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Veolia ES Technical Solutions Air Permit

Sauget, Illinois ______ 2014

Air Permit Renewal Planned 

for Hazardous Waste Incinerator

Public hearing scheduled

EPA will hold a public hearing from 

3 to 7 p.m., ________, at:

SIU-Edwardsville 

East St. Louis Higher Education 

Campus

Distance Learning Lab, Room 2083 

Building B

601 James R. Thompson Blvd.

If you need special accommodations 

to attend the hearing, contact 

Andrea Morgan at 

morgan.andrea@epa.gov 

by ________________.

How to comment

You will have an opportunity to 

make oral comments at the public 

hearing. You may also send EPA 

written comments on Veolia’s 

permit renewal from _____ to 

______. There are several ways to

comment (see Page 4 for details).

For more information

You may review the draft permit

and a document called a “Statement 

of Basis,” which details reasons for 

the permit changes. Visit one of 

these libraries:

Central Library, 1301 Olive St, 

St. Louis.

East St. Louis Library, 5300 State 

St., East St. Louis.

Cahokia Public Library, 140 

Cahokia Park Drive, East St Louis.

Facility tours available

Veolia is offering tours of its Sauget

facility. To arrange a tour, contact 

Doug Harris, 618-271-2804.

The U.S. Environmental Protection Agency plans to renew a Clean Air Act 

Title V operating permit for Veolia ES Technical Solutions LLC. The permit 

is for a facility at 7 Mobile Ave. that stores and burns hazardous waste. EPA 

is accepting public comments on the renewal (see box, left).

In addition to emissions limits, work practice requirements, and monitoring 

and recordkeeping requirements found in Veolia’s current permit, the 

renewed permit would incorporate some changes, including:

 Limits on how much arsenic, lead, mercury and other metals Veolia 

can put into its incinerators – called the “feedrate limits” or “OPLs”

– based on results of Veolia’s performance tests in October 2013.

 Enhanced waste analysis procedures to ensure compliance with the

metal feedrate limits.

 Temporary (12 months) installation and operation of a special 

emissions monitoring system on each incinerator to ensure the 

feedrate limits are adequate to assure compliance with applicable 

emissions limits.

 New requirements for emergency generators.

Veolia will continue operating under its current permit until EPA either 

renews the permit or denies the company’s application. 

Background

The Clean Air Act requires an operating permit – known as a Title V permit 

– for facilities that emit large amounts of air pollution. This permit details the 

amount of pollution the facility can emit and what it must do to control the

pollution. A Title V permit is valid for five years and may be renewed in 

five-year increments.

EPA issued Veolia’s initial permit Sept. 12, 2008. In January 2013, EPA 

began a process to revise the 2008 permit, but later chose to simply 

incorporate the proposed changes into Veolia’s permit renewal.

Pollutants affected by the permit

Veolia’s Sauget facility emits a variety of pollutants regulated by EPA,

including:

 Carbon monoxide.

 Nitrogen oxides.

 Sulfur dioxide.

 Fine particles, known as particulate matter.

 Volatile organic compounds.

 Mercury.

 Semi-volatile metals such as cadmium and lead.

 Low-volatile metals such as arsenic, beryllium and chromium. 

 Dioxins and furans.

 Hydrogen chloride.
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Burning hazardous waste

Hazardous waste – which is toxic, flammable or 

corrosive and can react with other materials – can be 

produced by businesses or manufacturing operations. 

Burning hazardous waste, usually in specially designed 

incinerators, boilers and industrial furnaces, is one way 

to safely manage it. 

Burning reduces waste volume by converting solids and 

liquids to ash while destroying toxic organic 

compounds. Disposing of the ash in a landfill is safer 

and more efficient than disposal of untreated hazardous 

waste. The ash from hazardous waste combustion must 

be tested. If it is still hazardous, it must be treated 

before it is disposed of in a landfill. However, the 

incineration of waste can result in emissions of 

hazardous air pollutants into the air. 

Veolia has three hazardous waste combustors: #2, #3, 

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

hazardous waste in gas, liquid and solid forms. 

Veolia may store liquid waste in a tank farm prior to 

burning it. Gases occasionally escape from the tanks, 

and carbon adsorption units are attached to each tank to 

help control these emissions. 

Veolia stores bulk solid wastes 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. 

Veolia burns gaseous wastes in Combustor #2 only.

Each combustor has a primary and secondary 

combustion chamber that includes natural gas-fired

auxiliary burners used during startup, shutdown, and 

malfunctions, and for additional heat input. The 

combustors are also connected to spray dryer absorbers 

and a baghouse, which help control air pollution. 

Combustor #4 also has a tempering chamber and 

activated carbon injection to further help control air 

pollution. Veolia is required to monitor continually for 

carbon monoxide and hydrogen chloride emissions.

The combustors are augmented by a lime handling 

system and an ash handling system. The lime handling 

system feeds lime to 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. 

Changes to the permit

A Title V permit is an enforceable compilation of all 

operating terms, conditions and limitations that apply to

an emission source. It is meant to improve compliance 

by making clear the Clean Air Act requirements with 

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

principles. 
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which the facility must comply. The permitting 

authority ensures requirements that apply to the facility 

are included and that there is enough monitoring and 

recordkeeping required to verify that the source is in 

compliance with permit requirements. EPA, the Title V 

permitting authority for the Sauget facility, is proposing 

to make changes to and renew Veolia’s existing permit.

Proposed changes to Veolia’s monitoring requirements

will verify the facility is complying with the feedrate 

limits and that the limits will assure compliance with 

the Clean Air Act (see “Monitoring,” below). 

EPA also removed some requirements that no longer 

apply. For example, an emission limit previously 

included in the permit to meet federal standards for the 

boiler is no longer applicable because EPA has 

promulgated new federal standards that apply to the 

boiler. EPA is therefore replacing that emissions limit 

with the new federal standards for boilers. 

Setting the limits

Veolia’s permit includes emission limits established by 

the following regulations or permits:

 National Emission Standards for Hazardous Air 

Pollutants, or NESHAPs, which are standards

promulgated under Section 112 of the Clean Air 

Act and promulgated under 40 C.F.R. Parts 61 and 

63. Veolia is subject to the NESHAP for hazardous 

waste combustors, 40 C.F.R. Part 63, Subpart EEE.

 New Source Performance Standards, which are 

emission standards promulgated under the authority 

of Section 111 of the Clean Air Act and 

promulgated under 40 C.F.R. Part 60.

 The Illinois State Implementation Plan, state 

regulations found at Title 35 of the Illinois 

Administrative Code, which are approved and 

made federally enforceable by EPA and codified at

40 C.F.R. § 52.720.

 Construction and operating permits issued by the 

Illinois EPA.

Most requirements in the current permit will not change

in the renewal. However, EPA is adding feedrate limits 

for certain heavy metals and updating other operating 

parameter limits as required by federal regulations for 

hazardous waste combustors. These limits were 

established using the results of Veolia’s October 2013 

comprehensive performance tests, and Veolia already is 

required to comply with the limits under the NESHAP 

for hazardous waste combustors, the “HWC MACT.” 

Monitoring

In the proposed revisions to the Title V permit, EPA is 

augmenting Veolia’s feedstream analysis procedures to 

ensure compliance with the metal feedrate limits. The 

proposed enhanced waste analysis procedures would 

require Veolia to:

 Sample and analyze each feedstream accepted for 

incineration unless specifically exempted.

 Sample and analyze all batched, treated, blended, 

mixed or otherwise altered waste for mercury and 

other metals in its final form as feed for incineration 

prior to incineration, or perform a mass balance 

calculation to determine concentrations in the final 

batched, treated, blended, mixed or otherwise altered 

waste.

 Not batch, treat, blend, mix or otherwise alter 

feedstreams which are exempt from sampling unless 

Veolia samples and analyzes the otherwise exempt 

feedstream.

 Document the concentration of mercury, LVM and 

SVM in any fuel other than natural gas, including 

used oil, diesel and alternative fuels fed into the 

incinerators by either obtaining analytical results 

from each fuel supplier or conducting representative 

sampling of each fuel supply and analyzing such 

samples using appropriate quality assurance/quality 

control procedures and test methods. Veolia would 

follow this procedure at least once per year for each 

fuel supply.

 Document concentrations that fall below the 

detection limit in non-exempt feedstreams as equal

to the detection limit.

 Maintain records of all required feedstream analyses 

for five years.

EPA also proposes requiring Veolia to temporarily 

install and operate a continuous emissions monitoring 

system, or CEMS, on each of its three combustion units. 

Veolia will operate the CEMSs as parametric monitoring 

systems to assess whether the operating parameter limits 

for specific metals are adequate to ensure compliance 

with federal rules. As parametric monitoring systems, 

the CEMSs will verify the adequacy of the feedrate 

limits. The systems will test the air emitted during 

incineration to determine the amount of mercury, semivolatile metals, low-volatile metals and other metals

emitted, and report results approximately once every 15

minutes. The test results will help Veolia and EPA 

ensure the feedrate limits are adequate to ensure that the 

facility can comply with the HWC MACT emissions 

limits for mercury, semi-volatile metals and low-volatile 

metals when complying with its metals feedrate limits. 

EPA will require Veolia to operate the CEMSs on a 

temporary basis until EPA has enough information to 

determine if the proposed feedrate limits are adequate to 

ensure Veolia complies with the Clean Air Act. 

Once EPA has collected sufficient information, EPA 

will no longer require Veolia to use multi-metal CEMSs.
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Public comments encouraged

The public comment period expires on <DATE>. All written comments must be postmarked or emailed no later 

than ____________. EPA will consider all comments before making a final decision on the permit renewal. If you 

submit a written comment, 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 EPA’s final decision and its 

responses to comments. 

There are several ways to submit written comments:

By visiting www.regulations.gov – put Docket ID No. EPA-R05-OAR-2014-0280 in the search box.

By mail to: By email to:

George Czerniak John Mooney

U.S. EPA Region 5 (A-18J) mooney.john@epa.gov

77 W. Jackson Blvd.

Chicago, IL 60604

Public hearing details

At the ________ public hearing you may submit a written statement or make an oral statement. There will be a 

signup sheet at the entrance for those who wish to present oral testimony. Presentations will be given on a firstcome-first-served basis. A court reporter will record all oral statements. 

Each spea ker will be limited to five to 10 minutes depending on the number of presenters. The EPA representative 

may ask clarifying questions during the oral presentations but will not respond to the comments at that time.