A-18J

Douglas Harris

General Manager

Veolia ES Technical Solutions, L.L.C.

7 Mobile Avenue

Sauget, Illinois 62201

Dear Mr. Harris:

I am writing to address Veolia Environmental Services’ (Veolia) extrapolation request

and to itemize a few of the concerns U.S. Environmental Protection Agency has identified with

the August and September 2008 performance tests at this time.

I. Request for Extrapolation

On October 10, 2008, you requested an extrapolation of feed rate levels pursuant to 40

C.F.R. § 63.1 209(l)( 1 )(v) and (n)(2)(vii). EPA is denying your request for extrapolation for the

feed rate limits at the levels you request. As discussed more fully below, we based this decision

on our review of the hazardous waste combustor maximum achievable control technology (HWC

MACT) requirements, the underlying performance test results from your August and September 2008 tests, and your October 10, 2008, request.

Pursuant to 40 C.F.R. § 63.1 209(l)( 1 )(v) and (n)(2)(vii), the HWC MACT allows subject facilities to request EPA approval of higher feed rate limits for rate low-volatile metals (LVM),

semi-volatile metals (SVM) and mercury based on extrapolation from performance test results.

In reviewing the extrapolation request, EPA considers whether the performance test metal feed

rates are appropriate, based on historical metal feed rate data, and whether the extrapolated feed

rates requested are warranted. EPA reviewed your methodology and provided comments to you

in a June 12, 2008 letter. One of our comments was:

“In order to conduct performance tests under operating conditions that

represent the extreme range of normal conditions - as 40 C.F.R.

§ 63.7(e)(1) and 63.1207(g) require -Veolia must feed each metal group

(i.e., mercury, LVM, and SVM) at no less than the highest 12-hour rolling

average during the previous 5 years.”

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would have equal system removal efficiencies at the requested extrapolated limits.

Furthermore. EPA believes that extrapolation on unit 4 is not appropriate since the tests

did not provide sufficient data to understand the relationship between the necessary amount ofcarbon needed to maintain the calculated system removal efficiency and different mercury feed

rates.

Lastly, EPA has a number of concerns with the test procedures which lead us to believe

that there may be significant uncertainty with the results. This uncertainty would only be

exacerbated by extrapolation. We describe some of these concerns below. We understand that

Veolia has submitted additional information in response to our May 28. 2009, request for

information which may provide some answers and/or additional questions not addressed in thisletter.

II. 2008 Test Burn Results

EPA has several concerns with the quality of the testing that, if verified, will significantly

affect the feed rates of LVM, SVM, and, in particular, mercury, which form the basis of yourremoval efficiency and requested extrapolated feçd rates. We believe that if Veolia operates atthe requested extrapolated feed rate levels, it may be in violation of the HWC MACT emission

limitations.

EPA is concerned with the percent moisture data as tested by Maxxam Analytics. The

Maxxam Analytics’ results are much lower than the resUlts reported by PSC Republic and EPA’s

laboratory. The feed data will not be representative of actual test burn conditions if inappropriate

moisture data are used to convert dry-weight concentrations to wet-weight, and could result in an

overstatement of metals feedrates.

EPA is concerned that Maxxam Analytics’ standard operating procedure (SOP) for

testing the mercury in the feed was not appropriate in this case because the samples were dried

prior to testing. Drying samples to be analyzed for a volatile metal could result in feed data that

is not representative oftest burn conditions.

EPA is concerned that Maxxam Analytics’ SOP for testing liquid samples was not

appropriate in this case because the samples were filtered prior to testing. Filtering samples

could result in feed data that is not representative of test burn conditions.
reviewing this information and are hopeful that it will inform us as we move forward in

developing operating parameter limits for mercury, LVM, and SVM feed rates. We are open to

meeting with you, your contractor, ENSR, and the laboratory that analyzed the test samples,

Maxxam Analytics to discuss these issues, as well as any other questions that may arise from the

review of the information you have submitted in response to the May 28, 2009, request for

information. If you have any questions regarding the letter or would like to set up a meeting to

discuss this letter, please contact Genevieve Damico, of my staff, at (312) 353-4761.

Sincerely,

C r Newton

ector

Air and Radiation Division

cc: Laurel Kroack, Illinois Environmental Protection Agency