Revised Title V Feedstream Analysis Permit Conditions

2.1(D)(4)(d)(ii)(B). Waste acceptance procedure.

Subject to the exemptions in condition 2.1(D)(4)(d)(ii)(F), below, the Permittee shall conduct 

representative sampling using the methods specified in 40 C.F.R. Part 261, Appendix I, of each shipment 

of waste. for mercury, LVM and SVM prior to feeding the waste into any incinerator and shall analyze 

such samples using appropriate quality assurance/quality control procedures and appropriate test 

methods that are consistent with SW-846. Each shipment of waste will be classified as either “suspect 

waste” or “non-suspect waste”. 

B. I. Suspect waste

Suspect waste is a waste stream that may contain or is expected to contain any of the MACT metals (i.e., 

arsenic, beryllium, chromium, lead, cadmium, and/or mercury). A waste stream would be classified as a 

suspect waste if the profile contains the federal waste code of any of the MACT metals, the chemical 

composition lists any of the MACT metals, or process/industry knowledge or generator knowledge of the 

waste indicates the potential for MACT metals to be present. Prior to feeding the waste to any 

incinerator, the Permittee will analyze such waste, using appropriate quality assurance/quality control 

procedures and appropriate test methods that are consistent with SW-846, or utilize the following 

analytical protocol and frequency for suspect waste:

1. The first three (3) shipments received at the facility. Each shipment will be processed using the 

metals analysis results obtained from each shipment for metals feed calculations. If any metals 

analysis result is below the reporting limit (i.e., non-detect), one-half (1/2) of the reporting limit 

will be used. For subsequent shipments received, the arithmetic mean plus two (2) standard 

deviations of the metals concentrations from the first three (3) shipments will be used for the 

next nine (9) shipments received.

2. Every tenth (10th) shipment received after the initial three (3) shipments. The metals analysis 

results from each tenth (10th) shipment will be used for metals feed calculations for that 

shipment.

3. The first (1st) shipment following a discrepant metals analysis of that waste stream. A shipment 

is discrepant for metals if the profiled range is exceeded by 100 ppm for a profiled metal 

concentration of 0-500, or if the profiled range is exceeded by 20% for a profiled metal 

concentration >500 ppm.

4. The first three (3) shipments received at the facility after a generator notifies Veolia of a change 

in the waste profile that increases the concentration of the MACT metal(s) in the waste stream.
B.II. Non-suspect waste

Non-suspect waste is a waste stream that is not expected to contain any of the MACT metals. A waste 

stream would be classified as a non-suspect waste if the profile does not contain the federal waste code 

of any of the MACT metals, the chemical composition does not list any of the MACT metals, and 

process/industry knowledge and generator knowledge of the waste indicate that MACT metals are not 

present. Prior to feeding the waste to any incinerator, the Permittee will analyze such waste, using 

appropriate quality assurance/quality control procedures and appropriate test methods that are 

consistent with SW-846, or utilize the following analytical protocol and frequency for non-suspect 

waste:

1. The pre-acceptance sample or the first (1st) shipment received at the facility. If all metals 

analysis results are below reporting limits (i.e., non-detect), zero (0) will be used for metals feed 

calculations. If metals analysis indicates the presence of metals (i.e., any metals analysis result is 

greater than or equal to the reporting limit), the waste will be classified as a suspect waste and 

metals analysis protocol for suspect waste will be followed for this waste stream. 

2. The first (1st) shipment received at the facility if the generator notifies Veolia of a change in the 

waste stream’s chemical composition that would indicate that MACT metals might be present.

2.1(D)(4)(d)(ii)(C). Batch sampling procedure. 

If waste accepted for incineration is batched, treated, blended, mixed, or otherwise altered from its 

shipped state, the Permittee shall sample and analyze such batched, treated, blended, mixed, or 

otherwise altered waste for mercury, LVM and SVM in its final form as feed for incineration, prior to 

incineration using appropriate quality assurance/quality control procedures and appropriate test 

methods that are consistent with SW-846. In lieu of sampling and analysis, the Permittee may perform a 

mass balance calculation to determine concentrations in the final batched, treated, blended, mixed, or 

otherwise altered waste. The calculation must be based on all batched, treated, blended, mixed, or 

otherwise altered ingredients having been analyzed and the contribution of each ingredient determined 

pursuant to condition 2.1(D)(4)(d)(ii)(E), below. Feedstreams which are exempt from sampling in 

accordance with condition 2.1(D)(4)(d)(ii)(F) must not can be batched, treated, blended, mixed, or 

otherwise altered. Examples of these are vitamins, pills, pill bottles, vials, health care products and 

consumer products . unless However, the Permittee samples and analyzes the otherwise exempt 

feedstream. shall sample and analyze such batched, treated, blended, mixed, or otherwise altered waste 

for mercury, LVM and SVM in its final form as feed for incineration, prior to incineration using 

appropriate quality assurance/quality control procedures and appropriate test methods that are 

consistent with SW-846. In lieu of sampling and analysis, the Permittee may perform a mass balance 

calculation to determine concentrations in the final batched, treated, blended, mixed, or otherwise 

altered waste. The calculation must be based on all batched, treated, blended, mixed, or otherwise 
altered ingredients and the contribution of each ingredient determined pursuant to condition 

2.1(D)(4)(d)(ii)(E), below.

2.1(D)(4)(d)(ii )(D). Fuel procedure. The Permittee shall document the concentration of mercury, LVM 

and SVM in any fuel other than natural gas, including used oil, diesel, and alternative fuels, but not 

including hazardous waste, fed into the incinerators by either (1) obtaining analytical results from each 

fuel supplier or (2) conducting representative sampling using the methods in 40 C.F.R. Part 261, 

Appendix I, of each fuel supply and analyzing such samples using appropriate quality assurance/quality 

control procedures and appropriate test methods. The Permittee shall follow this procedure at least 

once per year for each fuel supply.

2.1(D)(4)(d)(ii )(E). Treatment of detection limits for metal feedrate calculations. The Permittee shall 

determine the concentrations of arsenic, beryllium, cadmium, chromium, lead and mercury as set forth 

below in order to calculate the mass of mercury, LVM and SVM for each waste or fuel fed to each 

incinerator:

I. If the applicable metal is detected at or above the reporting limit for that metal, as defined in 

condition 2.1(D)(4)(d)(ii)(E)(III), in any sampling analysis required by condition 2.1(D)(4)(d)(ii), 

the metal concentration shall be equal to the concentration of that metal detected from the 

associated sampling analysis at or above the reporting limit, as defined in condition 

2.1(D)(4)(d)(ii)(E)(III), below.

II.If the applicable metal is detected at or above the reporting limit for that metal, as defined in 

condition 2.1(D)(4)(d)(ii)(E)(III), in any sampling analysis required by condition 2.1(D)(4)(d)(2), 

the metal concentration shall be equal to the reporting limit 1⁄2the reporting limit, as defined in 

condition 2.1(D)(4)(d)(ii)(E)(III), from the sampling analyses required by condition 2.1(D)(4)(d)(ii).

III. The reporting limit shall be determined as the lower limit of quantitation as described in 

Method 6010c of SW-846, multiplied by the appropriate extraction and dilution factors. All 

positive sample results must fall within the established linear dynamic range, and nondetects 

reported at the lower limit of quantitation with appropriate dilution factors applied as specified 

by Method 6010c of SW-846. 

IV. The mass of LVM in each feedstream is the algebraic sum of the mass of arsenic, beryllium 

and chromium in that feedstream. The mass of SVM in the feedstream is the algebraic sum of 

the mass of lead and cadmium in that feedstream. 

2.1(D)(4)(d)(ii )(F). Exemptions to the analysis procedures in condition 2.1(D)(4)(d)(ii). 

The following wastes that the Permittee determines do not contain mercury, LVM or SVM, consistent 

with this condition 2.1(D)(4)(d)(ii)(F), shall be exempt from the analysis procedures set forth in condition 

2.1(D)(4)(d)(ii): 

I. Packaged chemicals and debris from laboratories, hospitals, household clean sweeps, or 

manufacturing facilities, including scintillation vials packed in accordance with Small Quantity Chemical 
Guidelines (SQCGs) except those that are not packaged in numerous small containers or are unknowns

(such as having no labels or other identification). For packaged chemicals, the Permittee shall obtain a 

packing list for each container from the generator specifying type and quantity of chemicals contained 

within; 

II. Empty containers as defined in 35 IAC 721.107(b); 

III. Pharmaceutical, commercial products or chemicals and consumer products that are off-specification 

or outdated and are packaged in consumer quantities, or as designated by Veolia, are unused or 

banned, and are in their original packaging except those that are not packaged in numerous small 

containers or are unknowns (such as having no labels or other identification); 

IV. Aerosol cans, lecture bottles or gas cylinders, except those that are unknowns; 

V. Controlled substances, as defined in 21 C.F.R. Part 1308, regulated by the federal government and 

handled unopened until destroyed in the incinerator; and 

VI. Explosive, air and water reactive, poison inhalation hazard, or odiferous material, such as mercaptan, 

which present sampling and analytical safety hazards and that are handled unopened until destroyed in 

the incinerator.

VII. Wastes which are visually identifiable through the inspection process and cannot be sampled due to 

safety concerns or the ability to obtain a representative sample. This inclusive list includes batteries, 

cathode ray tubes, crushed glass, piping, filters, filter cartridges, wire or tubing, paper products, 

syringes, metal sheeting and parts, explosive components, devices, residues and debris from the cleanup 

of spills or releases of a single chemical substance or commercial product or a single waste, waste 

produced from the demolition or dismantling of industrial process equipment or facilities contaminated 

with chemicals from the process, debris and personal protection equipment that are impractical to 

sample and difficult to obtain accurate and representative analysis including rags, gloves, boots, and 

disposable garments. This list may be expanded with USEPA approval. 

VII. VIII. For each waste listed in condition 2.1(D)(4)(d)(ii)(F)(I) through (VII) the Permittee shall review 

any container labels, material safety data sheets, drum inventories, packing lists, and any other relevant 

data or information provided by the generator to determine the metals concentrations of these 

exempted waste. This relevant documentation will be kept in the Technical Manager’s File or electronic 

system. whether mercury, LVM or SVM is present in any waste listed in conditions 2.1(D)(4)(d)(ii)(F)(I) 

through (6) that otherwise is exempt. Only those wastes listed in conditions 2.1(D)(4)(d)(ii)(F)(I) through 

(VI) that The Permittee determines in writing contain no mercury, LVM or SVM based on such review are 

exempt from the analysis procedures set forth in condition 2.1(D)(4)(d)(ii). The Permittee’s written 

determination of exemption from these analysis procedures shall describe the information reviewed 

and the basis for the determination that no mercury, LVM or SVM is present. 

VIII.IX. Any waste listed in conditions 2.1(D)(4)(d)(ii)(F)(I) through (VII) for which there is insufficient 

information to allow the Permittee to make a reasonable determination that of the amount of mercury, 
LVM and SVM are not present in the waste shall not be exempt from the analysis procedures in 

conditions 2.1(D)(4)(d)(ii)(A) through E.

IX. X. The Permittee may request approval from the Administrator to exempt any waste that is not listed 

in conditions 2.1(D)(4)(d)(ii)(F)(I) through (VII) from the analysis procedures set forth in conditions 

2.1(D)(4)(d)(ii)(A) through (E). The Permittee shall describe the information reviewed and the basis for 

the determination that no mercury, LVM or SVM is present in the wastes proposed for exemption. The 

Permittee shall submit all such wriiten requests to the address in condition 4.2(B). The Administrator 

shall have 60 14 days from the date of receipt of the written request to either approve the request as 

submitted by the Permittee or request additional information needed to enable the Administrator to 

make a decision on the Permittee’s request. If the Administrator does not respond to the request within 

60 14 days of receiving the request and any additional information requested by the Administrator, the 

Permittee may consider its request to exempt the specified waste(s) approved.