From: 

To: 

Todd D. Ramaly, United States Environmental Protection Agency -~-??-fLFile 

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.)." 

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9. Veolia Risk Report, p. 21, Beryllium, 181 sentence: The first sentence appearing 

under the heading "Beryllium" should refer to "92 J..tg/dscm" not "97 J..tg/dscm." 

10. Veolia Risk Report, p. 21, Arsenic, 1st sentence: The first sentence appearing 

under the heading "Arsenic" should refer to "92 J..tg/dscm" not "97 J..tg/dscm."