**MEMORANDUM**

Date: February

9 , 201 5 Subject: Report of June 2 5 , 2014 Site Visit to Veolia in Port Arthur , T exas From: Alden West, EC/R Incorporated

Lesley Stobert, EC/R In corporated To: Paula Hirtz, EPA/OAQPS

This memo randum summarizes the visit to the Veolia facility in Port Arthur , Texas that was conducted on June 2 5 , 2014 . The purpose of this visit w as to better understand the processes used in the Offsite Waste and Recovery Operations (OSWRO) industry , the controls in place to reduce hazardous air pollutants (HAP) emissions, and the characteristics of the emission points at this facility

. This information will assist the EPA in the promulgation of amendments to the emission standards for the OSWRO industry

. A background discussion of this project is provided , followed b y an overview of the facility , a description of the off

- site waste operations at the facility , and a summary of emission sources at the facility . T he final section includes a summary of action items resulting from the meeting with Veolia

. The participants in the site visit included the following:

Randa Coffey , Veolia Ron Constance , Veolia Daniel Duncan , Veolia Mitch Osborne, Veolia Paula Hirtz, U.S. EPA/OAQPS Lesley Stobert , EC/R Incorporated Alden West , EC/R Incorporated
**BACKGROUND** Section 112(d) of the Clean Air Act requires the EPA to develop standards for each major source category listed under section 112(c). These technology

- based standards are often referred to as maximum achievable control t echnology , or MACT, standards. The National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Off

- site Waste and Recovery Operations (OSWRO) were promulgated on July 1, 199 6 ( 61 FR 34139 ) and codified at 40 CFR part 63, subpart DD . Th e Veolia facility in Port Arthur , TX is subject to subpart DD because it receives certain wastes from off

- site locations for storage and treatment , recovery or disposal

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Section 112 of the Clean Air Act contains provisions requiring the EPA to periodicall y revisit the technology

- based standards. Specificall y, section 112(d)(6) states that the EPA shall review these standards and revise them “as neces sary (taking into account developments in practices, processes, and control technologies)” no less fre quently than every

eight years. The second stage in the review process focuses on reducing any remaining (i.e., “residual”) risk according to CAA section 112(f). Section 112(f)(2) directs the EPA to assess the risk remaining (residual risk) after the application of MACT standards and promulgate additional standards as necessary to provide an ample margin of safety to protect public health, or to prevent, ta king into consideration costs, energy , safety, and other relevant factors, an adverse environmental impact. On May 30, 2014, the EPA proposed amendments to the OSWRO MACT standards to address the results of the residual risk and technology review (RTR) conducte d under the Clean Air Act. A site visit of the Ve o lia facility was conducted to better understand the current processes and control technologies in the OSWRO industry before promulgation of final amendments to the OSWRO MACT standards. As part of the RTR process, the EPA is seeking additional information to improve the Agency ’s understanding of the OSWRO processes and emission points, to improve the data used in site

- specific emission profiles and to better characterize the maximum risks to surroun ding populations as a result of activities at OSWRO facilities

. Further , the May 30, 2014 proposal includes new provisions that may change the way certain OSWRO sources are required to operate . This site visit was conducted to better understand the technical and operational implications of these changes based on current processes observed at the facility and discussions with facility personnel

. **PLANT SITE OVERVIEW** Veolia Environmental Services is a global company based in Paris with over $49 billion in revenue and is the largest environmental services company in the world. Veolia manages two incineration service locations in the United States, including the facility in Po rt Arthur, Texas. The Port Arthur facility is permitted under the Resources Conservation and Recovery Act (RCRA) as a hazardous waste Treatment Storage and Disposal Facility ( TSDF )

. At this location, Veolia operates a rotary

kiln and ancillary

units for in cineration of hazardous waste , two injection wells for waste disposal , and a regenerative thermal oxidizer (RTO) for control of HAP from offsite waste emission sources. The facility is one of three in the United States that is permitted to burn polychlorinated biphenyls ( PCBs ) commerciall y. While currentl y not permitted to treat F
- listed dioxins, facility personnel indicated that they will soon be revising their permit to be able to incinerate those compounds. **PROCESS DESCRIPTION** As noted above , the processes of interest at this site are th ose regulated by the OSWRO MACT standards . The description provided below is a summary developed from materials provided during the site visit and from notes taken based on discussions with Veolia personnel

. Wastes accepted b y Veolia include: aerosols; drum liquids, solids, and sludges ; bulk liquids solids and sludges; lab packs; cylinders; and PCB capacitors. Drums and other smaller non - bulk containers are stored on racks in the container storage facility , which is a large open

- air building

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When a waste submitted for approval i s received, Veolia first determines if it can be handled at the facility and if it is subject to subpart DD (OSWRO MACT) . This determination is made bas ed on a waste profile provided by the generator that includes a list of HAP constituents

. Wastes containing Subpart DD constituents are inspected to determine if they are leaking. Leaking containers are resealed and reanal yz ed for leaks ; if the container is still leaking it will be stored under a hood to collect and control vapors before it is delivered directly to the incinerator

. All waste streams are sampled unless they are exempted according to the facility ’s waste analy sis plan (WAP ). Containers can be burned individually by conveyance to the incinerator or they are conveyed to the mix pits for further processing

. Veolia operates two pits where bulk and drum wastes are mixed based on BTU content. One pit contains low flash wastes and the other contains high flash wastes. High flash wastes ignite at temperatures greater than 140 ° F
. The facility also operates two shredders and a blender /homogenizer

. On the low flash side, w aste from the pits and drum chute are shredded and blended und er a nitrogen blanket , then pumped via a P utzmeister concrete pump to the incinerator, or waste is shredded and transferred directly to the incinerator on a conveyor. The doors to the mix pit area are open to the atmosphere; however, negative pressure is maintained in the building and emissions are vented through a particulate filter bag

- house to the RTO

. Emissions from the shredders are also vented to the RTO. Bulk solids are delivered to the facility in roll

- off boxes that are sampled upon arrival in an enclosed building that is vented to a carbon adsorber. The facility is subject to the level 2 controls for containers (40 CFR §63.923), which require no detectable emissions (i.e., < 500 parts per million (ppm) ) based on Method 21 monitoring. Bulk liquid wastes are delivered to Veolia in cargo tanks and/or trailers with I SO portable tanks

. The facility

operates direct injection lines where liquid s are pumped from the truck directly to the incinerator. The direct injection lines are only used for certain types of liquid wastes than cannot be mixed with others. Li quids are also stored in tanks that range in size from 10,000 to 100,000 gallons. All storage tanks are equipped with fixed roofs and nitrogen blankets to suppress emissions

. Vapors originating from normal pressure fluctuations in the tank are routed to the RTO. Tanks are also equipped with pressure relief valves (PRVs) that release vapors to the atmosphere to relieve emergency pressure buildup. PRVs are monitored ev ery five days using Method 21 . The facility

has no instrumentation in place to determine the exact time or duration of a release or the amount of HAP that was released from a PRV
. However, Veolia indicated that they have monitors that surround the tank to detect a release of hydrocarbons above a concentration threshold. Veolia operates a 60 foot long rotary kiln permitted under RCRA to treat/incinerate offsite wastes. Wastes are carefully selected for incineration based on BTU content and other factors to maintain optimal conditions in the kiln. An imbalance of BTU content in the waste can result in higher carbon monoxide levels at the exhaust stack. Combustion gases from the kiln are vented to a secondary

combustion chamber, then to a rapid quench unit. The quench unit cools the incinerator exhaust from approximately 2000 ° F to 185 ° F in one second. The rapid cool down of exhaust gasses limits residence time in the formation temperature of dioxins and furans, which is 500 ° F to 800 ° F
. Because dioxin and furan formation is prevented b y the quench s ys tem, Veolia4

does not need to operate additional back

- end pollution control s for these compounds. Combustion gases are vented f ro m the quench sy stem to the back

- end pollution control sy stems, an acid gas scrubber, a wet particle scrubber, and a wet electrostatic precipitator. The treated gas is then vented through a single stack equipped with a continuous emissions monitoring system (CEMS). Veolia operates injection wells in which scrubber blowdown from the incinerator, which contains metals and various salts, is injected into the ground for disposal. Veol ia is currently testing a calciner pilot plant for recovery of nickel and moly

bdenum from offsite waste streams. **EMISSION SOURCES** Emission sources at Veolia include containers, mix pits, tanks, fugitives, transfer s ys tems, and control devices

. Veolia operates an RTO as a control device for emissions from storage tank s , mix pit s and shredder s. Drums and other containers placed in the container storage facilities are sealed by a cover and closure device

. The container storage facilities are not enclosed and hazardous vapors from leaking containers or sampling are emitted to the atmosphere. Subpart DD containers are monitored once for leaks when they are received. Leaking containers that cannot be resealed are placed under a hood to collect and control emissions before conveyance to the incinerator. Bulk containers are sampled for leaks upon arrival in an enclosed building that is vented to a carbon adsorber. Bulk containers are required to have no detectable emissions (< 500 ppm) based on Method 21 monitoring. Secured tarps are installed on all bulk containers to suppress emissions. Emissions from mix pits can occur from storag e, mixing, and shredding of drums and bulk solid wastes. The mix pit building is maintained at a negative pressure and emissions are vented to the RTO. Storage tank emissions can occur from the evaporation of liquid wastes placed in the tank

. The storage tanks at Veolia are equipped with fixed roofs and nitrogen blankets to reduce evaporation of tank contents to the atmosphere. Tanks are also equipped with conservation vents that provide relief from fluctuations in pressure resulting from normal op erating conditions such as filling/emptying and changes in atmospheric temperature

. The conservation vents at Veolia are set to open when the internal tank pressure reaches 0.5 psi. Vapors released by the conservation vent are routed through a closed vent sy stem to the RTO. All storage tanks are equipped with PRV s that will emit to the atmosphere if the tank internal pressure exceeds the device threshold setting for safe handling of liquid waste. The PRVs at Veolia are set to open at 2 psi, which is less th an the pressure specified in the definition of a PRV in the 2014 OSWRO proposal (2.5 psi). Veolia operates numerous valves, pump seals, flanges and other equipment components that could leak hazardous vapors to the atmosphere. Veolia complies with the leak detection and5

repair (LDAR) requirements of a new source review (NSR) permit that specifies a leak definition of 200 ppm for all components, which is more stringent than the LDAR requirements referenced by the OSWRO MACT standards

. Veolia also has an agreement with the City of Port Arthur and EPA Region 6 based on an environmental justice review to do quarterl y m onitoring of vapors at the facility

using an FLIR optical gas imaging (i.e., infrared) camera. According to Veolia, most refineries have their own optical gas imaging units; however, Veolia hires a subcontractor to conduct the monitoring. Transfer s ys tems are a potential source of emissions at Veolia that are subject to the OSWRO MACT standards

. Transfer s ys tems operated at the facility include pumps and conveyers. Pumps are used to transport liquid waste from trucks at direct injection lines to the kiln, and homogenized waste from the blender to the kiln . Conveyors are used to transport container s and solid wastes to the shredders or kiln. During the site visit, Veolia responded to a question on metals emissions from OSWRO sources. Metals are generally

not a concern with offsite waste emission sources because they have very low or no vapor pressure at ambient temperature. There are no heating processes associated with OSWRO emission sources that would raise the vapor pressure of metals to the point where evaporation could occur. While mercury has a higher vapor pressure than other metals, it is us ually combined with other compounds (e.g., phenyl mercuric acetate) from which it cannot easily evaporate. A facility

that reclaims mercury

in its pure form could potentially have higher mercury emissions; however, this operation is not conducted at Veolia

. **ACTION ITEMS**

 EPA tentatively

agreed to look into Veolia’s concerns with the “in vapor service” designation of a PRD on a fixed roof storage tank equipped with a nitrogen blanket. Veolia contends that PRD on these ty

pes of tanks should be designated as “in liquid service”.
 EPA agreed to send Veolia a cop y of the Federal Register notice for the proposed amendments to the OSWRO MACT standards

.