NEICVP0972E02 Page 2 of 27 Veolia ES Technical Services 

Sauget, Illinois 

CONTENTS 

INTRODUCTION .......................................................................................................................... 3

BACKGROUND ...................................................................................................................... 4

Facility Unit Operations Overview ...................................................................................................................... 4

Bulk Liquids Processing....................................................................................................................................... 6

Containerized Liquids Processing ........................................................................................................................ 6

Containerized Solids Processing .......................................................................................................................... 7

Bulk Solids Processing ......................................................................................................................................... 8

INVESTIGATION OBJECTIVES ........................................................................................... 8

WASTE CHARACTERIZATION PROCESS DESCRIPTION .............................................. 9

Waste Approvals .................................................................................................................................................. 9

Waste Acceptance .............................................................................................................................................. 10

On-site Laboratory Process Overview ................................................................................................................ 11

Veolia Feedstream Rate Determination .............................................................................................................. 12

NEIC FEED STREAM EVALUATION ................................................................................ 13

SUMMARY OF OBSERVATIONS ............................................................................................ 27

RESOURCE CONSERVATION AND RECOVERY ACT................................................... 27

TABLES 

1 Summary of Total Waste Profiles Meeting Specified Criteria for 2009, 2010, and 2011 ...... 14

2 Waste Profiles with RCRA Metals Codes that were not Analyzed On-site According to the 

WTS – Facility Explanation ................................................................................................. 16

3 Summary of High-Volume Waste Profiles Received in 2011 that were Reviewed On-site .. 16

4 List of Profiles with Concerns Regarding How the Metals Values were Established in the 

WTS ...................................................................................................................................... 19

5 Summary of Repeating Metals Concentrations for Waste Receipts Greater than 20,000 

Pounds Per Year .................................................................................................................... 24

6 Summary of Loads Received and Analyzed from June 2009 to June 2012 for Standard Profile 

CARBN1 and SOL005 ......................................................................................................... 24

FIGURES 

1 Google Earth Pro image of Veolia ES Technical Services in Sauget, Illinois ......................... 4

2 Summary of Waste Analysis Categories for Profiles Received in 2011 ................................ 26

The Contents page shows all sections contained in this report 

and provides a clear indication of the end of the report. 
NEICVP0972E02 Page 3 of 27 Veolia ES Technical Services 

Sauget, Illinois 

INTRODUCTION 

At the request of U.S. Environmental Protection Agency (EPA) Region 5, EPA’s National 

Enforcement Investigations Center (NEIC) conducted a focused multimedia compliance 

investigation of the Veolia Environmental Services (ES) Technical Solutions, LLC (Veolia) 

hazardous waste incinerator in Sauget, Illinois. The Veolia facility’s mailing address is 7 Mobile 

Avenue, Sauget, Illinois 62201. 

Figure 1 is an image of the Veolia site that was generated from Google Earth Pro. Veolia’s 

waste disposal and incineration operations are subject to several environmental statutes, including 

the Clean Water Act (CWA); Resource Conservation and Recovery Act (RCRA); Clean Air Act 

(CAA); and Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). 

 Veolia’s operations are subject to environmental permits and regulations administered by the EPA 

and the Illinois Environmental Protection Agency (IEPA). 

The NEIC on-site inspection was conducted December 5 through December 15, 2011. The 

inspection team included: Alison Ruhs (environmental scientist) Don Smith (chemist), Brad Venner 

(statistician) from NEIC and Shannon Downey, Sarah Marshall, and Jamie Paulin from EPA Region 

5. Credentials were presented to Veolia representatives Doug Harris, Dennis Warshol, and David 

Klarich. 
NEICVP0972E02 Page 4 of 27 Veolia ES Technical Services 

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Figure 1. Google Earth Pro image of Veolia ES Technical Services in Sauget, Illinois 

(9/1/2011) 

Veolia ES Technical Services 

Sauget, Illinois 

BACKGROUND 

Facility Unit Operations Overview 

According to Veolia’s RCRA permit, Veolia has a maximum total container storage capacity 

of 1,062,789 gallons of waste and a maximum tank storage capacity of 656,724 gallons. The facility 

has the following 12 container storage units: 

 Drum storage unit 1 with a capacity of 61,490 gallons 

 Drum storage unit 2 with a capacity of 90,640 gallons 

 Drum storage unit 3with a capacity of 563,200 gallons 

 Drum storage unit 6 with a capacity of 36,960 gallons 

 A roll-off storage building that can store up to 24 roll-off boxes with a total storage capacity of 

96,960 gallons 

 A drum decant area with a total capacity of 16,830 gallons 
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 Material processing area (MP) 1 with a total storage capacity of 15,950 gallons 

 MP 2 with a total storage capacity of 4,125 gallons 

 Lab pack repackaging building 2B with a storage capacity of 7,700 drums 

 A direct inject system at incinerators 2 and 3 with a total storage capacity of 77,920 gallons 

 A direct injection system at incinerator 4 with a storage capacity of 60,214 gallons 

 A trailer storage pad with a storage capacity of up to 30,800 gallons 

Veolia has two tank farms, tank farms 1 and 3. Tank farm 1 is located on the north side of 

the facility and has 10 tanks. Before stored bulk liquid wastes are incinerated, they are blended at 

tank farm 1 in tanks 2, 4, 6, and 8, which feed to incinerators 2 and 3. Six additional tanks (10, 20, 

30, 40, 50, and 60) at tank farm 1 are used to store different waste streams (typically based on 

British thermal unit [Btu] value) before they are pumped to one of the four blend tanks that feed the 

waste to incinerators 2 or 3. Tank farm 3 is located on the south side of the facility, adjacent to 

incinerator 4, and has eight tanks (300, 302, 304, 306, 308, 310, 312, and 314). The tanks in tank 

farms 1 and 3 are used to store the liquid organic waste, aqueous wastes, pumpable sludges, and 

virgin fuel that are fed to the incinerator system. Pumps transfer these wastes and fuel via aboveground pipelines to the incinerators. According to D. Warshol, Veolia environmental, health, and 

safety manager, the pipelines used to transfer liquid organic waste and aqueous waste are equipped 

with stainless steel strainers to remove solids that may plug the incinerator nozzles. Operators at 

each incinerator control rates of feed. The contents of the tanks are mixed and then sampled before 

they are fed to the incinerators. The samples are tested for Btu value and chlorine. After the 

analysis is completed, the tank contents are released to the incinerator. 

According to Veolia’s CAA Title V permit V-IL-1716300103-08-01, the facility operates 

two fixed-hearth dual-chambered incinerators (units 2 and 3) and one rotary kiln (unit 4). The two 

fixed-hearth units each are rated at 16 million Btu/hour (hr). According to D. Warshol, incinerator 3 

is a mirror image of incinerator 2. According to the Title V permit, the only difference between 

incinerators 2 and 3 is that incinerator 2 is equipped with four baghouse modules, while incinerator 3 

is equipped with three baghouse modules. Incinerators 2 and 3 are designed to receive containers of 

40 gallons or less of solid waste and containers of 1 gallon or less of containerized aqueous and/or 

organic liquid wastes. Additionally, incinerators 2 and 3 have specialty liquid feeds for containers 

with acute health hazards and a direct inject liquid feed for containers with viscosity, odor, and/or 

compatibility concerns. Incinerator 2 can also incinerate gases. Each of the fixed-hearth 

incinerators can also receive liquid wastes from the storage/blend tanks located in tank farm 1. 

Incinerator 4 is rated at 50 million Btu/hour and is equipped with its own tank farm system 

(tank farm 3), drum storage, bulk solids storage, and feed systems. Incinerator 4 is permitted for all 

forms of bulk waste, as well as containerized waste (including 85-gallon steel drums). 
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Bulk Liquids Processing 

Liquid waste can be blended in bulk tanks before it is incinerated, or it can be directly fed 

into the incinerators. If the waste is blended in a bulk tank before incineration, a sample is drawn 

from the tank to be analyzed for the following parameters: 

 Heat value – measured to control the feed rates of waste fed into the incinerators. 

 Total chlorine content – measured to control the percent chlorine in waste fed into the 

incinerators 

 pH – measured to protect the integrity of tank farm construction materials and provide 

management data for proper blending 

 Specific gravity (s.g.) – measured to ensure that the specific gravity of bulk or decant composite 

liquid is less than the design specific gravity for the storage tanks (s.g.= 1.5) 

Samples of bulk liquids are not analyzed for metals; instead, metals concentrations are 

calculated based on profile information stored in Veolia’s waste tracking system (WTS). The WTS 

pulls information from the corporate tracking system, called the “I-Series” (discussed in detail in 

“Waste Characterization Process Description”). Either a value from the profile, or a shipmentspecific value based on metals analysis at Veolia’s on-site laboratory, is used in the calculation. Onsite analyses may be used to update the profile information in the WTS. 

Containerized Liquids Processing 

Containerized liquids can be processed one of four ways, depending on the nature of the 

waste and which incinerator unit will ultimately receive the waste: (1) the entire container may be 

fed (charged) directly to incinerators as it was received, (2) the container may be repackaged into 

smaller charge boxes, (3) the container may be bulked with similar waste into a tote or a tank for 

injection into the incinerators, or (4) the container may be directly injected into the incinerator. 

Lab-packed liquid wastes usually remain in the original container and are placed with similar 

waste streams into charge boxes. However, lab packs can also be bulked together (done when 

original container is greater than 1 gallon) into a tote for injection into the incinerator. Lab-packs 

are stored in buildings 2A and 2C, and processed in building 2B. 

There are four possibilities for managing non-lab-pack containers of liquid waste that are 

greater than 1 gallon: (1) the entire container can be fed to the incinerator (up to 85 gallons can be 

fed into incinerator 4), (2) the container can be decanted with a suction wand directly to the 

incinerator if the material is highly odorous or poses a health hazard, (3) the container can be bulked 

into a tank or tote for injection into the incinerator (generally smaller containers of less than 5 

gallons), or (4) the container can be decanted to plastic-lined cardboard charge boxes at volumes of 
NEICVP0972E02 Page 7 of 27 Veolia ES Technical Services 

Sauget, Illinois 

1 gallon or less. These containers are processed in material processing areas 1 and 2 (MP1 and 

MP2). 

When smaller containers are bulked into a tote, the combined waste is assigned a 

“consolidation number” that tracks all the receiver numbers of all the waste that was placed in the 

tote. The consolidation number is created from the month-day-year when the first volume of waste 

was placed in the bulking container. Once the tote is full, a sample is taken for mandatory analyses 

(the same parameters used for bulk liquids) and supplemental analyses. The laboratory values for 

Btu and metals are used in the feed rate calculation when the tote is injected into the incinerator. 

As for containers destined to be bulked into a tank, a sample of each waste is taken before 

bulking occurs to ensure compatibility. If a “heel” of waste remains in the tank, the heel is also 

sampled to ensure compatibility. Once all the samples have been taken, they are combined in the 

laboratory and mandatory and supplemental analyses are performed. Once compatibility testing and 

mandatory and supplemental laboratory analyses are complete, the containers are decanted to the 

tank. After the wastes have been bulked into the tank, a final tank sample is taken for analysis of 

chlorine, viscosity, and Btu value to ensure optimum incinerator performance when the waste is 

injected. Laboratory staff enter the analytical results performed prior to bulking in the tank into the 

WTS, and this information, along with the tank volume, is used to calculate the metals values for the 

tank. 

Containerized Solids Processing 

Containerized solids are generally processed by repackaging the contents into containers that 

are suitable for storage and incineration at MP1 and MP2. However, incinerator 4 can directly 

receive up to 85-gallon drums if the material does not pose a concern with regard to maintaining 

incinerator operating parameters. Incinerators 2 and 3 can receive up to 40-gallon containers 

directly. 

According to Veolia personnel, the containers to be processed are moved using a forklift 

from storage, transport trailers, or other processing areas to MP1 or MP2. This container movement 

is tracked with a bar code scanner that sends the information to the WTS. At MP1 and MP2, 

operators place the container on a conveyor system. The containers are moved to a tipper system 

that is used to empty the contents into charge boxes. Operators empty the material from the 

container into a mixing box by slowly tilting the tipper and using a shovel or other appropriate tool 

to scrape material out of the container as needed until the container is empty. According to Veolia 

personnel, any free liquid of more than 1 gallon is absorbed with corn cobs or Dry-All absorbent. A 

process planner determines the amount and types of wastes placed in each charge box, and the 

information is included in a process plan for the waste type. According to D. Warshol, the criteria 

for filling the boxes include Btu value, regulated metals concentrations, presence of reactive 
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materials, and the size and shape of the material. After the charge boxes are filled, each pallet of 

boxes is labeled with a “skid card.” The skid card includes the words “hazardous waste,” the 

receiver number, the drum number, the date the charges were processed, the crew that processed 

them, where they were processed, and where they are to be incinerated. 

Charge boxes are received at the loading dock located at each dock adjoining each 

incinerator. The packages are loaded onto a scale, and the receiver number is entered into the 

incinerator control/processing system (ICS/IPS) system. The container is then introduced into the 

incinerator through an airlock-ram system located at the lower front of the primary chamber of the 

incinerator. The airlock is composed of a refractory-lined door adjacent to the incinerator, a door 

into the airlock enclosure, and a pneumatic ram to push the material into the incinerator. The 

loading operation can be controlled manually or set to automatic feed by the operator. 

Bulk Solids Processing 

Only incinerator 4 can receive bulk solids. Before bulk solids are introduced into the 

incinerator 4 hopper, they are dumped into one of four in-ground pits (pits 1, 2, 3, and 4). According 

to D. Harris, Veolia general manager, these pits are used for mixing and feeding bulk solids and 

incinerator ash from incinerators 2 and 3. The ash from incinerators 2 and 3 is incinerated in 

incinerator 4 to remove excess water. When bulk solids are scheduled for feeding into incinerator 4 

from pits 1–4, an operator lowers a clamshell into the pits and grabs the desired amount of material. 

The clamshell is then positioned above the bulk solids hopper located next to incinerator 4. The 

operator verifies that the hopper is empty by viewing the feed from the remote camera, observing the 

indicator light at the clamshell station, or by communicating on the intercom with the incinerator 

operator in the control room. Once it has been verified that the hopper is empty, the operator opens 

the clamshell and drops the material into the hopper. The incinerator operator then opens the hopper 

slide gate, allowing the material to fall into the charge box; closes the hopper slide gate; opens the 

charge door; and finally extends the ram, pushing the material into the incinerator. 

INVESTIGATION OBJECTIVES 

The goal of the investigation was to determine Veolia’s compliance with CAA and RCRA 

regulatory requirements. Veolia is subject to maximum achievable control technology standards 

under 40 Code of Federal Regulations (CFR) Part 63, Subpart EEE – National Emission Standards 

for Hazardous Air Pollutants from Hazardous Waste Combustors (HWC MACT). Regarding CAA 

compliance, the NEIC investigation primarily focused on 40 CFR Part 63.1209 (c) (analysis of feed 

streams). Regarding RCRA compliance, the investigation primarily focused on compliance with the 

facility’s waste analysis plan (WAP). 
NEICVP0972E02 Page 9 of 27 Veolia ES Technical Services 

Sauget, Illinois 

WASTE CHARACTERIZATION PROCESS DESCRIPTION 

Waste Approvals 

Veolia uses a corporate-wide waste tracking system called the “I-Series.” Waste generators 

usually work with Veolia Environmental Services North America (VESNA) representatives who 

begin the waste approval process by entering waste information into the I-Series. The generator fills 

out a waste profile sheet (WPS), often with the help of VESNA representatives, and the information 

is entered into the I-Series. VESNA representatives then determine which Veolia facility could 

manage the waste and work with that facility’s approvals department. Typically, Veolia deals 

directly with the VESNA representatives to obtain the necessary waste information for approval 

because VESNA provides waste transportation and acts as a broker for numerous generators. 

All approval decisions are based on an assessment of several criteria, which are listed in the 

WAP, Section 4.2. Veolia uses the WAP requirements to determine if further information, such as 

sample analysis results, is necessary before approving the waste stream. For some generators, 

Veolia’s on-site analytical laboratory also conducts mandatory analysis on the “sale samples” before 

Veolia approves the waste stream for treatment. Additionally, Veolia’s approvals coordinators have 

created a “dynamic suspect list” of industries and process wastes that could contain volatile/semivolatile metals (specifically mercury, cadmium, chromium, arsenic, lead, and beryllium) and must be 

analyzed for metals before the waste stream can be approved. This list continues to grow, according 

to Kelly Meredith, Veolia approvals coordinator, and Christie Narez, Veolia technical manager. 

If the waste stream submitted for approval is similar to waste streams that are already 

accepted for treatment at Veolia facilities, then a standard profile designation may be used. Standard 

profile designations are used for waste streams that have similar physical and chemical 

characteristics, are generated by similar industries or processes, or have the same EPA hazardous 

waste codes as similar process waste. When a standard profile is used for a waste stream, sampling 

is not conducted; instead, Veolia uses an analytical database that was developed for that standard 

profile. The analytical database is based on analytical data from wastes from similar industries or 

processes. According to C. Narez and D. Warshol, many of the standard profiles used at Veolia are 

based on historical data obtained by the Veolia facility located in Port Arthur, Texas. 

As described in the WAP, Veolia can perform three types of waste analyses: mandatory 

analyses, supplemental analyses, and blend analyses. Incoming wastes awaiting approval are subject 

to mandatory analyses, unless a standard profile can be used or if the waste meets an exception from 

required analyses. Five mandatory analyses are required for waste profile approval: pH, radiation, 

flash point, polychlorinated biphenyls (PCBs), and apparent viscosity. Supplemental analyses are 

performed to further identify wastes and are performed if the waste stream is suspected of containing 

constituents such as metals or PCBs. Facility management, along with the approvals department, 
NEICVP0972E02 Page 10 of 27 Veolia ES Technical Services 

Sauget, Illinois 

determines if supplemental analyses are necessary. Blend analyses are used to determine the liquid 

blend characteristics in order to maintain a steady state (normal) operation of the incinerator. Blend 

analyses are typically performed after approval, once the waste is received, and is scheduled to be 

bulked into a tote or tank. 

Ten categories of wastes are exempted from sampling requirements, as outlined in the WAP. 

 One of these categories is commercial products or chemicals, such as off-specification, outdated, 

unused, or banned chemicals that are in the original container or package. Another category is 

wastes that are identifiable through a visual inspection process, such as batteries, filters, and filter 

cartridges. A third category is non-hazardous waste for which the generator has provided analytical 

data to support the determination. 

Waste Acceptance 

Once Veolia has approved a waste stream profile, the waste may be delivered to the facility. 

VESNA representatives schedule waste shipments to Veolia in the I-Series, and Veolia’s material 

acceptance group (MAG) prints the daily shipping schedule every morning. MAG personnel 

compare the manifested profiles of wastes that are received at the facility to the schedule to ensure 

that each load is scheduled. Once the waste stream has been verified on the schedule, the profile 

information is downloaded from the I-Series into the WTS for waste tracking on-site. A receipt 

number for each manifested line item (waste profile) is sequentially generated during waste 

receiving and is used to track the waste stream throughout its on-site processing. The receipt 

numbers are written on the shipping document for each line item and on each receipt packet. A 

customer service representative (CSR) must resolve any waste profiles that are not approved. 

Veolia visually inspects and samples waste, according to the WAP, before a waste stream can 

be accepted, unless the waste stream is exempt from inspection and sampling, as discussed 

previously. Containers of wastes are sampled and analyzed after receipt at receiving building 3. 

Ten percent of containers from each receipt number (profile) within a shipment are randomly 

sampled. Mandatory analysis is performed on all samples, and additional analysis may be required. 

If multiple samples are taken from the same waste profile, up to five samples can be composited for 

analysis according to the WAP. 

Section 5.2 of the WAP describes how non-conforming waste is managed. If a discrepancy 

is discovered, the following Veolia personnel can initiate a discrepancy report: 
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Sauget, Illinois 

 Customer service supervisor (CSS) 

 Lab personnel 

 Receiving technicians and/or supervisor 

 MAG personnel 

 Sales coordinators 

 Tank farm technicians and/or supervisor 

 CSRs 

C. Narez contacts the waste generator or waste broker to resolve waste discrepancies. Onetime discrepancies typically are noted on the paperwork, and any changes in handling are tracked in 

the I-Series. If the discrepancy occurs again, then the profile is either changed or a new profile is 

created to better represent the waste stream. Once the received waste stream has been verified, it can 

be accepted for incineration processing. 

On-site Laboratory Process Overview 

Veolia’s on-site analytical laboratory performs waste analysis as required by Veolia’s WAP 

and feedstream analysis plan (FAP). The laboratory is equipped with two ion chromatograph (IC) 

instruments for measuring total halogens, two inductively coupled plasma- atomic emission 

spectrometers (ICP-AES) for measuring metals, two gas chromatographs (GCs) for analyzing 

samples for PCBs, and two bomb calorimeters for determining the Btu content of wastes. 

Samples of received wastes are assigned a unique, sequential laboratory identification 

number that is generated on the basis of when the sample is received at the laboratory. The 

laboratory identification number is entered into a laboratory database. The laboratory identification 

number and the associated analytical results are entered into the WTS under the waste receiver 

numbers associated with that laboratory sample. 

The Veolia on-site laboratory performs tests on samples of generator waste samples (sale 

sample) before approval, incoming accepted wastes, and some on-site-generated wastes. The primary 

tests conducted by the laboratory are: WAP-required fingerprint testing (mandatory analyses), 

supplemental analyses (including volatile/semivolatile metals analysis), and blend analyses. Blend 

analyses and supplemental analyses are only performed if the profile paperwork indicates these analyses 

are required. 

At a minimum, incoming wastes are subjected to 11 mandatory analyses: 
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Sauget, Illinois 

 Physical description 

 pH screen 

 Oxidizer screen 

 Radioactivity screen 

 Flammability potential screen 

 Paint filter test 

 Liquid waste compatibility (water mix) 

 Heat value (Btu) 

 Chlorine content 

 Cyanide screen 

 Sulfide screen 

Five of these mandatory analyses may not be performed due to the nature of the waste 

stream. Cyanide and sulfide screening are not performed on wastes with a pH less than or equal to 

2. The water mix screening is not necessary for wastes already in contact with excess water. Heat 

value and chlorine content are not measured on liquid decant drums. Liquid waste compatibility 

testing is performed on samples of liquid wastes for compatibility before the wastes are added to other 

wastes in tanks and containers. Samples of liquid wastes are added to each other in proportion to the 

bulk quantities of the wastes. During the addition, the generation of heat, fire, explosion, or violent 

reaction is noted by the analyst. 

The laboratory uses bomb calorimetry to determine Btu content. The bomb washings from 

the calorimetry determination are diluted and analyzed by ion chromatography for total halogens as 

chloride, fluoride, bromide, and iodide. Only the chloride result, as total chlorine, is entered into the 

feed rate calculation. Veolia determines the concentration of semivolatile metals (SVM) and volatile 

metals (VM) by microwave digestion and dilution followed by ICP-AES analysis. The facility has 

two ICP spectrometers that use a radial viewing of the plasma and simultaneous optical spectrometry 

for determining the trace elements—arsenic, beryllium, cadmium, chromium, and lead—and for 

mercury screening in acid-digested solutions of waste samples. 

Veolia Feedstream Rate Determination 

Several feed stream constituents have maximum feed rate limits specified in the HWC 

MACT standard, including: 
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 Chlorine and chloride 

 Semivolatile metals (cadmium and lead) 

 Low volatility metals (arsenic, beryllium, chromium) 

 Mercury 

 Ash 

According to D. Warshol, metals and ash concentrations for feed streams are entered into the 

WTS. These feed streams are identified in the WTS under a receiver number, bulk pit number, or 

tank number. Once this information is in the WTS, the incinerator control systems (ICS) are able to 

import and store the data for use as the waste streams are processed at the incinerators. All waste 

introduced into the incinerators has an associated site receiver number so it can be referenced to the 

appropriate data from the WTS. As weights are recorded at 15-second intervals for each specific 

waste stream entering the incinerator, computations are performed to calculate the quantities of 

metals (as low volatile metals, semivolatile metals, and mercury) and ash that are being incinerated. 

These quantities are displayed to the incinerator operator and recorded. One-hour and 12-hour 

rolling totals are displayed for the incinerator operators to monitor these feeds. 

NEIC Feed Stream Evaluation 

NEIC evaluated Veolia’s process for determining feed rates for compliance with the HWC 

MACT standard limits for chlorine and metals. The evaluation included an examination of 

laboratory methods and procedures, informational queries of the WTS database to evaluate how 

metals and chlorine values were established in the waste profiles, and an examination of select 

profiles based on the results of the database queries. According to D. Warshol and C. Narez, there 

are four sources of analytical information that Veolia can use in evaluating the feedstream 

parameters including: 

 Analysis performed on-site by Veolia 

 Analysis performed off-site 

 Manufacturer data or other published information such as material data safety sheets (MSDS) 

 Generator process knowledge 

According to D. Warshol, the following criteria are used in determining whether or not the 

Veolia laboratory will conduct metals analysis (supplemental analysis) on a waste: 
NEICVP0972E02 Page 14 of 27 Veolia ES Technical Services 

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 The waste has RCRA waste codes 

 The chemical composition of the waste provided by the generator 

 The process generating the waste 

 An internal list of suspect wastes (dynamic suspect list) 

 Brokered waste (third party) 

To evaluate the process for determining waste feed concentrations for metals, NEIC 

requested Veolia to conduct a query of the WTS database to compare the portion of waste profiles 

that were tested by the on-site laboratory to those that were not. This query was performed on 

wastes received in 2011 (January 1 through December 15, 2011), 2010, and 2009. Additional 

queries were performed for waste received in 2011, 2010, and 2009 to better understand why certain 

wastes were sampled and analyzed for metals, while others were not. Table 1 summarizes the total 

number of profiles for a particular year that met a particular query criteria. 

Table 1. SUMMARY OF TOTAL WASTE PROFILES MEETING SPECIFIED CRITERIA FOR 2009, 

2010, AND 2011 

Veolia ES Technical Services 

Sauget, Illinois 

Year 

Total 

Profiles 

Received 

Profiles with 

No On-site 

Metals 

Analysis 

Profiles 

with No 

RCRA 

Metals 

Codes 

Profiles With No 

RCRA Metals Codes 

and No On-site 

Metals Analysis 

Profiles with No RCRA 

Metals Codes but with 

On-site Metals Analysis

2011 4747 907 1131 881 250 

2010 5185 1043 1116 876 240 

2009 4396 1039 1051 973 178 

NEIC began its evaluation by reviewing waste profiles received in 2011 (January 1 through 

December 15, 2011) with RCRA metals codes but for which on-site analyses were not performed. 

Of the 907 profiles that were not analyzed for metals, 881 did not have RCRA metals codes. This 

left 26 profiles, according to the WTS, that were not analyzed for metals even though the waste 

stream had RCRA metals codes. C. Narez printed out the list of profiles that carried RCRA metal 

codes but for which on-site analyses were not performed. This list had 28 profiles instead of 26, 

because the WTS database query generated two profiles that did not have RCRA metals codes. K. 

Meredith and C. Narez went through 17 of the 28 profiles with NEIC inspectors during the on-site 

inspection. Information on the remaining 11 profiles was provided following the inspection. After 

review of all the information provided, 19 profiles had on-site metals analysis in the hard-copy file, 

but the metals information was entered in the approvals screen rather than the laboratory screen. 

Five of the profiles had been analyzed sometime in the past by the Port Arthur, Texas, Veolia, 

facility. Two profiles were analyzed by an off-site laboratory, and the metals concentrations for two 

profiles were based on generator knowledge but no analyses were performed. Both profiles 396651 
NEICVP0972E02 Page 15 of 27 Veolia ES Technical Services 

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and 008509 used generator knowledge; however, these profiles should not have been included in the 

RCRA metals codes group based on information provided by Veolia after the inspection. Table 2 

shows the profiles that had on-site analysis, historical data, off-site analysis, or generator knowledge 

data. 
NEICVP0972E02 Page 16 of 27 Veolia ES Technical Services 

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Table 2. WASTE PROFILES WITH RCRA METALS CODES THAT WERE NOT ANALYZED ON-SITE 

ACCORDING TO the WTS – FACILITY EXPLANATION 

Veolia ES Technical Services 

Sauget, Illinois 

Year Do In Fact Have 

On-site Analyses 

Historic Analyses 

(Port Arthur, TX) 

Off-site Analyses 

(Commercial 

Laboratory) 

Other 

(Process 

Knowledge, MSDS, 

etc.) 

2011 

Profiles 

157062 

272684 

323990 

360041 

374339 

388852 

554343 

554347 

565601 

566491 

567423 

581780 

6602101 

760266 

346628 

ELSOL3 

FSSOL3 

LOP005 

WSOL03 

CI5789 

6931282

ELLIQ32

WBA5012

WLIQ032

M57062 

360069 

0085092,3

3966513

1

 Veolia conducted on-site supplemental metals analysis after the NEIC inspection. 2

 Veolia intends to conduct on-site supplemental metals analysis the next time these profiles are received. 3

 These profiles do not contain RCRA metals codes. 

By December 2011, 881 profiles had been received in 2011 that did not contain RCRA 

metals codes and had not been analyzed for metals. Many of the waste names and process 

descriptions used to describe the 881 profiles in the WTS were generic and somewhat ambiguous. 

NEIC sorted the list of waste streams by largest volume in order to obtain more information on the 

higher volume wastes with generic descriptions. From the larger volume waste streams, NEIC 

inspectors briefly reviewed 26 profiles on-site based on the waste name and generator process 

description. K. Meredith and C. Narez explained the information provided in the hard-copy files for 

each selected profile. Table 3 summarizes the 26 high-volume wastes NEIC inspectors reviewed 

briefly while on-site. 

Table 3. SUMMARY OF HIGH-VOLUME WASTE PROFILES RECEIVED IN 2011 THAT WERE 

REVIEWED ON-SITE 

Veolia ES Technical Services 

Sauget, Illinois 

Profile Waste Name 

in the WTS 

Process Generating 

Waste 

in the WTS 

Quantity 

Received 

Jan – Dec 15, 

2011 

(Gallons) 
NEICVP0972E02 Page 17 of 27 Veolia ES Technical Services 

Sauget, Illinois 

Table 3. SUMMARY OF HIGH-VOLUME WASTE PROFILES RECEIVED IN 2011 THAT WERE 

REVIEWED ON-SITE 

Veolia ES Technical Services 

Sauget, Illinois 

Profile Waste Name 

in the WTS 

Process Generating 

Waste 

in the WTS 

Quantity 

Received 

Jan – Dec 15, 

2011 

(Gallons) 

397628 DE175 - IPA WASH & 

FILTRATE WA CHEMICAL MANUFACTURING 554,958 

388522 MOTHER LIQUOR 

RESIDUE 

PROCESS WASTE FROM 

MANUFACTURING OF 

INERMEDIATED HERBIC 

251,245 

076148 FORMULATION 

AQUEOUS W/ OR W/O PROCESS WASH WATER 230,602 

330470 RINSEWATER-ACUTE 

TOXIC CONTAINER CLEANING 55,591 

076886 DECON WATERTREATED VX & GB TO 

DECON OF CHEMICAL 

WEAPONS RECOGNITION 

TRAINING COMPLEX. 

52,372 

127773 WR-120S OVER 3MP 

CONCENTRATE PROCESS WASTE 29,828 

AF4699 RINSE WATER CLEANING OUT AN HERBICIDE 

PLANT 27,395 

BJ3050 LABORATORY GC/HPLC 

VIALS AND D 

LABORATORY ANALYSIS 

ACCUMULATION 24,500 

104147 FORMULATION 

AQUEOUS COMBO PROCESS WASH WATER 24,442 

PZLOP3 LOOSE PACKS OF NONREGULATED M 

UNUSED PRODUCTS OR USED 

MATERIALS 21,404 

075342 554 PAINT BOOTH 

FILTERS 

PAINT BOOTH FILTER CHANGE 

OUT 19,250 

375309 FORMULATING & 

PROCESS BIPRODUC PESTICIDE MANUFACTURING 16,775 

131690 MARS D-1200 TAR TANK 

WASTE PRODUCTION PROCESS WASTE 15,228 

JJLP03 NON REG MATERIAL - 

LOOSE PACK 

UNUSED PRODUCTS OR USED 

MATERIALS 13,880 

048932 

XM-077352 

ORGANOMETALLIC 

SOLID 

METALORGANIC 

MANUFACTURING 11,685 

164854 CARBON WITH 1107 

FLUID 

CARBON WITH RESIDUAL 

CONTAMINATION AFTER MOST 

OF FLUID REMOVED BY 

NITROGEN FLUSH 

11,600 

ELSOL3 SOLIDS CHLORINE <25%

INDUSTRIAL CLEANING, R&D, 

LAB WASTE, MACHINING 

OPERATIOANK CLEAN-OUTS 

10,744 

AF3753 MERCURY 

CONTAMINATED SOLIDS

THIMEROSAL FILTERING, 

COLLECTING AND STORING 10,230 

388582 GANTREZ S SOLUTION OFF-SPEC SOLUTION 9,985 

236152 CARBON WITH CHROME DISCARD OF USED CARBON 

FILTER MEDIA 9,090 
NEICVP0972E02 Page 18 of 27 Veolia ES Technical Services 

Sauget, Illinois 

Table 3. SUMMARY OF HIGH-VOLUME WASTE PROFILES RECEIVED IN 2011 THAT WERE 

REVIEWED ON-SITE 

Veolia ES Technical Services 

Sauget, Illinois 

Profile Waste Name 

in the WTS 

Process Generating 

Waste 

in the WTS 

Quantity 

Received 

Jan – Dec 15, 

2011 

(Gallons) 

008509 

CARBON 

W/HALOGENATED 

ORGANICS 

PROCESS BY PRODUCT 8,349 

127318 POWDER PAINT WITH 

BENZENE 

POWDER COATING METAL 

PARTS 7,205 

BZ3601 MERCK (PA) - 

TOLUENE/AVERMECTI SPILL CLEANUP 7,050 

442913 DEBRIS ARSENIC 

SEMICONDUCTOR 

MANUFACTURING/EQUIPMENT 

CLEANING 

6,600 

BS1067 WASTE VOC SLUDGE 

GRAVITY SEPARATION OF 

LEACHATE FROM NON-CERCLA 

REMEDIAT 

6,396 

075231 RED DUST W/TRACE 

FUNGICIDES/IN 

DUST CREATED BY 

APPLICATION OF FUNGICIDE & 

INSECTICIDE SEED CORN IN 

PLANT. COLLECTION SYSTEM 

REMOVES DUST FROM 

5,885 

Several profile files were photocopied and reviewed more thoroughly following the 

inspection. Six of the complete profile files for select waste streams from Tables 2 and 3 had 

conflicting information with respect to metals values in the WTS compared to the hard-copy file. 

Table 4 lists the six profiles with concerns regarding how the metals values were established in the 

WTS. 
NEICVP0972E02 Page 19 of 27 Veolia ES 

Sauget, Il

Table 4. LIST OF PROFILES WITH CONCERNS REGARDING HOW THE METALS VALUES WERE ESTABLISHE

Veolia ES Technical Services 

Sauget, Illinois 

Profile Generator/Waste Source Waste Type Initial Date Metal TCLP (mg/L) Total Metal Concentrations (mg/kg) Value used in the WTS Value used in IPS/ICS Gal/Year 

236152 Praxair Inc. /

Calgon

Spent Carbon Mar‐06 Cr 11.4 30000 None 228 9,090 1

(

m

T

3

p

p2o

ES3

m

0

V

t

w1

ict

tp3

s

w

f

Cd 0.876 None 17.52

691163 L‐3 Corp Combat

Prop Systems /

Painting Of M1

Abram Tank Parts

Paint Booth

Waste Purge

& Non

May‐

05

As <0.10

mg/L

0 0 935 1

g

tc

Be 0 0

Cd <0.10 0 0
NEICVP0972E02 Page 20 of 27 Veolia ES 

Sauget, Il

Table 4. LIST OF PROFILES WITH CONCERNS REGARDING HOW THE METALS VALUES WERE ESTABLISHE

Veolia ES Technical Services 

Sauget, Illinois 

Profile Generator/Waste Source Waste Type Initial Date Metal TCLP (mg/L) Total Metal Concentrations (mg/kg) Value used in the WTS Value used in IPS/ICS Gal/Year 

And Flushing Of

Sprayer

mg/L 1

o

i

2

t

g

i

cm

mb

Cr 1.8

mg/L

0 0

Pb <0.40

mg/L

0 0

Hg <0.002 0 0

660210 Veolia

– Azuza /

Unused Materials

From TSDF

Transhipment,

Consolidation

Cyanide

Loosepack

As <5 5 5 5 3,740 U

a

mtPwc

S

t

s

v

Be 0.1 0.1 0.1

Cd <1 1 1 1

Cr <5 2.5 2.5 2.5

Hg <.2 0 0 0

Pb <5 2.5 2.5 2.5

CI5789 Burlington

Environmental

Inc. / Cyanide

Consolidation

From Outside

Sources

Cyanide

Mixture

Solution

As 200 <5 14,281 P

a6

b

qNV

b

Cd 6470 None 4941

Cr 200 23.8

Pb 200 6.7

Hg 0 <0.2
NEICVP0972E02 Page 21 of 27 Veolia ES 

Sauget, Il

Table 4. LIST OF PROFILES WITH CONCERNS REGARDING HOW THE METALS VALUES WERE ESTABLISHE

Veolia ES Technical Services 

Sauget, Illinois 

Profile Generator/Waste Source Waste Type Initial Date Metal TCLP (mg/L) Total Metal Concentrations (mg/kg) Value used in the WTS Value used in IPS/ICS Gal/Year 

avt

r

AF3753 Boehringer

Ingelheim

Vetmedica /

Thimerosal

Filtering,

collecting and

storing

Mercury

contaminated

solids

Jul‐93 Hg 37.8 4140 0 – 25 25 10,230 7

T37m41

TAt

wt

o

t

rr

p

isd

iv

m

s

a

i
NEICVP0972E02 Page 22 of 27 Veolia ES 

Sauget, Il

Table 4. LIST OF PROFILES WITH CONCERNS REGARDING HOW THE METALS VALUES WERE ESTABLISHE

Veolia ES Technical Services 

Sauget, Illinois 

Profile Generator/Waste Source Waste Type Initial Date Metal TCLP (mg/L) Total Metal Concentrations (mg/kg) Value used in the WTS Value used in IPS/ICS Gal/Year 

374339 Environmental

Enterprises /

Consolidated at

TSDF

Organic

Debris

Jan‐04 As <5 None 5 76,760 A

t

w

tu

T

w

ser

Cd <1 None 5

Cr <5 None 5

Hg <0.2 None 0

Pb <5 None 5Be <10 None 10
NEICVP0972E02 Page 23 of 27 Veolia ES Technical Services 

Sauget, Illinois 

In general, the evaluation of the profiles listed in Table 4 revealed three major concerns 

regarding Veolia’s waste characterization protocols. 

 The use of toxicity characteristic leaching procedure (TCLP) results instead of total metals 

concentrations: Some of the profile packages reviewed contained metals values that were based 

on TCLP analysis instead of total metals analyses. For profile 236152, TCLP values were used 

to calculate the total chromium and cadmium feed rates in the ICS. This calculation is based on 

Veolia’s application of the “20 times rule” because of the 1:20 dilution used in the TCLP test. 

This rule cannot be used when attempting to derive total concentrations from TCLP because the 

ratio of 20 assumes that the material being analyzed by TCLP is completely soluble. The result 

of misapplication of the 20 times rule is an underestimation of actual metals concentration in the 

waste. Veolia is using a chromium value of 228 milligrams per kilogram (mg/kg) and a 

cadmium value of 17.52 mg/kg for profile 236152. However, a material safety data sheet in the 

profile package listed a total chromium oxide value of 30,000 to 60,000 mg/kg. Profile 691163 

has a TCLP value for chromium of 1.8 (milligrams per liter [mg/L]), but the WTS and ICS used 

a chromium value of 0 mg/L. This result may greatly underestimate the actual chromium 

concentration for this waste stream. 

 Overly broad profiles: NEIC reviewed several profiles that were based on general processes 

that did not consider the possibility for variability in volatile or semivolatile metals 

concentrations. For example, profiles 660210 and CI5789 both are described as “cyanide 

containing wastes.” While both profiles list cadmium cyanide as a possible constituent, Veolia 

uses a value of 6,470 mg/kg cadmium for profile CI5789 and 1 mg/kg cadmium for profile 

660210. Since these are very similar waste streams generated by different generators, Veolia 

should analyze these variable waste streams each time they arrive on-site. Profile 374339 is 

another example of overly broad profiling. Profile 374339 is organic debris, and the metals 

concentrations in the waste loads could vary greatly. 

 Conflicting metals data: NEIC identified the presence of conflicting metals data between the 

profile package and the information in the WTS and ICS. For profile 236152, an MSDS 

contained in the profile package listed the chromium concentration as “3 to 6 percent chromium 

as chromium oxide” (30,000 to 60,000 mg/kg), while the ICS used a value of 228 mg/L for this 

profile. The profile package for 691163 has a TCLP value for chromium of 1.8 mg/L, while the 

WTS and ICS used a value of 0 mg/L. The profile package for AF3753 has a total mercury 

value of 4140 mg/kg (TCLP value of 37.8 mg/L), but the WTS and ICS used a value of 25 

mg/kg for at least 5 years. Having conflicting values between profile packages and databases, 

without a clear indication as to which value is correct, could lead to the use of incorrect metals 

concentrations for feed rate calculations. 

Additionally, Veolia has several profiles that contain metals results identical to those used in 

other profiles. There is a concern regarding insufficient testing of incoming wastes under these 

profiles: Table 5 shows the number of times that a “pattern” of metals values was repeated for 

different profiles that were received in quantities greater than 20,000 pounds in 2010 and 2011. 

There are several times when a profile initially matches the metals values of several other profiles at 

one point in time, and then the metal values change and match the metals values of several other 

different profiles. 
NEICVP0972E02 Page 24 of 27 Veolia ES Technical Services 

Sauget, Illinois 

Table 5. SUMMARY OF REPEATING METALS CONCENTRATIONS FOR WASTE RECEIPTS 

GREATER THAN 20,000 POUNDS PER YEAR 

Veolia ES Technical Services 

Sauget, Illinois 

Number of 

Profiles With 

Same Metals 

Concentrations 

Pounds 

Received 

in 2010 

Repeating Constituents (mg/kg) 

Arsenic Beryllium Cadmium Chromium Lead Mercury 

21 192058 5 5 263.8 5 21.6 0 

15 187229 78 5 23 139 433 0 

4 144905 0 0 0 2.5 0 0 

18 45415 5 5 5 5 5 0 

49 43950 200 5 5 38 5 0 

9 43248 0 0 0 5 0 0 

7 42730 12 5 5 26 5 0 

6 40912 26 10 20 50 100 0 

21 30065 0 0 0 0 5 0 

6 20324 5 0 5 5 5 0 

NEIC examined the number of times that two of the profiles that contained repeating metals 

concentrations were analyzed by Veolia. The profiles examined were CARBN1 and SOL005. 

Veolia provided NEIC with a database containing the number of times each of these profiles was 

received during the period of June 2009 through June 2012. The database also listed the waste 

receipts that were analyzed for metals. For profile CARBN1, Veolia received 330 waste loads 

(receipts). Of the 330 receipts, 19 were analyzed for metals. As shown in Table 6, 12 of the 19 

loads analyzed were on waste loads received after December 2011, which is more than two times the 

number of loads analyzed in the previous 2 years. No analyses were conducted on the 56 waste 

loads received in 2009 and the 112 waste loads received in 2010. This data is summarized in Table 

6. 

Table 6. SUMMARY OF LOADS RECEIVED AND ANALYZED FROM JUNE 2009 TO JUNE 2012 FOR 

STANDARD PROFILE CARBN1 AND SOL005 

Veolia ES Technical Services 

Sauget, Illinois

Profile CARBN1 Profile SOL005

Number of receipts 

between 6/2009 and 

6/2012 

330 

Number of receipts 

between 6/2009 and 

6/2012 

264 

Number of receipts not 

analyzed 311 Number of receipts not 

analyzed 244 

Number of receipts 

analyzed between 

6/2009 and 6/2012 

19 

Number of receipts 

analyzed between 

6/2009 and 6/2012 

20 

SUMMARY OF WHEN LOADS WERE ANALYZED FROM JUNE 2009 TO JUNE 2012 FOR STANDARD 

PROFILE CARBN1 AND SOL005 

Veolia ES Technical Services 

Sauget, Illinois 
NEICVP0972E02 Page 25 of 27 Veolia ES Technical Services 

Sauget, Illinois 

Profile CARBN1 Profile SOL005

Month and Year Load 

Receipt Analyzed 

Number of Receipts 

Analyzed 

Month and Year 

Receipt Analyzed 

Number of Load 

Receipts Analyzed 

January 2011 1 July 2011 1 

March 2011 1 February 2012 5 

April 2011 5 March 2012 3 

December 2011 1 April 2012 7 

January 2012 11 May 2012 4 

Veolia provided NEIC with all analysis results for profile CARBN1. One of the load 

receipts (received on April 8, 2011) that was sampled and analyzed on June 9, 2011, had a chromium 

concentration of 99,780 mg/kg, while the standard value for chromium is 139 mg/kg chromium for 

CARBN1 waste streams. There is a concern that standard profiles such as CARBN1, which has the 

potential to have such significant differences in chromium concentrations, are not adequately 

representing the waste streams or being analyzed regularly enough to detect variability in the waste. 

 Only 19 of the 330 total CARBN1 loads received in a 3-year period (June 2009 to June 2012) were 

sampled and analyzed for metals, and all of these 19 analyzed loads were since January 2011. The 

use of overly broad standard profiles could lead to incorrect metals values being used to calculate the 

feed rate requirements for the incinerator. 

Figure 2 is a flowchart that summarizes analysis categories (exempt from analysis, 

mandatory analysis, or supplemental analysis) for all the profiles received from January 1, 2011, 

through December 15, 2011. Of the 1,197 profiles received in 2011 that required mandatory on-site 

analysis, 881 of these profiles were not analyzed for metals as of the NEIC inspection. This is 

roughly 73 percent of the profiles received that require mandatory sampling. 
NEICVP0972E02 Page 26 of 27 Veolia ES Technical Services 

Sauget, Illinois 

4,747

Profiles received

according to WTS

(7,859,146 gal)

Figure 2

Summary of Waste Analysis Categories for profiles Received in 2011

Veolia ES Technical Services – Sauget, Illinois

3,550

(1,827,451 gal)

1,197

(6,031,695 gal)

66

(1,037,577 gal)

1,131

(4,994,118 gal)

250

(1,303,408 gal)

881

(3,690,710 gal)

56 (at the time of the NEIC

inspection)

10 ‐6 profiles with  historical

analytical (e.g. Port Arthur)

‐2 profiles with offsite

metals analysis results

‐ 2 profiles with MSDS or

process knowledge

5.5% (by profile)

17.2% (by waste volume)

74.8% (by profile)

23.3% (by waste volume)

25.2% (by profile)

76.7% (by waste volume)

94.5% (by profile)

82.8% (by waste volume)

15.2% (by profile)

22.1% (by profile)

26.1% (by waste volume)

77.9% (by profile)

73.9% (by waste volume)

234

(3,541,552 gal)

71.5% (by profile)

4.1% (by volume) 28.5% (by profile)

95.9% (by volume)

647

(149,158 gal)

‐ 26 profiles reviewed

(1,442,289 gal)

‐ 2 profiles with

questionable metal

values (19,320 gal)

Reviewed:

11.1% (by profile)

40.7% (by volume)

‐ 2 profiles with

questionable metal

values (18,021 gal)

20.0% (by profile)

Have onsite

supplemental

metals analysis

According to

WTS

84.8% (by profile)

Have onsite

supplemental

metals analysis

according to

WTS

Less than

1,000 gal

received

Requires

Mandatory

sampling

according to

WTS

Have RCRA

metals codes

according to

WTS

YES NO

NO

YES

YES NO

YES

YES NO

NO

7.7% of profiles reviewed

1.3% of waste volume

These 6 profiles

Account for 115,036 gal of

waste received in 2011

‐ 1 profile reviewed

‐ Profile no. 691163

with questionable

metals values (935 gal)

Spot checked:

‐ 1 with concern

‐ profile no. 374339

is a variable waste

stream (76,760 gal)

Figure 2. Summary of Waste Analysis Categories for Profiles Received in 2011 

Veolia ES Technical Services 

Sauget, Illinois 
NEICVP0972E02 Page 27 of 27 

SUMMARY OF OBSERVATIONS 

The following observations were made at the time of the inspection, and during review of documents received prior to, dinspection of the Veolia facility. The observations pertain to areas or issues identified by NEIC that may have potential are neither inclusive nor exclusive of all such potential areas or issues. Observations included potential problems/activitienvironment, result in future noncompliance with permit or regulatory requirements, and/or are areas associated with poU.S. EPA Region 5 will assess the applicability of regulatory requirements based on its review of this report and other tefacility information. RESOURCE CONSERVATION AND RECOVERY ACT 

# Observations/Areas of Concerns 

1 1. On at least two waste profiles, Veolia used TCLP concentrations instead of total metals concentrations. 

2. Overly broad waste categories listed in profiles. 

2 1. Veolia is not analyzing the metals values for the ash from incinerators 2 and 3 at an evaluation frequency that ad

per the FAP requirements. 

2. Conflicting metals values are present in several profile packages (236152, 691163, and AF3753), with no clear i

appropriately characterize the waste per the FAP requirements. 

3 ICP analysis of metals – The automatic background and overlap corrections applied by the Veolia’s ICP software were ob

peaks when unknown constituents were present in the sample. Veolia personnel do not measure all major elements in sampotential negative interferences. 

4 Profile AF3753 is a debris waste stream from veterinary pharmaceutical manufacturing. In the profile package, there was 

4,140 ppm. If this concentration were present in the waste that was incinerated on August 28 and 29, 2011, the emissions would have been exceeded.