Apri114, 2015 

Mr. Robert Kaplan 

Deputy Regional Administrator 

US Environmental Protection Agency, Region 5 

77 W Jackson Blvd (Mail Code R-19J) 

Chicago, IL 60604-3507 

Dear Mr. Kaplan: 

VE 

Thank you for the opportunity to meet last week and review our cunent pennitting status. We appreciate both 

you and George allowing us to directly voice our concerns. 

As discussed, Veolia is the only commercial HWC in Region 5 that has not failed a CPT or had final Agency 

action taken against it. Our concern is that despite this fact, USEPA is attempting to require Veolia to install 

unverifiable (as compared to method 29) monitoring equipment at a great expense. USEPA's actions place 

Veolia at a competitive disadvantage to its two primary competitors, both of whom are located in Ohio (i.e. 

also in Region 5) and, unlike Veolia, have failed CPTs and had final Agency action taken against them. 

George stated during our meeting that the Agency is requiring Veolia to install such expensive, experimental 

monitoring equipment because the Agency believes Veolia services more small, "one off' type customers than 

either of Veolia's Ohio competitors. The Agency's belief does not justify its actions against Veolia and is, in 

fact, inaccurate. 

A Feedstream Analysis Plan ("FAP") is designed to accurately characterize the nature of incoming waste 

streams fed to the incinerators. The Agency's regulations contemplate a FAP being equally applied to all 

waste, regardless of whether the waste is generated by a large quantity generator ("LQ") or a "one off' type 

customer. Veolia has offered to enhance its existing FAP in order to provide the Agency with the assurances 

that it seeks or adopt either ofVeolia's Ohio competitor's FAPs which the Agency apparently believes provide 

the assurances the Agency seeks. 

Further, the Agency's assertion that Veolia's customer base is in some fashion fundamentally different than 

either of Veolia's Ohio competitors is inaccurate. Based on publicly available data and as reflected in the table 

below, all three Region 5 commercial HWC's service the same type of industries and, in many cases, the 

identical customers based on competitive bidding results: 

#7 Mobile Avenue, Sauget, IL 62201 

(618) 271-2804 

www.veolia.com 
VE 

Tons Incinerated Number of Tons' Tons Non- %Small 

LQ Received Haz & Small '"one off' 

Customers from LQ Qty Gen 

Generators "one off' 

2011 2012 2013 2013 2013 2013 

Veolia 33K 34K 444 19K 15 44.1% 

Heritage/WTI 61K 62K 602 33K 29 46.8% 

Ross 741<. 75K 773 32K 43 57.8% 

The information demonstrates Veolia receives and incinerates approximately 50% of the volume of waste that 

each of the Ohio incinerators incinerate. Further, all three commercial HWC's in Region 5 receive 

approximately 50% of their waste from large quantity generators. The remaining 50% for each of the 

incinerators is from non-hazardous/small quantity "one off' generators. Similarly, the number of large 

quantity generators shipping to each ofthe three commercial HWCs relative to each of the incinerator's 

volumes processed again supports the similar nature of each of these businesses. 

In short, the Agency's requirement that Veolia install expensive, experimental monitoring equipment is not 

justified given Veolia's record; the Agency's ability to obtain as much information as needed from ·an 

enhanced F AP; and the similarity of operations between Veolia, where the Agency is requiring the .expensive, 

experimental monitoring equipment, and Veolia's competitors, where the Agency is not requiring such 

equipment. 

US EPA Region 5 should not misuse its unique position of being the primary permitting authority for Veolia 

to force Veolia to install unverified monitoring equipment and force Veolia to pay for improvements to a 

heretofore failed technology that the Agency finds interesting. Rather, Region 5 should abide by the law and 

follow proper rulemaking in its attempt to impose such technology on the regulated community. 

Veolia respectfully requests that the Agency remove the unnecessary requirements for additional unlegislated 

continuous emission monitoring equipment from its Title V draft permit. 

s~:y, ~ 

Doug~ General Manager 

cc: Susan Hedman, Region 5 Administrator 

George Czerniak, Region 5 Director of Air & Radiation Division 

US Senator Dick Durbin- Dr. Jasmine Hunt 

US Congressman Mike Bast- Mark Ratto 

US Congressman John Shimkus- Steve Tomaszewski 

US Congressman Rodney Davis 

US Congressman Jerry Costello (ret) 

1 El Digest 2 EPA Biennial Generation & Management Report 

#7 Mobile Avenue, Sauget, IL 62201 

(618) 271-2804 

www.veolia.com