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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 the changes we 

discussed during the call, there are still two issues left to resolve in order for EPA to approve Veolia’s CPT and QAPP. We 

propose to resolve the remaining two issues as specified below. If Veolia submits an approvable CPT and 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 concentrations. We look forward to the rest of the information 

discussed on Monday about the spike preparation. 

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

Based on the first paragraph of your below email, EPA is concerned that Veolia is using wastes that it has limited or no 

data about and has never before received to represent normal operating conditions during this test. Please provide EPA 

with information that demonstrates why Veolia believes these new waste streams are in fact representative 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 generator, 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 (including acceptance 

sampling) in addition to any profile sampling that has been done by Veolia and/or the generator, and any 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 rate in the CPT for the solid and liquid waste streams. 

Item 2: Test Conditions. Conditions 1 and 2 refer to the conditions described in EPA’s email sent on July 11, 2013. 
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EPA has had numerous discussions with Veolia about what we consider to be representative operating conditions during 

the CPT. During the June 12, 2013 meeting, EPA explained 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 minimum temperature testing conditions on Units 2, 3, and 4. 

Furthermore, on Unit 4 only, EPA needs Veolia to demonstrate that D/F and metals are simultaneously controlled 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 stated it has concerns about how the OPLs will be set in this scenario. 

EPA wants to clarify that Veolia must demonstrate whether mercury emissions pass or fail the MACT standards during 

EPA’s Condition 2 as well as EPA’s Condition 1. Similarly, Veolia must demonstrate whether D/F emissions pass 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 further 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 responsibility. Help EPA fight pollution by reporting possible harmful 

environmental activity. To do so, visit EPA’s website 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 solid waste stream candidates for the CPT, we are finding that some of 

these streams have never been received before and others have limited data due to a lack of being received. In order to 

satisfy the Agency’s concerns of waste stream heterogeneity, Veolia is concerned that with the data available 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 solution from USEPA if there was a lack of data for solids. Veolia, in 

order to satisfy the Agency’s concern, is proposing that all waste feeds be sampled every 30 minutes regardless of 

previous available data. 

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

Also, during our call yesterday, it was requested that we provide anticipated Hg spike concentrations and target Hg 

feed. Veolia is anticipating that the Hg spike concentration for Unit 4 will be approximately 2% and Units 2 and 3’s will 

be approximately 1000 ppm. Hg feed rates will be approximately 0.04 lbs/hr for Unit 4 and Units 2 and 3’s will be 
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approximately 0.002 lbs/hr. The target concentrations 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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