### 1 

### Veolia Environmental Services Air Permit
Sauget, Illinois January 2013 

# U.S. EPA Proposes to Revise

Title V Air Permit

What can you do?

 S ubmit 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 , 201 3

, at the

Southern Illinois Univers ity

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 Do ug Harris or Dennis Warchol at

618

- 271

- 2804.

 Review the statement of

b asis and d raft p ermit.

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 P age 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 Cl ean 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 P age 3 for i nformation 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. Beca use 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 standar ds 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 react s with other materials

– can be produced by businesses or manufacturing operations. Burning hazardous waste is one way to safely manage it. Burning reduces waste volu me 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

### 2 mu st 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

e missions don’t escape from the building. Before the

waste is burned it is pa ckaged into more manageable containers and any liquids are absorbed.

Each combustor has a primary and secondary

combustion chamber that include s natural gas

- fired auxiliary burner s 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 inje ction t o further help control air pollution. Emissions are co nstantly 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 a bsorber, 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.



### P ollutants 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.

T hese 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 principal s.

### 3 could result in violations of other applicable federal requirements and sufficient information was not provided to determine how the increased mercury

fe edrates 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 w as 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 applica tion 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 m etal 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 Notic e 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 low

volatile metals in the air, and report s 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 determi ne 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 emai led 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 g rounds, 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 dur ing 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.

 E mail 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 a sk clarifying questions during the oral presentations but will not respond to the comments

a t 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:

 T he www. regulations

. gov / web site 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