Document mmjvVR5yZ0on9X2MZwONxEYgk

EPA Inspection Report - Page1 of 7 Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 02/05/2024 Air Title V, NESHAP Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: Veolia ES Technical Solutions, LLC Veolia ES Technical Solutions Beaumont 7665 Highway 73 Beaumont Texas 77705 7665 Highway 73 Beaumont Texas 77705 Jefferson County 409-289-2074 Randa Coffey Environmental Compliance Supervisor randa.coffey@veolia.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 110035783658 O1509 48-245-00118 562211 4953 Personnel participating in inspection: Justin Chen Region 6 ECDAT Benjamin Donaldson Region 6 ECDAT Kenneth McPherson Region 6 ECDAT Daniel Hoyt OECA AED Nathan Hicks OECA AED Richard Helmich NEIC Philip Myer NEIC Ron Constance Veolia Dietrich Hovener Veolia Daniel Schofield Veolia Randa Coffey Veolia Environmental Engineer Environmental Engineer Life Scientist Environmental Engineer Physical Scientist Chemist Mechanical Engineer Plant Manager Incineration Manager Health and Safety Manager Environmental Supervisor EPA Lead Inspector Signature/Date JUSTIN CHEN Digitally signed by JUSTIN CHEN Date: 2024.04.15 08:03:06 -05'00' Justin Chen Date Supervisor Signature/Date JAMES LEATHERS Date: 2024.04.15 08:09:03 -05'00' Digitally signed by JAMES LEATHERS James Leathers Date 6ENFORM-019-R8.2 (02/12/2020) 1 EPA Inspection Report - Page2 of 7 Section I - INTRODUCTION Veolia ES Technical Solutions / Beaumont Inspection Date 02/05/2024 PURPOSE OF THE INSPECTION EPA inspectors Justin Chen (R6 ECDAT), Benjamin Donaldson (R6 ECDAT), Kenneth McPherson (R6 ECDAT), Daniel Hoyt (OECA AED), and Nathan Hicks (OECA AED) accompanied by Philip Myers and Richard Helmich (National Enforcement Investigations Center, "NEIC") arrived at the Veolia ES Technical Solutions Beaumont ("Veolia") at 9:24 AM on February 5, 2024, for an unannounced inspection. We met with Ron Constance/Plant Manager, Dietrich Hovener/Incineration Manager, and Daniel Schofield/Health and Safety Manager. Randa Coffey, Environmental Supervisor at Veolia, joined the inspection party during the facility tour. Credentials were presented to Ron Constance and he was informed that this was an EPA inspection to evaluate potential sources of excess emissions using EPA's Geospatial Measurement of Air Pollution ("GMAP") vehicle and to evaluate compliance with the facility's Title V Air Permit and the Clean Air Act. The scope of the inspection is a partial evaluation ("PCE"). This inspection occurred as part of a multi-scale monitoring project in the Beaumont-Port Arthur area. The Opening Conference Sign-In Sheets are attached as Appendix 1. FACILITY DESCRIPTION Veolia is a Hazardous Waste Treatment and Disposal facility located near Port Arthur (Jefferson County). There are 231 employees (not including contractors) who work at the facility, which operates 8760 hours per year. The Veolia facility receives hazardous wastes and non-hazardous wastes from off-site sources. The facility also generates waste streams from its operations. Wastes received by the facility are categorized as gaseous, energetic pumpable, aqueous, non-pumpable, containerized that may be received in bulk containers (roll-off bins, end dumps, and tanker trucks) and/or smaller-volume containers such as boxes, pails, and drums. Veolia operates an Incinerator Train which consists of a 60 feet Rotary Kiln and a Secondary Combustion Chamber (SCC). This incinerator train operates approximately 8000 hours per year depending on maintenance turnover time. The facility operates under CAA Title V major source permit number O1509 issued on December 29, 2023, and a RCRA Industrial Hazardous Waste Storage and Treatment permit number HW-50212-001 issued on May 24, 2019. Section II - OBSERVATIONS The NEIC GMAP was driven by Richard Helmich and the instruments were operated by Philip Myers. Facility representatives Ron Constance, Dietrich Hovener, and Daniel Schofield led the GMAP in their vehicle. Randa Coffey, Environmental Supervisor, joined the facility representatives while we were touring the facility. Conditions were overcast and cloudy. Inspectors Justin Chen, Benjamin Donaldson, Kenneth McPherson, Daniel Hoyt, and Nathan Hicks followed the GMAP in secondary vehicles. Daniel Hoyt and Nathan Hicks operated a Data Acquisition in Real Time (DART) unit on their vehicle, equipped with a photoionization detector (PID) that measures volatile organic compounds ("VOC") in the air, and a wind monitor that monitors wind speed, wind direction and geolocation. The DART unit had a 10.6ev PID installed. The GMAP drove on all available facility roads measuring air pollutant concentrations downwind of each of the process areas, if possible. The GMAP driving tour began by driving around the 2 EPA Inspection Report - Page3 of 7 Veolia ES Technical Solutions / Beaumont Inspection Date 02/05/2024 perimeter of the entire facility. We then drove around the perimeter of the treatment, storage, and disposal facility. Downwind of the Incinerator Stack, the GMAP noted an 80 parts per billion ("ppb") reading of VOC between 10:25 to 10:40AM. The GMAP was also downwind of a barrel storage area. The DART equipped vehicle detected a 60 ppb reading of VOC at this same location and time period. We then drove by the deep well injection tank. A full report from the GMAP will be issued by NEIC at a later date. The site GMAP survey ended at 11:30AM and we returned to the administrative building. Section III - AREAS OF CONCERN Justin Chen conducted a closing conference at Veolia at 11:30AM on February 5, 2024,for the inspection. Mr. Meyers and Mr. Chen summarized the facility tour and presented their emissions observations, including the following Areas of Concern, a measurement of 80ppb of VOCs south of the stabilization building and incinerator stack. The facility made no claims of confidential business information as no documents, photos, or video were taken. We departed the facility at 11:45AM. Section IV - FOLLOW UP The following information was received by EPA on February 22, 2024, after exiting the Facility on February 5, 2024: - Number of Veolia employees at the facility (231, not including contractors). - Operating hours of the facility (8760 hours per year). - Information on the Risk Management Program ("RMP") program level of the facility ("The facility currently does not have a RMP covered process because inventory levels of all regulated substances remain below threshold quantities.") On February 29, 2024, the EPA received distributed control system ("DCS") continuous emission monitoring system ("CEMS") data pertaining to the incinerator from the facility for operations on February 5, 2024, between 10:25AM to 10:40AM. This was the period of time during which the GMAP detected an 80 ppb VOCs downwind of the incinerator stack. The DCS data included constituent chemicals that were monitored including chlorine, individual metals, polychlorinated biphenyls ("PCB"), dioxin/furans, and organic content. The data set also included total waste input feed, operating conditions of the incinerator (kiln temperature, exhaust temperature, stack flow rate, kiln pressure, and combustion efficiency), and stack CEMS measurements (carbon monoxide, hydrogen chloride, sulfur dioxide, and carbon dioxide). 3 EPA Inspection Report - Page4 of 7 Section V - LIST OF APPENDICES Veolia ES Technical Solutions / Beaumont Inspection Date 02/05/2024 There were no photos or videos taken at the facility. Appendix 1 - Opening and Closing Conference Sign-in Sheets 4 EPA Inspection Report - Page5 of 7 Veolia ES Technical Solutions / Beaumont Inspection Date 02/05/2024 Appendix 1 Opening and Closing Conference Sign-In Sheets 5 EPA Inspection Report - Page6 of 7 Veolia ES Technical Solutions / Beaumont Inspection Date 02/05/2024 6 EPA Inspection Report - Page7 of 7 Veolia ES Technical Solutions / Beaumont Inspection Date 02/05/2024 7