UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 5 

77 WEST JACKSO N BOULEVARD 

CHICAGO, IL 60604-3590 

MAY 1 3 2013 

REPL Y TO TH E ATTENTION OF: 

Douglas Harris, General Manager 

Veolia ES Technical Solutions, L.L.C. 

7 Mobile Avenue 

Sauget, Illinois 62201 

Re: EPA's comments on Veolia ES Technical Solutions, L.L.C.'s Comprehensive Performance 

Test Plans for Incinerators 2, 3, and 4 

Dear Mr. Harris: 

Veolia ES Technical Solutions, L.L.C. (Veolia) submitted its Comprehensive Perfonnance Test 

(CPT) plans and Quality Assurance Project Plan (QAPP) for Incinerators 2, 3, and 4 at its 

Sauget, Illinois facility to the U.S. Environmental Protection Agency on September 5, 2012. 

Veolia is required to conduct a CPT pursuant to the Clean Air Act (CAA) National Emission 

Standards for Hazardous Air Pollutants from Hazardous Waste Combustors, 40 C.F.R. Part 63, 

Subpart EEE (HWC MACT). Prior to commencing the CPT, Veolia must submit a complete 

CPT plan for each incinerator to EPA for review and approval or intent to deny, 40 C.F.R. 

§ 63.1207(e). The HWC MACT lists specific information that HWCs must provide in their CPT 

plans. Upon review of Veolia's September 5, 2012 submittal, EPA has discovered that the CPT 

plans and QAPPs are missing required information. EPA cannot approve the CPT plans or the 

QAPPs until they meet the requirements of the HWC MACT, including providing all of the 

required information. Therefore, EPA is providing Veolia with notice of its intent to deny the 

approval of its September 5, 2012 CPT plans. 

Specifically, Veolia's September 5, 2012 CPT plan and QAPP failed to include the following 

information: 

CPT Comments: 

1. Pursuant to 40 C.F.R. § 63.1206(b)(2), EPA must determine compliance with the 

emission standards of this subpart as provided by § 63.6(f)(2). Therefore, due to the 

synergistic nature of chlorine and mercury, Veolia must test Incinerator 4 for 

dioxin/furans (D/F), mercury (Hg), at the maximum chlorine level over the past five 

years at the same time with runs at each: low, medium, and high temperatures. At each 

Incinerator 2 and 3, Veolia must test for Hg and D/F during the same test runs with at 

least one run at the maximum chlorine level over the past five years and at least one run 

at low chlorine. 

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2. Pursuant to 40 C.F.R. § 63.1206(h)(2), pretesting is defined as: (i) Operations when 

stack emissions testing for D/F, Hg, semi-volatile metals (SVMs), low-volatile metals 

(LVMs), particulate matter (PM), or hydrochloric acid or hydrogen chloride (HCI/CI2) 

is being performed; and (ii) operations to reach steady-state operating conditions prior 

to stack emissions testing under paragraph (g)(l)(iii) of this_sectiom _Veolia's operating 

parameter limits (OPLs) will be waived ONLY during the testing period and the time it 

takes for operations to reach steady-state operations prior to each run that Veolia has 

claimed are required to reach steady-state operation. Veolia has not satisfactorily 

substantiated how its requested 720-hour pretesting period meets the above definition. 

Therefore, EPA will not approve waiving the OPLs for 720 hours prior to the test. 

3. Pursuant to 40 C.F.R. § 63.1207(f)(l)(i)(A), the CPT plan must include an analysis of 

each feedstream, including hazardous waste, other fuels, and industrial furnace 

feedstocks, as fired. The analysis must include the heating value, and concentrations of 

ash, SVMs, LVMs, mercury, and total chlorine (organic and inorganic). EPA 

recognizes that Veolia may have waste profiles for several hundred hazardous wastes 

that it receives during the course of its business. However, EPA requests that Veolia 

include in the CPT plan the waste profile [with the information listed in 40 C.F.R. 

§ 63.1207(f)(l)(i)(A)] for each waste that Veolia plans to bum during the performance 

test along with the sampling procedure and analysis appropriate for each waste. 

4. Pursuant to 40 C.F.R. § 63.1207(f)(l)(iii), the CPT plan must include a detailed 

description of the HWC. In Table 2-1 of the CPT plan for each Incinerator 2 and 3, 

Veolia indicates an external combustion chamber length for both primary and 

secondary combustion chambers of "1." However, the narrative in Section 2.3.2 

indicates the external length is 17.5 feet. Please explain or correct this inconsistency. 

Additionally, Veolia should include units of measurement for the external length, 

external diameter, and internal diameter in Table 2-1. Veolia should also correct the 

Date of Manufacture from " 1" to the correct date. 

5. Pursuant to 40 C.F.R. § 63.1207(f)(l)(iii)(F), the CPT plans must include a detailed 

engineering description of the automatic waste feed cut off (AWFCO) system. In 

Section 2.8.1 ofthe Veolia's CPT plan, Veolia stated that it tests the AWFCO system 

biweekly. Pursuant to 40 C.F.R. § 63.1206(c)(3)(vii), Veolia must test the AWFCO 

system and associated alarms at least weekly to verify operability, unless it is 

documented in the operating record that weekly inspections will unduly restrict or upset 

operations and that less frequent inspection will be adequate. Veolia made a 

conclusory statement in the test plans that the AWFCO is tested biweekly because 

weekly testing would interfere with operations and potentially increase emissions. EPA 

will consider the biweekly testing if Veolia provides documentation to demonstrate that 

weekly testing will unduly restrict or upset operations. Please submit a copy ofthe 

required operating record documentation and surnmarize that irrformation in Section 

2.8.1 ofthe CPT plan. 

6. Pursuant to 40 C.F.R. § 63.1207(f)(l)(vii), the CPT plan must include a description of, 

and planned operating conditions for, any emission control equipment that will be used. 

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Section 2.5 of the Veolia's plans provides a description of the air pollution control 

equipment. For Incinerators 2 and 3, please amend Section 2.5.1.1 to identify the 

sorbent feedrate. Section 2.5.1.2 notes that the spray dry absorber (SDA) cools the 

combustion gases from between 1600 degrees Fahrenheit (°F) and 2000°F to between 

300°F and 500°F. Please amendSection 2.5.1.2 to include the flow rate of quenching -

water. For Incinerator 4, please amend Section 2.5.1.2 to identify the sorbent feedrate. 

Section 2.5.1.3 notes that the SDA cools the combustion gases from between 600°F and 

800°F to between 300°F and 500°F. Please amend Section 2.5.1.3 to include the flow 

rate of quenching water. 

7. Pursuant to 40 C.F.R. § 63.1207(f)(l )(viii), the CPT plan must provide procedures for 

rapidly stopping the hazardous waste feed and controlling emissions in the event of an 

equipment malfunction. In Sections 2.3.6 and 2.4 of Veolia's CPT plan, Veolia 

specifies how it plans to rapidly stop the feed; however, Veolia does not specify how it 

plans to control emissions. Please modify the CPT plan to specify how Veolia plans to 

control emissions in the event of an equipment malfunction during the CPT. 

8. Pursuant to 40 C.F.R. § 63.1207(f)(l)(xii), the CPT plan must include documentation 

justifying the duration of system conditioning required to ensure the combustor has 

achieved steady-state operations. In Section 4.9, Veolia indicated that Incinerator 4 has 

a solids residence time of 30 minutes and Incinerator 2 has a solids residence time of 60 

minutes. However, the CPT plans provide for a 15-minute conditioning time. Please 

revise the time required to meet steady state operations to reflect the residence time for 

solids. 

9. Pursuant to 40 C.F.R. § 63.1207(f)(l)(xx)(B), the CPT plan for Incinerator 4 must 

provide key parameters that affect carbon adsorption, and the operating limits Veolia 

will establish for those parameters based on the carbon used during the performance 

test. In Table 1-2 for Incinerator 4, Veolia failed to include the carbon feedrate. The 

carbon feedrate OPL is proposed to be the average of three runs. Veolia needs to 

consider the carbon to mercury ratio when evaluating each run. The carbon-to-mercury 

ratio is an important variable in quantifying mercury removal. Therefore, Veolia must 

conduct testing at a sufficient number of different carbon-to-mercury ratios to be able to 

understand the synergistic relationship between carbon and mercury. See Modeling 

Sorbent Injection for Mercury Control in Baghouse Filters: I—Model Development and 

Sensitivity Analysis, Flora, J., et al, Journal of Air and Waste Management Association, 

Volume 53, pp. 489-496, April 2003. 

10. In Section 4.6 of its CPT plans, Metals Extrapolation Method, Veolia indicates that it 

plans to extrapolate to higher feedrate limits than what is actually fed during the CPT. 

Consistent with current EPA guidance and the criteria in 40 C.F.R. §§ 63.1209(l)(l)(v) 

and 63.1209(n)(2)(vii), EPA cannot approve Veolia's proposed extrapolation 

methodology until EPA has reviewed and considered whether the performance test 

metal feedrates are appropriate, based on historical metal feedrate data, and whether the 

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extrapolated feedrates requested are warranted. Pursuant to 40 C.F.R. § 

63.1207(f)(l)(x), because Veolia is requesting to extrapolate metal feedrate limits from 

the performance test levels under 40 C.F.R. § 63.1209(l)(l)(v) and (n)(2)(vii)2, the test 

plans must include: 

(a) A description of the extrapolation methodology and rationale for how the 

approach ensures compliance with the emission standards. Section 4.6 ofthe 

CPT Plans, states, "This is appropriate since it is generally agreed that [system 

removal efficiencies] SREs at higher feedrates would be at least as good as 

those observed at the lower level." However, Veolia has not provided data to 

support this statement. Please amend Section 4.6 ofthe CPT plans to include a 

more robust explanation of how the extrapolated feedrate limits will adequately 

ensure compliance with the emission standards, including documentation of 

observed SREs at the requested extrapolated feedrates; 

(b) Documentation ofthe historical range of normal (i.e., other than during 

compliance testing) metals feedrates for each feedstream. EPA will not 

entertain approval of an extrapolation methodology that requests feedrate limits 

that are significantly higher than the facility's historical range of feedrates. To 

consider a request for an extrapolated feedrate limit, it must be limited to levels 

within the range of the highest historical feedrates for the source;3 

(c) Documentation that the level of spiking recommended during the perfonnance 

test will mask sampling and analysis imprecision and inaccuracy to the extent 

that the extrapolated feedrate limits adequately assure compliance with the 

emission standards. Note that the intended purpose of metal spiking when 

Veolia is proposing to calculate feedrate limits for each metal category by dividing the maximum emission rate 

determined using 75% of the emission standard for that category by 1 minus the system removal efficiency (as a 

percentage) for the spiked compound representing that metal category, and to limit the maximum feedrate for any 

one metal category to three times the spiked feedrate during the testing. See Section 4.6 ofthe CPT plans. 

2

 40 C.F.R. § 63.1209(l)(l)(v) states: 

In lieu of establishing mercury feedrate limits as specified in paragraphs (l)(l)(i) through (iv) of [Section 

63.1209], you may request as part ofthe performance test plan under §§ 63.7(b) and (c) and §§ 63.1207 (e) 

and (f) to use the mercury feedrates and associated emission rates during the comprehensive performance 

test to extrapolate to higher allowable feedrate limits and emission rates. The extrapolation methodology 

will be reviewed and approved, as warranted, by the Administrator. The review will consider in particular 

whether: 

(A) Performance test metal feedrates are appropriate (i.e., whether feedrates are at least at normal levels; 

depending on the heterogeneity ofthe waste, whether some level of spiking would be appropriate; and 

whether the physical form and species of spiked material is appropriate); and 

(B) Whether the extrapolated feedrates you request are warranted considering historical metal feedrate 

data. 

40 C.F.R. § 63.1209(n)(2)(vii) provides the requirements for requesting approval to extrapolate to higher allowable 

feedrate limits and emission rates for SVMs and LVMs. 

3

 See 62 Fed. Reg. 24211, 24238, Fn 51, and 64 Fed. Reg. 52946-529447. 

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conducting CPTs is to enable a facility to verify compliance with HWC MACT 

limits under worst-case conditions. Therefore, if Veolia spikes metals when 

conducting CPTs, as proposed in the CPT plan, EPA will generally use the 

metal spike rates and the native mercury, SV M and/or LV M content of the 

waste to set the feedrate limit with little or no extrapolation, provided the 

corresponding stack emissions assure compliance with all MACT limits with 

an ample margin of safely; and 

(d) For Incinerator 4, documentation of the activated carbon injection rate that is 

required to maintain the calculated mercury system removal efficiency at the 

extrapolated mercury feedrate. EPA will not approve a mercury extrapolation 

methodology for Incinerator 4 that does not document the carbon injection rate 

required to achieve and maintain the projected mercury removal efficiency at 

the proposed extrapolated mercury feedrate. 

11. Pursuant to 40 C.F.R. §§ 63.7(e)(1) and 63.1207(g), Veolia must conduct performance 

testing under operating conditions representative of the extreme range of normal 

conditions.4 In order to conduct performance tests under operating conditions that 

represent the extreme range of normal conditions, Veolia must feed each metal group 

(i.e., mercury, LVM , and SVM) at no less than the highest 12-hour rolling average 

during the previous 5 years. Please amend the CPT Plan to include the 12-hour rolling 

average data for mercury, LVM , and SV M for the previous 5 years. Veolia must 

amend the proposed feedrate ranges to ensure the proposed feedrates during the CPT 

capture the extreme range of normal conditions. 

12. Pursuant to 40 C.F.R. § 63.1209(n)(4), Veolia must establish a SVM/LV M maximum, 

total chlorine, and chloride feedrate OPL. Thus, Veolia must feed cMorine at its normal 

or higher 12-hour rolling average feedrate. (On September 30, 1999, EPA provided the 

rationale for normal or higher chlorine feedrates during the SV M and LV M tests. See 

64 Fed. Reg. 52946.) Veolia included an expected feedrate for chlorine during the test 

in the CPT plan but did not provide documentation to demonstrate that those levels are 

at its normal or higher 12-hour rolling average feedrates. Please amend the CPT plans 

to include such documentation. 

13. Pursuant to 40 C.F.R. § 63.1207(g)(l)(i)(B), the ash feedrate during the SV M and LV M 

performance test must be normal or higher. Please amend the CPT plans to include the 

highest 12-hour rolling average ash feedrate during the previous 5 years and the 

planned ash feedrate for the SV M and LV M performance test. 

14. Pursuant to 40 C.F.R. § 63.1208(b)(8), Veolia must use reliable analytical methods to 

determine feedstream concentration of metals, chlorine, and Other constituents. It is 

Veolia's responsibility to ensure that the sampling and analysis procedures are 

unbiased, precise, and that the results are representative ofthe feedstreams. Please 

4

 64 Fed. Reg. 52922 clarifies that "sources will operate under "worst-case" conditions during the comprehensive 

performance tests..." 

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amend the CPT plan and Quality Assurance Project Plan (QAPP) to include the 

following information: 

CPT Plan Analytical Method Comments: 

(A) In Section 2.2.1.2, Veolia references its Resource Conservation and Recovery Act 

(RCRA) Waste Analysis Plan (WAP) and CA A Feedstream Analysis Plan (FAP). 

For the purpose of the upcoming CPT, Veolia must follow the requirements in an 

EPA-approved CPT plan to the extent that they differ from the WAP or FAP. 

Furthermore, this letter and any potential subsequent approval of Veolia's CPT 

plan should not be misconstrued as approval of Veolia's current WAP and/or 

FAP. 

(B) In Section 4.5, Veolia must include detailed descriptions of spike preparation 

procedures including manufacturer certificates of purity, scale calibration 

documentation, and detailed lab methodology demonstrating good laboratory 

practices for preparing the spikes. Provided that these procedures are appropriate 

and carried out with good practices, the best estimate of spike feedrate will be 

based on the concentrations mathematically calculated from a mass balance of 

spike preparation. Laboratory analysis of spike grab samples can be used to 

confirm the spike concentration by showing a comparable concentration; 

however, the spike mass balance will yield the best estimate of spike 

concentration. Additionally, please replace the word "verified" with "confirmed." 

E PA also requests that Veolia notify us, at least four weeks in advance, of when 

the spikes will be prepared, to allow EPA to witness the preparation, if we deem it 

necessary. 

(C) In Section 4.5.4, please provide the standard operating procedure (SOP) for 

producing the mercury spike solution and vials. 

(D) In Section 5.1, EPA requests that Veolia plan for the preparation of duplicate 

samples in the event that EPA or Illinois Environmental Protection Agency 

requests split samples for confirmatory analysis. 

(E) In Section 5.1.1, Veolia must state who will be collecting and compositing waste 

samples. Additionally, the spike solution samples collected need to be analyzed 

and not archived. The narrative in this section indicates there will be two 

chromium spike samples collected per run and Table 5-1 indicates three. Please 

rectify this discrepancy. 

(F) In Table 5-2, please explain why Veolia believes only three grab samples are 

adequate for characterizing solid-matrix waste streams. 

(G) In Section 5.2, Veolia must clearly state that results are to be provided on an as 

received or wet-weight basis. Veolia must not allow pre-dried samples to be 

analyzed for volatile constituents, such as mercury. 

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(H) In Section 5.4, Veolia references a very outdated EPA document. Please use and 

reference the EPA Requirements for Quality Assurance Project Plans (OA/R-5), 

which EPA has attached. 

(I) In Section 5.4.2, please indicate all the laboratories and sub-laboratories Veolia 

plans to use. Veolia shall provide all internal and contracted laboratory SOPs 

with the test plan. 

QAPP Comments: 

Veolia should follow the guidance at the EPA Requirements for Quality Assurance Project Plans 

(OA/R-5) or the QAPP development. Specifically, Veolia must should include and/or correct the 

following in the QAPP: 

1. In Section 1.0, Veolia must include the missing required elements of a QAPP, such as 

distribution list, problem definition, and data quality objectives. 

2. In Section 2.0, Veolia must indicate who will perform data validation. 

3. In Section 3.0, on page 3 of 3, Veolia must state all the quality objectives for all 

sampling and analysis. 

4. In Section 4.4, Veolia must submit with the CPT plans the profile of each waste it plans 

to burn during the CPT. 

5. In Section 4.5, Veolia must state the SOP and quality assurance objectives for the waste 

feed spiking. The spike samples should be labeled as confirmed, not verified. 

6. In Section 4.7, Veolia must correct the conditioning times to account for solidsresidence time. 

7. In Section 6.0, Veolia must include a discussion of compositing and sample splitting 

procedures. For example, will samples be composited in a safe manner, such as in a 

laboratory hood? 

8. In Section 6.4, Veolia must provide names for all sub-contract laboratories and identify 

their respective analyses. 

9. In Section 8.0, Veolia must provide all laboratory specific SOPs with the QAPP. 

10. In Section 8.5, Veolia must state which moisture analysis method will be used by what 

lab. Veolia should specify that results will be presented on an as received or wet weight 

basis and that samples to be analyzed for volatile components, such as mercury, will 

not be dried before extraction. 

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11. In Section 9.1.2, Veolia must include a discussion or reference to compositing and 

sample splitting procedures. 

12. In Section 9.2.6, Veolia must provide the procedure for spike preparation. 

13. In Section 10.1.2, Veolia must account for the weight of charge boxes as fed. The 

boxes contribute to the weight of material fed to the incinerator, but are not expected to 

include the same amount of MACT metals as in the waste. The concentrations of 

MACT metals within the waste should be applied to the weight of the waste only in the 

mass balance, not the combined weight of the charge box and waste. 

14. In Section 10.2, Veolia must include who will independently validate the data and how 

it will be validated. Using the laboratory validation is not acceptable. 

15. In Section 11.0, Veolia must include who will perform the quality control analysis. 

Veolia should note that in Table 2-3 ofthe CPT plan, Veolia incorrectly identifies the mercury 

OPLs. The table must include the corrected mercury limits based on the spike preparation/mass 

balance for calculating actual feedrates from the 2008 test burns as follows: 

• The Incinerator 2 mercury feedrate adjusted for spike mass balance is 0.00165 lbs/hr. 

• The Incinerator 3 mercury feedrate adjusted for spike mass balance is 0.0018 lbs/hr. 

» The Incinerator 4 mercury feedrate is 0.0214 lbs/hr. 

EPA's comments in this letter are solely for the purpose of conducting a CPT consistent with the 

H WC MACT. If Veolia intends to rely on the performance test to establish a mercury system 

removal efficiency for Veolia's RCRA permit, Veolia should consult with the appropriate RCRA 

permitting authority before finalizing its CPT plan. 

E P A would also like to clarify that the Agency's approval of a CPT plan or lack of comment on 

ancillary references in a CPT plan, such as Veolia's Feedrate Analysis Plan, should not be 

deemed to be approval of such ancillary references. 

Veolia is required to conduct a CPT pursuant to the HWC MACT, within 61 months of the 

August 5, 2008 test Veolia used for data-in lieu of its last CPT. On November 13, 2012, Veolia 

requested an extension under 40 C.F.R. § 63.1207(i). EPA sent a letter on December 13, 2012 

outlining the deficiencies in the extension request. Since EPA did not grant Veolia's request for 

an extension, Veolia must commence its next CPT by September 5, 2013. 

8 
If you have any questions regarding this response, please contact Sarah Marshall, at (312) 886-

6797, Shannon Downey at (312) 353-2151, or David Ogulei at (312) 353-0987, of my staff. 

Sincerely, 

George T-^Gz^rnia 

Director 

Air and Radiation Division 

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