere, and Trichloroethene
1, 1 -Dichloroethene, B eruzene,
Chlor ob enzene, Tetrachloro ethene
Tolueno, and Trichloroethene
Spiking Location
Tenax@ tube
Purge Vessel
Tenax@ tube
Purge Vessel
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Sample breakthrough will be checked by analyzing the two Tenax@ tubes separately from the
Anasorb@-747 tube. Breakthrough will be defined as 30 percent or greatei on the Anasorb@-747
tube relative to the two Tenax@ tubes. This criterion will not apply if 75 ng or less is detected on
the Anasorb@-747 tube. The analysis results of the two Tenax@ tubes and the Anasorb@-747
tube will be summed for subsequent emission calculations.
The VOCs determined by Method 5041A (1) will be identified as Products of Incomplete
Combustion with the exception of chlorobenzene and tetrachloroethene.' Table A-9-5 is the
Target Analyte List for the VOCs. The method for analysis of the Tenax@ tubes is calibrated
with standards for the 56 compounds listed in Table A-9-5. The method of analysis for the
Anasorb@-747 ttbes is calibrated for the 31 compounds marked in Table A-9-5.
The compounds not analyzedon the Anasorb@- 747 ttbesare not quantitatively desorbed from
the Anasorb@-747 tubes. These compounds will be collected on the Tenax@ tubes. The final
VOC concentrations will be a summation of the analyses from the Tenax@ tube pairs, the
Anasorb@-747 itbes, and the condensate sample. The20largest additional peaks, with an area
at least 10 percent of the intemal standards, will be tentatively identified from each analyses
conducted and will be classified as TICs. Performance of this method will be evaluated using the
criteria listed in the QA/QC tables found in Annex A.
TOCDF ATLIC STB
Section No.: 9.0
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Revision Date: December 2,2010
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TABLE A-9-5. VOLATILE ORGANIC COMPOUND TARGET ANALYTE
LIST FOR METHOD 5041A
Acetone tr ans -1,z-Dichloroethene *
Benzene *\,z-Dichloropropane *
Bromobenzene 1 ,3-Dichloropropane
Bromochloromethane *2,z-Dichloropropane
Bromodichloromethane *1,1-Dichloropropene *
Bromoform cis -1,3 -Dichloropropene *
Bromomethane *trans -1,3 -Dichloropropene *
2-Butanone Ethylbenzene
Carbon disulfide *n-Hexane
Carbon tetrachloride *2-Hexanone
Chlorobenzene *Iodomethane
Chloroethane {<Methylene chloride *
Chloroform *4-Methyl-2-pentanone
Chloromethane *n-Propylbenzefie
z-Chloropropane *Styrene
Z-Chlorotoluene 1 , 1 , 1 ,2-T etrachloroethane
4-Chlorotoluene |,l,2,2 -T etrachloro ethane
Cumene Tetrachloroethene *
Dibromochloromethane Toluene *
1,z-Dibromoethane 1 , 1 , 1 -Trichloroethane*
Dibromomethane *1,I,}-Trichloroethane *
ci s - I,4 -Di chloro - 2 -butene Trichloroethene {<
tr an s - 1,4 -Di chloro -2 -butene Trichloro fluoromethane *
Dichlorodifluoromethane *I,2,3 -Trichloroprop ane
1,1-Dichloroethane {<1,I,2-Trichloro- 1,2,2-trtf\uoroethane *
1,z-Dichloroethane *Vinyl chloride *
1,1-Dichloroethene {<m,p-Xylene
cis -L,z-Dichloroethene *o-Xylene
* These compounds will be analyzed on the Anasorb@-747 tubes.
TOCDF ATLIC STB
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Revision oate: Deffiii"1l "l?
9.2.4 Anrlysis of Method 0010 Samples for SVOCs
The filter, XAD-2@ resin, impinger contents, and rinses will be extracted with methylene
chloride and evaporated to a known volume. The extracts will then be analyzedby Method
8270C (l). An aliquot of the extract is injected into a GCA4S. The column separates the
compounds, and the mass spectrometer detects the compounds as they elute from the column. A
mass spectrometer allows the sample compound's mass spectra to be compared to the spectra of
a standard compound for identification.
Surrogate and intemal standards are used to measure the performance of the sample preparation
and analyses. Spiking locations are specified by Method3542 (1). Surrogate standards for the
front-half sample are spiked onto the filter before the filter is placed in the extraction device.
The back-half surrogate standards are spiked onto the XAD-2 resin after the resin is placed in the
extraction device. The condensate samples surrogate standards are spiked into the samples after
they have been transferred to separatory funnels. lnternal standards are spiked into the sample
vial just before the samples are analyzed. For Method 8270C, the following standards are
specified:
Standards
Surrog ate Standards
Internal Standards
Compounds
2,4,6 - Tribromopheno l,
2-Fluorobiphenyl,
2 -Fluoropheno 1, Nitrob enzene-ds,
Phenol-ds, and Terphenyl-d1 a
1,4 -Dichlor ob enzene- d+, Naphthalene-ds,
Perylene-d1 2, Acenaphthene-dr o,
Phenanthrene-dr o, and Chrysene-d1 2
Method 8270C reports analyses for the 133 compounds listed in Table A-9-6. These compounds
are a tentative list of PICs. The 20 largest additional peaks, with an arca at least 10 percent of the
internal standards, will be tentatively identified and classified as TICs. Performance of the
method will be evaluated using the criteria listed in the QA/QC tables in Annex A.
TOCDF ATLIC STB
Section No.: 9.0
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Revision Date: December 2,2010
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TABLE A.9-6. SEMI.VOLATILE ORGANIC COMPOUND TARGET ANALYTE LIST
Acenaphthene 4-Bromophenyl phenyl ether
Acenaphthylene Butyl benzyl phthalate
Acetophenone 2 - sec -B utyl - 4,6 - dinitropheno I
2-Acetylaminofluorene 4-Chloroaniline
4-tuninobiphenyl Chlorobenzilate
3 -Amino-9-ethylc arbazole'4- Chloro - 3 -methylpheno I
Aniline 1-Chloronaphthalene
Anthracene 2-Chloronaphthalene
Aramite 2-Chlorophenol
Benzidine 4-Chlorophenyl phenyl ether
Benzoic acid Chrysene
Benz(a)anthracene 4-4'-DDE,
Benzo(bXluoranthene Diallate (cis or trans)
Benzofi)fluoranthene Dibenz(q)acridine
Benzo(k)fluoranthene D i b en z(a,h)anthr ac en e
Benzo(g,h,i)perylene Dibenzofuran
Benzo(a)pyrene 1,2 -Dibromo - 3 - chl oroprop ane
Benzo(e)pyrene Di-n-butyl phthalate
Benzyl alcohol | ,2-Dichlorobenzene
Benzaldehyde 1 ,3 -Dichlor obenzene
Benzenethiol u
1 ,4-Dichlorobenzene
Biphenyl 3,3' -D i chlorob enzi dine
B i s (2 - chloro ethoxy)m ethane 2,4-Dichlorophenol
B i s(2 - chloro ethyl)ether 2,6-Dichlorophenol
B i s (2 -chloroi sopropyl) ether Diethyl phthalate
B i s (2 - ethylhexyl)phthal ate Dihydrosafrole u
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TABLE A-9.6. SEMI.VOLATILE ORGANIC COMPOUND TARGET ANALYTE LIST
(continued)
p - (D imethyl amino) azob enzene Isophorone
7,1 2 -D tmethylb enz(a)anthrac ene Isosafrole
3,3' -D imethylb enzrdrn e Methoxychlor u
0,, CI,, -D im ethylphenethyl amine Methyl cyclohexane'
z,4-Dimethyl phenol 3-Methylcholanthrene
Dimethyl phthalate M ethyl methane sul fonate
1;3-Dinitrob enzene 2-Methylnaphthalene
4,6 -Dinitro - 2 -methylpheno I 2 -Methyl - 5 - nitro ani I in e
2,4-Dinitrophenol 2-Methylphenol
2,A-Dinitrotoluene 3-Methylphenol
2,6-Dinitrotoluene 4-Methylphenol
Dioxathion u Naphthalene
Diphenylamrne 1,4-Naphthoquinone
L,2 -D iphenylhydra ztne b 1-Naphthylamine
Di-n-octyl phthalate 2-Naphthylamine
Ethyl methanesul fonate 5-Nitroacenaphthene u
Ethyl parathion 2-Nitroaniline
Fluoranthene 3-Nitroaniline
Fluorene 4-Nitroaniline
Heptachlor u Nitrob enzene
Hexachlorob enzene 2-Nitrophenol
Hexachlorobutadiene 4-Nitrophenol
H ex achloro cyc I op entadi ene 4-Nitroquinoline- 1 -oxide
Hexachloroethane N-Nitro so dibutyl amrne
Hexachloropropene N-Nitro so di ethyl amine
Indeno( 1,2,3-cd)pyrene N-Nitro s o dimethyl amrne
r",:3[lftI:'ffi
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TABLE A.9.6. SEMI-VOLATILE ORGANIC COMPOUND TARGET ANALYTE LIST
(continued)
Response factor is based on the closest eluting internal standard with the compound identity confirmed by library searches.
Laboratory quantifies as diphenylamine. 1,2-diphenylhydrazine will be analyzed as azobenzene.
N-N itrosodiphenylamine decomposes to diphenylamine,
a
b
c
N-Nitro s omethyl ethyl amine Pronamide
N-Nitro sodiphenylamine'Pyrene
N-Nitro s o - di -n-propyl amine Pyridine
N-Nitrosomorpholine Quinoline'
N-Nitrosopiperidine Safrole
N-Nitrosopyrrolidine 1,2,4,S-Tetrachlorob enzene
I Pentachlorobenzene 2,3,4,6 -Tetrachloropheno I
I Pentachloroethane o-Toluidine
P ent achl o ro ni tro b eruzene p-Toluidine u
Pentachlorophenol Tributylamine u
Phenacetin 1,,2,4 -Tri chlorob e nzene
Phenanthrene 2,4,S-Tri chloropheno I
Phenol 2,4,6 - Tri chloropheno I
1 ,4-Phenylenediamine L,3,5 - Trinitrob e ruzene
2 -Picoline ( z-Methylpyridine)
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Revision Du,., S.t'r',:l;L)l;r, I
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9.2.2 Analysis of Method 0023A Samples for PCDDs/PCDFs
The filter, XAD-2@ resin, and the impinger rinses will be extracted with toluene and evaporated
to a known volume. Then, the extract will be subjected to a series of cleanup procedures to
remove interferences. The final extract will be analyzed for PCDDs/PCDFs using Methods
0023N8290 (1). An aliquot of the cleaned extract is injected into an HRGC/HRMS, and
quantitation is achieved by comparison to internal standards.
The Method 0023A train is recovered into four containers that are subsequently combined into
two fractions. Surrogates are spiked onto the XAD-2@ resin before the samples are collectod for
the back-half fraction, Surrogates for the front-half fraction are spiked onto the filter just before
the filter is placed in the extraction thimble. The front-half fraction internal standards are spiked
onto the filter after it has been placed in the extraction thimble. The back-half fraction internal
standards are spiked onto the XAD-2@ resin after the resin has been transferred to the extraction
device. Method 0023N8290 (1) specifies the following standards:
STANDARI)COMPOUNDS
Surrogate Standards
t'c\o-2,3,7 ,8-TCDD,
"c n-\,2,3,4,7,8-HxcDD,
''C tz-Z,3,4,7, 8-PeCDF,
"c n-\,2,3,4,7, 8-HxcDF,''c n-\,2,3,4,J, 8,g-HpcDF
Internal Standards
''c n-2,3,7,8-TCDD, "c n-| ,2,3,7,}-PecDD,
''c n-\,2,3,6,7, S-HxcDD,
"c n-\,2,3,4,6,7,8-HpcDD,''c r z-ocDD,
"c n-2,3,7,8-TCDF,
"c n-\,2,3,7,8-PecDF, "c n-\,2,3,6,7,8-HxcDF,
"c n-\,2,3,4,6,7, 8-HpcDF
Table A-9-7 shows the target analyte list for this method. Performance of the method will be
evaluated using the criteria listed in the QA/QC tables found in Annex A.
TOCDF ATLIC STB
Section No.: 9.0
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Revision Date: Decemb er 2, 2010
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TABLE A-9-7, PCDD/PCDF TARGET ANALYTE LIST
H#tr,$.ffffiiilr
2,3,7,8-TCDD 2,3,7,8-TCDF
Total TCDDs Total TCDFs
L,2,3,7,8-PeCDD 1,2,3,7,8-PeCDF
Total PeCDDs 2,3,4,7,8-PeCDF
L 1213 14,7,8-HxCDD Total PeCDFs
l,2r3 1617 ,8-HxCDD I,2r3,4,7 ,8-HxCDF
1r2r3 r7 ,8,9-HXCDD 1,2r3,617 ,8-HXCDF
Total HxCDDs 2,3,4,6,7,8-HXCDF
L,2,3,4,6,7 ,8-HpCDD I,2,3,7,8,9-HxCDF
Total HpCDDs Total HxCDFs
Octachloro dib enzo -p - dio xin 1,2,3,4,6,7 ,8-HpCDF
I,2,3,4,7 ,8,9-HpCDF
Total HpCDFs
Octachloro dib enzo furan
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Revision Date: Decemb er 2, 2010
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9.2.3 Analysis of Metals Emissions
The Method 29 samples will be analyzed for the HHRA metals and are listed in Table A-9-8.
The samples will be prepared as described in Method29 (6). Mercury will be analyzedby
CVAAS using Method7470A. The remaining elements will be analyzed by ICP/I\{S using SW-
846, Method6020 (1), which was modified by adding tin and vanadium to the analyte list.
o SW-846 Method 7470A (liquids) - Manual Cold-Vapor Atomic Absorption Technique.
A representative portion of the sample is digested with acids, potassium permanganate,
and potassium persulfate. Mercury ions are reduced to metallic mercury and stripped
from the aqueous solution with a gas stream. The mercury vapors are then directed into
the path of an atomic absorption spectrometer. Quantitation is achieved by comparison of
sample component responses to the responses of extemal standards.
o SW-846 Method 6020 - ICP/I4S. Metals concentrations in the Method 29 samples will
be determined by ICPA4S (the most recent version of the method). A representative
portion of the sample is digested with nitric acid and the sample digest is aspirated into
the nebulizer of the ICP/MS. The sample mist enters the plasma, the plasma converts the
sample to an atomic vapor, and the mass spectrometer separates the elements by mass.
The masses detected are used to quantitate the elements present. Quantitation is achieved
by comparison of sample responses to the responses of internal standards.
Performance of the method will be evaluated using the criteria listed in the QA/QC tables found
in Annex A.
9.2.4 Analysis of Halogen Emissions
The analysis of HCl, and Clz in the exhaust gas impinger samples will be performed by IC using
Method 9057 (1). This method separates the anions by ion chromatography and the eluting
anions are detected. The HCI emissions are determined from the analysis of the sulfuric acid
impingers, and Clz emissions are determined from the analysis of the NaOH impingers using IC.
Concentrations are calculated based on external calibration standards. Performance of the
method will be evaluated using the criteria listed in the QA/QC tables found in Annex A.
9.2.5 Particulate Matter Analysis
The probe rinse and the filter of the combined Method 5126A (6) train will be used to determine
the PM concentrations. The probe rinse and filter will be dried and desiccated to a constant
weight as directed in Method 5 (6).
TOCDF ATLIC STB
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Revision No.: I
Revision Date: December 2,2010
Page No.: l8
TABLE A-9-8. METHOD 29 TARGET ANALYTE LIST
Aluminum Lead
Antimony Manganese
Arsenic Mercury
Barium Nickel
Beryllium Selenium
Boron Silver
Cadmium Thallium
Chromium .Tin
Cobalt Vanadium
Copper Zinc
TOCDF ATLIC STBt'fl;l,Y*"
,'o ?
Revision Date: Decembeil.lrr?
10.0 SPECIFIC LABORATORY QUALITY CONTROL CHECKS
The QC checks are performed to ensure the collection of representative samples and the
generation of valid analytical results on these samples. The project participants will perform QC
checks throughout the program. The laboratories will utilize EPA-approved analytical methods
for those analyes that have methods available. The QC samples analyzedwill include method
blanks, duplicate samples, LCS, and MS/I\4SD. Table A-9-2lists the field blanks to be collected.
Reagents used in the laboratory are normally of analytical reagent grade, or higher, purity; each
lot of acid or solvent used is checked for acceptability prior to laboratory use. All reagents are
labeled with the date received and the date opened. The quality of the laboratory DI water is
routinely checked. The glassware used in the sampling and analysis procedures are pre-cleaned
according to the method requirements. Standard laboratory practices for laboratory cleanliness,
personnel training, and other general requirements will be used, and the results of these QC
procedures will be included in the final report.
10.1 METHOD BLANKS
Method blanks contain all the reagents used in the preparation and analysis of samples and are
processed through the entire analytical scheme to assess any spurious contamination that might
arise from reagents, glassware, and other sources. The QC criteria for method blanks are shown
in Annex A by individual method.
10.2 LABORATORY CONTROL SAMPLES
The LCSs are samples generated from analyte spikes into a neutral matrix prepared
independently from the calibration concentrates. The LCS is used to establish that an instrument
or procedure is in control. An LCS is normally carried through the entire sample preparation and
analysis procedure. The QC criteria for the LCSs are listed in Annex A by analysis method.
IO.3 DUPLICATE ANALYSES
Duplicate sample analysis will be used to evaluate the variance in a particular applied analytical
method. Field duplicate samples will be collected for the surrogate mixture, scrubber liquor, and
phosphoric acid solutions samples during one performance run. Samples analyzedby CVAAS
will be analyzed in duplicate as specified in the methdil. Duplicate analyses will be performed
on the halogen samples analyzedby IC. One of the metals emission samples will also be
analyzed in duplicate as a measure of the precision of the analysis method.
IOCDF ATLIC STB
Section No.: 10.0
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Revision Date: December 2,2010
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10.4 MATRIX SPIKE SAMPLES
Matrix spikes are samples spiked with the analyte of interest and then aralyzed to determine a
%R. It is anticipated that these analyses would assess the behavior of actual analyses in
individual program samples during the entire preparative and analysis scheme. Matrix spike
analysis will be conducted to evaluate accuracy and general matrix recovery. An MSA{SD will
be prepared from the process water, scrubber liquor, and baghouse residue samples. The QC
criteria for %R and RPD are shown in Annex A for each method.
10.5 SURROGATE SPIKES
Surrogate spikes will be used for GC/MS analysis methods as an indicator of the general
accuracy of sample preparation and analysis. The QC criteria for surrogate spike recoveries are
listed in Annex A by analysis method. The following surrogate compounds will be used for
VOC analyses: toluene-ds, bromofluorobenzene; and 1,2-dichloroethane-d+. The following
surrogate compounds will be used for analysis of SVOCs: nitrobenzene-d5, fluorobiphenyl;
terphenyl-dr+;phenol-d6; 2-fluorophenol; and2,4,6-tibromophenol. Surrogate spikes will also
be used for Method 8290 for PCDDiPCDF analyses.
10.6 ANALYTICAL INSTRUMENT CALIBRATION
The analytical instrumentation used in the laboratory for analysis of ATLIC STB samples will
undergo several performance checks. An initial calibration curve will be analyzed before
performing any samples analyses to compare linearity of response to concentration of known
amounts of the analytes of interest. The initial calibration for some methods will use a calculated
Correlation Coefficient (CC) to demonstrate acceptability of the calibration. On a daily basis, a
continuing calibration check will be analyzedbefore any samples are mn for that day. If
acceptance criteria (as specified in the appropriate analytical methods for initial or continuing
calibrations) are not met, sample analysis will not proceed until the analytical problem has been
rectified and the criteria have been met. Linearity checks will be used to verify that response has
not shifted significantly from the most recent calibration. Some methods will use an Initial
Calibration Verification (ICV) to demonstrate that the calibration was accurate, and Continuing
Calibration Verification (CCV) will be used to ensure that the calibration is still representative.
A summary of the calibration procedures and frequency for the laboratory instruments to be used
for this project is provided in Table A-10-1. The instrument initial calibration procedures and
acceptance criteria will be those established in the analytical method and listed in Annex A.
lnternal standards will be analyzedto evaluate instrument and method performance. The QC
criteria for the internal standards are listed in Annex A by analysis method.
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TOCDF ATLIC STB
"ilTLY*"," ?
Revision r"., o*ff;;.*1.10,
?
11.0 DATA REPORTING, DATA REVIEW, AND DATA REDUCTION
Reporting the data generated during an STB is an important part of the overall project. This
section describes and discusses the components of reporting, reviewing, and reducing the
collected STB data.
11.I DATA REPORTING
The data reporting process will discuss the analytical datapackages, the data generated for this
STB, and the final ATLIC STB Report.
11.1.1 Analytical Data Packages
Data reported from commercial laboratories is required to be similar to the format used by the
EPA Contract Laboratory Program (CLP). This format includes a case narrative section,
Analytical Data Summary Sheets, QC Sample Results, the COC forms, and raw data organized
by analytical method. Complete data packages are included so that an independent verification
of the final analyical results can be conducted. These data packages are stand-alone deliverables
that include the instrument raw data, parameter-specific QC documentation, calibration and
calibration check performance, and instrumentation performance information.
The case narrative will:
. Describe the data package and identify project-specific information.
. Discuss any pertinent information concerning data quality and any difficulties or
analytical anomalies encountered in the analyses.
. Provide a cross-reference listing of the field sample and laboratory sample identities.
. Discuss information on achieving DQOs or project-specific objectives.
The Anallical Data Summary Sheets will contain a summary of the analyical results and the key
QC data. A separate sheet will be provided with the results for each sample. These data will
include the results, recovery of any surrogate materials, date sampled, and analysis date, which
will allow confirmation of meeting the QC and holding time requirements. Summary sheets for
the analysis of the QC samples will follow the sample results sheets.
Copies of the COC forms are also apart of the data package. These copies are submitted with
the samples and copies of any intemal COC forms used to track the samples through the different
analyses in the laboratory.
TOCDF ATLIC STB
'",illl,Y*"," ?
Revision Date: Decemberri.r, !
Raw data will be included in the Analytical Data Packages. This raw data will include
chromatograms for those methods generating them, blank data, sample preparation sheets, copies
of sequence files, and calibration data. The raw data will be organized by analysis method, and
enough data will be supplied to allow recreation of the sample analysis event.
ll.l.2 Analytical Data Format
The data that will be reported as "not detected" will use the LOQ for the lower reporting limit.
Analytes detected with a concentration between the MDL and the LOQ will be qualified as an
estimate and reported. The LOQ is the same as the reporting limit used by some laboratories.
The LOQ will be defined as the quantitation level that corresponds to the lowest level at which
the entire analytical system gives reliable signals and an acceptable calibration point or low-level
matrix spike. Each compound or element is assigned an LOQ that is contingent upon the
behavior of the compound or element during analysis. Changes to extraction protocol, amount of
sample prepared, or dilution applied to the sample can raise or lower the LOQ.
The analytical results for PCDDs/PCDFs are quantitated differently. They are quantitated using
an isotope dilution method. Each sample is spiked with an isotopically-labeled surrogate for
each target compound. On a sample-by-sample basis, the recovery of each surrogate is
determined; then, the analytical result is normalized to the recovqry of the corresponding
surrogate compound. In this manner, the LOQ for each sample and each compound can vary as
the surrogate recovery varies. This isotope dilution method is considered to be the most accurate
quantitation method available for these analyses.
Sample analysis results will be reported by the laboratory in matrix-specific units. Results will
be reported for all samples and parameters required for this STB, as listed in Table A-9-1. The
laboratory will assign qualifiers to the results, when necessary, based on guidelines found in the
analytical method, CLP, or in this QAPP. Qualifiers appearing on the anallical summary sheets
are defined on that specific sheet. Data presented in tables in the ATLIC STB Report will note
arry data qualifiers.
11.1.3 ATLIC STB Report
An ATLIC STB Report will be prepared and submitted to the DAQ and DSHW. EG&G will
complete the STB report as outlined in Section 8.0 of the STB plan. The report will compare the
STB results to the RCRA Permit, Title V Permit, and MACT limits.
The ATLIC STB Report will also contain:
Daily run summaries.
A summary of incinerator operating parameter data and associated limits.
TOCDF ATLIC STB
Section No.: 1 1.0
Revision No.: I
Revision Date: December 2,2010
Page No.: 3
A summary of sampling and analytical methods used and any deviations from.referenced
methods.
Analysis results, protocols, and quantitative gas analyses.
CEMS data emission averages and calculations.
A compilation and evaluation of analytical calibration data and QA/QC data, and
identification of problems encountered and the solutions implemented.
Copies of calibration data, chromatograms, and other raw data.
Audit cylinder results calculated in parts per billion (ppb).
Examples of all calculations, sampling train data, concentrations, and emission rates for
all gases and particulate samples collected.
A QA/QC Report will be submitted to the EG&G CAR and included in the ATLIC STB Report
as an appendix. Additionally, each formal data deliverable will contain a summary of QAiQC
activities. This summary will include:
Estimates of precision, accuracy, and completeness of reported data.
Reports of performance and system audits.
Any quality problems found.
Any corrective actions taken.
11.2 DATA REVIEW
The STC will review the field sampling data to determine the representativeness of the samples;
maintenance and cleanliness of sampling equipment; and the adherence to the approved, written
sample collection procedure. All field data will be recorded on prepared forms, and the data
sheets will be reviewed at the end of each run by the STC and the Sampling Subcontractor QA
Officer to ensure that each sheet is properly completed. The gas sampling data will be reduced
on-site to verify isokinetic sampling rates. Furthernore, the sampling subcontractor's software
for determining sample volumes and isokinetic sampling rates will be checked for accuracy
against an independent program, and any differences resolved before inclusion in the final report.
The analyst generating the data will review the laboratory data; then, the analyst's supervisor will
review the data. The laboratory QC personnel will further review the data per the laboratory
TOCDF ATLIC STB
Section No.: I 1.0
Revision r",., fill'#ollri ro, I
Page No.: 4
procedure before the project report is prepared by the Subcontractor Laboratory Project Manager.
When the analytical data are submitted to the sampling subcontractor, the data will again be
reviewed before it is used to prepare the ATLIC STB Report. This review process will confirm
that the data are usable for an assessment of incinerator performance.
ll.2.l Data Validation
Data validation is the process of accepting or rejecting data on the basis of established criteria.
Analytical and sampling data will be validated by the STB subcontractor QC personnel using
criteria outlined in this QAPP. The subcontractor QC personnel will use validation methods and
criteria appropriate to the type of data, even data judged to be "outlying" or of spurious value.
The persons validating the data will have sufficient knowledge (i.e., at least one year of
experience in data validation) of the sampling and analytical methods to identiff questionable
values and deviations from criteria specified in the methods and the QAPP.
The results from the field and laboratory method blanks, replicate samples, and internal QC
samples will be used to further validate analytical results. Anallical results on the field blanks
and replicate samples also are valuable for validation of sample collection. The QA/QC
personnel will review all laboratory and sampling raw data to verify: calculated results
presented, consistency, duplicate sample analysis, spike recoveries, tests for outliers, and
transmittal errors.
The criteria that will be used to evaluate the field sampling data include:
. LJse ofapproved test procedures.
. Proper operation of the process being tested.
. IJse of properly operating and calibrated equipment.
. IJse of proper forms for recordingdata, including identification numbers for each nozzle,
probe, and dry gas meter.
. Leak checks conducted before tests, during port changes, and after tests.
. Use of reagents that conform to QC-specified criteria.
. Maintenance of proper traceability.
TOCDF ATLIC STB
Section No.: I 1.0
Revision No.: I
Revision Date: Decemb er 2,201 0
Page No.: 5
The criteria used to evaluate analytical data include:
Use of approved analytical procedures.
Use of properly operating and calibrated instrumentation.
Precision and accuracy comparable to that achieved in previous analytical programs and
consistent with the DQOs listed in Annex A.
See Section 10.0 for the anticipated minimum number of QC samples. The %R of each matrix
will be calculated as shown in Section 13.0. lnorganic data will be evaluated using the general
methods outlined in the EPA CLP guidelines for inorganic data (12) using the criteria from
Annex A. The organic data will be evaluated using the general methods outline in the EPA CLP
guidelines for low level organic data (13). The PCDD/PCDF data will be evaluated using the
general methods outlined in the EPA guidelines for dioxin data (14). These evaluations will be
included in the QA report, which will be an appendix to the final report.
11.2.2 Identification and Treatment of Outliers
Any point that deviates from others in its set of measurements will be investigated; however, the
suspected outlier will be recorded and retained in the data while it is under investigation. One or
both of the following tests will be used to identify outliers:
Dixon's test for extreme observations, which is a computed procedure for determining
whether a single, very large or very small value is consistent with the data set.
The one-tailed t-test for difference.
If more than one outlier is suspected in the same data set, other statistical sources will be
consulted, and the most appropriate test of the hypothesis will be used and documented.
Those persons involved in the analysis and data reduction will be consulted if a data outlier is
suspected, as they may be able to add some insight to the evaluation of the suspect data. This
evaluation may provide an experimental basis for the outlier to determine its affect on the
conclusions. Two data sets may be reported - one including and one excluding the outlier.
11.3 DATA REDUCTION
Specific QC measures will be used to ensure the generation of reliable data from sampling and
analysis activities. Proper collection and organization of accurate information, followed by clear
and concise reporting of the data, is a primary goal in all projects.
l?:ffiffi:','?ffi
Revision No.: I
Revision Date: Decemb er 2, 2010
Page No.: 6
11.3.1 Field Data Reduction
Annex B contains the standardized data sheets that are representative of those used to record gas
sampling data. Raw sampling data will be reduced on a daily basis and will be reviewed in the
field by the STC and the sampling team leader. Isokinetic sampling rates and sample volumes
will be reported daily. Any errors or discrepancies will be noted in a field notebook. The
sampling team leader has the authority to institute corrective actions in the field, and the STC
will also be consulted for resolution if the situation warrants. At a minimum, the Sampling
Subcontractor QA Officer and the EG&G CAR will be apprised of all deviations from the
standard protocol.
11,3,2 Laboratory Analysis Data Reduction
Analytical results will be reduced to concentration units specified by the analytical procedure and
using the equations given in the analytical procedures. Results will be reported on an as received
basis. If the units are not specified, then units for data will be used as follows:
Liquid samples will be reported in milligrams per liter (mg/L).
Surrogate mixture sample results will be reported in weight percent (Wt%) for the organic
compounds and milligrams per kilogram (mg/kg) for the metals results.
Gas samples will be reported on a mass per dry standard cubic unit of measure except for
the halogen emissions and results from the CEMS, which are reported in parts per million
(ppm).
Oxygen and carbon dioxide data will be reported in volume percent.
Audit cylinder analysis results will be reported in parts per billion (ppb).
11.3.3 Blank Corrected Data
Results from the metals emissions train will be blank corrected as instructed in Method 29 (6). A
separate blank correction will be made for the front half and the back half. The raw data will
also be reported. The other data developed for this STB will not be blank corrected.
TOCDF ATLIC STB
"fl;,:,Y,*"," ?
Revision Date: December 2,2010
Page No.: 7
11.4 EXHAUST GAS SAMPLE TRAIN TOTAL CALCULATIONS
The calculation of the train total of an analyte is the sum of two or more fractions of train
components. Analyes not detected in the analysis will be reported as < LOQ. Analytes with
concentrations between the MDL and the LOQ will be qualified as estimated and reported. The
summation for the total will use the T.OQ value for those analytes not detected and the reported'
values for those analytes detected, including values between the MDL and LOQ. Totals
including LOQ and qualified data will have a "4" flBB added to the reported total. When the
analye is not detected in any of the fractions, the LOQ value for each fraction will be summed
for the total, and the results flagged with an 'ND" to indicate the analyte was not detected.
Calculations will be carried out to at least one decimal place beyond that of the acquired data and
should be rounded, after final calculations, to three significant figures for each analye for a train
total. Rounding of numbers should conform to procedures found in ASTM SI-10 (15).
ll.4.l Calculation of Chlorobenzene Emissions and DRE
Chlorobenzene is a HAP that was chosen to be the surrogate for organic compounds fed to the
PCC because it is a Class 1 compound in the EPA's thermal stability ranking system.
Chlorobenzene is also a VOC that is identified in the emissions of incinerators. The calculations
of the chlorobenzene emissions are shown here as an example calculation for VOC emissions.
The chlorobenzene emissions are calculated from the example data shown in Table A-1 1-1.
TABLE A-11-1. CHLOROBENZENE EMISSIONS CALCULATION DATA
*dsl- - dry standard liter
TOCDF ATLIC STB
Section No.: l l.0
Revision r.,., }ilI'##Irl ru I
Page No.: 8
The chlorobenzene concentration is calculated from the Train Total of chlorobenzene collected
and the Sample Volume using the equation:
Conc., pgldscm : (< 234 ng/79.1 dsl,) X (1 pgll000 ng) X (1000 dsl/dscm) : < 2.96 pgldscm
The chlorobenzene ER is calculated from the chlorobenzene concentration and the exhaust gas
flow rate using the equation:
ER : Conc., pgldscm X Exhaust Gas Flow Rate
ER, g/sec : (<2.96 pgldscm )(934 dscflmin) X (1 mir/60 sec) X (1 dscm/3s.3147 dscf) X
(1 g/10 6 pg): < 1.305 X 10{ g/sec
ER, lb/hr: (<1.305X10-6g/sec)X(3600sec/hr)X0b/453.59g): <1.03X10-5lbihr
Where:Exhaust Gas Flow Rate - 934 dscf/min
Determine DRE:
x r00% ->99.9999936%
160 lb/hr
TOCDF ATLIC STB
t'JlT;,Y..","
?
Revision Date: Decembell.r,
?
12.0 ROUTINE MAINTENANCE PROCEDURES AND SCHEDULES
The sampling subcontractor will follow an orderly program of positive action to prevent the
failure of equipment or instruments during use. This preventative maintenance and careful
calibration helps to ensure accurate measurements from field and laboratory instruments.
All equipment that is scheduled for field use will be cleaned and checked prior to calibration.
Once the equipment has been calibrated, sample trains are assembled and leak checked to reduce
problems in the field. An adequate supply of spare parts will be available in the field to
minimize any downtime caused by equipment failure.
The TOCDF CEMS are operated and maintained in accordance with Attachment 20 to the
TOCDF RCRA Permit (5). Maintenance is performed on a regularly scheduled basis prior to use
in the field and includes, but is not limited to, purging of sample lines, checking pump oil and
belts, cleaning rotometers or other sample flow monitoring devices, and checking sample
capillaries and mirrors. Routine maintenance procedures are critical for ensuring the continuous,
trouble-free operation of the CEMS in adverse environments.
The sampling subcontractor will maintain their CEMS in accordance with the specific methods
and manufacturer specifications. Sample lines will be inspected daily to ensure no leaks or other
problems occur. The subcontractor laboratories will maintain their instrumentation in
accordance with the instrument manufacturer specifications and appropriate methods. In
addition, the laboratories will maintain a stock of replacement parts to minimize downtime
resulting from foreseeable breakage or typical consumption.
TOCDF ATLIC STB
t?il',"1,Y*".,"
?
Revision Date: December 2,2010
Page No.: I
13.0 ASSESSMENT PROCEDURES F'OR ACCURACY,
PRECISION, AND COMPLETENESS
The QA/QC criteria for the analyses of samples for this project are presented in Annex A.
Annex A contains criteria for method calibrations, data accuracy, and precision of data. Each
method has a set of criteria to meet, and the methods of calculating the evaluation criteria are
discussed in this section.
13.1 PRECISION
Precision is defined as the degree of mutual agreement among individual measurements made
under prescribed conditions. Precision will use two different measurements depending on the
number of data points being considered. Two data points will have the RPD calculated; three or
more data points will use the RSD as a measure of the precision. Criteria for precision for each
method have been included in Arurex A.
Precision will be calculated for laboratory duplicate analysis using the following two equations:
1) RPD - [(Xr -xz)l((xt *Xz)tz))x 100
Where: RPD - Relative Percent Difference
Xr - Highest Analytical Result
Xz - Lowest Analytical Result
2) RSD: (standard deviation/average value) x 100
Calculation of the precision for each analysis will be based on different criteria taken from the
QA/QC Handbook ( ) and the analytical methods. The precision for the halogen samples will be
determined by the RPD calculated from the analysis of the MS/MSD. The MS/MSD will be used
because the field samples have a history of very low concentrations. The precision of the
SMVOC samples will be based on the RSD calculated from the analysis of the LCS, and the
results of the LCS analyses will be used because of the historically low concentrations found in
field samples. Precision for the metals emission samples will be based on the RPD of the LCS
and duplicate analyses of one emission sample. Precision data for metals in the process samples
will be based on analyses of MS/IVISD and duplicate samples.
1T,',"1ffi:''?l:
Revision No.: I
Revision Date: December 2,2010
Page No.: 2
13.2 ACCURACY
Accuracy is the degree of agreement between a measurement and an accepted reference or true
value. The accuracy of the ATLIC STB data will be determined from analysis of samples spiked
with a known concentration. The number of spiked samples and the spiking levels willbe
designated by the respective methods. Accuracy DQOs for each method are in Arurex A.
The formula used to assess the accuracy of the LCS is:
%R - (Q,-cs /Qrc) X 100
Qrc - Known Concentration of the LCS
The formula used to assess the accvracy of the MS/MSD samples is:
%R : [(Q,, - Q,,)/Q,] x 100
Where: %R : Percent Recovery
Q,, : Quantity of Analyte Found in the Spike Sample
Q,, : Quantity of Analle Found in the Unspiked Sample
Q, = Quantity of Added Spike
Calculation of the accuracy for each analysis will be based on different criteria taken from the
QA/QC Handbook (a) and the anallical methods. Determination of accuracy for samples will
be determined by the:
. o/oR calculated from the analysis of the MS/MSD for the halogen samples.
. oZR calculated from the analysis of the LCS for the SMVOC samples.
. Analysis of the LCS for the accuracy of the metals emission samples.
. Analysis of the LCS for the PCDD/PCDF samples.
. o/oR from the analysis of the LCS and MSA4SD for the SVOC analyses in the process
samples (scrubber liquor, process water, and baghouse residue).
I
rOCDF ATLIC STB
Section No.: 13.0
Revision No.: 1
Revision Date: Decemb er 2,20 I 0
Page No.: 3
13.3 COMPLETENESS
Completeness is defined as the amount of valid data for an STB compared to the amount that was
expected to be obtained under optimal conditions. The completeness objective here is to have
100 percent of the data valid for three performance nrns for each STB (i.e., acceptable results
must be obtained for three performance runs). The completeness objective for the entire
monitoring project is to obtain a certain amount of data needed to complete the statistical design
[see QA/QC Handbook (4)].
Completeness will be reported as the percentage of all measurements judged to be valid, and
every attempt will be made to ensure that the data to be generated is valid. If data appear
questionable based on circumstances observed during the field sampling, additional runs will be
completed as soon as the system can be reset to ensure three successful performance runs are
completed. Furthermore, in reality, some samples may be lost in laboratory accidents, and some
results may be qualified based on laboratory QC procedures.
The following formula will be used to calculate a percent completeness:
Where: C- PercentCompleteness
V - Number of Measurements Judged Valid
T - Total Number of Planned Measurements
TOCDF ATLIC STB
Section No.: 14.0
Revision o",., l!l'##)] ro, I
Page No.: I
14.0 AUDIT PROCEDURES, CORRECTM ACTION,
AND QUALITY ASSURANCE REPORTING
The ATLIC STB QA program will comply with EPA and state requirements for audits, which
include performance and system audits as independent checks on the quality of data obtained
from sampling, analysis, and data gathering activities. The procedures and techniques in place
will ensure that the audit is representative of the measurement processes during normal
operations. Either tlpe of these two audits may show the need for corrective action.
14.1 PERFORMANCE AUDITS
A performance audit checks the performance or accluracy of the measurements being made. The
sampling and analysis segments of the project are checked in a performance audit. Sampling
performance audits will be accomplished through observation of the sampling operations by the
regulatory agency representative and the Sampling Subcontractor QA Officer. For this purpose,
an audit cylinder or spiked audit samples may be supplied by the DAQ or DSHW during the
ATLIC STB. In the event an audit cylinder is supplied, it will be sampled and analyzed in the
same manner as the field samples. If a spiked sample is supplied, it will be extracted and
analyzed according to the same methods used for the field samples.
14.2 SYSTEM AUDITS
A system audit involves observations by a subcontractor or regulatory agency to ascertain that the
work is being performed in accordance with the methods specified in this QAPP.
14.2.1 Field Audit
The Sampling Subcontractor QA Officer will observe all activities to ensure that the QAPP is
being followed and that sample COCs are accurate before sample shipment. The Sampling
Subcontractor QA Officer will report any discrepancies to the STC, complete an STB QA
checklist, maintain a log of discrepancies for the STC and the QA Director, and attend
performance run meetings.
Representatives from the DAQ and DSHW are expected to be on-site to observe all sampling
activities. The point of contact for federal and state environmental regulatory agencies staff
during the ATLIC STB will be the Test Director or his designee.
';i:l,"lffiY'i;.t
Revision r.,., flll'##Irl ro, I
Page No.: 2
During each performance run, the sampling subcontractor performs a system audit, which
consists of an inspection and review of the total sampling system, including:
Setting up a pretest leak check of the sampling trains.
Isokinetic sampling check (if required).
Final leak checks of the sampling train.
Sample recovery.
Results of the leak checks are noted on the field data sheets while the remaining item checks are
documented on the audit checklist. When necessary, audit samples are analyzed along with the
test samples.
14.2.2 Laboratory Audit
The Test Director will direct that an audit of each laboratory be conducted to ascertain that work
is performed in accordance with the methods specified in the QAPP. Auditors will be selected
from the EG&G Environmental organization, TOCDF QC Inspectors, or the sampling
subcontractor's QC team.
14.3 CORRECTIVE ACTION
The need for corrective action will occur when a circumstance arises that adversely affects the
quality of the data output. In most instances, the personnel conducting the field work and the
laboratory analysis are in the best position to recognize problems that will affect data quality.
Awareness on their part can detect minor instrument changes, drifts, or malfunctions that can
then be corrected, thus preventing a major breakdown of the system. They will be in the best
position to decide upon the proper corrective action and to initiate it immediately, thus
minimizing data loss. Therefore, the field sampling and laboratory analysis persorurel will have
the prime responsibility for recognizing the need for a nonconformance report. The personnel
identifying or originating a nonconformance report will document each nonconformance. For
this purpose, a variance log, a testing procedure record, a notice of equipment calibration failure,
results of laboratory analysis QC tests, an audit report, an internal memorandum, or a letter will
be used, as appropriate.
(3)
(4)
(1)
(2)
(s)
(8)
(e)
IOCDF ATLIC STB
Section No.: I 5.0
Revision No.: I
Revision Date: Decemb er 2, 2010
Page No.: I
15.0 REF'ERENCES
Test Methodsfor Evaluating Solid lYaste, Physical/Chemical Methods,3'd Edition
including Update IV, USEPA, SW-846, February 2007.
Hazardous Waste Combustion Unit Permitting Manual, Component 2,"How to
Review A Quality Assurance Project Plan," U.S. EPA Region 6, Center for Combustion
Science and Engineering, January 1998.
EPA Guidance for Quality Assurance Project Plans, EPA QA/G-5, December 2002.
Handbook: Quality Assurance/Quality Control (QA/QC) Procedures for Hazardous
Waste In cin eratio n, EP N 625 I 6-89 / 023, January 1 990.
Attachment2D to the TOCDF RCRA Permit, CEMS Monitoring Plan, EG&G
Defense Materials, Inc., TOCDF, CDRL-06.
Title 40, Code of Federal Regulations, Part 60, Appendix A, "Test Methods."
ASTM D 3370,1995 (Reapproved 1999), "Standard Practices for Sampling Water from
Closed Conduits," ASTM International, West Conshohocken, Pennsylvania.
ASTM D 5633 ,2004, (Reapproved 2008), "Standard Practices for Sampling with a
Scoop," ASTM International, West Conshohocken, Pennsylvania.
Attachment 6 to the TOCDF RCRA Permit, Instrument Calibration Plan, EG&G
Defense Materials, lnc., TOCDF.
(6)
(7)
(10) Qualtty Assurance Handbookfor Air Pollution Measurement Systems; Volume III -
S tatio nary S o ur ce S p e cift c M etho ds, EPA-600/4 -7 7 -027b.
(11) Method 2540 Solid s, Standard Methods for the Examination of Water and Wastewater,
Edition 20,2005, American Public Health Association.
(12) aSEPA Contract Laboratory Program National Functional Guidelines for Inorganic
Review, EPA-540-R-04-004, October 2004.
(13) USEPA Contract Laboratory Program National Functional Guidelinesfor Low
C oncentration Organic D ata Review, EP A-5 40-R-00-006, June 2001.
TOCDF ATLIC STB
Section No.: 15.0
Revision r",,, Iill'-ilIrl ;0, i
Page No.: 2
(14) USEPA Analytical Operations/Data Quality Center National Functional Guidelines
for Chlorinated Dioxin/Furan Data Review, EPA-540-R-02-003, August 2002.
(15) ASTM SI-10, 2010, "American National Standard for Use of the Intemational System of
Units (SI): The Modem Metric System," ASTM Intemational, West Conshohocken,
Pennsylvania.
)p
rD
X
STIRROGATE TRIAL BTIRI{ PLAN
FORTHE
ARE,A 10 LIQUII} INCINERATOR
APPENDIX A
ANI\EX A
QA/QC OBJECTIVES FOR ANALYTICAL METHODS
REVISION 1
December 21 2010
TABLE OF CONTENTS
2.0 VOLATILE ORGAIIIC COMPOUNDS IN EXHAUST GAS......... ...... Annex A-2
2.1 Suuvanv QA/QC CpurBRre FoR SMVOC/CoNoeNsnre (5041A)..... . AIINEX A-2
2.2 Lwruor QUANTTTATToNFoRSMVOCTUBES/CoNDENSATE AIINEXA-3
3.0 SEMI-VOLATILE ORGANIC COMPOUNDS IN EXIIAUST GAS............ Annex A-5
3.1 SUMMARYoTQA/QCCrurBrueFoRSVOCSByMErHoDS3542eNo8270C.......... .ANNEXA-5
3.2 HISTORICAL COurnoI LIMITS FoR SVOCs BY METHoDS 3542 AND 8270C ANNEX A-6
4.0 PCDDS/PCDFS SAMPLING AND ANALYSIS METHODS............. ... Annex A-7
4.1 SUMMARv QA/QC Crurerue FoRDroxrNs sy MErHoo 0023A18290 .. ANNEX A-7
4.2 SUMMARv QA/QC Crursrue FoRDroxrNS By METHoD 8290 ............. . ANNEX A-8
4.3 LnramorQuaNIrenoNFoRPCDDs/PCDFS ANNEXA-g
5.0 HALIDE EMISSIONS Annex A-L0
6.0 METHOD 6020 ICP/MS...... .... Annex A-11
6.1 SUMMARyQA/QCCrurnzue ANNEXA-II
6.2 METHoD 6020 LOQs ANNEX A-12
7.0 MERCURY ANALYSIS METHODS (7470A). Annex A-13
8.0 VOLATILE ORGANIC COMPOUNDS IN PROCESS SAMPLES (82608) ......... Annex A-14
8.1 Suuuenv oF QC AND Cer-rsRArroN CzurenroN roRMersoo 82608 (Aqunous)...................... ANNEX A-14
8.2 CoNrnolLrMrrsFoRPRocESsSeupm,ssyMBrHoo82608.......... ..ANNEXA-15
9.0 SEMI-VOLATILE ORGANIC COMPOUNDS IN PROCESS SAMPLES Annex A-16
9.1 Sutuuenv oF SVOC QC eNn CeusRArroN CzurszuoN ronMerHoo 8270C ........ ANNEX A-16
9.2 HrsrorucelCoNrnoLl-rrrlrrs ronMeruoo 8270C. ...... ANNEX A-17
ATLIC STB Plan - Rev. I
Appendix A
December 2,2010
TOCDF
Annex A - r
1.0 INTRODUCTION
QA/QC OBJECTIVES FOR ANALYTICAL METHODS
These Quality Assurance/Quality Control (QA/QC) objectives are prepared based on the input
from the laboratories performing the analyses for the Area 10 Liquid lncinerator (ATLIC)
Surrogate Trial Burn (STB). The objectives were developed frorn the guidance provided in the
EPA reference methods (1,2,3), EPA Guidance for Quality Assurance Project Plans (4), each
laboratory QA program, and guidance in the EPA QA/QC Handbook (5). The DSHW will be
notified of any changes to these tables when they occur.
ATLIC STB Plan - Rev. I
Appendix A
December 2,2010
TOCDF
Annex A - 1
2.0 VOLATILE ORGAI\IC COMPOUNDS IN EXHAUST GAS
* Criteria for 1,1,2,2-tetrachloroethane, 1,1-dichloroethene, 1,2,3-trichloropropane, 1,2-dichloropropane,
1,3-butadiene, 2-hexanone, 4-methyl-2-pentanone, bromoform, chloroform, ethylbenzene, toluene, and
vinyl chloride.
** Criteria for remaining Compounds
TOCDF
ATLIC STB Plan - Rev. I
Appendix A
December 2,2010
Annex A - 2
2.1 Summary QA/QC Criteria for SMVOC/Condensate (5041A)
*jrjll,ffi
Field/Trip Blanks 1 per run < Lowest standard Report and narrate.
Lab Blanks 1 per analytical batch < Lowest standard Correct probleffi, reanalyze.
Tuning Criterra Prior to calibration and
every l2-hour period.
Method 5041A tuning criteria Correct problem and repeat
tune
Initial Calibration Minimum of five levels Relative Standard Deviation
(RSD) of Relative Response
Factor (RRF) < 30o/o*;
RSD < l5o **
Correct probleffi, rcanalyze.
System Performance Check
Compounds (SPCC) RRF
>0.30 for chlorobenzene and
1,1,2,z-tetrachloroethane ;
>0. 10 for Bromoform,
chloromethane, and
I , 1 -dichloroethane
Correct probleffi, r eanalyze.
Continuing Calibration
Compounds (CCC)
RRF <30% RSDX
RRF < 15% RSD**
Correct probleffi, rcanalyze.
Continuing
Calibration,
SPCC RRFi 12 hours Same as initial Corect probleffi, rcanalyze.
CCC||2 hours t 25 oh Difference (%D)Correct probleffi, rcanalyze .
Consistency in
Chromatography
Internal standard RRT t 30 Seconds Conect probleffi, narrate.
Internal standards 60% to 140%Correct probleffi, narrate.
Laboratory Control
Samples (LCSs)
Accuracy 70 % to 130 %Recovery (%R)*
50% to 150 %R**
Correct probleffi, reanalyze.
Precision RPD < 25o/o >k
< 50% RPD{<{'<
Correct probleffi, reanalyze.
Continuing Accuracy
Check, Surrogates
Dibromofluorornethane
Toluene-ds
4-Bromofluorobenzene
1,2 -D tchl oro ethane - da
SMVOC Tube %R limits are:
50 to 150 %
Condensate %R limits are:
70 to 130 %
Correct probloffi, narrate.
Audit Samples As supplied 50 to 150 %
Condensate Matrix Spike/Matrix Spike
Duplicate (MS/MSD)
50 to 150 %R
RPD <35 Yo
Reanalyze.
Holding Time 14 Days Contact client.
2.2 Limit of Quantitation for SMVOC Tubes/Condensate
ATLIC STB Plan - Rev. I
Appendix A
Decemb er 2,2010
ii:Iffi ],illffiffii::|iiiiffiiiiifi* ffi
riX,:iiiiri,:iiiiilii'iiir.iiiiiirXiliiii*liriiiiiiii;:i':i:'rnii.iiiiiiiriii:i;:::iiiiili
Acetone 50 400 58
Benzene t0 80 78
Bromobenzene 10 80 77
Bromochloromethane 10 80 t28
Bromodichloromethane 10 80 83
Bromoform 10 80 t73
Bromomethane 10 80 94
2-Butanone 50 400 9T
Carbon Disulfide 10 80 76
Carbon Tetrachloride 10 80 t11
Chlorobenzene 5 40 112
Chloroethane 10 80 64
Chloroform 10 80 83
Chloromethane 10 80 50
2-Chloropropane 10 80 9t
2-Chlorotoluene t0 80 126
4-Chlorotoluene 10 80 9l
Cumene (rso-propylbenzene)10 80 10s
Dibromochloromethane 10 80 t29
1,z-Dibromoethane 10 80 t07
Dibromomethane 10 80 93
c is - 1,4 -D ichl oro -2 -butene 10 80 53
trans -1, 4 -D ichloro -2 -butene 10 80 53
D i chlorodi fl uoromethane 10 80 85
I . 1-Dichloroethane 10 80 63
1,z-Dishloroethane 10 80 62
1 , 1-Dichloroethene 10 80 96
c i s - 1,2 -D ichl oro ethene 10 80 96
tr ans - 1,2 -Dichl oroethen e 10 80 96
1,z-Dichloropropane 10 80 63
TOCDF
Annex A - 3
2.2 Limit of Quantitation for SMVOC Tubes/Condensate (continued)
Note:
The term Limit of Quantitation (LOQ) refers to the laboratory's standard Reporting Limit.* SW-g+6 Method LOQ - ng reported are based on a 5 mL water equivalent.
ATLIC STB Plan - Rev. I
Appendix A
Decemb er 2,201 0
*.ul ,C
1 ,3 -Dichloropropane 10 80 76
2,z-Dichloropropane 10 80 77
1 , 1-Dichloropropene 10 80 75
cis -1, 3 -Dichloropropene 10 80 75
trans -1, 3 -Dichloropropene 10 80 75
Ethylbenzene 10 80 106
n-Hexane 10 80 5l
2-Hexanone 50 400 58
Iodomethane (Methyl Iodide)10 80 r42
Methylene chloride 10 80 84
4-Methyl-2-Pentanone 50 400 43
Propylbenzene 10 80 r20
Styrene 10 80 104
1 , 1 , 1 ,2-Tefrachloroehtane 10 80 131
1,1,2,2-Tetrachl oroehtane 10 80 83
Tetrachloroethene 5 40 r64
Toluene 10 80 92
I , I , 1 -Trichloroethane l0 80 97
1,1,2 -Tri chl oroethane l0 80 97
Trichloroethene 10 80 130
Tri chl oro fl uoromethane 10 80 101
1,2,3 -Trichloroprop ane 10 80 110
| ,l ,Z-Trichlor o-l ,2,Z-trifluoroethane 10 80 151
Vinyl Chloride 10 80 62
rn,p- Xylene 10 80 106
o-Xylene 10 80 106
TOCDF
Annex A - 4
3.0 SEMI-VOLATILE ORGANIC COMPOUNDS IN EXHAUST GAS
3.1 Summary of QA/QC Criteria for SVOCs by Methods 3542 and 8270C
Note:
The term LOQ refers to the laboratory's standard Reporting Limit.x Phthalate esters may be reported with qualifiers if the concentration of the analye is less than five times the LOQ;
any such action must be addressed in the case narrative.
TOCDF
ATLIC STB Plan - Rev. I
Appendix A
December 2,2010
Annex A - 5
,;i.ii.,,,,,,.,.,.,,i.ii.,C:G) iG:,ffn,l[4ffiiii,O***o,,ry..:,iit,:.;'.:r''i
Method Blank I per analytical batch <LOQ*Reanalyze.
Assess impact on data.
Narrate.
Field Blank I per ATB < LOQ Reanalyze and/or narrate.
Instrument f'une Every 12 hours, initially and as
required
As per 8270C Retune instrument.
Repeat DFTPP analysis.
Initial
Calibration,
Five Point
SPCC RRF > 0.050 Evaluate system.
CCC RSD <30%Recalibrute.
Other compounds < 15% RSD Average RF if 80% of
the compounds meet
the criteria
Continuing
Calibration
SPCC RRF Same as initial Evaluate system.
Repeat calibration check.
CCC RSD <20%Recalibrate.
Reanal yze affected samples.
Internal Standards RRT t 30 seconds Check sensitivity of system.
Reanalyze standard.
Accuracy 50 - 200%
Precision/
Accuracy
LCS per batch Ifistorical lab data
( See Table 3.2)
Check calculations.
Reanalyze.
Assess impact on data.
Narrate.
Sunogates Historical lab data
(See Table 3.2)
Check calculations.
Reanalyze.
Assess impact on data.
Narrate.
LOQ Standard Compounds 10 pglfraction
Audit Sample As Supplied 50-1 s0%
Holding Time 14 days to extraction
40 days to analysis
Contact client.
3.2 Historical Control Limits for SVOCs by Methods 3542 and 8270C
Notes:
Historical limits for the method are reported here. Current established limits will be used for the
evaluation of the data as required by SW-8a6 (1).
RPD : Relative Percent Difference
DCS = Duplicate Conhol Samples
NA : Not Applicable
ATLIC STB Plan - Rev. I
Appendix A
Decemb er 2,20 I 0
DCS
Acenaphthene 57 to 113 20
4- Chloro - 3 -methylpheno I 42 to 126 29
2-Chlorophenol 52to110 23
L, -Dichlorobenzene 50 to 108 22
2, -Dinitrotoluene 62to113 20
4-Nitrophenol 10 to 145 73
N.nitro s o - di -n-prop ylamine 46 to 123 30
Pentachlorophenol 11 to 135 t25
Phenol 20 to 119 24
Pyrene 47 to 155 27
7,2,4 -T rtchlorob enz ene 49 to ll2 20
Surrogates
7,2 -Di chl or ob enzene - d+10 to 136 NA
2-Fluorobiphenyl 35 to 122 NA
2-Fluorophenol 10 to 108 NA
Nitrob enzene-ds 15 to 118 NA
Phenol-ds 10 to l2l NA
i Terphenyl-dr+35 to 120 NA
2,4,6-Tribromophenol t0 to 154 NA
TOCDF
Annex A - 6
4.0 PCDDs/PCDFS SAMPLING AND ANALYSIS METHODS
4.1 Summary QA/QC Criteria for Dioxins by Method 0023A/8290
Notes: The term LOQ refers to the laboratory's standard Reporting Limit.
RSD : Relative Standard Deviation, OCDF : Octachlorodibenzofuran, RRF = Relative Response Factor,
o/oD : Percent Difference, TCDD : Tetrachlorodibenzo-p-dioxin, OCDD : Octachlorodibenzo-p-dioxin
TOCDF
ATLIC STB Plan - Rev. I
Appendix A
December 2,2010
Annex A - 7
ICAL Five point calibration
Initially and as
required.
Int Std RSD < 30 %
Natives RSD <20 %
Evaluate system.
Recalibrate.
CCAL Midpoint Standard at
Start of Each 12 hour
sequence
%D of IS < 30% fromavg
RRF (rCAL);
%D of natives <20'/o from
aYsRRF (ICAL).
Evaluate system.
Reanalyze CCAL.
Recalibrate as necessary.
WDM
CPSM
Once per 12 hours prior
to sample analysis.
Used to set retention times
CPSM must have < 25 %
valley resolution for
2,3,7,8-TCDD
Readjust windows.
Evaluate system.
Perform maintenance.
Reanalyze WDM/CPSM.
Method Blanks 1 per analytical batch < LOQ, except for
ocDD @< s xLoQ
Reanalyze.
Assess impact on data.
LCS 1 per analyical batch 60 to 140 oh for target
analytes
Review internal standards.
Assess impact on data.
Reextract and lor reanalyze
as necessary.
MSA4SD I per ATB 60 to 140 oh recovery for
target analytes;
RPD <20%
Review LCS.
Assess impact on data.
Narrate.
Internal Standards Every sample 40 to 1 3 5 o/o for tetra
through hexa isomers
25 to 1 5 0 o/o for hepta and
octa isomers
Check chromatogram for
interference.
Check instrument and
reanalyze.
Check signal-to-noise, if <
10:1, reextract.
Assess impact on data and
narrate.
Holding Time 30 Days Extraction
45 Days Analysis
Note: The term LOQ refers to the laboratory's standard Reporting Limit.
4,2 Summary QA/QC Criteria for Dioxins by Method 8290
Annex A - 8
ATLIC STB Plan - Rev. I
Appendix A
Decemb er 2,20 I 0
TOCDF
4.3 Limit of Quantitation for PCDDs/PCDFs
Annex A - 9
ATLIC STB Plan - Rev. 1
Appendix A
Decemb er 2,20 I 0
DlilDiiii8ilS.$;.i..,i.,,..,,,.'::.:.
,., ,,,.:,.:
i::r::I:j.:j.::!:1..:..:::.':..rr.:.'iri:i.::r. :.r:::..i':1rlJ.
t.::r..:I::r::i;if.:.:-::.::::.r:.1:.'.:.i:.r._..:.r.::....j:.i....:i:
'i[ ii'li.l1i.:...r',l l.tii.liliirl.i
iit00ifi i
riiiiiiiiiiiiiiiiiiiiilit'lili-ii.iiuiiiii
Efi fl firu'tii6il$l:..:.il::l.t.lll.l:.,;rll
2,3,7,8-TCDF 5 0.005
L,2,3,7,$-PeCDF 25 0.025
2,3,4,7,8-PeCDF 25 0.025
r,2,3,4,7 ,8-HxCDF 25 0.02s
1,2,3,6,7 ,9-HxCDF 25 0.025
1,2,3,7,8,9-HxCDF 25 0.025
2,3,4,6,7 ,9-HxCDF 25 0.025
1,2,3,4,6,7, 8 -Hp CDI-,'25 0.025
1,2,3,4,7,8,9-HpCDF 25 0.025
OCDF'50 0.0s0
2,3,7,8-TCDD 5 0.00s
L,2,3,7,S-PeCDD 25 0.02s
I,2,3,4,7 ,8-HxCDD 25 0.025
1,2,3,6,7 ,8-HxCDD 25 0.025
L,2,3,7,8,9-HxCDD 25 0.025
1,2,3,416,7,8-HpCDD 25 0.02s
OCDD s0 0.050
TOCDF
5.0 HALIDE EMISSIONS
Summary QA/QC Criteria for Hydrogen Chloride and Chlorine (9057)
Method Blank 1 per analytical batch < LOQ Reanalyze.
Assess impact on data.
Narrate.
Field Blank 1 per SWDT < Low standard Narrate
Initial
Calibration
4-point calibration and
a blank.
Initial las required
Correlation
coefficient
> 0.995
Evaluate system.
Recalibrate.
Continuing
Calibration
Midpoint standard
every 10 samples and
at end of sequence
90 to Il0 %Evalu ate system.
Repeat calibration check.
Recalibrate.
Reanalyze affected samples.
Precision/
Accuracy
LCS per batch 90 to ll0 %Check calculations.
Reanalyze.
Assess imp act on data.
Narrate.
MS/MSD per batch 85 to 1 15 o%R,
RPD <25 %
Check calculations.
If RPD is in control, accept
data and narrate. If RPD is
out of control, reanalyze.
Audit Sample As provided 90 to Ll} %Check calculations.
Reanalyze and Narrate.
LOQ Hydrogen Chloride
Chlorine
1.0 mgltran
1.0 mgltrain
Holding Time 28 days
Note: The term LOQ refers to the laboratory's standard Reporting Limit.
ATLIC STB Plan - Rev. 1
Appendix A
Decemb er 2,2010
TOCDF
Annex A - 10
6.0 METHOD 6020 ICP/MS
6.1 Summary QA/QC Criteria
Note: amu - atomic mass unit
ICV - Initial Calibration Verification
CCV - Continuing Calibration Verification* For air matrices, the QC samples per batch include a DCS only (no MS/MSD).
ATLIC STB Plan - Rev. 1
Appendix A
Decemb er 2, 2010
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I t*trur*rrt Tune Mass resolution < 1.0 Refune instrument.
calibration and
sample analysis
amu @ l0% peak height.
Mass calib. + 0.1 amu
Repeat tune solution and
analysis.
Initial Calibration Blank and at least
one standard.
ICV t l0 % of expected
value
Evaluate and reanalyze ICV
Recalibrate.
Calibration Blank After ICV and
CCV
< LOQ Clean system. Rerun.
Reanalyze affected samples.
CCV Every 10 samples
and end of run
sequence
+ l0 % of expected value Reanalyze CCV.
Recalibrate.
Reanalyze samples.
Method Blank 1 per analytical
batch
< LOQ Reanalyze.
Recalibrate as necessary.
Internal Standard Each sample 30 to 130 %R Reanalyze and/or narrate.
Duplicate Control
Sample (DCS) *
1 per analTrtical
batch
75 to 125 o R,
RPD <25 %
Check calculations.
Assess impact on data.
Reextract and reanalyze as
necess ary. Narrate.
MS/MSD *1 per analytical
batch
7 5 to 125 ohR,
RPD <25 %
Check calculations.
Reanalyze.
Assess impact on data
Duplicate Analyses 1 per analytical
batch
RPD <20 %Check calculations.
Reanalyze.
Assess impact on data
Holding Time 180 Days to analysis
TOCDF
Annex A - 11
6.2 Method 6020LOQs
ATLIC STB Plan - Rev. I
Appendix A
Decemb er 2,201 0
:.:;:.:::
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Aluminum 7.5 1.0
Antimony 0.30 0.050
Arsenic 0.30 0.050
Barium 0.15 0.025
Beryllium 0.15 0.025
Boron 7.5 1.0
Cadmium 0.15 0.025
Chromium 0.30 0.050
Cobalt 0.15 0.025
Copper 0.30 0.050
Lead 0.15 0.025
Manganese 0.1s 0.025
Nickel 0.3 0 0.050
Selenium 0.4s 0.050
Silver 0.15 0.025
Thallium 0.1s 0.02s
Tin 1.5 0.25
Vanadium 1.5 0.2s
Ztnc 0.7 5 0.12
TOCDF
Annex A - 12
':::*C m
Initial Calibration Blank and five standards.
Daily before analysis
Corr. Coefficient >
0.99s
Evaluate system.
Recalibrate.
Calibration Blank After ICV and each CCV < LOQ Rerun.
Clean system.
Reanalyze affected samples .
ICV After calibration 80 to 120 %Reanalyze ICV.
Recalibrate.
CCV Every 10 samples and end of
run sequence
80 to 120 %Reanalyze.
Recalibrate.
Reanalyze affected samples.
Method Blank 1 per analyical batch < LOQ Reanalyze.
Recalibrate as necessary.
Reanalyze.
LCS 1 per analyical batch 80 to 120 %Check calculations.
Reextract and reanalyze as
necessary.
Assess impact on data.
Narrate.
MS/MSD 1 per analyical batch (20
samples).
75 to 125 %Check calculations.
Evaluate LCS.
Assess impact on data.
Stack samples.
MS on one
FH fraction
1 per analyical batch 75 to 125 %Check calculations.
Reanalyze.
Assess impact on data,
LOQ Multiple Metals Train
Aqueous Samples
0.2 p,glfraction
0,0002 mglL
Holding Time 14 days
See Table A-7 -1
Note: The term LOQ refers to the laboratory's standard Reporting Limit.
7.0 MERCURY ANALYSIS METHODS (7470A)
Summary QA/QC Criteria
SW 846 Methods 7470A, Mercury by Cold Vapor AAS
ATLIC STB Plan - Rev. I
Appendix A
Decemb er 2,20 I 0
TOCDF
Annex A - 13
8.0 VOLATILE ORGANIC COMPOUNDS IN PROCESS SAMPLES (82608)
O 8.1 Summary of QC and Calibration Criterion for Method 8260B (Aqueous)
Note: The term LOQ refers to the laboratory's standard Reporting Limit.I Except for common lab contaminants: methylene chloride, acetone, and 2-butanone may be reported with
qualifiers if the concentration of the analyte is less than five times the LOQ. Such action must be addressed
in the case narrative.
2 Allowance for up to 6 tatget analytes > 50%.
ATLIC STB Plan - Rev. I
Appendix A
Decemb er 2,2010
:@Niiiit.i.,ii,tl.;,.1,.1,.'1
Method Blank 1 per analytical batch < LOQ,Reanalyze. Assess impact on data
Narrate.
Instnrment Tune Every 12 hours Refer to method.Refune instnrment.
Repeat BFB analysis.
Initial
Calibration,
Five point
SPCC RRF > 0.10 Chloromethane
> 0.10 1,1-DCA
> 0.10 Bromoform
> 0.30 Chlorobenzene
> 0.30 1,1,2,2-TCA
Evaluate system.
Recalibrate.
CCC RSD < 3O%
Compounds < 15% RSD Average RF if 80 '/o of
the compounds meet
the criteria
Continuing
Calibration
SPCC RRF Same as initial Evaluate system.
Repeat calibration check.
CCC < 20 o/o drift Recalibrate.
Reanalyze affected samples.
Every 12 hours RSD<50'/ofor
non-CCCs 2
Evaluate system.
Repeat calibration check.
lnternal Standards RRT < 0.50 or 30 seconds Check sensitivity of system.
Reanalyze standard.Recovery 50 to 200 %R
Precisioni
Accuracy
LCS, MS/MSD per batch
Surrogates
Historical lab data
(See Table 7 .2)
Check calculations. Reanalyze.
Assess impact on data.
Narrate.
Holding Time 14 days
TOCDF
Annex A - 14
8.2 Control Limits for Process Samples by Method 82608
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LCS
1,1 -Dichloroethene 66 to 130 NA
Benzene 77 to I2l NA
Trichloroethene 75 to 116 NA
Toluene 78 to 120 NA
Tetrachloroethene 72 to 120 NA
Chlorobenzene 80 to 120 NA
MS/MSD
1 , 1 -Dichloroethene 66 to 130 32
Benzene 77 to 121 21
Trichloroethene 75 to 116 24
Toluene 78 to 120 25
Tetrachloroethene 72 to 120 25
Chlorobenzene 80 to 120 20
Surrogates
1,z-Dichoroethane -d4 64 to 139 NA
Toluene-d8 72 to 128 NA
4-Bromofluorobenzene 66 to 121 NA
Notes: Historical limits for the method are reported here. Current established limits will be used for the
evaluation of the data as required by SW-8a6 (1).
NA: Not Applicable
ATLIC STB Plan - Rev. I
Appendix A
Decemb er 2,201 0
TOCDF
Annex A - 15
9.0 SEMI.VOLATILE ORGANIC COMPOUNDS IN PROCESS SAMPLES
9.1 Summary of SVOC QC and Calibration Criterion for Method 8270C
Note: The term LOQ refers to the laboratory's standard Reporting Limit.* Except for common lab contaminants: Phthalate esters may be reported with qualifiers if the concentration of the
analye is less than five times the LOQ. Such action must be addressed in the case narrative.
ATLIC STB Plan - Rev. 1
Appendix A
Decemb er 2,2010
Method Blank 1 per analytical batch <LOQ*Reanalyze.
Assess data,Narrate.
Instrument Tune Every 12 hours, initially
and as required
As per 8270C Refune instrument.
Repeat DFTPP analysis.
Initial
Calibration
Five point
SPCC RRF > 0.050 Evaluate system.
Recalibrate.CCC RSD<30%
Compounds < 15% RSD Average RF if 80 o/o of
the compounds meet the
criteria
Continuing
Calibration
SPCC RRF Same as initial Evaluate system.
Repeat calibration check.
CCC RSD <200 Recalibrate.
Reanalyze affected samples.
lnternal Standards RRT t 30 seconds Check sensitivity of system.
Reanalyze standard.Accuracy 50 to 200 %R
Precision/
Accuracy
LCS, MS/MSD per batch
Surrogates
Historical lab data
(See Table 8.2)
Check calculations.
Reanalyze.
Assess data, Narrate.
LOQ 0.050 mg/L to
0.25 mglL
Holding Time Extraction - 14 days
Analysis - 40 days
TOCDF
Annex A - 16
LCS Acenaphthene 62 to 103
4 -Chloro-3 -methylphenol 60 to 100
2-Chlorophenol 48 to 102
1 ,4-Dichlorobenzene 51 to 91
2, -Dinitrotoluene 60 to 113
4-Nitrophenol 18 to 63
N-nitro s o -di -n -propyl amine 61 to 105
Pentachlorophenol 35 to 118
Phenol l6 to 56
Pyrene 47 to 126
1,2,4 -Tri chlorob enzen e 57 to 97
9.2 Historical Control Limits for Method 8270C
for Semi-Volatile Organic Compounds in Aqueous Samples
:,.....:.C,O]N[p.Ouil$D',,:.,'.',..,...,',..,.,i,',.,.:.,,,,'.,.,,,r..,,,i,
MS/MST)Acenaphthene 59 to 103 15
4 -Chl oro- 3 -methylphenol 60 to 100 26
2-Chlorophenol 48 to 102 34
| ,4-Dichlorobenzene 51 to 91 29
2,4-Dinitrotoluene 60 to 113 26
4-Nitrophenol 18 to 63 67
N -n i tro s o -di -n -propyl amine 61 to 105 26
Pentachlorophenol 35 to 118 39
Phenol 16 to 56 7l
Pyrene 47 to 126 36
1,2,4 -Trichl orob enzene 57 to 97 27
Surrogates 2-Chlorophenol-d+25 to 101 NA
I,2 -D ichl orob enzene- d+49 to 99 NA
2-Fluorobiphenyl 47 to 106 NA
2-Fluorophenol 10 to 70 NA
Nitrobenzene-d5 50 to 102 NA
Phenol-dt l0 to 47 NA
Terphenyl-d1a 40 to 125 NA
2,4,6-Tribromophenol 2l to 127 NA
Note: Historical limits for the method are reported here. Current established limits will be used
for the evaluation of the data as required by SW-846 (1).
TOCDF
ATLIC STB Plan - Rev. I
Appendix A
December 2,2010
Annex A - 17
1O.() REFERENCES
(1) Test Methodsfor Evaluating Solid Waste, Physical/Chemical Methods,3'd Edition
including Update IV, USEPA, SW-846, February 20A7.
(2) Title 40, Code of Federal Regulations,Part 60, Appendix A, "Test Methods".
(3) Title 40, Code of Federal Regulations,Part 136, Appendix A, "Methods for Organic
Chemical Analysis of Municipal and Industrial Wastewater".
(4) EPA Requirements for Quality Assurance Project Plans, EPA QA/R-5, November
t999.
(5) Handhook: Quality Assurance/Quality Control (QA/QC) Procedures for Hazardous
lY a s t e I n cin e r atio n, EP N 62 5 I 6 -89 I 023, January 1 9 90.
TOCDF
ATLIC STB Plan - Rev. I
Appendix A
Decemb er 2,20 I 0
Annex A - 18
O
o
o
SURROGATE TRIAL BT]RI{ PLAN
FOR THE
AREA 10 LIAUID INCII\ERATOR
APPE,NDIX A
ANNEX B
EXAMPLE DATA FORMS
REVISION 1
December 2r 2010
TABLE OF CONTENTS
Chain of Custody Record...... .Annex B-1
Method 5l26AField Data Sheets....... ......Annex B-2
Method 29 Field Data Sheets................ ...Annex B-4
Method 0023A Field Data Sheets ............Annex B-6
Method 0031 Field Data Sheets................ .................Annex B-8
URS Source Sampling Temperature Readout Calibration Form......... ........Annex B-10
Five-Point Dry Gas Meter Calibration Form......... ..Annex B-11
Three-Point Dry Gas Meter Calibration Form......... Annex B-12
VOST Console DGM & Thermocouple Calibration Form......... .................Annex B-13
S-Type Pitot Tube Inspection Sheet ......Annex B-14
Pitot Tube Calibration Data Sheet .........Annex B-15
Potable Barometer Calibration Data Sheet ..............Annex 8-16
Balance Calibration ..............Annex B-17
Field Balance Calibration............ ..........Annex B-18
IIRS CEMS Operation Log........... ........An:rex B-19
ATLIC STB Plan - Rev. 1
Appendix A
December 2,2010
TOCDF
Annex B-i
Chain of Gustody Record
Samples from Multi-Metals Sa[plinq Trains Page of
ProJect
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ATLIC STB Plan - Rev. l, Appendix A
sample Type - PM/HCI/CIz (Methods 5/0050)
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Duration (min)
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S-Type Pitot Tube Inspection Sheet
Inspector: Date:
-
Pitot ID:
General Pitot
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Alignment
End View B-Side
Side View Planc
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Tube Axis \
lpnsitudinal
v
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lf all answers except the first (Dt) are "y',
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needs to be calibrated using a wind
tunnel.
Any other situation, the pitot tube must be
removed from service.
Annex B - 14 ATLIC STB Plan - Rev. l, Appendix A
Pitot Tube Calibration Data
Pitot Tube Identification Number:
Calibrated by:
Sheet
Date:
Run No.
66A" Side Calibration
Deviation
Cot'l - Avg CoAPrs6
(in. water)
AP'
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Cp(t)
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2
3
Average Cp(s) (Side A)
Run No.
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Cp(r)
1
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3
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Must be <0.01
Annex B - 15 ATLIC STB Plan - Rev. l, Appendix A
Portable Barometer Calibration Data Sheet
Portable Barometer ldentification
Date
Operator
Laboratory barometer reading (reference) (in Hg)
Portable barometer reading after correction (in Hg)
Difference between reference and portable
after correction (in Hg)
ls the difference stO.1 in Hg (yes/no)
Annex B - 16 ATLIC STB Plan - Rev. l, Appendix A
Balance lD
BaTANCE CAUBRATION
Date
lnitial
Galibration
Calibration Weight Operator
tD#Mass
Linearity
Check
Calibration Weight Balance
Reading
Acceptable
RangeID#Mass
100 99.9 - 100.1
200 199.9 - 200,2
500 499.5 - 500.5
1 000 999 - 1 001
Calibration of
Student Weights
Student Weight
Set lD
Calibration
Weight
Balance
Reading
Annex B - 17 ATLIC STB Plan - Rev. l, Appendix A
O FmLD B,trANcE Ca,IIBRATIoN
Balance lD Date
Operator
" Use only calibration weights greater than 20 g.
b The acceptance criteria for percent difference is t0.5%. This is calculated using this equation:
percent Difference - balance reading - actual mass , , oo
actual mass
Sensitivity Check "
" ln order to complete the sensitivity check of the field balance a weight greater than or equal to 1000 g
is placed on the balance and the balance reading is recorded. Then a second weight less than or
equalto 1 g is also placed on the balance. This second balance reading is recorded.
d The acceptance criteria for the sensitivity check is 85-'115% of the secondary weight. This is
calculated using this equation:
% of secondary weight - Balance reading B -Balance.Reading A *roo
Secondary Weight
Galibration Check
of Balance Using
Student Weights
Student Weight
Set lD
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Actua!
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Calibration Weight)
Balance
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Secondary
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Calibration
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Balance
Reading
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Balance Reading
of Secondary
Weight
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Balance Readinq A)
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Weightd
Annex B - 18 ATLIC STB Plan - Rev. l, Appendix A
Project 'Page of
Project Number Operator
Source Date
URS GEMS Operation Log
Analyzer Response
Annex B - 19 ATLIC STB Plan - Rev. l, Appendix A
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ST]RROGATE TRIAL BURN PLAN
FOR THE
AREA 10 LIQUID INCINERATOR
APPENDIX A
ANNEX C
RESUMES OF KEY INDIVIDT]ALS
REVISION 1
December 2r 2010
TABLE OF CONTENTS
URS CORPORATION KEY PERSONNEL RESUMES. ......C-1
TESTAMERTCA KEY PERSONNEL RESUMES ....................................... ...................C-8
AIR TOXICS, LTD., KEY PERSONNEL RESUMES ........C-11
ATLIC STB Plan - Rev I
Appendix A
December 2,2010
TOCDF
Annex C-i
URS CORPORATION KEY PERSONNEL RESUMES
Michael Fuchs
Eugene Youngerman) PhD
D. Chris Weber
Margaret L. Jephson
Adam Blank
Kevin McGinn
George Lipinski, PE
Carl Galloway
Steven Hall
Robert V. Woytek
David P. Maxwell
Derek Ballek
Nathan Reichardt
Andrew Hodgson
Meggen Delollis
Alex Bellon
Crawford Daniel Currin
Austen Joseph Sofhauser
ATLIC STB Plan - Rev. I
Appendix A
Decemb er 2, 2010
TOCDF
Annex C-l
URS CORPORATION KEY PERSONNEL RBSUMES
MICHAEL FUCHS
Project Manager
Mr. Michael Fuchs is a Project Manager in the Measurements group in the URS Austin, Texas,
office. Mr. Fuchs began his career performing source testing and now manages projects while
continuing to supervise tests in the field. Mr. Fuchs primarily manages projects related to the
treatment of hazardous waste (primarily combustion); emissions measurements, including source
testing; and regulatory compliance (RCRA, TSCA, and HWC MACT) for hazardous waste
combustion facilities. He actively participates in those projects by preparing test plans and
QAPPs; supervising trial burns, CPTs, and related projects; and preparing reports and regulatory
filings. Mr. Fuchs manages the trial burns and related projects at TOCDF and PBCDF, and
supervises on-site testing at TOCDF. He manages (and was instrumental in) the development
and implementation of the ongoing mercury monitoring at TOCDF. He also manages similar
projects for a number of industrial clients. He holds a Bachelor's degree in Chemistry from
Southwest Texas State University at San Marcos.
EUGENE YOUNGERMAN, Ph.D.
Senior Project Chemist, Unit Quality Officer
Dr. Eugene Youngerman currently serves as the Senior Project Chemist and Unit Quality Officer
for the Measurements group of the Austin General Engineering Office. He directs and
participates in permitting and testing activities of hazardous waste incinerators as well as other
source testing for process characterization or regulatory compliance. He has 24 years of
experience in this area including document preparation; test protocol design and preparation;
laboratory coordination; method development; plan implementation; and interpretation and
reporting of sampling, analysis, and QA/QC results. He has served as Project Director on major
sampling and analysis programs for RCRA and TSCA pre-trial and trial burns. Dr. Youngennan
has several publications relating to his experience on various projects. He holds a Bachelor's
degree in Chemistry from the Massachusetts Institute of Technology at Cambridge, and a
Master's and Doctorate in Chemistry, both from the University of California at San Diego.
D. CHRISTOPHER WEBER
Chemist
Mr. D. Christopher Weber is a Chemist in the Measurements Group in the URS Austin, Texas,
office. His primary focus is on projects dealing with emissions measurement in the chemical
demilitarization, power, petrochemical, semiconductor, pharmaceutical, cement, and various
manufacturing industries. He has gained experience with combustion, petrochemical, and other
industrial processes through participation in numerous efforts designed to permit and
charucterize processes or pollution control devices. Mr. Weber has a Bachelor's degree in
Biology, from Vanderbilt University at Nashville, Tennessee.
ATLIC STB Plan - Rev. I
Appendix A
Decemb er 2, 2010
TOCDF
Annex C-2
MARGARET L. JEPHSON
Scientist
Ms. Margaret L. Jephson is a Scientist in the Measurements group for the URS Austin, Texas,
office. Her areas of expertise include air regulatory compliance support, and trial bum testing
and reporting. She has been a field Team Lead,leading the field aspects for emissions testing
projects and working with clients to help them fulfill their compliance needs. In addition, Ms.
Jephson has been responsible for compiling test results and preparing formal reports for
submittal to the regulatory agencies. Ms. Jephson holds a Bachelor's degree in Chemistry from
Southwestern University at Georgetown, Texas.
ADAM BLANK
Project Scientist
Mr. Adam Blank is a Project Scientist prirnarily focusing on technical and measurement support of
projects characteizing emissions from combustion sources. During his career at URS, Mr. Blank
has participated in a number of projects supporting HWC MACT and RCRA trial burns. He has
worked with multiple hazardous waste combustion units and clients, including commercial and
process units, and a chemical weapons demilitarization facility. He has experience with test
design, project planning and execution, and reporting in numerous efforts designed to permit and
characteize emissions from processes or pollution control devices. Mr. Blank holds a Bachelor's
degree in Bio-Psychology from Tufts University at Boston, Massachusetts.
KEVIN McGINN
Project Manager
Mr. Kevin McGinn has 16 years of experience in emissions measurement. As a Project
Manager, he has supervised field teams, written test reports, and performed quality assurance
duties for projects in the waste incineration and petrochemical industries. As a Program
Manager, he managed projects in the chemical demilitarization, waste incineration, cement
production, and chemical industries. His specialty is the field of air quality. Mr. McGinn holds
a Bachelor's degree in Chemistry from McGill University at Montreal, Quebec, Canada.
ATLIC STB Plan - Rev. I
Appendix A
Decemb er 2,2010
TOCDF
Annex C-3
GEORGE LIPINSKI, Professional Engineer (PE)
Senior Project Manager
Mr. George Lipinski is a chemical engineer with26 years of experience in environmental
engineering. As a consultant, he managed projects in the waste management, chemical,
pharmaceutical, electric utility, and independent power-production industries. His experience
includes a variety of environmental programs in air quality, hazardous waste, solid waste, and
water quality. Mr. Lipinski has specialized experience in the fields of air quality, combustion,
incineration, and waste management. In addition, he has authored a number of papers and
presentations related to hazardous waste and wood fuel combustion. Mr. Lipinski is a registered
PE and holds a Bachelor's in Chemical Engineering from the University of Texas at Austin.
CARL GALLOWAY
Senior Sampling Technician
Mr. Carl Galloway has participated in trial bum sampling activities since 1989, performing
isokinetic sampling, VOST (0030 and 0031) CEMS operation, train preparation, process
sampling, gas chromatography (Ml8 and 0040), and sample shipping. He has experience with
sampling and analysis of FGD and SCR systems, including nitrogen oxides (M7D), sulfur
dioxide and sulfuric acid (M6 and NCASI 8A), ammonia (CTM 027 and other variants), plus
other related process measurements, including reduced sulfur species (Ml1, M15, M16). Mr.
Galloway holds a Bachelor's degree in Biology from the University of Texas at Austin.
STEVEN HALL
Senior Scientist
Mr. Steven Hall has conducted emission measurements at a myriad of sources over his 17 -year
career. As a Senior Scientist, he has managed projects, supervised field teams, analyzedl
interpreted data, written test reports and plans, and performed quality assurance duties for
projects in the power, oil and gas, gas transmission, semiconductor, cement, and petrochemical
industries. Mr. Hall specializes in the field of air quality measurements by Fourier Transform
Infrared Spectroscopy (FTIR). He holds a Bachelor's degree in Chemistry from the University
of Illinois at Champaign Urbana.
ATLIC STB Plan - Rev. I
Appendix A
Decemb er 2,201 0
TOCDF
Annex C-4
o ROBERT V. WOYTEK
Technician/Laboratory Man ager/Equipment Manager
Mr. Robert Woytek has been involved in numerous trial burn efforts throughout his 20-plus
years with URS. His experience ranges from isokinetic train preparation and recovery to
isokinetic train sample collection. Mr. Wolek is also responsible for maintenance, calibration,
and inspection of the URS sampling equipment and NIST Traceable calibration equipment, and
the management of two laboratories. He studied Biology at Austin Community College at
Austin, Texas.
DAVID P. MAXWELL
Senior Project Chemist
Mr. David Maxwell is an analytical chemist with 27 years of experience in the characterization
of chemical and industrial processes as a manager and task leader of emissions and process
testing, ambient air monitoring, and environmental sampling and analytical programs. Mr.
Maxwell uses his analytical chemistry and quality control background for the development and
proper application of chemical measurement methods to the sampling and analysis of multi-
media process streams and emissions from hazardous waste incineration, power generation, and
other combustion and gasification processes. He conducts and leads project tasks with an
attention to detail and provides the following professional leadership skills:. Management and technical direction of industrial and environmental sampling and
analytical projects;. Development of sampling and analytical solutions for complex industrial process and
environmental characterizations ;. Preparation of written project and quality assurance plans, project reports, technical
papers, and presentations; and. Evaluation and interpretation of analytical results and quality control data.
Mr. Maxwell holds a Bachelor's degree in Chemistry from the University of Southern California
at Los Angeles.
DEREK BALLEK
Chemist
Mr. Derek Ballek is currently a Chemist for the Measurements group of the URS Austin, Texas,
office. He has extensive experience in hazardous waste sampling; isokinetic sampling;
Appendix K monitoring; continuous emissions monitors; 40 CFR 60, Appendix A, methods for
sampling and recovery; and 40 CFR 63, Subpart EEE, at sources such as incinerators, boiler
industrial furnaces, and turbines. Mr Ballek has worked as a field lead many times and is
familiar with all facets of CPTs. He holds a Bachelor's degree in Chemistry from the University
of Texas at Austin.
ATLIC STB PIan - Rev. I
Appendix A
Decemb er 2,2010
TOCDF
Annex C-5
NATHAN REICHARDT
Environmental Scientist
Mr. Nathan Reichardt is an Environmental Scientist for the Measurements section of the URS
Austin, Texas, office. He has extensive experience in isokinetic sampling and continuous
emissions monitoring. He has held task lead, sampling, and sample recovery roles in projects
ranging from investigative emissions charactertzation to comprehensive performance tests and
trial burns. Mr. Reichardt holds a Bachelor's degree in Environmental Science from West Texas
A&M University at Canyon.
ANDREW HODGSON
Scientist III
Mr. Andrew Hodgson has over 12 years of experience in environmental measurements, including
gas chromatography, ambient and indoor air monitoring, and vapor intrusion studies. He has
worked with a *id. rrrg" of equipment manufacturers including Perkin Elmer, Agilent, SRI, and
Photovac. He has conducted systems and performance audits of ambient air quality and
meteorological monitoring systems for URS. Mr. Hodgson holds a Bachelor's degree in
Environmental Science from Lehigh University at Bethlehem, Pennsylvania.
MEGGEN DeLOLLIS
Chemist
Ms. Meggen Delollis is a Chemist for the Measurements section of the URS Austin, Texas,
office and has extensive experience in isokinetic sampling, Method 30B mercury monitoring and
thermal desorption analysis, continuous emissions monitoring, and sample analysis by gas
chromatography. She has held lead, sampling, sample recovery, and sample analysis roles in
projects ranging from investigative emissions characteization to comprehensive performance
tests and trial burns. Ms. Delollis holds a Bachelor's degree in Chemistry from the University
of Texas at Austin.
ALEX BELLON
Scientist
Mr. Alex Bellon has recently joined the Measurements section of the URS Austin, Texas, office
as an entry-level scientist. He has experience in isokinetic and sorbent tube sampling at sources
such as incinerators, furnaces, and turbines. Mr. Bellon has aided in mobilization for several
projects and has a working knowledge of isokinetic sampling based on EPA Test Method 5, and
sorbent tube sampling and analysis based on EPA 40 CFR 75, Appendix K. He holds a
Bachelor's degree in Physics from the University of Texas at Austin.
ATLIC STB Plan - Rev. I
Appendix A
Decemb er 2,2010
TOCDF
Annex C-6
CRAWFORD DANIEL CURRIN
Chemist
Mr. Crawford Daniel Currin has more than? years in emissions sampling and analytical
methods. As a chemist, he has performed laboratory analysis of various emissions, including
drinking water, waste water, and air emissions. Mr. Currin has analyzed these samples for
Method 29 metals analysis via ICP-MS, Biochemical Oxygen Demand, Total Kjeldahl Nitrogen,
Ammonia, Phosphorus, Cyanide, Fluoride, and Hexavalent Chromium, With URS, he has been
involved in the preparation, operation, and recovery of isokinetic sampling trains. He has also
been responsible for the operation of CEMS instruments to complete Relative Accuracy Test
Audits (RATAs). Mr. Cunin holds a Bachelor's degree in Chemistry from University of North
Carolina at Wilmington.
AUSTEN JOSEPH SOFHAUSER
Chemist
Mr. Sofhauser has more than 9 months experience in emissions sampling. V/ith URS, he has
been involved in the preparation, operation, recovery, and analysis of isokinetic sampling trains.' He hold s Bachelor's degree in Chemistry from the University of Texas at Austin.
Annex C-7
ATLIC STB Plan - Rev. I
Appendix A
Decemb er 2,2010
TOCDF
TESTAMERICA KEY PERSONNEL RESUMES
Robert Hrabak
Karla S. Buechler
Douglas Weir
Steven D. Rogers
David Allameh
Robert Weidenfeld
Kirby Garret
Michael Flournoy
ATLIC STB Plan - Rev. 1
Appendix A
Decemb er 2,2010
TOCDF
Annex C-8
TESTAMERICA KEY PERSONNEL RESUMES
ROBERT HRABAK
Operations Manager
Mr. Robert Hrabak has over 20 years experience in the environmental industry with over 16
years in various managerial positions. He is responsible for monitoring workflow, increasing
efficiency and productivity of all operational groups in the laboratory. He assures completion
and follow-through on day-to-day operations in all departments. These dayto-day operational
responsibilities include client satisfaction, financial management, human resources, health and
safety program compliance, and quality assurance plan compliance. Mr. Hrabak has specialized
in the area of the Advanced Technology Group, focusing on dioxins and specialty chemicals.
His extensive technical knowledge in these areas and excellent organizational skills made him
the ideal choice to manage these projects in the laboratory. Mr. Hrabak holds a Bachelor's
degree in Biological Sciences from the University of California at Davis.
KARLA S. BUECHLER
Laboratory Manager
Ms. Karla Buechler has over 20 years experience in the environmental industry with over 13
years in various managerial positions. In addition, she has eight years of hands-on experience
with pesticide extraction and GC. In her current role she oversees the overall operation of the
West Sacramento Laboratory. Ms. Buechler holds a Bachelor's degree in Biochemistry from the
University of California at Davis.
DOUGLAS WEIR
Quality Assurance Manager
Dr. Douglas Weir directs and monitors quality assurance activities at the West Sacramento
facility. He is responsible for reports to management, client concerns, project plan review, lab
performance review, and review of procedures that will ensure the production of data of a
defined quality. He is responsible for performing the systems and method audits of the
laboratory. He has over 19 years experience in the environmental laboratory industry, which
includes experience in high and low resolution GC/IvIS, GC/ECD, HPLC, UV/visible
spectroscopy, and magnetic resonance. He has authored method standard operating procedures,
Quality Assurance Plans, project/cost proposals, and 30 scientific papers. He is conversant with
a wide variety of U.S. EPA methodologies including SW846 organic and inorganic methods;
series 500 and 600 methods for drinking water and wastewater; methods 1613B, 1614,1668A,
1625,1656,8290, and 82804. Dr. Weir has a Bachelor's degree_in Chemistry and a Doctorate
in Physical Chemistry, both from Queen's University at Kingston, Ontario, Canada.
ATLIC STB Plan - Rev. 1
Appendix A
Decemb er 2, 2010
TOCDF
Annex C-9
STEVEN D. ROGERS
Volatile Organics Analysis Department Manager
Mr. Steven Rogers has over 22 years of management and bench level experience. He is currently
managing the Volatile Organics Analysis department. He provides technical expertise in all
organics areas of the lab. Mr. Rogers holds a Bachelor's in Biochemistry/Biophysics from
Oregon State University at Corvallis.
DAVID ALLAMEH
GC/HPLC/LCMS Department Manager
Mr. David Allameh has over 19 years of experience in environmental analyses. He is
responsible for the groups performing petroleum hydrocarbon methods and HPLC methods 8310
and 8330. He coordinates instrument maintenance, data review, analyst training, updating of
SOPs as well as scheduling sample analysis. He held technical and supervisory positions at
environmental testing laboratories prior to joining TestAmerica. He applies his experience to
both govemment and commercial customers, providing them with high quality datameeting the
specified data quality objectives. Mr. Allameh holds a Bachelor's in Engineering from United
States International University at San Diego.
ROBERT WEIDENFELD
Project Manager, Trial Burn Coordinator
Mr. Robert Weidenfeld brings over 20 years experience to the project manager position,
specializing in both source and ambient air monitoring programs. In this role, he functions as the
interface between the client and the laboratory ensuring that QAPP and sampling programs plans
are properly implemented. In addition, Mr. Weidenfeld is the primary laboratory project
manager for the Army Chemical Demilitarization program, managing and coordinating work
from Tooele, Umatilla, Pine Bluff, and Anniston. Mr. Weidenfeld holds a Bachelor's degree in
Agricultural Management from the University of California at Berkeley.
KIRBY GARRETT
Department Manager, Organic Preparations
Mr. Kirby Garrett has over 20 years of bench level and supervisory experience. He is
responsible for the quality assurance and efficiency of the Organic Extraction group. He
oversees the extractions for a wide variety of analyses and matrices including water, soil, solids,
wastes, and tissue. He is conversant with a wide variety of U.S. EPA methodologies including
SW846 organic and inorganic methods. As the Department Manager of Organic Preparations,
Mr. Kirby manages daily operations of the department in the extraction of environmental
samples for analysis by a wide variety of methods and instruments. He participates in daily
production meetings to determine the most efficient manner to complete work by communicating
ATLIC STB Plan - Rev. I
Appendix A
Decemb er 2,2010
TOCDF
Annex C-10
with other areas on capacity. In addition, he identifies priorities for new work as it is received,
and develops and implements new technology and upgrades to increase efficiency. Mr. Garrett
holds a Bachelor's degree in Chemistry from the California State University, San Bernardino.
MICHAEL FLOURNOY
Technical Director, Air Toxics
Mr. Flournoy has over 19 years of experience in the environmental industry with over 8 years in
various managerial positions and 15 years of hands-on experience with high resolution extraction
and gas chromatographyimass spectrometry. As Technical Director of Air Toxics, he works
closely with the corporate and local management team, as well as the sales staff, to identify and
support new opportunities and client management. He is also a member of the laboratory's
Senior Management Team and, as such, participates in the development and implementation of
strategic business plans. Additional responsibilities include proposal preparation, pricing,
contract review, and market development. Mr. Floumoy is also active in application
development for client and laboratory automation. Supported methods include pharmaceuticals
and personal care products by EPA Method 1694; steroids and hormones by EPA Method 1698,
modified; organochlorine pesticides by EPA Method 1699, modified; explosives by EPA Method
8330 and 8330B; nitrophenols by EPA Method 8330, modified; as well as other proprietary
TestAmerica methods. He holds a Bachelor's in Chemical Engineering from University of
California at Davis.
ATLIC STB Plan - Rev. I
Appendix A
Decemb er 2,2010
TOCDF
Annex C-11
AIR TOXICS, ITD., KEY PERSONI\EL RESUMES
Linda L. Freeman
Robert Mitzel
Heidi Hayes
Phua Penney
Sepideh Saeed
James Parker
Melanie Levesque
Ausha Scott
Kyle Vagadori
Bing Wang
ATLIC STB Plan - Rev. 1
Appendix A
Decemb er 2, 2010
TOCDF
Annex C-12
AIR TOXICS, LTD., KEY PERSONNEL RESUMES
LINDA L. FREEIVIAN
Chief Executive Officer and Laboratory (Technical) Director (1)
Ms. Linda L. Freeman is the Technical Director and the Chief Executive Officer of Air Toxics,
Ltd., providing leadership that ensures that the founding mission and core values of the company
are put into practice. Ms. Freeman leads programs relating to the development of long-range
strategy, quality systems, and financial infrastructure. As Technical Director (1), her
responsibilities include: the adminishative review of laboratory operations and qualifications for
the technical positions, ensuring and documenting initial and ongoing proficiency, and
overseeing the Quality systems. Ms. Freeman has over 24 years of combined environmental
experience and20 years of laboratory business management experience. She holds a Bachelor's
degree from Boston College and a Master's Degree in Chemistry from the University of
Wisconsin at Madison.
ROBERT M'ITZF-L
President
Mr. Robert (Bob) Mitzel is the President of Air Toxics, Ltd., and represents the partnership in all
matters. Mr. Mitzel provides day-to-day leadership and management of programs to oversee the
processes and resources necessary for establishing long-range service objectives, plans, and
policies, in cooperation with the CEO and Board of Directors. He is responsible for the
measurement and effectiveness of both internal and external processes by providing accurate and
timely feedback on the operating condition of the company. Mr. Mitzel also directs the
definition and operation of the laboratory production by fostering a suecess-oriented and
accountable environment within the company. A critical component of this is his ability to
motivate and lead a high-perfornance management team capable of meeting both customer
service and bottom-line financial objectives. Mr. Mitzel has over 28 years of combined
environmental laboratory experience. He holds a Bachelor's degree in Chemistry and Biology
from Califomia State University at Chico.
HEIDI C. HAYES
Vice President of Research & Development, and Technical Director (2)
Ms. Heidi C. Hayes is the Vice President of Research & Development and Technical Director (2)
of Air Toxics, Ltd. Ms. Hayes is responsible for developing products and solutiong to meet
client and industry needs. She oversees the validation process to ensure that quality objectives
are met as defined. Her focus is on testing new media, protocols, and technology related to air
phase analysis. She serves as a resource for the regulatory community in evaluating soil gas, and
indoor air sampling and analytical protocols. As Technical Director (2), Ms. Hayes provides
additional oversight for the quality systems and technical performance of the laboratory. Ms.
Hayes has over 17 years of environmental laboratory experience. She holds a Bachelor's degree
TOCDF ATLIC STB Plan - Rev. I
Annex C-13 ,...,ril5:1il$
in Chemistry and Mathematics from Luther College and a Master's degree in Chemistry from the
Colorado School of Mines.
PHUA PENNEY
Laboratory Director
Ms. Phua Penney is the Laboratory Director at Air Toxics, Ltd., and is responsible for the overall
management of laboratory operations and direction in project management. Ms. Penney is
responsible for implementing structures and measurement matrices to facilitate management
communication, prioritization, and feedback as needed to achieve corporate goals. In addition,
she applies experience and judgment in the interpretation and application of customer service
policies and procedures to exceed client expectations, and provides training and technical
support to the project management team. Ms. Penney has over 10 years of laboratory experience
and 5 years of supervisory experience. She has a Bachelor's degree in Biochemistry from the
University of California at Davis.
SEPIDEH SAEED
Laboratory Manager
Ms. Sepideh Saeed is the Laboratory Manager. She is responsible for managing and overseeing
all processes and resources involved in the daily operations of the VOC and SVOC departments.
In addition, she provides technical support to client services, sales, and the laboratory. Ms.
Saeed has 16 years of laboratory experience as a GC, HPLC, GC/MS, and extraction chemist,
and 3 years of supervisory experience; she has been employed at Air Toxics since 1998. Ms.
Saeed has a Bachelor's degree in Biochemistry from the University of California at Davis.
JAMES PARKER
Assistant Laboratory Man ager
Mr. James Parker is the Assistant Laboratory Manager of Air Toxic, Ltd. He is responsible for
data review, SOP creation/updates, development of intemal training programs for laboratory and
sales staff, planning and implementation of special projects, analyzing cause/effect to correct
systemic quality and technical challenges, responses to client inquiries, and content preparation
and performance of intemal audits for the Quality Assurance department. Mr. Parker holds
Bachelor's and Master's degrees from the University of Arizona.
MELANIE LEVESQUE
Quality Assurance Manager
Ms. Levesque is the Quality Assurance Manager at Air Toxics, Ltd., and develops and supervises
programs intended to ensure that the laboratory is producingdata of known and acceptable
quality. Ms. Levesque oversees QC activities including various independent checks of
laboratory systems, SOP generation, and corrective action procedures, as well as monitoring
laboratory certification programs. Ms. Levesque has documented training in the approved
Annex C-14
ATLIC STB Plan - Rev. I
Appendix A
December 2,2010
TOCDF
.O
methods and can verify that the laboratory is following SOPs. She maintains independence from
the operations by not engaging in production activities, and she reports directly to the President.
The QA department conducts a yearly independent.audit of the quality systems and methods
criteria, and notifies laboratory directors of deficiencies via a written quarterly status report. Ms.
Levesque has 8 years of environmental laboratory experience and has worked in a variety of
positions that include analytical and supervisory experience. Ms. Levesque holds a Bachelor's
degree in Chemistry and a Master's degree in Analytical Chemistry, both from the Rochester
Institute of Technology.
AUSHA SCOTT
Project lVlanager
Ms. Ausha Scott is a Project Manager at Air Toxics, Ltd., and is responsible for overseeing all
aspects of project management functions and liaison for goal achievement between clients and
Air Toxics' sales, frnance, and laboratory teams. Ms. Scott has been with Air Toxics for 10
years: 6 years as project manager and 4 years gaining environmental laboratory experience in a
variety of positions, including GC/MS chemistry. She holds a Bachelor's degree in Marine
Biology from the University of California at Santa Cruz.
KYLE VAGADORI
Project Manager
Mr. Kyle Vagadori is a Project Manager at Air Toxics, Ltd., and is responsible for overseeing all
aspects of project management functions and liaison for goal achievement between clients and
Air Toxics' sales, finance, and laboratory teams. Prior to joining Air Toxics in 2005, Mr.
Vagadori spent 4 years as a technical service representative in chemical grouping, waste
profiling, disposal options, RCRA, DOT, CallEPA TrtleZ},regulation, and compliance. He also
performed environmental specialist duties including manifesting, lab packing, labeling, loading,
and coordinating transportation; and sampling/profiling bulked and drummed waste streams.
Mr. Vagadori holds a Bachelor's degree in Environmental and Resource Sciences from the
University of California at Davis.
BING WANG
Information Technology Man ger
Mr. Bing Wang joined Air Toxics in 2009 as the Information Technology Manager. Mr. Wang
oversees all aspects of software engineering and development, database administration, and
network administration. He brings more than 12 years information technology experience to our
organization, including 10 years of commercial software development experience. His expertise
spans all aspects of direction, design, development, and implementation of customized
Laboratory Information Management Systems in an FDA Good-Laboratory-Practices-regulated
environment. Mr. Wang has been instrumental in designing and implementing model work flow
processes, defining user requirements, and proposing software design and implementation to
satisfy long-term company business goals. He has established policies and procedures to ensure
continuous database and server environment integrity and reliability. Mr. Wang holds a Master's
ATLIC STB Plan - Rev. I
Appendix A
Decemb er 2, 2010
TOCDF
Annex C-15
degree in Civil Engineering from the University of Califomia at Berkeley, and Master's and
Bachelor's degrees in Engineering from Central South University of Technology, China.
JEFFREY TECSON
Support Services Team Leader
Mr. Jeffrey Tecson is the Team Leader for the Support Services Team. This team is responsible
for cleaning and coordinating the certification of Summa, Silco, and Silonite Canisters. Other
responsibilities include preparation of flow controllers, TO-17 tubes, and VOST/SMVOC tubes
for Methods 0030 and 0031. Mr. Tecson has 11 years of management experience and five years
experience in bench work for Support Services; currently Mr. Tecson is spending 25 o/o of his
time on the bench. Mr. Tecson has an A.S. in Computer Technology from Heald College at
Rancho Cordova, California.
JEET GREWAL
Lead Scientist, VOST Analysis
Mr. Grewal has beep the Lead Scientist in VOST and TO-17 analysis for the last 10 years at Air
Toxics, Ltd., and he has extensive experience with VOST trial burn projects. His duties include
routine VOST analysis and data write up, work scheduling, and implementation of project
specific QA/QC requirements. Mr. Grewal is actively involved with staff training and teaching
VOST training classes. He is very experienced with instrument maintenance, troubleshooting,
solving analyical and technical problems, and method development involving VOST and TO-17
analysis. Prior to Air Toxics, Ltd., Mr. Grewal gained eight years of experience as a GC and
GC/MS chemist, including four years as a group leader in an environmental laboratory. He
holds a Master's degree in Organic Chemistry.
TIMOTHY SANFELICE
MS Interpretation Specialist
Timothy Sanfelice is a Scientist on the GC/MS Volatiles team. He is responsible for the
operation, calibration, and maintenance of the GC/MS quadrupole systems. In addition to
analyzing environmental air samples and standards for VOCs, he reduces the data acquired from
these analytical mainframes. Mr. Sanfelice takes a lead role in trouble-shooting and solving any
hardware/instrument problems that arise. In addition, he participates in method development
projects and evaluations. Mr. Sanfelice has worked in several Senior Chemist positions, where
his responsibilities included method development, equipment maintenance and repair, data
review, and report generation. He has over 18 years experience in the environmental laboratory
field. Mr. Sanfelice holds a Bachelor's degree in Chemistry with a minor in Biology from
California State University at Sacramento.
TOCDF ATLIC STB Plan - Rev. I
Appendix A
December 2,2010Annex C-16
o
o
o
O TOOELE CHEMICAL AGENT DISPOSAL
FACILITY (TOCDF)
ST.IRROGATE TRIAL BTIRI{ PLAN
FORTHE
AREA 10 LIAUD INCINERATOR
APPEI\DIX B
ATLIC SHAKEDOWN PLAN
REVISION 1
Decemb er 21 2010
TABLE OF CONTENTS
1.0 INTRODUCTION ...,.,..,.1
2.0 PREPARATORY ACTIVITIES............. .................. ............3
3.0 GENERAL SHAKEDOWN ACTTVITIES .......,4
4.0 ATLIC SHAKEDOWNACTIVITIES ...............5
5.0 POST-ATLIC STB ACTIVITIES............. ..........7
ATLIC STB Plan - Rev. I
Appendix B
Decemb er 2, 2Al0
TOCDF B-i
INTRODUCTION
The Tooele Chemical Agent Disposal Facility (TOCDF) was designed and built as a
hazardous waste disposal facility for the U.S. Army. The TOCDF is designed to dispose
of chemical Agents GB, VX, and Mustard (H-series), drained munitions, contaminated
refuse, bulk containers, liquid wastes, explosive, and propellant components, which are all
apart of the chemical agent stockpile at the Deseret Chemical Depot (DCD). The DCD is
located 20 miles south of Tooele, Utah. EG&G Defense Materials, Inc. (EG&G), operates
the TOCDF under contract to the U.S. Army through the Chemical Materials Agency
(cMA).
The TOCDF consists of five different Hazardous Waste Incinerators that are currently
processing the DCD mustard stockpile. The TOCDF incinerator will complete processing
the DCD mustard stockpile in mid to late 20L1.
EG&G also will operate the Area 10 Liquid Incinerator (ATLIC), which is located within
the DCD chemical munition storage area that is adjacent to the TOCDF. The ATLIC is
being designed and constructed to process the 4 ton containers (TCs) of Agent GA, the l0
TCs of Lewisite, and up to 10 TCs referred to as "Transparency" TCs, some of which
previously contained Lewisite.
The ATLIC Shakedown will begin after approvals for the Surrogate Trial Bum (STB) and
Lewisite Comprehensive Performance Test are received from the Executive Secretary of
the State of Utah, Department of Environmental Quality (DEQ), Division of Solid and
Hazardous Waste (DSHW) and approval by the Division of Air Quality (DAQ). The
wastes that will be processed during the shakedown period are a surogate mixture of
chlorobenzene and tetrachloroethene (with metals spikes) and simulated spent
decontamination solution (spent decon) comprised of 2 Yo percent sodium hydroxide and
10 % sodium chloride to simulate the ash loading from buming Agent GA.
The ATLIC includes a primary combustion chamber (PCC) followed by a secondary
combustion chamber (SCC). Exhaust gas from the SCC is routed to the Pollution
Abatement System (PAS), which consists of a quench tower, followed by a series of low-
energy packed bed scrubbers. The scrubbers are followed by a high-energy venturi
scrubber, moisture separator, exhaust gas re-heater, baghouse, fixed-bed carbon filter, and
finally, an induced draft (ID) fan.
The initial ATLIC Shakedown operations will be processing the surrogate mixture. The
objectives of the ATLIC Surrogate Trial Burn (STB) Shakedown are to:
. Demonstrate that the ATLIC can successfully and efficiently destroy the surrogate
mixture at the proposed permitted feed rates.
ATLIC STB Plan - Rev. I
Appendix B
Decemb er 2,201 0
TOCDF
B-1
. Familiari ze the operators with the actions and process steps necessary to process
Agent GA through handling and processing a less toxic substance (i.e., the
surrogate mixture).
. Evaluate the ATLIC operating conditions relative to regulated ATLIC Operating
Parameter Limits (OPLs) and waste feed rates.
. Evaluate the impact on the SCC of simultaneously processing a highly-chlorinated
surrogate mixture and spent decon.
ATLIC STB Plan - Rev. I
Appendix B
Decemb er 2, 2010
TOCDF
B-2
PREPARATORY ACTIVITIES
The ATLIC will only process Agent GA, Lewisite, and Transparency TCs. There are 4
GA TCs, 10 Lewisite TCs, and 10 Transparency TCs. In a2009 study, the Transparency
TCs were found to be empty, based on attempts to obtain samples followed by taking
boroscope pictures that verified the TCs were empty. The Transparency TCs were
sampled and no liquid or solid samples could be collected from the TCs, indicating that
they do not contain any liquids or solids; however, they may have once contained Lewisite.
In addition, the duration of the ATLIC agent campaigns will be much shorter than the
TOCDF agent campaigns.
The CMA requires that agent and munition-specific Operational Readiness Reviews
(ORRs) be conducted prior to the start of actual operations. During an ORR, all related
procedures are reviewed and tested; the operators execute the processing activities
according to procedures as ORR team members observe their actions. Agent draining and
transfer operations are simulated using ethylene glycol or water. The procedures are
further reviewed to ensure that environmental regulatory requirements are incorporated
into the procedures.
Issues arising during the ORR are required to be closed according to a timetable and prior
to the start of hazardous waste operations.
Because Agent GA will be fed shortly after the completion of the STB (i.e., upon approval
by the Executive Secretary of ATLIC STB preliminary data), and because the GA
Campaign is so brief (about 5 days), the function and operation of the Agent GA and
Lewisite agent monitoring system and associated procedures will be included in the same
ORR. The ORR findings associated with the agent monitoring systems may not
necessarily o-e closed prior to the start of hazardous waste operations with surrogate
mixture feed. Any findings associated with a specific chemical agent will be closed prior
to processing that agent.
ATLIC STB Plan - Rev. I
Appendix B
Decemb er 2, 2010
TOCDF
B-3
GENERAL SHAKEDOWN ACTIVITIES
The DSHW will be provided with two weeks notice before feeding the surrogate mixture.
The surrogate mixture is intended to be processed in the same manner as planned for Agent
GA. This will include adding the components of the mixture to a TC, and then mixing the
contents by rotating the TC. The surrogate mixture will be fed from TCs placed in the
ATLIC gloveboxes. This will familiarize operators with the Agent GA processing steps
using less toxic chemicals than Agent GA.
The ATLIC STB Shakedown Period is estimated to last less than 720 hours; however,
TOCDF requests 720 hours of shakedown in case additional time will be necessary to
ensure operational readiness before the STB. An extension of 720 additional hours of
operating time may be requested, if necessary, as allowed by the governing regulations and
TOCDF RCRA Permit, but the additional 720 hours will need to be approved by the
DSHW Executive Secretary before any operation beyond the original 720 hours of
shakedown.
Additionally, TOCDF may request final modifications to the ATLIC
the shakedown operational experience. Changes to the test plan will
DSHW.
Collection and analysis of samples during the shakedown period will
in the Waste Analysis Plan.
STB Plan based on
be coordinated with
follow the directions
ATLIC STB Plan - Rev. 1
Appendix B
Decemb er 2, 2010
TOCDF
ATLIC SHAKEDOWN ACTIVITIES
Surrogate feed to the ATLIC Primary Combustion Chamber (PCC) will be incrementally
ramped-up. At each feed increment, with each increment being a greater percentage of the
approved STB Plan feed rate limit, the feed rate will be held for a sufficient period of time
to evaluate the stability of each of the regulated operating parameter values. For each
regulated operating parameter, if the process value does not exceed the associated OPL, the
feed increment will be increased.
If OPLs are being approached relative to the magnitude of the waste feed rate, adjustments
to the incineration process will be made and an evaluation of the affects of the adjustments
made will be performed before the feed increment is increased again. The surrogate feed
rate to the ATLIC will be increased in this manner until the maximum feed rate of 325
pounds/hour (lbftr) is attained.
Although all the regulated operating parameters must be within the operational envelope
created by the OPLs (i.e., Automatic Waste Feed Cutoff setpoints), for surrogate mixture
feed, the pertinent regulated Operating Parameters are:
PCC Exhaust Gas Temperature;
Secondary Combustion Chamber (SCC) Exhaust Gas Temperature,
Packed Bed Scrubber Solution pH;
Venturi Scrubber Differential Pressure;
Exhaust Gas Flow Rate;
Exhaust Gas CO Concentration;
Exhaust Gas Oz Concentration.
In addition to those listed above, during times when metals spikes or spiking solutions are
fed with the surrogate mixture, the pertinent regulated OPLs are:
Pre-Baghouse Exhaust Gas Temperature;
Powdered Activated Carbon feed rate;
Baghouse Differential Pressure; and
o Fixed Bed Carbon Filter Differential Pressure.
TOCDF ATLIC STB Plan - Rev. I
Appendix B
Decemb er 2,2010B-5
Once the maximum sustainable surrogate feed rate has been determined and demonstrated,
the same procedure will be used to determine the maximum sustainable spent decon feed
rate. Note that it is intended to simultaneously feed wastes (i.e., surrogate mixture or
agents, and spent decon) to the PCC and SCC, respectively.
ATLIC STB Plan - Rev. 1
Appendix B
Decemb er 2,201 0
TOCDF
B-6
POST.ATLIC STB ACTIVITIES
Following completion of the ATLIC STB, any unused surrogate mixture remaining in TCs
and any unused spent decon will be fed to the ATLIC PCC and SCC, respectively, at half
the rate demonstrated during the STB. After the unused surrogate mixture and spent decon
have been treated, waste feed to the ATLIC will be stopped. Feed to the ATLIC will
resume upon approval of the ATLIC STB preliminary data package by the DSHW and
DAQ. The waste feeds shall be Agent GA and GA-derived spent decon. The feed rates of
each of the waste feeds shall be limited to half of the rate demonstrated during the ATLIC
STB. The restricted feed limits will ensure that the emissions are below the Hazardous
Waste Combustor Maximum Achievable Control Technology emission limits during
Agent GA processing.
ATLIC STB Plan - Rev. I
Appendix B
December 2,2010
TOCDF
B-7
,IJ
tlo
E)o.
Xo
TOOELE CHEMICAL AGENT DISPOSAL
FACILITY
(TOCDF)
SURROGATE TRIAL BURN PLAN
FORTHE
AREA 10 LIQUID INCINERATOR
APPENDIX C
MASS AND ENERGY BALANCES FOR ATLIC STB AND EXHAUST
GAS RESIDENCE TIME CALCULATIONS
REVISION 1
December 21 2010
Figure C- I
Figure C-2
LIST OF FIGURES
ATLIC Incinerator Process Flow Diagram................ .......... C-l
ATLIC Pollution Abatement System p.or"r, Flow Diagram............. ...C-2
Table C-l
Table C-2
LIST OF TABLES.
ATLIC STB Maximum Feed Mass and Energy Ba1ances..................... C-3
ATLIC Exhaust Gas Residence Time Calculation for Surrogate Trial Burn
Maximum Feed.......... .................... C-5
c-i ATLIC STB Plan - Rev. 1
Appendix C
Decembe( 2,2010
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TOOELE CHEMICAL AGENT DISPOSAL
FACILITY
(rocDF)
SURROGATE TRIAL BURN PLAN
FOR THE
AREA 10 LIQUID INCINERATORS
APPENDIX I)
AUTOMATIC WASTE FEED CUTOFF TABLES AND OPERATING
CONDITION TARGET VALUE TABLES FOR AREA 10 LIQUID
INCINERATOR
REVISION 1
December 21 2010
LIST OF TABLES
Table D-l ATLIC Liquid Incinerator Automatic Waste Feed Cutoff ..................... D-l
ATLIC STB Plan - Rev. 1
Appendix D
December 2,2010
Table D-l
ATLIC LIQUID INCINERATOR
AUTOMATIC WASTE FEED CUTOFF
tGmri::Nuimbref:trag:.NifiimbEf
I 307-FI-8430 Waste Feed Rate Greater Than or Equal to 325lblfu (Surrogate) one-hour rolling average
22-Pr-8410 A.gent Atomizing Air Pressure Less Than 35 psig
t5-TIC-8471 ?rimary Chamber Temperature Less Than 2550'F, one-hour rolling average
29-FtT-852r pent Decon Feed Rate Greater Than or Equal to 550 lb/hr over one-hour rolling average
22-Pr-85tr pent Decon Atomizing Air Pressure Le;s Than or Equal to 35 psig
15-TIC-8571 econdary Chamber Temperature Less Than 1850' F, one-hour rolling average
t9-FI-8932 lxhaust Gas Flow Rate (Unit Production Rate) Greater Than or
Squal to
>960 scfin, one-hour rolling average
t9-PI-8982 crubber Brine Pump Pressure Less Than or Equal to 25 psig
l9-FI-8921 ilow to Scrubber Tower #1 Less Than or Equal to 40 gpm, one-hour rolling average
l0 t9-Ft-8922 ilow to Scrubber Tower #2 Less Than or Equal to 40 gpm, one-hour rolling average
u l9-FI-8923 llow to Scrubber Tower #3 Less Than or Equal to 40 gpm, one-how rolling average
12 l9-PDI-891I crubber # I Pressure Drop Less Than or Equal to 0.3 in. w.c., one-hour rolling average
l3 t9-PDI-8912 crubber #2 Pressure Drop Less Than or Equal to 0.3 in. w.c., one-how rolling average
l4 l9-PDI-8913 crubber #3 Pressure Drop Less Than or Equal to 0.3 in. w.c., one-hour rolling average
l5 t9-Fr-8924 Brine to Venturi Scrubber Flow Less Than or Equal to 8 gpm one-hour rolling average
t6 l9-PDI-8915 Venturi Exhaust Gas Pressure Drop Less Than or Equal to 12 in. w.c., one-hour rolling average
t7 9-AIC-8917 Venturi Brine pH Less Than to Equal to 7 pH, one-hour rolling average
l8 9-AIC-8927 Venturi Specific Gravity Greater Than or Equal to 1.28 SGU, twelve-hour rolling average
19 t9-PI-8956 Venturi Pump Pressure Less Than or Equal to < 25 psig
z0 rg-AIC-8952 Scrubber Brine pH Less Than to Equal to 7 pH, one-hour rolling average
I l9-AI-8983 Brine Specific Gravity Greater Than or Equal to 1.28 SGU, twelve-hour rolling average
2 r9-TI-8931 Bag House Inlet Temperature Greater Than or Equal to 240o F, one-hour rolling average
J l9-PDI-8936 Bag House Pressure Drop Less Than or Equal to 1 in. w.c., one-hour rolling average
4 l9-FI-8933 Sarbon lnjection Feed Weight Less Than or Equal to <.5 lbsihr., one-hour rolling average
5 l9-FI-8940 Carbon Injection Air Flow Less Than or Equal to l5 SCFM, one-hour rolling average
6 19-PDI-8941 18942 larbon Filter Pressure Drop Less Than or Equal to 0.3 in. w.c., one-hour rolling average
[te-rr-8e3e I
lCarbon Filter Inlet Temperature Greater Than or Equal to
I
>.240" F, one-hour rolling average
I
: 100 ppm., one-hour rolling average, corrected to7%oo,2,
lry volumed
I I
3o/o Oz
I
I ls%o 02
D-1 ATLIC STB Plan - Rev. 1
Appendix D
December 2,2010
Table D-l
ATLIC LIQUID INCINERATOR
AUTOMATIC WASTE FEED CUTOFF
0a TEN 7O8AK tack Exhaust GA Agent Detect Greater Than or Equal to :0.2 SEL'f
0b TEN 7O8BK tack Exhaust GA Agent Detect Greater Than or Equal to z 0.2 SEL
0c TEN 7O8CK tack Exhaust GA Agent Detect Greater Than or Equal to :0.2 SEL"f
1a TEN 7O9AL tack Exhaust Lewisite Agent Detect Greater Than or Equal to :0.2 SEL"f
lb TEN 7O9BL tack Exhaust Lewisite Agent Detect Greater Than or Equal to t 0.2 sEL'l
lc TEN 7O9CL Stack Exhaust Lewisite Agent Detect Greater Than or Equal to :0.2 SEL"'
2 VOL.I2HR-ATLIC Volatile Metal (Hg) Greater Than or Equal to z 0.70 lb/12 hr trvelve-hour rolling average
3 V-I2HR.ATLIC Semi-Matile (Pb+Cd) Greater Than or Equal to 0.39lbl12 hr twelve-hour rolling average
4 LV.I2HR.ATLIC Low-Volatile (As+Be+Cr) Greater Than or Equal to 1156lbl12 hr turelve-hour rolling average
5 A.SH.l2HR.ATLIC A,sh Greater Than or Equal to 1536lbl12 hr twelve-hour rolling average
)6 VIC.I2HR.ATLIC lhlorine Greater Than or Equal to 2298lb/12 hr twelve-hour rolling average
Footnots:
' Logic code description used to set thc control WFCO alms.
' Rolling average mems the average of all one-minute averages over the averaging period. A one-minutE average mems the averages of detector resporoes calculated at leNt ever
i0 seconds from responses obtained at le6t every 15 seconds.
Waste feed cut-olTs recordcd upon switch activation.
L One hou rolling average is oomposed ofthe 60 most recent one-minute averages. Each one-minute average is composed ofthe 4 most recent instmtaneous CO process vriable
)ccming at ls-second intervsls.
An Automatic WFCO occus if the two onJine ACAMS/IT4INICAMS ue not staggered so that at leffit one uit is mpling the stack.
The alm setting (in mg/m3) for GA is 0.00006 md L is 0.006
ATLIC STB Plan - Rev. 1
Appendix D
December 2,2010
D-2