I Date: Subject: From: To: ERRATA November

6, 2007 Correction

to U.S. EPA, "Risk Screening and Risk Management Recommendations

for: Veolia ES Technical Solutions, L.L.C., Sauget, Illinois," dated May 2007

_.-...r ;I' Todd D. Ramaly, United States Environmental Protection Agency **-~-??-fL** File The "Risk Screening and Risk Management Recommendations

for Veolia ES Technical Solutions, L.L.C., Sauget, Illinois," dated May 2007, (the "Veolia Risk Report") evaluated whether compliance
by the Veolia facility with the emission standards for certain hazardous constituents established
by 40 CFR Part 63, Subpart EEE (the "Hazardous Waste Combustion- Maximum Achievable Control Technology Rule" or "HWC-MACT Rule") alone would be protective
of human health. The HWC-MACT Rule provides for interim emissions standards (40 CFR

§ 63.1203(a)) and replacement emissions standards (40 CFR

§ 63.1219(a)). Existing hazardous waste incinerators, such as the Veolia facility, currently must comply with the interim emissions standards (40 CFR

§ 63.1206(a)). Unless an extension

is granted, the Veolia facility must comply with the more stringent replacement emissions standards no later than October 14, 2008 (40 CFR

§ 63.1206(a)). The two sets of emissions standards are similar. However, with respect
to emissions limits for semi-volatile metals (lead and cadmium) and low-volatile metals (arsenic, beryllium, and chromium), the replacement emissions standards are more stringent than the interim emissions standards. Specifically,
the interim emission standards prohibit emissions
of semi-volatile metals in excess of 240 micrograms per drystandard cubic meter (ftg/dscm) and low-volatile metals in excess of 97 ftg/dscm while the replacement emissions standards more stringently prohibit emissions
of semi-volatile metals in excess of 230 ftg/dscm and low-volatile metals in excess of 92 ftg/dscm. For the other hazardous constituents evaluated for risk by the Veolia Risk Report, i.e., dioxins and mercury, the interim emissions standards and the replacement emissions standards applicable

to the V eolia facility are identical. The report's conclusions

on risks to human health are based on the calculation
of emission rates from the Veolia facility
at the replacement emissions standards (found in Attachment

A to the report). The replacement emissions standards represent the compliance point for the foreseeable future (as of October 2008) and are an appropriate evaluation
of the risk during the life of the proposed permit. However, the narrative portion of the report erroneously cites to the interim emissions standards.

In each instance where the narrative portion of the report cites to the interim emissions standards, the replacement emissions standards should have been cited. Specific corrections

to the text of the Veolia Risk Report are made below.If the calculation of emission rates from the Veolia facility were to be based on the

interim emissions standards, we estimate that there would be a corresponding

approximate 4-5% increase in the cancer and hazard risks over those stated in the Veolia

Risk Report for low- and semi-volatile metals. The risks from emissions of low- and

semi-volatile metals at the replacement emissions standards as stated in the report were

well below risk levels of concern. An approximate 4-5% increase in cancer and hazard

risks for low and semi-volatile metals would remain well below levels of concern.

Therefore, the ultimate conclusion of the risk assessment for low and semi- metals, i.e.,

no additional limits on low and semi-volatile metals are necessary to protect human

health, would be the same regardless of whether emissions were calculated at the interim

emissions standards or at the replacement emissions standards. Corrections:
1. Veolia Risk Report, p. 8, 4'hpara., 1'' sentence: The Code of Federal Regulations

citation should be-replaced with "(40 CFR § 63.1219(a)(l)(i))."

2. Veolia Risk Report, p.14, Part B,2"ct para., 2nd sentence: The sentence should

read: "The HWC-MACT standard limit for semi-volatile metals is 230 J.lg/dscm."

3. Veolia Risk Report, p, 17, 4th para: The paragraph should be replaced with the

following: "The HWC-MACT Rule metals emission limits for existing hazardous waste incinerators

at 40 CFR § 63.1219(a) are given in the stack gas as follows: Semi-volatile Metals -lead and cadmium (Pb and Cd): 230 J.lg/dscm, combined

emissions, corrected to 7 % oxygen.

Low Volatility Metals- arsenic, beryllium, and chromium (As, Be and Cr+6):

92 J.lg/dscm, combined emissions, corrected to 7 % oxygen.

Mercury (Hg): 130 J.lg/dscm corrected to 7 percent oxygen."

4. Veolia Risk Report, p. 18, 1'' full para;, 1'' sentence. The parenthetical in this

sentence should be rephiced with the following: "(e.g., Pb at 230 J.lg/dscm; Cd at

230 J.lg/dscm, etc.)."

5. Veolia Risk Report, p. 19, last sentence: This sentence should be replaced with

the following: "In addition, because new mercury emission limits became

applicable to the Veolia facility, this screening assessment now uses mercury

emissions at the new MACT-imposed emission limit as its starting point."

6. Veolia Risk Report, p. 20, Lead: The sentence appearing under the heading

"Lead" should refer to "230 J.lg/dscm" not "240 J.lg/dscm."7.VeoliaRiskRepoJ,p.20,Cadmium,1stsentence:Thefirstsentenceappearingundertheheading"Cadmium"shouldreferto"230J..tg/dscm"not"240J..tg/dscm."8.VeoliaRiskReport,p.20,HexavalentChromium,1"sentence:Thefirstsentenceappearingundertheheading"HexavalentChromium"shouldreferto"92J..tg/dscm"not"97J..tg/dscm."9.VeoliaRiskReport,p.21,Beryllium,181sentence:Thefirstsentenceappearingundertheheading"Beryllium"shouldreferto"92J..tg/dscm"not"97J..tg/dscm."10.VeoliaRiskReport,p.21,Arsenic,1stsentence:Thefirstsentenceappearingundertheheading"Arsenic"shouldreferto"92J..tg/dscm"not"97J..tg/dscm."