ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS, LLC NOVEMBER 1997

VEOLIA WAP Revision 3 10/30/2007 **WA STE**  **AN AL** **YSIS PLA N** 

**FOR VEOLIA**  **ES TECHNICAL SOLUTIONS, L.L.C.**ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS, LLC NOVEMBER 1997

1 VEOLIA WAP Revision 3 10/30/2007 **WA STE**  **AN AL** **YSIS PLA N**  **OUTLINE PA** **GE 1.0**  **INTRODUCTION 3**  **2.0 SA** **MPLING METHODOLOGY 4**  2.1 Materials 5 2.2 Types of Containment 5 2.2.1 Containers and Tanks 6 **3.0 AN**  **AL Y** **TICA L RA**  **TIONA LE**  **8** 3.1 Mandatory Analyses 8 3.2 Non
- hazardous W aste Analyses 10 3.3 Supplemental Analyses 10 **4.0 PROFILING PROCEDURES**  **14** 4.1 Procedural Requirements 14 4.1.1 Information Provided by Generator 14 4.1.2 Waste Management Decision 16 4 .1.3 Waste Re
-evaluation 16 4.1.4 Exceptions to the Foregoing Requirements 16 4.1.5 Standard Profiles 18 4.2 Decision Evaluation Logic for Profiling Procedures 19 **5.0 INCOMING W** **AS TE SHIPMENT PROCEDURES**  **23** 5.1 Receiving Procedures 24 5.1.1 Exceptio ns to Incoming Waste Analysis Procedures 25 5.2 Incoming W aste Shipment Decision Evaluation Logic 27 5.2.1 Waste Identification 27 5.2.2 The Need For Additional Analysis 28 5.2.3 An Evaluation of Wh ether a W aste is Found to be in Conformance or N on -conformance 28 5.2.4 An Evaluation of Wh ether W astes Found to be in Non
-conformance can be Accepted or will be Rejected 28ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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2 VEOLIA WAP Revision 3 10/30/2007 **6.0 PROCESS OPERA TIONS PROCEDURES**  **31** 6.1 Storage 31 6.1.1 Waste in Containers 31 6.1.2 Waste in Tanks 31 6.1.3 B ulk Solids Storage 33 6.2 Decanting 33 6.3 Incineration 33 6.3.1 Pre
-treatment Analyses 33 6.3.2 Treatment Residue Evaluation 34 **7.0 QUA** **LITY CONTROL POLICY 35**  **AT TA** **CHMENTS**
APPENDIX WAP
-A: ANALYTICAL PROCEDURES APPENDIX WAP
- B: ASH AND DRY SCRUBBER SOLIDS SAMPLING PROTOCOL APPENDIX WAP
-C: WASTE ACCEPTABILITY CRITERIA APPENDIX WAP
- D: DETERMINATION OF INCOMING WASTE CONFORMANCE/NON
-CONFORMANCE APPENDIX WAP
- E: CONTAINERIZED WASTE: SPECIAL SAMPLING PROCEDURE APPENDIX WAP
- F: BIBLI OGRAPHY OF STANDARD CHEMICAL REFERENCE MATERIALS APPENDIX WAP
- G: HM
- 181 COMPATIBILITY CLASSES PCB SCREENING POLICY DIOXIN ANALYSIS POLICYILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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3 VEOLIA WAP Revision 3 10/30/2007 **WA STE**  **AN AL** **YSIS PLA N**  **In accordance**  **with the**  **regulator y**  **requirements set**  **forth in**  **40 CFR**  **264.13 and**  **35 IA** **C 724.11**  **3, Veolia**  **ES Technical**  **Solutions, LLC**  **has dev** **eloped this**  **Waste Anal**  **ysis Plan**  **as an**  **integral part**  **of the**  **RCRA P**  **art B**  **Permit Ap**  **plication for**  **its facility located in Sauget (St. Clair County), Illinois. References to the company will**  **further be**  **know n**  **as Veo**  **lia. T**  **he procedures**  **set forth**  **in this**  **plan ensure**  **that this**  **facility will**  **be in**  **compliance with**  **all requirements**  **of 40**  **CFR 264.13**  **and 35**  **IA C**  **724.113. A**

**copy of this plan w**  **ill be available at the facility at all times.**  **1.0 INTRODUCTION**  The purpose of this Waste Analysis Plan (WAP) is to describe and document the necessary sampling methodologies, analytical techniques and overall procedures used to determine the acceptability and safe management of all wastes which enter this facility for treatment or storage. T hese procedures shall apply to all hazardous and non - hazardous wastes (hereafter referred to as "waste"), and fuels (natural gas will be excluded but specification sheets will be obtained form the supplier) received by the facility, except samples as identified and defined in 40 CFR 261.4(d), (e), and (f). S pecifically, the plan delineates the following:

-- Analytical Parameters, Rationale and Techniques to identify wastes or determine information so that treatment and storage techniques can b e utilized.

-- Sampling Methodology to ensure that adequate and representative samples are taken. Profiling Procedures to determine the acceptability of a particular waste s stream pursuant to facility permit conditions and operating capabilities prior to acceptance of the waste at the facility.

-- Incoming W aste Shipment Procedures to identify that the delivered waste conforms to the accompanying manifest, profile documents, and the conditions of the facility permit.

-- Process Operation s Procedures to maintain safe and appropriate methods of storage, treatment, disposal or movement of wastes within the facility.

-- Residue(s) resulting from on
-site treatment of land disposal restricted wastes will be evaluated, as needed, agai nst the appropriate treatment standard or prohibition.

-- Quality Control Policy the facility laboratory follows to achieve high quality analytical results. The forms shown within this WAP are typical forms currently used by the existing facility. These forms may require updating to equivalent or alternate forms based uponILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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4 VEOLIA WAP Revision 3 10/30/2007 changes in regulations, customer needs, facility operations, or company policies. Veolia will provide notification to the IEPA
- DLPC Permit Section as required by 35 IAC 703.280

. For purposes of implementation and performance of this WAP, “the Laboratory" means the facility laboratory, any Veolia laboratory, any Veolia subsidiary laboratory, or any Veolia designated contract laboratory. The Laboratory, Technical, Operations, En vironmental, and General Managers or their designees hereinafter are collectively referred to as "Facility Management", or individually referred to as the Laboratory, Technical, Operations, Environmental, or General Manager. All wastes handled by this facility will be subjected to these procedures. T his is to help ensure that this facility will be in compliance with applicable permits and regulations. The company strives to maintain, at all times, complete compliance with the hazardous waste regulations. Because new requirements, such as those promulgated under the land disposal restrictions, often become effective prior to the time WAP revisions can be formally made and approved by all appropriate agencies, it is impossible to have in place an approved WAP meeting all the conditions of immediately effective regulatory requirements. In light of these facts, the facility will follow the new requirements such as testing and frequency prior to receipt and/or processing of the regulated waste as specified by the new Regulations. T he facility may a lso periodically revise the protocol to reflect scientific advances or additional regulatory requirements. If WAP revisions are necessary because of a new regulatory rule, they will be submitted within 60 days afte r the effective date of the rule. **2.0 SA** **MPLING METHODOLOGY** Sampling is performed at the facility to identify waste shipments and by the waste generator to make the initial waste determination at their location. S pecific sampling procedures are dependent on both the nature of the material and the type of containment. A full
-depth representative sample will be obtained from each container and tank truck unless the physical properties (i.e., heterogeneous debris, extremely hard material, or high shear force) preclude obtaining a full
-depth representative sample. Exceptions to obtaining full
-depth samples are noted in Section 2.1 and do not apply to frozen or chilled material. This section presents sampling methodologies to be utilized on -site by personnel in accordance with 40 CFR 264.13(c)(2) and/or 35 IAC 724.113(c)(2). Waste generators are referred to 40 CFR 261, Appendix I and/or Appendix A of 35 IAC 721 for sampling procedures. In the case where the generator submits a sample for initial profile app roval, TW I requires the generator to certify that the sample submitted is representative. The sampling equipment and procedures described in this WAP represent the facility's recommended sampling protocol for general types of waste material and containmen t. All methodologies will be updated and revised as the references areILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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5 VEOLIA WAP Revision 3 10/30/2007 updated and revised. **2.1 Materials**  At a minimum, the methodologies utilized for specific materials correspond to those referenced in 40 CFR 261, Appendix I and/or 35 IAC 721, Append ix A. T he sampling methods and the equipment utilized for these and any different materials are presented in Table 2
- 1. T his table is a simplified summary of data excerpted from 40 CFR 261, Appendix I and/or 35 IAC 721, Appendix A. Care must be taken wh en collecting samples to ensure that excessive loss of volatile organic compounds does not occur during sample handling and storage. S ample containers must not be left opened except when preparing for the addition or removal of the sample, and sample jars must be filled as completely as practical. Certain waste materials will require deviations from these protocols. W hen deviations are necessary to sample materials which cannot be sampled using the recommended protocol (for example, debris, extremely ha rd materials, or other high shear force materials), the facility will obtain a representative sample, based on the circumstances preventing a vertical section, knowledge of the waste, and the container size and shape. For example, debris and like material will be sampled with scissors, tongs, hammer and/or chisel. Adhesives or other highly elastic substances will be sampled with a scoop or shovel and scissors or tongs. Resins and other extremely hard materials will be sampled with a hammer and a chisel. (See Appendix WAP
- E) **2.2 Ty** **pe of Containment** In addition to American Society for Testing Materials (ASTM) and other EPA
-approved sampling procedures, Veolia has instituted specific methodologies for ensuring that samples taken from various types of contai ners are representative. T he type of container may be transportable such as drums, portable transport units (e.g. small tanks, roll off boxes), and tanker trucks; or stationary (e.g., tanks) and in
- process sources. The sampling devices are selected, depe nding on the size and type of containment and on the specific material involved. Because there is a much greater tendency for heterogeneity in a vertical plane rather than a horizontal, sampling will be performed to address this concern (e.g., full
depth vertical samples will be taken when possible). Wh en samples are collected which consist of multiple phases, analysis will be conducted on the sample as a whole, except for PCBs, where only the suspect layer is analyzed. I n addition, access to a container (i.e., drum bungs, tank truck domes, and large tanks with sampling ports) will influence the location from which samples can be taken.ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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6 VEOLIA WAP Revision 3 10/30/2007 2.2.1 Containers and Tanks Sampling of small containers (e.g., drums, cartons, and other small units) varies with the nature of the waste material. For flowable materials, the sampling device to be used is either a Coliwasa unit or tube sampler to draw a full vertical axis sample of the flowable material (or other appropriate device as listed in Table 2
- 1). For nonfl owable wastes, a tube sampler or a thief is used to obtain a sample (or other appropriate device as listed in Table 2
- 1). Large containers and tanks for flowable materials and bulk containers for solid materials may be either stationary or mobile. L iquid s are sampled with a Coliwasa or tube sampler to obtain a vertical section (or other appropriate device as listed in Table 2
- 1). L ight, dry powders and granules are sampled with a tube sampler to obtain a vertical core (or other appropriate device as listed in Table 2
- 1). H eavier solids are sampled by thief or shovel, or by coring with a tube sampler (or other appropriate device as listed in Table 2
- 1). Stationary tanks for blending of liquids for feeding the incinerator are sampled with a bacon bomb (or other appropriate device as listed in Table 2
- 1). I n addition, tanks may be sampled from tank sampling ports or taps through tank inlets or outlets.ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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7 VEOLIA WAP Revision 3 10/30/2007 **TABLE 2 -**  **1 SAMPLING METHODS AND EQUIPMENT** 

_____________________________________________________________ ____________ MATERIAL METHOD EQUIPMENT c

_________________________________________________________________________ Extremely viscous liquid ASTM D 140

-70 a or Tube samplerd, thief, ASTM E 300 a or Coliwasa Crushed or powdered ASTM D 346

-75 a or Tube samplerd, thief, ASTM E 300 a scoop, or shovel Soil ASTM D 420

-69 a or Tube samplerd, thief, ASTM E 300 a auger, scoop, or shovel Soil

-like material ASTM D 1452

-65 a or Tube samplerd, thief, ASTM E 300 a auger, scoop, or shovel Fly ash

-like material ASTM D 2234

-76 a or Tube samplerd, thief, ASTM E 300 a auger, scoop, or shovel Containerized liquids SW

- 846b or Coliwasa/tube ASTM E 300 a samplerd, weighted bottle, bom b, or tank sampling ports

__________

_______________________________________________________________
a

-- American Society for Testing Materials , 1982. Annual Book of ASTM Standards, Philadelphia, PA, or mo st recent edition. b

-- "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods" , SW

- 846, Third Edition, Septem ber 1986 as amended by Update I (July 1992), U.S. Environmental Protection Agency, Office of S olid Waste (NTIS, 5285 Port Royal Road, Springfield, VA 22161) or more recent edition or revision (GPO, Supt. of Documents, Washington, DC 20402). c

-- The specific equipment is dependent on the type of container. S ee SW

- 846 for specific exam ples. S ee also Section 2.2. d

-- Personal Protection and Safety Training Manual (Cincinnati, Ohio: U .S. Environmental Protection Agency, National Training and Operational Technology Center, 1981) pp. 3

- 1 and 3

-4, or current revision.ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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8 VEOLIA WAP Revision 3 10/30/2007 **3.0 AN**  **AL YTICA** **L RA TIONA** **LE** In accordance with 40 CFR 264.13(b)(5) and/or 35 IAC 724.113(b)(5), a pre-existing waste characterization is supplied to Veolia by the wa ste generator on the Waste Profile Sheet (W PS, Figure 4
- 1). T he generator supplies Veolia with all the information required to characterize, treat, store or dispose of his waste, as defined in 40 CFR 264.13(a)(1) and/or 35 IAC 724.113(a)(1). [ref: 4 0 CFR 264.13(a)(2) comment and/or 35 IAC 724.113(a)(2) Board Note]. See Section 4.1 for a discussion regarding the information and data to be supplied by the generator. T he analyses if necessary, are provided by the generator or Veolia laboratory to evaluate the pre-existing waste characterizations and to comply with facility acceptance criteria.

Analytical methods are classified as Mandatory Analyses, Blend Analyses, and Supplemental Analyses. T his arrangement allows a tiered approach to waste ide ntification, enabling TW I to structure the analyses to adequately identify the waste or to define operational parameters for various treatment processes.

At a minimum, all incoming wastes are subjected to the Mandatory Analyses as a first step in the ana lytical scheme (except as noted in Section 4.1.4). Supplemental Analyses are performed as specified in Section 3.3. T he Blend Analyses are used to determine the liquid blend characteristics in order to maintain a steady state (normal) operation of the in cinerator (see Section 6.3). Facility Management may perform additional analyses to augment the mandatory screening or to provide operational control as prescribed in Section 3.3, Supplemental Analyses. T he parameters which constitute these categories are described below. T he methods to be utilized in determining these parameters are identified in Appendix WAP
-A (as required by 40 CFR 264.13(c)(1) and/or 35 IAC 724.113(c)(1)). F acility Management may waive specific Mandatory or Supplemental Analyses if performing the analysis presents a safety hazard in the laboratory. A summary of the analytical parameters within each category and their usage is provided herein. Analyses are not repeated for sequential activities or movement of the same waste within the facility unless required by changes in the waste's character. S ee Section 6.0 for a complete description of parameters performed in conjunction with process operations. T he results of all tests and inspections described below will be maintained at th e facility as part of its operating record for a minimum of three years after the testing has been performed. **3.1 Mandator** **y An**  **aly ses** 

Mandatory Analyses are basic fingerprinting procedures (key parameters) wh ich are used to identify a waste and to ensure that the appropriate waste management technique can be utilized. I n addition, they aid in liquid blending decisions and to determine the proper solid waste feed sequence prior to incineration. M andatory Analyses:ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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9 VEOLIA WAP Revision 3 10/30/2007 -- Provide the information concerning the waste which is pertinent to the safe storage, processing and incineration of the waste;

-- Provide Facility Management with data which can be used to evaluate the consistency of information provided by the generator. Incoming Mandatory Analysis are performed on the incoming waste shipment samples in order to make the final decision of whether or not the facility can manage a particular waste stream shipment (except as noted in Section 4.1.4) and determine if the waste shipment conforms to the identity of the waste as identified on the waste shipment manifest, and to the profile information. Wh en necessary for profile purposes, select Mandatory Analyses may also be performed on a generator supplied sample if the generator suppli ed information is not sufficient (See Section 4.1.1). I f an incoming waste conforms to the information provided in the profile, then the information gathered can be used to safely manage the waste.

In accordance with 40 CFR 264.13(c)(1) and/or 35 IAC 724.113(c)(1), the parameters and associated rationale for the Mandatory Analyses are as follows: 1. Physical Description (appearance) is used to determine the general physical properties of the waste (color, physical state, layering, turbidity, viscosity). This facilitates visual comparison of the sampled waste with prior waste descriptions or samples. 2. Heating Value (BTU) is used to establish the proper blend characteristics, evaluate its suitability for incineration and develop appropriate packaging requirements. There are no minimum or maximum acceptance limits for incoming waste shipments based on heating value. Heating value of a particular blend is controlled by the incinerator feed blend (see Section 6.3). Th is testing does not apply to liquid decant drums which will be blended prior to incineration. 3. Chlorine Content (Cl) is used to establish the proper blend characteristics, appropriate container packaging requirements and/or evaluate potential impacts on the incinerator and/or pollution control equipment. This testing does not apply to liquid decant drums which will be blended prior to incineration. 4. Radioactivity Screening is performed to detect radioactive materials a bove background levels (greater than 0.5 millirads per hour) and to ensure that mixed waste, as defined in the Veolia Part B RCRA Permit is not accepted by the facility.ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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10 VEOLIA WAP Revision 3 10/30/2007 5. Flammability Potential Screening is used to indicate the fire
- producin g potential of the waste. This testing can be applied to all wastes, liquids, semi
-solids or solids. All incoming liquid material indicating a positive flammability potential will be stored as Class I flammable liquids, unless closed cup flash point is performed showing a flash point of greater than 100 o F. 6. Liquid W aste Compatibility (Water Mix) is used to determine whether the waste has a potential to vigorously react when mixed with water, to form gases or other products, o r whether it generates significant heat. This testing does not apply to wastes that are already in contact with excess water. 7. Cyanide Screening indicates whether the waste has the potential to produce hydrogen cyanide upon acidification be low pH 2.0. It is not required if the pH of the waste is less than or equal to 2.0. 8. Oxidizer Screening is used to indicate the absence or presence of strong oxidizing material. 9. pH Screening is undertaken to indicate the pH and, in genera l, the corrosive nature of the waste. Full range paper is used for the initial screening of wastes. W aste accepted by the facility will, generally, be in the range of 2.0 to 12.5 pH units. Liquid waste outside of this range may be analyzed for alkalinity/acidity. If the material exhibits corrosive properties as identified in technical literature vs. tank farm material of construction, corrosion testing may be performed to allow for storage, or it will be accepted as specialty feed material and injected directly into the incinerator without blending. 10. Sulfide Screening indicates whether the waste has the potential to produce hydrogen sulfide upon acidification below pH 2.0. It is not required if the pH of the waste is less than or equal to 2.0. **3.2 Non**  **- hazardous Waste A** **nal yses** 

All protocols defined in this plan for the acceptability and safe management of hazardous waste apply to all non - hazardous waste which are candidates for acceptance and management at the facility. **3.3 Supplemental**  **An aly** **ses**

Supplemental Analyses are performed to further identify wastes and will be performed when needed as directed by Facility Management or as specified in the rationale.ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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11 VEOLIA WAP Revision 3 10/30/2007 Sup plemental Analyses are conducted wh en the Mandatory Analyses indicate that further information is needed to confirm the waste or to properly store and/or process the waste. T he analyses are performed as directed by Facility Management. The results of these analyses provide Facility Management with another level of confidence concerning the proper means of storage and/or processing.

Some of these additional analyses utilize unique procedures and protocols formulated by Veolia, wh ich have been found to be preferable for waste identification. These analyses will meet Veolia company performance standards. Others are standard analytical techniques recognized by the U.S. EPA and ASTM. T he parameters which constitute the Supplemental Analyses are identified b elow, the methods to be utilized in determining these parameters are in Appendix WAP
-A. 1. Liquid Waste Compatibility (Tanks) will be assessed by performing a liquid waste compatibility on the liquid waste received for bulk storage with a composite of the tanks and storage container within the containment system to which the new waste will be added. Containment area master composite will be made up once per week. T he incoming material will be checked against this master composite. 2. Gas Chromatography Scan is used to separate and identify certain organic compounds. 3. Metals (e.g., As, Be, Cd, Cr, K, Na, Pb, Hg) identifies metal concentrations in wastes to determine feedrates for compliance with Subpart EEE or for process control. 4. C losed Cup Flash Point identifies ignitable liquid wastes for storage purposes. This test may be performed to resolve non
-conformance issues when; a) An incoming waste indicates a positive flammability potential; and b) Profile information indicates that the material should not exhibit a flammability potential; and c) The discrepancy cannot be resolved through discussions with the generator. 5. Acidity/Alkalinity may be performed on liquid inorganic waste which exhibits a pH greater that 12.5 or less than 2.0 to evaluate the processability of these wastes. 6. Apparent Viscosity is an indicator of one of the feed characteristics to the incinerator. It is determined during profiling on liquids when the Physical Description indicates the waste is viscous or when analytical data is not provided by the generator on the W PS. 7. Confinement Test is used to measure the magnitude and rate of heat generation from a material subjected to a programmed temperature increase under confined conditions. This test will be used as an indicatorILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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12 VEOLIA WAP Revision 3 10/30/2007 of the waste's explosion potential. For materials for which the Facility Management lacks explosivity information, either as provided by the generator, through the fa cility's previous experiences with the material, or in a review of standard reference materials (a bibliography of standard references available to the site is included as Appendix WAP
- F) and Facility Management's evaluation of the chemical structure of the compound fails to preclude an explosion potential for the material, the suspect material will be subjected to a Confinement Test. 8. Liquid Waste Compatibility (Drums) is used to determine if waste streams can be blended without causin g a release to the environment. This test will be performed on all liquid wastes received for bulk storage, decant to bulk storage, or blending prior to incineration with all tanks within the containment system to which the new waste will be added. 9. PC Bs are run to indicate whether PCBs are present in wastes and to ascertain their concentration. PCB analysis will be provided by the generator or analysis will be performed prior to profile decision approval. Incoming waste shipments will be subjected to PCB testing based on the criteria defined in the Veolia PCB Suspect Analysis Policy. M aterials containing PCBs above 50 ppm will not be accepted. O rganic extractions will not be performed on wastes that present a safety hazard. 10. Chlorophenoxy Herbici des by HPLC is used to determine the presence of dioxin suspect compounds Silvex and 2,4,5
-T (see Appendix WAP
-C) at a level of 0.01% or greater subject to detection level/matrix interference. Suspect waste streams are identified by the Veolia Di oxin Suspect Analysis Policy. 11. Phenol Screening is used to determine the presence of dioxin suspect compounds pentachlorophenol (see Appendix WAP
-C) at levels greater than 0.01% or greater, subject to detection level/matrix interference. S uspect waste streams are identified by the Veolia Dioxin Suspect Analysis Policy. 12. Ash Content is used to determine the percent ash in liquid waste feeds. 13. Fluorine Content is used to determine the percent fluorine in liquid waste feeds. 14. Bromine Content is used to determine the percent bromine in liquid waste feeds. 15. Specific Gravity/Density indicates the density of the waste. This information is used to assure that the specific gravity of bulk liquids is less than the desig n specific gravity for the storage tanks (1.5). Other parameters not listed here may be added as required by changes in regulations, company policy, etc. S ee Figure 3.1 for a summary of analytical requirements.ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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13 VEOLIA WAP Revision 3 10/30/2007 **FIGURE 3 -**  **1 SUMMARY OF ANALYSIS**  **INCOMING PARAMETER**  **PROFILE WASTE**  **Physical Description X**  **pH Screen X**  **X Cyanide Screen (1)**  **X Oxidizer Screen**  **X Radioactivity Screen**  **X X**  **Flammability Potential Screen X**  **X Liquid Waste Co**  **mpatibility (** **Water Mix )**  **(2) X**  **Heat Value (BTU) X(4)**  **Chlorine Content X(4)**  **Ash Content S(5)**  **Specific Gravity S(6)**  **PCBs (3) X**  **S GC Scan (3)**  **S Acidity/Alkalinity**  **S Sulfide Screen (1)**  **X Liquid Waste Co**  **mpatibility S**  **Apparent Viscosity (5) X**  **S Pentachlorophenol Screening**  **S Chlorophenoxy Herbicides HPLC**  **S Mercury**  **X(7) S(7)**  **Fluorine S**  **Bromine S**  **Metals S**  **Confinement Test S** 
**X = Mandat ory Analysis**  **(1) Does not apply to waste with pH <or =2**  **S = Supplemental Analysis (2)**  **Does not apply to waste already in contact with excess water.**  **(3) Performed on suspect waste only, according to**  **PCB Policy. Not performed on waste that present**  **a safety hazard. (4)**  **Not performed on waste to be blended. (5)**  **Liquids only. (6)**  **Bulk liquids only. (7)**  **Mercury analysis will be completed during profiling on suspect waste only.** ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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14 VEOLIA WAP Revision 3 10/30/2007 **4.0 PROFILING PROCEDURES** 

Veolia has developed a series of control procedures to determine the acceptability of specific wastes for management at the facility. T he profiling procedure dictates what information a potential customer must provide to enable Veol ia to carry out its responsibility to obtain information necessary to manage the waste. I n accordance with 40 CFR 264.13(b)(5) and/or 35 Ill. Adm. Code 724.113(b)(5) this facility requires, at a minimum, the generator to supply all the information required by 40 CFR 264.13(a)(1) and/or 35 Ill. Adm. Code 724.113(a)(1) (see Section 4.1 for a discussion regarding the information and data to be supplied by the generator) necessary to characterize, treat, store or dispose of each waste stream.

Profiling is th e mechanism for deciding to reject or accept a particular type of waste prior to its acceptance at the facility based on the conditions necessary to maintain incinerator operations at a (normal) steady state, the limitations of existing permits, and its co mpatibility with other wa stes being treated, stored or disposed at the facility. Prior to accepting a waste at the Veolia facility for treatment, storage or disposal, a determination has previously been made by the generator (and reviewed by Veolia) that the waste is either:

o a characteristic waste as defined in subpart C of 40 CFR 261 and/or subpart C, 35 Ill. Adm. Code 721, o a listed hazardous waste as defined in subpart D of 40 CFR 261 and/or subpart B, 35 Ill. Adm. Code 721, o a solid waste which is not a hazardous waste as defined in 40 CFR 261.4(b) and/or 35 Ill. Adm. Code 721.104(b). The generator's supplied characterization (Waste Profile Sheet (W PS), Figure 4
- 1 in Section 4.1) provides Veolia with information concerning the distribution of waste components as well as the nature of the waste components. **4.1 Procedural Requirements** 

For each new waste stream that is a candidate for delivery to the facility, except for those special materials noted below in Section 4.1.4, the following procedures are implemented: 4.1.1 Information Provided by Generator

The generator will provide Veolia with: (1) Chemical and physical data requested on the Waste Profile Sheet (W PS), typical form shown as Figure 4
- 1. This information will be based on the following:ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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15 VEOLIA WAP Revision 3 10/30/2007 o Analytical Data; the generator must provide any available analytical data to support the information provided on the WP S. At a minimum, the generator must provide the following; Flammability Potential (liquids only) PCB (if applicable to PCB Policy and Safety Policy) Apparent Viscosity (liquids only) pH Screen Radioactivity Screen Wh ere the generator does not provide analytical data, for the above items, the data will be developed by Veolia prior to waste profile approval. o For waste code information, existing or published data on the waste or on waste generated from similar processes; o Process and ingredient information. (2) a representative sample; if required (a representative sample may not be required by Veolia if Facility Management determines that the profile documentation supplied by the generator gives sufficient information to maintain compliance with permit and operational constraints and that submittal of a sample would not aid in the disposal decision process. Also see Sections 4.1.4 and 4.1.5). Non
- hazardous waste profiles for which the generator has provided analytical data to support this determinatio n will not require a sample. (3) Certification that the representative sample when required for approval (see above) has been obtained using procedures identified in 40 CFR 261, Appendix I and/or 35 Ill. Adm. Code 721, Appendix A or eq uivalent methods. (4) Land Disposal Restriction (LDR) Notification/Certification I information and/or Data (40 CFR Part 268): (5) Material Safety Data Sheets, for single component materials or commercial products. If an MSDS is not available, a sample must be provided. (6) Wh ile not specifically required, generators are encouraged to provide other supporting documentation, including additional analytical results, product ingredients, etc. which will assist in the approval process. Veolia maintains as part of its profiling information generator
supplied and Veolia developed information. This information may be accessed electronically or via hard copy.ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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16 VEOLIA WAP Revision 3 10/30/2007 4.1.2 Waste Management Decision After evaluating the data supplied by the generator, Facility Management will determine the acceptability of the waste based on: ( 1) permit conditions; (2) the availability of proper waste management techniques and operational conditions necessary to maintain a steady state (normal) operation of the incinerator; and (3) storage and compatibility concerns. S ee Section 4.2 for a detailed discussion of the decision evaluation logic for profiling procedures. 4.1.3 Waste Re
-evaluation In accordance with 40 CFR 264.13 and/or 35 Ill. Adm. Code 724.113, a waste profile re
-evaluation will be conducted when one of the following occurs:

o A generator notifies Veolia that the process generating the waste has changed; o The results of inspection or analysis indicate that the waste received at the facility does not match the identity of the waste designated on the accompanying manifest (or shipping paper) or profile documentation (See Section 5.2.3); or o Every five years. A waste profile re
-evaluation along with a vigilant inco ming load screening program is sufficient to ensure that wastes continue to be properly managed at the facility. For bullet items one and three above, this re-evaluation process consists of a review of the paperwork to ascertain that the analytical d ata is accurate and current and that it is sufficient to properly manage the waste as intended. T he procedure typically involves comparing the current waste profile to the available results of routine inspection, sampling, and analysis obtained upon recei pt of an incoming load of the waste stream. To augment this review, if existing analytical is not sufficient, the generator may be asked to review the current waste profile, to supply a new profile, and/or to submit a sample for analysis, or Veolia may obtain a sample from a shipment of the waste. 4.1.4 Exceptions to the Foregoing Requirements The following waste types will be exempt from the foregoing sampling requirements for preacceptance:

(1) Packaged chemicals and lab packing debris (e.g., glassware, syringes, lab coats, tyveks, gloves, etc.) from laboratories, hospitals, household clean sweeps, manufacturing facilities, etc., including scintillation vials packed in accordance with Small Quantity Chemical Guidelines (SQCG's). For packaged chemicals, the generator will supply a packing list (Inventory) for each container (e.g., drums) specifying type and quantity of chemicals contained within. Technician(s) packaging the waste complete the drum inventory sheets and provide to Veolia for review to ensure compliance withILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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17 VEOLIA WAP Revision 3 10/30/2007 the SQCG’s. This drum inventory sheet must be reviewed and approved for each container by the Facility Management prior to acceptance at the facility. Veolia will open and inspect the contents of randomly selected direct charge containers received from each packing organization to verify that the contents conform to the drum inventory. See Section 5.1.1(1) for a complete description of Incoming Waste Shipment procedures for small quantity chemical drums. O ccasionally, Veolia determines that a particular material is not acceptable and so notifies the customer. These drums will be tracked on -site for the purposes of determining waste storage compatibility by manifest/profile/unique drum identification combination until the material is rejected. (2) Empty containers as defined in 35 IAC 721.107(b), (e.g., empty fiber, steel or plastic drums or bags). These wastes will be visually inspected upon receipt. I n addition to differences in physical appearance, these wastes will be determined to be no nconforming when they contain material that does not meet the RCRA empty definition defined in 35 IAC 721.107(b). (3) Pharmaceutical and commercial products or chemicals: off
specification, outdated. These materials are packaged in consumer qua ntities, unused or banned, in their original packaging or packaged as specified by Veolia. (4) Aerosol cans, Lecture Bottles or Gas Cylinders. (5) Controlled substances regulated by the Federal Government. These are typically generated by pharm aceutical companies, health care companies, state or Federal Agencies. (6) Single source spill material on undefined media where no generator knowledge exists will require Hg analysis. (7) Wastes which are visually identifiable through an inspection process. Examples of these types of wastes are, PPE, batteries, cathode ray tubes, crushed glass, piping, filters and filter cartridges, wire or tubing, paper products, syringes, metal sheeting and parts, explosive components and devises. This list is not meant to be all inclusive. Visually identifiable material will be specified on the W aste Profile Sheet. (8) Prior Agency Approval: Materials which do not fall into one of the other exemption categories, but present impractical sampling or analysis complications. Use of this exemption will be granted on a profile specific basis, with initial review by the IEPA field office (Collinsville). Profile approval will be subject to IEPA
- DLPC Permit Section written (e.g. fax) approval. (9) Explosive, Poison Inhalation Hazard (PIH) and Odiferous materialILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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18 VEOLIA WAP Revision 3 10/30/2007 (e.g.,mercaptan) wh ich present sampling, and analytical safety hazards or community nuisance odor problems, can be exempted by Facility Management without prior Agency approval. T he list is inclusive. The requirement that a generator provide a representative sample is waived for these materials beca use they exhibit unusual or impractical sampling and analytical complications and are of such a nature that their contents are known in sufficient and reliable chemical and physical detail that sampling and analysis is not wa rranted. For these exceptions, the generator will supply Veolia with chemical and physical characteristic information necessary for proper management of the waste and sampling is not required. T he above wastes will be described on a W PS as shown in Figure 4
- 1 and accompanied by suppor ting documentation (e.g., drum inventory, Material Safety Data Sheets (where available), and other data made available by the generator), including information as to whether the waste is subject to the Land Disposal Restrictions of 40 CFR Part 268. 4.1.5 Standard Profiles Standard Profiles may be used for waste streams which are similar in physical and chemical characteristics, generated by similar industries or processes, consistent with the USEPA approach of assigning a listed waste code to similar process wastes. An analytical database will be developed for a specific Standard Profile based on analytical data from waste streams that are representative of wastes from similar industries, processes or historical data. Veolia will review the database a nd determine whether the individual waste streams are sufficiently similar in physical and chemical characteristics to an established Standard Profile. T he analytical database developed as discussed above will replace the requirement for a profiling sampl e (see Section 4.1.1) for each individual waste stream.

Specific candidate waste streams which are identified as conforming to an existing Standard Profile will be managed under the existing disposal decision specific for that Standard Profile. E ach gen erator will submit a separate, unique waste profile sheet for approval. TWI a pproval personnel will review the unique profile and match it to a standard profile and complete a separate decision. T he approval decision will be completed, providing the gene rator’s waste is a subset of the chemical composition of the standard template.

An example of a standard profile would be K040, Wastewater Treatment Sludge from the Production of Phorate. A historical database of preacceptance analytical would be collected for random generators of K040 waste. Since the chemical composition and analytical results of these wastes is ve ry similar, no new i nformation would be gained from additional analysis of a K040 waste. M uch in the same manner as how the EPA developed the Phorate treatment standard for K040 (0.021 mg/l for wastewaters and 4.6ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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19 VEOLIA WAP Revision 3 10/30/2007 mg/l for non -wastewaters) through repeated analytical for LDR constituents, Veolia would develop and standardize an analytical database. Mercury for K040 would not be an issue since repeated analysis by EPA indicated the absence of this metal, hence the absence of a treatment standard for Mercury in K040 waste. W hen a new profile for K040 is submitted for approval, it will be approved under the K040 standard profile based on the p reviously developed knowledge of this waste. **4.2 Decision Evaluation Logic for Profiling Procedures** 

The Facility Management is responsible for the profile evaluation decision (e.g., whether to approve the candidate waste for acceptance). T he data obtained from the WP S (Figure 4
- 1), any analysis performed by the laboratory, and any other information provided by the generator or developed during the assessment of the waste is evaluated by

F acility Management. T he facility General Manager will designate written authority for profile decision approval to qualified individuals based on training, experience, and supervised decision reviews. S ee Figure 4
-2 for required waste management decision information.

Facility Management will apply technical experi ence and judgment to all the available information in order to reach a technical profile approval decision. At a minimum, the following criteria will be assessed:

o Management methods available; o Conditions or limitations of existing permits and regu lations; o Capability to manage the waste in a safe and environmentally sound manner; o WP S description of the process generating the waste; o WP S description of the chemical and physical properties of the waste; o Any additional documentation supplied by the generator, including information that the waste is subject to a Land Disposal Restriction of 40 CFR Part 268; o Results of Mandatory Analyses if applicable (see Section 4.1.1); o Results of Supplemental Analyses, as required. o MSDS recommendations (when available). A summary of particular data which, when observed on the WP S or during the Profiling phase, will subject the candidate waste stream to restrictions, special packaging requirements, or outright rejection from further consideration is provided as Appendix WAP
-C.

A waste stream will be rejected during the profiling phase for the following reasons: o Incomplete or outdated information supplied by the waste

generator which cannot be supplemented by the g enerator.ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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20 VEOLIA WAP Revision 3 10/30/2007 o WP S information is inconsistent and the discrepancy cannot be resolved with the generator. Inconsistent information is that which is mutually exclusive based on scientific facts and principles (for example, W PS indicates that a waste containing 50% acetone is nonflammable). o Sample analyses and W PS information are inconsistent and the discrepancy cannot be resolved with the generator. o The facility is not permitted to treat, store, or dispose of the particular waste in question (for example, the waste is radioactive). o The facility does not have the capacity to treat, store, or dispose of the waste stream in question. o Facility experience with similar materials or standard reference materials (See Appendix WAP
- F) indicates that this material cannot safely be incinerated by limiting size of charges or other processing controls. See Appendix WAP
-C for Waste Acceptability Criteria. o Facility Management is not assured of the ability of the facility to safely treat and store the waste. The profile evaluation is concluded with documentation of the decision regarding the acceptability of the waste and the proposed method of management, including such special packaging requirements as may be requi red of the generator. Handling and analytical requirements will be prepared from information gathered during the profile process (generator name, profile number, results of profile analyses, decisions restrictions, etc.). A

copy (photocopy or electronic) of this information will be made at the time the waste is scheduled to transmit profile and handling information to operations and the laboratory for the Incoming W aste Acceptance process.ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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21 VEOLIA WAP Revision 3 10/30/2007 **FIGURE 4 -**  **1 GENERA** 

**TOR'S W AS**  **TE MA**

**TERI AL** **PROFILE SHEET**ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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22 VEOLIA WAP Revision 3 10/30/2007 **FIGURE 4**  **- 2**  **WA STE MA** **NA GEMENT DECISION** ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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23 VEOLIA WAP Revision 3 10/30/2007 **5.0 INCOMING W** **AS TE SHIPMENT PROCEDURES** 

In accordance with 264.13(c) and/or 35 Ill. Adm. Code 724.113(c), each shipment of waste, upon arrival at the facility, will be inspected as defined herein before the initiation of an y further activity. T his serves two purposes. F irst, it compares the actual waste identity with that determined in the profile process and that listed on the waste manifest. I f the waste conforms to the expected descriptions and properties as determined during the profile review, then the information obtained during profiling can reasonably be used as the basis for managing the waste which arrives at the facility. Secondly, it provides a second level of assurance that the contemplated waste management technique can be utilized. Other Veolia personnel (or a Veolia approved laboratory) can provide the Mandatory and/or Supplemental Analyses required prior to or concurrent with the arrival of the load. W aste shipments that have arrived at the facility are considered to be in the receiving process until such time that Facility Management makes a final decision regarding waste acceptability; at such time the wastes are considered accepted.

If the waste does not conform to the expected descriptions and proper ties as determined during the profile review (is found to be nonconforming), then the information obtained using the Mandatory Analyses and any Supplemental Analyses performed, will be utilized to manage the waste.

All waste shipments which are subject to the Land Disposal Restrictions of 40 CFR Part 268 and have been treated, exempted, varianced, or meet the appropriate treatment standard or prohibition without treatment must be accompanied by a form from the treater or generator, certif ying that the tre ated, exempted, or varianced waste meets the appropriate treatment standard, prohibition, or variance (or that the untreated waste naturally meets the treatment standard or prohibition) and includes any applicable analytical data or reference to such data or documentation (in accordance with 40 CFR 268). F urthermore, all wastes which are subject to the land disposal restrictions and require treatment must be accompanied by a form from the generator (or treater) that (1) notifies that the wa ste contains pro hibited constituents; (2) identifies the appropriate treatment standards associated with the material; and (3) includes any applicable analytical data or reference to such data (in accordance with 40 CFR 268). S ee Section 4.1.1 for a discussion regarding the information and data to be supplied by the generator.ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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24 VEOLIA WAP Revision 3 10/30/2007 **5.1 Receiving Procedures** 

Incoming waste shipment identification begins upon arrival of the waste at the facility. T he only exception to this would be extraordinary circumstances (e.g. DEA drug clean
- up, sensitive military waste, etc.) where the waste would be sampled or visually inspected on site by a Veolia representative. T he trailer would be sealed and transported to the facility. Only then would the seal be opened. The inspection, sampling and analysis of the incoming waste will be performed in accordance with the methods/parameters described in Sections 2.0 and 3.0.

In the case of container shipments not covered in the exceptions (Section 4.1.4), each container of liquids in the shipment will have its contents visually inspected by observing a full depth vertical sample, if possible, to verify that the contents are similar prior to compositing. S imilar is defined as the same color and phase as it relates to the waste stream profile description. I f the waste is residual from a process, similar means same color and same number of phases. I f the profile description is plant debris, many colors and phases may be seen, however, the assessment of similar is that the material is debris
- like in nature **.** The receiving technician will note physical state for each drum on the receiving documents (see Figure 5
- 1, Physical Description Wo rksheet), which the lab will compare to the profiled physical description of the waste. I ncoming wastes will be vi sually inspected for color and phase (liquid, solid, semi
-solid). D rums of direct charge packaged chemicals will be randomly opened and inspected to verify that the drum is packed as identified in Section 5.1.1.

After the inspection, ten percent of the containers from each waste profile within a shipment which are similar, will be sampled, according to Section 2.0. I n the event that a single drum of a specific waste profile is received, or single drums within a profile or not similar, those individual d rums will be sampled. A m aximum of five containerized shipment samples from the same waste profile may be composited prior to analysis, provided the individual samples are similar.

Containers to be sampled, will be selected randomly. Drum numbers will be assigned randomly to the drums in a shipment upon off
- loading prior to inspection or sampling. Samples from incoming wa ste shipments will be subjected to Mandatory Analyses (see section 3.0). All such samples will be retained for a period required to approve the waste for incineration.

The results of the visual inspections and Mandatory Analyses will be documented.ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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25 VEOLIA WAP Revision 3 10/30/2007 5.1.1 Exceptions to Incoming W aste Analysis Procedures

The following materials, which are defined in Section 4.1.4, will not be samp led upon arrival but, at a minimum, will be subjected to a visual inspection as described below. T hese materials are not sampled because they exhibit unusual or impractical sampling and analytical complications and because sufficient chemical and physical data has previously been obtained:

1) Direct Charge packaged chemicals and lab packing debris (e.g., glassware, syringes, lab coats, tyveks, gloves, etc.) packed by Veolia ES Technical Solutions, LLC (see Section 4.1.4 for description). T his inspection pro cedure will apply to those drums which are selected for verification of the drum inventory sheets (DIS). D uring the ve rification, these drums will be identified as conforming, non -conforming and processable, or non -conforming and discrepant. The definitio ns and responses will be as follows: Conforming Drums: A d rum that meets guidelines and all material is identified and corresponds with DIS. C onforming drums will be processed. Processable Drums : A drum that is not conforming b ut sufficient information is available to determine its acceptability. The following are examples of processable drums: 1. Material identified on DIS but not present in the drum; 2. Broken bottle(s) with legible labels(s); 3. Broken bottle(s) and label(s) destroyed, but material identifiable with logical deduction and DIS review; 4. Extra containers of identified material; 5. Extra identifiable and acceptable material; 6. Extra materials consisting of PPE and job supplies (e. g., markers, absorbent bags, cardboard); 7. Material on DIS present but quantities are incorrectly identified; 8. Non
-containerized compound but identifiable from DIS; 9. Missing label but container type/size match DIS. Processable drums will be accepted and processed. The generator of processable drums will be notified of the inaccuracies associated with the processable drum. The generator will also be notified that the continued receipt of processable materials versus conforming, will not be tolerated and wil l result in the issuance of deterrent measures, up to and including banning the generator from sending hazardous waste to Veolia for treatment.ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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26 VEOLIA WAP Revision 3 10/30/2007 Discrepant Drums : A drum where insufficient information is available to determine acceptability of the drum or the drum contains unacceptable material. The following are examples of discrepant drums:

1. One or more broken bottles where the contents cannot be determined; 2. Unidentifiable material; 3. Missing label and container does not match anything on the DIS; 4. Unacceptable material in drum; 5. DIS not available. The portion of the drum which is discrepant will be rejected. 2) Empty containers as defined at 35 IAC 721.107(b). These wastes will be visually i nspected upon receipt. In addition to differences in physical appearance, these wastes will be determined to be nonconforming when they contain material that does not meet the RCRA empty definition defined in 35 IAC 721.107(b). 3) P harmaceutical and commercial products or chemicals consumer quantities in their original packaging. Veolia will visually inspect 5% of the incoming outer containers of these materials to verif y that the shipment contains consumer packages. 4) Aerosol Cans, Lecture Bottles or Gas Cylinders: These wastes will be visually inspected upon receipt or during processing into burnable charges. 5) Controlled substances will not be opened or sampled by Veolia due to the regulations gove rning these materials. Veolia will require an inventory from the packer of these materials as specified in the procedures outlined in Section 4.1.4. These materials are generated by a pharmaceutical company or health care agencies or state or Federal agency. 6) Single Source Spill Material on undefined media where no generator knowledge exists. Veolia will visually inspect 5% of the incoming containers. 7) Wastes which are visually identifiable through an inspection process. Wastes in original packaging will be subject to 5% inspection as per 5.1.1.4 above. W astes wh ich are not in original packaging will be subject to 100% visual inspection. Examples of these types of wastes are PPE, batteries, cathode ray tubes, crushed glass, piping , filters and filter cartridges, wire or tubing, paper products, syringes, metal sheeting and parts, explosive components and devices. T hisILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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27 VEOLIA WAP Revision 3 10/30/2007 list is not meant to be all inclusive. Visually identifiable material will be specified on the Waste Profile Sheet. 8) Prior Agency Approval: Materials which do not fall into one of the other exemption categories, but present impractical sampling or analysis complications. Use of this exemption will be granted on a profile specific basis, with initial review by the IEPA field office (Collinsville). Profile approval will be subject to IEPA
- DLPC Permit Section written (e.g. fax) approval. 9) Explosive, PIH, and odiferous material (e.g., mercaptan) which present sampling, and analytical safety hazards or community nuisance odor problems can be exempted by Facility Management without prior Agency approval. This list is inclusive. **5.2 Incoming Waste Shipment Decision Evaluation Logic** 

After a waste has been received by the facility, inspected, sampled, and analyzed in accordance with Sections 2.0, 3.0, and 5.1 Facility Management will review one or more of the following: the profile information, the Mandatory Analyses, Supplemental Analyses, and the manifest to determine whether the material received conforms with the profile information, and whether it can be safely managed at the facility. The major functions in the process are as follows: 5.2.1 Waste Identification Facility Management will rely on one or more of the following sources of information to determine the identity of the incoming material together with any other available information:

o Visual Inspection of the container contents. o Sampling. o Results of Mandatory Analyses. o Appropriate Land Disposal Restriction Notification/Certification Form. o Waste Manifest. The information gathered from the above sources will be compared with information taken from the following sources developed during profiling (see Section 4.1):

o Waste Profile Sheet. o Results of any analyses. o Any additional documentation supplied by the generator, such as a Material Safety Data Sheet, product ingredient, etc. Specific criteria for wa ste comparison will be documented (see example form). D etermination of conforma nce with specific parameters will be determined as described in Appendix WAP
- D.ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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28 VEOLIA WAP Revision 3 10/30/2007 5.2.2 The Need for Additional Analyses Facility Management may perform additional analyses according to the criteria in Section 3.3 when or results of the Mandatory Analyses or visual inspection do not conform or are inconsistent with profile information (i.e., if awaste is nonconforming as described in Appendix WAP
- D or information gathered is mutually exclusive based on scientific facts and principles). 5.2.3 An Evaluation of Wh ether a Waste is Found to be in Conformance or Non
conformance The Facility Management must classify the waste as being in non -conformance if it is significantly different from the information shown in the profile paperwork or on the manifest, or differs in quantity from that indicated on the manifest, in accordance with 40 CFR 264.72 and/or 35 Ill. Adm. Code 724.172.

Three major criteria are used to arrive at this decision. They are: o For bulk wastes, variations greater than 10% in volume or weight, o For batch wastes (e.g., drums, bags, etc.), any variation in piece count (e.g., the number of pieces listed on the manifest does not agree with the number of pieces received) or, o If inspection or analysis of any waste determin es significant differences exist between the physical properties of the waste and the descriptions on the profile and/or shipping paperwork. Significant differences are: 1) Variations from conformance criteria as described in Append ix WAP
- D or; 2) Analytical results which are mutually exclusive based on scientific facts and principles from the waste description on the manifest or profile paperwork. 5.2.4 An Evaluation of Wh ether Wastes Found to be in Non
-conformance can be Accepted or will be Rejected If the information collected in (1) and (2) above indicates that one or more of the incoming waste evaluation criteria is significantly different from the manifest or profile information, Facility Management must underta ke to account for the apparent observed difference. This evaluation will include one or more of the following:

o Review of sampling methods to verify representative sampling; o Supplemental Analysis, as specified in Section 3.3; o Further evaluation of the waste profile and incoming analytical or discussions with the generator.ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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29 VEOLIA WAP Revision 3 10/30/2007 If information gathered during this evaluation can resolve the discrepancy, the resolution of the discrepancy will be documented along with the results of the incoming waste analysis.

If discrepancies in incoming waste evaluation criteria cannot be resolved, the waste will be considered non
-conforming and the results documented.

Wastes found to be in non -conformance will either be rejected or re- profiled for possibl e acceptance by the facility despite the variance.

Wastes that are rejected during unloading may be placed back on the truck for transportation, as arranged with the generator. W astes that are rejected after the transporter has departed the facility are held in a storage area holding only compatible materials, based on the Mandatory Analyses results. A record is kept of the location of all drums on
-site at all times. Alternatively, Veolia may re-evaluate the wa ste to determine whether the waste materia l as shipped (i.e., inconsistent with WP S and/or manifest data) can be handled at the Facility. I f the facility determines that the waste can be managed consistent with permit requirements, the shipment will be managed. T he profile information will be am ended prior to acceptance of the next shipment. Wastes to be re- profiled will be subject to the profile process requirements as set forth in Section 4.0.

If the re
-evaluation procedure indicates that the waste can be accepted and the generator concurs, a revised waste management decision will be prepared by Facility Management, if the method of management changes.

If a discrepancy cannot be resolved within 15 days of shipment receipt, the IEPA will be notified, in writing, of the discrepancy and of attempts to reconcile it. Waste will be rejected for the following reasons:

o Facility Management for any reason determines that it cannot manage the material in compliance with all regulations, permit requirements, and standards of health and saf ety. o A manifest discrepancy (or non
-conformance) cannot be resolved to the generator's and Veolia’s satisfaction using the procedures outlined above. o The generator's/transporter's paperwork is not in order and the problems cannot be corrected upon arrival. o Storage space in container storage areas or in on
-site bulk liquid storage tanks is not available to provide segregation of incompatible materials. o A liquid waste is not compatible (per the Liquid W aste Compatib ility Test) with waste already in storage and no segregation or other management method is available. Rejected wastes will be picked
- up by the generator or by ap ermitted transporter to be returned to the generator's facility or transported to an al ternate hazardous waste treatment, storage, or disposal facility.ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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30 VEOLIA WAP Revision 3 10/30/2007 **FIGURE 5 -**  **1 PHYSICA** **L DESCRIPTION WORKSHEET**ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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31 VEOLIA WAP Revision 3 10/30/2007 **6.0 PROCESS OPERA**  **TIONS PROCEDURES** Each movement of a waste within the facility, during which any change in its characteristics may occur, makes it subject to additional inspection, sampling and analyses to determine appropriate handling and management of the waste. M any of the analyses needed for the treatment, storage, and disposal functions are performed during incoming waste shipment identification. T hese are not repeated unless it is known or believed that the waste characteristics have changed during storage.

Existing and anticipated operations at the facility, for which current and periodic sampling and analyses is important, include th e following:

-- Storage/Blending

-- Decanting

-- Incineration The analytical procedures for each of these are described separately below. **6.1 Storage** 

Before any wastes are placed into a storage unit, Facility Management will assess the compatibili ty of the waste with the storage unit materials of construction and with wastes already stored therein.

6.1.1 Waste in Containers Containerized wastes are stored with respect to ignitibility, reactivity and compatibility. Compatibility shall be dete rmined consistent with DOT HM
- 181 guidelines as summarized in the "Segregation Table for Hazardous Materials" listed in 49 CFR 177.848 (see Appendix WAP
- G). B ased on the initial DOT hazard class determination and analysis of the waste, the drummed waste will be segregated according to compatibility. These materials will be separated from incompatible materials by storage in segregated bays within the drum storage buildings. T his is accomplished by the data from the WP S, Mandatory Analyses, and Supplementary Analyses requested by the Facility Management. Compatibility segregation does not apply to material which have been repackaged, generated, or solidified due to the fact that the material no longer exhibits hazardous characteristics and are solids.

6 .1.2 Waste in Tanks Liquid wastes delivered in bulk form (e.g., tank trucks, railroad tank cars), or pumped from drums, are typically placed in bulk storage tanks prior to incineration. P rior to transferring any waste into a storage tank, the compatibil ity of the waste with the material already in the tank and the tank materials of construction will be determined by a liquid waste compatibility test (see Appendix WAP
-A). I n addition, tank farm compatibility will be assessed by performing a liquid waste compatibility test on the liquid waste received for bulk storage with a running composite of the tanks within the containment system to which the new waste will be added.ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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32 VEOLIA WAP Revision 3 10/30/2007 6.1.3 Bulk Solids Storage Bulk solids will be managed as follows for unloading into the bulk solids pits: The BTU and chlorine contents used will be either: (a) The higher value of the current pit or the incoming material, or (b) The material will be sampled after mixing and the sample will be analyzed for BTU and chlorine. **6.2 De**  **canting**

In the decanting process, liquid wastes are decanted from drums or other small containers into larger bulk storage units. T he applicable Mandatory Analyses will be performed on wastes to be decanted.

Prior to decanting, a Liquid Waste Compatib ility Test and specific gravity test on a volume weighted sample will be performed to ensure that wastes to be bulked together are compatible. A volume weighted sample is a volume proportionate composite of the intended decant liquids. **6.3 Incineration** 

In the incineration process, liquid, semi
-solid and solid wastes are destroyed by

h igh temperature thermal oxidation. T he resulting streams include combustion gases that are scrubbed to remove HCl and particulates, and other treatment residues (i.e., ash , slag and scrubber sludge, scrubber solids (bag house dust) that are further managed.

The treatment sampling/analysis program for incineration may be divided into two segments, each with a specific purpose:

o Pre
-treatment analyses confirm that the waste falls within the facility permit and operating constraints and allow fine tuning of the process operational constraints; o Treatment Residue Evaluations confirm successful treatment and that the characteristics of the process effluent a re such that it can be sent to the next step (discharge, disposal, or further treatment) based upon permit or process constraints. Residues from on
-site treatment of land disposal restricted wastes will be analyzed and/or evaluated, as needed, against the appropriate treatment standards or prohibitions. Any residues or wastes sent off site for storage, further treatment, and/or disposal will have appropriate notification forms (in accordance with 40 CFR Part 268). The application of these segments is discussed below.ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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33 VEOLIA WAP Revision 3 10/30/2007 6.3.1 Pre
-treatment Analyses All wastes fed to the incinerator are blended to meet permit constraints and to maintain steady state (normal) operation of the incinerator. L iquid waste is blended in bulk tanks prior to incineration. P re-treatment Analyses (6.3.1 numbers 1
-6) are optional for liquid waste in tanks wh ich will undergo further blending prior to incineration. P rior to incineration, a sample is drawn from the tank to be fed and analyzed for the fol lowing parameters: 1. Heat Value
- Heat value is measured to control the feed rates of

waste fed into the incinerators. The maximum heat value which can be burned per hour is established in the operating permit. 2. Total Chlorine Content
- Chl orine content is measured to control the percent chlorine in waste fed into the incinerators. The maximum chlorine content for waste fed into the incinerator is established in the operating permit. 3. pH Screen is used to protect the integ rity of tank farm materials of construction and provide management data for proper blending. 4. Specific Gravity
- This information is used to assure 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). 5. Metals values are calculated based on profile information. The permit operating values we re established through a trial burn. T he permit operating va lues may be changed if it is demonstrated through a trial burn that the new permit guidelines allow the incinerator to operate within the permit constraint and at a steady state (normal) operation.

The Facility Management will review the blend analyses to assure permit compliance and to assure that the bl end will allow steady state (normal) operation of the incinerator. T he blend will be readjusted whenever necessary to meet all permit specifications. This is accomplished through tank
-to
-tank blending with additional wastes. A Liquid Waste Compatibility Test will be performed prior to all tank
-to
-tank transfers of liquid waste. T his new blend is then tested for the blend parameters, which are used to determine optimum blend characteristics as mentioned in the previous paragraph.

Containerized waste is sequenced for incineration through careful indexing of container feed. The parameters necessary for selection of proper feed sequence (Heat Value, Chlorine Content) are evaluated based on the Mandatory Analyses. For the materials identified in Section 5 .1.1, the values of the above parameters are categorized based on physical and chemical composition information obtained per Section 4.1 and 5.1. Container feed sequences reflect an ongoing evaluation of operating experience.ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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34 VEOLIA WAP Revision 3 10/30/2007 6.3.2 Treatment Residue Evaluation

Post
-treatment analyses and evaluation will confirm successful treatment and that the characteristics of the process effluent are such that it can be sent to the next step (discharge, disposal or further treatment) based on permit or process con straints. I n accordance with 40 CFR 268.7(b), residues (or wastes) resulting from on
-site treatment of land disposal restricted wastes are analyzed and/or evaluated, as needed, against the appropriate treatment standard (e.g., Constituent Concentration in Waste Extract (CCW E) values) or prohibition. T he incineration process results in the generation of the following residues: ash, slag and scrubber system solids. E ach residue has been thoroughly evaluated to develop a sampling frequency that is consiste nt and independent of the original wastes accepted for incineration. Wastes or treatment residues sent off
-site for further treatment will be accompanied by the appropriate notification (or certification) forms. Incinerator ash and slag generated in the rotary kiln and dry scrubber solids generated in incineration units numbers 2, 3 or 4 are sampled, analyzed and evaluated on a regular basis (See Appendix WAP
- B, Section 2.2.1) in accordance with analytical procedures required to analyze against the appro priate treatment standard or prohibition (See Appendix WAP
- B).

Incinerator ash generated in the fixed hearth incineration units is either sampled, analyzed and certified to meet the 40 CFR 268 Land Disposal Standards or is re- incinerated and subsequently sampled, analyzed and certified to meet the 40CFR 268 Land Disposal Standards.

The Facility Management will review the analytical results and determine the disposition of the treatment residue. I f the analytical results meet the appropriate treatment standard (e.g., CCW E value), the treatment residue is then approved for shipment. Each shipment is accompanied with the following documentation:

Waste Manifest; Land Disposal Restriction Treatment Certification; Analytical Report or reference to an alytical data. In the event that the analysis does not meet the appropriate treatment standard (i.e., CCW E va lues), Facility Management will investigate the sampling procedure and the analytical procedure to ensure no contamination is present. Two additional samples will be submitted for analysis of the parameters which exceeded treatment standards in the first round of analysis. I f the second analyses pass, the residue will be approved for disposal. I f the source of the contamination can be determined , it will be documented. H owever, if the second analysis does not meet the appropriate treatment standard (i.e., CCW E values), Veolia will retreat the residues in order to meet the appropriate treatment standard (i.e., CCW E values). Alternatively, Veolia may forego additional sampling and analysis and choose to retreat the residue wh ich did not initially meet the treatment standard.ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

NOVEMBER 1997

35 VEOLIA WAP Revision 3 10/30/2007 **7.0 QUA** **LITY AS**  **SURA NCE/QUA** **LITY CONTROL**

The following quality assurance/quality control (QA/QC or "quality") information fo r this facility is being provided as required by 40 CFR Part 270.30(e) and in accordance with the following EPA guidance documents.

The Veolia company quality control program is based on the National Environmental Laboratory Accreditation Program (NELA P) as well as:

Handbook for Analytical Quality Control in Water and Wastewater Laboratories, EPA 600/4
-79
-019, March 1979, U.S. Environmental Protection Agency (U.S. EPA), Environmental Monitoring and Support Laboratory (EMSL), Cincinnati, OH, March 19 79, or most recent addition .

Test Methods for Evaluating Solid Waste: P hysical/Chemical Methods, SW
-846, Third Edition, Final Update III, U.S. EPA, Office of Solid Waste, Washington, DC, Chapter One, or most recent addition. Quality procedures are applicable to both sampling procedures and analytical techniques. T his section does not provide specific performance standards of quality procedures for individual sampling and analysis techniques. S uch specifics are defined on a corporate
-wide basis for all company facilities. T he specific performance standards are dynamic and are revised as warranted to reflect technological advances in sampling and analytical techniques. T hese performance standards are described in corporate policies, which are maintained and used at this facility and which are available for regulatory review. Portions of these policies have been summarized in the following sections. 7.1 Sampling Program Sampling procedures for facility operations are described in Section 2.0 and Table 2
- 1 of this WAP. T he selection of the sample collection device depends on the type of sample, the sample container, the sampling location and the nature and distribution of the waste components. In general, the methodologies used for specific materi als correspond to those referenced in 40 CFR Part 261, Appendix I. T he selection and use of the sampling device is supervised or performed by a person thoroughly familiar with the sampling requirements. Sampling equipment is constructed of non - reactive m aterials, such as, glass, PVC plastic, aluminum, or stainless steel. Care is taken in the selection of the sampling device to prevent contamination of the sample and to ensure compatibility of materials. For example, glass bottles are not used to collect hydrofluoric acid wastes. With some exceptions, all bulk and containerized waste shipments are sampled (see Section 5.1.1 of this WAP. I ndividual container samples may be composited prior to analysis.ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

NOVEMBER 1997

36 VEOLIA WAP Revision 3 10/30/2007 7.2 Analytical Program The company has developed a program of analytical quality practices and procedures to ensure that precision and accuracy are maintained throughout its laboratories. Company facility laboratories are required to participate in this program. Non
-company laboratories employed by the company demonstrate quality control practices that are comparable to the company's program. Good laboratory practices which encompass sampling, sample handling, housekeeping and safety are maintained at all laboratories. The following quality contro l practices are implemented at all laboratory operations: **I Instrument Performance Materials**  Each day of operation, analytical systems are evaluated through the use of instrument performance materials before sample analysis is initiated. Divergence from acceptance criteria specified in the Quality Control Procedures requires corrective action before analyses can be performed. Calibration blanks, instrument performance materials, instrument manual requirements and maintenance records are maintained in an organized manner. **II Contamination Evaluation**  Method blanks are prepared each day of sample analysis and analyzed to ensure that sample contamination has not occurred. W henever appropriate, a field blank is taken and analyzed accordingly. If blank ana lyses do not fall within acceptable limits, as specified in the Quality Control Procedures, corrective action is required before analyses can be performed. **III Laboratory** 

**Control Sample** A quality control check sample is analyzed each day an analytical re sult is determined for a specific parameter. These results show that analytical procedures are performed properly and the calibration and standardization of the instruments are within acceptable limits. Acceptable performance demonstrates that prescribe d precision and accuracy are being maintained. **IV Duplicate A** **naly sis**  A sample or spiked sample is analyzed in duplicate for each twenty (20) samples analyzed for a particular parameter to monitor analytical precision. Selection of theILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

NOVEMBER 1997

37 VEOLIA WAP Revision 3 10/30/2007 duplicate samples is specified in the Quality Control Procedures. Precision is periodically assessed using Relative Percent Difference.
**V Spike A** **naly sis**  Spiked samples are employed to monitor recoveries, to maintain extraction, digestion and concentration techniques at acceptable levels, and to assess analytical accuracy. Spiking samples provides information about the effect of the sample matrix on the analyte of interest. A ratio of one spike for each twenty (20) samples analyzed is maintained. The sample used as t he duplicate is spiked as specified in the Quality Control Procedures. The Percent Recovery results are tabulated periodically and reviewed for trend analysis. **VI Performance Evaluation Testing**  Annually, at a minimum, each laboratory must participate in a performance evaluation testing program. Results must be reported during each calendar year. The company’s Quality Assurance Officer or designee reviews results and generates a report summarizing performance. Each laboratory receives a copy of the resu lts and must investigate any outliers and undertake corrective action measures and report on investigations and corrective actions to the QA Officer. Summaries of performance are provided to company management. **VII Reports**  On a quarterly basis, each la boratory must submit a Quality Control Statistical Summary to the QA Officer. This summary includes: LCS summary data, Duplicate or Matrix Duplicate summary data, and Spike or Matrix Spike summary data. 7.3 Conclusion The aforementioned sampling and an alytical quality practices help ensure that the data obtained are precise and accurate for the waste stream being sampled. T he analytical results are used by facility management to decide whether or not to accept a particular waste and, upon acceptance, to determine the appropriate method of treatment, storage, and disposal. Results are also important to ensure that wastes are managed properly by the facility and that incompatible wastes are not inadvertently combined. T he quality of these results is as important as the results themselves. T hus, the quality of the analytical data, the thoroughness and care with wh ich the sampling and analyses are performed and reported, provides an important basis for day
-to
-day operational decision.ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS, LLC NOVEMBER 1997

WAP

-A

- 1 **AP PENDIX W** **AP -** **A AN**  **AL YTICA** **L PROCEDURES**ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

NOVEMBER 1997

WAP

-A

-2 **AP PENDIX WA** **P -** **A AN**  **AL YTICA** **L PROCEDURES** The following analytical procedures are designed to identify or screen waste. T hey are used by Veolia ES Technical Solutions, LLC based upon its operating experience, as rapid but effective means for establishing key decision parameters pertinent to proper wa ste management. T he analyses described in the sections below are based on ASTM and "Standard Methods" approved by EPA. I t should be noted that the information presented in this appendix is generic in character. T herefore, certain test methods are discussed wh ich may pertain to treatment or disposal processes that are excluded from the facility for which the foregoing waste analysis plan is presented.

**II. STANDARD ANALYTICAL**  **PROCEDURES** PARAMETER METHOD REFERENCE Sam ple Work Up Techniques: Inorganic Techniques Acid digestion procedure for flame atomic 1

-3010 absorption spectroscopy Acid digestion procedure for furnace absorption spectroscopy 1

-3020 Acid (Parr) Bom

b digestion 3

-E886; E926; 6

-Bulletin 4745 Acid digestion of oils, greases, or waxes 1

-3030 Dissolution procedure for oils, greases, or waxes 1

-3040 Acid digestion of sludges 1

-3050 Alkaline digestion (for solids) 1

-3060 Organic Techniques Separator funnel liquid

-liquid extraction 1

-3510 Continuous liquid

-liquid extraction 1

-3520 Acid

-base clean

-up extraction 1

-3530 Soxhlet extraction 1

-3540 Alumina Column Clean

-up and Separation of Petroleum Wastes 1

-3611 Flurosil Column Clean

-up 1

-3620 Silica Gel Clean

-up 1

-3630 Sulfur Clean

-up 1

-3660 Waste Dilution I

-3580 Inorganic Analytical Methods: Inductively Coupled Plasma Atomic Emission Spectroscopy (ICP) 1

-6010 Antimony Atomic absorption, direct aspiration method 1

-7040; 4

-204.1ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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WAP

-A

- 3 Atomic absorption, furnace method 1

-7041; 4

-204.2 Arsenic Atomic absorption, furnace method 1

-7060; 4

-206.2 Atomic absorption, gaseous hydride method 1

-7061; 4

-206.3 Barium Atomic absorption, direct aspiration method 1

-7080; 4

-208.1 Atomic absorption, furnace method 1

-7081; 4

-208.2 Beryllium Atomic absorption, direct aspiration method 1

-7090; 4

-210.1 Atomic absorption, furnace method 1

-7091; 4

-210.2 Cadmium Atomic absorption, direct aspiration method 1

-7130; 4

-213.1 Atomic absorption, furnace method 1

-7131; 4

-213.2 Calcium Atomic absorption, direct aspiration method 1

-7140; 4

-215.1 Atomic absorption, furnace method 4

-215.2 Chromium Atomic absorption, direct aspiration method 1

-7190; 4

-218.1 Atomic absorption, furnace method 1

-7191; 4

-218.2 Hexavalent chromium: CO

-precipitation 1

-7195 Hexavalent chromium: Colorimetric 1

-7196; 2

-3500CrD Hexavalent chromium: Chelation

-extraction 1

-7197; 4

-218.4 Copper Atomic absorption, direct aspiration method 1

-7210 ; 4

-220.1 Atomic absorption, furnace method 4

-220.2 Iron Atomic absorption, direct aspiration method 1

-7380; 4

-236.1 Atomic absorption, furnace method 4

-236.2 Phenanthroline method (ferrous) 2

-3500FeD Lead Atomic absorption, direct aspiration method 1

-7420; 4

-239.1 Atomic absorption, furnace method 1

-7421; 4

-239.2 Magnesium Atomic absorption, direct aspiration method 1

-7450; 4

-242.1 Manganese Atomic absorption, direct aspiration method 1

-7460; 4

-243.1 Atomic absorption, furnace method 4

-243.2 Mercury (manual cold

-vapor technique) In liquid waste 1

-7470 In solid or semi

- solid waste 1

-7471 Nickel Atomic absorption, direct aspiration method 1

-7520; 4

-249.1 Atomic absorption, furnace method 1

-7521; 4

-249.2 Selenium Atomic ab sorption, furnace method 1

-7740; 4

-270.2 Atomic absorption, gaseous hydride method 1

-7741; 4

-270.3 Silver Atomic absorption, direct aspiration method 1

-7760; 4

-272.1 Atomic absorption, furnace method 1

-7761; 4

-272.2ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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-A

-4 PARAMETER METHOD REFERENCE
ThalliumAtomic absorption, direct aspiration method 1

-7840; 4

-279.1 Atomic absorption, furnace method 1

-7841; 4

-279.2 Zinc Atomic absorption, direct aspiration method 1

-7950; 4

-289.1 Atomic absorption, furnace method 4

-289.2 Organic Analytical Methods: Gas Chromatographic Methods Halogenated Volatile Organics 1

- 8010 Non

-halogenated Volatile Organics 1

- 8015 Aromatic Volatile Organics 1

- 8020 Acrolein, Acrylonitrile, Acetonitrile 1

- 8030 Phenols 1

- 8040 Phthalate Esters 1

- 8060 Organochlorine Pesticides and PCBs 1

- 8080 Nitroaromatics and Cyclic Ketones 1

- 8090 Poly nuclear Aromatic Hydrocarbons 1

- 8100 Chlorinated Hydrocarbons 1

- 8120 Organophosphate Pesticides 1

- 8140 Chlorinated Herbicides 1

- 8150 GC Scans 3

-E260 Gas Chromatographic/Mass Spectroscopy Methods GC/MS Method for Dioxin 1

- 8280, 8290 GC/MS Method for Volatile Organics 1

- 8240; 7

-624 GC/MS Method for Semi

-Volatile Organics 1

- 8250; 8270; 7

-625 Infrared Spectroscopy Methods 3

-D2621, D4053; 5

- Screening Methods : Physical Description 3

-D4979 Flammability Potential Screen 3

-D4982 Water Compatibility 3

-D5058C pH Screen 3

-D4980 Sulfide Screen 3

-D4978 Cyanide Screen 3

-D5049 Commingled Waste Compatibility 3

-D5058A Polymerization Potential 3

-D5058B Oxidizer S creen 3

-D4981 Bulk Density and Apparent Specific Gravity Screen 3

-D5057ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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-A

- 5 PARAMETER METHOD REFERENCE Miscellaneous Analytical Methods: Acidity 2

-2310 Alkalinity 2

-2320 Ammonia 4

-350.3 Anions by Ion Chromatography 3

-D4327; 4

-300.0 Ash Content 3

-D482, D3174 Bromides 2

-4500Br- ; 4

-300.0, 320.1 Chlorides 2

-4500Cl- ; 4

-300.0, 325.3 Conductivity/Conductance 3

-D1125; 4

- 120.1 Extraction Procedure 1

- 1310 Flash point Pensky

-Martens closed

-cup method 1

- 1010; 3

-D93 Setaflash closed

-cup method 1

- 1020; 3

-D3278 Cleveland open

-cup 3

-D92 Fluoride 2

-4500F - ; 4

-300.0, 340.2, 340.3 Free Cyanides 2

-4500CN-H,I Halogen Content 3

-D808, D2361, D4327 Heat Value 3

-D240, D2015 Oil and Grease 2

-5520; 4

-413.1, 413.2 Oxidation

-Reduction (Redox) Potential (ORP) 3

-D1498 Petroleum Hydrocarbons, Total Recoverable 2

-5520F; 4

-418.1 Phenols 2

-5530, 6420; 4

-420.1 pH Measurement 1

-9040, 9041, 9045; 2

-4500H+; 3

-E70; 4

- 150.1 Phosphates 2

-4500P; 4

-300.0, 365.1

-4 Radioactivity Screen Solids Total (TS) at 103

- 105 oC 2

-2 540B; 4

- 160.3 Dissolved (TDS) at 180 oC 2

-2540C; 4

- 160.1 Suspended, Total (TSS) at 103

- 105 oC 2

-2540D; 4

- 160.2 Fixed and Volatile at 500 oC 2

-2540E, 2540G; 4

- 160.4 Specific Gravity 2

-2710F; 3

-D70, D891, D1217, D1429 Sulfates 2

-4500SO42

- ; 4

-300.0, 375. 3 Sulfur 3

-D129, D3177, D4327 Total and Amenable Cyanides 1

-9010A; 2

-4500CN-C,G; 4

-335.1 Total Chlorine Content 3

-D808, D4327 Total Organic Carbon 2

-5310; 3

-D2579 Total Sulfides 1

-9030; 2

-4500S 2

- Toxicity Characteristic Leaching Procedure (TCLP) 1

- 13 11 Viscosity 3

-D88, D446, D2983 Water Content 3

-D95, D3173, E203ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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-A

- 6 The above
- referenced procedures are described in the following publications. T he first digit of the reference numbers above are keyed to the numbers shown below: 1
- "Test Methods for Evaluating Solid W aste, Physical/Chemical

Methods", SW
-846, Third Edition, 1986 as amended by Update I (July 1992), U.S. Environmental Protection Agency, Office of Solid Waste (NTIS, 5285 Port Royal Road, Springfield, VA, 22161) or more recent edition or revision (GPO, Supt. of Documents, Washington, DC 20402). 2
- "Standard Methods for the Examination of W ater and W astewater", 18th Edition, American Public Health Association (1015 Fifteenth Street, NW, W ashington, DC 20005), American Water Works Association, W ater Environment Federation, 1992, or more recent edition or update. 3
- "Annual Book of ASTM Standards", American Society for Testing and Materials (1916 Race Street, Philadelphia, PA 19013
- 1187), 1992, or mo re recent edition or revision. 4
- "Methods for Chemical Analysis of W ater and Wastes", EPA
600/4
-79
-020,U.S.Environmental Protection Agency, Environmental Monitoring and Support Laboratory (Cincinnati, OH 45268), as revised March 1983, or more recent revision or technical edition. 5
- Infrared Analysis Method in IERL
- RTP Procedures Manual: Level 1 Environmental Assessment (2nd Edition), EPA
-600/7
-78
-201, October, 1978, or more recent edition. 6
- "Acid Digestion Bombs", Bu lletin 4745, Parr Instrument Company (Moline, IL 61265), or more recent bulletin. 7
- "Methods for Organic Chemical Analysis of Municipal and Industrial W astewater", Appendix A of Title 40 Code of Federal Regulations Part 136, U. S. Environmen tal Protection Agency, Environmental Monitoring and Support Laboratory
-Cincinnati, as amended June 1986 or more recent revision. Standard analytical procedures listed here wh ich are revised can be implemented upon the effective date of the revi sion, without notification to the IEPA.WAP

-B

- 1 **AP PENDIX WA** **P -** **B**
**AS H A** **ND DRY SCRUBBER SOLIDS**ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

NOVEMBER 1997

WAP

-B

-2 **SA MPLING PROTOCOL**  **AP PENDIX WA** **P -** **B AS**  **H A ND DRY SCRUBBER SOLIDS**  **SA MPLING PROTOCOL**  **1.0 PURPOSE**  The Veolia Incinerators destroy hazardous wastes in high temperature thermal oxidation processes. T his procedure provides assurance that a representative sample of ash or dry scrubber solids (DSS) is collected for analysis. **2.0 SA** **MPLING 2.1**  **Sample Identification** 2.1.1 Each sample container is labeled with date, time of day, sampler, and container identification number. T he samples are logged into the laboratory Production Chain
-of
-Custody logbook (or via the electronic Chain
-of
-Custody system) upon delivery to the laboratory. **2.2 Sample Collection**  2.2.1 Ash and DSS samples are collected, analyzed and evaluated on a quarterly basis to ensure the residuals met the LDR treatment standards. 2.2.2 Samples are collected as outlined in Section 2.2.1 of the WAP. An auger is typically used to obtain a representative sample of the ash or DSS. Each sample jar must be filled with ash or DSS. 2.2.3 Trained operations personnel will collect the sample and subsequently acknowledge custody by completing applicable sections of the Chain
-of
-Custody record. Sample preparation and analysis will be performed as soon as practicable following which the disposition of the ash (Section 4.0) will be determined. **2.3 Sampling Personnel**  2.3.1 It is the responsibility of Facility Management to assign only qualified personnel to perform the ash or DSS sampling. P ersonnel that have been trained in the implementation of this procedure are considered to be qualified. **3.0 SA** **MPLE A NA** **LYSIS** 3.1 Each sample will be sent to a Veolia laboratory or Veolia approved lab for analysis of LDR constituents by the appropriate method. 3.2 The tracking of waste codes through the incineration process to the incinerator residuals will be done in accordance with the facility Standard Division Practice 1651.ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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WAP

-B

- 3 **4.0 DISPOSITION OF**  **AS H**  **AN D DRY SCRUBBER SOLIDS (DSS)**  4.1 Any container of ash or DSS that was sampled for testing in accordance to the appropriate treatment standard or prohibition, will be retained by the facility until results are available for evaluation. 4.2 The analysis results are evaluated against the LDR treatment standards for the codes in the container. The container is released if all treatment standards are met. 4.3 The analysis results are evaluated against the LDR treatment standards for all codes accepted by Veolia. M eeting the treatment standards is demonstrated through the process. 4.4 Wh en compliance with the LDR standards has been demonstrated, the material will be stabilized and subsequently disposed of at Veolia approved hazardous waste management facilities. The manifest and Land Disposal Restriction Treatment Certification will be completed prior to shipment.WAP

- C

- 1 **AP PENDIX WA** **P -** **C WA** **STE AC**  **CEPTA BILITY CRITERI**  **A**ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

NOVEMBER 1997

WAP

- C

-2 **AP PENDIX WA** **P -** **C WA** **STE AC**  **CEPTA BILITY CRITERI**  **A** The following restrictions apply to the acceptance of wastes exhibitin g certain properties or specific wastes at Veolia. P rior to acceptance (see Section 5.2), the Mandatory Analyses and the W aste Profile Sheet will be evaluated against this appendix. Any restrictions identified will be documented on the waste management d ecision. T he list of items under each of these headings is not meant to be exhaustive. The profiling process will include a review of the MSDSs and a search of the other bibliographic resources (see Appendix WAP
- F) for synonyms, product names, or common n ames. The nature of the restrictions is as follows: **REJECT -**  **These Materials may not be processed at the facility.**  Radioactive W astes Thorium Compounds Uranium Compounds Radioactive materials as defined by the Veolia Part B RCRA Permit, or greater than 0.5 millirads per hour. (per Section 3.1.4) Permit Limited W astes F020 F021 F022 F023 F026 F027 F028 PCBs > 50 ppm (or other TSCA regulated PCBs) Regulatory Specified Treatment Technology other than Incineration D006 NiCd BatteriesILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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WAP

- C

- 3 DOO8 Lead acid Batteries K069 Non
-Calcium Sulfate Other Unacceptable Wastes Asbestos SPECIAL PACKAGING
- Wastes exhibiting the properties listed below (water/air reactive, malodorous, rapid heat release) during the profiling process may be accepted if they are shipped in special packaging, repackaged on site or if the material conforms to specifications allowing processing in existing Veolia facilities. Water/Air Reactive W astes Isocyanates Nitrates Chlorates Perchlorates Thionyl chloride Metal turnings Phosphorous Metal hydrides Silanes Chloroformates Methylamine Oleum Other water or air reactive wastesILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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WAP

- C

-4 Malodorous Compounds Mercaptans Sulfides Waste which exhibits energetic characteristics Waste which exhibits energetic characteristics (e.g., propellants, explosives, pyrotechnics, flammable liquids, etc.) will either be accepted per the Small Quantity Chemical guidelines or will be accepted per the following procedure. Wh en the volume of a waste stream or changes in incinerator performance indicates that a larger charge size is warranted, Veolia will follow the following procedure: 1) The material will be reviewed using reference information, MSDSs where available, generator discussions or previous experience. Based on this review, Veolia will determine if a larger charge size is acceptable. 2) Wh en it has been determined that a larger charge size is acceptable, Veolia will either: a) Determine if this type of material has been previously processed at Veolia in larger charge sizes and thereby establish a charge size; or b) Conduct a test burn of the material to determine what charge size would be acceptable. This test burn will start with the quantity specified in the SQCG's of the energetic component and be increased by no more than double the previous charge from this starting point based on the incinerator operations. The incinerator operations parameters which will be evaluated to determine if charge size ca n be increased will be as follows: > Vacuum decrease in the primary or secondary chamber. > Temperature increase in the primary chamber of >100 o F > Visual interruption of the primary flame > Non
-steady state gas flow. NOTE: This test protocol may be utilized to establish revised charge sizes for all

materials previously limited in the SQCG's. Test burn documentation will be provided to the IEPA
- DLPC prior to implementing larger charge sizes. Dioxin W aste See
-Veolia’s
- Dioxin
-Analysis
- Pol icy.WAP

-D

- 1

.

**AP PENDIX WA** **P -** **D**

**DETERMINA**

**TION OF INCOMING W AS** **TE**ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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WAP

-D

-2 **CONFORMA NCE/NONCONFORMA** **NCE**

**AP PENDIX WA** **P -** **D INCOMING W** **AS TE CONFORMA** **NCE/NON -** **CONFORMA NCE**  Incoming waste may vary from the information determined during the profiling phase due to the variabi lity in the process generating the waste or in collection of the waste material. In order to determine whether a particular incoming waste stream conforms to the profile, the following criteria will be used. All other Mandatory and Supplemental analysis data collected will be used to allow TW I to determine the best method for processing the waste material. 1. pH Screen: A variation in the pH from the range specified in the profile documents may indicate a change in the waste stream. I f a pH variation b eyond the range specified on the liquid profile sheet, the procedures outlined in Section 5.2.4 will be initiated (e.g., a waste which is normally neutral is found to be corrosive). 2. Flammability Potential Screen: A va riation in the thermal activity from the indicators specified in the profile documents will indicate a change in the waste stream. If the variation causes a change in the hazard class of the waste, the procedures outlined in Section 5.2.4 will be initiated (e.g. a material which did not exhibit flammability potential in the profiling phase does during the incoming shipment procedures). 3. PCBs: The unexpected presence of PCBs > 50 ppm contrary to that specified in the profile documents will indicate a change in the waste stream, which wou ld initiate the procedures outlined in Section 5.2.4. TWI i s not permitted to accept PCBs > 50 ppm or TSCA derived PCB wastes. 4. Radioactivity Screen: The presence of radioactive materials as determined by the radioactivity screen (see Section 3.1.4) will initiate the procedures as outlined in Section 5.2.4, leading to rejection of the material. 5. Apparent Viscosity: A significant variation in the apparent viscosity from that specified in the profile documents will indicate a change in the waste stream that would initiate the procedures outlined in Section 5.2.4. 6. Color: A

s ignificant variation in the color ranges specified in the profile documents may indicate a change in the waste stream. Wastes assigned a color on the profile due to gene rator knowledge or literature during pre-acceptance will be compared to the color of the sample or visual description at receipt. Some wastes types may be described as “varies” due to the type and variability of the constituents. For example, debris wastes may include blue gloves, white rocks, green leaves, and brown absorbent. S ignificant variations in color ranges would initiate the procedures outlined in Section 5.2.4.ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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-D

- 3 7. Phases : A

s ignificant variation in the number and type of phases specified in the profile documents may indicate a change in the waste stream. Wastes are typically described as solid, sludge, or liquid. I f the waste is profiled as one or any combination of the phases, the waste will be compared to the profile information. Variati ons would initiate the procedures outlined in Section 5.2.4. 8. Incidental Odor: Any incidental odor noticed by the samplers and/or laboratory analysts not specified on the profile documents may indicate a change in the waste stream and would initiate the procedures outlined in Section 5.2.4.WAP

-E

- 1 **AP PENDIX WA** **P -** **E CONTA** **INERIZED W ASTE: SPECIA** **L S AM**  **PLING PROCEDURES**ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

NOVEMBER 1997

WAP

-E

-2 **AP PENDIX WA** **P -** **E CONTA** **INERIZED W ASTE: SPECIA** **L S AM**  **PLING PROCEDURES** 1.0 PURPOSE This procedure provides assurance that representative sam ples of the following containerized wastes are collected for analysis. Specifically, these are containerized wastes of debris and like material, adhesives and other highly elastic substances, and resins and other hard materials. Representative samples are collected by using multipoint sampling. 2.0 DEFINITIONS 2.1 Debris and like material
- includes wood, bricks, concrete, vegetation, plastic sheeting, protective clothing, etc. 2.2 Adhesives and other highly elastic materials
- sticky, glue
- like, gum my, stretchable materials. 2.3 Resins and other hard materials
- plastics and plastic components, epoxies and other physically similar materials that have hardened or cured. 2.4 Multipoint sample
- A sample composed of sub
-samples collected from the same container that is representative the contents of the container. 3.0 INSPECTION Each container will be evaluated prior to opening to determine its integrity. After opening, the container's contents will be visually inspected to determine whether or not it conforms to its profiled description. 4.0 PERCENT SAMPLED See Waste Analysis Plan Section 5.1. 5.0 SAMPLING Multipoint samples based on inspection will be collected from containers selected for sampling. S ampling equipment will be se lected based on results of the inspection. Samples will be in Veolia custody from sample collection until transfer of custody to the analytical laboratory. S ampling equipment will be decontaminated prior to and after sampling each waste stream. 5.1 HIG HLY ELASTIC SUBSTANCES Adhesives and other highly elastic substances will be sampled with a scoop or shovel and scissors or tongs. The procedure is to:

5.1.1 Dip the shovel or scoop into the material to the depth of the blade and rotate;ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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- 3 5.1.2 Lift the scoop or shovel with the sample and cut with the scissors or tongs, as appropriate; 5.1.3 Wi nd the hanging portion of the sample onto the scoop or shovel and transfer the sample to the sample container by scraping the material from the shovel or scoop into the sample container. 5.2 DEBRIS AND LIKE MATERIAL Debris and like materials will be sampled with scissors, hammer, chisel and tongs as appropriate. The procedure is to:

5.2.1 Use hammer and chisel to collect samples of wood, brick or other hard material from the top of the container and place in the sample container with tongs; 5.2.2 Use scissors to cut sample of tyvek and other easily to cut materials (padding, rubber, plastic sheeting, etc.) and place in sample container with tongs. 5.3 RESINS AND/OR OTHER HARD MATERIALS Resins and/or other hard materials will be sampled with a hammer, chisel and tongs or scoop. The procedure is to:

5.3.1 Use hammer and chisel to reduce material(s) size so that i t can easily be placed in a sample container and place the sample in the container with tongs or scoop. 6.0 SAMPLING PERSONNEL It is the responsibility of Facility Management to assign only qualified personnel to perform specialized sampling of containerized waste. P ersonnel that have been trained in the implementation of this procedure are considered to be qualified. 7.0 SAMPLE ANALYSIS Samples will be analyzed as specified in Sections 3.1, 3.2, and 3.3, and Figure 3
- 1 of the WAP. Additional analysis will be performed at the request of the Facility Management.WAP

-F

- 1 **AP PENDIX WA** **P -** **F BIBLIOGRA** **PHY OF STA NDA** **RD CHEMICAL REFERENCE MA TERIA** **LS**ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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-2 **AP PENDIX WA** **P -** **F BIBLIOGRA** **PHY OF STA NDA** **RD CHEMICAL REFERENCE MA TERIA** **LS**
1. The Merck Index, Current Edition , 1983 Merck & Co. Inc., Rahway, NJ.
2. Dangerous Properties of Industrial Chemicals, Current Edition 1989, Van Nostrand Reinhold, NY NY.
3. Handbook of Reactive Hazards, Current Edition, 1987, Butterworths, London.
4. Condensed Chemical Dictionary, Current Edition, 1987 Van Nostrand Reinhold,NY NY.
5. Computerized MSDS system, current version.
6. Farm Chemicals, Current Edition, '91, Meister Publishing Co.
7. Chemical Synonyms & Trade Names, Current Edition, 1987 Gower Technical Press.
8. Lange's Handbook of Chemistry, Current Edition, 1985 McGraw
- Hill.
9. Handbook of Reactive Chemicals, Current Edition, 1985 L. Bretherick. 10. Handbook of Chemistry & Physics, Current Edition, 1976 CRC Press. These references are updated to the most current revision as they are made available and if significant changes have been made. F acility Management is responsible to assess when a revised reference is needed.WAP

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- 1 **AP PENDIX WA** **P -** **G HM**  **- 181 COMP** **AT IBILITY CLA** **SSES**ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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-2 **AP PENDIX WA** **P -**  **G HM**  **- 181 COMP** **AT IBILITY CLA** **SSES**
DOT Class NAME 1.1
- 1.6 Explosives 2.1
- 2.2 Aerosol Cans 3 Flammable Liquid 4.1 Flammable Solids 4.2 Spontaneously Combustibles 4.3 Dangerous W hen Wet 5.1 Oxidizers 5 .2 Organic Peroxides 2.3 Poisonous Gas Zone A & B 6.1 Poisonous Liquid Zone A 8 Corrosives 9 Miscellaneous N.O.S. Debris Non
- Hazardous Material NOTE: The Hazard Materials Load and Segregation Chart (49 CFR 177.848) that

Veolia will follow is included on the next page.ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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- 3 **HM -**  **181 COMPATIBILITY CLASSES** DOT Class Name Incompatible Class 1.1

- 1.6 Explosives 2.1, 2.2 3 4.1, 4.2, 4.3 5.1, 5.2 6.1 8 2 .1

- 2.2 Aerosol Cans 1.1

- 1.6 2.3 6.1 8 3 Flammable Liquid 1.1

- 1.6 2.3 5.1 6.1 4.1 Flammable Solids 1.1

- 1.6 4.2 Spontaneously Combustibles 2.3 4.3 Dangerous When Wet 6.1 8 5.1 Oxidizers 1.1

- 1.6 5.2 Organic Peroxides 2.3 3 6.1 8 **HM -**  **181 COMPATIBILITY CLASSES** DOT Class Name Incompatible Class 2.3 Poisonous Gas Zone A & B 1.1

- 1.6 6.1 Poisonous Liquid Zone A 2.1 3 4.1, 4.2, 4.3 5.1, 5.2 8 8 Corrosives 1.1

- 1.6 2.1, 2.3 4.1, 4.2, 4.3 5.1, 5.2 6.1 9 Miscellaneous N.O.S. Debris 1.1

- 1.6 Non

-Hazardous MaterialILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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-4 NOTES: • 6.1 Liquid PG I Zone A only

• Ignitables stack one high only

• Repacks/Solidifications

- No. HM 181 Classification

• For Consolidated Liquids, Consolidated Solids and decant batches, Lab compatibility testing will determine DOT Hazard Class.1 **VEOLIA PCB SCREENING POLICY** ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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2 **PCB SCREENING POLICY I.**  **INTRODUCTION** The Toxic Substances Control Act (TSCA) is the primary source of Federal regulations affecting the management of Polychlorinated Biphenyls (PCBs). M ost of the provisions of the TSCA regulations specified in 40 CFR Part 761 apply to PCBs, only if PCBs are present in concentrations above specified levels. T he 40 CFR Part 761 Subpart D Storage and Disposal provisions apply generally to material at concentrations of 50 parts per million (ppm) and above. H owever, no provision specifying a PCB concentration may be avoided by d iluting PCB containing materials unless otherwise specifically provided. Furthermore, the Resource Conservation and Recovery Act (RCRA) is an additional source of Federal Regulations affecting the management of hazardous waste containing PCBs. T he land disposal of liquid hazardous wastes containing PCBs at concentrations greater than or equal to 50 ppm is prohibited under the provisions of 40 CFR Part 268.32 (a)(2). T he land disposal of liquid or non - liquid hazardous wa ste containing halogenated organic compounds (HOCs) including PCBs (see 40 CFR Part 268 Appendix III for a listing of HOCs) at concentrations equal to or greater than 100 0 mg/L or 1000 mg/kg respectively, is prohibited under the provisions of 40 CFR Part 268.32 (a)(3), (e)(1), and (e)(2) the "California List." In addition, the management of liquid hazardous waste containing PCBs at concentrations of 50 ppm or above, as we ll as, liquid or non - liquid hazardous wastes continuing HOCs including PCBs (see 40 CFR Part 268, Appendix III for list of HOCs) in total concentrations equal to or greater than 1000 mg/L or 1000 mg/kg for liquid or solid, respectively, are specified under the provisions of 40 CFR Part 268.42. F inally, the land disposal of hazardous waste containing PCBs and identified by the listed hazardous waste code numbers K085 and F039 (multi
-source leachate) is regulated under Specific Land Disposal Restrictions (LD R) provisions under 40 CFR Part 268.43. These regulations require PCBs to be treated to the following levels (Table I) prior to land disposal.ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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3 **TABLE I**

Waste Water Non

-Waste Water K085 & F039 mg/L mg/kg Aroclor 1016 0.013 0.92 Aroclor 1221 0.014 0.92 Aroclor 1232 0.016 0.92 Aroclor 1242 0.017 0.92 Aroclor 1248 0.013 0.92 Aroclor 1254 0.014 1.8 Aroclor 1260 0.014 1.8 State and local agencies and permits may also regulate the management of PCBs. Compliance with these regulations is required wherever they are mover stringent than Federal Regulations (e.g., certain states require that the PCBs be reported on a dry we ight basis). Addi tionally, TSCA addresses PCBs, not Aroclors. T his includes incidentally produced PCBs and foreign produced materials that include Clophen®, Phenoclor®, Pyralene®, Kanechlor®, and Fenclor®. In order to assure that the appropriate practices are being appl ied consistently throughout Veolia regarding the management of wastes which may potentially contain PCBs, it is important to define procedures to be employed throughout the company. Therefore, the following Policy and Procedures has been developed. **II. P**  **OLICY** A. The treatment, storage, and disposal of any TSCA regulated waste shall occur only at a TSCA approved treatment, storage, or disposal facility. B. All PCB analyses required as a result of the application of this policy shall be performed by a Veolia laboratory or a Veolia approved laboratory. C. Any wa ste that will be analyzed for PCBs in accordance wit this policy shall not be accepted for storage, treatment, or disposal until PCB analyses have been completed and evaluated.ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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4 D. Any non -TSCA waste wh ich meets the following criteria shall be treated as a PCB suspect waste until demonstrated, otherwise, through chemical analysis.
**III. PCB SUSPECT W** **AS TE CRITERI**  **A** The following criteria have been developed by Veolia through its extensive operating experiences, as well as, through review of va rious sources of literature for defining a waste as being PCB Suspect. T hese criteria are intended to supplement existing requirements which may have been imposed through permit conditions, administrative o rders, or other agreements with Federal or state regulatory agencies. A. Generator
- Defined PCB W aste Any waste for which the generator has indicated on the "Generator's Waste Material Profile Sheet" or any other supporting documentation that PCBs are present below regulated levels. B. Oil Bearing W aste NOTE: O il bearing wastes are defined as any material (liquid, solid, organic, or aqueous) containing oil as described on the "Generator's Waste Material Profile Sheet" (other supporting documentation ) OR any material which exhibits the visual presence of oil. T he visual presence of oil may include, but is not limited to, an oil emulsion, oil film, oil phase, or water soluble oil. I t is the responsibility of the Laboratory Manager at each division to use sole judgment based on their analytical experience to make the final determination if a waste stream exhibits the visual presence of oil. C. **Sewer Clean**  **- up**  **Wastes*** **and** Municipal Waste Water Treatment Facility Sludge ***Note: all incoming loads of se wer clean**  **- up w** **aste will be analy zed for PCBs.**  D. Bulk Laboratory W astes E. Baghouse Dusts from Secondary Smelters (e.g., copper, aluminum) F. Any W aste as Designated by the Laboratory Manager G. All W astes, Liquids or Soils, from the following: 1

. Electrical Utility CompanyILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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5 2. Natural Gas Pipeline Transmission Company 3. Solvent Recovery, Reuse or Recycling Unit 4. Oil Recovery, Reuse or Recycling Unit 5. Oil Maintenance Centers 6. Pond Closures (including Pond Sludges and Dredgings) 7

. Remedial Action Superfund Sites 8. RCRA Corrective Action Project* 9. Timber/Lumber Treating Facility 10. Hydraulic Equipment 11. ENRAC Remedial Action Projects* 12. Heat Transfer Units 13. Metal Machining (Cutting) Operations 14. Pesticide/Herbicide Manufacturing 15. Ink and Pigment Manufacturing 16. Oil Based Paint Manufacturing 17. Paper Recycling Operations 18. Roofing Felt Manufacturing or Processing 19. Auto Fluff 20. Non
-WM I W aste Treaters 21. Chlorobenzene Manufacturing *Unless demonstrated non
-TSCA

**IV. PROCEDURES**  A. Pre
-Acceptance Samples Pre
-acceptance samples are to be analyzed for PCBs by a laboratory if the waste stream meets any of the criteria specified in Section III above. B. Incoming W aste Shipment Samples The need to analyze incoming waste shipment samples for PCBs will be established by the results of the sales sample analysis and evaluation of the sales sample Waste Profile Sheet information against this policy. Table II describes the overall requirements discussed below.

If a waste stream does not meet any of the PCB suspect criteria, then there is no specific requirement to perform PCB analyses on the incoming shipments of this waste stream unless specifically required under a W aste Analysis Plan (WAP).ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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6 If a waste stream meets any of the PCB Suspect Criteria and the sales sample analysis indicates PCBs are less than 5 ppm 1 or the regulatory limit (The EPA TSCA office has recently specified concentrations of less than 2 ppm PCBs in treatment residues for approval and refer to Table I for listed code specifications), whichever is lower, then the laboratory/technical manager must specify on the Waste Management Decision (W MD) whether PCB analyses on incoming waste shipments are required, an d, if so, the fr equency of analyses.

If a waste stream meets any of the PCB Suspect Criteria and the sales sample analysis indicates PCBs are above 5 ppm 1 or the regulatory limit, whichever is lower, then the laboratory/technical manager must specify on the W MDthat PCB analyses on incoming waste shipments are required and the fr equency at which that analysis is to be performed. If the receipt material demonstrates a change in the waste fr om the preacceptance sample and it now meets the PCB suspect criteria, then PCB analysis must be Performed before treatment, storage, or disposal.

1 The specific criterion of 5 ppm is the typical laboratory reporting limit for PCB analysis. It is a conservative approach to protecting the integrity of non

- TSCA facilities.ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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7 **VEOLIA DIOXIN A** **NA LYSIS POLICY**  I. Policy Statement Veolia is implementing this policy for the screening of wastes which may contain dioxin. This policy will identify the types of wastes which will be analyzed for dioxin precursors and/or dioxin. II. Definitions A. Dioxin : For purposes of this policy, dioxin is 2,3,7,8
-tetrachlorodibenzo
- pdioxin (2,3,7,8
-TCDD). B. Dioxin precursors : Dioxin precursors are similar in chemical composition to dioxins. For purposes of this policy, Dioxin precursors tested for are: 2,4,5
- trichlorophenoxy acetic acid, 2
- (2,4,5
- trichlorophenoxy) propionic acid (Silvex), Pentachlorophenol. C. Testing Procedure (See WAP Appendix A) : 1. HPLC:: High Pressure Liquid Chromatography 2. GC, GC/MS: Gas Chromatography, GC/Mass Spectroscopy. 3. Immunoassay screen: Semi
-quantitative method of identifying the presence of pentachlorophenol. III. Preacceptance Logic The following criteria have been developed for defining a waste as dioxin suspect. These criteria are intended to supplement existing requirements which may have been imposed through permit or other conditions with Federal or state authorities. Wastes which meet the criteria in this section will be screened for dioxin precursors. Dioxin precursors with detectable hits above 100 ppm will require dioxin testing prior to receipt at the facility. Waste considered under these criteria remains subject to all existing conditions imposed by Veolia policies and environmental directives. Dioxin Policy suspect wastes are defined as follows:ILD098642424 VEOLIA ES TECHNICAL SOLUTIONS

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8 A. Any waste from a process or remedial clean
- up for which the generator has indicated on the “Gene rator’s Waste Profile Sheet” or any other supporting documentation that dioxins are present at any level. These wastes are considered suspect if they are subject to historical contamination from dioxins B. Wastes from the following: 1. Process, by
- product or remedial clean
- ups of material from: a) Ti mber/Lumber treating facilities carrying the code K001 b) Pesticide/Herbicide manufacturing facilities carrying the code K043. C. Wastes bearing EPA hazardous waste codes: F039, K085, K105 due to their dioxin treatment standards. IV. Non
-Conforming Waste at Receipt Wh en non -conforming material meets the criteria in Section III of this policy, dioxin precursor analysis will be performed.