Memorandum 

USEPA Region 5 

Land and Chemicals Division 

To: File 

Date: May 6, 2009 

From: Todd D. Ramaly 

 Christopher Lambesis 

 RCRA Programs Branch 

Re: Calculations of Metal Feed Rates Used During the 2008 Test Burns at 

 Veolia Environmental Services, LLC, Sauget, IL 

In October 2008, Veolia Environmental Services, LLC (Veolia) of Sauget, 

Illinois, submitted results from test burns conducted in August and September of 2008 on 

each of the three hazardous waste incinerators at the Sauget facility. These results are 

contained in the following reports: Metals Performance Test Report Prepared for the 

Fixed Hearth Incinerator Number 2 in Accordance with 40 CFR § 63 Subpart EEE, 

ENSR Corporation, October 2008; Metals Performance Test Report Prepared for the 

Fixed Hearth Incinerator Number 3 in Accordance with 40 CFR § 63 Subpart EEE, 

ENSR Corporation, October 2008; and Metals Performance Test Report Prepared for the 

Rotary Kiln Incinerator Number 4 in Accordance with 40 CFR § 63 Subpart EEE, ENSR 

Corporation, October 2008. 

Analytical laboratory reports submitted as supporting documentation to these test 

burn reports did not specify whether or not the data for solid samples was expressed as 

concentrations in “wet weight” (meaning in the waste “as is”) or by “dry weight” 

(meaning in a concentration normalized for moisture content). The concentration of a 

given element or compound can vary widely with changes in moisture content of the 

media. In case of soils, the concentration of pollutants can change significantly if the 

sample was collected just after a rainfall versus after several days of dry weather. When 

chemically analyzing the soil, the extra moisture content (such as from rainfall) can dilute 

the dry concentration of pollutants. Since the concentration of pollutants in the soil can 

trigger regulatory determinations, influence risk assessments, or exceed clean-up goals, 

the variation of moisture content must be addressed. Analytical laboratories typically 

report environmental samples of solids like soil in “dry weight,” and include the mass 

fraction of the samples that are either moisture or solids (non-moisture) for “dry weight” 

data. 

It is important to know whether or not the chemical analysis of waste feed during 

a test burn is expressed in “dry weight” or “wet weight” because the mass balance of the 

inputs to the incinerator that is needed to calculate pollutant feed rates and other 
2

measurements of system performance (such as system removal efficiency) must match 

the condition of the waste feed as it was charged to the incinerator. Since the non-liquid 

waste feeds were sampled in the exact wet form in which they were burned and the mass 

of the waste feeds were measured “as is” or wet, the analytical results must be in “wet 

weight” for these calculations. Analytical results based on “dry weight” can be easily 

converted to “wet weight” by multiplying the “dry weight” concentration by the value of 

one minus the fraction moisture content. The data package submitted by Veolia did not 

specify under which convention the metals data were reported or provide the mass 

fraction moisture or mass fraction solids. 

On October 29, 2008, the U.S. Environmental Protection Agency’s Christopher 

Lambesis contacted Mike Challis, of Maxxam Analytical, Inc. (Maxxam), the laboratory 

that conducted the metal analysis for Veolia, to determine whether or not the solids data 

was expressed in “dry weight” or “wet weight” (Attachment 1). Mr. Challis stated that 

Veolia’s data in Maxxam’s lab reports were reported in “dry weight.” As such, they 

would not be appropriate for use in metal feed rate calculations without conversion to 

“wet weight.” EPA asked Veolia’s Dave Klarich to obtain the dry weight analytical 

results from Maxxam and submit to EPA. On December 5, 2008, Veolia’s Doug Harris 

confirmed in an electronic message that they “found a mistake that lowers the mercury 

feed in the waste” (Attachment 2). In order to obtain metal feed rates that matched the 

burn condition by converting the apparent “dry weight” results to “wet weight,” we 

recalculated the metal feed rates for the 2008 Veolia test burns assuming the metals 

concentrations for solid feed streams (Container Solids for all three incinerators, and Bulk 

Solids for incinerator number 4) are expressed in “dry weight.” We converted these 

values to “wet weight” using percent moisture data provided by Veolia’s secondary lab, 

PSC Republic Environmental Systems (Pennsylvania) LLC (PSC Republic). 

We also recalculated system removal efficiencies (SREs) since “wet weight” feed 

rates must be used in calculating SREs. See Table 1, below, for a summary of the metal 

feed rates and mercury SREs. The overall effect on the actual feed rate depended on the 

metal contribution of solid test burn wastes relative to that of metal spikes. In some 

instances, such as the mercury feed rate for Units 2 and 3, a significant portion of the 

total mercury burned came from the solid wastes, and the new calculation of mercury 

feed rates is significantly different than that originally provided by Veolia. Since the 

solid wastes burned for Unit’s 2 and 3 provided insignificant amounts of SVM and LVM 

to the test, the dry weight adjustment did not significantly change the claimed test feed 

rate for SVM or LVM. 

Veolia provided EPA with some updated calculations in December 2008 

however, these were incomplete. In an electronic message dated December 10, 2008, 

Veolia’s Doug Harris provided several spreadsheets which included new updated feed 

rates and estimated SREs. The information only addressed mercury feed rates and did 

not explain the drop in feed rates. Since Veolia’s new reported feed rate for Stack 4 

mercury is identical to EPA’s (in Table 1), it is likely that the new number reflects the 

“dry weight” correction to “wet weight.” The reductions in estimated feed rates for Units 

2 and 3 did not match EPA’s estimate, however. It was not apparent why the new feed 
3

rates differed from EPA’s feed rates without a clear accounting as to whether the data 

were reported as “wet weight” or “dry weight” and information from Maxxam on the 

values for moisture content, if they exist. Table 2 summarizes the updated mercury feed 

rates from Veolia’s electronic message with Veolia’s original rates and EPA’s 

recalculated rates. 

In March 2009, Veolia responded to requests for clarification on the issue of wet 

weight or dry weight. Veolia indicated that Maxxam provided percent moisture for the 

solid wastes and that the December recalculations of mercury feed rates were based on 

converting dry weight to wet weight using the new Maxxam percent moisture data. 

Maxxam provided new moisture data for container solids samples from Unit 2 and Unit 3 

test burns only. Veolia used existing percent moisture data from PSC Republic to 

recalculate the metal feed rates for Unit 4. According to the new Maxxam report, the 

new percent moisture data for Units 2 and 3 came from samples analyzed on November 

20, 2008; approximately 3 months after the samples were received. Analysis for 

moisture content is typically done soon after the laboratory receives the samples and a 

“holding time” restriction is often imposed requiring the analysis be completed within 14 

days of sample receipt. The new results differed greatly from percent moisture values 

provided by both Maxxam’s subsidiary lab, PSC Republic, and EPA’s Central Regional 

Laboratory just a few weeks after the test burns. See Table 3 below for a direct 

comparison. 

The solids used for most of the tests came from a single waste stream. Bulk 

solids are expected to have lower moisture content than the container solids because sand 

was added to achieve a particular test condition. EPA does not know why container 

solids used for the September rerun of the Unit 2 test burn would be much drier than 

container solids used in August. All container solids used during the August test burns 

were consistent in moisture content as reported by PSC Republic. We expect the PSC 

Republic samples were provided by Maxxam from split samples taken from the original 

sample set sent to Maxxam directly from the test burns as this is a common practice and 

the samples were noted as received by PSC Republic within approximately 10 days of the 

test burns. Furthermore, EPA’s laboratory obtained similar results to those of PSC 

Republic on split samples collected at the test burns. Veolia has not explained why the 

Maxxam moisture data should be used instead of the values provided by PSC Republic or 

why they are so different. In addition, Veolia has not explained why they wish to use 

Maxxam’s new moisture data to correct the dry weights for Units 2 and 3, but continue to 

use the PSC Republic moisture data for its recalculation of Unit 4 feed rates. 

From this information, we believe the moisture content analysis from PSC 

Republic should be used for converting dry weight to wet weight because the analysis 

was conducted in a timely manner, the results were consistent for the single waste stream 

used in the tests, and split samples analyzed by EPA’s laboratory provided similar results. 
4

Table 1. Metal Feed Rate Comparison - Veolia Environmental Services, Inc., Sauget, Illinois 

Unit Metal Group 

Test Feed Rate 

Claimed by Veolia 

from August-Sept 

2008 (lbs/hr) 

Overestimated 

by (%) 

System Removal 

Efficiency Using 

Veolia’s Claimed 

Feed Rates (%) 

Test Feed Rate 

Calculated by 

EPA (lbs/hr) 

System Removal 

Efficiency Using Test 

Feed Rate Calculated 

by EPA (%) 

Percent of 

Historical 

Feedrate 

(%) 

Highest Fe

between 

and 1/1/08 

Mercury 0.0047 154% 82.63% 0.00185 55.51% 34.3% 0.005

SVM 63 - NC 63.6 (Aug),62.9(Sept) 2 NC 124.9% 50.

LVM 47 - NC 47.2 (Aug),46.8(Sept) NC 55.2% 84.

Mercury 0.0047 154% 83.22% 0.00185 54.47% 33.9% 0.005

3 SVM 63 - NC 64.3 NC 89.1% 72.

LVM 47 - NC 47.7 NC 61.7% 77.

Mercury 0.031 19% 96.04% 0.026 95.36% 43.5% 0.059

4 SVM 65.2 2.5% NC 63.6 NC 109.6% 58.

LVM 55.3 10% NC 50.3 NC 71.9% 69.

NC – not calculated 

Table 2. Updated Mercury Test Feed Rates – Veolia Environmental Services, LLC, Sauget, Illinois 

Unit 

Test Feed Rate Claimed by 

Veolia in the October 2008 Test 

Burn Reports 

New Test Feed Rate Claimed by 

Veolia in December 2008 

Test Burn Feed Rates 

Estimated by EPA Converting 

Dry Weight Results to Wet 

Weight 

2 0.0047 lbs/hr 0.0034 lbs/hr 0.00185 lbs/hr 3 0.0047 lbs/hr 0.0044 lbs/hr 0.00185 lbs/hr 4 0.031 lbs/hr 0.026 lbs/hr 0.026 lbs/hr 
5

Table 3. Comparison of Moisture Content– Veolia Environmental Services, LLC, Sauget, Illin

Sample PSC Republic 

August, September 

2008 

EPA CRL 

August 2008 

August 2008 Test Burns Unit 2 – Run 1 – Container Solids 74% NA Unit 2 – Run 2 – Container Solids 74.3% NA Unit 2 – Run 3 – Container Solids 77% NA Unit 3 – Run 1 – Container Solids 75.1% 76.2% Unit 3 – Run 2 – Container Solids 71.5% NA Unit 3 – Run 3 – Container Solids 76.3% NA Unit 4 – Run 1 – Container Solids 76.6% 78.1% Unit 4 – Run 2 – Container Solids 76.2% NA Unit 4 – Run 3 – Container Solids 78.6% NA Unit 4 – Run 1 – Bulk Solids 20.8% 24.6% Unit 4 – Run 2 – Bulk Solids 22% NA Unit 4 – Run 3 – Bulk Solids 34.6% NA September 2008 Test Burn Unit 2 – Run 1 – Container Solids 31.9% NA Unit 2 – Run 2 – Container Solids 30.6% NA Unit 2 – Run 3 – Container Solids 32% NA 
Attachment 1 

Conversation Log 

October 29, 2008 - Chris Lambesis, EPA with Mike Challis, Maxxam Analytical, Inc. 

7

Attachment 2 

Electronic Message 

December 5, 2008 – Doug Harris, Veolia Environmental Services, LLC to Todd Ramaly, 

EPA 
Doug.Harris@veoliaes veoliaes veoliaes .com 

12/05/2008 11:17 AM To Todd Ramaly/R5/USEPA/US@EPA

cc David.Klarich@veoliaes.com

bcc

Subject Mercury SRE Graphs

History: This message has been replied to and forwarded .

Todd,

Wanted to send you an update on the Mercury SRE Graphs . We found a mistake

that lowers the mercury feed in the waste (some questions Chris asked got

us thinking and questioning... we owe him lunch!!). We've sent these to

Charlie and explained the change. As you'll see by the graphs, although

the slopes flattened, all SRE's remain better at the higher feed rates as

before. Have a good weekend and give Dave or I a call if you have any

questions.

(See attached file: UNIT2_HgSRErevised1125.doc)(See attached file:

UNIT3_HgSRErevised1125.doc)(See attached file: UNIT4_HgSRErevised1125.doc)

Doug Harris

General Manager

Veolia ES Technical Solutions, L.L.C.

#7 Mobile Avenue

Sauget, IL 62201

Office: 618-271-2804

Cell: 618-616-7420

Fax: 618-271-2128
Unit-2 

SRE versus Hg feedrate

20%30%40%50%60%70%80%90%

100%

0 0.001 0.002 0.003 0.004 0.005 

Hg feedrate (lbs/hr)

Hg SRE (%)

SRE Lin

5/2004

8/2008

Testing conducted on May, 2004 (pt 1) was used as data in lieu for interim MACT standard compliance. T

August, 2008 (pt 2) was testing conducted as required by June 5, 2008 USEPA letter and to demonstrate comMACT Standards. Pt (2) test was conducted at 3.5 times the Mercury feed rate as pt (1). Pt (2) resulted in h
 Unit-3 

SRE versus Hg feedrate

20%30%40%50%60%70%80%90%

100%

0 0.001 0.002 0.003 0.004 0.005 

Hg feedrate (lbs/hr)

Hg SRE (%) SRE Linear 

5/2006

8/2008

 Testing conducted on May, 2006 (pt 1) at the request of the IEPA was to verify the testing conducted on M

 being used as data in lieu for interim MACT Standard compliance for Unit #3. Testing conducted on Aug

 testing conducted as required by June 5, 2008 USEPA letter and to demonstrate compliance with the Fina Pt (2) was conducted at 3.1 times the Mercury feed rate at Pt (1). Pt (2) resulted in higher SRE’s. 
 Unit-4 

SRE versus Hg feedrate (@ 6 lbs/hr carbon)

80%90%

100%

0 0.005 0.01 0.015 0.02 0.025 0.03 0.

Hg feedrate (lbs/hr)

Hg SRE (%) SRE Line

5/2004 8/2008

Testing conducted on May, 2004 (pt 1) was used as data in lieu for interim MACT Standard Compliance. T

 August, 2008 (pt 2) was testing conducted as required by June 5, 2008 USEPA letter and to demonstrate com MACT Standards. Pt (2) was conducted at 2.2 times the Mercury feed rate as Pt (1). Pt (2) resulted in high
8

Attachment 3 

Electronic Message with Attachments 

December 10, 2008 - Doug Harris, Veolia Environmental Services, LLC to Todd 

Ramaly, EPA 
Doug.Harris@veoliaes veoliaes veoliaes .com 

12/10/2008 01:10 PM To Todd Ramaly/R5/USEPA/US@EPA

cc

bcc

Subject Fw: Hg SRE Spreadsheets

Todd,

Here's the info. Let me know if you need anything else .

Doug Harris

General Manager

Veolia ES Technical Solutions, L.L.C.

#7 Mobile Avenue

Sauget, IL 62201

Office: 618-271-2804

Cell: 618-616-7420

Fax: 618-271-2128

----- Forwarded by Doug Harris/OES/ONYX on 12/10/2008 01:08 PM -----

 

 David 

 Klarich/OES/ONYX 

 To 

 12/10/2008 09:49 Doug Harris/OES/ONYX@EMAIL 

 AM cc 

 

 Subject 

 Hg SRE Spreadsheets 

Here are the spreadsheets with the calculations below the graph .

(See attached file: Unit2HGremovalgraphrevised1125.xls)(See attached file:

Unit3HGremovalgraphrevised1125.xls)(See attached file:

Unit4HGremovalgraphrevised1125.xls)
Unit-2 

FEED SRE FEED SRE

0 70% May-04 0.00047 51.3% 5/2004 Average 0.000947 71%

0.01 80% 0.0017 87.5% 8/2008 Average 0.003433 76%0.02 90% 0.00067 73.4%0.03 100% Aug-08 0.0039 79.7%0.04 0.0033 75.1%0.05 0.0031 74.2%0.06

Mercury

SRE versus Hg feedrate

20%30%40%50%60%70%80%90%

100%

0 0.001 0.002 0.003 0.004 0.005 

Hg feedrate (lbs/hr)

Hg SRE (%)

SRE Linear 

5/2004

8/2008
Unit-2 

Feed Emissions Emissions

Date (lb/hr) (ug/dscm) (lb/hr) SRE

5/5/2004 0.00047 15.8 0.000229 51.35/6/2004 0.0017 13.5 0.000212 87.55/6/2004 0.00067 11.1 0.000178 73.4

8/11/2008 0.0039 58 0.000791 79.78/12/2008 0.0033 58.2 0.000822 75.18/13/2008 0.0031 57.4 0.000799 74.2
Unit-3 Hg removal

FEED SRE FEED SRE

0 70% May-06 0.00125 27.9% 5/2006 Average 0.001387 33%

0.01 80% 0.0014 22.1% 8/2008 Average 0.004367 81%0.02 90% 0.00151 47.8%0.03 100% Aug-08 0.0041 81.8%0.04 0.0048 80.5%0.05 0.0042 80.5%0.06

Mercury

SRE versus Hg feedrate

20%30%40%50%60%70%80%90%

100%

0 0.001 0.002 0.003 0.004 0.005 

Hg feedrate (lbs/hr)

Hg SRE (%) SRE Linear (SR

5/2006

8/2008
Unit-3 Hg removal

Feed Emissions Emissions

Date (lb/hr) (ug/dscm) (lb/hr) SRE

5/10/2006 0.00125 70.3 0.000901 27.95/10/2006 0.0014 61.5 0.00109 22.15/11/2006 0.00151 52.7 0.000788 47.8

8/5/2008 0.0041 54.8 0.000748 81.88/6/2008 0.0048 61.1 0.000938 80.58/7/2008 0.0042 57.5 0.000818 80.5
Unit-4 Hg removal

FEED SRE FEED SRE

0 70% May-04 0.0115 98% 5/2004 Average 0.0116 94%

0.01 80% 0.0131 95% 8/2008 Average 0.026033 95%0.02 90% 0.0102 89%0.03 100% Aug-08 0.0257 94%0.04 0.026 96%0.05 0.0264 96%0.06

Mercury

SRE versus Hg feedrate (@ 6 lbs/hr carbon)

80%90%

100%

0 0.005 0.01 0.015 0.02 0.025 0.03 0.03

Hg feedrate (lbs/hr)

Hg SRE (%) SRE Linear (

5/2004 8/2008
Unit-4 Hg removal

Feed Emissions Emissions

Date (lb/hr) (ug/dscm) (lb/hr) SRE

5/4/2004 0.0115 6.6 0.000253 97.85/4/2004 0.0131 18 0.000703 94.65/4/2004 0.0102 29.1 0.00114 88.8

8/21/2008 0.0257 37.8 0.00153 94.08/22/2008 0.026 24.3 0.000996 96.28/23/2008 0.0264 25 0.00108 95.9