United States Environmental Protection Agency

Region 5

Air & Radiation Division

77 West Jackson Boulevard

Chicago, Illinois 60604

AIR POLLUTION CONTROL

TITLE V PERMIT TO OPERATE

Permit No.: V-IL-1716300103-2014-10

Issue Date: DRAFT

Effective Date: DRAFT

Expiration Date: DRAFT

In accordance with the provisions of Title V of the Clean Air Act and 40 C.F.R. Part 71,

Veolia ES Technical Solutions, L.L.C.

is authorized to operate air emission units and to conduct other air pollutant emitting activities in 

accordance with the permit conditions listed in this permit. 

This source is authorized to operate in St. Clair County at the following address:

7 Mobile Avenue, Sauget, Illinois 62201

Terms and conditions not otherwise defined in this permit have the meaning assigned to them in 

40 C.F.R. Part 71 unless other regulations or statutes are referenced. All terms and conditions of 

the permit are enforceable by EPA and citizens under the Clean Air Act.

Once effective, this permit supersedes any other permit issued to the source pursuant to Title V 

of the Clean Air Act and 40 C.F.R. Part 71.

 

 

_____________________________________ ___________________

George Czerniak, Director

Air and Radiation Division

U.S. EPA - Region 5

 Date
Veolia ES Technical Solutions, L.L.C. Page 2 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

TABLE OF CONTENTS

1.0. SOURCE IDENTIFICATION AND UNIT-SPECIFIC INFORMATION .................... 8

1.1. GENERAL SOURCE INFORMATION.......................................................................... 8

1.2. FACILITY DESCRIPTION............................................................................................. 8

1.3. EMISSION UNITS .......................................................................................................... 8

2.0. UNIT-SPECIFIC OPERATING REQUIREMENTS .................................................... 11

2.1. HAZARDOUS WASTE COMBUSTORS, UNITS 2, 3 AND 4 ................................... 11

(A) Emission Limitations and Standards...................................................................... 11

(B) Nonapplicable Regulations..................................................................................... 14

(C) Work Practice and Operational Requirements....................................................... 15

(D) Monitoring and Testing .......................................................................................... 31

(E) Recordkeeping and Reporting. ............................................................................... 73

2.2. MATERIAL PROCESSING AREAS............................................................................ 90

(A) Emission Limitations and Standards...................................................................... 90

(B) Nonapplicable Regulations..................................................................................... 91

(C) Work Practice and Operational Requirements....................................................... 92

(D) Monitoring and Testing .......................................................................................... 94

(E) Recordkeeping and Reporting ................................................................................ 99

2.3. DRUM CRUSHER......................................................................................................... 99

(A) Emission Limitations and Standards.................................................................... 100

(B) Nonapplicable Regulations................................................................................... 100

(C) Work Practice and Operational Requirements..................................................... 100

(D) Monitoring and Testing ........................................................................................ 100

(E) Recordkeeping and Reporting .............................................................................. 101

2.4. LIQUID WASTE STORAGE TANKS........................................................................ 102

(A) Emission Limitations and Standards.................................................................... 102

(B) Nonapplicable Regulations................................................................................... 104

(C) Work Practice and Operational Requirements..................................................... 105
Veolia ES Technical Solutions, L.L.C. Page 3 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(D) Monitoring and Testing ........................................................................................ 105

(E) Recordkeeping and Reporting .............................................................................. 106

2.5. BULK SOLID WASTE STORAGE FACILITY......................................................... 109

(A) Emission Limitations and Standards.................................................................... 109

(B) Nonapplicable Regulations................................................................................... 111

(C) Work Practice and Operational Requirements..................................................... 112

(D) Monitoring and Testing ........................................................................................ 112

(E) Recordkeeping and Reporting .............................................................................. 114

2.6. GASOLINE STORAGE TANK .................................................................................. 117

(A) Emission Limitations and Standards.................................................................... 117

(B) Nonapplicable Regulations................................................................................... 118

(C) Work Practice and Operational Requirements..................................................... 118

(D) Monitoring and Testing ........................................................................................ 119

(E) Recordkeeping and Reporting .............................................................................. 119

2.7. BOILER........................................................................................................................ 120

(A) Emission Limitations and Standards.................................................................... 120

(B) Nonapplicable Regulations................................................................................... 121

(C) Work Practice and Operational Requirements..................................................... 122

(D) Monitoring and Testing........................................................................................ 123

(E) Recordkeeping and Reporting .............................................................................. 124

2.8. EMERGENCY GENERATORS.................................................................................. 126

(A) Emission Limitations and Standards.................................................................... 126

(B) Nonapplicable Regulations................................................................................... 126

(C) Work Practice and Operational Requirements..................................................... 126

(D) Monitoring and Testing ........................................................................................ 130

(E) Recordkeeping and Reporting .............................................................................. 130

2.9. FUGITIVE EMISSIONS ............................................................................................. 133

(A) Emission Limitations and Standards.................................................................... 133

(B) Nonapplicable Regulations................................................................................... 134
Veolia ES Technical Solutions, L.L.C. Page 4 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(C) Work Practice and Operational Requirements..................................................... 134

(D) Monitoring and Testing ........................................................................................ 143

(E) Recordkeeping and Reporting .............................................................................. 146

2.10. INSIGNIFICANT EMISSION UNITS AND ACTIVITIES ..................................... 148

(A) List of Insignificant Emission Units and Activities ............................................. 148

(B) Applicable Requirements..................................................................................... 149

(C) Compliance with Applicable Requirements......................................................... 149

3.0. FACILITY-WIDE PERMIT REQUIREMENTS......................................................... 150

3.1. GENERAL PART 71 RECORDKEEPING................................................................. 150

(A) Required Records................................................................................................. 150

(B) Record Retention Schedule .................................................................................. 150

(C) Emissions Calculation Methodology.................................................................... 150

3.2. GENERAL PART 71 REPORTING............................................................................ 151

(A) Semi-annual Reports ............................................................................................ 151

(B) Deviations............................................................................................................. 152

3.3. PERFORMANCE TESTING....................................................................................... 153

3.4. FACILITY-WIDE APPLICABLE REQUIREMENTS............................................... 154

(A) Fugitive Particulate Matter Restrictions............................................................... 154

(B) Open Burning Prohibitions................................................................................... 154

(C) Visible Emissions................................................................................................. 154

(D) Recycling and Emissions Reduction .................................................................... 154

(E) Risk Management Plan (RMP)............................................................................. 155

(F) Episode Action Plans............................................................................................ 155

(G) Annual Benzene Waste Quantity Determination ................................................. 155

(H) General Prohibition on Air Pollution ................................................................... 156

(I) Facility-wide Testing............................................................................................ 156

(J) Facility-wide Recordkeeping ............................................................................... 160

4.0. GENERAL PART 71 REQUIREMENTS..................................................................... 163
Veolia ES Technical Solutions, L.L.C. Page 5 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

4.1. DEFINITIONS ............................................................................................................. 163

4.2. ANNUAL FEE PAYMENT......................................................................................... 163

4.3. COMPLIANCE STATEMENT ................................................................................... 165

4.4. COMPLIANCE CERTIFICATIONS........................................................................... 165

4.5. SCHEDULE OF COMPLIANCE ................................................................................ 166

4.6. DUTY TO PROVIDE AND SUPPLEMENT INFORMATION................................. 166

4.7. ENFORCEABILITY.................................................................................................... 167

4.8. SUBMISSIONS............................................................................................................ 167

4.9. SEVERABILITY CLAUSE......................................................................................... 167

4.10. PERMIT ACTIONS ................................................................................................... 167

4.11. ADMINISTRATIVE PERMIT AMENDMENTS..................................................... 168

4.12. MINOR PERMIT MODIFICATIONS....................................................................... 168

4.13. SIGNIFICANT PERMIT MODIFICATIONS........................................................... 168

4.14. REOPENING FOR CAUSE....................................................................................... 168

4.15. PROPERTY RIGHTS ................................................................................................ 168

4.16. INSPECTION AND ENTRY..................................................................................... 168

4.17. EMERGENCY PROVISIONS................................................................................... 169

4.18. OFF PERMIT CHANGES ......................................................................................... 170

4.19. PERMIT EXPIRATION AND RENEWAL .............................................................. 170

4.20. OPERATIONAL FLEXIBILITY............................................................................... 171

4.21. PERMIT SHIELD ...................................................................................................... 171

4.22. CREDIBLE EVIDENCE ........................................................................................... 172
Veolia ES Technical Solutions, L.L.C. Page 6 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

Abbreviations and Acronyms

ASTM American Society for Testing and Materials

CAA or Act Clean Air Act [42 U.S.C. § 7401 et seq.]

CEM Continuous Emission Monitor

CEMS Continuous Emissions Monitoring System

C.F.R. Code of Federal Regulations

CMS Continuous Monitoring System

CO Carbon Monoxide

COM Continuous Opacity Monitor

CPMS Continuous Parametric Monitoring System

DOC Documentation of Compliance

DRE Destruction and removal efficiency 

EPA United States Environmental Protection Agency

ESV Emergency Safety Vent

EU Emission Unit

Facility Veolia ES Technical Solutions, L.L.C.

gal gallon

g grams

gr/scf grains per standard cubic foot of exhaust gas

HAP Hazardous Air Pollutant

hr hour

HWC hazardous waste combustor

IAC Illinois Administrative Code

IEPA Illinois Environmental Protection Agency

kg kilogram

kpa kilo pascals

lb pound

LVM Low Volatile Metals (Arsenic, Chromium and Beryllium)

MACT Maximum Achievable Control Technology

μg/dscm micrograms per dry standard cubic meter of exhaust gas

Mg megagram

MMBtu million British Thermal Units

NESHAP National Emission Standards for Hazardous Air Pollutants

ng TEQ/dscm nanograms toxicity equivalents per dry standard cubic meter of exhaust 

gas

NOC Notification of Compliance

NOx Nitrogen Oxides

NSPS New Source Performance Standard

NSR New Source Review

Operator Veolia ES Technical Solutions, L.L.C.

Permittee Veolia ES Technical Solutions, L.L.C.

PM Particulate Matter

PM10 Particulate matter less than 10 microns in diameter

ppm parts per million
Veolia ES Technical Solutions, L.L.C. Page 7 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

POHC principle organic hazardous constituent

PSD Prevention of Significant Deterioration

Psi Pounds per square inch

SO2 Sulfur Dioxide

SVM Semivolatile Metals (Lead and Cadmium)

tpy tons per year

VOC Volatile Organic Compounds

VHAP Volatile Hazardous Air Pollutant
Veolia ES Technical Solutions, L.L.C. Page 8 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

1.0. SOURCE IDENTIFICATION AND UNIT-SPECIFIC 

INFORMATION

1.1. GENERAL SOURCE INFORMATION

Parent Company: Veolia ES Technical Solutions, L.L.C.

700 E. Butterfield Road

Lombard, Illinois 60148

Facility: Veolia ES Technical Solutions, L.L.C.

7 Mobile Avenue

Sauget, Illinois 62201

County: St. Clair

SIC Code: 4953

AFS Plant Identification Number: 1716300103

1.2. FACILITY DESCRIPTION 

Veolia ES Technical Solutions, L.L.C. is a treatment, storage, and disposal facility, which 

accepts offsite waste for further disposal through incineration. Containers and bulk 

shipments of hazardous and solid wastes are received, analyzed, transferred to temporary 

storage facilities, processed, and incinerated in one of three combustion units.

1.3. EMISSION UNITS

The emissions units located at the facility at the time of permit issuance are:

Emission

Unit Description

Manufacturer

/Model

Date of 

Construction

Emission Control 

Equipment

Hazardous 

Waste 

Combustors

Incineration Unit #2 

(Incinerator) with a 

Maximum Heat 

Capacity of 

16 mmBtu/hr

Trade Waste 

Incineration, TWI2000, Series 2

October 1986 Joy-Niro Spray 

Dryer Absorber 

(SDA-2), Pulse Flo 

Fabric Filter (BH-2)
Veolia ES Technical Solutions, L.L.C. Page 9 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

Emission

Unit Description

Manufacturer

/Model

Date of 

Construction

Emission Control 

Equipment

Incineration Unit #3 

(Incinerator) with a 

Maximum Heat 

Capacity of 

16 mmBtu/hr

Trade Waste 

Incineration, TWI2000, Series 2

November 1987 Joy-Niro Spray 

Dryer Absorber 

(SDA-3), Pulse Flo 

Fabric Filter (BH-3)

Incineration Unit #4

(Rotary Kiln) with a 

Maximum Heat 

Capacity of

50 mmBtu/hr

International Waste 

Energy, PY*ROX

June 1988 Tempering 

Chamber, Activated 

Carbon Injection,

Spray Dryer 

Absorber, Fabric 

Filter

Material 

Processing 

Areas

Waste Processing 

Units (Area 1 and 

Area 2)

1988

None

Lab Pack Repack 

Unit

1988

Drum 

Crusher

Empty drums are 

crushed

1984 None

Storage 

Tanks for 

Liquid 

Wastes 

Tanks #2 (4,391 

gals), #4 (4,931 gals), 

#6 (7,200 gals), #8 

(5,820 gals), #10 

(12,869 gals), #20 

(12,869 gals), #30 

(12,869 gals), #40 

(12,869 gals), #50 

(12,869 gals), #60 

(12,869 gals), #300 

(19,850 gals), #302 

(30,000 gals), #304 

(30,000 gals), #306 

(30,000 gals), #308 

(30,000 gals), #310 

(30,000 gals), #312 

(10,000 gals) and 

#314 (10,000 gals)

Modern Welding April 2002 for 

#2 and #4; June 

2004 for #10 

and #20; March 

2009 for #30; 

1988 for the 

others.

Activated Carbon 

Absorption Systems 

on each storage tank 

vent.

Storage tank for #2 

fuel oil: Tank #390

(30,000 gals)

Modern Welding 1988 None

Bulk Solid 

Waste 

Temporary storage of 

bulk solid wastes in 

pits prior to being fed 

1988 Cyclone, Airtol 

Baghouse (BF BldgBH-1), Carbon 
Veolia ES Technical Solutions, L.L.C. Page 10 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

Emission

Unit Description

Manufacturer

/Model

Date of 

Construction

Emission Control 

Equipment

Storage 

Facility

to Incineration Unit 

#4

Adsorption Unit (BF

Bldg-CA)

Gasoline 

Storage Tank

550 gallon tank, 

equipped with 

submerged loading 

pipe

June 2012 None

Boiler Natural Gas-Fired 

Boiler with a 

Maximum Heat 

Capacity of 

10.6 mmBtu/hr

(Boiler #1)

Cleaver Brooks, 

250

November 1995 None

Emergency 

Generators 

(2)

Two #2 Fuel oil-fired 

Emergency 

Generators each with 

Maximum Heat 

Capacity of 

0.40 mmBtu/hr (<112 

kilowatts (kW))

1988 None

Fugitive 

Emissions

Pumps, Valves, 

Open-End Lines and 

Compressors

N/A None
Veolia ES Technical Solutions, L.L.C. Page 11 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

2.0. UNIT-SPECIFIC OPERATING REQUIREMENTS

2.1. HAZARDOUS WASTE COMBUSTORS, UNITS 2, 3 AND 4

(A) Emission Limitations and Standards [40 C.F.R. § 71.6(a)(1)]

The Permittee shall comply with the following requirements at each individual 

incinerator unless specified otherwise:

1. Visible Emission Limitations. 

(a) The Permittee shall not cause or allow from any emission source the 

emission into the atmosphere of smoke or other particulate matter with an 

opacity greater than 30 percent, except as allowed by 35 IAC 212.123(b) 

and 212.124. [35 IAC 212.123(a)]

(b) The Permittee shall not cause or allow from any process, including any 

material handling or storage activity, the emission of fugitive particulate 

matter that is visible by an observer looking generally overhead at a point 

beyond the property line of the source unless the wind speed is greater than 

40.2 kilometers per hour (25 miles per hour). [35 IAC 212.301 and 

212.314]

2. Sulfur Dioxide Limitations.

Total sulfur dioxide emissions from the facility shall not exceed 7.7 tons per year

(tpy) from Unit 2, 7.7 tpy from Unit 3, and 50.76 tpy from Unit 4. [Construction 

Permits 87100024 and 88010001]

3. Carbon Monoxide Limitations.

(a) The Permittee shall not allow emissions of carbon monoxide in excess of 

100 parts per million (ppm) by volume, on an hourly rolling average 

(monitored continuously with a continuous emissions monitoring system), 

dry basis and corrected to 7 percent oxygen. The Permittee must also 

document that, during the destruction and removal efficiency test runs or 

their equivalent as provided by 40 C.F.R. § 63.1206(b)(7), hydrocarbons do 

not exceed 10 ppm by volume during those runs, on an hourly rolling 

average (monitored continuously with a continuous emissions monitoring 

system), dry basis, corrected to 7 percent oxygen, and reported as propane. 

[40 C.F.R. § 63.1219(a)(5)]

(b) The Permittee shall not allow emissions of carbon monoxide from any

incinerator in excess of 500 ppm corrected to 50 percent excess air. [35 

IAC 216.141, Construction Permits 83120053, 87100024 and 88010001]
Veolia ES Technical Solutions, L.L.C. Page 12 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(c) The Permittee shall not allow emissions of carbon monoxide in excess of 

6.6 tpy from Unit 2, 6.6 tpy from Unit 3 and 13.86 tpy from Unit 4. 

[Construction Permits 87100024 and 88010001]

4. Particulate Matter Limitations.

(a) The Permittee shall not cause or allow the emission of particulate matter 

into the atmosphere from any incinerator burning more than 0.907 

megagram per hour (Mg/hr; 2,000 pounds per hour (lb/hr)) but less than 

27.2 Mg/hr (60,000 lb/hr) of refuse to exceed 183 milligrams per standard 

cubic meter (mg/scm; 0.08 grain per standard cubic foot (gr/scf)) of 

effluent gases corrected to 12 percent carbon dioxide. [35 IAC 212.181(b), 

Construction Permit 83120053]

(b) The Permittee shall not allow emissions of particulate matter from the 

facility in excess of 0.013 gr/dscf, corrected to 7 percent oxygen.

[40 C.F.R. § 63.1219(a)(7)]

(c) The Permittee shall not allow emissions of total suspended particulate 

matter from the facility in excess of 15.0 tpy from Unit 2, 15.0 tpy from

Unit 3, and 16.92 tpy from Unit 4. [Construction Permits 87100024 and 

88010001]

5. Volatile Organic Compounds Limitations.

(a) The Permittee shall not cause or allow the discharge of more than 3.6 kg/hr 

(8 lbs/hr) of organic material into the atmosphere from any emission unit, 

except that, if no odor nuisance exists, this limitation shall apply only to 

photochemically reactive material. Alternatively, the Permittee may use a 

control device to reduce such emissions either to 10 ppm equivalent 

methane (molecular weight 16) or less, or to convert 85 percent of the 

hydrocarbons to carbon dioxide and water. [35 IAC 219.301, 219.302]

(b) Organic material emissions from the facility shall not exceed 0.9 tpy from

Unit 2, 0.9 tpy from Unit 3, and 3.1 tpy from Unit 4. [Construction Permits 

87100024 and 88010001]

6. Nitrogen Oxide Limitations.

Nitrogen oxide emissions from the facility shall not exceed 4.0 tpy from Unit 2, 

4.0 tpy from Unit 3, and 61.6 tpy from Unit 4. [Construction Permits 87100024 

and 88010001]

7. Hazardous Air Pollutant Limitations.
Veolia ES Technical Solutions, L.L.C. Page 13 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(a) The Permittee shall not allow emissions of dioxins and furans from the 

facility in excess of 0.20 nanograms toxicity equivalents per dry standard 

cubic meter (ng TEQ/dscm), corrected to 7 percent oxygen. [40 C.F.R. 

§ 63.1219(a)(1)]

(b) The Permittee shall not allow emissions of mercury from the facility in 

excess of 130 micrograms per dry standard cubic meter (μg/dscm), 

corrected to 7 percent oxygen. [40 C.F.R. § 63.1219(a)(2)]

(c) The Permittee shall not allow combined emissions of cadmium and lead 

from the facility in excess of 230 μg/dscm, corrected to 7 percent oxygen. 

[40 C.F.R. § 63.1219(a)(3)]

(d) The Permittee shall not allow combined emissions of arsenic, beryllium, 

and chromium from the facility in excess of 92 μg/dscm, corrected to 

7 percent oxygen. [40 C.F.R. § 63.1219(a)(4)]

(e) The Permittee shall design, install, operate, and maintain a treatment 

process that destroys benzene in the waste stream by incinerating the waste 

in a combustion unit that achieves a destruction efficiency of 99 percent or 

greater for benzene. [40 C.F.R. § 61.348(a)(1)(iii)]

(f) All joints or seams between the pipe sections of any transfer system that 

consists of continuous hard-piping shall be permanently or semipermanently sealed (e.g., a welded joint between two sections of metal pipe 

or a bolted and gasketed flange). [40 C.F.R. § 63.689(c)(2)]

8. Hydrogen Chloride Limitations.

(a) The Permittee shall not allow combined emissions of hydrogen chloride 

and chlorine gas (total chlorine) from the facility in excess of 32 ppm by 

volume, expressed as a chloride (Cl−) equivalent, dry basis and corrected to 

7 percent oxygen. [40 C.F.R. § 63.1219(a)(6)]

(b) The Permittee shall not allow hydrogen chloride emissions in excess of 4.0 

pounds per hour (lbs/hr) from either Unit 2 or Unit 3 or the control devices 

shall demonstrate a minimum hydrogen chloride removal efficiency of 99

percent. [Construction Permits 83120053 and 87100024]

9. Destruction and Removal Efficiency (DRE) Standard.

(a) Units 2, 3 and 4 must each achieve a DRE of 99.99 percent for each 

principle organic hazardous constituent (POHC) specified under condition 

2.1(A)(9)(c)(ii), below. The Permittee shall calculate the DRE for each 

POHC using the following equation:
Veolia ES Technical Solutions, L.L.C. Page 14 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

DRE = [1-(WOUT/WIN)] x 100%

Where:

WIN = mass feedrate of one POHC in a waste feedstream; and

WOUT = mass emission rate of the same POHC present in exhaust 

emissions prior to release to the atmosphere. 

The Permittee must perform intermediate calculations using at least three 

significant figures, but may round the resultant emission levels to two 

significant figures to document compliance. [40 C.F.R. § 63.1219(c)(1)

and (d)]

(b) For dioxin-listed hazardous wastes F020, F021, F022, F023, F026, or F027 

(see 40 C.F.R. § 261.31), Units 2, 3 and 4 must each achieve a DRE of 

99.9999 percent for each POHC specified under condition 2.1(A)(9)(c)(ii), 

below. The Permittee must demonstrate this DRE performance on POHCs 

that are more difficult to incinerate than tetra-, penta-, and 

hexachlorodibenzo-p-dioxins and dibenzofurans. The Permittee must use 

the equation in condition 2.1(A)(9)(a), above, to calculate DRE for each 

POHC. In addition, the Permittee must notify the Administrator of its 

intent to incinerate hazardous wastes F020, F021, F022, F023, F026, or 

F027. [40 C.F.R. § 63.1219(c)(2)]

(c) Principal organic hazardous constituents [40 C.F.R. § 63.1219(c)(3)]

(i) The Permittee must treat the POHCs in the waste feed that the 

Permittee specifies under condition 2.1(A)(9)(c)(ii), below, to the 

extent required by 40 C.F.R. § 63.1219(c)(1) and (c)(2). 

(ii) The Permittee must specify one or more POHCs that are 

representative of the most difficult to destroy organic compounds in 

the hazardous waste feedstream. The Permittee must base this 

specification on the degree of difficulty of incineration of the organic 

constituents in the waste and on their concentration or mass in the 

waste feed, considering the results of waste analyses or other data 

and information.

(B) Nonapplicable Regulations [40 C.F.R. § 71.6(f)(1)]

1. Units 2, 3 and 4 are not subject to 40 C.F.R. Part 64, Compliance Assurance 

Monitoring (CAM) for Major Stationary Sources, because:
Veolia ES Technical Solutions, L.L.C. Page 15 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(a) The affected units are required to comply with a NESHAP proposed after 

November 15, 1990. Emission limitations or standards proposed by the 

Administrator after November 15, 1990 pursuant to section 111 or 112 of 

the Act are exempt from CAM. [40 C.F.R. § 64.2(b)(1)(i)]

2. Units 2, 3 and 4 are not subject to 35 IAC Part 229 of the Illinois State 

Implementation Plan (SIP), “Hospital Medical Infectious Waste Incinerators,”

because the Permittee is prohibited from accepting or processing hospital 

medical infectious waste at the facility. [35 IAC 229.110]

(C) Work Practice and Operational Requirements [40 C.F.R. § 71.6(a)(1)]

1. The Permittee shall not burn hospital medical infectious waste, municipal waste, 

or waste that is subject to the Beryllium NESHAP. [42 U.S.C. § 7661c(a)] 

2. The Permittee must operate Units 2, 3 and 4 in compliance with the following 

operating parameter limits (OPLs). The Permittee must also comply with the 

OPLs contained in the Notification of Compliance (NOC) required pursuant to 

condition 2.1(E)(2), below. If any OPL contained in this condition 2.1(C)(2) 

differ from the corresponding OPL contained in the Permittee’s most recent 

NOC, the Permittee may submit an application requesting a revision to the OPLs 

in this permit, pursuant to 40 C.F.R. § 71.7(e)(1). Nothing in this permit 

obligates the Administrator to approve an application to revise OPLs in this 

permit.

Operating Parameter

OPL Averaging 

Period Unit #2 Unit #3 Unit #4

Minimum primary 

combustion chamber 

temperature (40 C.F.R. 

§ 63.1209(j)(1), (k)(2))

1,709 °F 1,709 °F 1,561 °F hourly rolling 

average

Minimum secondary 

combustion chamber 

temperature (40 C.F.R. 

§ 63.1209(j)(1), (k)(2))

1,885 °F 1,850 °F 1,881 °F hourly rolling 

average

Maximum flue gas 

flowrate or production 

rate (40 C.F.R. 

§ 63.1209(j)(2)), (k)(3), 

(m)(2), (n)(5), (o)(2))

15,310 acf/min 15,310 acf/min 37,393 acf/min hourly rolling 

average

Maximum hazardous 

waste pumpable 

feedrate rate for each 

3,107 lbs/hr 3,107 lbs/hr 3,312 lbs/hr for 

PCC and 1,203

lbs/hr for SCC

hourly rolling 

average
Veolia ES Technical Solutions, L.L.C. Page 16 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

Operating Parameter

OPL Averaging 

Period Unit #2 Unit #3 Unit #4

combustion chamber 

(40 C.F.R. 

§ 63.1209(j)(3), (k)(4))

Maximum hazardous 

waste total feedrate rate 

for each combustion 

chamber (40 C.F.R. 

§ 63.1209(j)(3), (k)(4))

4,017 lbs/hr 4,017 lbs/hr 10,632 lbs/hr 

for PCC and 

1,203 lbs/hr for 

SCC

hourly rolling 

average

Operation of waste 

firing system for each 

location where waste is 

fed to the incinerator 

(40 C.F.R. 

§ 63.1209(j)(4))

Minimum 

waste 

atomization 

pressure for 

low BTU 

waste – 15 psi

Minimum 

waste 

atomization 

pressure for 

low BTU 

waste – 15 psi

Minimum 

waste 

atomization 

pressure for 

low BTU 

waste – 15 psi

Instantaneous

Maximum temperature 

of the gas at the inlet to 

a dry particulate matter 

control device (i.e., 

baghouse inlet) 

(40 C.F.R. 

§ 63.1209(k)(1)), 

(n)(1))

420 °F 420 °F 399 °F hourly rolling 

average

Minimum carbon 

injection rate 

(40 C.F.R. 

§ 63.1209(k)(6)(i))

N/A N/A 6.2 lbs/hr hourly rolling 

average

Minimum carrier fluid 

(gas or liquid) flowrate 

or pressure drop for

activated carbon 

injection system

(40 C.F.R. 

§ 63.1209(k)(6)(ii))

N/A N/A 3.10 gal/lb Cl2 hourly rolling 

average

The brand (i.e., 

manufacturer) and type 

of carbon used during 

the comprehensive 

performance test 

(40 C.F.R. 

§ 63.1209(k)(6)(iii))

N/A N/A NORIT 

Americas Inc.

DARCO® 

FGL
Veolia ES Technical Solutions, L.L.C. Page 17 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

Operating Parameter

OPL Averaging 

Period Unit #2 Unit #3 Unit #4

Maximum total 

feedrate of mercury (40 

C.F.R. 

§ 63.1209(l)(1)(i))

0.0021 lbs/hr 0.0021 lbs/hr 0.040 lbs/hr 12-hour 

rolling 

average

Maximum ash feedrate

(40 C.F.R. 

§ 63.1209(m)(3))

503 lbs/hr 503 lbs/hr 4,777 lbs/hr 12-hour 

rolling 

average

Maximum total 

feedrate of semivolatile 

metals (40 C.F.R. 

§ 63.1209(n)(2)(ii))

62 lbs/hr 62 lbs/hr 62 lbs/hr 12-hour 

rolling 

average

Maximum total 

feedrate of low volatile 

metals (40 C.F.R. 

§ 63.1209(n)(2)(ii))

46 lbs/hr 46 lbs/hr 46 lbs/hr 12-hour 

rolling 

average

Feedrate limits for low 

volatile metals in 

pumpable feedstreams 

(40 C.F.R. 

§ 63.1209(n)(2)(vii))

46 lbs/hr 46 lbs/hr 46 lbs/hr 12-hour 

rolling 

average

Feedrate of total 

chlorine and chloride in 

all feedstreams 

(40 C.F.R. 

§ 63.1209(n)(4), (o)(1))

204 lbs/hr 204 lbs/hr 203 lbs/hr 12-hour 

rolling 

average

Minimum sorbent 

feedrate (40 C.F.R. 

§ 63.1209(o)(4)(i))

2.24 lb/lb Cl2 2.24 lb/lb Cl2 2.13 lb/lb Cl2 hourly rolling 

average

Minimum carrier fluid 

flowrate or nozzle 

pressure drop for the 

spray dry adsorber 

(40 C.F.R. § 

63.1209(o)(4)(ii))

1.90 gal/lb Cl2 1.90 gal/lb Cl2 3.10 gal/lb Cl2 hourly rolling 

average

The brand ( i.e., 

manufacturer) and type 

of sorbent used during 

the comprehensive 

performance test 

(40 C.F.R. § 63.1209 

(o)(4)(iii)(A))

Mississippi 

Lime 

Company 

Hydrated Lime 

Code MR200

Mississippi 

Lime 

Company 

Hydrated Lime 

Code MR200

Mississippi 

Lime 

Company 

Hydrated Lime 

Code MR200
Veolia ES Technical Solutions, L.L.C. Page 18 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

Operating Parameter

OPL Averaging 

Period Unit #2 Unit #3 Unit #4

Maximum combustion 

chamber pressure 

(40 C.F.R. § 

63.1209(p))

-0.01 inch H2O -0.01 inch H2O -0.01 inch H2O 5 seconds for 

Units 2 and 3 

and 

instantaneous 

for Unit 4

3. Compliance with standards. [40 C.F.R. § 63.1206(b)(1)] 

The emission standards and operating requirements derived from 40 C.F.R. 

Part 63, Subpart EEE, apply at all times except:

(a) During periods of startup, shutdown, and malfunction; and

(b) When hazardous waste is not in the combustion chamber (i.e., the 

hazardous waste feed to the combustor has been cut off for a period of time 

not less than the hazardous waste residence time) and the Permittee has 

documented in the operating record compliance with all otherwiseapplicable requirements and standards promulgated under authority of 

sections 112 (e.g., 40 C.F.R. Part 63, Subparts LLL, DDDDD, and 

NNNNN) or 129 of the Clean Air Act in lieu of the emission standards 

under 40 C.F.R. §§ 63.1203, 63.1204, 63.1205, 63.1215, 63.1216, 63.1217, 

63.1218, 63.1219, 63.1220, and 63.1221; the monitoring and compliance 

standards of 40 C.F.R. §§ 63.1206 through 63.1209, except the modes of 

operation requirements of § 63.1209(q); and the notification, reporting, and 

recordkeeping requirements of §§ 63.1210 through 63.1212.

4. Changes in design, operation, or maintenance. [40 C.F.R. § 63.1206(b)(5)]

(a) If the Permittee plans to change (as defined in 40 C.F.R. 

§ 63.1206(b)(5)(iii)) the design, operation, or maintenance practices of the 

source in a manner that may adversely affect compliance with any emission 

standard that is not monitored with a CEMS, the Permittee must not burn 

hazardous waste for more than a total of 720 hours (renewable at the 

discretion of the Administrator) and only for the purposes of pretesting or 

comprehensive performance testing. Pretesting is defined at 40 C.F.R. 

§ 63.1207(h)(2)(i) and (ii). [40 C.F.R. § 63.1206(b)(5)(i)(C)(1)]

(i) The Permittee may petition the Administrator to obtain written 

approval to burn hazardous waste in the interim prior to submitting a 

Notification of Compliance for purposes other than testing or 

pretesting. The Permittee must specify operating requirements, 
Veolia ES Technical Solutions, L.L.C. Page 19 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

including limits on operating parameters that the Permittee 

determines will ensure compliance with the emission standards of 

40 C.F.R. Part 63, Subpart EEE, based on available information. 

The Administrator will review, modify as necessary, and approve if 

warranted the interim operating requirements. [40 C.F.R. 

§ 63.1206(b)(5)(i)(C)(2)]

(ii) Nothing in this permit exempts any changes made under this 

provision from any applicable requirements under Title I of the 

CAA. [40 C.F.R. § 71.6(a)(1)]

(b) Notification. [40 C.F.R. § 63.1206(b)(5)]

The Permittee must comply with the notification requirements of condition 

2.1(E)(9), below.

5. General Operating Requirements. [40 C.F.R. § 63.1206(c)(1)] 

(a) The Permittee must operate under the operating requirements specified in 

the Documentation of Compliance (DOC) under 40 C.F.R. § 63.1211(c) or 

the NOC under 40 C.F.R. §§ 63.1207(j) and 63.1210(d), except:

(i) During performance tests under approved test plans according to 40 

C.F.R. § 63.1207(e), (f), and (g);

(ii) Under the provisions of condition 2.1(C)(3)(a) or (b), above; and

(iii) As provided by condition 2.1(C)(2), above.

(b) Documentation of Compliance. [40 C.F.R. § 63.1211(c)] 

The Permittee’s operating record must include a DOC. The DOC must 

identify the applicable emission standards under 40 C.F.R. Part 63, Subpart 

EEE, and the limits on the operating parameters under 40 C.F.R. § 63.1209 

that will ensure compliance with those emission standards.

(c) Failure to comply with the operating requirements is failure to ensure 

compliance with the emission standards of 40 C.F.R. Part 63, Subpart EEE.

6. Startup, Shutdown, and Malfunction Plan. [40 C.F.R. §§ 63.6(e)(3), 

63.1206(c)(2)]

(a) The Permittee is subject to the startup, shutdown, and malfunction plan 

requirements of 40 C.F.R. § 63.6(e)(3). [40 C.F.R. § 63.1206(c)(2)(i)]
Veolia ES Technical Solutions, L.L.C. Page 20 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(i) The Permittee must develop a written startup, shutdown, and 

malfunction plan that describes, in detail, procedures for operating 

and maintaining the source during periods of startup, shutdown, and 

malfunction; and a program of corrective action for malfunctioning 

process, air pollution control, and monitoring equipment used to 

comply with the relevant standard. The startup, shutdown, and 

malfunction plan does not need to address any scenario that would 

not cause the source to exceed an applicable emission limitation in 

the relevant standard. The purpose of the startup, shutdown, and 

malfunction plan is to:

A. Ensure that, at all times, the Permittee operates and maintains 

each affected source, including associated air pollution control 

and monitoring equipment, in a manner which satisfies the 

general duty to minimize emissions established by 40 C.F.R. 

§ 63.6(e)(1)(i);

B. Ensure that the Permittee is prepared to correct malfunctions as 

soon as practicable after their occurrence in order to minimize 

excess emissions of hazardous air pollutants; and 

C. Reduce the reporting burden associated with periods of startup, 

shutdown, and malfunction (including corrective action taken 

to restore malfunctioning process and air pollution control 

equipment to its normal or usual manner of operation). 

[40 C.F.R. § 63.6(e)(3)(i)]

(ii) The Permittee must maintain at the affected source a current startup, 

shutdown, and malfunction plan and must make the plan available 

upon request for inspection and copying by the Administrator. In 

addition, if the startup, shutdown, and malfunction plan is 

subsequently revised as provided in 40 C.F.R. § 63.6(e)(3)(viii), the 

Permittee must maintain at the affected source each previous (i.e., 

superseded) version of the startup, shutdown, and malfunction plan, 

and must make each previous version available for inspection and 

copying by the Administrator for a period of 5 years after revision of 

the plan. If at any time after adoption of a startup, shutdown, and 

malfunction plan an affected source ceases operation or is otherwise 

no longer subject to the provisions of this part, the Permittee must 

retain a copy of the most recent plan for 5 years from the date the 

source ceases operation or is no longer subject to 40 C.F.R. Part 63, 

and must make the plan available upon request for inspection and 

copying by the Administrator. Upon receipt of a written request 

from the Administrator that the Permittee submit a copy of any 
Veolia ES Technical Solutions, L.L.C. Page 21 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

startup, shutdown and malfunction plan (or portion thereof) which 

the Permittee maintains at the affected source or which is in the 

possession of the Permittee, the Permittee must promptly submit a 

copy of the requested plan (or a portion thereof) to the 

Administrator. The Permittee may elect to submit the required copy 

of any startup, shutdown, and malfunction plan to the Administrator 

in an electronic format. The Permittee may claim that any portion of 

such a startup, shutdown, and malfunction plan is confidential 

business information (CBI) entitled to protection from disclosure 

under section 114(c) of the Act or 40 C.F.R. § 2.301. If the 

Permittee makes a CBI claim, it must clearly designate in the 

submission the material which it claims as confidential. [40 C.F.R. 

§ 63.6(e)(3)(v)]

(iii) To satisfy the requirements of 40 C.F.R. § 63.6 to develop a startup, 

shutdown, and malfunction plan, the Permittee may use the affected 

source’s standard operating procedures (SOP) manual, an 

Occupational Safety and Health Administration (OSHA), or other 

plan, provided the alternative plans meet all the requirements of 40 

C.F.R. § 63.6 and the Permittee makes the alternative plans available 

for inspection when requested by the Administrator. [40 C.F.R. 

§ 63.6(e)(3)(vi)]

(iv) The Permittee must revise the startup, shutdown and malfunction 

plan if required by the Administrator to do so based on the results of 

a determination made under 40 C.F.R. § 63.6(e)(1)(i), or if the 

Administrator finds that the plan: 

A. Does not address a startup, shutdown, or malfunction event that 

has occurred;

B. Fails to provide for the operation of the source (including 

associated air pollution control and monitoring equipment) 

during a startup, shutdown, or malfunction event in a manner 

consistent with the general duty to minimize emissions 

established by 40 C.F.R. § 63.6(e)(1)(i);

C. Does not provide adequate procedures for correcting 

malfunctioning process and/or air pollution control and 

monitoring equipment as quickly as practicable; or

D. Includes an event that does not meet the definition of startup, 

shutdown, or malfunction listed in 40 C.F.R. § 63.2.

[40 C.F.R. § 63.6(e)(3)(vii)]
Veolia ES Technical Solutions, L.L.C. Page 22 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(v) The Permittee may periodically revise the startup, shutdown, and 

malfunction plan for the affected source as necessary to satisfy the 

requirements of 40 C.F.R. Part 63 or to reflect changes in equipment 

or procedures at the affected source. The Permittee may make such 

revisions to the startup, shutdown, and malfunction plan without 

prior approval by the Administrator or the permitting authority. 

However, the Permittee must report each revision to the startup, 

shutdown, and malfunction plan in the semiannual report required by 

40 C.F.R. § 63.10(d)(5). If the startup, shutdown, and malfunction 

plan fails to address or inadequately addresses an event that meets 

the characteristics of a malfunction but was not included in the 

startup, shutdown, and malfunction plan at the time the Permittee 

developed the plan, the Permittee must revise the startup, shutdown, 

and malfunction plan within 45 days after the event to include 

detailed procedures for operating and maintaining the source during 

similar malfunction events, and a program of corrective action for 

similar malfunctions of process or air pollution control and 

monitoring equipment. In the event that the Permittee makes any 

revision to the startup, shutdown, and malfunction plan which alters 

the scope of the activities at the source which are deemed to be a 

startup, shutdown, or malfunction, or otherwise modifies the 

applicability of any emission limit, work practice requirement, or 

other requirement in a standard established under 40 C.F.R. Part 63, 

the revised plan shall not take effect until after the Permittee has 

provided a written notice describing the revision to the 

Administrator. [40 C.F.R. § 63.6(e)(3)(viii)]

(vi) Any revisions made to the startup, shutdown, and malfunction plan 

in accordance with the procedures established by 40 C.F.R. Part 63 

shall not be deemed to constitute revisions to this permit, and the 

elements of the startup, shutdown, and malfunction plan shall not be 

considered an applicable requirement as defined in 40 C.F.R. §§ 70.2 

and 71.2. [40 C.F.R. § 63.6(e)(3)(ix)]

(vii) The procedures specified in the startup, shutdown, and malfunction 

plan do not fall within the permit shield provided in condition 4.21

of this permit. [40 C.F.R. § 63.6(e)(3)(ix)]

(b) The Permittee is subject to the following provisions of 40 C.F.R. 

§ 63.1206(c)(2) and (3): 

(i) The Permittee must identify in the startup, shutdown, and 

malfunction plan a projected oxygen correction factor, based on 
Veolia ES Technical Solutions, L.L.C. Page 23 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

normal operations, to use during periods of startup and shutdown. 

[40 C.F.R. § 63.1206(c)(2)(iii)]

(ii) The Permittee must record the startup, shutdown, and malfunction 

plan in the operating record. [40 C.F.R. § 63.1206(c)(2)(iv)] 

(iii) Operating under the startup, shutdown, and malfunction plan: 

[40 C.F.R. § 63.1206(c)(2)(v)(A)]

A. Compliance with automatic waste feed cutoff (AWFCO) 

requirements during malfunctions:

I. During malfunctions, the AWFCO requirements of 

condition 2.1(C)(7) of this permit continue to apply, 

except for condition 2.1(C)(7)(e). If there is an 

exceedance of a 40 C.F.R. Part 63, Subpart EEE, 

emission standard monitored by a CEMS or COMS or 

operating limit specified under 40 C.F.R. § 63.1209, the 

automatic waste feed cutoff system must immediately 

and automatically cutoff the hazardous waste feed, 

except as provided by condition 2.1(C)(7)(f) of this

permit. If the malfunction itself prevents immediate and 

automatic cutoff of the hazardous waste feed, the 

Permittee must cease feeding hazardous waste as quickly 

as possible. 

II. Although the automatic waste feed cutoff requirements 

continue to apply during a malfunction, an exceedance 

of an emission standard monitored by a CEMS or 

COMS or operating limit specified under 40 C.F.R. 

§ 63.1209 is not a violation of 40 C.F.R. Part 63, 

Subpart EEE, if the source continues to operate in 

accordance with 40 C.F.R. § 63.6(e)(1)]. [40 C.F.R. 

§ 63.1206(c)(2)(v)(A)(2)]

III. Excessive number of exceedances during malfunctions.

For each set of 10 exceedances of an emission standard 

or operating requirement while hazardous waste remains 

in the combustion chamber (i.e., when the hazardous 

waste residence time has not transpired since the 

hazardous waste feed was cutoff) during a 60-day block 

period, the Permittee must: 

(aa) Within 45 days of the 10th exceedance, complete 

an investigation of the cause of each exceedance 
Veolia ES Technical Solutions, L.L.C. Page 24 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

and evaluation of approaches to minimize the 

frequency, duration, and severity of each 

exceedance, and revise the startup, shutdown, and 

malfunction plan as warranted by the evaluation 

to minimize the frequency, duration, and severity 

of each exceedance; and 

(bb) Record the results of the investigation and 

evaluation in the operating record, and include a 

summary of the investigation and evaluation, and 

any changes to the startup, shutdown, and 

malfunction plan, in the excess emissions report 

required under condition 2.1(D) of this permit and 

40 C.F.R. § 63.10(e)(3). [40 C.F.R. 

§ 63.1206(c)(2)(v)(A)]

B. Compliance with AWFCO requirements when burning 

hazardous waste during startup and shutdown: [40 C.F.R. 

§ 63.1206(c)(2)(v)(B)]

I. If the Permittee feeds hazardous waste during startup or 

shutdown, the Permittee must include waste feed 

restrictions (e.g., type and quantity), and other 

appropriate operating conditions and limits in the 

startup, shutdown, and malfunction plan. [40 C.F.R. 

§ 63.1206(c)(2)(v)(B)(1)]

II. The Permittee must interlock the operating limits 

established under condition 2.1(C)(6)(iii)(B)(1), above, 

with the automatic waste feed cutoff system required 

under condition 2.1(C)(7), except for condition

2.1(C)(7)(e). [40 C.F.R. § 63.1206(c)(2)(v)(B)(2)]

III. When feeding hazardous waste during startup or 

shutdown, the automatic waste feed cutoff system must 

immediately and automatically cutoff the hazardous 

waste feed if the Permittee exceeds the operating limits 

established under condition 2.1(C)(6)(b)(iii)(B)(1) of 

this permit, except as provided by condition 2.1(C)(7). 

[40 C.F.R. § 63.1206(c)(2)(v)(B)(3)]

IV. Although the automatic waste feed cutoff requirements 

of 40 C.F.R. § 63.1206 (c)(2)(v)(B)(4) apply during 

startup and shutdown, an exceedance of an emission 

standard or operating limit is not a violation of Subpart 
Veolia ES Technical Solutions, L.L.C. Page 25 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

EEE if the Permittee operates in accordance with 40 

C.F.R. § 63.6(e)(1). [40 C.F.R. 

§ 63.1206(c)(2)(v)(B)(4)]

(c) The Permittee shall not cause or allow the continued operation of an 

emission source during malfunction or breakdown of the emission source 

or related air pollution control equipment if such operation would cause a 

violation of the standards or limitations set forth in the Illinois 

Administrative Code, Subchapter c: Emission Standards and Limitations 

for Stationary Sources. The Permittee shall not cause or allow violation of 

the standards or limitations set forth in Subchapter c: Emission Standards 

and Limitations for Stationary Sources during startup. [35 IAC 201.149]

7. Automatic waste feed cutoff (AWFCO). [40 C.F.R. § 63.1206(c)(3)] 

(a) The Permittee must operate the hazardous waste combustor with a 

functioning AWFCO system that immediately and automatically cuts off 

the hazardous waste feed, except as provided by condition 2.1(C)(7)(f): 

(i) When any of the following are exceeded: Operating parameter limits 

specified under condition 2.1(C) of this permit and 40 C.F.R. 

§ 63.1209; an emission standard monitored by a CEMS; and the 

allowable combustion chamber pressure;

(ii) When the span value of any CMS detector, except a CEMS, is met or 

exceeded;

(iii) Upon malfunction of a CMS monitoring an operating parameter limit 

specified under condition 2.1(C) of this permit and 40 C.F.R. 

§ 63.1209 or an emission level; or 

(iv) When any component of the AWFCO system fails. [40 C.F.R. 

§ 63.1206(c)3)(i)]

(b) Ducting of combustion gases. During an AWFCO, the Permittee must 

continue to duct combustion gasses to the air pollution control system 

while hazardous waste remains in the combustion chamber (i.e., if the 

hazardous waste residence time has not transpired since the hazardous 

waste feed cutoff system was activated). [40 C.F.R. § 63.1206(c)(3)(ii)]

(c) Restarting waste feed. The Permittee must continue to monitor during the 

cutoff the operating parameters for which limits are established under 

condition 2.1(C) of this permit and 40 C.F.R. § 63.1209 and the emissions 

required under that section to be monitored by a CEMS, and must not 

restart the hazardous waste feed until the operating parameters and 
Veolia ES Technical Solutions, L.L.C. Page 26 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

emission levels are within the specified limits. [40 C.F.R. 

§ 63.1206(c)(3)(iii)]

(d) Failure of the AWFCO system. If the AWFCO system fails to 

automatically and immediately cut off the flow of hazardous waste upon 

exceedance of a parameter required to be interlocked with the AWFCO 

system under condition 2.1(C)(7)(a), the Permittee has failed to comply 

with the AWFCO requirements of condition 2.1(C)(7). If an equipment or 

other failure prevents immediate and automatic cutoff of the hazardous 

waste feed, however, the Permittee must cease feeding hazardous waste as 

quickly as possible. [40 C.F.R. § 63.1206(c)(3)(iv)] 

(e) Corrective measures. If, after any AWFCO, there is an exceedance of an 

emission standard or operating requirement, irrespective of whether the 

exceedance occurred while hazardous waste remained in the combustion 

chamber (i.e., whether the hazardous waste residence time has transpired 

since the hazardous waste feed cutoff system was activated), the Permittee 

must investigate the cause of the AWFCO, take appropriate corrective 

measures to minimize future AWFCOs, and record the findings and 

corrective measures in the operating record. [40 C.F.R. § 63.1206(c)(3)(v)]

(f) Ramping down waste feed. [40 C.F.R. § 63.1206(c)(3)(viii)]

(i) The Permittee may ramp down the waste feedrate of pumpable 

hazardous waste over a period not to exceed 1 minute, except as 

provided by condition 2.1(C)(7)(f)(ii) of this permit, below. If the 

Permittee elects to ramp down the waste feed, the Permittee must 

document ramp down procedures in the operating and maintenance 

plan. The procedures must specify that the ramp down begins 

immediately upon initiation of AWFCO and the procedures must 

prescribe a bona fide ramping down. If an emission standard or 

operating limit is exceeded during the ramp down, the Permittee has

failed to comply with the emission standards or operating 

requirements of 40 C.F.R. Part 63, Subpart EEE.

(ii) If the AWFCO is triggered by an exceedance of any of the following 

operating limits, the Permittee may not ramp down the waste feed 

cutoff: minimum combustion chamber temperature, maximum 

hazardous waste feedrate, or any hazardous waste firing system 

operating limits that may be established for its combustor.

(g) Compliance with the AWFCO requirements in 40 C.F.R. Part 63, Subpart 

EEE, will assume compliance with the requirements for a waste feed cutoff 

interlock system and sensors required by construction permits 87100024, 

88010001, and 83120053. [40 C.F.R. § 71.6(a)(3)(i)(A)]
Veolia ES Technical Solutions, L.L.C. Page 27 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

8. Emergency safety vent (ESV) openings. [40 C.F.R. § 63.1206(c)(4)]

(a) Failure to meet standards. If an ESV opens when hazardous waste remains 

in the combustion chamber (i.e., when the hazardous waste residence time 

has not expired) during an event other than a malfunction as defined in the 

startup, shutdown, and malfunction plan such that combustion gases are not 

treated as during the most recent comprehensive performance test (e.g., if 

the combustion gas by-passes any emission control device that was 

operating during the performance test), the Permittee must document in the 

operating record whether the source remained in compliance with the 

emission standards of 40 C.F.R. Part 63, Subpart EEE, considering 

emissions during the ESV opening event. [40 C.F.R. § 63.1206(c)(4)(i)]

(b) ESV operating plan. [40 C.F.R. § 63.1206(c)(c)(4)(ii)]

 

(i) The Permittee must develop an ESV operating plan, comply with the 

operating plan, and keep the plan in the operating record. 

(ii) The ESV operating plan must provide detailed procedures for rapidly 

stopping the waste feed, shutting down the combustor, and, if 

feasible, maintaining temperature and negative pressure in the 

combustion chamber during the hazardous waste residence time.

The plan must include calculations, information and data 

documenting the effectiveness of the plan's procedures for ensuring 

that combustion chamber temperature and negative pressure are 

maintained as is reasonably feasible. 

(c) Corrective measures. After any ESV opening that results in a failure to 

meet the emission standards as defined in condition 2.1(C)(8)(a) of this 

permit, the Permittee must investigate the cause of the ESV opening, take 

appropriate corrective measures to minimize such future ESV openings, 

and record the findings and corrective measures in the operating record. 

[40 C.F.R. § 63.1206(c)(4)(iii)]

9. Combustion system leaks. [40 C.F.R. § 63.1206(c)(5)]

(a) The Permittee must control combustion system leaks of hazardous air 

pollutants by maintaining the maximum combustion zone pressure lower 

than ambient pressure using an instantaneous monitor; and [40 C.F.R. 

§ 63.1206(c)(5)(i)(B)]

(b) The Permittee must specify in the performance test work plan and NOC

the method that it will use to control combustion system leaks. Because 

the Permittee controls combustion system leaks by maintaining the 
Veolia ES Technical Solutions, L.L.C. Page 28 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

combustion zone pressure lower than ambient pressure using an 

instantaneous monitor, the Permittee must also specify in the performance 

test work plan and NOC the monitoring and recording frequency of the 

pressure monitor, and specify how the monitoring approach is integrated 

into the automatic waste feed cutoff system. [40 C.F.R. 

§ 63.1206(c)(5)(ii)]

10. Operator training and certification. [40 C.F.R. § 63.1206(c)(6)]

(a) The Permittee must establish training programs for all categories of 

personnel whose activities may reasonably be expected to directly affect 

emissions of hazardous air pollutants from the source. Such persons 

include, but are not limited to, chief facility operators, control room 

operators, continuous monitoring system operators, persons that sample 

and analyze feedstreams, persons that manage and charge feedstreams to 

the combustor, persons that operate emission control devices, and ash and 

waste handlers. Each training program shall be of a technical level 

commensurate with the person's job duties specified in the training 

manual. Each commensurate training program shall require an 

examination to be administered by the instructor at the end of the training 

course. Passing of this test shall be deemed the “certification” for 

personnel, except that, for control room operators, the training and 

certification program shall be as specified in conditions 2.1(C)(10)(c) 

through (e) of this permit. [40 C.F.R. § 63.1206(c)(6)(i)]

(b) The Permittee must ensure that the source is operated and maintained at all 

times by persons who are trained and certified to perform these and any 

other duties that may affect emissions of hazardous air pollutants. A 

certified control room operator must be on duty at the site at all times the 

source is in operation. [40 C.F.R. § 63.1206(c)(6)(ii)]

(c) Hazardous waste incinerator control room operators must: [40 C.F.R. 

§ 63.1206(c)(6)(iii)]

(i) Be trained and certified under a site-specific, source-developed and 

implemented program that meets the requirements of condition

2.1(C)(10)(d), below; or 

(ii) Be trained under the requirements of, and certified under, one of the 

following American Society of Mechanical Engineers (ASME) 

standards: QHO-1-1994, QHO-1a-1996, or QHO-1-2004 (Standard 

for the Qualification and Certification of Hazardous Waste 

Incinerator Operators). If the Permittee elects to use the ASME 

program:
Veolia ES Technical Solutions, L.L.C. Page 29 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

A. Control room operators must, prior to the compliance date, 

achieve provisional certification, and must submit an 

application to ASME and be scheduled for the full certification 

exam. Within 1 year of the compliance date, control room 

operators must achieve full certification; 

B. New operators and operators of new sources must, before 

assuming their duties, achieve provisional certification, and 

must submit an application to ASME, and be scheduled for the 

full certification exam. Within 1 year of assuming their duties, 

these operators must achieve full certification; or 

(iii) Be trained and certified under a State program. 

(d) Site-specific, source developed and implemented training programs for 

control room operators must include the following elements: 

(i) Training on the following subjects:

A. Environmental concerns, including types of emissions;

B. Basic combustion principles, including products of 

combustion;

C. Operation of the specific type of combustor used by the 

operator, including proper startup, waste firing, and shutdown 

procedures; 

D. Combustion controls and continuous monitoring systems;

E. Operation of air pollution control equipment and factors 

affecting performance;

F. Inspection and maintenance of the combustor, continuous 

monitoring systems, and air pollution control devices;

G. Actions to correct malfunctions or conditions that may lead to 

malfunction;

H. Residue characteristics and handling procedures; and

I. Applicable federal, state, and local regulations, including 

Occupational Safety and Health Administration workplace 

standards; and 
Veolia ES Technical Solutions, L.L.C. Page 30 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(ii) An examination designed and administered by the instructor; and

(iii) Written material covering the training course topics that may serve 

as reference material following completion of the course. 

[40 C.F.R. § 63.1206(c)(6)(v)]

(e) To maintain control room operator qualification under a site-specific, 

source developed and implemented training program as provided by 

condition 2.1(C)(10)(d), above, control room operators must complete an 

annual review or refresher course covering, at a minimum, the following 

topics:

(i) Update of regulations;

(ii) Combustor operation, including startup and shutdown procedures, 

waste firing, and residue handling;

(iii) Inspection and maintenance;

(iv) Responses to malfunctions or conditions that may lead to 

malfunction; and

(v) Operating problems encountered by the operator. 

[40 C.F.R. § 63.1206(c)(6)(vi)]

(f) The Permittee must record the operator training and certification program 

in the operating record. [40 C.F.R. § 63.1206(c)(6)(vii)]

11. Operation and maintenance plan. [40 C.F.R. § 63.1206(c)(7)]

(a) The Permittee must prepare and at all times operate according to an 

operation and maintenance (O&M) plan that describes in detail procedures 

for operation, inspection, maintenance, and corrective measures for all 

components of the combustor, including associated pollution control 

equipment, that could affect emissions of regulated hazardous air 

pollutants. [40 C.F.R. § 63.1206(c)(7)(i)]

(b) The plan must prescribe how the Permittee will operate and maintain the 

combustor in a manner consistent with good air pollution control practices 

for minimizing emissions at least to the levels achieved during the 

comprehensive performance test. [40 C.F.R. § 63.1206(c)(7)(ii)]
Veolia ES Technical Solutions, L.L.C. Page 31 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(c) This plan ensures compliance with the operation and maintenance 

requirements of 40 C.F.R. § 63.6(e) and minimizes emissions of 

pollutants, automatic waste feed cutoffs, and malfunctions. [40 C.F.R. 

§ 63.1206(c)(7)(iii)]

(d) The Permittee must record the plan in the operating record. [40 C.F.R. 

§ 63.1206(c)(7)(iv)]

(D) Monitoring and Testing [40 C.F.R. § 71.6(a)(3)(i)(A)]

1. Continuous emissions monitoring systems (CEMS) and continuous opacity 

monitoring systems (COMS). [40 C.F.R. § 63.1209(a)]:

(a) The Permittee must use either a carbon monoxide or hydrocarbon CEMS 

to demonstrate and monitor compliance with the carbon monoxide or 

hydrocarbon standard. The Permittee must also use an oxygen CEMS to 

continuously correct the carbon monoxide measurements to 7 percent 

oxygen. 

(b) After such time as the EPA promulgates all performance specifications 

and operational requirements applicable to PM CEMS, the Permittee must 

install, calibrate, maintain, and operate a PM CEMS to demonstrate and 

monitor compliance with the particulate matter standards under this 

permit. 

(c) Performance specifications. The Permittee must install, calibrate, 

maintain, and continuously operate all CEMS and COMS in compliance 

with the quality assurance procedures provided in the appendix to 40 

C.F.R. Part 63, Subpart EEE, and Performance Specifications 1 (opacity), 

4B (carbon monoxide and oxygen), and 8A (hydrocarbons) in Appendix B 

to 40 C.F.R. Part 60.

(d) Carbon monoxide readings exceeding the span should be recorded in 

accordance with the following requirements of 40 C.F.R. § 63.1209(a)(3):

(i) Except as provided by 40 C.F.R. § 63.1209(a)(3)(ii), if a carbon 

monoxide CEMS detects a response that results in a 1-minute 

average at or above the 3,000 ppmv span level required by 

Performance Specification 4B in Appendix B to 40 C.F.R. Part 60, 

the Permittee must record the 1-minute average as 10,000 ppmv. 

The Permittee must use the 1-minute 10,000 ppmv value for 

calculating the hourly rolling average carbon monoxide level.

(ii) Carbon monoxide CEMS that use a span value of 10,000 ppmv when 

1-minute carbon monoxide levels are equal to or exceed 3,000 ppmv 
Veolia ES Technical Solutions, L.L.C. Page 32 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

are not subject to 40 C.F.R. § 63.1209(a)(3)(i). Carbon monoxide 

CEMS that use a span value of 10,000 are subject to the same CEMS 

performance and equipment specifications when operating in the 

range of 3,000 ppmv to 10,000 ppmv that are provided by 

Performance Specification 4B for other carbon monoxide CEMS, 

except:

A. Calibration drift must be less than 300 ppmv; and

B. Calibration error must be less than 500 ppmv.

(e) Hydrocarbon readings exceeding the span. 

(i) Except as provided by 40 C.F.R. § 63.1209(a)(4)(ii), if a 

hydrocarbon CEMS detects a response that results in a 1-minute 

average at or above the 100 ppmv span level required by 

Performance Specification 8A in Appendix B to 40 C.F.R. Part 60, 

the Permittee must record the 1-minute average as 500 ppmv. The 

Permittee must use the 1-minute 500 ppmv value for calculating the 

hourly rolling average hydrocarbon level.

(ii) Hydrocarbon CEMS that use a span value of 500 ppmv when 

1-minute hydrocarbon levels are equal to or exceed 100 ppmv are 

not subject to 40 C.F.R. § 63.1209(a)(4)(i). Hydrocarbon CEMS that 

use a span value of 500 ppmv are subject to the same CEMS 

performance and equipment specifications when operating in the 

range of 100 ppmv to 500 ppmv that are provided by Performance 

Specification 8A in Appendix B to 40 C.F.R. Part 60 for other 

hydrocarbon CEMS, except:

A. The zero and high-level calibration gas must have a 

hydrocarbon level of between 0 and 100 ppmv, and between 

250 and 450 ppmv, respectively;

B. The strip chart recorder, computer, or digital recorder must be 

capable of recording all readings within the CEM measurement 

range and must have a resolution of 2.5 ppmv;

C. The CEMS calibration must not differ by more than ±15 ppmv 

after each 24-hour period of the seven day test at both zero and 

high levels;

D. The calibration error must be no greater than 25 ppmv; and
Veolia ES Technical Solutions, L.L.C. Page 33 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

E. The zero level, mid-level, and high level calibration gas used to 

determine calibration error must have a hydrocarbon level of 

0–200 ppmv, 150-200 ppmv, and 350–400 ppmv, respectively. 

(f) Petitions to use CEMS for other standards. The Permittee may petition 

EPA to use CEMS for compliance monitoring for particulate matter, 

mercury, semivolatile metals, low volatile metals, and hydrogen chloride 

and chlorine gas under 40 C.F.R. § 63.8(f), in lieu of compliance with the 

corresponding operating parameter limits.

(g) Calculation of rolling averages. The Permittee shall calculate rolling 

averages in accordance with the following requirements of 40 C.F.R. 

§ 63.1209(a)(6):

(i) Calculation of rolling averages upon intermittent operations. The 

Permittee must ignore periods of time when 1-minute values are not 

available for calculating the hourly rolling average. When 1-minute 

values become available again, the first 1-minute value is added to 

the previous 59 values to calculate the hourly rolling average. 

[40 C.F.R. § 63.1209(a)(6)(ii)]

(ii) Calculation of rolling averages when the hazardous waste feed is cut

off. [40 C.F.R. § 63.1209(a)(6)(iii)]

A. Except as provided by condition 2.1(D)(1)(g)(ii)(B), below, the 

Permittee must continue monitoring carbon monoxide when 

the hazardous waste feed is cut off if the source is operating. 

The Permittee must not resume feeding hazardous waste if the 

emission levels exceed the standard. 

B. The Permittee is not subject to the CEMS requirements of 

40 C.F.R. Part 63, Subpart EEE, during periods of time the 

Permittee meets the requirements of 40 C.F.R. 

§ 63.1206(b)(1)(ii) (compliance with emissions standards for 

nonhazardous waste burning sources when the Permittee is not 

burning hazardous waste).

(h) Operating parameter limits for hydrocarbons. If the Permittee elects to 

comply with the carbon monoxide and hydrocarbon emission standard by 

continuously monitoring carbon monoxide with a CEMS, the Permittee 

must demonstrate that hydrocarbon emissions during the comprehensive 

performance test do not exceed the hydrocarbon emissions standard. In 

addition, the limits the Permittee establishes on the DRE operating 

parameters required under 40 C.F.R. § 63.1209(j) also must ensure that the 

Permittee maintains compliance with the hydrocarbon emission standard. 
Veolia ES Technical Solutions, L.L.C. Page 34 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

If the Permittee does not conduct the hydrocarbon demonstration and DRE 

tests concurrently, the Permittee must establish separate operating 

parameter limits under 40 C.F.R. § 63.1209(j) based on each test, and the 

more restrictive of the operating parameter limits applies.

(i) Multi-metals CEMS. [40 C.F.R. § 63.1209(g)(2)]

The Permittee shall install, calibrate, maintain and operate an x-ray 

fluorescence multi-metals CEMS for use as a continuous parametric 

monitoring system (CPMS) on Units 2, 3 and 4 within 12 months (365

days) after this permit becomes effective, unless the Administrator 

determines that a time extension is warranted based on the Permittee’s 

documentation in writing of factors beyond its control that prevent the 

Permittee from meeting the 12-month deadline. The Permittee must also 

install and operate an oxygen CEMS on each unit to continuously correct 

the multi-metals CEMS data to 7 percent oxygen.

(i) Each multi-metals CEMS must meet the installation requirements in 

Other Test Method (OTM) 16, Performance Specification YY 

(Specifications and Test Procedures for X-ray Fluorescence Based 

Multi-Metals Continuous Emission Monitoring Systems at 

Stationary Sources) and the on-going quality control and quality 

assurance procedures set forth in OTM 20, Procedure Z (Quality

Assurance Requirements for X-Ray-Fluorescence Based MultiMetals Continuous Emission Monitoring Systems at Stationary 

Sources) and subsequent revisions. 

(ii) At a minimum, each multi-metals CEMS shall measure and report 

the total concentrations (regardless of speciation) of the following 

metals in both their vapor and solid forms in the exhaust stream: 

arsenic, beryllium, cadmium, chromium, lead and mercury. If the 

Permittee installs a multi-metals CEMS that is incapable of 

measuring any of the specified metals, the Permittee must quantify 

that metal’s emissions using that metal’s feedrate as determined 

according to condition 2.1(D)(4)(d) for the most recent 12-hour 

period for which feedstream analysis data for that metal is available 

and the system removal efficiency and exhaust parameters used by 

the Permittee to estimate emissions of that metal for that 12-hour 

period. For this purpose, unless otherwise approved in writing by 

EPA, the Permittee shall base its calculations on the affected metal’s 

feedrate as determined according to condition 2.1(D)(4)(d), system 

removal efficiency from the last comprehensive performance test 

required by conditions 2.1(D)(8) and (10), and continuous flow and 

temperature data as measured by CMS required under condition 

2.1(D)(2).
Veolia ES Technical Solutions, L.L.C. Page 35 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(iii) The parametric range for each metal or class of metals measured by 

the multi-metals CEMS is equal to the emission limit for that metal 

or class of metals specified in condition 2.1(A)(7) of this permit.

(iv) For a period of no less than 12 consecutive months, the Permittee 

shall operate each multi-metals CEMS at all times except during 

periods of monitor downtime due to calibration, quality assurance 

checks or scheduled maintenance. Operation “at all times” is 

defined as the collection of at least one measurement for each 

successive 15-minute period. In order to calculate a valid one-hour 

block average, valid results must be available for at least three of the 

four 15-minute cycles in each hour.

(v) During the period when each multi-metals CEMS is installed and 

operating, the Permittee shall calculate and record 1-hour rolling 

average emissions from the raw data obtained by each CEMS. The 

Permittee shall also calculate a 12-hour rolling average of data for 

each CEMS, calculated each hour as the average of data collected 

over the previous 12 operating hours. The Permittee shall maintain 

for five years all data used in all calculations.

(vi) The Permittee shall report to EPA in accordance with condition 

2.1(D)(1)(i)(x) for every 12-hour averaging period during which the 

12-hour average emissions from any incinerator were higher than the 

limits in condition 2.1(A)(7) whether or not the levels of metals in 

the feedstream complied with the OPLs in the permit.

(vii) During periods when any multi-metals CEMS is malfunctioning, or 

during periods of monitor downtime due to calibration, quality 

assurance checks or scheduled maintenance, the Permittee shall use 

data from feedstream analysis, performance tests and/or other CMSs, 

as provided in this permit, to demonstrate compliance at the 

respective incinerator with the applicable emissions limits provided 

that the monitor downtime lasts at least three of the four 15-minute 

cycles in each hour needed to calculate a valid one-hour block 

average.

(viii) During the period when any multi-metals CEMS is being operated,

the Permittee must continue to operate other CMS required under 

condition 2.1(D)(2) for the respective incinerator, and must monitor 

feedrates for the incinerator using the procedures contained in the 

feedstream analysis plan required under condition 2.1(D)(4)(b), and 

the supplemental procedures contained in condition 2.1(D)(4)(d)(2). 

(ix) At the end of the 12-month period during which each multi-metals 

CEMS was continuously operated, the Permittee may petition the 
Veolia ES Technical Solutions, L.L.C. Page 36 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

Administrator, in accordance with 40 C.F.R. § 63.1209(a)(5), to 

continue to use any or all of the multi-metals CEMS for compliance 

monitoring for mercury, LVM and SVM under 40 C.F.R. § 63.8(f) in 

lieu of compliance with the corresponding operating parameter limits

for the respective incinerators.

(x) Any CEMS reading above any parametric range, as defined in 

condition 2.1(D)(1)(i)(iii), is a deviation. 

(xi) If the data from any multi-metals CEMS show a deviation, the 

Permittee must analyze the feedstream analysis data for the waste 

burned at the time of the deviation and the combustion conditions 

that existed at the time of the deviation to determine why the 

deviation occurred. The Permittee will send to the Administrator

within 30 days of the deviation all feedstream analysis data for the 

period of the deviation and its analysis of the cause of the deviation, 

and actions taken to address the deviation. 

(xii) From the time that a CEMS records a deviation, the Permittee must 

immediately stop feeding the batch of waste burned when the 

deviation occurred, and is prohibited from burning the remainder of 

the batch or any component that comprised the batch at that unit 

until such time that the Permittee demonstrates to the Administrator, 

and the Administrator indicates in writing that EPA accepts the 

demonstration, that a reduction in the feedrate for that affected class 

of metals is not necessary to assure compliance with the emissions 

limits in this permit.

(xiii) If operation of the multi-metals CEMS during the 12-month period, 

in conjunction with feedstream analysis or other relevant data, 

reveals that any of the feedrate limits included in this permit must be 

made more stringent in order to assure compliance with the 

applicable emissions limits, EPA will reopen this permit, pursuant to 

40 C.F.R. § 71.7(f), to either revise the affected feedrate limits or 

require operation of the multi-metals CEMS for a longer period of 

time or permanently.

(xiv) If operation of the multi-metals CEMS during the 12-month period, 

in conjunction with feedstream analysis or other relevant data, 

reveals that any of the feedrate limits included in this permit are

more stringent than necessary to assure compliance with the 

applicable emissions limits, the Permittee may petition the 

Administrator to use the results of historical comprehensive 

performance tests, feedstream analysis, and CEMS data to establish 

higher feedrate limits for the affected incinerators provided the 

CEMS data demonstrate that compliance would be assured at the 
Veolia ES Technical Solutions, L.L.C. Page 37 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

higher feedrate limits regardless of the waste burned. Nothing in this 

permit or 40 C.F.R. Part 63, Subpart EEE, obligates the 

Administrator to approve a petition for revised feedrate limits.

(xv) Notwithstanding the specific recordkeeping and reporting 

requirements contained in condition 2.1(E) of this permit, the 

Permittee shall, on a quarterly basis, submit to EPA a summary of 

emissions data recorded by each multi-metals CEMS and the 1-hour 

and 12-hour rolling average mercury, SVM and LVM feedrates 

recorded during the same period. The emissions data summary shall 

include:

A. The 1-hour and 12-hour rolling average concentrations of 

mercury, LVM and SVM as recorded by the multi-metals 

CEMS, in the units of the applicable MACT standards

(μg/dscm, corrected to 7 percent oxygen);

 

B. The 12-hour rolling average feedrates, as determined through 

the required feedstream analyses conducted during the same 

period;

C. Sample calculations, equations or other data used by the 

Permittee to convert CEMS and feedrate data;

D. The total duration in minutes of any excess emissions during 

the reporting period, the 1-hour and 12-hour rolling average 

concentrations recorded during each period of excess 

emissions, the total duration of excess emissions expressed as a 

percent of the total source operating time during that reporting 

period, and a breakdown of the total duration of excess 

emissions during the reporting period into those that are due to 

startup/shutdown, control equipment problems, process 

problems, other known causes, and other unknown causes; and

E. All deviations that occurred during the reporting period and 

corrective actions taken. 

2. Other continuous monitoring systems (CMS). [40 C.F.R. § 63.1209(b)]

(a) The Permittee must use CMS (e.g., thermocouples, pressure transducers, 

flow meters) to document compliance with the applicable operating 

parameter limits under 40 C.F.R. § 63.1209.

(b) Except as specified in conditions 2.1(D)(2)(b)(i) and (ii), below, the 

Permittee must install and operate continuous monitoring systems other 

than CEMS in conformance with 40 C.F.R. § 63.8(c)(3) that requires, at a 
Veolia ES Technical Solutions, L.L.C. Page 38 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

minimum, to comply with the manufacturer’s written specifications or 

recommendations for installation, operation, and calibration of the system: 

(i) Calibration of thermocouples and pyrometers. The calibration of 

thermocouples must be verified at a frequency and in a manner 

consistent with manufacturer specifications, but no less frequent than 

once per year. The Permittee must operate and maintain optical 

pyrometers in accordance with manufacturer specifications unless 

otherwise approved by the Administrator. The Permittee must 

calibrate optical pyrometers in accordance with the frequency and 

procedures recommended by the manufacturer, but no less frequent 

than once per year, unless otherwise approved by the Administrator.

(ii) Accuracy and calibration of weight measurement devices for 

activated carbon injection systems. If the Permittee operates a 

carbon injection system, the accuracy of the weight measurement 

device must be ± 1 percent of the weight being measured. The 

calibration of the device must be verified at least once each calendar 

quarter at a frequency of approximately 120 days. 

(c) A CMS must sample the regulated parameter without interruption, evaluate 

the detector response at least once each 15 seconds, and compute and 

record the average values at least every 60 seconds.

(d) The span of the non-CEMS CMS detector must not be exceeded. The 

Permittee must interlock the span limits into the automatic waste feed 

cutoff system required by 40 C.F.R. § 63.1206(c)(3). 

(e) Calculation of rolling averages.

(i) Calculation of rolling averages upon intermittent operations. The 

Permittee must ignore periods of time when 1-minute values are not 

available when calculating rolling averages. When 1-minute values 

become available again, the first 1-minute value is added to the 

previous 1-minute values to calculate rolling averages. 

(ii) Calculation of rolling averages when the hazardous waste feed is 

cutoff.

A. Except as provided by condition 2.1(D)(2)(e)(ii)(B), below, the 

Permittee must continue monitoring operating parameter limits 

with a CMS when the hazardous waste feed is cutoff if the 

source is operating. The Permittee must not resume feeding 

hazardous waste if an operating parameter exceeds its limit.
Veolia ES Technical Solutions, L.L.C. Page 39 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

B. The Permittee is not subject to the CMS requirements during 

periods of time the Permittee meets the requirements of 40 

C.F.R. § 63.1206(b)(1)(ii) (compliance with emissions 

standards for nonhazardous waste burning sources when the 

Permittee is not burning hazardous waste). 

3. Bag leak detection system requirements. [40 C.F.R. § 63.1206(c)(8)]

The Permittee must continuously operate a bag leak detection system under the 

following requirements:

(a) A bag leak detection system that meets the specifications and requirements 

of condition 2.1(D)(3)(b), below, and the Permittee must comply with the 

corrective measures and notification requirements of conditions

2.1(D)(3)(c) and 2.1(E)(5). 

(b) Bag leak detection system specification and requirements:

(i) The bag leak detection system must be certified by the manufacturer 

to be capable of continuously detecting and recording particulate 

matter emissions at concentrations of 1.0 milligram per actual cubic 

meter unless the Permittee demonstrates, under 40 C.F.R. 

§ 63.1209(g)(1), that a higher detection limit would routinely detect 

particulate matter loadings during normal operations; 

(ii) The bag leak detection system shall provide output of relative or 

absolute particulate matter loadings;

(iii) The bag leak detection system shall be equipped with an alarm 

system that will sound an audible alarm when an increase in relative 

particulate loadings is detected over a preset level;

(iv) The bag leak detection system shall be installed and operated in a 

manner consistent with available written guidance from EPA or, in 

the absence of such written guidance, the manufacturer’s written 

specifications and recommendations for installation, operation, and 

adjustment of the system; 

(v) The initial adjustment of the system shall, at a minimum, consist of 

establishing the baseline output by adjusting the sensitivity (range) 

and the averaging period of the device, and establishing the alarm set 

points and the alarm delay time; 

(vi) Following initial adjustment, the Permittee must not adjust the 

sensitivity or range, averaging period, alarm set points, or alarm 
Veolia ES Technical Solutions, L.L.C. Page 40 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

delay time, except as detailed in the operation and maintenance plan 

required under 40 C.F.R. § 63.1206(c)(7). The Permittee must not 

increase the sensitivity by more than 100 percent or decrease the 

sensitivity by more than 50 percent over a 365-day period unless 

such adjustment follows a complete baghouse inspection which 

demonstrates the baghouse is in good operating condition; and

(vii) The bag leak detector shall be installed downstream of the baghouse 

and upstream of any wet acid gas scrubber. Where multiple 

detectors are required, the system’s instrumentation and alarm 

system may be shared among the detectors.

(c) Bag leak detection system corrective measures requirements. The 

operating and maintenance plan required by 40 C.F.R. § 63.1206(c)(7) 

must include a corrective measures plan that specifies the procedures the 

Permittee will follow in the case of a bag leak detection system alarm or

malfunction. The corrective measures plan must include, at a minimum, 

the procedures used to determine and record the time and cause of the 

alarm as well as the corrective measures taken to correct the control device 

malfunction or minimize emissions as specified below. Failure to initiate 

the corrective measures required by this condition 2.1(D)(3)(c) is failure to 

ensure compliance with the emission standards in 40 C.F.R. Part 63, 

Subpart EEE. 

(i) The Permittee must initiate the procedures used to determine the 

cause of the alarm within 30 minutes of the time the alarm first 

sounds; and 

(ii) The Permittee must alleviate the cause of the alarm by taking the 

necessary corrective measure(s) which may include, but are not to be 

limited to, the following:

A. Inspecting the baghouse for air leaks, torn or broken filter 

elements, or any other malfunction that may cause an increase 

in emissions;

B. Sealing off defective bags or filter media;

C. Replacing defective bags or filter media, or otherwise repairing 

the control device;

D. Sealing off a defective baghouse compartment; 

E. Cleaning the bag leak detection system probe, or otherwise 

repairing the bag leak detection system; or 
Veolia ES Technical Solutions, L.L.C. Page 41 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

F. Shutting down the combustor.

4. Analysis of feedstreams.

(a) General. Prior to feeding the material, the Permittee must obtain an 

analysis of each feedstream that is sufficient to document compliance with 

the applicable feedrate limits contained in 40 C.F.R. § 63.1209 and 

condition 2.1(C) of this permit. [40 C.F.R. § 63.1209(c)(1)]

(b) Feedstream analysis plan. [40 C.F.R. § 63.1209(c)(2)]

The Permittee must develop and implement a feedstream analysis plan and 

record it in the operating record. The plan must specify at a minimum:

(i) The parameters for which the Permittee will analyze each feedstream 

to ensure compliance with the operating parameter limits contained 

in 40 C.F.R. § 63.1209 and condition 2.1(C) of this permit;

(ii) Whether the Permittee will obtain the analysis by performing 

sampling and analysis or by other methods, such as using analytical 

information obtained from others or using other published or 

documented data or information;

(iii) How the Permittee will use the analysis to document compliance 

with applicable feedrate limits (e.g., if the Permittee blends 

hazardous wastes and obtains analyses of the wastes prior to 

blending but not of the blended, as-fired, waste, the plan must 

describe how the Permittee will determine the pertinent parameters 

of the blended waste);

(iv) The test methods which the Permittee will use to obtain the analyses;

(v) The sampling method which the Permittee will use to obtain a 

representative sample of each feedstream to be analyzed using 

sampling methods described in Appendix IX to 40 C.F.R. Part 266, 

or an equivalent method; and

(vi) The frequency with which the Permittee will review or repeat the 

initial analysis of the feedstream to ensure that the analysis is 

accurate and up to date.

The feedstream analysis plan that the Permittee submitted to EPA on 

August 16, 2013, and dated October 2008, is hereby incorporated into this 

permit by reference. Any future version of the feedstream analysis plan 
Veolia ES Technical Solutions, L.L.C. Page 42 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

approved by EPA supersedes the October 2008 feedstream analysis plan 

and is incorporated by reference into this permit.

(c) Review and approval of feedstream analysis plan. The Permittee must 

submit the feedstream analysis plan to the Administrator for review and 

approval, if requested. [40 C.F.R. § 63.1209(c)(3)]

(d) Compliance with feedrate limits. 

(i) To comply with the applicable feedrate limits of 40 C.F.R. § 63.1209 

and condition 2.1(C) of this permit, the Permittee must monitor and 

record feedrates as follows:

A. Determine and record the value of the parameter for each 

feedstream by sampling and analysis or other method;

B. Determine and record the mass or volume flowrate of each 

feedstream by a CMS. If the Permittee determines flowrate of 

a feedstream by volume, the Permittee must determine and 

record the density of the feedstream by sampling and analysis 

(unless the Permittee reports the constituent concentration in 

units of weight per unit volume (e.g., mg/l)); and

C. Calculate and record the mass feedrate of the parameter per 

unit time.

[40 C.F.R. § 63.1209(c)(4)]

(ii) Analysis procedures for mercury, LVM and SVM. [40 C.F.R. 

§ 71.6(c)(1)]

The Permittee shall implement the following procedures for 

mercury, SVM and LVM, and must maintain records of all analyses, 

reports and written determinations in accordance with condition 

2.1(E)(21). 

Within 60 days of this permit becoming effective, the Permittee shall 

submit to the Administrator for approval a revised feedstream 

analysis plan, pursuant to condition 2.1(D)(4)(c), above, that 

incorporates into the plan, at a minimum, the feedstream analysis 

procedures contained in this condition 2.1(D)(4)(d)(ii).

A. Pre-acceptance screening procedure. 
Veolia ES Technical Solutions, L.L.C. Page 43 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

The Permittee may obtain, prior to the shipment of waste to the 

facility, a representative sample of the waste for analysis of 

mercury, LVM and SVM by the Permittee using appropriate 

quality assurance/quality control procedures and an appropriate 

test method that are consistent with EPA’s “Test Methods for 

Evaluating Solid Waste, Physical/Chemical Methods” (SW846), available at 

http://www.epa.gov/waste/hazard/testmethods/sw846/. The 

Permittee is not required for purposes of this permit to follow 

this pre-acceptance screening sampling and analysis procedure 

for each wastestream.

B. Waste acceptance procedure. 

Subject to the exemptions in condition 2.1(D)(4)(d)(ii)(F),

below, the Permittee shall conduct representative sampling of 

each shipment of waste for mercury, LVM and SVM prior to 

feeding the waste into any incinerator and shall analyze such 

samples using appropriate quality assurance/quality control 

procedures and appropriate test methods that are consistent 

with SW-846. 

C. Batch sampling procedure. 

If waste accepted for incineration is batched, treated, blended, 

mixed, or otherwise altered from its shipped state, the 

Permittee shall sample and analyze such batched, treated, 

blended, mixed, or otherwise altered waste for mercury, LVM 

and SVM in its final form as feed for incineration, prior to 

incineration using appropriate quality assurance/quality control 

procedures and appropriate test methods that are consistent 

with SW-846. In lieu of sampling and analysis, the Permittee 

may perform a mass balance calculation to determine 

concentrations in the final batched, treated, blended, mixed, or 

otherwise altered waste. The calculation must be based on all 

batched, treated, blended, mixed, or otherwise altered

ingredients having been analyzed and the contribution of each 

ingredient determined pursuant to condition 

2.1(D)(4)(d)(ii)(E), below. Feedstreams which are exempt 

from sampling in accordance with condition 2.1(D)(4)(d)(ii)(F) 

must not be batched, treated, blended, mixed, or otherwise 

altered, unless the Permittee samples and analyzes the 

otherwise exempt feedstream. 
Veolia ES Technical Solutions, L.L.C. Page 44 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

D. Fuel procedure. 

The Permittee shall document the concentration of mercury, 

LVM and SVM in any fuel other than natural gas, including 

used oil, diesel, and alternative fuels, but not including 

hazardous waste, fed into the incinerators by either (1) 

obtaining analytical results from each fuel supplier or (2) 

conducting representative sampling of each fuel supply and 

analyzing such samples using appropriate quality 

assurance/quality control procedures and appropriate test 

methods. The Permittee shall follow this procedure at least 

once per year for each fuel supply. 

E. Treatment of detection limits for metal feedrate calculations. 

The Permittee shall determine the concentrations of arsenic, 

beryllium, cadmium, chromium, lead and mercury as set forth 

below in order to calculate the mass of mercury, LVM and 

SVM for each waste or fuel fed to each incinerator: 

I. If the applicable metal is detected at or above the 

reporting limit for that metal, as defined in condition 

2.1(D)(4)(d)(ii)(E)(III), in any sampling analysis 

required by condition 2.1(D)(4)(d)(ii), the metal 

concentration shall be equal to the concentration of that 

metal detected from the associated sampling analysis at 

or above the reporting limit, as defined in condition 

2.1(D)(4)(d)(ii)(E)(III), below.

II. If the applicable metal is not detected at or above the 

reporting limit for that metal, as defined in condition 

2.1(D)(4)(d)(ii)(E)(III), in any sampling analysis 

required by condition 2.1(D)(4)(d)(2), the metal 

concentration shall be equal to the reporting limit, as 

defined in condition 2.1(D)(4)(d)(ii)(E)(III), from the 

sampling analyses required by condition 2.1(D)(4)(d)(ii).

III. The reporting limit shall be determined as the lower 

limit of quantitation as described in Method 6010c of 

SW-846, multiplied by the appropriate extraction and 

dilution factors. All positive sample results must fall 

within the established linear dynamic range, and nondetects reported at the lower limit of quantitation with 

appropriate dilution factors applied as specified by 

Method 6010c of SW-846.
Veolia ES Technical Solutions, L.L.C. Page 45 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

IV. The mass of LVM in each feedstream is the algebraic 

sum of the mass of arsenic, beryllium and chromium in 

that feedstream. The mass of SVM in the feedstream is 

the algebraic sum of the mass of lead and cadmium in 

that feedstream.

F. Exemptions to the analysis procedures in condition 

2.1(D)(4)(d)(ii). 

The following wastes that the Permittee determines do not 

contain mercury, LVM or SVM, consistent with this condition 

2.1(D)(4)(d)(ii)(F), shall be exempt from the analysis 

procedures set forth in condition 2.1(D)(4)(d)(ii):

I. Packaged chemicals from laboratories, hospitals, 

household clean sweeps, or manufacturing facilities, 

including scintillation vials packed in accordance with 

Small Quantity Chemical Guidelines (SQCGs) except 

those that are not packaged in numerous small 

containers or are unknowns (such as having no labels or 

other identification). For packaged chemicals, the 

Permittee shall obtain a packing list for each container 

from the generator specifying type and quantity of 

chemicals contained within;

II. Empty containers as defined in 35 IAC 721.107(b);

III. Pharmaceutical and commercial products or chemicals 

that are off-specification or outdated and are packaged in 

consumer quantities, are unused or banned, and are in 

their original packaging except those that are not 

packaged in numerous small containers or are unknowns 

(such as having no labels or other identification);

IV. Aerosol cans, lecture bottles or gas cylinders, except 

those that are unknowns;

V. Controlled substances, as defined in 21 C.F.R. Part 

1308, regulated by the federal government and handled 

unopened until destroyed in the incinerator; and

VI. Explosive, poison inhalation hazard, or odiferous 

material, such as mercaptan, which present sampling and 

analytical safety hazards and that are handled unopened 

until destroyed in the incinerator.
Veolia ES Technical Solutions, L.L.C. Page 46 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

VII. The Permittee shall review any container labels, material 

safety data sheets, drum inventories, packing lists, and 

any other relevant data or information provided by the 

generator to determine whether mercury, LVM or SVM

is present in any waste listed in conditions

2.1(D)(4)(d)(ii)(F)(I) through (6) that otherwise is 

exempt. Only those wastes listed in conditions

2.1(D)(4)(d)(ii)(F)(I) through (VI) that the Permittee

determines in writing contain no mercury, LVM or SVM

based on such review are exempt from the analysis 

procedures set forth in condition 2.1(D)(4)(d)(ii). The 

Permittee’s written determination of exemption from 

these analysis procedures shall describe the information 

reviewed and the basis for the determination that no 

mercury, LVM or SVM is present. 

VIII. Any waste listed in conditions 2.1(D)(4)(d)(ii)(F)(I) 

through (VI) for which there is insufficient information 

to allow the Permittee to make a reasonable

determination that mercury, LVM and SVM are not 

present shall not be exempt.

IX. The Permittee may request approval from the 

Administrator to exempt any waste that is not listed in 

conditions 2.1(D)(4)(d)(ii)(F)(I) through (VI) from the 

analysis procedures set forth in conditions

2.1(D)(4)(d)(ii)(A) through (E). The Permittee shall 

describe the information reviewed and the basis for the 

determination that no mercury, LVM or SVM is present 

in the wastes proposed for exemption. 

X. The Permittee shall maintain any written determination 

of exemption at the facility in accordance with condition 

2.1(E)(21). 

G. Condition 2.1(D)(4)(d)(ii) shall supersede any conflicting or 

less stringent provision in the Permittee’s feedstream analysis 

plan as required in condition 2.1(D)(4)(b), above.

(e) Waiver of monitoring of constituents in certain feedstreams. 

Notwithstanding the specific analysis procedures for mercury, LVM and 

SVM contained in condition 2.1(D)(4)(d)(ii), above, the Permittee is not 

required to monitor levels of metals or chlorine in the following 

feedstreams to document compliance with the feedrate limits contained in
Veolia ES Technical Solutions, L.L.C. Page 47 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

40 C.F.R. § 63.1209 and condition 2.1(C) of this permit, provided that the 

Permittee documents in the comprehensive performance test plan the 

expected levels of the constituent in the feedstream and accounts for those 

assumed feedrate levels in documenting compliance with feedrate limits: 

natural gas, process air, and feedstreams from vapor recovery systems. [40 

C.F.R. § 63.1209(c)(5)]

(f) Performance evaluations. [40 C.F.R. § 63.1209(d)]

(i) The requirements of 40 C.F.R. § 63.8(d) (quality control program) 

and (e) (performance evaluation of continuous monitoring systems) 

apply, except that the Permittee must conduct performance 

evaluations of components of the CMS under the frequency and 

procedures (for example, submittal of performance evaluation test 

plan for review and approval) applicable to performance tests as 

provided by 40 C.F.R. § 63.1207.

(ii) The Permittee must comply with the quality assurance procedures 

for CEMS prescribed in the appendix to 40 C.F.R. Part 63, Subpart 

EEE.

(g) Conduct of monitoring. [40 C.F.R. § 63.1209(e)] 

The provisions of 40 C.F.R. § 63.8(b) apply.

(h) Operation and maintenance of continuous monitoring systems. [40 C.F.R. 

§ 63.1209(f)] 

The Permittee is subject to the provisions of 40 C.F.R. § 63.8(c), except:

(i) Subsection 63.8(c)(3). Instead of complying with 40 C.F.R. 

§ 63.8(c)(3), the Permittee shall comply with 40 C.F.R. § 63.1211(c), 

which requires CMSs to be installed, calibrated, and operational on 

the compliance date; and 

(ii) Subsection 63.8(c)(4)(ii). Instead of complying with 40 C.F.R. 

§ 63.8(c)(4)(ii), the Permittee shall comply with the performance 

specifications for carbon monoxide, hydrocarbon and oxygen CEMS 

in 40 C.F.R. Part 60, Subpart B, which requires detectors to measure 

the sample concentration at least once every 15 seconds for 

calculating an average emission rate once every 60 seconds.

(i) Reduction of monitoring data. [40 C.F.R. § 63.1209(h)] 

The following provisions of 40 C.F.R. § 63.8(g) apply:
Veolia ES Technical Solutions, L.L.C. Page 48 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(i) The Permittee must reduce the monitoring data for each CMS, as 

specified in conditions 2.1(D)(4)(i)(ii) through (v), below.

(ii) The Permittee shall reduce all data from each COMs to 6-minute 

averages calculated from 36 or more data points which are equally 

spaced over each 6-minute period. Data from CEMS for 

measurement other than opacity, unless otherwise specified in the 

relevant standard, shall be reduced to 1-hour averages computed 

from four or more data points equally spaced over each 1-hour 

period, except during periods when calibration, quality assurance, or 

maintenance activities pursuant to provisions of this part are being 

performed. During these periods, a valid hourly average shall 

consist of at least two data points with each representing a 15-minute 

period. Alternatively, an arithmetic or integrated 1-hour average of 

CEMS data may be used. Time periods for averaging are defined in 

40 C.F.R. § 63.2.

(iii) The data may be recorded in reduced or nonreduced form (e.g., ppm 

pollutant and percent O2 or ng/J of pollutant).

(iv) All emissions data shall be converted into units of the relevant 

standard for reporting purposes using the conversion procedures 

specified in that standard. After conversion into units of the relevant 

standard, the data may be rounded to the same number of significant 

digits as used in that standard to specify the emission limit (e.g., 

rounded to the nearest 1 percent opacity). 

(v) Monitoring data recorded during periods of unavoidable CMS

breakdowns, out-of-control periods, repairs, maintenance periods, 

calibration checks, and zero (low-level) and high-level adjustments 

must not be included in any data average computed under this part. 

For the Permittee complying with the requirements of 40 C.F.R. 

§ 63.10(b)(2)(vii)(A) or (B), data averages must include any data 

recorded during periods of monitor breakdown or malfunction.

(j) When an operating parameter is applicable to multiple standards. [40 

C.F.R. § 63.1209(i)]

 

(i) As required by 40 C.F.R. § 63.1209(j) through (p), the Permittee 

must establish limits on operating parameters based on 

comprehensive performance testing to ensure the Permittee 

maintains compliance with the emission standards. 
Veolia ES Technical Solutions, L.L.C. Page 49 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(ii) For several parameters, the Permittee must establish a limit for the 

parameter to ensure compliance with more than one emission 

standard. An example is a limit on minimum combustion chamber 

temperature to ensure compliance with both the DRE standard of 40 

C.F.R. § 63.1209(j) and the dioxin/furan standard of 40 C.F.R. 

§ 63.1209(k). 

(iii) If the performance tests for such standards are not performed 

simultaneously, the most stringent limit for a parameter derived from 

independent performance tests applies.

(k) Destruction and Removal Efficiency. [40 C.F.R. § 63.1209(j)] 

To remain in compliance with the DRE standard, the Permittee must 

establish operating limits during the comprehensive performance test (or 

during a previous DRE test under provisions of 40 C.F.R. § 63.1206(b)(7))

for the following parameters, unless the limits are based on manufacturer 

specifications, and comply with those limits at all times that hazardous 

waste remains in the combustion chamber (i.e., the hazardous waste 

residence time has not transpired since the hazardous waste feed cutoff 

system was activated): 

(i) Minimum combustion chamber temperature.

A. The Permittee must measure the temperature of each 

combustion chamber at a location that best represents, as 

practicable, the bulk gas temperature in the combustion zone. 

The Permittee must document the temperature measurement 

location in the test plan the Permittee submit under 40 C.F.R. 

§ 63.1207(e).

B. The Permittee must establish a minimum hourly rolling 

average limit as the average of the test run averages.

(ii) Maximum flue gas flowrate or production rate.

A. As an indicator of gas residence time in the control device, the 

Permittee must establish and comply with a limit on the 

maximum flue gas flowrate, the maximum production rate, or 

another parameter that the Permittee documents in the sitespecific test plan as an appropriate surrogate for gas residence 

time, as the average of the maximum hourly rolling averages 

for each run.

B. The Permittee must comply with this limit on an hourly rolling 

average basis.
Veolia ES Technical Solutions, L.L.C. Page 50 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(iii) Maximum hazardous waste feedrate.

A. The Permittee must establish limits on the maximum pumpable 

and total (i.e., pumpable and nonpumpable) hazardous waste 

feedrate for each location where hazardous waste is fed. 

B. The Permittee must establish the limits as the average of the 

maximum hourly rolling averages for each run.

C. The Permittee must comply with the feedrate limit(s) on an 

hourly rolling average basis.

(iv) Operation of waste firing system. The Permittee must specify 

operating parameters and limits to ensure that good operation of each 

hazardous waste firing system is maintained.

(l) Dioxins and furans. [40 C.F.R. § 63.1209(k)] 

The Permittee must comply with the dioxin and furans emission standard 

by establishing and complying with the following operating parameter 

limits. The Permittee must base the limits on operations during the 

comprehensive performance test, unless the limits are based on 

manufacturer specifications. 

(i) Gas temperature at the inlet to a dry particulate matter control 

device.

Each combustor is equipped with a baghouse (fabric filter). 

Therefore, the Permittee must establish a limit on the maximum 

temperature of the gas at the inlet to the device on an hourly rolling 

average. The Permittee must establish the hourly rolling average 

limit as the average of the test run averages. 

(ii) Minimum combustion chamber temperature.

A. The Permittee must measure the temperature of each 

combustion chamber at a location that best represents, as 

practicable, the bulk gas temperature in the combustion zone. 

The Permittee must document the temperature measurement 

location in the test plan under 40 C.F.R. § 63.1207(e) and (f);

B. The Permittee must establish a minimum hourly rolling 

average limit as the average of the test run averages.
Veolia ES Technical Solutions, L.L.C. Page 51 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(iii) Maximum flue gas flow rate or production rate.

A. As an indicator of gas residence time in the control device, the 

Permittee must establish and comply with a limit on the 

maximum flue gas flow rate, the maximum production rate, or 

another parameter that the Permittee documents in the sitespecific test plan as an appropriate surrogate for gas residence 

time, as the average of the maximum hourly rolling averages 

for each run.

B. The Permittee must comply with this limit on an hourly rolling 

average basis.

(iv) Maximum hazardous waste feedrate.

A. The Permittee must establish limits on the maximum pumpable 

and total (pumpable and nonpumpable) waste feedrate for each 

location where waste is fed. 

B. The Permittee must establish the limits as the average of the 

maximum hourly rolling averages for each run.

C. The Permittee must comply with the feedrate limit(s) on an 

hourly rolling average basis.

(v) Particulate matter operating limit. 

Unit #4 is equipped with an activated carbon injection system, 

therefore, the Permittee must establish operating parameter limits on 

the particulate matter control device as specified by 40 C.F.R. 

§ 63.1209(m)(1).

(vi) Activated carbon injection parameter limits. 

A. Carbon feedrate. The Permittee must establish a limit on 

minimum carbon injection rate on an hourly rolling average 

calculated as the average of the test run averages for Unit #4. 

If the carbon injection system injects carbon at more than one 

location, the Permittee must establish a carbon feedrate limit 

for each location.

B. Carrier fluid. The Permittee must establish a limit on 

minimum carrier fluid (gas or liquid) flowrate or pressure drop 

as an hourly rolling average based on the manufacturer's 

specifications for Unit #4. The Permittee must document the 
Veolia ES Technical Solutions, L.L.C. Page 52 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

specifications in the test plan submitted under 40 C.F.R. 

§ 63.1207(e) and (f).

C. Carbon specification.

I. The Permittee must specify and use the brand (i.e., 

manufacturer) and type of carbon used during the 

comprehensive performance test until a subsequent 

comprehensive performance test is conducted, unless the 

Permittee documents in the site-specific performance 

test plan required under 40 C.F.R. § 63.1207(e) and (f) 

key parameters that affect adsorption and establish limits 

on those parameters based on the carbon used in the 

performance test.

II. The Permittee may substitute at any time a different 

brand or type of carbon provided that the replacement 

has equivalent or improved properties compared to the 

carbon used in the performance test and conforms to the 

key sorbent parameters identified under 40 C.F.R. 

§ 63.1209(k)(6)(iii)(A). The Permittee must include in 

the operating record documentation that the substitute 

carbon will provide the same level of control as the 

original carbon.

(vii) Inhibitor feedrate parameter limits. If the Permittee feeds a 

dioxin/furan inhibitor into the combustion system, the Permittee 

must establish limits for the following parameters:

A. Minimum inhibitor feedrate. The Permittee must establish a 

limit on minimum inhibitor feedrate on an hourly rolling 

average as the average of the test run averages.

B. Inhibitor specifications. 

I. The Permittee must specify and use the brand (i.e., 

manufacturer) and type of inhibitor used during the 

comprehensive performance test until a subsequent 

comprehensive performance test is conducted, unless the 

Permittee documents in the site-specific performance 

test plan required under 40 C.F.R. § 63.1207(e) and (f) 

key parameters that affect the effectiveness of the 

inhibitor and establish limits on those parameters based 

on the inhibitor used in the performance test.
Veolia ES Technical Solutions, L.L.C. Page 53 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

II. The Permittee may substitute at any time a different 

brand or type of inhibitor provided that the replacement 

has equivalent or improved properties compared to the 

inhibitor used in the performance test and conforms to 

the key parameters the Permittee identifies under 40 

C.F.R. § 63.1209(k)(9)(ii)(A). The Permittee must 

include in the operating record documentation that the 

substitute inhibitor will provide the same level of control 

as the original inhibitor.

(m) Mercury. [40 C.F.R. § 63.1209(l)] 

The Permittee must comply with the mercury emission standard by 

establishing and complying with the following operating parameter limits. 

The Permittee must base the limits on operations during the comprehensive 

performance test, unless the limits are based on manufacturer 

specifications. 

(i) Feedrate of mercury. When complying with the mercury emission 

standards under 40 C.F.R. §§ 63.1203, 63.1216 and 63.1219, the 

Permittee must establish a 12-hour rolling average limit for the total 

feedrate of mercury in all feedstreams as the average of the test run 

averages.

(ii) Extrapolation of feedrate levels. The Permittee may request as part 

of the performance test plan under 40 C.F.R. §§ 63.7(b) and (c) and 

63.1207(e) and (f) approval to use the mercury feedrates and 

associated emission rates during the comprehensive performance test 

to extrapolate to higher allowable feedrate limits and emission rates. 

The extrapolation methodology will be reviewed and approved, if 

warranted, by EPA. EPA’s review will consider in particular 

whether:

A. Performance test metal feedrates are appropriate (i.e., whether 

feedrates are at least at normal levels; depending on the 

heterogeneity of the waste, whether some level of spiking 

would be appropriate; and whether the physical form and 

species of spike material is appropriate); and

B. Whether the extrapolated feedrates the Permittee requests are 

warranted considering historical metal feedrate data.

(iii) Activated carbon injection. Unit #4 is equipped with an activated 

carbon injection system, therefore, the Permittee must establish 
Veolia ES Technical Solutions, L.L.C. Page 54 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

operating parameter limits prescribed by 40 C.F.R. § 63.1209(k)(5) 

and (k)(6).

(n) Particulate matter. [40 C.F.R. § 63.1209(m)] 

The Permittee must comply with the particulate matter emission standard 

by establishing and complying with the following operating parameter 

limits. The Permittee must base the limits on operation during the 

comprehensive performance test, unless the limits are based on 

manufacturer specifications. 

(i) Control device operating parameter limits.

For each particulate matter control device that is not a fabric filter or 

high energy wet scrubber, or is not an electrostatic precipitator or 

ionizing wet scrubber for which the Permittee elects to monitor 

particulate matter loadings under 40 C.F.R. § 63.1206(c)(9) for 

process control, the Permittee must ensure that the control device is 

properly operated and maintained as required by 40 C.F.R. 

§ 63.1206(c)(7) and by monitoring the operation of the control 

device as follows: [40 C.F.R. § 63.1209(m)(1)(iv)]

A. During each comprehensive performance test conducted to 

demonstrate compliance with the particulate matter emissions 

standard, the Permittee must establish a range of operating 

values for the control device that is a representative and 

reliable indicator that the control device is operating within the 

same range of conditions as during the performance test. The 

Permittee must establish this range of operating values as 

follows:

I. The Permittee must select a set of operating parameters 

appropriate for the control device design that the 

Permittee determines to be a representative and reliable 

indicator of the control device performance.

II. The Permittee must measure and record values for each 

of the selected operating parameters during each test run 

of the performance test. A value for each selected 

parameter must be recorded using a continuous monitor.

III. For each selected operating parameter measured in 

accordance with the requirements of 40 C.F.R. 

§ 63.1209(m)(1)(iv)(A)(1), the Permittee must establish 

a minimum operating parameter limit or a maximum 
Veolia ES Technical Solutions, L.L.C. Page 55 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

operating parameter limit, as appropriate for the 

parameter, to define the operating limits within which 

the control device can operate and still continuously 

achieve the same operating conditions as it did during 

the performance test.

IV. The Permittee must prepare written documentation to 

support the operating parameter limits established for the 

control device and must include this documentation in 

the performance test plan that the Permittee submits for 

review and approval. This documentation must include

a description for each selected parameter and the 

operating range and monitoring frequency required to 

ensure the control device is being properly operated and 

maintained.

B. The Permittee must install, calibrate, operate, and maintain a 

monitoring device equipped with a recorder to measure the 

values for each operating parameter selected in accordance 

with the requirements of 40 C.F.R. § 63.1209(m)(1)(iv)(A)(1). 

The Permittee must install, calibrate, and maintain the 

monitoring equipment in accordance with the equipment 

manufacturer's specifications. The recorder must record the 

detector responses at least every 60 seconds, as required in the 

definition of continuous monitor.

C. The Permittee must regularly inspect the data recorded by the 

operating parameter monitoring system at a sufficient 

frequency to ensure the control device is operating properly. 

An excursion is determined to have occurred any time that the 

actual value of a selected operating parameter is less than the 

minimum operating limit (or, if applicable, greater than the 

maximum operating limit) established for the parameter in 

accordance with the requirements of 40 C.F.R. 

§ 63.1209(m)(1)(iv)(A)(3).

D. Operating parameters selected in accordance with 40 C.F.R.

§ 63.1209(m)(1)(iv) may be based on manufacturer 

specifications provided the Permittee supports the use of 

manufacturer specifications in the performance test plan that 

the Permittee submits for review and approval.

(ii) Maximum flue gas flowrate or production rate. 
Veolia ES Technical Solutions, L.L.C. Page 56 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

A. As an indicator of gas residence time in the control device, the 

Permittee must establish a limit on the maximum flue gas 

flowrate, the maximum production rate, or another parameter 

that the Permittee documents in the site-specific test plan as an 

appropriate surrogate for gas residence time, as the average of 

the maximum hourly rolling averages for each run.

B. The Permittee must comply with this limit on an hourly rolling 

average basis.

(iii) Maximum ash feedrate. 

The Permittee must establish a maximum ash feedrate limit as a 12-

hour rolling average of the test run averages. This requirement is 

waived, however, if the Permittee complies with particulate matter 

detection system requirements under 40 C.F.R. § 63.1206(c)(9).

(o) Semivolatile metals and low volatile metals. [40 C.F.R. § 63.1209(n)] 

The Permittee must comply with the semivolatile metal (cadmium and 

lead) and low volatile metal (arsenic, beryllium, and chromium) emission

standards by establishing and complying with the following operating 

parameter limits, as specified in condition 2.1(C)(2). The Permittee must 

base the limits on operations during the comprehensive performance test, 

unless the limits are based on manufacturer specifications. 

(i) Maximum inlet temperature to dry particulate matter air pollution 

control device. The Permittee must establish a limit on the 

maximum inlet temperature to the primary dry metals emissions 

control device (e.g., baghouse) on an hourly rolling average basis as 

the average of the test run averages.

(ii) Maximum feedrate of semivolatile and low volatile metals.

A. General. The Permittee must establish feedrate limits for SVM

and LVM as follows, except as provided by 40 C.F.R. 

§ 63.1209(n)(2)(ii):

B. When complying with the emission standards under 40 C.F.R. 

§§ 63.1203 and 63.1219, the Permittee must establish 12-hour 

rolling average limits for the total feedrate of SVM and LVM

in all feedstreams as the average of the test run averages.

C. LVM limits for pumpable wastes. The Permittee must 

establish separate feedrate limits for LVM in pumpable 
Veolia ES Technical Solutions, L.L.C. Page 57 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

feedstreams using the procedures prescribed above for total 

LVM. Dual feedrate limits for both pumpable and total 

feedstreams are not required, however, if the Permittee 

establishes the total feedrate limit solely based on the feedrate 

of pumpable feedstreams.

(iii) Control device OPLs. The Permittee must establish OPLs on the 

particulate matter control device as specified by 40 C.F.R. 

§ 63.1209(m)(1).

(iv) Maximum total chlorine and chloride feedrate. The Permittee must 

establish a 12-hour rolling average limit for the feedrate of total 

chlorine and chloride in all feedstreams as the average of the test run 

averages.

(v) Maximum flue gas flowrate or production rate. 

A. As an indicator of gas residence time in the control device, the 

Permittee must establish a limit on the maximum flue gas 

flowrate, the maximum production rate, or another parameter 

that the Permittee documents in the site-specific test plan as an 

appropriate surrogate for gas residence time, as the average of 

the maximum hourly rolling averages for each run.

B. The Permittee must comply with this limit on an hourly rolling 

average basis.

(p) Hydrogen chloride and chlorine gas. [40 C.F.R. § 63.1209(o)] 

The Permittee must comply with the hydrogen chloride and chlorine gas 

emission standard by establishing and complying with the following 

operating parameter limits. The Permittee must base the limits on 

operations during the comprehensive performance test, unless the limits are 

based on manufacturer specifications. 

(i) Feedrate of total chlorine and chloride. The Permittee must establish 

a 12-hour rolling average limit for the total feedrate of chlorine 

(organic and inorganic) in all feedstreams as the average of the test 

run averages. 

(ii) Maximum flue gas flowrate or production rate.

A. As an indicator of gas residence time in the control device, the 

Permittee must establish a limit on the maximum flue gas 

flowrate, the maximum production rate, or another parameter 
Veolia ES Technical Solutions, L.L.C. Page 58 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

that the Permittee documents in the site-specific test plan as an 

appropriate surrogate for gas residence time, as the average of 

the maximum hourly rolling averages for each run.

B. The Permittee must comply with this limit on an hourly rolling 

average basis.

(iii) Dry Scrubber. The combustor is equipped with a dry scrubber, 

therefore, the Permittee must establish and comply with the 

following operating parameter limits:

A. Minimum sorbent feedrate. The Permittee must establish a 

limit on minimum sorbent feedrate on an hourly rolling 

average as the average of the test run averages.

B. Minimum carrier fluid flowrate or nozzle pressure drop. The 

Permittee must establish a limit on minimum carrier fluid (gas 

or liquid) flowrate or nozzle pressure drop based on 

manufacturer’s specifications.

C. Sorbent specifications:

I. The Permittee must specify and use the brand (i.e., 

manufacturer) and type of sorbent used during the 

comprehensive performance test until a subsequent 

comprehensive performance test is conducted, unless the 

Permittee documents in the site-specific performance 

test plan required under 40 C.F.R. § 63.1207(e) and (f) 

key parameters that affect adsorption and establish limits 

on those parameters based on the sorbent used in the 

performance test.

II. The Permittee may substitute at any time a different 

brand or type of sorbent provided that the replacement 

has equivalent or improved properties compared to the 

sorbent used in the performance test and conforms to the 

key sorbent parameters the Permittee identifies under 40 

C.F.R. § 63.1209(o)(4)(iii)(A). The Permittee must 

record in the operating record documentation that the 

substitute sorbent will provide the same level of control 

as the original sorbent.

(q) Maximum combustion chamber pressure. [40 C.F.R. § 63.1209(p)]
Veolia ES Technical Solutions, L.L.C. Page 59 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

The Permittee must monitor the pressure instantaneously and the automatic 

waste feed cutoff system must be engaged when negative pressure is not 

maintained.

(r) Operating under different modes of operation. [40 C.F.R. § 63.1209(q)]

The Permittee has not established different mode of operation. Therefore, 

the source shall only operate under the terms and conditions identified in 

this permit.

(s) Significant figures. [40 C.F.R. §§ 63.1203(d) and 63.1219(d)]

The emission limits provided in 40 C.F.R. §§ 63.1203 and 63.1219(a) and 

(b) are presented with two significant figures. Although the Permittee must 

perform intermediate calculations using at least three significant figures, 

the Permittee may round the resultant emission levels to two significant 

figures to document compliance.

5. Changes in design, operation, or maintenance. [40 C.F.R. § 63.1206(b)(5)(i)(B)]

If the Permittee plans to change (as defined in 40 C.F.R. § 63.1206(b)(5)(iii)) the 

design, operation, or maintenance practices of the source in a manner that may 

adversely affect compliance with any emission standard that is not monitored 

with a CEMS, the Permittee must conduct a comprehensive performance test 

under the requirements of 40 C.F.R. § 63.1207(f)(1) and (g)(1) to document 

compliance with the affected emission standard(s) and establish operating 

parameter limits as required under 40 C.F.R. § 63.1209, and submit to the 

Administrator a NOC under 40 C.F.R. §§ 63.1207(j) and 63.1210(d). 

6. Compliance with the carbon monoxide and hydrocarbon emission standards. [40 

C.F.R. § 63.1206(b)(6)] 

(a) This condition 2.1(D)(6) applies to the Permittee if it elects to comply with 

the carbon monoxide and hydrocarbon emissions standards of 40 C.F.R. 

Part 63, Subpart EEE, by documenting continuous compliance with the 

carbon monoxide standard using a CEMS and documenting compliance 

with the hydrocarbon standard during the DRE performance test or its 

equivalent.

(b) If during the acceptable DRE test the Permittee did not obtain hydrocarbon 

emissions data sufficient to document compliance with the hydrocarbon 

standard, the Permittee must either:

(i) Perform, as part of the performance test, an “equivalent DRE test” to 

document compliance with the hydrocarbon standard. An equivalent 
Veolia ES Technical Solutions, L.L.C. Page 60 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

DRE test is comprised of a minimum of three runs each with a 

minimum duration of 1 hour during which the Permittee operates the 

combustor as close as reasonably possible to the operating parameter 

limits that the Permittee established based on the initial DRE test. 

The Permittee must use the highest hourly rolling average 

hydrocarbon emission level achieved during the equivalent DRE test 

to document compliance with the hydrocarbon standard; or

(ii) Perform a DRE test as part of the performance test.

7. Performance testing requirements. 

(a) General. The provisions of 40 C.F.R. § 63.7 apply, except as provided by 

40 C.F.R. § 63.1207. [40 C.F.R. § 63.1207(a)]

(b) During the comprehensive performance tests required by conditions 

2.1(D)(8) and (10), below, the Permittee shall also measure emissions of 

nitrogen oxides, sulfur dioxide, visible emissions (opacity) and volatile 

organic compounds to document compliance with the nitrogen oxide, sulfur 

dioxide, visible emissions and volatile organic compound limitations, 

respectively. [40 C.F.R. § 71.6(a)(3)(i)(B)]

8. Types of performance tests. [40 C.F.R. § 63.1207(b)]

(a) Comprehensive performance test.

The Permittee must conduct comprehensive performance tests to 

demonstrate compliance with the emission standards provided by 40 C.F.R. 

Part 63, Subpart EEE, establish limits for the operating parameters 

provided by 40 C.F.R. § 63.1209, and demonstrate compliance with the 

performance specifications for continuous monitoring systems for each 

incinerator.

(b) Confirmatory performance test. 

The Permittee must conduct confirmatory performance tests on each 

incinerator to:

(i) Demonstrate compliance with the dioxin/furan emission standard 

when the source operates under normal operating conditions; and

(ii) Conduct a performance evaluation of continuous monitoring systems 

required for compliance assurance with the dioxin/furan emission 

standard under 40 C.F.R. § 63.1209(k).
Veolia ES Technical Solutions, L.L.C. Page 61 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

9. Initial comprehensive performance test. [40 C.F.R. § 63.1207(c)(3)]

The Permittee must commence the initial comprehensive performance test to 

demonstrate compliance with the standards under 40 C.F.R. §§ 63.1219, 

63.1220, and 63.1221 not later than 12 months after the compliance date. 

10. Frequency of testing. [40 C.F.R. § 63.1207(d)]

Except as otherwise specified in 40 C.F.R. § 63.1207(d)(4), the Permittee must 

conduct testing periodically as prescribed in 40 C.F.R. § 63.1207(d)(1) through 

(d)(3). The date of commencement of the initial comprehensive performance test 

is the basis for establishing the deadline to commence the initial confirmatory 

performance test and the next comprehensive performance test. The Permittee 

may conduct performance testing at any time prior to the required date. The 

deadline for commencing subsequent confirmatory and comprehensive 

performance testing is based on the date of commencement of the previous 

comprehensive performance test. Unless the Administrator grants a time 

extension under § 63.1207(b)(3)(i), the Permittee must conduct testing as 

follows:

(a) Comprehensive performance testing. Except as otherwise specified in 40 

C.F.R. § 63.1207(d)(4), the Permittee must commence testing no later than 

61 months after the date of commencing the previous comprehensive 

performance test. 

(b) Confirmatory performance testing. Except as otherwise specified in 40 

C.F.R. § 63.1207(d)(4), the Permittee must commence confirmatory 

performance testing no later than 31 months after the date of commencing 

the previous comprehensive performance test. If the Permittee submits

data in lieu of the initial performance test, the Permittee must commence 

the initial confirmatory performance test within 31 months of the date 6 

months after the compliance date. To ensure that the confirmatory test is 

conducted approximately midway between comprehensive performance 

tests, the Administrator will not approve a test plan that schedules testing 

within 18 months of commencing the previous comprehensive performance 

test.

(c) Duration of testing. The Permittee must complete performance testing 

within 60 days after the date of commencement, unless the Administrator 

determines that a time extension is warranted based on its documentation in 

writing of factors beyond its control that prevents the Permittee from 

meeting the 60-day deadline.

11. Content of performance test plans. [40 C.F.R. § 63.1207(f)]

The provisions of 40 C.F.R. § 63.7(c)(2)(i)–(iii) and (v) apply.
Veolia ES Technical Solutions, L.L.C. Page 62 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(a) Content of comprehensive performance test plan. [40 C.F.R. 

§ 63.1207(f)(1)] 

In addition to the requirements of 40 C.F.R. § 63.7(c)(2)(i)–(iii) and (v) 

regarding the content of the test plan, the Permittee must include the 

following information in the comprehensive performance test plan:

(i) An analysis of each feedstream, including hazardous waste, other 

fuels, and industrial furnace feedstocks, as fired, that includes:

A. Heating value, levels of ash (for hazardous waste incinerators 

only), levels of SVM, LVM, mercury, and total chlorine 

(organic and inorganic); and

B. Viscosity or description of the physical form of the feedstream;

(ii) For organic hazardous air pollutants established by 42 U.S.C. 

§ 7412(b)(1), excluding caprolactam (CAS number 105602) as 

provided by 40 C.F.R. § 63.60:

A. Except as provided by 40 C.F.R. § 63.1207(f)(1)(ii)(D), an 

identification of such organic hazardous air pollutants that are 

present in each hazardous waste feedstream. The Permittee 

need not analyze for organic hazardous air pollutants that 

would reasonably not be expected to be found in the 

feedstream. The Permittee must identify any constituents the 

Permittee excludes from analysis and explain the basis for 

excluding them. The Permittee must conduct the feedstream 

analysis according to 40 C.F.R. § 63.1208(b)(8);

B. An approximate quantification of such identified organic 

hazardous air pollutants in the hazardous waste feedstreams, 

within the precision produced by analytical procedures of 

40 C.F.R. § 63.1208(b)(8); and

C. A description of blending procedures, if applicable, prior to 

firing the hazardous waste feedstream, including a detailed 

analysis of the materials prior to blending, and blending ratios.

D. The Administrator may approve on a case-by-case basis a 

hazardous waste feedstream analysis for organic hazardous air 

pollutants in lieu of the analysis required under 40 C.F.R. 

§ 63.1207(f)(1)(ii)(A) if the reduced analysis is sufficient to 

ensure that the POHCs used to demonstrate compliance with 
Veolia ES Technical Solutions, L.L.C. Page 63 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

the applicable DRE standards of this subpart continue to be 

representative of the most difficult to destroy organic 

compounds in its hazardous waste feedstreams;

(iii) A detailed engineering description of the hazardous waste 

combustor, including:

A. Manufacturer’s name and model number of the hazardous 

waste combustor;

B. Type of hazardous waste combustor;

C. Maximum design capacity in appropriate units;

D. Description of the feed system for each feedstream;

E. Capacity of each feed system;

F. Description of automatic hazardous waste feed cutoff 

system(s);

G. Description of the design, operation, and maintenance practices 

for any air pollution control system; and

H. Description of the design, operation, and maintenance practices 

of any stack gas monitoring and pollution control monitoring 

systems.

(iv) A detailed description of sampling and monitoring procedures 

including sampling and monitoring locations in the system, the 

equipment to be used, sampling and monitoring frequency, and 

planned analytical procedures for sample analysis;

(v) A detailed test schedule for each hazardous waste for which the 

performance test is planned, including date(s), duration, quantity of 

hazardous waste to be burned, and other relevant factors;

(vi) A detailed test protocol, including, for each hazardous waste 

identified, the ranges of hazardous waste feedrate for each feed 

system, and, as appropriate, the feedrates of other fuels and 

feedstocks, and any other relevant parameters that may affect the 

ability of the hazardous waste combustor to meet the emission 

standards;
Veolia ES Technical Solutions, L.L.C. Page 64 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(vii) A description of, and planned operating conditions for, any emission 

control equipment that will be used;

(viii) Procedures for rapidly stopping the hazardous waste feed and 

controlling emissions in the event of an equipment malfunction;

(ix) A determination of the hazardous waste residence time as required 

by 40 C.F.R. § 63.1206(b)(11);

(x) If the Permittee is requesting to extrapolate metal feedrate limits 

from comprehensive performance test levels under 40 C.F.R. 

§ 63.1209(l)(1)(v) or 63.1209(n)(2)(vii):

A. A description of the extrapolation methodology and rationale 

for how the approach ensures compliance with the emission 

standards;

B. Documentation of the historical range of normal (i.e., other 

than during compliance testing) metals feedrates for each 

feedstream; and

C. Documentation that the level of spiking recommended during 

the performance test will mask sampling and analysis 

imprecision and inaccuracy to the extent that the extrapolated 

feedrate limits adequately assure compliance with the emission 

standards.

(xi) If the Permittee does not continuously monitor regulated constituents 

in natural gas, process air feedstreams, and feedstreams from vapor 

recovery systems under 40 C.F.R. § 63.1209(c)(5), the Permittee 

must include documentation of the expected levels of regulated 

constituents in those feedstreams;

(xii) Documentation justifying the duration of system conditioning 

required to ensure the combustor has achieved steady-state 

operations under performance test operating conditions, as provided 

by 40 C.F.R. § 63.1207(g)(1)(iii);

(xiii) The Permittee must submit an application to request alternative 

monitoring under 40 C.F.R. § 63.1209(g)(1) not later than with the 

comprehensive performance test plan, as required by 

§ 63.1209(g)(1)(iii)(A);
Veolia ES Technical Solutions, L.L.C. Page 65 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(xiv) The Permittee must document the temperature location measurement 

in the comprehensive performance test plan, as required by 40 

C.F.R. §§ 63.1209(j)(1)(i) and 63.1209(k)(2)(i);

(xv) Because Unit 4 is equipped with activated carbon injection, the 

Permittee must document in the comprehensive performance test 

plan for Unit 4:

A. The manufacturer specifications for minimum carrier fluid 

flowrate or pressure drop, as required by 40 C.F.R. 

§ 63.1209(k)(6)(ii); and

B. Key parameters that affect carbon adsorption, and the operating 

limits the Permittee establishes for those parameters based on 

the carbon used during the performance test, if the Permittee 

elects not to specify and use the brand and type of carbon used 

during the comprehensive performance test, as required by 40 

C.F.R. § 63.1209(k)(6)(iii).

(xvi) If its source is equipped with a particulate matter control device 

other than a wet scrubber, the Permittee must include in the 

comprehensive performance test plan:

A. Documentation to support the operating parameter limits the 

Permittee establishes for the control device, as required by 40 

C.F.R. § 63.1209(m)(1)(iv)(A)(4); and

B. Support for the use of manufacturer specifications if the 

Permittee recommends such specifications in lieu of basing 

operating limits on performance test operating levels, as 

required by § 63.1209(m)(1)(iv)(D).

(xvii) If its source is equipped with a dry scrubber to control hydrogen 

chloride and chlorine gas, the Permittee must document in the 

comprehensive performance test plan key parameters that affect 

adsorption, and the limits the Permittee establishes for those 

parameters based on the sorbent used during the performance test, if 

the Permittee elects not to specify and use the brand and type of 

sorbent used during the comprehensive performance test, as required 

by 40 C.F.R. § 63.1209(o)(4)(iii)(A); 

(xviii)For purposes of calculating SVM, LVM, mercury, total chlorine 

(organic and inorganic), and ash feedrate limits, a description of how 

the Permittee will handle performance test feedstream analytical 
Veolia ES Technical Solutions, L.L.C. Page 66 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

results that determine these constituents are not present at detectable 

levels; and

(xix) Such other information as the Administrator reasonably finds 

necessary to determine whether to approve the performance test 

plan.

(b) Content of confirmatory test plan. 

In addition to the requirements of 40 C.F.R. § 63.7(c)(2)(i)–(iii) and (v) 

regarding the content of the test plan, the Permittee must include the 

following information in the confirmatory test plan:

(i) A description of the Permittee’s normal hydrocarbon or carbon 

monoxide operating levels, as specified in 40 C.F.R. 

§ 63.1207(g)(2)(i), and an explanation of how these normal levels 

were determined;

(ii) A description of the Permittee’s normal applicable operating 

parameter levels, as specified in 40 C.F.R. § 63.1207(g)(2)(ii), and 

an explanation of how these normal levels were determined;

(iii) A description of the Permittee’s normal chlorine operating levels, as 

specified in 40 C.F.R. § 63.1207(g)(2)(iii), and an explanation of 

how these normal levels were determined;

(iv) A description of the Permittee’s normal cleaning cycle of the 

particulate matter control device for Unit 4, as specified in 40 C.F.R. 

§ 63.1207(g)(2)(iv), and an explanation of how these normal levels 

were determined;

(v) A detailed description of sampling and monitoring procedures 

including sampling and monitoring locations in the system, the 

equipment to be used, sampling and monitoring frequency, and 

planned analytical procedures for sample analysis;

(vi) A detailed test schedule for each hazardous waste for which the 

performance test is planned, including date(s), duration, quantity of 

hazardous waste to be burned, and other relevant factors;

(vii) A detailed test protocol, including, for each hazardous waste 

identified, the ranges of hazardous waste feedrate for each feed 

system, and, as appropriate, the feedrates of other fuels and 

feedstocks, and any other relevant parameters that may affect the 
Veolia ES Technical Solutions, L.L.C. Page 67 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

ability of the hazardous waste combustor to meet the dioxin/furan 

emission standard;

(viii) A description of, and planned operating conditions for, any emission 

control equipment that will be used;

(ix) Procedures for rapidly stopping the hazardous waste feed and 

controlling emissions in the event of an equipment malfunction; and

(x) Such other information as the Administrator reasonably finds 

necessary to determine whether to approve the confirmatory test 

plan.

12. Operating conditions during testing. [40 C.F.R. § 63.1207(g)] 

The Permittee must comply with the provisions of 40 C.F.R. § 63.7(e). 

Conducting performance testing under operating conditions representative of the 

extreme range of normal conditions is consistent with the requirement of 40 

C.F.R. § 63.7(e)(1) to conduct performance testing under representative 

operating conditions.

(a) Comprehensive performance testing. [40 C.F.R. § 63.1207(g)(1)]

(i) Operations during testing. 

For the following parameters, the Permittee must operate the 

combustor during the performance test under normal conditions (or 

conditions that will result in higher than normal emissions):

A. Chlorine feedrate. The Permittee must feed normal (or higher) 

levels of chlorine during the dioxin/furan performance test;

B. Ash feedrate. For hazardous waste incinerators, the Permittee 

must conduct the following tests when feeding normal (or 

higher) levels of ash: The SVM and LVM performance tests; 

and the dioxin/furan and mercury performance tests if activated 

carbon injection or a carbon bed is used; and

C. Cleaning cycle of the particulate matter control device. The 

Permittee must conduct the following tests when the particulate 

matter control device undergoes its normal (or more frequent) 

cleaning cycle: The particulate matter, SVM, and LVM

performance tests; and the dioxin/furan and mercury 

performance tests if activated carbon injection or a carbon bed 

is used.
Veolia ES Technical Solutions, L.L.C. Page 68 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(ii) Modes of operation. 

Given that the Permittee must establish limits for the applicable 

operating parameters specified in 40 C.F.R. § 63.1209 based on 

operations during the comprehensive performance test, the Permittee 

may conduct testing under two or more operating modes to provide 

operating flexibility.

(iii) Steady-state conditions. 

Prior to obtaining performance test data, the Permittee must operate 

under performance test conditions until the Permittee reaches steadystate operations with respect to emissions of pollutants the Permittee 

must measure during the performance test and operating parameters 

under 40 C.F.R. § 63.1209 for which the Permittee must establish 

limits. During system conditioning, the Permittee must ensure that 

each operating parameter for which the Permittee must establish a 

limit is held at the level planned for the performance test. The 

Permittee must include documentation in the performance test plan 

under 40 C.F.R. § 63.1207(f) justifying the duration of system 

conditioning.

(b) Confirmatory performance testing. [40 C.F.R. § 63.1207(g)(2)]

The Permittee must conduct confirmatory performance testing for 

dioxin/furan under normal operating conditions for the following

parameters:

(i) Carbon monoxide (or hydrocarbon) CEMS emissions levels must be 

within the range of the average value to the maximum value allowed, 

except as provided by 40 C.F.R. § 63.1207(g)(2)(v). The average 

value is defined as the sum of the hourly rolling average values 

recorded (each minute) over the previous 12 months, divided by the 

number of rolling averages recorded during that time. The average 

value must not include calibration data, startup data, shutdown data, 

malfunction data, and data obtained when not burning hazardous 

waste;

(ii) Each operating limit (specified in 40 C.F.R. § 63.1209) established 

to maintain compliance with the dioxin/furan emission standard must 

be held within the range of the average value over the previous 12 

months and the maximum or minimum, as appropriate, that is 

allowed, except as provided by 40 C.F.R. § 63.1207(g)(2)(v). The 

average value is defined as the sum of the rolling average values 
Veolia ES Technical Solutions, L.L.C. Page 69 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

recorded over the previous 12 months, divided by the number of 

rolling averages recorded during that time. The average value must 

not include calibration data, startup data, shutdown data, malfunction 

data, and data obtained when not burning hazardous waste;

(iii) The Permittee must feed chlorine at normal feedrates or greater; and

(iv) If the combustor is equipped with carbon injection or carbon bed, 

normal cleaning cycle of the particulate matter control device.

(v) The Administrator may approve an alternative range to that required 

by 40 C.F.R. § 63.1207(g)(2)(i) and (ii) if the Permittee documents 

in the confirmatory performance test plan that it may be problematic 

to maintain the required range during the test. In addition, when 

making the finding of compliance, the Administrator may consider 

test conditions outside of the range specified in the test plan based on 

a finding that the Permittee could not reasonably maintain the range 

specified in the test plan and considering factors including whether 

the time duration and level of the parameter when operations were 

out of the specified range were such that operations during the 

confirmatory test are determined to be reasonably representative of 

normal operations. In addition, the Administrator will consider the 

proximity of the emission test results to the standard.

13. Operating conditions during subsequent testing. [40 C.F.R. § 63.1207(h)] 

(a) Current operating parameter limits established under 40 C.F.R. § 63.1209 

are waived during subsequent comprehensive performance testing.

(b) Current operating parameter limits are also waived during pretesting prior 

to comprehensive performance testing for an aggregate time not to exceed 

720 hours of operation (renewable at the discretion of the Administrator) 

under an approved test plan or if the source records the results of the 

pretesting. Pretesting means:

(i) Operations when stack emissions testing for dioxin/furan, mercury, 

SVM, LVM, particulate matter, or hydrogen chloride/chlorine gas is 

being performed; and

(ii) Operations to reach steady-state operating conditions prior to stack 

emissions testing under 40 C.F.R. § 63.1207(g)(1)(iii).

14. Test methods. [40 C.F.R. § 63.1208] 
Veolia ES Technical Solutions, L.L.C. Page 70 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

The Permittee must use the following test methods to determine compliance with 

the emissions standards of 40 C.F.R. Part 63, Subpart EEE:

(a) Dioxins and furans. [40 C.F.R. § 63.1208(b)(1)]

(i) To determine compliance with the emission standard for dioxins and 

furans, the Permittee must use:

A. Method 0023A, Sampling Method for Polychlorinated 

Dibenzo-p-Dioxins and Polychlorinated Dibenzofurans 

emissions from Stationary Sources, EPA Publication SW-846 

(incorporated by reference—see 40 C.F.R. § 63.14); or

B. Method 23, provided in 40 C.F.R. Part 60, Appendix A, after 

approval by the Administrator.

I. The Permittee may request approval to use Method 23 in 

the performance test plan required under 40 C.F.R. 

§ 63.1207(e)(1)(i) and (ii).

II. In determining whether to grant approval to use Method 

23, the Administrator may consider factors including 

whether dioxin/furan were detected at levels 

substantially below the emission standard in previous 

testing, and whether previous Method 0023 analyses 

detected low levels of dioxin/furan in the front half of 

the sampling train.

III. Sources that emit carbonaceous particulate matter, such 

as coal-fired boilers, and sources equipped with 

activated carbon injection, will be deemed not suitable 

for use of Method 23 unless the Permittee documents 

that there would not be a significant improvement in 

quality assurance with Method 0023A.

(ii) The Permittee must sample for a minimum of 3 hours, and collect a 

minimum sample volume of 2.5 dscm;

(iii) The Permittee may assume that non-detects are present at zero 

concentration.

(b) Mercury. [40 C.F.R. § 63.1208(b)(2)]
Veolia ES Technical Solutions, L.L.C. Page 71 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

The Permittee must use Method 29, provided in 40 C.F.R. Part 60, 

Appendix A, to demonstrate compliance with the emission standard for 

mercury.

(c) Cadmium and lead. [40 C.F.R. § 63.1208(b)(3)]

The Permittee must use Method 29, provided in 40 C.F.R. Part 60, 

Appendix A, to determine compliance with the emission standard for 

cadmium and lead (combined).

(d) Arsenic, beryllium, and chromium. [40 C.F.R. § 63.1208(b)(4)]

The Permittee must use Method 29, provided in 40 C.F.R. Part 60, 

Appendix A, to determine compliance with the emission standard for 

arsenic, beryllium, and chromium (combined).

(e) Hydrogen chloride and chlorine gas. [40 C.F.R. § 63.1208(b)(5)]

(i) Compliance with MACT standards. To determine compliance with 

the emission standard for hydrogen chloride and chlorine gas 

(combined), the Permittee must use:

A. Method 26/26A as provided in 40 C.F.R. Part 60, Appendix A; 

or

B. Methods 320 or 321 as provided in 40 C.F.R. Part 63, 

Appendix A; or

C. ASTM D 6735–01, Standard Test Method for Measurement of 

Gaseous Chlorides and Fluorides from Mineral Calcining 

Exhaust Sources—Impinger Method to measure emissions of 

hydrogen chloride, and Method 26/26A to measure emissions 

of chlorine gas, provided that the Permittee follows the 

following provisions of 40 C.F.R. § 63.1208(b)(5)(C)(1) 

through (6):

I. A test must include three or more runs in which a pair of 

samples is obtained simultaneously for each run 

according to section 11.2.6 of ASTM Method D6735–

01.

II. The Permittee must calculate the test run standard 

deviation of each set of paired samples to quantify data 

precision, according to Equation 1 in 40 C.F.R. 

§ 63.1208(b)(5)(C)(2).
Veolia ES Technical Solutions, L.L.C. Page 72 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

III. The Permittee must calculate the test average relative 

standard deviation (RSDTA) according to Equation 2 in 

40 C.F.R. § 63.1208(b)(5)(i)(C)(3).

IV. If RSDTA is greater than 20 percent, the data are invalid 

and the test must be repeated.

V. The post-test analyte spike procedure of section 11.2.7 

of ASTM Method D6735–01 is conducted, and the 

percent recovery is calculated according to section 12.6 

of ASTM Method D6735–01.

VI. If the percent recovery is between 70 percent and 130 

percent, inclusive, the test is valid. If the percent 

recovery is outside of this range, the data are considered 

invalid, and the test must be repeated.

(ii) Compliance with risk-based limits under 40 C.F.R. § 63.1215. To 

demonstrate compliance with emission limits established under 

§ 63.1215, the Permittee must use Method 26/26A as provided in 40 

C.F.R. Part 60, Appendix A, Method 320 as provided in 40 C.F.R. 

Part 63, Appendix A, Method 321 as provided in 40 C.F.R. Part 63, 

Appendix A, or ASTM D 6735–01, Standard Test Method for 

Measurement of Gaseous Chlorides and Fluorides from Mineral 

Calcining Exhaust Sources—Impinger Method (following the 

provisions of 40 C.F.R. § 63.1208(b)(5)(C)(1) through (6)), except 

that for incinerators, boilers, and lightweight aggregate kilns, the 

Permittee must use Methods 320 or 321 as provided in 40 C.F.R. 

Part 63, Appendix A, or ASTM D 6735–01 to measure hydrogen 

chloride, and Method 26/26A as provided in 40 C.F.R. Part 60,

Appendix A, to measure total chlorine, and calculate chlorine gas by 

difference if:

A. The bromine/chlorine ratio in feedstreams is greater than 5 

percent; or

B. The sulfur/chlorine ratio in feedstreams is greater than 50 

percent.

(f) Particulate matter. [40 C.F.R. § 63.1208(b)(6)]

The Permittee must use Methods 5 or 5I, provided in 40 C.F.R. Part 60, 

Appendix A, to demonstrate compliance with the emission standard for 

particulate matter.
Veolia ES Technical Solutions, L.L.C. Page 73 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(g) Other Test Methods. [40 C.F.R. § 63.1208(b)(7)]

The Permittee may use applicable test methods in EPA Publication SW846, as necessary to demonstrate compliance with requirements of this 

subpart, except as otherwise specified in 40 C.F.R. § 63.1208(b)(2)–(b)(6).

(h) Feedstream analytical methods. [40 C.F.R. § 63.1208(b)(8)]

The Permittee may use any reliable analytical method to determine 

feedstream concentrations of metals, chlorine, and other constituents. It is 

the Permittee’s responsibility to ensure that the sampling and analysis 

procedures are unbiased, precise, and that the results are representative of 

the feedstream.

(i) Opacity. [40 C.F.R. § 63.1208(b)(9)]

The Permittee must use EPA Reference Method 9, provided in 40 C.F.R. 

Part 60, Appendix A.

(j) Nitrogen oxides. [40 C.F.R. § 71.6(a)(3)(i)(B)]

The Permittee must measure the nitrogen oxides emission concentration 

using EPA Reference Method 7 or 7E in Appendix A to 40 C.F.R. Part 60, 

or ASTM D6522–00 (IBR, see 40 C.F.R. § 63.14(b)).

(k) Volatile organic compounds. [40 C.F.R. § 71.6(a)(3)(i)(B)]

The Permittee must measure the volatile organic compounds emission 

concentration using EPA Reference Method 18 and either Method 25 or 

25A.

(l) Sulfur dioxide. [40 C.F.R. § 71.6(a)(3)(i)(B)]

The Permittee must measure the sulfur dioxide emission concentration 

using EPA Reference Methods 6 or 6C.

(E) Recordkeeping and Reporting. [40 C.F.R. § 71.6(a)(3)]

1. Summary of notification requirements. [40 C.F.R. § 63.1210(a)]

(a) The Permittee must submit the following notifications to EPA:
Veolia ES Technical Solutions, L.L.C. Page 74 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

Reference Notification

40 C.F.R. § 63.9(d) Notification that the source is subject to special 

compliance requirements

40 C.F.R. § 63.9(j) Notification and documentation of any change in 

information already provided under 40 C.F.R. 

§ 63.9

40 C.F.R. 

§ 63.1206(b)(5)(i)

Notification of changes in design, operation, or 

maintenance

40 C.F.R. 

§ 63.1206(c)(8)(iv)

Notification of excessive number of bag leak 

detection system exceedances

40 C.F.R. §§ 63.1207(e), 

63.9(e), 63.9(g)(1) and (3)

Notification of performance test and continuous 

monitoring system evaluation, including the 

performance test plan and CMS performance 

evaluation plan*

40 C.F.R. §§ 63.1210(d),

63.1207(j), 63.1207(k),

63.1207(l), 63.9(h),

63.10(d)(2), 63.10(e)(2)

Notification of compliance, including results of 

performance tests and continuous monitoring 

system performance evaluations

* The Permittee may also be required on a case-by-case basis to submit a 

feedstream analysis plan under 40 C.F.R. § 63.1209(c)(3).

(b) The Permittee must submit the following notifications to EPA if the 

Permittee requests or elects to comply with alternative requirements:

Reference Notification, request, petition, or application

40 C.F.R. § 63.9(i) The Permittee may request an adjustment of time 

periods or postmark deadlines for submittal and 

review of required information.

40 C.F.R. 

§ 63.10(e)(3)(ii)

The Permittee may request approval to reduce the 

frequency of excess emissions and CMS 

performance reports.

40 C.F.R. § 63.10(f) The Permittee may request approval to waive 

recordkeeping or reporting requirements.

40 C.F.R. 

§ 63.1206(b)(5)(i)(C)

The Permittee may request approval to burn 

hazardous waste for more than 720 hours and for 

purposes other than testing or pretesting after 

making a change in the design or operation that 

could affect compliance with emission standards 

and prior to submitting a revised NOC.
Veolia ES Technical Solutions, L.L.C. Page 75 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

Reference Notification, request, petition, or application

40 C.F.R. 

§ 63.1206(b)(8)(iii)(B)

If the Permittee elects to conduct particulate matter 

CEMS correlation testing and wishes to have 

federal particulate matter and opacity standards and 

associated operating limits waived during the 

testing, the Permittee must notify the Administrator

by submitting the correlation test plan for review 

and approval.

40 C.F.R. 

§ 63.1206(b)(8)(v)

The Permittee may request approval to have the 

particulate matter and opacity standards and 

associated operating limits and conditions waived 

for more than 96 hours for a correlation test.

40 C.F.R.

§ 63.1206(c)(2)(ii)(C)

The Permittee may request approval to make 

changes to the startup, shutdown, and malfunction 

plan.

40 C.F.R. 

§ 63.1206(c)(5)(i)(C)

The Permittee may request an alternative means of 

control to provide control of combustion system 

leaks.

40 C.F.R. 

§ 63.1206(c)(5)(i)(D)

The Permittee may request other techniques to 

prevent fugitive emissions without use of 

instantaneous pressure limits.

40 C.F.R. 

§ 63.1207(d)(3)

The Permittee may request more than 60 days to 

complete a performance test if additional time is 

needed for reasons beyond its control.

40 C.F.R. 

§§ 63.1207(e)(3), 63.7(h)

The Permittee may request a time extension if the 

Administrator fails to approve or deny its test plan.

40 C.F.R. 

§ 63.1207(h)(2)

The Permittee may request approval to waive 

current operating parameter limits during pretesting 

for more than 720 hours.

40 C.F.R. 

§ 63.1207(f)(1)(ii)(D)

The Permittee may request approval to perform a 

reduced hazardous waste feedstream analysis for 

organic hazardous air pollutants if the reduced 

analysis continues to be representative of organic 

hazardous air pollutants in its hazardous waste 

feedstreams.

40 C.F.R. 

§ 63.1207(g)(2)(v)

The Permittee may request approval to operate 

under a wider operating range for a parameter 

during confirmatory performance testing.

40 C.F.R. § 63.1207(i) The Permittee may request up to a 1-year time 

extension for conducting a performance test (other 

than the initial comprehensive performance test) to 

consolidate testing with other state or federallyrequired testing.
Veolia ES Technical Solutions, L.L.C. Page 76 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

Reference Notification, request, petition, or application

40 C.F.R. § 63.1207(j)(4) The Permittee may request more than 90 days to 

submit a NOC after completing a performance test 

if additional time is needed for reasons beyond its 

control.

40 C.F.R. § 63.1207(l)(3) After failure of a performance test, the Permittee 

may request approval to burn hazardous waste for 

more than 720 hours and for purposes other than 

testing or pretesting.

40 C.F.R. 

§§ 63.1209(a)(5), 63.8(f)

The Permittee may request: (1) approval of 

alternative monitoring methods for compliance with 

standards that are monitored with a CEMS; and (2) 

approval to use a CEMS in lieu of operating 

parameter limits.

40 C.F.R. 

§ 63.1209(g)(1)

The Permittee may request approval of: (1) 

alternatives to operating parameter monitoring 

requirements, except for standards that the 

Permittee must monitor with a CEMS and except 

for requests to use a CEMS in lieu of operating 

parameter limits; or (2) a waiver of an operating 

parameter limit.

40 C.F.R. § 63.1209(l)(1) The Permittee may request approval to extrapolate 

mercury feedrate limits.

40 C.F.R. 

§ 63.1209(n)(2)

The Permittee may request approval to extrapolate 

SVM and LVM feedrate limits.

40 C.F.R. § 63.1211(d) The Permittee may request approval to use data 

compression techniques to record data on a less 

frequent basis than required by 40 C.F.R. 

§ 63.1209.

2. Notification of Compliance. [40 C.F.R. § 63.1210(d)]

(a) The NOC status requirements of 40 C.F.R. § 63.9(h) apply, except that:

(i) The notification is an NOC, rather than compliance status;

(ii) The notification is required for the initial comprehensive 

performance test and each subsequent comprehensive and 

confirmatory performance test; and 

(iii) The Permittee must postmark the notification before the close of 

business on the 90th day following completion of relevant 

compliance demonstration activity specified in 40 C.F.R. Part 63, 

Subpart EEE, rather than the 60th day as required by 40 C.F.R. 

§ 63.9(h)(2)(ii).
Veolia ES Technical Solutions, L.L.C. Page 77 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(b) Upon postmark of the NOC, the Permittee shall comply with the OPLs

identified in the NOC, and the limits identified in the DOC or a previous 

NOC are no longer applicable, except as provided in condition 2.1(C)(2).

(c) The NOC requirements of 40 C.F.R. § 63.1207(j) also apply.

3. Summary of reporting requirements. [40 C.F.R. § 63.1211(a)] 

The Permittee must submit the following reports to the Administrator:

Reference Report

40 C.F.R. § 63.10(d)(5)(i) Periodic startup, shutdown, and malfunction 

reports.

40 C.F.R. § 63.10(d)(5)(ii) Immediate startup, shutdown, and malfunction 

reports.

40 C.F.R. § 63.10(e)(3) Excess emissions and continuous monitoring 

system performance report and summary report.

40 C.F.R. 

§ 63.1206(c)(2)(ii)(B)

Startup, shutdown, and malfunction plan.

40 C.F.R. 

§ 63.1206(c)(3)(vi)

Report on excessive number of exceedances

during malfunctions.

40 C.F.R. 

§ 63.1206(c)(4)(iv)

Emergency safety vent opening reports.

40 C.F.R. 

§ 63.1206(c)(8)(iv)

Reports on excessive number of exceedances from 

the bag leak detection systems.

4. AWFCO excessive exceedance reporting. [40 C.F.R. § 63.1206(c)(3)(vi)]

(a) For every 10 exceedances of an emission standard or operating requirement 

while hazardous waste remains in the combustion chamber (i.e., when the 

hazardous waste residence time has not transpired since the hazardous 

waste feed was cut off) during a 60-day block period, the Permittee must 

submit to the Administrator, within 5 calendar days of the tenth 

exceedance, a written report documenting the exceedances, the results of 

the investigation, and the corrective measures taken.

(b) On a case-by-case basis, the Administrator may require reporting on 

excessive number of exceedances when fewer than 10 exceedances occur 

during a 60-day block period.

5. Notification of excessive number of exceedances from bag leak detection 

system. [40 C.F.R. § 63.1206(c)(8)(iv)]
Veolia ES Technical Solutions, L.L.C. Page 78 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

If the Permittee operates the combustor when the detector response exceeds the 

alarm set-point more than 5 percent of the time during any 6-consecutive month 

period, the Permittee must submit to the Administrator within 30 days of the end 

of the 6-month period a notification that describes the causes of the exceedances 

and the revisions to the design, operation, or maintenance of the combustor or 

baghouse the Permittee is taking to minimize exceedances. To document 

compliance with these requirements the Permittee must:

(a) keep records of the date, time, and duration of each alarm, the time 

corrective action was initiated and completed, and a brief description of the 

cause of the alarm and the corrective action taken; 

(b) record the percent of the operating time during each 6-month period that 

the alarm sounds;

(c) not count the alarm time in calculating the operating time percentage, if 

inspection of the fabric filter demonstrates that no corrective action is 

required; and 

(d) count each alarm as a minimum of 1 hour if corrective action is required.

6. ESV reporting requirements. [40 C.F.R. § 63.1206(c)(4)]

The Permittee must submit to the Administrator within 5 days of an ESV 

opening that results in failure to meet the emission standards of this subpart (as 

determined in 40 C.F.R. § 63.1206(c)(4)(i)) a written report documenting the 

result of the investigation and corrective measures taken. 

7. Periodic startup, shutdown, and malfunction reports. [40 C.F.R. 

§ 63.10(d)(5)(ii)]

If actions taken by the Permittee during a startup, shutdown, or malfunction of an 

affected source (including actions taken to correct a malfunction) are consistent 

with the procedures specified in the source's startup, shutdown, and malfunction 

plan (see 40 C.F.R. § 63.6(e)(3)), and the startup or shutdown causes the source 

to exceed any applicable emission limitation in the relevant emission standards, 

the Permittee shall state such information in a startup, shutdown, and 

malfunction report. Actions taken to minimize emissions during such startups, 

shutdowns, and malfunctions shall be summarized in the report and may be done 

in checklist form; if actions taken are the same for each event, only one checklist 

is necessary. Such a report shall also include the number, duration, and a brief 

description for each type of malfunction which occurred during the reporting 

period and which caused or may have caused any applicable emission limitation 

to be exceeded. Reports shall be required only if a startup or shutdown caused 

the source to exceed any applicable emission limitation in the relevant emission 
Veolia ES Technical Solutions, L.L.C. Page 79 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

standards, or if a malfunction occurred during the reporting period. The startup, 

shutdown, and malfunction report shall consist of a letter containing the name, 

title, and signature of the Permittee or other responsible official who is certifying 

its accuracy, that shall be submitted to the Administrator semiannually (or on a 

more frequent basis if specified otherwise in a relevant standard or as established 

otherwise by the permitting authority in the source’s title V permit). The startup, 

shutdown, and malfunction report shall be delivered or postmarked by the 30th 

day following the end of each calendar half or other calendar reporting period, as 

appropriate). If the Permittee is required to submit excess emissions and 

continuous monitoring system performance (or other periodic) reports under this 

part, the startup, shutdown, and malfunction reports required under this 

paragraph may be submitted simultaneously with the excess emissions and 

continuous monitoring system performance (or other) reports. If startup, 

shutdown, and malfunction reports are submitted with excess emissions and 

continuous monitoring system performance (or other periodic) reports, and the 

Permittee receives approval to reduce the frequency of reporting for the latter 

under 40 C.F.R. § 63.10(e), the frequency of reporting for the startup, shutdown, 

and malfunction reports also may be reduced if the Administrator does not object 

to the intended change. The procedures to implement the allowance in the 

preceding sentence shall be the same as the procedures specified in 40 C.F.R. 

§ 63.10(e)(3).

8. Immediate startup, shutdown, and malfunction reports. [40 C.F.R. 

§ 63.10(d)(5)(ii)]

Notwithstanding the allowance to reduce the frequency of reporting for periodic 

startup, shutdown, and malfunction reports under § 63.10(d)(5)(i), any time an 

action taken by the Permittee during a startup or shutdown that caused the source 

to exceed any applicable emission limitation in the relevant emission standards, 

or malfunction (including actions taken to correct a malfunction) is not 

consistent with the procedures specified in the affected source's startup, 

shutdown, and malfunction plan, the Permittee shall report the actions taken for 

that event within 2 working days after commencing actions inconsistent with the 

plan followed by a letter within 7 working days after the end of the event. The 

immediate report required under 40 C.F.R. § 63.10(d)(5)(ii) shall consist of a 

telephone call (or facsimile (FAX) transmission) to the Administrator within 2 

working days after commencing actions inconsistent with the plan, and it shall be 

followed by a letter, delivered or postmarked within 7 working days after the end 

of the event, that contains the name, title, and signature of the Permittee or other 

responsible official who is certifying its accuracy, explaining the circumstances 

of the event, the reasons for not following the startup, shutdown, and 

malfunction plan, describing all excess emissions and/or parameter monitoring 

exceedances which are believed to have occurred (or could have occurred in the 

case of malfunctions), and actions taken to minimize emissions in conformance 

with § 63.6(e)(1)(i). 
Veolia ES Technical Solutions, L.L.C. Page 80 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

9. Notification of changes in design, operation, or maintenance specified by 

condition 2.1(B)(4). [40 C.F.R. § 63.1206(b)(5)] 

(a) The Permittee must notify the Administrator at least 60 days prior to a 

change (as defined at 40 C.F.R. § 63.1206(b)(5)(iii)) to the design, 

operation, or maintenance practices of the source in a manner that may 

adversely affect compliance with any emission standard that is not 

monitored with a CEMS, unless the Permittee documents circumstances 

that dictate that such prior notice is not reasonably feasible. The 

notification must include:

(i) A description of the changes and which emission standards may be 

affected; and

(ii) A comprehensive performance test schedule and test plan under the 

requirements of 40 C.F.R. § 63.1207(f) that will document 

compliance with the affected emission standard(s).

[40 C.F.R. § 63.1206(b)(5)(i)(A)]

(b) If the Permittee determines that a change will not adversely affect 

compliance with the emission standards or operating requirements, the 

Permittee must document the change in the operating record upon making 

such change. The Permittee must revise as necessary the performance test 

plan, DOC, NOC, and start-up, shutdown, and malfunction plan to reflect 

these changes. [40 C.F.R. § 63.1206(b)(5)(ii)]

(c) Nothing in this permit exempts any changes made pursuant to this 

provision from any applicable requirements under Title I of the CAA. [40 

C.F.R. § 71.6(a)(1)]

10. Notification of performance test and CMS performance evaluation, and approval 

of test plan and CMS performance evaluation plan. [40 C.F.R. § 63.1207(e)]

(a) The provisions of 40 C.F.R. §§ 63.7(b) and (c) and 63.8(e) apply, except:

(i) Comprehensive performance test. The Permittee must submit to the 

Administrator a notification of its intention to conduct a 

comprehensive performance test and CMS performance evaluation 

and a site-specific test plan and CMS performance evaluation test 

plan at least 1 year before the performance test and performance 

evaluation are scheduled to begin.
Veolia ES Technical Solutions, L.L.C. Page 81 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(ii) The Permittee must submit to the Administrator a notification of its 

intention to conduct the comprehensive performance test at least 

60 calendar days before the test is scheduled to begin.

(iii) Confirmatory performance test. The Permittee must submit to the 

Administrator a notification of its intention to conduct a 

confirmatory performance test and CMS performance evaluation and 

a site-specific test plan and CMS performance evaluation test plan at 

least 60 calendar days before the performance test is scheduled to 

begin. The Administrator will notify the Permittee of approval or 

intent to deny approval of the site-specific test plan and CMS 

performance evaluation test plan within 30 calendar days after 

receipt of the original test plans.

(b) The Permittee must make its site-specific test plans and CMS performance 

evaluation test plan available to the public for review no later than 

60 calendar days before initiation of the test. The Permittee must issue a 

public notice to all persons on its facility/public mailing list (developed 

pursuant to 40 C.F.R. §§ 71.11(d)(3)(i)(E) and 124.10(c)(1)(ix)) 

announcing the availability of the test plans and the location where the test 

plans are available for review. The test plans must be accessible to the 

public for 60 calendar days, beginning on the date that the Permittee issues 

its public notice. The location must be unrestricted and provide access to 

the public during reasonable hours and provide a means for the public to 

obtain copies. The notification must include the following information at a 

minimum:

(i) The name and telephone number of the source's contact person;

(ii) The name and telephone number of the regulatory agency's contact 

person;

(iii) The location where the test plans and any necessary supporting 

documentation can be reviewed and copied;

(iv) The time period for which the test plans will be available for public 

review; and

(v) An expected time period for commencement and completion of the 

performance test and CMS performance evaluation test.

(c) Petitions for time extension if Administrator fails to approve or deny test 

plans. The Permittee may petition the Administrator under 40 C.F.R. 

§ 63.7(h) to obtain a “waiver” of any performance test - initial or periodic 

performance test; comprehensive or confirmatory test. The “waiver”
Veolia ES Technical Solutions, L.L.C. Page 82 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

would be implemented as an extension of time to conduct the performance 

test at a later date.

(i) Qualifications for the waiver. 

A. The Permittee may not petition the Administrator for a waiver 

under condition 2.1(E)(10)(c) if the Administrator has issued a 

notification of intent to deny its test plans under 40 C.F.R. 

§ 63.7(c)(3)(i)(B);

B. The Permittee must submit a site-specific emissions testing 

plan and a continuous monitoring system performance 

evaluation test plan at least 1 year before a comprehensive 

performance test is scheduled to begin as required by 40 C.F.R. 

§ 63.1207(c)(1), or at least 60 days before a confirmatory 

performance test is scheduled to begin as required by 40 C.F.R. 

§ 63.1207(d). The test plans must include all required 

documentation, including the substantive content requirements 

of 40 C.F.R. §§ 63.1207(f) and 63.8(e); and

C. The Permittee must make a good faith effort to accommodate 

the Administrator's comments on the test plans.

(ii) Procedures for obtaining a waiver and duration of the waiver: 

A. The Permittee must submit to the Administrator a waiver 

petition or request to renew the petition under 40 C.F.R. 

§ 63.7(h) separately for each source at least 60 days prior to the 

scheduled date of the performance test.

B. The Permittee may submit a revised petition to renew the 

waiver under 40 C.F.R. § 63.7(h)(3)(iii) at least 60 days prior 

to the end date of the most recently approved waiver petition.

(iii) Content of the waiver. 

A. The Permittee must provide documentation to enable the 

Administrator to determine that the source is meeting the 

relevant standard(s) on a continuous basis, as required by 

40 C.F.R. § 63.7(h)(2). For extension requests for the initial 

comprehensive performance test, the Permittee must submit its 

DOC to assist the Administrator in making this determination.

B. The Permittee must include in the petition information 

justifying its request for a waiver, such as the technical or 
Veolia ES Technical Solutions, L.L.C. Page 83 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

economic infeasibility, or the impracticality, of the affected 

source performing the required test, as required by 40 C.F.R. 

§ 63.7(h)(3)(iii).

(iv) Public notice. 

At the same time that the Permittee submits its petition to the 

Administrator, the Permittee must notify the public (e.g., distribute a 

notice to the facility/public mailing list developed pursuant to 

40 C.F.R. §§ 71.11(d)(3)(i)(E) and 124.10(c)(1)(ix)) of its petition to 

waive a performance test. The notification must include all of the 

following information at a minimum:

A. The name and telephone number of the source’s contact 

person;

B. The name and telephone number of the regulatory agency’s 

contact person;

C. The date the source submitted its site-specific performance test 

plan and CMS performance evaluation test plans; and

D. The length of time requested for the waiver.

11. Time extension for subsequent performance tests. [40 C.F.R. § 63.1207(i)] 

After the initial comprehensive performance test, the Permittee may request up to 

a 1-year time extension for conducting a comprehensive or confirmatory 

performance test to consolidate performance testing with other state or federally 

required emission testing, or for other reasons deemed acceptable by the 

Administrator. If the Administrator grants a time extension for a comprehensive 

performance test, the deadlines for commencing the next comprehensive and 

confirmatory tests are based on the date that the subject comprehensive 

performance test commences.

(a) The Permittee must submit in writing to the permitting authority any 

request for a time extension for conducting a performance test.

(b) The Permittee must include in the request for an extension for conducting a 

performance test the following:

(i) A description of the reasons for requesting the time extension;

(ii) The date by which the Permittee will commence performance 

testing.
Veolia ES Technical Solutions, L.L.C. Page 84 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

12. Notification of Compliance. [40 C.F.R. § 63.1207(j)]

(a) Comprehensive performance test. 

(i) Except as provided by 40 C.F.R. § 63.1207(j)(4) and (j)(5), within 

90 days of completion of a comprehensive performance test, the 

Permittee must mail to the Administrator, with a postmark to 

document the submission date, a NOC documenting compliance with 

the emission standards and continuous monitoring system 

requirements, and identifying operating parameter limits under 40 

C.F.R. § 63.1209.

(ii) On and after the date of the postmark of the NOC, the Permittee 

must comply with all operating requirements specified in the NOC in 

lieu of the limits specified in the DOC required under 40 C.F.R. 

§ 63.1211(c).

(b) Confirmatory performance test. Except as provided by 40 C.F.R. 

§ 63.1207(j)(4), within 90 days of completion of a confirmatory 

performance test, the Permittee must mail to the Administrator, with a 

postmark to document the submission date, a NOC documenting 

compliance or noncompliance with the applicable dioxin/furan emission 

standard.

(c) The Permittee must comply with the additional requirements pertaining to 

the NOC (e.g., the Permittee must include results of performance tests in 

the NOC) at 40 C.F.R. §§ 63.7(g), 63.9(h), and 63.1210(d).

(d) Time extension. The Permittee may submit a written request to the 

Administrator for a time extension documenting that, for reasons beyond its 

control, the Permittee may not be able to meet the 90-day deadline for 

submitting the NOC after completion of testing. The Administrator will 

determine whether a time extension is warranted.

(e) Early compliance. If the Permittee conducts the initial comprehensive 

performance test prior to the compliance date, the Permittee must postmark 

the NOC within 90 days of completion of the performance test or by the 

compliance date, whichever is later.

13. Failure to submit a timely NOC. [40 C.F.R. § 63.1207(k)]

(a) If the Permittee fails to mail to the Administrator a NOC by the specified 

date, with a postmark meeting the requirements of this permit, the 

Permittee immediately must cease burning hazardous waste.
Veolia ES Technical Solutions, L.L.C. Page 85 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(b) Prior to submitting a revised NOC as provided by 40 C.F.R. 

§ 63.1207(k)(3), the Permittee may burn hazardous waste only for the 

purpose of pretesting or comprehensive performance testing and only for a 

maximum of 720 hours (renewable at the discretion of the Administrator).

(c) The Permittee must submit to the Administrator a NOC subsequent to a 

new comprehensive performance test before resuming hazardous waste 

burning.

14. Failure of performance test. [40 C.F.R. § 63.1207(l)]

(a) Comprehensive performance test.

The provisions of 40 C.F.R. § 63.1207(l) do not apply to the initial 

comprehensive performance test if the Permittee conducts the test prior to 

its compliance date.

(i) If the Permittee determines (based on CEM recordings, results of 

analyses of stack samples, or results of CMS performance 

evaluations) that the Permittee has exceeded any emission standard 

during a comprehensive performance test for a mode of operation, 

the Permittee must cease hazardous waste burning immediately 

under that mode of operation. The Permittee must make this 

determination within 90 days following completion of the 

performance test.

(ii) If the Permittee has failed to demonstrate compliance with the 

emission standards for any mode of operation:

A. Prior to submitting a revised NOC as provided by 40 C.F.R. 

§ 63.1207(l)(1)(ii)(C), the Permittee may burn hazardous waste 

only for the purpose of pretesting or comprehensive 

performance testing under revised operating conditions, and 

only for a maximum of 720 hours (renewable at the discretion 

of the Administrator), except as provided by 40 C.F.R. 

§ 63.1207(l)(3);

B. The Permittee must conduct a comprehensive performance test 

under revised operating conditions following the requirements 

for performance testing of 40 C.F.R. § 63.1207; and

C. The Permittee must submit to the Administrator a NOC

subsequent to the new comprehensive performance test.

(b) Confirmatory performance test. 
Veolia ES Technical Solutions, L.L.C. Page 86 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

The Permittee must determine within 90 days of the completion of a 

performance test whether it has complied with the dioxin/furan emission 

standard. If the Permittee determines (based on CEM recordings, results of 

analyses of stack samples, or results of CMS performance evaluations) that 

it has failed the dioxin/furan emission standard during a confirmatory 

performance test, the Permittee immediately must cease burning hazardous 

waste. To burn hazardous waste following the failure to comply with the 

dioxin/furan emission standard:

(i) The Permittee must submit to the Administrator for review and 

approval a test plan to conduct a comprehensive performance test to 

identify revised limits on the applicable dioxin/furan operating 

parameters specified in 40 C.F.R. § 63.1209(k);

(ii) The Permittee must submit to the Administrator a NOC with the 

dioxin/furan emission standard under the provisions of 40 C.F.R. 

§ 63.1207(j), (k) and (l). The Permittee must include in the NOC the 

revised limits on the applicable dioxin/furan operating parameters 

specified in 40 C.F.R. § 63.1209(k); and

(iii) Until the NOC is submitted, the Permittee must not burn hazardous 

waste except for purposes of pretesting or confirmatory performance 

testing, and for a maximum of 720 hours (renewable at the discretion 

of the Administrator), except as provided by 40 C.F.R. 

§ 63.1207(l)(3).

(c) The Permittee may petition the Administrator to obtain written approval to 

burn hazardous waste prior to submitting a NOC for purposes other than 

testing or pretesting. The Permittee must specify operating requirements, 

including limits on operating parameters, that the Permittee determines will 

ensure compliance with the emission standards of this subpart based on 

available information including data from the failed performance test. The 

Administrator will review, modify as necessary, and approve if warranted 

the interim operating requirements. An approval of interim operating 

requirements will include a schedule for submitting a NOC.

15. Summary of recordkeeping requirements. [40 C.F.R. § 63.1211(b)] 

The Permittee must retain the following in the operating records applicable to the 

Hazardous Waste Incinerators operated at this site:
Veolia ES Technical Solutions, L.L.C. Page 87 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

Reference Document, Data, or Information

40 C.F.R. 

§§ 63.1200, 63.10(b) 

and (c)

General. Information required to document and maintain 

compliance with the regulations of 40 C.F.R. Part 63, 

Subpart EEE, including data recorded by CMSs, and 

copies of all notifications, reports, plans, and other 

documents submitted to the Administrator.

40 C.F.R. 

§ 63.1206(b)(1)(ii)

If the Permittee elects to comply with all applicable 

requirements and standards promulgated under authority 

of the Clean Air Act, including Sections 112 and 129, in 

lieu of the requirements of 40 C.F.R. Part 63, Subpart 

EEE, when not burning hazardous waste, it must 

document in the operating record that it is in compliance 

with those requirements.

40 C.F.R. 

§ 63.1206(b)(5)(ii)

Documentation that a change will not adversely affect 

compliance with the emission standards or operating 

requirements.

40 C.F.R. 

§ 63.1206(b)(11)

Calculation of hazardous waste residence time.

40 C.F.R. 

§ 63.1206(c)(2)

Startup, shutdown and malfunction plan (SSMP).

40 C.F.R. 

§ 63.1206(c)(2)(v)(A)

Documentation of the Permittee’s investigation and 

evaluation of excessive number of exceedances during 

malfunctions.

40 C.F.R. 

§ 63.1206(c)(3)(v)

Corrective measures for any automatic waste feed cutoff 

that results in an exceedance of an emission standard or 

OPL.

40 C.F.R. 

§ 63.1206(c)(3)(vii)

Documentation and results of the automatic waste feed 

cutoff operability testing.

40 C.F.R. 

§ 63.1206(c)(4)(ii)

Emergency safety vent operating plan.

40 C.F.R. 

§ 63.1206(c)(4)(iii)

Corrective measures for any emergency safety vent 

opening.

40 C.F.R. 

§ 63.1206(c)(5)(ii)

Method used for control of combustion system leaks.

40 C.F.R. 

§ 63.1206(c)(6)

Operator training and certification program.

40 C.F.R. 

§ 63.1206(c)(7)(i)(D)

Operation and maintenance plan.

40 C.F.R. 

§ 63.1209(c)(2)

Feedstream analysis plan.
Veolia ES Technical Solutions, L.L.C. Page 88 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

Reference Document, Data, or Information

40 C.F.R. 

§ 63.1209(k)(6)(iii),

(k)(7)(ii), (k)(9)(ii),

(o)(4)(iii)

Documentation that a substitute activated carbon, 

dioxin/furan formation reaction inhibitor, or dry scrubber 

sorbent will provide the same level of control as the 

original material.

40 C.F.R. 

§ 63.1209(k)(7)(i)(C)

Results of carbon bed performance monitoring.

40 C.F.R. 

§ 63.1209(q)

Documentation of changes in modes of operation

40 C.F.R. 

§ 63.1211(c)

DOC

16. Documentation of Compliance. [40 C.F.R. § 63.1211(c)]

(a) The Permittee must develop and include in the operating record a DOC. 

The Permittee is not subject to this requirement, however, if the Permittee 

submits a NOC under 40 C.F.R. § 63.1207(j) prior to the compliance date. 

Upon inclusion of the DOC in the operating record, hazardous waste 

burning incinerators are no longer subject to compliance with the 

previously applicable NOC.

(b) The DOC must identify the applicable emission standards under 40 C.F.R. 

Part 63, Subpart EEE, and the limits on the operating parameters under 40 

C.F.R. § 63.1209 that will ensure compliance with those emission 

standards.

(c) The Permittee must include a signed and dated certification in the DOC

that:

(i) Required CEMS and CMS are installed, calibrated, and continuously 

operating in compliance with the requirements of 40 C.F.R. Part 63, 

Subpart EEE; and

(ii) Based on an engineering evaluation prepared under the Permittee’s 

direction or supervision in accordance with a system designed to 

ensure that qualified personnel properly gathered and evaluated the 

information and supporting documentation, and considering at a 

minimum the design, operation, and maintenance characteristics of 

the combustor and emissions control equipment, the types, 

quantities, and characteristics of feedstreams, and available 

emissions data:

A. The Permittee is in compliance with the emission standards of 

this subpart; and
Veolia ES Technical Solutions, L.L.C. Page 89 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

B. The limits on the operating parameters under 40 C.F.R. 

§ 63.1209 ensure compliance with the emission standards of 

40 C.F.R. Part 63, Subpart EEE.

(d) The Permittee must comply with the emission standards and operating 

parameter limits specified in the DOC. 

17. Calculation of hazardous waste residence time. [40 C.F.R. § 63.1206(b)(11)]

The Permittee must calculate the hazardous waste residence time and include the 

calculation in the performance test plan under 40 C.F.R. § 63.1207(f) and the 

operating record. The Permittee must also provide the hazardous waste 

residence time in the DOC under 40 C.F.R. § 63.1211(c) and the NOC under 

40 C.F.R. §§ 63.1207(j) and 63.1210(d).

18. Documenting compliance with the standards based on performance testing.

[40 C.F.R. § 63.1206(b)(12)] 

(a) The Permittee must conduct a minimum of three runs of a performance test 

required under 40 C.F.R. § 63.1207 to document compliance with the 

emission standards of this subpart.

(b) The Permittee must document compliance with the emission standards 

based on the arithmetic average of the emission results of each run, except

that the Permittee must document compliance with the DRE standard for 

each run of the comprehensive performance test individually.

19. Compliance with the carbon monoxide and hydrocarbon emission standards. 

[40 C.F.R. § 1206(b)(6)]

If the Permittee elects to comply with the carbon monoxide and hydrocarbon 

emissions standards of 40 C.F.R. Part 63, Subpart EEE, by documenting 

continuous compliance with the carbon monoxide standard using a continuous 

emissions monitoring system and documenting compliance with the hydrocarbon 

standard during the DRE performance test or its equivalent, and a DRE test 

performed pursuant to 40 C.F.R. § 63.1207(c)(2) is acceptable as documentation 

of compliance with the DRE standard, the Permittee may use the highest hourly 

rolling average hydrocarbon level achieved during the DRE test runs to 

document compliance with the hydrocarbon standard. An acceptable DRE test is 

any test for which the data and results are determined to meet quality assurance 

objectives (on a site-specific basis) such that the results adequately demonstrate 

compliance with the DRE standard. 
Veolia ES Technical Solutions, L.L.C. Page 90 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

20. Compliance with the Destruction and Removal Efficiency standard. [40 C.F.R. 

§ 63.1206(b)(7)]

(a) The Permittee must document compliance with the DRE standard under 

this subpart only once provided that the Permittee does not modify the 

source after the DRE test in a manner that could affect the ability of the 

source to achieve the DRE standard.

(b) The Permittee may use any DRE test data that documents that its source 

achieves the required level of DRE provided:

(i) The Permittee has not modified the design or operation of its source 

in a manner that could affect the ability of its source to achieve the 

DRE standard since the DRE test was performed; and,

(ii) The DRE test data meet quality assurance objectives determined on a 

site-specific basis.

21. The Permittee shall maintain all records for five calendar years and make them 

available at all times for inspection by EPA, Illinois EPA, local agencies, or their 

duly authorized representatives. [40 C.F.R. § 71.6(a)(3)(i)(B)]

2.2. MATERIAL PROCESSING AREAS

(A) Emission Limitations and Standards [40 C.F.R. § 71.6(a)(1)]

1. National Emission Standards for Hazardous Air Pollutants from Off-Site Waste 

and Recovery Operations. [40 C.F.R. Part 63, Subpart DD]

For a container having a design capacity greater than 0.1 m3and less than or 

equal to 0.46 m3, the Permittee must control air emissions from the container in 

accordance with the standards for Container Level 1 controls as specified in 40 

C.F.R. Part 63, Subpart PP, National Emission Standards for Containers.

[40 C.F.R. § 63.688(b)(1)(i)]

2. National Emission Standards for Containers. [40 C.F.R. Part 63, Subpart PP]

40 C.F.R. § 63.922(b)(1) through (3) define Container Level 1 controls as one of 

the following:

(a) A container that meets the applicable U.S. Department of Transportation 

(U.S. DOT) regulations on packaging hazardous materials for 

transportation as specified in paragraph 40 C.F.R. § 63.922(f). 

 
Veolia ES Technical Solutions, L.L.C. Page 91 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(b) A container equipped with a cover and closure devices that form a 

continuous barrier over the container openings such that when the cover 

and closure devices are secured in the closed position there are no visible 

holes, gaps, or other open spaces into the interior of the container. The 

cover may be a separate cover installed on the container (e.g., a lid on a 

drum, a suitably secured tarp on a roll-off box) or may be an integral part 

of the container structural design (e.g., a bulk cargo container equipped 

with a screw-type cap).

 

(c) An open-top container in which an organic vapor-suppressing barrier is 

placed on or over the regulated-material in the container such that no 

regulated-material is exposed to the atmosphere. One example of such a 

barrier is application of a suitable organic-vapor suppressing foam. 

3. Organic material emissions limitations. [35 IAC 219.301]

The Permittee shall not cause or allow the discharge of more than 3.6 kg/hr (8 

lb/hr) of organic material into the atmosphere from any emission unit, except as 

provided in 35 IAC 219.302, 219.303 or 219.304 and the following exception: If 

no odor nuisance exists this limitation shall apply only to photochemically 

reactive material.

4. Visible emissions limitations.

(a) Except as provided in condition 2.2(A)(4)(b), below, the Permittee shall not

cause or allow the emission of smoke or other particulate matter, with an 

opacity greater than 30 percent. [35 IAC 212.123(a)]

(b) The emission of smoke or other particulate matter from any such emission 

source may have an opacity greater than 30 percent but not greater than 60 

percent for a period or periods aggregating 8 minutes in any 60 minute 

period, provided that such more opaque emissions permitted during any 60 

minute period shall occur from only one such emission source located 

within a 305 m (1000 ft) radius from the center point of any other such 

emission source owned or operated by such person, and provided further 

that such more opaque emissions permitted from each such emission source 

shall be limited to 3 times in any 24 hour period. [35 IAC 212.123(b)]

(B) Nonapplicable Regulations [40 C.F.R. § 71.6(f)(1)]

1. Units MP-1, MP-2, and the Lab Pack Repack are not subject to 40 C.F.R. Part 

64, Compliance Assurance Monitoring (CAM) for Major Stationary Sources, 

because they do not use an add-on control device to achieve compliance with an 

emission limitation or standard. [40 C.F.R. § 64.2(a)]
Veolia ES Technical Solutions, L.L.C. Page 92 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

2. The conveyor systems associated with MP-1 and MP-2 are not subject to the 

requirements of 40 C.F.R. Part 63, Subpart DD, for transfer systems, because this 

equipment is used in the conveyance of material using a container. [40 C.F.R. 

§ 63.681]

3. Units MP-1, MP-2 and the Lab Pack Repack are not subject to the requirements 

of 40 C.F.R. Part 61, Subpart BB, because this source is not part of a benzene 

production facility. [40 C.F.R. § 61.300]

(C) Work Practice and Operational Requirements [40 C.F.R. § 71.6(a)(1)]

The affected waste processing units are subject to the following control requirements 

and work practices established by 40 C.F.R. § 63.922(c), (d) and (e): 

1. A container used to meet the requirements of either 40 C.F.R. § 63.922(b)(2) or 

(b)(3) shall be equipped with covers and closure devices, as applicable to the 

container, that are composed of suitable materials to minimize exposure of the 

regulated-material to the atmosphere and to maintain the equipment integrity for 

as long as it is in service. Factors to be considered when selecting the materials 

for and designing the cover and closure devices shall include: organic vapor 

permeability, the effects of contact with the material or its vapor managed in the 

container; the effects of outdoor exposure to wind, moisture, and sunlight; and 

the operating practices used for container on which the cover is installed.

[40 C.F.R. § 63.922(c)]

2. Whenever a regulated-material is in a container using Container Level 1 controls, 

the Permittee shall install all covers and closure devices for the container, and 

secure and maintain each closure device in the closed position except as follows: 

(a) Opening of a closure device or cover is allowed for the purpose of adding 

material to the container as follows: 

(i) In the case when the container is filled to the intended final level in 

one continuous operation, the Permittee shall promptly secure the 

closure devices in the closed position and install the covers, as 

applicable to the container, upon conclusion of the filling operation. 

(ii) In the case when discrete quantities or batches of material 

intermittently are added to the container over a period of time, the 

Permittee shall promptly secure the closure devices in the closed 

position and install covers, as applicable to the container, upon 

either: the container being filled to the intended final level; the 

completion of a batch loading after which no additional material will 

be added to the container within 15 minutes; the person performing 

the loading operation leaves the immediate vicinity of the container; 
Veolia ES Technical Solutions, L.L.C. Page 93 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

or the shutdown of the process generating the material being added 

to the container, whichever condition occurs first.

(b) Opening of a closure device or cover is allowed for the purpose of 

removing material from the container as follows:

(i) For the purpose of meeting the requirements of condition 2.2(C)(2), 

an empty container as defined in 40 C.F.R. § 63.921 may be open to 

the atmosphere at any time (e.g., covers and closure devices are not 

required to be secured in the closed position on an empty container).

(ii) In the case when discrete quantities or batches of material are 

removed from the container but the container does not meet the 

conditions to be an empty container as defined in 40 C.F.R. 

§ 63.921, the Permittee shall promptly secure the closure devices in 

the closed position and install covers, as applicable to the container, 

upon the completion of a batch removal after which no additional 

material will be removed from the container within 15 minutes, or 

the person performing the unloading operation leaves the immediate 

vicinity of the container, whichever condition occurs first.

(c) Opening of a closure device or cover is allowed when access inside the 

container is needed to perform routine activities other than transfer of 

regulated-material. Examples of such activities include those times when a 

worker needs to open a port to measure the depth of or sample the material 

in the container, or when a worker needs to open a manhole hatch to access 

equipment inside the container. Following completion of the activity, the 

Permittee shall promptly secure the closure device in the closed position or 

reinstall the cover, as applicable to the container. 

(d) Opening of a spring-loaded pressure-vacuum relief valve, conservation 

vent, or similar type of pressure relief device which vents to the atmosphere 

is allowed during normal operations for the purpose of maintaining the 

container internal pressure in accordance with the container design 

specifications. The device shall be designed to operate with no detectable 

organic emissions when the device is secured in the closed position. The 

settings at which the device opens shall be established such that the device 

remains in the closed position whenever the container internal pressure is 

within the internal pressure operating range determined by the Permittee

based on container manufacturer recommendations, applicable regulations, 

fire protection and prevention codes, standard engineering codes and 

practices, or other requirements for the safe handling of flammable, 

ignitable, explosive, reactive, or hazardous materials. Examples of normal 

operating conditions that may require these devices to open are during 

those times when the container internal pressure exceeds the internal 
Veolia ES Technical Solutions, L.L.C. Page 94 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

pressure operating range for the container as a result of loading operations 

or diurnal ambient temperature fluctuations.

(e) Opening of a safety device, as defined in 40 C.F.R. § 63.921, is allowed at 

any time conditions require it to avoid an unsafe condition. [40 C.F.R. 

§ 63.922(d)]

3. Inspection of containers using Container Level 1 controls [40 C.F.R. 

§ 63.922(e)]: 

The Permittee shall inspect containers using Container Level 1 controls in 

accordance with the procedures specified in 40 C.F.R. § 63.926(a). 

4. Containers that meet the applicable U.S. DOT regulations on packaging 

hazardous materials for transportation [40 C.F.R. § 63.922(f)]:

For the purpose of compliance with 40 C.F.R. § 63.922(b)(1), the Permittee shall 

use containers that meet the applicable U.S. DOT regulations on packaging 

hazardous materials for transportation as follows:

(a) The container must meet the applicable requirements specified in 49 C.F.R.

Part 178 “Specifications for Packagings” or 49 C.F.R. Part 179

“Specifications for Tank Cars.”

(b) Regulated-material is managed in the container in accordance with the 

applicable requirements specified in 49 C.F.R. Part 107, Subpart B,

“Exemptions;” 49 C.F.R. Part 172, “Hazardous Materials Table, Special 

Provisions, Hazardous Materials Communications, Emergency Response 

Information, and Training Requirements;” 49 C.F.R. Part 173, “Shippers—

General Requirements for Shipments and Packaging;” and 49 C.F.R. Part 

180, “Continuing Qualification and Maintenance of Packagings.”

(c) For the purpose of complying with 40 C.F.R. Part 63, Subpart PP, no 

exceptions to the 49 C.F.R. Part 178 or Part 179 regulations are allowed,

except as provided in condition 2.2(C)(4)(iv) of this permit, below.

(d) For a lab pack that is managed in accordance with the requirements of 

49 C.F.R. Part 178 for the purpose of complying with 40 C.F.R. Part 63, 

Subpart PP, the Permittee may comply with the exceptions for those 

packagings specified in 49 C.F.R. § 173.12(b).

(D) Monitoring and Testing [40 C.F.R. § 71.6(a)(3)(i)(A)]

1. Procedures to determine that there are no detectable organic emissions for the 

purpose of complying with 40 C.F.R. Part 63, Subpart PP. [40 C.F.R. 

§ 63.925(a)]
Veolia ES Technical Solutions, L.L.C. Page 95 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(a) The Permittee shall conduct the test annually in accordance with the 

procedures specified in Method 21 of 40 C.F.R. Part 60, Appendix A. The 

Permittee shall check each potential leak interface (i.e., a location where 

organic vapor leakage could occur) on the cover and associated closure 

devices. Potential leak interfaces that are associated with covers and 

closure devices include, but are not limited to: the interface of the cover 

and its foundation mounting; the periphery of any opening on the cover and 

its associated closure device; and the sealing seat interface on a springloaded pressure-relief valve. [40 C.F.R. § 63.925(a)(1)]

(b) The Permittee shall perform the test when the unit contains a material 

having a total organic concentration representative of the range of 

concentrations for the materials expected to be managed in the unit. 

During the test, the cover and closure devices shall be secured in the closed 

position. [40 C.F.R. § 63.925(a)(2)]

(c) The detection instrument shall meet the performance criteria of Method 21 

of 40 C.F.R. Part 60, Appendix A, except the instrument response factor 

criteria in section 3.1.2(a) of Method 21 shall be the criteria for the average 

composition of the organic constituents in the material placed in the unit, 

not for each individual organic constituent. [40 C.F.R. § 63.925(a)(3)]

(d) The detection instrument shall be calibrated before use on each day of its 

use by the procedures specified in Method 21 of 40 C.F.R. Part 60, 

Appendix A. [40 C.F.R. § 63.925(a)(4)]

(e) Calibration gases shall be as follows: [40 C.F.R. § 63.925(a)(5)]

(i) Zero air (less than 10 ppmv hydrocarbon in air); and

(ii) A mixture of methane or n-hexane in air at a concentration of 

approximately, but less than 10,000 ppmv.

(f) The Permittee may choose to adjust or not adjust the detection instrument 

readings to account for the background organic concentration level. If the 

Permittee chooses to adjust the instrument readings for the background 

level, the background level value must be determined according to the 

procedures in Method 21 of 40 C.F.R. Part 60, Appendix A. [40 C.F.R.

§ 63.925(a)(6)]

(g) The Permittee must check each potential leak interface by traversing the

instrument probe around the potential leak interface as close to the interface 

as possible, as described in Method 21. In the case when the configuration 

of the cover or closure device prevents a complete traverse of the interface, 
Veolia ES Technical Solutions, L.L.C. Page 96 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

all accessible portions of the interface shall be sampled. In the case when 

the configuration of the closure device prevents any sampling at the 

interface and the device is equipped with an enclosed extension or horn 

(e.g., some pressure relief devices), the instrument probe inlet shall be 

placed at approximately the center of the exhaust area to the atmosphere.

[40 C.F.R. § 63.925(a)(7)]

(h) The Permittee must determine if a potential leak interface operates with no 

detectable emissions using the applicable procedure specified in condition

2.2(D)(8)(a) or (b), below. [40 C.F.R. § 63.925(a)(8)]

(i) If the Permittee chooses not to adjust the detection instrument 

readings for the background organic concentration level, then the 

maximum organic concentration value measured by the detection 

instrument is compared directly to the applicable value for the 

potential leak interface as specified in 40 C.F.R. § 63.925(a)(9).

(ii) If the Permittee chooses to adjust the detection instrument readings 

for the background organic concentration level, the value of the 

arithmetic difference between the maximum organic concentration 

value measured by the instrument and the background organic 

concentration value as determined in 40 C.F.R. § 63.925(a)(6) is 

compared with the applicable value for the potential leak interface as 

specified in paragraph 40 C.F.R. § 63.925 (a)(9).

(i) A potential leak interface is determined to operate with no detectable 

emissions using the applicable criteria specified in condition 2.2(D)(9)(a) 

and (b), below. [40 C.F.R. § 63.925(a)(9)]

(i) For a potential leak interface other than a seal around a shaft that 

passes through a cover opening, the potential leak interface is 

determined to operate with no detectable organic emissions if the 

organic concentration value determined in condition 2.2(D)(8), 

above, is less than 500 ppmv.

(ii) For a seal around a shaft that passes through a cover opening, the 

potential leak interface is determined to operate with no detectable 

organic emissions if the organic concentration value determined in 

condition 2.2(D)(8), above, is less than 10,000 ppmv. 

2. Procedure for determining a container to be vapor-tight for the purpose of 

complying with 40 C.F.R. Part 63, Subpart PP. [40 C.F.R. § 63.925(b)]

(a) The Permittee shall perform the test in accordance with Method 27 of 

40 C.F.R. Part 60, Appendix A.
Veolia ES Technical Solutions, L.L.C. Page 97 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(b) The Permittee shall use a pressure measurement device that has a precision 

of ± 2.5 mm water and that is capable of measuring above the pressure at 

which the container is to be tested for vapor tightness.

(c) If the test results determined by Method 27 indicate that the container 

sustains a pressure change less than or equal to 750 Pascals within 5 

minutes after it is pressurized to a minimum of 4,500 Pascals, then the 

container is determined to be vapor-tight.

3. The Permittee shall inspect each container that uses either Container Level 1 or 

Container Level 2 controls and its cover and closure devices as described in 

conditions 2.2(D)(3)(a)-(c), below: [40 C.F.R. § 63.926]

(a) In the case when a regulated-material already is in the container at the time 

the Permittee first accepts possession of the container at the facility site and 

the container is not emptied (i.e., does not meet the conditions for an empty 

container as defined in 63.921) within 24 hours after the container has been 

accepted at the facility site, the Permittee shall visually inspect the

container and its cover and closure devices to check for visible cracks, 

holes, gaps, or other open spaces into the interior of the container when the 

cover and closure devices are secured in the closed position. This 

inspection of the container must be conducted on or before the date that the 

container is accepted at the facility (i.e., the date that the container becomes 

subject to the standards under this subpart). For the purpose of this 

requirement, the date of acceptance is the date of signature of the Permittee

on the manifest or shipping papers accompanying the container. If a defect 

is detected, the Permittee shall repair the defect in accordance with the 

requirements of 40 C.F.R. § 63.926(a)(3).

(b) In the case when a container filled or partially filled with regulated-material 

remains unopened at the facility site for a period of 1 year or more, the

Permittee shall visually inspect the container and its cover and closure 

devices initially and thereafter, at least once every calendar year, to check 

for visible cracks, holes, gaps, or other open spaces into the interior of the 

container when the cover and closure devices are secured in the closed 

position. If a defect is detected, the Permittee shall repair the defect in 

accordance with the requirements of paragraph 40 C.F.R. § 63.926(a)(3).

(c) When a defect is detected for the container, cover, or closure devices, the 

Permittee must either empty the regulated-material from the defective 

container in accordance with 40 C.F.R. § 63.926(a)(3)(i) or repair the 

defective container in accordance with 40 C.F.R. § 63.926(a)(3)(ii).

(i) If the Permittee elects to empty the regulated-material from the 

defective container, the Permittee must remove the regulatedmaterial from the defective container to meet the conditions for an 
Veolia ES Technical Solutions, L.L.C. Page 98 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

empty container (as defined in 40 C.F.R. § 63.921) and transfer the 

removed regulated-material to either a container that meets the 

applicable standards under this subpart or to a tank, process, or 

treatment unit that meets the applicable standards under the subpart 

referencing this subpart. Transfer of the regulated-material must be 

completed no later than 5 calendar days after detection of the defect. 

The emptied defective container must be repaired, destroyed, or used 

for purposes other than management of regulated-material. 

(ii) If the Permittee elects not to empty the regulated-material from the 

defective container, the Permittee must repair the defective 

container. First efforts at repair of the defect must be made no later 

than 24 hours after detection and repair must be completed as soon 

as possible but no later than 5 calendar days after detection. If repair 

of a defect cannot be completed within 5 calendar days, then the 

regulated-material must be emptied from the container and the 

container must not be used to manage regulated-material until the 

defect is repaired. 

4. The Permittee shall visually survey units MP-1, MP-2, and the Lab Pack Repack

each day for the presence of visible emissions or fugitive emissions of particulate 

matter. [40 C.F.R. § 71.6(a)(3)(i)(B)]

(a) If the Permittee identifies any visible emissions or fugitive emissions of 

particulate matter by visual observation, the Permittee shall:

(i) Immediately, upon conclusion of the visual observation, investigate 

the source and reason for the presence of visible emissions or 

fugitive emissions; and

(ii) As soon as practicable, take appropriate corrective action. 

(b) If the corrective actions undertaken do not eliminate the visible or fugitive 

emissions, the Permittee shall, within 24 hours of the initial survey,

conduct a test using EPA Reference Method 9 at 40 C.F.R. Part 60, 

Appendix A.

(i) If any of the visible emissions observations indicate visible 

emissions greater than 20 percent opacity, the Permittee shall 

conduct daily visible emissions observations, for 30 minutes, of the 

emission point in question until 2 consecutive daily observations 

indicate visible emissions of 20 percent opacity or less.

(ii) If the Method 9 visible emissions observations, or if 2 consecutive 

daily observations, indicate visible emissions of 20 percent opacity 
Veolia ES Technical Solutions, L.L.C. Page 99 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

or less, the Permittee shall conduct weekly visible emissions 

observations of the emission point for 3 additional weeks. 

 

(E) Recordkeeping and Reporting [40 C.F.R. §71.6(a)(3)]

1. The Permittee shall promptly notify the permitting authority of deviations of the 

affected waste processing units with the permit requirements, pursuant to 

40 C.F.R. § 71.6(a)(3)(iii)(B). Reports shall describe the probable cause of such 

deviations, and any corrective actions or preventive measures taken. 

[40 C.F.R. § 71.6(a)(3)(iii)(B)]

2. The Permittee shall maintain the following records of the fugitive emissions: 

(a) Details of each visual survey or visible emissions observation, including 

date, time, observer and results for each emission unit and any other 

pollutant emitting activity;

(b) Date, time and type of any investigation conducted;

(c) Findings of the investigation, including the reasons for the presence of 

visible emissions or fugitive emissions of particulate matter;

(d) Date, time and type of corrective actions taken; and

(e) Results of any Method 9 visible emissions observations conducted on the 

source of visible or fugitive emissions. 

[40 C.F.R. § 71.6(a)(3)(i)(B)]

3. VOM/HAP emissions from waste processing operations located at MP-1, MP-2 

and the Lab Pack Repack shall be calculated using the Emission Inventory 

Improvement Program’s surface evaporation model for calculating emissions 

from surface evaporation of VOM from open or partially covered mixing tanks 

during coating mixing operations, Methods for Estimating Air Emissions from 

Paint, Ink, and Other Coating Manufacturing Facilities, Volume II: Chapter 8,

Equation 8.4-22 (February 2005 or later version). In addition, the Permittee shall 

use the most recent version of the TANKS program or the equations and 

algorithms specified in Chapter 7 of AP-42 for estimating any VOM or HAPs

emitted from any enclosed storage tanks located in MP-1, MP-2 and the Lab 

Pack Repack. [40 C.F.R. § 71.6(a)(3)(i)(B)] 

2.3 DRUM CRUSHER
Veolia ES Technical Solutions, L.L.C. Page 100 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(A) Emission Limitations and Standards [40 C.F.R. § 71.6(a)(1)]

1. The Permittee shall not cause or allow the emission of particulate matter into the 

atmosphere in any one hour period from any new process emission unit, either 

alone or in combination with the emission of particulate matter from all other 

similar process emission units for which construction or modification 

commenced on or after April 14, 1972, at a source or premises, which exceeds 

the allowable emission rates specified in 35 IAC 212.321(c). [35 IAC 

212.321(a)]

2. The Permittee shall not cause or allow the discharge of more than 3.6 kg/hr (8 

lbs/hr) of organic material into the atmosphere from any emission unit, except as 

provided in 35 IAC 219.302, 219.303, and 219.304 and the following exception: 

If no odor nuisance exists this limitation shall apply only to photochemically 

reactive material. [35 IAC 219.301]

3. Pursuant to 35 IAC 212.123(a), the Permittee shall not cause or allow the 

emission of smoke or other particulate matter, with an opacity greater than 30 

percent, into the atmosphere from any emission unit other than those emission 

units subject to the requirements of 35 IAC 212.122, except as allowed by 35 

IAC 212.123(b) and 212.124. [35 IAC 212.123(a)]

(B) Nonapplicable Regulations [40 C.F.R. § 71.6(f)(1)]

The drum crusher is not subject to 40 C.F.R. Part 64, Compliance Assurance 

Monitoring for Major Stationary Sources, because it does not use an add-on control 

device to achieve compliance with an emission limitation or standard. [40 C.F.R. 

§ 64.2(a)]

(C) Work Practice and Operational Requirements [40 C.F.R. § 71.6(a)(1)]

[Reserved]

(D) Monitoring and Testing [40 C.F.R. § 71.6(a)(3)(i)(A)]

1. The Permittee shall visually survey the drum crusher each day for the presence 

of visible emissions or fugitive emissions of particulate matter. [40 C.F.R. § 

71.6(a)(3)(i)(B)]

2. If the observations conducted identify any visible emissions or fugitive emissions 

of particulate matter, the Permittee shall:

(a) Immediately, upon conclusion of the visual observation, investigate the 

source and reason for the presence of visible emissions or fugitive 

emissions; and
Veolia ES Technical Solutions, L.L.C. Page 101 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(b) As soon as practicable, take appropriate corrective action. 

[40 C.F.R. § 71.6(a)(3)(i)(B)]

3. If the corrective actions undertaken pursuant to condition 2.3(D)(2), above, do 

not eliminate the visible or fugitive emissions, the Permittee shall, within 24 

hours of the initial survey, conduct a test using EPA Reference Method 9 at

40 C.F.R. Part 60, Appendix A.

(a) If any of the visible emissions observations indicate visible emissions 

greater than 20 percent opacity, the Permittee shall conduct Method 9 

visible emissions observations of the emission point in question for 30

minutes each day, until 2 consecutive daily observations indicate visible 

emissions of 20 percent opacity or less.

(b) If the Method 9 visible emissions observation or if 2 consecutive daily 

observations indicate visible emissions of 20 percent opacity or less, the 

Permittee shall conduct weekly visible emissions observations of the 

emission point for 3 additional weeks.

[40 C.F.R. § 71.6(a)(3)(i)(B)]

(E) Recordkeeping and Reporting [40 C.F.R. § 71.6(a)(3)]

 

1. The Permittee shall maintain records of the total number of drums crushed 

(drums/hour and drums/year) for the drum crusher. [40 C.F.R. §

71.6(a)(i)(3)(B)]

2. The Permittee shall calculate and keep records of VOM emissions from the drum 

crusher based on the emission factor equal to 0.0221 lb VOM per drum crushed. 

This emission factor is based on a characterization of the drum residue as 

containing the most prevalent organics at the concentrations present in the waste 

received during 2007- 2011. [40 C.F.R. § 71.6(a)(i)(3)(B)] 

3. The Permittee shall maintain the following records of the fugitive emissions: 

(a) Details of each visual survey or visible emissions observation, including 

date, time, observer and results for each emission unit and any other 

pollutant emitting activity;

(b) Date, time and type of any investigation conducted;

(c) Findings of the investigation, including the reasons for the presence of 

visible emissions or fugitive emissions of particulate matter;
Veolia ES Technical Solutions, L.L.C. Page 102 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(d) Date, time and type of corrective actions taken; and

(e) Results of any Method 9 visible emissions observations conducted on the 

source of visible or fugitive emissions.

[40 C.F.R. § 71.6(a)(3)(i)(B)]

2.4 LIQUID WASTE STORAGE TANKS

(A) Emission Limitations and Standards [40 C.F.R. § 71.6(a)(1)]

1. National Emission Standards for Hazardous Air Pollutants for Benzene Waste 

Operations. [40 C.F.R. Part 61, Subpart FF]

(a) Each affected liquid waste storage tank is subject to the emission standards 

and requirements established in 40 C.F.R. Part 61, Subpart FF, National 

Emission Standards for Hazardous Air Pollutants for Benzene Waste 

Operations, when benzene-containing waste is stored in the tank.

[40 C.F.R. § 61.340]

(b) For each affected liquid waste storage tank, the Permittee shall install, 

operate, and maintain a fixed-roof and closed-vent system that routes all 

organic vapors vented from the tank to a control device, pursuant to 

40 C.F.R. §§ 61.343 and 61.349.

(i) The fixed roof shall meet the following requirements: [40 C.F.R. 

§ 61.343(a)(1)]

A. The cover and all openings (e.g., access hatches, sampling 

ports, and gauge wells) shall be designed to operate with no 

detectable emissions as indicated by an instrument reading less 

than 500 parts per million by volume (ppmv) above 

background, as determined initially, and thereafter at least once 

per year, by the methods specified in 40 C.F.R. § 61.355(h).

B. Each opening shall be maintained in a closed, sealed position 

(e.g., covered by a lid that is gasketed and latched) at all times 

that waste is in the tank except when it is necessary to use the 

opening for waste sampling or removal, or for equipment 

inspection, maintenance, or repair.

(ii) The closed-vent system and control device shall be designed and 

operated in accordance with the following requirements of 40 C.F.R. 

§ 61.349:
Veolia ES Technical Solutions, L.L.C. Page 103 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

A. The closed-vent system shall be designed to operate with no 

detectable emissions as indicated by an instrument reading of 

less than 500 ppmv above background, as determined initially, 

and thereafter at least once per year, by the methods specified 

in 40 C.F.R. § 61.355(h).

B. The control device shall be designed and operated in 

accordance with the following conditions: A vapor recovery 

system (e.g., a carbon adsorption system or a condenser) shall 

recover or control the organic emissions vented to it with an 

efficiency of 95 weight percent or greater, or shall recover or 

control the benzene emissions vented to it with an efficiency of 

98 weight percent or greater. 

C. The Permittee shall operate each closed-vent system and 

control device used to comply with 40 C.F.R. Part 61, Subpart 

FF, at all times that waste is placed in the waste management 

unit vented to the control device, except when maintenance or 

repair of the waste management unit cannot be completed 

without a shutdown of the control device. 

2. National Emission Standards for Hazardous Air Pollutants from Off-Site Waste 

and Recovery Operations. [40 C.F.R. Part 63, Subpart DD]

(a) Each affected liquid waste storage tank is subject to the emission standards 

and requirements established in 40 C.F.R. Part 63, Subpart DD, National 

Emission Standards for Hazardous Air Pollutants from Off-Site Waste and 

Recovery Operations, when non-benzene waste is stored in the tank. 

[40 C.F.R. § 63.680]

(b) Although the affected waste liquid storage tanks are subject to 40 C.F.R. 

Part 63, Subpart DD, the tanks (defined by 40 C.F.R. Part 63, Subpart DD,

as off-site material management units) are exempted from the control 

requirements of 40 C.F.R. § 63.683(b)(1) if such units are subject to 

another subpart or 40 C.F.R. Part 63 or 61 and the HAP emissions 

(identified in Table 1 of 40 C.F.R. Part 63, Subpart DD) are controlled. 

[40 C.F.R. § 63.683(b)(2)(i)]

3. Standards of Performance for Volatile Organic Liquid Storage Vessels 

(Including Petroleum Liquid Storage Vessels) for Which Construction, 

Reconstruction, or Modification Commenced After July 23, 1984. [40 C.F.R. 

Part 60, Subpart Kb]

(a) The affected liquid waste storage tanks #300, #302, #304, #306, #308 and 

#310, each of which has a capacity greater than 75 cubic meters (19,813 
Veolia ES Technical Solutions, L.L.C. Page 104 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

gallons), are subject to the emission standards and requirements established 

in 40 C.F.R. Part 60, Subpart Kb. [40 C.F.R. § 60.110b(a)]

(b) The Permittee shall equip each applicable storage tank with a closed vent 

system and control device meeting the following specifications: [40 C.F.R. 

§ 60.112b(a)(3)]

(i) The closed vent system shall be designed to collect all VOC vapors 

and gases discharged from the storage vessel and operated with no 

detectable emissions as indicated by an instrument reading of less 

than 500 ppm above background and visual inspections, as

determined in 40 C.F.R. § 60.485(b).

 

(ii) The control device shall be designed and operated to reduce inlet 

VOC emissions by 95 percent or greater.

4. Organic material emissions limitation from Construction Permit 88030101:

Emissions of organic material from Tank Farm #3 shall not exceed 2.5 tons per 

year. [Construction Permit 88030101]

5. Each affected liquid waste storage tank is subject to 35 IAC 219.129(f) and 35 

IAC 219.122(b):

(a) The Permittee shall maintain readily accessible records of the dimension 

and analysis of the capacity of each affected liquid waste storage tank. [35 

IAC 219.129(f)]

(b) Each affected liquid waste storage tank should be equipped with a 

permanent submerged loading pipe. [35 IAC 219.122(b)]

(B) Nonapplicable Regulations [40 C.F.R. § 71.6(f)(1)]

1. The affected liquid waste storage tanks are not subject to the control 

requirements of 35 IAC 219.120, 219.121 and 219.123 because these storage 

tanks have less than 151 m3(40,000 gal) capacity. [35 IAC 219.119, 219.121, 

219.123(a)(2)]

2. The affected liquid waste storage tanks are not subject to 40 C.F.R. Part 64, 

Compliance Assurance Monitoring for Major Stationary Sources, because:

(a) The affected liquid waste storage tanks are required to comply with a 

NESHAP proposed after November 15, 1990. Emission limitations or 

standards proposed by the Administrator after November 15, 1990 pursuant 

to section 111 or 112 of the Act are exempt from CAM. [40 C.F.R. 

§ 64.2(b)(1)(i)]
Veolia ES Technical Solutions, L.L.C. Page 105 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(b) Each affected liquid waste storage tank has potential pre-control device 

emissions of the applicable regulated air pollutants that are less than major 

source levels as defined in 40 C.F.R. § 64.2(a)(3). [40 C.F.R. § 64.2(a)(3)]

(C) Work Practice and Operational Requirements [40 C.F.R. § 71.6(a)(1)]

[Reserved]

(D) Monitoring and Testing [40 C.F.R. § 71.6(a)(3)(i)(A)]

1. Pursuant to 40 C.F.R. § 61.343(a)(1), the Permittee must test annually the cover 

and all opening components of each fixed-roof storage tank using the methods 

specified in 40 C.F.R. § 61.355(h) in the absence of the detectable emissions.

The Permittee must monitor the pressure continuously to ensure that the pressure 

in the tank remains below atmospheric pressure.

2. Pursuant to requirements of 40 C.F.R. § 61.349, the Permittee must test annually 

the closed-vent using the methods specified in 40 C.F.R. § 61.355(h). 

3. The Permittee shall comply with the following monitoring requirements as 

established in 40 C.F.R. § 61.354(d):

For a carbon adsorption system that does not regenerate the carbon bed directly 

on site in the control device (e.g., a carbon canister), the Permittee must monitor 

on a regular schedule either the concentration level of the organic compounds or 

the concentration level of benzene in the exhaust vent stream from the carbon 

adsorption system, and must replace the existing carbon with fresh carbon 

immediately when carbon breakthrough is indicated. The Permittee must 

monitor the device on a daily basis or at intervals no greater than 20 percent of 

the design carbon replacement interval, whichever is greater. As an alternative 

to conducting this monitoring, the Permittee may replace the carbon in the 

carbon adsorption system with fresh carbon at a regular predetermined time 

interval that is less than the carbon replacement interval that is determined by the 

maximum design flow rate and either the organic concentration or the benzene 

concentration in the gas stream vented to the carbon adsorption system.

4. If a breakthrough does not occur within 365 days of operation on a high BTU 

tank, the Permittee must replace the carbon. If a breakthrough does not occur 

within 3 years of operation on a low BTU tank, the Permittee must replace the

carbon. [40 C.F.R. § 71.6(a)(3)(i)(B)]

5. The Permittee shall comply with the following inspection requirements as 

established in 40 C.F.R. § 61.349(f) and (g):
Veolia ES Technical Solutions, L.L.C. Page 106 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(a) The Permittee must visually inspect each closed-vent system and control 

device quarterly. The visual inspection shall include inspection of 

ductwork and piping and connections to covers and control devices for 

evidence of visible defects, such as holes in ductwork or piping and loose 

connections.

(b) Except as provided in 40 C.F.R. § 61.350, if the Permittee observes visible 

defects during an inspection, or if the Permittee identifies other problems or 

measures detectable emissions, the Permittee must make a first effort to 

repair the closed-vent system and control device as soon as practicable, but 

no later than 5 calendar days after detection. The Permittee must complete 

the repair no later than 15 calendar days after the emissions are detected or 

the visible defect is observed. 

6. The Permittee shall also inspect the presence and condition of the submerged 

loading pipes from the top during the quarterly inspections and must conduct a 

physical inspection of the submerged loading pipes every 5 years. [40 C.F.R.

§ 71.6(a)(3)(i)(B)]

(E) Recordkeeping and Reporting [40 C.F.R. § 71.6(a)(3)]

1. Requirements of 40 C.F.R. § 61.356 (benzene waste operations):

(a) The Permittee shall maintain engineering design documentation for all 

control equipment used in accordance with 40 C.F.R. §§ 61.343 through 

61.347 that is installed on the waste management unit. The Permittee shall 

retain the documentation for the life of the control equipment. The 

Permittee shall maintain the control device records required by 40 C.F.R.

§ 61.356(f). [40 C.F.R. § 61.356(d)] 

(b) The Permittee shall maintain the following records on a closed-vent system 

and control device used in accordance with 40 C.F.R. § 61.349. The 

Permittee shall retain the documentation for the life of the control device: 

[40 C.F.R. § 61.356(f)]

(i) A statement signed and dated by the Permittee certifying that the 

closed-vent system and control device is designed to operate at the 

documented performance level when the waste management unit 

vented to the control device is or would be operating at the highest 

load or capacity expected to occur.

(ii) Specifications, drawings, schematics, and piping and instrumentation 

diagrams prepared by the Permittee, or the control device 

manufacturer or vendor that describe the control device design based 

on acceptable engineering texts. The design analysis shall address 
Veolia ES Technical Solutions, L.L.C. Page 107 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

the following vent stream characteristics and control device 

operating parameters:

For a carbon adsorption system that does not regenerate the carbon 

bed directly on-site in the control device, such as a carbon canister, 

the design analysis shall consider the vent stream composition, 

constituent concentration, flow rate, relative humidity, and 

temperature. The design analysis shall also establish the design 

exhaust vent stream organic compound concentration level or the 

design exhaust vent stream benzene concentration level, capacity of 

carbon bed, type and working capacity of activated carbon used for 

carbon bed, and design carbon replacement interval based on the 

total carbon working capacity of the control device and source 

operating schedule.

(c) For each control device, the Permittee shall maintain documentation that 

includes the following information regarding the control device operation 

[40 C.F.R. § 61.356(j)]:

(i) Dates of startup and shutdown of the closed-vent system and control 

device.

(ii) A description of the operating parameter (or parameters) to be 

monitored to ensure that the control device will be operated in 

conformance with these standards and the control device's design 

specifications and an explanation of the criteria used for selection of 

that parameter (or parameters). The Permittee shall keep this 

documentation for the life of the control device.

(iii) Periods when the closed-vent system and control device are not 

operated as designed including all periods and the duration when:

A. Any valve car-seal or closure mechanism required under 

40 C.F.R. § 61.349(a)(1)(ii) is broken or the by-pass line valve 

position has changed.

B. The flow monitoring devices required under 40 C.F.R. 

§ 61.349(a)(1)(ii) indicate that vapors are not routed to the 

control device as required.

(iv) If the Permittee uses a carbon adsorber that is not regenerated 

directly on site in the control device, then the Permittee shall 

maintain records of dates and times when the control device is 

monitored, when breakthrough is measured, and shall record the date 
Veolia ES Technical Solutions, L.L.C. Page 108 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

and time that the existing carbon in the control device is replaced 

with fresh carbon.

2. Requirements of 40 C.F.R. § 60.115b(c):

The Permittee must keep the following records on control equipment installed in 

accordance with 40 C.F.R. § 60.112b (a)(3) or (b)(1) (closed vent system and 

control device other than a flare) for the life of the control equipment:

A copy of the operating plan and a record of the measured values of the 

parameters monitored in accordance with 40 C.F.R. § 60.113b(c)(2). The 

Permittee must operate the closed vent system and control device and monitor 

the parameters of the closed vent system and control device in accordance with 

the operating plan submitted to the Administrator in accordance with 40 C.F.R.

§ 60.113b(c)(1), unless the plan was modified by the Administrator during the 

review process. In this case, the modified plan applies.

3. Other requirements: [40 C.F.R. § 71.6(a)(3)]

The Permittee must maintain the following records:

(a) Total organic liquid wastes processed in gallons per month and gallons per 

year;

(b) Average VOM/HAP content of received wastes (percent by weight);

(c) Average vapor pressure of received liquid wastes; 

(d) Records of the size (capacity) of the affected liquid wastes storage tanks;

(e) Monthly and annual VOM emissions as calculated using the most recent 

version of the TANKS program or the equations and algorithms specified 

in Chapter 7 of AP-42; and

(f) Records of all inspections performed.
Veolia ES Technical Solutions, L.L.C. Page 109 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

2.5 BULK SOLID WASTE STORAGE FACILITY

(A) Emission Limitations and Standards [40 C.F.R. § 71.6(a)(1)]

1. National Emission Standards for Hazardous Air Pollutants for Benzene Waste 

Operations. [40 C.F.R. Part 61, Subpart FF]

(a) The affected bulk solid waste storage facility is subject to 40 C.F.R.

Part 61, Subpart FF, National Emission Standards for Hazardous Air 

Pollutants for Benzene Waste Operations, when the storage pits are in 

“benzene” service. [40 C.F.R. § 61.340]

(b) For the affected bulk solid waste storage facility, the Permittee shall install, 

operate, and maintain a fixed-roof and closed-vent system that routes all 

organic vapors vented from the tank to a control device. [40 C.F.R.

§§ 61.343 and 61.349].

(i) The Permittee must install, operate, and maintain an enclosure and 

closed-vent system that routes all organic vapors vented from the 

tank, located inside the enclosure, to a control device. [40 C.F.R. 

§ 61.343(a)(2)]

(ii) The Permittee must meet the following requirements for its control 

device that controls air pollutant emissions by using an enclosure 

vented through a closed-vent system to the control device: [ 40 

C.F.R. § 61.343(e)(1) through (4)]

A. The tank must be located inside a total enclosure. The 

enclosure must be designed and operated in accordance with 

the criteria for a permanent total enclosure as specified in 

“Procedure T—Criteria for and Verification of a Permanent or 

Temporary Total Enclosure” in 40 C.F.R. § 52.741, Appendix 

B. The enclosure may have permanent or temporary openings 

to allow worker access; passage of material into or out of the 

enclosure by conveyor, vehicles, or other mechanical means; 

entry of permanent mechanical or electrical equipment; or 

direct airflow into the enclosure. The Permittee must perform 

the verification procedure for the enclosure as specified in 

section 5.0 of Procedure T initially when the enclosure is first 

installed and, thereafter, annually. A facility that has 

conducted an initial compliance demonstration and that 

performs annual compliance demonstrations in accordance 

with the requirements for Tank Level 2 control requirements at 

40 C.F.R. §§ 264.1084(i) or 265(i) is not required to make 
Veolia ES Technical Solutions, L.L.C. Page 110 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

repeat demonstrations of initial and continuous compliance for 

the purposes of this subpart. 

B. The enclosure must be vented through a closed-vent system to 

a control device that is designed and operated in accordance 

with the standards for control devices specified in 40 C.F.R. 

§ 61.349.

C. The Permittee may install and operate safety devices, as 

defined in 40 C.F.R. Part 61, Subpart FF, as necessary, on any 

enclosure, closed-vent system, or control device used to 

comply with the requirements of 40 C.F.R. § 61.343(e)(1) and 

(e)(2). 

(iii) The Permittee must design and operate the closed-vent system and 

control device in accordance with the following requirements of 

40 C.F.R. § 61.349:

A. The Permittee must design the closed-vent system to operate 

with no detectable emissions as indicated by an instrument 

reading of less than 500 ppmv above background.

B. The Permittee must design and operate the control device so 

that the vapor recovery system (e.g., a carbon adsorption 

system or a condenser) shall recover or control the organic 

emissions vented to it with an efficiency of 95 weight percent 

or greater, or shall recover or control the benzene emissions 

vented to it with an efficiency of 98 weight percent or greater. 

C. The Permittee shall operate each closed-vent system and 

control device used to comply with 40 C.F.R. Part 61, Subpart 

FF, at all times when waste is placed in the waste management 

unit, except when maintenance or repair of the waste 

management unit cannot be completed without a shutdown of 

the control device.

2. National Emission Standards for Hazardous Air Pollutants from Off-Site Waste 

and Recovery Operations. [40 C.F.R. Part 63, Subpart DD]

(a) The bulk solid waste storage facility is subject to 40 C.F.R. Part 63, 

Subpart DD, National Emission Standards for Hazardous Air Pollutants 

from Off-Site Waste and Recovery Operations, wherever any waste is 

stored in the storage pits. [40 C.F.R. § 63.680]
Veolia ES Technical Solutions, L.L.C. Page 111 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(b) Although the bulk solid waste storage facility (defined by Subpart DD as 

an off-site material management unit) is subject to 40 C.F.R. Part 63, 

Subpart DD, it is exempt from the control requirements of 40 C.F.R.

§ 63.683(b)(1) if the unit is subject to another subpart under 40 C.F.R. Part 

61 or 63, and the Permittee is controlling the HAPs listed in Table 1 of 

40 C.F.R. Part 63, Subpart DD, that are emitted from the unit in 

compliance with the provisions specified in the other applicable subpart of 

40 C.F.R. Part 61 or 63. [40 C.F.R. § 63.683(b)(2)(i)]

3. Particulate matter emission limitation: [35 IAC 212.321(a)]

The Permittee shall not cause or allow the emission of particulate matter into the 

atmosphere in any one hour period from any new process emission unit, either 

alone or in combination with the emission of particulate matter from all other 

similar process emission units for which construction or modification 

commenced on or after April 14, 1972, at a source or premises, exceeds the 

allowable emission rates specified in 35 IAC 212.321(c). 

4. Visible emissions limitation: [35 IAC 212.123(a)]

The Permittee shall not cause or allow the emission of smoke or other particulate 

matter, with an opacity greater than 30 percent, into the atmosphere from any 

emission unit other than those emission units subject to the requirements of 

35 IAC 212.122, except as allowed by 35 IAC 212.123(b) and 212.124.

5. Organic material emissions limitations:

(a) The Permittee shall not cause or allow the discharge of more than 3.6 kg/hr 

(8 lbs/hr) of organic material into the atmosphere from any emission

source, except as provided in 35 IAC 219.302, 35 IAC 219.303, 35 IAC 

219.304 and the following exception: If no odor nuisance exists the 

limitation of this subpart shall apply only to photochemically reactive 

material. [35 IAC 219.301]

(b) Emissions of organic material in excess of those permitted by 35 IAC 

219.301 are allowable if such emissions are controlled by a vapor recovery 

system which adsorbs at least 85 percent of the total uncontrolled organic 

material that would otherwise be emitted to the atmosphere. [35 IAC 

219.302(b)]

(B) Nonapplicable Regulations [40 C.F.R. § 71.6(f)(1)]

The affected bulk solid waste storage facility is not subject to 40 C.F.R. Part 64, 

Compliance Assurance Monitoring for Major Stationary Sources, at this time 
Veolia ES Technical Solutions, L.L.C. Page 112 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

because the potential pre-control device emissions are less than major source levels 

as defined in 40 C.F.R. § 64.2(a)(3).

(C) Work Practice and Operational Requirements [40 C.F.R. § 71.6(a)(1)]

1. Except during times when bulk solid wastes are unloaded into the pits, all doors 

of the building shall be closed and all operations shall be enclosed inside the 

building. [40 C.F.R. § 71.6(a)(1)]

2. The enclosed building where bulk solid waste is accumulated shall be operated 

under permanent negative pressure. [40 C.F.R. § 71.6(a)(1)]

(D) Monitoring and Testing [40 C.F.R. §71.6(a)(3)(i)(A)]

1. The Permittee must test annually the cover and all opening components of each 

fixed-roof storage tank using the methods specified in 40 C.F.R. § 61.355(h) in 

the absence of the detectable emissions. [40 C.F.R. § 61.343(a)(1)]

2. The Permittee must test annually the closed-vent using the methods specified in 

40 C.F.R. § 61.355(h). [40 C.F.R. § 61.349]

3. The Permittee shall visually survey the bulk solid waste storage building each 

day for the presence of visible emissions or fugitive emissions of particulate 

matter. [40 C.F.R. § 71.6(a)(3)(i)(B)]

(a) If the Permittee identifies through observations any visible emissions or 

fugitive emissions of particulate matter, the Permittee shall:

(i) Immediately, upon conclusion of the visual observation, investigate 

the source and reason for the presence of visible emissions or 

fugitive emissions; and

(ii) As soon as practicable, take appropriate corrective action. 

(b) If the corrective actions undertaken do not eliminate the visible or fugitive 

emissions, the Permittee, within 24 hours of the initial survey, shall 

conduct a test using EPA Reference Method 9 (see 40 C.F.R. Part 60, 

Appendix A).

(i) If any of the visible emissions observations indicate visible 

emissions greater than 20 percent opacity, the Permittee shall 

conduct daily visible emissions observations, for 30 minutes, of the 

emission point in question until 2 consecutive daily observations 

indicate visible emissions of 20 percent opacity or less.
Veolia ES Technical Solutions, L.L.C. Page 113 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(ii) If the Method 9 visible emissions observation, or if 2 consecutive 

daily observations, indicate visible emissions of 20 percent opacity 

or less, the Permittee shall conduct weekly visible emissions 

observations of the emission point for 3 additional weeks. 

4. The Permittee must design and operate the enclosure for the affected bulk solid 

waste storage facility in accordance with the criteria for a permanent total 

enclosure as specified in “Procedure T - Criteria for and Verification of a 

Permanent or Temporary Total Enclosure” in 40 C.F.R. § 52.741, Appendix B.

The Permittee must perform annually the verification procedure for the enclosure 

as specified in section 5.0 of Procedure T. [40 C.F.R. § 61.343(e)]

5. The Permittee shall perform the following monitoring procedures, as required by 

40 C.F.R. § 61.354(c): 

(a) The Permittee, on the basis of being subject to the requirements in 40 

C.F.R. § 61.349, shall install, calibrate, maintain, and operate according to 

the manufacturer’s specifications, a device to continuously monitor the 

control device operation as specified below.

(b) For a carbon adsorption system that does not regenerate the carbon bed 

directly on site in the control device (e.g., a carbon canister), the 

concentration level of the organic compounds or the concentration level of 

benzene in the exhaust vent stream from the carbon adsorption system shall 

be monitored on a regular schedule, and the existing carbon shall be 

replaced with fresh carbon immediately when carbon breakthrough is 

indicated. The device shall be monitored on a daily basis or at intervals no 

greater than 20 percent of the design carbon replacement interval, 

whichever is greater.

6. The Permittee shall maintain an average facial velocity of at least 200 ft/min 

flowing into the enclosure at all natural draft openings in the building. The 

Permittee shall annually demonstrate the facial velocity according to Procedure T 

– Criteria for and Verification of a Permanent or Temporary Total Enclosure, 40 

C.F.R. § 52.741, Appendix B. [40 C.F.R. § 71.6(a)(3)(i)(B)]

7. Closed-vent system and control device monitoring procedures. [40 C.F.R. 

§ 61.349]

The Permittee shall perform the following monitoring procedures:

(a) The Permittee shall visually inspect each closed-vent system and control 

device upon effectiveness of this permit and quarterly thereafter. The 

visual inspection shall include inspection of ductwork and piping and 

connections to covers and control devices for evidence of visible defects,
Veolia ES Technical Solutions, L.L.C. Page 114 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

such as holes in ductwork or piping and loose connections. [40 C.F.R.

§ 61.349(f)]

(b) Except as provided in 40 C.F.R. § 61.350, if the Permittee observes visible 

defects during an inspection, or if the Permittee identifies other problems or 

measures detectable emissions, the Permittee must make a first effort to 

repair the closed-vent system and control device as soon as practicable, but 

no later than 5 calendar days after detection. The Permittee shall complete 

repairs no later than 15 calendar days after the emissions are detected or the 

visible defect is observed. [40 C.F.R. § 61.349(g)].

(c) The Permittee shall monitor any control device used to comply with 40 

C.F.R. § 61.349(h)] in accordance with 40 C.F.R. § 61.354(c). [40 C.F.R.

§ 61.349(h)]

(E) Recordkeeping and Reporting [40 C.F.R. § 71.6(a)(3)]

1. Recordkeeping required by 40 C.F.R. § 61.356:

(a) The Permittee shall maintain for the life of the control device the following 

records for the closed-vent system and control device it uses in accordance 

with 40 C.F.R. § 61.349(f):

(i) A statement signed and dated by the Permittee certifying that the 

closed-vent system and control device is designed to operate at the 

documented performance level when the waste management unit 

vented to the control device is or would be operating at the highest 

load or capacity expected to occur. [40 C.F.R. § 61.356(f)]

(ii) If the Permittee uses engineering calculations to determine control 

device performance in accordance with 40 C.F.R. § 61.349(c), then a 

design analysis for the control device that includes, for example: 

Specifications, drawings, schematics, and piping and instrumentation 

diagrams prepared by the Permittee, or the control device 

manufacturer or vendor that describe the control device design based 

on acceptable engineering texts. The design analysis shall address 

the following vent stream characteristics and control device 

operating parameters: 

For a carbon adsorption system that does not regenerate the carbon 

bed directly on-site in the control device, such as a carbon canister, 

the design analysis shall consider the vent stream composition, 

constituent concentration, flow rate, relative humidity, and 

temperature. The design analysis shall also establish the design 
Veolia ES Technical Solutions, L.L.C. Page 115 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

exhaust vent stream organic compound concentration level or the 

design exhaust vent stream benzene concentration level, capacity of 

carbon bed, type and working capacity of activated carbon used for 

carbon bed, and design carbon replacement interval based on the 

total carbon working capacity of the control device and source 

operating schedule. [40 C.F.R. § 61.356(f)]

(iii) The Permittee shall maintain a record for each visual inspection 

required by 40 C.F.R. §§ 61.343 through 61.347 that identifies a 

problem (such as a broken seal, gap or other problem) which could 

result in benzene emissions. The record shall include the date of the 

inspection, waste management unit and control equipment location 

where the problem is identified, a description of the problem, a 

description of the corrective action taken, and the date the corrective 

action was completed. [40 C.F.R. § 61.356(g)]

(iv) The Permittee shall maintain a record for each test of no detectable 

emissions required by 40 C.F.R. §§ 61.343 through 61.347 and 

61.349. The record shall include the following information: date the 

test is performed, background level measured during test, and

maximum concentration indicated by the instrument reading 

measured for each potential leak interface. If detectable emissions 

are measured at a leak interface, then the record shall also include 

the waste management unit, control equipment, and leak interface 

location where detectable emissions were measured, a description of 

the problem, a description of the corrective action taken, and the date 

the corrective action was completed. [40 C.F.R. § 61.356(h)]

(v) For each control device, the Permittee shall maintain documentation 

that includes the following information regarding the control device 

operation: [40 C.F.R. § 61.356(j)]

A. Dates of startup and shutdown of the closed-vent system and 

control device;

B. A description of the operating parameter (or parameters) to be 

monitored to ensure that the control device will be operated in 

conformance with these standards and the control device's 

design specifications and an explanation of the criteria used for 

selection of that parameter (or parameters). The Permittee 

shall keep this documentation for the life of the control device;

and
Veolia ES Technical Solutions, L.L.C. Page 116 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

C. Periods when the closed-vent system and control device are not 

operated as designed, including all periods and the duration 

when:

I. Any valve car-seal or closure mechanism required under 

40 C.F.R. § 61.349(a)(1)(ii) is broken or the by-pass line 

valve position has changed.

II. The flow monitoring devices required under 40 C.F.R.

§ 61.349(a)(1)(ii) indicate that vapors are not routed to 

the control device as required.

(vi) If the Permittee uses a carbon adsorber that is not regenerated 

directly on site in the control device, then the Permittee shall 

maintain records of dates and times when the control device is 

monitored and when breakthrough is measured, and shall record the 

date and time that the existing carbon in the control device is 

replaced with fresh carbon. [40 C.F.R. § 61.356(j)]

(b) The Permittee must keep the following records required by 40 C.F.R. 

§ 61.356 (n)(1) and (2) when using a total enclosure to comply with control 

requirements for tanks in 40 C.F.R. § 61.343. The Permittee may use 

records as required in 40 C.F.R. §§ 264.1089(b)(2)(iv) or 

265.1090(b)(2)(iv) for a tank to meet the recordkeeping requirement in 40 

C.F.R. § 61.356(n)(1). The Permittee must make the records of each 

verification of a total enclosure available for inspection by EPA upon 

request:

(i) Records of the most recent set of calculations and measurements 

performed to verify that the enclosure meets the criteria of a 

permanent total enclosure as specified in “Procedure T—Criteria for 

and Verification of a Permanent or Temporary Total Enclosure” in 

40 C.F.R. § 52.741, Appendix B; and

(ii) Records required for a closed-vent system and control device 

according to the requirements in 40 C.F.R. § 61.356(d), (f), and (j). 

2. Other recordkeeping requirements: [40 C.F.R. § 71.6(a)(3)(i)(B)]

The Permittee shall keep the following records:

(a) Amount of accepted solid wastes, in tons per month and tons per year;

(b) A log of maintenance and repair of air pollution control devices with the 

dates of service/repair made, and inspection conducted;
Veolia ES Technical Solutions, L.L.C. Page 117 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(c) Records of the pressure being maintained inside the building; and

(d) Monthly and annual VOM/HAP emissions. VOM/HAP emissions from 

waste processing operations located at the bulk solid waste storage facility 

shall be calculated using the Emission Inventory Improvement Program’s

surface evaporation model for calculating emissions from surface 

evaporation of VOM from open or partially covered mixing tanks during 

coating mixing operations, Methods for Estimating Air Emissions from 

Paint, Ink, and Other Coating Manufacturing Facilities, Volume II: Chapter 

8, Equation 8.4-22 (February 2005 or later version). In addition, the 

Permittee shall use the most recent version of the TANKS program or the 

equations and algorithms specified in Chapter 7 of AP-42 for estimating 

any VOM or HAPs emitted from any enclosed storage tanks located in the 

bulk solid waste storage facility.

3. The Permittee shall maintain the following records of the fugitive emissions:

[40 C.F.R. § 71.6(a)(3)(i)(B)]

(a) Details of each visual survey or visible emissions observation, including 

date, time, observer and results for each emission unit and any other 

pollutant emitting activity;

(b) Date, time and type of any investigation conducted;

(c) Findings of the investigation, including the reasons for the presence of 

visible emissions or fugitive emissions of particulate matter;

(d) Date, time and type of corrective actions taken; and

(e) Results of any Method 9 visible emissions observations conducted on the 

source of visible or fugitive emissions.

2.6 GASOLINE STORAGE TANK

(A) Emission Limitations and Standards [40 C.F.R. § 71.6(a)(1)]

1. The Permittee shall not cause or allow the loading of any organic material in any 

stationary tank having a storage capacity of greater than 946 liters (250 gallons), 

unless such tank is equipped with a permanent submerged loading pipe or an 

equivalent device approved by the IEPA according to the provisions of 35 IAC 

201, and further processed consistent with 35 IAC 219.108, or unless such tank 

is a pressure tank as described in 35 IAC 219,121(a) or is fitted with a recovery 

system as described in 35 IAC 219.121(b)(2). [35 IAC 219.122(b)]
Veolia ES Technical Solutions, L.L.C. Page 118 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

2. The Permittee shall not cause or allow the transfer of gasoline from any delivery 

vessel into the stationary storage tank at a gasoline dispensing operation unless 

the tank is equipped with a submerged loading pipe. [35 IAC 219.583(a)(1)]

3. The Permittee shall not sell, offer for sale, dispense, supply, offer for supply, or 

transport for use in Illinois gasoline whose Reid vapor pressure exceeds the 

applicable limitations set forth in 35 IAC 219.585 (b) and (c) below during the 

regulatory control periods, which shall be June 1 to September 15. [35 IAC 

219.585(a)]

4. The Reid vapor pressure of gasoline, a measure of its volatility, shall not exceed 

7.2 psi (49.68 kPa) during the regulatory control period in 1995 and each year 

thereafter. [35 IAC 219.585(b)]

5. The Reid vapor pressure of ethanol blend gasolines having at least 9 percent but 

not more than 10 percent ethyl alcohol by volume of the blended mixture, shall 

not exceed the limitations for gasoline set forth in subsection (b) of 35 IAC 

219.585 by more than 1.0 psi (6.9 kilopascals). 35 IAC 219.585(c)]

(B) Nonapplicable Regulations [40 C.F.R. § 71.6(f)(1)]

1. The affected gasoline storage tank is not subject to the requirements of 35 IAC 

219.583(a)(2),(3),(4) pursuant to 35 IAC 219.583(b)(3), because the tank has a 

capacity of less than 575 gallons. [35 IAC 219.583(b)(3)]

2. The gasoline storage tank is not subject to the requirements of 40 C.F.R. Part 60, 

Subpart Kb, because the design capacity of the storage tank is less than 40 cubic 

meters (10,576 gallons). [40 C.F.R. § 60.110b(a)]

3. The gasoline storage tank is not subject to the requirements of 35 IAC 219.121 

because the tank has a capacity of less than 40,000 gallons. [35 IAC 219.121]

4. The gasoline storage tank is not subject to the requirements of 35 IAC 219.120 

because the tank stores petroleum liquids. [35 IAC 219.119(e)]

5. The gasoline storage tank is not subject to 40 C.F.R. Part 64, Compliance 

Assurance Monitoring, because the tank does not use an add-on control device to 

achieve compliance with an emission limitation or standard. [40 C.F.R. § 64.2]

(C) Work Practice and Operational Requirements [40 C.F.R. § 71.6(a)(1)]

[Reserved]
Veolia ES Technical Solutions, L.L.C. Page 119 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(D) Monitoring and Testing [40 C.F.R. § 71.6(a)(3)(i)(A)]

1. The Permittee shall have gasoline stored in the affected tank sampled and 

analyzed for Reid vapor pressure. Samples shall be conducted at least once per 

calendar year or within 15 days of a written request from EPA. [40 C.F.R.

§ 71.6(a)(3)(i)(B)]

2. The Permittee shall conduct all sampling (testing) of gasoline required by 35 

IAC 219.585 in accordance with the procedures contained in 40 C.F.R. Part 80, 

Appendix D, “Sampling Procedures for Fuel Volatility.”

3. The Permittee shall measure Reid vapor pressure of gasoline in accordance with 

the procedures contained in “Tests for Determining Reid Vapor Pressure (RVP) 

of Gasoline and Gasoline-Oxygenate Blends,” as set forth in 40 C.F.R. Part 80, 

Appendix E.

4. The Permittee shall determine the ethanol content of ethanol blend gasolines 

using one of the approved testing methodologies specified in 40 C.F.R. Part 80, 

Appendix F.

5. Any alternate to the sampling or testing methods or procedures contained in 35 

IAC 219.585 (d), (e), and (f) must be approved by the IEPA, which shall 

consider data comparing the performance of the proposed alternative to the 

performance of one or more approved test methods or procedures. Such data 

shall accompany any request for IEPA approval of any alternate test procedure. 

If IEPA determines that such data demonstrates that the proposed alternative will 

achieve results equivalent to the approved test methods or will achieve results 

equivalent to the approved test methods or procedures, IEPA shall approve the 

proposed alternative.

6. On an annual basis, the Permittee shall conduct an inspection of the gasoline 

storage tank to review its physical condition and ability to comply with 35 IAC 

219.585. 

[40 C.F.R. § 71.6(a)(i)(3)(B)]

(E) Recordkeeping and Reporting [40 C.F.R. § 71.6(a)(3)]

1. The Permittee shall keep current a file for the gasoline storage tank, which 

contains design information on the capacity of the tank and documents the 

presence of a permanent submerged loading pipe. [40 C.F.R. § 71.6(a)(3)(i)(B)]

2. The Permittee shall maintain an inspection, maintenance and repair log or other 

records for the storage tank that, at a minimum, includes information related to 
Veolia ES Technical Solutions, L.L.C. Page 120 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

any repair or replacement of the submerged loading pipe. [40 C.F.R.

§ 71.6(a)(3)(i)(B)]

3. The Permittee shall maintain records for each shipment of material loaded into 

the gasoline storage tank that include copies of the invoice, bill of lading or other 

documentation from the supplier that provides the type of material, the amount 

of shipment, date of delivery, and the Reid vapor pressure (psi) of the gasoline. 

The Permittee shall keep these records for 3 years. [40 C.F.R. § 71.6(a)(3)(i)(B)]

4. The Permittee must maintain records of results of any testing samples. [40 

C.F.R. § 71.6(a)(3)(i)(B)]

5. The Permittee must maintain records of the amount of gasoline dispensed from 

the gasoline storage tank (gallons/month and gallons/year). [40 C.F.R.

§ 71.6(a)(3)(i)(B)]

2.7 BOILER

(A) Emission Limitations and Standards [40 C.F.R. § 71.6(a)(1)]

1. The Permittee shall not cause or allow the emission of carbon monoxide into the 

atmosphere from any fuel combustion emission source with actual heat input 

greater than 2.9 MW (10 mmBtu/hr) to exceed 200 ppm, corrected to 50 percent 

excess air. [35 IAC 216.121]

2. Emissions and operation of this boiler shall not exceed the following limits:

Operating 

Hours

NOx CO

Fuel (Hr/Yr) (Lb/Hr) (Ton/Yr) (Lb/Hr) (Ton/Yr)

Natural Gas 8760 1.46 6.41 2.1 9.2

These limits are based upon the maximum firing rate for the boiler, and standard 

emission factors. [Construction Permit 95080025]

3. The Permittee shall not cause or allow the emission of smoke or other particulate 

matter, with an opacity greater than 30 percent, into the atmosphere from any 

emission unit other than those emission units subject to the requirements of 35 

IAC 212.122, except as allowed by 35 IAC 212.123(b) and 212.124. [35 IAC 

212.123(a)]
Veolia ES Technical Solutions, L.L.C. Page 121 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

4. Standards of Performance for Small Industrial-Commercial-Institutional Steam

Generating Units. [40 C.F.R. Part 60, Subpart Dc]

The 10.46 mmBtu/hr natural gas-fired boiler (Boiler #1) is subject to 40 C.F.R. 

Part 60, Subpart Dc. However, there are no numerical emission limits that apply 

to Boiler #1 because Boiler #1 only burns natural gas as defined at 40 C.F.R. 

§ 60.41c. [40 C.F.R. § 60.40c(a)]

5. National Emission Standards for Hazardous Air Pollutants for Major Sources: 

Industrial, Commercial, and Institutional Boilers and Process Heaters. [40 

C.F.R. Part 63, Subpart DDDDD]

(a) Boiler #1 is subject to 40 C.F.R. Part 63, Subpart DDDDD; however, no 

numerical emission limits apply to Boiler #1. This is because Boiler #1 is a 

unit designed to burn gas 1 (natural gas) as defined at 40 C.F.R. § 63.7575. 

[40 C.F.R. § 63.7485]

(b) The Permittee must comply with the applicable requirements of 40 C.F.R. 

Part 63, Subpart DDDDD, for Boiler #1 no later than January 31, 2016, 

unless the Administrator has granted an extension of compliance consistent 

with 40 C.F.R. § 63.6(i). [40 C.F.R. § 63.7495]

(B) Nonapplicable Regulations [40 C.F.R. § 71.6(f)(1)]

1. Boiler #1 is not subject to 35 IAC 217.121, emissions of nitrogen oxides from 

new fuel combustion emission sources, because the actual heat input of the 

affected boiler is less than 73.2 MW (250 mmBtu/hr). [35 IAC 217.121]

2. Boiler #1 is not subject to 35 IAC 219.301 because fuel combustion emission 

units are not subject to 35 IAC 219.301. [35 IAC 219.303]

3. Boiler #1 is not subject to 35 IAC 214.122 because solid or liquid fuels are not 

exclusively burned in the affected boiler. [35 IAC 214.122]

4. Boiler #1 is not subject to the National Emission Standards for Hazardous Air 

Pollutants for Industrial-Commercial-Institutional Boilers Area Sources, 40 

C.F.R. Part 63, Subpart JJJJJJ, because Boiler #1 is a gas-fired boiler as defined 

at 40 C.F.R. § 63.11237. [40 C.F.R. § 63.11195(e)]

5. Boiler #1 is not subject to Standards of Performance for Electric Utility Steam 

Generating Units, 40 C.F.R. Part 60, Subpart Da, because Boiler #1 is not

capable of combusting more than 73 MW (250 mmBtu/hr) heat input of fossil 

fuel (either alone or in combination with any other fuel). [40 C.F.R. 

§ 60.40Da(a)(1)]
Veolia ES Technical Solutions, L.L.C. Page 122 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

6. Boiler #1 is not subject to Standards of Performance for Industrial-CommercialInstitutional Steam Generating Units, 40 C.F.R. Part 60, Subpart Db, because 

Boiler #1 has a heat input capacity from fuels combusted in the unit of less than 

29 MW (100 mmBtu/hr). [40 C.F.R. § 60.40b(a)]

7. Boiler #1 is not subject to 40 C.F.R. Part 64, Compliance Assurance Monitoring, 

because it does not use an add-on control device to achieve compliance with an 

emission limitation or standard. [40 C.F.R. § 64.2(a)]

(C) Work Practice and Operational Requirements [40 C.F.R. § 71.6(a)(1)]

1. Natural gas shall be the only fuel fired. [Construction Permit 95080025]

2. Total natural gas consumption shall not exceed 7.6 mmscf/month and 91.1 

mmscf/year. [40 C.F.R. § 71.6(a)(3)(i)(B)]

3. The Permittee must conduct an annual tune-up of Boiler #1 as specified in 

condition 2.7(D)(2), below, as a work practice for all regulated emissions under 

40 C.F.R. Part 63, Subpart DDDDD. [40 C.F.R. § 63.7500 and Appendix to 40 

C.F.R. Part 63, Subpart DDDDD, Table 3 (Item 3)]

4. By January 31, 2016, the Permittee must have a one-time energy assessment 

performed by a qualified energy assessor. An energy assessment completed on 

or after January 1, 2008, that meets or is amended to meet the energy assessment 

requirements in Table 3 to 40 C.F.R. Part 63, Subpart DDDDD, satisfies the 

energy assessment requirement. A facility that operates under an energy 

management program compatible with ISO 50001 that includes the affected units 

also satisfies the energy assessment requirement. The energy assessment must 

include the following with extent of the evaluation for items (a) to (e) 

appropriate for the on-site technical hours listed in 40 C.F.R. § 63.7575:

(a) A visual inspection of the boiler system;

(b) An evaluation of operating characteristics of the boiler systems, 

specifications of energy using systems, operating and maintenance 

procedures, and unusual operating constraints;

(c) An inventory of major energy use systems consuming energy from the 

affected boiler and which are under the control of the Permittee;

(d) A review of available architectural and engineering plans, facility operation 

and maintenance procedures and logs, and fuel usage;

(e) A list of cost-effective energy conservation measures that are within the 

facility’s control;
Veolia ES Technical Solutions, L.L.C. Page 123 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(f) A list of cost-effective energy conservation measures that are within the 

facility’s control;

(g) A list of the energy savings potential of the energy conservation measures 

identified; and

(h) A comprehensive report detailing the ways to improve efficiency, the cost 

of specific improvements, benefits, and the time frame for recouping those 

investments.

[40 C.F.R. § 63.7500 and Appendix to 40 C.F.R. Part 63, Subpart DDDDD, 

Table 3 (Item 4)]

5. At all times, the Permittee must operate and maintain Boiler #1, including any 

associated air pollution control equipment and monitoring equipment, in a 

manner consistent with safety and good air pollution control practices for 

minimizing emissions. Determination of whether such operation and 

maintenance procedures are being used will be based on information available to 

the Administrator that may include, but is not limited to, monitoring results, 

review of operation and maintenance procedures, review of operation and 

maintenance records, and inspection of the source. [40 C.F.R. § 63.7500(a)(3)]

(D) Monitoring and Testing [40 C.F.R. § 71.6(a)(3)]

1. The Permittee shall perform an annual Method 9 test to ensure compliance with 

the opacity limit. [40 C.F.R. § 71.6(a)(3)(i)(B)]

2. The Permittee must conduct an annual tune-up of Boiler #1 to demonstrate 

continuous compliance with the work practice standards of 40 C.F.R. Part 63, 

Subpart DDDDD, as specified below:

(a) Inspect the burner, and clean or replace any components of the burner as 

necessary. The Permittee may delay the burner inspection until the next 

scheduled unit shutdown; [40 C.F.R. § 63.7540(a)(10)(i)]

(b) Inspect the flame pattern, and adjust the burner as necessary to optimize the 

flame pattern. The adjustment should be consistent with the 

manufacturer’s specifications, if available; [40 C.F.R. § 63.7540(a)(10)(ii)]

(c) Inspect the system controlling the air-to-fuel ratio, and ensure that it is 

correctly calibrated and functioning properly. The Permittee may delay the 

inspection until the next scheduled unit shutdown; [40 C.F.R. 

§ 63.7540(a)(10)(iii)]

(d) Optimize total emissions of CO. This optimization should be consistent 

with the manufacturer’s specifications, if available, and with any NOx 
Veolia ES Technical Solutions, L.L.C. Page 124 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

requirement to which Boiler #1 is subject; and [40 C.F.R. 

§ 63.7540(a)(10)(iv)]

(e) Measure the concentrations in the effluent stream of CO and NOx in parts 

per million, by volume, and oxygen in volume percent, before and after the 

adjustments are made. Measurements may be either on a dry or wet basis, 

as long as it is the same basis before and after the adjustments are made. 

Measurements may be taken using portable CO and NOx analyzers. 

[40 C.F.R. § 63.7540(a)(10)(v); 40 C.F.R. § 71.6(a)(3)(i)(B)]

3. If Boiler #1 is not operating on the required date for a tune-up, the tune-up must 

be conducted within 30 calendar days of startup. [40 C.F.R. § 63.7540(a)(13)]

4. The Permittee must conduct performance tests for CO and NOx from the 

affected boiler at a frequency of no less than once every 5 years to demonstrate 

compliance with the CO and NOx emission limits in condition 2.7(A)(2). Each 

performance test must be conducted between 48 and 60 months after the 

previous performance test. The Permittee must do the following during the 

performance tests:

(a) Select the sampling ports location and the number of traverse points using 

Method 1 in 40 C.F.R. Part 60, Appendix A;

(b) Determine oxygen and carbon dioxide concentrations of the stack gas using 

Method 3A or 3B in 40 C.F.R. Part 60, Appendix A, or ASTM D6522–00 

(IBR, see 40 C.F.R. § 63.14(b)), or ASME PTC 19, Part 10 (1981) (IBR, 

see 40 C.F.R. § 63.14(i));

(c) Measure the moisture content of the stack gas using Method 4 in 40 C.F.R. 

Part 60, Appendix A;

(d) Measure the NOx emission concentration using Method 7 or 7E in 

Appendix A to 40 C.F.R. Part 60, or ASTM D6522–00 (IBR, see 40 C.F.R. 

§ 63.14(b)); and

(e) Measure the CO emission concentration using Method 10, 10A, or 10B in 

Appendix A to 40 C.F.R. Part 60, or ASTM D6522–00 (IBR, see 40 C.F.R. 

§ 63.14(b)) when the fuel is natural gas.

[40 C.F.R. § 71.6(a)(3)(i)(B)]

(E) Recordkeeping and Reporting [40 C.F.R. § 71.6(a)(3)]

1. The Permittee must record and maintain onsite:
Veolia ES Technical Solutions, L.L.C. Page 125 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(a) Monthly records of natural gas usage; [40 C.F.R. § 60.48c(g)]

(b) Annual records of natural gas usage (million standard cubic feet per year);

[Construction Permit 95080025]

(c) An annual report containing the following information: 

(i) The concentrations of CO and NOx in the effluent stream in parts 

per million by volume, and oxygen in volume percent, measured at 

high fire or typical operating load, before and after the tune-up of the 

boiler; and

(ii) A description of any corrective actions taken as a part of the tune-up.

[40 C.F.R. § 63.7540(a)(10)(vi); 40 C.F.R. § 71.6(a)(3)(i)(B)]

(d) A summary of the results of all required performance tests. [40 C.F.R.

§ 71.6(a)(3)(i)(B)]

2. The Permittee must submit annually a compliance report which contains: 

(a) Company name and address;

(b) Statement by a responsible official with that official’s name, title, and 

signature, certifying the truth, accuracy, and completeness of the content of 

the report;

(c) Date of report and beginning and ending dates of the reporting period;

(d) A summary of the results of the annual tune-ups, including the date of the 

most recent burner inspection if it was not done annually and was delayed 

until the next scheduled or unscheduled unit shutdown. The Permittee shall 

make actual tune-up results available to the Administrator upon request;

(e) A summary of the results of performance tests conducted during the 

reporting period. The Permittee shall make actual test results available to 

the Administrator upon request;

(f) The hours of operation for the boiler for each calendar month within the 

reporting period;

(g) The amount of natural gas used during the reporting period (million 

standard cubic feet per year); and

(h) If the boiler had a startup, shutdown, or malfunction during the reporting 

period and the Permittee took actions consistent with the SSMP, the 
Veolia ES Technical Solutions, L.L.C. Page 126 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

compliance report must include the information in 40 C.F.R. 

§ 63.10(d)(5)(i).

[40 C.F.R. § 63.7550(c)(1); 40 C.F.R. § 71.6(a)(3)(i)(B)]

3. The Permittee shall notify the IEPA prior to any change in the types of fuel used 

in the boiler. [Construction Permit 95080025]

2.8 EMERGENCY GENERATORS

(A) Emission Limitations and Standards [40 C.F.R. § 71.6(a)(1)]

The two diesel fuel-fired emergency generators, each with a site rating of less than 

112 HP, are subject to the NESHAP for Stationary Reciprocating Internal 

Combustion Engines (RICE), 40 C.F.R. Part 63, Subpart ZZZZ. However, there are 

no numerical emission limitations that apply. [40 C.F.R. §§ 63.6585, 63.6602]

(B) Nonapplicable Regulations [40 C.F.R. § 71.6(f)(1)]

1. The emergency generators are not subject to the Standards of Performance for 

Stationary Compression Ignition Internal Combustion Engines, 40 C.F.R. 

Part 60, Subpart IIII, because construction of the emergency generator engines 

did not commence, as defined at 40 C.F.R. § 60.4200(a), after July 11, 2005 and 

the engines have not been modified or reconstructed after July 11, 2005. 

[40 C.F.R. § 60.4200]

2. The emergency generators are not subject to the Standards of Performance for 

Stationary Spark Ignition Internal Combustion Engines, 40 C.F.R. Part 60, 

Subpart JJJJ, because the emergency generator engines are not spark ignition 

engines as defined at 40 C.F.R. § 60.4248. [40 C.F.R. § 60.4230]

3. The emergency generators are not subject to 40 C.F.R. Part 64, Compliance 

Assurance Monitoring, because the emergency generators do not use an add-on 

control device to achieve compliance with an emission limitation or standard. 

[40 C.F.R. § 64.2(a)]

(C) Work Practice and Operational Requirements [40 C.F.R. § 71.6(a)(1)]

1. In order for each engine to be considered an emergency stationary RICE under 

40 C.F.R. Part 63, Subpart ZZZZ, any operation other than emergency operation, 

maintenance and testing, emergency demand response, and operation in nonemergency situations for 50 hours per year, as described in condition 2.8(C)(2), 

below, is prohibited. If the Permittee does not operate the engine according to 

the requirements in condition 2.8(C)(2), below, the engine will not be considered 
Veolia ES Technical Solutions, L.L.C. Page 127 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

an emergency engine and must meet all requirements for non-emergency engines 

in 40 C.F.R. Part 63, Subpart ZZZZ. [40 C.F.R. § 63.6640(f)]

2. The Permittee must operate each emergency generator according to the following 

requirements: [40 C.F.R. § 63.6640(f)]

(a) There is no time limit on the use of the emergency generators in emergency 

situations. 

(b) The Permittee may operate each emergency generator for any combination 

of the purposes specified in (i) through (iii), below, for a maximum of 100 

hours per calendar year. Any operation for non-emergency situations as 

allowed by condition 2.8(C)(2)(c), below, counts as part of the 100 hours 

per calendar year. 

(i) The Permittee may operate each emergency generator for 

maintenance checks and readiness testing, provided that the tests are 

recommended by federal, state or local government, the 

manufacturer, the vendor, the regional transmission organization or 

equivalent balancing authority and transmission operator, or the 

insurance company associated with the engine. The Permittee may 

petition the Administrator for approval of additional hours to be used 

for maintenance checks and readiness testing, but a petition is not 

required if the Permittee maintains records indicating that federal, 

state, or local standards require maintenance and testing of the 

emergency generator beyond 100 hours per calendar year.

(ii) The Permittee may operate each emergency generator for emergency 

demand response for periods in which the Reliability Coordinator 

under the North American Electric Reliability Corporation (NERC) 

Reliability Standard EOP-002-3, Capacity and Energy Emergencies 

(incorporated by reference, see 40 C.F.R. § 63.14), or other 

authorized entity as determined by the Reliability Coordinator, has 

declared an Energy Emergency Alert Level 2 as defined in the 

NERC Reliability Standard EOP-002-3.

(iii) The Permittee may operate each emergency generator for periods 

where there is a deviation of voltage or frequency of 5 percent or 

greater below standard voltage or frequency.

(c) The Permittee may operate each emergency generator for up to 50 hours 

per calendar year in non-emergency situations. The 50 hours of operation 

in non-emergency situations are counted as part of the 100 hours per 

calendar year for maintenance and testing and emergency demand response 

provided in condition 2.8(C)(2)(b), above. The 50 hours per year for non-
Veolia ES Technical Solutions, L.L.C. Page 128 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

emergency situations cannot be used for peak shaving or non-emergency 

demand response, or to generate income for a facility to supply power to an 

electric grid or otherwise supply power as part of a financial arrangement 

with another entity. [40 C.F.R. § 63.6640(f)(3)]

3. The Permittee shall perform the following work practices for each emergency 

generator except during periods of startup. The Permittee can petition the 

Administrator pursuant to 40 C.F.R. § 63.6(g) for alternative work practices.

(a) Change oil and filter every 500 hours of operation or annually, whichever 

comes first. The Permittee has the option to utilize an oil analysis program 

as described in condition 2.8(C)(6), below.

(b) Inspect air cleaner every 1,000 hours of operation or annually, whichever 

comes first, and replace as necessary.

(c) Inspect all hoses and belts every 500 hours of operation or annually, 

whichever comes first, and replace as necessary.

[Table 2c, Item 1, to 40 C.F.R. Part 63, Subpart ZZZZ]

4. During periods of startup, the Permittee minimize the engine’s time spent at idle 

and minimize the engine’s startup time at startup to a period needed for 

appropriate and safe loading of the engine, not to exceed 30 minutes, after which 

time the non-startup emission limitations apply. The Permittee can petition the 

Administrator pursuant to 40 C.F.R. § 63.6(g) for alternative work practices. 

[Table 2c, Item 1, to 40 C.F.R. Part 63, Subpart ZZZZ]

5. If an emergency engine is operating during an emergency and it is not possible to 

shut down the engine in order to perform the work practice requirements on the 

schedule required in condition 2.8(C)(3), above, or if performing the work 

practice on the required schedule would otherwise pose an unacceptable risk 

under federal, state, or local law, the work practice can be delayed until the 

emergency is over or the unacceptable risk under federal, state, or local law has 

abated. The work practice should be performed as soon as practicable after the 

emergency has ended or the unacceptable risk under federal, state, or local law 

has abated. [Table 2c to 40 C.F.R. Part 63, Subpart ZZZZ, footnote 1]

6. The Permittee has the option of utilizing an oil analysis program in order to 

extend the specified oil change requirement in condition 2.8(C)(3), above. The 

oil analysis must be performed at the same frequency specified for changing the 

oil in condition 2.8(C)(3), above. The analysis program must at a minimum 

analyze the following three parameters: Total Base Number, viscosity, and 

percent water content. The condemning limits for these parameters are as 

follows: Total Base Number is less than 30 percent of the Total Base Number of 
Veolia ES Technical Solutions, L.L.C. Page 129 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

the oil when new; viscosity of the oil has changed by more than 20 percent from 

the viscosity of the oil when new; or percent water content (by volume) is greater 

than 0.5. If all of these condemning limits are not exceeded, the Permittee is not 

required to change the oil. If any of the limits are exceeded, the Permittee must 

change the oil within 2 business days of receiving the results of the analysis; if 

the engine is not in operation when the results of the analysis are received, the 

Permittee must change the oil within 2 business days or before commencing 

operation, whichever is later. The Permittee must keep records of the parameters 

that are analyzed as part of the program, the results of the analysis, and the oil 

changes for the engine. The analysis program must be part of the maintenance 

plan for the engine. [40 C.F.R. § 63.6625(i)]

7. The Permittee shall operate and maintain each emergency generator and aftertreatment control device (if any) according to the manufacturer’s emissionrelated operation and maintenance instructions; or develop and follow your own 

maintenance plan which must provide to the extent practicable for the 

maintenance and operation of each engine in a manner consistent with good air 

pollution control practice for minimizing emissions. [40 C.F.R. § 63.6625(e); 

Table 6, Item 9, to 40 C.F.R. Part 63, Subpart ZZZZ]

8. The Permittee must be in compliance with the applicable emission limitations, 

operating limitations, and other requirements in 40 C.F.R. Part 63, 

Subpart ZZZZ, at all times. [40 C.F.R. § 63.6605(a)]

9. At all times the Permittee must operate and maintain each emergency generator, 

including associated air pollution control equipment and monitoring equipment

(if any), in a manner consistent with safety and good air pollution control 

practices for minimizing emissions. Determination of whether such operation 

and maintenance procedures are being used will be based on information 

available to the Administrator which may include, but is not limited to, 

monitoring results, review of operation and maintenance procedures, review of 

operation and maintenance records, and inspection of the source. [40 C.F.R. 

§ 63.6605(b)]

10. Beginning January 1, 2015, the Permittee must use diesel fuel that meets the 

following requirements of 40 C.F.R. § 80.510(b) for nonroad diesel fuel, except 

that any existing diesel fuel purchased (or otherwise obtained) prior to January 1, 

2015, may be used until depleted:

(a) Sulfur content of 15 ppm maximum for nonroad diesel fuel.

(b) Cetane index or aromatic content, as follows:

(i) A minimum cetane index of 40; or
Veolia ES Technical Solutions, L.L.C. Page 130 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(ii) A maximum aromatic content of 35 volume percent.

[40 C.F.R. § 63.6604(b)]

11. The Permittee must minimize the engine’s time spent at idle during startup and 

minimize the engine’s startup time to a period needed for appropriate and safe 

loading of the engine, not to exceed 30 minutes, after which time the emission 

standards applicable to all times other than startup apply. [40 C.F.R. 

§ 63.6625(h)]

(D) Monitoring and Testing [40 C.F.R. § 71.6(a)(3)]

1. The Permittee must install a non-resettable hour meter on each emergency 

generator if one is not already installed. [40 C.F.R. § 63.6625(f)] 

2. Except for monitor malfunctions, associated repairs, required performance 

evaluations, and required quality assurance or control activities, the Permittee

must operate any required monitors continuously at all times that the emergency 

generator is operating. A monitoring malfunction is any sudden, infrequent, not 

reasonably preventable failure of the monitoring to provide valid data. 

Monitoring failures that are caused in part by poor maintenance or careless 

operation are not malfunctions. [40 C.F.R. § 63.6635(b)]

3. The Permittee may not use data recorded during monitoring malfunctions, 

associated repairs, and required quality assurance or control activities in data 

averages and calculations used to report emission or operating levels. The 

Permittee must, however, use all the valid data collected during all other periods. 

[40 C.F.R. § 63.6635(c)]

(E) Recordkeeping and Reporting [40 C.F.R. § 71.6(a)(3)]

1. If the emergency generator operates or is contractually obligated to be available 

for more than 15 hours per year for the purposes specified in conditions 

2.8(C)(2)(b)(ii) and (iii), the Permittee must report the following information 

annually according to the requirements in condition 2.8(E)(2), below: 

(a) Company name and address where the engine is located.

(b) Date of the report and beginning and ending dates of the reporting period.

(c) Engine site rating and model year.

(d) Latitude and longitude of the engine in decimal degrees reported to the fifth 

decimal place.
Veolia ES Technical Solutions, L.L.C. Page 131 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(e) Hours operated for the purposes specified in conditions 2.8(C)(2)(b)(ii) and 

(iii), including the date, start time, and end time for engine operation for the 

purposes specified in conditions 2.8(C)(2)(b)(ii) and (iii).

(f) Number of hours the engine is contractually obligated to be available for 

the purposes specified in conditions 2.8(C)(2)(b)(ii) and (iii).

(g) Hours spent for operation for the purpose specified in condition 

2.8(C)(2)(d)(ii), including the date, start time, and end time for engine 

operation for the purposes specified in condition 2.8(C)(2)(d)(ii). The 

report must also identify the entity that dispatched the engine and the 

situation that necessitated the dispatch of the engine.

(h) If there were no deviations from the fuel requirements in 40 C.F.R. 

§ 63.6604 that apply to the engine (if any), a statement that there were no 

deviations from the fuel requirements during the reporting period.

(i) If there were deviations from the fuel requirements in 40 C.F.R. § 63.6604

that apply to the engine (if any), information on the number, duration, and 

cause of deviations, and the corrective action taken.

[40 C.F.R. § 63.6650(h)(1); Table 7, Item 4, to 40 C.F.R. Part 63, Subpart ZZZZ]

2. The first annual report, for purposes of condition 2.8(E)(1), above, must cover 

the calendar year 2015 and must be submitted no later than March 31, 2016, to 

the Administrator at the address in condition 4.8(A). Subsequent annual reports 

for each calendar year must be submitted no later than March 31 of the following 

calendar year. [40 C.F.R. § 63.6650(h)(2)-(3)]

3. The Permittee must report each instance in which the Permittee did not meet 

each operating limitation in condition 2.8(C), above, and the applicable 

requirements in Table 8 of 40 C.F.R. Part 63, Subpart ZZZZ. These instances 

are deviations from the emission and operating limitations in 40 C.F.R. Part 63, 

Subpart ZZZZ. The Permittee must report such deviations according to 

condition 3.2(B). [40 C.F.R. §§ 63.6640(b) and (e), 63.6650(b)(5)] 

4. The Permittee must keep onsite, and make available to the Administrator upon 

request, the following information:

(a) A copy of each notification and report that the Permittee submitted to EPA 

to comply with 40 C.F.R. Part 63, Subpart ZZZZ, including all 

documentation supporting any Initial Notification or Notification of 

Compliance Status that the Permittee submitted, according to the 

requirement in 40 C.F.R. § 63.10(b)(2)(xiv). [40 C.F.R. § 63.6655(a)(1)]
Veolia ES Technical Solutions, L.L.C. Page 132 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(b) Operation and maintenance plan, which includes either the manufacturer’s 

emission-related operation and maintenance instructions or the Permittee’s

own maintenance plan that provides to the extent practicable for the 

maintenance and operation of the engine in a manner consistent with good 

air pollution control practice for minimizing emissions. [40 C.F.R. 

§ 63.6655(d)]

(c) Records of any maintenance conducted on the emergency generator in 

order to demonstrate that the Permittee operated and maintained the engine 

and after-treatment control device (if any) according to the Permittee’s 

maintenance plan. [40 C.F.R. § 63.6655(e)]

(d) Records of all required maintenance performed on the air pollution control 

and monitoring equipment. [40 C.F.R. § 63.6655(a)(4)]

(e) Hours of operation of the engine as recorded through the non-resettable 

hour meter. The Permittee must document how many hours are spent for 

emergency operation, including what classified the operation as emergency 

and how many hours are spent for non-emergency operation. If the engine 

is used for the purposes specified in 40 C.F.R. § 63.6640(f)(2)(ii) or (iii) or 

40 C.F.R. § 63.6640(f)(4)(ii), the Permittee must keep records of the 

notification of the emergency situation, and the date, start time, and end 

time of engine operation for these purposes. [40 C.F.R. § 63.6655(f)]

(f) Records of the occurrence and duration of each malfunction of operation 

(i.e., process equipment) or the air pollution control and monitoring 

equipment. [40 C.F.R. § 63.6655(a)(2)]

(g) Records of actions taken during periods of malfunction to minimize 

emissions in accordance with 40 C.F.R. § 63.6605(b), including corrective 

actions to restore malfunctioning process and air pollution control and 

monitoring equipment to its normal or usual manner of operation. 

[40 C.F.R. § 63.6655(a)(5)]

5. The Permittee must report according to condition 3.2(B) any failure to perform 

the work practices on the schedule required in condition 2.8(C)(3) as a result of 

the circumstances specified in condition 2.8(C)(5) and the federal, state or local 

law under which the risk was deemed unacceptable. [Table 2c to 40 C.F.R. 

Part 63, Subpart ZZZZ, footnote 1]

6. The Permittee must keep each record readily accessible in hard copy or 

electronic form for at least 5 years after the date of each occurrence, 

measurement, maintenance, corrective action, report, or record. [40 C.F.R. 

§ 63.6660] 
Veolia ES Technical Solutions, L.L.C. Page 133 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

2.9 FUGITIVE EMISSIONS

(A) Emission Limitations and Standards [40 C.F.R. § 71.6(a)(1)]

1. Any leaking equipment is subject to the following requirements of 35 IAC 

Part 219, Subpart C:

(a) Pumps and Compressors: [35 IAC 219.142]

The Permittee shall not cause or allow the discharge of more than 32.8 ml 

(2 cu in) of VOL with vapor pressure of 17.24 kilo pascals (2.5 pounds per 

square inch absolute) or greater at 294.3 0K (70 0F) into the atmosphere 

from any pump or compressor in any 15 minute period at standard 

conditions. 

(b) Vapor Blowdown: [35 IAC 219.143]

The Permittee shall not cause or allow the emission of organic material into 

the atmosphere from any vapor blowdown system or any safety relief 

valve, except such safety relief valves not capable of causing an excessive 

release, unless such emission is controlled:

(i) To 10 ppm equivalent methane (molecular weight 16.0) or less; or

(ii) By combustion in a smokeless flare; or

(iii) By other air pollution control equipment approved by the IEPA 

according to provisions of 35 IAC 201 and further processed 

consistent with 35 IAC 219.108.

2. National Emissions Standards for Equipment Leaks [40 C.F.R. Part 61, 

Subparts J and V]

Any affected equipment that is a source of fugitive emissions of benzene or other 

volatile hazardous air pollutants (leaking equipment) is subject to 40 C.F.R.

Part 61, Subparts V and J. The Permittee shall comply with the standards and 

requirements of 40 C.F.R. Part 61, Subpart V, for pumps, compressors, pressure 

relief devices, sampling connection systems, open-ended valves or lines, valves, 

connectors, surge control vessels, bottoms receivers, and control devices or 

systems required by 40 C.F.R. Part 61, Subpart V. [40 C.F.R. § 61.112(a)]
Veolia ES Technical Solutions, L.L.C. Page 134 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(B) Nonapplicable Regulations [40 C.F.R. § 71.6(f)(1)]

1. The leaking equipment is not subject to the New Source Performance Standards 

(NSPS) for the Synthetic Organic Chemicals Manufacturing Industry, 40 C.F.R.

Part 60, Subparts VV, III, NNN, and RRR; and the NESHAP for the Synthetic 

Organic Chemicals Manufacturing Industry, 40 C.F.R. Part 63, Subparts F, G, H, 

and I, because it is not associated with the manufacture or production of the 

affected organic chemicals. [40 C.F.R. §§ 60.480; 60.610; 60.660; 60.700; 

63.100; 63.110; 63.160]

2. The leaking equipment is not subject to 40 C.F.R. Part 64, Compliance 

Assurance Monitoring, because the it does not use add-on control devices to 

achieve compliance with an emission limitation or standard. [40 C.F.R. 

§ 64.2(a)]

(C) Work Practice and Operational Requirements [40 C.F.R. § 71.6(a)(1)]

The Permittee shall comply with the following standards of 40 C.F.R. Part 61, 

Subpart V:

1. General: [40 C.F.R. § 61.242-1]

(a) The Permittee shall demonstrate compliance with the requirements of 

40 C.F.R. §§ 61.242-1 to 61.242-11 for each new and existing source as 

required in 40 C.F.R. § 61.05, except as provided in 40 C.F.R. §§ 61.243 

and 61.244.

(b) Compliance with 40 C.F.R. Part 61, Subpart V, will be determined by 

review of records, review of performance test results, and inspection using 

the methods and procedures specified in 40 C.F.R. § 61.245.

(c) The Permittee shall mark each piece of equipment to which 40 C.F.R. 

Part 61, Subpart V, applies in such a manner that it can be distinguished

readily from other pieces of equipment. 

2. Pumps: [40 C.F.R. § 61.242-2]

(a) The Permittee shall monitor each pump monthly to detect leaks by the 

methods specified in 40 C.F.R. § 61.245(b), except as provided in 

40 C.F.R. §§ 61.242-1(c) and 61.242-2(d), (e), (f) and (g). 

(b) The Permittee shall check each pump by visual inspection each calendar 

week for indications of liquids dripping from the pump seal.
Veolia ES Technical Solutions, L.L.C. Page 135 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(c) If an instrument reading of 10,000 ppm or greater is measured, a leak is 

detected.

(d) If there are indications of liquids dripping from the pump seal, a leak is 

detected.

(e) When a leak is detected, the Permittee shall repair it as soon as practicable, 

but not later than 15 calendar days after it is detected, except as provided in 

40 C.F.R. § 61.242-10. 

(f) The Permittee shall make a first attempt at repair no later than 5 calendar 

days after each leak is detected.

(g) Each pump equipped with a dual mechanical seal system that includes a 

barrier fluid system is exempt from the requirements of conditions

2.8(C)(2)(a) through (d) of this permit, provided the following 

requirements are met: 

(i) Each dual mechanical seal system is:

A. Operated with the barrier fluid at a pressure that is at all times 

greater than the pump stuffing box pressure; or 

B. Equipped with a barrier fluid degassing reservoir that is routed 

to a process or fuel gas system or connected by a closed-vent 

system to a control device that complies with the requirements 

of 40 C.F.R. § 61.242-11; or

C. Equipped with a system that purges the barrier fluid into a 

process stream with zero volatile hazardous air pollutant 

(VHAP) emissions to atmosphere. 

(ii) The barrier fluid is not in VHAP service and, if the pump is covered 

by standards under 40 C.F.R. Part 60, is not in VOC service.

(iii) Each barrier fluid system is equipped with a sensor that will detect 

failure of the seal system, the barrier fluid system, or both. 

(iv) Each pump is checked by visual inspection each calendar week for 

indications of liquids dripping from the pump seal. 

A. If there are indications of liquid dripping from the pump seal at 

the time of the weekly inspection, the Permittee shall monitor 

the pump as specified in 40 C.F.R. § 61.245 to determine the 

presence of VOC and VHAP in the barrier fluid. 
Veolia ES Technical Solutions, L.L.C. Page 136 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

B. If the monitor reading (taking into account any background 

readings) indicates the presence of VHAP, a leak is detected. 

For the purpose of this paragraph, the monitor may be 

calibrated with VHAP, or may employ a gas chromatography 

column to limit the response of the monitor to VHAP, at the 

option of the Permittee.

C. If an instrument reading of 10,000 ppm or greater (total VOC) 

is measured, a leak is detected.

(v) The Permittee must check each sensor as described in 40 C.F.R. 

§ 61.242-2(d)(3) daily unless it is equipped with an audible alarm. 

(vi) The Permittee must determine, based on design considerations and 

operating experience, criteria applicable to the presence and 

frequency of drips and to the sensor that indicates failure of the seal 

system, the barrier fluid system, or both.

(vii) If indications of liquids dripping from the pump seal exceed the 

criteria established in condition 2.8(C)(2)(g)(vi) of this permit, or if, 

based on the criteria established in condition 2.8(C)(2)(g)(vi) of this 

permit, the sensor indicates failure of the seal system, the barrier 

fluid system, or both, a leak is detected. 

(viii) When a leak is detected, the Permittee shall repair it as soon as 

practicable, but no later than 15 calendar days after it is detected, 

except as provided in 40 C.F.R. § 61.242-10. 

(ix) The Permittee shall make a first attempt at repair no later than 5

calendar days after each leak is detected.

(x) Any pump that is designated, as described in 40 C.F.R.

§ 61.246(e)(2), for no detectable emissions, as indicated by an 

instrument reading of less than 500 ppm above background, is 

exempt from the requirements of paragraphs (a), (c), and (d) if the 

pump:

A. Has no externally actuated shaft penetrating the pump housing;

B. Is demonstrated to be operating with no detectable emissions, 

as indicated by an instrument reading of less than 500 ppm 

above background, as measured by the method specified in 

40 C.F.R. § 61.245(c); and 
Veolia ES Technical Solutions, L.L.C. Page 137 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

C. Is tested for compliance with paragraph 40 C.F.R. § 61.242-

2(e)(2) initially upon designation, annually, and at other times 

requested by the Administrator.

(xi) If any pump is equipped with a closed-vent system capable of 

capturing and transporting any leakage from the seal or seals to a 

process or fuel gas system or to a control device that complies with 

the requirements of 40 C.F.R. § 61.242–11, it is exempt from the 

requirements of 40 C.F.R. § 61.242-2(a) through (e).

(xii) Any pump that is designated, as described in 40 C.F.R.

§ 61.246(f)(1), as an unsafe-to-monitor pump is exempt from the 

monitoring and inspection requirements of 40 C.F.R. § 61.242-2(a) 

and (d)(4) through (6) if: 

A. The Permittee demonstrates that the pump is unsafe to monitor 

because monitoring personnel would be exposed to an 

immediate danger as a consequence of complying with 

40 C.F.R. § 61.242-2(a); and

B. The Permittee has a written plan that requires monitoring of the 

pump as frequently as practicable during safe-to-monitor times 

but not more frequently than the periodic monitoring schedule 

otherwise applicable, and repair of the equipment according to 

the procedures in 40 C.F.R. § 61.242-2(c) if a leak is detected.

(xiii) Any pump that is located within the boundary of an unmanned plant 

site is exempt from the weekly visual inspection requirement of 

40 C.F.R. § 61.242-2(a)(2) and (d)(4), and the daily requirements of 

40 C.F.R. § 61.242-2(d)(5), provided that the Permittee visually 

inspects each pump as often as practicable and at least monthly.

3. Compressors: [40 C.F.R. § 61.242-3]

(a) Each compressor shall be equipped with a seal system that includes a 

barrier fluid system and that prevents leakage of process fluid to 

atmosphere, except as provided in 40 C.F.R. §§ 61.242-1(c) and 61.242-

3(h) and (i).

(b) Each compressor seal system required in paragraph 2.8(C)(3)(a), above,

shall be:

(i) Operated with the barrier fluid at a pressure that is greater than the 

compressor stuffing box pressure; or
Veolia ES Technical Solutions, L.L.C. Page 138 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(ii) Equipped with a barrier fluid system degassing reservoir that is 

routed to a process or fuel gas system or connected by a closed-vent 

system to a control device that complies with the requirements of 40 

C.F.R. § 61.242-11; or

(iii) Equipped with a system that purges the barrier fluid into a process 

stream with zero VHAP emissions to atmosphere.

(c) The barrier fluid shall not be in VHAP service and, if the compressor is 

covered by standards under 40 C.F.R. Part 60, shall not be in VOC service.

(d) The Permittee shall equip each barrier fluid system as described in 

40 C.F.R. § 61.242-3(a)-(c) with a sensor that will detect failure of the seal 

system, barrier fluid system, or both.

(e) The Permittee shall check each sensor as required in 40 C.F.R. § 61.242-

3(d) daily or shall equip the sensor with an audible alarm unless the 

compressor is located within the boundary of an unmanned plant site.

(f) The Permittee shall determine, based on design considerations and 

operating experience, a criterion that indicates failure of the seal system, 

the barrier fluid system, or both.

(g) If the sensor indicates failure of the seal system, the barrier fluid system, or 

both based on the criterion determined under paragraph (e)(2) of 40 C.F.R. 

§ 61.242-3, a leak is detected. 

(h) When a leak is detected, the Permittee shall repair it as soon as practicable, 

but not later than 15 calendar days after it is detected, except as provided in 

40 C.F.R. § 61.242-10.

(i) The Permittee shall make a first attempt at repair no later than 5 calendar 

days after each leak is detected. 

(j) A compressor is exempt from the requirements of 40 C.F.R. § 61.242-3(a) 

and (b) if it is equipped with a closed-vent system to capture and transport 

leakage from the compressor drive shaft back to a process or fuel gas 

system or to a control device that complies with the requirements of 

40 C.F.R. § 61.242–11, except as provided in 40 C.F.R. § 61.242-3(i).

(k) Any compressor that is designated, as described in 40 C.F.R.

§ 61.246(e)(2), for no detectable emission as indicated by an instrument 

reading of less than 500 ppm above background is exempt from the 

requirements of 40 C.F.R. § 61.242-3(a)-(h) if the compressor: 
Veolia ES Technical Solutions, L.L.C. Page 139 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(i) Is demonstrated to be operating with no detectable emissions, as 

indicated by an instrument reading of less than 500 ppm above 

background, as measured by the method specified in 40 C.F.R.

§ 61.245(c); and Is tested for compliance with 40 C.F.R. § 61.242-

3(i)(1) initially upon designation, annually, and at other times 

requested by the Administrator. 

4. Open-ended valves or lines: [40 C.F.R. § 61.242-6]

(a) The Permittee shall equip each open-ended valve or line with a cap, blind 

flange, plug, or a second valve, except as provided in 40 C.F.R. § 61.242-

1(c).

(b) The cap, blind flange, plug, or second valve shall seal the open end at all 

times except during operations requiring process fluid flow through the 

open-ended valve or line. 

(c) The Permittee shall operate each open-ended valve or line equipped with a 

second valve in a manner such that the valve on the process fluid end is 

closed before the second valve is closed. 

(d) When a double block and bleed system is being used, the bleed valve or 

line may remain open during operations that require venting the line 

between the block valves but shall comply with 40 C.F.R. § 61.242-6(a) at 

all other times. 

(e) Open-ended valves or lines in an emergency shutdown system which are 

designed to open automatically in the event of a process upset are exempt 

from the requirements of 40 C.F.R. § 61.242-6(a), (b) and (c). 

(f) Open-ended valves or lines containing materials which would 

autocatalytically polymerize or would present an explosion, serious 

overpressure, or other safety hazard if capped or equipped with a double 

block and bleed system as specified in 40 C.F.R. § 61.242-6(a) through (c)

are exempt from the requirements of 40 C.F.R. § 61.242-6(a) through (c).

5. Valves: [40 C.F.R. § 61.242-7]

(a) The Permittee shall monitor each valve monthly to detect leaks by the 

method specified in 40 C.F.R. § 61.245(b) and shall comply with 40 C.F.R.

§ 61.242-7(b)-(e), except as provided in 40 C.F.R. §§ 61.242-7(f), (g), and 

(h), 61.243-1 or 61.243-2, and 61.242-1(c).

(b) If an instrument reading of 10,000 ppm or greater is measured, a leak is 

detected.
Veolia ES Technical Solutions, L.L.C. Page 140 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(c) The Permittee may monitor any valve for which a leak is not detected for 2 

successive months the first month of every quarter, beginning with the next 

quarter, until a leak is detected.

(d) If a leak is detected, the Permittee shall monitor the valve monthly until a 

leak is not detected for 2 successive months. 

(e) When a leak is detected, the Permittee shall repair it as soon as practicable, 

but no later than 15 calendar days after the leak is detected, except as 

provided in 40 C.F.R. § 61.242-10.

(f) The Permittee shall make a first attempt at repair no later than five calendar 

days after each leak is detected.

(g) First attempts at repair include, but are not limited to, the following best 

practices where practicable:

(i) Tightening of bonnet bolts; 

(ii) Replacement of bonnet bolts; 

(iii) Tightening of packing gland nuts; and 

(iv) Injection of lubricant into lubricated packing.

(h) Any valve that is designated, as described in 40 C.F.R. § 61.246(e)(2), for 

no detectable emissions, as indicated by an instrument reading of less than 

500 ppm above background, is exempt from the requirements of 40 C.F.R.

§ 61.242-7(a) if the valve: 

(i) Has no external actuating mechanism in contact with the process 

fluid; 

(ii) Is operated with emissions less than 500 ppm above background, as 

measured by the method specified in 40 C.F.R. § 61.245(c); and 

(iii) Is tested for compliance with 40 C.F.R. § 61.242-7(f)(2) initially 

upon designation, annually, and at other times requested by the 

Administrator.

(i) Any valve that is designated, as described in 40 C.F.R. § 61.246(f)(1), as an 

unsafe-to-monitor valve is exempt from the requirements of 40 C.F.R.

§ 61.242-7(a) if: 
Veolia ES Technical Solutions, L.L.C. Page 141 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(i) The Permittee demonstrates that the valve is unsafe to monitor 

because monitoring personnel would be exposed to an immediate 

danger as a consequence of complying with 40 C.F.R. § 61.242-7(a); 

and

(ii) The Permittee has a written plan that requires monitoring of the 

valve as frequent as practicable during safe-to-monitor times.

(j) Any valve that is designated, as described in 40 C.F.R. § 61.246(f)(2), as a 

difficult-to-monitor valve is exempt from the requirements of paragraph (a) 

of 40 C.F.R. § 61.242-7 if:

(i) The Permittee demonstrates that the valve cannot be monitored 

without elevating the monitoring personnel more than 2 meters 

above a support surface;

(ii) The process unit within which the valve is located is an existing 

process unit; and 

(iii) The Permittee follows a written plan that requires monitoring of the 

valve at least once per calendar year. 

6. Alternative standards for valves in VHAP service - allowable percentage of 

valves leaking: [40 C.F.R. § 61.243-1] 

(a) The Permittee may elect to have all valves within a process unit comply 

with an allowable percentage of valves leaking of equal to or less than 2.0 

percent. 

(b) The following requirements shall be met if the Permittee decides to comply 

with an allowable percentage of valves leaking:

(i) The Permittee must notify the Administrator that it has elected to 

have all valves within a process unit to comply with the allowable 

percentage of valves leaking before implementing this alternative 

standard, as specified in 40 C.F.R. § 61.247(d). 

(ii) The Permittee conducts a performance test as specified in 40 C.F.R.

§ 61.243-1(c) initially upon designation, annually, and at other times 

requested by the Administrator.

(iii) If a valve leak is detected, the Permittee shall repair it in accordance 

with 40 C.F.R. § 61.242-7(d) and (e).

(c) The Permittee shall conduct performance tests in the following manner:
Veolia ES Technical Solutions, L.L.C. Page 142 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(i) The Permittee shall monitor all valves in VHAP service within the 

process unit within 1 week by the methods specified in 40 C.F.R.

§ 61.245(b). 

(ii) If an instrument reading of 10,000 ppm or greater is measured, a leak 

is detected. 

(iii) The Permittee shall determine the leak percentage by dividing the 

number of valves in VHAP service for which leaks are detected by 

the number of valves in VHAP service within the process unit.

(d) If the Permittee elects to have all valves comply with this alternative 

standard, no process unit shall have a leak percentage greater than 2.0 

percent.

(e) If the Permittee decides no longer to comply with 40 C.F.R. § 61.243-1, the 

Permittee must notify the Administrator in writing that it will follow the 

work practice standard described in 40 C.F.R. § 61.242-7(a)-(e).

7. Alternative standards for valves in VHAP service: [40 C.F.R. § 61.243-2]

(a) The Permittee may elect for all valves within a process unit to comply with 

one of the alternative work practices specified in 40 C.F.R. § 61.243-

2(b)(2) and (3).

(b) The Permittee must notify the Administrator before implementing one of 

the alternative work practices, as specified in 40 C.F.R. § 61.247(d). 

(c) The Permittee shall comply initially with the requirements for valves, as 

described in 40 C.F.R. § 61.242-7.

(d) After two consecutive quarterly leak detection periods with the percentage 

of valves leaking equal to or less than 2.0, the Permittee may begin to skip 

one of the quarterly leak detection periods for the valves in VHAP service. 

(e) After five consecutive quarterly leak detection periods with the percentage 

of valves leaking equal to or less than 2.0, the Permittee may begin to skip 

three of the quarterly leak detection periods for the valves in VHAP 

service.

(f) If the percentage of valves leaking is greater than 2.0, the Permittee shall 

comply with the requirements as described in 40 C.F.R. § 61.242-7, but 

may again elect to use 40 C.F.R. § 61.243-2.
Veolia ES Technical Solutions, L.L.C. Page 143 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(D) Monitoring and Testing [40 C.F.R. § 71.6(a)(3)(i)(A)]

1. The Permittee shall comply with the following test methods and procedures 

requirements of 40 C.F.R. § 61.245:

(a) The Permittee shall monitor, as required in 40 C.F.R. §§ 61.242, 61.243, 

61.244, and 61.135, as follows:

(i) The Permittee shall monitor as required by Method 21 of 40 C.F.R. 

Part 60, Appendix A.

(ii) The detection instrument shall meet the performance criteria of 

Method 21.

(iii) The instrument shall be calibrated before use on each day of its use 

by the procedures specified in Method 21.

(iv) Calibration gases shall be:

A. Zero air (less than 10 ppm of hydrocarbon in air); and

B. A mixture of methane or n-hexane and air at a concentration of 

approximately, but less than, 10,000 ppm methane or n-hexane. 

(v) The instrument probe shall be traversed around all potential leak 

interfaces as close to the interface as possible, as described in 

Method 21 of 40 C.F.R. Part 60, Appendix A. 

(b) When equipment is tested for compliance with or monitored for no 

detectable emissions, the Permittee shall comply with the following 

requirements: 

(i) The Permittee shall test equipment as required by 40 C.F.R.

§ 61.245(b)(1) through (4).

(ii) The background level shall be determined, as set forth in Method 21

of 40 C.F.R. Part 60, Appendix A.

(iii) The instrument probe shall be traversed around all potential leak 

interfaces as close to the interface as possible as described in Method 

21 of 40 C.F.R. Part 60, Appendix A.

(iv) The arithmetic difference between the maximum concentration 

indicated by the instrument and the background level is compared 

with 500 ppm for determining compliance. 
Veolia ES Technical Solutions, L.L.C. Page 144 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(c) Each piece of equipment within a process unit that can conceivably contain 

equipment in VHAP service is presumed to be in VHAP service unless the 

Permittee demonstrates that the piece of equipment is not in VHAP service. 

For a piece of equipment to be considered not in VHAP service, it must be 

determined that the percent VHAP content can be reasonably expected 

never to exceed 10 percent by weight. For purposes of determining the 

percent VHAP content of the process fluid that is contained in or contacts 

equipment, the Permittee shall use procedures that conform to the methods 

described in ASTM Method D-2267 (incorporated by reference as specified 

in 40 C.F.R. § 61.18).

(d) The Permittee may use engineering judgment rather than the procedures in 

40 C.F.R. § 61.245(d)(1) to demonstrate that the percent VHAP content 

does not exceed 10 percent by weight, provided that the engineering 

judgment demonstrates that the VHAP content clearly does not exceed 10 

percent by weight. When the Permittee and the Administrator do not agree 

on whether a piece of equipment is not in VHAP service, however, the 

Permittee shall use the procedures in 40 C.F.R. § 61.245(d)(1).

(e) If the Permittee determines that a piece of equipment is in VHAP service, 

the determination can be revised only after following the procedures in 

paragraph 40 C.F.R. § 61.245(d)(1).

(f) Samples used in determining the percent VHAP content shall be 

representative of the process fluid that is contained in or contacts the 

equipment or the gas being combusted in the flare.

2. Requirements of 40 C.F.R. § 61.246:

(a) The Permittee may comply with the recordkeeping requirements for 

multiple process units subject to the provisions of 40 C.F.R. Part 61, 

Subpart V, in one recordkeeping system if the system identifies each record 

by each process unit.

(b) When each leak is detected as specified in 40 C.F.R. §§ 61.242-2, 61.242-

3, 61.242-7, and 61.242-8, the following requirements apply:

(i) The Permittee shall attach a weatherproof and readily visible 

identification, marked with the equipment identification number, to 

the leaking equipment.

(ii) The Permittee may remove the identification on a valve after it has 

monitored the valve for 2 successive months as specified in 40 
Veolia ES Technical Solutions, L.L.C. Page 145 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

C.F.R. § 242-7(c) and no leak has been detected during those 2 

months.

(iii) The Permittee may remove the identification on equipment, except 

on a valve, after it has repaired the equipment.

(c) When the Permittee has detected each leak as specified in 40 C.F.R.

§§ 61.242-2, 61.242-3, 61.242-7, 61.242-8, and 61.135, the Permittee shall 

record the following information in a log and shall keep the information for 

2 years in a readily accessible location:

(i) The instrument and operator identification numbers and the 

equipment identification number;

(ii) The date the leak was detected and the dates of each attempt to repair 

the leak;

(iii) Repair methods applied in each attempt to repair the leak;

(iv) “Above 10,000” if the maximum instrument reading measured by 

the methods specified in 40 C.F.R. § 61.245(a) after each repair 

attempt is equal to or greater than 10,000 ppm;

(v) “Repair delayed” and the reason for the delay if a leak is not repaired 

within 15 calendar days after discovery of the leak;

(vi) The signature of the responsible official whose decision it was that 

repair could not be affected without a process shutdown;

(vii) The expected date of successful repair of the leak if a leak is not 

repaired within 15 calendar days;

(viii) Dates of process unit shutdowns that occur while the equipment is 

unrepaired; and

(ix) The date of successful repair of the leak.

(d) The Permittee shall record in a log and keep in a readily accessible location 

the following information pertaining to all equipment to which a standard 

applies:

(i) A list of identification numbers for equipment (except welded 

fittings) subject to the requirements of 40 C.F.R. Part 61, Subpart V;
Veolia ES Technical Solutions, L.L.C. Page 146 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(ii) A list of identification numbers for equipment that the Permittee

elects to designate for no detectable emissions as indicated by an 

instrument reading of less than 500 ppm above background;

(iii) The designation of this equipment for no detectable emissions shall 

be signed by a responsible official;

(iv) The dates of each compliance test required in 40 C.F.R. §§ 61.242-

2(e), 61.242-3(i), 61.242-4, and 61.242-7(f);

(v) The background level measured during each compliance test; and

(vi) The maximum instrument reading measured at the equipment during 

each compliance test.

(e) The Permittee shall record in a log and keep in a readily accessible location 

the following information pertaining to all valves subject to the 

requirements of 40 C.F.R. § 61.242-7(g) and (h) and to all pumps subject to 

the requirements of 40 C.F.R. § 61.242-2(g):

(i) A list of identification numbers for valves and pumps that are 

designated as unsafe to monitor, an explanation for each valve or 

pump stating why the valve or pump is unsafe to monitor, and the 

plan for monitoring each valve or pump; and

(ii) A list of identification numbers for valves that are designated as 

difficult to monitor, an explanation for each valve stating why the 

valve is difficult to monitor, and the planned schedule for monitoring 

each valve.

(f) The Permittee shall record and keep in a readily accessible location the 

following information:

(i) Design criterion required in 40 C.F.R. §§ 61.242-2(d)(5) and 61.242-

3(e)(2), and an explanation of the design criterion; and

(ii) Any changes to this criterion and the reasons for the changes.

(g) Hours of operation of each component.

(h) Emissions of VOC.

(E) Recordkeeping and Reporting [40 C.F.R. § 71.6(a)(3)]
Veolia ES Technical Solutions, L.L.C. Page 147 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

1. The Permittee shall promptly notify the permitting authority of deviations of the 

affected leaking equipment from the permit requirements. Reports shall describe 

the probable cause of such deviations, and any corrective actions or preventive 

measures taken. [40 C.F.R. § 71.6(a)(3)(iii)(B)]

2. Requirements of 40 C.F.R. § 61.247:

(a) The Permittee shall submit a statement in writing notifying the 

Administrator that it is implementing the requirements of 40 C.F.R.

§§ 61.242, 61.245, 61.246, and 61.247.

(b) In the case of an existing source or a new source which has an initial 

startup date preceding the effective date, the Permittee shall submit the 

statement to the Administrator along with the information required under 

40 C.F.R. § 61.10 within 90 days of the effective date, unless a waiver of 

compliance is granted under 40 C.F.R. § 60.11. If a waiver of compliance 

is granted, the Permittee must submit the statement on a date scheduled by 

the Administrator.

(c) The Permittee must include the following information for each source in 

the statement:

(i) Equipment identification number and process unit identification;

(ii) Type of equipment (for example, a pump or pipeline valve);

(iii) Percent by weight VHAP in the fluid at the equipment;

(iv) Process fluid state at the equipment (gas/vapor or liquid); and

(v) Method of compliance with the standard (for example, “monthly 

leak detection and repair” or “equipped with dual mechanical 

seals”).

(d) The Permittee shall submit to the Administrator a report, semiannually 

starting 6 months after the initial report required in 40 C.F.R. § 61.247(a), 

that includes the following information:

(i) Process unit identification;

(ii) For each month during the semiannual reporting period:

A. Number of valves for which leaks were detected as described 

in 40 C.F.R. §§ 61.242-7(b) or 61.243-2;
Veolia ES Technical Solutions, L.L.C. Page 148 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

B. Number of valves for which leaks were not repaired as required 

in 40 C.F.R. § 61.242-7(d);

C. Number of pumps for which leaks were detected as described 

in 40 C.F.R. § 61.242-2(b) and (d)(6);

D. Number of pumps for which leaks were not repaired as 

required in 40 C.F.R. § 61.242-2(c) and (d)(6);

E. Number of compressors for which leaks were detected as 

described in 40 C.F.R. § 61.242-3(f);

F. Number of compressors for which leaks were not repaired as 

required in 40 C.F.R. § 61.242-3(g); and

G. The facts that explain any delay of repairs and, where 

appropriate, why a process unit shutdown was technically 

infeasible.

2.10 INSIGNIFICANT EMISSION UNITS AND ACTIVITIES

(A) List of Insignificant Emission Units and Activities [40 C.F.R. § 71.5(c)(11)]

The following are insignificant emission units and activities at the facility:

1. One 2.5 mmBtu/hr Tioga portable boiler;

2. One horizontal 550-gallon kerosene tank;

3. Two horizontal 550-gallon No. 2 diesel fuel tanks;

4. Ash handling;

5. Handling of spent dry scrubber solids;

6. Lime unloading and proportioning;

7. Gasoline storage and dispensing;

8. Use of absorbent material;

9. General vehicle maintenance and servicing (assumed to include diesel fuel 

handling);

10. Laboratory (chemical and physical analysis);

11. Piping and storage system for natural gas;

12. Non-halogenated cold cleaning degreasers;

13. Internal combustion engines of motor vehicles; and 

14. Storage and handling of closed drums. 
Veolia ES Technical Solutions, L.L.C. Page 149 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(B) Applicable Requirements [40 C.F.R. § 71.6(a)(1)]

1. For each particulate matter process emission unit, the Permittee shall comply 

with the applicable particulate matter emission limit of 35 IAC 212.321 or 

212.322 and 35 IAC Part 266. For example, the particulate matter emissions 

from a process emission unit shall not exceed 0.55 pounds per hour if the 

emission unit’s process weight rate is 100 pounds per hour or less, pursuant to 35 

IAC 266.110. [35 IAC 212.321 or 212.322 and 35 IAC Part 266]

2. For each organic material emission unit that uses organic material, e.g., a mixer 

or printing line, the Permittee shall comply with the applicable VOM emission 

limit of 35 IAC 215.301, which requires that organic material emissions not 

exceed 8.0 pounds per hour or, if no odor nuisance exists, do not qualify as 

photochemically reactive material as defined in 35 IAC 211.4690. [35 IAC 

215.301]

3. For each open burning activity, the Permittee shall comply with 35 IAC Part 237, 

including the requirement to obtain a permit for open burning in accordance with 

35 IAC 237.201, if necessary. [35 IAC Part 237]

(C) Compliance with Applicable Requirements [40 C.F.R. § 71.6(a)(3)]

1. The Permittee shall keep current a file for the affected insignificant emission 

units, which may contain estimated emissions, throughput, inspection, 

maintenance and repair log, and other information necessary to demonstrate 

compliance with the applicable requirements and classification of the units as 

insignificant emissions units. [40 C.F.R. § 71.6(a)(3)(i)(B)]

2. The Permittee must maintain records of results of any emissions testing 

conducted on the affected emission units. [40 C.F.R. § 71.6(a)(3)(i)(B)]
Veolia ES Technical Solutions, L.L.C. Page 150 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

3.0 FACILITY-WIDE PERMIT REQUIREMENTS

3.1. GENERAL PART 71 RECORDKEEPING 

(A) Required Records [40 C.F.R. § 71.6(a)(3)(ii)]

The Permittee shall keep records of required monitoring information that include the 

following:

1. The date, place, and time of sampling or measurements;

2. The date(s) analyses were performed;

3. The company or entity that performed the analyses;

4. The analytical techniques or methods used;

5. The results of such analyses; and 

6. The operating conditions existing at the time of sampling or measurement.

(B) Record Retention Schedule [40 C.F.R. § 71.6(a)(3)(ii)]

The Permittee shall retain records of all required monitoring data and support 

information for a period of at least 5 calendar years from the date of the monitoring 

sample, measurement, report, or application. Support information includes, but is 

not limited to, all calibration and maintenance records, all original strip-chart 

recordings for continuous monitoring instrumentation, and copies of all reports 

required by this permit. 

(C) Emissions Calculation Methodology [40 C.F.R. § 71.6(a)(3)(i)(B)]

1. If an applicable requirement contained in this permit does not require the use of a 

specific methodology for calculating emissions, the Permittee must follow the 

following hierarchy (in order of preference) when selecting the appropriate 

methodology for calculating emissions:

(a) CEM data from the stationary source;

(b) Performance test data from the stationary source;

(c) Manufacturer’s emissions performance guarantee;

(d) CEM data from a similar stationary source or sources;

(e) Performance test data from a similar stationary source or sources;

(f) Industry-derived emission factors;
Veolia ES Technical Solutions, L.L.C. Page 151 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(g) Emission factors published in the latest version of EPA’s Compilation of

Air Pollutant Emission Factors (AP-42), with “A”-rated AP-42 emission 

factors being considered before the lower rated emission factors;

(h) Engineering judgment.

2. The Permittee must document that it reviewed the hierarchy in condition 

3.1(C)(1), above, before selecting the emissions calculation methodology 

including a demonstration of the selected emission factors’ appropriateness for 

the specific emission units from which emissions are being calculated.

3. The Permittee’s choice of emission calculation methodology pursuant to

condition 3.1(C)(1), above, does not preclude any person, such as EPA, the 

public and other regulatory agencies, from using other credible evidence to 

establish compliance or noncompliance with applicable requirements as provided 

by the Act. [42 U.S.C. § 7413] 

3.2. GENERAL PART 71 REPORTING [40 C.F.R. § 71.6(a)(3)(iii)]

(A) Semi-annual Reports

1. The Permittee shall submit to EPA semi-annual reports of all required 

monitoring each six month reporting period from January 1 to June 30 and from 

July 1 to December 31. All reports shall be submitted to the EPA and shall be 

postmarked by the 30th day following the end of the reporting period. All 

instances of deviations from permit requirements must be clearly identified in 

such reports. All required reports must be certified by a responsible official 

consistent with condition 4.8(A)(1) of this permit. [40 C.F.R.

§ 71.6(a)(3)(iii)(A)]

2. A monitoring report submitted pursuant to condition 3.2(A)(1) must include the 

following:

(a) The company name and address;

(b) The beginning and ending dates of the reporting period;

(c) The emissions unit or activity being monitored;

(d) The emissions limitation or standard, including operational requirements 

and limitations (such as parameter ranges), specified in the permit for 

which compliance is being monitored;

(e) All instances of deviations from permit requirements whether demonstrated 

by referenced test method, monitoring, or through any other credible 
Veolia ES Technical Solutions, L.L.C. Page 152 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

evidence, including those attributable to upset conditions as defined in this 

permit, and the date on which each deviation occurred;

(f) The total time when monitoring required by this permit was not performed 

during the reporting period and, at the source’s discretion, either the total 

duration of deviations indicated by such monitoring or the actual records of 

deviations;

(g) All other monitoring results, data, or analyses required to be reported by 

the applicable requirement; and

(h) The name, title, and signature of the responsible official who is certifying 

to the truth, accuracy, and completeness of the report.

(i) Any report required by an applicable requirement that provides the same 

information described in conditions 3.2(A)(2)(a) through (h), above, shall 

satisfy the requirement under condition 3.2(A)(1).

[40 C.F.R. § 71.6(a)(3)(iii)(A)]

(B) Deviations

1. “Deviation” means any situation in which an emissions unit fails to meet a 

permit term or condition. A deviation is not always a violation. A deviation can 

be determined by observation or through review of data obtained from any 

testing, monitoring, or record keeping established in accordance with 40 C.F.R.

§ 71.6(a)(3)(i) and (ii). For a situation lasting more than 24 hours, each 24-hour 

period is considered a separate deviation. “Deviations” includes, but is not 

limited to, any of the following: [40 C.F.R. § 71.6(a)(3)(iii)(C)]

(a) A situation when emissions exceed an emission limitation or standard;

(b) A situation where process or emissions control device parameter values 

indicate that an emission limitation or standard has not been met; and

(c) A situation in which observations or data collected demonstrates 

noncompliance with an emission limitation or standard or any work 

practice or operating condition required by the permit.

2. The Permittee shall promptly report to the EPA deviations from permit 

requirements, including those attributed to malfunction, emergency or other 

upset conditions, the probable cause of such deviations, and any corrective 

actions or preventive measures taken. “Prompt” is defined as follows: 

[40 C.F.R. § 71.6(a)(3)(iii)(B)]
Veolia ES Technical Solutions, L.L.C. Page 153 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(a) Any definition of “prompt” or specific timeframe for reporting deviations 

provided in an underlying applicable requirement (as identified in this 

permit); or 

(b) Where the underlying applicable requirement does not define prompt or 

provide a timeframe for reporting deviations, reports of deviations will be 

submitted based on the following schedule:

(i) For emissions of a hazardous air pollutant or a toxic air pollutant (as 

identified in an applicable regulation) that continue for more than an 

hour in excess of permit requirements, the report must be made 

within 24 hours of the occurrence.

(ii) For emissions of any regulated pollutant excluding a hazardous air 

pollutant or a toxic air pollutant that continue for more than two 

hours in excess of permit requirements, the report must be made 

within 48 hours.

(iii) For all other deviations from permit requirements, the report shall be 

submitted with the semi-annual monitoring report required in 

condition 3.2(A)(1) of this permit.

3. If any of the requirements in condition 3.2(B)(1)(a) through (c), above, are met, 

the Permittee must notify EPA by telephone or facsimile based on the timetable 

listed. A written notice, certified consistent with condition 4.8(A), must be 

submitted within 10 working days of the occurrence. All deviations reported 

under this condition must also be identified in the semi-annual report required 

under condition 3.2(A)(1), above.

3.3. PERFORMANCE TESTING [40 C.F.R. § 71.6(a)(3)(i)]

The Permittee shall provide performance testing facilities that include the following: 

(A) Sampling ports adequate for the applicable test methods;

(B) Safe sampling platform(s); 

(C) Safe access to sampling platform(s); and

(D) Utilities for sampling and testing equipment. 
Veolia ES Technical Solutions, L.L.C. Page 154 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

3.4. FACILITY-WIDE APPLICABLE REQUIREMENTS

(A) Fugitive Particulate Matter Restrictions [35 IAC 212.301]

The Permittee shall not cause or allow the emission of fugitive particulate matter 

from any process, including any material handling or storage activity that is visible 

by an observer looking generally toward the zenith at a point beyond the property 

line of the emission source. 

(B) Open Burning Prohibitions [35 IAC 237.102]

1. The Permittee shall not cause or allow open burning, except as provided in 

35 IAC 237.

2. The Permittee shall not cause or allow open burning of any refuse in any 

chamber or apparatus, unless such chamber or apparatus is designed for the 

purpose of disposing of the class of refuse being burned.

(C) Visible Emissions [35 IAC 212.123(a)]

The Permittee shall not cause or allow the emission of smoke or other particulate 

matter, with an opacity greater than 30 percent, into the atmosphere from any 

emission unit other than those emission units subject to the requirements of 35 IAC 

212.122, except as allowed by 35 IAC 212.123(b) and 35 IAC 212.124. 

(D) Recycling and Emissions Reduction [40 C.F.R. Part 82, Subpart F]

The Permittee shall comply with the standards for recycling and emissions reduction 

of ozone depleting substances pursuant to 40 C.F.R. Part 82, Subpart F, except as 

provided for motor vehicle air conditioners in 40 C.F.R. Part 82, Subpart B:

1. Persons opening appliances for maintenance, service, repair, or disposal must 

comply with the required practices pursuant to 40 C.F.R. § 82.156.

2. Equipment used during the maintenance, service, repair, or disposal of 

appliances must comply with the standards for recycling and recovery equipment 

pursuant to 40 C.F.R. § 82.158.

3. Persons performing maintenance, service, repair, or disposal of appliances must 

be certified by an approved technician certification program pursuant to 40 

C.F.R. § 82.161.
Veolia ES Technical Solutions, L.L.C. Page 155 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(E) Risk Management Plan (RMP) [40 C.F.R. § 68.215(a)(2)(i) and (ii)]

Should this stationary source, as defined in 40 C.F.R. § 68.3, become subject to the 

federal regulations for Chemical Accident Prevention in 40 C.F.R. Part 68, then the 

Permittee shall submit the items below: 

1. A compliance schedule for meeting the requirements of 40 C.F.R. Part 68 by the 

date provided in 40 C.F.R. § 68.10(a); or

2. A certification statement that the source is in compliance with all requirements of 

40 C.F.R. Part 68, including the registration and submission of the RMP, as part 

of the annual compliance certification.

(F) Episode Action Plans [35 IAC 244, Subpart C]

The Permittee shall maintain at the source and have on file with the IEPA a written 

episode action plan (plan) for reducing the levels of emissions during yellow alerts, 

red alerts, and emergencies, consistent with safe operating procedures. The plan 

shall contain the information specified in 35 IAC 244.144 and is incorporated by 

reference into this permit.

(G) Annual Benzene Waste Quantity Determination [40 C.F.R. § 61.355]

The Permittee shall determine the total annual benzene quantity from facility waste 

by the following procedure:

1. For each waste stream subject to 40 C.F.R. Part 61, Subpart FF, having a flow

weighted annual average water content greater than 10 percent water, on a 

volume basis as total water, or which is mixed with water or other wastes at any 

time and the resulting mixture has an annual average water content greater than 

10 percent as specified in 40 C.F.R. § 61.342(a), the Permittee shall: 

(a) Determine the annual waste quantity for each waste stream using the 

procedures specified in 40 C.F.R. § 61.355(b). 

(b) Determine the flow-weighted annual average benzene concentration for 

each waste stream using the procedures specified in 40 C.F.R. § 61.355(c).

(c) Calculate the annual benzene quantity for each waste stream by multiplying 

the annual waste quantity of the waste stream times the flow-weighted 

annual average benzene concentration. 

(d) Total annual benzene quantity from facility waste is calculated by adding 

together the annual benzene quantity for each waste stream generated 
Veolia ES Technical Solutions, L.L.C. Page 156 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

during the year and the annual benzene quantity for each process unit 

turnaround waste annualized according to 40 C.F.R. § 61.355(b)(4).

2. If the total annual benzene quantity from facility waste is equal to or greater than 

10 megagram per year (11 ton/yr), then the Permittee shall comply with the 

requirements of 40 C.F.R. § 61.342(c), (d), or (e).

(H) General Prohibition on Air Pollution [35 IAC 201.141]

No person shall cause or threaten or allow the discharge or emission of any 

contaminant into the environment in any State so as, either alone or in combination 

with contaminants from other sources, to cause or tend to cause air pollution in 

Illinois, or so as to violate the provisions of 35 IAC, Subtitle B, Chapter I, or so as to 

prevent the attainment or maintenance of any applicable ambient air quality 

standard. [35 IAC 201.141]

(I) Facility-wide Testing [40 C.F.R. § 71.6(a)(3)(i)]

1. Testing Required by 35 IAC 201.282.

Every emission source and all air pollution control equipment shall be subject to 

the following testing requirements for the purpose of determining the nature and 

quantities of specified air contaminant emissions and for the purpose of 

determining ground level and ambient air concentrations of such air contaminants:

(a) Testing by the Permittee. The IEPA may require the Permittee to conduct 

tests in accordance with procedures adopted by the IEPA, at such 

reasonable times as may be specified by the IEPA and at the expense of the 

Permittee. The IEPA may adopt procedures detailing methods of testing 

and formats for reporting results of testing. Such procedures and formats, 

and revisions thereto, shall not become effective until filed with the Index 

Division of the Office of the Secretary of State as Required by “An Act 

concerning administrative rules,” approved June 14, 1951, as amended. All 

such tests shall be made by or under the direction of a person qualified by 

training and/or experience in the field of air pollution testing. The IEPA 

shall have the right to observe all aspects of such tests.

(b) Testing by the IEPA. The IEPA shall have the right to conduct such tests 

at any time at its own expense. Upon request of the IEPA, the Permittee 

shall provide, without charge to the IEPA, necessary holes in stacks or 

ducts and other safe and proper testing facilities, including scaffolding, but 

excluding instruments and sensing devices, as may be necessary.
Veolia ES Technical Solutions, L.L.C. Page 157 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

2. Determination of annual benzene waste quantity for off-site wastes [40 C.F.R. 

§ 61.355]

(a) The determination of annual benzene waste quantity for the off-site wastes 

received by the Permittee shall be made by using the methods and 

procedures established in 40 C.F.R. § 61.355 along with the following: 

(b) For the purposes of the calculation required by 40 C.F.R. § 61.355(a), the 

Permittee shall determine the flow-weighted annual average benzene 

concentration in a manner that meets the requirements given in 40 C.F.R. 

§ 61.355(c)(1) using either of the methods given in 40 C.F.R. 

§ 61.355(c)(2) and (c)(3). 

(i) The determination for wastes that are received from offsite shall be 

made at the point where the waste enters the hazardous waste 

treatment, storage, or disposal facility.

(ii) Knowledge of the waste. The Permittee shall provide sufficient 

information to document the flow-weighted annual average benzene 

concentration of each waste stream. Examples of information that 

could constitute knowledge include material balances, records of 

chemicals purchases, or previous test results provided the results are 

still relevant to the current waste stream conditions. If test data are 

used, then the Permittee shall provide documentation describing the 

testing protocol and the means by which sampling variability and 

analytical variability were accounted for in the determination of the 

flow-weighted annual average benzene concentration for the waste 

stream. When the Permittee and the Administrator do not agree on 

determinations of the flow-weighted annual average benzene 

concentration based on knowledge of the waste, the procedures 

under 40 C.F.R. § 61.355(c)(3) shall be used. 

(iii) Measurements of the benzene concentration in the waste stream in 

accordance with the following procedures: 

A. Collect a minimum of three representative samples from each 

waste stream. Where feasible, samples shall be taken from an 

enclosed pipe prior to the waste being exposed to the 

atmosphere.

B. For waste in enclosed pipes, the following procedures shall be 

used:
Veolia ES Technical Solutions, L.L.C. Page 158 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

I. Samples shall be collected prior to the waste being 

exposed to the atmosphere in order to minimize the loss 

of benzene prior to sampling.

II. A static mixer shall be installed in the process line or in 

a by-pass line unless the Permittee demonstrates that 

installation of a static mixer in the line is not necessary 

to accurately determine the benzene concentration of the 

waste stream. 

III. The sampling tap shall be located within two pipe 

diameters of the static mixer outlet.

IV. Prior to the initiation of sampling, sample lines and 

cooling coil shall be purged with at least four volumes of 

waste.

V. After purging, the sample flow shall be directed to a 

sample container and the tip of the sampling tube shall 

be kept below the surface of the waste during sampling 

to minimize contact with the atmosphere.

VI. Samples shall be collected at a flow rate such that the 

cooling coil is able to maintain a waste temperature less 

than 10°C (50°F).

VII. After filling, the sample container shall be capped 

immediately (within 5 seconds) to leave a minimum 

headspace in the container.

VIII. The sample containers shall immediately be cooled and 

maintained at a temperature below 10°C (50°F) for 

transfer to the laboratory. 

C. When sampling from an enclosed pipe is not feasible, a 

minimum of three representative samples shall be collected in a 

manner to minimize exposure of the sample to the atmosphere 

and loss of benzene prior to sampling.

D. Each waste sample shall be analyzed using one of the 

following test methods for determining the benzene 

concentration in a waste stream:

I. Method 8020, Aromatic Volatile Organics, in “Test 

Methods for Evaluating Solid Waste, Physical/Chemical 
Veolia ES Technical Solutions, L.L.C. Page 159 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

Methods,” EPA Publication No. SW-846 (incorporation 

by reference as specified in 40 C.F.R. § 61.18); 

II. Method 8021, Volatile Organic Compounds in Water by 

Purge and Trap Capillary Column Gas Chromatography 

with Photoionization and Electrolytic Conductivity 

Detectors in Series, in “Test Methods for Evaluating 

Solid Waste, Physical/Chemical Methods,” EPA 

Publication No. SW-846 (incorporation by reference as 

specified in 40 C.F.R. § 61.18);

III. Method 8240, Gas Chromatography/Mass Spectrometry 

for Volatile Organics, in “Test Methods for Evaluating 

Solid Waste, Physical/Chemical Methods,” EPA 

Publication No. SW-846 (incorporation by reference as 

specified in 40 C.F.R. § 61.18);

IV. Method 8260, Gas Chromatography/Mass Spectrometry 

for Volatile Organics: Capillary Column Technique, in 

“Test Methods for Evaluating Solid Waste, 

Physical/Chemical Methods,” EPA Publication No. SW846 (incorporated by reference as specified in 40 C.F.R. 

§ 61.18);

V. Method 602, Purgeable Aromatics, as described in 40 

C.F.R. Part 136, Appendix A, Test Procedures for 

Analysis of Organic Pollutants, for wastewaters for 

which this is an approved EPA methods; or 

VI. Method 624, Purgeables, as described in 40 C.F.R. Part 

136, Appendix A, Test Procedures for Analysis of 

Organic Pollutants, for wastewaters for which this is an 

approved EPA method. 

E. The Permittee shall calculate the flow-weighted annual average 

benzene concentration by averaging the results of the sample 

analyses as follows: 

Where: 
Veolia ES Technical Solutions, L.L.C. Page 160 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

= Flow-weighted annual average benzene concentration 

for waste stream, ppmw. 

Qt = Total annual waste quantity for waste stream, kg/yr 

(lb/yr). 

n = Number of waste samples (at least 3). 

Qi = Annual waste quantity for waste stream represented 

by Ci, kg/yr (lb/yr). 

Ci = Measured concentration of benzene in waste sample i, 

ppmw. 

(J) Facility-wide Recordkeeping [40 .C.F.R § 71.6(a)(3)(i)(B)]

1. If testing is required by condition 3.4(I), the Permittee shall keep records of the 

testing, including the test date, conditions, methodologies, calculations, test 

results, and any discrepancies between the test results. 

2. Reporting requirements established by 40 C.F.R. Part 61, Subpart FF: [40 

C.F.R. § 61.357]

If the total annual benzene quantity from facility waste is equal to or greater than 

10 Mg/yr (11 ton/yr), then the Permittee shall submit to the Administrator the 

following reports:

(a) The Permittee shall submit annually to the Administrator a report that 

updates the information listed in 40 C.F.R. § 61.357(a)(1) through (a)(3).

If the information in the annual report required by 40 C.F.R. § 61.357(a)(1) 

through (a)(3) is not changed in the following year, the Permittee may 

submit a statement to that effect. 

(b) The Permittee must include the following information in the annual report:

[40 C.F.R. § 61.357(a)(1) through (a)(3)]

(i) Total annual benzene quantity from facility waste determined in 

accordance with 40 C.F.R. § 61.355(a).

(ii) A table identifying each waste stream and whether or not the waste 

stream will be controlled for benzene emissions in accordance with 

the requirements of 40 C.F.R. Part 61, Subpart FF. 

(iii) For each waste stream identified as not being controlled for benzene 

emissions in accordance with the requirements of 40 C.F.R. Part 61,
Veolia ES Technical Solutions, L.L.C. Page 161 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

Subpart FF, the Permittee shall add the following information to the 

table: 

A. Whether or not the water content of the waste stream is greater 

than 10 percent; 

 

B. Whether or not the waste stream is a process wastewater 

stream, product tank drawdown, or landfill leachate; 

C. Annual waste quantity for the waste stream; 

D. Range of benzene concentrations for the waste stream; 

E. Annual average flow-weighted benzene concentration for the 

waste stream; and 

F. Annual benzene quantity for the waste stream. 

(c) Beginning 3 months after the date that the equipment necessary to comply 

with 40 C.F.R. Part 61, Subpart FF, has been certified in accordance with 

40 C.F.R. § 61.357(d)(1), the Permittee shall submit quarterly to the 

Administrator a certification that all of the required inspections have been 

carried out in accordance with the requirements of 40 C.F.R. Part 61, 

Subpart FF. 

(d) Beginning 3 months after the date that the equipment necessary to comply 

with 40 C.F.R. Part 61, Subpart FF, has been certified in accordance with 

40 C.F.R. § 61.357(d)(1), the Permittee shall submit a report quarterly to 

the Administrator that includes: 

 

(i) If a treatment process or wastewater treatment system unit is 

monitored in accordance with 40 C.F.R. § 61.354(a)(1), then each 

period of operation during which the concentration of benzene in the 

monitored waste stream exiting the unit is equal to or greater than 10 

parts per million by weight.

(ii) If a treatment process or wastewater treatment system unit is 

monitored in accordance with 40 C.F.R. § 61.354(a)(2), then each 3-

hour period of operation during which the average value of the 

monitored parameter is outside the range of acceptable values or

during which the unit is not operating as designed.

(iii) If a treatment process or wastewater treatment system unit is 

monitored in accordance with 40 C.F.R. § 61.354(b), then each 

period of operation during which the flow-weighted annual average 
Veolia ES Technical Solutions, L.L.C. Page 162 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

concentration of benzene in the monitored waste stream entering the 

unit is equal to or greater than 10 ppmw and/or the total annual 

benzene quantity is equal to or greater than 1.0 mg/yr.

(iv) For a control device monitored in accordance with 40 C.F.R. 

§ 61.354(c), each period of operation monitored during which any of 

the conditions established by 40 C.F.R. § 61.357(d)(7)(iv) occur, as 

applicable to the control device. 

(v) For a cover and closed-vent system monitored in accordance with 40 

C.F.R. § 61.354(g), the Permittee shall submit a report quarterly to 

the Administrator that identifies any period in which the pressure in 

the waste management unit is equal to or greater than atmospheric 

pressure. 

3. The Permittee shall submit annually to the Administrator a report that 

summarizes all inspections required by 40 C.F.R. §§ 61.342 through 61.354 

during which detectable emissions are measured or a problem (such as a broken 

seal, gap or other problem) that could result in benzene emissions is identified, 

including information about the repairs or corrective action taken. 
Veolia ES Technical Solutions, L.L.C. Page 163 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

4.0 GENERAL PART 71 REQUIREMENTS

4.1. DEFINITIONS [40 C.F.R. § 71.2]

Terms and conditions not otherwise defined in this permit have the meaning assigned to 

them in 40 C.F.R. Part 71 unless other regulations or statutes are referenced.

4.2. ANNUAL FEE PAYMENT [40 C.F.R. §§ 71.6(a)(7) and 71.9]

A. The Permittee shall pay an annual permit fee in accordance with the procedures 

outlined below. [40 C.F.R. § 71.9(a)]

B. The Permittee shall submit an annual report of its actual emissions for the preceding 

calendar year, a fee calculation work sheet (based on the report), and full payment of 

the annual fee each year. The Permittee shall submit the annual report and pay the 

annual permit fee each year on or before the anniversary date (3 months from the 

issuance of this permit) of its initial fee calculation work sheet.

The Permittee shall submit the annual report to:

Air Permits Section (AR-18J)

Air and Radiation Division

EPA Region 5

77 West Jackson Boulevard

Chicago, Illinois 60604

C. The fee payment shall be in United States currency and shall be paid by money 

order, bank draft, certified check, corporate check, or electronic funds transfer 

payable to the order of the U.S. Environmental Protection Agency.

D. The Permittee shall send fee payment and a completed fee filing form to: 

U.S. Environmental Protection Agency

FOIA and Miscellaneous Payments, 

Cincinnati Finance Center,

P.O. Box 979078, 

St. Louis, MO 63197-9000

E. The Permittee shall send an updated fee calculation worksheet form and a photocopy 

of each fee payment check (or other confirmation of actual fee paid) submitted 

annually by the same deadline as required for fee payment to the address listed in 

condition 4.8(B) of this permit. (The Permittee should note that an annual emissions 

report, required at the same time as the fee calculation worksheet by 40 C.F.R.

§ 71.9(h), has been incorporated into the fee calculation worksheet form as a 

convenience.)
Veolia ES Technical Solutions, L.L.C. Page 164 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

F. Basis for calculating annual fee:

1. The annual emissions fee shall be calculated by multiplying the total tons of 

actual emissions of all regulated pollutants (for fee calculation) emitted from the 

source, including fugitive emissions by the presumptive emissions fee (in 

dollars/ton) in effect at the time of calculation.

(a) “Actual emissions” means the actual rate of emissions in tons per year of 

any “regulated pollutant (for fee calculation)” emitted from a Part 71 

source over the preceding calendar year. Actual emissions shall be 

calculated using each emissions unit’s actual operating hours, production 

rates, in-place control equipment, and types of materials processed, stored, 

or combusted during the preceding calendar year. [40 C.F.R. § 71.9(c)(6)]

(b) Actual emissions shall be computed using methods required by the permit 

for determining compliance, such as monitoring or source testing data. 

[40 C.F.R. § 71.9(h)(3)]

(c) If actual emissions cannot be determined using the compliance methods in 

the permit, the Permittee shall use other federally recognized procedures.

[40 C.F.R. § 71.9(e)(2)]

(d) The term “regulated pollutant (for fee calculation)” is defined in 40 C.F.R.

§ 71.2.

(e) Prior to the start of each calendar year, EPA will revise for inflation rate 

and make available the presumptive fee amount.

2. The Permittee shall exclude the following emissions from the calculation of fees:

(a) The amount of actual emissions of each regulated pollutant (for fee 

calculation) that the source emits in excess of 4,000 tons per year;

[40 C.F.R. § 71.9(c)(5)(I)]

(b) Actual emissions of any regulated pollutant (for fee calculation) already 

included in the fee calculation; [40 C.F.R. § 71.9(c)(5)(ii)] and

(c) The quantity of actual emissions (for fee calculation) of insignificant 

activities [defined in 40 C.F.R. § 71.5(c)(11)(i)] or of insignificant 

emissions levels from emissions units identified in the Permittee’s 

application [pursuant to 40 C.F.R. § 71.5(c)(11)(ii)]. [40 C.F.R.

§ 71.9(c)(5)(iii)]
Veolia ES Technical Solutions, L.L.C. Page 165 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

G. Fee calculation worksheets shall be certified as to truth, accuracy, and completeness 

by a responsible official in accordance with condition 4.8(A). (The Permittee should 

note that the fee calculation worksheet incorporates a section to help meet this 

responsibility.)

H. The Permittee shall retain fee calculation worksheets and other emissions-related 

data used to determine fee payment for 5 years following submittal of fee payment. 

Emission-related data include, for example, emissions-related forms provided by the 

EPA and used by the Permittee for fee calculation purposes, emissions-related 

spreadsheets, and emissions-related data, such as records of emissions monitoring 

data and related support information required to be kept in accordance with 40 

C.F.R. § 71.6(a)(3)(ii). [40 C.F.R. § 71.9(I)]

I. Failure of the Permittee to pay fees in a timely manner shall subject the Permittee to 

assessment of penalties and interest in accordance with 40 C.F.R. § 71.9(l). 

J. When notified by the EPA of underpayment of fees, the Permittee shall remit full 

payment within 30 days of receipt of notification. [40 C.F.R. § 71.9(j)(1) and (2)]

K. A Permittee who believes that the EPA assessed fee is in error and who wishes to 

challenge such fee shall provide a written explanation of the alleged error to the EPA 

along with full payment of the EPA assessed fee. [40 C.F.R. § 71.9(j)(3)]

4.3. COMPLIANCE STATEMENT [40 C.F.R. § 71.6(a)(6)]

(A) The Permittee must comply with all conditions of this Part 71 permit. Any 

noncompliance with this permit constitutes a violation of the CAA and is grounds 

for: [40 C.F.R. § 71.6(a)(6)(I)]

1. Enforcement action;

2. Permit termination, revocation and reissuance, or modification; or 

3. Denial of a permit renewal application.

(B) It shall not be a defense for a Permittee in an enforcement action that it would have 

been necessary to halt or reduce the permitted activity in order to maintain 

compliance with the conditions of this permit. [40 C.F.R. § 71.6(a)(6)(ii)]

4.4. COMPLIANCE CERTIFICATIONS [40 C.F.R. § 71.6(c)(5)]

The Permittee shall submit to EPA a certification of compliance with all permit terms and 

conditions, including emission limitations, standards, or work practices, each calendar 

year for the reporting period from January 1 to December 31, except the first reporting 

period shall begin on the effective date of this permit and end on December 31. All 
Veolia ES Technical Solutions, L.L.C. Page 166 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

reports shall be submitted to the EPA and shall be postmarked by the 30th day following 

the end of the reporting period. The compliance certification shall be certified as to truth, 

accuracy, and completeness by a responsible official in accordance with condition 4.8(A) 

of this permit. The certification shall include the following:

(A) Identification of each permit term or condition that is the basis of the certification;

(B) Identification of the method(s) or other means used for determining the compliance 

status of each term and condition during the certification period, and whether such 

methods or other means provide continuous or intermittent data. If necessary, the 

Permittee also shall identify any other material information that must be included in 

the certification to comply with section 113(c)(2) of the CAA, which prohibits 

knowingly making a false certification or omitting material information;

(C) The compliance status of each term and condition of the permit, including whether 

monitoring data is continuous and whether that data or any other credible evidence 

shows the compliance is continuous. The certification shall identify each deviation 

and take it into account in the compliance certification; and

(D) A statement indicating the compliance status of the source with any applicable 

enhanced monitoring and compliance certification requirements of the CAA.

4.5. SCHEDULE OF COMPLIANCE [40 C.F.R. §§ 71.6(c)(3) and 71.5(c)(8)(iii)]

(A) The Permittee will comply with all requirements of the permit.

(B) For applicable requirements that will become effective during the permit term, the 

Permittee shall timely comply with such requirements.

4.6. DUTY TO PROVIDE AND SUPPLEMENT INFORMATION 

[40 C.F.R. §§ 71.6(a)(6)(v) and 71.5(b)]

(A) The Permittee shall furnish to the EPA, within a reasonable time, any information 

that the EPA may request in writing to determine whether cause exists for 

modifying, revoking and reissuing, or terminating this permit or to determine 

compliance with this permit. Upon request, the Permittee shall also furnish to EPA 

copies of records that are required to be kept pursuant to the terms of this permit, 

including information claimed to be confidential. Information claimed to be 

confidential should be accompanied by a claim of confidentiality according to the 

provisions of 40 C.F.R. Part 2, Subpart B.

(B) The Permittee, upon becoming aware that any relevant facts were omitted or 

incorrect information was submitted in the permit application, shall promptly submit 

such supplementary facts or corrected information. The Permittee shall also provide 
Veolia ES Technical Solutions, L.L.C. Page 167 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

additional information as necessary to address any requirements that become 

applicable to the facility after this permit is issued.

4.7. ENFORCEABILITY [40 C.F.R. § 71.6(b)]

All terms and conditions in this permit, including any provisions designated to limit the 

source’s potential to emit, are enforceable by the EPA and citizens in accordance with the 

CAA.

4.8. SUBMISSIONS [40 C.F.R. §§ 71.5(d), 71.6 and 71.9]

(A) A responsible official of the Permittee shall certify as to the truth, accuracy, and 

completeness of any document required to be submitted by this permit. Such 

certifications shall state that based on information and belief formed after reasonable 

inquiry, the statements and information in the document are true, accurate, and 

complete. Except as otherwise noted, the Permittee shall submit all documents 

required to be submitted by this permit to:

Air Enforcement and Compliance Assurance Branch (AE-17J)

Air and Radiation Division

EPA Region 5

77 West Jackson Boulevard

Chicago, Illinois 60604

(B) The Permittee shall submit permit applications, applications for permit amendments, 

and other applicable permit information, which includes but is not limited to 

installation of control equipment, replacement of an emissions unit, fee calculation 

worksheets, and applications for renewals and permit modifications, to:

Air Permits Section

Air Programs Branch (AR-18J)

EPA Region 5

77 West Jackson Boulevard

Chicago, Illinois 60604

4.9. SEVERABILITY CLAUSE [40 C.F.R. § 71.6(a)(5)]

The provisions of this permit are severable, and in the event of any challenge to any 

portion of this permit, or if any portion is held invalid, the remaining permit conditions 

shall remain valid and in force.

4.10. PERMIT ACTIONS [40 C.F.R. § 71.6(a)(6)(iii)]

The EPA may modify, revoke, reopen and reissue this permit, or terminate it for cause. 

The filing of a request by the Permittee for a permit modification, revocation and 
Veolia ES Technical Solutions, L.L.C. Page 168 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

reissuance, or termination, or of a notification of planned changes or anticipated 

noncompliance does not stay any permit condition.

4.11. ADMINISTRATIVE PERMIT AMENDMENTS [40 C.F.R. § 71.7(d)]

The Permittee may request the use of administrative permit amendment procedures for a 

permit revision in accordance with 40 C.F.R. § 71.7(d).

4.12. MINOR PERMIT MODIFICATIONS [40 C.F.R. § 71.7(e)(1)]

The Permittee may request the use of minor permit modification procedures for those 

modifications that meet the requirements contained in 40 C.F.R. § 71.7(e)(1).

4.13. SIGNIFICANT PERMIT MODIFICATIONS [40 C.F.R. § 71.7(e)(3)]

The Permittee must request the use of significant permit modification procedures for 

those modifications that meet the requirements contained in 40 C.F.R. § 71.7(e)(3).

4.14. REOPENING FOR CAUSE [40 C.F.R. § 71.7(f)]

The EPA shall reopen and revise the permit prior to expiration under any of the following 

circumstances:

(A) Additional applicable requirements under the CAA become applicable to this source 

if the remaining permit term is 3 or more years. 

(B) The EPA determines that the permit contains a material mistake or that inaccurate 

statements were made in establishing the emissions standards or other terms or 

conditions of the permit.

(C) The EPA determines that the permit must be revised or revoked to assure 

compliance with the applicable requirements.

4.15. PROPERTY RIGHTS [40 C.F.R. § 71.6(a)(6)(iv)]

This permit does not convey any property rights of any sort, or any exclusive privilege.

4.16. INSPECTION AND ENTRY [40 C.F.R. § 71.6(c)(2)]

Upon presentation of credentials and other documents as may be required by law, the 

Permittee shall allow EPA or an authorized representative to perform the following as 

authorized by the CAA:
Veolia ES Technical Solutions, L.L.C. Page 169 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

(A) Enter upon the Permittee’s premises where the Part 71 source is located or 

emissions-related activity is conducted, or where records are kept under the 

conditions of the permit;

(B) Have access to and copy, at reasonable times, any records that must be kept under 

the conditions of the permit;

(C) Inspect at reasonable times any facilities, equipment (including monitoring and air 

pollution control equipment), practices, or operations regulated or required under the 

permit; and

(D) Sample or monitor at reasonable times substances or parameters for the purpose of 

assuring compliance with the permit or applicable requirements.

4.17. EMERGENCY PROVISIONS [40 C.F.R. § 71.6(g)]

(A) In addition to any emergency or upset provision contained in any applicable 

requirement, the Permittee may seek to establish that noncompliance with a 

technology-based emission limitation under this permit was due to an emergency. 

To do so, the Permittee shall demonstrate the affirmative defense of emergency 

through properly signed, contemporaneous operating logs, or other relevant evidence 

that:

1. An emergency occurred and that the Permittee can identify the cause(s) of the 

emergency;

2. The permitted facility was at the time being properly operated;

3. During the period of the emergency the Permittee took all reasonable steps to 

minimize levels of emissions that exceeded the emissions standards, or other 

requirements in this permit; and

4. The Permittee submitted notice of the emergency to EPA within 2 working days 

of the time when emission limitations were exceeded due to the emergency. This 

notice must contain a description of the emergency, any steps taken to mitigate 

emissions, and corrective actions taken. This notice fulfills the requirements of 

condition 3.2(B) of this permit, concerning prompt notification of deviations.

(B) In any enforcement proceeding, the Permittee attempting to establish the occurrence 

of an emergency has the burden of proof.

(C) An “emergency” means any situation arising from sudden and reasonably 

unforeseeable events beyond the control of the source, including acts of God, which 

situation requires immediate corrective action to restore normal operation, and that 

causes the source to exceed a technology-based emission limitation under the permit 
Veolia ES Technical Solutions, L.L.C. Page 170 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

due to unavoidable increases in emissions attributable to the emergency. An 

emergency shall not include noncompliance to the extent caused by improperly 

designed equipment, lack of preventive maintenance, careless or improper operation, 

or operator error.

4.18. OFF PERMIT CHANGES [40 C.F.R. § 71.6(a)(12)]

The Permittee is allowed to make certain changes without a permit revision, provided that 

the following requirements are met:

(A) Each change is not addressed or prohibited by this permit;

(B) Each change must comply with all applicable requirements and may not violate any 

existing permit term or condition;

(C) Changes under this provision may not include changes subject to any requirement of 

40 C.F.R. Parts 72 through 78 or modifications under any provision of Title I of the 

CAA;

(D) The Permittee must provide contemporaneous written notice to EPA of each change, 

except for changes that qualify as insignificant activities under 40 C.F.R.

§ 71.5(c)(11). The written notice must describe each change, the date of the change, 

any change in emissions, pollutants emitted, and any applicable requirements that 

would apply as a result of the change;

(E) The permit shield does not apply to changes made under this provision; and

(F) The Permittee must keep a record describing all changes that result in emissions of 

any regulated air pollutant subject to any applicable requirement not otherwise 

regulated under this permit, and the emissions resulting from those changes.

4.19. PERMIT EXPIRATION AND RENEWAL [40 C.F.R. §§ 71.5(a)(1)(iii), 71.6(a)(11), 

71.7(b), 71.7(c)(1)(i) and (ii), 71.8(d)]

(A) Except as provided in conditions 4.19(C) and (D), below, this permit shall expire 

five years from the effective date.

(B) Expiration of this permit terminates the Permittee’s right to operate unless the 

Permittee has submitted a timely and complete permit renewal application to the 

permitting authority at least 6 calendar months, but not more than 18 calendar 

months, prior to the date of expiration of this permit.

(C) If the Permittee submits a timely and complete permit application for renewal, 

consistent with 40 C.F.R. § 71.5(a)(1) and (2) and condition 4.19(B), above, but the 

permitting authority fails to issue or deny the renewal permit, then this permit shall 
Veolia ES Technical Solutions, L.L.C. Page 171 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

not expire until the permitting authority has issued or denied a renewal permit. Any 

permit shield granted under condition 4.21 of this permit may be extended during the 

period that the permitting authority fails to act on the renewal application.

(D) If the Permittee has submitted a timely and complete application for renewal

consistent with 40 C.F.R. § 71.5(a)(1) and (2) and condition 4.19(B), above, the 

Permittee’s failure to have a Part 71 permit is not a violation of Part 71 or the CAA 

until the permitting authority takes final action on the permit renewal application. 

This protection shall cease to apply if, subsequent to the completeness 

determination, the Permittee fails to submit any additional information identified as 

being needed to process the application by the deadline specified in writing by the 

permitting authority.

(E) Renewal of this permit is subject to the same procedural requirements that apply to 

initial permit issuance, including those for public participation and affected state and 

tribal review.

(F) The application for renewal shall include the current permit number, description of 

permit revisions and off-permit changes that occurred during the permit term, any 

applicable requirements that were promulgated and not incorporated into the permit 

during the permit term, and other information required by the application form.

4.20. OPERATIONAL FLEXIBILITY [40 C.F.R. § 71.6(a)(13)]

The Permittee may make changes within the permitted facility without a permit revision, 

including the addition of a new generator or replacement of an existing generator, 

provided the following conditions are met:

(A) The changes are not modifications under any provision of Title I of the CAA; 

(B) The changes do not exceed the emissions allowed under this permit (whether 

expressed therein as a rate of emissions or in terms of total emissions); and

(C) The Permittee notifies the EPA at least 7 days in advance of the proposed changes. 

The written notification shall include a brief description of the change within the 

permitted facility, the date on which the change will occur, any change in emissions, 

and any permit term or condition that is no longer applicable as a result of the 

change.

4.21. PERMIT SHIELD [40 C.F.R. § 71.6(f)]

(A) Except as noted in conditions 4.21(A)(1) and (2), below, compliance with the 

conditions of this permit shall be deemed compliance, as of the date of permit 

issuance, with any applicable requirements that are specifically identified and 
Veolia ES Technical Solutions, L.L.C. Page 172 of 172

Permit No.: V-IL-1716300103-2014-10

Issuance Date: DRAFT

Expiration Date: DRAFT

included in this permit or that are specifically identified in this permit as not 

applying to the facility.

1. Compliance with this permit shall not be deemed to be compliance with any 

requirement of 40 C.F.R. Part 63, Subpart EEE, (including the appendix and any 

requirement of the General Provisions (40 C.F.R. Part 63, Subpart A) identified 

in Table 1 as applicable to 40 C.F.R. Part 63, Subpart EEE).

2. The permit shield shall not apply, and compliance with this permit shall not be 

deemed to be compliance with, Parts C and D of Title I of the CAA, or any 

requirements of the Illinois SIP, or federal or state regulations that govern the 

permitting of major modifications to sources of air emissions.

(B) Nothing in this permit shall alter or affect the following:

1. The liability of the Permittee for any violation of applicable requirements prior to 

or at the time of permit issuance;

2. The ability of EPA to obtain information under Section 114 of the CAA; 

3. The applicable requirements of the acid rain program, consistent with section 

408(a) of the CAA; or

4. The provisions of section 303 of the CAA (emergency orders), including the 

authority of the Administrator under that section. 

4.22. CREDIBLE EVIDENCE [62 Fed. Reg. 8314 (February 24, 1997); 42 U.S.C. § 7413]

Notwithstanding the conditions of this permit specifying compliance practices for 

applicable requirements, any person (including the Permittee) may also use other credible 

evidence to establish compliance or noncompliance with applicable requirements.