Date: 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 5 

November 8, 2007 

77 WEST JACKSON BOULEVARD 

CHICAGO, IL 60604-3590 

MEMORANDUM 

Subject: 

From: 

To: 

Review of the Waste Analysis Plan for Trade Waste Incineration, TWI-WAP 

Revision 2, 11117/2000 

Todd D. Ramaly ~/L_ 

File 

I reviewed the Waste Analysis Plan for Trade Waste Incineration (W AP), dated November 17, 

2000, for the Veolia ES Technical; Solutions, L.L.C.'s (Veolia's) incineration facility in Sauget, 

Illinois. I prepared the following comments to assess the WAP's consistency with proposed 

permit conditions that would require Veolia to quantify the amount of mercury fed to the 

incinerator system to demonstrate compliance with feed rate limits on mercury. 

p.3 1.0 Introduction What about fuels? Are fuels screened for mercury? Are there any other 

non waste feedstocks? 

p.S 2.2 Type of Containment Why limit sampling to whole sample mixtures of the phases of 

multi-phase wastestreams? How would they be adequately mixed for extraction? Clearly 

distinct phases (organic liquid floating on aqueous liquid, etc) should be individually analyzed at 

least once due to the difficulty in obtaining a truly homogenized sample of immiscible phases. 

Otherwise, please specify a procedure for ensuring a homogenous sample for analysis. 

p.S 3.0 Analytical Rationale Specific mandatory or supplemental analyses should not be 

waived by facility management due to safety hazard in laboratory. The analytical information 

should be obtained from a lab equipped to safely handle the material or you shouldn't accept the 

waste in the first place. 

p.9 3.1 Mandatory Analyses, Figure 3-1, etc. Total mercury must be added as a mandatory 

analysis for all feedstreams 

p.17 4.1.4 Exceptions to the Foregoing Requirements Packaged chemicals should be 

evaluated for the presence of mercury and debris should be sampled for mercury to the greatest 

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extent practicable. For example, waste test tubes from some brands of chemical oxygen demand 

(COD) test kits might be considered debris, yet they contain significant amounts of mercury and 

other toxic substances. Under the current procedure, they could potentially be exempt from 

mercury screening. 

Why is single source spill material exempted from sampling requirements? Could soil or other 

debris be considered single source spill material (under a leaking product tank, for example)? 

How do we know that the soil doesn' t already contain other substances like mercury? What 

about contaminated PPE, batteries, etc. All of the items listed in Section 4.1.4 could be 

contaminated with mercury. It is not acceptable to exempt them from mandatory sampling. 

Lastly, the definition of empty container is incomplete. TheW AP ignores 35 lAC 107(b)(l)(A) 

which says the container must be empty as achieved by standard methods (for example, an inch 

of easily flowing, non viscous liquid should not be allowed to remain in the container since it 

should be easily poured out). The WAP also ignores 35 lAC 107(b)(l)(C)(ii) where containers 

larger than 119 gallons in capacity must be emptied to 0.3% of weight not 3% (although I 

understand this is a recent addition to the lAC). 

p.18 4.1.5 Standard Profiles All incoming wastestreams should be screened for mercury 

content, even if they are considered consistent with a "standard" profile. 

p.26 5.1.1 Exceptions to Incoming Waste Analysis Procedures (2) The discussion of "RCRA 

empty" containers is missing 35 lAC 107 (b)(1)(A) and (b)(l)(C)(ii). See comment on section 

4.1.4 above. 

p.26 5.1.1 Exceptions to Incoming Waste Analysis Procedures Any of these wastestreams 

could contain mercury. All wastestreams should be screened for mercury without exception. 

See comment above for section 4.1.4. 

p. 28 5.2.3 An Evaluation of Whether a Waste is Found to be in Conformance or 

Nonconformance and Appendix WAP-D The Incoming Waste Conformance/NonConformance requirements are dangerously deficient. Specifically, the acceptable ranges listed 

under the pH screen are too broad. In a terrible incident at a similar facility, a waste's incoming 

pH disagreed with that listed on the profile by 6 or 7 standard units, even though both 

measurements were between 2 and 12.5. In fact, the waste had changed from an acid to a base 

(or vice versa). As it turned out, the change in pH was chemically important, the waste had been 

misidentified by the generator, explosive crystals fonned, and an explosion dming handling 

killed a worker. There is no reason to believe the Veolia W AP would prevent such an incident 

as written. The approach to nonconformance must be more rigorous. I recommend reporting an 

actual pH measurement on the profile and identifying incoming shipments as non-conforming if 

pH differs by 2 or more standard pH units. I also recommend expanding on the definition of 

nonconforming with regards to other physical and chemical properties such as the existence or 

absence of specific phases noted on the profile, color changes, strong odors (if noticed despite 

respiratory protection), etc. 

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p.33 6.3.1 Pre-Treatment Analyses You must add mercury analysis to wastestreams altered by 

blending for wastes to be incinerated. 

p.35-36 Quality Assurance/Quality Control Peiformance parameters and quality procedures 

should be provided in the WAP. The WAP should also provide for data validation and 

documentation. TheW AP is completely deficient in this regard. I recommend referring to 

Region 5's RCRA Quality Assurance Project Plan (QAPP) guidance. 

U.S. EPA initially conveyed these comments to Veolia informally on October 9, 2007 during a 

conference call between representatives of the United States Environmental Protection Agency 

(U.S EPA), Veolia, and the Illinois Environmental Protection Agency (IEPA). 

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