# NEICVP0972E02 Page 2 of 27 Veolia ES Technical Services Sauget, Illinois 

# CONTENTS

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

BACKGR OUND .................................................................................................................... .. 4

Facility Unit Opera tions Over view ............................................................................................. ......................... 4 Bulk Liquids Proce ssing........................................................................................................ ............................... 6 Containerized Liqui ds Pro cessing .............................................................................................. .......................... 6

Containerized So lids Pro cessing ............................................................................................... ........................... 7

Bulk Solids Proce ssing ........................................................................................................ ................................. 8


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

WASTE CHARACTERIZATION PR OCESS DESCRIPTION .............................................. 9

Waste Appr ovals ............................................................................................................... ................................... 9 Waste Accep tance .............................................................................................................. ................................ 10 On-site Laboratory Pr ocess Over view ........................................................................................... ..................... 11

Veolia Feedstream Ra te Determ ination .......................................................................................... .................... 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 T echnical 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 Prot ection Agency (EPA) Region 5, EPA’s National

Enforcement Investigations Center (NEIC) conducted a focused multimedia compliance

investigation of the Veolia Environmental Se rvices (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 subj ect to several environmental statutes, including

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

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

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

and the Illinois Environmental Protection Agency (IEPA).

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

inspection team included: Alison Ruhs (environmen tal 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 repr esentatives Doug Harris, Dennis Warshol, and David

Klarich.

# NEICVP0972E02 Page 4 of 27 Veolia ES Technical Services Sauget, Illinois 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 ha s a maximum total contai ner 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

# NEICVP0972E02 Page 5 of 27 Veolia ES Technical Services Sauget, Illinois 

#  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 li quid 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 st ore 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 locat ed 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 orga nic waste, aqueous wastes, pumpable sludges, and

virgin fuel that are fed to the incinerator system . Pumps transfer these wa stes 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 th at 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 ar e 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 pe rmit 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 cont ainerized 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 liqui d feed for containers with viscosity, odor, and/or

compatibility concerns. Incinerator 2 can also in cinerate 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 a nd is equipped with its own tank farm system

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

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

# NEICVP0972E02 Page 6 of 27 Veolia ES Technical Services Sauget, Illinois 

# 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 percen t chlorine in waste fed into the

incinerators

 pH – measured to protect the integrity of ta nk farm construction materials and provide management data for proper blending

 Specific gravity (s.g.) – measured to ensure that the sp ecific 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 syst em, 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 recei ve 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 ar e 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 incinera tor (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 processe d 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 th e 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 compatib ility. If a “heel” of waste remains in the tank, the heel is also

sampled to ensure compatibility. Once all the samp les 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 ar e 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 optim um incinerator performance when the waste is

injected. Laboratory staff enter th e 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 re packaging 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 processi ng 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 tippe r 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 ab sorbed with corn cobs or Dry-All abso rbent. A

process planner determines the amount and type s 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

# NEICVP0972E02 Page 8 of 27 Veolia ES Technical Services Sauget, Illinois 

# 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 ch arges 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 s cale, and the receiver number is entered into the

incinerator control/processing system (ICS/IPS) syst em. 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 refr actory-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 dumpe d into one of four in-ground pits (pits 1, 2, 3, and 4). According

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

incinerator ash from incinerators 2 and 3. The as h 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 th e 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 co mmunicating on the intercom with the incinerator

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

the clamshell and drops the material into the hoppe r. 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 determ ine 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) Pa rt 63, Subpart EEE – National Emission Standards

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

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

streams). Regarding RCRA compliance, the inves tigation 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 sy stem called the “I-Series.” Waste generators

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

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

out a waste profile sheet (WPS), often with the he lp of VESNA representativ es, and the information

is entered into the I-Series. VESNA representa tives 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 obt ain 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, chro mium, 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 stream s 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 sta ndard 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 analy tical 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 wast e meets an exception from

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

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

performed to further identify wastes and are performe d 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 st ate (normal) operation of the incinerator. Blend

analyses are typically performed after approval, on ce 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 origin al container or package. Another category is

wastes that are identifiable through a visual inspec tion 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 shi pping 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 pr ofile) 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, acc ording 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 wast es are sampled and analyzed after receipt at receiving building 3.

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

sampled. Mandatory analysis is performed on all sa mples, 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-confor ming waste is managed. If a discrepancy

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

# NEICVP0972E02 Page 11 of 27 Veolia ES Technical Services 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 paperw ork, 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 labor atory is equipped with two ion chromatograph (IC)

instruments for measuring total halogens, tw o 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 ar e 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:

# NEICVP0972E02 Page 12 of 27 Veolia ES Technical Services 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 perf ormed on wastes with a pH less than or equal to

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

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

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, th e generation of heat, fire , explosion, or violent

reaction is noted by the analyst.

The laboratory uses bomb calorimetry to determ ine Btu content. The bomb washings from

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

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

feed rate calculation. Veolia determines the con centration 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:

# NEICVP0972E02 Page 13 of 27 Veolia ES Technical Services Sauget, Illinois 

#  Chlorine and chloride

 Semivolatile metals (cadmium and lead)

 Low volatility metals (arsenic, beryllium, chromium)

 Mercury

 Ash

According to D. Warshol, metals and ash concentr ations 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 str eams 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 ar e recorded at 15-second intervals for each specific

waste stream entering the incinerator, computati ons 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 incinerato r 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 determin ing 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 Sauget, Illinois 

#  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 da tabase to compare the portion of waste profiles

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

wastes received in 2011 (January 1 thr ough 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 wast e 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 me tals, 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 printe d out the list of profiles that carried RCRA metal

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

because the WTS database query generated two prof iles 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 prof iles was provided following the inspection. After

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

but the metals information was entered in the appr ovals 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 perfor med. Both profiles 396651

# NEICVP0972E02 Page 15 of 27 Veolia ES Technical Services Sauget, Illinois 

# 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, histori cal data, off-site analysis, or generator knowledge

data.

# NEICVP0972E02 Page 16 of 27 Veolia ES Technical Services Sauget, Illinois 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

660210 1



# 760266

346628
ELSOL3
FSSOL3
LOP005
WSOL03 CI5789

693128 2



# ELLIQ3 2



# WBA501 2



# WLIQ03 2 

# M57062

360069 008509 2,3



# 396651 3

1 

## Veolia conducted on-site supplemental me tals analysis after the NEIC inspection.

2 

## Veolia intends to conduct on-site supplemental meta ls analysis the next time t hese profiles are received.

3 

## These profiles do not contain RCRA metals codes.



# By December 2011, 881 profiles had been recei ved 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 st reams 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 WAST E 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 WAST E 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 WAST E 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 a nd reviewed more thoroughly following the

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

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

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

WTS.NEICVP0972E02 Page 19 of 27Veolia ES Technical ServicesSauget, IllinoisTable 4. LIST OF PROFILES WITH CONCERNS REGARDINGHOW THE METALS VALUES WERE ESTABLISHED IN THE WTSVeolia ES Technical ServicesSauget, IllinoisProfileGenerator/WasteSourceWasteTypeInitialDateMetalTCLP(mg/L)TotalMetalConcentrations(mg/kg)ValueusedintheWTSValueusedinIPS/ICSGal/YearComments:SourceofValueUsed236152PraxairInc./CalgonSpentCarbonMar‐06Cr11.430000None2289,0901)TotalCr=3%‐6%(30000–60000mg/kg)ChromiumTrioxidebasedona3/21/2006MSDSprovidedinprofilepackage.2)TCLPvaluesfromoffsiteanalytical(SGSEnvironmentalServices,Inc.on3/24/2006)was11.4mg/LforCr,and0.876mg/LforCd.Veoliastatedthat20timesTCLPvalueswereused(228and17.52mg/L)fortheincineratorfeedratecalculations(althoughtherearenovaluesintheWTSqueryprovidedtoNEIC).3)Veoliaisgoingtosamplethewastestreaminthefuture.Cd0.876None17.52691163L‐3CorpCombatPropSystems/PaintingOfM1AbramTankPartsPaintBoothWastePurge&NonMay‐05As<0.10mg/L009351)Crislikelymuchgreaterthan20timestheTCLPconcentrationofBe00Cd<0.1000NEICVP0972E02 Page 20 of 27Veolia ES Technical ServicesSauget, IllinoisTable 4. LIST OF PROFILES WITH CONCERNS REGARDINGHOW THE METALS VALUES WERE ESTABLISHED IN THE WTSVeolia ES Technical ServicesSauget, IllinoisProfileGenerator/WasteSourceWasteTypeInitialDateMetalTCLP(mg/L)TotalMetalConcentrations(mg/kg)ValueusedintheWTSValueusedinIPS/ICSGal/YearComments:SourceofValueUsedAndFlushingOfSprayermg/L1.8mg/L(6/9/2005offsiteanalysisresultinprofilepackage).2)VeoliastatedthattheprocessgeneratingthewasteisnotsuspectedofcontainingMACTmetals.NoonsitemetalanalyseshasbeenconductedCr1.8mg/L00Pb<0.40mg/L00Hg<0.00200660210Veolia–Azuza/UnusedMaterialsFromTSDFTranshipment,ConsolidationCyanideLoosepackAs<55553,740UsedPortArthur,TXanalytical.VeoliaranmetalsanalysisaftertheNEICinspection.Profilestatedthatthewastecontainscadmiumcyanide.Sincethisisabrokertypewaste,someshipmentsmayhaveveryhighCd.Be0.10.10.1Cd<1111Cr<52.52.52.5Hg<.2000Pb<52.52.52.5CI5789BurlingtonEnvironmentalInc./CyanideConsolidationFromOutsideSourcesCyanideMixtureSolutionAs200<514,281PortArthur,TXanalyticalvalueof6470ppmCdhasbeenusedsince1999.NovaluesintheWTSqueryprovidedtoNEIC.AccordingtoVeoliathewastehasbeenanalyzedonsiteCd6470None4941Cr20023.8Pb2006.7Hg0<0.2NEICVP0972E02 Page 21 of 27Veolia ES Technical ServicesSauget, IllinoisTable 4. LIST OF PROFILES WITH CONCERNS REGARDINGHOW THE METALS VALUES WERE ESTABLISHED IN THE WTSVeolia ES Technical ServicesSauget, IllinoisProfileGenerator/WasteSourceWasteTypeInitialDateMetalTCLP(mg/L)TotalMetalConcentrations(mg/kg)ValueusedintheWTSValueusedinIPS/ICSGal/YearComments:SourceofValueUsedandtotalmetalsvaluesareusedfortheincineratorfeedratecalculations.AF3753BoehringerIngelheimVetmedica/ThimerosalFiltering,collectingandstoringMercurycontaminatedsolidsJul‐93Hg37.841400–252510,2307/23/93and11/16/93TCLP(onprofile)=37.8mg/L.7/23/93Totalmercury(onprofile)=4140.12/30/04and2/14/07TCLP">=0.2mg/L".AccordingtoVeoliatotalmercuryanalysiswasmeasuredandthemeasuredvalueof25ppmisusedfortheincineratorfeedratecalculations,ratherthantheprofilevaluesstoredintheWTS.However,sincethehistoricaldataintheprofileindicatesamercuryvalueashighas4140mg/kg,thiswastestreamshouldbeanalyzedeachtimeitisreceived.NEICVP0972E02 Page 22 of 27Veolia ES Technical ServicesSauget, IllinoisTable 4. LIST OF PROFILES WITH CONCERNS REGARDINGHOW THE METALS VALUES WERE ESTABLISHED IN THE WTSVeolia ES Technical ServicesSauget, IllinoisProfileGenerator/WasteSourceWasteTypeInitialDateMetalTCLP(mg/L)TotalMetalConcentrations(mg/kg)ValueusedintheWTSValueusedinIPS/ICSGal/YearComments:SourceofValueUsed374339EnvironmentalEnterprises/ConsolidatedatTSDFOrganicDebrisJan‐04As<5None576,760AccordingtoVeoliatotalmetalsanalyseswasrunonsiteandtotalMACTmetalsusedforIPS/WTS.Thisisavariablewastestreamthatshouldbeanalyzedeachtimealoadisreceived.Cd<1None5Cr<5None5Hg<0.2None0Pb<5None5Be<10None10

# NEICVP0972E02 Page 23 of 27 Veolia ES Technical Services Sauget, Illinois 

# In general, the evaluation of the profiles liste d in Table 4 revealed three major concerns

regarding Veolia’s waste characterization protocols.

 The use of toxicity characteristic leaching pr ocedure (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 anal yses. 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 deri ve total concentrations from TCLP because the ratio of 20 assumes that the material being analy zed by TCLP is completely soluble. The result of misapplication of the 20 times rule is an undere stimation 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. Howe ver, a material safety data sheet in the profile package listed a total chromium oxi de 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 va riability in volatile or semivolatile metals concentrations. For example, profiles 660210 and CI5789 both are described as “cyanide containing wastes.” While both profiles list cadmi um 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 stream s 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. Pr ofile 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 th e WTS and ICS. For profile 236152, an MSDS contained in the profile package listed the chromi um 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 va lues between profile packages and databases,

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

concentrations for feed rate calculations.

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

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

profiles: Table 5 shows the numbe r 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 matche s 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. Th e profiles examined were CARBN1 and SOL005.

Veolia provided NEIC with a database containi ng 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. Fo r 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 afte r December 2011, which is more than two times the

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

loads received in 2009 and the 112 waste loads receive d 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 re sults 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 re gularly 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 thes e 19 analyzed loads were since January 2011. The

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

feed rate requirements for the incinerator.

Figure 2 is a flowchart that summarizes an alysis 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 recei ved in 2011 that required mandatory on-site

analysis, 881 of these profiles were not analyzed fo r 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, IllinoisNEICVP0972E02Page 27 of 27Veolia ES Technical ServicesSauget, IllinoisSUMMARY OF OBSERVATIONSThe following observations were made at the time of the inspection, and during review of documents received prior to, during, and after NEIC’sinspection of the Veolia facility. The observations pertain to areas or issues identified by NEIC that may have potential compliance implications, butare neither inclusive nor exclusive of all such potential areas or issues. Observations included potential problems/activities that could impact theenvironment, result in future noncompliance with permit or regulatory requirements, and/or are areas associated with pollutionprevention issues.U.S. EPA Region 5 will assess the applicability of regulatory requirements based on its review of this report and other technical, regulatory, andfacility information.RESOURCE CONSERVATION AND RECOVERY ACT#Observations/Areas of Concerns11.On at least two waste profiles, Veolia used TCLP concentrations instead of total metals concentrations.2.Overly broad waste categories listed in profiles.21.Veolia is not analyzing the metals values for the ash from incinerators 2 and 3 at an evaluation frequency that adequately characterizes the wasteper the FAP requirements.2.Conflicting metals values are present in several profile packages (236152, 691163, and AF3753), with no clear indication of which metal valuesappropriately characterize the waste per the FAP requirements.3ICP analysis of metals – The automatic background and overlap corrections applied by the Veolia’sICP software were observed toresult in large negativepeaks when unknown constituents were present in the sample. Veolia personnel do not measure all major elements in samples to identify and correct forpotential negative interferences.4Profile AF3753 is a debris waste stream from veterinary pharmaceutical manufacturing. In the profile package, there was a total mercury analytical value of4,140 ppm. If this concentration were present in the waste that was incinerated on August 28 and 29, 2011, the emissions and feed rate limits for mercurywould have been exceeded.