1 

### Ogulei, David

From: **Marshall, Sarah** Sent: **Wednesday, May 06, 2015 9:25 AM** To: **Ogulei, David** Subject: **FW: CPT Plan**

Sarah Marshall Section Chief MI/WI Section Air Enforcement and Compliance Assurance Branch U.S. Environmental Protection Agency, Region 5

312-886-6797

From: Downey, Shannon

Sent: Wednesday, July 17, 2013 10:40 AM

To: Dennis J Warchol

Cc: David A Klarich; Marshall, Sarah Subject: RE: CPT Plan

Dennis and Dave,

Based on our discussion on July 15, 2013, it is EPA ’s understanding that after Veolia incorporates th e changes we discussed during the call, there are still two issu es left to resolve in order for EPA to approve Veol ia’s CPT and QAPP. We propose to resolve the remaining two issues as spec ified below. If Veolia submits an approvable CPT a nd QAPP, that addresses all of our comments, by Friday, July 19, 2013, EPA is willing to grant a two week extension to Veolia’s test date, which would put the CPT date at September 19, 2013.

Thank you for the information about the target Hg c oncentrations. We look forward to the rest of the i nformation discussed on Monday about the spike preparation.

Item 1: Historical data of the waste Veolia plans t o burn during the test

Based on the first paragraph of your below email, E PA is concerned that Veolia is using wastes that it has limited or no data about and has never before received to represe nt normal operating conditions during this test. P lease provide EPA with information that demonstrates why Veolia belie ves these new waste streams are in fact representat ive of Veolia’s current operating conditions.

For each waste stream that has never been received before by Veolia, please provide the profile, along with any profile sampling that has been done by Veolia and/or the ge nerator, and any other generator information about the waste

stream.

For any waste streams for which Veolia has limited data, please still provide the limited data (includ ing acceptance sampling) in addition to any profile sampling that has been done by Veolia and/or the generator, and a ny other generator information about the waste stream.

During the July 15, 2013 call, EPA suggested Veolia sample the waste streams being fed during the test every 15
minutes. We recommend that Veolia include this rat e in the CPT for the solid and liquid waste streams

.

Item 2: Test Conditions. Conditions 1 and 2 refer t o the conditions described in EPA’s email sent on J uly 11, 2013.2 EPA has had numerous discussions with Veolia about what we consider to be representative operating con ditions during the CPT. During the June 12, 2013 meeting, EPA expl ained the importance of conducting a test that was both representative and at the extreme range of normal, as required under 40 C.F.R § 63.1207(g). To that end, EPA cannot approve a plan where the metals OPL is set during m inimum temperature testing conditions on Units 2, 3 , and 4.

Furthermore, on Unit 4 only, EPA needs Veolia to de monstrate that D/F and metals are simultaneously co ntrolled well enough at the current carbon feedrate when D/F and metals are each maximized. Metals emissions cannot be maximized at a minimum temperature. Veolia has stat ed it has concerns about how the OPLs will be set i n this scenario. EPA wants to clarify that Veolia must demonstrate w hether mercury emissions pass or fail the MACT stan dards during
EPA’s Condition 2 as well as EPA’s Condition 1. Sim ilarly , Veolia must demonstrate whether D/F emissions pas s or fail the MACT standards during EPA’s Condition 1, as well as EPA’s Condition 2. If the metals pass during EPA’s Condition 2, Veolia will not need to average these numbers with the three runs when it conducts EPA’s Condition 1. The same will be true for the D/F run during EPA’s Condition 1 run.

Please do not hesitate to contact me if you have fu rther questions.

Shannon Downey Environmental Engineer Air Enforcement & Compliance Assurance Branch U.S. Environmental Protection Agency, Region 5, (AE -17J)
77 W. Jackson Blvd Chicago, IL 60604

Tel: (312) 353-2151 Fax: (312) 385-5398

Protecting the environment is everyone’s responsibi lity. Help EPA fight pollution by reporting possib le harmful environmental activity. To do so, visit EPA’s websi te at http://www.epa.gov/compliance/complaints/index.html

From: Dennis J Warchol [ mailto:dennis.warchol@veoliaes.com ]
Sent: Tuesday, July 16, 2013 4:08 PM
To: Downey, Shannon Cc: David A Klarich Subject: CPT Plan

Shannon,

After reviewing the potential list of liquid and so lid waste stream candidates for the CPT, we are fin ding that some of
these streams have never been received before and o thers have limited data due to a lack of being rece ived. In order to satisfy the Agency’s concerns of waste stream heter ogeneity, Veolia is concerned that with the data av ailable we will not
be able to do this.

As a solution to this comment, Veolia is proposing to modify the CPT to require sampling of all liquid and solid waste streams every 30 minutes. This was proposed as a s olution from USEPA if there was a lack of data for solids. Veolia, in order to satisfy the Agency’s concern, is proposin g that all waste feeds be sampled every 30 minutes regardless of previous available data.

Let us know if that is acceptable and we will incor porate that into the Plans.

Also, during our call yesterday, it was requested t hat we provide anticipated Hg spike concentrations and target Hg feed. Veolia is anticipating that the Hg spike con centration for Unit 4 will be approximately 2% and Units 2 and 3’s will be approximately 1000 ppm. Hg feed rates will be a pproximately 0.04 lbs/hr for Unit 4 and Units 2 and 3’s will be3 approximately 0.002 lbs/hr. The target concentrati ons and feed rates will be better defined when the spike material is prepared and the feed streams are determined.

Please call Dave or me if you have any questions.

**SERVICE FIRST SAFETY ALWAYS**

**Dennis J. Warchol EHS Manager** 

**Veolia ES Technical Solutions, L.L.C. Trade Waste Incineration Facility**  **#7 Mobile Avenue Sauget, IL 62201**  **618-271-2804 (ext.169) 618-271-2128 (fax)**  **Dennis.warchol@VeoliaES.com www.VeoliaES.com** 

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