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Veolia ES Technical Solutions Air Permit

Sauget, Illinois February 2013

U.S. EPA Proposes to Reopen

Title V Air Permit

What can you do?

 Submit written comments

to U.S. EPA regarding the 

draft permit during the 

comment period that runs 

from Jan. 8 to April 1, 

2013. Comments should 

include factual grounds and 

supporting material or 

references.

 Attend the public hearing

on Feb. 19, 2013, at the 

Southern Illinois University 

Edwardsville – East St. 

Louis Higher Education 

Campus, Distance Learning 

Lab, Room 2083, Building 

B, 601 James R. Thompson 

Blvd., East St. Louis, from 3 

p.m. to 7 p.m. See more 

details on the comment 

period and meeting on the 

back page.

 Go on a tour. Veolia will 

be offering facility tours. To 

arrange a tour contact Doug 

Harris or Dennis Warchol at 

618-271-2804.

 Review the statement of 

basis and draft permit.

The statement of basis

provides more information 

and explains the legal and 

factual bases for the permit 

conditions. The draft Title V 

permit includes all of the 

requirements the source is 

legally obligated to follow. 

Only portions of the permit 

that are being changed 

because of the proposed 

action are currently open for 

comment during the 

comment period. See Page 3

for locations where you can 

view these documents.

The U.S. Environmental Protection Agency is proposing to reopen a Clean 

Air Act permit for a hazardous waste combusting facility in southern 

Illinois. U.S. EPA is undertaking this permit action for Veolia ES 

Technical Solutions LLC., 7 Mobile Ave., Sauget, Ill., near St. Louis, to 

modify its Clean Air Act Title V operating permit. The revised permit 

would include “feedrate” limits for certain heavy metals. Feedrate limits 

are the maximum amount of heavy metals Veolia can feed into the 

incinerator combustion unit per hour. The heavy metals include mercury, 

arsenic and lead. The permit also would include additional requirements 

for monitoring the waste incinerated by Veolia at the facility.

U.S. EPA has based the proposed feedrate limits, which comply with 

applicable regulations, on available performance test data. Veolia will 

continue operating the combustors following the requirements of their 

current permit until a final revised permit is issued. U.S. EPA will not 

issue a final permit until after the public has a chance to comment. See the 

left-hand box and read Page 3 for information about the public 

participation process for this proposed permit.

Background

The Clean Air Act requires certain sources that emit large amounts of air 

pollution to obtain an operating permit, also known as a Title V permit, 

after the source has begun to operate. This permit is designed to improve 

compliance by clarifying what facilities must do to control air pollution. 

For this permitting action U.S. EPA is the permitting authority. U.S. EPA

issued the initial Title V permit to Veolia on September 12, 2008. U.S.

EPA is now proposing to reopen the permit to incorporate feedrate limits

and monitoring requirements so that the permit complies with the Clean 

Air Act. Only those portions of the permit that US. EPA is proposing to 

change are open for public comment at this time. The federal Agency

expects the facility to submit an application for a permit renewal in 2013 

and will open the entire permit comment at that time.

Burning hazardous waste

Specially designed incinerators, boilers, and industrial furnaces can burn 

hazardous waste. Hazardous waste – which is toxic, flammable, corrosive 

or reacts with other materials – can be produced by businesses or 

manufacturing operations. Burning hazardous waste is one way to safely 

manage it. Burning reduces waste volume by converting solids and liquids 

to ash while destroying toxic organic compounds. In addition, disposal of 

the ash in a landfill is safer and more efficient than disposal of untreated 

hazardous waste. The ash generated from hazardous waste combustion 

must be tested, and, if found to be hazardous, must be treated for 

remaining toxicity before it is disposed of in a landfill.

Continued on P. 2 ...
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Veolia has three hazardous waste combustors: #2, #3, 

and #4 (#1 was closed in 1992). Veolia receives 

hazardous waste in both liquid and solid forms. Liquid 

waste may be stored in a tank farm prior to being 

burned. Gases occasionally escape from the tanks, and 

carbon adsorption units are attached to each tank to 

help control these emissions. Bulk solid wastes are 

stored in four pits in a building prior to combustion. 

The structure is maintained at negative pressure so 

emissions don’t escape. Before the waste is burned it is 

packaged into more manageable containers and any 

liquids are absorbed.

Each combustor has a primary and secondary 

combustion chamber that includes natural gas-fired 

auxiliary burners used during startup, shutdown, 

malfunctions and for additional heat input. The 

combustors are also connected to spray dryer absorbers 

and a baghouse, which help to control air pollution. 

Combustor #4 also has a tempering chamber and 

activated carbon injection to further help control air 

pollution. Emissions are constantly monitored for 

carbon monoxide and hydrogen chloride.

The combustors are supported by a lime handling 

system and an ash handling system. The lime handling 

system supports the spray dry absorber, as lime is an 

important material in this air pollution control 

technology. The ash handling system ensures that ash 

produced during the combustion process is collected 

and properly disposed of. 

Pollutants affected by the permit

The proposed permit action sets feedrate limits for 

mercury, semi-volatile metals such as cadmium and 

lead, and low-volatile metals such as arsenic, beryllium, 

and chromium. Volatility is a measure of how readily a 

substance changes from a solid or liquid to a vapor. 

These pollutants have known negative health effects. 

U.S. EPA is setting feedrate limits in this action that 

comply with applicable federal regulations. More detail 

about each of these pollutants can be found in the 

statement of basis. Information on how to review the 

statement of basis is found on the last page of this fact 

sheet.

Setting the limits

The heavy metal feedrate limits were established using 

the results of comprehensive performance tests Veolia 

performed in August and September 2008. U.S. EPA is 

proposing to incorporate into Veolia’s Title V permit 

the mercury feedrate limits used by the company during 

its 2008 testing. For the other heavy metals, the federal 

Agency is proposing slightly higher feedrate limits than 

the ones used in the 2008 tests. These higher feedrates 

are allowed under federal regulations.

Monitoring

In the proposed revisions to the Title V permit, Veolia 

will be required to install and operate a multi-metals 

continuous emissions monitoring system (CEMS) on 

one of its combustion units (Unit #3) for at least one 

This diagram shows the combustion process of Unit # 2. The combustion processes of Units 3 and 4 are slightly different, but 

follow similar principals. 
3

year. A multi-metals CEMS tests the air emitted during 

the incineration process to determine the amount of 

mercury, semi-volatile metals and low-volatile metals 

emissions, and reports the results approximately once 

every fifteen minutes. The test results will help U.S. 

EPA ensure the feedrate limits are adequate to protect 

air quality. After a year of running the CEMS, U.S. 

EPA believes we will have enough information to 

determine if the feedrate limits we are currently 

proposing are adequate to ensure that Veolia complies 

with the requirements of the Clean Air Act. Once U.S. 

EPA has collected sufficient data, Veolia will no longer 

be required to use the multi-metals CEMS.

Public participation

You can participate in the decision-making process on 

the permit by submitting comments during the public 

comment period that runs from Jan. 8 to April 1, 2013

or at the Feb. 19 public hearing in East St. Louis (see 

front page box).

All written comments must be postmarked or emailed 

no later than April 1, 2013. U.S. EPA will consider all 

written and oral comments received within the public 

comment period will be considered before making a 

final decision on the proposed action. U.S. EPA will 

consider written statements and supporting information 

submitted during the comment period with the same 

weight as any oral comments and supporting 

information presented at the public hearing. Your 

comments should include your name and address and 

all reasonable references, factual grounds, and 

supporting material. Be sure to note whether you would 

like to receive notification of U.S. EPA’s final decision 

regarding the permit and its responses to comments 

submitted during the public comment period. 

Comments can be submitted:

 Via the Internet at the www.regulations.gov/

website at Docket ID No. U.S. EPA-R05-

OAR-2012-0649 or at

www.epa.gov/region5/newsevents/ and look 

in the “public comment” section.

 Mail to George Czerniak, U.S. EPA, 77 W. 

Jackson Blvd. (A-18J), Chicago, IL 60604.

 Email to John Mooney at 

mooney.john@epa.gov.

At the Feb. 19 public hearing you will be invited to 

present any comments or concerns you have about the 

proposed changes. U.S. EPA is required to consider all 

comments and respond to all relevant comments. A 

signup sheet will be available at the public hearing for 

those who are interested in presenting oral testimony 

and spots will be available to present on a firstcome/first-serve basis. 

Each speaker will be limited to 5 to 10 minutes 

depending on the number of presenters. The U.S. EPA

representative may ask clarifying questions during the 

oral presentations but will not respond to the comments

at that time. If you require translation services or 

special accommodations for the public hearing contact 

U.S. EPA’s Andrea Morgan at 

morgan.andrea@epa.gov by February 5, 2013.

View the documents

The draft permit and another document called a 

statement of basis, which explains the bases for the 

proposed revisions to the permit, can be reviewed at:

 The www.regulations.gov/ website at Docket 

ID No. U.S. EPA-R05-OAR-2012-0649 or at

www.epa.gov/region5/newsevents/ and look 

in the “public comment” section.

 Central Library, 1301 Olive St, St. Louis, MO 

63103.

 East St Louis Library, 5300 State St., East St 

Louis, IL 62203.

 Cahokia Public Library, 140 Cahokia Park 

Drive, East St Louis, IL 62206