Loading...
HomeMy WebLinkAboutDSHW-2024-007866TOOELE CHEMIGAL AGENT DISPOSAL FACILITY (TOCDF) HAND ITLIVEffiED DEC t' 3 2010 UTAH Dlv-lEl9l'f 0F .....-mltzol'::ly,usTE Ipo[0, Mtrlt { Il*** ,i , ,{ P,...,* , *! .,. v'' :g$ tqr *$,hrlr LEWISITE GOMPREHENSIVE PERFORMANCE TEST PLAN FOR THE AREA 10 LIQUID INGINERATOR (Fulfilling Requirements of the RCRA, Title V, and MACT Regulations) Revision 1 December 2, 2010 EG&G Division REPLY TO ATTENTION OF DEPARTMENT OF THE ARMY US, ARMY CHEMICALS M,ATERIAL AGENCY TOOELE CHEMICAL AGENT DISPOSAL FACILITY 11620 STARK ROAD STOCKTON, UT 84071 DEC 1 g 20t0 iEHffi $ s trffit& IJTAH []tvh$l0t{ 0$; $OLID & I{AZARDOIJS WASTE J0 l0. 0bw[ [I 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 i0 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 concerning 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 (NRT) 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, respeclively to 0.2 SEL for each agent.^ The SEL value for Lewisite remains at 0.03 milligrbms per cubic meter (0.03 mg/m3). . The ATLIC Surrogate Trial Bum (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 Printed "" @ 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. c 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. . r 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 perforrnance 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 monitoring 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 l, 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 concerning as soon as possible The points of conlact in this matter are Ms. Sheila *. tun." at (435) 833-7577 or Mr. Trace Salmon at (a35) 833-7428. Sincerely, dM-k,ff{- PC&G Defense Materigls, Inc. Thaddeus A. Ryba, Jr. TOCDF Site Project Manager *CERTIFICATION STATEMENT* CERTIFICATION STATEMENT Enclosure r r cERTlFy uNDER pENALTv oF LAw rHAT THrs Dotur*renr lxo lrL ATTAcHMENTs wERE pREpARED UNDER My DtREcrror on surrnvrsroN rN AccoRDANca wrrH A sysrEM DESIGNED To AssuRE THAT eUALIFIED PERSoNNEL pRopERLv GATHER AND EVALUATE THE tNFoRMATtoN suBMrrrED. BAsED oN My rNeurRy or rHE pERsoN oR pERsoNs wHo MANAcE THE sysrEM. oR THosE pERsoNs DrREcrLv nesponslpr.E FoR cATHERTNc rHE INFORMATION. THE INFORMATION SUBMITTED lS. TO THE BEST OF MY KNOWLEDCE AND BELIEF; TRUE, ACCURATE AND COMPLETE. I AM AWARE THAT TIIERE ARE SIGNIFICANT PENALTIES FOR SUBMITTING FALSE INFORMATION, INCLTJDING THE ?C'SSTBILITY OF FTNE AND IMPRISONMENT FOR KNOWING vtotATIoNs. TOOELE CHEMICAL AGEI{T DISPOSAL FACILITY (TOCDF) LEWISITE COMPREHENSIVE PERFORMANCE TEST PLAN FOR THE AREA 10 LIQUID INCINERATOR Revision I December 212010 EXECUTIVE SUMMARY The Tooele Chemical Agent Disposal Facility (TOCDF) was designed and built for the United States (U.S.) Army to destroy 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 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 andHazardous 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 a new incinerator, the Area 10 Liquid Incinerator (ATLIC), to demonstrate the arsenic feed rate associated with a Lewisite feed rate of 300 lb/hr. The Lewisite Comprehensive Performance Test (LCPT) will be conducted at the same operating conditions as the ATLIC Surrogate Trial Burn (STB), but with Lewisite as the feed rather than Agent GA; Lewisite has higher arsenic, ash, and mercury feed rates. This test will demonstrate these increased feed rates of arsenic, ash, and mercury to fulfill the air permit requirements of 40 Code of Federal Regulation (CFR) 63, Subpart EEE [i.e., Hazardous Waste Combustors (HWC) Maximum Achievable Control Technology (MACT) regulationsl. A Destruction and Removal Efficiency (DRE) for the ATLIC was demonstrated with chlorobenzene as part of the ATLIC STB and, therefore, there is no reason to demonstrate another DRE. Test results will demonstrate compliance with the MACT arsenic, mercury, and particulate matter emission concentration limits that are specified in the HWC Final Replacement Standards for New Sources that were published in the Federal Register, October 72,2005, and finalized in October 2008. The LCPT will be conducted at the same operating conditions as the ATLIC STB, and will collect exhaust gas samples for particulate matter, hydrogen chloride, chlorine, metals, polychlorinated dibenzo-p-dioxins/polychlorinated dibenzofurans, and nitrogen oxides. This LCPT will demonstrate that the higher arsenic, ash, and mercury feed rates do not impact the ability of the ATLIC to meet the regulatory limits. LCPT Plan - Rev. I Decemb er 2,2010 TOCDF ES-1 TABLE OF CONTENTS iiiisiffiffis*}^*t".8#**lldilt::::::: :::::: ::::::::: :::: :::::::::::::::::::.:.:::.:::::::::::::::.:::::....::::I LIST OF CHEMICAL SYMBOLS AND FORMULAS ...............,............X LIST OF IDENTIFICATION CODES FOR LIQUID INCINERATOR INSTRUMENTS MONITORING REGULATED OPERATING PARAMETERS ............. .......................... xi I.I LEWISITE COMPREHENSIVE PERFORMANCE TESTPLAN ORGANIZATION.................................... 3 I.2 FACILITYINFORMATION........... ,,,...,.3 1.3 WASTE TREATMENT SYSTEM PROCESS AND FEED DESCRIPTIONS............... ..,..,,...... 4 1.3.1 Waste Handling and Storage.. ......... 4 L j. j Pollution Abatement System........ ......................... 6 1.4 WASTES TO BETREATED............. ..........:................ 6 1,5 LEWISITE COMPREHENSIVE PERFORMANCE TEST OBJECTIVE .............. 8 I.6 LEWISITE COMPREHENSIVE PERFORMANCE TEST APPROACH .............. 9 1.7 LCPT SAMPLING AND ANALYTICAL PROTOCOLS .................. .................... 9 2.0 DETAILED ENGINEERING DESCRIPTION OF THE ATLIC .......................1I 2.1 PRIMARY COMBUSTION CHAMBER .................. ...,.................. t '2.2 SECONDARY COMBUSTION CHAMBER. .i................... ,..,.,,,,,,.12 2.3 DESCRIPTION OF THE WASTE FEED NOZZLES AND GAS BURNERS................ ........... 13 2.4 DESCRIPTION OF THE AUXILIARY FUEL SYSTEM............... ...................... 14 2.5 TONCONTAINERDRAINANDRINSESYSTEM ...................... 14 2.5.1 Agent GA TC Drain and Rinse 5ystem......,... .......................... /5 2.5.2 Lewisite TC Drain and Rinse System .................. 16 2.5.3 Transparency TCs Decontamination 5ystem.......... ...,...,,..,...... 17 2.6 DESCRIPTION OF THE WASTE FEED SYSTEMS... ,..,.,,,..,.,...... 17 2.7 HEATING,VENTILATION,ANDCOOLINGSYSTEM ...,.......... 18 2.8 DESCRIPTION OF THEAUTOMATIC WASTE FEED CUTOFF SYSTEM ......,.................. 19 2.9 EXHAUST GAS MONITORING EQUIPMENT.................. ..........23 LCPT Plan - Rev. I Decemb er 2,201 0 TOCDF TABLE OF CONTENTS (continued) 2.IO POLLUTIONABATEMENT SYSTEM..... ..,.....,,,.,.26 2.10.2 Packed Bed Scrubber System/Brine Chiller System .............. 27 2.10. j High-Energt Venturi Scrubber/ Moisture Separator................ ................. 28 2.10.4 Exhaust Gas Electric.Reheater... .....,.................28 2.10.5 Powdered Activated Carbon Injection System 29 2. I 0.7 Carbon Filter System 29 2.ll CONSTRUCTIONMATERIALS;...... ...................... 30 2.12 LOCATION AND DESCRIPTION OF TEMPERATURE, PRESSURE, AND FLOW INDICATING AND 2.12.2 PCC Agent Feed Rate Control..... .................... 34 2.12.3 PCC Pressure Control. ...,..,......... i4 2.12.4 PCC Exhaust Gas Temperature and Burner Controls....... ......................... Sq 2. 1 2.5 SCC Exhaust Gas Temperature and Burner Control ......... ......................... 3.t 2.12.6 SCC Spent Decon l(aste Feed Control......... ......................... 35 2.12.8 Venturi Scrubber lilater Flow ...... 35 2.1 2. 1 0 Venturi Scrubber Dffirential Pressure.................. .............. i6 2.12.11 Scrubber Tower Sump Level Control .................... ................;.... . . . ... 36 2.12.12 Baghouse Pressure Drop............. .................... i6 2.12.13 Carbon Filter System Dffirential Pressure....... ,................. 36 2.12.14 ATLIC Exhaust Gas Oxygen Concentration,............... ........ 37 2.l2.]5ATLICExhaustGasCarbonMonoxideConcentration......,.,'......... 2. I 2. I 6 ATLIC Exhaust Gas Flow Rate ............. ......... 37 2.12.17 Uninterruptable Power Supply 5ystem.......... .......................37 2.13 INCINERATIONSYSTEMSTARTUPPROCEDTTRES................ .,................,37 2.1i.1 Startup of the ATLIC Pollution Abatement,s/sr.............. ...... 38 2. 1 3.2 Startup of the PCC/SCC ................ ................... 38 2.13.3 Initiation of Primary Waste Feed............. ........ 39 2.13.4 Initiation of Spent Decon Feed............. ........... 39 2.14 EMERGENCY/PLANNED SHUTDOWNS............ ...................... 40 1l LCPT Plan - Rev. I Decemb er 2, 2010 TOCDF TABLE OF CONTENTS (continued) 3.0 SAMPLING AND ANALYSIS PROCEDURES................... ...........41 3.1 SAMPLING LOCATIONS.........,..... .......................... 4l 3.2 SAMPLING METHODS................... ...............,.......... 43 3.3 ANALYSISMETHODS............... .........44 4.0 LEWISITE COMPREHENSIVE PERFORMANCE TEST SCHEDULE .........45 5.0 LEWISITE COMPREHENSIVE PERFORMAI\ICE TEST PROTOCOLS.................. ,,......46 5.I WASTECHARACTERIZATION .,..,,..,46 5.1.1 Lewisite Agent l\aste Feed... :.................... .......... 46 5.1.2 Spent Decontamination Solution lilaste Feed.. ........................ 46 5.3 TEST PROTOCOL AND OPERATING CONDITrONS................... ................... 48 5.4 COMBUSTIONTEMPERATURERANGES............. ....................49 5.5 WASTE FEED RATES AND QUANTTTIES OF WASTES TO BE BURN8D..,.....,....... .........49 5.6 EXHAUST GAS VELOCITY INDICATOR .............. 50 5.8 WASTEFEEDASHCONTENT ...........51 5.9 ORGANIC CHLORINE CONTENT OF THE WASTE FEED ........ 51 5.10 METALSFEEDRATES........ ..............51 5.11 POLLUTIONCONTROLEQUIPMENTOPERATTONS......... .........................53 5.I2 SHUTDOWNPROCEDURES...... .......53 5.13 INCINERATORPERFORMANCE. ......................... 54 6.0 LEWISITE SHAKEDOWN PROCEDURES .............55 6.1 STARTUPPROCEDURES.............. ......55 6.3 POST-LCPT-BURN OPERATION ..,,...57 ,6.4 INCINERATORPERFORMANCE. ......58 7.0 LEWISITE COMPREHENSIVE PERORMANCE TEST RESULTS... ............59 LCPT Plan - Rev. I Decemb er 2,2010 LIST OF APPENDICES APPENDIX A. LCPT QUALITY ASSURANCE PROJECT PLAN APPENDIX B. LCPT SHAKEDOWN PLAN APPENDIX C. MASS AND ENERGY BALANCE FOR THE AREA IO LIQUID INCINERATOR LEWISITE DEMONSTRATION TEST AND EXHAUST GAS RESIDENCE TIME CALCULATIONS APPENDIX D. AUTOMATIC WASTE FEED CUTOFF TABLES AND OPERATING CONDITION TARGET VALLIE TABLES FOR THE AREA 10 LIQUID INCINERATOR LCPT Plan - Rev. I Decemb er 2,2010 1VTOCDF 1-1 2-t 2-2 3-t 5-1 5-2 5-3 LIST OF TABLES Lewisite Characteization Summary............. .................7 ATLIC Construction Materials ..................31 Instruments Calibration Frequency................ ..............33 ATLIC Exhaust Gas Sampling Summary ..................:.42 Lewisite Properties.. .................47 Waste Feed Requirements.... ......................50 LCPT Estimated Metals Feed Rates and Emission Rates.... ..........52 LCPT Plan - Rev. 1 Decemb er 2,201 0 ACAMS AHU ASTM ATB ATLIC AWFCO BMS Brine CAL CEMS CFR CMA CPT Pftr1v15 DAQ DCD DEQ DF'S DI DRE DSHW EG&G EPA E-stop ETL FCS FSSS GC GC/MS HAP HEPA HHRA HRGC/HRMS HVAC LIST OF ACRONYMS AND ABBREVIATIONS Automatic Continuous Air Monitoring System Air Handling Unit ASTM International Agent Trial Burn Area 10 Liquid Incinerator Automatic Waste Feed Cutoff Burner Management System Wet Scrubber Recirculation Brine Chemical Assessment Laboratory Continuous Emission Monitoring System Code of Federal Regulations Chemical Materials Agency Comprehensive Performance Test Depot Area Air Monitoring Systems Department of Environmental Quality (State of Utah), Division of Air Quality Deseret Chemical Depot State of Utah, Department of Environmental Quality Deactivation Furnace System Deionized (as in deionized water) Destruction and Removal Efficiency State of Utah Department of Environmental Quality, Division of Solid and Hazardous Waste EG&G Defense Materials, Inc. U.S. Environmental Protection Agency Emergency Stop Extreme Temperature Limit Facility Control System Flame Safety Shutdown System Gas Chromatograph Gas Chromatograph/Mass Spectrometer Hazardous Air Pollutant High Efficiency Particulate Air Human Health Risk Assessment High Resolution Gas Chromatograph/High Resolution Mass Spectrometer Heating, Ventilation, and Cooling LCPT Plan - Rev. 1 Decemb er 2, 2010 TOCDF VI LIST OF ACRONYMS AllD ABBREVIATIONS (continued) HWC Hazardous Waste Combustor HRA Hourly Rolling Average IC Ion Chromatography ICPA{S Inductively Coupled Plasma/Mass Spectrometry ID Induced Draft LCPT Lewisite CPT LIC Liquid Incinerator LOQ Limit of QuantitationMACT Maximum Achievable Control Technology MEB Mass and Energy Balances MPF Metal Parts Fumace MRE Metals Removal Efficiency NDIR Non-Dispersive Infrared NOC Notifications of Compliance NRT Near Real Time PAC Powdered Activated Carbon PAS Pollution Abatement System PCC Primary Combustion Chamber P&ID Piping and Instrument Diagram PLC Programmable Logic Controller PM Particulate Matter Principal Organtc Hazardous Constituent Performance Specifi cation Test Quality Assurance Quality Assurance Project Plan Quality Control Quality Plant Sample Utah Administrative Code Section 3 15 Resource Conservation and Recovery Act Secondary Combustion Chamber Standard Operating Procedure Spent Decon Spent Decontamination Solution POHC PST QA QAPP QC QP R3 15 RCRA SCC SDS SOP STB SVOC sw-846 Surrog ate Trial Burn S emi-Volatile Organic Compound Test Methods for Evaluating Solid Waste, 3rd Edition including Update IV, USEPA, SW-846, February 2007. LCPT Plan - Rev. 1 Decemb er 2,2010 TOCDF vii TC TE-LOP TEQ TOCDF TOX TSCA TSDF UPS U.S. VFD VOC VSL WCL XSD LIST OF ACRONYMS AND ABBREVIATIONS (continued) Ton Container Tooele Laboratory Operating Procedure Toxic Equivalent Concentration Tooele Chemical Agent Disposal Facility Toxic Cubicle Toxic Substances Control Act Treatment Storage and Disposal Facility Unintemrptible Power Supply United States Variable Frequency Drive Volatile Organic Compound Vapor Screening Limit Waste Control Limit Halogen-Specific Detector LCPT Plan - Rev. 1 Decemb er 2, 2010 TOCDF viii acfm Btu/hr Btu/lb cP cfm OC OF dscf dscfm dscm ft ft3 ob g/sec gal gpm grldscf hp inHg inWC L Llm tb pg *3 mg mL N ng ppb ppm ppmdv lb/hr psi psig scfm AP wt% LIST OF UNITS AND MEASUREMENTS actual cubic feet per minute British thermal units per hour British thermal units per pound centiPoise cubic feet per minute degree centigrade degree Fahrenheit dry standard cubic foot dry standard cubic feet per minute dry standard cubic meter foot cubic foot gram grams per second gallon gallons per minute grains per dry standard cubic foot (1 atmosphere, 68 "F) horsepower inches of mercury inches of water column liter liters per minute pounds microgram cubic meter milligram milliliter Normal nanogram parts per billion parts per million parts per million on a dry volume basis pounds per hour pounds per square inch pounds per square inch gauge standard cubic feet per minute pitot velocity pressure weight percent lx LCPT Plan - Rev. 1 Decemb er 2,201 0 TOCDF LIST OF CHEMICAL SYMBOLS AND FORMULAS Agent GA AI Ag As B Ba Be Cd c1- Clz COz CO Cr Co Cu EDT HNO: Hg HCl HzOz Lewisite KMnO+ Mn NaOH HzSO+ Ni NO* Oz Pb PCBs PCDD PCDF Sb Se Sn TCDD TI V Zn Ethyl N,N-dimethyl phosphoroamidocyanidate aluminum silver arsenic boron barium beryllium cadmium chloride chlorine , carbon dioxide carbon monoxide chromium cobalt copper ethanedithiol nitric acid mercury hydrogen chloride hydrogen peroxide (2 - chlo ro vinyl) di chl o ro ars ine potas sium p ernan ganate manganese sodium hydroxide sulfuric acid nickel nitrogen oxides oxygen lead polychlorinated biphenyl s polychlorinated dib enzo-p -dioxin p o lychlorinated dib enzo furans antimony selenium tin tetrachlorodib enzo -p - di ox in thallium vanadium ZITLC LCPT Plan - Rev. I Decemb er 2,2010 TOCDF LIST OF'IDENTIX'ICATION 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-Pl-8410 Agent Atomizing Air Pressure 815-TIT-8571 Secondary Charrber Exhaust Gas Temperature, Hourly Rolling Average 829-FIT-8521 Secondary Chamber SDS Feed Rate, Hourly Rolling Average 822-Pl-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-FlT-8922 Scrubber Liquor Flow to Scrubber Tower #2,Hotrly 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 Average819-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 Average819-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 Average819-FI-8933 Carbon Injection Feed Weight, Hourly Rolling Average 819-PDI-8941 18942 Carbon Filter Differential Pressure, Hourly Rolling Average819-TI-8939 Carbon Filter Inlet Temperature, Hourly Rolling Average819-FI-8932 Exhaust Gas Flow Rate, Hourly Rolling Average 819-TIT-8932 Exhaust Gas Temperature @ annubar 819-PIT-8932 Exhaust Gas Pressure @ anrrubar 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 LCPT Plan - Rev. I Decemb er 2, 2010 x1TOCDF 1.0 INTRODUCTION The Tooele Chemical Agent Disposal Facility (TOCDF) is a hazardous 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 DCD facility closure necessitates the destruction of the final remains of the nerve Agent GA and 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 these destruction activities will be conducted in the DCD Area l0 in a newly-constructed facility. 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 315 (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 incineration facility. To fulfill the RCRA requirements, a trial burn will be conducted to demonstrate the newly-installed liquid incinerator (LIC) ability to effectively treat any hazardous waste such that human health and the environment are protected; a Comprehensive Performance Test (CPT) will fulfill the Title V andHazardous 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 finalizedrn 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 (LICI and LIC2), the Metal Parts Furnace (MPF), the Deactivation Furnace System (DFS), and the new Area 10 Liquid Incinerator (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 before processing Agent GA and Lewisite. The ATLIC Lewisite Comprehensive Performance Test (LCPT) will demonstrate the processing of increased concentrations of arsenic, ash, and mercury present in Lewisite. This plan also serves as the notification that TOCDF plans to conduct a CPT for Lewisite wastes treated in the ATLIC. The feed rates, exhaust gas flow rates, and combustion chamber temperatures demonstrated during the ATLIC Surrogate Trial Burn (STB) will be used to set limits and operating parameters to conduct the LCPT. The LCPT will establish new arsenic, ash, and mercury feed rates. LCPT PIan - Rev. I Decemb er 2, 2010 TOCDF 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 to that 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 because Lewisite TCs have a high amount of mercury and arsenic in the agents. Lewisite monitoring on the ATLIC and PAS will use MINICAMS@ and Depot Area Air Monitoring Systems (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-dimethylphosphoroamidocyanidate) and these TCs will be processed before the Lewisite processing begins. Ten TCs containing approximately 26,000lb of Lewisite [(2-chlorovinyl) dichloroarsine] currently being stored at the DCD will be drained and the Lewisite processed during the Lewisite Campaign. ln 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 10 TCs (known as "Transparency Tons") that were found to be empty with low concentrations of Volatile Organic Compounds (VOCs) in the headspace of the TCs. The Transparency Tons do not contain any appreciable materials, and the liquid levels were so low that samples could not be obtained. The Transparency Tons may have contained Lewisite at one time. This LCPT plan will describe how TOCDF will: o Demonstrate with the use of Lewisite that arsenic wastes can be destroyed in accordance with the MACT requirements outlined in 40 CFR 263.1219. 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) to demonstrate 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}0 to the TOCDF RCRA Permit (3), The LCPT 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 Lewisite in the ATLIC. Regulatory reference citations are given, as appropriate, throughout this LCPT plan. LCPT Plan - Rev. I December 2,2010 TOCDF 1.1 LEWISITE COMPREHENSIVE PERFORMANCE TEST PLAN ORGANIZATION This plan 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 LCPT. 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 LCPT. 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 summary of the Agent GA and Lewisite characteization data can be found in Supporting Information to the Permit Modification Attachment 3, and Attachment 4 contains the referenced drawings for the ATLIC. This introduction provides an overview of the plan, including: o Processdescriptions; o Waste feed descriptions; LCPT objectives; . LCPT approach; o LCPT sampling and analyses protocols; and . Expected final permit conditions resulting from the LCPT. 1.2 FACILITY INFORMATION The TOCDF is located in EPA Region 8. The TOCDF EPA Identification Number is UT5210090002, which is also the DSHW RCRA Permit number. The DCD Title V Operating Permit Number is 4500071001. The LCPT points of contact are: Thaddeus A. Ryba, Jr., TOCDF Site Project Manager 11620 Stark Road Stockton, UT 84071 (43s) 8 33-7 43e LCPT Plan - Rev. 1 December 2,2010 TOCDF Mr. Gary McCloskey, Vice President and TOCDF General Manager EG&G Defense Materials, Inc. 11600 Stark Road Stockton, UT 84071 (435) 882-s803 Mr. Larry Williams, LCPT Test Director EG&G Defense Materials, Inc. 11600 Stark Road Stockton, UT 84071 (43s) 882-s803 I.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. An overview of the facility is provided in the Supporting Information to the Permit Modification, Attachment 4, Facility Site Plan, Drawing TE-16-C-2. The Lewisite will be drained from TCs and pumped directly to the Lewisite Agent Holding Tank, LCS- TANK-S511. 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 demilitarrzation process begins with the transport of the TCs from their storage site at DCD Area 10 to the ATLIC for processing. The TCs are moved from Area 10 storage igloos and then placed in a glove box. The Lewisite drained from the TCs is pumped to ACS-TANK-S51 1. Any residual Lewisite in the TCs is removed or destroyed by the addition of two rinses with 3 molar (M) nitric acid and rotating the mixture for a minimum of 60 minutes with each rinse. The TC is then rinsed three times with water, and the final water rinse is sampled and analyzed for Lewisite. If the agent concentration is below the Waste Control Limit (WCL) of 200 parts per billion (ppb), the TC will be examined and sent to a Subtitle C Treatment Storage and Disposal Facility (TSDF). If the agent is above the WCL, then the TC is returned 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 demilitaization process, the facility generates spent decon, which is captured by the Spent Decontamination System (SDS) and stored in SDS-TANK-8523 until processed in the SCC. Each tank is sampled after it has been filled and analyzed for Lewisite and the Human Health Risk AssesSment (HHRA) metals. If the Lewisite concentration is less than 500 parts per LCPT Plan - Rev. 1 December 2,2010 TOCDF million (ppm), the spent decon is treated in the SCC. If the Lewisite concentration is less than the WCL, it may be shipped off-site to a Subtitle C TSDF. Acid gases and particulate matter (PM) generated during combustion are removed from the exhaust gases by the PAS. The scrubber liquor and venturi scrubber liquor remove the acid 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 to a Subtitle C TSDF. 1.3.2 Liquid Incinerator System The ATLIC 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 PCC is designed to treat the Lewisite, while the SCC is designed to process spent decon. The ATLIC will be controlled by the Facility Control System (FCS), which will be responsible to safely and efficiently monitoring and controlling the process systems, process support systems, and control systems that are located within the ATLIC. 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. The FCS system will consist of hardware, 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 is lined with SR-90 alumina brick. The PCC temperature is maintained by a 3-million-British-thermal-units/hour (Btu/hr) natural gas fired burner allowing maximum Lewisite feed rates of approximately 300 pounds per hour (lb/hr). A liquid waste nozzle is mounted next to the burner and angled towards the bumer such that material is fed through the waste nozzle mix with the hot burner gases. The PCC temperature is maintained at a setpoint of 2,500 oF for processing all wastes. The ATLIC will operate with a minimum of 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 associated with the ATLIC. The two 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 is lined with Ruby SR Brick and the temperature is maintained by a 1-million- 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. The nozzles are capable of flows up to 2 gpm. The nominal flow rate through the nozzles during normal operations will be 0.8 gpm. The SCC is maintained at a setpoint of approximately 1,800 oF for processing all wastes. LCPt Plan - Rev. 1 Decemb er 2, 2010 TOCDF 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, 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; then 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 start-up and at idle with no waste in the furnace. The PAS equipment consists of a quench tower, a series of packed bed scrubbers, a Brine chiller, a high-energy venturi scrubber with a manually-adjusted throat, a moisture separator, an electric gas reheater, a powdered activated carbon (PAC) injection system, a baghouse, a sulfur- impregnated carbon filter system, two ID fans in series, and an exhaust stack. A description of each piece of equipment and their function in the PAS can be found in Section 2.10. 1.4 WASTES TO BE TREATED The State of Utah has defined chemical agents as acutely hazardous and identified thern as P999 (i.e., chemical agent) wastes along with any agent contaminated items. 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, F02I,F022,F023,F026, orF027). The wastes to be treated for Lewisite operations are Lewisite agent, which is summarizedinTable 1-1, and spent decon. The ATLIC will destroy the Lewisite and spent decon through hightemperature incineration. Lewisite is manufactured by the catalyzed reaction of arsenic trichloride (AsCl3) with acetylene. Table 1-1 summarizes the compounds identified by analyses as part of a study conducted in2009 (6). The compounds present in the Lewisite TCs are consistent with munitions-grade Lewisite. The compounds identified were Lewisite compounds in the series of Ll [(2-chlorovinyl) dichloroarsinel, which averaged 76.9WtYo;L2fbis(2-chlorovinyl) chloroarsinel, which averaged 14.9 Wt%; and L3 ltrts(2-chlorovinyl) arsinel, which averaged 0.73 areapercent. The L1 and L2were analyzedby formation of a derivative with ethanethiol and then analysis using GC/FID and the concentrations estimated as the area percent. The non-derivatized samples were analyzed. by GC/lvIS where the L3 and arsenic trichloride were estimated from the area percent of the chromatogram. In addition to the Lewisite compounds, the starting material, arsenic trichloride, was identified and the concentration estimated at 1.3 areapercent. These four compounds represented 93.8 percent of the Lewisite agent. LCPT Plan - Rev. 1 Decemb er 2,2010 TOCDF o TABLT, 1.1. LEWISITE CHARACTERIZATION SUMMARY GAL Data Sum 2009.x1s Lewisite Summary" (2) LCPT Plan - Rev I Decemb er 2.2010 Lewisite will be fed to the ATLIC during the shakedown period and the LCPT, and the details for the Lewisite are discussed in Sections 5.1.1 and 5.3. The arsenic in the Lewisite accounts for 32Wt% of the feed. This high feed rate of arsenic will establish the maximum arsenic feed rate during the LCPT. The Destruction and Removal Efficiency (DRE) established by the ATLIC STB is the only demonstration of the ATLIC DRE necessary to meet the requirements of the regulations. The established chlorobenzene DRE will allow the ATLIC to process Agent GA and Lewisite wastes 6ased on the EPA guidance that ranks chemicals by their thermal stability (5). Since the ATLIC STB demonstrated a DRE for chlorobenzene (which is a Class 1 compound), any Class 1 compound or lower cari be safely processed by the incinerator. Table 1-1 shows the composition of the Lewisite in the TCs. This table shows that the demonstration of DRE by the chlorobenzene in the STB was a conservative demonstration for the actual compounds treated by the normal operations of the ATLIC. Spgnt decon will be composed of a combination of TC rinse water, sodium hydroxide used to decontaminate equipment, and surfactants used to decontaminate personnel. It will be treated in the SCC and will vary in concentration, but will always contain less than 0.5 % organic compound. Spent decon will have a Lewisite concentration that is less than 500 ppm before it can be treated in the SCC. The spent decon used in the LCPT will be actual spent decon collected in SDS-TANK -8523. 1.5 LEWISITE COMPREHENSIVE PERFORMANCE TEST OBJECTIVE The objective of the LCPT is to demonstrate that the increase in arsenic, ash, and mercury feed rates does not have an adverse affect on the ATLIC compliance status because the PAS controls these emissions within the regulatory limits. This objective is supported by demonstrating: o Control of carbon monoxide (CO) emissions to < 100 parts per million dry volume (ppmdv), corrected to 7 o/o oxygen (@7 % O2), on an Hourly Rolling Average (HRA) basis; o That PM emissions are < 0.0016 grains/dry standard cubic foot (gridscf) @7 % 02 (MACT limit); o That the combined halogen emissions [hydrogen chloride (HCl) and chlorine (Cl2) gas] are < 2l ppm (MACT) expressed as HCI equivalents, dry basis @ 7 % C'2. o That the polychlorinated dibenzo-p-dioxin (PCDD) and polychlorinated dibenzofuran (PCDF) emissions are < 0.20 nanograms/dscm (ngidscm) 2,3,7,8-Tetrachlorodibenzo-p- dioxin (TCDD) Toxic Equivalent Concentration (TEQ) @7 % Oz. LCPT Plan - Rev. I Decemb er 2,201 0 TOCDF o That the mercury emissions are < 8.1 pgldscm @7 % 02 (MACT limit). o That the semi-volatile metals emissions (lead and cadmium) are < l0 pgldscm @7 % 02 (MACT limit). o That the low-volatility metals emissions (arsenic, beryllium, and chomium) are < 23 pgldscm @7 % 02 (MACT limit). o The emission rate of nitrogen oxides (NO.). 1.6 LEWISITE COMPREHENSIVE PERFORMANCE TEST APPROACH The LCPT will take the universal approach outlined in the EPA Guidance (5). The universal approach establishes one set of permit conditions or limits applicable to all feed materials. This approach will treat Lewisite agent and spent decon in the ATLIC while confining incinerator operation to a well-defined set of operating limits or an operating envelope. It is anticipated that Lewisite and spent decon will be processed simultaneously during Lewisite treatment. Maximum waste feed rates for each stream will be demonstrated 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 combustion chamber temperature, exhaust gas flow rates, and waste feed rates). The ATLIC is operated as a steady-state incinerator. The LCPT will be conducted at one test condition within the envelope established by the ATLIC STB. The ATLIC temperatures will be maintained within the limits listed in Appendix D. The combustion airflows in the system vary over a small range, and system pressures are maintained negative relative to the ATLIC furnace rooms. The arsenic concentration in Table 1-1 will set the metals feed rate for Lewisite processing. Operation of the PAS follows the furnace; hence, fluctuations in the PAS parameters will be limited. Scrubber liquor pH is controlled at a pH > 7 to remove the acid gases from the exhaust gases, and scrubber liquor flows are controlled to maintain PAS component liquid levels and temperatures. I.7 LCPT SAMPLING AND ANALYTICAL PROTOCOLS Detailed discussions of the sampling and analysis procedures are provided in the QAPP (Appendix A). The structure of the LCPT is based on the previously stated objective in Section 1.5. The exhaust gas sampling and analytical methods to be used to quantify specific LCPT parameters are taken from SW-846 (1),40 CFR 60, Appendix A(2), and TOCDF Procedures. These methods are as described below: LCPT Plan - Rev. 1 Decemb er 2,2010 TOCDF o A 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. o EPA Methods I and2 (2) will determine traverse sampling locations and flow rates. o EPA Method 3 (2) will determine the exhaust gas molecular weight using an Orsat supplied by the sampling subcontractor. o Each isokinetic sampling train will determine the moisture content of the exhaust gas. o EPA Method 5126 (2)will determine the PM emissions and halogen (HCl and Clz ) emissions. . EPA Method 29 (2) will determine the metals emissions. . SW-846, Method 0023A (1), will determine PCDD/PCDF emissions. 1.8 FINAL PERMIT LIMITS New permit operating conditions will not be set as a result of the LCPT, with the exception of the feed rates of arsenic, ash, and mercury. The permit operating conditions for the ATLIC STB are summarizedin Appendix D. The OPLs are established on the basis of regulatory guidance in 40 CFR 63-1209, 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. LCPT Plan - Rev. 1 Deoemb er 2,2010O rocDF 10 2.0 DETAILED ENGINEERING DESCRIPTION OF THE ATLIC This plan discusses the requirements of 40 CFR 63.1206(b)(5)(B) to conduct a trial bum, and this section discusses the current engineering configuration of the ATLIC as required by 40 CFR 270.62(b)(2)(ii). The operating parameters to be included in the final permits will be established by the ATLIC STB and LCPT. Engineering changes that might be encountered during shakedown would necessitate revisions to this LCPT 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 Supplemental Information to the Permit Modification, Attachment 4. DrawingsEG-22-F-8201, Sheet 1, and EG-22-F-8202, Sheet 1, 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 agent 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 will have a diameter of 3.5 ft. It will be comprised of refractory that is 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-bumer assembly and waste feed injection nozzle will be mounted to the chamber end plate. Combustion air will be introduced to the burner 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 bumer will be used to ensure a stable flame pattern within the PCC and to control chamber temperature, which is maintained between 2,500 oF and 2,850 oF. Natural gas will be fed to the PCC burner at rates between 49 and 150lb/hr (see the MEB 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 Control (PLC) for temperature control. The natural gas supplied to the primary chamber bumer assembly will be modulated to maintain the primary chamber exit gas temperature at the setpoint. LCPT Plan - Rev. 1 Decemb er 2,201 0 11TOCDF Lewisite agent will be supplied to the PCC by an agent feed system consisting of a waste feed injection nozzle. Agent will be dispersed into the burner flame through the air-atomizing feed nozzle. 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 fumace 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 1.85 seconds (see calculations in Appendix C) and a combined residence time for the PCC and SCC of 4.73 seconds. The increased residence time supplied by the SCC is necessary to safely ensure the organic compounds in the Lewisite are destroyed in the PCC and SCC. 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 fumace 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 is a horizontal, refractory- lined steel cylinder that is 12 ftin length and has a diameter of approximately 4 ft. The refractory will be the same as that used in the TOCDF LICs and proven effective; 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 gases to the SCC. The ends of the chamber will be flanged and sealed with flat steel plates that can be removed for refractory repair. A single burner assembly and two liquid injection nozzles will be mounted to the SCC inlet 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 pattem within the SCC and to control chamber temperature. Natural gas will be fed to the SCC bumer at rates between 16 and 50 lb/hr (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 oF and2,200 "F. Either spent decon, generated from facility maintenance activities and the rinsing and decontamination of TCs, or process water is introduced through two liquid atomizing nozzles [with nominal flow rates LCPT Plan - Rev. 1 Decemb er 2,2010 TOCDF t2 during normal operations of 0.8 gallons per minute (gpm)] to lower temperature of the gas as it enters the SCC. The spent decon or water evaporates and destroys any organic compounds contained in them. 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 2l5lbitr for cooling of the liquid injection nozzles. Plant air is used to atomize the SDS 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 2.88 seconds (see calculations in Appendix C) and a combined residence time for the PCC and SCC of 4.73 seconds. The ATLIC SCC exhausts through a refractory-lined duct to the PAS. The exhaust duct is not included in the residence time calculation. 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 fumace 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 bumer 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/hr natural gas fired burner. An air-atomizing waste feednozzle is mounted next to the burner and angled towards the burner 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 bumer maintains the desired flow to the burners. The combustion air flow will be set proportional to the fuel flow during furnace 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. The SCC temperature is maintained by a 1-million-Btu/hr natural gas fired burner at a se@oint of approximately 1,800 oF. Exhaust gases from the PCC enter directly into the SCC. Spent decon or water is introduced into the SCC through air-atomized nozzles located next to the bumer to lower the temperature of the gas as it enters the secondary chamber. Thenozzles are capable of flows up to 2 gpm. The nominal flow rate through the nozzles during normal operations will be 0.8 gpm. The spent decon/water evaporates, providing cooling, and any organic residue burns. A natural gas fueled burner is used to ensure a stable temperature within the secondary chamber. LCPT Plan - Rev. I Decemb er 2, 2010 TOCDF 13 o 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 Lewisite agent 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 bumers. The FSSS is located in the burner management system (BMS) panel and connects to the furnace controls through a PLC. The BMS controls all furnace burner operations through its connections to the PLC. 2.5 TON CONTAINER 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-83 I I 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 LCPT Plan - Rev. 1 Decemb er 2, 2010 TOCDF t4 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 frll 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 filIvalves. 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 fill, the Agent GA TC is filled with an 18 oh NaOH solution. Approximately 110 gallons of 18 o/o NaOH will be added to fill the TC more than half way. The TC is then rotated for amininium 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 1 10 gallons of water added to fill 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 a total 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 analyz.ed for Agent GA and then handled as a hazardous waste and transferred to a Subtitle C TSDF. LCPT Plan - Rev. I Decemb er 2,2010 15TOCDF 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 [molar (M)] nitric acid solution. The Lewisite is drained from the TCs and transferred to the LCS-TANK-85l1, 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 filIthe 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-S516. 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 greater than 1,000 ppm, water rinse is less than the WCL. If the Lewisite concentration rs the TC will be rinsed with 3 M nitric acid and water until the water rinse Lewisite concentration rs less than 1,000 ppm. The water rinses are transferred to the SDS- 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. LCPT Plan - Rev. 1 Decemb er 2, 2010 TOCDF 16 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 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. In the case of the surrogate mixture and Agent GA, the pump will direct the material to the PCC, while the Lewisite will be sent to LCS-TANK- 8511. Lewisite will be pumped via the feed pump to the ATLIC agent feed nozzle. All waste feed pumps are located in the Toxic Area. Waste feed from the pump 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 supply for purge of the waste feednozzle 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. LCPT Plan - Rev. I Decemb er 2,201 0 TOCDF t7 Duplex basket strainers will be provided at the inlet of each 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 ponhol room will indicate plugging of the strainers. The duplex design of the strainers allows online switching from one basket to another, making the offline basket available for cleaning or change-out without intemrpting processing. A control valve and instrumentation skid will be supplied for fi'eld 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 and water to be used for purging 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 pump to the two SCC spent decon/water supply nozzles. The SDS feed pump is positive displacement rotary gear pump mounted to a single skid and sized to supply the required flow of spent decon to the spent decon/water supply nozzles. The SDS feed pump is located in the Toxic Area. A control valve in the discharge line of the pump 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 room will indicate plugging of the strainers. The duplex design of the strainers allows online switching from one basket to another, making the offline basket available for cleaning or change-out without interrupting processing. The 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 IJELTING, 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 area. The second stream provides conditioned air to the ATLIC room. The HVAC system is configured in a cascading fashion so that any LCPT Plan - Rev. I Decemb er 2,2010 TOCDF 18 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 to the glove box area. The AHUs are both natural gas fired, and both of them are 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]. Air from the glove boxes and the ATLIC room will be routed from a common discharge duct to the HVAC filter system. The filter system consists of three filter units with a combined rating of about 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 until will be started automatically, opening the inlet and discharge dampers simultaneously at 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 Lewisite agent 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 LCPT Plan - Rev. I Decemb er 2, 2010 TOCDF t9 decon feed to proeess 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 PCC 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 Lewisite agent 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. Lewisite 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. Lewisite 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. Lewisite Feed Rate - The Lewisite agent is pumped from LCS-TANK-S511 to the PCC. The agent flow rate is continuously measured by a mass flow meter and flow indicating transmitters that are in series, 807-FIT-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 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 is required to ensure complete atomization of spent decon as it enters the SCC. This parameter is controlled LCPT Plan - Rev. I Decemb er 2, 2010 TOCDF 20 by use of pressure regulators and pressure switch 822-PSL-8511. 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 a HRA basis. Brine Flow Rate to the 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 an 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. LCPT Plan - Rev. I December 2,2010 2lTOCDF 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-8302N8. The CO AWFCO will stop waste feeds to the ATLIC if the HRA CO concentration exceeds the permitted value corrected to 7 Yo C,2, dry basis. The Oz correction factor will be calculated using the following equation: CO.: CO,,, x t4 (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. Ozn', Blower Exhaust Gas 02 Concentration - The Oz concentrations are monitored continuously at the ID fan discharge by the Oz CEMS recorded by the FCS as 819-AIT- 8301A/B. If 02 concentrations fall below the minimum setpoint or rise above the maximum, waste feeds to the ATLIC are stopped. ATLIC Stack Exhaust Gas Agent Concentration - Lewisite will be monitored during the LCPT, and these AWFCOs will be activated for the Lewisite shakedown and LCPT. The agent concentrations in the exhaust gases at the stack are continuously monitored. The operation of the MINICAMS@ in use during the LCPT will be controlled according to Attachment22A of the TOCDF RCRA Permit (7). The agent monitoring requires three MINICAMS@ monitors for Lewisite (TEN 709 series). Two MINICAMS@ that are monitoring the exhaust gas will be sequenced so one is sampling while the other is in the desorb and analysis mode. The third MINICAMS will be in standby to be used if one of the other MINICAMS experiences a system failure. Waste feed to the ATLIC is stopped if any of the online MINICAMS@ measures a concentration of Lewisite in the exhaust gas that equals or exceeds 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 warnings give operators time to take corrective actions before operations necessitate an AWFCO. LCPT Plan - Rev. 1 Decemb er 2,201 0 TOCDF 22 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 MONTTORTNG 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 duct monitor for Lewisite from the time Lewisite is introduced into the system. For these parameters, an AWFCO will be activated when the instruments detect conditions beyond the setpoints. Ou@uts 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. The CEMS are used to monitor the exhaust gas concentrations of CO, 02, 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 aralyzers 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/B. They will be non-dispersive infrared (NDIR) analyzer as described in 40 CFR 60, Appendix A, Method l0 (2). The arralyzers are drift checked 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 azerc gas and a span calibration gas. The LCPT Plan - Rev, I Decemb er 2, 2010 TOCDF 23 CO monitor sends a reading to a PLC every 15 seconds. The readings are averaged over one minute by the PLC, which then calculates an HRA from the one-minute averages. The averages are sent to the FCS. The 40 CFR 60, Appendix B, Perfonnance 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 concenhations higher than the setpoint. If the CO monitor fails, an AWFCO will be initiated. The NDIR analyzers' specifi cations are: Range: 0-200, 0-5,000 ppm; Accuracy: + I o/o of full scale; Drift: ( 1 o/o of full scale per week; Reproducibility: 0.5 oh of reading; and Response time: ( 60 seconds. The CO CEMS are drift checked daily. Gases of 0 to 2 Yo and 60 to 90 o/o 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 Oz analyzers will be used on the ATLIC and they are identified as 819-AIT-8301A/8. They will be a paramagnetic 02 analyzers. The analyzers are 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: Range: 0-25 Volvme o ; LCPT Plan - Rev. 1 Decemb er 2, 2010 TOCDF 24 Drift: Less than 0.5 o/o of span; Reproducibility: * 0.2 o/o of measured value; and Response time: ( 2 mtnutes. The Oz CEMS are drift checked daily using a two-point method. Gases of 0 to 2Yo and 60 to 90 % of instrument span are used to drift check the Oz analyzers. Calibration gases are injected into the sampling system at the duct. 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 exhaust gas concentrations. The span gas calibrations are considered a verification of the quality of the CEMS data. 2.9.3 NO* Monitors Two NO* analyzers will 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 analyzers are calibrated according to the CEMS Monitoring Plan, Attachment 20 to the TOCDF RCRA Permit (3), using a zero gas and span calibration gases. The 40 CFR 60, Appendix B, Performance Specification 2 (8) is used to evaluate the NO* CEMS. The NO* analyzers' specificatiohs are: Range: 0 to 1,000 ppmv; Accur acy: + 20 % 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 checked for drift 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 NO* analyzers. Calibration gisds are injected into the sampling syStem at the duct. 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 LCPT Plan - Rev. 1' December 2,2010 TOCDF 25 gases span the expected exhaust gas concentrations. The span gas calibrations are considered a verification of the quality of the CEMS data. 2.9.4 Agent Monitoring Systems Operations of the agent monitoring systems are discussed in Attachment 22Ato the TOCDF RCRA Permit (7) and in Appendix A. Lewisite concentrations in the plant and in the exhaust gas are monitored using MINICAMS@ and DAAMS. The MINICAMS@, aNear Real Time (NrRT) monitoring system, provide a continuous record of compliance in regards to the Lewisite emission standards. These systems have undergone extensive testing and evaluation under both simulated and actual field conditions. Testing and evaluation of the Lewisite monitoring systems will be provided to the DAQ and the DSHW prior to the shakedown period. Operations of the MINICAMS@ are controlled by LOPs. The Lewisite monitoring methods utilize a derivatization 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 a derivative compound where the two sulfur atoms replace the chlorine atoms bonded to the arsenic, 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 concentration is confirmed with DAAMS tubes results. 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 exit; 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 ATLIC 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, amoisture separator, an electric gas reheater, a PAC injection system, a baghouse, a sulfur-impregnated carbon filter system, two ID fans operated in series, and an exhaust stack. A description of each piece of equipment and their function in the PAS follows. 2.10.1 Quench Tower The quench tower is a vertical, cylindrical vessel containing two water spray nozzles; it is also 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 LCPT Plan Rev. I Decemb er 2,201 0 TOCDF 26 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 "F. 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. The exhaust gas flows to the inlet of the packed bed scrubber. The quench tower has a second spray nozzle that 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 oF, 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 combustion exhaust gases exit the Quench Tower and enter the packed bed scrubber system. 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 any acid gases. The packed towers ltilize 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, and the scrubber liquor is pH 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'alarge surface area and are structured to provide good contact between the exhaust gas and scrubber liquor. Acid gases and other water-soluble compounds are removed by the scrubber liquor to form neutral salts. 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 exchanger coils using a set of electrically-driven fans. The chiller heat exchanger is a packaged unit that cools the liquid by circulating chilled liquid over heat exchanger coils. The coolers operate continuously during operation of the LIC PAS. The cooling of the scrubber liquor to the packed bed vessels allows for removal of heat transferred to the liquid by contact with the exhaust gas and allows for improved arsenic removal. LCPT Plan - Rev. 1 Decemb er 2, 2010 TOCDF 2l The scrubber liquor pH in the sump is continuously monitored by three pH monitors and maintained within normal operating values by addition of 18 o/o 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 clean liquor 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 sdlnp, 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 the blowdown. The blowdown will be taken off-site via tanker trucks. Flow meters, flow controllers, and control valves maintain the Brine 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 scrubber liquor 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. ZJO.q 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 de.w 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 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. LCPT Plan - Rev. I Decemb er 2, 2010 TOCDF 28 2.10.5 Powdered Activated Carbon Injection System The exhaust gas continues to flow downstream from 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 injectionnozzle 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 then exit 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 positioning empty containment bins beneath the baghouse discharge and removing filled containment bins. 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. LCPT PIan - Rev. 1 Decemb er 2,201 0 TOCDF 29 Each carbon filter bed consists of a pre-filter followed by a HEPA filter, an activated carbon bed, 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. Lewisite will be monitored using 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 90o from each other around the circumference of the horizontal duct leading to the exhaust stack for exhaust gas emission sampling and the CEMS equipment. The exhaust gas emissions will be continuously monitored in the stack using CEMS for the presence of CO, Oz, and NO*. 2.11 CONSTRUCTION MATERIALS The construction materials for the incinerator system components are listed in Table 2-1. LCPT Plan - Rev. 1 Decemb er 2, 2010 TOCDF 30 TABLE 2.I, ATLIC CONTRUCTION MATERIALS 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 0 o , amorphous silica up to 40 %) carbon steel Quench Tower Upper Section - AL6XN aluminum; Lower Section - Type 3 16 Stainless Steel Packed Bed Scrubber Tower Type 316 Stainless Steel Venturi Scrubber Type 3 16 Stainless Steel lnduced 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 Baghouse Crrb"" Ftl"r IJ* Discharge Stack Type 3 16 Stainless Steel Type 3 l6 Stainless Steel Type 3 16 Stainless Steel Fiberglass reinforced plastic 2.I2 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 LCPT report. A list of the alarm settings for key process monitoring equipment is found in Appendix D. 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 LCPT Plan - Rev. I Decemb er 2,201 0 31TOCDF located physically near the motor. Each hand station is connected to a motor controller that monitors motor curent, controls starting and stopping of the motor it is connected to, and relays all hand station activity and motor status (including qrotgr 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, equipment critical to compliance with permit operating conditions receives additional attention. Key issues associated with these instruments include: o Continuing and preventive maintenance; r Verification of instrument calibration; and o 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.t 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, logginB, 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 server for the FCS network in accordance with the specification(s) of the chosen equipment. LCPT Plan - Rev. I Decemb er 2,2010 TOCDF 32 TABLE 2-2. INSTRUME,NT CALIBRATION FREQUENCY : i: l:t ari::::::il:ii:r ::::if: 1il:i :::;,:;l:temi:i:,:,;:l : i: :: :. tit.i: : i::. i:.:i:i::l::, ..':Sl:Qf ,:,1::..,:r.i l::li :iit:i:i.: i::i:iiir: : ii.i:i:i.i:i oGf :::::r:::::i:i:rr.:::..':iil::::::.::::l:r::1...:::::::::,:i.i ".:::.::::::":,: $"S,i.D:a$e..i.D,gS-"c.[1ifi tiUnlt .i:i.iii:::iii: t:iiii:l: ii:i.:i; : tlal j:ir: ::': :::::!:il::i': a::;lllD[8tlt .ui;ii:.l,iii.ii.i:ii,iiii ii.riiil ie,qus,n! .i2 i: t'ji: i: i:::i:.::j:::Yl:: (.OI&:VS,),.., oun, i.vi'i t::,Utl::: ::.a:::l:::l:l :.::.::.:l:l:il :::::, i i::j lil:l ,,.:.i;:i1,11,if., : i:: :.: I iij: : : :.: :.: : i:.t :.i:r: :r::-t.:.: :. ..:::i::r::i. j:l: ar?..:r:.:...t.:..j iAEiiIIiUI I 815-FIT-8430 Agent Feed Rate 180 2 822-PSL-8410 Agent Atomizing Air Pressure 180 3 815-TIT-8 471 Primary Chamber Temperature 180 4 815-FIT-8 s2t Spent Decon Feed Rate r80 5 822-PSL-851 I Spent Decon Atomizing Air Pressure 180 6 815-TrT-8571 Secondary Chamber Temperature 180 7 819-FIT-8932 Exhaust Gas Flow Rate r80 7a 819-TIT-8932 Exhaust Gas Temperature @ anmtbar 180 7b 819-PIT-8932 Exhaust Gas Pressure @ annubar 180 8 819-PI-8982 Scrubber Delivery Pressure 180 9 8 19-Frr-892t Brine Flow to Scrubber Tower #1 180 10 819-Frr-8922 Brine Flow to Scrubber Tower #2 180 11 819-FrT-8923 Brine Flow to Scrubber Tower #3 180 t2 819-PDrT-891 I Scrubb er #1 Pressure Drop 360 13 8 l9-PDIT-8912 Scrubb er #2 Pressure Drop 360 t4 8 19-PDIT-8913 Scrubb er #3 Pressure Drop 360 15 819-Frr-8924 Brine to Venturi Scrubber Flow 180 16 819-PDrT-8915 Venfuri Exhaust Gas Pressure Drop 360 t7 819-AIT-8952A 819-ArT-89528 8 r 9-ArT-89s2C Scrubber Brine pH 7 18 8 19-AI-8983 Brine Specific Gravity 180 19 819-AIT-8917 A 8 19-AIT-89 t7B 8 19-ArT-89 t7 C Venturi Sump pH 7 20 819-ArT-8921 Venturi Sump Specific Gravity 360 2l 819-TrT-893 1 Baghouse Inlet Temperature 180 22 819-PDrr-8936 Baghouse Pressure Drop 360 23 819-Wr-8933 Carbon Iniection Feed Weight 90 24 8 19-FIT-8934 Carbon Injection Air Flow 180 25 8 19-PDIT-894U 8942 Carbon Filter Pressure Drop 360 26 8 19-TrT-8939 Carbon Filter Inlet Ternperature 180 27 819-AIT-83 02AlB Blower Exhaust CO Concentration Daily 28 8 r 9-AIT-8301A/B Blower Exhaust Gas 02 Low Daily 29a TEN 7O8AK Stack Exhaust Agent GA Every 4Ltr 29b TEN 7O8BK Stack Exhaust Agent GA Every 4 hr 29c TEN 7O8CK Stack Exhaust Agent GA Every 4 hr 30a TEN 7O9AL Stack Exhaust Lewisite Every 4I:r 30b TEN 7O9BL Stack Exhaust Lewisite Every 4 hr 30c TEN 7O9CL Stack Exhaust Lewisite Every 4 hr TOCDF LCPT Plan - Rev. 1 Decemb er 2,201 0 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 warnings 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 about 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 burner gas rate by modulating control valve 818-FY-8443 to maintain PCC exhaust gas temperature. The burner has a 10-to-1 turndown ratio. A low-low PCC exhaust gas temperature transmitter 815-TT-8471 actuates alarm 815-TALL-8471and an AWFCO if the PCC exhaust temperature falls below the low temperature setpoint. High temperature is sensed by 815-TT-847I, and will 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. LCPT Plan - Rev. 1 Decemb er 2,2010 TOCDF 34 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-8511 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 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 hightemperature exhaust gas from the primary chamber. When the SCC is processing spent decon, the burner 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 measured by means of magnetic flow meter 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 actuates 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, and 8952C. Indicating controller 819-AIC-8952 activates 819-HS-8907 to adjust the addition of caustic to O rocDF 35 LCPT Plan - Rev. I Decemb er 2, 2010 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 an HRA basis. 2,12.10 Ventu ri S crubb er 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 differenlial pressure falls below the setpoint on an HRA basis. 2.l2.ll Scrubber Tower Sump Level Control The Brine sump level is measured by level indicating transmitter 819-LIT-895 1. 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 a 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-895 1 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, the waste feed is stopped and the PCC and SCC burners will automatically shutdown. Additionally, if 819-LAHH-895 I is activated, all liquid inputs to the scrubber sump are isolated. 2.12.12 Baghouse Pressure Drop Prior to entering the baghouse the exhaust stream is injected with PAC 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 alarms when the pressure drop increases or decreases to unacceptable values. An AWFCO is initiated if the differential pressure falls below the setpoint on an 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 discharge to an enclosed containment bin. 2.12,13 Carbon Filter System Differential Pressure The differential pressure across the carbon filter will be 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 sepoint on a HRA basis. LCPT Plan - Rev. I Decemb er 2,201 0 TOCDF 36 2.12.14 ATLIC Exhaust Gas Oxygen Concentration The ATLIC exhaust gas 02 concentrations are measured continuously by 02 analyzers 819-AIT- 83014/8. 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 are 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 analyzerc 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 an HRA corrected to 7 Yo Oz dry volume, which is compared to the emission standard of 100 ppmdv. If the CO concentrations are above the limit, the alarms indicated by 819-AAH-8302A/B 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), 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 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 must be operational. The typical time required for startup from a cold system is about 36 hours. LCPT Plan - Rev. I Decemb er 2,2010 TOCDF E7 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 of 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 MINICAMS@ and DAAMS are on line. 4. Verify that the 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 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. Initiate a furnace 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 burner 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. All fuel-gas valve and running interlocks are verified. b. The primary and secondary bumer igniters are energized. c. The main gas control valves open. d. The igniters are tumed off 10 seconds after the main gas control valves open. 38 LCPT Plan - Rev. I Decemb er 2,201 0 TOCDF 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 oF. f. The operator verifies primary and secondary bumer light-off on the control screen from the BMS. 6. Water flow to the secondary chamber is initiated 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. 1. Verify that all waste feed permissives are met: a. Primary chamber temperature is between2,500 oF and 2,850'F. b. Secondary chamber temperature is between 1,800 oF and 2,200 "F.c. Toxic Area 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. There are no process alarms active. h. No stop feed conditions are active. 2. Insert a setpoint into the primary combustion air flow controller for processing Lewisite. Verify that the combustion air flow increase 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. Initiate 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. Verifying that all spent decon feed permissives are met: a. Secondary chamber temperature is between 1,800 "F and 2,200 "F. b. ATLIC PAS is normal. c. Open interlocks for SDS tank drain valve are satisfied. 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. LCPT Plan - Rev. I Decemb er 2, 2010 TOCDF 39 3. Enabling the DECON FEED mode. 4. Placing the DECON FEED mode to AUTO. 5. Verifying that the spent decon feed pump starts. 6. Verifying that the spent decon feed valve opens and the process water feed valve closes. l. Setting the spent decon flow rate setpoint. 2.1 4 EMERGENCY/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 E-stop shuts down the PCC and SCC bumers, 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 case 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 fumace. In case of a planned shutdown, a Dow anollair purge from the segment of the PCC waste feed piping and personnel in protective gear from exposure to waste piping. system will be used to clear all waste types waste feed nozzle. It is designed to protect feed materials when working on the feed 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. LCPT Plan - Rev. I Decemb er 2,2010 TOCDF 40 3.0 SAMPLING AND ANALYSIS PROCEDURES The sampling and analysis objectives for the LCPT are to demonstrate: That increased arsenic, ash, and mercury feed rates do not have an adverse affect on the ATLIC compliance status because the PAS controls these emissions within the regulatory limit. Control of CO emissions by maintaining the CO concentration at < 100 ppm, @7 o/o Oz, on a HRA basis. Control of PM emissions by showing that the concentration is < 0.0016 grldscf @7 % Oz (MACT limits). That the Lewisite emissions were not detected. That the exhaust gas metals emissions concentrations are in compliance with the MACT limits. That the PCDD/PCDF emissions are ( 0.20 ng 2,3,7,8-TCDD TEQ/dscm @ 7 o/o Oz. Control of NO* emissions on an HRA basis. That the halogen emissions (HCl and Clz) are < 21 ppmdv @1 o/o 02 expressed as HCI equivalents. 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 Appendix A, and reference to it will be made to prevent duplication of text. The PCDD and PCDF data are being collected to demonstrate compliance with the MACT limits. 3.1 SAMPLING LOCATIONS Samples collected for the LCPT will be divided into exhaust gas samples, process stream samples, and Lewisite agent 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*, Lewisite, metals emissions, PCDDs/PCDFs, PM, Cl2, and HCl. The exhaust gas sampling ports used for the sampling methods for the ATLIC are shown in Drawing EG-22-D- 8211 in Attachment 4 to the Permit Modification. LCPT Plan - Rev. I Decemb er 2,201 0 TOCDF TABLE 3.1. ATLIC EXHAUST GAS SAMPLING SUMMARY Method 1 Traverse Points Each Port Report Inflormation Method2 Exhaust Gas Velocity Isokinetic Trains Report Information Each Isokinetic Train Exhaust Gas Moisture Isokinetic Trains Report Information Method 0023A PCDDs and PCDFs Environmental Monitoring Ports in ATLIC Exhaust Stack Report Information Method 5126 PM, HCl, and Clz Environmental Monitoring Ports in ATLIC Exhaust Stack Report tnformation Metho d 29 HHRA Metals Environmental Monitoring Ports in ATLIC Exhaust Stack Report Information MNICAMS@ Lewisite ATLIC Exhaust Duct ACAMS Port AWFCOs & Report Information DAAMS Lewisite ATLIC Exhaust Duct DAAMS Port Report Information CEMS Oz, CO, NO*ATLIC Exhaust Duct CEMS Port AWFCOs & Report Information Method 3 Orsat analysis for exhaust gas molecular weight Environmental Monitoring Ports in ATLIC Exhaust Stack Report Information LCPT Plan - Rev. 1 December 2,2010 The other sampling locations are matrix specific. A grab sample of spent decon is taken from a valve on the SDS tank. The Brine samples will be taken via taps on the side of the PAS sump. The Lewisite agent feed will be sampled from a valve in the lines used to circulate agent to mix the contents of the tank. The baghouse residue will not be collected as a sample for this test, because the Lewisite analyses of the carbon residue has not been developed so the baghouse residue will be held in storage until a method can be developed to show there is no agent contamination. The baghouse residue will be analyzed for Lewisite before it is shipped to a Subtitle C TSDF. 3.2 SAMPLING METHODS The'scrubber liquor samples for each run will be collected during the final 60 minutes of the run. The spent decon samples will be collected before testing to allow the spent decon to be analyzed for Lewisite before being processed. The Lewisite agent samples will be collected in a separate entry into the Toxic Area before the test as a safety precaution. 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 International 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 to fill the sample bottles. Separate sub-sample bottles are used for each sample. The selected method ensures that the actual material collected is representative of the stream. - The agent tank will be filled with Lewisite before beginning a run. Circulation pumps allow the Lewisite agent to be removed from the tank and then returned to achieve a homogeneous mixture. The tank contents will be mixed for 30 minutes before beginning feed or collection of the feed sample. Mixing the contents of the tank before sampling makes it unnecessary to collect composite samples. Once the tank contents are mixed, the valve on the circulation line can be opened and a sample collected. The exhaust gas will be monitored as outlined in Table 3-1 using CEMS and selected EPA methods sampling trains. The ATLIC CEMS will collect data on the CO, Oz, and NO* exhaust gas concentrations. (The ATLIC CEMS are discussed in Section2.9.) The sampling subcontractor will determine the exhaust gas molecular weight by 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: LCPT Plan - Rev. I Decemb er 2, 2010 TOCDF 43 A comblnation of Method 5 and Method 26A(2), which will collect samples for PM, Cl2, and HCI emissions. Method 0023A (1), which will be used to collect samples for PCDDs/PCDFs. A Method 29 sampling train (2), which will collect samples for metals emissions. The ATLIC CEMS (3), which will sample for 02, CO, and NO*. The sampling subcontractor will determine the exhaust gas molecular weight by Method 3 using an Orsat (2). 3.3 ANALYSIS METHODS Summaries of these analysis methods are included in this section for completeness; detailed descriptions of the analysis methods are located in the QAPP (Appendix A, Section 9). Metals present in the Lewisite are analyzed by acid digesting the sample by Method TE-LOP- 584 and then analyzing the digested sample by Method TE-LOP-557. Appendix A lists the specific organic compounds target analytes and metals to be analyzed as well as the methods of analysis. The process stream samples will be analyzed by the following methods: Method 82608 (1), which will be used to analyze samples for VOCs. Method 8210C (1), which will be used to analyze samples for SVOCs. Method 8290 (1), which will be used to determine PCDD/PCDF concentrations. Methods 6020 and7470A (1), which will determine metals concentrations. Samples of the exhaust gas will be collected using three sampling trains and the TOCDF CEMS. The collected samples will be analyzed using the following methods: o TOCDF Method 5 (2), which will be used to analyze PM. Method 9057 (1), which will be used to measure halogen concentrations. Method 0023N8290 (1), to determine concentrations of PCDDs/PCDFs. Methods 6020 and 7470A(1), which will be used to anal,yzemetals emission samples. LCPT Plan - Rev. 1 Decemb er 2,2010 44 4.0 LEWISITE COMPREHENSIVE PERF'ORMANCE TEST SCHEDULE The LCPT is scheduled for the third quarter of 2011. The submittal of this plan will serve as the official60-day MACT notice required for CPT plans. The DAQ and DSHW will be notified at least 30 days in advance of the actual LCPT date. The LCPT will begin after TOCDF has: received approval of the LCPT Plan; successfully completed construction of the plant; successfully completed shakedown of the incinerator, and completed the ATLIC STB. The LCPT should span about 5 days: 1 day for setup, 3 days of testing, and 1 day for cleanup. However, the ATLIC must achieve steady-state conditions by 2:00 PM on any test day or the run will be cancelled for that day. The isokinetic sampling trains will sample for four hours. The isokinetic samples will be collected in four sampling ports and each train will sample for 60 minutes in each port. The LCPT 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 Lewisite at least 15 minutes before each sampling run to establish steady operation at process test conditions. This, combined with sample train port changes, will cause total test time each day to be about 6 hours. Assuming minimal intemrption of ATLIC operation during this test, the incinerator is expected to operate for 6 or more hours per day for 3 days. LCPT Plan - Rev. I Decemb er 2,2010 TOCDF 45 5.0 LEWISITE COMPREHENSIYE PERFORMANCE TEST PROTOCOLS The LCPT will consist of three replicate runs performed at one set of operating conditions. The Lewisite used for this test will not be spiked with metals because the arsenic and mercury in the Lewisite represents the maximum arsenic and mercury feed rates. The following subsections will discuss the waste to be bumed, 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 LCPT: Lewisite agent and spent decon. Table 5-1 summarizes the physical properties of Lewisite. 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, F021, F022,F023,F026, orF027). 5.1.1 Lewisite Agent Waste Feed The liquid waste stream fed to the PCC will be Lewisite agent drained from TCs. A representative sample of the Lewisite agent will be collected from each tank of Lewisite used in the LCPT. The samples will be analyzed for HHRA metals. The compounds present in the Lewisite TCs are consistent with munitions grade Lewisite (see Table 1-1). Table 1-1 summarizes the compounds identified and the majority of the compounds were Lewisite compounds in the series of Ll [(2-chlorovinyl) dichloroarsine], which averaged 76.9 Wt%;L2lbis(2-chlorovinyl) chloroarsinel, rvhich averaged 14.9 Wt%; and L3 ltrts(2- chlorovinyl) arsine], which averaged 0.73 Wt%. These three compounds represented 92.5 Wt% of the Lewisite agent with other impurities being inorganic arsenic compounds such as AsC13. 5.1.2 Spent Decontamination Solution Waste Feed Spent decon will be fed into the SCC during each run. The spent decon will be material from the rinsing of the TCs and other spent decon from decontamination activities in the facility. It is anticipated that the contents of SDS-TANK-8523 will be treated with NaOH to lower the Lewisite concentration to below 500 ppm before processing in the SCC. The estimated composition of the spent decon will be I to 2 Yo NaOH containing less than 0.5 % organic compounds and less'than 500 ppm Lewisite. Any organic compounds present will be mainly the oxidation products of Lewisite, and concentrations of organic compounds are anticipated to be less than 0.5 %. In the case where spent decon is not available for use, a solution of NaOH with a minimum concentration of I oh willbe used for spent decon. LCPT Plan - Rev. I Decemb er 2,201 0 TOCDF 46 TABLE 5-1. LEWISITE PROPERTIES Chemical Name (2 - chlorovinyl) di chl oro arsine Chemical Formula CzHzfusCl: Chemical Abstr act Service Identification cAS 54r-2s-3 Molecular Wei ght (glmole)207.32 Weight Percent Chlorlne 51 .3 Vapor Specific Gravity 7,L Liquid Density @20 "C (slcc)1.8793 Liquid Specific Gravity @20 oc 1 .891 Freezing Point ('F)-48to29 Boiling Point ("F)385 Flash Point ('F)None Vapor Pressure @ (mmHg) 25 OC 34.6 Viscosity @ 68 oF (centistokes)2.257 Color Colorless to Brownish Odor Like Geraniums. Very little odor when pure Solubility Readily soluble in common organic solvents, oils, and chemical warfare agents. Higher Heating Value (Btu/lb)5,000 Physical State Viscous Liquid LCPT Plan - Rev. I Decemb er 2,2010 5.2 DRE DISCUSSION The ATLIC STB demonstrated DREs for chlorob enzene,and since this test does not change any of the DRE OPLs from that test, there is no regulatory requirement to re-establish a DRE. Also the regulations in 40 CFR 63, Subpart EEE, specify that the DRE be established during the initial CPT; any further DRE demonstration is unnecessary under the MACT regulations. Furthermore, the chlorobenzene DREs will be > 99.9999 %, which show that the DRE goals for the system were met, so further measurement of DREs is not required by the HWC MACT regulations. The Lewisite emissions will be measured, but the Lewisite DRE will not be determined 5.3 TEST PROTOCOL AND OPERATING CONDITIONS The LCPT will be conducted to demonstrate that the increase in arsenic, ash, and mercury feed rates does not have an adverse affect on the ATLIC compliance status because the PAS controls these emissions within the regulatory limits. The LCPT will be conducted at one operating condition that will be within the operating limits established by the ATLIC STB. The arsenic and mercury concentrations in the Lewisite will produce a "worst case" for metals content to cover the highest anticipated metals concentrations in the Lewisite and spent decon. Table 1-1 summarizes the composition of the Lewisite agent. It is possible that the amount of spent decon needed for three successful runs will exceed the supply. If this is the case, a minimum I.0 % NaOH solution will be used for spent decon feed to the SCC. Tables in Appendix D show the target Group A operating parameters for the LCPT condition. Samples collected will support the data needs required for the RCRA Permit, the Title V Air Permit, and the HWC MACT emission limits. Values for these parameters were established by the ATLIC STB and will not be changed for the LCPT. The LCPT will be performed under the following operating conditions: o Maximum Lewisite feed rate to the PCC of 300 lbihr. Arsenic fed to the PCC at a maximum concentration of 33.5 Wtyo,which results in an arsenic feed rate of 100 lbilr. Maximum spent decon feed rate to the SCC of 450 lb/hr. PCC temperatures in the range of 2,500 oF to 2,850 oF. SCC temperatures in the range of 1,800 oF to 2,200 oF. The residence time through the PCC, SCC, and duct work to the quench tower > 2 sec as described in Sections 2.1 and,2.2. LCPT Plan - Rev. 1 Decemb er 2,201 0 TOCDF 48 The Oz concentration maintained above 3 %. The CO concentration below 100 ppm @7 % C,2. Pressure drop across the venturi > 30 inWC. Normal quench tower and venturi scrubber liquor flows, and minimum pH. Exhaust gas flow rate within the limits set by the ATLIC STB. 5.4 COMBUSTION TEMPERATURE RANGES The anticipated PCC temperatures for the LCPT will be between 2,500 oF and 2,850 oF as established by the ATLIC STB. 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 oF, which are the AWFCO limits from the tables located in Appendix D. Mini.mum temperature limits will be established by the ATLIC STB, and maximum temperatures are set by the manufacturer's Extreme Temperature Limit (ETL). 5.5 WASTE FEED RATES AND QUANTITIES OF WASTES TO BE BURNED The feed materials will be Lewisite agent and spent decon. The Lewisite feed rates for the LCPT will be up to 300 lb/hr, and the spent decon feed rates will be up to 450 lbftr. The LCPT will require the Lewisite and spent decon to be fed to the ATLIC for a minimum of 18 hours. The Lewisite quantity bumed during the LCPT will be approximately 5,925Ib based on a feed rate of 300 lb/hr. The quantity of spent decon processed during the LCPT will be about 8,886 lb based on a feed rate of 450 lb/hr. Allowing a 25 Yo safety factor, the consumption of test feed materials is expected to be about 7 ,400Ib of Lewisite agent and 1 1,000 lb of spent decon. The anticipated usage rates are summarized in Table 5-2. Metals feed rates will be determined by analyses of the Lewisite samples and the spent decon samples. The ATLIC will reach equilibrium at test conditions, with Lewisite and spent decon supplemented by natural gas, about 15 minutes before the start of each sampling run. A surplus of Lewisite and spent decon will be on hand in case operational problems require a longer testing period. After each performance run is completed, the feed materials remaining may be processed through the ATLIC. LCPT Plan - Rev. I Decemb er 2, 2010 TOCDF TABLE 5-2. WASTE FEED REQUIREMENTS 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 located 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 FCS 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 the natural gas from August 2OlO, showed that the Higher Heating Value averaged 1,047 Btulft3, and the methane concentration averaged94.1 %. LCPT Plan - Rev. I Decemb er 2,201 0 1 rl|.r:..!I Sil 11i|..,t1'iffi$fiffic.G.tt 'i|'i1111,i1l ;:iiiirii:ri:ii.iii.i.,ii.li.':.,iRGfi.iliifGUiii.ii::i:ii:ii,.iii.,.i;i.,i,,:,,i :riilrlill:ii:ii:i!i::I.:::i.......,-.:.::1..,,..............,. :, i:.:::: :i::I:l::::i::.::::i:::l::I : i: ir:: :i : :. r:i:ri:i::::'i.':::::ra'::ri::: i: l::::l:i: i.::::::ii: i1::: riJl:::::::::::::::,:::::::::.:!:::i_::::4.:::.* :.:.:,ir:irlri.:.iri:r::i. :::.::::.:i:::i::ri.::li.iii.:r: li:iiiii:li iiii.,;,i:i:;i;,::ii.:.i,iriii.i.i:ili:i,'i.t ,.1: : : :::::': : : :t:l: : : ::: : : : : : : :li-: : l:::i::j : l :t::t: Ramp-up, 20 min 100 150 Steady-State Operations, l5 min 75 tt2 Exhaust Gas Sampling, 6hr 1,900 2,700 Total per Performance Run 1,97 5 2,962 Total for Three Performance Runs 5,925 8,8 86 TOCDF 5.8 WASTE FEED ASH CONTENT Ash generated during the LCPT will potentially come from the arsenic in the Lewisite and the solids from the spent decon. Based on the arsenic concentrations from Table 1-1, the Lewisite will be the major contributor to the ash generated during Lewisite processing and was estimated at 150 lbftr. The spent decon ash feed rate was estimated at 5.3 lb/hr from the total suspended solids and total dissolved solids from the LIC HD ATB spent decon analyses. An estimated total ash feed rate of 155.3 lb/hr was calculated from the maximum values from the ash feed rate data. Ash particles exiting the SCC will be collected by the scrubber liquors, baghouse, carbon filter beds, or measured in the ATLIC stack. No spiking of the waste feeds will be done to generate ash or PM. 5.9 ORGANIC CHLORINE CONTENT OF THE WASTE FEED Lewisite contains organic chlorine and inorganic chlorine. The HCI and Clz emissions measured will be a product of both sources since the Lewisite will be oxidized to As2O3 and the inorganic chlorine will be converted to HCl. The chlorine feed rate for an average composition of the Lewisite is 153.9 lb/hr based on the feed rate cif Lewisite of 300 lb/hr and the percentage of chlorine from the compounds listed in Table 1-1. Concentrations of HCI and Clz in the ATLIC emissionswillbesampledusingMethod26(2)andanalyzedbyMethod905T (1). Detailsare given in the QAPP (Appendix A). 5.10 METALS FEED RATES The metals fed to the ATLIC will be dominated by the arsenic in the Lewisite. Table 5-3 shows the estimated metals feed rates and the estimated metals emission rates associated with the LCPT. The arsenic concentration is so high that it was considered in a two step process. The arsenic removal efficiency was measured during the LIC HD ATB at99.99989 %. This Metals Removal Efficiency (MRE) was applied to the arsenic emissions and then an additionalgg.0 o/o was applied for additional removal by the baghouse and the carbon filters, resulting in an arsenic concentration in the exhaust gas that is estimated to be below the MACT concentration limit of 23 pg/dscm. This concentration demonstrates a conservative estimate of the arsenic concentrations; this shows that the arsenic concentration will not be a threat to human health or the environment. Conducting the LCPT and processing Lewisite should not prove to be an environmental threat. Metals emissions will be sampled using Method 29 (2). Sampling and analysis details for metals emissions are given in the QAPP (Appendix A). LCPT Plan - Rev, I Decemb er 2,201 0 51TOCDF TABLE 5.3. LCPT ESTIMATED METALS FEED RATES AND EMISSION RATES Agent Feed Rate: 300 lb/hr I Exhaust Gas Flow Rate: 934 dscfm I Exhaust Gas 02 Conc.: 8.8 % | Total Metal MAXIMUM FEED CONCENTRATIONS I Feed Rate Arsenic Conc.: 320,000 ppm 96.00 lb/h Chromium Conc.: 1.6 ppm 0.00048 lb/hr Lead Conc.: 0.87 ppm 0.00026 lb/hr Mercury Conc.: 528 ppm 0.16 lb/hr Zinc Conc.: 72 ppm 0.022 lb/hr Arsenic + Wet Scrubber 99.99989 1.33E-05 34.633 Arsenic + Filters 1.338 -07 Chromium 99.9770 1.39E-08 0.0362 99.9960 1.328-09 2.00E-06Mercu 99.965 9.s38-07 Semi-Volatile Metals Low-Volatility Metals Notes: The MACT Lirnit for Semi-Volatile Metals is the sununation of Pb * Cd : The MACT Lirnit for Low Volatility Metals is the summation of As + Be + u The MREs were taken from the LIC HD ATB Data. o Th. MRE was estimated for the baghouse efficiency. l0 pg/dscm. Cr :23 pgldscm. LCPT Plan - Rev. I Decemb er 2,2010eJ,'i',iJ;,Y:$'# 11 [ ::' .',' 52 5.11 POLLUTION CONTROL EQUIPMENT OPERATIONS 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 for the PAS are the same as the operating conditions established by the ATLIC STB and are summarized in Appendix D. Fluctuations in PAS temperatures, flow rates, pressures, pH, and density will occur during this test. These normal variations will be reported in the final LCPT Report. Standard operating conditions for the pollution control equipment are described in Section2.l0. 5.12 SHUTDOWN PROCEDURES The shutdown procedures to be observed during the LCPT 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 monitored and interlocked, will be in operation during this test. In addition, the system's operation will be monitored closely by the system 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. Sampling will be stopped if an AWFCO is activated during the LCPT. Should the AWFCO condition persist for 2 hours, the run would 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 deviation 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 SOPs. Shutdown will be the reverse of the startup process and are discussed in Section 2.14. Subsystems will be shut down in the foilowing order: ATLIC PCC and SCC; PAS; and IJtilities. 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. LCPT Plan - Rev. I Decemb er 2,201 0 1. 2. 3. TOCDF 53 5.13 INCINERATOR PERFORMANCE lncinerator 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 test will be adequate to meet the performance standards of 40 CFF.264.343 while firing the Lewisite and spent decon because: . TOCDF experience with the ATLIC burning chlorobenzene and tetrachloroethene fulfilled the need for the demonstration of the DRE. TOCDF experience with the LICs buming mustard under similar operating conditions suggests that the HCI and PM emissions will be less than their performance standards. The operating conditions will be within the envelope established by the ATLIC STB. The ATLIC and PAS are tightly controlled by PLCs and AWFCO systems whenever hazardous waste is being fed to the ATLIC. The ATLIC PAS includes design features to provide additional insurance that the arsenic will be removed by the three packed bed scrubbers using chilled brine, the baghouse, and the HEPA filters of the carbon filter module. LCPT Plan - Rev. 1 December 2,2010 TOCDF 54 O 6.0 LEWISITE SHAKEDOWN PROCEDURES Once the approval of this 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 Lewisite. Shakedown testing will proceed in accordance with the LCPT 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, and over 13 years of experience processing Agents GB, VX, and mustard in the TOCDF LICs. Operating limits will comply with the requirements of 40 CFR 270.62(a)(l). 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, bumers, 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 furnace. 6.1 STARTUP PROCEDURES The startup periods for the ATLIC will heat the PCC and SCC with natural gas until operating conditions have been reached. Temperatures will be held at operating conditions for 48 hours to verify that all systems are operating correctly. During this 48-hour 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 seven days in advance. LCPT Plan - Rev. I Decemb er 2,2010 TOCDF 55 6.2 ATLIC SHAKEDOWN The objectives of the shakedown are to: o Demonstrate that the ATLIC can safely treat Lewisite at 300 lb/hr. o Familiarize the operators with the operation of the ATLIC when processing Lewisite. o Verify that all systems function properly. . Verify that the agent feed ramp-up rate is suitable for Lewisite. o Verify that the spent decon feed ramp-up rate is suitable for NaOH solutions. o Evaluate the ATLIC operating conditions when processing Lewisite. o Evaluate the impact on the SCC of simultaneously processing Lewisite and spent decon. The TOCDF will provide the DAQ and DSHW with notice before introducing Lewisite into the system. The Lewisite will be introduced into the ATLIC in accordance with 40 CFR 2643aa@)(1) to bring the unit to a point of operational readiness for the LCPT. This phase will take two to fqur weeks and consist of up to 144 hours of Lewisite processing or 7,500 lb of Lewisite or the volume of three TCs, whichever is less. If TOCDF determines that more time is necessary to ensure operational readiness before the test, an extension will be requested from 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 LCPT Plan based on data obtained during the shakedown period. If such changes are necessary, they will be coordinated with the DAQ and the DSHW. A Lewisite Mini-Bum will be conducted as part of the shakedown activities for the LCPT. The purpose of this mini-burn is to demonstrate the removal of arsenic and PM before reaching the final feed rate. The mini-bum will be conducted at a Lewisite feed rate of 150 lb/hr and a spent decon rate of 450 lblhr. The exhaust gas will be sampled for metal emissions and particulate matter. The results of the mini-burn will be submitted to the DSHW as supporting information for continuing operation of the ATLIC using Lewisite after completion of the LCPT. LCPT Plan - Rev. I Decemb er 2,201 0 TOCDF 56 6.3 POST-LCPT-BURN OPERATION The interim period between completion of the LCPT 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. Following completion of the ATLIC LCPT, Lewisite processing will continue after the data from the Lewisite Mini-Burn has been submitted to DSHW. The TOCDF expects the ATLIC to operate during this period within the operating envelope defined and demonstrated by the LCPT, with the exceptions of the waste feed rates. The Lewisite feed rate will be limited to the feed rate demonstrated in the Lewisite Mini-Burn, which is anticipated to be 50 % of the feed rate demonstrated during the LCPT. The spent decon feed will continue at a feed rate that corresponds to 50 o/o of the organic feed rate demonstrated during the STB, that would correspond to 2.25 lb/hr of total organic compounds. It is estimated that the remaining Lewisite would be processed at 150 lb/hr feed rate to the PCC and the spent decon would be processed at a total organic feed rate of 2.25lblhr. Limiting the ATLIC Lewisite waste feed to 150 lb/hr and the spent decon feed rate to 2.25 lblhr of total organic compounds following completion of the LCPT ensures compliance with the federal and state hazardous waste incinerator performance standards because the arsenic removal rate will be established by the Lewisite Mini-Bum data. The spent decon feed rate would be limited to 50 o/o of the total organic feed rate demonstrated by the STB and DRE data from the STB will establish that rate based on the chlorobenzene feed to the SCC in the STB for which exhaust gas sample results are available. The preliminary data from the STB will demonstrate a DRE of greater than 99.9999 oh for organic feed to the PCC and the SCC. Therefore, processing the remaining Lewisite at 50 %o of that rate will be protective of human health and the environment. The ATLIC inspection plan will be followed to look for fugitive emissions, leaks and associated equipment spills, and 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 remain unchanged from the methods specified in the RCRA and air permits. LCPT Plan - Rev. I Decemb er 2, 2010 TOCDF 57 6.4 INCINERATOR PERFORMANCE TOCDF believes that the conditions specified in Section 6.0 for the startup, shakedown, LCPT, and post-LCPT operation will be adequate to meet the performance standards of 40 CFR264.343 while processing Lewisite agent and spent decon because: TOCDF experience with the LICs burning mustard and spent decon under similar operating conditions suggests that the HCI and Clz emissions will be<2I ppm, and the PM emissions concentrations will be less than 0.0016 grldscf. These estimated emissions are within the performance standards. TOCDF experience with the LICs during incineration of Agents GB, VX, and mustard spiked with metals resulted in metals emissions that did not pose a threat to human health or the environment. The range of operating conditions planned for the shakedown and post-LCPT periods are within the design envelope of the ATLIC and PAS (refer to the Appendix C MEBs) as established by the ATLIC STB. 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-LCPT periods. In addition, meeting the performance standards of 40 CFR 264.343 and 63.1219 ensures protection of human health and the environment. LCPT Plan - Rev. 1 Decemb er 2,201 0 TOCDF 58 7.0 LEWISITE COMPREHENSIVE PERORMANCE TEST RESULTS The results of the LCPT will be submitted to DAQ and DSHIV in the report format used in prior ATB reports. The operating data will be summarized; the Lewisite emissions, PM emissions, and metals emissions will be reported; and the supporting laboratory data and data verification will be submitted. The TOCDF will submit the LCPT Report within 90 days after completion of the test. The report will be certified in accordance with the requirements of 40 CFR 270.62(b)(l-9). It should be noted that all data will be submitted for all analyses conducted, including the data from any failed runs. LCPT Plan - Rev. 1 December 2,2010 TOCDF s9 8.0 REFERENCES (1) Test Methodsfor Evaluating Solid Waste, PhysicaUChemical 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) Attachment20 to the TOCDF Permit, CEMS Monitoring Plan, EG&G Defense Materials, Inc., CDRL-06. (4) Hazardous llaste 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 Burn 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) Attachment22{to the TOCDF RCRA Permit, Agent Mortitoring Plan, EG&G Defense Materials, Inc., TOCDF CDRL 23. (8) Title 40, Code of Federal Regulations, Part'60, Appendix B, "Performance Specification." (9) "standard Practices for Sampling Water from Closed Conduits ,- ASTM D 3370-95a (Fte- approved 1999), ASTM International, West Conshohocken, Pennsylvania. LCPT Plan - Rev. I Decemb er 2,201 0 TOCDF 60 I15o r.Jo- X O TooF,LE CHEMICAL AGENT DISPOSAL FACILITY (TOCDF) LEWISITE COMPREHENSIVE PERFORMANCE TEST PLAN FOR THE ARE,A 10 LIQUID INCINE,RATORo APPENDIX A QUALITY ASSURANCE PROJECT PLAN APPENDIX A QUALITY ASSURANCE PROJECT PLAN TOOELE CHEMICAL AGENT DISPOSAL FACILITY Facility EPA ID Numberl:uT5210090002 Prepared for: Tooele Chemical Agent Disposal Facility 11600 Stark Road Tooele, AT 84074 Revision No.: I Date: December 2r 2010 TOCDF LCPT Plan Section No.: I .0 Revision No.: I Revision Date: December 2,2010 Page No.: I 1.0 TITLE PAGE 1.1 Project Title: LEWISITE COMPREHENSTVE PERFORMANCE TEST FOR THE AREA 10 LIQUID INCINERATOR QUALITY ASSURANCE PROJECT PLAN 1.2 Expected Trial Burn Dates: October 2011 1.3 Project Approvals: Thaddeus Ryba, CMA Project Manager Date Gary McCloskey, EG&G DMI General Manager Date Craig M. Young, Ph.D., EG&G DMI, Project Specialist Subcontractor Quality Assurance Director Date Date TOCDF LCPT Plan Section No.: 2.0 Revision No.: I Revision Date: December 2,2010 Page No.: I 2.0 TABLE OF CONTENTS 1.0 TrTLE PAGE ..........1-1 2.0 TABLE OF CONTENTS............ ...............2-1 LIST OF ACRONYMNS AND ABBREVIATIONS .,.,.,.,2-6 LIST OF UNITS AND MEASIIREMENTS ..,...,,.............2.8 3.0 PROJECT DESCRIPTION .....3-1 4.0 PROJECT ORGANIZATION........... ........4-l 4.2 CONTRACT ADMINISTRATIVE REPRESENTATIVE......... ...,.4-I 4.3 TOCDF LABORATORY MANAGER............... .......4-3 4.4 SUBCONTRACTORPROGRAMMANAGER. ,.,...,4-3 4.5 SAMPLING SUBCONTRACTORQUALTTYASSURANCE OFFICER ...........4-3 4.6 SAMPLTNG TEAM COORDINATOR.,........... .........4-4 4.7 SUBCONTRACTOR SAMPLING TEAM MEMBERS. ,.,.,.,...,.....4-4 4.8 SUBCONTRACT LABORATORIES............ ............4-5 s.0 QUALTTY ASSURANCE AND QUALITY CONTROL OBJECTIVES .....................5-1 5.1 EVALUATIONOFPRECISION .,........5-2 5.2 EVALUATIONOFACCURACY ......,..5-2 5.3 EVALUATION OF COMPLETENESS.............. .......5-3 5.4 DETECTIONAND REPORTINGLIMITS....... ........5-3 5.5 REPRESENTATIVENESS AND COMPARABILITY ..................5-4 6.0 SAMPLING AND MONITORING PROCEDURES ......... .........6-1 6.1 PRE-SAMPLINGACTIVITIES ...........6-I 6.1.1 Calibration of Process Monitoring Equipment....... ..............6-l 6.1.2 Sampling Equipment Calibration.. ................... 6-1 6.1.4 Sample Media Preparation ..........6-2 6.1.5 Addilional Pre-Sampling Activities ...................6-2 6.2 FIELD QUALTTYCONTROLACTTVTTTES. ...........6-3 TOCDF LCPT Plan Section No.: 2.0 Revision No.: I Revision Date: December 2,2010 Page No.: 2 TABLE OF CONTENTS (continued) 6.3 EXHAUSTGAS SAMPLING. ..,.,.,.,..,..6-4 6.3.1 Lewisite Monitoring Methods ............... ............6-5 6.3.2 Method I to Determine Duct Traverse Sampling Points ......6-7 6.3.3 Method 2 to Determine Exhaust Gas Yelocity and Volumetric Flow Rate... .................6-7 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 Methotl 0023Afor PCDDilPCDFs ...................6-9 6.3.7 Method 29 for Metals.................. ......................6-9 6.3.8 Continuous Emissions Monitoring .................6-10 6.4.1 Process Stream Sampling Locations......... ......6-12 6.4.2 Tap Sampling Method................. .................... 6-13 6.5 PROCESS MONITORING EQUIPMENT.................. ....................:.................6-13 6.6 POST-SAMPLINGACTIVITIES.... ...6-13 7.0 SAMPLE HANDLING, TRACEABILITY, AND HOLDING TIMES .......7-l 7.1 SAMPLEPRESERVATIONAND HOLDINGTIMES........... .......7-I 7.2.3 Chain-of-Custody Forms .............7-3 7.3 SAMPLE TRANSPORT TO THE LABORATORY............... ........7-4 8.0 SPECIFTC CALTBRATTON PROCEDURES AND FREQUENCY..............................8-1 8.1 PROCESS MONITORING EQUIPMENT CALIBRATION........... ....................8-l 8.2 EXHAUST GAS SAMPLTNG EQUrPMENT.................. ...............8-1 8.3 CALIBRATION OF CONTINUOUS EMISSION MONITORING SYSTEMS ....................,.. 8-2 9.0 ANALYTICAL OBJECTIVES AND PROCEDURES......... ......9-1 9.I ANALYSIS METHODS FORPROCESS STREAM SAMPLES ........................9-3 9.1.1 Lewisite Analysis Method........ .....9-3 9.1.3 Inorganic Analysis Methods ........9-3 9.1.4 Organic Compound Analysis Methods............... ...................9-4 9.2 ANALYSIS METHODS FOR LEWISITE AGENT SAMPLES .....9.7 9.3 ANALYSIS METHODS FOR EXHAUST GAS SAMPLES ................ ,............,.9-7 9,3.1 Analysis of Method 0023A Samplesfor PCDD{PCDFs ......9-7 9.3.2 Analysis of Metals Emisslozs.......... ..................9-9 9.3.3 Analysis of Halogen Emissions.... .....................9-9 9.3.4 Particulate Mutter Analysis.......... .................i... .....................9-9 TOCDF LCPT Plan Section No.: 2.0 Revision No.: I Revision Date: December 2,2010 Page No.: 3 TABLB OF CONTENTS (continued) 10.0 SPECIFIC LABORATORY QUALITY CONTROL CHECKS .............10-1 10.2 LABORATORY CONTROL SAMPLES... ............ IO-1 10.3 DUPLICATEANALYSES ............. ....................... l0-l IO.4 MATRIX SPIKE SAMPLES... .......... IO-2 10.5 SURRoGATESPIKES....... ..............10-2 10.6 ANALYTICAL INSTRUMENT CALIBRATIONS ............ .......10-2 11.0 DATA REPORTING, DATA REVIEW, AND DATA REDUCTION.......................11-1 11.1.1 Analytical Data Packages ........ 11-l 11.1.2 Analyticul Data Format......... ... 11-2 11.2.2 Identilication und Treatment of Outliers... ... 11-5 11.3.2 Laboratory Analyses Datu Reduction ........... 11-6 11.3.i Blank Corrected Data.................. .................. I l-6 1I.4 EXHAUST GAS SAMPLE TRAINS TOTAL CALCULATIONS ........... .......11.7 12.0 ROUTINE MAINTENANCE PROCEDURES AND SCHEDULES.........................12-1 13.0 ASSESSMENT PROCEDURES FOR ACCURACY, PRECISION, A}[D COMPLETENESS...................; ..... 13-1 14.0 AUDrT PROCEDURES, CORRECTIVE ACTION, AND QA REPORTrNG........ 14-1 14.I PERFORMANCEALIDITS ..............14-I 14.3 CORRECTIVEACTION............. .....14-2 15.0 REFERENCES. ...15.1 TOCDF LCPT Plan Section No.: 2.0 Revision No.: I Revision Date: December 2,2010 Page No.: 4 LIST OF ANNEXES AI\NEX A. QA/QC OBJECTIVES FOR ANALYTICAL METHODS ANNEX B. EXAMPLE DATA FORMS ANNEX C. RESUMES OF KEY INDIVIDUALS TOCDF LCPTPIan Section No.: 2.0 Revision No.: I Revision Date: December 2,2010 Page No.: 5 LIST OF TABLES A-6-1 EXHAUST GAS SAMPLING SUMMARY ...,.........6-5 A-6-2 PROCESS SAMPLES TO BE COLLECTED............ ,....,.........6-12 A-7.1 SAMPLE PRESERVATION AND HOLDING TIMES ............... ........,.......7-2 A-9-1 ANALYTICAL METHODS....... .............9-2 A-9-2 NUMBER OF SAMPLES ............ ...........9-2 A-9.3 TOTAL VOC TARGET ANALYTE LIST FOR PROCESS SAMPLES.......................9-5 4.9-4 TOTAL SVOC TARGET ANALYTE LIST FOR PROCESS SAMPLES ...9-6 A-9-5 PCDD/PCDF TARGET ANALYTE LIST ........ .......9-8 A-9-6 METHOD 29 TARGET ANALYTE LIST .............9-10 A-10-I CALIBRATION PROCEDURES FOR ANALYTICAL METHODS ...... 1O-3 LIST OF FIGURES A-4-1 ATLIC LCPT ORGANZATION CHART ....,.,.,......4-2 TOCDF LCPTPIan Section No.: 2.0 Revision No.: I Revision Date: Decembeii.:tr: LIST OF ACRONYMNS AND ABBREVIATIONS ACA Absolute Calibration Audit ASTM ASTM International ATB Agent Trial Burn ATLIC Area l0 Liquid Incinerator AWFCO Automatic Waste Feed Cutoff Brine Wet Scrubber Recirculation Brine CAL Chemical Assessment Laboratory CAR Contract Administrative Representative CC Correlation Coefficient CCV Continuing Calibration Verification CEMS Continuous Emission Monitoring System CFR Code of Federal Regulations CLP Contract Laboratory Program COC Chain-of-Custody CPT Comprehensive Performance Test CVAAS Cold Vapor Atomic Absorption Spectroscopy DAQ State of Utah, Department of Environmental Quality, Division of Air QualityDEQ State of Utah, Department of Environmental QualityDCD Deseret Chemical Depot DFS Deactivation Fumace System DI Deionized (as in deionized water) DQO Data Quality Objective DRE Destruction and Removal Efficiency DSHW State of Utah, Department of Environmental Quality, Division of Solid and Hazardous Waste EG&G EG&G Defense Materials, Inc. EPA U.S. Environmental Protection Agency FCS Facility Control System GC Gas Cromatograph GCA{S Gas Chromatograph/IVlass Spectrometer HHRA Human Health Risk Assessment HRGC/HRMS High Resolution Gas Chromatograph/I{igh Resolution Mass Spectrometer HWC Hazardous Waste Combustor IC Ion Chromatograph ICPA4S Inductively Coupled Plasma/Mass Spectrometer ICV Initial Calibration Verification LIC Liquid Incinerator LCPT LCS LOQ MACT MDL MPF MS MSD NIST NRT PCC PM POHC QA QAPP QC %R RATA RCRA TOCDF LCPTPIan Section No.: 2.0 Revision No.: I Revision Date: December 2,2010 Page No.: 7 LIST OF ACRONYMS AND ABBREVIATIONS (continued) Lewisite Comprehensive Perforrnance Test Laboratory Control S ample Limit of Quantitation Maximum Achievable Control Technology Method Detection Limit Metal Parts Furnace Matrix Spike Matrix Spike Duplicate National Institute for Standards and Technology Near Real Time Primary Combustion Chamber Particulate Matter Principal Organic Hazardous Constituent Quality Assurance Quality Assurance Project Plan Quality Control Percent Recovery Relative Accuracy Test Audit Resource Conservation and Recovery Act RPD Relative Percent Difference RRF Relative Response Factor RSD Relative Standard Deviation SCC Secondary Combustion Chamber SEL Source Emission Level SOP Standard Operating Procedure Spent decon Spent Decontamination Solution STB Surrogate Trial Bum STC Sampling Team Coordinator STEL Short Term Exposure Limit SVOC Semi-Volatile Organic Compounds SW-846 Test Methods for Evaluating Solid Waste, 3rd Edition including Update Itr, USEPA, SW-846, December 1996. TE-LOP Tooele Laboratory Operating Procedure TOCDF Tooele Chemical Agent Disposal Facility VOA Volatile Organic Analysis VOC Volatile Organic Compound XSD Halogen Specific Detector acfm amu cfm OC oF dscf dscfm dscm dsL ft ob g/sec gal gpm grldscf AH inHg inWC kg L L/min Irg 3m mg mglL mg/kg min mL mLlmin N ng ppb ppm ppmdv lb/hr psig AP wto Y. TOCDF LCPT Plan Section No.: 2.0 Revision No.: I Revision Date: December 2,2010 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 oF) average pressure differential across orifice meter inches of mercury inches of water column kilogram liter liters per minute 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 TOCDF LCPTPIan Section No.: 2.0 Revision No.: 1 Revision Date: December 2,2010 Page No.: 9 LIST OF CHEMICAL SYMBOLS AND FORMULAS Agent GA Ethyl N,N-dimethyl phosphoroamidocyanidate Al aluminum Ag silver As ilsenic B boron Ba barium Be beryllium Cd cadmium Clz chlorine COz carbon dioxide CO carbon monoxide Co cobalt Cr chromium Cu copper DFTPP decafluorotriphenylphosphine EDT ethanedithiol HNO3 nitric acid Hg mercury HCI hydrogen chloride HzOz hydrogen peroxide KMnOa potassium permanganate Mn manganese NaOH sodium hydroxide Na2S2O3 sodium thiosulfate H2SOa sulfuric acid Ni nickel NO* nitrogen oxides 02 oxygen Pb lead PCDD polychlorinated dibenzo-p-dioxin PCDF polychlorinated dibenzofuran Sb antimony Se selenium Sn tin TCDD tetrachlorodibenzo-p-dioxin Tl thallium V vanadium Zn zinc TOCDF LCPT Plan Section No.: 3.0 Revision No.: I Revision Date: December 2,2010 Page No.: I 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, for the destruction of 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. The closing of the DCD necessitates the destruction of Agent GA and the blister agent Lewisite to complete the destruction of chemical agents in storage. Destruction of these additional chemical agents has been contracted to EG&G Defense Materials, Inc. (EG&G), to 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 Incinerator (ATLIC), the fifth incinerator system that TOCDF operates to dispose of the chemical agents stored at DCD. The TOCDF incinerator systems include two Liquid Incinerators (LICI andLIC2), the Metal Parts Furnace (MPF), and the Deactivation Furnace System (DFS). The systems are designed to meet the Hazardous 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 Burns (ATBs) and Comprehensieve Performance Tests (CPT) 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 will describe how TOCDF intends to use Lewisite agent to demonstrate incineration of high concentrations of arsenic in a Lewisite Comprehensive Performance Test (LCPT) in the ATLIC. This plan also serves as the notification that TOCDF plans to conduct the LCPT. The feed rates, flows and temperatures demonstrated during the LCPT will be within the envelope established by the ATLIC Surrogate Trial Burn (STB) conducted prior to Lewisite processing. This Quality Assurance Project Plan (QAPP) describes the sampling and analyical activities that will be performed by the sampling subcontractor and laboratory during the LCPT. The QAPP was developed using methods from SW-846 (1) and guidance from EPA Region6 (2). TOCDF LCPT Plan 'fillliJi; '? Revision Date:,TTJ;iu?.r, ! EG&G is responsible for operating TOCDF and conducting testing. EG&G is the principal data user and decision-maker for the LCPT, but will subcontract the sampling and analyses portions of this LCPT. This subcontracted support will include gas sampling, transportation of samples to the laboratory, sample analyses, Quality Assurance/ Quality Control (QA/QC) associated with these tasks, and reporting of the results. 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 monitoring 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 substances during the LCPT: Lewisite Oxygen (O2), carbon monoxide (CO), nitrogen oxides (NO.) and carbon dioxide (COz); Particulate matter (PM); . Hydrogen chloride (HCl), and chlorine (Clz) also referred to as the halogens; Metals; and Polychlorinated dibenzo-p-dioxins and polychlorinated dibenzofurans (PCDDs/PCDFs). A percent Destruction and Removal Efficiency (% DRE) will not be demonstrated because the ATLIC STB demonstrated a DRE for a Class 1 compound which fulfills the requirement. The exhaust gas will be analyzed for the elements used in the Human Health Risk Assessment (HHRA): aluminum (Al), antimony (Sb), arsenic (As), barium (Ba), beryllium (Be), boron (B), cadmium (Cd), chromium (Cr), cobalt (Co), copper (Cu), lead (Pb), manganese (Mn), mercury (Hg), nickel (Ni), selenium (Se), silver (Ag), thallium (Tl), tin (Sn), vanadium (V), and zinc (Zn). Samples of the Lewisite agent feed will be analyzed for HHRA metals. Samples of the scrubber liquor, venfuri scrubber liquor, process water, and spent decontamination solution (spent decon) will be analyzed for Volatile Organic Compounds (VOCs), Semi-Volatile Organic Compounds (SVOCs), PCDDs/PCDFs, and HHRA metals. Scheduling for the project is found in the LCPT 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 in this QAPP. 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 LCPT Plan Section No.: 4.0 Revision D",., S"'.""1;;L)l;r t I Page No.: I 4.0 PROJECT ORGANIZATION The LCPT orgarrization is summarizedinFigure A-4-1. This organizationhas four groups that work together for the successful completion of the LCPT. One group is the EG&G organization, the second is the Battelle Chemical Assessment Laboratory (CAL), the third is the sampling subcontractor, and the fourth is the laboratory subcontractor. 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 Test Director has the overall responsibility for this LCPT, and as such, is the point of contact between EG&G Operations and the LCPT organization. The EG&G Contract Administrative Representative (CAR) will interface with the subcontractor organizations. Annex C contains copies of the resumes of the key individuals involved in the LCPT. If any subcontractors for the LCPT 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 LCPT. The Test Director coordinates the activities of EG&G, monitoring personnel, CAL personnel, and the sampling subcontractor. [n addition, the Test Director will coordinate the information to be provided in the final LCPT Report. The duties of the Test Director include: o Ensuring that the feed is prepared for the LCPT. o Establishing the system operating parameters as described in the LCPT plan. o Determining when Operations is ready to begin the performance run. o Notitnng the sampling subcontractor to begin sampling. o 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 they perform as directed by the QAPP and their contract. EG&G Test Director TOCDF QC Inspectors FIGURE A-4-I. ATLIC LCPT ORGANTZATION CHART TOCDF ATLIC LCPT Plan Section No.: 4.0 Revision No.: 1 Revision Date: December 2,2010 Page : 2 -tlltttl! Administrative Line Communication Line TOCDF Laboratory Manager ACAMS/DAAMS Sampling Team DAAMS Analysis Operators CAL Analyses Team Sampling Subcontractor Manager Subcontractor Program ManagerSubcontractor Laboratories Sampling Team Coordinator Data Analysis & Report Coordinator Sampling Trai Operators Document Preparation Recovery Technicians Subcontractor QA Officer ATLIC STB Project ORGN.xls TOCDF LCPT Plan Section No.: 4.0 Revision No.: I Revision Date: Decemb er 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 monitoring agent emission using the MINICAMS@ for automated Near Real Time ArRT) agent monitoring, the Depot Area Air Monitoring System (DAAMS) Sampling Team, and the Continuous Emission Monitoring System (CEMS) monitoring for CO, 02, and NO*. The CAL has the responsibility for the agent screening analyses, Lewisite agent 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 agent related 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: . 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 QA/QC 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 LCPT. o Assisting in the development of the data evaluation report for the LCPT. TOCDF LCPT Plan 'i:'iffI"i", o ? Revision Date: Decembei?.r rl o Enforcing the protocols of the QAPP. o Observing all on-site activities to ensure that the QAPP is followed. o 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 sampling data, emission calculations, and results reporting. . Delivering samples to the laboratory. . Overseeing the required sampling. . Directly supervising 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 testing equipment, QA/QC, and record keeping for the assigned train. The team leader reports any inegularities to the STC, an$ the STC will report any sampling problems to the EG&G CAR and the Subcontractor Program Manager. TOCDF LCPT Plan Section No.: 4.0 Revision Dut., si.'.;;L)l;r, i Page No.: 5 4.8 SUBCONTRACT LABORATORY The subcontracted laboratory 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 QC requirements outlined in the QAPP. In addition, the laboratories will be responsible for archiving the laboratory data that they generate. TOCDF LCPTPIan T:Ii:Hft". '? Revision Date: Dec;?;;i?.ir t ? 5.0 QUALITY ASSURANCE AND QUALITY CONTROL OBJECTIVES The overall objective of the measurement data for the LCPT is to demonstrate the removal of arsenic, ash, and mercury from the exhaust gas by the PAS. This will be demonstrated by collecting PM and metals emissions samples at the ATLIC exhaust stack. 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 LCPT. The DQOs, summarized in Annex A, will be used to evaluate the data generated during the LCPT. These criteria identify the target precision and accuracy limits that arc used to assess the DQO. 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 LCPT field data. A complete assessment of the DQOs will be included in the LCPT report. The data quality will be discussed with regard to the planned data acceptance criteria and the overall project objectives. Data that are outside the QC limits will be evaluated to determine their impact on defining system performance. A discussion of this evaluation will be included in the LCPT report. Several procedures will be used for monitoring the precision and accuracy objectives of the analytical program. These procedures include: o Sampling and analytical activities that will follow standard referenced procedures whenever possible. o 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 blanks, duplicate samples, and matrix or surrogate spiked samples. Sections 6.0 and 10.0 describe the project-specific QC sample tlpes that willbe analyzed, aurtd list the sampling and analytical methods to which theywill be applied. When analytical QC procedures reveal that a measurement error has exceeded the target criterion, the source of the deviation willbe identified, and corrective action will be taken as described in Annex A. If data fall outside the acceptable range ofprecision 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 analyical) 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. I TOCDF LCPT Plan Section No.: 5.0 Revision No.: I Revision Date: December 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 nearthe method detection limit, the precision estimates that are outside the target DQOs will be flagged as estimated measurements. In 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 (MSA4SD). The MSA{SD will be used because the field samples have a history of very low concentrations. Precision for the metals emission samples will be based on the RPD of the Laboratory Control Sample (LCS) and duplicate analyses of one emission sample. Precision data for metals in the process samples will be based on MSiIVISD and duplicate samples. The estimate for precision for the CEMS data willbe 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 DAQ or 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 MSA{SD. 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 compounds spiked into each sample. Section 13.0 provides the accuracy calculations. Accuracy data will be presented in the data validation report. TOCDF LCPT Plan Section No.: 5.0 Revision No.: I Revision Date: December 2,2010 Page No.: 3 Calculation of the accuracy for each analysis will be based on different criteria taken from the QA/QC Handbook (4) 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 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 Attachment2} (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 LCPT 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 occurrence of sample loss willbe assessed against the objective of obtaining valid runs and will be discussed in the LCPT Report. 5.4 DETECTION AND REPORTING LIMITS The laboratories will prepare Method Detection Limit (MDL) and LOQs for parameters to be analyzed for the LCPT using the laboratory's standard operating procedures and the analyical methods referenced in this document. These limits will be compared to the actual analyical results in the final report. Analyes not detected in the analyses will be reported as less than (<) the LOQ. Analytes 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 LCPT parameters are included in Annex A. TOCDF LCPT Plan Section No.: 5.0 Revision No.: I Revision Date: Decemb er 2, 2010 Page No.: 4 5.5 REPRESENTATIVENESS 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 LCPTPIan Section No.: 6.0 Revision r",., B!ffiXrl ro, i Page No.: I 6.0 SAMPLING AND MONITORING PROCEDURES The ATLIC must demonstrate an ability to effectively remove arsenic, ash, and mercury from the combustion gases 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 LCPT will demonstrate that the ATLIC operating parameters meet the required performance standards. The data obtained during this LCPT will demonstrate compliance with these regulations by demonstrating the arsenic, PM, and mercury concentrations meet the MACT limits. This section describes the process and exhaust gas sampling procedures to be performed and the equipment to be used during the LCPT. The sample types, sampling locations, and sample collection procedures will also be discussed. The sampling subcontractor will utllize EPA- approved sampling methods, if available, for the selected analytes. 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 the LCPT. 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, andfinalization 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 LCPT will be included in the LCPT Report. The calibration frequency for the process control instruments is summarizedin Table 2-2 of the LCPT plan. 6.1.2 Sampling Equipment Calibration Section 8.0 discusses the calibration procedures for the sampling equipment. TOCDF LCPT Plan Section No.: 6.0 Revision No.: 1 Revision Date: December 2,2010 Page No.: 2 6.1.3 Glassware Preparation The only consumables used in the LCPT sampling will be the sample bottles, and the reagents used in the impingers 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 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; l0 percent nitric acid soak; DI water rinse; acetone rinse; and air dry. 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 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. A High Resolution Gas Chromatograph/fligh Resolution Mass Spectrometer (HRGC/HRMS) analysis of each batch of XAD-2@ resin will be provided before use as a QA/QC step to ensure that the resin is contaminant free. 6.1.5 Additional Pre-Sampling Activities Prior to mobilization of the field progr anrL, asample team meeting will be held to designate responsibilities to each team member for the LCPT. 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 amd2 (6). These data will be used to calculate the appropriatenozzle size and sample flow rate to be used to accomplish isokinetic sampling. TOCDF LCPTPIan Section No.: 6.0 Revision No.: 1 Revision Date: December 2,2010 Page No.: 3 6.2 FIELD QUALITY CONTROL ACTIVITIES 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 outlined in Section 7.2. Submitting fi eld-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. Samples of 0.1 Normal (N) sulfuric acid (H2SO4), 0.1 N sodium hydroxide (NaOH), acetone probe rinse solvent, and the particulate filter will be collected for the Method 5l26[trains. The following samples will be collected for the Method 29 train: 0.1 N nitric acid (HNO3) probe rinse solution, particulate filter, 5 percent HNOI and 10 percent hydrogen peroxide (HzOz) impinger solution, 4 percent potassium permanganate (KMnOo) *d 10 percent HzSO+, and 8 N HCl. The following reagent blanks will be collected for the Method 0023A trains: acetone, methylene chloride, and toluene solvent rinses, particulate filter, and DI impinger water. Each reagent blank will be analyzed for the same analyical parameters as the actual LCPT 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 LCPT to provide a QC check on sample handling 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 samples. The DAQ and DSHW willbe notified when the field blanks will be collected to allow them the opportunity to observe. TOCDF LCPT Plan Section No.: 6.0 Revision No.: 1 Revision Date: December 2,2010 Page No.: 4 6.2.3 Field Duplicates Duplicate samples of the Lewisite agent, scrubber liquor, and spent decon will be collected during one performance run as a QC step. 6.3 EXHAUST GAS SAMPLING The exhaust gas sampling will be conducted by EG&G and a sampling subcontractor. The sampling will take place in the ATLIC exhaust stack. Lewisite monitoring and monitoring for CO, Oz, and NO* with the ATLIC CEMS will be conducted by EG&G. The sampling subcontractor will sample for PM, HCl, Cl2, metals, and PCDDs/PCDFs. 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 Lewisite agent 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 willbe 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 LCPT are summarized in Table A-6-1. Sampling port locations for each train are shown in Drawing EG-22-D-8211in Attachment 4 to the Permit Modification. Three sampling trains will be used in four 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 A-6-1. 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 the leak checks. The three trains and constituents to be sampled are: Method 5126A (6) for PM, HCl, and Clz) Method 29 (6) for HHRA metals; and Method 00234 (1) for PCDDs/PCDFs TOCDF LCPT Plan Section No.: 6.0 Revision No.: I Revision Date: Decemb er 2, 2010 Page No.: 5 TABLE A-6.1. EXHAUST GAS SAMPLING SUMMARY Sampling Analyses Performed Sampling Method Reference Number Of Samples Collecftd during the LCPT (3 Runs) Method 1 Traverse Points 40 CFR 60, Appendix A I Method 2 Duct Velocity 40 CFR 60, Appendix A With each isokinetic trarn Method 3 COz andC,2 40 CFR 60, Appendix A Integrated bag samples over each run Isokinetic Trains Exhaust Gas Moisture 40 CFR 60, Appendix A With each isokinetic trarn Method 5126A PM, HCl, and Cl,40 CFR 60, Appendix A 3 sample sets & 1 field blank Method 29 HHRA Metals 40 CFR 60, Appendix A 3 sample sets & | field blank Method 00234 PCDDs/PCDFs SW-846, Method 00234 3 sample sets & | field blank CEMS Oz, CO, and NO^Attachment 20 (5)Continuously The Lewisite monitoring techniques operated by EG&G are the automated NRT Lewisite monitoring with the MINICAMS@. The Lewisite concentration is confirmed with DAAMS tube analyses. 6.3.1 Lewisite Monitoring Methods Overall operation of the agent monitoring systems is discussed in the TOCDF "Agent Monitoring Plan" [Attachment 22Ato the TOCDF permit (7)]. These systems have undergone extensive testing and evaluation under both simulated and actual field conditions, and the U.S. Army has provided all of this information to the EPA and the DSHW. Lewisite concentrations in the plant and in the exhaust gas are monitored using MINICAMS@ (a NRT monitor). Operation of these systems is controlled by Tooele Laboratory Operating Procedures (TE-LOPs). The Lewisite monitoring methods lutllize 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 (XSDTM) for the detection of the Lewisite derivative. The Lewisite concentration is confirmed with t'wo different MINICAMS@ that have different columns that result in different retention properties for the Lewisite derivative. To confirm the Lewisite concentration, the derivative must be detected on both MINICAMS@. TOCDF LCPT Plan '.'ii',1i")ft;., '? Revision Date: December 2,2010 Page No.: 6 The precision and accuracy of each monitoring system is determined through actual on-site testing after the equipment has been installed. These data are used to establish QC bounds, calibration and challenge frequencies, and procedures. These challenge frequencies and procedures are then delineated in a QC plan for each system. MINICAMS@ is the commercial trademarked name for an automated system for the sampling and analyses of chemical compounds. The MINICAMS@ utilized for Lewisite monitoring employs a solid sorbent for agent collection and thermal desorption to an automated GC/XSDTM that is sensitive and selective to compounds containing halogens. Each MINICAMS@ requires a carrier gas (nitrogen) for chromatography separation, compressed air, a power source, and data recorder. The design is based on operational MINICAMS@ meeting the baseline acceptance criteria requirements in the Programmatic LMQAP or equivalent QC. The MINICAMS@ system will be utilized in all Lewisite-process areas where continuous monitoring for Lewisite is required to protect the health and safety of plant workers and for decontamination certification. The MNICAMS@ will also be employed for process monitoring activities. There are several MINICAMS@ units that will not be used for personnel safety monitoring and will not be connected to the Facility Control System (FCS) or ChromNet. These units will be used to monitor and clear various materials, buildings and equipment for disposal, entry or future use of equipment, and will be portable. Lewisite NRT monitoring requires dedicated sampling lines that cannot be shared for multiple agent or confirmation monitoring. Lewisite is detected by the MINICAMS@ at the Short Term Exposure Limit (STEL) (low-level) set by the U.S. Surgeon General for unmasked workers, and the Source Emission Limit (SEL) level. Operation of the MINICAMS@ is covered by TE-LOP-524. The agents monitored by the MINICAMS@ will be in accordance with Attachment22A(7). The MINICAMS@ represents state-of-the-art instrumentation for the detection and quantification of chemical agents in both workplace and furnace exhaust gas environments. These two environments are substantially different in their composition and potential interferences. The MINICAMS@ cycle time is divided into a sample collection period, and a desorption and analysis period. To provide continuous monitoring of the exhaust gas during the LCPT, there will be four MNICAMS@ online and two backups at the ATLIC stack. These MINICAMS will be divided into two sets. Two different columns will be used in the two sets to allow different elution orders to the Lewisite derivative to allow the Lewisite concentration to be verified. The instruments will be cycled, so one MINICAMS@ group will have a MINICAMS sample the gas at each location while the second MINICAMS@ in that group is in the desorb/analysis mode. The cycling of the ATLIC MINICAMS@ will be verified on an hourly basis by the MINICAMS@ operators. One MINICAMS@ of each group will be held in reserve to be used if a MINICAMS@ fails. TOCDF LCPT Plan *lrHft:'? Revision ru,., r"TT;...*?. lo, ? The MINICAMS@ collects the sample and then thermally desorbs the (2-chlorovinyl) arsonic acid into the GC column that separates the organic compounds and detects the Lewisite derivative when it leaves the column using the XSDTM. The XSDrM is a thermionic device that uses a platinum cathode treated with an alkali to detect halogens released by the combustion of the compound in a reactor assembly. Lewisite is monitored on a continuous basis to ensure that chemical agents are not emitted to the environment. An AWFCO will be initiated if a MINICAMS@ alarm occurs in the ATLIC stack. There are two scenarios of alarm: A MINICAMS@ malfunction - A technician responds and determines that the MINICAMS@ is malfunctioning. When the malfunction is resolved, feed resumes. Agent feed will resume upon verification that the MINICAMS@ malfunctioned. o A MINICAMS@ alarm with possible agent present in the ATLIC stack - Technicians respond to the alarm and determine whether both MINICAMS@ groups detected Lewisite. If Lewisite is not confirmed by being detected by both MINICAMS groups, feed will resume, and sampling will resume when the MINICAMS@ false alarm is resolved. If both MINICAMS groups detect Lewisite, feed will not resume. Prior to re- initiating waste feed to the incinerator, EG&G and the U.S. Armywill determine the cause and develop a course ofaction to prevent recurrence. The evaluation and testing program for these units in the field is rigorous. The precision and accuracy data are generated while sampling actual exhaust gases during non-agent operations. The LOQ of the MINICAMS@ at the SEL level is 0.003 mglms for Lewisite. The testing and evaluation in all agent modes have been completed. The monitors met the 95 % confidence level for +25 o/o acatracy. The MINICAMS@ Lewisite cycle time is estimated to be fifteen minutes. 6.3.2 Method I 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 EPA Method 1, "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 Method 2 to Determine Exhaust Gas Velocity and Volumetric Flow Rate The exhaust gas velocity and volumetric flow rate will be determined using EPA 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. TOCDF LCPT Plan Section No.: 6.0 Revision No.: I Revision Date: Decemb er 2, 2010 Page No.: 8 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 willbe 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 Method5l26Afor 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 qurartz-ftber 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: o Impinger 1: Condensate impinger containing 50 mL of 0.1 N HzSO+. . Impingers 2 and 3: Greenburg-Smith impingers containing 100 mL of 0.1 N HzSO+. o 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. 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 ! l0% of isokinetic conditions. The probe rinse and the material collected in the filter housing will be used to determine the PM emissions. This method does not require the sample fractions to be cooled. An ion chromatograph (IC) will be used to analyze the impinger solutions. The HCl emissions will be determined from the analysis of the HzSO+ impinger solutions and the Clz 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 hlpochlorite (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. 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 for the other trains. TOCDF LCPT Plan Section No.: 6.0 Revision No.: I Revision Date: December 2,2010 Page No.: 9 6.3.6 Method 0023A for PCDDs/PCDFS Method 0023A (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). Exhaust gas is extracted isokinetically through ports in the ATLIC exhaust stack 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 at 248'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 zuranged 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 O)23Asamples 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. 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. After sample collection, the recovered sample fractions will be cooled at< 4"C 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. 6.3.7 MethodZ9 for Metals Metal emissions will be sampled using EPA Method 29 (6). The set up, 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 confi gurations are: Impinger l: Empty modified Greenburg-Smith, to serve as a knockout. Impinger 2: Modified Greenburg-Smith containing 100 mL of 5Yo HNO: and l0o/o HzOz. o TOCDF LCPT Plan Section No.: 6.0 Revision No.: 1 Revision Date: December 2,2010 Page No.: l0 Impinger 3: Greenburg-Smith containing 100 mL of 5oA HNO3i 10% HzOz. Impinger 4: Empty modified Greenburg-Smith. Impingers 5 and 6: Modified Greenburg-Smith containing 100 mL each of 4oh KMnO+ andl}Yo HzSO+. Impin ger 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 HNOI 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 rinse weight recorded on the field sample recovery sheet. Then 100 mL of acid is placed in a second wabh 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 willbe 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 HCl; 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 fllter holder. These two fractions will be analyzed for the HHRA metals. Impinger 4 and its rinse will be analyzed for mercury only. Impingers 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; therefore, the samples will be shipped without cooling. The reagent blanks will be prepared as directed by Method 29. Analyze the reagent blanks to determine if significant amounts of metals are added through the reagents. The reagent blank will be used to make the corrections as called for in Sections 12.6 and 12.7 of EPA 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 will be leak checked and then allowed to sit for the sampling time. Recovered samples will be analyzed usiirg the same methods as field samples. 6.3.8 Continuous Emissions Monitoring The CEMS operated by EG&G as part of the environmental permits 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 20 (5), which also describes specific locations, sampling frequencies, and the specific tlpes of instrumentation for each TOCDF LCPT Plan Section No.: 6.0 Revision r",., llllHol)rl ;0, I Page No.: 1l monitoring station. Attachment 20 of the TOCDF RCRA Permit (5) describes the 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 LCPT as directed by the HWC MACT regulations. The CO, o,2, andNO. 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/B. 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 reference standards daily at a minimum. Zero and span checks will be considered a verification of 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 FCS will record the CEMS data, which will be used for Oz corrections. The CEMS are certified by on-site testing and calibrations according to the guidelines delineated in a quality control plan and laboratory operating procedure for each CEMS. In addition to the initial 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 20 (5). Additional parameters will also be monitored using CEMS operated by the sampling subcontractor or through manual methods involving an integrated sample. These CEMS will be used to monitor for COz and Oz. The subcontractor will report the data from each of the monitors. An exhaust gas molecular weight will be calculated from the subcontractor CEMS data or by manual reference rnethods. Each individual CEMS will be calibrated as directed in the respective methods. 6.4 PROCESS SAMPLING Table A-6-2lists the sample streams, analyses to be performed, sampling method, sampling frequencies, and sample volumes. The process samples will be collected using ASTM International (ASTM) methods. Liquid samples will be collected from taps provided for sample collection. Field duplicates of the scrubber liquor, spent decon, and Lewisite agent samples will be collected during one run. TOCDF LCPT Plan Section No.: 6.0 Revision No.: I Revision Date: Decemb er 2, 2010 Page No.: 12 TABLE A-6-2. PROCESS SAMPLE,S TO BE COLLE,CTE,D * One run will have a duplicate set of samples collected. 6.4.1 Process Stream Sampling Locations Process streams sampled as part of the LCPT include the Lewisite agent feed, spent decon, and scrubber liquors. Lewisite agent samples will be collected from a valve in the feed lines after the tank contents have been mixed. A grab sample of spent decon is taken from the SDS collection tank. The contents of the SDS tank will be mixed before collection of the sample. The spent decon samples are collected before the run begins to allow the contents to be agent screened before the spent decon is processed. If additional NaOH or other material is added to the SDS tank, then new samples will be collected. The scrubber liquor samples will be taken via taps on the side of the sump. Samples of the Lewisite agent 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 collected from a tap on the process water line. Sample Stre,am AnalySes Perfor,rned Sampling Method S.ampIin,g Frequency Sample Volume Scrubber Liquor * Lewisite, 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 Lewisite, 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 Spent Decon Solution >F Lewisite, 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 Process Water HHRA Metals, VOCs, SVOCs, PH, TDS Tap, ASTM Method D3370 One Sample per LCPT Three 40-mL VOA vials, one 250-mL, one 500-mL, and two 1-L bottles Lewisite Agent* HHRA Metals, agent purity, organic impurities Tup, ASTM Method D3370 One Sample per Run One 5-mL bottles I TOCDF LCPT Plan Section No.: 6.0 Revision No.: I Revision Date: Decemb er 2, 2010 Page No.: l3 6.4.2 Tap Sampling Method Liquid process samples will be collected using the method described by the ASTM Method D3370 (8). The sample 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. The sample line is inserted into the sample container, and the tap is opened so that the sample bottle is filled. This sampling flow reduces the loss of volatile compounds from the sampling container prior to closing the container. This 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 the run, and other samples will be collected throughout the run. The spent decon samples will be collected before the runs to allow the sample tobe analyzed before processing the spent decon. 6.5 PROCESS MONITORING EQUTPMENT Process electronic data output will be monitored carefully by incinerator operators to maintain steady-state operating conditions during the LCPT. 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; Waste Feed rates; 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 ACTIYITIES 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. TOCDF LCPT Plan ti'Jii.1)"*".,'? Revision out., D..ffi;,,?.r, ? 7.0 SAMPLE HA}IDLING, TRACEABILITY, AI\D HOLDING TIMES This section describes the sample preservation methods, holding times, field documentation and shipping requirements. Exhaust gas samples will be collected by the sampling subcontractor. Lewisite agent samples, scrubber liquor samples, and spent decon samples will be collected by EG&G operations personnel, who will label and transport the samples to the CAL for Lewisite analysis and transfer the required samples to 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 oC 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. TOCDF LCPT Plan Section No.: 7 .0 Revision No.: I Revision Date: Decemb er 2, 2010 Page No.: 2 TABLE A.7.1. SAMPLE PRESERVATION AND HOLDING TIMES Holding TimePreservationParameter Process Streams (Residue) IJnoreserved Metals 6 months (28 day Hg) 28 davs (14 davs H Cool (< 4 "C) Extract 14 days, Analyze 40 daysSVOCsCool (< 4'C) Extract 30 days, Analyze 45 daysPCDDs/PCDFs Cool (< 4'C) Exhaust Gas 28 daysMethod 5 - PM None Required 28 daysMethod26A- Sulfurrc Acid Solutions No Additional Required 28 daysMethod26{- Sodium Hydroxide Solutions 2mL of 0.5 NazSzO: No Additional Required Method29 28 days Method 0023A Extract 30 days, Analyze 45 daysCool (< 4 "C) Gummed-paper labels or tags will 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. The incinerator designator and trial run number. The tlpe 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. TOCDF LCPT Plan Section No.: 7 .0 Revision No.: I Revision Date: Decemb er 2, 2010 Page No.: 3 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 maybe 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 recovery laboratory, the laboratory chemist will check in the sample fractions, and sign 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 TOCDF LCPT Plan ti'J,T"T"*"., '? Revision Date: December 2,2010 Page No.: 4 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 following information: The sample identification number; The date and time of sample collection; The signature or initials of the sample collector; The matrix tlpe; 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 analysis request form. The request form will list the variables tobe analyzed by the laboratory and the total number and tlpes 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. TOCDF LCPT Plan Section No.: 8.0 Revision o",., fi!I'##)rl, I Page No.: I 8.0 SPECIFIC CALIBRATION PROCEDURES AND FREQUENCY 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 instruments are calibrated on a regular basis as directed in the Instrument Calibration Plan (9). The calibration status of the LIC process control instruments at the time of the LCPT will be summarized in the 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 LCPT and verify the calibration afterwards. When the STC arrives 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 LCPT Plan Section No.: 8.0 Revision No.: I Revision Date: December 2,2010 Page No.: 2 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 oF, 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-type 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 to 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 Attachment2} (s). TOCDF LCPTPIan ti'JiffJ"*",'? Revision Date: Decembe.a?.r, ? 9.0 ANALYTICAL OBJECTIVES AND PROCEDURES This section describes the analytical procedures to be used to analyze the samples collected during the LCPT. The analytical methods to be used include GC/IVIS, HRGC/HRMS, IC, Inductively Coupled Plasma/Mass Spectrometer (ICP/IvIS), 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 analyical 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 (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 and field blanks to be analyzed. Table A-9-2 assumes the following for: Method 0023A samples - One set of samples per run plus one field blank per LCPT. Analyses will be for PCDDs/PCDFs. Method 29 samples - One set of samples per run plus one field blank per LCPT. Analyses will be for the HHRA metals. Method 5126A samples - One set of samples per run plus one field blank per LCPT. Analyses will be for PM, HCl, and Clz. Liquid Samples - the scrubber liquor samples will be collected during the final 60 minutes of the run. A spent decon sample will be collected for each run, but it maybe collected before the run to allow analyses to be conducted before the run. One duplicate set of scrubber liquor samples and spent decon samples will be collected during one run. The liquid samples will be analyzed for total HHRA metals, VOCs, SVOCs, and PCDDs/PCDFs. The process water sample will be analyzed for HHRA metals, VOCs, and SVOCs. Lewisite Agent Samples - An agent sample will be collected for each run and analyzed for HHRA metals. TOCDF LCPT Plan Section No.: 9.0 Revision No.: 1 Revision Date: December 2,2010 Page No.: 2 TABLE A-9.1. ANALYTICAL METHODS Analysis MethodPfeparationParameterMatrix TE-LOP-562TE-LOP-562DAAMS TubesAgent Method 0023 A18290Method 0023AXAD -2 @/fi lter/rins e ate Method 5Method 5Particulate Matter Filter/rinse Metho d 9057Metho d 26AImpinger solutionsHCI and Clz Methods 6020 and 74704 Filter, rinse, impinger solution Metho d 29HHRA Metals TE.LOP-584 TE-LOP.551HHRA Metals Lewisite Agent TE-LOP-572 TE-LOP-572LewisiteScrubber liquor and spent decon Method 82608Scrubber liquor, process water, and spent decon Method 50308 Method 3510C Metho d 8270CScrubber liquor, process water, and spent decon Scrubber liquor and spent decon Method 8290PCDDs/PCDFs Metho d 8290 Method 3010Ai3015A/ 7 4701^ Scrubber liquor, process water, and spent decon HHRA Metals Method 602017470A TABLF, A-9.2. NUMBER OF SAMPLES Sarnple LCPT Field Duplic,ate Field BIan,k DA$4S Method 00234 Method 5126A 1 8 sets 3 3 9 9 0 1 Method 29 3 0 1 Process Water 1 0 0 Scrubber Liquor 3 1 0 Venturi Scrubber Liquor 3 I 0 Spent Decon 3 1 0 Lewisite agent 3 1 0 Method blanks, blank spikes, matrix spikes, and replicates will be performed according to the methods. TOCDF LCPT Plan 'i'Ji:JJ"i",'? Revision Date: December 2,2010 Page No.: 3 9.1 ANALYSIS METHODS FOR PROCESS STREAM SAMPLES Process samples collected include scrubber liquor and spent decon. The process streams will be sampled each run. 9.1.1 Lewisite Analysis Method Samples of the scrubber liquor and spent decon must be screened for Lewisite before the samples can leave the facility. The method used for this analysis is TE-LOP-572, which uses hexane to extract the agent. An aliquot of the extract is injected into a GCA{S, where the agent is separated from any other compounds, and three masses are monitored to quantitate the Lewisite. 9.1.2 pH Analysis The pH of scrubber liquor samples and spent decon samples will be determined with a pH probe and pH meter using TE-LOP-574. The pH probe and meter are calibrated using appropriate 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. 9.1.3 Inorganic Analysis 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/MS. The methods are described below. . 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. . SW-846 Method 6020 - ICP/NIS. The metals concentrations in the process samples will be determined by ICPA{S. (The most recent version of the method will be used.) 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 by comparing sample responses to the responses of internal standards. TOCDF LCPT Plan Section No.: 9.0 Revision No.: I Revision Date: December 2,2010 Page No.: 4 9.1.4 Organic Compound Analysis Methods Scrubber liquor and spent decon 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 willbe 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 50308 (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 GCA{S. The sample is then analyzed for the Target Analyte List shown in Table A-9-3 using SW-846, Method 82608 (1). Quantitation is achieved by comparison of sample component responses to the responses of internal standards. The 20 largest 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 Identifi ed Compounds (TICs). SW-846 Method 8270C - Semi-Volatile Oreanic 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 GCA{S. Quantitation is achieved by comparison of sample component responses to the responses of internal standards. Table A-9-4lists the target analyes for the total SVOC analyses. The 20 largest 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 TICs. SW-846 Method 8290 - PCDDs/PCDFs by 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 then evaporated to a small volume and diluted to a known volume. An aliquot of the cleaned extract is then injected into a HRGC/HRMS and the compounds quantitated against internal standards as directed by SW-846, Method 8290. TOCDF LCPT Plan Section No.: 9.0 Revision No.: I Revision Date: December 2,2010 Page No.: 5 TABLE A.9.3. TOTAL VOC TARGET ANALYTE LIST FOR PROCESS SAMPLES I Acetone 29 I ,z-Dichloropropane 2 Benzene 30 1 ,3 -Dichloropropane 3 Bromobenzene 3l 2,z-Dichloropropane 4 Bromochloromethane 32 1 , 1 -Dichloropropene 5 Bromodichloromethane aaJJ cis -1,3 -Dichloropropylene 6 Bromomethane 34 tr ans -1,3-Dichloropropylene 7 2-Butanone 35 1,4-Dioxane 8 Carbon Disulfide 36 Ethylb eruzene 9 Carbon tetrachloride 37 n-Hexane 10 Chlorobenzene 38 2-Hexanone 11 z-Ch\oro - 1, 3 -butadi ene 39 Iodomethane T2 Chlorodibromomethane 40 Methylene chloride 13 Chloroethane 4t Methyl isobutyl ketone L4 Chloroform 42 n-Propylbenzene 15 2-Chloroethyl vinyl ether 43 Styrene t6 Chloromethane 44 |,l,l,2-T etrachloroethane t7 2-Chlorotoluene 45 1,1,2,2-Tetrachloro ethane 18 4-Chlorotoluene 46 Tetrachloroethylene t9 Cumene (i sopropylben zene)47 Toluene 20 2l 22 23 u 25 26 1,2-Dibromoethane Dibromomethane trans -1 ,4-Dichl$o2-b D ichl oro di fl uoro methane t, 1 ,2-Dichloroethane 1 , 1 -Dichloroethylene 48 49 50 51 52 53 54 Tribromomethane (Bromoform) 1r1, 1, 1,2-Trichloroethane Trichloroethylene |,l,2-Trichloro - I,2,2-trifluoroethane 27 c i s - 1,2-Dichloro ethylene 55 Vinvl chloride 28 tr ans -1,2-Dichloro ethylene 56 Xylenes(o-, m-, p-) ATLIC STB TOCDF Analye List.xls VOC List (2) TOCDF LCPT Plan Section No.: 9.0 Revision No.: 1 Revision Date: December 2,2010 Page No.: 6 LISTTABLE A-9-4. TOTAL SVOC TARGET ANALYTE FOR PROCESS SAMPLES Acenaphthvlene 1,4-Dinitrob eruzene Acenaphthene 4,6-Dinitro-o-cresol Acetophenone 2,4-Dinitrophenol Aniline 2,4-Dinitrotoluene Anthracene 2,6- Dinitrotoluene Benz(a)anthracene Di-n-octvl ohthalate Benzo(b)fluoranthene Diphenylamrne Benzo(k)fluoranthene Fluoranthene Benzo(g,h,i)perylene Fluorene Benzo(a)pyrene Hexachlorob enzene 4-Bromophenyl phenyl ether Hexachlorobutadiene Butvl benzvl phthalate Hexachl oro cvc I oo entadi ene p-Chloroaniline Hexachloroethane Chlorobenzilate Indeno( 1,2,3-c,d) pyrene B i s (2 - Chl o ro etho xy) m ethane Naphthalene B i s (z-Chloro ethyl) ether 2-Naohthvlamine B i s (2-Chloroisopropyl) ether 2-Nitroaniline 4 - Chloro - 3 -methylpheno I 4-Nitroaniline 2-Chloronaphthalene Nitrob enzerne 2-Chloroohenol 2-Nitroohenol Chrysene 4-Nitrophenol o-Cresol Pentachlorobenzene m-Cresol Pentachloroethane -Cresol P e ntachl o ro nitro b enzene D i b e n z(a,h)anthrac e ne Pentachloroohenol m-Dichlorob enzene Phenanthrene o-Dichlorob enzene Phenol Dichlorobenzene 2,4-Dichlorophenol 1,2,4,5-Tetrachlorobenzene 2,6-Dichlorophenol 2,3,4,6 -Tetrachloropheno I Diethvl phthalate 1,2,4 -T richl oro benzene 2, -Dimethyl phenol 2,4,5 -Trichl oropheno I Dimethvl phthalate 2,4,6 -Trichl oropheno I Di-n-butyl phthalate ATLIC STB TOCDF Analyte List.xls SVOC List (2) TOCDF LCPT Plan Section No.: 9.0 Revision No.: 1 Revision Date: Decemb er 2, 2010 Page No.: 7 9.2 ANALYSIS METHODS FOR LEWISITE AGENT SAMPLES Lewisite agent samples collected are analyzed for HHRA metals. The Lewisite agent samples will be prepared by Method TE-LOP-584, and the HHRA metals present in the samples are analyzedby ICP/MS using TE-LOP-557. The agent samples are prepared for analysis using TE- LOP-584 by digesting an aliquot of Lewisite agent in a combination of hydrochloric acid and nitric acid, and then heating in a microwave oven. The digested sample is then diluted to a known volume and arralyzed by aspirating the solution into the plasma, which produces an atomic vapor. The mass spectrometer separates the elements in the vapor by their mass. The elements are quantitated against internal standards. 9.3 ANALYSIS METHODS FOR EXHAUST GAS SAMPLES 9.3.1 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 a 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 collected 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: STANDART)COMPOUNDS Surro gate Standards ''' clo-2,3,7 ,8-TCDD, "c n-\,2,3,4,7,S-HxcDD, "C tz-2,3,4,7, S-PeCDF, "c n-\,2,3,4,7,8-HxcDF,"c D-|,2,3,4,7, 8,9-HpcDF Internal Standards t'C t2-2,3,7,8-TCDD, t'C tz-L,2,3,7,8-PeCDD, "c n-|,2,3,6,7,S-HxcDD, "c n-|,2,3,4,6,7,8-HpcDD, "c l2-ocDD, "c n-2,3,7,8-TCDF, "C n-\,2,3,7,8-PeCDF, "C r2-1,2,3,6,7,8-HxCDF, "c n-r,2,3,4,6,7,8-HpcDF TOCDF LCPT Plan Section No.: 9.0 Revision No.: I Revision Date: December 2,2010 Page No.: 8 Table A-9-5 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. TABLE A-9-5. PCDD/PCDF TARGET ANALYTE LIST Po:Iy:ehlorina 2,3,7,$-TCDD 2,3,7,8.TCDF Total TCDDs Total TCDFs 1,2,3,7,S-PeCDD 1,2,3,7,8-PeCDF Total PeCDDs 2,3,!,7,S-PeCDF 1,2,3,4,7,S-HxCDD Total PeCDFs 1,2,3,6,7 ,S-HxCDD 1,2,3,4,7 ,8-HxCDF 1,2r3,7 ,8,9-HxCDD I,2,3,6,7 ,S-HxCDF Total HxCDDs 2,3,4,6,7,8-HxCDF 1,2,3,4,6,7 ,8-HpCDD 1,2,3,7 ,8,9-HxCDF Total HpCDDs Total HxCDFs O ct achl oro d rb enzo -p - di o x in 1r2,3,416r7,S-HpCDF 1,2,3,4,7 ,8,9-HpCDF Total HpCDFs O c t achl o ro d rb enzo furan TOCDF LCPT Plan Section No.: 9.0 Revision No.: I Revision Date: Decemb er 2, 2010 Page No.: 9 9.3.2 Analysis of Metals Emissions The Method 29 samples will be analyzed for the HHRA metals and are listed in Table A-9-6. The samples will be prepared as described in Method29 (6). Mercury will be analyzedby CVAAS using Method 7470A. The remaining elements will be analyzed by ICP/IMS using SW- 846, Method 6020 (l), which was modified by the addition of 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 external standards. o SW-846 Method 6020 - ICP/NIS. Metals concentrations in the Method 29 samples will be determined by ICPA{S. (The most recent version of the method will be used.) A representative portion of the sample is digested with nitric acid and the sample digest is aspirated into the nebulizer of the ICP/IvIS. 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. 9.3.3 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 impinger samples 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. 9.3.4 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 LCPTPIan Section No.: 9.0 Revision No.: I Revision Date: December 2,2010 Page No.: 10 TABLE A.9.6. METHOD 29 TARGET ANALYTE LIST .:t:l].:.:.:l:,l]:,1.:,..:::,i,,,:::.i::,:::.:::,:::.:.:':.::l:il .., :r,::. An:*rytq:;:ll. Aluminum Lead Antimony Manganese Arsenic Mercury Barium Nickel Beryllium Selenium Boron Silver Cadmium Thallium Chromium Tin Cobalt Vanadium Copper Ztnc TOCDF LCPT Plan "flT,:,Y*",'o ? Revision ru,., o.TT;;.*?.:0, ? 10.0 sPECrFrc 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 MSA{SD. 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 precleaned 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 analyical 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 LCSs are used to establish that an instrument or procedure is in control. The LCSs are normally carried through the entire sample preparation and analysis procedure. The QC criteria for the LCS are listed in Arurex A by analysis method. 10.3 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 Lewisite agent, scrubber liquor, and spent decon samples during one performance run. Samples analyzedby CVAAS will be analyzed in duplicate as specified in the method. 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. TOCDF LCPT Plan Section No.: 10.0 Revision No.: I Revision Date: December 2,2010 Page No.: 2 10.4 MATRIX SPIKE SAMPLES Matrix spikes are samples spiked with the analye of interest and then analyzed 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 spent decon samples. The QC criteria for %R and RPD are shown in Annex A for each method. rO.5 SURROGATE SPIKES Surrogate spikes will be used for GC/N{S 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-d1a; phenol-d6; 2-fluorophenol; and2,4,6-tribromophenol. Surrogate spikes will also be used for Method 8290 for PCDD/PCDF analyses. 10.6 ANALYTICAL INSTRUMENT CALIBRATION The analytical instrumentation used in the laboratory for analysis of LCPT 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 dailybasis, a continuing calibration check will be analyzedbefore any samples are nrn 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 verifo 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 analyical method and listed in Annex A. hrternal standards will be analyzed to evaluate instrument and method performance. The QC criteria for the internal standards are listed in Annex A by analysis method. EO + < O c A -L\ | A F -r l J A:- - a( f e ^i e ri ': A r- A Y O e () 6) ; z ?o r i" HE . g b o - , \J JJ 0) q) a I & o ?a (- ) :)cdn(1-o 'F l a't()& bosol. r t4 r- ( (J0)FECdHdaE EH(1 CE l =' o !- ; Xr < c d ){ r u tr E a 5H k ur , . € t 9 s (. ) t r = -q o. : U* E tr qJ i o M, i. j .r Cl l E; E ^. '- \. / +, !a .- lr - , r CB ! 8p 2 ', ; ll tt .l l C) r\ rr F €V l + i r a . OU i l Y zo dz 0RcHt{El F]=F]Ut. ( t' l F]ziloEr rardil-R14Uc&Frzolr (Frttr-F]Ua F{ !O-I Ft ] jtrFr )- rBot- { J1qio10g\O+t \0 )^. e Yc B ts {BoL{ -\ 4 (r {osO+tHE sONVI ,El<e (l )oo (obo PA f; &Ov o -o \ r- O .; { eO po CI ' 'n t& Ed ()a0 cOba ?a f, &O1 0 ht '= ca i; (J - / soHp bo HLrd ,. 1 ()a BoHJ1qro-Oo\O+t \ 0. ) YG I (D+)CB 'o HCO"a 9 ? 00 ) Y A. ( D tr = Hd :; g O? 1 x l- { be (' ) +. { \o^' d L- i c) 0) +)63€t- r cO (l ) [i e o. o i= = =du9 O? t F{ = hLbe (D q- { x\ o3E r\ H \J ( D €ot- r ()q(DLroINIi(l )o*tTUOU Eol- { ()P.otr):) t- . {oINxLro(DT, (. ) rEtic) Eol- rog(. ) t- {koINhl<()C) rd(. ) t r- {L{ (. ) e0 'o+roE)- ' ( ()E(€oo Llao (l )m (l ) (€El- r cOa0)ga l HOE8 o* F{ ( l )be () + r \o3' d vc ) 1: 1 , 1 , ; 1 1 ; 1 ; : 1 1 , f l ) : 1 : 1 : 1 , 1 , ': : : ' : : l ' : : : ' : . . J { : : : . : . : ' : ' : ' : ,l , t l , , t : , , , : * . 1 , . : , t . 1 :: : : : : : : : : : : : : : : j l : : : r . : :: ::: : .: : : , : , j , . , . , : ' : H i i : : j i : ': : : : : : : : l i : l : : i l : : : : : j . i ,. , . ' . , . , . , . ' . , . H . : i ' i : . : , .j i . , j , , , . # i : : : i : , { : : : :i : : i :: : : l : i : i i : $ l j: : : jl l : : ::t : i i i , : : : : : : : ' i i : i : i :,, , : : . : i ji j i :: : : : : : : : : : : : : : I | , : , : : , , : ] :: : : : : : : : : : : : : : : l I : : : ; : : : , : :: : : : : : : : : : : : : : : L r r : : : j j: : : ] ,: : : : : : : : : : : : : : : f j l : : : : : : : : : | :: a l . a a . , l : l A d , , t l | l l . l t: i ' t i : t t t t { i ' l z t t t t t t t : t l ji t : t j j : i i i i i f f i ii i ; i : i i i i i :, , : , , : , : , : , I , i . : , i : : , , :, : ' : , i , i : , i : ' I l i i : , i ', , , , , , r , i *i l :.i . : . : . , :: : : : : i : : : : I t : : : : : : : : : : :: : : : : : l : : : E l : : : : : : : : : : ll i i : i ; ; i i : ; : : i H : i : i : : i : : t i: i : i : i : i : I r : : : : : : t : : : : : : : : : : :l : l : l : : : : : H i Z : : : : : : : : . l l, l l , r : : ; : t : : t t t r : : : : : : : , : : : , t , , , ::: l : : : l : : : ; l l : : ; : : ; : : : , t : , 0 , : ; , ; : : : : : t u)El<dEtr (oa\. ) "O)- {63 \n \) O\ ll o \ dPnX( ) '* 5 U Ee _o .. = '5 o 8s EL{dEF{(oa()o€FIdJ1ts t odpo(€ l- {sCOO Ho(€L(pCCOoqI(. ) tu oC€ l- rp(s(JF{oqIo) fr r (1o(cL{pcO()oaIo tr . ( a+JoooB()se0oo(BL, ' +)Faz UUcdoo FIoo )- {oC€ t<s63()troo, (n '. O \ HO \ OO tL n a: . , : : , . : a . a a . : t :i : i l i l i i l i i i i ; i l 0EA- { (, aOc 0Uc a\< {a&FUc&)- t r C) ()cBcB FAc0oxcS t- { *{adl- raooCBtrol- rOHo Ofr .$fr . O6lO\o caO\oNoo UOfr .N@ Oo\Noo \nEoo fr . \nOo\ TOCDF LCPT Plan Section No.: I 1.0 Revision No.: I Revision Date: December 2,2010 Page No.: 1 11.0 DATA REPORTING, DATA REVIEW, AND DATA REDUCTION Reporting the data generated during an LCPT is an important part of the overall project. This section describes and discusses the components of reporting, reviewing, and reducing the collected LCPT data. 11.1 DATA REPORTING The data reporting process will discuss the analytical datapackages, review of the data generated for this LCPT, and the final LCPT Report. 11.1.1 Analytical Data Packages Data reported from subcontract commercial laboratories will be required to be similar to the format used by the EPA Contract Laboratory Program (CLP). This format will include a case narrative section, Analytical Data Summary Sheets, QC Sample Results, the COC forms, and raw data organizedby analytical method. Complete datapackages are included so that an independent verification of the final analytical 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 perfoflnance 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 Analytical Data Summary Sheets will contain a summary of the analytical 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 internal COC forms used to track the samples through the different analyses in the laboratory. TOCDF LCPTPIan "fliT,Y;"," ? Revision Date: December 2,2010 Page No.: 2 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 orgarized 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 a 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 recovery 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 LCPT, 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 analyical sunmary sheets are defined on that specific sheet. Data presented in tables in the LCPT Report will note any data qualifiers. 11.1.3 LCPT Report An LCPT Report will be prepared and submitted to the DAQ and DSHW. EG&G will complete the LCPT report as outlined in Section 8.0 of the LCPT plan. The report will compare the LCPT results to the RCRA Permit, Title V permit, and MACT Limits. The LCPT Report will also contain: Dailyrun summaries. A summary of incinerator operating parameter data and associated limits. TOCDF LCPTPIan Section No.: I1.0 Revision No.: 1 Revision Date: Decernber 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 LCPT Report as an appendix. Additionally, each formal data deliverable will contain a sunmary of QA/QC 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. Furthennore, 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. TOCDF LCPTPIan Section No.: 11.0 Revision r",., |!ffiIrl ro,I Page No.: 4 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 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 LCPT Report. This review process will confirm that the dataare usable for an assessment of incineratorperformance. 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 bythe LCPT subcontractor QC personnel using criteria outlined in this QAPP. The subcontractor QC personnel will use validation methods and criteria appropriate to the tlpe of data, even data judged to be "outlying" or 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 analyical methods to identify 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. Analytical 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 veriff: 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: Use of approved test procedures. Proper operation of the process being tested. Use of properly operating and calibrated equipment. Use of proper forms for recording data, including identification numbers for each rrozzle, probe, and dry gas meter. Leak checks conducted before tests, during port changes, and after tests. Use of reagents that have conformed to QC-specified criteria. Maintenance of proper traceability. The criteria used to evaluate ana\rtical data include: [Jse of approved analytical procedures. TOCDF LCPT Plan '"iilll,Y*"," ? Revision o".' i*...-i.l,i zorI . Use of properly operating and calibrated instrumentation. . Precision and accuracy should be comparable to that achieved in previous analyical 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. Inorganic data will be evaluated using the general methods outlined in the EPA CLP guidelines for inorganic data (11) 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 (12). The PCDD/PCDF data will be evaluated using the general methods outline in the EPA guidelines for dioxin data (13). 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, whlch is a computed procedure for determining whether a single, very large or very small value is consistent with the data set. . Thg 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 hlpothesis 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 orgarization of accurate information, followed by clear and concise reporting of the data, is a primary goal in all projects. TOCDF LCPT Plan Section No.: I 1.0 Revision No.: I Revision Date: December 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 dailybasis 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 Analyses 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 willbe reported in units of milligram per liter (mg/L). Lewisite agent sample results will be reported in weight percent (Wt%) for arsenic and milligrams/kilogram (mg/kg) for the other 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 Method29 (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 LCPT will not be blank corrected. TOCDF LCPT Plan "ilT,:,Yii"," ? Revision r"., r..ff;;.*?.:0, ; 11.4 EXHAUST GAS SAMPLE TRAINS TOTAL CALCULATIONS The calculation of the train total of an analyte is the sum of two or more fractions of train components. Anrilytes not detected in the analysis will be reported as < LOQ. Analytes with concentrations between the MDL and the LOQ willbe qualified as estimated and reported. The summation for the total will use the LOQ 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 "1" fla;E added to the reported total. When the analyte 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 analyte for a train total. Rounding of numbers should conform to procedures found in ASTM SI-10 (14). TOCDF LCPT Plan "fllT,Y*"," ? Revision Date: Decembelft.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. o TOCDF LCPT Plan t'il',',1,Y*".," ? Revision Date: Decembe..?.:r, ? 13.0 ASSESSMENT PROCEDURES FOR 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 Annex A. Precision will be calculated for laboratory duplicate analysis using the following two equations: 1) RpD - [(Xt -Xz)/((Xr + Xz)tz))X 100 Where: RPD - Relative Percent Difference 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 MSA4SD. The MS/MSD will be used because the field samples have a history of very low concentrations. 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. TOCDF LCPT Plan Section No.: 13.0 Revision No.: I Revision Date: Decemb er 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 LCPT data will be determined from analysis of samples spiked with a known concentration. The number of spiked samples and the spiking levels will be designated by the respective methods. Accuracy DQOs for each method are in Annex A. The formula used to assess the accuracy of the LCS is: %R : (Qrcs /Qrc) X 100 Where: %R : Percent Recovery Qrcs: Quantity of Analyte Found in the LCS Qrc : Known Concentration of the LCS The formula used to assess the accuracy of the MSA4SD samples is: %R : [(Q,,-Q*)/Q,] Xl00 Where: %R : Percent Recovery Q,. : Quantity of Analye Found in the Spike Sample Qu. : Quantity of Analyte 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 analytical methods. Determination of accuracy for samples will be determined by the: . o/oR calculated from the analysis of the MSA{SD for the halogen samples. . Analysis of the LCS for the accuracy of the metals emission samples. . Analysis of the LCS for the PCDD/PCDF samples. . oZR from the analysis of the LCS and MSAdSDfor the VOC analyses in the process samples. . o/oR from the analysis of the LCS and MS/MSDfor the SVOC analyses in the process samples. TOCDF LCPT Plan Section No.: 13.0 Revision No.: 1 Revision Date: December 2,2010 Page No.: 3 13.3 COMPLETENESS Completeness is defined as the amount of valid data for an LCPT 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 runs for the LCPT (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. lf 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 ilre 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: c - (v/T) x r00 % Where:C - Percent Completeness V - Number of Measurements Judged Valid TOCDF LCPTPIan Section No.: 14.0 Revision r"., Illili#)rl ro, I Page No.: I 14.0 AUDIT PROCEDURES, CORRECTM ACTTON, AND QUALITY ASSURANCE REPORTING The LCPT 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 accuracy 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 bythe 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 LCPT. 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 Qd 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 LCPT 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 LCPT will be the Test Director or his designee. During each performance run, the sampling subcontractor performs a system audit, which consists of an inspection and review of the total sampling system, including: TOCDF LCPT Plan Section No.: 14.0 Revision No.: I Revision Date: December 2,2010 Page No.: 2 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 arnlyzed 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 Department, TOCDF QC lnspectors, or the sampling subcontractor' s QC Department. 14.3 CORRECTIYE 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 personnel 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 1og, 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) TOCDF LCPT Plan Section No.: 15.0 Revision No.: I Revision Date: December 2,2010 Page No.: I 15.0 REFERENCES Test Methods for Evaluating Sotid Waste, Physical/Chemical Methods,3'd Edition including Update tV, USEPA, SW-846, February 2007. Hazardous Waste Combustion Unit Permitting Manual, Component 2,ooHow to Review A Quality Assurance Project Plan," U.S. EPA Region 6, Center for Combustion Science and Engineering, January 1998. EPA Guidancefor Quality Assurance Project Plans, EPA QA/G-5, December 2002. Handbook: Quality Assurance/Quality Control (QA/QC) Proceduresfor Hazardous Wast e I n cin e r atio n, EP N 625 I 6 -89 I 023, January I 9 90. Attachment20 to the TOCDF RCRA Permit, CEMS Monitoring Plan, EG&G Defense Materials, Inc., TOCDF, CDRL-06. Title 40, Code of Federul Regulations,Part 60, Appendix A, "Test Methods." Attachmentzz[to the TOCDF RCRA Permi[ ATLIC Agent Monitoring Plan, EG&G Defense Materials, [nc., TOCDF. ASTM D 3370,1995 (Reapproved 1999), "Standard Practices for Sampling Water from Closed Conduits," ASTM International, West Conshohocken, Pennsylvania. Attachment 6 to the TOCDF RCRA Permit INSTRUMENT CALIBRATION PLAN, EG&G Defense Materials, Inc., TOCDF. (6) (7) (10) Quality Assurance Handbookfor Air Pollution Measurement Systems; Volume III - S t atio n ary S o u r c e Sp e cift c M et h o ds, EPA-6 00/4 -7 7 -027b . (11) USEPA Contract Laboratory Program National Functional Guidelines for Inorganic Review, EPA-540-R-04-004, October 2004. (12) aSEPA Contract Laboratory Program National Functiotnal Guidelines for Low Concentration Organic Data Review, EPA-540-R-00-006, June 2001. (13) USEPA Analytical Operations/Data Quality Center National Functional Guidelines for Chlorinated Dioxin/Furun Data Review, EPA-540-R-02-003, August 2002. (L4) ASTM SI-1 0,2010, "American Units (SD: The Modern Metric Pennsylvania. TOCDF LCPT Plan Section No.: 15.0 Revision No.: I Revision Date: Decemb er 2,2010 Page No.: 2 National Standard for Use of the International System of System," ASTM lnternational, West Conshohocken, LEWISITE COMPREHENSIVE PERFORMANCE TEST PLAN FORTHE AREA 10 LIQUID INCINERATOR APPENDIX A ANNEXA QA/QC OBJECTIVES FOR ANALYTICAL METHODS REVISION 1 December 2r 2010 TABLE OF CONTENTS 2.0 PCDDS/PCDFS SAMPLING AI\D ANALYSIS METHODS............ .... Annex A-2 2.1 SuuuenvQA/QCCrursRreronDroxrNsByMErHoD 0023N8290 ..AllNEXA-2 2.2 Suuuenv QA/QC Crureru.q ronDroxnqs By METHoD 8290 ............ .. AIINEX A-3 2.3 Lrun or QueNrrrerroN ronPCDDs/PCDFs...,...,... ...... AI\NEX A-4 3.0 HALIDE EMISSIONS Annex A-5 4.0 METHOD 6020 ICP/1VIS...... ...... Annex A-6 4.2 METHoD 6020 LOQs AI\NEX A-7 5.0 MERCIIRY ANALYSIS METHODS (7470A)....... Annex A-8 6.0 VoLATILE ORGANTd COUTpOUNDS IN PROCESS SAMPLES (8260B) Annex A-9 6.1 Suuueny or QC AND CALTBRATToN CzurpruoN FoRMETHoD 82608 (AquEous).. . AIINEX A-9 6.2 CoNrnol LrMrrs FoRPRoCESS S^c.r\4pr-Es By METHoD 82608 ...................... AIINEX A-10 7.0 SEMI-VOLATILE ORGAI\IC COMPOUNDS IN PROCESS SAMPLES Annex A-11 7.1 SuuuenvorSVOCQCeNnCeLrsRArroNCrurBruoNronMnrsooS2T0C ........ANNEXA-11 7.2 HISroFJCeLCoNrnolLnarrs ronMsrHoo 8270C.......... AIINEX A-12 8.0 METHOD TE-LOP-557ICP/1US DQOS......... Annex A-13 LCPT Plan - Rev. I Appendix A Decemb er 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 Incinerator (ATLIC) Lewisite Comprehensive Performance Test (LCPT). The objectives were developed from 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. LCPT Plan - Rev. I Appendix A Decemb er 2,2010 TOCDF Annex A - 1 lil]l,,lll H Dil:::lllllllll|lll.llllllllllll FBE.QUEN.CY,.:.,..,,C,RITER{A Initial Calibration (rcAL) Five-point calibration Initially and as required. Natives RSD < 25 o , except for OCDF < 30 % Evaluate system. Recalibrate. Continuing Calibration (ccAL) Midpoint standard at start of each 12 hour sequence %D of natives S 25 % from avg RRF (ICAL), except for OCDF < 30 % Evaluate system. Reanalyze CCAL. Recalibrate as necessary. Reagent Blank I per batch <5XLOQ Reanalyze and/or narrate. Field Blank I per ATB <5XLOQ Reanalyze and/or narrate. Method Blank I per batch <5XLOQ Reanalyze and/or narrate. Window Defining Mix(wDM) Column Performance Standard Mixture (cPSM) Once per 12 hours prior to sample analysis Used to set retention times. CPSM must have f 25% valley resolution for 2,3,7,8-TCDD Readjust windows. Evaluate system. Perform maintenance. Reanalyze WDM/CPSM. Method Blanks 1 per analyical batch < LOQ, except for OCDD @<sxLoQ Reanalyze if appropriate. Assess impact on data. Process archive sample if necess ary. LCS 1 per analytical batch 60 to 140 o/, for target analytes Review internal standards. Assess impact on data. Process archive sample if necess ary. Field Surrogates Every sample 70 to 130 %Check chromatogram for interference. Assess impact on data and narrate. Internal Standards Every sample 40 to I 3 5 0h for tetra through hexa isomers; 25 to 150 o/o for hepta and octa isomers. Check chromatogram for interference. Check instrument and reanalyze rf necessary. Check signal-to-noise, if < 10: 1, process archive sample. Assess impact on data and narrate. Audit Sample As Supplied 70 to 130 % Holding Time 30 Days Extraction 45 Days Analysis 2.0 PCDDs/PCDFS SAMPLING AND ANALYSIS METHODS 2.1 Summary QA/QC Criteria for Dioxins by Method 0023A/8290 Notes: The term Limit of Quantitation (LOQ) refers to the laboratory's standard Reporting Limit. RSD : Relative Standard Deviation, OCDF : Octachlorodibenzofuran, RRF : Relative Response Factor, 7oD : Percent Difference, TCDD : Tetrachlorodibenzo-p-dioxin, OCDD : Octachlorodibenzo-p-dioxin TOCDF LCPT Plan - Rev. I Appendix A December 2,2010 Annex A - 2 F M.TrcR coBRs,c,trlIffi 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% from aYg RRF (rCAL); %D of natives < 20 o/o from aYgRRF (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 analyical batch < LOQ, except for ocDD@<sxLoQ Reanalyze. Assess impact on data. LCS 1 per analyical batch 60 to I40 o/o for target analytes Review internal standards. Assess impact on data. Reextr act andlor rean alyze as necessary. MSA{SD I per ATB 60 to 140 oh recovery for target analyes; RPD S2O% 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 150 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. 2.2 Summary QA/QC Criteria for Dioxins by Method 8290 LCPT Plan - Rev. 1 Appendix A Decemb er 2,2010 TOCDF Annex A - 3 2.3 Limit of Quantitation for PCDDs/PCDFs LCPT Plan - Rev. I Appendix A Decemb er 2,2010 ii.,,i .iiii...i...ixVlmimilto.D,.ii.iiSE.9i0 ",',,,,..,,'',......(n.g/L). .,.., .,,,.......,..,...,.., 2,3,7,8-TCDF 5 0.005 r,2,3,7,8-PeCDF 25 0.025 2,3,4,7,S-PeCDF 25 0.025 r,213 14,7,S-HxCDF 25 0.025 1,2,3,6,7,S-HxCDF 25 0.025 1,2,3,7 ,8,9-HxCDF 25 0.025 2,3,4,6,7,8-HxCDF 25 0.025 1r2,3,416,7,8-HpCDF 25 0.025 1,2,3,4,7 ,8,9-HpCDF 25 0.025 OCDF 50 0.050 2,3,7,$-TCDD 5 0.005 1,2,3,7,8-PeCDD 25 0.025 L,2,3,4,7,9-HxCDD 25 0.025 1,2,3,6,7,9-HxCDD 25 0.025 1,2,3,7 ,8,9-HxCDD 25 0.025 1r2,3,4,6,7 ,8-HpCDD 2s 0.025 OCDD 50 0.0s0 TOCDF Annex A - 4 3.0 HALIDE EMISSIONS Summary QA/QC Criteria for Hydrogen Chloride and Chlorine (9057) Method Blank 1 per analyical 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 ll0 %Evaluate system. Repeat calibration check. Recalibrate. Reanalyze affected samp Ies. Preciston/ Accuracy LCS per batch 90 to ll0 %Check calculations. Reanalyze. Assess imp act on data. Narrate. MS/MSD per batch 85 to 115 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 ll0 %Check calculations. Reanalyze and Narrate. LOQ Hydrogen Chloride Chlorine 1.0 mgltraln 1.0 mgltrain Holding T'rme 28 days Note: The term LOQ refers to the laboratory's standard Reportirrg Limit. LCPT Plan - Rev. I Appendix A Decemb er 2, 2010 TOCDF Annex A - 5 4.0 METHOD 6020 ICP/MS 4.1 Summary QA/QC Criteria 1, ,., ,:, : ,,...,...,..., ..',,.,,.,..MEitl'trODll. THEQIIffiNCY::,,: Instrument Tune Daily, prior to calibration and sample analysis Mass resolution < 1.0 amu @ l0% peak height. Mass calib. + 0.1 amu Refune instrument. 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 sample s. CCV Every 10 samples and end of run sequence + l0% of expectedvalue 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 analyical batch 75 to I25 o R, RPD <25 % Check calculations. Assess impact on data. Reextract and reanalyze as necess ary. Nar:rate. MSA4SD *1 per analyical batch 75 to 125 o R, RPD <25 % Check calculations. Reanalyze. Assess impact on data Duolicate Analvses 1 oer analvtical RPD <20%Check calculations batch Reanalyze. Assess impact on data Holding Time 180 Days to analysis Note: amu - atomic mass unit ICV - Initial Calibration Verification CCV _ Continuing Calibration Verification 'F For air matrices, the QC samples per batch include a DCS only (rro MS/MSD). TOCDF LCPT Plan - Rev. I Appendix A Decemb er 2, 2010 Annex A - 6 4.2 Method 6020LOQs LCPT Plan - Rev. I Appendix A Decemb er 2,2010 Aluminum 7.5 1.0 Antimony 0.30 0.050 Arsenic 0.30 0.0s0 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. 15 0.025 Nickel 0.30 0.050 Selenium 0.45 0.050 Silver 0.1s 0.025 Thallium 0.15 0.025 Tin 1.5 0.25 Vanadium 1.5 0.25 Ztnc 0.7 5 0.12 TOCDF Annex A - 7 5.0 MERCURY ANALYSIS METHODS (7470A) Summary QA/QC Criteria SW 846 Methods 7470A, Mercury by Cold Vapor AAS LCPT Plan - Rev. I Appendix A December 2,2010 ,,,.,.,.....,...,Q.[IALff'r-,',',,,', P ETE,R',',,,, ,, 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 sample s. 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 anallrtical batch < LOQ Reanalyze. Recalibrate as necessary. Reanalyze. LCS 1 per analyical batch 80 to 120 %Check calculations. Reextract arrd reanalyze as necessary. Assess impact on data. Narrate. MSA4SD 1 per analfiical batch (20 samples). 75 to 125 %Check calculations. Evaluate LCS. Assess impact on data. Stack samples. MS on one FH fraction 1 per analytical batch 75 to 125 %Check calculations. Reanalyze. Assess impact on data. LOQ Multiple Metals Train Aqueous Samples 0.2 ytglfraction 0.0002 mslL Holding Time 14 days See Table A-7 -l Note: The term LOQ refers to the laboratory's standard Reporting Limit. TOCDF Annex A - 8 Method Blank 1 per analytical batch <LOQI Reanalyze. Assess impact on data. Narrate. Instrument Tune Every 12 hours Refer to method.Refune instrument. Repeat BFB analysis. [ritial 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 < 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 < 20 % drift Recalibrate. Reanalyze affected samples. Every 12 hours RSD<50o/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 Precision/ Accuracy LCS, MSA{SD per batch Surrogates Historical lab data (See Table 7.2) Check calculations. Reanalyze. Assess impact on data. Narrate. Holding Time 14 days 6.0 YOLATILE ORGANTC COMPOUNDS IN PROCESS SAMPLES (82608) 6.1 Summary of QC and Calibration Criterion for Method 82608 (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 rnay 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. ' Allowance for up to 6 target analytes > s}yc LCPT Plan - Rev. I Appendix A December 2,2010 TOCDF Annex A - 9 6.2 Control Limits for Process Samples by Method 8260B PHffiiGnii$itiONiiii ,..:.,':.',....i.........i......i....ffiD......".,.......i................i..i...... LCS 1 ,1-Dichloroethene 66 to 130 NA Benzene 77 to Lzl 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 l2l 2t Trichloroethene 75 to 116 24 Toluene 78 to 120 25 Tetrachloroethene 72 to 120 25 Chlorobenzene 80 to 120 20 Surrogates I,z-Dichoroethan e-d4 64 to 139 NA Toluene-d8 72 to 128 NA 4-Bromofluorobenzene 66 to l2l 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 LCPT Plan - Rev. I Appendix A Decemb er 2, 2010 TOCDF AnneX A ' 10 P#R# lfrc:R Method Blank 1 per analyical 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 < 20 OA Recalibrate. Reanalyze affected samples. Internal Standards RRT + 30 seconds Check sensitivity of system. Reanalyze standard.Accuracy 50 to 200 %R Precision/ Accuracy LCS, MSA{SD per batch Surrogates Historical lab data (See Table 8.2) Check calculations. Reanalyze. Assess data,Narrate. LOQ 0.050 mg/L to 0.25 melL Holding Time Extraction - 14 days Analysis - 40 days 7.0 SEMI.VOLATILE ORGANIC COMPOUNDS IN PROCESS SAMPLES 7.1 Summary of SVOC QC and Calibration Criterion for Method8270C 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 analyte is less than five times the LOQ. Such action must be addressed in the case narrative. LCPT Plan - Rev. 1 Appendix A Decemb er 2,2010 TOCDF Annex A - 11 or semt- v otatue urganrc uomDounos tn Aqueous Damptes ..C.QMP,OUI$D , ' : ,i.'.,9 R:::,::,::.::,l :,., : A,QUffiiOUS ILCSI 62 to 103 60 to 100 2-Chlorophenol 48 to 102 1, -Dichlorobenzene 51 to 91 2, -Dinitrotoluene 60 to 113 4-Nitrophenol 18 to 63 N-nitro s o - di -n -propyl amine 6l to 105 Pentachlorophenol 35 to 118 Phenol 16 to 56 Pyrene 47 to 126 1,2,4 -T ri chl orob enzene 57 to 97 'l .2 Historical Control Limits for Method 8270C for Semi-Volatile Orsanic Comnounds in Aqueous Sampl MS/MSD Acenaphthene 59 to 103 15 4 -Chloro-3 -methylphenol 60 to 100 26 2-Chlorophenol 48 to 102 34 1 ,4-Dichlorobenzene 51 to 91 29 2, -Dinitrotoluene 60 to 113 26 4-Nitrophenol 18 to 63 67 N-nitro s o - di -n -propyl amlne 6r to 105 26 Pentachlorophenol 35 to 118 39 Phenol 16 to 56 7l Pyrene 47 to 126 36 1,2,4 -T ri chl orob enzene 57 to 97 27 Surrogates 2-Chlorophenol-d+25 to 101 NA 1,2 -D ichl orob enzen e - da 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-dr+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-8a6 (l). LCPT Plan - Rev. I Appendix A Decemb er 2,2010 TOCDF Annex A - 12 8.0 METHOD TE-LOP-557 ICP/MS DQOs Clr,,,fterie Instrument Tune Daily, prior to calibration and sample analysis Mass resolution < 1 .0 amu @ l0% peak height. Mass calib. + 0.1 amu Refune instrument. Repeat tune solution and analysis. Initial Calibration Blank and at least one standard. ICV + 10 % of expected value Evaluate and reanalyze ICV. Recalibrate. Calibration Blank After ICV and CCV < PQL 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 analyical batch < PQL Reanalyze. Recalibrate as necessary. lnternal Standard Each sample 70-130 % Recovery Reanalyze andl or narrate . LCS 1 per analyical batch 75 % to 125 % Recovery; RPD <25 % Check calculations. Assess impact on data. Re-extract and reanalyze as necessary. Narrate. MSAdSD 1 set per analyical batch As, Cd, Cr, Hg: 75-125 %R; RPD <25 %; Other elements: 50-150 %R; RPD < 50% Assess impact on data. Narrate Duplicate Analyses 1 per analytical batch RPD <25 % Check calculations. Reanalyze. Assess impact on data Holding Time NA 180 days to analysis Contact client. Note: amu - atomic mass unit ICV - Initial Calibration Verification CCV _ Continuing Calibration Verification LCPT Plan - Rev. I Appendix A December 2,2010 TOCDF Annex A - 13 9.0 REFERENCES (1) Test Methods for Evaluating Solid ll/aste, Physical/Chemical Methods,3'd Edition including Update IV, USEPA, SW-846, February 2007. (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 QAIR-5, November 1999. (5) Handbook: Quality Assurance/Quality Control (QA/QC) Proceduresfor Hazardous Wast e I n cin eratio n, EP N 625 I 6 -89 I 023, January 1 990. LCPT Plan - Rev. I Appendix A Decemb er 2, 2010 TOCDF Annex A - 14 o o o LEWISITE COMPREHENSIVE PERFORMANCE TEST PLAN FOR THE ARE,A 10 LIQUID INCINERATOR APPENDIX A ANNE,X B EXAMPLE DATA FORMS REVISION 1 December 2r 2010 TABLE OF CONTENTS Chain of Custody Record...... .Annex B-1 Method 5l26FieldData Sheets................ Annex B-2 Method 29 Field Data Sheets................ ...Annex B-4 Method 0023A Field Data Sheets ............Annex 8-6 URS Source Sampling Temperature Readout Calibration Form......... ..........Annex B-8 Five-Point Dry Gas Meter Calibration Form......... ....Annex B-9 Three-Point Dry Gas Meter Calibration Form......... Annex B-10 VOST Console DGM & Thermocouple Calibration Form......... .................Annex B-11 S-Type Pitot Tube Inspection Sheet ......Annex B-12 Pitot Tube Calibration Data Sheet .........Annex B-13 Potable Barometer Calibration Data Sheet ..............Annex B-14 Balance Calibration ..............Annex B-15 Field Balance Calibration............ ..........Annex B-16 URS CEMS Operation Log .Annex B-17 LDT Plan - Rev. I Appendix A Decemb er 2,2010 TOCDF Annex B-r ffio Chain of Gustody Record Samples from Multi-fVletals Sa[plinq Tralns Page of _ Project (os€ !3 ? U) =+oL' C\l =6-rE(tr.Co(u == (ot6* U) I as E.F bo =o0() -c,(I)(l) =E 'o o- o cn =U) = t-(l) -oE z. (l) C, (tt EoO ct .Eo-.g a Comments site TocDF Project Number Prepared by Sample lD Code Sample Matrix Date/Time Remarks: Provide results in total micrograms per sample. Raw data pac the following metals: Al, Sb, As, Ba, Be, B, Cd, Cr, Co, Cu, Pb, Mn, Hg, N kage required. Samples will be analyzed fro i, P, Se, Ag, Tl, Sn, V, andZn. Relinquished by:Date Time Relinquished by:Date Time Relinquished by:Date Time Received by:Date Time Received by:Date Time Received by:Date Time Relinquished by:Date Time Relinquished by:Date Time Relinquished by:Date Time Received by:Date Time Received by:Date Time Received by:Date Time Annex B - 1 LDT Plan, Rev. 1, Appendix A sample Type - PM/HCI/CIz (Methods 5/0050) Plant Narne - TOCDF Sampling Train Leak Rate (ft3 @ in, Hg) Location (Source) - MPF Nozzle Dia (in)Pitot Tube lD Pitot Tube Leak CheckDuct Dimension(s) lnitialElevation (relative to Barometer) (ft) Bar. Press. (in. Hg) Nozzle Calib,Stat. Press. (in. HeO) Dry Gas Vol, (fts)Temperature (' E $ g $ i* g .E H E E f : IE * E$ $ i t I Et Es H HE t E n E :E *. t f c€ l r o. E _. F . Ug E, g S E (D a r* E= u Hx gi s !: a e F : E? e gg :E S ; ia t e E ;+ E #E H$ g ,s # f I 5E =[ i EE {E E }B E { Q- (D , a , O *. a E* E gg E i E a f i ; : g g g I g l g g o) x+fS> r gP t 5, 8 EI<I zt -g .J'l - )o-o*bA bI ) O{ t r o' A {- . ir tr t r gE8tHE a* ) .= aB. E ae6 .H F r. . , ,8E .- l- l .' d f}(l ) @E9Nt s 9' r l" Q) 'o ( u ) HE 3e .O .= L-A. L ,E e ac n=c5E 'f i |Eq l Li ?. G Er - oo AV , /tl- . l- { '& '& ci l- .L.o9q , l< -? l. ' r Rl 5c oztrd ztOI Hl3lol FI I -l<t .a r ) 0oE-'} ( (/oa-ULooCJ€) tC) -a-ITH6€a-,xo .I l*.6l rlx.--IILo-| . .€)Rq)Lrla,+.a .l o\=a Sh .S!a sEI s* ss .s \o N$ t\h\% UUtdEF{ a0oI]o-g-L)rcBa adcl-oCd l<()ro ozoC) 'al<o< Eo .! | tr )g .l LcJaOR q)U) .EE(l )NNoz-oc(E(l ) -ooo- o)=1r - .C ,o(U (JL.o)o, .Eo-E'r c '6 (J(oo(l ) t)C'aqo.=El( ? ts i. . E d ES zg E U LoEErl-zRF{6) -aE6ta E. z.o-I r( )=I,l JEU)! lro-=I IJ LoOoF a=lJ - I lr )=I I I -vCD I IIo-=I lJ -o()oF o-E-( , ()Iorr )OO=,l .YCN I ll -o_=I LLoooF CLE .S C Iorf ,ooa I I -Y(/ ) I lJ -o-=I ]J -oooF -L'erhvb l *) \7 q)z ilE3 .- , Y 't s +i EB I /^ =' b r =\ , .= .: fE { Bl II II II lt ! I il !tq)E'6(9(l ) z. (goF 6l lidr = r= .9 =+ . oU o:< ct ) (, ct ) (9 Eo= Eo= E'o= q)EG !, F{ -- -l r-o 5 a olr ) oo Oo oo oo o) ooCAt ai,dho+, t-HoU <,oU)GI -z.o <toc/ )6t J-z.-o -1 .oct )C\ I -z. r.o .J -o(oz.z.=.o :t ro(t r z.z.-C; E(9Ct roch Q- l t! t- , EZ CN cf ) .< f rr ) (o An n e x B - 3 LD T Pl a n , Re v . l, Ap p e n d i x A Sample Type - Multi Metals (Method 29)Start Time Condition Page of Plant Name - TOCDF End Time Run Sampling Train Leak Rate (ft3 @ in. Hg) Project Number -Duration (min)0perator lnitial @ Date PTCF Nozzle lD Final @ Location (Source) - MPF DGMCF Nozzle Dia (in)Pitot Tube lD Duct Dimension(s)Console No,Kf Pitot Tube Leak Check Elevation (relative to Barometer) (ft)AH@ lnitial (*)(-) Nozzle Calib. Bar. Press. (in. Hg)Final (*)(.) Stat, Press. (ln. HzO)Filter No. Point Clock Time Dry Gas Vol. (ft3)AP (in. HzO) AH (in. HzO) Temperature ("F)Vacuum (in. Hs)Stack Probe Filter lmp Exit DGM ln DGM Out I I Comments: Annex B - 4 LDT Plan, Rev. 1, Appendix A E i' a; E g = ,* fu [ ;* s # ,; H 'E - *- ' ' g g g g i i g E l g l i i E EE i E E g g E i E E i E{ $E €i t r E ; IE i * g g e s c a * e a i E E r a a i gB Eg i g; Eg E E $ , EE EE g , gE i g EIolEI tr IslZI 0) .1 4Es -o I= &s ii zoo u. !) tr c .d .- 'o E .E .- () o c€ ru .9 .g ET J .- .i . r tr t r zz Fl OO -t r -t r H5 ' a- .t FB Ou ) E9NE9' E l< c) E( u ) l. l LE? . € oU o) IE .E l- . O - O. - l r ,t r 8 e A- . A t{ \+ . { xs F .. l J X E9 : d i Y t< ) ( < cd , :i 5 9. ! g -{ r l - L. 7\ l- r .t lJ .l ez & zo|- {HUoFl tr .F au2 OI-v tr l oq) t -lUL€)o(Jq) ilc) -a gaa4xG0 oHtrot, -a a Eg8A oztr&,2 R -$\6) S =s4E .i EE\ AHo .I l+)EBa- .E l aIxLo) {. )()aoL--*ia .l o le la u, cdtr l- { Lo{- JCB l<(l )ao o7, {. . r () (l ) 'aLA{ tro .F (*. )g .E . liCJ00)a I t-(l )g)c 'd - E.o.=z. mIo)g) 'aE(J .=z. (t ) (t rcNo)E(UE(I ) o- (Dt7 ) C,o_E(l ) (gC(U(: r ) C(sEc) o- E f. . E -: t r g t !, E + f z. E EU Lq)EE--zal- i o-aEG0 =LL Io, c\ l=I I I -Ycn+oFCN I LLoC)oF 1z.!o,GI,t .Ycnt(fFCJ ) I LLoooF d. tr I cr , c\ l=I I txaI t-oFU)t lJ -o()oF Eq) o-Io) GT=t,l 16U)IFaFU)a tl -c)ooF U'CG.--Io)GJ=,l 14aI t- -oFU)a LLoooF -H.-6l fA /^ vh t tr \z (DZ ll a +f="G .I Y+, .l -,HF{ I +aF A -l '\ r Ee .aFr { il I II n il il il II il(n '6(,q) z.EoF -l-a0 t r rE .9 Eqog s Ut s o\c Eo= cr ) (D E'o= -oo= 'oo= Eo= q)Ec i )r l ar - -l L AL -v \z a OO oos. oO o<>- g,oocr ) I rr l {. atL.q) .l iFIoU (l ) -C 'xo(l ) o*o.E=z, q)E)<oq. ) o_o.=z. cEct ) -foE=)< E6U) -foc=\< (t ) (9(I , .o6 q- : at LEZ C\ I (f ) !{ . lf ) (o F- . LD T Pl a n , Re v . 1, Ap p e n d i x A An n e x B - 5 Sample Type - PCDD/PCDF (Method 0023A)Start Time Condition I Page of Plant Name - TOCDF End Time Run Sampling Train Leak Rate (ft3 @ in. Hg) Projec{ Number -Duration (min)Operator lnitial @ Date PTCF Nozzle lD Final @ Location (Source) - MPF DGMCF Nozzle Dia (in)Pitot Tube lD Duct Dimension(s)Console No.Kf Pitot Tube Leak Check Stack Elevation (relative to Barometer)AH@ Initial (.)(, Nozzle Calib. Bar. Press. (in. Hg)Final (.)(-) Stat. Press. (in, HzO) | Filter No Point Clock Time Dry Gas Vol. (ftr)AP (in. HzO) AH (in. HeO) Temperature ('F)Vacuum (in. Hs)Stack Probe Filter Ht Trc Exit MD lnlet lmp Exit DGM ln DGM Out Comments: Annex B - 6 LDT Plan, Rev. l, Appendix A 6 A E H9 g E EE xa t s EO PH FH EE E T E 'E E S' B ae g . g a Bs en $E E b '- -; = -q E S) g $ TE EE E; q E c e5 q il E = * E E f r = a z o) <l r ' . " = bH E .= E E ?E fi n l E# 6 H gi g * B * E E g E E E * !s -z EE E ;e i €f . i B tE * EE ; Es g *g f ,E Ig i Ei B E$ : *E E B F= E .l , f i E #' a ' i -* o E qo u) ' o v) E HE Ei .E - H E# E S ilcE' l&ctrFIz o).P g .. l o q> { - -hEE .E OE ' . = 56 I u ct = zP f Td '- €E I €H E .= ( l ) - o> > . 9o i HE EE - Cg ^J l rc E -. = E- E} . Eg il E == EP 9* , 'E b ag Ei T H EE A? l . EE T T s Z g u = EE 3 E; :u 'j 5 O -. r tl f E $E Ei '& € ' i E€ zo-E{UcFl Fr +)0.- -l.t (oO--UliooO€) ilo-gEcsa dtrtro .t l+)EE i' ) Gt Oa cjzn V 2 .r ; h. GI rt s LS I- rf i tr t s ,t O t ES ar a I .= \o 5+5t a0oJ() -q-T!-Ga aEIo .- l {r )G-ts .-aH-L(D+joa€)L-l-+ia.-ot{a (r , cd {- , L. l- { l. <o+. 1ct f- .C)ao ozo(. )o' lr tr { Eo .J CL Lt3t t (Dcl (I ) cnCE, (1 )NNoz.Ec(Ec) -c roL-o_ o)=LL (I )a.EE. (l )ac(u '( , Lo() * t E. E EE E q) l-(1 , .c lEJ=e6'CLE(EC" t.z.o-!CAGI oo=I,l .YU)t lJ - o-=I lJ -o()oF t- .iT I cr ) (\ l oo=I,l .YCN ! lJ - o-=I LLoooF E,C)I (y )GIoo=I,l .YCJ ) ! lJ -o-=I lro(Jot- oxI (i )GIoo=,t -. YU)I ll -o-=t LLoOoF EDE(E(,+,o=trE) -,=E{l J E!E' ) -=Ecl, t - il I il I t! I il I 1t t lt I IItr tc'6(oaJ(l , z,-.E {- ,oF E' . E ?€6g () = oP ct ) (9 Eo= Eo= oE- i og oo oo C' ) oocf )I U' r, } . , Eo, {Jgo(J ost - oC\- (l ) (9(t r .s 2 cn Lc)qr . EO 'a - = E r (\ t co .+ l. o (o LD T Pl a n , Re v . 1, Ap p e n d i x A An n e x B - 7 Operator Date URS Source Sampling Temperature Readout Galibration Form Per Reference Readout ID Number Thermometer lD Number Voltage Generator ID Number Temperature Readout Galibration Thermometer ('F) | Temperature Readout ("F) (after adjustment) Acceptable difference is +5oF for temperatures below 1000'F and t10"F for temperatures Temperature Readout Calibration Check Channel Voltage (mv) Temperature ("F)Channel Voltage (mv) Temperature ("F) Theoretical 0bserved Differencet Theoretical Observed Difference 1 0.0 32 5 -1 .0 -10 1.0 77 0.0 32 3.0 165 1.0 77 7.0 341 2,0 121 15.0 692 3,0 165 2 0.0 32 6 -1.0 -10 3.0 165 0.0 32 4.0 208 1.0 77 5.0 251 2.0 121 7.0 341 3.0 165 3 0.0 32 7 -1.0 -10 3.0 165 0,0 32 4.0 208 1.0 77 5.0 251 2.0 121 7.4 341 3,0 165 4 -1,0 -10 0.0 32 1.0 77 2.0 121 3.0 165 above 1000"F.Annex B - 8 LDT Plan, Rev. 1, Appendix A \SSs\\Saaq) \lEat\S .H.3tiqJ r( Ell ttr3dLOEIJdEIfsEIJd, IfF-IJdE(Y l ?-I-i, (Y l tr=c,oNa-EIJ&,Na--=dEFI ?-IJd7{tr IdI Co(oUl - (E o) '{ = -O c9o= - J r- , - r- { L f-o+) (\ ) (ULL \z ,A rE\/gl .EE' (o(ud, (o a-*) .E1- l=(9o &\/Ul .E 'o(Eod.CI Lit r=(9o (o lF ) .Et{+,IEH EL) '=HP(u *- J=o Ecit r+, 0?C l- l EcIIo1- , Jo lno) {- ,=l .EEoEtr*, (/ ) (I JF oN-It< * , Tt-ol- toEoCo=o(J tt s .Eo AOt I,ol-)av,ol-o- (J l-+)oEol-(o6 ILo\- . / (u l-f+) (o l-(uo-Eo. )F+- JC,9-oE ql I'< - E==U(go-E=o- (f o ) ar n J e r a d u a l af l J l r o tm l l u f , lr , l 9 ) o pa [ q n s c, l-=+- , fi ,cOt taq. , +, ) (1 ]o 7a--troLtro rIP, ^ !E o. L rl SI != .r th E' 5 rIEn gvOE I II =. Ir UI G) ,$ l R \7 t r F' g ES '6rd, .=IL otr lc)olnCoL) V,o{- ,oz LD T Pl a n , Re v . 1, Ap p e n d i x A An n e x B - 9 \SSS\\SaaBbBao\S .H.k-q) F( oGI t-b=d A->eoEoc1--G? I- Iotrov^F t- LlEo?-,- T*, -itoE'ool-o?r-*,J(Josr-L} oz. (uCI-fi I f(J LLo\- / G) ()Co) t-(u (Lq- i5 fY t tr=d ]Lo\- / T' (t )too-oo 6Ntr--d oHo-o-)aocD (o llo IJ - o\- / -(oUJ- )of-o(I . ) .CF c{ rf ) NN lf ) (o !- l FI trY ) c{Ol \o N?-5d E\- /ocr ) (o at - ,o o "- { (n r\ lf t F{ EF{tr rJd FoHzG+JUt l--r lr r ls gl BE YE=o ot r E' i GO o. E LFoF-+, Jt,os-(J oHl-(u+,oEoEf-o.CFhr- lz LLo\- / (r t .EE(Uod. f-o+t (uEoEl-0, l-F ^ILo\- / (r l .E-c , (I , c) d, ,. t )JoE(ood FI F--Jd ?l -x0 l .= . r +r F8= J tr - -r , jt z' coEH L.o.l - JU(gTLV Arn J- t rL\- / tr DCE(ood, -(o ,EEHE(,o c3 - , IL g) .EE(o(I ) d, (t , L- tt r=(9o -( u a-+,E t- { oEH ?s a-t,.E l- l+) (u-+)=o (oc a-u- {- ,oC !- l (ocit r .1 - ' (u+t=o gg e g e =J - . ;, ; ' < - ' E ' < - .E Y E E E \/ = = ( t r = E; f r t s H ,f r P E P P P E E u* F E F, g C L = 6€ OE E .Eo (r " ) aJ n l u a d u u a l ac u F o Ie f , ! l ! r 3 H9 q pa [ q n s uo l l e r q ! l e f , rn o p e a u ?# F F f . ? l # P l , Ap uo n e r q l l e 3 ht 9 o An n e x B - 10 rd l-) ,, \ EOP (J E ) lI ri tl - A II LOr IIlt r I 9l rr lPI rr ll- I rJ l +. I Ia l EI rr lGI EI -. ' V( t r a El-o]Ltr .9Plt rLett r ILo+,oG(9Lo*);-'6Etool-F Il- oHooaCoL) di x A sSr\bsh\qc\qE$S *, .EooEJJoE(UotrE:, (E f-oo-EoF. LL oo-EoF1'oEoo-c loLL oo-EoFEo.; ,ol-ooF CNar ) l' - f- l. r ) (or r$cf ) No) (o go .I+, IEL.E t t--tUo-gEL=o(,oELoF-F o.>a.o-=U)ocn (U=oel-o*,q)EoEo.c , t- oU)o=o o (f ) F- lr ) ozEco(J o(U l-)o(J +t=oE' (( ,oE. (l ) t--, +t(U l-o)o.EoF +.=ot$otot-5ea - , (Ut-oa.EoF- LL oEJ+J(or-oo.EoFc;zoc$o o)EE' (Uou.bn oL , EoEt-o-cF tro .I+,c,L ,. c t IE-TEo=oo ot-=oc.9@l-oGl-oo-o (1 ,$o eooU'oo o+. ,otr3oLLoolFt-oG.EEoz FHELofE-, Io r-{r )GILE.- l -l clUq) -a,l)oc)o-Lr IL€)arr r lH€\-a(,RC) -oU)--oUHao (atr-JtrC\ tr-.Jt,r.tr=u Lo-oE=ze l-oo(U I. L\( GE ot- iL (U-,=+, -9c (u *1 .Eo:fo $.ctL+,ql (EciEoJo o(\ t I=E=ottoL. (LL-oyq)= tr ) Ti. -Efo(uCLE:,o- cr ) T(! .c I o- lro co) IlEoF I- .Ec.9+,E=o*t.ho) 1- JE ILo ooEF co OE = o( U IF E6E -c ED . . . .l = O .g E =€88 oE yoo' F .o E l- c oo LD T Pl a n , Re v . 1, Ap p e n d i x A An n e x B - 1l Inspector: S-Type Pitot Tube Inspection Sheet Date:Pitot ID: General Pitot Tube Alignment End View Side View Longitudinal TuEc fuds - A i_l A-Side Plane A- Dt= 0.188" S D, < 0.375"? (y/n) 1.05 s +. < 1.50? (y/n) 2D, Misalignment o1H tl 'o1 a2HH t:tltl \l 0l:or S 10o? az a l0o? (y/n) Az:(y/n) ./ Lnneitudinal\ TUFAF F,: Fz: 9r S 5"? 9z < 5"? (y/n) (y/n) y:_ 0- Z-Atan(y):_ W-Atan(0):- Z < 0.125"? (y/n) W < 0.03 1"? (y/n) Acceptability for Use (Circle Selection) If all answers are "|", this pitot tube is available for use, and could be assigned a correction factor of 0.84 lf all answers except the first (Dt) are "y", this pitot tube is available for use, but needs to be calibrated using a wind tunnel. Any other situation, the pitot tube must be removed from service. Annex B - 12 LDT Plan, Rev. 1, Appendix A Pitot Tube Identification Number: Calibrated by: Pitot Tube Calibration Data Sheet Date: c p(,) - cp(std)*.W cp(std):0.99 Var, 3 Average Deviation : o(u or b) : I ffu i=l Difference - I nr.rage Cplr;, - Average Cp(s)b 1 C p(r)t Must be <0.01 Must be <0.01 Run No. (( L" Side Calibration Deviation Cp(') - Avg CoAPr16 (in, water) AP' (in. water) Cp(s) 1 2 3 Average Cp(s) (Side A) Run No. 6(El" Side Catibration Deviation Cp(.) - Avg C,APrto (in. water) AP' (in. water) Cp(r) 1 2 3 AveraBe Cp(') (Side B) Annex B - 13 LDT Plan, Rev. 1, Appendix A o 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 - 14 LDT Plan, Rev. 1, Appendix A o BaTANCE CAUBRATION Balance ID Date lnitial Galibration Calibration Weight Operator tD#Mass Linearity Gheck Calibration Weight Balance Reading Acceptable RangeID#Mass 100 99.9 - 1 00.1 240 199.8 - 200.2 500 499.5 - 500.5 1 000 999 - 1001 Galibration of Student Weights Student Weight Set lD Galibration Weight Balance Reading Annex B - 15 LDT Plan, Rev. 1, Appendix A FmLD BaTANCE CaUBRATION 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 Differ"n." - balance reading - actual mass , , oo actual mass Sensitivity Gheck" " 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: o/o of secondary weight - Balance reading B -Balance.Reading A *.,00 Secondary Weight Galibration Gheck of Balance Using Student Weights Student Weight Set lD Student Galibration Weight' Actual Mass (from Annual Calibration) Balance Reading Difference Percent Difference b Primary Weight (1000 g Class 1 Calibration Weight) Balance Reading A Secondary Weight (1 g Class 1 Calibration Weight) Balance Reading B Balance Reading of Secondary Weight (Balance Reading B - Balance Readinq A) o/o ol 'fi,Tlfllfl Annex B - lb LDT Plan, Rev. 1, Appendix A URS GEMS Operation Log Time Activity Analyzer Response Project Page of Project Number Operator Source Date LDT Plan, Rev. 1, Appendix A Aoc, i. r , '=v(U -yo (o=otlr )=oJ.$=o (f ) =o-sl=oo- as cr )+t -E o) -c c=E or I e= qt E G' O- g) ' . . EO (I ) C , H8 - 6s cD o oc(ECLU'oas (r )#s ) .s .g -c E =( U=ERq cr fi e' = 6E N- r A 2; (, ) (g c, _Y ' . E O: E vEo tI Lo.=Lo c(sCL aDo:socon.EC,o'6.9 ,ELU G(oo- aoEsoo=oE€a(s=(E6Q)cotl , .t tEtu -' ! = .Ec.9(r , .9E(l ) (l )U' o)Eu?6I IqE(Uo- ct ) (l )q) E' (l ) () (l )o.xo)U)o)Eu? (\ l I '( ? F(I ,o- ct ) .Eg.9cl ) .c f ,Eo)oC= (uo-aobsooaoOEE(uESoqolq f (t ) (Uo)o(Joeo- C. (D(r , o.=Cq) rogo)o(l )N C, (uo- {,oEsO(r )o@EC, rt , bs lr ) r( ) u5sslr ) (f ) I tr )C\U) (r Jg)6()oeo- c) p(t r l-o)oo)N c(6o- C"o;sGI+t .s '=ct (so)E(Eo- U) c(uo- q,o;gGI+t .E .. E '=CI ' $,o, (l )o)cgtp= cCoo-U'o;s6l+t '=CN (uoto(l )N (l )6E(t )E(l )ooaSrf ) .c '=U' (oo) (l )o) c(t r a=o Q)=(E 't ,(l ) ', E ; (l ) (Jo.str ) .E :! ==.D(6(r ) o) tr Dc(E Ip= o)=(! 't ,(l )E(l ) (Jo:sr. f ) .g '=ctog)=No- U) I_o(! -o(uq)q,==E'o) .C-o(EEEsK)+tC'=a(o(r ) Eo) ()o) = u) ( l ) (u -o(( , .9o-o-oz. (r ,=. .9Eo.oc(!o-ooEs (Y )#.E '=tr DC,€ruo)U' (u(J ) E'oo ) (J -= (l ) . l C Eq cy e - [ L U' .E-( ,Co (l ) CN .oEa-oCNo-U'o>s (e+lc='=@(!tr )eC) N a=oq)o-oc(I lo-aoESco+l .E-c . '=g)EE(t ,o)U' (I ' (r ) p(l ) ct ) o. = (l ) 1 C 7i ( E 6E o) .go(oo)o=.9o)o.oC, (\ lo- cnobs (f ) +l='=aCUer )eoN !,o?-{- , (l ,= tJ - i Nr 4 dc a (o tr ) C\ I LU f\ < ci ' c o (o tr )c! df: 4 d" c a (o rI ) c! tu - l' - < d' c D (o lr , (\ J 'I I f: .4 c' o o (o lr ) c\ l .E.z+,o o(Jq)o) cnC(t ra- U) TDCU (,cOCE€E8 (E E () a o]Uco(u€(I , () o(t l i5o) ? i ?6 i 5 >t -C CN C) oe vt .= or - l- - lY -s J- o () A ,: , q) O (U - E o- o ( J .A.atr0(u?NEV.. I(,o?-(,+, hII LoI LIJo IrL oJ(,os(Jo(, trGELotorEo?-*.oE l-o-c lEl-3z-tI , .EooL 6E !r =OE=zLoL={r ,oTE lF JE(r=o+r .>ct F- h--(. ) L .F o xr r xf lEE so -t r 3h EI I c6 # -t r t - tr Lgo ;E6r tna. s I Eo .E E E= tr L o#HO .x F -O I tr I eLot,tr II-oAo \7 tro .I{. ,GL- *rtrootrooAo\/ +aEotroCLEoo ooolr (! , tro II*. IELf, I IE(, rFooC' ) c, o- Lo{r atrt-oo.o o+,Go +roo !q ol-o- Lo.c rE5z{J oorqol-o- oC' L=oo LD T Pl a n , Re v . 1, Ap p e n d i x A An n e x B - 18 LEWISITE COMPREHENSIVE PERFORMANCE TEST PLAN FOR THE ARE,A 10 LIQUID INCINE,RATOR APPE,NDIX A ANNEX C RESUMES OF KEY INDIVIDUALS RE\TISION 1 December 21 2010 TABLE OF CONTENTS URS CORPORATION KEY PERSONNEL RESUMES. ............ANNBX C-l TESTAMERICA KEY PERSONNEL RESUMES.................. ....AI\NEX C-8 LCPT Plan - Rev I Appendix A Decemb er 2,2010 URS CORPORATION KEY PERSONNEL RESUMES Michael Fuchs Eugene Youngenn?fl, 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 Soflrauser o rocDF LCPT Plan - Rev. I Appendix A Decemb er 2, 2010Annex C-l URS CORPORATION KEY PERSONNEL RESUMES 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) forhazardous 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 charucteization 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. Youngerman 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 characteize processes or pollution control devices. Mr. Weber has a Bachelor's degree in Biolo gy, from Vanderbilt University at Nashville, Tennessee. TOCDF LCPT Plan - Rev. I Appendix A December 2,2010AnnexC-Z 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 primarily focusing on technical and measurement support of projects chaxacteizing 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 confrol 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. LCPT Plan - Rev. I Appendix A December 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. ln 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 burn 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, Ml5, Ml6). 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 l7-year career. As a Senior Scientist, he has managed projects, supervised field teams, analyzed/ 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. LCPT Plan - Rev. I Appendix A Decemb er 2,201 0 TOCDF AnnexC-4 ROBERT V. WOYTEK Technician/Laboratory Manager/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. Woytek 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. DA\TID P. MAXWELL Senior Project Chemist Mr. David Maxwell is an analyical 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. LCPT Plan - 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 characteization to comprehensive performance tests and trial bums. 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 wide range 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. LCPT Plan - Rev. I Appendix A Decemb er 2, 2010 TOCDF Annex C-6 CRAWFORD DANIEL CURRIN Chemist Mr. Crawford Daniel Currin has more than2 years in emissions sampling and anallical 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. Currin 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. With 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. LCPT Plan - Rev. I Annexc-7 o...,ffiTi6$ TOCDF TESTAMERICA KEY PERSONNEL RESUMES Robert Hrabak Karla S. Buechler Douglas Weir Steven D. Rogers David Allameh Robert Weidenfeld Kirby Garret Michael Flournoy LCPT Plan - Rev. I Appendix A December 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 followthrough on day-to-day operations in all departments. These day-to-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 orgarizational 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 lVlanager 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 GCA{S, 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, C,anada. LCPT Plan - Rev. I 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 Manage 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 data meeting 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 ysars 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, IJmatilla, 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 Ga:rett 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 with other areas on capacity. In addition, he identifies priorities for new work as it is received, LCPT Plan - Rev. I Appendix A Decemb er 2, 2010 TOCDF Annex C-10 and develops and implements new technology and upgades 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 chromatography/mass 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. Flournoy 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 83308; 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. LCPT Plan - Rev. I Annex C-11 ,...,rt1lTi6$ TOCDF o o o LEWISITE, CPT FORTHE AREA 10 LIQUID INCINE,RATOR APPENDIX B ATLIC SHAKE,DOWN PLAN REVISION 1 December 21 2010 TABLE OF CONTENITS ATLIC LCPT - Rev. 1 Appendix B Decemb er 2, 2010 TOCDF 1.0 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 a part 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 itockpile. The TOCDF incinerator will complete the processing of the DCD mustard stockpile in mid to late 2011. EG&G also will operate the Area 10 Liquid Incinerator (ATLIC), which is located within the DCD chemical munitions 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 10 TCs of Lewisite, and the up to 10 TCs referred to a "Transparency" TCs, some of which previously contained Lewisite. The ATLIC Shakedown Period will begin after approvals for the CPT Plan are received from the State of Utah, Department of Environmental Quality (DEQ), Division of Solid andHazardous Waste (DSHW) and Division of Air Quality (DAO. The wastes that will be processed during the Shakedown Period are Lewisite and spent decontamination solution (spent decon) comprised of a sodium hydroxide solution and Lewisite ton container (TC) water rinses. 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, leading to a high-energy venturi scrubber, moisture separator, exhaust gas re-heater, baghouse, fixed-bed carbon filter, and finally, an induced draft (ID) fan. By the time the ATLIC is ready to begin processing Lewisite, a Surrogate Trial Burn (STB) will have been successfully completed. Therefore, the incinerator will have demonstrated its ability to process Principle Organic Hazardous Constituents (POHCs) more difficult to destroy then those contained in Lewisite. The ATLIC Lewisite Comprehensive Performance Test (LCPT) is being conducted to demonstrate the ability of the incinerator to control the arsenic and mercury emissions resulting from the incineration of Lewisite. Lewisite contains much higher concentrations of these metals and ash than the waste feeds that the ATLIC will have previously incinerated. ATLIC LCPT Plan - Rev. 1 Appendix B Decemb er 2, 201 0 TOCDF B-1 Therefore, the objectives of the ATLIC LCPT Shakedown are to: Demonstrate that the ATLIC can successfully control ash, arsenic and mercury emissions to an exhaust gas concentration less than the federal and state hazardous waste incinerator performance standards while processing Lewisite. This will be accomplished by performing a Mini-Burn during the shakedown period when exhaust samples willbe taken andanalyzed for metals. Familiarize the operators with the actions and process steps necessary to process Lewisite. The most notable process steps that are different between Lewisite processing and GA processing are 1) Lewisite is transferred from the TC to a storage tank before being fed to the ATLIC while GA is fed directly from the TC to the incinerator, and2) emptied Lewisite TCs are rinsed out with 3 Molar (lV[) nitric acid while GA TCs are rinsed with 18 % sodium hydroxide solution. Evaluate the ATLIC operating conditions relative to regulated ATLIC Operating Parameter Limits (OPLs) and waste feed rates. Evaluate the impact on the PCC and SCC while simultaneously processing Lewisite and spent decon). ATLIC LCPT Plan - Rev. 1 Appendix B Decemb er 2,201 0 TOCDF B-2 O 2.0 PREPARATORY ACTIVITIES The ATLIC will only process Agent GA, Lewisite, and Transparency TCs. There are 4 GA TCs, 10 Lewisite TCs, and up to 10 Transparency TCs; the Transparency TCs are empty and do not contain any liquids or solids. In addition, the ATLIC agent campaigns will be short compared to 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, and operators execute the procedures while 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 GA and Lewisite agent monitoring system and associated procedures will be included in the ORR. The ORR findings associated with the agent monitoring systems may not necessarily be closed prior to the start of hazardous waste operations associated with feeding the Surrogate Cocktail to the ATLIC; however, findings associated with a specific chemical agent willbe closed prior to processing that agent. The Lewisite ORR will include evaluations of only those aspects of Lewisite processing that are different from GA processing, since common aspects between GA and Lewisite processing will have been evaluated during the initial ORR. Appendix B December 2,2010 TOCDF ATLIC LCPT Plan - Rev. 1 i O 3.0 GENERAL sHAKEDowNACTrvrrrES The DSHW will be provided with a 2-week notice before Lewisite feed begins. The duration and quantity of waste feed allowed during the ATLIC LCPT Shakedown Period is specified in Module VI of the TOCDF RCRA Permit and is 144 hours and 7,500lb of Lewisite or the volume of three TCs, whichever is less. By the time the ATLIC is ready to process Lewisite, it will have already undergone the STB Shakedown Period and associated STB, and processed the four Agent GA ton containers. The TOCDF may request final modifications to the ATLIC LCPT Plan based on Shakedown Period operational experience. Any changes to the test plan will be coordinated with DAQ and DSHW. Collsction and analysis of samples during the shakedown period will follow the Waste Analysis Plan. ATLIC LCPT Plan - Rev. 1 Appendix B Decemb er 2,201 0 TOCDF B-4 O 4.0 ATLrc LCpr sHAKEDowN ACTIvITIES Lewisite feed to the ATLIC Primary Combustion.Chamber (PCC) will be incrementally ramped-up, with each increment being a greatt percentage of the approved LCPT Plan feed rate limit. At each feed increment, 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 Operating Parameter Limit (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 willbe made and an evaluation of the affects of the adjustments made willbe performed before the feed increment is increased again. The Lewisite feed rate to the ATLIC will be increased in this manner until the maximum feed rate 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 Lewisite waste feed, the pertinent regulated Operating Parameters are: . PCC Exhaust Gas Temperature; . SCC Exhaust Gas Temperature; . Packed Bed Scrubber Solution pH; . Venturi Scrubber Differential Pressure; . Exhaust Gas Flow Rate; . Exhaust Gas CO Concentration; and . Exhaust Gas Oz Concentration. In addition to those listed above, during times when metal spikes or spiking solutions are fed with the Surrogate, the pertinent regulated Operating Parameters are: . Pre-Baghouse Exhaust Gas Temperature; . Baghouse Differential Pressure; and . Fixed Bed Carbon Filter Differential Pressure. Once the maximum sustainable Lewisite feed rate has been determined and demonstrated, the same procedure will be used to determine the maximum sustainable spent decon feed rate. Note that TOCDF intends to simultaneously feed wastes (i.e., Lewisite and spent decon) to the PCC and SCC, respectively. ATLIC LCPT Plan - Rev. 1 Appendix B December 2,2010 TOCDF' B-5 A Lewisite Mini-Burn will be conducted as part of the shakedown activities for the LCPT. The purpose of this mini-bum is to demonstrate the removal of arsenic and particulate matter before reaching the final feed rate. The mini-burn will be conducted at a Lewisite feed rate of 150 lb/hr and a spent decon rate of 450 lb/hr. The exhaust gas will be sampled for metal emissions and particulate matter. The results of the mini-burn will be submitted to the DSHW as supporting information for continuing operation of the ATLIC using Lewisite after completion of the LCPT. ATLIC LCPT Plan - Rev. I Appendix B Decemb er 2, 2010 TOCDF B-6 o s.0 POST.ATLIC LCPT ACTIVITIES Following completion of the ATLIC LCPT, Lewisite processing will continue after the data from the Lewisite Mini-Burn has been submitted to DSHW. The Lewisite feed rate will be limited to the feed rate demonstrated in the Lewisite Mini-Burn, which is anticipated to be 50 Yo of the feed rate demonstrated during the LCPT. The spent decon feed will continue at a feed rate that corresponds to 50 o/o of the organic feed rate demonstrated during the STB, that would correspond to 2.25Ibltr of total organic compounds. It is estimated that the remaining Lewisite would be processed at 150 lb/hr feed rate to the PCC and the spent decon would be processed at atotal organic feed rate of 2.25lbll'r. Limiting the ATLIC Lewisite waste feed to 150lb/hr and the spent decon feed rate to 2.25lblhr of total organic compounds following completion of the LCPT ensures compliance with the federal and state hazardous waste incinerator performance standards. The arsenic removal rate will be established by the Lewisite Mini-Burn data and this data will be provided to DSHW before continuing Lewisite processing after the LCPT. The spent decon feed rate would be limited to 50 Yo of the total organic feed rate demonstrated by the STB. The organic compound feed rates to the ATLIC were established during the STB through the demonstration of the chlorobenzene feed rate and the measured DRE. The DRE data from the STB will establish that rate based on the chlorobenzene feed to the SCC in the STB for which exhaust gas sample results will be provided to DSHW with the preliminary data from the STB. The preliminary data from the STB will demonstrate a DRE of greater than99.9999 o/o for organic feed to the PCC and the SCC. Therefore, processing the remaining Lewisite at 50 %o of that rate will be protective of human health and the environment. ATLIC LCPT Plan - Rev. 1 Appendix B Decemb er 2, 2010 TOCDF B-7 €r5(})g /,e TOOELE CHEMICAL AGENT DISPOSAL FACILITY (rocDF) LEWISITE COMPREHENSIVE PERFORMANCE TEST PLAN FOR THE AREA 10 LIQUID INCINERATOR APPENDIX C MASS AND ENERGY BALANCES FOR ATLIC LEWISITE CPT AND EXHAUST GAS RESIDENCE TIME CALCULATIONS REVISION 1 December 21 2010 LIST OF FIGURES Incinerator Process Flow Diagram PollutionAbatementSystemProcessFlowDiagram c-1 c-2 Figure C- 1 Figure C-2 Table C-l Table C-2 ATLIC ATLIC LIST OF'TABLES ATLIC Lewisite Maximum Feed Mass and Energy BaIances.............. C-3 ATLIC Exhaust Gas Residence Time Calculation for Lewisite Maximum Feed........... .................. C-5 LCPT Plan - Rev. 1 Appendix C December 2,2010 c-i E] \o fu * nt1z q) Itr o r ot r < . l E. = g u) t- \/ (l J \ *fr \noe ooo?N ?a f-+ E] q)-. - H& ' = e =E - \. / l* OtC\ v?cn o\ ooqcn U*ila ;A ) l-OE .r r - c. l -i l | €EE 9 C\ \?ooO O.no\ v,- tfa q\ rn F(!f ,Fr ct ; * (, 6rNtrllU cq()L-CqF6 l -l €o( L .t \/ :)I()aIX c\9o\ f-c. i E Lc) l- ) c) C ) tr ra - Ir \r ' G.-AE Oncn c\qcn F t- lg .. \ . qO .: r ' aa \t s H\ J q)J O. cl oooq: F-lo .! a{r aA* .L LIU)q)A-;-o .ItIqJa (JU(- )() -o63 (- ) 'r = a.ooUIdtrd =U(- ) (t ) l-C) -oE(sUo(r )EUsO()a fI (r )-6 {i)F :oa5 tNlc : : + r8 lI ( . J - -F I B. g () o- olf , Io Eo .F *- ) .= ( ) E6 € E€ E bo i i , g (a rl E .= t x E- H (, E rg ^ (, ) q- .t - { i v q, , .- '- e ( . ) 6' v .E E t- dE = ;e a e L. -: LJ - .- - + J r/ : L ( I ) A T- F L, ' 5 ,. Y = +- ) (, ) O 9 E €. x b€ rT r t .l - . '= X i () e E- . e -E ,\ O- (. ) (D E4 - C . C cs \ ,* ' ,* ' €. = E E .- (J d) (L ) {- = - := 5 - i )- '. o E E ,; ' q- c) q) sb e E E E= a > a . l =u ; i € Et = (. E6 t r C or n o o L .F Hq - q - G. g T l E Eb e e -a = 5 = .= q 3 re F< c l ( . ) C' o = tr i- i - - EG . 2 . 2 EE H g G) >- - \J \. / l< FL r O- A nIiri fr l-zpl--X=ariF!r0-EriJL.o \t szo-F-]pU-]Urd---FriUzE]A--0rI ] il ,a()FaD-*XriU-JFO 6lIUIiJmF r\ ( l ) / . r \ v- c \ r \ J -j + J - T (- tr = c . . l 0 , l HL J )Pq t i : i : 8 ts ts ir r +J u +r . Y Ss Fs G: bo a o +- , t '6 '6 P O t- -C EG t- t- aa O O r- C S t - = ao = = .= u a 0 o O Ai a a ' )- - l. = a ) ( . ) qJ 6 g ; =- = o l o . l '= >< -c -c Ct ! F F 6o - o () E o o o TOOELE CHEMICAL AGENT DISPOSAL FACILITY (rocDF) LEWISITE COMPREHENSIVE PERFORMANCE TEST PLAN FOR THE AREA 10 LIQUID INCINERATORS APPE,NDIX D AUTOMATIC WASTE FEED CUTOFF TABLES AND OPERATING CONDITION TARGET VALUE TABLES FOR AREA 10 LIQUID INCINERATOR REVISION 1 December 2r 20lA LIST OF TABLES Table D-l ATLIC Liquid Incinerator Automatic Waste Feed Cutoff ..................... D-l LCPT Plan - Rev. 1 Appendix D December 2,2010 D-i Table D-I ATLIC LIQUID INCINERATOR AUTOMATIC WASTE FEED CUTOFF [te i:ilNififfibi:etiii 807-FI-8430 I 5 lb/hr one-hour rolling average 22-Pt-84t0 Agent Atornizing Air Pressure Less Than 35 psig l5-TIC-8471 Primary Chamber Temperature Less Than < 2550o F, one-hour rolling average* 29-FtT-8521 Spent Decon Feed Rate Greater Than or Equal to 550 lb/hr over one-hour rolling average* 22-Pt-85n Spent Decon Atomizing Air Pressure Less Than or Equal to 35 psig l5-TIC-8571 Secondary Charnber Temperature Less Than 1850" F, one-hour rolling average* l9-FI-8932 Exhaust Gas Flow Rate (Unit Production Rate) Greater Than or Equal to >960 scfrn, one-hour rolling average* l9-Pr-8982 Scrubber Brine Pump Pressure Less Tharr or Equal to 25 psig l9-FI-892 t Flow to Scrubber Tower #l Less Than or Equal to 40 gprn, one-hour rolling average l0 t9-Fl-8922 Flow to Scrubber Tower #2 Less Than or Equal to 40 gpm, one-hour rolling average ll l9-FI-8923 Flow to Scrubber Tower #3 Less Than or Equal to 40 gpm, one-hour rolling average t2 l9-PDI-891r crubber # I Pressure Drop Less Than or Equal to 0.3 in. w.c., one-hour rolling average l3 l9-PDI-89r 2 crubber #2 Pressure Drop Less Than or Equal to 0.3 in. w.c., one-hour rolling average t4 lg-PDI-8913 Scrubber #3 Pressure Drop Less Than or Equal to 0.3 in. w.c., one-hour rolling average l5 l9-FI-8924 Brine to Venturi Scrubber Flow Less Than or Equal to 8 gprn one-hour rolling average l6 l9-PDI-8915 Venturi Exhaust Gas Pressure Drop Less Than or Equal to 12 in. w.c., one-hour rolling average l7 l9-AIC-8917 Venturi Brine pH Less Than to Equal to 7 pH, one-hour rolling average l8 t9-Atc-8927 Venruri Specific Gravity Greater Than or Equal to 1.28 SGU, twelve-hour rolling average l9 l9-PI-8956 Venturi Pump Pressure Less Than or Equal to 25 psig 0 r9-AIC-89s2 Scrubber Brine pH Less Than to Equal to 7 pH, one-hour rolling average tl r 2 lzal- lzst- lze l9-AI-8983 - l9-TI-893 r - l9-PDI-8936 - r 9-FI-8933 - l9-FI-8940 - l9-PDI-8941 18942 - r 9-TI-8939 - l9-AIT-8302 AIB - I9-AAL.83OI A/B - l9-AAH-8301tuB Brirre Specific Gravity Greater Than or Equal to Bag House lnlet Ternperature Greater Than or Equal to Bag House Pressure Drop Less Than or Equal to Carbon Injection Feed Weight Less Than or Equal to Carborr Injection Air Flow Less Than or Equal to Carbon Filter Pressure Drop Less Than or Equal to Carbon Filter Inlet Temperature Greater Than or Equal to Blower Exhaust CO Concentration Greater Than or Equal to Blower Exhaust Gas Q Less Than or Equal to Blower Exhaust Gas Q Greater Than or Equalto Z 1.28 SGU, twelve-hour rolling average >-240" F, one-hour rolling average s .l in. w.c., one-hour rolling average S.5 lbs/lrr., one-hour rolling average < l5 scfrn, one-hour rolling average S 0.3 in. w.c., one-hour rolling average >240" F, one-hour rolling average : 100 ppm., one-hour rolling average, corected to 7o/o C,2, dry volurned <3o/oo,2 > l5oho2 D-1 LCPT Plan - Rev. 1 Appendix D December 2,2010 Table D-l ATLIC LIQUID INCINERATOR AUTOMATIC WASTE FEED CUTOFF 0a I'EN 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 0.2 sEL'r 0c rEN 7O8CK tack Exhaust GA Agent Detect Greater Than or Equal to 0.2 sEL'r la TEN 7O9AL Stack Exhaust Lewisite Agent Detect Greater Than or Equal to :0.2 SEL"f lb TEN 7O9BL Stack Exhaust Lewisite Agent Detect Greater Than or Equal to 0.2 SEL lc IEN 7O9CL Stack Exhaust Lewisite Agent Detect Greater Than or Equal to ] 0.2 SEL 2 YOL- I2HR.ATLIC olatile Metal (Hg) Greater Than or Equal to :0.70 lb/12 hr twelve-hour rolling average 3 V.I2HR-ATLIC Semi-VIatile (Pb+Cd) Greater Than or Equal to z 0.39 lb/12 lu'nvelve-hour rolling average 4 -V.I2HR.ATLIC -ow-Volatile (As+Be+Cr) Greater Than or Equal to I156 lb/12 hr nnelve-hour rolling average 5 \SH- I2HR-ATLIC -A,sh Greater Than or Equal to ll> tSf 0 lbllzlv twelve-hour rolling average I 6 \4C.I2HR-ATLIC lhlorine Greater Than or Equal to 2298lbll2 hr twelve-hour rolling average hootnotes: I 'Logic code description used to set th€ conhol WFCO alams. I i0 seconds fronr responses obtained at least every 15 secoDds. I 'Waste feed cuGoffs recorded upoD switch activation I )ccurriDgat l5-second intcrvals. I 'An Automatic WFCO occurs if the two on-lirre ACAMS/MINICAMS are not staggered so that at least one unit is sarnplirrg the stack. I The alam sening (in mg/nr3) for GA is 0.00005 and L is 0.012 beginning ofthe Lewisite Comprehensive Performance Test (CPT) Shakedown Period per the requinnent of 40 CFR 63. I 209 based on operational data gererated during the ATLIC Surogate Trial Bum (STB). LCPT Plan - Rev. 1 Appendix D December 2,2010 D-2