MEMORANDUM

Date: February 9, 2015

Subject: Report of June 25, 2014 Site Visit to Veolia in Port Arthur, Texas

From: Alden West, EC/R Incorporated 

Lesley Stobert, EC/R Incorporated

To: Paula Hirtz, EPA/OAQPS

This memorandum summarizes the visit to the Veolia facility in Port Arthur, Texas that was 

conducted on June 25, 2014. The purpose of this visit was 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 by 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. The 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 technology, 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, 1996 (61 FR 34139) and codified at 40 CFR part 63, 

subpart DD. The 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 periodically revisit the 

technology-based standards. Specifically, section 112(d)(6) states that the EPA shall review 

these standards and revise them “as necessary (taking into account developments in practices, 

processes, and control technologies)” no less frequently 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, taking 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) conducted under the Clean Air Act.

A site visit of the Veolia 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 surrounding 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 Port 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 incineration 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) commercially. While currently 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 those 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 by 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 is 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

based 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 reanalyzed 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 analysis 

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, waste from the pits and drum chute are shredded

and blended under a nitrogen blanket, then pumped via a Putzmeister 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 ISO portable tanks. 

The facility operates direct injection lines where liquids 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. Liquids 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 every 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 by the quench system, Veolia 
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does not need to operate additional back-end pollution controls for these compounds. 

Combustion gases are vented from the quench system to the back-end pollution control systems, 

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. 

Veolia is currently testing a calciner pilot plant for recovery of nickel and molybdenum from 

offsite waste streams. 

EMISSION SOURCES

Emission sources at Veolia include containers, mix pits, tanks, fugitives, transfer systems, and 

control devices. Veolia operates an RTO as a control device for emissions from storage tanks, 

mix pits and shredders. 

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 storage, 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 operating 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 system to the RTO. All storage tanks are equipped with 

PRVs 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 than 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 and 
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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 quarterly monitoring 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 systems are a potential source of emissions at Veolia that are subject to the OSWRO 

MACT standards. Transfer systems 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 containers 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 

usually 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 types of tanks should be designated as “in liquid service”. 

 EPA agreed to send Veolia a copy of the Federal Register notice for the proposed 

amendments to the OSWRO MACT standards.