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Veolia Environmental Services Air Permit

Sauget, Illinois January 2013

U.S. EPA Proposes to Revise

Title V Air Permit

What can you do?

 Submit written comments

to U.S. EPA regarding the 

draft permit during the 

comment period that runs 

for 45 days from _____ to 

_____. Comments should 

include factual grounds and 

supporting material or 

references.

 Attend the public hearing

on Feb. 19, 2013, at the 

Southern Illinois University 

Edwardsville – East St. 

Louis Higher Education 

Campus, 601 James R. 

Thompson Blvd., East St. 

Louis, Distance Learning 

Lab, Building B, Illinois, 

from 3 p.m. to 7 p.m. See 

more details on the 

comment period and 

meeting on the back page.

 Go on a tour. Veolia will 

be offering facility tours. To 

arrange a tour contact Doug 

Harris or Dennis Warchol at 

618-271-2804.

 Review the statement of 

basis and draft permit.

The statement of basis

provides more information 

and explains the legal and 

factual basis for the permit 

conditions. The draft Title V 

permit includes all of the 

requirements the source is 

legally obligated to follow. 

Only portions of the permit 

that are being changed 

because of the proposed 

action are currently open for 

comment during the 

comment period. See Page 3

for locations where you can 

view these documents.

The U.S. Environmental Protection Agency is proposing to revise parts of

a Clean Air Act permit for a controversial hazardous waste incinerator in 

Southern Illinois. U.S. EPA received and reviewed an application from 

Veolia Environmental Services, 7 Mobile Ave., Sauget, Illinois, near St. 

Louis, to modify its Clean Air Act Title V operating permit. The permit 

would add “feedrate” limits for certain heavy metals. Feedrate limits are 

the maximum amount of heavy metals Veolia can feed into the incinerator 

per hour. The heavy metals include mercury, arsenic and lead.

U.S. EPA determined the requested limits are unacceptable and proposes 

to revise the permit to incorporate more stringent feedrate limits. U.S. EPA

experts say the lower limits are supported by available performance test 

data and comply with applicable regulations. Veolia is currently operating 

the incinerator and will not have to shut down because of this permitting 

action. The Agency will not issue a final permit until after the public has a 

chance to comment. See the left-hand box and read Page 3for information 

about the public participation process for this proposed permit.

Background

The Clean Air Act requires sources that emit large amounts of air pollution 

to obtain an operating permit, also known as a Title V permit, after the 

source has begun to operate. This permit is designed to improve 

compliance by clarifying what facilities must do to control air pollution. 

Typically, Illinois Environmental Protection Agency is responsible for 

issuing Title V permits in Illinois. However, in this case U.S. EPA is the 

permitting authority because of past court action. In 2005 environmental 

groups petitioned U.S. EPA to object to the issuance of a proposed Title V 

permit for Veolia. The federal Agency ordered Illinois to revise the permit 

within 90 days. Because the state did not do so in a timely manner, the 

Sierra Club and American Bottom Conservancy sued U.S. EPA, alleging it 

had a duty to issue the permit. The federal Agency issued the Title V 

permit to Veolia on Sept. 12, 2008. The permit required Veolia to submit a 

significant modification application to incorporate heavy metal feedrate 

limits. In March 2010, Veolia submitted its application to modify the 

permit. U.S. EPA is now proposing to deny the requested permit 

modifications because they do not meet Clean Air Act standards and at the 

same time proposing tougher feedrate limits.

Burning hazardous waste

Specially designed incinerators, boilers, and industrial furnaces can burn 

hazardous waste. Hazardous waste – which is toxic, flammable, corrosive 

or reacts with other materials – can be produced by businesses or 

manufacturing operations. Burning hazardous waste is one way to safely 

manage it. Burning reduces waste volume by converting solids and liquids 

to ash while destroying toxic organic compounds. In addition, disposal of 

the ash in a landfill is safer and more efficient than disposal of untreated 

hazardous waste. The ash generated from hazardous waste combustion 
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must be tested, and, if found to be hazardous, must be 

treated for remaining toxicity before it is disposed of in 

a landfill.

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

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

hazardous waste in both liquid and solid forms. Liquid 

waste may be stored in a tank farm prior to being 

burned. The tanks release fugitive emissions, and 

carbon adsorption units are attached to each tank to 

help control these emissions. Bulk solid wastes are 

stored in four pits in a building prior to combustion. 

The building is maintained at negative pressure so 

emissions don’t escape from the building. Before the 

waste is burned it is packaged into more manageable 

containers and any liquids are absorbed.

Each combustor has a primary and secondary 

combustion chamber that includes natural gas-fired 

auxiliary burners used during startup, shutdown, 

malfunctions and for additional heat input. The 

combustors are also connected to spray dryer absorbers 

and a baghouse, which help to control air pollution. 

Combustor #4 also has a tempering chamber and 

activated carbon injection to further help control air 

pollution. Emissions are constantly monitored for 

carbon monoxide and hydrogen chloride.

The combustors are supported by a lime handling 

system and an ash handling system. The lime handling 

system supports 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. 

Pollutants affected by the permit

The proposed permit action sets feedrate limits for 

mercury, semi-volatile metals such as cadmium and 

lead, and low-volatile metals such as arsenic, beryllium, 

and chromium. Volatility is a measure of how readily a 

substance changes from a solid or liquid to a vapor. 

These pollutants have known negative health effects. 

U.S. EPA is setting feedrate limits in this action that 

comply with applicable federal regulations. More detail 

about each of these pollutants can be found in the 

statement of basis. Information on how to review the 

statement of basis is found on the last page.

Setting the limits

Veolia established the heavy metal feedrate limits for 

which it applied by extrapolating the results of 

comprehensive performance tests performed in August 

and September 2008 to higher metal feedrates, as 

allowed by federal regulations. Veolia then requested 

U.S. EPA incorporate the extrapolated feedrates into 

the Title V permit. Veolia has requested feedrate limits 

that are three times higher than the performance test 

feedrates.

U.S. EPA experts do not believe extrapolation is 

appropriate for mercury because the requested limits

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

follow similar principals. 
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could result in violations of other applicable federal 

requirements and sufficient information was not 

provided to determine how the increased mercury 

feedrates would affect the operation of pollution control 

devices. Additionally, since wastes containing mercury 

were spiked during comprehensive performance testing 

(that is, a chemical compound containing mercury was 

intentionally added to the waste that was fed into the 

combustor), U.S. EPA staff believes the amount of 

mercury that was spiked plus the mercury already 

present in the waste is sufficient to set the feedrate limit 

without extrapolation. Therefore, U.S. EPA is 

proposing to deny Veolia’s application to modify its 

Title V permit, and incorporate into Veolia’s Title V 

permit as mercury feedrate limits the feedrates at which 

Veolia conducted its 2008 testing. 

The federal Agency is also proposing to deny the higher 

semi-volatile and low-volatile metal feedrates requested 

by Veolia and at the same time incorporate tougher 

limits into the permit. The limits Veolia requested were 

more than twice the reported historical feedrates. 

Because of the denial of the application, U.S. EPA is 

issuing a Notice of Intent to Deny, known as a NOID, 

to Veolia in addition to proposing revisions to the Title 

V permit.

Monitoring

In the proposed revisions to the Title V permit, Veolia 

will be required to install and operate a multi-metals 

continuous emissions monitoring system (CEMS) on 

one of the most polluting incinerators (Unit #3) for at 

least one year. A multi-metals CEMS tests the air 

emitted during the incineration process to determine the 

amount of mercury, semi-volatile metals and lowvolatile metals in the air, and reports the results 

approximately once every fifteen minutes. The test 

results will help U.S. EPA ensure the feedrate limits are 

adequate to protect air quality. After a year of running 

the CEMS, U.S. EPA staff believes it will have enough 

information to determine if the feedrate limits are 

appropriate and Veolia will then no longer be required 

to use the multi-metals CEMS.

Public participation

You can participate in the decision-making process on 

the permit by submitting statements during the public 

comment period XXX to XXXX or at the public 

hearing Feb. 19 in East St. Louis (see front page box).

All written comments must be postmarked or emailed 

no later than ________. All comments received within 

the public comment period will be considered before 

U.S. EPA makes a final decision on the proposed 

action. Your comments should include your name and 

address and all reasonable references, factual grounds, 

and supporting material. Be sure to include your name 

and address if you would like to receive notification of 

U.S. EPA’s final decision regarding the permit and its 

responses to comments submitted during the public 

comment period. 

Comments can be submitted:

 Via the Internet at the www.regulations.gov/

website at Docket ID No. U.S. EPA-R05-

OAR-2012-0649 or at

www.epa.gov/region5/newsevents/ and look 

in the “public comment” section.

 Mail to George Czerniak, U.S. EPA, 77 W. 

Jackson Blvd. (A-18J), Chicago, IL 60604.

 Email to David Ogulei at 

ogulei.david@epa.gov.

At the Feb. 19 public hearing you will be invited to 

present any comments or concerns you have about the 

proposed changes. The federal Agency is required to 

consider all comments and respond to all relevant 

comments. A signup sheet will be available at the 

public hearing for those who are interested in 

presenting oral testimony and spots will be available to 

present on a first-come/first-serve basis. 

Each speaker will be limited to 5 to 10 minutes 

depending on the number of presenters. The U.S. EPA

representative may ask clarifying questions during the 

oral presentations but will not respond to the comments

at that time. If you require translation services or 

special accommodations for the public hearing contact 

U.S. EPA’s David Ogulei at ogulei.david@epa.gov.

View the documents

The actual draft permit and another document called a 

statement of basis that provides information from 

which the decision was made can be reviewed at:

 The www.regulations.gov/ website at Docket 

ID No. U.S. EPA-R05-OAR-2012-0649 or at

www.epa.gov/region5/newsevents/ and look 

in the “public comment” section.

 Central Express Library, Suite 160, 815 

Olive St, St. Louis, MO 63101.

 East St Louis Library, 5300 State St., East St 

Louis, IL 62203.

 Cahokia Public Library, 140 Cahokia Park 

Drive, East St Louis, IL 62206