~ VEOLIA 

ENVIRONMENTAL 

June 13, 2013 

Mr. Stephen F. Nightingale 

Manager, Permit Section 

Bureau of Land 

Illinois Environmental Protection Agency 

1021 North Grand Avenue East 

Springfield, IL 62794-9276 

RE: Veolia ES Technical Solutions, L.L.C. 

1631210009 

40 CFR 63.1207 (e)(i) — Subpart National Emission Standards for Hazardous Air 

Pollutants for Hazardous Waste Combustors 

Comprehensive PerFormance Test Plan and Continuous Monitoring System 

Performance Evaluation Test Plan 

Dear Mr. Nightingale, 

Veolia ES Technical Solutions, L.L.C. (Veolia) is in receipt of your letter dated June 11, 2013 

regarding Veolia's upcoming Comprehensive PerFormance Test. In your letter, you state that "In 

order for the test results to be used to modify the RCRA Part B Permit issued by Illinois EPA, 

the plan must first be submitted to Illinois EPA for review and approval before the test is 

conducted." Veolia had in fact submitted, on September 5, 2012, the Comprehensive 

Performance Test Plan and Continuous Monitoring System PerFormance Evaluation Test Plan 

to Ms. Laurel Kroack and Mr. Kevin Mattison of the Illinois EPA (IEPA)for review and approval 

(cover letters and FedEx receipts attached). To date,Veolia has not received any comments 

from IEPA regarding these plans. 

These performance tests are being conducted under the requirements of the Clean Air Act 

regulations, specifically 40 CFR 63.1200 - National Emission Standards for Hazardous Air 

Pollutants for Hazardous Waste Combustors. As defined in the Federal Register Vol. 64, 

No.189, Pages 52981 and 52982, September 30, 1999, Final Rule — Final Standards for 

Hazardous Air Pollutants for Hazardous Waste Combustors, EPA states that it is "deferring 

RCRA controls on hazardous waste combustor air emissions to the Part 63 hazardous waste 

combustor MACT standards, which are ultimately incorporated into title V permits issued under 

the CAA." EPA goes on to further explain that the permittee and regulators should "work 

together to defer permit conditions governing air emissions and related operating parameters 

from RCRA to MACT compliance and title V, and to eliminate any RCRA provisions that are no 

longer needed from these permits." As a result, Veolia believes that all CAA requirements 

defined by the National Emission Standards for Hazardous Air Pollutants for Hazardous Waste 

Combustors should remain in the Title V Permit and be eliminated from the RCRA Part B 

Permit. This would also eliminate the potential of having conflicting conditions in the Part B 

Permit and Title V Permit which has occurred in the past and presents compliance challenges to 

the Facility. 

Lastly, Veolia has received comments on the CPT Plans from USEPA, Region 5 and is actively 

working with the Agency to obtain an approval. USEPA has expressed a desire and intent to 

approve these plans by July 1, 2013. Veolia has regulatory obligations that must be met in the 

#7 Mobile Avenue, Sauget, IL 62201 

(618) 271-2804 

www.veoliaes.com 
QVEOLIA 

Mr. Nightingale 

June 13, 2013 

Page 2 

near future in regards to the CPT and it is critical that this process stay on schedule to meet 

these requirements. 

If you have any questions, please call me at (618) 271-2804 or via e-mail at 

Doup.Harris2r~.Veoliaes.com. 

Sinc ly, ~ 

Doug Har s 

General Manager 

Att. 

cc: George Czerniak, USEPA, Region 5 

Ted Dragovich, IEPA, BOL 

Mary Riegle, IEPA, BOL 

Melanie Jarvis, IEPA 

EPA Corr. File 

#7 Mobile Avenue, Sauget, IL 62201 

(618) 271-2804 

www.veoliaes.com 
(D VEC)L(/a 

ENVIRQNMENTAL SERVICES 

September 5, 2012 

Mr. George Czerniak, Acting Director 

Air and Radiation Division 

Bureau of Air (Mail Code A-18J) 

United.States Environmental Protection Agency, Region 

77 West Jackson Blvd. 

Chicago, IL 60604-3507 

RE: Veolia ES Technical Solutions, L.L.C. 

Sauget, IL 

40 CFR Part 63, Subpart EEE 

Permanent Replacement Standards for Hazardous Waste Air Pollutants for 

Hazardous Waste Combustors 

Comprehensive Performance Test (CPT) and Continuous Monitoring System 

(CMS) Performance Evaluation Test Plan 

Dear Mr. Czerniak, 

Veolia ES Technical Solutions, L.L.C., a leader in the hazardous waste service industry, 

in accordance with 40 CFR 63.1207(e)(i) is notifying the Agency of our intention to 

conduct a comprehensive perFormance test and continuous monitoring system 

performance evaluation within 12 months of the compliance date. Also, in accordance 

with 40 CFR 63.1207 (e)(i), Veolia is submitting for your review a Comprehensive 

Performance Test (CPT) Plan and a Continuous Monitoring System (CMS) 

Performance Evaluation Test Plan. 

Veolia submits these CPT Plans as set forth in 40 CFR 63.1207 and 63.7 and submits 

these CMS Performance Evaluation Test Plans as set forth in 40 CF63.1207 and 63.8 

for Incinerators 2, 3 and 4. 

I certify under penalty of law that this document and all attachments were prepared 

under my direction or supervision in accordance with a system designed to assure that 

qualified personnel properly gather and evaluate the information submitted. Based on 

my inquiry of the person or persons who manage the system, or those persons directly 

responsible for gathering the information, the information submitted, is to the best of my 

#7 Mobile Avenue, Sauget, IL 62201 

(618) 271-2804 

www.veoliaes.com 
• VEOI[A 

ENVIRONfvIENTAL SERVICES 

Mr. Czerniak 

Page 2 

September 5, 2012 

knowledge and belief, true, accurate, and complete. I am aware that there are 

significant penalties for submitting false information, including the possibility of fine and 

imprisonment for knowing violations. 

Upon review of these plans, should the Agency have any questions or a need for 

additional information, please contact David Klarich or Dennis Warchol at (618) 271- 

2804. 

Nothing contained herein shall be deemed a waiver of the objections set forth in 

Veolia's July 23, 2012 and August 8, 2012 correspondence (collectively 

"Correspondence") to Ms. Eileen L. Furrey, which is aftached hereto as Group Exhibit A. 

Veolia hereby adopts and incorporates the Correspondence along with such objections 

contained therein as if set forth entirely herein. 

Sincerely, 

Doug is 

General anager 

Enclosure 

#7 Mobile Avenue, Sauget, IL 62201 

(618)271-2804 

www.veoliaes.com 
\/EOlIA 

ENVIRONMENTAL SERVICES 

September 5, 2012 

Ms. Laurel Kroack 

Bureau Chief 

Bureau of Air 

Illinois Environmental Protection Agency 

1021 N. Grand Ave. East 

Springfield, IL 62794-9276 

RE: Veolia ES Technical Solutions, L.L.C. 

Sauget, IL 

40 CFR Part 63, Subpart EEE 

Permanent Replacement Standards for Hazardous Waste Air Pollutants for 

Hazardous Waste Combustors 

Comprehensive Performance Test (CPT) and Continuous Monitoring System 

(CMS) Performance Evaluation Test Plan 

Dear Ms. Kroack, 

Veolia ES Technical Solutions, L.L.C., a leader in the hazardous waste service industry, 

in accordance with 40 CFR 63.1207(e)(i) is notifying the Agency of our intention to 

conduct a comprehensive performance test and continuous monitoring system 

performance evaluation within 12 months of the compliance date. Also, in accordance 

with 40 CFR 63.1207 (e)(i), Veolia is submitting for your review a Comprehensive 

Performance Test (CPT) Plan and a Continuous Monitoring System (CMS) 

Performance Evaluation Test Plan. 

Veolia submits these CPT Plans as set forth in 40 CFR 63.1207 and 63.7 and submits 

these CMS Performance Evaluation Test Plans as set forth in 40 CF63.1207 and 63.8 

for Incinerators 2, 3 and 4. 

I certify under penalty of law that this document and all attachments were prepared 

under my direction or supervision in accordance with a system designed to assure that 

qualified personnel properly gather and evaluate the information submitted. Based on 

my inquiry of the person or persons who manage the system, or those persons directly 

responsible for gathering the information, the information submitted, is to the best of my 

#7 Mobile Avenue, Sauget, IL 62201 

(618)271-2804 

www.veoliaes.com 
VEOtIA 

ENVIRONMENTAL SERVICES 

Ms. Kroack 

Page 2 

September 5, 2012 

knowledge and belief, true, accurate, and complete. I am aware that there are 

significant penalties for submitting false information, including the possibility of fine and 

imprisonment for knowing violations. 

Upon review of these plans, should the Agency have any questions or a need for 

additional information, please contact David Klarich or Dennis Warchol at (618) 271- 

2804. 

Nothing contained herein shall be deemed a waiver of the objections set forth in 

Veolia's July 23, 2012 and August 8, 2012 correspondence (collectively 

"Correspondence") to Ms. Eileen L. Furrey, which is attached hereto as Group Exhibit A. 

Veolia hereby adopts and incorporates the Correspondence along with such objections 

contained therein as if set forth entirely herein. 

Sinc rely, 

Doug Ha is 

General Manager 

Enclosure 

#7 Mobile Avenue, Sauget, IL 62201 

(618)271-2804 

www.veoliaes.com 
VE®L!A 

ENVIRONMENTAL SERVECES 

September 5, 2012 

Mr. Kevin Mattison 

Bureau of Air 

Illinois Environmental Protection Agency 

9511 W. Harrison 

Des Plaines, IL 60016 

RE: Veolia ES Technical Solutions, L.L.C. 

Sauget, IL 

40 CFR Part 63, Subpart EEE 

Permanent Replacement Standards for Hazardous Waste Air Pollutants for 

Hazardous Waste Combustors 

Comprehensive Performance Test (CPT) and Continuous Monitoring System 

(CMS) Performance Evaluation Test Plan 

Dear Mr. Mattison, 

Veolia ES Technical Solutions, L.L.C., a leader in the hazardous waste service industry, 

in accordance with 40 CFR 63.1207(e)(i) is notifying the Agency of our intention to 

conduct a comprehensive performance test and continuous monitoring system 

performance evaluation within 12 months of the compliance date. Also, in accordance 

with 40 CFR 63.1207 (e)(i), Veolia is submitting for your review a Comprehensive 

Performance Test (CPT) Plan and a Continuous Monitoring System (CMS) 

Performance Evaluation Test Plan. 

Veolia submits these CPT Plans as set forth in 40 CFR 63.1207 and 63.7 and submits 

these CMS Performance Evaluation Test Plans as set forth in 40 CF63.1207 and 63.8 

forincinerators 2, 3 and 4. 

I certify under penalty of law that this document and all attachments were prepared 

under my direction or supervision in accordance with a system designed to assure that 

qualified personnel properly gather and evaluate the information submitted. Based on 

my inquiry of the person or persons who manage the system, or those persons directly 

responsible for gathering the information, the information submitted, is to the best of my 

#7 Mobile Avenue, Sauget, IL 62201 

(618) 271-2804 

wwW.veoliaes.com 
vEOlfA 

CNVIRONfv1ENTAL SERVICES 

Mr. Mattison 

Page 2 

September 5, 2012 

knowledge and belief, true, accurate, and complete. I am aware that there are 

significant penalties for submitting false information, including the possibility of fine and 

imprisonment for knowing violations. 

Upon review of these plans, should the Agency have any questions or a need for 

additional information, please contact David Klarich or Dennis Warchol at (618) 271- 

2804. 

Nothing contained herein shall be deemed a waiver of the objections set forth in 

Veolia's July 23, 2012 and August 8, 2012 correspondence (collectively 

"Correspondence") to Ms. Eileen L. Furrey, which is attached hereto as Group Exhibit A. 

Veolia hereby adopts and incorporates the Correspondence along with such objections 

contained therein as if set forth entirely herein. 

Sinc rely, ~ 

CU~{~ 

Doug H is 

General Manager 

Enclosure 

#7 Mobile Avenue, Sauget, IL 62201 

(618)271-2804 

www.veoliaes.com 
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CENNIS WARCHUL 

VEULIA ENVIRONMENTAL SERVICES 

7 MOBILE AVENUE 

EASTSAINTLOUISILfi2201 US 

Reci ien 

Ms. Laurel Kroack, Bureau Chie 

II EPA, Bureau of Air 

1021 n. Grand Ave. East 

SPRIN6FIELC IL 62794 US 

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PackageType FedExBox 7NIOBILEAVENUE 

Zone 03 EASTSAINTLOUISILfi2201 US 

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ServiceType FedExStandardOvernlght VEOLIA ENVIRONMENTAL SERVICES 

PackageType FedExBox 7M081LEAVENUE 

Zone 03 EAST SAINT LOUIS IL 62201 US 

Packages 1 

Rated Weight 4.016s, 1.8 kgs 

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.Recioient 

Mr. Kevin Mattison, Bureau of 

II EPA 

9511 W. Harrison 

DES PLAINES IL 60016 US 

Recipie nt 

GEORGE CZERNIAK, Acting Direct 

US EPA, Regian 5 

77 WEST JACKSON A-18J 

CHICAGO IL 60604 US