UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 5 

77 WEST JACKSO N BOULEVAR D 

CHICAGO, IL 60604-3590 

•' MA Y 1 6 2013 -t| 

t .,r REPL Y TO TH E ATTENTION OF: 

Douglas Harris, General Manager 

Veolia ES Technical Solutions, T.L.C. 

7 Mobile Avenue 

Sauget, Illinois 62201 

Re: Notification of Incompleteness of 40 C.F.R. Part 71 Permit Renewal Application 

Dear Mr. Harris: 

The U.S. Environmental Protection Agency has reviewed the Clean Air Act (CAA) Title V 

permit renewal application that Veolia ES Technical Solutions, T.T.C., Sauget, Illinois (Veolia) 

submitted on April 9, 2013. Veolia operates under a federal Title V Permit to Operate No. V -

EL-12716300103-08-01, which EPA issued on September 12, 2008, pursuant to Title V of the 

C A A and its implementing regulations at 40 C.F.R. Part 71. Veolia's permit expires on 

October 12, 2013. Pursuant to 40 C.F.R. § 71.5(a)(l)(iii), Veolia's renewal application is 

timely. 

E PA has reviewed Veolia's Title V permit renewal application for completeness pursuant to the 

criteria in 40 C.F.R. § 71.5(a)(2), which requires, among other things, that the information in the 

application must be sufficient to evaluate the subject source and its application and to determine 

all applicable requirements. EPA has determined that Veolia's Title V permit renewal 

application is incomplete. In order for EPA to deem the renewal application complete and for 

Veolia to continue to operate under its existing permit until EPA issues a renewed permit, Veolia 

must submit the following information no later than August 1, 2013: 

1. Citation and description of all applicable requirements. Pursuant to 40 C.F.R. 

§ 71.5(c)(4), the renewal application must include: (i) citations to and descriptions of all 

applicable requirements, and (ii) a description of, or reference to, any applicable test 

method for determining compliance with each applicable requirement. Pursuant to 40 

C.F.R. § 71.5(c)(3)(vi), Veolia must identify any restrictions on source operation that 

affect emissions or any work practice standards, where applicable, for all regulated 

pollutants at the source. 

Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Recycled Paper (100% Post-Consumer) 
2. Initial compliance plan and compliance certification. Pursuant to 40 C.F.R. § 71.5(c)(8) 

and (9), Veolia must provide the facility's compliance status and compliance plan for 

each unique combination of applicable requirements and emissions units at the facility. 

You must list all compliance methods (e.g., monitoring, recordkeeping and reporting) 

you used to detennine compliance with each applicable requirement. For all 

requirements for which the source is not in compliance, you must include a compliance 

schedule. Veolia may submit the information required by 40 C.F.R. § 71.5(c)(8) and (9) 

on EPA Form 5900-86 (I-COMP), which is available at: 

http://www.epa.gov/air/oaq^s/permits/p71forms.html. 

3. Description and justification of emissions estimation methods. Pursuant to 40 C.F.R. 

§ 71.5(c)(3)(viii), Veolia must provide sample calculations and the necessary 

documentation upon which you relied to estimate emissions from each emissions unit 

(e.g., copies of relevant pages of stack test reports, AP-42 section(s), industry 

publications, etc).1 If emission factors are used, Veolia must explain whether or not more 

accurate emissions estimation methods are available for the source, and how you 

determined that the emission factors you chose are applicable to your specific source. 

See In the Matter of United States Steel Corporation - Granite City Works, Petition 

Number V -2009-03 (January 31, 2011) at 14. 

4. A listing of all active air permits and consent orders (if applicable) issued by a state or 

federal agency. EPA believes that Veolia has received several construction permits, 

andtherefore, that the information provided in Section K, Form 5900-79 (GIS) is not 

complete. For each active permit, please identify the permitting authority, the date the 

permit was issued, date of expiration (if applicable), and type of permit (e.g., 

construction, operating, etc). 

5. Process flow diagrams showing all emissions units and air pollution control equipment, 

and a plot plan showing buildings and process areas. Veolia must label the emission 

points, process equipment, air pollution control equipment, stacks and vents. 

6. A listing and description of any inapplicable requirements, for which Veolia desires a 

nonapplicability determination in the permit. Veolia must identify and include a concise 

summary of any inapplicable requirements as well as a complete explanation of why 

Veolia believes each is not applicable to your source. Pursuant to 40 C.F.R. § 71.6(f), 

EPA may only extend a pennit shield to requirements that are included and are 

specifically identified in the permit, or EPA, in acting on the permit application or 

1

 Note that the sample volatile organic material (VOM) emissions calculation provided on page 20 (Appendix A) for 

the "Drum Crusher" refers to "Summation of Pounds VO M from Column J above;" however, Column J of the table 

on Page 19 is titled "Comments." This is probably a typographical error. 

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revision, determines in writing that other requirements specifically identified are not 

applicable to the source, and the permit includes the determination or a concise summary 

thereof. 

Should Veolia wish to request confidential treatment for business information, such information 

must be submitted separately along with a claim of confidentiality as provided in 40 C.F.R. Part 

2, Subpart B. Al l confidential business information must be clearly and properly marked, and 

copies of the renewal application suitable for public inspection must be submitted. EPA will 

process all business confidentiality claims following the procedures found in 40 C.F.R. Part 2. 

Consistent with 40 C.F.R. § 71.5(d), the responsible official must certify all information Veolia 

submits in response to this request. EPA is available to meet or teleconference with you to 

clarify any of the information requested in this letter. To arrange a meeting or teleconference, or 

if you have any questions, please contact David Ogulei, of my staff, at (312) 353-0987. 

Sincerely, 

Genevieve Damico 

Chief 

Air Permits Section 

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