# ~ VEOLIA
ENVIR O NMENTAL
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

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Recipie nt GEORGE CZERNIAK, Acting Direct US EPA, Regian 5 77 WEST JACKSON A-18J CHICAGO IL 60604 US