VES 001847.pdf 
, PV LL ) Pall Corporation Xact' M O Monitoring System 

Hea\ j Continuous Emissions 

Monitoring System (CEMS) 

Description 

Pall's Xact 640 system uses reel-to-reel (RTR) filter tape 

sampling and non-destructive X-ray fluorescence (XRF) 

analysis to monitor stack HAP metal emissions. An 

isokinetic sub-sample of stack gas is taken from the 

stilling chamber and drawn through a chemically-reactive 

filter tape. Vapor phase metals, including mercury (Hg), 

are deposited along with the particulate matter (PM) on 

the filter tape. The deposit is automatically advanced 

and analyzed by XRF for selected metals as the next 

sample is being collected. Sampling and analysis are 

performed continuously and simultaneously, except 

during advancement of the tape (-20 sec) and during 

daily automated quality assurance checks. 

In 2007, through its Clean Air Excellence Award, the 

EPA recognized the Xact 640 CEM S as an outstanding 

achievement in innovative clean air technology. The EPA 

also approved the Xact 640 CEM S as an alternative 

method2 for periodic Method 29 testing and feed stream 

analysis, as well as for monitoring emissions during plant 

operation. 

Features 

• Automatic quality assurance, alarms, and control 

features 

• Gas phase calibration not required 

• Identification and measurement of as many as 23 

elements simultaneously (refer to the periodic table on 

the Elements Supported page of this data sheet) 

• Internal calibration check incorporated with every sample 

analyzed 

• Proven RTR/XRF technology demonstrated on the 

ocean floor, Mars, and in thousands of beta attenuation 

monitors 

• Daily, automatic upscale, blank, and flow checks 

• Recognized by the EPA as an innovative clean air 

technology (Clean Air Excellence Award, 2007) 

• Sampling, analysis, and near-real-time reporting 

(every 15, 30, 60 and 120 minutes) 

Benefits 

• Single monitor platform for Hg and HAP metals monitor 

compliance 

• No PM monitor needed to comply with MATS 

• May be used to meet 40 CFR Part 60 and 63 regulations 

• Measures total mercury in ug/dscm 

Xact 640 Metals Monitor 

• Multi-metal analysis reduces expenses, time, and 

resources 

• Non-destructive analysis allows for sample archiving 

• Sensitive and reliable (ng/m3 to ug/m3 range) 

Request a quote for your customized Xact 640 

monitoring system. 

Applications 

The Xact 640 monitoring system can simultaneously 

identify and measure multiple metals in flue gas to 

provide data for use in the following applications. 

• Hg CEM S 

• HAP metals CEM S 

• Baselining a new process 

• Optimization of emission controls 

• Permitting 

• Regulatory compliance 

• Risk management 

^ Xact is a trademark of Cooper Environmental Services LLC. 

2 Approved by way of alternative monitoring petition. 

Filtration. Separation. Solution.TM 
Specifications 

Measurement method Based on EPA Method 10 3.3: Determination of metals in ambient PM using XRF 

Key applicable elements Sb, As, Ba, Cd, Ca Cr, Co, Cu, Fe, Pb, Hg, Mn, Ni, Se, Ag, Sn, Ti, Tl, V, Zn, and more 

available 

Measurement range Up to 1963 Ljg/dscm 

Detection limits (IF, EPA 10 3.3)3 Metal and sample time dependent; refer to the minimum detection limit 

(MDL) data 

Sampling and analysis times Every 15, 30, 60, 120 minutes, depending on the per sample mass 

Calibration stability check frequency Automatically with each sample analyzed 

Estimated recalibration frequency Annually, when manufacturer's operating recommendations are followed 

Sample flow rate TBD 

Linearity Correlation coefficient >0.98 

Size and weight (2 cabinets) • 19 inch w x 24 inch d x 19 inch h and 19 inch w x 24 inch d x 35 inch h 

• 180 lbs 

• 483 mm rack-mountable components 

Required operating environment Lab environment with temperature controlled to 20±3°C (68°F) 

Power requirements4 • 120 VAC/60 Hz @ 2-20 amp circuits 

• 220 VAC/60 Hz 20 amp with an optional power converter 

Outputs LAN (Ethernet) and USB ports for standard PC file transfer protocols 

and networking 

Options • Change or add elements 

• Enclosures 

• Remote control 

• Remote polling 

Detection limits are determined using 95% confidence interference-free data. 

Power must be conditioned to maintain a factory warranty or service agreement. 

Xact 640 Performance 

Minimum Detection Limits (ug/m3)

5 

Element Atomic Number Sampling Time (mins) 

15 30 60 120 

Cr 24 0.14 0.05 0.018 0.006 

Mn 25 0.14 0.05 0.018 0.006 

Fe 26 0.38 0.13 0,048 0,017 

Co 27 0.16 0.06 0.020 0.007 

Ni 28 0.11 0.04 0.014 0.005 

Cu 29 0.13 0.05 0.017 0.006 

Zn 30 0.12 0.04 0.014 0,005 

Ga 31 0.05 0.02 0.007 0.002 

Ge 32 0,06 0.02 0.008 0.003 

As 33 0.06 0.02 0.007 0.003 

Se 34 0.07 0.02 0.009 0.003 

Rb 37 0.17 0.06 0.022 0.008 

Sr 38 0.22 0.08 0.028 0.010 

Y 39 0.27 0.10 0.034 0.012 

Mo 42 0.49 0.17 0.061 0.022 

Ag 47 2.17 0,77 0.271 0.096 

Cd 48 2.88 1.02 0.360 0.127 

In 49 3.39 1.20 0.424 0.150 

Sn 50 3.74 1,32 0.467 0.165 

Sb 51 0.33 0.12 0,042 0.015 

Ba 56 0.47 0.17 0.059 0,021 

Pt 78 0.11 0.04 0.014 0.005 

Au 79 0.12 0.04 0.014 0.005 

Hg 80 0.09 0.03 0.012 0,004 

Tl 81 0.09 0.03 0.012 0.004 

Pb 82 0.11 0.04 0.014 0.005 

Bi 83 0.12 0.04 0,015 0.005 

Interference-free, 1 sigma 

VES 001848 
Elements Supported 

Xact 640 monitoring systems identify and measure the 

63 elements highlighted in the table below. Minimum 

detection limits for the elements highlighted in blue can 

be found on the Performance page of this data 

sheet. 

1 

H 

2 

He 

3 

Li 

4 

Be 

5 

B 

E 

c 

7 

N 

8 

o 

9 

F 

10 

Ne 

11 

Na 

12 

Mg 

ii 

At 

14 

Si 

15 

P 

16 

s 

17 

Cl 

18 

Ar 

19 

K 

zo 

Ca 

21 

Sc 

22 

Ti 

23 

V 

24 

Cr 

25 

Mn 

26 

Fe 

27 

Co 

28 

Ni 

29 

Cu 

30 

Zn 

31 

Ga 

32 

Ge 

33 

As 

34 

Se 

35 

Br 

36 

Kr 

37 

Rb 

36 

Sr 

33 

Y 

40 

Zr 

41 

Nb 

43 

Mo 

43 

Tc 

44 

Ru 

46 

Rh 

4G 

Pd 

47 

Ag 

49 

Cd 

49 

tn 

so 

Sn 

si 

Sb 

52 

Te 

S3 

I 

54 

Xe 

ss 

Cs 

56 

Ba 

** 

72 

Hf 

73 

Ta 

74 

w 

75 

Re 

76 

Os 

77 

Ir 

78 

Pt 

79 

Au Hg 

81 

Tl 

62 

Pb 

63 

Bi 

84 

Po 

85 

At 

B6 

Rn 

87 

Fr 

SB 

Ra ** 

104 

Rf 

105 

Ha 

106 

Sg 

107 

Bh 

108 

Hs 

109 

Mt 

110 

Ds 

111 

Rg 

112 

Uub 

113 

Uut 

114 

Uuq 

116 

Uup 

116 

Uuh 

117 

Uus 

118 

Uuo 

* Lanthanide Series 

** Actinide Series 

'57 

La 

5B 

Ce 

59 

Pr 

60 

Nd 

61 

Pm 

62 

Sm 

63 

Eu 

64 

Gd 

65 

Tb 

66 

Dy 

67 

Ho 

68 

Er 

69 

Tm 

70 

Yb 

71 

* Lanthanide Series Lu 

** Actinide Series Ac 

90 

Th 

91 

Pa 

92 

u 

93 

Np 

94 

Pu 

95 

Am 

9G 

Cm 

97 

Bk 

98 

Cf 

99 

Es 

100 

Fm 

101 

Md 

103 

No 

103 

Lr 

Minimum Detection Limits (MDLs) are available for these elements. 

System is capable of measuring these elements, but MDLs have not been developed. 

Orderin g Informatio n 

To place an order or for more information about the 

Xact 640 continuous emissions monitoring system, 

contact your regional Pall representative or email us at 

EnvironmentalSolutions@pall.com 

ENABLIN G A 

GREENER T°

 se e ho w Pal 1 i s

 helping enable a greener, safer and more sustainable 

FUTURE, , future, visitwww.pall.com/green. 

Visit us on the We b at www.pall.com/powe r 

Pall Corporation has offices and plants throughout the world. For Pall representatives in your 

area, please go to www.pall.com/contact 

Because of technological developments related to the products, systems, and/or services 

described herein, the data and procedures are subject to change without notice. Please 

consult your Pall representative or visit www.pall.com to verify that this information 

remains valid. 

© Copyright 2012, Pall Corporation. Pall, and (PAL£) are tradumarks of Pall Corporation. 

® Indicates a trademark registered in the USA. Filtration. Separation. Solution.TM and ENABLING A 

GREENE R FUTUR E are service marks of Pall Corporation. 

PGXACTfWOENa Produc t tn the USA Decfimbflr 2012 

P^L L i Pal! Corporation 

Power Generation 

25 Harbor Park Drive 

Port Washington, N Y 11050 

+1 516 484 3600 telephone 

+1 888 873 7255 toll free U S 

Filtration. Separation. Sotution.su 

VES 001849 
VES 001850.pdf 
THOMPSO N 

COBURNLL P 

December 13, 2012 Joseph M. Kellmeyer 

314-552-6166 

F A X 314-552-7166 

jkcllmeyer@ 

thompsoncobum.com 

VIA ELECTRONIC & CERTIFIED MAIL 

George Czerniak 

Chief Air Enforcement &. Comphance Assurance 

United States Environmental Protection Agency 

Region 5 

77 West Jackson Boulevard 

Chicago, IL 60604-3590 

Re: Withdrawal of Apphcation for Significant Modification to Title V Permit 

No. V-IL-1716300103-08-01 

Dear Mr. Czerniak: 

This firm represents Veolia ES Technical Solutions, LLC ("Veoha"). Veoha is in receipt of your 

e-mail correspondence, dated November 29, 2012, and attached hereto as Ex. A, regarding the 

United States Environmental Protection Agency's ("USEPA's") notice of intent to deny Veoha's 

application for significant modification regarding the above-referenced permit. For the reasons 

stated below, Veolia is formally withdrawing its application for significant modification. 

Veoha does not come to this decision lightly. Rather, it has carefully considered the path 

forward for it, and the Agency, and has determined that it is not in the best interests of either 

party to continue to waste time, energy, and resources carrying on the significant modification 

process when Veoha's Title V renewal process is set to begin in a few short months. 

Veoha first apphed for its Title V permit on September 7, 1995. USEPA officially took over the 

permitting process from the Illinois Environmental Protection Agency on September 29, 2006. 

Veoha then submitted a revised Title V apphcation to USEPA on May 2, 2007. The permit 

was finally issued on September 12, 2008—but, as you know—the Operating Parameter Limits 

("OPLs") for LVMs, SVMs, and mercury that are at the core of the significant modification 

process were left blank. 

However, so much time has now elapsed since September of 2008 that Veolia's application for 

renewal of that very same permit is due in less than four months—on April 12, 2013—and the 

permit expires in less than 10 months—on October 12, 2013. To this end, Veoha is already 

working on its renewal application. 

In an effort to articulate why Veolia believes it must withdraw its application for significant 

modification,—we need to understand how we got to this point. 

Thompson Coburn LLP | Attorneys at Law | On e US Bank Plaza [ St. Louis, Missouri 63101 

P 314.552.6000 | F 314.552.7000 | v/ww.thompsoncoburn.com 

VES 001850 
December 13, 2012 

Page 2 

The current stage of this process began with Veoha's submission of an apphcation for 

significant modification on October 10, 2008. Veolia's application, as required by USEPA, 

included the OPLs for LVMs, SVMs, and mercury that were left out of the Title V permit. See 

USEPA, Region 5, Request to Provide Information Pursuant to the Clean Air Act, Appx. B HI2, 

Sept. 12, 2008. The OPLs included in the October 2008 apphcation were based on the 

performance testing that Veolia undertook in August and September of 2008, again pursuant to 

the Agency's request. See id. at Appx. B H2 (the requirement was originally included in an 

information request from February of 2008). Further, the October 2008 apphcation included a 

request to use extrapolation in calculating Veolia's feedrates,- specifically, Veolia included an 

extrapolation methodology that was provided to them by USEPA Region 5 personnel in 2008. 

Subsequently, Veolia submitted a revised apphcation for significant modification to USEPA on 

or about January 6, 2009. This revision further restricted the OPLs for LVMs, SVMs, and 

mercury based on a revised calculation for the moisture content of the waste that was fed to the 

incinerator during the August and September 2008 performance tests. Veolia again used the 

extrapolation methodology provided to them by USEPA in 2008. 

On November 3, 2009, during a conference call with Veolia, USEPA requested that Veoha 

resubmit their application with more restrictive OPLs for LVMs, SVMs, and mercury. In the 

discussions, USEPA and Veolia agreed that Veoha could use the same extrapolation 

methodology as it had previously used (and that was previously provided by USEPA), but this 

time Veoha would hmit the extrapolation to a maximum of a low multiple of the performance 

test feedrates or 75% of the MACT Emission Standard, whichever was less. On February 25, 

2010, Veolia submitted the third revised application for significant modification. This 

February 2010 significant modification application included OPLs based on the revised 

extrapolation methodology that was discussed during the November 3, 2009, conference call. 

However, Veoha further hmited the OPLs to a maximum of three times the amount of LVMs, 

SVMs, and mercury actually fed into the incinerator during the performance testing. 

In light of Veolia's February 2010 revised apphcation, USEPA later requested that Veolia 

withdraw the October 10, 2008, and January 6, 2009, applications for significant modification. 

Veoha obliged USEPA via correspondence dated May 12, 2010. 

USEPA next contacted Veoha on February 27, 2012, two years after the submission of the 

February 2010 application, to set up a conference call. That conference call was held on March 

8, 2012. During that call, USEPA informed Veoha that the Agency was going to deny Veolia's 

application on the basis of the extrapolation methodology that Veolia used. Veoha and USEPA 

then discussed a schedule by which either Veolia would submit additional information, or the 

Agency would begin actions to deny the modification apphcation. 

Veolia responded to USEPA by email on March 27, 2012. In that correspondence, Veolia 

reiterated that it wanted to work with the Agency, but believed that the request by the USEPA 

to again revise the apphcation—for the fourth time—was unreasonable, particularly in light of 

the fact that Veolia prepared the February 2010 submission in accordance with the agreement 

reached with USEPA during November of 2009. 

VES 001851 
December 13, 2012 

Page 3 

Subsequently, at the Agency's request, Veoha submitted even more technical information to 

USEPA on June 7, 2012. Veoha received no other communication from the USEPA until 

Veoha received your email on November 29th. 

This entire modification process has taken over four years, has been very costly to Veolia, and 

has not achieved its objective of placing the OPLs in Veoha's Title V permit. 

The regulations are clear that four years is well beyond the required deadline for USEPA to 

make a final decision regarding Veolia's application: 

(2) Except as provided under the initial transition plan provided for under § 

71.4(i) or under 40 CFR part 72 or title V of the Act for the permitting of 

affected sources under the acid rain program, the permitting authority shall 

take final action on each permit application (including request for permit 

modification or renewal) within 18 months after receiving a complete 

application. 

40 C.F.R. § 71.7(a)(2) (emphasis supplied). USEPA has exceeded this clear non-discretionary 

deadline. This is true even based on the third iteration of the application for significant 

modification submitted on February 25, 2010. Using the third iteration as the most 

conservative approximate starting point of the 18 month period, USEPA would have had to 

make a final decision by the end of August of 2011 in order to comply with the regulation. The 

Agency failed to act within the 18 month period and thereby violated the regulation. 

These delays and constant uncertainties have frustrated Veolia and have ultimately thwarted 

the intent and mechanics of the regulatory process. However, while Veolia could escalate this 

matter to a point where a neutral third party could finally weigh in on USEPA's failure to 

follow its own regulations, Veoha, for now, has decided the best way forward is to simply 

withdraw its apphcation for significant modification and focus its efforts, and the Agency's 

efforts, on the permit renewal process that begins in April of 2013. 

Veolia understands that by withdrawing its application USEPA may still proceed with 

reopening the current permit under 40 C.F.R. 71.7(f). However, because the permit expires on 

October 12, 2013, less than a year from now, and less than seven months from the end of the 

proposed public comment period, it makes httle sense to proceed down this path. Veolia will 

submit its apphcation for renewal prior to April 12, 2013, per 40 C.F.R. § 71.5(a)(l)(iii). After 

the submission of the renewal materials, the clock begins ticldng again for both Veolia and the 

USEPA to complete the full Title V process within the 18 month window afforded by the 

regulations. In addition, the chances of achieving a successful, amicable, and permanent result 

from a reopening—that is not appealed in near perpetuity—are made worse because the process 

will surely begin to overlap with the renewal process. 

Thus, in sum, the current stage of this process has been an unequivocal failure, and, as a 

result, Veolia is withdrawing its application for significant modification. Veoha will not offer 

comments by the unreasonable deadhne of December 14, 2012, as set forth in your email. 

VES 001852 
December 13, 2012 

Page 4 

("Unreasonable" because it provides Veolia with 15 days to comment after USEPA has taken 

no action since March 8, 2012, and no substantive action on this matter since February of 

2010.) 

While the significant modification process did not produce the desired result for Veoha, we 

were encouraged by your predecessor's willingness to meet and negotiate over these very 

important issues to both parties. Veoha hopes again to work with you within the context of 

the permit renewal. In this spirit after Veoha submits its Title V apphcation in April 2013, 

Veolia requests a meeting with you and other Agency members this Spring to work out any 

differences between the parties. Veoha remains willing and able to work with the Agency on 

any issues that may arise as part of the permit renewal and believes that—at this stage in the 

process—success is most likely to result from communications between technical personnel 

during the upcoming Title V renewal. 

Please contact me should you have any questions or if I can be of assistance to you. 

Very truly yours, 

Thompson Coburn LLP 

5610885 

VES 001853 
VES 001854.pdf 
FW: Veolia SOB 

r

 Meed, Michael to= David Ogulei 12/14/2012 04=23 P M 

History: This message has been replied to. 

If this language needs to be changed I will let you know. 

Michael T. Eeed, CAAPP Unit Manager 

Illinois Environmental Protection Agency 

BOA/DAPC/Permit Section 

1021 N . Grand Ave East 

Springfield, Illinois 62794 

Mich.ael.Reed@illinois.gov 

Office: 217.782.4651 | Fax 217.524.5023 

E-MAI L CONFIDENTIALIT Y NOTICE : This electronic mail message, including any attachments, is 

for the intended recipient (s) only. This e-mail and any attachments might contain information that is 

confidential, legally privileged or otherwise protected or exempt from disclosure under applicable 

law. If you are not a named recipient, or if you are named but believe that you received this e-mail i n 

error, please notify the sender immediately by telephone or return e -mail and promptly delete this 

e-mail and any attachments and copies thereof from your system. Ifyo u are not the intended 

recipient, please be aware that any copying, distribution, dissemination, disclosure or other use of 

this e-mail and any attachments is unauthorized and prohibited. Your receipt of this message is not 

intended to waive any applicable privilege or claim of confidentiality, and any prohibited or 

unauthorized disclosure is not binding on the sender or the Illinois Environmental Protection 

Agency. Thank you for your cooperation. 

From= Pressnall, Chris 

Sent: Friday, December 14, 2012 4=16 PM 

To= Reed, Michael 

Cc= Armitage, Julie 

Subject: Veolia SOB 

On February 26, 2007, the Illinois EPA referred Veolia to the Illinois Attorney General for violations 

ofthe Illinois Environmental Protection Act, Illinois Pollution Control Board Regulations, and the 

HWC MACT. On March 5, 2010, after receiving additional mformation, the Illinois EPA referred 

additional violations of the Illinois Environmental Protection Act, Illinois Pollution Control Board 

Regulations, and the HWC MACT. 

My suggested language above. Unfortunately, I need to leave as I have to pick up my car at the 

shop. I will monitor my email from home over weekend/Monday should additional tweaks be 

necessary. 

Christopher Pressnall 

Assistant Counsel 

Illinois EPA 

(217) 782-5544 

chris.pressnall@illinois.gov 

CONFIDENTIALITY NOTE: 

This e-mail and any attachments are confidential and may be protected by legal privilege. If you are 

not the intended recipient, be aware that any disclosure, copying, distribution or use of this e-mail or 

VES 001854 
any attachment is prohibited. Ifyou have received this e-mail in error, please notify me immediately 

by returning it to the sender and delete this copy from your system. Thank you for your cooperation. 

VES 001855 
VES 001856.pdf 
Updates on Veolia Permitting Action 

— - [ Kathy Andria, Amy Funk, Verena Owen, 

Andrea Morgan to: David Bender, Samantha Ballard, Kat 12/17/2012 04=56 PM 

Logan Smith 

Cc= David Ogulei, Genevieve Damico, Jane Woolums 

Everyone, 

I hope the season is finding you well. We wanted to provide you all with a few updates on the 

permitting action pertaining to Veolia Environmental Services. Veolia has withdrawn their 

application to modify their Title V permit. EPA plans to continue to reopen Veolia's Title V permit 

under 40 C.F.R. § 71.7(f) to incorporate feedrate limits. We expect to public notice the draft permit in 

early 2013 and will notify you all by email when the comment period begins. 

Thank you, 

Andrea Morgan 

Environmental Engineer 

U.S. Environmental Protection Agency 

Region 5 | Air & Radiation Division 

Phone: (312) 353-6058 | Fax: (312) 692-2920 

VES 001856 
VES 001857.pdf 
Updates on Veolia Permitting Action Pj 

David Ogulei to: Doug Harris 

£ . Genevieve Damico, Andrea Morgan, Dennis J Warchol, John 

Mooney 

12/19/2012 09:14 AM 

Doug, 

In light of the December 13, 2012 letter from your attorneys formally withdrawing your significant 

modification application, I wanted to give you a brief update on our current plans with respect to 

your Title V permit. EPA plans to proceed with reopening Veolia's Title V permit under 40 C.F.R. § 

71.7(f) to incorporate feedrate hmits derived from the 2008 comprehensive tests. We expect to public 

notice the draft permit in early 2013 and will notify you when the comment period begins. 

As a part of our community outreach efforts, we are planning to inform the public that you have 

offered tours ofthe Veolia facility. However, as expressed in Genevieve Damico's email of December 

17, we would like to verify that the offer for facihty tours is still on the table, or if you would prefer 

we no longer include this information in our outreach materials. We would appreciate it if you could 

let us know this week if you would like us to remove this information. 

Regards, 

-David 

David Ogulei, Ph.D., P.E. 

U.S. Environmental Protection Agency 

Region 5 | Air & Radiation Division | A-18J 

77 West Jackson Blvd. | Chicago, Illinois 60604 

Phone: (312) 353-0987 | Fax: (312) 692-2080 

Ogulei.David@epa.gov 

VES 001857 
VES 001858.pdf 
FW Updates on Veolia Permitting Action 

*

4

' y Elizabeth. J , Hubertz to: Andrea Morgan 12/19/2012 01=53 PM 

' - * Cc= Damico.Genevieve, David Ogulei 

Hi Andrea -- we have been working with Kathy Andria in connection with Veolia. 

Could you please add me (ejhubertz@wulaw.wustl.edu) and our environmental scientist Ken Miller 

(kmiller@wulaw.wustl.edu) to the email list of people you notify when the comment period for the 

Veolia reopened permit begins or when you have any other updates on the matter ? 

Thank you very much and have a great hohday season! 

Liz 

Elizabeth J. Hubertz 

Clinic Attorney 

Interdisciplinary Environmental Clinic 

Washington University School of Law 

Campus Box 1120 

St. Louis, MO 63130 

Phone: 314.935.8760 

Fax= 314.935.5171 

Email: ejhubertz@wulaw.wustl.edu 

Forwarded message 

From: Morgan.Andrea@epamail.epa.gov 

Date: Mon, 17 Dec 2012 16:56=27 -0600 

Subject: Updates on Veoha Permitting Action 

To= Kathy Andria <kathyandria@gmail.com>, Amy Funk 

<amyfunk@illinois.edu>, Verena Owen <baumling@aol.com>, David Bender 

<bender@mwbattomeys.com>, Samantha Ballard 

<breaking.reality@gmail.com>, Kat Logan Smith 

<klogansmith@moen viron. or g> 

Cc= Ogulei.David@epamail.epa.gov, Damico.Genevieve@epamail.epa.gov, 

Woolums.Jane@epamail.epa.gov 

Everyone, 

I hope the season is finding you well. We wanted to provide you all with a 

few updates on the permitting action pertaining to Veolia Environmental 

Services. Veolia has withdrawn their application to modify their Title V 

permit. EPA plans to continue to reopen Veolia's Title V permit under 40 

C.F.R. § 71.7(f) to incorporate feedrate limits. We expect to public 

notice the draft permit in early 2013 and will notify you all by email 

when the comment period begins. 

VES 001858 
Thank you, 

Andrea Morgan 

Environmental Engineer 

U.S. Environmental Protection Agency 

Region 5 | Air & Radiation Division 

Phone: (312) 353-6058 I Fax: (312) 692-2920 
VES 001860.pdf 
i 

~ 7 

RE: Tour of Facility 

Doug Harris to= Genevieve Damico 

Cc: Andrea Morgan, David Ogulei, Dennis J Warchol, John Mooney 

12/20/2012 01:17 PM 

Genevieve, 

Nice to hear from you...hope the holiday season is finding you well also. I'm not sure whether you know 

or not but as a result of your outreach, we had a group request and come through for a tour. I believe 

the group enjoyed their tour and we sure had a good time giving it to them. As far as the offer of future 

tours, please keep it in your outreach documents as you see fit. Also, if you or any of your colleagues 

are ever in any type of group, organization or meeting that you think might enjoy or benefit from 

visiting our facility, please feel free to offer and just have them contact me directly. I think we enjoy 

giving these tours more than the groups receiving them!! Have a Merry Christmas and look forward to 

seeing you soon. 

Doug Harris 

General Manager 

Veolia ES Technical Solutions, LL C 

7 Mobile Ave. 

Sauget, IL 62201 

Office 618-271-2804 Ext. 101 

Cell: 618-616-7420 

Fax: 618-271-2128 

Doug.harris@veoliaes .com 

www.veoliaes.com 

Service First. Safety Always 

This e-mail message from Veolia Environmental Services North America Corp. is for the sole use of 

the intended recipient and may contain confidential and privileged information . Any unauthorized 

review, use disclosure or distribution is prohibited. Ifyou are not the intended recipient, please 

communicate with the sender by reply e-mail and destroy all copies of the original message and 

delete same from all computers. 

From: Damico.Genevieve@epamail.epa.gov [mailto:Damico.Genevieve@epamail.epa.gov] 

Sent: Monday, December 17, 2012 9:16 AM 

To: Doug Harris 

Cc: Morgan.Andrea@epamail.epa.gov; Ogulei.David@epamail.epa.gov; Dennis J Warchol; 

Mooney. John@epamail .epa.gov 

Subject: Tour of Facility 

Doug, 

I hope the season is finding you well. 

At our call a few months ago with the groups we expect to be interested in this 

VES 001860 
permitting action, you offered tours of the facility as a part of community outreach 

efforts. In light of the letter we received last Thursday we would like to verify that the 

offer is still on the table or if you would prefer we no longer include this information in 

the outreach documents. We would appreciate it ifyou could let us know if you would 

like us to remove this information this week. 

Thank you for your consideration. 
VES 001862.pdf 
RE: Tour of Facility 

Doug Harris to: Genevieve Damico 

Cc: Andrea Morgan, David Ogulei, Dennis J Warchol, John Mooney 

12/20/2012 01:17 PM 

Genevieve, 

Nice to hear from you...hope the holiday season is finding you well also. I'm not sure whether you know 

or not but as a result of your outreach, we had a group request and come through for a tour. I believe 

the group enjoyed their tour and we sure had a good time giving it to them. As far as the offer of future 

tours, please keep it in your outreach documents as you see fit. Also, ifyou or any of your colleagues 

are ever in any type of group, organization or meeting that you think might enjoy or benefit from 

visiting our facility, please feel free to offer and just have them contact me directly. I think we enjoy 

giving these tours more than the groups receiving them!! Have a Merry Christmas and look forward to 

seeing you soon. 

Doug Harris 

General Manager 

Veolia ES Technical Solutions, LL C 

7 Mobile Ave. 

Sauget, IL 62201 

Office 618-271-2804 Ext. 101 

Cell: 618-616-7420 

Fax: 618-271-2128 

Doug.haiTis@veoliaes.com 

www.veoliaes.com 

Service First. Safety Always 

This e-mail message from Veolia Environmental Services North America Corp. is for the sole use of 

the intended recipient and may contain confidential and privileged information . Any unauthorized 

review, use disclosure or distribution is prohibited. Ifyou are not the intended recipient, please 

communicate with the sender by reply e-mail and destroy all copies of the original message and 

delete same from all computers. 

From: Damico.Genevieve@epamail.epa.gov [mailto:Damico.Genevieve@epamail.epa.gov] 

Sent: Monday, December 17, 2012 9:16 AM 

To: Doug Harris 

Cc: Morgan.Andrea@epamail.epa.gov; Ogulei.David@epamail.epa.gov; Dennis J Warchol; 

Mooney.John@epamail.epa.gov 

Subject: Tour of Facility 

Doug, 

I hope the season is finding you well. 

At our call a few months ago with the groups we expect to be interested in this 

VES 001862 
permitting action, you offered tours of the facility as a part of community outreach 

efforts. In light of the letter we received last Thursday we would like to verify that the 

offer is still on the table or if you would prefer we no longer include this information in 

the outreach documents. We would appreciate it ifyou could let us know ifyou would 

like us to remove this information this week. 

Thank you for your consideration. 

VES 001863 
VES 001864.pdf 
Fw: Fact Sheet Request for Veolia 

Andrea Morgan to: David Ogulei 01/04/2013 12:48 PM 

Forwarded by Andrea Morgan/R5/USEPA/US on 01/04/2013 12:48 PM 

From: 

To: 

Date: 

Subject: 

Dennis J Warchol <dennis.warchol@veoliaes.com> 

Andrea Morgan/R5/USEPA/US@EPA, 

08/27/2012 10:52 AM 

Fact Sheet Request for Veolia 

Andrea, 

Attached are some simplified flow diagrams for the three incinerators. Please let me know if these are 

what you are looking for. There were also Fact Sheets developed by USEPA and IEPA when the Title V 

permit and RCRA Part B permit were issued in 2008 and 2009 respectively. Let me know ifyou need 

anything else. 

SERVIC E FII '.-i r ALWAY S 

Dennis J. Warchol 

EHS Manager 

Veolia ES Technical Solutions, L.L.C. 

Trade Waste Incineration Facihty 

#7 Mobile Avenue 

Sauget, IL 62201 

618-271-2804 (ext.169) 

618-271-2128 (fax) 

Dennis.warchol@VeoliaES.com 

www.VeoliaES.com 

This e-mail message from Veolia ES Technical Solutions, LL C is for the sole use ofthe intended 

recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, 

disclosure or distribution is prohibited. Ifyou are not the intended recipient, please communicate 

with the sender by reply e-mail and destroy all copies ofthe original message and delete it from all 

computers. 

Stwiscamierl2082709250.pdf 

VES 001864 
TANK fARM 

DIRECT INJECT. 

TANK FARM LOW 

aru 

DIRECT INJECT ( LIQUIDS 

LIQUID CONTAINER 

GAS CYIINOERS, 

SPECIALTY 

FEEOER 

PRIMARY 

FUEL 

-SECONDARY 

All! 

CMEBGOIM 

STACK 

INCINERATOR 

UPPER 

CHAMBER 

|BURlitt1iWn(CI!| 

J^L- J 

V/ET ASH 

DUMPSTER 

IIME 

PREPARATION 

SYSTEM 

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DRY 

ABSORBER 

DRY SCRUBBER 

SOUD5 [ DSS ) 

EHD DUMP 

jit 

MAIN STACKSTACX M S 

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BAGHOUSE I.D. FAN 

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END DUMP 

ccoccolaaoa*-

FUELS/UQUIO WASTE FUW 

COMBUSTION -MR FLOW 

STACK GAS FLOW 

ASH FLOW 

SOLID WASTE FLOW 

LIME SLURRY FLOW 

Figure 3-1. Unit 2 Process Flow Diagram 
TANK FARM 

DIRECT INJECT, 

HIGH 

BTU 

LIQUIDS 

SOCIO S 

rum FARM ] LOW 

BTU 

DIRECT INJECT Y LIQUIDS 

SPECIALTY FEEDER 

FUME HOOD 

EMISSION CONTROL 

SYSTEI, 

y 

IMI I 

Mil l 

T T T 7,1 -

COM6UST10N 

AIR 

BLOWER 

I 

-UHOBJIRE 

AIR 

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T T.T T T T 

-SECCHOARY 

AB 

INCINERATOR 

LOWER 

CHAMBER 

ENERG&CY 

SUCK 

LIME 

PREPARATION 

SYSTEM 

INCINERATOR 

UPPER 

CHAMBER 

f t 

WET ASH 

DUMPSTER 

SPRAY 

DRY 

ABSORBER 

PRIMARY 

FUEL 

DRY SCRUBBER 

SOUDS ( DSS ) 

END DUMP 

MAIN STACKSMCX CAS 

.VIALYERS ' 

BAGHOUSE 1.0. FAN 

DRY SCRUBBER 

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END DUMP 

GLOVE BOX 

EMISSION CONTROI 

SYSTEM ocoax»-

FUELS/LIQUID WASTE FLOW 

COMBUSTION AIR FLOW 

STACK CAE FLOW 

ASH FLOW 

SOUD WASTE FLOW 

UUt SLURRY FLOW 

Figure 3-1. Unit 3 Process Flow Diagram 
TANK FARM 

DIRECT INJECT 

sum 

\arr 

ORY SCRUBBER 

SOLIDS ( DSS ) 

END DUMP 

EMERGENCY 

STACK 

TANK FARM , LOW 

BTU 

DIRECT INJECT , LIQUIDS 

KILN 

SECONDARY 

COMBUSTION 

CHAMBER 

TEMPERING 

CHAMBER 

\ PRMARY 

/ rua 

ASH 

ROLL-OFF 

;0M8USTl0Nj 

AIR 

BLOVERS 

SPRAY 

DRY 

ABSORBER 

LIME 

PREPARATION 

SYSTEM 

c 

< 

• 

SPRAY 

DRY 

ABSORBER 

— 

WET ASH ORY ASH 

DUMPSTER DUMPSTER DRY SCRUBBER 

SOLIDS ( DSS ) 

END DUMP 

ORY SCRUBBER 

SOUDS ( DSS ) 

END DUMP 

BAGHOUSE 

MAIN STACKCARBON 

INJECTION 

SYSTEM 

BAGHOUSE 

Stao; CAS 

AVALT2£HS 

I.D. TAN 

ORY SCRUBBER 

SOUDS ( DSS ) 

END DUMP 

OlELS/UOUtD WASTE FLOW 

COMBUSTION AIR FLOW 

STACK GAS FLOW 

ASH ROW 

SOUD WASTE ROW 

LIME SLURRY FLOW 

Figure 3-1. Unit 4 Process Flow Diagram 
VES 001868.pdf 
BW: Upcoming actions regarding Veolia Environmental Services 

Andrea Morgan to: David Ogulei 01/07/2013 09:37 AM 

Forwarded by Andrea Morgan/R5/USEPA/US on 01/07/2013 09:37 A M -----

From-' "Funk, Amy" <amyfunk@illinois.edu> 

To: Andrea Morgan/R5/USEPA/US@EPA, 

Date: 08/07/2012 07:59 AM 

Subject: RE: Upcoming actions regarding Veolia Environmental Services 

Thanks for the explanation. Not something one can sum up in a sound bite. 

I look forward to receiving the public notice and factsheet. 

Take care, 

Amy Funk 

Metro East Community Air Project, Action Research. Illinois 

University of Illinois, Urbana-Champaign 

1 Regency Plaza Drive 

CollinsviUe, IL 62234 

618-514-7854 

amyfunk@illinois.edu 

Protect the environment. Don't print this document unless it's necessary. 

"Under the Illinois Freedom of Information Act (FOIA), any written communication to or from University 

employees regarding University business is a public record and may be subject to public disclosure." 

From: Andrea Morgan [mailto:Morgan.Andrea@epamail.epa.gov] 

Sent: Tuesday, August 07, 2012 7:46 AM 

To: Funk, Amy 

Subject: RE: Upcoming actions regarding Veolia Environmental Services 

Amy, 

Thank you for attending yesterday's call- we really appreciated your insights and suggestions. The 

proposed action is a revision to a Title V permit and more details will be available in the public notice. This 

came about after the Sierra Club and American Bottom Conservancy petitioned the EPA to object to the 

issuance of a proposed Title V permit back in 2005. The EP A issued an order granting the petition in part 

and denying it in part which started a 90-period during which the IEPA was required to issue a revised Title 

V permit that addressed the issues raised in the February 1, 2005 order. IEPA did not issue the permit 

during that 90-day window. As a result the Sierra Club and American Bottom Conservancy sued EPA, 

alleging that EP A had a duty to issue the permit following the State of Illinois' failure to timely issue the 

revised permit. EPA did issue that Title V permit, which is the current Title V permit, and the proposed 
revision will be to the federally issued permit. 

Thank you for providing us with your contacts. We completely understand why you would not feel 

comfortable sharing everyone's emails, so we will be sure to send you copies ofthe fact sheet and public 

notice in a timely manner so that you can share them. 

Thank you again for all of your help. 

Andrea 

From: "Funk, Amy" <amvfunk@illinois.edu> 

To: Andrea Morgan/R5/USEPA/US@EPA, 

Date: 08/06/2012 04:01 P M 

Subject: RE: Upcoming actions regarding Veolia Environmental Services 

Hell o Andrea , 

Than k yo u fo r includin g m e o n today' s call ! M y apologie s if I sounde d a bit confused . I a m a little unclea r as t o th e 

purpos e o f outreach . In you r previou s email , yo u mentio n modification s t o Veolia' s Title V permit , bu t it did no t 

provid e specific s (assumin g thi s wil l b e in th e publi c notice). Wh y is IEPA no t involved ? Doesn' t th e stat e agenc y 

overse e Title V permit s fo r majo r sources ? I've bee n at m y jo b fo r a yea r an d ther e is still a learnin g curve . I 

originall y assume d yo u wer e wit h IEPA, but notice d you r emai l is EPA . 

Attache d is a short list of agencies/POC' s fo r outreac h efforts . Thi s is a simila r list I sen t t o Ke n Bard o a t Regio n V 

regardin g som e outreac h effort s he ha s bee n involve d with . 

I a m involve d wit h a Universit y Collaborativ e in East St Loui s an d w e hav e a n list o f variou s nonprofit s /communit y 

group s tha t work/ar e base d in th e Eas t St . Loui s area . Onc e yo u hav e th e factshee t an d publi c notice , I can ge t tha t 

o u t throug h thes e channels . I d o no t fee l comfortabl e providin g all thos e email s directly . I hop e yo u understand . 

Dependin g o n th e timing , I coul d also mak e hardcopie s of th e factshee t availabl e at som e of th e meeting s I atten d 

in ESL. 

Hopefull y thi s helps . I a m happ y t o assis t wher e I can . 

Hav e a grea t evening ! 

A m y Fun k 

Metr o Eas t Communit y Air Project , Actio n Research . Illinois 

Universit y o f Illinois, Urbana-Champaig n 

1 Regenc y Plaz a Driv e 

CollinsviUe , IL 6223 4 

618-514-785 4 

amvfunk@illinois.edu 

VES 001869 
www.nieairproiect.org 

Protect the environment. Don't print this document unless it's necessary. 

"Unde r th e Illinois Freedo m of Informatio n Ac t (FOIA), an y writte n communicatio n t o o r fro m Universit y employee s 

regardin g Universit y busines s is a publi c recor d an d ma y be subjec t t o publi c disclosure. " 

From: Andrea Morgan [maitto:Morqan,Andrea@epa mail.epa.qovl 

Sent: Wednesday, August 01, 2012 12:01 PM 

To: Kathy Andria; Funk, Amy; Verena Owen; David Bender; Samantha Ballard; 

david.klarich@veoliaes.com: Dennis.warchol(Bveoliaes.com: Douq.harris@veoliaes.com: Kat Logan Smith 

Cc: Alan Walts; David Ogulei; Genevieve Damico; Jane Woolums; Lara Lasky; Ken Page; Althea Moses 

Subject: Re: Upcoming actions regarding Veolia Environmental Services 

Thank you everyone for the prompt replies. The best time for everyone is Monday, August 6 at 11am. If 

you are unable to make the call but have suggestions for the public participation plan, please sent them to 

me by Friday and I will share them with the group. The instructions on how to call in are below. 

Dial-In Number: (866) 299-3188 

Conference Code: #3128865031 

To join the conference call the dial in number and then when prompted enter the conference code 

followed by the pound key. 

Please let me know if you have any questions. 

Thank you for your time and we look forward to talking with you on Monday. 

Andrea 

Andrea Morgan 

Environmental Engineer 

U.S. Environmental Protection Agency 

Region 5 | Air & Radiation Division 

Phone: (312) 353-6058 | Fax: (312) 692-2920 

From: Kathy Andria <kathvandria@qmail.com> 

To: Andrea Morgan/R5/USEPA/US@EPA, 

C c : David Bender <bender@mwbattomevs,corn>. Kat Logan Smith <kloqansmith@moenviron.orq>, Samantha Ballard < 

breaking.realitv@qmail.com>. Amy Funk <amyfunk@illinofS.edu>, Verena Owen <baumlinq(5)aol.com>, 

david.klarich(5).veoliaes.com. Dennis.warchol@veotiaes.cofn, Douq.han-is@veoliaes.com, David Ogulei/R5/USEPA/US@EPA, 

Genevieve Damico/R5/USEPA/US@EPA, Jane Woolums/R5/USEPA/US@EPA, Alan Walts/R5/USEPA/US@EPA, Lara 

Lasky/R5/USEPA/US@EPA 

Date: 07/31/2012 06:22 AM 

Subject: Re: Upcoming actions regarding Veolia Environmental Services 

VES 001870 
monday bette r fo r me, too . 

On 7/30/12, Andre a Morgan <Morqan.Andrea@epamail.epa.gov> wrote : 

> Kathy : Thank you fo r you r comments and suggeste d contacts . 

> Everyon e : 

> We woul d lik e t o move forwar d and begi n t o develo p a publi c participatio n 

> plan . The goa l o f thi s pla n i s t o determin e what strategie s and approache s 

> make th e most sens e t o ensur e tha t we ar e abl e t o provid e opportunitie s 

> fo r community members and intereste d partie s t o havin g meaningfu l 

> involvemen t i n th e permittin g proces s . Such suggestion s can includ e th e 

> most suitabl e methods o f communicatio n t o infor m community members o f 

> publi c hearings , th e type s o f informationa l material s tha t woul d be most 

> beneficia l t o community members as wel l as th e bes t methods o f makin g suc h 

> material s available . Whil e we may no t be abl e t o ac t on al l o f th e 

> suggestions , the y wil l al l be take n int o consideration . We woul d lik e t o 

> schedul e a cal l fo r eithe r Thursda y Augus t 2, o r Monday Augus t 6 t o 

> discus s suggestion s fo r th e publi c participatio n plan . I f you ar e 

> intereste d i n participatin g pleas e sen d me you r availabilit y fo r Thursda y 

> Augus t 2 and Monday Augus t 6 by th e end o f th e day Tuesday , and we wil l 

> provid e th e informatio n fo r th e cal l no late r tha n Wednesday . 

> Thi s meetin g i s jus t a firs t step - more opportunitie s t o participat e wil l 

> be forthcomin g and discusse d a t th e cal l . I f you ar e unabl e t o atten d th e 

> call , bu t have suggestion s fo r th e publi c participatio n pla n tha t you 

> woul d lik e t o shar e pleas e send them t o me no late r tha n Wednesday and 

> the y wil l be share d wit h th e grou p . 

> Thank you fo r you r tim e and we loo k forwar d t o you r suggestion s . 

> Andre a 

> 

> Andre a Morgan 

> Environmenta l Enginee r 

> U.S. Environmenta l Protectio n Agency 

> Regio n 5 | Ai r & Radiatio n Divisio n 

> Phone: (312) 353-6058 | Fax: (312) 692-2920 

> 

> 

> 

> 

> From: Kath y Andri a <kathyandria@gmail•com > 

> To: Andre a Morgan/R5/0SEPA/US@EPA, 

> Cc: Davi d Bende r <benderimwbattorneys.com> , Davi d 

> Ogulei/R5/USEPA/US@EPA, Geneviev e Damico/R5/USEPA/US@EPA, Jane 

> Woolums/R5/USEPA/US§EPA, Ala n Walts/R5/USEPA/US@EPA, Ka t Logan Smit h 

> <kloqansmir.h@rrioenviron . org>, Samantha Ballar d 

> <breakin g . r.eality@gmai l . com>, Amy Funk < amy fun k@i l l i no i s . edu>, Veren a Owen 

> <baumling@aol•com> 

> Date : 07/27/2012 02:10 PM 

> Subject : Re: Upcoming action s regardin g Veoli a Environmenta l 

> Service s 

> 

> 

> 

> 

> 

> Andrea : I'm sorr y fo r th e dela y i n answering . Thank you fo r you r effort s 

> a t outreach . 

> 

VES 001871 
> 

> Ther e ar e a number o f folk s who ar e intereste d i n participatin g i n th e 

> publi c proces s fo r any propose d changes t o th e Veoli a emissio n limit s , 

> includin g peopl e i n Eas t St . Loui s and St . Loui s who ar e intereste d i n th e 

> environmenta l justic e issu e as wel l as ai r pollutio n . Indeed , we ar e 

> alarme d tha t you ar e considerin g suc h changes , sinc e th e issue s remai n th e 

> same: subsistenc e fishin g a t Fran k Holte n Stat e Par k (even more so , give n 

> th e curren t economy) and th e locatio n o f th e hazardou s wast e incinerato r 

> i n th e middl e between th e citie s o f Eas t St . Loui s and St . Louis . 

> 

> We ar e compilin g a lis t and thin k tha t Sierr a Clu b (bot h Illinoi s and 

> Missouri) , Missour i Coalitio n fo r th e Environment , th e Metr o Eas t 

> Community Ai r Project , and a number o f community and church-affiliate d 

> group s ar e interested . 

> 

> Thank you fo r th e emai l . 

> 

> Kath y 

> 

> Kath y Andri a 

> President , America n Botto m Conservanc y 

> Conservatio n Chair , Sierr a Clu b Kaskaski a Group 

> 

> 

> 

> 

> 

> 

> 

> Kathy , Maxine , and Doug, 

> EPA wil l soon be providin g publi c notic e o f it s propose d action s regardin g 

> a reques t by Veoli a Environmenta l Service s (Veolia) , locate d a t 7 Mobil e 

> Ave, Sauget , S t Clai r Count y Illinoi s t o revis e thei r Clea n Ai r Ac t Titl e 

> V. As th e /American Bottom Conservanc y and Washingto n Universit y Law Clini c 

> have bee n involve d i n previou s issue s regardin g thi s facilit y EPA woul d 

> lik e t o infor m you o f th e propose d actio n and reques t suggestion s t o 

> improv e publi c participatio n i n th e permittin g proces s . 

> As directe d by EPA, Veoli a requeste d a revisio n t o it s Titl e V operatin g 

> permi t t o incorporat e feedrat e limit s fo r heav y metal s base d on testin g 

> performe d i n 2008. I n th e propose d actio n EPA intend s t o revis e Veolia' s 

> Titl e V operatin g permit , throug h th e significan t modificatio n process , by 

> incorporatin g int o th e Titl e V permi t feedrat e limit s fo r heavy metal s . 

> EPA propose s t o establis h feedrat e limit s fo r mercury , semivolatil e 

> metal s and low volatil e metal s . 

> EPA woul d lik e t o invit e you t o provid e suggestion s on how you woul d lik e 

> t o see th e permittin g proces s ru n . Such suggestion s can includ e th e most 

> suitabl e methods o f communicatio n t o infor m community members o f publi c 

> hearings , th e type s o f informationa l material s tha t woul d be most 

> beneficia l t o community members as wel l as th e bes t methods o f makin g suc h 

> material s available . Whil e we may no t be abl e t o ac t on al l o f th e 

> suggestions , the y wil l al l be take n int o consideration . We woul d lik e t o 

> invit e you t o participat e i n a cal l wit h EPA staf f as wel l as a 

> representativ e fro m Veolia , Doug Harris , t o discus s suggestions . I f you 

> woul d be intereste d i n participating , pleas e provid e us wit h time s durin g 

> th e week o f eithe r Jul y 16 o r Jul y 23 tha t you woul d be availabl e t o 

> participate . 

> Thank you , 

> Andre a Morgan 

> Environmenta l Enginee r 

> U.S. Environmenta l Protectio n Agency 

> Regio n 5 | Ai r & Radiatio n Divisio n 

VES 001872 
> Phone: (312 ) 353-605 8 I Fax : (312 ) 692-292 0 

> 

>[attachmen t "ESL_POC info.pdf " delete d b y Andre a Morgan/R5/USEPA/US] 

VES 001873 
EastSide Health District- Public Health Dept covering East St. Louis, Cahokia, Sauget etc. 

Public Health Administrator: Elizabeth Patton-Whiteside- epatton@eshd.orR 

Doug King, Public Health Assistant Administrator- dking@eshd.org 

SIUE School of Nursing/East St. Louis Clinic/East St. Louis Community Gardens 

Kathi Thimsen, Director Community Nursing Services kthimse@siue.edu 

Claire Dalai,, Asthma nurse specialist cdalal@siue.edu 

St. Clair County Health Department, 

Director of Health Protection barb.holt@co.st-clair.il.us 

Kristy Mullins Environmental Protection Manager- Kristy.mullins@co.st-clair.il.us 

Christian Activity Center in East St. Louis- Chet Cantrell, Executive Director 

chet@cacesl.org 

Has expressed concerns related to environment & health 

United Congregations of Metro East, They have several East St. Louis churches in their organization. 

Jessica Wernli, Director iessica.wernli@gmail.com 618-451-1458 

Larry Evans- evans.larry9@gmail.com 

JoAnn Ellerbrake- iellerbrake@att.net 618-632-3158 

Larry Galligher- lgallagherl@iuno.com 

Kamina Loveless, ESL resident that is interested in her community and the environment. Active in a 

community garden initiative 

Kamlovel234@gmail.com 

Ramona Taylor Williams, Metro St. Louis Coalition for Inclusion & Equity 

rftwilliams@gmail.com 

Others organizations/entities active in area, but do not have an established relationship: 

Rush Senior Gardens Apartments 

(618) 875-9747 -1530 Bond Ave, East Saint Louis, IL, 62207 

I do not have a contact name for this. It is possible they might have some sort of board. 

Land of Lincoln 

Kathy O'Kiefe-398-0958 

Children's Home & Aid 

907 Martin Luther King Drive 

East St. Louis, IL 62201-1704 

VES 001874 
(618) 874-0421 

Lessie Bates Davis Neighborhood House 

Vera Jones 618-874 0777 vjones@lessiebatesdavis.org East St. Louis, Education & Youth 

Development Director 

Catholic Urban Programs 

phone (618) 398-5616 

East St. Louis Center—Charter School 

• Venessa Brown, Associate Provost forlnstitutional 

SlUE East St. Louis Center 

601 James R. Thompson Blvd. Box 1200 62201 

Phone: (618) 482-6912 

• Sandra Fields, Assistant Director 

Phone: (618) 482-6906 

• Public Information and Communications 

Patricia Merritt, SlUE Marketing & Communications 

Phone: (618) 650-2294 

Fax: (618) 650-2233 
VES 001876.pdf 
C E S J * v

 ~ 

QAGTM 820 

Quantitative Aerosol Generator (QAG) 

Key Features 

• Quantitative aerosol Traceable to NIST Standards 

• Simultaneous for one or more elements 

• Wide range: ng/dscm to mg/dscm 

• Automatic mass loss reporting 

• Single operator with minimal input requirements 

The QAGTM creates an aerosol of know concentration by ultrasonically 

nebulizing a solution. The resulting droplets are carried out of 

generation area to a drying chamber where they are dried to salt 

Q A G CE S particles. Depending on the application for the salt particles the size 

Quantitative Aerosol Generator

 ca n D e

 varied to a number mean between 0.1 and 2 pm in diameter. 

The aerosol exiting the drying chamber contains known concentrations 

of analyte elements calculated from the QAG' s input parameters. This 

reference aerosol produced by the QA G is process traceable to NIST 

standards and can be used to challenge and evaluate the accuracy, 

precision and linearity of measurement methods such as the Xact 

series monitors during certification and RATA. 

Approved t ': t - or Multi-Metal CEMS Audits 

g§siis = i;ss ; = sir-= , and Certifies wi. , 

Stability has been demonstrated through repeated use in the laboratory and in the field for over five years. The 

Q A G can be operated by one user with minimal parameter inputs and control. The QA G may also be potentially 

applicable to other inorganic analytes including most hazardous elements in stack and fugitive emissions as well as 

those present in the ambient environment. 

This instrument is the first quantitative aerosol generator to be approved by EP A for evaluating, validating and 

certifying continuous multi-metals CEM S used for compliance demonstration. The QA G greatly simplifies the 

certification and auditing of multi-metal CEM S and eliminates the need to compare multi-metal CEM S results to less 

precise and less accurate traditional multi-metal reference methods such as EP A Reference Method 29. 

VES 001876 
Applications 

Possible applications include evaluation, verification, audits and certification of metals and P M measurement 

systems. It is applicable to both metal and non-metal species as well as generic P M aerosols. 

Product Specifications 

Aerosol Generation Method Ultra-sonic nebulization 

Elements Hg, As, Pb, Cr, Cd, Co, Fe, Zn, Tl, Sb, Cu, Mn, Ni, V, Se, Ba, Br, Sr, Pd, Ag and more... 

Aerosol Concentration Range ng/dscm to mg/dscm 

Can spike flows Up to 1000 lpm 

Calibration Period Most components require recalibration at least annually 

Balance calibration check frequency Daily 

Percent Relative Difference 5% 

Linearity Correlation coefficient greater than 0.99 

Size and Weight 3' (W) x 2' (D)x 5' (H), 160 lbs assembled 

Range of Operating Temperatures 50 to 90 °F 

Power Requirements1 120VAC/ 60 Hz, two- 20 amp circuits (220 VAC/60Hz with optional power converter) 

Inputs/Outputs All mass data available through RS232 port 

Options Particulate matter, Metals, an d non-metal species 

1. 1 circuit must be condition power to maintain factory warrantee or service agreement. 

Quantitative 

Aerosol 

7^ 

Drying 

Chamber 

System 

Nozzle Air Size -

Control Selection 

Syslem V System 

7^ 

Solution f 

Control 

System 

f \ Atomizer / \ 

System \ j 

1 Atomizer Air 

Control 

i System 

VES 001877 
VES 001878.pdf 
Race 

Race (by percent of persons) Within 0.5 Miles of 

Facility 

Within 1 Mile of Facility 

Within 3 Miles of 

Facility 

Within 5 Miles of 

Facility 

Illinois US 

White 90.7% 58.5% 35.1% 38.0% 73.5% 75.1% 

African-American 9.3% 39.8% 60.3% 56.1% 15.0% 12.3% 

Asian/ Pacific Islander 0.0% 0.0% 1.3% 2.3% 3.4% 3.7% 

American Indian 0.0% 0.5% 0.4% 0.4% 0.2% 0.9% 

Other race 0.0% 0.7% 0.8% 1.0% 5.8% 5.5% 

Multiracial 0.0% 0.5% 2.1% 2.3% 2.0% 2.4% 

Hispanic-Origin* 0.0% 1.4% 2.1% 2.4% 12.3% 12.5% 

*not included in total that adds to 100% 

(by percent of persons) Within 0.5 Miles of 

Facility 

Within 1 Mile of Facility 

Within 3 Miles of 

Facility 

Within 5 Miles of 

Facility 

Illinois 

Percent below Poverty Level 10.5% 26.6% 32.7% 30.2% 10.7% 

Income 

Income Breakdown by 

Household 

Households within .5 

Miles (%) 

Households within 1 

Mile (%) 

Households within 

3 Miles (%) 

Households within 

5 Miles (%) Illinois US 

Less than $15,000 10.4% 26.7% 34.1% 33.4% 13.8% 15.8% 

$15,000 - $25,000 11.7% 14.8% 17.1% 18.2% 11.3% 12.8% 

$25,000 - $50,000 40.3% 31.0% 29.1% 28.8% 28.1% 29.3% 

$50,000 - $75,000 16.9% 10.7% 11.2% 11.5% 20.7% 19.5% 

Greater than $75,000 16.9% 15.3% 8.3% 8.0% 26.0% 22.5% 
Income of households within 3 mile of the facilit y 

1 1 %

 34 % iLes s tha n $15,000 

•$15,000 - $25,000 

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! it$25, 000 - $50,000 

•BBBBBBBBBBB I n$50 , 000 - $75, 000 

2 9 % ^Greate r tha n $75,000 

Race of residents within 3 miles of the 

facility 

1 3 % 0.4% _ 0.8%(i2.1% 

35.1% 

60 3% 

• White 

• African-American 

• Asian/ Pacific Islander 

• American Indian 

• Other race 

• Multiracial 

VES 001879