10.5 Implementation Procedures
A step-by-step description for implementing the method is provided below:
(1) Prepare initial limits and test plans.
• Determine the Tier III metal emission limit. The Tier II metal emission limit may also be used (see s.
NR 666.106).
• Determine the applicable PM emission standard. This standard is the most stringent particulate emission standard that applies to the facility. A facility may elect to restrict itself to an even more stringent self-imposed PM emission standard, particularly if the facility finds that it is easier to control particulate emissions than to reduce the kiln dust concentration of a certain metal (i.e., lead).
• Determine which metals need to be monitored (i.e., all hazardous metals for which Tier III emission limits are lower than PM emission limits—assuming PM is pure metal).
• Follow the compliance procedures described in Subsection 10.6.
• Follow appropriate guidelines for preparing test plans and waste analysis plans for the following tests:
- Compliance tests to determine limits on metal feedrates in pumpable hazardous wastes and in all hazardous wastes (as well as to determine other compliance parameters);
- Initial tests to determine enrichment factors;
- Quarterly tests to verify enrichment factors;
- Analysis of hazardous waste feedstreams; and
- Daily and/or weekly monitoring of kiln dust for continuing compliance.
(2) Conduct tests to determine the enrichment factor.
• These tests shall be conducted within a 14-day period. No more than 2 tests may be conducted in any single day. If the tests are not completed within a 14-day period, they shall be repeated.
• Simultaneous stack samples and kiln dust samples shall be taken.
- Stack sampling shall be conducted with the multiple metals train according to procedures provided in section 10.3 of this Methods Manual.
- Kiln dust sampling shall be conducted as follows:
- Follow appropriate sampling and analytical procedures such as those described in the waste analysis plan as they pertain to the condition and accessibility of the dust.
- Samples should be representative of the last ESP or Fabric Filter in the APCS series.
• The feedrates of hazardous metals in all pumpable hazardous waste streams and in all hazardous waste streams shall be monitored during these tests. It is recommended (but not required) that the feedrates of hazardous metals in all feedstreams also be monitored.
• At least 10 single (noncomposited) runs are required during the tests.
- The facility shall follow a normal schedule of kiln dust recharging for all of the tests.
- Three of the first 5 tests shall be compliance tests in conformance with s.
NR 666.103(3); i.e., they shall be used to determine maximum allowable feedrates of metals in pumpable hazardous wastes. and in all hazardous wastes, as well as to determine other compliance limits (see s.
NR 666.103(3)(a)).
- The remainder of the tests need not be conducted under full compliance test conditions; however, the facility shall operate at its compliance test production rate, and it shall burn hazardous waste during these tests such that the feedrate of each metal for pumpable and total hazardous wastes is at least 25% of the feedrate during compliance testing. If these criteria, and those discussed below, are not met for any parameter during a test, then either the test is not valid for determining enrichment factors under this method, or the compliance limits for that parameter shall be established based on these test conditions rather than on the compliance test conditions.
• Verify that compliance emission limits are not exceeded.
- Metal emissions may not exceed Tier III (or Tier II) limits.
- PM emissions may not exceed the most stringent of applicable PM standards (or an optional self-imposed particulate standard).
• The facility shall generate normal, marketable product using normal raw materials and fuels under normal operating conditions (for parameters other than those specified under this method) when these tests are conducted.
• Chromium shall be treated as a special case:
- The enrichment factor for total chromium is calculated in the same way as the enrichment factor for other metals (i.e., the enrichment factor is the ratio of the concentration of total chromium in the emitted particulate matter to the concentration of total chromium in the collected kiln dust).
- The enrichment factor for hexavalent chromium (if measured) is defined as the ratio of the concentration of hexavalent chromium in the emitted particulate matter to the concentration of total chromium in the collected kiln dust.
(3) Use the enrichment factors measured in Step 2 to determine EF95% , EF99% , and SEF.
• Calculate EF95% and EF
99% according to the t-distribution as described in Appendix A
• Calculate SEF by
- Equation 4a if EF95% is determinable and if EF99% is greater than 2 times EF95% ,
- Equation 4b if EF95% is determinable and if EF99% is not greater than 2 times EF95% ,
- Equation 4c if EF95% is not determinable.
The facility may choose to set an even more conservative SEF to give itself a larger margin of safety between the point where corrective action is necessary and the point where a violation occurs.
(4) Prepare certification of compliance.
• Calculate the “conservative" dust metal concentration limit (DMCLc) using Equation 5.
- Chromium is treated as a special case. The “conservative" kiln dust chromium concentration limit is set for total chromium, not for hexavalent chromium. The limit for total chromium shall be calculated using the Tier III (or Tier II) metal limit for hexavalent chromium.
- If the stack samples described in Step 2 were analyzed for hexavalent chromium, the SEF based on the hexavalent chromium enrichment factors (as defined in Step 2) shall be used in this calculation.
- If the stack samples were not analyzed for hexavalent chromium, then the SEF based on the total chromium enrichment factor shall be used in this calculation.
• Calculate the “violation" dust metal concentration limit (DMCLv) using Equation 3 if EF95% is determinable, or using Equation 6 if EF95% is not determinable.
- Chromium is treated as a special case. The “violation" kiln dust chromium concentration limit is set for total chromium, not for hexavalent chromium. The limit for total chromium shall be calculated using the Tier III (or Tier II) metal limit for hexavalent chromium.
- If the stack samples taken in Step 2 were analyzed for hexavalent chromium, the EF95% based on the hexavalent chromium enrichment factor (as defined in Step 2) should be used in this calculation.
- If the stack samples were not analyzed for hexavalent chromium, the EF95% based on the total chromium enrichment factor shall be used in this calculation.
• Submit certification of compliance.
• Steps 2-4 shall be repeated for recertification, which is required once every 3 years (see s.
NR 666.103(4)).
(5) Monitor metal concentrations in kiln dust for continuing compliance, and maintain compliance with all compliance limits for the duration of interim license.
• Metals to be monitored during compliance testing are classified as either “critical" or “noncritical" metals.
- All metals shall initially be classified as “critical" metals and be monitored on a daily basis.
- A “critical" metal may be reclassified as a “noncritical" metal if its concentration in the kiln dust remains below 10% of its “conservative" kiln dust metal concentration limit for 30 consecutive daily samples. “Noncritical" metals shall be monitored on a weekly basis.
- A “noncritical" metal shall be reclassified as a “critical" metal if its concentration in the kiln dust is above 10% of its “conservative" kiln dust metal concentration limit for any single daily or weekly sample.
• Noncompliance with the sampling and analysis schedule prescribed by this method is a violation of the metals controls under s.
NR 666.103.
• Follow the sampling, compositing, and analytical procedures described in this method and in other appropriate methods, as they pertain to the condition and accessibility of the kiln dust.
• Follow the same procedures and sample at the same locations as were used for kiln dust samples collected to determine the enrichment factors (as discussed in Step 2).
• Samples shall be collected at least once every 8 hours, and a daily composite shall be prepared according to appropriate procedures.
- At least one composite sample is required. This sample is referred to as the “required" sample.
- For QA/QC purposes, a facility may elect to collect 2 or more additional samples. These samples are referred to as the “spare" samples. These additional samples shall be collected over the same time period and according to the same procedures as those used for the “required" sample.
- Samples for “critical" metals shall be daily composites.
- Samples for “noncritical" metals shall be weekly composites. These samples can be composites of the original 8-hour samples, or they can be composites of daily composite samples.
• Analyze the “required" sample to determine the concentration of each metal.
- This analysis shall be completed within 48 hours of the close of the sampling period. Failure to meet this schedule is a violation of the metals standards of s.
NR 666.103.
• If the “conservative" kiln dust metal concentration limit is exceeded for any metal, refer to Step 8.
• If the “conservative" kiln dust metal concentration limit is not exceeded, continue with the daily or weekly monitoring (Step 5) for the duration of interim license.
• Conduct quarterly enrichment factor verification tests, as described in Step 6.
(6) Conduct quarterly enrichment factor verification tests.
• After certification of compliance with the metals standards, a facility shall conduct quarterly enrichment factor verification tests every 3 months for the duration of interim license. The first quarterly test shall be completed within 3 months of certification (or recertification). Each subsequent quarterly test shall be completed within 3 months of the preceding quarterly test. Failure to meet this schedule is a violation.
• Simultaneous stack samples and kiln dust samples shall be collected.
• Follow the same procedures and sample at the same locations as were used for kiln dust samples and stack samples collected to determine the enrichment factors (as discussed in Step 2).
• At least 3 single (noncomposited) runs are required. These tests need not be conducted under the operating conditions of the initial compliance test; however, the facility shall operate under the following conditions:
- It shall operate at compliance test production rate.
- It shall burn hazardous waste during the test, and for the 2-day period immediately preceding the test, such that the feedrate of each metal for pumpable and total hazardous wastes consist of at least 25% of the operating limits established during the compliance test.
- It shall remain in compliance with all compliance parameters (see s.
NR 666.103(3)(a)).
- It shall follow a normal schedule of kiln dust recharging.
- It shall generate normal marketable product from normal raw materials during the tests.
(7) Conduct a statistical test to determine if the enrichment factors measured in the quarterly verification tests have increased significantly from the enrichment factors determined in the tests conducted in Step 2. The enrichment factors have increased significantly if all 3 of the following criteria are met:
• By applying the t-test described in Appendix A, it is determined that the enrichment factors measured in the quarterly tests are not taken from the same population as the enrichment factors measured in the Step 2 tests;
• The EF95% calculated for the combined data sets (i.e., the quarterly test data and the original Step 2 test data) according to the t-distribution (described in Appendix A) is more than 10% higher than the EF95% based on the enrichment factors previously measured in Step 2; and
• The highest measured kiln dust metal concentration recorded in the previous quarter is more than 10% of the “violation" kiln dust concentration limit that would be calculated from the combined EF95% .
If the enrichment factors have increased significantly, the tests to determine the enrichment factors shall be repeated (refer to Step 11). If the enrichment factors have not increased significantly, continue to use the kiln dust metal concentration limits based on the enrichment factors previously measured in Step 2, and continue with the daily and/or weekly monitoring described in Step 5.
(8) If the “conservative" kiln dust metal concentration limit was exceeded for any metal in any single analysis of the “required" kiln dust sample, the “spare" samples corresponding to the same period may be analyzed to determine if the exceedance was due to a sampling or analysis error.
• If no “spare" samples were taken, refer to Step 9.
• If the average of all the samples for a given day (or week, as applicable) (including the “required" sample and the “spare" samples) does not exceed the “conservative" kiln dust metal concentration limit, no corrective measures are necessary; continue with the daily and/or weekly monitoring as described in Step 5.
• If the average of all the samples for a given day (or week, as applicable) exceeds the “conservative" kiln dust metal concentration limit, but the average of the “spare" samples is below the “conservative" kiln dust metal concentration limit, apply the Q-test, described in Appendix A, to determine whether the “required" sample concentration can be judged as an outlier.
- If the “required" sample concentration is judged an outlier, no corrective measures are necessary; continue with the daily and/or weekly monitoring described in Step 5.
- If the “required" sample concentration is not judged an outlier, refer to Step 9.
