March 26, 2009 

Cheryl L. Newton 

A-18J 

Director of Air and Radiation Division 

United States Environmental Protection Agency, Region 5 

77 West Jackson Blvd 

Chicago, IL 60604-3590 

Re: Veolia ES Technical Solutions, L.L.C. 

Response to January 22, 2009 Information Request 

Dear Ms. Newton: 

Pursuant to your letter dated January 22, 2009 regarding additional requested information on Veolia ES 

Technical Solution's October 10, 2008 and January 6, 2009 submittals, Veolia offers the following: 

1. The laboratory report(s) for the 2008 performance tests including the percent moisture or 

percent solids; 

> Veolia has attached the laboratory reports and supporting documentation for the 2008 

performance test including the percent moisture or percent solids. 

2. A statement identifying whether the highest feed rates of each mercury, semivolatiie metals 

(SVM), and low volatile metals (LVM) from each combustor unit from July 1, 2004 through 

January 1, 2008, submitted to Charles Hall via e-mail on December 5 and 10, 2008 are on a 

dry or wet basis, and a certification to the truth and accuracy of the data and the statement; 

> The LVM, SVM, and mercury feed rate data submitted to Charles Hall on December 5 and 10, 

2008, were calculated on an "as received" or wet basis. 

3. A statement identifying whether each of the 2008 performance test feed rates of mercury, 

S V M and LVM to each combustor unit submitted on October 10, 2008, are on a dry or wet 

basis, and certification to the accuracy ofthe data and the statement. 

> Historically, Veolia has managed sending the waste samples from testing programs to the 

laboratories for analysis. This analysis has always been conducted on an "as received" basis. 

Taking into consideration USEPA Region 5's recent concern regarding the QA/QC of sample 

collection and analysis, the independent stack testing firm was tasked with the responsibility of 

sampling and analyzing the waste samples from the testing program. When Veolia submitted the 

metals test reports for Incinerators 2, 3, and 4 on October 10, 2008, waste analytical results 

received from Maxxam Analytical Laboratories were used to calculate the metal feed rates for the 

tests that were conducted. All analytical results were used as "as received" metals concentrations 

of the waste feeds, as has always been done in the past, in calculating the metals feed rates for all 

runs of testing on the three incinerators. 

In early November Veolia discovered that the reported solid waste metals concentrations in 

Maxxam's analytical report were not on an "as received" basis. The solid samples were dried prior 

to analysis. This may have been identified prior to the report submittal had Veolia not changed its 

document review protocol in order to meet the aggressive schedule requirements. This change in 

protocol resulted in the removal of a redundant and independent QA/QC review that had been 

#7 Mobile Avenue, Sauget, IL 62201 

(618) 271-2804 

www.veoliaes.com 

201' 
standard on past test reports. For Veolia to correctly calculate the metals feeds during the testing, 

this drying of the samples needed to be taken into consideration. Veolia re-calculated the metals 

feed rates for Units 2, 3, and 4 which resulted in feed rates that were less than originally 

determined. 

The recalculated 2008 performance test solid waste metals concentrations of LVM, SVM, and 

mercury on Units 2, 3, and 4 submitted in this package were converted to "as received" metals 

concentrations since Veolia utilizes all metals analyses on an "as received" basis to calculate metal 

feed rates. This is necessary since the incinerator control systems use "as received" waste feed 

throughputs and metals analyses. Incinerator metal feed calculations have been performed on "as 

received" data since July 2004. The LVM, SVM, and mercury feed rate data submitted to Charles 

Hall on December 5 and 10, 2008, were calculated using "as received" data. 

I certify under penalty of law that this document and all attachments were prepared under my direction or 

supervision in accordance with a system designed to assure that qualified personnel properly gather and 

evaluate the information submitted. Based on my inquiry ofthe person or persons who manage the 

system, or those persons directly responsible for gathering the information, the information submitted, is 

to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are 

significant penalties for submitting false information, including the possibility of fine and imprisonment for 

knowing violation. 

Please call David Klarich or me at (618) 271-2804, if you have further questions concerning this submittal. 

Very truly yours, 

Doug Harris^ 

General Manager 

C C : Genevieve Damico, USEPA, Region 5 

Charles Hall, USEPA, Region 5 

E PA File 

#7 Mobile Avenue, Sauget, IL 62201 

(618) 271-2804 

www.veoliaes.com