UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 8
1595 Wynkoop Street
DENVER, CO 80202-1129
Phone 800-227-8917
http://www.epa.gov/region08

Ref: 8ENF-AT

Elizabeth A. Lowes
EG&G Defense Materials, Inc.
Department of the Army
US Army Chemical Materials Agency
Tooele Chemical Agent Disposal Facility
11620 Stark Road
Stockton, Utah 84071
Thaddeus A. Ryba, Jr.
TOCDF Site Project Manager
Department of the Army
US Army Chemical Materials Agency
Tooele Chemical Agent Disposal Facility
11620 Stark Road
Stockton, Utah 84071

Re: Response to Request to Revise the

Environmental Protection Agency (EPA)
Approval of the Manual Mercury Emission
Measurement during the Mustard Agent
Processing in the Metal Parts Furnace (MPF)
and Liquid Incinerators (LICs)
Dear Ms. Lowes and Mr. Ryba:
This letter approves a revision to Condition #2 of EPAs June 29, 2009 letter (copy
enclosed) which approved, with conditions, your March 11, 2009 request to revise the methods
used to determine compliance with the mercury (Hg) emission limit on the Metal Parts Furnace
(MPF) and the Liquid Incinerators (LICs). Specifically, the March 11, 2009 letter requested
revision of the previously approved Alternative Monitoring Request (AMR) pertaining to the
Manual Hg Emission Measurement method used during the Mustard Agent Processing in the
Tooele Chemical Agent Disposal Facilitys (TOCDFs) MPF, and to add the Manual Hg
Emission Measurement method on the LICs. TOCDF operates the MPF and LICs which are
subject to the National Emission Standard for Hazardous Air Pollutants for Hazardous Waste

Combustors (HWCs) found at 40 C.F.R. Part 63, Subpart EEE. EPA approved prior AMRs
under the authority retained by EPA for major AMRs in the National Emission Standard for
Hazardous Air Pollutants for Hazardous Waste Combustion (HWC) found at 40 C.F.R.
63.1214(c)(3).
In a September 1, 2009 email, Drew Papadakis, EG&G Defense Materials, Inc., requested
several changes to EPAs June 29, 2009 AMR approval letter. At this time, EPA is addressing
one of the requested changes. Specifically, Condition #2 of EPAs June 29, 2009 letter indicates,
among other things, that during the Non-Baseline Processing Phase, the sampling period for the
Appendix K System sorbent tube trap sets shall be no greater than 12 hours. Mr. Papadakis
requested that that the no greater than 12 hours be revised to no greater than 12 hours (plus or
minus 30 minutes to allow for unforeseen events).
TOCDF is requesting that the plus or minus 30 minutes to allow for unforeseen events
be included for the 12-hour sampling timeframes for several reasons.
First, it is necessary for TOCDF to have a consistent sample start and stop times.
Without the 30-minute leeway, the sample start and stop time would be ever-changing.
Typically, there is a 5-minute overlap between the new sample being started and the
sample being removed because of the requirement for continuous sampling.
Second, due to safety issues, a technician may not be able to access the sample location
(e.g., agent alarm).
Third, technical issues with the sampling equipment being prepared (e.g., failed leak
check, sample probe overheating, and sampling console (meter box) failure) may need to
be addressed before replacing the sample. Historically, it has taken 30-minues to address
these types of issues. The overlap is done to ensure that the sample that just started is
being collected properly (i.e., the meter-box, probes, thermocouples, data logger, etc., are
functioning correctly) before the previous sample is stopped.
EPA is approving the change to Condition #2 because TOCDF has confirmed that even
though the start or stop time may vary by up to 30 minutes, TOCDF will sample continuously.
For those periods where the start or stop time varies by 15 minutes or more, TOCDF will provide
a reason code in its reporting to explain why sampling was plus or minus 15 minutes or more.
Additionally, TOCDF confirmed that historically they have only needed to extend the sampling
times a handful of times. Finally, EPA believes the change in Condition #2 is approvable for
the reasons expressed on our June 29, 2009 letter.
Revised Condition #2
Sampling Period and Analysis
During the Baseline Processing Phase, the sampling period for the Appendix K System
sorbent tube trap sets shall be no greater than 4 hours (plus or minus 30 minutes to allow
for unforeseen events) during such time that waste is being processed. During periods of
extended idle, where no waste feed is being processed in the primary combustion
chamber (PCC), the sampling period may exceed 4 hours but shall be no greater than 12
hours.
2

During the Non-Baseline Processing Phase, the sampling period for the Appendix K
System sorbent tube trap sets shall be no greater than 12 hours (plus or minus 30 minutes
to allow for unforeseen events). However, TOCDF will revert to 4-hour Appendix K
System sampling periods when break-through of 100 g/dscm of Hg, corrected to 7 %
O2, measured with a non-certified Ohio Lumex analyzer, occurs between beds three and
four, in any PFS. (Reference to a non-certified Ohio Lumex analyzer here, and in
subsequent conditions, means that the analyzer has not been certified against EPAs
Performance Standards. However, the analyzer shall undergo daily calibration and the
meter box, used to collect the samples, shall undergo quarterly calibration.)
EPA will address the other two changes in Mr. Papadakis September 1, 2009 email in a
subsequent letter. Note that pursuant to 40 C.F.R. 63.8(f)(5)(iii), once EPA approves the use of
an alternative monitoring method for an affected source under 63.8(f)(5)(i), the owner or
operator of such source shall continue to use the alternative monitoring method until he or she
receives approval from the Administrator to use another monitoring method as allowed by
63.8(f).
Please note that the approval made above is subject to further review if there is reason to
believe that an alternative monitoring requirement fails to provide an equivalent or better
assurance of compliance with the relevant emission standard in 40 CFR Part 63 Subpart EEE. If
you have any questions or concerns, please feel free to contact Laurie Ostrand of my staff at
(303) 312-6437.
Sincerely,

Cynthia J. Reynolds, Director

Technical Enforcement Program

Enclosure
cc:

Joe Randolph, UDAQ

Deb Ng
Division of Solid and Hazardous Waste
P.O. Box 144880
Salt Lake City, UT 84114-4880
Carol Smith, 8ENF-AT
Mike Owens, 8P-AR