DSHW-2024-004759

DEPARTMENT OF THE ARMY
TOOELE ARMY DEPOT/HEADQUARTERS
1 TOOELE ARMY DEPOT, BUILDING 1
TOOELE, UT 84074-5003
February 20, 2024

Subject: Performance Test Plan, 1236M2 Deactivation Furnace, Building 1320, Tooele Army
Depot, Tooele Utah, EPA ID# UT3213820894.

Doug Hansen
Department of Environmental Quality
Division of Waste Management and Radiation Control (WMRC)
P.O. Box 144820
Salt Lake City, Utah 84114-4820

Dear Mr. Hansen:

In accordance with Module IV.G of the State of Utah RCRA Permit UT3213820894, TEAD-N
is submitting the 2024 Performance Test Plan for the 1236M2 Deactivation Furnace that will be
performed tentatively on the week of May 6, 2024.

Should you have any questions regarding this matter, please contact Lonnie Brown of my
staff at [phone].

I certify under penalty of law that this document and all attachments were prepared under
my direction or supervision according to a system designed to assure that quality personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate,
and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fine and imprisonment for knowing violations.

Sincerely,

Erin Trinchitella
Director, Base Operations

Enclosure
1 2024 Performance Test Plan

TRINCHITELLA.ERI
N.JO.1153738838
Digitally signed by
TRINCHITELLA.ERIN.JO.1153738
838
Date: 2024.02.20 11:50:43 -07'00'

840 FIRST AVENUE, SUITE 400 ● KING OF PRUSSIA, PA 19406
610.945.1777 ● WWW.COTERIE-ENV.COM
HWC NESHAP CONFIRMATORY
PERFORMANCE TEST
AND RCRA COMPLIANCE VERIFICATION
TEST PLAN FOR THE APE 1236M2
DEACTIVATION FURNACE

FEBRUARY 2024

US ARMY CORPS OF ENGINEERS
TULSA DISTRICT

TOOELE ARMY DEPOT
TOOELE, UTAH
TOOELE ARMY DEPOT

February 2024
Page i
TABLE OF CONTENTS
1.0 Introduction .................................................................................................................................. 1-1
1.1 Facility Overview .............................................................................................................. 1-1
1.2 Hazardous Waste Combustor Overview .......................................................................... 1-2
1.3 Regulatory Overview........................................................................................................ 1-2
1.3.1 HWC NESHAP Overview ...................................................................................... 1-1
1.4 RCRA Overview ................................................................................................................ 1-2
1.5 Confirmatory Performance Test and RCRA Compliance Verification Test Overview ...... 1-2
1.6 Reference Documents ..................................................................................................... 1-4
1.7 Test Plan Organization ..................................................................................................... 1-4
1.8 Document Revision History ............................................................................................. 1-6
2.0 Feedstream Characterization ........................................................................................................ 2-1
2.1 Ammunition Items ........................................................................................................... 2-1
2.2 Waste Feed Selection for the Test Program .................................................................... 2-2
2.3 Fuel Oil ............................................................................................................................. 2-2
3.0 Monitoring .................................................................................................................................... 3-1
3.1 Continuous Process Monitoring Systems ........................................................................ 3-1
3.2 Continuous Emissions Monitoring Systems ..................................................................... 3-2
3.3 Automatic Waste Feed Cutoff System ............................................................................. 3-3
3.4 Emergency Shutdown System ......................................................................................... 3-3
4.0 Historical Operating Conditions .................................................................................................... 4-1
4.1 Normal Furnace Operating Conditions ............................................................................ 4-1
4.2 Alternative Operating Condition Requests ...................................................................... 4-2
5.0 Confirmatory and RCRA CVT Operations ...................................................................................... 5-1
5.1 Operating Condition 1...................................................................................................... 5-1
5.2 Condition 2 ....................................................................................................................... 5-2
5.3 Test Materials and Quantities .......................................................................................... 5-4
5.4 Test Schedule ................................................................................................................... 5-4
6.0 Sampling and Analysis ................................................................................................................... 6-1
6.1 Waste Sampling and Analysis .......................................................................................... 6-1
6.2 Spiking Material Sampling and Analysis .......................................................................... 6-1
6.3 Stack Gas Sampling and Analysis ..................................................................................... 6-1

LIST OF TABLES
Table 1-1 Final Replacement Standards for Existing Incinerators ................................................... 1-1
Table 1-2 RCRA Performance Standards .......................................................................................... 1-2
Table 1-3 Document Cross-Reference Table ................................................................................... 1-5
Table 1-4 Document Revision History ............................................................................................. 1-6

February 2024
Page ii
Table 2-1 Characterization of Small Ammunition Items .................................................................. 2-1
Table 2-2 Characterization of Feed Items for the Test Program ..................................................... 2-2
Table 3-1 Continuous Process Monitoring Systems and Process Control Equipment .................... 3-1
Table 4-1 Average Values for Operating Parameters ...................................................................... 4-2
Table 5-1 Proposed Furnace Operating Conditions for Test Condition 1 ........................................ 5-1
Table 5-2 Proposed Feed and Spiking Program – Condition 1 ........................................................ 5-2
Table 5-3 Proposed Furnace Operating Conditions for Test Condition 2 ........................................ 5-2
Table 5-4 Proposed Feed and Spiking Program – Condition 2 ........................................................ 5-3
Table 5-5 Test Material Quantities .................................................................................................. 5-4
Table 5-6 Test Schedule ................................................................................................................... 5-5
Table 6-1 Stack Gas Sampling and Analysis Protocol ....................................................................... 6-2
LIST OF FIGURES
Figure 1-1 APE 1236M2 Deactivation Furnace Process Schematic ................................................... 1-3

LIST OF APPENDICES
Appendix A: Quality Assurance Project Plan
Appendix B: Continuous Monitoring Systems Performance Evaluation Test Plan
Appendix C: Source Test Plan for Relative Accuracy Test Audit and Process Control Equipment Audits

TOOELE ARMY DEPOT

February 2024
Page 1-1
1.0 INTRODUCTION
This confirmatory performance test (CfPT) and Resource Conservation and Recovery Act (RCRA)
compliance verification test (CVT) plan is being submitted by the United States Army (US Army) for the
hazardous waste incinerator operated at the Tooele Army Depot (TEAD) in Tooele, Utah. The
incinerator is an Ammunition Peculiar Equipment Model 1236M2 (APE 1236M2) deactivation furnace.
The furnace is subject to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for
Hazardous Waste Combustors (HWCs) codified in Title 40 Code of Federal Regulations (CFR) Part 63
Subpart EEE and the RCRA hazardous waste regulations provided in Section 315 of the Utah
Administrative Code (UAC) and documented in the facility’s RCRA Part B permit.
This plan describes the CfPT and RCRA CVT that will be conducted to demonstrate compliance with the
HWC NESHAP dioxin/furan (D/F) emission standard and the RCRA performance standards. It is being
submitted in accordance with 40 CFR § 63.1207(e)(1)(ii) and Module IV.G.2 of the RCRA Part B permit as
part of the requirements for these compliance demonstrations.
1.1 FACILITY OVERVIEW
The US Army owns and operates the TEAD. The site consists of 23,610 acres, 35 miles west of the Salt
Lake City International Airport. The facility includes over 1,100 storage, production, fabrication, and
administrative buildings. Approximately 500 people are employed at TEAD. At this time, TEAD is
considered an area stationary source of hazardous air pollutants (HAPs) as defined in Part A, Section 112
of the Clean Air Act, amended on November 15, 1990.
The street address and identification number of the TEAD are:
1 Tooele Army Depot
Tooele, Utah 84074-5000
EPA ID No. UT3213820894
All correspondence should be directed to the following facility contact:
Lonnie Brown
Environmental Engineer
JMTE-BOV, Building 501
1 Tooele Army Depot
Tooele, Utah 84074-5003

February 2024
Page 1-2
1.2 HAZARDOUS WASTE COMBUSTOR OVERVIEW
The TEAD deactivation furnace is designed to thermally treat obsolete or unserviceable ammunition
ranging from small arms through 20-millimeter items, as well as cartridge activated devices (CADs) and
propellant activated devices (PADs). All items larger than 20-mm must be disassembled before being
fed to the furnace.
Feed materials for the deactivation furnace are loaded into a push-off box located in the feed room.
From this push-off box, the materials travel on a feed conveyor through a concrete barricade wall and
into a barricaded area, where they drop through a feed chute into the rotary kiln. Once in the kiln, the
munitions are propelled through the unit countercurrent to the flue gas by the rotation of the kiln and
spiral flights that line the inside of the kiln.
Ash and metal components not entrained in the flue gas are discharged at the burner end of the kiln
onto a discharge conveyor. The discharge conveyor moves the ash materials from the kiln to an
adjacent accumulation area. Before disposal, the operators sort through the discharged materials to
ensure that no unspent munitions are sent for disposal. Any unspent munitions are sent back through
the deactivation furnace for further processing.
From the kiln, the flue gas is transported to the cyclone, where sparks that could harm the downstream
equipment are collected and discharged through a double tipping valve into a collection container for
disposal. The flue gases pass through the cyclone and into the afterburner, which is designed to further
heat the combustion gas, ensuring the required destruction of organic compounds.
Following the afterburner, the flue gas passes through stainless steel ductwork to a high temperature
ceramic baghouse. The baghouse is used to remove particulates and metals from the gas stream. An
induced draft (ID) fan, located downstream of the baghouse, provides the motive force for the flue gas
through the APE1236M2 incineration system.
Figure 1-1 provides a schematic diagram of the APE 1236M2 deactivation furnace.
1.3 REGULATORY OVERVIEW
Operations of the APE1236M2 deactivation furnace are regulated through RCRA and the HWC NESHAP.
The RCRA requirements for the unit are contained in Module IV of the facility's RCRA Part B Permit and
are based upon the regulations for incinerators promulgated in 40 CFR Part 264, Subpart O and UAC
Section 315. The facility's Title V permit houses the HWC NESHAP requirements, incorporating the
Federal standards that are promulgated in 40 CFR Part 63, Subpart EEE. Many of the RCRA and Title V
requirements are similar to one another. Therefore, compliance efforts, including emission tests, for
these two regulatory programs are often combined.

February 2024
Page 1-3
FIGURE 1-1
APE 1236M2 DEACTIVATION FURNACE PROCESS SCHEMATIC

February 2024
Page 1-1
1.3.1 HWC NESHAP OVERVIEW
On September 30, 1999, the United States Environmental Protection Agency (USEPA) promulgated the
HWC NESHAP under joint authority of the Clean Air Act Amendments of 1990 and the RCRA, codifying
the requirements in 40 CFR Part 63 Subpart EEE. On October 12, 2005, USEPA amended Subpart EEE to
include revised standards for the “Phase I” sources (i.e., hazardous waste incinerators, cement kilns, and
lightweight aggregate kilns) and to incorporate standards for “Phase II” sources (i.e., liquid fuel-fired
boilers, solid fuel-fired boilers, and hydrochloric acid production furnaces that burn hazardous waste).
The standards, which are based upon the maximum achievable control technology (MACT), regulate
emissions of D/F, mercury, hydrogen chloride and chlorine (HCl/Cl2), semivolatile metals (SVM) – lead
and cadmium, low volatile metals (LVM) – arsenic, beryllium, and chromium, particulate matter (PM),
carbon monoxide (CO), and hydrocarbons (HC) from both new and existing sources.
The deactivation furnace is subject to the HWC NESHAP emission standards for existing hazardous waste
incinerators. The applicable emission standards for the furnace are summarized in Table 1-1
TABLE 1-1
FINAL REPLACEMENT STANDARDS FOR EXISTING INCINERATORS
PARAMETER UNITS 1 EMISSION STANDARD
Dioxins and furans ng TEQ/dscm 0.20
Mercury mg/dscm 130
Semivolatile metals mg/dscm 230
Low volatile metals mg/dscm 92
Carbon monoxide ppmv, dry basis 100
Hydrocarbons ppmv, dry basis 10
Hydrogen chloride and chlorine ppmv, dry basis 32
Particulate matter gr/dscf 0.013
Destruction and removal efficiency % 99.99
1 Emission standards corrected to seven percent oxygen.
Periodically, facilities must sample unit emissions to verify compliance with the HWC NESHAP. Every
61 months, subject facilities must conduct a comprehensive performance test (CPT) to demonstrate
compliance with all of the applicable emission standards and to establish operating parameter limits
(OPLs) for the system. In between these CPTs, facilities must conduct confirmatory performance tests
(CfPTs) to demonstrate continued compliance with the D/F emission standard. Pursuant to 40 CFR §
63.1207(b)(2) these CfPTs must be conducted when the source operates under normal operating
conditions and must commence no later than 31 months after the start of the last CPT.

February 2024
Page 1-2
1.4 RCRA OVERVIEW
The TEAD RCRA Part B permit authorizes the deactivation furnace to operate as a hazardous waste
treatment operation. Module IV of the permit provides performance standards for the furnace. These
standards are summarized in Table 1-2 and are described below:
 Section IV.B.1 requires a destruction and removal efficiency (DRE) of 99.99 percent for each
designated principal organic hazardous constituent (POHC).
 Section IV.B.2 limits particulate matter (PM) emissions to less than 180 milligrams per dry standard
cubic meter (mg/dscm), corrected to seven percent oxygen, or 0.08 grains per dry standard cubic
foot (gr/dscf), corrected to seven percent oxygen.
 Section IV.B.3 limits hydrogen chloride (HCl) emissions to less than 1.8 kilograms per hour (kg/hr) or
4.0 pounds per hour (lb/hr).
 Section IV.B.4 limits the concentration of carbon monoxide (CO) in the furnace exhaust to less than
100 parts per million by volume, dry basis (ppmvd), corrected to seven percent oxygen over an
hourly rolling average (HRA) and 500 ppmvd, corrected to seven percent oxygen for more than one
minute.
 Section IV.B.5 limits the concentration of metals in the furnace exhaust. SVM are limited to less
than 230 micrograms per dry standard cubic meter (µg/dscm) corrected to seven percent oxygen,
LVM are limited to less than 92 µg/dscm corrected to seven percent oxygen, and barium is limited to
less than 1,392 µg/dscm corrected to seven percent oxygen.
TABLE 1-2
RCRA PERFORMANCE STANDARDS
PARAMETER UNITS 1 EMISSION STANDARD
Destruction and removal efficiency % 99.99
Particulate matter mg/dscm
gr/dscf
180
0.08
Hydrogen chloride kg/hr
lb/hr
1.8
4.0
Carbon monoxide ppmv, dry basis (HRA)
ppmv, dry basis (one-minute)
100
500
Semivolatile metals mg/dscm 230
Low volatile metals mg/dscm 92
Barium mg/dscm 1,392
1 All concentration-based emission standards corrected to seven percent oxygen.
1.5 CONFIRMATORY PERFORMANCE TEST AND RCRA COMPLIANCE VERIFICATION TEST
OVERVIEW
The protocol for the CfPT and RCRA CVT is designed to demonstrate compliance with the HWC NESHAP
D/F emission standard and the RCRA performance standards. Two test conditions will be performed:

February 2024
Page 1-3
 Condition 1 will be performed to demonstrate compliance with the HWC D/F emission standard and
the RCRA DRE and CO standards. During the condition, the deactivation furnace will be operated
within the HWC NESHAP and RCRA permit limits, at historically normal conditions, and the feed of
chlorine will be elevated above historically normal levels. Adequate diphenylamine will also be
provided in the waste feed to ensure proper measurement of the DRE.
 Condition 2 will be performed to demonstrate compliance with the RCRA PM, HCl, SVM, LVM, and
barium standards. During the condition, the deactivation furnace will be operated within the HWC
NESHAP and RCRA permit limits, at historically normal conditions, and the feed of PM, chlorine,
SVM, LVM, and barium will be elevated above historically normal levels.
The test program will be coordinated by Coterie Environmental LLC (Coterie) under the direction of US
Army personnel. Coterie is responsible for the test protocol development and implementation and will
oversee the furnace operations and the stack sampling activities during the test program. Montrose Air
Quality Services, LLC, (MAQS) will perform the stack sampling for the test program. MAQS will be
responsible for all emissions samples collected during the test program, with oversight by Coterie. The
emissions samples will be analyzed by Eurofins Environment Testing (Eurofins) in Knoxville, Tennessee.
Additional information on the project team roles and responsibilities is provided in the quality assurance
project plan (QAPP) in Appendix A.
Prior to the CfPT, the US Army will perform the HWC NESHAP continuous monitoring systems (CMS)
performance evaluation test (PET). The goal of the CMS PET is to demonstrate that the CMS associated
with the furnace and used to demonstrate compliance with the D/F emission standard are operating in
compliance with the standards presented in the HWC NESHAP and in the NESHAP General Provisions
contained in 40 CFR §§ 63.1 through 63.15 and the RCRA permit. As described in 40 CFR §§ 63.8(c)(2)
and (3), all CMS used in accordance with the HWC NESHAP shall be installed so that representative
measurements of emissions or process parameters can be obtained. During the CMS PET, the US Army
will verify that each CMS used to ensure continuous compliance with the D/F emission standard is
correctly installed, calibrated, and operational. A copy of the CMS PET plan is included as Appendix B.
In addition to conducting the HWC NESHAP CMS PET, the US Army will also conduct the process control
equipment (PCE) audit required under Section 5.2 of Attachment 13 to the RCRA Part B Permit. This
annual audit is required under the RCRA Part B permit to demonstrate proper calibration of all of the
PCE used to demonstrate compliance with the RCRA standards. A copy of the PCE audit protocol is
provided in Appendix C.
The previous CPT for the furnace commenced on October 26, 2021. The CfPT must begin no later than
31 months after the date that the previous CPT commenced, which would be May 26, 2024. The RCRA
CVTs are required biennially and, per Condition IV.G.1 of the RCRA Part B permit, are to be coordinated
to align with the HWC NESHAP CPT and CfPT schedules. The US Army anticipates conducting the CfPT
and RCRA CVT during the week of May 6, 2024. The testing is expected to take four days. The CfPT and
RCRA CVT report will be submitted within 90 days after completion of all emissions testing.

February 2024
Page 1-4
1.6 REFERENCE DOCUMENTS
Reference documents that have been used in developing this plan include the following:
 UDEQ, TEAD North RCRA Part B Permit, issued 2 February 2017.
 USEPA, National Emission Standards for Hazardous Air Pollutants from Hazardous Waste
Combustors, 40 CFR Part 63, Subpart EEE, September 30, 1999, and as amended through
October 28, 2008.
 USEPA, New Source Performance Standards, Test Methods and Procedures, Appendix A,
40 CFR Part 60.
 USEPA, New Source Performance Standards, Performance Specifications, Appendix B, 40 CFR
Part 60.
 USEPA, Test Methods for Evaluating Solid Wastes Physical/Chemical Methods, Third Edition, 1986
and updates (SW-846).
1.7 TEST PLAN ORGANIZATION
This test plan has been prepared to meet the requirements of 40 CFR § 63.1207(f) and the TEAD RCRA
Part B Permit. The remaining sections of the plan provide the following information:
 Section 2.0 presents information on the furnace’s feedstreams.
 Section 3.0 presents a description of the furnace’s CMS.
 Section 4.0 presents a discussion on the historically normal operations of the furnace.
 Section 5.0 presents a description of the proposed CfPT and RCRA operating conditions.
 Section 6.0 presents a summary of the test sampling and analysis procedures.
 Appendix A includes the QAPP.
 Appendix B includes the CMS PET plan required by 40 CFR § 63.1207(e)(1)(ii).
 Appendix C includes the PCE Audit protocol for the RCRA instrument audit.
Table 1-3 presents a cross-reference table to use in comparing the test plan to HWC NESHAP
requirements.

February 2024
Page 1-5
TABLE 1-3
DOCUMENT CROSS-REFERENCE TABLE
40 CFR 63 REQUIREMENT LOCATION IN
DOCUMENT
7(c)(2)(i) A test program summary, the test schedule, data quality objectives, and both an
internal and external quality assurance program
Sections 5
and 6, and
Appendix A
7(c)(2)(ii) An internal QA program, including the activities planned by routine operators and
analysts to provide an assessment of test data precision
Appendix A
7(c)(2)(iii) An external QA program, including: application of plans for a test method
performance audit (PA) during the performance test, and system audits that include
the opportunity for onsite evaluation by the Administrator of instrument calibration,
data validation, sample logging, and documentation of quality control data and field
maintenance activities
Appendix A
7(c)(2)(v) Additional relevant information requested after submittal of the site-specific test
plan
None
requested
1207(f)(2)(i) A description of your normal HC or CO operating levels and an explanation of how
these normal levels were determined
Section 4
1207(f)(2)(ii) A description of your normal applicable operating parameter levels and an
explanation of how these normal levels were determined
Section 4
1207(f)(2)(iii) A description of your normal chlorine operating levels and an explanation of how
these normal levels were determined
Section 4
1207(f)(2)(iv) If you use carbon injection or a carbon bed [for D/F control], a description of your
normal cleaning cycle of the particulate matter control device and an explanation of
how these normal levels were determined
Not
applicable
1207(f)(2)(v) A detailed description of sampling and monitoring procedures including sampling and
monitoring locations in the system, the equipment to be used, sampling and
monitoring frequency, and planned analytical procedures for sample analysis
Section 6 and
Appendix A
1207(f)(2)(vi) A detailed test schedule for each hazardous waste for which the performance test is
planned, including date(s), duration, quantity of hazardous waste to be burned, and
other relevant factors
Section 5,
Tables 5-5
and 5-6
1207(f)(2)(vii) A detailed test protocol, including, for each hazardous waste identified, the ranges of
hazardous waste feedrate for each feed system, and, as appropriate, the feedrates of
other fuels and feedstocks, and any other relevant parameters that may affect the
ability of the hazardous waste combustor to meet the dioxin/furan emission standard
Section 5,
Tables 5-1
and 5-2
1207(f)(2)(viii) A description of, and planned operating conditions for, any emission control
equipment that will be used
Section 5,
Table 5-1
1207(f)(2)(ix) Procedures for rapidly stopping the hazardous waste feed and controlling emissions
in the event of an equipment malfunction
Section 3
1207(f)(2)(x) Such other information as the Administrator reasonably finds necessary to determine
whether to approve the confirmatory test plan
None
requested

February 2024
Page 1-6
1.8 DOCUMENT REVISION HISTORY
The original version of this plan was submitted in February 2024. The nature and date of any future
revisions will be summarized in Table 1-4.
TABLE 1-4
DOCUMENT REVISION HISTORY
REVISION DATE DESCRIPTION OF CHANGES
0 February 2024 Original submittal

TOOELE ARMY DEPOT

February 2024
Page 2-1
2.0 FEEDSTREAM CHARACTERIZATION
The US Army incinerates obsolete and unserviceable ammunition items in the deactivation furnace at
TEAD. Over 100 different ammunition items are currently slated for destruction in the furnace. These
materials have all been manufactured following government specifications and are characterized in the
Munitions Items Disposition Action System (MIDAS). They may contain a variety of HAPs, including
regulated organic and inorganic compounds. Fuel oil is used throughout system operations to provide
the necessary heat for destruction of the munitions.
2.1 AMMUNITION ITEMS
The ammunition items processed in the furnace include various types of munitions, such as bullets,
grenades, and detonating fuses that contain propellant, energetic, and pyrotechnic (PEP) material.
Because of the dangers associated with sampling and analyzing explosives, the US Army does not rely on
sample analysis to characterize the waste munitions. These materials have all been manufactured
following government specifications and are characterized in MIDAS.
Munitions characterizations in MIDAS include information on the reactive portions (i.e., the PEP
material) and inert portions of each munition item. Any inert portions that are fed to the deactivation
furnace do not combust; they remain as scrap material and exit the system through the kiln discharge.
Therefore, the compositions of the inert portions are not considered when the feed rates of regulated
constituents to the furnace.
Table 2-1 provides typical ranges for the regulated constituents in the largest fraction of small
ammunition items found in TEAD’s demilitarization account. This table is intended to provide a broad
picture of the wastes that are likely to be incinerated within the immediate future.
TABLE 2-1
CHARACTERIZATION OF SMALL AMMUNITION ITEMS
PARAMETER MINIMUM
(G/ITEM)
MAXIMUM
(G/ITEM)
AVERAGE
(G/ITEM)
Propellant, explosive, and pyrotechnic 0.13 50 14
Mercury 0 0 0
Semivolatile metals 0 0.091 0.040
Low volatile metals 0 0 0
Chlorine 0 1.4 0.12
Barium 0 0.29 0.064
Particulate matter generation 0.045 12 4.3

February 2024
Page 2-2
2.2 WASTE FEED SELECTION FOR THE TEST PROGRAM
Two different feed items will be utilized during the upcoming test program. For Condition 1, HC-25 FS
propellant will be fed to the system. This item was selected to provide the targeted PEP and
diphenylamine for the DRE and D/F demonstrations. For Condition 2, 20-mm incendiary M96 cartridges,
carrying a Department of Defense Identification Code (DODIC) A776, will be fed to the furnace. This
item was chosen to provide the required particulate matter generation for the RCRA PM demonstration.
It will also supply some of the required LVM and chlorine for the test condition. Table 2-2 provides a
characterization of each of these feed items. If for some reason either of these feed items are
unavailable for processing during the test, another item will be selected to provide the required feed
contributions.
TABLE 2-2
CHARACTERIZATION OF FEED ITEMS FOR THE TEST PROGRAM
CONSTITUENT
CONCENTRATION IN FEED ITEM (LB/LB)
HC-25 FS PROPELLANT A776, 20-MM INC
Propellant, explosive, and pyrotechnic 1.0 0.171
Chlorine 0 9.77 x 10-5
Particulate matter generation 0.0164 0.0529
Semivolatile metals 0 1.02 x 10-4
Low volatile metals 0 0
Mercury 0 0
2.3 FUEL OIL
No. 2 fuel oil is used as the primary fuel for the deactivation furnace. The fuel oil is used to raise the
temperature of the rotary kiln and afterburner to the preset minimums before waste is introduced to
the system and to maintain temperature during operations. The fuel oil may contain small levels of
HWC NESHAP regulated metals. A certificate of analysis for the fuel oil is maintained at the TEAD.
TOOELE ARMY DEPOT

February 2024
Page 3-1
3.0 MONITORING
Monitoring equipment for the furnace includes systems for process control and for stack gas analysis.
This equipment enables the operators to maintain safe operation in compliance with the HWC NESHAP
and RCRA OPLs. This section of the plan provides an overview of the CMS associated with the furnace.
These CMS are comprised of continuous process monitoring systems (CPMS), or process control
equipment (PCE), and continuous emissions monitoring systems (CEMS). More information on the CMS
used for HWC NESHAP compliance can be found in the CMS PET plan, which is included as Appendix B.
The RCRA PCE audit protocol in Appendix C provides more detail on the required RCRA PCE.
3.1 CONTINUOUS PROCESS MONITORING SYSTEMS
40 CFR § 63.1209(b)(1) and the RCRA Permit require that TEAD use CPMS/PCE to document compliance
with the applicable OPLs. Under the HWC NESHAP, the CPMS must sample regulated operating
parameters without interruption and must evaluate a detector response at least once every 15 seconds.
One-minute average (OMA) values are calculated and recorded for each regulated operating parameter,
and the appropriate rolling average is calculated from the OMAs. Table 3-1 lists the CPMS and PCE used
to demonstrate continuous compliance with HWC NESHAP and RCRA requirements. Only those
instruments marked with an asterisk (*) are required to demonstrate compliance with the HWC NESHAP
D/F standard. For the RCRA program, only those instruments that require an annual calibration audit
are specified.
TABLE 3-1
CONTINUOUS PROCESS MONITORING SYSTEMS AND PROCESS CONTROL EQUIPMENT
PARAMETER INSTRUMENT
DESCRIPTION
PROGRAMMED
SPAN
CALIBRATION
ACCURACY
COMPLIANCE
PROGRAM
Charge feed rate * Waste feed scale 0 – 50 lb ± 2% of span HWC NESHAP, RCRA
Kiln burner end
temperature
Thermocouple 0 – 2,200°F ± 2% of span RCRA
Kiln feed end
temperature
Thermocouple 0 – 2,200°F ± 2% of span RCRA
Kiln feed end draft Pressure transmitter -2 to 2 in. w.c. ± 3% of span HWC NESHAP, RCRA
Enclosure pressure Pressure transmitter -2 to 0.05 in. w.c. ± 2% of span HWC NESHAP
Afterburner
temperature *
Thermocouple 0 – 2,200°F ± 2% of span HWC NESHAP, RCRA

February 2024
Page 3-2
TABLE 3-1 (CONTINUED)
CONTINUOUS PROCESS MONITORING SYSTEMS AND PROCESS CONTROL EQUIPMENT
PARAMETER INSTRUMENT
DESCRIPTION
PROGRAMMED
SPAN
CALIBRATION
ACCURACY
COMPLIANCE
PROGRAM
Baghouse inlet
temperature *
Thermocouple 0 – 2,200°F ± 2% of span HWC NESHAP, RCRA
Baghouse outlet
temperature
Thermocouple 0 – 2,200°F ± 2% of span RCRA
Baghouse
differential pressure
Differential pressure
transmitter
0 – 30 in. w.c. ± 3% of span RCRA
Stack gas velocity * Thermal mass
flow meter
0 – 100 fps ± 5% of span HWC NESHAP, RCRA
Stack gas temperature Thermal mass
flow meter
0 – 1,200°F ± 2% of span RCRA
3.2 CONTINUOUS EMISSIONS MONITORING SYSTEMS
Both 40 CFR § 63.1209(a)(1)(i) and the TEAD RCRA Part B Permit require that CEMS be installed to
measure the concentration of CO in the exhaust stack. TEAD is also required to use an oxygen CEMS to
continuously correct the CO levels to seven percent oxygen. Under the HWC NESHAP, these CEMS must
meet the requirements of Performance Specification 4B of 40 CFR Part 60 Appendix B for CO and oxygen
CEMS. This specification requires a dual range CO monitor with span values of zero to 200 ppmvd and
zero to 3,000 ppmvd. The HWC NESHAP also requires that any time an OMA CO value exceeds the
3,000 ppmvd span, the OMA value must be recorded as 10,000 ppmvd. As an alternative, facilities may
use a CEMS with a third span of zero to 10,000 ppmvd to provide additional measurement capability at
these elevated CO levels.
The US Army utilizes a Horiba non-dispersive infrared (NDIR) analyzer to continuously monitor the CO
concentration in the stack gas. The analyzer is dual range design with a zero to 200 ppmvd span value
for the low range and a zero to 3,000 ppmvd span for the high range. The oxygen analyzer that is used
to correct CO emission concentrations to seven percent oxygen is a Horiba paramagnetic analyzer. The
analyzer has a span of zero to 25 percent oxygen by volume on a dry basis.
The CEMS are maintained using a specified maintenance routine, which includes:
 Routine maintenance
 Daily auto calibrations
 Quarterly absolute calibration audits (ACAs)
 Annual relative accuracy test audits (RATAs)
Any problems identified by the above tests are remedied through corrective action measures specific to
the problem encountered.

February 2024
Page 3-3
3.3 AUTOMATIC WASTE FEED CUTOFF SYSTEM
40 CFR § 63.1206(c)(3) and the TEAD RCRA Part B permit require that the US Army operate the furnace
with a functioning system that immediately and automatically cuts off the hazardous waste feed when
OPLs or emission standards are exceeded. An immediate and automatic cutoff is also required under
the HWC NESHAP when the OMA of any CPMS exceeds the span value. Any malfunctions of the
monitoring equipment or the automatic waste feed cutoff (AWFCO) system should also initiate an
immediate and automatic cutoff of hazardous waste feed.
In accordance with these requirements, the AWFCO system is designed to restrict the feeding of
hazardous waste to the deactivation furnace should an OPL or CMS span value be exceeded or should
the system itself fail. Due to safety concerns, any waste that has already been placed on the feed
conveyor upon activation of the AWFCO system will continue to flow to the furnace after the AWFCO.
However, the system will not allow any new materials to be added to the conveyor.
3.4 EMERGENCY SHUTDOWN SYSTEM
Emergency shutdown features are included to protect the equipment in the event of a malfunction.
During an emergency shutdown, all waste feeds and fuel feeds are stopped. The trigger points for an
emergency shutdown have been set independent of regulatory test conditions. These limits are based
on equipment design and operating specifications and are considered good operating practices.
TOOELE ARMY DEPOT

February 2024
Page 4-1
4.0 HISTORICAL OPERATING CONDITIONS
40 CFR § 63.1207(g)(2) specifies that the CfPT must be conducted under “normal” operating conditions.
Likewise, the RCRA Part B permit requires that the CVT be conducted within the operating limit values
provided within the permit. Generally, the “normal” historical level helps to set the target for this test
as well.
“Normal” operating conditions are defined under the HWC NESHAP as follows:
 Each operating parameter, including the PEP feed rate limit (FRL), must be held within the range of
the average value over the previous 12 months and the maximum or minimum OPL, as appropriate.
 Chlorine must be fed at the average rate over the prior 12 months or greater for the HWC NESHAP
D/F demonstration.
 CO emissions levels must be within the range of the average value to the maximum value allowed.
For the RCRA parameters, the other constituent feed rate limitations (e.g., PM, chlorine, SVM, LVM, and
barium) must be held within the range of the average value of the previous 12 months and the
applicable FRL.
4.1 NORMAL FURNACE OPERATING CONDITIONS
To establish the operating conditions for this test program, furnace operating data from December 2022
through November 2023 was reviewed. For each parameter, the average or “normal” value was
determined by summing the HRA or OMA values recorded over the previous 12 months and dividing
that sum by the number of HRA or OMA values recorded during that time. For constituent feed rates,
TEAD does not use an averaging period in their feed rate determination; therefore, the definition of
average is the same, except that the OMA feed rates are averaged instead of HRAs. The average value
must not include calibration data, startup data, shutdown data, malfunction data, and data obtained
when not burning hazardous waste.
The following OPLs were established for the furnace to demonstrate compliance with the HWC NESHAP
D/F emission standard and the RCRA performance standards:
 Maximum total hazardous waste feed rate (as PEP feed rate)
 Minimum afterburner temperature
 Maximum baghouse inlet temperature
 Maximum flue gas flow rate (as stack gas velocity)
For the RCRA Permit, the following additional OPLs and FRLs are required to demonstrate compliance:
 Kiln exit (feed end) temperature

February 2024
Page 4-2
 Kiln rotational speed
 Baghouse differential pressure
 PM generation, chlorine, SVM, LVM, and barium feed rates
The prior 12 months of operating data were reviewed to determine the average value for each of these
parameters, as well as for the constituent feed rates and for the continuously monitored CO emissions.
Table 4-1 presents the average value for each parameter over the period and the associated OPL for that
parameter. The operating conditions for the CfPT and the RCRA CVT must be set within the averages
presented in Table 4-1 and the maximum or minimum OPL, as appropriate. For those parameters with
HWC NESHAP OPLs, those required to demonstrate compliance with the D/F standard are marked with
an asterisk (*).
TABLE 4-1
AVERAGE VALUES FOR OPERATING PARAMETERS
PARAMETER UNITS AVERAGE 1
OPERATING PARAMETER LIMIT
HWC NESHAP RCRA
PEP feed rate * lb/hr 35 ≤ 132 ≤ 237
Chlorine feed rate lb/hr 0 ≤ 2.2 ≤ 2.2
PM generation rate lb/hr 4.9 65 64
SVM feed rate lb/hr 0.10 14 7.9
LVM feed rate lb/hr 0 19 13
Barium feed rate lb/hr 0.0076 - - - 19
Kiln exit (feed end) temperature °F 439 - - - < 680
Kiln rotational speed rpm 1.4 - - - 0.2 – 3.0
Afterburner temperature * °F 1,682 ≥ 1,607 1,601 - 1,811
Baghouse inlet temperature * °F 916 801 – 1,042 2 750 - 1,018
Baghouse differential pressure in. w.c. 13 - - - ≥ 3.5 in.w.c
Stack gas velocity * fps 27 ≤ 44 ≤ 58
Carbon monoxide emission concentration
ppmv, dry basis 3 1.5 ≤ 100
≤ 100 (HRA)
≤ 500 (OMA)
1 Values shown represent the average of data collected from December 2022 through November 2023.
2 Only the lower limit is used to demonstrate compliance with the HWC NESHAP D/F standard.
3 Values are corrected to seven percent oxygen.
4.2 ALTERNATIVE OPERATING CONDITION REQUESTS
In some cases, it may not be possible to maintain unit operations between the historically “normal”
value and the OPL as required under the HWC NESHAP. For these cases, 40 CFR § 63.1207(g)(2)(v)

February 2024
Page 4-3
allows the Administrator to approve an alternative range for an operating parameter if the facility
documents it may be problematic to maintain the required range during the CfPT.
After reviewing the historical data and the system capabilities, the US Army requests one alternative be
approved for the CfPT:
 The US Army requests that the stack gas CO concentration be allowed to vary between zero and the
RCRA and HWC NESHAP emission limitations instead of between the historically normal CO value of
1.5 ppmvd, corrected to seven percent oxygen, and the RCRA and HWC NESHAP emission
limitations. The value of 1.5 ppmvd corrected to seven percent oxygen is within the allowable error
of the CO CEMS and trying to maintain the CO above this value is technically infeasible during the
test program.

TOOELE ARMY DEPOT

February 2024
Page 5-1
5.0 CONFIRMATORY AND RCRA CVT OPERATIONS
The US Army intends to perform two test conditions to demonstrate that the furnace operates in
conformance with the HWC NESHAP D/F and RCRA emission standards. This section of the plan
establishes the furnace operating conditions that will be demonstrated during those tests. In addition,
the preparation of materials to be fed during the testing, the amount of waste to be used, and a
schedule for the testing are presented here.
5.1 OPERATING CONDITION 1
Condition 1 is designed to demonstrate operations of the furnace at a normal or higher PEP and chlorine
feed rate and normal operating conditions. During Condition 1, the US Army will demonstrate
compliance with the HWC NESHAP D/F emission standard and the RCRA DRE and CO standards.
Triplicate sampling runs will be performed for the condition. Table 5-1 provides an overview of the
planned operations for the test condition. Those items marked with an asterisk (*) are tied to the HWC
NESHAP D/F demonstration. All flow rates and operating conditions presented below are estimated
values; the actual conditions observed during the test may vary slightly from these values.
TABLE 5-1
PROPOSED FURNACE OPERATING CONDITIONS FOR TEST CONDITION 1
OPERATING PARAMETER UNITS TARGETS ACCEPTABLE
RANGE 1
PEP feed rate * lb/hr 120 35 – 132
Chlorine feed rate * lb/hr 0.14 0 – 2.2
Diphenylamine feed rate lb/hr 1.4 - - - 3
Kiln exit (feed end) temperature °F < 680 < 680
Kiln rotational speed rpm 0.2 – 3.0 0.2 – 3.0
Afterburner temperature * °F 1,635 1,607 – 1,682
Baghouse inlet temperature * °F 875 801 – 916
Baghouse differential pressure in. w.c. ≥ 3.5 in.w.c ≥ 3.5 in.w.c
Stack gas velocity * fps 35 27 – 44
Carbon monoxide emission concentration ppmv, dry basis 2 ≤ 100 0 – 100
1 The acceptable range is established per 40 CFR § 63.1207(g)(2) as the range between the 12-month averages presented in Table 4-1
and the maximum or minimum OPL, as appropriate. In the case where RCRA and the HWC NESHAP both have applicable OPLs, the
more restrictive OPL was chosen as the upper/lower end value.
2 Corrected to seven percent oxygen.
3 The diphenylamine feed rate is measured to calculate the RCRA DRE. The feed rate of it is not a normal OPL and therefore it does not
have an “acceptable range” for the test program.

February 2024
Page 5-2
In order to accomplish the feed rate values provided in Table 5-1, some level of waste feed spiking will
be required. The chosen feed item, HC-25FS propellant, will not provide enough chlorine and
diphenylamine to achieve the desired targets. Therefore, the US Army will spike surrogate compounds
to supplement these feed requirements. Potassium perchlorate (KClO4) will be spiked to elevate the
chlorine feed rate for the HWC NESHAP D/F demonstration, and diphenylamine will be spiked to provide
adequate feed for the RCRA DRE calculation. Table 5-2 provides a summary of the planned feed and
spiking program for Test Condition 1.
TABLE 5-2
PROPOSED FEED AND SPIKING PROGRAM – CONDITION 1
FEED RATE
FEED ITEMS
PROP HC-25FS KCLO4 SPIKE DIPHENYLAMINE SPIKE
Total item feed rate 120 lb/hr
(2, 0.25-lb pkg, ev. 15 sec)
0.54 lb/hr
(1, 4.1-g pkg/minute)
0.54 lb/hr
(1, 4.1-g pkg/minute)
CONSTITUENT FEED RATES (LB/HR)
PEP feed rate 120 0 0.54
Diphenylamine feed rate 0.90 0 0.54
Chlorine feed rate 0 0.14 0
5.2 CONDITION 2
Condition 2 is designed to demonstrate operations of the furnace at normal or higher chlorine, PM,
SVM, LVM, and barium feed rates and normal operating conditions. During Condition 2, the US Army
will demonstrate compliance with the RCRA PM, HCl, SVM, LVM, and barium emission standard; no
HWC NESHAP demonstrations are included in this test condition. Triplicate sampling runs will be
performed for the condition. Table 5-3 provides an overview of the planned operations for the test
condition. All flow rates and operating conditions presented in this plan are estimated values; the actual
conditions observed during the test may vary slightly from these values.
TABLE 5-3
PROPOSED FURNACE OPERATING CONDITIONS FOR TEST CONDITION 2
OPERATING PARAMETER UNITS TARGETS ACCEPTABLE
RANGE 1
Chlorine feed rate lb/hr 0.49 0 – 2.2
PM generation rate lb/hr 45 4.9 – 64
SVM feed rate lb/hr 2.0 0.10 – 7.9
LVM feed rate lb/hr 3.0 0 – 13
Barium feed rate lb/hr 7.9 0.0076 - 19

February 2024
Page 5-3
TABLE 5-3 (CONTINUED)
PROPOSED FURNACE OPERATING CONDITIONS FOR TEST CONDITION 2
OPERATING PARAMETER UNITS TARGETS ACCEPTABLE
RANGE 1
Kiln exit (feed end) temperature °F < 680 < 680
Kiln rotational speed rpm 0.2 – 3.0 0.2 – 3.0
Afterburner temperature * °F 1,725 1,680 – 1,811
Baghouse inlet temperature * °F 960 919 – 1,018
Baghouse differential pressure in. w.c. ≥ 3.5 in.w.c ≥ 3.5 in.w.c
Stack gas velocity * fps 35 28 – 44
Carbon monoxide emission concentration ppmv, dry basis 2 ≤ 100 0 - 100
1 The acceptable range is established per 40 CFR § 63.1207(g)(2) as the range between the 12-month averages presented in Table 4-1
and the maximum or minimum OPL, as appropriate. In the case where RCRA and the HWC NESHAP both have applicable OPLs, the
more restrictive OPL was chosen as the upper/lower end value.
2 Corrected to seven percent oxygen.
In order to accomplish the feed rate values provided in Table 5-4, some level of waste feed spiking will
be required. The chosen feed item, the 20-mm M96 INC round, will not provide enough chlorine, LVM,
or SVM to achieve the desired targets. Therefore, the US Army will spike surrogate compounds to
supplement these feed requirements. The following surrogate spiking streams will be added:
 Potassium perchlorate (KClO4) will be spiked to elevate the chlorine feed rate for the RCRA CVT
 Chromium powder will be spiked to elevate the LVM feed rate for the RCRA CVT
 Lead nitrate (Pb(NO3)2)will be spiked to elevate the SVM feed rate for the RCRA CVT
Table 5-2 provides a summary of the planned feed and spiking program for Test Condition 1.
TABLE 5-4
PROPOSED FEED AND SPIKING PROGRAM – CONDITION 2
FEED RATE
FEED ITEMS
A776 – 20 MM INC KCLO4 SPIKE CR POWDER SPIKE PB(NO3)2 SPIKE
Item feed rate 1,260 items/hour
(7 items ev. 20 sec)
1.6 lb/hr
(3, 4.1-g pkg/minute)
3.0 lb/hr
(3, 7.5-g pkg/minute)
3.0 lb/hr
(3, 7.5-g pkg/minute)
CONSTITUENT FEED RATES (LB/HR)
Chlorine feed rate 0.069 0.42 0 0
PM generation rate 37.3 0.87 4.8 2.0
SVM feed rate 0.072 0 0 1.9
LVM feed rate 0 0 3.0 0
Barium feed rate 7.9 0 0 0

February 2024
Page 5-4
5.3 TEST MATERIALS AND QUANTITIES
Table 5-5 summarizes the quantity of materials required to conduct the testing. Triplicate runs will be
carried out for each test condition. Each Condition 1 test run will require approximately 3.5 hours to
complete, while each test run for Condition 2 will require approximately 1.5 hours to complete. An
additional 15 minutes of run time will be required each day to start up the unit and establish the steady
state conditions before the start of the test runs. Providing contingency for one extra test run for each
condition, a total of 16 hours of feed materials are necessary for Condition 1 and 6 hours of feed
materials are necessary for Condition 2.
TABLE 5-5
TEST MATERIAL QUANTITIES
FEED ITEM QUANTITY
PROP HC-25FS 1,920 pounds
A776 - 20-mm INC M96 projectiles 7,560 rounds
Diphenylamine spike 960, 4.1-gram packets
Potassium perchlorate spike 2,040, 4.1-gram packets
Chromium powder spike 1,080, 7.5-gram packets
Lead nitrate spike 1,080, 7.5-gram packets
5.4 TEST SCHEDULE
The sampling effort will require one day for setup and four days for testing. During setup, sampling
equipment and instruments will be prepared and calibrated, supplies will be brought onsite, and
sampling locations will be prepared. Although the onsite activities will dictate the actual timing, a
preliminary schedule is presented in Table 5-6.
TEAD has allowed one-hour to start up the furnace in the morning, and another 15 minutes of run time
to establish the steady state conditions before the start of the test runs. Steady state is defined as a
condition when waste is being fed to the furnace and the afterburner temperature, stack gas velocity,
and CO emissions remain stable with minimal fluctuation. Operating experience has shown that steady
state can be achieved within 15 minutes when targeting normal operating conditions. If there is
significant fluctuation at the end of the 15 minutes, the test will not begin until steady state conditions
are achieved.

February 2024
Page 5-5
TABLE 5-6
TEST SCHEDULE
DAY START STOP ACTIVITY
1 - - - - - - Setup of sampling equipment and pre-test meetings
2 07:30 09:30 Establish steady-state conditions and prepare sampling equipment
09:30 13:00 Condition 1, Run 1
13:00 - - - Recover test run samples and prepare for next run
3 07:30 09:30 Establish steady-state conditions and prepare sampling equipment
09:30 13:00 Condition 1, Run 2
13:00 - - - Recover test run samples and prepare for next run
4 07:30 09:30 Establish steady-state conditions and prepare sampling equipment
09:30 13:00 Condition 1, Run 3
13:00 - - - Recover test run samples and prepare for next run
5 07:30 09:30 Establish steady-state conditions and prepare sampling equipment
09:00 10:30 Condition 2, Run 1
10:30 11:00 Recover test run samples and prepare for next run
11:30 13:00 Condition 2, Run 2
13:00 13:30 Recover test run samples and prepare for next run
13:30 15:00 Condition 2, Run 3
15:00 - - - Recover test run samples and break down sampling equipment

TOOELE ARMY DEPOT

February 2024
Page 6-1
6.0 SAMPLING AND ANALYSIS
Sampling and analysis performed during the test conditions described in Section 5.0 will demonstrate
the performance of the furnace with respect to the HWC NESHAP D/F and RCRA emission standards.
Each test condition will consist of three replicate test runs. For each run, samples will be collected using
procedures described in the QAPP found in Appendix A.
6.1 WASTE SAMPLING AND ANALYSIS
Due to the hazards associated with dissembling munitions and analyzing explosives, samples of the
waste feed item will not be collected during the test program. In lieu of sampling the waste, the feed
item will be characterized using data contained in MIDAS.
6.2 SPIKING MATERIAL SAMPLING AND ANALYSIS
The spiking materials will not be sampled and analyzed during the test. These will be pure materials
purchased for testing. The composition of the materials will be determined from supplier-provided
material safety data sheets or certificates of composition.
6.3 STACK GAS SAMPLING AND ANALYSIS
The stack gas will be sampled for diphenylamine, D/F, SVM, LVM, barium, HCl, and PM and will be
monitored for CO and oxygen during this test program. The following stack sampling methods will be
used:
 USEPA Methods 1, 2, 3A, and 4 for determination of stack sampling traverse points, gas flow rate,
composition, and moisture content during both conditions.
 SW-846 Method 0010 for measurement of diphenylamine during Condition 1.
 SW-846 Method 0023A for measurement of D/F emissions during Condition 1.
 USEPA Method 29 for measurement of SVM, LVM, and barium emissions during Condition 2.
 USEPA Methods 5 and 26A combined for measurement of PM and HCl emissions during Condition 2.
In addition, the facility’s CEMS will be used to measure CO emissions during the test program.
Table 6-1 provides more information on the stack gas samples to be taken, the parameters to be
measured, the frequency of measurement, and the analyses to be conducted. Detailed information on
each method is provided in the QAPP in Appendix A.

February 2024
Page 6-2
TABLE 6-1
STACK GAS SAMPLING AND ANALYSIS PROTOCOL
SAMPLING
METHOD 1
SAMPLING
DURATION
ANALYTICAL
PARAMETER
ANALYTICAL
METHOD 1
USEPA Methods
1, 2, 3A, and 4
Not applicable Traverse points, stack flow,
composition, and moisture
Not applicable
SW-846 Method 0010 180 minutes
(minimum)
Diphenylamine SW-846 Method 8270C
SW-846 Method 0023A 180 minutes
(minimum)
Dioxins and furans SW-846 Methods 0023A and
8290A
USEPA Method 29 60 minutes
(minimum)
Arsenic, barium, beryllium,
cadmium, chromium, and
lead
SW-846 Method 6010C
USEPA Methods 5 and 26A 60 minutes
(minimum)
Particulate matter and
hydrogen chloride
USEPA Methods 5 and 26A
Facility CEMS
(USEPA Performance
Specification 4B)
Continuous Carbon monoxide Facility CEMS
(USEPA Performance
Specification 4B)
Facility CEMS
(USEPA Performance
Specification 4B)
Continuous Oxygen Facility CEMS
(USEPA Performance
Specification 4B)
1 SW-846 refers to Test Methods for Evaluating Solid Waste, Third Edition. USEPA Method refers to New Source Performance Standards,
Test Methods and Procedures, Appendix A, 40 CFR Part 60. USEPA Performance Specification refers to New Source Performance
Standards, Performance Specifications, Appendix B, 40 CFR Part 60.

TOOELE ARMY DEPOT

February 2024
Appendix A
Appendix A:
QUALITY ASSURANCE PROJECT PLAN

840 FIRST AVENUE, SUITE 400 ● KING OF PRUSSIA, PA 19406
610.945.1777 ● WWW.COTERIE-ENV.COM

QUALITY ASSURANCE PROJECT PLAN
FOR HWC NESHAP CONFIRMATORY
PERFORMANCE TEST AND RCRA
COMPLIANCE VERIFICATION TEST

FEBRUARY 2024

US ARMY CORPS OF ENGINEERS
TULSA DISTRICT

TOOELE ARMY DEPOT
TOOELE, UTAH
TOOELE ARMY DEPOT

February 2024

PROJECT TEAM SIGNATURE PAGE
Facility: Tooele Army Depot, Tooele, Utah
Unit ID: APE 1236M2 Deactivation Furnace
Test Title: Confirmatory Performance Test and RCRA Compliance Verification Test
This quality assurance project plan (QAPP) has been developed for the Hazardous Waste Combustor
National Emission Standards for Hazardous Air Pollutants (HWC NESHAP) confirmatory performance test
and Resource Conservation and Recovery Act (RCRA) compliance verification test (CVT) to be conducted
for the Tooele Army Depot (TEAD) Ammunition Peculiar Equipment Model 1236M2 (APE 1236M2)
deactivation furnace. This QAPP has been distributed to and read by the signatories. By signing, the
signatories agree to the appropriate information pertaining to their project responsibilities provided in
the QAPP.

Performance Test Manager
Lonnie Brown
Tooele Army Depot

Date

Project Coordinator
Michele E. Karnes, P.E.
Coterie Environmental LLC
Date

Stack Testing Director
Michael Krall
Montrose Air Quality Services, LLC
Date
Notes: The individuals listed above: 1) have received, read, and agreed to the appropriate information pertaining to their
project responsibilities listed and provided in this QAPP and 2) agree that no testing methods have been modified.

TOOELE ARMY DEPOT

February 2024

LABORATORY SIGNATURE PAGE
Facility: Tooele Army Depot, Tooele, Utah
Unit ID: APE 1236M2 Deactivation Furnace
Test Title: Confirmatory Performance Test and RCRA Compliance Verification Test
This quality assurance project plan (QAPP) has been developed for the Hazardous Air Pollutants (HWC
NESHAP) confirmatory performance test and Resource Conservation and Recovery Act (RCRA)
compliance verification test (CVT) to be conducted for the Tooele Army Depot (TEAD) Ammunition
Peculiar Equipment Model 1236M2 (APE 1236M2) deactivation furnace. This QAPP has been distributed
to and read by the signatories. By signing, the signatories agree to the appropriate information
pertaining to their project responsibilities provided in the QAPP. Laboratory representatives have
reviewed the methods specified in the QAPP and certify that all analytical methods will be performed in
accordance with these requirements, and any deviations will be noted.

Laboratory Project Manager
Courtney Adkins
Eurofins Environment Testing -- Knoxville
Date
Notes: The individuals listed above: 1) have received, read, and agreed to the appropriate information pertaining to their
project responsibilities listed and provided in this QAPP and 2) agree that no testing methods have been modified.

TOOELE ARMY DEPOT

February 2024
Page i
TABLE OF CONTENTS
1.0 Introduction .................................................................................................................................. 1-1
1.1 Facility Overview .............................................................................................................. 1-1
1.3 Confirmatory Performance Test and RCRA CVT Overview .............................................. 1-2
1.4 Quality Assurance Project Plan Organization .................................................................. 1-2
1.5 Document Revision History ............................................................................................. 1-3
2.0 Organization of Personnel, Responsibilities, and Qualifications .................................................. 2-1
2.1 Performance Test Manager ............................................................................................. 2-2
2.2 Project Coordinator ......................................................................................................... 2-2
2.3 Stack Testing Director ...................................................................................................... 2-2
2.4 Laboratory ........................................................................................................................ 2-2
3.0 Sampling Procedures .................................................................................................................... 3-1
3.4 Stack Gas Sampling .......................................................................................................... 3-1
3.4.1 Sampling Point Determination – USEPA Method 1 ............................................ 3-2
3.4.2 Flue Gas Velocity and Volumetric Flow Rate – USEPA Method 2 ....................... 3-3
3.4.3 Flue Gas Composition and Molecular Weight – USEPA Method 3A ................... 3-3
3.4.4 Flue Gas Moisture Content – USEPA Method 4 .................................................. 3-3
3.4.5 Diphenylamine – SW-846 Method 0010............................................................. 3-3
3.4.6 Dioxins and Furans – SW-846 Method 0023A .................................................... 3-4
3.4.7 Semivolatile Metals, Low Volatile Metals, and Barium – USEPA Method 29 ..... 3-6
3.4.8 Particulate Matter and Hydrogen Chloride – USEPA Methods 5 and 26A ......... 3-7
3.4.9 Carbon Monoxide and Oxygen – USEPA Performance Specification 4B ............ 3-8
3.5 Sampling Location ............................................................................................................ 3-9
3.6 Sampling Quality Control Procedures ............................................................................ 3-10
4.0 Sample Handling and Documentation .......................................................................................... 4-1
4.1 Field Sampling Operations ............................................................................................... 4-1
4.2 Field Laboratory Operations ............................................................................................ 4-2
5.0 Analytical Procedures ................................................................................................................... 5-1
6.0 Data Quality Objectives ................................................................................................................ 6-1
6.1 Quality Control Parameters ............................................................................................. 6-1
6.1.1 Precision .............................................................................................................. 6-2
6.1.2 Accuracy .............................................................................................................. 6-3
6.1.3 Representativeness ............................................................................................. 6-3
6.1.4 Comparability ...................................................................................................... 6-3
6.1.5 Completeness ..................................................................................................... 6-4
6.2 Evaluation of Contamination Effects ............................................................................... 6-5
6.3 Performance Audits ......................................................................................................... 6-5
6.4 Corrective Action ............................................................................................................. 6-6
6.4.1 Equipment Failure ............................................................................................... 6-6

February 2024
Page ii
6.4.2 Analytical Deviations ........................................................................................... 6-6
6.4.3 Contamination .................................................................................................... 6-6
6.4.4 Procedural Deviations ......................................................................................... 6-7
7.0 Calibration Procedures and Preventative Maintenance ............................................................... 7-1
7.1 Sampling Equipment ........................................................................................................ 7-1
7.1.1 Pitot Tubes .......................................................................................................... 7-2
7.1.2 Differential Pressure Gauges .............................................................................. 7-3
7.1.3 Digital Temperature Indicator ............................................................................ 7-3
7.1.4 Dry Gas Meter and Orifice .................................................................................. 7-3
7.1.5 Barometer ........................................................................................................... 7-3
7.1.6 Nozzle .................................................................................................................. 7-3
7.1.7 Continuous Emissions Monitors ......................................................................... 7-3
7.2 Analytical Equipment ....................................................................................................... 7-4
7.3 Preventative Maintenance .............................................................................................. 7-5
7.3.1 Sampling Equipment ........................................................................................... 7-5
7.3.2 Analytical Equipment .......................................................................................... 7-6
8.0 Data Reduction, Validation, and Reporting .................................................................................. 8-1
8.1 Data Reduction ................................................................................................................ 8-1
8.2 Data Validation ................................................................................................................ 8-1
8.2.1 Review of Field Documentation .......................................................................... 8-2
8.2.2 Laboratory Review of Data ................................................................................. 8-2
8.2.3 Evaluation of Data Quality .................................................................................. 8-2
8.3 Data Reporting ................................................................................................................. 8-2
8.3.1 Management of Non-Detects ............................................................................. 8-3
8.3.2 Background/Blank Correction ............................................................................. 8-3
8.3.3 Rounding and Significant Figures ........................................................................ 8-3
9.0 Quality Assurance Reports ............................................................................................................ 9-1
10.0 References .................................................................................................................................. 10-1

LIST OF TABLES
Table 1-1 Document Revision History ............................................................................................. 1-3
Table 3-1 Stack Gas Sampling .......................................................................................................... 3-2
Table 4-1 Sample Custody Documentation Requirements.............................................................. 4-1
Table 5-1 Sample Preparation and Analysis Procedures for Stack Gas Samples ............................. 5-1
Table 6-1 Quality Control Objectives for Stack Gas Samples ........................................................... 6-2
Table 6-2 Blank Analysis Objectives for Stack Gas Samples ............................................................ 6-5
Table 7-1 Sampling Equipment Calibration Requirements .............................................................. 7-2
Table 7-2 Analytical Equipment Calibration and Quality Control Checks ........................................ 7-4
Table 7-3 Maintenance Activities For Field Sampling Equipment ................................................... 7-6

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Table 7-4 Maintenance Activities for Analytical Equipment ........................................................... 7-7
LIST OF FIGURES
Figure 2-1 Project Organization ........................................................................................................ 2-3
Figure 3-1 SW-846 Method 0010 Sampling Train ............................................................................. 3-4
Figure 3-2 SW-846 Method 0023A Sampling Train ........................................................................... 3-6
Figure 3-3 USEPA Method 29 Sampling Train ................................................................................... 3-7
Figure 3-4 USEPA Methods 5 and 26A Sampling Train ..................................................................... 3-8
Figure 3-5 Sampling Location ............................................................................................................ 3-9

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February 2024
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1.0 INTRODUCTION
This quality assurance project plan (QAPP) is being submitted by the United States Army (US Army) for
the hazardous waste incinerator located at the Tooele Army Depot (TEAD) in Tooele, Utah. This unit is
designated as the Ammunition Peculiar Equipment Model 1236M2 (APE 1236M2) deactivation furnace.
The APE 1236M2 is subject to the National Emission Standards for Hazardous Air Pollutants (NESHAP)
for Hazardous Waste Combustors (HWCs) codified in Title 40 Code of Federal Regulations (CFR) Part 63
Subpart EEE and the Resource Conservation and Recovery Act (RCRA) requirements provided in the
facility’s RCRA Part B permit. This QAPP describes the quality assurance (QA) and quality control (QC)
program associated with the upcoming HWC NESHAP confirmatory performance test (CfPT) and RCRA
compliance verification test (CVT).
1.1 FACILITY OVERVIEW
The US Army owns and operates the TEAD. The site consists of 23,610 acres, 35 miles west of the Salt
Lake City International Airport. The facility includes over 1,100 storage, production, fabrication, and
administrative buildings. Approximately 500 people are employed at the TEAD. At this time, the TEAD is
considered an area stationary source of hazardous air pollutants (HAPs) as defined in Part A, Section 112
of the Clean Air Act as amended November 15, 1990.
The street address and identification number of the TEAD are:
1 Tooele Army Depot
Tooele, Utah 84074-5000
EPA ID No. UT3213820894
All correspondence should be directed to the following facility contact:
Lonnie Brown
Environmental Engineer
JMTE-BOV, Building 501
1 Tooele Army Depot
Tooele, Utah 84074-5003
1.2 HAZARDOUS WASTE COMBUSTOR OVERVIEW
The US Army owns and operates an APE 1236M2 deactivation furnace at TEAD. The furnace was
designed by the US Army to incinerate and destroy ammunition ranging from small arms through
20-millimeter (mm) rounds, as well as cartridge activated devices (CADs) and propellant activated
devices (PADs). Ammunition larger than 20-mm rounds must be disassembled prior before being fed to
the furnace.

February 2024
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The deactivation furnace consists of a rotary kiln, a cyclone, an afterburner, a high-temperature ceramic
baghouse, an induced draft (ID) fan, and a stack. More information regarding the design and operation
of the furnace can be found in Section 1.2 of the CfPT and RCRA CVT test plan.
1.3 CONFIRMATORY PERFORMANCE TEST AND RCRA CVT OVERVIEW
The CfPT and RCRA CVT are designed to demonstrate compliance with the HWC NESHAP D/F emission
standard and the RCRA performance standards. Two test conditions will be performed:
 Condition 1 will be performed to demonstrate compliance with the HWC NESHAP dioxin and furan
(D/F) emission standard, and the RCRA destruction and removal efficiency (DRE) and carbon
monoxide (CO) standards.
 Condition 2 will be performed to demonstrate compliance with the RCRA particulate matter (PM),
hydrogen chloride (HCl), semivolatile metal (SVM), low volatile metal (LVM), and barium standards.
This test program is being coordinated by Coterie Environmental LLC (Coterie) under the direction of US
Army personnel. Coterie is responsible for the test protocol development and implementation and will
oversee the furnace operations and the stack sampling activities during the test program. Montrose Air
Quality Services, LLC, (MAQS) will perform the stack sampling for the test program. MAQS will be
responsible for all emissions samples collected during the test program, with oversight by Coterie. The
emissions samples will be analyzed by Eurofins Environment Testing (Eurofins) in Knoxville, Tennessee.
1.4 QUALITY ASSURANCE PROJECT PLAN ORGANIZATION
This QAPP has been prepared following the United States Environmental Protection Agency (USEPA)
document entitled Preparation Aids for the Development of Category I Quality Assurance Project Plan.
The QAPP will serve as an essential guidance by which the CfPT and RCRA CVT will be performed. The
QAPP defines all aspects of QA/QC procedures and establishes sampling and analytical quality indicators
that will demonstrate achievement of the test objectives. Additionally, this QAPP defines precision and
accuracy criteria for the required measurements that will be used to demonstrate that all associated
test data is of sufficient quality to demonstrate compliance. The remaining sections of the QAPP provide
the following information:
 Section 2.0 presents information on the project team
 Section 3.0 describes the sampling procedures
 Section 4.0 presents sample handling and documentation information
 Section 5.0 discusses the analytical procedures
 Section 6.0 presents the data quality objectives
 Section 7.0 discusses calibration procedures and preventative maintenance
 Section 8.0 discusses data reduction, validation, and reporting procedures
 Section 9.0 discusses QA reports
 Section 10.0 includes a list of reference documents for the QAPP

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1.5 DOCUMENT REVISION HISTORY
The original version of this QAPP was submitted in February 2024. The nature and date of any future
revisions will be summarized in Table 1-1.
TABLE 1-1
DOCUMENT REVISION HISTORY
REVISION DATE DESCRIPTION OF CHANGES
0 February 2024 Original submittal

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2.0 ORGANIZATION OF PERSONNEL, RESPONSIBILITIES, AND
QUALIFICATIONS
The US Army and their contractors will have specific and unique duties in the implementation of the test
program. The project team duties are summarized below. A project organization flow chart is provided
in Figure 2-1. The contractors selected for this project have established training programs that identify,
ensure, and document that the personnel assigned to their tasks have appropriate knowledge, skills,
training, and certifications to perform their duties. Any key personnel that become unavailable will be
replaced by equally qualified personnel prior to test mobilization. This QAPP will be distributed to key
project personnel for review prior to the test program. These personnel will sign the appropriate QAPP
signature page.
The US Army, through the Performance Test Manager, will:
 Procure and prepare waste feeds.
 Operate the furnace at the designated conditions.
 Report all feed rates and the furnace process parameters.
Coterie, through the Project Coordinator, will:
 Serve as liaison with regulatory agencies and the test team.
 Provide oversight for the project.
 Perform a detailed QA review of all analytical results.
 Prepare the final report.
MAQS, through the Stack Testing Director and stack sampling field team, will:
 Perform stack gas sampling.
 Implement the QA program for the emissions testing and sample analysis.
 Provide custody of all samples generated by the test efforts.
 Transport the samples to the laboratories for analysis.
 Prepare the stack sampling report and supporting documentation.
The laboratory will:
 Perform sample analyses.
 Perform method and QAPP specified QA/QC.
 Provide a complete laboratory report with a detailed case narrative.

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2.1 PERFORMANCE TEST MANAGER
Lonnie Brown will serve as the TEAD Performance Test Manager. Mr. Brown will be responsible for
directing TEAD personnel in the operations of the furnace during the test. He will also ensure that all
necessary unit operating data is collected during the test.
2.2 PROJECT COORDINATOR
Michele Karnes of Coterie will provide coordination and oversight during the test program. Ms. Karnes
will ensure that all test team members communicate throughout the test program and that the
objectives of the CfPT and RCRA CVT plan are met (i.e., test operating conditions, spiking rates, field
sampling objectives). As the Project Coordinator, Ms. Karnes will also ensure that all test program data
is validated and that all deviations are adequately addressed in the appropriate sections of the report.
2.3 STACK TESTING DIRECTOR
Michael Krall of MAQS will serve as the Stack Testing Director for the test program. Mr. Krall will be
responsible for technical supervision of the project, data interpretation, and overall report preparation
and will coordinate with all laboratories and outside service providers. Mr. Krall, or a project manager
who reports to him, will oversee the field crew during the testing, will be responsible for all aspects of
sample collection, and will report any deviations immediately to the Performance Test Manager and
Project Coordinator. The Stack Testing Director may or may not be onsite during the test program.
2.4 LABORATORY
Eurofins will be the subcontracted laboratory. The point of contact for the laboratory will be
Ms. Courtney Adkins. The laboratory is well experienced in conducting analyses per the methods
described in this QAPP. Prior to test execution, the QAPP will be submitted to the laboratory for review
and understanding of their project responsibilities. The laboratory representative will sign the
appropriate QAPP signature page. The laboratory representative will be responsible for ensuring the
laboratory follows all analytical methods specified in the QAPP in accordance with their standard
operating procedure (SOPs), that a detailed case narrative is prepared that addresses all analytical
deviations, and that a complete laboratory report is provided.

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FIGURE 2-1
PROJECT ORGANIZATION
Lines of Responsibility
Double line boxes indicated on-site
responsibilities during testing
Performance Test
Manager
Project
Coordinator
Stack Testing
Director
Stack Sampling
Team Laboratories
Lines of Communication

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3.0 SAMPLING PROCEDURES
This section provides descriptions of the sampling procedures to be used during the CfPT and RCRA CVT.
3.1 WASTE SAMPLING
Due to the hazards associated with disassembling munitions and analyzing explosives, samples of the
waste materials will not be collected during the test program. In lieu of sampling the waste during the
test, characterization data contained in the government's Munitions Items Disposition Action System
(MIDAS) database will be used to determine the concentrations of targeted parameters. The MIDAS
characterizations were developed based upon the military specifications for the ammunition items.
3.2 FUEL OIL SAMPLING
The fuel oil will not be sampled during the test program. A certificate of analysis for the fuel oil is
maintained at the TEAD.
3.3 SPIKING MATERIAL SAMPLING
The spiking material will not be sampled during the test program. This will be pure material purchased
for testing. The suppliers will certify the spiking materials’ compositions with either certificates of
composition or material safety data sheets.
3.4 STACK GAS SAMPLING
The stack gas sampling will follow the methods documented in 40 CFR Part 60 Appendix A (USEPA
Methods) and Test Methods for Evaluating Solid Waste, Physical/Chemical Methods (SW-846 Methods).
Table 3-1 summarizes the sampling methods to be used for collection of stack gas samples. Brief
descriptions of the specified methods are provided in this section. Any modifications to prescribed
USEPA or SW-846 test methods are outlined in the sampling procedure descriptions below.

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TABLE 3-1
STACK GAS SAMPLING
CONDITION(S) PARAMETER SAMPLING METHOD 1 SAMPLE FRACTION(S)
1, 2 Traverse points, gas flow rate,
composition, and moisture
USEPA Methods 1, 2, 3A, and 4 Not applicable
1 Diphenylamine SW-846 Method 0010 Filter
Front-half methanol and
methylene chloride rinse
XAD-2 resin
Impinger contents
Back-half methanol and
methylene chloride rinse
1 Dioxins and furans SW-846 Method 0023A Filter
Front-half acetone, methylene
chloride, and toluene rinse
Back-half acetone, methylene
chloride, and toluene rinse
XAD-2 resin
2 Arsenic, barium, beryllium,
cadmium, chromium, and lead
USEPA Method 29 Filter
Front-half nitric acid rinse
Nitric acid/hydrogen peroxide
impinger contents and rinses
2 Particulate matter and
hydrogen chloride
USEPA Methods 5 and 26A Filter
Front-half acetone rinse
Sulfuric acid impingers contents
and back-half rinses
Sodium hydroxide impingers
contents and rinses
1, 2 Carbon monoxide and oxygen Facility CEMS
(USEPA PS 4B)
Not applicable
1 SW-846 refers to Test Methods for Evaluating Solid Waste, Third Edition. USEPA Method refers to New Source Performance Standards,
Test Methods and Procedures, Appendix A, 40 CFR Part 60. USEPA Performance Specification refers to New Source Performance
Standards, Performance Specifications, Appendix B, 40 CFR Part 60.
As shown in Table 3-1, multiple sampling trains will be operated during each test condition. This will
require careful coordination of the sampling team‘s efforts. During each condition, two isokinetic
sampling trains will be operated simultaneously. Adequate sampling ports are available to support this
simultaneous sampling. Also, during each condition, the gas flow rate, composition, and moisture
content will be determined concurrently with the isokinetic sampling trains.
3.4.1 SAMPLING POINT DETERMINATION – USEPA METHOD 1
The number and location of the stack gas sampling points will be determined according to the
procedures outlined in USEPA Method 1. Verification of absence of cyclonic flow will be conducted prior

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to testing by following the procedure described in USEPA Method 1. The cyclonic flow check will be
performed once for the test project.
3.4.2 FLUE GAS VELOCITY AND VOLUMETRIC FLOW RATE – USEPA METHOD 2
The flue gas velocity and volumetric flow rate will be determined according to the procedures outlined
in USEPA Method 2. Velocity measurements will be made using Type S pitot tubes conforming to the
geometric specifications outlined in USEPA Method 2. Differential pressures will be measured with fluid
manometers. Effluent gas temperatures will be measured with thermocouples equipped with digital
readouts.
3.4.3 FLUE GAS COMPOSITION AND MOLECULAR WEIGHT – USEPA METHOD 3A
The composition of the bulk gas and the gas molecular weight at the stack (concentrations of carbon
dioxide and oxygen) will be determined by USEPA Method 3A. The stack sampling contractor will supply
oxygen and carbon dioxide analyzers and all other associated equipment. The analyzers will be
calibrated according to the procedures outlined in the method. A continuous sample of stack gas will be
withdrawn via a sample probe. The gas will be filtered and passed through a conditioning system for
removal of particulates and moisture prior to being sent to the analyzer.
The calculated molecular weight will be used for all isokinetic calculations. The measured oxygen
concentration will also be used to correct emission concentrations to seven percent oxygen.
3.4.4 FLUE GAS MOISTURE CONTENT – USEPA METHOD 4
The flue gas moisture content will be determined in conjunction with each isokinetic train according to
the sampling and analytical procedures outlined in USEPA Method 4. The impingers will be connected in
series and will contain reagents as described for each sampling method. The impingers will be housed in
an ice bath to ensure condensation of the moisture from the flue gas stream. Any moisture that is not
condensed in the impingers is captured in the silica gel. Moisture content is determined by weighing the
various sample fractions.
3.4.5 DIPHENYLAMINE – SW-846 METHOD 0010
The sampling procedures outlined in SW-846 Method 0010 will be used to determine the diphenylamine
emissions from the stack during Condition 1. The sampling train will consist of a glass or quartz fiber
filter, a coil condenser, a XAD-2 resin cartridge, and a series of impingers. The XAD-2 resin will be
spiked, prior to testing, with the appropriate standards according to the procedures of the test method.
The impinger train will include two impingers each containing 100 milliliters (mL) of deionized water, an
empty impinger, and an impinger containing approximately 200 and 300 grams of silica gel. A
recirculating pump will also be connected to continuously circulate cold water to the condenser and
resin trap to maintain the resin trap temperature below 68 degrees Fahrenheit (°F). A diagram of the
sampling train is presented in Figure 3-1.

February 2024
Page 3-4
All sampling train components will be constructed of materials specified in the method and will be
cleaned and prepared per method specifications prior to testing. The probe and filter temperatures will
be maintained between 248 and 273°F. The sampling runs will be performed within ±10 percent of
isokinetic conditions. A minimum of 105.9 dry standard cubic feet (dscf) of sample gas will be collected
over a minimum of 180 minutes.
Sample recovery procedures will follow those outlined in the test method. Recovery of the SW-846
Method 0010 sampling train will result in the sample fractions listed in Table 3-1. The filter will be
packaged in a Petri dish for shipment, and the XAD-2 resin will be wrapped and shipped in the glass trap.
All rinses will be collected and shipped in amber glass jars.
FIGURE 3-1
SW-846 METHOD 0010 SAMPLING TRAIN

3.4.6 DIOXINS AND FURANS – SW-846 METHOD 0023A
The sampling procedures outlined in SW-846 Method 0023A will be used to determine D/F
concentrations in the stack gas during Condition 1. The sampling train will consist of a glass fiber filter
and coil condenser followed by a XAD-2 resin trap and a series of impingers. A total of five impingers
will be used in the sampling train. The first of these impingers will be empty and will be followed by two

February 2024
Page 3-5
impingers each containing 100 mL of reagent water and another empty impinger. These impingers will
be followed by an impinger containing approximately 200 to 300 grams of silica gel. A recirculating
pump will also be connected to the sampling train to continuously circulate cold water to the condenser
and resin trap in order to maintain the resin trap temperature below 68°F. A diagram of the sampling
train is presented in Figure 3-2.
In preparation for the sampling event, several labeled sampling standards will be introduced inside the
resin to monitor sampling efficiencies as well as to provide insights to the sample preservation and
storage conditions. Upon preparation of the spiked resin traps, a separate fraction of resin from the
same batch will be spiked the same day using the same solutions used in the field sampling modules and
will be refrigerated in the laboratory until the return of the field samples. At such time, the control resin
will become the laboratory method blank.
All sampling train components will be constructed of materials specified in the methods and will be
cleaned and prepared per method specifications prior to testing. The probe and filter temperatures will
be maintained between 223 and 273°F. The sampling runs will be performed within ±10 percent of
isokinetic conditions. A minimum of 88.3 dscf (2.5 dry standard cubic meters (dscm)) of sample gas will
be collected over a minimum of 180 minutes.
The sampling train will be recovered according to the procedures specified in the method. The recovery
of the sampling train will result in the sample fractions listed in Table 3-1. The filter will be shipped in a
Petri dish, and all rinses will be collected in amber glass jars. The XAD-2 resin will be wrapped and
shipped in the glass trap.
The front-half and back-half sample fractions will be spiked with extraction standards. The XAD-2 resin
and front- and back-halves of the sampling train will be analyzed separately for D/F by
SW-846 Methods 0023A and 8290A (high resolution gas chromatograph/high resolution mass
spectroscopy).

February 2024
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FIGURE 3-2
SW-846 METHOD 0023A SAMPLING TRAIN

3.4.7 SEMIVOLATILE METALS, LOW VOLATILE METALS, AND BARIUM – USEPA METHOD 29
The sampling procedures outlined in USEPA Method 29 will be used to determine the concentrations of
arsenic, barium, beryllium, cadmium, chromium, and lead in the stack gas during Condition 2. The
sampling train will consist of a quartz fiber filter followed by a set of three to four impingers. If high
moisture conditions are expected, the first impinger will be an empty knockout impinger. This impinger
is optional and will only be used if necessary. The next two impingers will each contain 100 mL of a five
percent nitric acid (HNO3) and ten percent hydrogen peroxide solution (H2O2) solution. The final
impinger will contain approximately 200 to 300 grams of silica gel. A detailed description of the types of
impingers used in this sampling train can be found in USEPA Method 29. A diagram of the sampling
train is presented in Figure 3-3.
All sampling train components will be constructed of materials specified in the method and will be
cleaned and prepared per method specifications prior to testing. The probe and filter temperatures will
be maintained between 223 and 273°F. The sampling runs will be performed within ±10 percent of
isokinetic conditions. A minimum of 60 dscf of sample gas will be collected over a minimum of
60 minutes.

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Sample recovery procedures will follow those outlined in the test method. The USEPA Method 29
sampling train will produce the sample fractions listed in Table 3-1. The filter will be packaged in a Petri
dish for shipping. All other sample fractions will be collected in glass jars. The filter and front-half rinse
and the contents and rinses from the HNO3/H2O2 impingers will be analyzed for the target metals.
FIGURE 3-3
USEPA METHOD 29 SAMPLING TRAIN

Note: If mercury is not an analyte, the fourth through sixth impingers are not required.
3.4.8 PARTICULATE MATTER AND HYDROGEN CHLORIDE – USEPA METHODS 5 AND 26A
The sampling and analytical procedures outlined in USEPA Methods 5 and 26A will be used to determine
PM and HCl concentrations in the stack gas during Condition 2. The sampling train will consist of a
Teflon mat or quartz fiber filter, one impinger containing 50 mL of 0.1 Normal (N) sulfuric acid (if
necessary due to high moisture conditions), two impingers each containing 100 mL of 0.1 N sulfuric acid,
two impingers each containing 100 mL of 0.1 N sodium hydroxide, and an impinger containing
approximately 200 to 300 grams of silica gel. If deemed necessary based on site-specific conditions
(i.e., expected high HCl concentrations), an additional empty impinger may be placed between the acid
and alkaline impingers to ensure that the HCl and Cl2 fractions are completely isolated. A diagram of the
sampling train is presented in Figure 3-4.

February 2024
Page 3-8
All sampling train components will be constructed of materials specified in the methods and will be
cleaned and prepared per method specifications prior to testing. The probe and filter temperatures will
be maintained between 248 and 273°F. The sampling runs will be performed within ±10 percent of
isokinetic conditions. A minimum of 60 dscf of sample gas will be collected over a minimum of
60 minutes.
Sample recovery procedures will follow those outlined in the test methods. Recovery of the USEPA
Methods 5 and 26A sampling train will result in the sample fractions listed in Table 3-1. For the USEPA
Method 5 portion of the recovery, the filter will be packaged in a Petri dish, and the probe rinse will be
collected in a glass jar. All impinger rinses and contents associated with the USEPA Method 26A
recovery will be collected and shipped in glass jars.
FIGURE 3-4
USEPA METHODS 5 AND 26A SAMPLING TRAIN

Note: If high HCl concentrations are expected, an additional empty impinger may be added between the acid and alkaline impingers.
3.4.9 CARBON MONOXIDE AND OXYGEN – USEPA PERFORMANCE SPECIFICATION 4B
The facility’s continuous emissions monitoring systems (CEMS) will be used to measure the
concentration of CO and oxygen in the stack gas during both conditions.
A continuous sample of stack gas will be withdrawn via a sample probe. The sampled gas will be filtered
and will be passed through a conditioning system for removal of particulates and moisture prior to being

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sent to the analyzer. The CO concentration will be reported in parts per million by volume dry basis
(ppmv dry) corrected to seven percent oxygen.
The HWC NESHAP requires that the CO and oxygen CEMS comply with Performance Specification 4B in
40 CFR Part 60 Appendix B. In addition, the CEMS must be operated and maintained according to a
written QA/QC program that complies with the requirements in the Appendix to the HWC NESHAP.
Performance and calibration of the CEMS during the test program will follow the requirements of the
QA/QC program and the continuous monitoring systems (CMS) performance evaluation test (PET) plan.
3.5 SAMPLING LOCATION
All sampling will be conducted on the APE 1236M2 stack. Figure 3-5 provides a diagram of the sampling
location.
FIGURE 3-5
SAMPLING LOCATION

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3.6 SAMPLING QUALITY CONTROL PROCEDURES
Specific sampling QC procedures will be followed to ensure the production of useful and valid data
throughout the course of this test program.
Prior to the start of testing, all sampling equipment will be thoroughly checked to ensure clean and
operable components and to ensure that no damage occurred during shipping. Once the equipment has
been set up, the manometer used to measure pressure across the pitot tube will be leveled and zeroed,
and the number and location of all sampling traverse points will be checked.
At the start of each test day and throughout the testing, all sample train components will be checked to
ensure that they remain in good condition and continue to operate properly. Electrical components will
be checked for damaged wiring or bad connections. All glassware will be inspected to make sure no
cracks or chips are present.
All sampling trains will be assembled and recovered in a mobile laboratory to ensure a clean
environment, free of uncontrolled dust. To ensure that the sampling trains are free of contamination,
all glassware will remain sealed until assembly of the sampling train.
Pre-test and post-test leak checks will be performed for each sampling train, as required by the
respective test methods. Care will be taken to make sure that all sampling trains are being operated
within the specifications of their respective method.
At the end of testing each day, all sampling equipment will be sealed and covered to protect from
possible contamination and weather damage.

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4.0 SAMPLE HANDLING AND DOCUMENTATION
Sample custody procedures for this program are based on procedures from Handbook: QA/QC
Procedures for Hazardous Waste Incineration (QA/QC Handbook) and Chapter One of SW-846. The
procedures that will be used are discussed below.
4.1 FIELD SAMPLING OPERATIONS
The stack sampling contractor will be responsible for ensuring that custody and sample tracking
documentation procedures are followed for the field sampling and field analytical efforts.
Documentation of all sample collection activities will be recorded on pre-printed data collection forms.
Table 4-1 provides a summary of sample custody documentation requirements.
TABLE 4-1
SAMPLE CUSTODY DOCUMENTATION REQUIREMENTS
CUSTODY DOCUMENT REQUIRED INFORMATION
Sample data forms Sampler’s name or initials
Date and time of sample collection
Sampling technique
Compositing technique (if applicable)
Sample identifier
Sampling location
Chain of custody Unique identifier for each sample shipped
Date and time of sample collection
Sample preservation requirements
Analysis and preparation procedures requested
Signature of individual relinquishing sample custody
Samples will be collected, transported, and stored in clean containers constructed of materials inert to
the analytical matrix, such as glass jars. Only containers that allow airtight seals will be used. Amber
glass will be employed when specified by the method. Sample tracking and custody forms, which
include sample identification and analysis requests, will be enclosed in the sample shipment container.
Upon receipt by the laboratory, information pertaining to the samples will be recorded on the sample
tracking and custody form or an attachment to the form. The laboratory will note the overall condition
of the samples, including the temperature of the samples upon receipt. The laboratory will also note
any discrepancy in the sample identification between the sample labels and the custody forms. The
signature of the person receiving the samples will be provided on the chain of custody (COC).

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If the laboratory notes discrepancies in sample identification labels and forms or suspects issues
concerning sample integrity, the laboratory will contact the Stack Testing Director, who will then contact
the Project Coordinator, as appropriate. In many instances, questions concerning sample labeling can
be rectified through discussions between the Stack Testing Director and the laboratory. Some sample
integrity concerns can be rectified using archived samples. If archive samples are not available, the
sample integrity issues are discussed with the Stack Testing Director and the Project Coordinator, and
appropriate actions are taken, as warranted by the specific issue.
Every record pertaining to sample collection activities, including, but not limited to, stack sampling data
sheets, process sample data sheets, sample tracking forms, sampling equipment calibration forms,
balance calibration forms, and reagent preparation information will be submitted with the report to
provide evidence that the samples were handled properly, taken at the correct time and in the correct
manner, assigned a unique identifier, received intact by the laboratory, and preserved as appropriate.
Adherence to the holding times indicated in Section 5.0, Table 5-1, will be noted in the laboratory
analytical results.
4.2 FIELD LABORATORY OPERATIONS
The stack sampling contractor will provide an onsite laboratory trailer for sample train assembly and
recovery and documentation and recordkeeping activities. Sample tracking documentation, shipping
records, reagent and standards traceability, and all sampling activity records will be maintained in the
laboratory trailer.
Documentation of onsite analytical activities, such as calibration, standards traceability, sample
preparation steps, and raw measurement results will also be maintained onsite.
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5.0 ANALYTICAL PROCEDURES
The analyses used in this test program will follow SW-846 Methods and USEPA Methods as shown in
Table 5-1. The table presents the referenced analytical method, the laboratory performing the analysis,
the extraction and analysis holding time, and if required, the sample preservation and sample
preparation method. Collection of these samples was described in Section 3.0. Note that Table 3-1
specified which samples are to be collected using which methods; Table 5-1 specifies the preparation
and analytical methods to be used to evaluate each sample.
TABLE 5-1
SAMPLE PREPARATION AND ANALYSIS PROCEDURES FOR STACK GAS SAMPLES
PARAMETER ANALYTICAL
METHOD
1,2 LAB PRESERVATIVE
REQUIRED
EXTRACTION
HOLDING
TIME
ANALYSIS
HOLDING
TIME
PREPARATION
METHOD
1,2
Molecular
weight
USEPA
Method 3A
Not applicable Not applicable Not applicable Not applicable Not applicable
Moisture USEPA
Method 4
Not applicable Not applicable Not applicable Not applicable Not applicable
Diphenylamine SW-846
Method 8270C
Eurofins ≤6°C 14 days 40 days
following
extraction
SW-846
Method 3542
Dioxins and
furans
SW-846
Method 8290A
Eurofins ≤6°C in the dark 30 days 45 days
following
extraction
SW-846
Methods
0023A/8290A
Arsenic,
barium,
beryllium,
cadmium,
chromium, and
lead
SW-846
Method 6010C
Eurofins Not applicable Not applicable 180 days USEPA
Method 29
Particulate
matter
USEPA
Method 5
Eurofins Not applicable Not applicable 180 days Not applicable
Hydrogen
chloride
USEPA
Method 26A
Eurofins Not applicable Not applicable 28 days Not applicable
1 SW-846 refers to Test Methods for Evaluating Solid Waste, Third Edition. USEPA Method refers to New Source Performance Standards,
Test Methods and Procedures, Appendix A, 40 CFR Part 60. USEPA Performance Specification refers to New Source Performance
Standards, Performance Specifications, Appendix B, 40 CFR Part 60.
2 All methods will be performed in accordance with the laboratory’s approved SOP.
TOOELE ARMY DEPOT

February 2024
Page 6-1
6.0 DATA QUALITY OBJECTIVES
The purpose of this test program is to demonstrate compliance with the HWC NESHAP D/F standard and
the RCRA performance standards applicable to the furnace. The US Army is committed to ensuring the
data generated during this project are scientifically valid, defensible, complete, and of known precision
and accuracy. These objectives can be best achieved by applying the requirements of USEPA accepted
methodology as well as the more specific recommendations and guidelines for test burns. To ensure
the consistency and adequacy of plans, reports, and overall data quality, guidance from Chapter One of
SW-846 and the QA/QC Handbook has been integrated into the approaches and philosophies of this
QAPP.
Key measures of performance include the objectives for precision, accuracy, representativeness,
completeness, and comparability (commonly referred to as PARCC parameters). This section presents
project-specific data quality objectives for this test program. These objectives represent the level of
data quality that would be considered acceptable for valid decision making, as measured in a manner
that best reflects performance in the actual project matrices. These objectives will be communicated to
the entire project team, including onsite sampling personnel and offsite contract laboratories.
6.1 QUALITY CONTROL PARAMETERS
QC objectives include precision, accuracy, representativeness, comparability, and completeness. Typical
parameters include matrix spike (MS) and MS duplicate (MSD) samples, laboratory control sample (LCS)
and LCS duplicate (LCSD) samples, post digestion spike (PDS) and post digestion spike duplicate (PDSD)
samples, field and sample duplicates, surrogates, standards, and spikes. Table 6-1 provides the project
specific QC procedures for assessing accuracy and precision for critical measurement parameters.
Critical parameters are those that directly relate to the demonstration of regulatory compliance. These
tables list the parameter of analysis, the QC parameter, the QC procedure, the frequency at which
accuracy and precision are determined, and the objective.

February 2024
Page 6-2
TABLE 6-1
QUALITY CONTROL OBJECTIVES FOR STACK GAS SAMPLES
ANALYTICAL
PARAMETERS QC PARAMETER QC PROCEDURE2 FREQUENCY 1 OBJECTIVE 1, 2 CORRECTIVE
ACTON
Diphenylamine Precision LCS duplicate One per
analytical batch
£35% RPD Review results
with laboratory,
re-analyze sample
portion archived
by laboratory if
appropriate
Accuracy Surrogates Every sample 34-121% recovery
LCS Two per
analytical batch
76-128% recovery
Dioxins and
furans
Precision LCS duplicate One per
analytical batch
£50% RPD Review results
with laboratory,
re-analyze sample
portion archived
by laboratory if
appropriate
Accuracy LCS Two per
analytical batch
70-130% recovery
Internal standards
(isotope dilution)
Every sample 40-135% recovery
Surrogate
standards
Every sample 70-130% recovery
Arsenic, barium,
beryllium,
cadmium,
chromium, and
lead
Precision LCS duplicate One per
analytical batch
£25% RPD Review results
with laboratory,
re-analyze sample
portion archived
by laboratory if
appropriate
Accuracy LCS Two per
analytical batch
80-120% recovery
PDS One per analytical
sequence
75-125% recovery
Particulate matter Precision Sample duplicate Front-half
rinse sample
£0.5 mg
difference
Review results
with laboratory,
re-analyze sample
if appropriate
Hydrogen
chloride
Precision MS duplicate One per
analytical batch
£25% RPD Review results
with laboratory,
re-analyze sample
if appropriate Accuracy MS Two per
analytical batch
90-110% recovery
LCS One per
analytical batch
80-120% recovery
1 Unless specified otherwise, the frequency and objective provided for each parameter are based on specifications in the analytical
method.
2 LCS = laboratory control sample. PDS = post-digestion spike. MS = Matrix spike. RPD = relative percent difference
6.1.1 PRECISION
Precision is a measure of the reproducibility of results under a given set of conditions. It is expressed in
terms of the distribution, or scatter, of replicate measurement results, calculated as the relative
standard deviation (RSD) or, for duplicates, as relative percent difference (RPD). RPD and RSD values are
calculated using the following equations:
RPD = |X1 - X2 |
avg X × 100

February 2024
Page 6-3
RSD = STDEV
avg X × 100
Where X1 and X2 represent each of the duplicate results.
6.1.2 ACCURACY
Accuracy is a measure of the difference between an analysis result and the “true” value. Accuracy is
expressed in terms of percent recovery (e.g., for surrogates, spikes, and reference material). Percent
recovery for spiked samples, such as MS samples, is calculated using the following equation:
%Recovery = SSR - SR
SA × 100
Where:
SSR = Spiked sample result
SR = Sample result
SA = Spike added
Percent recovery for other QC parameters, such as LCS, surrogates, and standards, is calculated using
the following equation:
%Recovery = Measured Value
True Value × 100
6.1.3 REPRESENTATIVENESS
Representativeness is defined as the degree to which data accurately and precisely represent a
characteristic of a population, parameter variations at a sampling point, a process condition, or an
environmental condition. An appropriate sampling strategy that addresses collection of representative
samples in time and space is crucial to subsequent decision-making and defensibility of the data. There
are no numerical objectives for representativeness. The selection of suitable locations and sampling
strategies, as described in this QAPP, and adherence to sample collection protocols are the bases for
ensuring representativeness.
6.1.4 COMPARABILITY
Comparability is defined as expressing the confidence with which one data set can be compared to
another. There are no numerical objectives for comparability. A representative sample whose results
are comparable to other data sets is ensured primarily using standard reference sampling and analytical
methods. Reported in common units, the results generated should thus be comparable to those
obtained from other emissions tests and allow for consistent decision-making.

February 2024
Page 6-4
6.1.5 COMPLETENESS
Completeness is defined as “the amount of valid data obtained from a measurement system compared
to the amount that was expected to be obtained under optimal normal conditions.” Completeness can
be defined quantitatively using the following equation:
%Completeness = No. of Valid Data
No. of Data Planned × 100
In the overall project context, the target is 100 percent completeness, which for a valid test condition is
defined as consisting of three valid test runs. A valid test run is one in which sufficient valid data are
presented to make any necessary demonstrations and to enable the permit writer/reviewer to write
appropriate permit conditions or to be confident about demonstration of compliance with a current
permit or regulation.
A run can be valid even though the completeness objective of 100 percent for the data package is not
achieved. Given the possibility of human error (and other unpredictable problems) and the inability of
collecting additional samples after a test is completed, the impact of achieving less than 100 percent
completeness must be assessed in the specific situation, rather than arbitrarily rejecting all the useable
scientific information for the run without such consideration. For example, satisfying the completeness
objective for a single piece of analytical data includes providing documentation that proves the
following:
 An acceptable number of sub-samples were collected and composited
 Compositing procedures were followed
 The sample collection log was completed
 Shipping documents and laboratory instructions were prepared and followed
 The correct analytical procedures were followed
 Any necessary modifications to methodology were documented and justified
 Approved laboratory records were completed
 Proper data reduction procedures were followed
 Analytical instrument printouts were included.
Clearly, the failure of a sampler to note the time a sub-sample was taken (where the previous and
following sample times are noted) has less impact on the validity and acceptability of a data package
than a failure by the laboratory to demonstrate that the analytical instrument was properly calibrated.
Any errors or omissions in a data package will be identified and accompanied by a discussion of the
potential impact on the validity of the data package, the conclusions of the report, and the
demonstration of performance standards for the consideration and approval of the Utah Department of
Environmental Quality (DEQ).

February 2024
Page 6-5
6.2 EVALUATION OF CONTAMINATION EFFECTS
Blanks will be collected throughout the test program to evaluate the effects of contamination on results.
Blank samples of all reagents used in the stack sampling program will be collected. Field blanks will be
collected during the test program if required by the respective method. Method blanks will be prepared
and analyzed by the respective laboratories to evaluate the cleanliness of sample handling and
preparation and overall laboratory practices.
Table 6-2 provides the type and acceptance criteria for each stack gas blank to be analyzed. These
blanks provide critical information on the potential contamination that may occur in test program
samples. The results of blank analyses can prove very useful when attempting to understand anomalies
in data, or generally higher than expected test results.
TABLE 6-2
BLANK ANALYSIS OBJECTIVES FOR STACK GAS SAMPLES
ANALYTICAL PARAMETERS BLANK TYPE FREQUENCY OBJECTIVE
Diphenylamine Field train blank One per test program <Reporting limit
Method blank One per analytical batch <Reporting limit
Reagent blanks One set per test program Archived 1
Dioxins and furans Method blank One per analytical batch <Reporting limit
Reagent blanks One set per test program Archived 1
Arsenic, barium, beryllium,
cadmium, chromium, and
lead
Initial calibration blank Following initial calibration
verification
<Reporting limit
Continuing calibration blank Following continuing
calibration verification
<Reporting limit
Method blank One per analytical batch <Reporting limit
Reagent blanks One set per test program <Reporting limit
Particulate matter Reagent blank One per test program <0.001 percent
Hydrogen chloride Method blank One per analytical batch <Reporting limit
Reagent blanks One set per test program Archived 1
1 The specified reagent blanks will initially be archived. These blanks will only be analyzed if sample contamination is suspected based on
other analytical results.
6.3 PERFORMANCE AUDITS
On September 13, 2010, the USEPA issued a final rule to restructure the stationary source audit
program. The program requires that audit samples be analyzed along with the samples collected while
testing for regulatory compliance. This analysis helps the regulatory agency determine the validity of
compliance test results. The rule requires sources to obtain and use audit samples from accredited
providers. The USEPA has approved the National Environmental Laboratory Accreditation Conference
(NELAC) Institute (TNI) Stationary Source Audit Program to provide accredited audit samples.

February 2024
Page 6-6
The USEPA suspended the audit program on May 28, 2019, due to a lack of sample providers.
Therefore, the US Army will not obtain any audit samples for this test program.
6.4 CORRECTIVE ACTION
During any testing project, simple or complex, there is potential that deviations from data quality
objectives may occur. This section gives corrective action procedures to be used to mitigate such
problems.
6.4.1 EQUIPMENT FAILURE
Any equipment found to be out of calibration or operating improperly will be repaired or replaced
before additional measurements are made. If equipment repair is done onsite, calibrations will be
performed in accordance with the applicable methods prior to use. It may be necessary to transport
equipment offsite for calibration. If calibrations cannot be performed, the equipment will not be used.
If measurements are made with equipment subsequently found to be out of calibration or operating
improperly, a detailed explanation of the cause of the malfunction will be provided. The effect of the
malfunction on the data will be assessed, and the data will be qualified.
6.4.2 ANALYTICAL DEVIATIONS
For analyses where a method QC check sample, such as a method blank, does not meet method
specifications, the problem will be investigated to determine the cause as well as any corrective action
that should be taken. Once the corrective action has been taken, the analysis will be re-examined to
verify that the problem has been eliminated.
In instances of out of specification spikes or calibrations, the samples involved will be re-extracted or
reanalyzed if possible. In those instances where reanalyzing the sample is not possible, corrective
measures will be taken to improve method performance prior to analysis of the next batch of samples.
Results for samples where matrix interferences preclude meeting objectives for recoveries of surrogates
or spikes will be evaluated for potential bias to calculated emission results.
6.4.3 CONTAMINATION
The handling procedures for samples taken during this test program, from blank testing to sample
collection and analysis, are designed to eliminate contamination by limiting their exposure to
contaminants in the ambient air and other outside sources. If levels of contamination are present above
the reporting limits in the analyzed blanks, the archived blank samples will be analyzed. Corrective
action will be taken if the results of the field blanks are significantly different from those of the reagent
blanks or trip blanks. This comparison will indicate whether high levels in the field blank are due to
contamination from exposure to outside sources, contamination of reagent materials or, in the case of
sorbent traps, from degradation of the traps.

February 2024
Page 6-7
6.4.4 PROCEDURAL DEVIATIONS
SOPs for the methods being performed will be available onsite during all testing. The US Army and the
project team will determine an appropriate action in all cases where standard procedures cannot
resolve the problem. The action will be implemented after approval from the representatives of the
DEQ.

TOOELE ARMY DEPOT

February 2024
Page 7-1
7.0 CALIBRATION PROCEDURES AND PREVENTATIVE
MAINTENANCE
This section presents a brief discussion of calibration and routine maintenance procedures to be used
for sampling and analytical equipment. Criteria for analytical calibrations are also included. Calibration
procedures for each analytical method are discussed in detail within the methods.
7.1 SAMPLING EQUIPMENT
All sampling equipment will be provided by the stack sampling contractor. The equipment will be
calibrated prior to arrival onsite and after all testing has been completed. The sampling equipment
calibration requirements and acceptance limits are listed in Table 7-1.
The equipment will be calibrated according to the criteria specified in the reference method being
employed. In addition, the stack sampling contractor will follow the guidelines set forth in the Quality
Assurance Handbook for Air Pollution Measurement Systems, Volume III, Stationary Source Specific
Methods. When these methods are inapplicable, methods such as those prescribed by ASTM
International (ASTM) will be used. Dry gas meters, orifices, nozzles, and pitot tubes are calibrated in
accordance with these documents. The range of the calibration is specified for all environmental
measurements to encompass the range of probable experimental values. This approach ensures all
results are based upon interpolative analyses rather than extrapolative analyses. Calibrations are
designed to include, where practical, at least three measurement points evenly spaced over the range.
This practice minimizes the probability that false assumptions of calibration linearity will be made. In
addition, it is common practice to select, when practical, at least one calibration value that
approximates the levels anticipated in the actual measurement.
Data obtained during calibrations are recorded on standardized forms, which are checked for
completeness and accuracy. Data reduction and subsequent calculations are performed using computer
software. Calculations are checked at least twice for accuracy. Copies of calibration forms will be
included in the test or project reports.

February 2024
Page 7-2
TABLE 7-1
SAMPLING EQUIPMENT CALIBRATION REQUIREMENTS
STACK GAS
PARAMETER
QUALITY
PARAMETER
METHOD OF
DETERMINATION FREQUENCY CRITERIA
Gas flow Pitot tube angle and
dimensions
Calibrated in a wind tunnel
or measurements with a
vernier micrometer and
angle indicator
Pre-test and post-test To specifications in
USEPA Method 2
Barometer Measurements with a NIST
traceable barometer or
calibrated vs. National
Weather Service station
Not applicable Not applicable
Stack gas
thermocouple
Calibrated vs. ASTM
mercury-in-glass
thermometer or NIST
standards
Pre-test and post-test Within 1.5% as °R
Isokinetic
sampling trains
Dry gas meter and
orifice
Calibrated against reference
orifices or against a
reference dry gas meter
Pre-test and post-test 1. Y within 0.05 of
pre-test Y
2. H@ within 0.15 of
pre-test
Probe nozzle Measurements with a
vernier micrometer to
0.001 inches
Pre-test and
post-test 1
Maximum difference
in any two dimensions
within 0.004 inches
Dry gas meter
thermocouples
Calibrated vs. ASTM
mercury-in-glass
thermometer or NIST
standards
Pre-test and post-test Within 1.5% as °R
Trip balance Calibrated vs. standard
weights
Pre-test Within 0.5 grams
Carbon dioxide
and oxygen
analyzers
Analyzer calibration
error test
Checked using USEPA
Protocol 1 calibration gases
Before the test run
and after any failed
system bias or drift
check
±2% of calibration
span
System bias test Checked using USEPA
Protocol 1 calibration gases
Before and after each
test run
±5% of calibration
span
System drift check Checked using USEPA
Protocol 1 calibration gases
After the post-test
system bias test
±3% of calibration
span
Carbon monoxide
analyzer
(Facility CEMS)
Calibration drift
check
Checked using calibration
gases
Daily ±3% of calibration
span
Oxygen analyzer
(Facility CEMS)
Calibration drift
check
Checked using calibration
gases
Daily ±0.5% volume
1 If glass or quartz nozzles are used, only a pre-test calibration will be performed, as the calibration cannot change.
7.1.1 PITOT TUBES
Each pitot tube is inspected in accordance with the geometry standards contained in USEPA Method 2
or calibrated in a wind tunnel. A calibration coefficient is calculated for each pitot tube.

February 2024
Page 7-3
7.1.2 DIFFERENTIAL PRESSURE GAUGES
Fluid manometers do not require calibration other than leak checks. Manometers are leak-checked in
the field prior to each test series and again upon completion of testing.
7.1.3 DIGITAL TEMPERATURE INDICATOR
One digital temperature indicator is used to determine the flue gas temperature, probe temperature,
oven temperature, impinger outlet temperature, and dry gas meter temperature. The digital
temperature indicator is calibrated with a reference thermocouple and potentiometer system that is
calibrated against National Institute of Standards and Technology (NIST) standards or calibrated versus
an ASTM mercury in-glass thermometer. The calibration is acceptable if the agreement is
within ±1.5 percent in degrees Rankine (°R) in the temperature range of 460 to 1,600°R (0 to 1,140°F).
7.1.4 DRY GAS METER AND ORIFICE
A set of calibrated orifices is used to calibrate the dry gas meter and orifice. For the meter orifice, an
orifice calibration factor is calculated using three different sized calibrated orifices. Each calibrated
orifice is measured twice for a total of six measurements. Alternatively, a reference dry gas meter is
used to calibrate the field dry gas meter over a range of five different meter pressures. For the dry gas
meter, the full calibration provides the calibration factor of the dry gas meter.
7.1.5 BAROMETER
The stack sampling contractor uses a purchased factory-calibrated NIST traceable barometer. The
barometer calibrations are good for one year, and the barometer is disposed of when the calibration
expires. Alternatively, the stack sampling contractor personnel will calibrate a barometer prior to arrival
onsite against a National Weather Service station.
7.1.6 NOZZLE
Nozzles will be calibrated onsite using a micrometer. At least three readings will be taken at quarter
turns. The arithmetic average of the values obtained during the calibration is used.
7.1.7 CONTINUOUS EMISSIONS MONITORS
The stack sampling contractor will supply CEMS to measure the concentrations of carbon dioxide and
oxygen in the stack gas. The monitors will be calibrated according to the procedures outlined in the
respective test methods.
The facility’s CEMS will be used to measure the concentrations of CO and oxygen in the stack gas. A
calibration drift check is performed daily as required by the Appendix to HWC NESHAP. A RATA will also
be performed on these CEMS concurrent with the CfPT test runs.

February 2024
Page 7-4
7.2 ANALYTICAL EQUIPMENT
Analytical equipment calibration and QC procedures and internal QC checks are included to ensure
accuracy of the measurements made by laboratory equipment. Table 7-2 provides a summary of the
calibration and QC checks included for each analytical method for this test program.
TABLE 7-2
ANALYTICAL EQUIPMENT CALIBRATION AND QUALITY CONTROL CHECKS
PARAMETER QUALITY
CONTROL CHECK
METHOD OF
DETERMINATION FREQUENCY ACCEPTANCE CRITERIA 1
Diphenylamine Initial calibration Five levels, as per
target list
Initially and as
needed
1. Compounds with linear response
factor, RSD of initial calibration ≤ 15%
2. Compounds with non-linear response
factor, CC or COD ³ 0.99
3. RRFs for SPCCs ≥ 0.050
4. RRF of calibration check compounds
≤30% RSD
Continuing
calibration
Continuing
calibration
verification
Every 12 hours
following tune as
required
1. Response factor for SPCCs:
Same as initial calibration
2. Percent difference of calibration
check compounds RRF from initial
calibration: ≤20%
Consistency in
chromatography
Internal standards Every sample and
standard
1. Retention time relative to daily
standard: ≤30 seconds
2. Area counts relative to
daily standard: 50-200%
Dioxins and
furans
Initial calibration Five high
resolution
concentration
calibration
solutions
Prior to sample
analysis
1. Mean RRF for unlabeled standards:
<20% relative standard deviation
2. Mean RRF for labeled compounds:
<30% relative standard deviation
Calibration
verification
Midlevel standard At the beginning
and end of each
shift
1. Response factors within ±20% of the
initial calibration mean RRF for unlabeled
standards in beginning standard
2. Response factors within ±25% of the
initial calibration mean RRF for unlabeled
standards in ending standard
3. Response factors within ±30% of the
initial calibration mean RRF for labeled
standards in beginning standard
4. Response factors within ±35% of the
initial calibration mean RRF for unlabeled
standards in ending standard

February 2024
Page 7-5
TABLE 7-2 (CONTINUED)
ANALYTICAL EQUIPMENT CALIBRATION AND QUALITY CONTROL CHECKS
PARAMETER QUALITY
CONTROL CHECK
METHOD OF
DETERMINATION FREQUENCY ACCEPTANCE CRITERIA 1
Dioxins and
furans (cont’d)
Retention time
window
verification and
gas
chromatograph
column
performance
Monitor retention
times, verify gas
chromatograph
column
performance
At the beginning
of each shift
Compliance with SW-846 Method 8290A
Arsenic, barium,
beryllium,
cadmium,
chromium, and
lead
Initial calibration Calibration blank
with at least one
standard
Daily before
analysis
Analysis of second calibration standard
±10 % difference
Calibration check Instrument
calibration
verification
Following initial
calibration
±10% difference with RSD <5% from
replicate (minimum of two) integrations
Serial dilution Five-fold dilution
of sample
digestate
1 per batch For samples >50x instrument detection
limit, dilutions must agree within 10%
Interference
check
Interference check
sample A/AB
analysis
Beginning of
sequence
1. <2x reporting limit for applicable
analytes
2. Recovery ±20% (as applicable)
Continuing
calibration
Continuing
calibration
verification
Every 10 samples
and at the end of
the sequence
±10% difference with RSD <5% from
replicate (minimum of two) integrations
Particulate
matter
Calibration check Class S weights Daily ≤0.5 milligrams
Hydrogen
chloride
Initial calibration Four levels Initially and as
needed
r ³ 0.995
Continuing
accuracy check
Instrument
calibration
verification
Following initial
calibration
±10% difference
Continuing
calibration
Midpoint standard Every 10 samples ±10% difference
1 RSD = relative standard deviation. CC = correlation coefficient. COD = coefficient of determination. RRF = relative response factor.
SPCCs = system performance check compounds.
7.3 PREVENTATIVE MAINTENANCE
To ensure the quality and reliability of the data obtained, preventative maintenance is performed on the
sampling and analytical equipment. The following sections outline those procedures.
7.3.1 SAMPLING EQUIPMENT
The potential impact of equipment malfunction on data completeness is minimized through two
complimentary approaches. An in-house equipment maintenance program is part of routine operations.
The maintenance program’s strengths include:

February 2024
Page 7-6
 Availability of personnel experienced in the details of equipment maintenance and fabrication
 Maintenance of an adequate spare parts inventory
 Availability of tools and specialized equipment.
For field equipment, preventive maintenance schedules are developed from historical data. Table 7-3
gives specific maintenance procedures for field equipment. Maintenance schedules for major analytical
instruments (e.g., balances, gas chromatographs) are based on manufacturer’s recommendations.
TABLE 7-3
MAINTENANCE ACTIVITIES FOR FIELD SAMPLING EQUIPMENT
EQUIPMENT MAINTENANCE ACTIVITIES SPARE PARTS
Vacuum system Before and after field program:
1) Check oil and oiler jar
2) Leak check
3) Verify vacuum gauge is functional
Yearly or as needed:
1) Replace valves in pump
Spare fluid
Inclined manometer Before and after each field program:
1) Leak check
2) Check fluid for discoloration or visible matter
Yearly or as needed:
1) Disassemble and clean
2) Replace fluid
Spare fluid, O-rings
Dry gas meter Before and after each field program:
1) Check meter dial for erratic rotation
Every 3 months:
1) Remove panels and check for excessive oil or corrosion
2) Disassemble and clean
None
Nozzles Before and after each test:
1) Verify no dents, corrosion, or other damage
2) Glass or quartz nozzles, check for chips and cracks
Spare nozzles
Diaphragm pump Before and after each test:
1) Leak check, change diaphragm if needed
None
Miscellaneous Check for availability of spare parts Fuses, fittings, thermocouples,
thermocouple wire, variable
transformers.
7.3.2 ANALYTICAL EQUIPMENT
In addition to including QC checks in the analysis of test program samples, the laboratories also perform
regular inspection and maintenance of the laboratory equipment. Table 7-4 lists some of the routine
maintenance procedures associated with the analytical equipment to be used in this test program.

February 2024
Page 7-7
TABLE 7-4
MAINTENANCE ACTIVITIES FOR ANALYTICAL EQUIPMENT
PARAMETER EQUIPMENT MAINTENANCE PROCEDURES
Diphenylamine Gas chromatograph/
mass spectroscopy
1. Redo tune
2. Replace filament(s)
Dioxins and furans High resolution gas
chromatograph/high
resolution mass
spectroscopy
1. Change rotary pump oil
2. Clean beam center/focus stack and outer source
3. Clean ion volume
4. Change source slit
Arsenic, barium,
beryllium, cadmium,
chromium, and lead
Inductively coupled
plasma
1. Check gases, vacuum pump and cooling water, nebulizer, capillary
tubing, peristaltic pump, high voltage switch, exhaust screens and torch,
glassware and aerosol injector tube
2. Clean plasma torch, nebulizer, and filters
3. Replace pump tubing
4. Clean and lubricate sampler arm
5. Clean power unit and coolant water filters
Hydrogen chloride Ion chromatograph 1. Check pump and gas pressure
2. Check all lines for crimping leaks and discoloration
TOOELE ARMY DEPOT

February 2024
Page 8-1
8.0 DATA REDUCTION, VALIDATION, AND REPORTING
This section presents the approaches to be used to reduce, validate, and report measurement data.
With respect to the test program, a quality team of companies and laboratories will be working together
to ensure the success of this project. The team will make certain that:
 All raw data packages are paginated and assigned a unique project number. Each project number
will reflect the type of analyses performed.
 The data packages contain a case narrative, sample description information, sample receipt
information, COC documentation, and summary report. All associated QA/QC results, run/batch
data, instrument calibration data, sample extraction/preparation logs, and chromatograms, etc. will
be included in the final laboratory report. The report will also contain a list of validation qualifiers.
 These data are assigned to a specific appendix in the stack sampling report for easy reference and
data review.
8.1 DATA REDUCTION
The methods referenced in this QAPP for field measurements and lab analyses are standard methods
and are routinely used for such measurements and analysis. Data reduction procedures will follow the
specific calculations presented in the reference methods.
Extreme care will be exercised to ensure hand-recorded data are written accurately and legibly.
Additionally, prepared and formatted data recording forms will be required for all data collection. This
is an important aid to verify that all necessary data items are recorded. The collected field and
laboratory data will be reviewed for correctness and completeness.
The stack sampling contractor will reduce and validate the sampling and field measurement data that
are collected. The sampling data will include flow measurements, calibrations, etc. Each laboratory will
reduce all analytical results prior to submission. The analytical data will be used to determine
concentrations and emission rates of the compounds of interest. The way the derived quantities will be
reported is discussed in Section 8.3.
8.2 DATA VALIDATION
Validation demonstrates that a process, item, data set, or service satisfies the requirements defined by
the user. For this program, review and evaluation of documents and records will be performed to assess
the validity of samples collected, methodologies used, and data reported. This review comprises three
parts: review of field documentation, review of laboratory data reports, and evaluation of data quality.
The Project Coordinator will have overall responsibility for data validation.

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The sampling and analytical methods for this program have been selected because of their accepted
validity for these types of applications. Adherence to the accepted methods, as described in this QAPP,
is the first criterion for validation. The effectiveness of the analytical methods as applied to this study
will be evaluated based on project-specific quality indicators, such as audit samples, replicate samples,
and matrix and surrogate spikes.
8.2.1 REVIEW OF FIELD DOCUMENTATION
Sample validation is intended to ensure that the samples collected are representative of the population
under study. Criteria for acceptance include positive identification, documentation of sample shipment,
preservation and storage, and documentation demonstrating adherence to sample collection protocols
and QC checks. As part of the review of field documentation, field data sheets will be checked for
completeness, correctness, and consistency.
8.2.2 LABORATORY REVIEW OF DATA
Laboratory raw data packages will include the following information:
 A table of contents for the raw data; and
 Numbered pages, correlating to the table of contents.
The representative from each laboratory will approve all data results. The representative’s signature
will be included in the report. This signature will indicate that all QA/QC expectations were met. If
expectations were not met, the discrepancies will be explained in the laboratory case narrative. The
laboratory representatives will discuss the QA/QC issues and include the impact of these issues on the
data results in the case narrative.
8.2.3 EVALUATION OF DATA QUALITY
Under the direction of the Project Coordinator, the project team will review and evaluate the reported
data. Data quality will be assessed. Review of the laboratory reports will result in an evaluation of the
following parameters:
 Holding time for samples from date of collection to date of preparation and/or analysis
 Sample storage conditions during the holding period prior to analysis
 Tuning and calibration of instruments
 PARCC parameter results and acceptance criteria
 Blank sample analysis results.
8.3 DATA REPORTING
The CfPT and RCRA CVT report will be submitted to the DEQ within 90 days of completing the testing, or
an extension will be requested. Both electronic and hard copies of the report will be provided.

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All data will be reported in the appropriate units as applicable to the sample stream and the method of
analysis. Emission results will be reported on a concentration and mass emission basis to allow
comparison to the HWC NESHAP and RCRA performance standards.
Specific procedures will be followed when reporting test results. This section describes the conventions
for detection limits, blank correction, and the use of significant figures.
8.3.1 MANAGEMENT OF NON-DETECTS
There are several specific situations that will arise in which calculations will need to be performed, but
the analytical results are non-detects (at some level). Contracted laboratories are requested to achieve
the lowest detection limits possible for each of the methods included in this QAPP. All detection limits
shall be defined in the laboratory reports. No data results shall be reported as “ND” without a defined
numerical value provided as the detection limit.
The procedures for handling non-detects will be communicated to each laboratory and the stack
sampling contractor. When dealing with detection limits and non-detect data, the following guidelines
will be used:
 Reporting limits (RLs), method detection limits (MDLs), reliable detection limits (RDLs), or estimated
detection limits (EDLs) will be used to report stack gas analytical data, as appropriate.
 For DRE calculations, a non-detect in the stack gas will be treated as the MDL.
 For D/F emissions results, the SW-846 Method 0023A train will be operated for a minimum of three
hours during each test run, and all non-detects will be assumed to be present at zero concentration,
in accordance with 40 CFR § 63.1208(b)(1)(iii).
 Any results that use non-detects will be reported as maxima (i.e., with a less-than sign – “<”).
8.3.2 BACKGROUND/BLANK CORRECTION
Some of the methods specified for use in this test program allow background or blank correction. Every
effort will be made to use reagents and sampling media of the highest quality to ensure no
contamination is indicated in any of the blank samples. If background contamination is found, any
background or blank correction will be carefully documented, and all calculations (e.g., emission rates)
will be developed using both corrected and uncorrected data. All corrections will be performed
according to the applicable method.
8.3.3 ROUNDING AND SIGNIFICANT FIGURES
Observational results will be made with as many significant figures as possible. Rounding will be
deferred until all resultant calculations have been made. The following rules will be applied in rounding
data:
 When the digit after the one to be rounded is less than five, the one to be rounded is left
unchanged; and

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 When the digit after the one to be rounded is greater than or equal to five, the one to be rounded is
increased by one.
Intermediate results will be presented in the final report at an appropriate level of significance
(i.e., rounded), although the derived, or resultant, calculations will be based on unrounded intermediate
data. Consequently, it may not be possible to precisely reconstruct the resultant calculations on any
table from the rounded intermediate results due to rounding errors.
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9.0 QUALITY ASSURANCE REPORTS
Activities affecting data quality will be reviewed by the project team daily in the field, and as appropriate
during non-field efforts. This will allow assessment of the overall effectiveness of the QAPP. These
reviews will include the following:
 Summary of key QA activities, stressing measures that are being taken to ensure adherence to the
QAPP
 Description of problems observed that may impact data quality and corrective actions taken
 Status of sample shipment and integrity at time of receipt and progress of sample analysis
 Assessment of the QC data gathered over that time period
 Any changes in QA organizational activities and personnel
 Results of internal or external assessments and the plan for correcting identified deficiencies, if any.
The testing program will have multiple tiers of QA/QC reviews. The specific laboratory performing the
analysis will review the data for which they are responsible, and the laboratory project manager will sign
the analytical data reports. Any QA/QC anomalies will be discussed in the case narrative. The Project
Coordinator will also review the laboratory data package to discuss how the QA/QC anomalies may
impact the emissions calculations. Any data that is determined to be invalid will be stated in the final
report, and the impact of the invalid data on the test program will be assessed. Through this multiple
tier process, all stages of the testing program will be tracked, monitored, reviewed, and documented.
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10.0 REFERENCES
ASTM. Annual Book of ASTM Standards, latest annual edition.
USEPA. 1994. Quality Assurance Handbook for Air Pollution Measurement Systems, Volume III,
Stationary Source Specific Methods. Office of Research and Development. EPA/600/R-94/038C.
USEPA. February 1991. Preparation Aids for the Development of Category I Quality Assurance Project
Plan. Office of Research and Development. EPA/600/8-91/003.
USEPA. 1990. Handbook: QA/QC Procedures for Hazardous Waste Incineration. Office of Research and
Development. EPA/625/6-89/023.
USEPA. November 1986 and updates. Test Methods for Evaluating Solid Wastes, Physical/Chemical
Methods. USEPA 530/ SW-846.
USEPA. National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors,
40 CFR Part 63, Subpart EEE, September 30, 1999, and as amended through March 20, 2023.
USEPA. New Source Performance Standards, Test Methods and Procedures, Appendix A, 40 CFR Part 60.
USEPA. New Source Performance Standards, Performance Specifications, Appendix B, 40 CFR Part 60.

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Appendix B
Appendix B:
CONTINUOUS MONITORING SYSTEMS PERFORMANCE
EVALUATION TEST PLAN
a

840 FIRST AVENUE, SUITE 400 ● KING OF PRUSSIA, PA 19406
610.945.1777 ● WWW.COTERIE-ENV.COM

HWC NESHAP
CONTINUOUS MONITORING SYSTEMS
PERFORMANCE EVALUATION TEST PLAN

FEBRUARY 2024

US ARMY CORPS OF ENGINEERS
TULSA DISTRICT

TOOELE ARMY DEPOT
TOOELE, UTAH
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Page i
TABLE OF CONTENTS
1.0 Introduction .................................................................................................................................. 1-1
1.1 Facility Overview .............................................................................................................. 1-1
1.2 Hazardous Waste Combustor System Overview ............................................................. 1-1
1.3 Regulatory Overview........................................................................................................ 1-2
1.4 Continuous Monitoring Systems Overview ..................................................................... 1-2
1.5 Continuous Emissions Monitoring Systems Overview ..................................................... 1-3
1.6 Plan Purpose and Scope ................................................................................................... 1-3
2.0 Continuous Process Monitoring Systems ..................................................................................... 2-1
2.1 Total Hazardous Waste Feed Rate ................................................................................... 2-1
2.2 Afterburner Temperature ................................................................................................ 2-2
2.3 Baghouse Inlet Temperature ........................................................................................... 2-2
2.4 Stack Gas Velocity ............................................................................................................ 2-2
3.0 Continuous Emissions Monitoring Systems .................................................................................. 3-1
4.0 Internal Quality Assurance Program ............................................................................................. 4-1
4.1 Installation Checks ........................................................................................................... 4-1
4.2 Operational Checks .......................................................................................................... 4-1
4.3 Calibration Checks ........................................................................................................... 4-1
4.4 Internal Quality Assurance Program Schedule ................................................................ 4-2
5.0 External Quality Assurance Program ............................................................................................ 5-1
5.1 Test Personnel ................................................................................................................. 5-1
5.2 Reduction of Test Data .................................................................................................... 5-1
5.3 Validation of Test Results ................................................................................................ 5-1
5.4 Reporting of Test Results ................................................................................................. 5-1

LIST OF TABLES
Table 1-1 Monitoring Requirements ............................................................................................... 1-3
Table 2-1 Summary of Continuous Monitoring Systems Equipment .............................................. 2-1
LIST OF ATTACHMENTS
Attachment A: Example CMS PET Checklists
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1.0 INTRODUCTION
The United States Army (US Army) is submitting this continuous monitoring systems (CMS) performance
evaluation test (PET) plan in accordance with Title 40 Code of Federal Regulations (CFR) Part 63
Section 1207(e)(1). This test plan describes the CMS PET that the US Army will conduct for the
Ammunition Peculiar Equipment Model 1236M2 (APE 1236M2) deactivation furnace at their Tooele,
Utah, facility. The furnace is regulated under 40 CFR Part 63 Subpart EEE, the National Emission
Standards for Hazardous Air Pollutants (NESHAP) for Hazardous Waste Combustors (HWCs).
1.1 FACILITY OVERVIEW
The US Army owns and operates the Tooele Army Depot (TEAD). The site consists of 23,610 acres and is
located 35 miles west of the Salt Lake City International Airport. The facility includes over 1,100 storage,
production, fabrication, and administrative buildings. Approximately 500 people are employed at TEAD.
At this time, TEAD is considered an area source of hazardous air pollutants (HAPs) as defined in Part A,
Section 112 of the Clean Air Act as amended November 15, 1990.
The street address of TEAD is:
1 Tooele Army Depot
Tooele, Utah 84074-5000
EPA ID No. UT3213820894
All correspondence should be directed to the facility contact at the following address and telephone
number:
Mr. Lonnie Brown
JMTE-BOV
1 Tooele Army Depot
Tooele, Utah 84074-5000
[phone]
1.2 HAZARDOUS WASTE COMBUSTOR SYSTEM OVERVIEW
The US Army owns and operates an APE 1236M2 deactivation furnace at TEAD. The furnace was
designed by the US Army to incinerate and destroy ammunition ranging from small arms through
20-millimeter (mm) rounds, as well as cartridge activated devices (CADs) and propellant activated
devices (PADs), all of which contain propellant, explosive, and pyrotechnic (PEP) materials. Ammunition
larger than 20-mm rounds must be sectioned or disassembled prior to feeding into the furnace.

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The APE 1236M2 furnace consists of a rotary kiln, a cyclone, an afterburner, a high-temperature ceramic
baghouse, an induced draft (ID) fan, and a stack. Feed materials for the furnace are loaded into a push-
off box located in the feed room. From this push-off box, the materials travel on a feed conveyor into a
barricaded area, where they drop through a feed chute into the rotary kiln. The flue gases exiting the
kiln pass through a cyclone for the removal of sparks and then an afterburner, which is designed to heat
the combustion gases and to provide destruction of organics. Following the afterburner, the flue gases
pass through stainless steel ductwork to a high temperature ceramic baghouse and then the exhaust
stack. An ID fan, located downstream of the baghouse, provides the motive force for the flue gases as
they move through the incineration system.
1.3 REGULATORY OVERVIEW
On September 30, 1999, the U.S. Environmental Protection Agency (USEPA) promulgated the HWC
NESHAP under joint authority of the Clean Air Act Amendments of 1990 and the Resource Conservation
and Recovery Act (RCRA). The HWC NESHAP is codified in 40 CFR Part 63 Subpart EEE. Originally, the
HWC NESHAP regulated emissions from three equipment categories: hazardous waste incinerators,
cement kilns, and lightweight aggregate kilns. These sources are referred to as Phase I sources. On
October 12, 2005, USEPA amended Subpart EEE to include Final Replacement Standards for Phase I
sources and to incorporate standards for Phase II sources (i.e., liquid fuel-fired boilers, solid fuel-fired
boilers, and hydrochloric acid production furnaces that burn hazardous waste). The HWC NESHAP limits
emissions from both new and existing facilities in each equipment category. The standards, which are
based upon the maximum achievable control technology (MACT), regulate emissions of dioxin/furan
(D/F), mercury, total chlorine (HCl/Cl2), semivolatile metals – lead and cadmium (SVM), low volatile
metals – arsenic, beryllium, and chromium (LVM), particulate matter (PM), carbon monoxide (CO), and
hydrocarbons (HC) from both new and existing sources.
HWC NESHAP requires facilities to continuously monitor both process operations and emissions to
ensure that the HWC is operating in compliance with the standards at all times. 40 CFR § 63.1209(b)(1)
requires that CMS be used to document compliance with the applicable HWC NESHAP operating
parameter limits (OPLs). The performance of these CMS must be evaluated in conjunction with each
comprehensive or confirmatory performance test. This evaluation is referred to as the CMS PET.
Facilities must document the protocol for each CMS PET in a CMS PET plan and must submit the plan for
review and approval along with their performance test plan.
1.4 CONTINUOUS MONITORING SYSTEMS OVERVIEW
The HWC NESHAP specifies the operating parameters that must be monitored for the APE 1236M2
deactivation furnace. For this test program, the CMS of interest are those required to demonstrate
compliance with the D/F emission standard in 40 CFR § 63.1209(k). A summary of these operating
parameters is provided in Table 1-1 along with a description of the CMS used to determine and/or
calculate the parameter’s value.

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TABLE 1-1
MONITORING REQUIREMENTS
OPERATING PARAMETER MEASUREMENT METHOD
Total hazardous waste feed rate (as PEP feed rate) Platform scale and weigh scale module
Afterburner temperature Thermocouple and thermocouple meter
Baghouse inlet temperature Thermocouple and thermocouple meter
Stack gas velocity Stack gas mass flow transmitter
1.5 CONTINUOUS EMISSIONS MONITORING SYSTEMS OVERVIEW
In addition to monitoring process parameters, facilities are also required by 40 CFR § 63.1209(a) to
continuously monitor the CO or HC concentrations in the HWC’s stack gas to demonstrate compliance
with the CO and HC standards. Additionally, facilities must use an oxygen continuous emissions
monitoring system (CEMS) to continuously correct the reported CO or HC concentrations to seven
percent oxygen. These analyzers must comply with the quality assurance (QA) procedures for CEMS
contained in the Appendix to the HWC NESHAP and in Performance Specifications 4B (CO and oxygen)
and 8A (HC) contained in 40 CFR Part 60 Appendix B.
The US Army has elected to continuously monitor CO concentrations in the system exhaust gas. The
collected readings are continuously corrected to seven percent oxygen using measurements of the stack
gas oxygen concentration. Each of these measurements is collected using the CEMS described in
Section 3.
1.6 PLAN PURPOSE AND SCOPE
The US Army has prepared this CMS PET plan following the regulations codified in 40 CFR § 63.1207.
With this CMS PET, the US Army will demonstrate that the CMS used to demonstrate compliance with
the HWC NESHAP D/F standard are operating in compliance with the standards presented in the HWC
NESHAP and in the NESHAP General Provisions contained in 40 CFR §§ 63.1 through 63.15. More
specifically, the US Army will, in accordance with 40 CFR §§ 63.8(c)(2) and (c)(3), demonstrate that all
CMS used to comply with the D/F standard are installed such that they can obtain representative
measurements of the process or emissions parameter. This will include verification of proper
installation, operation, and calibration of each CMS used to demonstrate compliance with the D/F
emission standard.
This CMS PET plan includes both an internal and external QA program, as required by 40 CFR
§ 63.8(e)(3). The internal QA program specifies the procedures that will be used to verify correct
installation, calibration, and operation of each CMS device prior to the confirmatory performance test
(CfPT). The external QA program provides information on data validation and documentation measures
for the CMS PET.

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The remaining sections of this plan are organized as follows:
 Section 2.0 provides a detailed description of the CMS.
 Section 3.0 provides a detailed description of the CEMS.
 Section 4.0 provides a summary of the CMS performance evaluations that will be conducted
(internal QA program) and presents a schedule for the CMS PET.
 Section 5.0 provides information on the data validation and reporting procedures (external QA
program).
 Attachment A provides detailed procedures and recording forms for the CMS PET.
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2.0 CONTINUOUS PROCESS MONITORING SYSTEMS
Section 1209 of the HWC NESHAP requires facilities to use CMS to document compliance with the
required OPLs. These CMS must sample regulated operating parameters without interruption and must
evaluate the detector response at least once every 15 seconds. For each regulated operating
parameter, one-minute averages (OMAs) must be calculated, and the appropriate rolling average must
then be calculated from the OMAs.
A summary of the CMS employed to meet the D/F monitoring requirements for the furnace is provided
in Table 2-1. A description of each of these CMS is provided in the sections that follow. Due to the use
of spare parts or replacement monitors, the actual manufacturer or model number of the CMS used at
the facility may differ from that described in this plan. However, should this occur, the replacement
instruments will perform equivocally to those described herein.
TABLE 2-1
SUMMARY OF CONTINUOUS MONITORING SYSTEMS EQUIPMENT
MEASURED PARAMETER TAG
NUMBER
INSTRUMENT
DESCRIPTION
PROGRAMMED
SPAN
CALIBRATION
ACCURACY
Total hazardous waste feed
rate (as PEP feed rate)
HourlyFeedRate Waste feed scale 0 – 50 lb ± 2% of span
Afterburner temperature AfterBurnerTemp Thermocouple 0 – 2,200°F ± 2% of span
Baghouse inlet
temperature
BaghouseInletTemp Thermocouple 0 – 2,200°F ± 2% of span
Stack gas velocity StackVelocity Thermal mass
flow meter
0 – 100 fps ± 5% of span
2.1 TOTAL HAZARDOUS WASTE FEED RATE
The total hazardous waste feed rate must be continuously monitored per 40 CFR § 63.1209(k)(4) to
demonstrate compliance with the D/F standard. The US Army monitors and complies with a limit on the
total feed rate of PEP to the incinerator to satisfy this requirement. Although permitted to be an hourly
rolling average (HRA) limit under the HWC NESHAP, TEAD complies with the PEP feed rate limit at all
times, limiting the feed of any item to be below the permitted feed rate limit.
The PEP feed rate is determined from the waste composition and the weight of each charge. The weight
of each charge of munitions is measured using a Hardy Instruments Model HI 4050-PM-DC-EIP-N2-N3
waste feed scale. The weight measurements are used in conjunction with the waste composition data
to determine the total PEP feed rate. Table 2-1 provides the programmed range and calibration

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accuracy for this device. Calibrations on the scale are performed weekly following site-specific and
manufacturer recommended procedures.
2.2 AFTERBURNER TEMPERATURE
The temperature of each combustion chamber must be continuously monitored per 40 CFR §
63.1209(a)(7), (j)(1), and (k)(2) to demonstrate compliance with the D/F standard. The continuous
measurements must be used to calculate OMAs, and an HRA must be calculated from the OMAs. The
HRA values are compared to the OPL to demonstrate compliance with the HWC NESHAP. The US Army
measures the temperature of the afterburner to comply with this requirement.
The afterburner temperature is measured in degrees Fahrenheit (°F) using a Wilcon Industries Type K
thermocouple. Table 2-1 provides the programmed range and calibration accuracy for the device. The
thermocouple is connected to a PLC thermocouple input card. The thermocouple is calibrated annually
in accordance with 40 CFR § 63.1209(b)(2)(i).
2.3 BAGHOUSE INLET TEMPERATURE
The temperature at the inlet to the initial PM control device must be continuously monitored per 40 CFR
§ 63.1209(k)(1) to demonstrate compliance with the D/F standard. The continuous measurements must
be used to calculate OMAs, and an HRA must be calculated from the OMAs. The HRA values are
compared to the OPL for the baghouse inlet temperature to demonstrate compliance with the HWC
NESHAP.
The gas temperature at the inlet to the baghouse is measured in °F using a Wilcon Industries Type K
thermocouple. Table 2-1 provides the programmed range and calibration accuracy for the device. The
thermocouple is connected to a PLC thermocouple input card. The thermocouple is calibrated annually
in accordance with 40 CFR § 63.1209(b)(2)(i).
2.4 STACK GAS VELOCITY
The flue gas flow rate or device production rate, or another appropriate surrogate for gas residence
time, must be continuously monitored per 40 CFR § 63.1209(k)(3) to demonstrate compliance with the
D/F standard. The US Army monitors the stack gas velocity to satisfy this requirement. The continuous
measurements must be used to calculate OMAs, and an HRA must be calculated from the OMAs.
The stack gas velocity is measured in feet per second (fps) using a Kurz thermal mass flow meter.
Table 2-1 provides the programmed range and calibration accuracy for the device. The flow meter is
calibrated annually following manufacturer recommended procedures.

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3.0 CONTINUOUS EMISSIONS MONITORING SYSTEMS
The stack gas CO or HC concentrations must be continuously monitored with a CEMS to satisfy the
requirements of 40 CFR § 63.1209(a) and to demonstrate compliance with the CO and HC standards.
The continuously measured values must be corrected to seven percent oxygen using measurements of
the stack gas oxygen concentration that are also collected using a CEMS.
The US Army monitors CO and oxygen concentrations in the incinerator exhaust stack to comply with
these requirements. HWC NESHAP requires that the CO and oxygen CEMS comply with Performance
Specification 4B in 40 CFR Part 60 Appendix B. These CEMS must also be configured as follows:
 CO CEMS: A minimum of two ranges, with span values of zero to 200 parts per million by volume
(ppmv) for the low range, and zero to 3,000 ppmv for the high range.
 CO CEMS: Anytime a reading of the CO monitor exceeds 3,000 ppmv, the CEMS must record the
value as 10,000 ppmv, unless the monitor is configured with three spans and the third span ranges
from zero to 10,000 ppmv.
 Oxygen CEMS: A single range with a span value of zero to 25 percent oxygen by volume on a dry
basis.
The US Army monitors CO concentrations in the stack gas using a Horiba infrared analyzer, configured
with dual range spans of zero to 200 ppmv, and zero to 3,000 ppmv. Stack gas oxygen concentrations
are measured using a Horiba paramagnetic analyzer. The analyzer is configured for a span of zero to
25 percent oxygen by volume on a dry basis, consistent with HWC NESHAP requirements.
The analyzers themselves are not mounted directly on the stack. Instead, samples of stack gas are
extracted through a sample probe and are relayed via a sample pump through heated sample transfer
lines and a sample conditioning unit down to the analyzers, which are housed in an environmentally
controlled shelter. All elements of the sample extraction, transfer, and conditioning system satisfy the
applicable installation and measurement requirements in Performance Specification 4B.
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4.0 INTERNAL QUALITY ASSURANCE PROGRAM
40 CFR § 63.8(e)(3) requires that the CMS PET plan include an internal QA program that specifies the
procedures that will be used to conduct the CMS PET. Additionally, the CMS PET plan must provide a
schedule for the program’s implementation. This section provides an overview of the required program
and the anticipated test schedule. Details on the internal QA program activities are provided on the
CMS PET checklists in Attachment A.
4.1 INSTALLATION CHECKS
During the CMS PET, installation checks will be performed on each of the HWC NESHAP required CMS to
verify that they are installed in accordance with manufacturer recommendations and plant internal
standards. The checklists in Attachment A provide the installation checks that will be performed for
each CMS. Examples of the installation checks include verifying proper orientation of the CMS, checking
the electrical wiring, and looking for evidence of corrosion or excessive buildup.
4.2 OPERATIONAL CHECKS
Operational checks will also be performed on each of the CMS to verify that they are operating properly.
The operational checks specific to each CMS are detailed on the CMS PET checklists in Attachment A.
These operational checks will vary depending upon the diagnostic capabilities of the instrument. For
those CMS equipped with internal diagnostic test routines, the US Army will activate the routine, if
necessary, and will review the instrument display for error codes after the diagnostic test is complete.
Absent such a diagnostic routine, the US Army will simply observe the CMS during normal unit operation
and will confirm that changes are registered with known changes in process conditions.
For the CEMS, a relative accuracy test audit (RATA) will be conducted following the procedures
described in Performance Specification 4B of 40 CFR Part 60 Appendix B. A protocol for the RATA will be
provided under separate cover.
4.3 CALIBRATION CHECKS
In addition to verifying proper installation and operation of each CMS, the US Army will also check the
calibration of each CMS during the CMS PET. The US Army will perform complete calibrations of the
CMS if the calibration checks indicate the potential for an unacceptable amount of bias in the
instrument readings. The checklists in Attachment A provide information on the instrument-specific
calibration procedures.
For the CEMS, the US Army will assess the daily calibration and zero drift of each CEMS. During the daily
calibration check, the stack gas sample stream is temporarily turned off and calibration gases are
injected into each analyzer. A zero-level calibration gas is used to test the baseline response of each

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CEMS. A span gas is then used to test the response of the instrument at the high end of its range. This
assessment is performed automatically each day by the CEMS and will continue during the CMS PET.
Should any adjustments to the CEMS be required, they will be performed manually by the US Army
following site-specific and manufacturer recommended procedures.
4.4 INTERNAL QUALITY ASSURANCE PROGRAM SCHEDULE
The activities designated for the internal QA program will require careful planning and substantial time
to complete. In fact, in some cases, it may be necessary to shutdown the furnace in order to complete
the CMS PET activities. To ensure completion prior to the CfPT, the US Army will perform the CMS PET
in the month prior to the CfPT. All tasks will be initiated no later than two weeks prior to the CfPT to
allow time for corrective actions to be implemented in the event that any installation, calibration, or
operational check is not successful.
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5.0 EXTERNAL QUALITY ASSURANCE PROGRAM
The external QA program required by 40 CFR § 63.8(e)(3)(i) and (ii) includes those procedures utilized to
validate the data collected during the CMS PET and to document the CMS PET activities. The primary
goal of the external QA program is proper collection and organization of test data followed by clear and
concise reporting of the test results. Details on the external QA program for this CMS PET are provided
in this section.
5.1 TEST PERSONNEL
The CMS PET activities described in this test plan will be performed by facility instrumentation staff or
qualified contractors. The personnel involved in each program element will be documented on the CMS
PET checklists in Attachment A or will be detailed in the contractor’s test logs and report.
5.2 REDUCTION OF TEST DATA
The data collected during the CMS PET will be compiled following test completion and will be included in
the CMS PET report. Extreme care will be exercised by test personnel to ensure that all manually
recorded data are written accurately and legibly. To help increase the quality and uniformity of the test
data, all CMS PET activities will be documented on pre-printed data recording forms. Examples of these
checklists are provided in Attachment A.
5.3 VALIDATION OF TEST RESULTS
After the CMS PET is performed, the facility will review the data recorded by the test personnel. When
evaluating the data, the facility will make sure that the specified procedures were followed, the
necessary forms were completed, and the results of each CMS installation, operation, and calibration
check were successful.
5.4 REPORTING OF TEST RESULTS
The results of the CMS PET will be compiled and will be summarized in the CMS PET report, which will be
prepared by a qualified contractor. The CMS PET report will provide the result of each CMS installation,
operation, and calibration check, and will also include, as an appendix, the completed CMS PET
checklists and/or contractor test report. The CMS PET report will be submitted as an appendix to the
CfPT report.
TOOELE ARMY DEPOT

February 2024
Attachment A
Attachment A:
EXAMPLE CMS PET CHECKLISTS

February 2024
Attachment A
CMS PET CHECKLIST
INSTRUMENT TAG MEASURED PARAMETER DEVICE TYPE CMS PET COMPLETED?
HourlyFeedRate Total hazardous waste feed
rate
Platform scale and weigh
scale module

AfterburnerTemp Afterburner temperature Thermocouple
BaghouseInletTemp Baghouse inlet temperature Thermocouple
StackVelocity Stack gas velocity Thermal mass flow meter
COCorrectedForO2 Stack CO concentration Non-dispersive infrared
analyzer

Oxygen Stack oxygen concentration Paramagnetic analyzer

February 2024
Attachment A
CMS PET CHECKLIST FOR
HAZARDOUS WASTE PLATFORM SCALE AND WEIGH SCALE MODULE
TAG NUMBER HOURLYFEEDRATE
INSTALLATION CHECK
TASK DATE COMPLETED COMMENTS
Review specifications for environmental
conditions in the Hardy Operation and
Installation Manuals and make certain that the
operating conditions for the scale meet these
requirements.

Check the area around the scale and make sure
there is not a build-up of debris on, around, or
under the scale.

Verify that the load cells are properly installed
and confirm that nothing is binding the load cell
or in contact with the cell that may prevent 100
percent of the applied load from passing
through the load cell.

Confirm that the platform scale has all rubber
boots or strips installed per the Operation and
Installation Manual.

Verify that the scale is properly leveled.
Examine the cable connections to make sure
that the cable is not pinched and is clear of the
feet, cover, and overload stops.

Make sure that all electrical wiring conforms to
appropriate plant and manufacturer
recommended practices.

OPERATIONAL CHECK
TASK DATE COMPLETED COMMENTS
Initiate an instrument self-test, check for
displayed error codes, and complete repairs or
maintenance as needed.

CALIBRATION CHECK
TASK DATE COMPLETED COMMENTS
Check the weigh scale system calibration
following the hard calibration method provided
in the Hardy Operation and Installation Manual.

*Note: Installation and operational checks should be conducted prior to instrument calibration.

COMPLETED BY:

February 2024
Attachment A
CMS PET CHECKLIST FOR
AFTERBURNER THERMOCOUPLE
TAG NUMBER AFTERBURNERTEMP
INSTALLATION CHECK
TASK DATE COMPLETED COMMENTS
Verify that the thermocouple input connections
are made correctly and are firmly secured.

OPERATIONAL CHECK
TASK DATE COMPLETED COMMENTS
Verify that the temperature reported by the
thermocouple responds to known changes in
temperature.

CALIBRATION CHECK
TASK DATE COMPLETED COMMENTS
Check the thermocouple calibration against a
reference thermocouple. The reference
thermocouple will be pre-calibrated using NIST
traceable mercury-filled thermometers.

* Note: Installation and operational checks should be conducted prior to instrument calibration.

COMPLETED BY:

February 2024
Attachment A
CMS PET CHECKLIST FOR
BAGHOUSE INLET TEMPERATURE THERMOCOUPLE
TAG NUMBER BAGHOUSEINLETTEMP
INSTALLATION CHECK
TASK DATE COMPLETED COMMENTS
Verify that the thermocouple input connections
are made correctly and are firmly secured.

OPERATIONAL CHECK
TASK DATE COMPLETED COMMENTS
Verify that the temperature reported by the
thermocouple responds to known changes in
temperature.

CALIBRATION CHECK
TASK DATE COMPLETED COMMENTS
Check the thermocouple calibration against a
reference thermocouple. The reference
thermocouple will be pre-calibrated using NIST
traceable mercury-filled thermometers.

*Note: Installation and operational checks should be conducted prior to instrument calibration.

COMPLETED BY:

February 2024
Attachment A
CMS PET CHECKLIST FOR
STACK GAS MASS FLOW METER
TAG NUMBER STACKVELOCITY
INSTALLATION CHECK
TASK DATE COMPLETED COMMENTS
Make sure that the transmitter is mounted such
that the flow arrow points in the same direction
as the stack gas flow.

Confirm that grounding practices comply with
recommendations provided in the Kurz User’s
Manual.

Make sure that all electrical wiring conforms to
appropriate plant and manufacturer
recommended practices.

Make certain that the power supply meets the
specifications provided in the User’s Manual.

OPERATIONAL CHECK
TASK DATE COMPLETED COMMENTS
Initiate an instrument self-test, check for
displayed error codes, and complete repairs or
maintenance as needed.

CALIBRATION CHECK
TASK DATE COMPLETED COMMENTS
Compare the readings on the flowmeter to
those obtained by a stack tester during a flow
RATA using USEPA Method 2.

* Note: Installation and operational checks should be conducted prior to instrument calibration.

COMPLETED BY:

February 2024
Attachment A
CMS PET CHECKLIST FOR
STACK GAS CARBON MONOXIDE CONCENTRATION
INFRARED ANALYZER
TAG NUMBER COCORRECTEDFORO2
INSTALLATION CHECK
TASK DATE COMPLETED COMMENTS
Check the physical mounting and operating
environment of the analyzer and make sure that
they conform to appropriate manufacturer
specifications.

Make certain that the analyzer is not installed
near equipment that may emit electromagnetic
interference (EMI) or, if it is, that proper
precautions are taken to ensure that the EMI
does not affect the operation of the instrument.

Check all tubing and joints and filters, making
sure that they are clean and free from excessive
buildup.

Make sure that the calibration gases are
properly connected to the unit, the supply lines
are pressurized, and regulators are set to the
proper pressure.

Confirm that the sample gas flow rate to the
analyzer is within the range recommended by
the manufacturer.

Make sure that all electrical wiring conforms to
appropriate plant and manufacturer
recommended practices.

OPERATIONAL CHECK
TASK DATE COMPLETED COMMENTS
Conduct a relative accuracy test audit.
CALIBRATION CHECK
TASK DATE COMPLETED COMMENTS
Review daily calibration drift test results.
Perform adjustments as necessary.

*Note: Installation and operational checks should be conducted prior to instrument calibration.

COMPLETED BY:

February 2024
Attachment A
CMS PET CHECKLIST FOR
STACK GAS OXYGEN CONCENTRATION
PARAMAGNETIC ANALYZER
TAG NUMBER OXYGEN
INSTALLATION CHECK
TASK DATE COMPLETED COMMENTS
Check the physical mounting and operating
environment of the analyzer and make sure that
they conform to appropriate manufacturer
specifications.

Make certain that the analyzer is not installed
near equipment that may emit electromagnetic
interference (EMI) or, if it is, that proper
precautions are taken to ensure that the EMI
does not affect the operation of the instrument.

Check all tubing and joints and filters, making
sure that they are clean and free from excessive
buildup.

Make sure that the calibration gases are
properly connected to the unit, the supply lines
are pressurized, and regulators are set to the
proper pressure.

Confirm that the sample gas flow rate to the
analyzer is within the range recommended by
the manufacturer.

Make sure that all electrical wiring conforms to
appropriate plant and manufacturer
recommended practices.

OPERATIONAL CHECK
TASK DATE COMPLETED COMMENTS
Conduct a relative accuracy test audit.
CALIBRATION CHECK
TASK DATE COMPLETED COMMENTS
Review daily calibration drift test results.
Perform adjustments as necessary.

*Note: Installation and operational checks should be conducted prior to instrument calibration.

COMPLETED BY:

TOOELE ARMY DEPOT

February 2024
Appendix B
Appendix C: SOURCE TEST PLAN FOR RELATIVE ACCURACY
TEST AUDIT AND PROCESS CONTROL
EQUIPMENT AUDITS

Source Test Plan for the 2024 Relative Accuracy
Test Audit and Process Control Equipment Audits
Building 1320 Deactivation Furnace, APE 1236M2
US Army Material Command
Tooele Army Depot
1 Tooele Army Depot
Tooele, Utah 84074
Prepared For:
Coterie Environmental, LLC
1150 First Avenue, Suite 501
King of Prussia, Pennsylvania 19406
Prepared By:
Montrose Air Quality Services, LLC
990 West 43rd Avenue
Denver, Colorado 80211
For Submission To:
Utah Division of Air Quality
195 N 1950 W
Salt Lake City, Utah 84114
Document Number: GP043AS-036949-PP-796
Proposed Test Date: May 6th and 7th, 2024
Submittal Date: February 2nd, 2024

Coterie Environmental, LLC
2024 Building 1320 Deactivation Furnace CEMS RATA Source Test Protocol
Tooele Army Depot

Review and Certification
I certify that, to the best of my knowledge, the information contained in this document is
complete and accurate and conforms to the requirements of the Montrose Quality
Management System and ASTM D7036-04.
Signature: Date: February 2, 2024
Name: Timothy Wojtach Title: Account Manager

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Coterie Environmental, LLC
2024 Building 1320 Deactivation Furnace CEMS RATA Source Test Protocol
Tooele Army Depot

Table of Contents
Section Page
1.0 Introduction ........................................................................................................ 5
1.1 Summary of Test Program ............................................................................. 5
1.2 Applicable Regulations and Emission Limits ...................................................... 7
1.3 Key Personnel .............................................................................................. 8
2.0 Plant and Sampling Location Descriptions................................................................ 9
2.1 Process Description, Operation, and Control Equipment ..................................... 9
2.2 CEMS Description ......................................................................................... 9
2.3 CMS/Instrument Description ........................................................................ 10
2.4 Flue Gas Sampling Location ......................................................................... 10
2.5 Operating Conditions and Process Data ......................................................... 11
2.6 Plant Safety ............................................................................................... 12
2.6.1 Safety Responsibilities ........................................................................ 12
2.6.2 Safety Program and Requirements ....................................................... 13
3.0 Sampling and Analytical Procedures ..................................................................... 14
3.1 Test Methods ............................................................................................. 14
3.1.1 EPA Method 1 .................................................................................... 14
3.1.2 EPA Method 2 .................................................................................... 14
3.1.3 EPA Methods 3A and 10 ...................................................................... 15
3.1.4 EPA Method 4 .................................................................................... 16
3.1.5 EPA Performance Specification 4B ........................................................ 17
3.1.6 Waste Feed Scale Audit ...................................................................... 17
3.1.7 Pressure Sensor Audits ....................................................................... 17
3.1.8 Temperature Sensor Audits ................................................................. 17
3.2 Process Test Methods .................................................................................. 18
4.0 Quality Assurance and Reporting .......................................................................... 19
4.1 QA Audits .................................................................................................. 19
4.2 Quality Control Procedures .......................................................................... 19
4.2.1 Equipment Inspection and Maintenance ................................................ 19
4.2.2 Audit Samples ................................................................................... 19
4.3 Data Analysis and Validation ........................................................................ 19
4.4 Sample Identification and Custody ................................................................ 20
4.5 Quality Statement ...................................................................................... 20
4.6 Reporting .................................................................................................. 20
4.6.1 Example Report Format ...................................................................... 20
4.6.2 Example Presentation of Test Results ................................................... 21
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Coterie Environmental, LLC
2024 Building 1320 Deactivation Furnace CEMS RATA Source Test Protocol
Tooele Army Depot

List of Appendices
A Supporting Information ...................................................................................... 23
A.1 Units and Abbreviations.............................................................................. 24
A.2 Accreditation Information/Certifications ........................................................ 32
“S” Field Work Safety Plan ....................................................................................... 34
List of Tables
1-1 Summary of Test Program and Proposed Schedule .................................................. 6
1-2 Summary of Part 60 RA Requirements .................................................................... 7
1-3 Test Personnel and Responsibilities ....................................................................... 8
2-1 CEMS Information ............................................................................................... 9
2-2 CMS Information ............................................................................................... 10
2-3 Sampling Location ............................................................................................. 11
4-1 Example RATA Results ....................................................................................... 22
List of Figures
3-1 US EPA Methods 2 and 4 Sampling Trai ............................................................... 15
3-2 US EPA Methods 3A and 10 Sampling Train .......................................................... 16
4-1 Typical Report Format ....................................................................................... 21

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Coterie Environmental, LLC
2024 Building 1320 Deactivation Furnace CEMS RATA Source Test Protocol
Tooele Army Depot

1.0 Introduction
1.1 Summary of Test Program
Coterie Environmental, LLC contracted Montrose Air Quality Services, LLC (Montrose) to
perform a CEMS RATA on the Building 1320 Deactivation Furnace, APE 1236M2 at the US
Army Material Command at the Tooele Army Depot facility located in Tooele, Utah.
The tests will be conducted to determine compliance with the RA requirements listed in
Appendix B of 40 CFR 60.
The specific objectives are to:
 Determine the RA for the gas velocity and O2 and CO CEMS used to monitor
the gas stream at the Deactivation Furnace
 Determine the CD for the CEMS1
 Evaluate the accuracy of the sensors used to measure the pressure at three
(3) points in the process
 Evaluate the accuracy of the sensors used to measure the temperature at six
(6) points in the process
 Evaluate the accuracy of the scale used to measure the hourly waste feed
rate
 Conduct the test program with a focus on safety
Montrose will provide the test personnel and the necessary equipment to measure emissions
as outlined in this test plan. Facility personnel will provide the process and production data
to be included in the final report. A summary of the test program and proposed schedule is
presented in Table 1-1.

1 Data for the CD will be provided by Coterie Environmental, LLC/Tooele Army Depot
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Coterie Environmental, LLC
2024 Building 1320 Deactivation Furnace CEMS RATA Source Test Protocol
Tooele Army Depot

Table 1-1
Summary of Test Program and Proposed Schedule

Test Date Source Name Activity/Parameters Test Methods
No. of
Runs
Duration
(Minutes)
May 6, 2024
Kiln Feed End

Baghouse
(Differential)

Enclosure Draft

Baghouse Inlet

Baghouse
Outlet

Kiln Feed End

Kiln Burner End

Afterburner
Pressure Audit

Pressure Audit

Pressure Audit

Temperature Audit

Temperature Audit

Temperature Audit

Temperature Audit

Temperature Audit
Direct
Comparison to
Reference
Manometer for
Pressure Audit

Direct
Comparison to
Reference
Temperature
Sensor for
Temperature
Audits
NA NA
Waste Feed
Scale Mass Audit
Direct
Comparison to
Certified
Weight Set
NA NA
May 7 and 8,
2024
Bldg 1320
Deactivation
Furnace
Gas Volumetric Flow
Rate (temperature
and velocity)

O2

CO

EPA 1, 2, 3A, 4

EPA 3A

EPA 3A, 10

21

21

21

To simplify this test plan, a list of Units and Abbreviations is included in Appendix A.
Throughout this test plan, chemical nomenclature, acronyms, and reporting units are not
defined. Please refer to the list for specific details.

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9-12
9-12
9-12

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2024 Building 1320 Deactivation Furnace CEMS RATA Source Test Protocol
Tooele Army Depot

1.2 Applicable Regulations and Emission Limits
The results from this test program are presented in units consistent with those listed in the
applicable regulations or requirements. The reporting units and emission limits are
presented in Table 1-2.
Table 1-2
Summary of Part 60 RA Requirements
Parameter/Units
Regulatory
Reference Allowable
Part 60
Oxygen (O2) 2
% volume dry PS-4B ≤ 20.0% of RM or ≤ 1.0% O2
Gas Velocity
ft/s PS-6 ≤ 20% of RM or ≤ 10% of AS
Carbon Monoxide (CO)2
ppmvd @ 7% O2 PS-4B ≤ 10% of RM or ≤ 5% of AS or
|dm| +CC ≤ 5 ppmvd CO

2 As referenced in 40 CFR Part 63, Subpart EEE, Appendix A, Sections 5.1 and 6.1.
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2024 Building 1320 Deactivation Furnace CEMS RATA Source Test Protocol
Tooele Army Depot

1.3 Key Personnel
A list of project participants is included below:

Facility Information
Source Location: US Army Material Command
Tooele Army Depot
1 Tooele Army Depot
Tooele, Utah 84074
Project Contact: Michele E. (Gehring) Karnes, P.E. Lonnie Brown
Role: Principal Environmental Engineer
Company: Coterie Environmental, LLC Tooele Army Depot
Telephone: [phone]
Email: [e-mail] [e-mail]

Agency Information
Regulatory Agency: Utah Division of Air Quality
Telephone: [phone]

Testing Company Information
Testing Firm: Montrose Air Quality Services, LLC
Contact: Timothy Wojtach
Title: Account Manager
Telephone: [phone]
Email: [e-mail]

Test personnel and observers are summarized in Table 1-3.
Table 1-3
Test Personnel and Responsibilities
Role Primary Assignment Additional Responsibilities
Account Manager Coordinate Project Post-test follow up
Field Project Manager Operate mobile lab Facility interface, test crew coordination
Field Technician Execute stack platform
responsibilities Preparation, support PM

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2024 Building 1320 Deactivation Furnace CEMS RATA Source Test Protocol
Tooele Army Depot

2.0 Plant and Sampling Location Descriptions
2.1 Process Description, Operation, and Control
Equipment
The US Army owns and operates the APE 1236M2 at the TEAD. The furnace was designed
by the US Army to incinerate and destroy ammunition ranging from small arms through
20-millimeter (mm) rounds. Ammunition larger than 20-mm rounds must be sectioned or
disassembled prior to feeding into the APE 1236M2. The system burns waste munitions that
contain propellant, explosive, and pyrotechnic (PEP) materials. The APE 1236M2 consists of
a rotary kiln, a cyclone, an afterburner, a high-temperature ceramic baghouse, an induced
draft (ID) fan, and a stack.
2.2 CEMS Description
The CEMS analyzers are presented in Table 2-1.
Table 2-1
CEMS Information
Analyzer Type Manufacturer Model No. Serial No. Range
CO Analyzer Horiba GI-749L U6RDT828 0-200 ppmvd
0-3,000 ppmvd
O2 Analyzer Horiba GI-749L U6RDT828 0-25% vd

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Coterie Environmental, LLC
2024 Building 1320 Deactivation Furnace CEMS RATA Source Test Protocol
Tooele Army Depot

2.3 CMS/Instrument Description
The CEMS analyzers are presented in Table 2-2.
Table 2-2
CMS Information
Analyzer
Type
Measurement
Device Manufacturer Model No. Range
Stack Gas
Flow
Insertion Mass
Flow Meter
Series 454FTB
Kurz 756054F32D4A000M01A
015B0537 0-100 ft/s
Baghouse
Differential
Pressure
Pressure
transmitter Foxboro IDP10-D22A11F-M1B1 0 – 30 in. H2O
Rotary Kiln
Feed End
Pressure
Pressure
transmitter Foxboro IGP20-D12A11FM1B1 -2 – 2 in. H2O
Enclosure
Pressure Magnahelic Dwyer 605-00N -2.0 - 0.05 in. H2O
Baghouse
Inlet
Temperature
Thermocouple United Electric MI1573KGPF14L11.5 0 – 2,200°F
Baghouse
Outlet
Temperature
Thermocouple United Electric MI1573KGPF14L11.5 0 – 2,200°F
Rotary Kiln
Feed End
Temperature
Thermocouple United Electric MI1573KGPF14L11.5 0 – 2,200°F
Rotary Kiln
Burner End
Temperature
Thermocouple United Electric MI1573KGPF14L11.5 0 – 2,200°F
Afterburner
Temperature Thermocouple United Electric MI1573KGPF14L11.5 0 – 2,200°F
Stack
Temperature
Insertion Mass
Flow Meter
Series 454FTB
Kurz 756054F32D4A000M01A
015B0537 0 – 1,200°F
Hourly Waste
Feed Rate
Waste Feed
Scale
Hardy
Instruments HI 4050-PM-DC-EIP-N2-N3 0 – 50 lb

2.4 Flue Gas Sampling Location
Actual stack measurements, number of traverse points, and location of traverse points will
be evaluated in the field as part of the test program. Table 2-2 presents the anticipated
stack measurements and traverse points for the sampling locations listed.
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2024 Building 1320 Deactivation Furnace CEMS RATA Source Test Protocol
Tooele Army Depot

Table 2-2
Sampling Location
Sampling
Location
Stack Inside
Diameter
(in.)
Distance from Nearest Disturbance
Anticipated Number
of Traverse Points
Downstream EPA
“B” (in./dia.)
Upstream EPA
“A” (in./dia.)
APE 1236M2
Exhaust Stack 19.5 102/5.2 300/15.4 Velocity: 16 (8/port)
Gaseous: 3
The sample location is verified in the field to conform to EPA Method 1. Gaseous pollutant
traverse points are located at 16.7, 50.0 and 83.3 percent of the stack inside diameter from
the stack wall per PS-4B. See Appendix A.1 for more information.
2.5 Operating Conditions and Process Data
Emission tests are to be performed while the source/units and air pollution control devices
were operating at the conditions required. The unit will be tested when operating at greater
than 50% of the maximum rated capacity of PEP.
Plant personnel are responsible for establishing the test conditions and collecting all
applicable unit-operating data. Data to be collected includes the following parameters:
 O2 CEMS, %
 CO CEMS, ppmvd and ppmvd @7% O2
 Stack gas velocity, ft/s
 PEP Feed rate, lb/hr

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Coterie Environmental, LLC
2024 Building 1320 Deactivation Furnace CEMS RATA Source Test Protocol
Tooele Army Depot

2.6 Plant Safety
Montrose will comply with all safety requirements at the facility. The facility Client Sponsor,
or designated point of contact, is responsible for ensuring routine compliance with plant
entry, health, and safety requirements. The Client Sponsor has the authority to impose or
waive facility restrictions. The Montrose test team leader has the authority to negotiate any
deviations from the facility restrictions with the Client Sponsor. Any deviations must be
documented.
2.6.1 Safety Responsibilities
Planning
 Montrose must complete a field review with the Client Sponsor prior to the
project date. The purpose of the review is to develop a scope of work that
identifies the conditions, equipment, methods, and physical locations that will
be utilized along with any policies or procedures that will affect our work
 We must reach an agreement on the proper use of client emergency services
and ensure that proper response personnel are available, as needed
 The potential for chemical exposure and actions to be taken in case of
exposure must be communicated to Montrose. This information must include
expected concentrations of the chemicals and the equipment used to identify
the substances.
 Montrose will provide a list of equipment being brought to the site, if required
by the client
Project Day
 Montrose personnel will arrive with the appropriate training and credentials
for the activities they will be performing and the equipment that they will
operate
 Our team will meet daily to review the Project Scope, Job Hazard Assessment,
and Work Permits. The Client Sponsor and Operations Team are invited to
participate.
 Montrose will provide equipment that can interface with the client utilities
previously identified in the planning phase and only work with equipment that
our client has made ready and prepared for connection
 We will follow client direction regarding driving safety, safe work permitting,
staging of equipment, and other crafts or work in the area
 As per 40 CFR Part 60 Subpart A, Section 60.8, the facility must provide the
following provisions at each sample location:
o Sampling ports, which meet EPA minimum requirements for testing. The
caps should be removed or be hand-tight.
o Safe sampling platforms
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2024 Building 1320 Deactivation Furnace CEMS RATA Source Test Protocol
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o Safe access to the platforms and test ports, including any scaffolding or
man lifts
o Sufficient utilities to perform all necessary testing
 Montrose will use the client communication system, as directed, in case of
plant or project emergency
 Any adverse conditions, unplanned shutdowns or other deviations to the
agreed scope and project plan must be reviewed with the Client Sponsor prior
to continuing work. This will include any safe work permit and hazard
assessment updates.
Completion
 Montrose personnel will report any process concerns, incidents or near misses
to the Client Sponsor prior to leaving the site
 Montrose will clean up our work area to the same condition as it was prior to
our arrival
 We will ensure that all utilities, connection points or equipment have been
returned to the pre-project condition or as stated in the safe work permit. In
addition, we will walk out the job completion with Operations and the Client
Sponsor if required by the facility.
2.6.2 Safety Program and Requirements
Montrose has a comprehensive health and safety program that satisfies State and Federal
OSHA requirements. The program includes an Illness and Injury Prevention Program, site-
specific safety meetings, and training in safety awareness and procedures. The basic
elements include:
 All regulatory required policies/procedures and training for OSHA, EPA and
FMCSA
 Medical monitoring, as necessary
 Use of Personal Protective Equipment (PPE) and chemical detection equipment
 Hazard communication
 Pre-test and daily toolbox meetings
 Continued evaluation of work and potential hazards
 Near-miss and incident reporting procedures as required by Montrose and the
Client
Montrose will provide standard PPE to employees. The PPE will include but is not limited to;
hard hats, safety shoes, glasses with side shields or goggles, hearing protection, hand
protections, and fall protection. In addition, our trailers are equipped with four gas detectors
to ensure that workspace has no unexpected equipment leaks or other ambient hazards.
The detailed Site Safety Plan for this project is attached to this test plan in Appendix “S”.
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2024 Building 1320 Deactivation Furnace CEMS RATA Source Test Protocol
Tooele Army Depot

3.0 Sampling and Analytical Procedures
3.1 Test Methods
The test methods for this test program have been presented in Table 1-1. Additional
information regarding specific applications or modifications to standard procedures is
presented below.
3.1.1 EPA Method 1, Sample and Velocity Traverses for Stationary
SourcesEPA Method 1 is used to assure that representative measurements of
volumetric flow rate are obtained by dividing the cross-section of the stack or duct
into equal areas, and then locating a traverse point within each of the equal areas.
Acceptable sample locations must be located at least two stack or duct equivalent
diameters downstream from a flow disturbance and one-half equivalent diameter
upstream from a flow disturbance.
3.1.2 EPA Method 2, Determination of Stack Gas Velocity (Type S
Pitot Tube)
EPA Method 2 is used to measure the gas velocity using an S-type pitot tube connected to a
pressure measurement device, and to measure the gas temperature using a calibrated
thermocouple connected to a thermocouple indicator. Typically, Type S (Stausscheibe) pitot
tubes conforming to the geometric specifications in the test method are used, along with an
inclined manometer. The measurements are made at traverse points specified by EPA Method
1. The molecular weight of the gas stream is determined from independent measurements of
O2, CO2, and moisture, which are used in calculations of stack gas velocity.
Pertinent information regarding the performance of the method is presented below:
o S-type pitot tube coefficient is 0.84
o RATA will be performed for stack gas velocity, feet per second (ft/s)
The typical sampling system is detailed in Figure 3-1.
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2024 Building 1320 Deactivation Furnace CEMS RATA Source Test Protocol
Tooele Army Depot

Figure 3-1
US EPA Methods 2 and 4 Sampling Train
MANOMETER
BY-PASS VALVE
(fine adjust )
AIR TIGHT
PUMP
VACUUM GAUGE
MAIN
VALVE
(coarse adjust )
THERMOCOUPLES
DRY GAS
METER
ORIFICE
GAS
EXIT
VACUUM
LINE
VACUUM
LINE
ADAPTOR
ICE
BATH
100 mL
CONDENSING
REAGENT
(standard tip)
100 mL
CONDENSING
REAGENT
(modified/no tip)
Empty
(modified/no tip)200-300g
Silica Gel
(modified/no tip)
THERMOCOUPLE
SAMPLE LINE
PROBE
MANOMETER
THERMOCOUPLE
TYPE “S”
PITOT

3.1.3 EPA Methods 3A and 10, Determination of Oxygen, Carbon
Dioxide, and Carbon Monoxide Concentrations in Emissions
from Stationary Sources (Instrumental Analyzer Procedures)
Concentrations of O2, CO2, and CO are measured simultaneously using EPA Methods 3A and
10, which are instrumental test methods. Conditioned gas is sent to a series of analyzers to
measure the gaseous emission concentrations. The performance requirements of the
method must be met to validate the data.
Pertinent information regarding the performance of the method is presented below:
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2024 Building 1320 Deactivation Furnace CEMS RATA Source Test Protocol
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o A dry extractive sampling system is used to report emissions on a dry
basis
o A paramagnetic analyzer is used to measure O2
o A nondispersive infrared analyzer is used to measure CO2
o A gas filter correlation nondispersive infrared analyzer is used to measure
CO
o Calibration span values are 21.03% O2, 17.69% CO2, and 6.007 ppmvd
CO
o Minimum Required Sample Duration: 21 minutes

Figure 3-2
US EPA Methods 3A and 10 Sampling Train
Sample / Calibration Gas
Exhaust
Exhaust
Sample / Calibration Gas
O2 AND/OR CO2
ANALYZER
CO ANALYZER
DATA
OUTPUT DAS
SIGNAL
SIGNAL
SAMPLE
CONDITIONING
SYSTEM WITH
PUMP
EPA Protocol
Calibration Gases
MASS FLOW CONTROLLER /
CALIBRATION GAS MANIFOLD
CALIBRATION GAS
LINE
STACK
GAS
STACK
WALL
HEATED
SAMPLE
LINE
HEATED
FILTER
"SAMPLE” AND “BY -PASS"
ROTAMETERS WITH FLOW
CONTROL VALVES
THREE
WAY
VALVE
BY-PASS
“BIAS” ROTAMETER
WITH FLOW CONTROL
VALVE
“ANALYZER”
ROTAMETERS WITH
FLOW CONTROL
VALVES
SAMPLE PROBE

3.1.4 EPA Method 4, Determination of Moisture Content in Stack
Gas
EPA Method 4 is a manual, non-isokinetic method used to measure the moisture content of
gas streams. Gas is sampled at a constant sampling rate through a probe and impinger
train. Moisture is removed using a series of pre-weighed impingers containing methodology-
specific liquids and silica gel immersed in an ice water bath. The impingers are weighed
after each run to determine the percent moisture.
Pertinent information regarding the performance of the method is presented below:
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o The reference method is used to measure moisture
o Moisture sampling is performed as a stand-alone method at a single point
in the centroid of the stack
o Minimum Required Sample Volume: 21 scf
The typical sampling system is detailed in Figure 3-1.
3.1.5 EPA Performance Specification 4B, Specifications and Test
Procedures for Carbon Monoxide and Oxygen Continuous
Emission Monitoring Systems in Stationary Sources
This specification is to be used for evaluating the acceptability of carbon monoxide (CO) and
oxygen (O2) continuous emission monitoring systems (CEMS) at the time of or soon after
installation and whenever specified in the regulations. The CEMS may include, for certain
stationary sources, (a) flow monitoring equipment to allow measurement of the dry volume
of stack effluent sampled, and (b) an automatic sampling system.
The typical sampling system is detailed in Figure 3-2.
3.1.6 Waste Feed Scale Audit
The scale used to measure the Waste Feed Rate will be audited with a certified weight set.
Certified weights will be placed on the scale and the results will be recorded. Certification
sheets for the weight sets will be included in the final report
3.1.7 Pressure Sensor Audits
The readings of the pressure sensors installed on the process will be compared to the
readings obtained on a calibrated reference pressure transducer. The results of the
reference device and the process sensor will be recorded. Certification sheets for the
pressure transducer will be included in the final report.
3.1.8 Temperature Sensor Audits
The readings of the sensors installed on the process to monitor the Baghouse Inlet and
Outlet, Feed Inlet, Burner Inlet and Afterburner temperatures will be audited using a
thermocouple calibration device. The device sends electrical signals to the temperature
sensors, simulating different temperature settings. Certification sheets for the pressure
transducer will be included in the final report.
The readings of the sensor installed on the process to monitor the Stack temperature will;
be audited as part of the gas velocity RATA. The reading of the process temperature will be
directly compared to the reference stack thermocouple readings obtained during the RATA.

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3.2 Process Test Methods
Data will be collected for the seven-day calibration drift (CD) per the requirements of PS 4B,
§4.2. All data will be collected by facility personnel and presented in the test report.

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4.0 Quality Assurance and Reporting
4.1 QA Audits
Montrose has instituted a rigorous QA/QC program for its air quality testing. Quality
assurance audits are performed as part of the test program to ensure that the results are
calculated using the highest quality data available. This program ensures that the emissions
data we report are as accurate as possible. The procedures included in the cited reference
methods are followed during preparation, sampling, calibration, and analysis. Montrose is
responsible for preparation, calibration, and cleaning of the sampling apparatus. Montrose
will also perform the sampling, sample recovery, storage, and shipping. Approved contract
laboratories may perform some of the preparation and sample analyses, as needed.
4.2 Quality Control Procedures
Montrose calibrates and maintains equipment as required by the methods performed and
applicable regulatory guidance. Montrose follows internal procedures to prevent the use of
malfunctioning or inoperable equipment in test programs. All equipment is operated by
trained personnel. Any incidence of nonconforming work encountered during testing is
reported and addressed through the corrective action system.
4.2.1 Equipment Inspection and Maintenance
Each piece of field equipment that requires calibration is assigned a unique identification
number to allow tracking of its calibration history. All field equipment is visually inspected
prior to testing and includes pre-test calibration checks as required by the test method or
regulatory agency.
4.2.2 Audit Samples
When required by the test method and available, Montrose obtains EPA TNI SSAS audit
samples from an accredited provider for analysis along with the samples. Currently, the
SSAS program has been suspended pending the availability of a second accredited audit
sample provider. If the program is reinstated, the audit samples will be ordered. If required
as part of the test program, the audit samples are stored, shipped, and analyzed along with
the emissions samples collected during the test program. The audit sample results are
reported along with the emissions sample results.
4.3 Data Analysis and Validation
Montrose converts the raw field, laboratory, and process data to reporting units consistent
with the permit or subpart. Calculations are made using proprietary computer spreadsheets
or data acquisition systems. One run of each test method is also verified using a separate
example calculation. The example calculations are checked against the spreadsheet results
and are included in the final report. The “Standard Conditions” for this project are 29.92
inches of mercury and 68 °F.
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4.4 Sample Identification and Custody
No samples are required to be recovered for this test program.
4.5 Quality Statement
Montrose is qualified to conduct this test program and has established a quality
management system that led to accreditation with ASTM Standard D7036-04 (Standard
Practice for Competence of Air Emission Testing Bodies). Montrose participates in annual
functional assessments for conformance with D7036-04 which are conducted by the
American Association for Laboratory Accreditation (A2LA). All testing performed by Montrose
is supervised on site by at least one Qualified Individual (QI) as defined in D7036-04
Section 8.3.2. Data quality objectives for estimating measurement uncertainty within the
documented limits in the test methods are met by using approved test protocols for each
project as defined in D7036-04 Sections 7.2.1 and 12.10. Additional quality assurance
information is included in the appendices. The content of this test plan is modeled after the
EPA Emission Measurement Center Guideline Document (GD-042).
4.6 Reporting
Montrose will prepare a final report to present the test data, calculations/equations,
descriptions, and results. Prior to release by Montrose, each report is reviewed and certified
by the project manager and their supervisor, or a peer. Source test reports will be
submitted to the facility or appropriate regulatory agency (upon customer approval) within
45 days of the completion of the field work. The report will include a series of appendices to
present copies of the intermediate calculations and example calculations, raw field data,
laboratory analysis data, process data, and equipment calibration data.
4.6.1 Example Report Format
The report is divided into various sections describing the different aspects of the source
testing program. Figure 4-1 presents a typical Table of Contents for the final report.
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Figure 4-1
Typical Report Format
Cover Page
Certification of Report
Table of Contents
Section
1.0 Introduction
2.0 Plant and Sampling Location Descriptions
3.0 Sampling and Analytical Procedures
4.0 Test Discussion and Results
5.0 Internal QA/QC Activities
Appendices
A Field Data and Calculations
B Facility CEMS and Process Data
C Quality Assurance/Quality Control
D Regulatory Information

4.6.2 Example Presentation of Test Results
Table 4-1 presents the typical tabular format that is used to summarize the results in the
final source test report. Separate tables will outline the results for each CEMS parameter/set
of units and compare them to their respective RA requirements.

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Table 4-1
Example RATA Results
Run
No. Date Time RM CEMS Difference
Run used
(Y or N)
Unit Load
(units)
1 XX/XX/XXXX XXXX-XXXX XX XX XX X XX
2 XX/XX/XXXX XXXX-XXXX XX XX XX X XX
3 XX/XX/XXXX XXXX-XXXX XX XX XX X XX
4 XX/XX/XXXX XXXX-XXXX XX XX XX X XX
5 XX/XX/XXXX XXXX-XXXX XX XX XX X XX
6 XX/XX/XXXX XXXX-XXXX XX XX XX X XX
7 XX/XX/XXXX XXXX-XXXX XX XX XX X XX
8 XX/XX/XXXX XXXX-XXXX XX XX XX X XX
9 XX/XX/XXXX XXXX-XXXX XX XX XX X XX
10 XX/XX/XXXX XXXX-XXXX XX XX XX X XX
11 XX/XX/XXXX XXXX-XXXX XX XX XX X XX
12 XX/XX/XXXX XXXX-XXXX XX XX XX X XX
Averages XX XX XX X XX

Standard Deviation XX
Confidence Coefficient (CC) XX
RA based on mean RM value XX %
RA based on difference plus CC XX units
RA based on absolute difference XX units

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Appendix A
Supporting Information

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Appendix A.1
Units and Abbreviations

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@ X% O2 corrected to X% oxygen (corrected for dilution air)
|CC|absolute value of the confidence coefficient
|d|absolute value of the mean differences
ºC degrees Celsius
ºF degrees Fahrenheit
ºR degrees Rankine
" H2O inches of water column
13.6 specific gravity of mercury
ΔH pressure drop across orifice meter, inches H2O
ΔP velocity head of stack gas, inches H2O
θ total sampling time, minutes
µg microgram
ρa density of acetone, mg/ml
ρw density of water, 0.9982 g/ml or 0.002201 lb/ml
acfm actual cubic feet of gas per minute at stack conditions
An cross-sectional area of nozzle, ft2
As cross-sectional area of stack, square feet (ft2)
Btu British thermal unit
Bws proportion by volume of water vapor in gas stream
Ca particulate matter concentration in stack gas, gr/acf
CAvg average unadjusted gas concentration, ppmv
CDir measured concentration of calibration gas, ppmv
cf or ft3 cubic feet
cfm cubic feet per minute
CGas average gas concentration adjusted for bias, ppmv
CM average of initial and final system bias check responses from upscale calibration gas, ppmv
cm or m3 cubic meters
CMA actual concentration of the upscale calibration gas, ppmv
CO average of initial and final system bias check responses from low-level calibration gas, ppmv
Cp pitot tube coefficient
Cs particulate matter concentration in stack gas, gr/dscf
CS calibration span, % or ppmv
CS measured concentration of calibration gas, ppmv
CV manufactured certified concentration of calibration gas, ppmv
D drift assessment, % of span
dcf dry cubic feet
dcm dry cubic meters
Dn diameter of nozzle, inches
Ds diameter of stack, inches
dscf dry standard cubic feet
dscfm dry standard cubic feet per minute
dscm dry standard cubic meters
Fd F-factor, dscf/MMBtu of heat input
fpm feet per minute
fps feet per second
ft feet
ft2 square feet
g gram
gal gallons
gr grains (7000 grains per pound)
UNITS OF MEASUREMENT
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UNITS OF MEASUREMENT
gr/dscf grains per dry standard cubic feet
hr hour
I percent of isokinetic sampling
in inch
k kilo or thousand (metric units, multiply by 103)
K kelvin (temperature)
K3 conversion factor 0.0154 gr/mg
K4 conversion factor 0.002668 ((in. Hg)(ft3))/((ml)(°R))
kg kilogram
Kp pitot tube constant (85.49 ft/sec)
kwscfh thousand wet standard cubic feet per hour
l liters
lb/hr pounds per hour
lb/MMBtu pounds per million Btu
lpm liters per minute
m meter or milli
M thousand (English units) or mega (million, metric units)
m3 cubic meters
ma mass of residue of acetone after evaporation, mg
Md molecular weight of stack gas; dry basis, lb/lb-mole
meq milliequivalent
mg milligram
Mg megagram (106 grams)
min minute
ml or mL milliliter
mm millimeter
MM million (English units)
MMBtu/hr million Btu per hour
mn total amount of particulate matter collected, mg
mol mole
mol. wt. or MW molecular weight
Ms molecular weight of stack gas; wet basis, lb/lb-mole
MW molecular weight or megawatt
n number of data points
ng nanogram
nm nanometer
Nm3 normal cubic meter
Pbar barometric pressure, inches Hg
pg picogram
Pg stack static pressure, inches H2O
Pm barometric pressure of dry gas meter, inches Hg
ppb parts per billion
ppbv parts per billion, by volume
ppbvd parts per billion by volume, dry basis
ppm parts per million
ppmv parts per million, by volume
ppmvd parts per million by volume, dry basis
ppmvw parts per million by volume, wet basis
Ps absolute stack gas pressure, inches Hg
psi pounds per square inch
psia pounds per square inch absolute
psig pounds per square inch gauge
GP043AS-036949-PP-796 26 of 48
UNITS OF MEASUREMENT
Pstd standard absolute pressure, 29.92 inches Hg
Qa volumetric flow rate, actual conditions, acfm
Qs volumetric flow rate, standard conditions, scfm
Qstd volumetric flow rate, dry standard conditions, dscfm
R ideal gas constant 21.85 ((in. Hg) (ft3))/((°R) (lbmole))
SBfinal post-run system bias check, % of span
SBi pre-run system bias check, % of span
scf standard cubic feet
scfh standard cubic feet per hour
scfm standard cubic feet per minute
scm standard cubic meters
scmh standard cubic meters per hour
sec second
sf, sq. ft., or ft2 square feet
std standard
t metric ton (1000 kg)
T 0.975 t-value
Ta absolute average ambient temperature, ºR (+459.67 for English)
Tm absolute average dry gas meter temperature, ºR (+459.67 for English)
ton or t ton = 2000 pounds
tph or tons/hr tons per hour
tpy or tons/yr tons per year
Ts absolute average stack gas meter temperature, ºR (+459.67 for English)
Tstd absolute temperature at standard conditions
V volt
Va volume of acetone blank, ml
Vaw volume of acetone used in wash, ml
Vlc total volume H2O collected in impingers and silica gel, grams
Vm volume of gas sampled through dry gas meter, ft3
Vm(std)volume of gas measured by the dry gas meter, corrected to standard conditions, dscf
Vma stack gas volume sampled, acf
Vn volume collected at stack conditions through nozzle, acf
Vs average stack gas velocity, feet per second
Vwc(std)volume of water vapor condensed, corrected to standard conditions, scf
Vwi(std)volume of water vapor in gas sampled from impingers, scf
Vwsg(std)volume of water vapor in gas sampled from silica gel, scf
W watt
Wa weight of residue in acetone wash, mg
Wimp total weight of impingers, grams
Wsg total weight of silica gel, grams
Y dry gas meter calibration factor, dimensionless
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AAS atomic absorption spectroscopy
ACDP air contaminant discharge permit
ACE analyzer calibration error, percent of span
AD absolute difference
ADL above detection limit
AETB Air Emissions Testing Body
AS applicable standard (emission limit)
ASTM American Society For Testing And Materials
BACT best achievable control technology
BDL below detection limit
BHP brake horsepower
BIF boiler and industrial furnace
BLS black liquor solids
CC confidence coefficient
CD calibration drift
CE calibration error
CEM continuous emissions monitor
CEMS continuous emissions monitoring system
CERMS continuous emissions rate monitoring system
CET calibration error test
CFR Code of Federal Regulations
CGA cylinder gas audit
CHNOS elemental analysis for determination of C, H, N, O, and S content in fuels
CNCG concentrated non-condensable gas
CO catalytic oxidizer
COC chain of custody
COMS continuous opacity monitoring system
CPM condensable particulate matter
CPMS continuous parameter monitoring system
CT combustion turbine
CTM conditional test method
CTO catalytic thermal oxidizer
CVAAS cold vapor atomic absorption spectroscopy
De equivalent diameter
DE destruction efficiency
Dioxins polychlorinated dibenzo-p-dioxins (PCDDs)
DLL detection level limited
DNCG dilute non-condensable gas
ECD electron capture detector
EIT Engineer In Training
ELCD electrolytic conductivity detector (hall detector)
EMPC estimated maximum possible concentration
EPA US Environmental Protection Agency
EPRI Electric Power Research Institute
ES emission standard (applicable limit)
ESP electrostatic precipitator
EU emission unit
FCCU fluid catalytic cracking unit
FGD flue gas desulfurization
FI flame ionization
FIA flame ionization analyzer
FID flame ionization detector
FPD flame photometric detector
FPM filterable particulate matter
ABBREVIATIONS
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ABBREVIATIONS
FTIR Fourier-transform infrared spectroscopy
FTPB field train proof blank
FTRB field train recovery blank
Furans polychlorinated dibenzofurans (PCDFs)
GC gas chromatography
GC/MS gas chromatography/mass spectroscopy
GFAAS graphite furnace atomic absorption spectroscopy
GFC gas filter correlation
GHG greenhouse gas
HAP hazardous air pollutant
HC hydrocarbons
HHV higher heating value
HPLC high performance liquid chromatography
HRGC/HRMS high-resolution gas chromatography/high-resolution mass spectroscopy
HRSG heat recovery steam generator
IC ion chromatography
ICAP inductively-coupled argon plasma emission spectroscopy
ICPCR ion chromatography with a post-column reactor
ICP-MS inductively coupled plasma-mass spectroscopy
IR infrared radiation
ISO International Standards Organization
kW kilowatts
LFG landfill gas
LHV lower heating value
LPG liquified petroleum gas
MACT maximum achievable control technology
MDI methylene diphenyl diisocyanate
MDL method detection limit
MNOC maximum normal operating conditions
MRL method reporting limit
MS mass spectrometry
NA not applicable or not available
NCASI National Council For Air And Steam Improvement
NCG non-condensable gases
ND not detected
NDIR non-dispersive infrared
NESHAP National Emissions Standards For Hazardous Air Pollutants
NG natural gas
NIOSH National Institute For Occupational Safety And Health
NIST National Institute Of Standards And Technology
NMC non-methane cutter
NMOC non-methane organic compounds
NMVOC non-methane volatile organic compounds
NPD nitrogen phosphorus detector
NSPS New Source Performance Standards
OSHA Occupational Safety And Health Administration
PAH polycyclic aromatic hydrocarbons
PCB polychlorinated biphenyl compounds
PCWP plywood and composite wood products
PE Professional Engineer
PFAS per- and polyfluoroalkyl substances (PFAS)
PI photoionization
PID photoionization detector
PM particulate matter
GP043AS-036949-PP-796 29 of 48
ABBREVIATIONS
PM10 particulate matter less than 10 microns in aerodynamic diameter
PM2.5 particulate matter less than 2.5 microns in aerodynamic diameter
POM polycyclic organic matter
PS performance specification
PSD particle size distribution
PSEL plant site emission limits
PST performance specification test
PTE permanent total enclosure
PTM performance test method
QA/QC quality assurance and quality control
QI Qualified Individual
QSTI Qualified Source Testing Individual
RA relative accuracy
RAA relative accuracy audit
RACT reasonably available control technology
RATA relative accuracy test audit
RCTO rotary concentrator thermal oxidizer
RICE stationary reciprocating internal combustion engine
RM reference method
RTO regenerative thermal oxidizer
SAM sulfuric acid mist
SCD sulfur chemiluminescent detector
SCR selective catalytic reduction system
SD standard deviation
Semi-VOST semi-volatile organic compounds sample train
SRM standard reference material
TAP toxic air pollutant
TBD to be determined
TCA thermal conductivity analyzer
TCD thermal conductivity detector
TGNENMOC total gaseous non-ethane non-methane organic compounds
TGNMOC total gaseous non-methane organic compounds
TGOC total gaseous organic compounds
THC total hydrocarbons
TIC tentatively identified compound
TO thermal oxidizer
TO toxic organic (as in EPA Method TO-15)
TPM total particulate matter
TSP total suspended particulate matter
TTE temporary total enclosure
ULSD ultra-low sulfur diesel
UV ultraviolet radiation range
VE visible emissions
VOC volatile organic compounds
VOST volatile organic sample train
WC water column
WWTP waste water treatment plant
GP043AS-036949-PP-796 30 of 48
Ag silver Se selenium
As arsenic SO2 sulfur dioxide
Ba barium SO3 sulfur trioxide
Be beryllium SOx sulfur oxides
C carbon TCDD tetrachlorodibenzodioxin
Cd cadmium TCDF tetrachlorodibenzofuran
CdS cadmium sulfide TGOC total gaseous organic concentration
CH2O formaldehyde THC total hydrocarbons
CH3CHO acetaldehyde Tl thallium
CH3OH methanol TRS total reduced sulfur compounds
CH4 methane Zn zinc
C2H4O ethylene oxide
C2H6 ethane
C3H4O acrolein
C3H6O propionaldehyde
C3H8 propane
C6H5OH phenol
Cl2 chlorine
ClO2 chlorine dioxide
CO carbon monoxide
Co cobalt
CO2 carbon dioxide
Cr chromium
Cu copper
EtO ethylene oxide
EtOH ethyl alcohol (ethanol)
H2 hydrogen
H2O water
H2O2 hydrogen peroxide
H2S hydrogen sulfide
H2SO4 sulfuric acid
HCl hydrogen chloride
Hg mercury
IPA isopropyl alcohol
MDI methylene diphenyl diisocyanate
MeCl2 methylene chloride
MEK methyl ethyl ketone
MeOH methanol
Mn manganese
N2 nitrogen
NH3 ammonia
Ni nickel
NO nitric oxide
NO2 nitrogen dioxide
NOx nitrogen oxides
O2 oxygen
P phosphorus
Pb lead
PCDD polychlorinated dibenzo-p-dioxins
PCDF polychlorinated dibenzofurans
Sb antimony
CHEMICAL NOMENCLATURE
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Appendix A.2
Accreditation Information/Certifications

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Accredited Air Emission Testing Body

A2LA has accredited
MONTROSE AIR QUALITY SERVICES

In recognition of the successful completion of the joint A2LA and Stack Testing Accreditation Council (STAC)
evaluation process, this laboratory is accredited to perform testing activities in compliance with
ASTM D7036:2004 - Standard Practice for Competence of Air Emission Testing Bodies.

Presented this 4th day of February 2022.

_______________________
Vice President, Accreditation Services
For the Accreditation Council
Certificate Number 3925.01
Valid to February 29, 2024

This accreditation program is not included under the A2LA ILAC Mutual Recognition Arrangement.
A merican Association for Laboratory Accreditation
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2024 Building 1320 Deactivation Furnace CEMS RATA Source Test Protocol
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Appendix “S”
Field Work Safety Plan

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SITE SAFETY P LAN BOO KLE T
Project:_____________________
Cus tomer :___________________
Loca tion:____________________
Units :_______________________
Cl ient Project Manager:______________________
Revisio n Date:June 29th, 2023
PROJ-000TBD
Coterie Environmental
TEAD
Deactivation Furnace/PCE
Timothy Wojtach
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Page 1 of 2
Site Safety Plan and JHA Purpose and Instructions
Purpose
Employee safety is the top priority of Montrose Environmental Group.All employees must be
trained to assess and mitigate hazards.The District Manager and Project Manager are
responsible to ensure all hazards have been properly identified and managed.All employees
have Stop Work Authority in all situations wh ere an employee f eels they or their co-worker
cannot perform a job safely or if there is a task for which th ey have not been adequately trained.
The Site Safety Plan (SSP)has been developed to help assist Montrose test crews with
identifying physical and health hazards and determining how the hazards will be managed.
Additionally,the SSP will help each crew manage the safety of the employees by providing
emergency procedures and information.The booklet contains a several safety forms that may
be required in the field.
Instructions
The SSP consists of t he following:
communicated to all employees,signed,and posted.
Supervisor/CPM will ensure that this Emergency Action Plan Form is completed,
CPM will maintain a roster and be respo nsible for accounting for all employees.The Job
to work commencing.In the event of an emergency situation/evacuation,the Job Supervisor/
emergency and evacuat ion procedures,assembly/rally points,alert systems,and signals prior
the Emergency Act ion Plan form and ensure that all employees are familiar with the facility
4.Emergency Action Plan -The Job Supervisor/Client Project Ma nager (CPM)will complete
observed plus applicable PPE that may be required.
administrative controls that a crew can use to reduce or eliminate the hazards they have
3.Hazard Control Matrix -contains useful information on both engineering and
with t he toolbox topic and signatures can be added to the SSP packet.
the hazard analysis is required daily for t he duration of the test.An additional sheet of paper
modified when conditions change.A toolbox meeting with a daily topic in addition to a review of
sign on the Job Hazard Analysis form in agreement and sign in Section 10.The JHA is t o be
Each team member has the option to discuss making changes or adding to the JHA and must
Section 9 will require at least three tasks,hazards and controls be identified for the project.
form for accuracy,making any corrections required and complete the remainder of the JHA.
complete the JHA form through section 8.Upon arrival at the test site,the team will review the
daily hazard review with sign off by the team.The client Project Manager is responsible to
task/site’s particular hazards and controls.The form also includes a daily toolbox topic and
2.A Job Hazard Analysis is a standardized,two-page,fillable form that is used to evaluated the
prior to the test.
1.A Pre-Mobilization Test Plan –To be completed in it’s entirety by the client project Manager
AQS-FRM-1.13R1
Extended Hours Formc.
Heat Stress Prevention Form Based on Heat Indexb.
MEWP Lift Inspection Forma.
Additional Forms,as applicable5.
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Page 2 of 2
Site Safety Plan and JHA Purpose and Instructions
The SSP is a living document.The Project Manager should continually update their SSPs as
new information and conditions change or if new hazards are presented.
Each completed SSP should be maintained with the Test Plan in the office for a period of 3
years.There will be an audit process developed for the Site Safety Plans.
AQS-FRM-1.13R1
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Page 1 of 2
PRE-MOBILIZATION TEST INFORMAT ION
Source Type:New Source:____Revisit:____Prj#/Date/Tech:__________________________
Co al Fired Electric Utility:____Ethanol Plant:____Chemical Mfg.of _________________________
Ce ment/Lime Kiln Plant:____Specialty Mfg.of:___________Other:_______________
Anticipated Effluent Composition –check all that apply and fill in expected concentration in ppm/%
CO NOX SO2 VOC other
If oth er,explain:_______________________________________________________
Flammable:_______Toxic:________Corrosive:_______Dust:__________
Engin eering Controls to be Implemented:
______________________________________________________________________________________
__________________________________________________________________________________
Additional Safety Equipment Required:
Personal gas monitors:____
Re spir atory Protection:
Ha lf Face____Full Face____HEPA Filters____Supplied Air:_____(Safety Dept.Approval)
Approximate Flue Gas Temperatures,(F)
below 210 210 to 450 450 to 950 above 950 other
If oth er,explain:_______________________________________________________
Approximate Duct Pressure,(iwg):
below -3 -3 to +3 +3 to +7 above +7 other
If oth er,explain:_______________________________________________________
PROJECT NAME/LOCATION :______________________PROJECT #:____________________
TEST DATE:______________________PROJECT MANAGER:___________________
TEST SCOPE:_________________________________________________________________
SITE CONTACT:Name:_____________________Contact Phone:_________________________
AQS-FRM-1.17
X PROJ-027746/August 2023/DSmith
X
~8% CO2, ~10% O2, <1 ppmv CO
TEAD Deactivation Furnace RATA/PCE Audit PROJ-000TBD
May 6, 2024 Timothy Wojtach
Gas Velocity, O2 and CO RATA on Deactivation Furnace and PCE Audits
Michele (Gehring) Karnes 610-945-1777
GP043AS-036949-PP-796 38 of 48
Page 2 of 2
PRE-MOBILIZATION TEST INFORMAT ION
Sampling Location:Stack Port ____Duct Port ____
Approximate Sampling Platform Height,(ft)
Effluent Chemic al Regulatory Limits
Gas Name Chemical
Formula
Cal OSHA PEL1
(ppm)
Cal OSHA
STEL2
(ppm)
NIOSH REL
TWA3 (ppm)
Cal OSHA
Ceiling
(ppm)
IDLH4
(ppm)
Carbon Monoxide CO 25 200 35 200 1,200
Nitric Oxide NOx 25 ND5 25 ND 100
Sulfur Dioxide SO2 2 5 2 ND 100
Hydrogen Chloride HCl 0.3 2 ND 2 50
Hydrogen Sulfide H2S 10 15 10 (10 min.)C 50 100
California Occupational Safety and Health Administration (OSHA)Permissible Exposure Limit (PEL)based on an 8-hour shift;
2:Cal OSHA Short-term Exposure Limit (STEL)based on a 15-minute period;
3:National Institute for Occupational Safety and Health (NIOSH)Recommended Exposure Limit (REL)Time -weighted Average (TWA)based
on an 8-hour shift;
4:Immediately Dangerous to Life or Health (IDLH);
5:Not Defined (ND);
C:Ceiling Limit -Maximum allowable human exposure limit for an airborne or gaseous substance,which is not to be exceeded,even
momentarily.
Prepared by:
Reviewed by:Date:
______________________________________________________________________________
______________________________________________________________________________
Additional Information:
______________________________________________________________________________
______________________________________________________________________________
De scribe how equipment will be mobilized to the sampling location:
Other:_____________________________________________________________________________
Guardrails:____Toe plate:____Engineered Tie Off Points:____Heat Shield:____
Elevators:____L adders:____MEWP Lift:____Scaffold:____Equipment Hoist:____
Ac cess and Protection:
If oth er,explain:_______________________________________________________
below 6 6 to 50 50 to 100 above 100 other
AQS-FRM-1.17
2
Timothy Wojtach Date: January 29, 2024
GP043AS-036949-PP-796 39 of 48
Job Hazard Analysis 1 of 3
1.
Client Rep
Job Preparation
Job Site Walk Through Completed Site Specific Training Complete
Safe Work Permit Received from Client
2.Facility Information/Emergency Preparedness
If non-emergency medical attention is needed, call: AXIOM #: 877-502-9466.
Plant Emergency # Certified First Aid Person:
EMS Location Evacuation Routes Rally Point
Severe Weather Shelter Location Eye Wash & Safety Shower Location
Operational: Yes No
Source Information: (list type):
Stack Gas Temp. (oF)Stack Gas Press. ("H2O)Stack Gas Components:
Stack Gas Inhalation Potential?Yes No If yes, see List of Hazard Chemicals.
3.Error Risk
Time Pressure Remote Work Location > 12 hr shift Working > 8 consecutive days
Lack of procedures Extreme temps, wind >30mph Personal illness/fatigue Vague work guidance
Monotonous Activity First day back after time off Multiple job locations Other:
4.Physical Hazards Hazard Controls
Dust Hazards Dust Mask Goggles Other:
Thermal Burn Hot Gloves Heat Shields Other Protective Clothing:
Electrical Hazards Connections Protected from Elements External GFCI Other:
XP Rating Requirement Intrinsically Safe Requirement
Inadequate Lighting Install Temporary Lighting Headlamps
Slip and Trip Housekeeping Barricade Area Other:
Hand Protection Cut Resistant Gloves Pinch Pts.General Electrical Impact Resistant
Other:
Potential Hazards for Consideration
Secondary Permits Hot Work Confined Space Excavation
Working from Heights Falling objects Fall protection Drop zone protection Platform load ratings
See also Sect. 7 Scaffold inspection Ladder inspection Barricades for equipment
Electrical Exposed wire/connector Verify equipment grounding Arc Flash
Lifting Crane lift plan Rigging inspection Tag lines used Hoists in place
Respiratory Unexpected exposure Chemical Dust (combustible)PEL provided
See also Sect. 8 Cartridges or supplied air available Gas detection equipment
5.Required PPE Hard Hats Safety Glasses Safety Toe Shoe/Boot Hearing Protection Safety Spotter
Hi-Vis Vests Harness/Lanyard*Goggles Personal Monitor Type:
Metatarsal Guards Hot Gloves Face Shield Respirator Type:
Nomex/FRC Other PPE:
Client Contact Name Date
Facility SSP Writer PM
If the heat index is expected to be above 91°, fill out the Heat Stress Prevention Form.
All hazards and mitigation steps must be documented.
If this JHA does not cover all the hazards identified,
use Section 9 to document that information.
AQS-FRM-1.18
Coterie Environmental
TW
Michele (Gehring) Karnes, P.E.5-6-24
TEAD
Lonnie Brown
GP043AS-036949-PP-796 40 of 48
Job Hazard Analysis 2 of 3
Additional Work Place Hazards
6.Critical Procedures – check all that apply – *indicates additional form must be completed or collected from client
Heat Stress Prevention*Confined Space*Roof Work Scaffold
Cold Weather Work Hazardous Energy Control*Other:
7.Working From Heights
Fall Protection Fixed Guardrails/Toe boards Fall Prevention PPE Warning Line System
Falling Objects Protection Barricading Netting House Keeping Tethered Tools Catch Blanket or Tarp
Fall Hazard Communication Adjacent/Overhead Workers Contractor Contact Client Contact
8.Other Considerations
Environmental Hazards - Weather Forecast
Heat/Cold Lightning Rain Snow Ice Tornado Wind Speed
Steps for Mitigation:
Electrical Safety Planning
Plant Hook up:110V 220/240V 480V Generator Hard wired into panel
Electrical Classified Area: Yes No Trailer Grounded: Yes No Plug Type
Electrical Hook Up Responsibility:
List of Hazardous Chemicals Other Chemicals:
Acetone Nitric Acid Hydrogen Peroxide Compressed Gases
Hexane Sulfuric Acid Isopropyl Alcohol Flammable Gas
Toluene Hydrochloric Acid Liquid Nitrogen Non-Flammable Gas
H2S Carbon Monoxide
Steps for Mitigation:
Wildlife/Fauna in Area
Poison Ivy Poison Oak Insects:Wildlife:
Personnel w/ known allergies to bees stings or other allergens?Yes No
9.Observed Hazards and Mitigation Steps
Task Potential Hazard(s)Steps for Mitigation
● 1 1
2 2
3 3
● 1 1
2 2
3 3
● 1 1
2 2
3 3
● 1 1
2 2
3 3
Exposure Monitoring
MEWP*
AQS-FRM-1.18
GP043AS-036949-PP-796 41 of 48
Job Hazard Analysis 3 of 3
10.JHA REVIEW: Crew Names & Signatures
11.Daily JHA Meeting & Review
Items to review:
● Change in conditions ● Extended work hours ● Daily Safety Topic
● New workers or contractors ● Occurrence of near misses or injuries
Printed Name Signature
2
Discussion TopicDay
Initialing demonstrates that site conditions and hazards have not changed from the original SSP. If changes did occur, make the
necessary updates to this JHA and add notes as applicable in Section 9.
Initials
9
8
7
6
3
Date Printed Name Signature Date
5
4
11
10
AQS-FRM-1.18
GP043AS-036949-PP-796 42 of 48
1
2
3
4
5
6 Local Hospital/ Clinic Telephone Number:
7
8
9
10
11
12
13
14
15
16
17
MEG Job Supervisor/ CPM's Telephone Number:
Plant's #1 Contact Person's Name:
Plant's #1 Contact Person's Telephone Number:
MEG Job Safety Supervisor's Telephone Number:
Plant's Emergency Telephone Number:
Emergency Ops Radio Channel:
The Fire Extinguisher is Located:
Eye Wash and Safety Shower Location:
The First Aid Kit is Located:
Page 1 of 2
The Job Supervisor/ Client Project Manager (CPM) will ensure that all employees are familiar with the facility emergency and evacuation
procedures, assembly/ rally points, alert systems, and signals prior to work commencing. In the event of an emergency situation/
evacuation, the Job Supervisor/ CPM will maintain a roster and be responsible for accounting for all employees. The Job Supervisor/
CPM will ensure that this Emergency Action Plan Form is completed, communicated to all employees, and posted.

•You must follow the client’s emergency action plan first, and notify your Supervisor immediately.
•If incident is life threatening, CALL 911 IMMEDIATELLY
•If non-emergency medical attention is needed, call AXIOM Medical number: 877-502-9466.
EMERGENCY ACTION PLAN FORM
MEG Job Supervisor/ CPM's Name:
MEG Job Safety Supervisor (if applicable):
Evacuation Routes:
Severe Weather Shelter Location:
Plant's #2 Contact Person's Name:
Plant's #2 Contact Person's Telephone Number:
Designated Assembly Point Location:
AQS-FRM-1.11
GP043AS-036949-PP-796 43 of 48
1
2
4
5
Signature:Date:Printed Name:Signature:Date:
EVACUATE:____________________________________;
OTHER:_______________________________________;
Alarm Tones:
EMERGENCY ACTION PLAN FORM AND EVACUATION ASSEMBLY MAP REVIEW:Crew Names and Signatures
Printed Name:
Draw the evacuation and assembly map here
Page 2 of 2
EMERGENCY EVACUATION AND ASSEMBLY MAP
3
Designated Shelter(s)Description:
Designated Assembly Point(s)Description:
YES or NO
Facility Name:
Facility Alarm (Circle):
FIRE:_________________________________________;
CHEMICAL/GAS:_______________________________;
SHELTER-IN-PLACE:_____________________________;
AQS-FRM-1.11
GP043AS-036949-PP-796 44 of 48
Serial Number:
Make:Rented or Owned:
•Check “Yes” if an item is adequate,operational,and safe.
•Check “No” to indicate that a repair or other corrective action is required prior to use.
•Check “N/A” to indicate “Not Applicable.”
Yes No N/A
☐☐☐
2.Hydraulic fluid level is s ufficient,with the platform fully lowered ☐☐☐
3.Hydraulic sys tem pressure (see m anufacturer specs)is acceptable.
If the pressure is low,determine cause and repair in accordance with accepted procedures
as outlined in service manual.
☐☐☐
4.Tires and wheel lug nuts (for tightness)☐☐☐
5.Hoses and cables (i.e.worn are as or chafing)☐☐☐
6.Platform rails and safety gate (no damage p resent)☐☐☐
7.Pivot pins secure ☐☐☐
8.Welds are not cracked and structu ral members are not bent or broken ☐☐☐
9.Warning and instructional labels are legible and secure,and load capacity is clearly marked.☐☐☐
10. Manufacturer’s Instruction Manual is present inside the bucket ☐☐☐
11.Base controls (switches and push buttons)can be properly operated ☐☐☐
12.Platform conditions are safe (i.e.not slippery)☐☐☐
13.Fire extinguisher is present,mounted a nd fully charged,loca ted inside the bucket ☐☐☐
14.Headlights,safety strobe light and back-up alarm are functional ☐☐☐
15.Workpla ce is free of hazards (overhead powerlines,obstru ctions,lev el surface ,high wind s,
etc.)*Do not operate if winds are 20 mph,unless otherwise specified by manufacturer
recommendations.
☐☐☐
Operator Name &Signature Location Date
Ground Control Name &Signature Location Date
Harness Inspections:
Printed Name Signature Date
Printed Name Signature Date
Printed Name Signature Date
Da ily MEWP Lift Inspection Form
Page 1 of 1
atthe beginning of each shift or following 6 to 8 hours of use.
All c hecks must be completed prior to each work shift,before operation of the MEWP lift.This checklist must be used
MEWP Lift Model #:
loose hoses,etc.)–if some thing can be easily loosened by hand then it is not sufficient.
1.All MEWP lift components are in working condition (i.e.no loose or missing parts,torn or
Items to be Inspected
AQS-FRM-1.16
GP043AS-036949-PP-796 45 of 48
Page 1 of 1
001AS-SAFETY-FM-3
Extended Hours Safety Audit

Project Number: Date: Time:

When a project is expected to extend past a 14-hour work day, this form must be completed to evaluate
the condition of the crew, and the safety of the work environment.

Permission to proceed into extended work hours must come from a District Manager (DM) or Regional Vice
President (RVP). Technical RVPs can authorize moving forward , if they are in the field or if they are
managing the project.

1. Hold test crew meeting Test crew initials:

The test leader should look for signs of the following in their crews:
• Irritability
• Lack of motivation
• Headaches
• Giddiness
• Fatigue
• Depression
• Reduced alertness, lack of concentration and
memory

The test leader should assess the environmental and hazardous concerns:
• Temperature and weather
• Lighting
• Working from Heights
• Hoisting
• PPE (i.e. respirators, etc.)
• Pollutant concentration in ambient air (SO 2,
H2S, ect.)

• Reason for extended hours
• Reason for delay
▪ Production limitations
• Impending Weather

3. Contact the client
The PM , DM or RVP must discuss with client any identified safety concerns, the client’s needs and
mutually agree on how to proceed. Discussion should also include the appropriate rest period
needed before the next day’s work shift can begin. The DM and/or a RVP must be informed on the
final decision.
Final Outcome:

Approver:

During this time,they can come to an agreement on how to proceed.Itemsto discuss include:
extended work period. If the DM is the acting PM on the job site, they must contact the RVP.
The PM must contact either the DM or RVP to discuss the safety issues that may arise due to the
Notify DM or RVP2.
GP043AS-036949-PP-796 46 of 48
Page 1 of 1
001AS-SAFETY-FM-5
Heat Stress Prevention Form
This form is to be used when the Expected Heat Index is above 91°F,and is to be kept with project
documentation.
Project Manager (PM):Expected High Temp:
Date(s):Expected Heat Index:
1.Review the s igns of Heat Exhaustion and Heat Stroke
2.If Heat Index is above 91°F:
•Provide cold water and/or sports drinks to all field staff (avoid caff einated drinks and energy
drink s which can increase core temperature).
o Bring no less than one gallon of water per employee
•If e mployee(s)are dehydrated,on blo od pressure medication or not acclimated to heat,
ensure they are aware of the heightened risk for heat illness
•Provide cool head ban ds/vests/etc.
•Have ice available to employees
•Implement work shift rotations and breaks,particularly for employees working in direct
sunlight.
•Provide as much shade at the jobsite as possible,including tarps,tents or other acceptable
temporary structures.
•PM should interview each field staff periodically to evaluate for signs of heat illness
3.If Hea t Index is above 103°F:
•Emp loyees must sto p for drinks and breaks every hour (about 4 cups/hour)
•Emp loyees are not permitted to work alone for more than one hour at a time without a
break offering shade and drink s
•Employees should wear cool bands and vests if working outside more than one hour at a
time
•PM should interview each field staff every 2 hours to evaluate for signs of heat illness
GP043AS-036949-PP-796 47 of 48

Coterie Environmental, LLC
2024 Building 1320 Deactivation Furnace CEMS RATA Source Test Protocol
Tooele Army Depot

This is the Last Page of This Document
If you have any questions, please contact one of the following
individuals by email or phone.

Name: Timothy Wojtach
Title: Account Manager
Region: Great Plains Region, Denver Office
Email: [e-mail]
Phone: [phone] ext. 14304

Name: Craig Kormylo
Title: District Manager, VP Technical
Region: Great Plains Region
Email: [e-mail]
Phone: [phone]

GP043AS-036949-PP-796 48 of 48