### Date: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5



### November 8, 2007 77 WEST JACKSON BOULEVARD CHICAGO,IL 60604-3590



### MEMORANDUM Subject:

From:
To: Review ofthe 

### WasteAnalysisPlanfor Trade Waste Incineration, TWI

-WAP Revision2, 11117/2000 ToddD. Ramaly

### ~/L_ File
I reviewed the 

### Waste AnalysisPlanfor Trade Waste Incineration (WAP), dated November 17, 2000, for the VeoliaES 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 quantif y the amount ofmercury 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 ofContainment Why limit sampling to whole sample mixtures ofthe 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 ofimmisciblephases. 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 MandatoryAnalyses, Figure 3-1, etc. Total mercury must be added as a mandatory analysis for all feedstreams 

### p.17 4.1.4 Exceptions to theForegoing Requirements Packaged chemicals should be evaluated for the presence of mercury and debris should be sampled for mercury to the greatest

1extent 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 ofmercury and other toxic substances

. Underthe 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 contaminatedPPE, batteries, etc. All ofthe 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 ofempty container is incomplete. TheWAP ignores 35 lAC 107(b)(l)(A) which says the container must be empty as achieved by standard methods (for example, an inch ofeasily flowing, non viscous liquid shouldnot 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% ofweight 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 screenedfor mercury content, even ifthey 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 ofthese wastestreams couldcontain mercury. All wastestreams should be screenedfor mercury without exception. See comment above for section 4.1.4.


### p. 28 5.2.3 An Evaluation ofWhether 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 or7 standardunits, even though both measurements were between 2 and 12.5. In fact, the waste had changedfrom an acid to a base (or vice versa). As itturned 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 VeoliaWAP wouldprevent 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 otherphysical and chemical properties such as the existence or absence ofspecific phases noted on the profile, colorchanges, strong odors (ifnoticed despite respiratory protection), etc.

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### p.33 6.3.1 Pre-TreatmentAnalyses You must add mercury analysis to wastestreams altered by blendingfor wastes to be incinerated

. 

### p.35-36 Quality Assurance/Quality Control Peiformanceparameters and quality procedures should be provided in the WAP. TheWAP should also provide for data validation and documentation. TheWAP is completely deficient in this regard. I recommend referring to Region 5's RCRA Quality AssuranceProject Plan (QAPP) guidance.
U.S. EPA initially conveyed these comments to Veolia informally on October 9, 2007 during a conference call between representatives ofthe United States Environmental Protection Agency (U.S EPA), Veolia, and the Illinois Environmental Protection Agency (IEPA).

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